SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
SHARON RUFO,
Plaintiff,
vs.
ORENTHAL JAMES SIMPSON et al.,
Defendants
FREDRIC GOLDMAN,
Plaintiffs,
vs.
ORENTHAL JAMES SIMPSON, et al.,
Defendants
LOUIS H. BROWN, etc.,
Plaintiffs,
vs.
ORENTHAL JAMES SIMPSON,
Defendant.
Videotaped deposition of ORENTHAL JAMES SIMPSON, taken on behalf of the Plaintiffs, at 11377 West Olympic Boulevard, 10th Floor, Los Angeles, California, commencing at 9:40 a.m., on Monday, January 22, 1996, before David S. Coleman, CSR #4613, pursuant to Court Order.
APPEARANCES:
FOR THE PLAINTIFFS FREDRIC GOLDMAN, ET AL:
MITCHELL, SILBERBERG & KNUPP
BY: DANIEL M. PETROCELLI, ESQ
PETER B. GELBLUM, ESQ.
EDWARD M. MEDVENE, ESQ.
ARTHUR GROMAN, 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 10017-5090
(212) 682-1700
FOR THE PLAINTIFF SHARON RUFO
HORNBERGER & CRISWELL
BY: MICHAEL A. BREWER, ESQ.
444 South Flower Street
Third-First Floor
Los Angeles, California 90071
APPEARANCES (Continued):
FOR THE DEFENDANT ORENTHAL JAMES SIMPSON:
BAKER, SILBERBERG & KEENER
BY: ROBERT C. BAKER, ESQ.
2850 Ocean Park Boulevard
Suite 300
Santa Monica, California 90405-2936
-and-
BAILEY, FISHMAN & LEONARD
BY: DANIEL LEONARD, ESQ.
66 Long Wharf
Boston, Massachusetts 02110
(61 7) 723-1380
-and-
ROBERT D. BLASIER, ESQ.
6355 Riverside Boulevard
Suite 2-F
Sacramento, California 95831
(916) 427-1600
THE VIDEOGRAPHER: ROD RIGOLE
ALSO PRESENT: FREDRIC GOLDMAN
THE VIDEOGRAPHER: Good morning. Here begins videotape number 1 in the deposition of Orenthal James Simpson, Volume 1, in the consolidated cases of Fredric Goldman, Sharon Rufo and Louis Brown v. Orenthal James Simpson in the Superior Court, State of California, County of Los Angeles, the lead case number of which is SC031947.
Today's date is Monday, January 22nd, 1996. The time is approximately 9:40. This deposition is being taken at 11377 West Olympic Boulevard in Los Angeles, California, and was made at the request of plaintiff, of the Law Offices of Mitchell, Silberberg & Knupp.
The videographer is Rod Rigole, employed by Coleman, Haas, Martin & Schwab of Los Angeles, California.
Would counsel please identify yourselves and state whom you represent
MR. PETROCELLI: Daniel Petrocelli of Mitchell, Silberberg & Knupp for plaintiff Frederick Goldman.
MR. BAKER: Bob Baker for O.J. Simpson.
MR. LEONARD: Daniel Patrick Leonard, O.J. Simpson.
MR. BLASIER: Robert Blasier, O.J. Simpson.
MR. KELLY: John Kelly for the Estate of Nicole Brown Simpson.
MR. BREWER: Michael Brewer, Sharon Rufo.
MR. GROMAN: Arthur Groman, Goldman.
MR. MEDVENE: Edward Medvene, Goldman.
MR. GELBLUM: Peter Gelblum for Goldman.
MR. PETROCELLI: Also present is plaintiff Frederick Goldman.
ORENTHAL JAMES SIMPSON, having been first duly sworn, was examined and testified as follows:
EXAMINATION BY MR. PETROCELLI:
Q: Good morning, Mr. Simpson.
A: Good morning.
Q: My name is Daniel Petrocelli. I represent plaintiff Frederick Goldman in this lawsuit against you. Do you understand that you are under oath?
A: Yes.
Q: You may have to speak up so that the folks down at the end of the table can hear you. Have you ever testified under oath before?
A: Yes.
Q: You understand that even though you're in our law office today, that the testimony that you give under oath here is subject to the same penalty of perjury as though you were testifying in a court of law?
A: Yes.
Q: How many times have you testified under oath before?
A: I'm not sure, but I'd say three or four times.
Q: Have you ever given a deposition before?
A: Yes.
Q: How many times?
A: I believe twice.
Q: All before the death of Nicole and the death of Ron Goldman?
Q: During those two times that you gave depositions, you understood you were under oath?
A: Yes.
Q: And did you tell the truth in those depositions?
A: Yes.
Q: Did you say anything untrue?
A: I don't believe so, no.
Q: You told the truth. Right?
A: The best I knew it.
MR. BAKER: That's enough. That's enough.
BY MR. PETROCELLI: Q: And have you ever testified at a trial?
A: Yes.
Q: When?
A: Late '60s, early '70s.
Q: What kind of case was it?
A: One I believe was a criminal case, and one was a lawsuit.
Q: Did they involve you?
A: No.
Q: You were just a witness?
A: Yes.
Q: And you told the truth in those criminal cases?
A: The best I knew it.
Q: Tell me who the parties were.
MR. BAKER: I am going to object. Instruct him not to answer. It's irrelevant and immaterial.
MR. PETROCELLI: What I would like to do is get a copy of the transcript of his testimony.
MR. BAKER: It's irrelevant, immaterial. Instruct him not to answer.
BY MR. PETROCELLI: Q: Now, is this the first time you're testifying under oath since the death of Nicole and the death of Ron Goldman?
A: Yes.
Q: So you've never been questioned under oath about the events surrounding Ron and Nicole's death. Is that right?
MR. BAKER: That's been asked and answered. Instruct him not to answer the question.
BY MR. PETROCELLI: Q: When you gave an interview on Ross Becker recently, you were not under oath. Correct?
A: Correct.
Q: Did you tell the truth?
A: Best that I knew it, yes.
Q: Would you have said anything differently if you were under oath?
MR. BAKER: It's argumentative. Don't answer that question.
MR. PETROCELLI: Are you instructing him?
MR. BAKER: Yes.
MR. PETROCELLI: Can we have a stipulation that if you instruct him not to answer, that he will abide by your instructions?
MR. BAKER: Yes.
MR. PETROCELLI: Thank you. Q: Did you-- you spoke in other elements of that video besides the Becker interview. Correct?
A: Correct.
Q: And did you tell the truth during the other times that you spoke on the video?
A: Best that I knew it, yes.
Q: And would you have said anything differently if you were under oath?
A: I don't think so, no.
Q: Now, you recall giving a statement to the Los Angeles Police Department on June 13?
A: Yes.
Q: Were you under oath?
A: I don't believe so.
Q: Did you tell the truth?
A: Best as I could remember it--
Q: Would you have said--
A:--at the time, yes.
Q: --the same thing--
MR. BAKER: Just a minute.
MR. PETROCELLI: I'm sorry.
MR. BAKER: Let him finish his answer.
MR. PETROCELLI: I apologize, Mr. Baker.
MR. BAKER: Go ahead and finish your answer.
THE WITNESS: As best as I could at that time, yes.
BY MR. PETROCELLI: Q: Would you have said anything differently at the time if you were under oath?
A: At the time, no.
Q: I would like to talk a little bit about preparing for the giving of testimony. You recently participated in this making of a video that is going to be released soon. Correct?
A: Yes.
Q: And you talked in that video about the events and circumstances of Ron and Nicole's deaths. Correct?
A: I answered the questions that were asked me.
Q: Okay. But the subject matter of that video was your side of the story with respect to the deaths of Ron and Nicole. Right?
MR. BAKER: I am going to object. That's a characterization that you're making.
BY MR. PETROCELLI: Q: You may answer.
A: I answered the questions that were asked me, basically, yes.
Q: But it was about the deaths of Ron and Nicole, generally speaking. Right?
A: Yes.
Q: Is that the only time--And there were video tape machines and tape recorders recording what you were saying. Right? A: Yes.
Q: Now, is that the only time that you have been recorded discussing the facts and circumstances surrounding Ron and Nicole's deaths?
MR. BAKER: Don't answer that question unless you exclude anything that was done vis--vis your attorneys. Any questions that he puts to you, I don't want you to answer and include anything that was done with your attorneys.
MR. PETROCELLI: I would like to know if he is excluding anything.
MR. BAKER: He is going to exclude everything that was done with and through and by his attorneys.
MR. PETROCELLI: But all I am saying, Mr. Baker, so that we know whether or not there is a relevant contact with an attorney where we might want to attack the assertion of the attorney-client privilege, we have to know the basic foundational facts. That's all I'm saying.
MR. BAKER: I understand what you're saying, and I'm not assenting to that, and we are not going to allow you to inquire as to what he did with his attorneys, whether he was taped, videotaped or anything else.
MR. PETROCELLI: Well, I am going to inquire into that, and I haven't asked so far about any communications. I have simply asked for the mere existence of such recordings, if they do exist.
MR. BAKER: And I am going to instruct him not to answer that, and you can certify it, and we can argue that point with the court.
MR. PETROCELLI: Okay.
Q: Let me get back to my question: Other than this recent video, have you ever been recorded on videotape or audiotape discussing facts and circumstances and events surrounding the deaths of Ron and Nicole?
MR. BAKER: And I want you to answer that, other than anything you did with your attorneys.
THE WITNESS: Other than anything that I did with my attorney, not that I knew of.
BY MR. PETROCELLI: Q: And what about with respect to things you did with your attorneys?
MR. BAKER: Could you be more vague?
MR. PETROCELLI: No.
MR. BAKER: I don't know what the question is.
BY MR. PETROCELLI:
Q: The question is: Have you ever participated in any events or any tapings in which you discussed the events and circumstances surrounding Ron and Nicole's deaths in the presence of your attorneys?
MR. BAKER: I instruct him not to answer that question.
BY MR. PETROCELLI: Q: What attorneys were present during such tapings?
MR. BAKER: And I instruct him not to answer that question.
BY MR. PETROCELLI: Q: Did you prepare for the possibility of testifying at your criminal trial?
A: When you say--I don't understand when you say "prepare."
Q: Did you -- Were you tape-recorded or videotaped?
MR. BAKER: Same objection. If it has --if you were there with your attorneys and it was pursuant to the instruction of your attorneys, I don't want you to answer that question.
BY MR. PETROCELLI: Q: Did a lawyer named Christina Arguendas subject you to a practice or mock cross-examination?
MR. BAKER: Don't answer that question. I'll instruct him not to answer.
MR. PETROCELLI: What are the grounds of these objections?
MR. BAKER: I think it's pretty evident.
MR. PETROCELLI: It's not to me. I just would like the record to be clear.
MR. BAKER: It's attorney-client privilege and attorney work product privilege.
MR. PETROCELLI: Okay.
Q: Is Christina Arguendas an attorney that has ever worked for you in the past two years?
A: I don't know.
Q: You --
A: The name really doesn't mean anything to me.
Q: Doesn't mean anything to you?
A: No
Q: Did such a person--do you know whether such a person subjected you to a practice or mock cross-examination?
MR. BAKER: I will instruct you not to answer again. That's based on attorney work product and attorney-client privilege.
BY MR. PETROCELLI: Q: Have you ever been cross-examined about the facts and circumstances of the death of Ron and Nicole by a person who you did not know?
MR. BAKER: If you did not know and you did not know they were an attorney, you can answer that question.
THE WITNESS: I'm sorry. I'm a little lost here.
BY MR. PETROCELLI: Q: In other words, I am trying to find out if anybody ever subjected you to a cross-examination when the person was not acting as your attorney, other than this video that just happened. Can you answer that yes or no, please?
MR. BAKER: That assumes that an attorney that was hired through another attorney of his is not-- may or may not be his attorney, and I am not going to allow him to answer that question.
MR. PETROCELLI: Same grounds: Attorney-client and work product objections?
MR. BAKER: Yes.
BY MR. PETROCELLI: Q: You took notes during the criminal trial?
A: Yeah, at times.
Q: Where are those notes?
A: I don't know.
Q: What did you do with them?
A: I have absolutely no idea.
Q: Who did you give them to?
A: I don't know when I packed up--I don't know.
Q: You don't know what you did with them?
A: No.
Q: At the end of each day did you have a routine where you gave your notes to somebody or saved them in some way?
A: No.
Q: Did you take them back with you to the jail cell?
A: Yes.
Q: And when you left, when you were released, did you take the notes with you?
A: I believe some of them, I must have.
Q: Did you give them to anyone? Such as your attorneys?
A: No.
Q: Or anyone else?
A: No.
Q: Your assistant?
A: No.
Q: So right now as you testify today, you don't know where those notes are?
A: No.
Q: Do you know if they exist?
A: I hope so.
Q: Why do you hope so?
A: I just hope so.
Q: Did you give them to someone for safekeeping?
A: No.
Q: Do you know if they are in your house?
A: No, I don't know.
Q: Did you meet with anyone to prepare for this deposition?
MR. BAKER: Other than your attorneys.
THE WITNESS: No.
BY MR. PETROCELLI: Q: Other than your attorneys.
A: No.
Q: Did you meet with your attorneys?
MR. BAKER: Don't answer that.
BY MR. PETROCELLI: Q: Who are the attorney that you met with to prepare for this deposition?
MR. BAKER: Don't answer that either.
MR. PETROCELLI: Are these instructions not to answer?
MR. BAKER: Yes.
MR. PETROCELLI: And based on what grounds?
MR. BAKER: On attorney-client and attorney work product privilege.
MR. PETROCELLI: Okay.
Q: Were there any persons who were not lawyers, other than yourself, of course, present during sessions in preparation for this deposition?
MR. BAKER: Assuming there were sessions in preparation for this deposition.
MR. PETROCELLI: Correct.
THE WITNESS: No.
BY MR. PETROCELLI:
Q: All persons present other than yourself were lawyers?
A: Assuming that-
Q: Such preparation sessions occurred.
A: Yes. Yes.
Q: Is that correct?
A: That's correct.
Q: Okay. Do you have a copy of any of the videotaped materials that were used to make this soon-to-be-released video?
A: No.
Q: You have nothing?
A: Nothing.
Q: Do you have the final product?
A: No.
Q: Have you seen it?
A: No.
Q: Do you have any of the script materials?
MR. BAKER: Well, that assumes there are script materials.
BY MR. PETROCELLI: Q: Were there scripts prepared by writers to prepare for the making of this video?
A: Given to me?
Q: That you saw, not necessarily given to you.
A: Saw, yes.
Q: Do you have copies of those scripts?
A: They weren't for me. No, I don't.
Q: You don't have anything?
A: No.
Q: What is the name of this soon-to be- released video?
A: "O.J. Tells," I believe.
Q: "O.J. Tells"?
A: Yes.
Q: Okay. So you have-
A: That's the phone number also.
Q: Excuse me?
A: That's the phone number: 1-800-OJTELLS.
Q: I see. So you--right now you have nothing in your possession with respect to this video "O.J. Tells." Is that right?
A: That's correct.
Q: Do your lawyers?
A: I don't know.
Q: Do any of your representatives have any of these materials relating to the video in their possession?
MR. BAKER: I don't know what you mean by "representatives." I will take the suspense out of it that the lawyers do not have a copy of any of the tapes.
MR. PETROCELLI: Okay.
Q: Mr. Blasier was present during the production of this video. Correct?
A: Correct.
Q: And Mr. Blasier prepared a list of topics or points to be covered in the course of making this video. Correct?
A: I would say that's not correct, no.
Q: Can you explain to me?
MR. BAKER: Explain to you what? He just-- Don't explain. Just answer his questions.
BY MR. PETROCELLI: Q: Did Mr. Blasier or anyone else hand out a list of points to be covered in the video?
MR. BAKER: Well, to the extent that Blasier talked to him about any points, I still believe and instruct him not to answer that that's going to be based on the attorney-client privilege. Mr. Blasier is an attorney, and he is of counsel in this matter. So I instruct him not to answer that question.
BY MR. PETROCELLI: Q: When Mr. Blasier was participating in the making of this video, did you understand that he was doing so in his role as attorney of record in this case?
A: Yes.
Q: And you asked him to do that for that reason?
A: Yes.
Q: And he had discussions with you from time to time?
A: Discussions, yes.
Q: And as part of those discussions, did other members of the production crew participate?
A: Some subjects, yes.
Q: What kind of subjects?
A: Locating blood drops, where the tags should go, and where various evidence, I guess, items were found.
Q: What was the name of the director?
A: I believe Larry Schiller.
Q: And the name of the producer?
A: Tony Hoffman.
Q: The name of the writer or writers?
A: I don't recall.
Q: And there were meetings and discussions involving the producer, the director and the writers from time to time. Correct?
A: I would assume so.
Q: And you attended some of those. Correct?
A: Yes.
Q: And Mr. Blasier attended and participated in some of those. Correct?
A: Yes.
Q: And at some point didn't somebody prepare a list of topics and points to be covered in this video?
A: As far as camera shots and where various evidence items were located, yes.
Q: Wasn't there another list of topics: Substantive points to be covered?
A: Now you're talking about what Bob and I discussed, and I understand that's attorney privileged.
Q: You and he had such a discussion, but nobody else participated. Is that your testimony?
A: Yes.
Q: Wasn't the idea--You did not know what Becker was going to ask you. Correct?
A: Correct.
Q: And wasn't the idea that after Becker asked you and you answered all of the questions, if there were other points that you wanted to cover, they would be covered later on in the video. Correct?
A: Correct.
Q: So isn't it--wasn't there a list of the topics that everybody would check off that Becker covered, and the ones he didn't cover, you would then bring up after the Becker interview?
A: To an extent, yes. To an extent.
Q: Who prepared that list of topics?
A: Generally, the public.
Q: The public.
A: Yes.
Q: How did the public prepare that list?
A: I believe they went out with cameras and asked the man on the street what you would want to ask O.J., and we looked at that and took the most probative questions from that.
Q: The producer and his crew did that?
A: Yes.
Q: Did you participate in deciding which ones you wanted to cover and --
A: Not at all.
Q: Who did that?
A: I guess they did.
Q: So you had nothing to do at what point--you had no say in what points would be covered and not covered on your video. Is that--
A: Not with them. Not with them, no.
Q: With who?
A: With my lawyer.
Q: Your lawyer, meaning Mr. Blasier?
A: Yes.
Q: Anyway, where are these lists of topics?
A: I have no idea.
Q: Where are the input that the public gave? The documents or the tapes, whatever the public gave, where is that?
A: I have no idea.
Q: You have none of that?
A: No.
Q: Okay. Do you know a man by the name of Keith Smith?
A: No. I don't remember--
Q: Excuse me?
A: I wouldn't remember him. If I did know him, I don't know his name. Like I don't know these guys' names.
Q: Which guys?
A: These guys.
Q: My partners?
A: Yeah.
Q: Okay. When is the video coming out?
A: I don't know.
Q: Did you participate in editing any part of the video?
A: I gave suggestions to portions that were not the interview.
Q: The interview we're referring to is the Ross Becker interview. Right?
A: Yes.
Q: That's one element of the video. Right?
A: Yes.
Q: There are essentially three components to the video?
A: I believe so, yes.
Q: What are the other two?
A: One is walking around looking at various, you know, stuff that came up, you know, in the trial about where blood and gloves and things were found, and one was just me talking to the camera.
Q: The one walking around looking at the various places where evidence was located, that was you also talking to the camera?
A: Yes.
Q: And you said you participated in editing the two elements not involving Becker. Is that right?
A: Not really. I just--I looked at it and--I just looked at it.
Q: Did you at any time during the making of this video indicate that you did not want any particular footage to be included in the final cut?
A: No.
Q: Do you have any outtakes?
A: No.
Q: Do you know if there are any outtakes?
A: I don't know. I haven't seen the final product.
Q: Who has all this material? Is it Mr. Hoffman?
A: I don't know. Maybe the production company.
Q: What is the name of the company?
A: I really don't know.
Q: Was there any other lawyer involved in assisting you with this video besides Mr. Blasier?
A: Not representing me, no.
Q: Was any part of what you said in the two elements of the video not involving Mr. Becker written out in advance?
A: Pardon me?
Q: Focusing on the two elements of the video not involving Becker, where you talked to the people and talked to the camera and walked around and so forth, was that material written out for you?
A: No.
Q: Did you write it out?
A: Write it out?
Q: Yeah.
A: No.
Q: Did you make notes about what you wanted to say?
A: At what point?
Q: At any point.
A: The interview?
Q: No. Forget the interview. The other parts where you're talking to the camera without Becker.
A: Yes.
Q: Where are those notes?
A: I don't know.
Q: You made them out in your own handwriting?
A: Yes.
Q: On index cards?
A: No.
Q: On regular paper?
A: Yes.
Q: You don't know where they are?
A: No.
Q: Would the production company have them, to the best of your knowledge?
A: No.
Q: Did you destroy them?
A: I don't know.
Q: What did you do with them when you were finished with them?
A: I looked at them, and that was it.
Q: Who did you give them to?
A: I didn't give them to anyone.
Q: Do you know where they are?
A: No.
Q: You don't know when this is coming out?
