2005 April 1 (Day 24)Testimonies J. Klapackis, J. Green, L. Feldman & J.

Salas

JEFF KLAPAKIS EXAMINATION

CROSS-EXAMINATION BY MR. MESEREAU:
Q. Mr. Klapakis, did you suggest last week that because of your discussions with the FBI
you delayed fingerprint analysis for a year?
A. Last week, do you mean Wednesday?
Q. Oh, thats right. Thats right. Youre right. How about Wednesday, did you suggest that
the FBI -- your discussions with the FBI had something to do with a one-year delay in
analyzing fingerprints?
A. No, my discussion with the FBI had to do with basically doing background investigations
for us as well as computer work for us.
Q. Did you suggest that the Department of Justice and the State of California does not do
fingerprint analysis?
A. What I suggested was that their priorities are for other agencies, and we can do
fingerprints ourselves.
Q. But they do do fingerprint analysis,correct?
A. Yes.
Q. And at times your office will use the Department of Justice to do fingerprint analysis,
correct?
A. I believe that we have, but its very rare. We do it ourselves.
Q. Do you know somebody named George Levine of the Department of Justice?
A. Yes, I do.
Q. Who is George Levine?
A. Hes an examiner with the Department of Justice.
Q. And what does he do, to your knowledge?
A. Well, he does a lot of things, but I believe fingerprints is one of them.
Q. And how long have you known him?
A. Oh, I think George has been with the agency longer than I have been with the sheriffs
department. So over 20 years.
Q. Have you worked with him on fingerprint analysis before?
A. Yes, I believe we have.
Q. Now, did you suggest to the jury that because it took so long to separate pages out of
magazines that fingerprint analysis in this case needed to be delayed for a year?
A. Thats not what I suggested.
Q. What did you suggest when you told the jury about the laborious process of removing
pages from magazines?
A. Well, that it was a multi-phase process, and that we wanted to -- there were several
things that we had to do. We wanted to maintain control over the evidence, and not
piecemeal it out. And because portions of the magazines were in different locations, we
had to do those phases at different times.
Q. And are you saying that contributed to a delay in analyzing fingerprints?
A. Yes, it did.
Q. Okay. And how long was the delay in analyzing fingerprints that you would attribute to
separating out pages from magazines?

A. Im not quite sure I understand the question.

Q. Youve said that separating pages out from magazines caused a delay in analyzing
fingerprints, correct?
A. Yes.
Q. The delay was approximately one year, correct?
A. Approximately.
Q. Are you attributing that delay exclusively to your need to separate out pages from
magazines?
A. No.
Q. Okay. Now, as the head of the search of Mr. Jacksons residence, you were in charge of
determining what forensic tests would be done of anything found in the residence, true?
A. I was part of that process, yes.
Q. Did you ask for any forensic tests on any bottles that seemed to contain alcoholic
beverages?
A. No.
Q. Do you know if any forensic tests were done on bottles that seemed to contain alcoholic
beverages found at Mr. Jacksons residence?
A. I dont believe we did.
Q. You saw bottles that seemed to contain alcoholic beverages in the wine cellar, correct?
A. I believe some of the investigators did, yes.
Q. And you found bottles that seemed to contain alcoholic beverages in the kitchen,
correct?
A. Yes.
Q. And they appeared to be in unlocked areas, correct?
A. Correct.
Q. You found bottles that seemed to contain alcoholic beverages in Mr. Jacksons
bedroom, true?
A. Yes, there was a bottle of alcohol in his bedroom.
Q. Do you know if any forensic tests were ever done on any bottles that seemed to
contain alcoholic beverages in Mr. Jacksons bedroom?
A. Not to my knowledge.
Q. Did it ever occur to you that trying to determine whose fingerprints were on bottles of
that sort might have merit in the investigation?
A. Well, it would -- my belief is, is that we were talking about something that occurred
eight months prior to the service of the search warrant, so the answer would be no.
Q. How long do fingerprints tend to last on surfaces, based upon your experience as a
police officer?
A. They can last that long, at least.
Q. They can last many years, correct?
A. Yes.
Q. Given what you had heard about potential charges, did it ever occur to you that trying
to see whose fingerprints were on glasses or bottles, glasses that seemed to have
contained or are used to contain alcoholic beverages or bottles that seem to contain
alcoholic beverages, might be relevant?
A. We didnt at the time.
Q. Okay. Did you do it at any time?
A. No.
Q. When the search went on in Michael Jacksons home, did you have a particular location

where you had either a desk or a chair?

A. Did I?
Q. Yes.
A. I believe -- Im not quite sure I understand. Did I have a desk or a chair?
Q. Did you -- as head of the search, did you have a central location in the residence of Mr.
Jackson where people came back and forth to report to you?
A. No. I dont believe I had a central location, no.
Q. So were you essentially walking around the residence during the entire search?
A. I was moving about the estate, yes.
Q. Okay. And were you supervising what people who reported to you were doing?
A. I along with others.
Q. Okay. Was your function primarily a supervisory function?
A. Yes.
Q. Did you ever ask for any fingerprint analysis of items of furniture in Mr. Jacksons
bedroom?
A. No.
Q. Did you ever ask for any fingerprint analysis of various boxes you saw in Mr. Jacksons
bedroom?
A. No.
Q. Did you ever ask for a fingerprint analysis of a lot of the mannequin-type toys you
found in Mr. Jacksons bedroom?
A. No.
Q. Did you ever ask for a fingerprint analysis of anything you saw on the floor in Mr.
Jacksons bedroom?
A. If some magazine material was found on the floor, yes, we would have, but -Q. Was the fingerprint analysis you requested only directed at magazines?
A. I believe so, yes.
Q. Did you ever request any fingerprint analysis of anything you saw hanging on the wall?
A. No.
Q. How about the railing on the stairs going into Mr. Jacksons bedroom?
A. No.
Q. How about any of the doors you have to go through to enter Mr. Jacksons bedroom?
A. No.
Q. Now, other than fingerprints and DNA analysis, is there any other type of forensic test
you wanted done during the day of that search?
A. During the day of the search, no.
Q. Were the forensic tests that you asked to be done limited to looking for DNA and
looking for fingerprints?
A. Well, we -- I also believe that photography is part of forensic work, and so we
photographed the different rooms of the estate and different things of that nature, but
limiting it to that, yes.
Q. Was any effort ever made to see if you could find fibers, hair or material, in Mr.
Jacksons bedroom that you could link to any of the Arvizos?
A. Well, when we took the bedding from Mr. Jacksons bed, I wasnt limiting it to biological
fluids. I was limiting -- basically, I wanted a complete analysis of anything that they found
out there. So, we took the -- all the bedding and left it to the examiners to determine
what evidence might be on that bed.
Q. And clearly, you never found any of the Arvizos DNA in that bedding, correct?

A. Thats correct.
Q. And you never found their hair or fibers in that bedding, correct?
A. Thats correct.
Q. And you never found any of their prints on any furniture linked to Mr. Jacksons bed,
correct?
A. Thats correct.
MR. MESEREAU: I have no further questions at this time.
THE COURT: Redirect?

REDIRECT EXAMINATION BY MR. SNEDDON:

Q. Lets go back to some of the things you were talking about last Wednesday that Mr.
Mesereau was asking you about, and specifically the execution of the search warrant. You
were asked by Mr. Mesereau about what you typically do in a typical murder case. Not
that theres really a typical murder case. But with regard to a murder case that occurs in a
residence, all right? When you have a murder case that occurs in a residence, what are
you legally required to do
in order to process the crime scene?
A. We have to obtain a search warrant.
Q. And when you obtain a search warrant from a judge to allow you to process the crime
scene of a residence, are there ordinarily any time limitations placed upon you in terms of
how long you can remain at the residence to complete the process of the crime scene?
A. No. We could -- it could take a day, it could take a week. Whatever it takes to process
the scene. Q. And have there been cases involving your agency in which crime scenes
have been secured an processed over the -- over days and weeks?
A. Yes.
Q. Have you ever, in your experience, and to your knowledge with the sheriffs
department, had a residence and a ranch of the size of Mr. Jacksons that youve had to
ever search?
A. No.
Q. And just so the jurys clear on this, there was more than one building searched that
day, correct?
A. There were several.
Q. In addition to his residence?
A. Yes.
Q. Would you consider the residence a typical search by your department?
A. No.
Q. Why?
A. Well, it involved a very large main house on the estate. It also involved different
buildings on the estate. It -- the estate, the house, was packed with a lot of things that we
had to go through. We had to make sure that we were very careful with them. And the
search also conducted was in different locations within the estate.
Q. Did you know at the time that you executed the search warrant on November the 18th,
2003, whether or not Mr. Jackson was present on the ranch?
A. We were not aware that he was on the ranch.
Q. Now, with regard to the time constraints given to you with the execution of the search
warrant on Mr. Jacksons ranch, what time constraints were you given on that?

A. I was told that I had to be done within a day.

Q. And how did that come about?
A. Well, I had asked you if we could write in the search warrant that we could take a
couple of days or more to conduct this search, because of the size of the estate, plus the
other things involved in this investigation, other searches. And through that discussion, it
was decided that we were going to have to do it within one day, so as not to burden the
ranch and its employees with our presence longer than that.
Q. And was there some relationship between the amount of time and the number of
personnel that you needed to do it within the time constraints that you were given?
A. Well, based on the size of the estate, we felt that in order to get it done within that
time frame, we had to have an abundance of personnel. It wasnt just the search.
Q. All right. Now, with regard to the questions Mr. Mesereau asked you about whether you
gave any instructions to the people who were under your supervision during the execution
of the search warrant; do you recall that question?
A. Yes.
Q. What were your instructions to your people?
A. Do not talk to the press.
Q. You were also asked by Mr. Mesereau whether or not you had -- whether or not there
were media that were -- that came outside the ranch on the second search warrant that
was executed almost a year later in December of 2004. Do you recall that?
A. Yes.
Q. And with regard to the source of the information that was given to the media, to your
knowledge, was the sheriffs department responsible for that?
A. No, we were not.
Q. And to your knowledge, was it somebody connected outside of the sheriff and law
enforcement community?
A. Thats what I believe.
Q. Now, Mr. Mesereau asked you several questions about items that were found at certain
locations and used the word unlocked. To your knowledge, was the wine cellar unlocked
when you folks first got into the building on the morning of the 18th of November?
A. The wine cellar was locked.
Q. And with regard to the closets in Mr.Jacksons bedroom where the alcohol was located,
to your knowledge, was that locked or unlocked at the time it was first approached by
your folks?
A. His bedroom was locked and alarmed.
Q. And the closet in which the two bottles of alcohol were found, was that closet locked or
unlocked at the time that your folks first approached that closet and opened it?
A. The -- Im not sure of the location youre talking about.
Q. Downstairs in the master suite.
A. The master suite was locked.
Q. And the closets in the master suite?
A. Im not sure of that. I know I wasnt the one of first ones to enter into the master suite.
I know the -- I was -- excuse me, I was the first -- one of the first ones to enter the
master suite. But as to the closets, I cant tell you.
Q. All right.
A. One closet was locked. It was on the -- it was on the left side library, or left side
bathroom, excuse me. There was a locked door there.
Q. The one with the Jacuzzi-type tub?

A. Next to the safe. Yes.

Q. Okay. Now, before you executed the search warrant or before the search warrant was
executed on November 18th, were you aware of the interviews that had been conducted
with the Arvizo children?
A. Yes.
Q. And were you aware of the information that they had provided about the interior of Mr
Jacksons bedroom suite area?
A. Yes.
Q. At the time that you were executing your search warrant on November the 18th of
2003, how much time had elapsed between the time that you had information that the
crimes were committed and the time you were executing the warrant?
A. Nine months. Eight, nine months.
Q. Now, at that time, Mr. Mesereau asked you whether or not you took any prints off the
balcony or whether you looked for hair or fibers or anything else. Was there a reason that
wasnt really an important part of the investigation at that particular stage in time?
A. It just didnt enter into the investigation at that particular time.
Q. Why?
A. Well, we were -- we had certain information regarding the crimes. We went in to the
search looking for those things. Our search was limited in time, and we were doing several
other things, interviews, other searches in other locations. The -- this investigation was
atypical because it entered into other -- other crimes, other overt acts in which we had to
investigate.
Q. With regard to the presence of the Arvizo children in Mr. Jacksons master bedroom
and in the suite itself, at the time you were executing the search warrant, can you tell us
whether or not there was any doubt in the investigators minds that they had actually
been in those rooms?
A. No, they described it uniquely, and it -- we actually knew where we were going when
we -MR. MESEREAU: Objection. Calls for hearsay and speculation. And also its improper.
THE COURT: Sustained.
MR. SNEDDON: Judge, whats the basis? Because I may be able to cure it. Because I
didnt think it was hearsay.
THE COURT: Well, youre talking about what was in the other investigators minds.
MR. SNEDDON: Im sorry, then I can cure it.
Q. With regard to what was in your mind as the lead investigator during the course of the
execution of this search warrant, were you aware of the information that the Arvizo
children had provided to you?
A. Yes.
Q. And with regard to that information, did that have an impact on you with regard to
trying to prove whether or not they were ever in those rooms?
A. No, they had described it. And when we entered the room, it fit their description.
Q. All right. Mr. Mesereau asked you one other -- another question with regard to whether
-- you were trying to explain what -- he uses the word delay in the processing of the
print. And you answered the question, No. Why was there no -- you didnt consider that
to be a delay of over a year?
A. As Mr. Mesereau stated, latents can stay on an object for a long time. We were
protecting the items of evidence. They were in different locations. We were conducting our
processes as we were able to. And ultimately we were able to develop and stabilize the

latents that we felt were on the items of evidence.

Q. Were there other items that were taken that you believe could have been processed for
forensic evidence?
A. Sure. We could have fingerprinted some alcohol bottles or other things like that, but we
didnt.
Q. With regard to this particular case, there are a number of books that are in evidence.
A. Yes.
Q. Youre aware of that?
A. Yes.
Q. Was there a conscious decision made with regard to those particular books and
processing them for the latent prints?
A. Right. The -- the books, in a discussion with Mr. Zonen, was -- we determined not to
conduct a latent fingerprint examination on them, because the process to do so would
have, one, destroyed the book and made the pages toxic. Mr. Zonen preferred to keep the
book in its original condition, and so the decision was made not to attempt the latent
search on them.
MR. SNEDDON: Thank you. Nothing further.
MR. MESEREAU: May I just take one second, Your Honor?
THE COURT: Yes. (Off-the-record discussion held at counsel table.)
RECROSS-EXAMINATIONBY MR. MESEREAU:
Q. Your investigation, Im talking about you personally, Lieutenant, began approximately
June 13th, 2003, when you were contacted by Attorney Larry Feldman, true?
A. No. I started this in February.
Q. Okay.
A. If thats -- I began in February 2003.
Q. Okay. But in the operations plan that was developed and typed up for the search that
you were in charge of, you attached a case timeline, correct? 4431
A. The sergeant who developed the ops plan did, yes.
Q. And that was Sergeant Eric Koopmans, correct?
A. Koopmans, yes.
Q. Did he develop that plan with your assistance?
A. Certainly mine. Sergeant Robles.
Q. With respect to that search, you talk about you being contacted by Attorney Larry
Feldman on Friday, June 13th, 2003, correct?
A. I believe that was the date.
Q. Okay. Do you know why that timeline doesnt include the investigation you were doing
much earlier?
A. The ops plan is basically the synopsis, a brief synopsis, of giving the investigators some
background on our investigation. I cant tell you why it didnt have the February
information.
Q. And the timeline associated with the operations plan doesnt include the fact that you
personally called the Department of Children & Family Services and asked them not to
interview the Arvizos, correct?
MR. SNEDDON: Your Honor, this is beyond the scope of the redirect. I object.
THE COURT: Sustained.
MR. MESEREAU: I have no further questions, Your Honor.

MR. SNEDDON: Nothing further, Your Honor.

THE COURT: You may step down.

JACK GREEN EXAMINATION

DIRECT EXAMINATION BY MR. AUCHINCLOSS:

Q. How are you employed?
A. Im the president of Affordable Telephone Systems in Ventura, California.
Q. And what is Affordable Telephone Systems?
A. Were an AT&T equipment dealer.
Q. And what do you do for Affordable Telephone Systems as the president?
A. Run the operation.
Q. All right. Do you actually go out to sites and perform services in relation to telephones
themselves?
A. I do. Uh-huh.
Q. And how long have you been doing this?
A. 20 years.

Q. Do you have a background in -- do you have any training in the area of telephone
systems?
A. I do.
Q. Could you describe that for me, please?
A. I was trained by AT&T Corporation.
Q. All right. How long ago?
A. In 1984 to 1990.
Q. What kind of training did you receive?
A. Technical training on their systems from their corporate trainers.
Q. And how long did this training take place, over what period of time?
A. Over the course of ten years.
Q. All right. And I take it youve had some hands-on experience with this subject matter?
A. Correct.
Q. Over the 20 years you have performed services for telephone systems?
A. Yes, I have.
Q. On -- you know, could you even estimate how many times?
A. Oh, geez, thousands.
Q. Okay. On December 3rd, 2004, did you visit Neverland Ranch in Los Olivos, California?
A. I did.
Q. And did you have an assignment when you went out to the ranch that day?
A. I did.
Q. What was your assignment?
A. To inspect the telephone system at the ranch. And to give information on how the
phone system was configured, programmed and would operate.
Q. Were you accompanied by law enforcement officers on that date?
A. I was.
Q. And did you perform that task?
A. I did.
Q. First of all, tell me, what type of system does Neverland Ranch have, what type of
telephone system?
A. Its manufactured by AT&T. Its called a Merlin II system is the model. Its a -- we call it
a key system, a hybrid key system.
Q. Okay. Are you familiar with the Merlin II system from AT&T?
A. I am.
Q. Have you serviced that system before?
A. I have.
Q. So tell me what you did. How did you go about inspecting the system?
A. We -- we inspected and looked at how many telephone lines that were -- from the
telephone company on the property, were installed in the system. We logged and
inventoried all of the telephones at each location on the system on the property, and
looked at how the system was programmed in terms of how you could make a call out,
how you could receive a call. You know, the typical aspects of how the system would
work.
Q. And how many lines did you find that system included, how many different telephone
lines?
A. On the property, theres a total of 24 telephone lines or numbers, telephone numbers
that come onto the property. Of those 24 lines, there are eight lines thats connected to
the Merlin II system.

Q. Okay. And the remaining 24 -- I guess we have 16 lines remaining.

A. Correct.
Q. Tell me about those.
A. Theres one -- there was one line that was not -- that was not on the system of the
eight. There were 15 lines that were connected to modems or computers or, you know,
other things.
Q. Okay. Were all of those 15 lines being used?
A. They had dial tone. I dont know if they were being used. There was dial tone at what
we call the demarc. Some of them might have been used; some of them might not have
been used.
Q. What did you say, the demarc, or the -A. The demarcation point from Verizon.
Q. I see. And where is that located?
A. Thats located in the garage, where the telephone equipment was at.
Q. Did you have access to the entire property?
A. Yes.
Q. Did you visit the various outbuildings as well as the main residence?
A. Yes.
Q. Did you inspect the phones at each of those -A. Yes.
Q. -- locations?
A. Uh-huh.
Q. And did you inspect a phone that was located in whats known as Mr. Jacksons
personal bedroom?
A. Yes, sir.
MR. AUCHINCLOSS: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. AUCHINCLOSS: Mr. Green, I show you -- go ahead and help yourself to some
water.
A. Yeah, I appreciate that.
Q. I show you Peoples Exhibit No. 165. Can you identify that for me, please?
A. That is a Merlin 34 button telephone.
Q. Is that the phone that you saw that day?
A. Yes.
MR. AUCHINCLOSS: Okay. May I have the Elmo, Your Honor? Do you have that laser
pointer?
MR. SNEDDON: Yeah.
MR. AUCHINCLOSS: I believe this exhibits already in evidence, Your Honor. Am I correct
in that?
THE COURT: What number is it?
MR. AUCHINCLOSS: 165.
THE COURT: Yes.
MR. AUCHINCLOSS: All right. Thank you.
Q. All right. Mr. Green, can you just briefly describe for the jury how this telephone works?
A. Sure. This telephone -- okay. All right. You have -- if you lift the handset and you want
to make a call out, this system is programmed, what we call in the phone industry,
pooled. What I mean by that is all eight lines on the phone system, on all the other
phones on the property, they -- they are a ten-button phone, except this phone. On 4438

this phone, you have your telephone lines that are on each button here. Each of the eight
lines. So, if I -- from this telephone, I can manually push this black button right here, or
any of these black buttons, and I can manually select any one of the eight lines that I
want to make a call out on. On the -- I dont know if Im jumping ahead, but on the other
telephone sets, they dont have the lines that appear individually on a button. You just -you just press a pooled button, and the telephone system selects at random a line that
youre going to call out on. And you enter an account code and then you get a dial tone
and you make that outside call, and you can -- from the ranch.
Q. All right. So the other phones on the ranch -- well, let me start with, was there another
phone that had similar capabilities on the ranch?
A. Yes. There were two phones -- yes, there are two phones on the ranch that you could
select a line to call out on, or -- or listen in to a telephone conversation on. That other
telephone set was in the -- I would call it the administrative office on the ranch. Its a
larger console, large than this.
Q. Okay. And was that in a separate building from the main house?
A. Yes. Yes, it was.
Q. Can you tell me -- approximate its location in relation to the main house?
A. Yeah. It was in what I call the big administrative office. It wasnt a security office. It
was up the hill. It was the -- it was the administrative office, the best I know it.
Q. All right. Now, if I understand correctly, the other phones on the property, you could
not select which line you were going to use?
A. Correct. The other phones on the property looked just like this phone, except this row
and this row of buttons were not there. Its a ten-button phone. So it looked exactly like
this, minus -- if I could just draw down here, exit that off.
Q. Youre indicating the right-hand portion of the phone, those buttons were gone?
A. Correct.
Q. Now, but you still could not -- you have these eight buttons, or it looks like -A. The line buttons.
Q. Yeah, two lines of buttons on the left. They had those buttons?
A. Yes.
Q. Would that allow that person on a -- lets say in the guest room, would that allow that
person to select a particular line? 4440
A. No. No, all you could do is lift the handset, press the pooled button, and the phone
system would select a line.
Q. Okay.
A. The phone cabinet, Ill call it a CPU.
Q. You also mentioned that in order to get an outside line you needed to enter a code.
What did you mean by that?
A. An account code.
Q. All right.
A. The phone system was restricted to where you couldnt just pick it up, have dial tone
and place a call. You had to enter an account code.
Q. So if an individual did not have the account code, then it would be impossible for them
to talk to an outside party off the ranch?
A. Thats -- yes, to my knowledge. Uh-huh.
Q. All right. Now, can you tell me what the term barging means?
A. Yes, we referred to it in telephone -- its our term that I want to -- I want to join a
conversation thats in place or I want to listen to a conversation in place. Or in business,

since this is a business phone system, it was transferred for office business use, if I was
on line 1, and I wanted you to join me in that conversation, you could press the line 1
button, and you could join the conversation.
Q. Okay. So in a business setting, that would let a secretary barge in a conversation;
would that be a reasonable use -A. Yes, or -Q. -- in business?
A. Sure. Or join the conversation.
Q. All right. Did this phone have barging capabilities?
A. Yes.
Q. Could you listen to this phone surreptitiously, and I mean secretly without letting the
parties know that you were a third party listening in on that conversation?
A. Yes.
Q. And how would you do that?
A. Well, from this telephone, if I saw that somebody -- if a telephone (sic) on the property
was on the phone, I would see -- on one of these line buttons, I would see it lit. There
would be a red light lit. And so if I wanted to listen in on that conversation, all Id have to
do is press this black button, lift the handset, press this black button, and I could listen to
the conversation, because Ive got what we call line access. I can select the line I want to
listen in on on this. Or I could press the speakerphone button, and mute it, mute the
microphone, and press the line I wanted to listen in on. 4442
Q. All right. And if you -- well, let me strike that. Does that phone have instructions on
how to do that?
A. This phone right here?
Q. Yeah.
A. No. Not on the telephone it doesnt.
Q. All right. So if you didnt know how to do that, you wouldnt be able to barge in without
the other peoples knowledge, is that fair to say, if you didnt have some kind of idea
about how this phone worked?
A. True.
MR. SANGER: Im going to object. That calls for speculation.
THE COURT: Overruled. The answer was,True. Next question.
Q. BY MR. AUCHINCLOSS: And would it be any difficulty -- would there be any difficulty
in connecting a recording device to this phone?
MR. SANGER: Objection; that calls for speculation.
MR. AUCHINCLOSS: I think hes an expert in this area.
MR. SANGER: Then its vague as phrased.
THE COURT: Overruled. You may answer.
THE WITNESS: You could do that, yes.
Q. BY MR. AUCHINCLOSS: And I believe you said one of the ways you could listen in
was on the speakerphone?
A. Yes. If you didnt want to hold the handset, all you had to do is just press the
speakerphone, and then press the line button, and you could sit there and listen to the
conversation without -- hands-free without lifting the handset.
Q. Would you also want to hit the mute button?
A. You could also hit the mute button so that it mutes the microphone on this telephone,
so the caller that you are listening in on wouldnt hear any background noise.
Q. So they couldnt hear you breathing, or talking, or anything like that?

A. Correct. Correct.
Q. All right. Mr. Green, did you bring -- did you make a report in this case?
A. Yes. Yes, sir.
Q. Did you bring that with you today?
A. Yes, sir.
MR. AUCHINCLOSS: If I could just have a moment with counsel. (Off-the-record
discussion held at counsel table.)
Q. BY MR. AUCHINCLOSS: Mr. Green, I show you Peoples Exhibit 298.
A. Uh-huh.
Q. Is this a refined version of your report that you prepared in this case?
MR. SANGER: Well, Im going to object to that question.
MR. AUCHINCLOSS: All right.
Q. Can you identify this exhibit, then?
A. Yes. Those are the telephone numbers that I found on the property.
Q. All right. And there are two groupings of them. And Ill put this on the Elmo.
A. May I refer to my report?
Q. Yes, you may. Why dont you check and make sure that these are correct, the correct
numbers.
A. Uh-huh. Theyre right here.
Q. There is one additional number on there?
A. Yes.
Q. Was that the private number that you mentioned?
A. Correct. (Off-the-record discussion held at counsel table.)
Q. BY MR. AUCHINCLOSS: All right. Mr. Green, Im going to ask you to write that
private number on this exhibit at the bottom portion of it. All right. So does this list
contain a complete listing of all the telephone numbers that you found in the various
systems at Neverland Ranch?
A. Thats correct.
MR. AUCHINCLOSS: Ask to admit Peoples Exhibit 298 at this time, Your Honor.
MR. SANGER: Your Honor, Im going to object and Id like to approach on a very specific
issue, please.
THE COURT: All right. Ill sustain the objection at this point.
MR. AUCHINCLOSS: Okay.
Q. Mr. Green, may I have the copy of the report that you brought with you?
A. Yes.
MR. AUCHINCLOSS: All right. Im going to ask to have this marked as an exhibit as well.
Q. Mr. Green, I show you Exhibit No. 299.
A. Okay.
Q. Would you identify that for me, please?
THE COURT: Is that the new number?
MR. AUCHINCLOSS: Thats the new exhibit number, yes.
THE WITNESS: This is the report that I made on December 3rd from Neverland Ranch
and my inspection on the phone system.
Q. BY MR. AUCHINCLOSS: Is that a complete copy of your report?
A. Yes, sir.
Q. There appears to be some handwritten items on that particular report. Did you make
those notations?
A. Yes, sir, I did.

MR. SANGER: Im going to object on the grounds of relevancy and its hearsay.
MR. AUCHINCLOSS: Well, Im laying -THE COURT: Just a minute. Overruled. The answer was, Yes, I did.Next question.
Q. BY MR. AUCHINCLOSS: And did you prepare this report pursuant to your duties as
the president of Affordable Telephone Systems Incorporated?
A. Yes, I did.
Q. And have you prepared similar reports
concerning telephone systems as part of your duties at Affordable Telephone Systems?
A. Yes.
MR. SANGER: Im going to object; relevancy.
MR. AUCHINCLOSS: I can make an offer of proof, if you like.
THE COURT: Overruled.
Q. BY MR. AUCHINCLOSS: And so was this prepared during the course of your business
activities at Affordable Telephone Systems?
A. Yes, it was.
Q. Was this report prepared at or near the time of the event that you described in
analyzing this system and visiting Neverland Ranch?
A. Yes. I prepared -- you know, I prepared this information at the ranch as I was -- as I
was taking my notes.
Q. And then did you reduce it to a writing when you got back to your office?
A. Yes.
Q. As far as the handwritten notes on here, what do those designate?
MR. SANGER: Objection; calls for hearsay.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did you write those handwritten notes on there pursuant to
the information that you were preparing for this particular report?
A. Yes.
Q. Is it just some additional handwritten information pertaining to this particular report?
A. Yes.
MR. SANGER: Objection. Asked and answered; leading.
MR. AUCHINCLOSS: This is foundational.
THE COURT: The objection is overruled.
Q. BY MR. AUCHINCLOSS: Was it done pursuant to your preparation of this report as a
business record?
A. Yes.
Q. And was it also done at or near the time of the events that are on this -- reported on
this particular report?
A. Yes.
Q. Is this report trustworthy?
A. Yes.
MR. SANGER: Objection.
Q. BY MR. AUCHINCLOSS: Why do you say that?
THE COURT: Sustained.
MR. SANGER: Move to strike.
THE COURT: Stricken.
Q. BY MR. AUCHINCLOSS: Do you have a duty when you prepare these reports to
accurately depict the information that youve observed when you go out to the actual
location?

A. Yes.
MR. SANGER: Objection. Lack of foundation; and leading.
THE COURT: Sustained.
MR. AUCHINCLOSS: On which grounds?
THE COURT: Leading.
MR. AUCHINCLOSS: Its for foundation, Your Honor.
THE COURT: Well, your -- the objection was sustained. Ask your next question.
MR. AUCHINCLOSS: All right. Ask to admit No. 299 as a business record, Your Honor.
MR. SANGER: Objection. Hearsay; no foundation.
THE COURT: Im just trying to look at some of your earlier testimony. When did you go
out and make that report?
THE WITNESS: On December 3rd, 2004.
THE COURT: And who requested that you go out to make that report?
THE WITNESS: The Santa Barbara Sheriffs Department.
THE COURT: All right. Its not a business record. It was done in preparation of litigation
and its not admissible under the business records.
MR. AUCHINCLOSS: All right.
Q. Well do this -- this will take a little bit of time.
A. Okay.
Q. But I do need to get the information.
MR. SANGER: Excuse me, move to strike counsels remarks.
MR. AUCHINCLOSS: Thats fine. Ill go to the next question.
THE COURT: Wait a minute. Just a moment Ill strike the remarks.
Q. BY MR. AUCHINCLOSS: Tell me -THE COURT: You know, I dont like to have conferences, but I need -- I dont know what
the problem with this record is thats causing all this difficulty. So would you come up here
and tell me?
MR. AUCHINCLOSS: Yes. (Discussion held off the record at sidebar.)
THE COURT: Its amazing what a little conference will do occasionally here. The problem
which I didnt get, maybe you got, was that those are all Mr. Jacksons private phone
numbers, and he doesnt want to receive all of those telephone calls. So that was the only
problem. And so were going to work with this as best we can, as long as we can, without
revealing his personal phone numbers. And I dont know if well succeed in doing that, but
thats what were going to try to do here.
MR. AUCHINCLOSS: And thats fine, Your Honor. The People would seek -- ask to admit
at this time Exhibit No. 298.
MR. SANGER: And I dont have an objection to the foundation being laid for 298, but Id
ask the Court just procedurally to delay receiving it until we work this out.
THE COURT: Theyre having trouble in the back hearing you.
MR. SANGER: Im sorry, the things turned off.Yes, Your Honor, I was just saying I dont
have any objection to the foundation for 298 based on this witnesss testimony at this
point. Id just ask the Court to delay receiving it in evidence until we work out the details.
THE COURT: Okay.
MR. AUCHINCLOSS: And thats fine.
THE COURT: Ill make that ruling; that the parties agree that the foundation is laid, and
well not admit it at this point until we can do something with the phone numbers.
MR. AUCHINCLOSS: Thats fine. Thank you, Your Honor. No further questions.
MR. SANGER: May I proceed, Your Honor?

THE COURT: Yes.

MR. SANGER: Okay.
CROSS-EXAMINATION BY MR. SANGER:
Q. Mr. Green, how are you?
A. Good. Pretty good.
Q. All right. Lets just clear up a couple things right off the bat here. First of all, this phone
system, this Merlin phone system that you saw at Neverland Ranch, is a fairly standard
business kind of phone system, correct?
A. Thats correct.
Q. And the Merlin phone system that you saw, that particular configuration, was really one
that was developed and used primarily in the 1980s; is that correct?
A. Thats correct.
Q. Phone systems have actually progressed quite a bit farther than what you see there,
right?
A. Thats correct.
Q. And thats the kind of phone system that in the late 80s you might have found in
executive offices, insurance companies, lawyers, and so on; is that correct?
A. Thats correct.
Q. All right.
A. It was designed for business use.
Q. And in your experience with Affordable Telephone Systems in Ventura, have you had
occasion over the last 20 years to install phone systems on large estates?
A. Yes. Yes, I have.
Q. Have you ever installed a phone system on an estate as large as Mr. Jacksons?
A. No.
Q. Okay. Have you installed a phone system on an estate that involved a working ranch?
A. I probably have. I dont recall at this point.
Q. Okay. What Im getting at is, where you have a number of operations going on besides
a residence, is there anything unusual about seeing a business kind of telephone system
on a working ranch?
A. Oh, no. Not at all. Its -- no.
Q. Okay. And what you might do, I think youre doing okay, but try to talk real close to
the microphone there.
A. Okay.
Q. Because it is hard for everybody to hear. All right. And particularly with regard to the
Merlin system, it would not be unusual to see a Merlin system like that installed in a
working ranch somewhere in the 1980s, correct?
A. No, not at all.
Q. And the fact that this phone system has not been switched out for a brand-new system
is also not unusual; is that correct?
A. Not at all.
Q. All right. So you would expect at working ranches and other business locations that
there are probably some Merlin systems still around; is that correct?
A. Oh, sure. Hundreds, thousands.
Q. All right. Now, you mentioned that -- you were asked, is it possible to attach a
recording device to this telephone system, correct?

A. Yes.
Q. Did you see a recording device attached to this telephone system?
A. No.
Q. All right. And in fact, its possible to attach a recording device to just about any
26 telephone system, correct?
A. Thats correct.
Q. All right. So theres nothing in particular that makes this phone system any more
susceptible to being attached to a recording device than any other, correct?
A. No.
Q. Now, another thing we talked about here was being able to pick up a line thats either
in use or not in use on this particular phone, correct?
A. Correct.
Q. In a typical telephone installation in a home, where you have more than one extension,
is it usually possible to pick up a line thats in use in the system?
A. Yes.
Q. So people who have two or three extension phones in their home generally have just
exactly that system. You pick it up -- if its in use in the kitchen and you pick it up in the
bedroom, you can listen in, right?
A. Yes.
Q. Home systems that have more than one line often have that same capability. You can
pick up line 1 -- lets say you have two lines. You can pick up line 1 or line 2 if its in use,
correct?
A. Correct.
Q. All right. Now, the history of business phones, without going into unnecessary detail,
before Merlin involved a couple of different kinds of technology I want to go over with you,
okay? The first one is, for those of us old enough to remember all this, it involved the
business phones that had the four, five lines with the buttons at the bottom and a hold
button at the end, correct?
A. Correct.
Q. And there might be actually an intercom button on one end, and the hold button on
the end, correct?
A. Correct.
Q. And under those old systems, if anybody in the property that was governed by this
phone system, whether it be a residence, a ranch or a business, if anybody was on line 1,
everybody else on the phone system could see that from their phone, correct?
A. That is correct.
Q. And they could just push the button and pick it up, and theyd be on line 1, and they
could listen in, correct?
A. Thats correct.
Q. Okay. Now, in those days, there were speakerphones, somewhat primitive, as I recall.
But it would also be possible to put a call on a speakerphone that same way and listen,
correct?
A. Correct.
MR. AUCHINCLOSS: Im going to object. Its irrelevant to phone systems that existed
before this phone line.
THE COURT: Overruled.
MR. SANGER: Thank you.
Q. After that -- let me withdraw that. At the same time as that more rudimentary system

existed there was the PBX system; is that correct?

