📄 Direct examination of Richard Walsh — Wednesday, July 19, 1995
Address:
C:\DEPT103\CRIMINAL\1995\JUL\19\DIRECT-EXAMINATION-OF-RICHARD-.DOC
TRIAL
▲ Day 118 of 167

Direct examination of Richard Walsh

Witness: Richard Walsh
Examiner: Johnnie Cochran
Called by: Defense • Date: Wednesday, July 19, 1995 • Utterances: 417
Richard Walsh, the writer and co-host of the OJ Simpson Playboy workout video filmed in May 1994, testified about the extensive physical limitations he observed in Simpson during production. He described Simpson as unable to complete a single bicep curl with 20-30 pound sandbags, having severely restricted lateral movement, and requiring ice bags on his knee and shoulder during breaks throughout a grueling 12-15 hour shoot day. The testimony was designed to support the defense theory that Simpson was too physically debilitated to have committed a violent double murder.
1 THE CLERK:

Thank you.

DIRECT EXAMINATION BY MR. COCHRAN

2 MR. COCHRAN:

Good afternoon, Mr. Walsh.

3 MR. WALSH:

Good afternoon.

4 MR. COCHRAN:

Mr. Walsh, you look familiar. I saw you on a video or something?

5 MR. WALSH:

Yes, you have.

6 MR. COCHRAN:

All right.

7 MR. WALSH:

Been watching TV for a day.

8 MR. COCHRAN:

What is your occupation, sir?

9 MR. WALSH:

I wrote, choreographed and co-hosted the OJ Simpson workout.

10 MR. COCHRAN:

And when did you do that, sir?

11 MR. WALSH:

We did that in May 1994.

12 MR. COCHRAN:

And prior to your writing it and co-hosting it, did you have occasion to go out and meet with or talk with OJ Simpson about his role in this particular exercise video?

13 MR. WALSH:

Yes. For several months prior to that.

14 MR. COCHRAN:

And you were doing this for what entity or what company?

15 MR. WALSH:

Playboy was the producers and the backers.

16 MR. COCHRAN:

All right. And they asked you to help with this; is that correct?

17 MR. WALSH:

Correct. They saw me in--on July 4 of 1993, I had a cable exercise TV show, and they happened to see me and had me in and talked about the idea and the concept and they hired me then. We actually made the contract in early 1994.

18 MR. COCHRAN:

All right. And is that your occupation, to--as a fitness expert?

19 MR. WALSH:

Not a fitness expert. I'm a fitness instructor. In my opinion, an expert is somebody who is an Md. Or Ph.D. in the exercise field. And I happen to just be a fitness instructor. I've been doing that for 16 years. I've done a number of video projects, TV shows and so forth. But on the video projects and TV shows that we--that I'm involved with, we always make sure we hire an expert who is either an Md. Or Ph.D., and he critiques every move I do and every word I say, and those are the experts.

20 MR. COCHRAN:

All right. Now, so that when you--you met with OJ Simpson regarding this particular project; is that correct?

21 MR. WALSH:

Correct.

22 MR. COCHRAN:

Did you become aware in meeting with Mr. Simpson of any physical limitations that he had?

23 MR. WALSH:

A few. Quite a few.

24 MR. COCHRAN:

What did you become aware of?

25 MR. DARDEN:

Objection. Calls for hearsay, your Honor.

26 THE COURT:

Foundation.

27 MR. COCHRAN:

How--in the course of your meeting with Mr. OJ Simpson, did you have occasion to talk with him about any physical limitations that he had? You can answer that yes or no.

28 MR. WALSH:

Yes.

29 MR. COCHRAN:

And did you have occasion--in writing this video, did you have to write it in such a way that there were things to be performed that he could do in that video?

30 MR. DARDEN:

Objection. Leading, your Honor.

31 THE COURT:

Sustained. Rephrase the question.

32 MR. COCHRAN:

Certainly, your Honor.

33 MR. COCHRAN:

In writing the video, did you have to take into account Mr. OJ Simpson's physical limitations, if any?

34 MR. WALSH:

Did I have to or did I?

35 MR. COCHRAN:

Yes. Did you?

36 MR. WALSH:

Yes, I did.

37 MR. COCHRAN:

And why did you do that?

38 MR. WALSH:

Well, when we began, the first time I met him, we discussed his situation, his injuries.

39 MR. DARDEN:

I'm going to object, your Honor. This is hearsay.

40 THE COURT:

It is. Sustained. Ask another question.

41 MR. COCHRAN:

Certainly.

42 MR. COCHRAN:

When you first met him, did you have occasion to learn about some injuries that he had?

43 MR. WALSH:

Yes.

44 MR. DARDEN:

It calls for hearsay.

45 MR. COCHRAN:

Well, he can answer that yes or no.

46 THE COURT:

Overruled.

47 MR. COCHRAN:

Thank you, your Honor.

48 MR. COCHRAN:

So you learned about some injuries that he had, right?

49 MR. WALSH:

Yes, I did.

50 MR. COCHRAN:

Okay. And were these injuries that he had, were they restricted to any particular part of his body? Can you answer that yes or no?

51 MR. WALSH:

Yes.