A: I would assume, I hope, in February sometime.
Q: Okay. Have you given any other interviews about the facts and circumstances surrounding Nicole and Ron's deaths other than the one to Becker?
A: No.
Q: You are doing one on Wednesday for Black Entertainment Television?
A: No.
Q: Are you doing an interview for them?
A: Yes.
Q: But it won't discuss the subject matter of your criminal case?
A: No.
Q: Or this case. Right?
A: I don't know.
Q: Have you--Are you working on a book?
A: No.
Q: Have you drafted any pages or manuscript material for a book?
A: No.
Q: Do you know whether anyone is doing that on your behalf?
A: No.
Q: Other than the notes that you made in connection with the making of this video, have you sat down and wrote out any of the facts and circumstances--
A: No.
Q: --about the deaths of Ron and Nicole?
A: No.
Q: You are not aware of any kind of narrative statement by you to that effect, are you, on paper?
A: No.
Q: Have you tape-recorded such statements?
A: No.
Q: Videotaped such a statement?
A: No.
Q: Is Mr. Schiller working on another book with you?
A: We hope to.
Q: Have you started work in earnest on that book?
A: No.
Q: What is the subject matter of that book?
A: My life; this case.
Q: But nothing has been written yet?
A: No.
Q: Does Mr. Schiller have materials that you gave him for the writing of this book?
A: No.
Q: Do you know... Let me ask you some questions about medical injuries in your life. You've had some surgeries. Correct?
A: Yes.
Q: Where have you had surgeries?
A: My hand, my knees and minor rectal.
Q: What knees?
A: And my eye. My eye once, too.
Q: Let's start with the knees. What knee did you have surgery on?
A: Basically the left knee, and I believe one on my right knee.
Q: Do you have surgical scars on the left knee?
A: Yes.
Q: Do you have surgical scars on the right knee?
A: Not that you can detect.
Q: What eye did you have surgery on?
THE WITNESS: You see a hole in one of these eyebrows? I don't recall.
MR. BAKER: Left.
BY MR. PETROCELLI: Q: Left eye?
A: Left eye, yeah.
Q: Left eyebrow?
A: Actually, it was the eye.
Q: Eye? And is there any scarring?
A: No.
Q: And hand surgery?
A: Yeah.
Q: Which hand?
A: Left hand.
Q: Any scars from that?
A: Yes.
Q: Do you have any other visible scars on your body?
A: Yes.
Q: Where?
A: All over.
Q: Where?
A: Elbow, ribs, foot, knees, arms, few on my face.
Q: These are from what, playing football?
A: Basically, yes.
Q: Are they permanent scars?
A: I haven't played football in 15 years and they're still there, so I would imagine so.
Q: And you have them on both of your arms?
A: Yeah.
Q: Where?
A: Wrists, elbows, forearms.
Q: And also on your legs?
A: Uh-huh.
Q: Where?
A: Mostly calf area.
Q: Now, did you have these scars, these visible scars, as of June 12,1994?
A: I haven't played football since then.
Q: So all these came from playing football. Right?
A: Yes. Basically.
Q: Are there any other scars that you know about?
A: Uh-uh.
Q: You have to answer audibly.
A: No.
Q: As of June 12,1994, l want to ask you a series of questions about who were your advisors and close friends and so forth as of that point in time. So I would like you to focus on June 12, 1994. Okay?
Did you have a general business attorney?
A: Yes.
Q: And who was that?
A: Skip Taft.
Q: Did you have an accountant?
A: Through his office, yes.
Q: Who was that?
A: Mary Ann--I can't think--no. Marilyn. I can't think of her last name.
Q: Did you have a business manager?
A: No.
Q: Did you have a secretary?
A: Yes.
Q: Who was that?
A: An assistant, I would rather say.
Q: Assistant?
A: Yeah. Cathy Randa.
Q: And any other assistants or secretaries?
A: No.
Q: How long had Randa been working for you?
A: Roughly 20 years.
Q: 20 years?
A: Yeah.
Q: Did Randa have any employees working with her on your matters?
MR. BAKER: Do you mean as employees or consultants?
MR. PETROCELLI: Employees.
THE WITNESS: From time to time.
BY MR. PETROCELLI: Q: Nobody you can identify?
A: No.
Q: And does Cathy Randa work at an office?
A: She did, yes.
Q: She did at that time?
A: Yes.
Q: What office was that?
A: 11661 San Vicente.
Q: Is that your office?
A: Yes.
Q: Do you still have that?
A: No.
Q: And what was the name of that--You had a company that she worked for?
A: Yes.
Q: O.J. Enterprises?
A: Yes.
Q: Does Randa still work for you?
A: Yes.
Q: For O.J. Enterprises?
A: Yes.
Q: And where does she work now?
A: Out of her home and at my home.
Q: Okay. Did you have any other assistants or secretaries besides Randa?
A: No.
Q: As of that time, who were your closest other advisors, if you had any? You mentioned Taft.
A: Marvin Goodfriend.
Q: And who is he?
A: Tax attorney.
Q: He's a tax attorney?
A: Uh-huh.
Q: Anyone else?
A: No.
Q: Okay. Who were your closest friends in or around June of 1994?
A: Al Cowlings--you want a whole list?
Q: Your closest.
A: Bobby Chandler, Paula Barbieri. When you say "in and around"--
Q: June 1994.
A: Nicole Brown, Reggie McKenzie, Louis Marx, Wayne Hughes, Jack Snyder, Bobby Bender. Goes on and on.
Q: Can you identify them for me?
A: Allen Austin, Bob Hoskins, Al Wyler--
Q: Wyler?
A: Wyler. Cory Wolman. I know I forgot someone, but I would say among my best friends, that would be pretty much the group.
Q: Was Kato Kaelin among your best friends--
A: No.
Q: --in June of 1994?
A: No.
Q: One of your close friends?
A: No.
Q: How would you characterize your relationship with him at that time?
A: He seemed to be a nice guy.
Q: An acquaintance?
A: Yes.
Q: Who were your house employees in June of 1994?
A: Gigi Gurin, I believe.
Q: How do you spell her last name?
A: G-u-r-i-n, I believe, although I may not be sure on that.
Q: Does she still work for you, Mr. Simpson?
A: Yes.
Q: When did she begin working for you in the house?
A: Roughly April, late March, April of '94. '94.
Q: And who preceded her? Back up. What were her duties? What does she do for you?
A: Housekeeper.
Q: Full time?
A: Yes.
Q: Did she live at the house?
A: During the week, yes.
Q: In the guest house?
A: No. In the quarters right off the kitchen.
Q: Right off the kitchen?
A: Yeah.
Q: What were her nights off?
A: Weekends.
Q: Saturday and Sunday?
A: Yes.
Q: She was not home, for example, on Sunday, June 12, 1994. Correct?
A: Yes. Or last night, for that matter, yes.
Q: And she was not there on Saturday, June 11, 1994. Correct?
A: Yes.
Q: The last time that Gigi was at your house in this time frame in June was Friday at the end of the day, June 9?
A: I believe so. I believe so. I don't recall seeing her Friday, but-
MR. BREWER: Mr. Petrocelli, could we ask the witness just to keep his voice up?
THE WITNESS: I believe so, Friday, yes.
BY MR. PETROCELLI: Q: Do you know how she got--how she departed your house on Friday, whether she had her own car or whether somebody in your house drove her?
A: I know no one at my house drove her-- I can't answer that because I don't know if Kato drove her, but I have no knowledge.
Q: Did she have her own car?
A: From time to time, yes.
Q: When she was at your house Monday through Friday, did she have a car there?
A: From time to time. yes.
Q: Her own car?
A: If her husband didn't have it, which was probably most of the time.
Q: Okay. And who was Gigi's predecessor?
A: Michelle Abudrahm. I can't spell the last name.
Q: A-b-d-u-r-a-n?
A: I have absolutely no idea
Q: Where is Michelle now?
A: She works in Beverly Hllls
Q: For whom?
A: I don't know.
Q: Do you have her phone number?
A: I'm sure it's around somewhere.
Q: You mean in your phone book?
A: Probably at my home.
Q: At your house?
A: Yeah.
Q: Do you know the name of the family that she works for?
A: I've heard it. The guy is very wealthy, I know, but I can't recall his name right now.
Q: Have you spoken to Michelle since you were released from prison in October of this year? A: Yes.
Q: Of last year. Excuse me.
A: Yes.
Q: You speak to her from time to time?
A: Yes.
Q: Has she done any work for you?
A: She's made me--yes.
Q: I mean since you--
A: Well, work, no, but she's--yeah, no, she hasn't done any work. I'm sorry.
Q: What has she done for you?
A: Made me cookies.
Q: Cookies. But she hasn't been in your employ?
A: No.
Q: But she is a friend now?
A: Yeah. I like her. Yes.
Q: How long did she work for you?
A: On and off over a 10 year,12-year period.
Q: So starting in the '80s and going to March 1994?
A: Yes.
Q: And did you have any other housekeepers in 1993 or '94 other than Michelle and Gigi?
A: Not that I recall.
Q: Any other house help?
A: I think Michelle got some help from time to time.
Q: Nobody you would know. Right?
A: No.
Q: Okay. By the way, would you consider Robert Kardashian one of your close friends?
A: Oh, yes, I'm sorry. I certainly would.
Q: As of June of 1994?
A: Yes.
Q: How long had you known Mr. Kardashian as of June of 1994?
A: Over 20 years.
Q: Did he ever act as your attorney?
A: Yes.
Q: When?
A: On some business deals that we had done in the past.
MR. KELLY: I am sorry. I am not able to hear the witness' answers.
BY MR. PETROCELLI: Q: They are having trouble hearing you, Mr. Simpson.
A: Some business deals that we had done in the past.
Q: In the '70s?
A: '70s and possibly '80s.
Q: But aside from those business deals, your relationship with him is principally a friendship one. Right?
A: Principally, yes.
Q: Have you ever been convicted of a felony?
A: No.
Q: Have you ever been convicted of any crime?
A: I pleaded no contest in a spousal abuse case in 1989, so I don't know what that is.
Q: Have you ever pleaded no contest or guilty or been found guilty to any other crimes?
A: No.
Q: Have you ever been charged with any crimes other than the spousal abuse and the murder case?
A: No.
Q: Have you ever been sued civilly for any acts of physical violence?
A: No.
Q: Have you ever been charged with rape?
A: No.
Q: I don't mean-- Formally in a complaint?
A: No.
Q: Or informally in a claim--
A: No.
Q: --by a person or in a letter?
A: No.
Q: Nothing like that in your whole past?
A: No.
Q: Have you ever been accused of battery other than the spousal battery?
A: No.
Q: Civilly?
A: No.
Q: Criminally?
A: No.
Q: Informally?
A: No.
Q: Did you ever make a settlement with anyone who charged you with assault, rape or battery?
A: No.
Q: As of June of 1994, is it true that you had generally favorable relations with the Los Angeles Police Department? MR. BAKER: I don't know what you mean by that, and I don't know that he can characterize his relations. BY MR. PETROCELLI: Q: You can answer.
MR. BAKER: No, don't answer. That question is overbroad, vague and ambiguous.
BY MR. PETROCELLI: Q: Did you think you had a good relationship with the LAPD as of June 1,1994?
MR. BAKER: His state of mind relative to his relations with the LAPD, it's irrelevant and I am going to instruct him not to answer that question.
MR. PETROCELLI: Okay.
Q: Before June 1 of 1994, had you ever been arrested by the LAPD?
A: No.
Q: Had they ever come out to your house?
A: Yes.
Q: When you were present?
A: In an official capacity?
Q: No. Had they ever--Yes, in an official capacity.
A: Yes.
Q: When you were present at the house?
A: Yes.
Q: On how many occasions?
A: One, possibly two times.
Q: What was the one time that you remember clearly? A: 1989.
Q: They came out to your house and did not arrest you?
A: Correct.
Q: And the other time was when?
A: I don't totally remember this time, but it was 19- I think -84. They tell me Mark Fuhrman came to my house.
Q: And he did not arrest you. Correct?
A: No.
Q: Nor did anyone else. Right?
A: No.
Q: And are there any other times that you can remember when the police in their official capacity came out to your house?
A: No.
Q: Now, were there any times when you were at Nicole's house that the police came out?
A: Once.
Q: When was that?
A: 1993.
Q: Did they arrest you then?
A: No.
Q: Did members of the LAPD frequent your house from time to time?
MR. BAKER: That's pretty vague and ambiguous, too.
THE WITNESS: Yeah, you'll have to be a little more specific because I can't answer that.
BY MR. PETROCELLI: Q: Did they ever come visit you?
A: Stop-
MR. BAKER: In an unofficial capacity come visit him for a social call, is that the question?
MR. PETROCELLI: Correct, Mr. Baker, and all of this is before June 12, 1994.
THE WITNESS: Yes. And even after they've stopped and talked to me at my driveway and stuff, yes.
BY MR. PETROCELLI: Q: Even now, you mean?
A: Yes.
Q: Okay. Prior to June 12, 1994, would they come to your house from time to time to use your pool?
A: No.
Q: Your tennis courts?
A: One individual had used my pool I think when he was still with the LAPD.
Q: Who was that?
A: Ron Shipp.
Q: Okay.
A: And never alone did he ever use my pool at that point, but my tennis court, I'm pretty sure he did.
Q: He used your tennis court?
A: Yes.
Q: Any other LAPD members use your tennis court--
A: Not that I know of.
Q: --besides Mr. Shipp?
A: Not that I know of.
Q: Did Mr. Shipp bring other people with him when he used the pool and tennis courts?
A: Tennis court we're talking, not pool. Yes, he had a--from time to time he had a foursome that he would play tennis with.
Q: Did you ever file any charge of harassment against the police at any time before June of 1994?
A: No.
Q: Okay. Did you ever attend any LAPD Christmas parties?
A: Not that I recall.
Q: Did you ever attend any LAPD functions?
A: Not that I recall.
Q: You don't remember attending annual Christmas parties?
A: I know I didn't attend, not annually any, but I don't recall ever doing that, no.
Q: Any kind of parties or functions?
A: Over my years in L.A. I've attended a lot of functions, and I can't really recall any that were specifically LAPD.
Q: Did you ever autograph footballs for officers?
A: Oh, yes.
Q: LAPD officers?
A: Every officer, everybody, yes.
Q: Did you charge them?
A: I never charge.
Q: And did not charge the LAPD. Correct?
A: Well, I don't know. If an LAPD officer drove up and had a football and asked me to sign it, I'm sure I didn't charge him.
Q: And you signed other things for them, too, besides footballs?
A: I've signed pictures for everybody, LAPD or whatever they might be.
Q: Your son Jason was given an LAPD cap from a police officer?
A: I would assume so. I have not saw the cap.
Q: Do you know who gave it to him?
A: Probably Ron Shipp. I don't know.
Q: You just don't know?
A: I'm guessing. I don't know.
Q: What reasons would the LAPD come visit you in their unofficial capacity?
MR. BAKER: Don't answer that question. That calls for speculation on the part of this witness.
BY MR. PETROCELLI: Q: What did you understand the purpose of the visits to do?
MR. BAKER: If they told you what they--the reason they came, you can relate that. Don't speculate.
MR. PETROCELLI: He doesn't have to be told.
MR. BAKER: Don't guess or speculate.
BY MR. PETROCELLI: Q: You can answer.
A: They dropped by, they look, they talk, and sometimes they'd ask for an autograph. Since the trial, on two occasions they came by to tell me I got screwed.
Q: Now, before the trial when they would stop by and talk, how would they get to the front door?
A: They wouldn't. Normally -- I don't ever recall them knocking on my front door. I mean, maybe Shipp has before. But normally, if they see me in my yard --I spend a lot of time in my yard, and I didn't keep my gates locked up previously.
Q: And they would see you, and you would converse and chat, just social talk. Right?
A: Yeah.
Q: Pleasantries. Right?
A: Uh-huh.
Q: So your dealings with the LAPD were cordial?
A: Yeah. For the most part, yes.
Q: Do you know any other--before June of 1994,did you know any other police officers by name other than Ron Shipp?
A: Yes. Years ago, and I can't think of his name now, when I was at USC there was a guy who worked for LAPD, nice guy, but I think he stopped working for the LAPD back then also. He was in a shoot-out and stopped working.
Q: Which officers came by and said you got screwed?
A: I don't know. I don't know the ones that came by and asked for an autograph either.
Q: The ones that came by and said you got screwed, you don't know who they are?
A: No. They were just outside of my house, and my security was around.
Q: Did they explain to you how you got screwed?
A: No. They just said--one guy on a motorcycle drove up to me once and said it also.
Q: Did he explain what he meant?
A: No. He drove off. Gave me the thumb's up--said, "They tried to screw you," gave me the thumbs up and left.
Q: "They" being whom?
MR. BAKER: If you had an impression.
THE WITNESS: I'm assuming the prosecution.
BY MR. PETROCELLI: Q: Did anybody ever say to you--these officers who drove by and spoke to you since you got out of jail ever say to you that the LAPD tried to screw you?
A: No
Q: Okay. Do you believe you were framed by the LAPD?
MR. BAKER: You don't answer that question.
MR. PETROCELLI: Why not?
MR. BAKER: Because that's argumentative. It's irrelevant, immaterial what his state of mind is.
BY MR. PETROCELLI: Q: Do you have any information that you were framed by the LAPD?
MR. BAKER: He is not going to answer that. You are not going to try this case through him. You are going to try it through evidence.
MR. PETROCELLI: I am trying to find out his state of mind.
MR. BAKER: His state of mind is irrelevant
MR. PETROCELLI: I am not asking for his state of mind. I am asking for what information he has, Mr. Baker.
MR. BAKER: No, you are not. You are not going to answer that question.
MR. PETROCELLI: Give me an objection so we can just have a clean record.
MR. BAKER: I did give you an objection, and I gave you an instruction. It's irrelevant, immaterial, and it calls for his state of mind, and it's argumentative.
BY MR. PETROCELLI: Q: When did you first think you were being framed by the LAPD?
MR. BAKER: Don't answer that question. We are not going to go through a deposition of his state of mind.
BY MR. PETROCELLI: Q: Do you contend that you were framed by the LAPD?
MR. BAKER: I will do the contentions, and he is not going to answer that question.
BY MR. PETROCELLI: Q: As of June 17, Mr. Simpson, did you have any information that caused you to believe that you were being framed or set up by the LAPD?
A: No.
Q: Let's talk a little bit about June 17th. You were present at the home of Mr. Kardashian on the morning of June 17th?
A: Yes.
Q: Okay. And you were there in the morning. Right?
A: Uh-huh.
Q: You have to answer yes.
A: Yes.
Q: And who was present with you? Who was in the house?
A: Paula Barbieri. At one point A.C. came.
Q: A.C. Cowlings?
A: Yes, Al Cowlings. At one point Shapiro and, of course, Kardashian. I believe Kardashian's girlfriend--
Q: What's her name?
A: Denise Halicki. I believe Nicole Pulvers, and then some doctors. I'm not sure. I'm pretty sure Dr. Lee was there. Dr. Huizenga I believe was there. I believe Mike Baden. I'm saying this only because I've heard these guys talk since then, so I believe that he was there.
Q: Who?
A: Mike Baden. Michael Baden. That's all I can recall right now.
Q: Bob Shapiro was, of course, your lawyer in the criminal case.
A: Yeah, he came there. I know he came.
Q: And Cowlings and Kardashian were your very close friends. Right?
A: Yeah, they have been my friends for years.
Q: And Paula Barbieri was -- she was your girlfriend?
A: Yeah, basically, yes.
Q: And Denise Halicki was Mr. Kardashian's girlfriend. Right?
A: Yes. Q: Nicole Pulvers was whom?
A: She was assisting Bob Kardashian.
Q: And these doctors, Lee, Huizenga and Baden, they were all retained in connection with your criminal case? A: Yes.
Q: Was Huizenga a preexisting doctor of yours?
A: No. I'd only--he had only done something for me on one other occasion previous to this.
Q: When was that?
A: I was on a plane coming back with the Raiders once and I was having some major eye problems, and he sort of helped me out.
Q: Was that when he was the Raider team physician?
A: Yes.
Q: Okay.
A: Oh, and previous to that day, that week he had done a physical on me and stuff.
Q: The week of June 13.
A: Yes.
Q: Correct?
A: Yes.
Q: He did that on June 15. Correct?
A: I believe so.
Q: Okay. Now, you understood that you were going to be arrested.
A: Yes.
Q: And the arrangements were that you were going to be taken down to LAPD?
A: I believe so. I believe I was gonna -- they were gonna drive me down. Mike, you know, Shapiro. I believe that was the arrangement.
Q: Shapiro was going to drive you to the police station?
A: Yes.
Q: And what time were you scheduled to go to the police station?
A: I don't recall.
Q: Were you on any medication?
A: Yes.
Q: At that time?
A: Yes.
Q: In the morning?
A: Yes.
Q: What were you on?
A: I have no idea.
Q: Who gave it to you?
A: I think Dr. Faerstein-
Q: He was there also?
A: I don't recall if he was there. I know he--I think he was the one who prescribed the medication
Q: What did he prescribe?
