Cross-examination of James Williams

📄 Cross-examination of James Williams — Wednesday, March 29, 1995

Address:

C:\DEPT103\CRIMINAL\1995\MAR\29\CROSS-EXAMINATION-OF-JAMES-WIL.DOC

TRIAL

▲ Day 47 of 167

◀ Direct examination of James Williams Sidebar: photographs ▶

Witness: James Williams
Examiner: Carl Douglas
Called by: Prosecution • Date: Wednesday, March 29, 1995 • Utterances: 107

Carl Douglas cross-examines James Williams, a LAX skycap who checked OJ Simpson's bags on the evening of June 12, 1994. Douglas methodically establishes that Williams handled dozens of bags per hour, that luggage tags are removed or crossed out when bags are re-checked, and that Williams could not see what Simpson was carrying as he walked away because Williams was busy getting the bags to the plane. The defense extracts that Simpson was carrying a small duffel bag.

# 1 MR. DOUGLAS:

THANK YOU, YOUR HONOR.

# 2

CROSS-EXAMINATION

# 3

BY MR. DOUGLAS:

# 4 Q:

MR. WILLIAMS, GOOD AFTERNOON, SIR.

# 5 A:

GOOD AFTERNOON.

# 6 Q:

MR. WILLIAMS, HOW LONG, SIR, HAD YOU BEEN WORKING AS A SKYCAP AS OF JUNE THE 12TH OF 1994?

# 7 A:

ABOUT A YEAR AND A HALF.

# 8 Q:

ABOUT A YEAR AND A HALF?

# 9 A:

YES.

# 10 Q:

AND SIR, TYPICALLY, WHAT WOULD BE THE NUMBER OF PASSENGERS THAT YOU WOULD CHECK BAGGAGE FOR IN A GIVEN -- SAY A GIVEN HOUR?

# 11 A:

THAT DEPENDS ON THE DAY, BECAUSE SOME DAYS ARE BUSIER THAN OTHER DAYS.

# 12 Q:

OKAY. WHAT WOULD BE YOUR AVERAGE IF YOU WERE TO ESTIMATE HOW MANY CUSTOMERS YOU TEND TO HANDLE IN A TYPICAL HOUR?

# 13 A:

IN A TYPICAL HOUR? OH, MAYBE FIFTEEN OR TWENTY MAYBE.

# 14 Q:

FIFTEEN TO TWENTY PER HOUR?

# 15 A:

YEAH.

# 16 Q:

AND FREQUENTLY EACH OF THESE PASSENGERS, THESE FIFTEEN OR TWENTY PER HOUR, WILL OFTEN HAVE MORE THAN ONE BAG, TRUE?

# 17 A:

YEAH.

# 18 Q:

SO IT WOULDN'T BE UNUSUAL FOR YOU TO SEE DOZENS OF BAGS IN ANY GIVEN HOUR, CONSIDERING ALL OF THE PASSENGERS THAT YOU ARE HANDLING, TRUE?

# 19 A:

TRUE, YES.

# 20 Q:

NOW, THERE CAME A TIME ON A SUNDAY EVENING YOU SAY WHEN THIS FELLOW CAME UP TO YOU ASKING ABOUT CHECKING IN SOME BAGGAGE, CORRECT?

# 21 A:

CORRECT.

# 22 Q:

AND LATER YOU REALIZED THAT THERE WAS A PASSENGER WITH THIS PERSON WHO WAS MR. SIMPSON, TRUE?

# 23 A:

EXCUSE ME? REPEAT THE QUESTION.

# 24 Q:

YOU LATER REALIZED THAT THIS PERSON THAT HAD COME TO YOU WAS HANDLING BAGS FOR MR. SIMPSON?

# 25 A:

YES.

# 26 Q:

AND MR. SIMPSON CAME TO YOU ON A SUNDAY EVENING, DIDN'T HE?

# 27 A:

YES.

# 28 Q:

HE DIDN'T COME THE NEXT DAY ON MONDAY EVENING AS WELL, DID HE?

# 29 A:

NO.

# 30 Q:

AND PART OF THE PROCESS OF YOUR CHECKING IN THE BAGGAGE WAS TO VERIFY MR. SIMPSON'S FLIGHT SCHEDULE ON THE COMPUTER THERE, CORRECT?

# 31 A:

CORRECT.

# 32 Q:

AND YOU WERE ABLE TO VERIFY THAT MR. SIMPSON WAS IN FACT BOOKED ON A FLIGHT THAT EVENING, DIDN'T YOU?

