📄 Direct examination of O.J. Simpson by Michael Brewer — Friday, February 23, 1996
Address:
C:\DEPT103\DEPOSITION\1996\FEB\23\DIRECT-EXAMINATION-OF-O-J-SIMP.DOC
TRIAL
▲ Day 15 of 31

Direct examination of O.J. Simpson by Michael Brewer

Witness: O.J. Simpson
Examiner: Michael Brewer
Called by: Plaintiff • Date: Friday, February 23, 1996 • Utterances: 795
Brewer cross-examines Simpson on two main fronts: the physical condition of the Rockingham estate as depicted in a defense-produced videotape versus June 12, 1994, and Simpson's knowledge of blood evidence found at both Bundy and Rockingham. The blood questioning grows pointed, with Brewer pressing Simpson on why he never mentioned his cut finger to police when told blood was found on his property, and Baker interjecting that blood 'placed' at a scene isn't 'found.' The session ends heading into Simpson's suicidal state around June 17th and the 'To Whom It May Concern' letter.
1

BY MR. BREWER:

2 Q:

Mr. Simpson, I want to focus for a couple minutes on the Rockingham property, and on three specific time periods, the first being 6-12-94, and then the second time period the time that you were shooting the videotape. All right? You awake?

3 A:

Uh-huh.

4 Q:

Yes?

5 A:

Yes.

6 Q:

You okay to go on?

7 A:

Yes.

8 Q:

All right. Between those two time periods has there been any substantial changes in the foliage of the property?

9 A:

I'm sorry. Between when I shot the video?

10 Q:

6-12-94 and when you shot the video, has there been any substantial changes in the foliage? Have you done any plantings, any changes in the foliage to the property?.

11 A:

Okay. Since the 6-12 of '94 to the video that was shot this time?

12 Q:

Yes.

13 A:

I would think that it's alot thinner. That I could tell you specifically: It's a lot thinner along the southern portion.

14 Q:

By the pathway?

15 A:

Yes.

16 Q:

Okay. Was that thinned out under your direction?

17 A:

No.

18 Q:

Okay. Was that through the gardener?

19 A:

Evidently.

20 Q:

Okay. And you didn't have any discussions with the gardener about thinning out that area?

21 A:

No.

22 Q:

Any other foliage that changed during that time frame?

23 A:

My whole property seemed to when I got back seemed to be changed. I mean, stuff was growing where it shouldn't have grown and flowers weren't blooming. Yeah. You know, in general, yes, I think it looked not to be as kept up as it was when I was around.

24 Q:

Between the same time frame, were there any changes that were made under Your direction to the foliage of the property?

25 A:

No. I mean. Once I got back home, I-- you know. I had made some things--I wanted him to try to get some color back and to cut some of the trees that were growing through the tennis court fence, and the tennis court was basically being overwhelmed.

26 Q:

Okay. Were those changes made prior to the videotape being shot, the 1-800-OJTELLS videotape?

27 A:

I don't think they--I don't think the tennis court shows on the 1-800 videotape.

28 Q:

Okay. The areas of the property that are depicted in the 1-800-OJTELLS videotape, are those areas substantially similar at the time that the videotape was shot as of 6-12-94?

29 MR. ROBERT BAKER:

With the exception of the south pathway?

30

BY MR. BREWER:

31 Q:

Yeah, with the exception of what you've already mentioned. In terms of just the foliage now.

32 A:

I can't tell. It just seemed it was better kept when I was around than it was when I came home. There was areas that we normally had flowers or roses that there weren't any, so...

33 Q:

Okay. With respect to the operation of the Ashford and Rockford gates, were there any changes between 6-12-94 and the shooting of the videotape to how those gates worked?

34 A:

How they worked?

35 Q:

Yes.

36 A:

I don't believe so.

37 Q:

Okay. So what's depicted in the videotape as of--the OJTELLS videotape in terms of the operation of both gates is the same as of 6-12-94?

38 A:

You mean how you could--you know, I walked out of the Ashford gate then. I mean--I'm sorry. I walked out of the Rockingham gate, which I obviously could have disengaged the controls back then. So basically, as far as I know the basic mechanisms are the same.

39 Q:

Okay. The operational aspects of the gates, the Ashford gate and the Rockingham gates, were the same at the time that you shot the videotape as of 6-12-94?

40 A:

Yeah, the ability to operate them Various ways as far as I know is the same.

41 Q:

How about the lighting outside on your property, not inside but outside around the property? Was that substantially similar at the time that you shot the videotape as of 6-12-94?

42 MR. ROBERT BAKER:

With the exception-- obviously we're in December and there's Christmas lights up, and 6-12 is June.

43 O.J. SIMPSON:

Yeah.

44

BY MR. BREWER:

45 Q:

Talking about permanent lighting rather than, you know. transitional lighting like Christmas lights.

46 A:

I believe the security has beefed up lighting.

47 Q:

Okay. Well, was there nighttime filming? There was nighttime filming in the videotape. Correct?

48 A:

Yes.

49 Q:

Okay. Were the outside lights activated at the time that the nighttime filming was done?

50 A:

I think where the lighting was beefed up was--you couldn't see from the footage of what you were looking at. I don't think they impacted that.

51 Q:

Okay. The nighttime filming that was done, were the outside lights activated during that filming?

52 A:

I think the coach lights were on.

53 Q:

Okay. And any other lights that you're aware of that were on during that film?

54 MR. ROBERT BAKER:

Exterior?

55 MR. BREWER:

I am just talking about exterior right now.

56 O.J. SIMPSON:

That you can see on the video, I don't think any that wouldn't have been operational then.

57

BY MR. BREWER:

58 Q:

Okay. So the lights were substantially similar as of the videotape Strike that. The lights were substantially similar as of the time of shooting the videotape as compared with 6-12-94. Correct?

59 A:

The lights that you can see on the nighttime shooting, those lights that are visual I think are similar and the same. There are other lights that has been beefed up in other areas of the property, but I don't think--they come to play on that. The only nighttime video I recall is the show that you can't tell what lights are on in my house, and from what I can see on that, the lights are virtually the same.

60 Q:

After 6-12-94 was there any change in the wattage of the coach lights, making them brighter or less bright?

61 A:

I can't say for sure. I do know inside the house there was.

62 Q:

Well, how about the coach lights? you--Were new lights put in under your direction that added more brightness

63 A:

No.

64 Q:

--or more wattage?

65 A:

No.

66 Q:

Okay. The new lights that you're talking about that aren't necessarily depicted on the videotape where are those lights? Exterior lights

67 A:

In some trees and focusing on some areas which the security people think my property may be vulnerable from.

68 Q:

Okay. Are these in the back of the house, the side of the house or in the front?

69 A:

In all areas, I believe.

70 Q:

Okay. Including the front?

71 A:

Yes.

72 Q:

Have there been any new structural changes--Strike that. Have there been any structural changes since 6-12-94 to the shooting of the videotape? And what I mean by that, where you have had some change in--some new structure put up or a change in the garage or a change in the inside of the house or something of that nature?

73 A:

Other than some bamboo--I mean, some what they call bamboo sheeting that we have up now so that the lookie-loos can't see through. I think they put a solid board on both gates. So before where you could see through the gates, you can't now.

74 Q:

Okay. Is that permanent or temporary, the bamboo?

75 A:

The bamboo hopefully is temporary, but who knows.

76 Q:

Okay. How about the benches in front of the front door, are those still there?

77 A:

Yes.

78 Q:

The two benches?

79 A:

Yes.

80 Q:

In the same position?

81 A:

Yes.

82 Q:

Now, you've described the locks, the various locks throughout the property, indicating that there was a master key that you had and that the rest of the locks were controlled by individual keys. Is that correct?

83 A:

That's correct.

84 Q:

Okay. Is that the same at the time of the videotape as it was as of 6-1294?

85 A:

I don't know.

86 Q:

Well, were there any changes made to the locks under your direction?

87 A:

No.

88 Q:

So presumably they'd be the same. Correct?

89 A:

I can only--it would only be a guess on my part.

90 Q:

Well, do you have any information that the locks were changed after 6-12-94?

91 A:

No.

92 Q:

Any changes to the--Now, again I want to go inside now and talk about flooring. Any changes to the flooring since 6-12-94 and the shooting of the videotape?

