Paul Gallagher - Cross (Part 1)

MR. JACKSON: It's not mine.

MR. JACKSON: Now, your honor.

MR. JACKSON: Mr. Gallagher, you have already established that you were at the scene on January 29th, early morning January 29th, 2022.

MR. JACKSON: So you were integral to at least an initial search of the scene which recovered the drinking glass that you've shown us, as well as some of the blood byproduct that you've talked about.

MR. JACKSON: Okay. You were the ranking person on scene. You've already described that.

MR. JACKSON: There were also several other officers from Canton PD there with you.

MR. JACKSON: Can you name those other officers?

MR. JACKSON: Okay. When you — let me back up and ask a different question. Given the fact that you were the ranking officer, the way that it works in a police department is everybody sort of reports up the chain of command. Correct?

MR. JACKSON: So they would have all reported up to you in some particular —

MR. JACKSON: And then of course you report to the — I think you're the deputy chief, and then the deputy chief reports on up to the chief.

MR. JACKSON: You were involved in not only the exposing of some of that blood byproduct, but also exposing the glass with the leaf blower. Correct?

MR. JACKSON: You were responsible for utilizing certain equipment. You chose a leaf blower at the time.

MR. JACKSON: There was also — I'm guessing there was also some use of your hands and/or the gloved hands with some others to recover some of the items.

MR. JACKSON: How did you get the glass into a bag?

MR. JACKSON: Somebody had to pick it up, right?

MR. JACKSON: That's what I mean. The use of hands to manipulate some of the evidence.

MR. JACKSON: No, that's okay. There was also some plastic cups that we've talked about. We'll talk more about those in a second. Those were utilized as well.

MR. JACKSON: And you were responsible for the use of those as well.

MR. JACKSON: In terms of the search of the scene, the recovery of evidence, the recovery of biological material, the use of tools to recover those biological materials, all of that rested at least ultimately at the scene

MR. JACKSON: Isn't it true that you weren't interviewed in this case with regard to anything having to do with this case until April 3rd, 2024?

MR. JACKSON: And that was about 2 and a half years, nearly 2 and a half years after this incident.

MR. JACKSON: Michael Proctor. You know that name?

MR. JACKSON: Who is Michael Proctor?

MR. JACKSON: Correct.

MR. JACKSON: As you sit here, you don't know that Michael Proctor was the lead case agent for —

MR. JACKSON: Okay. Do you know that he was the lead investigator assigned to the case?

MR. JACKSON: Right.

MR. JACKSON: Mr. Gallagher, I'm not asking you to. I'm just asking if —

MR. JACKSON: Okay.

MR. JACKSON: Okay. He may have had a partner.

MR. JACKSON: But it's not unusual to have a lead case agent — the person who's responsible for most of the search warrant writing and the memorialization of documentation of evidence collection and the movement of evidence and booking into evidence, things like that.

MR. JACKSON: You're also familiar with Yuri Bukhenik, correct?

MR. JACKSON: You're also familiar with Lieutenant Tully.

MR. JACKSON: They're all Massachusetts State Police officers, correct?

MR. JACKSON: Did Michael Proctor interview you before April of 2024?

MR. JACKSON: Did Bukhenik interview you before April of 2024?

MR. JACKSON: Did Lieutenant Tully interview you before April of 2024?

MR. JACKSON: Did anybody else from the Canton Police Department — any deputy chief or the chief — interview you formally about your conduct and responsibilities before April of 2024?

MR. JACKSON: Did anybody at Canton PD, separating out Massachusetts State Police — did you sit down at Canton PD and provide an interview with anybody at Canton PD about your conduct at the scene?

MR. JACKSON: Going to the scene, collecting evidence, securing evidence, transporting evidence, booking evidence, those kinds of things. Your conduct at the scene, sir.

MR. JACKSON: Okay. Other than briefing, was there a formal report written?

MR. JACKSON: Or a formal interview conducted of you?

MR. JACKSON: Okay. Tell us when you wrote your report about what happened at the scene, memorializing what you did at the scene.

MR. JACKSON: You didn't write a report about this scene that day?

MR. JACKSON: You never — in fact, the fact is you never wrote any report about what happened at the scene.

MR. JACKSON: You didn't memorialize that in any formal way on Canton PD letterhead to describe what you did and how you did it at the scene.

