Simpson Deposition - February 23, 1996

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS LOS ANGELES

SHARON RUFO, Plaintiff,

v.

ORENTHAL JAMES SIMPSON et al. Defendants

FREDRIC GOLDMAN, et al. Plaintiffs,

v.

ORENTHAL JAMES SIMPSON, et al. Defendants

LOUIS H. BROWN, etc., Plaintiffs

v.

ORENTHAL JAMES SIMPSON Defendant

VOLUME VII Continued videotaped deposition of ORENTHAL JAMES SIMPSON, taken on behalf of the Plaintiffs at 11377 West Olympic Boulevard, 10th Floor, Los Angeles, California commencing at 10:54 am, on Friday, February 23rd, 1996, before David S. Coleman, CSR #4613 pursuant to Court Order.

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

Today's date is Friday, February 23rd, 1996. The time is approximately 10:54. 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 for Plaintiff Fred Goldman.

MR. GROMAN: Arthur Groman for Plaintiff Fred Goldman.

MR. BREWER: Michael Brewer for Plaintiff Sharon Rufo.

MR. KELLY: John Kelly for Plaintiff Brown.

MR. PHILLIP BAKER: Phil Baker for O.J. Simpson.

MR. LEONARD: Dan Leonard for Mr. Simpson.

MR. ROBERT BAKER: Bob Baker, held hostage, Day 7, for O.J. Simpson.

ORENTHAL JAMES SIMPSON, having been previously sworn, was examined and testified further as follows:

EXAMINATION BY MR. PETROCELLI:

Q: Mr. Simpson, I would like to talk a little bit about your background. You grew up where?
A: San Francisco.

Q: And you left San Francisco when?
A: 1967.

Q: You went to junior college in San Francisco?
A: That's correct.

Q: San Francisco City College?
A: That's correct.

Q: And then in 1967 went off to University of Southern California?
A: Yes.

Q: Now, when you were a youth, were you involved in any gang fights?
A: Yes.

Q: Were you a participant?
A: Yes.

Q: Did you use a knife in any of those?
A: No.

Q: What weapons did you use?
A: Fists.

Q: Other than using your fists, did you have any--involved in any physical confrontations with other instruments?
A: I think we ran a gang off the hill once with rocks, throwing rocks at them.

Q: What age--how old were you when you were involved with gangs as a youth?
A: 13, 14, 15.

Q: Couple of years?
A: Yeah.

Q: Were you put into some institution or reform school at all?
A: No.

MR. ROBERT BAKER: You know, this is so remote and I've been, I think, more than lenient, but I am not going to let you ask him any more questions about when he was 13, 14, 15 years old.

MR. PETROCELLI: Well, that was my last question.

MR. ROBERT BAKER: Good. Good. We're on the same wavelength.

MR. PETROCELLI: We're on the same wavelength on that one.

Q: When you--you went to USC for two years. Right?
A: Yes.

Q: And graduated in 1969?
A: I didn't graduate.

Q: Oh, you left school in 1969.
A: Went to work, yes.

Q: Okay. And you then went into the NFL as a professional football player?
A: Correct.

Q: And that was your employment until when?
A: 1979.

Q: And between 1969 and 1979 did you have any other employment besides playing professional football?
A: Yes.

Q: What was that?
A: I couldn't name them all, but I worked for Chevrolet; I worked for RC Cola; I worked for Hertz; I did films and various other deals that came and went.

Q: What did you do for these manufacturers?
A: Commercials.

Q: And you were a spokesperson?
A: Correct.

Q: Okay. To endorse their products?
A: Correct.

Q: Did you--You also said you acted in some films?
A: Yes.

Q: How many films have you appeared in?
A: I don't know.

Q: Can you name them?
A: A few of them.

Q: Could you name them, please.
A: THE CLANSMAN, TOWERING INFERNO--

MR. KELLY: I'm sorry. I can't hear you, Mr. Simpson.

MR. PHILLIP BAKER: TOWERING INFERNO.

THE WITNESS: CASSANDRA CROSSING, FIREPOWER, THE NAKED GUN trilogy, COCAINE AND BLUE EYES, GOLDIE AND THE BOXER, and there's others that I just can't recall.

BY MR. PETROCELLI:

Q: COCAINE AND BLUE EYES is one movie?
A: Yes.

Q: And what's the last one you mentioned?
A: I don't know. What was the last one I mentioned?

MR. KELLY: I'm sorry. I'm still not hearing you.

THE WITNESS: I'm asking him a question. THE REPORTER: GOLDIE AND THE BOXER.

THE WITNESS: GOLDIE AND THE BOXER.

BY MR. PETROCELLI:

Q: In any of these--Is that it, Mr. Simpson?
A: Yes.

Q: Okay. In any of these roles that you played, did you use a knife?
A: In the movies I just mentioned?

Q: Yeah.
A: Not that I recall.

Q: Are there any others where you used a knife?
A: In FROGMAN.

Q: That's the only one?
A: That I know of, yes.

Q: How many TV pilots other than FROGMAN have you filmed?
A: I think COCAINE AND BLUE EYES was a pilot, I believe.

Q: Did you film a pilot called 1ST AND 10?
A: No.

Q: Did you work on that project?
A: What do you mean? A pilot project of 1ST AND 10?

Q: Yeah.
A: No.

Q: Did you have anything to do with a property called 1ST AND 10?
A: Yes.

Q: What?
A: I acted in a series called 1ST AND 10.

Q: It was a sitcom?
A: Not really, no.

Q: How long was it on the air?
A: The years that I was on, I think we were on three or four years. I'm not sure.

Q: You had a recurring role?

Q: What years were those?
A: In the '80s.

Q: Okay. Do you know someone named Eddie Reynoso?
A: No. I may have, but I don't know.

Q: Now, the movies that you've acted in, that started sometime when?
A: I don't understand the question.

Q: When did you begin to appear in motion pictures or television films?
A: 1969.

Q: And that continued all the way until what point in time?
A: 1993.

Q: What was the last--The last project you filmed was FROGMAN?
A: '94. Yeah, '94 it would have been FROGMAN.

Q: FROGMAN?
A: Yes.

Q: And before FROGMAN, one of THE NAKED GUNs?
A: Yes.

Q: Okay. Now, when did you first go to work for a television broadcasting company?
A: It was '69 or '70.

Q: What was the company?
A: ABC.

Q: And what was your job?
A: I was a commentator, color commentator.

Q: During the off-season?
A: Yes.

Q: Okay. For football games. Right?
A: Not so much football. It's probably more track. I mean, I did Irish hurling, Irish football, you know, whatever.

Q: And how long did you work for ABC, that first stint?
A: I don't know. You know, I'm sure we can give you my--Cathy Randa would send people my-- what do you call that?

Q: Resume?
A: Resume.

Q: Okay, I would like to have it.
A: Yeah, because I don't know all this stuff.

Q: Let me just follow up generally. You don't remember when you stopped working for ABC the first stint?
A: Not really, no.

Q: Okay. And what was your next broadcasting job?
A: I signed with NBC in the late 70s, but it wasn't really for sports, even though I would have done the Olympics if they weren't aborted in Moscow, and I may have done a Rose Bowl or so for them. I was more producing film, producing TV shows for them.

Q: Which shows did you produce?
A: GOLDIE AND THE BOXER, GOLDIE AND THE BOXER GO TO HOLLYWOOD. COCAINE AND BLUE EYES, DETOUR TO TERROR.

Q: Are these films that you also would appear in?
A: Yes. HIGH FIVE was one I didn't --I produced and didn't appear in. It was a pilot.

Q: Have you directed any film?
A: No.

Q: After the NBC production job, what was your next television job?
A: I believe Monday night football.

Q: What years were those?
A: It was in the '80s.

Q: In the '80s?
A: Yes.

Q: Okay. That was with ABC. Right?
A: Yes.

Q: And then after that what came next?
A: NBC.

Q: When was that?
A: I believe it started in '89.

Q: And that was still going on as of the time of Nicole's death?
A: Correct.

Q: Okay. Have you had any professional acting training?
A: No.

Q: Ever taken an acting course?
A: No.

Q: You ever take any courses or take any training in connection with your work as a spokesperson, an actor or commentator?
A: Voice lessons.

Q: You mean diction?
A: Yes. My voice diction.

Q: How long did you do that?
A: On and off for a few years.

Q: Who did you study with?
A: Arthur Josephs, and I can't think of the other guy's name. I see he still uses me in his advertisement, but I can't think of his name.

Q: Who taught you how to act?

MR. ROBERT BAKER: There's a lot of people who say no one. Sorry, O.J.

THE WITNESS: I don't know.

MR. PETROCELLI: You said it, not me.

THE WITNESS: I don't know.

BY MR. PETROCELLI:

Q: In the course of--In other words, when you did your film role, you didn't have any training before that; you just showed up and they told you what to do, and you did it?
A: No. They--I read the script, and I acted like I thought the person acted. Most of my acting roles are not too far from me, you know, so pretty much played myself personality-wise.

Q: And worked with the directors of those various films?
A: Correct.

Q: And other actors on them?
A: Yes.

Q: Okay. Now, are there any other companies that you've endorsed products for besides Chevrolet, Hertz and RCA?
A: I'm sure there are.

MR. KELLY: I think it was RC Cola.

MR. PETROCELLI: Oh, RC Cola. You're right.

Q: Any others come to mind?
A: No.

Q: Did you have contracts with these companies I just mentioned?
A: Yes.

Q: And did you have contracts for these other companies for sort of long-term sponsorship or endorsement work?
A: I don't know if it was long-term but those are the ones I recall that had any kind of length of time.

Q: As of the time Nicole died, which endorsement contracts were still in effect?
A: Hertz.

Q: Was that the only one?
A: Basically, yes. I don't recall. There may be something that I'm not thinking about right now, but that's basically it.

Q: Was there any economic fallout as a result of the 1989 incident?
A: No.

Q: Did any of the companies threaten to cancel contracts?
A: No.

Q: Did they discuss that with you?
A: No. No. No.

Q: Was there any suggestion by them that there might be a problem with one of your contracts
A: No.

Q: --during that period of time?
A: No.

Q: And did the subject come up at all in your dealings with these companies in the year 1989?
A: I probably discussed it with the chairman of Hertz.

Q: And what did you tell him?
A: I don't recall.

Q: Was he concerned about your public image?
A: I don't know. He talked to Nicole, because we went on a vacation with them later that month, so

Q: Month of January?
A: Yeah, at the end of January we went on vacation with him.

Q: What's his name?
A: Frank Olson.

Q: Excuse me? Frank Olson?
A: Yes.

Q: Okay. We are having trouble hearing you this morning, and I'm very close to you. Was there any economic fallout as a result of your divorce proceedings in 1992?
A: No.

Q: Was there any discussion with any of your employers or companies for whom you were endorsing products, about your divorce?
A: I probably alerted them that I was getting a divorce, yes.

Q: Did you discuss with Nicole that if she testifies in the divorce case, it might hurt you economically?
A: No.

Q: The subject never came up?
A: No.

Q: And did she bring that up with you.?
A: No. I wanted her to testify.

Q: Why did you want her to testify?
A: Because I wanted the truth to come out.

Q: About what
A: Whatever they were alleging.

Q: Isn't it the case that when she was about to testify, you took her into the hallway and insisted that she not?
A: No. The day she was supposed to testify, she didn't show up. She was in contempt of court; didn't show up.

Q: And is it your testimony that you had no conversation with her at all or through your lawyers with her to not testify?

MR. ROBERT BAKER: Don't answer that. He is not going to answer about what his lawyers did.

MR. PETROCELLI: What his lawyers said to Nicole or her lawyers.

MR. ROBERT BAKER: He not going to answer--if it went from him to the lawyers, he is not going to answer that question.

MR. PETROCELLI: I don't want that one.

MR. ROBERT BAKER: Okay. You want just if you know what your lawyers said to Nicole or her lawyers relative to her testifying, you can answer.

THE WITNESS: I don't think we ever said anything to her about testifying. I know I didn't. I told her, you know, "You can't not testify," when she didn't show up. "You have to show up."

BY MR. PETROCELLI:

Q: You said I think yesterday and also in your video that if Nicole did not file for divorce, you would have.
A: Yes.

Q: Why is that?
A: Because I didn't want to go a long period of time, and I was paying would have to pay temporary alimony. I didn't want to go a year and then decide we wanted to divorce and then go another year trying to get the divorce. So I just said--I figured it would take a year almost, I was told it would take a year almost to get a divorce as it were, and I figured in that length of time, if we didn't want a divorce, we wouldn't; and if we did, at least it's over.

Q: Well, if Nicole had indicated she did not want a divorce in January-February, are you saying you were going to file anyway?
A: I gave her an ultimatum: Either she files or I was going to file.

Q: So you made up your mind you were going to get divorced one way or the other?
A: Well, not get divorced. File and get the process going.

Q: And then see if it works out during the process?
A: Yeah. Yeah. During the process if we didn't, we didn't.

Q: Nicole was having an affair with someone at around this time, wasn't she?
A: I found out, yes, that she was, yes.

Q: You were trying to find out before the actual separation. Isn't that true?
A: What do you mean, "separation"?

Q: When you and Nicole separated when she left Rockingham
A: Yes.

Q: Before she left Rockingham you were trying to find out from her friends if she was having an affair. Right?
A: I asked her.

Q: And you asked her friends, too. Right?
A: No. I asked her.

Q: You asked Cora Fishman.
A: I asked Cora Fishman much later.

Q: You did not ask Cora Fishman before Nicole moved out of Rockingham whether Nicole was having an affair with anyone?
A: That's correct.

Q: Okay. And the only person you asked was Nicole?
A: Yes.

Q: And she told you what?
A: At that time she told me no.

Q: And you later found out that was untrue. Right?
A: Correct.

Q: You found out she was having an affair with Alessandro. Right?
A: That's what she told me, yes.

Q: And when did you first find out?
A: When she was trying to get back with me.

Q: In 1993. Right?
A: Yes.

Q: And you didn't know before then. Right?
A: No.

Q: You were--before Nicole moved out of Rockingham you were upset that this fellow Alessandro was coming over to the house and eating your expensive caviar and drinking your champagne. Isn't that right?
A: No, that's incorrect.

Q: Didn't you say that to Cora Fishman?
A: After--this was a year later I said that to Cora Fishman. After I found out they had and affair. I was a little put out that he was at my house on Christmas having champagne and caviar with me and they had been having an affair.

Q: This is a conversation you had with Cora in 1993?
A: Yes, after I found out that there was an affair. Up to then I didn't know that there was an affair.

Q: Okay. So Nicole's infidelity had nothing to do with your splitting up with her. Right?

MR. ROBERT BAKER: Now, what are you talking about?

BY MR. PETROCELLI:

Q: In other words, when you and Nicole split up, you had no state of mind that she was having an affair with anyone. Is that right?
A: In 19--

Q: '92.
A: In '92 she instigated that. I didn't instigate that.

Q: Yeah, I know. But when she instigated it, you didn't have any knowledge or information that she was having an. affair then or ever. Is that right?
A: Correct.

Q: Okay. Now, after the 1989 incident you and Nicole had several arguments about your infidelity. Is that right?
A: After?

Q: Yeah.
A: No.

Q: After January 1, 1989
A: No.

Q: --you and Nicole have a single argument or discussion about your being unfaithful?
A: I don't know what she may have talked to the psychologist about but we didn't discuss it after that, no.

Q: --After the '89 incident until the time that she moved out. there was no conversation between the two of you about your seeing other women or being unfaithful. Is that right?
A: Correct.

Q: Okay. Were you faithful during that period of time?

MR. ROBERT BAKER: You don't have to answer that.

BY MR. PETROCELLI:

Q: Were you seeing any other women during that time from January '89 to the time that you and Nicole split up in early '92?

MR. ROBERT BAKER: You don't have to answer that either.

BY MR. PETROCELLI:

Q: You said on your video that Nicole knew how to push your buttons. What did you mean by that?
A: Well, I think people who have been together a long time, they know each other pretty well, you know, push buttons. I don't know. She knows that I don't like leaving clothes around, and if she's upset, she leaves her clothes around. You know, just little things. It was nothing really particularly, but I think people know--I would imagine your wife knows how to get on your nerves, and you probably know how to get on her nerves.

Q: How did Nicole get on your nerves besides not being neat and orderly?
A: I don't know. Nicole was not a communicator at times. Sometimes she'd vent but not discuss, I think probably more than anything bothered me.

Q: That personality trait?
A: Yes.

Q: Anything else?
A: Nothing I can think of right now. I'm sure--

Q: And how did you press her buttons?
A: She hated the fact that I'm a leaver. You know, I will take off at times, and that would bother her, if she was venting at me and I would just take off. I think more than anything in the years we were together, that's the thing that she expressed to me that irritated her the most.

Q: Did she ever express to you that you were too controlling for her?
A: Yes.

Q: And that you were too possessive of her?
A: What do you mean 'for her'? She just thought I was a controlling a person.

Q: Controlling--She told you that. Right?
A: Yes.

Q: Okay. And did she tell you you were obsessive towards her?
A: No.

Q: Or possessive?
A: No.

Q: When Nicole got mad at you would she scream at you?
A: At times, yes.

Q: Was it a frequent occurrences
A: No.

Q: Okay. Would she insult you?
A: I mean, in the years that I've known her, I believe she has, yes.

Q: And would she use profanity towards you.?
A: At times.

Q: Now, when she did that, did you feel like hitting her?
A: No. I'd leave.

Q: Okay. Did you scream back at her?
A: At times.

Q: And use profanity.
A: At times.

Q: Did you break things?
A: No. See, that's something that I don't do.

Q: You never threw anything on the floor or smashed photographs or broke things. Is that right?
A: No. No.

Q: How many times in your relationship with Nicole when you were having an argument with her did you find yourself out of control?

MR. ROBERT BAKER: If ever.

THE WITNESS: To me, when I think of '89 when I was trying to get her out of the room that's something that I wouldn't have normally done. So in a sense I felt that I was not in control the way I would have liked to have been.

BY MR. PETROCELLI:

Q: And what about any other incidents?
A: No.

Q: What about 1993? Were you out of control then?
A: No. Q Okay. And how many times in your relationship with Nicole did you observe in your view that she was out of control?
A: I can't answer that.

MR. ROBERT BAKER: Are you talking just about arguments, not about when she was having her nervous

MR. PETROCELLI: Yes, arguments.

Q: Arguments with you.
A: I couldn't--I couldn't--I'm sure there were times that I thought, you know, she needed to slow down or at least to stop and sit and think about what she was saying, but I can't specifically name them

Q: Because they're too numerous?
A: No. I just can't specifically--you know, it's just spread out over a lot of years.

Q: But you told me that in your case there was only one time.
A: Uh-huh

Q: Now I am asking about Nicole. Are you saying that it was more than once?
A: Well, when you say "she was out of control"

Q: Yeah.
A: --I mean, my interpretation of that may be different than anyone else. I would leave whenever I thought it was mindless, so in a sense to me the situation was out of control and I'd leave.

Q: How many times did that occur?
A: I can't--I have absolutely no idea.

Q: More than a dozen?
A: Probably over the years, yes.

Q: More than a hundred?
A: No, certainly not, no.

Q: Somewhere between twelve and a hundred.?
A: Yes.

Q: Can you make it any closer than that?
A: No.

Q: Other than Alessandro, are you aware of any extramarital affairs that Nicole had?

MR. ROBERT BAKER: You don't have to answer that. it's been asked and answered, and I think

MR. PETROCELLI: You are instructing him not to answer?

MR. ROBERT BAKER: I am.

MR. PETROCELLI: Okay.

MR. ROBERT BAKER: Since we know Mr. Fuhrman has the right of privacy, I think Mr. Simpson has as well.

BY MR. PETROCELLI:

Q: Was sex an important part of your relationship with Nicole?
A: Yes.

Q: And you enjoyed having sex with her?
A: Yes.

Q: Did you ever have violent or rough sex with her?
A: No.

Q: Did Nicole ever complain to you about your need for excessive attention or admiration?
A: No.

Q: That subject ever come up?
A: No.

Q: Did Nicole ever tell you that you were a manipulator?
A: Say it to me?

Q: Yes.
A: No.

Q: Did she say you were the king of manipulation?
A: No.
A: Okay. She said it to others, I take it, about you?
A: I heard Kato say that in a deposition.

Q: Is that the first time you ever heard that?
A: I may have read it in a deposition of Kato's before, too.

Q: Have you always been close to your mother?
A: Yes.

Q: Is that the closest relationship with a woman that you've ever had in your life?

MR. ROBERT BAKER: Well, I don't know what you mean by "close." I mean. If you're talking just on an emotional basis

MR. PETROCELLI: Yeah.

MR. ROBERT BAKER: --ask the question.

BY MR. PETROCELLI:

Q: That's what I mean.
A: You know, I can't answer that. I had a different type of emotional relationship with Nicole and Marquerite that was as intense and satisfying as I've had with anyone. A mother is a whole different thing.

Q: You said in the video that your mother is your most favorite person in the world. Is that right?
A: Yes.

Q: And was that true throughout your life?
A: Yes.

Q: Did your mom raise you?
A: Yes.

Q: Was your father present in the home?
A: Not in the home, no.

Q: During your entire childhood?

MR. ROBERT BAKER: You don't have to answer that. This is way too remote.

MR. PETROCELLI: You've instructed him?

MR. ROBERT BAKER: Yes.

MR. PETROCELLI: Let me mark this and make it a little easier. This is a transcript of the 911 call. 98.

[Plaintiffs' Exhibit 98 was marked for identification by the reporter and is attached hereto.]

BY MR. PETROCELLI:

Q: Can you turn to ine 15, where Nicole says, "Then he came and he practically knocked my upstairs door down." Is that true?
A: No.

Q: You didn't knock the upstairs door down?
A: No.

Q: Or did you bang on it really hard? I knocked on the door. I think that's on the tape, isn't it? This is a transcript of the tape?

MR. ROBERT BAKER: This is the other one.

THE WITNESS: Pardon me?

MR. ROBERT BAKER: This is the other one.

THE WITNESS: You hear the whole thing on the tape.

BY MR. PETROCELLI:

Q: I want--I am asking you what's true and what's false that Nicole said.
A: You listen to the tape, and you'll hear that that's false. I knock on the door and asked, "Why is the door locked?" And she's talking to the police officer on the tape that I heard saying, "He wants to know why the door's locked, and then he went back downstairs."

