📄 Morning session opening — Thursday, March 23, 1995
Address:
C:\DEPT103\CRIMINAL\1995\MAR\23\MORNING-SESSION-OPENING.DOC
TRIAL
▲ Day 44 of 167

Morning session opening

Date: Thursday, March 23, 1995 • Utterances: 57
Before the jury was brought in, defense attorney Shapiro challenged the prosecution's good faith basis for impeachment questions asked of Kato Kaelin the previous day regarding two subjects: a Burger King reference and statements Kaelin allegedly made to friend Grant Cramer. Clark read from discovery page 906 to establish the Cramer basis, then admitted a second line of questioning came from an unlocated TV news interview — prompting Shapiro to argue the questions were grounded in 'tabloid television.' Judge Ito ultimately found the offer of proof sufficient and overruled the objection.
1 (JANET M. MOXHAM, CSR NO. 4855, OFFICIAL REPORTER.)
2 (CHRISTINE M. OLSON, CSR NO. 2378, OFFICIAL REPORTER.)
3 (THE FOLLOWING PROCEEDINGS WERE HELD IN OPEN COURT, OUT OF THE PRESENCE OF THE JURY:)
4 THE COURT:

ALL RIGHT. GOOD MORNING, COUNSEL. BACK ON THE RECORD IN THE SIMPSON MATTER. THE DEFENDANT 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. DARDEN. THE JURY IS NOT PRESENT. COUNSEL, IS THERE ANYTHING WE NEED TO CHAT ABOUT BEFORE WE INVITE THE JURORS TO REJOIN US FOR THE CONCLUSION OF THE DIRECT EXAMINATION?

5 MR. SHAPIRO:

YOUR HONOR, WE WOULD ASK TO APPROACH THE BENCH FOR AN OFFER OF PROOF OF GOOD FAITH ON THE PART OF THE PEOPLE FOR IMPEACHMENT IN TWO AREAS THAT THEY HAVE ALLUDED TO.

ONE, SOMETHING THAT TOOK PLACE AT BURGER KING, AND TWO, STATEMENTS SUPPOSEDLY MADE BY KATO KAELIN TO GRANT CRAMER. I HAVE THE DISCOVERY THAT THEY HAVE PROVIDED US WITH REGARDING GRANT CRAMER AND IT DOESN'T COME ANYWHERE NEAR THE SUGGESTIONS THAT MISS CLARK WAS GIVING TO THE WITNESS YESTERDAY.

6 THE COURT:

MISS CLARK.

7 MR. COCHRAN:

YOUR HONOR, MAY PERHAPS MR. --

8 MS. CLARK:

I DON'T KNOW IF MR. SHAPIRO KNOWS HOW TO READ, BUT I WOULD LIKE TO GET THE REPORT AND READ TO IT HIM. MR. CRAMER SAID PRECISELY WHAT I SAID TO THE WITNESS. IT IS QUOTED IN THE POLICE REPORT. AND WHAT MORE OFFER OF GOOD FAITH DO YOU NEED THAN THE ACTUAL STATEMENT OF THE WITNESS? THE WITNESS STATED TO THE POLICE THAT KATO KAELIN TOLD HIM WHEN HE WENT TO ROCKINGHAM, AFTER --

KEY QUOTE
9 THE COURT:

EXCUSE ME. PERHAPS WE OUGHT TO ASK MR. KAELIN TO STEP OUT IF YOU ARE GOING TO TALK ABOUT SPECIFICS.

10 MS. CLARK:

I DIDN'T KNOW HE WAS HERE.

11 THE COURT:

YES.

12 (MR. KAELIN EXITS THE COURTROOM.)
13 THE COURT:

MISS CLARK.

14 MS. CLARK:

YES, YOUR HONOR. FIRST OF ALL, WITH RESPECT TO THE BURGER KING, I DON'T BELIEVE THERE WAS ANY ATTEMPT AT IMPEACHMENT. I ASKED HIM WHETHER HE WAS SURE HE WENT TO MC DONALD'S AND WHICH ONE AND I DON'T THINK THERE WAS -- THERE WAS NO ATTEMPT TO IMPEACH HIM ON THAT. AND MR. SHAPIRO IS VERY WELL AWARE OF THE REPORTS.

