📄 Motion: exhibit admissibility — Monday, October 28, 1996
Address:
C:\DEPT103\CIVIL\1996\OCT\28\MOTION-EXHIBIT-ADMISSIBILITY.DOC
TRIAL
▲ Day 4 of 57

Motion: exhibit admissibility

Date: Monday, October 28, 1996 • Utterances: 42
Defense attorney Blasier moved to admit two exhibits: 1439 (a photograph outside Bundy) was admitted, while 2097 (a crime scene diagram with witness times and positions) was rejected for evidence but allowed for closing argument. The more significant dispute was Baker arguing that the defense should be permitted to question witnesses about LAPD's failure to collect documented evidence; Fujisaki ruled that the defense may challenge the integrity of collected evidence but may not introduce evidence about items that were never collected, drawing a sharp line Baker repeatedly tested.
1 (REGINA D. CHAVEZ, OFFICIAL REPORTER)
2 (The following proceedings were held in open court, outside the presence of the jury.)
3 MR. BLASIER:

I have two exhibits I neglected to move in. I will move them in, 1439 and the new one, 2097.

4 MR. KELLY:

Your Honor, with regard to 2097, I have two objections: One would be, the times that were testified to were just rough approximations and basically guesses by the witness. And secondly, there are indications put on there, such as Detective Roberts, where there's not even a setting or scenario in which to situate him, and they still placed his name and time on that.

Also, I don't believe it's an accurate reflection of the geographic area or the layout of the premises, or an accurate reflection of the times and positions of people, as to what was testified to.

I simply agreed to the foundation basis as to the diagram itself, and not any entries that may have been subsequently made.

5 MR. BLASIER:

These are times he testified to.

There is no time by Roberts and Phillips -- whether there was testimony by Roberts and Phillips at Bundy.

6 MR. KELLY:

The last, final --

I'm sorry. Are you done?

7 MR. BLASIER:

This is straight from the testimony.

8 MR. KELLY:

That Officer Riske indicated that he could not even find the kitchen on the diagram, not unless Mr. Blasier made markings and an arrow and diagram, and set a time and situated Officer Riske in a kitchen that he was not even able to identify or locate.

9 THE COURT:

What was 1439?

10 MR. BLASIER:

1439 was a picture outside of Bundy.

11 THE COURT:

Picture or photograph?

12 MR. BLASIER:

1439 --

13 THE COURT:

1439 is received.

14 (The instrument herein described was received in evidence as Defendants' Exhibit No. 1439.)
15 THE COURT:

2097 is not received. You can use it in your closing argument.

16 MR. BLASIER:

Thank you, Your Honor.

17 MR. BAKER:

One other issue: That's the issue, as the court is well aware from the testimony this morning, when Officer Riske was put on the stand, Mr. Kelly asked Officer Riske, number one, to describe his duties, which were to identify evidence, preserve evidence. Then he went in detail what he did to preserve the evidence. And the point being that this jury has heard from their first witness that, basically, the LAPD collected all the evidence and preserved all the evidence and preserved the crime scene.

Our view is, obviously, LAPD did not collect all of the evidence. LAPD did not preserve the evidence. And this is what we went into in detail vis a vis the opening statements. And you allowed me to do that after Mr. Petrocelli objected. And I think the Karush case, or whatever it is, is patently different than what you're talking about. We're not talking about different types of techniques; we're talking about what they have set forth in both in their opening statement and here in their first witness, that the LAPD did their job. And basically, the tenor is, there's only one suspect: That's my client.

We're saying the LAPD did not do their job relative to the evidence. And every time there's an objection, the Court sustains it. And so I wanted to get a ruling relative to that, because we're not talking about collection techniques; we're talking about the absence of collection after they identified and photographed evidence at the crime scene.

And we need this. This is relevant for two theories. It's relevant, one, the theory that they say LAPD did everything great and they protected the crime scene; they collected all of the relevant evidence; and there's only one suspect: That's Mr. Simpson.

We say LAPD did not do everything great. They did not collect all the evidence. And the reason there was only one suspect is because of what they didn't do, perhaps, but that's for our argument. That's to be implied as circumstantial evidence.

But I certainly wanted to get the Court's ruling before we went further, in view of what was a and wasn't a motion or anything else. It was just a brief relative to the questioning of witnesses and then the Court sustaining objections. So I wanted to get that cleared up before I went further with Mr. Terrazas, and very definitely before we go further into this case, sir.

