📄 Redirect examination of Michele Kestler — Thursday, June 30, 1994
Address:
C:\DEPT103\PRELIMINARY\1994\JUN\30\REDIRECT-EXAMINATION-OF-MICHEL.DOC
TRIAL
▲ Day 1 of 6

Redirect examination of Michele Kestler

Witness: Michele Kestler
Examiner: Marcia Clark
Called by: Prosecution • Date: Thursday, June 30, 1994 • Utterances: 611
Robert Shapiro cross-examines LAPD crime lab director Michelle Kestler, first attacking her credentials (outdated CV, limited DNA training, husband assigned to robbery/homicide) and then methodically going through each of the 60+ blood evidence items to establish how much sample remains for independent defense testing. Clark repeatedly objects and argues the relevant question is only what remains after all prosecution testing is complete, not after each individual test — a distinction the court ultimately endorses, though Shapiro is permitted to continue item by item.
1 THE COURT:

All right. We're once again on the record in the case of People versus Simpson. the defendant is present with counsel, the people are represented. Mr. Shapiro, I assume you do now have a copy of the curriculum vitae.

2 MR. SHAPIRO:

Your Honor, what I have is not a curriculum vitae, but a statement of qualifications.

3 THE COURT:

All right.

4 MR. SHAPIRO:

We're ready.

5 THE COURT:

Miss Kestler, if you'd retake the witness stand. You've previously been sworn and remain under oath.

6 MICHELE KESTLER:

yes, your Honor.

7 THE COURT:

Mr. Shapiro.

8 MR. SHAPIRO:

thank you much, your Honor.

9

CROSS-EXAMINATION

10

BY MR. SHAPIRO:

11 Q:

Good morning.

12 A:

Morning.

13 Q:

Is that -- is it miss or Mrs. Kestler?

14 A:

Mrs. Or Ms., whichever, you prefer.

15 Q:

What do you prefer?

16 A:

Doesn't matter.

17 Q:

Miss Kestler, does your husband work for the Los Angeles Police Department as a detective?

18 A:

Yes, he does.

19 MS. CLARK:

Objection, irrelevant.

20 THE COURT:

Sustained.

21 MR. SHAPIRO:

Your Honor, I think this goes to --

22 MS. CLARK:

Motion to strike.

23 MR. SHAPIRO:

I think it goes to credibility. I can make an offer of proof if you would like.

24 THE COURT:

The objection is sustained. The motion to strike is granted.

25 MR. SHAPIRO:

Your Honor, may I inquire as to whether or not he is, or has been assigned to the very division that's investigating this case? Would that be of relevance to the court?

26 THE COURT:

You can ask that.

27 MR. SHAPIRO:

Thank you.

28 Q:

What is your --

29 MS. CLARK:

Same objection, your Honor.

30 THE COURT:

Overruled.

31

BY MR. SHAPIRO:

32 Q:

has your husband been assigned to the robbery/homicide division, to your knowledge?

33 A:

Yes, he has.

34 Q:

Is he still assigned?

35 A:

Yes, he is.

36 Q:

And do you personally know the two lead detectives in this case?

37 A:

I've worked for them for several years, yes.

38 Q:

Do you know them personally, outside of work?

39 A:

No.

40 Q:

Have you discussed this case with them?

41 A:

Just as pertains to the case, and evidence involved in the case.

42 Q:

Have you discussed this case with your husband?

43 A:

Not really, no.

44 Q:

You have provided us with a statement of qualifications, consisting of three pages, in the form, really, of check boxes. Is this what you consider your curriculum vitae?

45 A:

This is the only thing that we have used most recent years. Since Prop 115, this is all I have available at this time. This is what we've been considering our C.V., yes.

46 Q:

My question is, do you consider this your curriculum vitae?

47 A:

I have used this type of statement for years. I used to spell it out in terminology, rather than have check boxes. It used to look more narrative, but it didn't go into much greater detail.

48 Q:

Prior to being employed by the Los Angeles Police Department, what was your work experience?

49 A:

I worked for approximately five years in a private laboratory, performing chemical analysis and biological analysis.

50 Q:

What part of that work consisted of D.N.A.?

51 A:

D.N.A. wasn't being done until the last few years.

52 Q:

What part of that work concerned microscopic comparison of hair?

53 A:

None, then.

54 Q:

What part of that work consisted of serology?

55 A:

Not at that time, other than my masters thesis.

56 Q:

What part of that work consisted of maintaining samples of blood?

57 A:

None.

58 Q:

What part of that work consisted of collecting samples of blood?

59 A:

None.

60 Q:

What part of that work consisted of preserving such samples of blood?

61 A:

None.

62 Q:

Now, you have authored one article; is that correct?

63 A:

I authored one article, yes. I've been coauthor on several others that aren't listed here.

64 Q:

What is the article that you have authored?

65 A:

It was -- I have to read the actual title. "The lab goes to the lab."

66 Q:

When was that published?

67 A:

1982.

68 Q:

And you were the coauthor on that?

69 A:

Yes.

70 Q:

Have you authored any articles?

71 A:

No.

72 Q:

What did that article deal with?

73 A:

That is about clandestine laboratories.

74 Q:

Drug cases?

75 A:

Yes.

76 Q:

Had nothing do with do with serology?

77 A:

No.

78 Q:

Have you published or coauthored any articles on serology?

79 A:

No.

80 Q:

Have you published or coauthored any articles on hair analysis?

81 A:

No.

82 Q:

You indicated your training in the discipline of hair. Is that how you refer to it? The discipline of hair?

83 A:

Actually, it's -- hair's just like a fiber, so I guess it would be hair and fiber analysis.

84 Q:

Let me refer you to page 3 of your statement of qualifications.

85 A:

Uh-huh.

86 Q:

Mrs. Kestler, you list there "Courtroom experience, discipline hair, 1980 through 1986;" is that correct?

87 A:

That's correct. That's the last time I testified on a hair case.

88 Q:

Up until that point in time, you testified approximately 35 times?

89 A:

Uh-huh, that's correct.

90 Q:

I don't see anything on your statement of qualifications indicating testifying regarding blood, blood samples or blood preservation. Is your qualification statement incomplete in that regard?

91 A:

No. It's under "Crime scene investigation and preservation of evidence" on page two. I have testified approximately 55 times in crime scene investigation and preservation of evidence. And in each of those cases, or almost all of those, had to do with blood preservation and obtaining sufficient sample for analysis purposes.

92 Q:

When was the last time you testified in a court of law regarding the amount of a sample necessary for preservation for later analysis?

93 A:

Oh, let's see, probably about 19 -- let's see, when did I prepare this. Actually, the date changes automatically, so last time I testified, and that was probably about 1988, '86.

94 Q:

Do you recall which it was? '88 or '86?

95 A:

No, I don't recall, I really don't recall the year. So, sometime between 1982 and now, but only once or twice since then, because I've been in management most of that time.

96 Q:

How many times have you testified since 1976, regarding the amount of blood that is necessary to preserve a sample for later analysis?

97 A:

Between 30 and 55 times. Almost all those cases listed on page 2, that refer to a crime scene investigation and preservation of evidence, are dealing with blood.

