Cross-examination of Zulema Iida

📄 Cross-examination of Zulema Iida — Friday, February 24, 1995

Address:

C:\DEPT103\CRIMINAL\1995\FEB\24\CROSS-EXAMINATION-OF-ZULEMA-II.DOC

TRIAL

▲ Day 25 of 167

◀ Direct examination of Zulema Iida Redirect examination of Zulema Iida ▶

Witness: Zulema Iida
Examiner: Marcia Clark
Called by: Defense • Date: Friday, February 24, 1995 • Utterances: 185

Marcia Clark cross-examines Zulema Iida, a travel agent called by the defense to corroborate that she booked a flight for Rosa Lopez on February 15th. Clark systematically dismantles the testimony: no records exist for the alleged reservation, Rosa Lopez called the witness that very morning and 'reminded' her of the February 15th date before she testified, and — most damaging — immediately after that call, the witness changed Lopez's ticket from a round-trip March reservation to a one-way departure leaving the next night.

# 1

CROSS-EXAMINATION

# 2

BY MS. CLARK:

# 3 Q:

HOW LONG HAVE BEEN WORKING AT THAT TRAVEL AGENCY?

# 4 A:

ONE YEAR.

# 5 Q:

ONE YEAR?

# 6 A:

YES.

# 7 Q:

AND DURING THAT YEAR, YOU'VE LEARNED TO BOOK FLIGHTS ON -- TO SALVADOR?

# 8 A:

YES.

# 9 Q:

AND WHAT AIRLINES DO YOU BOOK FLIGHTS TO SALVADOR WITH?

# 10 A:

UNITED, TACA, VIA TAICA, LATZA. THOSE ARE THE MOST THAT I USE.

# 11 Q:

AND SALVADOR HAS SOME PRETTY POPULAR DESTINATION PLACE? YOU BOOK A LOT OF FLIGHTS TO SALVADOR?

# 12 A:

YES.

# 13 Q:

DO YOU HAVE ANY RECORDS OF THE RESERVATIONS YOU MADE FOR ROSA LOPEZ ON FEBRUARY 15TH?

# 14 A:

NO, BECAUSE WE CHANGED THE SAME RESERVATION.

# 15 Q:

SO YOU DON'T HAVE ANY PAPERWORK TO SHOW THAT YOU MADE THAT RESERVATION ON FEBRUARY 15TH; IS THAT RIGHT?

# 16 A:

THAT'S RIGHT.

# 17 Q:

AND ORDINARILY WHEN YOU MAKE RESERVATIONS FOR A FLIGHT TO SALVADOR, YOU FILL OUT SOME KIND OF TICKET FORM, DON'T YOU?

# 18 MR. COCHRAN:

I DON'T THINK SO, YOUR HONOR. WELL --

# 19 ZULEMA IIDA:

YES AND NO BECAUSE WELL, YOU KNOW, YOU JUST GO STRAIGHT TO THE COMPUTER AND YOU JUST FILL IN ALL THE INFORMATION DIRECTLY TO THE COMPUTER.

# 20 Q:

BY MS. CLARK: RIGHT. AND YOU TYPE IT RIGHT INTO THE COMPUTER AND THAT GOES STRAIGHT TO THE AIRLINE, DOESN'T IT?

# 21 A:

CORRECT.

# 22 Q:

OKAY. SO YOU WOULD HAVE DONE THAT FOR ROSA LOPEZ ON FEBRUARY 15TH; WOULDN'T YOU?

# 23 A:

YES.

# 24 Q:

SO YOU SHOULD BE ABLE TO PULL UP SOMETHING, SOME RECORD. IF YOU WANTED TO PRINT OUT THE ACTIVITY THAT YOU DID FOR THE MONTH OF FEBRUARY, THAT PRINTOUT SHOULD SHOW A RESERVATION THAT YOU MADE FOR ROSA LOPEZ ON FEBRUARY 15TH, ISN'T IT?

# 25 A:

NOT IF YOU CANCEL IT OR IF YOU MAKE CHANGES TO THE RESERVATION.

# 26 Q:

OKAY. IF YOU CANCELED IT, THEN WOULDN'T YOU HAVE SOME RECORD OF THE FACT IT WAS CANCELED, THAT THE RESERVATION WAS MADE AND CANCELED?

# 27 A:

I DON'T THINK SO.

# 28 Q:

HOW MANY TIMES HAVE YOU BOOKED FLIGHTS FOR ROSA LOPEZ IN THE PAST YEAR TO SALVADOR?