A. Right, there were two types. After that, the equipment that youre describing was called
1A key. And then they developed a key system and a PBX system at the same time. The
PBX was simply a larger model of a key system.
Q. Okay. And the PBX system continued into existence into the 1980s, correct?
A. Yes, and its still today. Uh-huh.
Q. PBX system would allow an operator to answer the phone, and then switch the calls
from one place to another throughout the system, correct?
A. Correct. Or an individual could do it.
Q. All right. When the hybrid key system came along, which is the Merlin system, correct?
A. Correct.
Q. It was a system that allowed more flexibility than the PBX system, correct?
A. Yes.
Q. So it would allow a -- it would allow you to have a master console -- or in this case you
have a master console and you have sort of a junior master console, right?
A. Thats correct.
Q. And the junior master console was the one that was found in Mr. Jacksons living room
area of the first floor of his bedroom suite, correct?
A. Thats correct.
Q. And that allowed people to answer the phone
at different locations; is that correct?
A. Back up there. You lost me.
Q. You could answer the phone in the administration building with the big console, right?
A. That is correct.
Q. And you could join phone calls from one point to another?
A. That is correct.
Q. And to the extent that you have the eight lines here, you could do the same with this
phone, is that right?
A. That is correct.
Q. Now, since that time, technology has continued to march on, since the 80s, I take it,
correct?
A. That is correct.
Q. And I dont want to go into all the details, but there are more sophisticated telephone
systems that are much simpler than this, so you dont have to have all these buttons in
order to make them work, right?
A. Thats correct.
Q. Now, you mentioned that there were eight lines that were on the direct system -- well,
let me withdraw that. There were eight lines that were on this system that could be used
by people in Mr. Jacksons house; is that correct?
A. Thats correct.
Q. You examined the phone equipment throughout his house; is that right?
A. Yes, I did.
Q. And you noticed that were extension phones?
A. Yes.
Q. Okay. And by the extension phone, were talking about the phones that simply had
buttons that allowed you to pick up and get an available line?
A. Thats correct. Ten -- the other phones were ten-button phones.
Q. All right. And those phones could also receive a call if somebody were to direct it to

that particular extension; is that right?

A. That is correct.
Q. So if somebody answered the phone, they could say, I want to put this call through to
the library, because I believe Mr. Jacksons in his library and its for him, so Ill connect it
to the library, right?
A. Right, they could -- yes, they could transfer the call to the library, yes.
Q. All right. And the phones that were at the ranch were at various locations throughout
the house -A. Yes.
Q. -- correct? In the childrens living area; is that right?
A. Yes.
Q. The library?
A. Yes.
Q. The kitchen?
A. Yes.
Q. The maids room?
A. Yes.
Q. The maids break room. And then on into Mr. Jacksons personal office in the adjoining
building?
A. Yes.
Q. The security office at the end of that building; is that correct?
A. Yes, sir.
Q. Upstairs in the video library?
A. Yes, sir.
Q. All right. And you could also get the -- or the phone system also included the front
gate, the little guard house at the front gate; is that correct?
A. I didnt examine that. Im sure it did. Im sure there was a phone out there, but 1 didnt
-Q. You mentioned an administration building, which was up on the top of the hill, correct?
A. Yes.
Q. So it was outside the manicured lawn area that surrounded Mr. Jacksons private
residence; is that correct?
A. Thats correct.
Q. And the administration building also is the fire department, they have a fire truck up
there?
A. I believe so. I believe so.
Q. So you had phone capability in the administration building for the various
administrators, the fire department, and so on, is that correct?
A. Yes.
Q. The administration building, theres an executive assistant or staff person up there who
had a desk in the main administration building, correct?
A. Yes.
Q. And that desk is where the main console existed for this phone system; is that right?
A. Yes.
Q. All right. Now, in the -- you mentioned that you needed to have some kind of code to
call out; is that correct?
A. Yes.
Q. Is that unusual for a Merlin system?

A. No. Its quite common.

Q. All right. So many systems you have to push 9 to call out?
A. Some you have to press 9. And an account code is -- is able to be programmed in so
that you can eliminate phone abuse. People -- unauthorized people making calls you dont
want to make calls on your phone system.
Q. Now, you were out there with sheriffs who had a search warrant, correct?
A. Yes, thats correct.
Q. So you were not chatting with the -- with Mr. Jackson, I imagine?
A. That is correct.
Q. Okay. And you werent chatting with his staff about how they set the phone system up
or how it was set up when they -A. Thats correct.
Q. -- first came to work at the ranch?
A. Thats correct.
Q. So you werent able to determine whether or not there were separate account numbers
or there was just one number that everybody was given to get an outside line?
A. Thats correct.
Q. All right.
MR. AUCHINCLOSS: Objection; assumes everyone was given a number.
THE COURT: Overruled.
MR. SANGER: Did the answer -- I think the answer came in.
THE COURT: It did. He said, Thats correct.
Q. BY MR. SANGER: So based on your analysis of this system, there could have been
one number that would allow anybody on this Merlin phone system, wherever the
extensions were throughout the ranch, it would allow somebody to hit the number, and
get an outside line, correct?
A. Thats correct.
Q. All right. Did you determine -- let me withdraw that. So if somebody were able to make
a phone call to an outside number, for instance, somebody were able to call their, lets
say, boyfriend in Los Angeles from this phone, if they did it unassisted, they would have to
have the code, whatever it was, to get that outside line, correct?
A. Not from this phone. But from all the other phones, yes.
Q. Okay. Okay. Good point. Thank you. Im talking about the extension phones, and I
guess Im pointing to that one.
A. Yes.
Q. But this phone, you can just pick up an outside line, correct?
A. Uh-huh.
Q. And well come back to that. But as far as the extension phones are concerned, the
ones that -- other than the administration building and this phone, if you want to get an
outside line, you put in whatever the code is -A. Correct.
Q. -- one number, or two numbers, or whatever it is?
A. Correct.
Q. You get the outside line and then you can call wherever you want, right?
A. Thats correct.
Q. All right. So if somebody were, say, on an extension phone at someplace on the ranch
and they were able to call, as I say, for instance, their boyfriend in Los Angeles, you would
expect that they would know how to enter that code to get the outside line, correct?

A. Yes.
Q. And if somebody could enter that code and get an outside line to call their boyfriend in
Los Angeles, they could enter that code, get an outside line, and call 9-1-1, correct?
A. Yes.
Q. Theres no restriction on calling 9-1-1 from any phone in this phone system other than
simply knowing the code to call out, correct?
A. Yes.
MR. SANGER: If I could have just one moment, Your Honor.
Q. By the way, you mentioned the eight numbers, and then you said there were 16 other
numbers, one of which was a direct line to Mr. Jacksons area in whats called the
bathroom, but theres a sitting area and all that off the main floor -A. Uh-huh.
Q. -- of the bedroom, correct?
A. Uh-huh.
Q. Other than that direct number, did you ever figure out where on the ranch those other
numbers, the other 15 numbers went?
A. No.
Q. So when you say they came into the main -- you didnt say switch box, and Im going
to say that and Im sure its wrong, but the main -- what did you call the telephone closet?
A. Demarc. Verizons telephone demarc.
Q. Okay. So the lines come in from off the property, from the telephone lines off the
property that service the rest of the world, and they come in to the property, anybodys
property, they come in to a telephone box or telephone closet, correct?
A. Uh-huh.
Q. And thats what youre calling the demarc?
A. Correct.
Q. And you know that these other 15 lines came in there, you just never traced them out
to see exactly where they went, correct?
A. Correct. We put -- I made sure that they had actual dial tone and -- on the block. And
from my test set, you know, I have a code that I can dial and -- when I hear dial tone,
and I can get a recording from the phone company that tells me what that telephone
number is. So I verified that those -- that those telephone numbers Mr. Jackson was being
billed for those telephone numbers, he had live dial tone. Now, where it went, I dont
know.
Q. In other words, you take your phone -- you have a headset that has clips on it?
A. Called a butt set.
Q. All right.
A. Its a lineman -- a linemans test set.
Q. A linemans test set, okay. And you simply clip that onto a line, correct, and then you
dial a number, which we wont say, because everybody will go home and do it?
A. Right.
Q. And it will automatically - its kind of cool - automatically tell you what phone number
that is, right?
A. Exactly.
Q. And you verified that these are, in fact, phone numbers coming into the property, you
just 4466 never traced them to see exactly whatever phones there were, if any, that were
hooked up to them?
A. Right, they werent in the phone system.

Q. They were not in the Merlin phone system?

A. Correct.
Q. But you dont know if there was another phone someplace, at the zoo, or someplace
else that -A. Thats correct.
Q. -- that might have had that number. All right. Okay. I have no further questions. Thank
you.
REDIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. Mr. Green, did you go to the various outbuildings and check all the phones?
A. Yes. We checked the -- we looked for phones in the -- in all of the buildings. And the
only phones that we saw were the Merlin ten-button phones.
Q. Okay.
A. We didnt see any other phones that werent of the Merlin phone system.
Q. All right. So based on your inspection of the property, all the phones were hooked into
the Merlin system, with the exception of the 15 which you couldnt find a location for?
4467
A. Those 15 lines. They could have been connected.
Q. And you had one private line?
A. Thats correct. They could have been connected to computers, other types of devices.
Security. Im sure some of those lines were security lines connected to the security
companies, et cetera, et cetera. But we were not able to gain any information as to what
they were connected to.
Q. Okay. And when you say security, do you mean telephone lines as security or some
kind of computer or alarm line?
A. Alarm line. Computer. You know, for dialing out on the Internet. You know, anything
that took a telephone line.
Q. But not something you communicate on in the normal telephone fashion, talk to
somebody on?
A. Well, they could have been used for that. They could have been. They could have been
used for a computer to dial out to the Internet. They could have been used for the alarm
lines for the security system that Mr. Jackson had on the ranch.
Q. Okay. But you didnt find a source for that?
A. No. And they might not have been connected to anything.
Q. All right. Now, just as far as the exhibit that weve admitted here, there appears to be
eight
1 numbers at the top of this exhibit.
A. Yes.
Q. Which are those numbers for?
A. Those are the telephone lines connected to the Merlin system at Neverland Ranch.
Q. And then theres -- below that there appear to be 15 lines. Those are the ones that you
just talked about -A. Right.
Q. -- that dont hook into the Merlin system?
A. Right, those are the wild lines.
Q. And the handwritten one on the bottom is the private line?
A. Right. Thats Mr. Jacksons private phone.

Q. And where did you find that phone that was hooked into a private line?
A. That phone was in his rooming quarters downstairs in the bathroom to the left where
the closet was.
Q. Okay. And this phone was also in the downstairs area?
A. Yes. In the same -- in the same place.
Q. Same general vicinity?
A. Correct.
Q. Was this in the bathroom? If you recall.
A. No, I think it was just outside the bathroom door.
Q. All right
A. Just right outside the bathroom door.
Q. All right. Now -THE COURT: Counsel, take our break.
MR. AUCHINCLOSS: Very good
THE COURT: Go ahead.
MR. AUCHINCLOSS: Thank you, Your Honor.
Q. Mr. Green, when was the last year that the Merlin II system was made, if you know?
A. I can speculate. I dont know the exact date.
Q. Can you approximate?
A. Yes. It was taken out of production in probably the early 90s. 92, 93, maybe 94.
Q. And as far as the lines that weve talked about, those eight lines, if an individual called
from outside Neverland, called one of those eight numbers, where would that phone ring,
or where could it ring, maybe to begin with that question?
A. Okay. It could ring at the 34-button in Mr. Jacksons living quarters -Q. Okay.
A. -- at the console.
Q. All right.
A. And it could be programmed also to ring at any of the other telephones, if it was
programmed to ring there. So it could ring at every single telephone, or only at one or
two. Typically, it rings at the console, or the -- or the 34-button phone. But it could ring -and you could do that on a line-by-line basis.
Q. Okay. And do you know how this particular phone system was set up in terms of
incoming calls? 4476
A. No, because we werent allowed to have any incoming calls ring in so we could test
that.
Q. And -- but typically it would be either the console or the 34-button phone?
A. Yes. On a -- on an estate situation, you know, usually the calls are screened. They
come into the console and are screened and then transferred to wherever they want to
go.
Q. Mr. Sanger used the example of a home phone system as far as similarity regarding
listening in to a phone conversation.
A. Yes.
Q. Is this phone system really similar in terms of its barging capabilities?
MR. SANGER: Objection, leading, Your Honor; argumentative.
THE COURT: Overruled. You may answer.
THE WITNESS: Its different in that on the Merlin system, if you were barging in on -- in
youre barging in on a call, the caller on the -- the person on the other phone would not
know that you were -- there would be no audio knowledge that they were being listened

to.
Q. BY MR. AUCHINCLOSS: So you could listen secretly without any input, audio input,
on the
phone line?
A. Correct.
Q. And at a home system, when someone picks up the phone and is listening in, is there
typically some audio input that is noticeable to the other two parties that are conversing?
A. More so, uh-huh.
Q. And would the mute button also contribute to the secrecy of listening to those calls?
A. If you were using the speakerphone, yes.
Q. Does the mute button also work on the handset microphone?
A. No.
Q. Okay. So just on the speakerphone.
A. Yes.
Q. As far as other peoples ability to listen in on your conversations, does this system -- is
this system set up where any of the outside lines at Neverland, and I mean just the lines
that dont involve either the 34-button phone or the phone at the office, could any of
those lines listen in?
A. No.
Q. So would that be another dissimilarity between home systems and this system?
MR. SANGER: Objection. Leading, Your Honor. THE COURT: Its overruled. You may
answer.
THE WITNESS: No, because you would have no way on the other phones of selecting the
line, no.It has privacy. You couldnt -- from any of those other phones, you couldnt listen
in on another conversation.
MR. AUCHINCLOSS: All right. Thank you. I have no further questions.
RECROSS-EXAMINATIONBY MR. SANGER:
Q. Okay. Just a few. First of all, you could listen in on other lines on the phone system
from the console in the administration building, correct?
A. Thats correct.
Q. And that console is pretty much out in the open, there, in the staff area of the
administration office, correct?
MR. AUCHINCLOSS: Objection. Assumes facts; and no foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: Well, it was -- when I inspected it, it was in a locked office.
Q. BY MR. SANGER: When you say a locked office, though, the administration building,
the lock was on the front door of the administration building, correct?
A. No, theres an office inside the administration building, as I call it. I dont know if Im,
you know, using the right terminology, but there was an office inside there that was
locked.
Q. Thats your recollection?
A. Yes.
Q. Did you take a picture of this?
A. The detective had to have the ranch manager unlock the door for us to go in.
Q. All right. And it was -- there was a desk, somebody working at this area, correct?
A. There was no one in there.

Q. Im sorry?
A. There could have been. There was no one in there at that time.
Q. Let me ask the question again, just so were clear. It appeared to be a working area
where somebody had a desk, correct?
A. Thats correct, yes.
Q. And the point is, whoever had access to that phone would be able to listen in on phone
calls as well; is that correct?
A. Yes, thats correct.
Q. And you would expect -- from your testimony, you would expect that thats one of the
places that the phone would ring so that phone calls could be directed throughout the
ranch, correct?
A. Yes. The lines all had to ring at the console. That was a must.
Q. All right. So not only could ring there, but you believe it did ring there at that console
in the administration building, correct?
A. Yes.
Q. The phone in Mr. Jacksons -- what we call -- its a blank screen, Im kind of pointing
randomly here. The phone that was up on the board, what we call a junior console in Mr.
Jacksons living area, the phone did not ring there; is that correct, sir?
A. I dont know, because we didnt test any incoming calls.
Q. All right. And you can -- as you said, you can program any of the other phones to -- to
be able to answer the phone from that location; is that correct?
A. That is correct.
Q. So if there was a phone, for instance, in that guard shack -- you said you didnt go
down and look, but assume there was a phone there that appeared to be one of the
extension phones, you could program that phone to ring so that the person at the guard
shack could answer the phone there, correct?
A. That is correct, yes, sir.
Q. All right. You indicated these phones werelast made in the early 90s, correct?
A. Yes.
Q. But there are replacement parts and replacement phones that can be obtained if your
equipment breaks down?
A. Yes, theres still refurbished equipment out there. You know, it -- theres millions of
Merlin systems out there that was produced. It was the most widely sold telephone
system in the world, and theres readily available parts.
Q. Okay. And the most widely phone system --sold system in the world, this Merlin
system, had that mute capability on all of the phones that were sold throughout the
world, correct, if they were -A. Yes.
Q. -- if they were this kind?
A. If you were on the speakerphone.
Q. Yeah, the speakerphone had a mute.
A. That is correct.
Q. Now, almost all office or commercial kinds of telephone systems today, in fact, have
thatmute button; is that right?
A. Yes. Oh, yes.
Q. So theres nothing nefarious about themute button, is there?
A. No, no, its standard.
Q. All right. Thank you. You did mention one other thing. You said something about an

alarm system. Did you determine whether or not there was an alarm system in place at
Neverland?
A. There was an alarm panel in the garage. And, you know, I did not go in to the alarm
system to see what lines were attached to it, no.
Q. All right.
A. That wasnt my area of responsibility.
Q. I understand. In your work in the telephone industry and as a -- the president of a
telephone company in Ventura, do you have occasion to work with alarm companies when
they install -A. Yes.
Q. -- alarm systems? And I think what we need to do, Ive got to avoid talking over you.
And if you could wait just an extra beat before you answer, otherwise the court reporter
gets her fingers caught in the keys there.
A. Okay.
Q. When you work with an alarm system -- let me back up. When you go out to install a
phone system at the same time that an alarm system is being put in place, do you work
with the alarm company?
A. We do.
Q. All right. And one of the things that you often do is make sure that they have a
telephone line, a secure telephone line, so that the alarm system can automatically call
out to the alarm company or to a law enforcement agency; is that correct?
A. Thats correct.
Q. All right. And so you saw some phone lines that you thought the phone lines might -- in
fact, one or more of them might be associated with the alarm function at the ranch; is
that correct?
A. Thats correct.
Q. And based on your experience in installing telephone systems, is there anything
unusual, in a large ranch property, for the owner of the property to have an alarm system
hooked up to the telephone system?
A. No, you wouldnt have it hooked up to the telephone system. You would have a
telephone line hooked up to the alarm system.
Q. Okay. Im sorry.
A. But you wouldnt have -Q. Let me withdraw that so I dont make it any more complicated. I understand what
youre saying. So, what I meant was, have the alarm system hooked up to a telephone
line. Youve restated it correctly. Is there anything unusual, in a large ranch operation,
whereby the owner of the property has an alarm system hooked up to a telephone line
that goes off the property?
A. No.
Q. And youve seen that. Youve seen that in your work, correct?
A. Yes.
Q. Is there anything unusual about the owner and the family having an alarm system
around the immediate area where they reside to secure their own personal safety where
they are living?
A. No.
Q. So you see that from time to time, that there will be a system thats set up in the living
quarters actually where the family resides; is that correct?
A. Yes.

MR. SANGER: All right. Okay. No further questions.

MR. AUCHINCLOSS: Just one further question.
THE COURT: Yes.
FURTHER REDIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. Mr. Green, as far as this barging system works in the Merlin system as compared to a
home system, is this barging system different only in the fact that it has a mute button,
or is there an additional feature that allows you to secretly listen to other phone calls?
MR. SANGER: Objection. Thats compound; leading; and beyond the scope of cross,
recross.
THE COURT: Overruled. You may answer.
THE WITNESS: There is a bit of a difference. On the Merlin system, if I barge in,
the party that I barge in to cannot see any light, any visual indication or audio indication
that I am listening, unless he hears some background noise in the back of me, or he hears
me breathing.
Q. BY MR. AUCHINCLOSS: So there wont be a click?
A. There wont be a click. There wont be anything.
MR. AUCHINCLOSS: All right. Thank you. I have no further questions.
FURTHER RECROSS-EXAMINATION BY MR. SANGER:
Q. Oh, and on that -- if I may, Your Honor -- theres no reason -- you have absolutely no
information to suggest that this phone system was installed for the purpose of listening in
on other people, do you?
A. No, sir.
Q. In fact, it looks like a phone system that was installed sometime in the late 80s and
has just been maintained there on this property ever since, correct?
A. Yes.
MR. SANGER: Okay. Thank you. No further questions.
MR. AUCHINCLOSS: No further questions.
THE COURT: You may step down. Thank you.

LARRY FELDMAN EXAMINATION

DIRECT EXAMINATION BY MR. SNEDDON:

Q. Youre an attorney licensed -A. Right.
Q. -- to practice law in California?
A. I am.
Q. And how long have you been an attorney?
A. Since .
Q. And would you share with the ladies and gentlemen of the jury your academic
preparation to become a lawyer. Spare us the high school part. Just -A. I went to -- ultimately graduated from Cal-State Northridge, where Im proud to say
Im getting the Alumni of the Year Award this year. And thereafter I went to Loyola
University in Los Angeles, where I graduated in 1969 as the editor-in-chief for The Law
Review and No. 1 in my class.
Q. All right. And I assume you took and passed the bar?
A. I took and passed the bar.
Q. And in your practice, where are you currently employed?
A. Currently, I am at a law firm called Kaye, Scholer. K-a-y-e, S-c-h-o-l-e-r. It is in
Century City in Los Angeles.
Q. And does it have offices in other locations?
A. It does. All over the world. Its main office is in New York, but it has offices in 4488
Shanghai, and Washington D.C., Chicago, Los Angeles. Im probably forgetting some.
Q. What is the lawyer size of the firm?
A. About 600 lawyers.
Q. Now, prior to the time that you -- how long have you been with Kaye, Scholer?
A. Since January of 2004.
Q. And prior to that, what firm were you associated with?
A. Prior to that, I had my own law firm, which had different names from the time I joined
it right out of law school. But ultimately when -- as of January 2004, it was Fogel,

Feldman, Ostrov, Ringler & Clemens.

Q. And were you the senior partner of that firm at that time?
A. I was the head of that law firm.
Q. Just give the ladies and gentlemen of the jury some idea of the type of practice of law
that youre involved in.
A. I have been a trial lawyer all of my life. I started in this firm that I ultimately was the
senior partner of right out of law school. I started trying primarily cases for injured federal
workers, railroad workers and seamen. It was called The Federal Employers Liability Act,
and The Jones Act. And I did other kinds of, like, automobile cases, but very rarely. It was
-- primarily I practiced a lot in federal court, some in state court, and tried a lot of cases
in those years. And then slowly but surely my practice developed. I started doing a much
broader array of cases, from representing labor unions, to representing people involved in
wrongful discharge cases, African-Americans who had been discriminated against big
companies. Currently, right now, representing a class action in Washington D.C., the
largest class action of African-Americans who have not been promoted appropriately. I
represent -- on the other side of the coin, I represent the Oakland Raiders in their many
courtroom battles. I represent -- I have represented a lot of entertainment people suing
studios. I have defended studios. I have
represented individual people who have legal malpractice claims against lawyers. And I
have defended lawyers who have been accused of malpractice. I have sued rock groups
and defended rock groups. And so my practice really has grown from what it once was
into an array of cases, from really getting, at this stage of my life, some wonderful cases
to handle as a lawyer.
Q. And did you, at one time, represent the late Johnnie Cochran?
A. I did represent Johnnie Cochran for ten 4490 years in a legal matter from the day, or
thereabouts, when he became involved in O.J. Simpson till the end of that. Till 2000 and - January 2004 I represented Johnnie.
Q. What professional organizations have you been associated with and participated in?
A. I was the president of the Los Angeles County Bar Association. I was the president of
the Los Angeles Trial Lawyers Association. I was an officer in the American Board of Trial
Advocates, which is an organization that you have to be invited into and have to have a
certain skill level in trials and in representing people. I am what they call a Fellow of the
American College of Trial Lawyers, which is limited to 1 percent of the lawyers in the
United States. Another organization that you have to be invited into to get into. The
International Academy of Trial Lawyers, where I am -- which is limited to the top 500
lawyers, theoretically, in the world. I mean, I dont know whos making these judgments,
but thats sort of -Q. Its nice to be invited, even though you dont understand the standards.
A. Its one club you want to be invited into. But Im sure theres somebody else who
deserves to be in this club who for some reason doesnt get in. 4491
Q. And are there some committees that you operate in on a statewide basis?
A. Yes. Ive been appointed to -- by the governor to assist in selecting judges for the
Southern California area. I have been appointed by the chief justice of the California
Supreme Court, both chief justices, Malcolm Lucas, who was the chief justice originally,
who had a blue ribbon committee of lawyers throughout the state, with judges, who are
trying to improve the system of justice for -- so there would be better access to the Court
for people. Fancy people, big corporations, dont have any problems using the courts. But
little people have a lot of trouble getting through these courts, and the chief justice had a

committee, as we moved into the millenium, to try to figure out how to better access
courts for individuals who couldnt higher fancy lawyers. And then just recently the current
chief justice of the Supreme Court asked me to be on a committee to help with the
discipline of lawyers. There is a lot of criticisms that lawyers who shouldpublic doesnt feel
like were disciplining our own lawyers. And the State Bar is in charge of this system as it
exists right now. And there are these 4492 State Bar judges who judge it, and theres -Ive been asked to be on this committee to look at these issues and try to develop a better
system for making sure that lawyers who need to be punished are punished and that we
have the right people in place who can punish them appropriately.
Q. And have you done some teaching in your spare time?
A. In my spare time, when Im not in Santa Maria testifying, I do. I am -- I taught last
week at Loyola. I do a lot of teaching to judges, to lawyers, to law students, on different
things about the law, from ethics, to how to try a lawsuit, a whole potpourri of different
things. Ive written a lot about -- articles and chapters in books about how to try lawsuits
or some aspect of some part of a case that I may have tried.
Q. Lets turn to a specific case, if we can, and Id like to focus your attention to the year
1993 and 94, if we can. Are you familiar with a then young boy by the name of Jordan
Chandler?
A. I am.
Q. And how did you become involved -- by the way, did you know -- when you first met
Jordan Chandler, do you recall how old he was?
A. He was 13, as I recall.
Q. And how did you become involved with Jordan Chandler? Tell us.
MR. MESEREAU: Objection to the extent it calls for hearsay.
THE COURT: Calls for a narrative, sustained.
Q. BY MR. SNEDDON: Well, describe to us, then, the first contact you had with regard to
Jordan Chandler.
A. A lawyer -MR. MESEREAU: Same objection. To the extent it calls for hearsay, Im going to object.
THE COURT: Overruled. You may answer.
THE WITNESS: A lawyer in the community referred his -- the parents, and -- are we
using his name?
Q. BY MR. SNEDDON: Yeah.
A. Were using his name?
Q. Jordan Chandler, yeah.
A. Okay. Who used Jordie -- who brought Jordie to me, a lawyer who was representing the
father of Jordie at the time. If I recall, Jordie was being represented at the time, for like
20 minutes or so, by Gloria Allred. They wanted to switch lawyers. And he asked me to
interview the family, and I did.
Q. And as a result of the interviews and what other actions you also took, did you
eventually end up filing a lawsuit against the defendant in this case, Michael Jackson?
A. I did.
Q. On behalf of Jordan Chandler?
A. I did file a lawsuit.
Q. On behalf of the family also, members of the family?
A. You know, without seeing the lawsuit, the mother and father, if I recall correctly -- I
could be wrong about this, without seeing the lawsuit. I thought the mother and father
were just the guardians and didnt have their own claims that we asserted. I dont think

we ever asserted any claims on behalf of the mother and mother. We just asserted them
on behalf of Jordie. And the parents in the Chandler case were divorced, and there was a
lot of acrimony between mom and dad, and in order to keep peace between mom and
dad, I came up with the idea that there should be a joint guardianship, and I think we
took -- thats what we did.
Q. All right. With regard to that particular case, which would have been, I guess, Chandler
versus Jackson, correct?
A. It was.
Q. That would have been the heading? You did file a formal lawsuit?
A. I did.
Q. And what jurisdiction was that lawsuit filed?
A. Los Angeles Superior Court.
Q. And in that particular lawsuit, do you remember how many causes of action you
alleged?
A. I think seven, roughly seven causes of action.
MR. MESEREAU: Relevance, Your Honor.
THE COURT: Overruled. You may proceed.
Q. BY MR. SNEDDON: And with regard to the causes of action, what was the nature of
the causes of action alleged against the defendant Mr. Jackson?
A. The sexual molestation of Jordie Chandler.
Q. Now, did that particular case, the case of Chandler versus Jackson, eventually result in
a settlement?
A. There was.
Q. And with regard to that particular settlement, was there a particular form that the
settlement took?
A. Form meaning a contract?
Q. Well, a contract or some other document to -A. Yeah, there was a lot of documents that surrounded that settlement.
Q. And with regard to the settlement, was it -- youve heard - Im sure youre familiar
more than I am - the term confession of judgment?
A. Yes.
Q. Was that particular form of document used in the settlement of the Chandler versus
Jackson lawsuit?
MR. MESEREAU: Objection; relevance.
THE COURT: Whats the relevance, Counsel?
MR. SNEDDON: The form of the settlement in terms -- I mean, the form of the
settlement -- do you want me to go ahead and speak out, or do you want to approach the
bench?
THE COURT: I asked you the question.
MR. SNEDDON: All right. Then as I understand it, there are settlements that are done by
way of contract, and there are settlements that are done by way of confession of
judgment.
THE COURT: Whats the relevancy?
MR. SNEDDON: The legal effect of the judgment, plus the -THE COURT: All right. You may ask the question.
Q. BY MR. SNEDDON: All right. Im -- youre far more capable than I am of delineating
the differences, but is there a difference between a civil settlement that results from a

contract and one that results from a confession of judgment?

A. Yes.
Q. All right. Would you explain to the jury what the difference is and what the legal effect
is?
A. Yes. In a confession of judgment, it is as 4497 though we went to trial and had a
lawsuit and the jury came back with a verdict and we had a judgment, or the Judge came
back with a finding. And when the Judge says somebodys at fault, and Heres your
damages, you put it into a judgment. And when you have a judgment, you can file that
judgment in the county and then you can execute on that judgment, so that if -- and just
as an example, and Ill just make this number up, lets say you had it for one dollar, a
judgment for a dollar. Well, if you have a judgment, you could just go and take
somebodys house or take somebodys car, or go to their bank account and literally take
that dollar out to satisfy the judgment. If you just have a release or a contract, then you - all you get left with, if the person doesnt pay you the dollar, is a something that says, I
promise to pay you a dollar. And then you got to start all over and prove that person
breached that contract. So in the Michael Jackson case, because there were payments
going to take place -Q. Lets stay away from all that area, okay? Just tell us about -A. All right. Well, thats the best I can tell you the difference.
Q. All right. So -- but in the Michael Jackson case, you got a confession of judgment?
4498
A. I got a confession of judgment.
Q. Now, with regard to the case of Chandler versus Jackson, all right -A. Yes.
Q. -- you told us the causes of action involved child molestation, correct?
A. Correct.
Q. Had you handled other child molestation cases prior to the Chandler versus Jackson
case?
A. The answer is, to the best of my recollection, I had never handled a -- what I would call
a civil child molestation case sexually. If what youre asking -- I dont want to -- I did
handle, on the defense side, a family that was accused of abuse of a child.
Q. Physical abuse.
A. It wasnt sexual abuse. So, if the question is sexual molestation, to the best of my
recollection, I have never handled a sexual molestation case before Michael Jackson and
since Michael Jackson.
Q. Now, at the time that you were representing Jordan Chandler back in 1993 and 94,
were you aware, your own personal knowledge, whether or not the Los Angeles County
District Attorneys Office was involved in investigating the sexual abuse allegations against
Mr. Jackson?
A. I do, and they were. 4499
Q. And of your own personal knowledge, were you aware of the fact that at some point in
time later, that the Santa Barbara County District Attorneys
Office joined that investigation?
A. Yes.
Q. During the time that you were representing Mr. Chandler, the child Chandler, not the
father Chandler, the child, Jordan Chandler, during the time that you were representing
him, were either -- lets just go one at a time so we dont get a compound problem. But
was the Los Angeles District Attorneys Office given an opportunity to talk to your client?

A. The Los Angeles County District Attorneys, they talked to my client, they certainly did.
They talked to him all they wanted.
Q. And then later, when the Santa Barbara District Attorneys Office joined in the
investigation, were they allowed access to your client for interview purposes?
A. I mean, you know, I could be wrong. I think you were. Or I dont know about you, but I
thought you were. I thought, but I dont remember that, frankly, whether you were or you
werent. I know when the police wanted to talk to Jordie during that period of time, they
had access to him, so which ones I cant recall.
Q. Was there a time in which there was a request for your client, Jordan Chandler, to
appear before the Santa Barbara County Grand Jury?
A. Gee, I cant remember that really. There may have been. I just dont remember.
Q. To your knowledge, did your client appear before the Santa Barbara County Grand
Jury?
A. I dont think so.
Q. Was there some point in time where your client decided that he did not want to
participate in an investigation by -MR. MESEREAU: Objection. Relevance; foundation; and calls for speculation.
THE COURT: Sustained.
Q. BY MR. SNEDDON: Are you aware, as a practicing lawyer in the State of California,
that a juvenile who has been the alleged victim of a child molestation cannot be forced to
testify -MR. MESEREAU: Objection. Leading; and relevancy; and mis -- and misstates the law.
MR. SNEDDON: No, it doesnt mis -- Im asking his professional legal opinion, Your
Honor.
MR. MESEREAU: Calls for a legal conclusion.
THE COURT: Ill allow the question, but Im going to have you rephrase it because of the
-- of the way you asked it. Ill allow this subject matter to be questioned.
Q. BY MR. SNEDDON: With regard to your practice of law and in your civil litigation, and
with regard to your representation of Jordan Chandler in the Chandler versus Jackson
lawsuit, okay -A. Yeah.
Q. -- were you aware or did you become aware of the fact that there is a code section
dealing with the -- with a minors right to refuse to testify in a criminal prosecution?
A. I was aware of one in 93.
Q. And you were aware of that while you were representing Jordan Chandler?
A. I was.
BAILIFF CORTEZ: Speak more into the microphone.
THE WITNESS: What do you want me to do?
BAILIFF CORTEZ: Speak more into the microphone.
THE WITNESS: Oh.
Q. BY MR. SNEDDON: Now, I guess the last question I have, and Im probably taking it
too much for granted, but with regard to the lawsuit involving Chandler versus Jackson,
was that resolved in Chandlers favor?
MR. MESEREAU: Objection.
THE WITNESS: It was -- oop.
MR. MESEREAU: Move to strike. Vague; no foundation; calls for speculation.
THE COURT: Overruled.
Q. BY MR. SNEDDON: You may answer.