98 Q:

And you were specifically asked the amount of blood necessary to be preserved for later analysis; is that your testimony?

99 A:

I'm not sure if that was exactly what was questioned, no.

100 Q:

In fact, that was never asked of you before today; isn't that the case?

101 A:

No, that's not true.

102 Q:

Do you recall when the last time you testified to the amount of blood necessary for splitting was?

103 A:

I don't believe I've ever been asked to testify to that.

104 Q:

Now, I notice in your statement of qualifications that you, indeed, attended a seminar on D.N.A.; is that correct?

105 A:

Yes.

106 Q:

And that was in January of 1988?

107 A:

That was one, yes.

108 Q:

and that's eight hours?

109 A:

That's one, yes. I've attended several which are not on here. As I said, I was not prepared for this, so this is not up to date.

110 Q:

Well, it's dated the 24th, is it not, of this month?

111 A:

As I explained, the computer automatically updates it, and I did not have time to go back in. There was apparently a rush to get this here, so --

KEY QUOTE
112 Q:

Isn't that something that's standard for people who testify as expert witnesses, to have a curriculum vitae that is current to date?

113 A:

It's only required if I'm going to bring it to court. As I stated, I don't testify much anymore, so I don't update this on a routine basis, no. I keep track of my interests, and what I'm doing, but not -- I don't update the c.v. all the time.

114 Q:

When were you notified that you were going to come to court as a witness in this case?

115 A:

Yesterday, or perhaps the day before, late at night.

116 Q:

When were you given information regarding this case?

117 MS. CLARK:

Objection, vague.

118

BY MR. SHAPIRO:

119 Q:

When were you given evidence regarding this case?

120 A:

Well, I was never given evidence.

121 Q:

When were you aware that evidence was available during this case?

122 A:

When the case --

123 MS. CLARK:

Objection, irrelevant.

124 THE COURT:

Overruled. You can answer that.

125 MICHELE KESTLER:

Whenever the case went down, there was evidence. But again, I did not expect to be involved.

126

BY MR. SHAPIRO:

127 Q:

You didn't consider yourself as a potential witness in this case?

128 A:

No, I did not.

129 Q:

Well, the things you haven't had time to add on to your statement of qualifications, let's talk about D.N.A. What additional qualifications do you have since eight hours of a seminar of 1988?

130 A:

I have spent many, many hours with experts in the field from private laboratories, including cellmark, lifecodes. I've attended all the American society meetings from the past, since 1985, which is once a year for 40 hours a week. And I would say at least two days of that is always devoted to D.N.A. I also have attended all the A.S.C.L.D., as an A.S.C.L.D. board of directors meetings, MUST BE TWICE a year for the last -- since 1985, also. And there's always an update by the FBI and private laboratories on D.N.A. analysis, and what is required for that. AND I have been instrumental in implementation of D.N.A. in our laboratory as the manager, so I'm very familiar with it.

131 Q:

Do you know who the scientist is that is responsible for the D.N.A. subtypes that are being used in this case?

132 A:

The scientist that's responsible?

133 Q:

Yes.

134 A:

The person that developed it?

135 Q:

yes.

136 A:

Individually?

137 Q:

yes.

138 A:

Not -- no, not off the top of my head. I'd like to have it --

139 Q:

I take it you haven't read any of the books that he's published on this subject?

140 A:

No, I have not read extensive books on the subject.

141 Q:

I take it that you haven't taken any courses that directly relate to D.N.A., in a school atmosphere?

142 A:

Except in college, and it wasn't -- D.N.A. was, you know, barely mentioned as part of genetics and microbiology.

143 Q:

When was that? I don't want to --

144 A:

That's quite all right, counsel, I'm not concerned about my age here. It was 19 -- probably 1970.

145 Q:

That was the last time you were involved in any academic study?

146 A:

Academic study; that is correct.

147 Q:

Now, I understand that you list as your training the following things: "How to turn your work group into a winning team, Los Angeles Police Department"?

148 A:

that's management training.

149 Q:

That has nothing to do with winning or losing a criminal case?

150 A:

Not that I recall.

151 Q:

You've had two courses in management seminar?

152 A:

Actually, that's an ongoing management seminar. As I stated earlier, as a member of the American society of crime laboratory directors, board of directors, I attend the management seminars with the FBI twice a year.

153 Q:

And you attend seminars regarding sexual harassment?

154 A:

I've attended -- there's always an update on that, believe me.

155 Q:

And you've gone to forensic alcohol supervisors school?

156 A:

That's correct.

157 Q:

Do you consider yourself an expert in D.N.A.?

158 A:

Not in D.N.A. I considered myself an expert in preservation, collection and evaluation of evidence for all types of tests.

KEY QUOTE
159 Q:

Do you consider yourself an expert in serology?

160 A:

No, not in today's current serology. Again, evaluation, and I understand it, I can review reports, I can review People's analysis. I would never try to do it at the bench, but I do understand it.

161 Q:

Do you consider yourself an expert in the comparison of hair?

162 A:

Yes, I do.

163 Q:

What scientific training have you had academically, regarding the comparison of hair?

164 A:

well, There isn't really any academic training, other than my masters program and private courses in criminalistics, involved comparison of hair, and also the Mc Crone school hairs and fibers, that's one of the academic courses. And I've been trained as to on-the-job training by the FBI, as to hair and fiber analysis.

165 Q:

Are you familiar with a gentleman by the name of Dr. Henry Lee?

166 A:

Yes, I am.

167 Q:

Can you tell us who he is?

168 A:

He is a forensic scientist out of Connecticut.

169 Q:

Do you have an opinion regarding his qualifications in this area?

170 A:

Not in hair examination, I have no idea.

171 Q:

What about as a forensic scientist?

172 A:

I don't know if henry actually does any bench work anymore, or if he's like myself, and he advises and oversees and reviews work, and evaluates evidence. But other than that, I know he's like myself. He used to do a lot of bench work. I consider himself -- I considered at that time that what he was doing, as well as what I was doing, him to be an expert. He is also a member of all the associations that I'm member of.

173 Q:

Is he a member of any organizations that you're not a member of?

174 A:

I don't know.

175 Q:

Have you seen his 50 page curriculum vitae recently?

176 MS. CLARK:

Objection, your Honor. Counsel is testifying. That's hearsay. We have no evidence of that. If counsel wants to put it into evidence and call Dr. Lee, that's fine, but --

177 THE COURT:

the Objection is sustained.

178

BY MR. SHAPIRO:

179 Q:

If Dr. Lee is of the opinion that you only need one hair for D.N.A. testing, would you agree or disagree with that? Yes or no?

180 MS. CLARK:

Objection, irrelevant.

181 THE COURT:

Sustained.

182 MR. SHAPIRO:

I'd like to now, your Honor, direct the court's attention, and the prosecutor'S attention, to the list of evidence. I would like to, painstakingly as it may be, go through each item, to see what tests were done, what tests are anticipated, and what the amount of sample is, and how much remains.

183 MS. CLARK:

Objection, irrelevant.

184 THE COURT:

I don't think it's irrelevant. However, do you have that information at your fingertips?

