SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES
SHARON RUFO, Plaintiff
vs.
ORENTHAL JAMES SIMPSON, Defendants
DEPOSITION OF JASON LAMAR SIMPSON
Los Angeles, California May 8, 1996
DAVID S COLEMAN
CSR #4813
JOB NO 981370
SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES
SHARON RUFO, Plaintiff,
vs.
ORENTHAL JAMES SIMPS0N, Defendants.
FREDRIC GOLDMAN, etc., et al., Plaintiffs
vs.
ORENTIHAL JAMES SIMPSON, et al., Defendants.
LOUIS H. BROWN, etc., Plaintiffs,
vs.
ORENTHAL JAMES SIMPSON, defendant
Videotaped deposition of JASON LAMAR SIMPSON, taken on behalf of the Plaintiffs, at 11377 West Olympic Boulevard, 10th Floor, Los Angeles, California, commencing at 9:45a.m., on Wednesday, May 8, 1996, before David S. Coleman, CSR #4813, pursuant to Subpoena
APPEARANCES:
FOR THE PLAINTIFFS FREDRIC GOLDMAN, ET AL.:
MITCHELL, SILBERBERG & KNUPP
BY DANIEL M. PETROCELLI, ESQ
11377 West Olympic Boulevard
Sixth Floor
Los Angeles, California 90064-1683
FOR THE PLAINTIFF ESTATE OF BROWN:
JOHN QUINLAN KELLY, ESQ
330 Madison Avenue
New York, New York 7-5090
(212) 682-1700
(Of record but not present)
-and-
NATASHA ROIT, ESQ.
116 North Robertson Boulevard
Suite 705
Los Angeles, California 90048
FOR THE PLAINTIFF SHARON RUFO
HORNBERGER & CRISWELL
444 South Flower Street
Thirty First Floor
Los Angeles, California 90071
(Of record but not present)
FOR THE DEFENDANT ORENTHAL JAMES SIMPSON
AND THE WITNESS:
BAILEY, FISHMAN & LEONARD
BY DANIEL LEONARD, ESQ
66 Long Wharf
Boston, Massachusetts 02110
(817) 723-1980
-and-
BAKER, SILBERBERG & KEENER
2850 Ocean Park Boulevard
Suite 300
Santa Monica, California 90405-2936
(Of record but not present)
-and-
ROBERT D. BLASIER, ESQ.
6355 Riverside Boulevard
Suite 2-F
Sacramento, California 95831
(916) 427-1600
(Of record but not present)
ALSO PRESENT FREDRIC GOLDMAN
INDEX
WITNESS
JASON LAMAR SIMPSON
Examination by Petrocelli 8, 361
Examination by Ms Roit 347
EXHIBITS
181 Handwritten document
182 Handwritten document
183 Map of 360 N. Rockingham with handwritten markings
184 Deposition Subpoena and Production of Documents and Things
of Jason Simpson dated February 5,1996
THE VIDEOGRAPHER: Good morning. Here begins videotape No. 1 in the deposition of Jason Simpson 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 Wednesday, May 8th, 1996. The time is approximately 9:46. 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 and Schwab of Los Angeles, California.
Would counsel please identify yourselves and state whom you represent.
MR. PETROCELLI: Daniel Petrocelli for Plaintiff Fredric Goldman.
MS. ROIT: Natasha Roit for Plaintiff Brown.
MR. LEONARD: Daniel Leonard for O.J. Simpson and the witness, Jason Simpson.
JASON LAMAR SIMPSON, having been first duly sworn, was examined and testified as follows:
EXAMINATION BY MR. PETROCELLI:
Q: Good morning, Mr. Simpson. My name is Daniel Petrocelli, and I represent one of the plaintiffs in this lawsuit against O.J. Simpson. I represent Fredric Goldman.
You are here to give a deposition in this lawsuit. You've been put under oath by the court reporter, and that means you are obligated to tell the truth just like you were testifying in a court of law.
Do you understand that?
A: Yes, sir.
Q: And that means that you're subject to the same penalties of perjury just as though you were testifying in a court of law.
Do you understand that?
A: Yes, sir.
Q: And you understand that deliberately lying under oath is a felony under California law for which you can go to prison.
Do you understand that?
A: Yes, sir.
Q: Okay. Have you ever been examined under oath before?
A: No, not that I recall. Not that I recall.
Q: Well, are you unsure whether you've given testimony under oath?
A: Yeah, I'm not sure.
Q: Can you describe to me some proceedings when you think you may have testified under oath but are not sure?
A: Yeah. A court case I had gotten into, I got in a car accident a while back, and I don't -- I'm not sure if I swore in or anything like that. I just remember going to court and taking care of the matter.
Q: Okay. Let me --
A: It wasn't a trial or anything like that.
Q: Okay. Let me mention a couple of things just so we can get a clean record. Let me finish my question before you answer, and I will try not to interrupt you.
A: Okay.
Q: This is to make the reporter's job easy, because he can only, despite his extraordinary abilities, get only one person down at a time.
A: Okay.
Q: Secondly, your voice has a tendency to trail off near the end of your sentences, and if you could keep your voice up so that everybody can hear, and also so that we can tell when you've completed your answer.
A: Okay
Q: Okay? Rather than kind of mumbling near the end, just try to give a complete answer.
A: Okay.
Q: You were in an automobile accident, and the case went to court and you gave testimony?
A: Yes.
Q: Was that a trial?
A: No.
Q: Was it in a courtroom?
A: Yes.
Q: Was there a judge there?
A: Yes.
Q: A jury?
A: No.
Q: Okay. And when was that?
A: Last summer, I believe.
Q: Summer of 1995?
A: Yes, sir.
Q: Who sued you?
A: I forgot her name. Olga Klavaris or something like that.
Q: Over what?
A: A car accident. I ran into her.
Q: Okay. Were you under the influence of alcohol?
A: No, sir.
Q: Were you under the influence of drugs?
A: No, sir.
Q: Was anyone injured?
A: No, sir.
Q: Just property damage?
A: Yes, sir.
Q: Okay. Is that the only time you've been involved in an automobile accident?
A: Yes, sir.
Q: Okay. Have you ever been convicted of a crime?
A: Yes, sir.
Q: Okay. Tell me what crimes you've been convicted of.
MR. LEONARD: I am going to object, unless you can lay a foundation under the rule. You can ask him if it was a felony. You are going to lay a foundation for that?
MR. PETROCELLI: I want to know all crimes that he's been convicted of.
MR.LEONARD: Well, I don't think you have a right to ask for anything other than felonies.
MR. PETROCELLI: Well, it may lead to discoverable -- felony convictions are admissible --
MR. LEONARD: Right.
MR. PETROCELLI: -- but other convictions may or may not be, but they may lead to discoverable evidence.
MR. LEONARD: Well, I am going to instruct him not to answer other than felony convictions.
BY MR. PETROCELLI:
Q: Have you been convicted of crimes other than felonies? You can answer that yes or no.
A: I wasn't quite sure exactly what it was. It wasn't a felony.
Q: It was not a felony.
A: No.
Q Was it something that you pled guilty to?
A: No.
Q: Was it something that you were found guilty of after a trial?
A: No.
MR. PETROCELLI: What are we talking about, Mr. Leonard?
MR. LEONARD: Go ahead. Ask him.
BY MR. PETROCELLI:
Q: Okay. Tell us what you have in mind.
A: I got DUI. I don't know what that is, though. What's that?
Q: Driving under the influence?
A: Yeah. I don't know what thing that goes under.
Q: Okay. Let me see if I can find out what we're talking about here. You were charged with driving under the influence?
A: Yes, sir.
Q: What year was that?
A: I think I was 17, so it must have been -- or 18. It might have been 1988, '89.
Q: How old are you?
A: I'm 26.
Q: When were you born?
A: 1970.
Q: What's your birthday?
A: April 21st.
Q: What year did the DUI occur?
A: I think it was maybe in 1989.
Q: Were you involved in an automobile accident at that time?
A: Uh-uh.
THE REPORTER: No?
THE WITNESS: No.
BY MR. PETROCELLI:
Q: That's another rule. You have to --
A: I understand.
Q: -- give an audible response.
A: I forgot. Sorry.
Q: That's all right. Was this a charge brought against you by the City of Los Angeles?
A: Yes, sir.
Q: And what was the disposition of that charge?
A: I don't understand the question, "disposition of that charge."
Q: Were you found guilty or what?
A: Yeah. Yeah.
Q: Was there a trial?
A: No, there wasn't a trial.
Q: How were you found guilty?
A: What did I do? It's a while ago. I'm trying to remember. I remember
going to court and --
Q: Did you testify?
A: No.
Q: Was there a jury?
A: No.
Q: Did your lawyer plead guilty on your behalf?
A: I don't remember
Q: Make a deal?
A: Yeah, I believe so.
Q: Okay. Did you serve any time?
A: No. No.
Q: Community service?
A: Yes.
Q: How many hours?
A: 30 hours, I think, community service and AA meetings, and what else.
Q: Did you attend the AA meetings?
A: Yes, sir.
Q: And did you perform the community service?
A: Yes, sir.
Q: Okay. Is that the only time that you've ever been charged with a DUI?
A: Yes, sir.
Q: Is that the only time you've ever been charged with a crime?
A: Yes, sir.
Q: Okay. You ever been sued for anything else in your life?
A: Other than --
Q: You mentioned the -- excuse me. Was the automobile accident litigation? Did that result in litigation, the one this past summer?
A: What do you mean? Did it --
Q: I don't -- did someone sue you?
A: Yeah, she started to, but I guess she dropped it.
Q: She dropped it?
A: Yeah.
Q: Was there a settlement?
A: No.
Q: She just dropped the case?
A: Dropped the case.
Q: And you gave us the name of the plaintiff?
A: Olga something.
Q: Olga?
A: I don't remember what her last name was.
Q: Against Jason Simpson?
A: Uh-huh.
Q: You have to answer.
A: Yes.
Q: Where was that case filed?
A: Los Angeles.
Q: Who represented you in that case?
A: I forgot the lawyer's name. Carl Jones.
Q: Private practictioner?
A: Yes.
Q: Who represented you in the DUI case?
A: I forgot his name. It was a long time ago.
Q: Was that a public defender?
A: No
Q: A private lawyer?
A: Uh-huh.
Q: You have to answer yes.
A: Yes.
Q: Okay. And have you ever been sued either criminally or civilly in any other proceeding?
A: No, sir.
Q: Okay. Isn't it true that you were -- that charges were brought against you by the City of Los Angeles for assault on a guy named Goldberg at a restaurant?
A: Yes. Yes, sir. I forgot about that, but I wasn't sued.
Q: Charges were brought against you for assault. True?
A: Right. Right.
Q: You didn't tell us about that earlier.
A: I totally forgot about that.
Q: Okay. Well, it's crucial that you not forget --
A: Okay.
Q: -- and that you try to give it your best in answering these questions.
A: Okay.
Q: This was a case brought against you by the People of the State of California in January of 1993. Correct?
A: Yes.
Q: And you assaulted a man named Paul Goldberg. Correct?
A: Yes, sir.
Q: At Revival Cafe restaurant in Los Angeles. Right?
A: Yes, sir.
Q And you pled guilty to this. True?
A: No, sir.
Q: What was the outcome?
A: The -- I had to -- what I had to do?
Q: Did you plead nolo contendere or no contest?
A: No contest.
Q: Okay. What was the sentence you received?
A: Community service.
Q: Was that all?
A: That's it.
Q: How many hours?
A: I don't remember.
Q: Who represented you?
A: A public defender.
Q: Did you ask your dad for assistance in hiring a private attorney?
A: No, sir.
MR. LEONARD: Objection.
BY MR. PETROCELLI:
Q: Excuse me? You can answer it. It was no.
A: You asking him?
Q: I asked you. I only ask you questions. He answered no, for the record. Were you under the influence of drugs or alcohol when you struck Mr. Goldberg?
A: No, sir.
Q: What injuries did you inflict on Mr. Goldberg?
A: None that I know of, sir.
Q: What did he claim you inflicted upon him?
A: None that I know of.
Q: Have you ever been arrested for use of drugs or narcotics?
MR. LEONARD: I am going to object and instruct him not to answer. Not relevant, doesn't lead to any relevant evidence in the case.
BY MR. PETROCELLI:
Q: Did you take an overdose of drugs that resulted in your hospitalization?
MR. LEONARD: Objection, and I am instructing him not to answer.
BY MR. PETROCELLI:
Q: Did you attempt to commit suicide?
MR. LEONARD: Instructing him not to answer and objecting.
BY MR. PETROCELLI:
Q: Did you -- you've been hospitalized in the last three years?
MR. LEONARD: I am going to object. Instruct him not to answer.
BY MR. PETROCELLI:
Q: When were you hospitalized as a result of an overdose of drugs?
MR. LEONARD: I am going to object and instruct him not to answer.
MR. PETROCELLI: Could be highly relevant, Mr. Leonard.
MR. LEONARD: Well, I am instructing him not to answer.
MR. PETROCELLI: It could have to do directly with his reaction to the events --
MR. LEONARD: It could be a lot of things.
MR. PETROCELLI: -- and incidents involved in this case, and I am entitled to probe --
MR. LEONARD: Well, I am instructing him not to answer.
MR. PETROCELLI: It's obvious that you are trying to hide the facts here, but we will get to that sooner or later.
MR. LEONARD: That's not --
MR. PETROCELLI: You are not even permitting appropriate foundational inquiries, so you are just taking a blanket objection, and there is no way of my knowing whether there is relevant evidence that you're concealing or not.
MR. LEONARD: Well, I am not concealing anything.
MR. PETROCELLI: Then let him answer.
MR. LEONARD: No. I am instructing him. It's not relevant, can't lead to relevant evidence in this case.
MR.PETROCELLI: That wasn't the position you were taking when you were asking lots of witnesses about their drug use. As I recall, your argument, among other things, was that it had to do with the witnesses' capacity to observe and remember and recollect events.
Q: Are you currently on any medication or drugs, Mr. Simpson?
A: Yes, sir.
Q: What is that?
A: Depakote.
Q: Can you spell that?
A: D-e-p-a-k-o-t-e.
Q: I am not familiar with that. Could you describe --
MR. LEONARD: You have to lower your hands.
BY MR. PETROCELLI:
Q: Could you describe what condition that drug treats?
A: Epilepsy.
Q: When were you diagnosed as an epileptic?
A: About five years now. '91 maybe. Maybe longer than that. Seven years.
Q: Seven years?
A: Yes, sir.
Q: Okay. Is that the only reason you take Depakote: For epilepsy?
A: Yes, sir.
Q: And are you under any other -- are you under Depakote now?
A: Uh-huh.
Q: You have to answer audibly.
A: Yes.
Q: Are you under any other drugs now?
A: No, sir.
Q: Do you believe that your taking of Depakote now would in any way impair your ability to hear, understand and answer truthfully my questions?
A: No, sir.
Q: How many times have you been arrested?
MR. LEONARD: I am going to object and instruct him not to answer.
BY MR. PETROCELLI:
Q: Have you ever been arrested?
MR. LEONARD: He has already testified to one or two occasions.
BY MR. PETROCELLI:
Q: Were you arrested on those two occasions, once for the DUI and the other for the assault?
A: Once for the DUI, and that's it.
Q: Not arrested on the other occasion?
A: No, sir.
Q: How did you prepare for the giving of your deposition today?
A: Just some questions with him (Indicating). That was it.
Q: Him being Mr. Leonard?
A: Yes, sir.
Q: When did you meet with Mr. Leonard?
A: Yesterday.
Q: For how long?
A: 20 minutes, half hour.
Q: Where?
MR. LEONARD: I am going to object now. I think that gets into the attorney-client privilege at this point.
MR.PETROCELLI: I don't think where you met invades the attorney -- client privilege.
MR. LEONARD: Well, I do.
MR. PETROCELLI: It could lead to very relevant evidence, including --
MR. LEONARD: Well, I am going to object and instruct him not to answer.
MR. PETROCELLI: Okay.
Q: Who was present?
A: Mr. Leonard and myself, Mr. Simpson. Jason Simpson.
Q: Two people.
A: Yes, sir.
Q: Okay. Yourself and Mr. Leonard.
A: Yes.
Q: Okay. And did -- was there anybody else present but not involved in the conversation, present in the building, in the house, in the room, wherever it is that you met?
A: Could you be more specific?
Q: I am having trouble because your lawyer has blocked my ability to fully understand the facts here.
A: That's too general.
Q: I understand. It's because of your lawyer's objections, so you will have to bear with me.
Wherever you met yesterday, my question to you is whether there was anybody else in the building, in the home, in the facility, wherever it was, in the park, on the airplane.
A: Yeah.
Q: And who was present?
A: My girlfriend. Who else --
MR. LEONARD: When you say "present," you're asking in the building? Is that what you're asking him?
MR.PETROCELLI: If there was a building.
MR. LEONARD: Yeah. Go ahead.
MR. PETROCELLI: You might have been --
THE WITNESS: Anybody I know or just in general? All the people?
BY MR. PETROCELLI:
Q: Yeah, all of them. Name them all.
A: My father came at one point, I believe.
Q: Your father is O.J. Simpson. Right?
A: Last time I checked.
Q: Okay. There is no reason to be sarcastic.
A: Sorry.
Q: This is a serious proceeding. Are you unsure whether your father is O.J. Simpson?
A: No, sir.
Q: And who is your girlfriend?
A: [Name Deleted].
Q: Okay. Who else was present?
MR.LEONARD: Would you define "present"?
MR. PETROCELLI: He --
Q: You were in the process of naming me, quote, "all the people," end of quotes. Name the rest of the people.
MR. LEONARD: People that were present in the building?
MR. PETROCELLI: I am going off of his answer, Mr. Leonard, whatever he had in mind.
THE WITNESS: I'm sorry.
BY MR. PETROCELLI:
Q: You seem to have phased out. Is there a problem?
A: Yeah. He held a sign up to me, and I was reading the sign. You were asking me a question while I was reading the sign.
Q: What is the sign? "Can you please not twist the microphone cable" is the sign.
A: Yes, sir.
Q: Okay. That's because it affects the audio.
A: Yeah. Sorry.
Q: Okay. So besides O.J. Simpson and [Name Deleted], who else was present during your conversation with Mr. Leonard?
MR. LEONARD: No, that misstates his evidence. I object. That's not what he said.
BY MR. PETROCELLI:
Q: Please identify the rest of the people that were in the home, in the facility, in the building, in the park, in the airplane, wherever it was that you and Mr. Leonard met yesterday.
A: That's it. The housekeeper, Gigi.
Q: Okay. So you met at Rockingham. Right?
A: Yes.
Q: Okay. [Name Deleted] was with you?
A: Yes, sir.
Q: At Rockingham yesterday?
A: Yes, sir.
Q: And did she talk to Mr. Leonard at all?
A: Other than saying hello, no.
Q: Okay. And you and Mr. Leonard met in what room in Rockingham?
A: Outside. No room.
Q: Where outside? Near the pool? In the backyard?
A: Yes, sir.
Q: Okay. Is that the first time that you met with Mr. Leonard to talk about your testimony?
MR. LEONARD: Objection. Instructing him not m to answer. Invades the attorney-client privilege.
MR.PETROCELLI: I am entitled to know how many times he met with you.
MR. LEONARD: Well, you had some content in there as well. You can ask him how many times he's met with me.
MR. PETROCELLI: Well, to prepare for this deposition. He may have met with you socially. I am not interested in that.
MR. LEONARD: Okay. Go ahead.
THE WITNESS: Can you repeat the question?
BY MR. PETROCELLI:
Q: Yeah. I am trying to find out how many conversations you had with Dan Leonard regarding your having to be a witness in this case, involving your coming here to testify at your deposition.
A: Just the one.
Q: Just yesterday. Right?
A: Yes, sir.
Q: But you had met Mr. Leonard on a number of prior occasions. Right?
A: Yes, sir.
Q: Okay. And in those prior occasions did you have any discussions with Mr. Leonard other than social conversation?
A: No, not really
Q: Never discussed this lawsuit with Mr. Leonard before yesterday. Is that true?
A: Not really, no.
Q: It's not true or it is true?
A: It's true.
Q: Okay. And before yesterday did you ever discuss with Mr. Leonard the criminal case against O.J. Simpson?
A: No.
Q: Okay. So yesterday is the first time that you ever had any kind of legal conversation with Dan Leonard. Is that true?
A: Yes, sir.
Q: Okay. Are you paying Mr. Leonard?
A: Me personally?
MR. LEONARD: I am objecting. That definitely invades the attorney-client privilege.
MR. PETROCELLI: I am trying to establish whether there is any bona fide attorney-client relationship.
MR. LEONARD: Well, I can represent that there is, and I am not going to let him answer that question.
MR. PETROCELLI: Okay.
Q: Are you paying Mr. Leonard for his services?
MR. LEONARD: I am objecting and instructing him not to answer.
BY MR. PETROCELLI:
Q: Who is paying for Mr. Leonard's services on your behalf?
MR. LEONARD: I am going to object and instruct him not to answer.
BY MR. PETROCELLI: Do you have an agreement by which Mr. Leonard has been retained to represent you here today?
MR. LEONARD: I am going to object and instruct him not to answer.
BY MR. PETROCELLI:
Q: Who else was present at the Rockingham home yesterday when you met with Mr. Leonard other than [Name Deleted], Gigi Guarin and O.J. Simpson and yourself?
A: No one that I remember.
Q: Nobody at all?
A: (Shakes head.)
Q: You have to answer audibly.
A: No. Sorry.
Q: How long were you at Rockingham yesterday?
A: About three hours, four hours.
Q: Okay. And only 20 minutes of that time did you spend talking to Dan Leonard?
A: Yes, sir.
Q: What did you do the rest of the time?
A: Swam in the pool with my girlfriend.
Q: Okay. And did you discuss with your girlfriend this case or this deposition today?
A: No.
Q: Did you talk at all yesterday with O.J. Simpson about this case?
A: No.
Q: Not at all.
A: No.
Q: Not a word.
A: No.
Q: At any time did Mr. Simpson join your discussion with Dan Leonard?
A: No.
Q: Okay. Have you ever discussed this civil lawsuit with O.J. Simpson?
A: Not really, no.
Q: What does "Not really" mean?
A: I'd say, "How's everything going.?" and he might reply whatever, however -- whatever happened in the day, but specifics, no.
Q: Do you understand what this lawsuit is about?
A: Yes --
Q: What is your understanding?
A: -- generally. My understanding is that your case is a little bit different than the other two. You're representing the Goldmans. The Browns representing for monetary reasons -- I don't know. I don't know. I'm not -- I kinda got it and I kinda don't. And then Rufo, I don't know. You're Rufo, or you're Goldman?
Q: I represent Mr. Goldman.
A: The Goldmans. Okay. The Rufo thing I really don't understand, so...
Q: And what do you understand to be the nature and purpose of the Goldman suit against O.J. Simpson?
A: To -- the -- was it -- I -- they want -- it's the just the next step under what he just went through, except they think -- I don't know. I don't understand it totally.
Q: Did you ever ask your father what this case is all about?
A: No, I haven't.
Q: And you understand that in this lawsuit Mr. Goldman accuses O.J. Simpson of killing his son Ronald?
A: That I understand.
Q: Okay. Have you ever asked your father whether he killed Ron Goldman?
A: No, sir.
Q: Have you ever asked your father whether he killed Nicole Brown Simpson?
A: Absolutely not.
Q: Okay. Has he ever told you whether or not he killed Ron Goldman?
A: No, sir.
Q: Has he told you whether or not he killed Nicole?
A: No, sir.
Q: Have you had any conversation with O.J. Simpson on the subject of whether or not he killed Ron Goldman, any conversation at all?
A: No.
Q: And any conversation with O.J. Simpson on the subject of whether he killed Nicole?
A: No.
Q: Did O.J. Simpson ever tell you that he did not kill these people?
Q: MR. LEONARD: I am going to object to that. That's argumentative.
MR. PETROCELLI: It's not argumentative.
MR. LEONARD: Yeah. Well, I am objecting.
You can ask -- answer the question.
THE WITNESS: He never said he killed Nicole.
BY MR. PETROCELLI:
Q: Did he ever say to you he did not kill Nicole?
A: Yes.
MR. LEONARD: Objection --
THE WITNESS: He did say he did not kill Nicole.
BY MR. PETROCELLI:
Q: Okay. Well, I previously asked you whether you had any conversation with him on this subject at all, and you said no. Now you are telling me he said he did not kill Nicole, so that would have been responsive to my prior question.
A: I guess I heard you wrong.
Q: Well, you need to really work hard at this and let me know if we're not clicking. Okay?
A: Okay.
Q: I asked you that question previously in the broadest form possible so that you would give me any conversation at all. So tell me now about the conversation where you just said O.J. Simpson claimed he did not kill Nicole.
A: I believe he might have said, "I can't believe that this is happening. How could they think I killed Nicole?"
Q: What else did he say?
A: In that specific or particular conversation --
Q: Yes.
A: -- I don't recall. I remember hearing that, though.
Q: When did he say that to you, Mr. Simpson?
A: I don't remember.
Q: Was it shortly after the murders?
A: Yes, sir.
Q: Who else was present, if anyone?
A: I don't remember.
Q: Where were you and he when O.J. Simpson said this to you?
A: I don't remember.
Q: You don't remember anything?
A: I remember things. I don't remember exactly where I was standing, where -- who was there.
Q: Well, tell me -- one of the other things you need to understand about this process is that if you don't -- cannot remember exact things, which by and large people can't --
A: Right.
Q: -- but you do remember generally, tell me whatever it is you recall, however vague and general that may be. I am entitled to your best recollection, whatever it is. You understand?
A: I understand.
Q: So if I say, "What did O.J. Simpson say?" and you don't remember exactly what he said but you remember the gist of what he said, then tell me that.
A: Okay.
Q: Is that fair?
A: Yes.
Q: Okay.
A: I believe I told you the gist of what he said.
Q: Okay. And can you tell me anything else that he said or you said?
A: No.
Q: And can you tell me where you were, when it was and who was present?
A: Not exactly, no.
Q: Generally?
A: Generally, I think it was the house, after, our house, my dad's house.
Q: The night of the 13th when he came back from Chicago?
A: I think -- I think, because that was the last time I had a chance to be with him, so...
Q: The last time you were with O.J. Simpson --
A: Yeah. Could actually touch him and everything, you know.
Q: Was the night of the 13th a Monday night, on his return from Chicago?
A: Yes.
Q: Where he -- when he slept at Rockingham that night?
A: I think so.
Q: And then the next several nights he slept at Mr. Kardashian's home. Correct?
A: I believe so.
Q: And you were not at the Kardashian home. Right?
A: No, sir.
Q: And then on the 17th he had this ride in the Bronco which culminated in his arrest.
A: Yes, sir.
Q: And you did see him at Rockingham on the 17th. You were there at the house when he came back with Mr. Cowlings in the Bronco. Right?
A: Yes, I was.
Q: Okay. And you saw Mr. Simpson also at the funeral. Right?
A: Yes.
Q: And you also saw Mr. Simpson at Nicole's viewing. Right?
A: Yes.
Q: So in fact you saw him Monday, you saw him Wednesday, you saw him Thursday and you saw him Friday.
A: That's right.
Q: Okay. Do you remember all that?
A: Now, yeah.
Q: Okay. Well, we will get to all that. Did you see him on Tuesday, the 14th of June, the day that he went to pick up his golf clubs and the day that he went to Mr. Kardashian's house?
A: Tuesday. I don't know. I don't remember.
Q: Was [Name Deleted] your girlfriend in June of 1994?
A: Yes.
Q: When did she become your girlfriend?
A: November. November of '91. It's been five years now, I think -- six years, five years.
Q: Was [Name Deleted] with you at Rockingham at any time between June 13 and June 17, 1994?
A: I think every -- no, not every night. She was with me, yeah, at some point.
Q: She was generally with you that week?
[Portion Deleted in which Jason Simpson speaks about his girlfriend.]
(Plaintiffs' Exhibit 181 was marked for identification by the reporter and was retained by Mr. Petrocelli.)
BY MR. PETROCELLI:
Q: Do you live with [Name Deleted]?
A: Yes, sir.
Q: And the address that you have written down on Exhibit 181 is your current home address?
A: Yes.
Q: And how long has that been your current home address?
A: Six months, going on seven months.
Q: Is that the first time you've lived with [Name Deleted]?
A: No, sir.
Q: When was the first time? I'll tell you what. Let me do it this way: Where were you living in June of 1994 prior to Nicole's murder?
A: The address and everything?
MR. LEONARD: Can --
BY MR. PETROCELLI:
Q: Generally where were you living? Alone? Rockingham? Where were you living?
A: I was living alone, not in Rockingham.
Q: Okay. In an apartment?
A: Yes, sir.
Q: Where was that?
A: In Hollywood.
Q: You were living in an apartment by yourself in Hollywood in June of 1994?
A: Yes, sir.
Q: Prior to Nicole's murder.
A: Yes, sir.
Q: Okay. When did you first move into that apartment?
A: A little over a year before June of '94.
Q: So around June of 1993.
A: Little bit before. So May, April.
Q: Of 1993?
A: '93.
Q: Okay. What was the address there?
A: [Address deleted.]
Q: When did you vacate that apartment?
A: Like it was the week -- it was the week that everything happened, so from the 12th or the 13th to the 17th. I had friends like move all my stuff into my dad's house, because once he went away, I moved into the house. So that was...
Q: Okay. So --
A: During the week --
Q: -- the week or so after the murder, you then moved out of the Hollywood apartment and into Rockingham. True?
A: Yes. Yes, sir.
Q: What room at Rockingham?
A: The -- my old room, the guesthouse room, would have been the second room to the back.
Q: Okay. Is that the room that Kato Kaelin was staying in?
A: At one point I was living -- I was living in there, but he was living in that room.
Q: Is that the same room he occupied, Kato Kaelin, when he was there between January and June --
A: No, it's not.
Q: -- of 1994?
A: It's not.
Q: As I understand the property, there was the Kaelin room and then next to the Kaelin room, going to the back of the property, there was a room that Arnelle was living in?
A: Yeah, she was living there, but that was my room.
Q: Okay.
A: Bigger closet.
Q: And then there is another room back there also?
A: Right. That's Arnelle's room originally.
Q: Okay. Okay. So you then moved into this room next to Arnelle's original room after the murder of Nicole. Right?
A: Right. Right.
Q: And who was then in Kato Kaelin's room after he moved out?
A: After he moved out, I think some family, maybe my Uncle Benny and Uncle Shirley were staying there.
Q: Okay.
MR. LEONARD: Aunt Shirley.
THE WITNESS: Aunt Shirley.
BY MR. PETROCELLI:
Q: Okay. When did you -- how long did you stay at Rockingham as your permanent address? Well, withdrawn.
How long did you stay at Rockingham after you moved in following Nicole's murder?
A: About a year and a half.
Q: When did you move out?
A: Six months ago.
Q: Okay. And then you moved in with [Name Deleted]?
A: Yeah. Yes, sir. Well, no, that's wrong. I'm sorry. I moved into the apartment by myself. Then she moved in later.
Q: Okay. So you left Rockingham in about what, December of last year? November of last year?
A: November.
Q: Prior to -- Withdrawn. When did [Name Deleted] move in with you?
A: The last time?
Q: No. This --
A: The first time?
Q: In your current apartment, correct.
A: December, I think.
Q: Okay. The entire time that you lived at the Hollywood apartment on Sycamore, you lived alone?
A: No, sir.
Q: Okay. Miss [Name Deleted] lived with you?
A: Yes. We moved in together.
Q: And the two of you were there together the whole time?
A: No, sir.
Q: You moved in together, and at some point who left?
A: She got her own apartment.
Q: Okay. And when was that?
A: Maybe February
Q: Of 1994?
A: I'm guessing. I'm guessing. Maybe I should say I don't know.
Q: Around?
A: Of '94, yeah, that would be the year.
Q: Early 1994?
A: Yes, sir.
Q: Okay. She moved out into her own apartment, you stayed there until the week of -- after the murders, and you moved into Rockingham. Now, before you moved into this Sycamore apartment in, let's say, April or May of 1993, where did you live?
A: I lived at Orange and La Brea which is San Vicente and La Brea, which is still -- I don't know -- it's mid city, mid Wilshire.
Q: You lived in an apartment?
A: Yes, sir.
Q: Okay. By yourself?
A: Yes, sir.
Q: For how long?
A: No. Actually, I lived with my sister. She lived with us for a little while.
Q: Arnelle?
A: Yes, sir.
Q: Arnelle and you shared an apartment?
A: Yes, sir.
Q: With someone else?
A: No.
Q: You said, "She lived with us for a...while."
A: She -- well, my mom lived around the corner.
Q: Your "mom" being --
A: She owned the building.
Q: Your mom being Marquerite Simpson?
A: She owned the building.
Q: Your mom being Marquerite Simpson?
A: Yes, sir.
Q: Your mother owned the building?
A: Yes, sir.
Q: And Arnelle and you lived in an apartment in the building?
A: Yes, sir.
Q: Okay. What years are we talking about?
A: I think it was -- it would have been '91 and '92.
Q: From 1991 till the time that you moved into the Sycamore apartment you lived in your mother's apartment building.
A: Yeah.
Q: Is that true?
A: Yes, sir.
Q: And the only person that you lived with for part of that time was Arnelle?
A: Yes, sir.
Q: Okay. And what's the -- what was the address of that building?
MR. LEONARD: Could we have that --
MR. PETROCELLI: The location of it?
MR. LEONARD: Can we have that written down as well?
BY MR. PETROCELLI:
Q: Does your mother live there?
A: Not anymore.
MR. LEONARD: Oh, okay.
MR. PETROCELLI: Okay.
THE WITNESS: I don't want to --
MR. LEONARD: Okay.
THE WITNESS: The address was [address deleted].
BY MR. PETROCELLI:
Q: Where is that located?
A: It would just be Los Angeles.
Q: Okay. Did your mother also have an apartment at that building at the time?