52 MR. COCHRAN:

And can you describe for the jury what you observed regarding Mr. Simpson's body and/or injuries?

53 MR. DARDEN:

Objection, your Honor. He is not an expert.

54 THE COURT:

Overruled.

55 MR. COCHRAN:

You may answer.

56 MR. WALSH:

Excuse me. Umm, well, he was sitting when I met him, and then he was a little concerned about the type of--

57 MR. DARDEN:

Objection, your Honor. Hearsay.

58 THE COURT:

Sustained. It is.

59 MR. COCHRAN:

Describe for us the injuries that you became aware.

60 MR. DARDEN:

Objection to the form of the question.

61 THE COURT:

Overruled. You can answer the question. What kind of injuries did you become aware of?

62 MR. WALSH:

Umm, his knee, his hand, shoulder. Can I keep going?

63 MR. COCHRAN:

Yes.

64 THE COURT:

Yes.

65 MR. WALSH:

He talked about a sore lower back.

66 MR. DARDEN:

Objection, your Honor.

67 THE COURT:

Wait, wait.

68 MR. WALSH:

Can I keep going?

69 THE COURT:

What did you personally become aware of through your own observations?

70 MR. WALSH:

Well, initially, he was sitting. And so when--

71 THE COURT:

Well, I assume this relationship went on through making the video.

72 MR. WALSH:

Well, I thought we were talking about the first time.

73 THE COURT:

No.

74 MR. WALSH:

Okay.

75 MR. COCHRAN:

Okay. You can kind of save some time and tell us all the things you became aware of.

76 MR. WALSH:

Okay. I became aware eventually of his knee, his back, his lower back in particular, his shoulder. He also spoke of some ankle problems.

77 MR. DARDEN:

Objection. Hearsay, your Honor.

78 THE COURT:

Sustained. Answer is stricken.

79 MR. COCHRAN:

Which portion? The last part?

80 THE COURT:

Ankle.

81 MR. COCHRAN:

Okay.

82 THE COURT:

But it's in the other record from Dr. Huizenga.

83 MR. COCHRAN:

Sure. Sure.

84 MR. COCHRAN:

Did--at any point, did you ever notice any other parts that you actually noticed of his body?

85 MR. WALSH:

When he stuck out his hand to shake hands.

86 MR. COCHRAN:

And what did you notice about that?

87 MR. WALSH:

Well, his hand was half like--looked like it was half closed.

88 MR. COCHRAN:

Did you find that unusual?

89 MR. WALSH:

I thought it was unusual.

90 MR. COCHRAN:

All right. Now, after you had this initial contact over a period of time with Mr. Simpson, did you have any doubt as to whether or not he was the right candidate for this video?

91 MR. DARDEN:

Objection. Leading.

92 THE COURT:

Overruled.

93 MR. COCHRAN:

Was there any question in your mind about whether OJ Simpson was the candidate for this, proper candidate?

94 MR. DARDEN:

It's irrelevant, your Honor.

95 THE COURT:

Overruled.

96 MR. WALSH:

Yes, I did.

97 MR. COCHRAN:

And what were your doubts, sir, if any?

98 MR. WALSH:

I thought he was too physically limited to be the co-host with me.

KEY QUOTE
99 MR. COCHRAN:

And why did you think that?

100 MR. WALSH:

Because I knew the type of tape that I was making needed, you know, not somebody real, real physically fit, but it needed someone who had the ability to at least be mobile laterally, forward and back up, using upper body muscle groups and so forth.

101 MR. COCHRAN:

Did you notice anything about Mr. Simpson's ability to move laterally or from side to side?

102 MR. WALSH:

It was--it was pretty limited.

103 MR. COCHRAN:

Now, was there--now, at some point, despite your reservations about Mr. Simpson's abilities here, did you proceed with the project with him?

104 MR. WALSH:

Yes, we did.

105 MR. COCHRAN:

And this particular video that we've seen or seen parts of, that was shot during the month of May of 1994?

106 MR. WALSH:

Correct. The actual shooting day of the--most of the video that you've seen has been on May 27th of--excuse me--May 25th, 1994. We tried to shoot the exercise segment in one day.

107 MR. COCHRAN:

All right. And any particular reason why you tried to shoot the exercise segment in one day?

108 MR. WALSH:

Yes.

109 MR. COCHRAN:

And why was that?

110 MR. DARDEN:

Objection. Irrelevant, your Honor.

111 THE COURT:

Overruled.

112 THE COURT:

You can answer the question.

113 MR. WALSH:

Tried to shoot in one day because through the course of preparing for the video, we didn't know if, one, if he would make it, and, two, if he did make it, would he be available to work the next day. Can I continue on about rehearsals?

114 THE COURT:

No. Next question.

115 MR. COCHRAN:

All right. So you had this concern. So you tried to do it all in one day?

116 MR. WALSH:

Yes.

117 MR. COCHRAN:

All right. Did you want to prescribe any kind of rehearsals so you would have a practice day one day and then do it the next day?

118 MR. WALSH:

I had rehearsal schedules for the group behind me, there were four people behind OJ and I, and then rehearsal schedules--OJ and I got together once or twice.