Q: Did you pound on that door?
A: I knocked on the door.

Q: Knocked or pound?
A: I would say knocked.

Q: Okay. Did you knock real hard?

MR. ROBERT BAKER: Don't answer that.

BY MR. PETROCELLI:

Q: Yes or no?
A: I don't recall.

Q: Okay. Did she try to get you out of the bedroom because the kids were sleeping in there?
A: I never went in the bedroom. The door was locked.

Q: Okay. Did she try to get you to go downstairs because the kids were sleeping upstairs?
A: I would say no.

Q: Okay. Now, Nicole says on line 20 that you "wanted somebody's phone number," and she gave you a phone book.
A: Yes.

Q: Is that true?
A: Yes.

Q: What phone number did you want?
A: I wanted phone numbers of this girl that Nicole--of a girl named Alex and of Keith Zlomsowitzh.

Q: And why did you want their numbers?
A: Because I wanted to know what was going on with these people around my kids.

Q: You were going to call them up?
A: Yes.

Q: Did you.?
A: No.

Q: Did you get the phone numbers?
A: No.

Q: Okay. Did you have an argument with Nicole that day about her having a former boyfriend's number on her speed dial?
A: No.

Q: Joseph Perulli in particular?
A: No.

Q: That never came up?
A: No.

Q: On any other day did that come up?
A: No.

Q: On ine 10, Mr. Simpson, it says, "I had to read this bullshit all week in the National Enquirer."
A: Yeah.

Q: That statement is attributed to you. You said that. Right?
A: I may have.

Q: And what was the Enquirer article about?
A: I think--I believe the situation they were talking about this whole this whole--because I didn't--I was in--I don't know what it's about. but it wasn't about that week. It was about you. Right?
A: Yes.

Q: And something in that article upset you.?
A: Yes.

Q: And what was it?
A: It was just something some of her friends I were saying about her--First of all, I didn't want to be in the article, but it wasn't this week. This was something that had happened previous to this.

Q: Well, okay. Answer this question first, and then I will get back to the timing issue: What was it in the article about you that upset you?
A: It was just this implication that I Nicole--O.J. was begging Nicole to get back together and Nicole didn't want to, and her friends were saying O.J. wanted her to move back in the house but Nicole didn't want to, and it was just so the opposite of that, so--it was just so 180 degrees opposite of that, that that bothered me.

Q: To whom were those comments attributed in the Enquirer?
A: I don't know, but I'm sure it was one of her friends. To a friend of Nicole's, is who it was attributed to.

Q: And had that article come out in the week before this October 25 incident?
A: No.

Q: When had it come out?
A: I think earlier, maybe August.

Q: Why were you reading about it all week?
A: Well, I don't think that's correct, the way this is. I think we were venting about a lot of things, you know. This argument started about one thing and, like most arguments, you go into tons of things in the midst of an argument so...

Q: Okay. In cole states at line 15 that you were going--that, quote, "He's going"-- excuse me. "He's fucking going nuts." Is that a fair description of your behavior?

MR. ROBERT BAKER: Don't answer that.

BY MR. PETROCELLI:

Q: In your mind, were you going nuts?
A: No.

Q: Okay. How many arguments had you had with Nicole in the course of your entire relationship with her when you were screaming and yelling as loud as you were on October 25, 1993?
A: That may have been the best one.

Q: So in your entire relationship you don't think it ever happened?
A: No, not like this, no.

Q: Okay. I am reading from a brief your lawyers filed in the criminal case. It's with regard to this incident. It says you kicked in a French door to gain entry. Is that true?

MR. ROBERT BAKER: Don't answer that. You asked him that 15 times. He is not going to answer it again.

BY MR. PETROCELLI:

Q: Did you kick in a door to gain entry?

MR. ROBERT BAKER: Don't answer it. Don't answer the question.

BY MR. PETROCELLI:

Q: What I want to understand, Mr. Simpson, is whether you had permission to get into that house from Nicole or whether you broke in without her permission.

MR. ROBERT BAKER: We are not going to get back into that. You've been there and done that.

MR. PETROCELLI: You don't have to make speeches. Just instruct him, and we will move on.

MR. ROBERT BAKER: I didn't think that was a speech.

MR. PETROCELLI: I don't take it personally, Mr. Baker.

MR. ROBERT BAKER: I understand that. I'm not trying to have you take it personally, Mr. Petrocelli.

MR. PETROCELLI: I know, but, you know, you make a lot of comments about things that I do that are not true, and I don't feel the need to respond, and so maybe it would be better if you didn't make them.

MR. PHILLIP BAKER: What comments are those, Dan?

MR. PETROCELLI: See the above.

Q: At any time from 19---January 1992 until the end of Nicole's life,did you ever say to Nicole that you have no reason to live now?
A: No.

Q: Did you ever say that to anyone?
A: No.

Q: Were you ever so despondent about your relationship--
A: Oh, I--No, no. I didn't.

Q: Up to the time Nicole died.
A: No. No.

Q: Were you ever so despondent about your relationship with Nicole that you told someone that you didn't want to live or didn't have any reason to live?
A: No.

Q: Did you at any time ever say to Nicole-- Withdrawn. During the last six months of Nicole's life, did you at any time say to her words to the effect, "I don't know what I'm going to do if I see you with another man"?
A: No.

Q: Did you ever say that to her?
A: No.

Q: Did you ever say that to Judy Brown?
A: No.

Q: Did you ever say at any time during the last six months of Nicole's life: "If I ever see you with another man, I'll kill you"?
A: No.

Q: Did you ever say that at all?
A: No.

MR. ROBERT BAKER: You're up, candy man.

MR. PETROCELLI: No. not quite.

MR. PHILLIP BAKER: You want to take a break to call Steve?

MR. PETROCELLI: No. Let me mark as the next exhibit in order, 99, this letter.

[Plaintiffs' Exhibit 99 was marked for identification by the reporter and is attached hereto.]

BY MR. PETROCELLI:

Q: Take a look at Exhibit 99. Do you recognize this document, Mr. Simpson?
A: Yes.

Q: Is this in Nicole's handwriting?
A: Yes.

Q: This is a letter to you. Right?
A: Yes.

Q: And is this the letter that she sent to you or gave to you in mid March of 1993?
A: Yes.

Q: When she delivered the tapes of the wedding and your child's birth?
A: Yes.

Q: What did you do with the original of this letter?
A: I don't know. It's somewhere in discovery or with someone, I guess.

Q: Did you respond in writing to this letter?
A: No.

MR. PETROCELLI: I need to find something. Take a short break.

MR. ROBERT BAKER: Okay.

THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 11:33.

[Recess.]

THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 11:40.

BY MR. PETROCELLI:

Q: Getting back to your background for a minute, what promotional or other videos did you make in the year 1994?
A: The Playboy video, a Playboy by-- basically what it was supposed to be was a traveling man's, the lazy man's workout.

Q: That's the Playboy video?
A: Yeah.

Q: Is that where you're shown exercising?
A: Yes. Stretching basically, yes.

Q: Did you keep the clothing that you wore in that video?
A: No, unless it was mine.

Q: Was it?
A: I don't recall.

Q: And what about this Juice Plus, what was that about?
A: It was a concentrated--it's where that they flash-dry juice. I couldn't drink juice because of my arthritis, but juicing is very good for you. My arthritis--acidity in orange juice and stuff is stuff that irritated my arthritis, and this is a way that they could flash-dry it so you can get all the nutrients and things that you would get in normal juice. It was really the juice itself, it truly was oranges and, you know, carrots and everything, and it condensed into a powder and it condensed into a pill so you can--it was equivalent--if you take this, it's equivalent to drinking fresh juice because it was truly fresh juice.

Q: You were paid by a company to promote this product?
A: Yes.

Q: And how long were you--What is the name of the company?
A: Juice Plus was the product. The company is National Safety Association, I think, something. I can't--

Q: What did you do for them? Went around making speeches?
A: Yes, I made a few speeches for them, yes.

Q: How long before Nicole's death were you involved with Juice Plus?
A: I don't know.

Q: More than a year?
A: I don't think so.

Q: Did you make any videos for them?
A: I didn't really--I don't believe so. I think they may have video'd me speaking at various events. I don't recall doing a video for them.

Q: And when was the last--
A: I may have done a video. I don't recall.

Q: When was the last event you spoke at for Juice Plus?
A: I believe in Dallas.

Q: And when was that?
A: I don't know. I don't recall.

Q: In 1994?
A: I believe so.

Q: Is that the one you saw in court?
A: I believe so, yes.

Q: Okay. How long have you had arthritis?
A: I became aware of it--I've had it a while, but it got intolerable probably around '90, I mean when I felt like I was being crippled by it.

Q: In 1990?
A: Around '90 or so.

Q: Who treated it?
A: I first went to Frank Jobe, and it was Frank Jobe. who was possibly the top orthopedic person, who felt it was arthritis more than what he could do, and he sent me to Bertram Maltz.

Q: In the early '90s?
A: Yes.

Q: And was Dr. Maltz treating your arthritis up until the time of Nicole's death?
A: Yes, basically. yes.

Q: And what treatment did he prescribe for you?
A: The main thing he did is he started me on a medication calls Azulfidine, and I also went to a nutritionist who treated it a little differently, about me changing my diet. So I changed my diet and things got better.

Q: And when did things get better?
A: I mean at times. You know, right now things are better, but I do have relapses, you know. But the pain portion of it, things sometimes get better. The stiffness and everything is still there, but the pain got better. I mean, the pain was almost intolerable at one point.

Q: In 1994 before you went into jail, was the pain ever intolerable?
A: Maybe once or twice, but not for any length of time.

Q: And did your arthritis flare up at all in June of 1994?
A: Possibly, yes.

Q: When?
A: I couldn't say explicitly.

Q: And did you have a--was it in an acute phase on June 11 or June 12?
A: Acute, I can't do anything. When it's acute, I need help to go to the restroom so I would say no.

Q: Was it acute at any time in 1994?
A: To that degree, not that I recall.

Q: Okay. And what was the state of your arthritis condition on June 11 and June 12?
A: I had traveled. When I travel--I play a lot of golf always, but when I travel and play golf, it's--bothers me more. So, I would say more than-- My feet were bothering me then more than almost anything, but it was--and I had some swelling.

Q: Swelling of where?
A: My joints a little bit and my fingers, and my knees always a little bit.

Q: You had swelling in your joints on June 11 and June 12?
A: A little bit, yes.

Q: Did you seek any special treatment on those days?
A: I may have taken--some days I don't take Motrin, and I probably took Motrin those days.

Q: Do you remember doing so?
A: I'm sure I did.

Q: Were you inhibited in your ability to do any activities on June 11 and June 12th because of arthritis?
A: You mean was I inhibited in doing or inhibited that I couldn't do?

Q: That you couldn't do.
A: I couldn't really shuffle cards. I could deal them, but I had trouble shuffling them. But that happens to me quite often.

Q: You played cards both Saturday and Sunday?
A: I believe so.

Q: June 11 and June 12?
A: I believe so.

Q: Did you shuffle when it was your turn?
A: I don't think I shuffled Sunday. Saturday, I don't recall.

Q: Did you deal the cards?
A: Yes.

Q: Okay. And you played golf Saturday, Sunday and were planning to play on Monday, and Tuesday perhaps. Right?
A: I try to play every day.

Q: So the arthritis doesn't prevent you from playing golf. Right?
A: Just handicaps my game.

Q: Okay. Was your arthritis bothering your golf game on the 11th and the 12th?
A: It always bothers my golf game. If I didn't have--

Q: More than usual, I mean.
A: I don't know. I think the traveling and all, I was probably a little stiffer, but I travel so much that that's not unusual, so--so, I mean, I play with the handicap.

Q: Did you do anything for the swelling in your joints other than take some Motrin, perhaps?

MR. ROBERT BAKER: I don't know if Motrin is for swelling.

THE WITNESS: It's not.

MR. ROBERT BAKER: It's for pain.

MR. PETROCELLI: For pain. Well, let me rephrase the question then.

Q: Did you--other than taking some Motrin, did you do anything at all for your arthritis on June 11 and June 12?
A: You know, everything--I mean, I don't know how to answer the question because virtually everything I do, before I go play golf, stretching; sometimes I wear sleeves on my knees. I've had various--various analgesics, and I do this all the time. So virtually everything I do is for my arthritis. Otherwise I'd get up, do a stretch and go play golf. One of the reasons I get up so early is, because of my arthritis, it takes me a longer time than most people to stretch to, you know, be able to function.

Q: Did you wear sleeves on your knees on June 12?
A: I may have on my left knee. Not on the 11th, I'm sure, but probably on the 12th.

Q: Did you take any medications besides the ones you described? One was Motrin, and the other one was this other drug you mentioned.
A: I don't think I was taking the Azulfidine during this period of time.

Q: So you weren't taking any prescribed drugs at all for arthritis on June 11 and June 12. Is that right?
A: I don't think so, yeah.

Q: And you don't--You may have taken some Motrin.
A: I'm sure I took Motrin.

Q: Okay. And did you receive any particular medical treatment for your arthritis on those two days?
A: Other than the Motrin, no.

Q: Is Dr. Maltz the only doctor who treated you for arthritis in the '90s?
A: Other than the nutritionist.

Q: What's the nutritionist's name?
A: Oh, jeez. Well, I'm embarrassed. She has a line of vitamins out. Maybe ---I can't think of her name. I can get it for you easily.

Q: Okay. Is there a name for the arthritis that you have?
A: From what they told me, I have--well whatever is normal arthritis that I think many athletes might sustain, and then there's rheumatoid, and I was showing signs of rheumatoid arthritis.

Q: When did you start showing signs Of rheumatoid arthritis?
A: You'd have to ask them. I just went by what Dr. Jobe and what Dr. Bertram Maltz told me.

Q: Okay. Did you tell Nicole in May or June of 1994--Withdrawn. Did you have a conversation with Nicole in May or June of 1994 when she said in words or in substance to you, "How dare you buy my friends. How Come you're buying my friends?"
A: In substance--when she called me and yelled at me, in substance that's what she was saying.

Q: Did she also say to you, "You took my friends away. You took my family"?
A: No.

Q: She never said anything like that to you--
A: No.

Q: --in those same conversations?
A: No.

Q: Okay. And what did you understand her to mean when she was talking about your buying her friends?
A: I'd say in substance--I don't think she used that word, but in substance she was saying something about "Leave my friends alone" and stuff, and I didn't know.

Q: Had you just entered into any financial deals with any of her friends?
A: I don't understand the question.

Q: Had you made any business dealings with any of her friends in the three months before she died?
A: Well, Christian I consider my friend also, and Christian performed a service for me and he was paid for that service.

Q: When did you make this deal with Christian?
A: I can't say that we made a deal. He and I three or four months previous to this started working on this possible--a possible project, yeah. I would say we started about three, four months before June.

Q: Was that the Playboy video?
A: Uh-huh.

Q: Yes?
A: Yes.

Q: So Christian was involved in that?
A: Yes.

Q: And he got paid?
A: Yes.

Q: Who paid him.?
A: I did.

Q: How much did you pay him?
A: $5,000, which was just sort of a-- $5,000.

Q: When did you pay him the $5,000?
A: Probably in May.

Q: In--
A: After I did the video.

Q: --1994?
A: Yes.

Q: Was that the first business dealing you had with Christian Reichardt?
A: You know, it depends how you look at it. He did a lot of--I went to his office often, so, you know, if that's business, that was business.

Q: Was that the first time you paid him any money,
A: I just can't recall if we paid him for helping--he--I don't know if I paid him or if he did it as a friend for some--you know, some chiropractic work that he did for me.

Q: Was that the first time you recall paying him any money.?
A: Yes.

Q: Okay. Did Nicole say to you in May or June of 1994, "If you really want this marriage to work out, you're gonna have to go to therapy to control your anger"?
A: No.

Q: Anything like that?
A: No.

Q: Did she ask you to go see a therapist in May or June of 1994?
A: No.

Q: Did you see a therapist in May or June of 1994?
A: Yes.

Q: This is after you and she split up on Mother's Day. Right?
A: Yes.

Q: You saw Burt Kittay?
A: I talked to Burt.

Q: Is that the therapist you're talking about?
A: Yeah.

Q: You talked to him on the phone?
A: Yes.

Q: How many times?
A: I don't know.

Q: This is between Mother's Day and Nicole's death.
A: I don't know.

Q: More than once?
A: I don't think so, but possibly.

Q: Were these professional consultations or just friendly conversations?

MR. ROBERT BAKER: Well, when you say you talked to a therapist--

MR. PETROCELLI: They could be talking to play golf.

MR. ROBERT BAKER: Okay. If there is anything about psychotherapy, that's what he wants to know.

THE WITNESS: Possibly.

BY MR. PETROCELLI:

Q: You're not--Excuse me. You're not sure?
A: Any conversation I may have had with him would have been in connection with Paula, so possibly.

Q: Not in connection with Nicole?
A: Not in connection with Nicole.

Q: Did he charge you.?
A: I don't know.

Q: Okay. How long were the conversations?
A: I don't know. I know I joined him and Cathy at lunch once, and other than that, as I said, I don't have no real memory of flat-out talking to him about--for service.

Q: Where was the lunch?
A: At a place called--I believe it's called the Marquis West.

Q: Where is that?
A: Right out here, over here somewhere next to his office.

Q: Where is his office?
A: Was on Santa Monica Boulevard.

Q: And tell us about that conversation.
A: I don't think I want to tell you about if it was professional conversations that he and I had.

MR. ROBERT BAKER: If Cathy was there, it's waived.

THE WITNESS: Yeah, well, I don't recall exactly what--Cathy was there, and we were talking about the food, you know, and I may have asked his opinion about Paula, how to make things easier with-- you know, for Paula, what I should look for, because I knew I had hurt her before.

BY MR. PETROCELLI:

Q: It's your testimony that the--you did not discuss at all Nicole in that conversation?
A: I believe not. I may have mentioned that, you know, Nicole and I was through, but any conversation I had with him wasn't really concerning Nicole.

Q: And when you were talking about Paula--
A: I may have. Now, I'm not sure if I did at all, but I'm almost positive I would have brought Paula up if Burt was there.

Q: Can you tell me anything else that was said in that conversation?
A: No.

Q: How long was it?
A: I don't know. I came; they were having lunch. and I left and they were still having lunch.

Q: Is that the only time you specifically remember talking to Burt Kittay during this time frame of May and June of 1994?
A: Yes. I may have talked to him on the phone once coming from Palm Springs.

Q: Weekend of Memorial Day?
A: Yes.

Q: By the way, during that weekend did you have the children on Thursday and Monday.?
A: Of what weekend?

Q: Memorial Day weekend '94.
A: Maybe Monday but not Thursday. I didn't have them Monday. I think Sydney came by Monday. But Thursday, no.

Q: And Friday.?
A: No.

Q: But maybe Monday?
A: Maybe Monday.

Q: Who set up this meeting with Burt Kittay?

MR. ROBERT BAKER: Which meeting you talking about?

MR. PETROCELLI: The lunch meeting.

THE WITNESS: I don't think it was set up. I think I went to the office, and Cathy said she was going to lunch with Burt, if I wanted to join them and I said if I had time I would, and I think I did spin by. They were already having lunch. I picked off their plates and left.--

BY MR. PETROCELLI:

Q: Earlier you said that this was a conversation about professional consultation. You didn't want to describe it to me. What did you mean, "professional consultation"?

MR. ROBERT BAKER: He said it may have been.

THE WITNESS: It may have been. I'm not sure if I brought up Paula. I'm pretty sure I would have brought up Paula, and I may have asked for advice from him about that.

BY MR. PETROCELLI:

Q: What advice?
A: I'm sorry. What?

Q: What advice did you ask him?
A: About how to make it easier for Paula and what I should look for, because in getting back with Paula, I had hurt her before and, you know. I guess it was a trust issue.

Q: When you and Paula got back together during this time frame, did you and she have any discussions about Nicole?
A: No.

Q: Did she say to you in words or in substance, "I'm concerned about resuming my relationship with you because I don't want to get hurt again if you leave me for Nicole again"?
A: No.

Q: That never came up?
A: Never.

Q: When you picked her up at the airport or met her at the airport--I guess you said you surprised her--did--you and she had a conversation about getting back together?

MR. ROBERT BAKER: We are not going back through this. I instruct him not to answer.

BY MR. PETROCELLI:

Q: Did you and she have a conversation about getting back together and the impact on her of your breakup with Nicole?

MR. ROBERT BAKER: It's asked and answered. I am not going to allow him to go back through that.

BY MR. PETROCELLI:

Q: Tell me everything that you and Paula discussed concerning Nicole during the months of May and June.

MR. ROBERT BAKER: Same. I'm not going to allow him to do that. Not only that, it's overbroad.

BY MR. PETROCELLI:

Q: Is it your testimony that at no time before Nicole's death in the month of May and June you and Paula discussed Nicole? Is that your testimony?

MR. ROBERT BAKER: That's been asked and answered also. Don't answer that either.

BY MR. PETROCELLI:

Q: When did you and Paula get back together?

MR. ROBERT BAKER: We have been all through that. Don't answer that.

BY MR. PETROCELLI:

Q: Did you and she become monogamous in May or June of 1994?

MR. ROBERT BAKER: Don't answer that. It's been asked and answered, and it invades his right of privacy.

BY MR. PETROCELLI:

Q: Did Paula ever ask you if you killed Nicole?

MR. ROBERT BAKER: Asked and answered. Don't answer that.

BY MR. PETROCELLI:

Q: When Paula visited you during the week of June 13, did she ever discuss with you your involvement in Nicole's death?

MR. ROBERT BAKER: Don't answer that. That's been asked and answered as well.

MR. PETROCELLI: I don't agree with any of these, by the way--

MR. ROBERT BAKER: I understand.

MR. PETROCELLI: --but we will take care of it later on.

MR. ROBERT BAKER: I understand.

BY MR. PETROCELLI:

Q: Did Paula come to visit you in prison?

MR. ROBERT BAKER: Asked and answered. Don't answer that.

MR. PETROCELLI: I don't think--any of these have been asked and answered.

MR. ROBERT BAKER: Well, he talked about it.

MR. PETROCELLI: I don't think so, Mr. Baker, but--

MR. ROBERT BAKER: If I'm wrong, we will check it at the--we will run it through the computer at the lunch break.

