Direct examination of Dale St. John

📄 Direct examination of Dale St. John — Wednesday, December 4, 1996

Address:

C:\DEPT103\CIVIL\1996\DEC\4\DIRECT-EXAMINATION-OF-DALE-ST-.DOC

TRIAL

▲ Day 25 of 57

◀ Redirect examination of Josephine Guarin Cross-examination of Dale St. John ▶

Witness: Dale St. John
Examiner: Dan Leonard
Called by: Defense • Date: Wednesday, December 4, 1996 • Utterances: 146

Dale St. John, OJ Simpson's limousine driver of roughly 3.5 years, testified about his routine pickup habits at the Rockingham property. Petrocelli methodically established that Simpson was always home when St. John arrived, the intercom always answered promptly, and the Bronco was always parked on Ashford — never Rockingham. The testimony is clearly foundational, setting a behavioral baseline against which the events of June 12, 1994 (as testified by limo driver Allan Park) would stand in sharp contrast.

# 1 MR. PETROCELLI:

Call Dale St. John.

DALE ST. JOHN, called as a witness on behalf of The Plaintiff, 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 DALE ST. JOHN:

I do.

# 4 THE CLERK:

Sir, would you please state and spell your name for the record.

# 5 DALE ST. JOHN:

Dale St. John, D-A-L-E S-T. J-O-H-N.

DIRECT EXAMINATION BY MR. PETROCELLI:

# 6 Q:

Good afternoon, Mr. St. John.

# 7 A:

Good afternoon.

# 8 Q:

I know it's going to be the first question out of Mr. Leonard's mouth.

Let me ask you, did you meet with me at the Doubletree suite?

KEY QUOTE

# 9 A:

No, sir.

# 10 (Laughter.)

# 11 Q:

We had lunch there?

# 12 A:

Yeah.

# 13 Q:

Okay.

We -- You met with Mr. Leonard outside in the hall, didn't you?

# 14 A:

Yes, sir.

# 15 Q:

You answered his questions?

# 16 A:

Yes, sir.

# 17 Q:

Okay.

# 18 MR. PETROCELLI:

Does that do it, Mr. Leonard?

# 19 MR. LEONARD:

Great.

# 20 (Laughter.)

# 21 Q:

(BY MR. PETROCELLI) Let's move on.

What is your occupation?

# 22 A:

Limousine driver.

# 23 Q:

Are were you a limousine driver in June of 1994?

# 24 A:

Yes, I was.

# 25 Q:

How long had you been a limousine driver?

# 26 A:

About 18 years.

# 27 Q:

Were you a limousine driver in June of 1994 for O.J. Simpson?

# 28 A:

Yes, sir.

# 29 Q:

And how long had you been driving for O.J. Simpson?

# 30 A:

Three, three and a half years.

# 31 Q:

How many times had you been to Mr. Simpson's house to pick him up, if you can approximate, as of June 12, 1994?

# 32 A:

Hundred times.

# 33 Q:

Was there ever -- ever a single occasion when you came to pick Mr. Simpson up, that he was not home?

# 34 MR. LEONARD:

Objection, leading.

# 35 THE COURT:

Overruled.

# 36 A:

No.

# 37 Q:

(BY MR. PETROCELLI) When you came to pick Mr. Simpson up, could you describe where you normally would go onto the property to pick him up.

# 38 MR. PETROCELLI:

I'm going to put on the board here. Exhibit 116.

# 39 (Exhibit 116 displayed.)

# 40 A:

I would pull my limousine on the Ashford gate side and back my car up to the gate and buzz the house.

# 41 Q:

(BY MR. PETROCELLI) And how would you buzz the house?

# 42 A:

There's a call box to the left of the gate with a little telephone receiver in it, as I recall, and a button that you would push.

# 43 Q:

Okay.

And if I point to where it says intercom on Exhibit 116, is that the call box?

# 44 A:

Yes.

# 45 Q:

Okay.

Was there ever. In the more than 100 times you went to pick up Mr. Simpson. A single time when you buzzed at the intercom at the Ashford gate and someone did not answer your first-time buzzing?

# 46 MR. LEONARD:

Objection, irrelevant, leading.

# 47 THE COURT:

Overruled.

# 48 A:

No.

