📄 Brady motion discussion — Wednesday, September 6, 1995
Address:
C:\DEPT103\CRIMINAL\1995\SEP\6\BRADY-MOTION-DISCUSSION.DOC
TRIAL
▲ Day 148 of 167

Brady motion discussion

Date: Wednesday, September 6, 1995 • Utterances: 68
A brief administrative session covering three matters: Cheri Lewis made a supplemental argument against the defense's renewed motion to suppress, claiming Fuhrman's credibility on the Rockingham walkway search was already established by Kato Kaelin's preliminary hearing testimony. Fuhrman's attorney Darryl Mounger announced that Fuhrman would assert his Fifth Amendment privilege rather than testify, but the defense refused to accept a stipulation, forcing Fuhrman to do it from the stand. The bulk of the session was scheduling logistics for the Brady motion, with the defense requesting extra time to interview witnesses — drawing a sharp rebuke from Marcia Clark.
1 (The following proceedings were held in open court, out of the presence of the jury:)
2 THE COURT:

Let's have it quiet, please. Where did Mr. Shapiro and Mr. Cochran disappear to?

3 MR. DOUGLAS:

Mr. Cochran is in lockup.

4 MR. NEUFELD:

The two we need.

5 (The Defendant is now present.)
6 THE COURT:

All right. Back on the record in the Simpson matter. All parties are again present, including counsel Kent Spaulding. The court has acted upon the application pro hac vice and approved that. Good afternoon, counsel.

7 MR. SPAULDING:

Good afternoon, your Honor.

8 THE COURT:

All right. Over the--during the brief recess, counsel had the opportunity to informally discuss scheduling matters and based upon the Brady issue that the court still needs to deal with this afternoon. Mr. Cochran.

9 MR. COCHRAN:

One thing, your Honor, on the Brady matter. I had indicated to the court that with regard to Brady, Messers. Scheck and Shapiro along with Miss Shawn Snider Chapman will be down at 4 o'clock. They're in the process of interviewing witnesses. They did indicate to me that there may be--they may not be ready to proceed completely today on that and may ask to start that tomorrow morning, and I told them to come by 4 o'clock so they could let the court know that. That's the only holdup, what we talked about earlier.

10 THE COURT:

All right. And I see Mr. Mounger stepped out briefly.

11 MS. LEWIS:

Your Honor, may I take this opportunity very briefly just to mention something that I neglected--it's my fault--I neglected to mention to the court earlier?

12 THE COURT:

No, I don't think so, Miss Lewis. We've--you've filed your points and authorities. I've heard rather extensive argument--

13 MS. LEWIS:

Well, there was a supplemental memorandum filed by the Defense yesterday afternoon after they had already filed their two other memos in the same thing that I did not pay careful attention to. So I--just briefly for the record, please. Please. I can see your--we have time. We are waiting for Mr. Mounger. Very quickly. Very quickly. It might help the court in its ruling.

14 THE COURT:

The moment he walks in the court.

15 MS. LEWIS:

Thank you, your Honor. First of all, on page no. 4 of their Defense--

16 THE COURT:

But then I have to listen to Mr. Uelmen as well.

17 MS. LEWIS:

Okay. Offer of proof of newly discovered evidence for motion to suppress, the first--they have three things. Very briefly, your Honor. The first thing is that they say the decision to make entry by climbing the wall. Detective Fuhrman was the D2. We know that the others out there were all D3's.

18 THE COURT:

Counsel, I recollect the testimony.

19 MS. LEWIS:

I'm sure. It was their decision. The second offer had to do with Mark Fuhrman searching Kato's room, but that--their cross-examination of Mark Fuhrman would add nothing to the--Mark Fuhrman's credibility on that because Kato testified at the preliminary hearing during the motion to suppress and testified to the thumps--

20 THE COURT:

He indicated he gave consent, he gave consent to the search. Next question.

21 MS. LEWIS:

Yes. And also indicating the thumps on the wall. So that makes Detective Fuhrman's testimony that Kato told him he heard thumps on the wall--I mean, there's no credibility issue there whatsoever. And the third one was that, given the statements that Kato made to Detective Fuhrman, which we know were made, that was obviously why Detective Fuhrman went behind the walkway. So how is the Defense going to hurt his credibility in terms of why he went to the walkway when we know Kato testified during the preliminary hearing as to those three thumps behind there. That's all I wanted to say, your Honor. I just wanted to point out that their intended cross-examination would not shed light on the issues they list in their supplemental brief.

22 THE COURT:

All right. Thank you, counsel. Mr. Uelmen, do you feel compelled to respond to that?

23 MR. UELMEN:

No, your Honor.

24 THE COURT:

All right. Thank you.

25 (Brief pause.)
26 THE COURT:

All right. We've been rejoined now by counsel Darryl Mounger who represents Mark Fuhrman. Good afternoon again, counsel.