BY MR. PETROCELLI:

Q: Did you have any visits with Paula in the jail cell?
A: Pardon me? Say that again.

Q: Did she visit you in your jail cell?
A: No.

Q: Never?
A: Never.

Q: Well, when you were in jail, did she come to visit you?
A: Yes.

Q: Where?
A: Attorney room.

Q: Okay. Well, that's--you understood that's what I meant, didn't you?

MR. ROBERT BAKER: Don't answer that. You said "jail cell."

BY MR. PETROCELLI:

Q: Well, you understand what I mean.

MR. ROBERT BAKER: Well, don't answer that.

MR. PETROCELLI: I want to make sure I'm not-- he is not withholding important information on some hypertechnical interpretation of my questions.

MR. PHILLIP BAKER: You want to just answer the questions.

MR. PETROCELLI: I am sure he wouldn't want to mislead anyone.

MR. ROBERT BAKER: Don't get snotty.

MR. PETROCELLI: Well, you know, I think that's an inappropriate response, but we will go back.

MR. ROBERT BAKER: Tough. I don't really care what you think.

MR. PETROCELLI: I know you don't, and I'm not trying to please you, Mr. Baker. I am trying to do my job.

MR. PHILLIP BAKER: The question was "jail cell."

MR. PETROCELLI: One Baker is enough. Okay? I don't need two.

MR. ROBERT BAKER: Your point is well-taken on that.

MR. BREWER: It's 12:00. Do you want to just--

MR. PETROCELLI: Let me just wrap this up here on this point.

Q: She visited you in the attorney room. Right?
A: Yes.

Q: A number of occasions. Right?
A: Yes.

Q: And you had many, many telephone conversations. Right?
A: Yes.

Q: And if any of those conversations in the jail--in the attorney room or on the telephone, did she ask you if you killed Nicole?
A: I don't ever recall her asking me that.

Q: Did you tell her?
A: I'm sure I did.

Q: What did you tell her?
A: I'm sure I did. I don't remember any specific conversations, but I think anybody who heard me speak during that time once I was arrested, I've said many, many times, "Why are they doing this to me? I didn't do this," and basically that was my attitude.

Q: Did Paula ask you where you were on the evening of June 12 at any time?
A: Not that I recall.

Q: Did you ever ask Paula if she listened to the messages you left her on June 12?
A: No.

Q: Did you ever tell her to erase those messages?
A: No.

Q: Did you ever tell her if she could make copies of them or to retrieve them?
A: No.

Q: Did she ever discuss with you those messages?
A: No.

MR. PETROCELLI: Okay. I'm prepared to keep going, but did you want to break for lunch now, Mr. Baker?

MR. ROBERT BAKER: I think it was candy man that was kind of interested in groceries. No, it was Michael.

MR. BREWER: It wasn't me. You were getting into colloquy, so I thought it would be a good time to break.

MR. PETROCELLI: Is the lunch here?

MR. ROBERT BAKER: Yeah.

MR. PETROCELLI: Okay. Well, we will stop now, and start up again in an hour and finish up.

THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 12:04.

[At the hour of 12:04 p.m., a luncheon recess was taken, the deposition to resume at 1:04 p.m.]

[At the hour of 1:15 p.m., the deposition of ORENTHAL JAMES SIMPSON was resumed at the same place, the same persons being present.]

THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 1:15.

EXAMINATION [Resumed]

BY MR. PETROCELLI:

Q: Prior to Nicole's death, did you used to keep your gates open?
A: Years ago, before we got dogs.

Q: When did you stop keeping your gates open?
A: Probably mid '80s.

Q: And when you got dogs, then you closed them up all the time?
A: Well, in the beginning we didn't, but I would say probably closer to the late '80s, SPCA--we started getting a lot of complaints, and into the '90s a lot of complaints from the SPCA, so we had to start closing up.

Q: The Rockingham gate can open and close manually, can it not?
A: Yes.

Q: In fact, it was demonstrated on the video that you put out that it opened and closed manually. Right?
A: I don't think so.

Q: When you walked down the Rockingham driveway, you opened up the gate?
A: Yeah, I did open it up manually. We weren't making that as any demonstration, yes.

Q: Yeah. How do you make the gate work manually as opposed to automatically?
A: You have to disengage a lever on the machine box.

Q: Can you do anything at the location of the gate itself to take it off of--
A: Well, the machine box is over in the bushes that connects--the arm that connects to the gate to pull it open or not. At the end of the box is a--you can--there's a lever you can disengage, and then it's fully manual.

Q: If you're standing outside your property, can you disengage the--
A: No.

Q: --automatic feature of the gate and cause it to open and close manually?
A: No.

Q: It's impossible?
A: Yes.

MR. ROBERT BAKER: Be a great security system, wouldn't it.

MR. PETROCELLI: Not unless you're the only one who knew about it.

Q: The--Do you ever keep that gate on manual when you leave the property?
A: It's not been my habit to, no.

Q: Have you ever done that?
A: I might have in my life, yes, but I don't recall when, other than when we shot the video.

Q: Was the gate used to your knowledge in a manual mode on June 12?
A: I don't believe so. no.

Q: Are you sure about that?
A: I'm pretty sure about that, yes.

Q: You recall all of your trips out the Rockingham gate and in the Rockingham gate, and do you think any of them occurred when the gate was on manual mode?
A: No.

Q: If you were outside your property and you wanted to get inside and you didn't have a key, how would you do that?

MR. ROBERT BAKER: Are you talking about outside the physical walls of his property?

MR. PETROCELLI: Yes.

MR. ROBERT BAKER: Okay. I didn't know if you were talking about outside the house, because a key doesn't open the gates, is why.

MR. PETROCELLI: A key opens the Rockingham gate, doesn't it?

THE WITNESS: Yes.

MR. ROBERT BAKER: Well, you've got a clicker.

MR. PETROCELLI: Okay.

THE WITNESS: A key opens the Rockingham gate.

MR. ROBERT BAKER: Oh,the Rockingham. I'm sorry. You're right, the Rockingham.

THE WITNESS: So--

MR. PETROCELLI: He'll say you're right, but he won't say I'm right.

MR. ROBERT BAKER: You're right, Mr. PETROCELLI. I apologize.

MR. PETROCELLI: For the record. Okay.

Q: What's the answer, Mr. Simpson?
A: I don't know if that's ever happened to me. It has happened to me, but Justin was with us. So outside of that, it's just never happened to me.

Q: What has never happened to you?
A: That I was outside the gate and nobody was inside to let me in and I didn't have a key or a control.

Q: Well, when you had Justin, how did you get him to open it up for you?
A: Justin can--actually, there was two bars that he can actually walk through on the gate, and then he'd go and push the gate opener.

Q: And I take it you can't fit through those bars. Right?
A: No. No. No.

Q: Have you ever jumped any of your fences?
A: Since I've owned the house?

Q: Yeah.
A: Yes.

Q: Which ones?
A: Down where the tree grows through the wall.

Q: Which wall?
A: The Ashford wall.

Q: And near the Ashford gate?
A: Well, I can't say it's near it. In terms of the wall, it's about halfway down my property.

Q: Here is Exhibit 85. Where have you jumped the fence on your property?
A: Right about here [indicating].

Q: Okay. You are pointing to the tree on the east side--northeast side where the word "Lawn" appears. Right?
A: Yes.

Q: And would you just climb over that fence?
A: Well. there's a tree that grows through it, so you can kind of step on the branch--maybe a little taller now than when I did it but you would have to step on the branch and then just go over the wall.

Q: Then you're in the backyard?
A: Yes.

Q: When was the last time you did that?
A: I don't know. '80s.

Q: And have you ever gone over any of these other perimeter walls to your property?
A: No.

Q: Okay. And would you have been able to do so in June of 1994?

MR. ROBERT BAKER: Speculation. Don't answer that.

BY MR. PETROCELLI:

Q: How would one have jumped the walls? Where can you climb the walls on your property? I

MR. ROBERT BAKER: Other than where he just told you?

BY MR. PETROCELLI:

Q: Yes, other than the one area in the northeast quadrant of your property that you just identified.

MR. ROBERT BAKER: And when you say you can climb these walls, you mean him physically can climb any of the walls?

MR. PETROCELLI: A person. A person.

MR. ROBERT BAKER: Bruce Jenner maybe?

MR. PETROCELLI: Bob Baker.

MR. ROBERT BAKER: None. None without a crane.

MR. KELLY: Pure speculation.

BY MR. PETROCELLI:

Q: Again, Mr. Simpson.
A: I don't know. I think a motivated person probably could climb the walls.

Q: You could climb the fence--

MR. ROBERT BAKER: Your process server did it.

MR. PETROCELLI: No, he didn't.

Q: You could climb the fence at Rockingham. There are some trees around here [indicating] near the north of the Rockingham gate. Right?
A: I never have, and I never have seen anyone do it.

Q: Is it possible to do?
A: I would think anything's possible, yes.

Q: Now, you can get on the Salingers' property, which is on the south side, by simply walking from the sidewalk right up to the property. Correct?
A: Yeah, down their driveway to their house, yes.

Q: And then you can walk up to the south side of your property on the Salingers' side of the fence. Right?
A: I suppose you could.

Q: And you can walk all the way down that property until you come to the area opposite, oh, Kato Kaelin's room. Right?
A: I really don't know.

Q: Why not.?
A: Because I don't know.

Q: There is a carport back there, isn't there?
A: Yes.

Q: And you can climb on that carport and jump that fence, can't you?
A: I don't know.

Q: Do you think that's impossible to do?
A: I think it would be very difficult.

Q: Why? What would be the obstructions that you would encounter?
A: Thick foliage. I haven't really looked at the carport, but I would imagine it would be pretty tough to just climb on top of a carport. I don't know if they have any lattice work that would help you climb up there or not.And it would seem to me, and I'm just flat-out guessing, that if you got as high as a roof, those--the Eugenia bushes get thicker as they go up. I would imagine it would be dangerous coming through there.

Q: The--your property--the level of your property is higher than the level of the Salingers'. Right?

MR. PHILLIP BAKER: Where on his property,

MR. PETROCELLI: South side there.

MR. PHILLIP BAKER: Are you talking about his roof or the--

MR. PETROCELLI: No. The ground level.

MR. ROBERT BAKER: The ground level?

MR. PETROCELLI: Yeah.

THE WITNESS: I would--I believe so. I'm not a hundred percent sure of that.

BY MR. PETROCELLI:

Q: By how many feet? Do you know?
A: I don't know.

Q: About three feet?
A: I don't know.

Q: So you know of no way along the south side of your property that you could, if you didn't have a key, get from the Salingers onto your property. Is that right?
A: Unless you're climbing something. I don't know of a way to do it, no.

Q: Is there an easy place to climb over on the south perimeter?
A: I don't know. I've never really--

Q: Across the south perimeter of your property?
A: I've never really paid attention to it. Other than back here [Indicating] where that so-called glove was found, I don't--I've never paid attention to it.

Q: Well, since this whole situation occurred, have you investigated whether or not the fence could be climbed in that area opposite Kaelin's room?
A: I looked at the fence and thought it would be difficult to climb that fence without sustaining some type of injury. I mean, it would be--you'd have to be really motivated to do it.

Q: What kind of injury might you sustain?

MR. ROBERT BAKER: Speculation.

BY MR. PETROCELLI:

Q: You mean from the sharp edges on the top of the fence?
A: Yes.

Q: Okay. Going now to the east--southeast corner of your property, is there a way to access the property from that corner or, for that matter, from the east side of the property?
A: Not that I know of.

Q: There is a neighbor whose property is directly east of yours?
A: A couple of neighbors.

Q: Yeah. Is that vacant land there? Do you know?
A: No. Well, on one--now the--yeah. One of them is vacant, yes.

Q: Was it vacant in June of '94?
A: I don't know.

Q: What separates your property from the neighbor directly to the east?
A: Which one?

Q: Right here in the corner [Indicating), southeast corner.
A: I would imagine a fence and some pretty thick foliage.

Q: And how high is that fence?
A: I've never looked at it.

Q: Is the fence that extends down the south side of your property between your house and the Salinger property the same height all the way down to the corner?
A: I don't know.

Q: And is there a fence that extends northerly from the southeast quadrant?
A: I believe so, yes.

Q: Same height as the south fence?
A: I never looked at it. I don't know.

Q: Okay. So do you know whether one could climb that fence if they were so motivated?
A: I don't know.

Q: The only time you're aware of anyone accessing your property without a key is when Justin did so with you?
A: No. I know that various friends would climb the wall here [Indicating].

MR. PETROCELLI: One second.

[Telephone interruption.]

[Discussion held off the record.]

BY MR. PETROCELLI:

Q: Okay. Where on your property do you know your friends have jumped the wall or the fence to get on your property?
A: Right about the area that I spoke of [Indicating).

Q: Just in that northeast corner where the big tree is?
A: Yeah.

Q: That's the only place you're aware of?
A: Yes.

Q: Have you given anybody instructions at any time that if they need to get on your property without a key, that's the way to get on?
A: I may have implied that, yes.

Q: To whom?
A: Years ago this guy Schulman used to have a basketball game, and they played at my house on weekends, friends of his, and not bother us in the house. If we were home or not, they would jump the wall there.

Q: That's John Schulman?
A: Ricky Schulman.

Q: Rick Schulman. Is that Linda's husband?
A: Yes.

Q: The--In your video you make a point of showing that if someone wanted to get inside the house from that pathway behind Kaelin's room, they could enter one of two doors: One into the laundry room and the other one into the garage. Do you recall that?
A: Yes.

Q: And you also point out that the garage door opens outward, so even if it were jammed up, you could still open the door.
A: Yes.

Q: Do you recall that?
A: Yes.

Q: Do you know what was in that garage where the door is on June 12, 1994?
A: I think a--I didn't know at the time. saw a picture in jail, and it appeared to be a-- kind of a chest.

Q: A chest of drawers?
A: No. I think it was an Oriental chest Of some sort and with some things on it.

Q: Blocking the door?
A: Yeah, blocking access to walk--if you were trying to go that way, you would have had to climb the chest; then open the door. If you wanted to go from inside to outside. that's what it appeared.

Q: What if you wanted to go from outside to inside? You would open the door and then you would--
A: Climb the chest.

Q: Then you would be confronted with the chest?
A: I would think so.

Q: And how high is that chest?
A: If I recall, probably this table [Indicating].

Q: Conference room table, about
A: Yeah, maybe a little taller than this.

Q: --three feet, four feet. Is that about right?
A: Yeah.

Q: Okay. Was anything on that chest to your knowledge?
A: I don't know. You know, I saw a picture, so I would have to see the picture to refresh myself. So other than that, I don't know.

Q: Do you know whether there was anything in front of that chest such that if you moved the chest out of the way, you know, you would be confronted with some other obstacle?
A: It would be pretty tough because I know my car is in there, so there must have been some-- had to be some room. I'm just guessing now, so you'd have to show me a picture. Otherwise I'm flat-out guessing.

Q: I take it that was not a door that you used to enter into or leave from at or around June of 1994. Is that true?
A: That's correct.

Q: And when was the last time you recall using that door for access?
A: The garage door?

Q: Yeah. The one going out to the south side.

MR. ROBERT BAKER: When you say "for access," do you mean to access to the house or to the garage?

MR. PETROCELLI: To the house--to the garage.

THE WITNESS: As of when?

BY MR. PETROCELLI:

Q: When is the last time you remember using the door?

MR. ROBERT BAKER: Before June--

BY MR. PETROCELLI:

Q: June 12, 1994.
A: Before June 12.

Q: Yeah.
A: I don't know. I don't have a memory of it.

Q: Okay.
A: I've used it, I know, but I just don't have a memory of when.

Q: It had been a while since you used it it prior to June 12. Right?
A: I would think so, but I'm not sure.

Q: Was that door on the Westec alarm, that outside garage door?
A: I doubt it.

Q: And there is no keypad there, is there?
A: No.

Q: Is there a keypad on the door that goes into the residence from the garage?
A: Yes.

Q: On the outside of the door in the garage?
A: Yes.

Q: And the laundry room door, is that a door that you were--you or others using your house used regularly in June 1994?
A: I don't know about regularly, but it was a door that was used.

Q: Do you know whether there was anything obstructing that door from being used in June of 1994, June 12th to be specific?
A: Normally you could--you could as if-- if I was--the other day I went out that door, and there's always a little--when you go to the various rooms and you take dirty laundry and you put it on it and you end up dropping that right there, so you have to kick it out of the side.

Q: You have to kick what out of the side?
A: This little laundry, you know

Q: A basket?
A: Yeah, a basket.

Q: A plastic basket?
A: Yeah.

Q: So that would be the only thing that you believe would have been blocking that door, is a laundry basket?
A: Sometimes you'll have an empty Sparkletts bottle or something there, but they're never any problem to move aside.

Q: Does that door open inward or outward?
A: I believe inward.

Q: And is that door on the Westec or was that door on the Westec alarm in June of '94?
A: I would think so.

Q: Is there a keypad on the outside of that door?
A: No.

Q: Or on the inside?
A: Near the inside but not at the inside.

Q: Okay. When was the last time what was the last time prior to going to jail on June 17 that you were in the area of the air conditioner on that pathway behind Kaelin's room?
A: On the 13th.

Q: What were you there for on the 13th?
A: There was talk about something was outside of Kato's room, and and I don't know. I think possibly that ski mask or--I don't know. Something was found, and we walked out there to see what was out there.

Q: This was in the evening?
A: Yes.

Q: This is after the police had left and you had come back from your office and you were at Rockingham. Right?
A: Correct.

Q: And it was dark out by then. Right?
A: No.

Q: Still light out?
A: Yes.

Q: What time was it?
A: I don't know. 5:30, 6:00 o'clock maybe.

Q: And who did you go back there with?
A: I don't remember. I think Kardashian may have been with me, and there was somebody else with us, too, but I can't--I can't recall. I know there was two or three of us that walked back there.

Q: Now, what was your purpose in going back there?
A: I don't know. Curiosity.

Q: No other purpose?
A: No other purpose I can think of.

Q: And what did you determine, if anything, when you went back there?
A: Nothing.

Q: How did you get back there?
A: Walked out of the washroom door.

Q: That laundry room?
A: Yes.

Q: And were you able to walk past ---did you walk past the air conditioner?
A: I didn't, no.

Q: Are you able to?
A: Yes.

Q: Physically?
A: Yes.

Q: You can squeeze by it?
A: Oh, yeah.

Q: Okay. Between the air conditioner and the fence there is enough clearance for you to get by it?
A: No. You kind of duck under it.

Q: Duck under it?
A: Yeah.

Q: Before June 13 when was the last time you were back in that area?
A: I don't recall.

Q: When is the last time you know for sure you were back there?
A: I--for sure I don't know. I know I'd had to go back there a few times to do things like light the water--I mean light the heater.

Q: Where is the water--the water heater?
A: I guess--no. Just the heater. The house heater goes out sometimes, and I had to go back there a few times for that and

Q: Where is that heater?
A: Right outside that door before you get down the walkway.

Q: West of it?
A: West of where the air conditioner is; east of the laundry room door.

Q: On this map here, this sketch, Exhibit 85, you have "Kaelin's Room," right, and you have "Office." That's the office that adjoins Kaelin's room. Correct?
A: Yes.

Q: And then where is the laundry room?
A: Here. The laundry room would be here [indicating].

Q: Okay.Just immediately cast of the garage. Right?
A: Yeah.

Q: And where is the heater?
A: Heater is here [Indicating].

Q: Okay. So right about here [Indicating] I will put an H there.
A: Yeah.

Q: Okay. And when was the last time that you went to the heater before June 12,'94?
A: I don't know.

Q: So you have no recollection in 1994 of ever having been in that south pathway. Is that right?
A: That's not correct. I know at some point in time I was back there for not only the heater, but also for the lighting. Sometimes I have power outages, and you have to go hit the whatever you call, switch, but I don't recall.

Q: Where is the switch?
A: Right here [Indicating].

Q: Right next to the heater?
A: Yeah.

Q: Okay.
A: No. No. Right here [Indicating]. Across from here.

Q: Right here [Indicating]?
A: No.

Q: Why don't you put it. [Witness complies.]

Q: You put an X there. Okay?
A: Yeah.

MR. PETROCELLI: I will make this another exhibit.

MR. ROBERT BAKER: Fine.

MR. PETROCELLI: H for heater. X . . .

Q: Now, do you have any other purpose in 1994 for going back in that south pathway.?
A: No.

Q: Okay. And are you telling us that you know for sure you went back there in 1994 before June 13?
A: Yes.

Q: And you did so in order to turn fix the lights or fix the heater?
A: Yes. It's a regular occurrence at my house.

Q: What is?
A: Either the heater doesn't come on or one of the switches go off. So portions of my house, the light doesn't work. It's something that, you know-- and since I've been out of jail, I've done on numerous occasions.

Q: Now, when you did that in 1994, did you--how did you get to that location? I
A: I'd go out the washroom door.

Q: And then you would head west. Right?
A: No. East.

Q: East. Excuse me. And when was the last time before June 13, 1994 that you had gone down as far as Kaelin's room?
A: I have no idea.

Q: When was the last time in any year that you've been down there?
A: I don't know. I don't have a recollection. I've done it, obviously, on occasions, but I don't have any recollection at this point.

Q: Why do you say you have "done it obviously, on occasions"?
A: Well, because it's my property. I built that. My cable wires run back there. We play a game with my kids that you can go anywhere on the property and hide, and, you know, some times you look back there if they're back there, those kinda things.

Q: Do you recall you being back there in 1994?
A: No.

Q: Okay. In 1993?
A: I'm sure I did, but I don't recall when and what.

Q: And it was playing hide-and-seek with your kids?
A: Possibly. Possibly.

Q: Did you have any other reason for going as far as Kaelin's room?
A: Yeah.

Q: Why.?
A: The fire department each year gives you a thing about your property, so you have to go and look and see what they tell you you got to move.

Q: And what did they tell you.;
A: Oh, from time to time you have wood. I think it was too much wood back there at one time. At one point it was the leaves had to be cut back.

Q: Where would the wood be that had to be. moved?
A: I believe it was all the way back here [Indicating].

Q: To the corner. Right.?
A: I believe so, yes.

Q: And when is the last time you recall going back there before June 13?
A: I don't have a real memory of any specific time going back there. I just know I've been back there on numerous occasions.

