Direct examination of Teresa Ramirez (part 1)

📄 Direct examination of Teresa Ramirez (part 1) — Wednesday, September 13, 1995

Address:

C:\DEPT103\CRIMINAL\1995\SEP\13\DIRECT-EXAMINATION-OF-TERESA-R.DOC

TRIAL

▲ Day 153 of 167

◀ Witness preparation Sidebar: videotape evidence ▶

Witness: Teresa Ramirez
Examiner: Marcia Clark
Called by: Prosecution • Date: Wednesday, September 13, 1995 • Utterances: 174

Marcia Clark calls Teresa Ramirez, a DA's office photographer, to explain the 14-minute gap in the videotaped Thano Peratis interview from July 27, 1995. Ramirez testifies that the gap occurred while Peratis hooked up his multi-VCR entertainment system so they could review the tape on his TV, and that no one was interviewing him about the case during that time. She also admits she started recording late when the interview resumed, missing Oppler's resumption announcement and Goldberg's follow-up question.

# 1 THE COURT:

All right. Thank you, ladies and gentlemen. Have a seat, please. All right. Miss Clark, you may call the People's next witness.

# 2 MS. CLARK:

Thank you, your Honor. The People call Teresa Ramirez.

# 3 THE COURT:

All right. Miss Ramirez, come forward, please.

Teresa Ramirez, called as a witness by the People on rebuttal, was sworn and testified as follows:

# 4 THE CLERK:

Raise your right hand, please. You do solemnly swear that the testimony you may give in the cause now pending before this court, shall be the truth, the whole truth and nothing but the truth, so help you God?

# 5 MS. RAMIREZ:

Yes, I do.

# 6 THE CLERK:

Please have a seat in the witness stand and state and spell your first and last names for the record.

# 7 MS. RAMIREZ:

T-E-R-E-S-A, last name R-A-M-I-R-E-Z.

# 8 THE CLERK:

Thank you.

# 9 THE COURT:

Miss Clark.

# 10 MS. CLARK:

Thank you, your Honor.

DIRECT EXAMINATION BY MS. CLARK

# 11 MS. CLARK:

Miss Ramirez, can you tell us what you do for a living?

# 12 MS. RAMIREZ:

I'm a photographer for the Bureau of Investigation of Los Angeles county District Attorney's office.

# 13 MS. CLARK:

And do you work in what we call the photo lab in the D.A.'s office?

# 14 MS. RAMIREZ:

Yes.

# 15 MS. CLARK:

Directing your attention to the date of July 27th, 1995, did you perform the videotaping of an interview of Thano Peratis?

# 16 MS. RAMIREZ:

Yes.

# 17 MS. CLARK:

And in order to do that, did you go to the home of Thano Peratis?

# 18 MS. RAMIREZ:

Yes.

# 19 MS. CLARK:

And who was with you?

# 20 MS. RAMIREZ:

Uh, Hank Goldberg.

# 21 MS. CLARK:

Is he a D.A.?

# 22 MS. RAMIREZ:

Yes.

# 23 MS. CLARK:

Do you see him here in the courtroom?

# 24 MS. RAMIREZ:

Yes.

# 25 MS. CLARK:

Back there (Indicating)?

# 26 MS. RAMIREZ:

Yes.

# 27 MS. CLARK:

Okay. Who else?

# 28 MS. RAMIREZ:

Stephen Oppler.

# 29 MS. CLARK:

Was that a D.A. investigator?

# 30 MS. RAMIREZ:

Yes.

# 31 MS. CLARK:

And is that somebody who testified in court today?

# 32 MS. RAMIREZ:

Yes.

# 33 MS. CLARK:

Did you see him testify on television today?

# 34 MS. RAMIREZ:

Yes.

# 35 MS. CLARK:

Did you watch all of his testimony?

# 36 MS. RAMIREZ:

Excuse me?

# 37 MS. CLARK:

Did you watch all of his testimony?

# 38 MS. RAMIREZ:

No.

# 39 MS. CLARK:

Okay. And who else was there? There was you, Steve Oppler, Hank Goldberg and--

# 40 MS. RAMIREZ:

Mr. Peratis. He lives there.

# 41 MS. CLARK:

And did you perform the videotaping of the interview conducted by Hank Goldberg?

# 42 MS. RAMIREZ:

Yes.

# 43 MS. CLARK:

At some point, did the interview stop?

# 44 MS. RAMIREZ:

Yes.

# 45 MS. CLARK:

And at some point thereafter, did the interview resume again?

