<<Transcript of the nine parts of O.J. Simpson's deposition>> 
<<in the civil lawsuit brought against him by the families of>>
<<Nicole Brown Simpson and Ronald Goldman.>> 
<<File 1 of 2: OJSimpson1.txt, comprising volumes 1-4>> 
<<Source: http://www.islandnet.com/~walraven/simpson.html>> 
<<(This source has subsequently vanished.)>>
<<First prepared for CETH Summer Seminar 1996 by Willard McCarty>>
<<Subsequently modified by WM for use at King's College London 12/98>> 

<vol 1> 
Q: Good morning, Mr. Simpson. 
A: Good morning. 
Q: My name is Daniel Petrocelli. I represent plaintiff Frederick 
Goldman in this lawsuit against you. Do you understand that you are 
under oath? 
A: Yes. 
Q: You may have to speak up so that the folks down at the end of the 
table can hear you. Have you ever testified under oath before? 
A: Yes. 
Q: You understand that even though you're in our law office today, that 
the testimony that you give under oath here is subject to the same 
penalty of perjury as though you were testifying in a court of law? 
A: Yes. 
Q: How many times have you testified under oath before? 
A: I'm not sure, but I'd say three or four times. 
Q: Have you ever given a deposition before? 
A: Yes. 
Q: How many times? 
A: I believe twice. 
Q: All before the death of Nicole and the death of Ron Goldman? 
Q: During those two times that you gave depositions, you understood you 
were under oath? 
A: Yes. 
Q: And did you tell the truth in those depositions? 
A: Yes. 
Q: Did you say anything untrue? 
A: I don't believe so, no. 
Q: You told the truth. Right? 
A: The best I knew it. 
MR. BAKER: That's enough. That's enough. 
BY MR. PETROCELLI: 
Q: And have you ever testified at a trial? 
A: Yes. 
Q: When? 
A: Late '60s, early '70s. 
Q: What kind of case was it? 
A: One I believe was a criminal case, and one was a lawsuit. 
Q: Did they involve you? 
A: No. 
Q: You were just a witness? 
A: Yes. 
Q: And you told the truth in those criminal cases? 
A: The best I knew it. 
Q: Tell me who the parties were. 
MR. BAKER: I am going to object. Instruct him not to answer. It's 
irrelevant and immaterial. 
MR. PETROCELLI: What I would like to do is get a copy of the transcript 
of his testimony. 
MR. BAKER: It's irrelevant, immaterial. Instruct him not to answer. 
BY MR. PETROCELLI: 
Q: Now, is this the first time you're testifying under oath since the 
death of Nicole and the death of Ron Goldman? 
A: Yes. 
Q: So you've never been questioned under oath about the events 
surrounding Ron and Nicole's death. Is that right? 
MR. BAKER: That's been asked and answered. Instruct him not to answer 
the question. 
BY MR. PETROCELLI: 
Q: When you gave an interview on Ross Becker recently, you were not 
under oath. Correct? 
A: Correct. 
Q: Did you tell the truth? 
A: Best that I knew it, yes. 
Q: Would you have said anything differently if you were under oath? 
MR. BAKER: It's argumentative. Don't answer that question. 
MR. PETROCELLI: Are you instructing him? 
MR. BAKER: Yes. 
MR. PETROCELLI: Can we have a stipulation that if you instruct him not 
to answer, that he will abide by your instructions? 
MR. BAKER: Yes. 
MR. PETROCELLI: Thank you. 
Q: Did you --  you spoke in other elements of that video besides the 
Becker interview. Correct? 
A: Correct. 
Q: And did you tell the truth during the other times that you spoke on 
the video? 
A: Best that I knew it, yes. 
Q: And would you have said anything differently if you were under oath? 
A: I don't think so, no. 
Q: Now, you recall giving a statement to the Los Angeles Police 
Department on June 13? 
A: Yes. 
Q: Were you under oath? 
A: I don't believe so. 
Q: Did you tell the truth? 
A: Best as I could remember it --  
Q: Would you have said --  
A: -- at the time, yes. 
Q:  -- the same thing --  
MR. BAKER: Just a minute. 
MR. PETROCELLI: I'm sorry. 
MR. BAKER: Let him finish his answer. 
MR. PETROCELLI: I apologize, Mr. Baker. 
MR. BAKER: Go ahead and finish your answer. 
THE WITNESS: As best as I 
could at that time, yes. 
BY MR. PETROCELLI: 
Q: Would you have said anything differently at the time if you were 
under oath? 
A: At the time, no. 
Q: I would like to talk a little bit about preparing for the giving of 
testimony. You recently participated in this making of a video that is 
going to be released soon. Correct? 
A: Yes. 
Q: And you talked in that video about the events and circumstances of 
Ron and Nicole's deaths. Correct? 
A: I answered the questions that were asked me. 
Q: Okay. But the subject matter of that video was your side of the 
story with respect to the deaths of Ron and Nicole. Right? 
MR. BAKER: I am going to object. That's a characterization that you're 
making. 
BY MR. PETROCELLI: 
Q: You may answer. 
A: I answered the questions that were asked me, basically, yes. 
Q: But it was about the deaths of Ron and Nicole, generally speaking. 
Right? 
A: Yes. 
Q: Is that the only time -- And there were video tape machines and tape 
recorders recording what you were saying. Right? 
A: Yes. 
Q: Now, is that the only time that you have been recorded discussing 
the facts and circumstances surrounding Ron and Nicole's deaths? 
MR. BAKER: Don't answer that question unless you exclude anything that 
was done vis -- vis your attorneys. Any questions that he puts to you, I 
don't want you to answer and include anything that was done with your 
attorneys. 
MR. PETROCELLI: I would like to know if he is excluding anything. 
MR. BAKER: He is going to exclude everything that was done with and 
through and by his attorneys. 
MR. PETROCELLI: But all I am saying, Mr. Baker, so that we know whether 
or not there is a relevant contact with an attorney where we might want 
to attack the assertion of the attorney-client privilege, we have to 
know the basic foundational facts. That's all I'm saying. 
MR. BAKER: I understand what you're saying, and I'm not assenting to 
that, and we are not going to allow you to inquire as to what he did 
with his attorneys, whether he was taped, videotaped or anything else. 
MR. PETROCELLI: Well, I am going to inquire into that, and I haven't 
asked so far about any communications. I have simply asked for the mere 
existence of such recordings, if they do exist. 
MR. BAKER: And I am going to instruct him not to answer that, and you 
can certify it, and we can argue that point with the court. 
MR. PETROCELLI: Okay. 
Q: Let me get back to my question: Other than this recent video, have 
you ever been recorded on videotape or audiotape discussing facts and 
circumstances and events surrounding the deaths of Ron and Nicole? 
MR. BAKER: And I want you to answer that, other than anything you did 
with your attorneys. 
THE WITNESS: Other than anything that I did with 
my attorney, not that I knew of. 
BY MR. PETROCELLI: 
Q: And what about with respect to things you did with your attorneys? 
MR. BAKER: Could you be more vague? 
MR. PETROCELLI: No. 
MR. BAKER: I don't know what the question is. 
BY MR. PETROCELLI: 
Q: The question is: Have you ever participated in any events or any 
tapings in which you discussed the events and circumstances surrounding 
Ron and Nicole's deaths in the presence of your attorneys? 
MR. BAKER: I instruct him not to answer that question. 
BY MR. PETROCELLI: 
Q: What attorneys were present during such tapings? 
MR. BAKER: And I instruct him not to answer that question. 
BY MR. PETROCELLI: 
Q: Did you prepare for the possibility of testifying at your criminal 
trial? 
A: When you say -- I don't understand when you say "prepare." 
Q: Did you  --  Were you tape-recorded or videotaped? 
MR. BAKER: Same objection. If it has  -- if you were there with your 
attorneys and it was pursuant to the instruction of your attorneys, I 
don't want you to answer that question. 
BY MR. PETROCELLI: 
Q: Did a lawyer named Christina Arguendas subject you to a practice or 
mock cross-examination? 
MR. BAKER: Don't answer that question. I'll instruct him not to answer. 
MR. PETROCELLI: What are the grounds of these objections? 
MR. BAKER: I think it's pretty evident. 
MR. PETROCELLI: It's not to me. I just would like the record to be 
clear. 
MR. BAKER: It's attorney-client privilege and attorney work product 
privilege. 
MR. PETROCELLI: Okay. 
Q: Is Christina Arguendas an attorney that has ever worked for you in 
the past two years? 
A: I don't know. 
Q: You  --  
A: The name really doesn't mean anything to me. 
Q: Doesn't mean anything to you? 
A: No 
Q: Did such a person -- do you know whether such a person subjected you 
to a practice or mock cross-examination? 
MR. BAKER: I will instruct you not to answer again. That's based on 
attorney work product and attorney-client privilege. 
BY MR. PETROCELLI: 
Q: Have you ever been cross-examined about the facts and circumstances 
of the death of Ron and Nicole by a person who you did not know? 
MR. BAKER: If you did not know and you did not know they were an 
attorney, you can answer that question. 
THE WITNESS: I'm sorry. I'm a 
little lost here. 
BY MR. PETROCELLI: 
Q: In other words, I am trying to find out if anybody ever subjected 
you to a cross-examination when the person was not acting as your 
attorney, other than this video that just happened. Can you answer that 
yes or no, please? 
MR. BAKER: That assumes that an attorney that was hired through another 
attorney of his is not --  may or may not be his attorney, and I am not 
going to allow him to answer that question. 
MR. PETROCELLI: Same grounds: Attorney-client and work product 
objections? 
MR. BAKER: Yes. 
BY MR. PETROCELLI: 
Q: You took notes during the criminal trial? 
A: Yeah, at times. 
Q: Where are those notes? 
A: I don't know. 
Q: What did you do with them? 
A: I have absolutely no idea. 
Q: Who did you give them to? 
A: I don't know when I packed up -- I don't know. 
Q: You don't know what you did with them? 
A: No. 
Q: At the end of each day did you have a routine where you gave your 
notes to somebody or saved them in some way? 
A: No. 
Q: Did you take them back with you to the jail cell? 
A: Yes. 
Q: And when you left, when you were released, did you take the notes 
with you? 
A: I believe some of them, I must have. 
Q: Did you give them to anyone? Such as your attorneys? 
A: No. 
Q: Or anyone else? 
A: No. 
Q: Your assistant? 
A: No. 
Q: So right now as you testify today, you don't know where those notes 
are? 
A: No. 
Q: Do you know if they exist? 
A: I hope so. 
Q: Why do you hope so? 
A: I just hope so. 
Q: Did you give them to someone for safekeeping? 
A: No. 
Q: Do you know if they are in your house? 
A: No, I don't know. 
Q: Did you meet with anyone to prepare for this deposition? 
MR. BAKER: Other than your attorneys. 
THE WITNESS: No. 
BY MR. PETROCELLI: 
Q: Other than your attorneys. 
A: No. 
Q: Did you meet with your attorneys? 
MR. BAKER: Don't answer that. 
BY MR. PETROCELLI: 
Q: Who are the attorney that you met with to prepare for this 
deposition? 
MR. BAKER: Don't answer that either. 
MR. PETROCELLI: Are these instructions not to answer? 
MR. BAKER: Yes. 
MR. PETROCELLI: And based on what grounds? 
MR. BAKER: On attorney-client and attorney work product privilege. 
MR. PETROCELLI: Okay. 
Q: Were there any persons who were not lawyers, other than yourself, of 
course, present during sessions in preparation for this deposition? 
MR. BAKER: Assuming there were sessions in preparation for this 
deposition. 
MR. PETROCELLI: Correct. 
THE WITNESS: No. 
BY MR. PETROCELLI: 
Q: All persons present other than yourself were lawyers? 
A: Assuming that -- 
Q: Such preparation sessions occurred. 
A: Yes. Yes. 
Q: Is that correct? 
A: That's correct. 
Q: Okay. Do you have a copy of any of the videotaped materials that 
were used to make this soon-to-be-released video? 
A: No. 
Q: You have nothing? 
A: Nothing. 
Q: Do you have the final product? 
A: No. 
Q: Have you seen it? 
A: No. 
Q: Do you have any of the script materials? 
MR. BAKER: Well, that assumes there are script materials. 
BY MR. PETROCELLI: 
Q: Were there scripts prepared by writers to prepare for the making of 
this video? 
A: Given to me? 
Q: That you saw, not necessarily given to you. 
A: Saw, yes. 
Q: Do you have copies of those scripts? 
A: They weren't for me. No, I don't. 
Q: You don't have anything? 
A: No. 
Q: What is the name of this soon-to-be-released video? 
A: "O.J. Tells," I believe. 
Q: "O.J. Tells"? 
A: Yes. 
Q: Okay. So you have -- 
A: That's the phone number also. 
Q: Excuse me? 
A: That's the phone number: 1-800-OJTELLS. 
Q: I see. So you -- right now you have nothing in your possession with 
respect to this video "O.J. Tells." Is that right? 
A: That's correct. 
Q: Do your lawyers? 
A: I don't know. 
Q: Do any of your representatives have any of these materials relating 
to the video in their possession? 
MR. BAKER: I don't know what you mean by "representatives." I will take 
the suspense out of it that the lawyers do not have a copy of any of 
the tapes. 
MR. PETROCELLI: Okay. 
Q: Mr. Blasier was present during the production of this video. 
Correct? 
A: Correct. 
Q: And Mr. Blasier prepared a list of topics or points to be covered in 
the course of making this video. Correct? 
A: I would say that's not correct, no. 
Q: Can you explain to me? 
MR. BAKER: Explain to you what? He just --  Don't explain. Just answer 
his questions. 
BY MR. PETROCELLI: 
Q: Did Mr. Blasier or anyone else hand out a list of points to be 
covered in the video? 
MR. BAKER: Well, to the extent that Blasier talked to him about any 
points, I still believe and instruct him not to answer that that's 
going to be based on the attorney-client privilege. Mr. Blasier is an 
attorney, and he is of counsel in this matter. So I instruct him not to 
answer that question. 
BY MR. PETROCELLI: 
Q: When Mr. Blasier was participating in the making of this video, did 
you understand that he was doing so in his role as attorney of record 
in this case? 
A: Yes. 
Q: And you asked him to do that for that reason? 
A: Yes. 
Q: And he had discussions with you from time to time? 
A: Discussions, yes. 
Q: And as part of those discussions, did other members of the 
production crew participate? 
A: Some subjects, yes. 
Q: What kind of subjects? 
A: Locating blood drops, where the tags should go, and where various 
evidence, I guess, items were found. 
Q: What was the name of the director? 
A: I believe Larry Schiller. 
Q: And the name of the producer? 
A: Tony Hoffman. 
Q: The name of the writer or writers? 
A: I don't recall. 
Q: And there were meetings and discussions involving the producer, the 
director and the writers from time to time. Correct? 
A: I would assume so. 
Q: And you attended some of those. Correct? 
A: Yes. 
Q: And Mr. Blasier attended and participated in some of those. Correct? 
A: Yes. 
Q: And at some point didn't somebody prepare a list of topics and 
points to be covered in this video? 
A: As far as camera shots and where various evidence items were 
located, yes. 
Q: Wasn't there another list of topics: Substantive points to be 
covered? 
A: Now you're talking about what Bob and I discussed, and I understand 
that's attorney privileged. 
Q: You and he had such a discussion, but nobody else participated. Is 
that your testimony? 
A: Yes. 
Q: Wasn't the idea -- You did not know what Becker was going to ask you. 
Correct? 
A: Correct. 
Q: And wasn't the idea that after Becker asked you and you answered all 
of the questions, if there were other points that you wanted to cover, 
they would be covered later on in the video. Correct? 
A: Correct. 
Q: So isn't it -- wasn't there a list of the topics that everybody would 
check off that Becker covered, and the ones he didn't cover, you would 
then bring up after the Becker interview? 
A: To an extent, yes. To an extent. 
Q: Who prepared that list of topics? 
A: Generally, the public. 
Q: The public. 
A: Yes. 
Q: How did the public prepare that list? 
A: I believe they went out with cameras and asked the man on the street 
what you would want to ask O.J., and we looked at that and took the 
most probative questions from that. 
Q: The producer and his crew did that? 
A: Yes. 
Q: Did you participate in deciding which ones you wanted to cover and --  
A: Not at all. 
Q: Who did that? 
A: I guess they did. 
Q: So you had nothing to do at what point -- you had no say in what 
points would be covered and not covered on your video. Is that --  
A: Not with them. Not with them, no. 
Q: With who? 
A: With my lawyer. 
Q: Your lawyer, meaning Mr. Blasier? 
A: Yes. 
Q: Anyway, where are these lists of topics? 
A: I have no idea. 
Q: Where are the input that the public gave? The documents or the 
tapes, whatever the public gave, where is that? 
A: I have no idea. 
Q: You have none of that? 
A: No. 
Q: Okay. Do you know a man by the name of Keith Smith? 
A: No. I don't remember --  
Q: Excuse me? 
A: I wouldn't remember him. If I did know him, I don't know his name. 
Like I don't know these guys' names. 
Q: Which guys? 
A: These guys. 
Q: My partners? 
A: Yeah. 
Q: Okay. When is the video coming out? 
A: I don't know. 
Q: Did you participate in editing any part of the video? 
A: I gave suggestions to portions that were not the interview. 
Q: The interview we're referring to is the Ross Becker interview. 
Right? 
A: Yes. 
Q: That's one element of the video. Right? 
A: Yes. 
Q: There are essentially three components to the video? 
A: I believe so, yes. 
Q: What are the other two? 
A: One is walking around looking at various, you know, stuff that came 
up, you know, in the trial about where blood and gloves and things were 
found, and one was just me talking to the camera. 
Q: The one walking around looking at the various places where evidence 
was located, that was you also talking to the camera? 
A: Yes. 
Q: And you said you participated in editing the two elements not 
involving Becker. Is that right? 
A: Not really. I just -- I looked at it and -- I just looked at it. 
Q: Did you at any time during the making of this video indicate that 
you did not want any particular footage to be included in the final 
cut? 
A: No. 
Q: Do you have any outtakes? 
A: No. 
Q: Do you know if there are any outtakes? 
A: I don't know. I haven't seen the final product. 
Q: Who has all this material? Is it Mr. Hoffman? 
A: I don't know. Maybe the production company. 
Q: What is the name of the company? 
A: I really don't know. 
Q: Was there any other lawyer involved in assisting you with this video 
besides Mr. Blasier? 
A: Not representing me, no. 
Q: Was any part of what you said in the two elements of the video not 
involving Mr. Becker written out in advance? 
A: Pardon me? 
Q: Focusing on the two elements of the video not involving Becker, 
where you talked to the people and talked to the camera and walked 
around and so forth, was that material written out for you? 
A: No. 
Q: Did you write it out? 
A: Write it out? 
Q: Yeah. 
A: No. 
Q: Did you make notes about what you wanted to say? 
A: At what point? 
Q: At any point. 
A: The interview? 
Q: No. Forget the interview. The other parts where you're talking to 
the camera without Becker. 
A: Yes. 
Q: Where are those notes? 
A: I don't know. 
Q: You made them out in your own handwriting? 
A: Yes. 
Q: On index cards? 
A: No. 
Q: On regular paper? 
A: Yes. 
Q: You don't know where they are? 
A: No. 
Q: Would the production company have them, to the best of your 
knowledge? 
A: No. 
Q: Did you destroy them? 
A: I don't know. 
Q: What did you do with them when you were finished with them? 
A: I looked at them, and that was it. 
Q: Who did you give them to? 
A: I didn't give them to anyone. 
Q: Do you know where they are? 
A: No. 
Q: You don't know when this is coming out? 
A: I would assume, I hope, in February sometime. 
Q: Okay. Have you given any other interviews about the facts and 
circumstances surrounding Nicole and Ron's deaths other than the one to 
Becker? 
A: No. 
Q: You are doing one on Wednesday for Black Entertainment Television? 
A: No. 
Q: Are you doing an interview for them? 
A: Yes. 
Q: But it won't discuss the subject matter of your criminal case? 
A: No. 
Q: Or this case. Right? 
A: I don't know. 
Q: Have you -- Are you working on a book? 
A: No. 
Q: Have you drafted any pages or manuscript material for a book? 
A: No. 
Q: Do you know whether anyone is doing that on your behalf? 
A: No. 
Q: Other than the notes that you made in connection with the making of 
this video, have you sat down and wrote out any of the facts and 
circumstances --  
A: No. 
Q:  -- about the deaths of Ron and Nicole? 
A: No. 
Q: You are not aware of any kind of narrative statement by you to that 
effect, are you, on paper? 
A: No. 
Q: Have you tape-recorded such statements? 
A: No. 
Q: Videotaped such a statement? 
A: No. 
Q: Is Mr. Schiller working on another book with you? 
A: We hope to. 
Q: Have you started work in earnest on that book? 
A: No. 
Q: What is the subject matter of that book? 
A: My life; this case. 
Q: But nothing has been written yet? 
A: No. 
Q: Does Mr. Schiller have materials that you gave him for the writing 
of this book? 
A: No. 
Q: Do you know... Let me ask you some questions about medical injuries 
in your life. You've had some surgeries. Correct? 
A: Yes. 
Q: Where have you had surgeries? 
A: My hand, my knees and minor rectal. 
Q: What knees? 
A: And my eye. My eye once, too. 
Q: Let's start with the knees. What knee did you have surgery on? 
A: Basically the left knee, and I believe one on my right knee. 
Q: Do you have surgical scars on the left knee? 
A: Yes. 
Q: Do you have surgical scars on the right knee? 
A: Not that you can detect. 
Q: What eye did you have surgery on? 
THE WITNESS: You see a hole in one 
of these eyebrows? I don't recall. 
MR. BAKER: Left. 
BY MR. PETROCELLI: 
Q: Left eye? 
A: Left eye, yeah. 
Q: Left eyebrow? 
A: Actually, it was the eye. 
Q: Eye? And is there any scarring? 
A: No. 
Q: And hand surgery? 
A: Yeah. 
Q: Which hand? 
A: Left hand. 
Q: Any scars from that? 
A: Yes. 
Q: Do you have any other visible scars on your body? 
A: Yes. 
Q: Where? 
A: All over. 
Q: Where? 
A: Elbow, ribs, foot, knees, arms, few on my face. 
Q: These are from what, playing football? 
A: Basically, yes. 
Q: Are they permanent scars? 
A: I haven't played football in 15 years and they're still there, so I 
would imagine so. 
Q: And you have them on both of your arms? 
A: Yeah. 
Q: Where? 
A: Wrists, elbows, forearms. 
Q: And also on your legs? 
A: Uh-huh. 
Q: Where? 
A: Mostly calf area. 
Q: Now, did you have these scars, these visible scars, as of June 
12,1994? 
A: I haven't played football since then. 
Q: So all these came from playing football. Right? 
A: Yes. Basically. 
Q: Are there any other scars that you know about? 
A: Uh-uh. 
Q: You have to answer audibly. 
A: No. 
Q: As of June 12,1994, l want to ask you a series of questions about 
who were your advisors and close friends and so forth as of that point 
in time. So I would like you to focus on June 12, 1994. Okay? Did you 
have a general business attorney? 
A: Yes. 
Q: And who was that? 
A: Skip Taft. 
Q: Did you have an accountant? 
A: Through his office, yes. 
Q: Who was that? 
A: Mary Ann -- I can't think -- no. Marilyn. I can't think of her last 
name. 
Q: Did you have a business manager? 
A: No. 
Q: Did you have a secretary? 
A: Yes. 
Q: Who was that? 
A: An assistant, I would rather say. 
Q: Assistant? 
A: Yeah. Cathy Randa. 
Q: And any other assistants or secretaries? 
A: No. 
Q: How long had Randa been working for you? 
A: Roughly 20 years. 
Q: 20 years? 
A: Yeah. 
Q: Did Randa have any employees working with her on your matters? 
MR. BAKER: Do you mean as employees or consultants? 
MR. PETROCELLI: Employees. 
THE WITNESS: From time to time. 
BY MR. PETROCELLI: 
Q: Nobody you can identify? 
A: No. 
Q: And does Cathy Randa work at an office? 
A: She did, yes. 
Q: She did at that time? 
A: Yes. 
Q: What office was that? 
A: 11661 San Vicente. 
Q: Is that your office? 
A: Yes. 
Q: Do you still have that? 
A: No. 
Q: And what was the name of that -- You had a company that she worked 
for? 
A: Yes. 
Q: O.J. Enterprises? 
A: Yes. 
Q: Does Randa still work for you? 
A: Yes. 
Q: For O.J. Enterprises? 
A: Yes. 
Q: And where does she work now? 
A: Out of her home and at my home. 
Q: Okay. Did you have any other assistants or secretaries besides 
Randa? 
A: No. 
Q: As of that time, who were your closest other advisors, if you had 
any? You mentioned Taft. 
A: Marvin Goodfriend. 
Q: And who is he? 
A: Tax attorney. 
Q: He's a tax attorney? 
A: Uh-huh. 
Q: Anyone else? 
A: No. 
Q: Okay. Who were your closest friends in or around June of 1994? 
A: Al Cowlings -- you want a whole list? 
Q: Your closest. 
A: Bobby Chandler, Paula Barbieri. When you say "in and around" --  
Q: June 1994. 
A: Nicole Brown, Reggie McKenzie, Louis Marx, Wayne Hughes, Jack 
Snyder, Bobby Bender. Goes on and on. 
Q: Can you identify them for me? 
A: Allen Austin, Bob Hoskins, Al Wyler --  
Q: Wyler? 
A: Wyler. Cory Wolman. I know I forgot someone, but I would say among 
my best friends, that would be pretty much the group. 
Q: Was Kato Kaelin among your best friends --  
A: No. 
Q:  -- in June of 1994? 
A: No. 
Q: One of your close friends? 
A: No. 
Q: How would you characterize your relationship with him at that time? 
A: He seemed to be a nice guy. 
Q: An acquaintance? 
A: Yes. 
Q: Who were your house employees in June of 1994? 
A: Gigi Gurin, I believe. 
Q: How do you spell her last name? 
A: G-u-r-i-n, I believe, although I may not be sure on that. 
Q: Does she still work for you, Mr. Simpson? 
A: Yes. 
Q: When did she begin working for you in the house? 
A: Roughly April, late March, April of '94. '94. 
Q: And who preceded her? Back up. What were her duties? What does she 
do for you? 
A: Housekeeper. 
Q: Full time? 
A: Yes. 
Q: Did she live at the house? 
A: During the week, yes. 
Q: In the guest house? 
A: No. In the quarters right off the kitchen. 
Q: Right off the kitchen? 
A: Yeah. 
Q: What were her nights off? 
A: Weekends. 
Q: Saturday and Sunday? 
A: Yes. 
Q: She was not home, for example, on Sunday, June 12, 1994. Correct? 
A: Yes. Or last night, for that matter, yes. 
Q: And she was not there on Saturday, June 11, 1994. Correct? 
A: Yes. 
Q: The last time that Gigi was at your house in this time frame in June 
was Friday at the end of the day, June 9? 
A: I believe so. I believe so. I don't recall seeing her Friday, but -- 
MR. BREWER: Mr. Petrocelli, could we ask the witness just to keep his 
voice up? 
THE WITNESS: I believe so, Friday, yes. 
BY MR. PETROCELLI: 
Q: Do you know how she got -- how she departed your house on Friday, 
whether she had her own car or whether somebody in your house drove 
her? 
A: I know no one at my house drove her --  I can't answer that because I 
don't know if Kato drove her, but I have no knowledge. 
Q: Did she have her own car? 
A: From time to time, yes. 
Q: When she was at your house Monday through Friday, did she have a car 
there? 
A: From time to time. yes. 
Q: Her own car? 
A: If her husband didn't have it, which was probably most of the time. 
Q: Okay. And who was Gigi's predecessor? 
A: Michelle Abudrahm. I can't spell the last name. 
Q: A-b-d-u-r-a-n? 
A: I have absolutely no idea 
Q: Where is Michelle now? 
A: She works in Beverly Hllls 
Q: For whom? 
A: I don't know. 
Q: Do you have her phone number? 
A: I'm sure it's around somewhere. 
Q: You mean in your phone book? 
A: Probably at my home. 
Q: At your house? 
A: Yeah. 
Q: Do you know the name of the family that she works for? 
A: I've heard it. The guy is very wealthy, I know, but I can't recall 
his name right now. 
Q: Have you spoken to Michelle since you were released from prison in 
October of this year? 
A: Yes. 
Q: Of last year. Excuse me. 
A: Yes. 
Q: You speak to her from time to time? 
A: Yes. 
Q: Has she done any work for you? 
A: She's made me -- yes. 
Q: I mean since you --  
A: Well, work, no, but she's -- yeah, no, she hasn't done any work. I'm 
sorry. 
Q: What has she done for you? 
A: Made me cookies. 
Q: Cookies. But she hasn't been in your employ? 
A: No. 
Q: But she is a friend now? 
A: Yeah. I like her. Yes. 
Q: How long did she work for you? 
A: On and off over a 10 year,12-year period. 
Q: So starting in the '80s and going to March 1994? 
A: Yes. 
Q: And did you have any other housekeepers in 1993 or '94 other than 
Michelle and Gigi? 
A: Not that I recall. 
Q: Any other house help? 
A: I think Michelle got some help from time to time. 
Q: Nobody you would know. Right? 
A: No. 
Q: Okay. By the way, would you consider Robert Kardashian one of your 
close friends? 
A: Oh, yes, I'm sorry. I certainly would. 
Q: As of June of 1994? 
A: Yes. 
Q: How long had you known Mr. Kardashian as of June of 1994? 
A: Over 20 years. 
Q: Did he ever act as your attorney? 
A: Yes. 
Q: When? 
A: On some business deals that we had done in the past. 
MR. KELLY: I am sorry. I am not able to hear the witness' answers. 
BY MR. PETROCELLI: 
Q: They are having trouble hearing you, Mr. Simpson. 
A: Some business deals that we had done in the past. 
Q: In the '70s? 
A: '70s and possibly '80s. 
Q: But aside from those business deals, your relationship with him is 
principally a friendship one. Right? 
A: Principally, yes. 
Q: Have you ever been convicted of a felony? 
A: No. 
Q: Have you ever been convicted of any crime? 
A: I pleaded no contest in a spousal abuse case in 1989, so I don't 
know what that is. 
Q: Have you ever pleaded no contest or guilty or been found guilty to 
any other crimes? 
A: No. 
Q: Have you ever been charged with any crimes other than the spousal 
abuse and the murder case? 
A: No. 
Q: Have you ever been sued civilly for any acts of physical violence? 
A: No. 
Q: Have you ever been charged with rape? 
A: No. 
Q: I don't mean --  Formally in a complaint? 
A: No. 
Q: Or informally in a claim --  
A: No. 
Q:  -- by a person or in a letter? 
A: No. 
Q: Nothing like that in your whole past? 
A: No. 
Q: Have you ever been accused of battery other than the spousal 
battery? 
A: No. 
Q: Civilly? 
A: No. 
Q: Criminally? 
A: No. 
Q: Informally? 
A: No. 
Q: Did you ever make a settlement with anyone who charged you with 
assault, rape or battery? 
A: No. 
Q: As of June of 1994, is it true that you had generally favorable 
relations with the Los Angeles Police Department? 
MR. BAKER: I don't know what you mean by that, and I don't know that he 
can characterize his relations. 
BY MR. PETROCELLI: 
Q: You can answer. 
MR. BAKER: No, don't answer. That question is overbroad, vague and 
ambiguous. 
BY MR. PETROCELLI: 
Q: Did you think you had a good relationship with the LAPD as of June 
1,1994? 
MR. BAKER: His state of mind relative to his relations with the LAPD, 
it's irrelevant and I am going to instruct him not to answer that 
question. 
MR. PETROCELLI: Okay. 
Q: Before June 1 of 1994, had you ever been arrested by the LAPD? 
A: No. 
Q: Had they ever come out to your house? 
A: Yes. 
Q: When you were present? 
A: In an official capacity? 
Q: No. Had they ever -- Yes, in an official capacity. 
A: Yes. 
Q: When you were present at the house? 
A: Yes. 
Q: On how many occasions? 
A: One, possibly two times. 
Q: What was the one time that you remember clearly? 
A: 1989. 
Q: They came out to your house and did not arrest you? 
A: Correct. 
Q: And the other time was when? 
A: I don't totally remember this time, but it was 19 --  I think  -- 84. They 
tell me Mark Fuhrman came to my house. 
Q: And he did not arrest you. Correct? 
A: No. 
Q: Nor did anyone else. Right? 
A: No. 
Q: And are there any other times that you can remember when the police 
in their official capacity came out to your house? 
A: No. 
Q: Now, were there any times when you were at Nicole's house that the 
police came out? 
A: Once. 
Q: When was that? 
A: 1993. 
Q: Did they arrest you then? 
A: No. 
Q: Did members of the LAPD frequent your house from time to time? 
MR. BAKER: That's pretty vague and ambiguous, too. 
THE WITNESS: Yeah, 
you'll have to be a little more specific because I can't answer that. 
BY MR. PETROCELLI: 
Q: Did they ever come visit you? 
A: Stop -- 
MR. BAKER: In an unofficial capacity come visit him for a social call, 
is that the question? 
MR. PETROCELLI: Correct, Mr. Baker, and all of this is before June 12, 
1994. 
THE WITNESS: Yes. And even after they've stopped and talked to me 
at my driveway and stuff, yes. 
BY MR. PETROCELLI: 
Q: Even now, you mean? 
A: Yes. 
Q: Okay. Prior to June 12, 1994, would they come to your house from 
time to time to use your pool? 
A: No. 
Q: Your tennis courts? 
A: One individual had used my pool I think when he was still with the 
LAPD. 
Q: Who was that? 
A: Ron Shipp. 
Q: Okay. 
A: And never alone did he ever use my pool at that point, but my tennis 
court, I'm pretty sure he did. 
Q: He used your tennis court? 
A: Yes. 
Q: Any other LAPD members use your tennis court --  
A: Not that I know of. 
Q:  -- besides Mr. Shipp? 
A: Not that I know of. 
Q: Did Mr. Shipp bring other people with him when he used the pool and 
tennis courts? 
A: Tennis court we're talking, not pool. Yes, he had a -- from time to 
time he had a foursome that he would play tennis with. 
Q: Did you ever file any charge of harassment against the police at any 
time before June of 1994? 
A: No. 
Q: Okay. Did you ever attend any LAPD Christmas parties? 
A: Not that I recall. 
Q: Did you ever attend any LAPD functions? 
A: Not that I recall. 
Q: You don't remember attending annual Christmas parties? 
A: I know I didn't attend, not annually any, but I don't recall ever 
doing that, no. 
Q: Any kind of parties or functions? 
A: Over my years in L.A. I've attended a lot of functions, and I can't 
really recall any that were specifically LAPD. 
Q: Did you ever autograph footballs for officers? 
A: Oh, yes. 
Q: LAPD officers? 
A: Every officer, everybody, yes. 
Q: Did you charge them? 
A: I never charge. 
Q: And did not charge the LAPD. Correct? 
A: Well, I don't know. If an LAPD officer drove up and had a football 
and asked me to sign it, I'm sure I didn't charge him. 
Q: And you signed other things for them, too, besides footballs? 
A: I've signed pictures for everybody, LAPD or whatever they might be. 
Q: Your son Jason was given an LAPD cap from a police officer? 
A: I would assume so. I have not saw the cap. 
Q: Do you know who gave it to him? 
A: Probably Ron Shipp. I don't know. 
Q: You just don't know? 
A: I'm guessing. I don't know. 
Q: What reasons would the LAPD come visit you in their unofficial 
capacity? 
MR. BAKER: Don't answer that question. That calls for speculation on 
the part of this witness. 
BY MR. PETROCELLI: 
Q: What did you understand the purpose of the visits to do? 
MR. BAKER: If they told you what they -- the reason they came, you can 
relate that. Don't speculate. 
MR. PETROCELLI: He doesn't have to be told. 
MR. BAKER: Don't guess or speculate. 
BY MR. PETROCELLI: 
Q: You can answer. 
A: They dropped by, they look, they talk, and sometimes they'd ask for 
an autograph. Since the trial, on two occasions they came by to tell me 
I got screwed. 
Q: Now, before the trial when they would stop by and talk, how would 
they get to the front door? 
A: They wouldn't. Normally  --  I don't ever recall them knocking on my 
front door. I mean, maybe Shipp has before. But normally, if they see 
me in my yard  -- I spend a lot of time in my yard, and I didn't keep my 
gates locked up previously. 
Q: And they would see you, and you would converse and chat, just social 
talk. Right? 
A: Yeah. 
Q: Pleasantries. Right? 
A: Uh-huh. 
Q: So your dealings with the LAPD were cordial? 
A: Yeah. For the most part, yes. 
Q: Do you know any other -- before June of 1994,did you know any other 
police officers by name other than Ron Shipp? 
A: Yes. Years ago, and I can't think of his name now, when I was at USC 
there was a guy who worked for LAPD, nice guy, but I think he stopped 
working for the LAPD back then also. He was in a shoot-out and stopped 
working. 
Q: Which officers came by and said you got screwed? 
A: I don't know. I don't know the ones that came by and asked for an 
autograph either. 
Q: The ones that came by and said you got screwed, you don't know who 
they are? 
A: No. They were just outside of my house, and my security was around. 
Q: Did they explain to you how you got screwed? 
A: No. They just said -- one guy on a motorcycle drove up to me once and 
said it also. 
Q: Did he explain what he meant? 
A: No. He drove off. Gave me the thumb's up -- said, "They tried to screw 
you," gave me the thumbs up and left. 
Q: "They" being whom? 
MR. BAKER: If you had an impression. 
THE WITNESS: I'm assuming the 
prosecution. 
BY MR. PETROCELLI: 
Q: Did anybody ever say to you -- these officers who drove by and spoke 
to you since you got out of jail ever say to you that the LAPD tried to 
screw you? 
A: No 
Q: Okay. Do you believe you were framed by the LAPD? 
MR. BAKER: You don't answer that question. 
MR. PETROCELLI: Why not? 
MR. BAKER: Because that's argumentative. It's irrelevant, immaterial 
what his state of mind is. 
BY MR. PETROCELLI: 
Q: Do you have any information that you were framed by the LAPD? 
MR. BAKER: He is not going to answer that. You are not going to try 
this case through him. You are going to try it through evidence. 
MR. PETROCELLI: I am trying to find out his state of mind. 
MR. BAKER: His state of mind is irrelevant 
MR. PETROCELLI: I am not asking for his state of mind. I am asking for 
what information he has, Mr. Baker. 
MR. BAKER: No, you are not. You are not going to answer that question. 
MR. PETROCELLI: Give me an objection so we can just have a clean 
record. 
MR. BAKER: I did give you an objection, and I gave you an instruction. 
It's irrelevant, immaterial, and it calls for his state of mind, and 
it's argumentative. 
BY MR. PETROCELLI: 
Q: When did you first think you were being framed by the LAPD? 
MR. BAKER: Don't answer that question. We are not going to go through a 
deposition of his state of mind. 
BY MR. PETROCELLI: 
Q: Do you contend that you were framed by the LAPD? 
MR. BAKER: I will do the contentions, and he is not going to answer 
that question. 
BY MR. PETROCELLI: 
Q: As of June 17, Mr. Simpson, did you have any information that caused 
you to believe that you were being framed or set up by the LAPD? 
A: No. 
Q: Let's talk a little bit about June 17th. You were present at the 
home of Mr. Kardashian on the morning of June 17th? 
A: Yes. 
Q: Okay. And you were there in the morning. Right? 
A: Uh-huh. 
Q: You have to answer yes. 
A: Yes. 
Q: And who was present with you? Who was in the house? 
A: Paula Barbieri. At one point A.C. came. 
Q: A.C. Cowlings? 
A: Yes, Al Cowlings. At one point Shapiro and, of course, Kardashian. I 
believe Kardashian's girlfriend --  
Q: What's her name? 
A: Denise Halicki. I believe Nicole Pulvers, and then some doctors. I'm 
not sure. I'm pretty sure Dr. Lee was there. Dr. Huizenga I believe was 
there. I believe Mike Baden. I'm saying this only because I've heard 
these guys talk since then, so I believe that he was there. 
Q: Who? 
A: Mike Baden. Michael Baden. That's all I can recall right now. 
Q: Bob Shapiro was, of course, your lawyer in the criminal case. 
A: Yeah, he came there. I know he came. 
Q: And Cowlings and Kardashian were your very close friends. Right? 
A: Yeah, they have been my friends for years. 
Q: And Paula Barbieri was  --  she was your girlfriend? 
A: Yeah, basically, yes. 
Q: And Denise Halicki was Mr. Kardashian's girlfriend. Right? 
A: Yes. 
Q: Nicole Pulvers was whom? 
A: She was assisting Bob Kardashian. 
Q: And these doctors, Lee, Huizenga and Baden, they were all retained 
in connection with your criminal case? 
A: Yes. 
Q: Was Huizenga a preexisting doctor of yours? 
A: No. I'd only -- he had only done something for me on one other 
occasion previous to this. 
Q: When was that? 
A: I was on a plane coming back with the Raiders once and I was having 
some major eye problems, and he sort of helped me out. 
Q: Was that when he was the Raider team physician? 
A: Yes. 
Q: Okay. 
A: Oh, and previous to that day, that week he had done a physical on me 
and stuff. 
Q: The week of June 13. 
A: Yes. 
Q: Correct? 
A: Yes. 
Q: He did that on June 15. Correct? 
A: I believe so. 
Q: Okay. Now, you understood that you were going to be arrested. 
A: Yes. 
Q: And the arrangements were that you were going to be taken down to 
LAPD? 
A: I believe so. I believe I was gonna  --  they were gonna drive me 
down. Mike, you know, Shapiro. I believe that was the arrangement. 
Q: Shapiro was going to drive you to the police station? 
A: Yes. 
Q: And what time were you scheduled to go to the police station? 
A: I don't recall. 
Q: Were you on any medication? 
A: Yes. 
Q: At that time? 
A: Yes. 
Q: In the morning? 
A: Yes. 
Q: What were you on? 
A: I have no idea. 
Q: Who gave it to you? 
A: I think Dr. Faerstein --  
Q: He was there also? 
A: I don't recall if he was there. I know he -- I think he was the one 
who prescribed the medication 
Q: What did he prescribe? 
A: I don't know. You'd have to ask him 
Q: Did he give the pills to someone else to administer to you? 
A: I don't know. I know that when I needed them, Cathy or Paula would 
get them, and early when he was around, he'd give them to me. 
Q: Cathy Randa was there also? 
A: I believe she came there that day. I'm not a hundred percent sure. 
Q: Before you left? 
A: Yes. 
Q: By the way, are you on any drugs or medication now? 
A: Yes. 
Q: What are you taking? 
A: Sulfasalazine and prescription Motrin. 
Q: Motrin? 
A: Yeah. 
Q: For what? 
A: Pain. 
Q: What kind of pain? 
A: Just arthritic, whatever, general arthritic pains. 
Q: And what is the other medication? 
A: It's called Sulfasalazine. It's something that a rheumatologist has 
had me on for a few years now. 
Q: Going back to when? 
A: '93 sometime. 
Q: Are you taking anything else right now? 
A: No. 
Q: Do those medications in any way interfere with your ability to hear, 
understand and answer truthfully my questions? 
A: Not that I know of. 
Q: Okay. So going back to the morning of the 17th, do you remember what 
time you were scheduled to depart for LAPD? 
A: No. 
Q: What did you do on the morning of the 17th at the house? 
A: I think they were taking pictures of me. I know I wrote, I did some 
writing. That's pretty much all I recall. 
Q: They took pictures of you, meaning parts of your anatomy? 
A: I believe that was that morning. I'm not a hundred percent sure, but 
I believe --  
Q: The doctors did? 
A: Yeah, I'm pretty sure that was that morning. 
Q: Did you receive any injections? 
A: Not that I recall. 
Q: Did they take any blood? 
A: I don't recall. 
Q: What kind of writing did you do? 
A: Some writing, putting some of my thoughts down, thoughts that I had 
for friends and things. 
Q: Did you write individual letters to different people? 
A: Just a basic letter. 
Q: One basic letter? 
A: I may have written two basic letters. 
Q: The one basic letter, is that the letter that was later on that day 
read by Bob Kardashian? 
A: I believe so. 
Q: You wrote that? 
A: Yes. 
Q: In your own handwriting? 
A: Yes. 
Q: And you wrote it the morning of the 17th? 
A: Yes. 
Q: Did anybody assist you in writing it? 
A: No. 
Q: You wrote it all yourself? 
A: Yes. 
Q: Did anybody dictate anything to you? 
A: No. 
Q: Did anybody tell you what to say? 
A: No. 
Q: Did anybody suggest what to say? 
A: No. 
Q: Anybody review it after you finished it? 
A: No 
Q: What did you do with it when you finished writing It? 
A: I don't know immediately when I finished writing it, but I may have 
given it to Bob. 
MR. BREWER: Sorry. I can't hear you. 
THE WITNESS: I don't know what I 
did immediately when I finished writing it. I either gave it to Bob to 
hold or to A.C. I don't recall what I did. 
BY MR. PETROCELLI: 
Q: Did you put it in an envelope? 
A: Yes. 
Q: Did you seal the envelope? 
A: Yes. 
Q: How did you address the envelope? 
A: I don't know if I addressed it to anyone. I'm not sure. 
Q: When you handed it to Bob -- is that what you said? 
A: Yeah. 
Q: What --  
MR. BAKER: He said Bob or Al, I believe. 
MR. PETROCELLI: Bob or Al? 
Q: What did you say it was? 
A: I just told them to keep this. 
Q: What did you tell them to do with it? 
A: Just keep it. 
Q: Did you tell them to open it? 
A: No. 
Q: To read it? 
A: No. 
Q: Did you tell him that you'll know when it's appropriate to open and 
read this? 
A: No 
Q: Did you say that? 
A: No. 
Q: What was your purpose in giving it to them? 
A: It was just some thoughts I wanted to share with some people. 
Q: When did you understand that the thoughts would be shared? 
MR. BAKER: If you had an understanding. THE W1TNESS: If I had an 
understanding. I don't know. I was, you know, I was in a -- I don't know. 
My frame of mind, I can only speak to you based on how I feel now about 
it, and I thought that if I had harmed myself in any way, that they 
would read it to my friends. 
BY MR. PETROCELLI: 
Q: Such as if you killed yourself? 
A: Yes. 
Q: You were suicidal that week. Right? 
A: Evidently, yes. 
Q: And you were on suicide watch? 
A: I don't know about that week. I don't know. You say "suicide watch." 
I wasn't aware that I was suicidal, so I don't know. 
Q: When you wrote that letter, though, you had thoughts of suicide. 
Right? 
A: I had a thought -- thoughts of -- yeah, I had thoughts of ending what I 
was feeling, yes. 
Q: Certain persons were keeping vigil over you to see that you wouldn't 
harm yourself. Is that right? 
A: I really wasn't aware of that at the time, no. 
Q: Your sister? 
A: I wasn't aware of that so much at the time. I knew that they were 
with me for support. I knew my sister was. I only spent one night at 
Rockingham, and I knew she was there for support with me. 
Q: The one night you spent at Rockingham was the 13th, a Monday night. 
Right? 
A: Yes. 
Q: You summoned Paula Barbieri back from Las Vegas to be with you and 
to keep vigil over you. Is that right? 
A: That's not correct, no. 
Q: Did you ask her to come back? 
A: No. 
Q: Who did? 
A: I don't know. I think she insisted on coming back. 
Q: On her own? 
A: Pretty much so. 
Q: How do you know that? 
A: Because she came back. 
Q: How do you know she insisted on coming back on her own? 
A: I don't know. I just --  
Q: You don't know if anybody called her and asked her to come back? 
A: I don't know. I know I wanted her there, but at the same time I 
didn't want her there because of all the press that was hanging around, 
so I did  --  I was glad she came. 
Q: Did you ask anybody to call her? 
A: I don't recall doing that, no. 
Q: Did you ask Cathy to do that? 
A: I don't recall doing that, no. 
Q: What was the other basic -- Let me get back to this letter. When you 
wrote this letter, were you alone? 
A: Yes. 
Q: And where were you? 
A: I was sitting in my room. I guess I was sitting in the room. 
Q: Bedroom? 
A: I think I had written it in a few places. I was just taking notes 
when I was not being bothered. 
Q: You wrote it in one sitting? 
A: I don't think so. I'm not sure. I don't think so. 
Q: Did you write it all on the morning of the 17th of June? 
A: Yes. 
Q: You said you had thoughts of ending what you were feeling. What were 
you feeling? 
A: A lot of pain. 
Q: What kind of pain? 
A: Pain. 
Q: Pain over what? 
A: My wife had been murdered, and I was being attacked. 
Q: By whom. 
A: Media. 
Q: They were attacking you? 
A: Yes. 
Q: Meaning they were blaming you? 
A: No. They were attacking me during the week, saying things that 
weren't true. 
Q: You felt the media were saying things, attacking you, that were not 
true? 
A: I knew they were. I saw it on TV. 
Q: What were they saying about you? 
A: Just various things. 
Q: Well, can you tell us back then what you were thinking that was 
being said about you that was untrue? 
A: Just how I was reacting. One guy, I think Jim Avila, did a report 
that I was in Chicago, and when I arrived there I was loud and 
boisterous as if I was trying to be noticed, which was a flat-out lie, 
and I'm sure you talked to the people in Chicago when I arrived, and 
they made that clear, that I was anything but loud and boisterous. But 
things of that nature. I can't recall them all. 
Q: Were you feeling you were being attacked in the sense that you 
believed the press was pointing the finger at you as the person who 
killed Nicole? 
A: I can't say the press in general. Just a few things that I had 
heard, because I stopped watching it after a while. 
Q: But the gist of it was that these few things were pointing the 
finger at you. Right? 
A: My pain was for Nicole more than what they were doing. That was just 
all a part of it. 
Q: The loss of Nicole? 
A: Yes. 
Q: You loved her? 
A: Very much. 
Q: And you loved her on June 12? 
A: I loved her. Yeah. I didn't want to live with her, but I loved her, 
yes. 
Q: And you loved her so much that you were prepared to kill yourself? 
MR. BAKER: Well, that's argumentative. Don't answer. 
THE WITNESS: That's not why. 
BY MR. PETROCELLI: 
Q: You loved her so much that you were feeling so much pain that you 
had thoughts of ending your life? 
A: I just had pain for a lot of reasons, for everything that was going 
on that week, yes. 
Q: Well, besides the loss of Nicole and your feeling of being attacked, 
was there any other source of your pain? 
A: Just everything that was going on was my source of my pain. 
Q: What do you mean by that, "everything that was going on"? 
A: Everything that was going on. 
Q: Can you be more specific? 
A: No. 
Q: Do you mean in the sense that people were blaming you? 
A: No. I just mean everything that vas going on, and I can't be more 
specific. 
Q: You cannot tell us anything more than that? 
A: No. 
Q: What was the other note that you wrote? 
A: It wasn't a note. It was an amendment to my will. 
Q: Who did you give that to? 
A: I believe I directed it to be given to Skip Taft. 
Q: Did you write it in your hand? 
A: Yes. 
Q: What did you change? 
A: I don't recall. 
Q: Did someone tell you to change your will? 
A: No. 
Q: Was it your own idea? 
A: Yes. 
Q: Did you write it on a blank piece of paper? 
A: I believe so. 
Q: And who did you give that -- How many pages was it? 
A: I don't recall. 
Q: Who did you give it to? 
A: I believe whoever I gave the other letter to. 
Q: What did you tell that person about the second envelope? 
A: I think I put Skip Taft's name on it. 
Q: Was it in an envelope? 
A: I believe so, yes. 
Q: Did you write any other notes, letters, that morning? 
A: Not that I recall. 
Q: What about that week prior to the 17th, did you write any other 
notes or letters for people? 
A: No. 
Q: Were your children there with you? 
A: No. 
Q: Were your children with you at all during the week of the 13th? 
A: Yes. 
Q: What days? 
A: They came on the 14th and left on the 15th. 
Q: Came to? 
A: Bob Kardashian's home. 
Q: And they stayed over? 
MR. KELLY: I'm sorry. I can't hear you again, Mr. Simpson. I'm sorry. 

THE WITNESS: I'm sorry. Bob Kardashian's home. 
BY MR. PETROCELLI: 
Q: The 14th was a Tuesday. Right? 
A: Yes. 
Q: Your children came to your house on Tuesday, and they left on 
Wednesday. Is that what you're saying? 
A: That's correct. 
Q: They slept over at Mr. Kardashian's house? 
A: Yes. 
Q: By "your children," are we talking about Sydney and Justin? 
A: Yes. 
Q: Who brought them both ways? 
A: Al Cowlings. 
Q: And they were at the Brown residence in Dana Point? 
A: That's correct. Q. So Mr. Cowlings was with them in Dana Point, 
brought them to the Kardashian house and brought them back to Dana 
Point on Wednesday? 
A: That's correct. 
Q: Did he bring anyone else with him other than Sydney and Justin? 
A: I don't believe so, no. 
Q: The last time you saw your kids before you were arrested was 
Wednesday? 
A: No. 
Q: You saw them at the funeral? 
A: Yes. 
Q: I see. That was Thursday. Right? 
A: Yes. 
Q: Okay. Did you write any notes or letters out to your children that 
week? 
A: No. 
Q: Did you write any checks that day? 
A: No. 
Q: Did you give Mr. Cowlings any envelopes with anything in them? 
A: I don't think so, other than if he was the guy I gave the letter to. 
Q: Did you give Mr. Cowlings a sealed envelope with six checks in it? 
A: No. 
Q: Do you know whether Mr. Cowlings had a sealed envelope with six 
checks in it --  
A: No. 
Q:  -- on the 17th of June? 
A: No. 
Q: You have no knowledge about that? 
A: No. 
Q: After you did some basic writing, they took some pictures of you, 
what else did you do that morning? 
A: Nothing else I can recall. 
Q: Did you say good-bye to anybody? 
A: No. 
Q: You were anticipating going off to jail. Right? 
A: Yes. 
Q: And would not know when you would return. Right? 
A: Yes. 
Q: Now, you did not wait for the police, but left. Right? 
A: Correct. 
Q: And you left with whom? 
A: Al Cowlings. 
Q: What time did you leave? 
A: I have no idea. 
Q: When you left with Mr. Cowlings, you left the Kardashian residence 
in Mr. Cowlings' Bronco. Correct? 
A: Correct. 
Q: Parked in the driveway. Right? 
A: Correct. 
Q: Did you tell anyone that you were going? 
A: No. 
Q: Did they -- to your knowledge did they know that you were going? 
A: No. 
MR. BAKER: That calls for speculation. 
THE WITNESS: Not to my 
knowledge, no. 
BY MR. PETROCELLI: 
Q: Why didn't you tell them you were going? 
A: I didn't think about them. 
Q: You knew the police were coming, though. Right. 
A: Yes. 
Q: And you knew that if you had left, you would not be there when they 
arrived. Right? 
A: I didn't know they were coming. I knew that I was supposed to be 
going down there. 
Q: Supposed to be going to the police station. 
A: Yes. 
Q: And you knew by leaving the residence, you wouldn't be going to the 
police station then. Right? 
MR. BAKER: Well, I don't know --  
BY MR. PETROCELLI: 
Q: You can answer. 
MR. BAKER: That's argumentative, but go ahead. 
THE WITNESS: What was 
the question? I'm sorry. 
MR. PETROCELLI: Can you please repeat it? (Pending question read as 
follows: "
Q: And you knew by leaving the residence, you wouldn't be going to the 
police station then. Right?") THE W1TNESS: Correct. 
BY MR. PETROCELLI: 
Q: In other words, you didn't ask Mr. Cowlings to take you to the 
police station. Right? 
A: Correct. 
Q: Whose idea was it to leave? 
A: Mine. 
Q: Why did you leave? 
A: Because I wanted to go to Nicole's grave. 
Q: Did you ask your lawyers if you could go there first? 
A: No. 
Q: Your representatives? 
A: No. 
Q: Did you ask them to ask the police if you could go there first? 
A: No. 
Q: You just took it on yourself to leave? 
A: Yes. 
Q: Why did you do that? 
A: Because I wanted to go to her grave. 
Q: And did you go to her grave? 
A: Yes. Well, we never made it there because there was a police car 
blocking the entrance. 
Q: They wouldn't let you in? 
A: Well, A.C. saw them and avoided going in. 
Q: Do you know what time you left the house? 
A: No. 
Q: Do you know -- when you left the Kardashian house and you got in the 
truck, where were you sitting? 
A: In the passenger seat. 
Q: Visible to anybody who would look in? 
A: Yes. 
Q: And did you remain in the passenger seat all the way down to the 
grave site? 
A: Yes. 
Q: Did you make any phone calls from the car? 
A: I believe so. 
Q: Who did you call? 
A: I don't remember totally, but I know I called Nicole's house, and 
then I know I called some other people, but I don't recall who. 
Q: When you say "Nicole's house," do you mean the condo on -- the place 
on Bundy? 
A: Yes. 
Q: Who did you speak to there? 
A: Lou Brown. 
Q: He was staying there? 
A: Yeah. I guess so. 
Q: What did you tell Mr. Brown? 
A: I don't recall. 
Q: Did you call anybody else? 
A: I know l did, but I don't recall who. 
Q: Did you call Mr. Taft? 
A: I may have, yes. 
Q: Why did you call Mr. Taft? 
A: I don't recall. 
Q: Did you drive directly to the grave site? 
A: Yes. 
Q: How long did it take to get there? 
A: I don't know. 
Q: Did you make any stops? 
A: Well, I think there was a -- I've just heard this from A.C. -- that 
there was a dump truck that had turned over, so we sat on the freeway 
for quite a while. 
Q: Which freeway? 
A: I believe it was the 405. 
Q: For how long did you sit there? 
A: I don't know. 
Q: Half hour? 
A: I can't say. I really don't know. 
Q: And the whole time you were in the passenger seat 
A: Yes. 
Q: And when you got -- did you get to the entrance of the cemetery? 
A: Where we could see the entrance, yes. 
Q: What is the name of the cemetery? 
A: I don't know. 
Q: How close did you get to the entrance? 
A: I don't know. Couple hundred yards maybe. 
Q: And why did you not go through? 
A: Because there was a police car blocking it. 
Q: Were --  did you approach the officer and ask if you could go through? 
A: No. 
Q: Were you listening to the radio at all? 
A: No. 
Q: Did you believe at that time that you were a fugitive? 
A: I didn't give it a thought. 
Q: Did Mr. Cowlings tell you that? 
A: No. 
Q: Did you believe that the police were looking for you? 
A: I really didn't give it a thought, but  --  
MR. BAKER: You've answered the question. 
THE WITNESS: No, I really 
didn't give it a thought. 
BY MR. PETROCELLI: 
Q: Did you believe if you went up to the officer and asked to be let 
through, that he would have prevented you from doing so? 
MR. BAKER: He is asking for your state of mind on the 17th of June, 
1994, if you thought the officer would have prevented you from going 
into the cemetery. 
THE WITNESS: Probably. 
BY MR. PETROCELLI: 
Q: Why did you have that belief? 
A: I don't know. I just -- I think A.C. believed that, and I'm pretty 
sure I believed that, too. 
Q: When you asked Mr. Cowlings to take you to the cemetery, what did he 
say? 
A: "Come on." 
Q: Did he try to talk you out of it? 
A: Not at all. 
Q: He understood that you were supposed to go to the police station to 
be turned in. Right? 
A: You'd have to ask him that. 
Q: Did you believe he understood that? 
A: I believe that he probably knew that, yes. 
Q: Did you and he discuss what you would do after you left the 
cemetery? 
A: No. 
Q: Did you have a plan at that time? 
A: No. 
Q: Did you know what you were going to do after you left the cemetery? 
A: No. No. 
Q: Did you bring anything with you? 
A: Yes. 
Q: What did you bring? 
A: That I was aware of, three pictures of my family and a gun. 
MR. BREWER: What was the second thing? 
THE WITNESS: A gun. 
BY MR. PETROCELLI: 
Q: Did you plan to commit suicide at the cemetery? 
A: I didn't know what I was going to do. 
Q: Did you plan to commit suicide after the cemetery? 
A: I never thought of it to that extent. 
Q: Did you have in your mind when you would end your life? 
A: No. I just -- no. 
Q: Was the purpose of the gun to use to end your life if you saw fit to 
do so? 
A: I'm sure that was part of it, yes. 
Q: Where did you get the gun? 
A: From my -- actually, from my car. 
Q: Which car? 
A: My Bentley. 
Q: The Bentley was at Rockingham. Right? 
A: Uh-huh. 
Q: You have to answer --  
A: Yes. 
Q: And how did the Bentley get from Rockingham to Mr. Kardashian's 
home? 
A: It didn't. 
Q: You stopped off at Rockingham and picked up the gun? 
A: No. 
Q: Explain to me how you got the gun. 
A: I was curious when I got home from the police station, because I 
told the police that the gun was in my Bronco, and at that point no one 
had told me how Nicole was murdered, and I was curious if the gun was 
still in my car, and at one point -- I don't know who -- I asked some body 
to go look in my back seat and get a little case. They got it, and it 
was the gun. 
Q: When you said that you told the police the gun was in your Bronco, 
you're referring to the statement you  --  
A: The Bentley. 
Q: I am sorry. When you told the police -- your prior answer was that you 
told the police that the gun was in your Bronco. 
A: I meant Bentley. 
Q: You meant Bentley? 
A: Yes. 
Q: When you said that you told the police that the gun was in your 
Bentley, are you referring to the statement that you gave to Detectives 
Vannatter and Lange? 
A: Yes. 
Q: And when you left the police department, you went back to 
Rockingham, and you had someone go into the Bentley to see if the gun 
was still there? 
A: Eventually. Not quite the way you said it, but eventually. 
Q: That day? 
A: Yeah, later that day, yes. 
Q: Who went into the Bentley for you? 
A: I don't recall. 
Q: Who did you ask to get the gun? 
A: I don't recall. 
Q: Did the person bring it to you? 
A: Not the gun. They brought the case that it was in to me. 
Q: A gun case? 
A: No. 
Q: What case are you referring to? 
A: It's just a little case that it used to be carried in. 
Q: Leather bag? What was it? 
A: It was like a little violin case. 
Q: A violin case? 
A: Like a miniature violin case. 
Q: A hard case? 
A: Yes. 
Q: And what did that case have in it? 
A: A gun. 
Q: What else? 
A: That's it. 
Q: Bullets? 
A: I'm sure bullets, yes. 
Q: In the gun? 
A: Yes. 
Q: Now... 
MR. BAKER: Is this a good time? Let's take a break. We've been going 
for an hour and 20, 15 minutes. THE VIDEOGRAPHER: We are going off the 
record now, and the time is approximately 10:51. (Recess.) THE 
VIDEOGRAPHER: We are back on the record now, and the time is 
approximately 11:09. 
BY MR. PETROCELLI: 
Q: I want to go back to where we were, Mr. Simpson, concerning the 
retrieval of the gun. Do you remember what time you got back to 
Rockingham from the police station on the 13th of June? 
A: From my office because they wouldn't let us go directly back to 
Rockingham. If I had to guess -- it's a guess -- roughly 6:00 o'clock 
maybe. 
Q: You went from the police station to your office in Brentwood? 
A: Yes. 
Q: And then you went to Rockingham. 
A: They told us it was all right to come back. 
Q: Come back. Can you guys hear down there? 
Q: You just need to keep your voice up. 
A: From the police station to Rockingham, and then I believe it was 
Lange said it was all right, or Vannatter one, when I called my home, 
to come home. 
MR. BAKER: You just said you went from the police station to 
Rockingham. You went --  
THE WITNESS: To my office in Brentwood and then 
to Rockingham. 
BY MR. PETROCELLI: 
Q: Who drove you from the police station to the office? 
A: Either Bob or Bob Skip, Bob Kardashian or Weitzman. 
Q: And from the office to Rockingham, who drove you? 
A: I don't know. Probably Bob or Skip. I don't really recall. 
Q: Bob being Bob Kardashian? 
A: Yes. 
Q: And Skip being Skip Taft? 
A: Yes. 
Q: When you got to Rockingham, you then asked someone to go look into 
the Bentley for the gun because why? 
A: May have been a little later. 
Q: Later that evening? 
A: Yeah. Because I was curious. 
Q: What were you curious about? 
A: If they took the gun out of my car. 
Q: "They" being whom? 
A: The police officers. 
Q: Why did you want to know that? 
A: I was just curious. Some people were murdered, and I had a gun in my 
car. 
Q: Now, was it your suggestion to get the gun? 
A: I asked someone to go look and see, to bring me -- if there was a case 
in the back of my car, would they bring it to me. 
Q: In the trunk? 
A: No. In the back seat behind the front seat. Q; Is that where you 
kept it? 
A: Yes. 
Q: Who retrieved it for you? 
A: I don't recall. 
Q: No idea? 
A: No. 
Q: What was in the trunk of that Bentley? 
MR. BAKER: And you are talking again on the 13th? 
MR. PETROCELLI: Yeah. 
THE WITNESS: I couldn't tell you exactly, but I 
know some gloves and clubs and some balls were in there and some other 
paraphernalia. 
BY MR. PETROCELLI: 
Q: On the evening of June 12 and on to the day of June 13, you knew 
that there were some clubs and some balls and other paraphernalia in 
the trunk of the Bentley. Is that right? 
A: I would assume they were still there on the 13th, yes. 
Q: You last left the trunk -- clubs and balls and other paraphernalia in 
the trunk? 
A: The last time I looked in my trunk, some balls were left in and some 
I took out, and there was a bunch of junk back there, but a lot of 
clubs, yes. 
Q: Lots of clubs. 
A: Yes. 
Q: Golf clubs. 
A: Yes. 
