Cameron Brown 3rd Trial, Day 24 - Defense Case Continues

Complete Cameron Brown Case Coverage.

Inspiration Point, Rancho Palos Verdes, CA

Four year old Lauren Sarene Key plunged to her death off of

Inspiration Point on November 8, 2000. 

Lauren, on the last day of her life.

UPDATE 5/8 11 AM final edit for spelling, readability and accuracy.
UPDATE 5/7 8 AM More editing of Dr. Siegmond's testimony.
UPDATE 7:00 PM I have edited part way through Dr. Siegmond's cross examination for spelling, readability and accuracy.
UPDATE 4:20 PM I will try to edit this entry tonight and over the coming week.
Monday, May 4, 2015
9:05 AM
When I get inside Dept. 107, DDA Hum and Aron Laub are arguing whether or not the defense expert can present the dummy drop videos.

It's complicated. I can into this in the middle of these arguments. DDA Hum is arguing that these videos have nothing to do with travel through space, but impacts with the cliff.

Mr. Laub is arguing that the dummy shows the movement through space after the impact.

The court: It seems like your witness is trying to get this in through the back door, how Lauren's body would have reacted once it left the cliff, impacted with the cliff and after. The court has already ruled on that. There's a real problem with the video.


DDA Hum states that the simulations by Dr. Hayes do show how a human body would react with the cliff.

The court rules that these dummies have never been offered to replicate a human body.

Mr. Laub states that they will eliminate the human body video. We will present the golf ball throw videos.  He explains that there will be another another slide inserted that doesn't mention the dummy drop video.

The court asks Laub to go talk to Mr. Siegmund.

DDA Hum brings up the issue that the defense wants to read into the record Lynn Brown's testimony. The court asks who this is. DDA Hum states it's the defendant's mother. DDA Hum states he understands why they want it read into the record; there are health issues. He doesn't have a problem with that. He does have an issue with some of the testimony that he is objecting to. Mr. Laub states that he [knows?] the objections and will be submitting a redacted testimony to DDA Hum.

The court informs counsel if you need me to intervene, let me know. Judge Lomeli leaves the bench.

There is a young woman sitting in the row in front of me. Once Judge Lomeli leaves the bench, the defense investigator comes over to speak to her.

9:22 AM
Sarah and a friend arrive.  DDA Hum comes over to speak to Sarah to warn her about upcoming slides in the defense witness' presentation.

I forgot to mention that the court asked the defense if they expected to rest tomorrow. Mr. Laub states that they will rest tomorrow.  DDA Hum confirmed he will be putting on a rebuttal case.

9:29 AM
DDA Hum is helping the defense work out the logistics of getting the defense expert's presentation to work with the ELMO projection.

9:34 AM
We wait. Dr. Siegmund is working on getting his PowerPoint presentation to display on the overhead screen. Brown was just brought out.

9:38 AM
Jury enters. Judge Lomeli states "Jury walking" and Brown gets up from his seat, buttons his jacket and turns towards the jury.

GUNTER SIEGMUND
Please tell the jury what it is that you do? I am a mechanical engineer with a PHD in bio mechanics. He analyzes how injuries are caused in various incidents.  He gives his CV, his professional training, etc. His company is Mea Forensics Engineers & Scientists.  His work is hands on work, verses the academic who does the study of [this work].

He's testifying in regards to the death of Lauren Key. He was provided with a number of photographs, autopsy reports, reports from the police, Dr. Hayes's reports and things of that nature. And provided testimony of Dr. Hayes. Reports, did that include the work that he had done in this case? It described the work that he had done.

He produced a PowerPoint presentation to take us through the significant factors in this case? Yes. He also relies on Dr. Hayes' PowerPoint; a number of those slides.  He also did experiments with children throwing golf balls, to determine the speed/movement of children. Yes.

DDA Hum asks that Mr. Laub occasionally ask a question, verses a narration.

First slide is the same slide that Dr. Hayes was shown.  In the course of my PowerPoint, I'm going to be addressing the same question, and showing why I disagree with Dr. Hayes.

This slide shows, autopsy reports.

This slide as it stands, is Dr. Hayes slide. Will you explain why this is important? Dr. Hayes summarized Lauren's injuries, and there are some injuries that are missing. There are injuries on the back shoulder and injuries on the abdomen that don't show up on this slide. They are on Dr. Chinwah's autopsy.  He puts up a slide of the autopsy drawing from Dr. Hayes' presentation, the front and back sketch of a child's body and the major injuries.

Now showing autopsy photos. The left side of Lauren's body. They are photos of very small injuries on the left side of her body. The black arrows are Dr. Siegmund's.

[My observation: These do not appear to be massive injuries, like on the face and upper body. They are small bruises and cuts.]

There was another autopsy photo of Lauren's body showing an injury of her right shoulder.

Another slide of Dr. Hayes: The Scene Survey: Cliff Profiles. Going over this slide and his interpretation of this slide.

It's difficult to describe this testimony without the attached slides.

Now a photo of the cliff face, looking straight on and then a blow up of the photo on the left.

Regarding the previous slide. They dropped a rope and shows the cliff face is under cut. And taking that back to the previous side drawing, Dr. Hayes' side drawing of one of the pie slices shows this part of the cliff going out, when his dropped line weight shows that the cliff face is undercut.

[So, the interpretation is, Dr. Hayes drawing outline, of this pie slice of the cliff, at some point, is wrong.]

Now stating that he doesn't know if the rest of the graph is correct, but the bottom portion of Dr. Hayes' side graph, in the vicinity of where the dropped line is incorrect.

Now showing another slide of Dr. Hayes: Fall Biomechanics: Results.

Showing the cross section of the pie/line slices B, C, D, E & F.  These are all sections that end up in the inlet of the water.

A juror yawns. Another juror tries to keep his head up.

These represent fall trajectories. They represent the path as [the body? Lauren? would?] free fall. States that these lines don't all use the same point of departure. They would be beside each other. They also change in space.

Explains what Dr. Hayes chose as a point of departure.  Also explains that each black line on the latest slide, shows different cliff profiles, because there are different profiles at each pie/line slice point.

All of these slides show the bottom of the cliff face extending out, so they are incorrect.

The comparison is what Dr. Hayes is presenting is slip/fall [slip/trip] verses thrown/push.  The green line shows the slip/trip.

Explains that some of the lines show that they penetrate the cliff and that wouldn't happen.

States that there's something missing as far as another arc because nothing could penetrate the cliff. It would follow a new parabolic arc.

