📄 In chambers: closing argument objections — Wednesday, September 27, 1995
Address:
C:\DEPT103\CRIMINAL\1995\SEP\27\IN-CHAMBERS-CLOSING-ARGUMENT-O.DOC
TRIAL
▲ Day 162 of 167

In chambers: closing argument objections

Date: Wednesday, September 27, 1995 • Utterances: 23
Before resuming closing arguments, Scheck raises an objection to Clark's earlier remarks about defense experts who never testified — specifically arguing that commenting on untested EDTA evidence by unnamed defense experts invades privilege and goes beyond what the record supports. Clark maintains she only referenced experts who were in the record; the judge effectively resolves the dispute by directing Blasier to review the transcript and warning Clark not to make such comments in rebuttal.
1 THE COURT:

Back on the record in the Simpson matter. Mr. Simpson is again present before the court with his counsel, Mr. Shapiro, Mr. Cochran, Mr. Blasier. The people are represented by Mr. Darden and Miss Clark. The jury is not present. The record should reflect that this morning I had a chambers conference with counsel to discuss a questionnaire that will go to the jurors this afternoon inquiring of them if they are desirous of extending the hours of deliberation into a later session during the evening hours and whether or not they are desirous or willing to deliberate on Saturdays, with the understanding that any deliberations must be conducted here at the courthouse and in the jury deliberation room. We also discussed--and excuse me. Counsel had no objection to the questionnaire proposed by the court. Also, the record should reflect that the court has directed counsel to be available on a one-hour's call for the purposes of responding to questions by the jury and also requests for read back. And the court has indicated also that a longer time period to be available for the purposes of rendering a verdict will probably be in place, but we will discuss that when the time comes. All right. Anything else we need to discuss before--put on the record before we conclude with Mr. Darden's argument?

2 MR. NEUFELD:

Your honor, may I just go around?

3 THE COURT:

Sure. All right. Deputy Trower.

4 MR. SCHECK:

Your honor.

5 THE COURT:

Mr. Scheck, good morning.

6 MR. SCHECK:

Good morning. I just wanted to register for the record certain objections, one in particular to Miss Clark's argument, and get some determination from the court on this issue. At one point in her argument she began making references to the defendant's not performing tests on evidence and started making comments about experts for the defense who never appeared in court or testified and what they did or didn't do. In particular, the comment that concerned me the most was in reference to EDTA testing. It is one thing to say that dr. Rieders didn't perform a test using the ms/ms machine, because that certainly came out and was impeachment in the testimony, but what concerned me was a reference, well, the defense had other experts and they didn't come in and give you test results, or anything to that effect, and that seems to me improper, because, first of all, it is commenting on a privileged area, I think that is 913. And secondly, I think we've already had some litigation on this issue where the court actually made a finding that the conduct of the prosecution in terms of trying to find out what, if anything, defense experts were doing in this area was, in the court's words reprehensible, so it seems to me that a comment on what other experts could have done with respect to their testing or did do or anything like that would be improper, although I have no objection to her making comments about dr. Rieders. I thought that--and I would like some kind of guidance from the court on that issue.

7 THE COURT:

Miss Clark.

8 MS. CLARK:

I don't know what to say, judge. I pointed out to the jury what is in the record. I pointed out the truth. And I think I was very specific about the people they called and they didn't call. What I pointed out in--to the best of my recollection, is that they called dr. Rieders to testify about someone else's tests. He performed none. He could have. I talked about dr. Gerdes and I talked about dr. Lee and I talked about dr. Blake. This is all in the record. I don't recall--I did not refer to other experts that were unnamed or that did not come into the record. I talked about the ones that were in the record, and that is why they didn't perform any tests. So I don't know what the complaint is.

9 THE COURT:

All right. Mr. Scheck, do you want to--I mean, are there any case citations? Because primarily during the course of argument the prosecution counsel are entitled to comment upon the state of the evidence and the failure to call logical and material witnesses, and that is people versus miller, 50 cal.3D, 954, the court's comments at 996.

