📄 Motion: photograph evidence admission — Monday, February 6, 1995
Address:
C:\DEPT103\CRIMINAL\1995\FEB\6\MOTION-PHOTOGRAPH-EVIDENCE-ADM.DOC
TRIAL
▲ Day 13 of 167

Motion: photograph evidence admission

Date: Monday, February 6, 1995 • Utterances: 134
Judge Ito cleared the jury after the prosecution displayed People's 9, a Polaroid photograph of Nicole Brown Simpson appearing beaten, without first establishing its date, origin, or connection to any of the 1101(B) domestic violence incidents he had approved. Darden argued the photo was relevant to Nicole's and Denise Brown's state of mind, but Ito rejected that theory and ruled the photo inadmissible. Defense counsel Shapiro demanded serious sanctions, going as far as suggesting all 1989 domestic violence evidence be stricken from the record.
1 (THE FOLLOWING PROCEEDINGS WERE HELD IN OPEN COURT:)
2 THE COURT:

ALL RIGHT. CAN WE HAVE THE PHOTO TAKEN DOWN, PLEASE. LADIES AND GENTLEMEN OF THE JURY, I'M GOING TO ASK YOU TO STEP BACK INTO THE JURY ROOM, PLEASE. AND MISS BROWN, I'M GOING TO NEED TO DISCUSS SOMETHING WITH THE LAWYERS AND I'M GOING TO ASK YOU TO STEP OUT OF THE COURTROOM. THANK YOU.

3 (THE FOLLOWING PROCEEDINGS WERE HELD IN OPEN COURT, OUT OF THE PRESENCE OF THE JURY:)
4 MR. DARDEN:

MAY I BE HEARD, YOUR HONOR?

5 THE COURT:

I'M A LITTLE CONCERNED. WE ARE BACK IN OPEN COURT OUT OF THE PRESENCE OF THE JURY. MR. DARDEN, I'M A LITTLE CONCERNED HERE. PEOPLE'S 9, THE COURT RULED AS TO THE 1101(B) INCIDENTS, AND THERE WERE CERTAIN SPECIFIC INCIDENTS THAT WERE MENTIONED IN THE VARIOUS MOTIONS THAT THE COURT HAS SPECIFICALLY RULED ON YES OR NO. WHAT IS YOUR OFFER OF PROOF AS TO PEOPLE'S 9?

6 MR. DARDEN:

YOUR HONOR, PEOPLE'S 9, THE PHOTOGRAPH WHICH DEPICTS NICOLE BROWN, THE ONE THAT WAS JUST ON THE ELMO, IS A PHOTOGRAPH THAT WAS RECOVERED FROM THE SAFE-DEPOSIT BOX ALONG WITH THE 1989 PHOTOS, AS WELL AS THE HERALD-EXAMINER NEWSPAPER ARTICLE FROM 1989, THE NEWSPAPER ARTICLE THAT DESCRIBED THE JANUARY 1, 1989, CHARGES AND BEATING.

7 THE COURT:

ALL RIGHT. WELL, WE ALL KNOW FROM APOCRYPHAL STORIES THAT POLAROID PHOTOS CAN BE DATED TO A CERTAIN DEGREE BY THE CODE ON THE BACK OF THE PHOTOGRAPH INDICATING THE DATE OF MANUFACTURE, DISTRIBUTION, BLAH, BLAH, BLAH, ABOUT THE PHOTOGRAPH. WHAT HAVE YOU FOUND OUT FROM POLAROID REGARDING THOSE PHOTOGRAPHS?

8 MR. DARDEN:

AS FAR AS WHEN THE FILM WAS PRODUCED?

9 THE COURT:

YES.

10 MR. DARDEN:

'78 OR '79.

11 THE COURT:

THAT FILM WILL ALSO TELL YOU ABOUT FRESHNESS AND HOW LONG THE BATTERY PACK WILL STAY ALIVE AND THAT APPEARS TO BE AN SX-70 POLAROID PHOTO.

12 MR. DARDEN:

I DON'T HAVE ANY INFORMATION ABOUT BATTERY PACKS AND HOW LONG THINGS STAY ALIVE.

13 THE COURT:

HOW ARE WE GOING TO TIE PEOPLE'S 9 TO AN INCIDENT THAT THE COURT HAS RULED ADMISSIBLE UNDER 1101(B)?

14 MR. DARDEN:

YOUR HONOR, THIS IS THE ISSUES OF THE DEFENDANT'S ATTEMPT TO MINIMIZE WHAT HAPPENED IN JANUARY OF 1989. AND AS I INDICATED TO THE COURT BEFORE, IT IS OUR POSITION THAT MISS BROWN LEFT A TRAIL, A TRAIL OF EVIDENCE INDICATING THAT THERE HAD BEEN A PATTERN, A HISTORY OF ABUSE BETWEEN HER AND THE DEFENDANT. I THINK HER STATE OF MIND IS RELEVANT, GIVEN THE DEFENSE POSTURE AND CROSS-EXAMINATION OF RON SHIPP. I THINK THAT MISS BROWN'S STATE OF MIND IS GOING TO BE RELEVANT IN THESE PROCEEDINGS IN THE AREA OR ON THE ISSUE OF WHY IMMEDIATELY AFTER THE MURDERS SHE TOLD THE NEW YORK TIMES THAT SHE DIDN'T KNOW ANYTHING ABOUT NICOLE HAVING BEEN ABUSED.

