📄 Offer of proof discussion — Tuesday, September 5, 1995
Address:
C:\DEPT103\CRIMINAL\1995\SEP\5\OFFER-OF-PROOF-DISCUSSION.DOC
TRIAL
▲ Day 147 of 167

Offer of proof discussion

Date: Tuesday, September 5, 1995 • Utterances: 34
F. Lee Bailey attempts to add a new inflammatory Fuhrman quote to the offer of proof — specifically that Fuhrman said 'the only good N-word person is a dead N-word person' — which Marcia Clark vigorously objects to as a last-minute fabrication designed to circumvent the court's prior limiting ruling. Judge Ito overrules the objection and allows the statement, then briefly addresses witness scheduling with Cochran.
1 THE COURT:

All right. Back on the record in the Simpson matter. All parties are again present. All right. Deputy Magnera, let's have the jurors, please.

2 MR. BAILEY:

Your Honor, before you do?

3 THE COURT:

Yes, sir.

4 MR. BAILEY:

There is one thing, and the fault is mine, that I omitted from the offer of proof at least today, I think I may have mentioned it last week, and that is later on the day of the first conversation with the remarks about beating and so forth that you have excluded were used, Detective Fuhrman or Officer Fuhrman at that time made the observation that the only dead--only good "N" person is a dead "N" person and I would propose to have her testify to that. I don't think that comes anywhere close to bomb and burn them all, as the Prosecution put before the jury, and I think it is an indication of his overall attitude toward the case.

5 THE COURT:

Mr. Darden.

6 MS. CLARK:

Your Honor--I'm going to handle this witness, I'm sorry.

7 THE COURT:

Miss Clark.

8 MS. CLARK:

Your Honor, I recall very distinctly counsel's offer of proof when he last made it, as well as today, and he has never mentioned before, and it is very apparent that what has happened is since the court has excluded the reference to the beatings they have come up with another phrase that will be inflammatory along these lines. The court has ruled that the reference to the use of the word, that all that can be used. That is a great deal that counsel has been given. And to now heap more on because the court has ruled that other references could not come in, is unfair and I think highly suspect and I would urge the court not to allow these belated observations of Miss Singer.

9 MR. BAILEY:

If it please the court, Miss Clark's perennially professionally insulting conduct adds nothing to this trial. This woman told me--

10 THE COURT:

Excuse me. Counsel, counsel, counsel, counsel, please, if you are going to complain about somebody else's conduct, I suggest you not engage in that yourself. I will hear your argument.

11 MR. BAILEY:

My argument is that we have just been charged with concocting a fabrication in response to the court's limiting ruling. I personally interviewed this witness in Nashville on May 2nd, 1995, and was told about the remarks I have just recited at that time. This witness was interviewed in Mr. Cochran's office by a number of lawyers and we were told about the remark. I simply omitted it because I was focusing on the beating aspect of it and the fault is mine, but to suggest that lawyers are making up evidence to frustrate your ruling requires something more than a nasty attitude. I think you ought to require an offer of proof before you tolerate conduct of that sort in this trial any further.

12 MS. CLARK:

Your Honor, I have an offer of proof.

13 THE COURT:

Wait, wait. What is your offer of proof, Miss Clark?

14 MS. CLARK:

I would like to show counsel the fact--no, it is very easy. There is no discovery. We have no statement, we have nothing ever given to us by counsel that would indicate what Miss Singer said. There has been no offer of proof to date given to this court in which that phrase was represented as part of the offer. Today for the very first time, after the court's ruling, counsel comes up with it and now asserts to the court that that was something that had been said before. Now, if counsel had made an effort to comply with discovery, had made a good faith to give us a prior statement issued by Miss Singer, and I do not fault Miss Singer for this, I do fault counsel, however, then he would stand in a better posture before this court. But to come before this court now and represent, having given us no discovery, no statement from Miss Singer at all, that she said this all along, and yet he forgot to say it until this very moment, is something that should be considered by the court. If nothing else, counsel obviously didn't think it all that important if he did not include it any prior offer, which he did not; if did he not seek to tell us about it at any prior occasion, which he did not; if he included it in no discovery of any notes made by any investigator, which he did not. And if that is contained in notes somewhere, then we were entitled to discovery and we didn't get it under the discovery rules and laws under 1054, et seq. And I would urge the court to suppress it on those grounds as well.

15 (Discussion held off the record between the Deputy District Attorneys.)
16 THE COURT:

All right. Mr. Bailey.