MR. JACKSON: Normally, when you report to a scene as a first responder, you would be expected to write a report about that, whatever that conduct is.

MR. JACKSON: Now, what if you're the ranking person at a scene that ultimately turns into a homicide scene?

MR. JACKSON: Under ordinary circumstances, you would respond to a scene as a supervisor and you would oversee what other people are doing.

MR. JACKSON: Can I finish?

MR. JACKSON: I don't want to talk over each other. I apologize. You would want to supervise or oversee what your subordinate officers — whatever he or she might be doing, or they might be doing — you're going to oversee that, but they're the ones actually conducting the investigation, or picking up evidence, or doing the interviews and writing things of that nature.

MR. JACKSON: Detective Sergeant Lank's investigation.

MR. JACKSON: So in that circumstance, you wouldn't be expected to write a report because all of that conduct is memorialized by others subordinate to the supervisor.

MR. JACKSON: But in this case, quite the opposite happened. You were the one that was in the video utilizing the leaf blower.

MR. JACKSON: You were the one that actually exposed the drinking glass.

MR. JACKSON: You noted the drinking glass and actually called somebody else over to take a look at it.

MR. JACKSON: You directed someone, Sergeant Lank, to pick up the drinking glass and recover it as a potential piece of evidence.

MR. JACKSON: You noted the blood or the coagulation of blood in and around that area.

MR. JACKSON: You noted where you believed the drinking glass was — in other words, what location, if there were GPS coordinates, where it would be.

MR. JACKSON: And you instructed others to transport that important evidence back to Canton PD to have it booked.

MR. JACKSON: You also secured the plastic containers in which to recover the blood.

MR. JACKSON: You also directed someone to get a bag to put the plastic containers in and ultimately transport it.

MR. JACKSON: So, you would agree with me, Mr. Gallagher, that in this circumstance, you were the centerpiece of the recovery of evidence and the investigation as it was at that time in that limited context. You were the centerpiece of what was happening at the scene.

MR. JACKSON: But you didn't find it important enough to write a report yourself.

MR. JACKSON: When you were there at the scene — at what time was it, by the way?

MR. JACKSON: Okay. You knew that that person who was fighting for his life had already been transported and was in the best care we can provide at Good Samaritan Hospital.

MR. JACKSON: So certainly you're not excusing away the idea that you didn't memorialize your conduct because you were too busy fighting for someone's life. That's not what you're saying.

MR. JACKSON: Obviously, reporting to a scene and supervising a scene is one thing, but actually gathering evidence is a whole next level. You would agree with that?

MR. JACKSON: Because just to put a fine point on it — responding to a scene as a supervisor, you want to make sure everybody's doing their duty. But the officer or officers who, for instance, uncover — let's say it's a knife or a gun or some weapon or something like that — actually documenting and picking up that evidence and handling it in the appropriate way, that is all highly, highly technical. It's very important to get it right and memorialize it all.

MR. JACKSON: That's why you're highly trained to memorialize and report everything that you do in that regard in a report that can later be used forensically — in other words, in a courtroom setting — to recreate, as best you can, with as much detail as you can, exactly what you did and how you did it and where it was done.

MR. JACKSON: Officer Lank wrote a report in this case.

MR. JACKSON: Did Officer Mullaney?

MR. JACKSON: Did Officer Saraf?

MR. JACKSON: Officer Good — Sergeant Good.

MR. JACKSON: But you did not.

MR. JACKSON: Who was the first officer to find any potential physical evidence at the scene, be it blood or glass?

MR. JACKSON: Okay. Who's the first person to see the glass?

MR. JACKSON: One of the important things that we've talked about, Mr. Gallagher, is documenting the details of evidence recovery, not just the fact that something was recovered.

MR. JACKSON: So, you'd want to know what time of day it was recovered.

MR. JACKSON: You'd want to know who was there and who was around when it was recovered.

MR. JACKSON: You'd want to know what the item is, the condition of the item, right?

MR. JACKSON: You'd also want to know exactly where it's recovered.

MR. JACKSON: In other words, as best you can to pinpoint the exact location where an item was found. That could play a huge role in any investigation, be it criminal or otherwise.

MR. JACKSON: Did you diagram or draw a diagram back at Canton PD or out at the scene?

MR. JACKSON: About where that glass was found?

MR. JACKSON: Did you diagram exactly where you recovered the blood spots that you did recover?