A: I don't know. You'd have to ask him
Q: Did he give the pills to someone else to administer to you?
A: I don't know. I know that when I needed them, Cathy or Paula would get them, and early when he was around, he'd give them to me.
Q: Cathy Randa was there also?
A: I believe she came there that day. I'm not a hundred percent sure.
Q: Before you left?
A: Yes.
Q: By the way, are you on any drugs or medication now?
A: Yes.
Q: What are you taking?
A: Sulfasalazine and prescription Motrin.
Q: Motrin?
A: Yeah.
Q: For what?
A: Pain.
Q: What kind of pain?
A: Just arthritic, whatever, general arthritic pains.
Q: And what is the other medication?
A: It's called Sulfasalazine. It's something that a rheumatologist has had me on for a few years now.
Q: Going back to when?
A: '93 sometime.
Q: Are you taking anything else right now?
A: No.
Q: Do those medications in any way interfere with your ability to hear, understand and answer truthfully my questions?
A: Not that I know of.
Q: Okay. So going back to the morning of the 17th, do you remember what time you were scheduled to depart for LAPD?
A: No.
Q: What did you do on the morning of the 17th at the house?
A: I think they were taking pictures of me.
I know I wrote, I did some writing. That's pretty much all I recall.
Q: They took pictures of you, meaning parts of your anatomy?
A: I believe that was that morning. I'm not a hundred percent sure, but I believe-
Q: The doctors did?
A: Yeah, I'm pretty sure that was that morning.
Q: Did you receive any injections?
A: Not that I recall.
Q: Did they take any blood?
A: I don't recall.
Q: What kind of writing did you do?
A: Some writing, putting some of my thoughts down, thoughts that I had for friends and things.
Q: Did you write individual letters to different people?
A: Just a basic letter.
Q: One basic letter?
A: I may have written two basic letters. Q: The one basic letter, is that the letter that was later on that day read by Bob Kardashian?
A: I believe so.
Q: You wrote that?
A: Yes.
Q: In your own handwriting?
A: Yes.
Q: And you wrote it the morning of the 17th?
A: Yes.
Q: Did anybody assist you in writing it?
A: No.
Q: You wrote it all yourself?
A: Yes.
Q: Did anybody dictate anything to you?
A: No.
Q: Did anybody tell you what to say?
A: No.
Q: Did anybody suggest what to say?
A: No.
Q: Anybody review it after you finished it?
A: No
Q: What did you do with it when you finished writing It?
A: I don't know immediately when I finished writing it, but I may have given it to Bob.
MR. BREWER: Sorry. I can't hear you.
THE WITNESS: I don't know what I did immediately when I finished writing it. I either gave it to Bob to hold or to A.C. I don't recall what I did.
BY MR. PETROCELLI: Q: Did you put it in an envelope?
A: Yes.
Q: Did you seal the envelope?
A: Yes.
Q: How did you address the envelope?
A: I don't know if I addressed it to anyone. I'm not sure.
Q: When you handed it to Bob--is that what you said?
A: Yeah.
Q: What-
MR. BAKER: He said Bob or Al, I believe.
MR. PETROCELLI: Bob or Al?
Q: What did you say it was?
A: I just told them to keep this.
Q: What did you tell them to do with it?
A: Just keep it.
Q: Did you tell them to open it?
A: No.
Q: To read it?
A: No.
Q: Did you tell him that you'll know when it's appropriate to open and read this?
A: No
Q: Did you say that? A: No.
Q: What was your purpose in giving it to them?
A: It was just some thoughts I wanted to share with some people.
Q: When did you understand that the thoughts would be shared?
MR. BAKER: If you had an understanding.
THE W1TNESS: If I had an understanding. I don't know. I was, you know, I was in a--I don't know. My frame of mind, I can only speak to you based on how I feel now about it, and I thought that if I had harmed myself in any way, that they would read it to my friends.
BY MR. PETROCELLI:
Q: Such as if you killed yourself?
A: Yes.
Q: You were suicidal that week. Right?
A: Evidently, yes.
Q: And you were on suicide watch?
A: I don't know about that week. I don't know. You say "suicide watch." I wasn't aware that I was suicidal, so I don't know.
Q: When you wrote that letter, though, you had thoughts of suicide. Right?
A: I had a thought--thoughts of-yeah, I had thoughts of ending what I was feeling, yes.
Q: Certain persons were keeping vigil over you to see that you wouldn't harm yourself. Is that right?
A: I really wasn't aware of that at the time, no.
Q: Your sister?
A: I wasn't aware of that so much at the time. I knew that they were with me for support. I knew my sister was. I only spent one night at Rockingham, and I knew she was there for support with me.
Q: The one night you spent at Rockingham was the 13th, a Monday night. Right?
A: Yes.
Q: You summoned Paula Barbieri back from Las Vegas to be with you and to keep vigil over you. Is that right?
A: That's not correct, no.
Q: Did you ask her to come back?
A: No.
Q: Who did?
A: I don't know. I think she insisted on coming back.
Q: On her own?
A: Pretty much so.
Q: How do you know that?
A: Because she came back.
Q: How do you know she insisted on coming back on her own?
A: I don't know. I just-
Q: You don't know if anybody called her and asked her to come back?
A: I don't know. I know I wanted her there, but at the same time I didn't want her there because of all the press that was hanging around, so I did -- I was glad she came.
Q: Did you ask anybody to call her?
A: I don't recall doing that, no.
Q: Did you ask Cathy to do that?
A: I don't recall doing that, no.
Q: What was the other basic--Let me get back to this letter. When you wrote this letter, were you alone?
A: Yes.
Q: And where were you?
A: I was sitting in my room. I guess I was sitting in the room.
Q: Bedroom?
A: I think I had written it in a few places. I was just taking notes when I was not being bothered.
Q: You wrote it in one sitting?
A: I don't think so. I'm not sure. I don't think so.
Q: Did you write it all on the morning of the 17th of June?
A: Yes.
Q: You said you had thoughts of ending what you were feeling. What were you feeling?
A: A lot of pain.
Q: What kind of pain?
A: Pain.
Q: Pain over what?
A: My wife had been murdered, and I was being attacked.
Q: By whom.
A: Media.
Q: They were attacking you?
A: Yes.
Q: Meaning they were blaming you?
A: No. They were attacking me during the week, saying things that weren't true.
Q: You felt the media were saying things, attacking you, that were not true?
A: I knew they were. I saw it on TV.
Q: What were they saying about you?
A: Just various things.
Q: Well, can you tell us back then what you were thinking that was being said about you that was untrue?
A: Just how I was reacting. One guy, I think Jim Avila, did a report that I was in Chicago, and when I arrived there I was loud and boisterous as if I was trying to be noticed, which was a flat-out lie, and I'm sure you talked to the people in Chicago when I arrived, and they made that clear, that I was anything but loud and boisterous. But things of that nature. I can't recall them all.
Q: Were you feeling you were being attacked in the sense that you believed the press was pointing the finger at you as the person who killed Nicole?
A: I can't say the press in general. Just a few things that I had heard, because I stopped watching it after a while.
Q: But the gist of it was that these few things were pointing the finger at you. Right?
A: My pain was for Nicole more than what they were doing. That was just all a part of it.
Q: The loss of Nicole?
A: Yes.
Q: You loved her?
A: Very much.
Q: And you loved her on June 12?
A: I loved her. Yeah. I didn't want to live with her, but I loved her, yes.
Q: And you loved her so much that you were prepared to kill yourself?
MR. BAKER: Well, that's argumentative. Don't answer.
THE WITNESS: That's not why.
BY MR. PETROCELLI: Q: You loved her so much that you were feeling so much pain that you had thoughts of ending your life?
A: I just had pain for a lot of reasons, for everything that was going on that week, yes.
Q: Well, besides the loss of Nicole and your feeling of being attacked, was there any other source of your pain?
A: Just everything that was going on was my source of my pain.
Q: What do you mean by that, "everything that was going on"?
A: Everything that was going on.
Q: Can you be more specific?
A: No.
Q: Do you mean in the sense that people were blaming you?
A: No. I just mean everything that vas going on, and I can't be more specific.
Q: You cannot tell us anything more than that?
A: No.
Q: What was the other note that you wrote?
A: It wasn't a note. It was an amendment to my will.
Q: Who did you give that to?
A: I believe I directed it to be given to Skip Taft.
Q: Did you write it in your hand?
A: Yes.
Q: What did you change?
A: I don't recall.
Q: Did someone tell you to change your will?
A: No.
Q: Was it your own idea?
A: Yes.
Q: Did you write it on a blank piece of paper?
A: I believe so.
Q: And who did you give that--How many pages was it?
A: I don't recall.
Q: Who did you give it to?
A: I believe whoever I gave the other letter to.
Q: What did you tell that person about the second envelope?
A: I think I put Skip Taft's name on it.
Q: Was it in an envelope?
A: I believe so, yes.
Q: Did you write any other notes, letters, that morning?
A: Not that I recall.
Q: What about that week prior to the 17th, did you write any other notes or letters for people?
A: No.
Q: Were your children there with you?
A: No.
Q: Were your children with you at all during the week of the 13th?
A: Yes.
Q: What days?
A: They came on the 14th and left on the 15th.
Q: Came to?
A: Bob Kardashian's home.
Q: And they stayed over?
MR. KELLY: I'm sorry. I can't hear you again, Mr. Simpson. I'm sorry.
THE WITNESS: I'm sorry. Bob Kardashian's home.
BY MR. PETROCELLI: Q: The 14th was a Tuesday. Right?
A: Yes.
Q: Your children came to your house on Tuesday, and they left on Wednesday. Is that what you're saying?
A: That's correct.
Q: They slept over at Mr. Kardashian's house?
A: Yes.
Q: By "your children," are we talking about Sydney and Justin?
A: Yes.
Q: Who brought them both ways?
A: Al Cowlings.
Q: And they were at the Brown residence in Dana Point?
A: That's correct.
Q. So Mr. Cowlings was with them in Dana Point, brought them to the Kardashian house and brought them back to Dana Point on Wednesday?
A: That's correct.
Q: Did he bring anyone else with him other than Sydney and Justin?
A: I don't believe so, no.
Q: The last time you saw your kids before you were arrested was Wednesday?
A: No.
Q: You saw them at the funeral?
A: Yes.
Q: I see. That was Thursday. Right?
A: Yes.
Q: Okay. Did you write any notes or letters out to your children that week?
A: No.
Q: Did you write any checks that day?
A: No.
Q: Did you give Mr. Cowlings any envelopes with anything in them?
A: I don't think so, other than if he was the guy I gave the letter to.
Q: Did you give Mr. Cowlings a sealed envelope with six checks in it?
A: No.
Q: Do you know whether Mr. Cowlings had a sealed envelope with six checks in it-
A: No.
Q: --on the 17th of June?
A: No.
Q: You have no knowledge about that?
A: No.
Q: After you did some basic writing, they took some pictures of you, what else did you do that morning?
A: Nothing else I can recall.
Q: Did you say good-bye to anybody?
A: No.
Q: You were anticipating going off to jail. Right?
A: Yes.
Q: And would not know when you would return. Right?
A: Yes.
Q: Now, you did not wait for the police, but left. Right?
A: Correct.
Q: And you left with whom?
A: Al Cowlings.
Q: What time did you leave?
A: I have no idea.
Q: When you left with Mr. Cowlings, you left the Kardashian residence in Mr. Cowlings' Bronco. Correct?
A: Correct.
Q: Parked in the driveway. Right?
A: Correct.
Q: Did you tell anyone that you were going?
A: No.
Q: Did they--to your knowledge did they know that you were going?
A: No.
MR. BAKER: That calls for speculation.
THE WITNESS: Not to my knowledge, no.
BY MR. PETROCELLI: Q: Why didn't you tell them you were going?
A: I didn't think about them.
Q: You knew the police were coming, though. Right.
A: Yes.
Q: And you knew that if you had left, you would not be there when they arrived. Right?
A: I didn't know they were coming. I knew that I was supposed to be going down there.
Q: Supposed to be going to the police station.
A: Yes.
Q: And you knew by leaving the residence, you wouldn't be going to the police station then. Right?
MR. BAKER: Well, I don't know-
BY MR. PETROCELLI: Q: You can answer.
MR. BAKER: That's argumentative, but go ahead.
THE WITNESS: What was the question? I'm sorry.
MR. PETROCELLI: Can you please repeat it?
(Pending question read as follows:
"Q: And you knew by leaving the residence, you wouldn't be going to the police station then. Right?")
THE W1TNESS: Correct.
BY MR. PETROCELLI: Q: In other words, you didn't ask Mr. Cowlings to take you to the police station. Right?
A: Correct.
Q: Whose idea was it to leave?
A: Mine.
Q: Why did you leave?
A: Because I wanted to go to Nicole's grave.
Q: Did you ask your lawyers if you could go there first?
A: No.
Q: Your representatives?
A: No.
Q: Did you ask them to ask the police if you could go there first?
A: No.
Q: You just took it on yourself to leave?
A: Yes.
Q: Why did you do that?
A: Because I wanted to go to her grave.
Q: And did you go to her grave?
A: Yes. Well, we never made it there because there was a police car blocking the entrance.
Q: They wouldn't let you in?
A: Well, A.C. saw them and avoided going in. Q: Do you know what time you left the house?
A: No.
Q: Do you know--when you left the Kardashian house and you got in the truck, where were you sitting?
A: In the passenger seat.
Q: Visible to anybody who would look in?
A: Yes.
Q: And did you remain in the passenger seat all the way down to the grave site?
A: Yes.
Q: Did you make any phone calls from the car?
A: I believe so.
Q: Who did you call?
A: I don't remember totally, but I know I called Nicole's house, and then I know I called some other people, but I don't recall who.
Q: When you say "Nicole's house," do you mean the condo on--the place on Bundy?
A: Yes.
Q: Who did you speak to there?
A: Lou Brown.
Q: He was staying there?
A: Yeah. I guess so. Q: What did you tell Mr. Brown? A: I don't recall.
Q: Did you call anybody else?
A: I know l did, but I don't recall who.
Q: Did you call Mr. Taft?
A: I may have, yes. Q: Why did you call Mr. Taft?
A: I don't recall.
Q: Did you drive directly to the grave site?
A: Yes.
Q: How long did it take to get there?
A: I don't know.
Q: Did you make any stops?
A: Well, I think there was a--I've just heard this from A.C.--that there was a dump truck that had turned over, so we sat on the freeway for quite a while.
Q: Which freeway?
A: I believe it was the 405.
Q: For how long did you sit there?
A: I don't know.
Q: Half hour?
A: I can't say. I really don't know.
Q: And the whole time you were in the passenger seat
A: Yes.
Q: And when you got--did you get to the entrance of the cemetery?
A: Where we could see the entrance, yes.
Q: What is the name of the cemetery?
A: I don't know.
Q: How close did you get to the entrance?
A: I don't know. Couple hundred yards maybe.
Q: And why did you not go through?
A: Because there was a police car blocking it.
Q: Were-- did you approach the officer and ask if you could go through?
A: No.
Q: Were you listening to the radio at all?
A: No.
Q: Did you believe at that time that you were a fugitive?
A: I didn't give it a thought.
Q: Did Mr. Cowlings tell you that?
A: No.
Q: Did you believe that the police were looking for you?
A: I really didn't give it a thought, but --
MR. BAKER: You've answered the question.
THE WITNESS: No, I really didn't give it a thought.
BY MR. PETROCELLI: Q: Did you believe if you went up to the officer and asked to be let through, that he would have prevented you from doing so?
MR. BAKER: He is asking for your state of mind on the 17th of June, 1994, if you thought the officer would have prevented you from going into the cemetery.
THE WITNESS: Probably.
BY MR. PETROCELLI: Q: Why did you have that belief?
A: I don't know. I just--I think A.C. believed that, and I'm pretty sure I believed that, too.
Q: When you asked Mr. Cowlings to take you to the cemetery, what did he say?
A: "Come on."
Q: Did he try to talk you out of it?
A: Not at all.
Q: He understood that you were supposed to go to the police station to be turned in. Right? A: You'd have to ask him that.
Q: Did you believe he understood that?
A: I believe that he probably knew that, yes.
Q: Did you and he discuss what you would do after you left the cemetery?
A: No.
Q: Did you have a plan at that time?
A: No.
Q: Did you know what you were going to do after you left the cemetery?
A: No. No.
Q: Did you bring anything with you?
A: Yes.
Q: What did you bring?
A: That I was aware of, three pictures of my family and a gun.
MR. BREWER: What was the second thing?
THE WITNESS: A gun.
BY MR. PETROCELLI: Q: Did you plan to commit suicide at the cemetery?
A: I didn't know what I was going to do.
Q: Did you plan to commit suicide after the cemetery?
A: I never thought of it to that extent.
Q: Did you have in your mind when you would end your life?
A: No. I just--no.
Q: Was the purpose of the gun to use to end your life if you saw fit to do so?
A: I'm sure that was part of it, yes.
Q: Where did you get the gun?
A: From my--actually, from my car.
Q: Which car?
A: My Bentley.
Q: The Bentley was at Rockingham. Right?
A: Uh-huh.
Q: You have to answer-
A: Yes.
Q: And how did the Bentley get from Rockingham to Mr. Kardashian's home?
A: It didn't.
Q: You stopped off at Rockingham and picked up the gun?
A: No.
Q: Explain to me how you got the gun.
A: I was curious when I got home from the police station, because I told the police that the gun was in my Bronco, and at that point no one had told me how Nicole was murdered, and I was curious if the gun was still in my car, and at one point-I don't know who--I asked some body to go look in my back seat and get a little case. They got it, and it was the gun.
Q: When you said that you told the police the gun was in your Bronco, you're referring to the statement you --
A: The Bentley.
Q: I am sorry. When you told the police--your prior answer was that you told the police that the gun was in your Bronco.
A: I meant Bentley.
Q: You meant Bentley?
A: Yes.
Q: When you said that you told the police that the gun was in your Bentley, are you referring to the statement that you gave to Detectives Vannatter and Lange?
A: Yes.
Q: And when you left the police department, you went back to Rockingham, and you had someone go into the Bentley to see if the gun was still there?
A: Eventually. Not quite the way you said it, but eventually.
Q: That day?
A: Yeah, later that day, yes.
Q: Who went into the Bentley for you?
A: I don't recall.
Q: Who did you ask to get the gun?
A: I don't recall.
Q: Did the person bring it to you?
A: Not the gun. They brought the case that it was in to me.
Q: A gun case?
A: No.
Q: What case are you referring to?
A: It's just a little case that it used to be carried in.
Q: Leather bag? What was it?
A: It was like a little violin case.
Q: A violin case?
A: Like a miniature violin case.
Q: A hard case?
A: Yes.
Q: And what did that case have in it?
A: A gun.
Q: What else?
A: That's it.
Q: Bullets?
A: I'm sure bullets, yes.
Q: In the gun?
A: Yes.
Q: Now...
MR. BAKER: Is this a good time? Let's take a break. We've been going for an hour and 20, 15 minutes.
THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 10:51.
(Recess.)
THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 11:09.
BY MR. PETROCELLI: Q: I want to go back to where we were, Mr. Simpson, concerning the retrieval of the gun. Do you remember what time you got back to Rockingham from the police station on the 13th of June?
A: From my office because they wouldn't let us go directly back to Rockingham. If I had to guess--it's a guess--roughly 6:00 o'clock maybe.
Q: You went from the police station to your office in Brentwood?
A: Yes.
Q: And then you went to Rockingham.
A: They told us it was all right to come back.
Q: Come back. Can you guys hear down there?
Q: You just need to keep your voice up.
A: From the police station to Rockingham, and then I believe it was Lange said it was all right, or Vannatter one, when I called my home, to come home.
MR. BAKER: You just said you went from the police station to Rockingham. You went-
THE WITNESS: To my office in Brentwood and then to Rockingham.
BY MR. PETROCELLI: Q: Who drove you from the police station to the office?
A: Either Bob or Bob Skip, Bob Kardashian or Weitzman.
Q: And from the office to Rockingham, who drove you?
A: I don't know. Probably Bob or Skip. I don't really recall.
Q: Bob being Bob Kardashian?
A: Yes.
Q: And Skip being Skip Taft?
A: Yes.
Q: When you got to Rockingham, you then asked someone to go look into the Bentley for the gun because why?
A: May have been a little later.
Q: Later that evening?
A: Yeah. Because I was curious.
Q: What were you curious about?
A: If they took the gun out of my car.
Q: "They" being whom?
A: The police officers.
Q: Why did you want to know that?
A: I was just curious. Some people were murdered, and I had a gun in my car.
Q: Now, was it your suggestion to get the gun?
A: I asked someone to go look and see, to bring me--if there was a case in the back of my car, would they bring it to me.
Q: In the trunk?
A: No. In the back seat behind the front seat.
Q; Is that where you kept it?
A: Yes. Q: Who retrieved it for you?
A: I don't recall. Q: No idea?
A: No. Q: What was in the trunk of that Bentley?
MR. BAKER: And you are talking again on the 13th?
MR. PETROCELLI: Yeah.