18 MR. KELLY:

Your Honor, with regard to the questioning of Police Officer Riske, his testimony was, he was there to identify and preserve the evidence only, and offered absolutely no testimony as to the collection of evidence or any other procedures involved, and further investigation of the evidence or processing of it. He just basically said, I was there to preserve it and make sure it was not disturbed. And his testimony went no further than that.

19 MR. BAKER:

He said he identified it. I'm sorry; I apologize.

20 MR. PETROCELLI:

Your Honor, the position we had argued when we filed the motion originally is simply that evidence that is not collected is not relevant because they can't tie it in any way to the case. What's relevant is the integrity of the evidence that was collected and whether that evidence tends to identify or not identify Mr. Simpson.

But all of the things that were not done and that might have been done, don't tell us anything, and they consume undue time; they're confusing to the jury, and indeed could well be prejudicial.

21 MR. BAKER:

Respectfully, I think they tell us a lot. They tell us about a rush to judgment; they tell us an awful lot about what was being done by the LAPD and what was not being done. These people stand exactly in the shadows of the LAPD.

22 THE COURT:

I don't think so.

23 MR. BAKER:

Well --

24 THE COURT:

The Court, at the outset, had made a ruling; and that was on September 17. And essentially, the ruling is this: The plaintiff has the burden of proving that the defendant, and based on part of the evidence that they are offering, was a person who committed the acts resulting in the deaths.

This is not a case of the defendant defending against a criminal accusation by showing the shortcomings in any of the police investigations, as to raise a reasonable as to the police officers; this is not a case against the Los Angeles Police Department for, as I said before, committing malpractice. It's not a case where the defendant is suing LAPD for not pursuing evidence that would have proved his innocence.

The only issue in this case, really, is whether or not the evidence that is being offered by the plaintiff has proper foundation, and whether or not the evidence supports the plaintiffs' position with regards to connecting the defendant with the offense.

Whether or not the police department did or did not act within certain protocols of police investigation or not, other than the fact that if they spoiled some evidence or affected it, the evidence of the case, some of the evidence being offered, all their shortcomings, in the Court's opinion, do not go to the issue of efficacy of plaintiffs' evidence, and I am going to continue to sustain objections thereon.

25 MR. BAKER:

So I'm clear, in terms, Your Honor called this a civil murder case, all the evidence they're putting on.

26 THE COURT:

Mr. Baker, I'm not married to any term that I may have used at one point or another.

KEY QUOTE
27 MR. BAKER:

Well, when they identify evidence, are you telling us that they identify evidence by photograph?

In other words, as this Court is fully aware, they have a duty to recognize, and as Officer Riske indicated, to I.D. evidence and preserve that evidence.

If it's I.D.'d and preserved and then lost, I assume we get to talk about that.

28 THE COURT:

I agree.

29 MR. BAKER:

Okay. Thank you.

30 THE COURT:

All right. The only thing I am saying, Mr. Baker, is that you're not going to be able to talk about the evidence that they didn't find or failed to find.

31 MR. BAKER:

Okay, fine.

32 THE COURT:

Okay.

33 MR. BAKER:

I wanted to be clear on that. Thank you, sir.

34 THE COURT:

All right. Bring the jury in.

For the record, let me say the reason I would allow it is because it goes to the weight of the evidence.

35 MR. BAKER:

Okay. Thank you.

36 MR. PETROCELLI:

Your Honor, just so we don't interrupt any examination with unnecessary objections, as I understand it, the evidence that Mr. Baker can freely question concerning the evidence that we are offering to prove the defendant's guilt, the physical evidence that we are offering, but not with respect to other evidence that was not collected and not used at all.

37 THE COURT:

That's correct.

38 MR. PETROCELLI:

Thank you.

39 MR. BAKER:

Wait a minute. We're talking about two different things here, Judge. I want to be clear on it. Let's get very specific.

They documented -- that is, the LAPD documented -- and there will be testimony that the coroner was asked to take the blood off of Nicole's back because that blood could not have been the victim's blood.

By the way, she was lying.

That was never done. That blood was destroyed. We will never know where that blood went to.

There was a triangular piece of plain paper that existed in the photographs by the envelope that is of some significance, according to the criminalist that we have retained, and indeed the criminalist they have retained says that's evidence that should have been -- it was documented by the photograph -- should have been collected; it should have been preserved.