119 MR. COCHRAN:

Okay. Now, did OJ ever come dressed and participate in any rehearsals regarding this video?

120 MR. WALSH:

No.

121 MR. COCHRAN:

And did you ascertain why not?

122 MR. WALSH:

Yes.

123 MR. COCHRAN:

Why?

124 MR. DARDEN:

Objection. Hearsay.

125 THE COURT:

Sustained.

126 MR. COCHRAN:

Well, let me ask it this way. Did--did you ever request Mr. Simpson to come for a dress rehearsal as it were?

127 MR. WALSH:

Did I just--

128 MR. COCHRAN:

Ask him to do it?

129 MR. WALSH:

No. I just assumed that he would show up ready to exercise.

130 MR. COCHRAN:

All right. And did he show up?

131 MR. WALSH:

He showed up.

132 MR. COCHRAN:

All right. When he showed up, how was he dressed?

133 MR. WALSH:

Street clothes.

134 MR. COCHRAN:

Did you have a conversation with him as to why he was in street clothes?

135 MR. WALSH:

Yes, I did.

136 MR. COCHRAN:

You did? And did the subject matter of that concern his physical limitations if any?

137 MR. DARDEN:

Objection, your Honor.

138 THE COURT:

Sustained.

139 MR. COCHRAN:

All right. What--describe for this jury what you saw when you saw OJ show up for the dress rehearsal.

140 MR. WALSH:

What I saw or what I said?

141 MR. COCHRAN:

Yes. What you saw and what you observed.

142 MR. WALSH:

I saw him dressed in street clothes.

143 MR. COCHRAN:

All right. And what did you say.

144 MR. DARDEN:

Objection. Irrelevant and it's hearsay.

145 THE COURT:

Sustained.

146 MR. COCHRAN:

So you--did you have a conversation with OJ Simpson at that point?

147 MR. WALSH:

Yes.

148 MR. COCHRAN:

And in relation to May 25th, when was this dress rehearsal?

149 MR. WALSH:

I may be wrong, but I think it was May 24th, the day before.

150 MR. COCHRAN:

All right. And at any rate, did Mr. Simpson participate in the dress rehearsal on May 24th or whatever date it was?

151 MR. WALSH:

Not really.

152 MR. COCHRAN:

All right.

153 MR. WALSH:

He--

154 MR. COCHRAN:

What did he do, if anything?

155 MR. WALSH:

He watched a little bit. He tried on the clothes that he was going to wear the next day. He kind of moved a little bit, but that was about it. I mean, very--almost to the point of not really. Hardly at all.

156 MR. COCHRAN:

All right. Now, on May 25th or thereabouts, did you then come back and assemble the group to shoot the particular video?

157 MR. WALSH:

That was the first day of shooting.

158 MR. COCHRAN:

All right. And with regard to that, do you do something unusual when you--before you start a workout and before you're going to be on camera? Do you do something unusual for yourself?

159 MR. WALSH:

You're letting out all my secrets here. Yes, I do.

160 MR. COCHRAN:

Well, if you can tell us, and I guess everybody will know soon. What do you do before you start?

161 MR. DARDEN:

Objection, your Honor. Irrelevant.

162 THE COURT:

Overruled.

163 MR. COCHRAN:

I'll link it up.

164 THE COURT:

You can answer the question.

165 MR. WALSH:

Okay. Usually when I'm about to do a video project or a TV project and the outfit usually is a tank top or a leotard of some type, if you've ever been on a TV set or a video set or a movie set, there's these big lights and there's these reflector boards, and holding these reflector boards and lights down are big sandbags. And I always walk over to the sandbags right before I'm about to shoot, and I grab a couple of them and I start lifting like this (Indicating), and it gives you kind of a false size of your arms. It makes the arms a little bit bigger, makes the veins come out so that when we go out on the set and begin filming, you look a little bit--as the word would be--pumped up.

166 MR. COCHRAN:

All right. So when you were making a motion with your hands, as though you were doing curls with these bags?

167 MR. WALSH:

Right. I was doing curls with the sandbags.

168 MR. COCHRAN:

All right. And while you were doing the curls on this particular date of May 25th, did OJ Simpson come over to where you were?

169 MR. WALSH:

Yes, he did.

170 MR. COCHRAN:

And describe what you observed at that point.

171 MR. WALSH:

Well, he first asked what I was doing, and I told him, "This is a secret. You don't tell anybody this. This is my own secret." And so he grabbed a couple of the bags, and I told him about how it makes the arms look bigger. And he was standing with no back support, and I was doing curls and, you know, I'm not a strong man, but the bags probably weighed anywhere from 20 to 30 pounds, and I was doing a good amount of repetitions. And he's putting his hand--and much to my surprise, he couldn't even lift it. He couldn't do one bicep curl.

172 MR. COCHRAN:

And how many curls were you doing with these--when you talk about reps, "Reps" stands for repetitions; is that correct?

173 MR. WALSH:

Repetitions, correct.

174 MR. COCHRAN:

And how many--

175 THE COURT:

Excuse me. Mr. Walsh, if you would, would you allow Mr. Cochran to finish asking you the question before you start to answer. The reason is, the court reporter tries to take down the testimony and can only take one person at a time. All right. So take a breath, let him finish answering the question. That way, we don't have to do too many reps.