# 46 MS. RAMIREZ:

Yes.

# 47 MS. CLARK:

In-between the time that the interview stopped and it started, can you tell us what occurred?

# 48 MS. RAMIREZ:

I noticed that Mr. Peratis had very nice television set and I ask him if we could check the tape on his set, if we could watch it on his TV, and he agreed, but he had to go and change--I don't know. He rehook it up or something.

KEY QUOTE

# 49 MS. CLARK:

So did he go into another room at that point?

# 50 MS. RAMIREZ:

It was like a little--next to where I was standing, it was like a little--bigger than a closet. He had a lot of tapes and cables. He went in there, took some cables, went behind the TV and the VCR and hook it up.

# 51 MS. CLARK:

And did he do the actual hookup himself for you?

# 52 MS. RAMIREZ:

Yes.

# 53 MS. CLARK:

Your Honor, I wonder if we could play Defense exhibit 13--

# 54 THE COURT:

1375.

# 55 MS. CLARK:

Thank you.

# 56 THE COURT:

Mrs. Robertson, do you have 1375?

# 57 THE CLERK:

Yes.

# 58 THE COURT:

All right.

# 59 MS. CLARK:

Now, I'm going to show you a segment of tape and ask if you recognize it. I think.

# 60 (Brief pause.)

# 61 (At 4:57 P.M., People's exhibit 615, a videotape, was played.)

# 62 MS. CLARK:

Do you recognize this tape, Miss Ramirez?

# 63 MS. RAMIREZ:

Yes.

# 64 MS. CLARK:

All right. Is this the videotape you did of Thano Peratis in the company of Hank Goldberg and Steve Oppler on November 27th, 1995?

# 65 MS. RAMIREZ:

Yes.

# 66 MS. CLARK:

And did you operate the video camera?

# 67 MS. RAMIREZ:

Yes.

# 68 MS. CLARK:

All right. Now, you see the time there? Is that--you see the time 3:59 there?

# 69 MS. RAMIREZ:

Yes.

# 70 MS. CLARK:

Okay.

# 71 MS. CLARK:

No, go ahead. Keep it running. Can we back up for a minute? Just back up to 3:59. Thanks.

# 72 (At 4:58 P.M., People's exhibit 615, a videotape, continues playing.)

# 73 (At 4:58, the playing of the videotape was concluded.)

# 74 MS. CLARK:

All right. Okay. You saw that 3:59, then you heard a voice, "I'm going to conclude my audiotape"?

# 75 MS. RAMIREZ:

Yes.

# 76 MS. CLARK:

And whose voice was that?

# 77 MS. RAMIREZ:

Oppler.

# 78 MS. CLARK:

Okay. And then you saw the tape resume at 4:13?

# 79 MS. RAMIREZ:

Yes.

# 80 MS. CLARK:

What happened between 3:59 and when you resumed the tape at 4:13?

# 81 MS. RAMIREZ:

Mr. Peratis hooked up his TV so we could watch the tape. We watched the tape just for a minute or two probably.

# 82 MS. CLARK:

Okay. How long did it take for him to hook up the TV so you could watch the tape?

# 83 MS. RAMIREZ:

Few minutes because first he checked why the TV was not hooked up properly. Then he hook it up, then he check that it work again. Then we played the tape I did, and then Hank said that he had another question. So I had to cue the tape to the end, put the camera back on the tripod, put the tape back in there and start again. But--

# 84 MS. CLARK:

All right. So--I'm sorry.

# 85 MS. RAMIREZ:

But I missed--we showing--when we videotape somebody, we--the investigator that is conducting the interview says that we were off for few minutes or whatever, and I missed that part on the videotape. So when the tape starts again, Mr. Peratis is already answering to the question. So I probably missed, I don't know, up to a minute.

KEY QUOTE

# 86 MS. CLARK:

Okay. You--so you started the tape a little late; is that right?

# 87 MS. RAMIREZ:

Yes.

# 88 MS. CLARK:

And you missed the part where Mr. Oppler announced that you had been off tape for a while and you're resuming?

# 89 MS. RAMIREZ:

Yes.

# 90 MS. CLARK:

And did you miss Mr. Goldberg's question?

# 91 MS. RAMIREZ:

Yes.

# 92 MS. CLARK:

Is there anything else you missed?

# 93 MS. RAMIREZ:

No.

# 94 MS. CLARK:

During the time that you were setting up--Mr. Peratis was setting up the cable on the television so you could watch the tape, were you talking to him?