27 MR. MOUNGER:

Your Honor, over the break, I talked to Mr. Fuhrman, and it is our position that because I am walking into this trial after eight months, I am unfamiliar with all of the testimony. I have been handling my own cases and not followed this trial intimately. I have come into this court asking for the McKinny tapes and a copy of the transcripts so that I might review them with my client, although I have reviewed most of them. I have tried to correlate that information and interview my client, and I'm unable to put it in the context which it deserves. Based upon this court's July 31st--I'm sorry--August 31st ruling and the words specifically I believe on page 5, on the information I do know and the information especially I do not know, I have advised Mr. Fuhrman that he should not answer any questions before this court. Therefore, it is my understanding that he will assert his 5th amendment privilege if asked any questions.

28 THE COURT:

All right. Mr. Uelmen, for the purposes of the record, will you accept that representation?

29 MR. UELMEN:

No, your Honor. We believe it's necessary for him to assert the privilege from the witness stand in response to a question.

KEY QUOTE
30 THE COURT:

All right. Since there's an unwillingness to accept and stipulate to that, it will be necessary for Mr. Fuhrman to resume the witness stand for the purpose of this motion and to assert the privilege.

31 MR. MOUNGER:

He will be here shortly, your Honor.

32 THE COURT:

All right. All right. Then, Mr. Uelmen, Miss Lewis, I've indicated to you off the record that I need to--in order to rule on the motion to suppress, renewed motion to suppress, I need to review the preliminary hearing transcript, which I have not had the opportunity to do since earlier--much earlier in the trial. So I'll need to do that. So I don't think you should anticipate a ruling this afternoon on that motion.

33 MS. LEWIS:

Thank you, your Honor.

34 THE COURT:

And, Mr. Cochran, I did see Miss Chapman come in. There she is.

35 MR. COCHRAN:

She is here, your Honor.

36 THE COURT:

Did she give you a status report?

37 MR. COCHRAN:

May I confer with the two of them?

38 (Discussion held off the record between Defense counsel.)
39 MR. COCHRAN:

Your Honor, I'm informed by Mr. Scheck and Miss Shawn Snider Chapman that they're in the process of interviewing witnesses, that they will take the rest of the day to try and do that. They cannot finish they think until tomorrow morning in that regard. They're asking that we come back tomorrow at 10 o'clock, and they will be ready to proceed with the Brady motion. They're going to have these witnesses brought down shortly with Mr. Shapiro I believe along with Mr. Yochelson to ask that they be ordered back. They'll finish today and then ordered back for tomorrow morning. That's my understanding from what Mr. Scheck has indicated, and we can start again at 8:30 tomorrow morning after they finish today.

40 THE COURT:

I'm sorry. I heard 8:30 and I heard 10 o'clock.

41 MR. COCHRAN:

Yeah. 8:30. They want--they want--they're going to try to finish interviewing the witnesses this afternoon. In case they can't, they want to resume the interviewing tomorrow morning at 8:30. And they somehow manage--

42 THE COURT:

How about we finish the interviews tonight and start tomorrow morning at our regular 9 o'clock?

43 MR. COCHRAN:

I'm sure they're going to try to do that, your Honor. But out of an abundance of caution, their thought was--there are a number of witnesses--they would perhaps need until 10:00, to have the witnesses ordered back tomorrow for 8:30. I think that was the plan. They are trying, your Honor. We had them go do that this afternoon.

44 THE COURT:

How many people do we--how many witnesses are we--

45 MR. COCHRAN:

Let me let one of them speak, your Honor, if I might.

46 THE COURT:

All right. Miss Chapman.

47 MS. CHAPMAN:

Good afternoon, your Honor.

48 THE COURT:

Good afternoon.

49 MS. CHAPMAN:

I know that officer--Detective Maxwell was going to leave by 4 o'clock today to try to pick up a child from school. So I don't know that we'll be able to interview him this evening. Mr. Yochelson will be down with the rest of the witnesses, and we'll try to interview whomever we can this afternoon.

50 THE COURT:

But how about if we come back at 9 o'clock, and if we then at that point can't--

51 MS. CHAPMAN:

Okay. Okay.

52 THE COURT:

All right. Thank you.

53 MS. CLARK:

Your Honor, so the record is clear, the Defense has had six months to talk to these people. They interviewed Lucienne Coleman in April.

54 THE COURT:

Excuse me. Counsel.

55 (Brief pause.)
56 THE COURT:

Miss Clark.

57 MS. CLARK:

They interviewed Miss Coleman in April. That means that as of this date, we have more than four months that they have had to talk to these witnesses, and now we need extra time at the 11th hour for them to interview witnesses they've had access to, opportunity to talk to ad nauseam for more than four months and in some instances six months?

KEY QUOTE
58 THE COURT:

Which is why I'm inclined to resume tomorrow morning at 9 o'clock, at our regular time. There are other motions we do need to conclude however at this point in time.