MR. JACKSON: Did you at least, if you didn't write a report, did you at least take notes on a pad about what you were doing?

MR. JACKSON: At some point you mentioned a person by the name of Tom Kelleher. Deputy

MR. JACKSON: Who is Deputy Chief Kelleher?

MR. JACKSON: He was someone to whom — as a matter of fact, probably the only person to whom at Canton PD you actually reported. Correct?

MR. JACKSON: He was the only person to whom you reported up the chain of command, meaning he was your direct report.

MR. JACKSON: Okay. When you responded to the scene, Deputy Chief Kelleher did not come out of his house and take over the investigation. Correct?

MR. JACKSON: That was yours to detail.

MR. JACKSON: So, can you describe what you did to preserve the crime scene? I'm sorry, to preserve the scene, because at that time you said you did not know if it was a crime scene. Is that right?

MR. JACKSON: What did you do in terms of actually preserving the scene for later investigation? What steps did you take for later?

MR. JACKSON: So, let me take a step back.

MR. JACKSON: Have you been trained to preserve scenes?

MR. JACKSON: Okay. What's the reason that we want to preserve a scene? What does that mean?

MR. JACKSON: Collect evidence and make sure nothing is disturbed. Correct?

MR. JACKSON: Civilians can't traipse through or walk through evidence.

MR. JACKSON: You've heard the phrase — someone traipses through a crime scene, you bring evidence with you and you take it back out with you on your shoes or on your feet or your breath or your saliva, whatever it might be.

MR. JACKSON: Preserving the scene is best efforts, best practices to make sure that nothing is moved, touched, messed with in any way. Correct?

MR. JACKSON: And that's what was done here. What did you do? That's my question. What did you do to preserve that scene?

MR. JACKSON: So, you were interested in the area — By the way, I want to clear this up, make sure I'm not mistaken. You described for ADA Brennan basically where Mr. O'Keefe's body was. Correct?

MR. JACKSON: You never saw his body in situ. You never saw his body in place.

MR. JACKSON: You were told by Sergeant Lank generally where his body is. Correct?

MR. JACKSON: That's my next question.

MR. JACKSON: And Sergeant Goode. And Sergeant Goode as well. Right? Never saw — Sergeant Lank never saw him there actually, at any place.

MR. JACKSON: So you're receiving information from Sergeant Lank that he did not have personal knowledge of, and then you're providing that information later to crime scene investigators who are trying to establish a diagram, or some sort of a chart, about where that evidence was, where the glass was, where his body was. Correct?

MR. JACKSON: Didn't you ultimately go out to the scene along with others at Massachusetts State Police when they had a drone overhead?

MR. JACKSON: Sure. So, on

MR. JACKSON: [unintelligible] the drone — I'm interested in the first part, which was you accompanied Trooper Proctor to the scene. Correct?

MR. JACKSON: There were other members of CARS — C-A-R-S.

MR. JACKSON: Okay. So, it's a forensic — a member of MSP who does forensic diagrams.

MR. JACKSON: Or reconstruction of some sort.

MR. JACKSON: So you were there to help provide information about where Mr. O'Keefe's body was found. Correct?

MR. JACKSON: So you were there to help provide information about — or at least you did provide information to them about — where Mr. O'Keefe's body was found.

MR. JACKSON: Except you didn't see Mr. O'Keefe's body, did you?

MR. JACKSON: So that was a guess on your part.

MR. JACKSON: Yeah, it was the information you were told by Sergeant Lank. Correct?

MR. JACKSON: Who also didn't see John O'Keefe in place on the ground at 34 Fairview. Correct.

MR. JACKSON: So his would be a guess also.

MR. JACKSON: But the person, the police officer that was out there at the scene who was helping the reconstructionist establish the formal report — in the CARS report — was an officer who not only didn't see where John's body was, you got information about where John's body was from someone who didn't see it either. Can we at least agree on that?

MR. JACKSON: I'll try it again. The point is, Mr. Gallagher, you happen to be tapped as the person who is going to assist the CARS folks, the MSP, in creating their CARS report.

MR. JACKSON: Isn't it true that you accompanied Trooper Proctor and members of the CARS unit to document Fairview Road and the scene of the incident?

MR. JACKSON: Okay. So —

MR. JACKSON: You were there. You knew Brian Tully?

MR. JACKSON: Have you reviewed Brian's report?

