📄 Photograph montage and audio evidence — Friday, September 29, 1995
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C:\DEPT103\CRIMINAL\1995\SEP\29\PHOTOGRAPH-MONTAGE-AND-AUDIO-E.DOC
TRIAL
▲ Day 164 of 167

Photograph montage and audio evidence

Date: Friday, September 29, 1995 • Utterances: 40
Marcia Clark previews a photo-and-audio montage she plans to use in closing argument, combining domestic violence photographs with the 1989 and 1993 audio tapes to argue motive for the murders. Cochran objects vehemently, calling it inflammatory, improper rebuttal, and vouching. Judge Ito identifies a genuine problem — the two audio tapes are run together without a break, which is misleading — and overrules the objection on the condition that Clark explain the combined tapes clearly to the jury.
1 MS. CLARK:

I previewed the montage for Defense that Mr. Cochran indicates he'd like to interpose an objection to. Let me indicate to the court that what it is is a syntheses of evidence that has been admitted already.

2 THE COURT:

All right. May I see it?

3 MS. CLARK:

Yes. 150, 151, 153.

4 THE COURT:

What is the connection between the audio and the montage? Is that the audio that you anticipate playing at the same time as the montage?

5 MS. CLARK:

Yes. It goes in tandem with the argument that's going to be made to present it, which is the motive for the murder.

6 THE COURT:

Do you think the tape directly relates to the last two photographs?

7 MS. CLARK:

I'm sorry?

8 THE COURT:

Does the audio tape directly pertain to the last two--

9 MS. CLARK:

I can't--I'm sorry. The last--

10 THE COURT:

The last two photographs.

11 MS. CLARK:

Yes. That's the point. That's the case, your Honor. That's the whole--that is it; that the motive for these murders is the nature of the problem and that's why she wound up there. We are synthesizing the evidence. We do it through verbal argument, saying we have the motive, it carries forward up to the date of June 12th, and then we do it with pictures, pictures that have been admitted in evidence. All of this has been admitted.

12 THE COURT:

Mr. Cochran.

13 MR. COCHRAN:

This is unfair. It's incredibly inflammatory. Those tapes have nothing to do with the photographs that are up there. If she wants to argue that, then so be it. This is improper rebuttal, your Honor, trying to spring this on us at the last minute. The tape that she's referring to is a different time than the photographs. It's a photograph from 1989--tape's from `93 and the picture--they try to link all these things together. They have nothing to do with this evidence. This evidence of other offenses was limited for a very limited purpose so the court is aware of that. The reason it was in there--and this would be incredibly unfair and it's typical of what the Prosecution is doing in this rebuttal. This is outrageous, your Honor. They're vouching--they're doing all of these things, taking things out where they know they're wrong. Yet, they're trying to do this at the eleventh hour when she has maybe an hour or so left faced with this. This is outrageous and you should stop it. They held this back, you know, to keep us from dealing with this until the last minute. Now we see it at 1:55 on the day of the last day of her argument. This is outrageous, your Honor. The court should put a stop to it. This is the end of it and we should get on and get this case to the jury. They're never going to stop unless you exercise your wisdom and discretion and stop it.

14 THE COURT:

Thank you, counsel. Miss Clark.

15 MS. CLARK:

Your Honor, I don't think that Mr. Cochran has a right to use the word "Outrageous." This is a man who argued Mark Fuhrman was commensurate with Adolph Hitler. This is a man who demanded jury nullification. But this is proper argument.

KEY QUOTE
16 THE COURT:

Counsel, let's address the issue.

17 MS. CLARK:

Yes.

18 THE COURT:

Are these items in evidence?

19 MS. CLARK:

They're all in evidence, your Honor. And the purpose for which we're using the tape being played over these photographs is the very purpose for which the domestic violence matters were admitted, which is for the purpose of motive and identification, and that's why it's been synthesized this way. I think we are using it for an entirely appropriate purpose, as the court has permitted us to do, with the jury instruction that limits it. We have I think appropriately argued it. Mr. Darden appropriately argued in that vein, but this is argument. And we are synthesizing all of it. The domestic violence is the underlying theme in the case. It certainly is the motivation in the case and it goes to identification as well.

20 THE COURT:

All right. I think the record is not completely clear because we did not identify what all these items are, but what we started out with were photographs of the domestic violence injuries, the Polaroid photographs.

21 MS. CLARK:

Yes, your Honor. I should be more specific. They are the domestic violence photographs with respect to the 1989 incident. Then I believe they are the photographs from the safe deposit box and then we have the photographs from Rockingham that pertain to this case and they conclude with the photographs of Bundy pertaining to this case.

22 THE COURT:

And this is while you're playing the first portion of People's exhibit what?

23 MS. CLARK:

What is the number?

24 THE COURT:

This is the `93 tape?

25 MS. CLARK:

`89 and the `93 tapes.

26 MR. COCHRAN:

Your Honor, may I say something when you get an opportunity?

27 THE COURT:

Miss Clark, have you concluded with your argument?

28 MS. CLARK:

Yes, your Honor.