# 95 MS. RAMIREZ:

To who? Excuse me.

# 96 MS. CLARK:

To Mr. Peratis.

# 97 MS. RAMIREZ:

I don't remember.

# 98 MS. CLARK:

Was anyone questioning him?

# 99 MR. NEUFELD:

Objection. Hearsay.

# 100 THE COURT:

Overruled.

# 101 MS. RAMIREZ:

No.

# 102 MS. CLARK:

Was Mr. Goldberg interviewing him during the time the videotape was off?

# 103 MS. RAMIREZ:

No.

# 104 MS. CLARK:

Did you discuss anything with Mr. Peratis concerning the case?

# 105 MS. RAMIREZ:

No.

# 106 MS. CLARK:

Did he make any--did you make any remark to him about his equipment?

# 107 MS. RAMIREZ:

Yes.

# 108 MS. CLARK:

What was that?

# 109 MR. NEUFELD:

Objection. Objection. Hearsay.

# 110 THE COURT:

Sustained.

# 111 MS. CLARK:

Not for the truth of the matter, your Honor.

# 112 THE COURT:

All right. Does this explain subsequent conduct with regards to the television equipment?

# 113 MS. CLARK:

Yes.

# 114 THE COURT:

All right. Proceed.

# 115 MS. RAMIREZ:

I made a comment about his impressive television set, and he had more than one VCR, at least four.

# 116 MS. CLARK:

Okay. And so did that have some impact on the manner in which he was setting up the cables and connecting the TV to the cables--

# 117 MR. NEUFELD:

Objection.

# 118 THE COURT:

Sustained. Leading.

# 119 MS. CLARK:

I'm sorry. And why were you discussing that?

# 120 MS. RAMIREZ:

As part of my job, I work with VCR's and television sets and cameras. So I--I ask him to play the tape because I wanted to see how it worked.

# 121 MS. CLARK:

Was--did his system appear complex to you?

# 122 MS. RAMIREZ:

Yes.

# 123 MS. CLARK:

Was there more than one piece of equipment there?

# 124 MS. RAMIREZ:

Yes.

# 125 MS. CLARK:

How many pieces of equipment did he have?

# 126 MS. RAMIREZ:

It was one television monitor and I remember that there were at least four VCR's plus some stereo equipment and speakers, receivers.

KEY QUOTE

# 127 MS. CLARK:

Four VCR's?

# 128 MS. RAMIREZ:

Yes.

# 129 MS. CLARK:

So did you discuss that with him?

# 130 MR. NEUFELD:

Objection as to what they discussed.

# 131 THE COURT:

Overruled. You can answer the question.

# 132 MS. RAMIREZ:

I made a comment about his nice equipment. He said he didn't like to miss shows while he was at work.

# 133 MS. CLARK:

Okay. Now, during the course of that conversation, was he attempting to do anything with respect to the cable, the television and the VCR's?

# 134 MS. RAMIREZ:

Yes. He moved something in the back.

# 135 MS. CLARK:

And who was in the room at that time?

# 136 MS. RAMIREZ:

Stephen Oppler and Hank Goldberg.

# 137 MS. CLARK:

Was anybody asking him questions during that time?

# 138 MS. RAMIREZ:

I don't remember.

# 139 MS. CLARK:

Was anybody interviewing him concerning the case at that time?

# 140 MS. RAMIREZ:

No.

# 141 MR. NEUFELD:

Objection. Asked and answered.

# 142 THE COURT:

Overruled.

# 143 MS. CLARK:

Did he have--was--did he have any difficulty hooking up the TV to the correct VCR?

# 144 MS. RAMIREZ:

Not really.

# 145 MS. CLARK:

Okay. And after he finished the hookup, what happened next?

# 146 MS. RAMIREZ:

We watched the tape.

# 147 MS. CLARK:

And did you watch the entire tape?

# 148 MS. RAMIREZ:

No.

# 149 MS. CLARK:

How much did you watch?

# 150 MR. NEUFELD:

Objection. Asked and answered.

# 151 THE COURT:

Overruled. Haven't we already gotten an answer to the question?

# 152 MS. CLARK:

I'm sorry.

# 153 THE COURT:

A minute or so?

# 154 MS. CLARK:

Thank you, your Honor.

# 155 MS. CLARK:

And after you watched it for a minute or so, then what happened?

# 156 MR. NEUFELD:

Objection. Asked and answered. This whole line is asked and answered.

