Nancy Ney, Your Honor.

For the record, I have -- I object under hearsay 352 and the cases cited in the brief.

The Court's already ruled.

NANCY NEY, called as a witness on behalf of Plantiff, was duly sworn and testified as follows:

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?

I do.

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

Certainly. My name is Nancy, N-A-N-C-Y, middle initial N, Ney, N-E-Y.

DIRECT EXAMINATION BY MR. GELBLUM:

Morning, Ms. Ney.

Morning.

Do you have any relationship with an organization called Sojourn House?

Yes, I do.

What is Sojourn House?

Sojourn House is a -- there's a few different things that Sojourn does. We have a shelter, crisis shelter, that women can come and stay for four weeks when they're in crisis.

What kind of crisis?

Battering. They're battered women and their children. They come, and they get counseling and help, and any kind of help they really need. And it's a safe place, and it's secret.

Secret?

Secret.

The location is secret?

It's a private place, yes.

Why is the location secret?

So that their batterer can't find them.

What do you do at Sojourn House?

One of the things I do is, I work on the hot line.

What's the hot line?

It's 24 hours. There's someone there every hour of the day and night. And women call with -- battered women can call when they're in crisis or with legal problems, medical problems, any problem that might have to do with their battering situation.

Are you also on the Board of Directors at Sojourn?

Yes, I am.

Did you work at Sojourn in June of 1994?

Yes.

What did you do there at that time?

I was working on the hot line.

Same thing you described?

Yes.

How often did you work?

I worked one day a week, a four-hour shift.

The time that you worked remain constant, or was it different each week?

It was constant.

What was it?

It was the 8:00 to 12:00, 8:00 a.m. to 12 p.m. shift, Tuesday mornings.

By the way, did you receive any training before you started working as a person -- working on the hot line?

Yes.

What was the training?

The State of California mandates a 40-hour training for anyone in -- working in domestic violence.

What does the training consist of?

It consists of learning about the psychology of domestic abuse, what goes on in a relationship, the dynamics between the woman and her partner.

We learn about children's issues, how children react to domestic violence. We learn about legal issues.

Just everything that has to do with domestic violence.

Okay.

And we also have support groups.

And you get certified by the state?

Yes, we get a certificate, and they -- we are then able to work with battered women.

You had completed that training before June 7, 1994?

Yes.

Were you answering the phones on the hot line on June 7, 1994?

I was.

That was a Tuesday?

Yes.

Did you receive a call that morning, at about 11 o'clock, from a woman who identified herself as Nicole?

Yes, I did.

Did she give her last name?

No.

Did you ask for it?

I did not ask.

Is that unusual?

No, it's not unusual. I never ask and they usually never tell.

Why is that?

For confidentiality.

Objection. Relevance and speculation.

Overruled.

For confidentiality, they don't want their last names known.

(BY MR. GELBLUM) Does this person, this woman who identified herself as Nicole, give you any other information about herself that would help you identify her?

She did, yes.

What did she tell you?

She told me her age.

What did she say?

When -- I believe at the time was 34. I don't know exactly. But it was in her mid-thirties.

Okay.

She told me that she had -- she was divorced. She told me that she had been married for eight years. She told me that she had two children, a boy and a girl, and I don't remember now the exact ages, but when I heard about the ages of the children, they were the same ages, as I recalled, not right now. I don't remember the ages. But at that point, they were the correct ages; they were under 10.

She told you both children were under ten?

Under ten.

Did she say the gender of the children?

She said she had a boy and a girl.

Did she say what part of the city she lived in?

She said she lived in West L.A.

Did she tell you her ethnicity?

She was Caucasian.

Okay.

Did she tell you at some point during the call whether she had family in the area?

She did say she had family in the area, yes.

Did she tell you at some point in the conversation whether her ex-husband knew where her family lived?

I'm going to object to leading, Your Honor.

Sustained.

(BY MR. GELBLUM) Did she say anything to you about prior -- I'm sorry. Let me -- I'm getting ahead of myself here.

Have you -- have you heard since that date, tape recording of an October 25, 1994, 911 call made by Nicole Brown Simpson?

Your Honor, I'm going to object. I want to approach on this.

Overruled. Denied.

Yes, I have heard the tape.

Your Honor, I'm going to object to this. There is no foundation for any voice analysis.

