📄 Sidebar: polygraph evidence — Monday, November 25, 1996
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C:\DEPT103\CIVIL\1996\NOV\25\SIDEBAR-POLYGRAPH-EVIDENCE.DOC
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▲ Day 22 of 57

Sidebar: polygraph evidence

Date: Monday, November 25, 1996 • Utterances: 32
During Simpson's testimony, he volunteered that he had wanted to take a lie detector test but was refused. Petrocelli moved to follow up by asking whether Simpson actually went to take the test and failed it. Baker erupted in objection, arguing no test was ever taken and that the book (Schiller's) disclosing privileged communications did not constitute a waiver of attorney-client privilege. The judge overruled Baker, allowing the line of questioning.
1 THE COURT:

Approach the bench.

2 (The following proceedings were held at the bench, with the reporter.)
3 MR. PETROCELLI:

First of all, the witness himself just volunteered himself how he, you know, wanted to take a lie detector test. It was refused.

Trying to argue --

4 MR. BAKER:

Well --

5 MR. PETROCELLI:

-- Trying to argue that he had taken what he would have asked, and that's exactly what Mr. Baker argued to the jury in his opening statement, on page 110 of the transcript, that he had no reason to say what he said here other than to suggest that Mr. Simpson was totally innocent, and had he taken the test, which he was happy to do, he would have passed it.

And he has absolutely opened the door on that issue, and I am entitled to follow up, to demonstrate not only did he -- did he take it, but he failed it, Your Honor.

6 MR. BAKER:

Well, two things:

One, he never took a lie detector test.

Two, he didn't fail a lie detector test.

And three, a letter sent to Vannatter and Lange, as well as also the D.A.'s office, indicating that there was a lie -- they would offer for him to take a lie detector test at the same time that they offered the services of Baden, and he offered the services of Lee, and let the chips fall where they may, the LAPD refused all of that.

Now, to infer that he has taken a lie detector test and failed it is absolutely false.

7 MR. PETROCELLI:

I've not inferred he -- I'm asking the question. He opened the door. I have the right to ask him.

8 MR. BAKER:

No.

9 MR. PETROCELLI:

We know he went to take the test the 14th, 15th, at the offices of Edward Gelb.

It's all outlined in the book.

I'm going to ask him about it, Your Honor, particularly since he opened the door wide open.

10 MR. BAKER:

No, no. There's a couple of things -- and I want to make a record relative to that book. And I want to make a record relative to the Court's ruling that you say that that book -- because we have not filed a lawsuit, we have waived any attorney-client privilege.

That is, to me, absolutely without foundation.

And the -- in the law anywhere, we have never waived any attorney-client privilege. The fact that somebody else attempts to waive an attorney-client privilege for Mr. Simpson does not waive it for him at all.

And he has never waived it.

And I think the Court's ruling is improper.

And I think for them to bring this up is terribly improper. That is all because Kardashian waives the attorney-client privilege, or does whatever he does and gives an interview for a book because he gets 40 percent of the proceeds.

And it's my understanding, presently he's under investigation by the state bar over exactly this.

That doesn't waive his privilege. Only the holder of the privilege can waive it. The holder is O.J. Simpson.

11 MR. PETROCELLI:

We've heard, Your Honor, one month ago, when this book came out, counsel of record in this case, F. Lee Bailey, Mr. Leonard's partner, went on national television on the Larry King Show, and spoke openly about this test, openly.

Notwithstanding the Court's gag order, he talked about how Mr. Simpson went there, and he didn't think they asked all the right control questions, and on and on.

And the point is, basically, this -- not only did the witness get it out to the jury, but Mr. Baker, in opening statement -- we didn't utter a word about polygraph tests, and he opened that door. And he cannot have it both ways.

12 MR. BAKER:

That is absolutely --

13 THE COURT:

Are you going to address the issue of the book once more?

14 MR. PETROCELLI:

The book -- this book was put out by Simpson's colleague, Schiller, who wrote his first book with him. He, in consultation not only with Kardashian, but with all of Mr. Simpson's lawyers, all of them, Dershowitz and Cochran and -- what's that other guy -- Scheck, and Neufeld and on and on.

This book has been in the works for a long time. They never once filed any action to enjoin it. They never ever tried to stop the publication of it.

You can't simply allow material to go out there and then claim it's privileged without doing anything to stop the publication of it.

That is an absolute waiver.

A waiver doesn't have to be in writing. Waivers are frequently implications and acquiescence.

15 THE COURT:

Okay.

16 MR. BAKER:

Wait a second. That is not true. His representations are absolutely false. And that's why he's making a bunch of accusations he has no foundation to make.

Peter Neufeld wrote every lawyer in this case, as Mr. Simpson's lawyer, he wrote Random House, he wrote Schiller, and he said, if you do what you say you're going to do, there's going to be a lawsuit and there is going to be a lawsuit.

And for him to say we have acquiesced and waived it is absolutely an absolute bold-faced lie. It is a --

17 MR. PETROCELLI:

Absolute filed for injunctive relief --

18 MR. BAKER:

Let me finish.