185 MICHELE KESTLER:

I'm sorry. Could you repeat what you --

186

BY MR. SHAPIRO:

187 Q:

You testified there are 60 items of evidence. I'd like to first direct your attention to the items of evidence that relate to blood. And I would like to review with you each one of these items of evidence, what tests have been performed at your laboratory to date, and what tests you anticipate performing in the future, so the judge can make a determination as to whether or not we will be able to perform the exact same tests.

188 MR. SHAPIRO:

What we would like, your Honor, is this: If they have done serology and D.N.A., and there still remains a sample, we would like to do serology and D.N.A.

189 THE COURT:

I think I understand where you're going with this. You want to know how much of a sample remains?

190 MR. SHAPIRO:

Exactly.

191 THE COURT:

And what tests have been done. And if no tests have been done, you want the know that also?

192 MR. SHAPIRO:

Correct.

193 THE COURT:

Okay.

194 MS. CLARK:

Your Honor, I think that perhaps it would be a lot more efficient if counsel would simply look at the documents he was given today, which indicate exactly what tests have been done and not done. And with respect to having the court determine whether or not further testing should be done, or whether sufficient volume exists to provide a split at this point in time, as to any piece evidence, how could the Court do that? That's a matter of expert opinion.

195 THE COURT:

Well, that is correct. And my understanding is that apparently the defense intends to present some expert testimony on that issue.

196 MS. CLARK:

Well, that was not my understanding. And I expressly asked Mr. Uelmen last night, when he called to ask me what the order of witnesses would be. I asked him what witnesses he intended to call today, and he informed me there were none.

197 THE COURT:

Mr. Shapiro.

198 MR. SHAPIRO:

your Honor, I think we will be able to satisfy the court, from this witness, through our cross-examination, that the tests that have been done, samples remain. And those samples would be enough to duplicate those tests in almost every area.

199 THE COURT:

WELL --

200 MS. CLARK:

In other words, counsel is indicating that he is not going to call any witnesses, expert or otherwise, pertaining to this blood split issue. Is that the case?

201 THE COURT:

That seems to be the general import of what you're saying; is that correct?

202 MR. SHAPIRO:

Your Honor, that is a general import. Obviously, we have the right to call witnesses. We do not anticipate calling witnesses. But as the court well knows, depending on the answers that are given, we'll make that determination at an appropriate time.

203 MS. CLARK:

Your Honor, counsel is in possession of the information he is seeking, in the list that was provided to him this morning. It indicates what tests have been performed. If counsel needs to inquire further, as to what tests are planned, that could be done collectively, as opposed to item by item.

204 THE COURT:

well, I'm not going to tell counsel he has to examine in a collective fashion. you can go item by item. If you have this particular information, it might be helpful if the witness has it also, to refer to it. Because there's so many items by number. I don't want to get into the results, however, of any of these tests.

205 MR. SHAPIRO:

I will not ask the results. That is not my intention, your Honor.

206 THE COURT:

All right. You may proceed.

207 MR. SHAPIRO:

Thank you.

208 Q:

may I direct your attention to item number 1. Just let me know when you have an opportunity to focus on it.

209 A:

I'm fine.

210 Q:

Item number 1 contains two bindles?

211 A:

No, it contains two swatches.

212 Q:

Two swatches?

213 A:

I'm sorry. Item 1 is one bindle containing two swatches. And item 1-C is a swatch, which is just a control sample.

214 Q:

So, you would say that item number 1 has two bindles, that are composed of a swatch and a control?

215 A:

Two -- no, that's -- I prefer to keep them separate, because it will just be confusing. If we could stick to item 1 and 1-C separately. Item 1 contains two swatches.

216 Q:

And was any analysis done on item 1?

217 A:

Not yet.

218 Q:

How much evidence is contained in item 1?

219 A:

There is one swatch that's approximately two millimeters square, and one swatch which is one millimeter square.

220 Q:

Where was that found?

221 A:

I'm sorry. I thought we were going to deal with just quantity of evidence, not location.

222 MS. CLARK:

Yes, your Honor. Counsel is in possession of a property report, that indicates where all these items were found.

223 THE COURT:

I don't think it's necessary, at this point in time, to know where it's located.

224 MR. SHAPIRO:

Very well, thank you. Thank you.

225 Q:

When do you anticipate analyzing it?

226 MS. CLARK:

Objection, irrelevant. Counsel wants to know at this point, what this witness's opinion is with respect to the availability of the blood split. When the tests will be performed in the future, is irrelevant to that determination. I think that counsel should be confining his questioning to matters that are now in issue. And that would be what tests have been performed, what tests are planned, and what volume she anticipates will be available for the blood split, if any.

227 THE COURT:

I don't think the problem -- there is a problem asking about when the test is going to be performed, because that, I suppose, would be relevant in terms of knowing when there would be sufficient sample, since the witness has indicated that apparently she won't know until the tests are actually performed on any of these items, whether there's going to be enough for a split, and We'll just be back here again, doing this in the future, to try to find out this information. If she knows when the test is scheduled at this point, she can tell us.

228 MS. CLARK:

She --

229 THE COURT:

If she doesn't know, that's fine.

230 MS. CLARK:

My point is, your Honor, it doesn't matter. Because with respect to all the items, the few items she's indicated may be capable of providing a split, she won't have the answer for that, either, until the testing is done. So, we're going to be back here anyway, because one way or another --

231 THE COURT:

I understand that. If within her knowledge, at her fingertips, here on the witness stand, she happens to know when a particular test is scheduled, fine, she can answer that. If she doesn't, we're not going to go research it anymore. go ahead, Mr. Shapiro.

232 MR. SHAPIRO:

Yes.

233 Q:

You may answer the question.

234 A:

We have not had a chance to get back to this at this time, and schedule the testing. We spent a lot of time evaluating the samples. That's about all we've had time to do.

235 Q:

When do you anticipate testing that?

236 A:

Probably within the next -- they'll be either sent out, or done in our laboratory, within the next -- as soon as it can be arranged, probably -- depends on our schedule. We have other courts, so I'd say within the next three, four weeks.

237 Q:

what is the criteria for sending it out?

238 A:

It depends on whether we believe we can do it in-house. Depends on what we're going to do on it. obviously, if there's the R.F.L.P. that we think needs to be done, it has to be sent out. We don't do it in-house.

239 Q:

is That the only reason you would send It out?

240 A:

No, not necessarily. if we're going to send it for R.F.L.P., there's a good chance that we may decide to send all of it out. again, that determination hasn't been done yet. conventional serology, if it's possible, would be done in-house.

241 Q:

What tests do you anticipate doing on the sample?

242 A:

On this sample, it appears that, based on the small size, that we would be best suited to just attempt P.C.R., and possibly limit IT TO conventional. We'll try as much as possible. Doesn't appear to be enough for R.F.L.P.

243 Q:

Limited conventional refers to what?

244 A:

limited means We will pick the best markers out of conventional serology, whatever they may be, the most discriminating markers, and just do those. We probably cannot do a full battery of conventional serology tests.

245 Q:

After the serology test is done, how much of that sample will be consumed?

246 A:

Probably most of it will be consumed. It will be extracted. The extract will still remain, but the sample as is, the cross squares, will be consumed.