MR. JACKSON: Is it true that what you actually told Brian Tully is that you went with Trooper Proctor — and you're already shaking your head now?

MR. JACKSON: No, I got that part wrong. You accompanied Trooper Proctor.

MR. JACKSON: So, let me be a little bit more defined. So in Tully's report, where he reports what you said, you were actually talking to Adam Lally, my colleague sitting up in front. Correct?

MR. JACKSON: Okay. So now we got that cleared up. Let me ask you again. Did you say in front of Trooper Tully that you accompanied Trooper Proctor and members of the CARS unit to document Fairview Road? Meaning they were documenting Fairview Road.

MR. JACKSON: So, you just said something that I want to follow up on.

MR. JACKSON: The report's not clear.

MR. JACKSON: So, that's an inaccurate report.

MR. JACKSON: I see. And I'm misinterpreting it even though I just read it directly from the report.

MR. JACKSON: Okay. The reality is you did end up going to the scene. Correct?

MR. JACKSON: And you accompanied — I don't want to use a word that you'll challenge. You went with Trooper Proctor.

MR. JACKSON: You were there at the same time Trooper Proctor was.

MR. JACKSON: And you were aware that the CARS team was there so that they could document the scene. Correct?

MR. JACKSON: But you do believe that — as you sit here, you were there — you do believe that that's the reason that they were there was to document the scene, put up a drone.

MR. JACKSON: Did you tell any of the members of the CARS team where you believed John's body was?

MR. JACKSON: Trooper Proctor obviously was not there when John's body was there either. Correct.

MR. JACKSON: So, he would have gotten that information from you.

MR. JACKSON: So, now that's three people.

MR. JACKSON: Yeah. Well, I'm just talking about this report.

MR. JACKSON: —three people in line, none of whom saw John's body, John O'Keefe's body, as it lay in the lawn when he was—

MR. JACKSON: And there's no photographs of Mr. O'Keefe?

MR. JACKSON: There's no video specifically.

MR. JACKSON: There's no body cam.

MR. JACKSON: There's no dash cam that shows it.

MR. JACKSON: Well, hang on a second. You're not sure where Mr. O'Keefe was because you never saw him.

MR. JACKSON: Right. You don't know if he was 7 to 9 feet off.

MR. JACKSON: 12 feet off. You can't say — only approximately.

MR. JACKSON: You did meet with Officer Saraf. You met with all the officers when you arrived at the scene, correct?

MR. JACKSON: And Officer Saraf had been there from the beginning of the morning.

MR. JACKSON: Officer Saraf didn't report to you at that time any statements attributable to my client.

MR. JACKSON: You later went back to 34 Fairview with Sergeant Lank.

MR. JACKSON: And you rode back. Did you ride back to Canton PD with Sergeant Lank or separate cruisers?

MR. JACKSON: I'm sorry. That's a vague question on my part. You went back to 34 Fairview with just Sergeant Lank, and you described a circumstance in which you went in — you were led in by Brian Albert. He went to the kitchen. You were in the family room or some other place.

MR. JACKSON: Yes. Okay. So right next to where he was interviewing—

MR. JACKSON: Jennifer McCabe. Yes. Did you ride back from that — that event — to Canton PD with Sergeant Lank?

MR. JACKSON: And Sergeant Lank didn't say anything to you about his interview with Jennifer McCabe at that time.

MR. JACKSON: Okay. And you didn't write a report about any conversation that you had with Officer Saraf. You didn't write a report about any conversation you had with Sergeant Lank.

MR. JACKSON: Got it. You did say — let me back up and ask you a different question. You testified about a year ago in another proceeding. You talked a little bit about the evidence collection of the biological material — the blood — or, as you — I'm guessing at that time — presumed blood. You haven't done any testing.

MR. JACKSON: But you assumed it was blood just because of your experience and it looked like it could be blood.

MR. JACKSON: How far were you from Canton PD?

MR. JACKSON: Mile and a half. You had your cruiser with you?

MR. JACKSON: Your personal vehicle. In other words, your automobile — where you could get from point A to point B if you wanted to.

MR. JACKSON: Okay. But you also had subordinate folks at the scene that you could have dispatched had you wanted to.

MR. JACKSON: Yes, they did. Or personal vehicles — I'm not sure which. I'm sorry.

