📄 Sidebar: hostile witness — Monday, March 27, 1995
Address:
C:\DEPT103\CRIMINAL\1995\MAR\27\SIDEBAR-HOSTILE-WITNESS.DOC
TRIAL
▲ Day 45 of 167

Sidebar: hostile witness

Date: Monday, March 27, 1995 • Utterances: 52
Prosecutor Marcia Clark requested that Kato Kaelin be designated a hostile witness, citing his increasingly evasive testimony and contradictions with earlier statements. Judge Ito granted the request but reprimanded Clark for announcing it in front of the jury, ruling such requests must be made at sidebar. Shapiro requested sanctions against Clark, which she dismissed as 'ludicrous.'
1 (THE FOLLOWING PROCEEDINGS WERE HELD AT THE BENCH:)
2 THE COURT:

WE'RE OVER AT SIDEBAR.

3 MR. SHAPIRO:

MAY I BE HEARD FIRST?

4 THE COURT:

NO. MISS CLARK IS MAKING THE REQUEST.

5 MS. CLARK:

YES, YOUR HONOR. WITH RESPECT TO TODAY'S EVENTS AS WELL AS THE PREVIOUS EXAMINATIONS, THIS WITNESS HAS BECOME MORE AND MORE RELUCTANT. I WOULD LIKE TO POINT OUT TO THE COURT THE DISCREPANCIES IN THE WITNESS' TESTIMONY AND HIS DEMEANOR, WHICH DATES BACK TO AS EARLY AS JUNE THE 13TH AND FORWARD, CONTRASTING STATEMENTS HE GAVE TO MR. SHAPIRO ON JUNE THE 14TH, THE MANNER IN WHICH HE WAS VERY FORTHCOMING ABOUT THE DOMESTIC VIOLENCE SITUATION, WHICH I ALREADY POINTED OUT FOR THE JURY, AND THE MANNER IN WHICH HE TESTIFIED AT THE GRAND JURY SOME SIX DAYS LATER IN WHICH IN RESPONSE TO EQUALLY OPEN-ENDED QUESTIONS POSED BY MYSELF AND MR. SHAPIRO, HE INDICATED THERE WAS ONE ARGUMENT HE BARELY REMEMBERED, AND THAT WAS THE 911 TAPE THAT WE'VE HEARD IN THIS COURTROOM, WHICH CAN HARDLY BE CHARACTERIZED AS JUST AN ARGUMENT.

6 THE COURT:

LET'S ASSUME I AGREE WITH YOU HE'S A HOSTILE WITNESS TO THE PROSECUTION. WHAT BENEFIT DO YOU EXPECT FROM THAT?

7 MS. CLARK:

I WANT TO BE ABLE TO CROSS-EXAMINE HIM AS OPPOSED TO DIRECT EXAMINE HIM.

8 THE COURT:

IN OTHER WORDS, YOU WANT TO BE ABLE TO ASK HIM LEADING QUESTIONS?

9 MS. CLARK:

CORRECT.

10 THE COURT:

ALL RIGHT. MR. SHAPIRO, ANY COMMENT ON THAT?

11 MR. SHAPIRO:

YES.

12 THE COURT:

AND BEFORE WE DO THAT, MISS CLARK, BEFORE YOU ANNOUNCE THAT YOU ARE TAKING SOMEBODY AS A HOSTILE WITNESS, YOU NEED TO DO THAT AT SIDEBAR.

13 MS. CLARK:

I APOLOGIZE.

14 THE COURT:

THAT'S NOT SOMETHING THAT SHOULD BE DONE IN FRONT OF THE JURY.

15 MS. CLARK:

I APOLOGIZE TO THE COURT.

16 MR. SHAPIRO:

ON THAT ISSUE, WE WOULD AGAIN ASK FOR SANCTIONS AND ALSO FOR -- SANCTIONS FOR MISS CLARK'S CONDUCT WHEN I MENTION THESE THINGS WITH HER LAUGHING, ROLLING HER HEAD, ROLLING HER EYES IN TOTAL DISRESPECT OF YOUR HONOR AND THIS COURT.

