RUFO V. SIMPSON
Taken on FEBRUARY 9, 1996
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SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES
SHARON RUFO, Plaintiff vs. ORENTHAL JAMES SIMPSON, et al., Defendants
DEPOSITION OF FREDERIC GOLDMAN, a plaintiff herein, taken by Defendant Orenthal James Simpson, at 11377 West Olympic Boulevard, Los Angeles, California, at 9:17 a.m., Friday, February 9, 1996, before KAREN E. KAY, CSR 3862, RPR, HMR, CRR. Hutchings Number 96-01057-NO.
APPEARANCES OF COUNSEL:
For Plaintiff Sharon Rufo:
HORNBERGER & CRISWELL
BY MICHAEL A. BREWER
444 South Flower Street, Thirty-First Floor
Los Angeles, CA 90071
For Plaintiff Frederic Goldman:
MITCHELL, SILBERBERG & KNUPP
BY DANIEL M. PETROCELLI
11377 West Olympic Boulevard
Los Angeles, CA 90064-1683
For Defendant Orenthal James Simpson:
BAKER, SILBERBERG & KEENER
BY STEVEN R. VAN SICKLEN
and
PHILLIP A. BAKER
2850 Ocean Park Boulevard, Suite 300
Santa Monica, CA 90405-2936
WITNESS: FREDERIC GOLDMAN
EXAMINATION BY:
MR. VAN SICKLEN
Questions the witness refuses to answer are indicated in the transcript with a plus sign (+) and are located on the following page and line: 38/8, 38/14, 39/10, 42/9, 42/16.
FREDRIC GOLDMAN, a witness herein, having been sworn, testifies as follows:
- EXAM INAT I ON -
BY MR. VAN SICKLEN:
Q. Please state your name.
A. Fred Goldman
Q. And date of birth.
A. 12 – 6 – 40
Q Your Social Security number, please.
A. [Number deleted].
Q. My name is Steve Van Sicklen. I'm representing Mr. Simpson in this deposition.
You were here for your daughter's deposition earlier this week, correct?
A. Correct.
Q. And you heard the admonition given by Mr. Baker to Kim at the beginning, of the deposition?
A. Correct.
Q. You're aware that you're under oath and you're here to tell the truth, correct?
A. Correct.
Q. And that at a later time, if you testify under oath inconsistently with testimony you give today, that potentially could be embarrassing to you.
Do you understand that?
A. I do.
MR. PETROCELLI: Also, the pundits will point out all the inconsistencies as well.
MR. VAN SICKLEN:
Q. It's your obligation to tell the truth the best you can today and give us your most accurate and complete answers, if you can do that, all right?
A. Correct.
Q. Is there any reason physically, emotionally, mentally that you feel you can't give your best testimony today?
A. No.
Q. What have you reviewed in preparation for your deposition, if anything?
A. Nothing.
Q. And have you had, without going into the communications, conversations with Mr. Petrocelli about the nature of the deposition?
A, Just an overview of what happens in a deposition, which we knew about.
Q. Have you ever told any individuals that Mr. Simpson killed your son, Ron?
MR. PETROCELLI: Other than lawyers?
MR VAN SICKLEN: Yes.
THE WITNESS: Yes, I've told people I believe that.
MR VAN SICKLEN:
Q. Who have you told that to?
A. I don't know that I could name names, but probably any number of people. Q. Can you name any names?
A. Probably any close friend I have, business associates, et cetera.
Q. Give me names, please.
A. Rob Duben; Jim Ziegler; Gerald Gold; Dale Irving. I can go on forever, I guess.
Q. What is the basis for your belief that he killed your son?
A. Evidence in the trial.
Q. You don't have any personal knowledge regarding the facts -
A. No.
Q. - of the murder, do you?
A. No.
Q. Where were you when you first heard that your son had been killed?
A. My home.
Q. And that's in Agoura?
A. Yes.
Q. And that's where you currently reside?
A. Yes.
Q. May I have the address, please.
A. [Address deleted]
Q. When did you first hear he was killed?
A. Approximately, 5:00 o'clock on the 13th of June '94.
Q. 5:00am.?
A. pm.
Q. How did you hear it?
A. Phone call from the coroner.
Q. Do you remember who it was?
A. No.
Q. Do you remember what was said to you?
A. Something to the effect of "There was a murder today. Simpson's wife was murdered. The other person murdered was your son."
Q. Did you know who Simpson's wife was?
A. No.
Q. Had Ron Goldman ever told you before he died that he had any kind of a relationship with Nicole Simpson?
A. No.
Q. Did he say anything at all to you about her?
A. No.
Q. So until he was killed, is it true, you had no knowledge that he even knew Nicole Simpson?
A. Correct.
Q. Did you know her?
A. No.
Q. Have you ever driven her car?
A. No.
Q. Where were you between 6:00 and 10:00 p.m. on the 12th of June 1994?
A. My guess is home. I can't honestly remember.
Q. Do you remember with whom you were?
A. Family.
Q. That would be -
A. Wife and stepchildren.
Q. Your wife's name is?
A. Patti.
Q. And when is the last time, to your knowledge, that Ron saw Sharon Rufo?
A. About 13 or 14 years prior to his death.
Q. Do you have any knowledge as to when he might have last spoken to Sharon Rufo?
MR. PETROCELLI: Don't speculate. If you know, you can answer.
MR. VAN SICKLEN:
Q. Or if you've heard.
MR PETROCELLI: That's what I mean by "no," if you've heard any information.
THE WITNESS: I understood it was about 2 years prior, 2 or 3 years prior.
MR VAN SICKLEN:
Q. From whom did you hear this?
A. Ron.
Q. Did he tell you the nature of their communication, what they talked about or the purpose?
A. Told me of the conversation or of the call.
Q. It was a phone call?
A. Yes.
Q. What did he tell you about?
MR PETROCELLI: The two of you are starting to talk over each other a little bit, and both of you need to wait for the other to finish.