AND THESE PHOTOGRAPHS ARE NO SURPRISE TO THE DEFENSE. THESE PHOTOGRAPHS WERE PRESENTED TO THE COURT AND TO DEFENSE COUNSEL DURING THE DOMESTIC VIOLENCE MOTIONS AND HEARINGS.

15 THE COURT:

WELL, MR. DARDEN, THE FACT THAT IT IS NOT A SURPRISE DOESN'T MAKE IT AUTOMATICALLY ADMISSIBLE, WOULD YOU AGREE?

16 MR. DARDEN:

THERE HAS NEVER BEEN AN OBJECTION TO HAVING THESE PHOTOGRAPHS MENTIONED HERE IN OPEN COURT. THEY WERE SHOWN TO RON SHIPP JUST THE DAY BEFORE YESTERDAY.

17 THE COURT:

WELL, LET ME ASK YOU ANOTHER QUESTION, SINCE WE ARE OBVIOUSLY GOING TO TALK ABOUT PEOPLE'S 10 AND PEOPLE'S 11. HOW ARE YOU GOING TO CONNECT THIS UP TO ANY OF OUR INCIDENTS, 10 AND 11?

18 MR. DARDEN:

I'M SORRY, HOW AM I GOING TO CONNECT IT UP?

19 THE COURT:

ANY OF THE INCIDENTS UNDER 1101(B) THAT THE COURT HAS DEEMED ADMISSIBLE FOR THE PURPOSES OF THIS HEARING.

20 MR. DARDEN:

I DON'T THINK THIS IS AN 1101(B) ISSUE, FRANKLY, BUT AS FAR AS THE OTHER TWO PHOTOGRAPHS, 10 AND 11 --

21 THE COURT:

COUNSEL, YOU CAN'T JUST SHOW HORRIBLE PHOTOGRAPHS WITHOUT TYING IT TO SOMETHING RELEVANT TO THIS CASE.

22 MR. DARDEN:

DENISE BROWN'S STATE OF MIND IS RELEVANT AND SO IS NICOLE BROWN'S STATE OF MIND. THEY WILL MAKE NICOLE BROWN'S STATE OF MIND RELEVANT AS FAR AS DOMESTIC VIOLENCE. THEY HAVE INTRODUCED EVIDENCE THAT SHE WAS DRINKING OR THAT THE 1989 INCIDENT OCCURRED BECAUSE SHE WAS DRINKING. THEY HAVE ATTEMPTED TO MINIMIZE THE DEFENDANT'S CONDUCT EVERY STEP ALONG THE WAY, YOUR HONOR, AND THEY HAVE ALSO ATTEMPTED TO IMPLY TO THE JURY OR SUGGEST TO THE JURY THAT IT WAS AN ISOLATED INCIDENT.

23 THE COURT:

ALL RIGHT. WHAT IS THE -- MY RECOLLECTION OF LOOKING AT 9, 10 AND 11 IS THAT THE SERIAL -- NOT THE SERIAL NUMBER -- THE MANUFACTURER'S CODE ON EACH OF THESE POLAROID PHOTOGRAPHS IS VERY DIFFERENT, ONE FROM ANOTHER. WHAT IS YOUR INFORMATION AS TO THE DATE OF MANUFACTURE OF THE FILM OF 10 AND 11?

24 MR. DARDEN:

10 AND 11 ARE MANUFACTURED IN '88 OR '89, BUT DENISE BROWN IS GOING TO TESTIFY TO HAVING TAKEN 10 AND 11 HERSELF.

25 THE COURT:

SHE IS THE ACTUAL PHOTOGRAPHER THEN?

26 MR. DARDEN:

YES.

27 THE COURT:

ALL RIGHT. SO YOUR OFFER OF PROOF IS THAT THIS IS RELEVANT TO A STATE OF MIND OF NICOLE BROWN SIMPSON --

28 MR. DARDEN:

AS WELL AS DENISE BROWN. MR. SHAPIRO HAS BEEN KIND ENOUGH TO SHARE WITH US HIS STACK OF -- HIS STACK OF NEWSPAPER ARTICLES THAT RELATE TO EVERYTHING THAT DENISE BROWN HAS EVER SAID ABOUT THIS CASE, AND I THINK WE NEED TO EXPLAIN TO THE JURY WHY MISS BROWN FELT INITIALLY THAT HER SISTER WAS NOT THE SUBJECT OF ABUSE. AND I THINK IT IS -- I THINK OTHER THINGS THAT HAVE BEEN SHOWN TO THE COURT AND TO COUNSEL, THINGS THAT HAVE ACTUALLY BEEN OBJECTED TO AND THINGS THAT THE COURT HAS ACTUALLY ADVISED THE PEOPLE TO PROCEED WITH CAUTION --

29 THE COURT:

THE PROBLEM --

30 MR. DARDEN:

-- WILL BECOME RELEVANT.

31 THE COURT:

MR. DARDEN, THE PROBLEM I HAVE, THOUGH, IS THAT YOU ARE OFFERING A PHOTOGRAPH FOR WHICH THERE IS NO FOUNDATION AS TO DATE, TIME AND A CONNECTION WITH ANY ONE OF THE 1101(B) INCIDENTS. THAT IS YOUR PROBLEM.