247 Q:

Part of the sample will remain, however?

248 A:

The extract, which means someone has already worked on it and developed an abstract.

249 Q:

Will any of the original sample be maintained?

250 A:

No, it can't.

251 Q:

After serology, you're left with just an extract?

252 A:

That's correct.

253 Q:

How much of the extract will be left?

254 A:

I have no idea.

255 Q:

What do you anticipate being left?

256 A:

It's not a volume, at that point. It depends on the concentration of the sample. you can concentrate that down into essentially nil. It's a concentration more than it is a volume. A volume is sort of irrelevant. It's more concentration of sample than volume. I can go into it, and give you a gallon of extract, which means nothing, Because it would be so diluted, you couldn't use it.

257 Q:

In your opinion, is there enough material here for both your laboratory to do a serology, and for a sample to be given to an independent laboratory for serology?

258 A:

No.

259 Q:

So, your opinion is there will be none left for any P.C.R. tests?

260 A:

That's not what I said. I said there wouldn't be enough for us to do our work, and someone else to take original sample from scratch, and do any kind of serology testing, whether it's P.C.R., A.B.O. or R.F.L.P., et cetera.

261 Q:

Let me ask you regarding this P.C.R. that is a D.N.A. test?

262 A:

Yes, it is.

263 Q:

and Are there false positives in that?

264 MS. CLARK:

Objection, irrelevant.

265 THE COURT:

Sustained. I don't want to get into the evidence. just See if there's been tests at this point.

266 MS. CLARK:

May I make a suggestion to the court?

267 THE COURT:

Yes.

268 MS. CLARK:

This is going to take hours, in the manner in which counsel is PROCEEDING. I don't know that evidence is required to be taken in this manner. Counsel could sit down with his expert, and talk to this expert, who would be delighted to share all of her findings with counsel, and any expert counsel chooses to have with him, so that he can understand what her position is. And then we can frame a stipulation as to the nature of her testimony. This is going to take all day, in the manner in which counsel is proceeding. And I don't think it's going to assist the court any, in being able to determine its ruling.

269 MR. SHAPIRO:

Your Honor, with all due respect, I'm representing a man who is charged with two counts of first degree murder, where the people may be asking for the death penalty. And if it takes two hours to determine whether or not there will be enough of a sample for an independent evaluation, where we believe samples can be contaminated, where false positives are possible, and where errors can take place in laboratory procedure, I don't think that's being excessive at all.

270 MS. CLARK:

Your Honor, I take exception to the manner in which counsel has characterized my response. I am making a suggestion to counsel that would allow him to have much more information than he is going to obtain in the manner in which he is proceeding. If he wants the information so that he can make a determination as to how he wants to proceed with the evidence, and what he wants to argue to the court, what I am suggesting would allow him to learn far more than he will in this manner. He needs an expert at his side, so that he can understand what this witness is telling him. And the manner in which he is proceeding, will not permit him do so. So, I am actually offering him the opportunity to learn a great deal more than he is at the current time. I'm trying to assist counsel in being more efficient and more effective.

271 MR. SHAPIRO:

We certainly appreciate that.

272 THE COURT:

Mr. Shapiro, you know, I'm going to allow you to present your motion your way.

273 MR. SHAPIRO:

Thank you. It's not going to be that time consuming. We have been here since 9:30, and so far, I've been allowed to ask one question.

274 THE COURT:

I think you asked a few more.

275 MR. SHAPIRO:

that's on the direct evidence. There's 60 items, about 30 are blood. And I think the responses should take less than a minute. So, if we don't have any further interruptions, or suggestions as to how we should present our case, perhaps we can finish this.

276 MS. CLARK:

Excuse me, your Honor. These are not interruptions.

277 THE COURT:

I don't think that's necessary. Let's just proceed.

278 MR. SHAPIRO:

Thank you.

279 Q:

The next item on the blood that you have LISTED, is item number 4; is that correct?

280 A:

Well, if you're referring to simply swatches containing red stains that appear to be blood, or that tested preliminary positive for blood, yes.

281 Q:

That's what I'm referring to.

282 A:

okay, number 4.

283 Q:

that's ITEM NUMBER 4?

284 A:

Uh-huh.

285 Q:

Would you describe ITEM NUMBER 4, please?

286 A:

it's One swatch that is eight millimeters square, approximately square. This is all approximation of these measurements.

287 Q:

Have any tests been conducted on that to date?

288 A:

No.

289 Q:

Do you anticipate any tests being conducted?

290 A:

yes.

291 Q:

When do you anticipate tests being conducted?

292 A:

My answer on the testing would all be the same, overall. Maybe that would help.

293 Q:

I'd like to limit it just to this item, because this has a different quantity than the first, does it not?

294 A:

Yes, but your battery of tests proceed in the same manner. And the extract on all of them has to be done first, and it's the same extract that is used for both P.C.R. and R.F.L.P.

295 Q:

If you have no strenuous objection, if you could address ITEM NUMBER 4 as a separate item, I think that would be helpful for us.

296 A:

Okay, that's fine. I was just trying to make it less confusing for everyone.

297 Q:

Thank you.

298 A:

Could you repeat where we are?

299 Q:

Do you recall the question?

300 A:

No, I do not.

301 Q:

Regarding ITEM NUMBER 4, do you anticipate doing blood tests on this?

302 A:

Yes.

303 Q:

What blood tests do you anticipate doing?

304 A:

It appears to be enough to do -- we hope to do both P.C.R., some conventional serology, and possibly R.F.L.P., which would consume the sample.

305 Q:

If you just did serology, would there be enough of a sample left for an independent laboratory to conduct a serology test?

306 A:

Well, serology to me includes D.N.A., serology, D.N.A., are PART OF IT. ARE you talking about conventional serology?

307 Q:

Let's get our terms correctly. Conventional serology is blood typing, is that correct?

308 A:

conventional serology is markers, genetic markers, that is D.N.A., if you will. They're all genetic markers.

309 Q:

Let's start with the first test you would anticipate doing, and use your terms as to what test that would be.

310 A:

I'm assuming -- What I think we would do here first, would be to attempt to do D.N.A., and then if there's any remaining, do conventional serology.

311 Q:

If you did D.N.A. first, do you anticipate -- is there enough to do D.N.A.?

312 A:

I indicated that R.F.L.P., which is the most consuming sample consuming D.N.A., as opposed to P.C.R., which requires less sample, that we would consume the sample.

313 Q:

You haven't done R.F.L.P. on anything yet, have you?

314 A:

No.

315 Q:

Let's go over what you've done so far. So far, you've done serology on samples and you've done P.C.R. on samples; is that correct?

316 A:

That's correct.

317 Q:

Do you anticipate doing serology on this sample? Yes or no?

318 A:

only if there's a sufficient sample.

319 Q:

Do you know, as an expert witness, whether or not the quantity you have is sufficient sample for serology? Yes or no?

320 A:

As I indicated before, if we only did serology, yes, there's probably enough there to do only serology. But we would anticipate to do R.F.L.P. first.

321 Q:

Would you please answer my QUESTION.

