Direct examination of Daniel Gonzalez

📄 Direct examination of Daniel Gonzalez — Tuesday, December 17, 1996

Address:

C:\DEPT103\CIVIL\1996\DEC\17\DIRECT-EXAMINATION-OF-DANIEL-G.DOC

TRIAL

▲ Day 33 of 57

◀ Redirect examination of Thomas Tallarino (part 3) Sidebar ▶

Witness: Daniel Gonzalez
Examiner: Edward Medvene
Called by: Plaintiff • Date: Tuesday, December 17, 1996 • Utterances: 241

Defense attorney Robert Baker called LAPD Officer Daniel Gonzalez to establish the timeline of dog barking heard by Bundy Drive neighbors on the night of June 12-13, 1994, and to recount his observations at Rockingham including the Akita dog with blood on its paws and witnessing Arnelle Simpson break into tears when told her stepmother had been killed. Much of the examination was consumed by hearsay battles over Gonzalez's door-knock notes and by the witness's resistance to Baker's word choices, particularly 'backup,' 'visualize,' and 'play.'

# 1 MR. BAKER:

Dan Gonzalez.

DANIEL GONZALEZ, called as a witness on behalf of Defendants, was duly sworn and testified as follows:

# 2 THE CLERK:

You do solemnly swear that the testimony you may give in the cause now pending before this court shall be the truth, the whole truth, and nothing but the truth, so help you God?

# 3 DANIEL GONZALEZ:

I do.

# 4 THE BAILIFF:

Please be seated, sir.

# 5 THE CLERK:

And sir if you would, please state and spell your name for the record.

# 6 DANIEL GONZALEZ:

I'm Officer Daniel Gonzalez, last name G-o-n-z-a-l-e-z.

DIRECT EXAMINATION BY MR. BAKER:

# 7 Q:

Officer Gonzalez, you are employed by the Los Angeles Police Department, correct?

# 8 A:

Yes, I am, sir.

# 9 Q:

June 12, 1994, you were called to 875 South Bundy, were you not?

# 10 A:

Yes, I was.

# 11 Q:

And you knocked on doors at 875 South Bundy, did you not?

# 12 A:

Yes, I did.

# 13 Q:

And you talked to various people that lived in the neighborhood, correct?

# 14 A:

Yes, I did, sir.

# 15 Q:

And you were asking them when they heard dogs barking, correct?

# 16 MR. MEDVENE:

Objection. Calls for hearsay, Your Honor.

# 17 THE COURT:

Sustained.

# 18 MR. BAKER:

I was asking what he did, Your Honor.

# 19 Q:

(BY MR. BAKER) When you knocked on doors, you asked people when they heard dogs barking. That's what you did, is it not, sir?

# 20 MR. MEDVENE:

Objection. He's asking for hearsay.

# 21 MR. BAKER:

I'm asking what he --

# 22 THE COURT:

You can answer yes or no.

# 23 DANIEL GONZALEZ:

Answer the question?

# 24 THE COURT:

Yes or no.

# 25 A:

No.

# 26 Q:

(BY MR. BAKER) You filed a report indicating that people heard dogs barking at --

# 27 MR. MEDVENE:

Object, Your Honor. Calling for hearsay.

# 28 Q:

(BY MR. BAKER) You filed this report as a business record of the L.A. Police Department, did you not, sir?

# 29 THE COURT:

Overruled.

# 30 A:

Can you restate that again, about this report.

This isn't technically a report.

# 31 Q:

(BY MR. BAKER) It's what it is, is the addresses you went to and what you found out; isn't that correct?

# 32 A:

Correct. These are notes listing all the addresses that I door-knocked, yes.

# 33 Q:

Tell the jury what sounds people in the neighborhood heard, and at what times.

# 34 A:

Okay.

# 35 MR. MEDVENE:

Objection. Calls for hearsay. The fact that it's a business record doesn't get into hearsay.

# 36 MR. BAKER:

It is an exception to the hearsay rule.

# 37 THE COURT:

The document is an exception.

You want to offer a document, you may offer a document.

You want to offer the document?

# 38 MR. BAKER:

We'll offer the document next in order.

# 39 THE COURT:

Document received.

# 40 THE CLERK:

2275.

# 41 (The instrument herein referred to as A report generated by Officer Daniel Gonzalez was marked for identification as Defendants' Exhibit No. 2275.)

# 42 Q:

(BY MR. BAKER) Now, tell the jury what time people heard noises.