A: She had a house around the corner.
Q: Around the corner. Okay. Before you moved into this apartment on South Orange Drive, where did you live?
A: Dormitory at USC.
Q: What year were you at the USC dormitory?
A: '88 -- actually, before that -- sorry. I got that wrong.
Q: That's all right.
A: I had an apartment. I had an apartment in Hollywood.
Q: Alone?
A: No.
Q: With whom?
A: A girlfriend.
Q: Okay. What years did you live in this apartment in Hollywood?
A: No. You know what? That's wrong. I'm sorry. I had an apartment by myself in Hollywood.
Q: In Hollywood?
A: Yeah.
Q: What years?
A: That would have been '90.
Q: Okay. To '91?
A: Yeah.
Q: Okay. Lived there alone?
A: Uh-huh. Yes, sir.
Q: And before this apartment in Hollywood in 1990, where were you living?
A: In another apartment, in '89, I believe, but not the whole year. Just like six months, something like that.
Q: Where was that apartment?
A: It was in Hollywood -- West Hollywood.
Q: You lived there alone?
A: No. Roommate.
Q: And before --
MR.LEONARD: You have to keep your hands down, Jason.
THE WITNESS: I'm not going to answer --
BY MR. PETROCELLI:
Q: Before this apartment in Hollywood, where did you live?
A: Before this apartment I lived then in the dormitory.
Q: At USC?
A: At USC.
Q: For how long?
A: For a year and -- I'm sorry. About 10 months.
Q: What was the time period?
A: It was '88, '89 --
Q: September of '88?
A: The latter part of '88 and the beginning of '89.
Q: September of '88 until when?
A: Till -- through the summer session, so it would have been --
Q: Summer of '89?
A: Right.
Q: Okay. When did you graduate -- when did you enroll in USC?
A: '88,1988.
Q: And you attended USC for how long?
A: One full winter end summer term. That's it.
Q: One year at USC?
A: One year.
Q: Okay. So the '88-89 year at USC was your only year there. Is that right?
A: Yes, sir.
Q: Is that the only year that you have gone to school?
A: To college.
Q: To college.
A: Yes, sir.
Q: Okay. When did you graduate high school?
A: In 1988.
Q: In June. Right?
A: Yes, sir. No. May.
Q: May. Excuse me. What high school?
A: Army-Navy Academy.
Q: Where is that located?
A: Carlsbad, California.
Q: How long were you there?
A: Three years.
Q: Did you live there?
A: Yes, sir.
Q: When you came home for -- excuse me. Did you come home at all for vacations, weekends, from time to time?
A: Yes, sir.
Q: And at that time you were living with your mother, Marquerite?
A: No, sir.
Q: Where were you living?
A: With my father and Nicole.
Q: During what years?
A: '88, so it would have been from --
Q: '85 to '88?
A: Well, from the 6th grade, which was -- I don't know-up until the time I graduated or -- graduated high school.
Q: Okay. So give me a year on sixth grade.
A: We gotta go back. That would have been 19--
Q: '82, around there?
A: Yeah, a little bit younger than that. Right?
Q: You were 12 years old?
A: Yeah, I guess that's about the time frame, I think. 1982.
Q: Are you telling me that from about 1982 or thereabouts until the time you graduated high school in May of 1988 --
A: Yes, sir.
Q: -- that you resided at Rockingham with your father and Nicole?
A: It was my home.
Q: Rockingham was your home.
A: Yes, sir.
Q: Except when you were living at the Army-Navy Academy.
A: Yes, sir.
Q: Is that right?
A: Yes, sir.
Q: Okay. In other words, during that period of time from about sixth grade until you graduated high school, you did not live at all with your mother. Is that right?
A: Yes, sir.
Q: Do I have it?
A: Yes, sir.
Q: Okay. Was the Army-Navy Academy the only boarding school you attended?
A: Yes, sir.
Q: Before you enrolled in the Army-Navy Academy, where were you going to school?
A: Crossroads in Santa Monica.
Q: When you lived -- Withdrawn. You moved into Rockingham for the first time after you got out of sixth grade?
A: It was just toward the end of sixth grade.
Q: And did you move in with Arnelle at that time? Did Arnelle move into Rockingham with you?
A: No, sir.
Q: Okay. Arnelle was -- where was she living when you moved into Rockingham with O.J. Simpson?
A: With my mother.
Q: She stayed with her mother?
A: Yes, sir.
Q: Okay. Did there come a time when then she moved into Rockingham?
A: Not permanently.
Q: What do you mean by that?
A: She'd stay -- we went to the same school. She'd stay a week.
Q: I see. But basically her principal residence throughout her schooling was with Marquerite?
A: Yes, sir.
Q: Okay. All the way through high school that was true, that she lived with Marquerite, except for occasional nights over at your father's house?
A: Yes, sir, but -- yes, sir.
Q: Okay. But what?
A: When I was away at school, I don't know, sometimes she might stay for a week or something. I wouldn't know.
Q: Okay. When you moved into Rockingham after sixth grade or around the end of sixth grade --
A: Uh-huh.
Q: -- who was living there with you besides O.J. Simpson? Anyone else?
A: I don't remember.
Q: Had Nicole moved in yet?
A: Yes, sir.
Q: Okay. So Nicole was living there. O.J. Simpson was living there.
A: Uh-huh.
Q: You were living there.
A: Yes, sir.
Q: Anyone else?
A: We probably had a housekeeper, but I don't remember.
Q: It was not Michelle. Right?
A: No, she wasn't. She wasn't -- she didn't work for us.
Q: She came along later. Right?
A: Yes, sir.
Q: Do you remember who the housekeeper was at that time?
A: I don't.
Q: Okay. And when you -- did you stay continuously at Rockingham from sixth grade until the time you went off to boarding school?
A: Yes.
Q: And when you used to come back for vacations and weekends from boarding school, did you always go back to Rockingham?
A: Sometimes.
Q: And sometimes where?
A: To my mom's.
Q: Okay. And May of 1988 when you graduated from boarding school, was that the last time that you permanently lived at Rockingham prior to the murder of Nicole?
A: No, sir. No, sir.
Q: Okay. When did you live at Rockingham permanently after you graduated from boarding school?
A: Sometimes -- some -- well, it wasn't permanently. Sometimes between the apartments, I might stay for a week.
Q: I don't mean an occasional week here or there.
A: Okay. Well, then, no, that was it. That's the last time I lived there.
Q: Where did you live in the summer of 1988 between boarding school and USC?
[Portion del
Q: Okay. And they all met Nicole on numerous occasions. Correct?
A: She was like a -- yeah, they all met her.
Q: Did you love Nicole?
A: Yes, sir.
Q: Were you close to her?
A: Yes, sir.
Q: Was she like a second mother to you?
A: I wouldn't say second mother, no.
Q: Did you always remain close to your -- to Marquerite, your mother?
A: Yes, sir.
Q: Did you ever have a period where you had a falling out with Marquerite?
A: Yes.
Q: And what period of time was that?
A: Right when I first moved into -- with my dad and maybe periodically.
Q: Around sixth grade?
A: Yeah, around sixth grade.
Q: That's the period you're talking about, when you moved into Rockingham?
A: Yes, sir.
Q: And did there come a time when you were able to mend the breach with your mother?
A: Yes.
Q: When did that occur?
A: I don't -- I don't remember exactly.
Q: Just generally speaking.
A: Not too long after. I mean, my mom -- this was -- I moved in with my dad maybe a week before graduation, and she was at graduation, and I spent time with her.
Q: So you never had a prolonged period of estrangement from your mother, like a year or longer?
A: No, not that long, no.
Q: Okay. Describe your relation to -- your relationship with Nicole during the years that you lived at Rockingham with her from 1982 to 1988.
A: She was -- she was like a good friend. She was like a real, real good friend, more like an older sister than -- I mean mother doesn't really fit into the relationship, you know?
Q: Nicole was born in 1959?
A: I don't remember exactly when Nicole was born.
Q: And you were born 1970?
A: Uh-huh. Yes.
Q: And she was like a big sister to you. Right?
A: Yeah. She was fun.
Q: She talked to you a lot?
A: Did she talk to me a lot?
Q: Yeah. Did the two of you spend time talking alone?
A: Sometimes, yeah.
Q: Would you tell her about things going on in school?
A: School, girls, whatever.
Q: With girls and everything?
A: Yeah.
Q: Do you believe she loved you?
A: Yeah.
Q: And you loved her dearly?
A: Yes, sir.
Q: And was that true even after you moved out of Rockingham in 1988?
A: Yes, sir.
Q: Did you always remain close to Nicole?
A: Yes.
Q: All the way up until the end of her life?
A: Yes.
Q: And did Nicole -- and did that remain true even after Nicole and your father split up?
A: That -- yes.
Q: You still remained close to Nicole?
A: Yeah.
Q: Did there ever come a period of time when you had a falling out with Nicole?
A: Lots of times.
Q: I don't mean an occasional argument or two, but I mean a lengthy estrangement, let's say six months, a year, where you just didn't talk to her and she didn't talk to you.
A: No. Not -- no. The kids were born. No. There was -- no.
Q: "The kids" meaning your step --
A: My sister and my brother.
Q: Your stepsister and your brother.
A: Yeah.
Q: Or your brother and your sister. Right?
A: That's what I call them.
Q: You like to call them your brother and your sister.
A: Yes, sir.
Q: By your "brother" and your "sister " you are referring to Sydney and Justin. Right?
A: Yes, I am.
Q: Okay. So there never came a time when you had any significant falling out with Nicole. Is that right?
A: What do you mean by significant?
Q: Well, tell me what you have in mind.
MR. LEONARD: Well, I am going to object to that. You're asking the question.
MR. PETROCELLI: I know, but he seems to be troubled, and I am wondering if there is anything that you have in mind that I'm not understanding.
MR.LEONARD: Well, I don't think he's appearing troubled. I probably should have objected. I think it's a vague question, but -- and I don't think he understands it.
BY MR. PETROCELLI:
Q: Do you understand what I'm asking you?
A: No. That's why I'm asking you, what do you mean --
Q: That' s fair. Did you have any falling out with Nicole where you didn't talk to each other for a long period of time?
A: In high school, but maybe a week or -- that's my opinion--
Q: After high school?
A: No. No.
Q: Did you ever have any big fights with her?
A: No. Never. We were never really --
Q: Did you ever scream and yell at her?
A: After high school?
Q: Yes.
A: No.
Q: Before high school?
A: Before -- in high school, yeah.
Q: Over what kind of things?
A: Sneaking my dad's car out and she caught me, and she was gonna tell, and we were yelling at each other.
Q: Okay.
A: And that's about it. That was the only time we ever really got in a heated argument. I was like in the ninth grade or something like that.
Q: And you snuck your dad's car out.
A: Yeah, and I got busted.
Q: Okay. So other then that incident, after high school did you ever have an occasion where you were screaming and yelling at her for something?
A: No.
Q: Or she at you.
A: No.
Q: Okay. What kind of person was Nicole?
MR. LEONARD: Object. Vague.
You can answer.
THE WITNESS: My opinion?
BY MR. PETROCELLI:
Q: Yeah. Describe her to me.
A: I don't know. Nicole changed. I mean, in high school I remember her one way, and when I grew up I remember her another way. When she was married, I remember her one way and --
Q: When did Nicole change?
A: She went through a lot of changes. I mean, I've known her for 17 years.
Q: Can you describe the changes that she went through?
MR. LEONARD: I am going to object as vague and overbroad, but go ahead.
THE WITNESS: She -- sorry. She went from being at one point a young, fun-loving person to being a beautiful mother. You know, I mean, when you want to explain --
BY MR. PETROCELLI:
Q: A young, fun-loving --
A: Whatever, going out, you know, and single --
Q: Young, fun-loving person going out was when you -- she was living with you at Rockingham, and before she had the children. Right?
A: Before she got married to my dad, when she was married and they would do couples things and stuff like that, and then when she got married, and then another stage when they got divorced.
Q: And what changes did you see in her when she got divorced?
A: Maturity.
Q: She became more mature?
A: She always was becoming a little bit more mature. You know what I'm saying? She was off on her own. I've never seen her alone before, you know, living in a house. I never really got to see what it would be like for her to have a place of her own, what everything, you know, she would like. Do you understand what I'm saying? Go to her house and look and, you know, see all the things that, you know, she liked --
Q: As opposed to what your father would like?
A: Yeah, it would be --
MR. LEONARD: Objection. Argumentative.
MR. PETROCELLI: It's not argumentative.
Q: Okay. You can answer.
A. "Yeah, it would be?" Continue.
A: Different -- well, than the group of us. Say if you live in a home, you know, everybody's got input, so there might be a whole bunch -- the home might look one way. If there's one person living there, you see their interests, and I had no idea that she liked-the music selection that she had and certain other things like that.
Q: What was the music selection?
A: It was big. It was huge. I never thought she liked so much things. She had new CDs, new stereos and stuff. I liked going over to her house. It was cool.
Q: At Gretna Green.
A: At Gretna Green.
Q: Gretna Green is the first time that you saw Nicole in an environment where she made her own home and lived alone. Right?
A: Yes. Yes.
Q: And you went to visit her at Gretna Green from time to time. Right?
A: Once in a while, yeah.
Q: And she moved to Bundy in January of '94. Did you ever visit her there?
A: A handful of times.
Q: At Bundy?
A: Yes, sir.
Q: Okay. So when she moved from Gretna Green to Bundy, you continued to maintain your relationship with her. Right?
A: Yes.
Q: Okay. And, of course, she was the mother of Sydney and Justin, and you're -- I assume you've been very close to them?
A: Yeah.
Q: Since the time they were born?
A: Yeah.
Q: To the present?
A: Yeah.
Q: Okay. Did you ever see Nicole suffer what in your mind was a nervous breakdown?
A: Didn't seem like it, no.
Q: In the entire time that you knew Nicole, did you ever see her go through what you believed was akin to a nervous breakdown?
MR. LEONARD: I am going to object to lack of foundation, asking him to speculate.
BY MR. PETROCELLI:
Q: You can answer.
A: A nervous breakdown, no.
Q: Okay. Did you ever observe a period of time when you thought Nicole was not in control of herself?
MR. LEONARD: I am going to object as vague and lack of foundation, calling for speculation.
BY MR. PETROCELLI:
Q: You can answer.
A: Repeat the question.
Q: Yeah. Did you ever observe a period of time when you thought Nicole was not in control of herself?
MR. LEONARD: Same objections.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Did you ever observe a period of time when you thought that Nicole was not a fit mother?
A: No, absolutely not.
Q: Did you ever observe a period of time when you thought that Nicole was a danger to Sydney and Justin?
A: Never.
Q: Did you ever observe a period of time when you thought that Nicole was repeatedly under the influence of drugs?
MR. LEONARD: I am going to object. Lack of foundation, calls for speculation.
BY MR. PETROCELLI:
Q: You can answer.
A: No.
Q: Or under the influence of alcohol repeatedly to the point where she needed help.
MR. LEONARD: I am going to object. It's vague, overbroad, calls for speculation and lack of foundation.
BY MR. PETROCELLI:
Q: You can answer.
A: Not that I know of.
Q: Okay. Did your father ever tell you -- Withdrawn. Did O.J. Simpson ever tell you that Nicole was not a fit mother?
A: Never.
Q: That Nicole was dangerous to the children, Sydney end Justin?
A: No, never.
Q: That Nicole was going through a nervous breakdown?
A: No.
Q: That Nicole was out of control?
A: No.
Q: That Nicole needed help?
A: No.
Q: That Nicole was a pathological liar?
A: No.
Q: That Nicole was attempting to defraud him in any way?
A: No.
Q: That Nicole was attempting to cheat him out of money?
A: No.
A: That Nicole was excessively taking drugs?
A: No
Q: That Nicole was excessively consuming alcohol?
A: No.
Q: Did O.J. Simpson ever express any concern to you over Nicole's welfare prior to her death?
A: Once.
Q: What did he say?
A: She was sick. She had pneumonia a couple weeks before it happened. He just brought her some chicken soup or something like that.
Q: You're referring to a period of time shortly before Nicole's death?
A: I -- yeah, it wasn't too long before then. She was really sick.
Q: What did Mr. Simpson tell you about Nicole?
A: She was sick and he was going to go get her some chicken soup.
Q: Did she tell you what was wrong with her?
A: She said she had pneumonia.
Q: She said that to whom?
A: To me.
Q: You went to see her?
A: I spoke to her on the phone, I think. I don't remember if I saw her. No, you know what? I did see her. I did see her. She was really sick.
Q: Did you see her after your father told you that she was ill?
A: No. Before. Before.
Q: So you saw Nicole, knew she was ill; then later on had a conversation with your father when he said what to you?
A: He --
MR. LEONARD: Objection. I think you've already asked him that. But go ahead.
THE WITNESS: He had brought her chicken soup.
BY MR. PETROCELLI:
Q: Would you describe Nicole as an independent woman?
A: Toward -- yes. Yeah, I would.
Q: Toward the end, you were saying?
A: I was going to say, toward the latter part of -- yeah, I would.
Q: Toward the latter part of what? Her life?
A: Of her life, yeah.
Q: And what does the "latter part" mean in your thinking,
A: The last -- the last few years.
Q: When she moved out on her own?
A: Yeah, it would have been.
Q: What changes did you see in Nicole after she moved out on her own?
MR. LEONARD: Objection. Vague, lack of foundation.
BY MR. PETROCELLI:
Q: What kind of changes in her personality or in the way she handled herself? You talked about you saw signs of maturing. I'm trying to explore that in greater depth.
MR. LEONARD: I am going to object. It's vague. It's compound --
MR. PETROCELLI: That's fine.
MR. LEONARD: -- overbroad. You can answer if you can.
THE WITNESS: In one sense, at home, her home life seemed good. Everything seemed fine. In another sense, her social life was expanding more. She was going out more. She was partying a little bit more. But I wasn't around Nicole as much as I was in high school, but I knew that much.
BY MR. PETROCELLI:
Q: How did you know about her life after she moved out of Rockingham to Gretna Green and then to Bundy? By your personal contact with her?
A: Yes.
Q: During the Gretna Green years, '92 and 93 --
A: Uh-huh.
Q:-- how often would you have contact with Nicole?
A: Gretna Green years, maybe three days a week, four days a week, about two hours, three hours a day. After school, go by, see the kids.
Q: And also on the telephone, too?
A: Not that much on the phone.
Q: You wouldn't call her too often?
A: No, not that much.
Q: You wouldn't call the children on the phone too often?
A: Sometimes. They'd call me, but I'd usually just run out there and see them. I'm not a big phone person.
Q: Now, during these two years at Gretna Green, 1992 and '93 --
A: Uh-huh.
Q: -- did you maintain this level of contact with Nicole pretty constantly throughout that two-year period?
A: Steady? I think so.
Q: Okay. Then when Nicole moved to Bundy in 1994 up until the end of her life in June of 1994, did you continue to maintain that level of contact with her?
A: I tried to, but I couldn't get around as much.
Q: Because of your own --
A: Work.
Q:-- work requirements?
A: Yeah. Yes.
Q: Okay. Nicole always made you feel welcome at the home?
A: Yeah, she did. She did.
Q: Did you have a key to her Gretna Green home?
A: No, I didn't.
Q: Was there a place where she left a key for you to go there?
A: Not -- she never told me about anything.
Q: So the only time you could go there is if she or the housekeeper were home. Right?
A: Yeah.
Q: And her housekeeper during the Gretna Green years was whom?
A: I don't remember her -- there being a housekeeper. There might have been. I don't remember, though.
Q: When you were at the Gretna Green house, it was mainly when she was there, Nicole. Right?
A: Yeah. Can I explain?
Q: Yes, please.
A: I'd usually stop by because my bank's out there, usually stop by my dad's house. It's on the way. I would go by my dad's, go by Nicole's, go by my friends, whatever. It's just -- I'd kinda sweep the whole area and say hi to everybody. If she wasn't home, if I saw her car wasn't there, I wouldn't stop in. If she was, I would go in. It was more like if she was home, I saw her. If she wasn't, I wouldn't, that kinda thing. I never usually called before I came by.
Q: And the same true during the time she was at Bundy?
A: At Bundy, yeah, but I'd only been there a couple of times, so I wasn't -- I'd only been there a couple of times.
Q: Did you have a key to Bundy?
A: No.
Q: At any time?
A: No.
Q: Did she ever lend you her key?
A: No. She never even offered me a key.
Q: Did she have a place where she kept a key --
A: Not that I know of.
Q: -- to your knowledge?
A: Not that I know of.
Q: Did you have a clicker for the garage?
A: No. I didn't even know she had a garage.
Q: When you used to go to Bundy, where would you park?
A: In the front on Bundy.
Q: How many times were you there in the six months she lived there?
A: Maybe five times. Not as often as --
Q: And during the five times that you were there, who else was present?
A: One time I was there, her mother was there. The first time I was there, the movers were there. The kids. That's all I remember.
Q: When was the last time you were there?
A: It was when her mother was there and they were doing something, and I stopped by to say hello.
Q: Were the children home?
A: No, they weren't home.
Q: They were in school?
A: Yeah, I think.
Q: Was this in June of 1994?
A: No. It was in -- I don't remember when it was.
Q: Was it before or after Nicole was ill when you visited her?
A: I think it was -- I don't know. I think it was -- I don't know. I think then the last time would have been when she was ill. I really don't remember.
Q: When you went there the time she was ill, who else was there? Anyone?
A: I don't remember. That might have been the time when her mother was there.
Q: Just not sure?
A: Yeah.
Q: When you would go to Nicole's house at Bundy, how would you get in?
A: Front door.
Q: How would you get past the front gate?
A: Usually you'd have to buzz it or it wasn't closed all the way.
Q: Okay. And if it was not -- closed and you had to buzz it, did the person have to come out to get you, or could they buzz you -- buzz the gate open from inside the house?
A: I don't remember.
Q: Okay. Did you have a key in 1994 to Rockingham?
A: I think to my room, but not to the house. I think.
Q: You didn't have a master key?
A: No. I think, though. I'm not quite sure.
Q: You didn't have a room at Rockingham in 1994.
A:'94?
Q: This is before the murders. Excuse me.
A: I always had a room in Rockingham.
Q: But you didn't live there for years.
A: Yeah, but it was always my room.
Q: What do you mean by that?
A: It was still my room. It didn't -- it didn't -- it never did not become my room. At one point I left.
Q: Well, there was a place there that you regarded as your room even though you hadn't stayed there in many, many years?
A: We all regarded it as my room, yeah. I mean, I still had clothes and crap and stuff in the room.
Q: You had clothes there in June of 1994?
A: Yeah. In the closet? Yeah.
Q: This is the closet of the room in which Arnelle was sleeping?
A: Yeah. Some stuff, yeah.
Q: Okay. And was there an empty bed in that room? Or was there a bed in this room you're calling your room?
A: Yeah.
Q: Is that a bed that was unoccupied in June?
A: Arnelle was sleeping in it.
Q: Sleeping in that bed?
A: Yeah.
Q: So in effect she was sleeping in what you call your room.
A: Yeah.
Q: So even though you call it your room, you were not living there.
A: Yeah. It was still my room. I mean --
Q: That goes back to high school days. Right?
A: Well, yeah. I mean, you know --
Q: Okay.
A: -- if I were to ever come back, she would have to go back to her room.
Q: Okay.
A: That's my room.
Q: Okay. So you did not have a key to the -- a master key to the house. Right?
A: No. I don't think so, like I said.
Q: Did you have a key to the Rockingham gate?
A: No, because that would be the same one.
Q: As the master key?
A: Okay. So when you wanted to go to Rockingham in June of 1994, how would you get in the property?
A: I'd have to ring the buzzer
Q: At Ashford. Right?
A: Yeah. Yes.
Q: And then they would buzz you in. Right?
A: Yeah.
Q: Okay. And could you manipulate the gate to get in without the ringing of the buzzer?
A: Lots of times before all this, we never had the gate all boarded up and everything the way it is now, so, yeah, I mean usually it was unlocked. You'd just push the gate open and get in.
Q: At Ashford?
A: At Ashford.
Q: Just so we can clarify your answer, when you said, "before all this," you meant from the time of the murders. Right?
A: Yes. Yes, sir.
Q: Now you have this boarded-up area?
A: The gate is now securely locked, and you can't see through it because it's, you know, bars. We've got wood up. It's --
Q: All that as a result of the press and media being --
A: People.
Q: -- at your property and lookey-loos and all that?
A: Sightseers. Sightseers want to see stuff.
Q: Describe the way it was in June of 1994 prior to Nicole's death.
MR. LEONARD: And when you say it --
MR. PETROCELLI: The situation with the gate there.
THE WITNESS: The gate?
BY MR. PETROCELLI:
Q: Yeah. You said it was open.
A: Looking at the gate on the Ash- --
MR.LEONARD: Let me just -- I think you are mischaracterizing. You said "open."
I don't think that's what he said.
MR. PETROCELLI: That's exactly what he said. But, anyway, why don't you just let him testify. I'm not trying to put words in his mouth, but I don't want your testimony.
MR. LEONARD: But I'm not.
MR. PETROCELLI: Okay.
MR. LEONARD: I mean, I just think -- I want you to be fair to the witness. That's all.
MR. PETROCELLI: Okay.
Q: Describe to me the condition of the gate.
A: From what I remember --
Q: Yes. Before the murder, now.
A: From what I remember, the gate -- the gate -- the left gate usually was unlatched. Unless -- there's an arm, say, like this (Indicating). Unless it was like that. If it was locked into position, you could not open it. If you would jimmy it, then you could open it.
Q: Okay. And you are referring now to the Ashford gate. Right?
A: Yes, sir.
Q: Okay. And if you were outside and you saw that that arm was fully -- arm of the gate was fully extended --
A: Right.
Q: -- could you unhook it or disengage it from outside the property?
A: You couldn't reach it, no.
Q: Couldn't reach it?
A: You'd have to know how to do it.
Q: Could you do it?
A: Sometimes. Or I'd just hop the wall.
Q: Okay. And that gate, by and large, was not kept locked. Right?
A: No. It was -- sometimes. It depended on the gardeners or whoever was the last person in or out.
Q: And the same true of Rockingham?
A: No. Rockingham was always locked.
Q: Always?
A: Yeah.
Q: Why is that?
A: I don't know.
Q: Now, the Ashford gate was the gate that people used to come onto the property, and Rockingham, the gate used to leave the property.
MR. LEONARD: Objection.
BY MR. PETROCELLI:
Was that generally the case before Nicole's murder?
MR. LEONARD: Objection. Lack of foundation.
BY MR. PETROCELLI:
Q: You can answer.
A: Sometimes.
Q: Generally true?
MR. LEONARD: I think he just answered it twice. He said "Sometimes."
MR. PETROCELLI: I don't care how many times he answers.
MR. LEONARD: Well, I do. How many times you going to ask it?
MR.PETROCELLI: Till I get the truth.
MR. LEONARD: Well, till you get -- oh, the truth. You know -- Dan, you know what the truth is.
MR. PETROCELLI: I do indeed.
MR. LEONARD: Well, that's amazing.
BY MR. PETROCELLI:
Q: You may answer.
A: What's the question?
Q: The question is: Isn't it true that, generally speaking, the people who came to the Rockingham house would enter on Ashford and leave on the Rockingham gate? Isn't that generally true?
MR. LEONARD: Objection.
BY MR. PETROCELLI:
Q: Meaning more often than not?
A: Depends on what people, what time, when.
Q: You.
A: Me?
Q: Yes, you.
A: Personally?
Q: Yes.
A: I'd come on through Ashford or I'd park outside and just -- it depends. I usually didn't park my car in the driveway, though.
Q: You parked your car on Ashford usually. Right?
A: Yeah. I did.
Q: Your father did, too. Right?
A: Sometimes.
MR. LEONARD: Objection.
BY MR. PETROCELLI:
Q: What do you mean, "Sometimes"?
A: Sometimes he parked it on Rockingham. Sometimes --
Q: More often than not he parked his car on Ashford. True?
A: I couldn't tell you. I didn't live there, first of all.
Q: So you have no idea?
A: No. I do. I have an idea. Sometimes I'd see it on Rockingham. Sometimes I'd see it on Ashford.
Q: You wouldn't see it on -- parked on Rockingham for extended periods of time. Right?
A: I wouldn't see it parked anywhere for extended periods of time.
Q: Where would it be parked for extended periods of time?
MR. LEONARD: Objection. Vague.
THE WITNESS: In the neighborhood.
BY MR. PETROCELLI:
Q: Where in the neighborhood?
A: Either on Rockingham or on Ashford.
Q: Did your father usually park that Bronco on Ashford?
MR. LEONARD: Objection. He's asked -- you've asked him that I think three or four times. Oh, yeah.
BY MR. PETROCELLI:
Q: You can answer.
MR. LEONARD: I think you are badgering the witness at this point.
MR. PETROCELLI: He hardly appears badgered.
MR. LEONARD: I'm badgered.
MR. PETROCELLI: That's true.
Q: And you can answer.
A: Can you repeat the question?
Q: Yeah. Your father, O.J. Simpson, usually parked the Bronco on Ashford. True?
A: Sometimes he parked on Ashford.
Q: I said "usually." You said "sometimes."
MR. LEONARD: I think the answer is no.
MR.PETROCELLI: That's your answer. I know that's your answer.
MR. LEONARD: Well, you say he usually does, and he says "sometimes" --
MR.PETROCELLI: No, that's not true.
MR. LEONARD: Oh, that's right. You know what's true. I forgot.
BY MR. PETROCELLI: Okay. You can answer.
MR. LEONARD: I am going to object. Asked and answered. Go ahead.
THE WITNESS: Can you repeat -- the same question?
BY MR. PETROCELLI:
Q: Yes. In front of the mailbox on Ashford.
A: Sometimes in front of the mail box, sometimes in back of the mailbox and sometimes on Rockingham.
Q: Okay.
A: Depends on which way he came up the street.
Q: If he came up the street on --
A: On Rockingham, on Ashford -- on Bristol.
Q: When he came up the street on Rockingham, where would he park?
A: Sometimes I'd see the car on Rockingham. Sometimes I'd see the car on Ashford in front of the gate. Sometimes I'd see the car on Ashford past the gate where the call box was. In, what, the period of five years, six, seven, eight years, something like that we've had our Bronco, the car was never consistently parked at one place.
Q: Did you drive that Bronco?
A: Yeah, sometimes.
Q: Did you have keys to it?
A: No. When I drove the car, I had the keys.
Q: Where did you get the keys?
A: Every single time I drove the car?
Q: Where would you get the keys? From someone else?
MR. LEONARD: Yeah, I am going to object. I think -- I was a little slow there on the gun. I think --
MR. PETROCELLI: He doesn't need you. He's doing just fine.
MR.LEONARD: I think it's overbroad. Are you asking him --
BY MR. PETROCELLI:
Q: Generally speaking --
MR. LEONARD: Okay, there you go.
BY MR. PETROCELLI:
Q: -- how would you get keys to the car?
A: I'd ask my father if I could get the keys.
Q: And there would be a place --
A: Or Nicole.
Q: And there would be a place where you could get the keys?
A: Yeah.
Q: Where would that be?
A: The kitchen, somewhere in the kitchen, in a cup or something like that.
Q: And did the Bronco -- and I am talking about the Bronco that your father had in June of 1994 -- it had a clicker in it to operate the gates?
A: I think. It probably did.
Q: You don't remember?
A: No. I didn't drive the car that often.
Q: When was the last time before Nicole's death that you drove it?
A: I don't remember.
Q: Okay. When was the last time before Nicole's death that you were at Rockingham?
A: I don't remember that either.
Q: Months? Weeks? Days?
A: No, it wasn't months. It wasn't that long, but I don't remember -- oh, annually, it was -- we had a party. My sister and I had a party there. What was it --
Q: Monday of Memorial Day weekend?
A: Yeah.
Q: Allright. Was that the last time you were there?
A: I think I'm almost sure that was the last time I was there.
Q: At Rockingham before Nicole's death?
A: Yes, sir.
Q: And the last time you saw Nicole before her death was when you visited her when she was ill?
A: Yeah.
MR. LEONARD: You have to answer --
THE WITNESS: Yes.
BY MR. PETROCELLI:
Q: That was the last time?
A: Yes, last time I saw her.
Q: Last time you spoke to her?
A: Was I think the day before.
Q: Did you go to Justin's Sunshine graduation on June 7?
A: Oh, yes, I did.
Q: And you saw Nicole then. Right?
A: Yeah. Yeah, I did. Thank you. I did.
Q: Arnelle went also?
A: Yeah, she was there.
Q: And your father, O.J. Simpson, did not show up. Right?
A: No, he wasn't there.
Q: Okay. And do you know why he didn't show up?
A: No.
MR. LEONARD: Objection. Lack of foundation.
MR.PETROCELLI: I said, "do you know why" How can that be lack of foundation?
Q: Do you know?
A: I don't know the reason why.
Q: Did you ever talk to him about why he didn't show up?
A: I didn't talk to him about it, no.
Q: Who did you talk to?
A: Nicole.
Q: What did you and she talk about?
A: She said he had some business thing. That's all she said.
Q: Nicole said to you, "Your father's not going to be here"?
A: Not in those words, no.
Q: What did she say to you?
A: She said, "He's got some business thing."
Q: Did she appear upset to you?
A: No. She seemed happy.
Q: Happy that Mr. Simpson was not coming?
MR. LEONARD: Objection. Calls for speculation.
BY MR. PETROCELLI: Is that the sense that you got?
MR. LEONARD: Objection. Calls for speculation.
THE WITNESS: No. It was happy that it was Justin's graduation.
BY MR. PETROCELLI:
Q: Yeah, but what was her reaction to Mr. Simpson not showing up for the --
MR. LEONARD: Objection --
BY MR. PETROCELLI:
Q: -- for his son's graduation?
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
BY MR. PETROCELLI:
Q: You can answer.
A: She just -- just like I'm saying right now, she just said he had a business thing.