Q: If you had to go back there to get wood in that southeast corner, would you access that location from the other side of the property; from your backyard, that is?
A: No.

Q: You could. Right?
A: I would imagine so, yes.

Q: So right now, though, you don't have any specific recollection of going as far as back as Kaelin's room in 1993. Is that right?
A: That's correct.

Q: Okay.
A: 1994, you said.

Q: And 1993.
A: I know I did. I just don't know specifically when and, you know, what.

Q: What's the lighting back there? What was it in June of '94?
A: Whatever God gave it.

Q: There is no artificial lighting. Right?
A: None.

Q: So it's completely dark at night down there. Right?
A: That's correct.

Q: And that's what it was like in June of '94. Right?
A: I believe so.

Q: Does the neighbor have sprinklers that wet the south pathway?
A: I don't know.

Q: You know, get it wet when they go on?
A: I don't know.

MR. PETROCELLI: I will make a copy of this and mark that as Exhibit 100, I guess.

[Plaintiffs' Exhibit 100 was marked for identification by the reporter and is attached hereto.]

BY MR. PETROCELLI:

Q: Do you know whether the garage door was kept locked in June of 1994?
A: Which door?

Q: The one that leads from the garage to the south pathway.
A: I don't have any specific thought of that, no, one way or the other.

Q: Okay. And what about that laundry room door, was it kept locked?
A: Kept locked.

Q: And you had a master key. Right?
A: Yes.

Q: Which would have worked on the laundry room door. Right?
A: Yes.

Q: And the garage?
A: I believe so, yes. It wasn't our the garage door was normally not kept locked. But...

Q: Not kept locked?
A: Normally not. I don't know if it was that period of time or not.

Q: Did you the last three years before June of 1994 ever call someone to fix the heater?
A: I'm sure I did.

Q: Who did you call? Do you know?
A: I don't handle that. Michelle you'd have to ask Michelle about those things.

Q: And who handled the cable?
A: Whoever does cable in the area.

Q: Have you carried wood back to that corner of the house, the southeast corner?
A: No.

Q: How did the wood get there?
A: I think they cut down a tree.

Q: In that area?
A: Yes.

Q: Now, do you ever go there and get wood for your fireplace?
A: No.

Q: Do you know--Excuse me. In June of 1994 did you know any of Nicole's neighbors at Bundy?
A: No. No.

Q: Do you know any of their names?
A: No.

Q: Did you ever speak to any of them?
A: Yes.

Q: Which ones?
A: The person who shared the building that she was in, and I had an occasion to briefly talk to the person who lives just north of her. You know, they have a common--well, just--I don't know if they're condos or what, but the one just north of her.

Q: Those are the only two neighbors you recall talking to?
A: Yes.

Q: And did you talk to them a number of occasions or just once?
A: The neighbor that shared the building with her--

Q: Yeah.
A: --I talked to from time to time because our kids would play when he had his daughter, I believe. The neighbor to the north, only-- Nicole's in an argument with him and I kinda got into it a little bit, but that was the only time--

Q: That was about dogs?
A: Dogs and leaves and dog doo.

Q: When was that argument?
A: In late May.

Q: '94?
A: Yes. Mid to late May.

Q: Is that when you went over with your-- with Jason in the car--I am sorry--Justin?
A: I don't believe so.

Q: Was that another occasion?
A: Yes.

Q: Was that at night?
A: I was coming over for--I don't know. I don't know. It was in the afternoon. I do know that. I--it was light, and it was afternoon.

Q: Did there come a time after you split up with Nicole in May where you told her, as you had in previous years of your relationship, "I don't want to communicate with you except if it relates to the kids"?
A: I don't think I ever--after she. yelled at me, I think I told my office, and I think through the office she got the word. I know she called me after that, and I didn't return her call. So I don't think I technically ever said to her, "I don't want to communicate with you other than through the kids." I think I just started doing it.

Q: Did you ask someone to convey that message for you, such as Cathy.?
A: I don't think so. I don't think so.

Q: And you believe she got that message because why? She was--
A: Because I wouldn't talk to her, wouldn't receive her calls, and she started getting letters from my office.

Q: And she started getting calls--
A: Or she got a letter from my office.

Q: One letter. Right?
A: Yeah. And she called--she called me a couple of times about the tickets, and I didn't communicate with her. I had Cathy communicate with her.

Q: Did Nicole ask Cathy why you were not communicating with her?
A: I don't know what Nicole asked her.

Q: Do you know whether Cathy told Nicole that she didn't--you did not want to communicate with her?
A: No, I don't know that.

Q: Okay. And you--your recollection is that you never said that to her. Right?
A: I just stopped. Yeah, my recollection is I never told her that.

Q: Okay. And what is the date that you began--what is the date that you stopped communicating with her except for the kids?
A: I think whatever day she called and yelled at me, it was basically the next day I called and kinda left a message for her, and I might have-- I could be wrong. I might have said, "Don't call me." in that message, but I think I made it clear to her I didn't want any other communications with her or her communicating with my home or people in my home. And "communication" is not the right word. Of hassling people in my home would have been a better word.

Q: And you never talked with Nicole again about your call to her or your message to her. Right?
A: No. Even though we talked again. but I didn't talk to her again about that, no.

Q: Okay. You heard at Kaelin's deposition, which you attended, some discussion of a dispute between Michelle and Nicole. Right?
A: Yes.

Q: Can you tell me what know about that dispute?
A: What? I mean, she had an ongoing dispute with--

Q: Is it true that Michelle quit on account of Nicole?
A: I don't know if that's--

Q: Is it true--
A: --correct.

Q: --that Nicole hit Michelle?
A: That's correct.

Q: Okay. Tell me about that incident.
A: The kids were at my house swimming with some--with another kid or some other kids, and Nicole came over, and I was sitting in the backyard reading, and she came and sat next to me and she says, "I really can't be around here if Michelle's around here.' I said, "Why; She's just cleaning up." She says, "Well, you know how she just gets on my nerves." So I went into the kitchen and told Michelle, you know, Michelle, take the rest of the day off," which I've done on previous occasions. And Michelle said, "Okay, I just have to make your bed and finish the kitchen." I said, "Well. just do that and take the rest of the day off." And I came out and I told Nicole, "She's just gonna finish the kitchen and make the bed, and she's gonna take the rest of the day off." And the kids were trying to get me to turn the jacuzzi on, the heater on, so right at that area I went to the heater for about a minute or two. and when I walked out, Nicole was walking out of the house shaking, saying, "She drives me crazy. I hit her." And I said, "What do you mean, you hit her?" She said, "OJ., I know it's wrong. but I just can't take that woman, and I hit her." So I walked into the house, and Michelle was coming out of her bathroom, and her face was-- was beginning to show that she had been hit and was red, and she was crying and she was trying to call 911, but she was dialing 199, and then when she saw me she stopped and started venting at me, "Look what she did to my face." So I walked out and said to Nicole "What"--she was getting the kids out of the pool at that point. "I mean, how"--"I mean, you can't hit people." And she said, "I know. I know. I just can't that take that woman." And Nicole, as I went through the house, she went around the house, she put the kids in the car, and Michelle was crying, talking to me, and I just went to my office.

Q: What day was that?
A: I don't know.

Q: What month was it?
A: March.

Q: 1994?
A: Yes.

Q: Did Michelle continue to work for you, or did she quit after that?
A: I wouldn't let her stop. Nicole wanted me to fire her and I wouldn't. and I told her that And--Nicole that, "This girl works for me and she's gonna work for me," and she knew in June that if we got back together she'd move, "but at this point she's gonna work for me until she finds another job. If it takes six months, she's gonna work for me for six months. If it takes a week, it'll be a week, but she's gonna stay here until she finds another job.' Michelle felt that it would be best for her to move on if--because she knew I wanted the people around and they were coming around, and she didn't want to be in the way of that, and she--I think the guy that she had worked for previous to me had coincidentally then called. He was going through a divorce and wanted her to come back to work for him, so she found a job. And then she kinda hung around for three weeks to try to train Gigi once they found Gigi, to try to work with Gigi on how to run the house, and then she went to her new job.

Q: Did she leave your employ before you went to Cabo?
A: I believe so. No, no. Before I went to--before I went to Cabo, possibly. Possibly. Before I went--I'm not a hundred percent sure.

Q: How long had she been with you?
A: On and off, 10, 12 years.

Q: And she and Nicole had battled before?
A: Not like this, no. They had had disagreements before, but they always stayed friendly whenever Nicole--like when we split and Michelle was waiting--working for me, I guess Nicole called her on numerous occasions to come over to help her and to baby-sit for her.

Q: Did you ask Michelle to go get Nicole out of the police car in that 1989 incident?
A: I don't think I asked her. I think she just did it on her own.

Q: You did not ask her?
A: I don't believe so, no.

Q: Why did she do that? Do you know?
A: I don't know. Nicole appeared to want to get out of the car, and Michelle was there saying, "Come back in the house," or whatever, and the police were keeping her from getting out of the car-or this policewoman was keeping her from getting out of the car.

Q: You said in your video that you had some financial disagreements with Nicole in 1992 in connection with your divorce. What were they?
A: She was convinced that she would not have enough money to live the way she wanted to live.

Q: How much did she get a month?
A: Nothing.

Q: No spousal support?
A: None.

Q: just the 10,000 child support?
A: Well, we had a buyout. We bought out for a lump of money.

Q: How much did you give her?
A: I don't recall.

Q: What's the ballpark?
A: I don't know. You'd have to look at - I'm sure you've got all the financial stuff.

Q: The only--Was it cash you gave her or real estate or both?
A: Well, the real estate I had previously given her--

Q: The San Francisco place?
A: San Francisco. So it was cash. She expressed to me that she needed to buy a certain house, so we made the deal for her to have the house. Cash between the two properties.

Q: You mean with the cash and with the sale of the San Francisco property, she could buy another place?
A: Yeah. She had a choice of buying a place up to whatever worth. I don't know.

Q: Now, you were ordered to pay $10,000 a month--
A: Yes.

Q: --child support?
A: Yes.

Q: And you continued to pay that throughout your--throughout Nicole's life?
A: Yes.

Q: And after she died did you continue to pay that?

MR. ROBERT BAKER: You don't have to answer that. It's irrelevant to any issue in this case, and don't answer it.

MR. PETROCELLI: I don't think it's irrelevant but I'm not going to persuade you.

MR. KELLY: You guys want a ruling?

MR. PETROCELLI: We will call the judge in Idaho.

MR. BREWER: Could be Baker's first press conference.

BY MR. PETROCELLI:

Q: Okay. You said that you did not regard Nicole's activities when she was following you in golf courses, to Mexico and to the house as stalking. You said that on your video.
A: Yes.

Q: What do you regard as stalking?
A: I really don't know what stalking is. I've never experienced it, and I--as I pointed Out. the--I didn't think that's--from what I gather, stalking to me is a very negative thing, and I thought Nicole was just trying to get back with a guy that she was in love with. and I didn't feel that she infringed upon my space during that period of time.

Q: You think stalking involves infringing on your space?
A: Yes. I think when someone makes you very uncomfortable, coming around, follow you and it makes the person being followed very uncomfortable, you know, that has to be an element in stalking.

Q: In May and June of 1994 were you following Nicole anyplace?
A: No.

Q: Did you spend a whole day following Nicole?
A: No.

Q: Anybody who would say that would be lying. Is that right?
A: Correct.

Q: Do you recall driving by a restaurant on a Tuesday in early June and seeing Nicole and Judy having a meal in a restaurant?
A: No.

Q: And slowing down and stopping and looking through the glass at them?
A: No.

Q: That never happened?
A: Never happened.

Q: Did you ever tell anybody that you molded Nicole?
A: I can't remember specifically.

Q: Does that sound like something that you might have said?
A: Nicole and I talked quite a bit, and we're friends, about, you know, women and men adjusting to another person, so, I mean, it's--I don't recall specifically saying that, no.

Q: Did you ever tell anybody that you molded Nicole in the sense that you took her as a young woman of 17 years old and turned her into the adult woman that she became?
A: No. no, I don't--I wouldn't say that's correct. I think in some areas I had some influence on Nicole, yes.

Q: On what areas?
A: Dress... You know. I don't know.

Q: Besides dress, anything else?
A: I don't know. Just in general I think Nicole and I was a good match for one another, and we probably picked up a lot of things from one another. I thought--communication. I didn't--I never thought Nicole was a good communicator, and I think she picked up some of her--I don't think she ever became a good communicator either, but she certainly got better.

Q: Were you a father figure to her?
A: I hope not.

Q: Did she ever say that to you?
A: No.

Q: Did you ever tell anybody in words or substance that you molded Nicole?
A: I don't believe so.

Q: That's not something that you would say. Is that right?
A: I recall Nicole--I recall at dinners with people, everybody's talking about--Nicole used to always give me credit for, you know, from becoming a beach girl or whatever--

Q: What was the "whatever"?
A: Whatever she was, you know, and those are conversations that we went out to dinner with couples, people talk about, I guess.

Q: So she would give you the credit. You wouldn't take the credit. Is that what you're saying?
A: I would like to think that I had something to do--like she had something to do with who and what I am, I had something to do with who and what she is in areas.

Q: What did Nicole credit you with doing for her?
A: A lot of things. I think--

Q: Besides dress?
A: --changing her from a beach girl to whatever she was, where she felt relatively comfortable in any environment.

Q: How did you change her?
A: Exposed her to those things.

Q: To different things?
A: Yes.

Q: Was it at your suggestion that Nicole had breast implants?
A: No.

Q: And breast surgery?
A: Never been a breast man.

MR. ROBERT BAKER: He didn't ask you that.

BY MR. PETROCELLI:

Q: Did you ever use the expression "titty fairy"?
A: All the times. Still do.

Q: And what do you mean by that expression?
A: Girls who got tits, I said "What, did the titty fairy visit?"

Q: Now, did you ever say that the titty fairy visited Nicole?
A: Yes.

Q: To whom did you say that?
A: Nicole and I was at dinner--to whatever the conversation was. You know, these girls are very, very open about their breast jobs. In a restaurant, when Chris Kardashian had hers, her and Nicole and all the girls went in the bathroom to look at her breasts, and that's what started Nicole thinking about having a breast job. So there--it's--in West LA. it's a--you know, it was, "Hey, look at my breast job." "Who did this?" "Look at my breast job." "Who did yours?" It's kind of a--and I think all of her friends had breast jobs.

Q: When did Nicole have hers?
A: Late '80s, maybe it was early '90s. I'm not really sure.

Q: It was not your suggestion?
A: No.

Q: Did you give your approval?
A: I told her, "Just don't make them too big."

Q: When you were in Puerto Rico, did you call Cora Fishman about Nicole's behavior?
A: I called--I believe I tried to call Cora to find out what was going--if there was something the matter or what was going on, but she seemed to be having--I don't know if I ever talked to Cora, because they were having problems, and then Nicole told--you know what? I don't think I called Cora Fishman. I think I called Ron Fishman. I don't think I ever got to talk to Cora Fishman during this period of time.

Q: Did you tell Cora around this period Of time: "What's going on here? I left Nicole in April. In Cabo we were like lovers. We were planning to be together. She was going to move in. You know, we had the best sex, you know. She was gonna go follow me in Florida, and then she was gonna go to Florida because there was a wedding there. She was going to go to Florida and she was gonna go to Puerto Rico with me and all of a sudden, what happened? What happened?"
A: All of that, I don't think so, but in substance those are--were my attitudes during the time I was in Puerto Rico. I don't recall having this conversation with Cora. I do know that Cora and Faye said to me about Nicole told them what a great couple of weeks we had and how much she was looking forward to meeting me in Florida, but something-- something--something was going on.

Q: You had made plans to meet in Florida?
A: She was flying to meet me in Florida for a friend's wedding.

Q: Were you going to go off on a yacht trip, too?
A: No, because I was still working on the movie.

Q: Okay. And did you--Was she going to move in?
A: I was--it was--as I told you, I was--for the first time when I left to go to Puerto Rico was the first time I thought possibly this relationship could work.

Q: Had you discussed it with her, moving in?
A: The whole year she was constantly trying to move in, and I was constantly saying, "Wait till June."

Q: What I mean to say is: Had you and she discussed that now she would in fact move in when you got back from Puerto Rico?
A: Only thing we discussed is that I--I don't know. I don't think so. I just know when she got rid of Michelle, that was one of her purposes, to get rid of Michelle so that she could move back in, and I know that made me stronger to wait till June. But this last weekend before we went to Puerto Rico was the first time that I really felt that maybe they would move back in, I could let them move back in or, you know, say okay.

Q: What did you mean when you said, "that made me stronger to wait till June"?
A: Because when she hit Michelle. I was--I just, you know, didn't feel that I wanted this. You know, as I said, I wasn't sure that this was gonna work, and I wasn't sure that this is what I wanted--

Q: Wasn't Michelle--
A: --back in my life.

Q: I'm sorry. Wasn't Michelle gone by--
A: Yeah, three weeks later.

Q: So--
A: When she hit Michelle, I was dead against her moving back--

MR. ROBERT BAKER: No question pending.

THE WITNESS: Okay.

BY MR. PETROCELLI:

Q: But after Michelle moved out you had no further reservation at that point. Is that right?
A: No. The weekend she came back from Cabo to spend a weekend with me in LA. It was a great weekend. On the way to the airport I called Lou and Judy Brown and said, "You know, you guys, maybe I was wrong," because I had mentioned to them before that I didn't think this was gonna work. Maybe I was wrong. So it was the first time in my mind that I felt that possibly it would work out.

Q: And this is when you came back from where?
A: She came back from Cabo. I was on my way to Puerto Rico.

Q: Oh, on your way to Puerto Rico.
A: Yes. I was actually in the limo, driving in the limo to get on the plane to go to Puerto Rico.

Q: Okay. Now, as of that point in time had you and Nicole agreed on a date when she would move back in?
A: Not specifically. I told her we'd give it a year, and after a year, if it was working, they could move back in.

Q: No. I mean at this point in time when you're feeling like the relationship is going to work--you're in the limo; you call the Browns; you tell them, "I think this could work"--as of that point in time and before the problems began with Nicole again, did you and she fix a date for her to move back in?
A: We never fixed a date. It was--as I told you, it was--I said we'd give it a year. At one point right before she hit Michelle she wanted-- she had--no question pending. I'm sorry.

Q: Well, you were in the middle of an answer and you haven't answered the question yet.
A: No, no date. No specific date.

Q: Had you discussed a time frame for her moving back in?
A: Yes.

Q: When was she going to move back in?
A: A year from the previous Mother's Day. I would give it a year, and then I would--we'd decide if that was--

Q: I'm confused. I'm confused. When you said you "would give it a year," that was the previous Mother's Day--
A: Yes.

Q: --in May of '93. Right?
A: That's correct.

Q: And now we are one year later.
A: Not quite. We hadn't gotten to Mother's Day yet.

Q: Yes, but you're thinking it's now going to work out. Right?
A: I'm thinking that--for the first time I'm thinking there's a chance that this might work and maybe I was wrong.

MR. ROBERT BAKER: That was the end of March, early April of '94.

MR. PETROCELLI: Yeah, I know.

Q: But did you think there was some reason why you couldn't let her move in 11 months later or 10 months later?
A: Yes.

Q: What was that?
A: Because I wasn't ready.

Q: Okay. So you and she never fixed a date then. Right?
A: I think I answered that question.

MR. ROBERT BAKER: Around four times.

BY MR. PETROCELLI:

Q: And you and she--Did you discuss with her around this time frame that she would move in in June or late May of '94?
A: No.

Q: Okay. So you had no discussions about when she would move in, in April of '94. Right?
A: During April of '94 we had no discussions about her moving in.

Q: Okay. And none in May of '94. Right?
A: In May, certainly not.

Q: Okay.
A: Yeah. I mean, when you say "moving in," there was subjects about it in May. You know, she said, "Well, you never wanted me to move in," you know, that type of stuff.

Q: No. I mean plans to move in.
A: Yeah, okay. No.

Q: Okay.

MR. KELLY: Excuse me. Could we take a five-minute break now?

MR. ROBERT BAKER: Sure.

THE VIDEOGRAPHER: This is the end of tape No. I of Volume VII. The time is approximately 2:05, and we are off the record.

[Recess.]

THE VIDEOGRAPHER: We are on the record. The time is approximately 2:27. This is the beginning of tape No. 2 of Volume VII.

BY MR. PETROCELLI:

Q: At no time in 1994 did Nicole ever come to you to discuss or confide about relationships with other men. Is that right?
A: No.

Q: True?
A: That's true, yes.

Q: On your video you have some discussion about whether or not Nicole purchased--ever purchased gloves for you. Did she ever purchase gloves for you?
A: I don't believe so.

Q: Are you sure about that?
A: I'm pretty sure about that.

Q: Now, did she purchase gloves for someone else?
A: You know, it's hard for me to--I can't answer that. I think one person said she did, but she bought for so many people, I can't tell you what she bought for them. But I know she had a budget, and one person came forward and said that she did.

Q: Who was that?
A: Trying to think of his name. He sent them to the prosecution, I believe. Tom McCullum.

Q: And who is he?
A: He was a friend of ours.

Q: And he says Nicole bought him gloves?
A: Yes.

Q: Were those Aris Light gloves?
A: I don't think so.

Q: Do you know whether Nicole ever purchased Aris Light gloves?
A: No.

Q: You don't know that she didn't. You don't know either way. Right?
A: Yeah, you're right.

Q: Did you ever give away Aris Light gloves?
A: Not that I know of.

Q: Did you ever wear Aris Light gloves?
A: I really don't know. I could have.

Q: Do you ever remember owning a pair?
A: No.

Q: Do you remember wearing a pair?
A: No.

Q: But you could have. Right?
A: Yes.

Q: Did you give away any gloves one Month before June 12, 1994, within that period of time?
A: I don't believe so.

Q: What about in the year 1994?
A: I don't know.

Q: Did you give any gloves away then?
A: I don't know. I don't remember what was in my New York to get rid of.

Q: When was the last time you gave away clothes before Nicole's death?
A: January of '94.

Q: And these were clothes from the New York place?
A: Yeah.

Q: And who did you give them to?
A: Some to a guy named Fuhrman, believe it or not, and then other guys in the building. You know, you put them in big bags and you take them downstairs, and, you know, I don't know if they go to Goodwill or the doorman go through them or what.

