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           SUPERIOR COURT OF THE STATE OF CALIFORNIA
                 FOR THE COUNTY OF LOS ANGELES
     DEPARTMENT NO. WEQ        HON. HIROSHI FUJISAKI, JUDGE


     SHARON RUFO, ET AL.,                     )
                                              )
                                 PLAINTIFFS,  )
                                              )
               VS.                            )NO. SC031947
                                              )
     ORENTHAL JAMES SIMPSON, ET AL.,          )
                                              )
                                 DEFENDANTS.  )
     _________________________________________)






                  REPORTER'S DAILY TRANSCRIPT

                        JANUARY 16, 1997

                            VOLUME 44






                  REGINA D. CHAVEZ, CSR #8446
                       OFFICIAL REPORTER







     APPEARANCES:


     FOR THE PLAINTIFFS: DANIEL M. PETROCELLI ESQ.,
                         THOMAS LAMBERT, ESQ.,
                         PETER GELBLUM, ESQ., and
                         EDWARD MEDVENE, ESQ.
                         Firm:  MITCHELL SILBERBERG & KNUPP
                                11377 West Olympic Blvd.
                                Los Angeles, CA 90064-1663
                         For: Plaintiff Goldman



                         JOHN QUINLAN KELLY, ESQ.
                                330 Madison Ave.
                                New York, NY 10017-5090.
                         For: Plaintiff the Estate of
                              Nicole Brown Simpson



                         MICHAEL A. BREWER, ESQ.
                         Firm:  HORNBERGER & CRISWELL
                                444 South Flower St.
                                Los Angeles, CA 90071.
                         For:  Plaintiff Rufo



                        PAUL F. CALLAN, ESQ.
                        Firm:  CALLAN, REGENSTREICH,
                                KOSTER & BRADY
                                One Whitehall St.
                                New York, NY 10004
                        For:  Plaintiff Estate of.
                              Ronald L.  Goldman



     FOR THE DEFENDANTS: ROBERT C. BAKER, ESQ.,
                         MELISSA BLUESTEIN, ESQ., and
                         PHILIP BAKER, ESQ.
                         Firm: BAKER, SILBERBERG & KEENER
                               2650 Ocean Park Blvd., #300
                               Santa Monica, CA 90405-2936.

                                       -and-

                         DANIEL LEONARD, ESQ. and
                         ROBERT D.  BLASIER, ESQ.
                         Firm:  BAILEY, FISHMAN & LEONARD.
                                6355 Riverside Blvd.
                                Suite 2-F
                                Sacramento, CA 95831

                    CHRONOLOGICAL INDEX OF WITNESSES

     PLAINTIFFS' WITNESSES:                           PAGE

     GUZMAN, ANGELICA
            DIRECT (M)                                    2
            CROSS (L)                                     7
            REDIRECT (M)                                  9
            RECROSS (L)                                  10
            REDIRECT (M)                                 11

     LEE, TERRY
            DIRECT (TL)                                  12
            CROSS(B)                                     28
            CROSS (B)                                    38
            REDIRECT (TL)                                49
            RECROSS (B)                                  52

     POPOVICH, BRADLEY
            DIRECT (TL)                                  54
            DIRECT (TL)                                  85
            CROSS (PB)                                   89
            REDIRECT (TL)                               129
            RECROSS (PB)                                138

     RICHARDS, GERALD
            DIRECT (G)                                  142
            CROSS(L)                                    146
            REDIRECT(G)                                 156
            RECROSS(L)                                  158

     BODZIAK, WILLIAM J.
            DIRECT (M)                                  165
            CROSS (PB)                                  176
            REDIRECT (M)                                180

     Legend:  (B) = Mr. Robert B. Baker
             (BL) = Mr. Blasier
             (BR) = Mr. Brewer
              (C) = Mr. Callan
              (G) = Mr. Gelblum
              (K) = Mr. Kelly
              (L) = Mr. Leonard
              (M) = Mr. Medvene
             (MB) = Ms. Bluestein
              (P) = Mr. Petrocelli
             (PB) = Mr. Philip Baker
             (TL) = Mr. Lambert
             (MO) = Ms. Molinaro







               INDEX OF EXHIBITS MARKED FOR I.D.


     PLAINTIFFS'
        NO.                  DESCRIPTION               PAGE

      2403        Curriculum vitae of Dr. Terry Lee      15

      2404        Chart                                  23

      2061        Comparison board                      166

      2407        11-by-17-inch print of five           168
                  individuals, in addition to
                  Mr. Simpson, on a football field,
                  Marked roll 1, number 78-A

      2408        11-by-17-inch print of the same       169
                  frame from roll 1, number 7-A, as
                  Exhibit 2407, but zooming in on
                  the legs and feet of the
                  individuals in the center of that
                  photograph, including Mr. Simpson








     DEFENDANTS'
        NO.                DESCRIPTION               PAGE

      2405        Dr. Terry Lee's notes                35

      1223        Two-page letter dated 2/16/95        46

      2406        The McElroy price sheet             163








                  INDEX OF EXHIBITS RECEIVED IN EVIDENCE

     PLAINTIFFS'
        NO.                DESCRIPTION                PAGE

      2403                                               53

      2404                                               53

      2264                                              141

      2265                                              141

       732                                              164

       821                                              183



     DEFENDANTS'
        NO.                DESCRIPTION                PAGE

      1223                                              53

      2405                                              54

      2406                                             164






     SANTA MONICA, CALIFORNIA; THURSDAY, JANUARY 16, 1997

                        8:30 AM

     DEPARTMENT NO. WEQ    HON. HIROSHI FUJISAKI, JUDGE



     APPEARANCES:

                  (PER COVER PAGE)



                  (REGINA D. CHAVEZ, OFFICIAL REPORTER)



                         (Jurors resume their respective

                         seats.)



            THE COURT:  Good morning.

            JURORS:  Morning.

            MR. PETROCELLI:  Morning, Your Honor.

            MR. BAKER:  Morning, Judge.

            MR. LAMBERT:  Morning, Judge.

            MR. MEDVENE:  Morning, Your Honor.

                  Officer Guzman.



                        ANGELICA GUZMAN,

     called as a witness on behalf of the Plaintiffs, was

     duly sworn and testified as follows:



            THE CLERK:  You do solemnly swear that the

     testimony you may give in the cause now pending before

     this court shall be the truth, the whole truth, and

     nothing but the truth, so help you God?

            THE WITNESS:  I do.

            THE CLERK:  Please state and spell both your

     first and your last names for the record.

            THE WITNESS:  My name is Angelica Guzman,

     A-n-g-e-l-i-c-a, last name is spelled G-u-z-m-a-n.



                       DIRECT EXAMINATION

     BY MR. MEDVENE:

            Q.    What is your business or occupation?

            A.    I am a police officer for the Police

     Department of Los Angeles.

            Q.    And were you at 360 Rockingham the

     morning hours of June 13, 1994?

            A.    Yes.

            Q.    How long had you been a police officer at

     that time?

            A.    For approximately a year and a half.

            Q.    How long had you been working in the

     field?

            A.    Approximately four months.

            Q.    Was your assignment that morning, in

     part, to watch a Bronco that was parked in front of

     360 North Rockingham?

            A.    Yes.

            Q.    And what hours were you at that location?

            A.    I would say approximately from 7 o'clock

     in the morning until about 4 o'clock in the evening.

            Q.    Sometime around 3:30, did you fill out an

     impound report for the Bronco?

            A.    Yes.

            Q.    How many impound reports approximately

     had you filled out prior to that time?

            A.    Approximately four or five.

            Q.    We're going to put on the TV monitor

     what's previously been marked 271.  I ask you to --

            MR. MEDVENE:  Let's see if we can focus it a

     little bit better.

                  Can you go down, scan down to the bottom

     of it.



                         (Elmo adjusted.)



            Q.    (BY MR. MEDVENE)  Can you take a look at

     the monitor, Mrs. Guzman.

                  Is that the inventory report that you

     filled out?

            A.    That's correct.

            Q.    And is that your name and your badge

     number?

            A.    That's my name and my serial number, sir.

            Q.    And Officer Thompson was with you on that

     occasion?

            A.    Correct.

            MR. MEDVENE:  Now, can you, Mr. Foster, go to

     the body of the report, I know there's certain Y's and

     N's.



                         (Elmo adjusted.)



            Q.    (BY MR. MEDVENE)  See the Y's and the

     N's?

            A.    Yes.

            Q.    What does Y mean and what does N mean?

            A.    Y means yes and N means no.

            Q.    Can you move it over to the left a

     little, please.



                         (Elmo adjusted.)



            Q.    You see under battery and alternator,

     there's a cross in the Y column?

            A.    Correct.

            Q.    Did you put that cross there?

            A.    Yes.

            Q.    Did you notice a battery in the car on

     that occasion before you put the cross there?

            A.    No.

            Q.    Under the battery it says generator and

     alternator; is that correct?

            A.    Yes.

            Q.    Did you put an  X under the Y column?

            A.    Yes.

            Q.    Did you observe a generator or alternator

     before you put the X in the Y column?

            A.    No.

            Q.    Why did you signify yes, that the vehicle

     had a battery and alternator even though you did not

     see the battery and alternator?

            A.    I put yes because the vehicle appeared

     drivable.

            Q.    Did you -- I notice in the next column it

     says vehicle appears operable.

                  Do you see that?

            A.    Yes.

            Q.    And you put an  X there?

            A.    Yes.

            Q.    Is that what you -- you confirm that you

     thought it appeared operable?

            A.    That's correct, sir.

            Q.    Why did you think it appeared operable?

            A.    The vehicle didn't have any damage, it

     had four wheels, there was no debris on the vehicle,

     and it looked fairly clean; that's the reason why I

     believed it was operable.

            Q.    Okay.

                  So if you thought the vehicle was

     operable, why then would you, without knowing if it

     had a battery or alternator, check yes to those

     columns?

            MR. LEONARD:  Objection, leading, asked and

     answered.

            THE COURT:  Overruled.

            A.    I made the assumption of putting yes on

     the battery and alternator because the vehicle

     appeared driveable.

            Q.    (BY MR. MEDVENE)  I don't mean to

     embarrass you, I also don't know where it is, do you

     know where the alternator is on a vehicle?

            A.    It's underneath the hood, sir.

            Q.    Somewhere underneath there?

            A.    Somewhere under there.

            Q.    Okay.



                         (Laughter.)



            Q.    During your hours watching the Bronco as

     part of your duties, did you ever enter the Bronco?

            A.    No.

            Q.    Did you ever open the hood?

            A.    No.

            Q.    Ever open the trunk?

            A.    No.

            Q.    Ever open any of the doors?

            A.    No.

            Q.    Did Officer Thompson ever open the hood?

            A.    No.

            MR. LEONARD:  Objection, lack of foundation,

     calls for speculation.

            THE COURT:  Sustained.

            Q.    (BY MR. MEDVENE)  In your presence, did

     Officer Thompson ever open the hood?

            A.    No.

            Q.    The doors?

            A.    No.

            Q.    The trunk?

            A.    No.

            Q.    In your presence, did anyone ever open

     the car?

            A.    No.

            Q.    Ever open the trunk?

            A.    No.

            Q.    Ever open the hood?

            A.    No.

            MR. MEDVENE:  Thank you very much.  I have

     nothing further.

            THE COURT:  Cross-examine.



                       CROSS-EXAMINATION

     BY MR. LEONARD:

            Q.    Good morning, Officer Guzman.

            A.    Good morning.

            Q.    Is this the way -- the fashion in which

     you filled out this report, is that the way they

     taught you to do it at the academy?

            A.    I was in training at the time and I was

     being taught during the course of my training, sir.

            Q.    Did they tell you that you could just

     make assumptions about whether these parts of the car

     are actually there?

            A.    No, sir.

            Q.    They told you that you had to actually

     visualize that or look at it to confirm that, in fact,

     those parts were there when you filled out the report,

     right?

            A.    That's correct.

            Q.    So you made a mistake when you did this,

     right?

            A.    That's correct, sir.

            Q.    You weren't as careful as you could have

     been at filling out the report?

            A.    That's correct.

            Q.    Now, you testified to this jury that you

     didn't see anyone, Officer Thompson, or anyone else,

     go into that car, correct?

            A.    Yes.

            Q.    And part of your job was to be as

     vigilant and careful as you could in making sure that

     no one approached the car who wasn't permitted to do

     so, correct?

            A.    Correct.

            Q.    And you didn't have your eye on that car

     the whole time, did you?

            A.    No.

            Q.    You don't know if somebody got in that

     car at some point when you weren't watching, correct?

            A.    Correct.

            Q.    And is it fair to say that you were as

     careful watching that vehicle as you were in filling

     out that report?