Q: So you don't know how she felt one way or the other about his not being there?
A: I wasn't trying to get into it, no.
Q: I understand that, but I am just trying to find out whether you know.
A: No, I don't.
Q: Okay. You don't know. Right?
A: No, I don't.
Q: Okay. How did you get invited to Sydney -- to Justin's graduation?
A: She told me about it. She called me and told me about it.
Q: She called you at the apartment?
A: I think so.
Q: Okay. And --
A: I found out about it somehow. I don't know. I think she told me about it.
Q: Did you discuss with --
MR. LEONARD: Let me just instruct you, we don't want you guessing. It doesn't help Mr. Petrocelli. It doesn't help me.
THE WITNESS: Okay. Sorry.
MR.LEONARD: If you know, you know. If you don't, you don't. Go ahead.
BY MR. PETROCELLI:
Q: Did you discuss with your father whether or not he would be there at the graduation?
A: I don't remember.
Q: You don't remember any conversation at all with O.J. Simpson about going to this event?
A: No, I don't.
Q: Did you talk to him after the event about it?
A: No.
Q: Did he call you and ask you how it went?
A: No, I don't think so. I don't remember.
Q: You -- did you go anywhere after you left the school? Was there a family dinner or outing?
A: I had to go to work.
Q: You went off to work?
A: Yeah.
Q: I think that event took place on June 7.
A: I had totally forgot about it --
Q: Or June 8.
A: -- until you brought it up.
Q: When after that event did you next talk to Nicole?
A: That would have been June 8th, you're saying?
Q: I think so.
A: I think the day before the re- --
Q: Recital was on June 12.
A: I think it would have been the day before the recital.
Q: And how did you come to speak to Nicole on that day?
A: I wanted them to come in to my restaurant.
Q: Which restaurant was this?
A: This was Jackson's restaurant in West Hollywood, after the recital.
Q: Were you invited to the dance recital of Sydney?
A: Yes.
Q: How did you get invited?
A: I was -- she invited me.
Q: Who is --
A: Nicole.
Q: And when did Nicole invite you?
A: Couple -- a long time before, 'cause it was coming up. This is a long-planned event usually, and it's like a yearly thing, too. She's done it for like two, three years, Sydney. So I knew it was coming up. It was a planned event.
Q: You had gone to the ones in the past?
A: I've gone to one in the past, but I've always been invited.
Q: And the usual custom was that after the recital the family would go to dinner?
A: I don't know about the usual custom. The one I went to, I think we went out to dinner. I don't remember. It was a while ago.
Q: And at some point long before the 12th of June you were told by Nicole of the upcoming recital --
A: Reminded.
Q: -- and you were obviously invited.
A: Right.
Q: And you were told that you would be going to dinner afterwards?
A: They wanted to go to dinner. I had to work, so what better idea, "Why don't you come to my restaurant?"
Q: When she said, "they," meaning that the family would go out to dinner after the recital.
A: Yes, sir.
Q: And you then suggested to her, "Why not my restaurant?"
A: Yeah.
Q: And you were working where at the time?
A: Jackson's.
Q: Jackson's. What were you doing at Jackson's?
A: I was cooking. I was the sous chef.
Q: At that time were you contemplating having to work that evening?
A: I had to work. That's why -- it could kill two birds with one stone: I could see the kids -- I could see Sydney, since I had to miss the -- since I had to miss the recital, plus, you know, they were going to go out to eat, so why not just come in here.
Q: Now, being that she apprised you of the recital so far in advance, how did you know you would have to work that night on the 12th?
A: Because I have to work every Sunday.
Q: That's just a given. Right?
A: Yeah. There was no way. I couldn't get out of it.
Q: What hours --
A: It was the chef's day off. I had to work for him.
Q: What hours were you --
A: From 3:00 o'clock to closing.
Q: Which is? At midnight or so?
A: No. Sundays are usually slow, so probably around 10:30, 11:00. You close around 9:30, but --
Q: You don't make any exceptions to that?
A: Well, I mean --
MR. LEONARD: Objection. "Exceptions." I don't --
BY MR. PETROCELLI:
Q: Meaning saying, "I'II take off that night. I'll make arrangements."
A: I'm not the boss, no. I mean, I wish I could.
Q: Did you ask?
A: If I could?
Q: Yeah.
A: No. I mean -- no.
Q: Okay. So what did Nicole say to you when you suggested Jackson's?
A: First she said yes.
Q: First -- was this a telephone call?
A: Yes.
Q: Okay.
A: I think.
Q: And then she changed her mind?
A: Yes.
Q: In the same conversation?
A: No. Later. Actually, the day of the recital.
Q: How did you find out that the plan had been changed?
A: She -- in the conversation she said, "We can't come. It's just a little bit too expensive, so we're just gonna go right up the street."
Q: How did Nicole inform you of that? By telephone?
A: I think so, yeah. Yeah, I called.
Q: Did she call you?
A: No. I called her because I wanted to get some special stuff ready and everything.
Q: So it's fair to say that as of the 12th, the morning of the 12th of June, it was still your understanding that the family was all going to Jackson's. Right?
A: Yes, sir.
Q: And you had made appropriate reservations for them there?
A: Yes.
Q: And what kind of reservations did you make?
MR. LEONARD: Objection. Vague. Why don't you ask him the question.
BY MR. PETROCELLI:
Q: Your lawyer is comical. He's trying to make me laugh. He's trying to actually get me off track.
MR. LEONARD: How could I do that with you, Dan.
MR. PETROCELLI: You're very good at it, too. I'm doing a very poor job of --
MR. LEONARD: You're doing an excellent job.
MR. PETROCELLI: -- staying focused here.
Q: Anyway --
MR. LEONARD: What kind of reservation? Do you mean how many people did he make a reservation for?
MR. PETROCELLI: Well, it's a little broader than that --
MR. LEONARD: Come on.
MR. PETROCELLI: -- but let's ask your lawyer's questions.
Q: How many people?
A: I don't remember. I remember --
Q: That's why I didn't ask that. Okay. You don't remember.
A: No. I -- no.
Q: A large group, though. Right?
A: Yeah. It was just -- yeah, I was --
Q: And you were expecting your father to be there also. Right?
MR. LEONARD: Objection.
BY MR. PETROCELLI:
Q: You can answer.
A: I was expecting whoever to show up.
Q: Including your father. Right?
A: Yeah.
Q: Including Sydney. Right?
A: Oh, absolutely.
Q: Including Justin. Right?
A: Yes.
Q: Including Nicole. Right?
A: Yeah.
Q: And Nicole's family. Right?
A: I didn't know -- parts of Nicole's family. I didn't know who was coming --
Q: You knew Lou and Judy were coming. Right?
A: Yeah, I knew those two were.
Q: You didn't know about the sisters. Right?
A: I didn't know if they were coming.
Q: And their children.
A: I didn't know about that.
Q: Okay. What kind of restaurant is Jackson's?
A: What do you mean?
Q: What do they serve there?
A: What kind of food?
Q: Yeah.
A: It was --
MR. LEONARD: Good food.
THE WITNESS: Yeah. It was California/French type food.
BY MR. PETROCELLI:
Q: Did you say sushi before?
A: No. I was sous- --
MR. LEONARD: Sous. Sous chef.
THE WITNESS: The assistant to the chef.
MR. PETROCELLI: Oh.
MR.LEONARD: You don't know what sous chef means?
THE WITNESS: S-o-u-s.
MR. PETROCELLI: No, I don't.
Q: Where were you when you had this phone call with Nicole?
A: I'm not sure. I think I might have been at the apartment, at my house, at my apartment.
Q: Let me go back to my notes and see where you were living at that time.
A: Sycamore.
Q: You were living on Sycamore.
A: Yes, sir.
Q: Okay. And you were no longer living with [Name Deleted].
A: No, sir.
Q: Was [Name Deleted] going to be at this recital dinner at Jackson's?
A: No. She didn't know anything about it, I don't think. I don't remember if she knew anything about it or not.
Q: Okay. What time did you leave to go to work that day?
MR. LEONARD: "That day"?
MR. PETROCELLI: The 12th.
THE WITNESS: 3:00 -- I usually got to be there around 3:00 o'clock.
BY MR. PETROCELLI:
Q: Where is Jackson's located?
A: It's located on Beverly between La Cienega and Robertson.
MR. LEONARD: I think you have to sit up.
THE WITNESS: Oh, I'm sorry. Between -- I'm sorry -- Doheny and Robertson. Swall is the closest cross street.
MS. ROIT: Impossible to get into for lunch.
MR. PETROCELLI: Okay.
THE WITNESS: What?
MS. ROIT: Impossible to get into for lunch.
BY MR. PETROCELLI:
Q: You think you left to go there around 2:30 or so?
A: Probably. Sunday, I was probably -- yeah, around 2:30 or so.
Q: Did you see Nicole at any day -- at any time on June 12?
A: No.
Q: Did you see her at any time on June 11?
A: No, I don't think so.
Q: Did you speak to her on June 11, June 11 being Saturday?
A: I think that that's when we were talking about the reservations, about coming into the restaurant.
Q: You told me -- I thought you said before that the conversation when she told you she's not going to go there, to Jackson's, occurred on the 12th.
MR. LEONARD: But he also told you that the previous day there was a conversation about reservations. That's the state of his testimony.
MR. PETROCELLI:
Q: What is it?
A: What is what?
Q: What is your testimony on this?
A: I talked to her on, let's see, Friday or Saturday about coming into the restaurant, and she called me the day of the recital or I talked to her the day of the recital and she said that she couldn't --
Q: Okay.
A: -- because it was too expensive.
Q: But when you talked on the Friday or Saturday --
A: You said the 11th.
Q: Excuse me. Let me finish my question.
A: Sorry.
Q: Let me finish my question.
A: Okay.
Q: When you spoke to her on Friday or Saturday --
A: Okay.
Q: -- about the family going to Jackson's after the recital --
A: Yes.
Q: -- she did not then tell you that the family would not be going to Jackson's. True?
A: This was what date, now?
Q: On the Friday or Saturday.
A: Yes.
Q: Okay. And it was only until Sunday, on the 12th,when she told you for the first time that the family would not be going to Jackson's. True?
A: Correct.
Q: Now let's go back to the Friday or Saturday conversation. Can you give me your best recollection as to which of the two days it was?
A: No.
Q: Did you work that Saturday, June 11, from 3:00 to closing?
A: Yes.
Q: Did you work that Friday --
A: Yes.
Q: -- from 3:00 to closing?
A: Yes.
Q: Did you have the conversation with Nicole while you were at work?
A: No. I think I was home.
Q: So it would have been before 3:00 o'clock?
A: Yes.
Q: Okay. Who called whom?
A: I don't recall.
Q: Tell me the substance of the conversation.
A: It could have been -- I don't know what it was. When we got on the subject of the recital, we spoke about -- that's when -- when we got on the subject of the recital, that's when we spoke about dinner arrangement or whatever, but I don't remember why I called in the first place.
Q: Okay. And can you recall anything else --
A: Or if she called in the first place.
Q: Can you recall anything else that Nicole and you discussed other than the dinner arrangement?
A: No, I don't think there was anything else discussed.
Q: Tell me what was said by Nicole and you regarding the dinner arrangements in this conversation which occurred either on Friday or Saturday June 10 or June 11.
A: Well, I think she wanted me to go, and I said I couldn't. I couldn't get out of it. And I said, "Why don't you guys come into the restaurant?" And she thought it was a great idea. So we were getting all excited about her coming to the restaurant, or the kids coming to the restaurant, the whole family coming to the restaurant. I was excited, because I didn't want to have to miss another recital, and, like I said, I felt like finally, you know, I'd be able to take care of everything.
Q: You had had a previous conversation with her about going to the recital when you suggested that she come to Jackson's also. Correct? You previously testified that it was a long time before the recital.
A: No. It's just a standing -- everybody knows that the recital's coming up, but I never said anything about coming to the restaurant.
Q: Well, before you testified that when she first informed you about the recital, it was long before the recital, not the day before. True?
A: Yeah, but we never said anything about coming to the restaurant.
Q: Okay. Now, in that conversation you --
MR. LEONARD: Which conversation?
BY MR. PETROCELLI:
Q: The conversation when she first informed you of the recital. You told me --
A: She's never informed me of the recital.
Q: Excuse me. My question's not over.
A: I'm sorry.
Q: You previously testified that you were first informed of this recital not one or two days before, but well in advance of it. Correct?
A: Right. Right.
Q: And you had a telephone conversation with Nicole wherein she informed you of the recital and invited you to attend. Right?
A: Right. Yeah.
Q: You told her at that time you could not attend because it was on a Sunday and you worked on Sunday. Correct?
A: No, not necessarily, no.
Q: Well, what do you mean, "not necessarily"? Did you or did you not say that?
A: No. No, not -- when she told me a long time before that her recital is coming up, I didn't say I couldn't go. I just -- it was like, "Oh, okay her recital is coming up." I never said I was going to go or anything like that. Finally, when she reminded me soon before, I knew I had to work on Sundays; I couldn't go, so I said, "Why don't you just come into the restaurant."
Q: Is it your testimony that the first time that you and Nicole discussed that she would come and take the family to Jackson's was on this Friday or Saturday before the 12th of June?
A: Yes.
Q: And she thought that was a good idea, and so did you. Correct?
A: Yes. Yes.
Q: And that's what the two of you discussed. Right?
A: Yes, sir.
Q: And you then proceeded to make a reservation at Jackson's for the family. Right?
A: Yes.
Q: Okay. Did you and Nicole discuss your getting a ticket or how you would get a ticket to the recital at any time?
A: No, I don't think so. I don't remember.
Q: Is the first time that you informed Nicole that you would not be attending the recital on the 10th or 11th of June?
A: I believe so.
Q: Do you know whether she had procured a ticket for you in the meantime?
A: No, I don't.
Q: Did anybody ever talk to you about a ticket?
A: No.
Q: Cathy Randa? O.J. Simpson? Gigi? Anybody?
A: No.
Q: Okay. Did you and Nicole discuss the menu in this conversation?
A: No, sir.
Q: What would be served and so forth?
A: No.
Q: Had Nicole ever been to Jackson's?
A: No.
Q: Did she ask you what kind of food was served there?
A: Yeah.
Q: In this conversation --
A: No, not in this conversation. Before.
Q: Before she had?
A: Yeah. I say, "I'm working at Jackson's." "What kind of food do they have?" I answered the question.
Q: Did she answer the question?
A: No. Like a long time before, when I got the job in the first place.
Q: When did you first start working there?
A: Let's see. It would have to be March of -- March or February of '94, I think. I think.
Q: Okay. And --
A: Or -- no. '93.
Q: '93. So from March of 1993 till the time of Nicole's death, to your knowledge she had never been Jackson's.
A: No.
Q: True?
A: Positive.
Q: True?
A: To my knowledge she's never been there.
Q: Okay. And did she ever tell you whether she had gone there?
A: No. I wanted her to come. This was -- she finally was gonna come.
Q: So you and her had talked from time to time about --
A: Yeah. I would like for her to taste my food and taste all my stuff.
Q: And you were going to cook the food.
A: Yes, sir.
Q: And you were going to cook the food for the family when they came after the recital. Right?
A: Yes, sir.
Q: Okay.
MR. LEONARD: I need to take a break.
MR. PETROCELLI: Okay. We will take a break then.
MR.LEONARD: With the teacher's permission.
MR. PETROCELLI: Yes, permission granted.
THE VIDEOGRAPHER: This is the end of tape No. l. The time is approximately 11:27, and we are off the record.
(Recess.)
THE V1DE0GRAPHER: We are on the record. The time is approximately 11 :44.This is the beginning of tape No. 2.
BY MR. PETROCELLI:
Q: Let me go back and pick up a little bit of chronology on your background. After the year at USC, what did you do?
A: With my life?
Q: Yes.
A: The whole year? The summer -- the rest of the summer I lived with a girlfriend --
Q: Who was that?
A: Cici. After that I moved in with my mother and worked.
Q: Did you move into a house with your mother?
A: Yeah. Yeah, first.
Q: And where did you work?
A: I worked at Atlas Bar and Grill.
Q: As what?
A: Then I was a busboy.
Q: Full time?
A: Yeah.
Q: And how long did you work there?
A: I think I worked there about seven months.
Q: What year is this?
A: '89 --
Q: What did you do --
A: -- to '90. Sorry?
Q: What did you do next?
A: I moved on to the Border Grill in Santa Monica, working.
Q: What's the name of the place?
A: Border Grill.
Q: Border Grill? And what years there?
MR.LEONARD: Did you ask him what he did?
BY MR. PETROCELLI:
Q: What did do you there?
A: I started cooking. I started to cook then.
Q: Chef.
A: No, I wasn't the chef yet. I was working my way there. I wish I could start being the chef.
Q: I am not familiar with the hierarchy of cookers.
A: You just don't become a lawyer. You gotta go to school and stuff. Right? You gotta start somewhere.
Q: This is true.
A: Same thing with, you know, with cook -- I just started cooking at the Border Grill, and the year --
Q: Sort of like being a paralegal, I guess. Okay. So you started cooking. What years were you at Border Grill?
A: I was there for the next -- after that the next probably seven, eight months.
Q: 1990?
A: Yes.
Q: What did you do then?
A: I was working, living at a --
Q: I want you to do this in chronological order, if you could, please.
A: You need a job resume? I mean --
Q: Well, your jobs --
MR. LEONARD: Just keep going:
THE WITNESS: Oh, okay.
BY MR. PETROCELLI:
Q: Your jobs and whether you're going to school. I would --
A: Okay. Yeah. I was living -- I was living at my mother's.
Q: Yes.
A: I moved into the apartment at some point around the corner.
Q: Yes.
A: She had the apartment. I just finally cleaned it up and moved in.
MR. LEONARD: I think Mr. Petrocelli is interested in your employment history at this point.
MR. PETROCELLI: Well, that's fine. He was just doing it by reference to where he was living.
THE WITNESS: Oh, sorry.
BY MR. PETROCELLI:
Q: You can continue.
A: I was working at the Border Grill, and then I changed jobs -- after about seven months, seven, eight months, I think, I changed jobs to the -- to Bravo Cucina in Santa Monica, couple blocks away, and worked there for a little bit over a year, maybe two years, I think, and after that restaurant --
Q: What did you do there?
A: I was cooking there as well.
Q: What years were these?
A: Let's see. That would be going --
Q: '91-92?
A: Not to '92, no. So it would be going to '91 maybe. It would be just a year then. It wouldn't be '91. It would be '90. It would be '89 and '90.
Q: '89 and '90?
A: Or '90 and --
Q: When you had the assault at the Revival Cafe, were you working at that cafe?
A: I was working at the cafe, yes, so let's go from there back.
Q: According to my document here, you were working at the Revival Cafe in December of 1992.
A: Okay.
Q: If that helps you at all.
A: Yeah, that does. Thanks.
Q: After Bravo Cucina, then where?
A: After Bravo was -- where did I work after Bravo. I went to Cafe Laboheme in West Hollywood. I was there for only a couple of months.
Q: Cooking?
A: Cooking. After there -- after there I believe I went to Revival.
Q: Revival Cafe?
A: Yeah, and I helped to open up that place with Paul and somebody, a couple other people.
MR. LEONARD: You have to speak up.
THE WITNESS: I'm sorry. I -- should I repeat it?
BY MR. PETROCELLI:
Q: Helped open up that place with Paul and some other people. "Paul" being Paul Goldberg --
A: Yeah.
Q: -- the man who --
A: Yeah.
Q: -- you assaulted.
A: Yeah, the man where we got into a fight. I just didn't press charges. He did.
Q: Okay. How long were you cooking at -- were you a cook or a chef at the Revival Cafe?
A: Yeah, I was more of a consultant. I hired a kitchen staff for him.
Q: Okay. How long were you there?
A: It was just three months. I was just there to consult --
Q: And that was --
A: -- and to help open the place.
Q: That was during the time frame that included December of 1992, according to the --
A: Yeah.
Q: -- complaint of Mr. Goldberg.
A: Well, that would have been -- yeah, I guess that would have been the latter part of it, so it would have been a couple months before then. Right?
Q: Okay. And then after the Revival Cafe, what did you do?
A: After Revival I went to Jackson's, I think.
Q: Now we are in the beginning of 1993.
A: Yeah. That would be about right.
Q: And when did you -- what was your position at Jackson's again?
A: I started off as a line cook. There's a line with a bunch of different people.
Q: Then what?
A: I moved up to the sous chef, to the assistant.
Q: How do you spell that?
MR. LEONARD: S-o-u-s.
MR. PETROCELLI: S-o-u-s chef. Okay.
THE WITNESS: Uh-huh.
BY MR. PETROCELLI:
Q: Is that the position that you left when you left Jackson's?
A: No. Actually, I was the chef when I left.
Q: Okay. When did you leave Jackson's?
A: About six, seven months ago. No, no, not seven. About six.
Q: November of 19- --
A: I'm sorry. November. November --
Q: Of 1995?
A: -5.
Q: Were you fired?
A: No. I left.
Q: You just quit?
A: Yeah.
Q: And where did you go after Jackson's?
MR. LEONARD: If that's his present place of employment, I would like to also write that down.
BY MR. PETROCELLI:
Q: Is that a secret?
A: I would like for not everybody to be coming to my job. That would be nice.
Q: That's fine. Okay. Could you --
MR. LEONARD: Why don't you ask him the question if that's where he's working now.
MR. PETROCELLI: Is what?
Q: Is the next place --
MR. LEONARD: Yeah.
Q: -- after Jackson's where you are now working?
A: Yes, sir.
Q: And did you go work at that place right after November of 1995?
A: No. I've been working there about two months now.
Q: So you were unemployed for three or four months?
A: About three months.
Q: How did you support yourself?
A: What do you mean? I had money from Jackson's. I have a savings account.
Q: Does your dad support you?
A: No.
Q: Does he give you any money?
A: No. Not me, no.
Q: What do you mean, not you?
A: Just what I said: Not me. I'm a self-supported person. As a matter of fact, I pride myself on being self-supported.
Q: How long have you been self-supported?
A: Since we got this busboy job here. Since I got the busboy job at --
Q: Atlas Bar and Grill?
A: Atlas Bar and Grille, yeah.
Q: So since the late '80s you've been self-supported?
A: Well, in high school. While in high school. I mean, I've been working ever since I was 14.
Q: Your dad provides you no money for support?
A: Yeah, of course. In high school he did. I was living under his roof.
Q: Last five years?
A: No. I've asked a couple of times if I -- you know, I've been in a little bit of trouble and needed to pay the rent or something like that and asked for a couple bucks.
Q: Do you owe him any money?
A: No. I mean...
Q: What did you do between November of '95 and a couple of months ago?
A: Catered private parties and stuff like that.
Q: Did you work for a company?
A: No, not -- no.
Q: You did it on your own?
A: Yeah.
Q: During the course of your dad's criminal trial, you were working at Jackson's?
A: Yes, sir.
Q: The place that you currently work, what is your position?
A: I'm a line cook.
Q: And when did you start there? Two, three months ago?
A: Two months ago, not three.
Q: You work full time?
A: Yes, sir.
Q: Okay. Why don't you write it down on a piece of paper.
MR. LEONARD: Can we use your -- I'm running out of paper. Can we use yours?
MR. PETROCELLI: Yeah. I'll give you a pad if you run out of paper.
MR. LEONARD: Thanks, Dan. You're unbelievable.
THE WITNESS: Can I borrow your pen?
MR. LEONARD: That you can borrow. He wants the address, name, phone number, I guess.
MR.PETROCELLI: Yeah, name and address --
THE WITNESS: I don't know the phone number and the address. I could tell you where it is.
(Witness complies.)
MR. PETROCELLI: You can stamp that, David, as the next exhibit in order.
(Plaintiffs' Exhibit 182 was marked for identification by the reporter and was retained by Mr. Petrocelli.)
MR. PETROCELLI:
Q: Did you go to school at all after USC?
A: No, sir.
Q: What about culinary school?
A: No. I just started on-the-job training kind of thing.
Q: So you've taken no courses in school of any kind after USC?
A: No.
Q: That's true. Right?
A: Yes, sir.
Q: Okay. You hold no degrees of any kind?
A: No, sir.
MR. LEONARD: Other than high school.
BY MR. PETROCELLI:
Q: High school diploma?
A: Diploma, yeah.
Q: Were you ever interviewed by any lawyers or investigators retained by O.J. Simpson's criminal defense team?
A: Never interviewed, no.
Q: They never asked you where were you on the night of June 12 or anything like that?
A: I think maybe once. No, I don't think so. Well, yeah, I guess so.
Q: Who asked you?
A: Mr. Cochran. I think. I think he might have asked where I was and whatever.
Q: When was this when he asked you these questions?
A: Sometime early on in the trial. I don't remember exactly when.
Q: You and he met alone?
A: In his office.
Q: He asked you to come in to see him?
A: I think he asked me and my sister to come in to see him, just to have a conversation with him.
Q: And how long was your conversation with him?
A: No more than 10 minutes.
Q: Did you have a separate conversation from your sister's?
A: No.
Q: You were in together?
A: Yes.
Q: And what -- tell me about that conversation.
A: It was just a general conversation.
Q: What did he ask you?
A: He didn't really ask too many questions. He just -- besides, "How are you?" you know, "How's your mother?"
Q: Why were you brought down to his office?
MR. LEONARD: Objection. Calls for speculation.
BY MR. PETROCELLI:
Q: Why were you to your knowledge asked to go to this meeting at his office?
A: To talk to him.
Q: About what?
A: How we were, how we were holding up. I know Mr. Cochran from before this case.
Q: How did you know him?
A: Social event.
Q: He was a friend of yours?
A: Yeah. I wanted to meet the guy who was going to defend my father I mean...
Q: This was before the trial started?
A: Yeah.
Q: Were you interviewed by anybody else?
A: No.
Q: Any members of the prosecution team, the District Attorney's Office --
A: No.
Q: -- or the Los Angeles Police Department?
A: No, sir.
Q: Have you read any discovery materials, deposition transcripts, trial transcripts, any other documents from the criminal or the civil case?
A: No, I haven't.
Q: Nothing?
A: Nothing.
Q: Okay. Have you been briefed by anybody about this case or the criminal case other than your short conversation with Dan Leonard?
A: No. Uh-uh.
Q: Have you watched the videotape put out by O.J. Simpson?
A: Yeah, I just recently saw that.
Q: When?
A: About a month ago.
Q: Who were you with when you saw it?
A: I was by myself.
Q: Was that the first time you saw it?
A: Yes, sir.
Q: Were you present during the making of it?
A: No.
Q: Not at all?
A: No.
Q: Did you talk to your father, after you saw it, about it?
A: No, I didn't. I think I need to explain something about the present during the making of it. I came home one time -- I came home when they were doing it, saw all the cameras and everything, and left. So if you're talking about as far as being present, I never -- once I saw all the action going on, I turned around and left, because I'm just not down with all that camera stuff.
Q: You're not what?
A: I don't -- I'm not -- I'm not -- I don't like that. I don't really like cameras and all that crap. I think it's a bunch of bull.
Q: Cameras?
A: Well, you know, this case and everything kinda made me sick of cameras, so --
Q: The criminal case?
A: I didn't really want to be around all that, so I decided to leave.
Q: Did your father consult with you about the making of this video?
A: No, he didn't.
Q: When was the first time you found out that it was being made?
A: Then.
Q: When you walked upon the scene of camera equipment and camera crews?
A: Yes, sir.
Q: And did you ask someone, "What's going on here?"
A: Yeah.
Q: Who?
A: I don't remember.
Q: What was the answer you got?
A: "We're doing the video." I remember hearing something about the video, so I was aware of what they were talking about.
Q: What do you understand the purpose of the making of that video to be?
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
BY MR. PETROCELLI:
Q: You may answer
MR. LEONARD: Vague.
If you know.
BY MR. PETROCELLI:
Q: Well, when he objects, you can still answer. This is --
MR. LEONARD: He knows that, and he has been doing it consistently.
BY MR. PETROCELLI:
Q: Yeah, just so you understand and don't change your answers based on any of the objections.
MR. LEONARD: I object to that statement.
MR. PETROCELLI: Some witnesses may not understand that they're supposed to --
MR. LEONARD: Are you suggesting that he has changed any answers? And if so, let's find out right now. You show me where you think he has changed an answer.
MR. PETROCELLI: I don't know if he has or not. I just don't want him to.
MR. LEONARD: Well, he's not doing it. Okay?
MR. PETROCELLI: Well, that would be nice. I don't want him to be coached.
Q: Anyway, can you answer the question, please?
MR. LEONARD: Well, Dan, you want to repeat the question, because I think it's very vague, and I don't know how he would know that, but...
BY MR. PETROCELLI:
Q: What is your understanding about why that videotape was made?
MR. LEONARD: Objection. Vague, calls for speculation, lack of foundation.
BY MR. PETROCELLI:
Q: You can answer.
A: My understanding is for two reasons: One reason being the fact that he wanted to explain his side of the story, one reason. Another reason is that financially he has a right to earn money as much as anybody else does. Two reasons.
Q: On what do you base those reasons? Conversations with him?
A: Yes, sir.
Q: Were you troubled at all when you found out that your father was going to make this video?
MR. LEONARD: Objection. I don't know how that could possibly be relevant to any issue in this case or lead to any relevant evidence.
MR. PETROCELLI: The fact that --
MR. LEONARD: I mean, seriously.
MR. PETROCELLI: The fact that O.J. Simpson made this video to me is perhaps the most probative evidence of his guilt.
MR. LEONARD: Well, I don't share your opinion, but that's not what you asked.
MR.PETROCELLI: It doesn't make a difference if you and I agree. It goes to consciousness of guilt.
Q: You may --
MR. LEONARD: But you are asking him if he was troubled. How could that lead to any probative material, relevant evidence?
MR. PETROCELLI: Because the next question is going to be an appropriate follow-up question I do not want to preview, which I am sure you would agree would be an appropriate question.
MR. LEONARD: Well, I am objecting, but go ahead.
THE WITNESS: What's the question?
MR. LEONARD: The question was, were you troubled by the making of the video?
THE WITNESS: I wasn't troubled by it, no.
BY MR. PETROCELLI:
Q: Did you have a conversation with O.J. Simpson about it?
A: No, I didn't have a conversation with O.J. Simpson about it.
Q: Did you ever say, "Dad, why are you doing this?"
A: No.
Q: Okay. But he came and told you why he was doing it. He gave you those two reasons that you told me.
A: Yes.
Q: Okay. Did you participate with your father in going to Nicole's grave site to take photographs --
A: No.
Q: -- that were sold to tabloids?
MR. LEONARD: Objection --
THE WITNESS: I don't know anything about that.
MR. LEONARD: -- lack of foundation.
BY MR. PETROCELLI:
Q: Do you know whether your father has had photographs of Nicole's grave site sold to the tabloids, or sold to any organization, for that matter?
A: Well, the Browns do. I don't know about my dad, no.
Q: Well, I move to strike your answer regarding the Browns since it's non responsive to anything I remotely asked you.
A: I apologize.
MR. LEONARD: I thought we were reserving motions to strike.
MR. PETROCELLI: I know, but --
MR.LEONARD: Are we changing the rules at this point?
MR. PETROCELLI: No. That was inappropriate.
MR. LEONARD: No, but I want to know if you're changing the rules.
MR. PETROCELLI: If you want to attack the Browns, you may do so at your own time.
THE WITNESS: I don't want to. That's my family.
BY MR. PETROCELLI:
Q: Exactly. I don't know why you are talking about the Browns.
A: Well, you're talking about my dad.
Q: That's right, not the Browns. So you want to answer my question?
A: Knee jerk. Sorry. What's your question?
Q: The question was whether you are aware of whether or not your father, O.J. Simpson, has been selling or has sold photographs of Nicole's grave site.
MR. LEONARD: Objection. Lack of foundation. You can answer.
THE WITNESS: I -- I was never aware of it until you just said it.
BY MR. PETROCELLI:
Q: You have no knowledge of that?
A: No.
Q: Did you participate in any photographs following your father's release from prison?
MR. LEONARD: Objection. Vague. I don't understand that.
MR.PETROCELLI: Well, that's a good objection.
MR.LEONARD: Well, thanks. Was that the only one so far that was good?
MR. PETROCELLI: No. There was one other, but I'm not going to tell you which one.
MR. LEONARD: Okay. Okay.
BY MR. PETROCELLI:
Q: Do you know whether your father sold any photographs to anyone following his arrest from following his release from prison?
MR. LEONARD: Objection. Lack of foundation.
BY MR. PETROCELLI:
Q: You're looking at me like you're not supposed to answer. What --
A: You know, because I don't know who is winning here or who has won.
Q: Exactly. Exactly.
A: You guys are like two little kids.
Q: Let me explain something to you. After he objects, you simply ignore everything that he says and you answer the question.
A: Okay.
Q: Unless he instructs you otherwise. Could you please direct your client to do so?
MR. LEONARD: Yeah, he knows that. He hasn't done anything --
MR. PETROCELLI: He does not appear to know that.
MR. LEONARD: No. You are characterizing how he looks. Okay? We have a video camera that's going to capture that --
MR. PETROCELLI: Absolutely.
MR. LEONARD: -- so I don't appreciate your characterizations of what you think he looks like. And you know what the truth is in the case, and you also have this power to know, you know, how he looks.
MR. PETROCELLI: And you know what the truth is also.
MR. LEONARD: So let's go.
MR. PETROCELLI: Okay.
Q: Did you understand that you are to answer the questions --
A: Okay.
Q: -- whether or not he objects, unless he, your lawyer, tells you not to answer.
A: Okay. Thank you.
Q: Okay? Just so you understand that. The objections are for the court to worry about later on. You are not to be concerned about them.
A: Understood.
Q: Okay. There is no judge here. That's why --
A: That's why I get a little confused and I wonder what am I supposed to do. Watching too much TV.
Q: And it was that confusion that was apparent to me, and that's why I'm responding. Okay?
A: Okay. Can we repeat -- can you repeat the question?