32 MR. DARDEN:

THAT IS WHY I SAID I DON'T SEE IT AS AN 1101(B) ISSUE. I SEE IT AS A STATE OF MIND ISSUE FOR DENISE BROWN AND FOR NICOLE BROWN. AND AS IT RELATES TO NICOLE BROWN'S STATE OF MIND, THE FACT THAT SHE IS KEEPING IN HER SAFE-DEPOSIT BOX THESE PHOTOGRAPHS, ALONG WITH HER WILL AND THESE NEWSPAPER ARTICLES, WE THINK IT IS ALL RELEVANT, NOT UNDER 1101(B), BUT WE THINK THAT NICOLE BROWN'S STATE OF MIND IS RELEVANT.

33 THE COURT:

ALL RIGHT. LET ME HEAR FROM THE DEFENSE.

34 (DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)
35 THE COURT:

MR. SHAPIRO.

36 MR. SHAPIRO:

THANK YOU VERY MUCH, YOUR HONOR. FIRST, YOUR HONOR HAS BEEN TOLD BY THE PROSECUTORS THAT THESE THREE PHOTOGRAPHS WERE FROM 1989 WHEN THEY WERE DISCUSSED DURING OUR HEARINGS REGARDING THE RELEVANCY OF DOMESTIC DISCORD ISSUES, AND WITH THAT WE HAD NO OBJECTION. WE CERTAINLY HAVE NO OBJECTION TO THE TWO PHOTOGRAPHS THAT WERE TAKEN ALLEGEDLY BY DENISE BROWN IN 1989 AS BEING SIMILAR PHOTOGRAPHS TO THOSE THAT HAVE BEEN SHOWN TO A PREVIOUS WITNESS AND TAKEN BY THE LOS ANGELES POLICE DEPARTMENT. HOWEVER, FOR THE PROSECUTOR TO COME TO COURT AND OFFER A WITNESS AND FLASH A PHOTOGRAPH WITHOUT KNOWING WHAT THAT WITNESS WAS GOING TO SAY ABOUT THE PHOTOGRAPH AND TELLING YOUR HONOR THAT WE HASN'T ASKED HER, I GUESS SHE IS GOING TO SAY THEY WERE 1985, I DON'T KNOW WHAT SHE WILL SAY, I HAVE TO ASK HER, IS SOMETHING THAT IS NOT PERMITTED BY OUR RULES OF PROCEDURE.

FURTHER, THE FACT THAT I GRATUITOUSLY TURNED OVER AN EXTENSIVE LEXIS SEARCH REGARDING DENISE BROWN AND HER PUBLIC STATEMENTS, BOTH IN NEWSPAPERS AS WELL AS ABOUT TEN TELEVISION SHOW INTERVIEWS THAT SHE DID, AS WELL AS EXCERPTS FROM A BOOK THAT SHE PARTICIPATED IN, WAS ONLY TO AID THE PROSECUTION, SO THEY COULD NOT CLAIM SURPRISE AND SO THAT THEY WOULD BE PREPARED SHOULD THOSE ISSUES COME UP. HOWEVER, I HAVE NOT YET ASKED A QUESTION, AND I DON'T SEE HOW THE PROSECUTION CAN POSSIBLY KNOW WHAT QUESTIONS I'M GOING TO BE ASKING, IF ANY, OF MISS BROWN.

37 THE COURT:

WELL, COUNSEL, MY CONCERN IS NOT NECESSARILY ANTICIPATING WHAT THE CROSS-EXAMINATION OF MISS BROWN IS GOING TO BE. MY CONCERN IS SHOWING THE JURY A RELATIVELY GRAPHIC PHOTOGRAPH OF THE VICTIM IN THIS MATTER, ONE OF THE VICTIMS IN THIS MATTER, WHO OBVIOUSLY APPEARS TO HAVE BEEN BEATEN FROM THIS PHOTOGRAPH, WITHOUT BEING ABLE TO TIE IT TO ANY OF THE INCIDENTS THAT WE ARE TALKING ABOUT HERE. THAT IS MY CONCERN.

38 MR. SHAPIRO:

THAT IS OUR CONCERN AND WE ARE RELUCTANT TO OBJECT, BUT WHEN THEY START PUTTING UP MATERIAL LETTING THE COURT KNOW THAT THIS IS A 1989 INCIDENT AND THEN SAYING THEY CAN'T ESTABLISH A FOUNDATION, THEY DON'T KNOW WHEN IT WAS TAKEN AND THEY HAVEN'T EVEN ASKED THEIR WITNESS, IS CONDUCT THAT SHOULD NOT BE PERMITTED. THE QUESTION IS NOW WHAT IS THE REMEDY THAT CAN BE DONE AFTER THIS PHOTOGRAPH HAS BEEN SHOWN AND DISPLAYED FOR SEVERAL MINUTES? AND WHEN I INITIALLY WENT UP TO SIDE BAR, YOUR HONOR WILL RECALL, THAT I ASKED THAT THE PICTURE BEEN TAKEN DOWN IMMEDIATELY BECAUSE OF THOSE CONCERNS, AND YOUR HONOR DID HAVE THAT PICTURE REMOVED, BUT IT STILL TOOK A PERIOD OF TIME, AND I BELIEVE THAT IRREPARABLE HARM HAS BEEN DONE, AND TREMENDOUS BIAS TO MR. SIMPSON, BY DELIBERATELY DISPLAYING A PHOTOGRAPH WHERE THEY KNEW THERE IS ABSOLUTELY NO FOUNDATION AND THAT IT COULD NOT BE ADMITTED INTO EVIDENCE AND WAS IMPROPER TO SHOW.