If you fell onto the ground and slipped onto the ground, and enough friction and insufficient distance then you would go over the cliff. There are multiple variables as to whether you would go over the cliff if you tripped and these graphs do not show that.

His understanding of what the graphs are showing, is that they don't properly represent what would happen.

If we consider all the departure points, there would be many, many graphs and not just [these?]. [Yes.]

Now more testimony as to what the yellow lines mean.

I think the import thing that this slide depicts, is it's only five slices, a single departure point per slice. There are many, many other possibilities that have not been analyzed.

What is a spread sheet? It's a software program that allows you to put numbers or equations in a cell that relate to other cells, that generate numbers based on equations.  That's what engineers use it for.

Did Dr. Hayes create a spreadsheet showing the formulas or mathematics that led to these lines? Yes. These lines are generated from a graph. the spreadsheet contains the full equation. They show spots in time.  These are created from a spreadsheet, that Dr. Hayes created.

They do not represent everything on the spreadsheet.  Now showing an image of the spreadsheet that Dr. Hayes created.  It's many boxes with numbers in them. And the various computations on the spreadsheet that were not represented on the previous pie slice graphs.

The trip/run [scenarios] are generated in the spreadsheet program but not plotted on the graph [images that were shown to the jury].

What he did was plotted the trip/run on Dr. Hayes' graph, to show where it doesn't fall. He plotted the trip/run on Dr. Hayes previous graphs in blue and overlayed them on Dr. Hayes' graph.

They fall similar to the yellow lines in some of the graph images.

More explanation of the interaction of the yellow and blue lines that I don't understand.

Dr. Siegmund states that his overlay blue lines show, that they would end up in the same end point on the cliff place that Dr. Hayes says she could only have happened if she was thrown.

If we go back to the other graphs that Dr. Hayes showed us here, you're saying that ...[?]? No these are ones that I've redone.

You're saying that the point of departure in these, the yellow lines, is different than the yellow lines in the site experiment? Yes. These start at the same departure line, but [?] lines are above other lines.

If you look at this line, it no longer intersects the cliff face here, because now the yellow, red and blue line have moved back and now are behind. I understand why Dr. Hayes did this, he was attempting to match the point of departure that his associate used, to launch the pelican box.

In Dr. Hayes' experiment, he threw the pelican box, it hit the cliff face and bounced into the water.

In this bottom portion of this line, the blue line, that seems to be going inside the cliff, that portion is an analogy, you would take a point of impact, that blue line and shelf, you would end up with a new parabolic arc? Yes. The pelican box would bounce off the cliff and start a new line into the water.

What I then did was, in Dr. Hayes' hand written notes, there was a graph that was essentially the same as this graph, as that it shows the same cliff profile, the slip trip and throw, you can see these together lines, going back from that original departure point. But on the graph that was in his notes, there is an additional scenario that was in his sheet, a run scenario. The run scenario.

Because the colored lines are difficult to see, I created a colored version of this so we could better see what this would look like. Here is the green and yellow line, from Dr. Hayes' graph. The two lines I want to draw your attention to are the blue line that intersects the shelf here, and a different color blue that starts here at Lauren's center of mass height, that falls along a different trajectory, but arrives on the cliff point but ends at the same point as the pelican box.

This shows that there is another possible explanation [for the results of?] the pelican box throw, that does not involve a throw.

Did you do any of your own work? Yes. The run profile that Dr. Hayes uses, is at the speed of 11.3 feet per second, which is the run of a child of 4 years old. It would be a run on a level surface. We are on a slope surface that is 20 degrees down hill. A child might be able to run, but a 4 year old could reach a run speed of this.

What did you try to do, to approximate the speed using a run slope? I had two twin girls who were a bout Lauren's size, where they threw golf balls down a 20 degree slope. What a child of Lauren's size, would do, approaching a throw.

We had them stand there take a throw. Take a step and throw. Take a few steps and take a throw, and Take several steps and stop at a stick on the ground and take a throw.  The stick represents the edge of the cliff? It represents a point where, beyond the cliff you would slip and fall. It didn't [represent the edge] but as far as you should go.

Keeping in mind that on this slope, there was no cliff there. There was no consequence.  Did anyone give them directions? Yes. My partner was there instructing them to throw golf balls as [far? fast?] as they can.

What I was trying to understand was, how did the girls behave when they were throwing. Did they overstep when throwing. I was trying to find an explanation for Lauren's unintentional fall. One of the possibilities.

Going to see a film of this? Yes.

At times there is a voice that is telling them to run faster? Yes. We were trying to determine possibilities. It was to evaluate the range of possibilities that the girls would undertake in this case with encouragement. Lauren on the cliff may have been encouraged to see where her rocks would have landed.

DDA Hum. Objection! That's complete speculation. Sustained Stricken.

So when the voice is giving direction, that voice is not meant to represent something that happened? Correct. The purpose was to encourage the girls to throw as hard as they can to simulate possibilities.

The video of the girls throwing is played now.

Its a grassy slope. I remember this video from the second trial.

The first throws are simply standing throws. The female adult was the girls mother.

Stops the video to show the "stick" line. It's in line with a level that was held up by the camera bag.

On the video, the man in the video is encouraging the girls to throw real hard.

10:44 AM
I glance over at Sarah as the video plays. I wonder what she is thinking.

To me, from the photos I've seen, the surface of this hill doesn't look anything like the surface of the "horseshoe" area that detectives and law enforcement believe Lauren plunged from. It's more uniform. In the video, to me, there appears to be more grass.

10:52 AM
The video is still playing.  More examples of the girls throwing. The "stick" is now removed, and the girls are told to run as hard as they can and throw as hard as they can.

Dr. Siegmund explains that there is another one where she stumbles as she throws.

10:58 AM
Judge Lomeli calls the morning break.
As the last jurors exit, Brown leans over and with his right hand cupping over his mouth, whispers into the left ear of the private investigator.

11:13 AM
On the breaks, DDA Hum and Detective Leslie often quickly down an energy or power bar.

11:14 AM
The investigator comes over to look at something in the corner of the bailiffs box/desk area. They have a conversation.

11:17 AM 
Brown is brought out.
Off the record, the court and Mr. Laub talk about how much more direct Mr. Laub has.

11;18 AM
The clerk calls for the jurors into the courtroom.

Judge Lomeli tells the jury that this past weekend, it was his bailiffs birthday. The jury yells out to the bailiff, "Happy Birthday!"

