Detailed entries (73)
Series of EDTA chromatography slides used with Dr. Rieders and Agent Martz. During an admissibility hearing, the prosecution withdrew objections to slides A through L, had no objection to O, requested removal of the box showing Q207's location from P, and deferred consideration of Q and later slides to the afternoon session.
Two LC-MS/MS chromatogram runs of Q206, the sock edge cutting: run 4088 (Defense 1259-A; Defendants' 1215) and run 4094 (Defense 1259-B; Defendants' 1216). The candidate rows describe the first as showing EDTA present and the second as a confirmatory positive run; Martz confirmed peaks consistent with EDTA parent and daughter ions.
Combined charts depicting full daughter-spectrum runs for the sock and rear-gate evidence stains, formally marked as People's 543-E, 543-F, 544-E, and 544-F and referenced as the basis for Martz's inability to identify EDTA.
Four graphs depicting LC-MS/MS testing of the Q206 sock evidence blood in positive ion mode, showing attempted detection of the 160 daughter ion and the full daughter spectrum, plus known EDTA control samples on sock substrate. Interpreted by Martz as showing no EDTA daughter spectrum in the evidence blood.
A two-page letter dated February 16, 1995, from prosecutor Rockne Harmon to FBI Agent Roger Martz concerning EDTA testing of sock and back-gate samples and asking Martz to “refute the possibility” of planted blood. Identified as Defense 1263 in the criminal trial and Defendants' 1223 in the civil trial, the letter was used by the defense in advancing an argument about bias in the testing request.
K67 and K68, known EDTA-preserved reference blood samples from O.J. Simpson and Nicole Brown Simpson used as positive controls in Roger Martz's EDTA testing. Testimony described them as producing strong EDTA signals, including a large 160-ion abundance.
Graphs of Martz's own blood tested with and without EDTA on May 11, 1995, introduced and discussed as a baseline comparison.
People's 544 graph series documenting Roger Martz's LC-MS/MS testing of rear-gate blood Q204 and a preserved-blood control. The series included graphs 544-A through D and chart 544-E; Martz, Robert Blasier, and Marcia Clark offered differing interpretations of the displayed signals, and Martz testified that related raw full-daughter-spectrum data had not been retained in printed form.
Chromatograms of a 50-parts-per-million EDTA standard run on February 22 at 9:32 AM (discovery page 4077; ion count 319,561; Defense 1262-A) and 1:48 PM (discovery page 4070; ion count 49,393; Defense 1262-B). They were compared during testimony to demonstrate variation in the instrument's ion counts.
Photograph of purple-top blood-collection tubes containing EDTA, identified as exhibit 1258. Martz described two pictured tubes as containing blood from Simpson and Nicole Simpson, while stating that he assumed the latter was collected at autopsy.
Quantico information concerning EDTA extraction efficiency. Martz said it reported that very little EDTA remained in the second extract but did not state a precise percentage.
Graphs of known FBI laboratory blood samples from 1993 containing EDTA, introduced to show EDTA stability over time and the strong signal produced by known preserved samples as a comparator to the evidence stains.
Graphs of Martz's own blood tested with and without EDTA on July 22, 1995, introduced and discussed to confirm the May results.
A defense-prepared chart purporting to compare EDTA ion count levels between preserved blood and the evidence stains, displaying same-day measurements on what Blasier labeled as 'the 28th.' Martz testified it did not reflect any test he conducted or any result he obtained; Clark objected that it misrepresented data from two different days.
A graph of a gate swatch to which known EDTA-preserved blood had been applied as a positive reference. It was discussed during Martz's testimony and later displayed in criminal closing argument in contrast with 544-e.
Plaintiffs' 2294, a chart prepared by Terry Lee of the City of Hope comparing the large positive-ion signal from known EDTA-preserved purple-top-tube blood with the trace signal from evidence-sample blood identified as K206/Q206. The contrast was described as a "mountain" versus a "molehill." The chart was displayed during Dr. Fredric Rieders's examination subject to a foundation requirement and later displayed and explained during Terry Lee's testimony.
Plaintiffs' Exhibit 2404, a comparison chart for evidence sample Q204 introduced and discussed during Terry Lee's civil-trial testimony and admitted into evidence as an exhibit from Lambert's examination of Dr. Lee.
