Kim Goldman Deposition of February 5, 1996

Deposition of Kimberly E. Goldman
Rufo v. Simpson

HUTCHINGS COURT REPORTERS
CSR 649

(800) 697-3210
(213) 888-6300 Fax (213) 888-6333
Los Angeles
Santa Ana
San Clemente
Riverside
San Diego

Certified Copy

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

Sharon Rufo, Plaintiff vs. Orenthal James Simpson, et al., Defendants.

DEPOSITION OF KIMBERLY E. GOLDMAN, a witness herein, taken by Defendant Orenthal James Simpson, at 11377 West Olympic Boulevard, Los Angeles, California, at 10:07 a.m., Monday February 5, 1996, before KAREN E. KAY, CSR 3862, RPR, RMR, CRR. Hutchings Number 96-00904-NO

APPEARANCES OF COUNSEL:
For Plaintiff Sharon Rufo:
HORNBERGER & CRISWELL
BY MICHAEL A. BREWER
444 South Flower Street, Thirty-First Floor
Los Angeles, CA 90071

For Plaintiff Frederic Goldman and the Witness:
MITCHELL, SILBERBERG & KNUPP
BY DANIEL PETROCELLI
11377 West Olympic Boulevard
Los Angeles, CA 90064-1683

For Defendant Orenthal James Simpson:
BAKER, SILBERBERG & KEENER
BY PHILIP A. BAKER
and
STEVEN R. VAN SICKLEN
2850 Ocean Park Boulevard, Suite 300
Santa Monica, CA 90405

ALSO PRESENT: FREDERIC GOLDMAN

WITNESS: KIMBERLY E. GOLDMAN

EXAMINATION BY: MR. P. BAKER

EXHIBITS
1001 Larry King Live show segments from air date 12-30-95
1002 L.A. Times articles from 6-15-94 and 10-11-95 1003 List prepared by Ms. Goldman of her friends and their respective telephone numbers (Not attached hereto.)

KIMBERLY E. GOLDMAN, a witness herein, having been sworn, testifies as follows:

EXAMINATION BY MR. P. BAKER:

Q. Good morning. My name is Phil Baker. I represent the defendant in this action. Could you state and spell your name for the record.

A. Kimberly Erin Goldman, K-i-m-b-e-r-l-y E-r-i-n G-o-l-d-m-a-n.

Q. I know you've had a chance to speak to your attorney this morning. I want to go over a couple of the ground rules before we start so you understand them.

First of all, if we touch on anything sensitive or if you ever want to take a break, we'll take a break for however long you want.

Secondly, the court reporter has placed you under oath. That's under penalty of perjury. That's the same oath that you'd take in a court of law. You're still bound by the penalties of perjury as if you were in a court of 1aw.

The court reporter will be taking down everything that's said here today.

After we're done here, as you may or may not know, you'll be getting a booklet-form transcript of all that was said here. You'll have an opportunity to review it, make any changes that you want on the deposition transcript. If you do make any changes, rest assured, we'll probably talk about it at the time of trial.

Thirdly, I'd request you audibilize everything you say today. "Uh-huh," ''huh-uh" doesn't show up well on the record, and it's hard to determine what was said. Do you have any questions of me?

A. No.

Q. Good. What

MR. PETROCELLI: One second before you begin.

MR. P. BAKER:

Q. What is your date of birth?

A. 12-26-71.

Q. What's your Social Security number?

A. [Number deleted]

Q . Is it your understanding Mr. Petrocelli is representing you during this deposition?

A. Yes, it is.

Q. You understand that you're no longer a party to this lawsuit, true?

A. Correct.

Q. As a matter of fact, you were dismissed from this lawsuit on September 11th, 1995, true?

A. If that's the date, yes.

Q. Is Mr. Petrocelli handling any other matter for you?

A. No.

Q. When's the first time you met Mr. Petrocelli?

A. Sometime in October. I don't remember the exact date.

Q. Did you ever meet Mr. Tourtelot?

A. Yes.

Q. And he's no longer your attorney; is that true?

A. That's true.

Q. How many meetings have you had with Mr. Petrocelli or anyone from this law office?

A. Several.

MR. PETROCELLI: You mean about the deposition?

MR. P. BAKER:

Q. About the deposition, about this lawsuit.

A. Since we hired him?

Q. Yes.

A. I don't know. Several dozen, probably.

Q. You said, "we hired him." Does that mean you and your father?

A. As a family.

Q. Do you have any financial interest in this lawsuit?

A. In what lawsuit?

Q. The lawsuit against O.J. Simpson, the civil lawsuit.

MR. PETROCELLI: In other words You can answer.

THE WITNESS: No.

MR. P. BAKER:

Q. Has your father ever promised you any percentage of any proceeds obtained as a result of this lawsuit?

A. Never discussed it.

MR. PETROCELLI: Excuse me.

(Witness and her counsel confer off the record.)

MR. PETROCELLI: The question was, were you ever promised, and you answered you "never discussed it." You didn't answer the question.

THE WITNESS: Did he ever promise me? No.

MR. P. BAKER:

Q. You never discussed it?

A. He never promised me.

Q. Have you ever discussed it?

A. No.

Q. Do you have any other lawsuits for which you are a plaintiff?

A. No.

MR. PETROCELLI: She's not a plaintiff in this lawsuit either.

MR. P. BAKER:

Q. Any lawsuits which you are a defendant?

A. No.

Q. Have you ever filed a lawsuit?

A. Yes. I believe from my car accident I don't know if that was a lawsuit. Sorry.

MR. PETROCELLI: You just testify to the best of your recollection.

THE WITNESS: Sorry.

MR. P. BAKER:

Q. When do you think that lawsuit may have occurred?

A. In '85, '86.

Q. Did you ever obtain any compensation as a result of that possible lawsuit?

A. Yes.

Q. How much?

A. I don't know the exact dollar amount.

MR. PETROCELLI: I think her testimony was, she wasn't sure if there was even a lawsuit. There was some sort of claim, apparently.

THE WITNESS: Okay. No.

MR. PETROCELLI: Don't make up a lawsuit if one didn't exist. Testify to the best of your memory.

MR. P. BAKER:

Q. You have no idea how much you made as a result of that claim?

A. Not the exact amount, no.

Q. Can you give me an estimate?

MR. BREWER: Seems to me this line of inquiry is not reasonably calculated to lead to the discovery of any admissible evidence in this case, how much she got from another lawsuit.

MR. PETROCELLI: You just jumped the gun on me. I concur.

MR. P. BAKER: You can answer.

MR. PETROCELLI: If you got anything. Excuse me.

(Witness and her counsel confer off the record.)

MR. PETROCELLI: I'll instruct her not to answer on the grounds that it's not relevant. It's something that happened 10 years ago.

MR. P. BAKER: Could you mark that.

THE REPORTER Yes.

MR. P. BAKER:

Q. What time did you arrive here today?

A. About 9:15.

Q. Did you have a meeting with anyone?

A. No.

Q. What did you do from 9:15 to l0:00?

MR. PETROCELLI: Wait for me.

THE WITNESS: Waited for Dan. I used the restroom and had coffee and wandered.

MR. P. BAKER:

Q. Have you ever met Mr. Brewer before today?

A. Yes.

Q. When?

A. Formal introduction?

Q. Anytime you've had any contact with Mr. Brewer. Formal introduction would have been at Mr. Simpson's deposition.

Q. You never met him before that day?

A. I think I'm confused with the word "met." I've seen him. I was never formally introduced to him until Simpson's deposition.

Q. Maybe I'm unclear. When's the first time you've spoken with Mr. Brewer?

A. When we were formally introduced at, Mr. Simpson's deposition.

Q. You had never spoken with him before that, true?

A. True.

Q. You didn't speak to him today before this deposition, did you?

A. No.

Q. Have you ever attended any meetings between your father and Mr. Petrocelli?

A. Yes.

Q. How many?

A. 10 or 15 maybe.

Q. When was the first meeting?

A. Within the first week of us hiring him.

Q. Do you know how you paid for Mr. Tourtelot's representation?

MR. PETROCELLI: I think that's irrelevant. I'll instruct her not to answer. Hold on one second.

(Witness and her counsel confer off the record.)

MR. PETROCELLI: The witness doesn't know, in any event; I checked with her. But it's irrelevant.

MR. P. BAKER:

Q. The first meeting you had with Mr. Petrocelli and your father was when?

A. Within the first week of us hiring him.

Q. What do you recall from that meeting?

MR. PETROCELLI: I'll instruct her not to answer on the ground of the attorney-client privilege.

MR. P. BAKER: Do you understand that Ms. Goldman was not a party to the lawsuit at that time?

MR. PETROCELLI: Yes, I understand.

MR. P. BAKER: Are you

MR. PETROCELLI: Might have been a party at that time. I don't know when that dismissal was effected.

MR. P. BAKER: September 11th, 1995.

MR. PETROCELLI: Just to save you the burden of having to question her about this, instruct the witness not to disclose any of her conversations or communications with me on the ground of the attorney-client privilege.

MR. P. BAKER: Although she was dismissed from the lawsuit prior to your initiation of representation?

MR. PETROCELLI: Correct.

MR. P. BAKER: Does that same objection go to any conversations with any attorney from the Mitchell, Silberberg & Knupp office?

MR. PETROCELLI: Correct, if she's had any with them.

MR. P. BAKER:

Q. Have you had any conversations with any other attorneys at Mitchell, Silberberg & Knupp?

MR. PETROCELLI: Other than a casual banter?

MR. P. BAKER:

Q. Regarding the lawsuit.

MR. PETROCELLI: Substantive conversations.

THE WITNESS: Yes.

MR. P. BAKER:

Q. Who?

A. Peter Gelblum and Ed Medvene.

Q. How many conversations with Peter Gelblum?

A. Half a dozen maybe.

Q. How about Ed Medvene?

A. Same. Half a dozen.

MR. P. BAKER: And I suppose Mr. Petrocelli, you won't allow us to ever ask about any conversations she'd had with Mr. Gelblum or Mr. Medvene?

MR.. PETROCELLI: Correct. And any members of our firm on the ground of attorney-client privilege, as well as attorney work product.

MR. P. BAKER:

Q. Have you had any conversations with your father about this lawsuit?

A. Numerous.

MR. PETROCELLI: Mr. Baker, because of my instruction, I believe, is now asking about conversations with your father in which counsel were not participants.

THE WITNESS: I understand.

MR. P. BAKER:

Q. When was the first time you and your father discussed the civil lawsuit?

A. I need to ask a question.

Q. Of your lawyer? Do you want to take a break?

A. No.

(Witness and her counsel confer off the record.)

MR. PETROCELLI: I would say the very first time. That's the understanding I have of the question.

THE WITNESS: Probably in March or April of '94.

MR. P. BAKER:

Q. What do you remember from that conversation?

A. Just that we needed to decide whether we wanted to file or not.

Q. And what did you recommend?

MR. PETROCELLI: If anything.

THE WITNESS: I didn't recommend anything.

MR. P. BAKER:

Q. Is that all you remember from that conversation?

A. Vaguely, yes.

Q. Was anyone else there?

A. The rest of the family.

Q. Who is "the rest of the family"?

A. My dad's wife, Patti; And my stepbrother and sister, Michael and Lauren.

Q. How old are they?

A. Michael is 17 and Lauren is 15.

Q. And it's Michael Goldman?

A. Michael Glass.

Q. What's his date of birth?

A. 3-14 I have no clue what year he was born. He's going to turn 18. What is that, '77?

MR. PETROCELLI: No. It's got to be an even number. '78.

MR. P. BAKER:

Q. How about Lauren Glass?

A. August 10th, '80.

Q. Where do they live?

A. In Agoura with us.

Q. And who are Michael Glass and Lauren Glass's parents?

A. Patti Goldman and Marvin Glass.

Q. Was Sharon Rufo at the meeting?

A. No.

MR. PETROCELLI: Are you talking about this initial conversation?

MR. P. BAKER: Yes.

THE WITNESS: No.

MR. P. BAKER:

Q. When was the next time you had a conversation with your father about this lawsuit?

MR. PETROCELLI: If you recall.

THE WITNESS: Don't know specifically the day.

MR. PETROCELLI: One second.

(Witness and her counsel confer off the record.)

MR. P. BAKER:

Q. Michael and Lauren, are they employed, or do they go to school?

A. Both attend school, and Michael works.

Q. Which school do they go to?

A. Oak Park High School.

Q. In Agoura?

A. Uh-huh, correct.

Q. Where does Michael work?

A. Oak Tree Deli.

Q. When was the next conversation you recall with your father about this lawsuit?

A. When or what?

Q. When? I apologize.

A. I don't know the exact date. Could have been the next day. I don't know.

Q. Do you remember what the nature of that conversation was?

A. No.

Q. You remember a conversation, but you don't know what it was about or when it was, true?

A. True.

MR. PETROCELLI: These conversations are all about the subject of the lawsuit, right?

MR. P. BAKER: True.

MR. PETROCELLI: You remember it's about the lawsuit, but can't remember the specifics?

THE WITNESS: True.

MR. P. BAKER:

Q. Do you recall any conversations following that second conversation?

A. Just the final one, that we decided to file.

Q. When did you decide to file?

A. Late April, I would think.

Q. Who was at that conversation? MR. PETROCELLI: Was there any counsel there?

THE WITNESS: No.

MR. P. BAKER:

Q. Who was at that conversation?

A. My father, Patti, and I would the kids might have been there, but I don't remember specifically.

Q. Did you ever include Sharon Rufo in any of these conversations?

A. No.

MR. BREWER When you asked that question, was she ever present during any of these conversations?

MR. P. BAKER: Yes.

THE WITNESS: No.

MR. P. BAKER:

Q. When did you first learn she had filed a lawsuit?

A. In July of '94.

Q. What was your reaction to that?

A. I was shocked.

Q. You were angry?

A. I was shocked.

Q. You were not angry?

A. Maybe my initial reaction might have been anger.

Q. When was the last time Ms. Rufo ever saw Ron Goldman?

MR. BREWER Objection Calls for speculation, lacks foundation

MR. PETROCELLI: Lack of foundation. How would she know? You can probe, but

MR. P. BAKER: Maybe somebody told her.