15 THE COURT:

YOU DID ASK HIM YOU ARE SURE IT IS NOT THE BURGER KING ACROSS THE STREET?

16 MS. CLARK:

RIGHT, BUT I DID NOT ALLUDE TO ANY PRIOR WITNESS STATEMENTS OR ANYONE WHO SAID DIFFERENTLY. THAT IS DIFFERENT THAN SAYING "DID YOU TELL SOMEONE ELSE THE FOLLOWING." WITH RESPECT TO GRANT CRAMER, MR. SHAPIRO IS IN POSSESSION OF THESE REPORTS. IT STATES IN THE REPORT, I'M QUOTING RIGHT NOW AT PAGE 906 OF THE DISCOVERY, THIS IS GRANT CRAMER'S STATEMENT, THAT: "WHEN KATO WENT BACK TO -- KATO WENT TO ROCKINGHAM AFTER HAVING BEEN INTERVIEWED BY THE POLICE, HE WENT TO SEE GRANT CRAMER AND THEN HE WENT TO ROCKINGHAM AT THE DEFENSE REQUEST AND STAYED AT ROCKINGHAM UNTIL ABOUT MIDNIGHT OR 1:00 A.M. AND THEN HE CAME BACK TO GRANT CRAMER'S HOUSE, AND WHEN HE DID HE TOLD GRANT CRAMER THE FOLLOWING, THAT O.J.'S FAMILY AND FRIENDS WERE AT THE RESIDENCE ALONG WITH SOME OTHER ATTORNEYS, WHICH INCLUDED WEITZMAN, KATO SAID THAT O.J. HAD HUGGED HIM TELLING HIM 'THANK GOD YOU WERE HERE AND YOU CAN SAY I WAS AT HOME WHEN THIS THING HAPPENED.' "CRAMER SAID KATO SPENT THE NIGHT AT HIS APARTMENT AND LEFT THE NEXT DAY. KATO SPENT THE REST OF THE NEXT SEVERAL DAYS AT SIMPSON'S RESIDENCE. DURING ONE OF THOSE DAYS KATO CALLED CRAMER ON THE PHONE AND SPOKE VERY COVERTLY. KATO SOUNDED VERY EXCITED ON THE TELEPHONE AND SAID HE COULD NOT TALK. KATO TOLD CRAMER 'JUST BE CAREFUL.' CRAMER REPLIED, 'WHY? IS MY LIFE IN DANGER?' KATO ABRUPTLY SAID, 'NO, I DIDN'T SAY THAT.'"

17 THE COURT:

THAT IS IT?

18 MS. CLARK:

EXACTLY WHAT I -- WELL, THERE IS MORE TO IT, BUT THAT IS EXACTLY WHAT I CROSS-EXAMINED KATO --

19 MR. SHAPIRO:

WHY DON'T WE FINISH. THERE IS MORE THERE, YOUR HONOR, BECAUSE OUR POINT IS THAT I BELIEVE MISS CLARK TRIED TO INSINUATE --

20 THE COURT:

WELL, LET ME JUST SEE IF THERE IS MORE.

21 MR. SHAPIRO:

THANK YOU.

22 MS. CLARK:

WELL, NO. THERE IS NOTHING ON THAT. IT GOES ON: "THEN KATO ARRIVED AT CRAMER'S RESIDENCE ON FRIDAY MORNING, JUNE 17, AND CRAMER RELUCTANTLY ALLOWED HIM INSIDE AND IT WAS THE SAME DAY THAT DETECTIVES CARR AND TIPPIN SERVED HIM WITH A GRAND JURY SUBPOENA." THERE IS NOTHING MORE ABOUT THE EVENTS AT ROCKINGHAM. THAT IS ALL.

23 THE COURT:

ALL RIGHT.

