📄 Opening statement discussion — Wednesday, January 25, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JAN\25\OPENING-STATEMENT-DISCUSSION.DOC
TRIAL
▲ Day 6 of 167

Opening statement discussion

Date: Wednesday, January 25, 1995 • Utterances: 50
With the jury at lunch recess, Judge Ito asks Hodgman to identify specific argumentative portions of Cochran's opening statement. Hodgman struggles to cite specifics on the spot and asks to defer until 1:30, while Ito cautions Cochran directly about his comments regarding Dr. Golden and the Faye Resnick deposition — calling much of it argumentative and flagging a hearsay problem with the deposition. The exchange devolves into a lively back-and-forth about 'dancing around' the Faye Resnick issue, with Bailey memorably interjecting that 'disingenuous' means 'liar.'
1 (BRIEF PAUSE.)
2 THE COURT:

MR. OLSEN, WOULD YOU REMAIN, PLEASE. MR. BANCROFT, WOULD YOU REMAIN, PLEASE.

3 (BRIEF PAUSE.)
4 (THE JURY EXITS THE COURTROOM AND THE FOLLOWING PROCEEDINGS WERE HELD IN OPEN COURT:)
5 THE COURT:

ALL RIGHT. COUNSEL, THE JURY HAS WITHDRAWN FROM THE COURTROOM. MR. HODGMAN, DO YOU WANT TO MENTION SPECIFIC LANGUAGE THAT YOU ARE OBJECTING TO WAS ARGUMENTATIVE IN OPENING STATEMENTS?

6 MR. HODGMAN:

YOUR HONOR, THERE WAS SO MUCH THAT WAS ARGUMENTATIVE IN NATURE THAT IT IS HARD TO REALLY EVEN IDENTIFY SPECIFIC PORTIONS RIGHT NOW. AGAIN, YOUR HONOR, THERE WAS RANK HEARSAY THAT WAS REFERRED TO, THERE WAS -- AND I THINK THE COURT ITSELF CAN RECOGNIZE AN ARGUMENTATIVE OPENING STATEMENT WHEN IT HEARS ONE. AS I INDICATED TO THE COURT AT SIDE BAR, I HESITATE TO EVER OBJECT WHEN DEFENSE COUNSEL -- WHEN DEFENSE COUNSEL IS MAKING AN OPENING STATEMENT, OR EVEN MAKING AN ARGUMENT. AN ARGUMENT OBVIOUSLY IS A DIFFERENT PHASE OF THE CASE AND A DIFFERENT CONTEXT; HOWEVER, IN OPENING STATEMENT THERE ARE CERTAIN PARAMETERS, AND IT WAS ONLY WITH GREAT RESTRAINT THIS MORNING THAT I EVEN STOOD TO OBJECT WHEN I DID. AND MY OBJECTIONS ARE NOTED IN THE RECORD AT PORTIONS WHERE I FELT WE HAD GONE FAR BEYOND THE BOUNDS, FAR BEYOND THE BOUNDS OF WHAT IS PERMISSIBLE IN OPENING STATEMENT. AND I WOULD SIMPLY ASK --

7 THE COURT:

WHY DON'T YOU JUST GIVE ME TWO OR THREE SPECIFICS.

8 MR. HODGMAN:

VERY WELL. YOUR HONOR, I'M GOING TO ASK FOR A CAVEAT TO ONE SPEAKER RULE. MR. GOLDBERG HAD TAKEN SOME NOTES FOR ME.

9 THE COURT:

WELL, THAT IS WHY WE HAVE THE ONE SPEAKER RULE. YOU ARE THE ONE MAKING THE OBJECTION, MR. HODGMAN, SO YOU NEED TO BE SPECIFIC ON WHAT YOUR OBJECTION IS.

