📄 Sidebar: evidence foundation — Tuesday, April 18, 1995
Address:
C:\DEPT103\CRIMINAL\1995\APR\18\SIDEBAR-EVIDENCE-FOUNDATION.DOC
TRIAL
▲ Day 59 of 167

Sidebar: evidence foundation

Date: Tuesday, April 18, 1995 • Utterances: 12
Defense attorney Barry Scheck requested to play a videotape for the jury, arguing that the prosecution's redirect examination had opened the door by having the witness characterize what the tape depicted. Judge Ito sustained the objection, ruling that the defense had not yet established a proper foundation for the tape — specifically, the precise timing of when it was recorded — but left open the possibility of introducing it later in the defense's case-in-chief.
1 THE COURT:

Mr. Scheck.

2 MR. SCHECK:

Could we approach for just one minute?

3 THE COURT:

Sure.

4 (The following proceedings were held at the bench:)
5 THE COURT:

We are over at the sidebar.

6 MR. SCHECK:

Your Honor, I think he opened the door to playing the tape by his descriptions of how the camera panned. I think at this point he can't object to--the questions were done for purposes of impeachment in terms of his change of testimony. He has now redirected on how this tape didn't make the slightest bit of difference and now he has questioned him in implying what the view of that is in relation to the still photographs.

KEY QUOTE
7 MR. GOLDBERG:

I wouldn't object to that.

8 THE COURT:

But I still have the problem, Mr. Scheck, that one of the issues here is timing and the foundation for the tape is not there. I still have that problem. If you want to cross-examine him on what he saw on the tape, be my guest, but as to the actual playing of the tape, until we have somebody come in and lay a foundation as to precisely when it was, then we have a problem.

9 MR. SCHECK:

Your Honor, we have actually--the problem is I think, your Honor, that we've already had testimony on this and this is a tape. The real problem that I have with it--

10 THE COURT:

You see, you want to lock them into an hour or specific time. That is the stipulation you were offering.

11 MR. SCHECK:

No, no, no, no, no. I have no desire to lock them in. What I would ask the Court to do is on its own--a fair summary of what the different versions of time on the tape. I mean, we've had testimony. We've had testimony from the Prosecution's own witnesses that the time is either 3:14 or their better view of it is that it is 4:14 because the clock was not set ahead because of daylight savings time. It seems to me, particularly the tape that was turned over late in the game, that for them to be insisting now that this tape shouldn't be displayed to the jury on this point, when it is perfectly obvious that the redirect examination was questioning the witness on positions that he had taken previously on direct and that it related to the tape--and they have now been allowed to bring out through the witness an assertion that this tape depicts things in a certain manner that wouldn't be harmful or has no suspicious connotation with respect to the collection of the socks--it seems to me that it is unfair for them to hide behind this kind of foundational objection when the Court can clear it up with a simple statement with respect to the foundational testimony that was already given by the People's own witness. It is a very short segment, won't take very long, and I think in terms of the orderly presentation of evidence in a long trial, I think this would clarify to the jury what everybody is talking about, since the witness saw the tape himself.

12 THE COURT:

All right. I'm going to sustain the objection, the same objection that the Court previously sustained. If you want to bring this in in your case in chief, bring in those witness. I am not precluding the playing, but you don't have the foundation at this point.

Temperature

tense

Key Quotes (4)

Barry Scheck
I think he opened the door to playing the tape by his descriptions of how the camera panned.
Scheck's core argument: the prosecution's own redirect questioning waived any objection to the tape's admission.
Lance A. Ito
the foundation for the tape is not there. I still have that problem. If you want to cross-examine him on what he saw on the tape, be my guest, but as to the actual playing of the tape, until we have somebody come in and lay a foundation as to precisely when it was, then we have a problem.
Ito draws a clear line: oral cross-examination about the tape is permitted, but actual playback requires a timing foundation first.
Barry Scheck
it seems to me that it is unfair for them to hide behind this kind of foundational objection when the Court can clear it up with a simple statement with respect to the foundational testimony that was already given by the People's own witness.
Scheck argues the foundation has already been effectively laid by prosecution witnesses and the objection is being used as a tactical shield.
Lance A. Ito
If you want to bring this in in your case in chief, bring in those witness. I am not precluding the playing, but you don't have the foundation at this point.
Ito's ruling: objection sustained, but door left open for defense's own case.

Evidence (2)

Informal
Videotape at issue — timing disputed as either 3:14 or 4:14 due to daylight savings time clock error
challenged; court ruled foundation insufficient for playback
Informal
Still photographs related to the tape's subject matter (collection of socks)
discussed as context for why the tape's content was relevant

Notable Exchanges (2)

Barry ScheckLance A. Ito
Scheck made an extended argument that the prosecution had already introduced the tape's substance through their own witness and couldn't now hide behind a foundational objection. Ito acknowledged the timing ambiguity (3:14 vs. 4:14) but held firm that formal foundation was required before the jury could see the tape.
strategic
Barry ScheckHank Goldberg
Goldberg briefly noted he would not object to cross-examination about what the witness saw on the tape, narrowing the dispute to the question of actual playback.
procedural

Credibility Attacks (1)

⚔ prosecution witness (unnamed)
prior inconsistent statement
Scheck indicated the cross-examination was conducted to highlight the witness's changed testimony about what the tape showed, which was the precipitating reason for seeking to play it.

Objections

1 objections (1 sustained, 0 overruled)
Proceeding 5763 • 12 utterances
Criminal Trial
Department 103
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📂 APR 18, 1995 📄 Sidebar: evidence foundation
APR 18, 1995 KRT DvH TD