39 (DISCUSSION HELD OFF THE RECORD BETWEEN DEFENSE COUNSEL.)
40 MR. DARDEN:

YOUR HONOR, I --

41 MR. SHAPIRO:

ALSO, MR. COCHRAN REMINDS, ME REGARDING THE STATE OF MIND, DENISE BROWN'S STATE OF MIND IS IRRELEVANT TO THESE PROCEEDINGS. SHE IS NOT ON TRIAL. SHE IS A WITNESS SO FAR TO THREE EVENTS AND HER STATE OF MIND AND WHAT SHE FELT AND WHAT SHE WANTED TO DO IS TOTALLY IRRELEVANT TO ANYTHING. IF WE ARE SO SLOPPY AS TO BRING IT UP ON CROSS-EXAMINATION, THEN PERHAPS THE PEOPLE MIGHT CLAIM THE DOOR WAS OPENED, BUT TO TRY TO START WITH A PREEMPTIVE STRIKE AND TO ANTICIPATE BY BRINGING IN CLEARLY INADMISSIBLE MATERIAL IS NOT PERMITTED AND SHOULD NOT BE SANCTIONED BY THIS COURT AND THERE SHOULD BE A SERIOUS, SERIOUS MISCONDUCT SANCTION RENDERED AGAINST THE PROSECUTION FOR THIS BEHAVIOR.

42 THE COURT:

SUCH AS?

43 MR. SHAPIRO:

I THINK TO TELL THE JURY TO DISREGARD THE PHOTOGRAPH HAS NO EFFECT WHATSOEVER. I THINK A MORE SERIOUS SANCTION IS IN ORDER. AND I WOULD LIKE TO HAVE A MOMENT TO CONFER WITH MY COLLEAGUES AS TO WHAT THAT MIGHT BE AND ALSO TO PUT IN A CALL TO MR. DERSHOWITZ WHO IS VIEWING THESE PROCEEDINGS LONG DISTANCE.

44 MR. DARDEN:

MAY I RESPOND, YOUR HONOR?

45 THE COURT:

LET'S ALLOW COUNSEL TO CONFER FOR A MOMENT.

46 MR. DARDEN:

PARDON?

47 THE COURT:

LET'S ALLOW COUNSEL TO CONFER FOR A MOMENT.

48 (DISCUSSION HELD OFF THE RECORD BETWEEN DEFENSE COUNSEL.)
49 MR. DARDEN:

MAY I INTERJECT?

50 MR. SHAPIRO:

YOUR HONOR, WE WOULD LIKE TO TAKE A RECESS AT THIS POINT IN TIME TO CONFER WITH MR. DERSHOWITZ AND MR. UELMEN, AS WELL AS MY CO-COUNSEL HERE IN COURT.

51 THE COURT:

WELL, I THINK WE HAVE GOT ENOUGH HORSEPOWER HERE TO FIGURE THIS OUT, DON'T WE?

52 MR. SHAPIRO:

YOUR HONOR, YOU KNOW, I HAVE BEEN PRACTICING FOR A LONG TIME AND I HAVE NEVER SEEN ANYTHING QUITE THIS EXTRAORDINARY WHERE A PHOTOGRAPH THAT IS CLEARLY INADMISSIBLE IS JUST THROWN UP ON A GIANT SCREEN TELEVISION FOR THE JURY TO SEE --

53 MR. DARDEN:

YOUR HONOR --

54 MR. SHAPIRO:

-- WITHOUT EVEN KNOWING -- I MEAN, MR. DARDEN IS ON THE RECORD AS SAYING I HAVEN'T ASKED THE WITNESS ABOUT THIS, I DON'T KNOW WHAT HER ANSWERS WOULD BE.

55 MR. DARDEN:

I KNOW --

56 THE COURT:

HOLD ON. HOLD ON.

57 MR. SHAPIRO:

AND THE SANCTIONS -- CERTAINLY THE EASIEST SANCTION IS SIMPLY DISREGARD IT. WELL, MOST OF US WHO HAVE BEEN PRACTICING FOR A LONG PERIOD OF TIME KNOW THAT NOT ONLY IS THAT NOT EFFECTIVE, ALL IT DOES IS SERVE IN SOME INSTANCES TO REEMPHASIZE THE POINT, AND PERHAPS THERE SHOULD BE SOME SANCTIONS THAT ALL ISSUES OF DOMESTIC DISCORD BE STRICKEN FROM THIS RECORD AND THAT WE MOVE ON TO THE REAL ISSUES OF THIS CASE, AND THAT IS, WHO COMMITTED THESE HORRIBLE MURDERS. AND I THINK THAT MIGHT BE AN APPROPRIATE SANCTION UNDER THESE CIRCUMSTANCES, THAT THE PEOPLE WILL HAVE ALL OF THE EVIDENCE THAT THEY HAVE PRESENTED STRICKEN BECAUSE OF THIS TYPE OF CONDUCT.

58 MR. COCHRAN:

WOULD YOU GIVE US ABOUT TWO MINUTES?

59 MR. DARDEN:

YOU KNOW, THIS DOESN'T EVEN APPROACH ANYTHING THAT CAN BE CONSTRUED AS MISCONDUCT. THESE PHOTOGRAPHS WERE SHOWN TO THE COURT, THEY WERE SHOWN TO THE DEFENSE A MONTH AGO. THEY WERE PRESENTED HERE IN OPEN COURT AND THEY WERE SHOWN TO A WITNESS AND THEY WERE MARKED.

