Day 45 centered on Kato Kaelin's continuing testimony. Clark challenged the bases for his views of OJ Simpson's relationship with Nicole and his role as a father, questioned him about prior statements, and established that Kaelin could not account for Simpson's whereabouts during the 9:35-11:00 PM window on June 12th. Ito granted Clark's request to treat Kaelin as hostile after she cited evasiveness and contradictions, while Shapiro used recross to argue that Simpson showed no hostility toward Nicole and never asked Kaelin to lie or create an alibi. Following a final sidebar that included mutual complaints about rude conduct, the court adjourned because a juror needed to attend a funeral, with Kaelin ordered to return the next morning.

• Shapiro moved for sanctions over the prosecution's improper question about a 1989 domestic violence incident beyond Kaelin's knowledge; Ito declined to re-admonish the jury and later instructed jurors not to draw any inference from the question
• Clark challenged the basis for Kaelin's view that OJ was a devoted father, eliciting estimates that he saw OJ with his children for two to three hours over one year at Gretna Green and one and a half hours over six months at Rockingham
• Judge Ito granted Clark's request to treat Kato Kaelin as a hostile witness after she cited increasingly evasive testimony and contradictions with earlier statements, and reprimanded her for announcing the request before the jury
• Clark established that Kaelin cannot account for OJ's whereabouts during the critical 9:35-11:00 PM window on June 12th
• Kaelin testified that his only June 13 conversation with OJ concerned whether Kaelin could say OJ was home during the murder window; on recross, Kaelin said OJ never asked him to lie or create an alibi
• Shapiro and Clark traded complaints about rude conduct during the final sidebar, and Kaelin's examination was continued to the next morning