Okay. And you did not question her because you believed that she was telling you the truth; correct?
Argumentative and same objections.
HE WITNESS: I was concerned about her well-being.
And he was wrong because as you testified earlier you felt it was wrong for a men to hit a woman; true.
So what Mr. Simpson did in connection with this '89 incident ran counter to what you believed was right v vis how a man should treat a woman; true?
And as a result of this incident you said that you thought that Mr. Simpson was wrong, but did that change the nature of your relationship, that you were not as friendly with him, you didn't see him as often, anything of that nature?
No. We cared about each other. I still had my great love. I just stopped going around because they were getting back together, it seemed like, and they had things, you know, to work out.
The less frequent visits to Rockingham with Nicole and Mr. Simpson, was that because of a change in your - feeling about Mr. Simpson or that you wanted to give them an opportunity to kind of sort out own problems?
I felt bad for both of them, and I felt that they needed time to sort it out, whatever differences that they were having.
And when you state Strike that.
When you made the sacrifice not to go to the Rose Bowl that evening in order to be available for Nicole, Mr. Simpson went to the Rose Bowl?
I was planning on going. I have been to Rose Bowls before. I mean, one Rose Bowls like any other. It was no major thing that I had to go.
Would it be a fair statement to say that had this incident not occurred you probably would have gone to the Rose Bowl that evening?
And the principal reason why you did not go was because you wanted to be available for Nicole; true?
Did you think that it wasn't right given what had happened earlier that day that Mr. Simpson was at the Rose Bowl when his wife was at home with hat you have described as a
She didn't want to be bothered with him. And I guess the best thing for him to do was to be out of her sight, so instead of sitting there where he was all day, he chose to go to the Rose Bowl.
And so would it been a fair statement, then, other than this short period where you were staying away so that they could sort through the problems relative to the '89 incident, that your overall relationship with Mr. Simpson had not changed at all as a result of the '89 incident?
It hadn't changed. I thought that the two themHe didn't hit me. Nicole forgave him. They went on with their lives.
Okay. And is there anything that you observed about their relationship that was different that you attributed to the '89 incident?
So you didn't knowWhen you were around then and you made observations with respect to how they interacted together, you did not notice any major differences after the '89 incident that you attributed to that incident?
So after the incident occurred as far as you could tell when you were around then, you were never present where it was referred to or talked about in your presence; is that true?
Going back to your earlier statement that, you know, you may have had these feelings that Mr. Simpson was responsible early on, what was the basis for that statement?
And do you remember specifically what you heard that triggered a thought process that led you to conclude that Mr. Simpson may be responsible for Nicole's death?
Okay. That's a good point. When you say the thought was on your mind, it was something that you thought was in the realm of possible explanations relative to her death?
I don't know whet I learned. There was a lot of stuff coming out.
Was there anything that stuck in your mind as being a significant piece of information that started the thought process going relative to your belief that Mr. Simpson may be responsible for the death of Nicole and Ron Goldman?
So there is nothing in particular, it is just the combination of all of the information, nothing that you remember specifically thinking about?
Did you also tell Cici that you thought that Mr. Simpson may have been responsible for Nicole's death?
Did you also make the statement to Robin hat you thought that Mr. Simpson may be responsible for Nicole's death but had since changed your mind?
Other than Cora Fischman is there anyone else that you have told about a belief that you thought Mr. Simpson at some point may have been responsible for Nicole's death?
Objection. I think that that mischaracterizes his testimony when you use the word "belief."
In discussions with Nicole's friends have any of them asked you whether you thought Mr. Simpson killed Nicole?
Okay. And that is what prompted the discussion that we have been talking about for the past couple of minutes, her asking you about your belief with respect to whether he killed Nicole?
Well, we are talking about a belief that you had or at least you thought it was a possibility that Mr. Simpson may have killed Nicole at some point; is that true?
Now, in your discussions with Mr. Simpson's close friends, have any of those friends ever asked you whether you thought he did it?
Allen Austin? Any of people that you and Mr. Simpson had as common friends, have any of them at any point ever asked you, excluding this time period that is privileged, whether or not you thought Mr. Simpson killed Nicole?
Have you had any discussions with any of the friends that were at the meeting with Mr. Shapiro regarding a knife that may have been used in connection with the murders?
No.