MR. VAN SICKLEN:
Q. What did he tell you about it?
A. He said that he had called; And that a man answered the phone. Ron asked for Sharon. The person answering the phone indicated, "Who are you?" Ron said, "Ron." "Ron who?" Ron said, "Ron, her son." And he ultimately left a message.
Q. With Sharon Rufo or with this man?
A. The man that turned out to be her husband.
Q. What was the message?
A. He called.
Q. Did he ever speak directly with her?
A. I believe he did the following day, yes.
Q. Did he tell you what was discussed in that conversation?
A. Just that it was a short conversation; That he wasn't aware that she was married; And there was nothing specific about it, just that it was a short conversation.
Q. Did he tell you why he called her?
A. Yes. He just said that he had decided to call and see what was going on because he hadn't talked to her in a while.
Q. Did he say anything about calling her for money?
A. No.
Q. Can you remember anything that was specifically mentioned by Ron that they talked about in this phone call?
A. I think it was probably, as I recall, just a bit - as it turned out, a rehashing of old stuff.
Q. How would you characterize Ron's feelings about his mother as of, say, the time of his death, if you know?
MR. PETROCELLI: When you say "characterize," you're asking him to answer if -
MR. VAN SICKLEN: I'll rephrase it.
Q. To your knowledge, did Ron love his mother?
A. Yes.
Q. Did he respect her?
A. I think the answer would be no.
Q. Did he have any ill feelings towards her because of the circumstances of how she left his life?
MR. PETROCELLI: Are your questions posed with reference to the time at or near Ron's death?
MR. VAN SICKLEN: Yes.
MR. PETROCELLI: Do you understand that, Mr. Goldman?
THE WITNESS: Yes and no.
I guess the question is, when you say - Maybe you can rephrase it; maybe I'll understand it better.
MR. VAN SICKLEN:
Q. I want to know, let's say, in the month before Ron died, a third party came to you and said, "How would you characterize Ron's feelings about his mother?" What would you have said to him?
A. I would have said that Ron loves her, but hardly ever talks to her and doesn't have a relationship.
Q. Did Ron ever express feelings to you that he felt that she abandoned him?
A. I don't think it was - I don't know that it was in those words, "abandoned," but I think it was more in terms of just didn't maintain a relationship. I don't think '"abandoned" would have been the word that would have been used.
Q. How about "deserted"?
A. No, I don't think "deserted" either.
Q. To your knowledge, were there any cards or letters that were sent by Mrs. Rufo to Ron during the 13-year period that he didn't see her?
A. I think there were occasional but rare.
MR PETROCELLI: When you say "during the 13-year period that he didn't see her," his testimony was that was the last time they saw each other. He didn't have reference to Ron's entire life.
MR VAN SICKLEN:
Q. Just the last 13 years after she left his life, as it were, did she send birthday cards, to your knowledge?
A. Very rare. When they showed up, it was a topic of conversation.
MR. PETROCELLI: I also want to object to the question on the grounds that the statement, "after she left his life," is not consistent with his testimony.
The only point about 13 years ago was that is the last time he thinks that Ron saw Sharon.
MR. VAN SICKLEN: I heard the same thing you did.
Q. If my questions are unclear, please don't answer them.
To your knowledge, did she ever send presents to Ron?
A. Not that I'm aware of, no.
Q. Did she ever send any money to him?
A. No.
Q. Did she, to your knowledge, support him in any way?
A. No.
Q. Did he support her in any way?
A. No.
MR. PETROCELLI: Financially?
MR. VAN SICKLEN:
Q. Financially.
To your knowledge, did he ever write her any cards or letters?
A. I think a few.
Q. Do you know what the circumstances were?
A. I think it was just several times over the years, Ron just decided to attempt to have some contact again.
Q. Have you ever seen any of these cards or letters?
A. I think I did at the time they were written.
Q. How did you see them? Did he show them to you?
A. He showed them to me.
Q. Did you read them before they were sent?
A. Yes.
Q. And this was a period of time when he was living with you?
A. Oh, yeah.
Q. Did he ever get responses back to these cards or letters?
MR. PETROCELLI: If you know.
MR VAN SICKLEN:
Q. To your knowledge.
A. I can't tell you that I'm 100 percent sure. May have. I'm not sure.
Q. Did he -
MR. PETROCELLI: 1 second. (Witness and his counsel confer off the record.)
MR VAN SICKLEN:
Q. He was in no way financially supporting her, was he?
A. No.
Q. When have you last spoken with her?
A. Last time I spoke to her was a day or two after Ron's death.
Q. Since then, you've not had any communication with her?
A. No.
Q. Can you tell me generally what it was you spoke about?
A. Burial arrangements.
Q. Was she in St. Louis when you had this conversation?
A. Yes.
Q. Did she go to the funeral?
A. Pardon me?
Q. Did she go to the funeral?
A. Yes.
Q. Did she contribute financially towards any of the funeral or burial costs?
A. Pardon me?
Q. Did you pay for those?
A. Yes.
Q. Can you tell me approximately what the total amount of money was?
A. My recollection was somewhere in the 6 - or $7,000.
Q. Where is Ron? Is he buried?
A. Yes.
Q. Where?
A. An Agoura cemetery.
Q. Is this a family plot?
A. I guess, to some degree, it's sort of become one. It wasn't then.
Q. Is he there by himself?
A. Yes.
Q. Now, you were here for the entirety of your daughter's deposition which was taken, I guess, last Monday, correct?
A. Correct.
Q. To your recollection and knowledge did she say anything that you had a strong disagreement with in terms of accuracy?
MR. PETROCELLI: Object to the question on the grounds that it is necessarily compound, overbroad, vague and ambiguous, and lacks foundation.