Q: Yes. Are you aware of any photographs that have been shot or taken involving you, your father, your family, after your father's release from prison, that were then sold for money?
A: Yeah.
Q: Which ones?
A: Okay. For a magazine, but I don't remember the name of the magazine.
Q: The Star?
A: Might have been it.
Q: Okay. And did you sit for some of those photographs?
A: Yeah, a couple of them.
Q: Where were the photographs taken?
A: At a friend's house. Friend of my father's.
Q: Whose house?
A: Don Ohlmeyer's house.
Q: Is he a good friend of yours also?
A: Of mine?
Q: Yes.
A: Yeah, I mean, I think he's a nice guy.
Q: When were those photographs at Don Ohlmeyer's house taken?
A: Not too long after, so November maybe.
Q: Of 1995?
A: -5.
Q: And who was present besides yourself?
A: My sister, my father, Mr. Ohlmeyer. It was his house. His assistant -- I don't know her name -- and a photographer.
Q: Okay. Did you receive any money?
A: Yeah, I did.
Q: How much?
A: $25,000.
Q: How long were you there?
A: About half hour, 45 minutes, maybe an hour.
Q: And for the half hour to an hour, you got $25,000?
A: Yeah.
Q: Okay. What were the pictures of ?
A: I think there's a picture of us sitting around a table eating, a picture of the three of us, my mother -- my sister, my father and I standing on some stairs. Just took a bunch of...
Q: Was Marquerite Simpson there?
A: No.
Q: How much did Arnelle get?
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: Same as me, I believe. I didn't see it.
MR. PETROCELL1:
Q: $25,000?
A: Yes.
Q: And how much did O.J. Simpson get?
A: I don't know.
MR. LEONARD: Objection. Lack of foundation.
BY MR. PETROCELL1:
Q: Who gave you the check?
A: It came in the mail.
Q: It's from the organization who took -- who is printing the picture, or was the check from your father or some intermediary?
A: It was I think they probably mailed a lump sum to my father, and he -- I don't remember. I don't remember exactly what was on the check.
Q: How much other money have you made as a result of these murders?
A: Nothing.
Q: Just the 25,000?
A: Yeah, that.
Q: Have you been approached?
A: Yeah.
Q: By whom?
A: Everyone.
Q: You mean tabloid organizations?
A: Yes. Talk shows, you name it.
Q: Okay. For money?
A: Yeah.
Q: Okay. Have you -- do you have any plans to earn any more money or make any other deals --
A: No.
Q: -- with regard to this whole aftermath of the murder?
A: No.
Q: Do you have any current agreements in place by which you are to receive any further money beyond --
A: Didn't like it the first time. I'm sorry.
MR. LEONARD: You have to let Mr. Petrocelli --
THE WITNESS: Sorry.
BY MR. PETROCELL1:
Q: What didn't you like about receiving the $25,000?
A: I just -- I didn't feel clean. It didn't feel right.
Q: And why did you keep the money?
A: I needed it.
Q: Did you tell your father you didn't feel right; you didn't like this?
A: I said that I wasn't gonna do it anymore. I said I just wasn't gonna do -- be a part of anything like that.
Q: And what did he then say to you?
A: He said "Okay."
Q: Do you know whether -- did he tell you what his feelings about taking the money were?
A: Taking what?
Q: The money. The money. Money for these photographs.
A: Yeah.
Q: What did he say?
A: I told you before.
Q: You said you didn't like how it felt, "didn't feel clean." What did he say to you about how it felt to him, if anything?
MR. LEONARD: Objection. Lack of -- well, okay.
THE WITNESS: He said that with as much money as everybody else has made off of him for everything and as much money as he's lost because of this, and I believe rightly so, because he's not -- he hasn't done anything, he has a right to get some of his money back. This is the only -- he doesn't feel necessarily good about it, the fact -- the reason why he has to do it, but he's got to do it. He can't just go out to Hertz and get a job because of people have called him a killer and says that he's murdered Sydney and Justin's mother. So he can't just go get a job; he's not Mr. Squeaky Clean anymore because of everything that everybody's called him, so he needs to get money the way he can get his money.
BY MR.PETROCELLI:
Q: I know that's how you feel, but is that what he told you?
A: You asked me for --
Q: No. My question was what he said to you.
MR.LEONARD: If anything.
MR. PETROCELLI: Yes, if anything.
THE WITNESS: Generally -- generally it was -- that was my understanding of what he said.
BY MR. PETROCELLI:
Q: Okay. Do you know whether he has sat for photographs for money other than on that one occasion at Mr. Ohlmeyer's home?
A: I don't know.
Q: You don't know?
A: I don't know if he has.
Q: You have no knowledge?
A: I don't know if he has for money sat for photographs, no.
Q: Or has he sat for photographs for any other company or organization?
A: I don't know.
Q: You don't have any knowledge at all?
A: No.
Q: You don't have to have been there. You could have heard from somebody else.
A: Exactly. And that's why I said, "I don't know." I don't know what he's done for charity. I don't know what he's done for money.
Q: You have no information on whether he has participated in sitting for photographs other than on that one occasion.
MR. LEONARD: Well, now you have changed it, because before you said for companies or something like that. Are you talking about whether he has been photographed by anyone?
MR. PETROCELLI: No, no, no. I mean where someone comes into the house and takes photographs. He may not know the financial arrangements, but he may know that such photographs were taken.
MR. LEONARD: But you are limiting it to you know, media or entities that are -- I mean, seriously --
MR. PETROCELLI: Yes.
MR. LEONARD: -- because I can tell you that, you know, he's probably had thousands of photographs taken from, you know, people in the street.
BY MR. PETROCELLI:
Q: Do you understand my question?
A: I do, and that's what I said: I don't know. I don't know what he got money for or what he didn't. I don't know.
Q: Okay. Besides these photographs, what money are you aware that your father, O.J. Simpson, has made as a result of these murders?
MR. LEONARD: Object. "As a result of the murders." But go ahead.
THE WITNESS: I don't know.
BY MR. PETROCELLI:
Q: What deals has he made?
A: Besides the tape?
Q: The videotape, you mean?
A: Yes.
Q: Yes, besides the videotape and besides the money received at the -- from the Ohlmeyer photographs.
A: I think autographs. Autographs.
Q: He has sold his autograph?
A: Yeah. Autographed balls.
Q: Do you know whether O.J. Simpson has signed memorabilia from the trial, such as pictures of the Bronco and things like that?
A: Pictures of the Bronco, I don't know about that.
Q: Pieces of evidence from the trial?
MR.LEONARD: Object. Lack of foundation.
BY MR. PETROCELLI:
Q: You may answer.
A: I don't know. I see things on TV, but I don't know what -- to believe what's on TV or not. So I may see Home Shopping Network. They say they got a football card signed from him. I don't know if it's true or if it's not.
Q: I am not talking about sports memorabilia. I am talking about things that have to do --
A: That have to do with the case. I'm sorry.
No, I don't know anything about that.
Q: You said previously that if no one was available to buzz you in at Rockingham, you would climb the fence.
A: Uh-huh. Yes.
Q: Where have you ever climbed the fence at Rockingham?
A: What do you mean, "where"?
Q: Name all the locations.
A: Just down on Ashford, there's a tree that comes through the wall, and you just kinda -- it makes it easier to hop the fence that way. The tree comes through the wall and then forks. You can just grab on and hop over. I've been doing it ever since I was a little kid. That was actually a shortcut to get to my friend's house, so...
Q: If you wanted to hop onto the property at some other location, not on Ashford, how could you do so?
A: You talking about the whole house?
Q: Yes. Let's say you wanted to sneak in so no one would see you. Let's assume there was a person sitting on Ashford, and you didn't want that person to see you, and it was at nighttime, and you wanted to get into the house. How could you access the property?
MR. LEONARD: Objection. Lack of foundation, calls for speculation.
MR. PETROCELLI: I thought I gave you a pretty good foundation.
Q: Anyway, you can answer.
MR.LEONARD: And to the extent you are giving him a hypothetical, it's an incomplete one. I don't know what you're doing. But go ahead.
THE WITNESS: There's an adjoining gate from our next-door neighbors, our old -- former next-door neighbors, the Von Vatts, on Ashford and Bristol.
BY MR. PETROCELLI:
Q: That adjoining gate is where the tennis courts meet?
A: Yes, sir.
Q: On either side of that gate there is a tennis court --
A: Yeah.
Q: -- one on the Von Watts property, one on the Simpson property?
A: Yes, sir.
Q: So -- and how could you get onto the Von Watts property?
A: You could --
Q: Just walk up?
A: Well --
Q: Let's say you didn't want them to know. Let's say you were a burglar, okay, and you didn't want them to know. Could you just run up -- run into the Von Watts' backyard from the front of their house and then go through that gate and get to Rockingham?
A: I'm not a burglar. I don't know. I couldn't tell you.
Q: Are there any other places, other than that fence, that adjoining gate on the Von Watts-Simpson boundary line, by which you could get to Rockingham?
MR. LEONARD: Objection. I mean, that's vague. It's overbroad. You mean at any point in time?
MR. PETROCELLI: Nighttime.
MR. LEONARD: Oh, nighttime. Now we are at nighttime?
MR. PETROCELLI: Yes. We don't want to be seen at Ashford either.
MR. LEONARD: Okay. I object. This is --
BY MR. PETROCELLI:
Q: You can answer.
MR.LEONARD: I don't know what purpose this is serving. Go ahead.
THE WITNESS: You're asking if a normal person wanted to break into a house --
MR. PETROCELLI:
Q: Person of your father's height and strength and build.
MR. LEONARD: Okay. I am going to object. You know, it's an incomplete hypothetical, if that's what you're asking him. You are asking for an opinion.
MR. PETROCELLI: Why are you so concerned about this?
MR. LEONARD: I'm not concerned. I am concerned that the questions are
appropriate. I am doing what I'm supposed to do as a lawyer.
MR. PETROCELLI: Okay. You've made your objections.
MR. LEONARD: He can answer. I am not instructing him not to answer.
MR. PETROCELLI: You are taking up a lot of time, though.
Q: Go ahead.
MR.LEONARD: That from Dan Petrocelli? Go ahead.
THE WITNESS: Can you repeat it?
BY MR. PETROCELLI:
Q: Why? You don't remember? Is it necessary --
A: Do you not want to repeat it?
Q: I don't want to waste time. You want me to repeat it, I will.
A: I asked you to see if you would, but if you don't want to, then I guess we're gonna be stuck. You don't want to waste time.
Q: No, I don't.
A: This is wasting time.
Q: I agree.
A: If you could just repeat it, I could answer it.
Q: Okay. I'll repeat it again. Okay?
A: Please, sir.
Q: If you wanted to get onto the property and not be detected by a person sitting or standing out at the Ashford gate, how could you get over the fence and get onto the property --
MR. LEONARD: Same objection.
BY MR. PETROCELLI:
Q: -- to the Rockingham house?
MR. LEONARD: Same objections.
HEWITNESS: Assuming you're a burglar or something like that, I guess you could do it any way you wanted to, anyway you wanted to, if you needed to bad enough. Right?
BY MR. PETROCELLI:
Q: You could climb the fence?
A: Climb the fence?
Q: Yeah. The fence could be physically climbed at any point --
A: The wall? Or -- I mean, you talking about four sides of the property. You got to be more specific.
Q: Okay. What are the four sides?
A: You got Rockingham, Ashford, and you got the next-door neighbors of the Von Watts and whoever's next door to them.
Q: The Salingers?
A: No, it's not the Salingers. It would be Bristol, their backyard.
Q: Bristol.
A: And then you got the Salingers that are next door to us.
Q: Could you get over from the Salinger property onto your property?
MR. LEONARD: Objection. Calls for a conclusion, lack of foundation, vague, calls for speculation, incomplete hypothetical. I think that's it. You can answer.
THE WITNESS: At some parts I'm sure you could.
BY MR. PETROCELLI:
Q: Which parts?
A: Toward the gate, Rockingham gate, I bet you could get over there if you needed to bad enough. And that's about it. Toward the front -- toward the front part of the estate.
Q: I will show you a map, Mr. Simpson. This is -- this exhibit has been marked various times. The latest incarnation of it is Exhibit 179. We may end up marking it again.
MR. LEONARD: You going to mark it again?
MR. PETROCELLI: I don't know. Maybe. We may not have to. It's also Exhibit 100, I think, too.
Q: You see this sketch of the Rockingham property?
A: Uh-huh. Yes.
Q: Now, this part here where I am pointing to, which is all darkened (Indicating), which is immediately to the -- immediately south of the Rockingham gate, is the Salinger property. Correct?
A: Yes, sir.
Q: And the Salinger property runs the boundary line of the Rockingham property. Right?
A: Yes, sir.
Q: Now, where were you just mentioning or just referring to a few minutes ago in your testimony that one could go onto the Salinger property and get onto the Rockingham property?
MR. LEONARD: Just -- I have the same -- registering the same objections. He can answer.
THE WITNESS: Okay. I would assume if they wanted to jump over, they could jump over anywhere from here to here (Indicating). It's just a plain fence.
BY MR. PETROCELLI:
Q: Okay. Now, could you --
A: I am sorry. From here to here (Indicating). From Rockingham --
Q: Yes.
A: -- where the gate begins, to probably just to where the garage or where the back door is.
Q: We will mark this again, this exhibit, so what I want you to do is I am going to start drawing a blue -- with blue pen the line starting at the Rockingham gate, and I will go all the way down to where you just mentioned. Tell me when to stop.
A: Right about there (Indicating).
Q: Okay. Right about there (Indicating)?
A: Maybe a little bit further. Maybe around here (Indicating). Yeah, well, here right where this wall starts (Indicating).
Q: Okay.
A: That's about as far as you can probably -- as you can --
Q: Now, why would it be not possible to climb the fence from the Salinger property onto the Rockingham property after that point where we just stopped?
MR. LEONARD: Same objections.
THE WITNESS: 'Cause there's a succession of trees that are probably about six inches apart and probably about four inches in diameter that are right -- I mean that go from here all the way back (Indicating). So, I mean, you'd have to be a pretty thin dude or female to slip through them. And they got branches.
BY MR. PETROCELLI:
Q: Is there a carport on the Salinger property?
A: Yeah. Yes.
Q: Are you able to get on that carport and then jump on over?
MR. LEONARD: Same objections.
MR. PETROCELLI: You are shaking your head no. Have you tried that, Mr. Leonard?
MR. LEONARD: No, no. I'm shaking my head at the question, that's all.
MR.PETROCELLI: You aren't suggesting the answer?
MR. LEONARD: No. In fact, the videotape will show the witness wasn't even looking at me at the time. You were looking at me.
MR. PETROCELLI: I am.
MR. LEONARD: But he wasn't. And the same objections.
MR. PETROCELLI: Okay.
MR. LEONARD: I will keep perfectly still now. And, no, I haven't tried it.
BY MR. PETROCELLI:
Q: Opposite the air conditioner --
A: Right.
Q: -- that is affixed to the -- a wall where it's marked "Kaelin's Room" --
A: Right.
Q: -- on this sketch here, Exhibit 179, opposite that air conditioner on the
Salinger property is a carport. Correct?
A: Yes.
Q: Okay. Are you able to -- could one get on that carport and then jump over at that point?
MR. LEONARD: Same objections.
THE WITNESS: I believe the trees don't stop at the top of the carport. They continue up. So not only would you have to be skinny, you'd have to be a pretty good hurdler.
BY MR. PETROCELLI:
Q: Okay. How --in June of 1994 there was no barrier to getting onto the Salinger property from the sidewalk. Correct?
A: Correct.
Q: So you could just walk up the Salinger -- walk up to the Salinger property and then walk all the way down till you hit those trees that you were just talking about. Right?
A: Correct.
Q: Okay. And anywhere along that path, you were saying that you might be able to jump the fence. Right?
MR. LEONARD: Same objections.
THE WITNESS: Yeah.
BY MR. PETROCELLI:
Q: Okay. And I will put a little --an end point line to denote where you were pointing as the sort of final point where one might be able to jump the fence. True?
A: True.
Q: Okay. Have you ever done that, by the way?
A: No.
Q: You never jumped that fence?
A: Not that side, no.
Q: The only side that you've jumped is on Ashford where the big tree is?
A: No. I've jumped Rockingham a couple times.
Q: You've jumped the fence on Rockingham?
A: Yeah, I used to when I was a kid jump off here all the time (Indicating). We used to have a tree in the front.
Q: Okay. Have you ever jumped the fence any other place besides on Rockingham or on Ashford?
A: Jumped the fence --
Q: Or hopped the fence or the wall or done anything else to get onto the Rockingham property.
A: No, just --
MR. LEONARD: I am going to object to the compound nature of the question.
MR. PETROCELLI: I am trying to cover all possibilities.
MR. LEONARD: I know you are --
BY MR. PETROCELLI:
Q: Go ahead.
MR. LEONARD: -- but I am trying to cover the record.
THE WITNESS: Just the two streets, Rockingham and Ashford. I've never --is it okay?
BY MR. PETROCELLI:
Q: Yes. That's my assistant.
A: Okay. There's the fence that goes next door, so there's no reason to jump over anything, and then all back here is bushes and stuff (Indicating), so...
Q: Where is the gate that goes to the Von Watts tennis court?
A: Well, this right here (Indicating), which is the street on the map --
MR. LEONARD: Hold on till he's paying attention so we don't have to do it twice.
BY MR. PETROCELLI:
Q: I am sorry, Mr. Simpson.
A: Okay. This corner (Indicating), which is Ashford and Bristol, would be moved out (Indicating), right, so you got the house here (Indicating). It would be right here (Indicating) --
Q: Where there is a gate?
A: Yeah, there's a gate. We have -- like there's a little outside house there or like kitchen kinda.
Q: Who owns that?
A: My dad. He still owns -- this is part of the -- it's not on the map. It's still part of the --
Q: Property?
A: -- property. And they have like an outside house that's between our two tennis courts, and there's a gate, just a chain-link gate.
Q: So the chain-link gate is between the two houses?
A: Uh-huh.
Q: It's not between the two tennis courts?
A: It's between the two properties -- yeah, between the two houses, exactly.
Q: What is that house or shed?
A: Ours --or my father's, rather, is -- there's a kitchen and refrigerator out there and stove. Theirs is like a whole -- they have like an office upstairs, and it's like you could live out there.
Q: What did your father in June of 1994 use that little cabana for, whatever it was? What was its purpose?
A: I don't know. If people were playing on the tennis court -- in June, I mean, I don't think he used it for anything.
Q: Prior to Nicole's death what was its purpose then?
A: It was for -- they built it out there for -- you know, the tennis court, if they were having parties, outside parties or something, and they wanted to use a stove or something.
Q: It's fully enclosed?
A: Yeah, it's -- yeah, so you would never have to go in the house. Everybody could just still get inside.
Q: And could you put an X where that little cabin is?
(Witness complies.)
Q: Okay.
A: Yeah. Well, actually, let me just put a big thing over here because it's about this big (Indicating).
Q: Okay. You have put three Xs in a box.
A: Yeah.
Q: And where is the gate onto the Von Watts' property?
A: It would be going -- it would be right here (Indicating).
Q: Okay. You put a circle and you colored it in.
A: Yeah.
Q: Okay.
A: Yeah. See how this goes out like that (Indicating)?
Q: Have you ever been in the path behind where it's designated as "Kaelin's Room" where that air conditioner is?
A: Yes, I have.
Q: And when was the last time?
A: Not for a while. So --
Q: After Nicole's death have you been back there?
A: Yeah. Well, that being the reason why: Just to check it out and see --
Q: Because there was a glove found there?
A: Yeah. Well, because of everything that happened.
Q: You wanted to go back there and -- for what purpose?
A: Curiosity.
Q: Who did you go with?
A: I never really -- I don't think I ever went with anybody. I went with one of the guards once, I think, at one point.
Q: And how many times have you done that?
A: I don't know. A couple times.
Q: Did you do it at night?
A: Never did it at night, no.
Q: It's very dark back there at night. Right?
A: Yeah. It's dark in the daytime.
Q: You -- when you went back there, how did you get back there? From around the garage?
A: No. I would just come straight down the driveway and go back.
Q: I'm sorry. Right here (Indicating). You --
A: Yeah, because there was a door in the garage.
Q: There's a little gate here (Indicating). Right?
A: No. It's open.
Q: Tell me what you did. You walked around the garage?
A: Yes.
Q: And then started to head in a southerly direction -- excuse me --
A: East.
Q: -- in an easterly direction down that path. Right?
A: Yes, sir.
Q: And how far did you go?
A: To the air conditioner. I never wanted to go under because spiders and s---.
Q: When you got to the air conditioner, you stopped?
A: Yes, sir.
Q: Were you physically able -- How tall are you?
A: About 5-10-1/2, 5-11.
Q: How much do you weigh?
A: About 230, 235.
Q: Were you physically able to go past that air conditioner by going around it rather that underneath it?
A: Around it?
Q: Yes. Is there sufficient distance between the air conditioner and the fence that --
MR. LEONARD: I am going to object. Lack of foundation, calls for speculation.
BY MR. PETROCELLI:
Q: -- to permit you to get by?
MR. LEONARD: Same objection.
THE WITNESS: I got kind of a big belly. I think I'd have a hard time doing it.
BY MR. PETROCELLI:
Q: Was the guard able to do it? Do you know?
MR. LEONARD: Object --
BY MR. PETROCELLI:
Q: Did he go past the air conditioner?
A: I don't think so.
Q: Okay. Did you try to go past it?
A: No. You know who I was with? I was with the cable guy. It wasn't the guard. I was back there with the cable guy. We were trying to get cable for a room back there.
Q: For whose room?
A: For both the rooms -- all the rooms.
Q: This was not --
A: Something was wrong with the cable in the whole house.
Q: In the whole house.
A: Yeah. And they were back there trying to fix the wires. I was with the cable guy back there.
Q: Did you go underneath the air conditioner?
A: No.
Q: Were you able to?
A: I wasn't trying to.
Q: Could you?
MR. LEONARD: Objection. Calls for speculation.
BY MR. PETROCELLI:
Q: Could you physically do it? Could you -- was there enough room so you could get underneath it and go past?
A: If I really wanted to, I mean, I guess I could -- have to. I mean --
Q: If you -- have you ever been past that air conditioner to the tip of the property?
A: Yes, but there were no two rooms here (Indicating) when I been back there.
Q: That was before the rooms were constructed?
A: Yes, sir.
Q: Okay. After -- you are referring to what is denoted on this map as "Arnelle's Room"?
A: In Arnelle's room.
Q: In Arnelle's room. And in your view, in your heart, one of those rooms is your room. Right?
A: In my heart of hearts.
MR. LEONARD: Put a J there.
BY MR. PETROCELLI:
Q: In your heart of hearts. Okay. Put a J. Is it this one right here (Indicating)?
A: Yes, sir.
Q: And that's the room you used to live in when you lived there during high -- before high school. Right?
A: High school. High school.
Q: High school.
A: All through high school.
Q: Okay. I will put a J there. Since the -- when were these rooms, which are now denoted as "Arnelle's Room" on Exhibit 179, constructed?
A: Jeez. I think it was -- I think '85.
Q: Okay. And since 1985 yon have not been past the air conditioner?
A: No. I was, but -- yes, I was.
Q: But what?
A: I went this way (Indicating) to see what was going on back here (Indicating).
Q: When did you do that?
A: In '95 there was a big rain, and it was all flooded back here, and I had to go -- we had to go back there. It was just a big mess. I had to go back there and --
Q: And when you say "back there," you meant --
A: Behind Arnelle's room. I'm sorry.
Q: And you did it by starting in the backyard and going around that way (Indicating) rather than from the front yard?
A: Coming down this walkway (Indicating) in front of Kato's room, this says "Kato's room," in front of my room, Jason's room, all the way back --
Q: Starting in the backyard.
A: Yeah, yes.
Q: And going around Arnelle's room?
A: Right.
Q: And coming around and then sort of coming back in a westerly direction?
A: But I never came down here (Indicating), no. I just went to here (Indicating). There was a water-a broken pipe that was spilling into these neighbors or something.
Q: Now, in June of 1994 was there any way that one could walk in the same path that you just described, around the yard, to go behind Kaelin's room, or was it blocked off by fences?
A: There's a fence right here (Indicating), right at Arnelle's room, to the tennis court.
Q: And how do you get on the other side of that fence?
A: You'd have to hop over.
Q: There is no gate?
A: I don't think so, no.
Q: So that area behind and around Arnelle's room was kind of cordoned off and not for use?
A: Unless you came down by the south side of the house. And go past the air conditioner.
A: Yes, sir.
Q: So there wasn't really any ready and easy access to that area. Right?
A: No, sir.
Q: And what was the purpose of that area? Bad question.
What was in that area in June of 1994?
A: Old -- from what I saw, it was like an old lawnmower, an old raft.
Q: Well, if you needed to get the lawnmower or the raft, you were out of luck?
A: You were out of luck.
Q: Okay. So it was just a bunch of junk --
A: Junk.
Q: -- back there.
A: Exactly.
Q: Okay. And there was no way to get there, not even from the tennis court. Right?
A: No.
Q: Okay. Does the same configurations exist, by the way, today?
MR. LEONARD: When you say "configuration," do you mean the junk and everything?
BY MR. PETROCELLI:
Q: The same fence, the same inability to get back to that area, or has it been changed?
A: No. It's the same.
Q: It's exactly the same?
A: Yes. As far as I know, it's the same.
Q: Have there been any structural changes to m the property since June of 1994?
A: Yes.
Q: What?
A: They put -- they put a barrier, kind of, all along the Rockingham gate and the Ashford gate.
Q: That's to prevent people from looking in?
A: Looking over the fence.
Q: And have there been any other changes made to the property?
MR. LEONARD: I am going to object. Lack of foundation.
BY MR. PETROCELLI:
Q: If you know.
A: No, not that I know of.
Q: Any change to lighting?
A: Yeah. Yes.
Q: What changes?
A: Movement lights, certain -- some movement lights.
Q: What are "movement lights"?
A: When -- they turn on at nighttime if you know, if it catches movement.
Q: New lights like that have been installed?
A: Yes, sir.
Q: Where?
A: See, this is the pool (Indicating). Right around the pool -- all along, actually, the perimeter.
Q: Meaning Ashford and Rockingham.
A: Yeah, at certain spots.
Q: In June of 1994 before Nicole's death, were there lights on the outside property that would go on when motion was detected, so called motion light?
A: Not that I knew of, no.
Q: Okay. And were there lights that would go on on the timer automatically?
A: Yes, there were.
Q: At nighttime?
A: Yes.
Q: What time would they go on in June of 1994?
A: I don't remember. I haven't been in the house.
MR. LEONARD: I'm hungry.
MR. PETROCELLI: Yeah, we're going to stop soon.
THE WITNESS: Let's just finish.
MR. LEONARD: Well, unless you -- he says, "Let's finish." You are not going to finish before lunch. Right?
MR. PETROCELLI: No. No. Let me just think what I can do on this right now.
MR. LEONARD: Dan, you could think of a thousand questions on that diagram.
MR. PETROCELLI: That's true.
MR. LEONARD: I know you now.
BY MR. PETROCELLI:
Q: Other than that one time when you went to look for the water damage, have you been back in that cordoned-off area behind Arnelle's room since Nicole's death?
A: No.
Q: Not at all?
A: No, sir.
Q: Do you know whether there were any sprinklers on the Salingers' property where it adjoins the Simpson property?
A: I don't know.
MR. PETROCELLI: Okay, now is a good time to break for lunch.
I will have this marked as the next exhibit in order with your markings on it, which will become Exhibit 183.
(Plaintiffs' exhibit 183 was marked for identification by the reporter and is attached hereto.)
THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 12:37.
(At the hour of 12:37 p.m., a luncheon recess was taken, the deposition to resume at 1:37 p.m.)
(At the hour of 1:39 p.m., the deposition of JASON LAMAR SIMPSON was resumed at the same place, the same persons being present.)
THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 1:39.
EXAMINATION (Resumed)
BY MR. PETROCELLI:
Q: The exhibit that we had you mark on that was the sketch of the Rockingham property we have marked as Exhibit 183, for the record.
The next exhibit in order, Exhibit 184, is the subpoena duces tecum served on you in connection with this deposition.
Can you mark that, please, Mr. Reporter.
(Plaintiffs' Exhibit 184 was marked for identification by the reporter and is attached hereto.)
MR. LEONARD: We never got a copy of this, by the way.
MR.PETROCELLI: Of course you did.
MR. LEONARD: Well, according to Baker's firm, we didn't.
MR.PETROCELLI: Well, it was served on Mr. Baker's firm.
Q: This was the subpoena that was served on you?
MR. LEONARD: Take a look at it.
BY MR. PETROCELLI:
Q: I know we had trouble seeing you so eventually the lawyers for Mr. Simpson accepted service on your behalf.
Where are all the documents that I asked from the subpoena?
A: I --
MR.LEONARD: You know what? I would like to take a five-minute break and review the subpoena with the client at this point.
MR. PETROCELLI: Well, I am in the middle of a question.
MR. LEONARD: Yeah, and I know, and I want to confer with my client.
MR. PETROCELLI: I would like him to answer the question first.
MR. LEONARD: Well, I would like to confer with him first.
MR. PETROCELLI: There is a pending question. You can't talk to him --
MR. LEONARD: Sure I can.
MR. PETROCELLI: -- and tell him what the answer is.
MR. LEONARD: I'm not going to tell him what the answer is.
BY MR. PETROCELLI:
Q: Let me ask you this: Have you ever read the subpoena?
A: I kinda quickly went over it. That was it. I didn't like sit down and --
Q: Why not?
A: I don't know. I just didn't.
Q: Well --
MR. LEONARD: Let me -- I would like to go off the record and confer with my client at this point.
MR. PETROCELLI: Well, I object.
MR. LEONARD: Okay, you can object. Let's go.
MR. PETROCELLI: I can't stop you; there is no judge here, but could you make it quick, please?
MR. LEONARD: Yeah, two minutes.
MR.PETROCELLI: I noticed that you were working with your client in the conference room.
MR. LEONARD: Two minutes. Are we off the record?
THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 1:41.
(Recess.)
THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 1:45.
(Fredric Goldman enters the deposition.)
BY MR. PETROCELLI:
Q: Now that you have had a chance
to talk to your lawyer, where are the documents that I subpoenaed?
A: I don't have any of this stuff.
Q: And by "this stuff," what are you referring to?
A: Everything that's in this subpoena.
Q: All of which you've ascertained in the last two minutes by talking to your lawyer. Right?
A: Well, I just looked at it --
Q: In the last two minutes. Right?
MR. LEONARD: No, I don't think that's his testimony. I think he testified earlier he looked at it before.
BY MR. PETROCELLI:
Q: Did you just look at this in the last two minutes with your lawyer?
MR. LEONARD: I am going to object to anything that occurred between, you know, he and I as attorney-client privilege.
But go ahead.
THE WITNESS: I've seen this. I've kinda flipped through it before --
BY MR. PETROCELLI:
Q: I know. That's what you said. You said you didn't read it carefully. You flipped through.
A: I didn't get to finish my answer.
Q: Keep going.
A: I flipped through it before, and I kinda had a rough idea as to what was on here but not specifically, but then looking in there, I looked over and looked to see the specifics of what's on here and, I don't have any of this stuff on it.
Q: And when you just now said then looking at the "specifics" of this, you meant just a few minutes ago. Right?
A: Yes, sir.
Q: Okay. And just a few minutes ago you made a determination that you don't have any of this. Is that what you're saying?
A: Yes, sir.
Q: Okay. Do you have any -- you have phone bills, don't you?
A: I think I might have last month's phone bill.
Q: Were your phone records subpoenaed in June of 1994?
A: Not that I recall, no.
Q: Did you have a cell phone at that time?
A: No.
Q: You had a phone at your apartment. Right?
A: I didn't have --
Q: On Sycamore. Right?
A: Yes, sir.
Q: In June of '94. Right?
A: Yes, sir.
Q: And did you have any kind of calendar or papers on which you kept your appointments?
A: Calendar, no. No. I had like one of those boards you put up in the kitchen and you write with a marker sometimes.
Q: You had nothing that resembled a calendar or appointment book?
A: I had an address book, but not a --
Q: Where is that address book?
A: I think it's at home.
MR. PETROCELLI: I call for its production pursuant to the subpoena.
Q: Next, do you have any documents that in any way mention Nicole Brown Simpson? Do you have anything that mentions her?
A: Anything that mentions her?
Q: Anything. Anything.
A: Like a magazine that says her name in it?
Q: Anything that mentioned her before her death.
A: Probably.
Q: What do you have?
A: Like a cookbook that says, "To Jason, Merry Christmas."
Q: Okay. Anything else besides the cookbook?
A: I don't know. I'd have to check.
Q: Do you have any photographs?
A: Yeah, I got lots of photographs.
Q: Okay. Of Nicole?
A: Nicole, the whole family and Nicole.
Q: Do you have photographs of O.J. Simpson and Nicole?
A: Yeah.
Q: Okay. Do you have photographs -- Well, I call for the production of those photographs as well.
Prior to the death of Nicole, had you ever heard of Ron Goldman?
A: No, sir.
Q: Had Nicole Brown Simpson ever told you about a person named Ron Goldman or Ronald Goldman?
A: No, sir.
Q: Had anyone?
A: No, sir.
Q: Did you ever discuss Ronald Goldman with O.J. Simpson?
A: No.
Q: With anyone?
A: No, sir.
Q: At any time?
A: Ever?
Q: Yes, ever.
A: Yeah.
Q: With whom?
A: I don't remember I wondered who he was.
Q: What did you wonder about?
A: I wondered who -- who and -- who he was, finding out what happened. I found out that Nicole had died, and I found out that somebody else at that time had died, too.
Q: And how did you find out who he was?
A: I think the news.
Q: Did you speak to any person about who Ron Goldman was?
A: Probably, but I don't remember specifically.
Q: Tell me who you spoke to.
