📄 In chambers: motion scheduling — Monday, July 17, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JUL\17\IN-CHAMBERS-MOTION-SCHEDULING.DOC
TRIAL
▲ Day 116 of 167

In chambers: motion scheduling

Date: Monday, July 17, 1995 • Utterances: 47
A brief in-chambers scheduling session where the prosecution and defense arranged hearing dates for two pending motions: one to preclude defense expert Herbert McDonnell's testimony (due to alleged discovery violations and lack of foundation), and one regarding collateral impeachment witnesses related to Detective Fuhrman. The session also surfaced an urgent dispute over whether nurse Thano Peratis — who drew Simpson's blood sample — would testify live or be declared unavailable, with the defense seeking to use his preliminary hearing video and grand jury testimony instead.
1 (Appearances as heretofore noted.)
2 (Janet M. Moxham, CSR no. 4855, official reporter.)
3 (Christine M. Olson, CSR no. 2378, official reporter.)
4 (Pages 37050 through 37059, volume 188A, transcribed and sealed under separate cover.)
5 (The following proceedings were held in open court, out of the presence of the jury:)
6 THE COURT:

All right. Back on the record in the Simpson matter. Mr. Simpson is again present before the Court with his counsel, Mr. Shapiro, Mr. Cochran, Mr. Douglas, Mr. Bailey. The People are represented by Miss Clark and Mr. Kelberg and Miss Lewis. Good morning, counsel.

7 MS. LEWIS:

Good morning, your Honor. Your Honor, I'm here to simply schedule a hearing or two hearings on motions that were filed last week. One of those was filed by Hank Goldberg last Thursday to preclude the testimony of the Defense expert Herbert McDonnell for discovery violations, and as additional grounds, though it may not be addressed in the motion, lack of foundation for his testimony. Umm, that was served on counsel last Thursday, and I'm wondering--

8 THE COURT:

Excuse me, counsel. Can we have it quiet, please.

9 MS. LEWIS:

I'm wondering what the Court's convenience is on the scheduling. I should mention that I have listed him as potentially coming up as early as Wednesday, and since we feel that he should not be allowed to testify at all on a dual basis of inadequate foundation and discovery violations, I think this would be useful to both sides to resolve as soon as possible.

10 THE COURT:

Mr. Douglas, when do you anticipate this witness testifying?

11 MR. DOUGLAS:

Your Honor, I haven't seen this motion. I was asking Mr. Cochran if he had seen it.

12 MS. LEWIS:

It was served on Mr. Shapiro, I'm told, by Diana Martinez.

13 MR. SHAPIRO:

I think we got it Friday.

14 MS. LEWIS:

It was served Thursday.

15 THE COURT:

All right. Mr. Douglas, when do you anticipate this witness being called?

16 MR. DOUGLAS:

Your Honor, I anticipate his being called sometime on Wednesday. Can we have a hearing perhaps tomorrow afternoon?

17 MS. LEWIS:

What time, your Honor?

18 THE COURT:

1:30.

19 MS. LEWIS:

Thank you.

20 THE COURT:

Excuse me. One o'clock.

21 MS. LEWIS:

The other motion has to do with collateral impeachment witnesses regarding Detective Fuhrman. That was filed and served last Friday. The Defense initially had some such witnesses on a short list and then removed them and I'm not sure what their timing is, their expectation with regard to those witnesses, but we do need to have that resolved of course.

22 MR. DOUGLAS:

I think Friday, your Honor, will be an appropriate day for that motion. Those witnesses will likely not be called until next week.

23 THE COURT:

Let's see. That is the 21st. I seem to recollect we have another matter set the 21st in the afternoon.

24 THE CLERK:

That has been rescheduled.

25 THE COURT:

All right. We will make it the 21st then at 1:30. All right.

26 MS. LEWIS:

I think that does it. Thank you, your Honor.

27 THE COURT:

All right. Thank you, Miss Lewis. Mr. Douglas, you have a matter?

28 MR. DOUGLAS:

Your Honor, yes, and we can deal with it now or perhaps this afternoon. It concerns the testimony of the nurse Thano Peratis. I submitted this morning to the Court an affidavit from Mr. Peratis' doctor.

29 THE COURT:

Right. I received it. I have been in chambers with counsel on other matters. I have not had the opportunity to read it.

30 MR. DOUGLAS:

Yes, your Honor. In a nutshell, the motion seeks to declare Mr. Peratis unavailable and seeks to allow the introduction of his preliminary hearing testimony by video and portions of his grand jury testimony to be read. We would like that that to be resolved today so that we can edit the tape and have that presentation to the jury tomorrow afternoon.

KEY QUOTE
31 THE COURT:

Out of curiosity, what is your theory of admissibility of grand jury testimony?

32 MR. DOUGLAS:

That it is being offered against a party who introduced the testimony at the actual proceeding, the earlier proceeding. That is sworn testimony. We are simply having the grand jury portion to reinforce the preliminary hearing testimony concerning the amount of blood that was withdrawn, the approximately eight cc's, 1291-A(2) I believe it is.

33 THE COURT:

All right. Miss Clark.