176 MR. WALSH:

And I'm sure she can see from the videotape that I'm a man of many words.

177 THE COURT:

Yes. Proceed.

178 MR. COCHRAN:

Thank you, your Honor.

179 MR. COCHRAN:

With regard to the--these reps, how many of these reps did you do, sir?

180 MR. WALSH:

Probably about 20.

181 MR. COCHRAN:

And how many did you see OJ Simpson do, if any?

182 MR. WALSH:

I didn't see him do any. He got about halfway up and then he needed a little assistance.

183 MR. COCHRAN:

All right. Now, in the course of your preparing or shooting the video that day, did you ever have occasion to either touch or bump into Mr. Simpson at all?

184 MR. WALSH:

There was one situation. It was at a break, whether they're relighting or redoing cameras or whatever it was, and they asked us to stay on the floor, stay in our spots because, as you saw the videotape, each person has a spot and--

185 MR. DARDEN:

Objection, your Honor. Pardon me, sir. This is nonresponsive.

186 MR. COCHRAN:

Your Honor, this is--he's responding seems to me.

187 MR. DARDEN:

The question called for a yes or no answer.

188 THE COURT:

Proceed.

189 MR. COCHRAN:

You may proceed, sir.

190 MR. WALSH:

Okay. So everybody has a spot. And so you kind of stay right there. And all of a sudden, I looked at OJ, and he was kind of coming at me like he was carrying a football, kind of like this (Indicating), which is kind of just moving slow. And as he got near me like he--I just kind of took my elbow like a football player would and kind of hit him, but very, very lightly.

191 MR. COCHRAN:

And when you--you struck his body at that point?

192 MR. WALSH:

Like his elbow or shoulder or arm or something like that.

193 MR. COCHRAN:

Did you see his reaction when that happened?

194 MR. WALSH:

He started literally flying. I mean not flying in the air, but he started jumping around and hobbling and he started screaming, "My knee, my knee."

KEY QUOTE
195 MR. DARDEN:

Objection, your Honor. Hearsay.

196 THE COURT:

Overruled. Proceed.

197 MR. WALSH:

So he started--

198 THE COURT:

Wait, wait. Next question. This is not a narrative. This is question and answer.

199 MR. COCHRAN:

All right.

200 THE COURT:

Ask the next question.

201 MR. COCHRAN:

All right. At that point--this happened during a break on the set that day; is that correct?

202 MR. WALSH:

Not necessarily at a break. Just in-between shots, in-between takes.

203 MR. COCHRAN:

All right. And did he--as you observed Mr. Simpson, did he seem to be kidding at that point with you?

204 MR. WALSH:

I think he was kidding--

205 MR. DARDEN:

Objection. Calls for speculation.

206 THE COURT:

Overruled.

207 MR. COCHRAN:

Did he seem to be kidding with you at that point?

208 MR. WALSH:

He was kidding up to that point, and then as I gave him a little elbow bump, he was no longer kidding. This is--

209 MR. COCHRAN:

All right. Now, with regard to this video, we saw some video here in court over the course of the last couple of days. And were there times between the video when there were breaks while you reset up and started over various things?

210 MR. WALSH:

Yes.

211 MR. COCHRAN:

And do you recall what, if anything, Mr. Simpson would do during these breaks, during the times when the camera wasn't on? Do you recall, was there a chair for him or anything of that nature?

212 MR. WALSH:

Towards the end, there was a chair for him.

213 MR. COCHRAN:

Okay. Describe that for the Court and the jury, what you observed.

214 MR. WALSH:

Well, towards the end, when the chair came out, it was after one situation. But--

215 MR. COCHRAN:

All right. Well, we'll get back to that situation. Tell us about the chair.

216 MR. WALSH:

Okay. When the chair came out, we kind of were on a set, might have been lifted, I don't know, 12, 14 inches off the ground. It was a hardwood floor. So gives you the feeling of being inside a gym or inside a fitness studio. And when we would take a break toward the end of the day, because it was somewhere around a 12- or 14-, maybe even a 15-hour day of doing this, they would put a chair right up there so he wouldn't even have to walk down, and, you know, they would slap some ice bags on him.

217 MR. COCHRAN:

And where would--ice bags?

218 MR. WALSH:

Ice bags.

219 MR. COCHRAN:

And where would these ice bags be placed?

220 MR. WALSH:

Definitely the knee. I think I even saw one time on the shoulder.

221 MR. COCHRAN:

Do you recall seeing that?

222 MR. WALSH:

Yes. Definitely the knee, and I think they had one that they were even rubbing on his shoulder, his arm or something.

223 MR. COCHRAN:

And this would be between the shots?

224 MR. WALSH:

This would be--right. As we were--we would do things, a run-through. And as you saw on the video, any time it came to push-ups, we did three rounds. And so when you got to the push-ups, that was end of round 1. And you'd do round 1 two or three or four times; and when you work with me, you do it as many times as you possibly can because we shoot it with three cameras, and I think we might even have used a fourth camera in some shots. And the more footage you have, it makes editing a little more difficult, but gives you an opportunity to have better production, better quality video in case you missed a shot.