A: In the last two years, everybody I've ever spoken to?
Q: No. About Ron Goldman to find out who he was.
A: I never -- I heard from the news, from the media, from TV, who he was.
Q: Other than the news and the media, conversations that you have had with people.
A: Never.
Q: No one.
A: No one.
Q: Did Nicole ever discuss with you before her death that she was dating someone or seeing someone who was a waiter at a restaurant?
A: No, sir.
Q: Did she ever describe to you a person who fit the description of Ron Goldman?
MR. LEONARD: I am going to object. Lack of foundation.
BY MR. PETROCELLI:
Q: Go ahead.
A: No.
Q: Did she ever discuss with you any persons that she was seeing as friends or dating as friends in the last few months of her life?
A: No, sir.
Q: Now, you said you last saw Nicole -- first of all, you said you last saw her when she had pneumonia. Then you said, when I asked you the question about Sydney's -- about Justin's graduation, that it must have been on that occasion that you last saw Nicole.
Do you recall that?
A: Yeah, you reminded me.
Q: Okay. So it's now your recollection that you last saw Nicole at Justin's graduation at the Sunshine School?
A: I believe that was the last time.
Q: And when you went to that event who did you go with?
A: I went by myself.
Q: Did you get tickets to go there?
A: You didn't need a ticket for it.
Q: Who was there on behalf of your brother Justin?
A: My sister Arnelle, I don't know if Sydney was there, and Nicole was there.
Q: Did you go out afterwards?
A: No, I didn't. I think they went back to the house. I'm not sure. I'm not sure if I weft with them back to the house.
Q: Which house?
A: Back to Bundy, I think, but --
Q: Where did you go?
A: I know I had to work, so I couldn't spend the rest of the day with them. I wanted to.
Q: Which day was this?
A: The day of the graduation.
Q: Why did you want to spend the rest of the day with them?
A: Because I love them.
Q: Who is "them"?
A: Sydney, Justin, Nicole.
Q: Do you know what they did after they left the graduation?
A: No, I don't remember.
Q: Do you know if they went to dinner?
MR. LEONARD: Objection. Lack of foundation, asking him to speculate.
THE WITNESS: Actually, it was early still.
BY MR. PETROCELLI:
Q: In the afternoon?
A: Yeah. So, no, they didn't go out to dinner.
Q: Were you disappointed your father was not there?
MR. LEONARD: Objection.
THE WITNESS: I actually didn't really -- since Nicole told me that he was at some business thing he had to take care of, I really didn't think too much of it.
BY MR. PETROCELLI:
Q: It was not uncommon for your father to miss family functions because of business. Correct?
A: Correct.
Q: He was gone a lot. Right?
A: Correct.
Q: And that was through -- that was true throughout your lifetime as well. Correct?
A: Correct.
Q: And that continued to be true all the way up until Nicole's death. Correct?
A: Correct.
Q: So he missed lots of family functions involving you. Right?
A: Yes.
Q: And involving Sydney and Justin. Right?
A: Sydney and Justin, I don't know so much because I wasn't really there, but I'm sure he missed his share.
Q: A lot with you. Right?
A: Yeah. I mean, yeah, he was working a lot.
Q: Out of town?
A: Yeah.
Q: Played golf a lot?
A: Played golf every morning, but I wasn't up that early anyway, so...
Q: Went out of town on golf tournaments a lot, celebrity tournaments --
A: Not --
Q: -- golfing for Hertz, those sorts of things?
MR. LEONARD: Object to the compound nature of the question.
Q: You can answer it if -- you can try.
THE WITNESS: He didn't play golf when I lived at home.
BY MR. PETROCELLI:
Q: What was your relationship with O.J. Simpson like?
A: What was it like?
Q: Yes.
A: At what point?
Q: Did it ever change?
A: Well, I mean, it's matured.
Q: Other than matured as you became older and he, too, did you have a good relationship with him throughout your life, or did you have a --
A: Yeah, I mean --
Q: -- bad relationship with him at times?
A: At times.
Q: Did you have any falling-outs?
A: At times.
Q: What times?
A: I don't know. When I was 16 and wanted to get a car right away. What else. When I wanted my own room further away from the house. He won every time.
Q: These are less specific little incidents where you had arguments?
A: Yeah. I mean, I've argued with my dad.
Q: But other than normal father-son arguments, your testimony is that you've had a very strong relationship with him since day one?
A: I think so. Well, now, looking back, I mean, since everything that's happened it's gotten stronger, so in my opinion it's like I start to realize it is a lot stronger now than it was before.
Q: What was your opinion as of June of 1994?
A: Of our relationship?
Q: Yes.
A: I mean, I didn't have any problems with it.
Q: Was he there for you all the time?
A: Yeah.
Q: Okay. Did he ever beat you?
A: No.
Q: Never?
A: Beat me? No.
Q: Yes, beat you.
A: No.
Q: Did he ever hit you?
A: I've gotten a whipping on the butt before with his belt when I was a kid.
Q: Nothing that you would regard now, looking back, as abusive?
A: No.
Q: Okay. Did he ever strike you with anything other than his hands?
A: No. He's never stricken me with his hands, though.
Q: How has he hit you when he --
A: I told you, with a belt on my butt.
Q: Just a belt?
A: Yeah.
Q: Once or twice?
A: I don't know. I kinda -- kinda messed around a lot when I was a kid. No, I don't know. Maybe 10, 20 times. I don't remember exactly.
Q: When was the last time?
A: I don't remember.
Q: Small kid?
A: I was about 14 maybe. It was not too long before Nicole and my dad's wedding, which I think was in '85.
Q: Did he ever inflict serious injuries upon you?
A: Never.
Q: Did you ever have to get medical treatment as a result of a beating?
A: No, sir.
Q: Did you ever go to the hospital or the doctor as a result of being hit by your dad?
A: No, sir.
Q: Were you afraid of him?
A: No.
Q: Okay. Did you ever see him in a rage?
MR. LEONARD: I am going to object to that as vague.
THE WITNESS: No, not in a rage. I -- wouldn't characterize it as a rage.
BY MR. PETROCELLI:
Q: Did you ever see him in what you would characterize as somebody out of control?
A: Out of control, no.
Q: Did you ever see him throw things around?
A: No, I've never seen him throw things.
Q: Never saw him throw anything?
A: No. I saw him throw a football, saw him throw a tennis ball.
Q: Never saw him throw any item or article in anger?
A: No, I've never seen him throw an article.
Q: Like photographs or a glass or anything like that?
A: I've never seen him do that.
Q: Okay. Have you seen him get mad?
A: Yeah.
Q: Have you seen him get really mad?
A: Yeah.
Q: Have you ever seen him, when he got really mad, pick up a glass and throw it?
A: No.
Q: You ever see him get so mad that he actually hurt himself, cut himself?
A: No.
Q: You ever see him take a baseball bat to anything?
A: No.
Q: You ever see him break down a door or break -- or put his fist through a wall?
A: No, sir.
Q: Anything like that?
A: No, sir.
Q: So in your opinion, based on your experience living with your father and knowing him all these years, he was in total control of his emotions and temper. Is that true?
A: I never said that.
Q: Answer that question.
A: I said I've never seen him do anything like that.
Q: So you've never seen him lose control of himself. Right?
A: No, sir.
Q: And you've always seen him in control of himself. True?
A: Yeah. I've seen him upset, but he was in control.
Q: When he -- when you've seen him upset, how did he behave?
A: Angry.
Q: And did that manifest itself in any physical way?
A: Arguing.
Q: Just arguing?
A: Yeah. Maybe raising his voice, pacing.
Q: Veins in his neck bulge or pop?
A: I don't know about the veins.
Q: Or his eyes start to bulging?
A: Yeah, yeah, I've seen that.
Q: When he was angry at you?
A: A couple times.
Q: Did he ever threaten to hit you?
A: Yeah. I mean, yeah, if I don't get up to my room, "Get up to your room," or something like that. I mean --
Q: Did he ever threaten to hit you in such a way that you were really afraid for your life?
A: Well, any time he threatened me -- not for my life, no.
Q: Not for your life.
A: Hell, no. Sorry. Excuse me. No.
Q: Did he ever threaten you with anything other than a spanking?
A: No. Or punishment.
Q: Or punishment.
A: No.
Q: Okay. Did you ever see him on drugs?
A: No.
Q: Did you ever see him take drugs?
A: No.
Q: You ever been in the same room when he took drugs?
A: No, sir.
Q: Did you ever take any drugs?
MR. LEONARD: I am going to object to that --
BY MR. PETROCELLI:
Q: You can answer.
MR. LEONARD: -- and instruct him not to answer.
BY MR PETROCELLI:
[Portion Deleted]
Q: Okay. Did you ever see your father get angry at another person other than yourself?
A: Yeah. Yes.
Q: Who?
A: My sister, Nicole, my mom, I think a guy that ran over our dog once a long time ago; tried to get away with it.
Q: What did your father do in that incident with the dog?
A: I think he yelled at the guy. That's all. Guy tried to get away.
Q: Did you ever see O.J. Simpson strike somebody?
A: No. I got a picture of him hitting somebody -- that's about it -- in a football game.
Q: I don't mean in professional sports or college sports or any sporting activity. I mean in anger, in a fight, losing his temper or being provoked or whatever.
Did you ever see him strike another person other than when he spanked you?
A: No.
Q: Never?
A: Never.
Q: Never saw him hit Marquerite, your mother?
A: No.
Q: Did he?
A: Not that I know of.
Q: Did she ever tell you that he did?
A: No.
Q: Did anybody ever tell you that he did?
A: No. No.
Q: Did the police ever come out to the house when you lived -- when he lived with Marquerite and you?
A: Not that I ever remember.
Q: You have no knowledge and no information about anything like that. Is that true?
A: If he hit my mother, he'd know.
Q: How would he know?
A: Because nobody hit my mother.
Q: Nobody ever did.
A: No. If anybody ever hit my mother believe me, they'd know about it.
Q: From you?
A: Hell, yeah.
Q: Including your father?
A: Yes.
Q: That would be unacceptable to you. Right?
A: Very.
Q: Just because she's your mother or because it's unacceptable to hit another woman?
A: Both reasons.
Q: And would it also be unacceptable to you if he ever hit Nicole?
A: Yes.
Q: And you would find that totally outrageous and wrong on his part. Right?
A: Yes.
Q: Did you ever see him hit Nicole?
A: No.
Q: Ever?
A: No, sir.
Q: Did you ever -- were you ever told by anyone that he struck or hit Nicole?
MR. LEONARD: I am going to object to that as --
MR. PETROCELLI: Why?
MR.LEONARD: -- lack of foundation.
Told by anyone?
MR. PETROCELLI: Yes, by anyone.
THE WITNESS: I was never personally told that he hit Nicole.
BY MR. PETROCELLI:
Q: What do you mean, "personally"?
A: No one ever said, "Jason, your dad hit Nicole" or "O.J. hit Nicole."
Q: Did Nicole ever tell you that?
A: No, Nicole never did.
Q: Did Arnelle ever tell you that?
A: Arnelle never did.
Q: Did Mr. Simpson, O.J. Simpson, ever tell you that?
A: No, he never did.
Q: Did Al Cowlings ever tell you that?
A: No, he never did either.
Q: Did anyone ever tell you that?
A: No one ever personally ever told me that he did.
Q: Did you ever overhear a conversation where someone said O.J. Simpson hit Nicole?
A: On TV.
Q: When on TV?
A: I don't know. During the trial, on the HARD COPY shows and stuff like that.
Q: Is that the first time -- Strike that. You heard this on TV after Nicole's murder for the first time. Is that right?
A: That he hit Nicole?
Q: Yes.
A: Yeah.
Q: First time you ever heard it. Right?
A: Yeah.
Q: Never heard it in 1989 when you were 19 years old.
A: That's -- no. I heard they got in fight. I never heard that he hit Nicole.
Q: What did you hear about the fight in 1989?
A: That they got --
MR. LEONARD: I am going to object unless you can lay a foundation.
MR. PETROCELLI: I just asked him, what did he hear about it.
MR. LEONARD: Yeah, why don't you ask him where he heard it and when he heard it and who he heard it.
Is that the way you want the record?
MR. PETROCELLI: Yes.
MR.LEONARD: Okay, great, go ahead.
THE WITNESS: What was that?
BY MR. PETROCELLI:
Q: What did you hear about the fight in 1989?
A: I got a phone call, and my father told me that he and Nicole had gotten in a fight, and he wanted to tell me because he's probably gonna -- I was probably gonna hear about it in the paper or something like that.
Q: And when did you get that phone call?
A: I think it was either New Year's Eve or New Year's Day. New Year's Day.
Q: 1989?
A: Yeah. Because the Rose Bowl was on the 2nd that day. It wasn't on the 1st. It's usually on the 1st.
Q: How do you remember that?
A: Because he called me at the hotel. I was getting ready to go --
Q: What hotel?
A: -- to the Rose Bowl. I can't remember the name of it. We stayed in a hotel before football games at USC. It's on Wilshire. I think it's -- I don't know the name of it.
Q: So you think on January 2, 1989 your father --
A: No. January 1, it would have been.
Q: Why? You stayed in the hotel overnight?
A: Yeah, you stayed before the game.
Q: Who?
A: The team.
Q: You were on the team?
A: Yes, sir.
Q: Okay. And he called -- You were a freshman?
A: Yes, sir.
Q: Okay. And you were part of the SC varsity squad?
A: SC football team, yeah.
Q: On the football team.
A: Yes, sir.
Q: And he called you at the hotel where the USC football team was staying on January 1, 1989 to inform you that he and Nicole had gotten into a fight.
A: Yes.
Q: And where was he, if you know, when he made this phone call to you?
A: I don't know.
Q: Did you ask him?
A: No. I was kinda upset.
Q: What did he say to you had happened?
A: He said, "Look, we got into a fight. You're probably gonna read about it. I just wanted to tell you because I don't want you to find out reading in the paper."
Q: What about that upset you?
A: The fact that they got in a fight. I knew that it must have been a pretty big fight if it's gonna make it to the paper.
Q: Well, he had gotten into fights with Nicole before. Right?
MR. LEONARD: Objection.
BY MR. PETROCELLI:
Q: You had seen them argue before. Right?
A: I've heard them argue, yeah, seen them argue.
Q: So what about this particular account of his fight with Nicole upset you?
A: The fact that he called me to tell me, to warn me that for some reason I should know about this particular fight because -- I don't know -- because, "You might find out from somebody else." I knew that for some reason it must have been something severe about the fight.
Q: Now you say "for some reason." In fact, he told you much more than that. Correct?
MR. LEONARD: Objection. Argumentative.
THE WITNESS: No. He told me just what I told you.
BY MR. PETROCELLI:
Q: He told you that the police had come out to the house, for example. Correct?
A: No, he never said that. He just said, "We got into a fight."
Q: He said, "I want you to know we got in a fight and it may be in the newspapers," and that's all he said. Is that your testimony?
A: Basically, yes.
Q: Okay. He didn't tell you, "We got into a fight, and Nicole got hurt." Did he say that?
A: I don't remember him saying that.
Q: Did he say that Nicole had marks on her face or bruises?
A: He didn't get into detail.
Q: Did he say that the fight was a physical fight?
A: No, he didn't get -- he didn't even say that, I don't think.
Q: So as far as you knew --
A: He was pretty vague.
Q: -- it might have been just an argument. Right?
A: He was pretty vague. No, I knew it wasn't just an argument because arguments don't make it to the news paper.
Q: You knew this was a physical altercation. True?
A: It had to be.
Q: And he told you it was. Right?
A: Either that or the fact that the police must have found out or a neighbor must have found out or somebody must have found out in order for the newspapers to be alarmed by it. I mean, why would the newspapers print a fight between my father and my stepmom.
Q: Unless something serious happened. Right?
A: Yeah. I mean, it didn't take, you know, Einstein to figure that out.
Q: So you understood something really serious had happened. Right?
A: Something serious must have happened.
Q: And did you ask him, "What, Dad, happened?"
A: No, I didn't.
Q: Did you ask him if Nicole was okay?
A: I don't remember.
Q: Did you call Nicole to find out if she was okay?
A: I saw her the next day or two days later.
Q: After the Rose Bowl?
A: Yeah.
Q: Did you ask her at that time?
A: If she was all right?
A: Yes.
A: Yeah.
Q: So from the moment your father called you on January 1 to tell you about his fight with Nicole the time you saw her a couple of days later, you did not speak to Nicole at all. True?
A: No. True.
Q: Never once called her to see if she was okay. True?
A: She wasn't home. I didn't know where she was.
Q: I didn't ask you that. You didn't call her. Right?
A: No. I called the house. She wasn't home.
Q: You did call the house.
A: Yeah.
Q: How many times?
A: I think a couple times.
Q: Okay. From where?
A: I think my dorm room, maybe somebody else's room.
Q: What days did you call the house?
A: I think the 2nd -- or not the 2nd. The 3rd and the 4th.
Q: So you didn't call on the 1st, and you didn't call on the 2nd. True?
A: No. I found out the 1st at night.
Q: Right.
A: And I didn't call on the 2nd, no.
Q: Okay.
A: And the 3rd is the day I'm guessing I probably called, and I think I saw her on the 4th.
Q: Okay. Did you -- can you remember specifically calling her on the 3rd?
A: No.
Q: And when you spoke to her on the 4th, was it over the telephone or in person?
A: I said, "...I think I saw her on the 4th."
Q: Where did you see her on January 4?
A: It was the house.
Q: Whose house?
A: My dad's house and her house.
Q: You went over there?
A: Yeah.
Q: And did you talk to her about the fight?
A: Yeah. I said, "What happened? How are you?"
Q: When you said, "What happened," what did she say?
A: She was like -- I didn't see her. It wasn't like face to face. She was kinda like far away, and she was pretty upset, and from my best recollection, I mean, she was up -- she was just walking around, and I asked her if she was all right, and she was just like (Sound).
She didn't really say anything about it and I knew she was upset, and I just asked her, "Look, can I borrow the Bronco?" She didn't want to talk to me either, it seemed.
Q: Describe the marks and injuries that you saw on her.
A: I didn't see any marks or injuries on her.
Q: Nothing?
A: No, because I wasn't this close to her.
Q: How close were you?
A: I was -- she was probably about mid table, but --
Q: Like 15, 20 feet?
A: 15, 20 feet, yeah, but it was in the kitchen, and I couldn't tell if she was -- I mean, in retrospect it was like she didn't -- it was like she was acting like she didn't want me to see.
Q: Do you carried on a conversation with her from a distance of 15 to 20 feet. Is that what you're saying?
A: Yeah, but we weren't talking to each other me and you are talking to each other right now.
Q: Who were you talking to?
A: What do you mean? There was no mistaken who I was talking to. I'm saying just because I look like this (indicating) doesn't mean I'm not talking to Mr. Petrocelli. I may not be looking at you, but I'm still talking to you.
Q: What I am trying to find out is this: You went into the house, and you went and you saw her there. Right?
A: Yes, sir.
Q: And you asked her how she was what had happened, et cetera. Right?
A: I didn't really get into what had happened right away. It just kind of --
Q: But you told me just a few minutes ago --
A: -- blurted out.
Q: -- you said, "What happened?" that what you said?
A: I think.
Q: Okay. And you're telling me that for however long you and she conversed, it was conducted at a distance of 15 to 20 feet, and you got no closer to her at that time. Is that your testimony? Yes or no.
A: Yes.
Q: Okay. Did you ask Nicole why she didn't want to see you or to be with you or even to talk to you?
MR. LEONARD: Objection. I think that's misstating his testimony. Plus it's a compound question.
Go ahead. You can answer it.
THE WITNESS: She never said, "I didn't want to see you." She wanted to be left alone.
BY MR. PETROCELLI:
Q: How do you know that?
A: Just in knowing Nicole.
Q: What did she say to indicate that to you?
A: She didn't say. She didn't really want to be bothered.
Q: Did you try to get closer to her to look at her?
A: Kinda, yeah.
Q: What stopped you?
A: Her moving away.
Q: She ran away from you?
A: I didn't say run. I said move.
Q: Where did she move?
A: She was kinda pacing around, being fidgety all in the kitchen.
Q: Did you go up to her to hug her?
A: I kinda moved a little bit closer, but it wasn't a hug kind of -- it wasn't a real emotional type of thing. She was very standoff-ish. She was upset. I mean, she was upset about the whole situation, I guess.
Q: And that's the only conversation you ever had with her about this fight on New Year's Day?
A: Yeah.
Q: Did you ever ask her again?
A: About?
Q: Was she trying to avoid showing you her face, based on your observations?
MR. LEONARD: Objection. Calls for speculation.
BY MR. PETROCELLI:
Q: You can tell when a person is trying not to show you their face such as if I'm talking to you now, I'm turning my head away (indicating).
Did she make any movements to you to indicate that she really didn't want you to see her face?
MR. LEONARD: Objection. Calls for speculation.
Go ahead.
BY MR. PETROCELLI:
Q: You may answer.
A: I don't know.
Q: You don't know.
A: No, I don't know.
Q: It's fair to say that you love your father?
A: Yes.
Q: Fair to say that you don't want to see him lose this case?
A: I wouldn't want to see him lose it, no.
Q: And is it fair to say that even if a jury were to conclude that he killed Nicole and he killed Ron, you would stand by his side?
A: It would be kinda hard.
Q: You wouldn't abandon him, would you?
A: It would be really hard. He's my father, but...
Q: You're loyal to your father. Right?
A: Yes.
Q: And you don't want to hurt him in this case, do you?
A: No. I mean...
Q: Did you ever talk to your father again about this incident on New Year's Day other than the telephone conversation?
A: No. Never came up again.
Q: Do you think your father killed Nicole?
MR. LEONARD: Objection. Calls for a conclusion. Calls for speculation, lack of foundation.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Why do you think that?
MR. LEONARD: Objection. Same basis.
THE WITNESS: Just a feeling.
BY MR. PETROCELLI:
Q: Just a feeling you have?
A: Feeling in my heart, feeling in my head.
Q: It's not something that you would want to believe to be true.
A: Of course not.
Q: Okay. Do you know how your father's blood got at the crime scene where the two bodies were found?
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Do you have any information whatsoever as to how blood of your father's rare type was found next to the two bodies?
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Have you ever asked him?
A: No.
Q: Do you have any information as to why a shoe print in blood in size 12 the size of your father's shoes, was found at the crime scene?
MR. LEONARD: I am going to object. Calls for speculation, lack of foundation.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Have you ever asked him about that?
A: Never asked him.
Q: Has he ever told you?
A: No.
Q: Has he ever given you -- whether or not you asked, has he ever told you or given you an explanation for why his blood was found at the crime scene?
MR. LEONARD: I am going to object.
BY MR. PETROCELLI:
Q: Or why a size shoe-a size 12 shoe print was found there? Has he ever told you about any of that?
MR. LEONARD: I am going to object as compound, lack of foundation.
BY MR. PETROCELLI:
Q: You may answer.
A: No, sir.
Q: Has -- do you have any explanation or information as to why blood matching the type of Ron Goldman's was found in your father's Bronco?
MR. LEONARD: I am going to object. Lack of foundation, calls for speculation.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Or Nicole's blood.
MR. LEONARD: Same objections.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Have you ever asked your father about those circumstances?
MR. LEONARD: Same objections.
THE WITNESS: No, I haven't.
BY MR. PETROCELLI:
Q: Has he ever given you any information or any explanation for those circumstances?
MR. LEONARD: Same objections.
THE WITNESS: No, he hasn't.
BY MR. PETROCELLI:
Q: Does it not matter to you?
MR. LEONARD: I am going to object because that's argumentative.
BY MR. PETROCELLI:
Q: Does it matter to you or does it not matter to you?
MR. LEONARD: I'm going to object as argumentative.
BY MR. PETROCELLI:
Q: You may answer.
A: Yes, it matters.
Q: Why don't you ask him?
A: You're asking me, does it matter about the blood, or does it matter that he -- has he told me?
Q: Does it matter that this evidence was found linking him to these crimes?
MR. LEONARD: I am going on object. Lack of foundation, calls for
speculation, it's argumentative, and I am going to instruct the witness not to answer that question.
Don't answer that.
BY MR. PETROCELLI:
Q: Does it matter to you that your dad may have answers to these questions, and you haven't even asked him and he hasn't even told you?
MR. LEONARD: Same Objections.
Don't answer the question.
BY MR. PETROCELLI:
Q: These things don't matter to you?
MR. LEONARD: Same objections.
Don't answer the question.
BY MR. PETROCELLI:
Q: Do you have any information or any explanation as to why blood matching your father's rare type was found on the Rockingham property?
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
THE WITNESS: No, I don't know.
BY MR. PETROCELLI:
Q: You don't know?
A: Huh-uh.
Q: Did you ever ask him?
A: No.
Q: Did he ever tell you or give you an explanation as to why his blood was found on the property, having been dropped there the same time that Nicole was being murdered --
MR. LEONARD: I am going to object --
BY MR. PETROCELLI:
Q: -- or the same night of her murder?
MR. LEONARD: -- lack of foundation.
THE WITNESS: No, sir.
BY MR. PETROCELLI:
Q: Do you have any explanation or any information as to why your father's gloves were found, one at the crime scene and one at Rockingham?
MR. LEONARD: Object. Lack of foundation, calls for speculation, calls for a conclusion.
THE WITNESS: No, I don't know.
BY MR. PETROCELLI:
Q: You don't know?
A: No.
Q: Did you ever ask him, "Why were your gloves found at the crime scene, Dad?"
MR. LEONARD: Same objections.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: "Why was one of your gloves found at Bundy near Nicole and Ron's body," did you ever ask that question to him?
MR. LEONARD: Same objections.
THE WITNESS: No, I did not.
BY MR. PETROCELLI:
Q: Did he ever give you any answer or any information or any explanation about that?
MR. LEONARD: Same objections.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Did you ever discuss that with him?
A: That, yeah, I think.
Q: Tell me about your discussion.
A: I mean, I think I heard him say like "I don't know where they got the
gloves," or something like that, or even if they were his. I think I heard him say something like that.
Q: You heard him say, "I don't know where they got my gloves"?
A: "They got those gloves."
Q: "Those gloves"?
A: Or, "If they're even mine or not."
Q: You heard him say that they might not be his gloves?
MR. LEONARD: Objection. That mischaracterizes his testimony.
BY MR. PETROCELLI:
Q: Is that your testimony?
MR. LEONARD: That's not what he said.
BY MR. PETROCELLI:
Q: Is that what you heard him say?
A: I heard him say, "I don't know where they found those gloves," something like, "I don't know where they found those gloves or if they're even my gloves at all."
Q: And when did you hear O.J. Simpson say that?
A: I think it was at a-I think it was in jail or something.
Q: And to whom did he say that?
A: He was just saying it to whoever was in the room.
Q: And who was in the room besides you and O.J. Simpson?
A: I think Nicole Pulvers, me. I think that was it.
Q: Had you ever seen those gloves before? Yourself.
A: No.
Q: Were they your gloves?
A: No.
Q: Did you have any of your gloves at Rockingham on June 12, 1994?
A: Not that I know of.
Q: Did you have any -- What size shoe do you wear?
A: 11-1/2.
Q: What size glove do you wear? Extra large?
A: I don't know. I don't wear gloves, so I wouldn't know what that is.
Q: You don't own a pair of gloves. Right?
A: I mean, I've gone skiing- before, you know, and just gone for one that fits, but I've never really paid attention to what the size was.
Q: Okay. Where are your ski gloves?
A: They might be at my dad's house.
Q: Where?
A: In a closet somewhere. I don't know. I haven't seen them in a while.
Q: Do you even know if you have any ski gloves?
A: I did. I mean, when I was in high school, I went skiing. I had gloves.
Q: Is the last time you saw the ski gloves that you had in high school?
A: Yeah.
Q: 1988?
A: Well, before, prior to 1988. Right around in there.
Q: Prior to 1988.
A: Yeah.
Q: Okay. So you haven't put on a pair of gloves since after -- since before 1988. Correct?
A: No. I put on a pair of gloves since 1988.
Q: For skiing?
A: No.
Q: For what?
A: I don't know. Just farting around.
Q: Your gloves?
A: No. Friends or something like that.
Q: Friends. Okay. Have you seen any of your father's gloves in the past five years?
A: No.
Q: You've seen -- you saw those pictures at the trial of your father wearing gloves at football games. Right?
A: Right.
Q: You attended most of the trial, did you not?
A: Some of it. Not most of it.
Q: Okay. And you saw him wearing those photographs, right -- wearing the gloves depicted in the videos --
A: Yes.
Q: -- when he was announcing or broadcasting at football games?
A: Yes.
Q: Do you know where those gloves are?
A: No, I don't know.
Q: Did you ask him?
A: No.
Q: Did you say -- did you ever ask him, "Dad, where are the gloves that you were wearing that they showed in the court" --
A: No.
Q: -- "the gloves that you were wearing in the football"-"at those football games, where are they? Did you ever ask him that question?
A: No, sir.
Q: Okay. Did he ever tell you where those gloves are?
A: No, sir.
Q: Do you know where they are?
A: No, I don't.
Q: You've seen your dad wear sweat pants before, haven't you?
A: Yes,
Q: In all different kinds of colors, for that matter. Right?
A: I think just three colors.
Q: Including a dark color. Right?
A: Yeah, barely. I mean, just three colors.
Q: What three colors?
A: Red, blue and white.
Q: Okay. You've seen him with dark --you've seen him with dark blue sweats. Right?
MR. LEONARD: Objection.
BY MR. PETROCELLI:
Q: You just said "blue."
MR. LEONARD: Yeah.
THE WITNESS: Blue, but -- yeah, but like -- like the color of this shirt (indicating). If you think this is dark.
BY MR. PETROCELLI:
Q: Have you ever seen your father wearing a pair of dark blue sweats or black sweats?
A: Black, never, but --
Q: Dark blue?
A: No.
Q: Never?
A: Not dark blue. I wouldn't call it dark blue.
Q: You can positively exclude that never worn dark blue sweats to your knowledge?
A: To my knowledge, I can't say he's never worn them, but I'm telling you I've never seen them.
Q: Have you ever seen them in his house?
A: No.
Q: Did you see the clothing that your father wore during the shooting of a video, an exercise video that he made a few weeks before Nicole's death?
A: No, I never saw that video.
Q: You never saw that video?
A: The workout video?
Q: Yes.
A: No, I never saw that.
Q: Did he give you any of the clothing that he received from that production?
A: No.
Q: Did you even know about that production?
A: I knew mostly about it during the trial.
Q: That's the first you learned about it?
A: Yeah.
Q: Were you at that Rockingham property during any of the filming?
A: No.
Q: Do you have any information or explanation as to why your father's watch cap was found at the crime scene?
MR. LEONARD: I am going to object. Lack of foundation, calls for speculation.
THE WITNESS: I didn't even know if he even said it was his watch cap. I always thought that they found a watch cap. I never knew that they concluded --
BY MR. PETROCELLI:
Q: Do you believe that it belonged to your father?
MR. LEONARD: Objection. Lack of foundation, calls for speculation.
BY MR. PETROCELLI:
Q: You can answer.
A: No. I never even seen my dad in a watch cap, so --
Q: Do you know whether he owned one?
A: No. That's what I'm saying. I don't think he -- I didn't even think he had one.
Q: You weren't familiar with all his clothing, were you?
MR. LEONARD: Excuse me. I didn't hear that.
BY MR. PETROCELLI:
Q: You were not familiar with all the clothing that your father owned as of June of 1994.
Correct?
A: Not all of it.
Q: Correct?
A: Yeah.
Q: Do you know whether your father owned Bruno Magli shoes?
A: I don't know.
Q: Do you know what Bruno Magli shoes are?
A: I do now.
Q: Before June of 1994 did you ever see or hear of Bruno Magli shoes?
A: No, I didn't.
Q: Did you ever own a pair?
A: No.
Q: After you saw shoes of the Bruno Magli type depicted in the courtroom at your father's trial, you learned what they were. Right?
A: And not even then. I mean, just recently. When they -- Geraldo had did something because he got some -- that matter. Right? property during any of the filming thing --
Q: The photograph?
A: Enquirer, yeah.
Q: In the National Enquirer?
A: Yeah. Yeah.
Q: Wearing a pair of Bruno Magli shoes?
A: Yeah, I saw some picture.
Q: Of your father?
A: Yeah.
Q: Did you ask him when you saw that photograph of him wearing the Bruno Magli shoes?
A: This was like just a couple days ago I found out.
Q: I know. Did you ask him, "Hey, are those your shoes?"
A: No, I didn't.
Q: Why not?
MR. LEONARD: I am going to object. That's argumentative.
Go ahead.
THE WITNESS: First of all, information from the Enquirer, I don't really tend to hold with much weight, so I don't think I would take that --
BY MR. PETROCELLI:
Q: Why? Because they pay for stories?
A: No. Because I've heard stories reported by them that were totally wrong. Paying for stories, hey, it seems like everybody's doing that now, so, I mean, that's common practice.
Q: And you took money, too.
MR. LEONARD: Well, I am going to object, because you are not suggesting he took money for a story, are you?
BY MR. PETROCELLI:
Q: You took money for photographs. Right?
A: For a photograph --
Q: Right.
A: -- I did.
Q: Okay. So --
MR. LEONARD: I just wanted to make sure that was correct on the record.
BY MR. PETROCELLI:
Q: Anyway, when you saw this photograph of O.J. Simpson wearing Bruno Magli shoes in the National Enquirer a few days ago, did you ask your father about those shoes?
MR. LEONARD: I am going to object. Lack of foundation.
THE WITNESS: No, I didn't.
BY MR. PETROCELLI:
Q: Did you ask anyone?
A: No, I didn't.
Q: Did you overhear any conversation about whether -- about that picture?
A: Did I hear any conversation?
Q: Yes.
A: No, because I didn't really hear what they were saying on the TV because I was just flipping through. I didn't even have -- I didn't even hear their conversation.
Q: Okay. Did you ever ask your father where he was between 9:30 and 11:00 on June 12, 1994?
