Cross-examination of Tom Lange

📄 Cross-examination of Tom Lange — Tuesday, March 21, 1995

Address:

C:\DEPT103\CRIMINAL\1995\MAR\21\CROSS-EXAMINATION-OF-TOM-LANGE.DOC

TRIAL

▲ Day 42 of 167

◀ Direct examination of Tom Lange Recess ▶

Witness: Det. Tom Lange
Examiner: Johnnie Cochran
Called by: Prosecution • Date: Tuesday, March 21, 1995 • Utterances: 43

Cochran briefly cross-examined Detective Lange about the locked doors on the south side of OJ Simpson's Rockingham residence, focusing on what Lange checked on the morning of June 13th around 6:25 AM. Cochran established that Lange's recollections were from memory alone — no reports, no photographs — and that he could not confirm with certainty whether the doors could have been opened with a key from the outside or unlocked from within.

# 1 THE COURT:

MR. COCHRAN, ANY RECROSS AS -- ANY CROSS AS TO THAT ITEM?

# 2 MR. COCHRAN:

YES. MAY I HAVE THAT -- I WOULD LIKE TO HAVE THE POSTER PUT UP DEPICTING THE DOOR.

# 3 THE COURT:

MR. DOUGLAS, ARE YOU GOING TO ASSIST US HERE?

# 4 MR. DOUGLAS:

YES, YOUR HONOR.

# 5

CROSS-EXAMINATION

# 6

BY MR. COCHRAN:

# 7 Q:

GOOD AFTERNOON AGAIN, DETECTIVE LANGE.

# 8 A:

GOOD AFTERNOON.

# 9 Q:

WOULD YOU MIND STEPPING DOWN AND SHOWING US WHERE THIS DOOR INTO THE GARAGE IS LOCATED? AND IF YOU CAN MARK THAT BY USING ONE OF THESE ARROWS IF YOU WOULD BE SO KIND.

# 10 A:

SEEMS TO ME IT WAS RIGHT IN THIS GENERAL AREA HERE (INDICATING).

# 11 Q:

GOING INTO THE GARAGE; IS THAT CORRECT?

# 12 A:

I BELIEVE SO, YES.

# 13 Q:

ALL RIGHT. THAT'S JUST YOUR INDEPENDENT RECOLLECTION NOW MONTHS LATER; IS THAT CORRECT?

# 14 A:

YES.

# 15 Q:

YOU HAVE NO REPORTS TO REFRESH YOUR RECOLLECTION, DO YOU?

# 16 A:

NO.

# 17 Q:

ALL RIGHT. SO THAT WE'RE CLEAR AND WHILE YOU'RE STANDING HERE, WITH REGARD TO YOUR CHECKING THESE DOORS, AT WHAT TIME OF DAY ON JUNE 13TH DID THIS TAKE PLACE?

# 18 A:

IT WAS JUST SUBSEQUENT TO DETECTIVE FUHRMAN POINTING OUT THE GLOVE. SO IT WAS APPROXIMATELY 6:25 IN THE MORNING I BELIEVE GIVE OR TAKE A FEW MINUTES.

KEY QUOTE

# 19 Q:

ON THE 13TH?

# 20 A:

YES.

# 21 Q:

AND FROM WHAT I UNDERSTAND, YOU TESTIFIED THESE DOORS WERE LOCKED; IS THAT CORRECT?

# 22 A:

YES.

# 23 Q:

IN OTHER WORDS, DO THEY HAVE A KEY WHICH WOULD ACTIVATE THOSE DOORS?

# 24 A:

I DON'T RECALL SPECIFICALLY, BUT I BELIEVE THE KNOBS WERE SMOOTH. SO THERE WOULDN'T BE ANYTHING IN THERE, AND I BELIEVE THAT THERE MAY HAVE BEEN A DEADBOLT LOCK, BUT I'M NOT CERTAIN.

# 25 Q:

DID YOU EVER -- YOU MAY RESUME YOUR SEAT. DID YOU EVER GO AROUND TO THE OTHER SIDE OF THE GARAGE, INSIDE THE GARAGE AND SEE WHETHER OR NOT YOU COULD UNLOCK THAT DOOR FROM THE INSIDE?

# 26 A:

THE GARAGE DOOR? NO, I DIDN'T.