24 MS. CLARK:

IS THAT A GOOD FAITH OFFER OF PROOF OR WHAT? I MEAN, THE WITNESS SAID EXACTLY WHAT I CONFRONTED OUR WITNESS WITH AND MR. SHAPIRO HAS THIS REPORT. I DON'T KNOW WHAT KIND OF GAME HE IS PLAYING NOW. LET'S CALL THE JURY, YOUR HONOR.

25 MR. SHAPIRO:

YOUR HONOR, MY RECOLLECTION OF THE QUESTIONS YESTERDAY WERE THAT THEY WENT INTO THE DEMEANOR OF MR. SIMPSON AND WHAT KATO KAELIN TOLD GRANT CRAMER ABOUT MR. SIMPSON'S DEMEANOR AND HOW OUT OF SORTS IT WAS. AND I HAVE TO THIS DATE NOT RECEIVED ANY OTHER REPORTS THAN THE SIMPLE PARAGRAPH THAT MISS CLARK HAS READ TO YOUR HONOR, AND I WOULD STILL URGE THE COURT TO MAKE AN INQUIRY OF MISS CLARK AS TO WHERE THE REPORTS ARE THAT TALK ABOUT KATO KAELIN TALKING TO GRANT CRAMER ABOUT DEMEANOR.

26 MS. CLARK:

DO I HAVE TO READ EVERYTHING TO HIM?

27 THE COURT:

MISS CLARK.

28 MS. CLARK:

PAGE 906, YOUR HONOR.

29 THE COURT:

MISS CLARK, MISS CLARK.

30 MS. CLARK:

I'M SORRY.

31 THE COURT:

THAT KIND OF COMMENT IS NOT NECESSARY.

32 MS. CLARK:

I APOLOGIZE TO THE COURT. I'M SORRY. "KATO TOLD CRAMER THAT HE" --

33 THE COURT:

WHAT PAGE ARE YOU ON?

34 MS. CLARK:

MAINLY 906. CRAMER IS TALKING ABOUT KATO'S RECOUNTING OF O.J.'S DEMEANOR AT THE TIME AFTER THE LIMO HAD ARRIVED. "KATO TOLD CRAMER THAT HE OBSERVED O.J. TO BE FRAZZLED AND OUT OF BREATH," QUOTE-UNQUOTE, "AND DID NOT LOOK LIKE THAT HE HAD JUST AWAKED FROM SLEEP AT THE TIME THE LIMO DRIVER ARRIVED." I THINK THAT IS WHAT I ASKED HIM.

35 THE COURT:

OKAY. WAS THERE ANOTHER QUESTION, TO MY RECOLLECTION, CONCERNING MR. SIMPSON'S DEMEANOR AFTER THE RECITAL?

36 MS. CLARK:

YES, THERE WAS, AND THAT IS PURSUANT TO ANONYMOUS -- TWO, ACTUALLY -- ON TWO SEPARATE OCCASIONS, ANONYMOUS TIPS THAT WE HAVE RECEIVED -- NO, ONE ANONYMOUS; ONE NOT. ONE FROM EITHER AN EX-GIRLFRIEND OR THE EX-WIFE OF KATO KAELIN ON TELEVISION SAYING THAT HE DESCRIBED THE DEFENDANT'S DEMEANOR AFTER THE RECITAL AS BEING FURIOUS, ANGRY, YELLING AND SHOUTING. WE RECEIVED A BACK-UP TO THAT YESTERDAY, ANOTHER TIP IN WHICH KATO HAD ALLEGEDLY TOLD THAT WITNESS AS WELL THAT AFTER THE RECITAL HE WAS FURIOUS, YELLING AND SCREAMING AND SHOUTING ABOUT NICOLE.

37 THE COURT:

ALL RIGHT. WHEN DID YOU RECEIVE THIS INFORMATION REGARDING THE EX-WIFE OR EX-GIRLFRIEND?

38 MS. CLARK:

OKAY. THAT WAS JUST -- THAT WAS ON TELEVISION. THAT WAS A NEWS REPORT, A NEWS INTERVIEW, AND THAT WAS -- I DON'T REMEMBER WHEN. I THINK IT WAS MAYBE TWO, THREE WEEKS AGO. I DON'T HAVE A REPORT ON IT. IT WAS ON TELEVISION.