Overruled.

(BY MR. GELBLUM) And was the voice that you heard on that 911 call consistent with the voice that you heard on June 7, 1994 from this woman named Nicole?

Yes.

Leading, suggestive. Move to strike. Leading, subjective, no foundation.

Overruled.

(BY MR. GELBLUM) Did she say anything about her husband's occupation?

She didn't mention his occupation specifically. But she does say that he was very high profile and she said that if she told me who he was, I would know.

Did she tell you who he was?

No.

I'm sorry, I think I misspoke. You said she was divorced?

She said she was divorced.

It was her ex-husband?

It was her ex-husband, yes.

Now, did she tell you anything about what was prompting her to make this phone call?

Yes, she did.

What did she say?

She said that she was frightened.

Again, hearsay, Your Honor.

Overruled.

She said that she was very frightened.

(BY MR. GELBLUM) Did she say -- did she sound frightened to you?

She sounded frightened to me, yes.

Did she say why she was frightened?

Yes.

What did she tell you?

She said that her ex-husband had been calling her on the phone. He had been -- during these calls, he would beg her to please come back to him, he needed her, needed her back with him.

She said that he had been stalking her. She said that when she went to a restaurant, she would be sitting there and he'd be sitting -- she'd turn around, and he'd be there staring at her.

She would go to the market; he'd be there in the next aisle, looking at her. She'd be driving down the street; she'd look in the rearview mirror, he'd be there.

And she said this unnerved her and she was very frightened by it.

As a result of her telling you that her ex-husband was stalking her, did you ask her any questions about any other activities that her ex-husband had possibly engaged in?

I had asked her whether he had ever beaten her.

And what did she say?

She said yes.

Did she give you any indication about how long the beatings had been going on?

Well, she didn't say specifically how many years the beatings had been going on, but they'd been going on throughout her marriage.

Okay.

Did you ask her anything about any threats?

I did ask, yes.

What did you ask?

I said has he ever threatened you.

What -- why did you ask that?

Because -- well, that's not -- I ask every battered woman that calls; it's a question you ask; it's an important question. Plus, this stalking worried me a lot.

Why is that?

When a man stalks a woman, it's just very serious behavior. It's a red light that you need to pay attention to.

Is that something you learned in your training?

Yes.

Did Nicole respond to your question about whether her ex-husband had threatened her?

She did.

What did she say?

Did she express any confusion during this phone call?

She did, yes.

On what subject?

She was confused because he -- that this -- his behavior so frightened her, that --

I'm going to move to strike as nonresponsive and request that the witness be ordered to answer the question, not give her interpretation.

I think she's trying to, Your Honor.

Well, I request --

Overruled.

You may answer.

She told me that she was -- his behavior frightened her to such an extent that she was considering -- she was asking my opinion, whether I thought it might be safer for her and her children to move back in with him.

(BY MR. GELBLUM) And did you and she discuss that subject?

We did.

Did she express coming to a conclusion before the end of the call?

By the end of the call, she had come to a conclusion.

What did she say?

Well, after discussing the pros and cons, she came to the conclusion that in the long run, it would not be best for her to move back in.

Okay.

And the reason, again, she said that, she was wondering about whether she should move back in was what?

She --

Asked and answered.

Sustained.

(BY MR. GELBLUM) How long did the call last, altogether, Ms. Ney?

I would say about 20 minutes.

How did the call end?

She thanked me for helping her and letting her get out some of her feelings. And she asked me -- told me that she wanted to just think about what we talked about, and could she please call back the following week when I would be there.

And I said, sure, call back anytime.

Did she ever call back?

No.

Now, did you make some notes during the phone call?

Yes.

Okay.

I'd like to mark as next in order, 2223, a two-page document here.

I'd like the original to be marked as 2223.

The only problem I have with that, the shelter wants the original back at the conclusion of the case. I don't care.

Is there any difference between the original and copies?

Your Honor, there's going to be -- to be some testimony relative to these documents.

Okay. Original marked.

These --

(BY MR. GELBLUM) Can you tell us what Exhibit 2223 is?

Yes. This is a call sheet that, when every -- each call that comes in must be filled out, each woman that calls.

Mr. Baker, I think --

I certainly did, sure.