Composite slides displaying both Q206 sock stain chromatograms together, used with Dr. Rieders for jury visualization. Defense 1257-Q shows the combined display; Defense 1257-R is the same composite with EDTA peaks highlighted.
A 1954 Foreman and Trujillo study using radioactively labeled EDTA administered to human subjects to examine oral absorption and pharmacokinetics. Rieders and Martz cited it in their dispute over baseline EDTA levels and dietary absorption; its last page was displayed as Defense 1268 during examination of Martz.
Dr. Fredric Rieders' two-page report dated July 17, 1995, evaluating Agent Roger Martz's EDTA test results for the gate and sock stains. Introduced as People's 586, the report and its disclosure timing were disputed, and prosecutors used its documentation of one parent and one daughter ion to challenge Rieders' later testimony about a full daughter spectrum.
Excerpts from Roger Martz's criminal-trial testimony at page 38641, page 38649, and pages 38711–38712. They were referenced in later proceedings for foundation and impeachment concerning whether Martz's methods were quantitative and regarding his Quantico validation-study testimony; the page 38649 transcript was identified as Criminal Defense Exhibit 1264.
A slide comparing the can positive control, at approximately 3 million ion count, with the gate evidence stain, at approximately 221,000, from the same day. Blasier used it to argue that the difference was about 14-fold rather than 1,000-fold.
Chart prepared by Roger Martz comparing EDTA-related measurements across evidence samples and preserved reference blood. Marcia Clark used it to emphasize an approximately hundredfold difference, while Robert Blasier challenged its “ion count” label because the chart used peak area.
A paper introduced as People's 537 and used with both Dr. Rieders and Agent Martz regarding EDTA concentration levels, described variously as a one-page EPA report and as an abstract from the British Veterinary Journal. Martz characterized it as being about food preservation rather than human blood levels and 'completely out of context.' Rieders had previously cited the contested 2 mg/ml figure contained within it.
FDA Title 21 regulation listing foods in which EDTA was permitted as an additive, including carbonated soft drinks, mayonnaise, dressings, frozen potatoes, and cereals. It was introduced during Dr. Rieders' cross-examination to show that EDTA is commonly ingested and later used to contextualize a 50-milligram-per-day dietary figure.
Demonstrative slide illustrating fragmentation of the 293 parent ion into 160 daughter ions by the mass spectrometer. It was used during Dr. Rieders' direct examination and revisited on cross-examination to question whether the full daughter spectrum appeared in the stain evidence.
Photograph of five-microliter blood drops prepared by Agent Martz on two different substrates, used to establish the minimum detectable amount of bloodstain and to contextualize the quantity used in testing.
A full daughter-ion scan chromatogram of Q206 spanning mass range 130–295, described as broader and less focused than prior runs. It was introduced during Dr. Rieders's direct examination and later used on cross-examination to question whether the 132-ion signal rose meaningfully above noise.
Red bar chart prepared by Martz summarizing the July 22 EDTA analysis of a blank, known standards, 1993 stains, and Martz's blood with and without EDTA. During questioning, Martz agreed that ion counts varied approximately four-fold that day and described the variance as unusually large.
An additional EPA paper discussed during cross-examination of Dr. Rieders concerning whether the 2 mg/ml EDTA concentration standard derived from animal rather than human studies.
An article on food iron absorption and EDTA's effect on dietary iron uptake, used for a dietary figure of 50 milligrams per day.
A bar chart derived from FBI paperwork showing EDTA ion counts for multiple samples including the blood-stained dress swatch (K65) and the unstained dress swatch (K65C), introduced and displayed on the Elmo projector during Dr. Rieders' testimony.
A chart containing the mass spectrum of Benfluralin, an untested chemical that Martz had been told was an environmental contaminant with some mass-spectrum properties similar to EDTA. Martz testified that he learned of it by telephone that morning and had never tested it.
Page 49 of the Cambridge Isotope Laboratories 1994–1995 stable-isotopes catalogue, which appeared to list an EDTA internal standard usable in Martz's testing. Martz discussed listed prices of $690 and $115.
Demonstrative slide illustrating the general principle of chromatographic separation as part of Dr. Rieders' LC-MS/MS educational series for the jury.