A: No, I didn't.
Q: Has he ever told you?
A: No.
Q: Never?
A: No.
Q: Never discussed it with you?
A: No. I've heard his explanation, but I've ever sat down and had that conversation with him.
Q: Where have you heard his explanation?
A: I think I heard it throughout the case.
Q: What case?
A: What case?
Q: This case?
A: Yeah. Well -- yeah.
Q: Or the criminal case?
A: No, no.
Q: They are two separate cases.
A: The past case. I'm sorry. The criminal -- the previous case.
Q: What did you hear him say?
A: About with Kato and going to McDonald's and all that stuff.
Q: Tell me what O.J. Simpson said.
A: I could tell you what Kato said. I can't tell you what he said.
Q: How do you know what Kato said?
A: Because I watched it.
Q: No, no, no. You mean on television?
A: Yeah. And I was there I think at one point.
Q: At the trial?
A: Yeah, when Kato was there.
Q: I am only interested in your conversations with O.J. Simpson or conversations which you heard O.J. Simpson say things, and we started out his line by your telling me that you
heard him give his explanation of his whereabouts between 9:30 and 11:00 on the evening of June 12, and I now want you to tell me what you heard O.J. Simpson say about that.
A: Well, I never heard him say anything, then, if that's the case.
Q: What do you mean, "if that's the case"?
A: Well, I got what you said wrong.
Q: What does that mean?
A: I've heard -- I've heard testimony from him to the police when he spoke to the police and everything that was released through that and then through everything that he-or everything that went on through the case between a certain amount -- a certain time frame, and that's what I guess I was gonna tell you. He's never said anything to me about it, but...
Q: You've never been in the same room where he discussed his activities or his whereabouts between 9:30 and 11:00 on June 12?
A: No.
Q: And when did you overhear or when did you hear about his statement to the police?
A: I don't know. At some point on TV. They let out little things.
Q: So you have never spoken to your father at anytime or been in the same room and heard your father speak at any time about his whereabouts on June 12, 1994. Is that true?
A: I think, yeah.
Q: You never once asked him where he was?
A: I never asked him, no.
Q: Why not?
A: Never thought to.
Q: Never occurred to you?
MR. LEONARD: Objection. That's argumentative. I instruct him not to answer.
Next question.
BY MR. PETROCELLI:
Q: Don't you want to know who killed Nicole?
A: Yeah.
BY MR. LEONARD: Objection. Argumentative.
BY MR. PETROCELLI:
Q: So why don't you ask your father --
MR. LEONARD: Objection --
BY MR. PETROCELLI:
Q: -- where he was?
A: Why don't I ask you.
MR. LEONARD: Objection. Argumentative. Instruct the witness not to answer the question.
BY MR. PETROCELLI:
Q: Because my blood wasn't found at the crime scene.
MR. LEONARD: Come on.
THE WITNESS: Good answer.
MR. LEONARD: Come on.
MR.PETROCELLI: It's a good answer.
MR. LEONARD: Is there a question?
BY MR. PETROCELLI:
Q: Have you ever discussed with your sister -- Sydney what happened to Nicole that evening?
A: No.
Q: Or your brother Justin?
A: No.
Q: On the day your father was acquitted, you read a statement saying that he was going to devote his life's work to finding the real killer or killers of Nicole and Ron Goldman.
Do you remember that?
A: Yes.
Q: Okay. What has he done to your knowledge to find the real killer or killers?
A: I have no idea.
Q: What have you done?
A: What have I done?
Q: Yes.
A: Did I pledge? I don't recall pledging anything to try to find out who did it.
Q: Have you done anything?
A: No.
Q: Do you know whether O.J. Simpson has done anything,
A: No, I don't know.
Q: Do you know whether anybody in your family has done anything to find out --
A: I don't know, no.
Q: -- who committed these murders?
A: No, I don't know.
Q: Have you ever had a conversation with your father where you said, you know, "I read that statement on your behalf to the world at large. Dad, what have you done to fulfill your pledge?"
A: No, I never asked that.
Q: Do you care?
MR. LEONARD: Objection. Argumentative. Instruct him not to answer.
BY MR. PETROCELLI:
Q: You spoke to your sister Arnelle about any of this?
A: Any of what?
Q: About finding the real killer or killers.
A: Not finding, no.
Q: What have you spoke to Arnelle about in this regard?
A: Who the hell could have done something like this.
Q: And what did -- tell me about those conversations.
A: I mean, I can't remember everyone exactly, but, I mean, just sitting there, like, "Why is this happening? Who? What? You know, This just seems too crazy to be. "too crazy even to be real." You know, why? Who? What?" But I can't tell you, you know, I couldn't give you a date we --
Q: Did Arnelle identify any person who she thought might have killed Nicole?
A: No.
Q: Did she identify any suspect to you?
A: No.
Q: Did she give you any thoughts or theories as to who might have done it?
A: No. We might have maybe agreed with a couple or thought maybe some sounded kinda plausible, but we never --
Q: And who sounded plausible?
A: Who did it?
Q: Yeah.
A: Oh, I can't think of anybody who actually did it, but certain little things.
Q: Like what?
A: Like Faye.
Q: Faye Resnick?
A: Yeah.
Q: What about Faye Resnick?
A: She's just a real suspect character, in my opinion.
Q: You think she murdered Nicole?
A: No, I don't think she did it.
Q: What do you think she has to do with Nicole's death?
A: I just think she -- she ran with a suspect crowd, and just being around there and being around Nicole and even have the kids around it, it's just -- it's just -- it seems too fishy. She's just fishy.
Q: Is that the extent of your conversation with Arnelle?
A: The extent of the conversation?
Q: Yeah.
A: Not in so many words, but, you know, I mean, that's basic --
Q: Is that the only name that's popped up in your conversations with Arnelle, is Faye Resnick?
A: Yeah, hers is the biggest, I think, yeah.
Q: Who else pops up?
A: I think that's the only one. Nobody else's name really pops up.
Q: Before June 12, 1994, did you know Faye Resnick?
A: Yeah.
Q: Had you ever met her?
A: Yes.
Q: Okay. How many times?
A: A handful of times.
Q: Where had you seen her?
A: Our home in Laguna. At Nicole's house.
Q: Yeah. At Bundy?
A: Nicole's house -- no, not at -- was it at Bundy? Yeah, I guess it would have been at Bundy.
At my dad's house. And I think that's about it.
Q: Did you ever have a conversation with Faye about staying away from Nicole, that she was a bad influence on her?
A: No.
Q: Okay. Did you ever have that conversation with Nicole?
A: About staying away from Faye?
Q: Yes.
A: No, because I wasn't really aware of their -- wasn't really aware of what they were doing or anything like that.
Q: You were not aware of what Nicole and Faye Resnick were doing in the months leading up to Nicole's death. Correct?
A: No, I wasn't. I wasn't.
Q: So you never had any conversations with anybody on the subject of whether Faye was fishy or suspicious?
A: Previous?
Q: Yes.
A: To?
Q: To Nicole's death.
A: No.
Q: And you never had a conversation with O.J. Simpson about that either before Nicole's death. Right?
A: No, sir.
Q: Okay. So at no time did O.J. Simpson tell you, you know, "I'm really concerned about Nicole. She's hanging out with Faye. She's hanging out with the wrong crowd. She's leading a dangerous life." You had no conversations with O.J. Simpson about that prior to Nicole's death. True?
A: True.
Q: Okay. At any point in time from the moment you learned of Nicole's death to the present, did you ever form a belief that your father might be responsible for these deaths?
MR. LEONARD: I am going to object as it's not relevant, calls for speculation, lack of foundation.
BY MR. PETROCELLI:
Q: You may answer.
A: I never formed a belief, no.
Q: Did you ever form a suspicion?
MR. LEONARD: Objection. Same objections.
THE WITNESS: I formed a suspicion.
BY MR. PETROCELLI:
Q: Okay. And did you ever share your suspicion with Arnelle?
A: Probably, but I don't remember.
Q: Did Arnelle ever tell you that she, too formed a suspicion that your father might be responsible?
A: Never.
Q: Did she ever tell that you she thought your father was guilty?
A: No, never.
Q: Did she ever tell you that she thought your father was innocent?
A: Yeah, she has.
Q: Has she given you any explanations for the various items of evidence that I recounted to you?
MR. LEONARD: I am going to object on the same grounds I did before: Lack of foundation, speculation.
THE WITNESS: Like I said before, me and her talking, that just added more confusion to the mix.
BY MR. PETROCELLI:
Q: Did she ever tell you why O.J. Simpson's blood was found at the crime scene?
A: Did she tell me why?
Q: Did she give you an explanation as to why that blood was there?
MR. LEONARD: Objection --
THE WITNESS: No.
MR. LEONARD: -- calls for speculation, lack of foundation.
BY MR. PETROCELLI:
Q: You may answer.
A: No. She didn't know. She was just as confused as I was.
Q: So based on all your conversations with Arnelle, it is your understanding that she doesn't have any more information than you do on the evidence. Correct?
A: Basically.
Q: Is that correct?
A: Basically.
Q: Okay. Did you ever ask Arnelle whether O.J. Simpson hit Nicole? Did you ever discuss that subject with Arnelle?
A: With Arnelle, no.
Q: No?
A: No.
Q: Who have you talked to about that subject?
A: Nobody.
Q: Nobody?
A: No. This is the first time I ever really talked about it.
Q: Okay. Did you ever have a conversation with Marquerite Simpson about O.J. Simpson's responsibility for the death of Ron and Nicole?
MR.LEONARD: Objection. It calls for speculation, lack of foundation.
THE WITNESS: Did I ever have a talk with my mom about his responsibility?
BY MR. PETROCELLI:
Q: Yeah. In other words, whether he did it or not.
A: I don't think we actually got into that, no.
Q: Your mother never asked you any questions about where O.J. Simpson was or whether he had anything to do with it? You never discussed the subject at all with your mother?
A: No. She wanted -- she might have wanted to know questions about, you know, what was it like, what were they like. You know, she was curious.
Q: What was who like?
A: What was Nicole like, what were they like together. She was curious. She wanted to know. That was it. She never really asked about the actual killing.
Q: You are talking about questions that she asked you, what were Nicole and O.J. like?
A: Yeah. Were they happy, what was going on with them at the time.
Q: She asked you these questions after Nicole's murder. Right?
A: Yes.
Q: And what was going on at the time between them and so forth. Right?
A: What was their -- what was the state of their affairs, you know, the kids, what was it like, you know, with the divorce and everything, were they together, were they apart.
Q: What did you say to her?
A: On what questions?
Q: In answers to all those questions.
MR. LEONARD: Objection. It's overbroad --
THE WITNESS: Say yes, no, maybe. Which questions?
MR.LEONARD: It's -- objection --
BY MR. PETROCELLI:
Q: Tell me --
MR.LEONARD: Objection. It's overbroad. It's vague. You know, if you want him to try to answer a question like that --
BY MR. PETROCELLI
Q: Tell me what you told Marquerite about what was happening between O.J. Simpson and Nicole in their relationship at around the time of Nicole's death.
A: I said, "I don't know."
Q: Did you tell -- what did you say in answer to the question about whether they were happy together?
A: Last time I saw them together, they were cool with each other.
Q: "Cool"? What does "cool" mean?
A: "Cool" is a term, you see -- "cool" they seemed all right. They seemed fine with each other. They didn't seem --Nicole didn't seem really pissed off at my father, and my dad didn't really seem too pissed off at Nicole. They were pretty civil.
Q: When was the last time you saw them together?
A. I never saw -- I didn't see them together I mean, one person --one person's feeling toward the other, that was the general feeling I had, and that was around the time that he had gotten soup for her when she was sick. He didn't have anything bad to say about her. She didn't have too much bad to say about him.
Q: Did you find out that they had split up shortly before Nicole's death?
A: See, that part confuses me. I don't remember. They had gotten together and split up, gotten together and split up so many times, I don't remember. I'd come by sometimes; Nicole would be at the house, and they'd seem fine and everything would be cool, and then I'd come by again and Nicole wasn't around or Nicole was doing something else.
So I really tried -- I didn't even try to get into it, you know. I knew that sometimes they were together and sometimes they were apart.
Q: Well, what was your understanding as of the morning that -- of June 12th or the afternoon of June 12th when Nicole called you and told you that they were going to have dinner at Mezzaluna and not at Jackson's?
A: What was her what?
Q: What was your understanding at that point in time about the relationship between Nicole and O.J. Simpson?
MR. LEONARD: I am going to object. Calls for speculation, lack of foundation.
THE WITNESS: I didn't really think anything of it.
BY MR. PETROCELLI:
Q: In other words, did you think they were split up during this time or back together during this time?
A: No, no, I didn't think they were -- I didn't think they were sleeping together. I knew -- I didn't think they were sleeping together.
Q: You thought that their sexual/romantic relationship had ended. Right?
A: Yeah, because they were always pretty civil as far as the kids went --
Q: Yeah.
A: -- I mean that day, I mean, he was at the recital, and other days, you know, they were together, but they weren't, you know, romantically --
Q: And did you have an understanding as to when the romantic relationship ended --
A: Ended? Not --
Q: -- prior to Nicole's death?
BY MR. LEONARD: I am going to object because it's calling for speculation, lack of foundation.
THE WITNESS: I would be speculating because I don't know whether or not they were romantically involved when he brought her the soup or not. I don't know. Maybe they weren't just doing it because she was sick.
BY MR. PETROCELLI:
Q: Did there come a time --
MR. LEONARD: Excuse me. If you'd just sit up a little bit, I think you are going to be in the shot a little bit better. There you go.
BY MR. PETROCELLI:
Q: Did there come a time in the last two or three months of Nicole's life when you learned that their attempt at reconciling had come to an end?
A: Not that I knew of
Q: No one ever said, "By the way, Nicole and I are finished," or "O.J. and I are finished"?
A: Not to me.
Q: Did you hear from anyone that
that had happened?
MR. LEONARD: At the time?
MR. PETROCELLI: Prior to Nicole's death.
MR. LEONARD: Okay.
THE WITNESS: No. I didn't hang around too much, you know. I was just -I just came by once in a while.
BY MR. PETROCELLI:
Q: Did Arnelle pick up the phone and say, "Dad and Nicole have split up for good"?
A: No. Arnelle wouldn't do that.
Q: Why not?
A: I don't know. She just wouldn't. I mean, I knew they got divorced when they got divorced, but, I mean, they were already divorced, so I wouldn't get a phone call saying, "Dad and Nicole split up for good." Arnelle wouldn't do that, you know.
Q: In any event, you didn't get any such call. Right?
A: No, I didn't. I didn't.
Q: Okay. You had no information whatsoever about the state of their relationship other than that they were divorced, as of the date that Nicole was killed. Right?
MR. LEONARD: I am going to object. I think that mischaracterizes his testimony.
BY MR. PETROCELLI:
Q: Well, you said you didn't think they were sleeping together, but you have no basis for that. Right? Nobody told you that.
A: No, nobody told me.
MR. LEONARD: He said --
BY MR. PETROCELLI:
Q: After they were divorced --
MR. LEONARD: Excuse me-
MR. PETROCELLI: Excuse me. Let me ask a different question.
MR. LEONARD: Okay.
BY MR. PETROCELLI:
Q: After they were divorced, did you ever learn that they had begun sleeping together again?
A: Yes, I did.
Q: And how did you find that out?
A: When Nicole was at the house and they were all lovey-dovey with each other.
Q: Okay. And that's the first time that you found out, by seeing them together, not by someone announcing to you or telling you, "By the way, they were getting back together"?
A: No. Did I make it seem that way? If I did, no. No. They were just together.
Q: Okay. And when did that happen? Do you remember?
A: I don't remember the date. I don't remember dates.
Q: Did you talk to your father about, "Hey, what's going on? Are you getting back with Nicole?" Did you have a conversation like that with him?
A: No, I didn't get into it.
Q: Or with Nicole?
A: No, I didn't get into it. What they did was what they did. I did what I did.
Q: Okay. And you can't put a time frame on when you saw them lovey-dovey together?
A: No. Let's see. It was a nice day out. Let's see. It was at some point Nicole had just gotten in a car accident with Faye, so, I mean, I don't know if you have a date on that. Something --
Q: Is that the last time you saw O.J. and Nicole lovey-dovey together?
A: No.
Q: When is the last time?
A: I think it was when we were all together, and when I say "all," it was my father, myself, my girlfriend, my sister, a friend of my sister's, Faye, her boyfriend at the time Christian. I think I already said Nicole. We were all down in Laguna for a weekend, and everybody was one big, happy family.
Q: Do you remember the month?
A: No, I don't.
Q: Is that the last time you can recall all being together again as one big, happy family?
A: That was the one time I can recall.
Q: That's the last time. Right?
A: Yeah. That I can remember.
Q: Was it before -- before Mother's Day 1994?
A: I don't remember.
MR. PETROCELLI: Okay. We have to change the tape here.
THE VIDEOGRAPHER: This is the end of tape No. 2.The time is approximately 2:46, and we are off the record.
(Recess.)
THE VIDEOGRAPHER: We are on the record. The time is approximately 3:00 o'clock. This is the beginning of tape No. 3.
BY MR. PETROCELLI:
Q: When you were born in 1970, where did you first live?
A: Up on Mulholand off the 405.
Q: On Deep Canyon?
A: Not Deep Canyon.
Q: What was the name of the place?
A: The street was Elvill, I think.
Q: And at that time O.J. Simpson and Marquerite were married and living together?
A: Yes, sir.
Q: And when is the next house you lived in -- what is the next house you lived in?
A: We got a house in Buffalo, so we lived in Buffalo like, you know, during the football season a couple times.
Q: And then --
A: And then Rockingham.
Q: And then Rockingham.
A: Yeah.
Q: So the -- you lived at this house on Mulholand?
A: Yes.
Q: And in Buffalo.
A: Yeah, just during -- just a couple months out of the year.
Q: But all the time you were in Los Angeles until you moved to Rockingham, you lived in this house on Mulholland?
A: Yes, sir.
Q: What's the name of the street again?
A: I think it's Elvill or Elvito. I don't remember, it's such a long time ago.
Q: And your father left the household when?
A: Early '80s maybe. I'm sorry -- yeah, early '80s, late '70s.
Q: Late '70s? You were a young boy?
A: Yeah, ten, nine, maybe earlier. Seven. I mean, I know he was seeing Nicole while my mom was married.
Q: How do you know that?
A: Both of them have told me. All three of them, actually, have told me. But I can't remember when he actually moved out.
Q: Okay. And you first saw -- met Nicole when?
A: First time I really -- first time I met her I didn't know it was her. First time I officially met her had to be '81.
Q: The first time --
A: I don't know. It's a long time ago.
Q: The first time you met her when you didn't know it was her was when?
A: My dad took me and a friend to see THE CHAMP, and Nicole and Denise were there, and my dad said, "Look at those two girls. You think they're pretty?" I mean, he knew them already.
Q: I see. But he didn't tell you.
A: He didn't think it right that I met them yet, so it was just too soon.
Q: Okay. And when your dad left the home, he then moved into Rockingham?
A: When he left, no.
Q: Excuse me. You went to -- the whole family moved to Rockingham, including Marquerite. Right?
A: Yes, sir. Yes.
Q: And you lived with Marquerite and Arnelle and your father at Rockingham for a short period of time?
A: Yes, sir.
Q: And then when your father and Marquerite split up, Marquerite left the household. Right?
A: No. She stayed at the house, and he left first.
Q: And then as part of their divorce, he kept the house and she moved out?
A: Exactly.
Q: And then where did she move from Rockingham'
A: [Address deleted.]
Q: When she moved to Encino, did you move in with her at that time?
A: Yeah.
Q: With Arnelle?
A: Yeah.
Q: Okay. And you stayed at that Encino home for how long?
A: Until the 6th grade, so --
Q: Then you moved to Rockingham. Right?
A: Yes.
Q: Okay. Did you ever see Nicole and O.J. Simpson get into any heated arguments in your presence?
A: Yeah.
Q: Where they were really pissed off at each other, to use your terminology?
A: Yes.
Q: Okay. And how did each of them behave? Did they scream, They yell? They throw things at one another?
A: I --
Q: Describe the arguments to me, the way they conducted themselves.
A: They would scream and yell at each other. I never seen them throw things. I've seen maybe one person walk out into the next room and slam the door behind them, but that's the most actual physical thing that I've seen.
Q: They would yell profanity at each other?
A: Yeah, I'm sure there was some profanity in there.
Q: And what would they argue about in your presence?
MR. LEONARD: I'm going to object as being vague, compound, overbroad.
BY MR. PETROCELLI:
Q: You can answer.
A: I don't know. I remember one time there was bills were high in the house, and there was some argument about that.
Q: Anything else?
A: There was some other stuff. I don't remember specifically what it was.
Q: Do you remember whether they argued over infidelity on your father's part?
A: Yeah, I know -- yeah, I'm sure I heard them arguing. I never know exactly what it was about, but I had a -- I could tell by what Nicole was arguing about that, you know, it was about something like that.
Q: And do you know who your father was seeing while she was -- while he was living with Nicole?
MR. LEONARD: Object. Calls for speculation, lack of foundation.
THE WITNESS: Do I know who he was seeing when he was living with Nicole?
BY MR. PETROCELLI:
Q: Yes.
A: No. I mean, no.
Q: Do you know who he was unfaithful with?
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
THE WITNESS: No. Not specifically, no.
BY MR. PETROCELLI:
Q: You don't have any knowledge or information about other women that he was seeing?
A: No. I knew there were other women, but I didn't know exactly who.
Q: Well, you didn't know who they were. Is that what you're saying?
A: No.
Q: And how did you know there were other women?
A: I hear stories. And I know my dad, too, so...
Q: What do you mean, you "know" your dad"?
A: I know my dad. I know that he likes women.
Q: You ever see your dad hit another woman?
A: No.
Q: You ever see your dad restrain Nicole physically?
A: Because they were upset or something?
Q: Yes.
A: No.
Q: Did you ever see Nicole hit your father?
A: No.
Q: When O.J. and Nicole split up, do you know why they split up?
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
THE WITNESS: Not exactly.
BY MR. PETROCELLI:
Q: Did you talk to either one of them about why their marriage was coming to an end?
MR. LEONARD: Objection. Compound.
THE WITNESS: I listened.
BY MR. PETROCELLI:
Q: To whom?
A: Both of them.
Q: As they talked to you?
A: Yeah, basically.
Q: What did they say to you?
MR. LEONARD: Objection. Compound.
THE WITNESS: Nicole might talk about maybe my father's womanizing, and my dad might talk about -- about whatever bugged him about Nicole and about the situation, how -- where is she going to live in relation --
BY MR. PETROCELLI:
Q: What did he say bugged him about Nicole?
A: I don't know. Being accused all the time of actually doing something with other women.
Q: He being falsely accused?
A: Yeah. Well, he would say that.
Q: And he said that would bug him?
A: Yeah. I thought it was kinda funny. I just don't think that was the reason why they broke up with each other.
Q: What was the reason?
MR. LEONARD: Objection. Calls for speculation.
THE WITNESS: I don't -- I mean, I don't know. It was a combination of things, I'm sure.
BY MR. PETROCELLI:
Q: Do you know what they are?
MR. LEONARD: Objection --
THE WITNESS: No, I don't.
MR. LEONARD: -- calls for speculation.
You have to let me get an objection in, Jason.
THE WITNESS: Sorry.
MR. LEONARD: Want to go through that again?
MR. PETROCELLI: No. It's all right.
MR. LEONARD: Okay.
BY MR. PETROCELLI:
Q: When Nicole moved into the Gretna Green place, did you talk to her about men that she was dating?
A: Never.
Q: Never?
A: No.
Q: Did you ever meet or see any of the men she was dating?
A: Yeah, I met one guy, but I didn't know she was dating him until after, when I saw him during -- and I say "after," I mean after the killing. I didn't know she was seeing him until I saw him on TV and "Geraldo" and stuff like that.
Q: And who was this guy?
A: What's his name --
Q: Keith Zlomsowitzh?
A: Yeah, the tan guy, yeah. I saw him at the house, but I didn't know they were seeing each other.
Q: Nicole never discussed any of that with you. Right?
A: No, she didn't tell me she was seeing him. I don't know if they were, though. I thought they were just friends at the time. I thought he was in the restaurant business or something, because we spoke about restaurants.
Q: Prior to Nicole's death do you know whether she was involved in the use of drugs?
A: I don't know if she was involved with drugs, no.
Q: And do you know whether Faye Resnick was?
A: Prior to her death, no.
Q: Okay. Do you know of anybody other than O.J. Simpson who would have a reason to kill Nicole?
MR. LEONARD: Objection. Lack of foundation, calls for speculation.
BY MR. PETROCELLI:
Q: You can answer.
A: I can't understand why anybody would want to kill Nicole or Ron.
Q: Well, you didn't know Ron. Right?
A: I can't see why anybody would want to kill anybody.
Q: But you knew Nicole. Right?
A: Yeah.
Q: And you don't know of anybody that she was having any confrontations or conflicts with, putting aside O.J. Simpson?
A: I don't know anybody, no.
Q: Excuse me?
A: I didn't know of anybody she had any conflicts with. Enough to kill her?
Q: Any conflicts --
A: No.
Q: -- or confrontations with. Excuse me? The answer is no. Correct?
A: No, yeah.
Q: So she never told you about anybody that she was having a problem with. Right?
A: Not that she was having a problem with.
Q: Correct?
A: Yes, sir.
Q: Okay. For example, she never told you that one of her -- one of the men that she was seeing she was having a real problem with or he was giving her a hard time or anything like that. Correct?
A: Correct.
Q: Did you buy Nicole a birthday present for her birthday in May of 1994?
A: May of '94.
Q: Her last birthday.
A: No, I don't think I did.
Q: Do you know whether your -- whether O.J. Simpson did?
A: I don't know.
Q: Do you know whether O.J. Simpson was seeing Paula Barbieri near the end of Nicole's life?
MR. LEONARD: Objection. Lack of foundation, calls for speculation.
THE WITNESS: I don't. I don't know if he was seeing her at that time.
BY MR. PETROCELLI:
Q: When was the last time before Nicole's death that you had seen Paula Barbieri?
A: I don't even know. I don't even know. I've only seen her a handful of times.
Q: When was the last time before Nicole's death?
A: I really couldn't even tell you. I think I saw Paula maybe four or five times. I wasn't real tight with Paula or anything. I'm not now.
Q: Did you know that Paula Barbieri had gone with O.J. Simpson to Palm Springs on Memorial Day weekend, 1994?
MR. LEONARD: Are you asking if he knows that now or if he --
MR. PETROCELLI: Yes.
Q: Whether you knew it at the time that they had gone off together.
A: Memorial Day weekend?
Q: Yeah.
A: '94?
Q: Yes.
A: That was the weekend of the barbeque. He was at the house.
Q: That was on a Monday, the barbeque. I am talking about the Saturday and Sunday.
A: Oh, no, I didn't know.
Q: You didn't know any of that?
A: No, I didn't know.
Q: And was Paula Barbieri at that barbeque?
A: No. I didn't see her there if she was. I don't think she was.
Q: Were friends and family at that barbeque?
A: Yeah. Four family members and the rest was friends.
Q: Did you invite Nicole?
A: No, I didn't.
Q: Did you invite Sydney and Justin?
A: Yes. I think Nicole was sick still.
Q: Did you -- you didn't invite her.
A: No, I didn't. Sorry.
Q: Okay. What family members were there?
A: Sydney, Justin. My Aunt Shirley and my Uncle Benny surprised us. They were coming back from a reunion, so they stopped by on the way, and then my dad came home and my sister. That's all the family was there.
Q: And do you have any understanding as to why Nicole was not there?
A: It was my sister's friends and my friends. It was a bunch of kids. It was a barbeque for a bunch of younger folks. I didn't even expect my dad to come, to be perfectly honest.
Q: He showed up unexpectedly?
A: I think Arnelle knew he was coming. I didn't think he was gonna come.
Q: Okay. And during the week of -- first week of June, do you know if your father went out of town at all?
A: No.
Q: What about the second week of June?
A: Yeah, I knew he went to Chicago, but --
Q: Before the Chicago trip, did you know where any of -- where he went out of town?
A: I have no idea.
Q: Did you know that he went back East to Connecticut and Long Island?
A: No idea.
Q: Did he call you from the East?
A: Never.
Q: Okay. Did you speak to your father on June 12, 1994 --
A: No.
Q: -- the day of the recital and of Nicole's murder?
A: No.
Q: Did you speak to him on June 11?
A: No.
Q: In person or telephone?
A: No, I don't think so.
Q: And not on June 12 either. Right?
A: No.
Q: What about Friday June 9, the day he arrived back from New York?
A: Uh-uh. I don't remember when the last time was I saw him.
Q: When was the last time before Nicole's death that you spoke to your father?
A: I'd have to guess. It would be at the barbeque, that Memorial Day barbeque.
Q: Was it Labor Day or Memorial Day?
A: Memorial Day.
Q: You didn't tell your father that you were going to see him at the recital -- or see him at dinner, I should say, following the recital?
A: At the barbeque. I knew I wasn't going to be going to the recital. In the first place, I wouldn't have said that to him. So, no. I mean, I don't remember -- I just remember seeing him at the barbeque, and that was it. I never --
Q: Did you say, "I'll see you at Jackson's, where everyone is going to after the recital"?
A: I hadn't known that yet until the Friday or Saturday before I --
Q: So you had no conversation with him at the barbeque about seeing him at the recital --
A: Yes.
Q: -is that right?
A: Right. I didn't have a conversation with him at all about any of that.
Q: None.
A: No.
Q: And did you have any conversation with him at the barbeque about Nicole?
A: No.
Q: How he was feeling towards her, what was going on in their life, how she was, anything like that?
A: No.
Q: Okay. By the way, what was the relationship like prior to Nicole's
death between O.J. Simpson and Sydney Simpson?
MR. LEONARD: I am going to object as being vague.
Go ahead if you can answer.
THE WITNESS: It was -- it wasn't -- there didn't seem like anything wrong to me. I didn't see a problem.
BY MR. PETROCELLI:
Q: You didn't see any problems in that?
A: No, I didn't.
Q: Did Sydney ever talk to you or complain to you or talk to you about her father?
A: Yeah.
Q: And did she ever complain about him?
A: Sometimes.
Q: What would she say?
A: "Dad is being dorky," or "goofy" or whatever. But not -- I mean, not like "I hate him" or anything like that.
Q: So from your observations, there was a normal relationship there?
A: Yes.
Q: And with Justin also?
A: Justin, yeah.
Q: Okay. Did you ever see your father spank either Sydney or Justin?
A: I've never seen it, no.
Q: Last time you were hit by your father was when you were how old?
A: I don't remember. I mean, I gotta guess.
Q: 14, you said?
A: I'd have to guess. I'd say 14.
Q: Did he ever hit you with anything other than a belt?
A: Never.
Q: Okay. Let's go back to the telephone call that you had with Nicole on June 12. Who called whom?
A: I don't remember. I probably called her, though, I would think, just to find out exactly how many people were coming, you know, that whole thing. I think I did call her, actually, to find out exactly how many people, if they wanted like, you know, a fixed menu. "What time do you think you guys are going to be there?"
Q: What did she say to you?
A: What?
Q: Tell me what she said after you called her.
A: She said she didn't think that they were gonna be swinging by Jackson's because it was just too expensive, and the kids, by the time they got way out there, they're gonna be all restless, and by the -- you know, "We're just gonna have dinner up the street."
I mean, she went to Mezzaluna all the time so it was just easier for her. I figured okay, fine go. I was kinda hurt; I wish they would have come to the restaurant, but now I really wish they would have come to the restaurant, but she wanted to go to Mezzaluna.
Q: Did she tell you that O.J. Simpson would be going to the dinner?
A: She -- no, it never came up.
Q: That didn't come up?
A: It didn't. Because actually I was calling to find out how many people and who was coming, so once I found out they weren't gonna be coming at all, it was moot.
Q: When you first spoke to her about coming to Jackson's either Friday or Saturday before the 12th, did she tell you that Mr. Simpson would be attending this dinner?
A: She never -- that was never brought up.
Q: Your understanding was that the whole family would be coming, and if he was at the recital, he would come also. Right?
MR. LEONARD: Objection --
BY MR. PETROCELLI:
Q: Excuse me?
MR. LEONARD:-- lack of foundation.
BY MR. PETROCELLI:
You may answer.
A: Yeah, I would assume he would be there if he was in town.
Q: Did you learn after the -- you learned after the recital that he did not attend the dinner at Mezzaluna. Right?
A: Yes.
Q: And did you find out why he didn't attend?
A: From my understanding, it's because she didn't want him there.
Q: How did you find that out?
A: Through the previous case.
Q: Did you ever ask your father why he did not go Mezzaluna for dinner?
A: No, I didn't.
Q: Did you ever ask your father why Nicole did not want him to go and did not invite him to go?
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: No, I didn't.
BY MR. PETROCELLI:
Q: Have you ever asked anybody about that?
A: About why he didn't go?
Q: Yes.
A: No, I didn't.
Q: Have you come to learn since Nicole's murder that there was a severe conflict in your father's relationship with Nicole just before her death?
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: That seems to be the general belief, I guess, now.
BY MR. PETROCELLI:
Q: Have you ever asked your father about that?
A: No, I haven't.
Q: Do you know that he wrote her a letter dated June 6 concerning her possible violation of IRS laws?
A: No --
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: -- I never knew that.
BY MR. PETROCELLI:
Q: You didn't know that?
A: No.
Q: Never seen that letter?
A: No.
Q: Did you know that he was threatening to report her to the authorities?
MR.LEONARD: Objection. Lack of foundation.
THE WITNESS: I can't ask you a question.
BY MR. PETROCELLI:
Q: For violating tax laws, did you have any information like that?
A: No, I didn't. I didn't know anything.
Q: Does that come as a surprise to you, that your father would do such a thing?
A: Yeah. I was just about to ask you. For what?