MR. PETROCELLI: As phrased, I object, but you can answer.

THE WITNESS: What was the question?

MR. P. BAKER:

Q: "When was the last time Ms. Rufo ever saw Ron Goldman?"

MR. BREWER Question lacks foundation, calls for speculation.

MR. PETROCELLI: Same objections.

THE WITNESS: To the best of my knowledge, roughly 15, 16 years ago earlier.

MR. PETROCELLI: 15, 16 years earlier than what?

THE WITNESS: His death.

MR. P. BAKER:

Q. When was the last time you saw Sharon Rufo prior to June of 1994?

A. 6 years, roughly.

Q. Do you know if Ms Rufo ever had any contact whatsoever that you know of with Ron Goldman in the last 15 years before his death in June of 1994?

A. I know of one conversation.

Q. When was that?

A. '92, I think.

Q. Do you know what that was regarding?

A. No.

Q. How did you learn of the conversation?

A. Ron told me.

Q. What did he tell you about it?

A. He told me that he called Sharon.

Q. Did he tell you about what?

A. Just to chat. Q. Anything else you remember about what he told you about that conversation at all?

A. Just general conversation, nothing specific.

Q. Did they plan on seeing one another? Do you recall that?

MR. PETROCELLI: Lack of foundation.

MR. P. BAKER:

Q. Did he tell you?

MR. PETROCELLI: The question is, did Ron tell you that he planned on seeing Sharon Rufo in that conversation in 1992?

THE WITNESS: No.

MR. P. BAKER:

Q. Did Ron tell you that he planned on speaking with her again?

A. No.

Q. When you found out that Ms. Rufo filed this lawsuit, you were shocked?

A. Correct.

Q. And why were you shocked?

A. Because at this point, I didn't know that that was an option; I didn't understand what filing a civil suit meant.

Q. You were shocked because you didn't believe she had a right to file this lawsuit, true?

A. After I understood what it meant to file a lawsuit.

Q. And the answer is true?

A. True.

Q. In fact, you called up Larry King on January 25th, 1995, when she was a guest on that show, didn't you?

A. Yes

Q. Why did you call the show that day?

A. Because I wanted to confront her on some issues.

Q. Which issues?

A. Whatever she was speaking of at the time I don't remember specifically.

Q. You don't recall what you wanted to confront her on?

A. That was a year ago I don't remember specifically what the issues were at the time.

Q. You were upset she was filing a lawsuit and obtaining fame as a result of that lawsuit, true?

MR. PETROCELLI: "Obtaining fame"?

MR. P. BAKER:

Q. Seeking fame?

MR. BREWER: Objection. Question is argumentative, also, compound.

MR. PETROCELLI: He's asking you questions in a leading form, which he's entitled to, but you should evaluate whether what he's saying is what your belief is. If it's not, then tell him so.

MR. P. BAKER:

Q. Is that your belief?

A. I don't remember specifically at the time why I called. That was over a year ago.

Q. Let me read part of the transcript that may help you.

MR. PETROCELLI: Want to show it to her?

MR. P. BAKER: Sure. I think we have another copy.

MR. PETROCELLI: Are you going to mark this?

MR. P. BAKER: Let's mark it.

MR. PETROCELLI: I want to start at 1000.

MR. P. BAKER: We'll mark this 1000. It's a transcript from the Larry King show on numerous dates, and the date which I'm referring begins on page 9.

MR. PETROCELLI: This is Exhibit 1000?

MR. P. BAKER: Let's make it 1001.

MR. PETROCELLI: And what's the date of the show?

MR. P. BAKER: The transcript we have is of January 25th, 1995. It's a segment of the transcript.

MR. PETROCELLI: Larry King is a prominent witness in this case.

MR. BREWER: When you say "it's a segment," are you talking about a segment of a show that reflects their conversation or segment of their conversation?

MR. P. BAKER: Segment of the show that reflects their conversation.

MR. BREWER It's being shown to refresh her recollection with respect to what issue?

MR. P. BAKER: What she was upset about.

MR. PETROCELLI: Is this document, Exhibit 1001, transcript of the spoken words on that entire show?

MR. P. BAKER: No.

MR. PETROCELLI: It is not.

MR. P. BAKER: From what I understand, this is a CNN show that took together aspects of segments of shows and put them together into 1 show.

MR. PETROCELLI: And your belief is that one of the segments dealt with Ms. Goldman's

MR. P. BAKER: Turn to page 9, refers to a January 25th, 1995 call.

MR. PETROCELLI: You understand he is not representing that this is a transcript of what you said. It may or may not be accurate.

MR. VAN SICKLEN: Look on page 11, and it describes how it was

MR. P. BAKER: transcribed.

MR. PETROCELLI: Correct. And it is not obviously the entire interview. Okay. What's your question, Mr. Baker?

MR. P. BAKER: Do you want her to have a chance to read that? It goes back to page 10.

MR. PETROCELLI: Why don't you start reading over here (indicating), and then go through page 10.

MR. BREWER: Do you have another copy of 1001 in front of you?

MR. P. BAKER: Yes.

MR. PETROCELLI: Okay.

MR. P. BAKER:

Q. Does the transcript reflect or assist your recollection regarding that phone call?

A. Yes.

Q. Now, do you recall why you were upset?

A. Yes.

Q. Why were you upset?

A. Because she was saying she was feeling left out or there wasn't enough attention being paid to her.

Q. And that bothered you, right?

A. Yes.

Q. And it bothered you because Sharon Rufo and Ron Goldman had hardly any contact prior to his death, true?

A. Yes.

Q. It bothered you because she left your family when you were 3 years old, true?

A. True.

Q. In fact, you didn't even think Sharon Rufo would have recognized Ron Goldman if he walked down the street in June of 1994, true?

MR. BREWER: Objection. Argumentative, lacks foundation.

THE WITNESS: At that time, yes.

MR. P. BAKER:

Q. "At that time, yes." You didn't think she would recognize him in June 1994?

A. Correct.

Q. Did you learn of anything that would change your opinion about that?

A. Yes.

Q. What did you learn?

A. She was given photos of my brother and I.

Q. When was she given photos of your brother?

A. I have no idea.

Q. When did she receive those photos?

A. I have no idea.

Q. Do you know if it was prior to his death or after his death?

A. Prior.

Q. How did you find out she received photos?

A. I believe she told me she was given photos from my grandparents.

Q. What are your grandparents' names?

A. Julius

MR. PETROCELLI: These particular grandparents?

MR. P. BAKER: Yes. Sorry.

THE WITNESS: Julius and Blanche Fohrman.

MR. P. BAKER

Q. Where do they live?

[City and State Deleted]

Q. She told you that they had sent pictures of Ron to Sharon Rufo?

A. Correct.

Q. When did she tell you that?

A. I don't think I remember specifically when that conversation

Q. Was it during the criminal trial?

A. No.

Q. After the criminal trial?

A. No.

Q. Prior to the criminal trial.?

A. Yes.

Q. Prior to his death?

MR. PETROCELLI: That she learned about the photos?

MR. P. BAKER: Yes.

THE WITNESS: I don't remember if it was before he died.

MR. P. BAKER:

Q. In that conversation with Larry King, you said, "Sharon, people see right through you, Honey." What did you mean by that?

A. That maybe she was doing it for the wrong reasons.

Q. What reasons did you think she was doing it for?

A. Monetary reasons.

Q. Do you still think that?

A. Yes.

MR. PETROCELLI: It's irrelevant.

MR. BREWER: When you say "that" just to make sure I'm clear on your question, did Sharon Rufo file a civil lawsuit in Superior Court for monetary reasons; is that the gist of your question when you say she thought that?

MR. P. BAKER: I think the record reflects what was asked and answered.

MR. BREWER: Move to strike the answer to interpose the objection as vague and ambiguous.

MR. P. BAKER:

Q. Is it your position that this lawsuit filed by your family has nothing to do with money?

MR. PETROCELLI: I instruct her not to answer. She doesn't have a position. She's here to give you information or knowledge she has as a witness.

MR. P. BAKER: She doesn't have a position as to this lawsuit?

MR. PETROCELLI: If she does, it's in her personal view, it's not relevant, and you're not entitled to know.

MR. P. BAKER: In your view I want to understand the nature of you not allowing questions.

MR. PETROCELLI: The nature of the objection on her position is irrelevant, and I instruct her not to answer.

MR. P. BAKER:

Q. Have you ever made any public statements about why this lawsuit was filed?

A. Yes.

Q. What have you said?

A. To ensure justice.

Q. Have you ever said that you were not seeking any monetary compensation as a result of this filing?

A. I said that it was not about the money.

Q. When was the last time you spoke with Sharon Rufo?

MR. BREWER: In person, telephonically?

MR. P. BAKER:

Q. Either way.

A. January of '95.

Q. This phone call (indicating).

A. Oh, yes, this would be the last, I believe. Wait. Let me think. This may have been the last time.

Q. Do you know what she does for a living?

A. No.

Q. Do you know where she lives?

A. St. Louis.

Q. Do you know how she earns a living?

A. No.

Q. Do you know how she supports herself?

A. No.

Q. I was talking to you earlier about conversations you had with your father regarding this lawsuit, and we got through a few, but I don't think we discussed some in their entirety.

Can you name for me the first conversation you had with your father regarding this lawsuit following Mr. Simpson's acquittal on October 3rd, 1995?

MR. PETROCELLI: Excluding conversations with lawyers?

THE WITNESS: Not specifically.

MR. P. BAKER:

Q. Well, let s do it the other way. Do you recall your most recent conversation with your father outside of your attorneys regarding this lawsuit?

A. Daily.

Q. Has he ever told you about the progress of the suit?

A. Yes.

Q. What's he told you?

MR. PETROCELLI: Do not discuss anything that your father said to you that was communicated to him by lawyers representing him in the case.

MR. P. BAKER: You don't believe there's a waiver of the attorney-client privilege?

MR. PETROCELLI: No, Mr. Baker, I do not believe that.

MR. P. BAKER: Can you mark that, please.

THE REPORTER: Yes.

MR. P. BAKER:

Q. You can still answer.

A. Can you repeat that.

MR. PETROCELLI: Let me clarify where we are on this, Kim. He's asking you a question about conversations that you had with your father after Mr. Simpson's acquittal about the subject of the lawsuit. And you may answer if you recall, except you are not to discuss any information that your father disclosed to you that came from counsel.

If you are able to answer with those limitations, please do so. If you're not, then you must not answer. Okay?

THE WITNESS: Okay. What was the question now?

MR. PETROCELLI: I want you to listen to what I said because I gave you the question.

So please read that back, Ms. Reporter.

(The record is read by the reporter.)

THE WITNESS: Yes, there were conversations, and just about the progress of the case.

MR. P. BAKER:

Q. What progress was that?

A. Where we were at with discovery or hearings.

Q. And he, during those conversations, discussed information that he had learned from his attorneys, true?

A. Correct.

Q. And he told you that when he told you about the progress of the case; he did tell you information he gleaned from his attorneys, true?

A. True.

Q. And how many such conversations ever occurred?

A. On a day-to-day basis.

Q. Since Mr. Simpson's acquittal?

A. Since we hired Mitchell, Silberberg & Knupp.

Q. Do you presently live with your father?

A. Yes.

Q. What's the address?

A. [Address deleted.]

Q. Who lives there?

A. My father; Patti; Michael; And Lauren.

Q. Do you know if Ron Goldman was ever married?

A. No, he wasn't.

Q. Did he have any dependents whatsoever?

A. No.

Q. Did you ever meet Nicole Simpson?

A. No.

Q. Did Ron ever talk to you about her?

A. No.

Q. Had you ever heard her name in any manner whatsoever prior to June 12th, 1994?

A. No.

Q. Never went to her house?

A. No.

Q. Never got in her car?

A. No.

Q. You had dinner with Ron on May 15th, 1994, didn't you?

A. No.

Q. That never happened?

A. No.

MR. PETROCELLI: When you say "that," you mean dinner on May 15, 1994 with Ron Goldman?

MR. P. BAKER: Right.

THE WITNESS: No.

MR. P. BAKER:

Q. Where were you in June of 1994?

MR. PETROCELLI: Prior to Ron's death.

THE WITNESS: San Francisco.

MR. P. BAKER:

Q. What were you doing in San Francisco?

A. Going to school and working.

Q. Where were you going to school?

A. San Francisco State.

Q. What were you studying?

A. Psychology.

Q. Where were you working?

A. Wells Fargo Bank.

Q. Which branch was that?

A. Stonestown.

Q. What was your address up there?

A. [Address deleted.]

Q. In San Francisco?

A. San Francisco. Sorry.

Q. When was the last time you saw Ron prior to his death? Would you like to take a break?

A. Please.

MR. PETROCELLI: Okay.

(A recess is taken.)

MR. P. BAKER:

Q. Do you remember the question? Let me read it back.

"When was the last time you saw Ron prior to his death?"

A. In April '94.

Q. Where did you see him?

A. In Agoura. I went home for a Jewish holiday, Passover.

Q. He never mentioned Nicole Simpson to you?

A. No.

Q. Did you ever hear of O.J. Simpson prior to his death in anything involving a friendship or in a relationship with Ron?

A. No.

Q. The only knowledge you had of O.J. Simpson prior to his death was that of his celebrity status?

A. If even that much.

Q. What do you remember of your April 1994 interaction with Ron?

MR. PETROCELLI: You mean at the Passover?

MR. P. BAKER: Yes.

THE WITNESS: The Seder. The normal family jokes and conversations.

Q. Do you know what he was doing for a job in April of 1994?

A. He was working for Mezzaluna, M-e-z-z-a-l-u-n-a.

MR. PETROCELLI: Means half moon in Italian.