39 THE COURT:

HAVE YOU SUBPOENAED THIS PERSON?

40 MS. CLARK:

NOT YET. ACTUALLY, I HAVE DETECTIVE VANNATTER TRYING TO LOCATE HER.

41 THE COURT:

HE IS SITTING RIGHT HERE.

42 MS. CLARK:

WELL, NOT PERSONALLY. HIS HELPERS. HE IS AWARE OF THIS.

43 THE COURT:

ALL RIGHT. ANY COMMENT AS TO THAT ISSUE?

44 MR. SHAPIRO:

YES, YOUR HONOR. MY UNDERSTANDING OF THE LAW IN CALIFORNIA IS THAT GOOD FAITH REQUIRES SOMETHING MORE THAN TABLOID TELEVISION OR TABLOID NEWSPAPERS TO BE ABLE TO ASK QUESTIONS ON CROSS-EXAMINATION IN THE WAY THAT THEY WERE ASKED YESTERDAY, AND AT A VERY MINIMUM A FOLLOW-UP, KNOWING THAT THIS WITNESS WAS A KEY WITNESS AND HAD BEEN PROBABLY -- NOT PROBABLY -- WAS THE FIRST WITNESS INTERVIEWED IN THIS CASE IN JUNE OF 1994, THAT COMING TO COURT NOW TEN MONTHS LATER AND SAYING WE STILL HAVEN'T FOLLOWED UP ON OTHER REPORTS, KNOWING FROM THAT DAY HE GAVE THEM THE NAME OF GRANT CRAMER AND SAID HE HAD BEEN WITH GRANT CRAMER. CLEARLY I THINK THE COURT SHOULD FIND THERE WAS BAD FAITH AND THAT THE JURY SHOULD BE ADMONISHED THAT QUESTIONS WERE ASKED IN BAD FAITH AND THAT THERE WAS NO BASIS IN FACT FOR ASKING THEM.

KEY QUOTE
45 THE COURT:

ALL RIGHT. THANK YOU, COUNSEL.

46 MS. CLARK:

EXCUSE ME, YOUR HONOR. THE COURT SHOULD BE AWARE THAT MR. KAELIN DID NOT VOLUNTEER TO US THAT HE WENT TO GRANT CRAMER'S HOUSE. THAT IS FALSE. WE FOUND THAT OUT INDEPENDENTLY AND THERE HAS BEEN NO BAD FAITH HERE, I THINK THAT IS OBVIOUS. THE WITNESS INTERVIEW THAT I TALKED ABOUT, THE FACT THAT SOMEONE SAYS IT ON TELEVISION, THIS IS NOT A REPORT OR CHARACTERIZING WHAT THERE WOMAN SAID. THIS IS THE WOMAN HERSELF ON TELEVISION SAYING IT, SO THAT IS A LITTLE DIFFERENT. YOU KNOW, WE HAVE SOMEONE WHO IS SAYING IT WHO HAS BEEN VIEWED PROBABLY NATIONALLY SAYING WHAT I HAVE REPRESENTED TO MR. KAELIN. IF HE CHOOSES NOT TO ADMIT THAT HE SAID THAT, THAT IS HIS CHOICE, BUT IT CERTAINLY IS A GOOD FAITH SHOWING. IT IS NOT REQUIRED THAT I HAVE STATEMENTS UNDER OATH AND MR. SHAPIRO IS VERY WELL AWARE OF THAT. HE IS SIMPLY TRYING TO PROTECT HIS WITNESS. THIS WOMAN DID STATE PERSONALLY ON TELEVISION WHAT I CONFRONTED MR. KAELIN WITH. FURTHERMORE, WITH RESPECT TO THE STATEMENT ABOUT GRANT CRAMER --

47 THE COURT:

DO YOU HAVE A VIDEOTAPE OF THIS INTERVIEW?