MR. LEONARD: Objection. Argumentative.
BY MR. PETROCELLI:
Q: I'll show you the letter. Did you believe Nicole to be an honest person?
A: Yeah.
Q: Okay. Did you ever know her to lie to you?
A: Not that I know of.
Q: Okay. Are you aware that she wrote down in her own handwriting incidents of abuse at the hands of your father?
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: Am I aware that she did it?
BY MR. PETROCELLI:
Q: Yes.
A: I heard that she did it.
Q: Have you ever seen her notes?
A: No, I haven't.
Q: Have you ever asked your father about them?
A: No, I haven't.
Q: Excuse me for a second while I find these exhibits.
(Pause in the proceeding.)
MR. PETROCELLI: You know the exhibit number, Dan?
MR LEONARD: No, I'm sorry.
BY MR. PETROCELLI:
Q: Let me show you Exhibit 52. Do you recognize the signature as your father's?
A: Half of it, yeah.
Q: Where it says "O.J."?
A: Yeah. Do you mind if I read it?
Q: You can read it.
(Witness reviews document.)
A: You know what? I am aware of it, but I didn't know it was for that stuff. I just -- I thought he -- I remember him saying something about he just was gonna tell her not to use his address for anything to be mailed, but I didn't know it was stuff. I remember hearing him just saying something in passing.
Q: When did he tell you that?
A: I don't know. At some point.
Q: Before Nicole's death?
A: At some point before this, I guess, yeah.
Q: Before June of 1994?
A: Yes.
Q: Tell me as best you can recall what he said to you about this subject.
A: He had brought it to my attention that he was drafting a paper -- oh, sorry -- he was drafting a paper and telling Nicole to stop using Rockingham as an address to mail her mail. Here it says taxes and stuff. I didn't realize -- he wasn't specific like that. I didn't really think too much of it because I'm like, well, so what, you know, mail.
Q: Did he tell you why he was writing such a letter to Nicole?
A: No. Something like I would do in high school or something like that. It was chintzy. Just seemed like he gets tired of looking at her mail. You now, "Why don't you just have it mailed to your house?" That's the way I took it.
Q: Did you understand that they were going through -- a little fight or something at this time?
A: They must be if he's doing something so small. But this is taxes. That -- I would see something for a sale at Theodore and it said, "Nicole," and he'd be like (Sound), you know, and it as like, okay, whatever.
You know, it was divorce stuff. I'd seen it with my mom and my dad. I've seen it with my friends' parents when they were getting divorced. It was typical divorce stuff. I didn't know it was tax, though, whatever that is.
Q: This is another letter, Exhibit 53 June 8, 1994, which is four days before Nicole's death. It says:
"Dear Nicole, to set the record straight, when Arnelle, Jason or myself are at home to watch the kids, especially around the pool, they are welcome here at any time. I would love to have them 24 hours a day, as it is their home, too. However, Gigi is not an emergency cook, baby sitter or mad runner for you. She's an employee of mine and I expect you to respect that now and in the future." Do you know anything about that letter?
A: No. That's a little hard-core but, no, I didn't know about that.
Q: Okay. Did you have any argument with Nicole before her death about her coming to the house?
A: No.
Q: Did you know of any argument between Nicole and Gigi?
MR. LEONARD: Objection. Lack of foundation --
THE WITNESS: No.
MR. LEONARD: -- calls for speculation.
THE WITNESS: Sorry.
BY MR. PETROCELLI:
Q: These are Nicole's notes that she made. This is Exhibit 86. Do you recognize the handwriting as Nicole's?
A: Yes, I do.
Q: Okay. Nicole has several pages of notes dealing with Justin and Sydney and whether their dad was picking them up or taking them home or on time, things like this with Justin and Sydney.
Do you recall in the months before Nicole's death any arguments between O.J. and Nicole about Sydney and Justin?
MR. LEONARD: Are you asking if he overheard any such --
MR. PETROCELLI: Yeah.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: You're not aware of anything?
A: No. No. Between -- no.
Q: Were they fighting about the children --
A: No, I've never heard --
Q: -- to your knowledge?
A: No. No.
Q: You know nothing about that?
A: Uh-uh. No. Sorry.
Q: Okay. On June 3 Nicole writes:
O.J. came to pick up kids at 8:30 p.m. They wanted to stay home cuz I let them organize sleep overs at last minute -- thought daddy wasn't coming." Do you have any knowledge of whether your father was supposed to pick up the kids on June 3 but got there too late to get them?
MR. LEONARD: Objection. Lack of foundation.
BY MR. PETROCELLI:
Q: Do you have any information about that?
A: I have no clue about that. This is all news to me.
Q: She writes:
"Told O.J. I'd drop them off 1st thing in the morning [sic]. He said OK. Then 'You hung up on me last nite, you're gonna pay for this bitch, you're holding money from the IRS, you're going to jail you f---ing c--t. You think you can do any f---ing thing you want, you've got it coming -- I've already talked to my lawyers about this, bitch - they'll get you for tax evasion bitch I'll see to it. You're not gonna have a f---ing dime left, bitch, etc."' This was all being said as Sydney's girlfriend Allegra was being dropped off.
You want to take a look at that?
MR. LEONARD: Is there a question?
MR. PETROCELLI: Yeah, I'm going to ask him a couple questions about that.
MR. LEONARD: Was that part of a question, what you just --
MR. PETROCELLI: Yes, it is.
THE WITNESS: Go ahead. Go ahead.
BY MR. PETROCELLI:
Q: Have you ever heard -- well, first of all, were you aware of any argument between Nicole and O.J. on -- along the lines of what Nicole wrote in her notes?
MR. LEONARD: Objection. Vague, lack of foundation.
THE WITNESS: No, not like this. This doesn't even sound like he talks.
BY MR. PETROCELLI:
Q: My next question was: Have you ever heard your father use language like that --
A: No.
Q: -- towards Nicole?
A: The C word? No way. No. Not like that.
Q: You know of any reason why Nicole would make such things up?
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
THE WITNESS: No, I don't. No, I don't.
BY MR. PETROCELLI:
Q: Did you ever hear your father curse at Nicole like other than the C word, call her a bitch and things like that?
MR. LEONARD: Objection. Vague.
BY MR. PETROCELLI:
Q: You can answer.
A: No.
Q: Never?
A: I've heard him cuss, but not call her names.
Q: You ever hear him call her a bitch to her face?
A: Not that I remember he ever called her a bitch.
Q: Nicole ever tell you that she was afraid of O.J. Simpson?
A: No.
Q: Did she ever tell you that he had a very violent temper?
A: She never said that to me, no.
Q: She ever tell you that he -- that she had to call the police on him at Gretna Green?
A: No, she never told me.
Q: You heard your father's voice on the tape, the 911 tape?
A: Yes.
Q: You heard how angry he was on that tape?
A: Yes.
Q: You heard him ranting and raving and cursing?
A: Yes.
MR. LEONARD: Objection.
BY MR. PETROCELLI:
Q: Have you ever hear him do that?
A: I've heard him arguing, yeah, yelling, yeah.
Q: Like you heard him on the tape?
A: Yeah, not that much different. Sometimes. Once or twice.
Q: You've heard him arguing with Nicole like how he sounded on the 911 tape?
MR. LEONARD: I am going to object. You are asking him to remember something he heard at a trial months ago, to compare that to something else that may have occurred a long time? That's what you want to ask him?
MR. PETROCELLI: Exactly.
MR. LEONARD: Okay. I am objecting. I think it's an unfair question.
BY MR. PETROCELLI:
Q: Go ahead.
A: I've heard both of them but, yeah, he was -- he was at that level, but her voice was, too. So they were --
Q: You heard them --
A: -- both trying to get over each other's voice.
Q: When you heard them fighting like that, like at the level of intensity and anger, as reflected by that 911 tape, what were they fighting about?
A: The 911 tape, I don't know.
Q: The ones you heard.
A: I don't remember. I don't remember specifically. It was usually behind a closed door. I can hear them yelling. I wasn't trying to get into it because, I didn't like to hear it; I wasn't trying to hear something I didn't want to hear in the first place.
Q: Were you with O.J. Simpson and Nicole on Christmas 1988 when they went to Hawaii?
A: No, I wasn't.
Q: Did you hear about an incident when O.J. got upset with Nicole because she permitted a gay man to kiss Justin?
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Okay. Are you -- did you ever hear about an incident when your father beat Nicole in their apartment in San Francisco and threw her clothes out of a window?
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: No, I haven't heard that one either
BY MR. PETROCELLI:
Q: During Nicole's and O.J.'s divorce, did your father ever tell you that Nicole was inventing stories of abuse against him?
A: Absolutely not.
Q: Do you have any understanding or information as to why Nicole would write these incidents of abuse in her own handwriting --
MR. LEONARD: Objection. Lack of foundation --
BY MR. PETROCELLI:
Q: -- if they were not true?
MR. LEONARD: -- calls for speculation. It's argumentative.
BY MR. PETROCELLI:
Q: Okay. You can answer.
A: No.
Q: It wasn't your experience with Nicole in all the years you knew her that she would lie about serious things. Correct?
A: No, she wouldn't do something like that.
Q: And it wasn't your experience with Nicole that she would do things to hurt your father. Right?
A: No.
Q: You've never asked your father since the murder of Nicole whether he hit her, whether he ever hit her?
A: No, I didn't.
Q: You never discussed that with him?
A: No, I didn't.
Q: He has never come to you and said, you know, "We never had any altercations. "We did" or ever come to you at all to discuss that subject?
MR. LEONARD: Objection. Compound.
BY MR. PETROCELLI:
Q: You can answer.
A: No, he hasn't.
Q: Okay. Are you familiar with an incident where your father hit Nicole and put her in the wine closet at the Rockingham house?
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: I'm aware of the story.
BY MR. PETROCELLI:
Q: You are?
A: Yeah.
Q: You heard all those stories during the criminal trial?
A: Yeah.
Q: Did you think that they were all fabricated?
MR. LEONARD: Objection --
THE WITNESS: All of them?
MR. LEONARD: -- lack of foundation --
BY MR. PETROCELLI:
Q: Yes. You can answer.
MR. LEONARD: -- calls for speculation, calls for conclusion.
THE WITNESS: No. That one just seemed really far -- really far-fetched to me.
BY MR. PETROCELLI:
Q: When you heard these stories, did you do anything to find out if they were true or not?
A: Such as?
Q: Whatever. Ask Arnelle?
A: Investigate?
Q: Ask Arnelle, ask Marquerite, ask anyone, "Hey, is that true?"
A: Why would I ask Arnelle? I mean...
Q: Do you think that's a preposterous thing to do? Is that what you're suggesting? You're looking at me like I'm crazy.
A: Well, no. Arnelle, I don't think she knows anything.
Q: How do you know that?
A: Because she was just as surprised as I was.
Q: How do you know that?
A: Because like I said, when we just talked to each other, we -- when we would watch or we would see or hear this testimony, we were just as surprised to hear it. That's why if she obviously didn't know it, I didn't know it. Why would I ask her.
Q: So you and she have talked about this, and both of you have told each other that you had no knowledge of any of these incidents of abuse. Is that what you're saying?
A: We didn't -- no, we didn't look at each other and say we had no knowledge. We were just surprised. We were listening to it --
Q: And the implication --
A: -- dumbfounded.
Q: -- being that neither of you had any knowledge of this. Is that right?
A: Something like that?
Q: Yeah.
A: Yeah. Like that, yeah.
Q: And neither of you -- and both of you were just as -- and both of you were shocked when you heard these things in court. Right?
A: Like that, yeah. The 911 tape, to me heard it that -- I mean, I wasn't shocked to hear that. That was bad; it was disturbing, but me personally wasn't shocked. I don't know about Arnelle. That's different. She didn't grow up with my father.
Q: You were disturbed by the 911 tape but not shocked.
A: Yeah.
Q: Okay. And you were disturbed by hearing these other things as well right, these incidents of physical abuse?
A: The physical abuse all disturbed me.
Q: Just like the 911 tape?
A: And those shocked me, yeah.
Q: Did you -- you weren't shocked about the 911 tape because you had been used to hearing your father talk like that at times?
MR. LEONARD: Objection. That mischaracterizes his evidence.
BY MR. PETROCELLI:
Q: Right?
MR. LEONARD: That's argumentative. I instruct him not to answer
BY MR. PETROCELLI:
Q: You weren't shocked when you heard him on the 911 tape, just disturbed but not shocked, because you had heard him like that before. Correct?
A: I was disturbed because -- yeah because I heard him yelling. I've heard that, but I've heard him yelling before.
Q: Yes.
A: Yeah.
Q: That's why you weren't shocked when you heard it on the 911 tape.
MR. LEONARD: Objection. Argumentative.
BY MR. PETROCELLI:
Q: Correct?
A: I would be shocked to find out that Nicole was physically beaten up. I wouldn't be shocked to find out -- to hear somebody yelling in the background or somebody yelling. That doesn't shock, to hear people yell.
Q: That doesn't shock you --
A: It shocks me to hear people or see people hurt other people.
Q: Did you -- when you listened to that 911 tape and knowing Nicole, did you sense fear in her voice?
A: Yeah, she sounded scared.
Q: Did that shock you, that your father could frighten her that badly?
A: Yeah.
Q: Did you go to Michael Millitello's wedding at the Ritz Carlton?
A: No. I don't even know --
Q: Do you know who he is?
A: I remember hearing the name, but I don't even know who that is really.
Q: Who were your father's close friends in June of 1994?
A: Close friends? I would have to say A.C. --
Q: Who?
A: Allen Cowlings.
Q: A.C.?
A: Yeah. June of '94? Allen's always been his friend. Who else. I don't know who he was really tight with, who his really close friends were. Sorry.
Q: You can't identify any close friends in June of 1994 other than A.C. Cowlings?
A: No, because my dad hangs around with a lot of people, and I don't hang around my dad that much, so I don't know. One week he could be with a group of people, you know, and another -- next week see him with another group of people.
Like I said, I don't hang around that much. I stop in a couple times a week, grab a sandwich, do my laundry or something, and I'm back home to my apartment again.
Q: Where -- you were working on the night of June 12?
A: Yes.
Q: When did you leave work?
A: I think -- I think it was around 10:00, 10:30.
Q: Did you punch out?
A: Yeah.
Q: Where did you go?
A: Home, to my apartment.
Q: What time did you get there?
A: I don't remember. It had to be around between 10:30 and 11:00.
Q: Your apartment on Sycamore?
A: Yes, sir.
Q: How far was that from your job, which was Jackson's at that time?
A: About three miles.
Q: Okay. And when you got to your apartment at Sycamore around 10:30 or so, did you call anyone?
A: I might have called my girlfriend.
Q: And who was that?
A: [Name Deleted].
Q: Do you know if you did?
A: I don't remember, no.
Q: Has she told you that you and she talked that evening?
A: No. No.
Q: Okay. What did you do at your house when you got these?
A: Watched TV.
Q: Do you remember what you watched?
A: Not exactly.
Q: What time did you go to sleep?
A: Not till probably late, 3:00.
Q: So from 10:30 to 3:00 you watched television?
A: Yeah.
Q: Did you eat?
A: Probably.
Q: Did you drink anything?
A: Probably. I don't know.
Q: What did you drink?
A: Cranberry juice maybe.
Q: Did you drink any alcohol?
A: No.
Q: Did you take any drugs?
A: No.
Q: You think you spoke to [Name Deleted]?
A: Maybe.
Q: Did you make any plans to do anything?
A: That night?
Q: Yes.
A: No.
Q: Did you call over to anyone in the family to find out how the recital went?
A: No.
Q: Did you call Sydney or Justin --
A: It was too late, no.
Q: -- or Nicole?
A: No.
Q: Or your father?
A: No.
Q: You didn't even know where your father was. Right?
A: No.
Q: You didn't know he was going to Chicago. Right?
A: No. No.
Q: The last time you had spoken to him was the barbeque on the 31st of May. Right?
A: To the best of my recollection.
Q: Okay. So when you came home on June 12 from work, you had no idea where O.J. Simpson was. Correct?
A: I wasn't even thinking about my family, to be perfectly honest.
Q: And you didn't know where he was that evening. Right?
A: No.
Q: And you didn't know what his plans were. Right?
A: No.
Q: Correct?
A: Correct.
Q: Okay. Did you then get a phone call sometime in the middle of the morning?
A: Yeah. Yes.
Q: From whom?
A: From first my sister, but I didn't answer the phone.
Q: Why not?
A: I didn't want to get up. I didn't know what it was. I didn't know what time it was.
Q: How do you know it was your sister?
A: I found out. In retrospect I know it was my sister.
Q: Did you have an answering machine?
A: Yeah. It was --
Q: Was the answering machine on?
A: The volume was turned down low.
Q: So you didn't hear the message being recorded?
A: No.
Q: You still have that answering machine message tape?
A: I think so.
Q: Can you bring it to the deposition at the next session, please?
A: Sure.
Q: With the machine so that we can hear the message?
A: Sure. Well, it's not -- I don't have the message on the machine anymore.
Q: You don't?
A: No.
Q: You erased it?
A: I didn't erase it. I just rewinded it.
Q: You just rewind it.
Q: I see. Okay. So you learned later on that you had that message.
A: Yeah. Can I tell you what the message --
Q: Yes.
A: I mean, she just said, "Jason, call me back."
Q: That's all.
A: Yeah.
Q: Okay. What's the first thing that happened in the middle of the night or the next morning that you recall?
A: Well, then I got another phone call, and I decided to pick it up this time because I figured it must -- whatever, I got to pick it up.
Q: And what time was it?
A: I don't remember.
Q: Who was it?
A: My mom.
Q: What did she say?
A: She said, "Call your sister. It's important."
Q: Nothing else?
A: I don't think so.
Q: Did she tell you what had happened?
A: I was groggy. No, my mom didn't tell me.
Q: You called your sister?
A: I think so. No. You know what? I didn't talk to my mom. I can't remember if I talked to my mom, 'cause it was so early. I think I talked to my mom, hung up the phone. I can't remember if I called the house and Arnelle picked up the phone or if Arnelle ended up calling me back, but I did talk to Arnelle. It was the third phone call made, and she told me.
Q: You talked to your mother. She said, "Call Arnelle. "
A: She said, "Did Arnelle talk to you?" She said, "Jason, you need to talk to her."
I said, "I don't know. The phone just rang." I said, "Okay, fine," and I hung up the phone.
I can't remember then if I picked up the phone, called the house and got Arnelle or if I just put the phone down and the phone rang again.
Q: Anyway, the next call was with Arnelle?
A: Yes.
Q: And what time was it?
A: When was it. 6:30, 7:00.
Q: What did Arnelle say?
A: She -- she said, "Jason, you need to come to dad's house." She said, "Jason," she said, "Nicole had -- Nicole had just died."
Q: What did you say?
A: I don't think I said anything. I was -- I said, "How?" I couldn't figure out how. I thought she had died of steroids or something. I thought she was taking steroids because her body, every time I saw her, had changed. I thought -- I don't know. I thought she had a heart attack or something.
And Arnelle said, "No. She was killed," and that's it, and I hung up the phone.
Q: Did she tell you how she was killed?
A: No.
Q: Is that the end of the conversation: "She was killed"?
A: "She was killed.". "She's been killed."
Q: Was anything said about your father?
A: I just hung up the phone. I said, "I'm coming over now. " I hung up and got in my car immediately.
Q: No conversation about O.J. Simpson in the call with Arnelle?
A: No. I just got in my car. I left.
Q: Okay. And when you arrived, you went to Rockingham?
A: I first went to my girlfriend's house on the way 'cause I couldn't drive. I couldn't breathe. I couldn't do anything. I told you before, I have epilepsy. I have to take my pills in the morning and at night. Sometimes -- you know, when I'm scared -- I didn't want to get too overly excited, and on the way I just had to pull over, and I was right by her house, so I went there and I banged on her door, kinda collapsed there for a second, and -- no more than five minutes, and said, "I gotta go get Arnelle." So I went to the house, Rockingham.
Q: With your girlfriend?
A: No. By myself. I just said, "I gotta leave."
Q: And what happened when you got to Rockingham?
A: Arnelle was outside with Kato. We couldn't go anywhere. They were out on the curb. I tried to find out what was happening. I was asking questions, and Kato couldn't answer any questions. Arnelle couldn't answer any questions. She couldn't say anything. And I tried to ask the police. They wouldn't tell me anything.
Q: This was outside the property?
A: Yeah. They wouldn't -- they wouldn't let in. They wouldn't let us do -- I couldn't find anything out. All I know is that Nicole's dead. I didn't know where dad was. I was so far out of the picture, I felt like --
Q: Did at this time Arnelle tell you that they were trying to pin this on your father?
A: No, she never said that.
Q: There wasn't any suspicion at that time that they were trying to --
A: He was out of town. When I found out he was out of town, I was like, "Well, when he's coming back?"
Q: Who did you ask that to?
A: Arnelle said, "Well" -- I said, "Well, where's dad?"
And she said, "He's out of town."
"Does he know?" you know, I think. And I asked questions about the kids.
Q: What did Arnelle say when you said, "Does he know?" You asked Arnelle, "Does he know?" and what did she say?
A: I said, "What about dad, does he know?" And she said, "Well, he's out of town."
Q: Did Arnelle indicate to you whether or not she had spoken to your father?
A: No, she never said that to me. I found that out later.
Q: What did you find out later?
A: That she had talked to him on the phone.
Q: Before she saw you outside on the property?
A: Yes.
Q: How did you find that out?
A: TV.
Q: Did you ever ask Arnelle?
A: I think. Maybe -- I probably did. I don't remember exactly. I mean, we did go over everything over and over and over again. I can't remember, though, exactly.
Q: Who went over and over and over?
A: My sister and myself.
Q: When did you do that?
A: Later that night.
Q: On the 13th?
A: Yes.
Q: You mean the two of you were talking to each other, going over everything that had happened during the day?
A: Trying to piece together the course of events from when she found out to then.
Q: Where was Arnelle during the evening of June 12?
MR. LEONARD: Objection. Lack of foundation, calls for speculation.
BY MR. PETROCELLI:
Q: Did she tell you where she was?
A: I still don't know to this day. She was out. I don't know exactly what she was doing.
Q: You don't know?
A: I don't know if it was a movie or something. I'm not going to speculate, though. She was out.
Q: Did she tell you?
A: No. She might have told me, but I forgot, but she's always out.
Q: Okay. When did you first hear from your father?
A: The 13th. The 13th when he came home, and I -- I then came to the house.
Q: So you saw him for the first time at the house on Rockingham sometime in the evening of Monday, June 13?
A: Exactly.
Q: He had not spoken to you on the telephone yet?
A: No, I didn't -- no. No.
Q: Do you know whether he tried calling you?
A: No, I don't know.
Q: Were there any messages on your answering machine from him?
A: I don't remember.
Q: When you went home later that day and checked your messages, you then heard the message from Arnelle that you received in the early morning?
A: No. I think I might have gone out and replayed it once my mom said to call Arnelle and Arnelle said to come. I think I might have checked it then.
Q: Okay. No messages from your father --
MR. LEONARD: Objection.
BY MR. PETROCELLI:
Q:-- at any time on the 13th?
A: I don't believe so.
Q: Okay. When you saw your father on the evening of the 13th, what did you say to him and what did he say to you?
A: I think the first thing I said was, "I love you," and held him, and we -- he was in the living room, and we went into the kitchen, and we just held each other.
Q: Just the two of you?
A: There were a couple people walking in and out. I don't remember --
Q: What did he say to you?
A: He couldn't really say anything. And I started to talk about -- because I had talked to Justin, I started to talk about my conversation with Justin.
Q: What was your conversation with Justin?
A: I wanted to know what he knew, what his state of mind was and what his -- how he was.
Q: When did you talk to Justin?
A: I talked to Justin from my apartment some point in the afternoon of that day, the 13th.
Q: By telephone?
A: Yeah.
Q: They were at the Brown residence?
A: Yeah, they were in Laguna.
Q: You also spoke to Sydney?
A: I didn't speak to Sydney. I don't think she wanted to talk on the phone or something.
MR. LEONARD: You have to speak up.
THE WITNESS: I'm sorry. Sorry.
BY MR. PETROCELLI:
Q: You said you did not speak to Syndey --
A: I don't feel like talking loud about all this.
Q: -- because why?
A: Sorry. I didn't talk to -- I'm sorry.
A: What did you just say?
Q: I said, did you also talk to Sydney?
A: No, I didn't talk to Sydney.
Q: You spoke to Justin on the telephone, and tell us what that -- tell us what was said in that conversation.
A: I wanted to know how he was doing, how he was, what he was doing. I was kinda stuck because I didn't know what to say to him, but I wanted to talk to him. You know, I mean, I found myself talking to him, but then I was like, you know, Christ, what just happened, you know. I didn't -- and then I was stuck. I didn't know what the hell to say to him.
And then he just told me, "Mommy's dead," and then I just collapsed, told him I couldn't talk to him and that I'd talk to him later and that I loved him.
Q: You called him back -- oh, you said you would talk to him later.
A: Yeah.
Q: Did he tell you anything about what had happened that evening?
A: No. I didn't ask him.
Q: And have you ever?
A: No.
Q: And you haven't asked Sydney. Right?
A: No.
Q: Do you know anybody who has?
A: Not to my knowledge.
Q: Do you know of anyone who has told you what Sydney has said about that evening?
A: No.
Q: You told your father on the evening of the 13th when you were in the kitchen with him what transpired in your call with Justin?
A: Yeah. Yes.
Q: By this time did you have any information or knowledge that the police viewed him as a suspect, the evening of the 13th?
A: Yeah it was all over the news.
Q: Okay. Did you talk to him about that circumstance?
A: No, I didn't.
Q: And did he mention anything to you?
A: Quickly, I think.
Q: What did he say?
A: I think the words were just about how bad everything was, and then quickly he said-and then -- I think he said, "I think I've got a big target on my chest," is what he said. Actually, that's exactly what he said.
Q: What exactly did he say?
A: "I feel like I have a big target on my chest."
Q: Meaning people were aiming at him?
A: Yeah.
Q: Is that all that he said?
A: About that, yes.
Q: How long were you there that evening?
A: I might have spent the night. I'm not quite sure. It was a weekday.
Q: And who was there that evening at the house?
A: Felt like everybody I know was there.
Q: Do you remember who was there?
A: Yeah.
Q: Who?
A: Some people. My sister Arnelle, my Uncle Benny, my Aunt Shirley, my cousins Tony, Tracy and Terry came, my girlfriend had come --
Q: [Name Deleted]?
A: [Name Deleted]. Cathy Randa, Gigi I believe was there -- I'm assuming was there.
Q: Mark Slotkin?
A: Yeah, I remember he came. I can't remember if he came that day or if he came later that week.
Q: Skip Taft?
A: Skip, yeah, was there.
Q: Kato Kaelin?
A: Kato was there, yeah.
Q: Ron Shipp?
A: Yeah, Ron was there.
Q: Ron was a friend of yours. Right?
A: Friend of mine?
Q: Yeah.
A: No, I wouldn't call him a friend of mine.
Q: Prior to the murders.
A: No.
Q: Not a friend of yours?
A: Not mine, no.
Q: Friend of your father's?
A: I call him an acquaintance.
Q: Not a friend?
A: No. I'd fit A.C. more in the category of friend. Ron's more like an acquaintance.
Q: The next level down, you mean?
A: Next level down? No, I don't know. I mean, people you hang out with kinda, and there's people you're really like tight with.
Q: Did you ever have a falling-out with Ron Shipp?
A: Never.
Q: Okay. Any argument with him or dispute with him of any kind?
A: No, I never had any dispute with him.
Q: Okay. Did you ever confide in him about any problems you were having with your father?
A: No.
Q: Okay. Did you ever take a baseball bat, by the way, and beat up a bronze statue of your father in the yard?
A: Yeah, when I was a kid. I was hitting everything, though. The statue was one of the things I hit. I hit a tree.
Q: Did you ever beat that in anger about your father?
A: It wasn't about my father, no. I wanted a party, and I was gonna throw a party, and I got busted. My dad found out that I was going to have a party that night. He said I couldn't have a party.
Q: And what did you do?
A: I got mad, and I had a bat and I started hitting a tree outside, and I think I hit a couple other things, bushes and stuff like that, and I hit the statue. I also hit -- there's another statue of a tennis player.
Q: You hit them both?
A: Yeah. And don't forget the tree.
Q: You hit the tree and the statues. Right?
A: And a couple of plants, I think.
Q: And a couple of plants.
A: Yeah, I think.
Q: Did you damage the statue of your father?
A: Slightly.
Q: Did you hit it a lot of times?
A: No. Just once.
Q: Just one shot.
A: Yeah.
Q: Is that right?
A: Yes, sir.
Q: Okay. Do you recall any conversation between Kato Kaelin and your father on the evening of June 13?
A: No.
Q: Okay. When you first saw your father, did you notice if he had a cut on his finger?
A: No. I actually looked at his hands, and I didn't notice anything.
Q: No cuts?
A: Uh-uh.
Q: Why did you look?
A: Curiosity.
Q: To see if he was the murderer?
A: Just curiosity. I mean, just -- I couldn't believe this, and I looked -- I was looking at his whole person.
Q: You couldn't believe that he might be the killer. Right?
MR. LEONARD: Objection.
THE WITNESS: Yeah.
BY MR. PETROCELLI:
Q: You wanted to see if he had any signs of being in a struggle. Right?
A: Or anything like that, yeah. I mean, I was -- yeah, curiosity, I gotta say, did get me.
Q: Did you know that evening that Nicole had been killed by a knife?
A: No, I didn't. I assumed that, though.
Q: And you saw no bruises, marks or cuts of any kind on your father. Right?
A: No.
Q: And did you see --
MS. ROIT: Which night are we talking about?
MR.PETROCELLI: The night of June 13th when he first saw O.J. Simpson.
Q: Correct?
A: Correct.
Q: And you didn't see any bandages or Band-Aids or dressings for a wound?
A: No, I don't remember seeing anything like that.
Q: Why did you assume that Nicole had been killed by a knife?
A: That's what's in the movies usually. I don't know. If someone says if their throat was cut, I just assumed --
Q: You had heard her throat was cut by this time?
A: I think so.
Q: And then you assumed then it was by a knife. Right?
A: Yeah. I mean, it wasn't a spoon or a sword. I just -- I don't know.
Q: Did your father collect knives?
A: Not that I knew of.
Q: Before Nicole's death, did you have any knowledge of your father having collected or saved or bought knives?
A: Never. It didn't --
Q: You ever see any knives around the house other than in the kitchen?
A: Only knives he ever had were Swiss Army knives, and that's because he had something to do with the company, I think.
Q: And were those knives of different sizes and shapes?
A: No. There was a -- utility pocket knives and knives that go on a key chain.
Q: Small knives?
A: Small ones that you would like use to clean your nails.
Q: That's the only knives you've ever seen --
A: Yeah.
Q: -- him have?
A: Yeah.
Q: Other than kitchen knives.
A: Yes.
Q: What about camping knives?
A: No, I never seen --
Q: Fishing knives?
A: I've never seen any.
Q: You ever go camping or fishing with your father?
A: No.
Q: Did you ever go camping or fishing with Nicole?
A: No.
Q: Your father collect guns?
A: As a hobby, you mean? I don't know. I don't know. I know he had some.
Q: He had guns?
A: Yeah, but I don't know if he got more than one for a hobby or if he literally thought he might need it. I don't know.
Q: You're aware your father had filmed a pilot called FROGMAN?
A: Yeah.
Q: And you're aware that he had used a knife in the FROGMAN footage?
A: I am now, yes.
Q: At the time you were not?
A: No.
Q: Were you aware that he bought a knife in early May of 1994 at a Los Angeles cutlery shop?
A: Now I am, yes.
Q: But not at the time?
A: No.
Q: And you never saw the knife that he bought at the cutlery shop?
A: Have I ever seen it?
Q: Prior to Nicole's death.
A: I think.
Q: Where did you see it?
A: It was in my dad's bathroom.
Q: When did you see it there?
A: When the judge came by to pick it up.
Q: You were there at the time?
A: Yeah.
Q: And you saw the judge find the knife?
A: I saw the judge, yeah.
Q: Where did he find it in your dad's bathroom?
A: There's a vanity and two mirrors this way (Indicating) and a mirror that way (Indicating). You know, you open the mirror and that's where you put medicines.
Q: Surprise you to see a knife in there?
A: Sort of, yeah.
Q: Is that the first time you had seen that knife?
A: Yeah.
Q: Okay. Did you see any cut on your father's hands or fingers the rest of that week of June 13?
A: After that, no, I didn't. No.
Q: Not at all. Right?
A: No.
Q: Okay. And you saw any marks on his body that week?
A: No.
Q: Okay. Previously on the record when I was talking about Nicole's notes of incidents of abuse, I had referred to Exhibit 86 and that was Exhibit 88 I meant to say. Exhibit 86 is the document that I showed you that had her account of the June 3 conversation.
After the evening of June 13, when did you next see your father?
A: That would be the viewing, I think. The viewing.
Q: And between the Monday, the 13th, and the viewing on the 15th, did you talk to your father at all?
A: I think I talked to him a couple times on the phone.
Q: Okay. And do you know where he was staying?
A: At Bob Kardashian's house.
Q: And you called him there from time to time?
A: I didn't call him. I think he called.
Q: And what did he tell you in those conversations?
A: He wanted to know how we were. We wanted to know how he was. I wanted to see him, you know.
Q: Did you go see him?
A: No.
Q: Why not?
A: Because I was there to take care of the family. I guess he thought it was a better idea I stayed at the house.
Q: That you stay where?
A: At the house.
Q: At whose house?
A: Rockingham. I guess. I guess.
Q: What family was at Rockingham? The aunts and uncles?
A: My sister.
Q: And Sydney and Justin were where?
A: In Laguna.
Q: You didn't see Sydney and Justin until when?
A: I didn't see them until five days later or something like that.
Q: At the funeral?
A: Not the funeral. The wake. The wake. That's what it's called. Right?