MR. JACKSON: So, as a ranking officer at the scene, you could have dispatched one or more of those officers to run an errand — to go do something in furtherance of the investigation — had you wanted to.

MR. JACKSON: Okay. You did. What did you do in that regard?

MR. JACKSON: Got it. You also know that Canton PD has evidence collection bags at Canton PD.

MR. JACKSON: You also know that they have materials and tools to gather biological material.

MR. JACKSON: And those swabs go in little containers to maintain their sanitary nature.

MR. JACKSON: In other words, if you see a blood stain, you don't just walk up with a Kleenex that you find on the ground and wipe it up — there's your blood stain. There is a process for gathering that type of evidence, correct?

MR. JACKSON: Yeah, absolutely my point. Exactly. But if you're a mile from Canton PD—

MR. JACKSON: —you could have gone back and gotten the swab.

MR. JACKSON: But you didn't. Because you just said it's an emergency—

MR. JACKSON: But Canton PD was a mile, mile and a half away — four or five minutes — in a blizzard. Still in a blizzard. It was 3 minutes in good weather. Probably four, five, six minutes in a blizzard.

MR. JACKSON: So let's call it 12, 15 minutes. You certainly could have gone back if you wanted to. You could have just asked one of your officers to go back and get swabs and properly collect the blood material.

MR. JACKSON: And what you did instead — well, 15 minutes would have made a difference — but you asked Sergeant Goode to drive to his house and get a leaf blower.

MR. JACKSON: You could have documented the scene with photographs even if you went back and got a swab. What's the difference?

MR. JACKSON: I didn't ask you to leave the scene. I didn't ask if you're leaving.

MR. JACKSON: So you saw pink stains in the snow.

MR. JACKSON: And you said — "Sergeant Goode" — probably called him "Sarge" — go home and get the leaf blower.

MR. JACKSON: Could have said, "Officer Mullaney, get your butt over to Canton PD and pick up 10 swabs."

MR. JACKSON: He wouldn't have had access to the swabs?

MR. JACKSON: Could you have made a phone call?

MR. JACKSON: So you're the only person that could have gotten those swabs.

MR. JACKSON: So Sergeant Lank could have too.

MR. JACKSON: But you didn't say that.

MR. JACKSON: Okay. What you did do, however, is you went to the neighbor's house. Happened to be Tom Kelleher, right? The lieutenant of detectives.

MR. JACKSON: And Lieutenant Kelleher gave you red solo cups.

MR. JACKSON: The same kind of solo cups that we all see at backyard barbecues.

MR. JACKSON: They're also not sealed.

MR. JACKSON: They're also not normally used for evidence collection.

MR. JACKSON: And then you decided you needed to transport that very important biological material back to Canton PD for storage and safety.

MR. JACKSON: And why was it important to transport that blood material? What are the factors that you considered in terms of getting that material back to Canton PD in good condition, sanitary condition?

MR. JACKSON: What would happen if that material were contaminated?

MR. JACKSON: You tell me. You're a professional.

MR. JACKSON: [unintelligible] —then you would have two sets of DNA when it's tested, which would benefit you.

MR. JACKSON: That's correct. That's correct. While you were — I'm going to stay on this for a second. So obviously there's a reason why blood swabs or biological swabs are handled with such care. For instance, a DNA analyst is going to put on gloves.

MR. JACKSON: Often times they're going to put on a mask.

MR. JACKSON: Often times they put on goggles. Is that right?

MR. JACKSON: Yeah. But in order to go out and collect something, you'll see crime scene investigators in full body suits when you walk into a crime scene.

MR. JACKSON: Because you don't want to contaminate the scene with your own hair off your arm or an eyelash falling into a blood stain.

MR. JACKSON: So there are protocols. I mean, you said just a second ago, Gallagher — well, it's DNA, unless somebody pours bleach in it, you're pretty much golden, right?

MR. JACKSON: No, it's not quite what you said. You were suggesting that it's hardy enough that it doesn't really matter if it's contaminated or not. If there's multiple people's DNA, it just benefits everybody.

MR. JACKSON: Okay. So it can be contaminated with debris. Is that right?

MR. JACKSON: It could be contaminated with other people's DNA. Is that right?

MR. JACKSON: It could be contaminated with foreign items — foreign, either aerosols or somebody's — somebody spilled when you're talking.

MR. JACKSON: With a thousand things hypothetically, right?