            A.    That's correct.

            Q.    Thanks.



                      REDIRECT EXAMINATION

     BY MR. MEDVENE:

            Q.    Approximately how much of your -- strike

     that.

                  Can you tell the ladies and gentlemen of

     the jury whether the car was generally in your sight

     during your time at Rockingham?

            A.    Yes, it was.

            MR. LEONARD:  Objection, asked and answered,

     Your Honor.



                         (The Court reviewed real time

                         screen.)



            THE COURT:  Overruled.

            Q.    (BY MR. MEDVENE)  Was the car generally

     in your sight when you were at Rockingham?

            A.    Yes.

            Q.    If someone -- while that car --

     generally -- Strike that.

                  You've told us the car was generally in

     your sight.  Did you see anyone, any officer, any

     person, open up some car door and pour blood in the

     car while you were there?

            A.    No.

            MR. LEONARD:  Objection, asked and answered,

     and argumentative.

            THE COURT:  Sustained.

            (BY MR. MEDVENE)  Did you ever talk to anyone,

     any officer, about being part of some conspiracy to

     cover up the fact that some officer, while you were

     there, would open up the car door, pour blood in it,

     and you weren't supposed to say anything about it?

            A.    No.

            MR. LEONARD:  Same objection, Your Honor.

            THE COURT:  Sustained.

            MR. MEDVENE:  I have nothing further.

            MR. LEONARD:  Move to strike.

            THE COURT:  Stricken.

                  You going to ask some more questions?



                         (Mr. Leonard indicates index

                         finger.)



            THE COURT:  Go ahead.



                      RECROSS-EXAMINATION

     BY MR. LEONARD:

            Q.    (BY MR. LEONARD)  You saw Detective

     Fuhrman when you arrived there?

            A.    Yes.

            Q.    You don't know if he ever entered the

     car, do you?

            A.    No, I don't.

            Q.    Thank you.



                      REDIRECT EXAMINATION

     BY MR. MEDVENE:

            Q.    All the times you were watching the car,

     did you ever see Detective Fuhrman enter the car?

            A.    No.

            Q.    Any officer enter the car?

            A.    No.

            Q.    Thank you.

            THE COURT:  Okay.  You may step down.  You're

     excused.

            THE WITNESS:  Thank you, sir.

            MR. LAMBERT:  Plaintiffs call Dr. Terry Lee,

     Your Honor.



                           TERRY LEE,

     was called as a witness on behalf of the Plaintiffs,

     was duly sworn and testified as follows:



            THE CLERK:  You do solemnly swear that the

     testimony you may give in the cause now pending before

     this court shall be the truth, the whole truth, and

     nothing but the truth, so help you God?

            THE WITNESS:  I do.

            THE CLERK:  Please be seated.

            THE BAILIFF:  Please be seated.

            THE CLERK:  Sir, would you please state and

     spell your name for the record.

            THE WITNESS:  My name is Terry Lee, T-e-r-r-y

     L-e-e.

            MR. LAMBERT:  Thank you, Your Honor.



                       DIRECT EXAMINATION

     BY MR. LAMBERT:

            Q.    Good morning, Dr. Lee.

                  You are a Ph.D., sir?

            A.    Yes.

            Q.    When did you obtain your Ph.D.?

            A.    I obtained my Ph.D. degree in 1977 from

     the University of Oregon.

            Q.    And in what field did you obtain that

     degree?

            A.    Chemistry.

            Q.    And since obtaining your Ph.D., what has

     been your occupation, sir?

            A.    I have been a research scientist.

            Q.    Where were you first employed after

     obtaining the Ph.D.?

            A.    I first took a post doctoral position at

     Oregon Graduate Center for a period of three years,

     after which I took a position at Cetus Corporation

     which is a technology company in the Bay area.  And

     then finally, I ended up at Beckman Research Institute

     at the City of Hope.

            Q.    Dr. Frederic Rieders told the jury when

     he was here that he's testified as an expert witness

     in excess of 100 times.

            MR. BAKER:  Objection, irrelevant what he told

     this jury.

            MR. LAMBERT:  I haven't asked the question.

            MR. BAKER:  The preamble is argumentative.



                         (The Court reviewed real time

                         screen.)



            THE COURT:  Sustained.

            Q.    (BY MR. LAMBERT)  How many times,

     Dr. Lee, have you testified as an expert witness?

            A.    This is my first time.

            Q.    So you are not a professional expert

     witness?

            A.    No.

            Q.    If you are not a professional witness,

     sir, would you tell the jury what you are, sir?

            A.    I'm a research scientist.  I do research

     and analysis of molecules by liquid chromatography and

     mass spectrometry.

            Q.    You indicated you're now employed by the

     Beckman Research Center of the City of Hope?

            A.    Yes.

            Q.    Would you tell the jury what the City of

     Hope is?

            A.    The City of Hope is -- it's two things:

     It's a national cancer treatment center, it's also a

     research institute.

            Q.    And you're involved in the research side

     of that institute?

            A.    That's correct.

            Q.    How long have you been affiliated with

     Beckman Research Center with the City of Hope?

            A.    14 years.

            Q.    Can you tell the jury what your position

     is at the City of Hope?

            A.    My official title is research scientist.

     I do studies related to the analysis of biomolecules

     by mass spectrometry.

            Q.    You had headed the mass spectrometry

     section of the Beckman Research Center?

            A.    Yes.  Immunology has a mass spectrometry

     section; I'm the head of that section.

            Q.    Are you familiar with the profession

     known as liquid chromatography?

            A.    Yes, I am.

            Q.    One of the processes that is at issue in

     this case is a cell called HPLC test.  Are you

     familiar with that test?

            A.    Yes.

            Q.    How long have you been involved in doing

     HPLC tests?

            A.    Since my graduate work, so it would be in

     excess of 20 years.

            Q.    How many times have you yourself run

     tests using the HPLC method?

            A.    Hundreds of times.

            Q.    One of the other tests at issue in this

     case involves the use of liquid chromatography

     combined with tandem mass spectrometry using an

     electrospray interface, what Dr. Rieders referred to

     as LCESMSMS; are you familiar with that technology?

            A.    Yes, I am.

            Q.    How many times have you, yourself, run

     tests using such technology?

            A.    Hundreds of times.

            MR. LAMBERT:  I'd like to mark as the next

     exhibit in order which is --

            MR. FOSTER:  It's got a number.

            MR. LAMBERT:  No, the next exhibit in order,

     which is --

            THE CLERK:  2403.

            MR. LAMBERT:  2403.

                         (The instrument herein referred to

                         as curriculum vitae of Dr. Terry

                         Lee was marked for identification

                         as Plaintiffs' Exhibit No. 2403.)



            Q.    (BY MR. LAMBERT)  This is a copy of your

     resume, Dr. Lee?

            A.    Yes, it is.

            Q.    Is that current?

            A.    Yes.

            Q.    According to your resume, you've written

     129 articles that are listed on the resume.

                  Do any of those articles deal with mass

     spectrometry of the type that's at issue in this case?

            A.    Yes.  Nearly all of the articles in

     recent years have been related to that particular

     topic.

            Q.    And are any of those peer review

     articles?

            A.    Yes.  Nearly all of them.

            Q.    Now, have you reviewed the various tests

     performed by FBI Agent Martz on certain evidence

     samples from this case?

            A.    Yes, I have.

            Q.    Can you tell the jury precisely what you

     have reviewed in preparation for coming here?

            A.    I reviewed the analyses that were

     submitted to the -- to the I.G.'s -- the Court,

     related to direct analyses of the samples.

                  There was also a set of analyses that

     were termed validation studies which I believe were

     not done by Agent Martz but by other people at the

     FBI.

                  I reviewed Martz's testimony that he gave

     in the criminal trial.

                  I reviewed Dr. Rieders' testimony that he

     gave at the criminal trial.

                  I reviewed Dr. Rieders' testimony that he

     gave in this trial.

            Q.    Have you been asked to determine from the

     test results of Agent Martz whether or not the

     evidence samples tested by Agent Martz could have come

     from test tubes treated with the chemical EDTA?

            A.    Yes.

            Q.    Have you formed an opinion in that

     regard?

            A.    Yes, I have.

            Q.    What is that opinion?

            A.    My opinion is that it could not have come

     from those test tubes.

            Q.    Now, one of the tests that Agent Martz

     performed is a test that he called a negative ion

     test.

                  What kind of a test is that, sir?

            A.    That refers to negative ion mass

     spectrometry.  In mass spectrometry, you have the

     option of looking at either positive ions or negative

     ions.

                  In that particular analysis, Agent Martz

     found no evidence that there was any contamination in

     the blood samples by EDTA.

            Q.    When Agent Martz performed the negative

     ion test, was he able to see any EDTA at all in the

     evidence samples?

            A.    No.

            Q.    Have you yourself ever performed a

     negative ion test?

            A.    Yes.

            Q.    Have you reviewed the results of other

     persons who have performed them?

            A.    Yes, I have.

            Q.    Are you familiar with those tests?

            A.    Very familiar.

            Q.    Now, another test that Agent Martz

     performed is what we've talked about earlier, this

     so-called HPLC test, and would you describe briefly

     what an HPLC test is?

            A.    HPLC is -- is short for high pressure or

     high performance liquid chromatography.  It separates

     mixtures, and the analysis relies upon being able to

     separate what you want to look for from everything

     else and assign what is called a retention time to it.

     The identification is based on the retention time of

     the compound coming out of the instrument and the UV

     absorbance signal that the detector monitors.

            Q.    You mentioned before you yourself have

     performed many of these tests?

            A.    Yes, hundreds.

            Q.    And reviewed results of other people as

     well.

                  Is that part of your functions as the

     head of the mass spectrometry unit at the City of

     Hope, to review other people's test results?

            A.    Yes.

            Q.    Now, what do Agent Martz's HPLC tests

     show as to the possible presence of EDTA from a

     purple-top test tube in the evidence item?

            A.    There was no indication at all in those

     tests of any EDTA present in those samples.

            Q.    So both the negative ion test and the

     HPLC test showed no evidence of EDTA at all?

            A.    That's correct.

            Q.    Finally, Dr. Lee, Agent Martz also

     performed a so-called positive ion mode test.

                  What kind of test is that, sir?

            A.    That's a test exactly like the negative

     ion test except you're looking at the positive ions

     instead of the negative ions.

            Q.    That's another form of the LCESMSMS

     testing technology?

            A.    That's correct.

            Q.    Have you yourself performed such tests?

            A.    Yes.

            Q.    How many times?

            A.    Hundreds of times.

            Q.    Have you ever reviewed the test results

     of other people?

            A.    Yes, I have.

            Q.    How often?

            A.    Hundreds of times.

            Q.    Now, incidentally, Dr. Lee, are you

     familiar with the equipment that Agent Martz used to

     perform these tests?

            A.    Yes.  We have the same equipment in our

     laboratory.

            Q.    You have the very same equipment you used

     in your lab?

            A.    It's the same mass spectrometry and the

     same electrospray source, yes.

            Q.    Have you yourself used that equipment?

            A.    Yes.

            Q.    So you're familiar with the equipment?

            A.    I'm very familiar with it.

            Q.    When Agent Martz ran the LCESMSMS test in

     the positive ion mode to determine whether he could

     detect the presence of EDTA in the known sample, that

     is in a sample of blood from a purple-top test tube,

     was he able to detect EDTA in that testing mode?

            A.    Yes, he got a very strong signal for

     those kinds of samples.

            Q.    So the EDTA was clearly present and

     visible under the testing procedure?

            A.    Yes.

            Q.    Now, when Agent Martz ran the LCESMSMS

     test in the positive ion mode on the evidence samples

     in this case, was he able to obtain the same kind of

     showing as he did when he ran the known samples?

            A.    No.

            Q.    In those tests on the evidence samples,

     did Agent Martz obtain signals indicating the presence

     of blood from an EDTA-treated tube in the evidence

     samples?

            A.    No.

            MR. LAMBERT:  Let's put up Exhibit 2294.



                         (Exhibit 2294 is displayed.)



            MR. LAMBERT:  This isn't quite focused.

            MR. FOSTER:  It's too far away.

            MR. LAMBERT:  Yeah.  This is a little bit out

     of focus up here.  Little more.  Little more.  Little

     more.  Well, trouble is, we want to be able to see the

     whole thing.

            MR. FOSTER:  That's the problem.

            MR. LAMBERT:  Put the whole thing up.  We'll

     continue.  I want to see the whole chart.

            Q.    (BY MR. LAMBERT)  Can you explain to the

     jury what this exhibit depicts?

            A.    This is a direct comparison of the -- of

     one of the analyses for the blood which came from a

     purple-top tube comparing that with analyses of the

     evidence sample blood.

            Q.    This signal here, this mountain-like

     signal, what is that showing us?