(BY MR. GELBLUM) Is Exhibit 2223 the call sheet that you filled out during your call with Nicole?

Yes, it is.

The copy you have there is two pages, is the original -- this is the original the two-sided --

Right -- yes.

The top left entry is the date. Do you see that?

Yes.

And the date you wrote down originally was May 7; is that correct?

I did.

And was that the correct date?

It was not the correct date.

How did you determine what the correct date was?

Because I was not there May 7, number one.

Number two, after I heard about the murders, I thought that this -- the details sounded rather familiar to me, and I went back the next Tuesday I was in and I found my sheet in with the June sheets. And I just, you know, 'cause it was the first Tuesday I was there in June, I just was automatically writing the month before, the five, and, you know, like you do in your checkbook, the first of the month.

After you -- You, as you just said, you learned about the murders, you thought this sounded familiar.

Did you also make some additional notes shortly after that about the phone call?

Yes.

I'll show you the original of these notes which we'll mark as 2224.

(BY MR. GELBLUM) Those are notes you made?

Yes.

Why did you make those notes?

Actually, I think at this point -- that was about two weeks after the murder, and I had already contacted the police department and they were going to be calling me back. And I thought that just for -- just so that I could preserve my own memory, since memories do tend to fade over time, details, that I would just write down a few little details just to jog my memory so I'd remember.

I have no further questions, Your Honor.

Cross.

CROSS-EXAMINATION BY MR. BAKER:

(BY MR. BAKER) Ms. Ney, you -- you testified yesterday in Orange County?

Your Honor, objection.

(BY MR. BAKER) -- in the custody hearing --

Objection.

(BY MR. BAKER) -- of Mr. O.J. Simpson --

Excuse me.

Objection.

(BY MR. BAKER) -- did you not?

He knows this is out of line.

The fact that she testified, you may answer yes or no. Contents of the objection sustained.

I did testify.

(BY MR. BAKER) And Mr. Simpson was present at those hearings?

Objection.

(BY MR. BAKER) At those hearings?

This is for the benefit of the jury --

Sustained.

-- to the question.

(BY MR. BAKER) You talked to Natasha Roit.

This is the same subject matter. Counsel has been cautioned to stay away from this area.

Excuse me. Is this -- you're asking about her testimony?

I'm talking about her preparation in talking to the lawyer who's representing the Simpson -- estate of Nicole Brown Simpson and the custody hearing.

This is -- not in the trial process. Objection overruled.

Relative to her preparation?

If this was not part of her testimony or examination at the other trial, then the objection is overruled.

Okay. I'm sorry. I apologize.

(BY MR. BAKER) You talked to Natasha Roit before you testified in the custody hearings relative to Mr. Simpson's children, did you not?

Yes.

How long did you talk to her?

Do you mean on the phone or --

At any --

The whole time, I would say no more than 20 minutes.

And did you go over the -- the forms that you have before you now?

No.

And then you talked to Mr. Gelblum how long?

Maybe half an hour.

Now, as I understand it, you're on the Board of Directors of the Sojourn House, correct?

Yes.

As I understand it, the -- the form that we have here -- is this 2223? This was the form that was filled out by you, you say, on June 7, 1994, right?

Correct.

And, Phil, you want to put this on the Elmo.

Can you focus that up for me, please, if you can.

(BY MR. BAKER) Now -- now, on this form, this -- you say asked -- to ask -- has to be filled out every time there is a call that comes in, right?

Right.

Okay.

And on this form, that -- that form -- you have the original in front of you, do you not?

Um-hum. Yes, I do.

That was filled out in ball-point pen, was it not?

Yes.

And the 5-17 -- 5-7 was part of the original form, correct?

Correct.

And you crossed that out sometime subsequently and wrote in, in a different pen, the "6," did you not?

I didn't cross it out.

I mean, I was not the one who did that.

So someone else did that?

Yes.

And what's the -- what's the notation next to the 6?

I think -- oh, it's CD. That's the woman -- one woman who does these statistics in the shelter, Cynthia Davis.

You, in the ethnicity, you testified here this morning, that was Caucasian, right?

Right.

You didn't circle anything relative to the ethnicity, did you?

No, I didn't.

Now, you said that the victim's age was mid-thirties, did you not?

I did.

You didn't put anything in there relative to mid-thirties, did you?