# 29 A:

TO BE HONEST, I DON'T KNOW THE EXACT NUMBER, BUT PROBABLY TWO OR THREE.

# 30 Q:

OKAY. AND WHEN DID YOU BOOK THOSE?

# 31 A:

ONE THAT I REMEMBER WAS IN NOVEMBER.

# 32 Q:

OKAY. AND WHEN IN NOVEMBER?

# 33 A:

THE DATE, MIDDLE OF NOVEMBER.

# 34 Q:

YOU DON'T REMEMBER THE DATE?

# 35 A:

NO.

# 36 Q:

AND DID SHE GO ON THAT -- DID SHE ACTUALLY GO TO SALVADOR ON THAT OCCASION?

# 37 A:

YES, BECAUSE SHE HAD THE TICKET.

# 38 Q:

AND WHAT AIRLINE DID SHE FLY ON?

# 39 A:

AT THAT TIME, WAS I BELIEVE TACA OR UNITED.

# 40 Q:

AND SHE CAME BACK AFTER THAT, AND DID SHE FLY AGAIN?

# 41 A:

AFTER SHE CAME BACK, NO.

# 42 Q:

DID SHE GO EARLIER IN THE YEAR?

# 43 A:

WHAT I REMEMBER, NO.

# 44 Q:

SO SHE ONLY -- FROM THE TIME THAT YOU'VE BEEN WORKING AT THAT AGENCY DURING THE YEAR OF '94, SHE WENT ONCE, AND SHE WENT IN NOVEMBER; IS THAT RIGHT?

# 45 A:

YES.

# 46 Q:

DO YOU HAVE ANY -- LET ME ASK YOU THIS. IN THIS MONTH, IN THIS MONTH OF FEBRUARY, HOW MANY RESERVATIONS HAVE YOU MADE IN GENERAL TO EL SALVADOR?

# 47 A:

FOR ROSA?

# 48 Q:

NO. IN GENERAL.

# 49 A:

IN GENERAL. UMM, IT'S HARD TO SAY. OVER A THOUSAND.

# 50 Q:

OVER A THOUSAND?

# 51 A:

YES.

# 52 Q:

OVER A THOUSAND. DO YOU REMEMBER THE NAMES OF ALL THE PEOPLE YOU BOOKED THOSE TO?

# 53 A:

JUST FEW.

# 54 Q:

OKAY. HOW IS IT YOU REMEMBER ROSA LOPEZ?

# 55 A:

BECAUSE SHE CALLS ME ON THE PHONE AND SHE ALWAYS CALLS ME TO FIND OUT HOW THE PRICE IS AND SHE WANT TO COME AND GET THE TICKET WHEN THE PRICE IS DOWN.

# 56 Q:

WHEN DID YOU FIRST GET THE CALL TO COME TO COURT TODAY?

# 57 A:

THIS MORNING AT ABOUT 12:00.

# 58 Q:

AND WHO CALLED YOU?

# 59 A:

PAT, PAT I GUESS HIS NAME.

# 60 Q:

PAT, PAT MC KENNA?

# 61 A:

YES, I THINK SO.

# 62 Q:

AND DID HE TELL YOU THAT HE WANTED YOU TO COME IN AND TESTIFY THAT YOU BOOKED ROSA LOPEZ A FLIGHT ON FEBRUARY 15TH?

# 63 MR. COCHRAN:

OBJECT TO THE FORM OF THAT QUESTION, YOUR HONOR.

# 64 THE COURT:

OVERRULED. DO YOU UNDERSTAND THE QUESTION, MA'AM?

# 65 ZULEMA IIDA:

WOULD YOU REPEAT THE QUESTION?

# 66 MS. CLARK:

I AM SORRY?

# 67 THE COURT:

WOULD YOU REPEAT THE QUESTION?

# 68 MS. CLARK:

YES. I CAN'T. I CAN'T.

# 69 Q:

BY MS. CLARK: DID MR. MC KENNA TELL YOU THAT HE WANTED YOU TO COME IN AND TESTIFY THAT ROSA LOPEZ BOOKED A FLIGHT TO EL SALVADOR WITH YOU ON FEBRUARY 15TH?

# 70 MR. COCHRAN:

ASSUMES A FACT NOT IN EVIDENCE.

# 71 ZULEMA IIDA:

NO, I DON'T THINK SO.

# 72 THE COURT:

OVERRULED.