            A.    That's the signal that he got from the

     EDTA blood.

            Q.    From -- this is the blood from the

     purple-top test tube?

            A.    That's the purple-top test tube, yes.

            Q.    This small signal down here, what does

     that signal --

            A.    That's the signal that he obtained from

     the blood that came from the evidence sample.

            Q.    Okay.

                  Now, this -- this showing that he got

     from the evidence sample, the small little mole hill

     of a showing, in your opinion, could that showing be

     reflecting blood from a purple-top test tube?

            A.    No.

            Q.    And why not, sir?

            A.    The intensity difference is too great.

     Agent Martz, because he didn't have an internal

     standard, he designed his experiment such that if

     there was any errors in the quantitation, that he

     would err in the right way; in other words, he would

     always attempt to use more blood from the evidence

     sample than he would from his positive control.

                  In this case, there's 100 times or more

     greater intensity from blood obtained from a

     purple-top tube than he would get from his evidence

     sample.

                  So that result is inconsistent with the

     blood from the evidence sample having come from a

     purple-top tube.

            Q.    And the procedure that Agent Martz used,

     is that a standard operating procedure for somebody

     using these mass spectrometry machines?

            A.    Yes, it's a standard operating procedure

     when you don't have an internal standard that you can

     do exact quantitation with.

            Q.    And when Agent Martz did these tests, was

     there an internal standard commercially available to

     do these tests?

            A.    There was not.

            MR. LAMBERT:  Let's put up the next one.  This

     will be a new one.

            THE CLERK:  2404.



                         (The instrument herein described

                         as Chart was marked for

                         identification as Plaintiffs'

                         Exhibit No. 2404.)



            Q.    (BY MR. LAMBERT)  The one we just looked

     at was for K206 or Q206 this is for Q204.

                  Is this the same type of chart that you

     just showed us?

            A.    Yes.

            Q.    So for both of the two evidence samples,

     socks and back gate, tested by Agent Martz, he got

     only a trace signal from the evidence sample and some

     mountainous signal from the known sample?

            A.    That's correct.

            Q.    And once again, Doctor, is it your

     opinion -- what is your opinion as to whether these

     little trace signals could have come from a purple-top

     test tube?

            A.    In my opinion, they could not have come

     from a purple-top test tube.

            Q.    Now, did Agent Martz also perform these

     same tests on his own blood?

            A.    He did.

            Q.    And what results did he obtain when he

     did that test?

            A.    He got essentially equivalent results

     with his own blood as far as the trace level of EDTA

     that were detected in his analyses.

            Q.    So when Agent Martz took out his own

     blood and tested it in the machine, he got this same

     little signal from his own blood?

            A.    That's correct.

            Q.    And from a scientific point of view,

     Dr. Lee, could you tell us what the significance of

     that is?

            A.    The significance, from a scientific point

     of view, is that since the signal and response are the

     same, that the likely source of that signal was

     possibly the same.

            Q.    Well, Dr. Rieders testified that this

     wide variation between the small signal shown in the

     evidence sample and the very large signal shown in the

     known sample could be the result of some error by

     Agent Martz in measuring the amount of the evidence

     sample.

                  Do you believe Dr. Rieders could be

     correct in that regard?

            A.    No, I don't.  I think that is extremely

     unlikely.  Blood is a colored substance, so if there

     was a very large error, in this case it would have to

     be larger than a -- greater than a ten-fold error,

     then the solution you were sampling from would have

     been colored differently.  That's a difference that

     you would not be able to overlook.

            Q.    And did Agent Martz run these experiments

     more than one time?

            A.    He ran them several times.

            Q.    So if Dr. Rieders is right, would Agent

     Martz have to have made the same error every time he

     ran them?

            A.    That's correct.

            Q.    And I think you mentioned that Agent

     Martz was intentionally trying to use more of the

     evidence sample than the known sample.

                  Is that your understanding?

            A.    That's correct --

            MR. BAKER:  Objection, no foundation for that.

            A.    -- Yes.

            THE COURT:  Lay a foundation for that.

            Q.    (BY MR. LAMBERT)  You read Dr. Roger

     Martz's testimony?

            A.    It's contained in Dr. Martz's testimony

     in the criminal trial.

            THE COURT:  Overruled.

            Q.    (BY MR. LAMBERT)  So he was intentionally

     trying to use more evidence sample than the known

     sample; is that your understanding?

            A.    That's my understand.

            Q.    That's what would be standard operating

     procedure for a mass spectrometer doing these tests?

            A.    For doing these kinds of analyses, that's

     what you would do, yes.

            Q.    Dr. Rieders also tried to explain the

     difference between the small signal from the evidence

     sample and the large signal from the known sample by

     saying that it was possible that the EDTA in the

     evidence sample had somehow degraded before these

     tests were run.

                  Is there any scientific literature that

     supports Dr. Rieders' opinion that EDTA could degrade

     so significantly?

            A.    None that I'm aware of.

            MR. BAKER:  Objection.

            Q.    (BY MR. LAMBERT)  Do you believe that

     Dr. Rieders is correct or incorrect in that regard?

            A.    I believe he's incorrect.

            Q.    Why is that, sir?

            A.    EDTA is a very unstable compound; it's

     not likely to degrade under normal circumstances.  And

     these evidence samples were -- came from different

     places and were treated differently; yet they all show

     the same levels.  And so it's difficult to imagine the

     degradation that would be common to all the samples.

            Q.    And if Dr. Rieders was correct in his

     degradation theory, how would that explain the results

     that Agent Martz got in his own blood?

            A.    It wouldn't.

            Q.    As a scientist, Dr. Lee, what is the most

     likely explanation for this very small trace that is

     shown in the evidence sample here in this one test

     that Agent Martz did?

            A.    These results are consistent with a

     carryover from -- in the instruments.  In other words,

     if you first analyze on the instrument samples which

     contain a large quantity of EDTA and then you

     subsequently come in with the samples that don't have

     any, it's not uncommon to pick up trace levels from

     various parts of the instruments that have been

     contaminated with the EDTA and then subsequently

     alluded off when you did the other analyses.

            Q.    And is that a common problem with the

     LCESMSMS instruments?

            A.    It's a common problem with those

     instruments, yes.

            Q.    Is it something that you yourself have

     experienced?

            A.    Many times.

            Q.    And is it something that other people

     that do mass spectrometry have experienced as well?

            A.    Yes.

            Q.    And if people are very experienced in

     doing mass spectrometry, is it something that they are

     aware of is a problem with the instruments?

            A.    Yes.

            Q.    Despite, therefore, the small trace

     showings that we have on this chart for the evidence

     sample, are you of the opinion, Doctor, that there is

     no way that those evidence samples could have come

     from a purple-top test tube?

            MR. BAKER:  Leading, suggestive.

            THE COURT:  You may answer.

            A.    That's my opinion, yes.

            MR. LAMBERT:  I have no further questions.

            THE COURT:  Cross-examine.



                       CROSS-EXAMINATION

     BY MR. BAKER:

            Q.    Good morning, sir.

            A.    Good morning.

            Q.    Now, Dr. Lee, as I understand it, you

     were hired to refute the presence of EDTA in the blood

     samples that came from the socks and the back gate

     that was tested by Agent Martz, correct?

            A.    I was hired to review the data and give

     an expert opinion about it.

            Q.    And you were -- in terms of your review,

     you relied upon agent Rodger Martz, right?

            A.    I reviewed his data; I did not talk to

     him personally.

            Q.    Well, you relied upon the data that he

     had generated; you relied upon the testimony that he

     gave at the criminal trial; true?

            A.    That's what I used.  That's the evidence

     that I looked at, yes.

            Q.    And you were told by Mr. Lambert here,

     not to contact Rodger Martz, were you not?

            A.    I was told that I could not contact him.

            Q.    And you were told that you could not

     contact Rodger Martz because the FBI didn't want to

     get involved in the civil case?

            A.    That was my understanding.

            Q.    Did you know there's an FBI agent in town

     waiting to testify in this case?

            A.    No, I didn't.

            Q.    Do you know that we've had two FBI agents

     testify in this case?

            A.    No.

            Q.    Did you ever again ask to contact Rodger

     Martz to see what his opinions were relative to

     whether or not a ghost effect or cross-over could be

     the reason for the levels of EDTA in the samples in

     the -- from the back gate and the socks?

            A.    No.

            Q.    You were aware when you did your --

     arrived at your opinions, that Rodger Martz was not

     requested to find quantities in EDTA, correct?

            A.    He was requested to determine whether or

     not there was evidence that the blood from the

     evidence samples came from a purple-top tube.

            Q.    Next in order.

                  Have you ever seen the letter of

     Mr. Harmon from the D.A.'s office to the -- to Rodger

     Martz?

            A.    I don't know.  If it was included in the

     volumes of materials I had, yes, I saw it.

            Q.    It would be important for you to know

     exactly what Rodger Martz was attempting to do in

     arriving at your opinions and conclusions, since you

     didn't do any test to determine EDTA in any sample,

     correct?

            A.    Would you state that again?  I'm not sure

     I followed it.

            Q.    Okay.  Sure be happy to.

                  You did absolutely no testing yourself,

     correct?

            A.    That's correct.

            Q.    And you don't have -- never designed a

     test to determine the presence or absence of EDTA;

     correct?

            A.    That's correct.

            Q.    And you knew from your reading of

     material, that Rodger Martz had never designed a test

     to determine the presence or absence of EDTA in any

     material; correct?

            A.    Prior to the work that he did, that's

     correct.

            Q.    Okay.

                  And you're aware it took him a week to

     design the test; correct?

            A.    That's correct.

            Q.    You're aware that when he designed this

     test, he did not design it to determine quantities;

     true?

            A.    That's partially true.  He did not design

     it to actively determine quantities.

            MR. LAMBERT:  Objection.  Object to the use of

     this exhibit, not being relied upon by the witness in

     giving his opinion.

            THE COURT:  Sustained.

            MR. BAKER:  It's in evidence, Your Honor.  It's

     cross-examination of this witness.

            MR. LAMBERT:  It's not in evidence.

            THE COURT:  Show it to him.

            MR. BAKER:  Huh?

            THE COURT:  Show it to him.

            MR. BAKER:  All right.

            MR. LAMBERT:  It's not in evidence.

                  I object to it going into evidence.

            THE COURT:  He said in evidence, or -- it's not

     in evidence?

            MR. LAMBERT:  No.

            MR. BAKER:  Is it in evidence?

            MR. P. BAKER:  I don't think that document is

     in yet.

            MR. LAMBERT:  There's no foundation.

            THE COURT:  Okay.  I'll sustain the objection.

            Q.    (BY MR. BAKER)  Well, let me ask you

     this:

                  You certainly became aware, from reading

     the testimony of Rodger Martz in the criminal trial,

     that he was to refute the possibility that the stain

     on the socks would -- could have come from Nicole's

     reference sample, sample number 59; correct?

            A.    It was his purpose to determine if that

     was a possibility, yes.

            Q.    And he was also to refute the possibility

     that item number 117 could have come from

     Mr. Simpson's reference sample; right?

            A.    He was asked to determine if that was a

     possibility, yes.

            Q.    And he was asked to make those

     determinations and not to quantify at all.  And, in

     fact, he didn't quantify; true?

            A.    He did not accurately quantify the level

     of EDTA in those samples; that's correct.

            Q.    He didn't even attempt to quantify at all

     in designing his test, did he, sir?

            A.    Well, that depends upon what you mean by

     "quantify."  Any occasion, in order to draw a

     conclusion, you have to have some idea about the

     quantity involved; otherwise, you can't draw a

     conclusion based upon whether or not it's even there.

            Q.    Let me read to you what you read of

     Mr. Martz's testimony in the criminal trial at 38641,

     lines 1 through 5.

                         Q.     By the way, is the method

                  that you used, any of the methods that

                  you used, quantitative methods?

                         A.     I did not specifically use

                  these methods to quantitate the amount

                  of EDTA.



                  That's what his testimony was, was it

     not, sir?

            A.    That's correct.

            Q.    Okay.

                  Now, you in coming and arriving at your

     opinions, are not saying that wasn't EDTA; you're

     saying that the amount -- the quantity is too little;

     and hence, you don't believe it came from a purple-top

     test tube, correct?

            A.    That's correct.

            Q.    So you are using quantities, where

     Mr. Martz, in his tests, determined -- or attempted

     not to quantify anything; correct?

            A.    The --

            Q.    Well, can you answer that?

            A.    It's a matter of semantics.

            Q.    Can you answer that question, sir?

            A.    Yes.  Could you ask it again?

            Q.    You are attempting to use quantity to --

     in arriving at your opinion that -- that this EDTA

     that was found in the samples from both the back gate

     and the socks, was not EDTA from a purple-top test

     tube; correct?