No.

And nothing in the subsequent, two-week later notes have anything about age in them either, do they?

No.

And by the way, by the time you filled out the -- the notes that were two weeks later, you had read about the murders; you had seen the media barrage about the murders, correct?

I suppose so, sure.

And when you say you had heard about the ages of the children, you remember testifying --

Yes um-hum.

-- earlier this morning?

Yes.

You heard about the ages in the newspaper, didn't you?

Yes.

But can I answer?

You've answered the question. Let's go on up. I want to show you some more of the forms that you filled out.

Now, down here, on -- pull it up, please, where it says (indicating to Elmo) abuser and length of relationship.

Um-hum.

Now, length of relationship is right next to length of marriage, isn't it?

Right.

The length of the relationship of Nicole Brown Simpson and O.J. Simpson, in 1994, was what, 17 years?

I have no idea.

Now, move the form over. And you put -- put nothing relative to married number of years, did you?

No.

And yet you testified that, in fact, they were married eight years, did you not?

I did testify that --

In fact, in 1994, they hadn't been married eight years, because they were divorced in 1992, they'd been married seven years; isn't that right?

I guess so.

That's eight, Your Honor.

February 1985 to October of 1992.

Maybe that's new math.

In any event, I'll swear Mr. Petrocelli in; we'll put him on the stand.

(BY MR. BAKER) In any event, Your Honor, the -- you didn't put down one thing about there how long they were married in the form, where it calls for that information, true?

Wrong place. I put it -- I mean, I was not -- I put it in a spot that I shouldn't have put it in.

You were talking to her about the length of the relationship, were you not, in this 20-minute phone call, Ms. Ney?

We were talking. I had asked --

Can you answer my question?

I asked you if you were talking about, at any point in the 20-minute conversation you had with her, the length of the relationship?

Yes.

Yes or no?

Yes.

That's important if you're talking to a person, is it not?

Absolutely.

And the length of the relationship -- whether a person is married or not married, the length of the relationship is far more significant than -- than the length of the actual marriage, is it not?

She -- Probably.

And if, in fact, they've been living together some six, seven, eight years, whatever it was before they were married, and they were together, that's a more significant statistic for the purpose that you were receiving this call than the length of the actual, legal, marital relationship, is it not?

I had -- well, I had --

Is it not?

For the purpose of what I was talking to her about?

Sure. Talking about with this person whether or not there are acts of violence and -- and whether or not she's in jeopardy, and that relates not only to whether she's physically near the person who may be the batterer, but how long this has been going on, true?

True.

And whether or not there's been an escalating nature of violence, correct?

Yeah. She told me that.

Well, we'll get into that.

Now, so the length of the relationship, you never put down anyplace, and as far as you're concerned, the length of the relationship being eight years is really the length of the marriage, right?

In my mind, that was the length of the marriage.

Can you -- well -- and you never put down anyplace, the length of the relationship; you just made an error and put down the length of the relationship, eight years, correct?

Correct.

All right.

Now, you then go back. Names and ages of children, and you put "2-", correct?

Yes.

Now, that could be the -- the age of one child, could it not?

It could be, but it wasn't what I --

All right.

That wasn't it.

Now, you never put down the ages of the children, did you?

No. But I know what the ages are.

You knew that the ages of the children had been put in the newspaper from the date of June 13 until whenever you got together with Marcia Clark in August of 1994; isn't that true?

But that's not -- I --

Can you answer --

I remember --

-- my question for a change?

Objection. Argumentative.

Sustained.

(BY MR. BAKER) My question, ma'am, is: You knew the ages of the children from your conversation -- from your looking at the news media before you ever talked to Marcia Clark in August of 1994?

That's not true.

Well, I did know. Where I get the ages of the children are from my recollection of the phone call.

And the -- you didn't -- Even in your subsequent notes that you say were done two weeks later, you didn't put the ages of the children in, did you?

They're right in front of you. Take a look.

No. I agree that I didn't.

Now, in your form, right on the back of the form is a --

Phil, you want to turn it over.

MR. P. BAKER: I need the original. You have --

I've got the original. Let me take this. You keep the original.

Okay.

(BY MR. BAKER) Now, on the back of the form, right where you flip over on the same sheet of paper you were writing on --

Um-hum.