Demonstrative slide with a color-coded diagram (red square for EDTA, green and yellow for other compounds) illustrating the separation of analytes through the chromatography column.
A chart originally labeled 'Operator blood, no EDTA added, red top' that was subsequently corrected by hand after Martz failed to update the label between test runs. Introduced by Blasier to demonstrate a sample labeling error.
Memo by prosecutor Denoce describing alleged conversations with Dr. Rieders about reconciling his oleandrin findings with Dr. Henion's negative results. It was marked for identification and used in attempted impeachment; Rieders denied its contents.
A memo from prosecutor Kevin Denoce to Michael Bradbury and Harvey Giss. Clark attempted to introduce it, but the transcript ends when Blasier objected and requested a sidebar; the memo's contents are not stated.
Dr. Terry Lee's handwritten notes including observations that EDTA interpretation was 'problematic' and a notation about finding a 'convincing argument' if the blood was not planted. Marked for identification and read from during Baker's cross-examination to challenge Lee's objectivity.
Demonstrative slide showing the full chemical name and molecular structure of EDTA (ethylenediamineacetic acid), introduced by Dr. Rieders and displayed to the jury as part of the EDTA educational slide series.
Demonstrative slide showing EDTA's molecular weight of 292 and the corresponding parent ion at mass 293, used to explain the mass spectrometry detection approach during Dr. Rieders' testimony.
Graph of EDTA-preserved reference blood used as a positive control for the sock EDTA testing, contrasted with the actual sock evidence results to show what an EDTA-positive result should look like.
A document faxed directly from the EPA containing the same 2 mg/ml EDTA concentration figure as People's 537, introduced to corroborate the underlying report and confirm the contested number was not a transcription error in Rieders' copy.
Demonstrative slide related to the FBI's testing of specific stain swatches, introduced as part of the EDTA educational slide series with Dr. Rieders.
Demonstrative summary slide listing the five detection parameters used by Dr. Rieders to identify EDTA in the mass spectrometry data, constituting the criteria for a positive identification.
A full daughter-spectrum chart labeled “Control for dress for K65 dress.” Blasier introduced it to argue that the 132-ion signal barely exceeded the noise level and to challenge Martz's EDTA-identification standard.
Graph of actual evidence blood extracted from the sock (Q206) tested for EDTA, confirmed by Martz as the result he actually obtained, showing no EDTA signal.
Demonstrative slide used to display ion count data for cross-reference with the 50 ppm standard chromatograms (Defense 1262-A and 1262-B), part of the Rieders EDTA slide series.
Roger Martz's February 19, 1995 bar graph of negative-ion LC-ES-MS/MS results, showing large peaks for known samples and no EDTA detected in evidence samples. It was displayed during redirect to confront Dr. Rieders about test results he had forgotten.
A chart dated February 23, 1995, presenting Martz's HPLC results showing no EDTA in the evidence samples. When it was introduced, Dr. Rieders disputed Lambert's characterization of the HPLC test's purpose.
Graph showing ion counts comparing K67 and K68 reference EDTA-preserved blood (high EDTA signal) against Q204 and Q206 evidence stains (no EDTA signal) and a 100 ppm standard, introduced and discussed extensively during Agent Martz's testimony.
Six charts from Martz's positive-ion LC-ES-MS/MS analysis, including chromatographs for sock-blood item Q206 and positive control K67. The set was displayed during Rieders's testimony and was the subject of extended cross-examination.
Demonstrative slide illustrating the first stage of the tandem mass spectrometer's ion-weighing and filtering function, introduced during Dr. Rieders' explanation of the LC-MS/MS methodology.
Demonstrative slide showing the first mass spectrometer filter stage allowing only the 293 parent ion to pass, as part of the EDTA detection methodology explanation.
A photograph of the label used on the EDTA serology tube, introduced and discussed during Dr. Lakshmanan's testimony.
A photograph of Q207, a swatch from the cut-out sock-stain area sent to the FBI. It was introduced and displayed during Martz's testimony.
A printed hardcopy of an EDTA test results chart that had previously been displayed on screen during Dr. Rieders' testimony, marked for identification.
A composite slide displaying both Q204 back-gate chromatograms, introduced with Dr. Rieders for comparison.