17 MS. CLARK:

I'M NOT DISRESPECTFUL OF THIS COURT IN THE VERY LEAST. I HIGHLY RESPECT THIS COURT. MR. SHAPIRO'S REQUEST FOR SANCTIONS IS LUDICROUS GIVEN THE CONDUCT OF DEFENSE THROUGHOUT THIS TRIAL, IMPROPER QUESTIONS THAT HAVE BEEN ASKED BY DEFENSE COUNSEL REPEATEDLY AFTER THE COURT SUSTAINED THE PEOPLE'S OBJECTIONS. AND TO HEAR MR. SHAPIRO'S LACK OF ELOQUENCE ON THE SUBJECT OF SANCTIONS IS PREPOSTEROUS.

18 THE COURT:

BUT DO YOU AGREE REQUEST TO TAKE SOMEBODY AS A HOSTILE WITNESS SHOULD NOT BE ANNOUNCED TO THE JURY, BUT SHOULD BE ASKED AT SIDEBAR?

19 MS. CLARK:

WELL, I DIDN'T KNOW THAT, YOUR HONOR, AND I DO APOLOGIZE. IN ALL SINCERITY, I APOLOGIZE. HOWEVER, THE HOSTILITY OF THIS WITNESS TO THE PROSECUTION IS I THINK NO SECRET TO ANYONE IN THIS COURTROOM. BUT I DO APOLOGIZE TO THE COURT. AND IN THE FUTURE, I WILL CERTAINLY DO THAT AT SIDEBAR. I DIDN'T KNOW. YOU KNOW SOMETHING? I'VE NEVER HAD TO DO THIS BEFORE.

20 THE COURT:

NO. REQUEST -- THE REQUEST FOR LEAVE OF THE COURT TO TAKE SOMEBODY AS A HOSTILE WITNESS NEEDS TO BE DONE OUT OF THE PRESENCE OF THE JURY.

21 MS. CLARK:

I APOLOGIZE TO THE COURT. IN THE FUTURE -- I HOPE THERE WILL NOT BE A FUTURE OCCURRENCE, BUT IF THERE IS, I WILL.

22 THE COURT:

I'M SURE THERE WILL BE. SO I DO NEED TO TELL THE JURY IT'S NOT APPROPRIATE FOR YOU TO ASK FOR THAT IN FRONT OF THEM.

23 MS. CLARK:

YOUR HONOR --

24 THE COURT:

BECAUSE TO SUDDENLY ANNOUNCE THIS GUY IS A HOSTILE WITNESS, THAT'S FOR ME TO DECIDE, NOT FOR THEM TO DECIDE, NOT FOR YOU TO ANNOUNCE.

KEY QUOTE
25 MS. CLARK:

IT IS. BUT THE COURT WILL HAVE TO MAKE THAT RULING IN OPEN COURT IN FRONT OF THE JURY.

26 THE COURT:

NO. I MAKE THE RULING HERE, THAT I AM GOING TO ALLOW YOU TO TAKE HIM AS A HOSTILE WITNESS, WHICH MERELY MEANS YOU GET WIDER LEEWAY IN ASKING HIM LEADING QUESTIONS. BUT THAT'S ABOUT ALL THE BENEFIT YOU GET FROM THAT.

27 MS. CLARK:

RIGHT.

28 THE COURT:

YOU ARE NOT SUPPOSED TO ANNOUNCE THAT TO THE JURY IS THE POINT I'M MAKING.

29 MS. CLARK:

WELL, I APOLOGIZE TO THE COURT. I DIDN'T KNOW I WAS -- I DID NOT KNOW THAT WAS INAPPROPRIATE. I WISH I HAD KNOWN THAT. I WOULDN'T HAVE DONE IT. I DIDN'T KNOW. I DIDN'T KNOW. I DON'T THINK THAT SANCTIONS ARE APPROPRIATE.

30 THE COURT:

I CERTAINLY GAVE YOU AN OPPORTUNITY EARLIER TO DEEM HIM TO BE A HOSTILE WITNESS.

31 MS. CLARK:

YES. AND YOU KNOW SOMETHING? I REALLY WANTED TO RESIST IT. I DIDN'T WANT TO GET THIS TO THIS POINT, YOUR HONOR. I WAS TOSSING IT AROUND WITH MR. DARDEN WHETHER I SHOULD OR NOT AND FOR A LONG TIME, AND I'M PUSHED TO IT.