-- it says "presenting problem," right?

Right.

And you left that blank, correct?

Correct.

And did you normally fill out only the front page of the form when you were manning the hot lines?

Very frequently, that would be all that would be filled out.

And then you went back two weeks later, you say, and put in what was the presenting problem, correct?

There's no presenting problem.

Well, on your notes, your hand --

Oh, yeah, 'cause I remember what she said.

So you -- you remembered two weeks later that the presenting problem was this purported stalking and spying on her, right?

I remembered since the phone call, yes.

The purported problem was this stalking and following her around, right?

Yes.

And there's nothing mentioned in here about anything in restaurants, nothing in here, even in your -- in your two-week-later notes about --

Well --

-- market, and there's nothing in here about being in the car and seeing you in the -- seeing you in the rearview mirror when driving; you would agree with that?

I would.

And there was, in terms of your particular -- Well, let me ask you this:

Right after the -- you publicized this, and said this was Nicole Brown, you got a lot more donations to Sojourn House --

Assumes facts not in evidence, publicizing this.

Sustained.

You may ask a question in that regard.

(BY MR. BAKER) After you --

By the way, you didn't go meet Marcia Clark until August of 1994; is that correct?

No, I didn't meet with her until January.

1995?

Yeah.

And you didn't talk to anybody in the D.A.'s office or the LAPD until August of '94, correct?

Exactly, yes.

And you had talked to various people in the media before August of 1994?

I spoke with nobody in the media.

And it wasn't in the media at all, right?

Not that I know of, no.

Now, in terms of your two-week notes, the two-week-old notes, where you say "threatened and confused " -- you see that under number 4?

Um-hum. Yes, I do.

Okay.

Now, you -- You, in writing on the front page --

Phil, would you go to the first page, right down at the bottom.

(BY MR. BAKER) She said under her current needs, she didn't -- you never wrote that she was threatened when you wrote the notes on 5-7 or 6-7, correct?

Not in this sheet, no, I did not write that.

Well, this sheet that we have now on the monitor is the only sheet you wrote contemporaneous with the phone call, correct?

Correct.

You didn't write that she was threatened, did you?

No. No, I didn't.

And the fact if someone is threatened when they're calling in, that's significant to you, is it not?

Certainly it was.

That would be the most significant thing about the caller who was calling in, if in fact they are threatened, would it not be?

Probably, yes.

And if, in fact, somebody related to you that they were threatened, that's something you would want to include in the form, to make it complete, true?

I suppose -- Well, this form --

Can you answer my question, please.

Technically, yes.

Well, technically. Technically that's something that you want to perpetuate, that this person is, in fact, threatened, and you want to perpetuate it in your notes; isn't that correct?

This form --

Isn't that correct? If somebody tells you, ma'am, they are threatened, you want to perpetuate it in your notes?

In hindsight, it should have been written down.

Ma'am, I'm talking about when you're doing your job, not talking about hindsight or anything else. I'm talking about you trying to help or --

The purpose of this document is to memorialize what went on and with that call, so if there's a subsequent call or subsequent action, you have a source to go back to; isn't that true?

That is not the purpose of the form.

Now, is it your testimony that she indicated to you that she wondered whether she would be safer to get herself and the kids back together with him?

She did say that.

And -- That appears nowhere on the form, does it, on the form that you wrote contemporaneous with the phone call?

It doesn't.

And is it your testimony that this person who you say identified herself as Nicole, was talking that her children were in danger?

Yes, she -- yes, she would consider, since she was battered, that her children would be in danger.

Now I didn't ask you what you thought she considered; I asked you what she said to you.

Did she say to you, ma'am, that it was her belief when she communicated with you, that her children were in danger?

She didn't say that, not in so many words, no.

And you concluded, two weeks after the call, that she was wondering whether it would be safer for herself and the kids to move back in together, right?

Her -- her -- her concern was her --

No, I asked --

-- her safety.

Well, you concluded two weeks subsequent to your phone call, that, in fact, this woman had told you that her children were in some sort of danger, correct?

Exactly.

All right. Now --

By the way, did you bring anybody here to watch you testify today?

Objection. Relevance.

Sustained.

(BY MR. BAKER) You said that the caller had said to you that -- in questions that you were asked this morning by Mr. Gelblum, that if she was with another man, her ex-husband would kill her, correct?

