AC Cowlings Deposition of April 16

THE VIDEOGRAPHER: Good morning. Here begins videotape No. 1 in the deposition of Allen Cowlings in the consolidated cases of Fredric Goldman, Sharon Rufo and Louis Brown vs. Orenthal James Simpson in the Superior Court, State of California, County of Los Angeles, the lead case number of which is SC 031947.

Today's date is Tuesday, April 16th, 1996. The time is approximately 9:40. This deposition is being taken at 11377 West Olympic Boulevard in Los Angeles, California, and was made at the request of plaintiff of the Law Offices of Mitchell, Silberberg & Knupp.

The videographer is Rod Rigole, employed by Coleman, Haas, Martin & Schwab of Los Angeles, California.

Would counsel please identify yourselves and state whom you represent.

MR. KELLY: John Kelly for the Estate of Nicole Brown Simpson.

MS. ROIT: Natasha Roit for the Estate of Nicole Brown Simpson.

MR. BREWER: Michael Brewer for Plaintiff Sharon Rufo.

MR. BLASTER: Robert Blasier for Mr. Simpson.

MR. LEONARD: Daniel Leonard for O.J. Simpson,

MR. PETROCELLI: Daniel Petrocelli for Plaintiff Fredric Goldman.

MR. RE: Donald Re for Allen Cowlings, the witness.

ALLEN COWLINGS, having been first duly sworn, was examined and testified as follows:

EXAMINATION BY MR. KELLY:

Q: Good morning, Mr. Cowlings.

A: Good morning.

Q: My name is John Kelly, and I represent Nicole's estate. If I ask you any questions you do not understand or you want me to rephrase, just let me know and we will take care of that.

Secondly, if there is any time you want to take a break or you want to talk to your attorney, Mr. Re, let me know and we will accommodate you with that also.

You have to speak up a little bit.

A: Yes.

Q: Okay. Do you understand that you are under oath here today?

A: Yes.

Q: Okay. Have you ever given sworn testimony in a deposition before?

A: Yes, I have.

Q: And when was that?

A: I guess maybe about a year, year and a half ago. No, it was probably a year ago.

Q: Okay. And what type of case was that?

A: It was a lawsuit.

Q: What type of lawsuit?

A: Guy was trying to sue me for not selling him my car.

Q: Okay. So this was someone who was suing you?

A: Right.

Q: For money?

A: Uh-huh. Well, the car, actually, he was trying to sue me for.

Q: Okay. And you gave a sworn deposition during that?

A: Yes, I did, uh-huh.

Q: Okay. And what was the name of the person who was suing you?

A: I have no idea. He was out of Minnesota. It was pertaining to my truck. Basically that was it. It was all a surprise to me when it happened, and it ended up in my favor, so...

Q: Okay. And you told the truth during your deposition?

A: Yes, I did.

Q: Okay. Did that matter ever go to trial?

A: Yeah, it went to trial.

Q: Went to trial also?

A: Yeah.

Q: Did you testify at trial?

A: Yes.

Q: Okay. And you told the truth during your deposition?

A: Yes, I did.

Q: You told the truth during the trial?

A: Yes, I did.

Q: Okay. When was the last time you spoke to Mr. Simpson? Prior to coming here today, when was the last time you spoke to him?

A: I spoke with him Sunday.

Q: Okay. And did you discuss any of the deposition testimony he had given when he had been here for that 10-day period?

A: No, huh-uh.

Q: Have you ever discussed any of the testimony he gave here during this deposition?

A: No.

Q: Could you tell me how many times you've seen Mr. Simpson since he gave his deposition here?

MR.LEONARD: Objection. Lack of foundation.

BY MR. KELLY:

Q: Mr. Cowlings, when one of these gentlemen object, we will let them state their objection, but you will still have to answer the question.

A: I don't know. Maybe a handful of times.

Q: More than six?

A: Maybe a handful of times. I don't have a definite number.

Q: Okay. Approximately five, six times?

A: Something like that.

Q: And you never discussed his testimony -

A: No.

Q: - here?

A: No.

Q: Did you ever discuss anything relating to the murders of Nicole Brown Simpson or Ron Goldman when you saw him that handful of times?

A: No.

Q: Nothing?

A: No.

Q: Did you ever discuss Nicole Brown Simpson with him at all?

A: Yes.

Q: Could you tell me when you discussed that?

A: Well, things come up when I'm at the house, and the house reminds me a lot of Nicole, and it bothers me.

Q: That she's dead?

A: Yes.

Q: Okay. Could you tell me when you were last there at the house?

MR. BREWER: At the house, are we talking about -

MR. KELLY: Rockingham. I'm sorry.

THE WITNESS: It would have been almost three weeks, I would say.

BY MR. KELLY:

Q: And did you discuss Nicole at that time?

A: No.

Q: Prior to your being at Rockingham three weeks ago, when had you been at Rockingham before that?

A: Probably - I don't know. I mean, I've been by there. I can't give you a definite - from that three weeks ago, when was, you know, the time before then, I couldn't tell you.

Q: Well, was it after Christmas?

A: Oh, yeah.

Q: Okay. And could you give me the month you were there where you had a discussion regarding Nicole with Mr. Simpson?

A: You know, when I'm there at times. You know, I'm not there that long. Just like I just said, probably the last time it's been in those five times, I don't know how many times I've said something about Nicole.

Q: Okay. When you say you've "said something," could you tell me what you've said? Just in general terms.

A: Just the fact that the house has - that Nicole was very instrumental in doing a lot of things around the house, designing it, the layout about it, the pool, and to sit there and - you know, it's a difficult thing.

Q: Okay. You spent a lot of time there when she was working on the house?

A: Yeah. Matter of fact, I oversaw the house when they were back in New York, when it was under construction.

Q: This is when Mr. Simpson first bought the house?

A: No. They had the house redone.

Q: Okay. This was after Nicole and Mr. Simpson had gotten married?

A: Yeah.

Q: Okay. This was - they redid the grounds with the pool?

A: Pool, inside.

Q: Kitchen?

A: Yeah.

Q: Okay. Was that basically Nicole's doing or overseeing all that work?

A: Most likely, her and O.J. both. I'd say it was a mutual thing.

Q: Okay. Prior to coming here today, did you meet with your attorney, Mr. Re, at all?

A: Yeah. I have lunch with him all the time.

Q: Okay. And any of those times you've had lunch with him or met with him, has anybody been there with you other than Mr. Re or any member of his staff?

A: Another lawyer, or sometimes we have lunch with Mona Soo?

MR. RE: Sue.

THE WITNESS: Yeah, Mona Soo.

MR. KELLY: Someone from your office?

THE WITNESS: Uh-huh.

MR.RE: Someone who's associated with my office, yeah.

BY MR. KELLY:

Q: Okay. Other than that attorney, anybody else who has ever joined you for lunch or when you've discussed your upcoming deposition?

A: No, no, uh-uh.

Q: Okay. You know Cora Fischman, don't you?

A: Yes, I do.

Q: Okay. Have you spoken to her in the last couple of months?

A: I've saw her at O.J.'s.

Q: And when did you see her at Mr. Simpson's house?

A: It was one of the weekends that O.J. had the kids up from Laguna, and Cora brought her kids over.

Q: How long ago was that?

A: Could have been three, four weeks ago.

Q: Do you know whether that was before or after she had given her deposition -

A: I have no knowledge.

Q: - testimony?

A: I don't know.

Q: Okay. Mr. Cowlings, just let me finish the question, and then you can give your answer. Okay? Did you discuss Nicole Brown Simpson with Cora at all?

A: No.

Q: Okay. Did you discuss any of the facts or circumstances surrounding Nicole's or Ron's murder with her?

A: No.

Q: Okay. Could you tell me when was the last time you saw Christian Reichardt?

A: Christian Reichardt was at O.J.'s house one day when I came by. That's been a while.

Q: Could you approximate how long ago that was?

A: Could have been a month, month and a half, two months. I really don't know.

Q: Okay. Do you know if the kids were up there then?

A: I don't know. It's been a while.

Q: Okay. Would it be more than two months ago?

A: It was a long time.

Q: Okay. Do you recall any conversation you've had with him at that time?

A: "Hi, how are you doing?" "How are you doing," and that's about the extent of it.

Q: Did you talk about Nicole at all with him?

A: No.

Q: Did you talk about Faye Resnick with him at all?

A: No.

Q: Did you talk about Core Fischman with him at all?

A: No.

Q: Did you talk about Mr. Simpson with him at all?

A: No.

Q: You knew Michelle, Mr. Simpson's housekeeper -

A: Yes.

Q: - for many years, did you not?

A: Uh-huh.

Q: Can you tell me when was the last time you spoke to her?

A: I couldn't tell you. I don't remember.

Q: Has it been since Christmastime that you saw her?

A: It's been a long time. She was by the house one day helping out.

Q: At Rockingham?

A: Right, uh-huh.

Q: What was she helping out with?

A: Doing cleaning up, you know, straightening up the kitchen, what have you.

Q: Do you know if that was before or after Christmas in this past year?

A: I have no knowledge, no.

Q: Okay. Did you have any discussions of Nicole with her?

A: No.

Q: Any discussions regarding Mr. Simpson with her?

A: No.

Q: Any discussions regarding the facts and circumstances regarding Nicole's murder with her?

A: No.

Q: Okay. Did you ever have any such discussion with Michelle?

A: No.

Q: Did you ever have any such discussion with Christian Reichardt?

A: No.

Q: Ever, not from June 12th, 1994 on?

A: June what?

Q: 12th, 1994, the day of Nicole's murder.

A: We spoke one time on the phone.

Q: And when was that?

A: It must have been maybe two weeks after the 17th, I would say.

Q: After June 17th, 1994?

A: Yeah.

Q: Did he call you or did you call him?

A: I called him.

Q: And what was the purpose of your call?

A: My purpose of the call was to try to find out what Faye knew about this, and the conversation went for a few minutes, and that was it.

Q: Could you tell me what you said to Mr. Reichardt?

A: Exactly the words I used, but I was trying to find out who were some of the people that they were frequenting with, who - basically just trying to find out some answers.

Q: Well, could you tell me the questions you asked him?

A: I just wanted to know who Nicole was hanging out with.

Q: In that time period at the end in June of 1994?

A: It would have been, like I said, a couple weeks after the 17th.

Q: No. But I'm saying, what time period were you asking him about who Nicole and Faye were hanging out with?

A: I knew they were going out together a lot. I just wanted to find out.

Q: Okay. And what did Mr. Reichardt tell you?

A: He said that Faye was under doctor's care, and her lawyer suggested for her not to speak to anyone.

Q: I know, but you had a conversation with Mr. Reichardt himself, did you not?

A: That's who I spoke to.

Q: Okay. And what did he tell you other than the fact Faye could not speak to you?

A: That was it.

Q: He didn't give you any information as to who -

A: No.

Q: Okay. You have got to let me finish the question, Mr. Cowlings. Okay? He did not give you any information or any names as to who Faye and Nicole were hanging out with?

A: No.

MR. LEONARD: Objection. Argumentative.

THE WITNESS: No, he didn't.

BY MR. KELLY:

Q: Okay. Did he tell you anything other than Faye was under a doctor's care and couldn't speak to anybody?

A: That was all he told me.

Q: Okay. Did he tell you anything about Faye's drug use?

A: No.

Q: Did he tell you anything about Faye owing anybody money?

A: No.

Q: Did he tell you anything about drug lords stalking Faye Resnick?

A: No.

Q: Okay. Could you tell me, did you talk to Cora Fischman any time after June 12th, 1994?

A: Yes.

Q: How many times?

A: Once.

Q: And when was that?

A The exact day and time, I couldn't tell you. It - we met, we took a walk, and we talked about the situation that had occurred.

Q: Meaning the murders?

A: Right.

Q: Where did you meet Cora?

A: We were on San Vicente in Santa Monica between 26th and Burlingame.

Q: Was that a meeting that had been arranged?

A: Yeah, we had talked, and that's where we suggested to meet.

Q: Sat right on the street there?

A: Yeah, right on the - there is a grass divider that runs about four miles from Barrington down to Ocean Avenue on Sancente.

Q: And who had initiated that phone call to set up the meeting.

A: I did.

Q: Okay. And could you tell me what you said when you called Cora?

A: I wanted to talk to her and she wanted to talk to me.

Q: And that was the extent of the conversation?

A: On the phone, yes.

Q: Okay. And could you tell me how long you were with Cora for when you met with her?

A: 20 minutes, I guess, 25 minutes.

Q: And could you tell me what you said to her?

A: It was reports stating that she said if O.J. didn't do it, she knew who did.

Q: I am sorry. Could you repeat that?

A: It was reports or she had made a comment that if O.J. didn't commit the murders, she know who did, and I wanted to know who that person was.

Q: Cora Fischman had said this?

A: Yes.

Q: And where did you find out or from whom did you find out Cora Fischman had said this?

A: I was getting a lot of phone calls from various people.

Q: Could you give me the names of some of the people who called?

A: I don't remember.

Q: Could you tell me exactly what you had been told that Cora knew?

A: That Cora said that if O.J. didn't commit the murders, she know who did.

Q: Well, did you understand from that that she still thought O.J. may have the committed the murders?

MR. LEONARD: Objection. Speculation.

BY MR. KELLY:

Q: You can answer the question.

A: I have no idea. I didn't read into it. All I wanted to know was who did she think had committed the murders.

Q: Okay. And when you met with her, what did you say to her?

A: She asked me, "Did O.J. do it?" And I said, "No," and I asked her, "It was a rumor going around that you said if O.J. didn't do it, you know who committed the murders."

Q: And what did she say?

A: She told me the person.

Q: Who had killed Nicole and Ron?

A: Right.

Q: And what name did she give you?

A: Michelle, the maid.

Q: Okay. And when you had told her that you knew that O.J. didn't do that, was that something Mr. Simpson had told you?

A: No. Just my gut feeling.

Q: Okay. How did - Strike that. When you spoke to Cora and she told you Michelle had committed the murders, could you tell me how she elaborated on this at all?

MR. LEONARD: Objection. Lack of foundation.

THE WITNESS: I have no knowledge. When she just mentioned it to me, I kind of like laughed.

BY MR. KELLY:

Q: Well, there's about 20 minutes left there after she had mentioned this to you.

A: Uh-huh.

Q: Could you tell me what you spoke about then?

A: We just spoke about the relationship between her and Nicole, my relationship with Nicole, the life and the love between O.J. and Nicole and how did it end up in a situation like this.

Q: What did Cora tell you about her relationship with Nicole?

A: They were very close.

Q: Did she say anything more than they were very close?

A: They were very close. They were best of friends.

Q: Did she tell you anything Nicole had said to her about Mr. Simpson?

A: No.

Q: Okay. Could you tell me what you told her about your relationship with Nicole?

A: That I miss her. She was very close and very dear to me.

Q: Have you spoke to Gigi at all since the murders? Or do you know who Gigi is, first of all?

A: O.J.'s maid?

Q: Yeah.

A: I see her when I go by, I speak to her, when I go by O.J.'s house.

Q: Okay. Have you ever spoken to her regarding the facts and circumstances regarding Nicole and Ron's murder?

A: No.

Q: Okay. Have you ever spoken to her about Nicole at all?

A: I don't remember if I did or not. Gigi is, you know, just the lady that takes care of the house.

Q: Did Cora ever tell you why she thought Michelle was the murderer?

A: I guess it had to stem from the relationship between Michelle and Nicole.

Q: Did Cora tell you anything about the relationship between Michelle and Nicole?

A: I guess they were at difficulty, some kind of difficulty. To the exact - to what extent, I don't know.

Q: That Michelle and Nicole had had some difficulty?

A: Right.

Q: And you have no personal knowledge of any of those difficulties?

A: No.

A: Did Cora tell you any of the facts regarding the difficulties -

A: No.

Q: - Michelle and Nicole had?

A: No.

Q: Okay. Did Cora give you any other facts regarding Michelle being the murderer?

A: No. I -when she had mentioned it to me, I just shook my head and, like I said, I smiled and just, you know, didn't even elaborate on it.

Q: Okay. Now, other than calling Cora and Christian Reichardt, could you tell me who else you called looking for information on the murders?

A: I called Cici.

Q: Okay. Was this in the same time period?

A: Yeah, about the same week.

Q: And this would be approximately two weeks after June 17?

A: I can't give you a definite date. I know it had to be after because that's when - I would assume that it all happened for me to try to get in touch with some of Nicole's friends.

Q: Okay. By the way, when you called Christian Reichardt, did you happen to tape-record that conversation?

A: No.

Q: When you met with Cora Fischman, did you happen -

A: No.

Q: You are going to have to let me finish the question, Mr. Cowlings. Okay? When you met with Cora Fischman, did you tape-record that conversation?

A: No.

Q: Had you spoken to any members of Mr. Simpson's defense team regarding contacting people?

MR. LEONARD: Object as leading.

BY MR. KELLY:

Q: You can answer the question.

A: Bob Shapiro.

Q: And could you tell me - What day did you meet with him?

A: We spoke on the phone.

Q: Could you tell me approximately when?

A: Had to be after - sometime in June or July. I couldn't give you a definite date.

Q: Well, was it a result of this conversation you had with Mr. Shapiro that you started making these phone calls?

A: No, uh-uh. Bob had called me.

Q: Okay. What was the purpose of his call?

MR. LEONARD: Objection. Speculation.

BY MR. KELLY:

Q: Can you tell me the purpose of the call from Mr. Shapiro?

MR. LEONARD: Same objection.

BY MR. KELLY:

Q: I am sorry. Could you answer?

A: He wanted to speak to Nicole's friends.

Q: Okay. And did he tell you which friends he wanted to speak to?

A: To the ones I had spoken with.

Q: Well, would it be fair to say, Mr. Cowlings, that you had called these friends of Nicole's at Mr. Shapiro's request?

A: No.

MR. LEONARD: Objection. Leading.

BY MR. KELLY:

Q: I am sorry. Your answer?

A: No.

Q: Okay. Had you spoken to these people prior to Mr. Shapiro calling you?

A: Yes.

Q: Okay. Did you tell Mr. Shapiro you had spoken to these people?

A: Yes.

Q: Did you tell him the substance of these conversations?

A: Just trying to find some answers.

Q: You told him you were trying to find some answers?

A: Uh-huh, yes.

Q: Did he call you because he knew you had spoken to some of Nicole's friends?

MR. LEONARD: Objection. Speculation. Lack of foundation.

THE WITNESS: No.

BY MR. KELLY:

Q: Okay. Did he indicate that to you in the conversation, that he knew you had spoken to some of Nicole's friends?

MR. LEONARD: Objection. Leading.

THE WITNESS: No.

MR. KELLY: Mr. Leonard, just let me finish the question before you -

MR. LEONARD: I thought you had.

MR. KELLY: - voice your objection. Okay. I grew up in the Midwest. I have a very slow pattern there.

BY MR. KELLY:

Q: Okay. Could you tell me, had anybody told Mr. Shapiro that you had spoken to friends of Nicole's?

MR. LEONARD: Objection. Speculation.

THE WITNESS: I have no knowledge of that.

BY MR. KELLY:

Q: Okay. And he never indicated that to you in a phone call, that he knew you had spoken to these people?

A: No.

Q: Could you please tell me what you said to Cici when you called her?

A: I went by - well, I had called her and then wanted to speak with her, and she said "No problem," and I went by her apartment.

Q: And did you say anything other than that when you called her?

A: That's about the extent of it. We spoke, and I told her I wanted to speak to her.

Q: Okay. And how long were you at her apartment for?

A: 20 minutes, 25 minutes.

Q: Okay. Could you tell me what you said to her?

A: I was just trying to find out the people - that they were hanging out with or what have you.

Q: When you say who "they were hanging out with," who are you referring to?

A: Friends of theirs.

Q: Meaning Cici and Nicole?

A: Cici, Nicole, Faye.

Q: Okay. Other than Mr. Reichardt, Cora and Cici, were there any other friends of Nicole's?

A: I spoke with [Name Deleted].

Q: Okay. Going back to Cici for a minute, who did Cici tell you that she and Nicole had been hanging out with?

A: She didn't say.

Q: Why is that?

MR. LEONARD: Objection. Calls for speculation.

THE WITNESS: I don't know. She just didn't say.

BY MR. KELLY:

Q: Did she indicate that she didn't want to tell you?

A: Really, I don't know. She just - she just didn't say.

Q: Okay. When you spoke to Cici, did you discuss Nicole's murder at all?

A: Probably talked about it.

Q: All right. Did Cici indicate to you who she thought had murdered Nicole and Ron?

A: No.

Q: Okay. Did you tell her who you thought had murdered Nicole and Ron?

A: No.

Q: Okay. Could you tell me any of the substance of the conversation when you were with Cici, at all?

MR. LEONARD: Objection. Asked and answered.

THE WITNESS: Basically, you know, a lot of it was still confusing. It was hard to come to grips with the situation. It was a very, you know, difficult thing to talk about and, like I said, it only lasted maybe 20, 25 minutes.

BY MR. KELLY:

Q: Can you tell me anything more specifically as to what Cici said to you?

A: No, I don't remember.

Q: Okay. She didn't tell you anybody she and Nicole had been hanging out with that last year or two?

MR. LEONARD: Objection. Asked and answered.

THE WITNESS: No.

BY MR. KELLY:

Q: You asked her, though?

A: Yeah.

Q: Okay. Did she tell you anything about Nicole when you were there for that 20 or 25 minutes?

A: When you say "about," about what?

Q: Anything. I am trying to find out what you talked to her for 20 or 25 minutes.

A: The fact that, you know, our friend is dead.

Q: Okay. Did you call [Name Deleted] in the same time period also?

A: Yes.

Q: Okay. By the way, when you spoke to - who did you speak to first out of these people? Was it Cora? Christian? Cici? [Name Deleted]?

A: It could have been Cici.

Q: Okay. Did you tell her you were going to be speaking -

A: Yes.

Q: -to other people also?

A: Uh-huh.

Q: Okay. Did she respond to that in any way?

A: Seemed like she had no problem with it.

Q: Okay. When you spoke to Cora, did Cora know that you had already spoken to Cici?

MR. LEONARD: Objection. Calls for speculation.

THE WITNESS: I really don't know.

BY MR. KELLY:

Q: Okay. When you spoke to Mr. Reichardt, did he know that you had spoken to Cora and Cici already?

MR. LEONARD: Same objection.

THE WITNESS: I have no knowledge of it.

BY MR. KELLY:

Q: Okay. Could you tell me, did you call [Name Deleted] during this same time period?

A: Yes, we spoke.

Q: Okay. And what did you say to her when you called her?

A: I wanted to meet with her.

Q: And what was her response to that?

A: "No problem."

Q: Okay. And then did you meet with her?

A: Yes, I did.

Q: And how long after you called her did you met with her?

A: I think we met the same day that I called.

Q: And where did you meet?

A: Right off of San Vicente street. Right off of San Vicente between 26th Street and Burlingame. The exact street, I don't know. We just -

Q: Was this in the same vicinity -

A: Cora, yes.

Q: - that you had met Cora with?

A: Uh-huh.

Q: Okay. And you had already met with Cora?

A: I think so.

Q: Was there any particular reason you chose this location to meet Cora and [Name Deleted] there?

A: It was convenient for both - for the two of us.

Q: Okay. And could you tell me what you spoke to [Name Deleted] about when you met with her?

A: I wanted to know who were some of the t people that they were hanging out with.

Q: And what did [Name Deleted] tell you?

A: She didn't.

Q: How long were you with -

A: She said that she didn't - wasn't out with Nicole that much because she had her own problems and she wasn't going out as much.

Q: Okay. And other than that, did she say anything else to you?

A: No, because she didn't know.

Q: Now, Mr. Cowlings, when you met with [Name Deleted], did you tape record that conversation?

A: No, I didn't.

Q: Was anybody else aware of the fact or had you told anybody else you were going to a meeting with [Name Deleted] at that time and that place?

MR. LEONARD: Object to the compound nature of the question. Would you break it up, please?

MR. KELLY: Yes, Mr. Leonard.

Q: When you met with [Name Deleted], had you told anybody else that you would be meeting with her at that time and that place?

A: I don't remember.

Q: Do you - had you spoken to any investigators for Mr. Simpson before meeting with [Name Deleted]?

A: I spoke to an investigator.

Q: And what was his name?

A: I don't know. He was no longer - he didn't stay that long. He was an assistant to one of the head investigators.

Q: Was an assistant to Pavelick?

A: Yeah.

Q: Okay. Was there anybody to your knowledge videotaping your meeting with Cora Fischman at that location when you met with her?

A: I had no knowledge of it.

Q: Had you told anybody prior to going there that you would be meeting with her at that location?

A: No.

Q: When you went to that same location and met with [Name Deleted], do you have any knowledge of anybody videotaping your meeting with [Name Deleted] at that location?

A: No.

Q: Had you told anybody that you were going to be meeting with her there?

A: No.

Q: Okay. Now, other than these four people - Reichardt, Cora Fischman, Cici and [Name Deleted] - was there anybody else you reached out to speak to?

A: No.

Q: Okay. And was this something that you had taken upon yourself, Mr. Cowlings, to call these four people?

A: Yes.

Q: Okay. Had you discussed calling them with Mr. Simpson?

A: No.

Q: Had Mr. Simpson asked you to call these people?

A: No.

Q: Did any attorney for Mr. Simpson ask you to call these people?

A: No.

Q: Had any investigator asked you to call these people?

A: No.

Q: Okay. Did you later discuss with Mr. Simpson the conversations that you had with any of these people?

A: I don't remember.

Q: Did you ever discuss with any attorney for Mr. Simpson the conversations you had had with any of these four people?

A: Bob Shapiro.

Q: Okay. And was that the time he gave you the phone call?

A: Yes.

Q: Okay. And once again, did he indicate the purpose of his phone call to you?

A: He wanted to speak to them.

Q: To these same four people?

A: Right

Q: Okay. But he did not know that you had spoken to them already?

A: I think after we had talked for a few minutes, he knew that I had spoken with them.

Q: Okay. Did you arrange for Mr. Shapiro to meet with Christian Reichardt?

A: No. What Bob did was put him on a conference call, three-way - three-way call from his phone and my phone. And I don't think we reached anybody, but if their machines answered, he left his name and number and said he would like to speak with them.

Q: And you never reached any of these four people directly that day?

A: I don't think so.

Q: Okay. Do you know whether Cici ever called Mr. Shapiro after that?

A: I have no knowledge.

Q: Do you know whether Cora Fischman ever called Mr. Shapiro back?

MR. LEONARD: Objection. Calls for speculation, lack of foundation.

THE WITNESS: I have no knowledge.

BY MR. KELLY:

Q: Do you know whether [Name Deleted] ever called Mr. Shapiro back?