225 MR. COCHRAN:

And that's when you get down to the finished product; isn't that correct?

226 MR. WALSH:

Correct.

227 MR. COCHRAN:

Now, during the course of this day that you've described where you're trying to shoot all in one day, was there a period of time where you could not do anything for an hour or two period of time?

228 MR. WALSH:

We had one problem. I'd rather not get into that, the actual nature of the problem. But there was a situation where we had to take about a two-hour break.

229 MR. COCHRAN:

All right. And during that two-hour break, was there a problem with Mr. Simpson?

230 MR. WALSH:

Yeah. He had mentioned--

231 MR. DARDEN:

Objection. Hearsay, your Honor.

232 THE COURT:

Sustained.

233 MR. COCHRAN:

Well, with regard to Mr. Simpson's physical abilities, did you notice any difference in him after a two-your cool down period of time? Can you tell us about--you can answer that.

234 MR. WALSH:

He had mentioned that if--

235 MR. DARDEN:

Objection, your Honor.

236 THE COURT:

Sustained.

237 MR. COCHRAN:

All right. You have to tell us what you observed.

238 MR. WALSH:

Okay. I observed as we began, he could hardly function.

239 MR. COCHRAN:

Now, you're talking about after the two-hour period of time?

240 MR. WALSH:

Correct.

241 MR. COCHRAN:

All right. Describe for us the difference between when you stopped and when you started some two hours later in your own words.

242 MR. WALSH:

I know what it was. But do you want me just to say what it was or--

243 MR. COCHRAN:

Tell us what it was.

244 MR. DARDEN:

Objection, your Honor.

245 THE COURT:

Rephrase the question, counsel.

246 MR. COCHRAN:

All right. Would you describe for us in your own words what you observed with Mr. Simpson after you started up after this two hours.

247 MR. WALSH:

Okay. In the beginning, prior to the two hours, he was a little bit more mobile. You know, not near as mobile as, you know, like a lot of the people who are in the video. But after the two-hour break, he was very, very tight.

248 MR. COCHRAN:

And how did this tightness manifest itself, if you can describe that for us?

249 MR. DARDEN:

Objection. Competency.

250 THE COURT:

Overruled.

251 MR. WALSH:

Sometimes when muscles are warm and loose when you're exercising, you sit for a while, like sometimes even if you get off an airplane or out of your car after a long ride and you get up, you're very stiff and very tight. And that was what I observed.

252 MR. COCHRAN:

All right. Now, you didn't see Mr. Simpson the day after he shot this video, did you, the day after the 26th of May, did you?

253 MR. WALSH:

Yes, I did.

254 MR. COCHRAN:

Did you see him? Did you notice anything about how he appeared on that date?

255 MR. WALSH:

I didn't spend a lot of time speaking with him that day.

256 MR. COCHRAN:

All right. Now, at the end of the day, at the end of the time you finished this particular shoot, can you describe for us again your observations of him and his appearance at that time and how he appeared to you?

257 MR. WALSH:

Relieved. I mean, exhausted and relieved. I think everybody was pretty tired at the end of that day.

258 MR. COCHRAN:

All right. Now, with regard to this video, you of course have seen the finished product that was merchandised; is that correct?

259 MR. WALSH:

I have seen the finished product, right.

260 MR. COCHRAN:

Okay. And there were also some rough cuts or some--

261 MR. WALSH:

Out-takes.

262 MR. COCHRAN:

--out-takes; is that correct? And in that connection, I would like you--prior to your coming to the stand today, I asked you to show us or to look at a particular portion of the video which I don't think we've seen this part. I don't want to spend much time for the jury, but is there a particular portion where you are doing some stretching exercises?

263 MR. WALSH:

Correct.

264 MR. COCHRAN:

And does this stretching exercises show Mr. Simpson attempting to stretch?

265 MR. WALSH:

Correct.

266 MR. COCHRAN:

And I'm going to ask now--

267 MR. COCHRAN:

Your Honor, I think--I'm going to find out if this has been marked. This is part of the exhibit 124 I believe, your Honor.

268 MR. HARRIS:

124.

269 MR. DARDEN:

I understand it wasn't. I'll take Howard's word for it.

270 THE COURT:

As will i.

271 MR. COCHRAN:

Exhibit number 521, your Honor.

272 THE COURT:

Proceed.

273 MR. COCHRAN:

Is this cued up, Mr. Harris?

274 MR. COCHRAN:

All right. I'm going to ask you and the jury to take a look at a particular portion of exhibit 521, which is one of the People's exhibits, and I'm going to ask you some questions about it.

275 MR. DARDEN:

Is that without the volume, your Honor?

276 THE COURT:

No. It's with the sound.

277 MR. COCHRAN:

Just like it was when Mr. Kelberg played it.

278 THE COURT:

With the sound. Proceed.

279 (At 2:21 P.M., People's exhibit 521, a videotape, was played.)
280 MR. COCHRAN:

What are we seeing now?

281 MR. WALSH:

Just doing some stretches for the lower back and lats and warm up.

282 THE COURT:

1550.

283 MR. COCHRAN:

1550.

284 MR. WALSH:

Here it is I think.