THE WITNESS: I couldn't tell you exactly, but I know some gloves and clubs and some balls were in there and some other paraphernalia. BY MR. PETROCELLI:
Q: On the evening of June 12 and on to the day of June 13, you knew that there were some clubs and some balls and other paraphernalia in the trunk of the Bentley. Is that right?
A: I would assume they were still there on the 13th, yes.
Q: You last left the trunk--clubs and balls and other paraphernalia in the trunk?
A: The last time I looked in my trunk, some balls were left in and some I took out, and there was a bunch of junk back there, but a lot of clubs, yes.
Q: Lots of clubs.
A: Yes.
Q: Golf clubs.
A: Yes.
Q: What was the last time you looked in the
Bentley before June 13?
MR. BAKER: And you are referring to the trunk?
MR. PETROCELLI: Trunk of the Bentley.
THE WITNESS: Sunday night, the night--previous night.
BY MR. PETROCELLI:
Q: What time?
A: l0:00, a little after 10:00, a little before, in that area.
Q: P.M?
A: P.M., yeah.
Q: Okay. Let's go back now. When-at the point in time on the evening of the 13th that you had someone go into the Bentley to get the gun, did you not know how Nicole had been killed?
A: Yes.
Q: You did not know. Right?
A: I did not know.
Q: Did you believe that she had been killed by a gun?
A: I didn't know.
Q: Did you believe that that was even a possibility?
A: Obviously, yes.
Q: Did you have any information that she had been killed through the use of a knife?
A: Not at all.
Q: Did you ask anyone how she was killed?
A: I asked the police on many occasions what happened, and they continued to tell me that they didn't know and they were still investigating.
Q: Did you see press reports and television programs during the day about this?
A: Once I got home-
MR. BAKER: "The day" is the 13th?
MR. PETROCELLI: Yes.
Q: Before you went and asked that the gun be retrieved.
A: I knew that when I got home, we put on all three TVs, just about every TV in the house was on, and, you know, the press didn't seem to know much more than anyone else at that time.
Q: There were no reports that she had been killed perhaps by a knife?
A: None that I had seen, no.
Q: So you had no information whatsoever how she had been killed. Is that right?
A: That's correct.
Q: Were you told that she had been murdered?
A: Yes. Basically, yes.
Q: And that's all you knew.
A: Yes.
Q: As of the evening of June 13. Correct?
A: Yes.
Q: Did you ask anyone else besides the police how she had been killed? Bob Kardashian, Skip Taft, anyone else?
A: I may have during the course of the day as I came in contact with people. I think everybody was trying to ask everybody what happened, what did they know.
Q: And nobody had any knowledge about how she was killed as of that point in time.
A: No.
Q: Correct
A: As far as I recall, no.
Q: What did you do with the gun case when you got it? Did you open it up?
A: Yes.
Q: And what did you do?
A: I opened it up in my office. I believe I put it in my bag.
Q: Your office at the home?
A: Yes.
Q: Who was with you? A: I don't recall.
Q: What bag did you put it in?
A: I think no one was with me. When they gave me the case, I went in my office and put it in my bag.
Q: "They" being whom?
A: Whoever brought it in there.
Q: What bag?
A: My black bag that it was eventually found in.
Q: Can you describe that bag?
A: A black bag with zippers. And you guys have it, or the police department have it. I thought they turned it over to you guys.
Q: So was the gun loaded in the case?
A: Yes.
Q: You took the gun, closed the case, and then you put the case into the black bag?
A: I believe so.
Q: And was there anything else in the black bag at that time?
A: Yes.
Q: What was in it?
A: Everything I had taken to Chicago.
Q: What did that include? Withdrawn. Tell me as best as you can recall now what was in that bag on the 13th in your office when you put the gun in it.
A: My overnight kit, a book- Q: What book?
A: I believe it was "Inca Gold." Inca Gold," I believe it was. Some travel stuff.
Q: What do you mean by that?
A: You know, travel folder, that type of stuff.
Q: You mean tickets and stuff?
A: Yeah, tickets, travel, you know, schedule.
Q: What else?
A: What you guys now refer to as a disguise-
Q: When you say "you guys," what do you mean by that?
A: Well, I seen some people in this room refer to it on the news and the press and the prosecution.
Q: Okay. So what do you refer to it as?
A: It was a beard and a goatee.
Q: So you had a beard and a goatee in that bag. A: Yeah. I never really opened the package to see what, but it was like a Vandyke thing, I believe. I never really looked at it, so I don't know.
Q: It was in a sealed package?
A: Yes.
Q: It had never been opened?
A: I had never opened it, no.
Q: As of the evening of the 13th when it was in your bag, it had not been opened. Correct?
A: I had never opened it, no.
Q: Was it opened? You can't tell if it had been opened?
A: I don't know what Vannatter did, because he took my bag and- Q: That was latter.
A: I don't know. No, I'm only basing it on his testimony.
Q: I am a little confused. Vannatter didn't have your bag as of the evening of the 13th, did he?
A: Well, he perjured himself on the stand and testified that I told him he can look in my bag, which I didn't, but I would have if he would have asked, and he testified that he did look in my bag that Monday. Q: When you were interviewed?
A: Yes.
Q: At the police station?
A: When I left the police station, he kept--my bag was in the trunk of his car, and we're asking about picking it up, and he didn't want to walk to the --go downstairs to get it and asked if it would be all right if he took it to my house--gave it to me when he got back to my house. So I was there with two--three lawyers and said "Sure."
Q: Well, I will get back to that, but let me see if I understand the contents of the bag on the evening of the 13th. You mentioned the book, the overnight kit, the travel materials and the beard and goatee.
A: Yeah. And who knows what else. I mean, there's a lot of-
Q: Can you remember anything else?
A: Change, credit cards, passports, whatever, what I keep in the bag all the time. It's all in there that Monday.
Q: Your passport was in the bag?
A: Yes.
Q: You said 'passports." Do you have more than one? A: Well--no. Sometimes I have my kids'.
Q: Your passport was in this black bag you're describing?
A: Yes.
Q: And when did you put the passport in that black bag?
A: It's always in the black bag.
Q: Always.
A: Always.
Q: And when did you put the beard and goatee in the bag?
A: Whenever I got it.
Q: When did you get it?
A: I don't know. A few weeks before that.
Q: Where did you get it?
A: Someone ordered it for me, and then it came to my office, and then I got it.
Q: Who ordered it for you?
A: I asked a guy to get it for me, and I think he arranged it through Cathy.
Q: Who did you ask?
A: Whoever the makeup guy was on the--actually, I asked a girl who had a bunch of them on the shoot that I was doing for Playboy. She had a bunch of mustaches and beards, and while they were
doing my makeup, I said, "You know, I can use one of them," and I explained why.
And she said she'd get one, and while I was working she evidently had left, and then I had mentioned it to the other makeup person, and he said he can get it, and he and Cathy spoke, and he got it.
Q: That day?
A: I don't know.
Q: This was the exercise video?
A: Yes.
Q: And this was done at your residence. Correct?
A: Mostly no. Mostly at a studio.
Q: When you had the conversation with the makeup artist, was it at the studio?
A: Yes.
Q: What was that person's name?
A: I don't know.
Q: When you had the conversation with the second makeup artist, what was that person's name?
A: I don't know.
Q: When did you receive the beard and goatee?
A: I believe a few days after that.
Q: At your home on Rockingham. A: No. At my office, I believe it was.
Q: In Brentwood?
A: Yes.
Q: And who gave it to you?
A: I think it was just sitting on my
desk. When I go to my desk in Brentwood, things are there, and Cathy laid things out for me, I believe, and then I took it from the office one day.
Q: Did you pay for it?
A: I'm sure Cathy paid for it, yes.
Q: Do you know how much it cost?
A: No.
Q: Did you ever see a receipt for it?
A: No.
Q: What was the reason that you explained to the makeup artists why you wanted a beard and goatee?
A: Because I was going to Knotts Berry Farm. My kids had asked me to take them to Knotts Berry Farm, and I get harassed--and I can't say harassed, but people are after me all the time when I'm in those places. so consequently I thought when I saw it there, it seemed like a good idea.
Q: Have you ever used a disguise before in public places?
A: Just sorta. Q: What do you mean by that?
A: I've used--where I've had fake casts so I wouldn't have to sign autographs, you know, sunglasses and hats and stuff in the past.
Q: Have you ever used a fake beard and goatee?
A: I've used it before but not really for public, not really out in the public.
Q: Not to disguise yourself from members of the public?
A: No. It's just if I'm doing a shoot sometime and they have them, I'll come home, and I'll wear it home and tease my kids.
Q: Had you ever taken your kids to Knotts Berry Farm before?
A: Yes.
Q: Before June 1994?
A: Yes.
Q: And to Disney Land?
A: Yes.
Q: And other public places?
A: Yes.
Q: Did you ever wear a disguise to conceal your identity on those occasions?
A: Sunglasses, fake casts on my hands, hats, yes.
Q: The fake cast on your hand wouldn't conceal your identity as OJ. Simpson. Correct?
A: It keeps me from signing autographs. It's all for the same purpose.
Q: What I am trying to find out is whether you had ever worn a disguise with your children in public places for the purpose of preventing people from recognizing you.
A: As I say, when I wear sunglasses and hats that I wouldn't normally wear. I've done that many times.
Q: And was that successful?
A: For the most part, yeah.
Q: Besides hats and sunglasses, had you ever worn any other disguises in public for the purpose of concealing your identity?
A: Halloween. Other than that, no.
Q: Other than Halloween?
A: No.
Q: How did the beard and goatee get into your black bag from its location on your desk in Brentwood?
A: I put it in there.
Q: That day? A: I would imagine so, yes.
Q: Now, from the time-
A: Not the day that I--whatever day I got it, I put it in my black bag.
Q: That's what I meant.
A: Yes.
Q: Now, from that day on, had you ever used it?
A: I don't believe it's ever been used.
Q: So you never used it. Right?
A: No.
Q: And you never opened it yourself. Right?
A: No.
Q: You looked at it, put it in the bag and left it there. Right?
A: Yeah.
Q: When did you--You said your
passport was always in your bag.
Correct?
A: Uh-huh. My travel bag, yes.
Q: This is the black leather bag we're talking about?
A: Yes.
Q: Let me show you some photographs from the trial. These are trial exhibits. What they are--and correct myself: They are photographs of trial
1 exhibits. Okay?
A: Uh-huh.
MR. KELLY: Could I step up here and see these?
MR. PETROCELLI: Yes. I don't have duplicates of these, so everybody is free to look at them.
MR. BAKER: Okay. Question?
BY MR. PETROCELLI: Q: The question, Mr. Simpson, is whether this black bag that we've been talking about, this black leather bag where you had the beard and goatee and the passport and credit cards and other items, is identified in these exhibits.
A: Yeah, this appears to be the bag, yes.
Q: Could you point to it?
A:(Indicating.) It looks like that could be the bag- Q: So for the record, you are pointing to what was marked in the trial as Exhibit 1064.
Are there other exhibit numbers there, Mr. Baker?
MR. BAKER: No. It's just 1064.
THE WITNESS: Two different bags, though.
BY MR. PETROCELLI: Q: Oh, there are two different bags on- MR. BAKER: There is a carry-on bag in 1064 as
well. It's a fold-over bag, garment bag I think it's commonly called. It has his initials on it.
BY MR. PETROCELLI: Q: How many different bags are depicted in Exhibit 1064?
A: It appears to be two.
Q: The two on the right he bottom are a different bag. Right?
A: Yes.
Q: What bag is that?
A: Different than we're talking about. That's kind of a suit carry bag.
Q: And the other photographs, 1, 2, 3, 4, are the black garment bag?
A: No.
Q: The black leather bag?
A: Grip. Grip. I use it as a briefcase.
Q: What do you call this?
A: A grip, a briefcase. I use it as basically a briefcase, but I don't carry a briefcase anymore, and it's a grip. It's a grip.
Q: Okay. And this is Exhibit 1064,the grip where-
MR. BAKER: Two-thirds of it.
BY MR. PETROCELLI: Q: Two-thirds of it is the black bag that you had with you on the evening of June 13th. Right?
A: Yes.
MR. PETROCELLI: By the way, Mr. Baker, Mr. Gelblum just informs me that these two pictures here of the garment bags are 1065, Exhibit 1065, not 1064.
MR. BAKER: Okay. Are we going to mark anything? What are we going to do relative to these exhibits?
MR. PETROCELLI: I wasn't planning on marking them again. I just wanted to use it for identification.
MR. BAKER: Well, since he identified it, I want to mark it.
MR. PETROCELLI: These exhibits are immutable since we know what the numbers are. If you have any suggestions, I have no objections, but I don't have copies of this to mark, and I will be referring to a number of trial exhibits, but maybe what we can do is later on make copies of these. How's that?
MR. BAKER: All right. I don't have any objection to that.
MR. PETROCELLI: Do you have any suggestions?
MR. KELLY: Well, I was just thinking, at some
point I think that should be marked. Even though we have a number designating them with one copy in the book, I think it would be a good idea if we have exhibit labels or something to mark them at this point in the testimony. Especially since we have multiple bags on the same
MR. BAKER: We can mark that as plaintiffs' 1 and get copies.
MR. PETROCELLI: Let me think about the logistics of that, but for now let's just mark it Plaintiffs' Exhibit 1-
MR. KELLY: Through 4.
MR. PETROCELLI: We already have plaintiff exhibit numbers for the Barbieri deposition.
MR. LEONARD: Do you want to run sequentially, or do-
MR. PETROCELLI: I don't know if that's going to be possible.
MR. LEONARD: It's your deposition.
MR. PETROCELLI: What is your practice on that?
MR. BAKER: I usually run sequentially so we're not--so we don't have Plaintiffs' 1 from- MR. PETROCELLI: I usually do also. MR. LEONARD: Anybody know -anybody have a copy?
MR. PETROCELLI: Do you have a copy from the Barbieri deposition? We will get back to marking this.
MR. LEONARD: All right.
BY MR. PETROCELLI: Q: When you went to the police station, did you bring that black bag with you?
A: Yes. Q: And that black bag went to Chicago with you?
A: Yes.
Q: Okay. And the first time that black bag left your possession when you came back from Chicago is when?
A: When I believe it was Vannatter put it in the trunk of his car . Q: Where?
A: At Rockingham.
Q: Before you went to the police station?
A: Yes.
Q: Then when you got to the police station, did you have it there?
A: No. It stayed in his car.
Q: And at some point later in the day Vannatter returned it to you?
A: Yes.
Q: Okay. And that was when you got back from the office. Right?
A: Yes.
Q: And did you look in the bag when he returned it to you?
A: Yes.
Q: Did you notice anything missing?
A: No.
Q: Okay. Did you notice anything added to it, anything new?
A: I didn't look that closely, but would say no.
Q: Okay. Why did you put the gun in the bag?
A: Because someone had--well, at the time it's because I just brought it in the house, and my house was loaded with people, and I was in my office and I just stuck it in the bag at that time.
Q: Were you the registered owner of that gun?
A: I thought I was, yes.
Q: Were you?
A: It turns out since, I have only read that it was registered to someone else.
Q: Who?
A: I don't know.
Q: How did you cause to get a gun registered in the name of another person?
MR. BAKER: Well, wait a minute. That's argumentative. Don't answer that question. That assumes that he caused that to happen.
BY MR. PETROCELLI: Q: Did you purchase that gun?
A: No.
Q: How did you come to possess the gun?
A: It was given to me as a gift.
Q: Who gave it to you as a gift?
A: I believe it was Mike Ornstein.
Q: Mike?
A: Ornstein.
Q: When did he give it to you?
A: One Christmas, I believe.
Q: Years before?
A: Possibly.
Q: And when you received the gun, did you do anything to try to get it registered in your name?
A: I was told it was registered. It was already taken care of.
Q: By whom?
A: I don't know. I didn't ask.
Q: So as of June of-
MR. BAKER: You mean who took care of the registration, or who told him that it was registered?
MR. PETROCELLI: Who took care of the registration.
Q: Do you know who did?
A: I assume Mike Ornstein had.
Q: You don't know, though?
A: No.
Q: Who told you that it was taken care of?
A: Mike Ornstein.
Q: Had you ever used that gun?
A: No.
Q: Did you keep it loaded?
A: Yes.
Q: At all times?
A: From the time he gave it to me, no.
Q: When did you load it for the first time?
A: Roughly a month previous to the deaths.
Q: And why?
A: Because I had an incident on the freeway, and I started keeping the gun in my car.
Q: Before the incident on the freeway, you did not have the gun in your car?
A: Correct.
Q: Where was it?
A: Probably in my closet.
Q: And this incident was around the 7th of May en route to Dana Point?
A: That's correct.
Q: Or Monarch Bay, I should say?
A: That's correct.
Q: Did you own any other guns in June of '94?
A: Yes.
Q: How many?
A: I don't know.
Q: Lots?
A: I would think so.
Q: Where were they?
A: Mostly in my closet. Q: More than five?
A: I don't think so.
Q: Were any of them loaded in June of '94 besides this one gun?
A: I don't believe so. One might have been, but it had a lock on it.
Q: Can you identify the guns that you owned in June of '94?
A: No, I can't.
Q: Do you know the names of them?
A: One I know is an M---I think was an M-16,and I think that was the .357, and I think there was another.
Q: Three guns?
A: I may have had some more, but I don't know. Q: Did you--beginning around I think you said the month before the deaths, you put the .357 underneath the seat of the Bentley. Is that right?
A: Yes.
Q: And did you put any gun in the Bronco?
A: No
Q: You typically drove the Bronco. Right?
A: I drove both cars.
Q: You drove the Bronco more. A: You know, depends. It just depends. At night I would drive the Bentley and--it just depends. You know, I really can't tell you which one I drove more.
Q: You can't?
A: No.
Q: The Bronco was your favorite car, wasn't it?
A: Not necessarily, no.
Q: You drove them both around the same. Correct? Is that what you're now saying?
MR. BAKER: Is that what he is now saying as contrasted to what he said before? That's argumentative. Instruct him not to answer that.
BY MR. PETROCELLI: Q: Is that your testimony, that you drove both the Bentley and the Bronco roughly the same?
A: Yeah, I would think actually roughly the same amount of time, yeah.
Q: Did you in June of 1994--let's make it more specific. As of June 12 of 1994, in addition to any guns that you had mentioned, did you own any other weapons?
A: No.
Q: Did you own any knives other than kitchen 120] knifes?
A: Yes.
Q: How many?
A: I have no idea.
Q: Where did you get those knifes?
A: I worked for a company that made knifes.
Q: What is the name of that company?
A: Forschner.
Q: F-o-r-s-c-h-n-e-r. You are on the board of directors?
A: Yes.
Q: You were.
A: Yes.
Q: Are you still?
A: No.
Q: And what kind of knifes does Forschner make?
A: I was involved with the Swiss Army knife basically.
Q: What do you mean, you were "involved" with it?
A: Well, that's what I spent most of my time trying to promote.
Q: What is a Swiss Army knife?
A: A utility knife, I believe.
Q: How big is it?
A: It depends.
Q: There are different sizes?
A: Yes.
Q: What do they range from?
A: A pocketknife to a multi-purpose larger
knife. Q: How long?
A: I don't know.
Q: What is the longest Swiss Army knife that you've seen?
MR. LEONARD: You talking about hilt and blade or blade? What are you talking about?
MR. PETROCELLI: Blade.
THE WITNESS: I'm guessing now. I'd say the big knife is two, two and a half, three inches maybe.
BY MR. PETROCELLI: Q: Have you ever seen one where the blade is six inches?
A: No.
Q: Are the only knives that you owned outside of kitchen knives these Swiss Army knives made by Forschner?
Q: I may have had a few other knives. I'm not sure.
Q: You may have?
A: Yes.
Q: Do you remember having any?
A: I remember one, but I remember having others, too.
Q: Well, how many did you have, outside of
the Swiss Army knives, as of June 12?
A: I have no idea.
Q: More than 10?
A: I doubt that.
Q: More than five?
A: I don't know.
Q: Could it be more than five?
MR. BAKER: Don't guess or speculate.
THE WITNESS: I don't know.
BY MR. PETROCELLI:
Q: Where were these knives?
A: I have no idea.
Q: What was their purpose in your having-- what was your purpose in having them?
A: We went camping a lot, and, you know, from time to time you buy a knife. So I hadn't seen them, but I bought a knife a few weeks before, a month or so before.
Q: Who went camping a lot?
A: Nicole and I and the kids over the years, my other kids, Nicole and I.
Q: And you used these knives for camping, the ones you're now referring to?
A: Nicole would buy them and--I guess.
Q: Let me be clear on this, Mr. Simpson. I
am asking what knives were in your house on the evening as of June 12, 1994 outside of knives used for eating. A: I have absolutely no idea.
Q: You described some Swiss Army knives. Correct?
A: Yes.
Q: Where were those kept?
A: Wherever. Downstairs in drawers. I give them out as gifts, so they're all over the place.
Q: Were they in boxes?
A: Most of them, yes.
Q: Each individual Swiss Army knife was in a box. Correct?
A: Yes.
Q: And they were downstairs in various places?
A: Yes.
Q: Any in your bedroom?
A: I'm sure.
Q: You get them for free?
A: Yes.
