Attorneys for Adan Canela and Policarpio Espinoza are seeking a new trial for the pair on the grounds the trial transcripts indicate there were only a dozen such notes when there actually were 31.
"Appellate lawyers are sometimes asked to supplement or correct the record over something like leaving out one day of the transcript, but I've never had a hearing like this," Brian Murphy, Canela's appellate lawyer, said.
Canela and Espinoza were sentenced to life in prison in 2006 after a two-month trial for the murders of three young relatives.
The Baltimore Sun said Wednesday Murphy cross-examined the court clerk and two prosecutors Tuesday and will put the defendants' trial lawyers on the stand Wednesday.
On Tuesday, Baltimore prosecutor Sharon Holback testified some of the notes were handled off the record in the judge's chambers or outside the presence of courtroom cameras.