322 MS. CLARK:

Objection. Counsel IS argumentative. The witness is attempting to answer HIS question.

323 THE COURT:

Ask your question again, Mr. SHAPIRO.

324

BY MR. SHAPIRO:

325 Q:

Do you have enough of a sample to do standard serology? Yes or no?

326 A:

It appears we do.

327 Q:

If you did standard serology, would there be enough of a sample remaining for an independent laboratory to do serology?

328 MS. CLARK:

Objection, irrelevant, your Honor. Your Honor, This is the point. We intend to perform serology, R.F.L.P., P.C.R., poly markers, every test available on each piece of evidence. and The only relevant question is whether, after the completion of all those tests, there will be sufficient evidence left for a split.

329 THE COURT:

The objection is sustained.

330 MR. SHAPIRO:

may I be heard, your Honor?

331 THE COURT:

Yes.

332 MR. SHAPIRO:

Based on the records we have received, the following tests have been done --

333 THE COURT:

Have already been done?

334 MR. SHAPIRO:

Have been done by L.A.P.D.: serology and a D.N.A. test known as P.C.R. They have done no other tests. I've asked the witness this, and she has acknowledged that. What I would like to establish, for the record, is this: For those that have not been done yet, just go piece by piece, if you do serology, would there be enough for us to Do serology. If you do P.C.R., would there be enough for us to do P.C.R. If you do other tests, would there be enough for us to do other tests, to make a record. Because if these samples are consumed, and we want to contest the fact that possibly exculpatory evidence existed, that we were deprived the opportunity of exploring, that should be part of the court record.

335 MS. CLARK:

Your Honor, it is irrelevant to our consideration. That is exactly the point I don't think counsel understands. We have a battery of tests to which this evidence will be subjected. The question to be answered is whether or not, after the tests are completed, there's sufficient for a split. That's the question. Not whether, after each test is completed. Because counsel has no right to dictate to the prosecution the manner in which a case is investigated. We will subject the evidence to every test available, and every test possible. And at the conclusion of those tests, if there's sufficient left for a split, we would be delighted to share it with counsel. We have made that clear. this expert is only here to testify as to whether or not, after the conclusion of all the testing we deem appropriate, such amount will be left over. That's the only thing, not after each test. After each test makes no difference.

336 THE COURT:

Mr. Shapiro, I agree with the prosecution on this point. Because I'm not in a position -- I'm not going to put myself in a position to say they can or cannot perform a given test on a given sample. And I don't think what's what the court's position should be.

337 MR. SHAPIRO:

your Honor, I want the record just to be clear that we are requesting samples of all material relating to blood, that have not yet been tested, for our own testing. I will leave it at that.

338 THE COURT:

I think that the record is clear.

339 MR. SHAPIRO:

Thank you very much, your Honor.

340 MS. CLARK:

Let me make the record clear, then, your Honor, that I have repeatedly advised counsel that I am going to make every single test ready for observation, to him and to his experts. Every test performed, can be observed in every step of the process by his experts, at his choice. And if there is some question he has, or concerns about buffers or solutions being contaminated, we will be delighted to provide a split of any buffer or solution that is being used in the conducting of any test. So, counsel is going to be allowed to examine every piece of evidence, observe the testing process, to make sure that evidence is appropriately handled. And I want to reiterate that invitation on the record once again.

341 THE COURT:

I think the record is clear on that, also.

342 MS. CLARK:

Thank you.

343 MR. SHAPIRO:

Thank you very much.

344 Q:

The next item that blood was found is item number 5; is that correct?

345 A:

That's correct.

346 Q:

have you done tests on that item, or not?

347 A:

No.

348 Q:

Next item where blood was found was item number 6; is that correct?

349 A:

That's correct.

350 Q:

Have you done testing on that?

351 A:

No.

352 Q:

Next item where blood was found is item Number 9; is that correct?

353 A:

No, I believe number 7.

354 Q:

Number 7, okay. Have tests been done on that?

355 A:

NO.

356 Q:

What about number 8?

357 A:

No.

358 Q:

Was blood found on both of those?

359 A:

yes.

360 Q:

What's the next item where blood was found?

361 A:

Number 9.

362 Q:

Was testing done on that?

363 A:

Yes.

364 Q:

What was the first test that was done on item Number 9?

365 A:

The first test, because the sample appears to be very weak, was P.C.R.

366 Q:

Is there anything remaining of that sample?

367 A:

The glove gives quite a bit of positive area for blood. You cannot see it. You cannot differentiate how much is there, because of the leather. Until we actually extract it, and work with it, we don't know -- yes, there's some remaining, we don't know how much.

368 Q:

Is there enough remaining, in your opinion, for an independent laboratory to conduct their own investigation?

369 A:

Not to split at this time, no.

370 Q:

Is there enough remaining for an independent laboratory to conduct their investigation? Yes or no?

371 MS. CLARK:

Objection, asked and answered.

372 MR. SHAPIRO:

It was asked, but it wasn't answered.

373 THE COURT:

Do you know?

374 MICHELE KESTLER:

Some -- well, I have to clarify this. If you mean -- we're not done testing. So, do you mean at this time, or when we're done testing?

375

BY MR. SHAPIRO:

376 Q:

At this time.

377 A:

At this time?

378 MS. CLARK:

Objection, irrelevant.

379 THE COURT:

Sustained.

380

BY MR. SHAPIRO:

381 Q:

What additional tests do you intend to do on this?

382 A:

We're going to do everything possible, and again, until it's extracted, I believe we'll even try for D.N.A. -- I mean, I'm sorry, the R.F.L.P. and D.N.A. but, we're skeptical there will be sufficient there for that.

383 Q:

Next item I have, and correct me if I'm wrong, is item 17, where blood was found?

384 A:

No, actually number 11.

385 Q:

11 and 12, you have not analyzed yet; is that correct?

386 A:

No -- I'm sorry 11 we did not test, 12 we did.

387 Q:

12 you did test?

388 A:

Yeah. I didn't hear you. I almost thought you didn't say 12. I thought we were going one at a time.

389 Q:

On 12, what tests did you perform?

390 A:

P.C.R.

391 Q:

Is there any sample left on that?

392 A:

Yes, there is. We're not completed with our analysis yet.

393 Q:

would there be any sample left, in your opinion, when you complete your analysis?

394 MS. CLARK:

Objection, irrelevant.

395 THE COURT:

you're referring to completing all analysis; is that correct, Mr. Shapiro?

396 MR. SHAPIRO:

Yes.

397 THE COURT:

Overruled. You can answer that.

398 MICHELE KESTLER:

I believe I answered this earlier. I felt that there would be a possible sufficient amount when we're done, but we won't know until we're done.

399

BY MR. SHAPIRO:

400 Q:

The next item where blood was found is item 17?

401 A:

Actually number 14.

402 Q:

There was analysis done?

403 A:

Yes, P.C.R.

404 Q:

And the sample has been depleted?

405 A:

Yes, it has. It was very small.

406 Q:

You're saying extract was saved?

407 A:

Yes, we saved the extract.

408 Q:

What does that mean?

409 A:

That means the portion of which you're concerned about, the contamination in the extraction process, or at least one of the processes involving D.N.A., P.C.R., we extract the sample. We still have the extract, we don't need all the extract.