MR. P. BAKER:

Q. Do you know if he had any other jobs in April of 1994?

A. I know he had a company business.

Q. What company?

A. Called Design Wrap.

Q. What was Design Wrap?

A. It was a They promoted movie wraps and recording wraps, like they would do parties.

Q. Wrap parties like at the end of a movie?

A. That's correct, uh-huh. I don't know if that was consistent work, though.

Q. Was he the owner of that company?

A. He was a partner.

Q: Who were his other partners?

A. Jeffrey Wong Fong, Jeffrey Fong

MR. PETROCELLI: Fong.

THE WITNESS: Fong. And another man named Nicholas. I don't remember his last name.

MR. P. BAKER:

Q. Anyone else you know working for this Design Wrap?

A. No.

Q. Do you know when it was started?

A. No.

Q. Do you know where its office is?

A. I don't believe they had an office.

Q. Did they have fliers? Did you ever see any documentation of Design Wrap?

A. Yes.

Q. What did you see? A. Business cards and partnership agreement.

Q. Was Ron's partnership interest 33 percent, or was it higher or greater than that?

A. I believe they were all equal partners.

Q. And there were 3 partners?

A. Correct.

Q. Do you know when that company first came into existence?

A. Not specifically.

Q. And it was still active in June of 1994?

A. I believe so.

MR. PETROCELLI: If you know. Don't speculate. I don't know what "active" means.

THE WITNESS: I'm not sure.

MR. P. BAKER:

Q. Was it still in existence in June of 1994?

A. I'm not positive.

Q. How many parties did they have? Do you know?

A. I only know of 2 specifically.

Q. Which were those?

A. It was One was at the end of a movie. I don't remember the name. And the other, they just threw a party for I don't remember specifically.

Q. Do you know if that partnership was making money?

A. Probably.

Q. How do you know that?

A. Why else would he have a business? I would just I don't know specifically.

Q. You don't know if it was making money or not?

A. No, I don't.

Q. How much work did Ron do for Design Wrap? In other words, how much of his average workweek was spent working for Design Wrap?

A. Limited.

Q. What does "limited" mean to you, ma'am?

A. His main job was Mezzaluna. That's where he spent his time.

Q. Did he spend a couple hours a week working for Design Wrap a week?

MR. PETROCELLI: Kim, do not speculate. If you know based on his telling you or some other way, you can answer; but if you're just guessing, you can't answer that.

THE WITNESS: I don't know.

MR. P. BAKER:

Q. Anyone ever tell you?

A. No.

Q. Was he doing any other employment in April to June of 1994 other than Mezzaluna and Design Wrap?

MR. PETROCELLI: By "employment," Mr. Baker, you mean work for money?

MR. P. BAKER: Yes.

THE WITNESS: May have given a few tennis lessons, but I'm not I can't be specific on the dates.

MR. P. BAKER:

Q. Who was he giving these tennis lessons?

A. Sometimes when the client Either at their home or at their private club, he would give private lessons.

Q. Do you know how he'd get hired?

A. Word of mouth.

Q. When did he start giving tennis lessons?

A. 1990 he started.

Q. Where did he start?

A. He taught for Thousand Oaks Park and Recreation, teaching children.

Q. When did he stop working at Thousand Oaks Park and Recreation?

A. I believe that was the summer, a summer job.

Q. Just in 1990?

A. I believe so.

Q. And then he did private lessons following that?

A. Periodically he would.

Q. And he was doing those periodic lessons in the spring and summer of 1994?

A. I believe so.

Q. Any other jobs you know he may have had in April to June of 1994?

A. No.

Q. Was he a club promoter?

MR. PETROCELLI: What does that mean?

MR. P. BAKER:

Q. Do you know what that means?

A. No.

Q. Have you ever heard that he was promoting clubs?

MR. PETROCELLI: What kind of clubs, Mr. Baker?

MR. P. BAKER:

Q. Dance clubs, bars?

A. I believe that was part of Design Wrap.

Q. What did you understand that part of Design Wrap to be?

A. I didn't.

Q. Who told you that was part of Design Wrap?

A. Ron did.

Q. Did you understand that he was organizing parties at these clubs?

MR. PETROCELLI: The question is vague.

THE WITNESS: For the wrap job clubs. That's all I knew.

MR. P. BAKER:

Q. That's your only extent of knowledge of Ron acting as a club promoter?

A. Correct.

Q. Have you ever heard the name [Name Deleted]?

A. No.

Q. How about [Name Deleted]?

A. Yes.

Q. Where have you heard his name?

A. I met [Name Deleted] in Santa Barbara. And I know he was friends with Ron.

Q. When did you meet him in Santa Barbara?

A. '92, maybe.

Q. How did you meet him?

A. Mutual friends.

Q. Was Ron there?

A. No.

Q. Were you introduced to him randomly, or were you supposed to meet?

A. Blind date.

Q. You and [Name Deleted] were on a blind date?

A. Uh-huh.

THE REPORTER "Yes"?

THE WITNESS: Yes. Sorry.

MR. P. BAKER:

Q. Did you see him after that night?

A. Yes.

Q. On how many times?

A. A handful.

Q. Is that 5?

A. 5.

Q. Did you go out with him?

A. In a group of people.

Q. You never were dating[Name Deleted]?

A. No.

Q. What did he do for a living?

A. At this time?

Q. Yes.

A. He worked at I always forget the name at a restaurant in Santa Barbara.

MR. PETROCELLI: What's the time frame?

MR. P. BAKER:

Q. 1992 he worked at a restaurant in Santa Barbara?

A. Yes.

Q. Do you remember the name of the restaurant?

A. No.

Q. Do you know what he did following his work at the Santa Barbara restaurant?

A. He moved to Los Angeles.

Q. Did you ever see him in Los Angeles?

A. No.

Q. Did Mike meet Ron through you, or did he know Ron before you met Mike?

A. Can you say that again.

Q. I'm not sure I even understood it. Did[Name Deleted] know Ron prior to the first time you ever met [Name Deleted]?

A. No.

Q. Did you introduce Mike and Ron?

A. No.

Q. How did they meet?

A. I was told in Los Angeles.

Q. Do you know what Mike did for a living when he came to Los Angeles?

A. Not specifically.

Q. What understanding do you have at all about his employment in Los Angeles?

A. That he wanted to do acting.

Q. Do you know if he was successful?

A. No, I don't know.

Q. What do you know at all about [Name Deleted] after he moved to Los Angeles?

A. That he was killed.

Q. Anything else?

A. He got Ron a job at Mezzaluna.

Q. Did you ever hear that he was a club promoter?

A. No.

Q. Did [Name Deleted] work at Mezzaluna prior to Ron?

A. I don't know.

Q. How did [Name Deleted] get Ron a job at Mezzaluna, if you know?

A. I don't think I know.

Q. Do you know anything about [Name Deleted]'s death?

A. Yes.

Q. What do you know?

A. He was shot.

Q. Do you know when this occurred?

A. Sometime throughout the course of the criminal case.

Q. 1994, 1995?

A. Sometime in '95.

Q. Were you ever questioned regarding that case?

A. No.

Q. Were you ever questioned regarding the death of Ron by any LAPD officer?

MR. PETROCELLI: When you say "questioned" about "the death of Ron," you mean anyone ever at any time asked her any questions about Ron?

MR. P. BAKER: Yes.

THE WITNESS: Yes.

MR. P. BAKER:

Q. Which officer?

A. Detective Tippin, T-i-p-p-i-n.

Q. When did this occur?

A. Within a few days, first few days, of '94, June.

Q. Did Detective Tippin take notes?

A. I have no idea.

Q. Was there a tape recorder there?

A. I don't remember.

Q. When was this statement taken?

A. It wasn't a statement.

Q. It was just questioning?

A. Yes.

Q. What type of questions?

A. What?

Q. I apologize. What type of questions? Is it a he?

A. Yes.

Q. What type of questions did he ask you?

A. I think at that point just who lived with him, how long was he at his present address. Just general background on my brother.

Q. When thinking about the conversation, how do you recall that Detective Tippin took notes?

A. No, I don't.

MR. PETROCELLI: You don't know; is that what you are saying?

THE WITNESS: Right.

MR. P. BAKER:

Q. Did you ever talk to any other LAPD officers about this case or the criminal case? Actually, let me rephrase that.

Did you ever talk to any other LAPD officers about the death of Ron?

A. Tippin's partner, Detective Carr, C-a-r-r.

Q. When did that conversation take place?

A. Same day, within the first 2 days after Ron's death.

Q. Where was that conversation?

A. At Ron's apartment.

Q. Were you visiting Ron's apartment, and they were already there?

A. No. We met them there.

Q. Were they in the apartment?

A. We let them in.

Q. Who is "we"?

A. My father and I.

Q. Had any officer been in the apartment prior to that conversation?

MR. PETROCELLI: To your knowledge.

THE WITNESS: No.

MR. P. BAKER:

Q. When did you first go to Ron's apartment following the news you heard about his death?

A. Tuesday the 14th.

Q. Who did you go to that apartment with?

A. My dad and family friends.

Q. Who are those family friends?

A. [Names deleted.]

Q. [Name deleted]?

A. [Name deleted.]

Q. Where do they live?

A. In Agoura.

Q. Do you know their phone numbers?

A. Not off the top of my head.

Q. Do you know their address?

A. Not off the top of my head.

Q. How do you spell their names?

A. [Names deleted.]

Q. Was Patti Goldman there?

A. No.

Q. Had anyone been to Ron's apartment that you know of on June 13th, 1994?

A. Not that I know of.

Q. Did anyone advise you not to go to Ron's apartment? Any police officer, any district attorney, any law enforcement person ever tell you not to go to Ron's apartment following the news of his death on June 12th, 1994?

A. No.

Q. Did Detective Tippin and Carr inspect his apartment?

A. Can you explain "inspect."

Q. What rooms did they go in when they went to Ron's apartment?

A. All the rooms.

Q. Did they take anything from the apartment?

A. Yes.

Q. What did they take?

A. Some photos; A book or two; Ron had an electronic phone book; Maybe some paperwork.

Q. Did they ask your authorization before they took it?

A. Yes.

Q. And you agreed to let them take it?

A. Yes.

Q. What photos did they take?

A. The only one I remember specifically was one of Ron and his ex- girlfriend.

Q. Who was his ex-girlfriend?

A. Jacqui Bell, J-a-c-q-u-i. And another picture.

Q. Do you recall what that picture was?

A. I think a picture of a group of friends of his.

Q. What books?

A. A book about working out relationships.

Q. Do you remember any other books they took?

A. No.

Q. How long had you been in the apartment before Detective Tippin and Carr appeared?

A. We waited for them outside.

Q. You hadn't been in the apartment at all?

A. Right.

Q. Do you know if any one of your family had been in the apartment?

A. No.

Q. How did you get in?

A. A key.

Q. Who had the key?

A. My dad and I.

Q. Where did you acquire this key?

A. From the landlady.

Q. How long were Tippin and Carr there?

A. Less than an hour.

Q. Did you see any photos of Nicole in that apartment?

A. No.

Q. What was the address of that apartment?

A. [Name Deleted].

Q. And the apartment number?

A. I think it was 3.

Q. When did Ron and Jacqui break up?

A. I believe the end of '93.

Q. How did you learn of this?

A. Ron told me.

Q. Why did they break up? Do you know?

A. Relationship wasn't working.

Q. Is that all you know about it?

MR. PETROCELLI: About why they broke up?

MR. P. BAKER: Yes.

THE WITNESS: Just that they couldn't work it out.

MR. P. BAKER:

Q. Who broke up with whom? Do you know?

A. The final time, I think Ron did.

Q. Who was he dating after Jacqui?

A. Andrea.

Q. What is her name?

A. Andrea Scott.

Q. When did they start dating?

MR. PETROCELLI: If you know.

THE WITNESS: I don't think I know specifically.

MR. P. BAKER:

Q. When do you think they started dating? Were you told by Ron about when they started dating? A. No.

Q. Was it soon after the relationship with Jacqui ended?

A. No.

Q. Was it February, March, April of '94? Do you know?

A. The earliest time I knew about her was in May. '94.

Q. How did you find out about it?

A. I was supposed to meet her.

Q. Where were you supposed to meet her?

A. In Agoura

Q. Were you down in May of '94?

A. No. I was going to meet her in June.

Q. You were told about her in May?

A. Correct.

Q: Who told you about her?

A. Either my dad or Patti did.

Q. After you were down here in April of 1994 for the Passover, did you come down here until after the news of Ron's death in June of 1994?

A. No.

Q. Did you plan to return here in June of 1994?

A. Yes.

Q. For what reason?

A. My little sister's 8th grade graduation.

Q. That's Lauren?

A. Yes.

Q. Did you know if Ron spent a lot of time in Ventura?

A. No.

MR. PETROCELLI: You mean county of Ventura?

MR. P. BAKER: Yes.

Q. You don't know A. County of Ventura? Yes.

Q. Did he have any friends up there?

A. Well, we live in Ventura County.

Q. City of Ventura?

A: City of Ventura, no.

MR. PETROCELLI: You don't know?

THE WITNESS: Right, I don't know.

MR. P. BAKER:

Q. Who was Ron's best friend?

A. Mike Pincus and Pete Argyris. Q. Mike Pincus, how do you spell that name?

A. P-i-n-c-u-s.

Q. Where does he live?

A. Thousand Oaks.

Q. Do you know his phone number?

A. I would be guessing.

Q. Why don't you give me your guess, if you have any idea.

A. [Number deleted.]

Q. What is the second one?

A. Pete Argyris.

Q. How do you spell that?

A. A-r-g-y-r-i-s.

Q. Where does he live?

A. Las Vegas.

Q. Do you know his number?

A. Not off the top of my head.

Q. What do they do for a living?

A. Mike is a personal trainer; And Pete is in construction and real estate.

Q. I'm going to mention a series of names to you; and more often than not, I only have first names; and if it brings back any recollection about the name to me to you, rather, will you tell me that?

A. Yes.

Q. Jennifer, [Number deleted]?

A. No.

Q. Have you ever heard of Jennifer Nassiri?

MR. PETROCELLI: What is the document you're reading from?