93 A:

I'm sorry?

94 Q:

Any changes to the wooden flooring inside the foyer area

95 A:

No.

96 Q:

--between 6-12-94 and the shooting of the videotape?

97 A:

No.

98 Q:

Any changes in the carpeting that go up the stairs between 6-12-94 and the shooting of the videotape?

99 A:

No.

100 Q:

Interior lights, any changes in any of the interior lights? And I'm not talking about changing light bulbs to increase the wattage, but where you've had new lights put in between 6-12-94 and the shooting of the videotape.

101 A:

No.

102 Q:

Okay. Has there been any change in light bulbs inside your home where you've increased the wattage in, any particular rooms?

103 A:

Yes.

104 Q:

Okay. What rooms did you have lights put in that,would increase the wattage?

105 A:

I think I increased the wattage in all my lamps.

106 Q:

Was that done for a specific purpose?

107 A:

I don't know. Maybe just to show the lamps off a little more, and I'm yeah, no specific person--purpose.

108 Q:

Was it done for a specific purpose in relationship to shooting the video?

109 A:

No.

110 Q:

Was it done all at the same time?

111 A:

I don't know. I don't know if it was done--I'm sure it was done while I was in jail.

112 Q:

Well, do you have a specific recollection of having that done under your direction?

113 A:

Under my direction, no.

114 Q:

Okay. Why do you think that was done?

115 A:

I think--because people were just in the house, and when lights go out--a couple of lamps, I would only burn one or two bulbs in them because they burn all night, and I think people weren't aware of that, and when they changing bulbs, they see they're all out. They put all new bulbs in.

116 Q:

Okay. Are you assuming that when they put new bulbs in, they increased the wattage of the bulbs?

117 A:

Well, they put more bulbs--I don't know about the wattage of the bulbs, but most of my lamps I Will only burn--they have room for four to five or six bulbs in the lamp. I would only burn two or three bulbs in the lamp, and evidently during the course of changing lamps, they put more wattage in those lamps.

118 Q:

You said a moment ago that there are some lamps that you burn all night. Is that a practice that you follow: Burning particular lamps all through the night?

119 A:

Yes.

120 Q:

Okay. What lamps are those?

121 A:

My entry lamp and the lamp in my kitchen.

122 Q:

So those are on all night long, and you turn them off during the day?

123 A:

Yes. Normally, yes.

124 Q:

Are they on a timer?

125 A:

Now they are. They weren't before.

126 Q:

Okay. When did they first go on a timer?

127 A:

I don't know.

128 Q:

Well, but were they on a timer as of 6-12-94?

129 A:

I'm not sure.

130 Q:

Did you put them on a timer for--Strike that. Do you burn them all night for security purposes?

131 A:

No. I wake up every night and walk my house, and so it keeps me from turning on lights.

132 Q:

Okay. So you need some illumination in order to walk around your house?

133 A:

Yes.

134 Q:

Because otherwise--

135 A:

I don't need it. You could without it, but, you know, it's easier to have it.

136 Q:

Is there any light that comes into the house--any artificial light that comes into the house that would provide some illumination if you didn't have any of the interior lights off--on?

137 A:

I think any lights--I don't know if it provides illumination. I can walk around my house with no lights on. If all my outdoor lights am on, I can--you know, I can--I'm not going to trip over a couch or nothing.

138 Q:

Because of the illumination provided by the outdoor lights?

139 A:

To an extent, yes.

140 Q:

But those are lights on your property?

141 A:

Yes.

142 Q:

Are there any lights, streetlights, lamps off your property that provide illumination into your house that would facilitate your seeing as you're waking around?

143 A:

I wouldn't be able to tell. I wouldn't be able to answer that.

144 Q:

And you have no recollection with respect to whether these lights were on a timer--these all-night lights were on a timer as of June 12, '94?

145 A:

None, no.

146 Q:

The practice of your sometimes walking around at night, is that consistent with the entire time that you've lived at Rockingham?

147 A:

Yeah. I don't sometime. I always take at least one walk around my house at night.

148 Q:

Because of insomnia? You can't sleep?

149 A:

No. I check on my kids, look out at the dogs, you know, take a leak. It's just always been my practice.

150 Q:

Does the dog normally sleep outside?

151 A:

Yes.

152 Q:

Chachi?

153 A:

Yes.

154 Q:

How about in inclement weather?

155 A:

Yes. I open the garage door.

156 Q:

And you leave the door open, or do you shut the garage door?

157 A:

No. I leave it open.

158 Q:

The--There has been some--a lot of description and discussion relative to some gates along the south pathway. There's essentially two gates there. Is that correct?

159 A:

I believe so.

160 Q:

Okay. And the first gate, if you were to walk around the garage and then head in an easterly direction along that southern pathway, there is a gate that Mr. Kaelin described as having to pick up and kind of move to the side. Do you recall that description?

161 A:

I recall that description.

162 MR. PHILLIP BAKER:

Are we talking about the gates in June or as they presently are?

163

BY MR. BREWER:

164 Q:

Are those gates--Was that an accurate description?

165 A:

I don't know if it was an accurate description. I recall where the gate might have been, Yes.

166 Q:

Is there still a gate there today?

167 A:

I believe so.

168 Q:

Okay. When is the last time you were along the southern pathway?

169 A:

You mean all the way back the southern pathway?

170 Q:

Well, crossing past the garage and then heading easterly through these two gates that have been described.

171 A:

Maybe a month ago.

172 Q:

Okay. Did you have to walk past two gates or open two gates to--

173 A:

I don't recall.

174 Q:

--walk back there?

175 A:

I don't recall if the gates were open or not.

176 Q:

Okay. Have you made any repairs to any of the gates along the southern pathway since June of 19---June 12th, 1994?

177 A:

I don't know what state of repair they were in then, so I can't answer that.

178 Q:

Okay. Well, you would know whether you hired somebody to come out and make a repair to the gate, wouldn't you.?

179 A:

No.

180 Q:

You wouldn't know that.

181 A:

No.

182 Q:

Okay. Have you ever picked up the phone and contacted anyone to come out and make a specific repair to any of the gates along the southern pathway?

183 A:

No.

184 Q:

Have you ever asked anyone to do that on your behalf?

185 A:

No.

186 Q:

Have you ever been told that that was done in your behalf?

187 A:

No.

188 Q:

Is it your understanding that the first gate that we're talking about, that Kaelin described as having to move aside, is in the same condition today that it was as of June 12, 1994?

189 A:

I don't have an understanding one way or the other on that.

190 Q:

On those occasions where you had to go back along the southern pathway, do you recall having to, in a similar fashion as described by Mr. Kaelin, pick up the gate and move it aside to walk in an easterly direction?

191 A:

I don't have no recollection of that, no.

192 Q:

Do you recall it being a chain-link type of gate?

193 A:

I believe if there were gates there, they would be chain-link type gates.

194 MR. ROBERT BAKER:

Mike, let's take a break. He's getting tired. Any problem with that?

195 MR. PETROCELLI:

No.

196 MR. BREWER:

No.

THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 3:33.

[Recess.]

THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 3:48.

197

BY MR. BREWER:

198 Q:

Okay. Mr. Simpson, we are focusing on a time period between 6-12-94 and your shooting of the videotape. We have gone through a number of items where I've asked you whether there have been any changes. And focusing for the moment on Kato Kaelin's room and the interior of that room, were there any changes in the layout or configuration of that room between 6-12-94 and the videotape?

199 A:

I'm not in a position to answer that because I hadn't been in that room in so long previous to that date. So, you know, I can't tell you. I can't answer it.

200 Q:

Well, you've seen photographs that were introduced into evidence at the criminal trial of his room. Right?

201 A:

Yeah, but the bed--the bed's in the same place.

202 Q:

Okay. The picture on the wall to the right of the bed, is that still in the same place as of the shooting of the videotape?

203 A:

I don't recall. I don't think so because I think--I don't think so. I don't know about as of the shooting of the videotape. As of the shooting of the videotape, maybe. I don't know. I just know that other pictures are up right now.

204 Q:

Were there any changes made to the interior of his room under your direction?

205 A:

I don't believe--of the interior of his room I don't believe so. I know--I don't believe so. Not to my direction, I don't believe so.