A. It was absolutely resolved in Mr. -- in Jordie Chandlers favor.

Q. All right. Lets fast-forward, if we can, to the year 2003.Are you familiar with an
attorney by the name of Bill Dickerman?
A. I am.
Q. And have you ever had contact with Mr. Dickerman?
A. Before then or -Q. No, in 2003.
A. Yes.
Q. Had you ever had any prior contact with Mr. Dickerman of any kind?
A. Yes, he, I believe, tried to refer me a case or cases in the past. Most of the cases I get
are from other lawyers who refer me business, and I know that he did. I cant remember
what the case was about, and I know I didnt take it, but at least on one occasion, if not
more, he had called me and asked me to help him in cases that he was involved with.
Q. Okay. Now, before we get too far down the road with Mr. Dickerman, I neglected to
show you a photograph. Your Honor, Ive had a photograph marked as 7-76, 776 for
identification purposes. Im approaching the witness. Ive shown it to counsel. Mr.
Feldman, do you recognize the person depicted in that photograph?
A. I do.
Q. Who is that?
A. Jordie Chandler.
Q. Is that an accurate depiction of what Jordie Chandler looked like?
A. He was much better looking, I can tell you, at that age. He was adorable. Thats kind of
blurry.
MR. MESEREAU: Objection; move to strike the gratuitous remarks.
THE COURT: Stricken.
MR. SNEDDON: Move that 776 be admitted into evidence, Your Honor.
MR. MESEREAU: No objection, Your Honor.
THE COURT: The answer was stricken to the question as to whether or not it was an
accurate picture of Jordan Chandler. That hasnt been answered.
MR. SNEDDON: I thought you were just striking the last part.
THE COURT: I struck the whole thing.
Q. BY MR. SNEDDON: Is that photograph, 776, an accurate depiction of Jordan Chandler
at or about the time that you knew him?
A. Yes.
THE COURT: All right. Its admitted.
MR. SNEDDON: May I publish it, Your Honor?
THE BAILIFF: Input 4, Your Honor.
THE COURT: Yes.
Q. BY MR. SNEDDON: All right. Mr. Feldman, the exhibit that is on the Elmo there, 776,
thats the one you just identified as the individual depicted as Jordan Chandler, correct?
A. Thats correct.
Q. All right. Thank you very much. Now, lets get back to Mr. Dickerman. You indicated
that you had at least one prior referral from him that you recall. Now, lets just talk about
something in general. You say you get a referral. Is there ordinarily, in the practice of law
when somebody refers you a case, an agreement called a referral agreement?
A. Yeah. Depending on what kind of case, obviously, thats being referred, but the answer
is yes.
Q. Could you explain to the ladies and gentlemen of the jury how that referral agreement

usually works, in general terms?

A. Yeah, sure. If -- there are two ways, generally, lawyers make their money. One is a
contingent fee agreement, where they only receive payment if they are successful. And if
theyre not 4505 successful, they dont get paid. The second is just a straight hourly kind
of payment where you get paid for every hour that you work. In the contingent field,
when a lawyer referrs another lawyer in the contingent field, some lawyers, not all, want
to participate in some fashion, some way, and they then request the referral fee. And the
State Bar rules say thats legal and you can do that, as long as you tell the client in
advance and the client consents to that referral agreement.
Q. Now -A. And its traditionally done. Not traditionally, but depends where the case is coming
from and who the lawyer is, and, you know, its a whole variety of things.
Q. In 2003, did Mr. Dickerman refer you a case?
A. He did.
Q. And with regard to that particular case, was there one of these referral agreements
formed between you and he?
A. Ultimately, yes. Not right at the beginning. But ultimately, yes.
Q. As part of the referral process, did you have a conversation with Mr. Dickerman?
A. Yeah, Im sure I did. I must have.
Q. The first contact was by phone?
A. Oh, yeah. The first contact with Mr. Dickerman clearly was by phone.
Q. And did you eventually have an in-person conversation with him?
A. In general. Youre not talking about the referral fee now. Youre talking about just -Q. Yeah, Im talking about -A. In general, yeah, sure. I mean, he called me. He told me stuff. He then wanted to
come in and talk to me.
MR. MESEREAU: Objection. Hearsay; move to strike.
THE COURT: Sustained.
THE WITNESS: Im not going to say what he said.
MR. SNEDDON: I know, and you didnt.
Q. Okay. So he had a telephone conversation with you, and he told you some things over
the phone?
A. Thats right.
Q. All right. As a result of that telephone call, did you then have an in-person meeting
with Mr. Dickerman?
A. As a result of that, I had an in-person meeting, yes.
Q. Do you recall whether or not, at the time that you had the first in-person meeting with
Mr Dickerman or the first meeting in person - the sentence the other way was bad - with
Mr. Dickerman
A. Yes.
Q. -- do you recall whether or not the clients that he was referring to you were present?
A. I dont think they were in the first meeting.
Q. Now, at some point after that, then, did you meet the individuals that were the subject
of the case referred to you by Mr. Dickerman?
A. Yes.
Q. And with regard to those -- the clients, do you recall their names?
A. Yes.
Q. Who were they?

A. Janet Arvizo, her daughter Davellin, her son Gavin, and her son Star.
Q. Now, let me go back. I neglected to ask you one other question about referral
agreements. Does the fact that you take a referral agreement from another lawyer
obligate you to continue that case to a point of filing a cause of action or taking some form
of action?
A. Absolutely not. Absolutely not.
Q. You had a meeting involving the family where you met them?
A. Yes.
Q. Do you recall whether Mr. Dickerman was present or not?
A. My guess is he was, because I assume he brought them to me and brought them to my
office, and he had contact, a lot of contact, with them before he came to me, so Im
assuming he did. Im almost sure he was there. I would never have met with them
without him being there.
Q. And do you recall where the meeting took place?
A. In my office. This is when I was at Fogel, Feldman. This is not my new job, but when I
had my old law firm.
Q. Where was that office located?
A. In Santa Monica.
Q. Now, as a result of that first conversation with the Arvizo family, did you decide to take
a form of -- a course of action of any kind?
A. Well, sure, of some kind.
Q. All right.
A. I mean -Q. What would you categorize, in terms of the way you handle cases, as the process that
you felt was going on at this point?
A. The process that I follow in my law office at all times is people come in, they tell a -the factual story. We then -- depends on the case, but generally speaking we then will do
research, legal research, especially in a case like this, to see and try to understand what
the law is. 4509 And because of the nature of the potential defendants at that time, which
was ABC, this Martin Bashir, whatever his company was called, it involved Michael
Jackson, we were going to make sure we knew what we were doing before we started.
And so after we sort of heard this version of the facts, of some facts anyway, thats the
next step that we did. We also I think got -- we were shown letters. Mr. Dickerman had
letters that he had written to the BBC in England, and he wrote letters to Mark Geragos,
and Geragos to him, I cant recall which way they went, but -- so we had those, and we
were trying to make heads or tails in a legal sense, which nobody had done up to that
point in time, to try to focus on what is this about and where -- are we interested in taking
any more steps.
Q. Now, with regard to the legal research that you did, what was the research that you
did?
A. We had to research -- the fundamental issue was that Martin Bashir had done a tape at
Mr. Jacksons house that Ms. Arvizo had told us -MR. MESEREAU: Objection to the extent it calls for hearsay, as well as narrative.
THE COURT: Sustained.
Q. BY MR. SNEDDON: Just what are the issues that you were researching as a result of
your conversation with the Arvizo family?
A. Well, the -- whether or not Martin Bashir or 4510 ABC had to have consent to put the
children on television.

Q. Now, with regard to other aspects of the information provided to you by the Arvizo
family in this meeting, did you decide on another course of action that you felt you needed
to do to determine whether you were going to represent this family?
MR. MESEREAU: Objection. Thats leading; move to strike.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes.
Q. BY MR. SNEDDON: And what did you do in that connection?
A. I decided at some point in time that I had to make some heads or tails out of what was
being told to me by Mrs. Arvizo, by Star, the young boy, and Gavin. And I concluded that I
wasnt going to be able to do -MR. MESEREAU: Objection. Move to strike; impermissible opinion; no foundation;
relevance; hearsay.
MR. SNEDDON: Judge -THE COURT: The question, though, was what did he do next, so he answered that. So his
thoughts arent being called for at this point.
MR. SNEDDON: Judge, I believe under 1250 of the Evidence Code -- 4511
THE COURT: This just relates to the question and answer, Counsel. The question didnt
call for his thoughts. Dont look at me like that.
MR. SNEDDON: I -- Judge, I was thinking of the next question I was going to ask. If you
took it the wrong way, Im sorry, but I wasnt -THE COURT: All right. Go ahead.
MR. SNEDDON: I mean, its -Q. All right. So you -- you decided on a course of action?
A. I did.
Q. As a result of the information given to you?
A. Yes.
Q. And what was that course of action?
A. The course of action was to allow an expert, which I was not, to spend some time with
all three of them. Davellin wasnt really the issue, but Janet, Star and Gavin, and let some
expert figure out, if he could, what was happening.
Q. All right. Did you contact somebody to help you make that evaluation?
A. I did.
Q. And who was that?
A. Dr. Stanley Katz.
Q. And are you familiar -- were you familiar with Dr. Katz prior to the time that you
decided to use him in the case -A. Yes.
Q. -- involving the case that Mr. Dickerman had referred to you?
A. Yes.
Q. And what was your prior contact with Dr. Katz?
A. In 1987, I was defending a family who had been wrongfully accused of abusing a child,
and the court so found, but -- and Dr. Katz, the first time I met him, was an expert that
we hired for the defense to assist in that trial, and he testified in that case.
Q. Did you hire Dr. Katz or did he participate in the case of Chandler versus Jackson?
A. Yeah, in Chandler versus -- well, participate. Chandler versus Jackson moved very
quickly, because he was a minor.
Q. Did you retain him?
A. So I retained him, yes.

Q. And did he play any role in the case itself? It never went to trial, correct?
A. The case never went to trial. We never got that -MR. MESEREAU: Objection; asked and answered.
MR. SNEDDON: Ill move on, Your Honor. Its not a problem.
THE COURT: All right.
Q. BY MR. SNEDDON: As a result of your contacts with Dr. Katz, did you decide to send
the
Arvizo family to Dr. Katz?
A. Yes.
Q. In 2003?
A. Yes.
Q. Okay. Now, do you recall when that was, approximately, what month it was?
A. Either May or June, in that time frame, of 2003.
Q. At some point in time, did you receive a report back from Dr. Katz about his initial
contacts with the family?
A. Oral. I got an oral -- I had an oral conversation with him.
Q. Do you recall whether it was in person or over the phone?
A. I think it was in person, quite frankly. I think he came to my office.
Q. Now, after you received this report, did you do anything?
A. Yes.
Q. What did you do?
A. I called the Arvizo family, Mrs. Arvizo and the three children, back into my office for a
meeting.
Q. All right. And in that meeting, what was the topic discussed?
MR. MESEREAU: Objection to the extent it calls for hearsay.
MR. SNEDDON: All right.
THE COURT: Overruled. The subject matter only.
THE WITNESS: The subject matter only. The subject matter was the options -- well,
what Dr. Katz had told me, and their -- the options that existed at that point for that
family. Different courses of action that were available to them at that point in time.
MR. SNEDDON: Your Honor, at this point I would ask the Court to be able to have the
witness be able to recount those, and that it would be admissible under 1250 of the
Evidence Code not only as to this witnesss state of mind, but also as to the state of mind
and actions of the Arvizo family.
MR. MESEREAU: And I object. Hearsay, foundation; relevance; and calls for improper
conclusion; and 352.
THE COURT: Whose statements are you offering for the state of mind only?
MR. SNEDDON: Your Honor, both. I mean, youre asking me, so I guess I can go beyond
-THE COURT: Just give me names.
MR. SNEDDON: All right. This witness, Mr. Feldman, with regard to his state of mind with
regard to what the future of any lawsuit may be at this point; and secondly with regard to
the Arvizos, any decision that they would have made regarding any lawsuits against any
individuals at this point in time, which I believe is an issue in this case.
THE COURT: The objection is sustained.
Q. BY MR. SNEDDON: As a result of your conversation with the Arvizos on this particular
day, what was the next step that you took in evaluating this case?
A. Well, the next step I took was, after -- I wont say what I said. I understand the ruling.

They went back and saw Dr. Katz again. And I then went to the head of the -Q. Lets just stop there for just a second, Mr. Feldman.
A. All right.
Q. So as a result of the conversations that you had with the Arvizos, there was a decision
to go back to see Dr. Katz with the family again, correct?
A. Their decision to; that they wanted to go back and see him again.
Q. Okay. And to your knowledge, did that happen?
A. Yes.
Q. And to your knowledge, did you then find out the results of Dr. Katz subsequent
conversations with the family?
A. Yes.
Q. And as a result of those conversations with 4516 Dr. Katz, did you decide on a further
course of conduct that you felt needed to be done?
MR. MESEREAU: Objection; leading.
THE COURT: Overruled.
THE WITNESS: Yes.
THE COURT: You may answer.
Q. BY MR. SNEDDON: What did you do?
A. I then believed that -- Dr. Katz believed he had a report, and I then went to the head
of MR. MESEREAU: Objection. Move to strike; hearsay.
THE COURT: His belief is stricken. The question is, What did you do?
THE WITNESS: I went to the head of the Department of Children Services, Los Angeles
County, a fellow by the name of David Saunders, who was the head of the Department of
Children & Family Services.
Q. BY MR. SNEDDON: And did you contact him prior to going down to the department?
A. I did.
Q. By what form?
A. Well, thats a good question. I contacted him first between the meeting where I called
the Arvizos into my office after Dr. Katz talked to me and before they went back. I talked
to him and alerted him to a possibility that I might need to talk to him.
Q. And then after that?
A. And what I cant remember is if I saw him at a social gathering where we were both at,
or did that by phone. I just -- it was one or the other, but I definitely met with him or
talked to him and told him that -- I didnt tell him what it involved. I just told him it was a
high-profile thing, and if it happened, I needed to have secrecy.
Q. All right. Now, with regard to after your second conversation with Dr. Katz, did you
actually go down to the Los Angeles County Department of Child & Family Services?
A. Yeah, well, I did then definitely call him and talk to him again.
Q. Before you went down there?
A. Before I went down, and then after talking to him and telling him what it was -MR. MESEREAU: Objection. Move to strike; asked and answered.
THE COURT: Sustained. Well, not asked and answered, but its not responsive.
Q. BY MR. SNEDDON: So you had a telephone call with him?
A. I did have a telephone call.
Q. And after that telephone call, did you go down there, and with whom?
A. I went down there with a colleague of mine from my office and Dr. Katz.
Q. And what was the purpose for the three of you going down to the L.A. County

Department of Child & Family Services?

A. I wanted to get absolute assurance from the head of the department that there would
be no leaks of anything that they decided to do or not do in connection with the report
that Dr. Katz was going to make.
Q. Now, are you familiar with the law in the State of California that requires certain
psychologists or psychiatrists to make a mandatory report -A. I am.
Q. -- when they suspect child abuse or child -MR. MESEREAU: Objection. Leading; move to strike.
THE COURT: Overruled.
THE WITNESS: I am aware of that.
Q. BY MR. SNEDDON: And was this the purpose for the three of you going down to the
L.A. department?
A. The purpose was for him to report, but he could have done it on a hotline like was done
in93. This time it was to have it guaranteed it was never going to leak out to the press.
Q. Okay. Now, as a result of this conversation, were you directed to another agency?
A. Well, he directed me into a room with two people. Thats where he directed me.
Q. You had a conversation with those people?
A. I had a conversation with those people.
Q. And as a result of that conversation, were you directed to another agency? Let me put
it this way: Did they take the report?
A. They didnt take the report, and they didnt direct us to another agency. They -MR. MESEREAU: Objection. Hearsay; move to strike.
THE COURT: Overruled.
Q. BY MR. SNEDDON: Now, after you left the agency, did you decide on a course of
action?
A. Yes.
Q. And was this regarding and connected with Dr. Katz responsibility as a mandated
reporter?
A. Yes, because I felt he still hadnt reported because they didnt take the report.
MR. MESEREAU: Objection. Objection. Move to strike; nonresponsive.
THE COURT: After Yes is stricken.
Q. BY MR. SNEDDON: All right. Who did you call?
A. I called you.
Q. Okay. And as a result of that conversation, were you eventually contacted by
somebody else?
A. My recollection is that I was contacted by a police officer. Or he may have been a
sheriff. I dont know what he was, but he was some law enforcement person.
Q. Now, during the course of the conversation between you and I, did the subject of a civil
lawsuit against Michael Jackson in connection with the substance of the mandated report
come up?
A. Yes.
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. The answer was, Yes.
Q. BY MR. SNEDDON: And in that connection, was there a representation made by you
to me concerning a civil lawsuit?
A. Yes.
MR. MESEREAU: Objection; leading.

THE COURT: Overruled. The answer was, Yes.

Q. BY MR. SNEDDON: And with regard to that representation - and, Your Honor, Im
offering this under 1250 - what was said by you to me?
A. No lawsuit. I would not file a lawsuit.
And there was no plans to file a lawsuit. And that you would investigate it and make up
your own mind. Not you, but the police.
Q. Now, do you currently -- at some point in time did you feel you represented the Arvizo
family in some kind of litigation?
A. Thats a great question. Ive thought about it. Yeah, I mean -- yes, I guess -- I dont
know about some litigation. I certainly represented them in everything I did, because Im
a lawyer and I was doing it as a lawyer. So, yes. The answer is yes.
Q. With regard to the information and the substance of the original conversation with the
Arvizo family, did you feel that you represented them at least at some point with regard to
the exploration of the issues involving the Bashir tape and things of that nature?
A. Yes. For sure.
Q. And was there a certain point in time where that representation ended?
A. Yes.
Q. And when was that?
A. Approximately -- I terminated them, my relationship with them sometime in October, I
think, if not sooner. I think effectively it was August or September, somewhere in that
time, of 03, and then shortly thereafter I wrote a letter terminating my relationship,
confirming that I was not their lawyer and that I wasnt going to proceed with anything.
Q. And at any point in time from the time you first met the Arvizo family and to the time
you wrote the letter saying you were not going to represent them, which would have been
somewhere around October of 2003, did you ever file an action on their behalf?
A. No, never have.
Q. Now, subsequently, in the year 2004, you did some legal work for the Arvizo family,
correct?
A. Yes.
Q. And you -- and you have made appearances in court on representing the family; is that
correct?
A. Well, I havent physically made any appearance, but I have occasionally done things,
very limited, for them.
Q. And have you done that for other clients before?
A. Oh, yeah. I was -Q. Is there a term in the legal profession that we call that?
A. Yes.
Q. Whats it called?
A. Dumb.
Q. That wasnt exactly the one I had in mind.
A. Pro bono. Pro bono. Stupid.
Q. And do you consider what you did with the Arvizos after the point that you were no
longer officially their lawyer to be pro bono work for th family?
A. Yeah. Absolutely. I never expected to get paid, and Ive done very limited stuff, and the
stuff that Ive done is just stuff that I felt that I should do. That nobody was going to do it
for them, and I got this thing rolling and I ought to do it, and I have very limitedly done
things.
Q. Is one of the things that you did for them was to file a claim with the Los Angeles

County Department of Child & Family Services?

A. That I did for both of us, because of again, because I was upset that the county did
that, so we filed a claim.
Q. Why did you file a claim against Los Angeles County on behalf of Janet Arvizo?
A. Because the County of Los Angeles has a sworn obligation to protect children. And
here, they swore -- I went to the head to get this thing protected, and the minute Mr.
Jackson gets arrested, the first thing that happens is that county leaks out a report that
was created and written after he was arrested, a memo. It comes out, it quickly gets on
the news, and quickly blasts this family. And I thought, of all the things that Ive seen as a
lawyer -MR. MESEREAU: Objection. Move to strike; nonresponsive; giving a narrative;
impermissible opinion.
THE COURT: It is responsive, but it is a narrative answer. So Ill sustain the objection.
Q. BY MR. SNEDDON: All right. So with regard to this particular claim that you filed, its
not a lawsuit, right?
A. It was a claim.
Q. And thats required when you sue a governmental agency, to file a claim first?
A. Yes.
Q. And then what is the -- weve heard this term thrown around in the courtroom in
relationship to other things, whats the statute of limitations for an individual to actually
bring the lawsuit once the claim is filed?
A. You have 180 days to file the claim from the event. And then -- so you have to have a
claim on file if you were ever going to do anything. And then once they deny the claim,
you have another 180 days, essentially, to bring a lawsuit once its denied.
Q. And as a result of that claim that you filed on behalf of Janet Arvizo, has the second
180 days elapsed?
A. It has as to Janet, and it has as to Davellin. I dont think it has, frankly, as to the
minors. But it certainly has as to -- Janet couldnt file a lawsuit today and her daughter
couldnt file a lawsuit today.
Q. And thats because they have a certain number of years after they reach the age of
majority, to file a claim or a lawsuit?
A. Thats my understanding. Once they file a claim it protects their rights, I think. You
know, I really -- this was a claim that asked for an apology.
Q. So they were never seeking monetary damages?
A. Well, who knows? But, I mean, there really -MR. MESEREAU: Objection; move to strike.
THE WITNESS: I dont know what
THE COURT: Just a moment. The objection is sustained. Any answer is stricken.
Q. BY MR. SNEDDON: At the time that you made the written claim to the County of Los
Angeles, did you demand monetary damages?
A. It had -- it probably said words in there, whatever the damages are. It didnt have a
number, I can tell you that. And it had -- I mean, you cant file a lawsuit without the
claim. I mean, theres no such thing as a lawsuit for an apology. So it said some -- if I saw
it, if you had it, I could tell you, but it was really to conduct a -- get the county to do
something, for the next kid.
MR. MESEREAU: Move to strike the gratuitous remarks at the end; nonresponsive;
impermissible opinion.
THE COURT: Ill strike the last sentence.

Q. BY MR. SNEDDON: During the time that you -- since you first met Janet Arvizo -A. Yes.
Q. -- and the Arvizo family, were you ever 4526 asked to file a lawsuit against Michael
Jackson?
MR. MESEREAU: Objection. Move to strike; calls for inadmissible hearsay; no foundation.
THE COURT: The objection is overruled. You may answer.
THE WITNESS: I have never been asked to file any lawsuit against Michael Jackson.
MR. SNEDDON: Nothing further, Your Honor.
MR. MESEREAU: May I take just a second, Your Honor? I have to get some materials.

CROSS-EXAMINATION BY MR. MESEREAU:

Q. Good morning, Mr. Feldman.
A. Good morning, sir.
Q. Mr. Feldman, if Gavin Arvizo decided at some point in the future to sue Mr. Jackson for
alleged sexual abuse, how much time would he have to file that action?
A. I think hed have till his 20th birthday.
Q. If Star Arvizo decided in the future to sue Mr. Jackson for alleged sexual abuse, how
much time would he have to file that lawsuit?
A. I think the answers the same. 20.
Q. If, at the end of this trial, they were to decide, you know, Wed like to sue, theyd
have plenty of time to do it, wouldnt they?
A. They meaning the boy -Q. Gavin.
A. Not Janet.
Q. Gavin and Star.
A. The two boys?
Q. Yes.
A. If they wanted to at the end of the trial, they could sue, sure.
Q. Isnt it true that a judgment of conviction in a criminal case for anything related to child
molestation could be dispositive in a parallel civil suit alleged for the same facts?
A. As long as its a felony conviction, thats right.
Q. In other words, if Mr. Jackson were convicted of felony child molestation in this case,
either Gavin Arvizo or Star Arvizo could use that conviction to essentially win a civil case
regarding similar alleged facts against Mr. Jackson?
A. Thats correct.
Q. If there were a conviction for felony child molestation in this case, and if Star or Gavin
elected to sue in a civil case based on the similar alleged facts of sexual abuse, essentially
the only issue remaining would be how much money you get, correct?
A. Probably. I think thats -- its close enough. I mean, nothing is that simple, as just
stated. You know it as well as I. But essentially I think thats what would happen.
Q. Well, you would have to follow certain civil procedures in civil court, but essentially, Mr.
Feldman, you could take the judgment of conviction, you could walk into civil court, you
could lodge it with the court, you could ask a judge to determine that liability has been
established, true?
A. Yes. You get these problems with appeals, and the impact of appeals, and its a
complicated thing, but the answer is ultimately yes.

Q. And one of the reasons for that is that the burden of proof in a criminal case is proof
beyond a reasonable doubt. The burden of proof in a civil case is preponderance of the
evidence, and if you have proof beyond a reasonable doubt, you automatically have proof
by a preponderance of the
evidence, as you would need to have it in civil court, true?
A. Thats the theory.
Q. Well, thats correct, right?
A. Yeah, thats the theory behind it.
Q. All right. Now, lets assume there was a conviction in this case and that Mr. Jackson
were convicted of felony child molestation, and lets assume that Gavin and Star then
decided, We want to file a civil suit for millions of dollars in civil court, okay?
A. Yeah. 4529
Q. On similar alleged facts. And lets assume the process youve just identified, where you
walk into civil court, you follow rules, and you essentially establish to a civil court judge
that liability exists. If that were to happen, whoever the civil lawyer was representing the
Arvizos would have avoided costs of investigation, experts, depositions, filing fees,
messenger fees, all sorts of legal fees, right
A. Well, look, I dont want to open the hypothetical. Youd have to be nuts to do that,
what youre saying, as a civil lawyer.
Q. Sir -A. Youd have to be nuts.
Q. Sir, did you tell a grand jury in Santa Barbara County that you had incurred
tremendous costs of expenses during your lawsuit against Mr. Jackson in 1993?
A. I did. And it was true.
Q. And if liability were established through criminal conviction, a civil litigator could avoid
most of those costs, correct?
A. Some of those costs. Not most. Some. I mean, certainly some you would avoid.
Q. You could avoid of lot of investigative costs, correct?
A. You know, its -- can I -Q. Just answer my question, if you would, please.
A. I cant answer it that way. If I could explain to you why. You know, Ill tell you why I
cant, and you can ask me the next question and you can get to the answer.
Q. Is your answer you would not avoid investigative costs?
A. No, its the amount of investigative costs were talking about.
Q. Okay. Did you tell the jury today that when you were in front of the grand jury you
mentioned the enormous amount of expenses and legal fees you had incurred in 1993
litigating that case until it settled?
MR. SNEDDON: Object. Asked and answered, Your Honor.
THE COURT: Im not -- Ill sustain the objection if youre asking him what he previously
testified to -MR. MESEREAU: Yes.
THE COURT: -- today. I mean, youre saying, What did you just testify to on direct?
MR. MESEREAU: I couldnt -- to be honest, Your Honor, I couldnt tell if he had actually
addressed that issue. Its a long answer.
THE WITNESS: Im happy to -- the legal fees wouldnt change. The costs would change.
Were just debating how much those costs change. But the costs would change. The legal
fees would be the same. If youre on a contingent fee, you dont get paid any more if you
work a lot or work a little.

Q. BY MR. MESEREAU: But if you were to gauge your legal fees at hours, sir, and you
didnt have to prove liability, you would save a tremendous amount in legal fees, wouldnt
you?
A. Well, sir, I keep trying to tell you, that aint the way it works, and you want to keep
saying it is. Now, I can tell you how it works, and then you can get to what you want to
get.
Q. If you had to try a civil case on liability, Mr. Feldman, it could go months, couldnt it?
A. Sure.
Q. If you have a judgment of felony conviction in a criminal case and you walk into civil
court and establish it, you dont have a trial in civil court for months on liability, correct?
A. You have to -Q. Yes or no?
A. You could, if you -- you know, you could. I cant answer it the way you want me to
answer. Im happy to explain it to you, and maybe we can get to the answer.
Q. Would a judgment of felony conviction in criminal court possibly eliminate a trial on
liability in civil court for similarly alleged facts? Yes or no.
A. Do you count punitive damages in liability, or not?
Q. Sir, Im asking you to answer my question.
A. Well, I cant -- I cant answer it this way. Liability has a lot of aspects to it, sir, and one
of the things is the finding of malice.
Q. Okay.
A. And thats separate from what youre talking about.
Q. In other words, if you could avoid the liability phase of a civil case, you wouldnt save
some time in legal fees?
A. Of course you would save some time, and you would save some money. Were just
talking about how much. You keep saying its -- theres -- it would be a total saving, and
Im trying to explain to you thats not what would happen. It wouldnt go down that way.
Q. You wouldnt have to prove liability, because it would have been proven in a criminal
court, correct, or not?
A. Youd have to prove malice, though.
Q. Correct or not, Mr. Feldman?
A. Well, how many times can I go through this with you?
Q. Are you saying if you get a judgment of conviction in criminal court for felony child
molestation and you then walk into civil court with civil allegations based on the same
facts, you still have to establish liability? Is that what youre saying?
A. Not liability as to that aspect. But for malice, you would still have to prove it.
Q. Okay. All right. Now, what is the statute of limitations for civil fraud?
A. Civil fraud?
Q. Yes.
A. Three years from discovery.
Q. Okay. Were you aware that Attorney William Dickerman wrote letters on behalf of Janet
Arvizo to Attorney Mark Geragos alleging fraud?
A. Not sitting here. I thought it was over their belongings, or something, that he wrote
letters.
Q. You thought the letters were only about belongings?
A. You know what? I dont know. Im guessing. Show me the letters and maybe it will
refresh my memory. I remember there was letters to Mark Geragos, and thats what was
significant to me. What was in them, I cant remember, unless you show me the letters.

Q. Do you recall at some point during your relationship with Prosecutor Sneddon, Mr.
Sneddon spoke to the media and said, If theyre going to 4534 sue, I hope they dont do
it until after the criminal case is done?
MR. SNEDDON: Im going to object to the word relationship.
THE WITNESS: I dont even remember it happening.
THE COURT: Just a moment Youre asking him what Mr. Sneddon said, if he -MR. MESEREAU: If he was aware of it.
THE COURT: Thats not how you phrased it.
MR. SNEDDON: No.
THE COURT: Ill sustain the objection.
Q. BY MR. MESEREAU: Mr. Feldman, Prosecutor Sneddon asked you about a technical
term in civil litigation called confession of judgment?
A. Yes.
Q. Right?
A. Right.
Q. Now, in the civil case where you represented Mr. Chandler and his parents against Mr.
Jackson, there was a cross-complaint, was there not?
A. There was?
Q. Mr. Jackson sued for extortion, didnt he?
A. I dont know. I know he claimed -- I know that his investigator, Mr. Pellicano, claimed
extortion.
Q. You dont recall?
A. Im not saying it didnt happen. I just dont recall.
Q. Okay. And typically, in a settlement like the one described by Prosecutor Sneddon, if
someone agrees to pay money to the other side, the other side would like the payment of
that money secured by what is called a confession of judgment, correct?
A. Thats right. When its paid over time, thats correct.
Q. Okay. And the purpose of a confession of judgment is that if the paying party stops
paying, you can run into civil court and obtain what is called a certified judgment so you
can then collect on their assets?
A. Correct.
Q. Right?
A. Thats right.
Q. And if you didnt have that confession of judgment, your only remedy would be to then
file another lawsuit for breach of contract, correct?
A. Thats right.
Q. So what Mr. Sneddon was talking to you about was ways that you have to collect
money that youre owed in a settlement, true?
A. I dont know what he was talking to me about. He asked me questions, and I answered
the best I could. What youve said is true, and thats what I thought I just said.
Q. And typically in a civil settlement, and youve done many of them, obviously, there is a
provision in the settlement agreement which says that neither side admits liability, or
words to that effect, correct?
A. Generally. Not every one, but generally thats true.
Q. And essentially what that means is neither side admits wrongdoing, correct?
A. Correct.
Q. And the confession of judgment has nothing to do with an admission of wrongdoing or
liability?

A. Well, it would have the same impact if you had to file it. It would be a judgment for
that amount. I dont know what impact its going to later be. Ive never handled a case
where you filed a confession of judgment, and then somebody tried to use that in another
case to say you admitted something. I frankly dont know the answer.
Q. Its never used to say someone admitted something. Its simply used to collect the
money youre owed, right?
A. Sir, I just told you, Ive never researched that issue, and -- so you cant -- you got the
wrong person. Ive never had someone where I had to go use it.I didnt have to use it with
Mr. Jackson, so I cant tell you the answer. I know its -- it is -- my concern was the
making sure, if the money wasnt paid by Mr. Jackson, we could go into court and start
seizing his assets. That didnt happen. He paid. It never happened.
Q. Would you agree that in many civil settlements of civil cases, you will have both the
provision that says neither side admits wrongdoing or liability as well as a confession of
judgment?
A. Its rare you get a confession of judgment. It is very -- typical that you get neither
party admits wrongdoing in a release. Its typical. You dont need the confession, because
you usually exchange the release and the money at the same time. So there isnt that
issue.
Q. But you need a confession of judgment if you want to secure payments to be made in
the future, right?
A. That you need. Thats right. And thats what we got.
Q. And if payments are to be made in the future by any settling party, you would almost
be foolish not to have a confession of judgment, correct?
A. I dont know. Well let somebody else worry about whos foolish. We did it. We thought
it was the appropriate thing. We demanded it. We got it.
Q. Please answer my question, Mr. Feldman.
A. I dont know whats foolish for lawyers to do. I mean, I havent thought about it. Its a
good practice - I did it - to get it. I mean, I demand to get it for my clients. Thats all I can
tell you.
Q. You demand to get it for your clients because if payments were to stop, you would
have a faster way -A. Sure.
Q. -- to obtain that value than you would if you had to sue for breach of a settlement
agreement, right?
A. Yes. Thats what I think Im saying.
Q. And when you have your clients get a confession of judgment in a settlement
agreement in a civil case, typically there also is a provision where neither side admits any
wrongdoing to each other, right?
A. The settlement agreement will say that, thats correct.
Q. And thats what you had in 1993 in the Chandler case, correct?
A. We had the settlement language that said that, and we had a confession of judgment.
Q. You had settlement language that said neither side admits wrongdoing to the other,
and you also had the confession of judgment you just described, true?
A. True.
Q. Now, did I hear you say, in response to the prosecutors questions, you stopped
representing Janet Arvizo in the fall of 2003?
A. The first time.
Q. Pardon me?

A. The first time.

Q. Thats the first time you stopped?
A. Thats the first time I stopped.
Q. Okay. Now, as I look at pleadings filed by your law firm in this case, I count no less
than four lawyers representing the Arvizos well into 2005, correct?
A. Thats why I answered the question the way I did. I said thats the first time that
terminated the relationship with Ms. Arvizo.
Q. And in 2005, you have represented the Arvizos in documents filed in this particular
criminal case, correct?
A. Correct.
Q. A lawyer named Julian Brew from your firm has also represented the Arvizos in
documents filed in this criminal case in 2005, correct?
A. Well, my law firm, because of me, has done this for the -- Miss Arvizo, weve done it for
her parents, weve -- and for the newborn baby. I think those are the three people. But I
may be wrong.
Q. Let me rephrase the question.
A. Mr. Brew works for me. I mean, I dont want to demean him. I mean, he works with
me.
Q. Mr. Brew is a lawyer with your law firm, correct?
A. Yes.
Q. He has represented the Arvizos in the year 2005, correct?
A. The law firm has represented her, and hes one of the people, to be technical.
Q. Sir, you work for or your partner with approximately a 600-person law firm, correct?
A. Hes one of the lawyers that worked on this case. Thats what I said.
Q. Thats Julian Brew, correct?
A. Yeah.
Q. A lawyer named Theodore Maya has also worked for the Arvizos in the year 2005 in
this case, true?
A. True.
Q. A lawyer named Robert Turner has also worked for the Arvizos -A. Yes.
Q. -- in this case, correct?
A. Correct.
Q. Those are four lawyers with your 600-plus law firm, true?
A. True
THE COURT: All right. Its break time. (Recess taken.)
THE COURT: All right. Go ahead.
MR. MESEREAU: Thank you, Your Honor.
Q. Mr. Feldman, youve testified that you had filed, as a lawyer for the Arvizos, a Notice of
Claim against Los Angeles County, correct?
A. Correct.
Q. And the purpose of filing that notice of claim was to preserve the right to sue in the
future if you desire to, correct?
A. Correct.
Q. And you told the jury that at this point, in your opinion, Gavin Arvizo and Star Arvizo
still have time to file a lawsuit against Los Angeles County, correct?
A. I believe thats right.
Q. The lawsuit youre referring to, if it ever occurred, would be separate and apart, or

could be separate and apart from any lawsuit against Mr. Jackson in the future, true?
A. I think it would have to be separate and apart. I dont think you could join the two. But
it would be -- I think the simple question is -- the simple answer is yes.
Q. And as we speak, then, those two young men still have a right to sue Mr. Jackson, and
they still have a right to sue Los Angeles County in a separate action, true?
A. True.
Q. And by filing your Notice of Claim, you preserved that right for them, true? 4542
A. Thats what I did. Against the county.
Q. Against the County of Los Angeles?
A. Yeah. It had nothing to do with Mr Jackson.
Q. Okay. Now, youve indicated you know --excuse me, let me rephrase that. How long
have you known Attorney William Dickerman?
A. Well, certainly since 2003. He tells me that he brought a case to me that I rejected,
and I cant tell you when that happened. I sort of vaguely remember it happening, but I
cant place it. I never met him till he walked into my office. I think thats the first time I
ever saw him.
Q. Did you testify this morning that you have or had a referral arrangement with him with
respect to the Arvizos?
A. You know, loosely. I think there was an agreement with the Arvizos that he was a party
to. You need the consent -- under the State Bar rules, you have to have a clients consent
to have -- and he was in that agreement, and exactly what we said about him I dont
know. But I know he expected, if there was money, to get money for -- from me, from
her, I dont know where. I cant remember the details of it, but -Q. Do you recall him having what is called a joint legal services agreement with you?
A. Vis-a-vis the Arvizos?
Q. Yes.
A. He could have. I mean, I dont know what he had. He had -- he wanted to be involved
if I was going to bring a case. And how those financial terms were worked out with him, I
dont know. And what -- he was -- he wanted to be involved with the family, because he
said he had this great relationship with the family, so I was there to do the legal work,
and it never went anyplace.
Q. He also wanted money, true?
A. He wanted money, Im sure of that. Im sure of that.
Q. You had a lot of communications with him after he referred the Arvizos to you, true?
A. Well, we certainly had some. I dont know about a lot. I certainly had some with him.
Q. There were faxes and letters going back and forth from his office to you for many
months after he referred the Arvizos to you, right?
A. Could be. We certainly were trying to get his file and what he had in his file from the
time he had the case till the time we were done with it initially.
Q. And just to clarify what you just said, are you saying youre not sure if Attorney William
Dickerman had a legal services agreement with you?
A. What do you mean by a legal services agreement?
Q. Well, let me get -A. That I pay him to do legal services for me?
Q. He does legal work with you for the Arvizos.
A. I dont know -- is there something Im missing about what Im saying and youre
asking?
Q. I dont think so.