MR. LEONARD: Same objection.

THE WITNESS: I have no knowledge of it.

BY MR. KELLY:

Q: Okay. And prior to coming in here today, do you know who Robert Baker is, Mr. Simpson's civil attorney?

A: I know of him.

Q: Okay. Have you ever met with him prior to today?

A: No, I haven't.

Q: Do you know who Phillip Baker is?

A: No.

Q: Have you ever - okay. So you've obviously never met with him.

A: No, I haven't.

Q: Okay. Have you ever met with Mr. Leonard prior to today?

A: Yes.

Q: Okay. Have you ever discussed any of the testimony you are going to be giving at your deposition, with him?

A: No.

Q: Okay. When was the last time you met with Mr. Leonard?

A: It's been a while.

Q: Okay. Was that after the criminal trial was completed?

A: Yes.

Q: Okay. Was it after Christmas of this past year?

A: I don't know the exact date. It was a day I went by, and he was there with O.J.

Q: At Rockingham?

A: Uh-huh. Yes. Yes.

Q: Okay. Could you tell me what you discussed with him?

A: I guess that sooner or later I was going to be called for a deposition.

Q: Okay. Did you discuss any of the facts or circumstances surrounding Nicole's murder-

A: No.

Q: - with him? Did you discuss any conversations you had had with Mr. Simpson, with Mr. Leonard?

A: I don't remember.

Q: Could you tell me what you do remember discussing with Mr. Leonard when you spoke to him at Rockingham?

A: That how the house - I was bothered by being at the house.

Q: Because of Nicole's presence there?

A: Right.

Q: Other than that, could you tell me anything else you discussed with him?

A: I think he went and got something to eat.

Q: Okay. Did you ever see him make any notes?

A: Pardon?

Q: Did he take any notes when you were talking to him?

A: I have no knowledge of that.

Q: Okay. Do you recall him asking you any questions that you might be asked at a deposition?

A: Excuse me? You say what?

Q: Do you recall Mr. Leonard asking you any questions that you might later be asked at a deposition?

A: No.

Q: Okay. What about Mr. Blasier, have you ever spoken to him in the last couple of months?

A: Saying hi.

Q: Have you ever discussed or done any sort of preparation for this deposition with Mr. Blasier?

A: No.

Q: Okay. What about with Peter Neufeld?

MR. LEONARD: Objection. What's the question?

BY MR. KELLY:

Q: Have you ever met with Peter Neufeld since the completion of the criminal trial?

A: I met him.

Q: Have you ever met with him in preparation of this deposition?

A: No.

Q: What about with F. Lee Bailey?

A: No.

Q: Have you ever met with - Have I missed anybody, Mr. Leonard?

MR. LEONARD: I don't think so.

BY MR. KELLY:

Q: Melissa Fink -

A: Who's that?

Q: Have you ever heard of her?

A: I have no knowledge of her.

Q: And I've got to ask, what about Alan Dershowitz? Have you ever met with him -

A: No.

Q: - to discuss this case at all?

A: No.

MR. BREWER: Johnnie Cochran.

MR. KELLY: That's a good question.

Q: With the criminal case, did you ever - after June 17th, 1994, did you ever meet with Johnnie Cochran?

A: No.

Q: After June 17th,1994, did you ever meet with Robert Shapiro?

MR. RE: Well I am going - if you are including a period of time between June 17th for a period of approximately two weeks, we are going to be asserting the privilege with regard to anything that went on during that period of time.

MR. KELLY: Was Mr. Shapiro acting as his attorney during that period of time?

MR.RE: I am asserting the Fifth Amendment privilege.

MR. KELLY: Oh, Fifth Amendment privilege. This is during the same period of time he just answered all the questions regarding the other individuals he met with and spoke to?

MR. RE: No. He said that was two weeks or a week after that period of time. I am talking about the period of time from the date of the killing for a period of approximately two weeks after that.

MR. KELLY: Okay.

Q: Prior to your meetings with Cici and Cora and [Name Deleted] and speaking to Reichardt, had you spoken to Mr. Shapiro at all during that time period?

MR. RE: Wait a second. During what time period are you talking about?

MR. KELLY: Prior to his meeting with these individuals and after June 17th.

MR.RE: Well, that's the period of time that we are asserting the privilege to.

MR. KELLY: Okay. So you don't want him answering anything -

MR. RE: Right.

MR. KELLY: - in that time frame.

MR. RE: That's right.

MR. KELLY: Okay.

Q: Did you meet with Carl Douglas at all -

A: No.

Q: - after this two-week period after the 17th?

A: No.

Q: Okay. What about Barry Scheck?

A: No.

Q: Okay. Did you meet with any other attorneys on Mr. Simpson's criminal defense team?

A: No.

Q: No attorneys from Mr. Cochran's office?

A: No.

Q: Okay. Did you meet with - I know you had mentioned the name Bill Pavelick. Did you meet with any investigators from Mr. Simpson's criminal defense team after, say, late June 1994?

A: Just, like I say, that one guy. He didn't last too long. I met him at a hotel.

Q: Okay. Do you recall what you discussed with him?

A: He asked me about certain people and what did I know about them.

Q: What hotel did you meet this individual at?

A: At the Marriott in Century City.

Q: There is only one Marriott there?

A: As far as I know.

Q: Okay. I don't know. I am asking you. As far as you know, there is just one?

A: Yeah.

Q: Okay. And what street is that on?

A: Avenue of the Stars.

Q: Okay. And you don't remember this individual's name?

A: No, I don't.

Q: Okay. How long did you meet with him for?

A: It was a while. I guess an hour or so.

Q: Okay. And how was this meeting arranged?

A: He called me.

Q: And what did he say to you?

A: That he was working for Bill Pavelick and that he wanted to meet with me.

Q: What, if anything, did you do to confirm that this gentleman was in fact working for Mr. Simpson?

MR. LEONARD: Objection. Lack of foundation.

MR. RE: Give me a moment.

(Discussion held between the witness and counsel outside the hearing of the reporter.)

MR. RE: Okay.

THE WITNESS: Yeah, let me see -

BY MR. KELLY:

Q: Want to take a minute?

A: No. Yeah, it was after.

MR. KELLY: Okay?

MR. RE: Yeah.

MR. KELLY: Okay. Could I have the last question read back, please.

(Pending question read as follows:

"Q: What, if anything, did you do to confirm that this gentleman was in fact working for Mr. Simpson?)

MR. LEONARD: Same objection.

THE WITNESS: To be honest with you, I don't know.

BY MR. KELLY:

Q: Did you do anything, or take him on his word that he was working for Mr. Simpson?

A: I just assumed that he was working for him. He called me. I think I was told - I think I was told by Bob Kardashian about him.

MR. LEONARD: Move to strike the last answer.

MR. KELLY: Why is that?

MR. LEONARD: Speculation.

(Discussion held between the Witness and counsel outside the hearing of the reporter.)

MR. KELLY: You didn't strike that, did you?

Q: Had you been told by Mr. Kardashian prior to this phone call that you would be contained by someone?

A: All I know, he called and he stated he was working for Bill Pavelick and that he wanted to talk with me, and so I went over to the hotel.

Q: Did you go over there the same day?

A: I don't - I don't remember if it was the same day or the next day or...

Q: Okay. Was anybody there at the hotel other than you and this gentleman?

A: Just him and I.

Q: Okay. How long were you there for?

A: About an hour or so, I guess.

Q: Could you tell me what was discussed between the two of you during this hour?

A: Hopefully, to - he asked me about a number of people. He used to train at a gym that I used to train at years ago. He had a cold.

Q: He had a cold?

A: Yeah, we talked about his cold.

Q: Okay.

A: And...

Q: Well, when you say he asked you about a "number of people," whom did he ask you about?

A: About some of Nicole's friends.

Q: Could you be specific for me which friends of Nicole's did he ask you about?

A: Cora Fischman.

Q: And what did you tell him about Cora Fischman?

A: That her and Nicole was real good friends, jogging friends. They used to run together, I should say.

Q: Okay. Anything other than this?

A: It was probably Nicole's best friend.

Q: You told him that Cora was probably Nicole's best friend?

A: Uh-huh.

Q: And had Nicole told you that?

A: No.

Q: Had Cora told you that?

A: No. I knew that for a fact. They spent a lot of time together.

Q: Okay. Did you tell this gentleman that Cora thought Michelle had murdered Nicole and Ron Goldman?

A: No, uh-uh.

Q: Okay. Did you ever tell anybody that?

MR. RE: You.

THE WITNESS: Yeah.

MR. KELLY: I feel special.

THE WITNESS: No, no.

BY MR. KELLY:

Q: Who else did this gentleman ask you about?

A: Faye.

Q: And what did you tell him about Faye?

A: I didn't know Faye that well.

Q: Is that all you told him?

A: I didn't know anything about Faye. I mean, I had seen her a few times, her and Nicole, but I didn't know anything about her background.

Q: Okay. And there was nobody in this hotel room except you and this investigator?

A: As far as I know. Just him and I sitting there.

Q: Do you remember what floor the room was on?

A: I took an elevator. We went up.

Q: Was it a suite? Do you recall?

A: It was a room, a hotel room.

Q: Okay. After he asked you about Cora and Faye, who else did he ask you about?

A: He asked me about Ron Shipp.

Q: Okay. And what did you tell him about Ron Shipp?

A: That Ron had been around for a number of years doing things, you know, for O.J. and Nicole.

Q: By the way, was Ron Shipp a very close friend of Nicole's?

A: I think so.

Q: Was Ron Shipp a very close friend of Mr. Simpson's?

MR. LEONARD: Objection. Leading.

THE WITNESS: I think so.

BY MR. KELLY:

Q: Okay. When you spoke to this gentleman, was he - do you know whether he was tape-recording the conversation?

A: Not to my knowledge.

Q: Okay. Did you see him taking any notes?

A: Yes, he was writing things.

Q: Okay. Did you ever have occasion to see those notes or anything he had written again?

A: Excuse me. No.

Q: No sort of report that was generated from that conversation you had with him?

A: No.

Q: Did this gentleman or did any investigator - Strike that. Was there ever a time any investigator for Mr. Simpson ever asked you to wear a tape recorder?

A: No.

Q: Was there any time any attorney for Mr. Simpson's criminal defense team asked you to wear a tape recorder?

A: No.

Q: Okay. After you had spoken to this gentleman about Ron Shipp, did he ask you about anybody else?

A: I can't remember.

Q: Did this gentleman ever ask you to go out and speak to Ron Shipp?

A: No.

Q: Do you recall anything this gentleman told you about the facts and circumstances surrounding Nicole and Ron's murders?

MR. LEONARD: Objection. Lack of foundation.

THE WITNESS: No.

BY MR. KELLY:

Q: By the way, Mr. Cowlings, did you ever take a lie detector test regarding the murders of Nicole and Ron?

A: No.

Q: Were you ever asked to?

A: No.

Q: Okay. When I refer to Mr. Simpson's suicide note, do you know what I'm referring to?

MR. LEONARD: Objection -

MR. RE: Well, this is during the period of time we're talking about.

MR. KELLY: I am just asking him a general question now -

MR. RE: And I am giving him an instruction to assert the privilege.

MR. KELLY: He is not going to answer that?

MR. RE: Right.

MR. KELLY: Okay.

Q: Did you review any police reports in preparation of today's deposition?

A: No.

Q: Okay. Did you review any other deposition testimony in preparation of today's -

A: No.

Q: - testimony?

A: No. I'm sorry. I didn't let you wait - I didn't let you finish your question.

Q: Your answer is no?

A: No.

Q: Okay. Did you review any documents whatsoever in preparation of today's -

A: No.

Q: - deposition?

A: See, you do that on purpose. Go ahead.

Q: Sorry. Do you know what I am referring to when I refer to Mr. Simpson's infomercial?

A: Infomercial?

Q: Infomercial. His videotape.

A: O.J.'s done a lot of tapes.

Q: I am talking about the one he was selling for 29.95 by mail order.

A: Which tape was that?

Q: Do you know of more than one?

A: O.J.'s been selling a lot of stuff over the years.

Q: I'm talking about the one after his acquittal on the criminal charges regarding the murders of Ron and Nicole.

A: Oh, talking about the tape now. I thought you were talking about his exercise tapes. There's a lot of tapes O.J. has done. Sold vitamins, too.

Q: We'll stay away from the exercise tapes.

A: Okay.

Q: Have you seen that videotape?

A: Yes.

Q: Okay. When did you see that videotape?

A: Probably in February sometime.

Q: Okay. Did you watch it with any body else?

A: No. I watched it by myself.

Q: Is there anything in that videotape that you think was inaccurate?

MR. LEONARD: Objection. Over broad.

THEWITNESS: No.

MR. KELLY: You done?

MR. LEONARD: Yeah.

MR. KELLY: Okay.

Q: So as far as you're concerned, everything that you heard Mr. Simpson say in that videotape was accurate?

MR. LEONARD: Objection. Argumentative.

THE WITNESS: When you say "accurate," I mean, I listened to it.

MR. RE: Let me just make something clear here: I haven't seen the whole videotape. If there is a portion of that videotape that deals with the time frame we are talking about, then as to that part I am asking him to assert the privilege. As to the remainder, he is free to answer.

MR. KELLY: Okay.

Q: Is there anything in that videotape that you heard Mr. Simpson say that you know was not true?

MR. LEONARD: Objection.

THE WITNESS: I just listened to it. I wanted to listen to it.

BY MR. KELLY:

Q: Okay. Do you know of anything Mr. Simpson said in that videotape that wasn't true in your opinion?

A: I have no knowledge. I mean, I was just listening to it. What he covered was basically with the trial, I mean, and I didn't watch the trial that much.

Q: One more time: Is there anything in that videotape that Mr. Simpson said that you know to be not true?

MR. LEONARD: Objection. That's an unfair question. Why don't you -

THE WITNESS: I don't know.

MR. LEONARD: If you have a transcript, if you want to show him something.

THE WITNESS: Yeah, if you tell me something, you know, specific. I don't know. He covered a lot of stuff.

BY MR. KELLY:

Q: I know. I am asking: Do you know of anything he covered that was untrue?

A: I have no knowledge of it.

MR. LEONARD: Same objection.

BY MR. KELLY:

Q: Okay. You have no knowledge of anything being untrue that he spoke of in his videotape.

MR. LEONARD: Same objection.

THEWITNESS: I have no - I listened to the tape, and I wasn't there to - I just listened to it.

BY MR. KELLY:

Q: Okay. Did anything strike you as untrue that Mr. Simpson said during the course of that videotape?

MR. LEONARD: Objection. Same objection.

THE WITNESS: Not to my knowledge.

MR. LEONARD: Show him the transcript or play the videotape so he can answer the question fairly.

BY MR. KELLY:

Q: I am sorry. What was your answer?

A: I had said, not to my knowledge.

Q: Did you watch Mr. Simpson's interview on BET January 24th -

A: No.

Q: - of 1996

A: No.

Q: Did you see any portions of that interview after the fact?

A: I remember seeing like a, what you call, a trailer.

Q: Tickler?

A: Is that what they call it, tickler?

MS. ROIT: In the Midwest they call it a tickler.

THE WITNESS: Yeah, trailer out here.

BY MR. KELLY:

Q: Teaser.

A: Teaser.

Q: That's the East, the teaser.

A: But to what he said, no.

Q: Okay. In the trailer/tickler/teaser that you saw, was there anything in there that you heard him say that was inaccurate or untrue?

A: No. He just said that this is going to be shown on BET.

Q: Oh, okay. So you didn't see any of the actual interview -

A: No.

Q: - with Mr. Simpson?

A: Uh-uh.

Q: Okay. Did you see any of the interview with Mr. Simpson when he called in to CNN's "Burden of Proof "?

A: No.

Q: Did you see any portions of that after the fact on any shows or anything?

A: No.

Q: Mr. Cowlings, do you recall giving a statement to the police after your return to Rockingham on June 17th, 1994?

MR. RE: He is going to assert a privilege to that area.

MR. KELLY: Okay. No questions about the statement?

MR. RE: Right.

MR. KELLY: What I was just asking him is, does he recall giving one. I wasn't going to get into the contents of it.

MR. RE: I understand.

MR. KELLY: And you skill don't want him to answer it?

MR. RE: Right.

BY MR. KELLY:

Q: Could I have your date of birth, Mr. Cowlings?

A: 6-16-47.

Q: And are you presently working?

A: Yes.

Q: And where are you working?

A: Clothing company by the name of Jonathan Martin.

Q: And what type of work are you doing for them?

A: I do sales. I do production.

Q: And where are you presently living?

A: I'm giving my post office box.

Q: Okay.

A: [address deleted].

Q: Is that here in the LA. area?

A: Pacific Palisades.

Q: And - I was going to get to it - would you mind, or I will ask your attorney, if you could just write down his full address -

A: No

Q: - and make it available.

A: Uh-uh.

MR. RE: We will talk to you about that possibly off the record.

THE WITNESS: No, uh-uh.

MR. PETROCELLI: Let me say, then, can we have your agreement right now that you will accept service of a trial subpoena on this witness?

MR. RE: Sure.

THE WITNESS: Yeah.

MR. PETROCELLI: Okay.

MR. RE: Sure. Certainly.

MR. PETROCELLI: And the trial is for September 9. Okay? So we will serve a subpoena on you. And you are authorized to accept it on behalf of -

MR. RE: You can serve it right now on him.

THE WITNESS: You don't have to go on TV again and say that you couldn't find me, that I was trying to hide out.

MR. KELLY: You are not going to stay here till the 9th, are you?

MR. RE: He has always been available through me.

MR. PETROCELLI: I wish all the other witnesses -

MR. RE: He will always be available through me.

MR. PETROCELLI: - would be so cooperative; because they are still hiding out.

THE WITNESS: If you just go through your regular routine and try to get in touch with me instead of going out in front of the camera. Go ahead.

MR. PETROCELLI: Well, if you wouldn't -

THE WITNESS: I wouldn't what?

MR. PETROCELLI: Duck service.

THE WITNESS: No, I never ducked service. Don't even try that. You got in front of that camera -

MR. RE: Come on, come on. Mr. Petrocelli, the record is very clear -

THE WITNESS: He's an asshole.

MR. RE: - that you went out and said that he was ducking service at a time when nobody had called me and even asked to have him appear. As soon as anybody called and asked to have him appear, we made him available and he was willing to accept service. He certainly is not ducking service, and there is no real need to get into that. He is available-

MR. PETROCELLI: I didn't get into it.

MR. RE: Well, you just did.

MR. PETROCELLI: No, he got into it.

MR. RE: You got into it. He is available. He has made himself -

MR. PETROCELLI: I am glad that he will voluntarily appear and accept service of a trial subpoena, and that's all that needs to be said.

MR. RE: Okay, fine.

BY MR. KELLY:

Q: You were born in San Francisco -

A: Yes.

Q: - Mr. Cowlings?

A: Uh-huh.

Q: And that's where you grew up?

A: Yes.

Q: Okay. And where did you attend college?

A: University of Southern California.

Q: Okay. And was that for four years?

A: Two years.

Q: And prior to that you were at junior college?

A: Junior college, right.

Q: And where was that at?

A: San Francisco City College.

Q: Okay. And you attended that at the same time Mr. Simpson was there?

A: Yes. I was a year behind him. He was a year ahead of me.

Q: Okay. But you played ball together at the same time -

A: Right

Q: - with him there?

A: Uh-huh.

Q: And when you -

MR. RE: Yes?

THE WITNESS: Yes. I'm sorry.

BY MR. KELLY:

Q: When you were at USC, you played ball there at the same time with him?

A: Yes.

Q: Okay. Were you a year behind him at USC also?

A: Yes.

Q: Okay. And were you drafted by the Bills?

A: Yes.

Q: Okay. And what round were you drafted in?

A: First round.

Q: Okay. And who was your agent, assuming you had one?

A: Chuck Barnes.

Q: Was this Mr. Simpson's agent also?

A: Yes.

Q: Okay. What position did you play?

A: A defensive end.

Q: Okay. You played two years at USC, then?

A: Yes.

Q: And one year you were there was the same year Simpson was playing?

A: Right.

Q: And that was his Heisman Trophy year?

A: Yes.

Q: Okay. Did you go to the Rose Bowl the following year also?

A: My two years there, yes, we went to two Rose Bowls.

Q: When you went to Buffalo, where did you live there?

A: An apartment.

Q: Okay. Do you recall what the address was?

A: No. It was on Amherst.

Q: Okay. Did you share the apartment with anybody?

A: No.

Q: Okay. And what about during the off season when you were with Buffalo? Would you come back -

A: Yes.

Q: - West here?

A: Sorry. Yes. Come back West.

Q: To San Francisco or L A.?

A: Los Angeles.

Q: And did you have a home here during that period?

A: No. I rent apartments.

Q: Okay. By the way, was that an apartment you rented in Buffalo during the season?

A: Yes.

Q: Okay. And the apartment you had here in LA. during the off-season, you rented that also?

A: Yes.

Q: Okay. And there came a time that you were traded to San Francisco from Buffalo?

A: No.

Q: You were never traded?

A: Yeah, I was traded, but I wasn't traded from Buffalo to San Francisco.

Q: Who were you traded to?

A: I was traded to Houston.

Q: Okay. What year was that?

A: That would have been '73.

Q: And that was before Simpson was - Simpson was still with Buffalo -

A: Yes.

Q: - when you were traded to Houston?

A: Uh-huh.

Q: And how many years did you play at Houston for?

A: Two years.

Q: Then you stopped playing?

A: No. I was traded to the Rams after that. No. I signed with the Rams.

Q: Okay. After you signed with them, did you play at all?

A: Yes.

Q: And how many seasons?

A: I was there for three seasons.

Q: So what was your final year of pro ball?

A: My final year, in '79.

Q: Okay. Was that Simpson's final year also?

A: Right.

Q: Okay. Have you ever been married, Mr. Cowlings?

A: Yes.

Q: And when was that?

A: About a year and a half ago.

Q: Are you married now?

A: Yes.

Q: Okay. Any children?

A: No.

Q: Okay. Did you ever have any children?

A: Not that - not to my knowledge.

Q: Okay. Other than your present employment we talked about - what was that; in the clothing industry?

A: Uh-huh.

Q: Did you ever do any endorsement contracts during your playing days?

A: No endorsement contracts, no.

Q: No. Any promotional work?

A: When you say "promotional work," what were you speaking of?

Q: Well, for sports products or -

A: I've done commercials.

Q: For who?

A: Some athletic gear. It was early on in my career.

Q: Early '70s?

A: Yeah.

Q: Okay. And who was that for?

A: I don't remember.

Q: Okay. Have you ever been in any movies at all?

A: Yes.

Q: And what movies have those been?

A: Worked on a cable show called "1st and 10," did some work - extra work on a couple of features: CAPRICORN, DETOUR

Q: DETOUR TO TERROR, was that the name of it?

A: I guess. It was a TV program - it was a movie for TV.

Q: Okay. Now, "lst and 10," that was a show that Mr. Simpson was involved in -

A: Right.

Q: - also? Was he the one that got you involved in that?

A: Yes.

Q: And what about CAPRICORN, was that a Simpson movie?

A: Yes.

Q: Okay. By the way, for your appearances in "1st and 10," did you get paid for that?

A: Yes.

Q: Okay. And what about CAPRICORN, did you get paid for that appearance also?

A: I worked extra work. You don't appear. You just fill in. You're never seen on camera. Yes, I got paid.

Q: You get paid for that, don't you?

A: Yes.

Q: Do you have to be a member of the actors' guild for that?

A: Right.

Q: And would you get health benefits and things as a result of that also?

A: Yes.

Q: And had Mr. Simpson arranged that for you also?

A: No. I had to qualify for that.

Q: For the benefits and in the actor's guild?

A: No. You have to qualify to join the union. Then you pay to join the union.

Q: Okay. But in terms of being paid as an extra on the CAPRICORN set, Mr. Simpson arranged that for you?

A: Yes.

Q: And with DETOUR TO TERROR, the same m thing: Did Mr. Simpson arrange for you to be part of that set?

A: Yes. By that time I had did a lot of stand-in work for O.J., and so it was an ongoing thing during the off-season when he worked on films or commercials and required a stand-in, I would be his stand-in.

Q: What do you mean by being a "stand-in"?

A: They check the lights and stuff. You stand in his spot where they going to actually shoot the film -

MR. RE: You really are from the Midwest.

MR. KELLY: That's right.

THE WITNESS: - and you stand there -

MR. KELLY: Rural Midwest, obviously.

THE WITNESS: - and they work and figure out the camera angle and the lighting and all, and once they get that situated, then you step off camera and he stands - he comes in there and starts reading his lines.

BY MR. KELLY:

Q: Okay. You never - and excuse my Midwest upbringing - you never served as a second for Mr. Simpson in any movie or show, did you?

A: What do you mean by "second"?

Q: See, that's Midwest talk that you guys don't know.

A: I gave you "stand-in."

Q: Where you were appearing as Mr. Simpson, say, as a stunt or an action shot or a distance shot?

A: No, only - a distance shot in some things, yes.

Q: Okay. Did you ever work at having to be able to walk like Mr. Simpson or have his demeanor in any way?

A: From a distance.

Q: Okay. And DETOUR TO TERROR - I think I asked you this - he arranged for you to be on that set also?

A: Yeah. Yes.

Q: Okay. And what was your involvement with that movie?

A: Stand-in.

Q: Okay. Do you recall whether Nicole was part of that set also?

A: Yes, she was.

Q: Okay. Did that movie ever actually get produced?

A: Yes.

Q: In the theaters?

A: No. It was a movie made for TV.

Q: Okay. And that actually appeared on TV?

A: Yes.

Q: And were you an extra for that?

A: Yes. I was a stand-in.

Q: Stand-in. That's what we talked about before?

A: Right.

Q: Okay. What about Nicole, do you recall what her role was?

A: Nicole was an extra.

Q: Okay. Do you recall what she was an extra for, what particular scenes or anything?

A: Extras are used for background, atmosphere. She was on the bus a lot. She sat on as one of the passengers on the bus.

Q: Do you recall whether there was something she ever had to get made up for?

A: No, I don't remember.

Q: Did you ever see Nicole being made up at all for the movie DETOUR TO TERROR?

MR. LEONARD: Objection. Lack of foundation.

THE WITNESS: I don't know. I don't remember.

BY MR. KELLY:

Q: Okay. Looking back, do you recall any scene in DETOUR TO TERROR where any passengers on that bus were injured at all?

A: I would think so. It was - like I say, it was overtaken by terrorists or some robbers or whatever, so they probably had some people made up to look like they were injured or shot.

Q: Okay. Do you recall yourself whether Nicole was ever made up this way?