60 THE COURT:

MR. DARDEN, MR. DARDEN, PLEASE, LET ME ASK YOU A QUESTION. THE PROBLEM I HAVE IS THAT WE HAVE SHOWN THE JURY THIS PHOTOGRAPH WITHOUT A FOUNDATION AS TO WHERE AND WHEN THIS PHOTOGRAPH WAS TAKEN OR BY WHOM, AND WE DON'T KNOW IF IT TIES UP TO ANY OF THE INCIDENTS THAT I HAVE INDICATED ARE ADMISSIBLE UNDER 1101(B) RULING.

61 MR. DARDEN:

DID THE COURT -- DID THE COURT RULE IT INADMISSIBLE, THE RECOVERY OF THREE POLAROID PHOTOGRAPHS FROM A SAFE-DEPOSIT BOX?

62 THE COURT:

IT MAY BE IRRELEVANT.

63 MR. DARDEN:

OKAY.

64 THE COURT:

AND IF IT IS IRRELEVANT, THE INFLAMMATORY NATURE OF THAT PARTICULAR PHOTOGRAPH, WHICH YOU HAVE TO ADMIT IS A PRETTY STRONG PHOTOGRAPH --

65 MR. DARDEN:

THAT IS WHY WE HAVE THE LEARNED COUNSEL ON THE -- FOR THE DEFENSE, YOUR HONOR. THEY COULD HAVE OBJECTED. THEY HAVE AN EVIDENCE LIST JUST LIKE I HAVE.

66 THE COURT:

THAT IS WHY WE ARE HERE.

67 MR. DARDEN:

THAT'S RIGHT. THEY CERTAINLY DIDN'T. THEY DIDN'T OBJECT TO IT. THEY HAVE KNOWN ABOUT IT FOR A MONTH. THEY SAW IT LAST WEEK AND THEY DIDN'T OBJECT TO IT, BUT NOW THEY OBJECT TO IT TODAY AFTER THE JURY SEES IT.

68 THE COURT:

WELL, NOW WE FOUND OUT THERE IS A NO FOUNDATION.

69 MR. DARDEN:

THERE IS A FOUNDATION FOR IT. DENISE BROWN IS GOING TO TESTIFY TO HAVING SEEN THAT PHOTOGRAPH. IT ENDS UP IN A SAFE-DEPOSIT ALONG WITH THE 1989 PHOTOGRAPHS. THE DEFENSE HAS INDICATED THAT THEY ARE GOING TO CALL LENORE WALKER, AND IF THE COURT READS LENORE WALKER'S WRITING AS IT RELATES TO DOMESTIC VIOLENCE, THE FACT THAT THE VICTIM LEFT A TRAIL, A TRAIL JUST LIKE THE TRAIL LEFT BY NICOLE BROWN, IS VERY RELEVANT, EXTREMELY RELEVANT. IT IS GOING TO BE RELEVANT AS TO LENORE WALKER'S OPINION WHEN SHE ARRIVES.

70 THE COURT:

WHY ISN'T THIS A REBUTTAL ISSUE? WHY IS THIS IN THE CASE OF CHIEF IF IT IS NOT ONE OF THE 1101(B) ISSUES, ONE OF THE 1101(B) INCIDENTS THAT I HAVE ALLOWED?

71 MR. DARDEN:

BECAUSE IT IS RELEVANT AS TO DENISE BROWN'S STATE OF MIND.

72 THE COURT:

DENISE BROWN'S STATE OF MIND IS IRRELEVANT.

KEY QUOTE
73 MR. DARDEN:

IT IS ALSO RELEVANT AS TO --

74 THE COURT:

TAKE THAT TO THE BANK.

75 MR. DARDEN:

PARDON?

76 THE COURT:

TAKE THAT TO THE BANK.

77 MR. DARDEN:

IS THAT AN INDICATED RULING?

78 THE COURT:

IT IS A STRONG INCLINATION.

79 MR. DARDEN:

IN ANY EVENT --

80 THE COURT:

AT LEAST AT THIS POINT TO ESTABLISH -- DENISE BROWN IS HERE TO TESTIFY AS TO THE NATURE OF THE RELATIONSHIP AS TO THREE SPECIFIC INCIDENTS.

81 MR. DARDEN:

CAN I --

82 THE COURT:

THIS PHOTOGRAPH IS NOT RELATED TO ANY OF THOSE THREE INCIDENTS SO IT APPEARS TO ME TO BE IRRELEVANT. WHAT CONCERNS ME IS THE RATHER INFLAMMATORY NATURE OF THAT PHOTOGRAPH AND TO SHOW IT TO THE JURY WITHOUT ANY FOUNDATION FOR IT IS MORE THAN INAPPROPRIATE.

83 MR. DARDEN:

YOUR HONOR, EVERYONE UNDERSTANDS WHEN THOSE PHOTOGRAPHS WERE RECOVERED. EVERYONE UNDERSTANDS THAT IN THE PHOTOGRAPHS --

84 THE COURT:

DOESN'T MAKE IT ADMISSIBLE THAT THEY KNOW ABOUT IT, COUNSEL.

85 MR. DARDEN:

CAN I --

86 THE COURT:

GO AHEAD AND FINISH.

