Ms. Clark.

Thank you, Your Honor. DIRECT EXAMINATION (CONTINUED)

BY MS. CLARK:

Good morning, Mr. Matheson.

Good morning.

I think where we left off yesterday, I think you indicated you tested item number 49, which was the blood drop from the trail left at 875 south Bundy, shown in the close-up in photograph 'E', and shown in perspective in photograph 'D.' Do you recall saying that?

That's correct.

And you tested that initially to determine if it was of human origin?

Yes.

And with respect to the blood samples that were retrieved from the defendant and from Ronald Goldman and Nicole Brown Simpson, with respect to those samples, did you test them also?

Yes, I did.

What test did you perform on those?

On those I performed the ABO blood typing test, the group 1 enzyme electrophoresis test and the PGM sub-type electrophoresis test.

And did you also subject the blood drop from the trail, item number 49, to those same tests?

Yes, I did.

Did you prepare a chart, sir, indicating what you found?

Yes.

Your Honor, I have a chart that I have previously shown to the defense. Ask that it be marked as People's 24.

All right.

BY MS. CLARK:

Showing you People's 24, sir, do you recognize what I'm showing you?

Yes, I do.

What does that chart show us?

Well, it's just a summary of the results of the analytical tests that were performed on those items.

With respect to the ABO typing performed on each of the blood samples, with respect to the blood from Nicole Simpson Brown, item number 59, the ABO typing result was?

That I determined that she was a type A.

And as to Ronald Goldman in item number 60?

In that case I determined that the results indicate that he's a type O.

And as to the defendant, item number 17?

That he is a type A.

And as to item number 49, the blood drop?

That the tests indicate that it is of a type A.

Now, what do you mean when you say "indicates"?

Well, during the course of ABO typing, there's actually two different constituents that are present in the blood that can determine what the ABO type is. One of them is called antigen and the other is called an antibody. If we only determine one of those two, we call it "indicative of." If we're able to determine the presence of both the antigen and the antibody, and they confirm the type, then we just call it a type A or a type O or a type AB or type B, depending on whatever it turns out to be.

Does that mean when you say "indicative of O" that it might not be O?

Have you performed ABO testing before, sir?

Yes, I have.

About how many times?

Well, I didn't break -- there's a variety of different types of ABO tests. I didn't break it down to the individual ones. But in my career so far, I've run ABO typing tests a little over 6500 times.

In those 6500 times, have you had the experience of doing the initial run for ABO typing and come up with an indication of a type as you've indicated here -- like indicative of A or indicative of O -- and then had an opportunity to run the second test on the antibodies to confirm that result later?

Yes.

In any of those cases, did it turn out that the initial "indicative of" type -- whether it be O, A, or AB or B -- turned out to be wrong?

I don't know if I would say turned out to be wrong. Occasionally there are discrepancies that occur between the two, and we come up with what's called an inconclusive result. Normally you can through further testing try and decide or determine whether it may not have come out as clearly as you expected, but occasionally it does happen where your first indication or your first test is not how it's eventually reported.

And how often does that happen?

I don't have a number. It happens fairly rarely.

Now, in this case, after the ABO typing, did you perform further typing?

Yes, I did.

And what was that?

Well, there was additional tests run that I mentioned before. The enzyme group 1 test, which includes actually three different enzymes in one process. One of them is the ESD or esterase D that's indicated on the chart. Another is PGM or phosphoglucomutase, and the third is GLO or GLYOXALASE. Those all three are run in one process.

With respect to the Nicole Simpson Brown sample, item number 59, what was the ESD result?

A type 1.

With respect to Ronald Goldman, item number 60, what was the result?

Also a type 1.

And with respect to the defendant, item number 17?

Also was determined to be a type 1.

And with respect to item number 49, the blood drop?

That was also determined to be a type 1.

Thus far with respect to what -- the markers that you found in item number 49, would it be a fair statement that only Ronald Goldman's could be excluded from having been the source of that blood drop?

If our only population are the three people that are being described here, yes. He's the only one of those three that can currently be excluded as being the source of that blood drop.

Then you performed the PGM sub-type test?

Yes.

And the result with respect to Nicole Simpson Brown in item number 59?

I determined that she was a PGM sub-type 1+.

And Ronald Goldman, item number 60?

That he was a 2+1+.

And the defendant, item number 17?

So each of the three parties there are a different PGM sub-type; is that correct?

Yes, that's correct.

With respect to item number 49, the drop of blood on the trail at 875 south Bundy, what was the PGM sub-type?

Based on the three people that you see on that chart, could Nicole Simpson Brown have left the blood drop at 875 south Bundy marked item number 49?

No. With the inclusion of the PGM sub-type information, she's excluded as being a source of that sample.

With respect to Ronald Goldman, based on the PGM sub-type, could he have been a source of that blood drop on the trail known as item number 49 at 875 south Bundy?

No, he could not.

With respect to the defendant, could he have been the source of the blood drop that was found on the trail at 875 south Bundy known as item number 49?

Now, did you make some effort to determine what the frequency or number of percentage of the population that could have left the blood sample that you typed out in item number 49 as indicative of A, ESD type 1, PGM sub-type 2+2-, what percentage of the population could have left that blood drop?

Your Honor, we'll object to the admission of this evidence for lack of foundation. If the prosecution is going to offer a computation based on the multiplication of the frequency of three different types or enzymes in the blood, they're going to have to show that these are independent random variables that can be multiplied, and there's been no foundation here of the independence of each of these calculations.

Well, there's been no foundation as to how this particular number has been arrived at, so maybe you ought to go into that.

Yes, Your Honor. Thank you.

BY MS. CLARK:

Tell us how you arrived at that frequency, sir.

Within our laboratory, since actually the beginning of the serology unit, we have kept information on all the whole Bloods that have been run by that unit, all the genetic marker types that have been determined on all the victims, suspects, witnesses, whatever blood sample happened to come into the laboratory. And through doing that and identifying the different types, we have been able to establish percentages of the population that have a particular type. For example, in the ABO blood typing system, we've determined that approximately 33, 34 percent of the population is a type A, approximately 16 percent is a type B, approximately 4 percent is a type AB, and approximately 46 percent is a type O.

And how are those tables compiled, if you know?

The tables or the information is just an ongoing process. I, for the last, oh, approximately ten years or so, have on a annual or semiannual basis added up all the types that we've determined during that, you know, previous time period, added it to the quantity that we had before and performed the calculations.

And approximately how many times have you performed such calculations, sir?

Like I said, I do it approximately annually, anywhere from 9 to 18 months, and I would say -- maybe 9 or 10 times we've brought it up to date.

And on how many occasions have people in your lab testified to frequencies of types that are found in evidence stains and in various persons in courts of law?

Oh, I'm not sure I can give a specific number on it. I know that I have testified personally in blood stain type cases approximately, you know, 115 times. Out of that, frequencies are brought up in at least half of those.

And in each case, was the frequency based on the tables you've mentioned using the multiplication system admitted in the court?

Yes, it has.

Is the system of multiplying each of the factors to achieve a frequency, an overall frequency, a method that is accepted in the scientific community, sir?

Yes, it is.

And then you reported that the frequency you found to be for the typing that you found in the blood drop on the trail at 875 south Bundy was .43 percent?

Approximately that, yes.