# 27 Q:

DID YOU EVER GO INSIDE THE RESIDENCE ON THAT MORNING AND SEE WHETHER OR NOT YOU COULD OPEN THE DOOR INTO THE SIDE -- THE SECOND DOOR AND COME OUTSIDE?

# 28 A:

I DID CHECK THAT DOOR IN THE LAUNDRY ROOM, AND AGAIN, I BELIEVE IT WAS AN INSIDE DEADBOLT LOCK, BUT I'M NOT CERTAIN.

# 29 Q:

DO YOU HAVE ANY PHOTOGRAPHS OF HOW THAT EXISTED AND HOW IT APPEARED AT THAT TIME?

# 30 A:

I DON'T KNOW IF THERE ARE ANY PHOTOGRAPHS THAT WERE TAKEN OF THAT AREA. I DIDN'T DIRECT ANY.

KEY QUOTE

# 31 Q:

AND YOU'VE NOT SEEN ANY, HAVE YOU?

# 32 A:

THERE MAY NOT BE.

# 33 Q:

ALL RIGHT. SO YOUR BEST RECOLLECTION IS PRESENTLY THAT THERE ARE TWO DOORS ON THE SOUTH SIDE OF THE RESIDENCE WHICH YOU SAW THAT MORNING, CORRECT?

# 34 A:

YES.

# 35 Q:

YOU COULD NOT GAIN ENTRY INTO THOSE DOORS; IS THAT CORRECT?

# 36 A:

THAT'S CORRECT.

# 37 Q:

AND AS WE SIT HERE NOW, YOU CAN'T TELL US WHETHER OR NOT A KEY MIGHT HAVE ACTIVATED EITHER ONE OF THOSE TWO DOORS; IS THAT CORRECT?

# 38 A:

AGAIN, MY RECOLLECTION IS THAT THE KNOBS WERE SMOOTH FACED, BUT I BELIEVE THERE WAS A DEADBOLT IN AT LEAST THE UTILITY ROOM DOOR. SO IT'S POSSIBLE THAT A KEY COULD HAVE ACTIVATED THAT DOOR, YES.

# 39 Q:

THE -- THE SECOND DOOR, THE ONE INTO THE MAID -- INTO THE WASHING ROOM THERE, THE LAUNDRY ROOM?

# 40 A:

YES. BUT AGAIN, I'M NOT CERTAIN.

# 41 Q:

ALL RIGHT. SO YOU'RE NOT CLEAR ON THAT; IS THAT CORRECT?

# 42 A:

NO.

# 43 MR. COCHRAN:

ALL RIGHT. THANK YOU VERY MUCH. THANK YOU, YOUR HONOR.

Temperature

procedural

Key Quotes (3)

Tom Lange

IT WAS JUST SUBSEQUENT TO DETECTIVE FUHRMAN POINTING OUT THE GLOVE. SO IT WAS APPROXIMATELY 6:25 IN THE MORNING I BELIEVE GIVE OR TAKE A FEW MINUTES.

Anchors the door-check timeline to Fuhrman's glove discovery, linking two key investigative threads.

Tom Lange

I DON'T KNOW IF THERE ARE ANY PHOTOGRAPHS THAT WERE TAKEN OF THAT AREA. I DIDN'T DIRECT ANY.

Cochran elicits an admission of incomplete documentation — no photographic record of the door condition exists.

Tom Lange

IT'S POSSIBLE THAT A KEY COULD HAVE ACTIVATED THAT DOOR, YES.

Lange concedes uncertainty about whether the laundry room door could have been opened from outside, potentially relevant to defense theories about entry/exit.

Evidence (1)

Informal

Poster/diagram depicting the south side of the Rockingham residence showing door locations

used for witness to mark and identify door locations

Notable Exchanges (1)

Johnnie Cochran•Tom Lange

Cochran methodically established that Lange's entire recollection of the door conditions was from unaided memory — no reports, no photos — and that he was uncertain about whether deadbolts or smooth knobs were present on the relevant doors.

strategic

Credibility Attacks (1)

⚔ Tom Lange

lack of documentation / memory without refreshment

Cochran pressed that Lange had no reports to refresh his recollection and no photographs of the doors were taken, undermining the reliability of his account of the locked door conditions.

Witness Demeanor

(INDICATING) — Lange steps down to mark door location on diagram poster

Objections

None recorded

Proceeding 5359 • 43 utterances • Prosecution witness

Criminal Trial

Department 103