87 MR. DARDEN:

CAN WE PUT TWO PHOTOGRAPHS UP ON THE SCREEN FOR YOU FOR A MOMENT SO THAT I CAN JUST MAKE ONE OTHER POINT ON THE ISSUE OF THEIR FAILURE TO OBJECT?

88 THE COURT:

SURE.

89 MR. DARDEN:

MR. FAIRTLOUGH.

90 THE COURT:

ALL RIGHT. I SEE NO. 9 AND WHAT ELSE, MR. FAIRTLOUGH?

91 MR. FAIRTLOUGH:

ALSO NUMBER --

92 MS. CLARK:

10.

93 MR. FAIRTLOUGH:

-- 10, YOUR HONOR.

94 THE COURT:

ALL RIGHT. WHAT IS THE POINT?

95 MR. DARDEN:

THE POINT IS THIS: LOOK AT THE AGE OF NICOLE BROWN IN NO. 9 AND LOOK AT THE PHOTOGRAPH MARKED NUMBER -- WAS IT 11?

96 MS. CLARK:

10.

97 MR. DARDEN:

NO. 10. OKAY. NO ONE IS HIDING ANYTHING FROM THE DEFENSE. THEY KNOW THAT DENISE BROWN SAW THIS PHOTOGRAPH. THEY KNOW THAT DENISE BROWN -- OR RATHER, THAT THE PHOTOGRAPH WAS TAKEN OUT OF THE 1989 SAFE-DEPOSIT BOX. YOU CAN LOOK AT THE PHOTOGRAPHS AND CLEARLY DISCERN THAT SHE IS YOUNGER, SHE APPEARS YOUTHFUL IN PEOPLE'S 9 FOR IDENTIFICATION. IF THEY WANTED TO OBJECT TO THE INTRODUCTION OF THESE PHOTOGRAPHS, THEY COULD HAVE.

98 THE COURT:

THEY ARE.

99 MR. DARDEN:

YEAH, AFTER THEY HAVE BEEN SHOWN TO THE JURY. I MEAN DID I JUST THROW IT ON THE ELMO AND FLIP THE SWITCH AND HAVE IT JUMP OUT THERE IN FRONT OF THE JURY? OF COURSE NOT. I EVEN ASKED PERMISSION TO PUT THE THING ON THE ELMO. I MEAN, WHAT MORE DO THEY WANT? HOW MANY DAYS OR MONTHS DO THEY NEED TO FORMULATE AN OBJECTION? MAYBE MR. DERSHOWITZ SHOULD COME HERE FROM NEW YORK AND HELP THEM DECIDE WHEN TO OBJECT.

100 THE COURT:

I THINK HE IS IN BOSTON. BIG DIFFERENCE.

KEY QUOTE
101 MR. COCHRAN:

YOUR HONOR, IF I MIGHT RESPOND?

102 MR. DARDEN:

YOUR HONOR, WHAT ABOUT THE TWO-ATTORNEY RULE? YOUR HONOR, WHAT ABOUT THE ONE-ATTORNEY RULE ON THE ISSUE?

103 THE COURT:

HE IS THE ONE WHO RESPONDED. ACTUALLY THAT IS INCORRECT. MR. SHAPIRO.

104 MR. COCHRAN:

I AM ADDRESSING A SLIGHTLY DIFFERENT ISSUE THAN WHAT MR. SHAPIRO --

105 THE COURT:

NO. WE ARE TALKING ABOUT THE SAME PHOTOGRAPH, COUNSEL.

106 MR. COCHRAN:

ALL RIGHT. BOB.

107 (DISCUSSION HELD OFF THE RECORD BETWEEN DEFENSE COUNSEL.)
108 MR. DARDEN:

THEY NEVER CEASE TO AMAZE ME. THEY HAVE MUCH MORE EXPERIENCE THAN WE HAVE ON THE PROSECUTION SIDE, YOUR HONOR. MUCH MORE TRIAL EXPERIENCE.

109 THE COURT:

MR. DARDEN, THANK YOU. MR. SHAPIRO.

110 MR. SHAPIRO:

YOUR HONOR, THE PROSECUTION, DURING THEIR PRESENTATION ON THESE ISSUES, TOLD YOUR HONOR THESE PHOTOGRAPHS WERE 1989. I DON'T THINK THERE IS ANYTHING MORE TO SAY. IF WE ARE GOING TO CALL AN EXPERT IN AS TO BEING ABLE TO TELL THE AGE OF A WOMAN WHEN SHE HAS BEEN OUT AT A NEW YEAR'S PARTY AND ACCORDING TO THE EVIDENCE BEEN DRINKING AND BEEN INVOLVED IN A DOMESTIC DISPUTE AND THEN SHOW A PICTURE OF HER MADE UP, THAT COULD BE THE NEXT DAY AFTER. I DON'T THINK THERE IS ANY ROOM FOR ANY DOUBT THAT THIS COURT HAS BEEN TOLD, COUNSEL HAS BEEN TOLD, AND I WOULD LIKE MR. DARDEN TO TELL YOUR HONOR THAT HE DIDN'T TELL YOU THESE WERE ALL 1989.

