📄 Sidebar: objection and foundation — Thursday, March 9, 1995
Address:
C:\DEPT103\CRIMINAL\1995\MAR\9\SIDEBAR-OBJECTION-AND-FOUNDATI.DOC
TRIAL
▲ Day 34 of 167

Sidebar: objection and foundation

Date: Thursday, March 9, 1995 • Utterances: 42
A sidebar during cross-examination of an expert witness (likely a pathologist) over whether Cochran had properly laid foundation to use a medical publication to cross-examine the witness. Clark objected that the witness had not actually relied on the publication; Ito agreed there was a missing foundational step and sustained the objection, while explaining to Cochran exactly what question he needed to ask to cure the defect.
1 (THE FOLLOWING PROCEEDINGS WERE HELD AT THE BENCH:)
2 THE COURT:

MISS CLARK. OBJECTION.

3 MS. CLARK:

OBJECTION. NO. 1 THING IS THAT THE PROCEDURE IS TO SEE IF HE AGREES OR NOT WITH THE PASSAGE IS TO LET HIM READ IT TO HIMSELF; NOT TO DRAG IN ALL THE HEARSAY FROM THIS ARTICLE.

4 THE COURT:

I AGREE AND I SUSTAINED THE OBJECTION.

5 MS. CLARK:

THAT IS WHAT HE IS DOING AGAIN.

6 THE COURT:

NO, THAT IS NOT THE QUESTION. DIFFERENT QUESTION.

7 MR. COCHRAN:

MAY I BE HEARD?

8 MS. CLARK:

WHICH ONE?

9 THE COURT:

WAIT, WAIT, WAIT.

10 MS. CLARK:

AGAIN ON THE SAME PAGE, YOUR HONOR.

11 (BRIEF PAUSE.)
12 THE COURT:

THE QUESTION WAS DID YOU AGREE WITH THE STATEMENT THAT --

13 MS. CLARK:

THEN HE WAS ABOUT TO READ AGAIN FROM THE PASSAGE.

14 MR. COCHRAN:

I WASN'T GOING TO READ. I WAS GOING TO SUMMARIZE -- I THINK I AM PERMITTED TO SUMMARIZE. HE RELIED UPON THIS, JUDGE, AND THE PROBLEM IS --

15 MS. CLARK:

HE DIDN'T.

16 MR. COCHRAN:

PUT THIS TACTFULLY. IF YOU NEVER TRIED A CIVIL CASE AND DEALT WITH DOCTORS, IT IS VERY DIFFICULT. IN THESE KIND OF CASES YOU ARE PERMITTED TO GO INTO WHAT THIS MAN HAS RELIED UPON AND WHAT HE HAS LOOKED AT IN THE PAST AND WHAT -- HE IS THE ONE WHO TOLD US ABOUT THIS PUBLICATION, SO I WANT TO ASK HIM IF HE SAYS HE RELIED UPON THIS. I CAN THEN ASK HIM WHETHER OR NOT -- NOT HEARSAY -- WHETHER OR NOT HE AGREES WITH THE PRINCIPLE THAT STOMACH CONTENTS ARE PRESENT, THAT A PATHOLOGIST WITH REASONABLE ACCURACY CAN LOOK AT THAT AND DETERMINE WHEN THE LAST MEAL WAS -- WHAT IT CONSISTED OF AND WHEN IT WAS AND THE TIME OF DEATH. HE SAID HE GENERALLY AGREES WITH THIS, SO I CAN'T BE PRECLUDED BECAUSE OF THAT AND THAT IS THE POINT I'M TRYING TO GET. I DON'T KNOW IF COUNSEL FULLY UNDERSTANDS WHAT I WILL BE PERMITTED TO DO ONCE HE RELIES UPON A PUBLICATION.

KEY QUOTE
17 MS. CLARK:

THE PROBLEM IS THAT COUNSEL DOESN'T SEEM TO UNDERSTAND THIS IS NOT A CIVIL CASE, THIS IS A MURDER CASE. NO. 2, THE WITNESS DID NOT RELY ON IT.

KEY QUOTE
18 THE COURT:

THE SAME --

19 MR. COCHRAN:

SAME EVIDENCE CODE.

20 MS. CLARK:

THE WITNESS SAID HE DID NOT RELY ON THIS. HOW MANY TIMES DID HE HAVE TO TELL --

21 THE COURT:

MISS CLARK, THE OBJECTION IS FOUNDATION?

22 MS. CLARK:

FOUNDATION.

23 MR. COCHRAN:

THAT IS VERY EASY AND I WOULD ASK THE COURT AGAIN THAT IF -- EITHER SIDE DOESN'T NEED ANY HELP IN THIS CASE. THE PROBLEM IS IF HE SAYS WAIT A MINUTE, HE IS GOING TO MAKE ME BRING HIM BACK. HE SAID HE DIDN'T RELY UPON IT. HE SAID A READ A LATER EDITION MAYBE TEN OR FIFTEEN YEARS AND I ASKED TO HIM LOOK AT THIS BECAUSE CERTAIN PASSAGES DON'T CHANGE. ARE WE PLAYING GAMES OR ARE TRYING TO GET AT THE TRUTH?

