DIRECT EXAMINATION
                    BY MR. PETERS: 
                            Q.   Dr. White, have you ever used in your past 
                    experience a polygraph exam as a tool for investigative 
                    purposes? 
                            A.   Yes, I have, on prior occasions. 
                            Q.   To your knowledge, have any of your 
                    associates in the psychiatric profession ever used 
                    polygraph examinations for investigative purposes? 
                                 MS. MARTIN:  Objection, your Honor, to what 
                    his associates may or may not have used for investigative 
                    purposes. 
                                 THE COURT:  No, I will allow that question.  
                    Overruled. 
                            A.   Yes, they have. 
                            Q.   Doctor, how are these polygraph examinations 
                    used? 
                            A.   Well, I have used mine primarily when an 
                    individual was denying certain things.  When I felt or 
                    knew certain things to be true, in order to get them to 
                    begin working on certain problems, I used it.  Sex cases, 
                    rape cases, or incest cases are a difficult thing to 
                    admit.  If I could get them to admit to me the act, we 
                    could then begin some kind of rehabilitation program, 
                    treatment or therapy.  A polygraph test is very difficult 
                    to fool. 
                            Q.   Would you attempt to reevaluate your own 
                    diagnosis as to the problem, if a person was successful in 
                    passing the polygraph exam?
                            A.   Yes, I would. 
                            Q.   If you elicit a test result from the 
                    polygraph that is inconsistent with every other sign that 
                    a person is lying, would you consider the result of that 
                    test valid in every way?
                            A.   Probably not.  If everything I had available, 
                    the psychiatric examination and all the other materials, 
                    made me think one thing, but then the polygraph made me 
                    think another, I would probably go more with the clinical 
                    opinion.  The clinical impression would be more valid to 
                    me than the polygraph. 
                                 THE COURT:  Have you ever used the technique 
                    of hypnosis in your evaluations? 
                                 THE WITNESS:  Sometimes, yes. 
                                 THE COURT:  Have you ever used the technique 
                    of sodium pentothal? 
                                 THE WITNESS:  Sodium amytal, I have used it 
                    on several occasions. 
                                 THE COURT:  When is a polygraph exam 
                    recommended and the other techniques not?
                            A.   Well, hypnosis and sodium amytal are not 
                    really used to determine truth.  Hypnosis is useless as 
                    far as that is concerned.  It is used to recall or help a 
                    person find lost or suppressed memories, such as periods 
                    of amnesia and blackout.  Perhaps some of the data which 
                    it produces is true. 
                    BY MR. PETERS: 
                            Q.   You indicated that there are two basic types 
                    of amnesia.  There is one which is caused by a 
                    psychological trauma.  The other type of amnesia is caused 
                    by a physical trauma, is that correct?
                            A.   Well, there are more than just those two. 
                            Q.   Would a polygraph exam be particularly useful 
                    in a situation where you are trying to verify a case of 
                    amnesia due to physiological trauma? 
                            A.   It could be useful to verify whether the 
                    amnesia was genuine, malingered or faked. 
                                 THE COURT:  What other methods can be used to 
                    determine whether or not a person is faking amnesia? 
                                 THE WITNESS:  Well, they can also be 
                    hypnotized.  They could also be given drugs.  Sodium 
                    amytal or other stimulants are useful, but again, that, 
                    too, can be faked.  An individual under the influence of 
                    most drugs can still say "I don't recall" when they really 
                    do.  Or they can make up some other falsehood, so the 
                    results of a hypnosis situation or a sodium amytal 
                    situation are really no more valid than what the 
                    individual has said at any other time. 
                            Q.   Do you take at face value what a person says 
                    to you? 
                            A.   No, not as a general rule.  In legal cases, I 
                    am skeptical to begin with.  I approach each case 
                    differently and with a certain amount of caution. 
                            Q.   Do you look for particular signs as to the 
                    way in which a person presents his story to you, the way 
                    he is telling it to you? 
                            A.   Yes. 
                            Q.   What do you look for? 
                            A.   Basically, I look for eye contact and body 
                    language.  They have certain signs, such as frequent dry 
                    mouth, licking of the lips.  Frequent restlessness and 
                    moving in the chair can be signs that they are not telling 
                    you the truth.
                                 You can't look at somebody and find out their 
                    pulse or blood pressure, that is basically what a 
                    polygraph measures.  An accurate reading takes into 
                    account the variations in pulse, blood pressure and 
                    respiration rate.  Another indicator is that you also 
                    sweat more when you are telling a lie. 
                            Q.   So to assess credibility, polygraph exams can 
                    be used by psychiatrists? 
                            A.   I use them and the forensic psychiatrists use 
                    them.
                            Q.   On page 32 and 33 of the notes which you 
                    supplied to the District Attorney, you already recorded 
                    your diagnosis of Mr. Masters, is that correct? 
                            A.   Yes, on page 32 of my initial interview on 
                    April 14th I recorded my notes.  At the time of the 
                    interview, at the conclusion of it, I wrote down my 
                    opinion as to what his mental condition was at the time of 
                    the offense.
                            Q.   And what was that? 
                            A.   I wrote, "Compression amnesia, genuine and 
                    probably unconscious."  This was prior to any polygraph 
                    tests having been conducted.