It never was preserved; it never was collected. If it was, it was lost subsequently.

We've got the lens, two lenses in the glasses. Those two lenses were checked. Those two lenses went to LAPD's I.D. There is now one lens.

That's the type of evidence we're talking about that goes to the weight, as you say.

40 THE COURT:

No, I don't think so. That's the kind of evidence that's not coming in because it's not being offered. It has to have probative value. The fact that it's no longer here has no probative value as to --

41 MR. BAKER:

-- It does have probative value to rushing to judgment. You can't cherry-pick the evidence you want, and that's what LAPD did.

42 THE COURT:

I'm going to stand by my rulings.

Bring the jury in.

Temperature

tense

Key Quotes (4)

Hiroshi Fujisaki
This is not a case of the defendant defending against a criminal accusation by showing the shortcomings in any of the police investigations... It's not a case where the defendant is suing LAPD for not pursuing evidence that would have proved his innocence.
The judge's clearest articulation of the scope limitation on defense LAPD-criticism strategy — a ruling with major downstream consequences for the defense case.
Robert Baker
They tell us about a rush to judgment; they tell us an awful lot about what was being done by the LAPD and what was not being done. These people stand exactly in the shadows of the LAPD.
Baker's core theory of the case stated plainly — that LAPD tunnel vision on Simpson caused them to ignore or lose exculpatory evidence.
Hiroshi Fujisaki
Mr. Baker, I'm not married to any term that I may have used at one point or another.
Baker tried to leverage Fujisaki's prior use of 'civil murder case' as a concession; Fujisaki shut it down cleanly.
Robert Baker
You can't cherry-pick the evidence you want, and that's what LAPD did.
Baker's final push before Fujisaki ended the discussion — encapsulates the defense's theory that LAPD selectively preserved only inculpatory evidence.

Evidence (5)

Defendants' 1439
Photograph taken outside the Bundy crime scene
Admitted into evidence
Defendants' 2097
Crime scene diagram with annotated witness times and positions, including Detective Roberts and Officer Riske in kitchen
Rejected for evidence; permitted for use in closing argument only
Informal
Blood found on Nicole Brown Simpson's back — documented but reportedly never collected by coroner
Referenced by Baker; Fujisaki ruled it inadmissible as uncollected evidence
Informal
Triangular piece of plain paper photographed near envelope at crime scene — never collected
Referenced by Baker as example of documented-but-lost evidence; ruled out
Informal
Two lenses from glasses at crime scene — one lens went missing at LAPD ID
Referenced by Baker; ruled out under same scope limitation

Notable Exchanges (3)

Robert BakerHiroshi Fujisaki
Baker repeatedly tested the boundary of Fujisaki's evidence-scope ruling, citing specific examples of documented-but-uncollected evidence (blood on Nicole's back, paper triangle, missing lens). Fujisaki drew a firm line each time: integrity of collected evidence is fair game, evidence that was never collected has no probative value.
strategic
John KellyRobert Blasier
Kelly objected to exhibit 2097 on grounds that the witness times were approximations, Officer Riske couldn't identify the kitchen on the diagram without Blasier's added markings, and Kelly only agreed to the foundational diagram itself — not subsequent annotations. Blasier maintained the times came directly from testimony.
procedural
Daniel PetrocelliHiroshi Fujisaki
After the ruling, Petrocelli sought explicit confirmation of the scope to avoid objections during examination; Fujisaki confirmed defense can challenge offered physical evidence but not uncollected evidence.
strategic

Light Moments (1)

Hiroshi Fujisaki
Baker tried to pin Fujisaki to his prior use of the phrase 'civil murder case' as a rhetorical foothold; Fujisaki deflected with 'I'm not married to any term that I may have used at one point or another.'

Credibility Attacks (1)

⚔ LAPD / Officer Riske
Bias / investigative failure
Baker argued that LAPD's failure to collect documented evidence demonstrates a rush to judgment and selective preservation favoring the prosecution — framing LAPD's evidence handling as institutional bias rather than mere negligence.

Objections

3 objections (2 sustained, 0 overruled)
Proceeding 8051 • 42 utterances
Civil Trial
Department 103
⚖️ Start
📂 OCT 28, 1996 📄 Motion: exhibit admissibility
OCT 28, 1996 KRT DvH TD