# 33 A:

YES.

# 34 Q:

NOW, THERE IS CERTAIN INFORMATION THAT YOU PUT INTO THE COMPUTER BEFORE ONE OF THESE CLAIM CHECKS ARE PRINTED OUT, CORRECT?

# 35 A:

UH-HUH, YES.

# 36 Q:

PART OF THE INFORMATION THAT YOU PUT IN WOULD BE THE DESTINATION OF THE PASSENGER?

# 37 A:

YEAH. I CAN TELL YOU EXACTLY WHAT I -- THE FIRST THING YOU HAVE TO PUT IN IS HOW MANY BAGS ARE CHECKED, WHAT IS THE FLIGHT NUMBER, FINAL DESTINATION, NAME OF THE PASSENGER AND HOW MANY PEOPLE ARE IN THE PARTY.

# 38 Q:

OKAY. AND WHAT IS YOUR PRACTICE, SIR, WHEN THERE IS AN OLD TAG ON THE BAG THAT YOU ARE GOING TO CHECK IN? IS IT YOUR PRACTICE TO TAKE OFF THE OLD TAGS FIRST?

# 39 A:

YEAH, EITHER TAKE IT OFF OR SCRIBBLE IT, MARK OVER IT, SO IT DOESN'T INTERFERE WITH THE BAG.

# 40 Q:

AND THAT IS SO THAT THE BAGGAGE HANDLERS WILL NOT CONFUSE ONE DESTINATION FROM AN OLD TAG, AS OPPOSED TO THE CURRENT DESTINATION, CORRECT?

# 41 A:

YEAH, UH-HUH.

# 42 Q:

NOW, EVERY BAG THAT IS CHECKED IN HAS TO HAVE A LUGGAGE TAG PLACED ON IT, DOESN'T IT?

# 43 A:

YES.

# 44 Q:

AND WHEN THERE IS A BAG THAT SOMEONE IS TAKING ON THE AIRPLANE WITH THEM, THERE IS NO NEED TO CHECK THAT BAG IN NECESSARILY, CORRECT?

# 45 A:

CORRECT. IF THEY ARE TAKING IT ON, YOU DON'T CHECK IT IN.

# 46 Q:

SO IF SOMEBODY IS CARRYING A BAG -- LET'S SAY THAT SOMEBODY IS CARRYING A BAG TO LOS ANGELES FROM CHICAGO THAT THEY HAD CHECKED IN IN LOS ANGELES TO CHICAGO, BUT THEY CARRIED THAT BAG ON THE AIRPLANE WITH THEM BACK FROM CHICAGO, THERE WOULDN'T BE AN LAX TAG ON THAT PARTICULAR BAG, WOULD THERE?

# 47 A:

YOU ARE SAYING HE -- OKAY. HE CHECKED IT IN L.A.?

# 48 Q:

LET'S ASSUME, FOR EXAMPLE, LET'S TAKE THE GARMENT BAG, WHICH WOULD BE EXHIBIT 1062.

# 49 A:

OKAY.

# 50 Q:

AND IF THIS TAG HAS CERTAIN INFORMATION, THIS MEANS THAT THIS PIECE OF LUGGAGE WAS CHECKED IN FROM LOS ANGELES TO CHICAGO, CORRECT?

# 51 A:

CORRECT.

# 52 Q:

AND THEN IT WAS PLACED ON A CONVEYOR BELT TO GO TO THE AIRPLANE, CORRECT?

# 53 A:

YES.

# 54 Q:

AND IF THE PERSON WHO OWNED THIS BAG BROUGHT IT BACK FROM CHICAGO ON THE AIRPLANE WITH HIM --

# 55 A:

UH-HUH.

# 56 Q:

-- IT WOULD STILL HAVE THE ORD TAG ON IT, WOULDN'T IT?

# 57 A:

YEAH, UNLESS HE TOOK IT OFF, IT WOULD STAY ON THERE.

KEY QUOTE

# 58 Q:

OKAY. AND IF, FOR EXAMPLE, THAT SAME PERSON WAS BRINGING BACK NOT ONLY THE BAG THAT HE IS CARRYING ON, BUT ANOTHER BAG THAT THEY ARE CHECKING IN IN CHICAGO TO COME TO LOS ANGELES, IT WOULD BE THE PRACTICE TO TAKE OFF THAT OLD TAG, WOULD IT NOT?