A: I don't remember

MR. LEONARD: Objection. Asked and answered.

BY MR. KELLY:

Q: I am sorry. What was your answer?

A: I don't remember.

Q: Okay. Did you ever see her when the movie appeared on TV, in the movie?

A: Did I what?

Q: Did you see Nicole actually -

A: Yeah.

Q: - appear in the film?

A: Yeah.

Q: She was in it?

A: Yeah, she was in it.

Q: Okay. And could you tell me how long ago this was?

A: It was a long time ago. I can't give you an exact date. I think it was- let's see. It could have been - whenever O.J. had his production company is when, because he - it came through his production company.

Q: That's Orenthal Productions?

A: Yes.

Q: Okay. Were there any other investments or businesses Mr. Simpson got you involved in?

MR. LEONARD: Objection. Compound.

BY MR. KELLY:

Q: Were there any other investments Mr. Simpson got you involved in?

A: When did he ever get me in any investments?

Q: I don't know whether he did or not. Did he?

A: No, he didn't.

Q: Did you ever invest or - I don't want to ask you a compound question. Were you ever a partner of Mr. Simpson's in any business venture?

A: We had some business opportunities that we -but nothing ever developed. I mean, what I'm saying, I mean, it was more in the starting-up stages, but it never really matured into anything.

Q: Okay. Do you know - Mr. Simpson's first wife's name, her first name was Marquerite?

A: Yes.

Q: Do you recall what her maiden name was?

A: Weeklia - Week - started with a W. It's been a long time.

Q: Okay. And when did you first meet Marquerite?

A: In high school.

Q: Okay. And how long did you know her before she met Mr. Simpson?

A: I don't know. Could have been a couple months before.

Q: Okay. And as I understand, it was you who introduced her to Mr. Simpson?

A: Yes. Marquerite and I were dating, and I introduced her to O.J.

Q: And how long did she and Mr. Simpson date before they married, if you recall, approximately?

A: I don't know. Could have been a year, year and a half. I don't know how long, you know, it went.

Q: Did you attend their wedding?

A: Yes.

Q: Did they have a large wedding or a small wedding?

A: It was -

Q: Medium?

A: It was a wedding.

Q: Okay. Were you in the wedding party?

A: Yes.

Q: And what was your role in the wedding party?

A: I was one of the...

MR. RE: Ushers?

THE WITNESS: Ushers.

BY MR. KELLY:

Q: Do you recall whether Mr. Simpson had a best man?

A: Yes.

Q: And who was that?

A: Gentleman by the name of Mike Taylor.

Q: And who is Mike Taylor?

A: He was a friend of ours. We all played ball together.

Q: At junior college?

A: Yes.

Q: And he was - was he at USC also?

A: Yes, he came - he was a year ahead of O.J. He was an offensive tackle.

Q: Okay. Did he play pro ball?

A: Yes.

Q: Where did he go?

A: Pittsburgh Steelers.

Q: Okay. There you go, Mr. Cowlings. Now I'm learning about pro football, huh? Would it be fair to say that Taylor was a close friend of Mr. Simpson?

A: Yeah.

Q: Do you know whether they stayed close friends during their pro careers?

A: I assume. I don't know if they - how often they talked or how often they saw each other, yes.

Q: Okay. Do you recall how long Marquerite and Mr. Simpson were married for?

A: long time.

Q: About 10 years, would that be fair to say?

A: I don't know - you know, I don't know the exact years, but they were married for a long time.

Q: Okay. Did you spend time with them during their marriage?

A: Yes.

Q: Okay. You'd see them often in Buffalo during the season?

A: Yes.

Q: Okay. And did you remain friends with Marquerite also during the marriage?

A: Yes.

Q: Okay. Were there times that you ever saw Mr. Simpson and Marquerite argue?

A: I can't remember.

Q: Can't remember any specific times?

A: No.

Q: Did you ever observe any physical altercations -

A: No.

Q: - between - You have to let me finish the question, Mr. Cowlings. Did you ever observe any physical altercations between Marquerite and Mr. Simpson?

A: No.

Q: Okay. Do you remember when Jason was born?

A: Yes.

Q: Were you at the hospital for that?

A: Yes.

Q: Okay. Were you at his christening?

A: Yes.

Q: Okay. Are you his godfather or anything like that?

A: Yes, I am.

Q: You're his godfather?

A: Yes.

Q: Okay. You have attended birthday parties for him over the years?

A: Yes.

Q: Okay. And you were close to him when he was young?

A: Yes.

Q: And you remain dose to him to this day?

A: Yes.

Q: Okay. Do you remember when Arnelle was born?

A: Yes.

Q: Okay. By the way, what was the last time you saw Jason?

A: It's been maybe a month, month and a half.

Q: Okay. Did you speak to him at that time?

A: Yes.

Q: Where did you see him?

A: I went by his apartment.

Q: Okay. And what did you speak to him about?

A: Just went by to see him, see how he's doing.

Q: Okay. Did you talk anything about the civil case at all?

A: No.

Q: Talk anything about Nicole?

A: No.

Q: Talk anything about his dad in relation to this case?

A: No.

Q: Okay. Going back to Arnelle, were you at the hospital when she was born?

A: No. I was in San Francisco when Arnelle was born.

Q: Were you there for her christening?

A: I'm trying to remember did Arnelle get christened. I don't know. I don't remember.

Q: Okay. Did you have a close relationship to Arnelle when she was young?

A: Yes.

Q: Do you maintain that close relationship to this day?

A: Yes.

Q: Could you tell me the last time you spoke to Arnelle?

A: I spoke to her Sunday.

Q: Okay. Did you indicate to her that you were going to be testifying here at this deposition?

A: Yes.

Q: Did you discuss that at all?

A: No.

Q: Okay. Did you discuss Nicole at all with her at that time?

A: No.

Q: Did you discuss her father with her at all that time?

A: Yeah. She was telling me he was doing fine.

Q: Okay. Do you remember times when - well, during the time Marquerite and Simpson were married that you attended family events where Mr. Simpson was not there?

A: Excuse me/

Q: Well, do you remember times during Marquerite and Simpson's marriage where, say, for Jason's birthday parties that you were there and Mr. Simpson was not?

A: I don't remember.

Q: Okay. What about for Arnelle?

A: Don't remember.

Q: Okay. After Marquerite and Simpson were divorced, did you remain friends with Marquerite?

A: Yes.

Q: Okay. Do you remember when they made the decision to get divorced, Marquerite and Mr. Simpson?

A: No.

Q: Do you know whose decision it was for them -

A: No.

Q: - to get divorced? Do you recall ever discussing the divorce with Mr. Simpson prior to it happening?

A: No.

Q: He never told you why he was divorcing Marquerite?

A: At the time him and Nicole was going with each other, so I assume that he wanted to marry Nicole.

Q: Do you know whether he had decided to divorce Marquerite before he met Nicole?

MR. LEONARD: Objection. Lack of foundation.

THE WITNESS: I don't have no knowledge of it.

BY MR. KELLY:

Q: Okay. Did you discuss the divorce with Marquerite prior to those two being divorced?

A: I don't remember.

Q: Okay. Marquerite never told you why she and Mr. Simpson were getting divorced?

A: No.

Q: Okay. Did Marquerite ever discuss Nicole with you prior to the divorce?

A: No.

Q: Did she ever - did Marquerite ever discuss Nicole with you after the divorce?

A: - No.

Q: Do you remember ever discussing with Nicole Mr. Simpson's pending divorce with Marquerite?

A: No.

Q: Okay. When was the last time you spoke to Marquerite?

A: It's been a while. Oh, she was at O.J.'s for Christmas holidays - I mean Christmas - Christmas Eve or Christmas Day.

Q: That's this past year, '95?

A: Yes.

Q: Okay. And prior to that and after June 12th, 1994, the day of the murders, did you talk to Marquerite at all?

MR. RE: Excluding the period we're talking about.

MR. KELLY: Excluding - in fact, that will just be a standing exception to general questions I ask, Mr. Re. Okay?

MR. RE: Thank you.

THE WITNESS: I can't remember.

BY MR. KELLY:

Q: Okay. Do you know if you ever discussed with Marquerite the murders of Nicole Brown Simpson and Ron Goldman?

A: We talked at O.J.'s. She came up - she was staying - she came up - it was during that - you know, we talked about what had happened.

Q: Could you tell me the substance of that conversation?

A: Just saying it's unbelievable -

MR. RE: Is this during that period shortly after - was this two weeks after -

BY MR. KELLY:

Q: Well, when was it?

A: I don't know. It was after.

Q: Do you know what month it was in?

A: No, I don't.

Q: Would it have been after, say, July of 1994?

A: I couldn't - I could not pinpoint a date or a time.

Q: Do you know whether it was more then two weeks after June 17th,1994?

A: I don't remember.

Q: Okay. Did you discuss Mr. Simpson with her at all?

A: Yes.

Q: Okay. In the context of the murders of Nicole Brown Simpson and Ron Goldman?

MR. LEONARD: Object to the form as vague.

THE WITNESS: I wouldn't - I don't remember. I know we talked about, you know, our relationship and how, you know, something like this can happen

BY MR. KELLY:

Q: What had happened?

A: Just the whole craziness of this whole thing.

Q: What whole thing?

A: The murders, O.J. being accused.

Q: Okay. Did she ever express to you whether she thought Mr. Simpson had done it or not?

A: No

Q: One way or the other?

A: No.

Q: Okay. Did you ever express to her one way or the other whether you thought Mr. Simpson had done it or not?

A: No.

Q: Okay. Could you tell me the first time that you met Lou Brown, Nicole's father?

A: O.J. and Nicole had been together for I think a year or two. I don't think - they - Lou didn't know - Lou didn't know who she was going with at that time.

Q: That first year?

A: First year or first two years.

Q: How do you know that?

A: Because that was in '79, and Lou and Judy came up to San Francisco to meet with O.J. and Nicole.

Q: And when you say they didn't know who Nicole was going out with -

A: No, no, no. I didn't say they. I said Lou.

Q: Lou did not.

A: Yeah. Judy knew.

Q: Okay. Who had told you Lou did not know who Nicole was going out with?

A: Nicole.

Q: Okay. And do you know when she finally told Lou who she was going out with?

A: I don't know if she - he knew prior to coming to San Francisco, but the reason why him and Judy was coming up, to meet O.J.

Q: Okay. Were you there when they met -

A: No.

Q: - Mr. Simpson?

A: No.

Q: After they first met Mr. Simpson, did you then meet with Lou Brown and Mr. Simpson where they were together?

A: I think I didn't meet Lou until the off-season of '79, I think.

Q: Okay. And where did you meet him?

A: Could have been at O.J.'s house.

Q: At Rockingham?

A: Yes.

Q: And how would you describe Lou Brown?

MR. LEONARD: Objection. Vague.

THE WITNESS: Nice person.

BY MR. KELLY:

Q: Okay. Did you ever spend time in the Browns' home down at [Address deleted]?

A: For functions and family outings, yes.

Q: Okay. Did Lou Brown ever make you feel you weren't welcome there?

A: Never.

Q: Okay. Did you ever get the impression that Mr. Simpson wasn't welcome there when Lou Brown was there?

A: Never.

Q: Okay. Did you see Lou Brown at Rockingham for family events?

A: Yes.

Q: Okay. For Christmas?

A: Yes.

Q: Other holidays?

A: Yes.

Q: Okay. Birthday parties for Sydney and Justin?

A: Yes.

Q: Okay. Did Lou Brown ever indicate to you that he did not like Mr. Simpson?

A: No.

Q: Did he ever indicate to you that he was 1 ever angry at Mr. Simpson for any reason?

A: I have no knowledge of that.

Q: Okay. After June 12th of 1994, did Lou Brown ever indicate to you that he thought Mr. Simpson had killed Nicole?

MR. LEONARD: Objection. Leading.

THE WITNESS: We had a run-in a few weeks ago in Laguna.

BY MR. KELLY:

Q: Okay. Other than that run-in - that was at Justin's basketball game, by the way?

A: Right, uh-huh.

Q: You were down there with Mr. Simpson?

A: Right.

Q: Other than that run-in a few weeks ago and after June 12th, 1994, did you have any discussions with Lou Brown regarding what he thought - Mr. Simpson's involvement was in Nicole's murder, if any?

MR. RE: We are still excluding the two-week period?

MR. KELLY: Always. That's a standing -

MR. RE: I just want to make sure the witness is aware of that.

THE WITNESS: I don't remember.

BY MR. KELLY:

Q: Okay. You can't think of any other time?

A: No.

Q: Okay. That Laguna conversation that you're referring to-

A: Uh-huh.

Q: - was that with Lou and Judy Brown?

A: It started off with Judy first.

Q: Okay. And Lou was there also?

A: He came up when Judy and I were outside.

Q: Outside the gym?

A: Yes.

Q: There was nobody else there besides Lou, Judy and yourself, was there not?

A: There was people coming in and out.

Q: Okay. But Mr. Simpson was inside the gym at that time?

A: Yes.

Q: Okay. When you finished with the Rams in '78, you stayed in Los Angeles then?

A: No. I went to Seattle. Seattle Seahawks.

Q: Oh, you did.

A: I was - they claimed me off of waivers, and I went up to - no; no, I take that back. No, no, no. I'm going too fast. When I finished with the Rams, I went to Canada.

Q: To play football?

A: Right.

Q: With which team up there?

A: Montreal Allouettes.

Q: Okay. Did you actually play during their season?

A: Yes.

Q: And from the Canadian league season, you then went to Seattle?

A: No.

Q: What did you do after that?

A: I tore up my knee up there in the last game, and I came back to Los Angeles, and I had more or less retired.

Q: Did you have surgery for that?

A: Yes.

Q: Was it a ligament or meniscus?

A: It was a ligament.

Q: Okay. Did you have surgery immediately?

A: Yes.

Q: Okay. And you mentioned the Seahawks. What happened with them?

A: No. The first - I got released by the Rams. I was claimed by the Seahawks and went there, I didn't like it and came back and re-signed with the Rams.

Q: What did you do, just go to summer ball with them?

A: No. As a matter of fact, I played a league game with them, the first game of the year, and I didn't like Seattle, so I asked for my release.

Q: And they gave it to you?

A: Yes.

Q: Okay.

MR.BREWER: Take five minutes here, John?

MR. KELLY: Sure. You want to take a break now?

THE WITNESS: Yeah.

MR. KELLY: Okay.

THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 10:57.

(Recess.)

THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 11:09.

BY MR. KELLY:

Q: Mr. Cowlings, when we let off, I think we were discussing the end of your pro football career. Is that correct?

A: Whatever the question was.

MR. KELLY: Actually, could we have the question read back?

(Record read.)

BY MR. KELLY:

Q: Okay. All night. Earlier I had been asking you about some questions about Lou Brown. Do you recall that?

A: Yes.

Q: Okay. And you had indicated that you knew yourself that Mr. Simpson had met Judy Brown, Nicole's mother, before Simpson had ever met Lou Brown. Is that correct also?

A: I didn't say - I didn't know if they met, but I knew she knew who Nicole was going with.

Q: Okay. When did you first meet Judy Brown?

A: Probably the same time I met Lou and had - probably would have been the fall of '79, I think.

Q: Was that up in San Francisco?

A: No. That would have been here in Los Angeles.

Q: Okay. And in general terms could you tell me what type of person Judy Brown -

A: Very nice.

Q: - is? You have a good relationship with her?

A: I think up to a point. I don't think about now.

Q: Okay. We are talking about the Laguna incident?

A: Pardon?

Q: Prior to June 12th, 1994, did you have a very good relationship with Judy Brown?

A: Yes.

Q: Okay. And did you spend time - I think I asked you about spending time down at the Browns' house in [Address deleted]?

A: On family affairs.

Q: And did Judy ever make you feel that you weren't welcome there?

A: No

Q: Did you ever see any indication that she didn't always welcome Mr. Simpson into her house -

A: Always.

Q:-down there?

A: Always. I'm sorry.

Q: Okay. And did Judy ever indicate to you prior to June 12th, 1994 that she was ever angry at Mr. Simpson?

A: No.

Q: Did she ever indicate to you she didn't like Mr. Simpson?

A: No.

Q: Was there ever a time after June 12th, 1994 that Judy indicated to you that she thought Mr. Simpson had murdered Nicole?

MR. RE: Again excluding that same I period?

MR. KELLY: Always.

THE WITNESS: Pardon me? Could you -

MR. KELLY: Could you read the question back to him?

(Pending question read.)

MR. RE: Not including the two week period after.

THE WITNESS: Yes.

BY MR. KELLY:

Q: And when was that?

A: I couldn't give you a definite date or time or - you know, when she had voiced that to me.

Q: Do you recall what she said to you?

A: That she think that he had committed the murders.

Q: Do you know whether that was immediately after the murders or not, meaning the first couple days?

A: No.

Q: Okay. Do you know whether it was during the course of the trial that you spoke to her about this?

A: Probably during the course of the trial she felt that he did it.

Q: And she said that to you?

A: Yes.

Q: Do you recall where you were when she said this to you?

A: At their house.

Q: Was that sometime where you were down to visit the kids or something?

A: Right.

Q: Okay. And do you recall exactly what she said to you?

A: She would ask me, do I still think that he was innocent, and I would say yes.

Q: Okay. And then would she say something else to you?

A: And she will say, "How could you?"

Q: Did she give you any specific reasons why she thought he was guilty?

A: No.

Q: Okay. When was the first time you met Denise Brown, Nicole's sister?

A: We all were working on a film with O.J., and we all ended up - the film ended up in New York, and O.J. and Nicole, Denise, her boyfriend and myself went to a play.

Q: What film was that you were working on?

A: What was that. It was with Sophia Loren. What was it called. FIRE POWER, I think. FIREPOWER.

Q: Do you know what year that was?

A: That would have been '78.

Q: Okay. And how would you describe Denise Brown?

MR. LEONARD: Objection. Vague.

THE WITNESS: Nice person.

BY MR. KELLY:

Q: Okay. Up to at least June 12th, 1994, did you have a good relationship with her?

A: Yes.

Q: Did she ever, prior to that date at least, indicate to you that she didn't like Mr. Simpson?

A: Not to my knowledge.

Q: Did she ever indicate to you that she was ever angry at Mr. Simpson?

A: Not to my knowledge.

Q: Was there any time after June 12th, excluding those couple weeks, of course, that Denise indicated to you that she thought Mr. Simpson had killed Nicole and Ron Goldman?

A: Telling me personally?

Q: Yeah, speaking to you.

A: She may have.

Q: Do you recall approximately when?

MR. LEONARD: Objection. Calls for speculation.

THE WITNESS: No, I don't - a lot of times when I went down, Denise wasn't in, so I didn't see her that much.

BY MR. KELLY:

Q: Okay. Were there times you did see her, though?

A: For Justy's - when he got baptized, she was there.

Q: When Justin was baptized?

A: Yeah, in Laguna.

Q: Okay. How long ago was that?

A: I guess in the last year, if not - no. No. It had to be longer than that. Last year and a half, I guess.

Q: Did you have any discussions with her regarding -

A: No.

Q: - Mr. Simpson's involvement in Nicole's murder or not?

A: No. The only discussions I would have is with Judy or Lou.

Q: Going back to '78 when you finished playing pro football -

A: '79.

Q: '79?

A: (Nods head.)

Q: - you settled back in L.A. then?

A: Yes.

Q: Okay. And Mr. Simpson was living here at that time also?

A: Yes.

Q: Did you spend a lot of time with him -

MR. LEONARD: Objection. Vague.

BY MR. KELLY:

Q: - in that -

MR. LEONARD: Sorry. Go ahead.

MR. KELLY: You've got to give me a chance to be more vague before I finish the question.

Q: Did you spend much time with Mr. Simpson during the year 1979 after you finished playing pro football?

A: Yes.

MR. LEONARD: Objection. Vague.

BY MR. KELLY:

Q: Could you tell me who were some of the friends you and Mr. Simpson would spend time with together?

A: I played a lot of tennis with various - number of people. A lot of people used to come by O.J.'s house.

Q: Where? At Rockingham?

A: Yes.

Q: And this was in '79?

A: A lot. Even before '79 and after '79.

Q: Was Marquerite living there at that time?

A: I think Marquerite was - could have been at the house at that time. I think she was still staying - living there while he was in San Francisco.

Q: Okay.

A: Oh, okay. '79. Oh, no. He had gotten Nicole an apartment at Westwood, so he was spending a lot of time there.

Q: At Westwood?

A: Right, wherever her apartment was. No, no. I think - Westwood, yeah - no, no. This - the other apartment was in Beverly Hills. That's the one in '79.

Q: Are we talking about Nicole's apartment?

A: Yes.

Q: Okay. Was he living with Nicole at that time?

A: They were spending a lot of time. I don't know if he was living there all the time, though.

Q: Okay. Did he have his own place also, other than Rockingham?

A: Just, I mean, Rockingham.

Q: Did he live there while Marquerite was there?

A: I don't know.

Q: Okay. But you recall being over there when Marquerite was staying there still?

A: No. No. No. In '79, no.

Q: Okay. So you and Simpson wouldn't play tennis there -

A: No.

Q: - with your buddies when Marquerite was still there?

A: No.

Q: Okay. Prior to Marquerite moving out of Rockingham, when you and Simpson were still in L A., could you give me the names of some of the people you used to hang out with?

A: Hang out with?

Q: Yeah.

A: Or come by the house?

Q: No. Hang out with.

A: There was a lot of people.

Q: Give me what you would consider yours and Simpson's closest friends during that period of time.

A: O.J. had a lot of people. I mean, wasn't my friends - I mean, people who came by to see O.J., not me. I just -

Q: I am not talking about Rockingham. When you would go out at night or something, you and Simpson together, who else would be with you?

A: If O.J. went out prior to that, he was with his wife. If I happened to have a date, I would go out with them.

Q: Okay. Wasn't he going out with Nicole during that time period also?

A: Yes.

Q: Okay. Did you ever go out with he and Nicole?

A: They didn't go out that much.

Q: He and Nicole didn't go out that much?

A: No.

Q: Okay. But he had gotten her the apartment in Westwood?

A: Right. They would go to the movies, but they wouldn't like go out, you know, because he was still - at that time still married to Marquerite.

Q: Okay. Do you know who Simpson's - By the way, in '79 would you consider Simpson your closest friend at that time?

A: Yeah.

Q: And in your mind were you Simpson's closest friend?

A: I was - yeah, I guess.

Q: Okay. Could you tell me, other than yourself, who you viewed as Mr. Simpson's close friends at that time?

A: O.J.-a lot of people would make themselves available to O.J. as friendships. He had - it was a lot of people. I couldn't pinpoint who O.J. felt was closest to him. O.J. was a very warm, open person. He was very easy to approach.

Q: Did you know [Name Deleted]?

A: Yes.

Q: Okay. Could you give me - was there a particular crowd you would associate [Name Deleted] with during that time period?

A: We would frequent [Name Deleted]'s restaurant. [Name Deleted] had a restaurant in West Los Angeles on Pico called [Name Deleted]'s. His relationship with [Name Deleted] stems back to when [Name Deleted] worked for the Luau years before.

Q: Okay. Was there a particular group of people that you would hang out with during that period, say, at [Name Deleted]'s?

A: Well, [Name Deleted]'s place was - had good food, good atmosphere, and a lot of times you see a lot of the same faces. I couldn't pinpoint, you know, names.

Q: Who would Simpson go there with?

A: Him and Nicole would go there. That was one of the few places they would go.

Q: Would they go with other people, other than you?

A: No. They would be there by themselves a lot.

Q: So you can't tell me, other than yourself, who you considered Mr. Simpson's close 1 friends at that time?

MR. LEONARD: Objection. Argumentative.

THE WITNESS: I don't know who O.J. considered his close friends.

BY MR. KELLY:

Q: I know. I am asking you.

A: I don't know. He never voiced how he rated his friends to me.

Q: But were there any particular individuals he'd spend more time with than others?

A: No.

Q: At what age did you start - did you first meet Mr. Simpson? How old were you?

A: I don't know. I was in the third grade, something like that.

Q: Okay. You knew him through high school?

A: Grade school we knew - I knew of him.

Q: You spent time together during grade school?

A: No. We went to the same grade school. We actually didn't start becoming friends until junior high school.

Q: Okay. And you spent a lot of time with him then?

A: Yeah. We lived in the same neighborhood.

Q: Okay. Did you ever see him in any fist fights?

A: O.J. didn't fight a lot, no.

Q: No?

A: O.J. was boisterous.

Q: Okay. Never saw him in a fight?

A: No.

Q: Okay. Did you consider him a tough guy during that time period, high school?

A: Yeah -

MR. LEONARD: Objection. Vague.

BY MR. KELLY:

Q: I am sorry?

A: I - yeah, O.J. probably could hold his own in a fight.

Q: Okay. You never saw him hold his own, though, in a fight?

A: No.

Q: When you say he was "boisterous," did you ever see him talk himself out of a fight situation?

A: I've seen O.J. fight - talk himself out of a lot of situations.

Q: I am talking about fight situations now during that time period like in high school.

A: O.J. had an air about him that people - he could, you know - people didn't want to mess with O.J.

Q: He's a good talker, huh?

MR. LEONARD: Objection.

THE WITNESS: Well, talker, his appearance, because at that time O.J. had a Fu Manchu, and he looked a lot older than his age, so he was not to be messed with.

MR. PETROCELLI: What's the time frame here?

BY MR. KELLY:

Q: We are talking high school?

A: Junior high, high school.

A: Junior high and high school?

A: Uh-huh.

Q: Were you in a gang during any of that time period?

A: Yeah, we were in a social gang.

Q: What was the name of that?

A: The Superiors.

Q: When you say you saw O.J. talk himself out of a lot of situations, could you have -

A: No, I didn't say a lot of situations.

MR. PETROCELLI: Quote, "Saw OJ talk himself out of lots of situations."

THE WITNESS: Okay. Lots of situations, yeah.

BY MR. KELLY:

Q: Okay. Could you tell me some situations you saw Simpson talk himself out of?

A: Things - nothing out of the ordinary. Just, you know, young guy stuff.

Q: Such as?

A: Flirting.

Q: Flirting with other guys' gals?

A: No. Just flirting with girls.

Q: Why would he have to talk himself out of flirting with girls?

A: You know, like, "Did you say this about me?" "No, I didn't say it," and he probably did say it, and he probably talked his way out of it.

Q: Double-talking the girls?

A: Yeah, probably.

Q: Okay. Did you ever see him talk his way out of any situations with cops?

A: No.

Q: Never?

A: We got arrested, but I don't know what he said and what I - what he had said to the police.

Q: What did you get arrested for?