Have you had any discussion with that same group of people with respect to clothing that Mr. Simpson may have been wearing at the time that the murders
Is the question: Did you have discussions at this group meeting? Is that what the question is?
No. At any time, excluding the relevant time period where there is a privileged being asserted.
The people that were identified that he remembers being at this meeting with Mr. Shapiro, excluding the time period that you are asserting privilege, have you ever had a discussion with any of those individuals relative to the location of any clothes that Mr. Simpson may have been wearing at the time of the murders?
R.LEONARD: Objection. Vague, lack of foundation, compound, and calls for speculation.
The other thing is if you are asking if he had any conversation with anybody at any time regarding clothes that Simpson may or may not have been wearing, he would have asserted a privilege to that independent of the time period.
In other words, if you are talking about potential evidence in the case, did he ever talk to any of these people about Simpson's clothes, he would assert a privilege to that regardless of the time period.
R.BREWER: You know, I am not going to belabor this. I just want to make sure I understand the point so I do not waste our time here.
there was just a discussion with Mr. Cowlings concerning conversations he had with her with respect to the location of a knife, clothes that he may have been wearing, et cetera.
That is not what he said.
R.BREWER: But he was asked about discussions with her wherein he said this to her at the deposition.
R.RE: But he said that never happened. So what I am saying to you is, you are asking him now was there an event where he spoke to somebody about that evidence, and I am telling you that he will assert the privilege to this. The other question was did you say this to Jennifer Peace, and he said no, I never said that to Jennifer Peace. There is no privilege to that.
How about a question, did you tell Allen AustinDid you have any discussions with Allen Austin with respect to the location of evidence, a question like that?
I am not saying it is a joke. I am talking about the privilege. It is only the question I am concerned about.
The reason we let him go ahead with regard to Jennifer Peace is because that is one of the areas that he said at the very beginning of the deposition he wanted to clear up and testify about. When we are talking about anybody else, asking anybody in general or in specific did you talk about the evidence in the case, he is going to assert a privilege to that.
On the morning of the 12th you were called to Rockingham by Arnelle, and when you got to Rockingham did you notice whether anyone who was theresorrythe 13th, the police officers, Arnelle, Kato, anyone had any cuts or was bleeding at any time?
Do you have any information about a book that is being written by Larry Schiller concerning the events of June 13 end June 12, 1994?
No.
R.LEONARD:I am going to object. That is lack of foundation, vague, "any information."
THEWITNESS:I have no knowledge of that.
Have you heard that Robert Kardashian is in the process of providing information or collaborating with Mr. Schiller in connection with a proposed book?
Just so that I am clear, the conversation that I am referring to is the one that refers to him doing a book with Larry Schiller.
Objection. Vague, and I think that mischaracterizes his testimony.
THEWITNESS: It could have came up after the trial.
BYMR.BREWER:
And did Mr. Kardashian tell you that he was interested in doing a book since everyone was doing books?
I don't know if somebody was showing interest in him or he was showing interest in doing a book. I really don't know.
And did he indicate that he was collaborating with Larry Schiller in connection with a book?
Did he tell you what information, if any, he had provided to Mr. Schiller? MR. LEONARD: Same objections.
SO the only thing that he said to you concerning this book was the fact that he was doing a book collaboration with Mr. Schiller?
Did he tell you anything about, you know, what information was going to be accumulated that would go into the book?
Objection. I think you already asked that at least once. Lack of foundation, calls for speculation.
No.
BY MR. BREWER: Q: Did he tell you about anyone that had been interviewed with a view towards providing information for the book?
Did he indicate to you that there were going to be any disclosures of privileged or private information in the book?
Objection. calls for speculation, lack of foundation, calls for a legal conclusion.
Did Mr. Kardashian indicate at that time that they had a manuscript that had been completed?
Did he indicate to you that they were at least in the process of putting a manuscript together?
With respect to this Kardashian manuscript, have you ever seen a manuscript in connection with this book?
And when I say "a manuscript," I am talking about either a completed one or portions thereof.
Did he tell you whether he was Strike that. Did he tell you whether he had entered into any contractual relationship with a publisher in connection with this book?
Was there any discussion about how much he had been paid or expected to be paid in connection with the book?
Mr. Simpson, based upon your knowledge of him, is a very verbal person; is that a fair statement?