410 Q:

Is a portion of that available for us?

411 A:

We're not done. We may try to do some more on that, EXCLUDING poly marker, on the extract.

412 Q:

Do you anticipate a sample will be left for us?

413 A:

Probably not. Again, it a very, very weak, small stain.

414 Q:

The next item where blood was recovered?

415 A:

17 is the reference blood. That wasn't found. That's a reference known blood.

416 Q:

Next item where blood was found at the scene, or at one of the crime scenes?

417 A:

well, item 20.

418 Q:

What about item 18? Shoes, was any blood found?

419 A:

No, there wasn't any. That's the tests -- we did a search for blood, and didn't find any. I didn't know if we were getting into that.

420 Q:

The next item that you have?

421 A:

20.

422 Q:

Has that been tested yet?

423 A:

No.

424 Q:

21?

425 A:

Not tested.

426 Q:

23?

427 A:

22, not tested.

428 Q:

23?

429 A:

23, P.C.R., plus the extract remains. We intend to do with that as all others.

430 Q:

Right. Now, does a sample exist for re-analysis of P.C.R.?

431 A:

There's a small amount of the extract, yes.

432 Q:

24?

433 A:

No, not tested.

434 Q:

Next item?

435 A:

25, we did P.C.R.

436 Q:

Is there a sample left?

437 A:

There's A very small amount of sample left, about -- actually, this is small amount of fibers, small amount of stain, that's kind of like the glove. It's difficult, until we extract it, to know how strong it is.

438 Q:

will that be available to the defense?

439 A:

We don't know until we send it out for poly markers. The extract will always be available. Whether it's sufficient for testing, I don't know.

440 Q:

The next item that you recovered --

441 A:

26.

442 Q:

-- Regarding blood? That has not been tested yet?

443 A:

No.

444 Q:

Next item?

445 A:

28 are some threads. The sample is so small, it's not even what I consider a swatch. It's two or three little cloth threads, with red stain on them. That has not been tested.

446 Q:

Next item is 29?

447 A:

Correct.

448 Q:

That has not been tested?

449 A:

No.

450 Q:

Next item 30?

451 A:

It's not been tested.

452 Q:

31?

453 A:

P.C.R. only, and the extract remains. Plus one small square, and we don't anticipate any of that being left, except the extract.

454 Q:

At the present time, there remains a sample?

455 A:

That's correct. As you can see in the column, it indicates what's still there. That's your two by three millimeter piece.

456 Q:

Next item?

457 A:

Item 32.

458 Q:

Has that been tested yet?

459 A:

No. There's several little threads.

460 Q:

Next item is item 33, carpeting?

461 A:

Item 33 has a -- has blood in several very small areas of some pattern resembling -- resembling possibly a shoe print. So, that's -- we're holding off on that until we can decide how to progress and develop, and look at the shoe print, as well as the blood, without losing either one. We did do --

462 Q:

What tests have been done on that?

463 A:

We did separate little stain of one thread. We did P.C.R.

464 Q:

Is the same size sample available for the defense?

465 A:

It's threads all over the carpet. It's carpet with small little spatters of stain on them.

466 Q:

Would that be available to the defense?

467 A:

Not at this time. I think it's very weak. And we haven't done the shoe print, either.

468 Q:

Item 34, you have not analyzed yet?

469 A:

We did P.C.R.

470 Q:

you did?

471 A:

Uh-huh; that's correct.

472 Q:

And is there anything left on that?

473 A:

There's a two by three millimeter piece, that we have yet to continue with.

474 Q:

Is that enough for the defense to use for independent analysis?

475 A:

I don't know, because we're not finished. We're not finished on any of these, actually, except the one that was consumed. We probably can't do anything more on that. But we're going to attempt to, anyway.

476 Q:

At the present time, is there enough for a sample for re-analysis?

477 A:

Yes.

478 Q:

Thank you.

479 MS. CLARK:

Objection, that's irrelevant.

480 THE COURT:

Sustained.

481

BY MR. SHAPIRO:

482 Q:

Next item?

483 MS. CLARK:

May I just have a continuing objection to all of these questions, concerning the request for whether there would be sufficient split after one or two tests, before all the testing is completed? AND Counsel keeps going back to this, and I'm getting tired of objecting to the same thing. And the court keeps sustaining it. He's asking the irrelevant issue, which is whether, after each test, is there going to be enough left. The question is after all tests is there enough left.

484 THE COURT:

Miss Clark, if you have an objection, you have to make it question BY question.

485 MS. CLARK:

all right.

486

BY MR. SHAPIRO:

487 Q:

Next item, please, with blood?

488 A:

Number 37.

489 Q:

That is a glove?

490 A:

it's A glove, and there are -- appears to be stains on it that we have not tested yet. But, they appear to be blood -- I'm sorry, they preliminarily tested positive for blood.

491 Q:

Do you know the size of that sample?

492 A:

it's very small. There is a few drops.

493 Q:

What tests do you anticipate?

494 A:

as many as possible. Probably can't do R.F.L.P., but we are going to certainly have it evaluated further.

495 Q:

When do you anticipate doing that?

496 A:

We are going to begin it early in the week, probably Monday, by determining who's going to be -- who is going to do what testing.

497 Q:

Is there a standard laboratory that L.A.P.D. uses for independent testing?

498 A:

No, there's not. Well, there's more than one. We use two or three labs for different types of testing.

499 Q:

For R.F.L.P., who do you use?

500 A:

We most often use CELLMARK.

501 Q:

Next item where any blood material was found?

502 A:

Number 41, I believe we did P.C.R.

503 Q:

What was the size of that sample?

504 A:

There is a very, very -- there's several little swatches. There's three of them, but they're very weak.

505 Q:

Do you anticipate doing any more?

506 A:

We are going to try to do poly marker, probably. That's our hope, yes. We are going to attempt to do that.

507 Q:

Next item?

508 A:

Number 42, P.C.R. has already been done.

509 Q:

Do you have the results of that?

510 MS. CLARK:

Objection, irrelevant.

511 MR. SHAPIRO:

I don't think we've gotten that yet. I want to just check, just for information only.

512 Q:

Any sample remain --

513 MS. CLARK:

Objection withdrawn.

514 THE COURT:

She's withdrawn the objection. Do you have the result of that PCR, number 42?

515 MICHELE KESTLER:

I don't know if I have them. I DO know I gave them to the defense last week, at that same meeting.

516 MR. SHAPIRO:

My notes don't have the accuracy of that result, your Honor.

517 Q:

Any sample --

518 MS. CLARK:

Sorry, I didn't understand.

519 MR. SHAPIRO:

We'll withdraw the question.

520 Q:

Any sample remain of that?

521 A:

Yes. That's one of the ones that we're hopeful, after testing, after we complete our testing, that there may be some available for the defense, and -- but we're not sure.

522 Q:

Next item?

523 A:

Number 44. Oh, I'm sorry. I'm starting to skip to what we already did. I'm losing track in this melee of samples here. Number 43, there are four swatches. And out of those FOUR, they're weak in color. And we anticipate that the entire sample will be consumed when we're done testing.