A. I thought he wanted to get paid for the work he thought I would let him do in the
Arvizo case. If I took the Arvizo case - I dont want to break his heart - he wasnt going to
do very much work if I was the lawyer on the case, but he wanted to get paid. Thats the
point. And how we memorialized that, I dont remember. It was in the agreement, and
she consented to however we memorialized what he would get if there was money to be
had.
Q. But Prosecutor Sneddon asked you questions about a referral agreement between
lawyers, correct?
A. He asked me questions about a referral fee, yes.
Q. And what youre describing now is not a simple referral fee arrangement, true?
A. Well, Im describing -- I dont remember the way this worked. If you showed it to me, I
could. But I dont think it mattered. I was going to be the lead lawyer, and he was -- I
guess if we gave him a task to do, he would do it.
Q. And just to clarify things, thats something different from a strict referral fee
arrangement, true?
A. It can or cannot be, frankly. You can do it both ways. I mean, I dont think the form it
takes -- I think whats important is that the two lawyers have to decide how they are
going to divide fees, and on what basis, and that the -- the most important thing is the
client consents to whatever the arrangement is.
Q. And your typical referral fee arrangement involves one lawyer referring a case to
another lawyer, and if the lawyer who gets the case makes any money on it, that lawyer
gives a percentage to the lawyer that referred the case to him or her, correct?
A. That certainly happens frequently.
Q. Thats your typical referral arrangement, isnt it?
A. That was at one time my typical -- are you asking me now personally, or just in
general?
Q. Just generally speaking.
A. Generally, I think that is the way lawyers get a case. They send it to somebody else
and they get a referral fee, and they dont have to do any work.
Q. Now, in Los Angeles County, youre known as one of the most successful plaintiffs
lawyers, correct?
A. Say it again for the press. I want to -- thats the nicest thing anybodys said about me
in this case.
Q. Is that true?
A. I think so.
Q. Youve had numerous multi-million-dollar awards that you have obtained for your
clients, correct?
A. I have.
Q. You have numerous multi-million-dollar settlements youve obtained for your clients,
correct?
A. I have.
Q. And in most of those situations, you had what is called a contingency fee arrangement,
correct?
A. Oh, Im sure. Yeah. Over the life of my legal career, thats absolutely right.
Q. And generally speaking, in a contingency fee arrangement, the plaintiffs lawyer in
these cases, namely you, get a percentage of whatever is recovered for the client, true?
A. Yes.
Q. And in a strict contingency fee arrangement, if the lawyer doesnt obtain any money for

the client, the lawyer might not get paid anything, correct?
A. Correct.
Q. So theres an incentive for that lawyer to get as big a recovery as possible, because the
bigger the recovery for the client, the bigger the fee for the lawyer, correct?
A. Thats the theory.
Q. And you have a fairly standard contingency fee arrangement that youve used through
the years, correct?
A. I -- I have.
Q. In the Chandler case, the parents, who youve described as divorced, both signed your
fee agreement, true?
A. They did. Well, I mean, youre saying that. I -- it looks like youre looking at something.
If you tell me -- I hope they did. I dont remember.
Q. Would it refresh your -A. But it would have been smart on my part to get both of them to sign it.
Q. Would it refresh your recollection if you looked at your fee agreement?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Is that all of it?
MR. MESEREAU: (Nods head up and down.)
Q. Mr. Feldman, have you had a chance to look at that fee agreement?
A. I have.
Q. Is it true that June Chandler and Evan Chandler signed that agreement?
A. They did.
Q. They retained your services, correct?
A. They did on behalf of their son. I -Q. Now, to your knowledge, the father had been divorced from the mother since 1986,
correct?
A. I dont know the date, but they were -- the parents were divorced. The father was
remarried.
Q. The mother remarried also, true?
A. Yeah, I think that is right. Except I think they were separated at the time. The mother
was separated from her husband. She could have been divorced, but she did -- I think she
remarried.
Q. Now, the father had not only been divorced for a number of years from the mother, he
had given up all custody to the mother at that time, true?
MR. SNEDDON: Im going to object as irrelevant.
MR. MESEREAU: I believe the prosecutor raised these issues, Your Honor.
THE COURT: Whats the relevancy?
MR. MESEREAU: Who hes really representing, and what their influence is on the
litigation, what their influence is on the settlement and what their motives are, and what
example it sets to everyone else.
THE COURT: All right. The objection is sustained.
Q. BY MR. MESEREAU: You represented both parents on behalf of the minor, Mr.
Chandler, correct?
A. My memory is both parents were the guardian ad litems for the minor. I dont
remember if representing the parents separately and apart in a separate lawsuit against
anybody. I -- I think we only had them as guardian ad litems because the young minor

cant bring a lawsuit. It has to be done through someone. And originally it was done
through the parents and then ultimately through a judge, retired judge became the
guardian.
Q. And you had in that particular case ethical obligations to both the parents and the
minor in your representation, true?
A. I suspect at some level there was -- I certainly had an attorney-client privilege with
them.
Q. Well, without going into the amount of any settlement, isnt it true that both parents
wanted money for themselves as well?
A. They didnt want it. The defense wanted them to have it, and they accepted it, because
the defendant -- that was the defendants idea.
Q. Did the parents -- without going into the amounts -A. Sure.
Q. -- did the parents for Mr. Chandler accept money in the settlement?
A. They did accept money. Thats a fair statement.
Q. Okay. That would include a father who didnt even have the legal right to see the child,
right?
A. Im not sure thats right, you know, because he had the child. At that time that I came
in the case, the child was living with the father, so you may be right in some -- there may
be an order out there, but at the time I came in the case, the father -- the boy lived with
his dad and his dads wife, as I recall.
Q. Okay. Now, at some point -- excuse me, let me rephrase that. The mothers name is
June Chandler, correct?
A. Correct. Or at least it was.
Q. Okay. To your knowledge, has it changed?
A. No. But I dont know.
Q. Okay. At some point she married someone named David Schwartz, correct?
A. Sometime she married David Schwartz.
Q. When you were representing June Chandler, she was either married to or living with
David Schwartz, true?
A. Im not sure, you know, what the situation was. I dont think -- their relationship was
strained, I can tell you that -Q. Okay.
A. -- at that point in time. I have a recollection he wasnt living in the house at the time I
met her, but there was still a relationship, because I can picture him in my office with her,
with Evan Chandler, and with Evan Chandlers wife, and Jordie.
Q. Now, at some point when it became clear that you were seeking money from Mr.
Jackson, David Schwartz then filed his own suit against Mr. Jackson, right?
A. I think thats right. I think he did. I dont know when that happened, but now that you
mentioned -- not by me. I wasnt -- somebody else.
Q. And you were in communication with that attorney representing David Schwartz,
correct?
A. Who was the lawyer? I dont remember. Who was the lawyer in that -Q. Im questioning you. So Im just asking you.
A. Oh, you dont want to answer my questions. Its not so much fun. Okay.
Q. Do you recall that June Chandlers ex-husband then tried to sue Michael Jackson as
well?
A. I wouldnt have remembered it, but now that youve said it, I kind of remember that he

did. And I almost remember the name of the lawyer who had it, because he was a guy I
used to litigate against. But I may be wrong.
Q. In response to Prosecutor Sneddons questions, you indicated that the case was
referred to you by a lawyer for the Chandler family, correct?
MR. SNEDDON: Im going to object, Your Honor.
THE WITNESS: No.
MR. SNEDDON: Its vague as to what case.
MR. MESEREAU: Let me rephrase it. If its vague, Ill rephrase.
THE COURT: All right.
Q. BY MR. MESEREAU: Regarding your representation of Mr. Chandler, Mrs. Chandler,
and their son, did you say, in response to the prosecutors questions, that that case was
referred to you by another lawyer for the family?
A. What I want to correct is, if you take the family part out of it, I can answer it. Yes, it
was referred to me by a lawyer, but that lawyer who referred it to me wasnt representing
the family, per se.
Q. Was representing the father?
A. He was representing the father.
Q. His name was Barry Rothman, correct?
A. No, no, no, no. No.
Q. Who referred the case to you?
A. The guy that referred to me was a criminal defense lawyer, who was Bob Shapiro, who
was defending the father where these -- long before I ever got in the case, there was
these charges of extortion going back and forth between the father and the Jackson camp,
and it was long before I got in the case. In that case there was a criminal defense lawyer
representing the father, and that criminal defense lawyer brought the family to me. But he
was only representing the father, and he was only representing him criminally.
Q. Okay. Now, and Robert Shapiro, of course, is the Robert Shapiro who defended O.J.
Simpson, correct?
A. Thats correct.
Q. He was defending the father against claims that the father had tried to extort money
from Mr. Jackson, correct?
A. Time out. I think thats wrong. Let me go back. He may have been the lawyer not for
the father, but for -- now I got -- I think he represented Rothman, the lawyer, the lawyer
who was in the case before I ever got in the case. I think he, too, was accused of
extortion by someone on the Jackson side.
Q. Okay.
A. And I think he -- one of them -- and I think 4554 Richard Hirsch, who was also a
criminal defense lawyer, represented the father, or -- thats what I think really happened.
But somehow Shapiro and Richard Hirsch, who are two criminal defense lawyers, advised
the family that they had the wrong civil lawyer and they should come see me. And thats
basically how I got there.
Q. They advised the family that Gloria Allred was the wrong lawyer and they should come
to you, correct?
A. Thats what I understand.
Q. Okay. Now, there was a lawyer named Barry Rothman involved, correct?
A. Before Gloria Allred.
Q. And Barry Rothman represented the father, true?
A. Well, thats a good question, who he represented. I thought he -- he represented

probably the father and Jordie, I suspect. I mean, its unclear to me, that whole deal.
Q. And Rothman is a lawyer that was accused of extortion by people associated with Mr.
Jackson as well, correct?
A. I think both Rothman and Jackson -- I mean, Rothman and Jackson, Im sorry.
Rothman and Evan Chandler were accused of extortion by the Jackson side. I dont know
who on the Jackson side.
Q. And Attorney Barry Rothman has since been disbarred, correct?
A. I dont know. Has he?
Q. Yes.
A. I didnt know him before, I dont know him now. And if he is, he is. I dont know.
Q. So you dont know him at all?
A. I dont know Barry Rothman.
Q. You had various meetings with him during this litigation, did you not?
A. No.
MR. SNEDDON: Im going to object as immaterial and irrelevant.
THE COURT: Sustained.
THE WITNESS: No, I -- well, it -- oh, it was sustained, so....
Q. BY MR. MESEREAU: You typically enter into a contingency fee agreement at the
beginning of your relationship with the client, correct?
A. At the early stages, yes.
Q. And the obvious purpose of that is, before you want to do any work, you want to make
sure youre going to get paid if certain things happen, correct?
A. Yes.
Q. And before I go any further, you talked about people you have represented in your
practice. Youve also represented oil companies in recent years, correct?
A. Yes.
Q. Youve defended oil companies accused by the State of California of overcharging
consumers, correct?
A. Yes.
Q. And youve represented them quite successfully, havent you?
A. Well, that was one I represented, and it was a very successful -Q. It was a long trial, true?
A. It was a long trial.
Q. Okay.
A. First time and only time in my life that I ever did anything like that.
Q. Okay. And what year was that?
A. Lets see. I defended them -- is this important? I mean, I cant remember. Lets see, I
have enough trouble remembering who Im representing today. Lets see, I represented
them, I want to say late -- lets see. Somewhere around late 90s, 2000. I mean, it could
have been -- its one way or the other. I cant -- I was called in just to try the lawsuit. And
the case had been going on for like 20 years, believe it or not, and -- and so I just -- I
cant give it -- if its important, I could figure it out, but its somewhere then. 4557
Q. Somewhere where?
A. Somewhere 1999, 2000, 2001. 1998. It -- you know, a few years ago this happened.
Q. Now, in the 1993 case, you retained Stanley Katz, correct?
A. Yes.
Q. When had you first met Stanley Katz?
A. 1987.

Q. And that was in relation to a civil lawsuit?

A. No. I represented -- in fact, my wife really represented -- and she wasnt my wife then.
But I got called in to represent the -- a former grandson of the President of the United
States who was being accused of physical abuse, him and his wife. And I knew nothing
about that kind of a field, never done anything like that, but ultimately, I did it. And
Stanley Katz, who I never knew of or heard of, was an expert on the case. And if you ask
me what -- I dont even remember what he testified to, but he did testify. And it was a
case downtown in the criminal courts building.
Q. So this was a case where two adults were accused of abusing a child?
A. Yeah, by the Department of Children Services.
Q. And you and -- excuse me. You defended the -A. I defended -Q. -- the parents, true?
A. The parents, yes.
Q. And you did it successfully, correct?
A. I did it successfully.
Q. Stanley Katz was an expert for you
A. He was.
Q. -- right? So Stanley Katz knew that in this particular case, adults were falsely charged
with sexual assault, correct?
A. No. Well, charged by the government, not by the kid. The kids -- there was a baby, it
was one-year-old. He wasnt accusing anybody of doing
anything. This was the county. The kid was abused, there was no issue, Mr. Mesereau.
The child was abused. The question is, did the maid abuse the child or did these parents
abuse the child? And in my view and in the Courts view, the maid did it, and we proved it.
Q. But just to get it in the record -A. Yeah.
Q. -- you, with the assistance of Stanley Katz, defended two adults against false claims of
abuse,
correct?
A. By the government, yes.
Q. Okay.
A. And I do remember what he sort of testified to, if its important to you. 4559
Q. When were these false claims by the government initially filed; do you know?
A. Yeah. I assume its 1987, because thats when I did it.
Q. How long were you involved in that case with Stanley Katz?
A. Well, Stanley Katz testified. He was on the stand and got off the stand. But, I mean,
the case was ongoing. And I think we tried it -- took like five days or so to try it, six days.
And that was it.
Q. And was that tried in front of a judge or a jury?
A. Judge.
Q. Was that in the administrative courts or the criminal courts?
A. It was in the criminal court building. A regular judge.
Q. Was it a criminal case where a jury was waived?
A. No, it was a dependency case. They were trying to take the children -- the child away
from
these parents who had adopted this child.
Q. And it was just solely a judge who decided the governments claims of abuse were false

against your clients, right?

A. Thats correct.
Q. All right. Now, at some point you call Lieutenant Klapakis in this case, correct?
A. I called him or he called me.
Q. Okay. Do you know about when that was?
A. Yeah. About. I mean, it was in -- Im going to say around June of 03. I think he must
have called me. I dont think I would have called him. I never heard of him.
Q. It was approximately June 13th, 2003, correct?
A. I wouldnt disagree with that. I dont have an independent recollection of the day, but I
wouldnt disagree about the time frame.
Q. Would it refresh your recollection if I just show you a police report?
A. If you tell me -- unless that day is critical to you, Ill look at it. I dont know, is it a
police report of what he says about me?
Q. Yes.
A. I dont know. Its up to you. Its your show. I dont remember the precise day. Id
accept its about that time. If you told me it was the14th, Id believe you. And if you told
me it was the 12th, Id believe you.
Q. Would it refresh your recollection if I -A. You got to show me. I know that trick. Show me the document and Ill tell you if it
refreshes my recollection. How do I know unless you show it? It doesnt refresh my
memory.
Q. Have you had a chance to look at the report?
A. I have.
Q. Does it refresh your recollection about the day that you spoke to Lieutenant Klapakis?
A. I know I spoke to him. It doesnt refresh my recollection about the date. But as I said, I
cant argue with that date.
Q. Had you spoken with Lieutenant Klapakis before that date, to your knowledge?
A. You know, not by name. I mean, I dont know the person, to my knowledge. But I
wouldnt know him if hes in this courtroom.
Q. Have you met with anyone representing the government to discuss your testimony in
this case?
A. In a loose way. When you say -- I mean, the government interviewed me about my
testimony.
Q. When did anyone with the government last interview you about your testimony?
A. I guess yesterday.
Q. And who was in the meeting?
A. Mr. Sneddon.
Q. Anyone else?
A. No.
Q. How long was the meeting?
A. Besides locking myself up in his office and having to set the alarm because I couldnt
get out because it was after hours. If you dont count that time, it was probably an hour
and a half, maybe two hours, somewhere in that range.
Q. Was Mr. Sneddon alone?
A. Yeah, I thought I said that.
Q. There was no sheriff present?
A. No.
Q. No other prosecutor present?

A. No.
Q. Okay. So you and Mr. Sneddon, for an hour and a half yesterday, discussed your
testimony, right?
A. Yes.
Q. Were you shown any documents by Mr. Sneddon to help you prepare for your
testimony?
A. No.
Q. At any time did any representative of the government send you documents to review to
prepare you for your testimony?
A. They -- take out the prepare me for my -- they did send me my grand jury transcript.
Q. And did you review that?
A. Yes.
Q. Okay. When did you review it?
A. Within the last week or ten days. Two weeks. Something like that. I mean, at some
point when I got it, I read it.
Q. When did you last talk to Stanley Katz?
A. He called me when he left here from testifying on the way home.
Q. Did you talk to him before that?
A. He called me while he was waiting up --well, I dont know where he was waiting, but he
was waiting to testify, and he called me. Or I think he called me. He called me -Dickerman called me and he had a cell phone. They were both in some room together.
And I said, Is Katz with you? And he said, Yes. And he had previously called me, and
so I returned his call after I got done talking to Dickerman.
Q. Let me just get this straight. You talked to Mr. Katz?
A. Doctor. Doctor.
Q. You talked to Dr. Katz after he testified here, right?
A. After he testified, he called me on the way back to L.A.
Q. You talked to him as he was waiting to testify, correct?
A. I talked to him while he was waiting to testify.
Q. You talked to Mr. Dickerman as he was waiting to testify, correct?
A. I talked to Mr. Dickerman while he was waiting to testify.
Q. Did you talk to Mr. Katz before he came here to testify?
A. Yes.
Q. When was that?
A. I cant tell you the day. I can tell you that he called me and wanted to come to my
office and meet with me.
Q. Did you -A. I cant remember when it was. It was sometime during the -- this trial. I cant picture
exactly when it was.
Q. Did you talk to Mr. Dickerman before he came here to testify?
A. No, I dont think so. You dont mean ever. You mean -- I mean, I talked to Dickerman a
lot at one point, and then we really havent had contact. And then we had contact that
day, the day while he was here, and thats about it, that I remember. I mean, I cant
swear we didnt have a minute conversation at some point.
Q. So Stanley Katz wanted to come to your office to talk about this case?
A. Yes.
Q. And approximately when did he make that request?
A. Within the last couple of weeks. Maybe a month. Its between two weeks and a month.

Q. To your knowledge, has Stanley Katz ever met with Bill Dickerman, other than the fact
they were in the same room waiting to testify and both spoke to you on the phone at
essentially the same time?
A. Well, Katz came to see me to tell me that he -Q. Im not asking you what he said. Just -A. No, let me just -- let me think to myself. When he came to visit me after the first
meeting he had with the family -- I think he had two meetings with the family, but I wont
even swear to that. But I think he did. But -- and maybe he had more. But in between one
of these meetings that he had with the family where he was interviewing, he came to see
me, Dr. Katz, and it is possible that Dickerman was in that meeting. It is possible he
wasnt in that meeting. I dont know. And that would be the only time that I can think of
that they possibly could have been together.
Q. When did that meeting occur?
A. Do you mean the day?
Q. Not the specific day. Just roughly.
A. That meeting happened -- if I knew the day I went to the Department of Children
Services, which has got to be -- if you tell me that this lieutenant called me on the 13th, I
would guess I went to Children Services around the 12th of June. 11th, 12th of June. So
that would mean that that meeting happened before then, and after, say, June 1st. So, in
that time frame.
Q. Is it your understanding that other than interviewing members of the Arvizo family, Dr.
Katz did not pursue any other independent investigation?
A. Thats all -- thats all I know he did.
Q. Okay. To your knowledge, are you related to anyone who has referred patients to Dr.
Katz?
A. Not that I know of.
Q. Okay. You dont know of any -A. That referred patients to Dr. Katz?
Q. Anyone who you are related to by marriage that referred patients to Dr. Katz.
A. Oh, my wife. Im married to my wife, and I think she used Dr. Katz. She headed up a
law firm that defended children, and represented tens of thousands of children, and I
think they, from time to time, might have used Dr. Katz. I dont know if she did or didnt.
I mean, she certainly -Q. But you think she did?
A. Yeah. I mean, I know at times in her life she did. Shes the one that introduced me to
Dr. Katz in 1987, so she was a fan of Dr. Katz.
Q. And it was your understanding they had some kind of business relationship, but you
dont know what it is, right?
A. My wife and Dr. Katz? Well, they didnt have a business relationship. She would refer
clients. She defended people accused of abuse. She represented children against their
parents when parents were abusing them. And she headed up a public interest law firm,
and she would use Dr. Katz, and -Q. Okay.
A. -- hopefully it was totally business. (Laughter.)
Q. Did you ever learn that Dr. Katz was secretly recorded by the Santa Barbara Sheriffs
Department in a phone conversation?
A. Yes.
Q. How did you learn about that?

A. He told me.
Q. Did he tell you that on a number of occasions he referred to the lawsuit in discussing
the Arvizos?
MR. SNEDDON: This is hearsay, Your Honor.
THE COURT: Overruled. You may answer.
THE WITNESS: Did he -THE COURT: Do you want the question read back?
THE WITNESS: I just got to ask him, did he tell me what about that?
Q. BY MR. MESEREAU: That in that secretly recorded conversation with a sheriffs
representative, he, on a number of occasions in discussing the Arvizos, referred to the
lawsuit?
A. Did he tell the sheriff that, or did he tell the Arvizos that?
Q. The sheriffs that.
A. Oh. I dont know.
Q. You dont know about that?
A. I dont know one way or the other about that.
Q. But he told you he was secretly recorded, right?
A. He told me that he was secretly recorded by the sheriffs, yes.
Q. All right. To your knowledge, have you ever been secretly recorded in this case?
A. I hope not.
THE COURT: You need to speak closer to the microphone.
THE WITNESS: I hope not. I dont know of any recordings, no.
Q. BY MR. MESEREAU: Do you have any knowledge, other than what Mr. Katz told you,
about the sheriffs secretly recording people in phone conversations in this investigation?
A. No, I really dont. I just know he said he was recorded. I know it was secret. He didnt
know about it, so I guess it was a secret from him.
Q. How long, in your mind, did you represent the Arvizos?
A. Boy, thats the toughest question youve asked. I can tell you I represented them from
May to the time I referred it to the police, or referred 4569 it to Mr. Sneddon and the
police took over. And I had no contact, the best that I can recall, with the Arvizos, and
that ultimately culminated in a letter from me to them terminating my relationship with
them. I didnt want any responsibility. I didnt -- and I didnt talk to them again until after
the news hit of the search of Neverland and the pending arrest of Mr. Jackson. And it was
sometime after that that I heard from them again. But up -- so from my perspective, I
terminated our relationship legally, as a lawyer should do, in writing, telling them they
could do what they want, But dont look to me to represent you.
Q. And if you chose to in the future, Mr. Feldman, nothing would prevent you from
representing
them again, correct?
A. If I wanted to?
Q. Yes.
A. If I wanted to, nothing.
Q. Now, have you represented Mr. Jay Jackson in your legal work?
A. Well, only to the extent as I -- he has talked to me about issues of you guys trying to
get into -Q. Objection. Im not asking you what hes talked to you about. Im just asking, have you
represented Jay Jackson as a lawyer?
A. Well, when you say represented, he has called me in my capacity as a lawyer, and I

have given him advice as a lawyer.

Q. And approximately when did you give Jay Jackson advice as a lawyer?
A. Well, I dont know. Lets see. After they got married, which I dont remember when, but
it was after they got married. And it was -- you would know better. It was in connection
with a search warrant. Or, not a search warrant. A subpoena you served on his military
records, and thats the only time that I think I can remember talking to him.
Q. Well, you certainly were advising him as a lawyer as of approximately November 15th,
2004, correct?
A. I dont know the date. I just -Q. Well, your firm, in a legal proceeding in this case, took the position that a fax from Jay
Jackson to you dated November 15th, 2004, was confidential, right?
A. If Jay Jackson communicates with me, its in the attorney-client. Thats what I said.
And everything he told me is privileged, just like any other lawyer.
Q. Do you know whether or not your law firm has taken a position in this case that a fax
from Jay Jackson to you of November 15th, 2004, is confidential and privileged?
A. Well, I hope so, since it is.
MR. SNEDDON: Your Honor, Im going to object.
THE COURT: Sustained. Youre not allowed to go into attorney-client privilege without my
permission.
MR. MESEREAU: Im not going into it, Your Honor. Just their position.
THE COURT: Well, even claiming the privilege is improper, to raise it in front of the jury.
Weve gone over this before.
Q. BY MR. MESEREAU: You have represented the parents of Janet Arvizo in this case,
correct?
A. Her parents.
Q. Yes.
A. Yes.
Q. You represented them in an attempt to prevent us from seeing if she deposited money
into her parents account, true?
A. I prevented you from getting into their -- these parents bank records.
Q. Correct.
A. Thats right.
Q. And in doing that, sir, you tried to prevent us from seeing, if Janet got checks or David
Arvizo got checks, whether they deposited them into her parents account?
A. No, Mr. Mesereau, I prevented you from dragging in these poor parents, who dont
even speak English, into this melee.
Q. Do you know -A. Thats all I tried to do. I dont know anything about Janet doing anything. Im only
telling you -- you asked me what I did. Thats what I tried to do is prevent them from
getting dragged in. If you look at your subpoena, its pretty broad.
Q. Sir, you cant prevent the parents from being subpoenaed as witnesses in this case,
can you?
A. No.
Q. And you havent even tried to do that.
A. And I wouldnt.
Q. The only thing you tried to do was stop us from seeing whether Janet put money into
her parents account?
MR. SNEDDON: I object as argumentative.

THE WITNESS: Thats not true.

THE COURT: Just a minute. Theres a lot of law and motion in this case that took place
outside the presence of the jury, and theres various legal reasons why things were done,
and I did them. And its improper for you to be attacking a witness on that issue.
MR. MESEREAU: Yes, Your Honor. I will I withdraw the question. May I just ask about
the scope of his representation, just when he did it, when he represented the parents? Not
scope, Your Honor.The dates of it.
THE COURT: Im not sure if thats a privileged matter or not. Thats why Im concerned.
MR. MESEREAU: It would have to do with statements hes made before, Your Honor,
about representing the Arvizos. Im just trying to find out roughly when he represented
the parents.
THE COURT: No. I dont see any relevancy.
MR. MESEREAU: Okay. Your Honor, may I ask if he still does?
THE COURT: No. I dont see any relevance to -MR. MESEREAU: Okay.
THE COURT: -- to people he represents, when he represented them. If Im missing
something, you can approach the bench. Im, you know, trying to see from this standpoint
what the relevancy could be, but I cant see it.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: (To the jury) Okay. You can talk. (Discussion held off the record at sidebar.)
THE COURT: All right. After reviewing with Mr. Mesereau his reason, Im going to allow a
question that I didnt a moment ago. You may ask it.
Q. BY MR. MESEREAU: Mr. Feldman, during what approximate period of time did you
represent the parents of Janet Arvizo in this case?
A. I cant give you the date. The event was when they were served with a subpoena, their
bank got served with a subpoena to get all of their checks and all of their financial
records. And whenever you served that subpoena, that is when I represented them.
Q. Do you currently, as far as youre concerned, represent either of the parents of Janet
Arvizo?
A. I do not represent either of the parents of Janet Arvizo, as far as Im concerned.
Q. Would it refresh your recollection if I just show you a pleading just so you can identify
a time that you were representing the parents?
A. Sure. Yeah.
MR. MESEREAU: Would that be all right, Your Honor?
THE COURT: Yes.
MR. MESEREAU: May I approach?
THE COURT: Yes.
MR. MESEREAU: Thank you.
Q. Mr. Feldman, have you had a chance to review that document?
A. Yes. Yes.
Q. And does it refresh your recollection about the period of time during which you
represented David and Maria Ventura, the parents of Janet?
A. Approximately.
Q. And approximately what was the period during which you represented and your firm
represented David and Maria Ventura?
A. Approximately the end of December of 2004 to January 2005. Three, four weeks.
Q. That would be till approximately what, January 14th?
A. I thought thats the date of the hearing that we had, yes.

Q. Okay. And after that hearing, did your representation cease as far as youre concerned?
A. Yes. It was just for that limited purpose on that subpoena.
Q. Okay. How many meetings do you think youve had with Mr. Sneddon about this
criminal case?
A. And Im going to interpret meetings face to face. Is that what were talking about?
Q. Lets start with that.
A. I would say three, four, maybe five at the most, including yesterday.
Q. And how many times do you think youve spoken on the telephone with Prosecutor
Sneddon about this criminal case?
A. Well, I dont know. Maybe -- at least two or three times Ive been scheduled to come,
and hes called me to tell me Im not coming. So thats three. We havent had a lot of
phone calls. I cant -- frankly, I called him when I called him to say, Heres the case. Do
what you want with it. And maybe -- I dont know. You know, five, six. Something. Not a
lot. I mean, I dont know, something like that.
Q. How many times do you think you met with Mr. Sneddon regarding your representation
of Mr. Chandler in 1993?
A. I dont know if I ever met with him in 93. With Mr. Sneddon?
Q. Yes.
A. 93 I was on my own, without -- I was handling -Q. You certainly spoke to him.
A. I was handling the case. Im sure I spoke with him, but I dont think I ever met with
him. Maybe I did. I could have. I just cant remember, Mr. Mesereau. Its so long ago. I
mean, thats 12 years ago. I just dont -- I just dont have an independent memory of
whether I did or didnt. Because the case was also in L.A., and, you know, I was dealing
with the L.A. lawyers, criminal lawyers.
Q. Would it be accurate to say that you at least talked to Mr. Sneddon a number of times
in 1993 about your representation of Mr. Chandler?
A. You know, not Mr. -- Mr. Chandler now is little Jordie, whos now a Mister, or is it his
father were talking about? When you say Mr. Chandler, Jordie? Who are we talking
about?
Q. Any of them.
A. You know, I dont think -- it could have happened. I cant deny it. I just have no
recollection of it one way or the other. I dont remember having many -- any real
discussions with Mr. Sneddon on the case.
Q. Do you remember meeting with any other prosecutor besides Mr. Sneddon at any time
regarding this current case?
A. Yes.
Q. And who would that be?
A. Mr. Zonen.
Q. How many times do you think youve met with Mr. Zonen about this case?
A. A couple maybe. Maybe. I dont remember. You know, I can remember one. Ive seen
him, though. I mean, this isnt just the second time Ive seen him, so it must have been
more, but I just -- nothing stands out in my mind about meeting with him.
Q. Have you had phone conversations with Prosecutor Zonen about this case?
A. Yes.
Q. Approximately how many do you think?
A. A few.
Q. Have you had any other meetings with any other prosecutor on this case besides

Prosecutor Sneddon and Prosecutor Zonen?

A. Some prosecutor that -- my records got subpoenaed to the court, and somebody -some prosecutor, said he was a prosecutor, called me about it, whether I had filed the
documents or
didnt file the documents. I mean, I can remember that kind of stuff.
Q. Have you had any meetings with representatives of the sheriffs department involving
this case?
A. Ill answer that in a second. I just want to go back to something that just -Q. Sure.
A. There was a real issue in this case before it ever got to trial. I didnt want to do
anything, and there was an issue -- so I do think I talked to Mr. Zonen more about, Why
dont you do the objecting and leave me out of this. My law firm doesnt want to do this, I
dont want to do this, and he couldnt represent the victims, so thats how I -- so before I
ever acted, I wanted the D.A. to do all the legal work. Not me.
Q. I understand. And that saved you a lot of money, correct?
A. Pardon me?
Q. That could save you a lot of money in the future?
A. It would save me lot of aggravation and energy, I could tell you that. Not in the
future. Period. I didnt want to do it. Im not representing these people, so -- but, you
know, so I would talk to Mr. Zonen. I want to just amend that, because I would talk to
him, and he would say he cant do that, and Id wind up either doing it or not doing it. So
there were those kind of conversations. Now, back to the sheriffs. Who did I talk to? This
lieutenant, I guess, called me. I talked to him. When I went to the grand jury, there was
somebody who, you know, brought me up here on the freeway and drove me up here to - or I followed through some parking lot to get to where the secret grand jury was, so
somebody talked to me while I was sitting around waiting, those kind of things. But no
sheriff has ever interviewed me. No police officer, to my knowledge, has ever come down
and interviewed me or anything.
Q. How many meetings with any representative of the sheriffs department do you think
youve had in this case?
A. Meetings other than getting me here, logistics kind of things?
Q. Sure.
A. None, I dont think.
Q. Youve never been interviewed by any sheriffs in this case?
A. If I was, I dont remember it.
Q. How many phone conversations do you think youve had with any sheriff in this case?
A. I mean, I dont know who are the sheriffs and who are the police.
Q. How about the name Klapakis?
A. Well, he -- obviously you showed me something that says he called me. But in
deference to the lieutenant, I wouldnt have remembered that. But you did show me that,
so he obviously called me. But thats about it. I dont -- They -- the police cut me out of
this case the minute I gave it to them. They -- in fact, thats why we severed our
relationship. I severed the relationship. I was out of this.
Q. Do you remember you were interviewed on January 16th, 2004, on the NBC Today
Show by Matt Lauer?
A. I went on The Today Show and Matt Lauer interviewed me.
Q. Do you remember that?