# 43 MR. MEDVENE:

Objection. Calls for hearsay.

# 44 THE COURT:

Sustained.

You may explain the document.

# 45 Q:

(BY MR. BAKER) The document is the document that you took and went and put various addresses upon, indicating what houses you went to, correct?

# 46 A:

That is correct.

# 47 Q:

And you also put what observations you, as a police officer, had heard from the people who actually answered the door, correct?

# 48 A:

That is correct, also.

# 49 Q:

And what was the responses that you got on June 12, 199 -- June 13, actually, 1994?

# 50 MR. MEDVENE:

Objection. Hearsay, Your Honor.

# 51 THE COURT:

Sustained.

You may ask him what he put on the report.

# 52 Q:

(BY MR. BAKER) What did you put on the report in terms of what was heard?

# 53 A:

Okay. Would you like me to list them?

# 54 Q:

No. Just tell me the only ones that -- that have times on them.

There's only two on there, as I recall that have times that there was anything unusual heard; isn't that correct?

# 55 MR. MEDVENE:

Objection. It's hearsay.

# 56 THE COURT:

It's a business record. I've received it as a business record. The witness may be examined as to what those entries say.

# 57 A:

I'm sorry; I'm having a hard time trying to figure out when I'm supposed to answer a question and not answer.

# 58 MR. BAKER:

I can understand that. Believe me; I'm having a hard time myself.

# 59 (Laughter.)

# 60 Q:

(BY MR. BAKER) What time did you put on the report that barking dogs were heard?

# 61 A:

Okay.

On the report, I do list that there were dogs heard barking. And on some of the addresses that I listed, there are times, and on some of them, there are not times.

# 62 Q:

All right.

And when there are times listed, what times did you put on the report?

# 63 A:

Okay.

859 South Bundy --

# 64 Q:

Just the times would be fine.

# 65 A:

Okay.

Well, I have one person who said they heard a dog barking at approximately 12:15 in the morning, at 00:15 hours -- or 00:15.

I have one listing at -- I have to list the address just to point of reference. I can't read the time that I put on here. It looks like 0000 hours, which would make it midnight.

KEY QUOTE

# 66 Q:

Okay.

# 67 A:

But I'm not sure.

And then at another address, I have they heard barking since 2300 hours, which would be 11 p.m.

# 68 Q:

Okay.

Now, after you knocked on doors, did you also play with the Akita dog at the corner of Dorothy and Bundy?

# 69 A:

I think you have to define "play." I'm not quite sure what you mean by "play."

# 70 Q:

Did you pet the dog?

# 71 A:

Yes, I did.

# 72 Q:

Did you make observations that the dog had blood on it?

# 73 A:

Yes, I did.

# 74 Q:

Did you make observations as to the dog had blood on its paws?

# 75 A:

Yes, I did.

# 76 Q:

Did you make observations that the blood was moist?

# 77 A:

I would be speculating if I said that was true.

# 78 Q:

Did you touch the blood and find out whether it was moist?

# 79 A:

Oh, absolutely not. That's not true.

# 80 Q:

And after you left Bundy, you went out on another call, and then were called to Rockingham, were you not?

# 81 A:

Yes, sir.

# 82 Q:

And when you were at Rockingham, you got there at about 5:20 in the morning, didn't you?

# 83 A:

You must be referring to some report I turned in. I don't have a recollection exactly what time. I could -- can tell you it was before daylight.

# 84 Q:

And you were in a black and white, were you not?

# 85 A:

Yes, I was, sir.

# 86 Q:

You and your partner, Officer Astin?

# 87 A:

Yes, Officer Rich Astin.

# 88 Q:

Where did you park your black and white?

# 89 A:

When we first arrived?

# 90 Q:

Yeah.

# 91 A:

When we first arrived, we were parked on Rockingham, which is the north-south street at the bottom of that picture that you're showing. And we were basically parked next to a white Bronco.

# 92 Q:

You were there while there were four detectives also there, correct?

# 93 A:

That is correct, sir.

# 94 Q:

You were called to the scene as a black-and-white to back up four detectives that were there; and you were called to that scene at about 05:20 in the morning; isn't that correct?

# 95 MR. MEDVENE:

Objection. Using the word "backup" assumes facts not in evidence. It's also leading.

# 96 MR. BAKER:

I intend to be leading this witness.

# 97 THE COURT:

Overruled.

# 98 A:

Okay.