# 157 THE COURT:

Overruled.

# 158 MS. RAMIREZ:

I took the tape out of the machine.

# 159 MS. CLARK:

Okay. And then what happened?

# 160 MS. RAMIREZ:

And I was starting to put it away as well as my camera and the rest of the equipment, but the D.A. said that he had another question. So then I had to put the tape back and cue it to the end. But I don't remember if I did it in the camera or on his VCR.

# 161 MS. CLARK:

Okay.

# 162 MS. RAMIREZ:

But I had to do that. So that probably took another couple of minutes.

# 163 MS. CLARK:

And then you indicated I think before that you had to set your camera back up again?

# 164 MS. RAMIREZ:

Yes.

# 165 MS. CLARK:

Then at that point, did you resume the taping of Mr. Peratis?

# 166 MS. RAMIREZ:

Yes.

# 167 MS. CLARK:

And I would like to show the segment, if I may, Defense 1375 again.

# 168 (At 5:05 P.M., Deft's exhibit 1375, a videotape, was played.)

# 169 MS. CLARK:

Go ahead. Run it back.

# 170 (At 5:05 P.M., Deft's exhibit 1375, a videotape, was played.)

# 171 THE COURT:

Miss Clark, do you need to show this anymore?

# 172 MS. CLARK:

I wanted to show it to the end if I could.

# 173 MR. NEUFELD:

Sidebar, your Honor?

# 174 THE COURT:

Yes. With the court reporter, please.

Temperature

procedural

Key Quotes (4)

Teresa Ramirez

I noticed that Mr. Peratis had very nice television set and I ask him if we could check the tape on his set, if we could watch it on his TV, and he agreed, but he had to go and change--I don't know. He rehook it up or something.

Establishes the innocent explanation for the tape gap — it was about reviewing footage, not coaching the witness.

Teresa Ramirez

But I missed--we showing--when we videotape somebody, we--the investigator that is conducting the interview says that we were off for few minutes or whatever, and I missed that part on the videotape. So when the tape starts again, Mr. Peratis is already answering to the question. So I probably missed, I don't know, up to a minute.

Concedes a secondary gap — she started recording late and missed Oppler's resumption statement and Goldberg's question, potentially feeding defense suspicions about off-camera coaching.

Teresa Ramirez

He said he didn't like to miss shows while he was at work.

Peratis's explanation for having four VCRs — colorful detail that humanizes the break and supports the non-sinister explanation for the gap.

Teresa Ramirez

It was one television monitor and I remember that there were at least four VCR's plus some stereo equipment and speakers, receivers.

Explains why hooking up the TV to view the tape took several minutes — the system was legitimately complex.

Evidence (2)

People's 615

Videotape of the Thano Peratis interview conducted by Hank Goldberg on July 27, 1995

played in court to show timestamp gap between 3:59 and 4:13

Defense 1375

Videotape (same or related Peratis interview footage, defense exhibit number)

played and re-played to examine the resumption point; sidebar called before conclusion

Notable Exchanges (3)

Marcia Clark•Lance A. Ito

Judge Ito corrects Clark's exhibit number (she says 'Defense exhibit 13,' he supplies '1375') and later prompts her when she asks a question already answered ('A minute or so?'), streamlining repetitive testimony.

procedural, mildly corrective

Marcia Clark•Peter Neufeld•Lance A. Ito

Neufeld objects to hearsay when Clark asks what remark Ramirez made to Peratis; Ito sustains, then Clark argues it explains subsequent conduct and the judge allows it on that limited basis.

strategic

Marcia Clark•Peter Neufeld

Neufeld repeatedly objects 'asked and answered' as Clark circles back over the same timeline of events multiple times; all overruled but Ito — Ito — pointedly notes the repetition.

procedural friction

Light Moments (2)

Teresa Ramirez

Ramirez corrects Clark's implication about who was present at Peratis's home: 'Mr. Peratis. He lives there.'

Teresa Ramirez

Peratis's explanation for owning four VCRs — 'He said he didn't like to miss shows while he was at work' — gets a moment of levity in otherwise dry testimony.

Witness Demeanor

Ramirez speaks haltingly at times, self-correcting mid-sentence, suggesting nervousness or careful effort to be precise rather than coached.

Asks 'Excuse me?' twice when she mishears or needs clarification — overall cooperative but not polished.

Objections

6 objections (2 sustained, 4 overruled)

Proceeding 7649 • 174 utterances • Prosecution witness

Criminal Trial

Department 103