A. And if -- thats right before the gag order was issued. I dont remember the date that
the gagmorder was issued, but it was right about that time.
Q. Remember you were asked by Mr. Lauer if you were going to join Mr. Sneddon on the
prosecution team, and you said, I have no comment?
A. I did. I did.
Q. Other than your grand jury transcripts, have you reviewed any other documents to
prepare for your testimony today?
A. No.
Q. Now, you have represented Gavin Arvizo in other proceedings in Los Angeles other
than what you have identified, correct?
A. I have?
Q. Yes.
A. Gavin Arvizo?
Q. Yes.
A. What is that? No.
Q. Have you ever represented Gavin Arvizo in an attempt to stop his juvenile records from
being produced?
A. No. I mean, I wrote a letter, I think. No, not on Gavin. Not that I know of. I didnt even
know he had a juvenile record.
Q. Well, my question is, have you or your firm ever written to Judge Nash in Los Angeles?
A. Oh, thats a different story. Thats not his juvenile records.
Q. Why dont you explain.
A. Thats his Department of Childrens Services records. Yes. I wrote to Judge Nash, who
heads up that department, and said that those records should remain confidential,
because they are confidential under the law. And that children ought to be able to go to
the Department of Childrens Services and tell whatever they want to tell and it ought not
be used in any public forum.
Q. When did you represent -A. Whenever somebody was trying to get them.
Q. And over what period of time was this, do you think?
A. How long you were trying to get them?
Q. Im just asking -- let me rephrase the question. Over what period of time do you think
you represented any of the Arvizo children in that particular area?
A. From the moment I found out the -- Judge Nash wrote to me and said they were trying
to get -- I dont want to get this confused, because also my recollection is they were
trying to ge Jordies records.And I got a letter from Judge Nash. I didnt solicit it. He wrote
to me and wanted to know whether or not on behalf of these children, it was either you -maybe it was the press. I dont remember who wanted to get these records. Somebody
wanted to get these confidential records. And I wrote on behalf of Jordie and I wrote on
behalf of Arvizos probably, that we did object. We -- thats what we did. We didnt have a
hearing or anything. But, I mean -Q. You also wrote on behalf of Gavin, Star, and Davellin to prevent release of juvenile
court records, true?
A. Do you mean criminal records, like juvenile criminal?
Q. Juvenile court records. Yes or no, sir?
A. Well, I dont know what you mean by it, so I cant answer it yes or no. I just told you
what I remember. It was the Department of Childrens Services. I dont even know that
Gavin had -- I mean, I cant help you, because --

MR. SNEDDON: Unless counsel is going to produce something to show in good faith that
hes asking that question, I object to the question and ask that the question and the
answer be stricken.
MR. MESEREAU: I have some correspondence that I was going to try to refresh the
recollection of the witness, Your Honor. But I can move on, if the Court wants me.
THE COURT: The questions ambiguous, since the juvenile court covers several
jurisdictions.
MR. SNEDDON: Does that mean my motion is granted, then, Your Honor, to strike?
THE COURT: Strike his answer?
MR. SNEDDON: Yes, sir.
THE COURT: No. Go ahead. Next question.
Q. BY MR. MESEREAU: Mr. Feldman, have you represented Gavin, Star and Davellin
Arvizo in proceedings in the Juvenile Division of the Superior Court of Los Angeles when
representatives of the media tried to obtain any juvenile court records they might have?
A. Well, you keep saying -- I dont know that they have any criminal juvenile court. Thats
what I think about the juvenile court, as a criminal court for juveniles. I -- to my
knowledge, I never heard of this, to this second, that there was -- I did represent them in
the Department -- in the dependency court in the County of Los Angeles. And in that, I
objected to the media, to you, or anyone else, ever seeing those records. Yes. Theyre
supposed to be confidential. Now, I dont know what happened.
Q. Now, would it refresh your recollection on this issue if I show you a letter to you from
the Superior Court, Juvenile Division, Los Angeles?
A. Yes. Judge Nash?
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: I dont know if it will refresh my recollection, but Ill try. Yeah, but its -no, let me see. Let me see. Yeah, yeah. Im right. Its just what I told you. Judge Nash is
the supervising judge -Q. BY MR. MESEREAU: Mr. Feldman, let me just -- please.
A. Oh.
Q. Have you had a chance to look at that letter?
A. I have. I have. And its exactly what Ive said.
Q. Is it a letter to you of February 5th, 2004 -A. I didnt look at the date.
Q. -- Re In the Matter of Gavin, Star, and Davellin Arvizo, from Terry Tran, Research
Attorney, from the Office of the Presiding Judge -MR. SNEDDON: Your Honor, Im going to object to counsel reading this. The question is
does it refresh his recollection.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Have you had a chance to review the letter?
A. I have.
Q. Does it refresh your recollection about whether or not you represented the Arvizo
children on that issue?
MR. SNEDDON: Object as vague.
THE WITNESS: Whats -THE COURT: Sustained.
Q. BY MR. MESEREAU: Mr. Feldman, does that letter refresh your recollection about
whether or not you ever represented Gavin, Star or Davellin Arvizo on the issue of

whether or not any juvenile records should be disclosed from the L.A. Superior Court?
A. Sir, I am going to tell you that does refresh my recollection, and it says exactly what I
just told you. The news media was trying to get their records from dependency court.
Judge Nash is the head of the whole juvenile system for Los Angeles at that time. He was
the presiding judge. He asked me if I objected, and I did object, and I do object, and I will
always object for these child dependency records to ever leave that courthouse, because
children are supposed to be able to go there and be protected, not have to worry about
the media or you, or anybody else attacking those children.
Q. You did represent them on that issue, true?
A. Thats true.
Q. Thank you. Do you know how long you represented the Arvizo children on that issue?
A. Oh, you know, I got a lot of letters on that. It wasnt just one. So you showed me one.
What was the date? You said February 05? But if you asked me, I would have said I got
one before that, frankly.
Q. February 5th, 2004.
A. Oh, 04. That would be more likely. And over the period of time -- I mean, I know
Judge Nash, and so over time I think they had written me letters, like I said, on behalf of
the Arvizos and on behalf of the Chandlers asking for whether we objected to him
releasing it to the media. I think theres a procedure that they have to do that. But I may
be wrong on that. This is not my field.
Q. You told the jury that at some point you personally contacted the Los Angeles
Department of Children & Family Services regarding this particular matter, correct?
A. Yes.
Q. And you did that with Stanley Katz, correct?
A. Yes.
Q. To your knowledge, was Mr. Dickerman involved in that approach?
A. Did Dickerman go with us, was that the -- I dont know what you mean.
Q. Well start with that. Did Dickerman go with you?
A. No, he did not.
Q. Did Dickerman discuss it with you?
A. I am sure that -- I mean, I didnt just do this, because when you do this, there could be
serious ramifications for the family.
Q. Im just asking you, sir, to answer the question.
A. Well, Im trying to remember.
Q. Did Mr. Dickerman participate with you in any event?
A. He didnt go with me, I can tell you that. Whether or not I ever discussed it with him, I
thought
Q. Pardon me?
A. I mean, thats hard to remember. I certainly should have. I mean, in the normal
course, I should have told him that this was what I was going to do, and this is what I
thought might or possibly could happen. I mean, because I had to tell the parents what
was happening, or the mother.
Q. Do you have any knowledge of the case Janet filed against J.C. Penney?
A. Just what I read.
Q. Have you ever been in contact with any lawyers for Janet Arvizo who represented her
in the J.C. Penney matter?
A. Well, when you say contact, yeah, I tried to -MR. SNEDDON: Excuse me, Im going to object as immaterial.

THE COURT: Just a minute. Sustained.

Q. BY MR. MESEREAU: Do you remember ever meeting someone named Jamie Masada
in your office?
A. I remember Mr. Masada coming to my office for the first meeting and me not letting
him in my office. Thats -Q. Did he remain in the lobby, to your knowledge?
A. He did. I wouldnt let him in.
Q. Was it your understanding that he had transported the Arvizos to your office?
A. I dont know how they got to my office, but he was there with Mr. Dickerman, and I
wasnt letting him in.
Q. You werent letting him in because it could affect the attorney-client privilege, right?
A. Thats right.
Q. Explain that, if the members of the jury dont know, what you meant.
A. Sure.
Q. Why dont you explain that.
A. Give me break, huh? The privilege is sacrosanct. If you tell me something as a lawyer, I
can never tell anybody what youve told me. If I have a third party in that room with me,
then that privilege, there is no privilege. It no longer remains confidential. So good
lawyers will never let somebody other than the client in their office to talk to them
because you lose the privilege if they want to tell you something. The exception to that,
sort of, is with children, because children have to act through a guardian, so youd have
their parents in with you. But generally thats what it is. Mr. Masada wanted to, because I
think he was a friend of theirs is what I gathered at the time, wanted to be there to give
them moral support or whatever, and it wasnt going to happen on my watch. And I said
that he could not come in, and he accepted that, and I guess he sat out there. I cant
frankly -- I dont remember Mr. Masada, other than that.
Q. All right. Have you talked to him on the phone at any time?
A. Masada?
Q. Yes.
A. Not that I know of. I dont think I did.
Q. Okay. Was it your understanding he was a friend of the Arvizos when you met him?
A. You know, I didnt know if he was a friend of theirs, or a friend of Dickermans, or a
friend of both. I frankly didnt quite get where he fit in all this at that point. I knew he was
a friend of Dickermans, and I just couldnt -- I didnt know really.
Q. Okay. Who contacted you about testifying before the grand jury?
A. I guess Mr. Sneddon. Either Mr. Sneddon or Mr. Zonen. One of them.
Q. Before you testified to the grand jury, did you discuss your testimony with Prosecutor
Sneddon?
A. Lets see. Thats a good question. I mean, I can tell you nobody -- I just -- not that
day, thats for sure. I mean, I dont -- I dont really remember that, frankly. I know I
didnt that day. I just sat down in some room, and they called me in and they asked me
questions.
Q. Did you discuss your testimony that you gave before the grand jury with anyone
associated with the prosecution before you gave it?
A. I should know that. I dont remember that. I mean, I dont remember it, frankly. They
may have called me at some time on the phone, but there wasnt any in-depth
conversation about this, that I can remember, in anticipation of my testimony.
Q. Did anyone ever tell you what questions they were going to ask you in the grand jury

room?
A. No.
Q. No one ever even came close to the subject?
A. The subject came up about the privilege, and I was very concerned about the privilege,
and that I remember talking to somebody about.
Q. Well, you took the position it was waived in that proceeding, didnt you? 4592
A. I didnt take the position. The prosecution took the position it was waived. And it was.
But I was concerned long before it got waived when I was told that I might go -- that they
wanted me. I like being a lawyer, Mr. Mesereau. I dont like being a witness. You might
understand that. And Im much more comfortable where you are than where I am right
now. And so when -- when it was approached that I was going to become a witness and
testify, I was concerned about the privilege, and I wasnt about to testify unless there was
a written waiver by the children and the Arvizo -- Miss Arvizo, if they were planning on
asking me what she said to me, and where we are, and what I did, and why I did it. And
they obtained a written waiver.
Q. We can move on from that subject.
A. Okay.
Q. In May of 2004, you represented Janet Arvizo in an attempt to stop NBC from obtaining
West Covina Police Department records, correct, of Janet?
A. Yes. I sent them a letter, I mean, saying she objected to it.
Q. Did you do anything besides send a letter?
A. We certainly -- to my recollection, we didnt file anything. I think we sent a letter. They
said, If you object -- they sent a letter. I think the police sent a letter or something, said
they were going to release it, if you object or dont object. So we objected, because she
didnt want her picture -- it was about her picture, the mug shot of her picture going on
television. She was worried about. And we got assurance that nobody was going to do
that, put her picture on television, since she -- her privacy was being invaded already.
And so we -- once we got assurance that wasnt going to happen, I think thats what we
did. So we objected, and I think the lawyers for the media gave us that assurance that
nobody would do that, or something. Thats what the concern was.
Q. When you filed your claim against Los Angeles County -A. Yes.
Q. -- on behalf of Janet Arvizo, Star Arvizo, Gavin Arvizo, and Davellin Arvizo, where did
you file it?
A. The County of Los Angeles.
Q. Did you have any further correspondence with them after you filed it?
A. With the county?
Q. Yes.
A. Yeah. I think so. We wanted them to investigate and they werent investigating how
this thing got leaked, and -- so I had several letters back and forth with Mr. Saunders,
and then when we filed the claim, some claims adjuster for the county I think sent a
letter.
Q. Now, Mr. Feldman, you previously told the jury that you dont have knowledge of the
J.C. Penney case, correct?
A. No, I didnt say that. How could I not? It was all over the news. I mean, I hear it every
day. I mean, I dont have any -- I mean, I didnt say that.
Q. Well, Mr. Feldman, in June of 2004, you tried to stop the release of records involving
the J.C. Penney case on behalf of the Arvizos, correct?

A. We wanted the records for Janet. Mr. -- the lawyer that represented him -- them took
the position we couldnt have them unless we gave them to Janets husband. And since
Janets husband was having a love affair with the media at that time, and he was on
television every day, we werent going to let those records go out to him because we
thought he would use them against her. And so we were trying to get the records, and we
never got them.
Q. But you tried to stop the City of West Covina from releasing arrest records of Janet in
that case?
MR. SNEDDON: Im going to object as asked and answered.
THE WITNESS: It was the picture. It was the picture.
THE COURT: Objection sustained.
MR. MESEREAU: Let me just take a second,Your Honor, just to look at my notes.
THE COURT: Yes.
Q. BY MR. MESEREAU: Mr. Feldman, do you remember telling two individuals, Michael
Viner and Larry King, that Janet is making up these allegations?
A. Absolutely not. Are you kidding?
Q. Do you remember meeting with those two individuals at The Grill in Beverly Hills?
A. No. Never met with them.
Q. Do you know who Michael Viner is?
A. I couldnt pick him out. I know who he is. I think the answer is I wouldnt know him if
he was sitting in the jury box. But I know who he is by name. Hes -- hes a publisher or
something, or a writer, or -- I dont know. Viner Books, right? Something like that. I
certainly know who Larry King is.
Q. You did have a meeting with him and Larry King, right?
A. I have never had a meeting with Michael Viner in my life.
Q. So approximately nine months ago, you didnt meet with Mr. King and Mr. Viner,
correct?
A. I absolutely have never had a meeting with Michael Viner in my life.
Q. Okay. And did you ever tell Larry King that these allegations against Mr. Jackson are
false?
A. Absolutely not.
MR. MESEREAU: I have no further questions.
THE WITNESS: I dont even know.
MR. MESEREAU: Okay.
THE WITNESS: The proverbial answer.
REDIRECT EXAMINATION BY MR. SNEDDON:
Q. Mr. Feldman, lets go back to the -- and clarify something, if we can. You were involved
at one time in the dependency court involving a case where there was a baby who was
alleged to have been abused; is that correct?
A. Correct.
Q. And was the abuse, the nature of the abuse in that case sexual or physical?
A. Physical.
Q. And how old was this baby?
A. 13 months or -- 12 months or 13 months. It was an infant.
Q. And this was in the dependency court, correct?
A. This was in the dependency court. These parents had just adopted this child, and the

County of Los Angeles was trying to take the child away from these parents.
Q. So the lawsuit involved the County of Los Angeles and the individuals who were
accused, correct?
A. Correct.
Q. You indicated to the Court and to the ladies and gentlemen of the jury that at some
point you did represent, to oppose a subpoena duces tecum the parents of the Arvizos,
correct?
A. Yes.
Q. And what exactly was the objection that you had to that?
A. It was invading their privacy, two grandparents of this little boy, who all of a sudden
the defense wants to get all of their financial records, every check theyve ever written,
every bank account theyve ever done business in.
Q. Was there -A. I thought it was overly broad and unfair to these grandparents, since Im one myself, to
get dragged into this thing.
Q. Did the scope of the records that were requested go far beyond the time frame of the
events involved in this case?
A. I thought it was the most overbroad, overreaching thing, and we objected and brought
it to the Court, to Judge Melvilles attention. And frankly, I dont recall what the Judge
ruled, but thats what we did.
Q. Okay. I want to go back to the Jordan Chandler versus Michael Jackson lawsuit, if we
can for a moment.
A. Sure.
Q. I want to go to that point in time where the case has been settled, its been resolved,
okay?
A. Yes.
Q. Do you recall having a meeting after the case had been resolved and settled in favor of
your client, with members or representatives of the Los Angeles District Attorneys Office
and the Santa Barbara District Attorneys Office in your office?
MR. MESEREAU: Objection. Leading; beyond the scope.
THE COURT: Well, its leading. Ill sustain the objection.
Q. BY MR. SNEDDON: Do you recall whether or not you ever had a meeting with
representatives of the Los Angeles District Attorneys Office and the Santa Barbara District
Attorneys Office in your office after the case had been resolved in favor of your client?
MR. MESEREAU: Objection. Leading; and beyond the scope; no foundation.
THE COURT: Its the same question. Maybe we just ought to call it refreshing his
memory.
MR. SNEDDON: I said whether or not, YourHonor. That doesnt make it leading.
THE COURT: All right. I was trying to be humorous.
MR. SNEDDON: Oh, I guess I lost my humor this morning. You were trying to read my
mind once
before.
THE COURT: Lets take a break. (Recess taken.)
MR. SNEDDON: Judge, I think I can rephrase the question so we can move on. If thats
okay with the Court.
THE COURT: Yes.
Q. BY MR. SNEDDON: Mr. Feldman, Id like to direct your attention to that point in time
after you had resolved the case of Chandler versus Jackson, okay?

A. Yes.
Q. Do you recall at any point having a discussion with representatives of any District
Attorneys Office with regard to your client, Jordan Chandler, appearing before a grand
jury?
A. Vaguely, yes. Vaguely, yes.
Q. Do you recall -- do you recall the substanceof that conversation?
MR. MESEREAU: Objection. Hearsay; foundation; relevance; and beyond the scope.
THE WITNESS: This is -THE COURT: You may answer yes or no.
THE WITNESS: I mean, I cant -THE COURT: Yes or no.
Q. BY MR. SNEDDON: You have to lean into the microphone.
A. Oh.
THE COURT: Do you want the question?
THE WITNESS: Well, yes, and no, Your Honor. I mean, I remember the substance.
Q. BY MR. SNEDDON: Okay. To your knowledge, after the case of Chandler versus
Jackson was resolved, did your client, Jordan Chandler, ever appear before a grand jury?
MR. MESEREAU: Objection. Leading; beyond the scope.
THE COURT: Overruled. You may answer.
THE WITNESS: To my knowledge, he never appeared before a grand jury.
Q. BY MR. SNEDDON: Now, you were asked by -- just before Mr. Mesereau finished his
examination, about a purported conversation between you and Mr. King and Mr. Viner, or
Veener?
A. Viner.
Q. Viner?
A. Viner is what he said.
Q. Yes. And do you recall any such meeting?
A. I never met with Mr. Viner. I did once meet 4601 with Mr. King. I do remember
meeting with Mr. King, but I can tell you there wasnt a meeting with Viner.
Q. Were there other people present?
A. Well, we were in the delicatessen in Beverly Hills, so there were a lot of other people
around.
Q. Where -- were you having breakfast, lunch, dinner? You were in a deli, I assume you
were eating.
A. I was having breakfast with his -- with a producer from their show, who -Q. Whose show?
A. Larry Kings show, and he was sitting at a table, like over here, with -Q. Indicating to your right?
A. Right. With six of his pals that he had breakfast with.
Q. And were you with somebody else?
A. Yes.
Q. Who were you with?
A. I was with his producer.
Q. Who is?
A. Whose name was, or is, Nancy Baker, I think her name was.
Q. Is that the only time you ever recall being in any kind of close proximity with Mr. Viner?
A. Well, Im not even sure he was one of these guys. I didnt have any discussion with any
of those guys about anything, I can tell you. They were trying to get me to come on their

show. Thats all we ever possibly talked about, is -- I knew Mr. King. Ive run into him
since this, I mean, at different events.
Q. By Mr. King, youre talking about Larry King?
A. Right.
Q. The guys on -A. We say hello to each other. We see each other. Talk to each other. Never having talked
about this case, and they did want me to come on their program. I mean, I do remember
them talking to me about that. But I can tell you that I didnt tell them, and I didnt tell
anybody else, anything about what anybody tells me, because it is absolutely privileged,
and it would be absolutely improper. And if anybody says that, that person is lying. Cant
make it clearer than that.
Q. Let me just ask you a couple other questions, or at least one other question about the
Chandler versus Jackson lawsuit. You indicated in response to one of Mr. Mesereaus
questions that the defendant in that case, which would have been Mr. Jackson, were the
ones who wanted the parents to share in the financial or monetary settlement of the
case?
A. Thats right.
Q. Now, that seems counterintuitive. Can you explain to us why that happened?
MR. MESEREAU: Objection. Relevance; foundation; move to strike.
THE COURT: Overruled.
THE WITNESS: The reason it happened was because Mr. Jacksons legal team wanted
confidentiality. They didnt want anybody ever talking about this. And they were
concerned if, in fact, the parents werent getting money -MR. MESEREAU: Im going to object, this is nonresponsive. And move to strike.
THE WITNESS: They said this, Your Honor.
MR. MESEREAU: And calls for speculation and its hearsay.
THE COURT: No, the question was, Can you explain why that happened, and thats
what hes explaining. So -THE WITNESS: They told us that they wanted the parents to get the money so that the
parents would be bound by the settlement agreement, so that the parents couldnt talk,
that the parents couldnt write a book, the parents couldnt go -- I mean, we werent
precluded from talking to the police. We were just -- they werent able to write a book.
They werent able to go on television. They werent able to do anything. And they wanted
the parents bound. And its because of that that I brought in a retired Court of Appeal
Judge to become the new guardian ad litems, because I didnt want the parents taking
anything away from the child.
Q. BY MR. SNEDDON: All right. Now, at the time that you were introduced to the Arvizo
family, did you or were you aware of the fact that Gavin Arvizo had had cancer?
A. Yes.
Q. And were you given information about the severity of the cancer that he had?
A. Yes. Very severe. Life-threatening.
Q. And did the advice that you gave to the Arvizo family during the time that you did
represent them involve considerations about Gavins health?
MR. MESEREAU: Objection. Leading; and beyond the scope; and foundation.
THE COURT: Sustained.
MR. SNEDDON: Your Honor, could I
THE COURT: Its beyond the scope.
MR. SNEDDON: Beyond the scope?

Q. Mr. Feldman, based upon -- well, let me go back and lay one foundational thing. Did
you, during the course -- and I dont obviously want you to disclose anything that was
said, but as a foundational matter, during the course of the time that you did represent
the Arvizo family, and Gavin Arvizo in particular, did you have discussions with Gavin?
A. Yes.
MR. MESEREAU: Objection as beyond the scope.
MR. SNEDDON: Well, I
THE COURT: Overruled. The answer is, Yes. Next question.
MR. SNEDDON: All right.
Q. Based upon your conversations with Gavin and those of the family, and your
experience in civil suits as a trial lawyer, as an experienced litigator, are you able to tell
the ladies and gentlemen of the jury whether, in your opinion, Gavin Arvizo has any
interest in pursuing a suit against Michael Jackson over these molestation charges?
MR. MESEREAU: Objection. Calls for speculation; beyond the scope; foundation.
THE COURT: Sustained.
MR. SNEDDON: Is that a foundational thing, Your Honor, or just in total?
THE COURT: All of them. No, thats not a proper question.
MR. SNEDDON: All right.
Q. Mr. Mesereau asked you a question as to -- when he was asking you about criminal
cases versus civil cases, and why in your opinion it would be 4606 foolish to go criminal
first before you would go civil. Do you recall that?
A. He was saying its easier to go criminal than go civil. Thats what he was -Q. And you said it was foolish?
A. Oh, I said its foolish?
Q. Yeah, not him.
A. Oh, I said its foolish. Yeah, well, if I said it or not, I think it is foolish.
Q. All right. Explain why.
A. Well, part of it is what he just said. As a lawyer, I want to control what happens. I want
to protect this child. The only person that was ever going to be my client, even though
they all signed a retainer, was this child, and -- Gavin, and I wanted to do whats best for
Gavin. The District Attorney represents the People. They have to prove it by beyond a
reasonable doubt. As Mr. Mesereau says, in a civil case, you only have to prove it by a
preponderance of the evidence, more likely than not. And so I would never, if it was -- if I
was going to do a civil case, ever want the District Attorney, the police, any criminal case,
involved with a civil case. In a civil case -- in a criminal case defendants have Fifth
Amendment rights, and they dont have to testify. In a civil case, things are different, and
I would never want to do what Mr. Mesereau said. It is almost inhumane, when you have
a cancer victim, to have him go through a criminal trial, and then maybe he gets
convicted, and then all of a sudden, now hes going to do it again and spend these -these years of his life. I wouldnt do it. I wouldnt be a part of doing it. And I dont know
many lawyers in this -- who practice good law would ever suggest that the District
Attorney start and handle the case. I didnt do it in 93. I wouldnt have done it in 2003.
And I wont ever do it.
MR. SNEDDON: Thank you. No further questions.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Mr. Feldman, do you know that Gavin is not only in remission, hes playing football?

A. I know hes in remission. But I know that stress can impact cancer. And -Q. But you knew he was in remission a long time ago?
A. I know -- I didnt know where he was. Hes better today than he was when I first met
Gavin. Gavins done wonderful physically over the last -- how long has this been? Almost
two years now. Hes doing much better. If you saw him then compared to 460 seeing him
now.
Q. Have you ever been a criminal prosecutor yourself?
A. A criminal prosecutor?
Q. Yes.
A. No.
Q. Are you aware that criminal prosecutors often look to see if civil lawyers are trying to
use the criminal process to win their cases for them?
A. Say that one more time.
Q. Are you aware that prosecutors often, when approached by civil lawyers, are wary to
see if civil lawyers are trying to use them to win their cases for them in the criminal
courts?
A. I wouldnt have any idea what they do.
Q. Youre not changing what you told the jury earlier, that if you have a judgment of a
criminal conviction, you can go into civil court and use it to establish liability just with the
document?
A. Im not changing what I said. If you had a criminal -- were talking about -- no, I
wouldnt change that.
MR. MESEREAU: No further questions.
REDIRECT EXAMINATION BY MR. SNEDDON:
Q. The deadly one more question.
A. Yeah, Ive heard it.
Q. You know, its an occupational hazard.
A. Yes, I know.
Q. Lets just get back to this thing that Mr. Mesereau was just talking about, the impact of
a criminal conviction. For you, as a trial lawyer, could you explain to the ladies and
gentlemen of the jury what the difference is between compensatory damages and punitive
damages?
A. Yeah. In compensatory, youre trying to make a person whole. The jury assesses what
is the losses. In the grownup, you know, it would be loss of income, medical bills, home
care, things of that nature. And pain and suffering or emotional distress. Thats what we
call compensatory, and what the law says about that is the purpose is to make somebody
whole. Punitive damages are something that is on top of that. It is to punish someone who
needs to be punished for bad behavior. In certain places in the law -- not in all cases.
Most cases you cant get them, but in certain places under the law, sexual molestation
would be one. Assault and battery would be another. Fraud, where somebody is guilty of
what we call malice, or fraud, or oppression, is another. And in those, the law says you
got a higher standard of care, still not as high as a criminal case, but you have to prove
malice. And in order to prove malice, you have to prove fault. And its a different fault
than the fault thats in a criminal -- because I dont know what exactly you have to prove
in a criminal case, so I dont want to get too far ahead of myself here. But it doesnt just
follow that you wouldnt have to go back to starting to prove things all over again if you

were to be in a civil case. And you cant tell. You know, a lot of criminal cases wind up
hung juries. I mean, its just not the way most civil lawyers do things, and -MR. SNEDDON: Thank you. No further questions.
THE WITNESS: (To Mr. Mesereau) Well, there goes that last question, huh? If youd raise
your hand, Id stop.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Mr. Feldman, if youre going in front of a civil jury, and youre trying to prove that the
civil defendant acted with malice -A. Yes.
Q. -- dont you think it might affect that jury if the civil defendant is a convicted felon?
A. I think it helps. Yeah. Sure.
Q. Of course it helps, doesnt it?
A. Of course it helps. But thats -- you know, you got to balance this about a kid whos got
cancer and whos sick and -Q. Thats not what were talking about, Mr. Feldman. I asked you, if you go into civil court
and are trying to prove malice to get punitive damages, and the defendant is a convicted
felon, you have a much easier road, dont you?
A. I -- yes.
MR. MESEREAU: Thank you.
MR. SNEDDON: I keep my word.
THE COURT: All right. Thank you. You may step down.

JESUS SALAS EXAMINATION

DIRECT EXAMINATION BY MR. AUCHINCLOSS:

Q. In the year 2003, Mr. Salas, who were you employed by?
A. I was employed by Neverland Valley Ranch.
Q. And who was your employer?
A. Mr. Jackson.
Q. Michael Jackson?
A. Michael Jackson, yes.
Q. The man seated to my right?
A. That is correct.
Q. Mr. Salas, how long -- well, let me back up. When did you cease to work for Neverland
Valley Ranch? When did you stop working there?
A. It was late June 2003.
Q. And how many years did you work at Neverland Valley Ranch?
A. 20 years.
Q. Did you work there before Mr. Jackson bought that property?
A. Yes, sir.
Q. And what did you do during your years at working at Neverland Ranch? What were you
employed doing?
A. I was outside on-grounds maintenance supervisor.
Q. You were a supervisor of grounds maintenance?

A. Right.
Q. And what did that involve?
A. Keeping up the place, you know, maintaining the place, and anything that -- any
activities that needed to be done on the grounds.
Q. Did you have people working under you?
A. Yes.
Q. And how many?
A. I believe it was about 15 people, something like that.
Q. 15?
A. Uh-huh.
Q. Who did you report to during that period of time?
A. We had a ranch manager.
Q. And at some point, did you change jobs?
A. Yes, I did.
Q. When was that?
A. It was -- I would say it was in the middle of 2002.
Q. And what job did you take up? What was your new job at that time? 4614
A. I was assigned to be the house manager for Mr. Jackson.
Q. Was that a promotion?
A. I would say yes.
Q. Okay. More responsibility?
A. More responsibility.
Q. And what did you do as the house manager?
A. Making sure that the house was -- making sure that everything that the house needed
to be done. I was just to make sure that everything was there for Mr. Jackson and his
guests.
Q. And when you say the house, what structure or structures do you mean with
specificity, specifically?
A. It was the main house and guest units, theater. Anything involved with the facilities of
Mr. Jackson.
Q. How many people did you have working under you as house manager?
A. Eight people.
Q. And what were their various employments? What did they do?
A. House -- house maids and cooks.
Q. So who did you report to when you were house manager?
A. We also have a ranch manager. But I also report to Mr. Jackson.
Q. Did you report directly to Mr. Jackson?
A. Yes, I did.
Q. And whereabouts did you work? What was -- in your day-to-day life as house manager,
your employment as house manager, tell me about -- give me an idea of what you would
do in a given day.
A. Well, we did the various of things, you know. Making sure that the place was clean.
Making sure that we had everything stocked, supplies. And making sure that the
guesthouse was clean. Stuff like that. Just keeping up with the place.
Q. Did you have an office or anything of that nature?
A. Yes. Theres an office in the house.
Q. And where is that located?
A. Its in the back of the house, as you first go into the main, the back door on the left

side.
Q. When Mr. Jackson was on the property, how often would you have contact with him, as
house manager?
A. Daily basis.
Q. More than once a day, or -- give me an idea, if you would.
A. Sometimes it was once. Sometimes it was more than that. It depends.
Q. And if Mr. Jackson wanted something done, lets say he wanted flowers in a certain
place at the house, who would take care of that?
A. It was -- that responsibility, it was some 4616 other people who was in charge of the
flowers.
Q. Okay. Would he -- who would he tell that he wanted the flowers in that particular
place?
A. Mr. Jackson will tell anybody that he wanted to first.
Q. Okay. As far as keeping the kitchen stocked, was that one of your jobs?
A. Yes.
Q. What about alcohol on the ranch, was that your job as well, to keep alcohol stocked?
A. I had to make sure that we had what he needed or anything that needed to be in the
house.
Q. Can you characterize for me what level of service Mr. Jackson expected at Neverland
Ranch?
A. The best.
Q. What were your daily hours like?
A. It was pretty long hours. 7 a.m. to -- to 1:00 or 2:00 in the morning. 3:00 sometimes.
Q. Was that a normal day for you to work such long hours?
A. It was not normal. But it was a requirement that we had it -- to get things done.
Q. And can you characterize for me the expectation that Mr. Jackson had concerning the
level of service?
MR. MESEREAU: Objection. Vague; calls for speculation.
THE WITNESS: When you say expectation, could you specify it a little bit?
MR. AUCHINCLOSS: Just a moment.
THE COURT: Okay, hes asked you to clarify.
Q. BY MR. AUCHINCLOSS: You said that the services for Mr. Jackson was first class?
A. Yes.
Q. Yes?
MR. MESEREAU: Objection; misstates the evidence.
Q. BY MR. AUCHINCLOSS: I cant recall exactly what you said. What did you say about
the level of service?
A. That he expected the best.
Q. He expected the best. Okay. And if he didnt get the best, would he let you know that?
A. Yes.MR. MESEREAU: Objection; calls for speculation.
THE COURT: Overruled.
Q. BY MR. AUCHINCLOSS: Was Mr. Jackson shy about telling somebody, an employee,
that he was displeased about something?
A. Not necessarily. He would tell you the way -- he will make you understand what he
wanted.
Q. Did he ever fire people?
A. Not that Im aware of.
Q. Was he ever responsible for firing someone?

A. No.
Q. You dont know if he ever wanted someone fired?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Was anybody fired during the period of time that you worked
there?
A. Yes.
Q. Tell me, was anybody fired when you worked as a house manager?
A. No, nobody.
Q. While you worked at Neverland, were you ever asked to maintain any level of secrecy
about what happened at Neverland?
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. You may answer.
THE WITNESS: Theres -- theres a procedure that when you are hired at Neverland
Valley Ranch you do sign some confidentiality forms.
Q. BY MR. AUCHINCLOSS: And when you agree to that form, what are you agreeing to?
A. To respect the policy.
Q. What is the policy?
A. Of not talking anything that you shouldnt talk about, Neverland.
Q. Okay. Are you allowed to talk about anything that happens on Neverland off the
Neverland property?
A. No, youre not.
Q. Why did you -- why did you leave your employment at Neverland?
A. The reason I left -- it was many things involving that. And I became to the point that I
say, you know, This -- its time for me to move on. There was some things that I didnt
like about how things were running there. So it was a lot of stress, and I say, Okay, its
time for me to move on.
Q. Whose decision was it to leave Neverland?
A. It was my decision.
Q. When you were working at Neverland as the house manager, did you have occasion to
go into Mr. Jacksons private quarters?
A. Yes, I did.
Q. Were you -- did you have occasions where you went upstairs into the bedroom area?
A. Yes.
Q. Was there any notification system that signaled Mr. Jackson when someone was
coming into his room?
A. Yes.
Q. Can you describe it for me?
A. It was a doorbell as you come through the hallway. You can tell when somebody was
approaching to the door.
Q. And what kind of sound did it make?
A. Its a bell.
Q. Just a bell?
A. Uh-huh.
Q. Now, as you entered Mr. Jacksons room, tell me about the first level.
A. He had a big T.V. upstairs. There was some couches.
Q. Were there windows in that area?
A. Yes.