206 Q:

Any part of his room exterior or interior, any changes made under your direction?

207 A:

Maybe they got a new bedspread. Maybe-- I do know now, but I believe it's since the video, that there are different pictures and things in there, so I am aware of that. But as of the shooting of the video, because I wasn't aware of what was in there before and I never--I can honestly say what ever pictures came up in Kato's room I never really looked at it, so I can't--and I haven't been in that room you know, in a tremendous long time before Kato--you know, before that day. Since Kato lived in there, I hadn't been in there in--

208 MR. ROBERT BAKER:

You've more than answered the question.

209 O.J. SIMPSON:

I don't know.

210

BY MR. BREWER:

211 Q:

Were there any changes that you're aware of with respect to the interior of Kato's room that were done specifically for the videotape?

212 A:

No.

213 Q:

You mentioned a moment ago about a couple lights that you leave on through the night. Where exactly are those lights located inside your house?

214 A:

One's on a built-in desk type thing in the kitchen, and one is built--one is on a--well, it's no longer an armoire. Sort of a sideboard in my entry.

215 Q:

In your entry. Any other lights that you have a custom or practice of leaving on through the night other than those two?

216 A:

Sometimes I'll leave--No. That was basically it, yeah.

217 Q:

Are there lights that from time to time you leave on through the night other than those two?

218 A:

From time to time, yes, but those are basically the lights.

219 Q:

Other lights that you leave on purposely through out the night from time to time?

220 A:

Those are two that I leave on. There's one other one that sometimes since I've been home I might have on from time to time.

221 Q:

And where is that light located?

222 A:

In my TV room. It's a lamp on the table in my TV room.

223 Q:

What would dictate your leaving that on through the night?

224 A:

Depending who's staying in the guest room and how active they might be as the evening goes on.

225 Q:

Okay. How about Arnelle's room, either the interior or the exterior, between 6-12-94 and the shooting of the videotape, any changes that you're aware of?

226 A:

Shooting of the video? I don't--were their rooms in the video?

227 Q:

I am just asking: Were there any changes made to the room?

228 A:

More than likely there were, but I don't know because I never--I didn't go out there so I don't know.

229 Q:

Between--Strike that. At any time after June 12, 1994 did you direct that any repairs be made to the window outside Mr. Kaelin's bathroom?

230 A:

No.

231 Q:

How about outside Arnelle's room?

232 A:

No.

233 Q:

And now I am going to the third time frame I want to focus on is today, but I just want to go through like a checklist, and when I mention the item just tell me whether there has been any substantial changes made to that particular item so we can go through this. All right? You with me?

234 A:

Yes,

235 Q:

All right.

236 A:

Today.

237 Q:

Interior lighting? The time frame is between the shooting of the videotape and today. Okay?

238 A:

I moved a lamp, and--other than maybe lamp bulbs, I moved a lamp.

239 Q:

Okay. And what lamp did you move?

240 A:

A lamp out of my formal living room into my TV room.

241 Q:

Okay. And what was the purpose of moving that lamp?

242 A:

Just to give it a different look.

243 Q:

And did you replace any light bulbs since the shooting of the videotape that you specifically recall?

244 A:

I'm sure we may have, but I can't specifically recall.

245 Q:

Do you recall either yourself or directing someone to replace light bulbs, increasing or decreasing the wattage of those bulbs?

246 A:

The lamp that we moved I think only had two bulbs in it, and since it's one of my favorite lamps, maybe the first one I purchased, and when we moved it to put it in another room, I think I filled it up with bulbs just to, you know, to get the full effect of the lamp. I don't know if we kept it that way. I think we burn two or three of those bulbs in it now, but when I first did it, I know I wanted to look at the full effect of the lamp.

247 Q:

Okay. Other than this lamp, any other changes inside your home between shooting the videotape and today with respect to lighting?

248 A:

I may have added a lily pad lamp to my bedroom.

249 Q:

Okay. When you say "I may have," do you have a specific recollection between this time frame adding--

250 A:

No, I don't know if it was there before I we shot the video or after we shot. You know, it is there today. I know that. It's by my bed.

251 Q:

Okay. Was this a lamp that you added specifically for shooting the video?

252 A:

No.

253 Q:

Okay. Was it a lamp just for aesthetic purposes or lighting purposes?

254 A:

Yeah. Yeah. It's a lamp that was in a closet because some of the shades were missing, and I just wanted to use it.

255 Q:

Was the lamp--Do you remember exactly when you pulled it out of the closet and started using it?

256 A:

No.

257 Q:

Before or after the video?

258 A:

I don't know.

259 Q:

Okay. Your bedroom, do you have drapes on the windows in your bedroom?

260 A:

Yes.

261 Q:

Okay. Those drapes in the same condition now that they were as of June 12, '94?

262 A:

Yes.

263 Q:

Do you have a practice whether you close them or leave them open?

264 A:

I close them at night.

265 Q:

Okay. When you're sleeping?

266 A:

Yeah.

267 Q:

Otherwise you leave them open?

268 A:

Well, normally when I go up to my bedroom I close the drapes, because I don't know when I'm going to fall asleep and I don't want to have to get up and have to, you know, close them.

269 Q:

Do you have a practice during the summertime with respect to whether you sleep with windows open or closed?

270 A:

No way, no. Not one way or the other.

271 Q:

Not one way. So sometimes you may open them, and sometimes you'll close them?

272 A:

I don't have any windows open in My bedroom. I do have a door I could open. There is no windows really to open upstairs in my bedroom.

273 Q:

Okay. In the same time period, again, I am not--I am talking now about shooting the video at present day, and focusing now on exterior lighting, any changes?

274 A:

Well, I know that they've added since June 12th--

275 MR. ROBERT BAKER:

The video in December is the time period.

276 O.J. SIMPSON:

No, I don't think any changes since the video.

277

BY MR. BREWER:

278 Q:

So the lighting should be substantially similar to as it was as of shooting the videotape. Correct

279 A:

Yes.

280 Q:

Foliage? Again, I am not talking about natural growth. I am talking about where you have specifically put in plants or had things removed.

281 A:

Well, I've thinned out my trees, not in the front yard but in the backyard. I've had those pruned. I don't know if that was before or after the video. I don't think--I don't--I can't recall. I think along the walk drive that goes into Rockingham he may have planted some ground flowers, but I don't know if that was before or after either.

282 Q:

Same time frame, but the question is with respect to locks.

283 A:

I don't--I have no knowledge of us changing any locks.

284 Q:

Okay. So presumably they're the same now as they were as of shooting the videotape in December.

285 A:

Yes.

286 Q:

Okay. Flooring inside the foyer?

287 A:

I think I added a rug.

288 Q:

You did that since the videotape?

289 A:

Yes.

290 Q:

Okay. Was that just for aesthetic purposes?

291 A:

Yes.

292 Q:

Okay. Carpet inside the house?

293 A:

The same.

294 Q:

Window coverings?

295 A:

They're the same.

296 Q:

The two gates along the southern pathway between shooting the videotape and the present time?

297 A:

I have no idea.

298 Q:

Okay. How about Kaelin's room same time frame?

299 A:

Since the video, I think we have different pictures in there and--yeah, and a leak has been added. No. I know pictures are a little different. It my have been spruced up since then a little bit. I got--yeah, I think some--definite for sure some pictures have been added.

300 Q:

By the way--

301 A:

And I don't know if they were there before, but they were there since, since the video. Yeah. pictures have been added in there.

302 Q:

How about Arnelle's room? Since the video, any changes either inside the room or outside of the room?

303 A:

Since the video?

304 Q:

Yes.

305 A:

Well, I don't know when she moved, so I don't know. So when she moved,--she took most of her stuff out of there.

306 Q:

Since the videotape, any changes to the window outside Kato Kaelin's bathroom?

307 A:

Not that I know of

308 Q:

Well, did you make any changes or authorize any?

309 A:

No.

310 Q:

Okay. How about outside Arnelle's room?

311 A:

I got to say this: Any repairs that are done, even though my people who work for me know to make the repair if it needs to be done, so in a sense that's all authorized by me because I got to pay for it, but no specific knowledge of anybody doing any of this.

312 Q:

Were there any repairs made under your direction where you specifically asked them to make repairs with respect to Kaelin's window?

313 A:

No.