# 73 Q:

BY MS. CLARK: WELL, WHAT DID HE TELL YOU?

# 74 A:

HE TOLD ME THAT HE WANTED ME TO COME TO COURT AND HE ASKED ME QUESTIONS ABOUT HER, THAT WHEN SHE WAS LEAVING AND --

# 75 Q:

WHAT DID HE ASK YOU?

# 76 A:

HE ASKED ME WHAT AIRLINE SHE WAS LEAVING, AT WHAT TIME.

# 77 Q:

DID HE ASK IF YOU REMEMBERED THAT SHE HAD BOOKED A FLIGHT WITH YOU EARLIER THIS MONTH?

# 78 A:

YES. SHE -- I THINK SO, HE ASKED ME.

# 79 Q:

IS THAT WHAT HE ASKED YOU?

# 80 A:

YES.

# 81 Q:

AND DID HE ALSO ASK YOU WHETHER YOU REMEMBERED CANCELING THAT RESERVATION?

# 82 A:

YES. WHEN ROSA CALLED, WE MADE A RESERVA -- WE USUALLY MAKE RESERVATIONS AND THE PASSENGER CHANGES HER MIND. IN THIS CASE, LIKE IN ROSA, SHE CHANGED HER MIND FOR THE 15TH OF FEBRUARY. THEN WE BOOK ROUND-TRIP RESERVATION.

# 83 Q:

AND WHO TOLD YOU THE DATE WAS FEBRUARY 15TH?

# 84 A:

ROSA.

# 85 Q:

ROSA, SHE TOLD YOU?

# 86 A:

YEAH.

# 87 Q:

WHEN DID SHE TELL YOU THAT? TODAY?

# 88 A:

TODAY, AND ALSO WHEN SHE CALLED. IT WAS I THINK BEGINNING OF FEBRUARY.

# 89 Q:

WHEN DID YOU TALK TO ROSA TODAY?

# 90 A:

WHAT TIME? YOU MEAN WHAT TIME?

# 91 Q:

YES. WHAT TIME?

# 92 A:

IT WAS ABOUT NOONTIME.

# 93 MS. CLARK:

ONE MOMENT, PLEASE. COULD WE HAVE THE LAST ANSWER READ BACK? I'M SORRY.

# 94 THE COURT:

CERTAINLY. MADAM REPORTER.

# 95 (THE ANSWER WAS READ BY THE REPORTER.)

# 96 Q:

BY MS. CLARK: AND YOU SPOKE TO ROSA LOPEZ ON THE TELEPHONE?

# 97 A:

YES.

# 98 Q:

AND AFTER THAT, DID YOU SPEAK TO MR. MC KENNA?

# 99 A:

YOU MEAN PAT?

# 100 Q:

YES.

# 101 A:

YES.

# 102 Q:

SO FIRST YOU SPOKE TO ROSA LOPEZ; IS THAT RIGHT?

# 103 A:

RIGHT.

# 104 Q:

AND THEN YOU SPOKE TO PAT MC KENNA; IS THAT RIGHT?

# 105 A:

YES.

# 106 Q:

WHEN ROSA TALKED TO YOU, DID SHE TELL YOU THAT SHE WANTED YOU TO COME IN AND TESTIFY THAT SHE HAD BOOKED A FLIGHT EARLIER THIS MONTH FOR SALVADOR?

# 107 MR. COCHRAN:

OBJECT TO THE FORM OF THAT QUESTION.

# 108 THE COURT:

OVERRULED.

# 109 MR. COCHRAN:

ASSUMES FACTS NOT IN EVIDENCE.

# 110 ZULEMA IIDA:

WELL, SHE'S ALWAYS TALKING ABOUT HER FLIGHTS, AND I BELIEVE SHE DID.

# 111 Q:

BY MS. CLARK: WELL, BUT WHEN SHE TALKED TO YOU TODAY, DID SHE ASK YOU TO COME TO COURT AND TESTIFY THAT YOU BOOKED A FLIGHT FOR HER TO SALVADOR EARLIER THIS MONTH?

# 112 A:

YES.

# 113 Q:

AND DID SHE TELL YOU WHAT DATE SHE WANTED YOU TO TESTIFY TO?

# 114 A:

WELL, WHEN SHE CALLED, SHE TOLD ME SHE WANTED TO LEAVE ON THE 15TH OF FEBRUARY.

# 115 Q:

NO. I'M TALKING ABOUT YOUR CONVERSATION WITH HER TODAY.