A chart labeled 'control from Q204,' designated as a negative control but showing EDTA presence. Dr. Rieders opined that the positive and negative labels had been accidentally switched.
Billing document on Dr. Rieders' company letterhead submitted to the prosecution in the Sconce case, referencing examination and shipment of tissue samples to Dr. Henion. It was introduced to challenge Rieders' memory of the tissue chain of custody.
A compilation of six EDTA charts collectively summarizing stain and control results, introduced during Dr. Rieders's civil-trial testimony.
Demonstrative slide showing the second mass spectrometer filter stage isolating the 160 daughter ion for final measurement and quantitation.
Demonstrative slide showing the second mass spectrometry stage used to detect the 160 daughter ion produced by fragmentation of the 293 parent ion.
A second photograph from Agent Martz's dilution experiment, with substrate and blood quantity unrecorded. Objection to its admission was sustained and it was not shown to the jury.
Summary bar chart of HPLC results from February 23rd showing all samples alongside a 5 ppm EDTA standard, introduced to visually summarize the third round of testing confirming the absence of EDTA in the evidence samples.
A summary bar chart of some or most February 22 LC-MS/MS results, omitting blanks and including K67 and K68 reference samples, Q206 sock evidence, Q204 gate evidence, and K65 dress material. Martz used it to illustrate the response difference between preserved and non-preserved blood.
Slide showing ion-count charts for two positive controls run on different days: a cloth swatch at approximately 8 million and a metal can at approximately 3 million. It was introduced to highlight the roughly three-fold difference between the controls.
Blood drawn from FBI Agent Roger Martz and tested both with and without added EDTA across multiple sessions (May 11 and July 22, 1995) to establish a baseline and validate his extraction methods. Martz's unpreserved blood showed EDTA in the parts-per-million range, which Dr. Rieders characterized as 'absurd' and which Clark argued undermined Rieders' conclusion. The same results were cited to show a similar parent/daughter ion profile to the gate and sock evidence stains.
General results and methodology from Agent Roger Martz's FBI EDTA testing, discussed in criminal and civil proceedings. Civil closing arguments characterized the testing as producing two positive results before testing stopped and alleged that Martz erased a computer run and misrepresented a blood comparison.
K65 was a blood-stained swatch from Nicole Brown Simpson's dress, while K65C was an unstained swatch used for comparison. Rieders noted a higher EDTA quantity in K65 but cautioned that concentration could not be inferred without sample size; Martz said EDTA detected on the dress was possibly associated with the garment or its dye and did not attribute the small difference between the swatches.
Technical literature from Finnegan and Hewlett Packard on MS/MS instrumentation and single parent/daughter ion identification standards, referenced by Rieders to defend his identification methodology. Clark requested Rieders produce them; Rieders was unable to locate them over the lunch break.
The typed report Dr. Rieders submitted in the Sconce case documenting his oleandrin findings, shown to the witness by Clark to establish that oleandrigenin was not included in the formal report.
Additional references (39)
Brief references from transcripts that don't warrant an individual page. Each has a single source or is mentioned only in passing.
- 1993 EDTA Validation Bloodstain Swatches — Laboratory bloodstain swatches from 1993 that Martz tested to demonstrate that EDTA remains detectable in aged preserved blood.
- Agent Martz FBI EDTA testing reports — FBI reports documenting Agent Martz's EDTA testing, referenced as the underlying data analyzed by Dr. Rieders and requiring foundation testimony from Martz.
- Agent Martz's EDTA degradation experiment — Dr. Martz's degradation experiment, referenced by Rieders as an exception to his statement that no experimental literature existed on EDTA degradation in the relevant substances.
- Ahlerich routing slip to Murch — 'performance issue, not misconduct' — One-page routing slip from Ahlerich to Randy Murch stating, 'I view this as a performance issue, not misconduct. Please give me your recommendations.' It was introduced to the court.
- Blood swatches proposed for FBI EDTA testing — Biological-evidence blood swatches that the prosecution sought to retain for FBI EDTA testing before defense access.
- Bloodstains 47, 50, and 78 — transmitted through Rieders to Dr. Ballard — Bloodstains 47, 50, and 78, transmitted through Dr. Rieders to Dr. Ballard. Clark attempted to introduce them, but an objection was sustained as beyond the scope of direct examination.