If there's something that comes to mind, you can answer.
THE WITNESS: Nothing that comes to mind.
MR VAN SICKLEN:
Q. So you don't recall hearing anything regarding, say, the cleaning out of, Ron's apartment or some specific factual things that she talked about that you disagreed with factually?
A. Disagreed with, major, no; minor little things, but just a perception issue.
Q. Do you have any knowledge as to whether his wallet was ever retrieved by either the police or you or Kim?
MR. PETROCELLI: Assuming he had one.
MR. VAN SICKLEN: I don't, know. Maybe he didn't have one.
Q. Did he carry a wallet?
A. I can't tell you I remember specifically a wallet, but I know there was ID cards and things like that that ultimately I did get back from the coroner's office.
Q. Did he carry, say, a money clip or a wallet or some kind of a thing that men stick in their pockets to hold their cards?
A. He did not carry a money clip.
Q. What was it that you got back from the coroner that you understand was on his person when he was killed?
A. Photo ID; Some keys; I think a watch, but - No, wasn't a watch. That's all I can recall.
MR. PETROCELLI: Before you, answer -
THE WITNESS: I don't recall anything else.
(Witness and his counsel confer off the record.)
MR VAN SICKLEN:
Q. You have these items?
A. Yes.
Q. Where are they?
A. My home.
Q. And you'll preserve those for us in the event that they're needed in this case?
A. Yes.
Q. How much money, if any, was returned to you?
A. From -
Q. From the coroner's office that you understood to be on his possession when he was killed.
A. I can't honestly remember.
Q. Was it a large amount of money, over $100?
A. No, no. I don't recall that there was specifically any - one way or another whether there was or wasn't -
MR PETROCELLI: - money?
THE WITNESS: Right, money.
MR. PETROCELLI: - any, money?
THE WITNESS: Right.
MR VAN SICKLEN:
Q. To your knowledge, Ron did not have a driver's license at the time he was killed, correct?
A. That's correct.
Q. And to your knowledge, it had been suspended by the DMV; is that accurate? ,
A. I think so, although I think it was suspended, but I'm not 100 percent sure. What's the basis for your thinking it was suspended?
Q. I just remembered that it had been, but I can't tell you that I remember it was reinstated yet or not.
Q. Did you become aware of the suspension at the time it occurred, , if you remember?
A. Yes.
Q. Did Ron tell you about it?
A. Yes.
Q. Were you aware of the arrests that Kim talked about last Monday that involved Ron?
MR PETROCELLI: At the time the arrest occurred or at any time?
MR. VAN SICKLEN:
Q. Well, did you become aware of them at any time? And if so, when?
A. Yes.
Q. When did you become aware of them?
A. The first one, when Ron was arrested, he called me. And the second one, after the fact.
Q. When he called you, what did he say?
MR PETROCELLI: First one?
MR VAN SICKLEN: Yes.
THE WITNESS: Said he'd been arrested in a traffic violation and that he was at the jail, and I told him I would come and pick him up.
MR VAN SICKLEN:
Q. Did you bail him out?
A. Yes.
Q. Do you remember what the bail was?
A. No, I don't
Q. The second time he got arrested, he didn't call you; is that true?
A. That's correct.
Q. Are you aware of how much time he spent in custody for that arrest?
A. After the fact, I think it was 4 days, I believe.
Q. Are you aware of any other arrests involving Ron other than those 2?
A. No.
Q. Have you ever been a plaintiff in any other lawsuits other than this?
A. No.
Q. You've never been in any auto accidents which ultimately ended up in the filing of a lawsuit?
A. Involved in auto accidents, but there was no, quote, unquote, "lawsuit."
Q. Have you made any claims against other parties in connection with auto accidents that you've been involved in?
MR. PETROCELLI: This is irrelevant. You may answer anyway.
THE WITNESS: Claims against -
MR VAN SICKLEN: Yes.
THE WITNESS: We were involved in a very bad automobile accident years ago, and I - No, there was no claim against anyone else. Ultimately, the insurance companies -
MR VAN SICKLEN:
Q. Were you paid a settlement in that case by the other party?
A. Yes. Paid to my daughter.
Q. By the other party's insurance?
A. It was by my insurance company because the other party didn't have any insurance.
Q. Did you personally pay anything?
A. No.
Q. When you say "We were involved in a...bad accident, " you mean you and Kim?
A. Myself; My wife, Patti; Ron; And Kim.
Q. Was Kim the only one who received any compensation as a result of the accident?
A. Yes, compensation, yes.
Q. And the other party uninsured?
A. It was either uninsured or had minor insurance, $10,000, if I remember right.
Q. When you first heard Ron was killed, did anything come to mind as to who may have killed him?
A. No.
Q. Was it ever suggested to you by anyone at any time before Ron's funeral that O.J. Simpson had killed him?
MR. PETROCELLI: Before Ron's funeral?
MR VAN SICKLEN: Yes.
MR. PETROCELLI: Including media reports?
MR. VAN SICKLEN:
Q. Anybody.
A. I think by that time, there was information in the media that police were talking to him, but I don't recall anything more than that.
Q. Has anybody ever come to you or called you or written you and said, "I killed Ron Goldman" other than O.J. Simpson?
A. No.
Q. So nobody has, let's say, confessed to the killing to you?
A. No.
Q. Have you heard from third parties that they believed somebody other than O.J. Simpson may have killed Ron?
MR BREWER: Objection to the term "third parties." It's vague and ambiguous.
(The witness and his counsel confer off the record.)
MR VAN SICKLEN:
Q. In other words, has anybody come up j to you and said, "I know who killed" -
A. No. Never done that.
Q. - or "I think I know who killed Ron and Nicole"?
A. No
MR. PETROCELLI: Other than O.J. Simpson.