1 Q: Did the Forschner Company Ever give you any training on the use of these knives?
A: No.
Q: Now, in addition to the Swiss Army knives, you said that you owned some other knives, the number of which you cannot recall. Right?
A: I said I assumed I did. Over the years I know with my older kids, my younger kids, we have camped over the years and you buy things, and yes.
Q: Where did you keep the knives used for camping?
A: Normally outside with all whatever camping stuff we had, but I was never in charge of that so I don't know.
Q: In the garage?
A: Yeah.
Q: Did you have any other knives in the residence, outside of the garage?
A: I had one in particular that I do know of.
Q: Describe that knife.
A: It was sort of a jackknife, but it didn't have a spring.
Q: What do you mean by " jackknife"?
A: You know, when you used to push it and the knife jumps out.
Q: So when you pushed it, you have to pull it up, you mean? It didn't spring out?
A: Yeah. Well, I think you can even shake it out
Q: How long is that knife-
A: I don't know.
Q:--the blade?
A: I don't know.
Q: Where was that knife on the evening of June 12th?
A: In my--as far as I know, in my home.
Q: Where in your home?
A: In my bedroom.
Q: Was that a stiletto?
A: I don't know what -- I don't know.
Q: Where in your bedroom.
A: On a shelf.
Q: What shelf?
A: The shelf in my vanity.
Q: Can you describe exactly where in the vanity?
A: My vanity is one of these vanities with the mirrors, you can look three ways, and it was on a shelf there.
Q: Who put it there?
A: I did.
Q: When did you put it there?
A: Whenever I bought it.
Q: From the time you bought it and when you put it there, did you ever use it?
A: No.
Q: Did you ever see it?
A: Not consciously, no.
Q: Was it visible if you were standing in front of the vanity?
A: No.
Q: Where did you buy that knife?
A: Someplace downtown.
Q: Was that Ross Cutlery?
A: Could very well be, yes. Q: Was that during the shooting of "Frogman"?
A: Yes.
Q: Why did you buy it?
A: Because I liked it.
Q: You went in and browsed around?
A: Actually, my--we were there about a half a day, and my seat where they put us was virtually in the store, and various people took me in the store and tell me things that they wanted because they handled Swiss Army watches and knives, and during the course of hanging around all day I bought it.
Q: What about the knife did you like?
A: The way it looked.
Q: Was that the first time you bought a knife for aesthetic purposes?
A: I think most things that I buy are for aesthetic purposes.
Q: Is that the first time you bought a knife for aesthetic purposes?
A: I can't say that. I know in my life I've bought knives before, and I'm sure it was because aesthetically I liked it, because I'm not really a woodsman.
Q: So you have bought knives before just for souvenirs or to collect them. Right?
A: When I was a kid, you know, you buy knives or-
Q: And as an adult?
A: I'm sure I have as an adult.
Q: And whatever knives you collected over the years, if you still have them, they were in your residence. Is that right?
A: If I still have them. l don't know where they are because I haven't seen them.
Q: You haven't seen them since your release from jail?
A: I haven't seen them in years.
Q: When was the first time you remember purchasing a knife before May of 1994 when you purchased this knife from Ross Cutlery?
A: Probably the summer of 92 -summer of '91 or '92, I would think.
Q: What knife did you purchase then?
A: I don't know. It was like a Jim--I don't know if it was a Bowie. It was a hunting knife sort of thing.
Q: What did you do with it?
A: I don't know.
Q: Did you ever use it?
A: No.
Q: Where did you keep it?
A: With all my camping stuff.
Q: Where is that?
A: I don't know.
Q: You don't know where your camping stuff is?
A: No.
Q: In the garage?
A: I don't know. Nicole was the camper in the family, so--and I think she may have taken it to camp. You know, she does more camping than I do, so. . .
Q: Did you ever use the knife you bought from Ross Cutlery?
A: No.
Q: Where is that knife now?
A: I believe in the custody of you guys.
Q: The police took it?
A: No.
Q: Who took it?
A: A judge.
Q: Delbert Wong?
A: I have no idea.
Q: Was taken from where?
A: I wasn't with him. I was in jail.
Q: How do you know he took it?
A: I was told he did.
Q: Who told you that?
MR. BAKER: You don't have to get into that. That's-
BY MR. PETROCELLI: Q: Is that--I'm sorry.
MR. BAKER:--protected by the attorney-client privilege.
BY MR. PETROCELLI: Q: Is that the knife in the sealed envelope?
A: I don't know. I haven't seen the sealed envelope. Q: So it's your testimony that from the moment you bought that knife, you took it home that day, put it in that vanity and never touched it again. Is that right?
A: That's correct.
Q: Did--the week before, you were back in Connecticut. Right?
A: Yes.
MR. BAKER: The week before June 12, is that what we're talking about?
MR. PETROCELLI: Yes, Mr. Baker.
Q: You attended a board meeting at Forschner. Right?
A: Yes.
Q: And you were driven from Connecticut to Long Island, Correct?
A: Correct.
Q: By a limo driver. Right?
A: Correct.
Q: And you brought back with you from the board meeting a box of knives. Right?
A: No, that's not correct.
Q: Did you bring back with you any knives?
A: I believe so, yes.
Q: What did you bring back?
A: I think I may have brought three --two--I brought a bunch of little knives that were like team knives, because I dispensed them to--well, one friend, and I brought maybe two and I can't think of the name of this knife. It's a kind of a--it's a top-of-the-line thing with everything involved, and I brought back a lot of boxes of watches, a lot of boxes of watches.
Q: How many boxes?
A: I would say 13,14,15.
Q: And were the knives and the boxes all in one big box?
A: A bag, yes.
Q: A bag?
A: Yes.
Q: Did you pay for any of these items?
A: No . Q: They were given to you as promotional items for you to distribute?
A: Yes.
Q: Did--now I want to go back to the knives. You said that there were some team knives?
A: Yeah.
Q: T-e-a-m.
A: Yes.
Q: What are they?
A: Some of the people I was visiting when I left there are Giant fans, and they would have like the name of the Giants on them, and I gave them a knife.
Q: I see.
A: And they were for key chains.
Q: Did these knives have team names imprinted on them.
A: Yes.
Q: And you had one for a number of different teams?
A: No, because I only had two or three of them.
Q: These were football teams?
A: Giants I know because the person I was going to was a Giants fan, and I gave him one.
Q: Who was that?
A: Bobby Bender.
Q: In New York. Right?
A: Yes.
Q: He's a good friend of yours. Right?
A: Yes.
Q: And you saw him when you came back from the board meeting. Right?
A: Yes, and I gave some watches out there also.
Q: Besides these two or three team knives, did you have any other knives with you?
A: I'm not sure, but I may have taken one--I'm so sorry I can't think of the name of our top-of- the-line knife.
Q: A utility knife?
A: Yeah. I can't think of the name. There's a name for it, and I apologize. I can't think of the name of it. I may have taken one of them. But basically I'm interested in the watches. The watches are what I gave out. I had enough of the knives previous.
Q: You have to keep your voice up. You are trailing off.
A: Basically it was watches that--I think they took a list. I'm pretty sure they took a list of what I--inventory of what I took.
Q: You came out with two large white shopping bags from the Forschner warehouse. Right?
A: First, they wouldn't have been shopping bags, but I know there was at least one large bag.
Q: And you brought the bag or bags --
A: Yeah. Q:-- into the back seat with you. Right?
A: That's correct..
Q: Do you remember the name of the driver?
A: No.
Q: Does the name John Upson ring a bell?
A: No.
Q: Did you offer to give a knife or a watch to the driver?
A: I believe I did.
Q: You believe you offered?
A: I believe I gave him.
Q: What did you give him?
A: I don't recall. Probably that big- whatever you call it, utility knife thing. Probably. But I could have given him a watch, but I doubt that.
Q: Did you show the knives to Mr. Upson, the driver?
A: No.
Q: Now, you showed -- did you have with you one knife that was 12 to 16 inches long?
A: No.
Q: Are you positive?
A: Yes.
Q: Did you take that knife out and show it to him and make a stabbing motion?
MR. BAKER: Wait a minute. Don't answer that question.
MR. PETROCELLI: Why not?
MR. BAKER: Because there is no foundation for it. He just said he didn't have that knife. Now you've said, "Did you take that knife," assuming the one that's 12 to 16 inches long, "show it to him and make a stabbing motion?" We are not--
MR. PETROCELLI: It might refresh his recollection.
MR. BAKER: Yeah, right. No way he is going to answer that.
BY MR. PETROCELLI: Q: Do you recall if you took a knife 12 to 16 inches long and made a stabbing motion with it to the limo driver?
A: I know I didn't.
Q: You remember you didn't?
A: Yes.
MR. BAKER: He says he knows he didn't. How can you remember an act that you did not do?
BY MR. PETROCELLI: Q: What was the longest blade of the knives Pace 132
that you had with you and showed to the limo driver?
A: If I took one of our utility things, I would say whatever that blade is, two inch maybe, two and a half, maybe an inch and a half. I really don't know. You can get one and look at it.
Q: When showing the limo driver the knives, did you say, "You can even kill somebody with this"?
A: l never showed the limo driver the knives. I believe I may have given him one, but I didn't show him anything that I had in the bag.
Q: You did not even show him the knives you remember having?
A: I did not. I think I just gave him a gift.
Q: Did you say, "You can even kill somebody with this"-
A: No.
Q:--alluding to knives?
A: Absolutely not.
Q: Did you make four or five phone cal1s during that trip?
A: I believe so.
Q: To your friends?
A: Yes.
Q: Did you say you'd be a little late for golf?
A: Yes.
Q: You made some phone calls to your office?
A: Possibly.
Q: You looked at some papers?
A: Possibly.
Q: Fell asleep for about ha1f an hour?
A: Probably.
Q: Did you decide to change into golf clothes-
A: I'm pretty sure I did.
Q:--in the car?
A: I'm not sure, but I am pretty sure I would have tried if I had my clothes in the car, yes.
Q: With respect to any of these hunting knives or camping knives that you purchased over the years, did any of them have a blade six inches or longer?
A: I really don't know.
Q: You have no recol1ection at all?
A: No, I don't.
Q: Do you ever remember having in your house a hunting knife with a blade six inches or longer?
A: No.
Q: Do you ever remember using such a knife?
A: No. I know fishing with the kids, hunting, we seem to have always had a knife of some sort, but I don't recall when--
Q: When you have gone fishing--
A:--or what.
MR. BAKER: You have to wait until he finishes.
MR. PETROCELLI: I apologize, Mr. Baker.
MR. BAKER: Were you finished?
THE WITNESS: Yes.
BY MR. PETROCELLI: Q: When you have gone hunting or fishing, do you recall using a knife with a blade six inches or longer?
A: No, I don't recall.
Q: You don't remember one way or the other?
A: One way or the other.
Q: Okay. Can you account for all of the hunting and camping knives that you purchased?
A: No, of course not.
Q: You can't account for them. Right?
MR. BAKER: Don't answer that.
THE WITNESS: I haven't been hunting in two years.
MR. BAKER: Don't-
BY MR. PETROCELLI: Q: What kind of game do you hunt?
A: The one time I went hunting, I went hunting for birds once, and that was I would say the early '70s, and I went hunting in the '60s for deer.
Q: Did you go hunting in the '80s?
A: No.
Q: And in the '90s?
A: No.
Q: Did you go fishing in the '9os?
A: I believe so.
Q: And did you use a knife?
A: I believe so.
Q: Did it have a blade six inches or longer?
A: I don't know.
Q: Where is the knife you used?
A: I have no idea. Or the fishing poles or any of it.
Q: Let's go back to the black bag that we looked at which was marked as the Exhibit 1064 in the criminal case. When you put the gun into the bag, what did you do with the bag that evening?
A: Probably put it in my bedroom.
Q: Did you put anything else into it?
A: That night-
Q: Yes.
A:--no.
Q: Now, you left--you slept at your house that night. Right?
A: Yes.
Q: You went to the Kardashian house the next morning?
A: Yes.
Q: And took the black bag with you?
A: Yes.
Q: And did you take any other luggage with you?
A: I'm not sure. I think l took another bag, but I'm not real1y sure.
Q: Okay. And when you went to the Kardashian house with the black bag, where did you keep it while you were there?
A: I put it in a closet.
Q: In the bedroom in which you slept?
A: Yes.
Q: And did you ever go to that black bag during the time you were at the Kardashian house before you left the home on Friday morning?
MR. BAKER: And after he placed it there?
MR. PETROCELLI: Yes.
THE WITNESS: I don't believe--because I took some pictures out of it then, I don't believe so.
BY MR. PETROCELLI: Q: What pictures did you take out of it?
A: The pictures that I had carried over to Kardashian's house.
Q: These are the three family pictures you mentioned-
A: Yes.
Q:--before?
A: Yes.
Q: And you took them from your home in Rockingham.
A: Yes.
Q: And you put them in the black bag?
A: Yes.
Q: Where did you take them from in Rockingham, what location?
l A: Wherever they were. Wherever they were.
Q: In your bedroom?
A: I don't know.
Q: Put them in the black bag?
A: Yes.
Q: Did you put anything else in the black bag?
A: I think I put some socks and some underwear in the black bag.
Q: The same bag?
A: Yes.
Q: Anything else?
A: Well, the gun was in there.
Q: Anything else?
A: No.
MR. PETROCELLI: We have to change tapes now. We have to take a moment.
THE VIDE0GRAPHER: This is the end of tape No.1 of volume 1. The time is approximately 11:52, and we are off the record.
(Recess.)
THE VIDEOGRAPHER: We are on the record. The time is approximately 11 :56.This is the beginning of tape No.2 of Volume I.
BY MR. PETROCELLI:
Q: You put three photographs of your family in the black bag which you got someplace in the house at Rockingham. Right?
A: That's correct.
Q: And what did those photos depict?
A: My family.
Q: By "family," who are you referring to?
A: Sydney, Justin, Nicole, Jason, Arnelle.
Q: Each photo had all of them in it?
A: No. It was kind of a mixture.
Q: So your four children plus Nicole.
A: Yeah.
Q: And yourself.
A: And myself, yeah.
Q: And what was your purpose in putting those photos into the black bag?
A: Because I wanted pictures of my family with me.
Q: With you at the Kardashian house?
A: Wherever I was going, but, yes, at the Kardashian house.
Q: Did you anticipate taking them to jail?
A: No. I didn't anticipate being arrested.
Q: Why did you want to bring the pictures with you to the Kardashian house?
MR. BAKER: Asked and answered. Don't answer that.
BY MR. PETROCELLI: Q: Did you contemplate that you would be killing yourself?
A: No.
Q: At that point in time?
A: No.
Q: You put some socks and underwear into the black bag?
A: Yes.
Q: What was your purpose in that?
A: To have clean socks and underwear.
Q: For how many days?
A: I didn't know.
Q: And you also brought other clothing over. Right?
A: Yes, other clothes came over when I was over there.
Q: You brought some other clothing with you?
A: I think I did, but I know clothes came later on when I was there.
Q: You had additional clothes brought over?
A: Yes.
Q: Okay. When you got to the Kardashian house -- Can you remember putting anything else in this bag besides what you've already said?
A: I may have, but I don't recall. I don't think it could have held much more.
Q: When you went to the Kardashian house, you put the bag immediately into a closet?
A: I don't know about immediately, but I--before I went to sleep that night I did, yes.
Q: Did you take anything out of it to use?
A: Yes.
Q: What?
A: My overnight kit.
Q: Anything else?
A: Not that I recall. the pictures maybe. I'm not even sure If I took them out.
Q: And what about the socks and underwear?
A: Possibly, yes. Probably a pair of socks, a pair of underwear, I may have, yes, the next morning.
Q: Was this a locked closet?
A: No.
Q: A closet with a door on it?
A: Yes.
Q: And on the floor?
A: Well, I kinda--I had money in my bag, so I sort of put it under some stuff.
Q: You had money in this black bag?
A: Yes.
Q: How much money was in it?
A: A lot.
Q: How much?
A: I don't know.
Q: When you say "a lot," more than 10,000?
A: Could have been close to l0,000, yes.
Q: When did that money get into the bag?
A: When I went over to Bob's, I put it in--took it out of my pocket and put it in the bag.
Q: You had $10,000 in your pocket when you went over to the Kardashian house?
MR. BAKER: He doesn't know exactly. What he said-
MR. PETROCELLI: Roughly.
MR. BAKER: He said he approx--it could have been as much as 10,000.
MR. PETROCELLI: Approximately 10,000.
THE WITNESS: It could have been as much as 10,000.
MR. PETROCELLI: He just said it now, Mr. Baker.
MR. BAKER: He did not. He said, "It could have been as much as l0,000."
THE WITNESS: Could have been as much as 10,000.
BY MR. PETROCELLI: Q: What is your best estimate?
A: It could have been as much as 10,000.
Q: Let's call it 10,000.
MR. BAKER: Let's call it it could have been as much as 10,000. Let's call it --let's be accurate.
THE WITNESS: Yeah.
BY MR. PETROCELLI: Q: You had that money in your pocket when you went to Kardashian's. Right?
A: My pocket or my bag. I don't know exactly when I put it in the bag, but my pocket or my bag, yes.
Q: When did you get that money?
A: What do you mean?
Q: Did you have it with you when you came back from Chicago?
A: I had maybe 3,000 or so when I got back from Chicago. yes.
Q: On your person. Right?
A: On my person, yes.
Q: And when did you get the additional funds?
A: When Officer Lange walked us in my closet when I arrived back in my house with Skip Taft and with Bob Kardashian, I reached under a sweater and I pulled out roughly--roughly $6,000 and said to Officer Lange in front of Bob Kardashian, in front of Skip Taft, "At least your guys are honest. They
didn't take my money."
Q: Was there any money missing at all?
A: Well, I didn't know exactly what was there, so I wouldn't have known.
Q: Was that al1 the money you had there?
A: Yeah. Possibly, yeah. I may have had, you know, had some money spread around in other places, but that I recal1, yes.
Q: Did you have any other significant sums of cash around the house?
A: What's a significant sum of cash to you?
Q: More than a couple thousand.
A: I don't know. I real1y don't know.
Q: So you took that money and put it in your pocket?
A: At that point in time, yes.
Q: And you left it there. When you got to Kardashian's house, you put it in the black bag. Right?
A: I may have put it in the black bag before I left my house to go to Kardashian's.
Q: When you put the bag into the closet before you went into bed that night, the money was in the bag. Right?
A: The wad was, yes.
Q: Which could have been as much as 10,000. Right?
A: No. Which could have been as much as S5- or $6,000.
Q: And the 3,000 was still on your person?
A: I kept it with a couple credit cards probably in my pocket.
Q: What was your purpose in bringing that money?
A: Because it was mine.
Q: Did you plan to go anywhere or use it?
A: No.
Q: Now, did you go to the black bag at all the rest of the time you were there at the Kardashian house?
A: I'm not sure. I don't think so, but again I don't know. I was there a week. I mean, I was there three or four days, so I don't recal1 going there at all.
Q: You left he house on Thursday to go to the funeral. Right?
A: Yes.
Q: Did you go to the wake?
A: Yes.
Q: That was Wednesday?
A: I believe so.
Q: On Wednesday did you take the black bag with you?
A: No.
Q: Did you take the black bag with you to the funeral?
A: I don't think I took the black bag out of where I placed it in the closet after I put it in the closet.
Q: And did you take anything out of the black bag before you went to the wake?
A: As I stated, I may have taken a picture out. I'm not sure.
Q: And did you take anything out of the black bag before you went to the funeral?
A: I don't believe so.
Q: Okay. Now, on Friday morning, originally the plan was you were going to be driven down by Bob Shapiro to the police station. Right?
A: I believe so.
Q: At some point were you informed before you left that the plan had changed, and now the police were coming to the house?
A: I don't recall. I do know--I do recall them saying "We have to go" a few times.
Q: Now, the pictures were taken of you by the doctors upstairs. Right?
A: Yes.
Q: And that's where Shapiro was when you last saw him. Right?
A: I don't recall.
Q: When you left to go with Mr. Cowlings-
A: Yes.
Q:--where were the other people in the house?
A: I have no idea.
Q: What did you tell them you were doing?
A: I didn't tell them anything.
Q: To your knowledge where did they think you were?
A: I have no idea.
Q: Why didn't you tell them where you were at all times?
MR. BAKER: Well, don't answer that.. That's argumentative and assumes that he has some obligation to tel1 everybody where he is at al1 times.
BY MR. PETROCELLI: Q: You understood that you were about to be arrested. Right?
A: Yes.
MR. BAKER: We have been through this. BY MR. PETROCELLI:
Q: Didn't you believe that they should know your whereabouts at all times?
A: Never gave it a thought.
Q: And you never gave it a thought to te11 them that you were leaving.
A: Correct.
Q: Is it your habit to carry as much as $10,000 in cash on you?
A: Yes.
Q: You usual1y carry that much?
A: If I'm going anywhere, yes.
Q: When you went to Chicago, how much did you have on you?
A: About three. Thirty-five maybe.
Q: You said that you take that much cash, Up to $10,000, when you're going someplace.
A: Yeah, often, yes.
