📄 Sidebar: tape-recorded statement — Thursday, April 27, 1995
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C:\DEPT103\CRIMINAL\1995\APR\27\SIDEBAR-TAPE-RECORDED-STATEMEN.DOC
TRIAL
▲ Day 63 of 167

Sidebar: tape-recorded statement

Date: Thursday, April 27, 1995 • Utterances: 32
Defense attorney Peter Neufeld sought to use a transcript of a surreptitiously recorded tape to refresh a witness's recollection about statements she made to DA investigators. Prosecutor Hank Goldberg objected that the defense-created transcript was work product and that he hadn't received a copy. Judge Ito resolved the dispute quickly by requiring Neufeld to share the relevant pages, and mildly scolded both sides for not sorting this out over the lunch break.
1 (Christine M. Olson, CSR no. 2378, official reporter.)
2 (The following proceedings were held in open Court, out of the presence of the jury:)
3 THE COURT:

All right. Back on the record in the Simpson matter. All parties are again present. Deputy Magnera, let's have the jurors, please.

4 MR. NEUFELD:

Your Honor, we had an objection on that issue. You want to just resolve that before the jury comes in just so we're clear on this?

5 THE COURT:

You got to where you needed to get to is my recollection.

6 MR. NEUFELD:

What I wanted to do at this point is refresh her recollection with the transcript.

7 THE COURT:

I'm sorry. I recollect now. Apparently there's a tape-recorded statement, the tape recording of the statement.

8 MR. NEUFELD:

That's right. There was a surreptitious tape-recording by the detectives who interviewed her that day. And I want the Court to be very clear--

KEY QUOTE
9 THE COURT:

D.A. Investigators.

10 MR. NEUFELD:

D.A. Investigators. Thank you. Number one, this is a tape that was produced by the Prosecution and given to the Defense in discovery. There was no duty on the Defense to give it back to the Prosecution. It's a private tape and by this witness.

11 THE COURT:

All right. Hold on. Hold on. What's the objection?

12 MR. GOLDBERG:

Well, my objection is, your Honor, they created a transcript, which could qualify as work product and normally would unless they're going to use it, which he now intends to do. I don't have that transcript. This tape is extremely difficult to hear because the audio is poor and there's a lot of background noise. And if they're going to use this to refresh her recollection, then I am entitled to it. If he doesn't want to use it, fine. Maybe counsel doesn't know that in this county, there is basically an informal practice by most attorneys that although technically, transcribing a tape is work product and not something we have to turn over, that we do turn over transcripts. He may not know that because he does not practice here. But at any rate, once he wants to use it, at that point, we're entitled to a copy, we're entitled to sit down and determine whether it's correct.

13 MR. NEUFELD:

I actually would be more than happy to let her listen to the tape to refresh her recollection. I was actually just trying to save time.

14 THE COURT:

All right. Do you have any objection to providing Mr. Goldberg with a copy of the pages you intend on using out of this transcript?

15 MR. NEUFELD:

Not at all.

16 THE COURT:

All right. Then--it would have helped if you had talked about this over the lunch hour.

17 MR. GOLDBERG:

I asked him for the transcript.

18 MR. NEUFELD:

Well, I actually--excuse me. No, you didn't ask me for the transcript. What I suggested to Mr. Goldberg--

19 THE COURT:

Well, counsel, if you're willing to share it, then there's no issue, is there?

20 MR. NEUFELD:

Right.

21 MR. GOLDBERG:

May I take a look--

22 THE COURT:

Sure. Take a look.

23 MR. GOLDBERG:

Which part did you want her to read?

24 THE COURT:

You know, it would be thrilling if you guys talked about this stuff over the lunch hour rather than taking the jury time to do this.

KEY QUOTE
25 (Discussion held off the record between the Deputy District Attorney and Defense counsel.)
26 MR. GOLDBERG:

Basically what counsel has pointed out to me is identical to what the witness has already testified to, and the Court already gave very limited rulings on this. So I don't know why we're going over this all over again.

KEY QUOTE
27 MR. NEUFELD:

Mr. Goldberg is misstating the record. She said she didn't remember saying these statements to them and I now wanted to show her the actual statements to see if it refreshes her recollection.

28 THE COURT:

All right. And that's the purpose for which it will be allowed. All right. Let's have the jurors.

29 MR. NEUFELD:

Yeah. I may have to at some point call a detective, but not--I can't put it into this witness. I accept that.

30 THE COURT:

All right. Thank you. Let's have the jurors. And, Mr. Goldberg, you do have your next witness available, correct?

31 MR. GOLDBERG:

Yes.

32 THE COURT:

All right.

Temperature

procedural

Key Quotes (4)

Lance A. Ito
You know, it would be thrilling if you guys talked about this stuff over the lunch hour rather than taking the jury time to do this.
Ito's dry frustration with counsel for failing to communicate — characteristically blunt.
Hank Goldberg
This tape is extremely difficult to hear because the audio is poor and there's a lot of background noise.
Establishes why a transcript matters — the tape itself is hard to use directly.
Peter Neufeld
There was a surreptitious tape-recording by the detectives who interviewed her that day.
Frames the recording as secret/covert, which has implications for how the jury might perceive investigators' conduct.
Hank Goldberg
Basically what counsel has pointed out to me is identical to what the witness has already testified to, and the Court already gave very limited rulings on this.
Prosecution argues the transcript refresh is redundant given prior testimony — disputes whether there's anything new to surface.

Evidence (2)

Informal
Surreptitious tape recording of a witness interview conducted by DA investigators
discussed as basis for refreshing witness recollection
Informal
Defense-created transcript of the tape recording
disputed as potential work product; Neufeld agreed to share relevant pages with Goldberg

Notable Exchanges (2)

Peter NeufeldHank Goldberg
Brief factual dispute over whether Goldberg had asked for the transcript at lunch; Ito cut it off by noting that since Neufeld was willing to share it, there was no issue.
petty/procedural
Lance A. ItoPeter NeufeldHank Goldberg
Judge resolves the transcript dispute in under a minute by simply requiring Neufeld to hand over the relevant pages before proceeding.
efficient

Light Moments (1)

Lance A. Ito
Ito says 'it would be thrilling if you guys talked about this stuff over the lunch hour' — deadpan exasperation at counsel wasting jury time on something resolvable between themselves.

Credibility Attacks (1)

⚔ unidentified witness
prior inconsistent statement via tape recording
Neufeld sought to use the tape transcript to refresh the witness's recollection of statements she claimed not to remember making to DA investigators during their interview.

Objections

1 objections (0 sustained, 0 overruled)
Proceeding 5840 • 32 utterances
Criminal Trial
Department 103
⚖️ Start
📂 APR 27, 1995 📄 Sidebar: tape-recorded stateme
APR 27, 1995 KRT DvH TD