# 59 A:

YEAH, YOU USUALLY TAKE THE WHOLE TAG OFF BECAUSE YOU DON'T WANT THEM TO --

# 60 MS. CLARK:

OBJECTION. OBJECTION. THIS WOULD CALL FOR SPECULATION. IT IS BEYOND THE SCOPE AND ALSO IRRELEVANT.

# 61 THE COURT:

OVERRULED. OVERRULED.

# 62 Q:

BY MR. DOUGLAS: SO THAT YOU CANNOT TELL WHETHER OR NOT THIS GOLF CLUB BAG WAS CHECKED IN AT LAX TO CHICAGO BECAUSE YOU DON'T HAVE THAT TAG ON THERE, CORRECT?

# 63 A:

WELL, YEAH.

# 64 Q:

BUT YOU CAN TELL THAT THIS BAG WAS CHECKED INTO CHICAGO TO COME BACK TO LOS ANGELES ON JUNE 13TH, TRUE?

# 65 A:

YES.

# 66 Q:

NOW, YOU TALKED SOMETHING ABOUT THERE BEING A TRASH CAN SOMEWHERE NEAR THE AREA WHERE YOU ARE WORKING?

# 67 A:

YES.

# 68 Q:

AND YOU WOULD HAVE OCCASION, WOULD YOU NOT, TO LOOK INTO THAT TRASH CAN TO SEE -- TO THROW THINGS AWAY, WOULDN'T YOU?

# 69 A:

JUST -- I JUST USE TO IT THROW THINGS AWAY, BECAUSE THE WAY THE TRASH CAN IS DESIGNED, YOU JUST THROW IT IN THE FRONT AND IT JUST GOES DOWN THERE. THERE IS LIKE A COVER OVER IT.

# 70 Q:

AND YOU NEVER HEARD ANY INFORMATION ABOUT THERE BEING ANY LUGGAGE RECOVERED FROM ANY TRASH CANS NEAR YOUR AREA, DID YOU?

# 71 A:

NO, NOT TO MY KNOWLEDGE. I NEVER HEARD ANYTHING LIKE THAT.

# 72 Q:

NOW, YOU SAID THAT WHEN YOU SAW MR. SIMPSON ON JUNE THE 12TH THAT HE WAS WEARING A JEAN-TYPE SHIRT, WASN'T HE?

# 73 A:

YES.

# 74 Q:

AND THAT SHIRT WAS NOT TUCKED INTO HIS PANTS, WAS IT?

# 75 A:

NO.

# 76 Q:

AND YOU RECALL THAT HE HAD A WHITE SHIRT ON UNDERNEATH THAT JEAN-TYPE SHIRT? DO YOU RECALL THAT?

# 77 A:

I JUST REMEMBER A LIGHT -- LIGHT-COLORED SHIRT.

# 78 Q:

OKAY. DO YOU RECALL EVER SEEING HIM CARRYING AN OVERCOAT THAT EVENING?

# 79 A:

I CAN'T RECALL.

# 80 Q:

YOU DON'T RECALL THAT?

# 81 A:

NO, I CAN'T RECALL.

# 82 Q:

NOW, THERE CAME A TIME THAT YOU SAID MR. SIMPSON GAVE YOU A TIP FOR YOUR SERVICES, DID HE NOT?

# 83 A:

YES.

# 84 Q:

AND HE GAVE YOU A TWENTY DOLLAR BILL?

# 85 A:

YES, HE DID.

# 86 Q:

AND YOU GAVE HIM BACK AS CHANGE TWO FIVES; IS THAT CORRECT?

# 87 A:

YES, MA'AM.

# 88 Q:

WAS THAT ALL THE CHANGE THAT YOU THEN HAD IN YOUR POSSESSION, THAT YOU RECALL?

# 89 A:

I MEAN I HAD OTHER MONEY ON ME, BUT I JUST, YOU KNOW, GAVE HIM TWO FIVES. I DIDN'T WANT TO COUNT OUT SINGLES.

# 90 Q:

AS HE WAS WALKING AWAY DID YOU HAVE OCCASION TO STARE AT HIM WHEN HE WAS WALKING AWAY OR WERE YOU HANDLING OTHER WORK?

# 91 A:

I WAS TRYING TO GET HIS BAGS ON FOR HIM. THE WAY HE GOES, THERE IS AN ESCALATOR AND BEHIND THE ESCALATOR THERE IS A BELT FOR OVERSIZED ITEMS, FOR GOLF CLUBS, BUT REALIZING HE WAS RUNNING A LITTLE BEHIND SCHEDULE, I JUST TOOK THEM DOWN THE BACK WAY AND WALKED THEM HALFWAY TO THE PLANE.