After watching the experiment with the girls, what did you get out of that? First to see if the girls stumbled and over stepped. And second what was their speed. He could use that speed in a projectile motion calculation.  How did you measure the speed? The same way that Dr. Hayes did the pelican box.

What speed did you discover the girls were moving? Objection.

What speed did you find the girls were moving at in the instances they were over stepping? There's one where she takes multiple steps over that. 8.2 or 8.9 or an average of 8.55 feet per second.

That's not the same time that Dr. Hayes was using in his trip/run data? Dr. Hayes used 11.3 per second. And that was the running speed of a child on level ground. We used a lower speed of one of the girls after she threw, on the sloped ground. She was not ina full run.

11.3 is the average speed of a child running. [I'm not positive if the per second run speed that Dr. Hayes used was 11.3 or 11.13. I'll have to verify that tomorrow. 5/7 Update: It's 11.3 I'm correcting notes to reflect 11.3 Sprocket.]

After establishing your own speed, for overstepping, what did you do? He used Dr. Hayes' graph and input his own speed overlayed what he got with that over the graphs of Dr. Hayes.

Input 8.55 feet per second over what Dr. Hayes had input of 11.3 feet per second. In these graphs now the blue line falls just to the left of the yellow lines. Now instead of starting below the yellow line and crossing it, it stays just inside the yellow line for the fall trajectory.

Looking at the five boxes up here, is there an example of, where the overstepping with a run of 8.55 ft per second, resulted with an impact with the shelf? In C and D .... they impact with the shelf just a little above where Dr. Hayes says she struck without impacting the upper portion of the cliff.

I miss seeing a young man come in and sitting in the gallery while I was typing.

The data that you found on the spread sheet, included the run/trip math, that was needed to generate you later used as your first blue line? Yes. All the data and graphs I presented were generated, up until this one, the calculations were already in Dr. Hayes' spread sheet.

The only think that I had done, was enter 8.55 feet per second. Otherwise, what I've shown you is from Dr. Hayes' analysis and spread sheet.  He's reviewed Dr. Hayes testimony? Yes I have.

Is there any place in his testimony, where it described the blue trip/run fall? There was no place in his testimony that referenced the run/trip/fall.

He said a slip/trip and run discounted as an explanation [that it].  You found, when run his calculations, did produce a single impact with the cliff shelf.

Now, Dr. Hayes first opinion and conclusion slide. He had six slides with conclusions.

Now will present what he agrees with and what he disagrees with.

Yes. That's his first three conclusions. These are Dr. Hayes second three conclusions.

[I type what I see up on the screen and add in any additional testimony from Dr. Siegmund.]

Now Siegmund has further slides to help explain this.

[I've bolded Dr. Hayes' opinion to separate it from Dr. Siegmund's. Sprocket]

Dr. Hayes First Opinion
Lauren died form a single high speed impact to the cliff face.

Partially agree. Lauren died form a high-speed impact to the cliff face.

But she could have interacted more than once with the cliff Multiple other abrasions on her body prior face or upper chest contact would be masked by a later high speed impact.

Dr. Siegmund explains that the other injuries could be explained by a child who fell prior to then tumbling off the end of the cliff face and striking the shelf further down the cliff face. 

It's impossible to say that she didn't stumble at the top and then the later impact obliterate those injuries.

Lauren had multiple other abrasions on her body, that can be explained by prior cliff action.

In particular Lauren had a facial and chest injury but she also had these shoulder injuries. Those abrasion likely occurred at a different time than the face and chest. could have occurred at cliff interaction at the top, a stumble, and where the impact speeds would be much less. It also could have occurred later on, when Lauren was in the water.

I could not tell where those injuries came from, but I do not think they came at the same time as the chest.

Not saying definitely that's true. It is a possibility. The discussion you just gave us about the multiple other abrasions, your conclusion are another possibility? Yes.

Dr. Hayes Second Opinion.
It's inconsistent with a slip/trip and fall.

I disagree.
Hayes trip run scenario could generate only one impact.
Overstepping a rock throw could generate only one impact.
Closer departure points could generate only one impact.
There are multiple scenarios involving a slip or trip that could have generated only one impact.

Based on the child experiments, overstepping after throwing a rock, could also explain the second impact on the cliff shelf. It's another scenario where a slip or trip or stumble could explain Lauren's impact with the shelf.

I've discussed already that the changing the departure point will change the trajectory.

More explanations.

Disagree a slip/trip and fall scenario are inconsistent. I believe they are consistent. They are one possible explanation.

Dr Hayes' Third Opinion.
Lauren injuries are consistent with being launched at between 10 and 15 feet per sec from point of departure.

Agree. This is one scenario consistent with Lauren's injuries.

But... other scenarios are also consistent with her injuries. Slip, trip, slide, overstepping after throwing a rock...

Other departure points.

The material at the top of Inspiration Point is loose and could cause a slip trip.

You've been to the top of Inspiration Point? Yes.

Dr. Hayes Fourth Opinion.
The fall trajectory that would produce she had an impact is well within the physical capabilities of an adult male.

Agree. [I miss getting the text of the rest of his answer on the screen.]

Dr. Hayes Fifth Opinion.
Slip/Trip scenario would not cause Lauren to fall. Launch scenario would produce all known facts of the case.

Disagree.
Hayes trip/run scenario would produce all known facts of the case.
Over stepping scenario would produce all known facts.
Other departure points would produce all known facts.
Minor contacts at the cliff top from a stumble would produce ... [miss rest of answer on screen.]

Dr. Hayes Sixth Opinion.
Lauren sustained her fatal injury [injuries] by being launched fofceully from the point of departure, impacting the cliff face once, and then landing in the water of the inlet.

I disagree. Throwing Lauren is one possibility consistent with the physical evidence of this case.
The physical evidence does not rule out other possibilities consistent with Lauren's fatal fall.

My conclusions.

Lauren's head injury indicates she struck a hard surface during her fall.
Lauren leg torso and should abrasions are consistent with one or more interactions with the cliff edge and or cliff face.

Possible explanations for Laurens fall include.

-pushed or thrown
-trip or stumble near cliff edge
-sliding on lose soil slope
-overstepping after throwing a rock

These are all possible explanations for Lauren's fatal flaw.

There is no physical evidence to suggest one explanation is more likely than the other.

I cannot discern based on the physical evidence whether she was thrown or fell. There's no physical evidence that proves Lauren was pushed or thrown from the cliff top.

Based on the physical evidence, science and bio-mechanics, [?] cannot be used to conclude whether Lauren's fall was accidental or intentional.