Q: The viewing?
A: The viewing.
Q: So that's when you first saw Sydney and Justin?
A: Yeah.
Q: Okay. And that's the next time you also saw your father. Right?
A: Yeah.
Q: Did you drive down there with him?
A: We all drove down I think together, but -- no. He was there when we got there.
Q: You got there with whom?
A: With my sister Arnelle and my cousin Tracy and my cousin Tony and I think my cousin Tracy -- I mean Terry.
Q: Did your father tell you at any time in these conversations before the viewing that he was contemplating killing himself?
A: No.
Q: Did he at any time make you think that he might kill himself?
MR. LEONARD: Objection. Vague.
BY MR. PETROCELLI:
Q: Okay. You can answer.
A: Did he ever tell me if he felt like killing himself?
Q: Yeah. Did he ever cause you to be concerned that he might kill himself?
A: No. I didn't think about it. He didn't seem like it to me.
Q: You didn't get that sense from him?
A: No.
Q: Okay. Did you quit your job that week, by the way?
A: I didn't quit, no. They gave me some time off.
Q: Did you have a set of cooking knives?
A: Yeah.
Q: And did you ever take those knives off of, you know, your work premises?
A: All the time.
Q: And where did you keep those cooking knives?
A: In a bag, chef's bag.
Q: In where?
A: What do you mean?
Q: The bag.
A: The bag, I'll take it home with me.
Q: Okay. On the evening of June 12 where was the bag with your cooking knives?
A: With me.
Q: Has your dad ever seen those knives?
A: Probably. Yeah, I think he has.
Q: Okay. Have you ever had any missing?
A: Never.
Q: When you left the restaurant on the evening of June 12, did you wait for your girlfriend there at the restaurant?
A: Yeah. She had my car.
Q: So your girlfriend picked you up.
A: In my car, yes.
Q: From the restaurant.
A: Yes.
Q: And drove you where?
A: To her apartment.
Q: And what did you do there?
A: Dropped her off.
Q: And then went to your apartment?
A: Yes.
Q: Did you go into her apartment at all?
A: I don't think so. No, I didn't. I just kissed her in the car, and she went home.
Q: When was the -- did you -- during the week of the 13th, did there ever come a time when you thought your father was suicidal?
A: During the whole week? Maybe toward the latter part. I felt he was really unstable. I mean, he just seemed -- I think I felt he needed to be more -- maybe around us more.
Q: Did he say anything to you to indicate that he might take his life?
A: No.
Q: Did he say anything to you about arrangements for your future?
A: No.
Q: Did he tell you that he had contacted people who would help take care of you?
A: No.
Q: Did he tell you that he had changed his will?
A: No.
Q: Did he tell you that he had left money with persons for your use?
A: No.
Q: Did he tell you that he had given money to Al Cowlings for you?
A: No.
Q: Did he tell you that he had contacted Louis Marx?
A: No.
Q: And Wayne Hughes?
A: No.
Q: And asked these people to help them care for you?
A: No.
Q: You knew none of that?
A: No, he never said anything like that to me.
Q: Okay. Did you learn at some point that week that he was going to be arrested?
A: Yeah. When he was, when they were looking for him.
Q: Were you at the Kardashian home on Friday morning when your father was to surrender to the police?
A: No.
Q: Did you know that he was to surrender on Friday morning?
A: Yeah. Yeah.
Q: When did you find that out?
A: Friday.
Q: From whom?
A: A news station.
Q: Nobody called you?
A: No. Not me. There was a lot of people in my dad's house, so the phone was ringing off the hook.
Q: You were living at your dad's house that week. Right?
A: Yeah, I was staying there. I mean --
Q: And you learned on Friday morning in your dad's house that he was to surrender that day to the police?
MR. LEONARD: Objection.
BY MR. PETROCELLI:
Q: Is that what you're saying?
A: No. I found out that they went to the house. It was on the news. By the time I found out on the news, they had said that he's supposed to be here and he's not.
Q: So you found out the information from the news on the television.
A: Yeah.
Q: Not from persons in the house or in the family.
A: No. I didn't know. I didn't even know he was going to get arrested until the news said that they were looking for him.
A: Okay. So your dad didn't call you on the morning of the 17th to inform you that a decision had been made --
A: Oh, no.
Q: -- by the LAPD to arrest him.
A: No.
Q: Okay. So when you last saw your dad, let's say Thursday at the funeral, you didn't know whether or not he was going to be arrested the next day. Right?
A: No, I didn't know that.
Q: Did you then see on the news what transpired with your father taking off with Mr. Cowlings in the Bronco?
A: Some of it.
Q: Did you sit there and watch it the whole time?
A: No. I mean, we were in the house. The police came. We had to leave the house.
Q: Where did you go?
A: We started to walk down towards my friend's house, who lives about a block away, and -- so I wasn't watching any TV, but the street was packed full of people and cameras and everything, and we went to my friend Steve's house, his front yard. We were all standing outside of his front yard.
Q: At some point in the day the police had you evacuate the house?
A: Yes.
Q: When was that?
A: That was when I guess they confirmed or A.C. had confirmed that he was bringing my father back to the house.
Q: Did you talk to your father while he was in the car at all?
A: No.
Q: Did it become apparent to you from watching the news accounts that he might kill himself?
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
THE WITNESS: I didn't know.
BY MR. PETROCELLI:
Q: Did you know why he had fled the police?
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: I didn't know why, no.
BY MR. PETROCELLI:
Q: You had no clue as to why he had failed to surrender himself?
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Okay. Did you know that he had a gun in the back seat of the car with him?
A: I found out.
Q: From watching television?
A: Yeah.
Q: Okay. You never spoke to him in that Bronco?
A: No.
Q: No calls between him and you?
A: No.
Q: Okay. You spent the rest of that day until he arrived where? On the front lawn of your friends?
A: No. Only partly. I think we were there for 20 minutes.
Q: Then where did you go?
A: We all went outside because he was getting closer to home.
Q: So you left the house when he was close to home.
A: Yeah, we all went outside 'cause --
Q: I see.
A: We all went outside.
Q: And you were on the outside for 20 minutes or so; then he returned to Rockingham, Is that what you're saying?
A: No. The total amount of time we were at the house might have been about 20 minutes. We might have spent --we spent -- as soon as we got to the house, we were standing outside, my sister, we were all in a circle praying, and then we went inside to find out what was going on, looked at the TV. This is all in the time of maybe 20 minutes. Right?
We were looking at the TV and my sister was still saying some more prayers, and then as he had gotten -- he had gotten off the freeway, and I just -- we kinda thought that maybe he was going to be coming up Bristol, and my friend lives right there at the corner of Bristol and Ashford, so we went outside.
So everybody was outside, out on the corner on the street. Sure enough, they came rolling up the street.
Q: Who is "they"?
A: My dad and Allen.
Q: And they drove in the property?
A: They drove in the property.
Q: And where were you when this was taking place?
A: I was right in front of the car -- on the side of the car.
Q: Did you run to the car?
A: Yeah.
Q: For what reason?
A: Desperation.
Q: To do what? To stop your father from killing himself?
A: To stop --
MR. LEONARD: Objection.
THE WITNESS: To stop him, to talk to him.
BY MR. PETROCELLI:
Q: Did you get to him?
A: I didn't physically really get to him.
Q: Why not?
A: 'Cause the car was separated. The window was rolled up and A.C. was between us.
Q: Okay. Did you -- did the door open?
A: No. A.C.'s big, man. I couldn't get by him.
Q: What did you do?
A: I was so -- I was so full of energy, I tried to reach through A.C.'s window, and A.C. stopped me and pushed me back, and I guess it kinda shocked me and brought me back down to reality. And those cars, the back window's tinted, so I never really even saw my dad.
And I had the police behind me yelling, and then A.C. yelling, and it was -- I just turned around and just said, "Jesus just get back in the house and let these guys handle it,"
Q: So you never did make contact with your father?
A: No.
Q: And you went into the house to -- and he came into the house shortly thereafter?
A: A Little bit a while after, yeah.
Q: Did you talk to him in the house?
A: No. There was like a whole police department in the house.
Q: You never got a chance to talk to him at all?
A: No. I saw him for a quick second from a distance, from a far distance. That was it. That was it. I was like handcuffed in the corner of the house.
Q: You were handcuffed?
A: Yeah.
Q: Why were you handcuffed?
A: Well, this nut-head, me, just ran out after the car and jumped over two police cars, and they didn't want to let me go. I think it was pretty wise on their part.
Q: Before Nicole's murder, what was your father's relationship like with the LAPD?
MR. LEONARD: Objection. Vague. Calls for speculation, lack of foundation.
BY MR. PETROCELLI:
Q: You can answer.
A: The whole police department?
Q: Yeah. To your knowledge it was generally positive and favorable. Correct?
MR. LEONARD: Objection. Same objections.
BY MR. PETROCELLI:
A: Correct?
A: For the police officers he knew, yeah.
Q: You are not aware of any trouble that he had with the police department prior to June 12 of 1994. Correct?
A: I am not aware of any.
Q: In fact, you are seen in some photographs with an LAPD cap. Right?
A: Yeah. I like that cap.
Q: And you got that cap from whom?
A: I don't remember. I'm assuming it was from Ron because Ron Shipp was a police officer, I think, so... I think I got it from him.
Q: So as far as you knew, your father's dealings with the LAPD were favorable and positive. Right?
MR. LEONARD: Objection. Lack of foundation, calls for speculation.
THE WITNESS: As far as I knew.
BY MR. PETROCELLI:
Q: Correct?
A: Correct.
Q: Are you aware of any information to the effect that the police department framed your father for the murder of Nicole?
MR. LEONARD: Objection. Lack of foundation, calls for speculation.
THE WITNESS: Am I aware of it?
BY MR. PETROCELLI:
Q: Yes. Do you have any information to that effect?
A: No.
MR. LEONARD: Same objection.
BY MR. PETROCELLI:
Q: Excuse me?
A: No.
Q: No? Okay. Do you know whether or not your father ever took a lie detector test?
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
THE WITNESS: I heard that.
BY MR. PETROCELLI:
Q: On the news?
A: Yeah.
Q: Recently?
A: I heard it a long time ago, but then I heard it like about three months ago or something like that.
Q: When you heard it a long time ago, from whom did you hear it?
A: It was TV. It was the media.
Q: Did you ever ask your father whether or not he took a lie detector test?
A: No, I didn't.
Q: You heard that he failed the test?
MR. LEONARD: Objection.
THE WITNESS: I think they did say he failed the test, or one person said he failed the test. Another person said he didn't score highly on some -- on some questions.
BY MR. PETROCELLI:
Q: Have you ever asked anyone about that?
A: No I didn't.
Q: At no time?
A: No.
Q: At the wake you came in end then abruptly left and went into the car. Right?
A: Yeah.
Q: And you were hyperventilating?
A: Yeah, I couldn't breathe.
Q And you went into a limousine.
A. Right.
Q: Yeah. There was cameras outside. It was he only way -- place I could get away from them.
Q: Judy Brown and your father then came into the car. Right?
A: I guess. I don't remember who it was. I think -- yeah, I remember my dad was there.
Q: You heard Judy ask your father whether he was responsible for killing Nicole?
MR. LEONARD: Objection.
THE WITNESS: I don't know. I just remember them consoling me. I don't remember them talking to each other.
BY MR. PETROCELLI:
Q: Do you remember Judy asking O.J., "Did you do this to my daughter?"
A: No, I don't.
Q: Do you remember your father saying, "I loved her too much"?
A: I remember hearing my dad say that once, but I couldn't tell you when it was.
When did you hear your dad say, "I loved her too much"?
MR. LEONARD: Objection.
THE WITNESS: I just answered. I just said I couldn't tell you when.
BY MR. PETROCELLI:
Q: But it was sometime after her death. Right?
A: I don't know. I guess.
Q: At the funeral or at the wake?
A: I don't recall. Honestly.
Q: Well, everything is supposed to be honestly.
A: I'm not supposed to be sarcastic.
Q: Do you know that your father on Tuesday, the 14th, went to retrieve his golf bag from the airport?
MR. LEONARD: Objection. Lack of foundation.
THE WITNESS: Not till you just said that.
BY MR. PETROCELLI:
Q: Do you know that when he left the house at Rockingham on the morning of the 14th, he went to his office with Skip Taft and Robert Kardashian? Did you know that?
A: No, I didn't.
Q: What did you do on the morning of the 14th, Tuesday morning?
A: I got no clue. I have no idea. I was in a haze, a haze that whole week. I don't remember. Probably cried all morning, sat on the bed.
Q: Have you ever talked to any members of he Brown family as to the circumstances of Nicole's death?
A: No.
Q Your dad ever tell you that he had dropped blood or deposited blood at Nicole's condo when he was visiting her or the children?
A: No, he never said that.
Q: Did you ever talk to Kato Kaelin about his interaction with your father on the night of June 12?
A: No.
Q: At no time?
A: No. He had told me that he went to McDonald's, but that was it. That's all he said.
Q: Okay. Do you play golf?
A: No. It's too boring.
Q: Do you have golf clubs?
A: No, sir.
Q: Were you familiar with your father's luggage as of June of 1994?
A: No, I wasn't.
Q: Would you have recognized his golf bag or his travel -- his golf bag?
A: I gotta tell you, the whole garage is lined up with golf bags. I don't know which one is his -- his favorite or something. I'm telling you, he's got like 20, 30 golf bags in his garage, so I really couldn't -- I couldn't even answer that.
Q: Prior to Nicole's murder, did you ever see your dad hit golf balls at night at Rockingham?
A: I've never seen that.
Q: Do you have any people who are like your mentors or close advisors?
A: Close advisors? Yeah, a couple. I mean...
Q: Who is that?
A: I call my mom someone I talk to and console, talk to a lot.
Q: Do you have a godparent?
A: A.C.
Q: He's your godparent --
A: He's my godfather, yeah.
Q: Did you attack the restaurant owner with a knife?
MR. LEONARD: Objection.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: Did you have a knife in your hand when you had the fight with Paul?
A: Absolutely not.
Q: Did you not use a knife?
A: Did I use a knife to what?
Q: Did you use a knife?
A: No.
Q: Okay.
MR. LEONARD: Dan, are you going to pursue this with him, I mean, what possible relevance does that have? Seriously. I thought we wanted to get this thing over with.
THE WITNESS: Go ahead. I don't care. Paul will tell you I didn't.
MR. PETROCELLI: Goes to --
MR. LEONARD: Oh, yeah, sure. Don't even say it.
THE WITNESS: Paul would tell you there was no damn knife involved.
MR. PETROCELLI: I guess that's all I have for now.
EXAMINATION BY MS. ROIT:
Q: Mr. Simpson, I just have a couple of questions. I should be done within a few minutes. Okay?
A: Okay.
Q: I want to go back to January 4, 1989, when you indicated you had an opportunity to be with Nicole after the fight with your father. Do you recall testifying to that?
A: January 4, 1989. Okay, yeah.
Q: Do you recall that?
A: Yeah.
Q And do you recall testifying about the fact that you were talking to her and she was about 15 to 20 feet away?
A: Probably, yeah.
Q: All right. Have you ever seen any photographs of the injuries that she sustained as a result of the 1989 incident?
A: No.
Q: At no time during the criminal trial did you see those photographs?
A: I'm not sure which ones. I saw photographs of her, but she looked really, really young. I mean, she looked like the way she did when I first met her. She looked like she was like 20-something.
Q: Are you -- is it your testimony that you -- that she did not have any injuries on her, or is it your testimony that you did not get en opportunity to observe any injuries on her?
A: It's my testimony that I didn't get the opportunity to observe any.
Q: Okay. So she could have had injuries on her face; you just didn't get a chance to see them. Is that correct?
A: Correct.
Q: All right. She could have had injuries on her arms; you just didn't get a chance to see them. Is that correct?
A: Correct.
Q: Now, on that day was she -- what was she wearing, do you recall, in terms of her top?
In other words, was she wearing something sleeveless, or was she wearing something with sleeves?
A: I'd be guessing, and I don't want to give you an answer --
Q: You don't recall.
A: No.
Q: You testified also that you did not discuss with your father really any of the evidence that has come forth in the criminal trial. Correct?
A: Right. Right.
Q: You never asked him and he never told you. Correct?
A: Right.
Q: Other than what you've testified to, did you ever overhear your father make any comments about the evidence that were presented -- that was presented in the criminal trial?
A: Anything at all?
Q: Anything at all.
A: No. Other than the tape and stuff that like -- other than the tape, no.
Q: Well, what did you overhear him say about the tape?
And you are talking about the 911 tape?
A: No. I'm saying what I heard him say on the tape.
Q: Other than what you've already testified to --
A: Yes.
Q: -- and other than what you heard on the tape, at any time did you overhear your father make any remarks about the evidence in the criminal case?
A: No, I've never heard anything he's talked about.
Q: Did you ever hear him make comments like, "Oh, that's all bogus" or "baloney" or "I can't believe they're trying to pin it on me"?
MR. LEONARD: I am going to object to that. Lack of foundation.
BY MS. ROIT:
Q: Anything to that effect?
A: Maybe a sigh, but not -- you know, like if the news was on and something came on real quick and (Sound). That's about it.
Q: Well, are you indicating that there was -- that you had occasion to watch the news with your father where they were discussing the criminal the evidence in the criminal case?
MR. LEONARD: I am just going to object now because it's vague as to time. Are you asking him at any time or during the week? I mean, what are you talking about? Any time?
MS. ROIT: Asking any time.
MR.LEONARD: Up until today's date?
MS. ROIT: Up until today's date.
THE WITNESS: Maybe.
BY MS. ROIT:
Q: Well, as you sit here today --
A: Yes.
Q: -- and, you know, how we talk about memories, we can take ourselves back --
A: Right.
Q: -- and visualize?
A: Right.
Q: As you sit here today, can you visualize yourself watching the news --
A: Right.
Q: -- with your father --
A: Right.
Q: -- where any of the pieces of evidence were discussed?
A: Never sit and watch the news. The TV being on and everybody doing something in, say, the room and me walking through the room and him reacting to something being said about him on the news.
Q: Okay. On how many occasions has that occurred?
A: Jeez, in the last five months, six months, I don't know. Maybe five times, a handful of times.
Q: What evidence do you recall being discussed on TV to which your father reacted?
A: I don't think it was so much the evidence. That maybe like the end of the day, what you hear like, say, about what we just did today, something like that. You guys outside talking.
Q: So there would be occasions when on TV they would be broadcasting something that occurred in this, the civil case?
A: Yeah, but I'm not paying -- like I said, if the TV was on, I wasn't sitting there watching the TV. I'd just see that they're talking about the case and I'm seeing his reaction. I'm not seeing what his reaction is to specifically.
Q: All right. And what do you recall about his reaction to news stories about the civil case?
A: Disagreement. That's all I know.
Q: Such as?
A: I don't know. Like I said, I don't know what he's disagreeing with.
Q: Okay. Well, how did you determine from his reaction that he was disagreeing with whatever it was that was being broadcasted on the news about the civil case?
A: 'Cause he had a look of distaste. Sometimes it might just be -- I mean, don't take it personally (Indicating), because he's talking on TV.
Q: You are pointing to Mr. Petrocelli.
A: Yes.
Q: And your father's reacting with distaste.
A: Yeah. He's just -- yeah.
Q: Well, is he grunting? Is he making any noises when he's reacting to this?
A: Yeah, I guess.
Q: Is he making any comment when he's reacting to it?
MR. LEONARD: You know, I am going to -- this is now vague. You are saying, "Is he." I mean, if you -- you know, it's compound and vague.
But you can try to answer if you can.
MS. ROIT: Well, the witness has testified that he has seen his father react in a certain fashion to broadcasts about the civil case and the evidence in the civil case.
Q: Correct?
A: Yes.
Q: Okay. I am trying to understand what that reaction was.
MR. LEONARD: Well, just in general or...
THE WITNESS: Let's see. One time he was happy -- I'm gonna guess, though. I'm not going to sit there and spread out guesses to you.
BY MS. ROIT:
Q: You can take yourself back to those occasions, and you can actually see your father reacting. Right?
A: Right.
Q: Okay. I want to know if during any of those occasions he said anything out loud when he was so reacting.
A: Not that I recall.
Q: So on those approximate five or six occasions when the news was broadcasting something about evidence in the civil case, all you recall is your father reacting without saying anything. Is that correct?
MR. LEONARD: I am going to object. I think that mischaracterizes his testimony. I don't think he said on all occasions they were describing evidence in the civil case.
But go ahead. If you can answer it, go ahead.
THE WITNESS: I also said that he would be reacting, but I don't recall what it was he said. You're saying I don't remember. You're saying I'm not saying what it was he said. No, I don't remember what it was he said. I wasn't paying attention.
BY MS. ROIT:
Q: Other than what you've testified to now, have you ever heard your father make any comments about the evidence either in the criminal case or the civil case? And by "evidence," I am including testimony of any of the witnesses.
MR. LEONARD: I am going to object as that's very -- that's overbroad vague, lacks foundation.
You can answer the question.
MS. ROIT: I am trying to lay a foundation for any further questioning.
THE WITNESS: Have I ever heard him speak about either trial's evidence?
BY MS. ROIT:
Q: Yeah.
A: None of the evidence, no.
Q: Any testimony of any of the witnesses in the civil case, such as, "That person's lying" or "That person's telling the truth," or anything to that effect?
A: Yeah. Yeah, I guess.
Q: Okay. What comments have you heard him say?
A: Maybe something about Faye.
Q: What did he say about Faye?
A: I don't remember. I just know that he disagreed with something she -- something about her, I don't think it had to do with the actual case. It had to do with her book or something
and what she's doing in her book.
Q: I am focusing on the testimony of the witnesses in the case.
A: Well, I don't know. Have you questioned her? I don't know if he was talking about her and what she did her day in court or --
Q: Mr. Simpson, I am simply asking you what you heard your father say.
A: I don't remember. I just know he was talking about it.
Q: So as you sit here today, you cannot give me any specifics about what your father may have said with respect to the testimony of any of the witnesses in this case. Is that correct?
A: Yeah, basically.
Q: All right. He has said things. You just can't recall them. Is that correct?
A: Basically, yeah.
Q: You testified earlier that at some point you had at least a suspicion that your father could have committed these murders. Is that correct?
MR. LEONARD: I am going on object. I think that mischaracterizes his testimony.
But go ahead. You can answer.
THE WITNESS: I said at one point I was a -- you know, the thought crossed my mind, yeah.
BY MS. ROIT:
Q: And on what was that thought based?
A: I'd have to say just the evidence, what the evidence -- but it didn't seem -- I mean, he didn't have any motive, to me. In my mind he didn't have any motive. All these people in this room seem to know. I mean, I lived with Nicole and my dad for 17 years.
Q: What evidence were you aware of at the time that you formed that suspicion in your mind?
MR.LEONARD: Objection. Overbroad.
THE WITNESS: The evidence in the case that he was just acquitted from.
BY MS. ROIT:
Q: Okay. So the suspicion that you formed in your mind was during the criminal trial. Correct?
A: It was a while ago, yeah.
Q: Was it during the criminal trial?
A: Yes.
Q: Was there something in particular that occurred during the criminal trial that formed or assisted in forming that suspicion in your mind?
MR. LEONARD: You know, I am going to object to this line of questioning. It has absolutely no relevance, it can't lead to any relevant evidence, and I am going to instruct him not to answer at this point. He has gone over this several times.
So don't answer the question.
BY MS. ROIT:
Q: Did you ever share your suspicion with your father?
A: No.
Q: Why not?
A: He wasn't there at the moment.
Q: Did you visit your father in jail?
A: Yes.
Q: On how many times?
A: I don't remember exactly.
Q: Many times?
A: What's "many" to you?
Q: More than 10?
A: Yeah, I think.
Q: Any time during those visits did you discuss the criminal case with your father?
A: No, I tried not to. It's all he talked about, so when I got there, I tried to talk about anything else.
Q: I want to make sure I understand your answer.
A: No.
Q: During any of the visits to jail when you went to visit your father, did you ever discuss the criminal case or any of the evidence in the criminal case?
MR. LEONARD: Objection. Overbroad, vague, compound.
BY MS. ROIT:
Q: At any time during any of the visits with your father in jail.
A: Maybe.
Q: Maybe?
A: Maybe.
Q: Okay. As you sit here today, do you recall such discussions?
A: I recall -- yeah.
Q: What did you discuss with him?
A: The actual situation.
Q: What was said?
A: Reaction to what -- reaction to the situation. Reaction to the fact that "there's a piece of glass dividing you and me right now and that you're handcuffed," but not about the actual case, the actual situation.
Q: Situation with him being jail.
A: Yes.
Q: Okay. Not about the evidence in the case.
A: No, not about the evidence.
Q: Not about whether or not he killed Nicole and Ron.
A: No.
Q: Have you ever seen Bruno Magli shoes in your father's closet?
A: I don't remember ever seeing any in his closet.
Q: Did you ever see him wear Bruno Magli shoes?
A: I don't remember ever seeing him wear Bruno Magli shoes.
MS. ROIT: Okay, I have no further questions.
EXAMINATION BY MR. PETROCELLI:
Q: Prior to June of '94, you wouldn't have been able to tell if he was wearing Bruno Magli shoes. Correct? Correct?
A: Correct.
Q: And you wouldn't have been able to tell by merely taking a look in his closet whether any of them were Bruno Maglis. Correct?
A: Incorrect.
Q: Why is that incorrect?
A: Because, I mean, I'd have to agree with my dad. By looking -- I mean, when I saw him and saw the picture in the Enquirer, I was surprised to see him wearing the shoes because I don't necessarily think they're very nice-looking shoes either, to be perfectly honest, and I was kinda surprised to see the picture.
Q: You did not look in his closet in the last three or four months before Nicole's death to inventory his shoes. Right?
A: Not to inventory, but believe me, I don't mind, you know, snagging a T-shirt from my dad.
Q: But you didn't survey his shoes --
A: Sometimes.
Q: -- prior to Nicole's death. Correct?
A: Sometimes I do, yeah.
Q: When was the last time up went into his closet to look at his shoes --
A: I don't remember.
Q: -- prior to Nicole's death?
A: I don't remember exactly.
Q: So you don't know as of Nicole's death what shoes he had and what shoes he did not have. Correct?
A: No. Correct.
Q: Do you know if your father's writing a book now?
A: No, I don't know.
Q: Are you?
A: No.
Q: Do you know if he has any plans to write a book now?
A: No, I don't.
Q: Do you know whether Nicole had a relationship with Marcus Allen?
A: I do now.
Q: And how do you know that?
A: I found out like everybody else did -- like almost everybody else did.
Q: How?
A: Media.
Q: Did you ever talk to your father about Nicole's relationship with Marcus Allen?
A: No. Never.
Q: Did you ever talk to Marcus Allen about it?
A: No.
Q: Did you ever talk to Al Cowlings about it?
A: Yeah.
Q: Tell me about that conversation.
A: I asked him if it was true.
Q: If what was true?
A: If the -- if what I was hearing was true.
Q: What is it that you asked Mr. Cowlings?
A: Did Nicole and Marcus have an affair.
Q: What did Al say?
A: He said he thinks so.
Q: Did you ask him anything else?
A: About the affair?
Q: Yes.
A: No.
Q: Did you ask him when it occurred?
A: No. I had a feeling when it occurred.
Q: When did it occur?
MR. LEONARD: Objection. That calls for speculation.
BY MR. PETROCELLI:
Q: When did it occur?
A: I didn't know exactly the time frame, but I just -- there was a time -- I don't remember when it was, but there was a time I had been there and I had seen something that I thought was going on, but I dismissed it, later to find out that what I thought was true.
Q: And what is it that you saw?
A: Saw Marcus coming out of Nicole's house.
Q: Okay. And what house was that?
A: Gretna Green.
Q: And when was that?
A: I don't remember.
Q: Did you see where Marcus went when he left the house?
A: No.
Q: Did you tell your father about that?
A: No. I didn't think too much of it. They were friends.
Q: Is that the only thing that you ever saw that, looking back now, confirms this affair in your mind?
A: Yeah.
Q: You sure it was Gretna Green and not Bundy?
A: I'm positive.
Q: And why are you positive about that?
A: Just I'm positive. I knew where I was.
Q: Okay. Did you ever see Marcus' car parked outside of Nicole's Bundy condo?
A: No.
Q: Or parked outside of the Gretna Green condo?
A: Just that one time when I saw him.
Q: You saw him go to his car?
A: Yeah. He was coming outside. I was going in.
Q: Do you know whether Al Cowlings drove your father's white Bronco?
MR. LEONARD: Objection --
THE WITNESS: Ever?
BY MR. PETROCELLI:
Q: Within a month before Nicole's death.
MR. LEONARD: Objection. Calls for speculation, lack of foundation.
THE WITNESS: I don't know.
BY MR. PETROCELLI:
Q: Did you ever ask Mr. Cowlings whether he was involved with the murder of Nicole?
A: No.
Q: Whether he helped your father?
A: No.
Q: You ever ask him any questions about his whereabouts and activities --
A: No.
Q: -- on the night of June 12?
A: No, I don't think I asked him.
Q: Never discussed it with him?
A: No.
Q: He ever talk to you about it?
A: I don't think so. I don't think he told me what he was doing that night.
Q: Excuse me?
A: I don't think he told me what he was doing that evening.
Q: You said you would know better than all of us about whether your father had a motive to kill Nicole.
MR. LEONARD: No, I object. That mischaracterizes what he said. That's not what he said.
BY MR. PETROCELLI:
Q: You said you lived with her for 17 years.
A: I said I lived with them for 17 years, and in my opinion there's no way either of them could have killed each other.
Q: Well, you didn't live with them after 1988.
A: Neither did you.
Q: True?
A: So what's the question?
Q: It wasn't 17 years, in other words --
A: Oh, okay.
Q: -- that you lived with them.
THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 4:42.
(Pause in the proceedings.)
THE VIDEOGRAPHER: We are back on the record and the time is approximately 4:43.
BY MR. PETROCELLI:
Q: Your father was -- is a jealous man, is he not?
MR. LEONARD: Objection. Lack of foundation, calls for speculation. It's vague.
BY MR. PETROCELLI:
Q: You can answer.
A: I don't think he's any more jealous than the next guy.
Q: He is a jealous guy -- he was a jealous guy when it came to Nicole. Is that a fair statement?
MR. LEONARD: Objection. Lack of foundation, calls for speculation, argumentative.
THE WITNESS: Like I said, I don't think he' more jealous than the next guy.
BY MR. PETROCELLI:
Q: Yeah, but I'm not asking you that.
A: Well, I've never seen him do anything that --
Q: Did you regard him as a jealous man when it came towards Nicole?
MR. LEONARD: Objection --
THE WITNESS: No, I wouldn't regard him as a jealous man.
BY MR. PETROCELLI:
Q: A controlling guy --
MR. LEONARD: Objection. Vague.
BY MR. PETROCELLI:
Q: -- when it came to Nicole?
A: Maybe a little controlling.
Q: He's a controlling person in general. Is that a fair statement.'
A: Not in general.
Q: Towards Nicole he was. Right?
MR. LEONARD: Objection. Vague as to "controlling."
BY MR. PETROCELLI:
Q: You can answer.
A: Toward Nicole, no, I wouldn't -- toward a couple things. I mean...
Q: Like what?
A: Conversations. Talk to him, he likes to -- you know, he likes to head the conversation usually.
Q: What else?
A: What else. Let's see. He's an opinionated guy. And that's all I could think about right now. And, yeah, with Nicole sometimes.
Q: How did Nicole treat your father when she was alive?
MR. LEONARD: Objection. Vague.
THE WITNESS: She treated him well.
BY MR. PETROCELLI:
Q: Your father wrote in his so-called suicide note that he was a battered spouse or he was the battered one in the relationship, words to that effect. Do you recall that?
A: I recall it, yes.
Q: Did you see any evidence of that?
MR. LEONARD: Objection. Lack of foundation, calls for speculation.
THE WITNESS: Battered, no. I wouldn't call it battered.
BY MR. PETROCELLI:
Q: Do you know what he meant by that?
A: Yeah, I do.
Q: What did he mean?
A: I think he felt that -- in my opinion, I think he felt that he also sustained some abuse, but whether it be mental or even physical, but it doesn't matter. I mean, he's bigger than her, so it -- like I -- it doesn't matter.
You know, I mean, Nicole is a smaller white woman. He is a bigger black man. You will never, ever, no matter what, no matter in what court, in what country, in what land, if these two people fight, there's no way that he will ever, you know, be looked at with any kind of sympathy. I think that's what he might have thought when he wrote that.
Q: How was he abused by Nicole?
A: Abused? I don't know. You'd have to ask him that.
Q: You said you think that what he was referring to is that he had sustained some abuse.
A: Nicole, I mean -- Nicole -- Nicole, I mean, she was a great person and everything like that, she wasn't just a flower. I mean, you can get into arguments with Nicole. I mean, Nicole was a pretty hard-headed person herself.
Q: Did you see her abuse your father?
MR. LEONARD: Objection. Vague.
THE WITNESS: No, I never saw her abuse my dad.
MR. PETROCELLI: No further questions.
We will have a stipulation that the original of the transcript will be sent to Mr. Baker's firm?
MR. LEONARD: (Nods head.)
MR. PETROCELLI: And that you will have 30 days thereafter within which to inform us of any changes or corrections and whether the witness has signed it, and if it's not signed within 30 days after receipt by Baker's firm, then the transcript can be used for all purposes -- a copy of the transcript can be used for all purposes as though signed.
MR. LEONARD: Agreed.
MR. PETROCELLI: Thank you.
THE WITNESS: Thanks.
THE VIDEOGRAPHER: This concludes the deposition of Jason Simpson. The number of videotapes used was three. We are going off the record, and the time is approximately 4:48.
(ENDING TIME: 4:48 P.M.)
I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.
SUBSCRIBED AT
CALIFORNIA, THIS _ DAY OF 19 ___.
JASON LAMAR SIMPSON