MR. P. BAKER: From what I believe and to be honest, I don't have the full knowledge I believe it's a list of names taken off Ron's electronic Rolodex.

Q. Jennifer Nassiri, do you have any knowledge of that person?

A. No.

Q. Jim Klauskpf, K-l-a-u-s-k-p-f?

A. Yes.

Q. Who is he?

A. Friend of Ron's since he moved here.

Q. Do you know what he does for a living?

A. No.

Q. John Carpenter?

A. I think I've met him.

Q. What does he do?

A. I don't know.

Q. Where did you meet him?

A. At the funeral, I think.

Q. Julian Cone, C-o-n-e.

A. No.

Q. Kam, K-a-m.

A. Can I ask you a question? Is this before Ron's death? Do I know these people

Q. Any knowledge whatsoever you have about these.

A. Say it again.

Q. K-a-m?

A. I believe so.

Q. Who is that?

A. I think her name is Kamie.

Q. Where did you meet her?

A. I don't know if that I did.

Q. Did Ron mention her to you?

A. Yes.

Q. What did she do for a living?

A. I don't know.

Q. Katherine, [Number deleted].

A. No.

MR. BREWER: Rather than read the phone numbers into the record, unless it's absolutely necessary, why don't you show her the phone number, and maybe that will refresh her recollection.

MR. P. BAKER: All right. That's probably best, Mr. Brewer.

Q. Kelly Apone?

A. Yes.

Q. Who is she?

A. Friend.

Q. What does she do for a living?

A. I don't know.

Q. Do you know Kam's last name?

A. No.

Q. Kim Ross?

A. Yes.

Q. Who is she?

A. Friend.

Q. Do you know what she does for a living?

A. No. Idon't remember.

Q. Do you have any idea?

A. I just know she works for a company. I don't remember.

Q. Lauren perhaps Cohen?

A. Yes.

Q. What does she do?

A. She was doing temp work.

Q. Do you know anything else about their relationship?

A. They were really good friends.

Q. Did he know her from work, Mezzaluna?

A. No.

Q. Linda (indicating)?

A. No.

Q. Lou Gaetz?

A. No.

Q. Marcicella?

A. Marcicella.

MR. PETROCELLI: There you go pronouncing those Italian Cs incorrectly.

MR. P. BAKER: I have a little Italian in me. I don't know what my problem is.

MR. PETROCELLI: I knew there was something likable about you, Mr. Baker.

MR. P. BAKER: Nothing about Marcicella?

A. I don't think so.

Q. Marena?

A. Yes.

Q. Marena is

A. a friend.

Q. Last name?

A. I don't remember.

Q. Where does she live?

A. Maybe in the Valley, but I don't know for sure.

Q. Okay. Mark Levy?

A. I think Yes, I think I know him.

Q. Do you know what he does?

A. No.

Q. Do you know the nature of their relationship?

A. No.

Q. Melanie?

A. No.

Q. Melissa?

A. No.

Q. Michelle?

A. No.

Q. Mike Berg?

A. I don't think so. I don't think so.

Q. Mike Davis?

A. Yes.

Q. Who is he?

A. One of his friends in Brentwood.

MR. PETROCELLI: Well, Kim, are you answering about things that you knew as of the time he died or later when you say "One of his friends"? I'm a little confused.

THE WITNESS: He told me either.

MR. P. BAKER: I told her either.

MR. PETROCELLI: So from her answer, then, it's not clear if she knew this at the time or learned it later on from any source.

MR. P. BAKER:

Q. What's Mike Davis do?

A. I don't know.

Q. Mike Hess?

A. I knew of him after Ron's death.

Q. How do you know of him?

A. He came to the house after the funeral.

Q. Do you remember anything else about him?

A. Just that they were friends.

Q. Mike Senkman?

A. No.

Q. Mike Zakin?

A. Yes.

Q. Who is he?

A. This guy's an old family friend since Ron and were kids.

Q. What's he do for a living?

A. He works at a I don't know. I don't remember.

Q. Do you know who Pete is?

A. Pete is Pete Argyris.

Q. How do you spell the last name?

MR. VAN SICKLEN: She already did.

MR. P. BAKER:

Q. Did I ask you what he does for a living?

MR. PETROCELLI: Construction and real estate.

MR. BREWER In Las Vegas.

MR. P. BAKER:

Q. Rain Pryor?

A. Yes.

Q. What does she or he do?

A. I don't know what she does.

Q. Do you know the nature of their relationship?

A. They became friends when we moved here.

Q. Did they ever date?

A. Maybe once or twice. Just friends.

Q. Rob French?

A. No.

Q. Robert Bowde?

MR. PETROCELLI: B-o-w-d-e.

THE WITNESS: The name is familiar.

MR. P. BAKER:

Q. Sammi?

A. No.

Q. Satomihamana?

A. No.

Q. Scott Jason?

MR. PETROCELLI: The answer is "no" to Satomihamana? S-a-t-o-m-i-h-a-m-a-n-a. The answer is "no," Kim?

THE WITNESS: The answer is "no."

MR. PETROCELLI: And Scott Jason.

THE WITNESS: No.

MR. P. BAKER:

Q. Sean O'Brien?

A. No.

Q. Sheri Hursey?

A. No.

MR. PETROCELLI: What is the question? Repeat it so we know what she's answering.

MR. P. BAKER:

Q. Do you recognize the name?

MR. PETROCELLI: Okay. That's been the question.

THE WITNESS: No.

MR. P. BAKER:

Q. Stewart?

MR. PETROCELLI: S-t-e-w-a-r-t.

THE WITNESS: I know a Stewart. I don't know if that's the Stewart.

MR. P. BAKER:

Q. And what's Stewart's last name?

A. Stewart Tanner.

Q. What does he do for a living?

A. Works at Mezzauna.

Q. As a waiter?

A. Yes.

Q. Susan Molina?

A. I don't think so.

Q. Tamila?

A. No.

Q. Thomas?

A. I know a Thomas after Ron's death.

Q. Thomas who?

A. Roe.

Q. R-o-e?

A. Correct.

Q. Where does he work?

A. I don't know.

Q. Do you know where he lives?

A. No.

Q. Do you know the relationship between Ron and Thomas Roe other than friends?

A. I think they worked together.

Q. Where?

A. Calfornia Pizza Kitchen.

Q. When did he work at California Pizza Kitchen?

A. '93.

Q. Which California Pizza Kitchen was that?

A. Brentwood.

Q. The one on San Vicente?

A. Yes.

Q. Tifany Star?

A. I heard of her after Ron's death.

Q. How did you hear of her?

A. Saw her on a talk show.

Q. What was she saying? Do you recall?

A. Just that she and Ron were friends, or something like that.

Q. That's all you recall about what the talk show was about?

A. Just they were friends of Ron on this talk show. I don't remember anything else.

Q. Todd Bank?

A. No.

Q. Tracy Lepera?

A. I know of her after Ron's death.

Q. What does she do?

A. I don't know that.

Q. When did you first meet Stewart Tanner?

A. At the criminal case.

Q. Did you have a conversation with him?

A. He gave me a hug and said he missed Ron.

Q. Had you ever met him prior to June 12th, 1994?

A. No.

Q. Did you know John DeBello prior to June 12th, 1994?

A. No.

Q. What do you recall about your conversation with Stewart Tanner other than what you've already testified to? A. He told me that he and Ron had plans to go out the night that he was killed.

Q. Did he tell you what those plans were?

A. Yes, but I don't remember.

Q. You don't remember what they were?

A. I don't remember.

Q. Do you recall if they had agreed to meet at Baja Cantina?

A. I don't if he told me that specifically.

Q. Were you ever questioned by any other detectives other than Carr and Tippins?

MR. PETROCELLI: Tippin, singular.

MR. P. BAKER:

Q. Tippin.

MR. PETROCELLI: Questioned about what, Mr. Baker?

MR. P. BAKER:

Q. About Ron or anything relating to his death on June 12, 1994.

MR. PETROCELLI: That's a very broad question. He's asking any policemen, any police detectives, any D.A. anybody ever question you about anything, other than Tippin and What's his partner's name?

THE WITNESS: Carr.

MR. PETROCELLI: Carr?

MR. P. BAKER: Carr.

THE WITNESS: Yes. One time.

MR. P. BAKER:

Q. Who was that?

A. One I testified. I don't remember.

MR. PETROCELLI: One second.

(Witness and her counsel confer off the record.)

THE WITNESS: Could you ask me again, please.

MR. P. BAKER:

Q. Who was that that you spoke to prior to the time you testified?

A. Periodically, it was the Detective Lange and Vannatter; And Marcia, I'm sure.

Q. Anyone else?

A. And Bill Hodgman, I think.

Q. Anyone counsel you before you testified?

A. No.

Q. Bill Hodgman or Marcia, did they talk to you prior to the time that you were on the stand?

MR. PETROCELLI: Now, are we talking about questioning her generally about the case or now about testifying?

MR. P. BAKER:

Q. Testifying.

A. No. There was no reason to.

Q. No conversations prior to the time you testified regarding your testimony with Marcia and Bill Hodgeman?

A. I told them what I knew.

Q. So there was a conversation?

A. You said "counsel."

Q. When did this conversation take place?

A. The morning of.

Q. Did they tell you what they were going to ask you?

A. No. Oh, that's not true. They told me what they would ask me generally.

Q. They told you the topics they were going to cover?

A. Yes.

Q. And you told them what you knew about those topics?

A. Correct.

Q. And that conversation happened before you testified on the stand?

A. Correct.

Q. How long did this take place?

A. A few minutes.

Q. It only took a few minutes?

A. That's how long my testimony took, also.

Q. By "a few minutes," how much do you mean, 5,10?

A. 10 minutes probably.

Q. Where did this conversation take place?

A. In the D.A.'s office, district attorney's.

Q. Did Lange and Vannatter ever ask you any questions about Ron following June 12th, 1994, who his friends were, who he hung out with, what his job was?

A. Yes.

Q. When did that take place?

A. Periodically throughout the course of the criminal case.

Q. Did they come up and use you as a sounding board?

MR. PETROCELLI: That's different now. I'm confused. I thought you were asking questions to obtain information about Ron. Now you've switched to sounding board. I don't really know what that means in this context.

MR. P. BAKER:

Q. Do you not understand that?

A. I don't understand what that means.

Q. They asked you to confirm certain information during the criminal trial, true?

A. Not necessarily confirm. They would try to elicit information from me.

Q. Did they ever take any notes?

A. Not that I'm aware of.

Q. You don't recall ever them writing down anything when they asked you questions?

A. Not that I remember.

Q. And how many conversations occurred between you and either Lange or Vannatter after June 12th, 1994, during the criminal trial?

MR. PETROCELLI: About Ron's death?

MR. P. BAKER: Yes.

THE WITNESS: I don't know specifically.

MR. P. BAKER:

Q. Can you give me an estimate?

A. I saw them everyday for a year. I don't know specifically. Could have been one time a month. I don't know for sure.

Q. What did you say about "one time a month"; you said you saw them everyday?

A. Right.

MR. PETROCELLI: I'm confused by your answer.

THE WITNESS: They could have asked me a question once a month.

MR. PETROCELLI: Now I understand.

MR. P. BAKER:

Q. Did you ever have any social interaction with any of the officers, detectives, or attorneys regarding this case?

MR. PETROCELLI: What do you mean by "social interaction"?

MR. P. BAKER:

Q. Did you ever have dinner with any detective?

MR. PETROCELLI: Related or unrelated?

THE WITNESS: Since the case is over?

MR. P. BAKER: Either.

MR. PETROCELLI: Criminal case.

THE WITNESS: Yes

MR. P. BAKER:

Q. Who?

A. We had a party for the entire D.A.'s office.

Q. When did this party take place?

A. January 7th.

Q. Of this year?

A. Correct.

Q. Where was that party?

A. In Agoura.

Q. Where in Agoura?

A. La Pasta.

Q. La Pasta?

A. Yes.

MR. PETROCELLI: Another Italian name, Mr. Baker.

MR. P. BAKER:

Q. Who was there from the D.A.'s office?

A. Everybody. It would be easier for me to tell you who wasn't there. I don't know who was there.

Q. Tell me who was there.

A. Okay. First and last names?

Q. Please.

A. Marcia Clark; Chris Darden; Bill Hodgman; Cheri Lewis; Lisa Cone; Woody Clarke; Hank Goldberg; Scott Gordon; Phil Vannatter; Tom Lange; Ron Phillips. You want me to list all the law clerks, too?

Q. Please, if you know them.

A. Lisa Fox; Suzanne Dozier; Matt Gibbs; Michael Price; Kathy I don't know her last name. Patty Jo Fairbanks; Gary Shram; Wil Abrams; Dana Thompson; Mike Stevens; George Mueller; Brian Hale; Jack Gonterman; Steve Oppler; Pat McPhearson; Ken Godinez. Husbands and wives were also included, and I could be missing a few people. I think that's pretty good.

MR. VAN SICKLEN: Not bad.

MR. P. BAKER:

Q. Who paid for the party?

A. We did.

Q. Your family did?

A. Our family.

Q. How big was the party, how many people?

A. Roughly 70, including our family.

Q. Whose idea was it to have this party?

A. The family's.

Q. What does your father do for a living?

A. He designs and sells displays.

Q. What type of displays?

A. Point-of-purchase sale.

Q. I don't understand that. What is that?

A. The displays you bump into in the grocery store. He does designs designs displays for products.

Q. Were there any contributors to this party? Anyone else help pay for it?

A. No.

Q. Do you know how your lawsuit is being financed presently?

MR. PETROCELLI: I instruct her not to answer, Mr. Baker. This is irrelevant, and you know it is. I'm giving you some leeway just to speed the process up.

MR. P. BAKER: Would you mark that one, please.

THE REPORTER Yes.

MR. PETROCELLI: We didn't ask your client how his lawsuit is being financed.

MR. P. BAKER: Is Kim Goldman your client?

MR. PETROCELLI: Yes.

MR. P. BAKER: In this lawsuit?

MR. PETROCELLI: She's my client, Mr. Baker.