10 (DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)
11 MR. HODGMAN:

VERY WELL, YOUR HONOR. MAY WE BE HEARD ON THIS ISSUE RIGHT AFTER WE RETURN FROM LUNCH? AND I WILL GO THROUGH AND I WILL ADDRESS FOR THE COURT THOSE PORTIONS WHICH I BELIEVE TO BE ARGUMENTATIVE OR HEARSAY. AND WHAT I'M ASKING FOR, YOUR HONOR --

12 THE COURT:

COUNSEL, ONE OF THE REASONS I'M GIVING YOU A REAL TIME TRANSCRIPT HERE IS SO THAT YOU CAN SEE THIS STUFF IN FRONT OF YOU, SO MR. HODGMAN, I REALIZE THE LENGTH OF THE OPEN STATEMENTS, SO I WILL GIVE YOU LEAVE TO DO THAT. BUT MR. COCHRAN, I WILL CAUTION YOU THAT THE LAST SEVERAL COMMENTS AT THE END OF YOUR STATEMENT ABOUT DR. GOLDEN AND WHY THE PROSECUTION ARE NOT CALLING HIM, ET CETERA, ET CETERA, A LOT OF THAT IS ARGUMENTATIVE THE WAY IT IS PHRASED. THE FACT THAT YOU ARE GOING TO SAY WE ARE GOING TO CALL THE WITNESSES TO SAY THIS WASN'T DONE AND THE STOMACH CONTENTS, BLAH, BLAH, BLAH, THERE IS A MORE REASONABLE WAY OF SAYING THAT. I MEAN, MR. HODGMAN'S COMMENTS IN MANY RESPECTS ARE PROBABLY WELL TAKEN AND I'M CONCERNED ABOUT HOW YOU ARE GOING TO GET THAT DEPOSITION IN OVER THE HEARSAY OBJECTION.

13 MR. COCHRAN:

IN THE MIDDLE OF THAT, I CAN RECALL, I SAID THAT SHE GAVE A DEPOSITION AND PERHAPS YOU WILL HEAR ABOUT THAT, BUT I THINK THERE IS SOME OTHER THINGS THAT WE CAN DO IN THAT REGARD BECAUSE THERE IS A DIVORCE DECREE.

14 THE COURT:

I UNDERSTAND THERE ARE OTHER WAYS WE CAN GET THAT IN.

15 MR. COCHRAN:

I THOUGHT ABOUT WHAT I'M SAYING.

16 THE COURT:

OKAY.

17 MR. COCHRAN:

THAT IS WHY WE MOVED ON AND NOT ONLY -- IF I DON'T THINK I CAN GET SOMETHING IN, I'M NOT GOING TO DO IT.

18 THE COURT:

MR. HODGMAN, YOU COME BACK WITH YOUR SPECIFICS.

19 MR. HODGMAN:

WELL, I WAS GOING TO RECOMMEND TO THE COURT NOW, LET'S SEE IF WE CAN ADDRESS SOME OF THIS RIGHT NOW, BECAUSE WHAT IS DONE IS DONE. WHAT THE JURY HAS HEARD, THE JURY HAS HEARD. I WILL COME BACK WITH MORE SPECIFICS, BUT WE CAN'T UNRING THE BELL. WHAT I WAS ASKING THE COURT FOR AND AM RESPECTFULLY ASKING THE COURT FOR IS THE VERY CAUTION THAT YOU ARE GIVING, BECAUSE I DON'T INTEND TO BE SILENT THIS AFTERNOON IF I HEAR HEARSAY OR ARGUMENT, AND I AM JUST GIVING FAIR NOTICE TO COUNSEL RIGHT NOW. AND I CAN COME BACK -- WE WERE GOING INTO DR. GOLDEN, AND I AGREE WITH THE COURT, THAT WAS SOUNDING AWFULLY ARGUMENTATIVE TO ME WHEN WE WERE ADDRESSING THE FAYE RESNICK ISSUE THIS MORNING AND THE NATURE THAT WENT DOWN, VERY ARGUMENTATIVE IN NATURE. THE DEPOSITION, RANK HEARSAY. THOSE ARE A FEW EXAMPLES, YOUR HONOR.

20 THE COURT:

WELL, THE FAYE RESNICK STUFF CAME AROUND TO THE FACT THAT IT IS CLOSE IN TIME WITH THE PERSONS DEPARTING AND IT WAS BROUGHT BACK INTO A CONTEXT. THAT WAS APPROPRIATE.

21 MR. HODGMAN:

YES, BUT YOUR HONOR, COUNSEL WAS --

22 THE COURT:

IT WAS ON THE EDGE. IT WAS ON THE EDGE, THERE IS NO DOUBT ABOUT THAT.

23 MR. HODGMAN:

BUT IN ADDITION, YOUR HONOR, LET'S PUT IT THIS WAY: I MEAN, COUNSEL IS DISINGENUOUS WITH REGARD TO --

24 MR. BAILEY:

THAT WORD MEANS LIAR.