Q: What was Fuhrman's first name?
A: I only knew him as Fuhrman.

Q: You are not saying you gave away a pair of Aris Light gloves to Mr. Fuhrman, are you?

MR. ROBERT BAKER: Don't answer that. That's a great question, though.

MR. KELLY: That's one of the most remarkable--

MR. ROBERT BAKER: That is remarkable.

MR. KELLY: --things of all time.

MR. ROBERT BAKER: That was a great question.

MR. PETROCELLI: I couldn't resist.

MR. ROBERT BAKER: I understand.

BY MR. PETROCELLI:

Q: Who is Mr. Fuhrman?
A: He's a doorman or--I'm sorry-- concierge.

Q: At where?
A: At my apartment in New York.

Q: And what's his first name?
A: I told you I don't know.

Q: He still there now?
A: I believe so.

Q: Do you know whether you gave Mr. Fuhrman any gloves?
A: I don't know specifically what. I just know I put good things in a bag. Sometimes he'd come up and take some real good stuff. And then there would be a bunch of bags. Some of them get thrown away. Some of them they go through, you know. I left it up to him.

Q: Where would you leave the bags?
A: They come up to my apartment. Somebody would come up to my apartment and take them down.

Q: You would call them up?
A: Yeah.

Q: And say, "Here, you can"--
A: "I got a bunch of junk up here, you guys, if you come and get it," and they come and just grab the bags and...

Q: So you didn't parse out specific items--
A: No.

Q: --to people. Right?
A: No. I just basically took out things that I liked, and then everything else went.

Q: Do you recall ever giving away specifically a pair of gloves?
A: No.

Q: Okay. Do you do this every January?
A: Yes.

Q: Do you give gloves--excuse me. Do you give clothes away at any other time of the year?
A: Normally in the summer. Some times as early as the spring, but normally in the summer when I'm preparing to head back East.

Q: And you give clothes away at Rockingham?
A: Yeah.

Q: And who do you give them to?
A: Michelle handles that. You know, so much of it goes to my family up to San Francisco; gets boxed, or if they're down, they'll drive it up; and some friends, and Goodwill.

Q: How do you replace these clothes you give away?
A: With money at stores.

Q: You go and buy them yourself?
A: Most, yeah.

Q: You told the viewers in your video that the prosecution tried to intimidate various witnesses and get them to change their testimony. Who are these witnesses?
A: I don't know to change their testimony, but I felt to skew their testimony from what I got from them. A couple for sure would have been Cora Fishman. Christian Reichardt.

Q: And how do you know that?
A: From what they told me.

Q: What did they tell you?
A: Cora said every time she would answer their questions, they would tell her, "You're not"-- "How could you say that? You're not"--"I thought you were Nicole's friend," you know, words like that, which didn't sound like they were after the truth to me.

Q: And what about Christian?
A: Well, Christian told me he literally almost got into a fight with Darden and, you know, they had to turn off the thing, and they got into an argument because he was--you know, Darden didn't seem to like what Christian was saying.

Q: About what?
A: I don't know. Whatever the interview was about.

Q: Anyone else tell you that they had been--Well, withdrawn. Did Fishman and Reichardt tell you they were intimidated?
A: I don't know if those were words they used.

Q: That was your word, "intimidate"?
A: I thought the attempt was to intimidate, Yes.

Q: Okay. And any other witnesses tell you that the prosecutors tried to skew or alter their testimony?
A: Tell me, no, but I just saw conflicting--and I can't name any specifics, but conflicting police reports from when we interviewed people, what those people said.

Q: And from that you drew the conclusion that they were skewered [sic]?
A: Yes.

Q: But no one ever told you. Right?
A: Well, that's my word, "skewed," Yes.

Q: No one ever told you that. Right? Those witnesses didn't tell you that did they?
A: No. I thought the--no.

Q: Okay. Now, you also said in your video that the District Attorney went to a number of your former girlfriends and even offered $200,000 for information. Who did they offer that money to?
A: I believe it was--they were talking about media and stuff, and maybe it got misconstrued that it was the D.A. that offered the money. The media had offered the money to virtually every--I mean, to people like Tawny. I think there was a girl named--I can't think of her name, who left a message with Cathy that they were--they had--they had been offering her money. Marquerite. Various people were trying to offer them money to tell their story about O.J., but it seemed they all wanted negative stories.

Q: You're telling me that the media or the tabloid media was offering this money. Right?
A: Yes.

Q: Not the District Attorney. Right?
A: Correct.

Q: You said on the video that regarding the blood at Rockingham and the Bronco, you were not sure that it was yours, you didn't think it was yours, words to that effect.
A: Uh-huh.

Q: Was the blood found in the Bronco and at Rockingham your blood?
A: I don't know.

Q: Do you think it was your blood?
A: Personally, no, but...

Q: You don't recall depositing blood at the various blood spots where blood was found at Rockingham. Is that right?
A: That's correct.

Q: And you don't recall ever depositing blood in the Bronco where the blood was found?
A: That's correct.

Q: And if that blood were to be your blood, you have no idea how it got there. Is that true?
A: That's correct.

Q: So just so I'm clear on this, you don't recall any earlier occasions, that is, earlier than June 12, when you deposited blood in the Bronco.
A: Correct.

Q: Or at the various spots at the Rockingham location where blood was found. Correct?
A: Correct.

MR. PETROCELLI: I have to ask you about the subject of documents because we still haven't gotten anything, and there is a lot of things we requested, including, for example, his own gloves and shoes and various items.

MR. ROBERT BAKER: We objected to it all.

MR. PETROCELLI: You've objected to everything, suffice it to say, and we are going to have to take this to the court, and if we get further documents, then there will have to be further questions. If we get documents, I should say, because we haven't gotten anything.

MR. ROBERT BAKER: How we learned to do this was we looked at your responses to our requests--

MR. PETROCELLI: No, that's not true.

MR. BREWER: That's not the test, Mr. Baker.

MR. ROBERT BAKER: I think you're right, Mr. Brewer.

MR. PETROCELLI: Okay.

Q: Now, on Rosey Greer, when he came to the prison to visit you--Well, he did come to visit you. Right?
A: Yes.

Q: Okay. You heard reports of a so-called confession that others overheard?
A: Yes.

Q: Okay. Did you tell Rosey Greer that you killed Ron and Nicole?

MR. ROBERT BAKER: Don't answer that.

MR. PETROCELLI: You are not going to let him answer?

MR. ROBERT BAKER: No.

MR. PETROCELLI: Okay. So what's the ground? The privilege?

MR. ROBERT BAKER: Yes.

MR. PETROCELLI: Okay.

Q: In all of your discussions with Mr. Greer, you--did you understand that he was acting as a minister?
A: Yes.

Q: And it was only in that capacity that you spoke to him?
A: Yes.

Q: And in any of those conversations, were you ever speaking in a loud or upsetting tone of voice?
A: I don't know.

Q: You don't know. Meaning you could or--
A: Yes, meaning I could have.

Q: And do you recall whether, when you were speaking in a loud or upsetting tone of voice, there were others around who you believe were in a position to hear you?
A: No. I knew that's not true.

Q: At no time did you ever see any body around who might have overheard what you were saying to Rosey Greer. Is that what you're saying?
A: Yes.

Q: Are you aware of this fellow who came forward and said that he overheard you?
A: Yes.

Q: Did he?
A: I don't know.

Q: When you were speaking to Rosey Greer, do you know whether this fellow was present?
A: No.

Q: What's this person's name? Do you remember?
A: I don't know.

MR. PETROCELLI: Do you have his name?

MR. LEONARD: Let's call the Enquirer.

MR. ROBERT BAKER: There was a photo opportunity for Ito after that.

BY MR. PETROCELLI:

Q: You read that tabloid report about your telephone call with Mercury Morris?
A: Somebody told me about it.

Q: Did you have any calls with Mercury Morris since you got out of jail?
A: No.

Q: When was the last time you've spoken to him?
A: I believe--I believe I ran into him sometime in the mid '80s. I believe so.

Q: And when was the last time you've spoken to Sugar Ray Robinson?
A: I did speak to him before he died.

Q: What about--I must have the wrong

MR. ROBERT BAKER: Sugar Ray Leonard?

MR. PETROCELLI: Sugar Ray Leonard.

MR. ROBERT BAKER: Robinson has

MR. PETROCELLI: Sorry. I have the wrong boxer.

Q: When is the last time you spoke to Sugar Ray Leonard?
A: I believe at his wedding.

Q: When was that? Before you went to jail?
A: Before I went to jail.

Q: When did Sugar Ray Robinson die?
A: I think in the '80s.

Q: Oh, okay. Forget that.

MR. KELLY: Another bum lead.

BY MR. PETROCELLI:

Q: On your video you do a demonstration about the lights, and I want to make sure that I understand that-- MR. ROBERT BAKER: It's right in front of you if you want this one, Dan.

BY MR. PETROCELLI:

Q: When the lights in the room where the televisions are turned on, can you see those from the front gate at night, the Ashford gate?
A: No.

Q: Cannot?
A: No.

Q: Can you see the coach rights in the entryway from the Ashford gate?
A: That are outside?

Q: Yes.
A: Yes.

Q: And can you see the kitchen lights?
A: It depends. It depends.

Q: What does that depend on?
A: What lights are on in the kitchen.

Q: Some lights you can see and some you cannot see?
A: Correct.

Q: And which ones can you see?
A: I think when they're all on, you probably can see it, but like if a lamp is on--I keep a on there at night, and if it's on, you can't see it from the street. And I believe maybe around the range, I'm not--I didn't test around the range, but I would imagine at least from one gate you couldn't see--you couldn't see it.

Q: I am only now referring to the Ashford gate. Right?
A: No, the Ashford gate I don't think you would be able to see--tell.

Q: And from the Rockingham gate, could you?
A: The range, if the range lights are on, maybe.

Q: Okay. What are the main lights in the kitchen? Are there some overhead lights?
A: Overhead lights, yeah.

Q: Now, when those lights are on, can you see those from Ashford?
A: You should be able to, yes.

Q: And can you see those from Rockingham?
A: You should be able to, yes.

Q: And when those are off but the lamp is on, can you see that from Ashford?
A: No.

Q: Can you see that from Rockingham?
A: No.

Q: If only the range light is on, can you see that from Ashford?
A: I really don't know about the range light.

Q: And can you see that from Rockingham?
A: I would think you could from Rockingham but I'm not sure.

Q: And if the lamp and the range light are on, can you see those from Ashford?
A: Can't see the lamp from either one.

Q: Okay. What lights, if turned on, could you see from Ashford at night besides the kitchen and the coach lights?
A: If my office lights were on, I would think you could see them.

Q: From Ashford?
A: Yeah. And if my daughter Sydney's room's lights were on, you should be able to see.

Q: Okay. And can you see the office lights from Rockingham at night?
A: I don't know. You should be able to I would think, but I'm not sure if the trees get in the Way.

Q: And Sydney's room at night?
A: Yes.

Q: Now, if you were outside in your property in the backyard, could you see the lights on in the kitchen?

MR. ROBERT BAKER: Out by the pool area?

MR. PETROCELLI: Yeah.

THE WITNESS: If the doors are open, you may be able to detect light. You couldn't see the lights, no.

BY MR. PETROCELLI:

Q: Could you see the lights on--Withdrawn. If you were outside, leaving Kaelin's room and going past the pool and circling around the pathway to the driveway Okay?
A: Uh-huh.

Q: --what lights could you see on the downstairs if they were on?
A: You should be able to see all the TV room, the living room. If my drapes are drawn--not drawn, you should be able to see my bedroom you should be able to see my bathroom as you go around the back. As you come around the front, you should be able to see the kitchen, the office and Sydney's room and the hallway. If the--you know, the foyer lights up there. It depends what lights are on.

Q: Okay. Now, between--From the time you got back from McDonald's--By the way, you say on the video that was close to 10:00 o'clock. In fact that was 9:30 or so, wasn't it?
A: I don't believe I said that on the video. I think I disagree with you on that.

Q: Okay. Forget what you said on the video. You came back
A: 1-800-OJTELLS video?

MR. PETROCELLI: Could you redact that, Mr. Reporter?

MR. ROBERT BAKER: I think it was totally responsive.

BY MR. PETROCELLI:

Q: And you got back around 9:30 p.m. Right?
A: I believe it was 9:35. I don't know. Somewhere in that area.

Q: Okay. From that time to the time when you--right before you came downstairs for the first time. Okay? It wasn't asked and answered.

MR. ROBERT BAKER: Yes, it was, and in excruciating detail.

MR. PETROCELLI: No. I am asking him this following question:

Q: What lights in the house were on?

MR. ROBERT BAKER: We've gone into that.

MR. PETROCELLI: No, I have not asked that question. Trust me.

MR. ROBERT BAKER: See?

MR. BREWER: He's got it on an alarm.

MR. PETROCELLI: He's got an alarm for everything. It's my last part of this area, so...

THE WITNESS: Certainly my bedroom lights were on. Which ones, I can't tell you. I had a lot of different lights in my bedroom. Certainly my bathroom lights were on. I believe my entry lamp was on, and I believe my kitchen lamp was on, because when I close up the house at night, those are the lights I always leave on.

BY MR. PETROCELLI:

Q: All those lights were on during that interval from roughly 9:35 to, let's say, quarter to 11:00?
A: Well, I don't know about 9:35 because at 9:35 maybe most of the downstairs lights were on. I turned them off at some point when I went upstairs to do my final stuff.

Q: Okay. So when you went upstairs to do your final stuff, then you had the lamp light on in the kitchen. Right?
A: I'm pretty sure they were on because they--that's what I normally do, and I can't imagine I wouldn't have that night.

Q: The entryway light was on inside your house. Right?
A: The lamp entry.

Q: By the way, can you see that from Ashford through the glass of the front door?
A: No.

Q: Okay. So that's two lights. And downstairs, any other lights on?
A: I don't believe so.

Q: Okay. And the other lights that were on were in your bedroom and in the bathroom. Right?
A: Yeah, for sure. And in my closet probably.

Q: Okay.

MR. PHILLIP BAKER: Go back to 546, Dan.

MR. PETROCELLI: I'm done with that Mr. Baker. We can move on.

MR. PHILLIP BAKER: It took me too long.

MR. PETROCELLI: Asked and answered is not an appropriate objection, anyway.

MR. PHILLIP BAKER: The black robe's back on.

MR. PETROCELLI: Okay, that's that.

Q: Did you play golf with Bill Thibodeau anywhere in May or June of '94?
A: I don't--certainly not June. Maybe I played with him once in May. I'm not sure.

Q: Did you tell him about plans to throw a birthday party for Nicole?
A: Not in May I wouldn't have, no.

Q: No time in May or June of '94. Right?
A: Not in May I wouldn't have, no.

Q: And not in June either, obviously.
A: No. Her birthday was over at that time.

Q: Did you tell Bill Thibodeau that Nicole is just ripping you up, or words to that effect?
A: No.

Q: Tearing up your insides? Nothing like that?
A: No.

Q: Did you have any kind of conversation with him about Nicole?
A: No.

Q: Have you heard him say that?
A: Someone told me that he was saying that.

Q: Do you know why he's saying that?
A: No.

Q: Did you know about any calls Nicole made to a battered woman shelter?
A: No.

Q: Had she ever spoken with you about a shelter?
A: No.

Q: About Sojourn?
A: No.

Q: When we left off the first round of your deposition, I was coming to the subject of your watching this movie GARP with Kato Kaelin.
A: Uh-huh.

Q: You heard Mr. Kaelin testify about that. Correct?
A: I don't recall exactly what he testified, but yes.

Q: On Saturday, June 11, you were watching TV with Kaelin for a while in your house?
A: Yes, I believe so.

Q: And this movie GARP came on?
A: Yes.

Q: And there is this scene where someone is performing oral sex?
A: Yes.

Q: And at that point in the movie did you make any comment about Keith Zlomsowitzh?
A: I doubt it, but it is one of my favorite scenes, not only when I read the book, but when I saw the movie.

Q: You mean scenes in the movie. Right?
A: Yeah. Yeah.

Q: Yeah. Now, when you--And you've seen that scene many times. Right?
A: No.

Q: But whenever you have seen that scene, do you think of this incident when you observed--
A: I think this is the only time I--

Q: --Nicole performing oral sex on Keith Zlomsowitzh?
A: I don't think so. That's probably the only time I saw the movie since that incident.

Q: Oh, that day in your house?
A: Yeah.

Q: And did you say anything like that to Kaelin?
A: I don't believe so.

Q: But you're not sure?
A: I don't think I discussed Nicole's personal thing with Kato.

Q: That incident.
A: I don't believe so. I don't ever recall discussing that--that incident with--it wasn't something I talked about a lot.

Q: Did you ever discuss that incident with Kaelin on any occasion?
A: I don't recall. I don't recall ever discussing that with Kaelin. I know he was at the house in the '93 thing, but I don't recall discussing that with him, no.

Q: Did you have a photograph of Nicole under your bed?
A: They say I did, yeah.

Q: Do you know how it got there?
A: You know, the picture I saw at the foot of the bed--I don't know how. I do recall once taking a picture off our bed stand, putting it under the bed when Paula was coming to the house after we got back together, because I'm not--I got so many pictures in my house, I'm not aware of pictures, but women are always aware of pictures.

Q: When you broke up with Nicole in May Of '94, did you take any pictures down in your house?
A: I'm pretty sure, if there was a picture next to my bed, once Paula came over I probably slid it. You know, if I'm in bed and Paula's coming, I probably got rid of it some way, some way, shape or form, yes.

Q: You think you put it under your bed?
A: I could have done that yes.

Q: And did you take out or remove any other photographs of Nicole?
A: Not that I recall, no.

Q: Did you make a deal with a tabloid magazine or with some independent company for money in return for pictures of you at Nicole's grave site?
A: No.

Q: Did you ever enter into a contract that had such a provision in it?
A: There was a contract that they wanted something like that, but I told them I wouldn't do it.

Q: Did Skip Taft sign such a contract on your behalf?
A: I don't know.

Q: That's with a company that sold the photos to the Star. Right?
A: Yes.

Q: And how did you find out there was such a provision in the contract?
A: Well. at one point when Skip was going over--

MR. ROBERT BAKER: You don't have to talk about anything that relates to Skip-- THE WITNESS. Okay.

MR. ROBERT BAKER: --any conversation you had with Skip.

THE WITNESS: All right.

MR. PETROCELLI: I am going to ask him about such a conversation. You are not going to let him answer that question. Right?

MR. ROBERT BAKER: True.

MR. PETROCELLI: Okay.

MR. ROBERT BAKER: You are going to ask him about--

MR. PETROCELLI: I will ask him about another Skip Taft conversation, because he mentioned it in a public statement.

Q: Finishing this off, though, you didn't--did you authorize Skip Taft to sign such a contract?

MR. ROBERT BAKER: Well, when you say "such a contact," do you mean that included--

MR. PETROCELLI: Yes, I mean that.

MR. ROBERT BAKER: That included--

BY MR. PETROCELLI:

Q: Included a provision where you would get money for pictures of you at Nicole's grave.

MR. ROBERT BAKER: Don't answer that. That's irrelevant to any issue in this case, in any event, but he has already answered that.

MR. PETROCELLI: Goes to consciousness of guilt.

Q: Anyway, do you want to answer the question?

MR. ROBERT BAKER: No, he is not going to answer the question. That is a quantum leap, I'll tell you, "Petrocelli on Evidence."

BY MR. PETROCELLI:

Q: Did you sell any pictures of you at the grave site?

MR. ROBERT BAKER: Don't--

THE WITNESS: No.

BY MR. PETROCELLI:

Q: How many times have you been there?

MR. ROBERT BAKER: Don't answer that. It's irrelevant to any issue.

MR. PETROCELLI: He discussed this on your video.

MR. ROBERT BAKER: So what? Does that make it relevant.?

MR. PETROCELLI: Well, he thought it was important enough to put on his video. He's made a statement out there. The video was done with the cooperation of attorneys of record in this case on your side. I think I am entitled to ask about it.

MR. ROBERT BAKER: We disagree. Don't answer it.

BY MR. PETROCELLI:

Q: Okay. When you were informed of Nicole's death in Chicago, did you call your lawyer and ask him to go to your house and go to Nicole's house?

MR. ROBERT BAKER: Well, don't answer that question.

MR. PETROCELLI: Well, he said this on national television.

MR. ROBERT BAKER: I don't care what he said on national television.

BY MR. PETROCELLI:

Q: You told that to Roger Cossack and Gretta Van Susteren, didn't you? And I asked you those questions in the deposition, and you wouldn't tell me. Would you answer the question now?

MR. ROBERT BAKER: No.

MR. PETROCELLI: On what ground?

MR. ROBERT BAKER: Attorney-client privilege.

MR. PETROCELLI: How can it be privileged? He waived it.

MR. ROBERT BAKER: By saying he did it doesn't waive the content of the privilege. You can ask him if he did it. By MR. PETROCELLI:

Q: Okay. Did you call your lawyer and ask him to go to your house and Nicole's house?

MR. ROBERT BAKER: Well, no, the content-- Well, go ahead and answer since it's in there.

THE WITNESS: Yes.

BY MR. PETROCELLI:

Q: And who was the lawyer?
A: Skip Taft.

Q: And before Skip Taft picked you up in Chicago--excuse me--at LAX with Cathy Randa, do you know whether he had gone to your house?

MR. ROBERT BAKER: That calls for attorney-- client communication.

MR. PETROCELLI: Well, he might have found out from Randa or someone else.

MR. ROBERT BAKER: If you found out from Randa, you can answer the question.

THE WITNESS: I didn't find out from Randa, no.

BY MR. PETROCELLI:

Q: Did he go to Nicole's house?

MR. ROBERT BAKER: And you cannot answer that if the only way you found out is from Skip.

THE WITNESS: I can't answer that.

BY MR. PETROCELLI:

Q: Do you know, when you arrived in Los Angeles back from Chicago, had Cathy Randa been to the Bundy property? Do you know that?
A: I don't know that.

Q: Had she been to your home in Rockingham?
A: I think so, but I don't know that for sure.

Q: And what did you ask her to do at Rockingham?
A: Nothing.

Q: What clothing did you put on when you left Chicago to go back to LA.?

MR. ROBERT BAKER: We've been through all of this.

THE WITNESS: I started off with some jeans, and I ended up before I left with some black pants and a white shirt and whatever.

