📄 Sidebar: impeachment evidence — Wednesday, January 8, 1997
Address:
C:\DEPT103\CIVIL\1997\JAN\8\SIDEBAR-IMPEACHMENT-EVIDENCE.DOC
TRIAL
▲ Day 37 of 57

Sidebar: impeachment evidence

Examiner: Examiner
Date: Wednesday, January 8, 1997 • Utterances: 55
Defense counsel argued over two impeachment issues: first, whether a national television interview with witness India Allen could be played to contradict her trial testimony about reporting a fight between OJ and Nicole to her employer Dr. Shipp; second, whether Larry Fiato's testimony that Detective Vannatter told him Simpson was a suspect before going to Rockingham could impeach Vannatter. The judge denied the videotape but allowed Dr. Shipp to testify as impeachment, and overruled plaintiffs' objection to Fiato.
1 A:

I've told it to my family a number of times over the years just because it was the only time I've ever seen two people fight like that.

2 MR. LEONARD:

She does not say as she said on national television that she went and ran in and told it to her employer. I think that's another inconsistency we can bring in.

3 MR. KELLY:

The fact she doesn't say something and said in court is not inconsistent, it's lacking -- it's an omission. She was not put through a question answer period during her interview. Secondly, this Court has not allowed any interviews to be played thus far of any witnesses that have taken the stand for any reason. It's an out-of-court statement. It's just -- it's rank hearsay and there's no reason it should be admitted now, especially to serve as a foundation for the next witness they're going to call. They want to call their next witness and ask him certain questions regarding this incident. Any recollection he might have, we have no objection to that. Certainly, we strongly object to any playing of any video at this time, as we have to any other videotape of any other witness, Your Honor.

4 MR. LEONARD:

Your Honor, can I just respond briefly.

5 THE COURT:

Well, thus far I can't fathom the relevance of what it is you're trying to offer. What is it you're trying to offer?

6 MR. LEONARD:

Your Honor, it's a statement that's inconsistent.

7 THE COURT:

What is the statement?

8 MR. LEONARD:

The statement is that I -- after this incident I, India Allen, ran in, said to Dr. Shipp, my employer, that I just saw Nicole Brown Simpson strike O.J. Simpson. Her employer said to her --

9 MR. BAKER:

Other way around.

10 MR. LEONARD:

Excuse me, O.J. Simpson strike Nicole Brown Simpson, and her employer, Dr. Shipp, apparently said to her, don't worry about it, that's just the way they are, she asked if she -- I should call the police.

11 THE COURT:

What are you going to offer now?

12 MR. LEONARD:

The videotape. That's where she made this statement.

13 THE COURT:

That says what?

14 MR. LEONARD:

The statement I just said, Your Honor. She was interviewed on national television after her testimony and she makes this statement which she never stated before and actually contradicts what I just read to you. She was asked how many times have you told this story that you always get mixed up. She responded, I have -- I told only my family. She didn't say anything about going in and telling Dr. Shipp. And that was the question -- I'm sure Mr. Kelly is going to say the question was never put to her. I think we obviously know why. Because Dr. Shipp is going to come in here and say he has absolutely no recollection of that event ever occurring. I think it's very important. It goes directly to her credibility on -- on this -- this issue. And also again, she made the statement that we were asked -- she was asked why didn't you come forward before. And one of the reasons that she articulated was that she didn't want to get into the limelight, she wanted to avoid it, and here she is going on two different national television programs. So again, it goes directly to her credibility.

15 MR. KELLY:

First of all, her answer was not that she only told it to my people, family, she said I told it to my family a number of times over the year. She doesn't say I only told it to my family. Secondly, they had an opportunity to ask if she told anybody else about it or pursued further subsequent action that day, they did not address any questions regarding that on their cross-examination of her. For them to say they want to introduce a videotape, there's no reason if it -- it's not inconsistent with her prior testimony, it's just additional information or statements regarding subsequent actions or discussions she may have had that she wasn't asked about on the stand. We won't have the opportunity to discuss this with her, question her about it at a subsequent time. It's hearsay judge.

