📄 Sidebar: hearsay issues — Thursday, November 7, 1996
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C:\DEPT103\CIVIL\1996\NOV\7\SIDEBAR-HEARSAY-ISSUES.DOC
TRIAL
▲ Day 11 of 57

Sidebar: hearsay issues

Date: Thursday, November 7, 1996 • Utterances: 47
Petrocelli and Leonard clash at the bench over hearsay issues in deposition testimony being read to the jury. Judge Fujisaki rules that the disputed testimony constitutes double hearsay — a witness testifying that Phillips said he contacted someone who said a room wasn't made up — and Petrocelli adjusts which pages he will read. Leonard accuses Petrocelli of violating their prior agreement to keep hearsay out.
1 (The following proceedings were held at the bench:)
2 MR. LEONARD:

Thought you weren't -- I thought we had an agreement, he wasn't going to go into hearsay --

3 MR. PETROCELLI:

I'm not --

4 MR. LEONARD:

-- That elicit hearsay.

5 MR. PETROCELLI:

Where?

6 MR. LEONARD:

Which one you going to do?

7 MR. PETROCELLI:

Page 19, line 1 to page 19, line 10.

8 MR. LEONARD:

No, you skipped that, didn't you? That is hearsay. We spoke to general manager blah, blah, blah, blah.

9 MR. PETROCELLI:

Did I just do it?

10 MR. LEONARD:

No, you didn't. You skipped it.

11 MR. PETROCELLI:

No. I read that one. That one wasn't the problem. I just read that one. The next one I indicated was page 21, line 6.

12 MR. LEONARD:

It was your understanding that's from hearsay. That part.

13 MR. PETROCELLI:

That's his statement. Why don't you read the answer, Your Honor, starting on page 18.

14 THE COURT:

Starting at page 18?

15 MR. PETROCELLI:

I want to read from page 21, line 6 through page 23, line 4.

16 MR. PETROCELLI:

Just background.

17 MR. LEONARD:

I don't care. It's hearsay. If you want that in here, I want my hearsay.

KEY QUOTE
18 MR. PETROCELLI:

I don't think it's hearsay.

19 MR. LEONARD:

That's -- he's responding to a call.

20 THE COURT:

He's testifying about that he heard from Phillips that the room --

21 MR. PETROCELLI:

One at time. I can't hear the Judge. I can't hear what the Judge is saying.

22 THE COURT:

He's testifying that Phillips said he contacted somebody who said that the room wasn't made up. That's pretty clear hearsay.

KEY QUOTE
23 MR. PETROCELLI:

Okay.

24 THE COURT:

Double hearsay.

25 MR. PETROCELLI:

Okay. Your Honor, take a look at -- I want to cut through this now. Page --

26 THE COURT:

It's hearsay of Phillips and hearsay of somebody who talked to them.

27 MR. PETROCELLI:

What about 22, line 11, Your Honor?

28 MR. PETROCELLI:

That question and answer. I'm trying to get him into the room.

29 MR. LEONARD:

Well, get him into the room.

30 THE COURT:

I -- you can get him in the room.

31 MR. PETROCELLI:

I can't. This is how he described it. I can't make it up.

32 MR. LEONARD:

I'll stipulate he went in -- he went in the room, made observations.

33 THE COURT:

I think Mr. Leonard's objecting to the fact that the answer includes the statement that the room was made up.

34 MR. LEONARD:

Right. They're just going right to that question.

35 MR. PETROCELLI:

Which question?

36 MR. LEONARD:

Line 20. Fine. I don't care about that.

37 MR. PETROCELLI:

Do you have a problem with 23, line 9?

38 MR. LEONARD:

No.

39 MR. PETROCELLI:

Okay. Then I'll read that, then I'm going to go to 26, line 18.

40 MR. LEONARD:

Not really. I don't know what the relevance is.

41 MR. PETROCELLI:

It's just establishing foundation.

42 MR. LEONARD:

Okay.

43 MR. PETROCELLI:

Then we're going to go to page . That starts his observations.

44 MR. LEONARD:

Just -- I thought we had an agreement for hearsay. That's my only problem.

45 MR. PETROCELLI:

I'm trying to keep it out.

46 MR. LEONARD:

Do a better job, will you?

KEY QUOTE
47 (The following proceedings were resumed in open court in the presence of the jury:)

Temperature

tense

Key Quotes (4)

Hiroshi Fujisaki
He's testifying that Phillips said he contacted somebody who said that the room wasn't made up. That's pretty clear hearsay.
Judge's definitive ruling identifying the hearsay chain
Hiroshi Fujisaki
Double hearsay.
Fujisaki sharpens the ruling — two levels of hearsay embedded in the testimony
Dan Leonard
Do a better job, will you?
Sarcastic closing shot at Petrocelli for failing to honor their hearsay agreement
Dan Leonard
I don't care. It's hearsay. If you want that in here, I want my hearsay.
Leonard signals he is holding to a reciprocal agreement — if Petrocelli gets hearsay in, so does the defense

Evidence (1)

Informal
Deposition testimony being read to jury, pages 18-26, including references to a room not being made up and a witness entering the room
discussed, portions excluded as hearsay

Notable Exchanges (2)

Daniel PetrocelliDan Leonard
Leonard accuses Petrocelli of violating a prior agreement to avoid eliciting hearsay; Petrocelli denies it and they negotiate page-by-page which deposition excerpts are acceptable
tense, adversarial
Daniel PetrocelliHiroshi Fujisaki
Petrocelli asks the judge to look at specific line ranges to salvage portions of the testimony; Fujisaki rules the core statement is double hearsay and cuts it
procedural

Light Moments (1)

Dan Leonard
Leonard's parting shot — 'Do a better job, will you?' — lands as dry sarcasm after Petrocelli claims he was trying to keep hearsay out

Objections

3 objections (2 sustained, 0 overruled)
Proceeding 8190 • 47 utterances
Civil Trial
Department 103
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📂 NOV 7, 1996 📄 Sidebar: hearsay issues
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