Correct.

Now, that is something that is very, very significant in the line of work that you're in, is it not?

It is.

I mean that is a threat of death to another human being, true?

True.

And that is the most significant thing, according to what you've testified here today, that was told to you in this purported telephone call of June 7, 1994, correct?

Objection, asked and answered.

Overruled.

When she told me about --

(BY MR. BAKER) No, no, no. I asked you about, if in fact, that was the most important thing that was told to you in this 20-minute phone conversation, a threat of death to the caller?

It was very important, yes.

And it does not appear anywhere on either your contemporaneous form or your two week later form, does it?

Can I explain?

Can you answer the question?

No, it doesn't.

And I would take it that, if in fact, she had told you that she had been threatened to be killed, that you might want to report that to some authorities, correct?

No, I don't do that, we don't do that on the hot line.

All right.

And did you ever ask her, for example, if she was with another man, since the threat was linked to her being with another man?

Oh, sure.

That doesn't appear anywhere on either your contemporaneous form or your two week later additional form, does it?

No.

Thank you.

REDIRECT EXAMINATION BY MR. GELBLUM:

What's the purpose for filling out the form, Ms. Ney?

The purpose for filling out the form are basically for statistical purposes.

Meaning what?

Well, we don't get our funding unless we write down certain things on the sheet, such as the woman's name and where she lives.

Is the purpose of the form to make a record for future calls?

No, it's not.

Objection, leading.

Overruled.

(BY MR. GELBLUM) Your handwritten notes that you made two weeks later --

Um-hum.

-- did they say anything about how long Mr. Simpson -- I'm sorry -- how long -- how long Nicole had been married to her ex-husband, her high-profile husband?

No. Wait a minute. Let me -- I'm sorry.

Yes it does.

What does it say?

Just says married 8 years.

Okay.

Now, why didn't you write down Nicole's report to you that she had been threatened?

Basically, the reason this form is filled out for statistical purposes only, really.

If she had said to me that -- she had told me during the conversation she did not want to come to the shelter. I asked her whether she wanted to come. She said no.

As soon as she said no to me -- if a woman says she wants to come to the shelter, this form has to be filled out very -- in great detail.

You then ask for the last name?

I don't -- yeah, if she -- yes, then at that point I would -- she would -- would need to tell me her last name, she would need to tell me a lot more things, but I would need to write down a lot more things.

Okay.

So when a woman calls and has no interest in coming to the shelter, basically this does not need to be filled out in such great detail.

I was much more interested, at this point, in speaking to her and seeing what her issues were, and what her problems were, and trying to work with her than to get down the details of the -- just her little details she was telling me.

Once she told you she was not interested in coming to the shelter, what was your goal for the rest of the conversation?

The goal for the rest of the conversation --

Objection, irrelevant.

Overruled.

The goal for the rest of the conversation was to work on her problem and to get her to a place where she could feel comfortable about her decision.

I wasn't really concerned at that point on writing down the details.

Why not?

Because it wouldn't have mattered. No one looks at these sheets again.

What's done with these sheets for people who are not going to come into the shelter, what is done with these sheets after the call?

Someone takes them, writes down how many women called or what hours they call, and basically puts them away. They're never seen again.

Are they used for grant purposes?

Yeah, grant, and to get our money every month. We get a certain amount of money from the city and the state.

Is the level of detail, the amount of information you put on this form, atypical, not typical of what you usually fill out for a call when a woman is not coming into the shelter?

Sometimes a lot less is written down, quite frankly.

Okay.

On the subject of the date --

Like to mark as next in order --

2225.

2225.

4?

25 next in order.

Is it 5? 2225. Some calendars.

(The instruments herein described

as calendars for May 1994 and June 1994 were marked for identification as Plaintiffs' Exhibit No. 2225.)

May I approach, Your Honor?

You may.

(BY MR. GELBLUM) Do you recognize these calendars?

Yes.

What are they?

Well, they're the schedule of who's going to be on the hot line sessions.

Okay.

And --

The shifts.

Is your name -- does your name appear on May 7?

No.

Does your name appear on June 7?

Yes.

What time?

The 8 to 12 shift.

Is that the day that you had this call with Nicole?

Yes.

I have nothing further.