MR. P. BAKER:

Q. Did you clean out Ron's apartment?

A. Yes.

Q. Who did you do that with?

A. My dad; Patti; And Lauren.

Q. When did that take place?

A. Before the end of June. I don't remember specifically.

Q. Had any other detectives been to Ron's apartment prior to Tippin and Carr prior to the time you cleaned it out, to your knowledge?

A. Not to my knowledge.

Q. When Tippin and Carr were at the apartment for about an hour, did they go through all Ron's drawers and closets?

A. I don't know for sure.

Q. How many rooms was that apartment?

A. One bedroom with a family room and a kitchen area and a bathroom and a dining area off the kitchen.

Q. And they went through each room, Tippin and Carr, that is, when they were at the property on June 14th?

A. Correct.

Q. Did you ever turn over what you found in Ron's apartment to the police?

MR. PETROCELLI: What do you mean, what she found?

MR. P. BAKER:

Q. When you cleaned out his apartment, did they ever ask you for anything to turn over to them following the time that you cleaned it out?

A. Not me personally.

Q. Who turned something over that you know of?

A. I think my dad and Patti.

Q. What was it?

A. A hat and a blanket or a sweatshirt or something.

Q. What type of hat was it?

A. I believe it was his Tampa Bay Buccaneer hat .

Q. Do you know why they were asking for that hat?

A. Hair samples.

Q. Do you know why they asked for a blanket or a sweatshirt?

A. I would assume to take hair samples off of it.

MR. PETROCELLI: Kim, please don't assume anything. You would only know that if they told you why they wanted it or someone else told you. Did they tell you that?

THE WITNESS: They told me they needed the materials for hair samples.

MR. PETROCELLI: That's fine.

MR. P. BAKER:

Q. Do you remember where Ron's work clothes were when you were in his apartment on June 12th, 1994?

A. Yes.

Q. Which room?

A. They were hanging over the door.

Q. Of his bedroom?

A. I believe so.

Q. Can you describe those clothes to me?

A. A white dress shirt and black slacks.

Q. Black slacks were hanging over the door as well?

A. I believe so.

Q. Did you see his shoes he'd been wearing on the night of June 12th from work?

A. No.

Q. Did you go into his bathroom on June 14th, 1994?

A. I don't remember.

Q. Do you know if it looked like he had showered that night of June 12th?

A. I don't know if I went into the bathroom.

Q. So you have no idea of whether or not he showered on the night of June 12th?

A. Right.

Q. Do you recall seeing any shaving equipment? Does that jog your memory of whether you were in his bathroom on June 12th, 1994?

A. No.

Q. No, you don't recall?

A. Right.

Q. What parts of his apartment did you help clean out at the latter part of June?

A. Everything.

Q. Tell me what you cleaned out of his family room.

A. I packed up his TV and VCR and whatever might have been on the table at that point.

Q. Do you recall what was on the table?

A. I think just magazines.

Q. Do you know which magazines?

A. No.

Q. Did you see any videos?

A. Yes.

Q. What videos?

A. He had a Dick Tracy movie; The movie Total Recall; Movie Bad Influence.

Q. Any other tapes?

A. I think some blank household tapes.

Q. Did you ever put those in the VCR to see what was on them?

A. No.

Q. Do you still have them?

A. Probably, yes.

Q. And you've never looked at them, the blank videos?

A. They may have been marked. So if they were marked, I wouldn't have watched them.

Q. You don't recall if they were marked or not?

A. I believe that they were.

Q. Do you know if anyone in your family has watched the blank videos?

A. No.

MR. PETROCELLI: Ask her what you mean by "blank."

MR. P. BAKER:

Q. The untitled.

A. When I meant "blank," I meant compared to the movies that said Total Recall.

Q. The videos purchased.

A. Right.

Q. Do you know where they are presently?

A. Probably with all of our other videos.

Q. What else do you remember that was cleaned out of his family room?

A. All of his softball and tennis gear.

Q. Where was that located?

A. In the family room.

Q. In the closet or was it just lying on the floor?

A. When you walk in the front door there's an area right there. It was just like he just dropped it when he came in.

Q. Anything else from the family room that you recall?

A. No.

Q. Did the police ever ask for anything, to your knowledge, other than his hat and perhaps his blanket or sweatshirt?

A. No.

Q. Did he have a diary?

A. No.

Q. Did he have a journal?

A. No, not that I'm aware of.

Q. Did you ever see anything that he had written when you cleaned out his apartment notes, screenplays, books, poems anything that he had written at all when you cleaned out his apartment in the latter part of June?

A. Not at that time.

MR. PETROCELLI: One second.

(Witness and her counsel confer off the record.)

MR. PETROCELLI: I think you ought to make that clear.

THE WITNESS: At the time we packed, we didn't we just put it in. We didn't want to have to be at the house that long.

MR. P. BAKER:

Q. Did you unpack it when you returned to Agoura Hills?

A. About a year later.

Q. Did you find anything that he had written?

A. Yes.

Q. What did you find?

A. All his ideas for his restaurant that he wanted to open and a diagram of that restaurant he drew.

Q. How many pages was that?

A. 4 or 5 possibly.

Q. Do you still have that?

A. Yes.

Q. Where is that located?

A. At my house.

Q. And was it a formal architectural design or just his sketch?

A. It was my brother's version of a formal architectural design, which was very good, by the way.

Q. Did he have any monetary amounts listed on these pages?

A. No.

Q. Did he have any names on these pages?

MR. PETROCELLI: By "on these pages," you mean the sketched pages?

MR. P. BAKER:

Q. All documents regarding the restaurant that you found, were there any names on those pages?

A. I only remember one specifically.

Q. What was that?

A. Of a woman that was going to make pastries for him.

Q. Do you remember the name?

A. No.

Q. Did you see any monetary figures?

A. No.

Q. Did you see any list of donors?

MR. PETROCELLI: I assume you mean investors.

MR. P. BAKER: Correct.

THE WITNESS: I don't remember.

MR. P. BAKER:

Q. When was the last time you looked at this?

A. A few weeks ago, a week ago.

Q. A week ago?

A. Yes.

Q. Why did you look at it?

A. Because every once in a while, I go through my brother's things, and I always look at his what he did.

Q. Is this on a legal pad or a binder, or was it just loose-leaf papers?

A. On a blue piece of paper.

Q. All the documents that you found regarding the restaurant?

A. Oh, I thought you meant the actual picture.

Q. I apologize. All the documents you found regarding the restaurant.

A. Random pieces.

Q. Random pieces. Where was it found in his apartment, which room?

A. I don't remember.

Q. Did it say where he wanted this restaurant to be located?

A. Did what say?

Q. The papers.

A. No. Q. Do you remember anything else about this set of papers other than the sketch and this name of the pastry lady?

A. He proposed a menu, and he just wrote down all of the things he wanted to have in this restaurant, local artists, poetry readings, bands.

Q. Had a list of local artists?

A. No.

Q. Just said "local artists"?

A. Uh-huh, correct.

Q. Didn't have any documentation regarding financial support on these papers, did it?

A. No, not that I remember.

Q. Do you know how much he earned as a waiter from Mezzaluna?

A. Minimum wage, plus tips.

Q. Do you know how much he earned from tips?

A. No.

Q. How long did he work at Mezzaluna?.

A. I think like 4 or 5 months.

Q. By the way, regarding this restaurant, had you ever heard about his idea, his concept, about this restaurant prior to the time you saw the papers?

A. Yes.

Q. When did you hear about it?

A. My brother and I had numerous conversations about it.

Q. Did he ever tell you he was going to apply for a bank loan?

A. No.

Q. What do you recall him telling you about the restaurant?

A. Just that he wanted to do it; And he explained to me all of his ideas and opinions of how it would work; And that he knew some people that were interested in helping him.

Q. Did he mention names of those people?

A. I think so, but I don't remember who it was.

MR. PETROCELLI: One second.

MR. P. BAKER: Did he ever tell you

MR. PETROCELLI: One second. (Witness and her counsel confer off the record.)

MR. P. BAKER:

Q. Do you know if he was supporting anyone financially, Ron?

A. No, I don't know.

Q. Do you know if he was providing any money to Sharon Rufo?

A. No, I don't know.

Q. Do you know if she was providing any money to him?

A. No, she wasn't.

Q. Do you know how much he had in his savings account on June 12th, 1994?

A. I don't believe he had a savings account.

Q. How about a checking account? Do you know how much he had in his checking account in June of 1994?

A. A couple hundred dollars.

Q. Did he own any stocks or bonds?

A. No.

Q. Did he have any other investments that you know of?

A. No.

Q. What type of car did he have?

A. He didn't .

Q. How did he get around? Do you know?

A. He walked.

Q. Prior to June 12th, 1994, can you tell me, to the best of your recollection, the last 5 jobs he had starting with Mezzaluna?

A. He worked at California Pizza Kitchen.

Q. How long did he work there?

A. A little over a year.

Q. As a waiter?

A. Yes.

Q. Before that?

A. I don't know if I'm going to have them in order.

Q. To the best of your recollection.

A. He worked at the cerebral palsy hospital/home.

Q. What did he do there?

A. He worked with the mentally retarded patients, helping them get ready in the morning and eat and showered them and did recreational activities with them.

Q. Where was that located?

A. Thousand Oaks.

Q. Do you know the name?

A. United Cerebral Palsy.

Q. Before that?

A. He worked at Taylor & Bryce as a recruiter.

Q. What type of business is Taylor & Bryce?

A. I think it's a recruiting firm.

Q. Recruitment for what type of jobs?

A. I think all types. I'm not sure specifically.

Q. Do you know what he did there?

A. He was a recruiter.

Q. Do you know what the nature of that work was?

A. Recruiting.

Q. Make phone calls or interview people?

A. Correct.

Q. How long did he work there?

A. I don't know specifically.

Q. Before that?

A. He worked at Pierview. I might have these backwards. Pierview restaurant.

Q. What is that?

A. A restaurant in Malibu.

Q. He worked as a waiter?

A. Correct.

Q. How long did he work there?

A. I don't know for sure.

Q. Do you remember any other jobs?

A. He worked as a tennis coach at Oak Park High School.

Q. Anything else?

A. His private tennis lessons.

(Witness and her counsel confer off the record.)

THE WITNESS: Thousand Oaks Park and Rec, he was a counselor.

MR. PETROCELLI: Did you say that?

THE WITNESS: Earlier I did. Thousand Oak Park and Recreation. He was a counselor for kids.

(Witness and her counsel confer off the record.)

MR. P. BAKER:

Q. Do you know how much money was collected for his restaurant project, if any?

A. I don't believe that there was.

Q. Was Ron ever arrested? Do you know?

A. Yes.

Q. When was he arrested?

A. One time in '89, I think.

Q. Was that for credit card fraud?

A. No.

Q. What was that for?

A. Traffic

MR. PETROCELLI: Don't ask questions like that unless you have a foundation or basis for it.

MR. P. BAKER: I can ask questions the way I like.

MR. PETROCELLI: I think it's highly inappropriate. I want you to understand, in asking that question, he just picked something out of the thin blue air to sound prejudicial in this regard. Don't assume there's any basis for anything he's saying. Okay?

You may answer.

THE WITNESS: Traffic violations.

MR. P. BAKER:

Q. What type of traffic violations?

A. I don't know specifically.

Q. Was he incarcerated?

A. Yes.

Q. For how long?

A. However long it took my dad to go and bail him out.

Q. Was there a trial?

A. No.

Q. Did he plea, that you know of?

A. I don't remember.

Q. You don't know the nature of the violations? Were they tickets, speeding?

A. I believe they were in regards to speeding tickets, but I don't know specifically.

Q. And do you know the resolution at all of that arrest?

A. No, I don't know.

Q. Where was he arrested?

A. I think he was in Hollywood when he was arrested.

Q. Do you know of any other arrests other than this arrest in 1989 for traffic violations?

A. Yes.

Q. What are the other ones?

A. In 1992.

Q. For?

A. Traffic Parking citations or something.

Q. Was he in his own car when he was arrested in 1992?

MR. PETROCELLI: Don't speculate, Kim.

THE WITNESS: No, he wasn't.

MR. P. BAKER:

Q. Whose car was he in?

A. I think his friend's name is Blaine.

Q. B-l-a-i-n-e?

A. Yes.

Q. Do you know the last name?

A. No.

Q. And Blaine was driving, to your knowledge?

A. Blaine was not in the car.

Q. Ron was driving Blaine's car?

A. Correct.

Q. Do you know why he was pulled over?

A. No, I don't.

Q. Do you know if Blaine authorized Ron to use his car?

A. Yes, he did.

Q. Where was he arrested in 1992?

A. I don't remember.

Q. Do you know if he was incarcerated?

A. Yes, he was.

Q. Do you know the resolution of that incarceration?

MR. PETROCELLI: Excuse me one second.

(Witness and her counsel confer off the record.)

MR. PETROCELLI: You may answer.

THE WITNESS: The resolution; is that what you said?

MR. P. BAKER

Q. How long was he incarcerated?

A. 4 or 5 days for time served, because he didn't want anybody to bail him out.

Q. And he was released for time served?

A. Right.

Q. And he never went to trial regarding this incident?

A. Right.

Q. Did he have a driver's license in 1992?

A. I don't know for sure.

Q. Do you know if he had one in 1994?

A. He had an identification card.

Q. That wasn't my question. Did he have a driver's license? Do you know if he had one in 1994?

A. He had an identification card, which is not a driver's license.

Q. Is the answer, no, he did not have a driver's 1icense in 1994? l

A. Correct. Sorry.

Q. Do you know if the reason he didn't have a driver's license in 1994 is because he was suspended?

A. I believe that's the reason.

Q. Do you know why he was suspended?

A. No, I don't.

Q. Any other arrests that you know of?

A. No.

MR. P. BAKER: Do you want to take a lunch break?

MR. PETROCELLI: Sure.

(A lunch recess is taken.)

MR. P. BAKER: It's about 1:15.