48 MS. CLARK:

I HAVE -- WE HAVE BEEN TRYING TO LOCATE THAT. EVER SINCE I HEARD ABOUT IT WE HAVE BEEN TRYING TO LOCATE THE TAPE. PEOPLE HAVE CALLED ME WHO -- WHO HAVE SEEN IT AND TOLD ME ABOUT IT, SO I MEAN, I'M NOT --

49 THE COURT:

WHAT NEWS PROGRAM WAS THIS ON?

50 MS. CLARK:

I BELIEVE IT WAS CHANNEL 7 AND THAT IS WHERE IT HAS BEEN DIFFICULT TO LOCATE. THREE PEOPLE CALLED ME TO SAY THAT SEEN THIS WOMAN TALKING ON TELEVISION. IT WAS 7:00 OR 7:30 SHOWING DURING THE WEEK ABOUT THE STATEMENT THAT KAELIN HAD MADE TO HER CONCERNING THE DEFENDANT'S DEMEANOR, AND WE HAVE BEEN TRYING TO LOCATE THE FOOTAGE, AS WELL AS THE PERSON, AND DETECTIVE VANNATTER CAN ACTUALLY TESTIFY TO THE FACT THAT I HAVE REQUESTED HIM TO LOCATE THIS PERSON, BECAUSE I DID, IMMEDIATELY UPON HEARING THAT, BUT CERTAINLY I HAVE ENOUGH FOR A GOOD FAITH SHOWING TO ASK MR. KAELIN ABOUT THIS AND CONFRONT HIM WITH IT. IF HE ADMITS IT, THEN FINE. IF HE DOESN'T, THE WITNESS WILL BE PRODUCED.

51 THE COURT:

I THINK HE HAS ALREADY BEEN CONFRONTED WITH THOSE TWO ISSUES, THREE ISSUES.

52 MS. CLARK:

RIGHT.

53 THE COURT:

ALL RIGHT.

54 MS. CLARK:

THE COURT IS AWARE OF THE FACT THAT WE ARE PREPARED TO BACK IT UP AND MR. KAELIN DID NOT VOLUNTEER HIS CONVERSATIONS WITH GRANT CRAMER. HE NEVER VOLUNTEERED THE NAME. WE FOUND THAT OUT ON OUR OWN.

55 THE COURT:

ALL RIGHT. THANK YOU, COUNSEL.

56 MR. SHAPIRO:

YOUR HONOR, MAY I REFER THE COURT MOST RESPECTFULLY TO PAGE 348 OF THE MURDER BOOK, THE FIRST REPORT THAT WAS FILED, AND THAT WAS THE REPORT OF OFFICER TIPPIN AND CARR REGARDING GRANT CRAMER -- REGARDING KATO KAELIN. AND THE FIRST LINE OF THAT REPORT ON PAGE 2 IS "FRIEND AND BUSINESS PARTNER, GRANT CRAMER," AND IT GIVES HIS NUMBER.

57 THE COURT:

ALL RIGHT. THANK YOU. COUNSEL, I FIND THE OFFER OF PROOF TO BE SUFFICIENT FOR THE PURPOSES OF THE EXAMINATION OF THIS WITNESS. I WILL OVERRULE THE OBJECTION AT THIS TIME. LET'S HAVE THE JURY.

Temperature

tense

Key Quotes (5)