Q: What was the last time you looked in the Bentley before June 13? 
MR. BAKER: And you are referring to the trunk? 
MR. PETROCELLI: Trunk of the Bentley. 
THE WITNESS: Sunday night, the 
night -- previous night. 
BY MR. PETROCELLI: 
Q: What time? 
A: l0:00, a little after 10:00, a little before, in that area. 
Q: P.M? 
A: P.M., yeah. 
Q: Okay. Let's go back now. When -- at the point in time on the evening of 
the 13th that you had someone go into the Bentley to get the gun, did 
you not know how Nicole had been killed? 
A: Yes. 
Q: You did not know. Right? 
A: I did not know. 
Q: Did you believe that she had been killed by a gun? 
A: I didn't know. 
Q: Did you believe that that was even a possibility? 
A: Obviously, yes. 
Q: Did you have any information that she had been killed through the 
use of a knife? 
A: Not at all. 
Q: Did you ask anyone how she was killed? 
A: I asked the police on many occasions what happened, and they 
continued to tell me that they didn't know and they were still 
investigating. 
Q: Did you see press reports and television programs during the day 
about this? 
A: Once I got home --  
MR. BAKER: "The day" is the 13th? 
MR. PETROCELLI: Yes. 
Q: Before you went and asked that the gun be retrieved. 
A: I knew that when I got home, we put on all three TVs, just about 
every TV in the house was on, and, you know, the press didn't seem to 
know much more than anyone else at that time. 
Q: There were no reports that she had been killed perhaps by a knife? 
A: None that I had seen, no. 
Q: So you had no information whatsoever how she had been killed. Is 
that right? 
A: That's correct. 
Q: Were you told that she had been murdered? 
A: Yes. Basically, yes. 
Q: And that's all you knew. 
A: Yes. 
Q: As of the evening of June 13. Correct? 
A: Yes. 
Q: Did you ask anyone else besides the police how she had been killed? 
Bob Kardashian, Skip Taft, anyone else? 
A: I may have during the course of the day as I came in contact with 
people. I think everybody was trying to ask everybody what happened, 
what did they know. 
Q: And nobody had any knowledge about how she was killed as of that 
point in time. 
A: No. 
Q: Correct 
A: As far as I recall, no. 
Q: What did you do with the gun case when you got it? Did you open it 
up? 
A: Yes. 
Q: And what did you do? 
A: I opened it up in my office. I believe I put it in my bag. 
Q: Your office at the home? 
A: Yes. 
Q: Who was with you? 
A: I don't recall. 
Q: What bag did you put it in? 
A: I think no one was with me. When they gave me the case, I went in my 
office and put it in my bag. 
Q: "They" being whom? 
A: Whoever brought it in there. 
Q: What bag? 
A: My black bag that it was eventually found in. 
Q: Can you describe that bag? 
A: A black bag with zippers. And you guys have it, or the police 
department have it. I thought they turned it over to you guys. 
Q: So was the gun loaded in the case? 
A: Yes. 
Q: You took the gun, closed the case, and then you put the case into 
the black bag? 
A: I believe so. 
Q: And was there anything else in the black bag at that time? 
A: Yes. 
Q: What was in it? 
A: Everything I had taken to Chicago. 
Q: What did that include? Withdrawn. Tell me as best as you can recall 
now what was in that bag on the 13th in your office when you put the 
gun in it. 
A: My overnight kit, a book --  
Q: What book? 
A: I believe it was "Inca Gold." Inca Gold," I believe it was. Some 
travel stuff. 
Q: What do you mean by that? 
A: You know, travel folder, that type of stuff. 
Q: You mean tickets and stuff? 
A: Yeah, tickets, travel, you know, schedule. 
Q: What else? 
A: What you guys now refer to as a disguise --  
Q: When you say "you guys," what do you mean by that? 
A: Well, I seen some people in this room refer to it on the news and 
the press and the prosecution. 
Q: Okay. So what do you refer to it as? 
A: It was a beard and a goatee. 
Q: So you had a beard and a goatee in that bag. 
A: Yeah. I never really opened the package to see what, but it was like 
a Vandyke thing, I believe. I never really looked at it, so I don't 
know. 
Q: It was in a sealed package? 
A: Yes. 
Q: It had never been opened? 
A: I had never opened it, no. 
Q: As of the evening of the 13th when it was in your bag, it had not 
been opened. Correct? 
A: I had never opened it, no. 
Q: Was it opened? You can't tell if it had been opened? 
A: I don't know what Vannatter did, because he took my bag and --  
Q: That was latter. 
A: I don't know. No, I'm only basing it on his testimony. 
Q: I am a little confused. Vannatter didn't have your bag as of the 
evening of the 13th, did he? 
A: Well, he perjured himself on the stand and testified that I told him 
he can look in my bag, which I didn't, but I would have if he would 
have asked, and he testified that he did look in my bag that Monday. 
Q: When you were interviewed? 
A: Yes. 
Q: At the police station? 
A: When I left the police station, he kept -- my bag was in the trunk of 
his car, and we're asking about picking it up, and he didn't want to 
walk to the  -- go downstairs to get it and asked if it would be all 
right if he took it to my house -- gave it to me when he got back to my 
house. So I was there with two -- three lawyers and said "Sure." 
Q: Well, I will get back to that, but let me see if I understand the 
contents of the bag on the evening of the 13th. You mentioned the book, 
the overnight kit, the travel materials and the beard and goatee. 
A: Yeah. And who knows what else. I mean, there's a lot of --  
Q: Can you remember anything else? 
A: Change, credit cards, passports, whatever, what I keep in the bag 
all the time. It's all in there that Monday. 
Q: Your passport was in the bag? 
A: Yes. 
Q: You said "passports." Do you have more than one? 
A: Well -- no. Sometimes I have my kids'. 
Q: Your passport was in this black bag you're describing? 
A: Yes. 
Q: And when did you put the passport in that black bag? 
A: It's always in the black bag. 
Q: Always. 
A: Always. 
Q: And when did you put the beard and goatee in the bag? 
A: Whenever I got it. 
Q: When did you get it? 
A: I don't know. A few weeks before that. 
Q: Where did you get it? 
A: Someone ordered it for me, and then it came to my office, and then I 
got it. 
Q: Who ordered it for you? 
A: I asked a guy to get it for me, and I think he arranged it through 
Cathy. 
Q: Who did you ask? 
A: Whoever the makeup guy was on the -- actually, I asked a girl who had 
a bunch of them on the shoot that I was doing for Playboy. She had a 
bunch of mustaches and beards, and while they were doing my makeup, I 
said, "You know, I can use one of them," and I explained why. And she 
said she'd get one, and while I was working she evidently had left, and 
then I had mentioned it to the other makeup person, and he said he can 
get it, and he and Cathy spoke, and he got it. 
Q: That day? 
A: I don't know. 
Q: This was the exercise video? 
A: Yes. 
Q: And this was done at your residence. Correct? 
A: Mostly no. Mostly at a studio. 
Q: When you had the conversation with the makeup artist, was it at the 
studio? 
A: Yes. 
Q: What was that person's name? 
A: I don't know. 
Q: When you had the conversation with the second makeup artist, what 
was that person's name? 
A: I don't know. 
Q: When did you receive the beard and goatee? 
A: I believe a few days after that. 
Q: At your home on Rockingham. 
A: No. At my office, I believe it was. 
Q: In Brentwood? 
A: Yes. 
Q: And who gave it to you? 
A: I think it was just sitting on my desk. When I go to my desk in 
Brentwood, things are there, and Cathy laid things out for me, I 
believe, and then I took it from the office one day. 
Q: Did you pay for it? 
A: I'm sure Cathy paid for it, yes. 
Q: Do you know how much it cost? 
A: No. 
Q: Did you ever see a receipt for it? 
A: No. 
Q: What was the reason that you explained to the makeup artists why you 
wanted a beard and goatee? 
A: Because I was going to Knotts Berry Farm. My kids had asked me to 
take them to Knotts Berry Farm, and I get harassed -- and I can't say 
harassed, but people are after me all the time when I'm in those 
places. so consequently I thought when I saw it there, it seemed like a 
good idea. 
Q: Have you ever used a disguise before in public places? 
A: Just sorta. 
Q: What do you mean by that? 
A: I've used -- where I've had fake casts so I wouldn't have to sign 
autographs, you know, sunglasses and hats and stuff in the past. 
Q: Have you ever used a fake beard and goatee? 
A: I've used it before but not really for public, not really out in the 
public. 
Q: Not to disguise yourself from members of the public? 
A: No. It's just if I'm doing a shoot sometime and they have them, I'll 
come home, and I'll wear it home and tease my kids. 
Q: Had you ever taken your kids to Knotts Berry Farm before? 
A: Yes. 
Q: Before June 1994? 
A: Yes. 
Q: And to Disney Land? 
A: Yes. 
Q: And other public places? 
A: Yes. 
Q: Did you ever wear a disguise to conceal your identity on those 
occasions? 
A: Sunglasses, fake casts on my hands, hats, yes. 
Q: The fake cast on your hand wouldn't conceal your identity as OJ. 
Simpson. Correct? 
A: It keeps me from signing autographs. It's all for the same purpose. 
Q: What I am trying to find out is whether you had ever worn a disguise 
with your children in public places for the purpose of preventing 
people from recognizing you. 
A: As I say, when I wear sunglasses and hats that I wouldn't normally 
wear. I've done that many times. 
Q: And was that successful? 
A: For the most part, yeah. 
Q: Besides hats and sunglasses, had you ever worn any other disguises 
in public for the purpose of concealing your identity? 
A: Halloween. Other than that, no. 
Q: Other than Halloween? 
A: No. 
Q: How did the beard and goatee get into your black bag from its 
location on your desk in Brentwood? 
A: I put it in there. 
Q: That day? 
A: I would imagine so, yes. 
Q: Now, from the time --  
A: Not the day that I -- whatever day I got it, I put it in my black bag. 
Q: That's what I meant. 
A: Yes. 
Q: Now, from that day on, had you ever used it? 
A: I don't believe it's ever been used. 
Q: So you never used it. Right? 
A: No. 
Q: And you never opened it yourself. Right? 
A: No. 
Q: You looked at it, put it in the bag and left it there. Right? 
A: Yeah. 
Q: When did you -- You said your passport was always in your bag. 
Correct? 
A: Uh-huh. My travel bag, yes. 
Q: This is the black leather bag we're talking about? 
A: Yes. 
Q: Let me show you some photographs from the trial. These are trial 
exhibits. What they are -- and correct myself: They are photographs of 
trial 1 exhibits. Okay? 
A: Uh-huh. 
MR. KELLY: Could I step up here and see these? 
MR. PETROCELLI: Yes. I don't have duplicates of these, so everybody is 
free to look at them. 
MR. BAKER: Okay. Question? 
BY MR. PETROCELLI: 
Q: The question, Mr. Simpson, is whether this black bag that we've been 
talking about, this black leather bag where you had the beard and 
goatee and the passport and credit cards and other items, is identified 
in these exhibits. 
A: Yeah, this appears to be the bag, yes. 
Q: Could you point to it? 
A:(Indicating.) It looks like that could be the bag --  
Q: So for the record, you are pointing to what was marked in the trial 
as Exhibit 1064. Are there other exhibit numbers there, Mr. Baker? 
MR. BAKER: No. It's just 1064. 
THE WITNESS: Two different bags, though. 
BY MR. PETROCELLI: 
Q: Oh, there are two different bags on --  
MR. BAKER: There is a carry-on bag in 1064 as well. It's a fold-over 
bag, garment bag I think it's commonly called. It has his initials on 
it. 
BY MR. PETROCELLI: 
Q: How many different bags are depicted in Exhibit 1064? 
A: It appears to be two. 
Q: The two on the right he bottom are a different bag. Right? 
A: Yes. 
Q: What bag is that? 
A: Different than we're talking about. That's kind of a suit carry bag. 
Q: And the other photographs, 1, 2, 3, 4, are the black garment bag? 
A: No. 
Q: The black leather bag? 
A: Grip. Grip. I use it as a briefcase. 
Q: What do you call this? 
A: A grip, a briefcase. I use it as basically a briefcase, but I don't 
carry a briefcase anymore, and it's a grip. It's a grip. 
Q: Okay. And this is Exhibit 1064,the grip where --  
MR. BAKER: Two-thirds of it. 
BY MR. PETROCELLI: 
Q: Two-thirds of it is the black bag that you had with you on the 
evening of June 13th. Right? 
A: Yes. 
MR. PETROCELLI: By the way, Mr. Baker, Mr. Gelblum just informs me that 
these two pictures here of the garment bags are 1065, Exhibit 1065, not 
1064. 
MR. BAKER: Okay. Are we going to mark anything? What are we going to do 
relative to these exhibits? 
MR. PETROCELLI: I wasn't planning on marking them again. I just wanted 
to use it for identification. 
MR. BAKER: Well, since he identified it, I want to mark it. 
MR. PETROCELLI: These exhibits are immutable since we know what the 
numbers are. If you have any suggestions, I have no objections, but I 
don't have copies of this to mark, and I will be referring to a number 
of trial exhibits, but maybe what we can do is later on make copies of 
these. How's that? 
MR. BAKER: All right. I don't have any objection to that. 
MR. PETROCELLI: Do you have any suggestions? 
MR. KELLY: Well, I was just thinking, at some point I think that 
should be marked. Even though we have a number designating them with 
one copy in the book, I think it would be a good idea if we have 
exhibit labels or something to mark them at this point in the 
testimony. Especially since we have multiple bags on the same 
MR. BAKER: We can mark that as plaintiffs' 1 and get copies. 
MR. PETROCELLI: Let me think about the logistics of that, but for now 
let's just mark it Plaintiffs' Exhibit 1 --  
MR. KELLY: Through 4. 
MR. PETROCELLI: We already have plaintiff exhibit numbers for the 
Barbieri deposition. 
MR. LEONARD: Do you want to run sequentially, or do --  
MR. PETROCELLI: I don't know if that's going to be possible. 
MR. LEONARD: It's your deposition. 
MR. PETROCELLI: What is your practice on that? 
MR. BAKER: I usually run sequentially so we're not -- so we don't have 
Plaintiffs' 1 from --  
MR. PETROCELLI: I usually do also. 
MR. LEONARD: Anybody know  -- anybody have a copy? 
MR. PETROCELLI: Do you have a copy from the Barbieri deposition? We 
will get back to marking this. 
MR. LEONARD: All right. 
BY MR. PETROCELLI: 
Q: When you went to the police station, did you bring that black bag 
with you? 
A: Yes. 
Q: And that black bag went to Chicago with you? 
A: Yes. 
Q: Okay. And the first time that black bag left your possession when 
you came back from Chicago is when? 
A: When I believe it was Vannatter put it in the trunk of his car . 
Q: Where? 
A: At Rockingham. 
Q: Before you went to the police station? 
A: Yes. 
Q: Then when you got to the police station, did you have it there? 
A: No. It stayed in his car. 
Q: And at some point later in the day Vannatter returned it to you? 
A: Yes. 
Q: Okay. And that was when you got back from the office. Right? 
A: Yes. 
Q: And did you look in the bag when he returned it to you? 
A: Yes. 
Q: Did you notice anything missing? 
A: No. 
Q: Okay. Did you notice anything added to it, anything new? 
A: I didn't look that closely, but would say no. 
Q: Okay. Why did you put the gun in the bag? 
A: Because someone had -- well, at the time it's because I just brought 
it in the house, and my house was loaded with people, and I was in my 
office and I just stuck it in the bag at that time. 
Q: Were you the registered owner of that gun? 
A: I thought I was, yes. 
Q: Were you? 
A: It turns out since, I have only read that it was registered to 
someone else. 
Q: Who? 
A: I don't know. 
Q: How did you cause to get a gun registered in the name of another 
person? 
MR. BAKER: Well, wait a minute. That's argumentative. Don't answer that 
question. That assumes that he caused that to happen. 
BY MR. PETROCELLI: 
Q: Did you purchase that gun? 
A: No. 
Q: How did you come to possess the gun? 
A: It was given to me as a gift. 
Q: Who gave it to you as a gift? 
A: I believe it was Mike Ornstein. 
Q: Mike? 
A: Ornstein. 
Q: When did he give it to you? 
A: One Christmas, I believe. 
Q: Years before? 
A: Possibly. 
Q: And when you received the gun, did you do anything to try to get it 
registered in your name? 
A: I was told it was registered. It was already taken care of. 
Q: By whom? 
A: I don't know. I didn't ask. 
Q: So as of June of --  
MR. BAKER: You mean who took care of the registration, or who told him 
that it was registered? 
MR. PETROCELLI: Who took care of the registration. 
Q: Do you know who did? 
A: I assume Mike Ornstein had. 
Q: You don't know, though? 
A: No. 
Q: Who told you that it was taken care of? 
A: Mike Ornstein. 
Q: Had you ever used that gun? 
A: No. 
Q: Did you keep it loaded? 
A: Yes. 
Q: At all times? 
A: From the time he gave it to me, no. 
Q: When did you load it for the first time? 
A: Roughly a month previous to the deaths. 
Q: And why? 
A: Because I had an incident on the freeway, and I started keeping the 
gun in my car. 
Q: Before the incident on the freeway, you did not have the gun in your 
car? 
A: Correct. 
Q: Where was it? 
A: Probably in my closet. 
Q: And this incident was around the 7th of May en route to Dana Point? 
A: That's correct. 
Q: Or Monarch Bay, I should say? 
A: That's correct. 
Q: Did you own any other guns in June of '94? 
A: Yes. 
Q: How many? 
A: I don't know. 
Q: Lots? 
A: I would think so. 
Q: Where were they? 
A: Mostly in my closet. 
Q: More than five? 
A: I don't think so. 
Q: Were any of them loaded in June of '94 besides this one gun? 
A: I don't believe so. One might have been, but it had a lock on it. 
Q: Can you identify the guns that you owned in June of '94? 
A: No, I can't. 
Q: Do you know the names of them? 
A: One I know is an M -- I think was an M-16,and I think that was the 
.357, and I think there was another. 
Q: Three guns? 
A: I may have had some more, but I don't know. 
Q: Did you -- beginning around I think you said the month before the 
deaths, you put the .357 underneath the seat of the Bentley. Is that 
right? 
A: Yes. 
Q: And did you put any gun in the Bronco? 
A: No 
Q: You typically drove the Bronco. Right? 
A: I drove both cars. 
Q: You drove the Bronco more. 
A: You know, depends. It just depends. At night I would drive the 
Bentley and -- it just depends. You know, I really can't tell you which 
one I drove more. 
Q: You can't? 
A: No. 
Q: The Bronco was your favorite car, wasn't it? 
A: Not necessarily, no. 
Q: You drove them both around the same. Correct? Is that what you're 
now saying? 
MR. BAKER: Is that what he is now saying as contrasted to what he said 
before? That's argumentative. Instruct him not to answer that. 
BY MR. PETROCELLI: 
Q: Is that your testimony, that you drove both the Bentley and the 
Bronco roughly the same? 
A: Yeah, I would think actually roughly the same amount of time, yeah. 
Q: Did you in June of 1994 -- let's make it more specific. As of June 12 
of 1994, in addition to any guns that you had mentioned, did you own 
any other weapons? 
A: No. 
Q: Did you own any knives other than kitchen 120] knifes? 
A: Yes. 
Q: How many? 
A: I have no idea. 
Q: Where did you get those knifes? 
A: I worked for a company that made knifes. 
Q: What is the name of that company? 
A: Forschner. 
Q: F-o-r-s-c-h-n-e-r. You are on the board of directors? 
A: Yes. 
Q: You were. 
A: Yes. 
Q: Are you still? 
A: No. 
Q: And what kind of knifes does Forschner make? 
A: I was involved with the Swiss Army knife basically. 
Q: What do you mean, you were "involved" with it? 
A: Well, that's what I spent most of my time trying to promote. 
Q: What is a Swiss Army knife? 
A: A utility knife, I believe. 
Q: How big is it? 
A: It depends. 
Q: There are different sizes? 
A: Yes. 
Q: What do they range from? 
A: A pocketknife to a multi-purpose larger knife. 
Q: How long? 
A: I don't know. 
Q: What is the longest Swiss Army knife that you've seen? 
MR. LEONARD: You talking about hilt and blade or blade? What are you 
talking about? 
MR. PETROCELLI: Blade. 
THE WITNESS: I'm guessing now. I'd say the big 
knife is two, two and a half, three inches maybe. 
BY MR. PETROCELLI: 
Q: Have you ever seen one where the blade is six inches? 
A: No. 
Q: Are the only knives that you owned outside of kitchen knives these 
Swiss Army knives made by Forschner? 
Q: I may have had a few other knives. I'm not sure. 
Q: You may have? 
A: Yes. 
Q: Do you remember having any? 
A: I remember one, but I remember having others, too. 
Q: Well, how many did you have, outside of the Swiss Army knives, as 
of June 12? 
A: I have no idea. 
Q: More than 10? 
A: I doubt that. 
Q: More than five? 
A: I don't know. 
Q: Could it be more than five? 
MR. BAKER: Don't guess or speculate. 
THE WITNESS: I don't know. 
BY MR. PETROCELLI: 
Q: Where were these knives? 
A: I have no idea. 
Q: What was their purpose in your having --  what was your purpose in 
having them? 
A: We went camping a lot, and, you know, from time to time you buy a 
knife. So I hadn't seen them, but I bought a knife a few weeks before, 
a month or so before. 
Q: Who went camping a lot? 
A: Nicole and I and the kids over the years, my other kids, Nicole and 
I. 
Q: And you used these knives for camping, the ones you're now referring 
to? 
A: Nicole would buy them and -- I guess. 
Q: Let me be clear on this, Mr. Simpson. I am asking what knives were 
in your house on the evening as of June 12, 1994 outside of knives used 
for eating. 
A: I have absolutely no idea. 
Q: You described some Swiss Army knives. Correct? 
A: Yes. 
Q: Where were those kept? 
A: Wherever. Downstairs in drawers. I give them out as gifts, so 
they're all over the place. 
Q: Were they in boxes? 
A: Most of them, yes. 
Q: Each individual Swiss Army knife was in a box. Correct? 
A: Yes. 
Q: And they were downstairs in various places? 
A: Yes. 
Q: Any in your bedroom? 
A: I'm sure. 
Q: You get them for free? 
A: Yes. 1 
Q: Did the Forschner Company Ever give you any training on the use of 
these knives? 
A: No. 
Q: Now, in addition to the Swiss Army knives, you said that you owned 
some other knives, the number of which you cannot recall. Right? 
A: I said I assumed I did. Over the years I know with my older kids, my 
younger kids, we have camped over the years and you buy things, and 
yes. 
Q: Where did you keep the knives used for camping? 
A: Normally outside with all whatever camping stuff we had, but I was 
never in charge of that so I don't know. 
Q: In the garage? 
A: Yeah. 
Q: Did you have any other knives in the residence, outside of the 
garage? 
A: I had one in particular that I do know of. 
Q: Describe that knife. 
A: It was sort of a jackknife, but it didn't have a spring. 
Q: What do you mean by " jackknife"? 
A: You know, when you used to push it and the knife jumps out. 
Q: So when you pushed it, you have to pull it up, you mean? It didn't 
spring out? 
A: Yeah. Well, I think you can even shake it out 
Q: How long is that knife --  
A: I don't know. 
Q: -- the blade? 
A: I don't know. 
Q: Where was that knife on the evening of June 12th? 
A: In my -- as far as I know, in my home. 
Q: Where in your home? 
A: In my bedroom. 
Q: Was that a stiletto? 
A: I don't know what  --  I don't know. 
Q: Where in your bedroom. 
A: On a shelf. 
Q: What shelf? 
A: The shelf in my vanity. 
Q: Can you describe exactly where in the vanity? 
A: My vanity is one of these vanities with the mirrors, you can look 
three ways, and it was on a shelf there. 
Q: Who put it there? 
A: I did. 
Q: When did you put it there? 
A: Whenever I bought it. 
Q: From the time you bought it and when you put it there, did you ever 
use it? 
A: No. 
Q: Did you ever see it? 
A: Not consciously, no. 
Q: Was it visible if you were standing in front of the vanity? 
A: No. 
Q: Where did you buy that knife? 
A: Someplace downtown. 
Q: Was that Ross Cutlery? 
A: Could very well be, yes. 
Q: Was that during the shooting of "Frogman"? 
A: Yes. 
Q: Why did you buy it? 
A: Because I liked it. 
Q: You went in and browsed around? 
A: Actually, my -- we were there about a half a day, and my seat where 
they put us was virtually in the store, and various people took me in 
the store and tell me things that they wanted because they handled 
Swiss Army watches and knives, and during the course of hanging around 
all day I bought it. 
Q: What about the knife did you like? 
A: The way it looked. 
Q: Was that the first time you bought a knife for aesthetic purposes? 
A: I think most things that I buy are for aesthetic purposes. 
Q: Is that the first time you bought a knife for aesthetic purposes? 
A: I can't say that. I know in my life I've bought knives before, and 
I'm sure it was because aesthetically I liked it, because I'm not 
really a woodsman. 
Q: So you have bought knives before just for souvenirs or to collect 
them. Right? 
A: When I was a kid, you know, you buy knives or --  
Q: And as an adult? 
A: I'm sure I have as an adult. 
Q: And whatever knives you collected over the years, if you still have 
them, they were in your residence. Is that right? 
A: If I still have them. l don't know where they are because I haven't 
seen them. 
Q: You haven't seen them since your release from jail? 
A: I haven't seen them in years. 
Q: When was the first time you remember purchasing a knife before May 
of 1994 when you purchased this knife from Ross Cutlery? 
A: Probably the summer of 92  -- summer of '91 or '92, I would think. 
Q: What knife did you purchase then? 
A: I don't know. It was like a Jim -- I don't know if it was a Bowie. It 
was a hunting knife sort of thing. 
Q: What did you do with it? 
A: I don't know. 
Q: Did you ever use it? 
A: No. 
Q: Where did you keep it? 
A: With all my camping stuff. 
Q: Where is that? 
A: I don't know. 
Q: You don't know where your camping stuff is? 
A: No. 
Q: In the garage? 
A: I don't know. Nicole was the camper in the family, so -- and I think 
she may have taken it to camp. You know, she does more camping than I 
do, so. . . 
Q: Did you ever use the knife you bought from Ross Cutlery? 
A: No. 
Q: Where is that knife now? 
A: I believe in the custody of you guys. 
Q: The police took it? 
A: No. 
Q: Who took it? 
A: A judge. 
Q: Delbert Wong? 
A: I have no idea. 
Q: Was taken from where? 
A: I wasn't with him. I was in jail. 
Q: How do you know he took it? 
A: I was told he did. 
Q: Who told you that? 
MR. BAKER: You don't have to get into that. That's --  
BY MR. PETROCELLI: 
Q: Is that -- I'm sorry. 
MR. BAKER: -- protected by the attorney-client privilege. 
BY MR. PETROCELLI: 
Q: Is that the knife in the sealed envelope? 
A: I don't know. I haven't seen the sealed envelope. 
Q: So it's your testimony that from the moment you bought that knife, 
you took it home that day, put it in that vanity and never touched it 
again. Is that right? 
A: That's correct. 
Q: Did -- the week before, you were back in Connecticut. Right? 
A: Yes. 
MR. BAKER: The week before June 12, is that what we're talking about? 
MR. PETROCELLI: Yes, Mr. Baker. 
Q: You attended a board meeting at Forschner. Right? 
A: Yes. 
Q: And you were driven from Connecticut to Long Island, Correct? 
A: Correct. 
Q: By a limo driver. Right? 
A: Correct. 
Q: And you brought back with you from the board meeting a box of 
knives. Right? 
A: No, that's not correct. 
Q: Did you bring back with you any knives? 
A: I believe so, yes. 
Q: What did you bring back? 
A: I think I may have brought three  -- two -- I brought a bunch of little 
knives that were like team knives, because I dispensed them to -- well, 
one friend, and I brought maybe two and I can't think of the name of 
this knife. It's a kind of a -- it's a top-of-the-line thing with 
everything involved, and I brought back a lot of boxes of watches, a 
lot of boxes of watches. 
Q: How many boxes? 
A: I would say 13,14,15. 
Q: And were the knives and the boxes all in one big box? 
A: A bag, yes. 
Q: A bag? 
A: Yes. 
Q: Did you pay for any of these items? 
A: No . 
Q: They were given to you as promotional items for you to distribute? 
A: Yes. 
Q: Did -- now I want to go back to the knives. You said that there were 
some team knives? 
A: Yeah. 
Q: T-e-a-m. 
A: Yes. 
Q: What are they? 
A: Some of the people I was visiting when I left there are Giant fans, 
and they would have like the name of the Giants on them, and I gave 
them a knife. 
Q: I see. 
A: And they were for key chains. 
Q: Did these knives have team names imprinted on them. 
A: Yes. 
Q: And you had one for a number of different teams? 
A: No, because I only had two or three of them. 
Q: These were football teams? 
A: Giants I know because the person I was going to was a Giants fan, 
and I gave him one. 
Q: Who was that? 
A: Bobby Bender. 
Q: In New York. Right? 
A: Yes. 
Q: He's a good friend of yours. Right? 
A: Yes. 
Q: And you saw him when you came back from the board meeting. Right? 
A: Yes, and I gave some watches out there also. 
Q: Besides these two or three team knives, did you have any other 
knives with you? 
A: I'm not sure, but I may have taken one -- I'm so sorry I can't think 
of the name of our top-of-the-line knife. 
Q: A utility knife? 
A: Yeah. I can't think of the name. There's a name for it, and I 
apologize. I can't think of the name of it. I may have taken one of 
them. But basically I'm interested in the watches. The watches are what 
I gave out. I had enough of the knives previous. 
Q: You have to keep your voice up. You are trailing off. 
A: Basically it was watches that -- I think they took a list. I'm pretty 
sure they took a list of what I -- inventory of what I took. 
Q: You came out with two large white shopping bags from the Forschner 
warehouse. Right? 
A: First, they wouldn't have been shopping bags, but I know there was 
at least one large bag. 
Q: And you brought the bag or bags  --  
A: Yeah. 
Q: --  into the back seat with you. Right? 
A: That's correct.. 
Q: Do you remember the name of the driver? 
A: No. 
Q: Does the name John Upson ring a bell? 
A: No. 
Q: Did you offer to give a knife or a watch to the driver? 
A: I believe I did. 
Q: You believe you offered? 
A: I believe I gave him. 
Q: What did you give him? 
A: I don't recall. Probably that big --  whatever you call it, utility 
knife thing. Probably. But I could have given him a watch, but I doubt 
that. 
Q: Did you show the knives to Mr. Upson, the driver? 
A: No. 
Q: Now, you showed  --  did you have with you one knife that was 12 to 16 
inches long? 
A: No. 
Q: Are you positive? 
A: Yes. 
Q: Did you take that knife out and show it to him and make a stabbing 
motion? 
MR. BAKER: Wait a minute. Don't answer that question. 
MR. PETROCELLI: Why not? 
MR. BAKER: Because there is no foundation for it. He just said he 
didn't have that knife. Now you've said, "Did you take that knife," 
assuming the one that's 12 to 16 inches long, "show it to him and make 
a stabbing motion?" We are not --  
MR. PETROCELLI: It might refresh his recollection. 
MR. BAKER: Yeah, right. No way he is going to answer that. 
BY MR. PETROCELLI: 
Q: Do you recall if you took a knife 12 to 16 inches long and made a 
stabbing motion with it to the limo driver? 
A: I know I didn't. 
Q: You remember you didn't? 
A: Yes. 
MR. BAKER: He says he knows he didn't. How can you remember an act that 
you did not do? 
BY MR. PETROCELLI: 
Q: What was the longest blade of the knives Pace 132 that you had with 
you and showed to the limo driver? 
A: If I took one of our utility things, I would say whatever that blade 
is, two inch maybe, two and a half, maybe an inch and a half. I really 
don't know. You can get one and look at it. 
Q: When showing the limo driver the knives, did you say, "You can even 
kill somebody with this"? 
A: l never showed the limo driver the knives. I believe I may have 
given him one, but I didn't show him anything that I had in the bag. 
Q: You did not even show him the knives you remember having? 
A: I did not. I think I just gave him a gift. 
Q: Did you say, "You can even kill somebody with this"  --  
A: No. 
Q: -- alluding to knives? 
A: Absolutely not. 
Q: Did you make four or five phone cal1s during that trip? 
A: I believe so. 
Q: To your friends? 
A: Yes. 
Q: Did you say you'd be a little late for golf? 
A: Yes. 
Q: You made some phone calls to your office? 
A: Possibly. 
Q: You looked at some papers? 
A: Possibly. 
Q: Fell asleep for about ha1f an hour? 
A: Probably. 
Q: Did you decide to change into golf clothes --  
A: I'm pretty sure I did. 
Q: -- in the car? 
A: I'm not sure, but I am pretty sure I would have tried if I had my 
clothes in the car, yes. 
Q: With respect to any of these hunting knives or camping knives that 
you purchased over the years, did any of them have a blade six inches 
or longer? 
A: I really don't know. 
Q: You have no recol1ection at all? 
A: No, I don't. 
Q: Do you ever remember having in your house a hunting knife with a 
blade six inches or longer? 
A: No. 
Q: Do you ever remember using such a knife? 
A: No. I know fishing with the kids, hunting, we seem to have always 
had a knife of some sort, but I don't recall when --  
Q: When you have gone fishing --  
A: -- or what. 
MR. BAKER: You have to wait until he finishes. 
MR. PETROCELLI: I apologize, Mr. Baker. 
MR. BAKER: Were you finished? 
THE WITNESS: Yes. 
BY MR. PETROCELLI: 
Q: When you have gone hunting or fishing, do you recall using a knife 
with a blade six inches or longer? 
A: No, I don't recall. 
Q: You don't remember one way or the other? 
A: One way or the other. 
Q: Okay. Can you account for all of the hunting and camping knives that 
you purchased? 
A: No, of course not. 
Q: You can't account for them. Right? 
MR. BAKER: Don't answer that. 
THE WITNESS: I haven't been hunting in 
two years. 
MR. BAKER: Don't --  
BY MR. PETROCELLI: 
Q: What kind of game do you hunt? 
A: The one time I went hunting, I went hunting for birds once, and that 
was I would say the early '70s, and I went hunting in the '60s for 
deer. 
Q: Did you go hunting in the '80s? 
A: No. 
Q: And in the '90s? 
A: No. 
Q: Did you go fishing in the '9os? 
A: I believe so. 
Q: And did you use a knife? 
A: I believe so. 
Q: Did it have a blade six inches or longer? 
A: I don't know. 
Q: Where is the knife you used? 
A: I have no idea. Or the fishing poles or any of it. 
Q: Let's go back to the black bag that we looked at which was marked as 
the Exhibit 1064 in the criminal case. When you put the gun into the 
bag, what did you do with the bag that evening? 
A: Probably put it in my bedroom. 
Q: Did you put anything else into it? 
A: That night --  
Q: Yes. 
A: -- no. 
Q: Now, you left -- you slept at your house that night. Right? 
A: Yes. 
Q: You went to the Kardashian house the next morning? 
A: Yes. 
Q: And took the black bag with you? 
A: Yes. 
Q: And did you take any other luggage with you? 
A: I'm not sure. I think l took another bag, but I'm not real1y sure. 
Q: Okay. And when you went to the Kardashian house with the black bag, 
where did you keep it while you were there? 
A: I put it in a closet. 
Q: In the bedroom in which you slept? 
A: Yes. 
Q: And did you ever go to that black bag during the time you were at 
the Kardashian house before you left the home on Friday morning? 
MR. BAKER: And after he placed it there? 
MR. PETROCELLI: Yes. 
THE WITNESS: I don't believe -- because I took some 
pictures out of it then, I don't believe so. 
BY MR. PETROCELLI: 
Q: What pictures did you take out of it? 
A: The pictures that I had carried over to Kardashian's house. 
Q: These are the three family pictures you mentioned --  
A: Yes. 
Q: -- before? 
A: Yes. 
Q: And you took them from your home in Rockingham. 
A: Yes. 
Q: And you put them in the black bag? 
A: Yes. 
Q: Where did you take them from in Rockingham, what location? l 
A: Wherever they were. Wherever they were. 
Q: In your bedroom? 
A: I don't know. 
Q: Put them in the black bag? 
A: Yes. 
Q: Did you put anything else in the black bag? 
A: I think I put some socks and some underwear in the black bag. 
Q: The same bag? 
A: Yes. 
Q: Anything else? 
A: Well, the gun was in there. 
Q: Anything else? 
A: No. 
MR. PETROCELLI: We have to change tapes now. We have to take a moment. 
THE VIDE0GRAPHER: This is the end of tape No.1 of volume 1. The time is 
approximately 11:52, and we are off the record. (Recess.) THE 
VIDEOGRAPHER: We are on the record. The time is approximately 11 
:56.This is the beginning of tape No.2 of Volume I. 
BY MR. PETROCELLI: 
Q: You put three photographs of your family in the black bag which you 
got someplace in the house at Rockingham. Right? 
A: That's correct. 
Q: And what did those photos depict? 
A: My family. 
Q: By "family," who are you referring to? 
A: Sydney, Justin, Nicole, Jason, Arnelle. 
Q: Each photo had all of them in it? 
A: No. It was kind of a mixture. 
Q: So your four children plus Nicole. 
A: Yeah. 
Q: And yourself. 
A: And myself, yeah. 
Q: And what was your purpose in putting those photos into the black 
bag? 
A: Because I wanted pictures of my family with me. 
Q: With you at the Kardashian house? 
A: Wherever I was going, but, yes, at the Kardashian house. 
Q: Did you anticipate taking them to jail? 
A: No. I didn't anticipate being arrested. 
Q: Why did you want to bring the pictures with you to the Kardashian 
house? 
MR. BAKER: Asked and answered. Don't answer that. 
BY MR. PETROCELLI: 
Q: Did you contemplate that you would be killing yourself? 
A: No. 
Q: At that point in time? 
A: No. 
Q: You put some socks and underwear into the black bag? 
A: Yes. 
Q: What was your purpose in that? 
A: To have clean socks and underwear. 
Q: For how many days? 
A: I didn't know. 
Q: And you also brought other clothing over. Right? 
A: Yes, other clothes came over when I was over there. 
Q: You brought some other clothing with you? 
A: I think I did, but I know clothes came later on when I was there. 
Q: You had additional clothes brought over? 
A: Yes. 
Q: Okay. When you got to the Kardashian house  --  Can you remember 
putting anything else in this bag besides what you've already said? 
A: I may have, but I don't recall. I don't think it could have held 
much more. 
Q: When you went to the Kardashian house, you put the bag immediately 
into a closet? 
A: I don't know about immediately, but I -- before I went to sleep that 
night I did, yes. 
Q: Did you take anything out of it to use? 
A: Yes. 
Q: What? 
A: My overnight kit. 
Q: Anything else? 
A: Not that I recall. the pictures maybe. I'm not even sure If I took 
them out. 
Q: And what about the socks and underwear? 
A: Possibly, yes. Probably a pair of socks, a pair of underwear, I may 
have, yes, the next morning. 
Q: Was this a locked closet? 
A: No. 
Q: A closet with a door on it? 
A: Yes. 
Q: And on the floor? 
A: Well, I kinda -- I had money in my bag, so I sort of put it under some 
stuff. 
Q: You had money in this black bag? 
A: Yes. 
Q: How much money was in it? 
A: A lot. 
Q: How much? 
A: I don't know. 
Q: When you say "a lot," more than 10,000? 
A: Could have been close to l0,000, yes. 
Q: When did that money get into the bag? 
A: When I went over to Bob's, I put it in -- took it out of my pocket and 
put it in the bag. 
Q: You had $10,000 in your pocket when you went over to the Kardashian 
house? 
MR. BAKER: He doesn't know exactly. What he said --  
MR. PETROCELLI: Roughly. 
MR. BAKER: He said he approx -- it could have been as much as 10,000. 
MR. PETROCELLI: Approximately 10,000. 
THE WITNESS: It could have been 
as much as 10,000. 
MR. PETROCELLI: He just said it now, Mr. Baker. 
MR. BAKER: He did not. He said, "It could have been as much as l0,000." 

THE WITNESS: Could have been as much as 10,000. 
BY MR. PETROCELLI: 
Q: What is your best estimate? 
A: It could have been as much as 10,000. 
Q: Let's call it 10,000. 
MR. BAKER: Let's call it it could have been as much as 10,000. Let's 
call it  -- let's be accurate. 
THE WITNESS: Yeah. 
BY MR. PETROCELLI: 
Q: You had that money in your pocket when you went to Kardashian's. 
Right? 
A: My pocket or my bag. I don't know exactly when I put it in the bag, 
but my pocket or my bag, yes. 
Q: When did you get that money? 
A: What do you mean? 
Q: Did you have it with you when you came back from Chicago? 
A: I had maybe 3,000 or so when I got back from Chicago. yes. 
Q: On your person. Right? 
A: On my person, yes. 
Q: And when did you get the additional funds? 
A: When Officer Lange walked us in my closet when I arrived back in my 
house with Skip Taft and with Bob Kardashian, I reached under a sweater 
and I pulled out roughly -- roughly $6,000 and said to Officer Lange in 
front of Bob Kardashian, in front of Skip Taft, "At least your guys are 
honest. They didn't take my money." 
Q: Was there any money missing at all? 
A: Well, I didn't know exactly what was there, so I wouldn't have 
known. 
Q: Was that al1 the money you had there? 
A: Yeah. Possibly, yeah. I may have had, you know, had some money 
spread around in other places, but that I recal1, yes. 
Q: Did you have any other significant sums of cash around the house? 
A: What's a significant sum of cash to you? 
Q: More than a couple thousand. 
A: I don't know. I real1y don't know. 
Q: So you took that money and put it in your pocket? 
A: At that point in time, yes. 
Q: And you left it there. When you got to Kardashian's house, you put 
it in the black bag. Right? 
A: I may have put it in the black bag before I left my house to go to 
Kardashian's. 
Q: When you put the bag into the closet before you went into bed that 
night, the money was in the bag. Right? 
A: The wad was, yes. 
Q: Which could have been as much as 10,000. Right? 
A: No. Which could have been as much as S5- or $6,000. 
Q: And the 3,000 was still on your person? 
A: I kept it with a couple credit cards probably in my pocket. 
Q: What was your purpose in bringing that money? 
A: Because it was mine. 
Q: Did you plan to go anywhere or use it? 
A: No. 
Q: Now, did you go to the black bag at all the rest of the time you 
were there at the Kardashian house? 
A: I'm not sure. I don't think so, but again I don't know. I was there 
a week. I mean, I was there three or four days, so I don't recal1 going 
there at all. 
Q: You left he house on Thursday to go to the funeral. Right? 
A: Yes. 
Q: Did you go to the wake? 
A: Yes. 
Q: That was Wednesday? 
A: I believe so. 
Q: On Wednesday did you take the black bag with you? 
A: No. 
Q: Did you take the black bag with you to the funeral? 
A: I don't think I took the black bag out of where I placed it in the 
closet after I put it in the closet. 
Q: And did you take anything out of the black bag before you went to 
the wake? 
A: As I stated, I may have taken a picture out. I'm not sure. 
Q: And did you take anything out of the black bag before you went to 
the funeral? 
A: I don't believe so. 
Q: Okay. Now, on Friday morning, originally the plan was you were going 
to be driven down by Bob Shapiro to the police station. Right? 
A: I believe so. 
Q: At some point were you informed before you left that the plan had 
changed, and now the police were coming to the house? 
A: I don't recall. I do know -- I do recall them saying "We have to go" a 
few times. 
Q: Now, the pictures were taken of you by the doctors upstairs. Right? 
A: Yes. 
Q: And that's where Shapiro was when you last saw him. Right? 
A: I don't recall. 
Q: When you left to go with Mr. Cowlings --  
A: Yes. 
Q: -- where were the other people in the house? 
A: I have no idea. 
Q: What did you tell them you were doing? 
A: I didn't tell them anything. 
Q: To your knowledge where did they think you were? 
A: I have no idea. 
Q: Why didn't you tell them where you were at all times? 
MR. BAKER: Well, don't answer that.. That's argumentative and assumes 
that he has some obligation to tel1 everybody where he is at al1 times. 
BY MR. PETROCELLI: 
Q: You understood that you were about to be arrested. Right? 
A: Yes. 
MR. BAKER: We have been through this. 
BY MR. PETROCELLI: 
Q: Didn't you believe that they should know your whereabouts at all 
times? 
A: Never gave it a thought. 
Q: And you never gave it a thought to te11 them that you were leaving. 
A: Correct. 
Q: Is it your habit to carry as much as $10,000 in cash on you? 
A: Yes. 
Q: You usual1y carry that much? 
A: If I'm going anywhere, yes. 
Q: When you went to Chicago, how much did you have on you? 
A: About three. Thirty-five maybe. 
Q: You said that you take that much cash, Up to $10,000, when you're 
going someplace. 
A: Yeah, often, yes. 
Q: When you left the Kardashian residence with up to $10,000 in cash, 
where were you going? 
A: It was in my bag at that point in time, and I took my bag with me. I 
was going to the grave site, as I told you before. 
Q: Did you stil1 have in the car the 3,000 or so in your pocket? 
A: Actually I had given it, to be correct, and I am correcting myself 
here, I had given it all to A.C. that morning to dispense it among my 
kids, my older kids, and to give Paula some money to get her a flight. 
Q: You gave all of what to A.C.? 
A: Whatever cash, whatever checks I had from golf, I had given it to 
A.C. and told him that split it among my kids, and someone said about 
Paula's flight, and to give her a couple of thousand dol1ars for her 
flight. 
Q: And that was the cash you had --  
A: That was all the cash I had. I had  -- I ended up with $3 and 
something, I'm told, but I don't know. I just gave him all that money, 
yes. 
Q: And you told Cowlings to spread it around among the kids? 
A: No. I told him to split it between my daughter and my son, because I 
didn't think they would want to work at this time, and to give Paula 
what she needed for her flight. 
Q: Arnelle and --  
A: Jason. 
Q: Jason. 
A: And to give Paula whatever she needed for her flight. 
Q: And the rest of the money, the 6500 or so, was still in the bag? 
A: No. I gave him all of the money. There was no money the police ever 
found in the bag that was over $3.63. That's a fallacy that you guys 
have been promoting. 
Q: You gave the entire sum, up to -- which could have been as high as 
10,000, to Mr. Cowlings in the morning? 
A: Whatever it amounted to, checks or cash, I gave to Mr. Cowlings. a 
How much were in checks? 
A: I have no idea. 
Q: Do you have roughly any idea what the amount of checks were? 
A: Absolutely none. Some of them I had had for weeks. They're from 
golf. 
Q: When you say, "They're from golf," what do you mean? 
A: Money I won playing golf. 
Q: People wrote you checks? 
A: Yeah. When they don't have cash. 
Q: I see. And was it more than a couple thousand dollars? 
A: I don't know. 
Q: Could it have been as much 5,000 in checks? 
A: Could have been. 
Q: What is your best estimate of the total number of checks -- the total 
amount of the checks that you gave Mr. Cowlings that morning? 
A: I have no idea. 
Q: Could it have been more than $10,000? 
MR. BAKER: I am not -- you've exhausted that. I am going to instruct him 
not to answer that. 
BY MR. PETROCELLI: 
Q: When did you decide to give the money to Mr. Cowlings? 
A: In the morning when I was told  -- after I was told I was gonna be 
arrested. 
Q: Did any of these checks come from Mr. Thibodeau or Thibodeau? 
A: I doubt it. 
Q: Who were the checks from? 
A: I don't know. 
Q: Can you identify any of them? 
A: No. 
Q: They were all made out to you? 
A: I don't know. Could be cash. Sometimes a guy will give you a check 
that somebody gave them. 
Q: Okay. 
MR. BAKER: I've never had that experience. I give the checks. 
BY MR. PETROCELLI: 
Q: Were the checks in an envelope, Mr. Simpson? 
A: No. 
Q: Did you put -- When you made the decision to leave with Mr. Cowlings, 
what did you decide to take with you, if anything? 
A: Decide? I just grabbed my bag because it had the pictures in -- and 
the gun in it. 
Q: And when you took that bag and you went into the Bronco, did it have 
anything else in it besides the pictures and the gun? 
A: Whatever else was in it, yes. 
Q: From before. 
A: Yeah. Except my overnight kit, my medication and stuff, because I 
don't think I was thinking about packing stuff. 
Q: Was there a bottle of pills that you took with you? 
A: I don't recall. Not -- certainly not  -- my medication was not in there. 
Q: Were you taking any Xanax at that time? 
A: Never in my life. 
Q: Was there a pill vial of Xanax found in your bag? 
A: I'm told there was. 
Q: How did it get there? 
A: I took it from Nicole. 
Q: When? 
A: A few weeks before this incident. 
Q: Was it a prescription made out to Nicole? 
A: I don't know. 
Q: Where did you get it from Nicole? 
A: Just from her house. 
Q: The house on Bundy? 
A: Yes. 
Q: Where was it in the house? 
A: I believe in her bathroom. 
Q: Which was on which floor? 
A: Second or third floor. 
Q: In a medicine cabinet. 
A: I don't recall. 
Q: Did you take anything else on that occasion? 
A: No. 
Q: Just this one bottle of pills? 
A: Yes. 
Q: And why did you take it? 
A: Because they were having some problems, I guess, her and Dr. 
Fishman, and he had some concerns, and he mentioned them to me and 
Nicole had mentioned some stuff to me, and I was concerned about Nicole 
and what she had been doing the previous few months of her life. 
Q: Can you explain that more? 
A: I was concerned about Nicole. She was having some problems. Q What 
kind of problems? 
A: I don't know. 
Q: What kind of problems were you concerned that she was having? 
A: I don't know. She was just not herself. 
Q: How was she acting differently? 
A: She was -- ask her mother. I discussed it with her mother. I thought 
she was drinking --  
Q: I'm asking you now. 
A: Well, she was just not herself. She was a different person every 
time I talked to her. When I was in Puerto Rico, she seemed to be 
having a nervous breakdown; she even said she was, and I suspected it 
was drinking. I had hoped it wasn't pills or drugs, which I knew her 
friends were involved in, and I was hoping and still hope to this day 
that she wasn't involved in than 
Q: And how did these problems manifest themselves in her behavior 
toward you? 
A: She was erratic. She was -- from day to day I didn't know who she was. 
Then it didn't matter to me because I got out of the relationship. 
Q: Did you ever see her manifest that behavior before in your 
relationship? 
A: Yes. 
Q: When was that? 
A: Right before I went to Puerto Rico. 
Q: That was about April of 1994? 
A: March. 
Q: Before 1994 had she ever manifested this behavior that you were 
witnessing? 
A: Not really. No, not like this. 
Q: This was the first time you saw it? 
A: Well, yes, I saw it from time to time when I was back with her, but 
this -- I felt it was out of control to the point that I discussed it 
with her parents, and I attempted to get her to go to therapy again. 
Q: You were alarmed for her safety -- 
A: Yes. 
Q: -- and well-being? 
A: Yes. 
Q: And you spoke to her parents, meaning Louis and Juditha Brown? 
A: Basically Judy. 
Q: You call her Judy? 
A: Yes. 
Q: And did you say earlier, Mr. Simpson, that you spoke to Ron Fishman 
about this or Dr. Fishman? 
A: Yes. 
Q: Is Dr. Fishman Ron Fishman? 
A: Yes. 
Q: Why did you speak to Ron Fishman about Nicole's problems? 
A: Actually it was about his problem, but at this particular time a few 
weeks before her death, he was having a problem, and Nicole actually 
called me because they were having a problem 
Q: What kind of problem? 
A: You'd have to ask Ron Fishman. Basically Nicole was upset with Ron. 
He had just left her house. She called me at my office. Ron was having 
a beef with his wife. Somehow Nicole was involved in it. It had a lot 
to do with whatever these girls were doing. Nicole was concerned and 
called me. I told her to get Ron Fishman's number for me. She got his 
number, his car number for me.I asked him to come to my office. He came 
to my office. He was agitated. I took him and made him drink some 
coffee and told him to go back to work, and I went to Nicole's house to 
discuss it with her. 
Q: What did you discuss with Ron Fishman, if anything, about Nicole's 
problems? 
A: Well, it was basically about his problems. 
Q: What was the problem you and he discussed? 
MR. BAKER: Well, I am not sure that has anything to do with this, and I 
am going to invoke his right of privacy and instruct the witness not to 
respond to those questions. 
MR. PETROCELLI: Whose right of privacy? 
MR. BAKER: Dr. Fishman's right of privacy. 
MR. PETROCELLI: This is a conversation Dr. Fishman had with Mr. 
Simpson. 
MR. BAKER: I am well aware of that, but I am going to stand by my 
instruction and instruct Mr. Simpson not to discuss anything that he 
discussed with Mr. Fishman relative to Mr. Fishman's problems unless it 
somehow relates in that conversation to Nicole's problems. 
MR. PETROCELLI: I think that's what he was saying, Mr. Baker. 
MR. BAKER: Well, if it does, you can, but if not, then I don't think we 
need Mr. Fishman's problems brought into this matter. 
BY MR. PETROCELLI: 
Q: Well, is the discussion that you had with {l4] Mr. Fishman about his 
problems -- did that involve Nicole as well? 
A: Only to the fact that when he went to Nicole that morning to discuss 
it with her, evidently Nicole got very agitated with him and asked him 
to leave and then called me. 
Q: Who called you? 
A: Nicole. 
Q: So the sequence of events was you first got a call from Nicole 
saying that Fishman had come over to her house? 
A: Yes. 
Q: She got agitated with him. 
A: Evidently. 
Q: That's what she told you. Right? 
A: Yes. 
Q: And that -- and she was reporting this to you for you to talk to Ron 
or 
A: I guess so. 
Q: She asked you to talk to Ron? 
A: She was just telling me what was going on. 
Q: And what did Ron tell -- what did Nicole tell you about Ron's 
problems? 
A: That's between Ron and his wife. 
Q: But what did Nicole tell you about Ron's - -- 
A: That's between Ron and his wife. I don't recall. You ask Ron or his 
wife. 
Q: I'm a little confused. Are you saying that Nicole said, "That's 
between Ron and his wife," or are you refusing to tell me? 
A: No. I don't remember what she told me about Ron and his wife. I 
don't recall what he told me about Ron and his wife. Ask them. 
Q: I know. We will ask them. 
A: I don't recall. 
Q: But we are asking you now. 
A: I don't recall. 
Q: You don't recall what Nicole told you about Ron and his wife. 
A: I don't recall what Nicole told me about Ron and his wife. 
Q: And did Nicole tell you why she wanted you to call Ron? 
A: Not really. She was concerned about him, I guess. because she relied 
on him quite a bit over the previous two or three years when it came to 
Nicole's and my divorce and I guess getting back together. 
Q: She relied on Ron as a friend? 
A: As a friend and as an adviser, I presume. 
Q: Was Ron an internist? 
A: I don't know what his practice is. 
Q: Was he your doctor? 
A: No. 
Q: Was he Nicole's doctor? 
A: As far as I know. No. 
Q: And did Nicole tell you that she wanted you to tell Ron Fishman? 
A: No. She just called me. I gather she was somewhat concerned and 
agitated. 
Q: What did you then say to Ron Fishman? 
A: I told him to come by my office. 
Q: When he got there what did you say to him? 
A: I walked him to the Starbucks, had him drink some coffee, told him 
to get a  -- same advice I gave his wife: Either to get a lawyer or get a 
counselor. Basically that's what I told him 
Q: What day was that? 
A: I don't know. A few weeks before Nicole's murder. 
Q: Was it after Nicole's birthday? 
A: I don't recall, but it was around that time, yes. 
Q: Had you and Nicole already split up? 
A: Yes. 
Q: Now, what did all that have to do with the taking of the pills? 
A: That was just talking about what the girls had been up to and his 
concern about some things and -- 
Q: Ron's concern? 
A: About some things about what the girls were up to relative to 
drinking. 
Q: "Girls" meaning who? 
A: Faye,  -- -,  -- -, the whole group. 
Q: Just so I am clear on this, during this occasion Ron told you that 
he had concerns about  -- -, Nicole Simpson -- 
A: About the whole group, and I think the problems -- 
Q: Let me finish the question.  --  -- 
A: He didn't name them all, no, but he was talking about the girls, and 
normally when we spoke of the girls, it was this group of girls. 
Q: Describe that group by name. 
A: Faye Resnick,  -- -,  -- -, Nicole, and then one or two other girls that 
came in and out of the group who, you know -- I think  -- -, people who are 
 -- we knew had problems. 
Q: And Ron told you that he was concerned that the girls -- 
A: No. Basically he was discussing, I believe, as I recall, it was more 
concerning his wife, but evidently whatever was going on with him and 
his wife he felt was affected by whatever was going on in this group of 
women. 
Q: And what he was telling you was an expression of a concern about 
alcohol or drug use by these girls? 
A: Whatever it was. I don't recall exactly what he was expressing. I as 
a friend was just trying to tell him not to worry about the girls, to 
get out of the situation, would be my advice, or take his wife -- they 
need to go to therapy or they need to get a lawyer, which I advised her 
also. 
Q: "Her" being whom? 
A:  -- -. 
Q: Did anything that Ron said to you about the girls have to do with 
drugs? 
A: I think the whole tone of the conversations had to do with whatever, 
and drugs was obviously a part of it. 
Q: Did he say to you they were taking drugs? 
A: No. Not specifically, no. 
Q: Did he imply that to you? 
A: I think it was all a part of the conversation. a Did he tell you 
that he had prescribed the medication for Nicole? 
A: No. 
Q: Did he tell you that he gave pills to Nicole? 
A: No. Nicole had told me that she was concerned at times about who 
was taking what type of pills, especially Faye, and I believe she also 
mentioned  -- -. 
Q: Did Ron Fishman tell you that Nicole had pills that he had 
prescribed? 
A: No, he didn't. 
Q: Now, when you went into this medicine cabinet -- 
A: I don't know if it was a medicine cabinet. 
Q: That's right. You said you didn't remember. 
A: No. 
Q: Why did you take this particular bottle of pills? 
A: Because I heard them talking about Xanax, and when I saw it, I took 
it. 
Q: You heard who talking about Xanax? 
A: Nicole from time to time; Faye from time to time; Ron from time to 
time. We knew that Faye was taking them from time to time, and I 
assumed they were like the new Valium or something. 
Q: "Ron" being Ron Fishman? 
A: Pardon me? I'm sorry? 
Q: "Ron" being Ron Fishman? You said "Ron." 
A: In various conversations, yes. 
Q: You're saying that you had heard discussions involving Nicole and 
Ron and Faye about Xanax? 
A: I've heard various people discuss it from time to time, and that was 
the Xanax seemed to be something that they discussed from time to time, 
yes. 
Q: Did you ever talk to Nicole about her use of Xanax? 
A: I talked to Nicole about her drinking more than anything, and by 
this time I -- other than expressing my concern to her, which was 
difficult to do, most of my concerns about Nicole I expressed to her 
mother, and once I got out of our relationship, which is the early part 
of May, I had a long discussion for a couple days with her mother, and 
then after that I didn't want to hear it anymore. 
Q: Did you discuss Xanax with her mother? 
A: I don't believe so. 
Q: Now, when you took the Xanax, did Nicole see you take it? 
A: I don't re -- she may have asked me, "What is that you got, a but I 
don't really recall. She may have. I don't recall. 
Q: And what did you tell her? 
A: Nothing. 
Q: You took it to do what with it? 
A: To take it away from her. 
Q: So she wouldn't use it? 
A: I don't know if she was using it or if one of her friends left it 
there. 
Q: Did you ask her? 
A: No. 
Q: Do you know that the pills even belonged to her? 
A: No. 
Q: What did you do with them? 
A: Took them back to my office. 
Q: What did you do with them there? 
A: Put them in my bag. 
Q: Your black bag? 
A: Yes. 
Q: Why did you put them in your back bag? 
A: Because that's the bag I had. 
Q: Did you ever take any of them? 
A: Never, ever in my life have I ever taken a Xanax pill. 
Q: Why didn't you just throw them out? 
A: I don't know. They were in my office. I threw them in the bag. 
Q: When you left Nicole's, why didn't you throw them in the garbage? 
A: I probably would have if I would have cleaned out my bag one day, 
but I just put them in my bag. 
Q: So were the Xanax pills in your bag from that point on? 
A: I never looked to see. I have zipper areas in my bag that I never go 
into, so -- rarely go into, so I assume they were. If they were in my bag 
at this point when they got my bag, I assume they stayed there since 
then. 
Q: You never saw them again after you put the pills into your bag at 
your office. Is that right? 
A: That's correct. 
Q: Who is Naomi Fishman? 
A: I have no idea. 
Q: Let me show you a picture of a pill vial in the possession of LAPD, 
the Scientific Investigation Division, marked as their item No.158. 
After the break I will figure out how to get these things put into the 
record. 
MR. BAKER: I think it's 148. 
MR. PETROCELLI: I am sorry. I misspoke.148. 
Q: Did you see that photograph of the pill vial? 
A: I don't recall. I just saw it there, yeah. I just saw it just now. 
Q: Let me put it in front of you, SID item No. 148. Is that the bottle 
of Xanax that you took from Nicole's bathroom? 
A: I really couldn't tell you. 
Q: Does it look like it? 
A: It looks like all pill vials to me. 
Q: When you picked up the pill vial, did you read the name of the 
person to whom the prescription was made out? 
A: I'm pretty sure I did. 
Q: Did you know who Naomi Fishman was when you read it? 
A: I don't think I registered that. I just noticed Nicole's name wasn't 
on it. 
Q: Did you ask Ron Fishman about this pill bottle that you took? 
A: No. 
Q: Did you ask him how pills in the name of Naomi Fishman got to 
Nicole? 
A: No. 
Q: You never talked to him at all about the pill vial? 
A: Never, ever. 
Q: Did you ever ask anybody about how this got to Nicole? 
A: Never. 
Q: And you never asked Nicole? 
A: No. 
MR. PETROCELLI: It's 12:30now.We will take a break for lunch. THE 
VIDEOGRAPHER: We are going off the record l now, and the time is 
approximately 12:24. (At the hour of 12:24 p.m., a luncheon recess was 
taken, the deposition to resume at 1:34 p.m.) (At the hour of 1:27 
p.m., the deposition of ORENTHAL JAMES Simpson was resumed at the same 
place, the same persons being present.0 THE VIDEOGRAPHER: We are back 
on the record now, and the time is approximately 1:27. EXAMINATION 
(Resumed) 
BY MR. PETROCELLI: 
Q: Mr. Simpson, can you remember whether there was anything else in 
that black bag when you left Cowlings' -- Kardashian's house on the 17th 
of June other than what you've said so far? 
A: Well, I know there were things in there. I don't -- you know, I always 
keep my credit cards, I have a whole book of credit cards that I always 
keep in there, and cards, business cards. It's just a folder that I 
keep everything in. And, you know, I hadn't done an inventory of, 
obviously, what's in there, but I would imagine over a period of time I 
put things in there and they stay in there. I've seen a list since 
then, so I see watches and stuff in there also. 
Q: WHAT kind of watches? 
A: Probably Swiss Army watches and maybe a better watch. I don't know. 
I'm not sure. But there were other watches. I don't remember 
specifically exactly what watches. 
Q: Where are the three pictures now? 
A: I have no idea. 
Q: To your knowledge were they confiscated by the police? 
A: I would assume so. They were left in the Bronco. 
Q: You took them with you? 
A: NO. They were left in the Bronco. 
Q: You took them when you went into A.C.'s Bronco. Is that right? 
A: They were in my bag, yes, so they went with me. 
Q: And that's the last you saw of those pictures: When they were in 
A.C.'s Bronco? 
A: Yes. 
Q: Never seen them again? 
A: I don't recall. I don't recall seeing them again, no. 
Q: Have you asked for them back? 
A: I asked for everything back. 
Q: Have you ever gotten those back? 
A: I don't think -- other than my passport and this ring (Indicating), I 
don't think I've gotten anything else back. 
Q: At the Kardashian house, the bedroom where you slept and the closet 
where the bag was were the same room. Right? 
A: Yes. 
Q: And was that room located downstairs or upstairs? 
A: Upstairs. 
Q: Upstairs. 
A: Yes. 
Q: And where you had the examination by the doctors was also upstairs. 
Right? 
A: I believe so, yes. 
Q: Okay. When you went to Kardashian's house from Rockingham sometime 
on the 14th,what was your purpose in doing so? 
A: To get away from the press and to see my kids. 
Q: And how long were you planning to stay? 
A: When I went there originally, I had no plans. 
Q: You weren't planning to stay there indefinitely. Right? 
A: That's what I meant: I had no plans, so that's why I didn't bring a 
whole lot of stuff. 
Q: You were planning to stay for a couple days and then come back. 
Right? 
A: Yeah. Yeah. 
Q: In light of that, why did you go and make a point of getting the 
money and bringing all that money under the sweater with you? 
A: I don't understand why "all that money." I carry my money with me 
all the time normally. 
Q: But this money was tucked away under a sweater for a rainy day. 
Right? 
A: No. 
Q: Why was it under a sweater? 
A: Because I didn't want to leave it on the table. 
Q: How long had that money been there? 
A: Since I came back from New York where I won most of it -- or a lot of 
Q: Oh, the cash that was in the sweater was largely winnings from golf? 
A: Not largely -- oh, yeah, yes. Overall, yes, largely winnings from 
golf. Not necessarily over those three days, but probably over a week's 
period of time, yes. 
Q: With friends? 
A: Yes. 
Q: Guys who play golf regularly? 
A: Yes. 
Q: ANd again, what was your reason for taking the money to 
Kardashian's? 
A: Same reason I have for taking money wherever I go. 
Q: Well, you didn't take the money to Chicago. 
A: I took $3500 to Chicago. 