285 MR. COCHRAN:

Can you stop it there?

286 MR. COCHRAN:

All right. Now, what, if anything, happened when he tried to do this particular exercise we're demonstrating now?

287 MR. WALSH:

He has an inability to stretch this position. What we're doing is extending the--as you can see from the people behind him, we're extending the left hamstring with the heel on the floor and the toe up as we prepare to do the activity so we can loosen the hamstring, loosen the lower back and avoid pulled muscles. He cannot seem to bend either the left or right knee. And part of writing this, I used some of his injuries and wrote alternative ways of working out. If you think about the people in the world, everybody may have a shoulder problem, an elbow problem, a knee problem. It doesn't exclude them from exercising. There should be alternative ways of exercising. That's something I try to bring to the forefront in this video.

288 MR. COCHRAN:

All right. So you were aware of these limitations and tried to write that into it; is that correct?

289 MR. WALSH:

Right. This was a hamstring stretch from a standing position that we're going to put him in.

290 MR. COCHRAN:

All right. Your Honor, so the record is clear, we're at 15:51:43 at this point where we've stopped it.

291 THE COURT:

Yes.

292 MR. COCHRAN:

And you tell us how much further this should go, this goes on, this particular stretch aspect.

293 MR. WALSH:

Do you mind if I let it go for like an hour?

294 MR. COCHRAN:

Well, no. Maybe--I don't think the Judge and jury would like that. So we'll go just as long as it's relevant.

295 MR. WALSH:

All right.

296 MR. COCHRAN:

All right. We'll proceed now. Can I stop right there?

297 MR. COCHRAN:

There's a lady who seems to be in very good shape right behind Mr. Simpson. Is she doing it the way you would want a particular participant to do it?

298 MR. WALSH:

She's doing that the correct way.

299 MR. COCHRAN:

And then you have to characterize that with the way Mr. Simpson is doing it?

300 MR. WALSH:

Right.

301 MR. COCHRAN:

All right. You may continue on.

302 MR. WALSH:

I think that's the end of the stretching portion. Yeah. We're going into push-ups here.

303 MR. COCHRAN:

All right. Now, there are I presume other stretching scenes which are pretty illustrative of what we just saw; is that right?

304 MR. WALSH:

I believe so.

305 MR. COCHRAN:

Where it would further indicate the problems he was having on that date?

306 MR. WALSH:

I believe so.

307 MR. COCHRAN:

All right. Well, I don't want to bore the jury. So I'm going to skip down to something else. Is that all right with you?

308 MR. WALSH:

It's fine with me.

309 MR. COCHRAN:

Is it fine with you, your Honor?

310 THE COURT:

Perfect.

311 MR. COCHRAN:

I knew you'd say that. (At 2:25 P.M., the playing of the videotape was concluded.)

312 MR. COCHRAN:

I want to now--in addition to this video, and we've seen a lot of this particular video in the aerobics part of it, was there also a part where Mr. Simpson sits behind a desk and talks about kind of sedentary exercises and things like that?

313 MR. WALSH:

Right. There's a scene from an office, a simulated office where part of the tape, the first half hour of the tape or 30 minutes, whatever it was, was aerobic activity, and the second half hour of the tape was little segments of things you can do to stay loose or physically fit a little bit while you're in the office or on an airplane or a hotel room or so forth.

314 MR. COCHRAN:

And we're going to ask Mr. Harris to cue up--first of all, I think the airplane scene, your Honor, I'm not sure, your Honor, this has been marked yet. This is not marked. So I'd like to mark this as the Defendant's next in order if the Court pleases.

315 THE COURT:

All right. Is this the commercial video itself?

316 MR. COCHRAN:

I think this is part of the commercial video, yes, your Honor. The next two will be.

317 THE COURT:

All right.

318 MR. COCHRAN:

That will be 1255?

319 THE COURT:

1255.

320 MR. COCHRAN:

We'll make this 1255. All right.

321 (Deft's 1255 for id = videotape)
322 MR. COCHRAN:

And I'm going to ask you to take a look at 1255, this particular portion of the video and tell us what is taking place.

323 MR. WALSH:

Okay.

324 (At 2:26 P.M., Defendant's exhibit 1255, a videotape, was played.)
325 MR. DARDEN:

Your Honor, this is irrelevant.

326 THE COURT:

Overruled.

327 MR. COCHRAN:

As far as Richard, who is he talking about?

328 MR. WALSH:

Me.

329 MR. COCHRAN:

All right. And then you then proceed to do some exercises where you're standing?

330 MR. WALSH:

Correct.

331 MR. COCHRAN:

On the plane?

332 MR. WALSH:

Correct.

333 (At 2:29 P.M., the playing of the videotape was concluded.)
334 MR. COCHRAN:

All right. And did you write the portion that Mr. Simpson gave there also?

335 MR. WALSH:

I wrote the exercise.

336 MR. COCHRAN:

You wrote the exercises? And when you talked to Mr. Simpson about his participation in the video, did he want to participate in this kind of video as opposed to the aerobics kind?

337 MR. DARDEN:

Objection, your Honor. Hearsay.

338 THE COURT:

Sustained.

