Page 101 of The Lincoln Lawyer

“What did she tell you?”

“She said a man had come to her door and knocked and when she opened it he punched her. She said he hit her several times and then took out a knife.”

“She said he took the knife out after he punched her?”

“That’s how she said it. She was upset and hurt at the time.”

“I understand. Did she tell you who the man was?”

“No, she said she didn’t know the man.”

“You specifically asked if she knew the man?”

“Yes. She said no.”

“So she just opened her door at ten o’clock at night to a stranger.”

“She didn’t say it that way.”

“But you said she told you she didn’t know him, right?”

“That is correct. That is how she said it. She said, ‘I don’t know who he is.’”

“And did you put this in your report?”

“Yes, I did.”

I introduced the patrol officer’s report as a defense exhibit and had Maxwell read parts of it to the jury. These parts involved Campo saying that the attack was unprovoked and at the hands of a stranger.

“‘The victim does not know the man who assaulted her and did not know why she was attacked,’” she read from her own report.

Maxwell’s partner, John Santos, testified next, telling jurors that Campo directed him to her apartment, where he found a man on the floor near the entrance. The man was semiconscious and was being held on the ground by two of Campo’s neighbors, Edward Turner and Ronald Atkins. One man was straddling the man’s chest and the other was sitting on his legs.

Santos identified the man being held on the floor as the defendant, Louis Ross Roulet. Santos described him as having blood on his clothes and his left hand. He said Roulet appeared to be suffering from a concussion or some sort of head injury and initially was not responsive to commands. Santos turned him over and handcuffed his hands behind his back. The officer then put a plastic evidence bag he carried in a compartment on his belt over Roulet’s bloody hand.

Santos testified that one of the men who had been holding Roulet handed over a folding knife that was open and had blood on its handle and blade. Santos told jurors he bagged this item as well and turned it over to Detective Martin Booker as soon as he arrived on the scene.

On cross-examination I asked Santos only two questions.

“Officer, was there blood on the defendant’s right hand?”

“No, there was no blood on his right hand or I would have bagged that one, too.”

“I see. So you have blood on the left hand only and a knife with blood on the handle. Would it then appear to you that if the defendant had held that knife, then he would have to have held it in his left hand?”

Minton objected, saying that Santos was a patrol officer and that the question was beyond the scope of his expertise. I arguedthat the question required only a commonsense answer, not an expert. The judge overruled the objection and the court clerk read the question back to the witness.

“It would seem that way to me,” Santos answered.

Arthur Metz was the paramedic who testified next. He told jurors about Campo’s demeanor and the extent of her injuries when he treated her less than thirty minutes after the attack. He said that it appeared to him that she had suffered at least three significant impacts to the face. He also described a small puncture wound to her neck. He described all the injuries as superficial but painful. A large blowup of the same photograph of Campo’s face I had seen on the first day I was on the case was displayed on an easel in front of the jury. I objected to this, arguing that the photo was prejudicial because it had been blown up to larger-than-life size, but I was overruled by Judge Fullbright.

Then, when it was my turn to cross-examine Metz, I used the photo I had just objected to.

“When you tell us that it appeared that she suffered at least three impacts to the face, what do you mean by ‘impact’?” I asked.

“She was struck with something. Either a fist or a blunt object.”

“So basically someone hit her three times. Could you please use this laser pointer and show the jury on the photograph where these impacts occurred.”