17 MS. CLARK:

And let me also indicate to the court that it's another highly inflammatory statement that adds nothing to the evidence of racial bias other than to seek to inflame the passions of the jury again improperly.

18 THE COURT:

I am concerned about any investigator's reports, any notations as to interviews of Miss Singer that haven't been turned over.

19 MR. BAILEY:

Your Honor, investigator's notes have been turned over. No report has been written. No one was present with me when I talked with the witness.

20 THE COURT:

Counsel, all I asked for was investigators notes.

21 MR. BAILEY:

Pardon me?

22 THE COURT:

Have they been turned over?

23 MR. BAILEY:

They have been turned over. Furthermore, if I may--

24 MR. COCHRAN:

Lee, Lee.

25 THE COURT:

I have heard all I need to hear.

26 MS. CLARK:

The statement does not appear in any notes, your Honor.

27 THE COURT:

All right. The objection is overruled. All right. Let's have the jury, please.

28 (Brief pause.)
29 THE COURT:

Mr. Cochran, who is after Miss Singer?

30 MR. COCHRAN:

Your Honor, the lawyers are out now interviewing. We have three or four witnesses and can I--may I tell you that in a moment?

31 (Discussion held off the record between Defense counsel.)
32 MR. COCHRAN:

Mr. Douglas, Mr. Shapiro have been doing that. I can let the court know that very shortly.

33 THE COURT:

All right.

34 MR. COCHRAN:

Thank you.

Temperature

tense

Key Quotes (4)

F. Lee Bailey
Detective Fuhrman or Officer Fuhrman at that time made the observation that the only dead--only good 'N' person is a dead 'N' person and I would propose to have her testify to that.
The specific new Fuhrman quote Bailey sought to add to the offer of proof — a direct racial epithet going beyond what had already been ruled admissible.
Marcia Clark
It is very apparent that what has happened is since the court has excluded the reference to the beatings they have come up with another phrase that will be inflammatory along these lines.
Clark's central theory — that the defense manufactured a new quote in direct response to the court's limiting ruling, raising bad faith concerns.
F. Lee Bailey
I personally interviewed this witness in Nashville on May 2nd, 1995, and was told about the remarks I have just recited at that time... I simply omitted it because I was focusing on the beating aspect of it and the fault is mine.
Bailey's direct rebuttal, accepting personal blame for the omission while denying fabrication — a rare instance of a defense attorney explicitly admitting fault on the record.
Lance A. Ito
Counsel, if you are going to complain about somebody else's conduct, I suggest you not engage in that yourself.
Ito shutting down the escalating personal attacks between Bailey and Clark before they could spiral further.

Evidence (1)

Informal
Investigator notes from interviews with witness Laura Hart McKinny (referred to as 'Miss Singer') — specifically notes from Bailey's May 2, 1995 interview in Nashville
Disputed — Clark asserts no discovery provided; Bailey asserts notes have been turned over

Notable Exchanges (2)

F. Lee BaileyMarcia Clark
Bailey introduces a new Fuhrman quote mid-proceeding; Clark accuses him of fabricating it to circumvent the court's ruling; Bailey fires back calling her conduct 'perennially professionally insulting'; Ito intervenes to stop the personal attacks.
heated
Lance A. ItoF. Lee Bailey
Ito presses Bailey directly on whether investigator notes have been turned over in discovery; Bailey confirms they have, while Cochran audibly attempts to interrupt him ('Lee, Lee').
strategic

Credibility Attacks (2)

⚔ Mark Fuhrman
prior bad acts / racial animus statements
Bailey sought to add testimony from witness Singer that Fuhrman stated 'the only good N-word person is a dead N-word person,' arguing it demonstrates his overall attitude toward the case.
⚔ F. Lee Bailey
discovery violation / bad faith allegation
Clark argued Bailey withheld the new Fuhrman quote from all prior offers of proof and provided no discovery materials documenting Singer's statement, suggesting the quote was invented in response to the court's adverse ruling.

Witness Demeanor

(Discussion held off the record between the Deputy District Attorneys.)
(Discussion held off the record between Defense counsel.)
(Brief pause.)

Objections

1 objections (0 sustained, 1 overruled)
Proceeding 7501 • 34 utterances
Criminal Trial
Department 103
⚖️ Start
📂 SEP 5, 1995 📄 Offer of proof discussion
SEP 5, 1995 KRT DvH TD