32 THE COURT:

MR. SHAPIRO.

33 MR. SHAPIRO:

YES. YOUR HONOR, WE WOULD CONCEDE THAT MR. KAELIN PRESENTS QUITE AN ENIGMA AS A WITNESS. HOWEVER, THERE IS NO SHOWING THAT HE IS HOSTILE TO EITHER SIDE OF THIS CASE. I THINK QUITE THE CONTRARY. I THINK HE IS TRYING TO ABSOLUTELY DO HIS BEST TO RELATE WHAT HE KNOWS. AND QUITE FRANKLY, IT IS NOT A TREMENDOUS AMOUNT THAT HE KNOWS, AND MOST OF THIS IS OVER SEMANTICS. "WHAT DO YOU MEAN BY THE WORD ANGRY? MILDLY ANGRY? SERIOUSLY ANGRY?" DEMEANOR IS VERY, VERY HARD TO RELATE TO, ESPECIALLY ON A QUESTION BY QUESTION BASIS AS IT WOULD BE IF ANYBODY WAS TRYING TO RELATE THE DEMEANOR OF THE THREE OF US AT COUNSEL -- AT THE SIDEBAR HERE. AND I THINK THAT THIS WITNESS, IF ASKED APPROPRIATE QUESTIONS, WILL GIVE RESPONSES THAT WILL BE APPROPRIATE SO THE JURY CAN FIND THE TRUTH. BUT THE COURT HAS ALREADY GIVEN THIS -- GIVEN THE PROSECUTION GREAT LATITUDE IN LEADING QUESTIONS.

KEY QUOTE
34 THE COURT:

I SUSPECT YOU GET TIRED OF MAKING OBJECTIONS IS WHAT HAPPENS.

35 MR. SHAPIRO:

NO. MR. COCHRAN CONTINUES TO COACH ME ON THOSE.

KEY QUOTE
36 THE COURT:

ALL RIGHT. ALL RIGHT. I AM GOING TO ALLOW THE PROSECUTION TO TAKE THE WITNESS AS A PROSECUTION WITNESS BECAUSE IT APPEARS TO ME THERE'S SOME CONFLICT HERE IN HIS --

37 MR. COCHRAN:

PROSECUTION WITNESS?

38 THE COURT:

I'M GOING TO ALLOW THEM TO TAKE HIM AS A HOSTILE WITNESS. HOWEVER, I'M GOING TO TELL THE JURY THAT THE DETERMINATION IS FOR ME TO MAKE OUT OF THEIR PRESENCE AND THEY ARE TO DISREGARD THE COMMENT BY COUNSEL. AND LET ME SEE. WHAT ELSE? HOW MUCH MORE DO YOU HAVE WITH THIS GUY?

39 MS. CLARK:

I MAY VERY WELL GO INTO NOON. UNFORTUNATELY, BECAUSE OF THE BREAK, I WOULD HAVE -- WE WOULD HAVE BEEN DONE WITH HIM TODAY IF WE DID NOT HAVE THAT BOMB SCARE STUFF.

40 THE COURT:

HOW MUCH MORE? YOU'VE ESTABLISHED, YOU KNOW, THAT HE DID AT ONE POINT IN TIME SAY THE DEFENDANT WAS ANGRY THAT AFTERNOON. WHAT MORE DO WE HAVE?

41 MS. CLARK:

ON THIS ISSUE?

42 THE COURT:

YES.

43 MS. CLARK:

I'M ALMOST DONE WITH THIS ISSUE.

44 THE COURT:

WHAT MORE DO YOU HAVE BESIDES THIS?

45 MS. CLARK:

EVENTS OF JUNE 12 AND THERE'S MORE, YOUR HONOR. THERE'S A LOT MORE.

46 THE COURT:

JUST GIVE ME A PREVIEW. WHAT ARE WE LOOKING AT?

47 MS. CLARK:

I CAN'T REMEMBER -- I WANT TO DISCUSS WITH HIM THE EVENT THAT TRANSPIRED AFTER THE LIMO DRIVER GOT THERE. JUST A COUPLE AREAS, YOUR HONOR. I CAN'T REMEMBER RIGHT NOW.

48 THE COURT:

ALL RIGHT. LET'S --

49 MS. CLARK:

I WOULD LIKE TO MOVE IT ALONG.

