Cross-examination of Arnelle Simpson

📄 Cross-examination of Arnelle Simpson — Wednesday, July 6, 1994

Address:

C:\DEPT103\PRELIMINARY\1994\JUL\6\CROSS-EXAMINATION-OF-ARNELLE-S.DOC

TRIAL

▲ Day 4 of 6

◀ Direct examination of Arnelle Simpson Direct examination of Cathy Randa ▶

Witness: Arnelle Simpson
Examiner: Marcia Clark
Called by: Defense • Date: Wednesday, July 6, 1994 • Lines: 118

Marcia Clark reconstructed Arnelle Simpson's movements on June 12, including her return to Rockingham around 1:00 a.m., where she parked, and what she told police when they arrived. Clark also explored Simpson's limited memory of questions about the maid's room and established that she was tired, confused, and frazzled after only about four hours of sleep.

# 1

CROSS-EXAMINATION

# 2

BY MS. CLARK:

# 3 Q:

Good afternoon, Miss Simpson. On the night of June the 12th, did you go out at some point that night?

# 4 A:

Yes.

# 5 Q:

Were you staying full time at the Rockingham residence at that time?

# 6 A:

Yes, I was.

# 7 Q:

What time did you go out?

# 8 A:

I had been out all day. I had left, oh, at around 10:30 and had returned at around 1.

KEY QUOTE

# 9 Q:

You left at 10:30 in the morning?

# 10 A:

Yes.

# 11 Q:

And you got back at 1 in the morning?

# 12 A:

Yes.

# 13 Q:

And you had not been back in the house that entire time?

# 14 A:

Yes, I had.

# 15 Q:

When?

# 16 A:

At around 11:30.

# 17 Q:

In the morning or at night?

# 18 A:

Morning.

# 19 Q:

And you came back at 11:30 for what purpose?

# 20 A:

I had gone to church, and I came home to change.

# 21 Q:

OKAY. And you changed clothes and left again?

# 22 A:

Yeah.

# 23 Q:

At what time?

# 24 A:

At around 12:30.

# 25 Q:

And then did you come back to the house again between 12:30 p.m. and 1 a.m.?

# 26 A:

No, I did not.

# 27 Q:

So you were out that entire time?

# 28 A:

Yes.

# 29 Q:

You drive a black Saab?

# 30 A:

Yes.

# 31 Q:

When you came home at 1 in the morning -- did you drive that day when you went out?

# 32 A:

Yes, I did.

# 33 Q:

And when you came back, did you park it in the driveway?

# 34 A:

Yes, I did.

# 35 Q:

Where did you park it?

# 36 A:

Right here.

# 37 Q:

You are showing us on the defense diagram?

# 38 A:

Yes.

# 39 Q:

And you pointed to the area that -- just below that area is written "driveway" on the Rockingham side of the residence?

# 40 A:

Yes.

# 41 Q:

Now, when the officers first came to your door, they asked you where your father was; is that right?

# 42 A:

Yes.

# 43 Q:

And you indicated to them, "I believe he is out of town"?

# 44 A:

Yes.

# 45 Q:

You were unsure then?

# 46 A:

No.

# 47 Q:

You told them, "I believe he is out of town"?

# 48 A:

"I believe he is out of town." I knew he was gone, but I just didn't know where he was out of town.

KEY QUOTE

# 49 Q:

Did you know when he had left?

# 50 A:

Yes, I did.

# 51 Q:

Did you tell them that?

# 52 A:

No, I did not.

# 53 Q:

Did you know when he was due back?

# 54 A:

No, I did not.

# 55 Q:

Did you know where he was staying?

# 56 A:

No, I did not.

# 57 Q:

And when they were asking you about your father's whereabouts, you were, I assume, concerned?

# 58 A:

Yes, I was.

# 59 Q:

And so you wanted to, I assume, find out where he was?

# 60 A:

Yes.

# 61 Q:

And so you let the officers in so you could find that out and perhaps get their help, if needed, right?

# 62 A:

Yes.

# 63 Q:

And in order to do that, you had to disarm the alarm because it was set?

# 64 A:

Yes.

# 65 Q:

When you went into the house, were there any lights on in the house?

# 66 A:

I don't recall.

# 67 Q:

And the officers asked you to show them where the maid's room was?

# 68 A:

I don't recall that.

# 69 Q:

Do you recall them asking you about the maid when they came in?

# 70 A:

Yes.

# 71 Q:

Do you recall them asking whether she was all right or where she stayed, in what room she slept?

# 72 A:

No.

# 73 Q:

Do you recall showing them where she slept?

# 74 A:

No.

# 75 Q:

Is it you don't recall; it might have happened, but you no longer remember?

# 76 A:

I don't recall doing that, no.