THE WITNESS: No one has come up to me and said that, no.
MR. VAN SICKLEN:
Q. Have you ever spoken with O.J. Simpson?
A. No.
Q. When was the first time that you can recall ever saying to somebody that you believed O.J. Simpson killed your son?
A. My guess is it would have been somewhere into the trial.
Q. Can you, without guessing, tell us approximately when that was?
A. Sometime when the evidence started piling up if you would.
Q. I take it, you obviously disagreed with the jury and their verdict?
A. Completely.
Q. Have you ever spoken to any of the jurors?
A. No.
Q. Have you ever attempted to speak to any of them?
MR. PETROCELLI: This is all irrelevant.
THE WITNESS: No.
MR. VAN SICKLEN:
Q. To your knowledge, was Ron in debt to anybody at the time of his death?
MR. BREWER: Before you answer that. that's vague and ambiguous with respect to "debt to anyone."
MR VAN SICKLEN:
Q. Did he owe anybody any money, as far as you know?
A. Not that I'm aware of at that point, no.
Q. Have you personally paid any claims made by any individuals or institutions, banks, on behalf of Ron since he died?
A. After his death?
Q. Yes.
A. There may have been a bill or two that showed up that I may have paid, but I can't tell you specifically remember any specific one.
MR. PETROCELLI: When you say "a bill," you mean like a utility bill?
THE WITNESS: Yes. Because I had all his mail forwarded to my home; and if there were utility bills or anything, I would have paid them.
MR. VAN SICKLEN:
Q. And he was renting the apartment he was in?
A. Yes.
Q. Was it on a month-to-month basis, to your knowledge?
Q. Yes. Do you remember what the amount of the rent was?
A. No, I don't.
Q. In the last 5 years before he died, did, you provide any financial support to him?
A. Yes.
Q. How much?
A. I don't know that I could put a dollar figure on it, but it was a little money here and there.
Q. You are going to have to tell me what you mean by "a little money here and there." Mr. Petrocelli is a very wealthy man, and his idea of –
MR. PETROCELLI: Let the record reflect howling laughter by me.
MR. VAN SICKLEN:
Q. How much would you say you contributed, let's say, every 6 months in the 5 years before he died?
MR. PETROCELLI: Assuming you could do it that way.
THE WITNESS: I don't know that I could put a number on it because -
MR. PETROCELLI: I think what he wants to know, is it like in the thousands or hundreds, you know, some ballpark.
THE WITNESS: Over a 5-year period, probably several thousand.
MR. VAN SICKLEN: Would he call occasionally and ask you for money?
A. No. More me just doing it.
Q. And were you aware of his filing bankruptcy in 1992?
A. Yes.
Q. Did you offer before he did that to help him with any of his financial obligations?
A. Yes.
Q. Did he accept the offer?
A. Yes.
Q. And did you, in fact, help him?
A. I helped him in the sense of going to a financial planner and trying to work out payment of his bills.
Q. Did you personally contribute towards the payment of the bills that he owed at the time he went to the financial planner?
A. No.
Q. And when he filed bankruptcy, did he discuss with you the fact that he was going to do that?
A. Yes.
Q. Did you try to talk him out of it?
A. Initially, when we - when there was the conversation that ultimately resulted in seeing a financial planner, we had talked about not going through bankruptcy and attempting to take care of his debts.
Q. When did Ron last live in the same house with you?
A. Year, year and a half or so prior to his death.
Q. And after he left the house, how often would you say that you saw him?
A. Oh, at least once a week.
Q. Would he come up to your house, and would that be generally how it was -
A. It was typically either/or. Sometimes we met for lunch. Sometimes dinner. Sometimes he came to the house.
MR PETROCELLI: 1 second.
(Witness and his counsel confer off the record.)
MR. VAN SICKLEN:
Q. How would you characterize your relationship with Ron in the last year and a half of his life in terms of whether you were close, best friends? You can use any words you want.
A. Very close, best friends, all of the above.
MR PETROCELLI: You should describe yourself a little more than -
THE WITNESS: We always had a close relationship, and it never changed, whether he was living at home or not living at home.
MR VAN SICKLEN:
Q. Did he ever anger you?
A. Sure.
Q. Did you ever anger him, to your knowledge?
A. Sure.
Q. Just generally, what sort of things angered you about Ron?
MR. PETROCELLI: Mr. Van Sicklen, are you talking about that last year and a half still?
MR VAN SICKLEN: Yes.
THE WITNESS: I think it was typical father-son stuff. My wanting Ron to push for the best, issues like that; but it was never anything over anything that I would consider ultimately serious.
MR VAN SICKLEN:
Q. Was there anything about his lifestyle that you were aware of that frustrated you as a father? A. Lifestyle, no, no.
Q. To your knowledge, was he healthy?
A. Yes.
Q. Did he have a doctor that he saw on a, regular basis?
A. I don't know that he saw a doctor on a regular basis, but I know he went to the doctor to make sure he was healthy.
Q. And to your knowledge, he didn't have any diseases or life-threatening diseases or anything like that?
A. No.
Q. And he was physically fit?
A. Yes.
Q. To your knowledge, did not use drugs?
A. Did not use drugs.
Q. Or alcohol?
A. Did not drink alcohol.
Q. Did you find any drugs or alcohol in his apartment?
A. None.
Q. And no paraphernalia?
A. None.
Q. He didn't have any credit cards to your knowledge; is that correct?
A. At the time of his death?
Q. Yes.
A. No.
Q. And he didn't have a car; is that accurate?
A. That's correct.
Q. Did he have car insurance, to your knowledge?
A. No.
Q. When did he last, to your knowledge, have car insurance?
A. Would have been when he had his car, which was - I can't remember exactly, but several years prior to that.
Q. What happened to that car?
A. It was stolen and ultimately found wrecked.
Q. What kind of car was it?
A. It was a jeep.
Q. When Kim told us about finding his clothes in the apartment tossed up or folded over the door – Is that your memory?
A. Yes.
Q. – those were his work clothes?
A. Thrown over the door, white shirt and black pants.
Q. Belt?
A. I can't honestly tell you there was a belt or not.
Q. Suspenders?
A. No. He didn't wear suspenders, that I recall.
Q. Have you spoken to any of his friends about the circumstances of where Ron was going that night after he left work?
A. Yes.
Q. With whom have you spoken?
A. Name slips me at the moment, but one of the people he worked with at Mezzaluna.
Q. Can you tell me what that person said to you?
A. Yeah. That they were going to be meeting later that evening after Ron got off of work; or after they both got off of work, they were going to be meeting later.