19 MR. PETROCELLI:

Lower your voice.

20 MR. BAKER:

No, I will not lower my voice.

KEY QUOTE
21 THE COURT:

I think you better lower your voice.

22 MR. BAKER:

I think it's an outrage.

Simpson has done everything possible to stop that book.

We represented to the Court and read portions of a letter to this Court, November 28 letter, and there has been at least four or five more pieces of communication to Schiller, to Random House, and to all of his lawyers, that they have not -- that he has not waived the attorney-client privilege.

Now, to say that he's waived it by acquiescence is a bold-faced lie. It hasn't happened. He has never waived it.

23 THE COURT:

When did Mr. Simpson first get notice that it was going to be published?

24 MR. BAKER:

That the book was going to be published?

25 THE COURT:

Um-hum.

26 MR. BAKER:

About mid-September.

I had a conversation with Mr. Scheck in early September, when they indicated that they were going to publish this book.

And there was a plethora of communications back and forth ordering them not to.

27 THE COURT:

Was there any effort to file a -- file for an injunction?

28 MR. BAKER:

My understanding is they got a representation that the book wasn't going to be published. And then it was published. And that's why there was no injunction filed for it.

But Mr. Neufeld -- we'll get the communications, and he can wait on this until we get the communications. I will get the communications from Peter Neufeld and have them faxed.

29 MR. PETROCELLI:

This tells the tale. (Indicating to transcript.) This is a red herring about what -- Mr. Simpson sat for interviews for this book. He gave all the tapes up. That's how -- they gave the tapes -- he gave his notes up, too.

30 MR. BAKER:

That's absolutely not true.

31 MR. PETROCELLI:

Why does Mr. Baker tell the jury that Mr. Simpson was more than happy to take a lie detector test, but they refused, other than to suggest that he was innocent and would have passed the test?

This -- that's the only inference he wanted the jury to draw.

32 THE COURT:

Okay. I'll stand on my ruling.

Overruled.

Temperature

heated

Key Quotes (5)

Daniel Petrocelli
I have the right to ask him. We know he went to take the test the 14th, 15th, at the offices of Edward Gelb. It's all outlined in the book.
Petrocelli signals he has specific evidence — dates and a location — that Simpson did in fact attempt to take the polygraph, contradicting Baker's flat denial.
Robert Baker
That is an absolute bold-faced lie. It is a --
Baker loses composure at the bench, prompting the judge to order him to lower his voice.
Robert Baker
No, I will not lower my voice.
Direct defiance of the judge's instruction, illustrating how heated this exchange became.
Daniel Petrocelli
That is all because Kardashian waives the attorney-client privilege, or does whatever he does and gives an interview for a book because he gets 40 percent of the proceeds.
Petrocelli frames Kardashian's cooperation with the Schiller book as financially motivated, undermining Baker's privilege argument.
Hiroshi Fujisaki
I'll stand on my ruling. Overruled.
Terse, final ruling allowing Petrocelli to pursue polygraph questioning despite Baker's extended objection.

Evidence (3)

Informal
Baker's opening statement transcript, page 110, in which Baker told the jury Simpson was willing and happy to take a lie detector test
cited by Petrocelli to establish that Baker opened the door on polygraph evidence
Informal
Schiller book containing accounts of Simpson's polygraph session at the offices of Edward Gelb on approximately November 14-15
cited by Petrocelli as basis for polygraph questioning; disputed by Baker on privilege grounds
Informal
November 28 letter and subsequent communications from Peter Neufeld to Schiller, Random House, and Simpson lawyers objecting to publication
cited by Baker to argue no privilege waiver by acquiescence

Notable Exchanges (3)

Robert BakerDaniel PetrocelliHiroshi Fujisaki
Baker refused to lower his voice when instructed by both opposing counsel and the judge, insisting the book-based privilege waiver argument was a 'bold-faced lie.' The judge had to intervene twice.
heated
Daniel PetrocelliRobert Baker
Petrocelli argued that F. Lee Bailey — Baker's co-counsel's partner — went on Larry King Live and discussed the polygraph test openly, despite the court's gag order, further undermining any privilege claim.
strategic
Hiroshi FujisakiRobert Baker
Judge questioned Baker about when Simpson first learned the book would be published and whether an injunction was ever sought, pressing him on the acquiescence argument.
procedural

Credibility Attacks (2)

⚔ O.J. Simpson
prior inconsistent statement / opening the door
Petrocelli argued Simpson's own testimony that he 'wanted' a lie detector test but was refused opened the door to evidence that he actually went to take one (at Gelb's office) and failed it.
⚔ Robert Baker
impeachment of counsel's opening statement
Petrocelli cited Baker's own opening statement (page 110) as the basis for the door-opening argument, turning Baker's rhetorical gambit against him.

Objections

1 objections (0 sustained, 1 overruled)
Proceeding 8404 • 32 utterances
Civil Trial
Department 103
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