Q: Right. So why did you go and get another 6500 and take it with you 
to go to Kardashian's house? 
A: Because it was there, and I put it in my bag, and I didn't know how 
long I'd be at Kardashian's. 
Q: Did you use any of the money at Kardashian's? 
MR. BAKER: Other than what he has previously testified to: Giving it to 
Al Cowlings? 
BY MR. PETROCELLI: 
Q: Wel1, let me ask you about that. Other than giving it to Al 
Cowlings, did the money go anywhere else? 
A: No. 
Q: Now, did Mr. Cowlings ever give it back to you? 
A: No. 
Q: What happened to it? 
A: I'm assuming that he gave it to my kids. 
Q: Have you ever found that out? 
A: I'm sure he told me he did, yes. 
Q: DId he give any of it to Paula? 
A: Yes. 
Q: How much? 
A: Whatever it took for her to get her a first class ticket out of L A. 
Q: Did he tel1 you that he did that? 
A: I think Paula may have said that. 
Q: Did you see him do it? 
A: No. 
Q: And to your knowledge he gave the rest of the cash plus those checks 
to your kids. 
A: My kids and -- yeah, wel1, that's who I told him to dispense it among, 
so I'm assuming he did. 
Q: And by "kids,' you mean -- 
A: My older two kids. 
Q:Arnel1e and Jason? 
A: Yes. 
Q: DId you give him instructions to give any of that money or checks to 
anyone else? 
A: No. 
Q: DId you make any arrangements at all during that week at 
Kardashian's house, including all day Friday, to acquire any other 
cash? 
A: No. 
Q: Or to have anybody get any other cash? 
A: No. 
Q: So the only cash that you had any interest in getting or keeping was 
that money in the sweater and the money you had on your person. Right? 
MR. BAKER: I object. That's argumentative. 
MR. PETROCELLI: Okay, I'll withdraw it. 
Q: The only cash that you had with you that entire week was the money 
from the sweater and the money you had in your person. Right? 
A: Yes. 
Q: And you didn't ask anybody to get any other cash from anyplace else 
that whole week. Is that right? 
A: That's correct. 
Q: And did anybody get any cash from any other sources? 
A: Not to me, no. Not to me, no. 
Q: Did anybody get any cash that belonged to you from any other 
sources? 
A: I don't know. I don't know. 
Q: Do you have any information that anybody got money that belonged to 
you from some other location? 
A: No 
Q: You have no such information. Is that correct? 
A: That's correct. 
Q: When you -- Is it fair to say that you made the decision to go to the 
cemetery and not wait for the police shortly before you left in the 
Bronco with Mr. Cowlings? 
A: Yes. 
Q: In other words, did you make the decision earlier in the day and 
decide that with Cowlings, or did you make it later in the day? How did 
that work? 
A: Just the way you asked it. the way I answered it, is how it 
happened: Shortly before left, I made the decision. 
Q: When you made that decision with Cowlings, where were you? 
A: I think in the kitchen. 
Q: And where is the kitchen: Upstairs or downstairs? 
A: Downstairs. 
Q: So what you had to do then before leaving was go upstairs and 
retrieve the bag. Is that right? 
A: That's correct. 
Q: Okay. And when you did so, you saw other people in the house. Right? 
A: I don't think so. 
Q: And you didn't -- you've said already you didn't tell anybody that you 
were leaving. Right? 
A: Right. 
MR. BAKER: You don't have to answer it again. 
BY MR. PETROCELLI: 
Q: Did you tell anybody that you were going to your bedroom to get your 
bag? 
A: No. 
Q: Did anybody see you go to the bedroom? 
A: I don't think so. 
Q: Did anybody see you leave the bedroom with your bag? 
A: I don't think so. 
Q: Where was everyone else? 
A: I don't know. 
Q: When you went into the bedroom, did you get anything else besides 
the bag? 
A: No. 
Q: Did you put anything into the before you left? 
A: I'm not sure. If I'd taken one of the pictures out, I may have put 
it in the bag. Q; Wasn't your passport on the side table? 
A: No. 
Q: You're positive of that? 
A: Yeah. l read everything you read The answer is no. 
Q: Did you read any statement by. Miss Barbieri -- 
A: Yes. 
Q: -- that the passport was on the table? 
A: Yes. 
Q: And she's incorrect? 
A: Yes. 
Q: Have you discussed that with her? 
A: No. 
Q: WheN you said you've read everything I've read, what have you read, 
Mr. Simpson? 
A: I've read most of the discovery in this case. 
Q: WhaT do you mean by a discovery? 
A: I don't know. You tell me. Whatever discovery is. 
Q: You've read a number of witness statements? 
A: Yes. 
Q: You've read the trial transcript? 
A: No. 
Q: Any part of it? 
A: No. 
Q: Have you read any of the transcripts of the preliminary hearing? 
A: Transcripts, no. 
Q: Have you read any of the transcripts of the Grand Jury proceeding 
A: Yes. 
Q:  --  in your matter? 
A: Yes. 
Q: And in Mr. Cowlings' matter? 
A: Only in Mr. Cowlings' matter. don't think it was my matter. 
Q: WheRe are these documents that you read? 
A: I don't know. 
Q: When you read them, where were they? 
A: In jail. 
Q: Did you read any of these documents after you got out of jail? 
A: No. 
Q: Did you read any of them in preparation for this deposition? 
A: No. 
Q: Earlier you described that -- you wouldn't answer questions about 
certain tape recordings and video recordings, if there were any, in the 
presence of your lawyers or under the direction of your lawyers. 
MR. BAKER: Don't answer. 
MR. PETROCELLI: That's a foundational statement. 
MR. BAKER: Well, it's a preamble that is absolutely vacuous of any 
importance. 
MR. PETROCELLI: Yes. Well, the importance will now appear. 
Q: Who are those lawyers? 
MR. BAKER: Well, you don't have to respond who your lawyers. His 
lawyers are of record in this case. 
BY MR. PETROCELLI: 
Q: Who were all of the lawyers of record in your criminal case? 
A: That I know? Johnnie Cochran, Bob Shapiro, Mr. Bailey, Mr. Blaiser, 
Mr. Scheck, Mr. Neufeld, Mr. Oleman, Mr. Douglas, Miss Chapman. For a 
while Sarah -- I can't think of her last name. Then there was another 
person with Shapiro, and I don't remember her name, and then there's 
other people that came in and went, and I don't remember their names. 
Oh, Mr. Dershowitz. I'm sorry. 
Q: Have you left anybody out? 
A: I'm sure I have, but. . . 
Q: Have you consulted with any of those lawyers in preparation for this 
deposition? 
MR. BAKER: Instruct him not to answer on the attorney-client privilege. 
BY MR. PETROCELLI: 
Q: Have you reviewed any documents in connection with this deposition, 
to prepare for it, I should say, in the last three weeks? 
A: Yes. 
Q: What did you review? 
A: My divorce and I believe my divorce deposition. 
Q: Anything  --  you said your divorce deposition. Anything else? 
A: Probably Nicole's divorce deposition. 
Q: Anything else? 
A: I believe -- I didn't read it all -- the police  --  the thing with the 
police. 
Q: What thing? 
MR. BAKER: Your statement? 
THE WITNESS: Yes. 
MR. BAKER: The recorded statement? 
THE WITNESS: The recorded statement, 
that portion of it, yes. 
BY MR. PETROCELLI: 
Q: The statement to Vannatter and Lange? 
A: Yes. 
Q: Is that what you meant by "recorded statement?" 
A: Yes. 
Q: Now, your lawyer put the word "recorded" there. Is there some other 
statement that was made that was not recorded? 
A: A lot, yes. 
Q: What are those statements? 
A: Whatever the police were asking me that day. 
Q: You mean there's a portion of the statement that's not recorded that 
you gave to the police? 
A: Yes. Yes, quite a bit, as a matter of fact. 
MR. BAKER: What I'm talking about is the conversations that he had with 
the police other -- 
MR. PETROCELLI: I know what you're talking about. He's talking about 
something differently, though 
MR. BAKER: No, he is not. 
MR. PETROCELLI: Let him testify. Okay? 
MR. BAKER: I think I've really let him testify. 
MR. PETROCELLI: I'm not complaining so far, except for a couple of 
parts, Mr. Baker. 
MR. BAKER: I'm euphoric. 
MR. PETROCELLI: I know you are. 
Q: Anyway, during this taping -- during this statement that you gave to 
Detectives Vannatter and Lange, did you make statements to them during 
this interview that were not recorded in the written transcript that 
you saw later? 
A: I answered whatever they asked, and there were some things that they 
asked there that they didn't ask -- 
Q: That they didn't what? 
A: I answered whatever they asked, and there are obviously some things 
they never asked, from what I can see in the recorded statement. 
Q: What I am asking you is: Was there anything that the recorded 
statement failed to reflect that you believe was said to them? 
A: I don't understand that I'm sorry. 
Q: Did the recorded statement pick up everything that was said between 
you and Detectives Vannatter and Lange? 
A: During the time that they recorded it? 
Q: During the time they talked to you in the room when they recorded 
it, yes. 
A: During the time the recording was on, it appears to me that, from 
what I can recall. it recorded everything that we talked about while 
the recording was on. 
Q: Now, was there a part of the discussion you had with them during 
that time that was not when the tape recording was on? 
A: What do you mean? In the middle of the tape? 
Q: Or the beginning or end of it. 
A: Quite a bit. 
Q: Quite a bit? 
A: Yes. 
Q: Have you ever seen any documents or tapes or any other materials 
reflecting what you said and what they said during those portions of 
the discussion? 
A: No. 
Q: You testified just a few moments ago that shortly before leaving in 
the Bronco with Mr. Cowlings, you went upstairs and got the bag, and 
then when you got that bag, did you then immediately go downstairs and 
to the car? 
A: Yes. 
Q: Did you stop to talk to anybody? 
A: No. 
Q: Okay. Had you already by this point in time given the money to Mr. 
Cowlings? 
A: Oh, yes, l had given it to him much earlier than this. 
Q: How much earlier? 
A: I don't know. Shortly after I was told that I was being arrested, 
and I think Mr. Shapiro told me I can only have so much money or 
something to take, you know, downtown. 
Q: So earlier that day -- in the morning, I should say, you gave the 
money 
A: Whenever he showed up, yes. 
Q: Whenever who showed up? 
A: A.C. 
Q: And that's when you told -- gave him the instructions to give it to 
the children. Correct? 
A: Yes. 
Q: The two older children. 
A: Yes. 
Q: Did you and Mr. Cowlings discuss what you would do after visiting 
the cemetery? 
A: No. 
Q: Did you have any plan at that time? 
A: No. 
Q: You didn't know where you were going to go after the cemetery? 
A: I never even thought about it. I just wanted to get to Nicole's 
grave, yes. 
Q: Have you been to Nicole's grave since you got out of jail? 
MR. BAKER: Don't answer that. That's irrelevant and immaterial. I'm not 
going to let him get into that. 
BY MR. PETROCELLI: 
Q: How many times have you been to Nicole's grave? 
MR. BAKER: Don't answer that either. 
MR. PETROCELLI: What's the objection? 
MR. BAKER: Well, we're talking about obviously after he got out, and 
that has been a media circus, and I am not going to put OJ. through 
that without a court order. 
MR. PETROCELLI: I am not sure I understand what you're saying, Mr. 
Baker. 
MR. BAKER: He has attempted to visit the grave site and has been 
besieged, beleaguered by media people, and we're not -- 
MR. PETROCELLI: Let him testify to that. I didn't know that. 
MR. BAKER: We are not going through it again. I don't see any relevance 
to whether or not Mr. Simpson has anything to do with the unfortunate 
deaths of Nicole Simpson Brown or Ron Goldman. 
MR. PETROCELLI: It's relevant to the question of his motive to kill 
them. 
MR. BAKER: Well, that's about as farfetched as I can imagine, but -- 
BY MR. PETROCELLI: 
Q: Let me say, since you got out of jail, have you attempted to visit 
the --  
MR. BAKER: I'm not going to let him answer that either. 
BY MR. PETROCELLI: 
Q: -- grave site of Nicole? 
MR. BAKER: It's irrelevant and immaterial to any issue in this case. 
I'm not going to let him answer that. 
MR. PETROCELLI: Do you instruct him not to answer? 
MR. BAKER: I do. 
MR. PETROCELLI: Just so the record is clear, when you say, "I'm not 
going to let him answer," is that the equivalent to an instruction not 
to answer? 
MR. BAKER: Yes. I'll agree to that. 
BY MR. PETROCELLI: 
Q: Now, when you got to the grave site, were you still --  or near or 
outside the entrance to the cemetery, I should say, were you still 
sitting in the passenger side of the car? 
A: Yes. 
Q: At some point did you get out of the passenger side and go into the 
back seat? 
A: Yes. 
Q: When did that occur? After we couldn't get in, we went and parked 
somewhere and we were waiting, and A.C. I think got out of the car, and 
I got in the back and laid down. 
Q: Now, where did you park? 
A: In an orange grove. 
Q: Near the cemetery? 
A: Yes. 
Q: How long were you parked there? 
A: I have no idea. 
Q: Do you have any sense if it was a 
A: No. 
Q: -- short time? Long time? 
A: No. 
Q: More than an hour? 
A: I have no idea. 
Q: When you parked there, did you sit in the passenger side, or did you 
go immediately to the back floor? 
A: I didn't go immediately. I did not go immediately to the back 
portion of the car. 
Q: Where did you go to the back portion? 
A: Sorry? 
Q: Where in the back did you go? 
A: Just in the back of the Bronco. He had the seats where there was no 
back seats, and there was an area that I just laid down back there. 
Q: Was the purpose of laying down so that no one could see you? 
A: No. Because they couldn't see us where we were parked. l just laid 
down because I was tired. 
Q: Did you and he have a talk in the Bronco while you were parked? 
A: I can't say it was a conversation. We turned on the radio then and 
realized what was going on. 
Q: What did you hear on the radio? 
A: That they were hunting for me. 
Q: And then did you at that time make a decision what to do? 
A: No. 
Q: So you did not immediately upon hearing that they were hunting for 
you decide to go back to Rockingham. Right? 
A: Exactly. 
Q: By hunting for you, you mean the police were looking for you. Right? 
A: Yes. 
Q: And you did not decide at that time to go back to the police -- to go 
to the police station Right? 
A: Right. 
Q: What did you and A.C. discuss you would do? 
A: Nothing. We were waiting, and hopefully the police would leave the 
entrance, and then I could go to the grave site. 
Q: Could you see the police at the entrance from your vantage point? 
A: Oh, no. No. No. 
Q: Did you make a few trips to the entrance in the car? 
A: No. 
Q: so you were just going to wait for a while and then go? 
A: Yes. 
Q: Is that what you did? 
A: We waked for a while. Then we began to come home. 
Q: After you waited for a while, did you then go once more to check out 
the entrance? 
A: I don't believe so. I think A.C. said he was taking me home. 
Q: And you then got in the back of the car -- or you were there already. 
A: Yes. 
Q: And he gets in and drives home. Is that right? 
A: Yes. 
Q: Where did he go when he left the Bronco? You said he got out? 
A: I guess he went and took a leak, something. Who knows. 
Q: Just gone for a short time? 
A: Yes. 
Q: Did you say good-bye to him when he left? 
A: No. 
Q: Were you planning to kill yourself in the back of the car? 
A: I don't know what I was doing. I was  --  I don't know what I was 
thinking. 
Q: At any time when you were in the passenger seat of the front of the 
Bronco, did you ever have your gun out of the bag? 
A: No. 
Q: And when you were in the back of the car, did you have your gun out? 
A: Yes. 
Q: And the gun was in the black bag which was in the back of the car. 
Right? 
A: Yes. 
Q: And what did you -- when did you first take out the gun? 
A: I don't know. 
Q: Now, the gun was in a case, right that violin-like case that you 
described earlier? 
A: I don't remember if it was still in that. I don't recall if it was 
still in that. 
Q: Did you not take the case with you? 
A: I don't recall if I took the case. 
Q: What happened to the case? 
A: I don't know. 
Q: Did you leave the case at Mr. Cowlings' -- I mean at Mr. Kardashian's 
house? 
A: No. 
Q: Did you even take the case to Mr. Kardashian's house? 
A: I don't really know. 
Q: When is the last time you've seen this case? 
A: When --  for sure, when I was looking at it after it was taken out of 
my car, which would have been Monday night. 
Q: On the 13th. 
A: Yes. 
Q: So to your knowledge it's not at your house now. Right? 
A: To my knowledge, it's not. 
Q: When Mr. Cowlings said he was taking you back, where did you and he 
discuss you would be taken to? 
A: We didn't have a discussion. He was talking to me to try to keep my 
attention on him, I think, and he got on the telephone immediately, and 
I think he called the police and called my home. 
Q: And then did he tell you where he was taking you? 
A: Home. 
Q: "Home" meaning Rockingham. Right? 
A: Yes. 
Q: Did you ask him to take you someplace else? 
A: Not in so many words, no. 
Q: Did you tell him you didn't want to go back to Rockingham. 
A: No. 
Q: Did you tell him you wanted to stay longer and wait to see Nicole? 
A: No. 
Q: Do you remember anything you said to him? 
A: "Take me to my mother." 
Q: Take you to your mother. 
A: Yeah. 
Q: Where was your mother living at that time? 
A: Living? 
Q: Where was she staying? 
A: I assumed she was at my house. 
Q: At Rockingham. 
A: Yes. 
Q: I see. So you wanted Mr. Cowlings to take you to see your mother at 
Rockingham. 
A: Yes, basically. 
Q: Why did you want to see your mother at that time? 
A: Because she's my mother. 
Q: You wanted support from her? 
A: I wanted to be with my mom. 
Q: At what point in this ride back -- well, let me ask you this: Once he 
turned on the car to drive back to Rockingham, did you go straight to 
Rockingham without any stops? 
A: Yes. 
Q: Do you remember the route that was taken? 
A: No. a And this whole route, you were in the back of the car. Right? 
A: Yes. 
Q: And you were lying down. Right? 
A: Yes. 
Q: You were also were also on the telephone? 
A: I don't recall. 
Q: Did Mr. Cowlings have a cell phone? 
A: Yes. 
Q: Was it mounted to the car, or was it a freestanding cell phone? 
A: I don't know. 
Q: Did you have a cell phone? 
A: Yes. 
Q: Where did that cell phone come from? 
MR. BAKER: I don't know what you mean, where did it come from. 
BY MR. PETROCELLI: 
Q: You said you brought the black bag, and you didn't indicate that you 
brought anything else, and you haven't so far said that the cell phone 
was in the black bag. 
A: More than likely it was in the black bag. 
Q: Was it? 
A: If it was in the Bronco, and I'm sure the police have it, and I had 
it obviously it must have been in the black bag. 
Q: Okay. Well, let me ask you some questions about the cell phone. How 
many cell phones did you have? 
A: One that I know of. I've had others, but they get ripped off. So 
one. One that I can think of. 
Q: What was the phone number of that cell phone? 
A: I don't recall. 
Q: Is this a cell phone that you could use in the Bronco? 
A: Yes. 
Q: By putting it onto a mounted stand? 
A: Yes. 
Q: And when it was on the stand, it would also charge? 
A: I guess so. 
Q: But you could take it off the stand and use it without any cords. 
Right?. 
A: Yes. 
Q: When you took it off the stand to use, did you have to put a battery 
pack on it? 
A: No. 
Q: So you just take it right off and use it. Right? 
A: Yes. 
Q: Did it have a battery pack that came with it? 
A: Yes. 
Q: And it was attached to the back of it? 
A: Yes. 
Q: You could also put that same cell phone into a bracketed stand in 
the Bentley? 
A: Yes. 
Q: So you didn't have two cell phones, but one for both cars. Right? 
A: Yes. 
Q: Did you take that cell phone with you to Chicago? 
A: Yes. 
Q: And again, it had its battery pack. Right? 
A: Yes. 
Q: Was there more than one battery pack? 
A: Yes. 
Q: Did you have two battery packs in your black bag: One on the phone 
and a spare one in the bag? 
A: I believe so. 
Q: Did you -- 
MR. BAKER: Do you mean  --  at what point are we talking about? Are we 
talking about Chicago? 
MR. PETROCELLI: On the trip to Chicago. 
MR. BAKER: Okay. 
THE WITNESS: Yes. 
BY MR. PETROCELLI: 
Q: Did you have a battery charger also to charge the battery packs? 
A: I don't -- 
MR. BAKER: You mean with him -- 
MR. PETROCELLI: Yes. 
MR. BAKER: -- on the trip to Chicago? 
MR. PETROCELLI: No. I'm sorry. I'm talking about the trip to Chicago 
and the black bag. 
THE WITNESS: No. I don't believe so, no. 
BY MR. PETROCELLI: 
Q: WHEN you arrived back from Chicago on the morning of the 13th, you 
had your cell phone in the black bag. Right? 
A: Yes. 
Q: Were you still able to use it? In other words, did the batteries 
still have any charge left in them? 
A: I'm not sure. 
Q: You don't remember? 
A: No, because I had been trying to make a lot of calls. 
Q: Do you remember having to switch battery packs during the trip 
A: No. 
Q: -- to Chicago and back from Chicago? 
A: No. 
Q: And did you use your cell phone during the day of the 13th? 
MR. BAKER: After he got back from Chicago? 
MR. PETROCELLI: Yes. 
THE WITNESS: I don't think so. 
BY MR. PETROCELLI: 
Q: So when you got back to Rockingham and let's say before you went to 
the police station, the phone is in the black bag together with the 
spare battery charger. Is that right? 
A: I believe so. 
Q: And did you use it at all the rest of the week up to the Friday, the 
17th? 
A: I might have, but I don't know. 
Q: Did you use it at all at Kardashian's house? 
A: I don't think so. 
Q: Okay. Do you know for a fact that the cell phone was in the black 
bag when you went up to the second floor to get the black bag before 
you left in the Bronco on the 17th? 124] 
A: If I had it with me in the Bronco, which I did, so it must have 
still been in my black bag. 
Q: Did you use the phone going down to the cemetery? 
A: Yes. 
Q: And you used it on the way back, too. Is that right? 
A: I might have. Yeah. 
Q: Then is the first time that you took the gun out with the bullets in 
it and put it to your head? 
A: And put it to my head? 
MR. BAKER: Assuming he ever -- 
BY MR. PETROCELLI: 
Q: Let me ask you that question. Did you ever do so? Did you ever take 
the gun out of the black bag and put it  -- and hold it to your head? 
A: I took it out, and I was laying, so I don't think I physically held 
it to my head, but I certainly had it out, yes. 
Q: What was your purpose in taking the gun out of the bag and putting 
it in your hand? 
A: Using it. 
Q: To kill yourself? 
A: Yes. 
Q: Did you ever cock the gun? 
A: No 
Q: In order to fire that weapon, do you have to first trigger a safety 
device? 
A: I've never fired it, so I don't know. 
Q: Did Mr. Cowlings try to stop you from using it? 
A: I think when he saw it is when he started telling me, "I'm taking 
you home," and that's when he just started the car up and started 
heading up the freeway. He was talking to me. 
Q: And how -- 
MR. BREWER: Keep your voice up, please. 
THE WITNESS: Okay. 
BY MR. PETROCELLI: 
Q: Was the gun just -- was the gun encased in anything in the black bag? 
A: I don't recall. 
Q: Was there a green towel? 
A: I don't recall. 
Q: Were you talking about suicide to Mr. Cowlings on the way down to 
the cemetery? 
A: No. 
Q: And when you were parking there -- where did you say you were parked? 
In a grove of some sort? 
A: Yeah. 
Q: Were you talking about suicide then? 
A: No. 
Q: And then when you got in the back and started to head on home, did 
you start talking about suicide with Mr. Cowlings? 
A: No 
Q: So on your own, that is, without bringing the subject up with Mr. 
Cowlings, you just reached in and took out the gun and contemplated 
killing yourself. Is that right? 
A: That's correct. 
Q: And how long did you actually keep the gun out? 
A: I have no idea. 
Q: When did you put it -- Did you ever put it back in the bag? 
A: I don't think so. 
Q: Did you ever let go of it? 
A: I don't recall. 
Q: Did you ever relinquish it back to Mr. Cowlings? 
A: No. 
Q: When you left -- 
A: Back to Mr. Cowlings? 
MR. BAKER: Yeah, I don't -- 
MR. PETROCELLI: Not back to him. Excuse me. 
Q: Did you ever give it to Mr. Cowlings? 
A: No. 
Q: When you left the Bronco that evening was when you arrived at 
Rockingham. Is that right? 
A: Pardon me? 
Q: When the Bronco arrived at Rockingham m that evening is when you 
left it? 
A: Yes. 
Q: And did you have the gun with you when you walked out? 
A: When I got out of the Bronco? 
Q: Yes. 
A: No. 
Q: Left it in the car? 
A: Yes. 
Q: In your bag? 
A: I don't think so. 
Q: At that moment, coming back to go home to see your mother, why did 
you want to kill yourself? 
A: Excuse me? 
Q: When you were driving back in the Bronco to go see your mother, why 
did you want to kill yourself? 
A: I don't think I did at that point in time. 
Q: On the way back from the cemetery to Rockingham -- and you testified 
you went to Rockingham because you wanted to go see your mother who was 
there. Is that right? 
A: Yes. 
Q: Why did you take the gun out in m contemplation of using it to kill 
yourself? 
A: I had taken the gun out when I was in the grove and A.C. was not in 
the car. 
Q: Why did you consider killing yourself, given that you had wanted to 
go see your mother? 
MR. BAKER: That's pretty argumentative. You can answer why you wanted 
to. 
THE WITNESS: You're talking two different times, too. 
BY MR. PETROCELLI: 
Q: What are the two different times I'm talking? 
A: My mother hadn't come up when I was contemplating that. When A.C. 
came back to the Bronco and saw me, he started talking to me, and when 
he started talking to me, I told him to take me to my mom, or he said, 
"I'm taking you home." And I said, "Yeah, take me to my mom," and he 
kept talking to me as he drove up the freeway. 
Q: And as he drove up the freeway, though, you still had the gun out. 
Right? 
A: Yes. 
Q: Now, by the way, did you ever put the gun to your head? 
A: I don't recall. 
Q: How close to any part of your body did you put the gun? 
A: It was laying on my chest. 
Q: On your chest. Did you ever point it at yourself? 
A: I don't recall doing that. 
Q: Why did you want to kill yourself during the time when you took the 
gun out? 
A: I was feeling a lot of pain, and I wanted it to stop. 
Q: And what was the cause of that pain? 
A: Losing Nicole. 
MR. BAKER: That assumes he knows, but -- 
MR. PETROCELLI: He said, "Losing Nicole." 
THE WITNESS: Part of it was 
Nicole, and part of it was just, I don't know, everything, losing 
Nicole. I was just feeling depressed, I guess. 
MR. BREWER: Mr. Simpson, I can't hear what you are saying. I am going 
to reask the questions if I can't hear. 
THE WITNESS: Just everything 
that happened that week: Losing Nicole, part of it. Just it was a tough 
week. 
BY MR. PETROCELLI: 
Q: Losing Nicole, and the other part of it m was feeling attacked? 
A: That was part of it, yes. 
Q: Were there any other reasons? 
A: Why I was -- why I thought about it, no. I was on medication. Someone 
told me that that didn't help me at that time, but who knows why 
anybody does this kind of thing. I don't know. 
Q: You have been attacked publicly from time to time in the past before 
this incident. Correct? 
A: Virtually never. 
Q: People have made negative comments about you in the press or in the 
public? 
A: If they have, it's been very, very rarely. 
Q: This is the first time in your life that you experienced an attack 
from the public? 
A: First time I ever lost someone like that, yes. 
Q: Well, l am not talking about the losing Nicole part of it. I am 
talking about the other part of it, which was feeling attacked by I 
think you said certain members of the press. 
A: Yes. 
Q: Are you saying that you never before had felt attacked by certain 
members of the press? 
A: No, not that I felt anything. Someone criticized acting or saying I 
ran through the wrong hole, such immaterial stuff that I never felt 
anything from it, even though I was very sensitive to any criticism. 
Those are things I could work on. This is not something that you work 
on. 
Q: And this attack was, as you're saying, much different. Right? 
A: Yeah, it felt obviously  --  obviously it was much different, yes. 
Q: How was it different? 
A: They were talking about -- implying that I possibly could have taken a 
human being's life. That was different than anything I've ever 
experienced in my life. 
Q: But you believed you were innocent. Right? 
A: I don't believe nothing. I am innocent. 
Q: Then you were confident that you would be acquitted. Right? 
A: I didn't think I'd be arrested until then, and by then I was in so 
much pain for Nicole, I wasn't thinking about the police at that point. 
Those weren't things -- being arrested was not something that was on my 
mind at that time. 
Q: Well, at the time you had that gun out in that Bronco, though, you 
knew you were going to be arrested, and you knew -- 
A: I could care less. 
Q:  --  and you knew the police were hunting for you. 
A: And I could care less about what the police was thinking. It was 
how I was feeling, and that's why that gun was out, is because I felt I 
was in a lot of pain and I couldn't handle it at the time. I didn't 
feel I could handle it at the time. 
Q: Was the pain of losing Nicole so great that you were prepared to 
deprive your children of their parents? 
MR. BAKER: Don't answer that. That is outrageous. 
MR. PETROCELLI: I am trying to understand the witness' -- 
MR. BAKER: I don't care what you're trying to do. That's an outrageous 
argumentative question, and he is not going to answer it. 
MR. PETROCELLI: You instruct him not to answer? 
MR. BAKER: You bet. 
BY MR. PETROCELLI: 
Q: Well, let me ask you this: Before you went in that Bronco, had you 
made arrangements with anyone for the care of your children? 
A: Well, yes. 
Q: What arrangements did you make? 
A: What arrangements. There are certain people that I asked to, you 
know, see if they can help if anything came up with my kids. 
Q: You mean to help in case you killed yourself. Is that what you mean? 
A: That was a possibility, yes. 
Q: I just want to understand what you're saying. When you say "if 
anything came up," I just want to make sure I understand what you're 
saying. 
A: Yes. 
Q: Okay. And who were those people? 
A: Mainly Wayne Hughes and I believe Louis Marx. 
Q: Who is Louis Marx? 
A: A businessman. 
Q: Friend of yours? 
A: Yes. 
Q: And Wayne Hughes? 
A: Businessman who is a friend of mine. 
Q: What arrangements did you make with Mr. Hughes about your children? 
A: Not an arrangement. I just asked him to look after my kids, to make 
sure that -- whatever. If something happened, look after my kids. 
Q: And by the "kids," are you now referring to Justin and Sydney? 
A: Yes, and probably also to an extent my older kids. 
Q: Did you tell Mr. Hughes to financially provide for them. 
A: No. 
Q: Help guide them and give them counsel? 
A: Whatever. Whatever I --  whatever. 
Q: Did you give him any specific instructions? 
A: No. 
Q: What about Mr. Marks? What did you tell him regarding your kids? 
A: Pretty much the same thing. 
Q: And who did you understand would be caring for your children? 
A: At that point I would assume, and I didn't really give it a lot of 
thought, but I would assume Lou and Judy Brown. 
Q: Did you -- 
A: Or Arnelle Simpson and my family. 
Q: Or Jason? 
A: No. More Arnelle and my family. 
Q: Did you have any discussions with the Browns those days that you  -- 
something might happen to you and that they should take care of the 
children? 
A: No. 
Q: Or with any member of Nicole's family? 
A: Other than whatever brief conversation I had with Lou when I first 
got in the Bronco. Other than that, no. 
Q: Are you talking about Mr. Cowlings' Bronco? 
A: Yes. 
Q: On the 17th? 
A: Yes. 
Q: And you called Lou? 
A: Yes. 
Q: Tell me about that discussion. 
A: I don't remember the discussion. You should ask Lou. 
Q: Do you recall it? 
A: I recall that I spoke with him, yes. 
Q: You don't remember what you said? 
A: No. 
Q: Do you know why you called him? 
A: Not really, no. I called Nicole's house, and Lou was there. 
Q: When you called Nicole's house, it was to speak was to speak to Lou. 
Right? 
A: Not really. I didn't know who would be there. If Judy was there. I'd 
speak to Judy, or whoever. I was not that -- well, whoever. 
Q: Did there come a time, Mr. Simpson, when Mr. Cowlings made the 
decision to take you back to Rockingham to see your mother, that you 
decided to put in effect the gun away and you weren't going to use it? 
A: I never thought about it. 
Q: You never made that decision clearly in your mind? 
A: I don't think I did anything rationally that day. 
Q: You were irrational that day? 
A: Well, I think any time you have a gun on your chest, you're being 
irrational, yes. 
Q: Have you ever acted irrationally before in moments of severe 
crisis? 
A: Severe crisis? 
Q: Is it fair to say that you were in a period of severe crisis the 
week of June 13? 
MR. BAKER: Well, I am going to object. That's a characterization and 
instruct him not to answer that question. 
BY MR. PETROCELLI: 
Q: Did you feel that you were in a severe family crisis or personal 
crisis that week? 
MR. BAKER: You can describe what you felt. 
THE WITNESS: I felt pain, 
actually, when I was in the Bronco going to  -- I felt at peace at that 
point in time, the day of the 17th, once I got in the Bronco and was 
going down there, but most of the week I was -- I don't know. I think I 
was obviously a little confused and in pain. 
BY MR. PETROCELLI: 
Q: What made you feel at peace? 
A: I don't know. I just felt at peace. 
Q: When you have experienced severe personal pain in your past before, 
have you acted irrationally? 
A: Yes. 
Q: On when -- on what occasions? 
A: When my father died. When my baby drowned. 
Q: What did you do irrational on those occasions? 
MR. BAKER: I am not going to let him get into it. I think that's 
totally irrelevant and immaterial. Instruct him not to answer. 
BY MR. PETROCELLI: 
Q: Who else -- Was the first call you made in that Bronco to Lou Brown at 
Bundy? 
A: I believe so. 
Q: Who else did you call? 
A: I don't know. I know Lou --  I mean I know Wayne and I know -- I know 
Louis and Wayne, and other than that, I don't know. 
Q: You had spoken to Louis and --  Marks and Wayne Hughes from the Bronco? 
A: I believe so. 
Q: You had also spoken to them earlier in the week. Right? 
A: I don't know. I don't recall. 
Q: Did you call anybody else besides Mr. Marks, Mr. Hughes and Lou 
Brown? 
A: I may have, but I really don't recall. 
Q: If you felt at peace in that Bronco, why did you want to kill 
yourself? 
A: Because that's why I felt at peace: I thought all my pain was about 
to end. 
Q: You felt that peace in contemplation of dying? 
A: I felt at peace that I was going to stop feeling the way I was 
feeling. 
Q: Is it fair to say that virtually all of the pain you were feeling 
came from the loss of Nicole? 
A: Obviously it was the -- yeah, the genesis of it all, but I would say 
the  -- yes, I would say that had a lot to do with it, yes. Yes. 
MR. PETROCELLI: Let me attach as the next exhibit in order, which would 
be Plaintiffs' 6 -- 
MR. LEONARD: Are you passing out copies? 
MR. PETROCELLI: Yeah. 
MR. LEONARD: That's what I need. 
MR. PETROCELLI: Do you want to mark this as 6. (Plaintiffs' Exhibit 6 
was marked for identification by the reporter and is attached hereto.) 
BY MR. PETROCELLI: 
Q: Mr. Simpson, before I show you this document, whatever happened to 
the amendment to the will that you wrote? 
A: I don't know. 
Q: Have you ever seen that again? 
A: No 
MR. KELLY: I'm sorry. What has this been stamped? Exhibit  --  
MR. PETROCELLI: 6. 
MR. KELLY: 6. 
BY MR. PETROCELLI: 
Q: Did you discuss with Mr. Cowlings during this Bronco ride the 
question of who killed Nicole? 
A: No, I don't think we had any discussion of it, no. 
Q: Did Mr. Cowlings ever ask you whether you did? 
A: I think I told him I didn't, and I don't think he ever questioned me 
about it after that. 
Q: He initially asked you, and you said you didn't? 
A: I don't think he ever asked me. I think I may have just said it to 
him early in the week, and I don't think he ever asked me about it 
after that. 
Q: Did you speak to Mr. Cowlings at all in preparation for this 
deposition? 
A: Not at all. 
Q: You still see him on a regular basis? 
MR. BAKER: I don't know what "regular basis" is. 
BY MR. PETROCELLI: 
Q: Frequently? 
A: I saw him -- as an example, I ran into him on Montana Street three 
days ago, and then I had seen him maybe 10 days previous to that and 
then maybe a week previous to that. So if that's frequent 
Q: Are you still close friends? 
A: Oh, yes. Oh, yes. Even before this happened, I played golf and he 
didn't, so we really didn't see each other that much, but we talked 
from time to time, but he's still my best friend. 
Q: Okay. I have placed before you a document marked as Exhibit 6. Do 
you recognize this? 
A: Yes. 
Q: What is this? Can you identify it? 
A: It's a letter I wrote that day, I guess. 
Q: It's a letter you referred to earlier when you said you wrote down 
your thoughts? 
A: Yes. 
Q: Is this letter entirely in your handwriting? 
A: Yes, I believe so. 
Q: Is the date of the letter in your handwriting? 
A: Yes. 
Q: And all the characters? 
A: Yes. 
Q: Are all of the cross-outs in your handwriting? 
A: Probably, yes. 
Q: For example. look at the next to last page. 
A: Yes. 
Q: Are the cross-outs at the bottom of the bottom of the page in your 
handwriting? Let me ask: Did you cross out the material  --  
A: Pretty sure. 
Q:  -- at the bottom of the second to the last page? 
A: Probably. 
Q: Any doubt in your mind? 
A: I know I was in a hurry and there were a lot of things that I 
spelled poorly, that didn't come out quite the way I wanted to say it, 
and I just resaid it. 
Q: Do you know what you wrote here at the bottom that you crossed out 
A: No. 
Q:  -- on the third page? 
A: No. 
Q: Have you ever tried to translate that for someone? 
A: This is the first time I've looked at this since then. 
Q: You didn't look at it throughout your criminal trial? 
A: No. 
Q: Now, it's dated 6-15, which is Wednesday, but you've testified you 
wrote this on Friday. Is that right? 
A: Yes. 
Q: Why did you date it on the 15th? 
A: I guess I was just guessing at the date, and I was alone and I 
didn't ask anybody what the date is. 
Q: Is it clear in your mind that you wrote this entire note on the 
17th, that Friday? 
A: Yes. 
Q: And how long before you made the decision -- Let me ask you this: Did 
you write this note after you made the decision to leave with Mr. 
Cowlings? 
A: No. No. But I did -- no. 
Q: When you made the decision to write this note, were you still 
planning to turn yourself in? 
A: I don't know. I don't really think so. 
Q: Did you have any idea -- With drawn. When you wrote this note, you 
were expressing thoughts consistent with the idea that you would kill 
yourself. Right? 
A: Yeah. Yeah. 
Q: And when you wrote this note, Exhibit 6, did you have any sense of 
how you would do that? 
A: I must have, but I can't give you any conscious thought, but I must 
have, yes. 
Q: Did you have a sense of when you would do so? 
A: Yes. 
Q: When was that? 
A: Before I left Bob's house. 
Q: Before the police came. Right? 
A: Yes. 
Q: When you awakened that morning did you --  Withdrawn. When was the 
first time you were told that you would be arrested? 
A: Early that morning. 
Q: On the 17th? 
A: Uh-huh. 
Q: Who told -- You have to answer yes. 
A: Yes. I'm sorry. 
Q: And who told you? 
A: Bob Shapiro and Bob Kardashian. 
Q: Do you remember what time it was? 
A: No. 
Q: Where were you when they told you? 
A: I was in bed. 
Q: They got you out of bed? 
A: Yes. 
Q: When you got out of bed, do you remember what you did next? 
A: No. No. 
Q: Take a shower? 
A: I'm sure I did. 
Q: Got dressed? 
A: I'm sure I did. 
Q: Did you eat breakfast? 
A: I don't know. 
Q: Did you write this letter before or after the doctors examined you 
and took the photographs? 
A: I could have been writing parts of it during the time they were 
doing that. 
Q: I see. Now, this morning Miss Barbieri was present with you. Right? 
A: Part of --  well, she was in the house, yes. 
Q: You wrote this letter before she left. Right? 
A: Yes. 
Q: And when she left, you had no idea whether you would ever see her 
again. Right? 
A: Yes. 
Q: Did you and she discuss that, that this might be the last time? 
A: No. 
Q: Did you and she said good-bye? 
A: I told her to go to Florida and find some nice guy. 
Q: And was that a tearful parting? 
A: The whole week was tearful for me, and I think -- yes, I think she got 
pretty emotional at that time. 
Q: You wanted her to go back to Panama City? 
A: Yes. 
Q: And that's why you -- Did you give Miss Barbieri the money yourself, 
or did Mr. Cowlings give it to him -- her? 
A: No. A.C. 
Q: How did A.C. get the money? 
MR. BAKER: I think we've been over that at least three times. 
BY MR. PETROCELLI: 
Q: You said -- 
MR. BAKER: Don't answer that. 
BY MR. PETROCELLI: 
Q: Here is what I am asking you: You said that the money was in the 
black bag which is in the closet. Now, Miss Barbieri left before you 
left the house. Correct. 
A: Yes. 
Q: How did Mr. Cowlings get the cash to give to Miss Barbieri? 
A: I gave it to him. 
Q: So you went to the bag, took out some money, counted out a sum of 
money and gave it to Al? 
A: No. 
Q: Explain what you did. 
A: I went to the bag, took everything that was in there that looked 
like it was money and gave it to Al. 
Q: At that point. 
A: At that point. 
Q: And Paula was still there. Right? 
A: She was in the house, I'm sure. 
Q: How long before she left did you do that? 
A: I don't know. 
Q: Do you know what the two words that are crossed out after the word 
"understand" on the first and second line? 
MR. BAKER: What page are we on? 
MR. PETROCELLI: I am sorry. Page 1, "First everyone understand," and 
then there are two cross-outs. 
Q: Do you know what those words are? 
A: I don't think they're words. They're probably just -- 
MR. BAKER: Looks like this has been cropped a little, too. 
THE WITNESS: Yeah, I can't tell, but they don't look like they're words to me. 
BY MR. PETROCELLI: 
Q: You addressed this "To whom it may concern." 
A: Yeah. 
Q: WhO did you have in mind by addressing the letter that way? 
A: To whom it may concern. 
Q: Did you intend that this be read to the public? 
A: No, but I wasn't going to write individual letters to everyone who's 
named in here, so I thought to whom it may concern. 
Q: Did you tell anybody to read this 
A: No.  -- to the public? 
A: No, totally not. 
Q: There is a reference in this letter about the Goldman family. 
A: Uh-huh. 
Q: If I could find it. 
MR. BAKER: Bottom of page -- 
MR. PETROCELLI: 3. 
MR. BAKER: -- 3. 
BY MR. PETROCELLI: 
Q: It says, I'm sorry for the Goldman family. I know how much it 
hurts." Do you see that? 
A: Yes. 
Q: You --  Did you ever meet Ron Goldman? 
A: Not that I know of. 
Q: Did you ever talk to Ron Goldman? 
A: Not that I know of. 
Q: Did you ever see Ron Goldman? 
A: Not that I know of. 
Q: Did you ever hear Ron Goldman's name mentioned prior to his death? 
A: No, not that I know of. 
Q: Did the name Ron Goldman mean anything to you prior to his death? 
A: No. 
Q: Did you ever -- did anyone ever point him out to you? 
A: No. 
Q: Did anyone ever point out a person whom was not identified to you by 
name but who you later discovered was Ron Goldman? 
Q: Not that I have any knowledge of. 
Q: You have no knowledge of ever seeing him or hearing of him, whether 
by name or otherwise, before his death. Is that right? 
A: No. That's correct. 
Q: That's correct? 
A: Yes. 
Q: So everything you learned about Ron Goldman was after he died, from 
the news reports. Is that right? 
A: Till this day? 
Q: No. Up till the date you wrote this letter on the 17th of June. 
A: I didn't know anything about him. Yes, that's correct. 
Q: Had anybody  --  prior to Ron Goldman's death, had anybody ever told 
you that he was someone who was seeing Nicole? 
A: No. 
Q: Did you have any knowledge of any kind that he was in a relationship 
with Nicole? 
A: No. 
Q: Did you have any information or knowledge that he was a friend of 
Nicole's? 
A: No. 
Q: Did Nicole ever mention him to you? 
A: No. 
Q: Had you ever been to the Mezzaluna restaurant before June 12, 1994? 
A: Yes. 
Q: Had you ever seen him there? 
A: Not that I would know of. 
Q: So when -- You've seen photos of him since his death. Correct? 
A: Yes. 
Q: At the trial, for example? 
A: Yes. 
Q: When you saw a photo of Ron Goldman, did you -- was there any 
recognition that you had ever seen that person before? 
A: No. 
Q: Since Mr. Goldman's death, has anyone ever told you about any 
relationship between Ron Goldman and Nicole? 
A: No. 
MR. BAKER: Don't -- 
BY MR. PETROCELLI: 
Q: Anyone other than lawyers. 
A: No. No. 
Q: Have lawyers told you that? 
MR. BAKER: Don't answer that. 
BY MR. PETROCELLI: 
Q: Have you read anything to that effect? 
A: I may have. 
Q: What did you read? 
A: I believe in some discovery and possibly in Faye Resnick's book. 
Q: Did you read Faye's book? 
A: Yes. 
Q: Did you read Mr. Kaelin's book? 
A: I don't think Mr. Kaelin had a book. 
Q: Oh, Mr. Elliot's book about -- 
A: No. 
Q: Did you read any of these other books that are out? 
A: No. 
Q: Just Resnick's -- 
A: Yes. 
Q: -- and just Elliot's? 
A: I didn't read Elliot's. 
Q: You didn't read Elliot's, just Resnick's. 
A: Yes. 
Q: What are the discovery materials that you're referring to? 
A: Just interviews from various people. 
Q: What do you remember having read about Mr. Goldman and Nicole? 
A: I think Faye Resnick, that he liked her and she liked him as a 
friend, I believe was how it was described. 
Q: That was from an interview of Faye Resnick? 
A: Yes. 
Q: Other than that interview, whatever it said, do you know anything 
about any relationship between Ron Goldman and Nicole? 
A: No. 
Q: Now, you signed this letter at the end with a happy face on it. Do 
you see that? 
A: Yeah. 
Q: You weren't feeling happy at the time. Right? 
A: No. 
Q: Why did you do that? 
A: I just wanted people to remember me that way. Q. As a happy person? 
A: As I was most of my life until that week and maybe one or two small 
instances in my life, I've been a happy person. 
MR. PETROCELLI: I think we'll break here -- 
MR. BAKER: Okay. 
MR. PETROCELLI: --  and resume  -- Because of the court appearance, we are 
not able to resume this afternoon, Mr. Baker. Is that right? 
MR. BAKER: Yeah, I think that would be best, and we'll start at 9:00, 
if that's agreeable to everybody. 
MR. PETROCELLI: Okay. THE VIDEOGRAPHER: This concludes the deposition 
of Orenthal James Simpson, Volume I. The number of videotapes used was 
two. We are going off the record, and the time is approximately 2:24. 
(Plaintiffs' Exhibits 4 (A-D) and 5 were marked for identification by 
the reporter and are attached hereto.) (ENDING TIME: 2:24 P.M.) I 
DECLARE UNDER THE PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND 
CORRECT. SUBSCRIBED AT CALIFORNIA, THIS DAY OF , 19 . 
ORENTHAL JAMES Simpson <vol 2> 
Q: Good morning, Mr. Simpson. You understand you are still under oath? 
A: Yes, sir. 
Q: Other than talking to your lawyers, did you do anything to prepare 
for today's session of the deposition? 
A: No. 
Q: Did you review any materials? 
A: No. You mean from yesterday till today? 
Q: Yes. 
A: No. 
Q: Let me clarify a couple things we discussed yesterday. When Phil 
Vannatter received your black bag, where did he get it from you? 
MR. BAKER: Are you talking about the 13th of June? 
MR. PETROCELLI: Yes, Mr. Baker. 
THE WITNESS: They had me handcuffed, 
and the bag kept falling off my shoulder, so I guess that's where he 
got it. 
BY MR. PETROCELLI: 
Q: We are now talking about June 13. Correct? 
A: Yes. 
Q: Did you drive down to the police station? 
A: Yes. 
Q: With whom? 
A: Phillip Vannatter. 
Q: You were handcuffed at your house? 
A: Yes. 
Q: And when you went into his car, I take it, or some LAPD vehicle, you 
took your bag with you? 
A: Yes. 
Q: And the bag was in the back seat with you? 
A: I believe it was in the trunk. 
Q: Trunk? 
A: Yes. 
Q: When you arrived at the police station, did you take the bag out and 
take it up with you? 
A: No. 
Q: And later on that evening when you got back to Rockingham, Mr. 
Vannatter delivered the bag back to you? 
A: Correct. 
Q: And so you didn't have the bag in your possession for several hours? 
A: Correct. 
Q: Okay. Why did you take the bag with you down to the police station? 
A: Well, I didn't want to leave it in my driveway. 
Q: You could have left it in your house. 
A: They wouldn't let me in my house. 
Q: Okay. That's the only reason? 
A: Yes. 
Q: When you went to Mr. Kardashian's house I guess it was on the 14th 
of June to stay there for a while, who drove you there? 
A: Mr. Kardashian. 
Q: In whose car did you go? 
A: His. 
Q: Did Mr. Cowlings spend the evenings over at the Kardashian house? 
A: I don't believe so. 
Q: Did anybody else spend the evenings, other than yourself --  
MR. BAKER: I'm sorry. Do you mean by "spend the evenings," did they 
sleep at the house? 
MR. PETROCELLI: Yes. 
THE WITNESS: Which night? 
BY MR. PETROCELLI: 
Q: The night of the 14th, the first night. Other than yourself and Mr. 
Kardashian. 
A: The night --  
Q: Of the 14th. 
A: The night --  
Q: Tuesday. 
A: -- of the 14th, my kids. 
Q: Your kids. Anyone else? 
A: I don't -- not that I know of. 
Q: And the night of the 15th? 
A: Other than people live there, you mean? 
Q: Who lived there? 
A: I guess Denise Halicki and Bob Kardashian, and they may have had 
house help that spend the night. 
Q: Other than those folks, on the 15th did anybody else join you and 
spend the night there? 
A: Paula Barbieri. 
Q: And she slept over there? 
A: Yes. 
Q: And on the 16th? 
A: Paula Barbieri. 
Q: Now, the clothing that you took with you to Mr. Kardashian's house 
in Mr. Kardashian's car was contained in the black bag that we 
discussed yesterday? 
A: Yeah. And I think I might have taken another change. I'm not sure of 
that, but I seem to remember that before we went, that I put some 
clothes in a bag. 
Q: The same black bag? 
A: No. No. 
Q: A different bag? 
A: Yeah. 
Q: So you remember now taking two bags --  
A: I don't remember. It seems to me I don't know if they brought it the 
next day. It just seems to me I brought something to put on the next 
day. 
MR. BAKER: Just wait a second. And I object to the preamble of the 
question, "you remember now," because that's exactly what he testified 
to yesterday. 
BY MR. PETROCELLI: 
Q: How many bags did you take with you to Mr. Kardashian's car en route 
to his house? 
A: My black bag. 
Q: And do you remember any other luggage that you took with you? 
A: No, but I -- I just seem to have a memory that I did bring some 
clothes with me, and I just don't recall if I carried a bag. I don't 
think I carried a bag. I think I just had my black bag, but it just 
seems to me that I carried a change of clothes. 
Q: Were all the clothes that you carried with you to Mr. Kardashian's 
house put in this black bag? 
A: I don't recall. 
Q: You think you might have just set them in the car, you mean? 
A: Yeah, maybe I had a suit bag or something. I just don't recall. 
Q: And do you recall specifically --  Withdrawn. You said yesterday you 
think some other clothes may have been delivered to you while you were 
there. 
A: I know they were. 
Q: And were they delivered in a suitcase? 
A: I don't know. 
Q: Okay. When you went into the Bronco on the 17th, Mr. Cowlings' 
Bronco, you testified yesterday that you took the black bag with you. 
A: Yes. 
Q: Correct? 
A: Yes. 
Q: And do you remember if it had any clothes in it? 
A: If it did, whatever was in there from when I got there Monday: 
Socks, maybe underwear, something. 
Q: And you were taking out some of those socks and underwear during the 
course of the week. Right? 
A: No, I don't recall that. I think they brought me clothes. I think 
from my house they brought me a lot of stuff. 
Q: so whatever socks and underwear were in the black bag when you 
arrived at Kardashian's remained in the bag and were in the bag when 
you took it into the Bronco. Is that right? 
A: Correct. 
Q: Did you take any other clothes with you, other than what might have 
been in the black bag, when you went into Mr. Cowlings' Bronco? 
A: No. 
Q: Did you have him do so? 
A: No. 
Q: Were there any other clothes in the Bronco? 
A: I didn't look around really to see. They weren't mine if they were. 
Q: When we were off the record, we distributed copies of exhibits 4A,-
B, -- C and -- D and 1201 Exhibit 5 that we referred to yesterday on the 
record. I now would like to show you a photograph  -- three photographs, 
which we will mark as the next exhibit in order, which will be 7, and 
we will mark it 7-A, -- B and -- C, and I will show you the original 
photographs that we have, and I will distribute Xerox copies of these 
to counsel. (Plaintiffs' Exhibit 7 (A C) was marked for identification 
by the reporter and is attached hereto.) 
BY MR. PETROCELLI: 
Q: Mr. Simpson, looking at the photos which we've marked as Exhibit 7 
collectively, do you recognize what is depicted in the photos? A. Yes. 
Q: What is it? 
A: A type of cell phone. 
Q: Was this the cell phone that you owned and used in June of 1994? 
A: It could be. 
Q: Do you recognize the telephone number 613-3232? 
A: I believe that was my number. 
Q: And yesterday you -- Withdrawn Is this the cell phone that was in the 
black bag that you took with you to Chicago? 
A: If this is mine, yes. 
Q: Do you have any reason to believe it's not yours? 
A: Well, I know that -- No, I don't. 
Q: Does it look like yours? 
A: The type that I use, yes. 
Q: And does this cell phone appear to be the one that you would have 
mounted in the Bronco or mounted in the Bentley when you drove in the 
car? 
A: Yeah, it was this type of form, yes. 
Q: And you were able to use it outside of the automobiles as well. 
Right? 
A: Yes. 
Q: And you said it had a battery pack that was attached to it when you 
used it outside of the car. Is that correct? 
A: And inside of the car. 
Q: And inside of the car. Do you see the battery pack there, by the 
way? 
A: No. 
Q: Is it clear to you then that neither of the two battery packs that 
you mentioned yesterday appears in these photographs? 
A: True. 
Q: Do you know where those battery packs are? 
A: I would imagine in A.C.'s Bronco. 
Q: Did you remove the battery pack from the cell phone at anytime while 
you were driving in Mr. Cowlings' Bronco? 
A: I removed numerous battery packs from mine, I guess A.C.'s. I think 
the police officers gave us a few of them, yes. 
Q: And you were using additional battery packs on your cell phone? 
A: They kept giving them because the phone kept going dead, and I think 
the police officers were giving us battery packs, too, to get the phone 
alive again. 
Q: Okay. In June of 1994, how many telephones did you have in 
Rockingham? 
A: I don't know. 
Q: How many telephone lines did you have? 
A: One, two. I know I had a rotary phone. 
Q: You had phones in various rooms throughout the house? 
A: Yes. 
Q: Were they all operable? 
A: I would imagine so. 
Q: How did the police, by the way, provide you with battery packs while 
you were in the Bronco? 
A: Through A.C. I'm sure it's all in -- police have that all. I guess A.C. 
was going back and forth, and I was in my driveway and --  
Q: While you were at Rockingham? 
A: Yes. 
Q: Do you have a recollection that you were out in that Bronco about 
eight hours on the 17th of June? 
A: No. 
Q: Can you estimate how long you were out in the Bronco? 
A: No. 
Q: You don't have a clear recollection of those events? 
A: No. Not time-wise, no. 
Q: Did you take any Xanax? 
A: No. 
Q: Have you ever taken Xanax? 
A: No. 
MR. BAKER: You don't have to answer that. You answered that yesterday. 
BY MR. PETROCELLI: 
Q: Are you under any medication today? 
A: Yes. 
Q: Which medication? 
A: Sulfasalazine and Motrin. 
Q: Your blood was taken on June 13. Correct? 
A: Correct. 
Q: From the police? 
A: Yes. 
Q: Have you ever seen a report from the LAPD that showed traces of 
marijuana in your blood? 
A: No. 
Q: Are you aware that there is such a report? 
A: No. 
MR. BAKER: Don't answer that. 
THE WITNESS: No. 
BY MR. PETROCELLI: 
Q: Did you smoke any marijuana on the 12th of June? 
A: No. 
Q: Did you smoke any marijuana on the 11th of June? 
A: No. 
Q: Did you smoke any marijuana one week before June 12th, 1994? 
A: No. 
Q: Did you take any drugs during that week? 
A: No. Other than Sulfa -- well, other than Motrin. 
Q: What medications did you take on June 10, 11 or 12? 
A: Motrin. 
Q: You have a clear memory of that? 
A: I always take Motrin. 
Q: Every day? 
A: Yes. 
Q: How often? 
A: In the morning. Sometimes late in the day if I'm in pain. 
Q: And you were taking Motrin on a regular basis in June of 1994? 
A: Correct. 
Q: Did you take any other kind of drugs or medication on June 12? 
A: No. 
Q: Cocaine? 
A: No. 
Q: Methamphetamine? 
A: No. 
Q: Were you a cocaine user in June of 1994? 
A: No. 
MR. BAKER: Don't answer that. You  --  
THE WITNESS: No. 
BY MR. PETROCELLI: 
Q: The answer is you were not? 
A: No. 
Q: In May of 1994? 
A: No. 
MR. BAKER: That's enough. Don't answer any more questions about that. 
BY MR. PETROCELLI: 
Q: Did you take cocaine at any time in the period January 1994 through 
June 12, 1994? 
A: No. 
MR. BAKER: I am instructing you not to --  
BY MR. PETROCELLI: 
Q: Did you take --  
MR. BAKER: Am I a potted plant? 
BY MR. PETROCELLI: 
Q: Did you take any kind of amphetamines during that period of time? 
A: No. 
Q: Did you take any kind of illegal narcotics at anytime in June -- in 
the period January to June of 1994? 
A: No. 
Q: Did you take any -- did you use cocaine in the year 1993? 
MR. BAKER: Don't answer that. 
THE WITNESS: No. I'm sorry. 
BY MR. PETROCELLI: 
Q: Did you use any kind of illegal narcotics in the year 1993? 
MR. BAKER: Don't answer that. 
BY MR. PETROCELLI: 
Q: You refuse to answer? 
MR. BAKER: Yes, he refuses to answer. 
BY MR. PETROCELLI: 
Q: You said yesterday that you were concerned about possible drug 
and/or alcohol abuse by Nicole Simpson. Do you recall that? 
A: Yes. 
Q: Did you and she participate in using narcotics in 1994? 
A: No. 
Q: Did you see her do so? 
A: No. 
Q: At any time did you see her do so? 
MR. BAKER: Don't answer that, OJ. 
MR. PETROCELLI: I think the answer was no. 
Q: Do you have any information whatsoever that in 1994 Nicole Simpson 
Brown abused or took illegal narcotics? 
A: Yes. 
Q: What is that information? 
A: She told me on one occasion, and people that I talked to that was in 
the intervention mentioned that it came up in the intervention. 
Q: What intervention? 
A: Intervention for Faye Resnick. 
Q: When did you first talk to anyone about that intervention? 
A: After -- maybe when I was in jail, but I think more when I got out, 
but possibly when I was in jail. 
Q: Prior to the time you went to jail, you had not spoken to anyone 
about that intervention. Correct? 
A: Wrong. 
Q: Who did you speak to about it? 
A: I was told about it by Ron Fishman. And I talked to Christian 
Reichardt about it. 
Q: When did the intervention occur? 
A: I gather during the week of May 6 -- I mean June 6. 
Q: And was Nicole a part of the intervention? 
A: I believe she called it or she caused it to be caused -- called. Q 
What was the purpose of the intervention? 
A: I gather Faye Resnick was a little out of control, and Nicole was 
concerned. 
Q: Nicole told you that she did this. Correct? 
A: No. 
Q: She didn't tell you that she had called the intervention? 
A: No. 
Q: Did she tell you that she participated in it? 
A: No. 
Q: Did she ever discuss with you the intervention? 
A: No. 
Q: And how did you find out what you just said a moment ago? 
A: Originally, Ron Fishman told me. Then Christian Reichardt told me. 
Q: The conversations with Fishman and Reichardt occurred before 
Nicole's murder? 
A: Yes. 
Q: And when you heard about the intervention from Ron Fishman and 
Christian Reichardt, did you speak to Nicole about that? 
A: No. 
Q: Did you speak to anyone about that? 
A: Other than the two of them. 
Q: Yes. 
A: No. 
Q: You said that Nicole told you that she had used some drugs, illegal 
drugs. When was that? 
A: In January. 
Q: Of what year? 
A: '94. 
Q: Was that the first time that she told you that? 
A: That she was using it, well, yeah. I mean, would be concerned in 
'94. In '93 she told me, too, but we weren't together in '93. But in 
'94, she -- something happened in '94, and she called me in New York and 
told me about it. 
Q: Let's just focus for now on 1994. When is the first time in 1994 
that she told you that she was using drugs? 
A: Somewhere near the middle to end, I believe, of January. Could have 
been the beginning of February, but I think it was the middle or the 
end of January. 
Q: What did she say to you? 
A: She called me. She was crying. 
Q: What did she say? 
A: She was in trouble. 
Q: What else did she say? 
A: She was in trouble. She did something she wasn't -- she thought she 
was going to get in some trouble. She needed my help. 
Q: What did she say that she had done? 
MR. KELLY: I am going to object at this time. 
THE WITNESS: Thank you. 
MR. KELLY: I am going to ask to see you. I want to speak to you for a 
minute, Mr. Petrocelli. 
THE WITNESS: Thank you. 
MR. PETROCELLI: Excuse me. THE VIDEOGRAPHER: We are going off the 
record now, and the time is approximately 9:48. (Recess.) THE 
VIDEOGRAPHER: We are back on the record now, and the time is 
approximately 9:58. 
BY MR. PETROCELLI: 
Q: Mr. Simpson, let me go back to the intervention that you described 
involving Faye Resnick. Okay? You said you spoke to Ron Fishman about 
it and Christian Reichardt. Correct? 
A: Correct. 
Q: Tell me what Fishman told you about the intervention. 
A: Told me that there was an intervention; did I hear, and I said no. 
And he described to me that they had evidently called an intervention, 
and there was a lot of people angry with one another. Faye was put into 
a center, rehab center and there was a lot of anger among the various 
people involved. 
Q: Did Fishman tell you this? 
A: Yes. 
Q: And did he attend it? 
A: No. 
Q: And how did he find this out? 
A: You would have to ask him. 
Q: Did he tell you how he knew? 
A: No. 
Q: Did you do anything about that information once you heard it? 
A: I -- immediately, no. 
Q: At any time? 
A: Other than talk to Christian to see how he was faring about it, 
other than that, no. 
Q: Who is Christian Reichardt? 
A: He was -- had some relationship with Faye Resnick. 
Q: And you spoke -- you called him up? 
A: Yes. 
Q: And after hearing from Fishman about the intervention? 
A: Yes. 
Q: And tell me what you and he discussed; that is, you and Reichardt. 
A: I asked how he was doing, and he told me he was hanging in there, 
and he sort of described what happened. 
Q: Was the subject of the intervention essentially Faye's problems? 
A: I'm sure the intervention was, yes. 
Q: Did you do anything after talking to Reichardt? 
A: What do you mean, did I do anything? 
MR. BAKER: Relative to the intervention? 
BY MR. PETROCELLI: 
Q: About the intervention. 
A: No. 
Q: Was that the last time you discussed that before the time you were 
incarcerated, with anyone? 
A: I -- as best I can recall, yes. 
Q: And you never discussed it with Nicole. Correct? 
A: No. 
Q: Now, did you -- in your conversation with Fishman, was there any 
discussion about Nicole? 
A: Yes. 
Q: Relate that discussion. 
A: That Christian and Nicole had an argument because of how, I guess, 
the intervention came across -- came about. 
Q: You mean the way it was being handled? 
A: I guess so, yes. 
Q: And that was reported to you by Fishman. Right? 
A: Yes. 
Q: And was there anything else said about Nicole in your conversation 
with Fishman? 
A: Not that I recall. Q Okay. And in your conversation with Reichardt, 
was there any discussion of Nicole? 
A: Yes. 
Q: And what was that discussion? 
A: In part he was upset with her for not letting him know what had been 
going on. 
Q: With Faye? 
A: With Faye. And in part that she didn't call him, and the fact that 
they were letting it go, and I guess it was he who really forced the 
intervention at that point. 
Q: Christian? 
A: Yes. 
Q: What did Christian tell you that was going on with Faye Resnick that 
he was upset with Nicole for not responding to sooner? 
A: That she was heavily involved in cocaine and was doing it in 
Nicole's presence regularly and that Nicole never alerted him to it. 
Q: Now, this is something that was told to you by Christian Reichardt? 
A: Correct. 
Q: You didn't witness this yourself. Right? 
A: No. Q You've never witnessed Faye Resnick taking cocaine. Correct? 
A: Cocaine, no. 
Q: In 1994 did you ever see Faye Resnick take any sort of illegal 
narcotic? 
A: Illegal? 
Q: Yeah. 
A: I would say I wouldn't know, so I don't know what's illegal or not. 