Q. Where?
A. My recollection was either it was a dance club someplace -
Q. Did he have any knowledge about the circumstances of Nicole's mother's glasses?
A. It was that Ron had offered to return the glasses that had been left or lost at the restaurant.
Q. And did he say to you that he heard Ron say that he would take the glasses over to Nicole's house?
A. I don't know that he said that he heard he would do it or that he was told, that he was doing it. I don't recall which.
Q. Did he tell you what time he expected to meet Ron?
A. I'm going to tell you, I think it was 11:00-plus, but I'm not 100 percent sure.
Q. Can you remember - I think I asked you - where it was that they expected to meet each other?
A. I think it was a dance club, but I'm not 100 percent sure.
Q. Was it somewhere, to your knowledge, within walking distance of Ron's apartment?
A. I don't know.
Q. Did he say anything about how Ron was to get there?
A. No.
Q. Did he say anything about whether there were to be other people at the club later other than Ron and whoever this person was?
A. Didn't say.
Q. Did he say anything to you about trying to find out where Ron was when he didn't show up?
A. I can't - I don't recall.
Q. Have you spoken to any of Ron's friends or acquaintances about what relationship, if any, he had with Nicole Simpson before he died?
A. Over all this time, it's been mentioned to me, yes.
Q. With whom have you spoken?
A. Various friends of Ron's that he worked with primarily or that knew Ron.
Q. Can you give me any names?
A. A couple people that he worked with at Mezzaluna. I'm horrible with names. I can't tell you that I remember the names.
Q. Can you tell me generally what the relationship was described as being?
A. Friends.
Q. Has anybody told you that they were ever intimate?
A. No, never.
Q. Has anybody told you they were not intimate?
A. Told me they were friends only.
Q. Did anybody tell you that he had been -
MR. PETROCELLI: 1 second. I want to make sure. (Witness and his counsel confer off the record.)
MR. PETROCELLI: I'd tike you, to repeat the prior t question because it went by quickly, and I'm not sure the witness understood it.
(The record is read by the reporter.)
THE WITN'ESS: Told me they were friends, and people had also said, in fact, they had not been.
MR. VAN SICKLEN:
Q. So to your knowledge, Ron had never told anybody that he had been intimate with Nicole Simpson? .
A. Correct.
Q. Did anybody tell you that Ron had spent time at Nicole Simpson's house?
MR. PETROCELLI: Vague and I ambiguous. You can answer.
THE WITNESS: No one told me that.
MR. VAN SICKLEN:
Q. Did anybody tell you that Ron had driven her car?
A. Yes.
Q. Who told you that?
A. Again, it's a blur at that time, but someone had told me he had driven the car.
MR. PETROCELLI: By "that time," you mean after Ron's death? |
THE WITNESS: After Ron's death, sure.
MR. VAN SICKLEN:
Q. Did this person or persons tell you how frequently he had driven her car?
A. I only heard that he had driven it once.
Q. Do you have any knowledge as to whether he was in her car - I'm speaking about the Ferrari with the license plate, L84AD8, on June 12, 1994.
A. No one told me that
Q. To your knowledge, did he wait on Nicole Simpson that night?
A. No, he did not.
Q. When you retrieved his notebook which had the specials for the menu specials that night, were there any receipts or tabs that he had reflecting the orders he took that night?
A. I don't believe so, no. As a matter of fact, there weren't.
Q. To your knowledge, other than yourself, who do you believe Ron would have said was his best friend?
A. Might have said his sister; but other than that, it would have been Mike Pincus or Peter Argyris.
Q. How would you have characterized, let's say, in the month before Ron died, to a third party who asked, how would you characterize Kim and Ron's relationship?
A. Incredibly close.
Q. Did they ever fight, argue, I mean?
A. As brother and sister, yes.
Q. Did Ron ever, to your knowledge, undergo any professional counseling, psychological counseling?
A. As an adult?
Q. Yes.
A. I don't believe so.
(Witness and his counsel confer off the record.)
THE WITNESS: That's why I asked the question, "As an adult?"
When Ron and Kim were young, the answer is yes.
MR VAN SICKLEN: Did he undergo any counseling because of the circumstances surrounding the lack of relationship with their natural mother?
A. Yes. The three of us went to counseling together.
MR. PETROCELLI: Three of you being who?
THE WITNESS: Ron, Kim, and I.
MR. VAN SICKLEN:
Q. About when was that?
A. Oh, anywhere from the time Ron was 6, Kim was 3 on.
Q. Was it any particular counselor? Can you give me a name?
A. Was a particular counselor, and I can't think of her name right now. A lot of years ago.
Q. In the Agoura area?
A. Oh, no. This would have been in Chicago.
Q. Are you making any claims for lost income in this case?
MR PETROCELLI: Instruct you not to answer. He's here to give facts and information, not -
MR VAN SICKLEN: I just want to know if there's a claim for lost earnings.
Q. Are you claiming you've lost any income as a result of the death of your son?
MR. PETROCELLI: Did he? You can ask him, did he. Don't ask him if he's making a claim. Do you want me to cite back the eloquent words of Robert Baker?