314 Q:

Okay. How about Arnelle's windows?

315 A:

Not that I know of.

316 Q:

Okay. In the entire time period that you have lived at Rockingham. has anyone ever--who was in Arnelle's room or Kato's room ever reported noises presumably emanating along the southern pathway?

317 A:

I can't recall.

318 Q:

Okay. I want to go back to an exhibit that was previously marked I believe as 1. I'm not Sure. What number do you have on that?

319 MR. ROBERT BAKER:

6.

320 MR. BREWER:

6?

321 Q:

Exhibit 6, which was the--

322 MR. KELLY:

A description--

323

BY MR. BREWER:

324 Q:

--which was the June 15, '94--it's dated June 15, '94, "To 'Whom It May Concern" letter, which I think you've indicated it was actually on 6-17-94. Is that correct?

325 A:

That's correct.

326 Q:

Mr. Simpson, at the time that you drafted this letter, had you heard from any source, excluding conversations, with lawyers, that the police theorized that a killer or killers had left blood at the Bundy crime scene?

327 A:

I don't recall. There was so much on TV, I'm sure I probably heard something.

328 MR. ROBERT BAKER:

You don't have to speculate. If you don't recall, you don't recall.

329 O.J. SIMPSON:

I'm sure--No, I don't recall. There was so much going on and being said at that Period of time, I don't know.

330

BY MR. BREWER:

331 Q:

Well, do you recall at some point learning that the police were theorizing that blood had been left by a killer or killers at the Bundy crime scene?

332 A:

I may have.

333 Q:

Do you remember how you learned that information?

334 A:

No.

335 Q:

Do you remember when you learned that information?

336 A:

Not particularly, no.

337 Q:

Do you remember whether it was before or after you began drafting this letter? A. I don't know.

338 Q:

At some point after the murders did you learn that a glove was found on your property?

339 A:

As I said, I heard so much that day, and during that week that I'm sure I had heard about--I know I heard about a glove and ski mask.

340 Q:

When did you hear that for the first time?

341 A:

I believe the first day.

342 Q:

Okay. I mean, that would be a pretty significant piece of information, that evidence linked with the crime scene was found on your property. Right?

343 A:

I don't know if anybody linked anything at that point.

344 Q:

Well, what did you hear exactly about the glove?

345 A:

I don't know. I was hearing everything. I was hearing bloody ski mask. I don't know if I heard glove the first day. I know I heard bloody ski mask right away.

346 Q:

Well, when you said you "heard bloody ski mask," did you hear a bloody ski mask was found on your property?.

347 A:

That's what they were reporting, something about a bloody ski mask, I believe.

348 Q:

And when you first heard--Strike that. At some point did you determine or learn that a bloody ski mask was not found on your property, that that was a false report

349 A:

At some point, yes.

350 Q:

Do you remember when that was?

351 A:

No.

352 Q:

Do you remember what evidence, if any, you knew about at the time that you began drafting this letter?

353 A:

I didn't know what was evidence and what wasn't evidence. I was hearing everything that was in the--everything that was being reported, I was hearing it all. So whatever was being reported that Week, I heard it.

354 Q:

Well, do you remember hearing about any evidence that you believe may tend to implicate you?

355 MR. ROBERT BAKER:

Well, the point that he has just made is he didn't know what was evidence and what wasn't, so your question is without foundation.

356

BY MR. BREWER:

357 Q:

Did you hear about any information that may tend to implicate you in these murders?

358 A:

I heard they were going to arrest me, and that was the information that was implicating me.

359 Q:

Okay. That's the first time in your mind there was any information that was implicating you in these murders, was when you actually heard that you were going to be arrested?

360 A:

I heard everything on the news. I heard newscasters theorizing and making claims about things that I didn't think were true.

361 Q:

Okay. Well, what reports do you remember by newscasters--

362 A:

Well one of them--

363 Q:

---regarding information that you didn't think was true?

364 A:

DeVilla, Bob DeVilla, somebody with Channel 4.

365 Q:

Avila?

366 A:

Avila. He was doing a report about when I arrived at the hotel in Chicago, I was loud and boisterous as if I was attempting to draw attention to my self, and I'm saying that was not true. There was nobody in the lobby except the people who were greeting me, and I was dragging when I walked through the door. So, I mean--and other than specifics--I know that was a specific, and there was a lot of that type of stuff being said.

367 Q:

Is that a report that you heard at Rockingham?

368 A:

I may have. I may have. I just know that week I heard it, and it was on TV.

369 Q:

And that's a report that specifically sticks out in your mind as you're testifying here today. Is that true?

370 A:

Because that was something I knew was not true.

371 Q:

Okay. I mean, you knew for a fact that that was totally inaccurate. Is that correct?

372 A:

Correct.

373 Q:

And because it was inaccurate and it was being reported on television. it's something that you have a specific recollection of as you're sitting here testifying during this deposition. Is that true?

374 A:

That one, yeah. There was a lot of stuff, and I can't recall a lot of it, but that was one that--you know why? It may have been the first thing I heard, and then so much was being said and implied after that, it was almost like I had to kind of turn off and my focus went to my family.

375 Q:

Okay. Well, I just want to make sure I understand your testimony, which I understand isn't the test, but for me it's going to be the premise of this question: With respect to this report that you heard from the reporter, Bob Avila, was there something about the way in which he reported the information or was it the substance of the report that caused you to have some difficulty with his reporting?

376 A:

It was a lie.

377 Q:

Okay. It was a lie.

378 A:

Yes.

379 Q:

Okay. Now, are there any other reports relative to information in the case that you specifically recall as you sit here today because you felt the information was false or untrue?

380 A:

There was--I can't give you specifics, but if you take tapes of that week, there was just so much being said that--so much I didn't know if it was true or false, and there was numerous things that I knew were not true and--as they were reporting it. And so there were things that I heard that week that were just--just--you know, I just didn't believe them.

381 Q:

Well, Mr. Simpson, you knew that they were reporting that your blood was actually found at the crime scene, didn't you?

382 A:

I don't know if they reported that that week. I'm not sure if they reported that that week, but whenever they reported it, I was aware of it, and I don't recall if that week that was reported or not.

383 Q:

Okay. Well, the first time that you heard that your blood was found at the crime scene or a claim that your blood was found at the crime scene was through the press. Isn't that true?

384 A:

I would imagine so.

385 Q:

Okay. And you knew that to be absolutely false. Isn't that true?

386 A:

I knew that I hadn't deposited any blood at Nicole's house that night.

KEY QUOTE
387 Q:

You knew that it was virtually impossible for your blood to be at that crime scene. Isn't that true?

388 A:

I don't know if it's impossible for me to have blood at Nicole's house or not. I knew--

389 Q:

Well, was it possible--

390 MR. ROBERT BAKER:

Let him answer the question.

391

BY MR. BREWER:

392 Q:

Excuse me. Go ahead.

393 A:

I knew that--and I don't know if I knew this that week. I'm telling you as I know today. I knew I didn't deposit any blood at Nicole's house that day. So that's what I know today. I don't recall in the scheme of things when this blood drops became an issue in all of this. I don't recall if that was that week or the following week or what.

394 Q:

So you're saying that when you first heard that report, you weren't certain whether you had deposited blood at the crime scene?

395 MR. ROBERT BAKER:

Wait a minute. "At the crime scene"? That isn't what he said.

396 MR. BREWER:

I am just asking.

397 Q:

Is that what you're saying?

398 A:

No. I'm saying that as I can tell you now today, I did not deposit any blood that day at Nicole's house. It just--it didn't happen. So that's what I know for a fact today. During the course of all of this, when whose blood was where, I don't know when I found that out. I don't know if that was that week, the next week. I don't know if it was weeks later. I really don't know.

399 Q:

Well, when you first heard that report about your blood being at the crime scene, in your mind did you know that that wasn't possible?

400 A:

I knew it was impossible for me to have deposited that blood that night at anywhere. If it was my blood or wherever they may have found blood of mine, I knew it was impossible for me to have deposited that blood at Nicole's house that night.

401 Q:

That's because you weren't there. Right?

402 A:

Correct.

403 Q:

And you weren't bleeding on her property. Is that true?

404 A:

Not that day, certainly not, no.

405 Q:

Well, some other day do you recall bleeding on the Bundy property?