Q: When you left the Kardashian residence with up to $10,000 in cash, where were you going?
A: It was in my bag at that point in time, and I took my bag with me. I was going to the grave site, as I told you before.
Q: Did you stil1 have in the car the 3,000 or so in your pocket?
A: Actually I had given it, to be correct, and I am correcting myself here, I had given it all to A.C. that morning to dispense it among my kids, my older kids, and to give Paula some money to get her a flight.
Q: You gave all of what to A.C.?
A: Whatever cash, whatever checks I had from golf, I had given it to A.C. and told him that split it among my kids, and someone said about Paula's flight, and to give her a couple of thousand dol1ars for her flight.
Q: And that was the cash you had-
A: That was all the cash I had. I had --I ended up with $3 and something, I'm told, but I don't know. I just gave him all that money, yes.
Q: And you told Cowlings to spread it around among the kids?
A: No. I told him to split it between my daughter and my son, because I didn't think they would want to work at this time, and to give Paula what she needed for her flight.
Q: Arnelle and- A: Jason.
Q: Jason.
A: And to give Paula whatever she needed for her flight.
Q: And the rest of the money, the 6500 or so, was still in the bag?
A: No. I gave him all of the money. There was no money the police ever found in the bag that was over $3.63. That's a fallacy that you guys have been promoting.
Q: You gave the entire sum, up to--which could have been as high as 10,000, to Mr. Cowlings in the morning?
A: Whatever it amounted to, checks or cash, I gave to Mr. Cowlings.
a How much were in checks?
A: I have no idea.
Q: Do you have roughly any idea what the amount of checks were?
A: Absolutely none. Some of them I had had for weeks. They're from golf.
Q: When you say, "They're from golf," what do you mean?
A: Money I won playing golf.
Q: People wrote you checks?
A: Yeah. When they don't have cash.
Q: I see. And was it more than a couple thousand dollars?
A: I don't know.
Q: Could it have been as much 5,000 in checks?
A: Could have been.
Q: What is your best estimate of the total number of checks--the total amount of the checks that you gave Mr. Cowlings that morning?
A: I have no idea.
Q: Could it have been more than $10,000?
MR. BAKER: I am not--you've exhausted that. I am going to instruct him not to answer that.
BY MR. PETROCELLI: Q: When did you decide to give the money to Mr. Cowlings?
A: In the morning when I was told --after I was told I was gonna be arrested.
Q: Did any of these checks come from Mr. Thibodeau or Thibodeau?
A: I doubt it.
Q: Who were the checks from?
A: I don't know.
Q: Can you identify any of them?
A: No.
Q: They were all made out to you?
A: I don't know. Could be cash. Sometimes a guy will give you a check that somebody gave them.
Q: Okay.
MR. BAKER: I've never had that experience. I give the checks.
BY MR. PETROCELLI: Q: Were the checks in an envelope, Mr. Simpson?
A: No.
Q: Did you put--When you made the decision to leave with Mr. Cowlings, what did you decide to take with you, if anything?
A: Decide? I just grabbed my bag because it had the pictures in--and the gun in it.
Q: And when you took that bag and you went into the Bronco, did it have anything else in it besides the pictures and the gun?
A: Whatever else was in it, yes.
Q: From before.
A: Yeah. Except my overnight kit, my medication and stuff, because I don't think I was thinking about packing stuff.
Q: Was there a bottle of pills that you took with you?
A: I don't recall. Not--certainly not --my medication was not in there.
Q: Were you taking any Xanax at that time?
A: Never in my life.
Q: Was there a pill vial of Xanax found in your bag?
A: I'm told there was. Q: How did it get there?
A: I took it from Nicole.
Q: When?
A: A few weeks before this incident.
Q: Was it a prescription made out to Nicole?
A: I don't know.
Q: Where did you get it from Nicole?
A: Just from her house.
Q: The house on Bundy? A: Yes.
Q: Where was it in the house?
A: I believe in her bathroom.
Q: Which was on which floor?
A: Second or third floor.
Q: In a medicine cabinet.
A: I don't recall. Q: Did you take anything else on that occasion?
A: No.
Q: Just this one bottle of pills?
A: Yes.
Q: And why did you take it?
A: Because they were having some problems, I guess, her and Dr. Fishman, and he had some concerns, and he mentioned them to me and Nicole had mentioned some stuff to me, and I was concerned about Nicole and what she had been doing the previous few months of her life.
Q: Can you explain that more?
A: I was concerned about Nicole. She was having some problems.
Q What kind of problems?
A: I don't know.
Q: What kind of problems were you concerned that she was having?
A: I don't know. She was just not herself.
Q: How was she acting differently?
A: She was--ask her mother. I discussed it with her mother. I thought she was drinking-
Q: I'm asking you now.
A: Well, she was just not herself. She was a different person every time I talked to her. When I was in Puerto Rico, she seemed to be having a nervous
breakdown; she even said she was, and I suspected it was drinking. I had hoped it wasn't pills or drugs, which I knew her friends were involved in, and I was hoping and still hope to this day that she wasn't involved in than
Q: And how did these problems manifest themselves in her behavior toward you?
A: She was erratic. She was--from day to day I didn't know who she was. Then it didn't matter to me because I got out of the relationship.
Q: Did you ever see her manifest that behavior before in your relationship?
A: Yes.
Q: When was that?
A: Right before I went to Puerto Rico.
Q: That was about April of 1994?
A: March.
Q: Before 1994 had she ever manifested this behavior that you were witnessing?
A: Not really. No, not like this.
Q: This was the first time you saw it?
A: Well, yes, I saw it from time to time when I was back with her, but this--I felt it was out of control to the point that I discussed it with her parents, and I attempted to get her to go to
therapy again. Q: You were alarmed for her safety-
A: Yes.
Q:--and well-being?
A: Yes.
Q: And you spoke to her parents, meaning Louis and Juditha Brown?
A: Basically Judy.
Q: You call her Judy?
A: Yes.
Q: And did you say earlier, Mr. Simpson, that you spoke to Ron Fishman about this or Dr. Fishman?
A: Yes.
Q: Is Dr. Fishman Ron Fishman?
A: Yes.
Q: Why did you speak to Ron Fishman about Nicole's problems?
A: Actually it was about his problem, but at this particular time a few weeks before her death, he was having a problem, and Nicole actually called me because they were having a problem
Q: What kind of problem?
A: You'd have to ask Ron Fishman. Basically Nicole was upset with Ron. He had just left her house. She called me at my office. Ron was having a beef with his wife. Somehow Nicole was involved in it. It had a lot to do with whatever these girls were doing. Nicole was concerned and called me. I told her to get Ron Fishman's number for me. She got his number, his car number for me.I asked him to come to my office. He came to my office. He was agitated. I took him and made him drink some coffee and told him to go back to work, and I went to Nicole's house to discuss it with her.
Q: What did you discuss with Ron Fishman, if anything, about Nicole's problems?
A: Well, it was basically about his problems.
Q: What was the problem you and he discussed?
MR. BAKER: Well, I am not sure that has anything to do with this, and I am going to invoke his right of privacy and instruct the witness not to respond to those questions.
MR. PETROCELLI: Whose right of privacy?
MR. BAKER: Dr. Fishman's right of privacy.
MR. PETROCELLI: This is a conversation Dr. Fishman had with Mr. Simpson.
MR. BAKER: I am well aware of that, but I am going to stand by my instruction and instruct Mr. Simpson not to discuss anything that he discussed with Mr. Fishman relative to Mr. Fishman's problems unless it somehow relates in that conversation to Nicole's problems. MR. PETROCELLI: I think that's what he was saying, Mr. Baker.
MR. BAKER: Well, if it does, you can, but if not, then I don't think we need Mr. Fishman's problems brought into this matter.
BY MR. PETROCELLI: Q: Well, is the discussion that you had with {l4] Mr. Fishman about his problems--did that involve Nicole as well?
A: Only to the fact that when he went to Nicole that morning to discuss it with her, evidently Nicole got very agitated with him and asked him to leave and then called me.
Q: Who called you?
A: Nicole.
Q: So the sequence of events was you first got a call from Nicole saying that Fishman had come over to her house?
A: Yes.
Q: She got agitated with him.
A: Evidently.
Q: That's what she told you. Right?
A: Yes.
Q: And that--and she was reporting this to you for you to talk to Ron or
A: I guess so.
Q: She asked you to talk to Ron?
A: She was just telling me what was going on.
Q: And what did Ron tell--what did Nicole tell you about Ron's problems?
A: That's between Ron and his wife.
Q: But what did Nicole tell you about Ron's-
A: That's between Ron and his wife. I don't recall. You ask Ron or his wife.
Q: I'm a little confused. Are you saying that Nicole said, "That's between Ron and his wife," or are you refusing to tell me?
A: No. I don't remember what she told me about Ron and his wife. I don't recall what he told me about Ron and his wife. Ask them.
Q: I know. We will ask them.
A: I don't recall.
Q: But we are asking you now.
A: I don't recall.
Q: You don't recall what Nicole told you about Ron and his wife.
A: I don't recall what Nicole told me about Ron and his wife.
Q: And did Nicole tell you why she wanted you to call Ron?
A: Not really. She was concerned about him, I guess. because she relied on him quite a bit over the previous two or three years when it came to Nicole's and my divorce and I guess getting back together.
Q: She relied on Ron as a friend?
A: As a friend and as an adviser, I presume.
Q: Was Ron an internist?
A: I don't know what his practice is.
Q: Was he your doctor?
A: No.
Q: Was he Nicole's doctor?
A: As far as I know. No.
Q: And did Nicole tell you that she wanted you to tell Ron Fishman?
A: No. She just called me. I gather she was somewhat concerned and agitated.
Q: What did you then say to Ron Fishman?
A: I told him to come by my office.
Q: When he got there what did you say to him?
A: I walked him to the Starbucks, had him drink some coffee, told him to get a --same advice I gave his wife: Either to get a lawyer or get a counselor. Basically that's what I told him
Q: What day was that?
A: I don't know. A few weeks before Nicole's murder.
Q: Was it after Nicole's birthday?
A: I don't recall, but it was around that time, yes.
Q: Had you and Nicole already split up?
A: Yes.
Q: Now, what did all that have to do with the taking of the pills?
A: That was just talking about what the girls had been up to and his concern about some things and-
Q: Ron's concern?
A: About some things about what the girls were up to relative to drinking.
Q: "Girls" meaning who?
A: Faye, ---, ---, the whole group.
Q: Just so I am clear on this, during this occasion Ron told you that he had concerns about ---, Nicole Simpson-
A: About the whole group, and I think the problems-
Q: Let me finish the question. ---
A: He didn't name them all, no, but he was talking about the girls, and normally when we spoke of the girls, it was this group of girls.
Q: Describe that group by name.
A: Faye Resnick, ---, ---, Nicole, and then one or two other girls that came in and out of the group who, you know--I think ---, people who are --we knew had problems.
Q: And Ron told you that he was concerned that the girls-
A: No. Basically he was discussing, I
believe, as I recall, it was more concerning his wife, but evidently whatever was going on with him and his wife he felt was affected by whatever was going on in this group of women.
Q: And what he was telling you was an expression of a concern about alcohol or drug use by
these girls?
A: Whatever it was. I don't recall exactly what he was expressing. I as a friend was just trying to tell him not to worry about the girls, to get out of the situation, would be my advice, or take his wife--they need to go to therapy or they need to get a lawyer, which I advised her also.
Q: "Her" being whom?
A: ---.
Q: Did anything that Ron said to you about the girls have to do with drugs?
A: I think the whole tone of the conversations had to do with whatever, and drugs was obviously a part of it.
Q: Did he say to you they were taking drugs? A: No. Not specifically, no.
Q: Did he imply that to you?
A: I think it was all a part of the conversation.
a Did he tell you that he had prescribed the medication for Nicole?
A: No.
Q: Did he tell you that he gave pills to Nicole?
A: No. Nicole had told me that she was
concerned at times about who was taking what type of pills, especially Faye, and I believe she also mentioned ---.
Q: Did Ron Fishman tell you that Nicole had pills that he had prescribed?
A: No, he didn't.
Q: Now, when you went into this medicine cabinet-
A: I don't know if it was a medicine cabinet.
Q: That's right. You said you didn't remember.
A: No.
Q: Why did you take this particular bottle of pills?
A: Because I heard them talking about Xanax, and when I saw it, I took it.
Q: You heard who talking about Xanax?
A: Nicole from time to time; Faye from time to time; Ron from time to time. We knew that Faye was taking them from time to time, and I assumed they were like the new Valium or something.
Q: "Ron" being Ron Fishman?
A: Pardon me? I'm sorry?
Q: "Ron" being Ron Fishman? You said "Ron."
A: In various conversations, yes.
Q: You're saying that you had heard discussions involving Nicole and Ron and Faye about Xanax?
A: I've heard various people discuss it from time to time, and that was the Xanax seemed to be something that they discussed from time to time, yes.
Q: Did you ever talk to Nicole about her use of Xanax?
A: I talked to Nicole about her drinking more than anything, and by this time I--other than expressing my concern to her, which was difficult to do, most of my concerns about Nicole I expressed to her mother, and once I got out of our relationship, which is the early part of May, I had a long discussion for a couple days with her mother, and then after that I didn't want to hear it anymore.
Q: Did you discuss Xanax with her mother?
A: I don't believe so.
Q: Now, when you took the Xanax, did Nicole see you take it?
A: I don't re---she may have asked me, "What is that you got, a but I don't really recall. She may have. I don't recall.
Q: And what did you tell her?
A: Nothing.
Q: You took it to do what with it?
A: To take it away from her.
Q: So she wouldn't use it?
A: I don't know if she was using it or if one of her friends left it there.
Q: Did you ask her?
A: No.
Q: Do you know that the pills even belonged to her?
A: No.
Q: What did you do with them?
A: Took them back to my office.
Q: What did you do with them there?
A: Put them in my bag.
Q: Your black bag? A: Yes.
Q: Why did you put them in your back bag?
A: Because that's the bag I had.
Q: Did you ever take any of them?
A: Never, ever in my life have I ever taken a Xanax pill.
Q: Why didn't you just throw them out?
A: I don't know. They were in my office. I threw them in the bag.
Q: When you left Nicole's, why didn't you throw them in the garbage?
A: I probably would have if I would have cleaned out my bag one day, but I just put them in my bag.
Q: So were the Xanax pills in your bag from that point on?
A: I never looked to see. I have zipper areas in my bag that I never go into, so--rarely go into, so I assume they were. If they were in my bag at this point when they got my bag, I assume they stayed there since then.
Q: You never saw them again after you put the pills into your bag at your office. Is that right?
A: That's correct.
Q: Who is Naomi Fishman?
A: I have no idea.
Q: Let me show you a picture of a pill vial in the possession of LAPD, the Scientific Investigation Division, marked as their item No.158.
After the break I will figure out how to get these things put into the record.
MR. BAKER: I think it's 148.
MR. PETROCELLI: I am sorry. I misspoke.148.
Q: Did you see that photograph of the pill vial?
A: I don't recall. I just saw it there, yeah. I just saw it just now.
Q: Let me put it in front of you, SID item No. 148. Is that the bottle of Xanax that you took from Nicole's bathroom?
A: I really couldn't tell you.
Q: Does it look like it?
A: It looks like all pill vials to me.
Q: When you picked up the pill vial, did you read the name of the person to whom the prescription was made out?
A: I'm pretty sure I did.
Q: Did you know who Naomi Fishman was when you read it?
A: I don't think I registered that. I just noticed Nicole's name wasn't on it.
Q: Did you ask Ron Fishman about this pill bottle that you took?
A: No.
Q: Did you ask him how pills in the name of Naomi Fishman got to Nicole?
A: No.
Q: You never talked to him at all about the pill vial?
A: Never, ever.
Q: Did you ever ask anybody about how this got to Nicole?
A: Never.
Q: And you never asked Nicole?
A: No.
MR. PETROCELLI: It's 12:30now.We will take a break for lunch.
THE VIDEOGRAPHER: We are going off the record l now, and the time is approximately 12:24.
(At the hour of 12:24 p.m., a luncheon recess was taken, the deposition to resume at 1:34 p.m.)
(At the hour of 1:27 p.m., the deposition of ORENTHAL JAMES SIMPSON was resumed at the same place, the same persons being present.0
THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 1:27.
EXAMINATION (Resumed) BY MR. PETROCELLI: Q: Mr. Simpson, can you remember whether there was anything else in that black bag when you left Cowlings'--Kardashian's house on the 17th of June other than what you've said so far?
A: Well, I know there were things in there. I don't--you know, I always keep my credit cards, I have a whole book of credit cards that I always keep in there, and cards, business cards. It's just a folder that I keep everything in. And, you know, I hadn't done an inventory of, obviously, what's in there, but I would imagine over a period of time I put things in there and they stay in there. I've seen a list since then, so I see watches and stuff in there also.
Q: WHAT kind of watches?
A: Probably Swiss Army watches and maybe a better watch. I don't know. I'm not sure. But there were other watches. I don't remember specifically
exactly what watches.
Q: Where are the three pictures now?
A: I have no idea.
Q: To your knowledge were they confiscated by the police?
A: I would assume so. They were left in the Bronco.
Q: You took them with you?
A: NO. They were left in the Bronco.
Q: You took them when you went into A.C.'s Bronco. Is that right?
A: They were in my bag, yes, so they went with me.
Q: And that's the last you saw of those pictures: When they were in A.C.'s Bronco?
A: Yes.
Q: Never seen them again?
A: I don't recall. I don't recall seeing them again, no.
Q: Have you asked for them back?
A: I asked for everything back.
Q: Have you ever gotten those back?
A: I don't think--other than my passport and this ring (Indicating), I don't think I've gotten anything else back.
Q: At the Kardashian house, the bedroom where you slept and the closet where the bag was were the same room. Right?
A: Yes.
Q: And was that room located downstairs or upstairs?
A: Upstairs.
Q: Upstairs.
A: Yes.
Q: And where you had the examination by the doctors was also upstairs. Right?
A: I believe so, yes.
Q: Okay. When you went to Kardashian's house from Rockingham sometime on the 14th,what was your purpose in doing so?
A: To get away from the press and to see my kids.
Q: And how long were you planning to stay?
A: When I went there originally, I had no plans.
Q: You weren't planning to stay there indefinitely. Right?
A: That's what I meant: I had no plans, so that's why I didn't bring a whole lot of stuff.
Q: You were planning to stay for a couple
days and then come back. Right?
A: Yeah. Yeah.
Q: In light of that, why did you go and make a point of getting the money and bringing all that money under the sweater with you?
A: I don't understand why "all that money." I carry my money with me all the time normally.
Q: But this money was tucked away under a sweater for a rainy day. Right?
A: No.
Q: Why was it under a sweater?
A: Because I didn't want to leave it on the table.
Q: How long had that money been there?
A: Since I came back from New York where I won most of it--or a lot of
Q: Oh, the cash that was in the sweater was largely winnings from golf?
A: Not largely--oh, yeah, yes. Overall, yes, largely winnings from golf. Not necessarily over those three days, but probably over a week's period of time, yes.
Q: With friends?
A: Yes.
Q: Guys who play golf regularly?
A: Yes.
Q: ANd again, what was your reason for taking the money to Kardashian's?
A: Same reason I have for taking money wherever I go.
Q: Well, you didn't take the money to Chicago.
A: I took $3500 to Chicago.
Q: Right. So why did you go and get another 6500 and take it with you to go to Kardashian's house?
A: Because it was there, and I put it in my bag, and I didn't know how long I'd be at Kardashian's.
Q: Did you use any of the money at Kardashian's?
MR. BAKER: Other than what he has previously testified to: Giving it to Al Cowlings?
BY MR. PETROCELLI: Q: Wel1, let me ask you about that. Other than giving it to Al Cowlings, did the money go anywhere else?
A: No.
Q: Now, did Mr. Cowlings ever give it back to you? A: No.
Q: What happened to it?
A: I'm assuming that he gave it to my kids.
Q: Have you ever found that out?
A: I'm sure he told me he did, yes.
Q: DId he give any of it to Paula?
A: Yes.
Q: How much?
A: Whatever it took for her to get her a first class ticket out of L A.
Q: Did he tel1 you that he did that?
A: I think Paula may have said that.
Q: Did you see him do it?
A: No.
Q: And to your knowledge he gave the rest of the cash plus those checks to your kids.
A: My kids and--yeah, wel1, that's who I told him to dispense it among, so I'm assuming he did.
Q: And by 'kids,' you mean-
A: My older two kids.
Q:Arnel1e and Jason?
A: Yes.
Q: DId you give him instructions to give any of that money or checks to anyone else?
A: No.
Q: DId you make any arrangements at all
during that week at Kardashian's house, including all day Friday, to acquire any other cash?
A: No.
Q: Or to have anybody get any other cash?
A: No.
Q: So the only cash that you had any
interest in getting or keeping was that money in the sweater and the money you had on your person. Right?
MR. BAKER: I object. That's argumentative.
MR. PETROCELLI: Okay, I'll withdraw it. Q: The only cash that you had with you that entire week was the money from the sweater and the money you had in your person. Right?
A: Yes.
