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From: Lollie
Date: 8/30/03
Time: 3:10:22 PM
Remote Name: 198.81.26.72
Maybe I am off subject but is this proof there was a deposition by Browns other than Denise.(Not shown on Walraven in list of depositions and interviews. Only Denise Brown 's deposition is listed).
"The plaintiff, Estate of Nicole Brown Simpson, respectfully moves to exclude certain evidence which the plaintiff believes defendant Simpson will offer at the time of trial. The evidence in question is irrelevant, non probative, misleading and inflammatory.
The court should issue an order in limine to instruct defendant's attorney and witnesses as follows:
Defendant's attorney and witnesses are directed not to introduce, suggest, refer to, or comment on, either directly or indirectly, during voir dire, or before the jury regarding the allegation that any member of the Brown family including Louis Brown, Juditha Brown, Denise Brown, Dominique Brown, Tanya Brown and Rolph Bauer sold or profited from the sale of any items, stories or materials related to Nicole Brown Simpson, Orenthal Simpson, or their children, Sydney and Justin.
Dated: August 26, 1996
/s/
John Quinlan Kelly, Esq. Attorneys for Plaintiff Estate of Nicole Brown Simpson
MEMORANDUM OF POINTS AND AUTHORITIES
I.
PRELIMINARY STATEMENT
Based upon certain questions propounded by defense counsel at the deposition of certain Brown family members, the plaintiff, Estate- of Nicole Brown Simpson, has reason to believe that defendant Simpson will seek to introduce and utilize non- probative, misleading, inflammatory allegations and materials regarding various members of the Brown family.
At the deposition of Dominique Brown, the younger sister of the deceased Nicole Brown Simpson, defendant Simpson's counsel asked the following questions:
"Since your sister has been killed, have you received any income from the sale of photographs of Nicole . . ."
"Have you sold photographs of Nicole to anybody?"
Shortly after receiving answers to these questions, defendant's attorneys immediately contacted the national media and provided them detailed answers to same as an obvious attempt to slander and embarrass this witness. See Exhibit "A" hereto.
These questions strongly suggest that at the trial of this matter, defendant Simpson will seek to introduce and utilize material and questions tending to suggest that members of the Brown family have profited from the sale of various items and materials relating to Nicole Brown Simpson, defendant Simpson and the children, Sydney and Justin Simpson. It is impossible to anticipate the number or specific kind of questions which may be propounded by defense counsel under the guise of "impeachment" or "attack on witnesses' credibility." A wealth of inaccurate, slanderous and scurrilous material regarding the Brown family has appeared in the tabloid press and in other media outlets since the murder of Nicole Brown Simpson.
The entire motion is in:
http://simpson.walraven.org/pm_01.html
There was so much that was kept out of the trial that would have been helpful in O J winning the civil suit.