            A.    Yes.

            Q.    All right.

                  And you are fully aware that Rodger Martz

     does not use quantity to make any determination

     relative to EDTA, nor was he asked to; correct?

            A.    By the strict definition of quantitative

     analysis, he was not doing that.

            Q.    Can you answer my question, sir?

                  He was not using --

            A.    I can answer.

                  I can tell you, as an expert, that I

     could draw no conclusions whatsoever unless he had

     some measure of the amount of material present.

            Q.    Now --

            A.    He has to know the limits of the

     sensitivity, the limits of his detection, limits --

     all these things he has to know, or his analysis means

     absolutely nothing.

            Q.    And you're aware that he testified that

     the levels of EDTA or -- strike that -- what he found

     on the 206 and 207 was consistent with EDTA on the

     back gate and the socks, correct?

            A.    No.

            Q.    Maybe we'll get that in a minute.

            MR. BAKER:  You want to put that up?

            MR. P. BAKER:  This is next in order.

            THE CLERK:  2405.

            MR. P. BAKER:  Dr. Lee's notes.



                         (The instrument herein referred to

                         as Dr. Terry Lee's notes was

                         marked for identification as

                         Defendant's Exhibit No. 2405.)



            Q.    (BY MR. BAKER)  Now, you said in your

     notes --

            MR. BAKER:  Go down to outcome No. 3.

            MR. P. BAKER:  (Adjusts Elmo.)

            MR. BAKER:  Back it off, please.

            Q.    (BY MR. BAKER)  "If detectable levels of

     EDTA are found in the stains, but significantly lower

     than the levels from blood in the tube, then

     interpretation becomes problematic."

                  What you meant by that, sir, it becomes a

     problem to determine the EDTA.  Isn't that true, sir?

            MR. LAMBERT:  Objection.  Argumentative.

            A.    No.

            Q.    (BY MR. BAKER)  Let's go down to the next

     one.

                  You say, if not planted -- can you read

     that for us -- convincing argument must be found why

     EDTA is present at that level.

            A.    Yes.  You want me to read it?

            Q.    Yes, because I have trouble reading your

     writing.

            A.    So do I.

            Q.    I can understand that.

            A.    "If not planted, convincing argument must

     be found for why the EDTA is present at these levels.

            Q.    Now, read the next one.

            A.    I can't even finish that one.

            Q.    I'm sorry.

            A.    I think it's -- I don't know that word.

            Q.    You were attempting to find convincing

     argument as to why the EDTA --

            A.    Oh, I think I can do it now.

                  One would be direct contamination from

     either the environment or contamination from the lab

     during the sample analysis.

            Q.    So you were attempting to find convincing

     argument to explain away the EDTA found by Rodger

     Martz, and you understood that to be your -- your --

     your goal; correct, sir?

            A.    No, that wasn't my goal.

                  My goal was to understand why the trace

     levels that were observed in that particular analysis

     were there.

            Q.    Well, now, so you came up with this

     ghosting or carry-over effect from the equipment,

     correct?

                  That's your theory of why these levels of

     EDTA were found by Rodger Martz?

            A.    Another most reasonable explanation, yes.

            Q.    You have no information whatsoever about

     how Rodger Martz runs his lab, correct?

            A.    Direct information, no.

            Q.    And from a the available data, you can't

     determine what the matrix used to dissolve the sample.

     You can't determine the quantity and you can't

     determine the volume equilibrium was done before the

     next analysis, can you?

            A.    There was statements in the materials

     that I reviewed with -- with regard to the matrix,

     with -- with -- with regard to rough estimations about

     the quantity.

                  I have no information at all with regard

     to the exact procedures with respect to the

     chromatography and the sample injection procedures.

            Q.    You would agree it's sheer speculation --

            MR. BAKER:  You can take that down.

            Q.    (BY MR. BAKER)  -- it's sheer speculation

     on your part as to whether or not there was any

     ghosting or cross-over effect; true?

            A.    No.  My opinion is based upon evidence.

            Q.    Well, your opinion --

            A.    The data that's present there tells me

     something.

            MR. PETROCELLI:  Need a break, Your Honor for

     the juror?



                        (Juror is coughing.)



            THE COURT:  Do you want to take a recess?

            JUROR:  I'm okay.

            THE COURT:  All right.  You --

                  All right.  Let's a take a ten-minute

     recess.

                        (Recess.)



                         (Jurors resume their respective

                         seats.)



                       CROSS-EXAMINATION

     BY MR. BAKER:

            Q.    You discussed in your deposition the way

     to design an experiment in such a way there would be

     no carryover effect?

            A.    Yes, we discussed those things.

            Q.    And you had testified that you'd have to

     be very, very careful about the blank, correct?

            A.    That's correct.

            Q.    You testified that the blank would have

     to be done exactly the same way the samples were done,

     using exactly the same matrix, exactly the same

     volume, and exactly the same procedure?

            A.    Yes.

            Q.    And if you do that, you would have

     greater confidence that what you were seeing in your

     samples came from what was exactly in the sample; is

     that correct?

            A.    That's correct.

            Q.    And you don't know whether or not Roger

     Martz designed the experiments and was very, very

     careful about his blank, was done exactly the same way

     as the samples were done, using exactly the same

     matrix, exactly the same volume, and exactly the same

     procedure, do you?

            A.    I know what his blanks are.  I don't know

     about his procedures, yes.

            Q.    And now, you would obviously love to talk

     to Roger Martz, wouldn't you?

            A.    I think it would be a very interesting

     conversation.

            Q.    Yeah.

                  And you testified that you'd love to, but

     Tom Lambert told you couldn't?

            MR. LAMBERT:  Objection, argumentative,

     misstates its testimony.

            THE COURT:  Overruled.

            A.    He told me that Roger Martz was

     unavailable.

            Q.    Speaking of Roger Martz; page 17, lines 1

     through 11.



                         (Mr. Baker read a portion of Terry

                         Lee's deposition transcript.)



                      Q.     Have you ever made an effort

               to contact him, to ask him whether he agreed

               with your opinion?

                      A.     I was told that he was not

               available for me to contact.

                      Q.     Who told you?

                      A.     Tom Lambert.

                      Q.     Did he tell you why he was not

               available?

                      A.     Well, I don't recall exactly

               what he said, but the impression was that

               the FBI kind of wanted to stay out of the

               civil matter.  I would love to talk to him.

            Q.    (BY MR. BAKER)  That's what you testified

     to?

            MR. LAMBERT:  Objection, improper impeachment,

     it's not at all inconsistent with what he said.

            THE COURT:  I'll sustain that because you

     asked, and he answered the same question before in the

     same way.

            Q.    (BY MR. BAKER)  Now, you were talking a

     little bit during the examination by Mr. Lambert about

     Roger Martz testing his own blood; do you recall that?

            A.    Yes.

            Q.    And you're aware that Roger Martz threw

     away all the computer data relative to the test on his

     own blood, correct?

            A.    That's my understanding.  He threw away

     all the computer data as to any of the test.

            Q.    No one could ever go back and see, but we

     know -- you are aware that the tests that Roger Martz

     ran on his own blood is icorrect, correct?

            A.    Incorrect in what sense?

            Q.    That's a poor question.  I apologize.

                  The levels that he found in his blood is

     inconsistent with life, correct?

            A.    If you're saying that it would be

     impossible for him to have found EDTA levels at those

     levels in his own blood, that is true, but he didn't

     know that at the time.

            Q.    He was alive; he knew that, didn't he?

            A.    Yes.  But he didn't know it was

     impossible for him to have EDTA levels that high in

     his own blood; he did not know that.

            Q.    You talked to him about that?

            A.    No.

                  There's no way I could have known.

     Nobody knew it at that point.

            Q.    Now, it is common knowledge in the

     scientific industry that there are no detectable

     levels of EDTA in a normal human being's blood,

     correct?

            A.    In the past year there have been two labs

     that have designed tests to prove that point, and they

     have determined that there's no detectable levels of

     EDTA in anybody's blood.

            Q.    And so if, for example, Richard Fox were

     on the stand yesterday and testified that there can be

     EDTA levels in human blood, that's incorrect?

            A.    That's incorrect.

            Q.    And we know presently, of course, that

     EDTA is not in human blood to the level that was found

     by Roger Martz in his experiments done on the blood

     samples from both the back gate and the socks, true?

            A.    I'm sorry.  That was a long question.  I

     lost part of it.  Could you repeat that, please.

            Q.    I get these notes -- I have I got an I.Q.

     that's about ground level, so I have to rephrase and

     think back of what I was asking you.

                  But -- But basically, in terms of EDTA,

     the EDTA that Roger Martz found in his test from the

     samples of the back gate and the socks would not be in

     a normal person's blood; you would agree with that?

            A.    I would agree that he could not find --

     he would not detect any EDTA in a normal person's

     blood, that's true.

            Q.    If his test results were in fact

     accurate, if EDTA was in both the samples from the

     back gate and the socks, they had to have been

     planted, if your theory is incorrect; you would agree

     with that?

            A.    I would say there is another

     possibility -- there may be another possibility, a

     possibility that I haven't thought of.

            Q.    Well, you had a lot of time, haven't you?

            A.    Yes.

            Q.    Okay.

                  And your possibility, sir -- you have

     absolutely no facts to substantiate that there was any

     cross-over effect or ghosting effect on this machine,

     true?

            A.    That's not a statement of the facts.

     There's evidence in the data that would support that

     conclusion.

            Q.    Your argument, as I understand it, is

     because of the results, you believe that there is a

     ghosting or cross-over effect, correct, kind of a

     bootstrap approach, isn't it?

            MR. LAMBERT:  Objection, argumentative.

            Q.    (BY MR. BAKER)  Let me just ask this

     question.

            MR. BAKER:  I'll withdraw that.

            Q.    (BY MR. BAKER)  Let me ask you this

     question:

                  We've established that you certainly

     don't know what Roger Martz's lab procedures are,

     correct?

            A.    That is correct.

            Q.    You certainly do know that he was

     requested to determine that there was no EDTA in

     either the sample from the back gate or the socks,

     correct?

            MR. LAMBERT:  Objection, asked and answered.

            A.    That's not my understanding, no.

            Q.    (BY MR. BAKER)  He was given the job to

     refute any EDTA in the back gate or the sock samples,

     wasn't he?

            MR. LAMBERT:  Objection, argumentative, Your

     Honor, been asked and answered as well.

            THE COURT:  You may answer if you know.

            A.    I don't think the word "refute" is

     correct.  I think he was asked to determine whether or

     not that was a possibility.

            MR. LAMBERT:  I still object to any use of this

     letter.  There's no foundation for it.

            THE COURT:  Sustained.

            MR. BAKER:  I'll lay a foundation.  I'll tie it

     up if I have to get Rockne Harmon to come in here,

     Your Honor.  This was an exhibit in the criminal

     trial.

            MR. LAMBERT:  Your Honor, Roger Martz was a

     witness in the criminal trial.

                  He's not a witness in this trial.

     There's no foundation.

            MR. BAKER:  Your Honor, in that regard, all of

     this testimony is relative to what Roger Martz did.

     This witness didn't do any experiments, didn't do

     anything except look at what Roger Martz said, and if

     you give me a minute, I think I'll go over and find

     that letter.

                  Phil, look up Roger Martz's testimony and

     find that letter because I think this gentleman has

     already read it.

            Q.    (BY MR. BAKER)  If you read that

     testimony there's a lot of it.  I can understand,

     Dr. Lee, how you'd forget reviewing or reading that in

     the testimony because there was a lot of testimony

     from Roger Martz.

            THE COURT:  Okay.  Find it.

            MR. P. BAKER:  Can I see it?

            MR. BAKER:  Yeah.



                         (Mr. Baker handed a document to

                         Mr. P. Baker.)



            MR. P. BAKER:  It's Criminal Defense Exhibit

     1264, on July 25, page 38649.

            THE COURT:  I don't think that's what you're

     supposed to be finding.

            MR. P. BAKER:  Okay.

            Q.    (BY MR. BAKER)  Now, Mr. Martz -- let me

     show you 36648.  Mr. Martz was given a two-page

     letter, correct, that was Exhibit 1263, okay, and he

     reviewed 1263, correct?

            A.    That's what it says there.

            Q.    All right.

            THE COURT:  Okay.  That's foundation, go ahead.



            MR. P. BAKER:  Well, I'll mark this next in

     order.

            THE CLERK:  I don't think it is -- I think it's

     already been marked 1223.





                         (The instrument herein referred to

                         as a two-page letter dated 2/16/95

                         was marked for identification as

                         Defendants' Exhibit No. 1223.)



            Q.    (BY MR. BAKER)  Would you read what the

     request was to Roger Martz as an FBI agent, and what

     his goal was.