406 A:

I do recall at some point, and it may have been when we first got Kato, the dog, I do recall at one point Sydney and Justin getting me a--I don't know if it's Flintstones or something Band-Aid. I just don't recall when. That could have been months previous to this. I just don't recall.

407 Q:

Well, did you cut yourself and were you dripping blood up the walkway at the Bundy property?

408 A:

At that time? I don't know.

409 Q:

At any time prior to June 12, 1994--

410 A:

Not that I'm aware of.

411 Q:

--did you ever drip blood up the Bundy walkway?

412 A:

Not that I'm aware of

413 Q:

Is it possible?

414 A:

Anything's possible. But not that I'm aware of.

415 Q:

You have a specific recollection of having the kids get you a Band-Aid because you cut yourself at the Bundy property?

416 A:

I don't know. I just have a--I remember having a--I think a Flintstones--I'm not sure. One of these Band-Aids, I remember Sydney getting me one. It may have had something to do with Nicole closing my hand in her car door.

417 Q:

Was that an accident?

418 A:

Yeah. Yeah. But I don't recall dripping blood at that time. I know it was like a tear or something [indicating] , but I don't recall dripping blood at that time.

419 Q:

You're pointing to the pinkie on your left hand.

420 A:

I think so. I think it was one of my hands. I can't even remember what hand it was. But she--the window part of her thing, she closed the door on my hand.

421 Q:

And do you remember the reporter that first made that report that was reporting your blood being found at the Bundy crime scene?

422 A:

No.

423 Q:

Do you remember what channel it was on?

424 A:

No.

425 Q:

Do you remember where you were when you first heard that report?

426 A:

No.

427 Q:

Do you remember saying anything in response to the TV or anyone else in the room when you first heard that report?

428 A:

No.

429 Q:

Did you have a verbal response when you first heard the report your blood was being found-- your blood had been found at the crime scene?

430 A:

Possibly.

431 Q:

Okay. What did you say?

432 A:

I don't know.

433 Q:

You have no recollection whatsoever?

434 A:

No.

435 Q:

When did you first learn about the location of the blood drops found at Rockingham? Do you understand that question?

436 A:

No.

437 Q:

Okay. As you sit here today, do you know where blood drops were found at Rockingham?

438 A:

Yes.

439 Q:

Okay. For example, they were found in the foyer. Is that correct?

440 A:

I'm told that, yes.

441 Q:

Well, when you say you're "told that." you've seen the actual photographs that have identified the location in the foyer where the blood drops were found. Isn't that true?

442 A:

Yes.

443 MR. ROBERT BAKER:

If you put blood drops there, they're not found.

KEY QUOTE
444 MR. BREWER:

Excuse me?

445 MR. ROBERT BAKER:

If blood drops are placed there, they're not found, but go ahead.

446

BY MR. BREWER:

447 Q:

Well, aside from semantics, you have seen photographs where there are identifying marks indicating that blood drops were found in your foyer. Is that true?

448 A:

I've seen those photographs, yes.

449 Q:

And, similarly, you have seen photographs where identifying marks have been placed on blood drops found in your driveway. Is that true?

450 A:

That's correct.

451 Q:

Okay. Now, Mr. Simpson, when is the first time that you learned or had any information relative to the location of blood drops found at Rockingham?

452 A:

Some of it I think I learned upon arriving at my house.

453 Q:

Okay. And how did you learn that?

454 A:

A police officer. I don't know if it was Phillips. When I was handcuffed by the house, I kept saying, "Why am I handcuffed?" And somebody said something about blood, "There's blood here, and that, 'We got blood there; we got blood here," and I saw these cards, and I assumed--I guess I made an assumption that maybe that was some blood drops.

455 Q:

Okay. So there was some discussion in your police statement about blood being found at Rockingham. Is that correct?

456 A:

I believe so, yes.

457 Q:

And in fact you knew before you even went down to the police station that there was blood found--at least you speculated that there may have been blood found at Rockingham because you saw cards identifying blood spots. Is that true?

458 A:

I really didn't speculate anything. This guy said, "Blood was found" or "There's blood here and there's blood there," or something, and--

459 Q:

Who said that?

460 A:

I believe it was Phillips or it was-- whoever had--said it had a mustache.

461 Q:

They have white cards identifying where the drops were?

462 A:

I don't know. I don't know. There were just--there were--yes, there were cards. I don't know if they were white cards or what, but there were things, you know, sitting in spots and--I don't know. The guy just said that, and, you know, that wasn't prevalent--that wasn't foremost on my mind. That wasn't what I was focusing on.

463 Q:

Well, you came back from Chicago because your wife had been killed. Is that correct, Mr. Simpson?

464 A:

Because my ex-wife had been killed, yes.

465 Q:

Okay. And then you were told as you entered the property, after being handcuffed, that blood was found on your property. Is that true, sir?

466 A:

Correct.

467 Q:

Did you tell them "Hey, I cut myself last night. Maybe that's from me"?

468 A:

No.

469 Q:

Did you offer any explanation at that time with respect to those blood drops?

470 A:

No.

471 Q:

Did you conclude in your own mind that perhaps those blood drops were left by you because you had cut your finger--

472 A:

No.

473 Q:

--the night before?

474 A:

No.

475 Q:

You had no thoughts one way or another how those blood drops got there?

476 A:

I didn't think about blood drops. I was thinking about Nicole, my kids and why was I handcuffed.

KEY QUOTE
477 Q:

Well, all the way back from Chicago you were making phone calls to a number of different people, trying to investigate exactly what happened. Isn't that true?

478 A:

No. I was trying to have people go by my house, see what my family was doing, what was going on with my family, and, yes, information--I like to know what was going on, what happened, and still to this day want to know what happened.

479 Q:

And when you saw the blood drops, you made no statements whatsoever with respect to those possibly coming from you from the night before, to Detective Phillips.

480 A:

That's correct.

481 Q:

Did you ask him whether he knew how those blood drops got there?

482 A:

No.

483 Q:

Did you ask him how long they believed they were there?

484 A:

No.

485 Q:

Did you ask him any questions whatsoever with respect to how those blood drops got there?

486 A:

I asked him. "Why am I hand---cuffed?"

487 Q:

Well, you saw blood drops on your driveway. Right?

488 A:

No.

489 Q:

You just indicated that you were told that blood drops were on your driveway.

490 A:

No. The guy said, "There's blood around here" or "blood here and there's a lot of blood there," so--

491 Q:

Well, did you ask him, "Hey, did it come from the murderer?"

492 A:

I didn't ask him anything. I didn't know what to ask him. I wanted to know where my kids are. I want to know, "Why am I handcuffed? Where are my kids? Why can't I go in my house?" Those are the things I wanted to know.

493 Q:

So you had no interest in finding out any information with respect to blood drops found--

494 MR. ROBERT BAKER:

Don't answer. That's--

495

BY MR. BREWER:

496 Q:

--on your property?

497 MR. ROBERT BAKER:

--argumentative.

498 O.J. SIMPSON:

At that time, no.

499

BY MR. BREWER:

500 Q:

Okay. Prior to Detective Phillips telling you about blood drops on your--

501 A:

If it was Phillips. I'm not sure it was Phillips. There's another guy I see sometimes, and it could have been that guy, but whoever did it had a mustache. I wasn't paying attention to him. It was so much going on, and as things were happening, you know, my lawyer was there and Vannatter was there. You know. it was a tough, tough time.

502 Q:

Let's kind of hone in here and see if we can identify possibly who you spoke with. It could have been Phillips. Is that what you're saying?

503 A:

Yes.

504 Q:

Okay. There is someone else that was there that it could have been?

505 A:

There was a lot of other people there, but there is one other guy I have seen since, and when I think about it, I wonder was that Phillips or this other guy.

506 Q:

That spoke to you about the blood drops.

507 A:

Yes.

508 Q:

Okay. And was the other person a detective or a uniformed officer?

509 A:

Detective.

510 Q:

And can you describe him?

511 A:

He has a mustache. That's all I can tell you.

512 Q:

Have you ever learned his identity?

513 A:

I may have seen him and heard his name, but I can't recall now.

514 Q:

Did he testify at the criminal trial?

515 A:

No.

516 Q:

Was he ever in the court?