Let me see that last calendar, please.

As I understand, Mrs. Ney, the hot line sheet, this says first assessment is not terribly relevant to get funded, right?

No, it's not.

And yet it has filled out --

Phil, put up the first sheet.

(BY MR. BAKER) It has sources to make your job easier, so that you can identify a person and just put in basically a checklist; isn't that correct?

Correct.

And, for example, if someone is calling you and saying that they are -- have been a victim of domestic violence, their age is pretty important, is it not?

Not necessarily, no.

Their ethnicity has no importance either?

Not particularly.

And the details concerning the length of the relationship, that we've already been through?

Um-hum.

And are alcohol or drugs a part of the problem, that's not important either? All you have to do is circle a yes or no, don't you?

Sometimes I don't ask these questions because there are other things that I find, at the moment, more important, and maybe -- and it could be I even asked her, but I don't remember, I mean I -- just in hindsight, I didn't know that I'd be up here on the stand talking about this, so I guess I --

Okay.

But you did know you were going to be up on the stand talking about it when you did your two week memorandum --

No, I didn't.

Let me finish my question.

-- you did the two week memorandum to memorialize the details you testified to in the first examination by Mr. Gelblum, to memorialize the details of the conversation, because you said the memory fades with time, correct?

Correct.

Those were my notes; not for anybody else to look at. I remember the details that I felt were important. I didn't think anybody was going to be looking at these.

My question to you, when you wrote out the card in a totally different pen and on a -- not going back and looking at the form or -- strike that.

Did you go back and look at the form when you wrote this --

No, I didn't.

-- memorandum?

No.

And so you were trying, then, to memorialize all the details, because memory fades, and you left out the major details about the phone call, right?

I was not trying to memorialize all the details.

Now, Mr. Gelblum showed you some calendars, and can you tell me how these calendars are filled out and who fills them out?

There's a woman who's in charge of just that, just calls the volunteers and seeing what shifts they would like to take on which days.

And obviously, these have to do with scheduling, right?

Right.

And these don't have anything to do with Mr. O.J. Simpson, do they?

Not at all.

And Mr. O.J. Simpson's name doesn't appear on any of these, does it?

No.

Would you kindly read the top of the July 1994 calendar to the jury. Whose name appears there?

June?

(BY MR. BAKER) June 1994, tell them what -- just tell them what name appears on the upper right-hand corner of that calendar. Left.

Can I read the note or --

Can you just tell us . . .

O.J. Simpson. O.J. Simpson.

Now, is there in that calendar any other name of any other human being that is not connected with Sojourn House?

No.

And that just happened to get on there?

I have no idea what that's doing there. The only thing I can guess --

I don't want you to guess.

Okay.

Nor does anyone else in this courtroom.

You have no idea how my client's name is on the scheduling calendar of June 1994 -- well --

I -- well, I do have an idea, yes.

You can speculate?

'Cause I can read what the note here --

REDIRECT EXAMINATION (Continued) BY MR. GELBLUM:

Would you do that, please.

It says, "Calls to the hot line R-E O.J. Simpson, no comment."

What do you understand that to mean?

That means if anyone calls the hot line about O.J. Simpson, not to -- to say no comment. This is for everybody.

Thank you. Nothing further.

RECROSS-EXAMINATION (Continued) BY MR. BAKER:

So as early as sometime in June of 1994, there wouldn't be any calls to the Sojourn House unless you or somebody else had put out this purported call of Nicole Brown Simpson?

Objection, calls for speculation, no foundation.

I don't understand the question.

He asked her if -- if somebody else would have any reason to call. How would she know?

Overruled.

I did not say a word to anybody in June.

(BY MR. BAKER) Didn't ask you whether you said a word to anybody. Maybe my question --

That's the problem with the question.

(BY MR. BAKER) I said that was put on that calendar because someone at Sojourn House had publicized what they wanted to publicize as a call from Nicole Brown Simpson, true?

Objection, calls for speculation, assumes facts not in evidence.

True. Sustained. No testimony that it was publicized.

Well, that's circumstantial evidence that it is because --

Pardon me.

-- The fact it's on there to deflect calls about O.J. Simpson.

Sustained.

Jurors to disregard that last comment by Mr. Baker.

Nothing further, Your Honor.

Nothing further.