# 49 Q:

(BY MR. PETROCELLI) For example, was there ever an occasion where you buzzed, no one answered, you went back in the car, sat around, came out and buzzed again?

# 50 A:

No.

# 51 MR. LEONARD:

Same objections, Your Honor, leading.

# 52 THE COURT:

Overruled.

# 53 Q:

(BY MR. PETROCELLI) When you buzzed the intercom, who would answer?

# 54 A:

Usually it was Michele.

# 55 Q:

Who is Michele?

# 56 A:

Michele was the housemaid.

# 57 Q:

And in June of 1994, do you know whether Michele was still the housekeeper?

# 58 A:

As far as I know. She was not.

# 59 Q:

Who was the housekeeper in June of 1994?

# 60 A:

Gigi.

# 61 Q:

And were there occasions when the housekeeper did not answer?

# 62 A:

Yes.

# 63 Q:

And who would answer when the housekeeper did not answer?

# 64 MR. LEONARD:

Objection, relevance, Your Honor.

# 65 THE COURT:

Overruled.

# 66 A:

O.J.

# 67 Q:

(BY MR. PETROCELLI) When Mr. Simpson answered the intercom when you buzzed it, what would you then do?

# 68 MR. LEONARD:

Objection, relevance, Your Honor, what would he then do.

# 69 THE COURT:

Overruled.

# 70 A:

I would tell him that I was at the gate and say, this is Dale, I'm here.

# 71 Q:

(BY MR. PETROCELLI) And what then happened?

# 72 A:

The gate would --

# 73 MR. LEONARD:

Same objection.

# 74 THE COURT:

Overruled.

# 75 Q:

(BY MR. PETROCELLI) Excuse me?

# 76 A:

The gate would open; he would buzz and the gate would open.

# 77 Q:

And you would pull in?

# 78 A:

Yes.

# 79 Q:

Okay.

Now, let me show you a photograph.

# 80 MR. PETROCELLI:

Put it up there, 1984.

# 81 (Exhibit 1984 displayed.)

# 82 Q:

(BY MR. PETROCELLI) Okay.

Do you recognize that gate there that's opened in that photograph?

# 83 MR. PETROCELLI:

Can you make it a little better focused than that.

# 84 Q:

(BY MR. PETROCELLI) Do you recognize the gate?

# 85 A:

That looks like the Ashford gate.

# 86 Q:

Okay.

Do you recognize the animal?

# 87 A:

Yes.

# 88 Q:

Who is it?

# 89 A:

It's Chachi.

# 90 Q:

Okay.

In all the times that you picked up -- went to Mr. Simpson's house and went into the gates, did you ever once see Chachi walk or run outside?

# 91 MR. LEONARD:

Leading, Your Honor.

# 92 THE COURT:

Overruled.

# 93 A:

No.

# 94 Q:

Did you ever receive any instructions from Mr. Simpson about watching out for Chachi?

# 95 A:

No.

# 96 Q:

Did you ever receive any instructions from anyone about watching out for Chachi?

# 97 MR. LEONARD:

Same objection, leading, Your Honor.

# 98 THE COURT:

Overruled.

# 99 A:

No.

# 100 Q:

Excuse me.

Did you ever see, by the way, that dog run anywhere?

# 101 A:

No.

# 102 Q:

The times you picked up Mr. Simpson when the -- when you would buzz the intercom, you indicated the gates were -- would then be opened for you at Ashford, right?

# 103 A:

There's correct.

# 104 Q:

Would the gates be opened after a considerable delay or promptly?

# 105 A:

Pretty prompt.

# 106 MR. LEONARD:

Objection, relevance, Your Honor.

# 107 THE COURT:

Overruled.

# 108 Q:

(BY MR. PETROCELLI) Excuse me?

# 109 A:

Pretty prompt.

# 110 Q:

And during the 1994 time frame did you have occasion to pick up Mr. Simpson?

# 111 A:

Sure.

# 112 Q:

Did you have occasion to see what kind of vehicles he had?

# 113 A:

Yes.

# 114 Q:

Okay.

Do you know if he had a white Bronco?

# 115 A:

Yes.

# 116 Q:

Did you ever notice where the Bronco was parked?

# 117 MR. LEONARD:

Objection, relevance, did you ever notice where the Bronco was parked.