339 MR. COCHRAN:

You can't answer that. All right. Now, there was still a further one--

340 MR. COCHRAN:

And Mr.--I'll ask him to find that. All right. He's going to try to get the last segment, your Honor.

341 MR. COCHRAN:

With regard--you mentioned earlier there was a scene in a simulated office; is that correct?

342 MR. WALSH:

Correct.

343 MR. COCHRAN:

And what is depicted in this scene at the simulated office, if you recall?

344 MR. WALSH:

I recall he did a bunch of exercises that you can do. Most of them are from stretching positions that you could do if you were in a coat and tie in the office where you wouldn't really perspire a lot. And sometimes sitting for extended periods of time, again, makes you feel tired and groggy. And if you implement a few of these exercises when you're in your office, you tend to be a little bit more awake and have a little bit more life about you.

345 MR. COCHRAN:

And did you write this also?

346 MR. WALSH:

The exercise I did.

347 MR. COCHRAN:

All right. The exercise you did?

348 MR. COCHRAN:

And with regard to that, if Mr. Harris can get to it and shortly.

349 MR. COCHRAN:

How long is that aspect? How long is that one?

350 MR. WALSH:

That one, if I remember, I think that might have been the longest of all. It might have been four minutes.

351 MR. COCHRAN:

About four minutes?

352 MR. WALSH:

About four minutes.

353 MR. COCHRAN:

All right. Now, with regard to other anecdotal information, did you have any other particular anecdotes or any other things that occurred during the course of this day with Mr. Simpson? We've talked about the chair, sitting on the chairs and the ice.

354 MR. WALSH:

Right.

355 MR. COCHRAN:

The bags. Any other anecdotal things of that nature?

356 MR. DARDEN:

Objection. The question is vague.

357 THE COURT:

Sustained. Rephrase the question.

358 MR. COCHRAN:

All right. Did anything else happen with regard to Mr. Simpson that you observed and his physical limitations on that day?

359 MR. WALSH:

Not that I can recall right now.

360 MR. COCHRAN:

We're still getting there, your Honor.

361 MR. COCHRAN:

The--with regard to the other people who participated in this video, there were some ladies in the background?

362 MR. WALSH:

Two women.

363 MR. COCHRAN:

And two men?

364 MR. WALSH:

Two men.

365 MR. COCHRAN:

Plus yourself? Now, were those people fairly physically fit?

366 MR. WALSH:

The women were in pretty good shape as were the men. But due to the nature of the concept of the video, which was, we were going to target the men's market--and one study that I saw indicated that as many as 50 percent of the men in America are sedentary. So we didn't want to come back with a real hard-hitting video nor did we want to come in with a video where everybody was in great shape. And so the men were kind of what we called an every-day man.

367 MR. COCHRAN:

Every-day man?

368 MR. WALSH:

Like an every-day man, not bad shape, not great shape.

369 MR. COCHRAN:

All right.

370 MR. WALSH:

In fact--well, go ahead.

371 MR. COCHRAN:

The women were in better shape than the men, weren't they?

372 MR. WALSH:

The women were in a little bit better shape.

373 MR. COCHRAN:

And the women--may be a sensitive subject. What was the general age of the women in that video?

374 MR. WALSH:

I would say--no disrespect to them, but I would say they were 30 to 35.

375 MR. COCHRAN:

All right. And with regard to you, you were kind of the leader of that video, right?

376 MR. WALSH:

Correct.

377 MR. COCHRAN:

And at the time this video was shot last May, were you just a tick under 40?

378 MR. WALSH:

It's a lot under 40.

379 MR. COCHRAN:

Were you 39?

380 MR. WALSH:

Yes.

381 MR. COCHRAN:

Is that a lot under 40?

382 MR. WALSH:

Yeah.

383 MR. COCHRAN:

All right. So you were just under 40. All right. And the other men who were in the video, they were approximately--

384 MR. WALSH:

Actually I take that back. I was 38.

385 MR. COCHRAN:

38? All right. You're 39 now?

386 MR. WALSH:

No. I'm 40 now. We shot in May.

387 MR. COCHRAN:

All right. Now, with regard to the other men in the video, approximately how old were they?

388 MR. WALSH:

Once again, I would say 33 to 40.

389 MR. COCHRAN:

All right. I think Mr. Harris has this now. And would you take a look at this and tell us what we're looking at.

390 (At 2:34 P.M., Defendant's exhibit 1255, a videotape, was played.)
391 MR. COCHRAN:

All right. I think we got the idea.

392 (At 2:26 P.M., the playing of the videotape was concluded.)
393 MR. COCHRAN:

Now, with regard to this particular--did you again write this--write the exercises for Mr. Simpson?

394 MR. WALSH:

Yes. Once again, I kind of routined the exercise program with the doctor's sale of approval, always.

395 MR. COCHRAN:

All right. And you got the doctor's approval before you did it; is that right?

396 MR. WALSH:

On every one of that--I'll repeat it every time if you need me to. But just so you know, that the expert did approve everything I wrote, and there were many changes.

397 MR. COCHRAN:

On the plane situation, again, the travel situation, did Mr. Simpson participate in helping to write that because he traveled so much?