Q. Do you know if your brother had a modeling agent?

A. Not that I know of.

Q. Do you know if he did any modeling for hire?

MR. PETROCELLI: You mean where he got paid?

MR. P. BAKER: Yes.

THE WITNESS: Not paid.

MR. P. BAKER: Q. You don't know of any modeling he did in which he was compensated?

A. He was compensated with clothes.

Q. Do you know who he did that for?

A. Barry Zeldes, I believe, Z-e-l-d-e-s.

Q. Where is that located?

A. Brentwood Gardens, I think, where California Pizza Kitchen is. There is a store there.

Q. Do you know how often he did this modeling?

A. I only know of that one.

Q. That one picture?

A. That one time pictures were printed.

Q. We were talking earlier about when you were cleaning out Ron's apartment at the end of June.

A. Correct.

Q. Do you know if he ever had a private video camera?

A. Not that I know of.

Q. All the videotapes we spoke about earlier, that's your normal VHS-size tape you found in his apartment, correct?

A. Correct.

Q. You didn't find any of those tapes that were personal in VCR machines, did you?

A. No.

Q. What else did you clean out of his family room, if you recall, other than his sports equipment, TV equipment, VCR, and magazines?

A. That was it.

Q. Any photos?

A. Not that I remember.

Q. What photos do you recall were in his apartment that you cleaned out?

A. Photos of Jacqui and him.

Q. How many of those were there?

A. Like a roll, whatever an average roll would be, 20.

Q. Were there any framed photos?

A. Not that I remember.

Q. All the boxes that you cleared out from his apartment, are those still presently intact; in other words, do you have anything that you cleared out of his apartment in late June of 1994 still present

A. No.

Q. Agoura Hills?

A. No.

Q. What has been removed from those boxes?

A. Some of his clothes and some pots and pans that were no longer usable.

Q. Which clothes were removed from the boxes in Agoura Hills?

A. Almost everything everybody went through and took what things reminded them of Ron, and the rest was donated.

Q. Who took his work clothes from the night of June 12th, 1994?

A. I did.

Q. Do you still have those?

A. No.

Q. What did you do with those?

A. I gave them to Marcia Clark.

Q. Did she ask you for them?

A. Yes.

Q. When did she ask you for those clothes?

A. I believe in February. I don't remember when I testified.

Q. It was in anticipation of your testimony that she requested the clothes?

MR. BREWER: Object as calling for speculation.

MR. P. BAKER:

Q. If you know.

A. I think I'm confused. Say that again.

Q. Did she ask you for his clothes immediately before the time in which you were going to testify, a couple days before?

A. They sort of happened at the same time. The issue of the clothes came up. I had them.

Q. You testified that you had them, so I don't know if one preceded the other. I was a little bit unclear, and my questioning was vague.

How did you find his clothes on the bedroom door? Were they on hangers, hanging over the top?

A. They were thrown over the door.

Q. Were they folded, or were they just thrown loosely over the door?

A. Thrown over the door.

Q. Was there a belt in the black slacks?

A. Not that I remember.

Q. It was just his shirt and pants, correct?

A. Correct.

Q. Did you ever see his socks or shoes?

A. Not that I remember.

Q. Did you help clean out his bedroom?

A. Yes.

Q. What do you recall cleaning out from his bedroom?

A. His closet and the headboard and the drawers, the backboard of his bed.

Q. His dresser, did you clear out his dresser?

A. He didn't have a dresser.

Q. Tell me everything you recall taking from his closet.

A. Clothes and shoes, hats, hangers.

Q. Anything else?

A. Not that I remember.

Q. There have been reports there were certain drug paraphernalia found in his apartment. Did you ever see anything along those lines?

A. Absolutely not.

Q. Nowhere in his apartment?

A. Absolutely not.

Q. What else do you recall? Do you recall any jewelry or pagers or anything found in his bedroom?

A. No.

Q. There were drawers in his headboard; is that what you said earlier?

A. Correct?

Q. What did you clean out of his headboard, those drawers?

A. Just loose paper, like receipts or phone numbers or business cards, just loose paper.

Q. And you kept all those things, true?

A. Yes.

Q. Are those still in the boxes in Agoura Hills, if you know? A. Not everything.

Q. What has been removed from those boxes, if you know, in Agoura Hills?

A. Scrap pieces of paper, phone numbers, or whatever.

Q. Were those discarded or turned over?

A. Discarded.

Q. Who decided to throw them away?

A. My dad and I.

Q. Do you remember anything about the papers that you threw away?

A. Nothing more than I just told you.

Q. Do you recall any names, any specific numbers?

A. No.

Q. Did you find any money around the apartment?

A. Yes.

Q. How much?

A. Roughly $60.

Q. Where did you find that?

A. My dad found it on the table and showed it to me.

Q. Which table?

A. Not a table. It's a In the hallway between the bathroom and the bedroom, there's like a (indicating) in the wall, shelving unit with a little counter. I don't know how to explain it.

Q. Was it in a wallet?

A. I don't My dad found it first.

Q. Do you know if anything else was found in that little hallway?

A. His checkbook. And his What do you call it? The thing that he writes on for work, the little where he kept his checks for work and the menu for work. I don't know what it's called. It's a leather folder, a little miniature leather folder. I don't know what it's called. And just bills, current bills, that he owed and what not, like a little working area.

Q. Did you keep all that, if you know?

A. Yes.

Q. His leather folder, I'll refer to it as that, is that still in the boxes in Agoura Hills?

A. Yes.

Q. Did you ever look through the leather folder?

A. Yes.

Q. What did you find in the folder?

A. The specials from the restaurant from that evening, and a napkin and a coaster, or something like that.

Q. Was there anything written on the napkin or coaster?

A. No.

Q. If you want to take a break at any time, just tell me.

A. I will.

Q. Anything else you recall finding in the bedroom?

A. Not that I remember.

Q. Did you see any books in his bedroom?

A. No.

Q. Did you see any books anywhere in his apartment? Why don't we take 5 minutes. Do you want to take a break?

A. No. I'm fine. Thank you.

Q. Okay.

A. Not that I remember.

Q. Anything else you recall in his bedroom?

A. Just the phone and the answering machine, but, no.

Q. Were there any messages on his answering machine?

A. I don't think that there was a tape in the answering machine.

Q. Did you see Detectives Tipkin

MR. PETROCELLI: Tippin.

MR. P. BAKER:

Q. Tippin or Carr take the tape out of the answering machine?

A. They may have. I don't know, specifically.

Q. As you sit here today, you don't recall if there was a tape or not in the answering machine?

MR. PETROCELLI: As of what time?

MR. P. BAKER:

Q. At any time following June 12th, 1994.

A. I'm stating strictly from when we cleaned out the apartment.

MR. PETROCELLI: End of June.

THE WITNESS: Not that I remember.

MR. P. BAKER:

Q. How about June 14th when you were at the apartment, did you listen to his messages? A. I don't believe so.

Q. Did you ever walk over there and see if the light was blinking or see if it was even on?

A. I don't believe I did.

Q. The answering machine, was that placed in the box?

A. Yes.

Q. Do you know if that answering machine is still in the box in Agoura Hills?

A. Yes.

Q. Have you ever specifically looked at the answering machine, if you recall, at any point to see if there was a tape in that machine?

A. I don't think I looked specifically for a tape, no.

Q. And the police never asked you if you knew if there was a tape in that answering machine, true?

A. No. They probably asked me. I don't remember if they took the tape.

Q. Do you recall them asking you that?

A. Not specifically.

Q. You don't recall it?

A. Correct.

Q. Anything else you remember in the bedroom?

A. No.

Q. Was there anything other than clothing or hats in this closet? Shoes. Anything other than that?

A. No, not that I remember.

Q. Any boxes in the closet?

A. Not that I remember.

Q. You cleaned out the kind of a dinette area?

A. Right.

Q. You cleaned that out as well, true?

A. There was nothing there except laundry.

Q. Laundry in a basket or a bag?

A. Correct, basket.

Q. And that laundry was all boxed up as well?

A. No. We put that in a bag.

Q. And took that to Agoura Hills?

A. Yes.

Q. How long did Ron live in that apartment? Do you know?

A. About a year. Could have been a few months more.

Q. Had you ever visited that apartment?

A. Yes.

Q. How many times had you visited it?

A. Maybe 8 to 10 times.

Q. Ever attend a party there?

A. No. Didn't have parties there.

Q. He never had a party there, to your knowledge?

A. Not to my knowledge.

Q. Did you ever stay over there?

A. No. Q. When was the last time you were over there prior to his death?

A. I may have gone in April, but for sure in November and December of '93.

Q. Who did you go over there with?

A. Me.

Q. Was anyone else there?

A. Jacqui.

Q. Jacqui and him broke up in the end of '93; is that true?

A. I believe so. I don't know specific dates.

Q. And then he began to date Andrea Scott?

A. In April or May.

Q. And they were still dating until his death in June

A. Yes.

Q. as far as you know?

A. Yes.

Q. But you found a picture of Jacqui in his apartment on June 14th of 1994?

A. Yes. They were in a folding envelope.

Q. Where was this envelope found?

A. In the drawer.

Q. Which drawer?

A. In that hallway thing. There's like a little desk there.

Q. Were there a series of photos?

A. Yes.

Q. Were those ever turned over to the detective?

A. No.

Q. Are those still in the boxes in Agoura Hills?

A. Yes.

Q. Do you remember any other photos in that series?

A. There was a picture of my dad and my brother and Michael and Lauren from father's day. And I believe there was a picture of my brother and I from my high school graduation.

MR. PETROCELLI: '94?

THE WITNESS: '94 Father's Day, no. '93 Father's Day, I think.

MR. P. BAKER:

Q. Any other photos that you recall?

A. No.

Q Were these photos from one roll of film or kind f his own photo album?

A. From different rolls of film.

Q. The pictures that the 2 detectives took, where did they get those pictures, if you know?

A. I don't know.

Q. Were they in frames?

A. No.

Q. When you walked in with the detectives on June 14th, you were all together, correct?

A. Correct.

Q. Who opened up the door?

A. I believe my dad did.

Q. Is there anything else other than those photos and the leather folder that was found in that little hallway desk area and bills?

A. That's where we found all of his stuff for the restaurant, architectural paperwork, and all that.

Q. Anything else?

A. Not that I remember.

Q. On the 8 times that you visited his apartment, who else was there, if you recall?

A. Jacqui was there a few times. And the other times, I think I was by myself.

Q. Anybody else? Were there any male friends of his or any other girlfriends of his for the 8 times you were there?

A. Not that I remember.

Q. And these 8 times were in the year or so that he lived there?

A. Correct.

Q. Can you tell me what was cleaned out of his kitchen?

A. His refrigerator; Freezer; And all the cabinets and drawers; And the countertop; And the utility closet.

Q. What was in the utility closet?

A. A broom; And a mop; And cleaning cleaning utensils; And the garbage can; And rags.

Q. And was everything cleaned out of the kitchen solely kitchen supplies?

A. Correct.

Q. Was there a telephone in the kitchen?

A. No

Q. Were there any notes or pieces of paper in the kitchen?

A. Just his workout schedule; And his diet, so to speak, how many proteins and carbohydrates and stuff he should be getting.

Q. What clubs did he belong to?

A. The Gym in Brentwood.

Q. Which is called The Gym?

A. Yes. That's all I know for sure.

Q. Do you know if he had any credit cards?

A. No, he didn't.

Q. Was there a phone also in the family room?

A. There might have been a jack. There wasn't a phone in there.

Q. Were there any pieces of paper or notepad in the family room?

A. No.

Q. The only thing you remember are magazines on the table?

A. Correct.

Q. All the boxes, where are they located in Agoura hills, what part of your home?

A. The garage.

Q. Is there anything that is missing that you know of from those boxes other than the clothes you gave Marcia Clark, the other clothes that were disbursed to family members, or the scrap pieces of paper which were thrown away?

A. Some of the kitchen utensils.

Q. Anything other than that?

A. Some of his shoes; And the bedding; And some of the toiletries in the bathroom and such, but

Q. Those were simply discarded, shoes, toiletries, and bedding?

A. They were donated to Cerebral Palsy, I believe.

Q. When did Ron go to school?

A. When?

Q. From high school onward.

A. He went to Illinois State University when he graduated; And he went to Pierce Community College; And he went to EMT school.

Q. Where did he go to high school?

A. Stevenson High School.

MR. PETROCELLI: Can I hear her answer back.

(The record is read by the reporter.)

MR. PETROCELLI: When you said "he graduated," you meant after he graduated high school?

THE WITNESS: After he graduated high school, he went to Illinois State.

MR. P. BAKER: Okay.

THE WITNESS: And then to Pierce; And he also went to EMT school.

MR. P. BAKER:

Q. Did he graduate from Pierce Community College?

A. No.

Q. What was he studying at Illinois State and Pierce Community?

A. Business.

Q. Where is Stevenson High School? Is that in Agoura?

A. Prairie View, Illinois.

Q. The statement you said you made to the press

MR. PETROCELLI: What statement?

MR. P. BAKER: The statement she made to the press.

MR. PETROCELLI: What statement?

MR. P. BAKER:

Q. On June 15th, 1994, the report reads that you stated "Because we grew up with a lot of upheaval, he wanted some stability." Do you recall that comment?

A. Yes.

Q. Do you recall making that comment?

A. Yes.

Q. What did you mean by that?

A. Because my dad and Sharon were divorced, and my dad was the one who raised us, and that's what I meant by "upheaval."

Q. When were your dad and Sharon divorced?

A. 1974.

Q. And your dad basically raised you two?

A. Sorry.

MR. PETROCELLI: Let's get a clean record. "And your dad basically raised you two?" Your answer?

THE WITNESS: My dad raised Ron and I, yes.

MR. P. BAKER:

Q. When did your father marry Patti Goldman who is now Patti Goldman?

A. 1987.

Q. How old were you at the time of the divorce?

A. A little over 3 years.

Q. When you were referring to "upheaval" in that comment, you were basically talking about the divorce when a you were 3 years old?