A: We didn't get arrested. We got stopped. A friend of ours got into an altercation with a bus driver. We were on the same bus, and he got - the bus driver got hit, and we got off the bus, and I said, "We should go." And he said, "No. We haven't done anything."

Q: Wait. The bus driver got hit by a car or by a person?

A: No. He got hit by a person.

Q: That you were with?

A: Yeah, that we were with, a high school chum.

Q: Okay.

A: And O.J. suggested that we stay. And it was a good thing that we did because when the police finally came, they were talking to a few of the witnesses there, and they just said, "Well, there was about three or four of them that jumped the bus driver, which was not true, and luckily there was one lady there - no. The first lady, she pointed at us, and this other lady said, "No, they had nothing to do with it," so it was a good thing that we did wait.

Q: And did Simpson actually talk to the cops?

A: Yes. They took us down and questioned us.

Q: Okay. Together?

A: No. They took O.J. in one room and me in the other.

Q: Okay. As a result of the conversation that you had with the cops, you weren't arrested. Correct?

A: No. Neither one - either one of us wasn't arrested. We were let go.

Q: Okay. And how old were you at that time?

A: I guess about 17.

Q: Okay. What other times did you see Simpson talk himself out of situations?

A: No, a lot of times O.J. wouldn't have to talk himself out. I mean, O.J. was very liked by the teachers and by the students, and if he got into a problem, they would call him down and sit and talk with him, and all would be forgotten. We used to tease him about it.

Q: Tease him about what?

A: That, you know, if we ran the ball like he did, we probably would get off, too.

Q: You think he was shown a little preference because of his football ability?

A: Oh, yes.

Q: Okay. Did you consider him a very smooth talker also?

MR.LEONARD: Objection.

THE WITNESS: No, not really. I mean, you know, he was - for what O.J. accomplished there at Galileo and what - you know, O.J. wasn't a bad person.

BY MR. KELLY:

Q: I am not asking that. Actually what I am asking you is: In response to a question, you said you had seen Simpson talk himself out of lots of situations.

A: Yeah, he talked himself with me or with anybody. I mean, O.J. is a great kidder. He likes to have - he likes to, you know, to do things for a 1augh.

Q: Were there times he got you ticked off?

A: He'll pull a practical joke on me or something like that.

Q: All right. I guess in general you considered him a good talker, though. Would that be fair to say?

A: Yeah, O.J. -

MR. LEONARD: Objection, vague.

BY MR. KELLY:

Q: I am sorry?

A: He could talk.

Q: Good talker?

A: He could talk.

MR. LEONARD: Objection.

BY MR. KELLY:

Q: Now, at USC and with the Bills, I assume you got to know Simpson's temperament very well -

A: Yes.

Q: - in terms of on the football field and off it. Is that correct?

A: Yes, uh-huh.

Q: Could you describe his basic game day temperament to me?

A: Very low key, quiet, didn't show a lot of emotion, and he just turned it up - I mean turned - his performance did most of his talking. O.J. -

Q: Okay. He wasn't -

A: No, he wasn't a boisterous person. He wasn't, "Hey, we got to get going" or "Let's get fired up" O.J. stayed within his self.

Q: Okay. Even for big games?

A: Even for big games. That's - that helps, you know, because when things are on the line and every - you know, most guys are very emotional, but O.J. always stayed within, kept a calmness about him, and everybody gelled around that.

Q: Okay. Was he always in control prior to starting the game?

A: Yeah, seemed to be.

Q: And always the same even temperament?

A: Yeah.

Q: Always calm,

A: Uh-huh.

Q: Always cool?

A: Uh-huh. Yes. I'm sorry. Yes. Yes.

Q: Okay. And in your opinion was always in control?

A: Yes.

Q: What about in actual game situations, and I am talking about once a game had started, was he always under control during these periods also?

A: Seemed to be. And I played defense; he played offense, so I wasn't out there on the field in the huddle, so I don't know exactly what was going on in the huddle, but from appearance-wise, from the sidelines and from when he came off the field, he was all - you didn't know if he was hurting or you didn't know if he was upset. He just kept up a very -

Q: Would it be fair to say he was always even keeled?

A: Yes.

Q: Okay. Wasn't a big talker?

A: No.

Q: Okay. Kept most things to himself during the games -

A: Yeah.

Q: - also?

A: Uh-huh.

Q: Okay. Did his performance -

A: His performance was extremely - you know, he did his job.

Q: Okay. And that did his talking for him: His work on the field?

A: Yes.

Q: Okay. Would it be fair to say that he was a go-to player also in clutch situations?

A: Yes.

Q: Okay. Had a good set of nerves?

A: Yes.

Q: Very good set of nerves?

MR. LEONARD: Objection. Leading. Vague.

THE WITNESS: I don't know about nerves, but he was a great performer.

BY MR. KELLY:

Q: Okay. You never saw him lose his cool in a tight situation on the field, did you.?

A: I haven't, no.

Q: Okay. Would you consider him quick thinking?

MR. LEONARD: Objection. Vague.

THE WITNESS: He could think.

BY MR. KELLY:

Q: Would you consider Mr. Simpson a quick thinker?

A: When you say quick thinker, what are you saying?

Q: Well, good reactions to situations.

A: On the field?

Q: Yeah.

A: Well, you can't think on the field. You think, the game - the play is over. You have got to react.

Q: You react. Would you consider him a good reactor?

A: Yeah, his reactions were very good.

Q: Okay. And in post-game situations, could you describe his general temperament to me then?

A: Even keel.

Q: Win or lose?

A: I mean, he was upset if they lost. I mean, you know, nobody likes to lose.

Q: Right.

A: But he didn't show any more emotions than out of the ordinary.

Q: Okay. Would it be fair to say that he had extraordinary foot speed?

A: He was very fast.

Q: Okay. Strong hands?

A: Yes.

Q: Okay. He wasn't a fumbler, was he?

A: He did fumble.

Q: He wasn't known as a fumbler though?

A: If you get hit, you'll fumble.

Q: Okay. Did he ever drop a pass?

A: Did I?

Q: Did Mr. Simpson ever drop a pass?

A: Yes.

Q: What if I told you Mr. Simpson had testified that he had never dropped a pass that he can recall? Is that true or false?

A: That's -

MR. PETROCELLI: In a game.

BY MR. KELLY:

Q: In a game.

A: Well, he may say it was a bad pass from the quarterback. I don't know.

Q: Or he's got a bad recollection?

A: I don't know.

Q: Okay. You recall him dropping passes in games, don't you?

A: It looked like to me.

Q: Let me ask you, when Mr. Simpson was playing with Buffalo, did you ever see him run right over large linemen, like 300 pound linemen?

A: I mean, some - on some incidents you have no choice. I mean, he's gotten - he has taken some licks.

Q: Yeah. Have you ever seen him give some licks, too?

A: Yeah, you got to. You know, you got to be able to defend yourself.

Q: I am asking, did you ever see him run right over a defensive lineman?

A: O.J. was more elusive than bowl over somebody. That wasn't his style.

Q: Did you ever see him do it, though?

A: I've seen goal-line situations, short-yard situations where you only need two or three yards, where he'll go up the middle. It wasn't too many people that could take him on one-on-one in the open field.

Q: Did you ever see him shed linebackers or cornerbacks that got hold of him?

A: If they don't got a good hold onto him, he could break their tackle.

Q: Okay. Do you recall, other than his knee injury at the end of his Buffalo career, where he ever missed a game due to an injury?

A: I only played three years with him in Buffalo, so I don't know prior to - I mean after that what happened. I knew in my three year - the three years I was there, he suffered a knee injury that put him out for the rest of the season.

Q: Other than that knee injury, do you remember him missing any other game due to an injury?

A: Like I say, I was only there for three years, so I don't know what happened after that.

Q: But I'm saying, during those three years, other than that knee injury, do you remember any other time he missed a game due to an injury?

A: I don't remember.

Q: Okay. Simpson didn't baby himself at all during football, did he?

A: "Baby," what do you mean by that?

Q: Baby himself. Like would he play through the pain, or would he take himself out if he was hurting at all?

A: O.J. was very strong, very - had great endurance.

Q: Would it be -

A: Carried the ball a lot. Couldn't have been a baby if he carried the ball a lot.

Q: Would he generally carry it 30 or more times a game?

A: I don't know the exact number, but he carried the ball a lot.

Q: Okay. And your general impression was he wouldn't just pull himself out whenever he was hurt a little bit or not feeling good?

A: During the course of a battle, you know, you don't have time to think, so you do what you have to do. That's your job.

Q: Playing on adrenaline?

A: Yeah.

Q: Okay. Do you recall when Marquerite moved out of Rockingham and O.J. moved in there?

A: I guess that would have been in the fall of '79, I guess.

Q: Do you have a general recollection of that time period?

A: I don't know the exact date.

Q: But it was end of '79, early '80, when -

A: Yeah, something like that, I guess.

Q: Okay. And do you recall whether Nicole moved into Rockingham at that same time?

A: I couldn't tell you if she moved exactly right in, but I know eventually she did.

Q: Within a year?

A: It could have been.

Q: Okay. Did you spend a lot of time there at Rockingham after Nicole and Simpson were living there?

A: Yes.

Q: Okay. You played a lot of tennis there during that time period?

A: Yes.

Q: Okay. Could you tell me who Nicole and Simpson's inner circle of friends were during that time period, now that they were in Rockingham?

A: '79... I don't know the time frame. I mean, like I said, there's a lot of people that O.J. is acquainted with and friends with that would frequent the house -

Q: I know, but did he not have -

A: I would say -

Q: Go ahead, Mr. Cowlings. You were saying something.

A: I don't know if it was '79 or '80 or '81[Names Deleted] when she came into town, her boyfriend, who - I don't know his name, they basically went out - when him and Nicole moved into the house, they would basically go out with other couples.

Q: Can you think of any other couples, other than [Names Deleted]and Kardashians maybe?

A: It came across - I don't know if Chris and Bob was married then. It could have been. I know they were friends. Bob was a close friend of O.J.'s. I mean, as years went on, I mean, there was other couples. Are you still talking about that particular time frame?

Q: Yeah, when they moved in, before they got married and before Sydney.

A: There was quite a few people that have come and gone, you know.

Q: I am talking about that time period, if you can remember anybody else.

A: That's - those are the ones that stand out to me.

Q: Okay. Did you include the Kardashians in that?

A: I was trying to - I don't know if Bob and Chris were married then. That I couldn't tell you. I couldn't tell you because the only ones I'm familiar with that I know that they would go out was the ones that I just mentioned.

Q: Okay. After Nicole and Simpson got m married in '85, do you know whether their group of friends changed at all then?

A: No, it seemed like it stayed the same. I mean, it was always new friends. People were always - you know, wanted to be associated with O.J.

Q: Okay. Can you think of any other couples that sprung up later on in the '80s besides the Kehoes and Schwartzes -

A: They were together for eight years, so there's a lot of - you know, I think [Names Deleted]. Business associates of his that O.J. has done business with over the years, I guess when they came into town with their wives, you know, either stayed there or would be - you know, if they were there for a week or two weeks - I mean a weekend, you know, they would come by O.J.'s and they would go out to dinner.

Q: Do you know when Simpson first became friendly with Marcus Allen?

A: Would have been - Marcus was an athlete at USC. I don't know if O.J. helped in recruiting Marcus to USC.

Q: Did you?

A: No, I didn't.

Q: Okay. Did you know Allen when he was at USC?

A: Yes. As a matter of fact, I was introduced to him at O.J.'s.

Q: Okay. Did you ever work with the USC team after you had retired from pro football?

A: I did some help in recruiting at the time when they allowed alumnae to help out. Then after SC came under -

Q: The good old days?

A: Hey, I thought you were from the Midwest.

Q: I am. Someone told me to say that. They whispered it to me.

A: No. Then SC got into trouble with the recruiting violations; they was on probation. So you can't do any of that now.

Q: Okay. Getting back to Allen, do you recall when you first met him?

A: It would have probably been around that time, but I don't know if he was a sophomore or freshman, but I remember meeting him. He would come by O.J.'s.

Q: Okay. So he knew Simpson during that time when he was at USC?

A: Yes.

Q: Okay. And did you see him often there during his playing days at USC?

A: Yeah, Marcus would come around, and him and I became friends.

Q: Okay. Have you maintained that friendship to this day?

A: Yeah.

Q: Okay. When was the last time you spoke to him?

A: I haven't spoken to Marcus in two or three months, I guess.

Q: Okay. Have you ever had any conversations with Marcus regarding Nicole since the murders?

MR. RE: Excluding that period?

MR. KELLY: Excluding that period.

MR. RE: Want to -

THE WITNESS: Yeah.

MR. KELLY: Want to take a break?

MR. RE: Yeah.

THE VIDEOGRAPHER: This is the end of tape No. 1 of Volume I. The time is approximately 1l:43 and we are off the record.

(Discussion held between the witness and counsel outside the hearing of the reporter.)

THE VIDEOGRAPHER: We are on the record. The time is approximately 11:46. This is the beginning of tape No. 2 of Volume I.

BY MR. KELLY:

Q: Can we have the last question read back to Mr. Cowlings, please.

(Pending question read as follows:

Q. Okay. Have you ever had any conversations with Marcus regarding Nicole since the murders?)

THE WITNESS: Yes.

BY MR. KELLY:

Q: And could you tell me when the first time you talked to Marcus Allen after Nicole's murder was?

MR. RE: Excluding the time period we're talking about.

MR. KELLY: Excluding the time period.

THE WITNESS: I told Marcus that I knew of his relationship with Nicole, and I was speaking to him as a friend, because I said, "There's a strong possibility, Marcus, that her friends know, and it may come out in court. Would you want [Name Deleted] to find out through the papers, or better that you tell her."

BY MR. KELLY:

Q: Okay. When did you have this conversation?

A: This would have been, I don't know, a couple weeks after.

MR. RE: Sort of at the end of the period of exclusion.

MR. KELLY: We just made it?

MR. RE: You're just under the wire.

MR. KELLY: We snuck in with this conversation, fortunately.

Q: Were you talking to him in person?

A: Yes.

Q: And where did this meeting take place?

A: .At a friend's house.

Q: Okay. And who was the friend?

A: [Name Deleted].

Q: Okay. [Name Deleted] was a longtime friend of yours, wasn't he?

A: Yes.

Q: Okay. And he is along-time friend of Simpson's also?

A: Yes.

Q: Was he a long-time friend of Marcus Allen's?

A: He hasn't known Marcus as long as he's known O.J. and I.

Q: Okay. Marcus is a lot younger than O.J. and you also, isn't he?

A: Yes. Right.

Q: Okay. [Name Deleted] is a big USC supporter?

A: He's a friend.

Q: Okay. But you knew him through a USC connection, didn't you?

A: Yeah, we got introduced to [Name Deleted] my first year at SC.

Q: Okay. And who was present at this conversation between you and Marcus?

A: Just Marcus and I.

Q: [Name Deleted] wasn't present there?

A: No.

Q: Do you know who else was in the house -

A: It was outside. I'm sorry.

Q: Who was present in the house besides [Name Deleted] when you had this conversation?

A: Marcus and I were outside.

Q: Okay. In the driveway?

A: Excuse me?

Q: Where outside the house?

A: By the corrals, horse barn or horse corrals.

Q: Okay. And how did it come about that you were meeting at [Name Deleted]' house?

A: There was a family function there for [Name Deleted].

Q: Okay. And you had been invited by [Name Deleted]?

A: Yes.

Q: Okay. And Marcus had been invited?

A: Him and [Name Deleted], yes.

Q: Okay. Had you talked to Marcus after the murders and prior to this day you saw him there?

MR. RE: Well that would obviously be within the time of exclusion, so I am advising him to assert a privilege as to any conversation before that day.

MR. KELLY: Okay. Starting June 12th?

MR. RE: For about a period of two weeks. We are not sure when this is, but we are letting this one come in.

MR. KELLY: Okay.

Q: Now, what was - how long did you talk to Marcus for?

A: We talked for - I don't know how long. I didn't want to draw any suspicion from anyone there. You know, we just -

Q: But you and Marcus were talking alone, the two of you?

A: Yes.

Q: And you were out by the corrals alone?

A: Right.

Q: Okay. And how long were you out there for?

A: Could have been maybe 15, 20 minutes.

Q: Okay. What did you talk about other than the fact that you knew that he had been having an affair with Nicole?

A: What he was going to tell his wife.

Q: Okay. What did he tell you he was going to tell his wife?

A: He was somewhat - he was just bothered, upset, probably confused.

Q: Did you also talk to him at that time about who may have murdered Nicole?

A: No.

Q: Did you ever discuss Mr. Simpson at all with Marcus that day?

A: No.

Q: Did you ever discuss whether Mr. Simpson had murdered Nicole and Ron Goldman, at all with Marcus that day?

A: No.

Q: Is it your testimony today that you had no discussion with Marcus regarding the facts and circumstances around Nicole's murder, that day?

A: No.

Q: Yes, that is your testimony?

A: That day, yes.

Q: Okay. After that day can you tell me the next time you spoke to Marcus Allen?

A: I spoke on the phone a few times from Kansas City.

Q: Okay. Did you call him or did he call you?

A: We called each other.

Q: Okay. Could you tell me the substance of those conversations?

A: I don't remember.

Q: Did you ever discuss his relationship with Nicole in any of those conversations?

A: Not since that day.

Q: At [Name Deleted]' house.

A: Right.

Q: Did you ever discuss with Marcus Allen Mr. Simpson's possible involvement with the murders of Nicole and Ron?

A: No.

Q: You've never had that conversation with him to this day?

A: When you say "involvement," how are you saying that?

Q: Have you ever had any conversations with Marcus Allen in which you discussed - either you or Marcus discussed Mr. Simpson's possible involvement in the murder of Nicole Brown Simpson?

A: When you say "involvement," as he being accused?

Q: No. Of him committing the murder.

A: No, not to my recollection. I remember we may have spoke about the death of Nicole and O.J. being accused.

Q: Okay. Did Marcus ever indicate to you at any time that he thought Mr. Simpson had murdered Nicole?

A: No.

Q: Did you ever express to Marcus Allen at any time that you thought Mr. Simpson may have murdered Nicole?

A: No.

Q: Okay. When was the last time you spoke to Marcus Allen?

A: I spoke to him I guess about maybe two months ago, maybe a little longer.

Q: Okay. Did you call him, or did he call you?

A: He called me.

Q: Do you know where he called you from?

A: No.

Q: Do you know whether he was in Los Angeles -

A: No, I take that back. He called, and I wasn't home. He left a number, and I called back. It could have been in Kansas City.

Q: Okay. Could you tell me whet that number was?

A: No, I don't remember it.

Q When you say, "He left a number," how was it left for you?

A: "Hey, man, this is Marcus. How you doing, blah, blah, blah, ·Hoping to catch you."

Q: Was this on an answering machine?

A: On my voice mail, yeah.

Q: Okay. Would you be able to recall that number now on your voice mail still?

A: No.

Q: Could you tell me what Marcus Allen's address in Kansas City is presently?

A: No, I couldn't tell you. I don't know his address.

Q: Do you know whether he is living in Kansas City or Los Angeles?

A: I don't think he's in Los Angeles.

Q: Why don't you think that?

A: I don't think Marcus has been back to Los Angeles.

Q: Why not?

A: You have to ask him that.

Q: I am asking you why you don't think he's been back -

A: I have no -

Q: You've got to let me finish my questions, Mr. Cowlings. Why do you not think he's been back to Los Angeles?

MR. RE: Wait a second. Are you asking him what Marcus' motivation is, or why is it that he believes he is not here?

MR. KELLY: I am asking Mr. Cowlings from his own personal knowledge why he believes Marcus Allen is not in Los Angeles now.

MR. RE: Do you mean why Marcus Allen is not coming back, what his motivation is -

MR. KELLY: No, I didn't say anything about -

MR. RE: - or why he thinks that he is not present in Los Angeles?

MR. KELLY: No. I am just asking him why he personally has an opinion that Mr. Allen is not residing in Los Angeles at this time.

MR.RE: Why does he think he's someplace else?

MR. KELLY: Yeah.

Q: Why do you think he's some place other than Los Angeles? Thank you, Mr. Re.

A: I wouldn't know. I mean, I don't know what reasons Marcus-his reasons for not being here.

Q: I am not asking the reason why. Just do you know for a fact he is not living in Los Angeles right now?

A: He's not here.

Q: How do you know he's not here?

A: Because he hasn't been here.

Q: How do you know he hasn't been here?

A: I think he would have called me and said, "A.C., I'm in town."

Q: Okay. So that's the basis for thinking that he is not in Los Angeles -

A: Right.

Q: - because he hasn't called you?

A: Right. Okay.

Q: And you don't have a number to reach him here in Los Angeles?

A: His house - the house he owns is still here.

Q: And where is that?

A: It's in Pacific Palisades.

Q: Okay. And what street is that on?

A: It's on - it's right off of Amalfi. I forget the name of the street. Starts with a V, I think.

Q: Do you have it written down somewhere?

A: No.

Q: You know it by sight?

A: Oh, yeah.

Q: Okay. But you don's keep Marcus' address anywhere?

A: I may have written it down some time ago but not recently.

Q: Would you have it somewhere still, since you wrote it down a while ago?

A: His address?

Q: Yes.

A: It could be in an old phone book of mine.

Q: Would you be able to provide it to your attorney, Mr. Re, and he could provide it to us within a reasonable period of time?

A: The police has my phone book.

Q: They do. And that's where it'd be?

A: I would assume if it's written down, it would be in my old phone book.

Q: Okay. You haven't written anything, since that other phone book was seized by the police, in terms of Marcus Allen's address or phone numbers?

A: I have numbers which - I had to recoup a lot of the numbers that I was unable to get because they still have my phone book.

Q: Okay. So have you started a new phone book?

A: I have pieces of papers.

Q: Okay. Do you have a piece of paper somewhere with phone numbers for Marcus Allen?

MR. RE: Let me do it this way: He will check. If we find it, we'll give it to you. Is that all right?

MR. KELLY: Okay. Address and phone number.

MR. RE: Whatever he has, I mean, we will give it to you. What we are doing now is chasing around whether he has it. I don't think he knows whether he has it.

MR. KELLY: Okay.

Q: Is that all right with you, Mr. Cowlings?

A: Yes, sir.

Q: Okay. Do you know any place that Allen would stay in Los Angeles, other than the house we were discussing before, when he's here?

A: No.

Q: Okay. Do you - have any mutual friends of yours and Allen's told you they have seen him in Los Angeles in the last couple of months?

A: No.

Q: Have any mutual friends of yours and Allen's told you anything about Allen's whereabouts the last couple of months?

A: I spoke with [Name Deleted] from Phoenix. They were over in Phoenix playing golf. That was a few weeks ago.

Q: Do you know where they were in Phoenix?

A: At some hotel.

Q: Was it the Phoenician?

A: That could have been.

Q: Okay. And you think that was within the last few weeks?

A: [Name Deleted] had called me, and she needed to get some information and wanted me to help her, and I said okay, and I called her back and gave her the information.

Q: Did you have any other discussions with her regarding her husband at all?

A: No.

Q: All right. Do you recall in 1992 when Nicole moved out of Rockingham?

A: Oh, you still asking the question?

Q: Yeah.

A: In 1992?

Q: Yes.

A: When she moved out of Rockingham?

Q: Yeah.

A: To where?

Q: To Gretna Green.

A: Yeah, I guess if that was the time when she moved out, yes.

Q: Okay. And she and Simpson were going through a divorce during that time period also?

A: Yes.

Q: Could you tell me whether Simpson changed the people he started hanging around with after 1992 when he and Nicole were going through the divorce?

A: I don't know. You talking about friends of the two of them or - I don't know.

Q: He alone. Do you know who he started spending time with during the divorce and right afterwards?

A: O.J. was in and out of town a lot because of his -

Q: New York?

A: - New York connection with NBC and his other commitments.

Q: Would you see him when he came into town?

A: We didn't see a lot of each other because O.J. is really - was into golf at the time, so he was either on the golf course or out of town. We would talk periodically, "Hey, man," if we did talk, you know, "When you get some free time, let's have dinner," or some thing like that.

Q: You don't play golf at all?

A: No.

MR. KELLY: This might be a good place to stop or go for a half hour, either way.

MR. LEONARD: Sure, whatever.

MR. KELLY: Anybody have an opinion on that?

MR. BREWER: Let's stop here.

MR. KELLY: Okay.

THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 12:00 o'clock.

(At the hour of 12:00 p.m., a luncheon recess was taken, the deposition to resume at 1:00 p.m.)

(At the hour of 1:00 p.m., the deposition of ALLEN COWLINGS was resumed at the same place, the same persons being present with the exception of Mr. Robert Blasier.)

THE VIDEOGRAPHER: We are back on the record t now, and the time is approximately 1:00 o'clock.

EXAMINATION (Resumed)

BY MR. KELLY:

Q: Good afternoon, Mr. Cowlings.

A: Good afternoon.

Q: I had been asking you earlier some questions about Lou, Judy and Denise Brown, and I just wanted to ask you a few more about the Brown family. Do you recall when you first met Dominique Brown?

A: It all had to be - let me see. No, I can't remember exactly when I met Dominique.

Q: Okay. Was it in the same time frame that you got to know the other Browns, Lou and Judy, 1979-1980 period?

A: It could have been before I actually met the parents.

Q: Okay. And could you describe what kind of person Dominique is?

A: Nice.

Q: Okay. Ever have any problems with her yourself?

A: No.

Q: Okay. And she was there when you would spend time at the Brown house sometimes?

A: Yeah. Yeah.

Q: Okay. And she would stop at Rockingham on several occasions, too?

A: Yes.

Q: Okay. Did Dominique ever indicate to you at any time prior to June 12th,1994 that she disliked Mr. Simpson?

A: No.

Q: Did she ever indicate to you at any time prior to June 12th,1994 that she was ever angry at Mr. Simpson?

A: No.

Q: Was there any time after June 12th,1994 that Dominique indicated to you that she thought Mr. Simpson had murdered Nicole?

A: I think one incident down at the Browns' house, she - in her - she said something to me, and it made me to believe that she believed O.J. is responsible.

Q: Do you recall -

A: But I can't tell you exactly how she worded it. It wasn't like she asked me directly. I was talking to someone else, and she said something.

Q: Do you recall what she said?

A: Not exactly what she said, but it led me to believe that she felt that O.J. is responsible.

Q: Okay. How long ago was this?

A: This was quite a while ago.

Q: Was this during the course of the trial?

A: Not that I remember.

Q: Okay.

A: It would have had to be one of the weekends or one of the days I came down to see the kids or do something with the kids.

Q: Okay. And with regard to [Name Deleted], you know her also?

A: Yes.

Q: You got to know her in that same time frame we've been discussing?

A: Yes.