Q: Did you ever see her abuse drugs, witness her abusing drugs in the 
year 1994? 
A: I felt I did, yes. 
Q: You personally witnessed it? 
A: I felt I did, yes. 
Q: When was that? 
A: In March. 
Q: Where was that? 
A: At a restaurant called Toscana. 
Q: Who? --  
MR. KELLY: I'm sorry I can't hear. 
THE WITNESS: A restaurant called 
Toscana. 
MR. PETROCELLI: 
Q: And who was present there? 
A: Nicole, Christian Reichardt and Faye. 
Q: And did you say anything to Faye about this? 
A: Yes. 
Q:: What did you say? 
A: Told her she was out of line doing what she was doing and -- 
Q: Referring to what? 
A: Taking all the pills she was taking and drinking. 
Q: And what did she say? 
A: She argued a little bit, but the other two people sided with me, 
and, you know, they took the pills from her. 
Q: Other than that incident, did you ever witness her in 1994 abusing 
drugs in your presence? 
A: Not with my eyes, no. O Okay. Other than that incident and what Mr. 
Reichardt told you, did you ever obtain any other information in 1994 
before Nicole's murder that Faye was abusing drugs? 
A: Other than comments Nicole made. O: Nicole would make comments to 
you from time to time about that? 
A: Yes. 
Q: To what effect? 
A: That she had drug problems and that she was a --  
Q: "She" being whom? 
A: Faye Resnick. 
Q: And what was your reaction to that? 
A: It had nothing to do with me, and I really didn't spend that much 
time with Faye, so it wasn't a part of my life. It was her -- you know, 
their problems, not mine. 
Q: I see. Do you know what the intervention consisted of, by the way? 
A: No 
Q: Do you know the details of it? 
A: Other than what was told to me by Christian. no. 
Q: Do you know where it took place? 
A: No. 
Q: Do you know what happened after the intervention --  
A: When I got --  
Q:  -- with Faye? 
A: From what I gather, Christian took her to some place. 
Q: Do you know where? 
A: No. 
Q: And did you ever see Faye there? 
A: No. 
Q: Or call her there? 
A: No. 
Q: Do you know what date Faye went there? 
A: I believe it was in the middle of the week of the week of the 6th. 
Q: June 6? 
A: Yeah, the middle of that week, sometime during that week. A few days 
before Nicole's death. 
Q: You did not speak to Faye Resnick at any time from the moment she 
went into the treatment center? 
A: No. 
Q: When was the last time that you spoke to her? 
A: Either Sunday or Monday of that week. That would have been whatever 
those dates were, Sunday and Monday preceding the 12th. 
MR. BLAZER: Spoke to Faye, you mean? 
MR. PETROCELLI: Yes. 
Q: Let me show you as the next exhibit in order a calendar marked as 
Exhibit --  
MR. BAKER: 8? 
MR. PETROCELLI: -- 8. (Plaintiffs' Exhibit 8 was marked for 
identification by the reporter and is attached hereto.) 
MR. BAKER: And what do you want him to look at particularly here? 
MR. PETROCELLI: June. First of all, I want him to identify it. 
MR. BAKER: Well, I will stipulate it's a 1994 Month-At-A-Glance. 
MR. PETROCELLI: I want to go over the calendar. 
MR. BAKER: I'm sorry. Go ahead. 
MR. KELLY: Do you have copies for everybody? 
MR. PETROCELLI: Yes. 
MR. KELLY: I'm sorry. 
MR. BREWER: What exactly is Exhibit 8? Has it been identified? 
BY MR. PETROCELLI: 
Q: I have before you -- I'm getting copies circulated. I have before you 
what we have marked as Exhibit 8. Do you recognize this document? 
A: It depicts a calendar. 
Q: Excuse me? 
A: It depicts portions of a calendar, I believe. 
Q: Now, is this your calendar? 
A: I think it does -- I think it is a cop -- I believe so. yes. It's not my 
calendar, but it's somehow, I guess, if I put it together, it would be
 -- 
Q: Right. You have to put the two pages together where the spirals are. 
That's how it was Xeroxed. Do you see that? 
A: Yeah. Yeah, I think it is mine. 
Q: Now, this is a calendar that you maintained yourself? 
A: I never really had a calendar, no. Cathy would fax me a page or, you 
know, whatever was coming up, she'd send me a page with what's on it, 
and that was it. So I never had a calendar. 
Q: You didn't carry a calendar like sort of like this one, Month-At-A 
Glance --  
A: No. a  -- in your bag with you, right --  
A: No. 
Q: -- or on your person? 
A: No. 
Q: And Cathy Randa would maintain your calendar? 
A: Yeah. 
Q: Is any of the handwriting on here your handwriting? If you take a 
look at the page for June, for example. 
A: I don't believe so. 
Q: And do you know whose handwriting is on there? 
A: I believe it's Cathy's. 
Q: There seems to be different handwriting on these pages. 
MR. BAKER: I am not sure it's different handwriting. It's different 
pens. 
BY MR. PETROCELLI: 
Q: Do you recognize all of the handwriting on June of 1994 as that of 
Cathy Randa? 
MR. BAKER: This is the page he s looking at --  THE Witness: That's part 
of June That's part of June. 
MR. BAKER: Oh, sure it is. I'm sorry. 
THE WITNESS: I don't even 
recognize it as Cathy's. I'm just assuming, it's Cathy's. I wouldn't 
recognize Cathy's handwriting if you wrote it down and showed it to me. 
BY MR. PETROCELLI: 
Q: You wouldn't recognize her handwriting? 
A: No. I never paid attention to her handwriting. 
Q: But none of this is your handwriting. Is that right? 
A: I don't believe so, no. Q Did you maintain any other kind of 
appointment book or calendar yourself, like one of those computerized 
or any kind, for that matter? 
A: No. 
Q: Nothing? 
A: No. 
Q: So any time you needed to know what your appointments were, Cathy 
would send you something. Is that right? 
A: Well, normally. She always in my travel folder or whatever would 
have whatever I got to do that week or whatever my month looked like, 
yeah. 
Q: Did you maintain a calendar at home? 
A: No. 
Q: In your office or anywhere? 
A: No. 
Q: Okay. Now going back to the calendar for June, okay, and looking at 
it, can you tell me what's the last day that you spoke to Faye Resnick? 
A: It was either Monday or -- Sunday or Monday, the 5th or the 6th. One 
of those days. I'm not sure. 
Q: Of June. Correct? 
A: Yes. 
Q: And do you recall what the purpose of that call was? 
A: It wasn't a call. 
Q: You met with her? 
A: No. She was at Nicole's house. 
Q: And that's before the intervention, to the best of your knowledge. 
Right? 
A: Yes. Yeah, it was definitely before the intervention. 
Q: So you were at Nicole's house what day, now? 
A: Either Sunday or Monday. 
Q: Now we are talking June 5 or June 6. Correct? 
A: Yeah. 
Q: In Nicole's house, you mean 875 Bundy. Right? 
A: Yes. 
Q: Who else was there? 
A: I don't -- Justin may have been with me, and I didn't go in the house, 
so -- well, no, I didn't go in the house that day, so I don't know who 
was in the house. 
Q: So you stayed outside? 
A: Yes. 
Q: Where? 
A: In the front. 
Q: Front of the house? 
A: Yes. 
Q: By the way, is there a buzzer at the front that you could ring the 
doorbell? 
A: Yes. 
Q: And was that operable? 
A: As far as I knew, yes. 
Q: And was there one in the back? 
A: No. 
Q: There was no buzzer in the back? 
A: No. 
Q: Could you enter the back? 
A: If they opened the garage, you could. 
Q: And was there a back -- another back entrance besides the garage? 
A: Not that I know of. 
Q: Was there a back gate, for example? 
A: What do you mean? To the property? 
Q: Yes. 
A: Yes. 
Q: Did that have a buzzer? 
A: No. 
Q: How would you get in through the back gate if you wanted to? 
A: Somebody would have to open it. 
Q: Was it locked? 
A: I would think so, yes. 
Q: So if you came in through the back gate, you couldn't get in unless 
you had a key? 
A: Yes. 
Q: And on the front gate, you would have to buzz somebody. Right? 
A: Yes. 
Q: And then --  
A: Or have a key. 
Q: Or have a key. 
A: Yeah. 
Q: And then there was the garage in the back. Right? 
A: Yes. 
Q: And on this occasion did you buzz to gain entry to the property? 
A: Yes. 
Q: And did you come alone? 
A: I may have been with Justin. 
Q: What was your purpose in going there? 
A: Get the dogs. 
Q: What dogs? 
A: Actually, get Chachi. 
Q: That's your dog? 
A: Yes. 
Q: And then take the dog back in the car and leave. Right? 
A: Yes. 
Q: When you buzzed the buzzer in the front there, is there like a voice 
box where you can talk and be heard? 
A: Yes. 
Q: And you identified yourself? 
A: No. 
Q: They just buzzed, and you opened the door and went through? 
A: No. 
Q: Tell me what happened. 
A: I buzzed and Faye came out. 
Q: She came all the way out to the front gate? 
A: Yes. 
Q: Opened it up? 
A: Yes. 
Q: And then you and Justin went in? 
A: No. 
Q: Justin stayed in the car? 
A: No. 
Q: Tell me what happened. 
A: The dog ran out. 
Q: Out of the gate? 
A: Yes. 
Q: And ran where? 
A: Off. 
Q: What did you do? 
A: I went one way and Faye went up Bundy, and I went one way, and then 
I drove back -- I mean I walked back. got in my car and started driving 
and caught the dog in the alley across on the other side of Bundy in an 
alley and then brought the dog back to the front of the house. 
Q: What did you do then? 
A: I got the dog back on her property. 
Q: How did you do that? 
A: Grabbed it and brought it, you know, back on the property. 
Q: And where did you bring the dog? 
A: To the -- inside the front gate. 
Q: Who did you give the dog to? 
A: Nobody. 
Q: When you went inside the front gate, was it open? 
A: Yes. It wasn't closed, yes. 
Q: So you could push it open without a key? 
A: Yes. 
Q: And you entered the property? 
A: Yes. Q And with the dog? 
A: Yes. 
Q: What did you do when you entered the property? 
A: The dog ran, and I went looking for the other dog. 
Q: Did you find the dog? 
A: Yes. 
Q: Where? 
A: Down below the side of her house. 
Q: You mean the side of the alleyway? 
A: Yes. 
Q: And you walked down that alleyway, and did you go down the stairs? 
A: I believe so. I'm not sure. 
Q: Saw the dog -- How far did you go down the alley? 
A: I don't -- I'm not sure. 
Q: What did you do then? 
A: I got the dog and kinda shooed it to come with me. 
Q: And then what did you do? 
A: Walked the dog back to the front gate. 
Q: And then what? 
A: Faye was at the front gate at that point in time, and I got the dog 
to the truck and put him in and left. 
Q: Did you spend time talking to Faye at the front gate? 
A: Faye was talked -- babbling. Faye was, in my judgment, totally 
plastered. So she was babbling, yes. 
Q: What was she saying? 
A: I couldn't even tell you. Didn't make any sense to me. 
Q: She wasn't coherent to you. Is that what you're saying.7 
A: In my opinion, no. 
Q: Did you spend time trying to talk to her? 
A: No. 
Q: Did you do anything to -- Were you concerned at all for her safety? 
A: No. 
Q: You got the dog and then went back in the car? 
A: Yes. 
Q: Did you talk to anyone else on that occasion? 
A: No. 
Q: For example, did you talk to Nicole? 
A: No. 
Q: Do you know if she was home? 
A: I thought I saw her at the door when I came back with the dog. I 
think she was standing in the doorway. 
Q: Front doorway? 
A: I believe so. I'm not sure. She could have been up on the balcony 
looking down. 
Q: And you said nothing to her? 
A: No, because I just saw her as I was coming, you know, driving up, 
and then she wasn't there. I believe. Other than, "Hey, the dog got 
out," or something maybe, but nothing relevant to anything. 
Q: Did you gesture or wave to her? 
A: Possible. I don't know. I mean, we acknowledged each other, but, you 
know... 
Q: You can't recall any conversation of substance --  
A: No. 
Q: -- of any kind with Faye Resnick. Is that right? 
A: No. 
Q: Was that the last time you were at the Bundy property before 
Nicole's death? 
A: I believe so, yes. 
Q: Were you bleeding on that occasion? 
A: Not that I know of. 
Q: Did you have any cuts that you knew of? 
A: Not that I was aware of. 
Q: Were you wearing any Band-Aids? 
A: Not that I was aware of. 
Q: When you were looking for the dog, what is the other dog you were 
looking for? 
A: I was going to get Chachi and Kato, a dog called Kato is the one 
that got out. 
Q: The dog that got out onto Bundy 
A: Kato. 
Q: -- was Kato. 
A: Yes. 
Q: And you put that dog in the Bronco. Right? 
A: No. 
Q: What car were you driving? 
A: Bronco. Q; Bronco. You first got -- you retrieved Kato. Is that what 
you're saying? 
A: Yes. 
Q: What did you do with Kato when you retrieved him? 
A: As I said, I put him back on the property. 
Q: On the property. 
A: Yes. 
Q: And you went and got Chachi. Right? 
A: Yes. 
Q: When you went and got Chachi, you said you walked a little bit down 
the property. Right? 
A: Yes. 
Q: Did you go all the way down to the back gate? 
A: I don't recall. 
Q: What is your best recollection? 
A: I don't have a best recollection. It's something I do often. 
Q: What is that? 
A: Pick up the dogs. And this one didn't stand out any more than any 
other time. 
MR. KELLY: I'm sorry, Mr. Simpson. I can't hear you. 
MR. BAKER: There was no question, anyway. 
MR. KELLY: Well, he was talking. I couldn't hear him. 
MR. BAKER: I understand. 
MR. KELLY: Okay. 
MR. BAKER: But, you know, if he wants to give a monologue against his 
lawyer's advice... 
MR. KELLY: Well, I especially want to hear things against his lawyer's 
advice. 
BY MR. PETROCELLI: 
Q: We have marked that calendar as Exhibit 8, and while we are on the 
subject of calendars, I am going to show you another calendar. which we 
will mark as Exhibit 9. (Plaintiffs' Exhibit 9 was marked for 
identification by the reporter 1 and is attached hereto.) 
BY MR. PETROCELLI: 
Q: Take a look at what we have marked as Exhibit 9. 
A: Uh-huh. 
Q: Can you tell me if this appears to be a copy of a calendar for you 
for the year 1994? 
A: Yes, it appears to be. 
Q: Is this a calendar that you maintained? 
A: As I told you before, I didn't maintain any calendar. 
Q: Do you recognize the handwriting? 
A: Yeah. Pretty much looks like what is normally on my calendars. 
Q: To the best of your knowledge, do you think this calendar was one 
that was maintained by Cathy Randa? 
A: Possibly. 
Q: This calendar is different from the Exhibit 8 calendar. There are 
different entries for the various dates. Do you know why that is? 
A: I can only surmise. Q What is your best understanding of that? 
A: That normally this would be -- looks more like what she would have 
printed to send to me. The other one looked more like something that 
she would maintain herself. Because I wouldn't want to see all that 
other stuff that's on the calendar. 
Q: Exhibit 9 appears to be a copy of the kind of information that she 
would transmit to you. Correct? 
A: Yeah. She did this page, and if I was taking some trips this week, 
she would put this in my travel folder, just copy a page like this and 
put it in my travel folder. 
Q: So you would take a copy of the page with the days involved in your 
travel. Correct? 
A: Virtually, yes. Q; Literally a Xerox copy? 
A: Yes. 
Q: And you put it in that black bag we discussed yesterday? 
A: Yes. 
Q: What do you call that again? 
A: My grip. 
Q: Your grip. Okay. Are you aware of any other calendars that were 
maintained for you other than these two 
A: No. 
Q: -- for the year 1994? 
A: No. 
Q: Are you aware of whether Cathy Randa shredded any documents in 1994? 
A: No. 
Q: Do you know if she did? 
A: l hope so. 
Q: You told her to? 
A: No. 
Q: Why do you say you hope so? 
A: At one point once the trial began, everybody, all the lawyers, were 
given shredders, and I believe Marcia Clark also talked in court that 
they were all shredding everything, and all our lawyers were shredding 
everything because the media was going through the garbage cans to get 
story material. So it was discussed in the courtroom at one point. 
Q: It was discussed in the courtroom that documents should be shredded? 
A: No. That you should shred all garbage and all stuff once you looked 
at it or whatever. You shredded it and got rid of it. And I believe the 
prosecution said they were doing the same thing. 
Q: You are referring to documents generated in the course of the case, 
you mean? 
A: Yes. 
Q: What about documents at the Brentwood office where Cathy Randa 
worked? 
A: What about it? 
Q: Do you know whether she ever shredded any documents there? 
A: No. 
Q: Did you ever tell her to do so? 
A: No. 
Q: Has anyone ever told you that she did so? 
A: No. 
Q: Have you ever acquired any information that Randa shredded any 
documents after --  
A: What do you mean by "documents"? Garbage? 
Q: No, not things already thrown away. Things that were in your desks 
or your drawers or cabinets. 
A: I think I saw where things were being shredded In our office, yes. 
Q: How did you see that? 
A: They were talking about it in court. 
Q: Who was talking? 
A: I don't know. lt. was an issue in court one day. 
Q: Did you discuss that issue with Cathy Randa? 
A: No. 
Q: Did you tell your lawyers what to tell Cathy to shred? 
A: No. 
Q: Do you know what Cathy shredded? 
A: No. 
Q: Do you know whether she shredded any documents relating to Nicole? 
A: No. 
Q: You don't know one way or the other? 
A: No. 
Q: Do you know whether she shredded any documents relating to the l989 
incident involving spousal abuse? 
A: No. 
Q: Do you know anything about that one way or the other? 
A: No. 
Q: Do you know whether she destroyed any documents? 
A: No. 
Q: Do you know whether Cathy Randa shredded any documents that the 
prosecutors had subpoenaed and requested to be produced in court? 
A: No. 
Q: Do you know whether anyone told her to do so? 
A: No. 
Q: Before you were incarcerated, did you destroy any documents? 
A: No. 
Q: Or ask other people to dispose of, discard or shred any documents? 
A: No. 
Q: After you were incarcerated, did you ask anybody to see that certain 
documents or materials were destroyed, discarded or shredded? 
A: No. 
Q: Do you know whether that occurred? 
A: No. 
Q: Looking at your calendar again, Exhibit 8, let's say --  
A: Which one? 
Q: Take a look at Exhibit 8. It's also -- you could look at the trial 
exhibit number for the criminal case. It was Exhibit 599. Just make 
sure you have the right one. 
A: Uh-huh. 
Q: And look at June again or May. May and June. Can you tell me, prior 
to -- Well, let me back Up. The occasion that you described where you 
retrieved the dogs, when did that occur; on June 5 or June 6? 
A: I'm not sure. 
Q: What is your best understanding? 
A: I don't have one. 
Q: Excuse me? 
A: I don't have one. 
Q: It's one of those two days? 
A: Yes. 
Q: What time of day? 
A: Afternoon. 
Q: And what was the total amount of time that you believe you were on 
the Bundy property on that occasion? 
A: I don't know. 
Q: Less than a minute? 
A: No. 
Q: Less than five minutes? 
A: Yes. 
Q: And when was the time before that occasion when you were last at the 
Bundy property? 
A: In the Bundy -- in Bundy? 
Q: Yes. On the property or in the house. 
A: June 4th. 
Q: And prior to June 4th? 
THE WITNESS: I can't tear this thing? 
MR. BAKER: Yeah. 
MR. PETROCELLI: That's the court exhibit. Why don't you -- I will try to 
fix that at a break. 
THE WITNESS: We're talking on the property? 
BY MR. PETROCELLI: 
Q: Yeah, last time before June 4. 
A: I was definitely there on June 22nd and 23rd --  
MR. BAKER: May? 
THE WITNESS: I mean May 22nd and May 23rd, and --  
BY MR. PETROCELLI: 
Q: Both days? 
A: Yeah, pretty sure both days, and possibly... I can't really recall. 
Possibly another time during the course of that week. Just briefly, 
yes. 
Q: What happened on June 4 that caused you to be on the property? 
A: I had to look at my son's Nintendo setup. 
Q: That was in the house? 
A: Yeah. 
Q: And how did you access the property on that occasion? 
A: I came. I blew the horn. Justin was with me. I blew the horn, Nicole 
opened the garage, and we came up through the garage, went to his room 
looked at his setup and went back down the stairs and went back out the 
garage and left. 
Q: You drove up to the back of the property? 
A: Yeah. 
Q: Right in front of the garage? 
A: Yeah. 
Q: And the garage door is closed? 
A: Yeah. 
Q: You blew the horn, and the garage door went up? 
A: Yeah 
Q: And then you went in? 
A: Yeah. 
Q: And how long were you there? 
A: Whatever time it took to walk up the stairs, whatever it took, about 
a minute or two maximum to see the hookup, and then walk back down the 
stairs. Five minutes or less. 
Q: Now, the stairs that we're referring to are the stairs that lead 
from the inside of the garage up into the home. Correct? 
A: Yes. 
Q: we are talking about interior stairs. Right? 
A: Yes. 
Q: Then when you got into the first level of the home, you then went 
upstairs using interior stairs to the bedroom --  
A: Yes. 
Q: -- of your son. correct? 
A: Yes. 
Q: And you fixed the Nintendo setup for him --  
A: I didn't fix it. I needed to see the hookup and how it was arranged 
and everything. 
Q: Did you buy him a Nintendo cartridge around that time? 
A: I bought him one later, and I had already bought him one  -- whatever 
the other game is. There's another one like Nintendo. 
Q: Sega? 
A: Sega or something, and we were trying to set it up in his room. 
Q: Do you remember the name of the game you bought him? 
A: No. 
Q: And then you came -- After you checked out the setup --  
A: Yeah. 
Q: -- what did you then do? 
A: Went and got in my car. 
Q: Came right back down the stairs same way you came up? 
A: Yeah. 
Q: Went out the garage and into the car. Is that right? 
A: Yeah. 
Q: And drove off. 
A: Yeah. 
Q: Did you converse with Nicole that occasion? 
A: On the 4th, no. 
Q: Was she there? 
A: Yeah. 
Q: Did you see her? 
A: No. 
Q: How do you know she was home? 
A: Jason -- Justin ran in her room, and she was in bed and they were 
talking, and you have to go by the door of her room, and I heard them 
talking as I went to his room. You have to walk by her room to get to 
his room. 
Q: Justin came with you? 
A: Yes. 
Q: And then he left with you? 
A: Yes. 
Q: Was there anybody else home with Nicole? 
A: Not that I know of. 
Q: And you didn't speak to Nicole at all? 
A: No. Well, somebody may have been home with Nicole, because I saw 
Faye's car, but I don't know if Faye was there. 
Q: You recognized her car? 
A: Yeah. 
Q: Where was it parked? 
A: In the back. 
Q: What kind of car was it? 
A: I don't know. I don't recall. 
Q: You don't remember? 
A: I don't remember, but I know it was her car. 
Q: Nicole then had two cars. Is that right? 
A: I believe so, yeah. 
Q: What were they? 
A: A Ferrari and a truck. 
Q: Were they both in the garage? 
A: I don't recall. I don't think so. 
Q: Were they parked there on the property? 
A: I don't think so because I was able to pull right up to the garage, 
so one of them must not have been there. 
Q: Is that where one usually  -- where she usually parked one of them? 
A: Yes. 
Q: Where? Outside the garage door? 
A: Yes. 
Q: Which one was that? 
A: The jeep. 
Q: And the other car, the Ferrari, was always parked in the garage? 
A: Yes. 
Q: When you used to arrive, would you literally turn into the driveway 
or just park parallel to it? 
A: Turn into it. 
Q: Turn into it? 
A: Yeah. 
Q: So you would park next to the other jeep. Right? 
A: Yeah. You couldn't park parallel. You'd block the alley. 
Q: Now, the last time before June 4 you were at the Bundy property you 
said was definitely when? 
A: Well, I was definitely there the 22nd and 23rd --  
Q: 22nd and 23rd? 
A: Of May, yes, and I believe I could have been there one time during 
that week. 
Q: What did you do there on the 22nd and 23rd? 
A: 22nd I helped Nicole with something, and we talked, and 23rd I think 
I had dinner with her. 
Q: Let's start with the 23rd. Tell me about that occasion. 
A: Nicole needed  -- I think she needed some cough syrup, and the kids 
were with me and she called -- I believe she called. She went home. I 
checked on her, and she needed some cough syrup or something, and I 
went over and we talked. We talked about a few things. 
Q: Did you go over there alone? 
A: Yes. 
Q: And parked in the same place in the back? 
A: I don't recall. 
Q: Which car did you drive? 
A: I don't recall. 
Q: And how did you get into the house? 
A: Either I blew, if I was in the back, and she answered or she buzzed 
me in the front. I just don't recall. 
Q: You don't remember which way? 
A: I don't remember. 
Q: Was it your practice to drive to the front of the house or the back 
of the house? 
A: I did both, depending on -- normally depended on where I was coming 
from. If I was coming from home, normally I went to the back. So, you 
know. So more than likely it was the back, but I don't recall how I 
entered the house that time. 
Q: And if it was the back, that's the way you would go up. Right? 
A: Yeah. 
Q: And if it was the front, you would be let in through the front gate, 
and then you would go right to the front door. Right? 
A: Yes. 
Q: Now, that front door is situated on the property prior to those 
steps going down the alleyway. Right? 
A: Yes. 
Q: So in order to go from the gate to the front door, you don't have to 
walk down the alleyway and go down the steps and go back up again. 
Correct? 
A: True. 
Q: Is there any other entrance to the property besides -- to the home 
besides that garage in the back and the front door that you just 
described? 
MR. BAKER: The back gate you were talking about? 
MR. PETROCELLI: Let me start all over again. 
Q: Is there any other entrance to the Bundy home of Nicole other than 
the garage and the front door that you just described? 
MR. BAKER: You mean actually to get into the -- physically inside the 
house? 
MR. PETROCELLI: Yes. 
MR. BAKER: Okay. THE witness: I don't know if you can -- there's a room 
down there. I don't know if you can -- I don't know if it needs a key to 
get into, but there is a room that is down on that walkway, but I'm not 
sure if there's -- if it's -- if it can he used as an entrance. 
BY MR. PETROCELLI: 
Q: You are now talking about the walkway, meaning that side alley. 
Right? 
A: Yes. 
Q: And you are saying that if you come down that side alley, there is a 
door? 
A: There is a room, and I know you come out of that room. I just don't 
know if it's a room that you can get into if it's locked. I don't know. 
Q: If you were inside the property, you could come out of that room by 
going out a door to the side alley? 
A: Yes. 
Q: I see. And what is that room. 
A: I think she used it as a maid's room. 
Q: Maid's room. 
A: Yes. 
Q: And it had a door that opened out into the side alley? 
A: I believe so, yes. 
Q: Is that a door that you ever used? 
A: No. 
Q: Never went in or out that door? 
A: Never went in or out of that room. 
Q: Never was in that room? 
A: No. 
Q: How do you know about it? 
A: I know it's there. You can't come in from the garage without seeing 
the room there. 
Q: How do you know that it has a door on the other side that goes w the 
side alley? 
A: Because I've been in the alley with the dogs. 
Q: And you've seen that door? 
A: Yes. 
Q: And you can look -- Does the door have a window? 
A: I think it's a glass door. I'm not sure. 
Q: You can see right into the room.7 
A: Yes. 
Q: Are there any other ways of accessing the home? 
A: I don't know. 
Q: Is there more than --  
A: Not that I know of. 
Q: Is there more than one front door? 
A: Not that I know of. 
Q: Did you have any keys m the property? 
A: Not that I know of. 
Q: Are you unsure of yourself? 
MR. BREWER: Well, I am going on object. Vague as to time also. 
BY MR. PETROCELLI: 
Q: In May of 1994 --  
A: I'm sorry. I didn't hear. 
Q: -- did you have any keys to Nicole's property? 
A: None that I knew were Nicole's keys. 
Q: In June of 1994 did you have any keys? 
A: None that I knew of. 
Q: When you say that you did not have keys of Nicole's that you knew 
of, do you have a belief that you had some keys that might have been 
hers but you are not sure? 
A: No, I don't know if -- I have no knowledge of having any keys to 
Nicole's house. 
Q: At any time? 
A: Well, yes, at some time, yes. 
Q: At any time in 1994 did you have any keys to Nicole's house on 
Bundy? 
A: Not that were my keys, no, but I've had in my possession the keys to 
her house in '94. 
Q: I see. And when was that? 
A: Numerous times. 
Q: Why would you have possession of keys to Nicole's house? 
A: Because I stayed at her house a lot, and some nights when I would 
either walk the dog or run to the store to get something, I'd go out 
the front door, and I'd use the key to get back in the front door. Q 
Where would you get that key? 
A: From her. 
Q: You would ask her? 
A: I'd just grab her key. 
Q: Was there a place where you would find the key? 
A: I don't recall. Normally she keeps her key on the counter, I 
believe, the counter in the kitchen. 
Q: And that key on the counter in the kitchen is the only key that you 
would have possession of from time to time? 
A: Yes. 
Q: Is it a single key? 
A: No. I think it was always a group of keys. 
Q: What were they keys to? 
A: Her car, her house, whatever. 
Q: Which keys would you use to access what locks on what doors? 
A: As far as I knew, it was one key that accessed the gate and the 
front door. 
Q: Same key? 
A: As far as I knew, yes. 
Q: Worked for both the gate and the front door? 
A: Yes. 
Q: Which gate are you referring to? 
A: In the front of the house. 
Q: And that's a key that you can specifically recall using to enter the 
front gate and the front door? 
A: And the exit also, yeah. 
Q: And the exit? 
A: And to exit. 
Q: To lock it behind you? 
A: Yeah. 
Q: I see. When was the last time you had that key? 
A: I don't know if I took it -- her keys on the -- the week of -- the week 
she had pneumonia, so it would be the week of the 16th I may have, 
because I left her house to go get her some cough syrup at Westward Ho, 
and I went out the front door and to lock the front door. I may have 
then. 
Q: If you used it on the 16th --  
A: No. The week of the 16th, sometime during the week. O: Did you then 
return it? 
A: Yes. 
Q: Did you return it? 
A: Yes. 
Q: After the time you used the key to go get the cough syrup --  Is that 
what you said? 
A: Yes. 
Q: -- you never had possession of Nicole's keys? 
A: No. 
Q: That was the absolute last time? 
A: Yes. 
Q: Do you remember whether that key had a key ring? 
A: No. I think it was a bunch of keys 
MR. KELLY: Dan, I am going to ask, can we take a five-minute break? 
MR. PETROCELLI: Yes. This is a good time. THE VIDEOGRAPHER: We are 
going off the record now, and the time is approximately 10:38. 
(Recess.) THE VIDEOGRAPHER: We are back on the record now, and the time 
is approximately 11:00 o'clock. 
BY MR. PETROCELLI: 
Q: Going back to your prior testimony about visiting Bundy on the 22nd 
and the 23rd, the day that you went and took care of the Nintendo setup 
was which day, when you went up through the garage into the house? 
A: I believe that was the 4th. 
Q: That was the 4th. 
A: Yes. 
Q: Of June. Correct? 
A: Yes, I believe so. 
Q: And the 23rd, tell me again what you did then. 
A: Nicole and I talked -- the 23rd? 
Q: Yes, May 23rd. 
A: I think I had dinner with them, with Sydney and Justin and her. 
Q: Sydney and Justin were at the house? 
A: On the 23rd, if that's a Monday, yes. 
Q: And you went there and had dinner? 
A: Yeah, I believe so. 
Q: Which car did you drive over? 
A: I don't know. 
Q: Where did you park? 
A: I don't know. 
Q: How did you get into the property? 
A: I don't recall. 
Q: Did you blow the horn? Did you --  
A: I don't know. 
Q: Did you buzz? 
A: I don't recall. 
Q: You have no idea? 
A: No. 
Q: Do you know whether you went in through the garage or some other 
way? 
A: The only other way would have been the front door, and I don't 
recall either. 
Q: When you went into the house, you had dinner there. Did you spend 
the night? 
A: No. 
Q: You came back. 
A: Yeah. 
Q: Were you bleeding on that occasion? 
A: Not that I recall. 
Q: And you didn't have any cuts or anything Like that. Right? 
A: Not that I recall. 
Q: Did you have any Band-Aids or anything like that? 
A: Not that I recall. 
Q: When you say not that you recall, is there any doubt in your mind? 
A: I don'trecall. If you go prior to the 23rd, I can't tell you any 
time in my life I ever bled, but I know I have. 
Q: You can't remember. Is that what you're saying? 
A: Yeah. Yes. 
Q: Now, on the 22nd, what was that occasion when you visited the condo 
at Bundy? 
A: Nicole had left my house feeling weak, and I had the kids. She told 
me she wanted to talk to me. So at some time later on that day I -- that 
night we -- or that afternoon or whatever, I went to her house. I think I 
brought her some food, too. 
Q: Which car did you drive? 
A: I don't recall. 
Q: Where did you park? 
A: I don't recall. 
Q: How did you get into the property? 
A: I don't recall. 
Q: Would it have been through the front gate or the garage? 
A: Yes. 
Q: And you spent -- How long did you spend there with Nicole? 
A: We're talking the 2 --  
Q:  -- 2nd. 
A: I would say an hour or two. That's a guess. That's an estimate. 
Q: Was anyone else home besides the two of you? 
A: I believe the kids. 
Q: The same true on the 23rd; just you, Nicole and the kids. Right? 
A: Yes. 
Q: By the "kids" --  
A: I don't know. Housekeeper might have been there that day on the 
23rd. I'm not sure. 
Q: Her name is? 
A: I don't know. 
Q: Were you bleeding on the 22nd there? 
A: Not that I recall. 
Q: Did you have any cuts? 
A: Not that I recall. 
Q: Now go to -- When was the last time before the 22nd you were there? 
You said the week of the 16th. Right? 
A: Yeah. 
Q: We are in May, of course. 
A: Yeah. 
Q: You described an occasion when you went to go get some cough 
medicine? 
A: Yes. 
Q: And Nicole was sick? 
A: Yes. 
Q: She was in bed? 
A: Yes. 
Q: And when did you first go to her house -- What day was that during the 
week of the 16th of May? 
A: I don't know. I was there almost  -- when I was in town that week, I 
was there each day. 
Q: You went there a number of days? 
A: That week, yes. 
Q: How did you get there? 
A: I'm sure I drove. 
Q: Which car? 
A: I don't know. 
Q: Where did you park? 
A: I don't know. 
Q: You have no recollection where you parked? 
A: No. Q Was --  
A: The front or the back. 
Q: Excuse me? 
A: Front or the back of the house. 
Q: If you were going to be there an extended !181 period of time, would 
you typically park in the back? 
A: No. 
Q: And when you -- So whenever you entered the house on those various 
days, you would have entered through the garage or the front gate. 
Correct? 
A: Yes. 
Q: When you went through the front gate, you would go directly from the 
front gate to the front door. Correct? 
A: Yes. Unless the dogs were there and I was dicking around with the 
dogs. 
Q: Do you remember doing so? 
A: I've done it many times. 
Q: Did you do so that week? 
A: I'm sure I did. 
Q: Were you bleeding at all at the property during the week of May 
16th? 
A: Not that I recall. 
Q: Did you have any cuts? 
A: Not that I recall. 
Q: When you entered through the front, you would park on Bundy. Is that 
right? 
A: Yes. 
Q: Now, during that week did you make various trips and errands for 
Nicole to get her things? 
MR. BAKER: During what week are we talking about? 
MR. PETROCELLI: 
Q: During the week of May 16 when she was ill, you identified one time 
when you were there, then left to bring her some cough medicine and 
came back. Right? 
A: Yeah. Yeah. 
Q: Were there any other occasions during that week when you were 
visiting Nicole where you were there, left and then came back? 
A: Possibly. 
Q: Do you have a specific recollection of any? 
A: I know I bought the kids dinner at least one night that week and 
went to probably Rosti to get it, so obviously I'm pretty sure that I 
did at least one time that week go to Rosti to get it and came back. 
Q: You were already at Nicole's place and --  
A: Yeah. 
Q: -- then left --  
A: Yeah. 
Q: -- and came back? 
A: I'm pretty sure. 
Q: How would you get back into the property when you returned to the 
property to get back in? 
A: I don't recall. 
Q: Did you have a key? 
A: She may have given me a key one of those times. May have, but I 
don't recall. 
Q: You don't recall. 
A: No. 
Q: Is that correct? 
A: Yes. 
Q: Do you know any other person. other than Nicole, who in May or June 
of 1994 had keys to her apartment? 
A: Firsthand, no, but I think Cora did. 
Q: When you say, "Firsthand, no," what does that mean? 
A: I never saw her hand a key to anyone else. 
Q: What makes you believe that Cora may have had a key? 
A: Because I believe when we were on a trip -- I know she had a key to 
Cora's house, and when we were on a trip, couple of trips we were on, I 
believe Cora was -- had a key to her house. It just seems to me that she 
had mentioned that Cora had a key to her house for something. 
Q: You didn't see the key. Right? 
A: No. 
Q: And you never got the key from Cora. Right? 
A: No. 
Q: And you've never seen Cora take possession or hold or use the key. 
Right? 
A: No. I've been in Nicole's house when Cora's come in, but actually 
that was on Gretna Green. I've been in her house upstairs with Nicole 
in the shower, Nicole's in the shower, I'm in the shower, and Cora's 
come in the house, so I assume she had a key. 
Q: Just an assumption on your part? 
A: Yes. Yes. And I'm pretty sure I've heard her say that Cora had a 
key. 
Q: You're pretty sure you heard who say? 
A: Nicole state that Cora's had a key. 
Q: When did she tell you that? 
A: I don't know. During the course of the year or so we were back 
together. 
Q: Did you question why Cora had a key? 
A: No. 
Q: And you don't know of anybody else who had a key to Nicole's Bundy 
condo. Is that correct? 
A: No. 
Q: That's correct? 
A: Yes. 
Q: After Nicole's death, you never got a key to her condo. Correct? 
A: No. No. 
Q: Is that correct? 
A: That's correct. 
Q: And you don't know of anybody else who received the key to the condo 
after Nicole's death. Correct? 
A: No, that's not correct. 
Q: What do you know in that regard? 
A: I know A.C. got a key. 
Q: When did A.C. get a key? 
A: I don't know. There was some things that they were trying to move, 
and he got a key from the Browns. 
Q: The Browns gave A.C. a key? 
A: Yes. 
Q: When did that occur? 
A: I don't know. Sometime in June. 
Q: After Nicole's death? 
A: Yes. 
Q: How do you know that? 
A: I just remember they were talking about getting something -- helping 
move, is what I think it had to do, helping to move some things, and I 
believe -- or maybe it was getting something for -- might have had something 
to do with getting some clothes for Nicole or getting something for the 
kids that week, but I'm pretty sure A.C. had access to the house. 
Q: Are you telling me that -- This is a  -- This is access -- Withdrawn. You 
are saying that A.C. got a key to Nicole's condo --  
A: Got access. I think a better word would be "access." 
Q: What does "access" mean? 
A: The ability to get in. 
Q: How do you know that? 
A: Because there was some conversation about it. 
Q: You were present? 
A: I just heard it being spoken about. 
Q: You heard who speaking about it? 
A: I believe it was A.C. and maybe Lou Brown. 
Q: When were you in the presence of A.C. and Lou Brown? 
A: At the wake I was in the presence of Lou Brown and at the funeral in 
the presence of Lou Brown, I think on the phone a few times speaking to 
Lou Brown, and A.C. I believe was in and out and around. He was running 
errands, bringing my kids to me, bringing the kids back to Laguna, 
doing various things. 
Q: Were you ever in a conversation with Lou Brown and A.C. Cowlings 
when the subject of access to Nicole's condo came up? 
A: I believe. yes. l believe it was the subject of getting something 
from Nicole's house, and I believe I was, yes, but I can't -- I don't have 
a specific memory. 
Q: Where was that conversation? 
A: I don't know. 
Q: What exactly was said? 
A: I told you I don't have a specific memory. 
Q: What was said at all about access? 
A: I just recall A.C. was supposedly helping the Browns get something 
or move something from Nicole's house. 
Q: But you don't know that A.C. actually received a key to the condo. 
Correct? 
A: That's correct. 
Q: And you have never seen A.C. Cowlings possess a key to Nicole's 
condo. Correct? 
A: No. That's correct. a That's correct? 
A: Yes. 
Q: So other than this conversation that you may have -- or whatever you 
heard in this conversation, you are not aware of anybody else getting a 
key to Nicole's condo after her death. Correct? 
A: Access, keys -- access, I think Ron Hardy's someone  -- I don't know 
firsthand. You're right. I don't know firsthand. a You don't know that 
anybody actually got a key to the condo. Correct? 
A: Correct. 
Q: Including Cowlings. Correct? 
A: Correct. 
Q: Did you ever use a key to Nicole's condo to the back gate? 
A: No. 
Q: Do you know whether you even needed a key? 
A: No. 
Q: You don't know? 
A: I don't know. I know it locks. 
Q: But you don't know whether you need a key to get in or out? 
A: I've never looked at it and see if you need a key. I never thought 
about it, no. 
Q: Can you estimate for me how many times you went to Nicole's property 
on the 16th of May when she was ill? 
MR. LEONARD: On the 16th? 
MR. PETROCELLI: The week of the 16th. 
MR. BAKER: I thought we talked about --  Go ahead. You can answer, O.J., 
if you have an estimate. 
THE WITNESS: I think pretty sure on the 17th I 
did. I don't know if I went on the 16th at all. I may not even have 
been in town on the 16th. I'm pretty sure on the 17th, 18th and 19th I 
did probably twice each day. 
BY MR. PETROCELLI: 
Q: On those occasions Nicole was ill with a pneumonia? 
A: Yes. 
Q: And she was confined to bed? 
A: Well, not really, but for the most part, yeah. 
Q: For the most part she was in bed? 
A: Whenever I saw her, she was in bed a few times and she was out of 
bed a few times. 
Q: Where is her bedroom. 
A: On the third floor, depending on which side of the property you're 
entering from. 
Q: That's the top floor? 
A: Yeah. 
Q: And the front door accesses which level of the property? 
A: Second. 
Q: Second? 
A: Uh-huh. 
Q: And the garage, when you come in through the garage, what floor do 
you enter into? 
A: The bottom. 
Q: And then you take another set of stairs to the second floor? 
A: Yes. 
Q: And that's where the living room and kitchen are. Correct.? 
A: Yes. 
Q: And the bedroom is upstairs, correct, Nicole's bedroom? 
A: Yes. 
Q: I would like to show you some photographs, which I am going to mark 
as exhibits 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21. 0kay? 
(Plaintiffs' Exhibits 10 through 21 were marked for identification by 
the reporter and are attached hereto.) 
BY MR. PETROCELLI: 
Q: I have handed you exhibits 10 through 21, which depict various 
articles of clothing. You've looked through exhibits 10 through 21, Mr. 
Simpson? 
A: Yes. 
Q: You recognize that clothing? 
A: Not necessarily, no. 
Q: Do you recognize any of it? 
A: Not necessarily, no. 
Q: When you say "not necessarily" 
A: I mean, I recognize Calvin Klein underwear --  
Q: Let's --  
MR. BAKER: Go ahead. Finish your answer, O.J. 
THE WITNESS: I recognize 
Calvin Klein underwear and I recognize white socks, yeah. 
BY MR. PETROCELLI: 
Q: Exhibit 10 is a picture of a jacket. Do you see that? 
A: Yeah. 
Q: Is that yours? 
A: I don't know. 
Q: Do you know whose jacket that is? 
A: No. 
Q: No idea if it's your jacket? 
A: No. 
Q: Could it be? 
A: If I could see the size --  
MR. BAKER: Is it possible? Wait, wait. Don't answer that. 
MR. KELLY: I am sorry. What number are we on? 
MR. LEONARD: 10. 
MR. BAKER: That is irrelevant and has no probative value, and it's 
immaterial whether it could be when he has no recollection. There is no 
foundation, and I instruct him not to answer the question. 
MR. PETROCELLI: If that standard were applied to the criminal trial, it 
would have lasted half the time. 
Q: Look at Exhibit 11. It depicts a shirt. Do you see that? 
A: Yes. 
Q: Is that your shirt? 
A: I really couldn't say. 
Q: It says Palm Beach Polo. 
A: Does it? 
Q: Let me see. No, it doesn't. Next one does. Do you recognize that 
shirt? 
A: Do I? 
Q: Yes. 
A: I recognize it as a white shirt. 
Q: Is it your shirt? 
A: I really couldn't say. 
Q: Do you know whose shirt that is? 
A: I have no idea. 
Q: I would like you to take a look at Exhibit 12, a shirt with the name 
"Palm Beach Polo" on it. Do you see that? 
A: Yes. 
Q: Do you recognize that shirt? 
A: I've seen a shirt like this, and I think I've owned a shirt like 
this. 
Q: Do you still have it? 
A: I don't know. 
Q: Have you seen it lately? 
A: I haven't looked for it lately. 
Q: Have you seen it since you were released from jail? 
A: Not that I know of. Possibly. I see all my shirts hanging in my 
closet. I don't look to see the decals on them, so I don't know. Maybe 
I have seen it. 
Q: You do own a shirt like the one depicted in Exhibit 12. Correct? 
A: I believe so, yes. 
Q: Okay. Take a look --  
MR. LEONARD: Dan, which number was that? 
MR. PETROCELLI: 12 
MR. BAKER: 12. 
BY MR. PETROCELLI: 
Q: Take a look at Exhibit 13. depicting some socks. Are those your 
socks? 
A: I have no idea. No way of knowing. 
Q: Do you have socks like that? 
A: White socks, yes. 
Q: Did you have socks like the ones depicted in Exhibit 13 in June of 
1994? 
A: I owned white socks. 
Q: Like those? 
A: Well, I can't sec the details on them, but they're white socks from 
what I can see. 
Q: You did own white in June of 1994? 
A: Yes. 
Q: Take a look at Exhibit 14 depicting a white and blue pair of 
underwear. Calvin Klein, I believe? 
A: Yes. I can't tell if they're Calvin Kleins or not. 141 
Q: Are those your pairs of underwear? 
A: I have no way of knowing. 
Q: Did you own underwear like that in June of 1994? 
A: I owned Calvin Kleins and Jockey underwear, yes. 
Q: Did you own the color blue and the color white? 
A: White for sure. Blue, I don't know. 
Q: You don't remember? 
A: No. 
Q: Are you affiliated in any way -- Withdrawn. Take a look at the next 
photograph, Exhibit 15, depicting a shirt -- two shirts. One that says 
what on it? It says "Don't Knock New York, Donna Karan, New York." Do 
you see that? 
A: Yes. 
Q: Is that your shirt? 
A: It could be. 
Q: You owned a shirt like that in June of 1994? 
A: I'm not sure, but I did work for Donna Karan -- I mean I had a lot of 
Donna Karan stuff. 
Q: They gave you free clothing? 
A: Yes. Sometimes, yes. 
Q: You mean before you were incarcerated, you worked for Donna Karan 
and received clothing from them? 
A: No, I didn't work for them, but I had sort of -- I liked their 
clothes, yes. 
Q: You received clothing from Donna Karan before you were incarcerated. 
Correct? 
A: Yes. Yes. 
Q: Next is Exhibit 16, which depicts two more shirts. Are those your 
shirts? 
A: I have no way of knowing. 
Q: Do they look like shirts you owned in June of 1994? 
A: I owned T-shirts, yes. 
Q: Like those? 
A: I don't know what these are like. 
Q: That look like those. 
A: They look like white T-shirts. 
Q: Did you own such T-shirts in June of 1994? 
A: I own white T-shirts, yes. 
Q: Okay. Not currently. Did you in June of 1994? All my questions are 
directed to that time frame. 
A: Yes. 
Q: Okay. Next is Exhibit 17, which depicts a Polo shirt. Is that your 
shirt? 
A: I have no way of knowing. 
Q: It's extra large. Is that your size? 
A: Sometimes, yes. 
Q: Did you wear extra large Polo shirts in June of 1994? 
A: I don't know. 
Q: You don't know? 
A: I don't know. This is a Polo make. 
Q: I don't recall. 
Q: Did you wear extra large shirts in June of 1994? 
A: Sometimes, yes. 
Q: Did you own any Polo shirts? 
A: I don't know. 
Q: Is that your shirt? 
A: I have no way of knowing. 
Q: Next is Exhibit 18, a pair of Calvin Klein underwear. Is that yours? 
A: I have no way of knowing. 
Q: Did you own that in June of '94? 
A: Own what? 
Q: That pair of underwear. 
A: I told you I have no way of knowing that these are mine. How can I --  
Q: Did you wear Calvin Klein underwear? 
A: I'm sure I did, yes. 
Q: In June of 1994? 
A: I'm sure I owned some pair then, yes. 
Q: By Calvin Klein? 
A: I'm positive I did, yes. 
Q: Next is Exhibit 19, Nike shirt. Is that your shirt? 
A: I have no way of knowing. 
Q: Did you own a shirt like that in June of 1994? 
A: I don't know. 
Q: Did you receive clothing from Calvin -- from Nike, as you did from 
Donna Karan, prior to being incarcerated? 
A: In my life? I'm sure I did. 
Q: Within a year of your incarceration? 
A: I have no way of knowing. 
Q: Did Nike provide from time to time free clothing to you? 
A: I doubt it, but they could have. They could have, yes. 
Q: Next is Exhibit 20, depicting two pairs of socks. Are those your 
socks? 
A: I would have no way of knowing. 
Q: Did you own those socks in June of 1994? 
A: l have no way of knowing if they're my socks. How can I say if I 
owned them. 
Q: Next is Exhibit 21, a pair of Calvin Klein white underwear. Is that 
yours? 
A: I have no way of knowing. 
Q: Did you own that in June of 1994? 
A: I have no way of knowing if they're mine, so I wouldn't know if I 
owned them. 
Q: Did you bring any of these items with you to Mr. Kardashian's house 
during the week of June 14th, 1994? 
A: I have no way of knowing. 
Q: Did you bring these items -- did you put all of these items into your 
black bag in June of 1994? 
A: I have no way of knowing. 
Q: You don't remember? 
A: I don't know if those are my items, so I can't recall if I put them 
in this black bag or not. 
Q: Did you bring these items into the Bronco with you when you went on 
the trip to Nicole? 
A: I have no way of knowing. 
Q: Were they in the Bronco with you? 
A: I have no way of knowing. 
Q: You don't remember? 
A: No. 
Q: So if these items were recovered from your bag, you would have no 
way of saying that these are not now items. Is that right? 
A: Yes. That's correct. 
Q: And if they were obtained from the Bronco where you were lying down, 
you would have no way knowing that they're not your items. Correct? 
MR. BAKER: That's kind of a double negative. 
THE WITNESS: I don't get 
it. 
BY MR. PETROCELLI: 
Q: In other words, if these were found in or near your bag in the 
Bronco, you can't say that they're not your items. Correct? 
MR. BAKER: Wait a minute. If they were found in or near --  
MR. PETROCELLI: Yes. 
MR. BAKER -- his bag in the Bronco --  
MR. PETROCELLI: Yes. 
MR. BAKER: -- you can't say that they're your items, and I am going to 
instruct him not to answer based on the pictures because you can't tell 
from the pictures whether they're his, whether they're A.C.'s or 
someone else. 
MR. PETROCELLI: Who's talking about A.C.? He never mentioned A.C. Why 
did you mention A.C., Mr. Baker? 
MR. BAKER: My depo isn't being taken. 
MR. PETROCELLI: Exactly. That's my point. 
MR. BAKER: I don't care what your point is, and I'm trying to respond 
to your question. 
MR. PETROCELLI: My point is, stop trying to suggest answers. The 
witness can speak for himself. Just make an objection. 
MR. BAKER: Thank you very much. 
MR. PETROCELLI: Just make an objection, and we will move on. 
MR. BAKER: Well, thank you very much for your speech, and I really am 
not taking legal advice from you, so I will put anything on the record 
that I feel like I am going to, so you --  
MR. PETROCELLI: You know better than that, Mr. Baker. 
MR. BAKER: Don't tell me what I know and what I don't know --  
MR. PETROCELLI: Then don't testify. 
MR. BAKER: -- in court telling me what the state of mind of my client was, 
and if you knew, you probably had some conversations with him in 
violation of the Code of Professional Conduct. So don't give me that 
nonsense. I'm --  
MR. PETROCELLI: Are you finished? 
MR. BAKER: -- not going to put up with it. 
MR. PETROCELLI: Are you finished? 
MR. BAKER: I'm finished for now, but I'll put anything on the record I 
want. 
BY MR. PETROCELLI: 
Q: Okay. You put those items in the Bronco? 
A: I have no way of knowing. 
Q: You deny doing it? 
MR. BAKER: Don't answer that. He's answered the question, and he is not 
going to answer that. That's argumentative. Don't answer it. 
BY MR. PETROCELLI: 
Q: You don't know what clothes you own, Mr. Simpson? 
MR. BAKER: Don't answer that question. 
MR. PETROCELLI: Why not? 
MR. BAKER: Because you are arguing. 
MR. PETROCELLI: I am not arguing. 
MR. BAKER: No. You put photographs that are unidentifiable, and now you 
try to make a quantum leap, and I am not going to let him answer. 
BY MR. PETROCELLI: 
Q: In June of 1994 you were familiar with the clothing that you owned. 
Correct? 
A: To the most part, yes. 
Q: And did you put any of the items that I showed you into the Bronco? 
A: I don't know if those are any of my items. 
Q: Did you put them in the Bronco? 
A: I don't know if they were any of my items. 
MR. BAKER: Don't answer it, O.J. 
MR. PETROCELLI: Excuse me? 
MR. BAKER: Don't answer the question. 
BY MR. PETROCELLI: 
Q: Did you -- before you left of the house on the 17th, did you put 
anything into the bag? 
A: Yes. 
Q: What did you put? 
A: I believe I took a picture. One of the pictures was out, and I put 
it in the bag. 
Q: Did you put any clothing in there? 
A: On that day, no. 
Q: Did anybody do that for you? 
A: No. 
Q: I will represent to you that those items that I showed you were all 
items recovered from the Bronco. Do you have any way of disputing that? 
MR. BAKER: Don't. He has asked and answered that, and we are not going -- 
 -- 
BY MR. PETROCELLI: 
Q: Do you know for a fact that that's not true, that they were not in 
the Bronco? 
MR. BAKER: Don't answer that question. 
MR. PETROCELLI: He can answer that question. 
MR. BAKER: I told him he couldn't. Don't give my client legal advice. 
MR. PETROCELLI: What is the objection? 
MR. BAKER: The advice is it's asked and answered and it's 
argumentative, and I'm not going to let him answer it. 
MR. PETROCELLI: It's argumentative? 
MR. BAKER: You've been through this five times --  
MR. PETROCELLI: I am not getting a clear answer. 
MR. BAKER: Maybe that's your impression. I think you are getting very 
clear answers. He is not going to answer it. 
BY MR. PETROCELLI: 
Q: Do you know for a fact that those items were not in the Bronco? 
MR. BAKER: Don't answer that. 
MR. PETROCELLI: On what ground? 
MR. BAKER: I am not going to  -- You've gone through that. I am not going 
to allow you --  
MR. PETROCELLI: You are not even going to state your objections? 
MR. BAKER: No, I'm not. 
MR. PETROCELLI: Okay. Well, we will just have to let the judge --  
MR. BAKER: I think you should. 
MR. PETROCELLI: -- take a look at these objections. 
MR. BAKER: I think you should. 
BY MR. PETROCELLI: 
Q: Identify every item that you know was in the black bag when you took 
it into the Bronco when you left Kardashian's house on the 17th. 
A: I believe three pictures, a gun, whatever underwear and stuff I may 
have had in there when I left Rockingham earlier in the week --  
Q: By "stuff," what do you mean? 
A: Maybe socks, underwear. underapparel. 
Q: Any other articles of clothing? 
A: Maybe-under-apparel. I don't think anything else could fit in there 
with the gun and the three pictures. 
Q: Anything else? 
A: Credit cards, keys, watches. The only reason I know that is I saw 
some kind of property list, but other than that, I don't know. 
Q: What keys were in there? 
A: I don't know. 
Q: You have no idea? 
A: Uh-uh. No. I'm sorry. 0: I would like to talk a little bit about the 
examination conducted on the 17th of June by Drs. Huizenga, Lee and 
Baden. You testified about that yesterday. 
A: Yes. 
Q: And they took some photographs? 
A: I believe so. 
Q: Can you tell me, what were they saying to you at that time? 
A: I don't recall. 
Q: You don't have any recollection at all? 
A: Not at all. 
Q: Do you know why they were examining you? 
MR. BAKER: And exclude any conversations that you had with your lawyers 
about that incident, about them being there. 
BY MR. PETROCELLI: 
Q: Were lawyers there with them. 
A: I believe Shapiro was there. 
Q: While they were examining you? 
A: And Bob Kardashian. 
Q: While they were examining you? 
A: I believe so. 
Q: Can you remember what was said? 
A: No. 
Q: Do you know why they were examining you? 
MR. BAKER: Again, exclude any conversations that you had with your 
lawyers relative to the reason for their examination. 
THE WITNESS: No, 
not really. 
BY MR. PETROCELLI: 
Q: Paula Barbieri was there also. Right? 
A: I believe she was in the house, yes. 
Q: And Denise Halicki. Right? 
A: I believe they were in the house. 
Q: Cowlings, too. Right? 
A: I don't know. 
Q: Now, was that the first time you had been examined by any doctor 
that week? 
A: No. 
Q: What other examinations occurred that week? 
A: Dr. Huizenga examined me. 
Q: Now, where did Huizenga examine you? 
A: In his office. 
Q: Where is his office? 
A: In Beverly Hills. 
Q: Who else was present, if anyone? 
A: I believe my lawyers were. I'm not sure of this, but I believe my 
lawyers, Kardashian and Shapiro, were. 
Q: Kardashian, Shapiro and Huizenga? 
A: I believe. 
Q: Anybody else? 
A: I don't recall. 
Q: What happened at that examination? 
A: I got examined. 
Q: They checked every part of your body? 
A: I believe so. 
Q: And did they take photographs? 
A: I don't recall. 
Q: Did they find any injuries? Any injury marks? 
MR. BAKER: You mean from his past? MR.PETROCELLI: No. 
MR. BAKER: From his past operations? 
MR. PETROCELLI: Whatever. 
MR. BAKER: What do you mean, "whatever?" Don't answer that question. 
BY MR. PETROCELLI: 
Q: Any injury marks. Did they find any injury marks on your body? 
A: I don't recall. Whatever they examined, they examined. 
Q: You don't recall? 
A: I don't recall. 
Q: Let's go to the 17th for a second. Did the doctors then find any 
injury marks on your body? 
A: I don't recall. Whatever's on my body, I guess they found. 
Q: What injury marks did you have on your body on the 17th of June? 
MR. BAKER: If any. 
BY MR. PETROCELLI: 
Q: If any. 
A: You have to be a little more specific. 
Q: In what way? 
A:: What injuries. I mean, okay, they found that I have a bad left 
knee --  
Q: Marks. 
A: -- from knee surgery, I have scars on my knee. Whatever I had, 
whatever was on my body, they found. 
Q: What do you know that was on your body on the 17th of June? What 
marks? 
MR. BAKER: If you have -- Are you talking about his scars? Because you 
went through this all yesterday. 
MR. PETROCELLI: 
Q: I want to know specifically what marks that you had on your body, 
injury marks, bruises, cuts, whatever, on the 17th of June. 
MR. BAKER: I don't know what an injury mark is. He will answer the 
question bruises and cuts if he has any recollection. In other words, 
if you --  
THE WITNESS: I'm not trying to be difficult. I don't 
understand what you mean here. I truly don't. 
BY MR. PETROCELLI: What cuts, what bruises, what --  
A: You mean like recent cuts, open cuts, old cuts? 
A: Including those, yes. 
A: Whatever they looked at. I got so many scars and bruises and old 
cuts on my body. Whatever was on my body. I didn't go with -- you know, I 
was in space, I guess. Whatever was on my body, they found. 
Q: Did you have any open cuts on your body on the 17th of June? 
A: l don't know about open, no. 
Q: Did you have any recent cuts on your body on the 17th of June? 
A: On my finger I had a recent cut. 
Q: Where on your finger? 
A: On my left hand on my -- I don't know what you would call this finger 
(Indicating). 
MR. BAKER: Ring finger? 
THE WITNESS: No. Actually my middle finger on 
my left hand. 
BY MR. PETROCELLI: 
Q: On the 17th of June you had a recent cut on the middle finger of 
your left hand? 
A: I would say five-day recent, possible. 
Q: And did you have any other cuts on your body, other than the one on 
your finger that you just mentioned, on the 17th of June? 
A: I still, once again, I don't know. 1 don't know. 
Q: You don't know? 
A: No. I don't know how to answer that. I got cuts, as you can see, all 
over my body, and I -- that's what I have. My body is -- I've been in a lot 
of games --  
Q: Let's talk --  
A:  -- and I received a lot of injuries. 
MR. BAKER: Let him finish. 
BY MR. PETROCELLI: 
Q: Okay. I want to know about cuts that you had on your body on the 
17th of June when the doctors were examining you that had been caused 
within the previous seven days. 
MR. BAKER: So is there a question in there? 
MR. PETROCELLI: Yes. 
MR. BAKER: Regardless of what you want to know? 
MR. PETROCELLI: Yes. 
MR. BAKER: Where is the question? 
BY MR. PETROCELLI: 
Q: I want to know what those cuts were. 
MR. BAKER: Then ask him a question. 
MR. PETROCELLI: I just did. 
MR. BAKER: You didn't. You told him what you wanted to know. 
BY MR. PETROCELLI: 
Q: Describe it to me. 
MR. BAKER: Describe any recent cuts that you had that were of five 
days' duration or less. 
THE WITNESS: The only one that I was aware of --  
MR. PETROCELLI: I said seven days. 
THE WITNESS: The only one I was 
aware of is the middle finger one. 
BY MR. PETROCELLI: 
Q: One cut on the middle finger. 
A: That was the only one I was aware of, yes. 
Q: On the 17th. 
A: Yes. 
Q: You were aware of no other cuts. Correct? 
A: I wasn't aware of any cuts, no. 
Q: Were you aware of any abrasions on the 17th of June? 
A: On the 17th of June. I have trouble differentiating what I was aware 
of on the 17th that I found out after the 17th, so on the 17th I can't 
tell you what I was aware of. 
Q: What did you find out after the 17th? 
A: That I had other -- on this side of my finger (Indicating) I had an 
abrasion. 
Q: On the --  
A: On the finger next to the ring finger. And then --  
MR. KELLY: Could we have a description of the finger? 
MR. PETROCELLI: One second. 
Q: You just pointed to the ring finger. Correct? 
A: Yes, I believe so. 
Q: Ring finger being the one next to your pinkie. 
A: Uh-huh. 
Q: And you had an abrasion on the 17th of June on that ring finger. Is 
that correct? 
A: I don't know. As I said, I became  -- in sitting in that court looking 
at evidence, they talked about those things. 
Q: Your doctors did? 
A: On the stand, yes. 
Q: Drs. Huizenga and who? 
A: I don't recall. I'm pretty sure Dr. Huizenga did. 
Q: And they identified an abrasion on your ring finger. 
A: Yes. 
Q: On your left hand. 
A: I may be not characterizing it right when I said I had an abrasion. 
Q: Prior to the time they identified it in court, did you know that you 
had had that abrasion? 
MR. BAKER: Do you have any recollection of having that abrasion? THE 
WITNESS: Not really, no. 
BY MR. PETROCELLI: 
Q: Did you tell the doctors on the 17th of any recent cuts or abrasions 
that you had received or injuries that you had received in the last 
seven days prior to the examination? 
A: I don't recall 
Q: Let's go back to the 15th, the Huizenga -- was that at his office? 
A: Yes. 
Q: Where is his office? 
A: In Beverly Hills somewhere. 
Q: Did he take pictures? 
A: I don't recall. 
Q: Did anyone take pictures? 
A: I don't recall. 
Q: What cuts within the previous five days did you have as of the 15th 
of June that you can now remember? 
A: The one on my middle finger; I know that. And maybe the abrasion, I 
may have had it then or by then. 
Q: Any others? 
A: Not that I recall. 
Q: Do you remember telling the doctors about any cuts or bruises or 
abrasions you sustained within the prior five days, on the 15th of 
June? 
A: I think I talked about this middle finger cut, yes. 
Q: Did you talk about anything else? 
A: Not that I recall. 
Q: Did the doctors on the 15th ask you how you got that? 
A: I don't recall. 
Q: Did they ask you on the 17th how you got that? 
A: I don't recall. 
MR. BREWER: Mr. Petrocelli, for the record, I would like to describe 
what the witness is pointing to twice with respect to those cuts. He 
has referred to something as an abrasion on his left middle -- left ring 
finger, and actually what he has done -- correct me if I'm wrong, Mr. 
Simpson -- is you were motioning to the medial aspect of that finger --  

THE WITNESS: Yes. 
MR. BREWER: -- inside of the finger, back and forth. Is that a more 
specific description or location of that abrasion? 
THE WITNESS: I 
believe so. 
MR. BREWER: And then the other description, you have rubbed on the 
middle finger of your left hand where the knuckle area is to describe a 
cut. Is that an accurate description of where that cut was located? THE 
WITNESS: That is correct. 
MR. BAKER: Where the joint is. He wasn't describing the knuckle. 
MR. KELLY: Excuse me. Can we go off the record for a moment? 