24 THE COURT:

WELL, MR. COCHRAN, AT THE RISK OF HELPING ONE SIDE OR ANOTHER, WE ARE MISSING ONE FOUNDATIONAL QUESTION. YOU HAVE ASKED HIM THE QUESTION DOES THIS APPEAR TO BE CONSISTENT WITH WHAT WAS IN THE EDITION YOU READ? AND HE SAID YES. IS THIS THE INFORMATION THAT YOU -- SOME OF THE INFORMATION THAT YOU RELIED UPON IN FORMING YOUR OPINION? HE HASN'T SAID YES OR NO TO THAT QUESTION BECAUSE NOBODY HAS ASKED HIM. YOU HAVE ESTABLISHED THAT IT IS SIMILAR TO WHAT HE READ. YOU HAVEN'T ESTABLISHED --

25 MR. COCHRAN:

OKAY.

26 THE COURT:

-- THAT THIS IS WHAT HE RELIED UPON, SO THERE IS A GOOD FOUNDATION OBJECTION AT THIS POINT.

27 MR. COCHRAN:

OKAY. IF I AM ABLE TO ESTABLISH --

28 THE COURT:

IT IS A TECHNICALITY, BUT THAT IS WHAT THE EVIDENCE CODE SAYS.

KEY QUOTE
29 MR. COCHRAN:

OKAY.

30 THE COURT:

YOU ARE MISSING A STEP AND A HALF.

KEY QUOTE
31 MR. COCHRAN:

THANK YOU.

32 THE COURT:

SUSTAINED.

33 MR. COCHRAN:

OKAY. IF HE DOES, SO WE DON'T HAVE TO COME BACK UP HERE, THREE OR FOUR ALREADY, IF HE DOES, IF HE DID RELY UPON THIS AS PART OF THE PUBLICATION, THEN I AM THEN PERMITTED TO ASK HIM ABOUT CERTAIN THINGS CONTAINED HEREIN; AM I NOT?

34 THE COURT:

IF HE DOES SAY THAT, YEAH, YOU CAN CROSS-EXAMINE.

35 MR. COCHRAN:

JUST SO WE UNDERSTAND THAT.

36 THE COURT:

WAIT. NOW --

37 (DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)
38 THE COURT:

MISS CLARK, CAN I HAVE YOUR ATTENTION?

39 MS. CLARK:

YES.

40 THE COURT:

LET ME GET EVERYBODY'S CLEAR UNDERSTANDING NOW. IT IS OBJECTION AND THEN STATE THE GROUNDS; NOT ARGUE IT. STATE THE GROUNDS. ALL RIGHT.

KEY QUOTE
41 MR. COCHRAN:

THANK YOU.

42 THE COURT:

THANK YOU.

Temperature

tense

Key Quotes (5)

Johnnie Cochran
PUT THIS TACTFULLY. IF YOU NEVER TRIED A CIVIL CASE AND DEALT WITH DOCTORS, IT IS VERY DIFFICULT.
Cochran subtly jabs at Clark's civil-case inexperience while arguing for a broader evidentiary rule borrowed from civil practice.
Marcia Clark
THE PROBLEM IS THAT COUNSEL DOESN'T SEEM TO UNDERSTAND THIS IS NOT A CIVIL CASE, THIS IS A MURDER CASE.
Clark fires back directly, rejecting Cochran's civil-practice analogy and reframing the stakes.
Lance A. Ito
YOU ARE MISSING A STEP AND A HALF.
Ito's concise diagnosis of exactly where Cochran's foundation broke down — unusually helpful and direct.
Lance A. Ito
IT IS A TECHNICALITY, BUT THAT IS WHAT THE EVIDENCE CODE SAYS.
Ito acknowledges the ruling is formalistic but enforces it anyway, signaling he will hold both sides to strict procedure.
Lance A. Ito
LET ME GET EVERYBODY'S CLEAR UNDERSTANDING NOW. IT IS OBJECTION AND THEN STATE THE GROUNDS; NOT ARGUE IT.
Ito uses the end of the sidebar to reset courtroom decorum, reminding both sides of proper objection protocol.

Evidence (1)

Informal
A medical/pathology publication (an older edition) containing passages about stomach contents and time-of-death determination
disputed — Cochran attempting to use it to cross-examine expert; Clark and Ito find foundation lacking

Notable Exchanges (2)

Johnnie CochranMarcia Clark
Cochran argues civil-case evidentiary rules should apply to expert reliance on publications; Clark sharply rejects the analogy, reminding him this is a murder case.
heated
Lance A. ItoJohnnie Cochran
Ito walks Cochran through the exact missing foundational question he needs to ask — whether the witness relied on this specific publication in forming his opinion — allowing Cochran to cure the defect.
strategic

Credibility Attacks (1)

⚔ pathology expert (unnamed)
impeachment via learned treatise
Cochran attempting to use a pathology publication to challenge or confirm the expert's opinions on stomach contents and time-of-death estimation; blocked by lack of foundation establishing the witness actually relied on this edition.

Witness Demeanor

(BRIEF PAUSE.)
(DISCUSSION HELD OFF THE RECORD BETWEEN THE DEPUTY DISTRICT ATTORNEYS.)

Objections

2 objections (2 sustained, 0 overruled)
Proceeding 5222 • 42 utterances
Criminal Trial
Department 103
⚖️ Start
📂 MAR 9, 1995 📄 Sidebar: objection and foundat
MAR 9, 1995 KRT DvH TD