                         (Mr. Baker read from a letter,

                         mission statement, from Rockne

                         Harmon to Roger Martz.)



                      We would like you to test these items

               for the presence/absence of EDTA in order to

               refute the possibility that the stain on the

               sock could have come from Nicole's reference

               sample.

                      59 or 72 similarly, we'd like you to

               test Item 117 to refute the possibility that

               it could have come from Simpson's reference

               sample.



            Q.    So his mission statement, that is the

     mission statement of Roger Martz, was to refute that

     there was any EDTA in either the reference -- in the

     sample from the back gate or the socks; you would

     agree with that?

            MR. LAMBERT:  Argumentative, misstates the

     evidence as to what the letter says.

            THE COURT:  The argument seems to be over the

     word "refute."  I'll sustain it.

                  The letter speaks for itself.  You can

     argue over that.

            Q.    (BY MR. BAKER)  The letter says he was to

     refute the allegation that there was any blood from

     Mr. Simpson's or Nicole Brown Simpson's reference

     sample, does it not, sir?

            A.    I read it.

            Q.    Okay.

                  Roger Martz was in the FBI lab for 19

     years, wasn't he, when he ran these tests?

            A.    I don't remember.  I mean he could have

     been.  I have no idea how long he was in the lab.

            Q.    Page 386, 21, you don't dispute that he

     was in the lab --

            A.    No.

            Q.    -- for 19 years?

            A.    I have no knowledge of that.

            Q.    You don't dispute if he had the goal to

     refute there was any EDTA, that he would run his lab

     as best he could in an uncontaminated fashion to get

     the best results possible; you would agree with that?

            A.    Yes.

            Q.    So your theory here is that it was

     contaminated, he didn't do the test correctly, and the

     elements that you see are not because they were

     actually EDTA from a purple top test tube, but they

     were EDTA that was left somehow in the machine and

     occurred only on the samples from the socks and the

     back gate, right?

            A.    That's incorrect.

            MR. BAKER:  Nothing further.



                      REDIRECT EXAMINATION

     BY MR. LAMBERT:

            Q.    Dr. Lee, these notes that you were shown

     before by Mr. Baker, he just had you read this one

     paragraph which -- would you read both paragraphs to

     the jury and then explain what these notes are all

     about.



                         (Mr. Lambert read from a letter,

                         mission statement, from Rockne

                         Harmon to Roger Martz.)



            A.    (Reading:)



                      "If not planted, a convincing

               argument must be found for why the EDTA is

               present at those levels.  Direct

               contamination from environment or

               contamination from the lab during the sample

               process and it planted -- convincing

               arguments must be found to explain why the

               levels are so low.  Is to say why would --"

               where did the rest of it go?



                         (Indicating to Elmo screen.)

            Q.    And what is your intent in setting forth

     those two possibilities in your notes?

            A.    This was just organizing my thinking as

     to what the issues were.

            Q.    And you read the testimony of Dr. Rieders

     in both the criminal case and the civil case.

                  Did Dr. Rieders do any testing of his

     own?

            A.    No.

            Q.    Was he relying upon the same test results

     that you were relying upon for his --

            A.    Yes.

            Q.    -- Dr. Rieders' opinion?

                  Do they take into account all of the data

     in Roger Martz's set of data?

            MR. BAKER:  Well, I object.  That calls for

     speculation and conclusion on the part of this

     witness, and it's argumentative and outside the scope.



                         (The Court reviewed real time

                         screen.)



            THE COURT:  Overruled.

            A.    I'm sorry.  I've forgotten the question.

            Q.    (BY MR. LAMBERT)  Let me try again.

                  Did Dr. Rieders opinions account for all

     of the various test results that Martz got when he did

     his test?

            A.    No.

            Q.    Do yours?

            A.    I believe so, yes.

            Q.    The test results that Roger Martz got

     when he found this little trace, that little molehill

     that we saw in testing his own blood, you testified

     during the examination by Mr. Baker that that couldn't

     be actual EDTA in his own blood, true?

            A.    That's correct.

            Q.    And therefore, it has to be some artifact

     that's creating that trace result, correct?

            A.    That's correct.

            Q.    And what is your opinion of the artifact

     that's creating that trace result?

            A.    That artifact is most likely the result

     of carryover from previous analyses in that

     instrument.

            Q.    What's most likely creating the trace,

     little trace level, we saw in the evidence sample?

            A.    The same effect.

            Q.    And Dr. Rieders' opinions don't account

     at all for how that little trace shows up in Roger

     Martz's own evidence, own blood sample?

            MR. BAKER:  That's argumentative.  There's no

     way to know that, Your Honor.



                         (The Court reviewed real time

                         screen.)



            THE COURT:  Overruled.

            A.    Could we repeat the question so I am sure

     I answer it the right way.

            Q.    Do Dr. Rieders' opinion that he gave to

     this jury in this case explain how those little trace

     levels could have shown up in Roger Martz's own blood?

            A.    No.

            MR. LAMBERT:  No further questions, Your Honor.



                      RECROSS-EXAMINATION

     BY MR. BAKER:

            Q.    You want to be sure you answer the right

     way?

            A.    I wanted to be sure I answered the right

     question.

            MR. BAKER:  Nothing further.

            THE COURT:  You may step down.

            MR. LAMBERT:  Thank you.

                  Dr. Brad Popovich, Your Honor.



                       BRADLEY POPOVICH,

     called as a witness on behalf of the Plaintiffs, was

     duly sworn and testified as follows:



            THE CLERK:  You do solemnly swear that the

     testimony you may give in the cause now pending before

     this court shall be the truth, the whole truth, and

     nothing but the truth, so help you God?

            THE WITNESS:  I do.

            THE BAILIFF:  Please be seated.

            THE CLERK:  Please state and spell both your

     first and your last names for the record.

            THE WITNESS:  Yes.  My name is Brad Popovich,

     B-r-a-d-l-e-y  P-o-p-o-v-i-c-h.

            MR. LAMBERT:  Before I forget, could I move in

     2403 and 2404 from my examination of Dr. Lee.

            THE COURT:  Received.

            MR. BAKER:  1224 and 2405.

            THE CLERK:  That exhibit number is 1223.

            MR. LAMBERT:  I object to the letter on the

     grounds there no foundation.

            THE COURT:  Overruled.  Received.



                         (The instrument previously marked

                         as Plaintiffs' Exhibit 2403 for

                         identification was received in

                         evidence.)



                         (The instrument previously marked

                         as Plaintiffs' Exhibit 2404 for

                         identification was received in

                         evidence.)



                         (The document previously marked

                         Defendants' Exhibit 1223 for

                         identification, was received in

                         evidence.)



                         (The document previously marked

                         Defendants' Exhibit 2405 for

                         identification, was received in

                         evidence.)



                       DIRECT EXAMINATION

     BY MR. LAMBERT:

            Q.    Dr. Popovich, what is your occupation,

     sir?

            A.    I'm a clinical geneticist, clinical

     molecular geneticist.

            Q.    Would you explain for the jury your

     formal educational background?

            A.    Yes.  I have a Bachelor of Science

     degree, and in biology, I have a Master's of Science

     degree in genetic counseling, a Master's of Science in

     biochemical genetics, and my Ph.D. is in molecular

     genetics.

            Q.    And when did you obtain your Ph.D.?

            A.    That would be 1986.

            Q.    And would you describe what employment

     you've had since obtaining your Ph.D.?

            A.    Since obtaining my Ph.D., I was first a

     post-doctoral fellow at the University of Wisconsin in

     Madison where I did a fellowship in the department of

     medical genetics there.

                  I then went from there to the University

     of North Carolina where I did a fellowship in the

     department of pathology there.

            Q.    And where are you currently employed,

     sir?

            A.    I'm currently employed at the Oregon

     Health Sciences University which is the medical school

     in Oregon.  And I have two appointments at the

     university; one is an academic appointment as an

     assistant professor in the department of molecular and

     medical genetics, and then a hospital-based

     appointment which is as the director of the DNA

     diagnostic lab.

            Q.    Are you certified by any organizations

     involving DNA testing?

            A.    I am.  I have a medical board

     certification as a clinical molecular geneticist from

     the American Board of Medical Genetics, which is the

     accrediting board of the American College of American

     Genetics which is the accrediting board for all people

     with genetics training that do anything to do with

     patient care or management.

            Q.    And how long did it take you to be

     certified by that board?

            A.    Well, after one has a doctoral degree,

     either an M.D. or Ph.D. degree, one would then do

     post-doctoral residency, if you are an M.D., and after

     that then one would do a fellowship, and that

     fellowship is usually two to three years.

            Q.    And do you know approximately how many

     people in the country are certified by the American

     Board of Medical Genetics?

            A.    Well, in clinical molecular genetics, it

     was about 120 until recently, and I think

     approximately 80 more were added to that list, so

     there's about 200 people.

            Q.    Of the whole country?

            A.    That would be in the whole country, and

     also including Canada.

            Q.    And are you yourself involved in

     proficiency testing of DNA labs?

            A.    I am.  One of my responsibilities through

     the -- my professional college American College of

     American Genetics is on what's called a proficiency

     testing committee.  And essentially, what this

     committee does is we are the people, the small group

     of people, there are approximately six of us in this

     group, and we're the ones to put together the

     proficiency testing materials.  In other words, write

     the exam questions, decide what labs need, what types

     of specimens labs need to test to demonstrate the fact

     that they are proficient.  Then we also score their

     performance and write critiques and so on their

     performance.

            Q.    In addition to all this work that you do,

     are you also involved in the forensic uses of DNA in

     criminal cases?

            A.    Yes, I am.

            Q.    How are you involved in that regard?

            A.    Well, in a couple different capacities.

     I have been involved -- well, first of all, in the

     state of Oregon we have a panel of DNA experts that

     attorneys can turn to that have criminal cases that

     involve DNA, and can turn to this group for expert

     advice on the reliability of DNA data, the strength,

     weaknesses, as to that data, and in particular cases,

     essentially serve in an educational role, and I do a

     number of cases within the state in that capacity.

                  In addition, my lab does do some forensic

     DNA testing, but that type of testing is very limited

     in scope, and by no means do I want to leave you with

     the impression that we have a forensic DNA lab.

                  I consider it a medical diagnostic lab,

     but the state of Oregon, whatever, whatever.  A young

     individual -- these are statutory rape cases where a

     victim is 12, 13 years old and is pregnant, and where

     the pregnancy -- I can help the state determine who

     fathered that child, and then the state would use that

     evidence to press charges against that individual.  My

     lab does those cases and these are criminal cases.

            Q.    And you've actually testified in court in

     some DNA criminal cases?

            A.    Yes, I have.

            Q.    Have you testified for just the

     prosecution or just the defense or how does that work?

            A.    No, I've, I guess, been involved in, I

     think it's about 18 cases now, and it's been about an

     even split between number of cases for the prosecution

     and number for the defense.

            Q.    So you've sometimes worked as a DNA

     expert on behalf of criminal defendants?

            A.    I do.

            Q.    Do you know who Barry Sheck is?

            A.    I do.

            Q.    Is Mr. Sheck one of the DNA lawyers that

     represented Mr. Simpson in the criminal case?

            A.    Yes, he was.

            Q.    And since that time, has he employed you

     to act as an expert in a criminal case?

            MR. P. BAKER:  Objection, irrelevant.

            THE COURT:  Goes to his CV, I guess.

                  Overruled.

            A.    I should answer?

            Q.    (BY MR. LAMBERT)  Yes.

            A.    Yes.  Subsequent to the criminal case --

     the criminal proceedings in the Simpson case, I was

     approached by Mr. Sheck and -- and did work with him

     on a case.

            Q.    And what did he ask you to do in that

     case?

            MR. P. BAKER:  Irrelevant.

            THE COURT:  Sustained.

            Q.    (BY MR. LAMBERT)  Was that -- was that a

     case in which Mr. Sheck was representing --

            MR. P. BAKER:  Same objection.

            THE COURT:  Overruled.

                  You may establish what the nature of the

     work was.  Don't go into detail.

            Q.    (BY MR. LAMBERT)  Okay.

                  Was that a case in which Mr. Sheck asked

     you to do some -- review some DNA evidence in the

     case?

            A.    Yes, he did.  He asked me to -- it was a

     case --

            MR. P. BAKER:  Your Honor --

            THE COURT:  Sustained.

            MR. P. BAKER:  -- objection, hearsay.

            Q.    (BY MR. LAMBERT)  That was a case that

     Mr. Sheck asked you to work on since the criminal

     trial?

            A.    Yes, it was.

            Q.    Have you concluded your work on that

     case?

            A.    I have.

            Q.    Was there a successful conclusion to that

     work?

            MR. P. BAKER:  Objection, irrelevant.

            THE COURT:  Overruled.