398 MR. WALSH:

He may have had some of the speaking parts he may have put in on his own.

399 MR. COCHRAN:

Some ad-libs?

400 MR. WALSH:

Sure. And maybe put in a little bit of it. I did the actual exercises, and where the dialogue came from may have been put in by him, may have been put in by another writer.

401 MR. COCHRAN:

All right. Now, you have come here to testify today pursuant to subpoena, is that correct, or request from the Defense?

402 MR. WALSH:

Yes, I have.

403 MR. COCHRAN:

All right. And you've talked to the Prosecution before this; have you not?

404 MR. WALSH:

Yes, I have.

405 MR. COCHRAN:

And you cooperated with them when they came to talk to you?

406 MR. WALSH:

Yes, I did.

407 MR. COCHRAN:

Did they tape-record that statement?

408 MR. WALSH:

Yes, they did.

409 MR. COCHRAN:

They tape-recorded it?

410 MR. WALSH:

Yes.

411 MR. COCHRAN:

When was that you talked to them?

412 MR. WALSH:

I don't remember the date, but I remember Kato Kaelin was on the stand, because we were watching that from my house.

413 MR. COCHRAN:

And they came out to see you, and who came out to talk to you?

414 MR. WALSH:

I believe it was Dana Thompson and one other gentleman.

415 MR. COCHRAN:

And they tape-recorded your statement?

416 MR. WALSH:

Yes, they did.

417 MR. COCHRAN:

Very well. Thank you very kindly. I have nothing further at this point, your Honor.

Temperature

procedural

Key Quotes (5)

Richard Walsh
He got about halfway up and then he needed a little assistance.
Walsh describing OJ being unable to complete even one bicep curl with sandbags Walsh himself was doing 20 reps of — the core physical incapacity testimony.
Richard Walsh
He started literally flying. I mean not flying in the air, but he started jumping around and hobbling and he started screaming, 'My knee, my knee.'
Walsh's account of OJ's extreme reaction to a light elbow bump, supporting severe knee vulnerability.
Richard Walsh
I thought he was too physically limited to be the co-host with me.
Walsh's professional assessment as a fitness instructor — not a defense spin, but his genuine pre-trial opinion about Simpson's condition.
Richard Walsh
After the two-hour break, he was very, very tight... Sometimes when muscles are warm and loose when you're exercising, you sit for a while... you're very stiff and very tight. And that was what I observed.
Testimony about how OJ's condition deteriorated after rest, undercutting any argument he could have exerted sustained physical force.
Lance A. Ito
That way, we don't have to do too many reps.
Judge Ito making a gym pun to remind Walsh to let Cochran finish his questions — one of the few light moments in the trial.

Evidence (2)

People's 521
OJ Simpson workout videotape — the exercise/aerobics segment, including stretching scenes showing OJ's inability to bend his knees
played in court; Walsh narrated OJ's failed hamstring stretches in real time
Defendant's 1255
Commercial workout video — segments set on a simulated airplane and office, showing sedentary exercises OJ could perform
introduced and played; Walsh confirmed he wrote the exercises

Notable Exchanges (3)

Johnnie CochranRichard Walsh
Walsh described his pre-shoot sandbag pumping ritual to make his arms look bigger on camera, then revealed OJ tried to copy him and couldn't lift the bags at all — a moment Cochran clearly planned as the centerpiece of the testimony.
revealing
Lance A. ItoRichard Walsh
Ito intervened to remind the verbose Walsh to let Cochran finish questions before answering, making a 'too many reps' gym pun; Walsh responded self-deprecatingly that the court reporter could see from the videotape he was 'a man of many words.'
light
Johnnie CochranRichard Walsh
Extended back-and-forth about Walsh's age — Cochran said 'just a tick under 40,' Walsh insisted he was 38 at the time of the shoot, then corrected himself to say he's 40 now.
light

Light Moments (4)

Richard Walsh
'You're letting out all my secrets here' — Walsh's reaction when Cochran asked about his pre-shoot sandbag pumping ritual.
Richard Walsh
After Ito's 'too many reps' pun, Walsh quipped: 'And I'm sure she can see from the videotape that I'm a man of many words.'
Richard Walsh
When asked how long the stretching clip should play, Walsh deadpanned: 'Do you mind if I let it go for like an hour?'
Richard Walsh
Walsh's age confusion: insisted he was 'a lot under 40' at the shoot, then said 38, then clarified he's 40 now because the shoot was in May. Cochran played along.

Witness Demeanor

(Indicating) — Walsh physically demonstrated bicep curl motion while testifying
(Indicating) — Walsh mimed OJ's slow football-carry approach across the set
Walsh repeatedly started answering before Cochran finished questions, prompting Ito's intervention
Walsh asked 'Can I keep going?' multiple times when describing injuries, suggesting eagerness to testify fully
Walsh self-edited mid-answer when hearsay objections were sustained, visibly working to distinguish what he observed versus what he was told

Objections

22 objections (9 sustained, 12 overruled)
Proceeding 6938 • 417 utterances • Defense witness
Criminal Trial
Department 103
⚖️ Start
📂 JUL 19, 1995 📄 Direct examination of Richard
JUL 19, 1995 KRT DvH TD