Q. Did they have any window coverings?

A. Yes, they did.
Q. Generally speaking, would Mr. Jackson keep those -- well, let me, first of all, strike
that. Let me ask you, what type of window coverings are we talking about?
A. Shutters.
Q. Shutters?
A. Uh-huh.
Q. Were there any curtains?
A. No.
Q. Typically would the shutters be open, closed, or something in between? You tell me.
A. They were closed.
Q. They usually were closed?
A. Thats correct.
Q. Could people from outside see inside Mr. Jacksons room?
A. No.
Q. Was it generally dark in there?
A. Pretty much.
MR. MESEREAU: Objection. Foundation; move to strike.
THE COURT: Overruled.
MR. AUCHINCLOSS: If I may approach, Your Honor?
MR. MESEREAU: May I see what counsels -MR. AUCHINCLOSS: Yes, certainly.
Q. BY MR. AUCHINCLOSS: All right. Mr. Salas, I show you Peoples Exhibit No. 338. Can
you identify that photograph for me, please?
A. Yes. Thats Gavin, Star, and the sister.
Q. Okay.
A. Davellin.
Q. Davellin?
A. Davellin.
Q. Are those the Arvizo children?
A. That is correct.
Q. I show you Peoples Exhibit No. 3. Have you ever seen that individual?
A. I probably have. I dont remember.
Q. Okay. If you -- does he look at all like somebody youve ever seen at Neverland Ranch?
A. Yes.
Q. He does?
A. Uh-huh. 4622
Q. But you dont know his name?
A. No. I dont remember his name.
Q. I show you Peoples Exhibit No. 17. Do you recognize that picture?
A. Yes, sir.
Q. And who is that?
A. Dieter.
Q. Dieter?
A. Uh-huh.
Q. Was he a visitor at Neverland Ranch?
A. Yes, he was.
Q. I show you Peoples Exhibit No. 18. Can you identify that photograph?

A. Thats Mr. Ronald.

Q. Ronald?
A. Uh-huh.
Q. This photograph is maybe not so good, but Ill show it to you anyway. Peoples Exhibit
19. Are you able to identify that individual?
A. Yes. Cant remember his name. Sorry.
Q. Okay. Well talk about him. Peoples Exhibit No. 20. Do you recognize him?
A. Thats Frank Tyson.
Q. Frank Tyson. Peoples Exhibit No. 21, I show you that. Can you recognize that?
A. That is Aldo. 4623
Q. Aldo?
A. Uh-huh.
Q. And then I have three exhibits which we havent introduced yet. Exhibit 46, do you
recognize that photograph?
A. I do, but I dont remember his name.
Q. Peoples Exhibit 45?
A. Yes, I do.
Q. Do you recognize that?
A. Yes.
Q. Do you remember his name?
A. No.
Q. And Peoples Exhibit 47, do you recognize that photograph?
A. Yes, I do. Dont remember his name.
Q. All right. Good enough. First of all, going back to 47, how do you recognize this
picture? Where have you seen that face before?
A. At Neverland Valley Ranch.
Q. And have you seen this person at Neverland Valley Ranch on -- give me an idea of how
many times hes visited there.
BAILIFF CORTEZ: They cant hear you, sir, in the back.
Q. BY MR. AUCHINCLOSS: How many times has this individual visited at Neverland
Valley Ranch, if you know?
A. Im not quite sure how many times. But he was there quite a few times.
Q. Quite a few times? Did this individual associate with Mr. Jackson while he was at
Neverland Valley Ranch?
A. Yes, he did.
Q. Showing you Exhibit 45, can you tell me how many times this individual was at
Neverland?
A. About the same amount of times.
Q. A number of times?
A. Yes.
Q. Did he also associate with Mr. Jackson?
A. That is correct.
Q. Peoples Exhibit 46, same question. Was he -- how many times did he come to
Neverland?
A. Same answer.
Q. Many times?
A. Uh-huh.
Q. Did he also associate with Mr. Jackson?

A. Thats correct.
Q. Thank you. Those last three photographs that I showed you, Mr. Salas, is there
anything that these three individuals have in common?
MR. MESEREAU: Objection; vague.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Can you tell me, do those three individuals have anything in
common
concerning the area where they live?
A. They -MR. MESEREAU: Objection; vague.
THE WITNESS: They live in Los Olivos.
THE COURT: Overruled.
Q. BY MR. AUCHINCLOSS: All right. So, lets go back to the Arvizo family. Or -- I think
Ill begin with a different photograph. Could I have the Elmo on, please, Your Honor? All
right. Showing you Peoples Exhibit No. 3, you previously identified that photograph as
someone that youve seen at Neverland Valley Ranch; is that correct?
A. That is correct.
Q. Can you tell me approximately -- if you have seen that individual at Neverland Valley
Ranch on more than one occasion.
A. I believe I have, but Im not quite sure how many times.
Q. Okay. Can you tell me if that individual had any association with Michael Jackson while
he was at Neverland Valley Ranch?
MR. MESEREAU: Objection; foundation.
MR. AUCHINCLOSS: I can -THE COURT: Overruled. You may answer.
THE WITNESS: I believe they did.
MR. AUCHINCLOSS: All right.
Q. Showing you Exhibit No. 20. I believe youve identified this as whom?
A. Frank Tyson.
Q. And how long have you known Frank Tyson?
A. I know Frank Tyson for quite a few year already.
Q. Can you give me an idea how old he was when you first met him?
A. Not quite sure how old he was, but he was pretty young.
Q. Okay. Can you estimate?
A. He was probably about 18 years, or something like that.
Q. 18 years old?
A. Something like that.
Q. When you first met him?
A. Right.
Q. Do you know how old he is now?
A. I dont.
Q. Okay. And where did you meet him?
A. At Neverland Valley Ranch.
Q. And did he associate with Mr. Jackson while he was at Neverland Valley Ranch?
A. Yes, he did.
Q. How often?
A. I would say pretty often.
Q. Do you know what his relationship was with Mr. Jackson?

A. Just a friend, I believe.

Q. Okay. Have you ever described him as Mr. Jacksons right-hand man?
MR. MESEREAU: Objection. Leading; move to strike.
THE COURT: Overruled.You may answer.
THE WITNESS: At one point, yes, sir, he was.
Q. BY MR. AUCHINCLOSS: When was he Mr. Jacksons right-hand man?
A. Dont remember exactly the year that he was, but I believe it was probably around 90.
I want to say that. Not quite sure of the year, you know.
Q. 1990?
A. Somewhere around there.
Q. So that would have been 15 years ago?
A. Something like that, I would say. Maybe less than that.
Q. How old do you think he is now?
A. Im not sure. I dont know. I honestly dont know.
Q. How many years have you known him?
A. Well, I want to say it was about 15 years since the first time I met him.
Q. All right. Now, why did you characterize him as Mr. Jacksons right-hand man?
A. Because at one point he came to the ranch and he is the one that was giving orders as
to what to do around the property.
Q. When he was there in 2003 -- well, let me back up. Was Frank Tyson on the ranch in
2003?
A. Yes, he was.
Q. And when he was there in 2003, did he also give orders as to what should go on at the
ranch?
A. No.
Q. Didnt he also give you some orders, Mr Salas?
MR. MESEREAU: Objection; leading.
MR. AUCHINCLOSS: Thats impeachment.
MR. MESEREAU: Misstates the evidence. Its asked and answered.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes, he did. I mean, he did, but not the same orders as when he was the
first time. This was more like for Mr. Jackson.
Q. BY MR. AUCHINCLOSS: More like he was giving you orders for Mr. Jackson; is that
what youre saying?
A. Yes.
MR. MESEREAU: Move to strike. The prosecutor didnt let him finish his answer. And
thats leading.
THE COURT: Actually, hes just repeating what the witness said. Would you phrase a new
question, please?
MR. AUCHINCLOSS: Yes. Thank you.
Q. Why do you say that he was giving you orders for Mr. Jackson?
A. Because many times, if things that needed to be done, or anything that need -- to Mr.
Jackson to be notified, he would said, I will take care of that. So thats how I realized
that he was also giving orders.
Q. Did you ever see Mr. Jackson give Frank Tyson orders or -A. No, no, I didnt.
Q. And did Mr. Jackson spend time with Frank Tyson in 2003?
A. Yes.

Q. Can you characterize how often they would spend time together when they were at the
ranch?
A. I would say, I dont know, about once a day or something like that. All depends.
Q. Once a day they would get together?
A. On occasions. Not always, okay?
Q. Im just asking you for what you saw.
A. Right.
Q. Okay. So when youd see them get together during the day, can you tell me,
whereabouts would they meet on the ranch? Where would you see them?
A. Many times it was in his office. Many times it was in the video library. Not in the video
4630 library. The library at the house.
Q. Uh-huh.
A. Sometimes in Mr. Jacksons room.
Q. When you say his office, do you mean Mr. Jacksons office?
A. Mr. Jacksons office, yes.
Q. Can you tell me, how would you characterize their relationship, based upon what you
saw, the years of seeing them together?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Overruled. You may answer. Do you want the question read back?
THE WITNESS: Yes. Go ahead and ask the question again, please.
Q. BY MR. AUCHINCLOSS: My question is, how would you character -- how would you
describe their relationship, based on all the years that you saw Mr. Tyson and Mr. Jackson
associating with one another?
A. I would say that it was some friend relationship, bonded together.
Q. How would you characterize it in terms of closeness?
A. What do you mean by that?
Q. Well, were they close friends or distant friends? You know what I mean, I think. 4631
A. No, I think at one point they were pretty close friends.
Q. Did they still appear to be friends in 2003?
A. Not really.
Q. Not really?
A. No.
Q. Well, Mr. Tyson was a guest in 2003, wasnt he?
A. Yes, he was.
Q. And he was -- did Mr. Jackson allow guests on the ranch when he didnt want them
there?
MR. MESEREAU: Objection; leading question.
THE COURT: Its argumentative.
MR. AUCHINCLOSS: Okay.
Q. Do you know if Mr. Jackson allowed anybody on the ranch who he was not friends with?
MR. MESEREAU: Objection; calls for speculation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: If Mr. Jackson did not want somebody on the ranch, would
he keep them out?
MR. MESEREAU: Objection; calls for speculation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Is there a security gate at Neverland Ranch?
A. Yes, there is.

Q. And does someone have to get permission to get into Neverland Ranch?
A. Absolutely.
Q. And if Mr. Jackson says, Dont let this person in, will that person get into Neverland
Ranch?
A. No.
MR. MESEREAU: Objection; calls for speculation.
THE COURT: Overruled. The answer is, No.
Q. BY MR. AUCHINCLOSS: Now, during this time in 2003, was Mr. Jackson still meeting
with Frank on about a daily basis?
MR. MESEREAU: Objection. Misstates the evidence; move to strike; its leading.
THE COURT: Assumes facts. Ill sustain the objection.
MR. AUCHINCLOSS: Okay.
Q. When Mr. Jackson and Mr. Tyson -- well, let me back up. In early 2003, January,
February, March 2003, where was Mr. Tyson living?
A. He was living -- he was at the video library.
Q. At Neverland Ranch?
A. Yes, sir.
Q. He had his own bedroom there?
A. They had a bed upstairs, yes.
Q. And during that period of time in 2003, would you see Mr. Jackson and Mr. Tyson
together?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Sustained.
THE WITNESS: Occasionally, yes.
Q. BY MR. AUCHINCLOSS: You would see them together?
A. Yes.
Q. Did Mr. Tyson have an office set up at Neverland Valley Ranch during that period of
time?
A. Yes, he did.
Q. Where was his office?
A. It was in the video library.
Q. Was there anybody else who had an office in the same area?
A. Yes. That was Vinnie.
Q. Who?
A. Vinnie.
Q. Vinnie?
A. Uh-huh.
Q. Who is Vinnie?
A. Vinnie was a friend of Frank Tyson. Or I guess, I should say.
Q. Where was Vinnie living during that time?
A. He was living in the same area, same place.
Q. I show you grand jury exhibit -- or, sorry, Peoples Exhibit No. 19. Can you identify that
photo?
A. Yes, thats Vinnie.
Q. All right. Do you know what the office that Vinnie and Frank had in the video library
was being used for? Do you know what they were using that office for during that period
of time?
A. No, I dont.

Q. That was in the house; is that true?

A. That was at the video library.
Q. Is that in the house?
A. That is outside the main house.
Q. Okay. And where is it?
A. That is above Mr. Jacksons office, upstairs.
Q. Okay. So is that connected in some way by any building to the main house?
A. Yes, theyre all bonded together.
Q. Theyre all part of the same structure?
A. Right.
Q. And would Mr. Jackson go up into the video library during that period of time, in early
2003?
A. I would say occasional.
Q. And why didnt you know what was going on up there? Why didnt you know what
Frank and Vinnie were doing up there if you were the house manager?
MR. MESEREAU: Objection. Calls for speculation; no foundation; leading.
THE COURT: Overruled. You may answer.
THE WITNESS: It wasnt my business to find out what they were doing up there.
Q. BY MR. AUCHINCLOSS: Were you ever discouraged from asking those kinds of
questions?
MR. MESEREAU: Objection; leading.
THE COURT: Sustained.
THE WITNESS: Not really.
MR. MESEREAU: Withdraw the objection.(Laughter.)
THE COURT: (To the jury) You know, we are -- I think were at a point where well stop,
because we have to take up a motion with the attorneys before the end of the day. So Ill
let you go early. Well see you on Monday morning at 8:30. If you havent seen the
wildflower displays -- I went out yesterday. Its really worth seeing. Highway 58 out of -up by Lake Santa Margarita. If you go out on that, its just carpets and carpets of yellow
and spotted with blue, and its just a nice way to relax. I recommend it. Thanks. Ill see
you -- remember next Wednesday were dark.
MR. AUCHINCLOSS: Mr. Salas? You come this way.
THE WITNESS: Oh. Somebody needs to guide me. (The following proceedings were held
in open court outside the presence and hearing of the jury
THE COURT: All right. Mr. Sanger, you had a motion you wanted to make?
MR. SANGER: Yes, Your Honor. Theres actually two things. But the first is a motion
regarding prosecutorial misconduct, and the issue is the admonishment by the prosecutors
to their witnesses to conform to the courts orders. In particular, in this case, we have
several witnesses, Louise Palanker, who discussed her testimony with Jamie Masada, and
perhaps vice versa, but at least theres clear evidence of that. We have Bill Dickerman,
who talked with Dr. Katz. We had Larry Feldman, who talked with Mr. Dickerman and Dr.
Katz. And it is up to the parties who call the witnesses to admonish them to conform to
the courts orders. The courts already admonished the prosecution that they need to do
that with regard to the gag order and going outside and talking to the press. That may
have occurred, actually, since the Court made that admonishment. But in particular, at
this point, Im addressing the discussion of testimony between witnesses who are
witnesses called by the prosecution. The prosecutor has sufficient staff, 4637 including a
witness coordinator, to take care of this, sheriffs personnel and the D.A.s themselves. It

seems to be a consistent problem, and as a result of that, I believe it rises to the level of
prosecutorial misconduct. It could be conveniently forgotten, but it just couldnt be
innocently forgotten after all this time, and the repetition of the -- of the misconduct on
the part of the witnesses that weve heard. So Id ask the Court to fashion an appropriate
remedy. Remedy number one, of course, in any misconduct situation, prosecutorial
misconduct situation, is a mistrial. And depending on how the Court rules on that, I have a
proposed curative instruction. But the Court would have to rule on the first remedy before
we get to that, I believe. I can go ahead and give the Court a quick idea, because I dont
want to spend unnecessary time. If the Court denied the motion for mistrial, I think a
proper curative instruction is along the lines of other instructions, that the Court can
advise the jury that witnesses called by a particular party, in this case the prosecution, are
supposed to be admonished by the -- by the lawyers calling them to conform to the courts
order. And if the jury finds that they have not conformed to the courts orders particularly
in this 4638 case, not to discuss their testimony with other witnesses, that the jury can
draw an adverse inference from that as to the credibility of the witnesses, and as to the
strength of their testimony. And that the jury, if they find that to be true, can disregard
the entire testimony of the witness, unless the review of all the facts in the case supports
the testimony of that witness. And that would be the alternative, but I propose that only
in the event that the Court denied the motion for mistrial.
THE COURT: Counsel?
MR. SNEDDON: Well, first of all, Your Honor, I dont think theres any evidence that they
were discussing their trial testimony. The discussion was they had conversations. Theres
no evidence at all that I can hear of that they talked about -- about their trial testimony.
And even in the case of Palanker, she didnt discuss her trial testimony. She discussed
some observations about the behavior of one of the lawyers in the courtroom. And -THE COURT: When did she do that?
MR. SNEDDON: Im sorry?
THE COURT: When did she do that?
MR. SNEDDON: When Mr. Masada testified -- when counsel asked Mr. Masada, he was
trying to get him to say that she said something about the 4639 pathological liar thing,
but she really didnt. She really said something else. She said -- I dont want to describe it
again, but I can if you want me to, about counsels behavior, that he was -THE COURT: Did she say that outside the courtroom?
MR. SNEDDON: Yes, sir. It wasnt -THE COURT: I dont -- I havent watched this -MR. SNEDDON: No, no. Let me go back. I -- THE COURT: Im missing something.
MR. SNEDDON: The whole thing -- these ought to be put in writing, if theres a motion,
and we ought to be able to respond in writing. It would be more efficient.
THE COURT: Lets do this. I think thats a good way to do it. Why dont you put
something in writing for Monday morning, and -MR. SANGER: My free time on the weekend while Im looking at the flowers?
THE COURT: Yes. If you want -- if you look at the flowers, Ill give you till Tuesday.
(Laughter.)
MR. SANGER: Theres an incentive. Ill do both and try to get it for you on Monday, Your
Honor.
THE COURT: And then youll have to respond by Tuesday. 4640
MR. SANGER: Okay. The other matter -THE COURT: Okay.

MR. SANGER: -- it was simply that we had submitted, I believe, by remote control
proposed
instructions on the 1108 and 1101, and I believe the Court got it, although I was sitting
here -THE COURT: Yes, I did. I received it.
MR. SANGER: And I believe the prosecution indicated they were relying on the straight
CALJICs.
THE COURT: They showed me theirs. They pulled -- did you show each other what you
had given me?
MR. SANGER: They served it.
MR. SNEDDON: I gave the clerk the copies of the ones that we had given you, but they
already had a copy of those previous. Theyre the standard 1108, 1101 instructions.
THE COURT: The only reason I asked that is theres a little more. You gave a couple of -theres more than just the key instruction. Theres some others that may or may not be
given. It gave a package. And Im not saying its outside of the framework, its just -theres a couple more -- I just want to be sure everyones looking at the same
instructions.
MR. SANGER: I do not know which instructions they selected out. And we did serve ours,
I believe, on the prosecution. Im sure we 4641 did.
THE COURT: Okay. Well, they can tell you the numbers. They are CALJIC instructions.
Standard 1101, 1108. And that there were a couple of additional ones that are connected
to it. Im not saying theyre not connected.
MR. SNEDDON: The burden of proof, yes, sir.
THE COURT: The burden of proof.
MR. SNEDDON: CALJIC says you have to give that when you give that instruction, yes,
sir.
THE COURT: And I think there was one other, too.
MR. SNEDDON: Well, the standard of proof upon -- Ill take care of it, Your Honor.
Theres no use wasting the courts time with that.
THE COURT: What I thought we would do -- I wont give any instructions until weve all
had a chance to discuss which ones should be given.
MR. SANGER: My understanding is the prosecution is going to call their first 1108 witness
on Monday. Obviously this witness will still be going. So hopefully well have a chance to
take that up at the 9:45 break, or something.
THE COURT: Well take it up before we call 1108 witnesses, so that -MR. SANGER: Very well.
THE COURT: Because I want to do that.
MR. SANGER: Thank you, Your Honor.

2005 April 4 (day 25) J. Salas & J. Francia

JESUS SALAS EXAMINATION (Continued)

DIRECT EXAMINATION (Continued) BY MR. AUCHINCLOSS:

Q. Im not sure exactly where I left off, but Id like to begin by going back to generalit ies
about Neverland. As far as your relationship with Mr. Jackson concerning your
employment as house manager, can you characterize the level of control that Mr. Jackson
maintained over Neverland and over the main house?
A. I would say pretty high.
Q. And as far as in terms of how demanding he could be, could you characterize that as
well?
MR. MESEREAU: Objection. Vague; foundation.
THE COURT: Sustained.
MR. AUCHINCLOSS: I can be more specific.
Q. How demanding he was about the level of his service that was provided to him by his
employers.
MR. MESEREAU: Objection. Vague; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Who was it that determined what -- which guests -- well, let
me back up. How was it determined, if you know, whether a guest would be coming to
Neverland or not?
A. I did not know that.
Q. Okay. And would guests of Neverland be allowed to bring their own guests to
Neverland; do you know?
MR. MESEREAU: Objection. Calls for speculation; foundation.
MR. AUCHINCLOSS: If you know.
THE COURT: The objection is overruled. You may answer.
THE WITNESS: I do not know that either.
Q. BY MR. AUCHINCLOSS: Okay. The guests of Neverland wou ld be whose guests?
MR. MESEREAU: Objection. Foundation; calls for speculation.
THE COURT: Foundation is sustained.
Q. BY MR. AUCHINCLOSS: Do you know if people were allowed on Neverland without
Mr. Jacksons permission?
A. I believe that if they werent allowed by Mr. Jackson, I dont think they would come in.
Q. Okay. And do you know who would determine how long a guest was allowed to stay at
Neverland?
MR. MESEREAU: Objection. Foundation; calls for speculation.
MR. AUCHINCLOSS: Its a foundational question.
THE COURT: You may answer that yes or no.
THE WITNESS: I believe they didnt have no time -THE COURT: Just a moment. Hes just asking if you have the knowledge. Hes not asking
you what the knowledge is. Do you know who determined how long a guest could stay?
Yes or no.
THE WITNESS: No, I didnt.

Q. BY MR. AUCHINCLOSS: How were children treated at Neverland?

MR. MESEREAU: Objection. Vague; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Can you -- when you were at Neverland, Mr. Salas, when you
were house manager, did you observe at any time Mr. Jackson with child guests?
A. Yes, I did.
Q. And did Mr. Jackson ever inform you of the level of the service he expected of his child
guests?
MR. MESEREAU: Objection. Leading; foundation.
THE COURT: Overruled.You may answer.
THE WITNESS: He was -- he always expected the best, to be treated the best.
Q. BY MR AUCHINCLOSS: If a child wanted something at Neverland, had a request, or
lets say food, a movie, any special request of that nature, would that request be fulfilled
by the employees?
MR. MESEREAU: Objection. Vague; foundation; calls for speculation. 4652
THE COURT: Overruled.
THE WITNESS: Yes.
Q. BY MR. AUCHINCLOSS: Do you know if thats the way Mr. Jackson wanted it?
A. That is correct.
Q. How do you know that?
A. Because of what he told me, that -- whatever the guests needed, we needed to provide
that for them.
Q. And did you notice whether or not this level of service or treatment as far as the
children went, did you notice if it affected those kids behavior in any way?
MR. MESEREAU: Objection. Vague; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did you ever have a chance to observe the children -- well,
let me ask you this: Were the children basically given whatever they wanted?
MR. MESEREAU: Objection; leading.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Mr. Salas, please characterize for me, if you would, in
general, the level of service and -- well, I think youve said before that the children were
allowed the best treatment, the best service, true?
A. That is correct.
Q. Give me an example. What are you talking about when you say that?
A. Well, the best service Im talking about, if they wanted to see a movie and have their
meal at the theater or any of that kind of stuff, I mean, they -- I would make sure that
they would get it that way. Or if they wanted to eat like anywhere else, if they w anted to
eat. If guests called me, or the kids called me, they wanted to eat in the train depot, I
would make sure that thats where they get their meal, or whatever they asked for.
Q. If they wanted candy, were they given candy?
A. Absolutely.
Q. If they wanted to play at the amusement park, could they do it?
A. Absolutely.
Q. Were there any rules about that?
A. No.
Q. As far as when and how they would play?
A. Well, there was some rules, you know, for their safety, you know.

Q. Yes.
A. Yes. But other than that, there wasnt any other rules.
Q. Did you have golf carts at Neverland?
A. Yes.
Q. Were the children allowed to use them?
A. There was some kids that they were allowed 4654 to use them.
Q. Who decided who got to use the golf carts?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Are you aware who allowed the children these privileges of
using the golf carts?
A. I had some control on that. We had security or wed have security there. Many times
kids, they were told they werent allowed to drive certain cars, but they were some kids
that they were allowed to drive them.
Q. If Mr. Jackson said, Let this kid drive golf cart, would that kid be allowed to drive the
golf cart?
A. I would say yes.
Q. Tell me about the theater at Neverland. Could you describe it for me?
A. Well, its a full-sized theater with a candy bar, ice cream. Its got pretty much anything
that a kid can enjoy.
Q. Are there any unusual features as far as where you can watch the movie?
MR. MESEREAU: Objection.
THE WITNESS: Yes, theres an upstairs -THE COURT: Just a moment.
MR. MESEREAU: Vague and foundation.
THE COURT: Overruled. You may answer.
Q. BY MR. AUCHINCLOSS: Go ahead.
A. Theres an upstairs room where people can sit up there and watch the movie if they
want to.
Q. Are there any beds in the theater?
A. Yes, theres two rooms downstairs with two facilit ies for kids that they can sit in there
or lay in bed and watch a movie, if thats what they want.
Q. Is the theater ever closed? I mean, does it have hours, I guess is my question? Is it -A. Pretty much when Mr. Jackson is on the property, we always kept the place open.
Q. When he had some what?
A. When Mr. Jackson is on property.
Q. I see.
A. We pretty much keep the place open for -- you know, for guests or himself.
Q. All night long?
A. All night long.
Q. Was there one person who made all the main decisions about what happened at
Neverland?
A. Well, there is the ranch manager there.
Q. Yes. And was there one person in charge of the ranch manager?
A. Yes.
Q. And did that person make all the main decis ions at Neverland?
A. Yes, I believe so.
Q. And who was that?

A. That would be Mr. Jackson.

Q. Now, you spoke a little b it last week about Mr. Jacksons room. Was there -- I believe
you testified there was a combination to get in that room?
A. Yes, I did.
Q. Was that combination ever changed?
A. Not too often, but yes, it did.
Q. How often would that combination change?
A. I believe the time that I was there, I think it was about two times that we changed it.
Q. Okay. Now, when you say you were there, are you referring to the time -- the full 20
years you were there, or just the year or so that you were house manager?
A. Just when I was the house manager.
Q. And was there a combination to get into the main house?
A. Yes, there was.
Q. And would that ever change?
A. That one got changed more often.
Q. How often, if you could tell us?
A. I would say that we changed that about every two months, somewhere -- somewhere
along that.
Q. Were -- do you know if certain people were
given the comb inations -- the combination to Mr. Jacksons bedroom?
A. Not to my knowledge.
Q. Do you know if certain people were given the comb ination to the Jackson house, the
main entry into the home?
A. Yes. Pretty much all his guests have access to the house so they had to have the
combination.
Q. And who would give them that combination?
A. Myself personal.
MR. AUCHINCLOSS: Okay. All right. Could we have the Input 4, Your Honor?
Q. All right. Mr. Salas, I show you Peoples Exhibit No. 20. Weve shown this to you
before. Youve identified it as Frank Tyson. You mentioned that at some point during your
employment, Mr. Tyson -- you mentioned something about a problem with Mr. Jackson
that Mr. Tyson had. Do you recall that testimony?
A. Yes, I did.
Q. How do you know about that problem?
A. I believe about Mr. Jacksons frustrations.
Q. Okay. You were present when Mr. Jackson expressed some from frustrations?
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes, I did.
Q. BY MR. AUCHINCLOSS: And what was -- can you tell us what he was frustrated
about?
MR. MESEREAU: Objection; foundation.
MR. AUCHINCLOSS: Ill withdraw and reask.
THE COURT: Okay.
Q. BY MR. AUCHINCLOSS: Did Mr. Jackson tell you what he was frustrated about? Thats
yes or no.
A. Yes.
Q. What -- did Mr. Jackson tell you what was frustrating him?

A. He did not know about Frank bringing people at Neverland Valley without his
permission.
Q. Okay. Bringing guests without Mr. Jacksons permission?
A. Yes.
Q. Who was it that informed Mr. Jackson of this issue?
A. I dont know.
Q. Okay. And you have previously ident ified Peoples Exhibit 35 as the Arvizo family; is
that right?
A. That is correct.
Q. You recall the time when the Arvizo family visited Mr. Jackson in the year 2003?
A. Yes.
Q. Was this frustration that Mr. Jackson expressed with Mr. Tyson before, or after, or
during the time that the Arvizo family was present at Neverland in 2003?
A. That was after the family was there.
Q. After the family left?
A. Yes.
Q. All right. I show you Peoples Exhibit No. 17. Youve previously identified this individual
as Dieter. Tell me, when was the first time you met Mr. -- Dieter, do you know his last
name? Maybe Ill ask you that question first.
A. No, I dont remember his last name.
Q. Well just refer to him as Dieter. When was the first time you met Dieter?
A. I believe it was early or mid 2002.
Q. Okay. And where did you meet him?
A. I met him at Neverland Valley.
Q. Can you tell me about the circumstances? How is it that you met him, under what
circumstances?
A. Well, he came to the ranch as a guest, and stayed there for a while. Thats how I met
him.
Q. Okay. So, were in mid 2002. Dieter co mes and visits. Do you know how long he visited
for?
A. Not exactly sure, but I believe he stayed there for a couple of weeks the first time he
came.
Q. Was Mr. Jackson there at the time?
A. Yes, he was.
Q. Was Mr. Jackson there before Dieter came on the property, if you recall?
A. I dont remember.
Q. When Dieter left the property, do you know if Mr. Jackson left with him?
A. Im not exactly sure if they did. But there was a few times that they left together.
Q. Okay. So Dieter visited the property again after that first time?
A. Yes.
Q. How many times, if you can estimate?
A. Not exactly sure, but he came, I dont know, maybe about three or four times after
that. Something like that.Q. All right. And you said that -- some of those times. Do you
know how many times Mr. Jackson left with him, when D ieter left?
A. I dont.
Q. Do you know how many times Dieter arrived on the property with Mr. Jackson, if at all?
A. I would say about a couple times.
Q. Show you Peoples Exhibit 18, which youve identified as Ronald. Do you know Ronalds

last name?
A. I believe h is last name is Konister.
Q. Konister?
A. Something like that.
Q. Okay. Well refer to him as Ronald. How -- when was the first time you met Ronald?
A. It was at the same time I met Dieter. 4661
Q. Did Dieter come on the property with Ronald in that period, the first visit he came?
A. They both came together.
Q. Did they leave together?
A. Yes.
Q. And when -- did Ronald ever come back to the property after that?
A. Yes, he did.
Q. How many times?
A. He came back about -- I believe about another couple times.
Q. And during the times that he visited the ranch, did Ronald ever come to the ranch with
Mr. Jackson?
A. I believe he came once, if I can recall.
Q. Did he ever leave the ranch with Mr. Jackson?
A. I -- Im going to say no on that one.
Q. Okay. And while Mr. -- while Ronald was on the property, was -- I think you said the
first time Ronald came with Dieter, and they were there the entire t ime together; is that
right?
A. That is correct.
Q. During those subsequent visits of Ronald, was Dieter on the property?
A. Yes, he was.
Q. Did you ever see these two men together?
A. Yes. 4662
Q. How often?
A. Daily basis.
Q. Daily basis?
A. Uh-huh.
Q. Did you ever see these two men with Mr. Jackson?
A. Yes, I did.
Q. How often?
A. Oh, Im going to say at least they try to have a meet ing once a day.
Q. Do you know what Ronalds -- well, let me back up. Do you know what Dieters
relationship was to Mr. Jackson?
A. No, I dont.
Q. Do you know if it was -- dealt with friendship, business, or a combination?
A. I would say it was more business.
Q. Why do you say that?
A. Because of what they were discussing about business in Europe.
Q. You heard them talking about business?
A. Yes.
Q. What about Ronald, how would you characterize Ronalds relationship on the same
continuum?
A. Same category.
Q. Mostly business?

A. Mostly business.
Q. During the time that the Arvizo family was on the property, was at Neverland in 2003,
did you ever observe Ronald on the property at the same time?
A. Yes.
Q. How about Dieter?
A. The same.
Q. And how long were they on the property when the Arvizos were there, if you know, or
can estimate?
A. Id say about two weeks.
Q. Is that two weeks total, one continuous time, or two weeks total different times?
A. It was one continuous time.
Q. What about Frank, was he on the property during the period of time in 2003 when the
Arvizo family was on the property?
A. Yes, he was.
Q. And about how much -- same question, about how much time was he on the property
when the Arvizos were there?
A. Well, he was living there. He was all the time there.
Q. Okay. So whenever the Arvizos were on the ranch, Frank was there?
A. Yes.
Q. Have you ever heard of an individual by the name of Malnik? Malnik?
A. Yes, I did.
Q. Was he a visitor? W as that a man?
A. Yes, its a man.
Q. Did you meet him?
A. Yes.
Q. Was he ever a visitor at the ranch?
A. At the time that I was there he only came once, I believe.
Q. For how long?
A. I dont know. A couple weeks.
Q. Was that time that Mr. Malnik visited the ranch, did that coincide with any time that the
Arvizos were there?
A. Yes.
Q. Im showing you Peoples Exhibit 3. You didnt know this individuals name last week.
But you did recognize him. Was this individual on the ranch at any time during the period
that the Arvizos were at Neverland?
A. I dont believe he was there around that time.
Q. Okay. Do you remember if he was there -- you did testify that he had been at
Neverland before?
A. Right.
Q. Was he there before or after the Arvizos were there, if you recall?
A. I dont recall. He was there before.
Q. All right. Do you know an individual by the name of Zia?
A. Yes.
Q. Who is Zia?
A. My understanding, he is a lawyer.
Q. Have you met him?
A. Yes, I did.
Q. Where did you meet him?

A. At the ranch.
Q. Do you know who he works for?
A. Not exactly. My understanding, he was working for Mr. Jackson.
Q. Was Zia -- well, let me back up. How many times did Zia vis it Neverland where you
saw him there?
A. I saw him there a couple of times.
Q. Did -- any of the time that Zia was on Neverland, did that coincide with any of the time
that the Arvizos were there in 2003?
A. Yes.
Q. Did you ever see Zia during that period of time when he was visit ing the ranch in 2003
talking with Mr. Jackson?
A. I believe, yes, they did have a meeting one time.
Q. Okay. Lets talk a little bit about the Arvizos, okay? In 2003, what members of the
Arvizo family were visiting Neverland?
A. It was just the kids and the mother.
Q. Okay. So the three children, Davellin, Star, Gavin, and the mother?
A. And the mother.
Q. Do you know her name?
A. Janet.
Q. Okay. Did you participate in bringing them to Neverland in any fashion on that visit,
first visit, in 2003 Im talking about?
A. Yes, I picked them up at Santa Barbara Airport.
Q. Okay. And was Mr. Jackson with them at that time?
A. Yes.
Q. And you drove to Neverland Ranch?
A. That is correct.
Q. Now, you testified that you would stay very late pursuant to your employment at
Neverland.
A. Yes.
Q. And youd arrive pretty early, around 7:00, I think you said?
A. That is correct.
Q. Were you in a position to see who spent the night in Mr. Jacksons room?
A. Yes, I was aware of who was sleep ing there.
Q. Okay. And during the time that the Arvizo boys, or lets say the Arvizo children, were at
Neverland Ranch, can you tell me where the two boys would sleep?
MR. MESEREAU: Objection; vague as to time.
MR. AUCHINCLOSS: Im talking about the period in 2003. The visit in 2003.
MR. MESEREAU: I repeat the objection. Its vague.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: In 2003, you said that you brought the Arvizo family to
Neverland. How long did they stay on that -- on that particular visit?
A. Not exactly sure how long they stayed. But I would say they stayed a week or two,
something like that.
Q. And did they -- they then left the ranch for a period of time?
A. Yes.
Q. How long did they leave the ranch for, about, before they came b ack?
A. I would say about another two weeks.
Q. Okay.

