📄 Cross-examination of Dale St. John — Wednesday, December 4, 1996
Address:
C:\DEPT103\CIVIL\1996\DEC\4\CROSS-EXAMINATION-OF-DALE-ST-J.DOC
TRIAL
▲ Day 25 of 57

Cross-examination of Dale St. John

Witness: Dale St. John
Examiner: Daniel Petrocelli
Called by: Defense • Date: Wednesday, December 4, 1996 • Utterances: 65
Defense attorney Leonard cross-examined limousine driver Dale St. John about OJ Simpson's typical behavior when being picked up for trips — establishing that Simpson was habitually rushed and chaotic, with housekeepers usually handling his bags. Leonard also briefly probed St. John's knowledge of Simpson's dogs and neighbor complaints, which was shut down by sustained objections.
1 THE COURT:

Cross.

CROSS-EXAMINATION BY MR. LEONARD:

2 Q:

Good afternoon.

3 A:

Good afternoon.

4 Q:

Let's talk a little bit about Mr. Simpson's habit when you would pick him up, what he would normally do and how he would normally act.

It's true, isn't it, that often when you would pick Mr. Simpson up, things were a little chaotic, he'd be hurrying around, picking up things?

5 A:

That's true.

6 Q:

Right.

It wasn't uncommon for him to come in and out of the house, grab an item, come out, grab something else, put it in the car, so forth and so on; he was rushing, right?

7 A:

He was rushing. He usually didn't put stuff in the bags.

8 Q:

Excuse me?

9 A:

He didn't -- he didn't usually fill -- usually Michele would put something in the bag. I don't recall O.J. putting -- coming out with like a couple of shirts and putting them in a bag. Rarely.

KEY QUOTE
10 Q:

Now, you said you've picked him up something like 100 times --

11 A:

That's correct.

12 Q:

-- is that right?

Is it fair to say that the vast majority of the times that you picked him up, Michele was there or Gigi, one of the housekeepers?

13 A:

Yes.

14 Q:

What you're saying is that, typically, if the housekeeper's there. They might be taking care of putting any last-minute items in Mr. Simpson's bag, as opposed to Mr. Simpson, correct?

15 A:

That's correct.

16 Q:

Okay.

But he was the kind of guy -- as a limousine driver he might make you a little bit nervous about getting someplace on time; is that fair to say?

In other words, he wouldn't always give you enough -- as much time as you'd like to get to where you're supposed to go; is that fair to say? Cut it close?

17 A:

Yeah.

18 Q:

Okay.

In fact, about a week before June 12 you had picked him up -- you picked him up and you were taking him on a trip out to LAX, had about 45 minutes to make the flight.

Do you remember that?

19 A:

Yes.

20 Q:

That was kind of rushed, wasn't it?

21 A:

Not really.

22 Q:

Do you remember on that occasion that you -- and occasions prior to that, having the feeling about Mr. Simpson as a passenger. That you were really cutting it close?

23 A:

He -- I think he felt that way, that he was cutting it real close, because when he'd get in the car he'd say, we gotta go, we got a go.

KEY QUOTE
24 Q:

Okay.

25 A:

But in actuality we would make the airport with usually plenty of time.

26 Q:

The bottom line is there was a lot of rushing around?

27 A:

Yeah, there was.

28 Q:

Okay.

Let me see if I can understand some of the things you were saying.

You would -- you would buzz, and I guess in the vast majority of times when you buzz, Michele or even one of Mr. Simpson's adult children, Arnelle or Jason, might come out and open the gate, right, vast majority?

29 A:

Come out and open the gate?

30 Q:

Or buzz the gate open, right?

31 A:

Yes. Nobody --

32 Q:

In other words, you would -- go ahead.

33 A:

I don't recall someone actually coming out and opening the gate, except for a time when Michele came out, when I think the gate was not working properly.

34 Q:

Okay.

But the vast majority of the hundred times that you went out to pick up Mr. Simpson and you buzzed you would be talking to Michele, right?

35 A:

Yes.

36 Q:

Or one of the other housekeepers, right?

37 A:

Yeah.

38 Q:

Gigi after her?

39 A:

Yeah.

40 Q:

And when -- on occasion, when you would buzz and Mr. Simpson responded, he wouldn't always respond -- you're not saying before this jury that he would respond on the first buzz on every occasion, are you?