524 Q:

Next item?

525 A:

Number 44. There are several swatches, and it's possible, we're hoping there may be some left when we complete our analysis. We haven't done anything, we're not done.

526 Q:

Next item?

527 A:

Number 45, we don't anticipate any being left. We have not tested it.

528 Q:

Next item?

529 A:

Number 47. We have done P.C.R. we feel that there, hopefully, based on what's there now, when we're done testing, that there will be some left. Can't guarantee it, but looks promising.

530 Q:

48?

531 A:

48? Probably will not be any left when we've completed. We have done P.C.R.

532 Q:

49?

533 A:

49, we have done P.C.R. and conventional, and plan on R.F.L.P. It's ready to send out.

534 Q:

50?

535 A:

By the way, on 49 we anticipate -- that's one of those we anticipate there will be enough left, hopefully, presuming everything goes well for the defense. Number 50, possibly. It's a little weaker than number 49, but there may be some left.

536 Q:

Number 51?

537 A:

Number 51, we haven't done anything. We don't anticipate any being left, though, when we are completed.

538 Q:

Number 52?

539 A:

We've done P.C.R., and we feel that R.F.L.P. will consume the sample.

540 Q:

Is the next number 54?

541 A:

Yes. Number 54 we have not done it. There's several little swatches, but we feel our R.F.L.P. will consume the sample.

542 Q:

Number 55?

543 A:

not tested. It's very, very small. We feel that there's not enough for R.F.L.P. and P.C.R. and conventional, and poly marker, of course, is part of the P.C.R. technique, will be all that will be done on that one.

544 Q:

Number 56?

545 A:

None left, but we feel R.F.L.P. will probably consume the sample. So that means R.F.L.P. and P.C.R.

546 Q:

Number 57?

547 A:

That's -- 57 is a label found on a walkway, I believe. I made a separate note of this. it's difficult, again, because of the label, to say how strong the stain is, how much interference from the label. But assuming everything goes well, there may be enough left when we're done. We haven't done anything with it yet.

548 Q:

59 and 60 are CORONER samples?

549 A:

That's correct.

550 Q:

does that complete the blood that's been submitted to you to date?

551 A:

No. I also have number 72, which is coroner's sample.

552 Q:

What else?

553 A:

Number 82, which is a coroner's sample.

554 Q:

Anything else?

555 A:

We have not -- any of these were in the column that indicates "split," where I have written yes or no, that means we may do something with them. Number 84-A, we've examined the nail scrapings, and we think that possibly there won't be any sample left when we're done. But possibly, we may be able to do P.C.R., and one or two conventional tests. And 84-B, these are the left and right-hand nail scrapings. Same thing, 84-C, the nail clippings, there won't be any left, but we may be able to do P.C.R. and conventional. Number 84-D are the right hand nail clippings. and There may be enough -- it's even questionable there may be enough there to do our R.F.L.P., but we don't anticipate there being anything left when we're done. number 85-A are some scrapings we received from the coroner, that they scraped. We'll have to refer to their report. We believe we can do P.C.R. and conventional. Again, we don't anticipate enough being left. And 85-B are some scrapings, again, and anticipate P.C.R., possibly some conventional. And don't anticipate any being left over for the defense.

556 Q:

Does that complete the blood?

557 A:

At this time -- At this time we have not looked at -- like I indicated -- as I indicated earlier in my testimony, we have not examined some of the evidence that was recently collected.

558 Q:

May I direct your attention now to the hair samples?

559 A:

Sure.

560 Q:

first one you refer to is item Number 9, the gloves.

561 A:

Item Number 9, there's hairs removed from item Number 9, which are item number 19 and item number 110.

562 Q:

have you made a determination as to the origin of those hairs?

563 A:

No, we have not. We don't have the hair sample to compare those hairs to yet. I'M Sorry, you just want a -- did you want a body origin?

564 Q:

Yes?

565 A:

I don't have that with me. I don't know if I gave that to -- it's in process. I don't know if that's one of the completed reports that I brought with me last night, which I know the prosecution hasn't had time to review.

566 Q:

Have you determined those to be Caucasian hairs?

567 A:

I can't tell you that without referring to the reports.

568 Q:

Can you look at the report?

569 A:

I don't have it with me, because no one has reviewed it yet, and I know you don't have it.

570 MS. CLARK:

Your Honor, I was just provided this this morning. This is a package for counsel, pursuant to the request he made when we were last in court, and I'm going to turn it over to counsel, and give him an opportunity to look at it. I haven't seen it myself. We all just got these packages. So, I'd ask counsel to acknowledge receipt of it on the record, and --

571 THE COURT:

That package is from the crime lab?

572 MICHELE KESTLER:

Yes, it is.

573 MS. CLARK:

It's from the crime lab. last time we were in court, If the court recalls, I promised to turn over the records requested verbally, and I just got them. I ask that counsel sign where it's indicated, and date it, and he can take possession of that. And I hope I can get mine at some point later today.

574 MICHELE KESTLER:

Just so -- if I may interject, what is not there is the protocol. We're still copying those. Those are volumes, and we hope to have them early next week, Monday or Tuesday.

575 MS. CLARK:

If you can inform THE court what you mean by protocol.

576 MICHELE KESTLER:

The protocol for D.N.A., and proficiency testing for D.N.A., P.C.R., and also conventional serology.

577 MS. CLARK:

Does that have anything to do with the results for testing conducted in this case?

578 MICHELE KESTLER:

It does, but it's not -- you haven't talked -- We haven't talked about it here today.

579 MS. CLARK:

No. The point being, does that -- that's a protocol you follow in all cases; is that right?

580 MICHELE KESTLER:

That's correct.

581 MS. CLARK:

not just for this case?

582 MICHELE KESTLER:

That's correct.

583 MR. SHAPIRO:

Your Honor --

584 THE COURT:

Yes?

585 MR. SHAPIRO:

-- I wonder, based on what the court indicated the schedule would be, if we might take a break, so we can review these records, before we continue questioning. I anticipate very, very limited questions, only on the remaining four hair samples, the amount. And for preparation, so that the records can be looked at over the break, we'd like to know the number of hairs, whether they are follicles or shafts of hair, where they were found, and how many of them there are.

586 MS. CLARK:

Your Honor, perhaps the reports that counsel has been given indicate all that, and if that's the case, then --

587 THE COURT:

Right. And if that information is contained within what you have, you're going to have the answer to that.

588 MR. SHAPIRO:

If we do. If we don't, those are the things that will be questioned.

589 MICHELE KESTLER:

If you haven't got the report, I can't officially, because it hasn't been verified. That means those items are not done yet, not completed, we're still working on them.

590 THE COURT:

You'll have to determine that, and maybe you can sort of confer, if you need, to off the record, with regard to some of these items. I don't think it necessarily has to be part of this motion that we're doing now.

591 MR. SHAPIRO:

Thank you very much.

592 THE COURT:

all right. Then we'll break at this time.

593 MS. CLARK:

I'm sorry, your Honor. just one more. we received this from GTE. it Looks like a response from the subpoena duces tecum. and It been DELIVERED To me by the CLERK, in a sealed condition, which is the manner it was delivered to her, I take it. Yes. and I'm going to ask to open it now on the record, in open court, so counsel can observe the opening, and the contents of the envelope. If I may.