Is this something based on your training and years of experience? Yes. In order to conclude that something happened, we need to exclude all other potential possibilities.

Proving something happened, is proving everything else didn't happen. There are possibilities that we cannot prove.

Direct ends and cross begins.

Dr. Siegmund I have a couple of questions starting off.

You're not telling us that Lauren accidentally fell off? No.

Your not saying that Lauren death is an accident? No.

You're not telling us that Lauren was not thrown from a cliff? No.

You're not telling us that Lauren's injuries are inconsistent with being thrown from a cliff? No.

Dr. Hayes Opinion  #2.
I notice that where you say you disagree, you have four different scenarios.

I don't see in any of these, that ... I don't see where you say that Dr. Hayes could generate one impact?
They don't say that they would generate Lauren's injuries.

If Lauren left running with a leap off the cliff she would impact feet first? She would have to leave the cliff, with no forward rotation.

The defendant's lawyer asked you, if you read Dr. Hayes' testimony? Yes.

[You testified under direct there's no place where Dr. Hayes referenced a [run/ slip-fall as a single impact?]. What I would ask you to do, is look at Dr. Hayes' testimony. Look at the highlighted testimony there. page 5760 line 12.

In fact, in Dr. Hayes testimony he does discuss Lauren running off the cliff as fast as she could? Yes.

[Dr. Hayes testified that] she would land farther, hitting her back and hitting her feet. So on that basis, he ruled that out.

Mr. Laub argues that this is improper impeachment. Judge Lomeli shakes his head.

Laub argues with the court.

Your testimony was that Dr. Hayes said that a run could not produce this simple impact?

Laub very forcefully, or passionately argues his point. He argues that wasn't his witness' testimony.  DDA Hum just as forcefully states it is exactly.

Laub argues with the court again. The court states this is proper cross examination. [The court tells Mr. Laub that he will have the opportunity to redirect.]

The just ... [your?] testimony was the trip run test in that he had in his run sheet, was not on the graphs, and that he did testify that a run could not have.... [miss rest].

DDA Hum: Dr. Hayes did not say that a slip/fall/run would not produce a single impact, what he did say is that they would not produce Lauren's injuries.

I believe Dr. Siegmund did agree with that.

11:58 AM 
The noon break is called.  The court addresses counsel.

Let me say that these speaking objections. The court is not going to tolerate that. It's heated. The court is not going to tolerate that.

But this witness is being asked, Isn't that correct.

It's proper cross examination at this point. You're going to have to bring it down a notch, because it's too heated. The court informs Mr. Laub, like he did in front of the jury, that he would have the opportunity to redirect.

Laub argues with the court as to whether this is proper cross examination. Asking if his witness can ask to explain.

We are now on break. The young man [that I didn't notice come in] sat with the pretty woman in the gallery and they both spoke to the defense investigator.

12:01 PM
Everyone packs up for the noon break.

1:32 PM
Back inside Dept. 107. Brown has not been brought out yet. Judge Lomeli takes the bench.

1:34 PM
Jury enters.

Dr. Siegmund, did you talk with the defendant's lawyer over the lunch hour? Just briefly.  Did you discuss your testimony? No.

The court reporter is now reading the prior testimony that he was asked on direct.

Although using this calculations, the graph did [I can't keep up with the reading that DDA Hum is going over. There is read back by the court reporter.]

DDA Hum has made his point.

Do you agree with me that Dr. Hayes did not say, that running would not produce a single impact? What Dr. Hayes said was that it would not produce the injuries that Lauren sustained. [Yes.]

Dr. Siegmund's CV, is that in fact, your CV? Entered into evidence. Witness agrees that his CV is current as of December 2014.

The name of his firm, MEA, and there are about 60 employees. Their firm is located in Vancouver. They have offices in Los Angeles, Toronto and San Francisco.

Various areas that his firm covers and that they are all divisions of MEA forensics. It also has a marketing department. The marketing department helps to generate work.

They sponsor events, charity events, hockey, to help generate contacts in business? That's correct.

One of the things that you do, is you go and conduct analysis and testify as necessary? Yes. And other people do other things. And he gets paid for his testimony, Yes. You don't testify for free, correct? [Correct.]

Approximately how much to you anticipate making for your work in this case? The prior work in this case was I think, $36,000.00 but we weren't paid that much. And this portion of the case we were allowed to charge $14,400.00 plus travel.

So 50,000.00 without the travel? Except, I don't think we were paid the entire 36,000.00 I think we were paid about $25.000.00 ... US Dollars.

When did you get your Bachelor of Science degree? In 1986. Bachelor of Applied Science.

Is that when you also started with MEA Forensics? Shortly there after. Graduated in May and started in August.

At some point, you went back to school to get your Phd? Yes. Got that in 2001.

Then went back to MEA Forensics that same year? Yes.

He was an adjunct professor. DDA Hum asks if he teaches as an adjunct professor. Some do, I do not. I do not run a course of my own. He steps in for other teachers.

[Question about if he's ever taught a class.] He's never done that. He doesn't have time for that. He consults.

You co-supervise graduate students? Yes.

How many? Currently I have about 4.

[What is the total you've supervised?] He's supervised, it's not many. 10 or 8.

He's never been a salaried professor at a university. Never had appointments at hospitals.

Have you ever taught classes at any hospitals? No.

Now you have that medical training correct? I have taken classes with medical and dental students and those classes are offered by the faculty of medicine. How many? I think it was two or three.

It was part of his Ph.D. program.

Gross anatomy, which is a dissection course, where we dissect cadavers. The second is neuro-anatomy. It's the same thing except focused on the brain. The third was muscle biophysics, how muscles are studied.

How many cadavers did you dissect during your course in gross anatomy? Students are assigned a single cadaver, but exams are on all 50 in the room.

Dr. Siegmund expands. I would have spent time on all 50. The following year, I was asked to help as a TA [teaching assistant] the gross anatomy lab, but I wasn't able to keep that and do all my work as well. I ultimately declined.  How long was that? Eight months.

Dr. Siegmund worked as a TA less than a month.

Have you ever done any autopsies? No.

Not a medical doctor? No.

Not a forensic pathologist? Correct.

You talked a little bit about the materials you reviewed for this case, other than Dr. Hayes testimony, Have you reviewed any additional material, from the time you testified previously until the time you testified in this case? The only additional material recall reviewing was my prior testimony.

He testified in 2009 correct? Yes.