I also have a problem with the term "backup." That can mean a number of different things. To me, it means something much more serious than I think you're trying to imply.

# 99 Q:

You were told on your car radio to go to 360 North Rockingham before 5:20 in the morning, were you not, sir?

# 100 A:

No, sir; that is not true.

# 101 Q:

You just happened to wander by and there were four detectives there?

# 102 A:

No.

I can explain if you'd like to hear how I got up there. I can explain it to you. It's very simple.

# 103 Q:

Were you told to go to that location?

# 104 (Exhibit board No. 1174 is displayed.)

# 105 A:

Yes, I was told to go to that location.

# 106 Q:

And in terms of being told to go to that location, you remained outside, originally, outside the perimeter of 360 North Rockingham, did you not?

# 107 A:

Originally, upon our arrival, yes, we did.

# 108 Q:

And you filed a report, in your own handwriting, within a couple of weeks after this event occurred, did you not?

# 109 A:

That is correct.

# 110 Q:

And you were standing at the Rockingham gate at approximately 5:30, 6 o'clock, somewhere in there, when you saw Arnelle Simpson, a black female, come around the north end of the pool with detectives; isn't that true, sir?

# 111 A:

Okay. Once again, you have a big question in front of me. I'm trying to figure out what you're trying to say.

# 112 Q:

I'm trying to ask you whether or not you observed a black female in the company of Fuhrman and Phillips, walk on the north side -- around the north side of the pool in they're company.

Did you see that?

# 113 A:

Yes, I saw that.

What I have problem with is, you keep referring to locations that I was at, that I was not at. And like I said, I can -- I can explain it if you wanted me to explain.

# 114 Q:

All right. I first want to get into the issue of the fact that you saw and you were later -- were you later able to identify the black female on the morning of June 13, 1994 as Arnelle Simpson?

# 115 A:

Well yes, I was. I spoke to her that morning.

# 116 Q:

And when she came around in the company of the detectives, you were also able to hear what was being said between the detectives and Arnelle Simpson, were you not?

# 117 A:

Yes, sir, I did.

# 118 Q:

And you were able to hear the detectives discuss whether she knew where her father was; isn't that true?

# 119 A:

That is correct.

# 120 Q:

And you were also able to hear her respond that, in fact, she didn't know where her father was, and must be gone, because the Bronco's gone, correct?

# 121 A:

Correct. I believe she might have even made a statement to me regarding such.

# 122 Q:

Then the officers walked her out and showed her the one Bronco over by where your car was parked over on Rockingham, didn't they? The detectives, rather?

# 123 A:

Once again, I have a problem with location.

At that point, my black-and-white was not at that location where the Bronco was.

# 124 Q:

All right. You moved it by then?

# 125 A:

We had moved it by then. We moved it several times when we were there.

# 126 Q:

In any event --

# 127 A:

Okay.

# 128 Q:

-- you heard her being asked about the whereabouts of her father, O.J. Simpson, did you not?

# 129 A:

Yes, sir; that is correct.

# 130 Q:

You also heard her, or watched her being led over to the area where Rockingham and the Bronco was, correct?

# 131 A:

Yes. I'm trying -- I want to apologize for the brief moment of silence. I'm trying to remember if she was being led.

And, yes, you are correct; she was being led to that location.

# 132 Q:

And after she was, the detectives -- and this included Fuhrman and Phillips, didn't it?

# 133 A:

If you read through my report again, which I haven't done too much in great detail, I don't believe I exactly recall which detectives were there. I might be mistaken, but right now, I don't have a recollection which detectives were actually interviewing her.

# 134 Q:

The detectives came with her around the north side of the house, though, did they not?

# 135 A:

Correct. Whichever detectives had previously stated they were the ones talking to her, those are the ones I saw.

# 136 Q:

They came around the pool area and around the north area of the house, and were asking her the whereabouts of her father, and then came around the driveway?

# 137 A:

That is correct, yes.

# 138 Q:

And you were able to visualize this, and not only visualize it, you were able to hear what was being said among those people, were you not?

# 139 A:

"Visualize" as -- you mean see?

# 140 Q:

See them.

# 141 A:

Okay.

# 142 Q:

And hear them?

# 143 A:

I saw them; I heard them. Very simple.

# 144 Q:

All right. all right.

And after they pointed out the vehicle on Rockingham, they were walking back towards the front of Mr. Simpson's residence, and you heard Ron Phillips tell Arnelle Simpson that her stepmother had been killed, isn't that true? And you watched her break into tears?