Q: Okay. And did you always have a good relationship with her?

A: Yes.

Q: Did she ever make you feel that you weren't welcome at the Brown house?

A: No.

Q: Did she ever give you any indication that she didn't like Mr. Simpson?

A: No.

Q: Ever indicate to you that she was angry at Mr. Simpson for any reason?

A: No.

Q: Has there been any time since June 12th, 1994 where she indicated to you she thought Mr. Simpson murdered Nicole?

A: No.

Q: Okay. Could you tell me when you first met Nicole?

A: Whatever year O.J. and her met, I probably met her - I think I went to - no. I think I met Nicole at [Name Deleted]'s with O.J.

Q: Okay. Do you know what year that was?

A: Whatever year they met.

Q: Okay. Had - when you met her at [Name Deleted]'s, had she and Simpson already started dating?

A: I assume so, yes.

Q: Okay. Do you know where she was living at that time?

A: No.

Q: Okay. Do you know where she was working at that time?

A: No.

Q: Did you ever see her in The Daisy?

A: O.J. told me that's where he met her: At The Daisy.

Q: Okay. Did you ever go there with Simpson?

A: I would go there myself.

Q: Okay. Had you ever seen Nicole in there?

A: No.

Q: Do you remember seeing people like [Name Deleted] in The Daisy?

A: At night - excuse me. You said at The Daisy?

Q: Yeah.

A: Yeah, The Daisy was a popular night spot.

Q: Okay.

A: And I would frequent The Daisy at night.

Q: Okay. All right. Do you know how old Nicole was when you first met her?

A: I think O.J. told me she was 18.

Q: What type of person was Nicole then?

A: Quiet, nice, quiet. Didn't say too much.

Q: Did you enjoy talking to her, though?

A: You couldn't talk to Nicole. She didn't talk that much.

Q: You didn't talk to her at all?

A: She wasn't a woman with a lot of words. She was somewhat shy. I would say she was shy a lot at that time.

Q: Okay. Did she open up later on in life in terms of -

A: After you spent time with her, you know. I mean, it wasn't like she was distant or anything. She was just a shy person. And we probably got better acquainted when we were down in the Caribbean because her and I, we spent a lot of time together when O.J. was filming. We were down there for quite a long time.

Q: When was the first time you went down there with her?

A: Pardon?

Q: When was the first time yon were down in the-

A: The Caribbean?

Q: - Caribbean?

A: In '78, the year '78. I was still playing with the Rams, and O.J. was working on a film there.

Q: Do you know what film he was working on at that time?

A: FIREPOWER.

Q: Okay. And after she opened up a little bit, did you enjoy talking to Nicole then?

A: Yeah. She was a pleasant person. She was always very, very pleasant.

Q: Okay. Did she seem to be interested in your life also?

A We were friends. I mean, she didn't ask me, you know, what I was doing, but we were just friends. It was just an average relationship at the time.

Q: Okay. Did she like to laugh?

A: Yeah. She was - O.J.'s a - has a great sense of humor, and, you know, we've had some good laughs.

Q: Did she like to dance?

A: Yeah.

Q: Was she athletic?

A: Very.

Q: Okay. What sports did you see her playing?

A: Tennis. I would help her with her tennis game. Nicole was a doer. Whatever Nicole put her mind to, she could do, and I always admired that about her.

Q: Okay. By the way, did you ever see her riding bikes?

A: Yes.

Q: Okay. Down in the Caribbean?

A: I don't remember if she rode a bike down in the Caribbean.

Q: Do you know if she had a bike up in Rockingham?

A: Yeah, all of - yeah, there was bikes there.

Q: Okay. Did you ever see her riding one?

A: I think so. And she had a baby seat on hers. I guess her and O.J. had bikes. I mean, they had bikes together.

Q: Okay. Did there come a time that Nicole moved to San Francisco?

A: Her and O.J. was inseparable a lot of - every time I - most of the time I saw O.J., he was with Nicole. They traveled -

Q: Well - I'm sorry.

A: They traveled a lot together, and when he ended up with the 49ers, she moved with him.

Q: Okay. And she was living with him up there?

A: Yes.

Q: Did she have her own place up there?

A: No. O.J. had a condo, and she lived with O.J.

Q: Okay. How long did they live up in San Francisco at the condo?

A: During the season for the two years he was there, they lived there in San Francisco together.

a: Do you know where Simpson would live in the off-season then?

A: Back in Los Angeles on Rockingham.

Q: He -

A: No, no. Back on Rockingham, but they - she had an apartment here.

Q: Nicole did?

A: Matter of fact, they maintained - think she maintained her apartment here in Los Angeles.

Q: Okay. Do you know if Simpson ever rented a place during that time period before he moved into Rockingham down in LA.?

A: For hisself?

Q: Yeah.

A: Not that I know of.

Q: Okay. So as far as you know, he would either stay in Nicole's place or at Rockingham?

A: As far as I know.

Q: Okay. Would you go out with them socially at all when they were up in San Francisco?

A: Yeah.

Q: Okay. See them regularly?

A: Yes.

Q: Okay. Were you dating anybody at that time?

A: When I was playing - you talking about the period when I was in San Francisco playing for the 49ers?

Q: The period when Nicole and O.J. were living up in San Francisco.

A: Yes, I was dating a young lady.

Q: And what was her name?

A: I don't know. Slips my mind.

MR. PETROCELLI: What years are we talking about?

THE WITNESS: It would be '79. No. '6 - no, '79. When did I retire? '79. Yeah, '79.

MR. RE: Time flies.

THE WITNESS: You telling me.

BY MR. KELLY:

Q: You can't think of the first name of that lucky young lady you were dating back then, Mr. Cowlings?

A: I don't know how lucky she was, but my memory slips on that one.

Q: How long did you date her for?

A: Quite a while. I was heartbroken.

Q: More than a year?

A: Yeah.

Q: And you can't remember her name?

A: No. It's tough times.

Q: Any old love letters you might have or something -

A: No.

Q: - that might refresh your recollection?

A: No.

Q: Telephone directories?

A: No.

Q: Just draw a blank on that name?

A: It'll probably come to me. I'll pass it on to Donald when I -

Q: I might ask you again later.

A: Okay.

Q: Okay?

A: All right.

Q: You let me know any time during this questioning, though, if you think of it. Okay?

A: Okay.

MR. RE: You're going to make him rake over these old sorry loves, huh?

MR. KELLY: Very reluctant about that one.

Q: When Nicole was living with Simpson up in San Francisco at the condominium, do you remember any argument between them that you witnessed?

A: There was one argument I remember.

Q: And what was that?

A: I don't know. It was something - she was messing with him or doing something. I don't know. They were in the bedroom. I was in the front room watching TV.

Q: And what did you hear?

A: I didn't hear. Nicole came out.

Q: And what did she say?

A: She was just sitting there, and I could tell that she was upset about something. She just had a, you know, look on her face.

Q: She didn't say anything to you?

A: No. She just said - I said, "What's wrong?" And she just was tightlipped and just shook her head.

Q: Did you ever talk to her again after that about what had happened that day?

A: No.

Q: Did you ever talk to Simpson after that about what had happened that day?

A: Well, I heard some commotion in the bedroom.

Q: When you say a "commotion," was it voices you heard?

A: No. No. When her and I were up front, and this is a while - I don't know - a few minutes had went by, and I see that she didn't want to, you know, talk, so she sat there with me watching TV. Then I heard some commotion in the - towards the bedroom in the condo.

Q: When she was up watching TV with you -

A: Right.

Q: - you heard a commotion?

A: Uh-huh.

Q: You don't know what the commotion was?

A: Oh, yeah, I know because I went back to investigate it.

Q: And what was it?

A: O.J. was - I heard some - when I opened the door, he had just closed the bathroom door. Then I opened the bathroom door, and the window was up, and then I looked out and her clothes were three stories down, laying over her car.

Q: Okay. He had chucked her clothes out the window?

A: Yeah.

Q: Okay. Did you say anything to him at that point?

A: I asked him what was he doing.

Q: And what did he tell you he was doing?

A: He said, "None of your business."

Q: What else did you say to him after that?

A: I said he was crazy.

Q: Did he look crazy at that time?

A: No. I just said, "You crazy," and I went downstairs and picked everything up and brought it back up.

Q: Okay. How did he - could you describe his appearance to me when you walked in the bathroom?

A: Seemed like he was upset, too.

Q: Well, how did he physically appear to you?

A: Mad, somewhat. To what level, I have no idea because I was just - when I realized what he had done when I looked out and saw her belongings over - laying on top of her car, I went downstairs and got them.

Q: Were the clothes anywhere other than on top of the car?

A: I mean, they had fallen on the side.

Q: Did you see where he had gotten the clothing from?

A: No.

Q: Did you say anything to him other than, "You're crazy?"

A: I just said, "You're crazy"; just you know, went downstairs.

Q: Did Nicole go downstairs with you?

A: No.

Q: Do you know whether it was all the clothing she had in the apartment?

A: I have - no, I don't know if it was everything she had.

Q: What did you mean when you told Mr. Simpson he was crazy?

A: I said he's crazy for throwing her clothes out. I mean, "You're crazy."

Q: You think that was a little unusual?

A: It's very unusual.

Q: You ever in all your experiences ever seen a friend of yours chuck clothes out the window before?

A: I've seen some friends go off on their spouses or arguments. You know, guys do - you've been in - well.

MR. RE: He's from the Midwest.

THE WITNESS: He's from the Midwest. He's been married all his life, married his high school sweetheart. No, but it was an unusual situation. I've never seen him and Nicole in that frame before.

BY MR. KELLY:

Q: Okay. And how long had they been dating at that point?

A: They had been dating a while. It had been over a year, a year and a half or so.

Q: Had you heard anything Simpson said prior to you walking in the bathroom?

A: No.

Q: And Nicole had not said anything to you when she walked -

A: No.

Q: - out of the bedroom?

A: Uh-uh. She was tight-lipped and just shook her head when I asked her what was wrong.

Q: Did you see any bruises on her?

A: No.

Q: Any signs whatsoever of a physical altercation with Simpson -

A: No.

Q: - when she walked out of here?

A: No.

Q: Okay. How long did it take you to gather the clothes outside?

A: It took me a while. You know, clothes, I had to pick them up and try to put them in a manner so I could carry them, you know, back up.

Q: Do you recall whether there was like underwear out there?

A: I don't know. It was just clothes. Could have been.

Q: I mean, it wasn't just like one outfit, was it?

A: No, it wasn't one outfit, no.

Q: Okay. And when you brought them upstairs, you brought them back up three flights yourself?

A: Yeah, I brought them back. It's a long flight of stairs.

Q: When you were outside, did you see anybody else outside there?

A: No.

Q: Do you know what time of day this was at?

A: It was at night.

Q: How late?

A: I don't know. If I was still - could have been - probably had to be 8:30, 9:00 o'clock, 10:00 o'clock range, because I didn't stay up that late because I had practice the next day.

Q: Do you know where - Had you been out earlier that evening with Nicole and Simpson?

A: I don't remember.

Q: Do you remember anything you had done that day prior to this?

A: Practice.

Q: Other than that, had you been out to dinner with them?

A: I can't remember if we had dinner or if I ate out somewhere by myself or if what they - eat at home or whatever.

Q: Do you know whether Simpson had been drinking at all?

A: I doubt it.

Q: Do you know whether he had been drinking at all?

A: I don't know if - no, I don't know if he had a drink, but I - it didn't appear to me that he had been drinking.

Q: Okay. Do you know whether he had done any drugs or not?

A: No.

Q: You don't know?

A: It appeared to me that he hadn't done any drugs.

Q: Okay. What did you do with the clothes after you brought them back upstairs?

A: I brought them back upstairs, folded them, tried to put them neatly back in the living room. When I got back, the two of them were in the bedroom together.

Q: Were they talking?

A: I don't know. I didn't ask. The door was closed.

Q: Did you see them again that night?

A: No. I went to bed.

Q: At their place?

A: Yes.

Q: Okay. And you left the clothes in the living room?

A: Yes.

Q: Okay. Just one minute here.

MR.RE: And I thought we were making such progress.

MR. KELLY: Just looking for something. It's all right.

Q: After that night, did you ever discuss this incident again with Mr. Simpson?

A: I think maybe at practice I may have mentioned something.

Q: Do you recall what you said to him?

A: "Man, you know, what was all that about?"

Q: What did he tell you?

A: Nothing.

Q: He never told you why he chucked all her clothes out the window?

A: No. It's all forgotten, I guess.

Q: Did you ever talk to Nicole again after that?

A: No, uh-uh.

MR. RE: You mean about that.

MR. KELLY: About that.

THE WITNESS: No, uh-uh. I just left it alone.

BY MR. KELLY:

Q: In what year did Mr. Simpson retire? Do you recall?

A: '79, 1979.

Q: And did he move back to Los Angeles after that?

A: I stayed in San Francisco for another six months. I was working - I was going through a mining program with Levi Strauss, so I stayed at their condo the whole time I was there.

Q: At Simpson's condo -

A: Right.

Q: - after he moved out?

A: Uh-huh.

Q: Okay. And was Nicole still living in her Westwood place at that time?

A: I don't know. Like I said, I stayed; I didn't come back. When the season was over, I was accepted to try - to start the training program with Levi Strauss, so I was up there for six months.

Q: Okay. Do you know whether Marquerite was still living in Rockingham at this point?

A: I really don't know.

Q: Okay.

A: I was traveling. They had me going into Oregon and Seattle and stuff, so I didn't know what was going on down in L A. that much.

Q: Okay. So you didn't spend much time with Nicole end Simpson before they -

A: After -

Q: - before they moved into Rockingham and after the '79 season?

A: No, they hadn't moved back into Rockingham, because I remember O.J. - they must - okay. O.J. had rented a house up on Stone Canyon. That's what - yes. They didn't move into - they moved into a house in Stone Canyon.

Q: And this was after the '79 season?

A: Yeah. When I came back down to L A., that's where he was living.

Q: Okay. So at the end of the '79 season, Marquerite was still in Rockingham?

A: As far as I know. You know, like I said, I was in San Francisco, and when I came down - came back to Los Angeles, moved back to Los Angeles, O.J. and Nicole were living at - rented a house up in Stone Canyon.

Q: Okay. And Marquerite, as far as you know, was still in Rockingham?

A: If that's where she was staying, yes.

Q: Okay. After Simpson - Do you know when Marquerite moved out of Rockingham, by the way?

A: Whenever her period was up for her to be in the house.

Q: What was your understanding of when her period was up?

A: I don't know. I know she - that's why he couldn't move into the house right away, because she - whatever stipulations they had in their agreement, she was to stay in the house.

Q: Was it your understanding that once their divorce was final, she had to move out of Rockingham?

A: I don't know the particulars of it. All I know, she had the house up until a certain part of time.

Q: And then she permanently moved out.

A: Right.

Q: And she had to leave with the two children.

A: Yeah.

Q: Okay. And he moved in by himself.

A: Or Nicole moved in with him.

Q: Okay. Did you spend much time there after they - Nicole and Simpson moved into Rockingham?

A: Yeah, I occasionally would be by there.

Q: Were you there in this period I am talking about, between 1980 when they moved into Rockingham -

A: Uh-huh.

Q: - and 1985 when they finally got married? Did you spend much time there at Rockingham?

A: Yes.

Q: Okay. Did you - were there times during this '80 to '85 period you discussed with Simpson his intentions of marrying Nicole?

A: I didn't discuss them. If O.J. volunteered to say, "I'm going to marry this girl one day," you know, I didn't - I was - whatever O.J. was - you know, they were going together, you know...

Q: Well, did you ever discuss the relationship he had with Nicole, with Simpson?

THE WITNESS: No, uh-uh. I just left it alone.

BY MR. KELLY:

Q: In what year did Mr. Simpson retire? Do you recall?

A: '79,1979.

Q: And did he move back to Los Angeles after that?

A: Yes.

Q: After the season in '79, do you recall where he moved back to?

A: It didn't need to be discussed. I knew both of them loved each other.

Q: But he never talked to you separately about Nicole?

A: Yeah, that he loved her.

Q: And that's all you ever talked to him about?

A: Basically that's - you know, how wonderful she was, she was his best buddy and, you know, he was very grateful to have her in his life, and she was everything to him, she - her whole world was O.J., and they got along great together.

Q: Through this whole time period, '80 to '85?

A: Yeah.

Q: Okay. Never saw any arguments there?

A: I wouldn't say arguments. I would probably say disappointment on Nicole's part.

Q: Because she wanted to get married?

A: No. I guess because O.J.'s womanizing.

Q: During this 1980 to '85 time period?

A: Yeah.

Q: He was still dating other women?

A: Yeah, I guess. He was, you know, being - I know one incident she saw him, and I thought - she supposedly, I guess, drove up on him and he was standing on a corner I guess talking to a girl, and Nicole got very upset about it.

Q: What did she do?

A: I think she threw a picture frame at him or something like that.

Q: And this was before they were married?

A: Probably, yes.

Q: And did Simpson tell you about this incident?

A: No. Nicole did.

Q: Did she tell you why she threw a picture frame at him?

A: I guess she thought he was flirting with this - with a girl, with this girl.

Q: And Nicole didn't like that?

A: No. Would you?

Q: I don't know. I'm asking you.

A: No, uh-uh.

Q: Do you know who, if anybody, Nicole - I mean Simpson was dating during this period besides Nicole?

A: Uh-uh. No. I'm sorry. No.

Q: Did you ever see him with any other women, other than Nicole, during this time period?

A: No.

Q: Okay.

A: When you say "seeing," like on a regular basis, the same person?

Q: No. Out on a date. Did you ever see Simpson on a date with someone other than Nicole?

A: No, I wouldn't see him on a date. He may flirt with a girl, say, "Hey know, you look nice," or something like that, if I was in his company, but it wasn't like, "A.C., come with me. I got this date" or "I'm going to see this other girl," no.

Q: That never happened.

A: I wouldn't be around it.

Q: Why is that?

A: Because I like Nicole.

Q: And Simpson knew you'd never tolerate it, also?

MR.LEONARD: Objection. Lack of foundation.

THE WITNESS: Well, if I wasn't around there, I couldn't say anything.

BY MR. KELLY:

Q: Okay. In this period between 1980 and 1985 before they got married, do you know of any time that Nicole and Simpson broke up?

A: Yeah. Yeah.

Q: More than once?

A: Yes.

Q: Okay. Could you tell me the first time this was?

A: I don't know the first time. It became a - somewhat of a joke. I'm not trying to make it out as a funny situation, but I was the one always called either by O.J. or Nicole to help her move her stuff, so -

Q: Did you use a Hertz man, by the way?

A: No. No. I told them, if they kept that up, I was going to go into the moving van business. So she would go back home to Laguna.

Q: Let me ask you specifically, when was the first time, if you can recall, that they broke up after 1980 when they moved into Rockingham,

A: The only one that stands out in my mind was that particular day of when she drove up on O.J., because I was at the house playing tennis -

Q: With whom?

A: I forgot who I was playing with - and Nicole pulled up and - no. The phone had rang. He had an outside phone. The phone had rang. I went over and picked it up, and it was O.J., and he said, "Is Nicole there?"

Just as I said - I went to go say "no," Nicole pulled up in her car, and I said, "Yes, she just pulled up."

And he said, "Ah, man," he said, "Ah, A.C., man, she thinks I was flirting with this girl, and it's not so."

I'm saying - I'm like - I mean, because all of this was new to me. I don't know.

So he said, "Let me speak to Nicole." And I said, "Nicole, you want to speak to O.J.?"

She says-can I use the word?

MR. PETROCELLI: Please.

THE WITNESS: "F**k O.J.," you know, such and such, "I'm outta here."

And that was the most memorable - mean, that's the one that stands out in my mind.

BY MR. KELLY:

Q: Okay. Let me ask you a couple of questions. First of all, when you say O.J. had an "outside phone" -

A: Out by the tennis court.

Q: Okay. Was there a cabana there for the pool and tennis court?

A: Yeah, uh-huh.

Q: Okay. And was that part of the phone system?

A: Yes.

Q: Okay. Other than the cabana, were there other places outside that he had phone jacks that you can recall?

MR. LEONARD: During this time period?

MR. KELLY: During this time period.

THE WITNESS: Not that I know of, except the phone on the front gate, but that phone don't - only work to buzz to let somebody know that's somebody outside.

BY MR. KELLY:

Q: Okay. You don't know of any phone outlets out on the terraces that he had?

A: No, I don't remember.

Q: Okay. And how far would the cabana be from the main house?

A: It's in between the tennis court and the main house. Exact1y how far, I don't know.

Q: Okay. And do you recall what type of car Nicole drove in on that day when she came in the driveway?

A: She may have had her Mercedes then. He had bought her a Mercedes.

Q: And what color was that?

A: A white.

Q: Okay. Was that a little one?

A: Yeah, a little one.

Q: Convertible?

A: Convertible, yes.

Q: Like a 450? Do you recall?

A: The sports model. If that's the number on it yes.

Q: The two-seater?

A: Yeah, two-seater.

Q: Okay. And do you recall what color the top was on that?

A: Tan. Sandy, tan, brown.

Q: Okay. And after she made that statement of "F**k O.J.," did she actually knock the phone out of your hands?

A: No, no, no, no, no. When I - she wasn't by - she had just pulled up in the driveway.

Q: Okay.

A: And when O.J. said, "Let me speak to her," I said, "Nicole, O.J. want to speak to you." From there she said, "F**k O.J."

Q: So you yelled from the cabana over to the driveway?

A: I said, "Nicole, O.J. wants to speak to you."

Q: Uh-huh. After she said that, what happened next?

A: I said, "O.J., she don't want to talk to you."

Q: Okay. Did you talk to Nicole after that?

A: She got her stuff and went to Laguna.

Q: Were you there while she was packing?

A: She didn't pack a lot of stuff. She just, you know, took her stuff, and she says, "I'm through with it," you know, and she went to Laguna.

Q: Did you help her pack?

A: I think I did, yeah, because she took a lot of her stuff and - because I remember later on in the week O.J. was - I mean, because Nicole was so - did everything there -

Q: What do you mean, she "did everything"?

A: I mean, she cooked; you know, the kitchen was arranged how she wanted it to be, and he couldn't find anything, and he couldn't even find a can opener to open up a can of soup.

Q: Wasn't much of a cook?

A: No.

Q: Okay. What was - do you recall any specific conversation you had with Nicole before she was leaving for Laguna?

A: I think - I guess she expressed that she was tired of O.J. fooling around with girls, I guess.

Q: That's -

A: I don't know exactly, but I know that was a topic. I mean, that's what was her problem at that time with him.

Q: Do you recall what year that was?

A: No.

Q: Do you recall approximately how long they had been living at Rockingham when this incident took place?

A: I could say they'd been living there for a while.

Q: Over a year?

A: Yeah, I would think so.

Q: Okay. And when Simpson came home, did you discuss the incident with him?

A: I think I had left by that time.

Q: Did you - was there a time after that that you discussed -

A: I'd go by and check on him, see if he had starved to death or something like that. You know, he was - so at that time I think he was trying to talk Nicole back.

Q: Did he tell you anything more about the incident that occurred that day?

A: From what he told me, it wasn't the way it looked, the way Nicole said. I wasn't there, so I don't know exactly what went down.

Q: Did you repeat to him the conversation you had with Nicole about she'd had it with him and his womanizing?

A: Yeah, I think so. I probably did say something to him about it.

Q: Do you recall what his response was to that?

A: I have no idea. I can't remember.

Q: Okay. Do you recall Simpson discussing with you his decision to finally marry Nicole?

A: Probably, because he asked me, you know, to stand up for him.

Q: You were his best man?

A: Yeah, Jason and I.

Q: Okay. Going back to this one incident where Nicole grabbed her clothes and went down to Laguna, where did she go down to Laguna?

A: I guess to her parents.

Q: Okay. That was your understanding of where she was going?

MR. LEONARD: Objection. Calls for speculation.

THE WITNESS: I don't know exactly. I just assumed that's where she was going. Where she went exactly, I don't know. I just assumed that's where she went.

BY MR. KELLY:

Q: Okay. Do you know when she moved back to Rockingham after that?

A: I don't know.

Q: Do you know when the next time you saw her was?

A: No

Q: Was it at Rockingham?

A: Yeah.

Q: Did you talk to her any time in between the time she had left that day and when she was back at Rockingham?

A: I think I met with her one time. She had called me, and we met down - at that time it wasn't Mezaluna. It was Georges VII Pietro?

MR. RE: Yes.

THE WITNESS: Yeah, that's when he had it. And we met, and she was missing O.J., and-

BY MR. KELLY:

Q: How long had she been out of Rockingham for?

A: I don't know.

Q: More than a week?

A: Could have been. Could have been more. Could have been less. I don't know exactly.

Q: I'm sorry to interrupt you. You were -

A: I'm used to you.

Q: - talking about the meeting.

A: We met, and she missed him, and I was encouraging her to say - you know, I say, "Hey, if he's that sorry, have him come down to Laguna to get you." You know, "Wait till he comes down here to apologize to you."

Q: Did she indicate that he had been calling her?

A: I guess. I assumed they had been talking.

Q: And did she tell you what he had said to her?

A: No.

Q: Okay. What else did she say to you at that meeting?

A: By that time O.J. pulled up.

Q: I am sorry. Where were you talking to her again?

A: At the restaurant.

Q: And where was this restaurant?

A: Where Mezzaluna is now.

Q: In Brentwood.

A: In Brentwood, yes.

Q: In Brentwood?

A: Uh-huh.

Q: And who had decided on that place to meet at?

A: I think we both did. She wanted me to get her something. There was something at the house she wanted, and so I went and got it for her.

Q: Okay. And she had driven up from Laguna?

A: I don't know if - she met me there. Where she came from, I don't know.

Q: Okay. All right. And were you having lunch there or dinner or...

A: No. We met there, and I guess maybe I was eating something or maybe having a drink or a Coke or something like that.

Q: And you were sitting inside.

A: Yes, we were sitting inside facing San Vicente.

Q: Okay. And how long were you there with her for?

A: 5 minutes.

Q: Okay. And other than her saying she wanted to get back together with O.J., what else did she tell you?

A: Well, no, she didn't say she wanted to get back. She was just saying how much she missed him.

Q: Okay.

A: You know, and they had talked on the phone. I don't know how many times they talked, but they had been talking.

And so I say, "Well, stay strong." You know, "Wait till he comes down there and apologizes."

Then before we knew it, I looked up and there he was in his car. He pulled up. So she -

Q: Did - go on. I'm sorry.

A: No. Go ahead. You go ahead.

Q: No. I want you to go first, Mr. Cowlings.

A: No. You go ahead.

Q: He pulled up in the car and?