            A.    There was a conclusion to that -- to this

     case.

            Q.    (BY MR. LAMBERT)  What was it?

            A.    In this particular case, a defendant who

     had been convicted --

            MR. P. BAKER:  Same objection.

            THE COURT:  I'm not -- I said don't go into

     detail, Counsel.  You can -- you want to know if he

     was successful or not, you have him answer that.  You

     don't need the details.

            Q.    (BY MR. LAMBERT)  Was it a successful

     conclusion?

            A.    It was a successful conclusion.

            Q.    Now, Dr. Gerdes, the defense expert,

     testified that he did not even use the DQ Alpha or

     D1S80 test at issue in this case.

            THE COURT:  Excuse me.

                  Is there some question on that issue?

            MR. P. BAKER:  It's argumentative, there's no

     foundation.

            THE COURT:  If it's argumentative, it's

     overruled.  If you're saying that didn't occur or

     there's no foundation for that, then we'll hear you at

     bench.

            MR. P. BAKER:  Okay.



                         (The following proceedings were

                         held at the bench with the

                         reporter.)



            MR. P. BAKER:  Your Honor, I just -- I'm

     objecting on foundational grounds.

            THE COURT:  Trying to see what the question is.

            MR. P. BAKER:  I think I have it -- I just lost

     it.

            THE COURT:  What is your question?

            MR. LAMBERT:  My question is has he done DQ

     Alpha and D1S80 tests?

            MR. P. BAKER:  You were asking about

     Dr. Gerdes.

            THE COURT:  That -- this is what you asked.

     This is not Dr. Gerdes.

            MR. LAMBERT:  He read Dr. Gerdes's testimony.

     That's what Dr. Gerdes said.

            MR. P. BAKER:  I thought you asked whether

     Dr. Gerdes did it.

            MR. LAMBERT:  That's what Dr. Gerdes said, he

     doesn't do it.

            MR. P. BAKER:  I object on foundation,

     argumentative.  He should be eliciting his testimony,

     his opinions.

            THE COURT:  What's the relevance of whether

     Dr. Gerdes does it?

            MR. LAMBERT:  The issue of DQ Alpha D1S80.

     Dr. Gerdes doesn't do it.  He does.  This is rebuttal.

     His opinion has more weight than Gerdes' 'cause he

     does the test and Gerdes doesn't.

            MR. P. BAKER:  He elicited his testimony from

     Gerdes.

            MR. LAMBERT:  This is foundational to make the

     comparison.  This jury should be able to hear it.

            THE COURT:  That kind of question is

     argumentative.  You want to ask this witness if he

     does DQ Alpha tests and what the relevance is and how

     it's important or not important, go ahead.

            MR. LAMBERT:  I will.

            THE COURT:  You can argue it to the jury

                  With regards to the fact that Dr. Gerdes

     doesn't do it, that's his objection, I'll sustain it.

            MR. LAMBERT:  It's argumentative, not

     foundation.



                         (The following proceedings were

                         held in open court in the presence

                         of the jury.)



            Q.    (BY MR. LAMBERT)  Dr. Popovich, one of

     the tests at issue in this case is the DQ Alpha test.

                  Is that a test you do in your own lab?

            A.    Yes.

            Q.    Is it used often?

            A.    Fairly frequently.

            Q.    How many times have you yourself had

     experience with the DQ Alpha test in your own lab?

            A.    Hundreds.

            Q.    And the D1S80 test is another test that's

     at issue in this case.

                  Do you do that in your own lab?

            A.    Yes, we do.

            Q.    How often have you yourself had

     experience with the D1S80 test?

            A.    Fairly frequently.

            Q.    A final test at issue in this case is the

     RFLP test.

                  Do you yourself have experience with the

     RFLP test?

            A.    Yes.

            Q.    How often have you done those kinds of

     tests?

            A.    We do those literally every day.

            Q.    Now, Dr. Gerdes compared the issues faced

     by a DNA lab doing forensic testing to one doing

     medical testing.

                  Are you familiar with his testimony in

     that regard?

            MR. P. BAKER:  Same objection, argumentative.

            THE COURT:  Overruled.

            Q.    (BY MR. LAMBERT)  Do you agree with

     Dr. Gerdes's testimony on that subject?

            A.    I disagree.

            Q.    And why is that, sir?

            A.    Well, I disagree because I think he is

     telling one side of a complex story and I think that

     the issues that we have to deal with in a medical

     diagnostic lab are absolutely synonymous with what a

     forensic lab has to deal with and, sure, we deal with

     pristine samples where you know which is -- Dr. Gerdes

     has pointed out very few of the problems that one is

     encountered with in forensic testing.  But we also

     deal with trace evidence, trace samples where there is

     trace amounts of DNA, all the time.  And where the

     issues that arise are absolutely no different than

     what one is encountered with in a forensic setting.

            Q.    So in your opinion, is DNA equally

     suitable to use in the forensic field as it is in the

     medical field?

            A.    If one has an adequate DNA sample, it's

     equally suitable for either application.

            Q.    Now, what material have you reviewed in

     connection with this case, Doctor?

            A.    Well, I've reviewed a lot of materials.

     I've reviewed -- I've personally visited each of the

     labs on more than one occasion.

                  I've talked to the analysts that were

     responsible for performing the actual testing.  I've

     reviewed their bench notes.

                  I reviewed all the original photographs,

     all the original -- all the original documentation for

     each -- each and every piece of evidence in the case.

                  In most cases I've reviewed the trial

     transcripts from both the criminal and the civil case

     of what was said.

                  I've looked at the conclusions the people

     had reached on the basis of the results that they had

     obtained.

                  I've looked at the physical layout of the

     lab.

                  I've looked at personnel qualifications.

                  I mean, I was really brought in to look

     at everything that happened in the case and give a --

     a non-biased opinion as to if that was credible

     evidence.

            Q.    And was one of the things that you were

     looking for when you did this review, in order to

     determine whether there was any contamination that

     affected any of the evidence samples?

            A.    Yes, that was definitely -- any time one

     is looking at DNA evidence, one has to take into

     account the possibility of contamination.

            Q.    Now, is contamination something that you

     worry about in your own lab?

            A.    Any time one performs DNA testing, one

     has to worry about contamination.  Yes, we do.

            Q.    And is contamination something that DNA

     scientists are all aware of and take steps to prevent?

            A.    Absolutely.

            Q.    Is the risk of contamination the same

     with the PCR-base test as it is with the RFLP-base

     test?

            A.    The risk of contamination in either is

     real, but for PCR-base testing, it is a much increased

     test, and one has to be extremely careful.

            Q.    Have you reviewed Colin Yamauchi's

     testimony concerning his sampling of evidence items on

     June 14 and June 15, 1994?

            A.    Yes, I have reviewed his testimony and

     I've personally questioned Colin in great detail

     about -- about what he had done on both of those days.

            MR. LAMBERT:  We're going to put up on the

     television screen -- what number is this?

            MR. P. BAKER:  2265.

            MR. LAMBERT:  2265.

                  It's a little bit hard to read.  If you'd

     like your own copy, it might be easier to read.

            Q.    (BY MR. LAMBERT)  This is a document

     which has previously been used with Dr. Gerdes's

     testimony, lists the items of evidence tested by Colin

     Yamauchi on 6/14 and 6/15.

                  Are you familiar with those items that he

     tested, sir?

            A.    I am.

            Q.    And you said you interviewed Colin about

     his work?

            A.    I have.

            Q.    And did you examine the LAPD lab and the

     related facilities?

            A.    I did.  I visited the facilities, looked

     at the physical layout, did everything that I did in

     all the other labs, and that included going to Piper

     Tech, going to Parker Center, and so on.

            Q.    Do you have an opinion as to whether

     Colin Yamauchi's sampling of the evidence on June 14

     and June 15 caused any contamination of that evidence?

            A.    Do I have an opinion on that?

            Q.    Yes.

            A.    Yes, I do.

            Q.    What is your opinion?

            A.    My opinion is that there is absolutely no

     evidence of any contamination whatsoever.

            Q.    In that connection, could you explain to

     the jury what these controls are that are listed in

     Colin Yamauchi's samples that he tested that day?

            A.    Yes, I can.

                  There are really three places where

     contamination can be introduced.

                  And that would be where the evidence is

     actually gathered that's at the crime scene.

                  Then it would be where the evidence --

     when the evidence comes back to the lab, it could be a

     laboratory within the laboratory.

                  And then it could ultimately be at the

     last step, which is essentially where one is doing the

     procedure that gives you the result and led to

     conclusions being able to be reached on the basis of

     this.

                  So the first one -- the 7 substrate

     controls speak to that very first point, at the actual

     crime scene -- at the actual crime scene.

                  And what one is doing is looking at

     samples that, in fact, are sitting next to the actual

     samples that were tested.  And if there is

     contamination that's taken place at the crime scene,

     one is going to see some of that contamination in

     those -- those controls.

                  And in Colin's work, none of those

     controls tested positively, so that says something to

     me, even not being a forensic scientist and not being

     involved in crime-scene investigation.  It speaks to

     the molecular genetic side of the fact that there was

     not enough DNA, if there was any, to spread around

     there to cause any type of problems in any subsequent

     results.

                  The next place would be when one is

     actually working with the evidence back in the lab,

     and in that regard, the one positive control is

     actually a stained piece of fabric that Colin ran in

     parallel.  What that says is that when he was actually

     doing his -- his extractions of the DNA from the --

     from the samples that were tested, from the -- from

     the samples listed above, that none of those, in fact,

     on the basis of this one control, suggests that there

     was no contamination that took place at that stage.

                  The reagent blank cloth speaks to that

     same thing -- I mean -- I'm sorry, the reagent blank

     cloth was really what I was speaking to, and the

     positive control essentially says that the extraction

     went as planned, that he got the result that he should

     have obtained from that particular control.

                  The amplification blank speaks to that

     last stage, the actual testing phase where one is

     actually doing what you've heard of, the PCR, and one

     is actually looking at the methodologies that generate

     this DNA result.  And in that case, that amplification

     blank was negative.  It's exactly what it should be if

     one is not introducing contamination in the reagent.

                  The last one is the amplification

     positive, which is a quality control that's internal

     to this kit and really speaks to the kit functioning

     as -- as it was designed to perform.

                  So many controls, every controlling

     exactly the type -- type of information that one would

     want to see if one was -- if, in fact, there was no

     contamination and if, in fact, the conclusions that

     were reached on these -- on these particular items of

     evidence were because of DNA that was picked up and

     not because of some DNA that was introduced at a

     subsequent stage.

            MR. LAMBERT:  Why don't you push this up to the

     top then see -- this, Steve, up to the bottom

     (indicating to Elmo).

            Q.    (BY MR. LAMBERT)  These two days he

     sampled 18 evidence items, 3 exemplars and 21

     controls.  Half of the things he sampled that day or

     those two days were controls, and did you look at all

     of those test results?

            A.    Yes, I did.

            Q.    And what did the controls show?

            A.    Well, the controls showed that any one of

     those three stages of -- of either collection or

     examination of the evidence or actually doing the

     process of the PCR, that there was no -- there was no

     contamination whatsoever there that was detectable.

            Q.    Thank you.

            MR. LAMBERT:  Now let's show the next one,

     Steve.  Which number is this?

            MR. FOSTER:  2264.

            MR. LAMBERT:  2264.

            Q.    (BY MR. LAMBERT)  This exhibit --

     particular exhibit is just talking about 6/14, this

     one day, and it lists the number of swatches that were

     in these various evidence items and the number of

     controls that were sampled by Mr. Yamauchi on that one

     day.

            MR. LAMBERT:  Let's get to the bottom, Steve.

            Q.    (BY MR. LAMBERT)  So 32 evidence swatches

     and 7 controls that were handled by Colin that one

     day; is that your understanding?

            A.    That's my understanding, yes.

            Q.    And these controls that were handled,

     were those controls all negative for any

     contamination?

            A.    They did not demonstrate any

     contamination.  That's correct.

            Q.    And in order for this evidence to have

     been contaminated by the handling by Colin Yamauchi,

     would all 32 of those evidence swatches have to have

     been uniformly contaminated?

            A.    I'm sorry, can you --

            Q.    In order for the evidence to be

     contaminated in this case, the evidence handled on

     June 14, would all of those 32 swatches, each one of

     them, had to have been contaminated?

            A.    That would be --

            MR. P. BAKER:  Vague.

            THE COURT:  Overruled.

            A.    That would be correct if the results were

     due to contamination.

            Q.    (BY MR. LAMBERT)  In your opinion, were

     those results due to contamination?

            A.    There's no evidence that there is

     contamination in those 32.

            Q.    Now, Dr. Gerdes implied in his testimony

     that Colin Yamauchi sampled too many evidence items at

     once on these two days.