41 A:

He didn't respond necessarily on the first buzz, but he responded on the first attempt to buzz him. In other words, I would ring it once and I'd wait maybe 10 seconds. Then I would buzz it again, maybe wait 10 more seconds, and buzz it a third time, and by that third time I always had a response from somebody.

KEY QUOTE
42 Q:

Now -- okay.

From somebody. That might be Michele or someone else that's in the house, right?

43 A:

Right.

44 Q:

Okay.

By the way, you obviously didn't pick Mr. Simpson up on the 12th, that was a fellow that was working for you; is that right?

45 A:

That's correct.

46 Q:

You have no idea what Mr. Simpson was doing when he was buzzed that night, you don't know whether he was in the shower or what --

47 A:

No.

48 Q:

-- correct?

All right.

Now, let's talk about the dog.

You have no idea -- and I guess Mr. Simpson never discussed this with you -- you have no idea of any complaints that Mr. Simpson got from his neighbors to the ASPCA with regard to his dogs wandering the neighborhood?

49 MR. PETROCELLI:

Arguing. No foundation.

50 A:

No.

51 THE COURT:

This --

52 Q:

(BY MR. LEONARD) And there was -- there was -- are you aware that there was another dog that would be at the Rockford (sic) location from time to time, are you aware of that?

53 A:

No.

54 MR. PETROCELLI:

Rockingham.

55 Q:

Excuse me. Rockingham.

56 A:

Yes.

57 Q:

Now, you say that you never had any discussion with Mr. Simpson about the dogs.

Were you ever there when the other dog was at the location?

58 A:

Yes.

59 Q:

Of the hundred times you were there, how often were you there that the dog was there?

I guess that didn't make --

60 MR. PETROCELLI:

I'm going to object. The undisputed evidence is there was only one dog there, Chachi, that night.

61 THE COURT:

Sustained.

62 MR. PETROCELLI:

No other dogs involved.

63 MR. LEONARD:

This goes to Mr. Simpson's state of mind.

64 MR. PETROCELLI:

There was no other dog there.

65 THE COURT:

Sustained.

Temperature

procedural

Key Quotes (3)

Witness
He didn't respond necessarily on the first buzz, but he responded on the first attempt to buzz him. In other words, I would ring it once and I'd wait maybe 10 seconds. Then I would buzz it again, maybe wait 10 more seconds, and buzz it a third time, and by that third time I always had a response from somebody.
Undercuts the narrative that Simpson's delayed response to the limo buzzer on June 12 was unusual or suspicious.
Witness
He -- I think he felt that way, that he was cutting it real close, because when he'd get in the car he'd say, we gotta go, we gotta go. But in actuality we would make the airport with usually plenty of time.
Establishes Simpson's rushed demeanor as a consistent pattern, normalizing chaotic behavior on the night of the murders.
Witness
He didn't -- he didn't usually fill -- usually Michele would put something in the bag. I don't recall O.J. putting -- coming out with like a couple of shirts and putting them in a bag. Rarely.
Suggests that Simpson's handling of luggage on June 12 may have deviated from his normal pattern, potentially relevant to the duffel bag issue.

Notable Exchanges (2)

Dan LeonardDaniel PetrocelliHiroshi Fujisaki
Leonard tried to introduce evidence of neighbor complaints about Simpson's dogs and the presence of a second dog at Rockingham, arguing it went to Simpson's state of mind. Petrocelli objected that the undisputed evidence showed only one dog (Chachi) was there that night. Fujisaki sustained twice.
strategic
ExaminerWitness
Leonard established that in nearly all 100 pickups, it was Michele or Gigi (the housekeeper) who responded to the gate buzz — not Simpson himself — normalizing the fact that someone other than Simpson typically answered.
methodical

Light Moments (1)

Daniel Petrocelli
Leonard referred to the Rockingham estate as 'Rockford,' and Petrocelli corrected him mid-question: 'Rockingham.'

Credibility Attacks (1)

⚔ Dale St. John
prior inconsistent framing
Leonard pressed St. John to concede that Simpson was routinely chaotic and rushed during pickups, softening the significance of any unusual behavior observed on June 12.

Objections

3 objections (2 sustained, 0 overruled)
Proceeding 8479 • 65 utterances • Defense witness
Civil Trial
Department 103
⚖️ Start
📂 DEC 4, 1996 📄 Cross-examination of Dale St.
DEC 4, 1996 KRT DvH TD