MR. JACKSON: These Solo cups didn't have lids on them, right?

MR. JACKSON: They were open.

MR. JACKSON: You didn't photograph where you picked up the samples.

MR. JACKSON: You didn't document where you picked up the samples.

MR. JACKSON: So — how many Solo cups were there?

MR. JACKSON: Six Solo cups. We don't know, as we sit here, where each of those Solo cups' contents came from specifically, do we?

MR. JACKSON: Okay. Then those Solo cups with no lids were placed into a bag, right?

MR. JACKSON: You said on direct examination that this was a brown paper bag, right?

MR. JACKSON: And you said that that Stop and Shop bag — other than having the words "Stop and Shop" on it versus "evidence" on it — is basically one and the same thing: same dimensions, made out of the same materials.

MR. JACKSON: Right. But with an evidence bag, you know exactly where it came from and who's handled it.

MR. JACKSON: Sure. Whose job it is to secure those bags so that they are not mishandled — so they can have some sort of bona fide that they're clean and ready to accept evidence — in, say, for instance, I don't know, the investigation of a homicide of a police officer? Important stuff, right?

MR. JACKSON: I'm talking about evidence bags in general. Evidence bags in general — in other words, I'm trying to think of some of the most important investigations around — the manufacturers of those bags manufacture them and send them in a way so that their bona fide — the provenance of those bags — is maintained.

MR. JACKSON: And protected. That's the way they ship them.

MR. JACKSON: Right. And Canton PD pays extra money for those bags for that very purpose.

MR. JACKSON: You mentioned almost tongue-in-cheek — look, except for the price, they're probably pretty close.

MR. JACKSON: There's a reason that there's a price difference, right? What's the reason?

MR. JACKSON: Yeah. Because I don't really care where it's been or who's handling it, right? It's got my milk and my eggs in it. Really don't care.

MR. JACKSON: Well, you mentioned the price point.

MR. JACKSON: I'm sorry. We're speaking over each other.

MR. JACKSON: I apologize. I'm sorry — you've got to wait for me.

MR. JACKSON: My point is there's a reason, right?

MR. JACKSON: The evidence bags are more expensive because of the way they're manufactured and taken care of, and Canton PD is willing to pay that extra price, like every other law enforcement agency, because of that.

MR. JACKSON: All right. So they're not quite the same, are they?

MR. JACKSON: Those Solo cups were placed in the evidence bag uncovered.

MR. JACKSON: The evidence bag was then placed in Sergeant Lank's vehicle.

MR. JACKSON: Okay. When you say closed, you mean the top of it was rolled up.

MR. JACKSON: Or folded over.

MR. JACKSON: Okay. It wasn't forensically sealed.

MR. JACKSON: There was no evidence tape that went on it.

MR. JACKSON: Matter of fact, the cups were still open and could slosh around.

MR. JACKSON: That's correct. And you indicated that those were — at least you believe those were placed in an evidence locker, a temporary evidence locker, correct?

MR. JACKSON: My mistake. I thought the refrigerator was the temporary storage locker. It's different.

MR. JACKSON: That's correct. That was to maintain the integrity of the sample — the biological sample inside the cups — correct?

MR. JACKSON: You have an evidence log of that?

MR. JACKSON: No. You've never seen an evidence log indicating that those were actually put into a refrigerator?

MR. JACKSON: When did you remove them? On February 1st, right?

MR. JACKSON: I'm just asking — let me ask a foundational question. Does Canton PD maintain something called evidence logs?

MR. JACKSON: Right. And that evidence number is associated with just that piece of evidence.

MR. JACKSON: And every time it's checked out or put back in, there is a log created.

MR. JACKSON: Yes. It's a digital fingerprint, right?

MR. JACKSON: All right. I mean, you're a former narco specialist, right? You did narcotics for years, right?

MR. JACKSON: Drugs — about the most sensitive thing out there, right?

MR. JACKSON: Correct. That is correct. You've never seen an evidence log for these items that were taken from 34 Fairview Road and supposedly put into the —

MR. JACKSON: In two minutes. Two questions — and I'm also —

MR. JACKSON: That's the way it's supposed to work, correct?

MR. JACKSON: But you've never — as you sit here — you've never seen an evidence log documenting where that blood went and who was handling it between January 29th and February 1st.

MR. JACKSON: That's all I had.