# 145 A:

I watched her break into tears. I don't remember which detective told her. So if you say it's Ron Phillips, and you're saying that's been stipulated and that's true, then that must be true.

I can only tell you I saw a detective talking to her. It appeared to me he explained that there -- that her stepmother had been killed, and she burst into tears.

KEY QUOTE

# 146 Q:

And this was not anywhere inside the house; this was out on the driveway, wasn't it?

# 147 A:

Correct.

# 148 Q:

And then they went into the front door of the house, didn't they, the detectives and Arnelle Simpson?

# 149 A:

I'd have to look at my report to remember that. I don't know right now. I don't remember which door they went into.

They did go back in the house; I know that's a fact, at some time.

# 150 Q:

You say back in the house?

# 151 A:

Or back -- excuse me -- into the house the first time, I believe.

# 152 Q:

They had -- you had never seen them in the house when you first observed them come around the north side and come out the pathway; isn't that correct?

# 153 A:

That's correct. I saw her emerge from her -- I guess you call it a bungalow in the back.

# 154 Q:

So you never saw --

# 155 MR. BAKER:

Can we get the other --

THE COURT REPORTER: Excuse me. What number is this one?

# 156 MR. BAKER:

It is -- hold on one second, Gina.

# 157 MR. LEONARD:

Want the other diagram.

# 158 MR. BAKER:

Yeah, the diagramatic --

MR. P. BAKER: It's 1174.

# 159 (Exhibit 116 is displayed.)

# 160 Q:

(BY MR. BAKER) Now, did -- when you arrived there at approximately 5:20, there were already two unmarked police cars there, correct?

# 161 A:

Possibly. I don't know. That's not what I saw when I arrived. I just saw Westec there when I arrived.

# 162 Q:

All right.

Well, you obviously observed the detectives subsequently, correct?

# 163 A:

Right. There were four detectives there. I only remember seeing one police car or one unmarked car.

# 164 Q:

Okay.

And -- and you observed the detectives walk Arnelle out of her room, around the north side of the property, and onto the driveway?

# 165 A:

That is correct.

# 166 Q:

And they did not go from Arnelle's room, up the stairs and into the back of Mr. Simpson's house, did they?

# 167 A:

That's what I believe I saw. I don't believe I saw them walk through the house. They had emerged from the pool area and walked around.

# 168 Q:

And you were clear -- clear in your report -- and you gave -- by the way, you gave two reports, did you not?

# 169 A:

Kind of, I guess. I don't know what you're referring to.

# 170 Q:

You have a statement form that's in your handwriting?

# 171 A:

Correct.

# 172 Q:

And then you subsequently gave another report to Detective Phillips, did you not?

# 173 A:

Is that the impound report you're talking about?

# 174 Q:

No, sir, it is not.

# 175 A:

Okay.

# 176 Q:

Let me show it to you.

# 177 A:

Please.

# 178 Q:

And see if this refreshes your recollection.

# 179 A:

Okay.

# 180 Q:

Now, this two-page handwritten report is all in your handwriting, is it not?

# 181 A:

Correct. That is my handwriting.

# 182 Q:

And that was your recollection a couple of weeks post-incident; that is, you wrote that within a couple of weeks of June 13, 1994, correct?

# 183 A:

Correct.

# 184 Q:

And you then -- well, strike that.

Why didn't you date it?

# 185 A:

I should have dated this.

# 186 Q:

I agree.

Why didn't you?

# 187 A:

I don't know. I would -- I would imagine there would have been a date someplace on this. You're correct.

# 188 Q:

There's -- there is a space for the date, is there not?

# 189 A:

Well, this was -- this statement form is usually used for suspects, when we're interviewing them, and we want to take statements.

# 190 Q:

Maybe you didn't understand the question.

# 191 A:

Okay.

# 192 Q:

There is a space for the date and the time of the interview, is there not?

# 193 A:

Correct.

Although this wasn't an interview, but that is correct.

# 194 Q:

And there was nothing that precluded you from dating the form, true?

# 195 A:

No.

# 196 Q:

Now, in that particular statement, you document your observations relative to the detectives relating to Arnelle Simpson. Number one, the inquiry concerning the whereabouts of her father; and number 2, the issue of telling her that her stepmother had been in a homicide, correct?

Those are your words?

# 197 A:

That's what I believe I saw, yes.

# 198 Q:

And -- and you certainly visualized Arnelle break down in front of you, didn't you?