# 116 A:

OH, TODAY. YEAH, SHE REMIND ME ABOUT THAT.

# 117 Q:

SHE REMINDED YOU?

# 118 A:

YES.

# 119 Q:

SHE TOLD YOU TO SAY IT WAS ON FEBRUARY 15TH WHEN YOU CAME TO COURT; IS THAT RIGHT?

# 120 MR. COCHRAN:

OBJECTION.

# 121 MS. CLARK:

OBJECT -- YOUR HONOR --

# 122 MR. COCHRAN:

OBJECT TO THE FORM OF THAT QUESTION.

# 123 THE COURT:

OVERRULED.

# 124 MS. CLARK:

YOUR HONOR --

# 125 MR. COCHRAN:

MISSTATES THE TESTIMONY.

# 126 THE COURT:

OVERRULED. WHY DON'T YOU RESTATE THE QUESTION.

# 127 Q:

BY MS. CLARK: AND DID SHE TELL YOU TO SAY IT WAS ON FEBRUARY 15TH THAT YOU BOOKED THE FLIGHT FOR HER?

# 128 A:

YEAH. SHE REMIND ME, YEAH.

KEY QUOTE

# 129 Q:

SHE TOLD YOU TO COME IN AND TELL THAT TO THE COURT; IS THAT RIGHT?

# 130 MR. COCHRAN:

OBJECT. THAT'S NOT WHAT SHE SAID. SHE SAID SHE REMINDED HER, YOUR HONOR.

# 131 THE COURT:

OVERRULED. COUNSEL, I HEARD THE TESTIMONY. LET'S FINISH THIS.

# 132 Q:

BY MS. CLARK: DID YOU HEAR --

# 133 A:

YEAH, SHE REMIND ME.

# 134 Q:

OKAY. BECAUSE YOU DIDN'T KNOW THAT ON YOUR OWN?

KEY QUOTE

# 135 A:

NOT REALLY. NO.

# 136 Q:

NOW, ISN'T IT TRUE THAT YOU HAVE ACTUALLY BOOKED A FLIGHT TO EL SALVADOR FOR ROSA LOPEZ DUE TO LEAVE ON MARCH 15TH AND TO RETURN ON MARCH THE 20TH?

# 137 A:

YES.

# 138 Q:

AND WITH WHICH AIRLINE IS THAT?

# 139 A:

UNITED.

# 140 Q:

UNITED. CAN YOU TELL US HOW MUCH THAT TICKET IS?

# 141 A:

AT THIS MOMENT, IT'S ABOUT $452 INCLUDING TAXES.

# 142 (DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)

# 143 THE COURT:

IS THAT ROUND TRIP?

# 144 ZULEMA IIDA:

THAT'S A ROUND TRIP.

# 145 THE COURT:

GOOD DEAL.

# 146 (DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)

# 147 MS. CLARK:

EXCUSE ME, YOUR HONOR.

# 148 (DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)

# 149 Q:

BY MS. CLARK: I AM SORRY. WHAT WAS THAT AMOUNT AGAIN?

# 150 A:

$452.

# 151 (DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)

# 152 Q:

BY MS. CLARK: ALL RIGHT. THAT'S A ROUND-TRIP FARE?

# 153 A:

YES.

# 154 Q:

AND WHAT'S THE ONE-WAY FARE?

# 155 A:

ABOUT 300, 320 OR 315 INCLUDING TAXES.

# 156 Q:

UH-HUH. AND DID YOU TELL -- DID YOU TELL MR. COCHRAN ABOUT THIS ROUND-TRIP TICKET YOU BOOKED FOR ROSA LOPEZ IN MARCH TO AND FROM EL SALVADOR?

# 157 A:

YES.

# 158 Q:

YOU TOLD HIM ABOUT THAT, DID YOU?

# 159 A:

YES.

# 160 Q:

AND WHEN DID YOU TELL HIM ABOUT THAT?

# 161 A:

TODAY.

# 162 Q:

TODAY WHEN YOU TALKED TO HIM AT NOON?

# 163 A:

YES.

# 164 Q:

OKAY. NOW, HAS THAT TICKET BEEN PAID FOR, THAT ROUND-TRIP TICKET?

# 165 A:

NO.

# 166 Q:

DO YOU HAVE A REQUIREMENT THAT IT BE PAID FOR WITHIN 24 HOURS OF THE RESERVATION?

# 167 A:

YES, TO KEEP THE FARE.