517 A:

I can't recall.

518 Q:

Okay. Other than having a mustache, do you have any other information that would help identify him?

519 A:

No.

520 Q:

Any other description of him other than having a mustache?

521 A:

White guy with a mustache.

522 Q:

How tall was he?

523 A:

I don't know.

524 Q:

What color was his hair?

525 A:

I wasn't paying attention to him. I don't--you know, I don't really study guys.

526 Q:

Okay. Was it Detective Lange?

527 A:

No.

528 Q:

You're able to definitively rule out that it was Detective Lange?

529 A:

Yeah.

530 Q:

Was it Detective Vannatter?

531 A:

No.

532 Q:

Able to rule out that it was Vannatter?

533 A:

Yes.

534 Q:

Was it Detective Fuhrman?

535 A:

No.

536 Q:

Are you able to rule out that it was Detective Fuhrman?

537 A:

Yes.

538 Q:

Okay. You know it was a detective, though.

539 A:

Well, he was on my property, had on a suit. and I assumed it was a detective.

540 Q:

Did he have a badge?

541 A:

I didn't see a badge.

542 Q:

Did he represent himself as a Los Angeles police officer or detective?

543 A:

I don't recall that.

544 Q:

Going back to Exhibit 6. Now, when you wrote this letter, you indicated that you were in a lot of pain from the loss of Nicole. Is that true?

545 A:

Yes.

546 Q:

And you felt suicidal. Is that true?

547 A:

I wanted the pain to stop.

548 Q:

Okay. And the secondary component to your feelings at that time were other things. There were other things going on, I think is how you described them earlier. Is that correct?

549 A:

I don't know.

550 Q:

Well

551 A:

Everything was going on. I was in pain. I wanted the pain to stop. That's all I can really say about it. I was in a lot of pain.

552 Q:

Okay. And the pain, as you've indicated already, is because of Nicole, the loss of Nicole.

553 A:

I would say that was obviously the genesis and the major portion of it all. Yes.

554 Q:

And were you beginning to feel like you were being targeted as the person that committed these murders?

555 A:

Yes.

556 Q:

And wasn't that based upon news reports of evidence that was being developed in the case?

557 A:

I believe so.

558 Q:

And you knew at the time that you were told about these murders and thereafter that the Los Angeles Police Department was conducting an investigation. Isn't that true?

559 A:

Yes.

560 Q:

And I take it, Mr. Simpson, that you assumed that they would continue the investigation and develop evidence and leads and follow those leads in connection with this case. True?

561 A:

Yes.

562 Q:

At the time of--Strike that. As of June 12,1994, did you have any concerns about the competency of the Los Angeles Police Department in conducting murder investigations?

563 A:

I didn't give it any thought.

564 Q:

Okay. Did you assume that they would competently follow through with any leads that they developed in connection with the case?

565 A:

At the time I didn't give it any thought.

566 Q:

Did you have any reason to believe they wouldn't?

567 A:

No reason whatsoever.

568 Q:

Did you have any reason to believe that they would not ultimately locate or identify the person or persons responsible for these murders?

569 A:

At the time I didn't think about that.

570 Q:

Okay. Well, were you confident that they would conduct an investigation and hopefully find the person that murdered your wife--ex-wife and Ron Goldman?

571 MR. ROBERT BAKER:

How can you be confident if you didn't think about it?

572 O.J. SIMPSON:

I have--you know, I read a lot of--a lot, and I know that normally they don't. In most cases they don't. So, I mean, that was just knowledge I had from you know, years of reading, and, you know, in most cases they don't.

573

BY MR. BREWER:

574 Q:

Well, Mr. Simpson during the first

575 A:

I don't know if I thought about that that day. I'm pretty sure I didn't even think about that then.

576 Q:

When you talk about everything going on, you're talking about press reports that are intimating that you killed Nicole and Ron Goldman. Right?

577 MR. ROBERT BAKER:

You mean to the exclusion of everything else, that's what he's talking about?

578 MR. BREWER:

No.

579 Q:

When you said earlier that the reason why you were suicidal--you gave two reasons: One was the pain associated with the loss of Nicole. The second reason was what you characterized as "everything." I want to figure out what is the everything. And in relationship to that, you've indicated that you began to hear press reports about you possibly being the number one target or the suspect in connection with these murders. Is that true?

580 MR. ROBERT BAKER:

Which one do you want him to answer? Don't answer that question. There's about four questions in there, and it's compound. Don't answer that.

581

BY MR. BREWER:

582 Q:

Well, were you concerned, Mr. Simpson, about the press reports that were indicating that you were the number one suspect in connection with these murders?

583 A:

I don't know if I was concerned. I was hurt by it all, and it just added to the hurt that I was feeling.

584 Q:

Okay--And did you believe that the information that was being reported as tending to indicate that you had some responsibility was false?

585 A:

Yes.

586 Q:

And that--Let's take, for example, the information relative to your blood being found at Bundy. Did you have a belief that any information that reported your blood being found at Bundy was false?

587 A:

I don't know if I knew or heard that that week, so I can't answer that because I don't have any--I can't tell you when I heard that. That could have been three weeks later or four weeks later, as far as I know. So that wasn't anything that I could focus on right now and say that that was a part of it.

588 Q:

As you sit here today, is the only report that you recall indicating anything about you in connection with these murders the NBC report referring to your demeanor and attitude when you got to Chicago?

589 A:

I'm sorry. Ask the question again.

590 Q:

As you sit here today, is the only news report that you recall in this first week that you have a specific recollection of the NBC news report by Jim Avila about you coming to Chicago and being loud and boisterous? Is that the only one you recall?

591 A:

I have a specific recollection that there were numerous things being said that week that gave an impression that I was--I committed this crime. I do remember that. Avila's--I remember because I believe it was the first thing I heard to be--that I knew personally was totally false.

592 Q:

Okay. And did you perceive his report as having a tendency to implicate you in these murders?

593 A:

That's the way it sounded to me, yes.

594 Q:

Okay. Is there any other report that you have a specific recollection of other than the Avila report?

595 A:

Right now I can't at this moment not say. I just know there were numerous things that week.

596 Q:

Well, when you say "numerous things." what is the numerous? What

597 A:

I don't know.

598 Q:

--items were being reported that you were responding to or concerned about?

599 A:

If you--maybe you should do go and listen to all the reports that week, and you'll find them. I have no specific memory right now. I know they were there, I know I heard them, and I know that at the time that they were--all of it was causing more pain.

600 Q:

well, as of the writing of this letter, did you assume that eventually this would all be sorted out and that the murderers would eventually be found or identified?

601 A:

I certainly hoped so.

602 Q:

Okay. And you had every reason to believe that that would happen, didn't you?

603 A:

I certainly hoped so.

604 Q:

Okay. And that was your frame of mind at the time that you wrote this letter. Isn't that true?

605 A:

When I wrote this letter my frame of mind was stopping pain that I was feeling. Everything else was--everything else at the time, everything else was almost irrelevant to me. I just wanted to stop the way I was feeling.

606 Q:

Well, part of that pain could be alleviated if they identified the murderers or the murderer. Isn't that true?

607 A:

I don't know. I don't--that day I was feeling so much pain that I don't know what could have alleviated it.

608 Q:

Was it was on the 17th that you were feeling this pain?

609 A:

I was feeling it all week, but it came to a crescendo on the 17th.

610 Q:

Well, did something happen in particular on the 17th that brought it to a crescendo?

611 A:

I think that I was then arrested, yes.

612 Q:

Okay. So prior to the 17th did you have any occasion where you began to think about suicide?

613 A:

Maybe.

614 Q:

When did you first--when did it first cross your mind?

615 A:

I don't know if it ever crossed my I mind. I just know I wanted the pain to stop, and at that point on the 17th I wanted to be with Nicole, and that's what I attempted to do.

616 Q:

Well, when did you first think about doing anything affirmatively to stop the pain?

617 A:

I don't know. It was kind of a spontaneous thing. At just a moment I remember looking at A.C. I said,'Take me to Nicole's grave," and I don't know when at any point in any of that that anything ever became affirmative in my mind. If it had, I'd be dead right now. So I don't--I can't say that it ever got affirmative at any point, but I know I just wanted to stop the pain.