59 MS. CLARK:

And can we get a representation on the record as to what other witnesses the Defense intends to call other than the Brady witnesses, quote, unquote, and I use the term loosely that they intend to call before the jury?

60 THE COURT:

I think part depends on the court's ruling on the 1538.

61 MS. CLARK:

How would that be? Assume the court grants it, what further witnesses would they need to call.

62 THE COURT:

I don't know. I don't ask. Mr. Cochran, who else do you have after--since we've finished Mr. Hodge and the court's ruling, we're finished with Miss McKinny.

63 MR. COCHRAN:

Part of it is, your Honor, that there are two witnesses as the court is aware that I mentioned, Mr. Vettraino and Mr. Goulston, who are upstairs--I presume they're going to be talked to. I haven't gotten a report on those two at this point. We would also like, so we don't have any downtime--I've indicated this to counsel earlier--to know who their first rebuttal witnesses are so we can prepare for those. In other words, so we don't have downtime on that also.

64 THE COURT:

All right. So your representation is Goulston and Vettraino based upon the interviews that you conduct this afternoon.

65 MR. COCHRAN:

And Fuhrman if--the court's aware of that, and then plus the Brady motion.

66 THE COURT:

All right. All right. Thank you, counsel.

67 MR. COCHRAN:

Thank you, your Honor. We're going to need the rebuttal witnesses also, your Honor.

68 MS. CLARK:

As soon as the Defense rests.

Temperature

procedural

Key Quotes (4)

Darryl Mounger
I have advised Mr. Fuhrman that he should not answer any questions before this court. Therefore, it is my understanding that he will assert his 5th amendment privilege if asked any questions.
Mounger formally announces Fuhrman will take the Fifth, citing his own unfamiliarity with the trial record and inability to prepare Fuhrman adequately.
Gerald Uelmen
No, your Honor. We believe it's necessary for him to assert the privilege from the witness stand in response to a question.
The defense refuses to stipulate to Fuhrman's Fifth Amendment invocation, forcing the symbolic moment of Fuhrman refusing to answer on the stand before the jury.
Marcia Clark
They interviewed Miss Coleman in April. That means that as of this date, we have more than four months that they have had to talk to these witnesses, and now we need extra time at the 11th hour for them to interview witnesses they've had access to, opportunity to talk to ad nauseam for more than four months and in some instances six months?
Clark frames the defense's scheduling request as tactical delay, undermining their Brady motion urgency.
Cheri Lewis
So how is the Defense going to hurt his credibility in terms of why he went to the walkway when we know Kato testified during the preliminary hearing as to those three thumps behind there.
Lewis argues the defense's intended Fuhrman cross-examination on the suppression motion would add nothing because Kato's own preliminary hearing testimony already corroborated Fuhrman's account.

Evidence (3)

Informal
McKinny tapes and transcripts
Referenced by Mounger as materials he needed to review with Fuhrman before advising him on testimony
Informal
Preliminary hearing transcript
Ito states he needs to review it before ruling on the renewed motion to suppress
Informal
Defense supplemental memorandum / offer of proof of newly discovered evidence for motion to suppress
Discussed by Lewis, who argued the three points raised would not impeach Fuhrman's credibility

Notable Exchanges (3)

Darryl MoungerGerald UelmenLance A. Ito
Mounger offered to stipulate on the record that Fuhrman would take the Fifth; Uelmen refused, insisting Fuhrman must do it from the witness stand. Ito agreed and ordered Fuhrman to appear.
strategic
Marcia ClarkJohnnie CochranLance A. Ito
Clark pushed back sharply on the defense's request for additional witness interview time, noting they'd had months of access. Ito split the difference, ordering a 9 a.m. resumption rather than granting the 10 a.m. the defense wanted.
tense
Cheri LewisLance A. Ito
Lewis pressed for a chance to address the defense's supplemental brief while waiting for Mounger to return; Ito reluctantly allowed it, then largely cut her off mid-argument, indicating he already recalled the testimony.
procedural

Light Moments (1)

Peter Neufeld
Ito opens by asking where Shapiro and Cochran have gone; Douglas deadpans that Cochran is in lockup; Neufeld quips 'The two we need.'

Credibility Attacks (1)

⚔ Mark Fuhrman
anticipated impeachment (preemptively countered by prosecution)
Lewis argued the defense's planned cross-examination of Fuhrman on the suppression motion — regarding his decision to climb the wall, his search of Kato's room, and his reason for going to the walkway — would all fail because Kato's own preliminary hearing testimony already corroborated Fuhrman's account on each point.

Objections

None recorded
Proceeding 7527 • 68 utterances
Criminal Trial
Department 103
⚖️ Start
📂 SEP 6, 1995 📄 Brady motion discussion
SEP 6, 1995 KRT DvH TD