And, for example, if you have a conversation with him, the tendency is for him to typically spend most of the time in that conversation doing the talking; is that true?
Have you ever been around Mr. Simpson where you have known that he is angry or upset about something and he has become very quiet and introverted
I have seen him sometimes when he was quiet, when he is being bothered by something.
And he tends to be a more reflective or introverted based upon what you are able to see of him when he is en' or upset?
Objection. Calls for speculation, argumentative, lack of foundation, misstates his prior testimony.
Are there any particular occasions that stand out in your memory where you have been around Mr. Simpson and you have known that he is angry about something where he has been quiet or reflective?
Unless he tells me. Sometimes I am around and he is tired. Maybe he is just coming off the road or he has been working too hard.
And as a good friend sometimes you are around him and he will be quiet and you will say "what is going on" to find out why he has been quiet?
Sometimes if, you know, some people don't want to be bothered, and you just don't bother them.
Has that ever happened where he has been unusually quiet, and you have asked him "What is going on? What is the matter?"
And would you say that most of the time when you are around Mr. Simpson if he is not being bothered or he is not upset about something, he tends to be a very verbal person, talking and gregarious type of person?
If you were asked to describe a personality trait, would you describe that as one of Mr. Simpson's personality traits, that he tends to be a very talkative and verbal person?
Now, going back to this New York incident after the Louis Marx party, which may or may not be r63 related to their anniversary when you received a call from Mr. Simpson, were you in bed at the time that you received the call?
And when he called you, the word that you said was that he seemed upset. Did he seem angry when 1121 he contacted you?
Okay. Well ,upset could mean crying, could mean quiet, could mean yelling, boisterous. Can you help us figure out how he was upset when he contacted you that evening?
For him to call me at that time I figured, you know, something was wrong.
141 BY MR. BREWER:
Okay. So it was based upon the timing of the call that led you to believe that he was upset about something?
And he essentially told you that he needed you to come over to the suite where they were 1141 staying; is that correct?
And you knew that there was a problem as a result of that call and being summoned over to their suite; true?
Well, did you expect that you were going over there to socialize, to have a drink and just talk?
Prior to receiving that call, in your experience with Nicole and Mr. Simpson, had you ever been called upon to mediate disputes between them;
Had you ever been called upon to provide an objective or third
Let's change the tape.
THE VIDEOGRAPHER: This is the end of tape number two of Volume IV. The time is approximately 1:23, and we are off the record.
Mr. Cowlings, I think before we had to go off the record I asked you whether you had ever been called upon by Mr. Simpson and Nicole to provide like, a third-party view of things or to be an objective observer of something that was going on in their relationship or a mediator or something of that sort. Has that ever happened
prior to this? So this was the first time that you had ever been called upon by the Simpsons to sort out a dispute that they were in?
His reason for calling me, I couldn't tell you exactly what his reasons were. I went there. He said she had embarrassed him, and she 1 said I was sorry, that I didn't mean to embarrass you, and that was it.
Were you asked to provide an opinion, like whether or not this was something that would be embarrassing to you?
I am going to object to the extent that you are asking him to speculate, when you say he was there to listen.
I am just asking what your understanding was with respect to why you were there, what you were to do.
So the first thing Mr. Simpson said to you was, "This is what she said that embarrassed me this evening"?
And did Mr. Simpson ask you something like, "Do you think that is embarrassing?" Or "Is that something that would embarrass you?" Or something of that nature?
I don't remember any too much more because I didn'tYou know, after she apologized or whatever, the conversation was over.
Would it be a fair statement that that wasWould it be a fair description of that whole episode, that that was a relatively bizarre episode?
A friend called. He needed me. I went. All right. I got there. She said something, something. She said, "I apologize." There was no more said after that. I turned around and went back to my hotel.
KEY QUOTEBy the way, just so the record is clear, you never observed any markings on her either that evening or the following day on her face or any part of her body?
The thing that Mr. Re has just pointed out to us on his electronic calendar is that January New Year's day would have been Sunday. Correct?
Are we back to that. I don't know, man. All I know is that the Rose Bowl is played on the 1st. Now, if that year it was played on the 2nd, your guess is as good as mine. I don't know. All I know, playing in the Rose Bowl myself, it is always played on the 1st. It may have changed. I really don't know.