MR. VAN SICKLEN: I don't need any more speeches.
MR. PETROCELLI: I instruct him -
MR VAN SICKLEN:
Q. Do you believe you have lost any income as a result of your son's death?
A. Yes.
MR. PETROCELLI: You can answer that question.
THE WITNESS: The answer is yes.
MR VAN SICKLEN:
Q. What's the basis for the belief?
A. I have over this past year and a half simply, because of the time constraints, not worked as often and probably haven't been able to have my mind as much on work as typically. Those kinds of issues.
Q. Is there a dollar amount that you can give me that you feel that you have lost as a result of the death of your son?
MR. PETROCELLI: I'm not going to let him answer the question because we're not seeking any such income, lost income.
MR. VAN SICKLEN: That's a stipulation?
MR. PETROCELLI: So stipulated.
MR. BREWER: Stipulation by law. It's a wrongful death case.
MR. PETROCELLI: In any event, Mr. Brewer is absolutely right, that is the law; but we're not seeking it, in any event.
MR VAN SICKLEN:
Q. It's not your intention to ask the jury in this case, or the finder of fact, to award lost income as a result of Ron Goldman death?
MR PETROCELLI: Correct. Lost income to Mr. Goldman?
MR VAN SICKLEN: Yes. MR PETROCELLI: Correct.
MR VAN SICKLEN:
Q. In terms of your son's future plans in life, were they consistent with what Kim said? Was his dream to build a restaurant and run a restaurant?
A. Yes, it was.
Q. To your knowledge, did he, at the time of his death, have anybody who was financially willing to back him in such a project?
A. From several conversations that I had had with Ron, he had told me there were some people interested in helping financially. It was in the same conversation that we had in which he asked me if I would be interested.
Q. What did you say?
A. The answer was "Yes, probably; but when you have more information, we'll talk further."
Q. When was this conversation in relation to his death?
A. 6, 9 months prior. Probably 9 months prior.
Q. Did he offer or have a name for this restaurant?
A. I don't - I know there was conversation about what he was going to call it, but my recollection is he said he didn't want to give it a name. He wanted to give it an image, and the image had something to do with an ankh, the Egyptian sign for life, peace, et cetera.
Q. Can you spell ankh for me?
A. A-n-k-h, I believe.
Q. Have you ever spoken with Kato Kaelin?
A. No.
Q. Have you ever spoken with Faye Resnick?
A. No.
Q. Have you ever -
A. Wait. That's not true.
MR PETROCELLI: Excuse me.
(Witness and his counsel confer off the record.)
THE WITNESS: That's not true. We did talk for a few minutes.
MR. PETROCELLI: Slow down just a little bit. He shifted gears very quickly on you. It's an old lawyer's trick.
MR. VAN SICKLEN:
Q. It's not a trick at all. You answer the question; I ask you the next question.
A. The answer is yes.
Q. That's Faye Resnick?
A. Faye Resnick.
Q. When did you speak with her?
A. At a fund-raiser.
Q. What type of fund-raiser?
A. There was some people that held a fund-raiser for the Ron Goldman Justice Fund.
Q. What is the Ron Goldman Justice Fund.
MR PETROCELLI: I'll instruct you not to answer. You're not going to inquire about the justice fund, which I will state for the record is a fund to assist in the prosecution of this lawsuit; and beyond that, you're not entitled to anything.
MR VAN SICKLEN:
Q. Well, let me ask this: Who started the fund?
MR PETROCELLI: Instruct you not to answer.
MR VAN SICKLEN:
Q. Who formed the fund?
MR. PETROCELLI: Invades privacy, work product, attorney-client privilege.
MR VAN SICKLEN:
Q. What did Faye Resnick and you talk about at this fund-raiser?
A. I don't believe it was truly a, quote, unquote, "conversation." It was more just, "Hello, nice meeting you. Thank you for being here." It wasn't a lengthy conversation. It was really nothing more than a few words.
Q. Did she get into any of the details of her relationship with Nicole?
A. None.
Q. Did she say anything about whether she had known Ron?
A. No conversation about that.
Q. To your knowledge, from any source other than your lawyers, did she know, Faye Resnick, know Ron?
A. To my knowledge, the answer is no.
Q. Did you have any conversation with any of the police officers that investigated, not the detectives, but the police officers that investigated the circumstances of the murders on June 14th –
MR. PETROCELLI: June 12th.
MR VAN SICKLEN: I'm sorry. June 12th.
A. When you say "the police officers," meaning -
Q. Have you had any personal conversations with any of the officers that were at the scene of the murders that morning?
A. Do you mean other than people like Vannatter and Lange?
Q. Yes.
A. No, did not.
Q. Have you had any conversations with -
MR. PETROCELLI: Excuse me.
(Witness and his counsel confer off the record.)
THE WITNESS: Well, to clarify, in terms of the police officers that investigated the murders?
MR VAN SICKLEN: Yes.
THE WITNESS: Other than Lange and Vannatter, no. But I did have conversation with some other officers.
MR. VAN SICKLEN:
Q. With the LAPD –
A. Yes.
Q. - who were not involved in the investigation?
A. Indirectly. They were Officers Tippin and Carr that were assigned to, I guess check on Ron's whereabouts, et cetera.
Q. Did they ever tell you anything about the circumstances of whether there were ever 2 gloves at the scene of the murders?
A. Who are we talking about now?
Q. Tippin and Carr, the 2 police officers you just named.
A. No, I don't believe so. No, I don't believe they ever discussed that whole issue at all.
Q. Did you ever discuss that issue with either Detective Lange or Vannatter?
A. I believe so.
Q. Can you tell me what was said on the subject of the gloves?
A. That there was one found at the scene.
Q. Did you ever ask either of them whether they believe that Detective Fuhrman planted the glove that was found in Mr. Simpson's house?