A. Correct.

Q. The statement you made on June 15th, 1994, you said, "My brother basically raised me. It was a hard time for us and for my father and he took care of me." Do you remember making that statement?

MR. PETROCELLI: Let's see that.

MR. P. BAKER: (Indicating.)

MR. PETROCELLI: Let the record reflect you're reading these quotes, which may or may not be accurate, from some document that your office has prepared.

MR. P. BAKER: It's on the front L.A. Times article.

THE WITNESS: Okay.

MR. P. BAKER:

Q. Do you recall making that comment?

A. Yes.

Q. Is it your testimony that your father raised you or your brother raised you?

MR. PETROCELLI: They're not a mutually exclusive. Your answer?

THE WITNESS: Both. What I meant by "basically," my brother was at home with me until my dad was working until dinner time, when we were all home together.

MR. P. BAKER:

Q. Did Ron ever have a roommate?

A. At what time?

Q. Well, in the past 5 years?

A. Yes.

Q. Who was that?

A. Jacqui Bell.

Q. How long did they live together?

A. A little over a year.

Q. Was that at the Gorham apartment?

A. Yes.

Q. Where did he live before that?

A. Home in Agoura.

Q. Did he live anywhere but the Gorham apartment and the home in Agoura?

A. Prior to that he lived in Canoga Park. And prior to that he was home. And then prior to that he was in Calabasas. And prior to that he was home.

Q. Do you remember his address in Canoga Park or in Calabasas?

A. No.

Q. Do you know the street?

A. Calabasas was Malibu Canyon. And Canoga Park was Keswick, K-e-s-w-i-c-k.

Q. Did he live with Jacqui only in the Gorham apartment?

A. Yes.

Q. And they lived together for a little over a year?

A. Correct.

Q. Were they ever engaged?

A. No.

Q. When they broke up, were they living together?

A. I think she was there until she found a place to live.

Q. Do you know where she moved to?

A. No.

Q. Did you find any calendars of Ron's around his apartment?

A. Not that I remember.

Q. Have you ever seen a calendar of Ron's?

A. Ever? Yes.

Q. When was that?

A. Gosh, probably back in '87, '88 when we first moved here.

Q. That was from Illinois?

A. I don't know where it was from. Wait. Where did we move here from?

A. Yes. Sorry.

A. From Illinois.

Q. You never saw a calendar from 1994, did you?

A. No.

Q. Did you ever find an address book other than the electronic address book of Ron's?

A. No.

Q. Did he leave an address book around the Agoura Hills home?

A. At one point he had a day-to-day datebook with a space for addresses, but that was years earlier.

Q. I didn't hear the end.

A. That was years earlier.

Q. Do you know where that is now?

A. I'm sure he threw it away. I don't know where it is.

Q. Did he ever express any concern to you whatsoever for his safety?

A. No.

Q. When you first learned of his death, did you have any thoughts about or any suspicions about who may be involved?

A. No, absolutely not.

Q. You never told anyone that you had any suspicions of who may be involved in his death; is that true?

A. True.

Q. How long was his license suspended? Do you know?

A. I don't know.

Q. You've heard stories that he was driving Nicole's car in 1994, true? You've heard those stories?

A. Have I heard the stories? Yes.

Q. Do you know if his license was suspended 6 months prior to his death in 1994?

A. I don't know.

Q. You had a number of conversations with Phil Vannatter and Tom Lange during the criminal trial?

A. True.

Q. Did they ever express any concern to you whatsoever about Mark Fuhrman?

A. No.

Q. Did they ever talk about the fact that it had been gleaned he had made racist statements before? Did they ever talk to you about that?

A. No.

Q. You never had a discussion once with them about anything? Did you ever discuss Mark Fuhrman with Mr. Vannatter or Mr. Lange?

A. My disapproval of what he did, yes.

Q. When did that conversation occur?

A. After that whole issue erupted.

MR. PETROCELLI. Hold on.

(Witness and her counsel confer off the record.)

MR. PETROCELLI: I'd like you to clarify your answer.

THE WITNESS: The racial comments that were made is what we talked about, my disapproval of him.

MR. P. BAKER: :

Q. When did that conversation occur?

A. At whatever point it came out that he guess the tapes, maybe when the whole issue of the tapes came about.

Q. Where did that conversation occur? Do you know?

A. I don't remember.

Q. Did you ever distrust any of the prosecutions witnesses during the criminal trial?

A. What?

Q. Distrust.

MR. PETROCELLI: I instruct her not to answer. Her opinion of the witnesses is totally irrelevant. I'm giving you lots of leeway. A lot of these questions are absolutely irrelevant, but I just want to get through this.

MR. P. BAKER:

Q. You attended a party for Phil Vannatter recently, did you?

A. Yes.

MR. PETROCELLI: With 500 other people.

MR. P. BAKER:

Q. Who invited you to that party?

A. Partly Jo Fairbanks and Tom Lange.

Q. Are you still in contact with Tom Lange?

A. Yes.

Q. When is the last time you spoke with him?

A. The night of Phil's dinner.

Q. Where was that dinner?

A. At the Police Academy.

Q. Were you guest of honor at that dinner?

A. No.

Q. Did you guys sit at a front table?

A. No.

Q. Did you have to pay any money to attend that party?

A. Yes.

Q. How much did you pay?

A. $25 per person.

Q. By the way, the party you had in January for the district attorney's office, how much did that cost, if you know?

MR. PETROCELLI: Instruct you not to answer.

MR. P. BAKER: Will you mark that, please.

THE REPORTER Yes.

MR. P. BAKER:

Q. Do you know where Phil Vannatter presently lives?

A. Not off the top of my head.

Q. Do you know which city?

A. No.

Q. Have you ever been to his house?

A. No.

Q. Have you ever been to Tom Lange's house?

A. No.

Q. Other than the clothes you gave Marcia Clark, did you ever give the police or prosecution any documents regarding Ron Goldman?

A. Not that I remember.

Q. Any photographs?

A. Yeah. I gave them the picture of my brother.

Q. Which picture was that?

A. Picture that was taken at my little sister's bat mitzvah.

Q. Did they ask you for that picture?

A. They asked me for pictures of him.

Q. Is that prior to your testimony?

A. I don't remember.

Q. Did I ask you this: Which person asked you for those pictures?

MR. PETROCELLI: What pictures?

MR. P. BAKER:

Q. The picture of Ron.

A. Who specifically asked me, I don't remember.

Q. Did they ever ask you to give a formal statement?

A. No.

Q. Did you keep a diary during the trial?

A. Sort of.

Q. You wrote down your thoughts?

A. Occasionally, yes.

Q. Where is that diary presently?

A. In my room.

Q. Has anyone ever offered you book deals regarding this case?

A. No.

Q. Any movie deals?

A. No.

Q. Has anybody offered you any financial compensation for interviews or anything, any financial compensation at all, regarding this case?

A. For interviews?

Q. Yes.

A. No. There's been The public has donated money to our family. Q. As an outside interest, has anyone ever offered you financial compensation as a result of this lawsuit or as a result of the criminal case?

A. Yes.

Q. Who?

A. The public.

MR. PETROCELLI: He means for services rendered.

THE WITNESS: No, then. Sorry.

MR. PETROCELLI: Like are you currently marketing an infomercial?

THE WITNESS: No. I'm sorry.

MR. P. BAKER:

Q. You are not writing a book, are you?

A. No.

Q. And I'll refer to it as a diary or journal, whichever you'd prefer. When did that journal start?

A. First day of opening arguments.

Q. Are you still writing in the journal?

A. Occasionally, yes.

(Witness and her counsel confer off the record.)

MR. P. BAKER:

Q. Other than the 2 people you mentioned as Ron's best friends, can you think of anyone who was a close friend of his?

A. Lauren Cohen.

Q. Anyone else?

A. Yeah, but I'm sort of drawing a blank.

Q. Did you ever go out with Lauren Cohen?

A. No. Just Ron brought her to my little sister's bat mitzvah.

Q. Were they dating?

A. We wished they were.

Q. Did you ever go to Mezzaluna?

A. Not before Ron's death.

Q. Why did you go there afterwards?

A. Because we wanted to see where he worked.

Q. Had he ever introduced you to any coworkers at Mezzaluna?

A. No.

Q. Ever tell you of any problems he was having with any personnel at Mezzaluna?

A. No. Quite the contrary.

Q. After you saw Ron in April of 1994, when was the next time you saw him or talked to him, rather? I apologize.

A. On Mother's Day. I don't remember what day it was.

Q. In May?

A. Correct.

Q. What do you recall from that conversation? A. Just "Hi, how are you? Miss you. See I you soon. Love you." Q. Any other conversations, telephone conversations?

A. No. We played phone tag.

Q. So that was the last conversation you had?

A. Yes.

Q. Did you call him?

A. Yes.

Q. How often did Ron and your father see each other within the last year before his death?

A. For everybody's birthday, that means there's 5; All the holidays; Periodically throughout the week, they would see each other. I don't know, 4 times a month maybe, including holidays, birthdays, special occasions.

Q. Did they work together?

A. No.

Q. Did Ron provide any financial compensation to your father?

A. No, not that I know of.

Q. Do you know if your father supported him in any manner in 1994?

A. I don't know specifically.

Q. Do you know the last time your father saw Ron prior to his death?

A. I don't for sure.

Q. Have you ever talked about it with your father?

A. I'm sure we did, but I don't know

Q. Did you say you don't know?

A. I don't remember, no.

Q. Was Ron ever involved in any lawsuits? Do you know?

A. Not that I know of.

Q. Did he ever have to file for bankruptcy?

A. Yes.

Q. When did that occur?

A. '92.

Q. Do you know what type of bankruptcy it was?

A. Chapter 7. I don't know. Whatever.

MR. PETROCELLI: Sounds a good to me.

THE WITNESS: Business is Chapter 11, and I think personal is Chapter 7. I'm not sure.

MR. P. BAKER:

Q. Do you know what caused him to file bankruptcy, if you know?

MR. BREWER: Take a wild guess.

MR. PETROCELLI: One guess, Mr. Baker.

THE WITNESS: Bills were too big, couldn't pay them.

MR. P. BAKER:

Q. Credit card bills?

A. Uh-huh, yes. There were others besides credit cards.

Q. What other types of bills were there?

A. Tele Check, when you have check services, when you bounce a check, or something, they put you on. Stuff like that. I don't know specifically off the top of my head.

Q. When did he file bankruptcy?

A. '92.

Q. Do you know how much he owed?

A. I don't remember specifically.

Q. Do you have an estimate?

A. 10-grand area maybe; would be a real high estimate, though. I think that's high, but

Q. About 10,000?

A. Yeah. I think that might be high, but that would maybe be a guess.

Q. That was the same year he called Sharon Rufo, true?

MR. PETROCELLI: Are you asking her again?

MR. P. BAKER:

Q. He called Sharon Rufo in 1992, true?

A. I think it may have been '92. Could have been '91.

Q. Do you know if the purposes of that call was to call her and ask her for some money?

A. No, that wasn't the purpose.

Q. Any other bankruptcy filings other than the '92?

A. No.

Q. Last time you saw Ron and your father together, when was that?

A. Passover '94.

Q. Where were you when you learned of Ron's death?

A. I was at home, San Francisco.

Q. How did you learn of the news?

A. My dad and Patti called me and told me.

Q. And then you returned to Los Angeles?

A. That evening, yes.

Q. Did you ever return to San Francisco?

A. Yes.

Q. When was that?

A. End of June of '94.

Q. How long did you stay back in San Francisco?

A. For about a week, and I came back to Los Angeles for the preliminary hearing in July.

Q. Did you attend everyday of the preliminary hearing?

A. Not the first 2 days.

Q. Did you move down to Los Angeles by July of 1994?

A. No.

Q. When did you return to San Francisco?

A. Within a week of the preliminary hearing ending.

Q. How long did you live in San Francisco?

A. Until January of '95.

Q. Then you returned to Los Angeles

A. Yes.

Q. and moved into your family's home in Agoura Hills?

A. Correct.

Q. Did you talk to anyone about the civil trial at the dinner for Phil Vannatter?

MR. BREWER: Civil trial?

MR. P. BAKER:

Q. I apologize. The civil lawsuit.

A. Maybe generally, just how were things going.

Q. Who did you speak to?

A. I don't remember.

Q. But you talked about the status of the litigation?

A. No. "How is it going?" "Fine, thank you." That was it.

Q. Did you speak to Phil Vannatter at that trial

MR. PETROCELLI: Dinner.

THE WITNESS: Dinner, yes.

MR. P. BAKER.

Q. What was that conversation about?

A. "Congratulations on your retirement." Wished him good luck.

Q. Did he mention that he had been served with a subpoena for his deposition in this case?

A. No.

Q. Anybody else you remember speaking to at all that evening, anyone you remember specifically talking about the civil lawsuit with?

A. No.

Q. Did you ever hear the name Faye Resnick prior to June 12th, '94?

A. No.

Q. Following the jury's acquittal on October 3rd, there was a press conference attended by your family. I believe Robert Tourtelot was there, the deputy district attorneys, and Gil Garcetti.

A. Yes.

Q. Whose idea was that?

A. Gil's. Someone in the prosecutor's office. I don't know who specifically it was.

Q. Did Gil Garcetti ever speak to you prior to that press conference about that press conference?

A. No.

Q. Did you speak to Gil Garcetti at all on that day?

A. Yes.

Q. What do you recall that conversation was about?

A. Just my disbelief that the man who murdered my brother got away with it.

Q. You believe O.J. Simpson murdered your brother?

A. Yes.

Q. You have a lot of hate for him, don't you?

MR. PETROCELLI: Irrelevant.

MR. P. BAKER: Goes to her bias.

MR. PETROCELLI: She is not a witness to any fact involving Mr. Simpson's murder of Ron Goldman. Mr. Simpson was tried because all the evidence pointed to him and nothing

MR. P. BAKER: We don't need a speech.

MR. PETROCELLI: and no evidence points to any other person. So let's get on with it. I've let you go for a long time.

MR. P. BAKER: I hope you've entertained your clients.