KEY QUOTE

# 77 Q:

Is it a fact that the maid's bedroom is off the kitchen?

# 78 A:

Yes.

# 79 Q:

And do you recall the officers asking you whether that bedroom was the maid's room?

# 80 A:

No.

# 81 Q:

You don't remember anything about that?

# 82 A:

No.

# 83 Q:

Do you recall telling the officers that you had been out all night at the movies and you just got back about 1 a.m.?

# 84 A:

Yes.

# 85 Q:

Now, you said that you explained to the officers that the maid has weekends off?

# 86 A:

Yes.

# 87 Q:

Was that when you were in the house when they were asking you about where the maid was?

# 88 A:

No. That's -- when I was walking from my room, inside the house, they had asked me, "does anybody else live here?"

# 89 Q:

And you said, "yes. The maid does"?

# 90 A:

Yes.

# 91 Q:

And when you got into the house, did they ask where she was at that time?

# 92 A:

No. They asked me outside. They had said, "does anybody live here?" I said "yes." They said "who?" I said "gigi." They asked me, "is she here?" And I said "no."

# 93 Q:

Were you in the house at that point?

# 94 A:

No.

# 95 Q:

You were on your way into the house?

# 96 A:

Yes.

# 97 Q:

You went to pick up the children at the police station?

# 98 A:

Yes.

# 99 Q:

How far away was that from the Rockingham address?

# 100 A:

Hmm. We live in Brentwood; so -- it was in Santa Monica. Maybe four miles away.

# 101 Q:

Four miles?

# 102 A:

Yeah. I am estimating. I don't know really how far it is.

# 103 Q:

What time did you finally go to sleep the night before? You got home at 1 a.m. on June 13. What time did you go to sleep?

# 104 A:

Maybe around 1:30.

# 105 Q:

And they woke you up just four hours later?

# 106 A:

Yeah.

# 107 Q:

Were you a little bit tired when they woke you up?

# 108 A:

Yeah.

# 109 Q:

Were you a little bit confused, seeing police officers at your door?

KEY QUOTE

# 110 A:

Yes.

# 111 Q:

Feel a little bit frazzled at seeing them and hearing what might be bad news?

# 112 A:

Yeah.

# 113 Q:

Before you heard it?

# 114 A:

Yeah.

# 115 MS. CLARK:

Thank you. I have nothing further.

# 116 THE COURT:

Mr. Uelmen, anything further?

# 117 MR. UELMEN:

Nothing further, your Honor.

# 118 THE COURT:

Thank you, Miss Simpson. You may step down. Please do not discuss your testimony with anyone.

Temperature

routine

Key Quotes (4)

Arnelle Simpson

I had been out all day. I had left, oh, at around 10:30 and had returned at around 1.

Simpson accounted for most of June 12 and placed her return to Rockingham at about 1:00 a.m.

Arnelle Simpson

"I believe he is out of town." I knew he was gone, but I just didn't know where he was out of town.

She explained why her statement to police sounded uncertain even though she believed her father had left town.

Arnelle Simpson

I don't recall doing that, no.

Her inability to remember showing officers the maid's room became a central memory issue during the cross-examination.

Marcia Clark

Were you a little bit confused, seeing police officers at your door?

Clark elicited circumstances suggesting Simpson was disoriented when police questioned her early that morning.

Evidence (1)

Informal

A defense diagram of the Rockingham residence and driveway, on which Simpson indicated where she parked her black Saab.

displayed and discussed

Notable Exchanges (4)

Marcia Clark•Arnelle Simpson

Clark carefully reconstructed Simpson's movements on June 12, clarifying that she briefly returned from church in the morning, left again around 12:30 p.m., and did not return until about 1:00 a.m.

methodical

Marcia Clark•Arnelle Simpson

Clark pressed Simpson about her statement that she believed her father was out of town. Simpson said she knew he was gone but did not know his destination, when he would return, or where he was staying.

revealing

Marcia Clark•Arnelle Simpson

Simpson remembered discussing the maid with officers but repeatedly denied recalling any request to identify or show them the maid's bedroom.

strategic

Marcia Clark•Arnelle Simpson

Clark ended by establishing that Simpson had slept only about four hours and was tired, confused, and frazzled when officers arrived.

strategic

Credibility Attacks (2)

⚔ Arnelle Simpson

memory challenge

Clark repeatedly tested Simpson's memory about whether officers asked about or were shown the maid's bedroom; Simpson repeatedly answered that she did not recall.

⚔ Arnelle Simpson

capacity and recollection challenge

Clark established that Simpson had slept only about four hours and felt tired, confused, and frazzled when police arrived, suggesting her early-morning perceptions and recollection may have been impaired.

Objections

None recorded

Proceeding 9128 • 118 lines • Defense witness

Preliminary Trial

Department 103