So you had reviewed [an] amount of material prior in 2009, and that was Dr. Hayes testimony in 2009, and subsequent testimony from Dr. Hayes in this trial.

Did you review the testimony of Dr. Chinwah who conducted the autopsy? No.

Are you aware that Dr. Chinwah had performed over 8,000 autopsies? No.

Are you aware that of those autopsies Dr. Chinwah testified somewhere between 100 to 200 those autopsies involved falls from heights? I recall a number like that.

You remember that from me questioning you previously? Correct.

Dr. Siegumnd, would it be accurate to say, your firm's focus is in traffic collisions and slip and fall from a standing height? Yes. And more recently football injuries.... concussion injuries.

[The witness is asked if that's soccer or American football]. American football.

The cases on which you have done work, would those be primarily civil or criminal cases? Many more civil than criminal. How many criminal [cases] have you testified in the US? Believe this may be the only criminal case in the US that he's testified to.

Now, you do have a in your CV a number of peer review publications? Yes. How many of those involve falls from great heights? None.

Research actives in your CV, how many of those involve falls from great height? None. Investigated falls from standing heights.

You've written a book correct? Yes. And additional chapters in other books? Yes.

Did the book involve falls? No. And [I] wrote three or four book chapters. Do any of those involve falls? No.

He's not testified in cases that involve falls from cliffs. They were step stools or ladders. Of approximately 3,500 cases he's handled, this is the highest fall. The fall equations are the same ones we use for bicycle impact.

The physics are the same, the physics don't change? Generally not.

When we're talking about fall, we're talking about a movement from one point to a lower point. [Yes.]

Dr. Siegmund, you were first contacted about this case in 2004? I have April 5th, 2004.

In 2004, did you actually go to Inspiration Point? Or did you just review materials? I went to Inspiration Point and [?].

Did you take photos back in 2004? Yes.

The photo you had in your PowerPoint, you remember when that photo was taken? Yes. I need to look in my computer. Jan 28, 2009.

So when you were testifying that the topographic map, doesn't comport with the photograph, the photograph was taken in 2009, that was your photograph? [Yes.]

Asks about Dr. Hayes' photos and topographic map and when it was done.

The witness did not use a PowerPoint presentation when he testified in 2009.

When did you prepare this PowerPoint that you used today? Last weekend.

So, eight or nine days ago? Yes the first slide may have been prepared on Wednesday, It wasn't all prepared until Sunday night.

You were first contacted in 2004 but the PowerPoint wasn't put together until two weeks ago? [Yes?]

And you gave the PowerPoint to the defendant's lawyer a week ago Sunday? Yes. Sunday night.

Are you aware that reports and materials that are generated by experts are supposed to be presented to the other side 30 days before trial to the other side? No.

Did the defendant's attorney tell you that? No.

When you provided the PowerPoint to the defendants lawyer on Sunday, did you discuss the PowerPoint with the defendant's lawyer? Yes.

Was that the first time you talked to the defendant's lawyer? Sunday.

Was the defense investigator Mr. Ross, was he there was well? Yes.

Did you suggest to the defendants lawyer any areas of inquiry that he might want to ask of you? [Miss answer]

Did you go over questions he might want to ask you? Informally yes, not formally, no.

Did you discuss any, [in?] any way, with the defendant's lawyer, questions that he might want to ask you? I showed him the presentation, and that would naturally suggest questions, yes.

Did you discuss any questions with regard to that PowerPoint, other than what are we looking at? I imagine, yes.

Now you also reviewed a report generated by Dr. Hayes? Yes. There was also a supplemental report as well? Yes.

Showing the reports to Dr. Siegmund. People's 92.

Primary report by Dr. Hayes. Yes he reviewed this.

And this report details Dr. Hayes qualifications, what he reviewed, what he did, calculations he made, findings and conclusions? [Yes, yes, yes, yes, yes.]

And also reviewed Dr. Chinwah's autopsy report? Yes.
What he did and what he found? His observations, yes.

The injuries that he found significant? Yes.
Also reviewed the photos taken at the autopsy correct? Yes.
And also reviewed the diagrams? Yes.

In addition to Dr. Hayes report and the supplemental report which you said you also reviewed, correct? Yes.

And also reviewed supplemental material that was provided by Dr. Hayes that was not in the report, which is where you got the figures and the black and white diagram? Yes.

So all that was provided to you from Dr. Hayes? Yes. And it's your understanding that was generated by Dr. Hayes? Either Dr. Hayes or one of his associates.

Did you prepare a report similar to the report by Dr. Hayes, detailing your qualifications, what you did, your findings and conclusions? No.

Now, obviously you had the opportunity to review Dr. Hayes report? Yes.

And you would correct me if I' wrong, you would presume, that if you gave me a report, I would give that to Dr. Hayes and have him review it? [Yes.]

And had you been asked by the defense to prepare a report, you would have done that? Yes.

So we can conclude that you were not asked by the defense to prepare a report? Yes.

Now Dr. Siegmund. I think, one of the things you testified about this morning, Lauren could have suffered multiple impacts with the cliff, and one impact could have been masked by a second impact? Yes. You might be able to drop an apple and it gets a bruise, and if you drop it again, you might not be able to tell, it could land on the same spot.

In reviewing Dr. Hayes testimony, Dr. Hayes reviewed at least the same amount of material that you did. I believe so.

So Dr. Hayes may have looked at more? Yes.

I recall on that one of your slides, you [criticized? used one of?] Dr. Hayes slides of Dr. Hayes of the autopsy injuries and that you added some of your own? [Yes.]

You know that Dr. Hayes did not include the injuries that he when he testified, that he did not consider significant.

Did you know about testimony where a witness testified that he saw Lauren crawling on her hands and knees on a rocky trail? Wasn't aware of that.

Are you aware of Dr. Chinwah has seen injuries that involve falls from a great height that involve slipping and sliding. No, I didn't read Dr. Chinwah's testimony.

Well, from any source. Did the defense attorney tell you that Dr. Chinwah is familiar with injuries from great heights of slipping and falling? No.

Would you agree, that Dr. Chinwah, having performed this number of autopsies, ... [?] ?

I don't know what Dr. Chinwah has observed or the nature of the injuries whether they were inconsequential, I don't think that I can answer.

Are you saying you have the same familiarity as Dr. Chinwah does with falls from great heights? No.

Are you aware that Dr. Chinwah testified, that he would have seen more numerous scrapes and lacerations if she had slipped and fallen from a great height? No, not that specifically.