Q: And you didn't ask anybody to get any other cash from anyplace else that whole week. Is that right?
A: That's correct.
Q: And did anybody get any cash from any other sources?
A: Not to me, no. Not to me, no.
Q: Did anybody get any cash that belonged to you from any other sources?
A: I don't know. I don't know.
Q: Do you have any information that anybody
got money that belonged to you from some other location?
A: No
Q: You have no such information. Is that correct?
A: That's correct.
Q: When you--Is it fair to say that you made the decision to go to the cemetery and not wait for the police shortly before you left in the Bronco with Mr. Cowlings?
A: Yes.
Q: In other words, did you make the decision earlier in the day and decide that with Cowlings, or did you make it later in the day? How did that work?
A: Just the way you asked it. the way I answered it, is how it happened: Shortly before left, I made the decision.
Q: When you made that decision with Cowlings, where were you?
A: I think in the kitchen.
Q: And where is the kitchen: Upstairs or downstairs?
A: Downstairs.
Q: So what you had to do then before leaving was go upstairs and retrieve the bag. Is that right?
A: That's correct.
Q: Okay. And when you did so, you saw other people in the house. Right?
A: I don't think so.
Q: And you didn't--you've said already you didn't tell anybody that you were leaving. Right?
A: Right.
MR. BAKER: You don't have to answer it again.
BY MR. PETROCELLI: Q: Did you tell anybody that you were going to your bedroom to get your bag?
A: No.
Q: Did anybody see you go to the bedroom?
A: I don't think so.
Q: Did anybody see you leave the bedroom with your bag?
A: I don't think so.
Q: Where was everyone else?
A: I don't know.
Q: When you went into the bedroom, did you get anything else besides the bag?
A: No.
Q: Did you put anything into the before you left?
A: I'm not sure. If I'd taken one of the pictures out, I may have put it in the bag.
Q; Wasn't your passport on the side table?
A: No.
Q: You're positive of that?
A: Yeah. l read everything you read The answer is no.
Q: Did you read any statement by. Miss Barbieri-
A: Yes.
Q:--that the passport was on the table?
A: Yes.
Q: And she's incorrect?
A: Yes.
Q: Have you discussed that with her?
A: No.
Q: WheN you said you've read everything I've read, what have you read, Mr. Simpson?
A: I've read most of the discovery in this case.
Q: WhaT do you mean by a discovery?
A: I don't know. You tell me. Whatever discovery is. Q: You've read a number of witness statements?
A: Yes. Q: You've read the trial transcript?
A: No. Q: Any part of it?
A: No. Q: Have you read any of the transcripts of the preliminary hearing?
A: Transcripts, no. Q: Have you read any of the transcripts of the Grand Jury proceeding
A: Yes. Q: - in your matter?
A: Yes.
Q: And in Mr. Cowlings' matter?
A: Only in Mr. Cowlings' matter. don't think it was my matter.
Q: WheRe are these documents that you read?
A: I don't know.
Q: When you read them, where were they?
A: In jail.
Q: Did you read any of these documents after you got out of jail?
A: No.
Q: Did you read any of them in preparation for this deposition?
A: No.
Q: Earlier you described that--you wouldn't answer questions about certain tape recordings and video recordings, if there were any, in the presence of your lawyers or under the direction of your lawyers.
MR. BAKER: Don't answer.
MR. PETROCELLI: That's a foundational statement.
MR. BAKER: Well, it's a preamble that is absolutely vacuous of any importance.
MR. PETROCELLI: Yes. Well, the importance will now appear. Q: Who are those lawyers?
MR. BAKER: Well, you don't have to respond who your lawyers.
His lawyers are of record in this case.
BY MR. PETROCELLI: Q: Who were all of the lawyers of record in your criminal case?
A: That I know? Johnnie Cochran, Bob Shapiro, Mr. Bailey, Mr. Blaiser, Mr. Scheck, Mr. Neufeld, Mr. Oleman, Mr. Douglas, Miss Chapman. For a while Sarah--I can't think of her last name.
Then there was another person with Shapiro, and I don't remember her name, and then there's other people that came in and went, and I don't remember their names. Oh, Mr. Dershowitz. I'm sorry.
Q: Have you left anybody out?
A: I'm sure I have, but. . .
Q: Have you consulted with any of those lawyers in preparation for this deposition?
MR. BAKER: Instruct him not to answer on the attorney-client privilege.
BY MR. PETROCELLI: Q: Have you reviewed any documents in connection with this deposition, to prepare for it, I should say, in the last three weeks?
A: Yes. Q: What did you review?
A: My divorce and I believe my divorce deposition.
Q: Anything -- you said your divorce deposition. Anything else?
A: Probably Nicole's divorce deposition.
Q: Anything else?
A: I believe--I didn't read it all-the police -- the thing with the police.
Q: What thing?
MR. BAKER: Your statement?
THE WITNESS: Yes. MR. BAKER: The recorded statement?
THE WITNESS: The recorded statement, that portion of it, yes.
BY MR. PETROCELLI: Q: The statement to Vannatter and Lange?
A: Yes.
Q: Is that what you meant by "recorded statement?" A: Yes.
Q: Now, your lawyer put the word "recorded" there. Is there some other statement that was made that was not recorded?
A: A lot, yes.
Q: What are those statements?
A: Whatever the police were asking me that day.
Q: You mean there's a portion of the statement that's not recorded that you gave to the police?
A: Yes. Yes, quite a bit, as a matter of fact.
MR. BAKER: What I'm talking about is the conversations that he had with the police other-
MR. PETROCELLI: I know what you're talking about. He's talking about something differently, though
MR. BAKER: No, he is not.
MR. PETROCELLI: Let him testify. Okay?
MR. BAKER: I think I've really let him testify.
MR. PETROCELLI: I'm not complaining so far, except for a couple of parts, Mr. Baker.
MR. BAKER: I'm euphoric.
MR. PETROCELLI: I know you are. Q: Anyway, during this taping--during this statement that you gave to Detectives Vannatter and Lange, did you make statements to them during this interview that were not recorded in the written transcript that you saw later?
A: I answered whatever they asked, and there were some things that they asked there that they didn't ask-
Q: That they didn't what?
A: I answered whatever they asked, and there are obviously some things they never asked, from what I can see in the recorded statement.
Q: What I am asking you is: Was there anything that the recorded statement failed to reflect that you believe was said to them?
A: I don't understand that I'm sorry.
Q: Did the recorded statement pick up everything that was said between you and Detectives Vannatter and Lange?
A: During the time that they recorded it?
Q: During the time they talked to you in the room when they recorded it, yes.
A: During the time the recording was on, it appears to me that, from what I can recall. it recorded everything that we talked about while the recording was on.
Q: Now, was there a part of the discussion you had with them during that time that was not when the tape recording was on?
A: What do you mean? In the middle of the tape?
Q: Or the beginning or end of it.
A: Quite a bit.
Q: Quite a bit?
A: Yes.
Q: Have you ever seen any documents or tapes or any other materials reflecting what you said and what they said during those portions of the discussion?
A: No.
Q: You testified just a few moments ago that shortly before leaving in the Bronco with Mr. Cowlings, you went upstairs and got the bag, and then when you got that bag, did you then immediately go downstairs and to the car?
A: Yes.
Q: Did you stop to talk to anybody?
A: No.
Q: Okay. Had you already by this point in time given the money to Mr. Cowlings?
A: Oh, yes, l had given it to him much earlier than this.
Q: How much earlier?
A: I don't know. Shortly after I was told that I was being arrested, and I think Mr. Shapiro told me I can only have so much money or something to take, you know, downtown.
Q: So earlier that day--in the morning, I should say, you gave the money
A: Whenever he showed up, yes.
Q: Whenever who showed up?
A: A.C.
Q: And that's when you told--gave him the instructions to give it to the children. Correct?
A: Yes.
Q: The two older children.
A: Yes.
Q: Did you and Mr. Cowlings discuss what you would do after visiting the cemetery?
A: No.
Q: Did you have any plan at that time?
A: No.
Q: You didn't know where you were going to go after the cemetery?
A: I never even thought about it. I just wanted to get to Nicole's grave, yes.
Q: Have you been to Nicole's grave since you got out of jail?
MR. BAKER: Don't answer that. That's irrelevant and immaterial. I'm not going to let him get into that.
BY MR. PETROCELLI: Q: How many times have you been to Nicole's grave?
MR. BAKER: Don't answer that either.
MR. PETROCELLI: What's the objection?
MR. BAKER: Well, we're talking about obviously after he got out, and that has been a media circus, and I am not going to put OJ. through that without a court order.
MR. PETROCELLI: I am not sure I understand what you're saying, Mr. Baker.
MR. BAKER: He has attempted to visit the grave site and has been besieged, beleaguered by media people, and we're not-
MR. PETROCELLI: Let him testify to that. I didn't know that.
MR. BAKER: We are not going through it again. I don't see any relevance to whether or not Mr. Simpson has anything to do with the unfortunate deaths of Nicole Simpson Brown or Ron Goldman.
MR. PETROCELLI: It's relevant to the question of his motive to kill them.
MR. BAKER: Well, that's about as farfetched as I can imagine, but-
BY MR. PETROCELLI: Q: Let me say, since you got out of jail, have you attempted to visit the--
MR. BAKER: I'm not going to let him answer that either.
BY MR. PETROCELLI: Q:--grave site of Nicole?
MR. BAKER: It's irrelevant and immaterial to any issue in this case. I'm not going to let him answer that.
MR. PETROCELLI: Do you instruct him not to answer?
MR. BAKER: I do.
MR. PETROCELLI: Just so the record is clear, when you say, "I'm not going to let him answer," is that the equivalent to an instruction not to answer?
MR. BAKER: Yes. I'll agree to that.
BY MR. PETROCELLI: Q: Now, when you got to the grave site, were you still-- or near or outside the entrance to the cemetery, I should say, were you still sitting in the passenger side of the car?
A: Yes.
Q: At some point did you get out of the passenger side and go into the back seat?
A: Yes.
Q: When did that occur?
After we couldn't get in, we went and parked somewhere and we were waiting, and A.C. I think got out of the car, and I got in the back and laid down.
Q: Now, where did you park?
A: In an orange grove.
Q: Near the cemetery?
A: Yes.
Q: How long were you parked there?
A: I have no idea.
Q: Do you have any sense if it was a
A: No.
Q:--short time? Long time?
A: No.
Q: More than an hour?
A: I have no idea.
Q: When you parked there, did you sit in the passenger side, or did you go immediately to the back floor?
A: I didn't go immediately. I did not go immediately to the back portion of the car.
Q: Where did you go to the back portion?
A: Sorry?
Q: Where in the back did you go?
A: Just in the back of the Bronco. He had the seats where there was no back seats, and there was an area that I just laid down back there.
Q: Was the purpose of laying down so that no one could see you?
A: No. Because they couldn't see us where we were parked. l just laid down because I was tired.
Q: Did you and he have a talk in the Bronco while you were parked?
A: I can't say it was a conversation. We turned on the radio then and realized what was going on.
Q: What did you hear on the radio?
A: That they were hunting for me.
Q: And then did you at that time make a decision what to do?
A: No.
Q: So you did not immediately upon hearing that they were hunting for you decide to go back to Rockingham. Right?
A: Exactly.
Q: By hunting for you, you mean the police were looking for you. Right?
A: Yes.
Q: And you did not decide at that time to go back to the police--to go to the police station Right?
A: Right.
Q: What did you and A.C. discuss you would do?
A: Nothing. We were waiting, and hopefully the police would leave the entrance, and then I could go to the grave site.
Q: Could you see the police at the entrance from your vantage point?
A: Oh, no. No. No.
Q: Did you make a few trips to the entrance in the car?
A: No.
Q: so you were just going to wait for a while and then go?
A: Yes.
Q: Is that what you did?
A: We waked for a while. Then we began to come home.
Q: After you waited for a while, did you then go once more to check out the entrance?
A: I don't believe so. I think A.C. said he was taking me home.
Q: And you then got in the back of the car--or you were there already.
A: Yes.
Q: And he gets in and drives home. Is that right?
A: Yes.
Q: Where did he go when he left the Bronco? You said he got out?
A: I guess he went and took a leak,
something. Who knows.
Q: Just gone for a short time?
A: Yes.
Q: Did you say good-bye to him when he left?
A: No.
Q: Were you planning to kill yourself in the back of the car?
A: I don't know what I was doing. I was -- I don't know what I was thinking.
Q: At any time when you were in the passenger seat of the front of the Bronco, did you ever have your gun out of the bag?
A: No.
Q: And when you were in the back of the car, did you have your gun out?
A: Yes.
Q: And the gun was in the black bag which was in the back of the car. Right?
A: Yes.
Q: And what did you--when did you first take out the gun?
A: I don't know.
Q: Now, the gun was in a case, right that violin-like case that you described earlier?
A: I don't remember if it was still in that. I don't recall if it was still in that.
Q: Did you not take the case with you?
A: I don't recall if I took the case.
Q: What happened to the case?
A: I don't know.
Q: Did you leave the case at Mr. Cowlings'--I mean at Mr. Kardashian's house?
A: No.
Q: Did you even take the case to Mr. Kardashian's house?
A: I don't really know.
Q: When is the last time you've seen this case?
A: When-- for sure, when I was looking at it after it was taken out of my car, which would have been Monday night. Q: On the 13th.
A: Yes.
Q: So to your knowledge it's not at your house now. Right?
A: To my knowledge, it's not.
Q: When Mr. Cowlings said he was taking you back, where did you and he discuss you would be taken to?
A: We didn't have a discussion. He was talking to me to try to keep my attention on him, I think, and he got on the telephone immediately, and I think he called the police and called my home.
Q: And then did he tell you where he was taking you?
A: Home.
Q: "Home" meaning Rockingham. Right?
A: Yes.
Q: Did you ask him to take you someplace else?
A: Not in so many words, no.
Q: Did you tell him you didn't want to go back to Rockingham. A: No.
Q: Did you tell him you wanted to stay longer and wait to see Nicole?
A: No.
Q: Do you remember anything you said to him?
A: "Take me to my mother."
Q: Take you to your mother.
A: Yeah.
Q: Where was your mother living at that time?
A: Living?
Q: Where was she staying?
A: I assumed she was at my house.
Q: At Rockingham.
A: Yes.
Q: I see. So you wanted Mr. Cowlings to take you to see your mother at Rockingham.
A: Yes, basically.
Q: Why did you want to see your mother at that time?
A: Because she's my mother.
Q: You wanted support from her?
A: I wanted to be with my mom.
Q: At what point in this ride back-well, let me ask you this: Once he turned on the car to drive back to Rockingham, did you go straight to Rockingham without any stops?
A: Yes.
Q: Do you remember the route that was taken?
A: No.
a And this whole route, you were in the back of the car. Right?
A: Yes.
Q: And you were lying down. Right?
A: Yes.
Q: You were also were also on the telephone?
A: I don't recall.
Q: Did Mr. Cowlings have a cell phone?
A: Yes.
Q: Was it mounted to the car, or was it a freestanding cell phone?
A: I don't know.
Q: Did you have a cell phone?
A: Yes.
Q: Where did that cell phone come from?
MR. BAKER: I don't know what you mean, where did it come from.
BY MR. PETROCELLI: Q: You said you brought the black bag, and you didn't indicate that you brought anything else, and you haven't so far said that the cell phone was in the black bag.
A: More than likely it was in the black bag.
Q: Was it?
A: If it was in the Bronco, and I'm sure the police have it, and I had it obviously it must have been in the black bag.
Q: Okay. Well, let me ask you some questions about the cell phone. How many cell phones did you have?
A: One that I know of. I've had others, but they get ripped off. So one. One that I can think of.
Q: What was the phone number of that cell phone?
A: I don't recall.
Q: Is this a cell phone that you could use in the Bronco?
A: Yes.
Q: By putting it onto a mounted stand?
A: Yes.
Q: And when it was on the stand, it would also charge?
A: I guess so.
Q: But you could take it off the stand and use it without any cords. Right?.
A: Yes.
Q: When you took it off the stand to use, did you have to put a battery pack on it?
A: No.
Q: So you just take it right off and use it. Right?
A: Yes.
Q: Did it have a battery pack that came with it?
A: Yes.
Q: And it was attached to the back of it?
A: Yes.
Q: You could also put that same cell phone into a bracketed stand in the Bentley?
A: Yes.
Q: So you didn't have two cell phones, but one for both cars. Right?
A: Yes.
Q: Did you take that cell phone with you to Chicago?
A: Yes.
Q: And again, it had its battery pack. Right?
A: Yes.
Q: Was there more than one battery pack?
A: Yes.
Q: Did you have two battery packs in your black bag: One on the phone and a spare one in the bag?
A: I believe so.
Q: Did you-
MR. BAKER: Do you mean - at what point are we talking about? Are we talking about Chicago?
MR. PETROCELLI: On the trip to Chicago.
MR. BAKER: Okay.
THE WITNESS: Yes.
BY MR. PETROCELLI: Q: Did you have a battery charger also to charge the battery packs?
A: I don't-
MR. BAKER: You mean with him-
MR. PETROCELLI: Yes.
MR. BAKER:--on the trip to Chicago?
MR. PETROCELLI: No. I'm sorry. I'm talking about the trip to Chicago and the black bag.
THE WITNESS: No. I don't believe so, no.
BY MR. PETROCELLI: Q: WHEN you arrived back from Chicago on the morning of the 13th, you had your cell phone in the black bag. Right?
A: Yes.
Q: Were you still able to use it? In other words, did the batteries still have any charge left in them?
A: I'm not sure.
Q: You don't remember?
A: No, because I had been trying to
make a lot of calls.
Q: Do you remember having to switch battery packs during the trip
A: No.
Q:--to Chicago and back from Chicago?
A: No.
Q: And did you use your cell phone during the day of the 13th?
MR. BAKER: After he got back from Chicago?
MR. PETROCELLI: Yes.
THE WITNESS: I don't think so.
BY MR. PETROCELLI: Q: So when you got back to Rockingham and let's say before you went to the police station, the phone is in the black bag together with the spare battery charger. Is that right?
A: I believe so.
Q: And did you use it at all the rest of the week up to the Friday, the 17th?
A: I might have, but I don't know.
Q: Did you use it at all at Kardashian's house?
A: I don't think so.
Q: Okay. Do you know for a fact that the cell phone was in the black bag when you went up to the second floor to get the black bag before you left in the Bronco on the 17th?
124] A: If I had it with me in the Bronco, which I did, so it must have still been in my black bag.
Q: Did you use the phone going down to the cemetery?
A: Yes.
Q: And you used it on the way back, too. Is that right?
A: I might have. Yeah.
Q: Then is the first time that you took the gun out with the bullets in it and put it to your head?
A: And put it to my head?
MR. BAKER: Assuming he ever-
BY MR. PETROCELLI: Q: Let me ask you that question. Did you ever do so? Did you ever take the gun out of the black bag and put it --and hold it to your head?
A: I took it out, and I was laying, so I don't think I physically held it to my head, but I certainly had it out, yes.
Q: What was your purpose in taking the gun out of the bag and putting it in your hand?
A: Using it.
Q: To kill yourself?
A: Yes.
Q: Did you ever cock the gun?
A: No
Q: In order to fire that weapon, do you have to first trigger a safety device?
A: I've never fired it, so I don't know.
Q: Did Mr. Cowlings try to stop you from using it?
A: I think when he saw it is when he started telling me, "I'm taking you home," and that's when he just started the car up and started heading up the freeway. He was talking to me.
Q: And how-
MR. BREWER: Keep your voice up, please.
THE WITNESS: Okay.
BY MR. PETROCELLI: Q: Was the gun just--was the gun encased in anything in the black bag?
A: I don't recall.
Q: Was there a green towel?
A: I don't recall.
Q: Were you talking about suicide to Mr. Cowlings on the way down to the cemetery?
A: No.
Q: And when you were parking there--where did you say you were parked? In a grove of some sort?
A: Yeah.
Q: Were you talking about suicide then?
A: No.
Q: And then when you got in the back and started to head on home, did you start talking about suicide with Mr. Cowlings?
A: No Q: So on your own, that is, without bringing the subject up with Mr. Cowlings, you just reached in and took out the gun and contemplated killing yourself. Is that right?
A: That's correct.
Q: And how long did you actually keep the gun out?
A: I have no idea.
Q: When did you put it--Did you ever put it back in the bag?
A: I don't think so.
Q: Did you ever let go of it?
A: I don't recall.
Q: Did you ever relinquish it back to Mr. Cowlings?
A: No.
Q: When you left-
A: Back to Mr. Cowlings?
MR. BAKER: Yeah, I don't-
MR. PETROCELLI: Not back to him. Excuse me.
Q: Did you ever give it to Mr. Cowlings?
A: No.
Q: When you left the Bronco that evening was when you arrived at Rockingham. Is that right?
A: Pardon me?
Q: When the Bronco arrived at Rockingham m that evening is when you left it?
A: Yes.
Q: And did you have the gun with you when you walked out?
A: When I got out of the Bronco?
Q: Yes.
A: No.
Q: Left it in the car?
A: Yes.
Q: In your bag?
A: I don't think so.