10 MR. SCHECK:

No, no. It sounds like from her comments I heard something different, and if Miss Clark doesn't believe she said that or certainly isn't going to make that argument on rebuttal, then I guess we don't have a quarrel.

11 THE COURT:

Okay.

12 MR. SCHECK:

It seems to me, though, just to make the point very, very clear, it is one thing to comment on dr. Rieders on what tests he did or did not perform under the circumstances. I distinctly heard her say the defense has other experts that could have done that test and that I think is beyond the miller case and beyond proper comment on the record. And it appears that Miss Clark agrees.

13 THE COURT:

Something based in the record, correct.

14 MR. SCHECK:

Right, so it appears as though there is no disagreement here, but I am very concerned because--

15 THE COURT:

All right. Let's do this: Let's have our computer maven, Mr. Blasier, see if he can find the appropriate comment and at the next recess we will take it up, if you feel it is something that is appropriate.

16 MS. CLARK:

Your honor, I will tell you what--

17 THE COURT:

No, no. We have just settled it.

18 MS. CLARK:

No, because in case--I don't know--we can't all remember what we say over the period of hours, but I will say this: Any reference to other experts would have been they could have brought someone in, not they had someone available.

19 THE COURT:

Miss Clark.

20 MS. CLARK:

Assuming that is the case--don't do it? Wait?

21 THE COURT:

The discussion is over.

KEY QUOTE
22 MS. CLARK:

All right.

23 THE COURT:

All right. Thank you. Deputy Trower, let's have the jurors, please.

Temperature

tense

Key Quotes (4)

Barry Scheck
it is commenting on a privileged area, I think that is 913... the court actually made a finding that the conduct of the prosecution in terms of trying to find out what, if anything, defense experts were doing in this area was, in the court's words reprehensible
Scheck invokes a prior judicial finding of prosecutorial misconduct to argue Clark's closing argument comment was not an isolated misstep but part of a pattern the court had already condemned.
Marcia Clark
I pointed out to the jury what is in the record. I pointed out the truth. And I think I was very specific about the people they called and they didn't call.
Clark defends her closing remarks by framing them as record-based comment, which is the legal standard — but her later hedge ('Any reference to other experts would have been they could have brought someone in') suggests some ambiguity in what she actually said.
Marcia Clark
Any reference to other experts would have been they could have brought someone in, not they had someone available.
A telling slip — Clark tries to clarify but arguably confirms Scheck heard something real. Ito shuts the discussion down before she can dig deeper.
Lance A. Ito
The discussion is over.
Ito's blunt close signals he considered the matter resolved and was not interested in Clark relitigating it.

Evidence (1)

Informal
EDTA testing — specifically Dr. Rieders's failure to perform ms/ms machine testing, and Clark's broader comments about defense experts who could have conducted such tests
discussed as subject of closing argument objection

Notable Exchanges (2)

Barry ScheckMarcia Clark
Scheck objects that Clark implied unnamed defense experts had EDTA test results they withheld, which would violate privilege; Clark insists she only referenced experts in the record (Rieders, Gerdes, Lee, Blake). Scheck ultimately accepts her clarification as sufficient — 'it appears as though there is no disagreement here' — but reserves the right to revisit if Blasier finds the transcript language.
strategic
Marcia ClarkLance A. Ito
Clark attempts to continue clarifying after Ito declares the discussion closed; Ito cuts her off twice ('Miss Clark.' / 'The discussion is over.'), leaving her mid-sentence.
tense

Credibility Attacks (1)

⚔ Marcia Clark
prior judicial finding
Scheck reminds the court that it had previously found the prosecution's efforts to investigate defense expert EDTA testing 'reprehensible,' using that finding to frame Clark's closing argument comment as part of an improper pattern rather than an isolated remark.

Objections

1 objections (0 sustained, 0 overruled)
Proceeding 7839 • 23 utterances
Criminal Trial
Department 103
⚖️ Start
📂 SEP 27, 1995 📄 In chambers: closing argument
SEP 27, 1995 KRT DvH TD