# 199 A:

Yes, she was definitely crying.

# 200 Q:

And with that, the police officers detectives, whatever, took her into the front of the house?

# 201 A:

If you can hold on just a moment.

# 202 Q:

Sure.

# 203 MR. MEDVENE:

Objection. Asked and answered, Your Honor.

# 204 THE COURT:

Mr. Baker, you've got around six minutes. You did this twice. I don't want to hear this again.

# 205 DANIEL GONZALEZ:

Okay.

You're asking me if I saw him enter the front of house.

On this report, all I had stated is that they entered the house, like I said before, what, five, ten minutes ago, I don't remember which door they entered in. So they could have entered at any door. I just know they went inside the house.

# 206 Q:

(BY MR. BAKER) You did not see them go back around the house, did you, sir?

# 207 A:

They may have gone back around.

# 208 Q:

Maybe you didn't understand that question correctly.

# 209 MR. MEDVENE:

If the Court --

# 210 Q:

(BY MR. BAKER) You didn't see them go back around the house?

# 211 MR. MEDVENE:

Excuse me, Mr. Baker. The witness was answering the question.

# 212 THE COURT:

Not very well.

# 213 DANIEL GONZALEZ:

Okay. I'll try harder.

# 214 Q:

(BY MR. BAKER) You didn't visualize with your own eyes and go anywhere into the house; isn't that correct, sir?

You didn't see him walk around the driveway in front of the house over to the north side and walk around after Nicole's -- after -- strike that -- after Arnelle broke down in tears, did you?

# 215 A:

I see.

I would be speculating saying "notice." If I put down they entered the house, then -- I wouldn't say they entered the house; I would say they walked back to the pool area and never saw them.

As you saw, it's pretty detailed. I'm not going to say they walked through the front of the house. They may have walked through the front of house. You ask them.

Maybe she said they did. I personally don't know. I just said they entered the house. If they got in through the back, that's -- they could have entered either door.

For me to say they only entered through the front door, only through the back door, now I'd only be -- I'd be speculating.

They obviously went inside the house. I may have seen them go back -- to the back.

I don't have a visualization.

Those are your words.

# 216 Q:

Got ya.

# 217 A:

Thank you very much.

# 218 Q:

So your total recollection is, after she broke down, you don't have a recollection, except them entering the house, correct?

# 219 A:

In how -- if I put in that report they entered that house, I watched them enter the house.

# 220 Q:

And you --

# 221 A:

And they -- location. They entered either through the front door or the back door. I don't know which one now. If they entered someplace weird like a window, I would obviously remember that. I'm not trying to be sarcastic.

# 222 Q:

They didn't fly up through the garage?

# 223 A:

Correct. I don't know which door they entered into.

# 224 Q:

Where were you when you visualized this?

# 225 A:

Okay.

# 226 Q:

Where were you standing when you saw it?

# 227 A:

Can you define "visualize"? I'm really -- I'm not trying to make a joke of this, but I saw this, and I'm really having a hard time with that.

# 228 Q:

Fine; let's use your word.

# 229 A:

Thank you.

# 230 Q:

Mine's not working.

# 231 A:

I'm having a hard time with that one.

# 232 Q:

In --

# 233 A:

You want to know where I was when I saw this?

# 234 Q:

Just --

# 235 A:

I'm sorry.

# 236 Q:

We're going to start all over.

# 237 A:

All right.

# 238 Q:

I know.

Now, Arnelle had come down the driveway and they had pointed out the Bronco?

# 239 A:

Okay. Not really like that.

# 240 Q:

She was in it, the driveway. You testified a few moments ago she was in the driveway; they pointed the Bronco out and she said, yes, that's my father's Bronco, or words to that effect, right?

# 241 A:

But the way you're pointing through the gate, it's as if they exited the gate onto that driveway on Rockingham.

They never exited the gate. They simply walked to the gate, which at the time you could see through, and they pointed, there's the Bronco, and said something to the effect, well, yeah, she didn't know what the heck it was doing there, but it was there.

I'm sorry.

Temperature

procedural

Key Quotes (4)

DANIEL GONZALEZ

I have one person who said they heard a dog barking at approximately 12:15 in the morning, at 00:15 hours... I have one listing... it looks like 0000 hours, which would make it midnight... And then at another address, I have they heard barking since 2300 hours, which would be 11 p.m.

Establishes the timeline of the Akita's barking, which was used by the defense to fix the time of the murders.