# 92 Q:

SO AFTER HE GAVE YOU THE TIP YOU THEN TRIED TO PUT THE BAGS ON THAT SPECIAL BELT FOR HIM?

# 93 A:

YES.

# 94 Q:

YOU DIDN'T FOCUS YOUR ATTENTION ON HIM WALKING AWAY FROM YOU GOING TO THE AIRPLANE?

# 95 A:

I JUST FIGURED HE WENT UP TO THE PLANE BECAUSE HE HAD TO MAKE THE FLIGHT.

# 96 Q:

SO YOU DIDN'T REALLY HAVE A CHANCE TO SEE WHAT, IF ANYTHING, HE WAS CARRYING IN HIS HAND WHILE YOU WERE PUTTING THE GOLF BAG ONTO THAT SPECIAL BELT, DID YOU?

# 97 A:

ASIDE FROM THE SMALL LITTLE DUFFEL BAG.

KEY QUOTE

# 98 MR. DOUGLAS:

THANK YOU VERY MUCH. ONE MOMENT, PLEASE.

# 99 (DISCUSSION HELD OFF THE RECORD BETWEEN DEFENSE COUNSEL.)

# 100 MR. DOUGLAS:

NO FURTHER QUESTIONS.

# 101 THE COURT:

MISS CLARK, ANY REDIRECT?

# 102 MS. CLARK:

MAY I HAVE ONE MOMENT, YOUR HONOR?

# 103 THE COURT:

CERTAINLY.

# 104 JAMES WILLIAMS:

I DON'T MEAN TO BE A BURDEN, BUT IS THERE ANYWAY I CAN GET SOME MORE WATER? I'M THIRSTY.

# 105 THE COURT:

MRS. ROBERTSON.

# 106 MR. DOUGLAS:

YOUR HONOR, MAY WE APPROACH ABOUT SOME PHOTOGRAPHS?

# 107 THE COURT:

SURE.

Temperature

procedural

Key Quotes (3)

James Williams

ASIDE FROM THE SMALL LITTLE DUFFEL BAG.

Williams confirms Simpson had a duffel bag when leaving — relevant to the defense's or prosecution's account of what bags Simpson had that night.

James Williams

YEAH, UNLESS HE TOOK IT OFF, IT WOULD STAY ON THERE.

Supports the defense's point that a bag returning from Chicago could still have an ORD tag — the golf bag's tag history doesn't prove it was checked at LAX that night.

James Williams

I JUST TOOK THEM DOWN THE BACK WAY AND WALKED THEM HALFWAY TO THE PLANE.

Explains why Williams lost sight of Simpson — he was preoccupied getting the bags to the plane, undermining any claim he carefully observed Simpson's departure.

Evidence (2)

Exhibit 1062

Garment bag with luggage tag showing LAX-to-Chicago routing

discussed to illustrate how bag tags work and what can be inferred about a bag's travel history

Informal

Golf club bag with ORD (Chicago) tag

discussed — Douglas establishes the tag shows Chicago-to-LAX routing on June 13, but does not prove whether it was checked at LAX going to Chicago or carried on

Notable Exchanges (2)

Carl Douglas•James Williams

Douglas walks Williams through a hypothetical: if a bag was carried on returning from Chicago, it would still have an ORD tag — establishing the golf bag tag alone doesn't prove it was checked at LAX that night.

strategic

Carl Douglas•James Williams

Douglas establishes that Williams was not watching Simpson walk away — he was busy getting bags to the plane — so Williams could not observe what Simpson was carrying or wearing as he departed.

revealing

Light Moments (1)

James Williams

Witness interrupts off-record discussions to ask for more water: 'I DON'T MEAN TO BE A BURDEN, BUT IS THERE ANYWAY I CAN GET SOME MORE WATER? I'M THIRSTY.'

Credibility Attacks (1)

⚔ James Williams

scope of observation

Douglas establishes Williams handles 15-20 passengers per hour with multiple bags each, and that he was not watching Simpson depart — undermining the weight of any specific observations Williams made about Simpson's belongings or appearance.

Witness Demeanor

Cooperative and straightforward throughout

Occasionally asked for clarification on hypotheticals

Relaxed enough to make a personal request (water) during a break in questioning

Objections

1 objections (0 sustained, 1 overruled)

Proceeding 5487 • 107 utterances • Prosecution witness

Criminal Trial

Department 103