34 MS. CLARK:

Yes, your Honor. I believe that Mr. Goldberg will be best able to address this. I think that we can take live testimony if Mr. Peratis, yes, I do. We have had contact with him in the past couple of days and it is not clear at all that this declaration by the physician is dispositive. I understand that the Defense does not want to allow Mr. Peratis to testify live to modify his testimony or explain what actually occurred when he drew Mr. Simpson's blood, but the People think it is very important that the jury get the truth of this matter and that the jury be informed of what actually transpired.

35 THE COURT:

We are talking about holding a 240 availability hearing here?

36 MS. CLARK:

Yes.

37 THE COURT:

All right. When do you anticipate being able to do that, since this was just filed today?

38 MS. CLARK:

If I may make a phone call--I was just handed this this morning as well. If I may call Mr. Goldberg, we have been working on this issue, as a matter of fact, to see when Mr. Peratis would be available and able to testify and in what manner. I can call Mr. Goldberg now. I can find out for the Court immediately.

39 THE COURT:

Why don't you just advise the Court after the lunch hour.

40 MS. CLARK:

Okay. Sure. Okay.

41 THE COURT:

And counsel today the lunch hour will go until 1:30.

42 MS. CLARK:

Okay. Thank you, your Honor.

43 THE COURT:

All right.

44 MR. DOUGLAS:

For the record, your Honor, Mr. Peratis had a triple bypass surgery.

KEY QUOTE
45 THE COURT:

Counsel, I understand that he has had some medical problems, but we will take it up when we have the hearing.

46 MR. DOUGLAS:

Very well.

47 MS. LEWIS:

I'm sorry, there was one other thing I wanted to mention that I forgot. In a footnote in my brief with regard to the collateral impeachment witnesses I asked to see the Court in camera ex parte and I'm going to submit that under seal.

KEY QUOTE

Temperature

procedural

Key Quotes (4)

Carl Douglas
In a nutshell, the motion seeks to declare Mr. Peratis unavailable and seeks to allow the introduction of his preliminary hearing testimony by video and portions of his grand jury testimony to be read.
The defense wanted to lock in Peratis's earlier testimony about the ~8cc blood draw rather than allow him to testify live and potentially modify or clarify that account.
Marcia Clark
I understand that the Defense does not want to allow Mr. Peratis to testify live to modify his testimony or explain what actually occurred when he drew Mr. Simpson's blood, but the People think it is very important that the jury get the truth of this matter.
Clark directly names the defense's strategic motivation — preventing Peratis from walking back or contextualizing his preliminary hearing statement about the blood volume.
Carl Douglas
For the record, your Honor, Mr. Peratis had a triple bypass surgery.
Establishes the medical basis for the unavailability claim; Ito cuts him off, signaling he'll rule after a proper hearing.
Cheri Lewis
I'm sorry, there was one other thing I wanted to mention that I forgot. In a footnote in my brief with regard to the collateral impeachment witnesses I asked to see the Court in camera ex parte and I'm going to submit that under seal.
An ex parte, sealed request regarding Fuhrman impeachment witnesses — hints at sensitive material the prosecution didn't want on the record.

Evidence (3)

People's 1291-A(2) (referenced by Douglas)
Grand jury testimony of Thano Peratis regarding the approximately 8cc of blood withdrawn from O.J. Simpson
Defense seeking to introduce at trial in lieu of live testimony
Informal
Affidavit from Thano Peratis's doctor, submitted by Carl Douglas that morning
Filed to support motion declaring Peratis unavailable to testify live
Informal
Preliminary hearing video testimony of Thano Peratis
Defense seeking to play for jury as substitute for live testimony

Notable Exchanges (3)

Carl DouglasLance A. Ito
Douglas argues Peratis should be declared unavailable due to triple bypass surgery; Ito declines to rule immediately and defers to an afternoon availability hearing, cutting Douglas off when he tries to elaborate on the medical situation.
strategic
Marcia ClarkLance A. Ito
Clark pushes back on the unavailability declaration, asserting the People have been in recent contact with Peratis and believe live testimony is possible — and desirable so the jury can hear what 'actually transpired' with the blood draw.
strategic
Cheri LewisCarl Douglas
Brief dispute over when the McDonnell motion was served — Lewis says Thursday, Shapiro says Friday — underscoring the tight scheduling crunch.
procedural

Credibility Attacks (3)

⚔ Thano Peratis
Prior inconsistent statement (implied)
The entire Peratis dispute centers on locking in his earlier testimony about drawing ~8cc of blood, which the defense preferred over any live testimony that might let him clarify or walk back that account — directly relevant to blood volume discrepancies at the heart of the evidence-planting theory.
⚔ Herbert McDonnell
Discovery violations / lack of foundation
Prosecution filed a motion to preclude the defense's blood-spatter expert entirely, alleging he was not properly disclosed and lacks adequate foundation for his opinions.
⚔ Mark Fuhrman
Collateral impeachment witnesses
Defense listed then removed collateral impeachment witnesses regarding Fuhrman; the prosecution filed a motion on the issue and sought a sealed ex parte conference, suggesting sensitive material about who those witnesses were or what they would say.

Objections

None recorded
Proceeding 6858 • 47 utterances
Criminal Trial
Department 103
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📂 JUL 17, 1995 📄 In chambers: motion scheduling
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