            MR. P. BAKER:  Objection, Your Honor, no

     foundation.

            THE COURT:  Excuse me?

            MR. P. BAKER:  Objection, no foundation,

     argumentative; implied.

            MR. LAMBERT:  Stated --

            MR. P. BAKER:  Where --

            THE COURT:  Overruled.

            Q.    (BY MR. LAMBERT)  Dr. Gerdes stated --

     said that Colin Yamauchi examined too many evidence

     items on these two days.

                  Do you agree with that opinion?

            A.    I do not.

            Q.    And do you occasionally handle the same

     number of items at once in your laboratory?

            A.    Yes.  It would be -- not at all.  I mean

     it's a significant number that were handled on that

     day, but then again, Colin did indicate in his

     testimony that he worked overtime in order to handle

     this number of samples.

                  And in my own lab, I mean it would be a

     very similar scenario where, if one had this number of

     samples and needed to process those, one could, yes.

            Q.    Dr. Gerdes stated in his testimony that

     Colin Yamauchi's handling of the reference vial

     containing Mr. Simpson's blood might have caused some

     contamination.

                  How do you yourself handle reference

     vials?

            A.    Well, when a reference tube of blood

     comes in, one would handle it essentially very similar

     to what Colin described.  One places something over

     it.  The concern is two-fold.  One is your own person

     being contaminated by the materials -- the blood

     materials that are in there.  And the second is the

     laboratory environment.

                  So, in fact, it's very synonymous in many

     ways to opening a bottle of wine.  I mean if you were

     to take a bottle of wine and pull the cork out a good

     bit of the way, and it was a red bottle of wine, what

     you want to do is prevent any of that wine from

     sliding down the side of the bottle or getting on you,

     you would place a napkin over it and you would pull

     the cork out the last bit of the way, and inevitably

     what would end up happening is some of the blood from

     that -- from that bottle or from the -- from the

     actual vial, or in the case of the wine, from the cork

     would actually get onto that napkin, and one would see

     that.  And so -- and by holding that napkin, or in

     this case chemwipes, which are just green kleenexes,

     over that, and pulling out that cork, one would keep

     that blood on those chemwipes and basically keep it

     from getting spread around, so it's exactly what we

     would do in opening those.

            Q.    So is the method that Colin Yamauchi

     described that he used to open the vial as part of the

     sampling process, a customary way of handling?

            A.    Absolutely.

            Q.    Is it uncommon to get a little bit of

     blood on the Chemwipes when that happens?

            A.    Not at all.  The majority of the time,

     one would.

            Q.    And does that cause any problems?

            A.    In my view, it causes no problem.

            Q.    Now, Dr. Gerdes suggested that perhaps

     some contamination could have taken place because of

     maybe Colin Yamauchi got some blood on a pen.

                  Do you remember him saying that in his

     testimony?

            A.    I do recall that.

            Q.    Is that, in your view, a possible

     explanation for all this evidence sample in this case?

            A.    Not at all.  It's not at all consistent

     with these -- these items of evidence and the results

     that were obtained.

            Q.    Dr. Gerdes suggested that Colin Yamauchi

     may have reintroduced contamination when he brought

     evidence samples back to Piper Tech after he had done

     the PCR amplification.

                  Do you remember that portion of his

     testimony?

            A.    I do remember.

            Q.    Do you agree with that?

            A.    I think that's absolutely ridiculous.

            Q.    There's no basis for that testimony, in

     your view?

            A.    None whatsoever.

            Q.    Now, the test results that Colin Yamauchi

     obtained on June the 14th and June the 15th, were

     those test results consistent with test results later

     performed by DOJ or Cellmark Diagnostics on the same

     evidence items?

            A.    Yes, they were.  All the results that

     were obtained on those items of evidence were

     essentially concorded between all three labs.  They

     all obtained the same result.

            Q.    If any contamination had occurred, what

     does the fact that all three labs got the same results

     tell us about that contamination?

            A.    Well, it says that the contamination had

     to be there before Colin actually processed it.

            Q.    And is there any evidence at all that

     there was any contamination before he began his

     process of testing it?

            A.    No, there's no.

            MR. P. BAKER:  Objection.

            THE COURT:  Overruled.

            A.    (Continuing.)  There's no evidence that

     those results are due to contamination.

            Q.    There were -- in the case, how many

     different evidence items were collected and tested?

     Do you have a rough number in mind?

            A.    The total number that were collected?

            Q.    Yes.

            A.    I don't actually know that number.

                  I mean, I know that, for instance, that

     in addition to what we've talked about at LAPD, that

     Cellmark looked at a approximately 25 samples -- items

     of evidence that were tested; and DOJ, something in

     the neighborhood of 100 to 110.

            Q.    In all of those evidence items, was there

     any evidence at all of contamination?

            A.    None at all.

            MR. LAMBERT:  Let's start with the Bundy board.



                         (Board entitled Results of DNA

                         Analysis, Bundy Crime Scene, is

                         Exhibit 291 displayed.)



            MR. LAMBERT:  Mr. Baker asked me to wait.

            MR. P. BAKER:  I'm back.

            MR. LAMBERT:  There he is.

            Q.    (BY MR. LAMBERT)  Now, we've put up

     Exhibit Number 291, which is the board showing the

     results of the DNA analysis at the Bundy crime scene.

                  Did you review all of those tests for all

     those evidence items?

            A.    I did, from all three labs.

            Q.    And are the results among the three labs

     consistent?

            A.    The results are consistent.

            Q.    Incidentally, do you have any opinion as

     to the quality of the testing work done by Gary Sims

     in the California Department of Justice?

            MR. P. BAKER:  Objection.  Speculation and

     foundation.

            THE COURT:  Overruled.

            A.    I do.

            Q.    (BY MR. LAMBERT)  And what is that

     opinion?

            A.    I think that Gary Sims, Renee Montgomery,

     and DOJ, in general, does excellent work.

            Q.    Do you have any opinion about the quality

     of the testing done in this case by Robin Cotton,

     Cellmark Diagnostics?

            A.    I do.

            Q.    What is your opinion?

            A.    Again, I think Cellmark is a very

     reputable company, and the work that was done in this

     case was excellent.

            Q.    Finally, do you have any opinion about

     the quality of work done in this case by Colin

     Yamauchi, by SID?

            A.    Yes.  I think the work that Colin did is

     reliable.  I have -- see no reason not to trust any of

     it; I think it's very good data.

            Q.    When you looked at all the evidence

     samples reflected on this board from the crime scene

     at Bundy, did you see any evidence at all of any

     contamination in any of these evidence samples?

            A.    I did not.

            Q.    Now, in regard to item number 52,

     Dr. Gerdes testified that when he looked at the

     DQ Alpha strips for the Department of Justice, he

     detected what he said could be contamination in those

     strips.

                  Do you remember that testimony?

            A.    I do.

            Q.    Do you agree with that opinion?

            A.    I do not.

            Q.    What did you see when you reviewed the

     DOJ DQ Alpha strip?

            A.    Well, the DOJ DQ Alpha strip, as I

     recall, there is a -- a -- a very faint 1.3 that's

     there, also.

                  And in that particular case, there are a

     number of explanations for that; and -- and the most

     likely explanation for that is something that would be

     called cross-contamination.  That's in a sample, where

     one has quite a bit of DNA, and it -- in a way, it

     overwhelms the system a bit, and is showing you

     something that's very closely related, but is not

     necessarily there.

                    And because of the amount of DNA that

     was in that sample, I agree with the testimony that

     was given by, for instance, Gary Sims in this case,

     that -- as to the explanation for that.  It's a very

     logical explanation; and it a would be my -- it would

     be the explanation that I would offer as the most

     logical.

            Q.    So do you believe that Dr. Gerdes is

     wrong in regard to item 58?

            A.    I do.  I think that Dr. Gerdes is looking

     very narrowly at one side of the data in this

     particular specimen, and isn't looking at the whole

     case -- at all the evidence related to that particular

     specimen.

            Q.    Now, Cellmark obtained an RFLP result on

     that evidence item 52.

                  Did you see any evidence at all of

     contamination in that RFLP test result?

            A.    I did not.

            Q.    In your opinion, could that RFLP result

     have been caused by contamination?

            A.    I believe it could not be.

            Q.    And is that RFLP result a significant

     result, sir?

            A.    I think it's very significant.

            Q.    It's very significant in terms of

     identifying Mr. Simpson as the person who left that

     blood at crime scene?

            MR. P. BAKER:  Objection.  Argumentative.

            THE COURT:  Overruled.

            A.    Well, I think it's very significant in

     the sense that the profile that was generated by each

     and every one of those five probes matches that of

     Mr. Simpson.

            Q.    In your opinion, are the DNA test results

     for this evidence found at the Bundy crime scene,

     accurate test results?

            A.    I believe it is, yes.

            Q.    Are they reliable?

            A.    I see no reason to not trust the

     reliability of this evidence.

            Q.    Excuse me.  In your opinion, can this

     jury consider those test results to be unaffected by

     any contamination?

            MR. P. BAKER:  Argumentative.

            THE COURT:  Overruled.

            A.    I do not find any reason to believe that

     any of this is due to contamination.

            MR. LAMBERT:  Next board.



                         (Board displayed entitled Results

                         of DNA Analysis, Bronco

                         Automobile.)



            MR. LAMBERT:  We now have up before you,

     Dr. Popovich, the results of the DNA analysis of the

     Bronco automobile.

                  Have you reviewed all of the test results

     for the evidence collected from that Bronco?

            A.    I have.

            Q.    Did you see any evidence of contamination

     in any of those test results?

            A.    No, I did not.

            Q.    In regard to the Department of Justice

     DQ Alpha result on item 31, there, Dr. Gerdes

     testified that Sims misread those results.

                  Did you review his testimony in that

     regard?

            A.    I did.

            Q.    Do you agree with Dr. Gerdes?

            A.    I do not agree with Dr. Gerdes.

            Q.    What is your opinion on those test

     results?

            A.    Well, I think that what Gary Sims did,

     is -- is look at exactly what was there, and -- and,

     in fact, called it exactly like he saw it.

                  And we have supporting evidence of his

     call by D1S80 result, the 24, 25 in that regard done

     by Renee Montgomery.  Not only do we have concordant

     data by SID and the DOJ Lab for item 331, but we also

     have data that substantiates that, which is D1S80 data

     that was done by Renee Montgomery at DOJ.

            Q.    And Mr. Sims was later able to obtain an

     RFLP result in items 303, 304, and 305.

                  Does that tend to validate his PCR

     results on item 31?

            A.    I think it does, yes.

            Q.    Do you have any doubt at all whether

     Mr. Sims is correct in calling item 31 to be an item

     that could contain the blood of both Mr. Simpson and

     Mr. Goldman?

            A.    No; I think that his conclusion is an

     accurate one.

            Q.    In your opinion, are these DNA results,

     or the evidence found in the Bronco automobile,

     accurate?

            A.    I believe they are accurate.

            Q.    Are they reliable?

            A.    I believe they're reliable.

            Q.    In your opinion, can the jury consider

     those results to be unaffected by any contamination?

            A.    I believe they are unaffected by

     contamination.

            MR. LAMBERT:  Rockingham --

            MR. P. BAKER:  Your Honor, can I approach real

     quickly while Mr. Foster is getting the boards?



                         (The following proceedings were

                         held at the bench, with the

                         reporter.)



            MR. P. BAKER:  Your Honor, I'd like to put on

     my objection to any further testimony by this witness.

     I'd like to put an objection on the record to any

     further testimony by this witness.  He's not rebuttal;

     he's a summary witness who's been brought in as a

     clean -- to try to clean up other witnesses.

                  It's improper rebuttal testimony.  I'd

     like to object to any further --

            MR. BAKER:  He's talking about the opinions of

     their own witnesses and their own people as to whether

     it's reliable or unreliable.  That's a conclusion for

     the jury to make.

                  This is improper, Your Honor, and we

     object to it.

            MR. LAMBERT:  Dr. Gerdes claimed that the test

     results in this case were affected by contamination.

                  This witness is saying they're not.

     They're all reliable.  That's what the opinion is all

     about.

            MR. BAKER:  That isn't what he's asking him.

     He is asking him summary questions.

                  The jury is entitled to believe this

     evidence, whether or not he's entitled to render his

     opinion pursuant to your ruling.  That -- whether or

     not he believes the evidence is contaminated, in my

     opinion, is totally argumentative to -- asking these

     questions, to kind of summarize his views for the

     jury.

            THE COURT:  It's proper rebuttal.  It's

     argumentative.

                  I'll sustain it on the basis it's

     argumentative.

            MR. LAMBERT:  Which question?

            THE COURT:  When you're questioning in terms of

     should the jury --

            MR. LAMBERT:  I'll take that part out.