618 Q:

Well, you just mentioned that you looked at A.C. and said, 'Take me to Nicole's grave." Was that after you learned that you were going to be arrested?

619 A:

Yes.

620 Q:

And would it be fair to say that that was the first time that you decided to do anything affirmatively to stop the pain?

621 A:

It was the first time that I--yeah, I wanted to go to Nicole's grave, yes. I did want to do that.

622 Q:

Did you begin to draft the letter after you were advised that you were going to be, arrested?

623 A:

Yes.

624 Q:

Okay. So prior to that information - Strike--that. Prior to learning that information, you hadn't undertaken any effort to draft this letter. Is that true?

625 A:

That's correct.

626 Q:

You also said that you made some amendments or an amendment to your will. Is that correct?

627 A:

I believe so, yes.

628 Q:

Okay. And you don't recall what you changed or what you were going to after, if anything.?

629 A:

That's correct.

630 Q:

Do you recall whether any of those changes included making dispositions to the Goldmans?

631 A:

I know that didn't. I know that's wrong.

632 Q:

Any of those changes include dispositions to the Browns?

633 A:

No.

634 Q:

To your children.?

635 A:

I don't know. I think it just had to do with my family.

636 Q:

When you say your "family," you're talking about Sydney and Justin or Arnelle and Jason or

637 A:

Yeah, basically. My mother, my family.

638 Q:

Was there anything in there that stated anything about the Browns?

639 A:

I--in my will? I don't believe so.

640 Q:

Was there anything, whether it be a dispositive provision or not, just a statement

641 A:

I don't believe so.

642 Q:

--or comment

643 A:

I don't believe so.

644 Q:

Let me finish my question. whether it be a dispositive provision, whether there was a statement or comment mentioning the Browns?

645 A:

I don't believe so.

646 Q:

How the about the Goldmans?

647 A:

No, definitely not.

648 Q:

You're positive there is no mention in the amendment with respect to the Goldmans. Is that correct?

649 A:

Positive.

650 Q:

I want you to look at, if you would, Mr. Simpson. Exhibit 6, and in large part, as you've already indicated, this letter or this "To Whom It May Concern" letter was drafted because of the pain that you were experiencing from losing Nicole. Right?

651 MR. ROBERT BAKER:

Don't answer that. You've answered it six times.

652

BY MR. BREWER:

653 Q:

Prior to drafting this letter had you heard news reports about any marital discord between you and Nicole?

654 A:

Yes.

655 Q:

Okay. Do you recall any specific reports?

656 A:

No.

657 Q:

Do you recall what you were specifically told or what you heard."

658 A:

No.

659 Q:

Do you recall the general tenor of the reports?

660 A:

Negative, but, no, not anything specific to it other than that.

661 Q:

Well, when you say 'negative,' what do you mean by that?

662 A:

I know that it--I felt negative. I felt it was a negative report. I felt it was negative. It made me feel more pain.

663 Q:

Okay. Did the reports include claims that you had battered Nicole?

664 A:

I don't recall.

665 Q:

Did they include reports that you had beat Nicole?

666 A:

I don't recall.

667 Q:

Did they include reports that you had choked Nicole?

668 A:

I don't recall.

669 Q:

Do you recall any of the specifics as they relate to your relationship with Nicole that were being reported?

670 A:

Right at this day, I don't recall the specifics, but there was a lot of stuff, and I just don't recall the specifics.

671 Q:

Well, the first paragraph of this exhibit is really defending your relationship, isn't it?

672 MR. ROBERT BAKER:

Well. that's your characterization.

673

BY MR. BREWER:

674 Q:

Well, I am asking for your state of mind.

675 A:

I don't know

676 Q:

Isn't that what you were doing?

677 A:

As of the date, my state of mind then was to stop the pain or whatever the hell was going on in my life. I was in a lot of pain at the time, and, you know, I was just not the way I normally am.

678 Q:

Well, the first paragraph of Exhibit 6 relates to your explanation as to problems you had with Nicole. True?

679 A:

Let me read that.

[Witness reviews document.]

I don't think so. No, I don't agree with you there.

680 Q:

Well. You are describing a relationship that has ups and downs in the first paragraph, aren't you

681 A:

No. I think I'm describing a relationship that had come to a place where we were both comfortable with who we are and where we were, and we were going in our--on with our lives.

682 Q:

And in fact you indicate on the 10th line down that you mutually agreed to go--"We mutually agreed to go our separate ways." Do you see that?

683 A:

Yes.

684 Q:

Is that an accurate statement?

685 A:

I believe so.

686 Q:

And are you referencing the time frame of April-May 1994?

687 A:

No. I'm referencing--I'm doing either Mother's Day or the day after Mother's Day of May.

688 Q:

1994.

689 A:

Yes.

690 Q:

That's the time period that you're referring to?

691 A:

Well that's when we split and had no problems and were--you know, that's when we sat and talked and went our separate ways.

692 Q:

Okay. And the adjective that you used, "mutually" agreed

693 A:

Yeah.

694 Q:

--that's a fair characterization of how you

695 A:

Yeah, she was accepting of it. She was very accepting. She wouldn't go to therapy, so she was accepting of it. That was a choice she made.

696 Q:

When do you first recall reading any press articles that said anything about your relationship with Nicole in a negative context?

697 A:

Oh, months after all of this.

698 Q:

Months after the murders?

699 A:

Yes.

700 Q:

So during the week

701 A:

Maybe not months. Weeks after the murders.

702 Q:

Well, up until June 17, then, you didn't read any press reports that spoke negatively about you and Nicole? A:. No.

703 Q:

Is that true?

704 A:

That's true.

705 Q:

Were you anticipating then that there were going to be press reports subsequent to June 17, 1994 that portrayed your relationship with Nicole in a negative way?

706 A:

No. That was the tenor I got off TV, the reports that I heard on TV

707 Q:

Prior to June 17, 1994.

708 A:

That's correct.

709 Q:

Did you read anything that related to a negative relationship between you and Nicole?

710 A:

I didn't read anything.

711 Q:

Okay. I mean a press report, newspaper?

712 A:

I didn't read anything.

713 Q:

You didn't read anything at all that week?

714 A:

That's correct

715 Q:

You got all of your information from TV?

716 A:

That's correct.

717 Q:

Were there particular stations that you watched?

718 A:

I'm sure all of them.

719 Q:

You were just looking for information?

720 A:

Yes.

721 Q:

You wanted to obtain information relative to these murders?

722 A:

Yes.

723 Q:

Were you following the investigation?

724 A:

Only what I saw on TV when I was watching TV

725 Q:

Were you doing anything else to develop information relative to the investigation other than watching TV?

726 A:

At this time, no.

727 Q:

Were you continuing to contact the police department to determine the status of their investigation?

728 A:

I believe my lawyer was. I wasn't.

729 Q:

Did you personally contact the police department?

730 A:

No.

731 Q:

Let me finish my question. Did you personally contact the police department after June 13, 1994 in an effort to learn the status of the investigation?

732 A:

I think my lawyer was under my employment, and he was doing that. My concern was to bury Nicole and try to get through the week with My kids and deal with what I was trying to deal with there, the pain of it all.

733 Q:

The lawyer that you thought

734 A:

I wasn't in a place

735 Q:

I'm sorry.

736 A:

I wasn't in a place that first week to-- I had family to consider, and I had myself to consider, and I wasn't into an investigative mode that week.

737 Q:

Okay. So it would be--your state of mind was really one wanting to stay with the family and

738 A:

My state of mind was to get through the week and for Nicole to be buried and hopefully that my kids would be fine through it, which they which they were.

739 Q:

And that was your focus.

740 A:

That was my focus.

741 Q:

And that focus made it difficult for you to do anything else.

742 A:

It was tough. I mean, yeah, it was tough doing other things that week, Yes.

743 Q:

Okay. But you found time on the 14th to go down and get your golf clubs at the airport. Right?

744 A:

Yeah.

745 MR. ROBERT BAKER:

Don't-- okay.

746 O.J. SIMPSON:

No, I think that's wrong. Yeah, the 13th, was it? Was that the 13th?

747

BY MR. BREWER:

748 Q:

Was it the 13th?

749 A:

No. It may have been the 14th. Yes, that's correct.

750 Q:

You went down with Mr. Kardashian in his car to the airport to get your golf clubs. Right?