MR. PETROCELLI: Off the record. THE VIDEOGRAPHER: This is the end of 
tape No. 1 of Volume II. The time is approximately 11:40, and we are 
off the record. (Discussion held off the record.) THE VIDEOGRAPHER: We 
are on the record. The time is approximately 11:43. This is the 
beginning of tape No. 2 of Volume II. 
MR. BAKER: Let me just correct what Michael Brewer said, because I 
think he mentioned the knuckle of O.J. Simpson's middle finger of his 
left hand, and we were talking about the joint that he was rubbing. 
MR. BREWER: That's correct, Mr. Simpson? 
THE WITNESS: That's correct, 
yes. 
BY MR. PETROCELLI: 
Q: When you were examined by Dr. Huizenga on the 15th of June, had any 
recent cuts or abrasions or wounds that you may have received been 
fully healed by the 15th of June? 
A: I don't believe so, but I'm not sure. You'd have to ask the doctor. 
Q: What did you tell the doctor on the 15th as to how the cut on the 
middle finger was caused? 
MR. BAKER: If you told him anything. 
THE WITNESS: I don't recall if we 
talked about it, but we may have. We may have. I don't recall. 
BY MR. PETROCELLI: 
Q: What did you say? 
MR. BAKER: There is no foundation for that question if he doesn't 
recall 
BY MR. PETROCELLI: 
Q: you don't recall what he said? 
A: No. 
MR. BAKER: He doesn't recall even talking about it. 
BY MR. PETROCELLI: 
Q: I thought you said earlier that you discussed how that injury was 
caused. 
A: I may have, but I don't -- I may have, yes. 
Q: What did you say? 
A: I don't know if I did. 
Q: And you can't recall. Right? 
A: I must have, but I don't recall. I don't recall any specific 
conversation. 
Q: Do you recall on the 17th any discussion as to how you were cut? 
A: Not at all. 
Q: And how did you suffer the cut on the middle finger? 
A: I broke a glass when I was in Chicago, and in the process of 
cleaning it up I evidently cut my finger. 
MR. KELLY: I couldn't hear that. I'm sorry, Mr. Simpson. THE Witness: I 
said, in the process of cleaning -- not cleaning it up, but scooping it 
up, I evidently cut my finger. 
BY MR. PETROCELLI: 
Q: Did you remember cutting your finger? 
A: I remember bleeding. 
Q: Do you remember cutting your middle finger on --  
A: I remember bleeding and seeing that I was bleeding, so... 
Q: This was on the morning of June 13, 1994? 
A: Yes. 
Q: At your hotel in Chicago? 
A: Yes. 
Q: Name of that hotel? 
A: I don't remember. 
Q: And exactly how did you cut it with the glass? 
A: I was trying to scoop the glass into the sink with some toilet paper 
and I believe a towel. 
Q: You were at the sink of the hotel room? 
A: Yes. 
Q: In the bathroom. 
A: Yes. 
Q: What were you doing there at that time? 
A: I don't know. I was going back and forth to the phone. I was trying 
to pack. I was trying to brush my teeth. I was in and out of the 
bathroom. 
Q: And at some point you did something to a glass? 
A: Yes. 
Q: A drinking glass? 
A: Yes. 
Q: Was it like the glass next to you to your right? 
A: Yeah, a drinking glass. 
Q: About that tall (Indicating)? 
A: I don't know. 
Q: And did it have anything in it? 
A: I don't recall. 
Q: Can you show that glass on camera? Because I referred to it for the 
record. (Witness complies.) 
Q: Was it a glass about that size? 
A: I don't recall. 
Q: And the glass was sitting where? 
A: On the counter in the bathroom. 
Q: Upright or upside down? 
A: I believe I had my toothbrush set in there. 
Q: And was there anything else in the glass besides your toothbrush? 
A: I don't recall. 
Q: Had you already used your toothbrush? 
A: l don't recall. 
Q: When did you put the toothbrush in the glass? 
A: Probably the night before. 
Q: When you got into the hotel? 
A: Yeah. 
Q: So you got to the hotel and you unpacked? 
A: Yeah. 
Q: You took out your toiletries? 
A: Yes. 
Q: And took your toothbrush out and put it in the glass? 
A: I believe so. 
Q: Did you use that glass at any point before the time you hit it? 
A: I don't recall. 
Q: You don't remember? 
A: No. 
Q: And tell me exactly how you cut your hand on that glass with the 
toothbrush in it on the counter and the sink. 
A: I don't believe that's correct, what you just said. 
Q: It was on the sink counter in the bathroom. Right? 
A: Yes. 
Q: And the toothbrush was in it. Right? 
A: Not when it broke, it wasn't. And I don't even know if the 
toothbrush was in it. I believe there were two glasses, and I just 
don't recall. 
Q: One with your toothbrush in it? 
A: I'm pretty sure. Normally when I check into a hotel, I'll put my 
toothbrush in a glass, so I'm assuming that I did --  
Q: And the other glass --  
MR. BAKER: You've got to wait until he finishes. 
MR. PETROCELLI: I am sorry, Mr. Baker. I'm jumping the gun a little 
bit. 
Q: Are you finished? 
A: Yes. 
Q: The other glass did not have a toothbrush in it? 
A: I don't believe so. I only had one toothbrush, and if I put it in, I 
would have only used one glass. 
Q: Were both glasses about the same size as the one you just showed on 
the video? 
A: I don't really recall. 
Q: And they were both standing or sitting on the countertop next to one 
another? 
A: I don't recall. 
Q: Was there anything underneath the glasses, like a towel or a napkin? 
A: I don't recall. 
Q: And describe what you did to break the glass and cut yourself. 
A: I don't really know. 
Q: You said something about your palm of your hand? What did you say 
before? 
A: I didn't say anything about breaking the glass at all. You didn't 
ask me about breaking the glass. 
Q: How did you cut your finger? 
A: Cleaning up the broken glass. 
Q: How did the glass get broken? 
A: I don't know. I was -- I don't know. I was out of it, and I was doing 
a few things and the glass broke, and I was going back and forth to the 
phone, and maybe I slammed it down. Maybe I knocked it over. I really 
don't know. 
Q: You are saying you do not know how the glass broke. Is that right? 
A: Yes. 
Q: And at some point you saw that there was a broken glass. Correct? 
A: No. At some point I was trying to get my toiletries together. 
Q: And you saw there was broken glass around. Correct? 
A: Yes. 
Q: And where was the broken glass, Mr. Simpson? 
A: Mostly on the counter, and I think one big piece was on the floor. 
Q: And was any of it in the sink? 
A: I don't know. Probably some of it. Maybe. I don't know. 
Q: And you then went to pick up the piece on the floor? 
A: I was going back and forth to the telephone, and I was trying to 
pack, and I was trying to get it out of my way as I was packing. 
Q: And you saw the broken glass, and you wanted to get it out of the 
way. Correct? 
A: Correct. 
Q: Were you on the phone at the time this was happening? 
A: I was going back and forth to the phone, So I can't tell you 
exactly. I wasn't really, you know, trying to remember everything I was 
doing at that time, so... 
Q: I am trying to focus on the point in time when you saw the glass. 
Okay? 
MR. BAKER: What do you mean, "when you saw the glass?" 
BY MR. PETROCELLI: 
Q: When you saw that there was broken glass on the --  
A: At some point after I was told that my wife was dead -- or that Nicole 
was dead, I broke the glass. In the process of going back and forth to 
the phone and trying to get packed, I cut myself trying to move the 
glass out of my way. Somewhere in that, that happened. 
Q: Now, how did you break the glass? 
A: I don't know. I think I answered that already. I don't know 
Q: You said -- But you do remember breaking the glass. Right? 
A: I remember the glass was broke, yes. 
Q: But you don't know how you broke it? 
A: No. 
Q: But you are confident you broke it? 
A: Yes. 
Q: And when you broke it, where was the glass? 
A: In the bathroom. 
Q: You went into the bathroom and then, while you can't remember how, 
broke the glass. 
A: Yes. 
Q: Correct? 
A: Yes. 
Q: Why did you break the glass? 
A: I had no purpose in breaking the glass. 
Q: Did you break one glass or two glasses? 
A: I believe it was one. 
Q: Did you throw the glass? 
A: I don't recall. 
Q: Did you squeeze it? 
A: I doubt that, but I don't recall. 
Q: When you broke the glass, were you on the phone? 
A: I don't recall. 
Q: Did you break the glass after you got off the phone? 
A: I don't recall. 
Q: Did you break the glass during the conversation when the detective 
told you that Nicole had been killed? 
A: No. 
Q: What phone was it that you were using? 
A: The phone by the bed. 
Q: Was that the only phone in the room? 
A: I don't know. 
Q: Was there a phone in the bathroom 
A: I don't know. 
Q: Did you use your cell phone in that room. 
A: No. 
Q: Immediately after you broke the glass, you then began -- what was your 
next movement? 
A: I don't know. As I told you, I was going back and forth to the 
phone. Sometimes they had me on hold, sometimes various people I was 
talking about was trying to find me a flight, and I was just going back 
151 and forth trying to pack, and that's --  
Q: After --  
A: -- and in the midst of all of that this glass broke, and in the midst 
of all of that I was cleaning up the glass, and in the midst of all of 
that all of this happened. 
Q: After the detective told you Nicole had been killed --  
A: No. 
Q: did you make another phone call before you broke the glass? 
A: I don't recall. 
Q: Do you believe you were on hold when you went to the bathroom and 
broke the glass? 
A: I don't know. 
Q: Are you confident that you broke the glass while it was in the 
bathroom. 
A: Yes. 
Q: Right after you broke the glass, did you pick up the pieces? 
A: I don't recall. 
Q: You don't know when you picked up the pieces? 
A: Someone in the midst of all of that, trying to pack a bunch of 
toiletries, I did. 
Q: And what is the length of time that that process took? 
A: Well, from the time --  
MR. BAKER: What process are we talking about? 
MR. PETROCELLI: After he found out about the -- Nicole's death and then 
he was packing and rushing around and --  
MR. BAKER: Making phone calls? 
MR. PETROCELLI:  -- making phone calls. 
Q: That whole process, how long did that take? 
A: From the time the police told me to the time I was actually at 
Chicago O'Hare Airport on the plane was about 60 minutes. So I must 
have been on five, six, seven phone calls, packed, checked out of the 
hotel, got a ride to the airport and got on the plane in 65 minutes, 
so -- or in something roughly that long, so obviously a lot was going on. 
Q: How long were you in the hotel room after the call from the 
detective about your ex-wife's death? 
A: I don't know. 
Q: More than 20 minutes? 
A: I would think so, yes. 
Q: Half hour? 
A: Possibly. 
Q: Longer? 
A: I don't know. 
Q: When you picked up the glass -- Withdrawn. When you broke the glass, 
did it cause a cut at that time? 
A: I don't believe so, no. 
Q: And do you know where the glass struck your body? 
A: I don't know if it ever struck my body. 
Q: Your hand. 
A: No. 
Q: Do you know even if you used your left hand to break the glass? 
A: No. 
Q: You don't know which hand you used? 
A: No. 
Q: Did you throw it against the wall? 
A: No. I don't recall. 
Q: Did you throw the glass in the sink? 
A: I don't believe so. 
Q: Did you slam the glass down on the table -- on the -- I'm sorry -- on the 
counter? 
A: Possibly. 
Q: Picked it up and then slammed it down. Is that your best 
recollection of how you broke the glass? 
A: No, I didn't say that. I said that was a possibility. 
Q: You say it's a "possibility." Does that sound like what happened? 
A: That's a possibility. 
Q: Are there any other possibilities that you know of? 
A: Obviously a myriad of possibilities. 
Q: Do any come to mind besides slamming the glass down on the counter? 
A: I may have knocked it over. I may have hit it with my bag that I use 
to pack. 
Q: Do you believe --  
A: I mean my bag that I have my things in. I don't know. I know when I -- 
 -- I don't know. I was sort of out of it at the time. 
Q: Did you break the glass accidentally? 
A: Yeah. I believe so, yes. 
Q: In other words, you were not intending to break the glass. Correct? 
A: I had no intentions of anything but getting out of there and getting 
home. 
Q: Were you attempting to break the glass? 
A: No. 
Q: You cut yourself when you picked up the pieces of the glass. 
Correct? 
A: I never -- I picked up maybe a piece off the floor. I'm not sure. But 
I didn't pick up the other pieces, no. 
Q: You picked up a single piece from the floor? 
A: I believe so, yes. 
Q: The floor of what? 
A: The bathroom. 
Q: Were you wearing shoes at the time? 
A: I don't know. 
Q: How were you dressed when the officer called? 
A: I was in bed. 
Q: How were you dressed? 
A: Probably naked. 
Q: Did you put any clothes on before you broke the glass? 
A: I don't recall. 
Q: Did you put any clothes on before you picked up the piece from the 
floor? 
A: I don't recall. 
Q: Did you put on any clothing before you began to pack up the items in 
the bathroom? 
A: Probably. 
Q: What clothes did you have on when you went into the bathroom to pick 
up the glass? 
A: Pardon me? 
Q: What clothes did you have on when you went into the bathroom to pick 
up the glass from the floor? 
A: I don't recall. 
Q: And what did you use, if anything, to pick up the glass? 
A: I didn't pick up the glass. 
Q: The glass piece on the floor. 
A: Probably my hand. 
Q: Did you have anything in your hand, like a towel or a napkin? 
A: I don't recall. 
Q: Which hand did you use to pick up the broken piece of glass? 
A: I don't remember. 
Q: When you picked it up, did you cut yourself? 
A: I don't think so, no. 
Q: So as of this point in time, your finger -- your middle finger on your 
left hand was not cut. Correct? 
A: I believe so, yes. 
Q: Is that correct? 
A: I believe so, yes. 
Q: When you picked up the piece of  -- There were no other cuts on your 
left hand at that time either. Correct? 
A: Correct. 
Q: And when you picked up the piece of glass --  
A: Not that I know of, I should say. 
Q: When you picked up the piece of glass, what did you do with it? 
A: Put it in the sink. 
Q: And were there any other pieces in the sink at that time? 
A: I don't know. 
Q: Did you cut yourself at all putting it into the sink? 
A: No. 
Q: And did you then -- what did you do after you put the piece of glass 
in the sink? 
A: I don't recall. 
Q: Did you clean up any other pieces of glass? 
A: Eventually or at some point. yes. 
Q: Later on in the process of packing? 
A: And talking on the phone and getting dressed, yes. 
Q: When you say "and talking on the phone," you intermittently would be 
going back from the bathroom to the bedroom, make phone calls and go 
back in the bathroom. 
A: Yes. 
Q: How many items did you have in the bathroom? 
A: Whatever my toiletries were. 
Q: They all come in what, a little travel bag? 
A: Yes. 
Q: And how many items had you taken out of that travel bag the night 
before? 
A: Whatever was in it. 
Q: What was in it? 
A: Shaving cream, toothpaste, toothbrush, mouthwash, probably my 
medication. I'd say a razor blade, I guess, underarm deodorant. 
Whatever was in it. 
Q: Anything else you remember? 
A: Not that I recall right now. 
Q: What medication? 
A: Motrin. And vitamins. I always have my vitamins, Vitamin E, Vitamin 
C, sometimes, yes. 
Q: You laid all those things out on the bathroom counter the night 
before  --  
A: Yeah, probably. 
Q:  -- or right before you went to bed. Right? 
A: Yes. 
Q: Was there anything else you unpacked and put in the bathroom. 
A: Not that I recall. 
Q: And when you say you packed up the items in the bathroom, you are 
now referring to the -- you are referring to the items that you had taken 
out of the travel bag. Right? 
A: That's correct. 
Q: You put them back in the travel bag. Right? 
A: Yes. 
Q: Did you shave that morning? 
A: I don't believe so. 
Q: Did you take a shower? 
A: I may have. I don't believe so. 
Q: You don't believe you did? 
A: I was trying to get out of there, so I don't -- I really can't imagine 
taking a shower. 
Q: Did you wash your face? 
A: I'm sure I did, yes. 
Q: Did you brush your teeth? 
A: Yeah, I'm sure I did. 
Q: Did you use the underarm deodorant? 
A: I don't know. 
Q: Did you use any cologne or aftershave? 
A: I don't know. 
Q: Did you take any medication that morning? 
A: I probably took my Motrin at some point. Maybe not then, but at some 
point. 
Q: Did you take it with water? 
A: Probably I took it -- I try to take it with food, so I probably took 
it on the plane. 
Q: Did you eat anything in the hotel room? 
A: No. 
Q: Did you drink anything? 
A: Other than water, and I may have not drank water. I don't know. I 
really don't. 
Q: Do you remember drinking water? 
A: No. 
Q: Now, at what point in this process did you break -- did you cut your 
finger? 
A: Again? 
Q: Yes. 
A: Somewhere in between going back and forth to the phone, trying to 
pack, trying to get dressed, at some point in there I cut my finger. 
Q: And on what piece of glass -- Strike that. Did you cut it on one of the 
broken pieces of glass? 
A: Yeah. 
Q: On what piece? 
THE WITNESS: Can we take a break? 
MR. BAKER: Yeah, sure. 
THE WITNESS: Jesus Christ. THE VIDEOGRAPHER: We 
are going off the record now, and the time is approximately 12:02. 
(Recess.) THE VIDEOGRAPHER: We are back on the record now, and the time 
is approximately 12:11. 
BY MR. PETROCELLI: 
Q: We have had a nine-minute break. You requested a break, Mr. Simpson. 
Correct? 
A: Yes. 
Q: And you wanted to talk to your lawyers? 
A: No. 
Q: You requested the break because you were uncomfortable with the 
subject matter? 
A: No. 
MR. BAKER: You don't have to answer why you requested a break. You 
don't have to answer that. 
BY MR. PETROCELLI: 
Q: I am not asking about the content of your discussions. I am asking 
about your state of mind in the middle of the examination. 
MR. BAKER: His state of mind in the middle of examination is 
irrelevant, and I am going to instruct him not to answer. 
BY MR. PETROCELLI: 
Q: Did you talk to your lawyers during the break? 
A: Yes. 
Q: Why were you unable to continue with the examination? 
MR. BAKER: Don't answer that. That assumes that he was unable to 
continue with the examination. He is entitled to take a break. 
BY MR. PETROCELLI: 
Q: Why did you request a break during that part of the examination? 
MR. BAKER: Don't answer that either. 
MR. PETROCELLI: Excuse me? 
MR. BAKER: I said, "Don't answer that..." 
MR. PETROCELLI: He whispered something, Mr. Baker. 
THE WITNESS: No, I 
did not. 
BY MR. PETROCELLI: 
Q: You mouthed something. 
A: I think I'm allowed to mouth something to myself, aren't I? 
BY MR. PETROCELLI: 
Q: What did you mouth? 
MR. BAKER: You don't have to answer that either, Mr. Simpson. You are 
entitled to mouth things. And if you want to continue to try to badger 
the witness, I've heard that on "Perry Mason," and it's not a good 
thing. 
BY MR. PETROCELLI: 
Q: Do you want to tell us what you were mouthing? 
MR. BAKER: No, and don't tell him that either. That's not relevant to 
any issue in this case. 
BY MR. PETROCELLI: 
Q: Did you brush your teeth before or after you cut the glass? 
MR. BAKER: That's been asked and answered. 
MR. LEONARD: Cut the glass? 
MR. PETROCELLI: Excuse me. Withdrawn. 
Q: Did you brush your teeth before or after you broke the glass? 
A: I don't recall. 
Q: Did you brush your teeth before or after you picked up the glass? 
A: I don't recall. 
Q: What did you do to clean up the bathroom? 
MR. BAKER: Well, I don't know that he testified that he cleaned up the 
bathroom. 
BY MR. PETROCELLI: 
Q: What did you do to clean up the broken glass? 
A: Took some toilet paper and some towel and just -- I didn't really 
clean it up. I just tried to scoop it out of my way. 
Q: Toilet paper --  
A: Yes. 
Q: and a towel. 
A: I believe so, yes. 
Q: What did you do with the toilet paper? 
A: I don't know. Either -- I don't know. Some of it I know I had with me 
when I went to the lobby. 
Q: What did you do with the towel? 
A: I believe I left it in the room. 
Q: What I am trying to get to is this: You picked up some toilet paper 
and you picked up the towel for the purpose of scooping out of the way 
the glass. Is that what you're saying? 
A: Yeah, brushing out of the way the glass. 
Q: Now, is this after you picked up the piece of glass on the floor and 
put it in the sink? 
A: I'm pretty sure it is, yes. 
Q: So now the glass is in the sink, a chunk of glass. Correct? 
A: I'm pretty sure, yes. 
Q: And there are other shards or chunks of glass on the counter top? 
A: Yes. 
Q: And you wanted to get those glasses off the counter top. Correct? 
A: Actually I just wanted to put my stuff in my travel bag, and it was 
kind of around it, so... 
Q: You hadn't yet put the stuff in the travel bag? 
A: No. 
Q: You remember that distinctly? 
A: That's the only reason I took the time to sweep the stuff out of the 
way. 
Q: Did you remember that before the break? 
MR. BAKER: That's argument. Don't answer that question. 
BY MR. PETROCELLI: 
Q: So in trying to pick up the items and put them into the travel bag, 
you then went to the toilet paper holder and took a piece of toilet 
paper out? 
A: I believe so, yes. 
Q: And you put it in your hand? 
A: Yes. I probably wrapped it on my hand. 
Q: And then you also  -- Oh, you wrapped it around your fingers? 
A: No. I think I just took a ball of it and was using it, and then I 
probably used it --  
Q: Which hand? 
MR. BAKER: Just a minute. 
MR. PETROCELLI: I apologize. THE REPORTER: "Probably used it"? 
MR. BAKER: In a sweeping motion and probably used a towel, is what he 
said, if I recall. 
MR. PETROCELLI: Mr. Baker, in fairness to me, his voice is tailing off, 
and I'm not quite sure when he is finished with his statement. That's 
why I'm interjecting. 
MR. BAKER: Then you can wait for a moment, unless you believe that the 
staccato approach is what you have to do to get an answer, but I think 
that he is entitled to the courtesy of finishing his answer, and you 
are attempting to pepper him with questions and not allow it, and that 
is not appropriate. 
MR. PETROCELLI: I am not going to debate that with you. 
Q: Let's go back to the examination. You got the toilet paper, wrapped 
it around what hand, by the way? 
A: I don't know. I may have just balled it up. 
Q: Balled it up. 
A: Possibly, yes. 
Q: Are you right-handed or left-handed? 
A: Right-handed. 
Q: What hand did you put the toilet paper in? 
A: I really don't know. At some point it could have been in both hands. 
Q: You took two pieces of toilet paper and balled them up into both 
hands? 
A: No. 
Q: You took one piece, balled it up into one hand? 
A: I believe so, yes. 
Q: Which hand? 
A: It could have been both hands, as I answered. 
Q: Can you demonstrate what you mean by that? 
MR. BAKER: You don't have to demonstrate, Mr. Simpson. 
BY MR. PETROCELLI: 
Q: Could you show us what you mean? 
MR. BAKER: It's irrelevant whether he could. This is a question and 
answer. 
BY MR. PETROCELLI: 
Q: Will you show us? 
MR. BAKER: No, he won't. 
BY MR. PETROCELLI: 
Q: You will not show us? 
MR. BAKER: I indicated that he will not. 
MR. PETROCELLI: On what theory? 
MR. BAKER: Because he doesn't have to. This is not show-and-tell time. 
This is just tell time. 
BY MR. PETROCELLI: 
Q: You took a piece of -- single piece of toilet paper and put it into 
both hands at the same time. 
A: I don't think I've ever said that. 
Q: I am trying to find out what you're saying. 
MR. BAKER: Just say no. THE witness: No. 
BY MR. PETROCELLI: 
Q: Just describe what you did with the toilet paper as best and as 
clearly as you can so we can all understand. 
A: I believe I took some toilet paper and used it and then at one point 
probably grabbed a towel and used it. C: When you took the toilet paper 
and used it, you mean you put it in the palm of your hand, and then you 
used it to scrape off the glass? 
A: I believe so. I could have also -- I believe so. I'm not totally sure. 
I may have just -- I may have cut my finger when I was using the towel, 
and I just took the toilet paper and wrapped it around my finger. I'm 
not really sure as the sequence. My concern at that time was to get a 
flight out of Chicago, and I was going back and forth to the plane 
[sic]. 
Q: You are not sure then that you took the toilet paper to scoop the 
glass into the sink at all. 
A: I know I had toilet paper in my hand during that period of time, 
yes. 
Q: But you don't know whether you had it before or after you put the 
glass into the sink. 
A: That is correct. That is correct. Well, during the process of doing 
it, at what process of doing it, I don't know if I did it in the middle 
of it or in the end of it, but at some point I did. 
Q: You do also remember taking a towel. Correct? 
A: Yes. 
Q: A washcloth? 
A: I believe so. 
Q: What did you do with the washcloth? 
A: I'm pretty sure, as I answered before, that I left it in the room. 
Q: What did you do with the washcloth in reference to the glass? 
A: I'm sorry. I don't understand that. 
Q: Did you use the washcloth to scrape off the glass from the sink or 
to pick it up or to do anything with respect to the glass? 
A: I don't recall. 
Q: Did you have anything on your hands, either toilet paper or a 
washcloth, when you were scraping off the glass shards into the sink? 
A: At first I think I was just moving them, and then I grabbed some 
paper, toilet paper. I may have even been using one of my -- my bag thing 
at one point, but then I do know I grabbed toilet paper at one point 
and a towel at one point. So I do know during the course of it, going 
back and forth, I may have done it all. I wasn't concentrating on it. I 
was concentrating on getting a phone call or getting back to the phone 
and trying to get dressed, is what my mind was on at the time, not on 
how I was moving the glass. It really wasn't something I was paying a 
lot of attention to. 
Q: Why did you -- What was your purpose in going to the --  
MR. BREWER: Mr. Petrocelli, before you go on, the witness as he is 
answering you is making a motion with his left hand, with the back of 
his hand, like he's scraping the glass or moving the glass, just for 
the record. 
BY MR. PETROCELLI: 
Q: What was your purpose in using the toilet paper and the towel? 
A: I don't know. Either I had cut my hand or I was trying not to cut my 
hand, one or the other. 
Q: That's what I'm getting to: Was the toilet paper and the towel 
intended to address a cut that just occurred, or did you pick it up to 
use it to clean off the sink? 
A: Both. As I said, it was either one or the other. I really wasn't 
really paying much attention to it at the time. 
Q: When you cut yourself, did you have toilet paper on the hand that 
you cut? 
A: I don't think so. I don't think so, but... 
Q: When you cut yourself, did you have a towel in the hand that you 
cut? 
A: Possibly. 
Q: Where was the towel in the hand when you cut yourself? 
A: I don't know. 
Q: And how exactly with the towel in your hand did you cut yourself on 
the glass? 
A: I was trying to scrape whatever I had in my hand. I was trying to 
move it, and it happened. 
Q: Let the record reflect that you are demonstrating a sort of --  
A: Yes. 
Q:  -- a sweeping motion. 
A: Yes. 
Q: And did the glass come into contact with the back of your hand? The 
front of your hand? Where? 
A: I don't know. 
Q: Where did you cut yourself? 
A: On my knuckle. 
Q: Which knuckle? 
A: The middle knuckle of my left hand. 
Q: You cut yourself on the middle knuckle on the outside --  
A: Yes. 
Q: -- of your middle finger? 
A: Yes. 
Q: When you cut yourself, did you feel any pain? 
A: No. 
Q: And did you see that you were bleeding? 
A: I would assume so at one point. Obviously I did, yes. 
Q: No. At that point when you cut yourself, did you notice blood? 
A: If I didn't feel pain, I didn't know I cut myself. So at whatever 
point I saw blood, I assumed that I had cut myself. 
Q: When did you first see blood? 
A: When I was in the bathroom. 
Q: Did you see blood before you left the bathroom to go out to the 
phone area? 
A: Yes. 
Q: Did any blood drip off of your finger onto another surface? 
A: I would assume so. 
Q: Did you clean up any blood? 
A: When I wiped off the counter, I just pushed everything into the 
sink. 
Q: Including your blood? 
A: I don't recall that. 
Q: Do you remember using anything to clean off blood? 
A: Not particularly, no. 
Q: Did blood drip into the sink? 
A: I don't know. 
Q: You don't know? 
A: No. 
Q: Did blood drip on the floor? 
A: I don't recall. I wasn't trying to clean up the bathroom. 
Q: Did you wash out your cut? 
A: I believe -- I don't think I washed it off because I just put -- 
whatever I had on it, I put some more paper on it, and that's what I 
went downstairs with. 
Q: Did you put your cut under the water, cold water, hot water, 
whatever, to wash it out? 
A: I don't recall. 
Q: Did you keep the toilet paper on your finger from the moment you 
observed the cut until you left the room? 
A: I would pretty much think so. I may have added some to it yes. 
Q: And did you also keep a towel on the cut? 
A: Until I left the room --  
MR. BAKER: Wait a minute. "Keep a towel." He has never testified he put 
a towel on the cut. 
BY MR. PETROCELLI: 
Q: Did you put the towel on the cut? 
A: I don't recall. I may have. It may have been in my hand also when I 
was going back and forth to the phone. 
Q: Was the blood bleeding onto the towel? 
A: l would assume so. 
Q: Do you know so? 
A: No. 
Q: Did you see blood on the towel? 
A: I wasn't looking for blood. 
Q: I know. Did you see it, though? 
A: I don't recall seeing it, no. 
Q: Did you see blood on the toilet paper? 
A: Yes, plenty. 
Q: Lots of it? 
A: When I got downstairs and I unwrapped it to get -- to show the girl to 
get me a Band-Aid, yes. 
Q: Did you call down and ask for a Band-Aid or any first-aid when you 
saw the cut? 
A: I think from the time I cut my hand -- I'm not sure of this, but from 
the time I cut my hand to the time I got downstairs wasn't so very 
long, but, no, I wouldn't have waited. I was trying to get out of the 
room. 
Q: From the time you cut your hand, you completed packing up your items 
in the bathroom. Right? 
A: I don't know. 
Q: You put the rest of the stuff in the travel bag? 
A: I don't understand your question. 
Q: After you cut your hand and after you put the toilet paper around 
it, you then completed packing. Correct? 
A: Yes, at some point, yes. 
Q: Including packing up the items in the bathroom. Right? 
A: Yes. 
Q: You put everything into the travel bag and zippered it up and walked 
out of the bathroom. Is that right? 
A: I don't know if that's in that sequence, but eventually obviously I 
did, yes. I may have --  
Q: What are all the things you did before you left the room after you 
cut yourself and put the toilet paper around your finger? 
A: I don't know because I don't know at what point in time I had cut my 
finger. I was trying to get packed, as I told you. I was going back and 
forth to the telephone, as I told you. During the course of doing all 
of that, I cut my finger. At what point during all of that, I don't 
know. 
Q: When you left the hotel room, did you see any blood left behind? 
A: I didn't look for any blood left behind, so I wasn't really looking, 
no. 
Q: Did you see any? 
A: I don't recall seeing any, no. 
Q: Did you see any blood in the sheets of the bed? 
A: No, I don't recall seeing any, no. 
Q: Did you unpack your clothing when you got the room that evening? 
A: I hung up my suit, yes. 
Q: How many bags did you bring into the hotel room besides your travel 
bag? 
A: Bag? 
Q: Excuse me. Besides the little bathroom bag, how many other items of 
luggage did you bring into the hotel room with you? 
MR. BAKER: Well, that assumes the bathroom bag was a separate piece of 
luggage and not in the grip, which is not what he's testified to. So 
don't answer that question. 
BY MR. PETROCELLI: 
Q: Are you saying that the items of toiletry that you described were 
carried in your grip? 
A: Are you asking me that question? 
Q: I'm asking that question now. 
A: Yes. 
Q: There wasn't a separate little bag for the shaver and the deodorant; 
it was all in the grip? 
MR. BAKER: He has testified to you that your question -- my objection was 
your question assumed that the toiletry bag was outside of the grip 
when he brought it into the room. That was my objection. 
MR. PETROCELLI: Let me see if I understand this. 
Q: You had toiletries in a separate toiletry bag which itself was in 
the black grip bag. Correct? 
A: That's correct. 
Q: And when you brought the toiletries into the bathroom to unpack 
right before you went to bed, as you previously described, did you 
bring just the toiletry bag or the whole grip bag into the bathroom? 
A: Probably just the toiletry bag. Probably just the toiletry bag. 
Q: So you left the grip bag in the bedroom. Correct? 
A: More than likely, yes. 
Q: So when you finished packing after you cut your finger, you took the 
toiletry bag and put it in the grip bag. Right? 
A: That's correct. 
Q: What other items of luggage besides the toiletry and grip bag did 
you have in that room with you? 
A: What other -- I'm sorry. 
Q: Items of luggage. 
A: Of luggage. 
Q: Yes. 
A: Louis Vuitton bag. 
Q: Is that a garment bag? 
A: Yeah. It's a suitcase. 
Q: Suitcase or one of those --  
A: Fold-over suitcase. 
Q: Fold-over. 
A: Yeah. 
Q: Louis Vuitton? 
A: Uh-huh. 
Q: You have to answer audibly. 
A: Didn't I say "Louis Vuitton bag"? 
Q: You said "uh-huh." You have to answer yes or no. 
A: Yes. 
Q: And what else? 
A: A suit bag. 
Q: A different suit bag than the Louis Vuitton bag? 
A: That's correct. 
Q: And what else? 
A: That's all I recall. 
Q: So two suit bags, one grip, and in the grip bag a toiletry bag 
A: Yes. 
Q: Anything else? 
A: That's all I recall. 
Q: What about your golf bag? 
A: I never took them out of -- the guy who brought me there, I never took 
them out of his car, since he was going to take them to the golf course 
and put them on the golf cart and lay all of my stuff out. 
Q: So the golf bag never made it to your hotel room. Correct? 
A: That's correct. 
Q: Where exactly -- Withdrawn What other unpacking did you do when you 
got to the hotel room besides take out the toiletry bag from the grip 
bag and hang up your clothing that you were wearing? 
A: I hung up what I was going to wear to play golf the next day --  
Q: Was that a different set of clothing than you wore to the hotel that 
night? 
A: Yes. 
Q: You took those clothes out. Correct? 
A: Yes. 
Q: What were they? 
A: Golf clothes. 
Q: Shirt and pants? 
A: Shirt and pants, yeah. 
Q: Shoes? 
A: I'm sure my shoes was with my golf bag. 
Q: Which bag were the shirt and pants in that you took out? 
A: In my Louis Vuitton bag. 
Q: Did you do any other unpacking? 
A: Unpacking. There was nothing else to unpack. I took a book out of my 
thing. I may have looked at my travel thing again to see what the times 
were. 
Q: When you said, "There was nothing else to unpack," there were other 
items in these two suitcases. 
A: Yes. 
Q: Correct? 
A: Yes. 
Q: What were they? 
A: Golf clothes, underwear, socks, maybe a pair of dress shoes. I'm not 
sure of that. 
Q: More golf clothes, you mean? 
A: Another golf outfit, yes. 
Q: And other attire as well? 
A: I don't think so. 
Q: How long were you planning to be gone? 
A: One or two days. 
Q: It was not determined yet? 
A: If I would have found another golf game, since I had nothing to do 
Tuesday, I would have -- that's why I brought the other golf outfit: So -- 
which I do often, is -- and if I saw Mike Ditka, I'd see if he wanted to 
play at his club. But, yeah, quite often I go to a tournament. If I 
have nothing to do and somebody got a good golf course to play, I'll 
stay and play golf. 
Q: So in the two suitcases you had two golf changes of clothing. 
Correct? 
A: No, that's not correct. 
Q: What did you have? 
A: I didn't have two suitcases. 
Q: You had the Louis Vuitton bag and another bag, you said, another 
suitcase. 
A: No, I didn't say that at all. 
Q: You told me that you had a Louis Vuitton fold-over suitcase. Right? 
A: Yes. 
Q: And you had a second item of luggage similar to that. Right? 
A: No. I had a suit bag. 
Q: What's a "suit bag"? 
A: When you buy a suit at a store, they put it in a bag and you carry 
it home. 
Q: I see. What was in that suit bag? 
A: A suit. 
Q: For what purpose? 
A: Because there were gonna be a cocktail party I would have to attend. 
Q: What suit was it? 
A: I don't know. It was a suit, whatever suit I took with me. 
Q: And the dress shoes were in the Louis Vuitton bag? 
A: I believe so. 
Q: Did you come to Chicago with any other luggage besides the suit bag, 
the Louis Vuitton bag and the grip? 
A: My golf clubs. My golf clubs. 
Q: Anything other than that? 
A: No. 
Q: Did you have a second grip or duffel bag with you when you came to 
Chicago? 
A: No. If it wasn't in my golf bag, nothing else. 
Q: It might have been in your golf bag? 
A: What do you mean by "might"? 
Q: You said, "If it wasn't in my golf bag..." 
A: In my golf bag, I had various things in my golf bag. So if it wasn't 
golf related, no. 
Q: Well, we will get back to that. On your cut, Mr. Simpson, where did 
you cut yourself when you -- where on your finger? 
MR. BAKER: That's been asked and answered. Don't answer it. 
BY MR. PETROCELLI: 
Q: Did you cut yourself on only one location on your middle finger? 
A: As far as I knew, yes. 
Q: And that had -- you had not cut that same location prior to coming to 
Chicago. Right? 
A: I don't think so, but -- I don't think 
Q: And you weren't aware of any cuts on your left hand prior to coming 
to Chicago. Correct? 
A: No. I was -- no, I never -- no, I never saw a cut on my hand. No, I 
hadn't, no. That's correct. 
Q: That's correct. 
A: That's correct. 
MR. BREWER: By "hand, " are you including fingers? 
THE WITNESS: Yeah. 
Yeah. 
MR. PETROCELLI: Mr. Brewer --  
THE WITNESS: So a cut, no, I never saw a 
cut on my hand, no. That's correct. 
BY MR. PETROCELLI: 
Q: Just so we get this clear, prior to coming to Chicago and prior to 
cutting your hand in Chicago, you were not aware of any cuts of any 
kind on your hand. Correct? 
A: I never saw a cut on my hand, no. That's correct. 
Q: You never saw any cuts on your hand or any of the fingers on your 
hand. Correct? 
A: That's correct. 
Q: That would be true for either hand. Correct? 
A: That's correct. 
Q: And the only cut that you're aware of receiving as a result of the 
glass incident in Chicago is a cut on the knuckle of your middle 
finger. Correct? 
A: That's correct. 
Q: And you did not -- did you look at the cut when it happened or shortly 
after you noticed it? 
A: Yes. 
Q: And did you examine it closely? 
A: I don't know about "closely." I saw it was bleeding. I saw it was 
cut. 
Q: How big was the cut? 
A: I don't know. I can't -- it was a cut. There was blood on it, so I 
couldn't tell. But I could just tell it was cut. 
Q: Did you think you needed a stitch? 
A: Not necessarily, no. 
Q: Was there any skin that was jagged or abraded or pulled off the area 
of the cut? 
A: It looked like a cut, whatever a cut looks like. 
Q: A big cut? 
A: It looked like a cut. 
Q: Did you notice any other cuts around it or any abrasions? 
A: No. 
Q: Just the single cut. 
A: That's correct. 
MR. PETROCELLI: Okay, why don't we take our lunch break now. 1:30. 
MR. BAKER: All right. THE VIDEOGRAPHER: We are going off the record 
now, and the time is approximately 12:33. (At the hour of 12:33 p.m., a 
luncheon recess was taken, the deposition to resume at 1:30 p.m.) (At 
the hour of 1:37 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 1:37. (Plaintiffs' Exhibit 8-A was marked for 
identification by the reporter and is attached hereto.) EXAMINATION 
(Resumed) 
BY MR. PETROCELLI: 
Q: Mr. Simpson, I would like to mark as Exhibit 8-A a calendar in which 
the Xeroxing has been reduced to a single page to make it more 
readable. I will represent to you this is a copy of what was previously 
marked as Exhibit 8. Do you see that? 
A: Yes. 
Q: And that appears to be the same calendar that we discussed before 
that was filled out by Randa? 
A: One of the two that was filled out by Randa. 
Q: Okay. This appears to be a calendar pertaining to your appointments, 
though. Correct? 
A: For the most part, yes. 
Q: Okay. When family appointments or matters, events, were listed on 
this calendar, where would Randa get that information? 
A: I don't get the question. 
Q: In other words, there are items on the calendar not business related 
but family related. like --  
A: Whose family? 
Q: Your family. 
A: Show me. 
Q: Take a look at June 12, 1994 on Exhibit 8-A. 
A: Uh-huh. 
Q: What does that say? 
A: I can't -- oh, "Recital," yeah. 
Q: "Recital." What does it say underneath it? 
A: "Recital" is underneath. 
Q: It says, "Sydney Recital Dance 5:00." Do you see that? 
A: Yes. 
Q: And that pertains to your daughter Sidney's dance recital at 5:00 
p.m. on June 12. Correct? 
A: Yeah, that's one of the two things here. 
Q: Where would Miss Randa obtain that information to put on the 
calendar? 
A: I would imagine from Nicole. 
Q: Not from you? 
A: No. 
Q: She called Nicole from time to time to get these appointments, or 
Nicole called her? 
A: Nicole would normally call her and give her various things she 
wanted Cathy to put on my calendar. 
Q: I see. Is that what happened with the 5:00 p.m. dance recital for 
Sydney on June 12, 1994? 
A: Possibly, yes. 
Q: Do you recall Nicole telling or asking you to come to the recital? 
A: Yes. She wanted to know if I was going to be in town. 
Q: When did you and she have that conversation? 
A: Numerous times, but the last time I believe was the Thursday or so 
before the reciul, Wednesday or Thursday night. 
Q: June 8 or June 9, 1994? 
A: Yes. 
Q: Now, how did she tell you that; on the phone or in person? 
A: Tell me what? 
Q: That she wanted you to -- wanted to know whether you would be in town 
and be able to attend Sydney's dance recital. 
A: On the telephone. She just wanted to know whether I would be in town 
for the dance recital. I think she spoke to Cathy also during that week 
and talked about how many tickets I might need. 
Q: And what did you tell her? That is, what did you tell Nicole when 
she asked you if you would be in town for the dance recital? 
A: That I'd be back in town. 
Q: How many tickets did you tell her you needed? 
A: l didn't know if -- she said she was getting a bunch -- I don't know how 
many. I don't recall right now  -- and wanted to know if Arnelle and 
Jason was gonna go. I think it was sold out, which it always is. And I 
said I would see if -- I think I told her I told Cathy to try to get two, 
and she had hers, and she wasn't really sure who all was coming, you 
know, things like that. 
Q: You told her to make available tickets for Jason and Arnelle? 
A: No, that's not correct. That's not what I said either. l said I 
didn't know if Jason or Arnelle -- I think she asked me, were they going 
to come, and I said I didn't know. I said I did tell Cathy to see if 
she can get a few, and that was about the extent of it. 
Q: Did you and Nicole discuss this before June 8 or June 9 on Wednesday 
or Thursday night, that is, whether or not you would be attending 
Sidney's dance recital? 
A: I know the dance recital had come up before then. We knew the dance 
recital was coming up. I don't know the exact conversation was would I 
be in town, but it could have come up, yes. 
Q: How long in advance of June 12 did you know about that recital? 
A: I don't know. 
Q: A month? 
A: I don't know. 
Q: Did you and Nicole discuss whether Paula Barbieri would attend with 
you? 
A: Never. 
Q: Did that subject come up at all? 
A: Never. 
Q: Nicole never mentioned it to you? 
A: Never. 
Q: You never mentioned it to her? 
A: Never. 
Q: Do you know whether she tried to find out from any other source 
whether Miss Barbieri would be attending with you? 
A: No 
Q: Did you ask her for a ticket for Miss Barbieri? 
A: No. 
Q: Did you plan to take Miss Barbieri with you? 
A: No. 
Q: There is another entry on that day that says "Kallie" or "Kallic 
Shower." Do you know what that is? 
A: No. 
Q: Do you know who that person is? 
A: No. 
Q: Do you know whose entry that pertains to? Excuse me. Do you know 
whether that pertains to you or to Miss Randa or --  
A: It's Cathy's calendar, so I assume it pertains to Cathy. 
Q: When you say, "It's Cathy's calendar," it's a calendar that Cathy 
kept? 
A: As I explained to you before, yes. 
Q: Did Cathy in 1994 also put on Nicole's own appointments on this 
calendar? 
A: I don't know what you mean. 
Q: In other words, if Nicole had appointments not involving you, like 
going out to lunch with somebody, would she coordinate with Cathy at 
all? 
A: I doubt it. 
Q: Cathy wasn't a calendar keeper for Nicole, in other words? 
A: No. 
Q: That's correct. Right? 
A: That's correct. 
Q: I would like to go to the subject of the luggage --  
MR. BAKER: What? 
BY MR. PETROCELLI: 
Q: I want to go back to the subject of luggage and specifically the 
luggage that you took with you to Chicago, when you arrived in Chicago 
on the morning of June 13th. So far you testified that you had with you 
the golf bag. Correct? 
A: Uh-huh. 
Q: You have to answer audibly. 
A: Yes. 
Q: You also testified that you had the Louis Vuitton bag. Correct? 
A: Yes. 
Q: And you also said you had your grip, your black grip. Correct? 
A: Yes. 
Q: And you also said you had the -- a bag with the suit in it. Correct? 
A: Yes. 
Q: Now, was that bag with the suit in it the Louis Vuitton bag? 
A: No. Now you talking about the 12th? 
MR. BAKER: June 12. 
BY MR. PETROCELLI: 
Q: June 12. 
A: No. 
Q: Is there -- Whatever luggage you went to Chicago with on June 12th, 
you came back with. Correct? Is that correct? 
A: In a sense, yes. 
Q: Explain what you mean. 
A: I didn't know if my golf bag had come back. 
Q: But you brought back the Louis Vuitton bag, correct --  
A: Yes. 
Q:  -- with you when you came back the morning of the 13th. 
A: Yes. 
Q: And you brought back the black grip. Right? 
A: Yes. 
Q: And you brought back the suit bag. Right? 
A: Yes. 
Q: And you were carrying those three items separately. Correct? 
A: When? 
Q: When you came back from Chicago. 
A: No. 
Q: How were you carrying them? 
A: The Louis Vuitton bag and the grip. 
Q: Where was the suit bag? 
A: In the Louis Vuitton bag. 
Q: But when you went to Chicago, the suit bag was not on the Louis 
Vuitton bag? 
A: That's correct. 
Q: Why was that? 
A: Because I didn't want it to be wrinkled when I went to this affair. 
I wouldn't have had time to get it pressed. 
Q: It didn't fold, that bag, the suit bag? 
A: What do you mean? 
Q: It wasn't folded? 
A: At times, if I laid it gently, I'd fold it gently, but --  
MR. BAKER: I think you are talking about two different things. 
BY MR. PETROCELLI: 
Q: The suit bag when you went to Chicago on June 12 from Los Angeles, 
it wasn't the type of bag that folded and snapped. It was --  
A: No, it didn't fold and snap, but it folded over my arm or something. 
Q: Okay. Did the golf bag have any other bags in it? 
A: Yeah. 
Q: Talking about now when you left Los Angeles on June 12. 
A: Yes. 
Q: What bags were in the golf bag? 
A: I believe another pair of shoes. That had a pair of shoes in it, 
which is not really a bag. It's a little black thing that's a shoe bag. 
And a bag that had a windbreaker and some balls in it. 
Q: Golf balls? 
A: Yes. 
Q: What was the color of that bag? 
MR. BAKER: What was "that bag"? 
MR. PETROCELLI: The bag that had the windbreaker and golf balls in it. 

THE WITNESS: I'm not sure. They had it in court one day, but I can't 
recall what the color was. 
BY MR. PETROCELLI: 
Q: Is that a bag that you always carried in your golf bag? 
A: No. 
Q: You always carried the shoe bag in your golf bag. Correct? 
A: Not always, no. 
Q: How would you transport your shoes when they were not in the shoe 
bag? 
A: Sometimes I'd put them directly in the golf bag, and sometimes I'd 
just throw a shoe bag in, and sometimes I carried more than one pair of 
shoes, and the shoe bag -- the shoes would be in the shoe bag. Only one 
pair fits in the shoe bag, and sometimes I carried more than one pair 
of shoes, golf shoes, with me. 
Q: So the shoe bag, when it doesn't have any shoes in it, would also be 
carried in the golf bag? 
A: No, not necessarily. 
Q: You might carry it separately from the golf bag? 
A: May not carry it. 
Q: Just leave it home? 
A: Yeah. 
Q: But on this occasion you had the shoe bag --  
A: I believe. I'm not sure about that. I just know when they brought 
all the golf stuff in court, the shoe bag was there, so I'm assuming it 
was in the overall bag. 
Q: And were the golf shoes in the shoe bag? 
A: A pair of golf shoes were in the shoe bag, yes. 
Q: Did you bring another one with you to Chicago? 
A: There were some black shoes that I know were in the outer cover bag 
that was definitely in there. 
Q: Golf shoes? 
A: Golf shoes, yes. 
Q: So you went to Chicago on June 12 with two pairs of golf shoes. 
A: Possibly, yes. 
Q: One in the golf club bag and another in the shoe bag which was in 
the golf club bag. Correct? 
A: No. One was in the golf shoe bag that was in the golf bag, I 
believe, and the other one definitely was just in the cover bag laying 
in the shoe -- in the golf bag, cover bag of the golf bag. 
Q: What is a cover bag? 
A: It's a bag that you use to -- normally use to travel with. 
MR. BAKER: It's so that when you get there, you have all of your irons 
and your Callaway woods are still there, and the bellman --  
BY MR. PETROCELLI: 
Q: You mean the cover that goes over the clubs --  
A: Yeah. 
Q: and snaps onto the golf bag? 
A: Yes. 
Q: And you're saying --  
MR. BAKER: No. 
THE WITNESS: No. 
BY MR. PETROCELLI: 
Q: Well, wait a second. You said "Yes." Your lawyer said "No." Explain 
yourself, Mr. Simpson. 
A: What do you want me to explain myself? You're the one that's 
confused. What do you mean, explain myself? 
Q: I don't understand your answer. 
A: There's a cover bag that you can put your whole golf bag in when you 
travel. 
Q: And in the cover bag which surrounded the entire golf bag --  
A: There was --  
Q: Some shoes. 
A:  -- shoes, yes. 
Q: Is there a compartment in the cover bag for the shoes? 
A: I don't recall. I don't recall. This is -- was a relatively new cover 
bag. 
Q: Okay. And in the golf bag, you said you had the shoe bag with shoes 
in it. 
A: I believe so. I'm not a hundred percent sure of that, but I believe 
so. 
Q: Now, we had this other bag that had the windbreaker and the golf 
balls. Right? 
A: Uh-huh. 
Q: You have to answer audibly. 
A: Yes. Yes. 
Q: What was the color of that bag? 
A: I'm not totally sure of that. 
Q: What is your best recollection? 
A: Blue, bluish-gray, blue. 
Q: What was the color of the windbreaker? 
A: Blue or green. One or the other. I'm not a hundred percent sure of 
that. 
Q: Was it your windbreaker? 
A: Yes. 
Q: And had you used it before? 
A: I don't know. 
Q: Where did you get that windbreaker? 
A: From Hertz. 
Q: Did you see that windbreaker in court also? 
A: I don't recall. 
Q: Have you ever seen that windbreaker after you packed it for Chicago? 
A: I don't recall. 
Q: Have you ever seen the blue or bluish-gray bag --  
A: Yes. 
Q:  -- that was shown in court? 
A: Yes. 
Q: And when it was shown in court, did it have anything in it? 
A: I don't recall. 
Q: Did it have golf balls in it? 
A: I don't recall. 
Q: Do you always take that bag with the windbreaker and golf balls when 
you play golf? 
A: Never. Never before. 
Q: What made you do it this time? 
A: When I was getting balls, it was the only bag -- I don't know if it 
was the only bag, but it was a bag that was in the back of my Bentley 
when I was trying to find balls to take to Chicago with me. 
Q: It's not a bag that you bought at a sports store or a golf store to 
carry golf balls, is it? 
A: No. 
Q: What was the use of that bag that you usually made? 
A: For me it was no use at all. I play in a lot of tournaments, and 
they give you this crap all the time and it ends up in your car and 
your house, and my kids, people, take them or housekeepers use them. I 
get a lot of them, I mean a lot of them, and it was just something that 
was in the trunk of my car. 
Q: How many of them were in the trunk? 
A: I don't know. I didn't really count what was in the trunk of my car 
at that time. 
Q: Was there more than one such bag in the trunk of your Bentley? 
A: Could have been. 
Q: You pulled that bag out. Is that what you're saying? 
A: Well, I just grabbed a bag that was small that I could put balls in 
and a windbreaker in. 
Q: Was the bag empty? 
A: Yes. 
Q: And the windbreaker that you put in it, is that a windbreaker that 
you bring with you to golf courses? 
A: I hadn't, but I -- it was given to me at a golf course during a golf 
tournament, so it was -- you know, it was a gift that Hertz give out at 
one of our golf tournaments. You give it to the golfers. 
Q: When did you receive that windbreaker? 
A: I don't know. 
Q: Had you ever used it before? 
A: Possibly. 
Q: Where was it on the evening of June 12 when you went to get it for 
your trip? 
A: Laying in the trunk of my car. 
Q: The windbreaker? 
A: Yes. 
Q: Where were the golf balls that you put into this bag? 
A: In various bags in the trunk of my car. 
Q: What kind of bags? 
A: Just bags they give you at the country club to put your shoes in 
when you finish playing golf. 
Q: So in those bags were golf balls? 
A: Yes. 
Q: And you emptied out those golf balls from those bags and put them 
into this bluish-gray bag? 
A: No . 
Q: What did you do? 
A: I took some out and used some, and the rest I left in those bags. 
Q: How many golf balls did you take out? 
A: Four or five, six, that I took with me; three, four, five that I hit 
away. 
Q: You hit away right there? 
A: Yeah. 
Q: At Rockingham? 
A: Yes. 
Q: And when you hit those balls away, did you retrieve them and bring 
them with you? 
A: No. 
Q: You already had golf balls in your golf bag. Correct? 
A: I may have. I had no new golf balls. I had no new balls, so I may 
have had one or two used balls, but not many at all. 
Q: And these balls you took from the Bentley trunk were all new? 
A: No. 
Q: They were used? 
A: Yes. 
Q: And what was the brand? 
A: Maxfli lOOs. 
Q: All of them were? 
A: The ones that I took. 
Q: Were you specifically looking for Maxfli 100s? 
A: Specifically, yes. 
Q: And you had other types of balls in there? 
A: Yes. 
Q: So when you were searching your trunk, you looked for the Maxfli 
100s in the various bags of balls you had there, took out four or five 
or six and put them in the bluish-gray bag. Correct? 
A: Yes. 
Q: And then hit three, four or five others. Right? 
A: Yes. 
Q: And you took the windbreaker and put that in the bag, too? 
A: Yes. 
Q: And did the bag have a zipper? 
A: I don't -- I'm not sure. Probably. 
Q: Did you take anything else out of the trunk in addition to what 
you've just described? 
A: Yes. 
Q: What was that? 
A: Pitching wedge. 
Q: What was the make? 
A: Callaway. 
Q: Was it a new pitching wedge? 
A: No. 
Q: An old one? 
A: Yes. 
Q: Did you have any other clubs in the trunk? 
A: Yes. 
Q: How many? 
A: I don't know. 
Q: A whole set? 
A: At least. 
Q: Two sets? 
A: I don't know. 
Q: You specifically looked for pitching wedge? 
A: No. I was looking for a sand wedge. 
Q: Did you find one? 
A: No. 
Q: How many pitching wedges were there? 
A: I don't know. 
Q: Why did you pick this one? 
A: Because it's the closest thing to a sand wedge. 
Q: Did you take anything else out? 
A: No. 
Q: And then you closed the trunk? 
A: No. 
Q: What did you do? 
A: Hit some balls away. 
Q: While the trunk was open? 
A: Yes. 
Q: Why did you leave the trunk open? Let me ask you this: What club did 
you use to hit the balls with? 
A: Pitching wedge. 
Q: The one you took out? 
A: Yes. 
Q: Why did you leave the trunk open while you did that? 
A: I don't know. 
Q: But you specifically recall it was open? 
A: Yeah. 
Q: After you hit the balls, did you then close the trunk? 
A: Yes. 
Q: Did go into it again? 
A: What do you mean? 
Q: To do anything, to get any more balls out, to put something back. 
A: Yes. 
Q: What did you do? 
A: Put the pitching wedge back. 
Q: Did you take it with you? 
A: No. 
Q: Did the golf clubs that you did take with you include a sand wedge? 
A: To Chicago? 
Q: Yes. 
A: Yes. 
Q: Did you ever locate a different sand wedge to take with you? 
A: No. 
Q: So you ended up going with the sand wedge in the set. Right? 
A: Yes. 
Q: Was that a new set of clubs? 
A: Yes. 
Q: What was the make? 
A: Callaway. 
Q: Had you ever used them before? 
A: Yes. 
Q: When did you get the clubs? 
A: Sometime in May. 
Q: May of what year? 
A: '95 -- '4. 
Q: How did you get them? 
MR. BAKER: What do you mean, how did he get them? 
BY MR. PETROCELLI: 
Q: Did you buy them, or were they given to you? 
A: They were given to me. 
Q: Who gave them to you? 
A: Callaway. 
Q: The company? 
A: Yes. 
Q: What representative? 
MR. BAKER: Don't answer that. This is irrelevant. 
MR. PETROCELLI: It's not irrelevant. 
MR. BAKER: Tell me what relevance it is what representative gave him 
Callaway golf clubs. 
MR. PETROCELLI: We are going to go ask him if it's true. 
Q: Who gave it to you? 
MR. BAKER: Don't answer it. 
THE WITNESS: Callaway. I told you. 
BY MR. PETROCELLI: 
Q: No. What person at Callaway? Eli Callaway himself? 
MR. BAKER: Don't answer the question. 
BY MR. PETROCELLI: 
Q: Have you ever met Mr. Eli Callaway? 
MR. BAKER: Don't answer that. That's irrelevant. 
MR. PETROCELLI: What are the objections, just for the record? 
MR. BAKER: It's irrelevant. It's irrelevant and immaterial to any issue 
in this case. 
MR. PETROCELLI: You are mistaken, but we will proceed. 
Q: From what location in your Rockingham property did you hit those 
golf balls? 
A: My front yard. 
Q: On the grass? 
A: Yes. 
Q: Did you tee them up? 
A: No. 
Q: You just put them on the grass? 
A: Just dropped them on the grass. 
Q: Did you take full swings? 
A: Once or twice I did, yes. 
Q: And were you hitting in the direction of Rockingham, Ashford or 
someplace else? 
A: A couple in the direction of -- in the direction of Rockingham but not 
to Rockingham, and a couple in the direction of Ashford. 
Q: Which ones did you take the full swing, which direction? 
A: Ashford. 
Q: Is there a clearing where you can hit the ball far without hitting 
anything? 
A: Not really. 
Q: Did it hit anything? 
A: No. 
Q: In other words, when you took the full swing and hit those balls 
with your pitching wedge, did you hear any sound when the ball landed? 
A: No. 
Q: Okay. How far do you hit a full pitching wedge? 
A: It depends. 
Q: How far --  
A: Full swing, you mean? 
Q: Full swing, yeah. 
A: It depends. If I'm trying to hit a full-swing pitching wedge, 
anywhere from 120 to 130 yards. If I'm trying to make it into a sand 
wedge, a lot less. 
Q: Is that what you were trying to do? 
A: Yes. 
Q: So by taking less than a full swing? 
A: No. By changing your grip and the head of the club. 
Q: Is that what you did when you took those full cuts? 
A: Yes. 
Q: You imitated a sand wedge swing, in other words? 
A: Yeah. I was trying to get it up, the ball up. 
Q: Did you take a divot in your grass? 
A: I don't know. 
Q: Did the club dig up any grass or dirt? 
A: I just don't recall if I took a divot. I don't normally take divots, 
but I don't recall. I'm sure there was, but  -- some grass taken up, 
but... 
Q: You hit two or three balls in that direction? 
A: Yeah. I mean, just a couple. I chipped a couple real -- five or six 
yards, brought them back, then I hit a couple into the sand and a 
couple -- you know, when I say "a couple," two or three one way and then 
whatever was left the other way. 
Q: Now, you said you first chipped a couple of balls five or six yards 
away. Right? 
A: Yeah. 
Q: Where did they land? In the yard? 
A: Which ones? 
Q: The ones you chipped five or six yards away. 
A: Yeah, right on the grass. 
Q: On the grass. 
A: Yeah. 
Q: Then did you hit those balls into the sand? 
A: Yeah. 
Q: What sand are you referring to? 
A: My playground. 
Q: Where the kids play? 
A: Uh-huh. I skulled one of them and it hit the equipment, I don't know 
where it went. 
Q: Made a loud sound? 
A: Yeah. 
Q: It bounced someplace, and you didn't retrieve it? 
A: True. 
Q: Do you know if it stayed on the property? 
A: I don't know that one. I don't know. 
Q: You skulled it --  
A: Sculled it. 
Q: -- meaning you made more solid contact with the ball than you 
intended. Right? 
A: Yes. 
Q: And the other balls landed in the sand? 
A: I believe so, in or around there. Within the walls of the property, 
I'm pretty sure. They could have hit into the ivy there, but this 
should have been inside of the property. 
Q: Did you then take some cuts in the sand? 
A: Oh, no. No. 
Q: As though you were in a sand trap. 
A: No. No. I just left them there. 
Q: You left the balls in the sand trap  -- in the sand? 
A: Wherever they went, I --  
Q: Did they land in the sand? 
A: I don't know. One of them should have, at least, but I really don't 
know. 
Q: Wherever they landed, you didn't retrieve them. 
A: Correct. 
Q: And then you said you took some fuller swings and hit the remaining 
balls? 
A: Yeah, one or two. I don't really recall. But one or two I tried to 
hit over my tree into the yard across Ashford. 
Q: As though you were taking a sand  -- a shot with a sand wedge. Right? 
A: For the most part, yeah. 
Q: And how far did that ball travel? 
A: I don't know. 
Q: Do you have any estimation? 
A: No. 
Q: Under a hundred yards? 
A: I would think so, yes. 
Q: Between 50 and 70? 
A: 40 and 70, I would say. 
Q: Between 40 and 70. 
A: I hope so. 
Q: And the other ball, not that one that you tried to hit over the 
tree, where did you hit that one when you were taking a full swing? 
MR. BAKER: I don't know. I thought that's what you were just talking 
about. 
MR. PETROCELLI: He said he hit one ball high 40 to 70 yards. 
Q: Right? 
A: Both of them about the same, but as I said, one of them may have 
gotten through and one of them may not have. I don't recall. 
Q: Gotten through where? 
A: One of my big trees that are on my property. 
Q: I see. If it did not get through the big tree, would it have landed 
somewhere in your property? 
A: It could have gone through, but it didn't clear the big tree. I do 
this all the time, so it's hard to recall if that moment that was the 
exact one, but I do know I hit something over to Mrs. Nebeker's, 
because it's my practice to always do that. 
Q: Over to Mrs. what? 
A: Nebeker's yard. 
Q: How do you spell that name? 
A: I don't know. 
Q: Could you say it a little more slowly? 
A: Nebeker. 
Q: Has Mrs. Nebeker ever talked to you about your hitting golf balls 
there? 
A: No. 
Q: Have you ever spoken to her about the fact that you've done that? 
A: She's seen me actually on her -- in her yard hitting balls many, many 
times. 
Q: And she has never said anything to you about it? 
A: She likes to talk to me, but she's no longer living, but she would 
sit in her front door. 
Q: When did she die? 
A: I think early '94. 
Q: And who was living at that property when you hit the golf balls in 
that direction? 
A: I have no idea. 
Q: Was the house vacant? 
A: I don't know. 
Q: Did you ever hit her with a golf ball? 
MR. BAKER: You don't have to answer that. You couldn't resist. Is that 
the reason that she passed --  
THE WITNESS: No, that's not the reason. 
MR. PETROCELLI: That is where he was going with it, but I didn't even 
have the nerve to ask that. 
Q: Did you take any other shots of a greater distance than chipping --  
A: No. 
Q: -- other than the two over the big tree? 
A: No. No. The one or two, as I said, but no. 
Q: What time was it when you did that? 
A: I believe around or a little after 10:00 o'clock. 
Q: What fixes that time in your mind? 
A: Nothing in particular, except I knew I was back from having a 
burger, and then I just know when I got upstairs  -- it wasn't but 15 or 
20 after 10:00 by the time I got upstairs, so I knew it had to -- and 
other than turning lights out in my house, I can't imagine -- I don't 
recall doing anything else before I got upstairs. 
Q: Was there any light on your property where you hit the golf balls? 
A: Yeah. 
Q: And what was illuminating that area? 
A: It's not that it was illuminating the area, but it was illuminating -- 
 -- there is a light in a tree that's right above where I was hitting, and 
my garage was open. 
Q: When you hit the balls on the grass, it was near the big tree? 
A: Well, yeah. 
Q: And  -- 
MR. BAKER: "Near" is all relative. 
MR. PETROCELLI: Excuse me? 
MR. BAKER: "Near" is all relative. 
BY MR. PETROCELLI: 
Q: How many yards were you from the big tree? 
A: From the base of the big tree? 
Q: Yes. 
A: Seven, eight, ten maybe. 
Q: Okay. 
A: Whatever the width of my driveway is. It's on the other side of my 
driveway, and whatever the width of the driveway. 
Q: Right on the other side of the driveway? 
A: Yeah. But the tree hangs over, you know, so the light would be 
hanging over a little more than the base of the tree. 
Q: Was it light out where you were hitting? 
A: The way it is always in my front yard. I wouldn't call it light, but 
I can hit a couple of balls away. 