# 168 Q:

UH-HUH.

# 169 A:

THE PRICE OF THE FARE.

# 170 Q:

TO KEEP THE PRICE OF THE FARE. BUT THE RESERVATION STILL STANDS; ISN'T THAT RIGHT?

# 171 A:

THAT'S RIGHT.

# 172 Q:

SO AS OF NOW, ROSA LOPEZ IS SCHEDULED TO FLY OUT TO EL SALVADOR ON MARCH THE 15TH AND RETURN ON MARCH THE 20TH TO LOS ANGELES; ISN'T THAT RIGHT?

# 173 A:

AS OF RIGHT NOW, SHE -- WE MADE A CHANGE. SHE'S LEAVING TOMORROW NIGHT, ONE-WAY TICKET.

KEY QUOTE

# 174 Q:

AND WHEN DID THAT CHANGE OCCUR?

# 175 A:

TODAY.

# 176 Q:

WHAT TIME TODAY?

# 177 A:

AROUND NOONTIME, RIGHT AFTER -- AFTER I TALKED TO HER.

# 178 Q:

AFTER SHE CALLED YOU AND ASKED YOU TO COME TO COURT?

# 179 A:

YES.

# 180 Q:

AND THAT WAS AFTER NOON?

# 181 A:

YES, WHEN I TALKED TO HER.

# 182 (DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)

# 183 MS. CLARK:

I HAVE NOTHING FURTHER.

# 184 THE COURT:

MR. COCHRAN.

# 185 MR. COCHRAN:

YES.

Temperature

devastating

Key Quotes (4)

Zulema Iida

YEAH. SHE REMIND ME, YEAH.

The witness effectively admits Rosa Lopez told her what date to testify to — a stunning concession suggesting witness coaching.

Zulema Iida

OKAY. BECAUSE YOU DIDN'T KNOW THAT ON YOUR OWN? Not really. No.

Confirms the February 15th date came from Rosa Lopez, not from the witness's independent recollection.

Zulema Iida

AS OF RIGHT NOW, SHE -- WE MADE A CHANGE. SHE'S LEAVING TOMORROW NIGHT, ONE-WAY TICKET.

Reveals that after Rosa Lopez called to ask the witness to testify, the ticket was changed to a one-way departure — suggesting Lopez was about to flee the country.

Lance A. Ito

IS THAT ROUND TRIP? ... GOOD DEAL.

A rare light moment from the bench — the judge commenting on the airfare mid-testimony.

Evidence (2)

Informal

Computer reservation records for Rosa Lopez's alleged February 15th flight booking to El Salvador — no records exist

discussed; absence established

Informal

Round-trip United Airlines ticket for Rosa Lopez, March 15–20, $452, not yet paid for

discussed; subsequently revealed to have been changed to one-way departing the following night

Notable Exchanges (3)

Marcia Clark•Zulema Iida

Clark walks the witness through the sequence of events on the day of testimony: Rosa Lopez called first at noon, reminded the witness of the February 15th date, then Pat McKenna called, then the ticket was changed to one-way — all after Rosa asked the witness to testify.

devastating

Marcia Clark•Zulema Iida

Clark establishes the witness booked over a thousand flights to El Salvador in February and remembers Lopez specifically because Lopez calls frequently asking about prices — but cannot independently recall the February 15th reservation date.

strategic

Johnnie Cochran•Lance A. Ito

Cochran repeatedly objected to Clark's questions implying Rosa Lopez coached the witness, but Ito overruled every objection, at one point telling Cochran 'I heard the testimony. Let's finish this.'

tense

Light Moments (1)

Lance A. Ito

After the witness quoted the $452 round-trip fare to El Salvador, Judge Ito interjected 'Good deal.'

Credibility Attacks (2)

⚔ Zulema Iida

admission of coaching / lack of independent recollection

Clark gets the witness to admit she did not independently remember the February 15th date — Rosa Lopez 'reminded' her of it during a phone call the morning of her testimony, after which the ticket was changed to a one-way departure, undermining the corroborating value of her entire testimony.

⚔ Rosa Lopez

witness coordination / flight risk

Through Iida's testimony, Clark implies Lopez orchestrated the witness's appearance and then immediately arranged to leave the country one-way the next day — raising questions about both Lopez's credibility and her availability as a witness.

Objections

6 objections (0 sustained, 6 overruled)

Proceeding 5074 • 185 utterances • Defense witness

Criminal Trial

Department 103