MR. PETROCELLI: I'm not entertaining my clients.

You're asking Kim Goldman whether she has hatred for O.J. Simpson. It is about the most offensive, insensitive question that I've ever heard a witness answer, and I'm surprised to hear it come from you. I instruct you not to answer the question. Move on, please.

MR. P. BAKER:

Q. Ms. Goldman, on October 11th, 1995, there was a press conference. When you looked at OJ. Simpson, you felt "Hate. Absolute hate. Rage. Disgust Pain. Sadness." Do you recall that statement?

A. Where was that coming from?

Q. In a statement made to the L.A. Times on October 11th, 1995. Do you recall?

MR. PETROCELLI: Do you want to continue to badger the witness with these insensitive, offensive questions that have absolutely no basis in relevancy?

You explain to me how this could possibly lead to discoverable information.

MR. P. BAKER: Directly to bias of the witness.

MR. PETROCELLI: Bias about what?

MR. P. BAKER: Bias about her testimony.

MR. PETROCELLI: Testimony about what?

MR. P. BAKER: What I'm asking her. I am taking the deposition; you're not.

MR. PETROCELLI: How is her bias, if she had any, relevant to any issue in the case?

MR. P. BAKER. May affect her answers.

MR. PETROCELLI: The only issue

MR. P. BAKER: Do you understand what bias is?

MR. PETROCELLI: The only answer she can provide any relevant testimony on has to do with the relationship between Fred Goldman and Ron Goldman and Sharon Rufo and Ron Goldman, and that's about it .

MR. P. BAKER: Apparently, you've been attending a different deposition than what I've been attending.

Q. Do you recall that conversation? Do you recall that statement, Ms. Goldman? I'm sorry. It's on page 2 where the Post-it note is.

MR. PETROCELLI: I guess we'll have to examine O.J. Simpson about his offensive remarks concerning the Browns and Goldmans, and I'll cite this examination as the basis for that inquiry.

MR. VAN SICKLEN: These remarks are intended to be a part of the record because this deposition, like Mr. Simpson's, is going to get leaked. Is that why you're making the speeches?

MR. PETROCELLI: That's a ridiculous comment, and you know it is. You should be ashamed of yourself. In the words of Robert Baker "Act like a lawyer." Let's move on, please.

MR. P. BAKER: I'm waiting for the answer.

THE WITNESS: Yes.

MR. P. BAKER:

Q. And you do hate Mr. Simpson, true?

MR. PETROCELLI: I instruct you not to answer the question. It's irrelevant

MR. P. BAKER: Mark it, please.

MR. PETROCELLI: It's offensive and it's insensitive and it's irrelevant.

MR. P. BAKER:

Q. Have you ever made a statement to any detective regarding any matter outside of this case?

MR. PETROCELLI: Instruct the witness not to answer on the ground of irrelevancy. By your own question, it's irrelevant.

MR. P. BAKER: Are you instructing her not to answer on the grounds of relevancy?

MR. PETROCELLI: You said, "outside this case." I assume you mean the civil, not criminal.

MR. P. BAKER: I understand you're

MR. PETROCELLI: Your question asks for conversations with detectives having nothing to do with this case. I instruct her not to answer.

MR. P. BAKER: |

Q. Who did you know personally who testified at trial prior to their testimony?

MR. PETROCELLI: Who did she know prior to June 12, 1994, who testified at the trial?

MR. P. BAKER: Yes.

MR. PETROCELLI: If anyone.

THE WITNESS: Patti.

MR. P. BAKER:

Q. Anyone else?

MR. PETROCELLI: By "Patti" you are referring to Patti Goldman?

THE WITNESS: Correct. No not that I can think of.

MR. PETROCELLI: There were over 100 witnesses, I think, but is that your best recollection?

THE WITNESS: Yes.

MR. P. BAKER: Do you want to take a break so you can coach your witness outside the room?

MR. PETROCELLI: I don't need to coach the witness, unlike other lawyers I know.

MR. P. BAKER: Why don't we take about a 10-minute break.

(A recess is taken.)

MR. P. BAKER: Just for the record, I'll attach the articles as Exhibit 1002, so it's clear what I referred to.

MR. PETROCELLI: Why don't you describe it on the record.

MR. P. BAKER: There's 3 computerized reproductions of L.A. Times articles, which should be attached.

MR. BREWER We're marking those collectively as 1002?

MR. P. BAKER: Right. I have trial subpoenas.

MR. PETROCELLI: Mr. Baker, you asked Ms. Goldman a question about whether she hates OJ. Simpson, and I've instructed her not to answer the question. And over my objections, she wishes to answer. So if you want to ask her, she will answer.

MR. P. BAKER:

Q. What is your answer, ma'am?

A. I absolutely hate the man.

Q. You believe he killed your brother, true?

A. Absolutely.

Q. And you'll say anything to make sure he is found responsible for that death, true?

A. No.

Q. Who have you told of this hatred?

A. Lots of people. I'm not ashamed of it

Q. Who have you told was the question.

A. Lots of people.

Q. Do you have any names?

A. My family; My friends.

Q. Which friends?

A. Would you like me to list all my friends?

Q. Please.

MR. PETROCELLI: He wants you to list the friends that you've said this to. He doesn't want you to list all your friends. (The names and telephone numbers provided by the witness have been stricken from the transcript per counsel present and written on a piece of paper to be marked as Exhibit 1003 and retained by Mr. P. Baker.)

THE WITNESS: Are you going to be Is this going to be out in public, these phone numbers?

MR. P. BAKER: This is not going to be released from our office.

MR. PETROCELLI: Well, none of these depositions are subject to a sealing order. And as you know, there are all sorts of lawyers, including 4 firms on your side, 3 firms on plaintiff's side, that have access to these depositions, not to mention numerous other persons.

So there's no assurance, Ms. Goldman, that these depositions won't be made public.

If you have a concern about that, I think we could go back and take those names off and write them on a piece of paper, as Mr. Baker has done in other depositions. We can accommodate that.

THE WITNESS: I would rather do that.

MR. P. BAKER: We'll have the list attached.

MR. PETROCELLI: Make this 1003.

MR. P. BAKER: 1003. We'll leave blanks for the numbers already referred to in the last 2 pages of deposition testimony, and she'll write the names and the phone numbers, and Exhibit 1003 will be placed in a Manila envelope in the back of the deposition.

MR. PETROCELLI: You know what I would suggest is that you just hold onto that exhibit. Okay? Just don't make any copies of it, and you hold onto it, Mr. Baker, and we'll know the numbers.

MR. P. BAKER:

Q. Why don't you place the numbers next to the names which you have referred to, the first one being [name deleted].

A. (Indicating.)

Q. [Name deleted] was next.

A. (Indicating.)

Q. [Name deleted] was next

A. (Indicating.)

Q. [Name deleted] was next.

A. (Indicating.)

Q. [Name deleted.]

A. (Indicating.)

Q. And [name deleted].

A. (Indicating.)

Q. You have told these persons that you hate Mr. Simpson, true?

A. Yes.

Q. And you've told them that on many times, true?

A. After all the evidence was shown, yes. I didn't know him before my brother's murder. I would have no reason to hate him before that.

Q. You didn't tell anyone you hated Mr. Simpson until all the evidence was shown?

A. Until I believe he murdered my brother.

Q. And that is until you analyzed all the evidence?

A. At some point.

Q. What point was that, ma'am?

A. I don't know the exact day I believed in his guilt.

Q. Do you have an estimate as to when you believed in Mr. Simpson's guilt?

A. Probably during the DNA, since that was the most revealing and hurtful evidence towards him.

Q. That's what you believe to be the most hurtful evidence against him?

A. Yes. Part of it. There's a whole slew of pieces of evidence that show his guilt.

Q. So you told these persons that you hated Mr. Simpson following the DNA portion?

A. I don't know specifically when I told him, but probably at some point around there, yeah.

Q. Prior to the time that the defense put on their case, true?

A. I can't answer that.

Q. When was the last time you told any one of these individuals that you hate Mr. Simpson?

MR. PETROCELLI: Don't speculate.

THE WITNESS: I don't know.

MR. P. BAKER:

Q. You have no idea when the last time was?

A. I don't know, no.

Q. Was it recently?

A. Probably. I don't know for sure.

MR. PETROCELLI: Don't guess.

MR. P. BAKER: Q. You attended Mr. Simpson's deposition, didn't you?

MR. PETROCELLI: She was excluded from Mr. Simpson's deposition by your law firm, so she was unable to attend.

MR. P. BAKER:

Q. You held press conferences about that deposition, didn't you?

MR. PETROCELLI: She did hold a press conference and talked to the press assembled and amassed outside my office.

THE WITNESS: I was asked a question about that, yes.

MR. P. BAKER: Q. How many days of the week of Mr. Simpson's deposition did you speak to the press?

MR. PETROCELLI: What's the relevance of this, Mr. Baker?

MR. P. BAKER: I want to understand how she obtained this knowledge about his deposition.

MR. PETROCELLI: Why? I'm going to stop it here. That's irrelevant. I'll instruct her not to answer.

MR. P. BAKER: Again, you're instructing her not to answer on relevancy grounds; is that correct, sir?

MR. PETROCELLI: Yes, Mr. Baker. And by "relevancy," it's a shorthand reference to the longer form of objection that is not reasonably calculated to lead to the discovery of admissible evidence.

I also think, in all due respect, that you're harassing the witness.

MR. P. BAKER:

Q. Do you know if Mr. Goldman, Ron Goldman, ever Well, he was an aspiring actor, wasn't he?

A. No.

Q. Did he ever act?

A. No.

Q. Did he ever make any movies of any manner whatsoever?

A. No.

Q. Never in any commercials?

A. No.

Q. He didn't have a SAG card?

A. No.

Q. You mentioned that your family had received donations since Mr. Simpson's acquittal. What's the total amount of those donations?

MR. PETROCELLI: Instruct you not to answer.

MR. P. BAKER: On what grounds?

MR. PETROCELLI: On the grounds that it's irrelevant and it's harassing. You know it is, too.

MR. P. BAKER: Can you mark that, please.

MR. PETROCELLI: Also invades privacy and a slew of other objections.

MR. P. BAKER:

Q. How often did you see Ron in the last 6 months of his life?

MR. PETROCELLI: You already went through this, but you can answer it again.

THE WITNESS: On 2 separate occasions for an extended period of time.

MR. P. BAKER:

Q. That was in April of '94, was one of those occasions, true?

A. Yes.

Q. What was the second occasion?

A. Sometime in Oh, wait. More than 2 times.

Q. One time in November when I came down for Lauren's bat mitzvah, I was there about a week and spent almost everyday with my brother, November of '93.

Q. How many days did you spend with him?

A. I'd say 4 out of the 6 days that I was home.

Q. What type of things did you do with him?

A. Went shopping. We had lunch together. Hung out together. Ran errands. Brother and sisterly things.

Q. Did you stay at his house or apartment?

A. No.

Q. You've heard reports that

A. There was another time.

Q. Okay.

MR. PETROCELLI: She's not completed.

THE WITNESS: Sometime in December when we all got together for the holidays; And my birthday; And my dad's birthday when I came down for another length of time; As well as the time in April.

MR. P. BAKER:

Q. There have been tabloid stories about every party involved in this case including your brother. You're aware of that, true?

A. I've heard about them, yes.

Q. You've heard the tabloid stories that he was involved in drugs. Do you have any knowledge of that?

A. Absolutely not, he was not involved in drugs.

Q. And you'd never seen him use any drugs?

A. No.

Q. Did you find any prescription drugs in his apartment when you cleaned it out?

A. No.

Q. Do you know how many pages your journal is that you prepared during the criminal trial?

A. As many days as the criminal trial existed, a year, 9 months, whatever it was. Q. Each day you had a journal entry?

A. For the most part, yes.

Q. And have you had journal entries since the conclusion of the criminal trial on October 3rd?

A. Off and on, just what may have happened that day.

Q. Any journal entries about the civil lawsuit?

A. A few, yes.

Q. In 1992 when Ron was arrested, did you ever see your father and Ron get in an argument?

A. My dad didn't know at first. I told my father. I don't They didn't get into an argument about it.

Q. How did you learn about it?

A. My brother called me from jail.

Q. Did he want you to bail him out?

A. No.

Q. Did he just advise where he was?

A. He told me where he was. He thought he was going to be released later. I offered to come help him. And he wanted to take care of it on his own, so he decided to stay, so that nobody would have to pay for him.

Q. And as you sit here today, you can't recall why he was arrested specifically?

A. I believe it was parking citations, traffic violations, things of that nature.

MR. P. BAKER: I've got no further questions. Mr. Brewer, do you have any questions?

MR. BREWER: No questions.

MR. P. BAKER: Propose the stipulation that the deposition be sent to Mr. Petrocelli's office. It's about 143 pages, so 15 days, 20 days to review the deposition transcript. Make any changes and then sign.

MR. PETROCELLI: 20 is fine.

MR. P. BAKER: 20 days. And Mr. Petrocelli will advise me if there are any changes made to that deposition testimony. And also propose that we stipulate that if the original is lost, a copy can be used in its stead.

MR. BREWER: So stipulated.

MR. PETROCELLI: So stipulated. ]

(Whereupon the documents referred to are marked by the reporter as Defense Exhibits 1001 through 1003 for identification.)

(The proceedings concluded at 2:33 p.m.)

Executed at ______________________________, California, on ___________________.

KIMBERLY E. GOLDMAN

STATE OF CALIFORNIA

I, Karen E. Kay, CSR 3862, do hereby declare:

That, prior to being examined, the witness named in the foregoing deposition was by me duly sworn pursuant to Section 2093 of the Code of Civil Procedure in effect as of January 1, 1989;

That said deposition was taken down by me in shorthand at the time and place therein named and thereafter reduced to typewriting under my direction.

I further declare that I have no interest in the event of the action.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

WITNESS my hand this 6th day of February 1996. __________________
Karen E. Kay, CSR 3862, RPR, RMR, Certified Realtime Reporter.


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