Q: Now, this light, is this actually in the tree, the light? 
A: Yes. 
Q: How does the light get turned on? 
A: It's on automatic. 
Q: Was there any other light illuminating that area where you were 
hitting the golf balls? 
A: Maybe coming from my garage a little bit. When you say 
"illuminating" an area, it wasn't like shining on the area, but I could 
see what I was doing. 
Q: Okay. Was there any other light besides that tree light that would 
have enabled you to see what you were doing? 
MR. BAKER: And the garage light coming from his garage? 
BY MR. PETROCELLI: 
Q: Now, the garage light --  
A: Yeah, the garage light. And I don't know. I think I have a little 
walkway light that was in front of me, but I don't think it does much 
illuminating. 
Q: Was the garage door open or closed? 
A: Open. 
Q: The garage door was open. 
A: Yeah. 
Q: And the garage light was on in it? 
A: Yes. 
Q: When that garage light is on, it passes some light out of the garage 
and near this area --  
A: Yeah. 
Q: where you were hitting the golf balls? 
A: It's not a spotlight or anything, but yes. 
Q: Were there any other lights on outside the property or from inside 
the house that would cast light onto the area where the golf balls 
were? 
MR. BAKER: By that you are excluding streetlights? 
MR. PETROCELLI: Any lights. 
MR. BAKER: Because you said "inside the house" and --  
MR. PETROCELLI: I guess I was excluding streetlights. THE witnesS: I 
don't know. The coach lights may have been on in the front of my door. 
BY MR. PETROCELLI: 
Q: What are coach lights? 
A: Two lights that hang on the outside of the front door at my entryway 
there. 
Q: Were they on? 
A: I don't recall. 
Q: Do they go on automatically? 
A: No. 
Q: You have to turn them on? 
A: Uh-huh. 
Q: You have to answer audibly. 
A: Yes. 
Q: Where is the light switch? 
A: Right inside of my front door. 
Q: Inside the house. 
A: Yes. 
Q: And how do you turn the garage light on that was on? Inside the 
garage? 
A: No. One portion comes on automatically; and the other portion, as 
you enter the garage, you have to turn  -- the back portion you have to 
turn on, and then the front portion comes on as the garage door comes 
up. 
Q: One of those Genie --  
A: Yeah. 
Q:  -- electric garage doors? 
A: Yeah. 
Q: When the garage door opens auto -- with a remote control or a clicker 
on the wall? 
A: Yeah. 
Q: There is a light on, and that stays on at all times? 
A: What do you mean? 
Q: In other words, there is a light on in the mechanism, the garage 
door mechanism. Correct? 
A: Uh-huh. 
Q: You have to answer audibly. 
A: Yes. 
Q: And when you open the garage door, this light goes on. Correct? 
A: Yes. 
Q: Does that light stay on as long as the garage door is open? 
A: I don't know. 
Q: Or does the light go off after a few minutes? 
A: I don't know. 
Q: Do you have the same garage door opener now? 
A: Yes. a Do you have the same garage door --  
A: Yes. 
Q: -- and same equipment? 
A: Yes. 
Q: The other light, in the back of the garage, you have to manually 
turn on. Correct? 
A: Yes. 
Q: Was that light on? 
A: Yes. 
Q: When was the last time before June 12th that you hit golf balls at 
around 10:00 o'clock at night from your property at Rockingham? 
A: I spent most of April in Puerto Rico, so probably -- I don't know if 
it would be 10:00 o'clock, but certainly at night many times. 
Q: When was the last time of the many times? 
A: I have no -- I don't recall. 
Q: The last time before June 12th. 
A: I don't recall. 
Q: You can't give me a single day? 
A: I can't recall. 
Q: Was it the day -- night before? 
A: No. 
Q: Was it in June of 1994? 
A: It may have been in June. 
Q: What night? 
A: I don't know. 
Q: You want to look at your calendar? Would that help you? 
A: No. 
Q: Maybe by refreshing your recollection as to whether you were in town 
or not? 
A: I don't get what you're saying. 
Q: Well, take a look at 8-A and look at June and tell me what evening 
before June 12 you last hit golf balls at Rockingham. 
A: I told you I may have. It's something I do often. So I don't have 
any specific memory, but I know I would have because it's something 
that I do often. I don't know about 10:00 p.m. Certainly I drop balls 
and hit them all the time. I actually had a net that I put up on my 
garage and hit off a mat into my garage. As late as midnight I've done 
that. So --  
Q: Is the net still there? 
A: I'm sure it's hanging around somewhere, because I've bought new 
nets. I've bought two new nets, I know, in the last -- since I'd gotten 
back home that time, I had bought two new nets to put in various places 
on my property. 
Q: What nets were up at the property on June 12? 
A: They weren't up. It was something you would have to hang. 
Q: You had nets, but they were not hanging on June 12. Is that what 
you're saying? 
A: Yes. 
Q: Where were the nets? 
A: I don't know. Probably around my garage somewhere. 
Q: When was the last time you hung those nets to use them before June 
12? 
A: Sometime in May I may have done it in my backyard. 
Q: Do you have a specific recollection of doing it in May? 
A: No. But since it's something that I've done so much over the last 10 
years, I'm sure I must have, you know. 
Q: When you hit into the net, you're not hitting the balls off the 
property. Right? You're n hitting them into the net. Correct? 
A: Yeah, but normally I would take one or two because I want to do 
something, hit them somewhere. yeah. 
Q: Do you have a specific recollection in June, prior to June 12, of 
hitting golf balls at night? 
A: Not in June. Not in June, I don't, no. 
Q: Do you have a specific recollection of hitting golf balls at night 
from your property in May of 1994? 
A: Specific, no, but I can  -- I'm pretty sure I did, but I don't have any 
specific recollection, no. 
Q: And do you have a specific recollection of hitting golf balls at 
night from your property in April of 1994? 
A: I was never in L A. in April. 
Q: In March of 1994? 
A: When you say "specific," I don't know the specific day, but I know I 
did in March. I know for sure I did on numerous occasions. 
Q: Did you ever do so with another person? 
A: No. 
Q: Can you identify a single person --  
A: Well, no, that's wrong. Yes. 
Q: Okay. Who? 
A: Justin. 
Q: Your --  
A: My son. 
Q: -- younger boy? 
A: Yes. 
Q: He was with you on one occasion when you were hitting golf balls at 
night at your property? 
A: He's been with me on numerous occasions when I've done that, yes. 
Q: When was the last time? 
A: I don't recall -- last time? 
Q: Withdrawn. When was the last time before June 12, 1994 that Justin 
was with you at night at Rockingham hitting golf balls? 
A: I don't know. 
Q: And do you have a specific recollection that he was with you in June 
hitting golf balls at night? 
A: I told you I didn't think I hit any balls other than that night. 
Q: So maybe going back to March? 
A: Possibly to March, yes. Possibly March. Possibly February, possibly, 
yes. 
Q: Did Justin also hit golf balls, too? 
A: Yes. 
Q: Off the property like you were doing? 
A: No. He's just gotten to the point where he can hit it on the 
property. 
Q: Were these situations where you were just hitting into the net or 
actually taking a couple and hitting them out? 
A: Well, yeah. Normally --  
MR. BAKER: And you are talking about instances with --  
MR. PETROCELLI: With Justin. 
MR. BAKER: Thank you. 
THE WITNESS: If he's hitting, because only one of 
us could hit into the net, I might drop a ball or two and chip it over 
the wall or chip it somewhere, yeah. 
BY MR. PETROCELLI: 
Q: And he saw you do that? 
A: I'm sure he did, yes. 
Q: Besides Justin, is there any other person who in 1994 before June 12 
saw you hit golf balls from your property at night? 
A: What do you mean, from my property? 
Q: Hitting golf balls on your property like you said you were doing on 
June 12. 
A: I would imagine a housekeeper must have seen me. Nicole obviously 
seen me many times. I don't know. Whoever was around. Probably my 
housekeeper. Probably Michelle more than Gigi, but possibly Gigi. 
Q: Was there any other person besides Justin who ever participated in 
that with you? 
A: What do you mean? 
Q: Hitting golf balls at night at your property in the year 1994. 
A: Not that I recall, no. 
Q: Now, have you ever seen -- Withdrawn. Do you know whether any of those 
golf balls that you said you were chipping around the yard were ever 
retrieved by anybody? 
A: I believe so, yes. 
Q: Who retrieved them? 
A: I believe LAPD. 
Q: How do you know that? 
A: Because I have a -- some memory that I read a report that they did. 
Q: And have you ever seen those golf balls? 
A: No. 
Q: Did LAPD ever bring them into the courtroom, or did anybody else 
ever bring them into the courtroom? 
A: Not that I know of. 
Q: Did you ever say to somebody, "Hey, get those golf balls for me; 
bring them to court"? 
A: For what? 
Q: Did you ever request that they be brought to court? 
A: No. 
Q: And what is this document where you read at the golf balls were 
retrieved from your property? 
A: In some form of discovery. 
Q: Do you know whether the golf balls that you read in this report that 
were retrieved from your property were the ones that you hit on the 
evening of June 12 as opposed to some prior occasion? 
A: No. 
Q: Did you hit Maxfli 100s on June 12 on your property? 
A: One might have been. They might have been. It was just the scuffed 
balls that I hit away. I just looking for scuffs more than anything. 
Q: When you were going into your golf bag, you said you picked out 
Maxfli 100s. 
A: Yes. 
Q: I am talking about the bag of balls in the Bentley trunk. 
A: Uh-huh. 
Q: You have to answer audibly. 
A: Yes. 
Q: So I take it all these balls, then, were Maxfli 100s. 
A: No. 
Q: You also picked out other balls as well? 
A: I probably hit away some other balls, yes. 
Q: Were you picking out balls to hit in the yard that were not Maxfli 
100s? 
A: I was picking balls out to take with me were Maxfli 100s. Whatever I 
grabbed to hit away were scuffed balls, and I just hit them away. 
Q: So you have no way then, of knowing whether these balls that you 
read about in the LAPD report are the actual balls you hit that night. 
Correct? 
A: That's correct. 
Q: Did you ever ask anybody to go look for those balls that you hit 
that evening on the property? 
A: No. 
Q: Now, the balls that you hit -- Withdrawn. The club you used to hit 
those balls was the pitching wedge Correct? 
A: That's correct. 
Q: And was that wedge seized by the LAPD? 
A: I think at some point, yes 
Q: And did you get it back yet? 
A: I believe so, yes. 
Q: When did you get that wedge back? 
A: I think when I was in jail. 
Q: They returned it to whom? 
A: To Rockingham, I assume. 
Q: All the clubs were returned? 
A: I never really checked to see, but I'm assuming, of that group of 
clubs, I'm assuming they were, yes. 
Q: Where is this pitching wedge now? 
A: I hope in my garage. 
Q: Have you used it since that evening when you hit golf balls on June 
12, 1994? 
A: I might have. 
Q: Do you remember using it? 
A: I might have. I don't know. We hit a lot of balls in the front yard. 
So, I mean, I grab a club; some of my security; I grab a club; even 
some of my lawyers have grabbed a club. So, you know... 
Q: You are saying since you were --  
A: Even some of my lawyers have taken some clubs. 
MR. BAKER: We don't need to put this on the record. 
MR. PETROCELLI: Let the record reflect that the witness looked towards 
the general direction of Mr. Baker. 
Q: Have you hit any golf balls at night from the Rocking -- at your 
Rockingham property since you were released from jail? 
A: Yes. 
Q: And have you done so with other persons? 
A: Yes. 
Q: Who? 
A: Security. And I don't know if you guys were around. Whoever was 
around. 
Q: How many times did you do that? 
A: How many times I've done it since I've been back? 
Q: Since you got out of jail, at night at Rockingham, 10:00 o'clock. 
A: Oh, Jesus, 10:00 o'clock --  
Q: 9:00,10:00 o'clock or later. 
A: After dark. 
Q: After dark. 
A: After dark, three or four times. 
Q: And every time was with someone else? 
A: Well, every time somebody was there. I mean, I have security there 
that's full time now. A few times they were there. 
Q: And they saw you do it? 
A: Oh, yeah. 
Q: Who were the security personnel? 
A: I can't give you any last names, but Thomas, Jeff, Dave. 
Q: Who were the lawyers? 
A: Phil Baker, Bob Baker. Bob Blasier, I'm not sure. 
Q: Did the lawyers also swing the clubs? 
A: Yes. 
Q: And were you --  
A: Not all the time. You're talking on at least one occasion or 
something. 
Q: Were any of these incidents when you hit golf balls from Rockingham, 
after you got out of jail, for the purpose of demonstrating what you 
were doing on the evening of June 12? 
MR. BAKER: Well, you can talk about -- don't answer that question, but 
you can talk about anything other than any demonstrations that your 
lawyers had you do. 
THE WITNESS: After dark, no. 
BY MR. PETROCELLI: 
Q: But before dark, yes? 
MR. BAKER: Well, don't answer that question. 
BY MR. PETROCELLI: 
Q: You want to answer that? 
MR. BAKER: No, he not going to answer that 
MR. PETROCELLI: I think what he does, Mr. Baker, is not a 
communication -- demonstrations are not protected, but I am not going to 
convince you, I can see. 
MR. BAKER: No, you're not. 
MR. PETROCELLI: We will just have to take it to the judge. 
MR. BAKER: Fair enough. 
MR. PETROCELLI: Okay. 
Q: I would like to show you some photographs, which I would like to 
mark -- I guess we will start with Exhibit 22. (Plaintiffs' Exhibit 22 
was marked for identification by the reporter and is attached hereto.) 
MR. PETROCELLI: I will have to make copies. 
Q: I would like to show you what I will mark as Exhibit 22, a 
photograph of -- a photograph. Hold on for a second, Mr. Simpson. (Pause 
in the proceedings.) 
BY MR. PETROCELLI: 
Q: Mr. Simpson, now that the lawyers have seen this, let me show you 
Exhibit 22. What is that a picture of? 
A: A golf bag. 
Q: Is that the golf bag that you took to Chicago on June 12? 
A: It appears to be, yes. 
Q: And does this contain the clubs that you had recently received from 
Callaway about a month before? 
A: I really can't tell, but they -- I see one or two of the clubs look 
like Callaway Big Bertha irons, and that would be the type of irons 
that I had. 
Q: This was a new set of irons you had gotten? 
A: Yes. 
Q: Were the woods new also? 
A: No. 
Q: And the putter? 
A: No. 
Q: When you took this -- it was a Swiss Army golf bag. Correct? 
A: Yes. 
Q: Is that made by the Forschner Company? 
A: I doubt it. 
Q: Have anything to do with Forschner? 
A: Well, Swiss Army is. 
Q: Is that something that is placed on the bag? 
A: Yes, I believe so. 
Q: Oh, I see. When you went to Chicago, you put this bag in what you 
called a cover bag. Correct? 
A: That's correct. 
Q: Was this the  -- Had you used these clubs earlier on the day of June 
12? 
A: Yes. 
Q: This exact set of clubs? 
A: Well, if that's the clubs. yes 
Q: And had you used them the day before, on June 11th? 
A: Yes. 
Q: And when you used them, you went to play locally at Riviera correct? 
A: That's correct. 
Q: Both on June 11 and June 12 Right? 
A: That's correct. 
Q: When you used them on those occasions, you did not have a black  -- 
excuse me -- you didn't have a cover bag. Correct? 
A: Didn't have a travel bag, no. 
Q: Where was your cover bag? 
A: In the entry of my house. 
Q: Kept there on June 11 and June 12? 
A: Correct. 
Q: What car did you use to drive to the golf course on June 11? 
A: I don't know. 
Q: What are the choices? 
A: Bentley or Bronco. 
Q: You don't remember which one you used? 
A: No. 
Q: What did you use on June 12? 
A: Bronco. 
Q: Where were you -- Strike that. Where did you put this golf bag with 
all the clubs in it into the cover bag? 
MR. BAKER: The location where he was when he inserted it? 
MR. PETROCELLI: Correct. 
THE WITNESS: In front of my house or at the 
entry portion of my house. 
BY MR. PETROCELLI: 
Q: You took the golf clubs to the entryway of your house? 
A: Yeah, at the entry, and then the cover was still there because I had 
taken it off Saturday morning there. 
Q: The entryway was inside the house. Right? 
A: Yes. 
Q: On the floor? 
A: That -- yeah. 
Q: In a closet? 
A: No. 
Q: Just lying there? 
A: Yes. 
Q: Just on the other side of the front door? 
A: Yes. 
Q: If you opened the front door, would it hit the golf cover bag? 
A: If it spread out, maybe, but I don't think it was then. It was to 
the -- facing the front door, to the left. 
Q: Against the wall? 
A: Yeah. 
Q: Okay. And you took your golf clubs inside the house and put the 
cover bag on? 
A: I don't think so. I think I brought the cover bag out. 
Q: Right outside the front door? 
A: Yes. 
Q: In the entry -- What do you call that area right outside the front 
door? 
A: My entry. Front -- not the foyer, but the entry. 
Q: You put the cover bag on at that time. Right? Or at that location, I 
should say. 
A: Yes. 
Q: What time was that? 
A: That was between -- that was before I went to McDonald's, so that 
would have been before 9:00 o'clock. 
Q: When you put the cover bag over the golf clubs, did the cover bag 
also have another pair of shoes in it? 
A: It may have. Or the golf bag may have had a pair of shoes in it. 
Q: This golf bag had a pair of shoes in it? 
A: It could have. I'm not sure right now. I don't recall. 
Q: Did you put another pair of shoes in the cover bag? 
A: Another pair of shoes ended up in the cover bag. I didn't 
specifically put them in the cover bag, but at some point obviously I 
had, but there was definitely a pair of shoes in the outer cover bag, 
yes. 
Q: When did you put those shoes in he outer cover bag? 
A: I don't know. 
Q: Did you do it on the evening of June 12? 
A: I went to make sure that they were in there on the evening of June 
12, and they were. 
Q: When you took the cover bag off two or three days before, were the 
shoes in the cover bag from your prior trip? 
A: They could have been, because I did take them with me on the prior 
trip. 
Q: You don't remember one way or the other? 
A: No. 
Q: And did this bag have a place where you could put the shoes and the 
shoe bag? 
A: If I wanted to, yes. 
Q: And where was that? Can you point to it? 
A: This zipper that comes down, it could have gone in right there 
(Indicating). 
Q: Under where it says "Swiss Army"? 
A: Yes. 
Q: Now, when you put the golf bag into the cover bag shortly before you 
went to McDonald's -- is that what you said? 
A: Yes. 
Q: Around 9:00 p.m.? 
A: Well, before I went, yes. 
Q: Shortly before you went? 
A: I don't know about shortly, but sometime before I went, yes. 
Q: What time was it? 
A: I don't know. It was sometime between 7:00 and 9:00. 
Q: You can't fix it any closer than that? 
A: Cannot fix it any closer than that. 
Q: So any time between 7:00 and 9:00 o'clock is when you put the golf 
bag into the cover bag. 
A: That's correct. 
Q: And when you did that, what did you do with the cover bag that had 
the golf clubs in it? 
A: Put them on my bench. 
Q: Outside the front door? 
A: That's correct. 
Q: And it stayed there? 
A: Yes. For a while. 
Q: For a while. 
A: Yeah. Till we took them off the bench. 
Q: To go into the limousine. 
A: No. A little bit before I went into the limousine. 
Q: But once you closed up that cover bag between 7:00 and 9:00 o'clock, 
you never opened it again. Correct? 
A: Incorrect. 
Q: Why did you open it? 
A: I wanted to make sure I had my black shoes in there. 
Q: Golf shoes? 
A: Yes. 
Q: And were they in there? 
A: Yes. 
Q: And are those the shoes in the coverbag or the shoes in the golfbag? 
A: Cover bag. 
Q: So you opened it one time, looked in the coverbag, saw the shoes, 
closed it, and then you did not open it again. Correct? 
A: Until when? 
Q: Until you got to Chicago. 
A: No, that's not correct. 
Q: Until you got into the limousine. 
A: That's correct. 
Q: Okay. Focusing up until the time when you left the Rockingham 
property in the limousine on June 12, you did not open that cover bag 
again after you looked and checked for the black shoes. Right? 
A: Yes. 
Q: And when was it that you looked and checked for the black shoes? 
A: Somewhere around 11:00 o'clock or -- somewhere around 11:00 o'clock. 
That's a guess. 
Q: That's your best guess? 
A: Yeah. Shortly before I left to go -- before we drove out of my 
driveway. 
Q: When you looked for the shoes, was the limo already there? 
A: Yes. 
Q: And it was past the gate? 
A: No. 
Q: It was still on the other side of the gate? 
A: That's right. (Plaintiffs' Exhibit 23 was marked for identification 
by the reporter and is attached hereto.) 
BY MR. PETROCELLI: 
Q: Let me show you what has been marked as Exhibit 23. Mr. Simpson, I 
am showing you a photograph marked as Exhibit 23. Can you identify what 
is in that photograph? 
A: It appears to be a Swiss Army cover travel bag. 
Q: And is that the travel bag that you have been referring to? Excuse 
me. Is that the bag you've been referring to so far as a "cover bag"? 
A: One like this, yes. 
Q: Is that the exact one? 
A: I don't know. 
Q: Does it look like it? 
A: Yes. 
Q: That's the bag that you just testified about. Correct? 
A: Yes. 
MR. BAKER: Bag that he just testified about? 
MR. PETROCELLI: Cover bag. 
THE WITNESS: Yes, I believe so. 
BY MR. PETROCELLI: 
Q: Now, pointing to this cover bag, where do you open the zipper to 
look for the shoes? Or where did you open the zipper to look for the 
shoes? 
A: I really can't make it out here. Wherever you open the zipper to put 
the clubs in is the zipper that I opened to look for the shoes. 
Q: There is another compartment in there for the shoes? There is 
another compartment inside the coverbag --  
A: No. 
Q:  -- for the shoes? 
A: No. 
Q: Just lying loose in there? 
A: Yeah, lying loose. 
Q: Is that a blue cover bag? 
A: No. 
Q: What color is it? 
A: Black. 
Q: And the golf bag is black, too. Right? 
A: Yes. 
Q: Let me show you the next photograph, which I will mark as Exhibit 
24. (Plaintiffs' Exhibit 24 was marked for identification by the 
reporter and is attached hereto.) 
BY MR. PETROCELLI: 
Q: Do you recognize what is depicted in that photograph? 
A: Yes. 
Q: What is that? 
A: A Louis Vuitton travel bag --  
Q: And that was -- Excuse me. I'm sorry. 
A: Suitcase. 
Q: Is that the Louis Vuitton suitcase that you took to Chicago? 
A: One like this. Possibly this could be it. 
Q: And that's the -- When you went to Chicago, you've already said you 
didn't have your new suit in there. Right? 
MR. BAKER: He didn't say it was new. He said he didn't have a suit in 
there. 
MR. PETROCELLI: You are correct. 
Q: You did not have your suit in there. 
A: That's correct. 
Q: Was it a new suit? 
A: All my clothes are relatively new, yes. 
Q: What was in this Louis Vuitton bag when you went to Chicago? 
A: Couple of golf outfits, maybe a T-shirt or two, some underwear. 
maybe a pair of shoes --  
Q: Dress shoes? 
A: Yes, I believe so. I'm not a hundred percent sure if I didn't try to 
double up the shoes I was wearing as dress shoes. 
Q: Anything else? 
A: That would be about it. 
Q: And everything that you went to Chicago with you came back with in 
the Louis Vuitton bag except that you also added the suit? 
A: That's correct. 
Q: And also the garment bag in which the suit was located? 
A: That's correct. 
Q: Okay. Did you come back with the same clothes that you went to 
Chicago on? 
A: Yes. 
MR. BAKER: You mean was he wearing the same clothes? 
MR. PETROCELLI: Withdrawn. 
Q: Were you wearing the same clothes back to Chicago that -- back to Los 
Angeles that you had worn to Chicago? 
A: No. 
Q: Wearing different clothes? 
A: Yes. 
Q: What did you wear to Chicago on the evening of June 12? 
A: I believe some jeans, white shirt and jean jacket, and I may have 
had a windbreaker with me. Not a windbreaker, but a wet jacket. 
Q: What were the  -- Were these stone-washed jeans? 
A: Yes. 
Q: What was the  -- who was the manufacturer? 
A: I don't know. 
Q: Were they Guess? jeans? 
A: I don't know. 
Q: What kind of jeans do you usually wear? 
A: All kinds. 
Q: You don't remember? 
A: I do remember. 
Q: What jeans they were? 
A: All kinds of jeans I have in my home. 
Q: You don't remember what particular style this was? 
A: No. No. No, I don't. 
Q: Did you have any socks on? 
A: I don't think so. 
Q: What kind of shoes did you have on? 
A: Some loafers. 
Q: What color were they? 
A: Black or blue. 
Q: What size were they? 
A: I don't know. 
Q: Which size did you wear in 1994? 
MR. BAKER: We've been through the size. You asked that yesterday. 
MR. PETROCELLI: No, I never asked that. 
MR. BAKER: You never asked the size shoes he has? 
MR. MEDVENE: No. 
MR. BAKER: It's no big deal. I will let him answer, anyway. 
MR. PETROCELLI: Let me rephrase  -- or reask the question. 
Q: In June of 1994 what size shoes did you wear? 
A: Depends what shoe I was wearing. I could wear 12s, 11-1/2s, some 
13s. 
Q: What size shoes -- what type of shoes did you wear in size 12? 
A: Depends on the shoe make and the shoe. 
Q: What size -- what type and make of shoes did you own at that time in 
size 12? 
A: Loafers. I would imagine some loafers were 12s, some tie-ups and 
tennis shoes. 
Q: Were most of your shoes that you owned in June of 1994 size 12? 
A: I would say so, yes. 
Q: And you also said you had some size 11-1/2s? 
A: Uh-huh. 
Q: You have to answer audibly. 
A: Yes. 
Q: What shoes did you have of that size in June of 1994? 
A: Probably tennis shoes and one or two pairs of loafers. 
Q: Are these shoes gifts to you, these 11-1/2s? 
A: Not necessarily, no. 
Q: Why did you have some 11-1/2s? 
A: Because that's what they were. 
Q: You tried them on --  
A: Yeah. 
Q: -- and you bought them? 
A: Yeah. 
Q: And they fit? 
A: Yeah. 
Q: These particular tennis shoes and one or two loafers. 
A: Yeah. 
Q: What was the width of your shoe size --  
A: I don't know. 
Q:  -- in June of 1994? 
A: I don't know. 
Q: What is it now? 
A: I don't know. 
Q: You have no idea? 
A: None. 
Q: When you go into a shoe store and ask the salesman for shoes, do you 
give him a width size? 
A: No. 
Q: You just say, "Give me a size 12"? 
A: Yes. 
Q: Now, you also have some size 13s? 
A: Uh-huh. 
Q: Is that what you said? 
A: Yes. 
Q: What shoes in June of 1994 were size 13s? 
A: Some golf shoes. 
Q: Did you own a brand-new pair of Nike golf shoes in June of 1994, 
white? 
A: Could very well. 
Q: Do you pay for your golf shoes, or are they given to you? 
A: Sometimes I pay. Sometimes they're given to me. 
Q: Do you remember a pair of white Nike golf shoes that you owned in 
June --  
A: Not particularly. 
Q:  -- in June of 1994? 
A: Not particularly, but I'm sure -- I like Nike golf shoes, so I'm sure 
I probably had a pair. 
Q: Are all your  -- Withdrawn. Were all of your -- Withdrawn. Were all of 
your golf shoes In June of 1994 size 13? 
A: No. 
Q: What were the other sizes? 
A: I don't know. I'd have to look at them. Some probably were 12, for 
sure, and I would have to look at them. 
Q: How many pairs of golf shoes did you own in June of 1994? 
A: Guess? 
Q: Excuse me? 
A: Guess? 
Q: Guess? 
A: You want me to make a Guess? 
Q: No. Your best recollection. 
A: It would be my best guess. 
Q: Well, tell me. 
A: 10. No. 15. 
Q: 15? 
A: Yes. 
MR. BAKER: He didn't ask you that. 
THE WITNESS: I'm sorry. 10 to 15. 
BY MR. PETROCELLI: 
Q: 10 to 15 . And where are -- where were they maintained or kept in June 
of 1994? 
A: Some in my home; some at my country club; some at my other country 
club; some at my other home. 
Q: What are your two country clubs? What were they then? 
A: Riviera -- in LA., Riviera -- that I was a member of, Riviera, Sherwood, 
Mountain Gate, even though I didn't keep nothing at Mountain Gate, and 
then there's courses around the country. 
MR. BAKER: Why don't we take 10 minutes. 
MR. PETROCELLI: Okay. 
MR. BREWER: These are country clubs where you were a member. Is that 
correct? 
THE WITNESS: Yes. THE VIDEOGRAPHER: This is the end of tape 
No. 2 of Volume II. The time is approximately 2:39, and we are off the 
record. (Recess.) THE VIDEOGRAPHER: We are on the record. The time is 
approximately 3:03. This is the beginning of tape No. 3 of Volume II. 
BY MR. PETROCELLI: 
Q: We were talking about the clothing that you wore to Chicago, and you 
said you had the jeans and the loafers, and then we talked a little bit 
about the shoes. You said you also were wearing a shirt? 
A: Pardon me? 
Q: You also were wearing a shirt when you went to Chicago on June 12? 
A: Yes. 
Q: What kind of shirt? 
A: Jean. A jean shirt. 
Q: J-e-a-n, jean shirt? 
A: Yes. 
Q: What was the manufacturer? Do you know? 
A: No . 
Q: The brand? 
A: I don't know. 
Q: What color was it? 
A: Blue. Stone-washed blue. 
Q: Did you have an undershirt? 
A: No. I had on a golf shirt, I believe, underneath it. 
Q: Underneath the  -- this blue stone-washed shirt you had a golf shirt? 
A: Yeah. 
Q: What color was the golf shirt? 
A: White. 
Q: What was the brand, if any? 
A: I don't know. 
Q: And then you had a jacket on? 
A: Actually I used the jean shirt as a jacket, but I had a jacket with 
me also, yes. 
Q: That you carried with you? 
A: I can't recall if I put it in the bag or carried it with me, but I 
had sort of a golf wet jacket with me. 
Q: A windbreaker, you said earlier? 
A: Yeah. Yeah. It's a golf jacket. Windbreaker's a description. There 
was another thing that was a windbreaker, Hertz windbreaker. 
Q: And what was the color of that jacket? 
A: Blue or green. 
Q: Did I show you a picture of that jacket earlier today? 
A: Could have been. 
MR. PETROCELLI: Excuse me, Mr. Baker? 
MR. BAKER: Which jacket are we talking about? He's got the windbreaker 
and Hertz jacket. 
MR. PETROCELLI: I am going to get it out right now. 
MR. BAKER: Thank you. 
MR. PETROCELLI: I need to find the original. 
MR. BAKER: It's 10, I think. 
MR. PETROCELLI: Might be 10. Yeah. One second. 
Q: Let me show you what has been previously marked as Exhibit 10, a 
photograph of a jacket. Is that the jacket you took? 
A: It could have been. 
Q: And did you carry it, or did you have it in the Louis Vuitton bag or 
someplace else? 
A: It wouldn't have been in the Louis Vuitton bag. 
Q: So if it wasn't -- you were not carrying it in your hand, in which bag 
would this jacket have been? 
A: I could have carried it, and I could have just slid it into the suit 
bag that I had. 
Q: With the suit? 
A: With the suit, yeah. Just, you know, unzip it, lay it in there and 
zip it up. 
Q: In that suit bag there was surely a suit. Right? 
A: Yes. 
Q: Pants and matching jacket? 
A: Yes. 
Q: On a wooden hanger? 
A: Yes. 
Q: And anything else in that bag besides the possibility of this 
windbreaker? 
A: Shirt and tie. 
Q: Shirt and tie. 
A: Uh-huh. 
Q: Anything else? 
A: No. 
Q: What is your best recollection: That you carried the windbreaker or 
you packed it? 
A: I don't know. I really don't. I didn't pack it then, but I could 
have thrown it in there, you know. I could have just laid it in there 
so I wouldn't have to carry it on the airplane. 
Q: When you said you didn't "pack it then," what did you mean by 
"then"? 
A: Well, you're talking about packing the Louis Vuitton bag. I packed 
the Louis Vuitton bag in my home, and I didn't have it up in my home 
when I was packing the Louis Vuitton bag. 
Q: Where was it? 
A: In my Bronco. 
Q: That windbreaker was in your Bronco? 
A: I believe so, if that was the one, yes. 
Q: And you were packing the Louis Vuitton bag in your bedroom. 
A: Yes. 
Q: Did you wear the windbreaker that day playing golf? 
A: No. 
Q: The day before? 
A: No. 
Q: What time did you pack the Louis Vuitton bag? 
A: I would say right up to almost 11:00 o'clock. 
Q: When did you start packing it? 
A: Technically? 
Q: What does that mean? 
A: Technically, I put something in it. First time I put something in 
it, somewhere between 8:00 and -- somewhere between 7:30 or so and 9:00 
o'clock. 
Q: Where was the Louis Vuitton bag in your home before you began to 
pack? 
A: In my closet in my bedroom. 
Q: When you took it out of your closet, what time was it? 
A: After 10:00 o'clock. 
Q: What is your best estimate after 10:00 o'clock what time it was 
when you took the Louis Vuitton bag out of the closet? 
A: I don't know. 
Q: When you took that bag out of your closet, you then put it on your 
bed? 
A: Yes. 
Q: And you opened it up? 
A: No. It was open. 
Q: It was open in the closet. 
A: Yes. 
Q: And there was nothing in it. Correct? 
A: I think some underwear and some socks. 
Q: From a prior trip? 
A: No. 
Q: When did the underwear and the socks get into the Louis Vuitton bag 
when it was open in the closet? 
A: Somewhere between 7:30 and 9 o'clock. 
Q: And --  
A: That's a guess. 
Q: What is your best estimate of the time when -- Back up. When did the 
socks and underwear go into the Louis Vuitton bag? 
MR. BAKER: He just answered that question. 
MR. PETROCELLI: Is that right? 
THE WITNESS: Somewhere between 7:30 and 
9:00 o'clock. 
MR. LEONARD: Yeah. 
BY MR. PETROCELLI: 
Q: And when you put the socks and underwear into the Louis Vuitton bag 
from where did you retrieve the bag? 
A: From my closet. 
Q: And it was open in the closet? 
A: I opened it in the closet, yes. 
Q: You can pack in your closet. Is that what you're saying? 
A: Yes. 
MR. BAKER: You can bowl in your closet. 
MR. PETROCELLI: You have to understand, I have one of those little 
closets where it's about eight inches deep, you know. 
MR. BAKER: But you're a mere mortal. 
BY MR. PETROCELLI: 
Q: So you have a walk-in closet. Right? 
A: Yes. 
Q: Off of your bedroom. Right? 
A: Yes. 
Q: At some time between 7:30 and 9:00 you went into your closet, and 
you picked up the bag from the floor? 
A: No. From a shelf. 
Q: From a shelf. 
A: Yes. 
Q: And the bag was empty at that time. Correct? 
A: I'm not so sure of that. 
Q: What was in it? 
A: I don't know. 
Q: Do you have any -- do you have reason to believe that it was not 
empty? 
A: It could have not been empty, yes. 
Q: What could have been in it? 
A: Dirty clothes. 
Q: Did you take the dirty clothes out? 
A: If they were in there? 
Q: Yes. 
A: Yes. 
Q: Where did you put them, if you did so? 
A: In my hamper. 
Q: Where is your hamper? 
A: In my bathroom. 
Q: Next to the closet? 
A: Yeah. 
Q: Now, do you have a place in your closet where you pack, lay the bag 
out, open and pack? 
A: Not always, but sometimes, yes. 
Q: On this occasion did you pack in the closet? 
A: Partially, yes. 
Q: And what location in the closet? 
A: On the floor. 
Q: You laid the bag down on the floor. Correct? 
A: Uh-huh. 
Q: You have to answer audibly. 
A: Yes. 
Q: If there were dirty clothes, you took those out and put them in the 
hamper in the bathroom. Right? 
A: That's correct. 
Q: Then you went and took some socks and underwear and put them into 
the bag. Correct? 
A: Yes. 
Q: How many pairs of socks? 
A: I don't know. 
Q: How many pairs of underwear? 
A: I don't know. 
Q: You were only packing for one or two nights. Right? 
A: Yes. 
Q: And after you put the socks and underwear in the Louis Vuitton bag, 
did you leave the bag there on the floor? 
A: Yes. 
Q: And then did you resume packing at a later time? 
A: Some more packing, yes. 
Q: After you put the socks and underwear, did you leave for a while? 
A: I don't know if it was directly after I put the socks and underwear, 
but obviously I came downstairs again, yes. 
Q: So after the socks and underwear were in the Louis Vuitton bag, you 
came downstairs for a while. Right? 
A: At some point after, yes, after I put them in there, yes. 
Q: And then at some point after 10:00 o'clock p.m., you went back to 
the closet in the bedroom --  
A: Yes. 
Q:  -- and resumed packing. 
A: Yes. 
Q: And where did you continue packing? 
A: I took the Louis Vuitton out of the  -- out of there, put it on my bed. 
Q: Okay. And what did you then put into the Louis Vuitton bag on your 
bed? 
A: Two golf outfits. 
Q: "Two golf outfits," meaning --  
A: One and then -- yeah, eventually two golf outfits, yes. Two golf 
outfits. 
Q: Well, did you pack both of the golf outfits in the Louis Vuitton bag 
at the same time? Did you go to your drawers and pull out two shirts 
and two pants --  
A: No. 
Q:  -- and take them to the thing? What did do you? 
A: I just looked at what outfits I had hanging there, and one outfit I 
knew I was taking, and the other outfit I kind of made a last-minute 
decision. 
Q: And what outfit did you know you were taking? 
A: Just basic outfit with a Hertz -- with a white shirt, black pants, and 
then I decided to bring a yellow shirt just in case for the Hertz 
thing. 
Q: So the white shirt and black pants you put into the Louis Vuitton 
bag first when you began repacking after 10:00 o'clock p.m. Correct? 
A: Yes. 
Q: And what did you then put into the bag next after the white shirt 
and black pants? 
A: I laid a yellow shirt in there. 
Q: A yellow shirt. A golf shirt? 
A: Yes. 
Q: Now, did you do this right after you put in the white shirt and 
black pants, or was there a gap? 
A: I don't know. 
Q: You didn't leave the bedroom, though. Right? 
A: No. 
Q: Now, what did you put in after the yellow shirt? 
A: Maybe a T-shirt. 
Q: White T-shirt? 
A: Yeah. 
Q: An undershirt? 
A: Yeah. 
Q: And then what? 
A: Not much else. 
Q: And then you closed the bag up? 
A: Yes. 
Q: And then did you fold it? 
A: Yes. 
Q: And left it on the bed? 
A: No. 
Q: What did you do? 
A: Brought it downstairs. 
Q: Where? 
A: To the front of the house. 
Q: And laid it where? 
A: Well, he put it in the car the minute I brought it out. 
Q: When you started resuming your packing at 10  -- sometime after 10:00 
o'clock p.m., was the limo driver there yet? 
A: Yes. 
Q: When you started to pack as you've just described, starting with the 
white shirt and black pants, the limo driver was already there? 
A: Yes. 
Q: Okay. Now, when you came down the stairs, did you carry that bag 
down yourself? 
A: Yes. 
Q: Did you carry anything else down? 
A: At that point, maybe my grip. 
Q: Your grip was up in your bedroom too? 
A: Yes. 
Q: And what did you then do? 
A: Walked out front. 
Q: And what did you do next? 
A: Put them on the ground. 
Q: Where? 
A: Front of my house. 
Q: Was the car there? 
A: Yes. 
Q: So you came down the steps --  
MR. BAKER: You mean the limo --  
MR. PETROCELLI: The limo. I'm sorry. 
MR. BAKER -- when you say he talked about a car? 
MR. PETROCELLI: The limo. 
Q: Was the limo there? 
A: Yes. 
Q: You came down the steps. The front door was open or closed? 
A: I believe it was open at that point. 
Q: Who opened it? 
A: Me. 
Q: And was it open the entire time you were packing upstairs? 
A: What do you mean by "entire time"? 
MR. BAKER: He means from 7:30 till approximately 11:00. 
BY MR. PETROCELLI: 
Q: When you took the Louis Vuitton bag out of the closet and put it on 
the bed and started to put in the white shirt and black pants and then 
the yellow shirt and then the T-shirt, you said that the limo driver 
was already there. 
A: Yeah. 
Q: Now, my question to you is: Was the door open during that period of 
time? 
A: Not when I first took it out, no. 
Q: When you first took the Louis Vuitton bag out of the closet and put 
it on the bed --  
A: Uh-huh. 
Q: You have to answer audibly. 
A: Yes. 
Q:  -- the front door was open or closed? 
A: Closed. 
Q: Then you put in the white shirt and black pants and yellow shirt and 
T-shirt. When did you open the front door? When you came down with the 
bag? 
A: What bag? 
Q: The Louis Vuitton bag. 
A: No. Well, I may have opened it. If it was closed again, I would have 
opened it, yes. 
Q: Was the door open or closed when you came downstairs? 
A: At that particular time? 
Q: To put the bag in the car. 
A: I don't recall. 
Q: Did you make another trip downstairs to open the door? 
A: What do you mean? 
Q: During the time that you were packing this Louis Vuitton bag. 
A: I had just been downstairs a few minutes before. 
Q: Are you saying that while you were packing this Louis Vuitton bag as 
it was on your bed, you made a trip downstairs? 
A: Yes. 
Q: Before or after you completed packing these items? 
A: Before. 
Q: You had started to put in these shirts and pants? 
A: Yes. 
Q: But not completed? 
A: Correct. 
Q: You had put in the white shirt and black pants and then stopped? 
A: Yes. 
Q: And then you went downstairs? 
A: Yes. 
Q: And you opened the door? 
A: Yes. 
Q: And then what did you do? 
A: I looked in my golf bag. 
Q: To see if your --  
A: Black shoes were there. 
Q: And they were. 
A: Yes. 
Q: And you went upstairs? 
A: After I laid it off the bench onto the ground and left my suitbag 
there, then I went upstairs. 
Q: Your golf bag was inside the house. Right? 
A: No. 
Q: Previously you testified that it was inside the door. 
MR. BAKER: No, he did not. 
THE WITNESS: That's not correct. 
BY MR. PETROCELLI: 
Q: It was outside. Correct? 
A: Correct. 
Q: You opened the door, it was outside, you looked into it, you left 
the door open and then took your suit bag out also and put it outside? 
MR. BAKER: Let me have that question read back, please. (Pending 
question read.) 
MR. BAKER: That's compound. 
MR. PETROCELLI: Okay, let me reask it. 
Q: You just said you came down, opened the door. The golfbag, which was 
already in the cover bag --  
A: Yes. 
Q: -- was outside on the ground. Right? 
A: No. 
Q: On the bench. 
A: Yes 
Q: Which is outside the door. Right? 
A: Yes. 
Q: And you opened it up, looked in  --  
A: Yes. 
Q: and saw your shoes there. 
A: Yes. 
Q: And you zippered it back up. Right? 
A: Yes. 
Q: And then you went inside. Right? 
A: Yes. 
Q: And did you do anything else before you went upstairs? 
A: No. 
Q: Okay. So you left the door open? 
A: I don't recall. 
Q: And you went upstairs. 
A: Yes. 
Q: And you resumed packing the Louis Vuitton bag. 
A: Yes. 
Q: Put in the yellow shirt and the T-shirt. Right? 
A: Yes. 
Q: Zipped it up --  
A: Yes. 
Q:  -- and then came back downstairs? 
A: Yes. 
Q: And out? 
A: Yes. 
Q: Now, when you came out the door, what did you then do? 
A: I put the bags down, I looked into my grip --  
Q: Put what bags down? 
A: Louis Vuitton and my grip. And I looked in my grip, and I was 
looking for a few things, and I guess I started a conversation with 
Kato maybe right then or maybe a little later, but Kato was saying 
something. 
Q: I want to be clear about these bags. When you came downstairs, you 
were carrying your grip and your Louis Vuitton bag. Right? 
A: Yes. 
Q: And the door was open or closed; you don't remember. Correct? 
A: No. No, I don't remember. 
Q: Then you came out that door, and you are carrying now two bags. 
Right? 
A: Yes. 
Q: And is your golf bag still on the bench? 
A: I think at that point they had already put it in the trunk of the 
car. 
Q: And then you went -- What did you do with your two bags? 
A: Put them right down on the ground right there. 
Q: Right there next to the bench? 
A: Well, between the benches, yeah. Between the benches is what that 
area is, yes. 
Q: Between the two benches. 
A: Yes. 
Q: There is one on either side. 
A: Yes. 
Q: You dropped the bags down. Did someone come and take them? 
A: They grabbed  -- one of them grabbed the Louis Vuitton bag. 
Q: One of whom? 
A: Kato or Alan Park. 
Q: The limo driver. 
A: Yes. 
Q: And put that where? 
A: They were putting it in the trunk of the car. 
Q: And you then looked into your grip, you said? 
A: Yes. 
Q: And what were you looking for? 
A: Whatever I might have forgotten, make sure I had everything. 
Q: And did you forget anything? 
A: Yes. 
Q: What had you forgotten? 
A: My cell phone or the parts  -- other parts of my cell phone. 
Q: You mean the battery packs? 
A: Yeah. I carry -- it comes in a case, and it has another battery and it 
has a plug-in for a car, and it -- what else does it have. A card for all 
the -- you know, just a bunch of stuff. It's a nice little case. 
Q: Are we talking about the cell phone that I showed you earlier? 
A: Yeah, one like that. 
Q: Are we talking about Exhibit 7? 
A: Yeah, one like that. 
Q: Now, when you looked in your grip, the cell phone was not in it? 
A: I don't think so, but it could have, but I know the rest of it 
wasn't in there. 
Q: Meaning the case with the cord? 
A: The case with the cord with the other battery wasn't in there. 
Q: There was already a battery on the phone itse3f. Right? 
A: There's a battery on the phone. There's a charger that's not on the 
phone, there's another battery that's not on the phone, and then there 
is a cord that you can use for a cigarette lighter, and mine comes in a 
nice little case. 
Q: Missing from the grip were the charger, the battery, the cord, all 
of which would be contained --  
A: Together. 
Q: -- in the case. 
A: Yes. 
Q: What color is that case? 
A: Black. 
Q: Where is that case normally kept? 
A: There is no real normal place. Normally with me. If I'm traveling, 
it's normally with me in grip. 
Q: And when you are not traveling, where did you keep the case at that 
time? 
A: No particular place. 
Q: Did you keep it in the car? 
A: Well, sometimes if I got in the car and the case was -- and I had the 
case, I'd take it out of the thing and plug it into the car. Wherever I 
was. 
Q: So normally you kept the case in the grip, and the grip was with 
you? 
A: Yeah. 
Q: Did you take the grip with you to play golf that morning? 
A: No. 
Q: You left it home? 
A: Yeah. 
Q: I am talking about the morning of the 12th, of course. 
A: Yes. 
Q: When you looked into the grip, did anybody see you doing that? 
A: It would have been hard for them not to. 
Q: That was in the area between the two benches. Right? 
A: Yes. 
Q: And you then did not see the case. Correct? 
A: Well, I can't recall even if I saw the phone at that point, but I 
know that those are two things that were  -- at least the case was 
missing. I can't recall right now if I saw the phone because I went in 
the house briefly, and I may have picked the phone up when I went in 
the house in the kitchen at that point, or the phone was there and then 
I came back out, and then, you know... 
Q: This is all while the limo driver is still there? 
A: Yeah. And Kato was walking around. 
Q: Now, you usually take the case with you on trips? 
A: Yes. That's what it is: A travel case. 
Q: And when you looked in your bag, was it your intention to see if the 
case was there and, if it was not there, to make sure you had it? 
A: No. 
Q: What was your intention? 
A: Just to see if I had everything. 
Q: When you saw that the case was missing, you decided you wanted to 
get it? 
A: Yes. 
Q: You wanted to bring the case with you. 
A: Yes. 
Q: And the phone. Correct? 
A: Of course. 
Q: And did you do so? 
A: Yes. 
Q: You brought the case and the phone? 
A: I believe so, yes. 
Q: And did you put the phone into the case? 
A: At some point, yes. 
Q: Did you do that before you got into the limo? 
A: I don't remember. 
Q: And did you then go retrieve the case someplace? 
A: Yes. 
Q: Where did you go get the case? 
A: In the Bronco. 
Q: Where in the Bronco was the case? 
A: On the seat, on the other seat in the Bronco. 
Q: On the passenger seat? 
A: Yes. 
Q: Just sitting there? 
A: Yes. 
Q: Is that where you normally keep it? 
A: It depends. 
Q: Is that where you used to keep it at the time? 
A: Just depends. 
Q: Depends on what? 
A: Depends on where I put it down. 
Q: So you don't have a regular habit  --  
A: No. 
Q:  -- of putting it in a particular place in the Bronco. Is that what 
you're saying? 
A: Yes. 
Q: Did you use that case that day? 
A: What do you mean? 
Q: Did you use the battery, the cord or the charger? 
A: No. 
Q: When you went out to -- Where was the Bronco when you went to get the 
case? 
A: On Rockingham. 
Q: And you went out to Rockingham to get -- to the Bronco to get the case? 
A: Correct. 
Q: Was the limo driver in the car waiting for you while you were doing 
this? 
A: No. 
Q: He had already put in the Louis Vuitton and the golf clubs in the 
trunk. Right? 
A: And I assume my suit bag, because I told him, "Don't smash my suit 
bag." 
Q: You didn't mention coming downstairs with the suit bag. When did the 
suit bag get downstairs? 
A: First of all, you're incorrect. 
Q: I may be. I may not be. Just tell me when the suit bag came 
downstairs. 
A: When I came down to look in my golf bag for my shoes. 
Q: You brought the suit bag with you? 
A: Yes, because I knew I couldn't carry all three of them at once. 
Q: Where did you leave the suit bag? 
A: Right out front with my golf bag. 
Q: On top of the golf bag on the bench? 
A: No, because I put my golf bag on the ground, so -- and I could have 
put the suit bag on top of it or I could have just folded it right 
there on the ground and then looked in my golf bag and then throw my 
golf bag on the ground. 
Q: So in any event, when you went off to get your phone case, the suit 
bag, the Louis Vuitton bag and the golf bag were all in the trunk. 
A: Yes. 
MR. PETROCELLI: Excuse me. Mr. Grornan needs to leave now. THE 
VIDEOGRAPHER: We are going off the record now, and the time is 
approximately 3:27. (Arthur Groman leaves the deposition.) (Pause in 
the proceedings.) THE VIDEOGRAPHER: We are back on the record now, and 
the time is approximately 3:28. 
BY MR. PETROCELLI: 
Q: I think I asked you before. Let me ask you again. I'm not sure what 
the answer -- I remember the answer. When you went to the Bronco to get 
the case, what was Alan Park doing? 
A: Standing around by the trunk of the car, I believe. 
Q: And you left your grip back on the floor between the two benches --  
A: Yes. 
Q:  -- on the ground? 
A: Yes. 
Q: When you went out towards the Rockingham gate, how did you cause the 
gate to open? 
A: Push the button. 
Q: Right on the inside of the gate? 
A: Yes. 
Q: Which side? 
A: Left side. 
Q: And the gate swings inward? 
A: Yes. 
Q: And then you go out the left side. Right? 
A: I don't know. Left side or the right side. 
Q: The box is on the left side, the gate starts to open, and then you 
exit. Correct? 
A: Correct. 
Q: And you walked out to your car? 
A: Yes. 
Q: The Bronco. 
A: Uh-huh. 
Q: You have to answer audibly. 
A: Yes. 
Q: And what did you do? 
A: I looked in my car. 
Q: You looked through the window? 
A: No. I just opened the door. 
Q: Which door? 
A: The driver door. Looked in, saw the case, got -- if that was the 
windbreaker, grabbed that -- I mean the golf jacket, grabbed that. 
Q: You mean Exhibit 10? 
A: Yes. 
Q: And first of all, where was the phone? 
A: The phone, I'm not sure, but I think the phone was either in the bag 
or on my entry table, because I can't be sure if the phone was there or 
not. as I told you before. But the case wasn't. And then when I came 
back  -- yeah, then I grabbed the case and I grabbed the jacket. 
Q: The case was on the passenger seat. Correct? 
A: Yes. Yes. 
Q: Did you open up the case right while you were in the Bronco to see 
what was in it? 
A: No. 
Q: You looked around then for the jacket. Right? 
A: No. The jacket was laying right there in between the seats. 
Q: Between the front seat and the passenger seat? 
A: Yeah. 
Q: On the console? 
A: Partially on the passenger seat and the console, yes. 
Q: And you picked up the case; you picked up the jacket. Did you pick 
up anything else? 
A: No. 
Q: Did you look for anything else? 
A: No. 
Q: How were you able to see while you were doing that? 
A: Because I got eyes. 
Q: Was there any light in there? 
A: Yeah. 
Q: In the car? 
A: I would assume so, but there's certainly light from the 
intersection. 
Q: There was a light -- The car was parked near the intersection? 
A: No. Yeah, I would say so. 20 feet, 30 feet from the intersection. 
Q: The intersection of what two streets? 
A: Ashford and Rockingham. 
Q: And where is there a streetlight there? 
A: Right in the middle of the intersection. 
Q: And you could see inside the Bronco from that streetlight? 
A: I would assume I could have seen inside the Bronco without that 
street light, but, yes, I could see clearly inside the Bronco for what 
I was looking for. 
Q: Was there any light on in the Bronco? 
A: Should have been. 
Q: Why? 
A: Because I think when you open the doors, lights come on the doors. 
Q: There are only lights on the doors? 
A: I don't know. I don't know. I don't really pay attention. When I 
open the door, my car's lights come on. 
Q: Whatever lights are usually on when you open the door came on that 
time, too? 
A: Yes. 
Q: Then you closed the door? 
A: Yes. 
Q: And did you lock it? 
A: I don't recall. 
Q: Do you have a -- How do you lock your car when you leave it, the 
Bronco? 
A: Push a button, I think. 
Q: On a key? 
A: No. 
Q: On the door panel? 
A: Yes. 
Q: Where is that button? 
A: On the door panel. 
Q: Which door panel? 
A: Whichever door, I guess, I'm going in or out. 
Q: Did you press that button that night? 
A: I don't recall. 
Q: Did you lock the car? 
A: I don't recall. 
Q: Is that the only way you can lock the car: By pressing that button 
on the door panel? 
A: I don't know. You may be able to lock it with a key, but I'm not 
sure. 
Q: When you typically locked the Bronco in May-June 1994, how did you 
do so? 
A: I'm sure I would push that button. 
Q: You don't have one of those keys with the automatic lock on it, do 
you? 
A: As I already said. no. 
Q: Okay. And you closed the door? 
A: Yes. 
Q: And how did you get back into the property? 
A: I think -- I'm not sure. I'm not sure of this, but I think the gate 
had closed, and I used my key to open it, the gate. 
Q: There is a key on the outside of the gate? 
A: Yes. 
Q: When you key it, the gate automatically opens again? 
A: Yes. 
Q: When that gate automatically opens at Rockingham, then when you 
press the button on the inside, let's say, does it then close after a 
certain amount of time? 
A: Yes. 
Q: What is that interval of time? 
A: I don't know. 
Q: Roughly. 
A: 30, 40 seconds. 
Q: It opens, it stays open for 30, 40 seconds and then closes? 
A: Yes. 
Q: And is the same true of Ashford? 
A: No. 
Q: How does Ashford work? Or how did it work? 
A: How does it work. You can push it open if it's off the hinges, or 
you can push a button to open it to go out. There is no key you use to 
come in. 
Q: When you are on the outside -- excuse me. When you want to go out of 
the Ashford entrance, there is a place where you can press the button 
to open up the gate? 
A: Yes. 
Q: And is that on the left side also? 
MR. BAKER: As you are going out? 
BY MR. PETROCELLI: 
Q: Yes, as you're going out. 
A: Yes. 
Q: When you press that button, does the gate then -- is the hinge on the 
left side, or is the hinge on the right side? 
A: No. It opens both ways 
Q: Oh, there's two -- okay. Does it swing inside? 
A: Yes. 
Q: And does it also then automatically close? 
A: No. 
Q: It stays open? 
A: Yes. 
Q: How does one close it? Manually? 
A: Yeah, or with -- if you got a thing from the car. 
Q: Oh, like a remote control? 
A: Yes. 
Q: Is there a remote control device for the closing and opening of the 
Rockingham gate? 
A: Yes. 
Q: Is it the same one for both gates? 
A: Yes. 
Q: And you always kept one in the Bronco? 
A: Yeah. 
Q: In the car? 
A: Yeah. They kept getting ripped off by the kids and stuff, so, you 
know, you're always fighting to have one. 
Q: You mean the gate openers? 
A: Yes. 
Q: Where did you keep them in the Bronco? 
A: Wherever. On the dash -- I mean, on the dashboard; sometimes up there, 
but they were all broke; in the glove compartment; on the seat. 
Q: Do you have a separate one for the Bentley? 
A: Pardon me? 
Q: You have a separate clicker --  
A: Yes. 
Q: -- for these doors for the Bentley? 
A: Yes. 
Q: Is it the same clicker that works the garage door? 
A: No. 
Q: Different one? 
A: I don't know if I really have one to work the garage door, but I'm 
sure at one point I did. 
Q: How do you open and close the garage door from the outside of the 
garage? 
A: I don't know if I in recent years ever have. 
Q: For example, when the door was open that evening, it was opened from 
the inside? 
A: Yes. 
Q: Does the outside of the Ashford gate, like the Rockingham gate, have 
a place for a key so that you can make the doors open? 
A: No. 
Q: So if you don't have one of those remote control gizmos, you're out 
of luck? A Yes. 
Q: You can't manually open them can you, by pushing them. 
A: No. 
Q: When you close -- You used the key on the outside of the Rockingham 
gate to get back in. Correct? 
A: I believe so. I'm not a hundred percent sure of that, but I believe 
so. 
Q: And then the door opened -- the gate opened, I should say. 
A: Yeah. 
Q: And then you walked into the gate and then into the car? 
A: I'm sorry? 
Q: You walked into the driveway on Rockingham and then to the limousine 
and then into the car? 
A: No. 
Q: Where did you go? 
A: Kato was talking about some noise, and I talked to him out front and 
asked Park if he had a flashlight and told Kato to go in and look in 
the cupboard in my kitchen. 
Q: The front door was still open? 
A: Yes. 
Q: When Kato said this to you, were you near the front door? 
A: What do you mean? 
Q: In other words, you had walked in through the Rockingham gate and 
walked in the direction of the limousine. Correct? 
A: Yes. 
Q: And when --  
A: Well, to the direction of my front door, yes. 
Q: To the direction of your front door. 
A: Yes. 
Q: Why were you walking to the front door and not to the limousine? 
A: Because my front door was open, and my bag was sitting there between 
the benches in front of my front door. 
Q: The grip bag. 
A: Yes. 
Q: And you went to the grip bag, and what did you do then? 
A: I put the phone thing in the grip bag, and I put -- that's what I did 
at that moment. 
Q: Did you put the jacket in the grip bag? 
A: I don't recall. I may have laid it across it. 
Q: "The phone thing" meaning the case. Right? 
A: Uh-huh. 
Q: You have to answer audibly. 
A: Yes. 
Q: And then at that point in time Kato came up to you and said 
something to you? 
A: Kato had been talking to me even before I went out, and he was 
continuing to talk again when I came back in. 
Q: He mentioned something at that moment in time about sounds? 
A: I think he was talking about it all the time, but I'm not sure. 
Q: Including that time? 
A: Yes. 
Q: And you then asked Mr. Park if he had a flashlight? 
A: When I was coming back in, I said, "Does he have" -- I may have said 
it to Kato and Kato may have said no, and then I know during the course 
of whatever -- I was just trying to pack and leave. 
Q: I want to go back here. When you were coming back to the grip bag, 
your purpose was to put the items in the grip bag or in the car, close 
the door and get in the limo. Right? 
A: Yeah. And I had some other things, yes. 
Q:: You didn't have any further business to do in the house. Right? 
A: Except to close the door. 
Q: Except to close the door. 
A: Yeah. 
Q: Which you closed from the outside. Correct? 
A: I would have, yes, but I didn't. 
Q: You had your keys with you. Right? 
A: Coming back, yes. 
Q: Because you used that to get in the Rockingham entrance 
A: That's right. 
Q: What key chain was that, by the way? 
A: I don't know. 
Q: How many keys were on it? 
A: Two or three. 
Q: What were those keys to? 
A: Probably my house, maybe my office, maybe my New York apartment I 
really don't know. I know my house for sure. 
Q: Are all of the keys to your Rockingham house that you have on a 
single key chain? 
MR. BAKER: You mean in 1994 
MR. PETROCELLI: Correct. June of 1994. 
THE WITNESS: What do you mean? 
BY MR. PETROCELLI: 
Q: In other words, the key chain that had the key that you used get in 
the Rockingham gate --  
A: Yeah. 
Q: -- that also had some other keys? 
A: I believe so, yeah. 
Q: Including the front door. Right? 
A: Yes. 
Q: How many keys to get into your front door are needed? 
A: One. 
Q: Is that the same key as the Rockingham gate key? 
A: Yes. 
Q: They are keyed alike. Right? 
A: Pardon me? 
Q: Same key to use both? 
A: Yes. 
Q: Does that key operate any other exterior doors going to your home? 
A: Yes. 
Q: Which ones? 
A: My bedroom, my closet and every other lock that's in my house. 
Q: So all of the locks in your house, including interior locks, work 
off of one key? 
A: Yes. 
Q: And that would include the exterior front door key and the 
Rockingham gate key? 
A: That's right. 
Q: Did you have any other keys on that chain that had to do with the 
Rockingham property? 
A: I don't think so. 
Q: What other keys did you have on there, if any? 
A: I don't know. I know there were other keys on there, but I don't 
know what they were for. 
Q: Is that where your car key to the Bronco is also? 
A: No. 
Q: To the Bentley? 
A: Probably, yes. 
Q: The Bronco is on a separate --  
A: Yes. 
Q:  -- key chain of its own? 
A: Yes. 
Q: And is there anything else on that key chain? 
A: No. 
Q: When you went to put the stuff in the case and close the door, you 
were -- Kato was talking to you, you asked Park for a flashlight --  
A: Kato may have asked --  
MR. BAKER: He hasn't finished, and it's compound, and I don't know what 
you mean about "the stuff" and  --  
MR. PETROCELLI: Let me withdraw that question. 
Q: When you were going back to the front door to put the stuff that you 
were carrying, I guess the case, I should say, into the grip bag and to 
close the front door, you then encountered Kato and he was talking to 
you. Right? 
A: Yeah, Kato had been talking to me or I had been watching Kato 
talking or hearing him speak almost ever since I first walked out -- the 
second time I walked out the front door. 
Q: Now, when you saw Kato at that moment, did you then go back inside? 
A: What moment? 
Q: That moment when you returned from the Bronco. 
A: Yes. 
Q: Where did you go inside the house? 
A: What did I do or where did I go? 
Q: Where did you go? 
A: I was on my way to the kitchen, and I went in the kitchen. 
Q: What did you do in the kitchen? 
A: Got a drink of water, basically. 
Q: And then you left? 
A: Yes. 
Q: Did you carry your grip bag in with you? 
A: No. I did carry a bag in with me but not the grip bag. 
Q: The grip bag was still on the floor outside between the two benches? 
A: Yes. 
Q: What bag did you carry into the house with you? 
A: A ball bag. 
Q: Where did that ball bag come from? 
A: It was on the ground outside. 
Q: Where outside? 
A: By where I was chipping balls behind my Bentley. 
Q: What was in that ball bag? 
A: Balls. 
Q: Anything else? 
A: Maybe  -- I don't know. Balls. Maybe a golf glove. 
Q: Golf glove? 
A: Yeah. 
Q: And how did that bag with balls and a golf glove in it get on the 
ground near your Bentley? 
A: When I was picking balls out of the back of my Bentley for taking 
with me to Chicago and for chipping away, I dropped the bag. After I 
picked out, I dropped the bag on the ground. 
Q: And you just left it there? 
A: Yes. 
Q: Why? 
A: Because --  
MR. BAKER: Why not? 
THE WITNESS: -- I was doing other things. 
BY MR. PETROCELLI: 
Q: Why did you leave the bag on the ground when you closed up your 
Bentley trunk and went inside? 
A: Because I was doing other things. 
Q: Did you just forget, you mean? 
A: Yes. 
Q: Had you not forgotten, you would have put the bag back into the 
trunk and closed the trunk? 
A: Possibly, yes. Possibly. 
Q: When did you pick up that bag to go inside the house? 
A: When I came back from the Bentley from getting my cell phone stuff. 
Q: Did you get the cell phone out of the Bentley? 
A: No. 
MR. BAKER: You just said "Bentley." You said getting the cell phone out 
of the Bentley. Did you mean --  
THE WITNESS: Out of the Bronco. 
BY MR. BAKER: 
Q: Did you get the cell phone out of the Bronco? 
A: I got the stuff that goes with the cell phone out of the Bronco. 
Q: And the cell phone? 
A: No. 
Q: Just the case? 
A: Yeah, I believe just the case and the stuff and a jacket. 
Q: And a jacket. 
A: Yes. 
Q: So walking back from the Bronco you then picked up that ball bag? 
A: Picked up two bags. 
Q: What bags? 
A: The bag that I put the balls and a windbreaker in and the white bag 
that had nothing but balls in it. 
Q: So then when you were walking from the Bentley to the front door, 
you were carrying three things then, right --  
A: Yes. 
Q:  -- two bags and the case from the Bronco? 
