Cross-examination of Teresa Ramirez (part 2)

📄 Cross-examination of Teresa Ramirez (part 2) — Thursday, September 14, 1995

Address:

C:\DEPT103\CRIMINAL\1995\SEP\14\CROSS-EXAMINATION-OF-TERESA-RA.DOC

TRIAL

▲ Day 154 of 167

◀ Sidebar: videotape Redirect examination of Teresa Ramirez (part 1) ▶

Witness: Teresa Ramirez
Examiner: Peter Neufeld
Called by: Prosecution • Date: Thursday, September 14, 1995 • Utterances: 39

The continuation of Neufeld's cross-examination of Teresa Ramirez focused on a July 27, 1995 videotaped session with prosecution witness Thano Peratis, played in court to refresh the witness's recollection. Neufeld attempted to establish that prosecutor Goldberg was coaching or communicating with Peratis during the taping — specifically that Peratis was mouthing the words 'I don't remember' in response to Goldberg — but the witness said she could not tell, and two argumentative objections by Clark were sustained.

# 1 (The following proceedings were held in open court:)

# 2 MR. NEUFELD:

I apologize, your Honor. It will take one minute. We just have to switch the tapes.

# 3 (Brief pause.)

# 4 (At 9:41 A.M., a videotape was played.)

# 5 THE COURT:

That should be about the right spot.

# 6 (At 9:42 A.M., a videotape was played.)

# 7 MS. CLARK:

Can we complete the sentence?

# 8 THE COURT:

Let's just see that in its--let's go back about 20 seconds. All right.

# 9 MR. NEUFELD:

That's the end of that segment.

# 10 (At 9:44 A.M., a videotape was played.)

# 11 (At 9:45, the playing of the videotape concluded.)

# 12 MR. NEUFELD:

Okay. Thank you.

# 13 MR. NEUFELD:

By the way, there's a reference there to Patti Jo. Do you know who Patti Jo is?

# 14 MS. RAMIREZ:

Yes.

# 15 MR. NEUFELD:

And who is that?

# 16 MS. RAMIREZ:

She's secretary for the lawyers.

# 17 MR. NEUFELD:

You mean the District Attorneys?

# 18 MS. RAMIREZ:

District Attorney's office. Yes. Yes.

# 19 MR. NEUFELD:

Okay. And on that tape--I'm sorry. And on that occasion when there's that reference to Mr. Goldberg--is that Mr. Goldberg's voice you hear on the tape?

# 20 MS. RAMIREZ:

Yes.

# 21 MR. NEUFELD:

And--

# 22 THE COURT:

Miss Ramirez, why don't you just pull the microphone closer to you so you don't have to keep leaning over. Thank you.

# 23 MR. NEUFELD:

Now, during that session, apparently--not apparently. During that session, they were discussing a Prosecution subpoena that was given to Mr. Peratis in early February of 1995? Do you recall that?

# 24 MS. RAMIREZ:

Yes.

# 25 MR. NEUFELD:

During the July 27th, 1995 taping session, ma'am, did the topic come up at all as to why during the four months, Mr. Peratis was never brought in as a Prosecution witness?

# 26 MS. CLARK:

Objection. Objection, your Honor. The tape speaks for itself.

KEY QUOTE

# 27 THE COURT:

Sustained. Sustained. It's argumentative, counsel.

# 28 MR. NEUFELD:

Okay. One second.

# 29 (Discussion held off the record between Defense counsel.)

# 30 MR. NEUFELD:

Now that you've seen the tape again to refresh your recollection, Miss Ramirez, when Mr. Goldberg asked Mr. Peratis about his visit, about Mr. Goldberg's visit to the dispensary where Mr. Peratis worked and you saw Mr. Peratis mouth the words--do you remember that?

# 31 MS. RAMIREZ:

Yes.

# 32 MR. NEUFELD:

Was Mr. Peratis, as you recall, having been there, was he mouthing the words, "I don't remember"?

# 33 MS. RAMIREZ:

I couldn't tell.

# 34 MR. NEUFELD:

But what Mr.--but what Mr. Peratis was doing was responding to Mr. Goldberg trying to talk to him about Mr. Goldberg's earlier visit with Mr. Peratis at the dispensary. That's when it came up, didn't it?

# 35 MS. CLARK:

Objection.

# 36 THE COURT:

It's argumentative. Sustained.

# 37 MR. NEUFELD:

Good luck at the dentist, ma'am. Thank you.

KEY QUOTE

# 38 THE COURT:

Miss Clark, anything further?

# 39 MR. NEUFELD:

There's such a thing as possible.

Temperature

procedural

Key Quotes (3)

Teresa Ramirez

I couldn't tell.

The defense's key goal in this segment — establishing that Peratis mouthed 'I don't remember' as coached non-testimony — was neutralized by the witness's inability or unwillingness to confirm it.

Marcia Clark

Objection. Objection, your Honor. The tape speaks for itself.

Successful objection blocking Neufeld from having the witness characterize what the tape showed, keeping interpretation away from the jury.

Peter Neufeld

Good luck at the dentist, ma'am. Thank you.

Neufeld's closing remark — a surprising, humanizing aside suggesting the witness had a dental appointment — signals the examination concluded without the dramatic confirmation the defense sought.

Evidence (2)

Informal

Videotape of the July 27, 1995 taping session with Thano Peratis (LAPD nurse who drew Simpson's blood), in which prosecutor Goldberg was present

played in court to refresh witness recollection; specific segments replayed and rewound

Informal

Prosecution subpoena given to Thano Peratis in early February 1995

referenced in questioning about why Peratis was not called as a live prosecution witness during the four-month window

Notable Exchanges (2)

Peter Neufeld•Teresa Ramirez

Neufeld pressed Ramirez on whether Peratis was mouthing the words 'I don't remember' during the taping session in response to Goldberg's prompting. Ramirez deflected with 'I couldn't tell,' leaving the defense's implicit coaching narrative unconfirmed.

strategic

Peter Neufeld•Marcia Clark•Lance A. Ito

Clark successfully objected twice to Neufeld's argumentative framing of what the tape showed, with the judge sustaining both and noting the tape speaks for itself.

procedural

Light Moments (1)

Peter Neufeld

Neufeld closed his examination with 'Good luck at the dentist, ma'am,' an oddly warm parting comment suggesting the witness had a personal appointment to get to.

Credibility Attacks (1)

⚔ Thano Peratis

implied coaching / inconsistent prior conduct

Neufeld used the videotape session to suggest Goldberg coached or influenced Peratis during the July 27 taping — pointing to Peratis mouthing words in response to Goldberg — and questioned why Peratis was never brought in as a live witness despite a subpoena four months earlier. The attack was indirect, using Ramirez as a percipient witness to the taping.

Objections

2 objections (2 sustained, 0 overruled)

Proceeding 7687 • 39 utterances • Prosecution witness

Criminal Trial

Department 103