📄 Sidebar: Gerry Richards deposition — Friday, December 20, 1996
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▲ Day 35 of 57

Sidebar: Gerry Richards deposition

Date: Friday, December 20, 1996 • Utterances: 21
Defense counsel Dan Leonard objected at sidebar to plaintiffs attempting to introduce the opinions of Gerald Richards, a photographic expert the plaintiffs had retained but never called as a witness. Judge Fujisaki sustained the objection, ruling that the testifying expert could only reference Richards' work if he actually relied on it — not merely reviewed it.
1 MR. LEONARD:

Your Honor, I object, at this point. Ask to approach.

2 THE COURT:

Are we going to spend our time up here?

3 MR. LEONARD:

No, Your Honor, but—

4 THE COURT:

Okay, approach.

5 MR. LEONARD:

Thank you. Very briefly.

6 (The following proceedings were held at the bench with the reporter.)
7 MR. LEONARD:

Your Honor, Gerald Richards is the ex—photographic expert that the plaintiffs retained and did not call in their case.

8 MR. GELBLUM:

So what?

9 MR. LEONARD:

I'm objecting to any publishing of his opinion through this expert. This expert did not rely on his opinion in any way. I think that's improper hearsay.

10 MR. BAKER:

This is their second attempt to get this in.

KEY QUOTE
11 MR. LEONARD:

They tried to do this through Bodziak.

12 THE COURT:

Was his deposition taken?

13 MR. LEONARD:

Yes.

14 THE COURT:

Did their witness take this—read this deposition?

15 MR. LEONARD:

Yes. But he's not relying on his opinion. I think it's improper.

16 THE COURT:

Okay. I'll sustain the objection. Lay foundation that he relied on it. If not, then you can't use it.

17 MR. GELBLUM:

He reviewed it.

18 THE COURT:

I don't care whether he reviewed it or not. If he didn't rely on it, you can't use it. You got it?

KEY QUOTE
19 MR. GELBLUM:

He also opined about Mr. Richards' credentials. Can I ask him about his credentials?

20 THE COURT:

If you don't lay foundation that he relied on it, you can't use it. Period. Okay. Let's get going. Get to the subject matter.

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

Temperature

tense

Key Quotes (3)

Dan Leonard
Gerald Richards is the ex—photographic expert that the plaintiffs retained and did not call in their case.
Establishes the core problem: plaintiffs are trying to backdoor opinions from their own unused expert through a different witness.
Robert Baker
This is their second attempt to get this in.
Signals a pattern of plaintiffs trying to smuggle Richards' opinions into evidence, having already tried through Bodziak.
Hiroshi Fujisaki
I don't care whether he reviewed it or not. If he didn't rely on it, you can't use it. You got it?
Sharp, unambiguous ruling drawing the line between 'reviewed' and 'relied on' — the legal standard for expert witness foundation.

Evidence (1)

Informal
Deposition of Gerald Richards, plaintiffs' photographic expert who was not called at trial
challenged — defense objected to publishing his opinions through current expert witness

Notable Exchanges (1)

Peter GelblumHiroshi Fujisaki
Gelblum tried to salvage something by arguing the witness 'reviewed' Richards' deposition and could speak to his credentials; Fujisaki flatly shut it down, requiring reliance not mere review.
sharp/one-sided

Objections

1 objections (1 sustained, 0 overruled)
Proceeding 8722 • 21 utterances
Civil Trial
Department 103
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📂 DEC 20, 1996 📄 Sidebar: Gerry Richards deposi
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