Let's do it this way. The one thing that you are positive of is that the Rose Bowl was the same eveningplayed the same evening as the episode that we have described involving Mr. Simpson and Nicole?
New Year's we're at a party. New Year's morning I was called. There was a problem at the house. I went. The Rose Bowl, I assume, was played that afternoon.
I want to just focus on what you said. You said I assume" it was played. Do you have a specific memory that it was on the same date as the altercation?
The only reason I am saying this is because you guys are bringing up the 2nd and 1st. That is the only reason. Normally, up until this point, as far as I was concerned or knew, the game was played on the 1st.
Me too. And I just want to make sure we are clear on this. Irrespective of the date, whether it is the 1st or the 2nd, the Rose Bowl
Why don't we get a press guide from USC or something that says that the game was played then or call over there.
Okay. Let me ask it this way, because this will help figure it out. You don't understand. I don't care about the date. I just want to make sure
Ask eitherLet me se. It could beIf it was on the 1st, it would be 1980 1990. Do you understand what I am saying?
Hold on. Let me explain something. Let me explain My last year at SC we played in the Rose Bowl. That was in '69, but it was the 1970 Rose Bowl.
Just general information. They will probably give you You could ask for the athletic department.
Let me just ask a question so that we can clear this upclean it up, and then close out the deposition.
Forget about the date, whether it is
the 1st or 2nd.
The only thing I am concerned about is you were summoned over to Rockingham that morning by Michelle; true?
And the Rose Bowl that we are talking about would have been the same evening, you would have one to the Rose Bowl that evening?
No, I didn't.
0: Did you ever have any conversations with 1221 Mr. Simpson excluding the time period regarding Ron Goldman?
Prior to Nicole's death had you ever been
Page 1090
with Mr. Simpson where he pointed out someone that you later learned to be Ron Goldman?
Did Mr. Simpson ever say anything to you about Nicole dada" a waiter who worked at the Mezzaluna restaurant? And again, this is prior to
Nicole's death.
And, Mr. Re, just so that I am clear, I think you have already stated this, but in terms of discussions between Mr. Cowlings and Mr. Simpson, any conversations are going to be privileged?
I guess what we don't know right now isand I am certainly not suggesting it but we don't know whether Dan has any more.
Let's go off the record.
THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 1:35.
Given that information, the fact that the Rose Bowl was on the 2nd and not, in fact, on the 1st, does that in and of itself refresh your recollection with respect to what you did or didn't do on the evening of the 1st?
And if we are correct end the Rose Bowl was on the 2nd, that means that on the 1st where we thought he was at the Rose Bowl he was somewhere else; true?
: Probably, yes.
Objection. Lack of foundation.
THEWITNESS:I saw him in and out that day because I eventually brought him back up to the house that evening.
BYMR.BREWER:
Okay. Do you know from any source whether he had left and gone anywhere else after you left to take Nicole to the hospital?
Do you remember how long you stayed with Nicole after your return from the hospital at Rockingham?
Probably from Alan Schwartz.
Q And when you dropped him off, was that the last time that you saw him that evening, was after you dropped him off at Rockingham?
We talked. I suggested to take her in and he said yesto the hospital.
Q Was Howard Weitzman there at the time?
Objection. Lack of foundation, calls for speculation.
THEW1TNESS: What day? BYMR.BREWER: Q: On the 1st.
At any time, by the way. My question is open to at any time on the 1st do you recall seeing Howard Weitzman at Rockingham?
Any time on the 1st?
Yes. A: Not that I remember.
Do you recall or do you have any knowledge with respect to whether Mr. Simpson spoke with Howard Weitzman on the 1st?
Objection. Lack of foundation, calls for speculation, compound.
HEWITNESS:I have no knowledge of that.
YMR.BREWER:
Same question with respect to Skip Taft. do you have any knowledge with respect to whether Mr. Simpson spoke by telephone with Skip Taft?
I don't remember seeing Howard. BY MR. BREWER:
And after you left Rockingham you took Nicole to the hospital that evening; correct?
Let's focus on those two time periods. When you left Rockingham with Nicole to take her to the hospital, do you know where O.J. Simpson was?
I couldn't tell you how long I stayed.
: Do you remember leaving Rockingham that evening and going back home?
Yeah, I went home.