594 THE COURT:

Yes.

595 MS. CLARK:

Thank you.

596 MR. SHAPIRO:

Your Honor, can this be possibly be done in the appropriate manner?

597 MS. CLARK:

This is the appropriate manner, your Honor.

598 THE COURT:

I don't know that it has to be on the record.

599 MR. SHAPIRO:

Seems to me like a little bit of grandstanding.

600 MS. CLARK:

Excuse me. I can't believe I heard Mr. Shapiro say that. I'd rather conduct everything on the record, your Honor, in open court.

601 THE COURT:

Go ahead and open it. Go ahead.

602 MS. CLARK:

May the record reflect I have now broken the seal. Opening the envelope, and I've retrieved what appears to be a one-page letter. I'm going to show to counsel.

603 THE COURT:

All right, miss Clark. My clerk, Alicia, informs me that came, accompanied by another larger packet of records, which she is holding there, which you'll want to review. I really prefer that you, if possible, can review those records off the record.

604 MS. CLARK:

I'd been delighted to review them off the record. All I want to indicate now is that they're in a sealed condition, and we may open them, and duplicate them for counsel.

605 THE COURT:

Assuming that both sides were agreeable to that.

606 MR. SHAPIRO:

That is agreeable. That's the proper procedure.

607 MS. CLARK:

Excuse me, your Honor. I don't think I've engaged in any improper procedures thus far. I don't appreciate counsel's editorializing.

608 THE COURT:

All right. Now, today, only because of certain matters that do not concern the rest of you, we are going to be breaking until 2:00 o'clock. I anticipate the following schedule, and I assume that most of you then, advised of it. That is, that the court intends to start at 9:00 o'clock and go until 12:00, with a 15-minute break somewhere during the mid part of that morning session. The court intends to, under normal circumstances, continue with the proceeding at 1:30, with a 15-minute break somewhere around 3:00 o'clock or so, and concluding the proceeding at 4:30. That's what I anticipate, and that's the schedule, Hopefully, that we will be able to abide by, generally speaking. I'm going to ask everyone's cooperation with regard to the breaks we take, the 15-minute break. I would very much like to see them remaining 15 minutes as opposed to 20, 25 minutes, 30 minutes, 40 minutes. It's really going to be up to you folks, to make sure that you are back in your seats, and all the necessary counsel and so forth, are back, so that we can keep this matter moving along. So, I would request the cooperation of everyone, so that we can handle this matter as smoothly as possible. At this point in time, we will be in recess until 2:00 o'clock. We'll conclude this motion, hopefully, shortly thereafter. And we'll begin with the other motions, including the motion to suppress at that time.

609 MR. SHAPIRO:

Thank you very much, your Honor.

610 MS. CLARK:

Thank you, your Honor.

611 (recess at 11:40 a.m.)

Temperature

tense

Key Quotes (4)

Robert Shapiro
I'm representing a man who is charged with two counts of first degree murder, where the people may be asking for the death penalty. And if it takes two hours to determine whether or not there will be enough of a sample for an independent evaluation, where we believe samples can be contaminated, where false positives are possible, and where errors can take place in laboratory procedure, I don't think that's being excessive at all.
Shapiro's clearest statement of why this blood-split hearing matters — establishing a record that exculpatory evidence may be destroyed before the defense can test it.
Michelle Kestler
Not in D.N.A. I considered myself an expert in preservation, collection and evaluation of evidence for all types of tests.
Kestler concedes she is not a DNA expert, undermining her authority to opine on DNA testing protocols and sample sufficiency.
Michelle Kestler
As I explained, the computer automatically updates it, and I did not have time to go back in. There was apparently a rush to get this here.
Kestler admits her curriculum vitae was auto-dated and not actually current, handed over the day before testimony — damaging her credibility as a prepared expert witness.
Marcia Clark
Every test performed, can be observed in every step of the process by his experts, at his choice. And if there is some question he has, or concerns about buffers or solutions being contaminated, we will be delighted to provide a split of any buffer or solution that is being used in the conducting of any test.
Clark's on-the-record offer to allow defense experts to observe all testing and receive splits of buffers/solutions — a significant concession put into the record.

Evidence (17)

Item 1
Two swatches (approx. 2mm sq. and 1mm sq.) and control swatch 1-C; no testing done yet
discussed for sample quantity and anticipated testing
Item 4
One swatch approx. 8mm sq.; no testing done
discussed for sample quantity
Item 9
Glove with blood; PCR performed; leather makes quantity assessment difficult
discussed — PCR done, remaining sample uncertain
Item 12
Swatch; PCR performed; sample remains
discussed for split availability
Item 14
Small swatch; PCR done; sample consumed, extract saved
discussed — original sample depleted, only extract remains
Item 17
Reference (known) blood sample
identified as reference blood, not a crime scene item
+ 11 more

Notable Exchanges (4)

Marcia ClarkRobert Shapiro
Clark suggests Shapiro sit down with the expert off the record to learn more efficiently; Shapiro responds that he has a client facing the death penalty and two hours to establish a record is not excessive.
heated
Kathleen Kennedy-PowellRobert ShapiroMarcia Clark
Extended argument over whether Shapiro may ask about sample availability after each test versus only after all prosecution testing is complete. Court ultimately agrees with Clark's framing but allows Shapiro to continue item by item.
procedural
Robert ShapiroMichelle Kestler
Shapiro establishes that Kestler's husband is a detective assigned to robbery/homicide — the division investigating this case — and that Kestler has worked with the two lead detectives for years. Judge sustains Clark's objection to the husband question but allows the robbery/homicide assignment.
strategic
Robert ShapiroMichelle Kestler
Shapiro walks through Kestler's qualifications revealing: last academic training was 1970, sole authored article was on clandestine drug labs from 1982, no published work on serology or hair analysis, CV was auto-dated and not updated.
revealing

Light Moments (2)

Michelle Kestler
Kestler, asked about attending sexual harassment seminars, responds: 'I've attended — there's always an update on that, believe me.'
Kathleen Kennedy-Powell
Shapiro notes the hearing has been going since 9:30 and he has only been allowed to ask 'one question.' The judge dryly replies: 'I think you asked a few more.'

Credibility Attacks (2)

⚔ Michelle Kestler
qualification challenge
Shapiro establishes Kestler has no academic DNA training since 1970, no authored articles on serology or hair, limited courtroom testimony since the mid-1980s, and a CV that was auto-dated and not actually current — submitted only a day before she testified.
⚔ Michelle Kestler
bias — professional relationship
Shapiro elicits that Kestler's husband is assigned to robbery/homicide (the unit investigating the case) and that she has worked professionally with the two lead detectives for years, suggesting a potential conflict of interest.

Objections

18 objections (11 sustained, 4 overruled)
Proceeding 8953 • 611 utterances • Prosecution witness
Preliminary Trial
Department 103
⚖️ Start
📂 JUN 30, 1994 📄 Redirect examination of Michel
JUN 30, 1994 KRT DvH TD