# 118 THE COURT:

Overruled.

# 119 A:

Yes.

# 120 Q:

(BY MR. PETROCELLI) Okay.

Where did you see the Bronco parked?

# 121 A:

On Ashford.

# 122 Q:

On Ashford in front of the property?

# 123 A:

Yes.

# 124 Q:

At any time, did you ever see Mr. Simpson's Bronco parked on Rockingham?

# 125 A:

No.

# 126 Q:

Were there ever any occasions, by the way, when you arrived at Mr. Simpson's property and the Ashford gates were open?

# 127 A:

There was a couple of occasions.

# 128 Q:

What did you do on those occasions?

# 129 A:

When the gates were opened I would just -- I would just back the limo into the -- into the driveway and wait.

# 130 Q:

Did you ever receive any instructions from Mr. Simpson on letting yourself in the Ashford gate if the gate was closed?

# 131 A:

No, sir.

# 132 Q:

Did you ever receive any instructions from anyone as to letting yourself in that gate when the gate was closed?

# 133 A:

No.

# 134 Q:

Do you know how to let yourself in through the Ashford gate when the gate was closed?

# 135 A:

No.

# 136 Q:

Did you ever let yourself in the Ashford gate when the gate was closed?

# 137 A:

No.

# 138 Q:

When you would pick up Mr. Simpson. Where would you pick him up at, the front door?

# 139 A:

Yes.

# 140 Q:

Did you ever see Mr. Simpson go retrieve items of luggage on the driveway?

# 141 A:

No.

# 142 Q:

When you would get Mr. Simpson in the car and leave to go to the -- wherever you were going, did Mr. Simpson give you any instructions about waiting at the gates to see if Chachi, the dog, would not run out?

# 143 A:

No.

# 144 Q:

Did you have any kind of practice or custom or habit of specifically looking out for Chachi, the dog, so he wouldn't run out when you were -- you would exit the property?

# 145 A:

No.

# 146 MR. PETROCELLI:

I have nothing further.

Temperature

procedural

Key Quotes (4)

Dale St. John

No.

Repeated answer to whether Simpson was ever not home when St. John arrived — in 100+ pickups, Simpson was always there. This baseline makes his absence on June 12 more damning.

Dale St. John

On Ashford.

The Bronco was always parked on Ashford, never on Rockingham — directly relevant to Allan Park's testimony that the Bronco was absent from its usual spot on the night of the murders.

Daniel Petrocelli

I know it's going to be the first question out of Mr. Leonard's mouth. Let me ask you, did you meet with me at the Doubletree suite?

Petrocelli preemptively defuses a defense attack about witness preparation by joking about it in open court — a calculated disarming move.

Dale St. John

Pretty prompt.

The gate always opened promptly after buzzing — reinforcing that the intercom system worked and was always staffed, making the non-response on June 12 anomalous.

Evidence (2)

Exhibit 116

Diagram or map of the Rockingham property showing the Ashford gate and intercom/call box location

displayed, used to orient witness testimony about pickup routine

Exhibit 1984

Photograph of the Ashford gate open, with Chachi the dog visible

displayed, witness identified gate and dog

Notable Exchanges (2)

Daniel Petrocelli•Dan Leonard

Petrocelli opened by preemptively asking St. John if they met at the Doubletree suite (they did not — they had lunch there), then called out to Leonard asking if that satisfied him. Leonard responded 'Great.' Both got laughs.

light, strategic — Petrocelli inoculating against a credibility attack before it landed

Daniel Petrocelli•Dale St. John

Extended line of questioning establishing that in 100+ pickups, Simpson was never not home, the intercom always answered on the first buzz, the gate always opened promptly, and the Bronco was always on Ashford — never Rockingham.

methodical, strategic

Light Moments (1)

Daniel Petrocelli

Petrocelli opened by preemptively asking the witness if they met at the Doubletree suite — they hadn't, they just had lunch there — and then asked Leonard directly if that settled it. The courtroom laughed twice.

Witness Demeanor

(Laughter.) — after Petrocelli's preemptive Doubletree disclosure

(Laughter.) — after Leonard said 'Great' and Petrocelli moved on

Objections

11 objections (0 sustained, 11 overruled)

Proceeding 8478 • 146 utterances • Defense witness

Civil Trial

Department 103