📄 Sidebar: cross examination hearsay — Thursday, April 20, 1995
Address:
C:\DEPT103\CRIMINAL\1995\APR\20\SIDEBAR-CROSS-EXAMINATION-HEAR.DOC
TRIAL
▲ Day 60 of 167

Sidebar: cross examination hearsay

Date: Thursday, April 20, 1995 • Utterances: 16
Defense attorney Peter Neufeld argues at sidebar that a statement from Dennis Fung to Andrea Mazzola is not hearsay because it is offered to impeach Mazzola's testimony and show her state of mind, not to prove the truth of what Fung said. Judge Ito overrules the prosecution's objection but instructs Neufeld to narrow his question to whether Fung reviewed evidence collection with Mazzola after her August 23rd testimony.
1 (The following proceedings were held at the bench:)
2 THE COURT:

We're over at the sidebar. Mr. Neufeld.

3 MR. NEUFELD:

On the contrary, your Honor. I'm certainly not offering the statement to suggest that it happened. I'm offering it as impeachment to suggest that it didn't happen. If I wanted to--as you know, the Defense position is, we're not trying to suggest Dennis Fung's recollection of who did what is correct. I'm suggesting that Miss Mazzola's recollection as she testified to on August 23rd is correct. So to the extent that I am saying that Dennis Fung told her something different than what she testified to and told her he totally disagreed with it, I'm not offering it to prove the truth of what Dennis Fung told her. I'm simply offering it to prove, number one, that he said it, number two, equal importance, to show what effect that had on Miss Mazzola's state of mind.

4 THE COURT:

So what's the exception?

5 MR. NEUFELD:

State of mind of Miss Mazzola. That's why it's being introduced. And secondly, not even--

6 THE COURT:

Keep your voice down.

7 MR. NEUFELD:

Secondly, all right, it's not even hearsay because it's not being offered for the truth of the matter asserted therein.

8 THE COURT:

Mr. Goldberg.

9 MR. GOLDBERG:

How is it going to have any impact on this witness' state of mind--I don't see how--what Dennis Fung's recollections were of the evidence collection procedure. Also, it seems to me counsel shouldn't be allowed to ask leading questions like that unless he has a good faith belief that something like that was actually said. And he doesn't. Otherwise, it should be based on some sort of offer of proof.

10 MR. NEUFELD:

My good faith basis is, Dennis Fung testified that after August 23rd, he had this discussion with her and he made up a list of who collected what, and his recollection was obviously different from her recollection because, as you know, what she just testified to on direct examination as to who collected what is contradicted by her testimony on August 23rd. In fact, he brought it out to try to take--

11 THE COURT:

Phrasing the question as you just stated right now, I'll overrule the objection, which has to do with the fact that Dennis Fung after her testimony went back and went over with her who collected what.

KEY QUOTE
12 MR. NEUFELD:

Right.

13 THE COURT:

You can ask that question.

14 MR. NEUFELD:

Okay.

15 THE COURT:

Did that happen.

16 MR. NEUFELD:

Fine.

Temperature

procedural

Key Quotes (3)

Peter Neufeld
I'm not offering it to prove the truth of what Dennis Fung told her. I'm simply offering it to prove, number one, that he said it, number two, equal importance, to show what effect that had on Miss Mazzola's state of mind.
Classic non-hearsay argument — reframes the statement's purpose to avoid the hearsay rule.
Hank Goldberg
It seems to me counsel shouldn't be allowed to ask leading questions like that unless he has a good faith belief that something like that was actually said. And he doesn't.
Prosecution challenges the factual foundation for the question, not just its form.
Lance A. Ito
Phrasing the question as you just stated right now, I'll overrule the objection, which has to do with the fact that Dennis Fung after her testimony went back and went over with her who collected what.
Ito threads the needle — allows the inquiry but constrains it to a narrower, less leading form.

Evidence (2)

Informal
Mazzola's August 23rd testimony regarding who collected what evidence at the crime scene
discussed as baseline being impeached
Informal
Dennis Fung's post-testimony conversation with Mazzola in which he reviewed and disputed her recollection of evidence collection
discussed as basis for impeachment question

Notable Exchanges (2)

Peter NeufeldLance A. Ito
Neufeld articulates a dual-track argument — state of mind exception and non-hearsay — and Ito cuts through it to craft a narrower permissible question himself.
strategic
Hank GoldbergPeter Neufeld
Goldberg challenges whether Neufeld has a good faith basis to ask the question; Neufeld responds by citing Fung's own prior testimony as the foundation.
adversarial

Credibility Attacks (1)

⚔ Andrea Mazzola
prior inconsistent statement
Neufeld seeks to impeach Mazzola's current testimony about who collected what evidence by showing her August 23rd testimony contradicted it, and that Fung himself disputed her account in a post-testimony conversation.

Objections

1 objections (0 sustained, 1 overruled)
Proceeding 5775 • 16 utterances
Criminal Trial
Department 103
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📂 APR 20, 1995 📄 Sidebar: cross examination hea
APR 20, 1995 KRT DvH TD