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Trial transcript: impeaching lying witness

Jamison Koehler Trial Advocacy

Q:        I understand that you are bipolar.

A:         I am not bipolar.

Q:        You’re not?

A:         No.

Q:        And never have been?

A:         No.

Q:        Ms. Jones.  You realize that when the police interviewed you, they were wearing body worn cameras?

A:         Actually I didn’t know that.  That’s not something I was aware of.  

Q:        Yes.  They wear them on their chests.  There is a blinking light when activated.

A:         Okay.

Q:        So your conversations with them that night were recorded.  You didn’t know that?

A:         Actually no.

Q:        And these body worn camera files were turned over to the defense before trial.  So I was able to watch them.  I was able to see and hear what you told the officers that night.  You didn’t know that?

A:         No.

Q:        Let me ask you again:  Are you bipolar?


THE COURT:    Overruled, overruled.  You can answer the question.

A:         I have PTSD but I am not bipolar.

Q:        I see.  You have PTSD but you are not bipolar.  You didn’t tell police that night when they first got there that you’re bipolar?

A:         Maybe.  I – they changed my diagnosis.  The psychiatrist that I went to from 2012 to 2016 or 17 said that my diagnosis was post-traumatic stress disorder and anxiety and depression.  The psychiatrist that I’m currently going to said my diagnosis is that in addition to bipolar.

Q:        I see.  PTSD and bipolar.  So when I asked you earlier whether you were bipolar and then I asked you again, just a moment ago, and you said, unequivocally, no, that was inaccurate?

A:         True, yes.  

Q:        True yes that was inaccurate?

A:         Yes.

Q:        Both times?

A:         Yes.  

Q:        Both times it was a lie?

A:         I don’t know — 

Q:        — Did you misunderstand my question?

A:         No, I understood what you were trying to say.

Q:        Trying to say?  I asked you if you were bipolar and you said no.  Do you understand the word bipolar?

A:         Really I — 

PROSECUTOR:– Objection.

COURT: Alright, counsel. You have made your point.  You can move on.   

Q:        Are you on any medication?

A:         Yes.

Q:        Are you on any medication now for bipolar?

A:         Yes.

Q:        Were you on medication that night?

A:         No.  But I am on my medication now.