BY MR. PETROCELLI:

Q: Before you left the hotel?
A: Yeah, I changed before I left the hotel.

Q: Okay. So when you left the hotel, you had black pants on and a white shirt, and you stayed in that outfit all the way--
A: Yes.

Q: --till you got to--the rest of the evening. Right?
A: Yes.

Q: And you never changed your clothes. Right?
A: No.

Q: You mentioned something to Gretta Van Susteren and Roger Cossack that I want to follow up on, make sure I understand, and it concerns the buzzing of your gate at Ashford.

MR. ROBERT BAKER: What page are you on?

MR. PETROCELLI: It's on f this transcript of the show.

Q: And as you're talking about Alan Park, and you say: "He called me on two occasions at that time. You don't buzz my gate. My gate is not a buzz gate. He could have pushed it eight times. The phone is going to ring X amount of times and stop. It's not a when you push the button the gate buzzes. It doesn't work that way. I don't know if the prosecution ever took the time to figure that out. It just doesn't work that way." What did you mean by the gate not being a "buzz gate"? I don't understand what you were saying there.
A: It's not--when you push the button, it doesn't buzz.

Q: When you push the button at the Ashford gate, what happens? Your phone rings. Right?

MR. ROBERT BAKER: You mean from the exterior of Ashford and the button outside--

MR. PETROCELLI: Yes.

MR. ROBERT BAKER: --the Ashford driveway door--driveway gate, rather?

BY MR. PETROCELLI:

Q: There is a button and there's a little speakerphone there--not a phone, but a little speaker outlet?

MR. ROBERT BAKER: Box.

BY MR. PETROCELLI:

Q: Speaker box. Right?
A: Uh-huh.

Q: Correct?
A: Yes.

Q: And there is no telephone or any thing. Right?
A: No.

Q: And when the person presses the button, does that person hear anything from pressing the button?
A: I don't believe so.

Q: The only thing that person might hear is the phone ringing inside your house. Right?
A: Possibly.

Q: Okay. And if that person--When you pick up the phone and talk, the sound comes out of a little speaker box. Right?
A: Correct.

Q: Now, if that person wants to talk back, can he just start talking and you'll hear?
A: Yes.

Q: He can only hear, however, once you have picked up the phone receiver. Right?
A: Correct.

Q: He can only speak, I mean, once you-- and be heard by you once you pick up the receiver. Right?
A: Correct.

Q: So if he starts talking right away, you won't hear anything in the house. Right?"
A: That's right.

Q: Now, when the phone rings in the house, does it ring exactly like an ordinary phone call?
A: I believe so. Maybe a little different, but basically it's the same.

Q: And if it rings and rings and rings and you don't pick up, it will just continue to ring until he stops. Right?
A: No. I think it may ring eight or nine times and then stop.

Q: And then it won't ring anymore until you press the button again?
A: Yes.

Q: And you may have told me this already, but when you went to let him in from your telephone, what do you do upstairs in your bedroom?
A: I push a number.

Q: Push a number and then the gate can open. Right?
A: Yes.

Q: How long will the gate remain activated such that it can open?
A: I don't understand the question,

Q: In other words, if he is on the phone and you're pressing the button, he has to get off--or get out of the speaker box area, get into the car--
A: When the gate opens, there's no timer.

Q: When the gate opens, it stays open?
A: Yeah, till you push the button to close it.

Q: I see. It doesn't close automatically. Right?
A: Correct.

Q: What didn't the prosecution figure out that you were referring to?
A: That there is no--my phone is not a buzzer.

Q: That your phone is not a buzzer?
A: Yeah.

Q: As opposed to a normal ringing phone. Right?
A: Yes.

Q: Okay. Who were the two or three witnesses that you were praying they would put on the stand?
A: I don't recall.

Q: You don't recall?
A: I don't recall.

MR. ROBERT BAKER: Gretta was one of them.

BY MR. PETROCELLI:

Q: Excuse me?
A: I don't know. Maybe I'll be refreshed in this trial.

Q: You do recall, but you don't want to tell me?
A: I don't recall.

Q: Actually you do say, "And these guys might put them on the stand," I guess referring to us. Right?
A: Yes.

Q: So let us know who you're talking about, and maybe we'll comply.

MR. ROBERT BAKER: Don't bother, 0.J.

THE WITNESS: I don't recall.

MR. PETROCELLI: Okay.

Q: You also said in--to a national television audience that there was no doubt in your mind whatsoever that the answer to these murders are in the world of Faye Resnick.
A: Yes.

Q: Okay?
A: Yes.

Q: Now, tell us what you know that leads you to that belief.
A: That she's lied about every--so much, I should say, since this thing is over, and I can't believe that a person would lie the way she has for no reason. She claimed her life was in danger early on, which I guess it was, and she claims her life is in danger now. Certainly not from me, but I wouldn't be surprised. But when a person--when a tragedy like this hits and a person starts changing the truth and lying to the police or to the prosecutors, to me that's a consciousness of guilt of some sort, and, you know, I just noticed that the bizarre--what I thought, the bizarre way Nicole was acting seemed to somehow be related to Faye Resnick.

Q: Is that the only thing on which you base your conclusion?
A: Yeah, lying, the way she's been lying so much. I think that's pretty good.

Q: You don't know of any witnesses to the murder, do you?
A: No.

Q: Okay. Had anyone ever told you that the killer or killers were somehow related to Faye Resnick?
A: Told me that they were?

Q: Yeah.
A: No.

Q: Or had something to do with Faye Resnick?
A: No.

Q: Do you have any other information other than the fact that she lied in her book?
A: Not only in her book. She seemed to lie everywhere. She lied under oath to you guys, from what I gather, so that's probably more than anything.

Q: Do you know who she was buying--excuse me. Do you know who she was purchasing drugs from?
A: No.

Q: Do you know of any confrontation that she had with any drug dealers?
A: Know of firsthand?

Q: Yeah.
A: No.

Q: Or secondhand?
A: Well, I've been told about something that happened in San Francisco once.

Q: When?
A: I guess before she moved to LA.

Q: What year?
A: I don't know.

Q: Early '90s?
A: I have no idea. Before she moved to L.A. is all I know.

Q: What happened?
A: And once again, this is rumors. I'm as bad as she is maybe. But that a friend of hers was murdered, and her husband at the time or--Hutchinson or Hallaby or something, they both got out of the country, ended up in Australia, and when things calmed down she came back.

Q: Did you ever talk to Faye about that?
A: No, but Nicole evidently did because Nicole was the first person to tell me that story.

Q: Is that the only way you know that: From Nicole?
A: I don't know. Since that time I think I read where some ex-boyfriend of her--or the guy that she was having an affair with went on some show and talked about this--all this stuff happening.

Q: Faye was admitted to a treatment center on June 9. Right?
A: I don't know, but I'm told that, yes.

Q: Yeah. What did she lie about in her deposition?

MR. ROBERT BAKER: Don't, don't, don't, don't. Don't answer that.

BY MR. PETROCELLI:

Q: You said she lied in her deposition. What did she lie about?

MR. ROBERT BAKER: He said he thinks she lied, so he's not--that's irrelevant to any issue in this case, and he is not going to answer that question.

MR. PETROCELLI: Okay.

MR. ROBERT BAKER: What his opinion of what her lies are.

MR. PETROCELLI: It's not his opinion. He said she flat-out lied.

MR. ROBERT BAKER: The only way he could tell when Faye Resnick was lying was when his lips--her lips were moving, so that's our view of Miss Resnick.

BY MR. PETROCELLI:

Q: Do you agree with your lawyer?

MR. ROBERT BAKER: Don't--you don't have to answer that, and you don't have to agree with me or disagree with me. We are not going to get into that.

BY MR. PETROCELLI:

Q: Do you know--Excuse me. Do you know if anyone spoke to Nicole after she came back from Mezzaluna on June 12?
A: You mean had a conversation with her?

Q: Yeah.
A: No.

Q: Do you know any of her movements or activities after she returned from Mezzaluna till the time of her death?
A: No.

Q: Have you spoken to anyone who said he or she spoke to her during that time frame?
A: No.

Q: Have you spoken to your children about their mother's movements or activities in the home that evening?
A: No.

Q: You ever spoken to Sydney about it?
A: No.

Q: You said something on the video or perhaps in the burden of proof interview about Sydney's last observations of her mother.
A: Yes.

Q: You said that Sydney heard her mother crying. Do you recall that?
A: Yes.

Q: How do you know that?
A: It was in a police report.

Q: I see. The only knowledge you have of Sydney's observations is what you read in the police report?
A: Yes.

Q: And you have never once spoken to Sydney about that evening?
A: And never will. Till she wants to when she gets older.

Q: And you've never spoken to your son Justin either. Correct?
A: No.

Q: Okay. Have you, since you were released from prison, done anything to track down the real killer or killers?

MR. ROBERT BAKER: Don't answer that. It's irrelevant to any issue in this case.

BY MR. PETROCELLI:

Q: You made a statement or a statement was read on your behalf following your acquittal that you would devote your life's work to finding the real killer or killers. Is that right?
A: Correct.

Q: What have you done in that regard?

MR. ROBERT BAKER: Well, you don't have to answer that.

BY MR. PETROCELLI:

Q: Have you done anything?

MR. ROBERT BAKER: You know, he doesn't have to answer that. That has nothing to do with this case.

MR. PETROCELLI: Well, I disagree, but you're not going to let him answer?

MR. ROBERT BAKER: No.

BY MR. PETROCELLI:

Q: Did you sleep at all on the plane going to Chicago?
A: I may have dozed, but I wouldn't call it sleep, but I may have dozed for a while.

Q: Were you-- Quick, Phil. Were you agitated?

MR. ROBERT BAKER: Come on. Enough. Enough. This is enough. Seven days is enough.

BY MR. PETROCELLI:

Q: Were you agitated or nervous on that flight?
A: No.

Q: Okay. Now, when I questioned you about your calling the house that evening on June 12th, I believe you told me that Nicole answered the phone and you said, "Let me speak to Sydney," and the phone was handed to Sydney, and there was no conversation at all with Nicole. Do you recall that?
A: There was no conversation with Nicole, that's correct.

Q: Now, when you called Gretta Van Susteren, you said, "Is Sydney asleep yet?" And Nicole said, "No."
A: No. I said, "Is Sydney asleep?" and she handed the phone to Sydney.

Q: Well, the transcript said she said "No."
A: Well--

Q: Is that correct, or--did she say "No" to you?
A: That's probably incorrect. She handed the phone to Sydney. And she may have said "No" and handed the phone to Sydney.

Q: I see. You asked the question, "Is Sydney asleep yet?"
A: Yeah. Yeah.

Q: Or did you say, "Can I speak to I Sydney?"
A: I believe I said, "Is Sydney asleep yet?"

Q: And what's now your best recollection?
A: I believe that would be the best recollection.

Q: And what is your best recollection of what Nicole said or did?
A: She handed the phone to Sydney.

Q: With no conversation.
A: No conversation.

Q: And Sydney hung up the phone without giving it back to Nicole?
A: Yes. I assume she was in Sydney's room or Sydney was in her room.

Q: You heard Denise Brown testify about an incident at the Red Onion where you grabbed Nicole's crotch?
A: Yeah, I believe we talked about this.

Q: I didn't find it in the transcript. Let me just ask you: Did that occur?
A: No.

Q: You never grabbed her crotch. Right?
A: No.

Q: At any time. Right?
A: No.

Q: You're saying "No." You mean correct. Right?
A: Correct.

Q: Okay. Have you ever talked to Sydney about whether she observed any incidence of abuse?
A: No.

Q: Or your son Justin?
A: No.

Q: At any time?
A: No.

Q: Was there an incident in--Withdrawn. Do you recall an incident in Cabo in April of 1994 where you were flirting with a woman in a restaurant and Nicole got upset?
A: No.

Q: That never occurred?
A: Never occurred.

MR. PETROCELLI: Okay, that's all I have for now, subject to a number of objections and instructions not to answer and, of course, not getting any documents or materials that we requested, and also subject to the final phase on the punitive damage examination.

MR. ROBERT BAKER: Roll 'em. Michael, how long do you have approximately? And how long do you have approximately, John?

MR. BREWER: Seven days.

MR. ROBERT BAKER: Don't do that to me.

MR. KELLY: No one wants to Lay the foundation at [Unintelligible].

MR. BREWER: I probably have half a day.

MR. ROBERT BAKER: Okay.

MR. BREWER: Possibly a day. Half a day.

MR. KELLY: Or more.

MR. ROBERT BAKER: We can finish this up by Tuesday if

MR. PHILLIP BAKER: Dan's still got

MR. PETROCELLI: I've got to do the punitive damage. I guess that'll take half a day at the most.

MR. PHILLIP BAKER: Half, half and a full.

MR. KELLY: Are we on right now or

MR. ROBERT BAKER: Yeah. All I'm trying to do is--I'm tired. But I don't want--you've got to get back to Boston one of these days.

MR. LEONARD: Yeah, I mean, let's go.

MR. KELLY: Can we go off the record?

THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 3:13.

[Recess.]

THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 3:17.

EXAMINATION BY MR. BREWER:

Q: Mr. Simpson, I want to focus for a couple minutes on the Rockingham property, and on three specific time periods, the first being 6-12-94, and then the second time period the time that you were shooting the videotape. All right? You awake?
A: Uh-huh.

Q: Yes?
A: Yes.

Q: You okay to go on?
A: Yes.

Q: All right. Between those two time periods has there been any substantial changes in the foliage of the property?
A: I'm sorry. Between when I shot the video?

Q: 6-12-94 and when you shot the video, has there been any substantial changes in the foliage? Have you done any plantings, any changes in the foliage to the property?.
A: Okay. Since the 6-12 of '94 to the video that was shot this time?

Q: Yes.
A: I would think that it's alot thinner. That I could tell you specifically: It's a lot thinner along the southern portion.

Q: By the pathway?
A: Yes.

Q: Okay. Was that thinned out under your direction?
A: No.

Q: Okay. Was that through the gardener?
A: Evidently.

Q: Okay. And you didn't have any discussions with the gardener about thinning out that area?
A: No.

Q: Any other foliage that changed during that time frame?
A: My whole property seemed to when I got back seemed to be changed. I mean, stuff was growing where it shouldn't have grown and flowers weren't blooming. Yeah. You know, in general, yes, I think it looked not to be as kept up as it was when I was around.

Q: Between the same time frame, were there any changes that were made under Your direction to the foliage of the property?
A: No. I mean. Once I got back home, I-- you know. I had made some things--I wanted him to try to get some color back and to cut some of the trees that were growing through the tennis court fence, and the tennis court was basically being overwhelmed.

Q: Okay. Were those changes made prior to the videotape being shot, the 1-800-OJTELLS videotape?
A: I don't think they--I don't think the tennis court shows on the 1-800 videotape.

Q: Okay. The areas of the property that are depicted in the 1-800-OJTELLS videotape, are those areas substantially similar at the time that the videotape was shot as of 6-12-94?

MR. ROBERT BAKER: With the exception of the south pathway?

BY MR. BREWER:

Q: Yeah, with the exception of what you've already mentioned. In terms of just the foliage now.
A: I can't tell. It just seemed it was better kept when I was around than it was when I came home. There was areas that we normally had flowers or roses that there weren't any, so...

Q: Okay. With respect to the operation of the Ashford and Rockford gates, were there any changes between 6-12-94 and the shooting of the videotape to how those gates worked?
A: How they worked?

Q: Yes.
A: I don't believe so.

Q: Okay. So what's depicted in the videotape as of--the OJTELLS videotape in terms of the operation of both gates is the same as of 6-12-94?
A: You mean how you could--you know, I walked out of the Ashford gate then. I mean--I'm sorry. I walked out of the Rockingham gate, which I obviously could have disengaged the controls back then. So basically, as far as I know the basic mechanisms are the same.

Q: Okay. The operational aspects of the gates, the Ashford gate and the Rockingham gates, were the same at the time that you shot the videotape as of 6-12-94?
A: Yeah, the ability to operate them Various ways as far as I know is the same.

Q: How about the lighting outside on your property, not inside but outside around the property? Was that substantially similar at the time that you shot the videotape as of 6-12-94?

MR. ROBERT BAKER: With the exception-- obviously we're in December and there's Christmas lights up, and 6-12 is June.

THE WITNESS: Yeah.

BY MR. BREWER:

Q: Talking about permanent lighting rather than, you know. transitional lighting like Christmas lights.
A: I believe the security has beefed up lighting.

Q: Okay. Well, was there nighttime filming? There was nighttime filming in the videotape. Correct?
A: Yes.

Q: Okay. Were the outside lights activated at the time that the nighttime filming was done?
A: I think where the lighting was beefed up was--you couldn't see from the footage of what you were looking at. I don't think they impacted that.

Q: Okay. The nighttime filming that was done, were the outside lights activated during that filming?
A: I think the coach lights were on.

Q: Okay. And any other lights that you're aware of that were on during that film?

MR. ROBERT BAKER: Exterior?

MR. BREWER: I am just talking about exterior right now.

THE WITNESS: That you can see on the video, I don't think any that wouldn't have been operational then.

BY MR. BREWER:

Q: Okay. So the lights were substantially similar as of the videotape Strike that. The lights were substantially similar as of the time of shooting the videotape as compared with 6-12-94. Correct?
A: The lights that you can see on the nighttime shooting, those lights that are visual I think are similar and the same. There are other lights that has been beefed up in other areas of the property, but I don't think--they come to play on that. The only nighttime video I recall is the show that you can't tell what lights are on in my house, and from what I can see on that, the lights are virtually the same.

Q: After 6-12-94 was there any change in the wattage of the coach lights, making them brighter or less bright?
A: I can't say for sure. I do know inside the house there was.

Q: Well, how about the coach lights? you--Were new lights put in under your direction that added more brightness
A: No.

Q: --or more wattage?
A: No.

Q: Okay. The new lights that you're talking about that aren't necessarily depicted on the videotape where are those lights? Exterior lights
A: In some trees and focusing on some areas which the security people think my property may be vulnerable from.

Q: Okay. Are these in the back of the house, the side of the house or in the front?
A: In all areas, I believe.

Q: Okay. Including the front?
A: Yes.

Q: Have there been any new structural changes--Strike that. Have there been any structural changes since 6-12-94 to the shooting of the videotape? And what I mean by that, where you have had some change in--some new structure put up or a change in the garage or a change in the inside of the house or something of that nature?
A: Other than some bamboo--I mean, some what they call bamboo sheeting that we have up now so that the lookie-loos can't see through. I think they put a solid board on both gates. So before where you could see through the gates, you can't now.

Q: Okay. Is that permanent or temporary, the bamboo?
A: The bamboo hopefully is temporary, but who knows.

Q: Okay. How about the benches in front of the front door, are those still there?
A: Yes.

Q: The two benches?
A: Yes.

Q: In the same position?
A: Yes.

Q: Now, you've described the locks, the various locks throughout the property, indicating that there was a master key that you had and that the rest of the locks were controlled by individual keys. Is that correct?
A: That's correct.

Q: Okay. Is that the same at the time of the videotape as it was as of 6-1294?
A: I don't know.

Q: Well, were there any changes made to the locks under your direction?
A: No.

Q: So presumably they'd be the same. Correct?
A: I can only--it would only be a guess on my part.

Q: Well, do you have any information that the locks were changed after 6-12-94?
A: No.

Q: Any changes to the--Now, again I want to go inside now and talk about flooring. Any changes to the flooring since 6-12-94 and the shooting of the videotape?
A: I'm sorry?

Q: Any changes to the wooden flooring inside the foyer area
A: No.

Q: --between 6-12-94 and the shooting of the videotape?
A: No.

Q: Any changes in the carpeting that go up the stairs between 6-12-94 and the shooting of the videotape?
A: No.

Q: Interior lights, any changes in any of the interior lights? And I'm not talking about changing light bulbs to increase the wattage, but where you've had new lights put in between 6-12-94 and the shooting of the videotape.
A: No.

Q: Okay. Has there been any change in light bulbs inside your home where you've increased the wattage in, any particular rooms?
A: Yes.

Q: Okay. What rooms did you have lights put in that,would increase the wattage?
A: I think I increased the wattage in all my lamps.

Q: Was that done for a specific purpose?
A: I don't know. Maybe just to show the lamps off a little more, and I'm yeah, no specific person--purpose.

Q: Was it done for a specific purpose in relationship to shooting the video?
A: No.

Q: Was it done all at the same time?
A: I don't know. I don't know if it was done--I'm sure it was done while I was in jail.

Q: Well, do you have a specific recollection of having that done under your direction?
A: Under my direction, no.

Q: Okay. Why do you think that was done?
A: I think--because people were just in the house, and when lights go out--a couple of lamps, I would only burn one or two bulbs in them because they burn all night, and I think people weren't aware of that, and when they changing bulbs, they see they're all out. They put all new bulbs in.

Q: Okay. Are you assuming that when they put new bulbs in, they increased the wattage of the bulbs?
A: Well, they put more bulbs--I don't know about the wattage of the bulbs, but most of my lamps I Will only burn--they have room for four to five or six bulbs in the lamp. I would only burn two or three bulbs in the lamp, and evidently during the course of changing lamps, they put more wattage in those lamps.

Q: You said a moment ago that there are some lamps that you burn all night. Is that a practice that you follow: Burning particular lamps all through the night?
A: Yes.

Q: Okay. What lamps are those?
A: My entry lamp and the lamp in my kitchen.

Q: So those are on all night long, and you turn them off during the day?
A: Yes. Normally, yes.

Q: Are they on a timer?
A: Now they are. They weren't before.

Q: Okay. When did they first go on a timer?
A: I don't know.

Q: Well, but were they on a timer as of 6-12-94?
A: I'm not sure.

Q: Did you put them on a timer for--Strike that. Do you burn them all night for security purposes?
A: No. I wake up every night and walk my house, and so it keeps me from turning on lights.

Q: Okay. So you need some illumination in order to walk around your house?
A: Yes.

Q: Because otherwise--
A: I don't need it. You could without it, but, you know, it's easier to have it.

Q: Is there any light that comes into the house--any artificial light that comes into the house that would provide some illumination if you didn't have any of the interior lights off--on?
A: I think any lights--I don't know if it provides illumination. I can walk around my house with no lights on. If all my outdoor lights am on, I can--you know, I can--I'm not going to trip over a couch or nothing.