And when you left Rockingham that evening, do you recall specifically with respect to whether Mr. Simpson was at Rockingham' :I don't remember. Q: So you have no memory of Mr. Simpson's whereabouts after you left Rockingham to go to the hospital; is that true?
After you left Rockingham to take Nicole to the hospital you have no recollection with respect to seeing Mr. Simpson or knowing his whereabouts?
I don't know if he stayed there. I don't know if he was still there when I got back. I don't remember.
And when you say you don't remember, you do not remember seeing him; true?
:I just don't remember if he was still there when I got back.
You do not remember reporting to him with respect to what happened at the hospital, what the m doctor said? A: I don't remember.
Yes. I am just focusing on that evening.
THEWITNESS:I don't remember. 1131 BY MR. BREWER:
When you say you could have, does that sound like something that you would have done, to call 1221 him end check on her
Do you have a recollection of any discussions that you had with Mr. Simpson the day after the incident occurred?
Assuming that is the date of the Rose Bowl, and we think it is, do you remember whether you saw Mr. Simpson before he went to the Rose Bowl that year?
Since you mention this, there is a thought in my mind right now that I probably went to the Rose Bowl if it was on the 2nd.
BYMR.BREWER:
KEY QUOTEWhen you brought up Jason, some
thing in my mind clicked that Jason came up to me while I was on the side lines.
So is now your best recollection that you were probably at the Rose Bowl that year?
: Yes. Something is telling mein my mind is telling me that I was there.
And were you there with O.J. Simpson that year?
So to the best of your knowledge as you e41 sit here today you just remember you and Mr. Simpson?
Do you remember the individual on Exhibit 07?
r41 A: He could have been.
Do you remember there being kind of a pregame party or event that you went to and then went m from there to the Rose Bowl?
I don't remember. There is always a pregame thing. I don't know if we were in time to go into the hospitality tent, as they called them, or did we get there just before the game started. I really don't remember.
Because you are scalums, is there specialthere is obviously special treatment anyway, but is there a particular event that is held for former SC football players that attend the Rose Bowl?
I don't know. It is just in general there is various support groups that have their own tents. The network could have had their tents up. O.J. could have been invited by the networks to come down. I don't know who covered the game that year.
When you say he could have been invited by the networks, you are talking about going up and maybe doing some commentary or just giving an interview?
I see. Do you recall giving any interviews that year?
Me? Q:Yes. : Not How about Mr. Simpson, do you recall seeing him being interviewed
by anyone while you were at the game?
Do you recall any discussion that you had at the Rose Bowl relative to the events the preceding day?
: No, I don't remember.
: Do you remember where you went after the game?
I remember coming back to Rockingham or I could have went back to Wayne's or I could have went home. I really don't know.
No, I don't remember.
Do you have a memory after the Rose Bowl on the 2nd of talking to Nicole by telephone?
Other than the hospital is it on the 1st, did you ever take Nicole for any follow-up medical visits
And that is the only occasion that you have ever had to take her to the hospital for any reason?
I'm trying to get the cobwebs out. I remember going to the hospital with her when she was giving birth.
Apart from giving birth, this is the only time because of an injury that you ever had to take her to the hospital?
Apart from this hospital visit during the '89 incident, do you recall any other incidents that you had to take her to the hospital for?
How about where you accompanied Mr. Simpson when he took her to the hospital as a result of some injury, do you recall that?
No.
: Other than the arguments and the physical altercation that we have talked about, do you recall any other fight or argument that we have not discussed during the course of the deposition?
Can we have the stipulation that the original will be sent to you, Mr. Re, on behalf of Mr. Cowlings; you will have 30 days from your receipt in which to inform us of any changes and whether it has been signed; and if not so informed, that a certified copy can be used in lieu of an original for all purposes; the court reporter is otherwise relieved of his and her statutory dudes.
Yes.
THE VIDEOGRAPHER: This concludes the deposition of Allen Cowlings, Volume IV. The number of videotapes used was three. We are going off the record, and the time is approximately 1:51.
He didn't hit me. Nicole forgave him. They went on with their lives.
A friend called. He needed me. I went.
Yes. Shut up.
I am just a dumb football player.
Since you mention this, there is a thought in my mind right now that I probably went to the Rose Bowl if it was on the 2nd.