A: Nicole looked at me. I looked at Nicole. She smiled. And then he kind of like - I guess he asked her to come there, and she did.

Q: Do you know whether she had driven up to the restaurant that day?

A: I don't know for sure.

Q: Did you ever see her car outside the restaurant?

A: No.

Q: Did you ever tell Simpson you were meeting her that day?

A: No.

Q: Did she indicate to you that she had told Simpson she was meeting you there that day?

A: No. I was led to believe that O.J. didn't know she was up there, because she had asked me to get - I forgot what it was she wanted me to get from the house, but I got it for her, so it was obviously she didn't want O.J. to know.

Q: Okay. How long prior to meeting her at the restaurant had you been at Rockingham?

A: I don't know.

Q: Did you go straight from Rockingham to the restaurant?

A: Oh, you - oh, yes. I went by to get what she wanted and went to meet her.

Q: Was Simpson at the house when you went by there?

A: No, I don't think so. I don't think he was there.

Q: Okay. Was Michelle there?

A: I don't know if Michelle was the maid at that time. No, it wasn't. I think Michelle came later on. It was some other maid.

Q: Okay. Was anybody else there when you went by there before meeting Nicole?

A: I can't remember if anybody else was there.

Q: Did Simpson indicate to you how he knew you two - that the two of you were in that restaurant?

A: To this day I don't know how he knew that.

Q: Where was your car parked?

A: I guess on the street where I parked it.

Q: Okay. And he had already parked and was coming in when you saw him?

A: Pardon?

Q: Had Simpson already parked his car -

A: No, no, no, no, no. O.J. pulled up in his car, and we were sitting on the San Vicente side, and we looked up and there he was. He was still sitting inside his car, double - I guess either the red zone or he had pulled up double to the car that was parked to the curb.

Q: And you never told him you were going there?

A: No.

Q: Okay. Now, after that did Nicole move back into Rockingham?

A: They left together.

Q: Okay. Did they spend any time in there talking with you there?

A: No. She got in the car, and they went on about their business.

Q: After this incident you said there were a number of occasions that Nicole left O.J. during this time period, '80 to '85?

A: It was occasions that, you know, because of his womanizing, that she would get upset and go home.

Q: All right. Can you tell me another specific incident when you were there and this happened?

A: I don't remember exactly. Like I said, that one incident stood out in my mind, but -

MR. KELLY: I am sorry. Are we picking up sound all right from Mr. Cowlings?

THE WITNESS: No. Sometimes I cross my arms.

MR.KELLY: Because the mike is down low, too; that's why.

It's fine? Okay. I'm sorry. Could you read the last question, please.

(Pending question read as follows:

"Q. All right. Can you tell me another specific incident when you were there and this happened?")

THE WITNESS: What happened?

BY MR KELLY:

Q: Nicole and Simpson had a fight.

A: Oh, I never saw a fight.

Q: Argument.

A: Arguments?

Q: Well, strike that. I had asked you and you had indicated there were other times that Nicole left because of Simpson's womanizing?

A: Uh-huh.

Q: Okay. Could you tell me the other specific times this happened?

A: The only one I said that stands out in my mind is that incident that happened at that particular day.

Q: Do you remember any other time where Nicole actually packed her clothes and left there?

A: I can't give you a definite answer on that. It's just that one stood out in my mind. There was other times that her - she would move - go to Laguna. You know, she, you know...

Q: Did you talk to her about any of those incidences?

A: No I would just tease her about me moving her.

Q: So there was more than one time you helped her move out of Rockingham.

A: I helped her move out of her apartment -

Q: In Westwood?

A: - in Beverly Hills. No.

Q: Okay.

A: Because I moved a lot of her stuff to O.J.'s house. So I helped her, you know, whenever she needed help.

Q: Okay. But there were other occasions, other than this one, before they got married when Nicole moved out of Rockingham, were there not?

MR LEONARD: Objection. Leading.

THE WITNESS: Like I say, it happened. She had - I don't know about moving. Maybe she had left the house and went to Laguna.

BY MR. KELLY:

Q: Were you there any of the times she actually left Rockingham?

A: The only one that stands out in my mind is that one I told you about.

Q: Okay. Do you have any recollection of conversations you had with Nicole on other occasions when she had left the house?

A: I wouldn't talk to her from - if she had left to go to Laguna, I wouldn't be talking to her, no.

Q: You never called her down at her parents' house -

A: No.

Q: - down there?

A: No.

Q: Okay. Do you recall how many times you helped her move out of Rockingham -

A: No.

Q: - before they got married?

A: Uh-uh.

Q: Do you recall how many times she herself left Rockingham before they got married?

A: No.

Q: Would it be more than two times?

A: I have no knowledge of it.

MR. LEONARD: Objection.

BY MR. KELLY:

Q: You indicated before there was more than one occasion when she left.

A: Yeah, I couldn't - like I said, I can't give you a direct number on how many times it happened. It could have happened once. It could have happened twice. It could have happened three times. I don't know.

Q: Well, we know it happened once. Correct?

A: We know that.

Q: Okay.

A: And that's the only one that stands out in my mind.

Q: But you indicated there had been other times that you knew of she left the house, did you not?

A: I knew I had helped her move. Now, it could have been the time I helped her move her stuff from Beverly Hills to Rockingham. I can't pinpoint - you see, I know - if I - I wish I could give you a direct answer, but I don't know it.

Q: I am asking you very specifically, after Nicole had moved into Rockingham, how many times she left Rockingham and went elsewhere?

A: I don't know.

Q: You know of the one specific time she left Rockingham and went elsewhere. Correct.?

A: Yes.

Q: Do you know of any other time she left Rockingham and went elsewhere?

A: I know of her going. I don't know how many times she has gone.

Q: Okay. Was it more than twice?

MR. LEONARD: Objection.

THE WITNESS: I can't give you that answer. I don't know, sir.

BY MR. KELLY:

Q: Well, you indicated earlier that you and Nicole would sort of joke about your moving Nicole, did you not?

A: Right.

Q: So there were enough occasions where she moved out of Rockingham where it was at least a topic of conversation between the two of you.

A: I had -

MR. LEONARD: Objection. Argumentative.

THE WITNESS: I'm sorry. Go ahead.

MR. KELLY: I am sorry. Could you read the question back?

(Pending question read.)

THE WITNESS: It was more of a standard joke with Nicole and I.

BY MR. KELLY:

Q: And that was the joke about her leaving Simpson?

A: Or packing up, yes.

Q: To -

A: I can't tell you how many times that - because I don't know.

Q: Okay. But it was a standard joke between you and Nicole -

A: Right.

Q: - about her pecking up to leave Simpson.

A: Packing up to leave, yeah, Rockingham.

Q: Okay. Where Simpson was living.

A: Where the two of them were living.

Q: Okay. You indicated you were best man at their wedding?

A: Yes, Jason and I, his son Jason. We both stood up.

Q: Were there any ushers in addition to you and Jason there?

A: Yes.

Q: And who were they? Do you recall?

A: Marcus Allen, [Name Deleted], Ahmad Rashad, Skip Taft, I think. I don't know if his brother was down here, Truman. I don't know. It could have been...Those are the ones that come to mind.

Q: Okay. And after they were married did you spend a lot of time at Rockingham still with O.J. and Nicole?

A: They went on their honeymoon.

Q: After they got back from their honeymoon and for the next several years, would you be at Rockingham?

A: I would come by, yes.

Q: Okay. By the way, did you discuss with Nicole her getting married to O.J. after O.J. proposed to her?

A: I don't know. I don't recall any conversation. I mean, they were getting married.

Q: You never discussed this with Nicole separately, about her getting married to Simpson?

A: Discuss what?

Q: The fact that she was getting married to Simpson finally.

A: They made the announcement. I assumed that they were getting married. There was no need to discuss it - discuss to her about their marriage.

Q: Prior to that announcement did Nicole ever express frustration to you that she and Simpson were not married yet?

A: Not to me.

Q: She never indicated to you she wished she was married to Simpson?

A: Not to me.

Q: Okay. Was there any time prior to the wedding that Simpson indicated to you his frustration that Nicole wouldn't marry him?'

A: Not to me.

Q: You never got any indication from either one of them that they had wanted to get married prior to the time they did?

A: No, not to my knowledge. I mean, they went together for eight years. They lived there together. You know, they were happy, so...

Q: Did you ever live at Rockingham.'

A: I would stay there on periods. Like I said, early on, when the house was under construction, they were back East, so I oversaw the grounds.

Q: Okay. Where did you stay when you were there at Rockingham

A: In the guesthouse.

Q: There are two guest rooms, are there not?

A: At that time it was just the one.

Q: Do you know when the second guest room was put on the house?

A: When they - I think when he had all the work done to the house. I think the other guesthouses - I mean the two bedrooms were added on. They could have been there before. I don't know.

Q: The guest room you stayed in, is it your understanding that's the same guest room that Kato Kaelin was staying in in June of 1994?

A: Yes.

Q: Okay. When you were staying there, you never heard any thumps on the wall out back, did you?

A: No, sir.

Q: Okay. Did you ever go back behind that room?

A: Yes.

Q: And when was that?

MR. RE: If we're talking about -

THE WITNESS: A number of times.

BY MR. KELLY:

Q: Okay. Could you tell me the last time you were out behind that room?

MR. RE: Again, we are excluding the period -

THE WITNESS: Okay.

BY MR. KELLY:

Q: Well, let's be more specific. Do you recall the last time before June 12th,1994 that you were out behind that guesthouse?

A: No.

Q: Did you ever chase the kids back here at all in playing with them?

A: No. When I would - when Nicole and O.J. would go out of town, I would - and they would ask me to look after the animals, the cats and the dogs, and I would - Cheba, the biggest dog, had a rash on its neck, and I had to keep him separate from the other dog. So I would take him back there, and there was a little fence that I could keep him from getting with the other dogs to give the wound a chance to heal.

Q: Okay. Was that up at the laundry room there?

A: No. It's along - it's - you could - I guess the gate is still there. I guess it's about three or four feet high. And I just, you know, closed him back there. So he had the full run along that back way to the back.

Q: And was that gate next to the garage there and driveway?

A: No. It was more close to the - I would think, if my memory doesn't slip me, I think its closer to the laundry door. It could be, yeah.

Q: Okay. And what was at the far end of that runway, then, to keep the dog from getting out?

A: Pardon?

Q: What was at the far end of that runway to keep the dog from getting out of that run?

A: If you walk directly and went all the way to the back of the house, there's like an open area back there, and it's all fenced off, so there was no way for him to get out.

Q: Okay. Did you ever play games with the kids, Sydney and Justin, over at the house there?

A: Yes.

Q: Did you ever play hide-and-go-seek?

A: Yes.

Q: Did you ever go looking for the kids back there ever?

A: I don't remember.

Q: Okay. And going back to my previous question, could you tell me approximately the Last time you were back there prior to June 12th, 1994?

A: I couldn't tell you. I don't remember.

Q: Was it within a year?

A: I don't remember.

Q: Okay. Could you tell me, after June 12th,1994 when, if ever, you were behind that room?

MR. RE: Excluding the period.

MR. KELLY: Well, I would like to know during that period if he was back there.

MR. RE: Well, we will assert the privilege to that.

BY MR. KELLY:

Q: Was there any - I think we had this discussion. I think your client would have to assert the privilege.

Was there any time after dune 12th, 1994 that you went to look behind that guesthouse?

MR.RE: Are you asking him the previous question, if it was between - if you ask him a specific question, was he there during the period, then you can get the privilege -

MR. KELLY: Well, I'm going to ask him very specifically -

MR. RE: - and then you can go to a time after that, after he asserts the privilege to that.

BY MR. KELLY:

Q: Okay. Was there any time between June 12th and June 14th that you had occasion to go behind that guesthouse?

MR. RE: I would -

THE WITNESS: No.

MR. RE: Okay.

THE WITNESS: No.

BY MR. KELLY:

Q: Okay. Was there anytime between June 14th and June 17th you had occasion to go behind that guesthouse?

A: I'd say no.

Q: Okay. Was there any time between June 17th and July 1st you had occasion to go behind that guesthouse for any reason?

MR. RE: Let me just ask you a question because I want to make sure I have my dates right: What was the date that Simpson surrendered?

MR. KELLY: 17th.

MR. RE: So you are asking for the period following the time of his -

MR. KELLY: I am trying to put it - you said "two weeks," so I am going June 17th to July 1st.

MR. RE: Which is the two-week period following the -

MR. KELLY: The surrender.

MR. RE: - surrender. Let me just talk to him for a second.

THE WITNESS: That give me - I could talk to him, and then can I go to the restroom?

MR. KELLY: Yeah.

MR. PETROCELLI: Sure.

THE WITNESS: Okay, thank you.

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

1:51. (Discussion held between the witness and counsel outside the hearing of the reporter.)

(Recess.)

THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 2:07.

MR. KELLY: Could you read the last question back?

(Pending question read as follows:

"Q. Okay. Was there any time between June 17th and July 1st you had occasion to go behind that guest house for any reason?

THE WITNESS: Yes.

BY MR. KELLY:

Q: Okay. And what date was that, if you recall?

A: It was well after the 17th.

Q: Okay. And before July 1st?

A: I couldn't give you a direct date.

Q: Okay. But somewhere between June 17th and July lst, 1994 -

A: Most likely, yes.

Q: - you had occasion to go back there? And what was the reason for your going back there?

A: I wanted to observe it and look at it for myself.

Q: Okay. Did anybody accompany you back there?

A: My first time I went back?

Q: Well, when was the first time you went back there?

A: First time I went back was on my own. The second time I went back there was with the investigator that I had spoken with early on.

Q: At the Marriott?

A: Yes.

Q: Had you already had the meeting at the Marriott with this investigator?

A: Yes.

Q: Now, the first time you went back there, it was within this two-week period we're discussing?

A: Yes. Could have been. After the 17th.

Q: And what was your purpose specifically for going back there?

A: I wanted to see it for myself because everything was said about it and I just wanted to see it for myself.

Q: What had you heard said about that area back there behind the guesthouse?

A: That that's where the glove was found, and the thump on the walls.

Q: Okay. Did you discuss the fact that you were going back there with anybody prior to your first time going back there?

A: No.

Q: Did you ever tell Mr. Simpson you were going back there?

A: No.

Q: Did he ever ask you to go back there?

A: No.

Q: Prior - and the second time you went back there, this was also within this two-week period of June 17th to July 1st, '94?

A: That I don't know. I know I went back there a second time because he wanted me to meet him at the Rockingham.

Q: The first time that we spoke of that you went back there, was it day or night?

A: It was during the day.

Q: And how long were you back there for?

A: Few minutes.

Q: Did you take any pictures?

A: No.

Q: Did you take any measurements?

A: No.

Q: Did you discuss the fact that you had been there, with anybody afterwards?

A: I may have.

Q: Who do you think you spoke to?

A: That I don't know.

Q: When you went there with this investigator the second time, did you go back there during the daytime or nighttime?

A: During the daytime.

Q: And how long were you back there for?

A: A few minutes.

Q: Where did you meet - where did you originally meet the investigator that day prior to going back behind that area?

A: I don't know if he was already there at the Rockingham address or we met at the same time, but I know that's where we met.

Q: Did you come over to Rockingham for that specific -

A: Yes.

Q: Had he contacted you about coming over there?

A: Yeah, that's where he wanted me to meet him.

Q: And did he say for what purpose he wanted you to meet him there for?

A: No, I didn't - no, he didn't.

Q: And the first time you knew you were going back behind the guest house was when you arrived there that day?

A: I don't know if he wanted me to explain to him the layout of the house or - I don't think that was the sole purpose why he had me there: To go to the side of the house. I think he wanted to know the whole layout.

A: Let me ask you, this was the only investigator you had dealt with from Simpson's defense team up to this point?

A: Yes. I spoke to Bill Pavelick maybe one or two times.

Q: Okay. And you don't remember this guy's name?

A: No. He would have - Bill Pavelick, I'm quite sure, can give it to you.

Q: Okay. We will ask him. By the way, did you ever remember your girlfriend's name from San Francisco?

A: No. You caused my sinuses to act up.

Q: Okay. You working on it?

A: I'm working on it.

Q: Okay. Now, when you arrived at Rockingham that day to meet with the investigator -

A: Yes.

Q: - what was the first thing you did when you met with him at Rockingham?

A: I think more or less he was asking me certain things about the layout of the house. He had - I guess he had some notes made out that he was pointing out.

Q: Okay. Was Mr. Re your attorney at that time?

A: Yes.

Q: Okay. Was he aware of the fact that you were meeting with this investigator?

MR. RE: That would call for attorney-client privileged information.

BY MR. KELLY:

Q: Okay. When you met with him, did he have actual diagrams of the house?

A: I don't remember.

Q: Okay. Do you recall how long you were at Rockingham for that day?

A: I don't know how long it was.

Q: More than 10 minutes?

A: Probably 10, 15 minutes.

Q: Okay. Who else was there besides you and this investigator?

A: I think Gigi was in the house. Him and I was conducting what he was - what him and I was doing just between the two of us. There was nobody else present with us.

Q: Do you know if Arnelle was back in the house at that time?

A: No.

Q: Okay. Were there a number of media people there when you went by the house?

A: I don't remember.

Q: Was that investigator living at the house at that time?

A: Not that I know of.

Q: Okay. What did you do when you walked back behind the guesthouse with this investigator, if anything?

A: He just pointed out some things -

Q: What-

A: - the fence -

Q: What did he point out about the fence?

A: How something wasn't - if somebody did come over the fence, something about there should have been some branches broken or the spikes at the top should have been bent over or something like that, and he asked me, "Why would O.J. come over this side?" And I said, "It's beyond me." I mean, to me it would be the last place, if you knew the house, that you would come to.

Q: Okay. And what else did he point out to you?

A: That the spider webs supposedly were intact on the air conditioning.

Q: Were there spider webs there when you were back there?

A:I didn't notice them.

Q: Okay. What else?

A: How narrow the walkway was.

Q: These were things he was pointing out to you?

A: Yes.

Q: Did he know you had spent weeks and months there over a period of years in that guesthouse and over at Rockingham?

A: Probably.

Q: Did he indicate to you why he was pointing these things out to you?

A: He was doing his investigation.

Q: Did he ask you any questions about that area back there?

A: Just pointed out those things.

Q: Okay. Did you tell him anything about that area back there?

A: Not that I could remember.

Q: Did you have any discussions concerning the glove?

A: No.

Q: Okay. Did you take - did he take any photographs back there?

A: I don't remember.

Q: Did he take any measurements?

A: I don't remember.

Q: Do you recall seeing him with a camera?

A: I don't remember.

Q: Was there anybody else there assisting him in any way?

A: No. Not when him and I was there, no.

Q: Okay. When you said it was the last place anybody would come over who knew the place, what did you mean by that?

A: Just there's so many other ways to get to the grounds of O.J.'s house.

Q: What other ways are there?

A: You can come over your neighbor's - his back neighbor's - through his yard, through his tennis court to right into O.J.'s tennis court.

Q: There is a gate that opens there, isn't there?

A: Yeah.

Q: Okay. What other ways?

A: Come over the wall.

Q: Right in front there?

A: Yeah. Anywhere along the long wall.

Q: Along Rockingham.

A: Ash - no. Ashton.

Q: Okay.

A: Ashford.

MR. PETROCELLI: Ashford.

THE WITNESS: Ashford. I'm sorry.

BY MR. KELLY:

Q: Had you ever come over the wall to Ashford yourself?

A: Uh huh. Yes. I'm sorry.

Q: Is there a big tree that comes into the wall there at someplace?

A: Yes.

Q: Is that usually where you would come over?

A: All of us have come over that wall at one time or another.

Q: Including Mr. Simpson?

A:I know Nicole has. I have.

Q: Okay. Have you ever been with Mr. Simpson when he came over the wall?

A: Not that I remember.

Q: Have you ever been locked out of the premises with Mr. Simpson?

A: Not that I can remember.

Q: Okay. The Ashford gate can be released manually with a card, can it not?

A: The Ashford? No.

Q: No?

A: No.

Q: Is there any way to open that gate manually?

A: If you release the latch inside before, you can open it manually.

Q: Okay. Where does that latch have to be released from.?

A: It's on the arm, the bent arm. It's at the end of the arm where the controls sit. There's a little lever you lift up, I think, and that takes it off of the automatic that opens from the house. They punch a keyboard - the telephone.

Q: Okay. Can that be done with the Rockingham gate also?

A: No. You need a key.

Q: From the outside?

MR. PETROCELLI: Was your question whether it can be taken off the manual from the automatic mode at Rockingham?

MR. KELLY: Right.

MR. PETROCELLI: That's -

THE WITNESS: No. He said Ashford.

BY MR. KELLY:

Q: No. And then I asked you whether the Rockingham gate could be taken off the automatic mode in the same manner as the Ashford gate.

A: Oh, yes, it can.

Q: Okay.

A: Yeah.

Q: So either the Ashford gate or the Rockingham gate, if you punch in a code, it can be left on manual release?

A: No, no, no, uh-uh, not a code. Manual, you have to lift up the lever that sits right at the base of the arm.

Q: Okay.

A: And that takes it off of automatic. You go open it up with your hand. But if -

Q: And -

A: Go ahead.

Q: That can be done from inside the gate?

A: That can only be done from inside the gate.

Q: Okay. That can be done with either Ashford or Rockingham?

A: Yes.

Q: Okay. Have you ever done that with the Ashford gate?

A: Yes.

Q: Have you ever done that at the Rockingham gate?

A: Yes.

Q: Okay. When you - I think you indicated - Was there ever a time that you stayed in the guesthouse for any length of time when Nicole and O.J. were living there?

A: Could have.

Q: Okay. Were there many times you spent the night there at Rockingham when they were there?

A: Yes.

Q: Okay. Were there times you spent the night there when Nicole was there and Simpson was out of town also?

A: If Nicole was scared, she would call me and I would stay up there, yes.

Q: Where? In the guesthouse?

A: Uh-huh. Yes. I'm sorry.

Q: Okay, Would it be fair to say that you would see Nicole under her most casual moments when you were staying there at Rockingham?

MR. LEONARD: Object to casual. Vague.

THE WITNESS: What do you mean by "casual"?

BY MR. KELLY:

Q: Well, I mean, would you sit and talk to her right before she was going to bed?

A: Yes.

Q: Okay. Would you see her first thing in the morning when she first got up?

A: Yeah, if we have tea.

Q: Okay. Did you ever do that on occasion?

A: Yeah, I used to drink a lot of tea. She had Sydney to buy me a little tea cup. So Sydney would watch me drink tea.

Q: Okay. And as I asked you before, there were times you would see Nicole first thing in the morning when she came downstairs?

A: Yes.

Q: Okay. Were there ever times you saw blemishes on Nicole's face where she had been, say, picking blackheads or something like that?

A: Nicole would pick at her skin sometimes.

Q: Okay. Did you ever see blemishes as a result of that?

A: I would tease her about it: She should, you know, stop picking at her skin, because it only made it worse. She had a tendency of doing that.

Q: Okay. Did you ever see her cause pronounced markings on her face from picking at blackheads?

MR. LEONARD: Objection to "pronounced."

THE WITNESS: I don't know what you mean by "pronounced." I would tell - because a lot of times Nicole would sit and she'd be picking, and I would like hit her on her hand.

BY MR. KELLY:

Q: Okay. Was it a nervous habit?

A: Yeah, she did that and bit her nails.

Q: Okay. That was a nervous habit also?

A: I don't know nervous. She did it. You know, we all tried to get her to stop.

Q: But I am asking you, with her face, did you ever see, as I said, pronounced marks from her picking at blackheads?

A: I would see her pick, and I would tell her to stop picking.

Q: Were there ever times you just saw her face and could tell she had been picking at it?

A: I can't remember.

Q: Okay. Do you recall when Nicole was pregnant with Sydney? First time she was pregnant after she and O.J. had gotten married.

A: Yeah. Yes.

Q: Okay. Do you recall how you first found out Nicole was pregnant?

A: I think the two of them told me.

Q: Okay. And were you around Rockingham during that period of time when she was pregnant?

A: Yes.

Q: Did you have dinner there sometimes?

A: Yes, or I would come by and do things for Nicole. I didn't want her to lift anything heavy, and I would, you know - Nicole is, like I said, is a doer, and she just - and you got to sit Nicole down. She will, you know, do whatever it is necessary to run that house.

Q: So she wouldn't call you up and ask you to come over and do things for her?

A: Oh, she would call me and ask me to come over, yes.

Q: Okay. Did you know that if you didn't come over, she would probably do them herself?

A: Most likely, yes.

Q: Okay. So would it be fair to say that she just wouldn't do them if someone didn't do them for her, would she?

A: Pardon?

Q: Strike that. That's a horrendous question. Did you ever hear Simpson comment to Nicole about her weight when she was pregnant with Sydney?

A: No.

Q: Ever?

A: No

Q: Okay. Did you ever observe any arguments between Simpson and Nicole when she was pregnant with Sydney?

A: No.

Q: Do you remember the day Sydney was born?

A: Yes.

Q: Did you visit Nicole in the hospital?

A: I was there, yes.

Q: Was Simpson there also?

A: Yes.

Q: And was Nicole excited after Sydney was born?

A: The two of them were.

Q: Okay. When Sydney was born, you had been friends with Nicole for almost 10 years?

A: Yeah. Yes.

Q: Okay. And you had spent a lot of time with her at this point?

A: Yes.

Q: Okay. And you had spent a lot of time with her when Simpson was on the road?

A: I would go by to see if she's okay, of if she wanted me to do something, I would go by.

Q: And you considered her family at that time?

A: Oh, yes.

Q: And she considered you family?

A: Yes.

Q: Okay. Were there times that Simpson confided in you regarding his relationship with Nicole?

A: Confided in me to what level?

Q: Well, just how things were going with him and Nicole, if there were any problems?

A: He was great. It was great. I mean, she was everything he wanted in a woman. She -

Q: Okay. Never complained about her?

A: There was nothing to complain about Nicole.

Q: Okay. He never complained about her.

A: No.

Q: Okay. Were there times that Nicole confided to you about her relationship with Simpson?

A: Sometimes she would voice her displeasure, not knowing - I mean, because of maybe the past, maybe she would question or - I shouldn't say question. She would be under suspicion maybe he was fooling around.

Q: Okay. Would it be fair to say that Nicole trusted you more than probably anybody else she knew?

MR. LEONARD: Objection.

THE WITNESS: That I wouldn't know.

BY MR. KELLY:

Q: Okay. Was there any doubt in your mind as to whether or not Nicole loved you as a friend?

A: We had a good friendship.

Q: Okay. And she loved you?

A: She never told me she loved me, but I know we had a good friendship.

Q: Okay. Did you love her?

A: Yes.