A. Something like that.

Q. And then when they came back to the ranch, how long did they stay?
A. That time, I believe they stayed about another, I would say, two weeks, three weeks.
Somewhere around there.
Q. All right. When they left that time, did they return to the ranch?
A. Yes, they came once again.
Q. Okay. And how long did they stay the third time?
A. About another week.
Q. Okay. When they left the third time, how long -- did they ever return to the ranch?
A. That was the last time I saw them.
Q. Okay. Now, this period of these visits that youve just described, of visiting the ranch,
leaving, vis iting, leaving, visit ing, and visit ing one third time, over what period of time did
all of these visits take, if you can estimate in terms of weeks, months? How many weeks
or months did it take for all of these visits to take place?
A. I would say about five weeks, something like that.
Q. All right. Now, tell me how detailed your recollect ions are about exact dates and exact
periods of time concerning this, the visits by the Arvizos.
A. I -- I dont remember the dates, okay.
Q. Okay.
A. Its just -Q. Are you giving us your best estimates?
A. That is the best.
Q. Are you -- but are you exactly sure about the time periods and the amount of time?
A. Im pretty sure about the time of them being there. But not exact -Q. When you say the time, do you mean the dates, or the amount of time?
A. The amount of time.
Q. Okay. So during this period of time that -- these three visits that you talked about that
the Arvizos visited Neverland, was Mr. Jackson there during that period of time?
A. Yes, he was.
Q. Do you know if he was there the entire time or if he had periods where he was gone?
A. I would say that he was there most of the time. Pretty much all the time.
Q. Okay. Are you sure whether or not he -- do you have a specific reco llection of whether
he left or not and came back; do you know?
A. I dont.
Q. During the time -- these three visits -- during that period of time in which Mr. Jackson
was on the property, on Neverland - okay? - can you tell me where the Arvizo boys slept?
MR. MESEREAU: Again, vague as to time. Vague as to what visit. Vague as to what
portion of the visit.
THE COURT: Sustained.
MR. AUCHINCLOSS: I can tighten that up. 4670
Q. Lets do them one at a time, okay? Well do the first one. During the first visit in 2003
of the Arvizo family, during the period of time that Mr. Jackson was on the property, can
you tell me where the Arvizo boys slept?
A. There was times that they slept in the guesthouse. Okay. There were t imes that they
sleep with -- with Mr. Jackson.
Q. Okay. And during the time that -- during this second visit when they left and came
back, can you tell me, during that second visit, where d id the Arvizo boys sleep?
A. That would be about the same. They sleep with Mr. Jackson. Most of the time I believe

that they were trying to sleep with Mr. Jackson.

Q. And same question for the third visit.
A. And thats going to be the same answer.
Q. Okay. Now, you said that they had a guest room.
A. That is correct.
Q. Did -- let me ask you, first of all, while you were manager, house manager, did you
notice if any other children slept in Mr. Jacksons room, other than the Arvizos?
A. There was some other kids.
Q. Was it unusual for a kid who was sleeping in Mr. Jacksons room to also have a guest
room?
A. No, not really.
Q. Did you see Mr. Jackson interact with these children who spent the night in his room?
MR. MESEREAU: Objection; vague.
MR. AUCHINCLOSS: Foundational question.
THE COURT: Overruled.You may answer.
THE WITNESS: He would spend time, because he would play with them.
Q. BY MR. AUCHINCLOSS: And while -- and Im just talking about the year that you
were house manager. While you were house manager, how often would he play with these
children?
A. I would say anyt ime that he had some spare time he would play with the kids.
Q. Okay. Would it be -- you tell me. Would it be daily?
A. He would try to be with them daily.
Q. As far as the children visit ing the ranch, did you notice whether or not Mr. Jackson
formed -- appeared to form any special bonds with certain children?
MR. MESEREAU: Objection. Vague; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Over the period of time, and Im talking just about the time
that you were manager of the ranch, you mentioned that you would see the children p lay
with Mr. Jackson, true?
A. That is correct.
Q. Where would you see them play?
A. Well, they would go to the park. They would go for a walk. They would go bike riding.
Or they have quads, and they would ride the quads everywhere.
Q. Quads, what -- what are quads?
A. The four-wheelers.
Q. Those are motorized vehicles?
A. Right.
Q. Did you see them in the house?
A. Yes.
Q. Did you see them having meals together?
A. Yes, I did.
Q. Would you see this on a daily bas is?
A. Pretty much.
Q. So over that period of time, did you notice whether or not he formed any special bonds
with certain children?
MR. MESEREAU: Objection. Vague and foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: These children who spent the night in Mr. Jacksons room,

did they share any common characteristics?

MR. MESEREAU: Objection. Vague; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: Go ahead and ask me the question again.
Q. BY MR. AUCHINCLOSS: Okay. The question is, the children that spent the night in
Mr. Jacksons room that youve talked about, did they share anything in common, any
common characteristics?
MR. MESEREAU: Vague; foundation. Objection.
Q. BY MR. AUCHINCLOSS: Did they have anyth ing in common? Sorry.
THE COURT: All right. Objection sustained.
Q. BY MR. AUCHINCLOSS: Do you know if these children, whether or not -- did you
notice the age of these children?
A. They were around 10, 11. Around that age.
Q. Did you notice what gender they were?
A. No, I dont.
Q. Did you notice whether they were boys or girls?
A. Well, yes, they were mostly boys.
Q. Did you ever see anyone else sleep in Mr. Jacksons room other than these children?
A. Pretty much it was just the boys. Thats about it.
Q. You previously testified that there was alcohol on Neverland, true?
A. That is correct.
Q. And I think you said you were somewhat responsible for stocking the alcohol at
Neverland as house manager?
A. That is correct.
Q. Did Mr. Jackson drink?
A. Yes, he did.
Q. Are you aware of what his drinks of choice were, what he liked to drink, in terms of
alcohol?
A. Well, he drink wine and vodka also.
Q. Okay. Where was the wine stored on the property?
A. Most of the wine, it was in the wine cellar. We also have wine in the house.
Q. Where in the house?
A. In the refrigerators.
Q. In the kitchen area?
A. Right.
Q. And the vodka, where was that kept?
A. In the kitchen.
Q. Okay. Was there any -- was it any secret at Neverland that Mr. Jackson drank alcoholic
beverages?
MR. MESEREAU: Objection. Vague; calls for speculation; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Mr. Salas, were you ever told by anybody that Mr. Jacksons
drinking was to be concealed from anybody?
MR. MESEREAU: Objection. Hearsay; foundation.
THE COURT: Sustained.
MR. AUCHINCLOSS: On which basis, Your Honor?
THE COURT: Hearsay.
Q. BY MR. AUCHINCLOSS: Did you see Mr. Jackson drinking at Neverland?

A. I never saw him drinking.

Q. Have you ever seen him exhibiting the effects of drinking?
A. Yes.
Q. On how many occasions?
A. Well, lately it was on a pretty much regular basis.
Q. A regular basis?
A. Right.
Q. Did you ever see Mr. Jackson where he appeared to have been drinking a great deal,
that he appeared to be drunk?
A. Yes.
Q. Did you ever see him appear to be drunk -- well, let me ask you this: Was there ever
any effort that you saw to conceal this fact that Mr. Jackson had been drinking, that he
was drunk, to conceal that fact from his children?
MR. MESEREAU: Objection. Vague; leading; foundation.
THE COURT: Foundation; sustained.
Q. BY MR. AUCHINCLOSS: Mr. Salas, when you saw Mr. Jackson when he was drunk,
did you ever see him in the presence -- in that condition, in the presence of his children?
A. Yes, I did.
Q. On more than one occasion?
A. Yes.
Q. Can you tell me how many or approximate?
A. Well, I couldnt tell you exactly how many times, but it was quite a few times.
Q. During that period of time -- and tell me -- lets get time specific here. What time
frame are we talking about? Is this when you were house manager?
A. That is correct.
Q. During that period of time did you ever see Mr. Jackson make any effort to conceal his
condition from his children?
MR. MESEREAU: Objection. Vague; foundation; calls for speculation.
THE COURT: Im going to allow an answer to that question, but again, its a foundational
question. So it can only be answered yes or no. Ill have the court reporter read it back
to you. Were asking do you have this knowledge. (Record read.)
THE WITNESS: Can you ask me the question a different way?
MR. AUCHINCLOSS: Sure.
Q. My question is, during the period of time when you saw Mr. Jackson when he was
drunk in the presence of his children, d id Mr. Jackson do anything to hide the fact that he
had been drinking or that he was drunk when that occurred, when you saw that?
MR. MESEREAU: Same objection.
THE COURT: Overruled. You may answer.
THE WITNESS: Not to my knowledge.
Q. BY MR. AUCHINCLOSS: You said that wine is stored in the wine cellar. Is there any
hard liquor thats ever kept in the wine cellar?
A. Yes.
Q. What kind of hard liquor?
A. Theres some whiskey, I believe. Some tequila. Pretty much thats it.
Q. And was there whiskey and tequila in the wine cellar during the time that the Arvizo
children were there in 2003?
A. Yes.
Q. Did you ever see kids go into the wine cellar, any kids, during your period of time as

house manager?
A. Yes.
Q. And did you ever see the Arvizo kids go into the wine cellar?
A. I never saw them down in the wine cellar.
Q. Did you ever see them come out of the wine cellar?
A. No.
Q. Okay. Did you ever have any reports, as house manager, that the Arvizo children were
in the
wine cellar?
MR. MESEREAU: Objection; hearsay.
THE COURT: Overruled. You may answer.
THE WITNESS: Not specifically the Arvizo kids.
Q. BY MR. AUCHINCLOSS: Okay. Have you ever served wine or any alcoholic beverage
to Mr. Jackson when he was in the presence of children?
A. Yes, I did.
Q. On more than one occasion?
A. I would say that was a couple times.
Q. Do you remember any of the children that were with him when you served him
alcoholic beverages, or wine, lets say?
A. Im not exactly what kids were in there, but I know the Arvizos were there, the kids,
and some other kids that were there as well.
Q. Okay. Now, tell me, was there a time when you brought him some wine and four
glasses?
MR. MESEREAU: Objection; lead ing.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Okay. Tell me -- you said there was a couple of times that
you brought Mr. Jackson wine in the presence of children. Tell me about the first one you
remember. When was it?
A. It was at nighttime.
Q. Do you remember when it was in terms of the year that you served as house manager,
approximately?
A. Well, it was -- I would say it was January somewhere. January, somewhere around
there.
Q. Of 2002, 2003?
A. 2003.
Q. And about what time of night?
A. It was about -- I would say it was about nine oclock.
Q. And where did you go, what room?
A. I went to Mr. Jacksons bedroom, upstairs.
Q. And what did you bring to Mr. Jacksons bedroom?
A. I brought some glasses, and some wine.
Q. What type of wine; do you remember?
A. I dont remember the type of wine.
Q. Do you remember whether it was red or white?
A. I want to say that it was a white wine.
Q. What type of glasses did you bring? 4680
A. Glass -- it was just glass wines.
Q. Im sorry?

A. Glass wines.
Q. Wine glass?
A. No, let me back up. It was just glasses, normal glasses.
Q. Normal glasses?
A. Yes.
Q. Were they tall glasses or short glasses?
A. Short glasses.
Q. Can you describe them?
A. Short glasses.
Q. And who ordered this wine?
A. Mr. Jackson.
Q. Did you talk to him personally?
A. Yes.
Q. What did he tell you?
A. He called me and asked me to bring some glasses to his room and some wine.
Q. Did he tell you how many glasses?
A. Yes.
Q. How many?
A. Four of them.
Q. All right. So you brought the -- and did you do as he ordered you to do?
A. Yes, I did.
Q. And when you delivered this wine, did you deliver it to his bedroom?
A. Yes, I did.
Q. Did you deliver it to the lower portion of his bedroom or the upstairs portion?
A. Just to the lower portion.
Q. Was Mr. Jackson or any of the children present when you delivered this wine?
A. Yes, there were.
Q. Who was present?
A. The kids that were there. Gavin, and I believe it was also Franks brothers, the ones
that were there. But let me tell you something else. He also ordered some sodas with
that.
Q. Okay. So what do you mean, some sodas?
A. He also asked me to bring some sodas with that order.
Q. Tell me what you mean by sodas.
A. Yes, just the normal soda cans.
Q. Soda drinks?
A. Yes.
Q. Now, you have previously talked to the sheriffs about this incident, havent you?
A. Right. Right.
Q. And described for them that you brought a bottle of wine and glasses?
A. Uh-huh.
Q. Let me back up. Let me back up. So you brought some wine and glasses, and some
sodas?
A. Uh-huh.
Q. Lets move on to the second incident first, okay?Tell me about the second incident.
When did that occur?
A. That was -- it was also -- it was also nighttime.
Q. Nighttime?

A. Right.
Q. About what time?
A. That time it was about around eleven oclock. Somewhere around 11:00.
Q. And was this before or after the incident that you just described?
A. That was after.
Q. And who placed the order on this occasion?
A. Mr. Jackson.
Q. And what did he order?
A. Some more wine.
Q. Okay. Did he also ask for glasses?
A. Yes.
Q. How many glasses?
A. This time I believe it was just one glass. It was just for him.
Q. Okay. And who was present when that -- when you delivered that wine?
A. Im not exactly sure who was there, but I believe this time it was himself at night. 4683
Q. But Im talking about -- you said there were two times that children were present when
you served him. Im talking about the second time that children were present.
A. Yeah, that time Im not exactly who was there, how many of the kids were there.
Q. Youre not sure?
A. No, Im not sure.
Q. All right. Now, lets go back to this time -- this first incident where you said that you
served wine and soda. You have been interviewed about this by the sheriffs department,
right?
A. That is correct.
Q. And you were interviewed back in, I believe it was, 2003; is that right?
A. Thats correct.
Q. And when you talked to the sheriffs department about this, you never mentioned
anything about any soda?
A. No, I didnt.
Q. And why is that?
A. I dont know. It just -- it just flip out right now to my mind.
Q. You just remembered it just this second?
A. Right.
Q. And you said that you came back and the bottle of wine was empty?
A. That is correct.
Q. Was there any other liquor you brought?
A. No, that was the second time -Q. Im talking about the first time.
A. No, that was it.
Q. And when you came back, was the bottle empty?
A. Yes, it was.
Q. Okay. The wine cellar. You said you didnt ever have any complaints of -- hear of any
complaints regarding the Arvizos. Did you ever have any other complaints of any other
children in the wine cellar?
A. Yes.
Q. And do you know which children they were?
A. When I was given those complaints, it was about the kids from Los Olivos.
MR. AUCHINCLOSS: Okay. If I could have the Elmo again, Your Honor, please.

Q. Showing you Peoples Exhibit 45. Is that

20 one of the kids youre talking about?
A. Yes.
Q. 46?
A. Yes.
Q. Thats one of the kids?
A. Thats correct.
Q. And 47.
A. That is correct.
Q. Okay. Are there any other kids that youre referring to, or is that everybody that were
talking about?
A. No, I did get some other complaints about some other kids which wasnt these kids.
Q. Okay. Now, these three kids that -- I think youve identified them as being from Los
Olivos previously, correct?
A. Thats correct.
Q. Well call them the Los Olivos boys, okay?
A. Okay.
Q. Now, the Los Olivos boys, you said you had a complaint, comp laints regarding them in
the wine cellar. W hat was the nature of the complaint?
MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: Its offered to explain conduct.
THE COURT: Whose conduct?
MR. AUCHINCLOSS: Mr. Salass. And I can tell you at sidebar where Im going, if you
like.
THE COURT: The objection is sustained.
Q. BY MR. AUCHINCLOSS: Did you personally ever see the Los Olivos boys in the wine
cellar?
A. Not in the wine cellar, but I saw them come out.
Q. You saw them coming out of the wine cellar. And when you saw them coming out of
the wine cellar, what time of day are we talking about?
A. Early in the morning, around eight oclock in the morning.
Q. And during that previous -- lets say the ten hours -- well, lets see, let me back up. Do
you know if Mr. Jackson was in the win cellar with them?
A. That early morning, or late night, early morning, Mr. Jackson was with the kids.
Q. And when you saw these kids come out of the within cellar, did you notice whether or
not they exhibited any signs of being intoxicated?
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes, I did.
Q. BY MR. AUCHINCLOSS: Tell me what you saw.
A. When I saw the boys coming out of the arcade, which is where the wine cellar is, the
kids werent acting normal. So I approached one of them, and I said, Are you okay?
Thats when I noticed that the kids were drunk.
Q. How drunk were they, if you could characterize it?
A. I would say that they were -- what would you call it? I mean, you can tell that they
were drunk. I mean, I could see that they had been drinking.
Q. What were they doing that made you believe theyd been drinking?
A. The way they were acting. I mean, they werent just normal. Something was wrong

with the kids.

Q. Did you notice any other times when these three boys had been drinking, and it was
apparent to you that they had been drinking?
MR. MESEREAU: Objection. Leading; relevance; foundation.
THE COURT: Overruled. You have may answer.
THE WITNESS: Your question was what date?
Q. BY MR. AUCHINCLOSS: No, my question -- youve told us about one incident where
you noticed the three Los Olivos boys had been drinking. I want to know if you ever
observed a second time that these same boys had been drinking.
A. Yes, there was a second time.
Q. And when was that?
A. I want to say it was -- it was after that one. Not exactly sure, you know, how many
weeks after that. But I would say it was two, three weeks after that one.
Q. And when was the first time, approximately?
A. I want to say it was in October when I saw those kids the first time.
Q. 2002? 2003? You tell me.
A. It was 2002, I believe.
Q. Okay. And where did you see these boys the second time when they appeared to have
been drinking?
A. At the house.
Q. Inside the house?
A. Yes. Well, they were everywhere, but, yes, they were in the house.
Q. Was Mr. Jackson on the property at that time?
A. Yes, he was.
Q. Had these boys been spending any time with Mr. Jackson that day?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Had you observed whether or not Mr. Jackson had spent any
time with these boys earlier that day?
A. I dont believe that day he spent time with them. They were alone.
Q. Okay. Did you see the boys all -- during the entire time they were on the property?
A. Yes.
Q. You were with them the entire t ime?
A. No.
Q. So do you know whether or not they spent time with Mr. Jackson for certain?
MR. MESEREAU: Objection. Leading; foundation.
THE COURT: Argumentative; sustained.
Q. BY MR. AUCHINCLOSS: Okay. So what portion of that day did you spend actually
observing the boys? Let me back up. Let me back up. How long were these boys on the
property that particular day?
A. They were there till twelve oclock, one oclock.
Q. At night?
A. Uh-huh.
Q. Or one oclock in the morning, I guess?
A. One oclock in the morning, yes.
Q. And when did they arrive?
A. They arrived around noontime.
Q. And how much of that time -- so thats about 12 hours, right?

A. Right.
Q. How many of those hours were they in a place that you could see them, where you
were actually seeing them?
A. Well, they were back and forth, and they were everywhere, so I really didnt have a
control of watching them or any of that stuff.
Q. Okay.
A. But they were back and forth in the house, back at the park, different places.
Q. Do you know where they got their alcohol?
A. No, I dont.Q. Were you responsible for cleaning the wine cellar?
A. Yes.
Q. Did you observe any other incidents where Mr. Jackson was in the wine cellar with
children? I mean, did that happen on other occasions? And Im confining this just to the
time you were house manager.
A. No, I dont.
Q. Do you know? You dont recall any other times?
A. Not that I can rememb er.
Q. Okay. Now, during the time that you were house manager, did you ever observe any
adult magaz ines in Mr. Jacksons private quarters?
A. Yes, I did.
Q. Did these magazines feature nudity?
A. Yes.
Q. And where were these -- which room were these magaz ines in?
A. They were on the first floor on the left side in one of the bathrooms.
Q. Were those magazines there in that bathroom during the time that the Arvizos were at
Neverland?
A. Yes.
MR. AUCHINCLOSS: Madam Clerk, may I double-check with you? I have three items Im
marking. I want to double-check and make sure these numbers havent been used. 777,
778, and 779.
THE CLERK: No, they havent.
MR. AUCHINCLOSS: All right. Thank you. May I approach, Your Honor?
THE COURT: Yes.
Q. Mr. Salas, I show you Peoples Exhibit 777. Can you identify that for me, please?
A. Yes. These are some statues that were in Mr. Jacksons office.
Q. I show you Peoples Exhibit 778. Would you please ident ify that for me?
A. Yes, they were also in his office.
Q. And Peoples Exhibit 779?
A. Yes. That is correct. They were in his office.
Q. Okay. Thank you. Can you tell me where these statues were located?
A. They were located in Mr. Jacksons office. They were placed on different stands.
Q. Were they on display?
A. Yes.
Q. Over what period of time are we talking about?
A. Well, they have been there a long time.
Q. Were they there the entire time you were house manager?
A. Yes.
Q. Were they there during the time that the Arvizos were present on the property?
A. Yes.

Q. Were they there -- did Mr. Jacksons children ever visit that office?
A. Yes.
MR. AUCHINCLOSS: Your Honor, Id like to offer into evidence Peoples Exhibit 777, 778
and 779 at this time.
MR. MESEREAU: No objection.
THE COURT: Its admitted. All three.
MR. AUCHINCLOSS: All right. If I may publish these, Your Honor.
THE COURT: All right.
Q. BY MR. AUCHINCLOSS: All right. Showing you Peoples Exhibit 777, is that an
accurate depiction of one of the dolls that you saw in Mr. Jacksons office?
A. That is correct.
Q. Or statues. Whatever they are. 778, there are two photographs there. Do those
photographs accurately depict the dolls that were present during the period of time that
you were house manager in Mr. Jacksons office?
A. Yes.
Q. And 779; same questions. Were those -- are those accurate depictions of what you
observed in Mr. Jacksons office during the time that you were house manager?
A. That is correct.
Q. All right. Going back to the period of time when the Arvizos were on the property, was
there -- and I want to talk about the first visit, the first visit in 2003, after you picked up
the Arvizos from the airport. You previously testified that they were at Neverland for a
period of approximately two weeks. Mr. Salas, during that period of time did you observe
the Arvizo family to be restricted in any way?
A. That is correct.
Q. In what way were they restricted?
A. I believe they werent allowed to leave Neverland Valley Ranch.
Q. And why do you say that?
A. Because I had a talk to the mother and shes the one that told me.
MR. MESEREAU: Objection, thats hearsay. Move to strike.
MR. AUCHINCLOSS: Goes to state of mind. Also offered to explain this witnesss conduct
later.
THE COURT: I will ad mit it for the limited purpose of explaining the conduct of Jesus. Its
not to be used for the truth of the matter asserted by Janet.
MR. AUCHINCLOSS: All right.
Q. So at some point, did you personally help the Arvizo family to get out of Neverland?
A. Yes, I did.
Q. How did you do that?
A. I took them down to L.A.
Q. You drove them personally?
A. Yes, I did.
Q. Did you take -- use -- I take it you used one of Mr. Jacksons cars?
A. That is correct. I got a phone call from her, and she wanted to talk to me about
something.
MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: Its offered for the same purpose.
THE COURT: Its nonresponsive. Sustained.
MR. AUCHINCLOSS: Okay.
Q. So tell me what precipitated your conduct of helping the Arvizos by taking them off the

property. What happened? What was it that made you do that?

A. Like I said, she called me at my office and wanted to talk to me. So I came over, and I
thought it was something that I needed to take care of, you know, in the room. And she
asked me to -MR. MESEREAU: Objection, hearsay, Your Honor.
THE COURT: Ill admit it for the limited purpose again to explain what hes doing, not for
the truth of the matter that she asserted.
THE WITNESS: So she asked me -- she told me if I can drive them down to L.A., that
she wanted to leave the property. So I ask her, you know, Whats the reason? Why do
you want to leave the property? She was very -MR. MESEREAU: Same objection.
THE COURT: Sustained after he started on another subject.
MR. AUCHINCLOSS: Okay.
Q. Can you tell me what her emotional state was at the time?
A. She was very upset.
Q. How was she demonstrating that she was upset?
A. Crying.
Q. What time of -- what time of the day or evening are we talking about here when this
happened?
A. Were talking about nighttime.
Q. Nighttime?
A. Yes.
Q. Did she express any -- did she express any fear while you were talking to her?
MR. MESEREAU: Objection; leading.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: When you were talking to her, did she appear to be fearful of
something?
MR. MESEREAU: Objection; lead ing.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Tell me about any other 4696 emotional -- expressions of
emotion that she had, if you noticed any.
A. Well, she looks very preoccupied. She was just -- she wasnt comfortable there. She
just wanted to leave the property.
THE COURT: All right. Lets take our break.
THE COURT: Go ahead, Counsel.
MR. AUCHINCLOSS: Thank you, Your Honor.
Q. Before I continue where I left off with the Arvizos, Mr. Salas, I wanted to ask you a
couple of questions about -- one involving the wine cellar. At some time during your
occupation as the house manager, was there a safe that was put in to keep some of the
keys to various places, including the wine cellar?
A. Yes, there was.
Q. And where was that safe put in?
A. It was in the -- inside the house in what we call the maids room.
Q. When was that safe put in?
A. It was during the time that we noticed the kids were having access to alcohol.
Q. The Los Olivos boys?
A. That is correct.
Q. And can you help me out with the time frame in terms of what were -- 2002 or 2003?

A. 2003.
Q. 2003?
A. Yes.
Q. You said that it was October of 2002 when the problem occurred with the Los Olivos
boys.
A. Yes, but we didnt took action until after that. It took us a while to put the key away.
Q. Have you previously told detectives that it 4702 was in the -- it was around December
of 2002 that the safe was put in?
A. I must have said that. I mean, I could be wrong.
Q. Do you have a clear reco llect ion of exactly when the safe went in?
A. I dont know.
Q. Do you recall that the safe was there when the Arvizos were there?
A. Yes, it was in, the safe.
Q. All right. And the wine cellar key, was it kept in that safe?
A. That is correct.
Q. All right. So when you took the Arvizos from Neverland, what car did you use?
A. I used the Rolls Royce.
Q. And who was it that decided to use that particular car? Whose decision was that?
A. It was my decision.
Q. Had you previously done some driving for Mr. Jackson? I know you previously testified
you did the limo drive to Neverland. But other than that, had you previously done some
driving for
Mr. Jackson?
A. Yes, I did.
Q. And did you previously use that car on occasion?
A. Yes.
Q. Did you tell anybody that you were taking the Jacksons -- or did you tell anybody that
you were taking the Arvizos off property?
A. Yes, I did.
Q. Who did you tell?
A. I told Mr. Jacksons bodyguard, Chris Carter.
Q. And why did you tell Chris?
A. Because it was not my decision to make to take the family off the property without
telling somebody.
Q. Okay. Was Dieter on the property at the time?
A. Yes, he was.
Q. Was Ronald on the property at the time?
A. No, he wasnt.
Q. Was Frank on the property at the time?
A. Yes, he was.
Q. Was there a reason you didnt tell Dieter or Frank that you were taking them off the
property?
A. It was late, and the reason I didnt told them, it was because I didnt know who to tell,
so I told Chris about the situation.
Q. Okay.
A. And so -Q. Did Miss Arvizo express to you, during that period of time, that she was fearful of
anything?

MR. MESEREAU: Objection; leading. 4704

THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did Miss Arvizo express concern to you over any particular
individuals at Neverland?
MR. MESEREAU: Objection; leading.
THE COURT: Overruled.
THE WITNESS: Yes, she did.
Q. BY MR. AUCHINCLOSS: Who was she concerned about?
A. It was Dieter and Ronald.
Q. Was she concerned about Frank at all?
A. She didnt really say too much about Frank.
Q. So you drive her off the property. Where did you take her and her children?
A. Down south, L.A.
Q. Did you take her to a residence?
A. Yes.
Q. Was it a house or an apartment?
A. It was a house.
Q. And was it the place -- did she direct you to the location where she wanted to go?
A. Yes.
Q. Did you get in any trouble for taking the Arvizos off the property?
A. Yes, I did.
Q. Tell me about that.
A. Well, the next day, I was told that they werent supposed to leave the property. 4705
MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: I can ask a couple of other questions that will tighten it up, Your
Honor.
THE COURT: All right. Ill strike the answer.
MR. AUCHINCLOSS: And this answer will be offered in furtherance.
Q. Who told you you were in trouble?
A. The first person that told me, it was Frank.
Q. Frank Tyson?
A. Uh-huh.
Q. And what did Frank tell you?
A. He told me not -- that they werent supposed to leave the property. They were
supposed to be notified first.
Q. Who was supposed to be notified first?
A. Him.
Q. Did he tell you how to handle yourself in the future?
A. Yes, he did.
MR. MESEREAU: Objection; leading.
MR. AUCHINCLOSS: Ill rephrase.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did he make any remarks to you concerning the future?
A. Yes, he did.
Q. What did he say?
A. Not to make -- I mean, if it was a second time, not to do that anymore.
Q. Not to let the Arvizos off the property if they come back?
MR. MESEREAU: Objection; leading.

THE COURT: Sustained.

MR. MESEREAU: Move to strike.
THE COURT: Stricken.
Q. BY MR. AUCHINCLOSS: Did anybody else tell you that you did the wrong thing?
A. Yes.
Q. Who was that?
A. Dieter.
Q. What did Dieter tell you?
A. Same thing.
MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: Same purpose.
THE COURT: Overruled. Its admitted for the limited purpose under the conspiracy
instruction that I talked to you about earlier. Go ahead.
Q. BY MR. AUCHINCLOSS: Tell us what Dieter told you.
A. He told me the same thing; that next time I should tell them about the situation first.
Q. Did the Arvizos -- well, let me back up. When Miss Arvizo was talking to you about her
desire to leave the ranch, did you speak English with her?
A. Yes, I did.
Q. Did you ever speak with her in a different language?
A. No.
Q. Okay. Are you fluent in Spanish?
A. Yes, I am.
Q. Do you know if she is?
A. No, I dont.
Q. Around -- well, lets talk about when they returned to the property. You said a short
time after the first -- they first left Neverland, the Arvizos returned.
A. Thats correct.
Q. Were you there when that happened?
A. Yes.
Q. And when they returned to the property, did Mrs. Arvizo ever ask you to transport her
off the property on that occasion, on the second visit?
A. Yes, she -MR. MESEREAU: Objection. Leading; hearsay.
MR. AUCHINCLOSS: Also offered to explain conduct.
THE COURT: The objection is overruled. And Ill admit it for the limited purpose of
explaining his behavior. Go ahead.
Q. BY MR. AUCHINCLOSS: What was your answer?
A. Yes. Yes, I was.
Q. And when did she make that request of you, in relat ionship to the time that she
arrived?
A. I would say it was -- it was about a week when she asked me again.
Q. And did you take her off the property that time?
A. No, I didnt.
Q. Why not?
A. Because I was told not to do that anymore.
Q. Now, at some point the Arvizos left Neverland -A. Yes, they did.
Q. -- for the final time. Have you ever seen them since that time?

A. That was the last time I saw them.

Q. Do you recall when you were first interviewed about the general facts that youve just
described for us by law enforcement?
A. Yes.
Q. And was there anything special about that particular day when you first spoke to law
enforcement?
MR. MESEREAU: Objection. Vague; leading.
THE COURT: Overruled. You may answer.
THE WITNESS: When you said about special, what do you mean?
Q. BY MR. AUCHINCLOSS: Was there anything unusual that happened on that date -A. Yes.
Q. -- that youre aware of?
A. Yes, it was.
Q. What was it?
A. That was when the police came over to Mr. Jacksons house.
Q. The day of the search warrant?
A. The day of the search, yes.
Q. Do you remember what month that was?
A. It was November.
Q. Okay. So you told the police about this, helping the Arvizos, on the same day as the
search warrant was issued, or executed, I should say; is that accurate?
A. That is correct.
MR. AUCHINCLOSS: Thank you, Mr. Salas. I have no further questions.
THE COURT: Okay. Cross-examine?
MR. MESEREAU: Yes, please, Your Honor.
CROSS-EXAMINATIONBY MR. MESEREAU:
Q. Is it Mr. Salas or Salazar?
A. Salas.
Q. Salas, okay. My name is Tom Mesereau and I speak for Michael Jackson, okay? W e
havent spoken before, right?
A. I believe we have. Didnt you call me one time or something like that?
Q. I didnt. That was an investigator.
A. It wasnt you.
Q. Okay. You spoke to one of our investigators named Jesus Castillo, correct?
A. That is correct.
Q. And you spoke to him around January 9th, 2005, right?
A. Must have been, yes.
Q. Okay. Okay. And do you know -- where did that interview take place; do you know?
A. Yes. Was it the Holiday Inn, Santa Maria?
Q. Okay. And approximately how long do you remember speaking with our investigator,
Jesus Castillo?
A. It took, I would say, about half an hour.
Q. Okay. And do you remember you told Mr. Castillo that when you told the police that
you rememb ered Gavin and Star sleeping in Mr. Jacksons room, you meant the lower
portion of the two-level suite, correct?
A. That is correct.
Q. You told Mr. Castillo that Mr. Jacksons room has an upstairs portion and a downstairs,

correct?
A. That is correct.
Q. And you told him that you never saw Gavin or Star sleeping in Mr. Jacksons bed
located upstairs, right?
MR. AUCHINCLOSS: Ill object; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: That is correct. I never saw them sleeping in the bed. I saw them out of
bed, not sleeping.
Q. BY MR. MESEREAU: Right. The only place you ever saw Gavin or Star sleeping was in
the downstairs portion of Mr. Jacksons room, right?
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: That is correct.
Q. BY MR. MESEREAU: Okay. And you remember many guests of Mr. Jackson sleeping in
his room, sometimes upstairs and sometimes downstairs, right?
A. That is correct, if youre talking about the boys, yes.
Q. Yeah. He had guests come and sleep from time to time -A. That is correct.
Q. -- in that suite, correct?
A. That is correct.
Q. Sometimes youd see them upstairs, sometimes youd see them downstairs, right?
A. That is correct.
Q. Okay. Now, one time you suspected that Gavin might have been drinking at a dinner
table, right?
A. That is correct.
Q. But you never saw Gavin drinking, right?
A. That is correct.
Q. And his family used to have dinner at the dinner table, right?
A. That is correct.
Q. His mother used to have dinner at the dinner table, correct?
A. Yes.
Q. Now, the prosecutor asked you questions about whether or not children have a lot of
freedom at Neverland, right?
A. Right.
Q. And your answer was basically they do, right?
A. That is correct.
Q. And so do their parents have freedom at Neverland, correct?
A. That is correct.
Q. The prosecutor asked you about something along the lines of first-class service. Do you
remember that?
A. Yes.
Q. And you said that Mr. Jackson liked to have his guests get high-quality service, right?
A. That is correct.
Q. But when you said that, you were also including adult guests, correct?
A. Right.
Q. And when you were there and you saw Janet Arvizo there, she was getting first-class
service, true?
A. Yes, she was.

Q. Do you remember a period of time when Janet Arvizo was there with her former
husband, David Arvizo? Do you remember that?
A. One time, yes.
Q. And they both were entitled to first-class service, correct?
A. That is correct.
Q. And when Janet came with just her children, she had all the privileges that guests get
at Neverland, right?
A. That is correct.
Q. She was able to enter the main residence, right?
A. Yes.
Q. She was able to order food when she wanted, correct?
A. Yes.
Q. She could sit at the dinner table at the main house and have dinner, or lunch, or
breakfast, right?
A. That is correct.
Q. She also was allowed to enter the kitchen and sit at that bar area and order breakfast
when she chose, right?
A. That is correct.
Q. She also ordered room service when she wanted, right?
A. That is correct.
Q. And do you know which quarters she stayed in?
A. If I remember, it was on Unit 4.
Q. And thats one of the most beautiful rooms on that property, isnt it?
A. Yes, it is.
Q. Its a room where Elizabeth Taylor and Marlon Brando request to stay, or used to
request to stay from time to time, correct?
MR. AUCHINCLOSS: Objection; relevancy.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Janet was entitled to the same service that guests like Elizabeth
Taylor and Marlon Brando would get, correct?
MR. AUCHINCLOSS: Objection; relevancy.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Right?
A. That is correct.
Q. And when you told the jury that the theater would be open day and night, adult guests
also were allowed to go into the theater day or night, right?
A. That is correct.
Q. And when you told the prosecutor that there was some rooms in the theater with beds
in them, adults could use those rooms, true?
A. That is correct.
Q. The prosecutor talked about candy and sodas and food being availab le at all hours of
date. They were also available for adult guests, correct?
A. That is correct.
Q. And isnt it true that Mr. Jackson wanted his adult guests to have special, classy
service, right?
A. That is correct.
Q. Now, you saw kids at Neverland vis iting when Mr. Jackson wasnt there, correct?
A. That is correct.