Q: Because of the illumination provided by the outdoor lights?
A: To an extent, yes.

Q: But those are lights on your property?
A: Yes.

Q: Are there any lights, streetlights, lamps off your property that provide illumination into your house that would facilitate your seeing as you're waking around?
A: I wouldn't be able to tell. I wouldn't be able to answer that.

Q: And you have no recollection with respect to whether these lights were on a timer--these all-night lights were on a timer as of June 12, '94?
A: None, no.

Q: The practice of your sometimes walking around at night, is that consistent with the entire time that you've lived at Rockingham?
A: Yeah. I don't sometime. I always take at least one walk around my house at night.

Q: Because of insomnia? You can't sleep?
A: No. I check on my kids, look out at the dogs, you know, take a leak. It's just always been my practice.

Q: Does the dog normally sleep outside?
A: Yes.

Q: Chachi?
A: Yes.

Q: How about in inclement weather?
A: Yes. I open the garage door.

Q: And you leave the door open, or do you shut the garage door?
A: No. I leave it open.

Q: The--There has been some--a lot of description and discussion relative to some gates along the south pathway. There's essentially two gates there. Is that correct?
A: I believe so.

Q: Okay. And the first gate, if you were to walk around the garage and then head in an easterly direction along that southern pathway, there is a gate that Mr. Kaelin described as having to pick up and kind of move to the side. Do you recall that description?
A: I recall that description.

MR. PHILLIP BAKER: Are we talking about the gates in June or as they presently are?

BY MR. BREWER:

Q: Are those gates--Was that an accurate description?
A: I don't know if it was an accurate description. I recall where the gate might have been, Yes.

Q: Is there still a gate there today?
A: I believe so.

Q: Okay. When is the last time you were along the southern pathway?
A: You mean all the way back the southern pathway?

Q: Well, crossing past the garage and then heading easterly through these two gates that have been described.
A: Maybe a month ago.

Q: Okay. Did you have to walk past two gates or open two gates to--
A: I don't recall.

Q: --walk back there?
A: I don't recall if the gates were open or not.

Q: Okay. Have you made any repairs to any of the gates along the southern pathway since June of 19---June 12th, 1994?
A: I don't know what state of repair they were in then, so I can't answer that.

Q: Okay. Well, you would know whether you hired somebody to come out and make a repair to the gate, wouldn't you.?
A: No.

Q: You wouldn't know that.
A: No.

Q: Okay. Have you ever picked up the phone and contacted anyone to come out and make a specific repair to any of the gates along the southern pathway?
A: No.

Q: Have you ever asked anyone to do that on your behalf?
A: No.

Q: Have you ever been told that that was done in your behalf?
A: No.

Q: Is it your understanding that the first gate that we're talking about, that Kaelin described as having to move aside, is in the same condition today that it was as of June 12, 1994?
A: I don't have an understanding one way or the other on that.

Q: On those occasions where you had to go back along the southern pathway, do you recall having to, in a similar fashion as described by Mr. Kaelin, pick up the gate and move it aside to walk in an easterly direction?
A: I don't have no recollection of that, no.

Q: Do you recall it being a chain-link type of gate?
A: I believe if there were gates there, they would be chain-link type gates.

MR. ROBERT BAKER: Mike, let's take a break. He's getting tired. Any problem with that?

MR. PETROCELLI: No.

MR. BREWER: No.

THE VIDEOGRAPHER: We are going off the record now, and the time is approximately 3:33.

[Recess.]

THE VIDEOGRAPHER: We are back on the record now, and the time is approximately 3:48.

BY MR. BREWER:

Q: Okay. Mr. Simpson, we are focusing on a time period between 6-12-94 and your shooting of the videotape. We have gone through a number of items where I've asked you whether there have been any changes. And focusing for the moment on Kato Kaelin's room and the interior of that room, were there any changes in the layout or configuration of that room between 6-12-94 and the videotape?
A: I'm not in a position to answer that because I hadn't been in that room in so long previous to that date. So, you know, I can't tell you. I can't answer it.

Q: Well, you've seen photographs that were introduced into evidence at the criminal trial of his room. Right?
A: Yeah, but the bed--the bed's in the same place.

Q: Okay. The picture on the wall to the right of the bed, is that still in the same place as of the shooting of the videotape?
A: I don't recall. I don't think so because I think--I don't think so. I don't know about as of the shooting of the videotape. As of the shooting of the videotape, maybe. I don't know. I just know that other pictures are up right now.

Q: Were there any changes made to the interior of his room under your direction?
A: I don't believe--of the interior of his room I don't believe so. I know--I don't believe so. Not to my direction, I don't believe so.

Q: Any part of his room exterior or interior, any changes made under your direction?
A: Maybe they got a new bedspread. Maybe-- I do know now, but I believe it's since the video, that there are different pictures and things in there, so I am aware of that. But as of the shooting of the video, because I wasn't aware of what was in there before and I never--I can honestly say what ever pictures came up in Kato's room I never really looked at it, so I can't--and I haven't been in that room you know, in a tremendous long time before Kato--you know, before that day. Since Kato lived in there, I hadn't been in there in--

MR. ROBERT BAKER: You've more than answered the question.

THE WITNESS: I don't know.

BY MR. BREWER:

Q: Were there any changes that you're aware of with respect to the interior of Kato's room that were done specifically for the videotape?
A: No.

Q: You mentioned a moment ago about a couple lights that you leave on through the night. Where exactly are those lights located inside your house?
A: One's on a built-in desk type thing in the kitchen, and one is built--one is on a--well, it's no longer an armoire. Sort of a sideboard in my entry.

Q: In your entry. Any other lights that you have a custom or practice of leaving on through the night other than those two?
A: Sometimes I'll leave--No. That was basically it, yeah.

Q: Are there lights that from time to time you leave on through the night other than those two?
A: From time to time, yes, but those are basically the lights.

Q: Other lights that you leave on purposely through out the night from time to time?
A: Those are two that I leave on. There's one other one that sometimes since I've been home I might have on from time to time.

Q: And where is that light located?
A: In my TV room. It's a lamp on the table in my TV room.

Q: What would dictate your leaving that on through the night?
A: Depending who's staying in the guest room and how active they might be as the evening goes on.

Q: Okay. How about Arnelle's room, either the interior or the exterior, between 6-12-94 and the shooting of the videotape, any changes that you're aware of?
A: Shooting of the video? I don't--were their rooms in the video?

Q: I am just asking: Were there any changes made to the room?
A: More than likely there were, but I don't know because I never--I didn't go out there so I don't know.

Q: Between--Strike that. At any time after June 12, 1994 did you direct that any repairs be made to the window outside Mr. Kaelin's bathroom?
A: No.

Q: How about outside Arnelle's room?
A: No.

Q: And now I am going to the third time frame I want to focus on is today, but I just want to go through like a checklist, and when I mention the item just tell me whether there has been any substantial changes made to that particular item so we can go through this. All right? You with me?
A: Yes,

Q: All right.
A: Today.

Q: Interior lighting? The time frame is between the shooting of the videotape and today. Okay?
A: I moved a lamp, and--other than maybe lamp bulbs, I moved a lamp.

Q: Okay. And what lamp did you move?
A: A lamp out of my formal living room into my TV room.

Q: Okay. And what was the purpose of moving that lamp?
A: Just to give it a different look.

Q: And did you replace any light bulbs since the shooting of the videotape that you specifically recall?
A: I'm sure we may have, but I can't specifically recall.

Q: Do you recall either yourself or directing someone to replace light bulbs, increasing or decreasing the wattage of those bulbs?
A: The lamp that we moved I think only had two bulbs in it, and since it's one of my favorite lamps, maybe the first one I purchased, and when we moved it to put it in another room, I think I filled it up with bulbs just to, you know, to get the full effect of the lamp. I don't know if we kept it that way. I think we burn two or three of those bulbs in it now, but when I first did it, I know I wanted to look at the full effect of the lamp.

Q: Okay. Other than this lamp, any other changes inside your home between shooting the videotape and today with respect to lighting?
A: I may have added a lily pad lamp to my bedroom.

Q: Okay. When you say "I may have," do you have a specific recollection between this time frame adding--
A: No, I don't know if it was there before I we shot the video or after we shot. You know, it is there today. I know that. It's by my bed.

Q: Okay. Was this a lamp that you added specifically for shooting the video?
A: No.

Q: Okay. Was it a lamp just for aesthetic purposes or lighting purposes?
A: Yeah. Yeah. It's a lamp that was in a closet because some of the shades were missing, and I just wanted to use it.

Q: Was the lamp--Do you remember exactly when you pulled it out of the closet and started using it?
A: No.

Q: Before or after the video?
A: I don't know.

Q: Okay. Your bedroom, do you have drapes on the windows in your bedroom?
A: Yes.

Q: Okay. Those drapes in the same condition now that they were as of June 12, '94?
A: Yes.

Q: Do you have a practice whether you close them or leave them open?
A: I close them at night.

Q: Okay. When you're sleeping?
A: Yeah.

Q: Otherwise you leave them open?
A: Well, normally when I go up to my bedroom I close the drapes, because I don't know when I'm going to fall asleep and I don't want to have to get up and have to, you know, close them.

Q: Do you have a practice during the summertime with respect to whether you sleep with windows open or closed?
A: No way, no. Not one way or the other.

Q: Not one way. So sometimes you may open them, and sometimes you'll close them?
A: I don't have any windows open in My bedroom. I do have a door I could open. There is no windows really to open upstairs in my bedroom.

Q: Okay. In the same time period, again, I am not--I am talking now about shooting the video at present day, and focusing now on exterior lighting, any changes?
A: Well, I know that they've added since June 12th--

MR. ROBERT BAKER: The video in December is the time period.

THE WITNESS: No, I don't think any changes since the video.

BY MR. BREWER:

Q: So the lighting should be substantially similar to as it was as of shooting the videotape. Correct
A: Yes.

Q: Foliage? Again, I am not talking about natural growth. I am talking about where you have specifically put in plants or had things removed.
A: Well, I've thinned out my trees, not in the front yard but in the backyard. I've had those pruned. I don't know if that was before or after the video. I don't think--I don't--I can't recall. I think along the walk drive that goes into Rockingham he may have planted some ground flowers, but I don't know if that was before or after either.

Q: Same time frame, but the question is with respect to locks.
A: I don't--I have no knowledge of us changing any locks.

Q: Okay. So presumably they're the same now as they were as of shooting the videotape in December.
A: Yes.

Q: Okay. Flooring inside the foyer?
A: I think I added a rug.

Q: You did that since the videotape?
A: Yes.

Q: Okay. Was that just for aesthetic purposes?
A: Yes.

Q: Okay. Carpet inside the house?
A: The same.

Q: Window coverings?
A: They're the same.

Q: The two gates along the southern pathway between shooting the videotape and the present time?
A: I have no idea.

Q: Okay. How about Kaelin's room same time frame?
A: Since the video, I think we have different pictures in there and--yeah, and a leak has been added. No. I know pictures are a little different. It my have been spruced up since then a little bit. I got--yeah, I think some--definite for sure some pictures have been added.

Q: By the way--
A: And I don't know if they were there before, but they were there since, since the video. Yeah. pictures have been added in there.

Q: How about Arnelle's room? Since the video, any changes either inside the room or outside of the room?
A: Since the video?

Q: Yes.
A: Well, I don't know when she moved, so I don't know. So when she moved,--she took most of her stuff out of there.

Q: Since the videotape, any changes to the window outside Kato Kaelin's bathroom?
A: Not that I know of

Q: Well, did you make any changes or authorize any?
A: No.

Q: Okay. How about outside Arnelle's room?
A: I got to say this: Any repairs that are done, even though my people who work for me know to make the repair if it needs to be done, so in a sense that's all authorized by me because I got to pay for it, but no specific knowledge of anybody doing any of this.

Q: Were there any repairs made under your direction where you specifically asked them to make repairs with respect to Kaelin's window?
A: No.

Q: Okay. How about Arnelle's windows?
A: Not that I know of.

Q: Okay. In the entire time period that you have lived at Rockingham. has anyone ever--who was in Arnelle's room or Kato's room ever reported noises presumably emanating along the southern pathway?
A: I can't recall.

Q: Okay. I want to go back to an exhibit that was previously marked I believe as 1. I'm not Sure. What number do you have on that?

MR. ROBERT BAKER: 6.

MR. BREWER: 6?

Q: Exhibit 6, which was the--

MR. KELLY: A description--

BY MR. BREWER:

Q: --which was the June 15, '94--it's dated June 15, '94, "To 'Whom It May Concern" letter, which I think you've indicated it was actually on 6-17-94. Is that correct?
A: That's correct.

Q: Mr. Simpson, at the time that you drafted this letter, had you heard from any source, excluding conversations, with lawyers, that the police theorized that a killer or killers had left blood at the Bundy crime scene?
A: I don't recall. There was so much on TV, I'm sure I probably heard something.

MR. ROBERT BAKER: You don't have to speculate. If you don't recall, you don't recall.

THE WITNESS: I'm sure--No, I don't recall. There was so much going on and being said at that Period of time, I don't know.

BY MR. BREWER:

Q: Well, do you recall at some point learning that the police were theorizing that blood had been left by a killer or killers at the Bundy crime scene?
A: I may have.

Q: Do you remember how you learned that information?
A: No.

Q: Do you remember when you learned that information?
A: Not particularly, no.

Q: Do you remember whether it was before or after you began drafting this letter? A. I don't know.

Q: At some point after the murders did you learn that a glove was found on your property?
A: As I said, I heard so much that day, and during that week that I'm sure I had heard about--I know I heard about a glove and ski mask.

Q: When did you hear that for the first time?
A: I believe the first day.

Q: Okay. I mean, that would be a pretty significant piece of information, that evidence linked with the crime scene was found on your property. Right?
A: I don't know if anybody linked anything at that point.

Q: Well, what did you hear exactly about the glove?
A: I don't know. I was hearing everything. I was hearing bloody ski mask. I don't know if I heard glove the first day. I know I heard bloody ski mask right away.

Q: Well, when you said you "heard bloody ski mask," did you hear a bloody ski mask was found on your property?.
A: That's what they were reporting, something about a bloody ski mask, I believe.

Q: And when you first heard--Strike that. At some point did you determine or learn that a bloody ski mask was not found on your property, that that was a false report
A: At some point, yes.

Q: Do you remember when that was?
A: No.

Q: Do you remember what evidence, if any, you knew about at the time that you began drafting this letter?
A: I didn't know what was evidence and what wasn't evidence. I was hearing everything that was in the--everything that was being reported, I was hearing it all. So whatever was being reported that Week, I heard it.

Q: Well, do you remember hearing about any evidence that you believe may tend to implicate you?

MR. ROBERT BAKER: Well, the point that he has just made is he didn't know what was evidence and what wasn't, so your question is without foundation.

BY MR. BREWER:

Q: Did you hear about any information that may tend to implicate you in these murders?
A: I heard they were going to arrest me, and that was the information that was implicating me.

Q: Okay. That's the first time in your mind there was any information that was implicating you in these murders, was when you actually heard that you were going to be arrested?
A: I heard everything on the news. I heard newscasters theorizing and making claims about things that I didn't think were true.

Q: Okay. Well, what reports do you remember by newscasters--
A: Well one of them--

Q: ---regarding information that you didn't think was true?
A: DeVilla, Bob DeVilla, somebody with Channel 4.

Q: Avila?
A: Avila. He was doing a report about when I arrived at the hotel in Chicago, I was loud and boisterous as if I was attempting to draw attention to my self, and I'm saying that was not true. There was nobody in the lobby except the people who were greeting me, and I was dragging when I walked through the door. So, I mean--and other than specifics--I know that was a specific, and there was a lot of that type of stuff being said.

Q: Is that a report that you heard at Rockingham?
A: I may have. I may have. I just know that week I heard it, and it was on TV.

Q: And that's a report that specifically sticks out in your mind as you're testifying here today. Is that true?
A: Because that was something I knew was not true.

Q: Okay. I mean, you knew for a fact that that was totally inaccurate. Is that correct?
A: Correct.

Q: And because it was inaccurate and it was being reported on television. it's something that you have a specific recollection of as you're sitting here testifying during this deposition. Is that true?
A: That one, yeah. There was a lot of stuff, and I can't recall a lot of it, but that was one that--you know why? It may have been the first thing I heard, and then so much was being said and implied after that, it was almost like I had to kind of turn off and my focus went to my family.

Q: Okay. Well, I just want to make sure I understand your testimony, which I understand isn't the test, but for me it's going to be the premise of this question: With respect to this report that you heard from the reporter, Bob Avila, was there something about the way in which he reported the information or was it the substance of the report that caused you to have some difficulty with his reporting?
A: It was a lie.

Q: Okay. It was a lie.
A: Yes.

Q: Okay. Now, are there any other reports relative to information in the case that you specifically recall as you sit here today because you felt the information was false or untrue?
A: There was--I can't give you specifics, but if you take tapes of that week, there was just so much being said that--so much I didn't know if it was true or false, and there was numerous things that I knew were not true and--as they were reporting it. And so there were things that I heard that week that were just--just--you know, I just didn't believe them.

Q: Well, Mr. Simpson, you knew that they were reporting that your blood was actually found at the crime scene, didn't you?
A: I don't know if they reported that that week. I'm not sure if they reported that that week, but whenever they reported it, I was aware of it, and I don't recall if that week that was reported or not.

Q: Okay. Well, the first time that you heard that your blood was found at the crime scene or a claim that your blood was found at the crime scene was through the press. Isn't that true?
A: I would imagine so.

Q: Okay. And you knew that to be absolutely false. Isn't that true?
A: I knew that I hadn't deposited any blood at Nicole's house that night.

Q: You knew that it was virtually impossible for your blood to be at that crime scene. Isn't that true?
A: I don't know if it's impossible for me to have blood at Nicole's house or not. I knew--

Q: Well, was it possible--

MR. ROBERT BAKER: Let him answer the question.

BY MR. BREWER:

Q: Excuse me. Go ahead.
A: I knew that--and I don't know if I knew this that week. I'm telling you as I know today. I knew I didn't deposit any blood at Nicole's house that day. So that's what I know today. I don't recall in the scheme of things when this blood drops became an issue in all of this. I don't recall if that was that week or the following week or what.

Q: So you're saying that when you first heard that report, you weren't certain whether you had deposited blood at the crime scene?

MR. ROBERT BAKER: Wait a minute. "At the crime scene"? That isn't what he said.

MR. BREWER: I am just asking.

Q: Is that what you're saying?
A: No. I'm saying that as I can tell you now today, I did not deposit any blood that day at Nicole's house. It just--it didn't happen. So that's what I know for a fact today. During the course of all of this, when whose blood was where, I don't know when I found that out. I don't know if that was that week, the next week. I don't know if it was weeks later. I really don't know.

Q: Well, when you first heard that report about your blood being at the crime scene, in your mind did you know that that wasn't possible?
A: I knew it was impossible for me to have deposited that blood that night at anywhere. If it was my blood or wherever they may have found blood of mine, I knew it was impossible for me to have deposited that blood at Nicole's house that night.

Q: That's because you weren't there. Right?
A: Correct.

Q: And you weren't bleeding on her property. Is that true?
A: Not that day, certainly not, no.

Q: Well, some other day do you recall bleeding on the Bundy property?
A: I do recall at some point, and it may have been when we first got Kato, the dog, I do recall at one point Sydney and Justin getting me a--I don't know if it's Flintstones or something Band-Aid. I just don't recall when. That could have been months previous to this. I just don't recall.

Q: Well, did you cut yourself and were you dripping blood up the walkway at the Bundy property?
A: At that time? I don't know.

Q: At any time prior to June 12, 1994--
A: Not that I'm aware of.

Q: --did you ever drip blood up the Bundy walkway?
A: Not that I'm aware of

Q: Is it possible?
A: Anything's possible. But not that I'm aware of.

Q: You have a specific recollection of having the kids get you a Band-Aid because you cut yourself at the Bundy property?
A: I don't know. I just have a--I remember having a--I think a Flintstones--I'm not sure. One of these Band-Aids, I remember Sydney getting me one. It may have had something to do with Nicole closing my hand in her car door.

Q: Was that an accident?
A: Yeah. Yeah. But I don't recall dripping blood at that time. I know it was like a tear or something [indicating] , but I don't recall dripping blood at that time.

Q: You're pointing to the pinkie on your left hand.
A: I think so. I think it was one of my hands. I can't even remember what hand it was. But she--the window part of her thing, she closed the door on my hand.

Q: And do you remember the reporter that first made that report that was reporting your blood being found at the Bundy crime scene?
A: No.

Q: Do you remember what channel it was on?
A: No.

Q: Do you remember where you were when you first heard that report?
A: No.

Q: Do you remember saying anything in response to the TV or anyone else in the room when you first heard that report?
A: No.

Q: Did you have a verbal response when you first heard the report your blood was being found-- your blood had been found at the crime scene?
A: Possibly.

Q: Okay. What did you say?
A: I don't know.

Q: You have no recollection whatsoever?
A: No.

Q: When did you first learn about the location of the blood drops found at Rockingham? Do you understand that question?
A: No.

Q: Okay. As you sit here today, do you know where blood drops were found at Rockingham?
A: Yes.

Q: Okay. For example, they were found in the foyer. Is that correct?
A: I'm told that, yes.

Q: Well, when you say you're "told that." you've seen the actual photographs that have identified the location in the foyer where the blood drops were found. Isn't that true?
A: Yes.

MR. ROBERT BAKER: If you put blood drops there, they're not found.

MR. BREWER: Excuse me?

MR. ROBERT BAKER: If blood drops are placed there, they're not found, but go ahead.

BY MR. BREWER:

Q: Well, aside from semantics, you have seen photographs where there are identifying marks indicating that blood drops were found in your foyer. Is that true?
A: I've seen those photographs, yes.

Q: And, similarly, you have seen photographs where identifying marks have been placed on blood drops found in your driveway. Is that true?
A: That's correct.

Q: Okay. Now, Mr. Simpson, when is the first time that you learned or had any information relative to the location of blood drops found at Rockingham?
A: Some of it I think I learned upon arriving at my house.

Q: Okay. And how did you learn that?
A: A police officer. I don't know if it was Phillips. When I was handcuffed by the house, I kept saying, "Why am I handcuffed?" And somebody said something about blood, "There's blood here, and that, 'We got blood there; we got blood here," and I saw these cards, and I assumed--I guess I made an assumption that maybe that was some blood drops.