You know that Dr. Hayes testified, that he would have expected to have seen greater injuries specifically abrasions and lacerations.  I thought that was confined to his slip/trip on one of the maps.

Were you aware that Dr. Chinwah had discussed his conclusions about [this case]? I only know that from the question you asked me last time.

Anothe question about what Dr. Chinwah said. He testified that if Lauren had actually fallen, he would have expected more lacerations and abrasions, and if Dr. Chinwah had discussed those conclusions and with Dr. Lakshmana, and if Dr. Hayes, said that if Lauren had fallen from a great height, he would expect to see more lacerations and abrasions on Lauren's body, would that change your opinion? No.

Question as to if he knew that Dr. Chinwah had inspected Laurens clothing [missanswer]

Question as it if he inspected Lauren's clothing. [No.]

Are you aware that Dr. Chinwah testified that Lauren, under his opinion, that Lauren died from an asissted drop, and... [?]?

He read that, from the prior statement in the autopsy report that that was limited to the major injuries.

So Dr. Chinwah said, basically what Dr. Hayes said? Yes.

Now you testified that in order to draw a conclusion with regard to what happened, you would have to eliminate all other possibilities? Yes.

That Dr. Hayes in his slide, used limited points of departure? Yes.

And Dr. Hayes states in his testimony that he analyzed an area 8 ft by 12 ft? Yes.

And that Dr. Hayes stated that it's not necessary to analyze every point within that 8 ft by 12 ft area to draw a conclusion? Yes, but I don't necessarily agree with that.

Well lets talk about that. DDA Hum asks about a throw from 8 feet from the edge and Lauren missed the cliff and went directly into the water, and if you would then also have to test from 4 feet from the edge.

In fact that is what is mean by testing limits of boundaries? For example I give you a tennis ball from the back wall, I wouldn't need to have you stand from where I'm standing to see if you could hit the back wall? Well, that only takes into account ....

Now another question about throwing a bowling ball against the back wall.

So we do not need to analyze every point within this 8 foot area? That's correct. but if the scope within an engineering analysis, .... [miss rest of answer]

Would you say, there is a limited area, where someone could leave Inspiration Point and there is a limited area where they could end up in the inlet to the east? Yes.

Brown leans in to speak to his investigator. They have a conversation.

You did talk about Dr. Hayes of grasp of projectile motion. And about the black lines that you don't go inside the cliff. Didn't Dr. Hayes only testify that the lines only represented what would happen when Lauren first interacted with the cliff and everything else wasn't representative as to what would happen? [Yes.]

Has Dr. Siegmund read prior of Dr. Hayes testimony.

And he never said that her body would go into the cliff. [Yes.] And he's not suggesting that he was trying to tell us that he would be saying that she would be inside the cliff were you? I was not.

You did talk about the fact that in the materials that Dr. Hayes provided you indirectly, there was a scenario that if Lauren was running at 11.3 ft per second she would have a single impact with the cliff? Yes.

Did the defendant ever anyone that Lauren was running as fast as she could, and ran right off the cliff? No, I think he looked away.

No where in any of the reports, is there anywhere, that Lauren was running as fast as she could off the cliff? Not that I'm aware.

And, there's just one other area I want to talk about with you, and that's this video of the girls throwing golf balls.

In [your testimony, you testified that, you had two girls that were approximately Lauren's height and weight. They were Riley and Hunter? Correct. Both were a little taller and one a little lighter and one a little heavier. And they were 6 years old.

Lauren was 4 years, 2 months and 10 days. You put your [someone from your] department put a stick on the slope, correct? Yes. And the girls were instructed not to go past the stick? Correct.

The consequences of going past the stick, is not that they fell 120 feet to their death? Correct.

So the consequences for Lauren would have been significantly greater? Correct.

Out of the 44 trials, they went past the stick area, twice? Right.

And at one point, your partner had taken the stick away? Yes. We had removed the boundary.

Is your testimony, is that a four year old would not know what the edge of a cliff was like? I would not know [what a four year old would/wouldn't know?].

The stick that was there, there was one situation where someone went past the stick? [Miss answer.] One where they went past when they were told not to go past? Yes.

In addition to that, we could hear your partner encouraging them to take a big run and throw, go really fast up to the twig. Run really fast. Stop really close to the twig. We could hear that from the video? Yes. all of those were possibilities.

There were 26 times, where your partner encouraged [the girls] to run faster, get closer to the twig, take bigger steps? I didn't count them, but I think they did them for most of the trials where they were not standing still.

Do you have nay information that when Lauren was on the top of the cliff, [Lauren took a] big run and big throw? I don't have any information.

[Another question as to whether or not Brown said that to Lauren.] No I don't have any information that anyone said that to Lauren.

There's nothing that Lauren was encouraged to run as fast as she could and throw as far as she could? Not that he knows of.

Nothing further.

Cross ends and redirect begins.

The prosecution asked you a number of questions and number of points about Dr. Hayes and whether or not Dr. Yayes had [testified?] to Lauren running. Do you recall this portion of cross? Yes.

And the prosecution has placed this in the context of Lauren running full spedd off the cliff. [Do you] recall that? Yes.

When you looked at Dr. Hayes spread sheet, was there a label that Dr. Hayes had applied, that said running full speed off the cliff? No. ... The one area we focused on, was something labeled, run/trip or trip/run.

The question, you were cross examined on, your testimony had denied that Dr. Hayes, the question was asked on direct was regarding trip run? We were discussing that part of the analysis, yes.

So when you responded with the answer that the prosecutor sought from the record, and you said the run, without including the word, trip, were you referring to something different than the question that was? The question I was asked us as if the question I was posed, a trip ... a trip would catch the feet.

The witness gets confused on which question he was just asked about by Mr. Laub.

In repsonse to your question I had in mind we were dealing with the trip run scenario. So there's no significance that in your use of the word run, rather than the word trip, that you were actually speaking of something to running... Object to question. Leading.

I was referring to the trip/run, and if I just said run I apologize.

You were also cross examined whether the wording used by Dr. Hayes and his research, a single impact vs producing injuries? You recall? Yes.

Is it correct from you review of all the materials in this case including Dr. Hayes work, that when Dr. Hayes is referring to a single impact, he's referring to the injuries int he autopsy report? Yes.

You were also asked a number of questions of how much of an academic you really are? Do you recall this question? Yes.

As you sit here testifying for the jury, are you saying you are someone who is a nationally recognized academic? No. Is it what your are of [experience? experts?] ...? Objection. Leading.