A: Four things. 
Q: And the windbreaker. 
A: Yes. 
Q: And then when you got to the front door area, what did you do with 
these four things? 
A: Three of them I sat down right there --  
Q: What three? 
A: The cell phone I put in the bag, my grip and either laid the jacket 
there and the other bag. I asked Park to get my golf bag. I think he 
was in the process of getting my golf bag, which I don't think he knew 
was a golf bag because he seemed very confused, and Kato was talking 
about where for the flashlight and Juice, you know, "Show me where." So 
I kind of stopped what I was doing, and as I was walking back in the 
house to go show him to go into the cupboard, I had dropped the ball 
bag with all the bag -- balls in it right there at the front door, and 
then I went into the kitchen and he went into the cupboard. 
Q: The ball bag that you dropped near the front door --  
A: Yeah. 
Q:  -- was the white ball bag --  
A: Yes. 
Q:  -- that you had accidentally left outside on the ground by the 
Bentley. Correct? 
A: I'm sorry. 
MR. PETROCELLI: Do you want to repeat that question, please. (Record 
read.) 
THE WITNESS: Your characterization of "accidentally" -- yeah. I 
don't know if it was accidental or it was there. I didn't purposely do 
it, but it was still on my property. 
BY MR. PETROCELLI: 
Q: That's what I meant. You didn't purposely leave it on the ground. 
A: One way or the other. No. It was neither one way or the other. It's 
my house. It was there, yes. 
Q: The white bag. 
A: The white bag, yes. 
Q: With the balls in it. 
A: Yes. 
Q: How many balls were in it? 
A: A whole bunch. 
Q: Scuffed or new or both? 
A: Scuffed, yeah. Used balls. 
Q: Used balls? 
A: Yes. 
Q: Okay. And then you dropped that white bag at the door? 
A: Right inside the front door. 
Q: Inside the front door. 
A: Yes. 
Q: And you had put your case and/or cell phone in the grip? 
A: Yes. 
Q: Left the grip outside still? 
A: Yes. 
Q: And then gave this other bag which had balls and the windbreaker to 
Park. 
A: No. I left it there, but I wanted Park to give me my golf bag so 
that I could put this -- the balls and stuff in my golf bag, but I got 
distracted because Kato was talking to me. 
Q: So before you went into the house to the kitchen, you left that 
other bluish --  
A: I left them right there. 
Q:  -- bag right that had the windbreaker and the new balls --  
A: Yes. 
Q:  -- outside the front door. Right? 
A: That's correct. 
Q: And just dropped -- just laid it down there. Right? 
A: Right with my grip, yeah. 
Q: Did you then before you entered the door tell Alan Park what to do 
with that bag? 
A: No. I was asking him -- I was in the process of asking him to bring me 
my golf bag because I wanted to condense, but Kato was talking to me, 
so I just went in the house with Kato. 
Q: Did you ask Park to get the golf bag out of the trunk? 
A: Yeah. 
Q: Did he do so? 
A: He was beginning to do it, but he seemed a little confused, because 
he was reaching, and I mentioned to him, "Don't smash my suit," and I 
don't know. You know, I didn't know him, so he just seemed a little 
confused. But Kato was talking. This was all happening at once. Kato 
was talking, so I just went inside with Kato. 
Q: When you went inside to the kitchen to get the drink of water --  
A: Yeah. 
Q:  -- did you have any bags with you? 
A: Not in the kitchen, no. 
Q: When you passed the front door and dropped down that white bag, at 
that point in time you had no further bags in your hand? 
A: That's correct. 
Q: And you were carrying nothing. Right? 
A: That's correct. 
Q: You went into the kitchen; you got a drink of water. Right? 
A: Yes. 
Q: From the sink or from the refrigerator? Where did you get the water? 
A: From the washroom. 
Q: From the washroom. Is that near the kitchen? 
A: Yes. 
Q: Where did you get the glass? 
A: From the kitchen. 
Q: And what did you do with the glass when you finished? 
A: Probably sat it right there. 
Q: Where? 
A: Either on the counter or in the sink. 
Q: Kitchen counter or kitchen sink? 
A: Yes, I believe so. 
Q: You said something about looking in the cupboard for a flashlight? 
A: Kato was looking in the cupboard for a flashlight. 
Q: And did you do anything more other than get a drink of water and 
walk out? 
A: Yeah. I wiped my hand. I saw what I thought was blood on my hand, 
and I tore a piece of tissue that was right there and wiped my hand, 
but I was talking to Kato at the same time. 
Q: And after you did that, did you then go to the car? 
A: Yes. 
Q: And when you went out to the car, you went out the front door now. 
Right? 
A: Actually I walked to the front door with Kato, and I was about to 
describe the alarm to him, but we were running late, so I just got in 
the car and told him I'd call him. 
MR. BAKER: The car we're speaking of is the limo? 
MR. PETROCELLI: The limo. 
THE WITNESS: The limousine . 
MR. PETROCELLI: The limo. 
THE WITNESS: Yeah. 
BY MR. PETROCELLI: 
Q: When you came to the front door with Kato, did you begin explaining 
 --  
A: I was --  
Q: Excuse me.  -- did you begin explaining to him about the alarm? 
A: I was talking to him about continuing to look because he -- I wasn't 
really -- it was the first time I really paid attention to what he was 
talking about. So I was talking about him to look further for the 
flashlight, but I was running late, and so I just went and got in the 
car. Talking to Kato -- okay. 
Q: When you came out of the house, did Kato come out with you? 
A: Yeah, I think he was coming out the front door or standing in the 
entry when I got into the limo. 
Q: When you came out of the kitchen to go outside, was Kato walking 
with you? 
A: He was walking behind me. 
Q: Behind you. 
A: Yes. 
Q: When you walked out of the front house -- I'm sorry -- the front door, he 
walked out behind you. Right? 
A: Well, he was behind me. I wasn't looking behind me. So he was behind 
me, yes. 
Q: Did you then turn to close the door? 
A: I didn't see him turn to close the door. 
Q: Did you? 
A: No. 
Q: Did you close the door? 
A: No, 
Q: Did you lock the door? 
A: No. 
Q: You left it open? 
A: No. The door will lock if you close it. 
Q: Does it close automatically, or do you have to manually pull it 
closed? 
A: You'd have to I think manually pull it closed. 
Q: And it locks automatically? 
A: Yeah. It should. 
Q: And that's what you did. Right? 
A: No. I went and got in the car, Kato was behind me, and I thought I 
told him to look for a flashlight and see what's going on. 
Q: When you came out the door, you closed the door and it locked. 
Right? 
A: Yes. 
Q: And then --  
A: No, I didn't close the door. Kato was behind me. I'm assuming Kato 
was going to close the door. 
Q: When you got in the car, was the door closed? 
A: I don't recall. 
Q: Were there any lights on there? 
A: Yes. 
Q: Which lights? 
A: I would assume my coach lights on that were out front, and normally 
the lamps that I normally have on would have been on. 
Q: Where are those lamps? 
A: One's in the entry. One's in the kitchen. 
Q: Inside, you mean? 
A: Yes. 
Q: Do they go on automatically? 
A: Then I don't know. I don't know. 
Q: Do you have any timers? 
A: Yes. 
Q: Did you have them activated that night? 
A: Some parts of the house. I don't know exactly what parts of the 
house they were, but some parts of the house there are. 
Q: Were the timers operating in June 12, 1994? 
A: I'm not sure. but I would think so, but I'm not sure. 
Q: When they are working, what time do the lights go on? 
A: I don't know. 
Q: What time were they set for? 
A: I don't set them. I don't know. 
Q: Which lights were set on the timer? 
A: I don't know. 
Q: Are the coach lights set on the timer? 
A: No. 
Q: Now, when you walked out the front door, did you then go right into 
the limousine? 
A: Yes. 
Q: And did you go into the back seat of the limousine? 
A: Yes. 
Q: Was the limousine pointing towards Rockingham? 
A: Well, it was pointing south, yes. 
Q: And so you went in the seat right behind the driver. Correct? 
A: Yes. 
Q: And that door was already open waiting for you? 
A: Yes. 
Q: And when you got in, did you close the door? 
A: I believe so, yes. 
Q: Or did Park close the door? 
A: I don't recall. 
Q: Was Park already in the driver's seat? 
A: I don't recall. 
Q: Was the trunk closed? 
A: Yes. 
Q: And were the items that were outside put away? 
A: No. 
Q: Where were they? 
A: Sitting right there. 
Q: Sitting right where? 
A: Between the benches. 
Q: And you were inside the limo. Right? 
A: You talking about when I walked out of the front door? 
Q: And you went into the limo. 
A: I grabbed those things and got into the limo. 
Q: What did you grab? 
A: Everything that was sitting between the benches. 
Q: What were those items? 
A: My grip, a little -- the other bag, and I believe the windbreaker. 
Q: "The other bag" --  
A: The jacket, yeah. 
Q: "The other bag" being the bag with the windbreaker and the golf 
balls? 
A: That's correct. 
Q: And so Park never put that bag in the trunk? 
A: No. 
Q: And you never had him take the golf bag out and put it into the golf 
bag? 
A: We never got to that, no. 
Q: But you had asked him to start to do that. Correct? 
A: No. I asked him to get me the golf bag, but Kato was distracting me, 
and so he never got to get me the golf bag. 
Q: When you came back out of the house, did he say, "Mr. Simpson, what 
do you want me to do with this golf bag?" 
A: No, he did not. 
Q: Did he say anything to you? 
A: No, except he was looking very nervous, and I said. "We better get 
going." 
Q: Did you tell -- Did Mr. Kaelin pack any bags into the limousine? 
A: I don't know. 
Q: And Mr. Park, you said, put in the Louis Vuitton, the suit bag and 
the golf club. Right? 
A: I'm not sure. I'm not sure. 
Q: You don't remember? 
A: I think I dropped them, and I went back in the house, and I went 
out. When I went back in the house when I first came down -- secondly came 
down, they were in the limo. The second time I came down, my golf bag 
and my suit bag were in the limo already, so they were already put 
away. 
Q: And the Louis Vuitton bag. 
A: No. I came down with the Louis Vuitton bag, and during the process 
of doing that, I guess they were putting the other bag away, but I 
wasn't really paying attention to them. I was, you know, looking for 
what I was looking for. 
Q: Did you tell Mr. Park not to pack any particular -- excuse me -- not to 
put any particular bag into the trunk? 
A: No. 
Q: Or not to put it into the limo? 
A: No. 
Q: Did you tell that to Kaelin? 
A: No. 
Q: At no time did you say to either Mr. Park or Mr. Kaelin not to 
handle a particular bag? 
A: No. 
Q: So you had in the back seat with you the windbreaker, the grip and 
the other bag? 
A: Yes, I believe so. 
Q: Do you have any explanation why the bags that were left outside on 
the area between the two benches when you went into the kitchen were 
not put into the limousine? 
MR. BAKER: He is not here to give you explanations. He is here to 
answer questions, and he doesn't have to give an explanadon, and I 
instruct him not to answer that question. 
BY MR. PETROCELLI: 
Q: Do you know why those bags were not put into the car? 
A: No. 
Q: Did you tell anybody not to put them in? 
A: No. 
Q: Were you surprised when you came back out and saw that they were 
still there? 
A: No. 
Q: Why not? 
A: Because they didn't look like bags, I would think for me. I know 
what the bags are, so I'm influenced by it. One is a grip that I had 
all my personal things in. It was laying there open, and I was going in 
and out of it. And the other was a windbreaker, and I just assumed -- I 
can't make an assumption for them, but it's -- when I was looking at it, 
I pulled my ticket out to make sure my ticket was there, so maybe he 
just assumed it was my bag. I don't know. I don't know. 
Q: The windbreaker and the grip, but then there was another bag there. 
A: Yeah, but it was a little bag; it wasn't a big bag, and it was put 
with these two bags. So I don't know. You'd have to ask them. I can't 
think for them. 
Q: I am going to show you another photograph, which we will mark as 
Exhibit 25. (Plaintiffs' Exhibit 25 was marked for identification by 
the reporter and is attached hereto.) 
BY MR. PETROCELLI: 
Q: Exhibit 25 is a photograph that shows a bag. Do you see that? 
A: Yes, 
Q: Do you recognize that bag? 
A: Yes. 
Q: What is it? 
A: It's my suit bag. 
Q: Is that the bag that you took to Chicago to carry the suit and the 
shirt and the tie? 
A: Yes. 
Q: And you don't remember if the windbreaker was in there. Correct? 
A: Correct. 
Q: What color is that bag, Mr. Simpson? 
A: Black. 
Q: Did that bag have room to carry any more items in it? 
A: Yes. 
Q: In other words, your Louis Vuitton bag was stuffed, or did it have 
room for additional items? 
A: I could have put more stuff in there, yes. 
Q: Let me show you the next exhibit, No. 26. (Plaintiffs' Exhibit 26 
was marked for identification by the reporter and is attached hereto.) 
BY MR. PETROCELLI: 
Q: 26 contains another -- is a photograph of another bag. Do you see 
that? 
A: Yes. 
Q: Do you recognize that bag? 
A: I believe so. 
Q: What is it? 
A: It's a grip. 
Q: Is that the bag --  
MR. KELLY: I am sorry. I couldn't hear you. 
THE WITNESS: Grip. 
MR. KELLY: A grip bag? 
BY MR. PETROCELLI: 
Q: What color is that bag? 
A: It looks to be blue and sort of leatherish]. 
Q: Now, is that the bag that you took into the back seat with you that 
had the golf balls and the windbreaker? 
A: I believe so. 
Q: That's it? 
A: I believe so. 
Q: Is there any uncertainty in your mind? 
A: Well, it wasn't one of my regular bags, so I'm assuming that was the 
bag. 
Q: This was one of your regular travel bag bags? 
A: Was not. 
Q: I am sorry. I missed your answer. "Well, it wasn't one of my regular 
bags, so I'm assuming that was the bag." Why were you assuming this is 
the bag that you took with you? 
A: Because it looks like the type of bag that was there, and it was 
what I saw in the courtroom. 
MR. LEONARD: Can I just see that for a second? 
MR. KELLY: Dan, could I see that, please? 
BY MR. PETROCELLI: 
Q: And that was the bag that you retrieved initially that evening from 
the Bentley trunk? 
A: Yes. 
Q: Did you have any other bags with you, other than the ones we have 
now described? 
A: No. 
Q: You're sure of that? 
A: Yes. 
Q: In the back of the limo did you do anything with these two bags, the 
grip and this Exhibit 26 bag? 
A: No. 
Q: Nothing at all? 
A: No. Oh, I'm sorry. Say that again. 
Q: Did you ever fiddle around in the bags at all? 
A: Maybe in --  
MR. BAKER: I don't know what "fiddle around in the bags." Don't answer 
that. 
BY MR. PETROCELLI: 
Q: Do you know what that means? 
MR. BAKER: It doesn't matter if he knows what it means. 
BY MR. PETROCELLI: 
Q: Did you look into the bags? 
A: Yes. 
Q: For what purpose? 
A: See what airlines I was going on to tell -- make sure the driver know 
and just, you know, get my ticket out, tear it out of the thing so I 
can carry it, close up the bag, put my cell phone in its case. You 
know, do the whole thing, that kind of stuff. 
Q: And you did all that in your black grip bag. Right? 
A: Yes. 
Q: Did you look into this other bag at all? 
A: No. 
Q: Where was it? 
A: Sitting on the floor, sitting on the seat next to me. 
Q: What kind of car was it? 
A: Stretch limo. 
Q: What color? 
A: I don't know. 
Q: What color was the interior? 
A: I don't know. 
Q: Was the light on in the back? 
A: I don't think so, but it could have come on. I don't think so. 
Q: Did you make any phone calls from the limousine? 
A: No. 
Q: Did the driver take you directly to the airport? 
A: Yes. 
Q: Did you converse with him7 
A: Yes. 
Q: What did you converse about? 
A: About rushing to the airport, about him getting a little lost at one 
point, about Kato. 
Q: What did you tell the driver about getting lost? What was that 
conversation about? 
A: I told him he was going the wrong way. 
Q: When did he go the wrong way? 
A: At Sunset. 
Q: Which way did he go wrong? 
A: When we got to the freeway and he was in the left lane instead of 
the right lane. 
Q: And did he then get on --  
A: Yes. 
Q: -- the right lane? 
A: Yes. 
Q: So he was in the wrong lane. You moved him over to the right lane so 
he could get on the freeway? 
A: Freeway, yes. He was about to stay in the left lane, and the on ramp 
is on the right. 
Q: The on ramp is on the right lane on the east side of the freeway. 
Correct? 
A: It would be the south side. 
Q: Which side of the freeway is the on ramp going south? 
A: It's on the west and it goes south. 
Q: West and it goes south. 
A: Yes. 
Q: And he was on the left. 
A: Yeah, he was on the north lane. 
Q: So you moved him over to the right. 
A: Yes. 
Q: But he didn't get lost. Right? 
A: Yeah. Okay. 
Q: In other words, he didn't go the wrong way. He just was in the wrong 
lane. 
A: Well, I know he was going the wrong way until I corrected him. 
Q: So it turned out he didn't go the wrong way. 
A: Yeah, I corrected him before he went the wrong way. 
Q: And then he got on the freeway going south, and you got to the 
airport? 
A: Yes. Yes. 
Q: What time did you leave Rockingham? 
A: I don't know. I think it was a little after 11:00. 
Q: Before 11:15? 
A: I would think so. 
Q: Sometime between 11:00 and 11:15? 
A: Yes. 
Q: Can you pin it down any closer? 
A: No. 
Q: Did it have a clock in it, in the limo? 
A: I would assume so, but in a stretch limo you can't see over that 
thing to the dashboard. 
Q: Were you wearing a watch? 
A: I may have been. 
Q: What watch were you wearing? 
A: If I was wearing a watch it would have been a Swiss Army watch, 
probably this watch (Indicating). 
Q: That watch right there (Indicating)? 
A: This type of watch, yes. 
Q: And when did you put that watch on? 
A: Who knows. 
Q: When in the evening of June 12 did you put on your watch? 
A: I don't know if I did, but if I had on a watch, this would have been 
the watch. 
Q: You don't remember if you had a watch when you put it on? 
MR. BAKER: Just answer the question. 
THE WITNESS: No. 
BY MR. PETROCELLI: 
Q: Were you looking at the watch while you were in the limousine to see 
if you were going to be late? 
A: No. 
Q: Were you looking at the watch before the limousine? 
MR. BAKER: You have now elevated "I may have had a watch and I don't 
recall if I did" to he had a watch on and was he looking at it, and I 
am going to object and instruct him not to answer the question. 
MR. PETROCELLI: By asking him the questions, it may jog his memory that 
he had such a watch, he was wearing it and was indeed looking at it. 
MR. BAKER: Then frame it correctly. Don't frame it as a fait accompli, 
because it is not. 
BY MR. PETROCELLI: 
Q: You don't remember, do you? 
A: No. 
Q: You don't remember looking at a watch to see if you were running 
late at all. Correct? 
A: Correct. 
Q: Were you looking at clocks in the house to see if you were running 
late? 
A: I looked at a clock. 
Q: Which clock? 
A: In my kitchen. 
Q: How many times did you look at that kitchen clock? 
A: In what period of time? 
Q: The evening of June 12. 
A: I have no idea. 
Q: When you did look at it, what time did it say? 
A: It was after 11:00. 
Q: When you went in to get the drink of water? 
A: Yes. 
Q: Did you look at it any time before that point in time to see if you 
were running late or for any other reason? 
A: I'm sure, if I was in the kitchen earlier that day or that 
afternoon, there's a chance I might have looked at the watch -- I mean 
the clock. 
Q: I mean any time in the evening of the 12th. 
A: If I was in the kitchen, I may have looked at the clock. 
Q: Did you look at any other, clocks in your house the evening of June 
12? 
A: Yes. 
Q: Where were those clocks? 
A: One was by my bed. 
Q: And what other clocks did you look at? 
A: That I'm conscious of, I can't recall. 
Q: And do you remember specifically looking at the bed clock? 
A: Yes. 
Q: What times? 
A: It was -- it registered about 10:40, 10:35 to 10:40. 
Q: What was your purpose in looking at the clock at 10:35? 
A: That's when I became aware that the limo driver was, to me, late and 
I had to get moving, 
Q: The limo driver had not yet arrived? 
A: Yes. 
Q: And do you recall looking at the clock any other time? 
A: No. 
Q: When you were in the bedroom around 10:35 or so and you looked at 
the clock, what were you doing in the bedroom.? 
A: Sitting on my bed, kind of sitting, half laying, sitting on the 
pillows on my bed. 
Q: How long had you been doing that? 
A: 10, 15 minutes. 
Q: So you were lying on the bed for about 15 minutes, sitting or lying -- 
 -- 
A: Yeah. 
Q:  -- on the bed. 
A: Yes. 
Q: And then you saw the clock at 10:35 or so? 
A: 10:35 or 40. It's right in that area. That's what it registered. 
Q: And then you -- when you saw the time, you got up? 
A: Yes. 
Q: And what did you do at that point? 
A: Went and took a dump. 
Q: How long did that take? 
A: I don't recall. 
Q: Then what did do you? 
A: Jumped in the shower. 
Q: How long did that take? 
A: I don't recall. 
Q: Then what did you do? 
A: Got out of the shower. 
Q: Then what did you do? 
A: Dried off. 
Q: Then what? 
A: Started to get dressed. 
Q: Then what? 
A: Started finishing packing my suitcase. 
Q: When you got out of the shower and got dressed, what time was it 
when you finished dressing? 
A: I don't know. 
Q: Was the limo driver there --  
A: Yes. 
Q:  -- when you finished dressing? 
A: Yes. 
Q: Was he there when you got out of the shower? 
A: Yes. 
Q: How do you know? 
A: Because I heard my phone continuing to ring. 
Q: And you didn't answer it? 
A: No. 
Q: When is the first time you heard it ring? 
A: I don't know. 
Q: When is the first time you remember hearing it ring? 
A: At some point in time when I was in the shower. 
Q: You heard the phone in the shower? 
A: Yes. You don't hear it clearly. At some point I thought I heard the 
phone ring, and I opened the door to the shower and I looked at it, and 
the phone was ringing. 
Q: When you are talking about the phone ringing, are you talking about 
the telephone ringing? 
A: Yes. 
Q: Is that what rings when the limo buzzes outside the Ashford gate? 
A: Right. 
Q: Does it ring different than a normal telephone call? 
A: You mean the sound? 
Q: Yeah. 
A: No. 
Q: Can you tell if it's a person out at the gate versus a phone call? 
A: I can, yes. 
Q: How? 
A: It keeps ringing in the line that lights up when it's ringing. 
MR. BREWER: I'm sorry? 
THE WITNESS: The line that lights up when it's 
ringing and it keeps ringing. 
BY MR. PETROCELLI: 
Q: But if you're in the shower, you can't see the line. Correct? 
A: When I open the door to the shower, I can. 
Q: Did you do that? 
A: Yes. 
Q: So you heard the phone ringing, you opened the door to the shower, 
then you looked at a phone instrument, you saw a light on, and that 
told you it was the limo driver. 
A: No. At first I knew it was the limo driver because once I heard it 
ringing, at one point when I was aware of it ringing, I hit the door 
and it continued to ring, so I knew it had to be the gate; and at some 
point as I'm coming out, I looked and it was the gate, but it had 
stopped ringing, It had stopped ringing at that point. 
Q: When you say you "hit the door," what do you mean by that? 
A: The shower door. 
Q: You hit it for what reason? 
A: To open it. 
Q: To open it to see the phone? 
A: Actually I was getting out, but I tend to open the shower door, grab 
my towel, and because my shower is sort of a steam shower, dry off in 
the shower. 
Q: In any event, by looking at the instrument and hearing the constant 
ringing, you knew it wasn't a phone call, but the limo driver. Right? 
A: That's correct. 
Q: Now, did you hear it while you were in the shower then? 
A: At some point, yes. 
Q: And when you got out of the shower and were drying off --  
A: Yes. 
Q:  -- did you still continue to hear it? 
A: No. 
Q: So when you got out, before you dried off, did you go to the phone 
to call the limo driver? 
A: No. 
Q: Can you call from your phone? 
A: I think so. I think you can hit the gate and the gate will open. I 
don't know if it will ring out there. The gate will open out there. 
Q: When you hear  -- when you heard -- Withdrawn. What do you have to do to 
let the limo driver in from upstairs in your bedroom? 
A: Pick up the phone and push a number that's on my phone. 
Q: What number is that? 
A: I don't recall right now. 
Q: Can you talk to the limo driver by picking up the phone and dialing 
some number? 
A: No. Just by picking up the phone, if it's on that line, you can talk 
to the limo driver. 
Q: And if he is not on the line, you can't talk to him, obviously. 
Right? 
A: Yes. 
Q: Will his phone ring on the other, line? 
A: I don't know. 
Q: If you wanted to talk to him but he is not on the line, will it ring 
so that he will pick it up and he can talk to you? 
MR. BAKER: Do you understand that question? 
THE WITNESS: I think I 
understand what he's saying, yes. 
MR. PETROCELLI: Yes. 
THE WITNESS: I don't know. 
BY MR. PETROCELLI: 
Q: Okay. But --  
A: I've never done that. 
Q: In any event, when you got out of the shower, you dried off before 
pressing that button to open the door. Correct? 
A: No. 
MR. BAKER: To open the door? 
MR. PETROCELLI: Open the gate. 
THE WITNESS: No. 
BY MR. PETROCELLI: 
Q: When you got out of the shower, you dried off before doing anything? 
A: Yes. 
Q: When did you go and press the button on your phone that would 
activate the gate and let the driver in? 
A: I didn't. 
Q: You didn't. 
A: No. 
Q: And after you -- But you knew he was out there. Right? 
A: Yes. 
Q: And after you dried off, you dressed. Right? 
A: Yes, started to get dressed and started to pack -- finish packing. 
Q: While you were dressing -- Withdrawn. While you were drying, did the 
phone ring again? 
A: No. 
Q: While you were dressing, did the phone ring again? 
A: Yeah, eventually, yes. 
Q: And did you then, while you were dressing and heard the phone ring, 
press the button to let the gate open? 
A: No. 
Q: And then you finished dressing and then --  
A: Yes. 
Q:  -- did what? 
A: Went outside. 
Q: Did you pack first after you finished dressing? 
A: I don't understand what you're saying. 
Q: When you finished dressing --  
A: Yes. 
Q:  -- did you resume packing? 
A: No. 
Q: You were already packed? 
A: Yes. 
Q: Completely packed? 
A: Completely packed. 
Q: And where was the Louis Vuitton bag? 
A: On my bed. 
Q: Closed and packed. Right? 
A: Yes. 
Q: And that occurred, it was closed and packed, before you went into 
the shower. Right? 
A: No. 
Q: When did you close and pack it? 
A: As I told you before --  
Q: Pack and close it, I should say. 
A: As I told you before, when I came up, I closed it up, I folded it 
up, put on my shirt, put on my jean top and carried it downstairs. 
Q: What I am trying to understand, Mr. Simpson, is: Did you complete 
the packing of the Louis Vuitton bag and closing it up --  
A: Yes. 
Q:  -- after or before you took your shower? 
A: After I took my shower. 
Q: Right after you took your shower, you dried. Right? 
A: Yes. 
Q: And then you dressed. Right? 
A: Halfway, yeah, and eventually, yes. Yes. 
Q: When you were packing your Vuitton bag to finish off the packing, 
were you already fully dressed? 
A: No. 
Q: So you were partly dressed. 
A: Yes. 
Q: You had pants on? 
A: Yes. 
Q: Loafers? 
A: Yes 
Q: No shirt? 
A: Yes. 
Q: And then you resumed packing. 
A: Yes. 
Q: Finished packing. 
A: When I finished packing, yes. 
Q: Put your shirt on. 
A: Yes. 
Q: Then put that other shirt over it Right? 
A: Yes. 
Q: Then went downstairs. 
A: For the second time, yes. 
Q: Now, from the time you got out of the shower to the moment you went 
downstairs, at any time during that interval did you press the button 
to let the limo driver in? 
A: No. 
Q: And how many times did the phone ring from the moment you got out of 
the shower until you went downstairs? 
A: Once. 
Q: And how many times did it ring that occasion? 
A: Once. 
Q: When I said -- how many rings? 
A: Once. 
Q: And you could tell from the line that it was the limo driver. Right? 
A: That and the fact that I picked it up. 
Q: You picked it up and you talked to him? 
A: Yes. 
Q: And what did you then say? 
A: I said, "I'm coming right down. I'm running late, I know. I'm coming 
right down." 
Q: Then you hung up. 
A: I believe so. Yeah, I believe so. 
Q: Did you press the button at that point to let the gate open? 
A: No. 
Q: What did he say to you? Anything? 
A: I think he dialed me right back to say that he had been there, and 
I'm not sure if it was all a part of the same conversation or the phone 
rung immediately right after I said, "Yeah, I'm running late," and then 
I told him. He said something about he had been waiting. I said, "Yeah, 
I know. I was in the shower." 
Q: So you hung up the phone, and then he called right back? 
A: Yeah, I believe so. I believe so. 
Q: And you picked up again? 
A: Yeah. It could have been one conversation. I'm not sure, but I seem 
to recall it, because I know I was irritated when I had to continue 
this conversation with him. 
Q: Irritated about what? 
A: Well, I was running late, and it was like, you know, this guy's 
telling me he's been here. So terrific. You've been here. And it wasn't 
Dale, so... 
Q: Dale? 
A: Dale. 
Q: St. John? 
A: Yes. 
Q: Your regular driver? 
A: Yes. 
Q: For many years? 
A: Yes. 
MR. LEONARD: I don't know about anybody else, but I've got to hit the 
head. I don't know if this is a good time for a break or --  
MR. PETROCELLI: Okay. THE VIDEOGRAPHER: We are going off the record 
now, and the time is approximately 4:17. (Recess.) THE VIDEOGRAPHER: We 
are back on the record now, and the time is approximately 4:42. 
BY MR. PETROCELLI: 
Q: Mr. Simpson, when -- is it clear in your mind that the first time you 
heard the buzzer from the limo driver was when you were in the shower? 
A: Yes. 
MR. BAKER: Well, the phone. 
THE WITNESS: The phone. 
BY MR. PETROCELLI: 
Q: The phone rings. 
A: Yes. 
Q: And you were in the shower. 
A: That's correct. 
Q: And you didn't respond at that time. 
A: Correct. 
Q: And the second time --  
A: I didn't respond by answering it. 
Q: Right. You didn't respond at all. 
A: Yes. 
Q: The second time you heard it is when you were getting dressed. 
Correct? 
A: Yes. 
Q: And you didn't respond then either. 
A: That's incorrect. 
Q: When you were dressing and you heard the phone ring --  
A: Yes. 
Q:  -- did you pick it up? 
A: Yes. 
Q: And you had a little discussion which you've already testified to. 
Right? 
A: That's correct. 
Q: But you did not let him in then. Correct? 
A: Correct. 
Q: And then you finished dressing, packing, going downstairs, and you 
didn't hear the phone ring again during that time. Correct? 
A: Correct. 
Q: And then you went downstairs and out the door. Correct? 
A: Correct. 
Q: And did you let him in then? 
A: He was in then, but -- yeah, he was in then. 
Q: Did you let him in? 
A: No. 
Q: How did he get in? 
A: I assume Kato let him in. 
Q: You don't know? 
A: That's the only assumption I make. 
Q: You didn't buzz him in. Correct? 
A: That's correct. 
Q: You never went to your phone instrument, pressed that button and let 
the gate open. Correct? 
A: That's correct. 
Q: And you didn't do anything to cause the gate to open. 
A: That's correct. 
Q: And when you came downstairs to go out to the Bronco to get what you 
said was the windbreaker and the case for the phone, he was already 
there. Correct? 
A: I didn't come downstairs to do that, no. 
Q: When you came downstairs, though, you did that. 
A: I ended up doing that, yes. 
Q: Came downstairs, looked in your grip bag --  A Yes 
Q:  -- and then went out to the car 
A: Yes. 
Q: The Bronco. 
A: Yes. 
Q: But at that point in time Mr. Park was already in --  
A: Correct. 
Q:  -- and you don't know how he got there. Correct? 
A: Correct. 
Q: Did you ask Kato? 
A: No. 
Q: How would Kato have let him in? 
A: Since he was out front, I'm assuming he pushed the button. 
Q: To the left of the gate? 
A: Yes. 
Q: Would there have been any other way that Kato could have opened that 
gate on Rockford? 
A: I believe so. 
MR. BAKER: On Rockford? 
MR. PETROCELLI: Excuse me. On Ashford. 
THE WITNESS: Yes. 
BY MR. PETROCELLI: 
Q: What are the other options that Kato had to do that? 
A: He could have picked up the phone and pushed whatever number to let 
him in. 
Q: Any telephone in the house? 
A: Yes. 
Q: He had access to the phones in the house? 
A: In his room. 
Q: Even in his room he could operate the gate? 
A: You know, once he got in that room, I never went in that room to see 
what his phone setup was, but before he got in that room I know you 
could have, yes. 
Q: You don't recall if you changed it or not? 
A: I didn't do anything. 
Q: And in Arnelle's room -- she also lived there. Right? 
A: Yes. 
Q: On June 12th. Correct? 
A: Yes. 
Q: And she had the same ability on her telephone to press the button 
and have the gate open. Right? 
A: Yes. 
Q: Is there another button to press to have the Rockingham gate open? 
A: No. 
Q: Does that open by the phones? 
A: No. 
Q: Can you talk to that gate? 
A: No. 
Q: When you got off the bed  -- Strike that. Earlier you testified that 
you went upstairs about 10:20 p.m. and shut off the lights. When you 
went upstairs then --  
A: 10:15, 10:20. 
Q:  -- where did you go? 
A: To my bedroom. 
Q: And is that -- What did you do when you got to the bedroom at that 
time? 
A: Sat on my bed and kinda laid back on my bed. 
Q: And then you noticed the clock around 10:35 or 10:40, and then you 
got up and you went to the bathroom. Right? 
A: Yes. 
Q: And at that time you knew that you had to hustle to get out of 
there. Right? 
A: Yes. 
Q: How long were you in the bathroom? 
A: I don't know. 
Q: Less than five minutes? 
A: I don't know. 
Q: More than five minutes? 
A: I don't know. 
Q: What's your best estimate? 
A: I don't have one. 
Q: How long were you in the shower? 
A: I don't know. 
Q: When you were on the bed, you were dressed. Right? 
A: Yes. 
Q: What were you wearing? 
A: Probably some pants and a shirt. 
Q: What was the color of the pants you were wearing? 
A: Probably a royal bluish pants. 
Q: What was the color of the shirt? 
A: I believe white. 
Q: Did you have socks on? 
A: I believe so, yes. 
Q: What kind of socks did you have on? 
A: White socks. 
Q: And did you have shoes on? 
A: No. 
Q: What happened  -- Were you wearing shoes when you were outside chipping 
the golf balls and leaving the Bentley and going upstairs? 
A: Yes. 
Q: What shoes were those? 
A: Tennis shoes. 
Q: White? 
A: Yes. 
Q: Reebok? 
A: I believe so. 
Q: When did you take those shoes off? 
A: When I got upstairs. 
Q: Where did you put them? 
A: I don't know. I think I probably just kicked them off my feet when I 
laid on the bed. 
Q: Now, the pants and shirt that you were wearing, is that what you 
were wearing to the... You said that the pants were a royal blue? 
A: Yes, I believe bluish -- blue. Blue. It could have --  
Q: Dark blue? 
A: Could have been dark blue, yes. 
Q: You sure of that color? 
A: Yes, I'm pretty sure of that color. 
Q: Were they -- And the shirt was a white shirt? 
A: I believe so, yes. 
Q: Open-collar shirt? Polo shirt? What kind of shirt? 
A: Golf shirt. 
Q: Golf shirt. Were those the same clothing you had worn to the 
recital? 
A: No. 
Q: When you came back from the recital, you changed? 
A: Yes. 
Q: And you changed into these royal blue pants and this golf shirt? 
A: Yes. 
Q: You're not sure that it was a white shirt. Correct? 
A: At this recollection right now, no. 
Q: It could have been a dark shirt. Correct? 
A: Could have been darker, yes 
Q: Now, when did you put these clothes on? 
A: When I -- between 7:30 or so and 9:00 o'clock. 
Q: What did you wear to the recital? 
A: Black pants, I believe a white shirt, black sweater-jacket 
Q: Black pants, white shirt and what? 
A: I believe a black sweater-jacket. 
Q: Socks? 
A: I'm not sure. 
Q: And shoes. 
A: Yes, black shoes. 
Q: What kind of shoes? 
A: Dress shoes. 
Q: Loafers? 
A: Yes. 
Q: Made by whom? 
A: I don't know. 
Q: You don't remember? 
A: I don't think I ever knew. 
Q: Did you buy them? 
A: Yes. 
Q: Where did you buy them. 
A: I don't remember. 
Q: What time did you take these clothes off? 
MR. BAKER: What do you mean, "these clothes"? 
BY MR. PETROCELLI: 
Q: The black pants, the white shirt, the black sweater-jacket and the 
black dress shoes that you wore to the recital. 
A: Sometime between 7:30 and 9:00 o'clock. 
Q: Can you fix the time any better than that? 
A: No, 
Q: Why did you take those clothes off? 
A: Because I was beginning to pack, and I was lounging around, and they 
weren't lounge-around clothes. 
Q: And you took them back when you got back from the recital? 
A: Yes. 
Q: As soon as you got back? 
A: I don't think immediately, no. 
Q: You lounged around for a while in those clothes? 
A: No, I was not lounging around. After that, when I decided I was 
going to hang around the house, I lounged around. 
Q: When you got back from the recital, there was a period of time that 
you were home, and then you changed? 
A: Yes. 
Q: How long were you home before you changed after the recital? 
A: I don't know. Half hour, maybe, 40 minutes, 50 minutes. 
Q: Half hour to 50 minutes? 
A: I would say so, yeah. 
Q: When you took those clothes off, you were up in your bedroom? 
A: Yes. 
Q: In that closet? 
A: Yes. 
Q: What did you do with those clothes? 
A: Hung them up. 
Q: And you put on what clothes? 
A: I put on the golf pants that I had worn that day, a shirt, some 
white socks. 
Q: Now, the golf pants you wore, were those the blue pants that you 
just told me about? 
A: Yes. 
Q: Same ones you played golf in? 
A: Yes. 
Q: And you put on this shirt. 
A: Yes. 
Q: The color of which you cannot recall. 
A: Correct. 
Q: And then you put on socks and Reeboks. 
A: No. Just socks at that point. 
Q: What time did you leave the Rockingham house to go to the recital? 
A: About 5:00. 
Q: 5:00? 
A: Yes. 
Q: What time did you get dressed? 
A: A little before 5:00. 
Q: What time did you start getting dressed? 
A: A little before 5:00. 
Q: Quarter to 5:00? 
A: Possibly. Maybe even a shorter time than that. 
Q: Like 10 to 5:00? 
A: Could be. I was running late. 
Q: Did you take a shower? 
A: No. 
Q: Are you sure of that? 
A: Yes. 
Q: And when you were on your bed and noticed it was 10:35, 10:40 and 
decided to get changed, the clothes that you took off were these golf 
pants and this shirt. Correct? 
A: Yes. 
Q: And those were the clothes that you wore while you were chipping and 
hitting golf balls on your lawn. Right? 
A: Yes. 
Q: And those were the clothes that you wore when you left the Bentley 
and went upstairs around 10:15, 10:20. Correct? 
A: Yeah, correct. 
Q: And -- Now, you said when you went upstairs, you closed the lights, 
and what lights --  
A: I turned off the lights at some point downstairs, yes. 
Q: You previously testified that you did so when you left the Bentley, 
went into the house and went upstairs. 
MR. BAKER: Don't answer that question. You can ask him a question, but 
you're not going to interrogate him on your interpretation of what he 
previously said. 
BY MR. PETROCELLI: 
Q: Did you turn the lights off when you went into the house from your 
business at the Bentley on your way upstairs? 
A: What lights were still on downstairs, big lights, yes. 
Q: What lights did you turn off downstairs that you just referred to? 
A: If -- probably the kitchen lights. because I think I had previously 
turned out all the TV and the lights that were in my den and stuff. 
Q: The lights in your TV room, if on, can be seen -- first of all, 
they're on the first floor. Right? 
A: Yes. 
Q: And those lights can be seen from Ashford out in front of the gate 
there? 
A: No. 
Q: If they're on, nobody can see that? 
A: That's correct. 
Q: But they were off. 
A: I believe I turned them off, yes. 
Q: Then you turned off the big lights downstairs. Right? 
A: The overhead lights in the kitchen I believe so. 
Q: And then you turned off the coach lights outside? 
A: I don't think so. 
Q: They were not on, though. Correct? 
A: I'm not sure. 
Q: What's your best recollection? Were they on or not on? 
A: I don't have a recollection one way or the other. 
Q: Then you turned off the entryway light on the other side of the 
front door. Correct? 
A: I don't think so. 
Q: Were those lights already off? 
A: I believe so. 
Q: So when you went upstairs around 10:15, 10:20 p.m., there were no 
lights on downstairs to your knowledge. Correct? 
A: That's incorrect. 
Q: What lights were on? 
A: A lamp in my kitchen and my lamp in my entry. 
Q: And can -- do those lights project light outside of the home onto the 
property? 
A: It depends. 
Q: It depends on what? 
A: If you're sitting in front of the front door or if you're sitting in 
front of the kitchen. 
Q: If you're sitting in front of the front door, can you see any lights 
on? 
A: Yes. 
Q: If you're sitting in front of the kitchen, can you see any lights 
on? 
A: Yes. 
Q: If you are sitting out at the Ashford gate. can you see any lights 
on? 
A: No. 
Q: How do you know that? 
A: Because I've done it. 
Q: When did you do it? 
A: Numerous times. 
Q: Did you do it in the last month? 
A: Yes. 
Q: For what reason? 
A: To prove it to some people. 
Q: To whom did you prove it? 
A: To my lawyers. 
Q: Which lawyers? 
A: My current lawyers. 
Q: The lawyers sitting here to your right? 
A: Yes. 
Q: And what did you attempt to prove? 
A: Just showing them that you can't tell what lights are on in my house 
from the gates. 
Q: Did you do it at night? 
A: Yes. 
Q: At 10:00 -- What time was it? 
A: Late at night. I don't know exactly what time. 
Q: After 10:00 o'clock p.m.? 
A: Possibly. 
Q: And what lights did you turn on downstairs? 
A: Virtually all of them. 
Q: Every single light downstairs? 
A: I said "virtually," not all. I would say 90 percent of the lights. 
Q: Did you turn on the lamp in the kitchen? 
A: Yes. 
Q: The lamp in the entryway? 
A: Yes. 
Q: The big light in the kitchen? 
A: No. 
Q: Did you turn on the coach lights outside? 
A: I think at one point they were, yes. 
Q: But at one point they were not turned on. 
A: Yes. 
Q: Correct? 
A: Yes. 
Q: And did you turn on the lights in the TV room? 
A: All of them. 
Q: All of them. 
A: Yes. 
Q: And did you then turn on any other lights? 
A: Yes. 
Q: Which ones? 
A: All the lights in my dining room, all the lights in my living room, 
all the lights in my tennis room, all the lights in my bedroom, all the 
lights in my bathroom, yes. 
Q: What lights downstairs did you leave off? 
A: Downstairs? The overhead lights in my kitchen and my office. 
Q: Why did you leave those lights off? 
A: Because those are lights I don't believe was on the night of the 
12th. 
Q: And then you went and positioned yourself on the other side of the 
gate at Ashford? 
A: Inside and outside of the gate, on both gates. 
Q: And what did you see? 
A: A house that looked like no lights were on. 
Q: Why did it look like no lights were on? 
A: You'd have to ask God that. 
Q: Why? 
A: Because --  
MR. BAKER: Because he's a physicist. 
THE WITNESS: He's a physicist and 
I'm not. 
BY MR. PETROCELLI: 
Q: You could not see any lights? 
A: Nobody with me could see any lights. 
Q: How do you know that? 
A: Because they said it. 
Q: Who said it? 
A: Whoever I was with. 
Q: And who were you with? 
A: I've done this -- I can't recall who  --  I've done this with virtually 
everyone who's come into my house. 
Q: You've done it with Bob Baker, Dan Leonard and Bob Blasier. Right? 
A: Yes. 
Q: Who else have you done it with? 
A: A film crew. 
Q: That made your video? 
A: That's correct. 
Q: Anyone else? 
A: Just about everybody who's come to my house who -- I can't recall who. 
Q: You make a point of doing it when they come to your house? 
A: Yes. 
Q: What else do you make a point of doing? 
MR. BAKER: If anything. 
THE WITNESS: Treating them very nice. 
BY MR. PETROCELLI: 
Q: Do you make a point of proving anything else to these people? 
A: Yes. 
Q: What else? 
A: That my housekeeper can cook and that my mom's a great cook and that 
I'm a good host. 
Q: Did you make a point of proving anything else that you were innocent 
of these charges? 
MR. BAKER: That's argumentative. Don't answer that. 
BY MR. PETROCELLI: 
Q: You said you were trying to prove to these people that nobody could 
see the lights, and that's for the purpose of proving some fact that 
you think is important to your case. Correct? 
MR. BAKER: He didn't say that. 
THE WITNESS: I didn't say that. 
MR. BAKER: Don't. Don't. 
BY MR. PETROCELLI: 
Q: Why do you prove this fact to so many people who come to your house? 
What's your purpose in doing it? 
A: That's a question that's asked. 
Q: It's always volunteered by the other person? 
A: Except with the film company, yes. 
Q: What do they ask you, these people? 
A: Why no lights were on in my house that night. 
Q: And what you do you say? 
A: I say that was incorrect. 
Q: What was incorrect? 
A: That assumption that there were no lights on in my house. 
Q: You know for a fact that all these lights that you just described 
were on? 
A: When? 
Q: You've already -- I want to be clear about this. When you went upstairs 
at 10:15, 10:20, the only lights that you said were on -- or that were 
on, I should say, were the lamp in the kitchen and the lamp in an 
entryway. Correct? 
A: No, that's not correct. 
Q: What else was on? 
A: My bedroom lights. 
Q: The only lights downstairs were the lamp in the kitchen and the lamp 
in the entry. Correct? 
A: Yes, I believe so, yes. 
Q: When you came downstairs the first time after showering and going to 
the bathroom and all that, you came downstairs with the Louis Vuitton 
bag. Did you turn on any lights? 
A: I don't think that's correct. 
Q: What's not correct? 
A: That I came down the first time with the Louis Vuitton bag. 
Q: After you were dressed. 
A: Yes. 
Q: Came down with what bag? 
A: Louis Vuitton, after I was dressed, completely dressed. 
Q: Had you turned on any lights by then? 
A: I don't know. I don't really know. 
Q: What's your best --  
A: I may have turned on -- then I may have turned on the coach lights. 
Q: When you came down with the Louis Vuitton bag? 
A: No. I may have turned them on earlier. 
Q: What time? 
A: When I came down with my suit bag to look for my shoes and my golf 
bag. 
Q: Before or after you dressed? 
A: Before I got completely dressed. 
Q: Half dressed? 
A: Yes. 
Q: No shirt on? 
A: No shirt on. 
Q: You walked downstairs with the suit bag and laid it outside where 
the golf bag is. Right? 
A: Yeah. 
Q: And at that time you turned on a light? 
A: I may have, when I went back in, turned on the coach lights. 
Q: And the coach lights but not the entryway light. Correct? 
A: Yes, I believe so. 
Q: And Park was already there at that time. Right? 
A: He was at the gate. 
Q: Not in. 
A: Not in. 
Q: Kato hadn't let him in yet. 
A: As far as I know, no. 
Q: And you went upstairs, finished dressing, came back down with the 
Louis Vuitton bag. Right? 
A: Yes. 
Q: Did you turn any lights on at that point? 
A: I don't think so. 
Q: And by this point Park was there, Right? 
A: Yes. 
Q: Now, when you were half dressed and the phone rang and it was Park, 
why didn't you let him in then? 
A: Because I didn't want to open my gate. 
Q: Why not? 
A: I didn't want my dog to go out. 
Q: Where was your dog? 
A: In the front yard. 
Q: As it turned out, your gate was opened without your knowledge, 
anyway. Right? 
A: Yes. 
Q: Did your dog run out? 
A: No. 
Q: How do you know? 
A: Well, I really don't know. Maybe he did. But Kato was there at that 
point in time, so I may have mentioned to Kato -- I may have; I may not 
have, but I normally do. I wouldn't have worried about it because 
somebody would have been there to get her back in. 
Q: Chachi? 
A: Chachi. 
Q: And when you -- Was Chachi outside? 
A: Chachi lives outside, yes. 
Q: She never goes into your house? 
A: She's been in my house once or twice, but... 
Q: Was she outside on the evening of June 12 when you were doing the 
golf balls? 
A: Yes. 
Q: And when you went back down to go to the Bronco to get the cell 
phone and/or the cell phone case, was she outside? 
A: Outside of the house, yes. 
Q: When you opened that gate to go out to the Bronco, did she go out 
the gate? 
A: At that time, no. 
Q: Did you look for her to restrain her before you went out? 
A: I always do, yeah. I have look to see where she is. 
Q: Did you see her? 
A: I didn't see her, so I knew she wasn't where she can go out. 
Q: But when you were at the Bronco, she could have gotten out. Correct? 
A: Which time at the Bronco? 
Q: When you went out that time to get the phone. 
A: The last time. 
Q: The last time that you've mentioned to us. 
A: Yes, but I wasn't concerned because Kato was there then. 
Q: When you went to get the phone or the phone case and the 
windbreaker. Kato was --  
A: Was there, so he could have gotten her in while I was gone. 
Q: Did you tell Kato, "Hold on to the dog" or "Watch the dog"? 
A: No. I didn't need to do that, no. 
Q: Why not? 
A: Because I didn't see the dog go out. Because it's understood at my 
house, as a rule at my house, because the SPCA has given us numerous 
warnings, as a rule at my house with housekeepers and Kato and everyone 
there: Don't let the dog out. So everybody is sort of aware that you 
don't let the dog out. 
Q: And you were aware of that when you went to the Bronco? 
A: I'm aware of that even every morning when I leave to go play golf. 
Q: So you didn't want to let the limo driver in because the dog might 
get out. Is that what you're saying? 
A: Yeah, and I didn't know if Kato was around or not, so I wouldn't 
have time to look for her. 
Q: When you came downstairs the last time and saw the limo driver 
there, were you concerned that your dog might have gotten out 
inadvertently? 
A: Not so much, no. 
Q: Did you ask Kato, "Did the dog get out?" 
A: No. 
Q: Did you ask the driver? 
A: No. 
Q: Did you ask Kato or the driver anything about the dog? 
A: I don't think so. 
Q: You just said that you -- I asked you a question about going to the 
Bronco. You said "the second time." Did you go to the Bronco another 
time? 
A: Yes. 
Q: An earlier time? 
A: Yes. 
Q: When did you go to the Bronco on the evening of June 12 an earlier 
time? 
A: When I was chipping balls and looking for my sand wedge. 
Q: You described what you did at the Bentley truck already. 
A: At the Bentley car, yes. 
Q: The Bentley car. Excuse me. 
A: Yes. 
Q: And when did you go to the Bronco in reference to what you did at 
the Bentley? 
A: After I put my pitching wedge back in the trunk of the Bentley, I 
walked and looked into the back window of the Bronco to see if there 
were any clubs back there. 
Q: After you got the pitching wedge out of the Bentley, hit those golf 
balls wherever you hit them --  
A: Yes. 
Q:  -- you put the pitching wedge back --  
A: Yes. 
Q:  -- took out the bag? 
A: Yeah. 
Q: You took out the bag with the balls and the windbreaker, you put it 
on the ground and then you went to the Bronco? 
A: No, not correct. 
MR. BAKER: Compound question and the sequence is wrong. 
THE WITNESS: Yeah, the sequence is wrong. 
MR. PETROCELLI: Let's get it right then. Okay? 
MR. LEONARD: He did get it right. 
MR. PETROCELLI: Well, I'm kinda slow. Let me see if I can sort it out. 
Q: You got the --  
MR. BAKER: This is the third time we are going over this, and I am not 
going to let him go over it again. 
MR. PETROCELLI: He has not discussed going to the Bronco before at all. 
MR. BAKER: Discuss going to the Bronco then, but you keep going back, 
and I think it's untoward to have him go over and over and over the 
same thing, and you've done it 15 times today; and you can talk all you 
want about him going to the Bronco the first time, but we are not going 
to sequence -- we are not going to resequence the events that we've 
already sequenced. 
MR. PETROCELLI: Let's try to move on. It's getting late. Okay? 
Q: Did you go to the Bronco after you completed all of the activities 
that you previously described at the Bentley? 
A: Yes, sir. 
Q: You had finished hitting all your golf balls. Right? 
A: Yes, sir. 
Q: And you had closed the trunk of the Bentley. Right? 
A: Yes. 
Q: So on the ground was the bag with the windbreaker. 
A: Yes, I believe so, yes. 
Q: Okay. Before you went inside, you then went to the Bronco? 
A: Yes. 
Q: Okay. You pressed the button? 
A: Yes. 
Q: Rockingham gate opened up? 
A: Yes. 
Q: You went out and you went to the Bronco. What did you then do at the 
Bronco? 
A: I looked into the back of the Bronco. 
Q: For what reason? 
A: To see if I had any clubs there. 
Q: Did you? 
A: No. 
Q: You could see? 
A: Yes. 
Q: Then what did you do? 
A: I waited for my dog, and we walked around and came in the Ashford 
gate. 
Q: You waited for your dog to do what? 
A: I guess she took a dump. 
Q: Oh, the dog had come out the property? 
A: Yes. 
Q: On the Rockingham side? 
A: Yes. 
Q: And you waited until the dog finished its business? 
A: Yeah. It went over across the street and up a little bit into ivy 
and various things and took a dump. 
Q: The dog did. 
A: Yes. 
Q: While you were standing at the Bronco? 
A: Yes. Yes. 
Q: Doing what? Just watching? 
A: Yeah, just -- you know, I had what they call a 3 wood in my hand, and 
I was swinging a 3 wood. 
Q: Where did you get the 3 wood? 
A: Out of my garage. 
Q: And then that was after you did the chipping of the golf balls --  
A: That was before. 
Q:  -- with the pitching wedge? 
A: That was before. 
Q: You had gotten the 3 wood out. Right? 
A: Yes. 
Q: And you had laid it next to you when you were hitting the other 
club? 
A: I don't think next to me. I may have laid it against the trunk, you 
know, the open trunk, possibly laid it there. I guess. 
Q: Of the Bentley? 
A: Yes. 
Q: After you closed the Bentley, you then took the 3 wood? 
A: Yeah, the 3 wood I had, and I was just swinging it. 
Q: When you went to the Bronco, you took it with you? 
A: Yes. 
Q: Did you take anything else with you? 
A: Other than what I had on me? 
Q: Yeah. Carrying anything else? 
A: In my pocket, yes. 
Q: What? 
A: I had a cell phone. 
Q: In your pocket? 
A: Yes. 
Q: How long had the cell phone been in your pocket? 
A: Since I had gone into the garage. Actually, maybe not. Maybe I went 
and grabbed it after I was in the garage. 
Q: Grabbed it from where? 
A: The kitchen. 
Q: When you went outside to go hit golf balls? 
A: Yes. 
Q: You went into the kitchen, grabbed your cell phone? 
A: Yes. 
Q: And put it in your pocket? 
A: No. I made a phone call. 
Q: On the cell phone? 
A: Yes. 
Q: Who did you call? 
A: Paula Barbieri. 
Q: What time was that? 
A: I don't know. I didn't know at the time. I know now. 
Q: Now, when you called Paula Barbieri from your cell phone, where were 
you literally standing? 
A: In front of my house right behind my Bronco. By the time it was 
ringing, I was standing behind my Bronco. 
Q: Had you already hit the golf balls? 
A: No. I hadn't even gotten them yet. 
Q: You hadn't swung the wood either? 
A: No. I was swinging the wood. 
Q: So let me get this straight. You got the phone from the kitchen --  
A: Uh-huh. 
Q:  -- and you went outside the front door? 
A: No. 
Q: Where did you go? 
A: Outside the garage door. 
Q: You went into your garage from the inside of your house? 
A: Yeah. It's right at my kitchen, yes. 
Q: Opened up the light? 
A: The light was already on. 
Q: The back light? Was the door open already? 
MR. BAKER: I don't know what the "back light"  --  
MR. PETROCELLI: He said there were two lights in the garage. THE 
WITNESS: Yeah, it was already on. 
BY MR. PETROCELLI: 
Q: Was the door already opened? 
A: Yes. 
Q: The garage door? 
A: I believe so. Yes. I'm not sure of that, but I think so. I'm not a 
hundred percent sure of that. 
Q: When had you opened the garage door? 
A: When I came out to look in my Bentley. 
Q: So when you went to get the cell phone in the kitchen, this was 
before you had gone to the Bentley to open up the trunk and look for 
the clubs. Correct? 
A: As I said a few minutes ago, that's correct. 
Q: So you went into the garage from the kitchen, and you went -- opened 
the light into the garage. Right? 
A: Yes. 
Q: Went out the front -- went out the garage door. Right? 
A: No. I looked for my sand wedge, and I grabbed  -- and I was also 
looking for a 3 wood. 
Q: Did you find a sand wedge? 
A: No. 
Q: Found a 3 wood? 
A: Yes. 
Q: What did you do with the 3 wood when you came out of the garage? 
A: I walked back to the door to the kitchen to push the button to open 
the garage door, and opened the door to the kitchen, walked in, grabbed 
my cell phone and walked back out to the garage. 
Q: So now you come back out the garage with the 3 wood and the cell 
phone. 
A: Correct. 
Q: Then what do you do? 
A: I put a call in to Paula and opened the trunk of my Bentley. 
Q: So you were standing near the Bentley when you called Paula. Is that 
right? 
A: That's correct. 
Q: And the clothing you were wearing? 
A: Was whatever I had on from --  
Q: Dark blue pants and a shirt, the color of which you can't remember? 
A: Yes. 
Q: Did you talk to Paula? 
A: No. 
Q: Did you reach an answering machine? 
A: Yes. 
Q: Did you leave a message? 
A: Yes. 
Q: What was your message? 
A: I don't recall. 
Q: Do you recall anything that you said? 
A: Well, yeah. I said I was wondering what was happening, because she 
hadn't called me, said what was going on. 
Q: And --  
A: And I thought it was her last chance of taking me to the airport. If 
I had of got her, we had enough time for her to take me to the airport, 
if she was in town. 
Q: Okay. If she was in town, you were figuring that she would come over 
and pick you up? 
A: Yes. 
Q: You had already ordered the limo. Right? 
A: Yes. 
Q: So then you went -- After you made your phone call, what did you do 
with the cell phone? 
A: Put it in my pocket. I may have just sat it there because I hit a 
few balls, and then grabbed it and put it in my pocket then swung the 3 
wood. 
Q: After you made the phone call, you either put the phone down or in 
your pocket. 
A: Uh-huh. 
Q: If you put it down, where did you put it? 
A: Right there at the trunk of the Bentley. 
Q: And you opened up the trunk, and you described what you did at that 
point. 
A: Yeah. 
Q: Closed the trunk. 
A: Yes. 
Q: Took your 3 wood, went out to the Bronco . 
A: Yes. 
Q: Dog went out. 
A: Yes. 
Q: And you looked into the Bronco. 
A: Yes. 
Q: And you were looking for your sand wedge. 
A: Yes. 
Q: You didn't find it. Right? 
A: Correct. 
Q: You waited for the dog to finish and then --  
A: We walked up the street. She went across and up a way. First she 
went to Stanley Sheinbaum's stuff. and she walked up, started going up 
the grass to the other, and I was just on the grass walking, swinging, 
and then finally, "Come on, Chachi," and we went into the Ashford gate. 
Q: The Rockingham gate closed behind you? 
A: Yes. 
Q: And then you entered in the Ashford gate? 
A: Yes. 
Q: How did you get into the Ashford gate? 
A: Pushed it. 
Q: From the outside of the gate? 
A: Uh-huh. 
Q: You need a key? 
A: No. I keep one gate on the hinge, and only we know this, but 
normally I would keep one gate off hinge. So it works if you push the 
button, or if you're walking the dog and you come home and you want to 
get on the property and you don't have a key, you just push the gate. 
Q: You just push the gate manually. 
A: You have to kind of know how to do it. You can't just walk and push 
it. There is a little trick to it that I'm not going to tell America. 
Q: Okay. So does the trick still work? 
A: Well, now I got security and we keep everything locked all the time. 
Q: You pushed the gate; you went in with the dog? 
A: Yes. 
Q: On Rockford and closed the gate behind you? 
A: Yes. 
Q: And then you went inside? 
A: Yes. 
Q: Closed the lights and went upstairs. 
A: I went --  
MR. BAKER: I don't know what "Rockford" is. 
MR. PETROCELLI: I'm sorry. Ashford. 
THE WITNESS: I went in, closed the 
garage door, turned off the lights, yeah. 
BY MR. PETROCELLI: 
Q: And that's about 10:15 or 10:20. Correct? 
A: Yes. 
Q: What did you do with the 3 wood? 
A: Laid it back -- when I went in the garage, just put it back in the 
garage. 
Q: Through the inside of the house? 
A: What do you mean? 
Q: You went in through the front door. 
A: No, I didn't. 
Q: You went into the garage. 
A: Yes. 
Q: You laid the 3 wood down? 
A: Yeah, put it where it belongs. 
Q: Then came out of the garage? 
A: No. 
Q: And what did do you? 
A: Walked back into the house. 
Q: And closed the garage door? 
A: Yes. 
Q: And entered in the house that way? 
A: Yes. 
Q: And went through the kitchen, then upstairs? 
A: Yes. 
Q: Does your garage door make sound -- does it make a sound when it goes 
up and down? 
A: If you're standing there, I guess you can hear it, yes. 
Q: And the dog stayed outside on the property? 
A: Yes. 
Q: Now, when you -- when was the first time that you encountered Kato 
Kaelin when you were getting ready to leave for the airport? 
MR. BAKER: I don't know what you mean by "getting ready to leave for 
the airport." 
BY MR. PETROCELLI: 
Q: Do you know what I mean? 
MR. BAKER: Well --  
MR. PETROCELLI: He said that he ran into Kato sometime when he came 
back -- when he came downstairs to go to the airport. 
MR. BAKER: Okay. You mean when the limo -- that's not getting ready to 
go, in my view, but that's okay. As long as we are on the same 
wavelength, that's fine. 
MR. PETROCELLI: Yes, we're on the same wavelength. 
Q: Do you understand what I'm saying? 
A: Yeah. 
Q: Okay. 
A: This is to the best of my recollection. This is -- you know, I came 
out, dropped the two bags. I didn't see Kato. The limo driver was 
standing there. I think I heard Kato, because he wasn't standing in 
front of the house. I looked in my bag, and I went back into the house 
and into the kitchen, came back out, and then I saw Kato over by the 
garage and he was talking to me from over there. Q The garage door was 
closed Right? 
A: Yeah 
Q: He was in front of the garage. Right? 
A: Yeah, he was in that area between the house, the garage. He was 
talking to me in front of the limo, just in that area. 
Q: Now, what was he saying to you? 
A: He was talking about -- something about earthquakes 
Q: He said he heard -- felt an earthquake? 
A: I wasn't really paying much attention to him. I was trying to get 
myself together and he was talking, and I don't think I really focused 
on what he was talking about until I came back from the Bronco, and 
then I for the first time really focused on what he was talking about. 
Q: The first time, before you went to the Bronco, he -- what is your best 
recollection of what he said to you across from this garage area where 
he was standing? 
A: He was moving, and he was just talking about an earthquake. 
Q: He used the word "earthquake"? 
A: Yeah. He did ask me if I overslept. That was one of the first things 
he said to me, "Did you oversleep?" And then he was talking about noise 
and earthquake. 
Q: When he asked you, "Did you oversleep," what did you say? 
A: I don't even think I responded to it. I don't recall really 
responding. I said, "I'm just running late," or something, but I didn't 
have any really specific response to it, I don't think. 
Q: What was he wearing? 
A: I don't know. 
Q: Did he have shoes on? 
A: I would assume so. 
Q: You don't remember? 
A: It isn't I remember. I didn't pay any -- I don't know if you got on 
shoes. I haven't paid any attention. 
Q: Did you see that he had shoes on? 
A: No, I didn't see one way or the other. 
Q: Can you identify what he was wearing? 
A: Not at all. Or Alan Park, for that matter. 
Q: Was he holding anything? 
A: Not that I recall. 
Q: He said something to you about noises? 
A: He was talking about an earthquake, is what he was talking about. 
Q: You mentioned before that he said something about noises. What did 
he say about noises? 
A: He heard something. "Did you feel an earthquake" --  
MR. BAKER: Are we talking about a different time now? We are not 
talking  --  
MR. PETROCELLI: We are talking about the same time. 
MR. BAKER: Wait a minute. We are talking about him moving out by the 
garage area and the earthquake, and then you said -- your question goes 
to the noises, and I just want to make sure we are at the same time 
frame. 
MR. PETROCELLI: Yeah. He  -- in one of his prior answers about this exact 
event, he said Kato was talking about earthquake noises, noises, 
earthquake. 
MR. BAKER: That's not the exact event. I want the question read back, 
please. 
MR. LEONARD: And the answer. (Record read as follows: "Q. You mentioned 
before that he said something about noises. What did he say about 
noises? "A. He heard something. "Did you feel an earthquake' -- ") 
BY MR. PETROCELLI: 
Q: When he said something to you about noises, you are saying he said, 
"Did you hear something." 