            THE COURT:  Okay.

            MR. BAKER:  One other question.

                  When he's asking these questions, he --

     it seems to me, it's argumentative to say, do you

     think these opinions given are reliable.  Those are

     argumentative questions.  I mean, he's arguing whether

     or not those opinions are reliable, and he ought not

     be able to do that.

            MR. LAMBERT:  That's not argumentative.

            THE COURT:  Overruled.



                        (The following proceedings were

                         held in open court, in the

                         presence of the jury.)



            THE COURT:  How much longer are you going to

     be?

            MR. LAMBERT:  Ten minutes, fifteen, maybe.

                  You want to take a break now?

            THE COURT:  Yes.

                  Ten minutes, ladies and gentlemen.

                  Don't talk about the case.

                        (Recess.)



                         (Jurors resume their respective

                         seats.)









                 DIRECT EXAMINATION (continued)

     BY MR. LAMBERT:

            Q.    Dr. Popovich, we now have up the results

     of the DNA Rockingham residence.  Did you review all

     the tests done from the evidence collected at the

     Rockingham residence?

            A.    I did from all three labs.

            Q.    Did you observe some evidence of

     contamination in those results?

            A.    No.  I saw no trace of any contamination.

            Q.    And in your opinion, are these reliable

     test results?

            A.    I believe they are.

            Q.    Are they unaffected by contamination?

            A.    I believe they're unaffected by

     contamination.

            Q.    Are they accurate results?

            A.    I believe they are accurate.

            Q.    We now have up the results of the DNA

     analysis of the Rockingham gloves.

                  Did you review the test results on the

     Rockingham glove?

            A.    I did.

            Q.    Did you observe any evidence of

     contamination in those test results?

            A.    Again, I saw no evidence of

     contamination.

            Q.    And in your opinion, are these test

     results reliable?

            A.    I believe they are.

            Q.    Are they accurate?

            A.    I believe they're accurate.

            Q.    Are they unaffected by contamination?

            A.    I believe they are unaffected by

     contamination.

            Q.    And these are RFLP results where we have

     5 probe and 8 probe matches, are those significant

     results, Doctor?

            A.    I think they are.

            Q.    Are they significant results in terms of

     identifying the source of the blood on that glove?

            A.    I think they're very significant in

     identifying that.

            MR. LAMBERT:  And finally, the socks board,

     please.

            Q.    Finally, Dr. Popovich, we have the

     results of the DNA analysis on the Rockingham socks.

                  Did you review these test results?

            A.    I have.

            Q.    And did you observe any evidence of

     contamination on these test results?

            A.    No, I did not.

            Q.    In your opinion, are those test results

     reliable?

            A.    I believe they are.

            Q.    Are they accurate?

            A.    I believe they are.

            Q.    Are they unaffected by contamination?

            A.    I believe they are unaffected by

     contamination.

            Q.    At 11 probe, 5 probe, 9 probe, RFLP

     matches, are those significant matches?

            A.    Highly significant.

            MR. LAMBERT:  You can take that down, Steve.



                         (Indicating to board.)



            Q.    Now, Dr. Gerdes talked a little bit in

     his testimony about degradation of evidence samples,

     degradation of evidence samples change the DNA from

     one person to another?

            A.    Meaning, can it change the type -- the

     results that one gets.

            Q.    Yes.

            A.    DNA degradation -- when it degrades, DNA

     cannot change the actual type that one gets with any

     of these tests.  It can make things go away, it can

     make the type, in other words, disappear, and

     sometimes it can make one of the two genes that that

     person has disappear first.  But it cannot change the

     type of that.

                  So in other words, they are not going to

     go from a type 1 to a type 2 or something, in some DNA

     tests, if the type 1 -- if the one gene is degraded,

     it is just not going to show up, it's not going to be

     a result.

            Q.    So degradation could not result in

     somebody getting false DNA test results?

            A.    Degradation cannot result in one being

     mistyped.  It can result in no result.  But it cannot

     result in mistyping.

            Q.    Now, Dr. Popovich, you've reviewed a lot

     of evidence samples in this case?

            A.    I have.

            Q.    Have you ever had a case where you

     reviewed so many evidence samples?

            A.    I have not.

            Q.    Taking everything into account from your

     review of all of those evidence samples, are the test

     results, the DNA test results in this case, by LAPD,

     Cellmark, and DOJ, are they accurate?

            MR. P. BAKER:  Objection, argumentative, no

     foundation.

            THE COURT:  Overruled.

            A.    I believe these results are accurate.

            Q.    Are they reliable?

            A.    I believe they're very reliable.

            Q.    Are they unaffected by contamination?

            A.    I do believe they're unaffected by

     contamination, yes.

            MR. LAMBERT:  No further questions.

            THE COURT:  Cross-examine.

                       CROSS-EXAMINATION

     BY MR. P. BAKER:

            Q.    Dr. Popovich, you're the cleanup hitter,

     aren't you?

            MR. LAMBERT:  Objection, argumentative.

            THE COURT:  I'll give him that.

            A.    I'm not sure what you call me.

            Q.    (BY MR. P. BAKER)  You told this jury you

     visited the lab basically to give an unbiased opinion

     to the standards, right?

            A.    That is what I did.

            Q.    You billed the prosecution $30,000 for

     that, didn't you?

            A.    I did.

            Q.    How much have you billed the plaintiffs'

     attorneys in this case?

            A.    Probably in the neighborhood of about

     5,000.

            Q.    Okay.  Pretty unbiased?

            A.    Yes.  I put 300 hours into that previous

     case.

            Q.    Colin Yamauchi is a friend of yours, is

     he not?

            A.    I would say he's absolutely not a friend.

                  I mean I knew him in no way, shape or

     form before I became involved in this case.

            Q.    When did you become involved in the case?

            A.    I'd have to look at my CV to look at the

     exact date.  I believe it was September of '94.

            Q.    And you weren't called by the prosecution

     as a witness, right?

            MR. LAMBERT:  Objection irrelevant.

            THE COURT:  Overruled.

            Q.    You can answer.

            A.    I was on their list to be a witness but I

     was never called.

            Q.    Okay.

                  And how many times have you met with --

     you call him Colin, since September of 1994?

            A.    No.  I met with Colin on two occasions.

            Q.    How many times have you talked to him?

            A.    Oh, probably two more than that.

            Q.    Four times?

            A.    Yes.

            Q.    And your opinion is that everything was

     hunky dory in terms of the examination of the

     swatches?

            A.    I'm not sure what hunky dory means.

            Q.    Never heard that before?

            A.    I've heard of it.

            Q.    You have no opinion as to that question?

            A.    Well, if you define hunky dory, I'll

     answer it.

            Q.    Why don't you use your definition.

            A.    I wouldn't use the term "hunky dory."



                         (Laughter.)



            Q.    All right.

                  How many nanograms of DNA are in a drop

     of blood?

            A.    Depends how big the drop is.

            Q.    It's generally held in the scientific

     community that approximately a thousand nanograms are

     found in a drop of blood, right?

            A.    Well, that would be approximate.

            Q.    Okay.

                  Do you have a dark pen up there.



                         (Witness handed marker to Mr. P.

                         Baker.)



            Q.    How many nanograms of undegraded DNA was

     found in Item 47 on the Bundy walk?

            A.    I'd have to look at my notes on that.

            Q.    Is it about 33.6?

            A.    I would say that's probably in the right

     neighborhood.

                  Then again, I wouldn't testify to any of

     the numbers if I don't look.  It's a specific science.

            Q.    Go ahead.

            A.    I do not have that with me.

            Q.    Okay.

            A.    I'd have to look.

            Q.    Do you have any notes on the DNA nanogram

     Bundy walkway?

            A.    No.

                  I know that Gary Sims --

            Q.    A question is not pending, sir.

                  How many nanograms were found in Item 48,

     about five, more or less?

            A.    I don't have those numbers memorized.

            Q.    Okay.  49; about 1.8 nanograms?

            MR. LAMBERT:  Seems to me that the lawyer is

     testifying here other than the witness.

            MR. P. BAKER:  Your Honor, he's testifying as

     to the DNA in this case.  If he doesn't know the

     nanograms as to the Bundy walkway, we got problems.

            THE COURT:  You may.



                         (Laughter.)



            MR. P. BAKER:  I'd agree with that.

            THE COURT:  Why don't you present figures to

     him and let him look at it if he doesn't remember.

            Q.    (BY MR. P. BAKER)  I just have my notes.

     I don't have the exact drawings, you understand, of

     the five Bundy swatches.

                  The maximum amount of nanograms is 33.6,

     right?

            A.    That's including 52?

            Q.    Yes.  52 had 31.6, right?

            A.    Well, it depends on which lab you're

     referring to.

            Q.    Un degraded DNA testified the LAPD?

            A.    Okay.  This is strictly by LAPD.

            Q.    Correct?

            A.    Again, I'd have to look at the bench

     notes for that.  I mean I'll -- basically, if you put

     a number up there and you want me to give you an

     interpretation of what it means, I'll be happy to do

     that.

            Q.    Let's assume for a hypothetical Item 52

     had 31.6 nanograms, Item 58 had 12.1, Item 49 had 1.8,

     Item 48 only had 5?

            A.    Okay.

            Q.    That's a lot less than the thousand

     normally found in a drop of blood, true or untrue,

     sir?

            A.    Well, if a drop of blood has a thousand,

     33.6 is less than a thousand.

            Q.    A lot less?

            A.    It's significantly less.

            Q.    Okay.

                  Now, what about Item 117.  How many

     nanograms did that have?

            A.    Again, I don't have any of this committed

     to memory.

            Q.    Item 117 had 150 nanograms, didn't it?

                  Do you have any idea about that, sir?

            A.    Well, I know it had more than the others.

            Q.    And Item 117 is a stain collected on the

     back gate?

            A.    That's correct.

            Q.    That was checked on July 3?

            A.    It was collected after the others, that's

     correct.

            Q.    Collected about 19 days after the five

     other swatches, right?

            A.    Sounds about right.

            Q.    About five times as strong in terms of

     nanograms, right?

            A.    Approximately, yes.

            Q.    And you know that the Bundy walkway was

     washed down after the crimes, right?

            A.    I did not know that.

            Q.    Never heard that.

            A.    I mean I -- again, that part of the

     transcript -- I mean I may have read that at one

     point.  Again I -- again, that's not something that

     was fundamental to my part of this investigation.

            Q.    Okay.

                  Now, you can have contamination in terms

     of DNA from simply changing gloves, right, you can

     transfer DNA by changing gloves, transfer from one to

     the other, right?

            A.    Can you be a bit more explicit.

            Q.    Sure.  If you have DNA on your right hand

     and you touch the left hand with it, you can transfer

     the DNA?

            A.    Yes.

            Q.    You can transfer it when you pick up some

     tweezers, right?

            A.    It's possible.

            MR. LEONARD:  Can I stop holding this?



                         (Indicating to chart.)



            MR. P. BAKER:  You can put it down.

            MR. LEONARD:  Thanks.

            Q.    (BY MR. P. BAKER)  You can transfer DNA

     when you touch your glasses, right?

            A.    It's possible.

            Q.    Now, did the plaintiffs show you the

     demonstration that Andrea Mazzola did of her best

     collection techniques?

            A.    I have never seen any collection

     techniques of Andrea Mazzola.

            Q.    They never showed you -- they never

     showed you the videotape that Andrea Mazzola presented

     at the prosecution of -- about what was her best

     collection techniques?

            A.    I am not -- I have never seen that, no.

            Q.    Okay.

                  You never heard that in that videotape

     she touches the pavement, moves the swatches,

     transfers the tweezers, touches her glasses; you never

     heard anything like that?

            A.    No.  I mean --

            Q.    Answer my question yes or no.

            A.    I mean I have heard bits and pieces of

     this, yes -- I mean from the transcript, reading the

     transcript of the civil trial.

            Q.    And you have no independent knowledge, as

     you sit here today, how Andrea Mazzola collected the

     swatches at the crime scene, correct?

            A.    Personal knowledge?

            Q.    Yeah.

            A.    Well, I read the transcript.

            Q.    Personal knowledge, independent

     knowledge; you have none, right?

            A.    Other than from the official transcript I

     have none.

            Q.    Okay.

                  Now, you can have contamination by

     bottles of reagent, right?

            A.    You can, right.

            Q.    That's another liquid that's used when

     you're working with DNA; the liquid you use in the

     process, correct?

            A.    You may, yes.

            Q.    And in your lab you use reagents, right?

            A.    We do.

            Q.    How often do you change those reagents?

            A.    It all depends on the reagent.

            Q.    Okay.

                  Do you leave some reagents there for more

     than six months?

            A.    Some reagents are years old, yes.

            Q.    Okay.

                  Had you ever looked at the r