- Bundy gate and bedroom sock EDTA samples — Blood from the Bundy gate and bedroom sock discussed during Dr. Rieders's recross-examination through EDTA concentration comparisons.
- Bundy rear gate paint and rust as EDTA-testing variables — The rear gate at 875 South Bundy was discussed for its paint surface and rust as potential variables in EDTA degradation. The questioning noted that no defense expert had conducted experiments under those conditions.
- Carl Selavka sworn declaration (National Medical Services) — Sworn declaration from Carl Selavka of National Medical Services denying that he told Agent Martz about defense EDTA testing activities, submitted by the defense in the criminal proceedings.
- Defense subpoenas to FBI and Department of Justice / Office of Inspector General — Two sets of two defense subpoenas served on the FBI and the Department of Justice Office of Inspector General, requesting laboratory records, personnel files, and case documents. The federal government filed a responsive brief with an in-camera submission to the court.
- Defense supplemental witness list — listing Dr. Fredric Rieders — A defense supplemental witness list originally dated March 13th, with that date crossed out and rewritten as March 17th, listing Dr. Fredric Rieders. Harmon questioned its authenticity because the court had no record of it and suggested that it might be fraudulent or backdated.
- Dr. Kevin Ballard's published GC-based EDTA quantification methodology — Dr. Kevin Ballard's published methodology for gas chromatography-based EDTA quantification using a radioactive carbon-label internal standard. Discussed extensively in civil trial; plaintiff's counsel argued that Simpson's defense could have sought definitive quantitative EDTA testing using Ballard's approach but did…
- Dr. Lee's notes organizing EDTA analytical possibilities — Two paragraphs of notes written by Dr. Lee organizing the EDTA analytical possibilities. They were reread in full context during F. Lee Bailey's redirect after only one paragraph had been read on cross-examination.
- Dr. Rieders sworn declaration denying unsolicited Harmon contact — Sworn declaration submitted by Dr. Fredric Rieders of National Medical Services, denying that he made unsolicited comments to prosecutor Harmon about EDTA testing, submitted by the defense in the criminal proceedings.
- Dr. Rieders' billing records and lab time sheets submitted to defense — Rieders' billing records and laboratory time sheets submitted to the defense, requested by Clark to establish the hours worked and the financial relationship between Rieders and the defense team.
- Dr. Rieders' fax letter to LAPD's Hanukahs on EDTA testing — A letter faxed by Dr. Rieders to Leonard Hanukahs at LAPD after a January contact, inviting further discussions on EDTA testing. Introduced by the prosecution in the criminal proceedings to show the collegial and voluntary nature of expert contacts between Rieders and law enforcement.
- EDTA mass-spectrometer test graphs — Graphs generated from mass-spectrometer testing of bloodstain samples for EDTA and discussed as representations of the test results.
- EDTA photodegradation study — Neckar River iron-chelate form — A published scientific study on the photodegradation of EDTA in the Neckar River (Germany) in its iron-chelate form, referenced by Dr. Rieders to support his argument that EDTA degrades under environmental conditions. The prosecution objected to its introduction as irrelevant.
- EPA and FDA records on dietary EDTA levels in human blood — EPA and FDA records concerning dietary EDTA levels in human blood, referenced as a basis for Dr. Rieders's expert opinion.
- EPA study on EDTA environmental tolerances — An EPA study on environmental EDTA tolerances, challenged during Martz's testimony as having been misapplied by Rieders; Martz argued that the 'one part per billion' figure cited by the defense was a typographical or resolution error for 1,000 parts per million, and that the study addressed blood preservation rather …
- FBI EDTA test report March 1st — no EDTA detected in Q204 or Q206 — An FBI EDTA test report dated March 1st stating that no EDTA was found in bloodstains from the rear-gate swabbing, Q204, or the sock cutting, Q206 / 13-A1. The report was quoted and disputed during a hearing concerning EDTA discovery and a proposed curative instruction.
- FBI EDTA testing report — FBI report concerning EDTA testing, distinct from the People's evidence disposition summary; its introduction was repeatedly attempted, with several objections sustained and foundation expressly questioned for some attempts.
- FBI sample Q204 — Bundy back gate swatch (stain no. 117) — FBI sample Q204, identified during Dr. Rieders' direct examination as a swatch from the back gate of Nicole Brown Simpson's condominium, stain no. 117.