KEY QUOTE
25 MR. COCHRAN:

WE DON'T USE THAT WORD.

26 MR. HODGMAN:

ANOTHER WAY OF PUTTING IT, MR. COCHRAN IS REAL CLEVER. HE IS ABLE COUNSEL AND HE WAS ABLE TO DANCE AROUND IT, BUT YOUR HONOR, WE MAY OR MAY NOT CALL FAYE RESNICK. IN LIGHT OF THE FACT WE HAD JUST BEEN AT SIDE BAR AND THE WAY THAT WAS DANCED AROUND, YOUR HONOR, THAT IS SIMPLY NOT FAIR. THERE WAS NO INDICATION WHETHER THEY ARE GOING TO CALL HER OR NOT, BUT IT ALLOWED SOME SEMBLANCE OF A SEGUE INTO GETTING THAT INFORMATION BEFORE THE JURY AT THIS TIME. THAT IS EXTREMELY PREJUDICIAL.

27 THE COURT:

WELL, IT IS A DANGEROUS PLACE TO BE FOR THE DEFENSE, FOR THEM TO SAY WE MAY CALL HER AND NOT CALL HER THAN FOR THE PROSECUTION TO SAY WE ARE NEVER GOING TO CALL HER. MR. COCHRAN DID DANCE AROUND, THOUGH. HE DIDN'T LAND ON IT.

28 MR. HODGMAN:

YOUR HONOR, MY POINT IS --

29 THE COURT:

YOU ARE BEING CAUTIONED HERE.

30 MR. COCHRAN:

I WAS GOING TO DANCE AROUND IT ANYWAY, YOUR HONOR, BECAUSE IT IS AN AREA THAT WE HAVEN'T MADE A FINAL DECISION.

31 THE COURT:

THERE ARE MANY LAND MINES.

KEY QUOTE
32 MR. COCHRAN:

THERE ARE MANY LAND MINES IN THIS AREA AND WHAT I INDICATED TO THE COURT, THAT WE HAVE, HOWEVER, TALKED WITH CHRISTIAN RIECHARDT WHO KNOWS AN AWFUL LOT AND HE WILL BE TESTIFYING. I DON'T KNOW WHAT COUNSEL IS TALKING ABOUT. THAT INTERVENTION IS VERY WELL. SHE WAS LIVING AT MISS BROWN'S HOME. SHE HAD THE INTERVENTION ON THE 8TH. FAYE RESNICK CONTINUED TO CALL. HE WAS WORRIED I WAS GOING TO BRING OUT SOMETHING ABOUT RELATIONSHIPS. I'M GOING TO DO THAT.

33 THE COURT:

WE ARE WAITING FOR THE TELEPHONE CALL AT NINE O'CLOCK IS WHERE IT EVENTUALLY WOUND UP.

34 MR. COCHRAN:

WHICH WAS VERY RELEVANT THAT NIGHT.

35 THE COURT:

TAKE A LOOK AT YOUR COMPUTER, TAKE IT WITH YOU, TELL ME WHAT IS THERE. MR. COCHRAN, I AM CAUTIONING YOU AT THIS POINT, WE ARE SLIDING HERE.

36 MR. COCHRAN:

I WILL TRY TO GET BACK ON POINT. I WILL NOT FOLLOW MISS CLARK YESTERDAY.

37 MR. SHAPIRO:

YOUR HONOR, MAY I RESPOND ON BEHALF OF MR. COCHRAN?

38 THE COURT:

NO, NOT ON BEHALF OF MR. COCHRAN.

39 MR. SHAPIRO:

MAY I MAKE SOME OBSERVATIONS?

40 THE COURT:

ONE ARGUMENT, ONE LAWYER. WE ALREADY CUT THE OTHER LAWYER OFF.

41 MR. COCHRAN:

CAN I SAY ONE THING, YOUR HONOR? THEY DID HAVE THREE PEOPLE INTERRUPTING ME, COUNSEL DID, YOUR HONOR, BUT IT IS OKAY, THEY ARE ALL GOOD FRIENDS, THEY ARE WHISPERING, BUT I THINK ONE OF THEM SHOULD INTERRUPT ONE AT A TIME.

42 THE COURT:

I AGREE.