Q: Okay. So there was some discussion in your police statement about blood being found at Rockingham. Is that correct?
A: I believe so, yes.

Q: And in fact you knew before you even went down to the police station that there was blood found--at least you speculated that there may have been blood found at Rockingham because you saw cards identifying blood spots. Is that true?
A: I really didn't speculate anything. This guy said, "Blood was found" or "There's blood here and there's blood there," or something, and--

Q: Who said that?
A: I believe it was Phillips or it was-- whoever had--said it had a mustache.

Q: They have white cards identifying where the drops were?
A: I don't know. I don't know. There were just--there were--yes, there were cards. I don't know if they were white cards or what, but there were things, you know, sitting in spots and--I don't know. The guy just said that, and, you know, that wasn't prevalent--that wasn't foremost on my mind. That wasn't what I was focusing on.

Q: Well, you came back from Chicago because your wife had been killed. Is that correct, Mr. Simpson?
A: Because my ex-wife had been killed, yes.

Q: Okay. And then you were told as you entered the property, after being handcuffed, that blood was found on your property. Is that true, sir?
A: Correct.

Q: Did you tell them "Hey, I cut myself last night. Maybe that's from me"?
A: No.

Q: Did you offer any explanation at that time with respect to those blood drops?
A: No.

Q: Did you conclude in your own mind that perhaps those blood drops were left by you because you had cut your finger--
A: No.

Q: --the night before?
A: No.

Q: You had no thoughts one way or another how those blood drops got there?
A: I didn't think about blood drops. I was thinking about Nicole, my kids and why was I handcuffed.

Q: Well, all the way back from Chicago you were making phone calls to a number of different people, trying to investigate exactly what happened. Isn't that true?
A: No. I was trying to have people go by my house, see what my family was doing, what was going on with my family, and, yes, information--I like to know what was going on, what happened, and still to this day want to know what happened.

Q: And when you saw the blood drops, you made no statements whatsoever with respect to those possibly coming from you from the night before, to Detective Phillips.
A: That's correct.

Q: Did you ask him whether he knew how those blood drops got there?
A: No.

Q: Did you ask him how long they believed they were there?
A: No.

Q: Did you ask him any questions whatsoever with respect to how those blood drops got there?
A: I asked him. "Why am I hand---cuffed?"

Q: Well, you saw blood drops on your driveway. Right?
A: No.

Q: You just indicated that you were told that blood drops were on your driveway.
A: No. The guy said, "There's blood around here" or "blood here and there's a lot of blood there," so--

Q: Well, did you ask him, "Hey, did it come from the murderer?"
A: I didn't ask him anything. I didn't know what to ask him. I wanted to know where my kids are. I want to know, "Why am I handcuffed? Where are my kids? Why can't I go in my house?" Those are the things I wanted to know.

Q: So you had no interest in finding out any information with respect to blood drops found--

MR. ROBERT BAKER: Don't answer. That's--

BY MR. BREWER:

Q: --on your property?

MR. ROBERT BAKER: --argumentative.

THE WITNESS: At that time, no.

BY MR. BREWER:

Q: Okay. Prior to Detective Phillips telling you about blood drops on your--
A: If it was Phillips. I'm not sure it was Phillips. There's another guy I see sometimes, and it could have been that guy, but whoever did it had a mustache. I wasn't paying attention to him. It was so much going on, and as things were happening, you know, my lawyer was there and Vannatter was there. You know. it was a tough, tough time.

Q: Let's kind of hone in here and see if we can identify possibly who you spoke with. It could have been Phillips. Is that what you're saying?
A: Yes.

Q: Okay. There is someone else that was there that it could have been?
A: There was a lot of other people there, but there is one other guy I have seen since, and when I think about it, I wonder was that Phillips or this other guy.

Q: That spoke to you about the blood drops.
A: Yes.

Q: Okay. And was the other person a detective or a uniformed officer?
A: Detective.

Q: And can you describe him?
A: He has a mustache. That's all I can tell you.

Q: Have you ever learned his identity?
A: I may have seen him and heard his name, but I can't recall now.

Q: Did he testify at the criminal trial?
A: No.

Q: Was he ever in the court?
A: I can't recall.

Q: Okay. Other than having a mustache, do you have any other information that would help identify him?
A: No.

Q: Any other description of him other than having a mustache?
A: White guy with a mustache.

Q: How tall was he?
A: I don't know.

Q: What color was his hair?
A: I wasn't paying attention to him. I don't--you know, I don't really study guys.

Q: Okay. Was it Detective Lange?
A: No.

Q: You're able to definitively rule out that it was Detective Lange?
A: Yeah.

Q: Was it Detective Vannatter?
A: No.

Q: Able to rule out that it was Vannatter?
A: Yes.

Q: Was it Detective Fuhrman?
A: No.

Q: Are you able to rule out that it was Detective Fuhrman?
A: Yes.

Q: Okay. You know it was a detective, though.
A: Well, he was on my property, had on a suit. and I assumed it was a detective.

Q: Did he have a badge?
A: I didn't see a badge.

Q: Did he represent himself as a Los Angeles police officer or detective?
A: I don't recall that.

Q: Going back to Exhibit 6. Now, when you wrote this letter, you indicated that you were in a lot of pain from the loss of Nicole. Is that true?
A: Yes.

Q: And you felt suicidal. Is that true?
A: I wanted the pain to stop.

Q: Okay. And the secondary component to your feelings at that time were other things. There were other things going on, I think is how you described them earlier. Is that correct?
A: I don't know.

Q: Well
A: Everything was going on. I was in pain. I wanted the pain to stop. That's all I can really say about it. I was in a lot of pain.

Q: Okay. And the pain, as you've indicated already, is because of Nicole, the loss of Nicole.
A: I would say that was obviously the genesis and the major portion of it all. Yes.

Q: And were you beginning to feel like you were being targeted as the person that committed these murders?
A: Yes.

Q: And wasn't that based upon news reports of evidence that was being developed in the case?
A: I believe so.

Q: And you knew at the time that you were told about these murders and thereafter that the Los Angeles Police Department was conducting an investigation. Isn't that true?
A: Yes.

Q: And I take it, Mr. Simpson, that you assumed that they would continue the investigation and develop evidence and leads and follow those leads in connection with this case. True?
A: Yes.

Q: At the time of--Strike that. As of June 12,1994, did you have any concerns about the competency of the Los Angeles Police Department in conducting murder investigations?
A: I didn't give it any thought.

Q: Okay. Did you assume that they would competently follow through with any leads that they developed in connection with the case?
A: At the time I didn't give it any thought.

Q: Did you have any reason to believe they wouldn't?
A: No reason whatsoever.

Q: Did you have any reason to believe that they would not ultimately locate or identify the person or persons responsible for these murders?
A: At the time I didn't think about that.

Q: Okay. Well, were you confident that they would conduct an investigation and hopefully find the person that murdered your wife--ex-wife and Ron Goldman?

MR. ROBERT BAKER: How can you be confident if you didn't think about it?

THE WITNESS: I have--you know, I read a lot of--a lot, and I know that normally they don't. In most cases they don't. So, I mean, that was just knowledge I had from you know, years of reading, and, you know, in most cases they don't.

BY MR. BREWER:

Q: Well, Mr. Simpson during the first
A: I don't know if I thought about that that day. I'm pretty sure I didn't even think about that then.

Q: When you talk about everything going on, you're talking about press reports that are intimating that you killed Nicole and Ron Goldman. Right?

MR. ROBERT BAKER: You mean to the exclusion of everything else, that's what he's talking about?

MR. BREWER: No.

Q: When you said earlier that the reason why you were suicidal--you gave two reasons: One was the pain associated with the loss of Nicole. The second reason was what you characterized as "everything." I want to figure out what is the everything. And in relationship to that, you've indicated that you began to hear press reports about you possibly being the number one target or the suspect in connection with these murders. Is that true?

MR. ROBERT BAKER: Which one do you want him to answer? Don't answer that question. There's about four questions in there, and it's compound. Don't answer that.

BY MR. BREWER:

Q: Well, were you concerned, Mr. Simpson, about the press reports that were indicating that you were the number one suspect in connection with these murders?
A: I don't know if I was concerned. I was hurt by it all, and it just added to the hurt that I was feeling.

Q: Okay--And did you believe that the information that was being reported as tending to indicate that you had some responsibility was false?
A: Yes.

Q: And that--Let's take, for example, the information relative to your blood being found at Bundy. Did you have a belief that any information that reported your blood being found at Bundy was false?
A: I don't know if I knew or heard that that week, so I can't answer that because I don't have any--I can't tell you when I heard that. That could have been three weeks later or four weeks later, as far as I know. So that wasn't anything that I could focus on right now and say that that was a part of it.

Q: As you sit here today, is the only report that you recall indicating anything about you in connection with these murders the NBC report referring to your demeanor and attitude when you got to Chicago?
A: I'm sorry. Ask the question again.

Q: As you sit here today, is the only news report that you recall in this first week that you have a specific recollection of the NBC news report by Jim Avila about you coming to Chicago and being loud and boisterous? Is that the only one you recall?
A: I have a specific recollection that there were numerous things being said that week that gave an impression that I was--I committed this crime. I do remember that. Avila's--I remember because I believe it was the first thing I heard to be--that I knew personally was totally false.

Q: Okay. And did you perceive his report as having a tendency to implicate you in these murders?
A: That's the way it sounded to me, yes.

Q: Okay. Is there any other report that you have a specific recollection of other than the Avila report?
A: Right now I can't at this moment not say. I just know there were numerous things that week.

Q: Well, when you say "numerous things." what is the numerous? What
A: I don't know.

Q: --items were being reported that you were responding to or concerned about?
A: If you--maybe you should do go and listen to all the reports that week, and you'll find them. I have no specific memory right now. I know they were there, I know I heard them, and I know that at the time that they were--all of it was causing more pain.

Q: well, as of the writing of this letter, did you assume that eventually this would all be sorted out and that the murderers would eventually be found or identified?
A: I certainly hoped so.

Q: Okay. And you had every reason to believe that that would happen, didn't you?
A: I certainly hoped so.

Q: Okay. And that was your frame of mind at the time that you wrote this letter. Isn't that true?
A: When I wrote this letter my frame of mind was stopping pain that I was feeling. Everything else was--everything else at the time, everything else was almost irrelevant to me. I just wanted to stop the way I was feeling.

Q: Well, part of that pain could be alleviated if they identified the murderers or the murderer. Isn't that true?
A: I don't know. I don't--that day I was feeling so much pain that I don't know what could have alleviated it.

Q: Was it was on the 17th that you were feeling this pain?
A: I was feeling it all week, but it came to a crescendo on the 17th.

Q: Well, did something happen in particular on the 17th that brought it to a crescendo?
A: I think that I was then arrested, yes.

Q: Okay. So prior to the 17th did you have any occasion where you began to think about suicide?
A: Maybe.

Q: When did you first--when did it first cross your mind?
A: I don't know if it ever crossed my I mind. I just know I wanted the pain to stop, and at that point on the 17th I wanted to be with Nicole, and that's what I attempted to do.

Q: Well, when did you first think about doing anything affirmatively to stop the pain?
A: I don't know. It was kind of a spontaneous thing. At just a moment I remember looking at A.C. I said,'Take me to Nicole's grave," and I don't know when at any point in any of that that anything ever became affirmative in my mind. If it had, I'd be dead right now. So I don't--I can't say that it ever got affirmative at any point, but I know I just wanted to stop the pain.

Q: Well, you just mentioned that you looked at A.C. and said, 'Take me to Nicole's grave." Was that after you learned that you were going to be arrested?
A: Yes.

Q: And would it be fair to say that that was the first time that you decided to do anything affirmatively to stop the pain?
A: It was the first time that I--yeah, I wanted to go to Nicole's grave, yes. I did want to do that.

Q: Did you begin to draft the letter after you were advised that you were going to be, arrested?
A: Yes.

Q: Okay. So prior to that information - Strike--that. Prior to learning that information, you hadn't undertaken any effort to draft this letter. Is that true?
A: That's correct.

Q: You also said that you made some amendments or an amendment to your will. Is that correct?
A: I believe so, yes.

Q: Okay. And you don't recall what you changed or what you were going to after, if anything.?
A: That's correct.

Q: Do you recall whether any of those changes included making dispositions to the Goldmans?
A: I know that didn't. I know that's wrong.

Q: Any of those changes include dispositions to the Browns?
A: No.

Q: To your children.?
A: I don't know. I think it just had to do with my family.

Q: When you say your "family," you're talking about Sydney and Justin or Arnelle and Jason or
A: Yeah, basically. My mother, my family.

Q: Was there anything in there that stated anything about the Browns?
A: I--in my will? I don't believe so.

Q: Was there anything, whether it be a dispositive provision or not, just a statement
A: I don't believe so.

Q: --or comment
A: I don't believe so.

Q: Let me finish my question. whether it be a dispositive provision, whether there was a statement or comment mentioning the Browns?
A: I don't believe so.

Q: How the about the Goldmans?
A: No, definitely not.

Q: You're positive there is no mention in the amendment with respect to the Goldmans. Is that correct?
A: Positive.

Q: I want you to look at, if you would, Mr. Simpson. Exhibit 6, and in large part, as you've already indicated, this letter or this "To Whom It May Concern" letter was drafted because of the pain that you were experiencing from losing Nicole. Right?

MR. ROBERT BAKER: Don't answer that. You've answered it six times.

BY MR. BREWER:

Q: Prior to drafting this letter had you heard news reports about any marital discord between you and Nicole?
A: Yes.

Q: Okay. Do you recall any specific reports?
A: No.

Q: Do you recall what you were specifically told or what you heard."
A: No.

Q: Do you recall the general tenor of the reports?
A: Negative, but, no, not anything specific to it other than that.

Q: Well, when you say 'negative,' what do you mean by that?
A: I know that it--I felt negative. I felt it was a negative report. I felt it was negative. It made me feel more pain.

Q: Okay. Did the reports include claims that you had battered Nicole?
A: I don't recall.

Q: Did they include reports that you had beat Nicole?
A: I don't recall.

Q: Did they include reports that you had choked Nicole?
A: I don't recall.

Q: Do you recall any of the specifics as they relate to your relationship with Nicole that were being reported?
A: Right at this day, I don't recall the specifics, but there was a lot of stuff, and I just don't recall the specifics.

Q: Well, the first paragraph of this exhibit is really defending your relationship, isn't it?

MR. ROBERT BAKER: Well. that's your characterization.

BY MR. BREWER:

Q: Well, I am asking for your state of mind.
A: I don't know

Q: Isn't that what you were doing?
A: As of the date, my state of mind then was to stop the pain or whatever the hell was going on in my life. I was in a lot of pain at the time, and, you know, I was just not the way I normally am.

Q: Well, the first paragraph of Exhibit 6 relates to your explanation as to problems you had with Nicole. True?
A: Let me read that.

[Witness reviews document.]

I don't think so. No, I don't agree with you there.

Q: Well. You are describing a relationship that has ups and downs in the first paragraph, aren't you
A: No. I think I'm describing a relationship that had come to a place where we were both comfortable with who we are and where we were, and we were going in our--on with our lives.

Q: And in fact you indicate on the 10th line down that you mutually agreed to go--"We mutually agreed to go our separate ways." Do you see that?
A: Yes.

Q: Is that an accurate statement?
A: I believe so.

Q: And are you referencing the time frame of April-May 1994?
A: No. I'm referencing--I'm doing either Mother's Day or the day after Mother's Day of May.

Q: 1994.
A: Yes.

Q: That's the time period that you're referring to?
A: Well that's when we split and had no problems and were--you know, that's when we sat and talked and went our separate ways.

Q: Okay. And the adjective that you used, "mutually" agreed
A: Yeah.

Q: --that's a fair characterization of how you
A: Yeah, she was accepting of it. She was very accepting. She wouldn't go to therapy, so she was accepting of it. That was a choice she made.

Q: When do you first recall reading any press articles that said anything about your relationship with Nicole in a negative context?
A: Oh, months after all of this.

Q: Months after the murders?
A: Yes.

Q: So during the week
A: Maybe not months. Weeks after the murders.

Q: Well, up until June 17, then, you didn't read any press reports that spoke negatively about you and Nicole? A:. No.

Q: Is that true?
A: That's true.

Q: Were you anticipating then that there were going to be press reports subsequent to June 17, 1994 that portrayed your relationship with Nicole in a negative way?
A: No. That was the tenor I got off TV, the reports that I heard on TV

Q: Prior to June 17, 1994.
A: That's correct.

Q: Did you read anything that related to a negative relationship between you and Nicole?
A: I didn't read anything.

Q: Okay. I mean a press report, newspaper?
A: I didn't read anything.

Q: You didn't read anything at all that week?
A: That's correct

Q: You got all of your information from TV?
A: That's correct.

Q: Were there particular stations that you watched?
A: I'm sure all of them.

Q: You were just looking for information?
A: Yes.

Q: You wanted to obtain information relative to these murders?
A: Yes.

Q: Were you following the investigation?
A: Only what I saw on TV when I was watching TV

Q: Were you doing anything else to develop information relative to the investigation other than watching TV?
A: At this time, no.

Q: Were you continuing to contact the police department to determine the status of their investigation?
A: I believe my lawyer was. I wasn't.

Q: Did you personally contact the police department?
A: No.

Q: Let me finish my question. Did you personally contact the police department after June 13, 1994 in an effort to learn the status of the investigation?
A: I think my lawyer was under my employment, and he was doing that. My concern was to bury Nicole and try to get through the week with My kids and deal with what I was trying to deal with there, the pain of it all.

Q: The lawyer that you thought
A: I wasn't in a place

Q: I'm sorry.
A: I wasn't in a place that first week to-- I had family to consider, and I had myself to consider, and I wasn't into an investigative mode that week.

Q: Okay. So it would be--your state of mind was really one wanting to stay with the family and
A: My state of mind was to get through the week and for Nicole to be buried and hopefully that my kids would be fine through it, which they which they were.

Q: And that was your focus.
A: That was my focus.

Q: And that focus made it difficult for you to do anything else.
A: It was tough. I mean, yeah, it was tough doing other things that week, Yes.

Q: Okay. But you found time on the 14th to go down and get your golf clubs at the airport. Right?
A: Yeah.

MR. ROBERT BAKER: Don't-- okay.

THE WITNESS: No, I think that's wrong. Yeah, the 13th, was it? Was that the 13th?

BY MR. BREWER:

Q: Was it the 13th?
A: No. It may have been the 14th. Yes, that's correct.

Q: You went down with Mr. Kardashian in his car to the airport to get your golf clubs. Right?
A: That's correct.

Q: And you weren't going to play golf that week, were you?
A: No.

Q: Okay. Were you in some need of having your golf clubs with you?
A: I was in need to have something to do while I was waiting for my kids.

Q: Okay. And so the thing that you chose to do was to go get your golf clubs at the airport?
A: Because I was near it, yes. That's correct.

Q: Did it help you at all deal with the pain associated with losing Nicole to drive down to the airport and get your golf clubs?

MR. ROBERT BAKER: Don't answer that. That's argumentative.

MR. BREWER: No, it's not. He's already said that

MR. ROBERT BAKER: He is not going to answer it, so you can just save your speech.

BY MR. BREWER:

Q: By the way, did you go anywhere else that day with Mr. Kardashian other than the airport to get your golf clubs?
A: Yes.

Q: Where else did you go?
A: To my office, to Nicole's house, to his house.

Q: Okay. And the visit to Nicole's house was really a drive-by visit because there was too much media there to stop. Is that true?
A: That's correct.

Q: And from there you went down to the airport to get your golf clubs. Right?
A: No. From there he just drove, and at one point when we realized that A.C. was 40 or 50 minutes away and he said, "Where do you want to drive?" I said, "Just drive." And we were near the airport and I said, "You know, I have some bags at the airport or bag at the airport. Let's go by and get it," which we did.

Q: Was there anything that you needed out of that bag?

MR. ROBERT BAKER: Had you finished Mr. Simpson?

THE WITNESS: Huh?

MR. ROBERT BAKER: Had you finished your answer?

THE WITNESS: Well, so it was a matter of killing time. It was a matter of just trying to do something while I was waiting for my kids to come, and not just to sit and look at the news. It was just a matter to occupy myself while my kids were coming, and we just happened to be in that--in the general vicinity, and my kids were still 40 or 50 minutes away.

BY MR. BREWER:

Q: Okay. Is there anything that you needed out of your golf bag?
A: Needed at that moment?

Q: Sure.
A: No.

Q: On the top of the page of Exhibit 6, you indicate--you make the statement that "What's being said, most of it, totally made up." You see that?
A: Yes.

Q: What specifically are you talking about is made up?
A: Well, as I told you, I can specifically remember the Avila story, and there were other things being said. and I can't specifically remember them. but there was numerous things being said. I'm sure all the people still have the video of their reports that we can go through it.

Q: Well, I don't know--I want to know what you were thinking when you made that statement
A: Just what I told you

Q: --what were you--excuse me. What were you referencing when you said most of what's been said is totally made up?
A: What I told you before: That in the reports they were saying various things. I don't recall all those things right now. I believe they may have had to do with Nicole's and my relationship, but various things were being reported, and it was negative--certainly had negative tones to it.

Q: Well, when you say, "various things were being reported," what was being reported?
A: I don't know how many times I have to tell you, I don't recall that week, but they--I'm sure they have tapes of all of that stuff. I don't recall what it was. I just know it was.

Q: Okay. The reason why I'm asking you .
A: I don't have a memory of this date ---as of this date what they were. It was so much stuff in this trial that's been negative, I don't recall what I learned after the 17th or before the 17th. I do know that during the course of that week it was painful to me, some of the things that were being said, and it all added to my state of mind that I was in. And we can go talk about the same thing over and over if you want, but that's--I don't remember anything specific other than Avila at this particular time.

Q: That's the only thing you remember

MR. ROBERT BAKER: Don't answer that. Don't answer that. He's asked it numerous--innumerable times.

MR. BREWER: Well, I haven't asked that innumerable times.

[Discussion held off the record.]

THE VIDEOGRAPHER: This concludes the deposition of Orenthal James Simpson, Volume VII. The number of videotapes used was two. We are going off the record, and the time is approximately 4:40.

[ENDING TIME: 4:40 P.M.]


Return to previous page.