A: I don't think so. I think he asked me, did I feel an earthquake. 
Q: Did he --  
A: And then as -- as I said, I was going in and out, to my Bronco and 
back, and he was talking about noises and  -- and hearing something, 
earthquakes. I mean, I really didn't pay any much attention to what he 
was talking about. 
MR. BAKER: Most people don't. 
BY MR. PETROCELLI: 
Q: Well, off of your lawyer's comment, was Mr. Kaelin to your knowledge 
typically incoherent in your dealings with him? 
A: I mean, you guys seen Kato. Kato's Kato. 
Q: Did you find him to be incoherent, by and large, in your dealings 
with him? 
A: I found him to be Kato. Kato's very unique. I found him to be a very 
nice guy who is a little goofy, but I like him. 
Q: You didn't believe at that time, June 12, 1994, that he was 
incoherent? 
A: I wasn't paying -- Kato. for what I was doing at the time, he was 
totally  -- it was totally insignificant, whatever he was talking about 
to me at that moment. 
Q: But prior to that moment, though, my question to you is: In your 
relationship with him, you didn't find him to be someone incoherent. 
A: I found him to be Kato, and he's just not your everyday guy. He's 
Kato. He's Kato. I mean, you've seen him. 
Q: In your conversations with Kato before that moment, were you able to 
communicate with him? 
A: I've always been able to communicate with him. 
Q: Now, when he mentioned this thing about noises and/or earthquake, 
had you felt an earthquake? 
A: No. 
Q: Had you heard any noises? 
A: I don't believe so, no. 
Q: At that point then, you went out to the Bronco, as you testified. 
Right? 
A: I don't think -- that's not necessarily what I testified. I said as I 
was doing all of this stuff, Kato was talking, and I can't say exactly -- 
-I know when he first saw me, almost the first thing he asked me was, 
"Did you oversleep and did you hear" --  "did you feel an earthquake?" 
Then I was busy doing what I was doing; he and Park was talking, he was 
saying things, and I can't tell you exactly what he said. Between then 
and when I went out and when I came in, it was just about noises or 
hearing  --  I wasn't paying attention to him. I just was not paying 
attention to him or Park when I came -- I do recall asking him, "Well, 
doesn't he have a flashlight," and saying that there should be one in 
the kitchen in the cupboard. Other than that, I -- whatever he was 
talking about at the time meant -- was insignificant to me. It really -- I 
wasn't really -- I was trying to get a flight to Chicago, a flight I 
didn't want to take. 
Q: Did Mr. -- Withdrawn. Did Mr. Kaelin tell you why he wanted a 
flashlight? 
A: To look -- I guess to look around the side of the house. I may have 
said to him, "Get a flashlight and look back there." I may have said 
that to him. 
Q: What did Mr. Kato Kaelin tell you about wanting to go and look back 
with a flashlight? 
A: I don't know if he said anything about. I may have suggested it. 
Q: Did he tell you that he thought there were prowlers back there? 
A: No. 
Q: Did he say anything about that? 
A: No. He just said he heard a noise. 
Q: And he wanted to investigate the noise? 
A: Pardon me? 
Q: He said he wanted to investigate the noise? 
A: No. He said he heard a noise, and I said, "Well, why don't you get a 
flashlight and look," and I made a suggestion, "Let's grab a 
flashlight. I'll go one way, you go the other way, and we'll see." 
Q: Did he --  
MR. LEONARD: Excuse me. 
BY MR. PETROCELLI: 
Q: Did he tell you what the noise was that he heard? 
A: No. 
Q: Did he describe the noise to you? 
A: No. 
Q: Did you in fact go one way and he went the other way? 
A: I think we were about to, and it was very dark, and that's when I 
may have said, "Well, we better get a flashlight," and he went into the 
kitchen. 
Q: Did he describe generally where the noise came from7 
A: No. 
Q: Did he say if the noise -- he heard the noise in his room? 
A: Yes. I assume that's where he heard it, yes. 
Q: Did he say he wanted to go look in the alleyway behind his room? 
MR. BAKER: Well, I don't know what you're referring to as an 
"alleyway," but if you're talking about the space behind his room, I'll 
certainly allow him to answer that question. 
MR. PETROCELLI: That's what I'm talking --  
THE WITNESS: Well, I 
obviously got that impression, yes. 
BY MR. PETROCELLI: 
Q: And did you give him a flashlight? 
A: We went and looked for a flashlight, told him where I thought a 
flashlight was. 
Q: Where? 
A: In the cupboard of my kitchen. 
Q: Did you find one? 
A: He looked and -- I never looked. He looked and said it was. I noticed 
the time about that time and realized I needed to get moving, so I 
said, "Why don't you keep looking" as I was leaving. 
Q: And then you left? 
A: Yes. 
MR. BAKER: And then we should leave, He's got very few minutes left on 
the tape. 
MR. PETROCELLI: Well, we'll stop now because he's out of tape, as you 
suggest, and we will resume tomorrow at 9:30. 
MR. BAKER: That's a great segue: "Did you leave," and we're all 
leaving. Wonderful. THE VIDEOGRAPHER: This concludes the deposition of 
Orenthal James Simpson, Volume II. The number of video tapes used was 
three. We are going off the record and the time is approximately 5:25. 
(ENDING TIME: 5:25 P.M.) I DECLARE UNDER PENALTY OF PERJURY THAT THE 
FOREGOING IS TRUE AND CORRECT. SUBSCRIBED AT ______ CALIFORNIA, THIS 
______ DAY OF __ , 19__. ORENTHAL JAMES Simpson <vol 3> 
Q: Can you remember when that occurred? 
A: No,I can't. 
Q: What did your lawyers tell you about when you may have misused 
Bronco and Bentley? MR.BAKER: He is not going to tell you what we told 
him, Mr. Petrocelli. 
BY MR. PETROCELLI: 
Q: Well, based on what they said to you, can you tell us where you 
think you may have misused Bronco and Bentley, without going into your 
conversation with them? 
MR. BAKER: That's the same thing. That's by another means trying to 
break into the attorney-client privilege, and I am not going to allow 
him to do that. But you can ask him  --  BY 
MR. PETROCELLI: 
Q: Since you've opened it up, I need to follow up on this to make sure 
we have a complete understanding of your testimony, and I don't want to 
have to go through  --  
MR. BAKER: I will tell you where I thought he misspoke, and that was 
where he was talking about the cell phone conversation with Barbieri, 
and he said "Bentley" once and "Bronco" once and "Bentley" another 
time. 
BY MR. PETROCELLI: 
Q: As I understood your testimony yesterday, you made a cell phone call 
to Paula Barbieri when you got out of the garage at or near the 
location of the Bentley, and when you completed that call, you either 
put the cell phone in your pocket or near the trunk of the Bentley. Is 
that correct? 
A: That is correct. 
Q:: Do you have a clearer understanding as to what you did with that 
cell phone when you completed the call? 
A: Obviously I took it with me, so since I was swinging the club, I 
assume it was in my pocket. 
Q: Did you do any preparation for today's session, Mr. Simpson? 
A: Absolutely none. 
Q: Read anything? 
A: Absolutely nothing. 
Q: Did you watch television and pick up any pointers? 
MR. BAKER: You don't have to answer that. It's a good question, but he 
is not going to answer it. 
MR. PETROCELLI: Okay. 
Q: I would like to ask you a few questions about the alarm system at 
your house in June of 1994. 
A: Uh-huh. 
Q: Could you tell us whether you had an alarm system.? 
A: Yes. 
Q: And did the alarm system work with respect to the Ashford and 
Rockingham gates? 
A: No. 
Q: It worked with respect to the exterior doors of the residence. 
Correct? 
A: Yes. 
Q: It was a Westec system. 
A: Yes. 
Q: Is this a system where you could activate or deactivate the alarm 
through a remote location or device, such as a telephone? 
A: No. 
Q: The only  --  What were the ways in which you could activate the alarm 
at the house in June of 1994? 
A: There's a pad in my bedroom. There's a pad in my upstairs hall. 
There's a pad inside and outside the front door. There's a pad inside 
and outside the laundry door. 
Q: Inside and outside the laundry door? 
A: Yeah. 
Q: Is the outside of the laundry door the exterior of the property? 
A: No. It's in the garage. 
Q: So when you go into the garage from the driveway, if you were to 
enter the garage and go out the door that leads into the residence, you 
go right into the laundry room. 
A: Yes. 
Q: And in the garage on the outside of that laundry room door is a pad? 
A: That's correct. 
Q: And on the inside is a pad? 
A: That's correct. 
Q: Now, when you enter the residence, and let's assume the alarm is on, 
are you required to deactivate the alarm from the outside pad? 
A: Yes. 
Q: And if you deactivate the alarm from the outside pad and then you 
open the door and enter, is the alarm off now? 
A: Yes. 
Q: If you were not to deactivate the alarm from the outside pad but 
enter the residence anyway, could you then deactivate it from an inside 
pad? 
A: Yes. 
Q: And is there a delay of a certain interval of time before the alarm 
will start ringing? 
A: I don't believe so. 
Q: So if you fail to punch in the code on the pad and you open the 
door, what happens? 
A: The alarm goes off. 
Q: And what does that mean? Bells ring? Whistles sound? 
A: An alarm goes off. 
Q: Does it ring over to the Westec Security place as well? 
A: Yes. 
Q: And the police department? 
A: I don't think so. 
Q: Okay. Who  --  By the way, the way you just described the system, 
that's how it functioned in June of 1994. Correct? 
A: Yes. 
Q: It hasn't changed, has it? 
A: That's -- yeah. Yes. 
Q: Correct? 
A: Correct. 
Q: Did you have the code in June of 1994? 
A: Yes. 
Q: What was it, like a four-digit code? 
A: Yes. 
Q: And who else had that code to your knowledge? 
A: My family, my immediate family, Arnelle and Jason; my house keeper --  
Q: Names. 
A: Well, Gigi. Michelle possibly. Nicole. A.C. And I don't know after 
that. 
Q: Were there doors that one could  --  Let's assume the alarm was on. 
Were there doors that people could go in and out of the house through 
that would not activate the alarm? 
A: Yes. 
Q: Which doors were those? 
A: The ones that came from the guest house into the house, and  --  I 
don't know  --  I have some window doors. I don't know if they're  --  if 
they were on the alarm at the time, and I don't think any of the 
windows were on the alarm at that time. 
Q: How many guest houses were on the property? One? 
A: Three. 
Q: Now, do each of those guest houses have a door that goes into the 
main residence? 
A: No.Just one. 
Q: Just one. And who was in that guest house at the time? 
A: Kato. 
Q: Did Kato also have a door that went out to the exterior of the 
property? 
A: Yes. 
Q: And was that door on the alarm? 
A: To the exterior of the property, no. 
Q: So Kato could come into his guest house by getting into this 
exterior door that went directly into his guest house; even if the 
alarm was on, it would not go off. Correct? 
A: It depends. If --  there was an alarm there, too. I missed that one. 
It depends if it was engaged or not. 
Q: Kato's exterior door had an alarm on it? 
A: Yeah. 
Q: Was there a keypad in  --  and outside of his door? 
A: Yeah. No. Just outside of his door. 
Q: So when Kato  --  if the alarm were on and Kato were coming home  --  
let's say you were out of town  --  he would have to punch the code in 
order to get in. Right? 
A: Well, he didn't know the code, but if he had known the code, he 
would have had to do that. 
Q: Is this the same -- is it on the same code as the rest of the house? 
A: Yes. 
Q: So when you were out of town and Kaelin was staying there, the alarm 
was never on? 
A: He didn't have access to my house. I don't know if the alarm was on, 
because the housekeeper was there, but he didn't have unlimited access 
into my home. 
Q: So he would go into the guest house. Right? 
A: Yes. 
Q: And his normal routine was to enter through this exterior door? 
A: Yes. 
Q: And based on your ground rules with him, was he permitted to go into 
the interior of the house from his guest house? 
A: Unless somebody invited him in. 
Q: What if no one invited him? 
A: He wasn't supposed to go in. And the door was always locked. There's 
two doors, actually, and both of them were always locked. 
Q: Did he have the key to unlock those doors? 
A: No. 
Q: You said yesterday there was a single key that keyed all the doors 
on the property. 
A: No. I had a single key to all the doors on the property. 
Q:: But that key also worked on Kaelin's lock, too? 
A: Yes. 
Q: And he had a key. Right? 
A: Yes. 
Q: So he could have used that key to access any lock on the property. 
Right? 
A: That's incorrect. 
Q: Why is that incorrect? 
A: Because he couldn't. Q; Is it because he didn't have permission? 
A: No. 
Q: I'm confused. I'm not understanding your testimony. If his lock was 
keyed the same as all the other locks and he had a key  --  
A: I didn't say that. You said that. 
Q: Okay. So his lock was keyed differently. Is that what you're saying? 
A: Yes. 
Q: The exterior door. 
A: Yes. 
Q: And the interior doors he did not have the key to. Right? 
A: Correct. 
Q: And he couldn't open those doors from the inside of his room to get 
into the residence. Is that right? 
A: Correct. 
Q: They could be locked on the other side of the door. Right? 
A: Correct. 
Q: Okay. So is his exterior door the only door that was keyed 
differently from the rest of the property? 
A: No. 
Q: What other doors? 
A: Most of them. 
Q: Most of the other doors? 
A: Yeah, in my house. 
Q: Were keyed differently? 
A: Yeah, different keys for different things. 
Q: Okay.Then I must have misunderstood your testimony yesterday because 
I thought you told me that there was a single  --  
MR. BAKER: God, he's got a master key. Come on. Let's get it. 
BY MR. PETROCELLI: 
Q: Is that what it is, a master key? 
A: That's correct. 
MR. PETROCELLI: See, I don't have a master key, but that's a good idea, 
Mr. Baker. I have like seven keys for my house. 
Q: So you have a master key, and everyone  -- there are a bunch of 
different keys. 
A: Yes. 
Q: Who has the master key? 
A: Me and the housekeeper. 
Q: And Arnelle? 
A: No. 
Q: Did Nicole have one? 
A: She wasn't supposed to have one. 
Q: Okay. So bottom line here is Kaelin could only get into his room and 
no other room. 
A: Correct. 
Q: Now, let me go back again. If the alarm was on in the rest of the 
house unbeknownst to Kaelin and Kaelin entered his room through the key 
 --  through the exterior door, would the alarm go off? 
A: If the alarm was on, yes. 
Q: Was it your practice when you were out of town to have the alarm 
set? 
A: It was my practice when I was out of town to have someone at my 
house. 
Q: If you were to  --  Your housekeeper, did she work weekends? 
A: No, not generally. 
Q: So if you were going to be out of town on weekends, would the alarm 
be set? 
A: Should be, yes. 
Q: And how would Kaelin deal with the setting of the alarm if he's 
going in and out of the house on weekends? 
A: As I told you before, he wasn't supposed to be going in and out of 
the house on weekends. 
Q: What if he went in and out of his guest room, and the alarm were 
activated on the property, and nobody else was home, like your 
housekeeper, would the alarm be going on and off when Kaelin's entering 
his guest room? 
A: No. 
Q: Why is that? 
A: Because, as I told you, his exterior door to his guest room is not 
on the alarm. 
Q: Just the interior door? 
A: Yes. 
Q: Okay. Now, you didn't have anybody at home  --  excuse me. There were 
no housekeepers on duty on Saturday and Sunday, June 11 and June 12. 
Correct? 
A: Correct. 
Q: And the housekeeper was coming the next morning, on Monday? 
A: I would assume so, yes. 
Q: And she had the code. Right? 
A: Yes. 
Q: Whenever you leave town and the housekeeper isn't home, do you  --  
and no one else is home, do you always set the alarm? 
A: I try to. If I'm thinking about it, I definitely do, yes. 
Q: And you set the alarm after you close the front door  --  
A: Not always. 
Q: from the outdoor keypad? 
A: Not always. Sometimes as I'm going out the front door. 
Q: Can you set the alarm from the inside of the house and then go to 
the front door, open it and leave without the alarm going off? 
A: Correct. 
Q: Is there a delay from the moment you set it until it becomes 
activated? 
A: Yes, there is. 
Q: How long is that delay? 
A: I don't know. 
Q: Did you set the alarm on the evening of June 12th before you went 
into the limousine? 
A: No. 
Q: Why not? 
A: Because Kato was looking for a flashlight, or I thought he would 
continue to look for a flashlight. 
Q: And you left him in the residence, in other words. 
A: He was at the front door. When I walked out he was behind me, and I 
got in the limo and I said, "Well, look and see if you can find a 
flashlight." 
Q: Now, your understanding was that Kaelin when he was finished would 
close the front door and go back to his room. Right? 
A: Yes. 
Q: Through the outside of the property. Right? 
A: Well, yes. Or through the inside  --  well, yes, through the outside, 
because he couldn't lock the back door, yes. 
Q: Did you ask Kaelin to set the alarm for you? 
A: No. I think I told him I would call and give him the code. At one 
point we were talking about the code, but I had to leave, and I called 
him and gave him the code. 
Q: From where did you call him? 
A: I think the airport. 
Q: From a pay phone? 
A: Yes. 
Q: At the gate? 
A: Yes. 
Q: At American Airlines? 
A: Yes. 
Q: What gate number? Do you remember? 
A: No. 
Q: Is that the first time you had ever given Kato Kaelin the code to 
your alarm? 
A: I believe so, yes. 
Q: Is that the first time you had asked Kato Kaelin to set the alarm 
for you? 
A: Yes. 
Q: Did Kato say to you that he would do as you requested? 
A: Yes. 
Q: And do you know whether he did? 
A: No. 
Q: Did he tell you that he wasn't comfortable receiving the code or 
doing the alarm? 
A: No. 
Q: Did he tell you that he didn't have confidence that he could 
properly activate the alarm? 
A: No. 
Q: Did you explain to him how to do it? 
A: Yes. 
Q: What did it involve? Punching in some numbers? 
A: Yes. 
Q: And that's all. Right? 
A: Yes. 
Q: If the alarm is on and you're inside the home, does the alarm go 
off? Is there any motion detector? 
A: There is one, yes. 
Q: Where is that located? 
A: I would prefer not to say. 
Q: Where was it located in June of 1994? 
A: I would prefer not to say. 
Q: Could you please tell us? 
A: No. 
MR. BAKER: I will give you that information, and he can write it on a 
piece of paper. Is that fair enough for you? 
MR. PETROCELLI: For now. yes. 
MR. BAKER: Okay. Just write down where it is. 
BY MR. PETROCELLI: 
Q: Just so I am clear, you have only one location in the whole 
residence that's  --  
A: That's correct. 
Q: subject to a motion detector, and when you activate the alarm, the 
motion detector goes on. Right? 
A: Pardon me? 
Q: When you set the alarm, that also activates the motion detector. 
Correct? 
A: No. 
Q: Do you have to also set the motion detector? 
A: Yes. 
Q: And how  --  Can you do that from any of the keypads? 
A: No. 
Q: How do you set the motion detector? 
A: By a pad that's upstairs, in my upstairs hall. 
Q: You did give me a description of that pad before when you said you 
had one in your bedroom and one upstairs. Is that the upstairs one? 
A: Yes. 
Q: Is it a second pad next to the other pad for the doors? 
A: Yes. 
Q: And that's the only pad that activates a motion detector. Right? 
A: Yes. 
Q: Do you know how large of an area that motion detector covers? 
A: A relatively large area, yes. 
Q: Would it cover the kitchen? 
A: I m not going to talk about that. I already had to spend a fortune 
changing my alarms, by talking about my alarm system in court. 
Q: Have you changed it since the court case? 
A: Yes. Made it better. 
Q: Well, I am only interested in what it was at the time. 
A: Well, some things are in the same place. 
MR. KELLY: Could you send it around, so.... 
MR. PETROCELLI: 
Q: Did you have Mr. Kaelin  --  Withdrawn. Did you activate the motion 
detector before you left the premises? 
A: No. 
Q: Did you ask Mr. Kaelin to do so? 
A: No. 
Q: You only told him to do the doors. Correct? 
A: Yes. 
Q: Now, why on this one occasion for the first time ever did you ask 
Kato Kaelin to activate the alarm? 
A: Because on this one occasion for the first time ever Kato was, as 
far as I know, present when I was leaving and concerned about something 
around the house. Since he was there, I told him to look for a 
flashlight, investigate whatever he was investigating and put my alarm 
on. 
Q: Were you concerned about what Kato Kaelin was describing to you? 
A: Not really, but he seemed to be concerned. 
Q: You were not concerned? 
A: Not really, but he seemed to be concerned. 
Q: Why were you not concerned? 
A: Because I had to go. I was concerned about making my flight. 
Q: He told you that there were some noises and maybe he felt an 
earthquake. Right? 
A: Yes. 
Q: And he wanted a flashlight to go investigate who might be in the 
property. Correct? 
A: Correct. 
Q: And you were not concerned that there might be somebody there? 
A: Well, my alarm goes off many times. I'm a person who gets up in the 
middle of the night every night and walk around my house. I hear noises 
all the time. If he was concerned, he could look and put on my alarm 
when he left. 
Q: Did he describe the noises to you? 
A: As I told you before, no. 
Q: Well, you saw Kaelin for the first time when you came downstairs 
after you completed getting dressed, brought your Louis Vuitton bag and 
went out to the front entryway. 
MR. BAKER: Wait a minute. We've been through that sequence about 10 
times. 
MR. PETROCELLI: I am not going to go through that sequence. I am trying 
to establish his conversations with Kaelin  --  
MR. BAKER: Ask him. MR.PETROCELLI: I want to make sure, though, in 
point of time that we are talking about the same time. 
Q: Is that correct, that you first spoke to Kaelin at that point in 
time? 
A: No, that's not correct. 
Q: When did you first speak to Kaelin? 
A: I believe it was at 2:00 o'clock that day. 
Q: I am sorry.I am only talking about the evening of June 12th. 
MR. BAKER: After they get back from McDonald's? 
MR. PETROCELLI: Exactly. 
Q: Now, my question is: After you got back from McDonald's, you saw 
Kaelin for the first time when you came down finally from your bedroom 
with your bags packed, dropped them in the entryway. Then you saw 
Kaelin. Correct? 
A: I saw him, yes. An hour or so  --  I'd saw him when we had come back 
from McDonald's, and then the next time I saw him I was about to leave, 
about a hour later or so. 
Q: I didn't understand what you just said. An hour or so after you came 
back from McDonald's you saw him 
A: Yeah, whatever  --  yeah, when I was about to leave. 
Q: The time that I just described to you is about an hour or so after 
you came back from McDonald's? Is that what you're saying? 
A: Roughly, yes. 
Q: So you left around 11:00 o'clock, so you are saying you came back 
from McDonald's around 10:00 o'clock? 
A: I didn't say anything. We got back from McDonald's at whatever time 
we got back from McDonald's, and an hour or so after that I was leaving 
and I saw Kato. 
Q: But you were leaving around 11:00 o'clock p.m. Correct? 
A: Correct. 
Q: So you came back from McDonald's around 10:00 o'clock p.m. Correct? 
A: Maybe a little earlier than 10:00 o'clock p.m. 
Q: How early? 
A: 1 wasn't keeping time at the time. I was not paying attention to the 
time at the time to that extent. All I know, I told Kato that I'd be 
leaving and the limo would be here in about an hour. I do recall us 
having a conversation when we got back from McDonald's. So an hour or 
so after Kato was there, and I saw him when I was trying to leave. 
Q: And I am trying to fix precisely the point in time that you saw him 
an hour or so after you came back from McDonald's, and my question  --  
A: I thought we fixed that yesterday. 
Q: My question to you is: You saw him for the first time an hour or so 
after McDonald's when you came down ready to leave. 
A: Correct. 
Q: Now, you were in the entryway, and where was Kaelin? 
MR. BAKER: We have been through this. 
MR. PETROCELLI: I have not  --  
MR. BAKER: Yes, you have. You went through it yesterday  --  
MR. PETROCELLI: Mr. Baker  --  
MR. BAKER: Yes,you did.You talked about it, and he told you he was over 
in the garage, and you went through it in excruciating detail. 
MR. PETROCELLI: No, I did not. 
MR. BAKER: Yes, you did, and we are not going to go through it again. 
MR. PETROCELLI: I am going to have to ask him some questions about his 
conversations with Kaelin. MR.BAKER: You have asked him about every 
conversation he had with Kaelin after -- when he came down out of his 
house that night. We are not going to go through it again. 
MR.PETROCELLI: You know, you are just going to prolong this; that's 
all. 
MR. BAKER: Well, you are not going to try to trip him up by asking him 
the same question 15 times. That's not appropriate conduct at this 
deposition. 
MR. PETROCELLI: I am trying to get the truth. I am not trying to trip 
him up. If he is telling the truth, he won't be tripped up. 
MR. BAKER: I don't need a lecture from you about what the truth is or 
anything else. 
MR. PETROCELLI: l don't need to listen to pejorative descriptions of 
why I'm doing.. 
MR. BAKER: Pull it up. Let's see  --  
MR. PETROCELLI: I am not interested in pulling it up. 
MR. BAKER: I don't care what you're interested in . Pull it up. He is 
not going to answer another question until we pull it up. 
MR. PETROCELLI: You can pull it up. I am going attach the next exhibit 
in order. Okay? 
MR. BAKER: Pull it up. Let's see what he asked about yesterday. 
MR. PETROCELLI: I intend to pursue conversations with Kaelin right now. 
Can you attach this as Exhibit 27 and this is Exhibit 28. Okay? 
(Plaintiffs' Exhibits 27 and 28 were marked for identification by the 
reporter and are attached hereto. 
BY MR. PETROCELLI: 
Q: Okay. You have before you Exhibit 27, Mr. Simpson? 
A: Correct. 
Q: And Exhibit 28. You can look at them together.These are sketches of 
the Rockingham property. Do you see that? 
A: Right. 
Q: When you came downstairs for the last time to leave and you saw 
Kaelin for the first time, I want you to point out on either one of 
these, whichever one you think is better, where Kaelin was and where 
you were. 
A: I was here (Indicating), outside of what you call an entry. I call 
it a foyer. But in this area here, which I will call the entry. And he 
was somewhere in this area here (Indicating). 
Q: Okay. I am going to put an "OJS" where you were. Correct? 
A: Uh-huh. 
Q: And Kato Kaelin was where? 
A: Somewhere over here (Indicating). He was moving around, but 
somewhere over there. 
Q: Right around there? 
A: Yeah, in that area. 
Q: Okay. I'll put a "K" there. And that's  --  
A: In front of the  --  he was in the front of the limo, which was 
straddling this (Indicating). He was in the front portion of the limo, 
but he was moving around. 
Q: Where was the limo? 
A: Straddling right where it says there. 
Q: Right here (Indicating)? 
A: Yeah. 
Q: Okay. And were there any other cars parked there? 
A: Yeah. My Bentley was right there (Indicating). 
Q: Right in this little area here? 
A: Yeah. 
Q: Okay. I will put "Bentley." You see that? 
A: Uh-huh. 
Q: And can you spot the Bronco for us? 
A: It would be out here (Indicating). 
Q: Right here? Just north of the  --  
A: Yeah. 
Q:  --  gate? 
A: North of the gate at some point, yeah. 
Q: Were there any other  --  You had said yesterday that you took a walk 
from Rockingham through the Ashford gate with the dog. Were there any 
other cars parked on Rockingham or Ashford when you took that walk? 
A: Not that I noticed. 
Q: Okay. 
A: I'm sure Kato's car must have been there, but I didn't notice it. 
Q: You didn't see it. 
A: No. 
Q: What kind of car did he have? 
A: I don't know. Maybe it was a Datsun or something like that. I don't 
know. 
Q: Now, where was Mr. Park, by the way, when you first spotted Kaelin? 
A: I don't know. Somewhere around the limo. 
Q: Out of the car? 
A: Yes. MR.PETROCELLI: Let the record reflect, though, we have made 
notations on I guess Exhibit 28. 
Q: Correct? 
A: Pardon me? 
Q: This is Exhibit 28 on which we have made these notations. 
A: Yes. MR.BAKER: It's definitely not to scale. MR.PETROCELLI: I don't 
represent that this is to scale. 
Q: Now, when you first spotted Kaelin and you guys were talking, did he 
then at some point with you go into the kitchen? 
A: Later on, yes. 
Q: When you say "later on," was that after you went out to, as you 
testified yesterday, the Bronco? 
A: Correct. 
Q: And when you went out to the Bronco to get I think you said the cell 
phone case and other  --  and the windbreaker, when you were doing that, 
where was Kaelin? Do you know? 
A: No, I didn't see him, but I assume he was  -- I can hear him at one 
point  --  he was talking to me as I went out. 
Q: Did he go out with you? 
A: No. And I don't know if he was talking to the limo  -- I just heard 
him talking as I went out, but I really wasn't focusing on what he was 
saying, and... So he was behind me talking. 
Q: And then when you came back --  MR.BREWER: Would you describe  -- the 
witness made a circular motion with his finger  --  MR.BAKER: We are on 
videotape. MR.BREWER: We are also making a written transcript, Mr. 
Baker. THE WlTNESS: What do you want me to describe? MR.BREWER:I just 
want to make sure the record reflects what you are doing. 
BY MR. PETROCELLI: 
Q: When you came back from the Bronco and you testified yesterday you 
dropped your items off at the front entryway and then went into the 
kitchen, did Kaelin go with you? 
A: Yes, I think he went before me. 
Q: He was in the house already? 
A: Yeah. We were talking when I came back. 
Q: You were talking for a bit? 
A: We were moving. I couldn't stand in front of him like you and I are 
talking. I was doing what I was doing, and he was talking to me as 
we're doing it, and at this point in here (Indicating) I was talking 
about going this way and him going the other way, and that's when  -- I 
think that's the first time I heard about a flashlight, is when I came 
back --  
Q: From the Bronco. 
A: Yeah. And I remember asking the limo  --  I said, "Does the limo 
driver have one," I believe, or words that to that effect --  
Q: Meaning a flashlight? 
A: Yes. And he says no, and he may have showed me this little pen 
flashlight he had. And I said, "Look in the cupboard in the kitchen. 
There might be one." And that's when I went to my bag, and I think I 
had a quick conversation with Park about my golf bag, and at that point 
Kato was still talking, and I went into the kitchen. 
Q: Okay. At no point during this whole encounter with Kaelin outside 
the property did you ever sort of stand face to face, stop and talk. 
Correct? 
A: Not really, no. No. 
Q: You were moving around all the time. 
A: Yeah.Yeah. 
Q: When you went into the kitchen, did you have a face-to-face 
conversation? 
A: No. He was  --  I think he was looking in the cupboard. 
Q: And you were getting a drink of water. Right? 
A: Yeah. I was talking to him. I went and got a water, came back, and I 
was just talking to him about, "Look there," and I didn't know where 
else to look for the flashlight. 
Q: You didn't give him the alarm code at that time. Right? 
A: No. As he was walking behind me as we went out and I think I was 
discussing, "Well, look for a flashlight, and the alarm is"  --  
whatever, and I said -- and he was being Kato, and I said  --  you know, I 
think I said, "I'll call you," or something, but I know I said, "Well, 
look for the flashlight," and I just went and got in the limo. 
Q: When the alarm is activated and you are entering the property, 
entering the door to the house, can you tell that the alarm is on? 
A: Yes. 
Q: On all exterior doors? 
A: Not all exterior doors. Doors that there are a pad on and stuff, 
yes. 
Q: Was there a pad outside Arnelle's door? 
A: No. 
Q: Now, if Arnelle came home later that evening and the alarm had been 
set by Kato, would the alarm have gone off when she opened her door? 
A: Unless she disengaged it. No. No, it wouldn't have. 
Q: And why is that? 
A: Because there is no alarm on her door. 
Q: On the exterior door of her guest room, there is no alarm. 
A: Correct. 
Q: Is that the only exterior room, plus Kato's, not subject to an 
alarm? 
A: No. The other room is not subject to an alarm. All the exterior 
rooms are not subject to the alarm or were not subject to alarm. 
Q: The three exterior guest rooms. Correct? 
A: Yes. 
Q: Now, from Arnelle's room, when she enters her room, can she go 
directly from her room to the inside of the home  --  
A: No 
Q:  --  through an interior door? 
A: No. 
Q: It's a free-standing room? 
A: Yes. MR.BAKER: Well, I don't know what you mean by "free-standing." 
BY MR. PETROCELLI: 
Q: What I want to know is: Does she have another room that leads into 
the residence? 
MR. BAKER: He answered that. 
BY MR. PETROCELLI: 
Q: The answer is no. Correct? 
A: The room that she was staying in at the time does not lead into the 
residence. 
Q: So if Arnelle wanted to access the residence and the alarm were on, 
would she at all times be aware of that? 
A: I would hope so, yes. 
Q: And she would have to look at the keypad and see that it was on. 
Right? 
A: Yes. 
Q: Is there a light? 
A: Yes. 
Q: And she had the code. 
A: Yes. 
Q: Okay. Now, earlier yesterday you had talked about where the luggage 
was placed, and I just want to make sure I understand. On this entryway 
area there are benches on either side? 
A: Yes. 
Q: Where I am going to put these X's, there are benches. Right? 
A: Yes. 
Q: You testified yesterday that you had laid the golf clubs and the 
golf cover bag on one of the benches. Which bench? 
A: Originally the southern bench. 
Q: Which one is that? 
A: This way (Indicating). 
Q: This one over here (Indicating)? 
A: Yes. 
Q: Okay, the southern bench. And then you came down  --  Did you move 
that to the northern bench at some point? 
A: No. 
Q: And you also testified that at some point when you were half 
dressed, you came down and dropped the suit bag on this golf bag. 
Correct? 
A: I don't know if it was on it, but in the same place, yeah. 
Q: On also the south bench? 
A: 
A: No, because I took the golf bag off the bench at that time and threw 
it down on the ground. 
Q: When you brought the suit bag down, you put this golf bag on the 
floor? 
A: Yes. 
Q: And then put the suit bag on the south bench? 
A: No, I don't know. I may have just  --  I may have put the suit bag 
down when I started going through the golf bag. 
Q: The Bentley was  --  
MR. BAKER: We've gone through this whole thing yesterday, and I will 
pull it up because this is getting ridiculous to sit here, and when we 
are going to have our argument on Friday about ending the depo, we're 
going to pull this all back up for the judge when we go back and talk 
to him. 
BY MR. PETROCELLI: 
Q: The Bentley was facing Rockingham? 
A: Yes. 
Q: And yesterday you testified about leaving the white golf ball bag 
and another bluish bag. Did you leave that behind the Bentley or in 
front of the Bentley? 
A: Behind the Bentley. 
Q: Yesterday you testified about chipping the golf balls --  
A: Yes. 
Q:  -- and I wanted to know whether, using either one of these, you could 
point to the area where you were doing the golf ball hitting? 
A: Right about in here (Indicating). Yeah, the lower part. 
Q: I will put an "X" with a circle on it. Right there? 
A: Uh-huh. 
Q: And you talked about a big tree. Was that the tree right here? 
A: Tree over here (Indicating). 
Q: This tree near Ashford. Right? I'll put a "T" there. And the golf 
balls you were hitting over the tree were the tree where the "T" is on. 
Is that correct? 
A: That's correct. 
Q: Did you tell Kato Kaelin to call the police? 
A: No. 
Q: Or Westec? 
A: No. 
Q: Did you give  --  did you say anything to him about talking to 
Arnelle? 
A: No. Arnelle wasn't home. 
Q: When she got home, I mean. 
A: No. 
Q: Did you take Kato's concerns seriously? 
A: Not really. 
Q: Why not? 
A: Because I didn't. 
MR. BAKER: He already answered that. 
BY MR. PETROCELLI: 
Q: Because he was Kato. Right? 
A: No. 
MR. BAKER: Don't. You answered it once, and that's enough. 
BY MR. PETROCELLI: 
Q: When Kaelin told you that he heard these noises, did he say at what 
time he heard them.? 
A: No. 
Q: Did he tell you whether he just heard them or heard them earlier in 
the day? 
A: I assumed it relatively just happened. Just an assumption on my 
part. 
Q: Based on the way he was explaining it to you? 
A: Based on that he had not mentioned it to me earlier in the day. 
Q: But as best as you can recall, he didn't tell you when it happened? 
A: No. 
Q: Since you didn't take his concern seriously, why did you give him 
access to your house when you were leaving? 
A: Because he seemed concerned and because I wanted him to find a 
flashlight and look around if that's what he wanted to do. 
Q: And when you called him from the airport to give him the security 
code, did you discuss with him whether he had investigated the 
situation? 
A: I may have. I may have said, "Did you find a flashlight?" I believe 
he said "No." 
Q: Did you ask him if he had looked for people on the property or had 
investigated the sounds and noises that had concerned him? 
A: I may have said, "Is everything all right?" And I'm assuming he said 
"Yes." I don't recall specifically. And then he  --  I said, "Did you set 
the alarm?" And he said "Yes." That was that. 
Q: Wasn't it in this call that you had given him the code? 
A: Yes. 
Q: So when you said, "Did you set the alarm," how was he supposed to 
have set the alarm  --  
A: Well, I asked him to set the alarm. 
Q: Excuse me  --  if he didn't have the code? 
A: Well, I was then telling him to set the alarm. So he said he would 
set the alarm. 
Q: So you didn't say, "Did you set the alarm?" 
A: No. 
Q: You asked him to set the alarm. 
A: To set the alarm. 
Q: I don't want you to assume anything. I just want to make sure I 
understand your testimony. Do you recall asking him what had happened 
with his concern about someone  --  about hearing noises? 
A: I do recall asking him, "Was everything okay?" 
Q: And tell me what he said to the best of your recollection. 
A: Well,you don't want me to assume, so I can't. 
Q: Don't assume anything. 
A: So I can't. 
Q: So you don't recall. 
A: I don't recall, no. 
Q: At any time before you got on that airplane, did you consolidate any 
of your luggage? 
A: Yes. 
Q: When did you do that? 
A: When we got to the airport. 
Q: Did you do that where the limo driver pulled up to get the skycap? 
A: Yes. 
Q: What did you consolidate into what? 
A: I put my balls in my golf bag, and I put balls -- and I think I took 
the windbreaker and put it in my golf bag. 
Q: Let me back up a bit. You had this bluish bag, right, which had the 
wind-breaker and the new maxfli 100s? 
A: Yes. 
Q: You took that bag and put it in what? 
MR. BAKER: He didn't testify that they were new Maxfli 100s. 
MR. PETROCELLI: He testified they were not scuffed. 
MR. BAKER: There is a difference. 
MR. PETROCELLI: Okay. 
MR. BAKER: Isn't there? 
MR. BLASIER: Yes. 
MR. PETROCELLI: Okay. I wouldn't know that. 
MR. BAKER: I'm looking at you. 
MR. KELLY: Were they Balatas? 
MR. BAKER: Of course they're Balatas. 
MR. PETROCELLI: I wouldn't know that. 
Q: Tell me, did you take that bag with the Maxfli 100s and the wind-breaker and put it into another bag? 
A: Yes. 
Q: What bag did you put it into? 
A: My golf bag. 
Q: Opened up the golf cover bag and put it in. 
A: Yes. 
Q: Didn't put it into the golf bag itself, Correct? 
A: I may have put the balls in the golf bag. I may have put it in the 
golf bag. I'm not sure about that. 
Q: You took the balls out, you think? 
A: I think so. 
Q: And you left that other bag, the bluish bag in the golf cover bag? 
A: Yes. 
Q: Not the golf bag itself. Correct? 
A: Correct. 
Q: And did you take the wind-breaker out? 
A: I'm not sure. 
Q: You already had another wind-breaker. Correct? 
A: No. I had a jacket. I had a jacket. I call it a windbreaker, as you 
saw, but it was a wet coat, but it's  --  yeah. it's a different type, 
though. 
Q: That's the one you got from the Bronco. Right? 
A: Yes. 
Q: Were you carrying that? 
A: I believe so. If I hadn't put it in my suit bag, I had it  --  I was 
carrying it. One or the other. 
Q: So where did you do this consolidation of the luggage? While the 
luggage was in the trunk? 
A: No. I had taken it out of the trunk, and while I was standing out of 
the trunk and some guys were asking me for an autograph standing there, 
and I was doing it while they were standing there talking to me. 
Q: Out of the trunk on the ground? 
A: On the ground, yes. 
Q: And did you do any other luggage consolidation? 
A: No. 
Q: What bags did you check with the skycap, and what did you carry onto 
the plane? 
A: The Louis Vuitton bag and the golf clubs I checked, and I carried my 
suit bag and my grip. 
Q: And how much did you tip the skycap? 
A: He said he only had $10 change, so he ended up with a $10 tip. 
Q: You gave him a 20? 
A: Yes. But he promised me he'd get my clubs on the car. 
MR. BAKER: On the plane? 
THE WITNESS: On the plane, yes. 
BY MR. PETROCELLI: 
Q: When you left that limo, you paid Park, too? 
A: No. I told him to put 20 percent on the bill. 
Q: And you signed it? 
A: No. I don't think so, anyway. I normally don't. 
Q: Did you use a credit card? 
A: No. 
Q: He just billed you. Right? 
A: I believe so, yes. 
Q: When you left the limo area, what did you do then? 
A: Went to the plane. 
Q: Went directly in the doors and up to the gate? 
A: Yeah. 
Q: Did you stop at any trash containers --  
A: No. 
Q:  --  or receptacles? 
A: No. 
Q: None at all? 
A: No. 
Q: Did you stop to throw anything away? 
A: No. 
Q: Did you stop to rest any luggage on there in order to rearrange 
yourself or anything like that? 
A: It's a possibility. 
Q: When you say that's a possibility, give me your best recollection of 
whether you did that or not. 
MR. BAKER: If you have a recollection. 
THE WITNESS: I don't have a 
recollection. I just know that it wouldn't be unusual to stand by the 
ticket counter, put my bag on something, because I know he had people 
in front of him that he was dealing with, and I was beside him, and I 
might have put my bag either down or something to get my tickets out 
for him to give me my baggage claim. 
BY MR. PETROCELLI: 
Q: This is outside, you mean? 
A: Yes. 
Q: Where the baggage guy works behind that counter? 
A: Yes. 
Q: So you think you stopped there and rested your luggage? 
A: Well, I know I stopped there and I know I went into my bag to get my 
ticket for him to, you know, do what he had to do, so I know that took 
place there. So if there was a garbage there, I could have been around 
a garbage there. 
Q: Do you remember putting a bag on the garbage, though? 
A: No. 
Q: Did you talk to anybody besides the skycap and the limo driver? 
A: Everybody who spoke to me, talked to. 
Q: Who spoke to you? 
A: People. 
Q: Can you name them. 
A: No. 
Q: How many? 
A: I don't know. 
Q: You mean just fans? 
A: Yes. 
Q: About how many? 
A: I have no idea. 
Q: Well, you spoke to Mr. Park and you spoke to the skycap. Correct? 
A: Yes. 
Q: You don't remember the skycap's name? 
A: No. 
Q: How many fans approached you? 
A: I don't know. 
Q: More than 10? 
A: Probably, yes. Well, in the course of  --  you mean during the course 
of getting from there to the plane? 
Q: Yeah, from that point until you got on the airplane. 
A: That spoke to me? 
Q: Yeah. 
A: I don't know. I don't know. Whoever I went by spoke to me. 
Q: Did you stop to speak to anybody? 
A: Other than  --  I didn't  --  I can't say I stopped to speak to the two 
guys who were there. I might have. But it wasn't like  --  the skycap 
was trying to check my luggage, so I didn't feel as if I was stopping 
for them. They just happened to be there. 
Q: Two skycaps? 
A: No . Two guys. 
Q: Oh, two guys. Did you give an autograph --  
A: Yes. 
Q:  --  to both of those guys? 
A: I don't recall. 
Q: One or two autographs? 
A: I don't recall. 
Q: Did you give any other autographs? 
A: I believe so, but I -- I just believe so yes. 
Q: Where did you give those other autographs? 
A: I believe at the plane or at the counter of the plane, but I'm not 
sure. 
Q: And you made one phone call? 
A: Yes. 
Q: Did you make any others? 
A: No. 
Q: Did you use coins to make the call, or did you charge it to a 
number? 
A: I don't recall. 
Q: You have a calling credit card. Right? 
A: Yes. 
Q: You use it regularly? 
A: I believe so, yes. 
Q: Bills it to your home phone? 
A: I don't know. 
Q: Or the OJ. Enterprises' office phone? 
A: I would imagine. One of them. 
Q: How long did the limo ride take to the airport? 
A: I don't know. Not long. 
Q: You just made casual conversation with Park? 
A: Yes. 
Q: Did you complain about anything. 
A: Yes. 
Q: What did you complain about? 
A: Traveling. 
Q: Just constant traveling? 
A: Yes. 
Q: Complain about anything else? 
A: No. 
Q: Complain about it being hot? 
A: I don't think so. 
Q: Were you hot? 
A: Hot, no. 
Q: Were you sweaty? 
A: I was wet. I know that. 
Q: From? 
A: Jumping out of the shower, running downstairs, getting my thing 
together, getting in the plane  --  I mean getting in the limo. 
Q: Did you lower the windows in the back seat? 
A: I always do. 
Q: All the time? 
A: Yeah. I don't like air-conditioning, so normally I would turn it off 
if it's on, and most limo drivers have it on, and put the window down. 
Q: Dale St.John does that for you? 
A: Sometimes, yes. 
Q: You said you always do it. 
A: Yes. But I don't need him to do that for me. I don't tell you to let 
the window down. I can let my own window down. 
Q: But you tell him to shut the air-conditioning off? 
A: No. Sometimes if the sun is hot, he'll have it on when I get in, and 
I'll turn it off. 
Q: Now, did you and Mr. Park discuss Kato Kaelin? 
A: Yes, I believe so. 
Q: And tell us what was said. 
A: Something about, "Was he nervous? He seemed serious." Words to that 
effect. 
Q: Who said that? Park? 
A: I think Park said, "He seemed serious." 
Q: Serious about what? 
A: Whatever he was talking about. 
Q: About investigating the property? 
A: Yeah. 
Q: And what did you say in response to that? 
A: That's when I -- I don't know if I said anything, but that's when I 
think I decided to call and make sure he had the alarm. 
Q: Was there a phone in the airport  --  I'm sorry -- in the limousine? 
A: I believe so. 
Q: And you had your cell phone in your grip in the back seat with you. 
A: Yes. 
Q: Did you call from the car? 
A: I may have tried. 
Q: What is your best recollection? 
A: I don't know, but I think I may have tried. I think something might 
have been wrong with the phone. I'm not really sure, but I might have 
tried. 
Q: On what phone? 
A: I don't know. If they had a phone there, I may have tried on their 
phone. 
Q: Did you try on your cell phone? 
A: No, but I would have once I got to the plane. 
Q: You "would have"' meaning what? 
A: If I didn't have time to -- if they didn't tell me I had time to call 
on the regular phone, I'd have sat on the plane and called. 
Q: No. I am asking whether you used your cell phone in the limousine to 
make that call. 
A: I don't believe so. I don't believe so, but I might have. I don't 
know. 
Q: It was working. Correct? 
A: Yes. 
Q: What number would you have called? 
A: His number. 
Q: And how did you know that number? 
A: I would have had to dig my phone out of my bag -- phone book out of my 
bag, which I might have done, and that would have been what I would 
have had to do. 
Q: You have Kaelin's number in there? 
A: I believe so. 
Q: That's what you used at the airport phone? 
A: I believe so. 
Q: Any other discussion about Kaelin? 
A: I don't believe so. 
Q: When he said, "He seemed serious," what did you say? 
A: He might have been answering an inquiry of mine. 
Q: What was your inquiry? 
A: "How was Kato? Did he seem serious to you?" I might have asked that. 
I'm not sure. I just know that was the gist of the  --  I can't even call 
it a conversation. It was probably just a quick exchange between the 
two of us. 
Q: Why do you think you asked him that question? 
A: Because I hadn't really given Kato much thought when I was leaving, 
and then as I was settling down finally in the car, I started thinking 
about it. 
Q: When you picked up the phone in your bedroom from Alan Park, what 
did you say to him? 
A: Actually I started talking before he spoke. I just picked it up 
because I thought it was Dale, and I said, "Yeah, yeah, I know I'm 
running late. I'll be right down." 
Q: Did you say anything else? 
A: If he didn't call me right back, because I thought I might have hung 
up right then and then he called right back, and  --  because he had said 
something to me that  --  rather tentatively, "I've been here," and I 
said -- I guess I said something about, "Yeah, I know. I've been in the 
shower, but I'm coming right down," and that was it. 
Q: You did not tell him you had overslept. Correct? 
A: Absolutely not. 
Q: And you in fact had not been sleeping. Correct? 
A: True. 
Q: When was the last time on June 12 you had slept? When you up that 
morning? 
A: I may have dozed a little between  --  may have. I was reading and 
watching I think basketball, or whatever was on, and I may have dozed 
somewhat before I went to the recital. 
Q: We will get to that later. When you were walking the dog after 10:00 
o'clock p.m. down Rockingham and up Ashford, did you see anybody? 
A: First, that's not correct. I wasn't walking the dog down Rockingham 
and up Ashford. That's not correct. My dog went out when I went to the 
Bronco, went and did her doo, and I walked around to the other gate. 
Q: You walked the dog from the Rockingham gate to the Ashford gate. 
Correct? 
A: I walked to the Ashford gate, called my dog to come in at the 
Ashford gate. 
Q: Did you see anyone during that time? 
A: No, but I heard someone. 
Q: Did anyone see you? 
A:I don't know. 
Q: Did you talk to anyone? 
A:No. 
Q: What did you hear? 
A: I heard the doors in my neighbor's yard over here (Indicating). 
When they were moving around, sometimes you can hear them if they're 
outside going inside or outside. 
Q: And what neighbors are you referring to? 
A: The Schlesingers. 
Q: Schlesingers? 
A: Yes. 
Q: Salingers? 
A: Oh, yeah, I'm sorry. Salingers. 
Q: Salingers. 
A: Yes. 
Q: Do they live just north of your property on Rockingham? 
A: No. 
Q: Where do they live relative to this? 
A: Just south. MR.BAKER: South of the --  MR.PETROCELLI: Do I have my 
directions wrong? MR.BAKER: You do. BY MR.PETROCELLI: 
Q: Okay. So --  MR.BAKER: Here. It's on here. See? South that way 
(Indicating). MR.PETROCELLI: Okay. South is where the Rockingham gate 
is. Okay. 
Q: You heard some sounds in the Salinger property? 
A: Yes. 
Q: They seemed normal sounds to you? 
A: Yes. 
Q: Just people going m and out of the house? 
A: Yes. 
Q: Did you see anyone there? 
A: No. 
Q: Did you see cars driving by? At any time when you were out on that 
 --  when you went to the Bronco and then walked to Ashford and got your 
dog and went in. 
A: I don't recall, no. 
Q: Now, you've heard the testimony of Mr. Park about seeing a person 
in dark clothing in the vicinity of the front entryway and driveway 
area going into the front door. Correct? 
A: Correct. 
Q: And you told Larry King that that was you. Correct? 
A: I told Larry King that I walked out of my house, and I assume that 
if he saw someone at that point in time it was me, because judging by 
his testimony, right when I got back at the top of the stairs the phone 
rung, and his testimony I guess sort of said that. So that would have 
been me, yes. 
Q: That would have been you when you came down the stairs half dressed 
the first time to put down the suit bag. Correct? 
A: Yeah, and to look  --  actually I didn't come down to put down the 
suit bag. I came down to see if I had black shoes in my golf bag. 
Q: And you came downstairs, and you opened that golf bag and looked in 
for your shoes. Right? 
A: That's correct. 
Q: And that's when you put the golf bag on the floor from the south 
bench. 
A: I actually held it up, thinking that Dale was in the car looking at 
me, and threw it down for  --  sort of me signaling to Dale: Come and get 
the golf bag. 
Q: Dale was, you thought --  
A: Yeah. 
Q: By the way, you didn't know that it was Park. Right? 
A: No. 
Q: You thought it was Dale? 
A: Right. 
Q: "Dale" being Dale St. John, your regular --  
A: Dale or one of his guys who normally drive me. 
Q: Who else normally drives you? 
A: You'd have to ask Dale. 
Q: You don't --  
A: I don't recall their names, no. 
Q: You don't remember their names? 
A: No. 
Q: Anyway, you signaled to Dale from the front entry area? 
A: I picked the golf clubs up and held them up and then threw them 
down, thinking whoever was there, because it's an unobstructed view, 
would see me, and threw it down on the ground; and if it was Dale or 
the other guy, I thought they would push the gate, come in and get the 
bag. 
Q: Dale knows how to push that gate open? 
A: I would assume so. I know he has a tall guy that works for him that 
would have known because I'm sure he's done it before, because they're 
all concerned about not letting my dog get out. 
Q: Who is that tall guy? 
A: As I told you, I don't know. You'd have to ask him. But he's driven 
me often. 
Q: Dale has come to your property and basically let himself in that 
Ashford gate. Is that what you're saying? 
A: I'm saying that many times Dale has come to my property  --  I'm 
normally getting dressed. I'm normally not the guy that's letting him 
in  --  left the --  THE REPORTER: Excuse me. "Left the"? 
THE WITNESS: --  
have come to pick me up without driving on my property, come into my 
property, take my luggage outside of the gate and put it in the car. 
I'm saying that that has happened often. 
BY MR. PETROCELLI: 
Q: And when that happens often, who lets Dale in the gate, or his 
driver? 
A: I would assume Michelle or Gigi or whoever was downstairs at the 
time. 
Q: My question to you is: Did you tell Dale or this tall driver how to 
get into the Ashford gate --  
A: No. 
Q: -- if no one lets them in? 
A: No. I've never told them personally, no. 
Q: You testified yesterday that you know a way in which you can push 
the door manually open. Correct? 
A: Yes. 
Q: Did you ever describe that to the drivers? 
A: No. 
Q: Did you ever see them let themselves in without being buzzed in? 
A: I've seen them on my property when I'm down, go out that gate with 
that gate going back and forth on the hinge, yes. 
Q: And do you know how they got in? 
A: Well, normally my housekeeper was down there dealing with it. 
Q: On this occasion you knew, on the evening of June 12, there wasn't a 
housekeeper. Correct? 
A: Correct. 
Q: And when you signaled to the driver with your golf bag  --  is that 
what you're now saying? 
MR. BAKER: What do you mean, "now saying"? Don't --  
BY MR. PETROCELLI: 
Q: Is that what you're saying, that you signaled to the driver with 
your golf bag? 
A: Start all over again, please. 
Q: Okay. You said you came down to the golf bag with your suit bag, put 
the suit bag down someplace  --  
A: Correct. 
Q:  --  looked in the golf bag  --  
A: Right. 
Q:  --  for your shoes. 
A: Correct. 
Q: Black shoes. 
A: Yes. 
Q: Actually picked the bag up and walked out into the driveway area? 
A: No. 
MR. BAKER: He never said that. 
THE WITNESS: I never said that. 
BY MR. PETROCELLI: 
Q: You said you held the bag up --  
A: I picked it off the bench. I guess they can see me. You want to 
describe it as I'm doing it. 
Q: Correct. 
A: Picked it up off the bench, held it up and threw it down on the 
ground (Indicating). 
Q: Held it up and looked over towards the limousine? 
A: Yeah, held it up towards that, because it was I guess parking lights 
shining in, and the limo was right there looking at me, and threw it 
down. 
Q: Limo was on the other side of the gate. 
A: Yes, but there was no  --  it was unobstructed. There was nothing on 
the gate to keep him from looking straight down the whole driveway, for 
that matter. 
Q: And you did that, what you just described, in order to signal to him 
to put  --  come get the golf bag. Right? 
A: Yeah. 
Q: How did you expect him to come into the property to get the golf 
bag? 
A: Well, I thought he would push the gate. If he didn't push the gate, 
it would have been simple: I would have said "Push the gate" when I 
came back down. It was no big deal. 
Q: You had never told him about pushing the gate. 
A: I never told Kato how to open a door, but I assume he knows how to 
open a door. 
Q: Why would you assume that the limousine driver would know how to get 
into a gate that would appear to be closed and locked? 
A: Because he had been coming to my house for years, and everyone else 
who has come to my house for years know that. 
Q: Knows that you can get into that gate by just pushing it? 
A: Yes. 
Q: But you never told the drivers that. 
A: I never told Kato that, but I'm sure if you asked him, he'll tell 
you that's how he came into that gate. I never explained it to him. 
I've never explained it to Gigi, but I'm sure she does it. 
Q: And what were you wearing when you did that? 
A: Wearing what -- when? 
Q: What were you wearing when you motioned to the limousine driver with 
your golf club from that entryway? 
MR. BAKER: It's a golf bag. MR.PETROCELLI: Golf bag. Golf bag. THE 
WITNESS: I had on pants. I had on shoes. I had on a robe. 
BY MR. PETROCELLI: 
Q: What color was the robe? 
A: I don't know, but it's still in my house now. 
Q: And no shirt. 
A: And no shirt. 
Q: What kind of robe was it? 
A: Cloth robe. 
Q: White terry cloth? 
A: No. 
Q: What color? 
A: I said it's at my house. It's a darker robe, but it's at my house. 
Q: A black robe? 
A: I don't think so. 
Q: Blue? 
A: Possibly. 
Q: Was it tied? 
A: I doubt it. 
Q: The robe was never taken by the police? 
A: Neither were the bath towels. .Neither were the clothes that I were 
wearing. 
Q: Which clothes? You mean the clothes you took off? 
A: The clothes you asked me about, yes. 
Q: The golf pants you took off. Right? 
A: Yes. 
Q: And the shirt. 
A: Yes. 
Q: So is it your recollection  --  Withdrawn. Did you actually come out 
onto the driveway? 
A: No. 
Q: You're positive of that? 
A: Yes. 
Q: Can you indicate, Mr. Simpson. by pointing to Exhibit 28 where you 
were standing or as far out near the driveway that you came? 
MR. BAKER: OJ., just wait until I come down there. 
BY MR. PETROCELLI: 
Q: Do you understand the question? Okay. You can wait until Mr. Baker 
returns. 
MR. BAKER: And the question is to point where or to make a mark where 
he was the furthest out from the entrance of his front door? 
BY MR. PETROCELLI: 
Q: During this occasion when you lifted your golf bag to signal to the 
limousine driver. 
A: This is purely an estimation. There is not much room there. So I 
would say to the westernmost point of  --  possibly. I don't know if my 
body went that far, but to certainly in the area to the westernmost 
point of my benches. 
Q: What is the distance from the door to the driveway, to the beginning 
of the driveway? 
A: I'd be totally guessing. 
Q: 10 feet? 
A: 15 feet. 
Q: 15 feet. And how many feet were you from the front door? 
A: You told me not to assume, so I'm not going to assume. 
Q: What is your best estimate? 
A: Halfway, three-quarters of the way. 
Q: From the front door? 
A: Yes. 
Q: So you were at least three or four feet from the driveway? 
A: I would say so, yes. 
Q: Okay. I will put a little... 
MR. BAKER: What is that --  
MR. PETROCELLI: What is that, Mr. Baker? You describe it. 
MR. BAKER: No. But I'm saying --  
MR. PETROCELLI: It's a cross. 
MR. BAKER: I understand that, but what I'm saying, that is not where he 
indicated where he said the furthest most  --  the westernmost portion of 
the bench is, and the benches don't go out that far. So that's --  THE 
WlTNESS: And that's an estimate, the westernmost part of the benches, 
but roughly in that area. 
MR. BAKER: There are aerial photographs of this property. There's --  
MR. PETROCELLI: Do you have any? 
MR. BAKER: I do at the office. MR.PETROCELLI: Maybe you can bring one, 
and we can be real clear about it. 
Q: Anyway, your testimony is westernmost part of the benches --  
A: Roughly. 
Q: -- three or four feet from the edge of the driveway. 
A: Yeah, I would say so. 
Q: And standing there upright, a person at the Ashford gate can see 
unobstructed? 
A: Upright, yes. I think if I was down  --  I used to have a bunch of 
bushes there at the time  --  down they would have -- probably would have 
had a little bit of a problem, but standing upright they should have 
had absolutely no problem seeing a person there, as they should have 
had no problem seeing anybody along this entire driveway at this end. 
Q: And at this time when you picked up the bag, Kato Kaelin wasn't 
around yet. Correct? 
A: Correct. 
MR. PETROCELLI: Let's take a short break. 
MR. BAKER: Sure. THE VIDEOGRAPHER: We are going off the record now, and 
the time is approximately 10:51. (Recess.) THE VIDEOGRAPHER: We are 
back on the record now, and the time is approximately 11 :15. 
MR. PETROCELLI: I am going to mark as Exhibit 29 the piece of paper on 
which Mr. Simpson wrote the area of his house that is subject to the 
motion detector  --  was at the time, June 1994. We will omit this from 
the transcript. I will just maintain custody of it. (Plaintiffs' 
Exhibit 29 was marked for identification by the reporter [ and was 
retained by Mr. Petrocelli.) THE WlTNESS: I should write  --  never mind. 
BY MR. PETROCELLI: 
Q: Mr. Simpson, referring to Exhibit 27, which is another sketch of 
Rockingham, when Mr. Kaelin would access typically his property  -- his 
room, I should say, would he take this route that goes around the pool 
to get to his front door? 
A: No. 
Q: Okay. Can you trace how he would go, with the pen? 
A: From the front driveway? 
Q: Yeah. 
A: (Witness complies.) 
Q: And what you -- where you terminated the line, is that the door to his 
room? 
A: Yes. 
Q: This is Exhibit 27. 
A: Actually, I terminated it to the wrong room. That's my daughter's 
room. This is his room. I'll try to put an X there. 
Q: Where the "X" is? 
A: Yes. 
Q: Now, when Kaelin was telling you about these noises, yesterday you 
indicated that he indicated the noises came from the other side of his 
wall, and I just would like you to put a marking there on this sketch 
so that we have a clear understanding. 
A: I'm not sure if I indicated that he said the noises came from the 
other side of his walls. He thought it was  --  I thought he was talking 
about an earthquake. So I didn't have any really idea where he said the 
noises had come from, but he was in his room, and he thought we might 
have had an earthquake, and he was concerned about sounds or something, 
but as I said, I wasn't really paying that much attention to him. 
Q: Did Mr. Kaelin tell you where the sounds or noises that he heard or 
the earthquake that he felt had emanated from? 
A: I don't believe so, but he may have, but I don't have -- I don't 
really know. He just wanted to go look around. 
Q: So you had no idea where on the property that Kaelin heard these 
sounds. 
A: At that point I don't believe I did, but  --  he was talking about an 
earthquake, which I don't know where an earthquake emanates from, and 
he wanted  --  he seemed to want to look around. 
Q: He did not tell you where on the property he believed he might have 
heard a prowler? 
A: I don't believe so? 
MR. BAKER: He didn't mention a prowler. 
THE WITNESS: I don't believe 
so. 
BY MR. PETROCELLI: 
Q: He did not tell you where on the property he wanted to go 
investigate with a flashlight? 
A: Well, he was over by the garage when I saw him. When I was walking, 
he was hanging around by the garage and he had a flashlight. and as I 
said, as I came back in, there was some talk, and I think I suggested 
to him, "Well, let's get a flashlight. You walk one way, I'll go the 
other way, and we'll see. " 
Q: Which way did you tell him to go? 
A: I didn't tell him to go either way at that point. At that point the 
conversation went into the flashlight, and at that point he was going 
to go into the house to see if there was a flashlight. 
Q: When you said to him, "You go one way and I'll go the other way," 
you did not designate which ways you were referring to. Is that 
correct? 
A: Well, there's only two ways to go if you're going to go around my 
house. 
Q: What are those two ways? 
A: One way he would normally take. 
Q: Correct. 
A: And other way is the way to the walkway south of my garage. 
Q: And could you trace that route? 
A: From? 
Q: And then end it with a Y instead of an X. 
A: End it where? 
Q: Well, start at the garage. And you said there were two ways. 
A: Yeah. 
Q: Describe what you just said. 
A: I said he could walk around my house one way. I'll go the other way, 
and we'll see --  
Q: What's the other way? 
A: The walkway. Where do I put the Y, is what I'm trying to ask you? 
Q: Well --  
A: The back of his front door? 
Q: Yes. 
A: Okay. Witness complies.) 
Q: So you could actually walk on the south side of the garage? 
A: Yes. 
Q: The south side of the property? 
A: Yes. 
Q: And is there a path? 
A: Yes. 
Q: And walk all the way to the southern end of the property and then 
come back around. Correct? 
MR. BAKER: Well, that's not the southern end. 
MR. PETROCELLI: Eastern end. 
Q: You are on the southern end, you are walking along the southern end 
of the property heading east. 
A: Yes. 
Q: Go towards the eastern tip of the property, head north and come back 
around. 
A: There is a fence right here (Indicating). 
Q: Are you describing what existed in June of 1994? 
A: I believe so, yes. 
MR. KELLY: Dan, can we just agree that we are going to make copies of 
this after we are done marking it? 
MR. PETROCELLI: Yes. Absolutely. 
MR. KELLY: I don't think Mr. Baker is excited about me looking over his 
shoulder. 
MR. PETROCELLI: I don't think Mr. Baker --  
MR. KELLY: It's just hard to follow it. 
BY MR. PETROCELLI: 
Q: When you were designating, "I'll go this way; you go the other way," 
did you have in mind that Kaelin would go around the pool area and you 
would go around the garage? 
A: We never really got to that point. At that point the conversation 
went to a flashlight. 
Q: If you were heading down the property in an easterly direction 
starting with the garage and going to the end, are there any gates that 
you have to open before you get to the end? 
A: There are gates there, yes. -- 
Q: Could you mark them? 
A: I believe there's one here. (Witness complies.) 
Q: Do you need keys to open those gates? 
A: I don't think so. 
Q: Did you at that time? 
A: I don't believe so