- FBI sample Q206 — sock edge cutting (physical sample) — FBI sample Q206, identified during Dr. Rieders' direct examination as a cutting from the edge of a large stain on OJ Simpson's sock.
- Martz EDTA-on-metal-can experiment and methodology critique — Agent Martz's test results and methodology, including his EDTA-on-metal-can experiment and self-blood red-top tube test, reviewed and critiqued by Dr. Rieders for methodological inadequacy during re-direct testimony.
- Martz internal chart '4049' — 200,000 ion count blood sample — Martz's internal chart labeled '4049,' showing an ion count of approximately 200,000 from a blood sample. It was referenced and cross-checked against Blasier's chart during questioning.
- Martz memo September 15, 1995 — response to reprimand recommendation — A September 15, 1995 memo titled 'Validation studies' from Agent Martz to Ahlerich, responding to the Nimmich reprimand recommendation, in which Martz acknowledged working with Quantico on method development. Compared to Martz's criminal trial testimony at pages 38711–38712 to allege inconsistency.
- Merck index entry on calcium disodium EDTA as food preservative — Merck Index entry describing calcium disodium EDTA as a food preservative, referenced by Clark to challenge Rieders' characterization of EDTA's uses.
- Nicole Brown Simpson autopsy evidence collection — EDTA swatch and biological kits (items 82–85) — Nicole Brown Simpson's EDTA reference swatch (item 82), hair kit (item 83), fingernail kit (item 84), and blood scrapings (item 85), recovered from the frozen analysis envelope during the criminal trial.
- Nimmich memo August 30, 1995 — recommending Martz reprimand — An August 30, 1995 memo from K.W. Nimmich, acting head of the Quantico research laboratory, to Ahlerich, acting head of the FBI laboratory, recommending that Agent Martz be reprimanded for his testimony in the Simpson case and characterizing Martz as 'less than candid.'
- Nimmich memo September 18, 1995 — walking back 'less than candid' characterization — A September 18, 1995 memo from Nimmich to Ahlerich walking back the 'less than candid' characterization of Martz's testimony, reframing it as 'enhanced self-importance rather than a misstatement of factual data.' Characterized by defense counsel Blasier as a 'circle the wagons' memo.
- Positive control '4043' — approximately 3 million ion count — Positive control sample labeled '4043' with an ion count of approximately 3 million, used as the baseline in Blasier's four-fold scaling hypothetical.
- Purple-top EDTA blood-collection tube — Purple-top EDTA-preserved blood-collection tube identified during testimony as a likely source of EDTA contamination.
- Red top (non-EDTA) blood collection tube — trace EDTA contamination question — A red-top, non-preserved blood collection tube, discussed in connection with whether it could contain trace EDTA as a possible contamination source.
- Steroid-type compound chromatogram faxed to Martz during testimony — A chromatogram of a steroid-type compound faxed to Agent Martz during the proceedings as a possible alternative explanation for his EDTA-like ion findings. Martz disclosed receiving it mid-testimony; Blasier established it used gas chromatography and electron impact ionization rather than Martz's LC-MS/MS technique.
- Terry D. Lee EDTA motion report and supporting documents — Expert report and supporting documentation from plaintiffs' expert Dr. Terry D. Lee, considered by the court during the motion to exclude EDTA evidence.
- Whitehurst 26-page DOJ Inspector General memo on Martz and FBI lab — A 26-page memo authored by Dr. Whitehurst and submitted to the Department of Justice Inspector General, detailing allegations against Agent Martz and other FBI laboratory personnel. The court reviewed it, and Kelberg quoted from it.
- Whitehurst interview and examination transcript, volumes 1 and 2 — Transcript volumes 1 and 2 of the Whitehurst interview and examination, including page 281 on which Whitehurst admitted his inability to challenge Martz's EDTA conclusions, cited by prosecutor Kelberg during the criminal trial.
- World Trade Center case reports — Martz original and Whitehurst/Burmeister corrected version — World Trade Center case reports concerning urea-nitrate testing methodology: an original report signed by Agent Martz and a corrected version by Whitehurst and Burmeister. They were discussed during the proceedings, although the original reports had not yet been produced to the defense.