If your expertise is not academia, what is it? My area is applying the knowledge in real world application.

Now questions regarding medicine, over how many years he has worked as a conslutant? 29. And 3500 consultations? Cases.

Was part of your task was to learn about injuries and how they relate to biomechaincies. Certainly since 2001, My focus was what causes inures. I'm not a medical doctor as to how to treat injuries.

[You] had to study a wide variety of injuries and a wide variety of causes ?Yes. Yes.

And this case for you, outside your experience? Skull fractures, neck injuries, not to belittle but are the bread and butter [of his business/practice] ... what kind of force, that could cause these injuries.

Questions about work before, falling from a great height. Yes. The bio mechanics, is it necessary to have experience of reviewing great falls .... [in order to determine?] ... ? The great height simply changes the impact speed, with the cliff face, or in this case, the shelf. ...Mostly what I've studied have been lower impact. The speed of this case is what we more see in auto accident impacts. The principals are fundamentally the same. The exposure is greater than the falls that we've seen but not out of the range of car crashes.

A standing height fall can cause a skull fracture. The additional height we see here considerably causes a skull fracture.... but not ... [miss rest of answer].

Laub asks questions about [how] the bio-mechanics doesn't change and what you have to do is plug in a formula? Objection. Leading.

[I believe a rephrased question.] The witness states the physics are the same. As you get into higher and higher speeds, the equation breaks down because you have to get into air resistance. But as you get into that you can [work out?] the air resistance into mass.

Now questions about how he was asked about Dr. Chinwah's report. Asks him to look at the end of Dr. Chinwah's report. One of the things you also reviewed was his statement.

DDA Hum objects on hearsay grounds. Sidebar.

The jury relaxes and stretches and chats among each other during the sidebar.

Judge asks the jury if they are hot. The jury says yes.

Mr. Laub is back to questioning.

2:55 PM
You were further questioned again under cross about the issue of 11.3 ft per second that appeared in Dr. Hayes' spread sheet? Do you recall? Yes.

This was presented to you as running straight off the cliff? Yes.

Was that tied in that spread sheet to, running straight ahead off the cliff? Objection this has been asked and answered.

The 11.3 feet was tied to the trip/run.

Is there any evidence that you are aware of that Lauren understood that what would happen if Lauren went past a certain point? There is no evidence.

You were also cross examined ...  I should also clarify that last point.... but I don't thin he finishes this.

Questions on cross about partner encouraged the girls ran faster and throw harder.

What was the point? The point was to explore possibilities. These are things of Lauren's height and weight would do. The girls were encouraged to throw.

I'm going to object this is speculation. As to this is what someone what Lauren would do. [I believe this objection is sustained.]

Was the point of what you were doing, to try to show what in fact Lauren did, or was it to show there are possibilities that were reasonable as to what happened? It was the latter. I was exploring reasonable possibilities.

Redirect ends and recross begins

Is is your testimony Dr. Siegmond that is the reason ... possible that at the top of Inspiration Point, that the defendant was saying to Lauren, run as fast as you can run as close as you can to the edge, is that a reasonable possibility to you?

Its' possible. I'm not a judge of what's reasonable.

To you that's a reasonable possibility? I don't know what was said betwen Mr. Brown.
I know...

I believe there are more questions about what's reasonable for Lauren at the top of the cliff.

The utterance, but the reasonable possibilities, was the [speed?] of getting close to the edge.

It wasn't trying to replicate what Mr. Brown might have been saying? Objection leading.

Judge, I think he's testified to that.

Judge asks the witness, what was the point of your partner, in asking all those statements of the girls?

What were the possibilities, what would children would do, [what might happen] if they were to throw a rock.

Recross is finished and the witness is excused.

2:58 PM
Judge Lomeli calls the afternoon break.

3:22 PM
Jury files in.

Call the next witness.

JAN MUELLER

What was your occupation 1999 to 2000. I was a court mediator for Orange county Superior Court. I helped parents with custody issues come to some kind of agreement.  She has a masters in psychology. At the time, [to qualify for this work] she had to have five years past graduate experience. Also required to have continuing education.

When did you start working for the court? August 1990.   Family court? Yes. About how many? Currently done about 10,000 meditations.

She is employed by the court.

Met Mr. Brown? Yes. Met the mother, Sarah Key-Marer? Yes.

First mediation January 3, 2000. Before that, did you look and see that they had met another court mediator? Yes. Once before.

When you meet with parents, do you have an initial explanation about the mediation process? Yes. I tell them that the process is confidential. I don't tell the what should happen. That I don't tell the court what happens, except if there is a safety issue, regarding the parents.

And when you met Mr. Brown and Ms. Marer, did you explain this to them? Yes.

On January 2000, did you try to help these two parents about visitation? They reached a temporary agreement. That was to hold for how long? If made into a court order it can be held for so long, they were to see me in February.

In Feb did they also reach an agreement? They reached a temporary agreement. Did that include overnights with her father? Yes it did.

Did the parents at some point, the parents express that their relationship had [broken down]?

June 2000, learned Mr. Brown believed that the mother was physically abusive to Lauren and they weren't communicating well. Mr. Brown would sometimes not speak with Ms Marer and the relationship had deteriorated.

Other than that, she had telephone contact with both parents separately.  That's when she spoke with the parents.

She had an note from Sarah and she believe she spoke to her.

In these phone calls, would they complain about the other? Mr. Brown was making allegations Sarah was physically abusive to Sarah, and each of them talking negatively about them and to other relatives.

So Mr. Brown thought Sarah was talking negatively about him and Sarah thought he was talking negatively about her? That's correct.

So at the June 22nd meeting, realizing that you had tow parents that were not working well together, what did you decide to do? I met wit them individually to start with and just to find out what was going on.

Did you decide that it would be good to have a 730 evaluation? After the June 22 meeting? Yes.

Explains the 730 evaluation. A psychologist interviews the child, interviews the child with both parents, sees the parents separately, they do psychological testing, and the result is sent to both parties and the court.

The goal is to have recommendations made for custody and visitation.

Are you what is called a mandated reporter? Yes.

I am required by law, to make a child abuse report, if there are allegations of abuse.  A 730 evaluation, is that something that is mandatory or is that something that is discretionary to you? I don't understand your question.

Is a 730 evaluation different or part of the mandatory reporter. [That is not a part of being a mandatory reporter.]

Did you make any kind of report in this case? Yes, I made a report to social services. I did do a consultation with social services to see if it was a report that they wanted to make.