Q: At that moment, coming back to go home to see your mother, why did you want to kill yourself?
A: Excuse me?
Q: When you were driving back in the Bronco to go see your mother, why did you want to kill yourself?
A: I don't think I did at that point in time.
Q: On the way back from the cemetery to Rockingham--and you testified you went to Rockingham because you wanted to go see your mother who was there. Is that right?
A: Yes.
Q: Why did you take the gun out in m contemplation of using it to kill yourself?
A: I had taken the gun out when I was in the grove and A.C. was not in the car.
Q: Why did you consider killing yourself, given that you had wanted to go see your mother?
MR. BAKER: That's pretty argumentative. You can answer why you wanted to.
THE WITNESS: You're talking two different times, too.
BY MR. PETROCELLI: Q: What are the two different times I'm talking?
A: My mother hadn't come up when I was contemplating that. When A.C. came back to the Bronco and saw me, he started talking to me, and when he started talking to me, I told him to take me to my mom, or he said, "I'm taking you home." And I said, "Yeah, take me to my mom," and he kept talking to me as he drove up the freeway.
Q: And as he drove up the freeway, though, you still had the gun out. Right?
A: Yes.
Q: Now, by the way, did you ever put the gun to your head?
A: I don't recall.
Q: How close to any part of your body did you put the gun?
A: It was laying on my chest.
Q: On your chest. Did you ever point it at yourself?
A: I don't recall doing that.
Q: Why did you want to kill yourself during the time when you took the gun out?
A: I was feeling a lot of pain, and I wanted it to stop.
Q: And what was the cause of that pain?
A: Losing Nicole.
MR. BAKER: That assumes he knows, but-
MR. PETROCELLI: He said, "Losing Nicole."
THE WITNESS: Part of it was Nicole, and part of it was just, I don't know, everything, losing Nicole. I was just feeling depressed, I guess.
MR. BREWER: Mr. Simpson, I can't hear what you are saying. I am going to reask the questions if I can't hear.
THE WITNESS: Just everything that happened that week: Losing Nicole, part of it. Just it was a tough week.
BY MR. PETROCELLI: Q: Losing Nicole, and the other part of it m was feeling attacked?
A: That was part of it, yes.
Q: Were there any other reasons?
A: Why I was--why I thought about it, no. I was on medication. Someone told me that that didn't help me at that time, but who knows why anybody does this kind of thing. I don't know.
Q: You have been attacked publicly from time to time in the past before this incident. Correct?
A: Virtually never.
Q: People have made negative comments about you in the press or in the public?
A: If they have, it's been very, very rarely.
Q: This is the first time in your life that you experienced an attack from the public?
A: First time I ever lost someone like that, yes.
Q: Well, l am not talking about the losing Nicole part of it. I am talking about the other part of it, which was feeling attacked by I think you said certain members of the press.
A: Yes.
Q: Are you saying that you never before had felt attacked by certain members of the press?
A: No, not that I felt anything. Someone criticized acting or saying I ran through the wrong hole, such immaterial stuff that I never felt anything from it, even though I was very sensitive to any criticism. Those are things I could work on. This is not something that you work on.
Q: And this attack was, as you're saying, much different. Right?
A: Yeah, it felt obviously -- obviously it was much different, yes.
Q: How was it different?
A: They were talking about--implying that I possibly could have taken a human being's life. That was different than anything I've ever experienced in my life.
Q: But you believed you were innocent. Right?
A: I don't believe nothing. I am innocent.
Q: Then you were confident that you would be acquitted. Right?
A: I didn't think I'd be arrested until then, and by then I was in so much pain for Nicole, I wasn't thinking about the police at that point. Those weren't things--being arrested was not something that was on my mind at that time.
Q: Well, at the time you had that gun out in that Bronco, though, you knew you were going to be arrested, and you knew-
A: I could care less.
Q: - and you knew the police were hunting for you.
A: And I could care less about what the police was thinking. It was how I was feeling, and that's why that gun was out, is because I felt I was in a lot of pain and I couldn't handle it at the time. I didn't feel I could handle it at the time.
Q: Was the pain of losing Nicole so great that you were prepared to deprive your children of their parents?
MR. BAKER: Don't answer that. That is outrageous.
MR. PETROCELLI: I am trying to understand the witness'-
MR. BAKER: I don't care what you're trying to do. That's an outrageous argumentative question, and he is not going to answer it.
MR. PETROCELLI: You instruct him not to answer?
MR. BAKER: You bet.
BY MR. PETROCELLI: Q: Well, let me ask you this: Before you went in that Bronco, had you made arrangements with anyone for the care of your children?
A: Well, yes.
Q: What arrangements did you make?
A: What arrangements. There are certain people that I asked to, you know, see if they can help if anything came up with my kids.
Q: You mean to help in case you killed yourself. Is that what you mean?
A: That was a possibility, yes.
Q: I just want to understand what you're saying. When you say "if anything came up," I just want to make sure I understand what you're saying.
A: Yes.
Q: Okay. And who were those people?
A: Mainly Wayne Hughes and I believe Louis Marx.
Q: Who is Louis Marx?
A: A businessman.
Q: Friend of yours?
A: Yes.
Q: And Wayne Hughes?
A: Businessman who is a friend of mine.
Q: What arrangements did you make with Mr. Hughes about your children?
A: Not an arrangement. I just asked him to look after my kids, to make sure that--whatever. If something happened, look after my kids.
Q: And by the "kids," are you now referring to Justin and Sydney?
A: Yes, and probably also to an extent my older kids.
Q: Did you tell Mr. Hughes to financially provide for them.
A: No.
Q: Help guide them and give them counsel?
A: Whatever. Whatever I-- whatever.
Q: Did you give him any specific instructions?
A: No.
Q: What about Mr. Marks? What did you tell him regarding your kids?
A: Pretty much the same thing.
Q: And who did you understand would be caring for your children?
A: At that point I would assume, and I didn't really give it a lot of thought, but I would assume Lou and Judy Brown.
Q: Did you-
A: Or Arnelle Simpson and my family.
Q: Or Jason?
A: No. More Arnelle and my family.
Q: Did you have any discussions with the Browns those days that you --something might happen to you and that they should take care of the children?
A: No.
Q: Or with any member of Nicole's family?
A: Other than whatever brief conversation I had with Lou when I first got in the Bronco. Other than that, no.
Q: Are you talking about Mr. Cowlings' Bronco?
A: Yes.
Q: On the 17th?
A: Yes.
Q: And you called Lou?
A: Yes.
Q: Tell me about that discussion.
A: I don't remember the discussion. You should ask Lou.
Q: Do you recall it?
A: I recall that I spoke with him, yes.
Q: You don't remember what you said?
A: No.
Q: Do you know why you called him?
A: Not really, no. I called Nicole's house, and Lou was there.
Q: When you called Nicole's house, it was to speak was to speak to Lou. Right?
A: Not really. I didn't know who would be there. If Judy was there. I'd speak to Judy, or whoever. I was not that--well, whoever.
Q: Did there come a time, Mr. Simpson, when Mr. Cowlings made the decision to take you back to Rockingham to see your mother, that you decided to put in effect the gun away and you weren't going to use it?
A: I never thought about it.
Q: You never made that decision clearly in your mind?
A: I don't think I did anything rationally that day.
Q: You were irrational that day?
A: Well, I think any time you have a gun on your chest, you're being irrational, yes.
Q: Have you ever acted irrationally before in moments of severe crisis?
A: Severe crisis?
Q: Is it fair to say that you were in a period of severe crisis the week of June 13?
MR. BAKER: Well, I am going to object. That's a characterization and instruct him not to answer that question.
BY MR. PETROCELLI: Q: Did you feel that you were in a severe family crisis or personal crisis that week?
MR. BAKER: You can describe what you felt.
THE WITNESS: I felt pain, actually, when I was in the Bronco going to --I felt at peace at that point in time, the day of the 17th, once I got in the Bronco and was going down there, but most of the week I was--I don't know. I think I was obviously a little confused and in pain.
BY MR. PETROCELLI: Q: What made you feel at peace?
A: I don't know. I just felt at peace.
Q: When you have experienced severe personal pain in your past before, have you acted irrationally?
A: Yes.
Q: On when--on what occasions?
A: When my father died. When my baby drowned.
Q: What did you do irrational on those occasions?
MR. BAKER: I am not going to let him get into it. I think that's totally irrelevant and immaterial. Instruct him not to answer.
BY MR. PETROCELLI: Q: Who else--Was the first call you made in that Bronco to Lou Brown at Bundy?
A: I believe so.
Q: Who else did you call?
A: I don't know. I know Lou-- I mean I know Wayne and I know--I know Louis and Wayne, and other than that, I don't know.
Q: You had spoken to Louis and- Marks and Wayne Hughes from the Bronco?
A: I believe so.
Q: You had also spoken to them earlier in the week. Right?
A: I don't know. I don't recall. Q: Did you call anybody else besides Mr. Marks, Mr. Hughes and Lou Brown?
A: I may have, but I really don't recall.
Q: If you felt at peace in that Bronco, why did you want to kill yourself?
A: Because that's why I felt at peace: I thought all my pain was about to end.
Q: You felt that peace in contemplation of dying?
A: I felt at peace that I was going to stop feeling the way I was feeling.
Q: Is it fair to say that virtually all of the pain you were feeling came from the loss of Nicole?
A: Obviously it was the--yeah, the genesis of it all, but I would say the --yes, I would say that had a lot to do with it, yes. Yes.
MR. PETROCELLI: Let me attach as the next exhibit in order, which would be Plaintiffs' 6-
MR. LEONARD: Are you passing out copies?
MR. PETROCELLI: Yeah.
MR. LEONARD: That's what I need.
MR. PETROCELLI: Do you want to mark this as 6.
(Plaintiffs' Exhibit 6 was marked for identification by the reporter and is attached hereto.)
BY MR. PETROCELLI: Q: Mr. Simpson, before I show you this document, whatever happened to the amendment to the will that you wrote?
A: I don't know.
Q: Have you ever seen that again?
A: No
MR. KELLY: I'm sorry. What has this been stamped? Exhibit --
MR. PETROCELLI: 6.
MR. KELLY: 6.
BY MR. PETROCELLI: Q: Did you discuss with Mr. Cowlings during this Bronco ride the question of who killed Nicole?
A: No, I don't think we had any discussion of it, no.
Q: Did Mr. Cowlings ever ask you whether you did?
A: I think I told him I didn't, and I don't think he ever questioned me about it after that.
Q: He initially asked you, and you said you didn't?
A: I don't think he ever asked me. I think I may have just said it to him early in the week, and I don't think he ever asked me about it after that.
Q: Did you speak to Mr. Cowlings at all in preparation for this deposition?
A: Not at all.
Q: You still see him on a regular basis?
MR. BAKER: I don't know what "regular basis" is.
BY MR. PETROCELLI: Q: Frequently?
A: I saw him--as an example, I ran into him on Montana Street three days ago, and then I had seen him maybe 10 days previous to that and then maybe a week previous to that. So if that's frequent
Q: Are you still close friends?
A: Oh, yes. Oh, yes. Even before this happened, I played golf and he didn't, so we really didn't see each other that much, but we talked from time to time, but he 's still my best friend.
Q: Okay. I have placed before you a document marked as Exhibit 6. Do you recognize this?
A: Yes.
Q: What is this? Can you identify it?
A: It's a letter I wrote that day, I guess.
Q: It's a letter you referred to earlier when you said you wrote down your thoughts?
A: Yes.
Q: Is this letter entirely in your handwriting?
A: Yes, I believe so.
Q: Is the date of the letter in your handwriting?
A: Yes. Q: And all the characters?
A: Yes. Q: Are all of the cross-outs in your handwriting?
A: Probably, yes.
Q: For example. look at the next to last page.
A: Yes.
Q: Are the cross-outs at the bottom of the bottom of the page in your handwriting? Let me ask: Did you cross out the material --
A: Pretty sure.
Q: --at the bottom of the second to the last page?
A: Probably.
Q: Any doubt in your mind?
A: I know I was in a hurry and there were a lot of things that I spelled poorly, that didn't come out quite the way I wanted to say it, and I just resaid it.
Q: Do you know what you wrote here at the bottom that you crossed out
A: No.
Q: --on the third page?
A: No.
Q: Have you ever tried to translate that for someone?
A: This is the first time I've looked at this since then.
Q: You didn't look at it throughout your criminal trial?
A: No.
Q: Now, it's dated 6-15, which is Wednesday, but you've testified you wrote this on Friday. Is that right?
A: Yes.
Q: Why did you date it on the 15th?
A: I guess I was just guessing at the date, and I was alone and I didn't ask anybody what the date is.
Q: Is it clear in your mind that you wrote this entire note on the 17th, that Friday?
A: Yes.
Q: And how long before you made the decision--Let me ask you this: Did you write this note after you made the decision to leave with Mr. Cowlings?
A: No. No. But I did--no.
Q: When you made the decision to write this note, were you still planning to turn yourself in?
A: I don't know. I don't really think so.
Q: Did you have any idea--With drawn. When you wrote this note, you were expressing thoughts consistent with the idea that you would kill yourself. Right?
A: Yeah. Yeah.
Q: And when you wrote this note, Exhibit 6, did you have any sense of how you would do that?
A: I must have, but I can't give you any conscious thought, but I must have, yes.
Q: Did you have a sense of when you would do so?
A: Yes.
Q: When was that?
A: Before I left Bob's house.
Q: Before the police came. Right?
A: Yes.
Q: When you awakened that morning did you- Withdrawn. When was the first time you were told that you would be arrested?
A: Early that morning.
Q: On the 17th?
A: Uh-huh.
Q: Who told--You have to answer yes.
A: Yes. I'm sorry.
Q: And who told you?
A: Bob Shapiro and Bob Kardashian.
Q: Do you remember what time it was?
A: No.
Q: Where were you when they told you?
A: I was in bed.
Q: They got you out of bed?
A: Yes.
Q: When you got out of bed, do you remember what you did next?
A: No. No.
Q: Take a shower?
A: I'm sure I did.
Q: Got dressed?
A: I'm sure I did.
Q: Did you eat breakfast?
A: I don't know.
Q: Did you write this letter before or after the doctors examined you and took the photographs?
A: I could have been writing parts of it during the time they were doing that.
Q: I see. Now, this morning Miss Barbieri was present with you. Right?
A: Part of-- well, she was in the house, yes.
Q: You wrote this letter before she left. Right?
A: Yes.
Q: And when she left, you had no idea whether you would ever see her again. Right?
A: Yes.
Q: Did you and she discuss that, that this might be the last time?
A: No.
Q: Did you and she said good-bye?
A: I told her to go to Florida and find some nice guy.
Q: And was that a tearful parting?
A: The whole week was tearful for me, and I think--yes, I think she got pretty emotional at that time.
Q: You wanted her to go back to Panama City?
A: Yes.
Q: And that's why you--Did you give Miss Barbieri the money yourself, or did Mr. Cowlings give it to him-her?
A: No. A.C.
Q: How did A.C. get the money?
MR. BAKER: I think we've been over that at least three times.
BY MR. PETROCELLI: Q: You said-
MR. BAKER: Don't answer that.
BY MR. PETROCELLI: Q: Here is what I am asking you: You said that the money was in the black bag which is in the closet. Now, Miss Barbieri left before you left the house. Correct.
A: Yes.
Q: How did Mr. Cowlings get the cash to give to Miss Barbieri?
A: I gave it to him.
Q: So you went to the bag, took out some money, counted out a sum of money and gave it to Al?
A: No.
Q: Explain what you did.
A: I went to the bag, took everything that was in there that looked like it was money and gave it to Al.
Q: At that point.
A: At that point.
Q: And Paula was still there. Right?
A: She was in the house, I'm sure.
Q: How long before she left did you do that?
A: I don't know.
Q: Do you know what the two words that are crossed out after the word "understand" on the first and second line?
MR. BAKER: What page are we on?
MR. PETROCELLI: I am sorry. Page 1, "First everyone understand," and then there are two cross-outs. Q: Do you know what those words are?
A: I don't think they're words. They're probably just-
MR. BAKER: Looks like this has been cropped a little, too.
THE WITNESS: Yeah, I can't tell, but they don't look like they're words to me.
BY MR. PETROCELLI: Q: You addressed this "To whom it may concern."
A: Yeah.
Q: WhO did you have in mind by addressing the letter that way?
A: To whom it may concern.
Q: Did you intend that this be read to the public?
A: No, but I wasn't going to write individual letters to everyone who's named in here, so I thought to whom it may concern.
Q: Did you tell anybody to read this
A: No. --to the public?
A: No, totally not.
Q: There is a reference in this letter about the Goldman family.
A: Uh-huh.
Q: If I could find it.
MR. BAKER: Bottom of page-
MR. PETROCELLI: 3.
MR. BAKER:--3.
BY MR. PETROCELLI: Q: It says, I'm sorry for the Goldman family. I know how much it hurts." Do you see that?
A: Yes.
Q: You-- Did you ever meet Ron Goldman?
A: Not that I know of.
Q: Did you ever talk to Ron Goldman?
A: Not that I know of.
Q: Did you ever see Ron Goldman?
A: Not that I know of.
Q: Did you ever hear Ron Goldman's name mentioned prior to his death?
A: No, not that I know of.
Q: Did the name Ron Goldman mean anything to you prior to his death?
A: No.
Q: Did you ever--did anyone ever point him out to you?
A: No.
Q: Did anyone ever point out a person whom was not identified to you by name but who you later discovered was Ron Goldman?
Q: Not that I have any knowledge of.
Q: You have no knowledge of ever seeing him or hearing of him, whether by name or otherwise, before his death. Is that right?
A: No. That's correct.
Q: That's correct?
A: Yes.
Q: So everything you learned about Ron Goldman was after he died, from the news reports. Is that right?
A: Till this day?
Q: No. Up till the date you wrote this letter on the 17th of June.
A: I didn't know anything about him. Yes, that's correct.
Q: Had anybody -- prior to Ron Goldman's death, had anybody ever told you that he was someone who was seeing Nicole?
A: No.
Q: Did you have any knowledge of any kind that he was in a relationship with Nicole?
A: No.
Q: Did you have any information or knowledge that he was a friend of Nicole's?
A: No.
Q: Did Nicole ever mention him to you?
A: No.
Q: Had you ever been to the Mezzaluna restaurant before June 12, 1994?
A: Yes.
Q: Had you ever seen him there?
A: Not that I would know of.
Q: So when--You've seen photos of him since his death. Correct?
A: Yes.
Q: At the trial, for example?
A: Yes.
Q: When you saw a photo of Ron Goldman, did you--was there any recognition that you had ever seen that person before?
A: No.
Q: Since Mr. Goldman's death, has anyone ever told you about any relationship between Ron Goldman and Nicole?
A: No.
MR. BAKER: Don't-
BY MR. PETROCELLI: Q: Anyone other than lawyers.
A: No. No.
Q: Have lawyers told you that?
MR. BAKER: Don't answer that.
BY MR. PETROCELLI: Q: Have you read anything to that effect?
A: I may have.
Q: What did you read?
A: I believe in some discovery and possibly in Faye Resnick's book.
Q: Did you read Faye's book?
A: Yes.
Q: Did you read Mr. Kaelin's book?
A: I don't think Mr. Kaelin had a book.
Q: Oh, Mr. Elliot's book about-
A: No.
Q: Did you read any of these other books that are out?
A: No.
Q: Just Resnick's-
A: Yes.
Q:--and just Elliot's?
A: I didn't read Elliot's.
Q: You didn't read Elliot's, just Resnick's.
A: Yes.
Q: What are the discovery materials that you're referring to?
A: Just interviews from various people.
Q: What do you remember having read about Mr. Goldman and Nicole?
A: I think Faye Resnick, that he liked her and she liked him as a friend, I believe was how it was described.
Q: That was from an interview of Faye Resnick?
A: Yes.
Q: Other than that interview, whatever it said, do you know anything about any relationship between Ron Goldman and Nicole?
A: No.
Q: Now, you signed this letter at the end with a happy face on it. Do you see that?
A: Yeah.
Q: You weren't feeling happy at the time. Right?
A: No.
Q: Why did you do that?
A: I just wanted people to remember me that way.
Q. As a happy person?
A: As I was most of my life until that week and maybe one or two small instances in my life, I've been a happy person.
MR. PETROCELLI: I think we'll break here-
MR. BAKER: Okay.
MR. PETROCELLI:-- and resume --Because of the court appearance, we are not able to resume this afternoon, Mr. Baker. Is that right?
MR. BAKER: Yeah, I think that would be best, and we'll start at 9:00, if that's agreeable to everybody.
MR. PETROCELLI: Okay.
THE VIDEOGRAPHER: This concludes the deposition of Orenthal James Simpson, Volume I. The number of videotapes used was two. We are going off the record, and the time is approximately 2:24.
(Plaintiffs' Exhibits 4 (A-D) and 5 were marked for identification by the reporter and are attached hereto.)
(ENDING TIME: 2:24 P.M.)
I DECLARE UNDER THE PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.
SUBSCRIBED AT
CALIFORNIA, THIS DAY OF , 19 .
ORENTHAL JAMES SIMPSON