16 MR. PETROCELLI:

They're trying to set up an impeachment by setting up a statement that she made in a television show not under oath or in this trial, then bring in another witness to contradict it. You can't do that, Your Honor, it's hearsay. They had a chance to ask her whatever they wanted in the initial examination and it's -- I would object as irrelevant, prejudicial, 352, hearsay, improper impeachment, no foundation.

KEY QUOTE
17 MR. BAKER:

Anything else?

18 MR. LEONARD:

Just one other point. If we need to -- we don't want to have to bring her in because of a medical problem she has; that's one of the reasons that we're trying to do it from this. If we have to bring her in, we'll do it. We can go from there.

19 MR. KELLY:

Fine.

20 MR. LEONARD:

We asked her the question how many times --

21 MR. PETROCELLI:

Bring her in. We can examine her then. We object to playing television shows in court. Substitute for testimony.

22 MR. BAKER:

I thought that's what you guys did with Baden.

23 MR. PETROCELLI:

No. We impeached with a prior inconsistent statement after a proper foundation while the witness was on the stand.

24 MR. LEONARD:

This isn't inconsistent? How many times have you told this story that you always get mixed up. She doesn't mention the first time she ever told it to anybody according to her when she ran in excitedly.

25 THE COURT:

You want to impeach her with Dr. Shipp, go ahead. But I don't think that the video is going to impeach her in that regard. Bring the jury in.

KEY QUOTE
26 MR. LEONARD:

Your Honor, can we have one minute?

27 THE COURT:

Yeah.

28 MR. LEONARD:

Your Honor, we ask that this witness be ordered back to the courtroom, India Allen.

29 MR. PETROCELLI:

Don't know if she's under subpoena or not.

30 THE COURT:

She's been excused. You have got to subpoena her.

31 MR. PETROCELLI:

Subpoena her.

32 MR. BAKER:

All right. Let's -- since Mr. Kelly has control over that, can we have on the record, her address.

33 MR. KELLY:

I have no control over this witness, Judge.

34 MR. BAKER:

You were in communication with her all the time, Kelly, come on.

35 MR. PETROCELLI:

Are you?

36 MR. KELLY:

I don't know whether to deny that or not, Judge.

KEY QUOTE
37 THE BAILIFF:

Jury panel walking in.

38 MR. LEONARD:

Can we approach? We don't need the reporter. (The following proceedings were held at the bench without a reporter:) (Jurors resume their respective seats.) (The following proceedings were held at the bench with the reporter:)

39 THE COURT:

What did you advise me as to what Mr. Fiato's testimony pertains to?

MR. P. BAKER: Mr. Fiato is going to testify that he had two conversation with Phil Vannatter in which Mr. Vannatter told him at a hotel room that Mr. Simpson was a suspect when he went to Rockingham. That's direct impeachment of what Phil Vannatter said during the trial, more importantly, what he said on this stand. He was asked that question. He was asked whether he was suspicious of O.J. Simpson. He denied it each and every time. The motion in limine was filed before the September 17 hearing in which the plaintiffs tried to preclude all introduction or all argument regarding search warrants.

40 THE COURT:

What is your objection?

41 MR. KELLY:

That it's irrelevant. He ruled on the probable cause, the suspect issue, and the hearsay.

42 THE COURT:

I'll stand by my ruling. I'll say there's something that's in way of impeachment. I'll permit it.

43 MR. PETROCELLI:

For the record, I would like to note there's been no question asked of Mr. Vannatter whether -- about whether he had made such statement to Mr. Fiato, so therefore this testimony is not impeaching 'cause there isn't any previous statement to which this is contrary.

KEY QUOTE
44 THE COURT:

Okay. Overruled.

45 MR. LEONARD:

All I want is an order for Dr. Shipp's subpoena continuing. That's all. When we -- he's in the courtroom now.

46 THE COURT:

Where?

47 MR. LEONARD:

He's in the back. Dr. Shipp, would you just stand up. (Dr. Shipp stands.)

48 THE COURT:

What do you want?

49 MR. LEONARD:

Just want him back probably Monday -- Monday, Tuesday.

50 THE COURT:

You said you are going to finish Monday. I'm going to hold you to it.

MR. P. BAKER: Monday afternoon.