50 MR. SHAPIRO:

I WOULD SAY WE HAVE VERY, VERY LITTLE RECROSS AND WE WOULD LIKE TO FINISH TODAY.

51 THE COURT:

LET'S SEE HOW FAR WE GET. LET ME ASK THE BAILIFF WHAT ABSOLUTE TIME THAT WE HAVE TO GET OUT OF HERE FOR THE JUROR.

52 (THE FOLLOWING PROCEEDINGS WERE HELD IN OPEN COURT:)

Temperature

tense

Key Quotes (5)

Marcia Clark
THIS WITNESS HAS BECOME MORE AND MORE RELUCTANT. I WOULD LIKE TO POINT OUT TO THE COURT THE DISCREPANCIES IN THE WITNESS' TESTIMONY AND HIS DEMEANOR, WHICH DATES BACK TO AS EARLY AS JUNE THE 13TH AND FORWARD
Clark lays out the evidentiary basis for hostile witness designation, pointing to Kaelin's shifting accounts of domestic violence from forthcoming to minimizing.
Lance A. Ito
TO SUDDENLY ANNOUNCE THIS GUY IS A HOSTILE WITNESS, THAT'S FOR ME TO DECIDE, NOT FOR THEM TO DECIDE, NOT FOR YOU TO ANNOUNCE.
Ito clarifies the procedural rule Clark violated and why it prejudices jury deliberations.
Marcia Clark
I DIDN'T KNOW. I DIDN'T KNOW. I DON'T THINK THAT SANCTIONS ARE APPROPRIATE.
Clark's repeated insistence on ignorance of the rule — unusual for a senior prosecutor — while batting away Shapiro's sanctions request.
Robert Shapiro
WE WOULD CONCEDE THAT MR. KAELIN PRESENTS QUITE AN ENIGMA AS A WITNESS. HOWEVER, THERE IS NO SHOWING THAT HE IS HOSTILE TO EITHER SIDE OF THIS CASE.
Shapiro's concession that Kaelin is puzzling while arguing he isn't formally hostile — a careful distinction aimed at preserving examination constraints on the prosecution.
Robert Shapiro
MR. COCHRAN CONTINUES TO COACH ME ON THOSE.
Rare moment of levity at sidebar — Shapiro deflects Ito's observation that he seems tired of objecting by crediting Cochran as his coach.

Evidence (3)

Informal
911 tape from Nicole Brown Simpson, referenced as evidence of the domestic violence incident Kaelin downplayed at grand jury
discussed
Informal
Kaelin's statements to Shapiro on June 14th, in which he was forthcoming about the domestic violence situation
discussed as prior inconsistent statement
Informal
Kaelin's grand jury testimony six days after June 13th, in which he minimized the argument
discussed as prior inconsistent statement

Notable Exchanges (3)

Marcia ClarkLance A. Ito
Ito repeatedly corrects Clark for announcing the hostile witness designation in front of the jury; Clark apologizes multiple times and claims she did not know the procedural requirement.
corrective
Robert ShapiroMarcia Clark
Shapiro requests sanctions against Clark for courtroom conduct (eye-rolling, laughing); Clark calls the request 'ludicrous' and attacks the defense's own record of improper questions.
heated
Lance A. ItoMarcia Clark
Ito presses Clark on how much examination remains with Kaelin and what topics are left; Clark admits she cannot remember all areas she intended to cover.
procedural

Light Moments (2)

Robert Shapiro
Ito quips 'I suspect you get tired of making objections' to Shapiro, who responds that Cochran keeps coaching him on when to object.
Johnnie Cochran
Cochran interjects with a confused 'PROSECUTION WITNESS?' when Ito momentarily misstates 'hostile witness,' prompting Ito to self-correct.

Credibility Attacks (1)

⚔ Kato Kaelin
prior inconsistent statement
Clark contrasts Kaelin's forthcoming June 14th statements to Shapiro about domestic violence with his minimizing grand jury testimony six days later, arguing he has become 'more and more reluctant.'

Objections

None recorded
Proceeding 5429 • 52 utterances
Criminal Trial
Department 103
⚖️ Start
📂 MAR 27, 1995 📄 Sidebar: hostile witness
MAR 27, 1995 KRT DvH TD