A. Did I ever ask them?
Q. Yes.
A. I might have.
Q. What did they say?
A. They didn't believe - They did not believe it at all.
Q. Did they give you reasons why they didn't believe it?
A. No, I don't think that they gave - don't believe there was any discussion about reasons why, no.
Q. Did they ever tell you that they felt that Mr. Simpson came back from the scene of the murders and got onto his property by climbing the fence at or near the location where the glove was found?
MR. PETROCELLI: The questions is, did Vannatter and Lange ever tell you that?
MR. VAN SICKLEN:
Q. That is, that was their belief.
A. I don't think so.
Q. Did they ever discuss how he reentered his property that night?
A. I don't believe so.
Q. Have you ever discussed with them the whereabouts of any missing blood that was taken from Mr. Simpson?
A. No.
Q. Have you ever discussed the details of their belief that Mr. Simpson committed these crimes, other than what they have testified to at trial?
A. Other than what they testified to at trial, no.
Q. You don't have any personal knowledge in conversations with them over and above what they have publicly testified to about their beliefs or impressions regarding the guilt or innocence of Mr. Simpson?
MR. BREWER: I'll object to that question as vague and ambiguous.
MR. PETROCELLI: They testified as to facts, not belief. The question is, do you know anything more than what they said on the stand?
THE WITNESS: Nothing more than what they said on the stand, no.
MR. VAN SICKLEN: Were you able to identify the keys that were returned to you from the coroner's office that were found with Ron at the scene?
A. Identify them in the sense of -
Q. Apartment key, work key? Do you know what locks they fit?
A. They weren't apartment keys. My recollection is, one of them was an old key off his jeep. I think there were some old keys; A house key on it from our house, my house.
Q. Have you provided any photographs of Mr. Goldman to the police other than those that Kim talked about?
A. Other than the ones Kim mentioned, no. That's not true. Not to the police. To the D.A.'s office, we later provided another photo of Ron.
MR PETROCELLI: It was true, because the question was directed to the police, but you've amplified.
MR. VAN SICKLEN:
Q. Have you ever been offered money to write about the circumstances of your relationship with Ron?
A. No.
Q. Has any newspaper or tabloid approached you with offers of money to discuss the facts of the case?
A. There was a tabloid recently that showed up at our door - I did not personally talk to them - that said they're willing to pay, I don't know, some amount of money for something. And the answer was no and goodbye.
Q. Do you remember how much was offered?
A. No, I don't
Q. You have no plans to write a book or anything about the circumstances of the events of this case, do you?
MR. PETROCELLI: It's irrelevant. You can answer.
THE WITNESS: I guess the answer to that would be, it's a possibility.
MR. VAN SICKLEN:
Q. Have you discussed it with publishers?
A. No.
Q. Have you discussed it with anybody?
A. We've talked about it as a family. Talked about it with - I guess we'll call it a book agent or representative.
Q. Did you know Brett Cantor, C-a-n-t-o-r?
A. I don't recognize the name. Doesn't ring a bell.
Q. Did you know Mike Nigg, N-i-g-g?
A. A friend of Ron's.
Q. And do you have any recollection as to how much your son had in the way of either checking or savings accounts at the time of his death?
A. How much or how many?
Q. How much?
A. I know he had a checking account. I don't recall. I don't believe he had a savings account.
Q. And to your knowledge, Ron had never been married?
A. Had not been married.
Q. And had no children?
A. Correct.
MR VAN SICKLEN: Let's take a break for a second.
(A recess is taken.)
MR VAN SICKLEN:
Q. Other than the fund that you discussed, have you made any money resulting from the death of Ron and Nicole?
MR PETROCELLI: I object to the characterization that he made money through the fund. But the question, you can answer. Have you made any money?
THE WITNESS: Haven't made any money.
MR. VAN SICKLEN:
Q. Do you recall the name of the doctor that treated Ron when he would go to the doctor?
A. I believe it was Jon Matthew.
Q. Where is he located?
A. Dr. Jon Matthew, in Agoura.
Q. Is he a Kaiser doctor?
A. No. Private physician.
Q. Just a family doctor?
A. Correct.
Q. And who, to your knowledge, were Ron's roommates in the apartment he lived in?
A. In -
Q. Before he died.
MR. PETROCELLI: If he had any.
MR. VAN SICKLEN:
Q. If you know.
A. The last apartment he was in?
Q. Yes.
A. Short while, it was his girlfriend, Jacqui Bell.
Q. How many times were you over at that apartment?
A. I guess the answer would have been dozens.
Q. Did you have a key?
A. No.
Q. Can you tell me, other than your lawyers, names of people that you have had conversations with about the progress of this civil lawsuit?
MR PETROCELLI: If anyone.
THE WITNESS: I guess the best answer to that would be, never been conversations in detail because there aren't details at the moment. But close personal friends only.
MR VAN SICKLEN:
Q. Can you name any of them?
A. Rob and Barbara Duben; Jim and Andrea Ziegler; Marilyn and Gerald Gold.
Q. You were present for some of Mr. Simpson's deposition testimony, correct?
A. Correct.
Q. Have you ever told anybody or expressed an opinion to anybody, other than lawyers, your lawyers, that you felt at any time in the deposition that he was lying?
A. Yeah, I probably did.
Q. To whom?
A. Same group of friends.
Q. And what did you say?
A. I think I said that I felt, based on various things that were said, that I felt he was lying.
Q. About what?
A. I don't know that I could pinpoint one specific thing, but -
Q. What do you think that he lied about in his deposition?
MR. PETROCELLI: That's irrelevant, his state of mind about Mr. Simpson's lies.
MR VAN SICKLEN:
Q. What was the basis for your statement to other people that you felt he was lying?
MR. PETROCELLI: You can, answer what you said if you can recall. Beyond that, it's not necessary.