51 MR. BAKER:

That was a guesstimate, Your Honor.

52 MR. LEONARD:

Okay. Monday.

53 THE COURT:

Monday afternoon, 1:30.

MR. P. BAKER: The defense calls Larry Fiato.

54 THE COURT:

You may proceed. (Selected portions of the trial transcript of Lawrence Fiato were read by counsel, Mr. P. Baker reading the questions, and Mr. Baker reading the answers.)

MR. P. BAKER: L-a-w-r-e-n-c-e, last name F-i-a-t-o. Page 46,589, line 6. (Reading:)

55 Q:

Are you also known as Larry Fiato?

Temperature

tense

Key Quotes (5)

MR. LEONARD
She was asked how many times have you told this story that you always get mixed up. She responded, I have -- I told only my family. She didn't say anything about going in and telling Dr. Shipp.
Core of the impeachment argument — defense claims Allen's TV statement contradicts her trial testimony about immediately reporting the incident to her employer
Daniel Petrocelli
They're trying to set up an impeachment by setting up a statement that she made in a television show not under oath or in this trial, then bring in another witness to contradict it. You can't do that, Your Honor, it's hearsay.
Articulates the plaintiff's legal theory against the two-step impeachment strategy
THE COURT
You want to impeach her with Dr. Shipp, go ahead. But I don't think that the video is going to impeach her in that regard.
The ruling — video denied, but live witness impeachment permitted
MR. KELLY
I don't know whether to deny that or not, Judge.
Kelly's candid and slightly comic response when Baker accused him of being in contact with witness India Allen
MR. PETROCELLI
For the record, I would like to note there's been no question asked of Mr. Vannatter whether -- about whether he had made such statement to Mr. Fiato, so therefore this testimony is not impeaching 'cause there isn't any previous statement to which this is contrary.
Raises proper foundation objection to Fiato impeachment — court overrules

Evidence (2)

Informal
National television interview with India Allen in which she stated she only told her family about witnessing the fight
offered for impeachment, denied by court
Informal
Lawrence Fiato trial transcript, page 46,589, line 6
read into record by counsel as impeachment of Vannatter

Notable Exchanges (3)

MR. BAKERMR. KELLY
Baker accused Kelly of being 'in communication with [India Allen] all the time' when trying to get her address on the record; Kelly deflected with an ambiguous non-denial
pointed/sardonic
MR. BAKERMR. PETROCELLI
Baker invoked the Baden videotape impeachment to challenge Petrocelli's objection to playing TV footage; Petrocelli distinguished it as a properly-laid prior inconsistent statement while witness was on the stand
strategic
MR. LEONARDTHE COURT
Leonard pressed for the India Allen videotape; court cut through the argument demanding to know exactly what statement was being offered and ultimately found the video insufficient to impeach
procedural

Light Moments (2)

MR. BAKER
When Petrocelli rattled off 'irrelevant, prejudicial, 352, hearsay, improper impeachment, no foundation,' Baker deadpanned: 'Anything else?'
MR. KELLY
Kelly, cornered by Baker's accusation of being in contact with India Allen, responded: 'I don't know whether to deny that or not, Judge.'

Credibility Attacks (2)

⚔ India Allen
prior inconsistent statement via TV interview + contradiction by subsequent witness
Defense argued Allen told national television she only shared the story with family, contradicting her trial implication that she immediately reported it to employer Dr. Shipp; court denied the video but allowed Dr. Shipp to testify
⚔ Phil Vannatter
prior inconsistent statement via third-party witness
Larry Fiato to testify Vannatter told him in a hotel room that Simpson was a suspect before going to Rockingham, directly contradicting Vannatter's repeated denials on the stand; court overruled plaintiffs' objection and permitted the testimony

Witness Demeanor

(Dr. Shipp stands.)
(Selected portions of the trial transcript of Lawrence Fiato were read by counsel, Mr. P. Baker reading the questions, and Mr. Baker reading the answers.)
(The following proceedings were held at the bench without a reporter:)
(Jurors resume their respective seats.)

Objections

6 objections (1 sustained, 1 overruled)
Proceeding 8751 • 55 utterances
Civil Trial
Department 103
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