DANIEL GONZALEZ

I watched her break into tears. I don't remember which detective told her. So if you say it's Ron Phillips, and you're saying that's been stipulated and that's true, then that must be true. I can only tell you I saw a detective talking to her. It appeared to me he explained that there -- that her stepmother had been killed, and she burst into tears.

Eyewitness account of Arnelle Simpson's reaction to learning of Nicole's death, establishing the sequence of events at Rockingham and the detectives' actions before entering the house.

DANIEL GONZALEZ

I'm not trying to say they only entered through the front door, only through the back door, now I'd only be -- I'd be speculating. They obviously went inside the house. I may have seen them go back -- to the back. I don't have a visualization. Those are your words.

The witness turns Baker's own vocabulary back on him while illustrating the limits of his recollection about the detectives' movements inside Rockingham — relevant to the defense theory about unauthorized entry.

ROBERT BAKER

I'm having a hard time myself.

Rare moment of candor from Baker acknowledging the procedural chaos around hearsay rulings, which drew laughter from the courtroom.

Evidence (6)

Defendants' 2275

Officer Gonzalez's handwritten notes listing addresses he door-knocked on June 13, 1994, with entries about times dogs were heard barking

introduced and received over hearsay objection as business record

1174

Exhibit board / diagram of the Rockingham property

displayed during testimony about Arnelle Simpson's movements

116

Diagrammatic exhibit of Rockingham property

displayed as alternative diagram during testimony

Informal

Two-page handwritten statement form (written within weeks of June 13, 1994) documenting Gonzalez's observations at Rockingham, including Arnelle Simpson's interaction with detectives

shown to witness to refresh recollection; undated

Informal

Akita dog at the corner of Dorothy and Bundy with blood on its paws

described by witness; Gonzalez petted the dog but denied testing whether the blood was moist

Informal

White Ford Bronco parked on Rockingham

referenced — Gonzalez parked his black-and-white next to it on arrival; detectives showed it to Arnelle

Notable Exchanges (4)

Robert Baker•DANIEL GONZALEZ

Extended back-and-forth over whether Gonzalez could say detectives 'backed up' — witness objected to the term as implying something more serious than Baker intended, leading Baker to rephrase around the radio dispatch.

strategic

Robert Baker•DANIEL GONZALEZ

Baker repeatedly used the word 'visualize' and the witness persistently pushed back, asking Baker to define it, ultimately saying 'Can you define visualize? I'm really — I'm not trying to make a joke of this' before Baker conceded to use 'see' instead.

light/combative

Robert Baker•Edward Medvene•Hiroshi Fujisaki

Prolonged hearsay battle over whether Gonzalez's door-knock notes could come in as a business record and whether the witness could orally relay the contents. Fujisaki ultimately received the exhibit but repeatedly constrained Baker to asking 'what he put on the report' rather than what people told him.

procedural

Hiroshi Fujisaki•DANIEL GONZALEZ

After the witness complained he couldn't tell when to answer, the judge told him 'yes or no' — and the witness answered 'no' to Baker's question about asking neighbors when they heard dogs barking, forcing Baker to reframe entirely.

revealing

Light Moments (3)

Robert Baker

After the witness complained he was having trouble figuring out when to answer, Baker said 'I can understand that. Believe me; I'm having a hard time myself.' The courtroom laughed.

Robert Baker

Baker asked 'They didn't fly up through the garage?' after Gonzalez exhaustively hedged about which door Arnelle and the detectives used to enter the house.

DANIEL GONZALEZ

When asked whether he 'played with' the Akita dog, Gonzalez replied 'I think you have to define play. I'm not quite sure what you mean by play.'

Credibility Attacks (1)

⚔ DANIEL GONZALEZ

omission / document quality

Baker noted that Gonzalez's handwritten statement was undated despite having a space for a date and time, suggesting sloppiness or deliberate omission in documentation.

Witness Demeanor

(Laughter.) — after Baker's 'I'm having a hard time myself' remark

Witness repeatedly hedges and asks Baker to restate or define words ('visualize,' 'play,' 'backup')

Witness volunteers to explain context multiple times, saying 'I can explain it if you'd like to hear'

Witness ends a long rambling answer by saying 'Those are your words' — turning Baker's vocabulary back on him

Objections

9 objections (3 sustained, 4 overruled)

Proceeding 8697 • 241 utterances • Plaintiff witness

Civil Trial

Department 103