Q: Okay. Is there any doubt in your mind that Nicole would have done anything to help you if you asked her for it?

A: No doubt in my mind.

Q: Okay. And would you have done anything for Nicole if asked to do it, also?

A: Yes.

Q: Would it be fair to say that the entire Brown family also treated you like family?

A: Yes.

Q: Okay. Did Nicole ever disappoint you?

A: Not that I can remember, no.

Q: She ever let you down in anyway?

A: Not that I can remember.

Q: Okay. Now, prior to Sydney's birth in 1986, talking about when Sydney was born all the way back to the time Simpson met Nicole. Now I am going to ask you some questions. Okay?

A: Okay.

Q: So this would be probably from 1977 to '86, about a 10-year period.

A: Okay.

Q: Okay. Other than the arguments we previously spoke about, which would be the incident in San Francisco and the time where Nicole threw the picture at O.J., were there any other arguments you witnessed between -

A: I was told that she threw the picture. I wasn't there, so I don't know if the picture was thrown at him or she just threw it out of the car. I don't know. I was told that.

Q: Who told you that?

A: Nicole told me - O.J. told me first. Then Nicole told me later on.

Q: Okay. But then you were back at Rockingham when Nicole came back there?

A: Yes.

Q: Okay. Other than those two incidences, was there any other time that you observed any arguments between Nicole and Simpson prior to Sydney's birth?

A: No.

Q: Did you ever observe any physical altercations between Nicole and Simpson in this time period up through 1986?

A: No.

Q: You never observed Simpson strike Nicole -

A: No.

Q: - during this time period?

A: No.

Q: Never slap her?

A: No. Not in front of me.

Q: Okay. Ever punch her?

A: No.

Q: Kick her?

A: No.

Q: Push her?

A: No.

Q: Grab her by the arm?

A: No.

Q: Throw her?

A: No.

Q: Okay. Did -

MR. PETROCELLI: The time frame for this series of questions?

MR. KELLY: We are talking about any time prior to Sydney's birth in 1986 now.

THE WITNESS: From the time they met until Sydney was born.

BY MR. KELLY:

Q: Right.

A: Right.

Q: Okay. In the same time period, did Simpson ever tell you of any physical altercation he had with Nicole?

A: No.

Q: In the same time frame, did Nicole ever tell you of any physical altercation she had with Simpson?

A: No.

Q: Okay. Did Nicole ever tell you that - and this is in the same time period still. Did Nicole ever tell that you Simpson had slapped her?

A: No.

Q: Ever tell you that he had punched her?

A: No.

Q: Ever tell you that he had kicked her?

A: No.

Q: Ever tell you that he had pushed her?

A: No.

Q: Cheated on her?

A: Has she ever said that -

Q: Yeah.

A: - to me?

Q: Yeah.

A: Yes, she has.

Q: A number of times?

A: I don't know how many times, but she has, you know, said, you know, she suspected him cheating on her.

Q: Okay. In this same time frame, do you know of any time that Simpson kicked Nicole out of the house?

MR. LEONARD: Objection. Vague as to "kicked...out of the house."

BY MR. KELLY:

Q: Made her leave.

A: Not to my knowledge. If he did, I wasn't there.

Q: Okay. Was there any time after the fact Simpson told you he had kicked her out of the house?

A: I heard of an incident that happened with O.J., Nicole, Denise and [Name Deleted], but I wasn't there, so I don't know what happened.

Q: Okay. Other than that incident, any others?

A: I mean -

MR. PETROCELLI: Same time frame?

MR. KELLY: Yeah, same time frame still.

THE WITNESS: I mean, once he got upset with Nicole. Dominique had came up, and a friend of mine called him to meet Dominique and they - he came over - I had left before he got there, and they went out, and I got a call later on that night; it was O.J.; he was out of town, and woke me up. I don't know what time it was, but it was late. And he called and he said, "Hey, man, what's going on?.

I said, "Nothing man. I'm asleep. What's going on?"

He said - did he ask me where Nicole was? I said, "I don't know. Maybe she went out with Dominique and Tom to" - I think they went out to get something -

BY MR. KELLY: .

Q: Who is Tom?

A: I don't know his last name.

Q: McCullum?

A: No. No.

Q: Okay.

A: This was a young guy. And I introduced the two of them, and I think he invited them out to dinner.

Q: This was someone you had introduced Dominique to?

A: Right. He came by the house to meet Dominique.

Q: And Dominique came up from Laguna?

A: Yes, she was up. I don't know if it was during the week or during the weekend, but she was there, and -

Q: Okay. And where did they meet?

A: There at the house.

Q: At Rockingham.

A: Yes.

Q: Okay. And they left there then?

A: I think the three of them left, Nicole, Dominique and Tom.

Q: Did Nicole know Tom?

A: No. I knew Tom.

Q: Okay. Nicole never met Tom before -

A: No.

Q: - this night? Okay. What year was this?

A: I don't know.

Q: Was it before they were married?

A: I think so.

Q: Okay. What happened next?

A: I got a phone call from O.J. later on that night, wanted to know - I told him I introduced Dominique to Tom, and I guess he took them all out to dinner.

Q: Tom did?

A: Yeah.

Q: Okay. And what was Simpson calling about?

A: I guess he wanted to know. I guess he had called the house, and I guess he found out that Nicole was out or Nicole had been out, and I guess my name must have came up in the conversation, so he called me.

Q: And what else did he say to you other than, "What's going on?"

A: That was it. And I hung up the phone. Then -

Q: Mr. Cowlings, this whole line of questioning started when I asked you if you knew of any other -

A Well -

Q: We're getting to it?

A: You said you were slow. Anyway, I come to find out two days - a day later that an argument had started behind this.

Q: Okay.

A: See, I wasn't - up until when O.J. called me, I just assumed he was trying to find out where Nicole was. I mean, it wasn't no big thing as far as I was concerned.

Q: Okay. And what did you find out a day or two later?

A: That he got upset that she left the house.

Q: Where was Simpson when he called you?

A: He was out of town somewhere.

Q: Do you know where?

A: No.

Q: Who told you the argument started?

A: I don't know if he did or Nicole did. The argument was over the phone.

Q: Between Simpson and Nicole?

A: Yes.

Q: Do you know when that argument took place?

A: No.

Q: Was it that same night later, do you know?

A: I don't know. Like I said, when he called me, he gave me no indication that it was any problems. He was just, you know -

Q: What time of night was it?

A: I was asleep, so I don't know what time it was.

Q: After 9:00?

A: Could have been. Could have been before 9:00.

Q: Okay. And that's all you know about this argument?

A: Yeah, that it started an argument between the two of them over the phone.

Q: Okay. And what about the incident with [Name Deleted], Denise and Nicole and O.J., what were you told about that?

A: That they got into an -

MR. LEONARD: Objection. No foundation.

THE WITNESS: That they got into an argument.

BY MR. KELLY:

Q: That who got into an argument?

A: All four of them.

Q: Who told you this?

A: I think O.J. did.

Q: What did he tell you exactly happened?

A: All of them had been drinking. I think it had something to do with Nicole - O.J. didn't allow any smoking in the house, and it was - that was understood by everybody whoever smoked.

Q: Nicole smoked, didn't she?

A: Right. And Nicole would go outside and smoke.

Q: Did he like that Nicole smoked?

A: No, but -

Q: Did he express the fact that he didn't like that she smoked?

A: He would like her to quit smoking, but he never told her she couldn't smoke.

Q: Would it make sense for him to ever give her, say, a lighter as a present?

MR. LEONARD: Objection.

THE WITNESS: I don't know if he did or not.

BY MR. KELLY:

Q: Okay. Anyway, I'm sorry. Go on with...

A: And the argument started actually, for what I was told, between him and Denise.

Q: Okay. And why did he say the argument started?

A: Because Denise felt that O.J. - I think should allow Nicole to smoke in the house. Nicole - like I said, it was understood if you smoked, you go outside, either off the front door or step off by the pool and do your smoking. When you finish, you came back into the house.

Q: And what is your understanding of what happened this night with regards to smoking?

A: Him and Denise got into an argument.

Q: Did Nicole come inside and start smoking, do you know?

A: That I don't know.

Q: Did someone else come in and start smoking?

A: That I don't know.

Q: Did he tell you what type of argument they had?

A: That they got into an argument, and they left.

Q: And who left?

A: [Name Deleted], Denise and Nicole.

Q: Did he ever tell you he made them leave?

A: No.

Q: Did he ever tell you he physically removed Nicole from the house?

A: No.

Q: Did Nicole ever tell you that?

A: No

Q: Did Denise ever tell you that?

A: No.

Q: Did [Name Deleted] ever tell you that?

A: No.

Q: Did you ever discuss this incident with Denise?

A: No.

Q: Did you ever discuss this incident with [Name Deleted]?

A: No.

Q: Did you ever discuss this incident with Nicole?

A: No

MR. KELLY: Okay. I've got to take a break here.

THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 2:36.

(Recess.)

THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 2:52.

BY MR. KELLY:

Q: Did you ever observe any injuries on Nicole prior to Sydney being born?

A: She fell off the roof once; injured her back.

Q: What roof?

A: Rockingham roof.

Q: Of the house?

A: Yes.

Q: What was she doing up there?

A: Hanging Christmas trees - I mean Christmas lights.

Q: What year was this?

A: Nicole did it every year. She would line the house with Christmas lights, and the fence.

Q: What year did she fall off?

A: I don't know what particular year, but I know she fell off.

Q: She wasn't pregnant at the time she fell off?

A: No.

Q: Okay. Was it prior to her marrying Simpson?

A: I think it could have been.

Q: Okay. Do you know if she went to the hospital for that?

A: Not that I know of.

Q: Were you there when she fell off?

A: No. I found out about it the next day.

Q: Do you know which roof that was that she fell off?

A: No.

Q: Do you know how far a distance she fell to the ground?

A: No.

Q: Do you know whether she stayed in bed at all the next day after that happened?

A: No.

Q: Do you know what type of injury she had has a result -

A: She said her back was stiff.

Q: Did you see her after the fall?

A: Yeah. Not directly after the fall, but I did see her later on.

Q: Like how long after the fall?

A: Could have been a day or two days.

Q: Okay. And she indicated to you her back was still stiff?

A: It was stiff, but Nicole continued to do - you know, not to get back up on the roof. I think after then the gardener - O.J. paid the gardener extra to do that. He didn't want Nicole back up there again.

Q: When you said Nicole was Nicole and you sort of shrugged, you meant little things like that wouldn't bother her?

A: No.

Q: Would it be fair to say that Nicole wouldn't pamper herself?

A: When you say "pamper," like what?

Q: Well, in terms of -

A: Doing her nails and stuff or -

Q: No. In terms of if she had an ache or pain, she wouldn't like go running to the doctor?

A: No, Nicole - Nicole was - motor was always going. You know, she'd work - whatever duties that was to be done around the house, she did. You know, if she had a cold or, you know, she always stayed active.

Q: Okay. It was tough to slow her down, then?

A: Oh, yeah, definitely.

Q: Okay. And she'd - By the way, who told you she had fallen off the roof?

A: She did.

MR. LEONARD: I hate to interrupt, but if we are going to go to 5:00, I have to make a phone call.

MR. KELLY: I don't want to go - actually, I understood the tape is going to be out in about a half hour or so, and why don't we go till that time since we had originally planned on it, anyway.

MR. LEONARD: Okay.

MR. KELLY: We will go to the original quitting time: 3:30.

MR.LEONARD: And then we will stop?

MR. KELLY: Yeah.

MR. LEONARD: Okay.

MR. BREWER: For a break and then resume or stop for the day?

MR. KELLY: Which do you want to do?

MR. BREWER: I can go on.

MR. KELLY: Want to go to about 4:15, 4:30?

MR. LEONARD: Well, then I need to make a phone call right now.

MR. KELLY: Okay.

MR. PETROCELLI: Just make it right now.

MR. BREWER: So we are going to go till 4:30, then?

MR. KELLY: Yeah, go to 4:30.

MR. LEONARD: Well, we need to go off the record for one minute.

MR. KELLY: Okay.

THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 2:56.

(Brief recess.)

THE VIDEOGRAPHER: We are on the record. The time is approximately 3:01. This is the beginning of tape No. 3 of Volume I.

BY MR. KELLY:

Q: Mr. Cowlings, would it be fair to say that Nicole was not someone who would complain about every little ache and pain that she had?

A: Yeah, I would say so.

Q: And would it be fair to say also she wouldn't complain, like you said before, if she had a cold or a headache or something like that?

A: I mean, I would know that she had a cold, but Nicole wouldn't -

Q: She wouldn't put herself in bed, would she?

A: She wouldn't stay in bed for the next three days. No, that's not Nicole.

Q: And if - like you said, when she hurt her back or some injury like that, she wouldn't go running to a doctor right away either, would she?

A: I guess she felt that it wasn't serious enough to go to the doctor.

Q: Okay. And as far as you were concerned, it would take something that at least Nicole would perceive as serious before she would see a doctor for an ache or pain or injury?

A: I would think so, yeah.

Q: She was a very athletic person?

A: Yes.

Q: Fitness conscious?

A: Yes.

Q: Okay. In good shape?

A: Yes.

Q: When you first met Nicole, would it be fair to say that Simpson was your closest friend?

A: Yes.

Q: Okay. And when Simpson moved into Rockingham in 1980, would it be fair to say that Simpson was your closest friend then?

A: Yes.

Q: And when Nicole and Simpson got married in 1985, would it be fair to say that Simpson was still your closest friend?

A: Yes.

Q: And in '92 when Nicole and Simpson divorced, was Simpson still your closest friend then?

A: Yes.

Q: Okay. And in 199 - Well, strike that. You're aware of the fact that in 1993 Nicole and Simpson reconciled again, got back together?

A: I don't know if that was the year, but -

Q: You know they got back together -

A: Yes.

Q: - after the divorce? Okay. And you were still Simpson's closest friend during this time period?

A: Yes.

Q: And as of even June 12th, 1994, Simpson was your closest friend?

A: Yes.

Q: Okay. And as you sit here today and testify, would it be fair to say that Simpson is still your closest friend?

A: Yes.

Q: Okay. And as you sit here today, would it be fair to say that in your mind you are O.J. Simpson's closest friend?

A: In my own mind, yes, I would think so, yes.

Q: Okay. Has Mr. Simpson ever lent you money in the past?

A: Yes.

Q: Do you always pay that back?

A: Sometimes.

Q: Okay. Did you ever run into some financial difficulty with the place you had off [Address Deleted] when you lived in LA.?

A: [Address Deleted]?

Q: [Address Deleted] Road?

A: [Address Deleted] Road, no. I never lived on [Address Deleted].

Q: Did you ever own a condo?

A: No.

Q: No?

MR. RE: On [Address Deleted] Road?

THE WITNESS: I don't know what he's talking about.

BY MR. KELLY:

Q: Near [Address Deleted] Road.

A: No.

Q: Did you ever own a place that Mr. Simpson and [Name Deleted] had to buy from you?

A: Yes.

Q: Okay. Where was that located?

A: That was on [Address Deleted].

Q: [Address Deleted].

A: Right.

Q: And was that a condominium?

A: No. A duplex.

Q: A condominium duplex.

A: No. A duplex. That's what it's called: a duplex.

Q: Out West here?

A: Right.

Q: Okay. Was it a single-family detached structure?

A: It's two units. One unit I lived in; the other unit I rented out.

Q: Sort of like the Bundy place that Nicole lived at at the end: Attached units?

A: I didn't know that her place was attached.

Q: Okay. All right. But there came a time when Mr. Simpson and [Name Deleted] bought that from you?

A: Yes.

Q: Okay. What year was that?

A: It would have been in the - I don't know - the mid '80s, late '80s, I think.

Q: And you always felt that Mr. Simpson would help you if you needed it?

A: Yes.

Q: Okay. And would it be fair to say that you'd always be there to help Mr. Simpson if he needed it?

A: Yes.

Q: I believe you described Nicole earlier as a nice person?

A: Yes.

Q: Okay. And you still stand by that testimony?

A: Yes.

Q: Did you know her always to be an honest person?

A: Yes.

Q: Did you ever know her to be deceptive in any way?

A: Not that I can remember.

Q: Did she ever lie to you?

A: She never had a reason to.

Q: Did she ever lie to you?

A: Not that I know of.

Q: Okay. Do you know if she ever lied to anybody else?

A: That I don't know.

Q: Was Nicole the kind of person that would make things up?

A: I have no knowledge of that.

Q: Did she strike you as someone who would make things up?

MR. LEONARD: Objection. Vague.

THE WITNESS: I have no idea.

BY MR. KELLY:

Q: Okay. Did you feel you could trust her?

A: Yes.

Q: Was Nicole a good mother?

A: Great mother.

Q: Great mother. In what ways was she a great mother?

A: Her kids were everything to her. She really took - she really took to motherhood, and her kids were very important to her.

Q: Was she very involved in their lives?

A: Yes, she was.

Q: Was she very organized with their lives?

A: Yes, she was.

Q: Did she make sure they had everything they needed?

A: That's right, yes.

Q: Give them all the attention they could ever want from a mother?

A: Yes.

Q: Okay. Was she a good wife?

A: Yes.

Q: Great wife?

A: She was a good wife. She was.

Q: Okay. Always good to Simpson?

A: Yes.

Q: Very supportive of him?

A: Yes.

Q: Very protective of him?

A: Yes.

Q: Know of any incident where she ever deceived him?

A: Not to my knowledge.

Q: Ever cheated on him when they were married?

A: Not to my knowledge.

Q: Ever lied to him?

A: Not to my knowledge.

Q: Okay. Was Nicole always sensitive to Simpson's public image?

A: When you say "sensitive," what do you mean?

Q: She would never have done anything to embarrass him, would she?

A: Not that I know of.

Q: Was she very good about keeping the children out of public scrutiny?

A: I think her and O.J. both agreed on that.

Q: Okay. Do you know whether she kept the kids active in kids' activities?

A: Yes.

Q: Justin always engaged in sporting activities?

A: As he got older. They were so active around the house because the grounds of the house was geared to the children, the play area out in front, so -

Q: And who had set it up that way?

A: O.J. and Nicole.

Q: And would Nicole always participate with the kids in what they were doing?

A: Yes.

Q: Play ball with them?

A: O.J. would. Nicole would be watching. Both of them were active with the kids.

Q: Okay. Going to a different time period now, which would be after Sydney was born, okay, did you ever observe any arguments between Nicole and Simpson?

A: You said prior -

Q: No. Now we are talking about after Sydney's birth.

A: There was an argument during the construction of the house.

Q: What was that argument about?

A: I have no idea. They were yelling at each other.

Q: You were there then?

A: Yes, I was there.

Q: Okay. This was during the renovation Nicole was doing?

A: Yeah, it was - it was - it - during the renovation - it took a lot longer than they expected. Everything was in shambles. You know, they expected to be in at a certain time and it wasn't, so I guess everybody's nerves were on edge.

Q: Were they living somewhere else while the renovation was going on?

A: I don't think so.

Q: What part of the house inside other than the kitchen was being renovated?

A: The back facing the pool, all that was redone -

Q: The family room-type thing?

A: Family room.

Q: All the glass - go on, Mr. Cowlings. I'm sorry.

A: The family room, the fireplace, the bar, outside the pool area, all that was redone. The pool - there was a new pool. They stoned the front of the house, new driveway. They stoned the back of the house along the guest rooms.

Q: Tell me about the argument they had.

A: I assumed that it started - basically it was something about - it had something to do with the house.

Q: What did you hear Nicole say?

A: All I knew, I was sitting outside and I think I had Sydney with me, and Nicole was in the jacuzzi and her and O.J. were talking. All of a sudden Nicole just started yelling at him.

Q: What did she say?

A: I just grabbed Sydney and I walked in the house because I didn't want Sydney to hear it.

Q: You were near them when this started?

A: Yeah. I heard - the yelling started with Nicole, and then I grabbed Sydney, because it was kinda like Nicole was pretty loud and -

Q: Always?

A: Pardon?

Q: When you say, "Nicole was pretty loud," do you mean this particular incident?

A: She was loud that particular time.

Q: Okay.

A: And I grabbed Sydney because it kinda like caught Sydney - caught me and Sydney by surprise, and I picked Sydney up and I walked in the house.

Q: What did you hear Nicole saying?

A: I don't know. I didn't want Sydney to hear it; I didn't want Sydney to see it, so I walked in the house with Sydney.

Q: Did you hear Simpson say anything?

A: I don't know if he did or not, to be honest with you.

Q: How old was Sydney at that time?

A: I don't know if she was two or three. Probably three, I think. I don't know for sure.

Q: Do you know whether Nicole was pregnant at this time?

A: I don't know.

Q: Well, Sydney was at least two years old?

A: Something like that, I think.

Q: And Sydney was born in 1986?

A: Yeah, I guess that's when she was born, yes.

Q: And Justin hadn't been born yet?

A: I don't know. I don't know if he was or not.

Q: Okay. Did you ever discuss this argument afterwards with Simpson?

A: No.

Q: Did you ever discuss this argument afterwards with Nicole?

A: The only thing I said to Nicole was that it was a bad thing for Sydney to see.

Q: This was after the argument had ended?

A: Either - maybe later on, probably a day later or two days later.

Q: What did Nicole say?

A: She agreed.

Q: Was she upset that she had yelled in front of Sydney?

A: Yeah, I think so.

Q: Okay. Did she strike you as being sorry she had yelled in front of Sydney?

MR. LEONARD: Objection.

THE WITNESS: I don't know.

BY MR. KELLY:

Q: Now talking about this period after Sydney was born, did you ever observe any physical altercations between Nicole and Simpson?

A: No.

Q: Ever observe O.J. get angry at Nicole?

A: After -

Q: After Sydney had been born.

MR. PETROCELLI: All the way to the present?

THE WITNESS: To now?

MR. KELLY: Yeah.

THE WITNESS: There was a situation in Hawaii.

BY MR. KELLY:

Q: Okay. That was the one when you were all on vacation that Christmas?

A: Yes.

Q: Okay. Other than - and it was at Charo's?

A: Pardon?

Q: Charo's, the restaurant -

A: I think was it.

Q: - with Nicole and all those guys?

A: Yeah, we were all in the - yeah, I guess that was the restaurant.

Q: Okay. Other than that incident, can you think of any others where you saw Simpson get angry at Nicole?

Actually, I had asked - me stop for a second. Let me see my last question. Okay. Other than that one incident in Hawaii, did you ever observe any other time when Simpson got angry at Nicole?

A: I don't remember.

Q: Did you ever observe Simpson strike Nicole?

A: No.

Q: Okay. Did Simpson ever tell you he had struck Nicole?

A: No.

Q: Did Nicole ever tell you that Simpson had struck her?

A: No.

Q: Never?

A: No.

Q: Did you ever take Nicole to a doctor at Simpson's request?

A: I took her to - drove her to the hospital.

Q: And when was that?

A: This was in '89.

Q: That was New Year's Day?

A: New Year's night.

Q: New Year's night?

A: Yes.

Q: Other than that one time, was there any other time you accompanied Nicole to the hospital?

A: When she gave birth to her kids.

Q: Other than when she gave birth to her kids?

A: No.

Q: Ever take Nicole to any doctor for any reason, like to a doctor's office, not the hospital?

A: I took her to a dentist's office. She said - she was having some major work done, and she couldn't drive afterwards, so I took her; came back and got her.

Q: Do you recall what year that was?

A: No, I can't remember.

Q: Would you be able to approximate for me?

A: No.

Q: Do you know the name of the dentist?

A: No. It was in Beverly Hills. I think she had some teeth removed or something like that.

Q: Do you know whether that was after or before that New Year's Day 1989 -

A: That was before, way before.

Q: Way before?

A: Uh-huh.

Q: Was it before they were married?

A: I don't know if it was before or during when they were married.

Q: Did you ever talk to Simpson regarding any fights he had had with Nicole during this time period after Sydney was born?

A: No.

Q: Did you ever see Nicole strike Simpson?

A: I think Nicole slapped O.J. once.

Q: When was that?

A: I couldn't tell you exactly when.

Q: Could you approximate for me?

A: I wouldn't - it had - it was during a period that they had been together.

Q: Do you know where it was that she slapped him?

A: I think it was in the kitchen of Rockingham.

Q: Was she living there at that time?

A: Yes.

Q: Was anybody else present there besides you?

A: I don't remember.

Q: Do you recall why she slapped him?

A: No. I don't know if O.J. said something smart aleck to her or something like that. She just hauled off and popped him.

Q: What did Simpson do after she popped him?

A: Looked stupid.

Q: He looked stupid?

A: Uh-huh.

Q: Ho w long did he look stupid for?

A: I didn't time it. I don't know how long.

Q: Did he ever discuss it with you afterwards?

A: I guess he felt he deserved it.

Q: He didn't complain about it?

A: No.

Q: Okay. Did she ever discuss that with you after the fact?

A: No.

Q: Did you ever see Nicole kick Simpson?

A: I personally never saw her kick O.J.

Q: Did someone -

A: I never - huh?

Q: I am sorry. Go on.

A: Go ahead.

Q: Go on. I interrupted you.

A: No, that's all right. I'll let you get away with it this time.

Q: Okay. Thank you. Did someone ever tell you that Nicole had kicked Simpson?

A: I don't know if O.J. mentioned it to me, that Nicole kicked him. To be honest with you, I don't know,

Q: Do you know whether this was after or before New Year's Day 1989?

A: I have no knowledge.

Q: What exactly did he tell you when he said that had Nicole kicked him?

A: It was a vague thing. I don't know if she did or not. I think he mentioned something about her kicking him, but I don't know if it was in jest or a playful thing or whatever. I don't know -

Q: He wasn't complaining about the pain, was he?

A: I don't remember.

Q: He wasn't afraid of Nicole, was he?

A: No.

Q: Have you been able to remember that girlfriend's name from San Francisco?

A: No. My sinuses are backed up. I barely can hear you.

Q: I'll speak louder.

A: I'll probably get it to you.

MR. BREWER: Along with that check.

MR. KELLY: Huh?

MR. BREWER: Along with that check.

MR. KELLY: That's right. That was already mailed?

Q: Do you recall the San Francisco incident in '77 we were talking before about where Simpson had thrown all Nicole's clothes out the window? Do you recall that?

A: Yes.

Q: Do you recall any time any discussion that Nicole had accused him of sleeping with some girl named Terry?

A: No.

Q: Ever hear of a girl named Terry that Simpson was ever going out with?

A: No.

Q: Do you recall during that incident ever hearing Simpson call Nicole a F**king bitch?

A: No.

Q: Do you recall ever hearing him call her a motherF**ker during that incident?

A: No.

Q: Do you ever recall him using that kind of language with Nicole?