29 MR. COCHRAN:

Your Honor, in the `93 incident, as you're well aware, the tape they played, there was only the back--the French doors were damaged. There was no physical damage. And the `89 incident, they ran these two things together. They have nothing to do with each other. They're just supposing. This is an interpretation they're placing on the evidence. If they want to show the evidence, that's one thing. But to play the tape in conjunction with that, that's a production from the District Attorney's office at this eleventh hour and it's unfair. It's absolutely unfair. It's inflammatory. This is improper rebuttal. We've seen all this evidence. In addition to that, the court has told us on several occasions you are going to stop us when there's redundancy, and this is absolutely redundant. It is improper. The prejudice far outweighs any probative value because they're meshing things that don't follow. They do not follow. This evidence was limited for a limited purpose, and they're tying things together and making a conclusion just as she did with this incident regarding the air conditioning, and that's unfair, vouching for things. It's wrong, Judge, and it shouldn't happen.

30 THE COURT:

Is that the word for the day?

KEY QUOTE
31 MR. COCHRAN:

"Vouching"?

32 THE COURT:

Yes.

33 MR. COCHRAN:

"Vouching" is the word for the day, your Honor, the eye word, and it's personally vouching and it's wrong and they know it's wrong, everybody knows it's wrong and it shouldn't happen, Judge.

34 THE COURT:

Miss Clark, I do think it is a problem with the sound track because you've run the two sound tracks together, the `89--is that two tapes?

35 MS. CLARK:

Yes, your Honor, both of which have been admitted.

36 THE COURT:

I understand. It's misleading because you can't tell that there are two tapes. There's no break with them.

37 MS. CLARK:

I'll tell them. How about if I tell the jury we're running them together?

38 THE COURT:

When do you anticipate doing this in your argument?

39 MS. CLARK:

At the end. I'll introduce it, I'll explain to the jury we've run the two tapes together. I have to--I have to tell them what they're seeing and hearing.

I don't want to mislead them. I want to tell them the truth. I want them to hear exactly--I want them to know exactly what it is that they're hearing. I want them to know that it's the `89 tape. And then we're going to run the `93 tape and we're going to run the pictures from `89 and we're going to run the pictures from the safe deposit box. I want them to be very clear about what they're seeing and hearing. I don't want there to be any mistakes about it.

40 THE COURT:

All right. With that caveat, the objection is overruled. All right. Let's proceed.

Temperature

heated

Key Quotes (5)

Marcia Clark
That's the case, your Honor. That's the whole--that is it; that the motive for these murders is the nature of the problem and that's why she wound up there.
Clark frames the entire montage as the prosecutorial thesis: domestic violence as the direct motive for murder.
Johnnie Cochran
This is outrageous, your Honor. They're never going to stop unless you exercise your wisdom and discretion and stop it.
Cochran's most heated moment in this proceeding — an escalating plea to the judge framed as an appeal to judicial authority.
Marcia Clark
Your Honor, I don't think that Mr. Cochran has a right to use the word 'Outrageous.' This is a man who argued Mark Fuhrman was commensurate with Adolph Hitler. This is a man who demanded jury nullification.
Clark counter-attacks by invoking Cochran's own inflammatory rhetoric from trial, prompting the judge to redirect the discussion.
Lance A. Ito
Is that the word for the day?
A dry, deadpan interjection about Cochran's repeated use of 'vouching' — rare levity in an otherwise heated argument.
Marcia Clark
I want them to know that it's the '89 tape. And then we're going to run the '93 tape... I want them to be very clear about what they're seeing and hearing. I don't want there to be any mistakes about it.
Clark's concession to the judge's concern — she accepts the caveat and frames her transparency as a feature, not a concession.

Evidence (3)

People's 150, 151, 153
Photograph montage: 1989 domestic violence Polaroids, safe deposit box photographs, Rockingham crime scene photos, Bundy crime scene photos
previewed for defense, objected to, ultimately admitted with caveat
Informal
1989 audio tape from domestic violence incident
discussed as part of montage soundtrack, combined with 1993 tape
Informal
1993 audio tape from domestic violence incident (French doors damaged)
discussed as part of montage soundtrack, Cochran notes no physical injury in this incident

Notable Exchanges (4)

Johnnie CochranLance A. Ito
Cochran delivers a prolonged, escalating objection calling the montage 'outrageous' multiple times and accusing the prosecution of deliberately withholding it until the last minute. Ito thanks him curtly and turns to Clark.
heated
Marcia ClarkLance A. Ito
Ito identifies the substantive problem: the two audio tapes are combined with no break, which is misleading. Clark immediately offers to tell the jury explicitly what they're hearing, and Ito accepts this as sufficient.
procedural
Marcia ClarkJohnnie Cochran
Clark responds to Cochran's use of 'outrageous' by citing his Hitler/Fuhrman comparison and jury nullification argument; Ito shuts it down and redirects to the actual legal issue.
combative
Lance A. ItoJohnnie Cochran
After Cochran uses 'vouching' repeatedly, Ito deadpans 'Is that the word for the day?' and Cochran earnestly confirms it is.
dry/wry

Light Moments (1)

Lance A. Ito
After Cochran repeatedly invokes 'vouching,' Ito asks 'Is that the word for the day?' — Cochran confirms it is with full seriousness.

Credibility Attacks (1)

⚔ Johnnie Cochran
tu quoque / prior inflammatory conduct
Clark responds to Cochran's use of 'outrageous' by citing his comparison of Mark Fuhrman to Adolf Hitler and his jury nullification argument — attacking his standing to object to inflammatory tactics.

Objections

1 objections (0 sustained, 1 overruled)
Proceeding 7888 • 40 utterances
Criminal Trial
Department 103
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📂 SEP 29, 1995 📄 Photograph montage and audio e
SEP 29, 1995 KRT DvH TD