111 MR. DARDEN:

THESE WERE ALL --

112 (DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)
113 MR. DARDEN:

ARCHIVED IN '89. THEY ALL RELATE TO THE 1989 INCIDENT. I THINK THAT IS THE ONLY CONCLUSION WE CAN DRAW, GIVEN WHAT WAS CONTAINED IN THE SAFE-DEPOSIT BOX, JUDGE. I MEAN, IT IS CLEAR TO ME THAT WHAT NICOLE BROWN WAS DOING WAS, ONE, IDENTIFYING HER FUTURE MURDERER, HER FUTURE KILLER, AND SHE WAS TRYING TO ESTABLISH FOR US, FOR MYSELF AND MR. GORDON AND MISS CLARK, PROOF OF A PATTERN OF ABUSE AND --

114 THE COURT:

WELL, MR. DARDEN, THAT MAY VERY WELL BE, BUT I THINK THAT COMES IN THE PEOPLE'S REBUTTAL CASE AFTER YOU SEE WHAT DR. WALKER SAYS, AFTER YOU HAVE ESTABLISHED THAT THROUGH YOUR OWN EXPERTS AND THROUGH THE CROSS-EXAMINATION OF DR. WALKER. BUT TO THROW UP A PHOTOGRAPH THAT WE CAN'T DATE TO ANY OF THE INCIDENTS THAT I HAVE ALLOWED IS NOT APPROPRIATE. THAT IS THE COURT'S RULING.

115 MR. DARDEN:

WELL, I THINK THEIR FAILURE TO OBJECT --

116 THE COURT:

NO, NO.

117 MR. DARDEN:

-- IS A WAIVER.

118 THE COURT:

COUNSEL, WHEN THE COURT ALLOWS 1101(B) EVIDENCE, YOU HAVE TO BE -- YOU, AS THE PROSECUTION, HAVE TO BE VERY CONSERVATIVE AS TO HOW YOU GO ABOUT DOING THAT. IF YOU CAN'T TIE THIS PHOTOGRAPH TO ANY ONE OF THOSE THREE INCIDENTS THAT DENISE BROWN CAN TESTIFY TO, THAT PHOTOGRAPH IS NOT COMING IN. ALL RIGHT.

119 MR. SHAPIRO:

MAY I ADDRESS THE COURT ON SANCTIONS, YOUR HONOR?

120 THE COURT:

YES.

121 MR. SHAPIRO:

YOUR HONOR, THE REASON THAT ONE MIGHT ASSUME THAT THAT PHOTOGRAPH WAS THROWN UP RELATES BACK TO THE TESTIMONY OF A POLICE OFFICER NAMED EDWARDS WHO TESTIFIED THAT HE TOOK PHOTOGRAPHS, BUT THE PHOTOGRAPHS DID NOT ADEQUATELY DEPICT THE INJURIES AS HE OBSERVED THEM BECAUSE THEY WERE TAKEN WITH POLAROID FILM AND BECAUSE NICOLE BROWN SIMPSON DID NOT WANT TO GO DOWNTOWN FOR PROPER PHOTOGRAPHS.

122 THE COURT:

I THOUGHT WE WERE TALKING ABOUT SANCTIONS.

123 MR. SHAPIRO:

WELL, I'M LEADING TO THAT. THE INFERENCE NOW IS THIS IS THE WAY SHE REALLY LOOKED IN 1989, AND I THINK THE SANCTIONS SHOULD BE THAT THE JURY SHOULD STRIKE FROM THEIR DELIBERATIONS ANY REFERENCE TO AN INCIDENT IN 1989, ANY REFERENCE TO ANY INJURIES THAT WERE SUFFERED BY NICOLE BROWN SIMPSON, AND ANY PHOTOGRAPHS THAT THEY HAVE SEEN OR ANY TESTIMONY DEPICTING THOSE INJURIES.

124 THE COURT:

ALL RIGHT.

125 MR. DARDEN:

YOUR HONOR, WHEN WE BEGAN THIS TRIAL THE COURT ORDERED THE DEFENSE TO PROVIDE US AN OPPORTUNITY TO LOOK AT THEIR EXHIBITS AND WE WERE GIVEN A NANOSECOND TO DO THAT, AND WHEN WE REALIZED THERE WAS A PROBLEM WITH ONE OF THOSE EXHIBITS AND OBJECTED, THE COURT FOUND THAT WE HAD WAIVED THE RIGHT TO OBJECT BECAUSE THE OBJECTION WAS UNTIMELY, AS THE COURT RULED. I THINK THE COURT SHOULD FIND THE SAME IN THIS SITUATION. THEY KNEW WHAT EXHIBIT 9 WAS. THEY HAVE SEEN IT, THEY HAVE IT IN THEIR HAND, THEY HAVE POSSESSED IT. IT WAS AN ISSUE IN THE DV HEARINGS. I MEAN TO SANCTION US NOW --

126 THE COURT:

DO YOU HAVE A FOUNDATION FOR THIS PHOTOGRAPH?

127 MR. DARDEN:

YES. IT IS A PHOTOGRAPH THAT DENISE BROWN SAW IN THE EIGHTIES AT ROCKINGHAM.

128 THE COURT:

DOESN'T HELP US. THANK YOU.

129 MR. DARDEN:

I'M SORRY, DID YOU SAY SOMETHING, MR. COCHRAN?

130 (SHAKES HEAD FROM SIDE TO SIDE.)
131 THE COURT:

LET'S HAVE THE JURY, PLEASE.

132 MR. DARDEN:

WOULD THE COURT KINDLY INDICATE TO US WHAT THE COURT INTENDS TO TELL THE JURY?

133 THE COURT:

YOU WILL SEE IN ABOUT THIRTY SECONDS.