A: No.

Q: Was there ever an incident where - or did you ever discuss any injuries with Nicole that she had gotten falling off a bike?

A: I didn't even know Nicole fell off a bike.

Q: Okay. Did you ever - you never took her to St. John's Hospital for any reason relating to a fall off a bike?

A: No. I don't remember.

Q: Okay. Before we were talking about a conversation you had with Judy in the last month or so down at Laguna? Do you remember having a conver -

A: I been down there a lot.

Q: I said in the last month or so.

A: The last couple weeks, yes.

Q: Okay. Last couple weeks you had a conversation down at Laguna with Judy Brown?

A: Well, we were trying to have a conversation, but she was pretty upset.

Q: Okay. Can you tell me what she said and what you said during that conversation?

A: She was addressing issues to me about O.J. and the kids where she should have been addressing O.J.

Q: Okay. Other than issues involving the kids, did she say anything to you about you not protecting Nicole from O.J.?

A: She - no. What she said to me, she called me either - I don't know if she called me a coward or she called me something, and she said 1 something about O.J. controlling me, and then she told me I could influence O.J. And she was all sporadic; she was up and down, so I couldn't make heads or tails what Judy exactly was trying to say to me.

Q: Did you ever say something to the effect that, "I told Nicole to tell the truth, but even when she went to the doctor, she told them she had fallen off a bike"?

A: No, I did not say that.

Q: Did you have any conversation -

A: No.

Q: - like that at all?

A: I didn't have that conversation with Judy. I had that conversation with Lou.

Q: That was the same day?

A: The same day.

Q: Could you tell me about that conversation?

A: Lou started in on me -

Q: How did he start in on you?

A: He - she - he started on me in the same vein about not - how did he start. First with O.J., about how nobody wants him down here and stuff and why did he come down, and I said, "Well, the psychologist in his conversations with O.J., O.J. told him that Justin had been calling him for him to come down to watch him play basketball."

And the psychologist said, "Well, if that's the case, you should go."

I did not know until after all this happened that the Browns didn't know that O.J. was coming down.

Q: Okay.

A: When we got down there -

Q: I am sorry. O.J. didn't tell you that -

A: No, O.J. did not tell me that the Browns did not know he was coming down there. I was under the impression that everybody knew, because Justy - him and - Justy had called; he knew where to go; he knew the time. When I got there - when we got there, we didn't know if we were in the - if it was the right time or we got the right place. I said, "Well, let's call the Browns."

And he says, "No, no, no. Let's ride around a little longer."

So I said, "O.J., it's senseless to be driving around. Why don't we call the Browns to find out if we have the right place or the right time or whatever, if it is today?"

So he said, "Well, call on Sydney's phone."

So I called on Sydney's phone. There was no answer. I said, "Why don't we just call Judy?" So I called Judy, I told who I was, and I said, "Judy, we here to see Justy play basketball."

And she said, "Who?" I said, "O.J. and I" And she got upset and she said, "What is this all about?" She said, "Let me speak to him."

They spoke. That ended. We go to - we were at the right place. The time was later than the time that we were there. The game started at 8:00.

So we got there. I got out of the car. Dominique pulled up with Sydney and Justy. We embraced, the kids and I spoke to Dominique, she spoke, and then we went into -

Q: Did she speak to Simpson, by the way?

A: I don't remember. I doubt it. We walked in the gym and we watched Justy warm-up, and I don's know how long before that Judy walks in, she sits behind me and she says, "I want to talk to you" -

Q: Were you sitting with Simpson at that time?

A: I was sitting next to Dominique. Sydney was sitting next - I was sitting next to Dominique, Dominique was sitting next to Sydney, Sydney was sitting next to O.J. Judy said, "I want to talk to you." So we go outside - we walk out in the hallway and I think she referred to me as a coward or gutless or something like that. And I said, "Well, Judy, if you want to talk to me, let's step outside," because people were walking in and out. As we got outside, she just was throwing her arms up, yelling and -

Q: What was she saying?

A: I don't know exactly. You know, one thing led to another. Then one of - I guess a friend of hers or somebody said, "You want me to call the cops or call the police?" And Judy said, "No." I'm standing there. I'm saying, what - I'm feeling awkward, stupid. You know, I'm out here; for what reason, I have no idea. She brought up the issue about O.J. being down there, and I said, "Well, why don't you talk to him?" "No." Then she says something about - I said, "Well, the psychologist said" - "told O.J. to come down."

And she says, "Well, I talked to the psychologist this morning. He said O.J. read into it the way he wanted to read into it."

And I said, "Well, it's obvious that the psychologist should bring both of - all of you guys on the same page. Whatever he's talking with O.J. concerning the kids, he should relay that to you guys, and vice versa. Why you guys sitting down - jumping down my goddamn throat, I have no idea.

Then Lou walked up, and he started in on me -

Q: How did he start in on you?

A: About, "Nobody wants him down here. He's not" -

Q: "Him" referring to Simpson?

A: Right.

Q: Okay.

A: So I say, "Hey, you know, he's down here because his son wants him to watch" - "his son wants him to watch him play basketball. What is the big deal? He's going to have the kids, anyway."

That was his weekend to have the kids. We was there to pick him up. At 10:00 o'clock we were going to come back up to L.A. with the two kids.

He said something about a scene. I said, "There's no scene here. If anybody's making a scene here, it's Judy. O.J. hasn't done anything."

Then Lou started in on me again. Then he accused me of knowing that O.J. killed Nicole, and I flat out told him, how dare he point a finger at me, saying - in other words, if O.J. did do this, he's trying to say that I'm part of it because I know?

I said - I expressed that - my feelings towards Nicole.

He said, "Well, you been friends with O.J. for 40 some odd years."

And I said, "Let me tell you something, Lou." I said, "If I have one wish when O.J. and Nicole was together, I wish" - I mean, when they got divorced, I wished they could have gotten back together and lived happily ever after, but it wasn't happening. And Nicole would tell you that I never sided with O.J. If O.J. was wrong, he was wrong. I was always there for Nicole."

He said, "Well, Nicole did say that." I said, "Make up your mind, Lou. Either I was her friend or wasn't her friend." So he says, "Well, O.J. controls you." I said, "O.J. doesn't control me." I said, "He is my friend, and we've been friends and we will continue on to be friends." And he went into about - what did he say after that - about the evidence, the overwhelming evidence. I said, "Lou, he went to trial. He was found not guilty." And Lou went into, "Well, the black" - I said, "Why people don't want to listen to what the jury is saying"-

Q: The "black" what? I'm sorry?

A: The black jurors. Because O.J. got off because, I guess, the jury was black. I said, "Nobody wants to listen to what they are saying after the trial." I said, "You been lied to, I been lied to by the authorities."

And I said, you know - he said something - he went to the effect that 10 percent of the population or whatever hates O.J., or whatever.

Q: 10 percent?

A: That's what he - I don't know. Lou was going back and forth, and he expressed to me - and I told him something that I had never told anybody, about what Nicole told me that night I took her to the hospital and -

Q: What was that?

A: About how she felt her family would side with O.J., and that disturbed her a great deal. And when we went down to the hospital, I stood by her, and when the nurse asked her what had happened, Nicole looked at me, and I said, "Nicole, you got to tell them," and she told them that she was hit.

Q: By?

A: By O.J. I don't know if she said O.J., but she said she was hit. They asked her, "How did you sustain your injuries," or whatever, like that. And she said, "I was hit."

Q: Okay. When you told Lou that the authorities had lied to you -

A: No, not lied. A lot of lies have been out about this whole thing that I know are lies, that the authorities or the press has been saying.

Q: But specifically you had said before - I can read it back to you. "I said, 'You been lied to, I been lied to by the authorities.'" Do you remember just stating that?

A: I stated that, but what I'm saying - because I never spoke to the authorities myself. It's just all the lies have come out about certain things that I know that's not true.

Q: Such as?

A: I can't go into it.

Q: Why is that?

A: We just talked about that.

Q: Who just talked about it?

A: My lawyer and I.

MR. RE: I think what he is saying is there are lies about some of the events that involve him that have been misreported in the media which has to do with the area in which he is asserting the privilege.

MR. KELLY: In what area again is he asserting the privilege?

MR. RE: Same area we've been asserting it in the past.

MR. KELLY: That two-week time frame there?

MR. RE: Well, the time frame is basically from the point in time when Mr. Simpson returns to Los Angeles from Chicago until the time frame shortly after Mr. Cowlings' and Mr. Simpson's arrests after the Bronco ride, and then there are certain other potential subject matters that may come up after that period of time but on a subject matter basis.

BY MR. KELLY:

Q: Well, going to June 12th, which was before Mr. Simpson came back from Chicago, or early June 13th, is it your understanding, first of all, that that's when a lot of the evidence in that criminal case was gathered?

A: I have no knowledge. All I know, as time has - as time since then, a lot of lies have been said pertaining to things that I know for a fact are not true.

Q: And you can't state -

A: I didn't state - I did not state it to Lou. I just told Lou that. And Lou proceeded to talk to me about him not being a good father, and I told him that he did the best that he could. There's not a book in the library that says this is how to be a great father. You do the best you can, and after your kids get to a certain age, you keep your fingers crossed.

We talked about O.J. not being a father. I said, "Why don't you give him that opportunity?" It was...He said to me - and then I criticized him for allowing you lawyers to go on TV to -

Q: You criticized Lou?

A: - Lou to let his lawyers go on TV claiming that I was hiding out and I didn't want to be served with a paper. I said that was an outright lie, because the Browns has got all the numbers on me, has always been able to get in touch with me for any reason, to do something for the kids, to do something for them. They about the only people that got numbers - direct numbers to me.

Q: Do you know who the Browns' attorney is?

A: Well, now I know you are. All I know is he (Indicating) stood on TV and made like I was hiding out somewhere, which was a lie. I mean, the Browns knew where I worked. I had brought dresses down there to Sydney. They got labels that list the address - I mean the company I work for.

If you two was communicating, all you had to say, "Where does he work?" They would have gave you the phone number, because for certain - you guys went way out to Public Storage. I haven's worked out there in years.

Q: What else have you discussed with Lou or Judy?

A: No, Judy - Judy - everyone else is - I don't see Justy play basketball. Nobody knows what's going on outside. I'm sitting out there yelling - yelling and Lou yelling at me.

Q: So this is just you and Lou at this point?

A: Just you and - just me and Lou outside. Everybody else is watching Justy play basketball.

Q: Anything else in the conversation?

A: He expressed that he did not want Nicole to date O.J. I said, "Why didn't you say something then?"

He expressed that he did not want Nicole to marry O.J. I said, "Why didn't you say something then, Lou?"

Q: Did he say why he didn't want Nicole -

A: He never did. He never did.

Q: Anything-

A: I think - you know, why he was unloading on me. I have no idea. Even with that. I mean, I never questioned him being a father. I never questioned the fact that O.J. and Nicole got married. They were very happy. Everybody seems to be - the families got along great together. O.J. was very good to the family. They were very good to him. It was one big happy family.

Q: Did Lou seem upset during this conversation?

A: I'm quite sure he was bothered with it. I'm quite sure Lou is bothered deeply.

Q: Would you be bothered if your daughter was murdered?

A: Yes, I would be bothered.

Q: Do you recall at any time being at Rockingham when Nicole, her mother Judy and Dominique were going to a show Disney On Ice with Sydney?

A: I don't know. They did a lot of things. I can't pinpoint, you know, where they were going.

MR. KELLY: Could we just take a break for a minute? I want to look at some exhibits, and then we will keep going. Five minutes?

THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 3:37.

(Recess.)

(Fred Goldman enters the deposition.)

THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 3:52.

BY MR. KELLY:

Q: Mr. Cowlings -

A: Yes.

Q: - the last couple minutes I believe you had the opportunity to look at this particular exhibit I am showing you?

A: Uh-huh.

Q: And that's previously been marked as Exhibit No. 87.

First of all, did Nicole ever send you letters, cards?

A: Birthday cards, she would. After her and O.J. divorced, my apartment on San Vicente wasn't too far from Sydney's school, and every once in a while they would leave notes on my car, but that was about the extent of it.

Q: Okay. Did Nicole used to leave like notes on the refrigerator of things that had to be done?

A: If they went out of town like on a vacation or something like that, she would leave instructions on how to feed the dogs or how to feed the cats. If she had - of course. when she was doing her interior decorating business, if there were some items to be picked up, some fabric or a chair or something like that, she'll leave the address or the phone number.

Q: Okay. Do you recognize that handwriting on Exhibit No. 87 I've given you?

A: Yes, I do.

Q: And whose handwriting do you -

A: Seems to be Nicole's handwriting.

Q: Okay. Do you recall - let me take this for a minute - a time in January of 1988 where you were over at Rockingham with Mr. Simpson, and Nicole and her mother Judy and Dominique came back from a show with Sydney?

A: I don't remember that. There's been a number of occasions where I've been at their company at the house. I couldn't pinpoint a day or a time.

Q: Okay. Do you remember a time when they showed up that you kissed Nicole, her mother and Minnie, but Simpson did not?

A: I don't remember that.

Q: Okay. Do you recall drinking over there at any time in January of 1988 with Simpson?

A: I've drank there. I couldn't tell you the exact day or month or year, but I've drank there quite a few times.

Q: Do you remember drinking there on some afternoon prior to Nicole, her mother and Dominique arriving back at the premises?

A: I don't remember.

Q: Okay. Do you remember any occasion when Simpson started screaming at Nicole, and you had to grab Sydney and get out of there?

A: What I stated earlier about what happened at the pool is the only time I ever grabbed Sydney and took her away.

Q: Okay. Do you recall ever hearing Simpson call Nicole a fat pig?

A: Not that I remember.

Q: Do you recall specifically in January of 1988 Simpson saying to Nicole in front of you, "You're a fat pig"?

A: Not that I can remember.

Q: Do you recall ever hearing him say to Nicole in front of you at Rockingham, "You're disgusting. You're a slob. I want you out of my F**king house"?

A: I've never heard them - those words come out of O.J.'s mouth.

Q: Okay. Do you remember Nicole trying to take Sydney and get away from Simpson as he said these things to Nicole?

A: I don't remember.

Q: Okay. Do you recall Simpson ever saying to you in front of Nicole, "My wife's a fat ass liar. I stopped F**king other girls, and now I jack off, the fat ass"?

A: No, I do not remember him saying that to me.

Q: Did Simpson ever say anything like that to you, ever?

A: Over the years he has expressed that he was going to change his ways and, you know, be more, you know, honest with Nicole, be more loyal o her, but he's never in those terms told me what him and Nicole was doing in the bedroom or what actions they were doing.

Q: Did you ever hear Simpson yell at Nicole in January of 1988, "Get out of my F**king house, you fat ass liar"?

A: No, I don't remember that.

Q: Okay. Do you recall in January of 1988 Nicole ever having to leave the house with Sydney, packing some things and to leave?

A: No, I don't.

Q: Do you recall ever hearing Simpson say to Nicole while you were in the house at Rockingham, "Let me tell you how serious I am. I have a gun in my hand right now. Get the F**k out of here"?

A: No.

Q: And were you ever there when Nicole had to take Sydney and the cats and a bag and a bottle and leave the house at Rockingham?

A: No.

Q: Okay. And this three-page exhibit, Exhibit 87 that I asked you to read before -

A: Uh-huh.

Q: - is it your testimony here today that none of these events referred to in this later here ever occurred?

A: No, no. I don't know if things have been misplaced. All I know is when Nicole and O.J. were arguing at the pool, I picked Sydney up and took her into the house.

Q: I am not talking about -

A: Okay. That's - that's - that's the only thing I know of being in their company when an argument started between the two of them and I was present. That's - you know, that's when I picked up Sydney and went in the house. That I have no knowledge of.

Q: None whatsoever.

A: None whatsoever.

Q: Okay. Can you tell me of any reason that you know of that Nicole would make up those things that are written on those three pages?

MR. LEONARD: Objection. Argumentative. Lack of foundation.

THE WITNESS: No.

BY MR. KELLY:

Q: Did you ever discuss any incident similar to this, with Nicole?

A: Have I discussed?

Q: Yeah.

A: Incidents in here?

Q: Yeah.

A: No, uh-uh.

Q: Okay. Do you know any reason why Nicole would use your name if it wasn't true?

MR. LEONARD: Objection. Calls for speculation.

THE WITNESS: I have no knowledge of it.

BY MR. KELLY:

Q: Okay. If Judy Brown were to testify to the events referred to in this letter, would she not be telling the truth?

MR. LEONARD: Objection. It's an improper question.

A: I have no knowledge of this. Like I say, I don't remember this.

Q: At all.

A: At all.

Q: You had mentioned earlier some incident that occurred in Hawaii?

A: Yes.

Q: Okay. And was that over Christmas in 1988?

A: I believe it was '88. It was at Christmastime. I don't know the exact date - I mean the exact year.

Q: Well, let me ask you: You have a vivid recollection of New Year's Day 1989 when you took Nicole to the hospital, do you not?

A: From when I was there that night -

Q: Yeah.

A: - yes, uh-huh.

Q: Okay. And would it be fair to say that your trip to Hawaii was just prior to that incident?

A: Prior? What do you mean by "prior"?

Q: Yeah, like the week before. Hadn't you just gotten back from Hawaii when the New Year's Day incident occurred?

A: I've never really - I never put the two of them together. I know we all went to Hawaii. If it was '88 or '89, I don't remember.

Q: Okay. Who did you go to Hawaii with?

A: O.J. and his family. When I say "his family,. Nicole, Arnelle, Sydney, and I think Justy was a baby, the Browns -

Q: Which Browns?

A: Lou, Judy, Dominique - was Dominique...I think [Name Deleted] was there. Denise was there with Sean, her son. Tom McCullum and his girlfriend; I don't know her name, and -

Q: Was Denise there?

A: Pardon?

Q: Denise?

A: Yes, Denise was there with Sean, her son.

Q: Okay. And who planned this vacation?

A: I assume the Browns and O.J.

Q: Okay. And do you know who paid for it?

A: That I don't know.

Q: Okay. Did you pay for any of it?

A: I paid - O.J. refused to take my money at the airport, and so...

Q: So he paid for it.

A: Yeah.

Q: Okay. Do you know the name of the hotel you stayed at when you were down there?

A: It was a West - was it Western?

Q: I'm asking you, Mr. Cowlings.

A: I think it's a Western. It's a big hotel right next to the airport on one of the islands.

Q: Okay. And did everybody stay at that same hotel that you mentioned before?

A: Yes. Yes.

Q: Do you recall how long you went to Hawaii for?

A: I think we were there for a week, maybe longer.

Q: Were you there for Christmas Day?

A: Could have. Probably. I don't know.

Q: Okay. Were you back before New Year's Day?

A: I don't know that either.

Q: You don't play golf, by the way, do you, Mr. Cowlings?

A: No.

Q: What would you do during the day when you were there in Hawaii?

A: Play tennis.

Q: Who would you play with?

A: Anybody up at the tennis facility. They would line games up for me.

Q: What would Simpson do during the days?

A: I assume he was playing golf.

Q: Every day?

A: Yeah.

Q: Did you spend much time with Nicole, Sydney and Justin when he was playing golf?

A: No. Everybody - the girls - when I say "the girls," all of them would go to the beach; I would either be at the courts, the tennis courts, or I'd be in the gym; O.J. and Tom McCullum would be off playing golf somewhere, and later on we all would meet at the little pool area there and have, you know, drinks, mai tais, whatever, you know, beach drinks.

Q: Okay. Was there any day there that Simpson and McCullum didn't go off and play golf?

A: I don't remember.

Q: Do you recall any argument between Nicole and O.J. during this vacation?

A: It was more of a comment that she made. It didn't - I don't think it ever developed into a - I mean, like I say, in my presence it wasn't an argument.

Q: Can you tell me what happened?

A: Nicole supposedly had made a comment in reference to O.J.'s father to - we were all sitting in a large dining room -

Q: Do you know where you were, first of all?

A: We were at a restaurant.

Q: Do you know the name of it?

A: You mentioned it earlier.

Q: Charo's?

A: I guess that's it.

Q: Okay. Does that name sound familiar?

A: Yeah, if that's it.

Q: Okay. First of all, who was there at the restaurant with you?

A: All of us, the whole group.

Q: Okay. Was this for lunch or dinner?

A: I would say lunch. I think we were just driving out there to see the place and to have lunch out there.

Q: Okay. Would it be fair to say that Simpson had not played golf on this particular day?

A: I don't know if they played in the morning or whatever I really don't know.

Q: Okay. So tell me about what happened at the restaurant.

A: We were all sitting around, you know, talking, you know, enjoying that particular day-

Q: Was anybody drinking?

A: I really don't know. When you say "drinking"-

Q: Alcohol?

A: That I don't know.

Q: Do you know if Simpson was drinking that day?

A: I don't remember.

Q: Do you know if Nicole was drinking that day?

A: Don't remember.

Q: What, if anything, happened while you were there in the restaurant?

A: We were there. There was two gentlemen sitting at a smaller table directly about ahead of this long table that all of us were sitting at, and I think Sydney - Nicole got up with the baby - I don't know if the baby was crying or kinda like being restless -

Q: This is Justin you're speaking of?

A: I guess. Anyway, one of the gentlemen made a comment how cute the baby was, and, I mean, Nicole responded, you know, accepted the compliment, accepted it -

Q: Did you hear the comment?

A: I didn't hear the comment. I had gotten up and went into the - the little card shop or -

Q: Gift shop?

A: Gift shop. Next thing I knew, Arnelle came in there and said, "We going. Daddy is going."

Q: I am sorry. Were Arnelle and Jason on this trip?

A: Arnelle was. Jason wasn't.

Q: Was there anybody there with Arnelle? Did she have a boyfriend with her?

A: No.

Q: Okay. I'm sorry.

A: If [Name Deleted] was there, I think her and [Name Deleted] hung out. So I said, "What's wrong?" She said, "Dad said to come on."

Q: "Dad" -

A: "Dad said to come on."

Q: Okay.

A: So when I got to the car, O.J. had a straight face on. I said, "What's wrong?" And he says, "I'm not going to take that. I said, "What happened?" And he told me that Nicole - after Nicole had let the man hold the baby, after - no - she took the baby back, O.J. supposedly had said, you know, "Why did you have that gay guy to hold my baby?" or something like that. And she says, "Why you concerned about him being gay? Your father is gay." and O.J. got very upset with it, and he told me in the car -

Q: Was this whole conversation taking place in the car?

A: When he told me?

Q: Yeah.

A: Yes.

Q: Okay. Was anybody else in the car with you?

A: I think Arnelle was.

Q: Anybody else?

A: No.

Q: Was Denise in that car?

A: No.

Q: Definitely not?

A: Not that I remember.

Q: You're sure she wasn't in the car?

A: All I remember, Arnelle came in and got me from the little card shop. When I got in the car, O.J. - I asked him what was wrong, and he told me, and he was going to fly off the island that night. He said, "I'm outta here." He said, "The rooms and everything are taken care of, no problem, but I'm not going to take that."

Q: Okay. Did you hear anything Nicole said to Simpson during this time period at the restaurant?

A: I don't know what went down once they got back to the hotel.

Q: But in the - at the restaurant still, did you hear Nicole say anything after you came out of the gift shop?

A: I don't remember. I don't know if she tried to stop him or - I really don't know.

Q: Did you even see her at all when you came out of the gift shop?

A: I don't remember.

Q: Who drove back to the hotel with you and Simpson in the car?

A: I think it was Arnelle and myself and O.J.

Q: Do you know how long a drive it was back to the hotel?

A: I don't know how long it takes to get back.

Q: Was it more than 10 minutes?

A: I really don't know.

Q: More than 20 minutes?

A: I don't know.

Q: Okay. Do you recall any other conversation in the car?

A: It was pretty quiet going back.

Q: Any discussion at all?

A: He expressed that he was going to leave. He was going to catch the next available flight and fly back to California.

Q: Okay. Was it your impression he was angry the entire drive back to the hotel?

A: Pardon?

Q: Was it your impression that: Simpson was angry the entire time back to the hotel?

MR.LEONARD: Objection. Lack of foundation.

THE WITNESS: I would say he was upset.

BY MR.KELLY:

Q: Okay. And very quiet?

A: Yes.

Q: Okay. What, if anything, did he - Let me ask you, first of all, when you got back to the hotel, did you meet up with anybody else there?

A: I think I went to my room.

Q: Did you see anybody when you pulled into the parking lot of that hotel?

A: I don't remember.

Q: Did you see the Browns?

A: Don't remember.

Q: Did you see Nicole?

A: I don't remember.

Q: Did you see Simpson after you got out of the car, at all?

A: I went to my room. I assumed that he was gonna make plans to fly out of there.

Q: And when was the next time you spoke to Simpson?

A: I think we all ended up going out that night.

Q: Did you speak to Simpson again about what had happened that day?

A: No, I didn't. It seemed like it was - they were together. It seemed like it was over with, you know.

Q: Did you discuss with Nicole at all -

A: Nope.

Q: - that night?

A: No, I didn't.

Q: Do you recall what Nicole's mood was like that night when you went out to dinner?

A: Seemed like they were - you know, they were sitting together. Seemed like I guess whatever differences they had, they patched it up or came to -

Q: Did they appear to be friendly towards one another again?

A: Seems to be. They were sitting together.

Q: Were they talking together?

A: I guess. I didn't know if they were - I wasn't sitting close enough to see if there was continuous conversation between the two of them.

Q: Do you recall when you did leave Hawaii then after this incident?

A: When we came back to LA.?

Q: Yeah.

A: Yeah. The vacation was over.

Q: How long after this incident was the vacation over?

A: I don't know.

Q: Was it the next day?

A: I don't know.

Q: Okay. When I believe Simpson had told you he was out of there he said -

A: Uh-huh.

Q: - did he leave early?

A: No. We all flew back together.

Q: Okay. So the plans weren't changed at all?

A: No. Whatever went down that day, that night we were all together, so I guess they patched it up or put it aside.

Q: Okay. And you never saw any physical altercation between Nicole and Simpson regarding this incident?

A: No.

Q: And Simpson never told you after the fact that he had had any physical altercation with Nicole after he got back to the hotel?

A: No.

Q: And did Nicole ever tell you that she had had any physical confrontation with Simpson after she got back to the hotel -

A: No.

Q: - that day? Okay. I was going to break here now, if it's all right with you guys.

THE VIDEOGRAPHER: This concludes the deposition of Allen Cowlings, Volume I. The number of video tapes used was three. We are going off the record, and the time is approximately 4:13.

(ENDING TIME: 4:13 P.M.)

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.

SUBSCRIBED AT _____________, CALIFORNIA, THIS _ DAY OF 19 _____, 19___.

ALLEN COWLINGS


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