751 A:

That's correct.

752 Q:

And you weren't going to play golf that week, were you?

753 A:

No.

754 Q:

Okay. Were you in some need of having your golf clubs with you?

755 A:

I was in need to have something to do while I was waiting for my kids.

756 Q:

Okay. And so the thing that you chose to do was to go get your golf clubs at the airport?

757 A:

Because I was near it, yes. That's correct.

758 Q:

Did it help you at all deal with the pain associated with losing Nicole to drive down to the airport and get your golf clubs?

759 MR. ROBERT BAKER:

Don't answer that. That's argumentative.

760 MR. BREWER:

No, it's not. He's already said that

761 MR. ROBERT BAKER:

He is not going to answer it, so you can just save your speech.

762

BY MR. BREWER:

763 Q:

By the way, did you go anywhere else that day with Mr. Kardashian other than the airport to get your golf clubs?

764 A:

Yes.

765 Q:

Where else did you go?

766 A:

To my office, to Nicole's house, to his house.

767 Q:

Okay. And the visit to Nicole's house was really a drive-by visit because there was too much media there to stop. Is that true?

768 A:

That's correct.

769 Q:

And from there you went down to the airport to get your golf clubs. Right?

770 A:

No. From there he just drove, and at one point when we realized that A.C. was 40 or 50 minutes away and he said, "Where do you want to drive?" I said, "Just drive." And we were near the airport and I said, "You know, I have some bags at the airport or bag at the airport. Let's go by and get it," which we did.

771 Q:

Was there anything that you needed out of that bag?

772 MR. ROBERT BAKER:

Had you finished Mr. Simpson?

773 O.J. SIMPSON:

Huh?

774 MR. ROBERT BAKER:

Had you finished your answer?

775 O.J. SIMPSON:

Well, so it was a matter of killing time. It was a matter of just trying to do something while I was waiting for my kids to come, and not just to sit and look at the news. It was just a matter to occupy myself while my kids were coming, and we just happened to be in that--in the general vicinity, and my kids were still 40 or 50 minutes away.

776

BY MR. BREWER:

777 Q:

Okay. Is there anything that you needed out of your golf bag?

778 A:

Needed at that moment?

779 Q:

Sure.

780 A:

No.

781 Q:

On the top of the page of Exhibit 6, you indicate--you make the statement that "What's being said, most of it, totally made up." You see that?

782 A:

Yes.

783 Q:

What specifically are you talking about is made up?

784 A:

Well, as I told you, I can specifically remember the Avila story, and there were other things being said. and I can't specifically remember them. but there was numerous things being said. I'm sure all the people still have the video of their reports that we can go through it.

785 Q:

Well, I don't know--I want to know what you were thinking when you made that statement

786 A:

Just what I told you

787 Q:

--what were you--excuse me. What were you referencing when you said most of what's been said is totally made up?

788 A:

What I told you before: That in the reports they were saying various things. I don't recall all those things right now. I believe they may have had to do with Nicole's and my relationship, but various things were being reported, and it was negative--certainly had negative tones to it.

789 Q:

Well, when you say, "various things were being reported," what was being reported?

790 A:

I don't know how many times I have to tell you, I don't recall that week, but they--I'm sure they have tapes of all of that stuff. I don't recall what it was. I just know it was.

791 Q:

Okay. The reason why I'm asking you .

792 A:

I don't have a memory of this date ---as of this date what they were. It was so much stuff in this trial that's been negative, I don't recall what I learned after the 17th or before the 17th. I do know that during the course of that week it was painful to me, some of the things that were being said, and it all added to my state of mind that I was in. And we can go talk about the same thing over and over if you want, but that's--I don't remember anything specific other than Avila at this particular time.

793 Q:

That's the only thing you remember

794 MR. ROBERT BAKER:

Don't answer that. Don't answer that. He's asked it numerous--innumerable times.

795 MR. BREWER:

Well, I haven't asked that innumerable times.

[Discussion held off the record.]

THE VIDEOGRAPHER: This concludes the deposition of Orenthal James Simpson, Volume VII. The number of videotapes used was two. We are going off the record, and the time is approximately 4:40.

[ENDING TIME: 4:40 P.M.] Return to previous page.

Temperature

tense

Key Quotes (5)

O.J. Simpson
I knew that I hadn't deposited any blood at Nicole's house that night.
Simpson's clearest denial — framed as personal knowledge, not impossibility, leaving open the theoretical question of whether his blood could be there from another time.
Robert Baker
If you put blood drops there, they're not found, but go ahead.
Baker openly signals the defense's planted-evidence theory on the record during a deposition, an unusually aggressive sidebar comment.
O.J. Simpson
I wanted to be with Nicole, and that's what I attempted to do.
Simpson's direct admission that his suicidal crisis on June 17th was framed as wanting to reunite with Nicole — emotionally charged and legally double-edged.
O.J. Simpson
I didn't think about blood drops. I was thinking about Nicole, my kids and why was I handcuffed.
Simpson's explanation for not mentioning his cut finger to police — establishes his stated mental state at Rockingham on the morning of June 13th.
O.J. Simpson
It was a lie.
Unusually blunt response about Bob Avila's NBC report on his demeanor in Chicago — Simpson's clearest, most emphatic denial of any specific media claim in this session.

Evidence (4)

Exhibit 6
The 'To Whom It May Concern' letter, dated June 15, 1994 but confirmed by Simpson to have been written June 17, 1994
discussed, used to probe Simpson's mental state and knowledge of evidence at the time of writing
Informal
OJTELLS videotape — defense-produced property walkthrough of Rockingham, shot in December 1994
used as baseline for property-condition comparison questions throughout examination
Informal
Photographs showing numbered evidence cards marking blood drop locations in the Rockingham foyer and driveway
discussed; Simpson confirms he has seen them
Informal
Blood drops at Bundy crime scene alleged to match Simpson's DNA
discussed; Simpson says he cannot recall when he first heard this reported and denies depositing blood there

Notable Exchanges (4)

Michael BrewerO.J. Simpson
Brewer presses Simpson on why he never told police about his cut finger when an officer informed him blood was found on his property — Simpson says he wasn't thinking about blood drops at all in that moment.
strategic
Robert BakerMichael Brewer
Baker interjects unprompted: 'If you put blood drops there, they're not found' — explicitly stating the planted-evidence theory on the record in front of opposing counsel.
heated
Michael BrewerO.J. Simpson
Brewer asks Simpson whether he knew it was 'virtually impossible' for his blood to be at Bundy. Simpson carefully corrects the framing: he knew he hadn't deposited blood there 'that night,' not that it was impossible for his blood to ever have been there — leaving open a prior-incident window.
revealing
Michael BrewerO.J. Simpson
Simpson volunteers a memory of bleeding at Bundy on a prior occasion — Nicole accidentally closing a car door on his hand, with Sydney retrieving a Flintstones Band-Aid — while denying he was dripping blood up the walkway.
revealing

Light Moments (2)

O.J. Simpson
When asked to describe the mystery detective beyond 'has a mustache,' Simpson says: 'I don't really study guys.'
Robert Baker
Baker interjects on the nighttime lighting questions to note it was December when the videotape was shot, so Christmas lights account for some differences from June.

Credibility Attacks (2)

⚔ O.J. Simpson
omission / failure to offer exculpatory explanation
Brewer establishes that when police told Simpson blood was found at Rockingham, Simpson — despite having cut his finger the night before — said nothing about it, asked no questions about the blood, and offered no explanation. Brewer uses this silence to imply consciousness of guilt.
⚔ O.J. Simpson
prior inconsistent framing
Brewer gets Simpson to say he 'knew it was impossible' for his blood to be at Bundy, then Simpson walks it back to 'I knew I didn't deposit blood there that night' — leaving open prior-occasion contamination, which Brewer then exploits by eliciting the car-door / Band-Aid memory.

Witness Demeanor

[indicating] — Simpson points to his left pinkie finger while describing Nicole closing a car door on his hand

Objections

9 objections (0 sustained, 0 overruled)
Proceeding 9044 • 795 utterances • Plaintiff witness
Deposition Trial
Department 103
⚖️ Start
📂 FEB 23, 1996 📄 Direct examination of O.J. Sim
FEB 23, 1996 KRT DvH TD