Marcia Clark
I DON'T KNOW IF MR. SHAPIRO KNOWS HOW TO READ, BUT I WOULD LIKE TO GET THE REPORT AND READ TO IT HIM.
Earned an immediate judicial rebuke; illustrates the antagonism between counsel at this stage of trial.
Marcia Clark
KATO TOLD CRAMER THAT O.J. HAD HUGGED HIM TELLING HIM 'THANK GOD YOU WERE HERE AND YOU CAN SAY I WAS AT HOME WHEN THIS THING HAPPENED.'
An alleged statement by OJ to Kaelin that directly implies consciousness of guilt — the heart of the impeachment the prosecution was trying to lay in.
Robert Shapiro
MY UNDERSTANDING OF THE LAW IN CALIFORNIA IS THAT GOOD FAITH REQUIRES SOMETHING MORE THAN TABLOID TELEVISION OR TABLOID NEWSPAPERS TO BE ABLE TO ASK QUESTIONS ON CROSS-EXAMINATION.
Shapiro's sharpest legal point — Clark admitted one basis for impeachment was a TV news report she had not been able to locate or subpoena.
Marcia Clark
THREE PEOPLE CALLED ME TO SAY THAT SEEN THIS WOMAN TALKING ON TELEVISION. IT WAS 7:00 OR 7:30 SHOWING DURING THE WEEK ABOUT THE STATEMENT THAT KAELIN HAD MADE TO HER CONCERNING THE DEFENDANT'S DEMEANOR.
Clark's candid admission that her evidentiary basis for one line of questioning was secondhand accounts of a TV segment she could not locate — a notably thin foundation.
Lance A. Ito
COUNSEL, I FIND THE OFFER OF PROOF TO BE SUFFICIENT FOR THE PURPOSES OF THE EXAMINATION OF THIS WITNESS. I WILL OVERRULE THE OBJECTION AT THIS TIME.
Ruling that ends the dispute: the prosecution's cross-examination of Kaelin on these subjects was permissible.

Evidence (3)

Informal
Page 906 of prosecution discovery — Grant Cramer's police statement describing what Kaelin told him after returning from Rockingham, including OJ's alleged 'thank God you were here' comment and Kaelin's observation that OJ appeared 'frazzled and out of breath' when the limo arrived.
read into record by Clark to establish good faith basis for cross-examination
Informal
Page 348 of the Murder Book — initial report by Officers Tippin and Carr regarding Kaelin, which lists 'friend and business partner, Grant Cramer' with his phone number.
cited by Shapiro to argue the prosecution had Cramer's name from day one and had ten months to follow up
Informal
Unlocated Channel 7 news segment in which Kaelin's alleged ex-girlfriend or ex-wife stated on television that Kaelin described OJ's demeanor after a recital as 'furious, angry, yelling and shouting about Nicole.'
described by Clark as basis for demeanor impeachment; no tape or report in possession

Notable Exchanges (3)

Marcia ClarkLance A. Ito
Clark made a sarcastic remark about whether Shapiro 'knows how to read'; Ito cut her off and said 'that kind of comment is not necessary.' Clark apologized.
heated, then corrected
Marcia ClarkLance A. Ito
Ito probed Clark's TV-interview basis methodically — asking when she received it, whether she'd subpoenaed the witness, what program it aired on — and noted dryly that Detective Vannatter 'is sitting right here' when Clark said he was working to locate the witness.
pointed, slightly wry
Robert ShapiroLance A. Ito
Shapiro argued the court should find bad faith and admonish the jury; Ito heard him out but rejected the request entirely.
strategic, unsuccessful

Light Moments (1)

Lance A. Ito
When Clark mentioned Detective Vannatter was working to locate the TV witness, Ito replied 'He is sitting right here.' Clark fumbled: 'Well, not personally. His helpers.'

Credibility Attacks (2)

⚔ Kato Kaelin
prior inconsistent statement via third-party witness (Grant Cramer)
Clark cross-examined Kaelin on statements he allegedly made to Grant Cramer — including that OJ hugged him and said 'thank God you were here,' and that OJ appeared frazzled and out of breath when the limo arrived. Defense challenged whether prosecution had sufficient good faith basis; court overruled.
⚔ Kato Kaelin
prior inconsistent statement via unlocated television source
Clark questioned Kaelin about his alleged description of OJ's demeanor after a recital as 'furious, yelling and screaming about Nicole,' based on a TV news interview Clark saw or heard about but could not locate. Shapiro characterized this as 'tabloid television.'

Witness Demeanor

(MR. KAELIN EXITS THE COURTROOM.)

Objections

1 objections (0 sustained, 1 overruled)
Proceeding 5406 • 57 utterances
Criminal Trial
Department 103
⚖️ Start
📂 MAR 23, 1995 📄 Morning session opening
MAR 23, 1995 KRT DvH TD