THE WITNESS: I think it was relative to contradictions of testimony in the trial versus what he was saying.
MR VAN SICKLEN:
Q. What contradictions?
MR. PETROCELLI: What did you say, if anything, about that subject?
THE WITNESS: Issues relative to why didn't he answer the limo driver's call, et cetera.
MR VAN SICKLEN:
Q. Well, "et cetera"?
A. That whole area of discussion was still what he was doing and why he didn't answer.
Q. Have you kept any notes, journals, diaries, anything -
A. No.
Q. - like that -
A. No.
Q. - regarding the case?
A. No.
Q. And you mentioned that Kim, you felt there was some, in your mind, minor inconsistencies with Kim's deposition last Monday regarding the details of cleaning up his apartment.
MR PETROCELLI: I don't think he said ''inconsistencies.''
THE WITNESS: I didn't say "inconsistencies." I said minor detail differences.
MR VAN SICKLEN:
Q. Such as?
A. As an example, when Kim made reference of when we met the police at Ron's apartment, more accurately, the landlady was there. She opened the door. The police went in first. We were asked to wait until they went into the apartment first. And then we stood in the doorway and we came in.
Q. There weren't any weapons found in his apartment?
A. No.
Q. Was anything in his apartment found that had Nicole Simpson's name on it or in it?
A. I think the only thing I can recall that had her name in it was Ron's electronic address book.
Q. Anything found with Faye Resnick's name in it?
A. Not that I recall, no.
Q. Kato Kaelin?
A. No.
Q. Did Ron ever tell you at any time that he knew the ex-wife of a celebrity which you know or said anything to you that he knew somebody that you later figured out to be Nicole Simpson?
A. No, he didn't
Q. Did Ron have hobbies like golf? We know he played tennis.
A. Tennis.
Q. Anything else?
A. Tennis was his big love.
Q. Can you tell me generally how your life has changed as a result of his death?
A. Other than not having my son -
Q. We can break at any time.
A. It's okay.
Q. This is my last question.
A. There isn't anything in my life that hasn't changed since his death.
Q. Everything?
A. Every single, solitary moment of my life has changed.
Q. What things did you do that you don't do now as a result of the impact of his death on you?
A. I'm sorry. Say that again.
MR. PETROCELLI: Other than the loss of his entire relationship with his son?
MR. VAN SICKLEN:
Q. I'm speaking about, has your life changed in terms of worship, traveling, work, hobbies that you engage in? I want to know what it is when you're asked that question at trial, how has your life changed. what it is you're going to tell the jury.
MR. PETROCELLI: Apart from your relationship you had with Ron of course, other things in your life.
THE WITNESS: Things, I guess that come to mind quickly are don't sleep through the night anymore. There isn't a day that goes by that ' s I don't think about the loss of Ron or the loss of all the things that we would have had in the future. I don't concentrate as well. I forget a lot more than I used to. Changed in relationship to my daughter.
MR. VAN SICKLEN:
Q. How is that?
A. Because her life is much more painful and difficult for her.
Q. Are you closer with her?
A. It's hard to imagine closer, but I guess the answer would be yes.
Q. How about the relationship with your wife?
A. Same. Our whole life is upside down. They are - Life is more stressful. Our lives are an open book, almost no privacy.
Q. Would you agree to some extent that you have sought out publicity?
A. Haven't sought the publicity, no.
Q. But you have spoken to the press when asked to?
A. On occasion, yes.
Q. And you elected to go to the trial and be there everyday, correct?
A. I was not there everyday. I was there as often as I could be as work permitted.
Q. How often was that?
A. I don't know that it was consistent, but I was there numerous times during the week: sometimes morning, sometimes afternoons, occasionally all day. It's whenever I could break free. It was an uncomfortable, ongoing; balancing act between work and trial.
Q. And your work is - What do you do?
A. I sell point-of-purchase displays.
Q. Do you design them or manufacture them, or are you in sales?
A. Sales. My company manufactures.
Q. What's the name of the company?
A. Reliable Container.
Q. And it's not a 9:00 to 5:00 job; it's a job you can do sort of independent of a clock?
A. No. It's pretty much still a 9:00 to 5:00 job.
MR. VAN SICKLEN: I don't have any further questions.
MR. PETROCELLI: Same stipulation. Mr. Brewer?
MR. BREWER: No questions.
MR. PETROCELLI: Same stipulation with Kim Goldman. It was 20 days.
MR. VAN SICKLEN: Okay.
(By instruction of counsel the reporter has redacted the following stipulation from the deposition of Kimberly E. Goldman as reproduced below:
MR. P. BAKER: Propose the stipulation that the deposition be sent to Mr. Petrocelli's office. It's about 143 pages, so 15 days, 20 days to review the deposition transcript. Make any changes then sign.
MR. PETROCELLI: 20 is fine.
MR P. BAKER: 20 days. And Mr. Petrocelli will advise me if there are any changes made to that deposition testimony. And also propose that we stipulate that if the original is lost, a copy can be used in its stead.
MR BREWER: So stipulated.
MR. PETROCELLI: So stipulated.)
(The proceedings concluded at 10:33 a m.)
I declare under penalty of perjury under the State of California that the foregoing is true and correct.
Executed at ________________________, California,
on________________________________,
__________________________________
FREDRIC GOLDMAN
STATE OF CALIFORNIA
I, Karen E. Kay, CSR 3862, do hereby declare:
That prior to being examined, the witness named in the foregoing deposition was by me duly sworn pursuant to Section 2093 of the Code of Civil Procedure in effect as of January 1, 1989;
That said deposition was taken down by me in shorthand at the time and place therein named and thereafter reduced to typewriting under my direction.
I further declare that I have no interest in the event of the action.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
WITNESS my hand this 13th day of February 1996.