KEY QUOTE
134 MR. DARDEN:

NO.

Temperature

tense

Key Quotes (5)

Lance A. Ito
DENISE BROWN'S STATE OF MIND IS IRRELEVANT. TAKE THAT TO THE BANK.
Ito's blunt, definitive rejection of Darden's primary theory for admitting the photograph — one of the sharpest rulings of the hearing.
Robert Shapiro
I BELIEVE THAT IRREPARABLE HARM HAS BEEN DONE, AND TREMENDOUS BIAS TO MR. SIMPSON, BY DELIBERATELY DISPLAYING A PHOTOGRAPH WHERE THEY KNEW THERE IS ABSOLUTELY NO FOUNDATION AND THAT IT COULD NOT BE ADMITTED INTO EVIDENCE AND WAS IMPROPER TO SHOW.
Shapiro frames the photo display as deliberate prosecutorial misconduct, not a good-faith mistake, laying the groundwork for sanctions.
Christopher Darden
MAYBE MR. DERSHOWITZ SHOULD COME HERE FROM NEW YORK AND HELP THEM DECIDE WHEN TO OBJECT.
Darden's frustration boils over — he argues the defense's delay in objecting was strategic, waiting until the jury had already seen the photo.
Lance A. Ito
I THINK HE IS IN BOSTON. BIG DIFFERENCE.
Ito's dry correction of Darden's Dershowitz geography — a rare moment of levity in a heated exchange, and a subtle put-down.
Lance A. Ito
YOU WILL SEE IN ABOUT THIRTY SECONDS.
Ito refuses to preview his jury instruction for Darden, asserting courtroom control with characteristic terseness.

Evidence (5)

People's 9
Polaroid photograph of Nicole Brown Simpson, appearing to depict injuries; film manufactured circa 1978-79; recovered from Nicole's safe-deposit box alongside 1989 photos and a Herald-Examiner newspaper article
Displayed to jury without foundation, then challenged and excluded by Ito
People's 10
Polaroid photograph, film manufactured 1988-89; Denise Brown will testify she took it herself
Discussed in chambers argument; admissibility contingent on tying to approved 1101(B) incidents
People's 11
Third Polaroid photograph from safe-deposit box grouping
Referenced in admissibility argument; same foundational problems as People's 9
Informal
Herald-Examiner newspaper article from 1989 describing January 1, 1989 charges and beating, recovered from Nicole's safe-deposit box
Referenced as contextual evidence establishing the 1989 grouping of materials
Informal
Lexis search of Denise Brown's public statements — newspaper articles, ~10 TV interview excerpts, and book excerpts — provided by Shapiro to prosecution
Discussed as context for why prosecution sought to explain Denise Brown's initial denials of abuse

Notable Exchanges (4)

Lance A. ItoChristopher Darden
Extended back-and-forth over whether People's 9 could be admitted on a state-of-mind theory rather than as a 1101(B) incident. Ito repeatedly challenged Darden to establish foundational dating and connection; Darden pivoted theories multiple times (state of mind, pattern of abuse, Lenore Walker rebuttal setup) before Ito flatly ruled Denise Brown's state of mind irrelevant.
adversarial
Robert ShapiroLance A. Ito
Shapiro argued for severe sanctions — not just a jury instruction to disregard, but striking all 1989 domestic violence evidence from the record — on the grounds that the prosecution knowingly displayed an inadmissible photo. Ito listened but appeared skeptical of the most extreme remedy.
strategic
Christopher DardenRobert Shapiro
Darden argued the defense waived any objection by knowing about the photo for a month, seeing it during prior hearings, and waiting until the jury had already viewed it. Shapiro countered that the prosecution had represented the photo as a 1989 exhibit and had no foundation even by their own admission.
heated
Lance A. ItoRobert Shapiro
When Shapiro asked for a recess to confer with Dershowitz and Uelmen by phone, Ito quipped: 'I think we've got enough horsepower here to figure this out, don't we?' — declining the request.
dry/controlling

Light Moments (4)

Lance A. Ito
When Darden said Dershowitz should 'come here from New York' to help the defense decide when to object, Ito deadpanned: 'I think he is in Boston. Big difference.'
Lance A. Ito
'I think we've got enough horsepower here to figure this out, don't we?' — Ito declining Shapiro's request for a recess to phone consult Dershowitz and Uelmen.
Lance A. Ito
When Darden asked the court to preview its jury instruction, Ito replied 'You will see in about thirty seconds.' Darden responded simply: 'No.'
Johnnie Cochran
Cochran's only visible contribution to the hearing: shaking his head from side to side when Darden addressed him directly.

Credibility Attacks (2)

⚔ Christopher Darden
prosecutorial misconduct allegation
Shapiro argued Darden deliberately displayed People's 9 knowing it lacked foundation and was inadmissible, characterizing it as a preemptive strike designed to inflame the jury, and demanded serious sanctions beyond a mere curative instruction.
⚔ Defense team
strategic late objection / waiver argument
Darden argued the defense had known about People's 9 for over a month, saw it in prior hearings, watched it displayed to a previous witness without objecting, and only raised an objection after the jury had already seen it — framing their conduct as tactical rather than principled.

Objections

None recorded
Proceeding 4643 • 134 utterances
Criminal Trial
Department 103
⚖️ Start
📂 FEB 6, 1995 📄 Motion: photograph evidence ad
FEB 6, 1995 KRT DvH TD