43 MR. HODGMAN:

YOUR HONOR, WE WILL ADDRESS THIS AGAIN AT 1:30, BUT MAY COUNSEL AND I APPROACH ON AN ISSUE THAT I THINK THE COURT NEEDS TO ADDRESS REGARDING SOME PUBLIC RECORDS?

44 THE COURT:

SURE.

45 MR. HODGMAN:

THANK YOU.

46 (A CONFERENCE WAS HELD AT THE BENCH, NOT REPORTED.)
47 (THE FOLLOWING PROCEEDINGS WERE HELD IN OPEN COURT:)
48 (AT 12:10 P.M. THE NOON RECESS WAS TAKEN UNTIL 1:30 P.M. OF THE SAME DAY.)
49 (JANET M. MOXHAM, CSR NO. 4855, OFFICIAL REPORTER.)
50 (CHRISTINE M. OLSON, CSR NO. 2378, OFFICIAL REPORTER.)

Temperature

tense

Key Quotes (5)

F. Lee Bailey
THAT WORD MEANS LIAR.
Terse, cutting interjection after Hodgman calls Cochran 'disingenuous' — forces Hodgman to immediately rephrase and defuses the attack while shaming Hodgman in front of the judge.
William Hodgman
WE CAN'T UNRING THE BELL. WHAT I WAS ASKING THE COURT FOR AND AM RESPECTFULLY ASKING THE COURT FOR IS THE VERY CAUTION THAT YOU ARE GIVING.
Hodgman acknowledges the jury has already heard the argumentative opening and pivots to seeking prospective relief rather than a curative instruction.
Lance A. Ito
MR. COCHRAN DID DANCE AROUND, THOUGH. HE DIDN'T LAND ON IT.
Ito effectively defends Cochran's technique while still cautioning him — acknowledging the strategic footwork was deliberate and (barely) within bounds.
Johnnie Cochran
I WILL NOT FOLLOW MISS CLARK YESTERDAY.
Pointed dig at Marcia Clark's opening statement in the criminal trial, implying her approach set a bad precedent for argumentative openings.
Lance A. Ito
THERE ARE MANY LAND MINES.
Ito's shorthand warning to Cochran about the Faye Resnick territory — confirms the court is watching carefully.

Evidence (2)

Informal
Faye Resnick deposition referenced by Cochran in opening statement
Challenged by Hodgman as rank hearsay; Ito flags a hearsay admissibility problem; Cochran notes a divorce decree as alternative avenue
Informal
Real-time transcript of proceedings provided by Ito to counsel
Ito directs Hodgman to use it to identify specific argumentative passages

Notable Exchanges (4)

F. Lee BaileyWilliam Hodgman
Hodgman calls Cochran 'disingenuous'; Bailey immediately interjects 'THAT WORD MEANS LIAR,' forcing Hodgman to rephrase as 'Mr. Cochran is real clever.'
pointed
Lance A. ItoRobert Shapiro
Shapiro attempts to speak on Cochran's behalf; Ito shuts him down twice, invoking the one-speaker rule. 'ONE ARGUMENT, ONE LAWYER. WE ALREADY CUT THE OTHER LAWYER OFF.'
firm
Lance A. ItoJohnnie Cochran
Ito cautions Cochran specifically about Dr. Golden comments and Faye Resnick territory, using 'blah, blah, blah' to characterize Cochran's stomach-contents argument; Cochran defends his choices as deliberate and provisional.
strategic
Johnnie CochranWilliam Hodgman
Cochran complains that three prosecutors were interrupting him during his opening and only one should do so at a time; Ito agrees.
light

Light Moments (2)

Lance A. Ito
Ito uses 'blah, blah, blah' to summarize Cochran's stomach-contents argument when cautioning him about argumentative phrasing.
Johnnie Cochran
Cochran lodges a mock-aggrieved complaint that three prosecutors were whispering and interrupting him — 'but it is okay, they are all good friends' — drawing agreement from Ito.

Credibility Attacks (1)

⚔ Johnnie Cochran
conduct criticism
Hodgman calls Cochran 'disingenuous' for implying the defense might call Faye Resnick when no decision had been made, characterizing it as a deliberate end-run to get prejudicial information before the jury; Bailey's interjection neutralizes the attack.

Objections

None recorded
Proceeding 4485 • 50 utterances
Criminal Trial
Department 103
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📂 JAN 25, 1995 📄 Opening statement discussion
JAN 25, 1995 KRT DvH TD