Did Mr. Brown ask you to make this report? Not that I recall.

One of the things that Mr. Brown had photos of bruises on Lauren's legs? Yes that's one of the things. she never saw the photos but that was one of the things that she was made aware of.

I don't know if I talked about forming a relationship, one of the things that...

I had some concerns that he was not very understanding about child development issues.  The child was young, so it was environmentally developmental for the child to be uncomfortable being away from the mother. He didn't understand why she didn't just want to be with him.

Did he ever say or do anything that indicated he didn't want to be with Lauren? No.

Did he want more visitation with Lauren? Objection. Foundation.

He wanted more visitation? Yes.

What is it that he expressed that he stated he wanted? That he wanted to have more additional time.

In your evaluation of his demeanor, did he appear to have strong interest in developing an interest in Lauren? Objection. Sustained.

Did he talk with you about Lauren? Yes.

Did Mr. Brown in his words, your perspective, did he show a strong interest in developing  an interest in Lauren? He appeared to be interested, yes.

Did you have any concerns about him visiting Lauren? No.

In regards to Mr. Brown's expectations of Lauren, the lack of awareness of Lauren's developmental stage and her relationship with her mother, when you talked with Mr. Brown about this, did he make any improvement? Yes. I think he did.

Asks about a note from Lauren's mother. [The] note said, that she wanted to reschedule the next mediation immediately, because Cameron was getting aggressive, if she didn't have Lauren adopted in 30 days, or that it was going to get ugly.  Did Mr. Brown say anything to you, that he wanted to have Lauren adopted? No.

Did Mr. Brown ever say it was financial burden? We didn't discuss finances.

Did he express Love for Lauren? Define Love. Mr. Laub moves on.

He was calm to angry. Would he have at times a muted affect? Sometimes.

[Another question about Brown's demeanor in mediation.] I expect people to be very emotional in mediation so I would say no.

Did he ever say he desired to have full custody of Lauren? Yes.

At some point, you were interviewed by Detective Leslie? Yes.

Did you tell Detective Leslie, that Brown wanted to form a relationship with Lauren? Yes.

And you told him that Mr. Brown's interest was growing stronger the longer he spent with Lauren? I don't recall that.

Did you say that Mr. Browns emotional ... okay I'll move on.

Did you tell Detective Leslie, you felt that Mr. Brown loved Lauren? I don't recall that.

Regarding difficulties you'd seen with Mr. Brown in your office, that he had problems compartmentalizing his relationships? What did you mean by that? He would put his relationships in separate areas and put that by the side. So when he would get angry he would just close off.

Did you tell Detective Leslie, that he was black and white in his thinking? Yes.

And that he had frustration issues? Yes, I did.

A juror's phone goes off.

Luab looks through his notes.

Direct ends and cross begins.

A few questions, you actually met with the defendant and Sarah on two occasions. and the third [meeting] separately? Correct.

In reviewing the file, there was a mediation prior to you on Jan 3 there was one before that? Yes.

That was on Oct 2 1999? Yes. And there was one prior to that where the defendant didn't actually show up? Yes. The date she doesn't remember.

There was a mediation scheduled on September 14, 1999, where Sarah showed up and waited 15 minutes and the defendant didn't show up? That's correct.

Back at that time, there's an orientation that they go through, with someone else, that would last about 15 minutes and they would get a pamphlet at that same time. 

DDA Hum goes over the pamphlet, and that it states that allegations of child abuse are reported to the court.

If you can mediate an agreement between the parties, then that actual agreement becomes a court order? Yes.

On Jan 3rd, they agreed to a graduated visitation schedule, and that was stamped as a court order? I don't know if they went to court [for that] but I assume they did.

Next saw [them both] on February 29, 2000.  Which transitioned from supervised to unsupervised visits? Yes.

Sarah thought the relationship was improving but the defendant thought it was staying the same? Correct.

There were phone calls prior to the June 22 meeting.

In June, Sarah, ... at that 22nd meeting, it was the same time that Brown made the allegation of child abuse.

At that meeting she learned that Brown was refusing to speak to Sarah, and she suggested that [the parents] use a notepad that Lauren could take back and forth.

Did Sarah indicate to you, that Lauren was saying things about distancing herself from Greg and Josh.? Yes. And that Lauren was saying things that Sarah was a bad mom? Yes.

[About Brown's allegations of Sarah abusing Lauren] He didn't just say that Brown was concerned about bruises on her legs, but that the defendant also said that Sarah had kicked her? Yes. And that Sarah had also grabbed Laurens face? Yes.

Did you believe those allegations Ms. Mueller? No I did not.

Did you tell Sarah that the defendant made those allegations? Yes. Did you, when the defendant make these allegations [did you tell the defendant] that there might be alternate explanations but he refused to believe that? I don't recall that.

Did you tell the detectives that you made suggestions to the defendant that there might be other explanations for the bruises? I don't recall that? Well if you did, would it be true? Yes.

She recommended the 730 report, because she had concerns about the defendant's psychological [?] emotional make up/stability.

She's not really there to diagnose, she's there to help work out a visitation plan.

She never saw Brown with Lauren together.

You were worried about his emotional stability? You knew he had issues with his mother? He didn't talk about it.

More questions about Brown and that he didn't want the child to spend time with his mother.

Noticed this anger and frustration when he talked about his mother? She doesn't recall. So DDA Hum will present her with her previous testimony.

DDA Hum goes over her prior testimony. Did the defendant in fact tell you he had issues with his mother? He said that he didn't want Lauren to see his mother.  Did he in fact say that she was a bad person? Yes.

Did the defendant tell you that his mother was an evil person? I believe so.  Do you remember giving those answers? I believe so.

From the mediation, because part of what you were trying to do was arrange a schedule, you knew how much time the defendant was spending with Lauren? Yes.

And that the defendant had filed a claim of 50% visitation? Yes. And the defendant never came close to 50% visitation? No he did not have 50% visitation.

You told the detectives to look at the court file? .... The court file was public record, but I don't recall telling them that.  I said they could go look at it.

I'm not there to diagnose. I had concerns about the stability and the behavior that I saw.

Were you asked these questions and did you give these answers?

Reads prior testimony.

Did you have concerns about psychological issues on part of the defendant ? Yes.

You had concerns about emotional issues on the part of the defendant? Yes.

And prior, you testified about... I miss this DDA Hum is reading too fast.

Going to recess.

4:01 PM
The court releases the jury. The witness will be back tomorrow to finish her testimony.