📄 Sidebar: scope of examination — Monday, December 16, 1996
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C:\DEPT103\CIVIL\1996\DEC\16\SIDEBAR-SCOPE-OF-EXAMINATION.DOC
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▲ Day 32 of 57

Sidebar: scope of examination

Date: Monday, December 16, 1996 • Utterances: 23
Plaintiffs' counsel objected mid-examination to Baker leading witness MacDonell toward blood-stain interpretation at the crime scene, arguing a stipulation froze MacDonell's testimony to what he gave at the criminal trial. Baker countered that he needed to rebut Spitz's testimony about the 1-minute-15-second timeline. Fujisaki sustained the objection pending production of the stipulation, and allowed Baker to proceed only on coagulation testimony if MacDonell had covered it at the criminal trial.
1 MR. MEDVENE:

Objection.

May we approach the bench, Your Honor?

2 THE COURT:

All right.

3 (The following proceedings were held at the bench, with the reporter.)
4 MR. MEDVENE:

If the Court please, this witness -- this witness's deposition was not taken pursuant to a stipulation between the parties, that his testimony would be frozen as the testimony he gave in the criminal trial. At the criminal trial, he testified about something he saw on the inside of the sock.

Mr. Baker appears to be leading him up, now, to blood-stain interpretation at the crime scene, and it wasn't the testimony at the criminal trial. He was frozen. We weren't allowed to take his deposition. And our understanding is, his testimony is to be limited. That's what it was with all the other witnesses.

5 MR. BAKER:

First of all, they were totally allowed to take anybody's deposition they wanted to. That was never stipulated.

6 THE COURT:

Can I have the stipulation?

7 MR. BAKER:

Second -- second of all, Your Honor they put on -- they put on Spitz to testify as to the time of the crime of a minute and 15 seconds. I have to be able to rebut that testimony, that both crimes took a minute and 15 seconds and that can be done in those small measures through the interpretation of blood stains. And I have to have leeway after they put on their evidence to rebut that evidence.

8 MR. MEDVENE:

If the Court please, there's nothing --

9 THE COURT:

Excuse me. I want to see the stipulation.

10 MR. PETROCELLI:

It's at the -- Your Honor, I will represent that it recites, and it's in the court file, that the parties stipulate that if they designate a particular person to be frozen, then that person's testimony at trial cannot go beyond anything given at the criminal trial, in return for the other side not taking that person's deposition.

And that's all set out in the stipulation.

And, for example, they asserted that against us in regard to Bruce Weir, we were not allowed to expand his testimony pursuant to that stipulation.

Mr. MacDonell is one of the enumerating deponents on the list of the defense witnesses whose testimony is frozen.

It would take me ten to 15 minutes for me to get it for you. I have to go back to the hotel across the street and get it. He's clearly on the list. That is clearly what's been said; there's never been a dispute about that.

11 MR. MEDVENE:

This is really out of blue, Your Honor, totally, because everything up to now was going to be limited to his area.

12 MR. BAKER:

All I can say, Your Honor, is that when they put on testimony, we have to be able to rebut that testimony. And all of the experts that we're calling are the experts that were called in the criminal trial. So I've got to be able to -- where Spitz was not -- did not testify in the criminal trial -- I've got to be able to rebut his testimony.

13 MR. MEDVENE:

If the Court please, Dr. Spitz's testimony was taken. He offered the opinion. He offered it at trial. And they cross-examined him on that on the length of time his deposition was offered. They cannot do this. This is not what the agreement was.

14 MR. PETROCELLI:

I'd like to go get the stipulation.

15 THE COURT:

All right. I'll sustain the objection pending production of the stipulation. If you don't show me the stipulation, I'll set it aside.

KEY QUOTE
16 MR. PETROCELLI:

Absolutely.

17 MR. BAKER:

Your Honor, he did testify on coagulation times during the trial, so I want to go into coagulation.

18 MR. MEDVENE:

Wait. Wait. What do you mean, coagulation times?

19 MR. BAKER:

Basically, how long it takes blood to coagulate.

20 THE COURT:

If he testified to that at trial, he may testify to that.

21 MR. MEDVENE:

I'd like to see the page you're talking about.

No. Excuse me.

Look, I'm trying to play by the same rules that they're supposed to play by. If there's coagulation testimony, just show me what it is. I'm not arguing about it.

22 THE COURT:

Show him the coagulation testimony.

23 (The following proceedings were held in open court, in the presence of the jury.)

Temperature

tense

Key Quotes (4)

Daniel Petrocelli
the parties stipulate that if they designate a particular person to be frozen, then that person's testimony at trial cannot go beyond anything given at the criminal trial, in return for the other side not taking that person's deposition.
Clearest articulation of the stipulation's terms, which governed scope of all frozen witnesses including MacDonell
Robert Baker
they put on Spitz to testify as to the time of the crime of a minute and 15 seconds. I have to be able to rebut that testimony, that both crimes took a minute and 15 seconds and that can be done in those small measures through the interpretation of blood stains.
Baker's strategic justification for expanding MacDonell's testimony — linking blood-stain interpretation to rebutting Spitz's timeline
Hiroshi Fujisaki
I'll sustain the objection pending production of the stipulation. If you don't show me the stipulation, I'll set it aside.
Fujisaki's conditional ruling — he enforces the stipulation but gives Baker an out if Petrocelli can't produce the document
Edward Medvene
Look, I'm trying to play by the same rules that they're supposed to play by. If there's coagulation testimony, just show me what it is. I'm not arguing about it.
Medvene signals good faith while holding firm — narrows the dispute to a concrete factual question about what MacDonell actually said at the criminal trial

Evidence (2)

Informal
Stipulation between parties freezing designated witnesses' testimony to their criminal trial testimony in exchange for waiving depositions
disputed, referenced, Petrocelli offers to retrieve from hotel
Informal
MacDonell's criminal trial testimony on coagulation times
Baker invokes to justify limited expansion; Fujisaki orders it shown to Medvene

Notable Exchanges (2)

Robert BakerDaniel PetrocelliEdward Medvene
Three-way argument over whether the frozen-witness stipulation bars Baker from using MacDonell to rebut Spitz's timeline testimony, given Spitz did not testify at the criminal trial
strategic
Robert BakerEdward Medvene
After Fujisaki limits scope, Baker pivots to coagulation testimony; Medvene immediately demands to see the specific criminal-trial pages rather than take Baker's word for it
cautious, adversarial

Objections

1 objections (1 sustained, 0 overruled)
Proceeding 8649 • 23 utterances
Civil Trial
Department 103
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📂 DEC 16, 1996 📄 Sidebar: scope of examination
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