Q. And typically, if kids visited Neverland when Mr. Jackson wasnt there, there were rules
that were supposed to be followed for safety, as you said, right?
A. That is correct.
Q. And typically, it was their parents or whatever adults were with them that appeared to
be in charge of them, correct?
A. That is correct.
Q. And you saw busloads of children from various locations visit Neverland from time to
time, correct?
A. That is correct.
Q. And to your knowledge, Mr. Jackson wasnt in charge of all of those busloads of
children, was he?
A. No, he wasnt.
Q. In fact, most of the time when lots of kids would visit Neverland, some other adult
appeared to be in charge of those kids, right?
A. That is correct.
Q. And adults and children would visit Neverland and be given tours of Neverland, right?
A. That is correct.
Q. Who typically would give those tours?
A. We assigned different people, employees of Neverland Valley.
Q. And tell the jury how a tour would be conducted when children and adults would visit
Neverland.
A. They were -MR. AUCHINCLOSS: Objection. Relevancy; beyond the scope.
THE COURT: Overruled. Go ahead.
THE WITNESS: They would arrive at Neverland Valley Ranch, park on the outside parking
lot, walk to the train station. And from there, they were picked up either by train or walk,
whatever they preferred to do, okay, take them back to the theater. Enjoy, you know, the
petting zoo. They were allowed to visit where they wanted to. I mean, we had a schedule
for them and took them everywhere, the property, to show them the place and enjoy the
place. And they ended up at the theater and at the park.
Q. BY MR. MESEREAU: And you would schedule lots of tours from time to time, right?
A. That is correct.
Q. Sometimes youd have a couple of hundred children visiting with adults, correct?
A. That is correct. Sometimes more than that.
Q. Whats the largest number of kids you remember visiting at one time to Neverland?
A. I would say about 300, 300 kids.
Q. And did they come with adults who were in charge of them?
A. Yes.
Q. Okay. And did you arrange tours for these children as well?
A. Yes. We assigned the personnel to give them a tour, yes.
Q. Okay. And sometimes, if Michael Jackson was on the premises, he would come out and
say hello, right?
A. That is correct.
Q. But he never was in charge of what these kids did, right?
A. That is correct.
MR. AUCHINCLOSS: Objection; vague as to kids.
THE COURT: Overruled. The answers in. Next question.
Q. BY MR. MESEREAU: Who would prepare the schedule to indicate whether children

were coming to Neverland on a particular day?

A. I believe that came from L.A. office.
Q. And would it be posted somewhere?
A. Yes. All Neverland personnel got a schedule of the kids coming to Neverland.
Q. And would you get a schedule typically the day before or that morning?
A. Normally we got it, like, two days before, a day before, yes.
Q. And as part of your work, you had to look at the future schedule every day, didnt you?
A. That is correct.
Q. Because almost every day something unusual or special would be going on at
Neverland, right?
A. That is correct.
Q. And how long did you work at Neverland?
A. The total was 20 years.
Q. During that 20-year period, would it be accurate to say that many, many thousands of
children came through, right?
A. That is correct.
Q. They came from Los Angeles, right?
A. That is correct.
Q. They came from Santa Barbara, right?
A. Right.
Q. They came from foreign countries, right?
A. That is correct, yes.
Q. Based upon your experience over 20 years, Neverland was a real attraction for children
around the world, wasnt it?
A. Yes, it was.
Q. And you considered a major part of your responsibility to be making sure that
Neverland was kept up properly so that when children from all over the world came,
theyd have a good time, right?
A. That is correct.
Q. Over 20 years, it may have been hundreds of thousands of children you saw visit,
right?
A. That is correct.
Q. Now, the prosecutor asked you about the time Janet Arvizo asked you to drive her to
Los Angeles, okay?
A. Correct.
Q. You told Jesus Castillo, our investigator, that at no time did anyone forcibly keep her at
Neverland Ranch, right?
A. That is correct.
Q. And at no time was she ever locked in her room, right?
A. Not that I was aware of.
Q. And at no time was she kept at Neverland Ranch against her will, right?
A. That is exactly what I said, yes.
Q. She called you upset and asked you to take her home and you did so, right?
A. Yes.
Q. You took her, yourself, in December; is that correct? Do you remember what month
you took her yourself in the Rolls Royce?
A. It was Decemb er or January, somewhere around there. Pretty bad on dates.
Q. And then she came back, what, in less than a week?

A. I would say in about a couple weeks, thereabout.

Q. She came back, and then, a few weeks later, wanted to leave again, right?
A. That is correct.
Q. And you arranged transportation for her to leave again, right?
A. Yes, I had to call a limo.
Q. And that was, as far as you know, the last time you ever saw the Arvizos, correct?
A. Correct.
Q. When you drove Ms. Arvizo and her children in the Rolls Royce, she never made any
complaints about the way shed been treated at Neverland, right?
A. That is correct.
Q. She never said shed been abused at Neverland, right?
A. That is correct.
Q. She never said her children had been taken advantage of at Neverland, right?
A. That is correct.
Q. But she didnt seem to like Dieter or Ronald, right?
A. That is correct, yes.
Q. And she told you she was concerned about media attention on her family, right?
A. She mentioned about that, yes.
Q. Her concerns to you were media attention and the fact that she didnt like D ieter, right?
A. That is correct, yes.
Q. She never complained about anything else, did she?
A. No.
Q. In fact, she told you she respected and liked Michael Jackson, right?
A. Yes, she did.
Q. She never complained to you about Michael Jackson at all, did she?
A. Never.
Q. When you drove her in the Rolls Royce, she was in the front seat with you, right?
A. Yes.
Q. Her children were in the back seat, right?
A. That is correct.
Q. And you and she spoke during that three-hour trip, right?
A. She didnt spoke too much, but, yes, she did.
Q. Did you speak to her very much when she used to stay at Neverland?
A. No.
Q. Okay. And in -- on that trip, excuse me, Janet Arvizo never complained that she was
being taken out of the country against her will, did she?
A. No, she never said anything.
Q. Do you remember when she returned, you think, within the next couple of weeks?
A. It was in the next couple of weeks, yes.
Q. Do you remember seeing her suddenly show up with her children again?
A. Yes.
Q. And do you know what time of day that was?
A. I believe it was afternoon.
Q. Did you talk to her when you saw her return?
A. Yes, I did.
Q. You never got the impression she was there against her will at that point, did you?
A. No, I didnt.
Q. The last time Janet and the kids left Neverland, do you know who drove them home?

A. Yes, I called a limousine service.

Q. So you took her in a Rolls Royce one time, and the last time it was a limousine service
that you arranged, true?
A. That is correct.
Q. Do you remember any other times that Janet and the children left Neverland?
A. That was the last time I saw them.
Q. So youre only personally aware of two times where they left Neverland; is that right?
A. Yes.
Q. That you had anything to do with?
A. That is correct.
Q. Okay. Now, the prosecutor asked you about a safe that was brought onto the property
to lock keys. Do you remember that?
A. Uh-huh.
Q. And if you remember, whose idea was it to put a safe where the keys could be locked?
A. It was the ranch manager idea and my idea.
Q. Did you discuss it with Michael Jackson?
A. No, we never d id.
Q. You just ordered a safe?
A. We just ordered a safe.
Q. And you put the keys in the safe?
A. That is correct.
Q. And before that, where were the keys kept?
A. They were kept in the same room, behind 472 the -- behind the door to the entry to
the room, yes.
Q. Is that the entrance to the wine cellar?
A. No, no, no. Thats the entrance to the maids room.
Q. Okay. Okay. But they were hung out in open view, right?
A. That is correct, yes.
Q. Do you remember Frank Tysons sister, Marie Nicole?
A. Yes.
Q. Do you remember her staying at Neverland?
A. Yes.
Q. Do you remember her walking around the property and playing with Michael Jackson?
A. Yes, I do.
Q. Was it your impression that the family was close to Michael Jackson?
A. Yes.
Q. Did you see Frank Tysons parents visit from time to time?
A. That is correct, yes.
Q. And do you remember their names?
A. I dont. Sorry.
Q. Did you see Frank Tysons brothers visit from time to time?
A. Yes.
Q. Okay. You talked about a combination to Mr. Jacksons room. Remember that?
A. Yes.
Q. And did you always have that comb ination?
A. Yes, I did.
Q. Do you know if anyone else had it, to your knowledge?
A. Ranch manager.

Q. What about staff who cleaned the room? Did they typically have it?
A. Yes. Yes. We have -- we had another guy there that also had it, know the combination
of the room.
Q. And that combination was changed periodically, right?
A. My time there, we changed it about a couple times.
Q. Okay. Do you remember it being changed because too many people seemed to have it?
A. We noticed there was so many kids going into the room, so we figured we change the
combination, yes.
Q. Do you remember Michael Jackson complaining that Frank was going into his bedroom
when Michael was out of town?
MR. AUCHINCLOSS: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Was it your understanding that Frank could get into that room on
occasion?
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know whether or not Frank seemed like he could get into
Michaels bedroom from time to time?
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you ever observe Frank in Michael Jacksons bedroom?
A. Yes.
Q. Did you ever see Marie Nicole in Michael Jacksons bedroom?
A. Yes.
Q. And again, when I say bedroom, were talking about two levels, right?
A. That is correct.
Q. Its a rather large area, isnt it?
A. That is correct, yes.
Q. And on the lower level, people can sit down and enjoy themselves, cant they?
A. That is correct. Yes.
Q. What do you recall there being on the lower level of Michael Jacksons bedroom when
you were working there?
A. I just recall that it was a peaceful area that people can sit and enjoy themselves there.
Fireplace or -- it was pretty peaceful p lace to be.
Q. And he would entertain people in the lower portion of his bedroom, correct?
A. That is correct, yes.
Q. People would get served food there, correct?
A. That is correct, yes.
Q. People would get served drinks there, right?
A. That is correct.
Q. And you say theres a fireplace?
A. Theres a fireplace there.
Q. People would sit around the fireplace and chat, correct?
A. Yes.
Q. And sometimes they did it when Mr. Jackson was there, and sometimes they did it
when he wasnt there, right?
MR. AUCHINCLOSS: Objection. Foundation; assumes facts.
THE COURT: Overruled. You may answer. Do you want the question read back?

MR. MESEREAU: Do you want -- Im sorry.

THE WITNESS: Answer it?
THE COURT: Yes. Do you want the question read back?
THE WITNESS: No, I understood the question. Pretty much when Mr. Jackson wasnt
there, nobody was allowed to go into his room.
Q. BY MR. MESEREAU: There were times when he let people in, werent there? 4728
A. Yes, there was.
Q. And they would have some fun when Mr. Jackson wasnt even there, right?
A. That is correct, yes.
Q. Okay. Now, approximately what year d id you start working at Neverland?
A. Since the beginning, do you mean?
Q. Yes.
A. I would say in 83, 1983.
Q. 83?
A. Uh-huh.
Q. So, there was a point in time where your daughter used to visit Neverland, right?
A. That is correct.
Q. And what is her name?
A. Sandra.
Q. Sandra used to visit when she was approximately five years old, right?
A. Five, six, yes.
Q. She used to play with Michael Jackson, right?
A. Yes, that is correct.
Q. He used to give her gifts, right?
A. That is correct, yes.
Q. Now, normally do people who work at Neverland bring their children there very often?
A. We have -- they have what is called Family Day, yes.
Q. And please tell the jury what Family Day is.
A. Family Day is a day where its open for the employees to bring all your family and have
access to all the facilities there, yes.
Q. And how often does that happen?
A. Once a year at least.
Q. And thats a big event at Neverland, right?
A. That is correct, yes.
Q. And Michael Jackson closes Neverland off for other visits and lets all of the help and
their family take over pretty much, right?
A. Yes, sir.
Q. And it starts in the morning, doesnt it?
A. Yes.
Q. Goes late into the evening, right?
A. Yes.
Q. Now, you mentioned a petting zoo before. Please tell the jury what the petting zoo is.
A. The petting zoo is a place where they have just little animals for kids, where they can
go and play with the animals. We have -- I mean, they have a variety of animals where
kids can, pretty safe, go and touch the animals.
Q. And what kind of animals do you have in the petting zoo?
A. Well, they have llamas. They have deers. They are rabb its. They have pigs. Birds. What
4730 else do they have? They have lots of animals.

Q. And the petting zoo is primarily designed for kids, correct?

A. That is correct, yes.
Q. And then you have a larger zoo, right?
A. That is correct.
Q. And please tell the jury whats in the larger zoo.
A. Well, thats where you can find the big animals. Like you can find elephants, lions,
chimpanzees. You can find llamas and different other animals. Wolfs. Stuff like that.
Q. You got giraffes, right?
A. Giraffes.
Q. Theres a camel?
A. Right, exactly.
Q. And typically, at least once a day, the trainers walk two elephants through the
property, right?
A. That is correct, yes.
Q. And they walk the elephants through the property, and very often guests, if they follow
the rules, can feed them, right?
A. That is correct, yes.
Q. And Mr. Jackson will pay for bags of doughnuts and goodies to give to the elephants,
right?
A. That is correct, yes.
Q. Is that a once-a-day affair?
A. Yes, pretty much once a day.
Q. Okay. Its usually a big thing for kids and their parents, right?
A. Right.
Q. Now, as part of your duties at Neverland, you often would pay for toys for kids,
correct?
A. That is correct. Yes.
Q. And you would be reimbursed, typically, if you spent your own money on toys, right?
A. That is correct, yes.
Q. You would get a reimbursement check of -- for as much as $11,000 from time to time,
right?
A. That is correct, yes.
Q. And what kind of rules did you follow as far as buying toys for kids is concerned?
A. Really wasnt any rules. We just went and bought some toys.
Q. But the prosecutor asked you questions about how influential Mr. Jackson was in
running affairs. Didnt he give you a lot of flexibility in just going out, buying hundreds of
toys, and then just charging him for it?
A. That is correct, yes.
Q. And where would you go buy those toys?
A. Toys-R-Us.
Q. Okay. Would you drive there yourself?
A. Pretty much Mr. Jackson came along or with the kids or some adults, yes.
Q. And Mr. Jackson would from time to time let you drive parents and their children to
Toys-R-Us, right?
A. That is correct. Yes.
Q. And he would tell you to buy them whatever theyd like, right?
A. That is correct, yes.
Q. Youd spend thousands of dollars on these kids, right?

A. That is correct, yes.

Q. And that was one of your responsibilities as ranch manager, right?
A. That is correct. Yes.
Q. To try and take care of the children as best you could, right?
A. Correct, yes.
Q. Now, what are the safety regulations in effect at the zoo, to your knowledge?
A. Well, theres certain regulations for the zoo, especially with the big animals. Again, for
the safety of the guests or kids, yes.
Q. And you have all these amusement rides as well, right?
A. That is correct, yes.
Q. Please tell the jury what amusements rides you have for the kids and the parents.
A. Well, theres different rides. The Ferris wheel. They have the merry-go-round. They
have a b ig slide. They have a -- oh, got -- they have the Sea Dragon. They have various
rides also for kids, for small kids, yes.
Q. And when you have these busloads of kids and adults show up and they want to use
the rides, what safety precautions do you have?
A. Well, we have a -- we just got to make sure that the kids dont get hurt. We have
regulat ions for that. We have personnel there guiding the kids and taking care of the kids
so nobody gets hurt.
Q. And the personnel specialize in the amusement park portion of Neverland, right?
A. That is correct, yes.
Q. And are they in charge of maintaining the rides, making sure the machinerys okay?
A. That is correct, yes.
Q. And were they under your supervision?
A. No.
Q. Okay. Who was supervising the people who run the amusement park?
A. Theres -- Neverland has different groups of people, you know, like departments, what
we call it, and it was the person in charge of the amusement park.
Q. Just like theres a group in charge of the petting zoo and the bigger zoo, right?
A. That is correct, yes. 4734
Q. And when these children and these adults visit Neverland, these different groups are all
available to make sure kids are safe, right?
A. That is correct. Yes.
Q. Now, when you have hundreds of children running around Neverland, they can
sometimes get into all kinds of mischievous situations, right?
A. Absolutely, yes.
Q. Youve seen kids caught in the house in various rooms, right?
A. That is correct.
Q. And theyve been politely asked to leave, right?
A. That is correct, yes.
Q. Youve seen kids trying to get in doors theyre not supposed to get through, correct?
A. Correct.
Q. Youve seen kids trying to get into the arcade whenever they can, right?
A. That is correct, yes.
Q. And kids are sometimes caught with things in their hands, little things they found in the
main house and they have -- you have to take them away from them, right?
A. That is correct, yes.
Q. And its never been your understanding that Mr. Jackson is personally supervis ing all of

this, right?
A. No.
Q. In fact, hes amazingly generous in letting people come into his home and go through
it, and see it, right?
A. Yes, he is.
Q. And this is a large home that has a lot of beautiful ant iques, correct?
A. That is correct, yes.
Q. A lot of family pictures, right?
A. That is correct, yes.
Q. He has things hes collected from all over the world, right?
A. Yes.
Q. And he often lets whoever visits come through the house so they can see all of this,
right?
A. Yes.
Q. And when he has guests stay over in the guest quarters, I believe you said that they
pretty much can walk into that main house when they want right?
A. That is correct, yes.
Q. He has staff available all the time to prepare a meal for them if they want one, right?
A. Yes.
Q. And in that kitchen area, you have unlocked -- an unlocked refrigerator area, correct?
A. Thats correct. Its open.
Q. And they can go in there all the time and get sodas, right?
A. That is correct.
Q. Juice, right?
A. Yes.
Q. Milk?
A. Whatever their choice is.
Q. And youll find wine in there, right?
A. That is correct, yes.
Q. And he lets his adult guests go in there and get wine when they choose, correct?
A. That is correct, yes.
Q. And glasses are nearby if they want a glass, right?
A. Yes.
Q. Its a very large refrigerator area, isnt it?
A. It is.
Q. How many glass doors do you think are on that large refrigerated area?
A. Oh, God. About six, eight, something like that.
Q. Six or eight transparent doors they can go into to get all kinds of beer, wine, soda,
milk, orange juice, right?
A. That is correct, yes.
Q. And theres a menu thats posted on a blackboard most days, right?
A. That is correct, yes.
Q. And what do you typically find on that menu?
A. You find the menu for the food or whatever the people wants to use.
Q. Theres usually some special dishes that the staff are preparing for that day, right?
A. Exactly, yes. Right.
Q. And there also is a standard menu that Michael Jackson printed up that he gives that

people have to order from, right?

A. That is correct, yes.
Q. And you got sandwiches and soup and stuff like that, right?
A. Yes.
Q. And on that bar area where people can come anytime of day, you can sit there and just
ask whoever is there to prepare eggs or an omelet, whatever you want, right?
A. That is correct, yes.
Q. And there are homemade buns and doughnuts that are put on there every day, right?
A. Right.
Q. Anytime of day, 24 hours a day, you can go into that main house and get what you
want, correct?
A. That is correct, yes.
Q. Even when Mr. Jackson is upstairs with his children, very often people will come
downstairs to either see the house or get something to eat, right?
A. That is correct, yes.
Q. The prosecutor asked you about candy and ice cream and stuff like that. Thats
available to everybody, isnt it?
A. That is correct, yes.
Q. Its not just available to children. Its availab le for adults as well, right?
A. That is correct, yes.
Q. And when you walk into that theater, youve got a whole candy/ice cream area in the
front, right?
A. Yes.
Q. And typically, Mr. Jackson will have one of his people there just to serve whatever
people want,
right?
A. That is correct, yes.
Q. Ice cream sandwiches, ice cream cones, right?
A. Whatever they prefer, yes.
Q. Theres a big popcorn area, correct?
A. Correct.
Q. And you will see sometimes visitors looking at movies anytime of day, right?
A. That is correct, yes.
Q. And theres a huge collection of movies they can sometimes choose from, right?
A. Right.
Q. And other times there are just a couple that you can choose for the day, right?
A. That is correct, yes.
Q. Okay. There are other areas of Neverland people want to see, right?
A. Right.
Q. There are areas where they can see Mr. Jacksons costumes that hes worn on music
tours, right?
A. That is correct, yes.
Q. There are areas where they can see his glove? Kids love to see the gloves hes worn,
right?
A. That is correct, yes.
Q. In fact, some of the memorab ilia from his musical tours around the world are actually
in an area not far from the wine cellar; correct?
A. That is correct, yes.

Q. You also have sleeping bags stored down in the area near where the wine cellar is,
correct?
A. That is correct.
Q. Did you work there before Mr. Jackson purchased the property?
A. Yes, I did.
Q. That wine cellar area was already there when Mr. Jackson purchased the property,
right?
A. Yes, it was.
Q. Now, there is a procedures manual at Neverland that, at least on paper, identifies what
people are supposed to do or not do, right?
A. That is correct.
Q. And security is a concern there, is it not?
A. Yes.
Q. Because if you really look at the perimeter of Neverland, you can get in those fences,
cant you?
A. Absolutely, yes.
Q. In fact, its -- its easy for anyone to go in or out of those three-rail fences anytime,
right?
A. Absolutely.
Q. And youve caught people on the property who tried to get over to Neverland and find
Mr. Jackson, correct?
A. Many times.
Q. And there are roads around the property where cars drive at high speeds, correct?
A. Yes.
Q. And there is also a concern that children will somehow wander on the road, right?
A. That is correct, yes.
Q. Let me get back to Janet Arvizo. Didnt she complain one time that she felt Frank and
Vinnie were separat ing her from Michael Jackson?
A. I dont recall her telling me that, no.
Q. Did she complain that Dieter and Ronald were separating her from Michael Jackson?
4741
A. Yes.
Q. She appeared not to like Dieter or Ronald at all, right?
A. That is correct, yes.
Q. When Janet and the children would arrive of the property, were they given assistance
in transporting their luggage to their rooms?
A. Absolutely.
Q. Who would help Janet transport her luggage to her rooms?
A. Many times it was security, Neverland Valley security, or myself.
Q. And would Janet pretty much tell you what to carry from her car or however she got
there?
A. No, not really.
Q. Who would assign the rooms to the Arvizos when they visited and stayed at Neverland?
A. I did.
Q. And what would determine, for you, what room to put them in?
A. It would depend. Many times we had some other guests on the property. And if we
have one available, that was the only one that was going to be for them. And many times
I ask them, Okay, which room do you guys want to stay in? So thats how I decided.

Q. Did anyone ever complain about the room that they were placed in?
A. No, not really.
Q. Did the kids ever comp lain?
A. No.
Q. The rooms they were placed in, as far as youre concerned, were all beautiful rooms,
werent they?
A. Yes, they are.
Q. They were cleaned every day, correct?
A. That is correct.
Q. And they had constant room service if they wanted it, right?
A. That is correct. Yes.
Q. Mr. Jackson wanted them treated just as well as any other guests, right?
MR. AUCHINCLOSS: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: How many times, Mr. Salas, has the prosecution contacted you to
talk to you about the case?
A. A couple times.
Q. And how many times did you meet with representatives of the sheriffs department?
A. A couple times.
Q. They never asked you if you ever brought nonalcoholic beverages for the Arvizo
children, did they? They never asked you that question, did they?
A. No, they didnt. 4743
Q. Now, I think you said that Michael Jackson appeared frustrated at what Frank was
doing on the property from time to time, right?
A. That is correct. Yes.
MR. AUCHINCLOSS: Objection; misstates the evidence.
MR. MESEREAU: I dont think it does, Your Honor.
THE COURT: Overruled. The answer was, Yes. Next question.
Q. BY MR. MESEREAU: Michael Jackson was frustrated that Frank was bringing guests to
Neverland without him knowing about it, right?
A. That is correct, yes.
Q. And how old was Frank at the time, do you think?
A. Im not sure how old was he. I will say he was about, what, 35.
Q. Early twenties?
A. Somewhere around there, yes.
Q. To your knowledge, how was Frank able to bring guests to the property without Michael
Jackson knowing about it?
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: It was his own decision.
Q. BY MR. MESEREAU: But what would Frank do, if you know, to bring guests onto the
property without Michael Jackson knowing about it?
A. What he would do there?
Q. Yes.
A. Just have fun at Neverland.
Q. Oh, no, excuse me. I didnt state it properly. Its my mistake. If Frank wanted to bring
guests onto the property without Michael Jackson knowing about it, what would he do?
A. He would just call security and tell -- let security know that he had some guests coming

in, or tell me.

Q. Would he typically tell them that Michael wants them visit ing?
A. No, he never said that.
Q. He just said he wanted them to visit, right?
A. That is correct.
Q. Okay. And he would bring a number of female guests from time to time, correct?
A. Correct.
MR. AUCHINCLOSS: Objection; relevance.
THE COURT: Overruled. The answer is,Correct.
Q. BY MR. MESEREAU: In fact, he tried to bring a lot of girls onto the property, didnt
he?
A. That is correct.
Q. He used to brag to them that he was a friend to Michael Jackson, right?
MR. AUCHINCLOSS: Objection. Hearsay; relevance.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Now, you mentioned someone named Malnik visited the property
one time, right?
A. Right.
Q. Did you speak to him?
A. Not in a conversation, no, I didnt.
Q. You just saw him?
A. Just saw him, say hi. And that was it.
Q. The prosecutor mentioned someone named Zia, right?
A. Thats correct. That is correct.
Q. Did you see Zia on the property?
A. Yes, I did.
Q. Did you talk to him?
A. Just for a short time. Not -Q. And Zia was, to your knowledge, Mr. Jacksons attorney, right?
A. Yes.
Q. Did you see him there often?
A. No, I only saw him there a couple times.
Q. And what did you see him doing?
A. Just had a meet ing with Mr. Jackson.
Q. Okay. You would see all kinds of people visit from time to time to meet with Mr.
Jackson, right?
A. Yes.
MR. AUCHINCLOSS: Objection; vague.
MR. MESEREAU: Ill rephrase.
Q. The prosecutor has limited his questions to you to Dieter, Ronald, Frank. Mr. Jackson
didnt spend all of his time meeting with these people, did he?
A. Not all the time, no.
Q. Mr. Jackson from time to time would have nu merous visitors to Neverland to see him,
correct?
A. That is correct.
MR. AUCHINCLOSS: Objection; vague as to time.
THE COURT: Overruled. You may answer.
THE WITNESS: That is correct.

Q. BY MR. MESEREAU: You would often see a full schedule of people visiting Neverland
to see Mr. Jackson, right?
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: That is correct.
Q. BY MR. MESEREAU: Do you recall Mr. Jackson doing work in his studio at Neverland?
A. Yes.
Q. And what do you recall seeing him doing?
A. Doing some recording. Dancing. Pract icing. Yes.
Q. Did you watch him practice dance?
A. No, I didnt.
Q. And how did you know he was practicing dance? Would he tell you?
A. Right.
Q. And would he tell you not to let anyone in, that hes doing his creative work?
MR. AUCHINCLOSS: Objection; hearsay.
THE COURT: Overruled. You may answer.
THE WITNESS: Because of his work, yes, he did not want to be bothered, yes.
Q. BY MR. MESEREAU: Did you also see him teaching kids how to dance from time to
time?
A. I never saw that.
Q. Okay. How about in his recording studio, would he bring kids and adults into his
recording studio to see it?
A. Yes, he did.
Q. And didnt he used to show them how he does his work in his recording studio?
A. Yes.
Q. And sometimes he wanted to just be left alone in there, right?
A. That is correct. Yes.
Q. And when he wanted to be left alone, hed spend hours and hours in there, right? 4748
A. Thats correct, yes.
Q. Okay. Now, you would see Mr. Jackson awake on his property at all d ifferent hours,
right?
A. Yes.
Q. Sometimes he gets up at 3:00 in the morning, doesnt he?
A. That is correct, yes.
Q. And he will take walks alone on his property, right?
A. Thats right.
Q. Thats how he does a lot of his composing, right?
A. That is correct.
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Youd also see Mr. Jackson from time to time driving alone on his
property, right?
A. That is correct, yes.
Q. Would you know in advance if Mr. Jackson was going to leave the property to go
somewhere?
A. Yes.
Q. And who would you -- who would tell you that Mr. Jackson was leaving the property?
A. Sometimes I found out about -- by his bodyguard.

Q. Okay. And what are some of the other ways that you would find out Mr. Jackson might
be either leaving the property or going out of town?
A. By Mr. Jackson.
Q. Okay. Did you speak to Mr. Jackson every day when he was there?
A. Pretty much, yes.
Q. When he wasnt there, who would you speak to?
MR. AUCHINCLOSS: Objection. Ambiguous; relevance.
THE COURT: Overruled.
THE WITNESS: When he wasnt there, well, nobody is -- the ranch manager.
Q. BY MR. MESEREAU: Let me ask you this: When Mr. Jacksons out of town, which you
saw him do quite often during your 20 years there, right?
A. Right.
Q. You saw him go on music tours, right?
A. That is correct.
Q. And you saw him travel to various cities in America, right?
A. Yes.
Q. And he would travel to various cities around the world, right?
A. Yes.
Q. When hes not there, does the place pretty much run the way it runs when hes there?
A. It runs the same way.
Q. And thats because there are various procedures in effect to make sure it runs properly,
correct?
A. That is correct, yes.
Q. When Mr. Jacksons there, hes not walking around the property just running
everything, is he?
A. No, no.
Q. In fact, very often when hes there, you hardly see him, right?
A. That is correct, yes.
Q. Because Mr. Jackson is doing his creative work for hours and hours on end, right?
A. Correct.
Q. So how does the place sort of run when hes not there? I mean, if you can explain it.
A. Because of the people in charge of running the place, so well -- the place always
running the same, so -- whether hes there or not.
Q. And even if hes there, you have to report to other individuals to get information, dont
you?
A. That is correct, yes.
Q. Okay. So when the prosecutor asked you about your reporting directly to Michael
Jackson, you didnt mean youre talking to him all day about whats going on?
A. No.
Q. And if you report to him on a given day, it might be just one time, right?
A. That is correct, yes.
Q. Okay. In response to the prosecutors questions, you mentioned some things about
Frank saying hell take care of things, correct?
A. Correct, yes.
Q. But Frank also used to brag about how close he was to Michael Jackson, didnt he?
A. Right.
Q. You didnt get the impression he was always telling the truth, did you?
MR. AUCHINCLOSS: Objection; calls for a conclusion.

THE COURT: Sustained.

Q. BY MR. MESEREAU: You said, in response to the prosecutors questions, that on
occasion you would see Frank and Michael Jackson together, right?
A. Right.
Q. But you also often saw Frank not around Mr. Jackson, correct?
A. Oh, yes.
Q. And you often saw Mr. Jackson without Frank, right?
A. That is correct, yes.
Q. And you didnt really know what work Frank was doing, correct?
A. That is correct, yes.
Q. But from time to time, he would try and brag that he was in the music business, right?
A. Correct.
MR. AUCHINCLOSS: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: I want to ask you a little more about security at Neverland,
okay? Its about 2800 acres of property, right?
A. Uh-huh.
Q. Very spread out over hills, right?
A. Yes.
Q. And its surrounded by these fences that you said anybody could come in, r ight?
A. That is correct, yes.
Q. You have a front gate that you have to stop at if youre driving in, right?
A. Correct.
Q. And you have to push a button and identify who you are, right?
A. That is correct, yes.
Q. And people at that security gate typically have a list of whos supposed to be allowed
in, right?
A. Right.
Q. And I think what you said is that Frank would often call the people at that gate and
say, Let so and so in, right?
A. That is correct, yes.
Q. Okay. Now, you did indicate there had been efforts by people to drive and get onto the
property and find Mr. Jackson, right?
A. Right.
Q. And you have some security guards who patrol the property a bit, right?
A. Correct.
Q. And they dont have weapons, right?
A. Not to my knowledge.
Q. Because Michael Jackson doesnt want weapons on his property, right?
A. Correct
MR. AUCHINCLOSS: Objection. Foundation; hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know whether or not Mr. Jackson has a policy that he
doesnt want weapons on his property?
A. Yes, I do.
Q. And hes typically very concerned about his childrens safety, correct?
A. That is correct.
Q. You said that Frank was staying in the video library, right?

A. Correct.
Q. And was there a bed in there?
A. Its a couch that turns into a bed, yes.
Q. Is that where he would stay when he visited?
A. Correct.
Q. There were long periods of time Frank wasnt even there, right?
MR. AUCHINCLOSS: Objection as to -- vague as to time.
Q. BY MR. MESEREAU: Lets go to 2003. Ill rephrase it, Your Honor.
THE COURT: All right.
Q. BY MR. MESEREAU: Lets take the year 2003. There were periods of time you
wouldnt even see Frank on the property, right?
A. There was some times, yes.
Q. And there are times you would also see him, correct?
A. Correct. Yes.
Q. There were t imes you would see Dieter on the property, right?
A. Correct.
Q. And there were times you wouldnt see him at all, right?
A. Correct. Yes.
Q. There were t imes youd see Ron on the property, correct?
A. That is correct. Yes.
Q. And there were times you wouldnt see him at all?
A. Right.
Q. And during this period of time, you had your constant visitors on a daily basis to the
property, correct?
A. Yes.
Q. You had many other people who had scheduled meetings with Michael Jackson, right?
A. Right. Yes.
Q. And you also had your periodic tours of children and adults to Neverland, right?
A. That is correct, yes.
Q. You indicated that you think that Mr. Jackson was at Neverland when the Arvizos
visited in 2003, right?
A. Right.
Q. Youre not sure that he was there every day, though, are you?
A. That is right, yes.
Q. If there were days he wasnt there when the Arvizos were there in 2003, youre just
not sure, correct? Thats a bad question. Let me -- I dont think I could answer that one.
In 2003 when the Arvizos were at Neverland, sometimes Michael Jackson was there and
sometimes he wasnt, right?
A. That is correct. There was days that he was not there, yes.
Q. There were t imes he was out of town, right?
A. Right.
Q. There were t imes he was gone from the premises during the day, right?
A. That is correct, yes. 4756
Q. There were t imes he was in his studio, right?
A. That is correct, yes.
Q. There were t imes he was doing his dance routines, correct?
A. Correct.
Q. There were t imes he was taking children around Neverland on a tour, right?

A. Correct, yes.
Q. And there would be constant meetings of one form or another involving Michael
Jackson with other people, correct?
A. That is correct, yes.
Q. Okay. The prosecutor asked you about Michael Jackson playing with kids. Michael
Jackson plays with kids all the time at Neverland, doesnt he?
A. Yes, he does.
Q. He often acts like a kid himself, doesnt he?
A. Yes.
Q. And he takes pride particularly in bringing inner city kids to Neverland to have fun,
doesnt he?
A. Correct. Yes.
Q. Were talking about kids from poverty, kids from broken homes, right?
A. That is correct, yes.
Q. He sometimes personally arranges those visits himself, doesnt he?
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know whether or not Michael Jackson sometimes
personally arranges visits by kids to Neverland?
A. Yes.
Q. And typically when these busloads of kids get to Neverland, they all want to see
Michael Jackson, right?
A. Correct.
Q. And sometimes you schedule all these kids and these adults to be at a certain location
to wait for Michael to come out and see them, right?
A. That is correct.
MR. AUCHINCLOSS: Ill object as cumulative.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Isnt that true?
A. That is correct, yes.
Q. And he would call you and arrange to have toys available for all these kids when they
would vis it, right?
A. Correct.
Q. And you would typically have all the kids assemble on the property, and staff would
start distributing toys to them, right?
A. That is correct, yes.
Q. And very often in the middle of the toy distribution, Michael comes out to see the kids,
right?
A. On some occasion, yes.
Q. And youll see them running to Michael.They want to see him; they want to touch him,
right?
A. Correct.
Q. The adults will do the same, correct?
A. Correct, yes.
Q. Now, the prosecutor asked you what these children do at Neverland, and you talked
about bike riding.
A. Yes.
Q. What did you mean by bike riding?

A. Hes got so many toys, they can just take off on the quad-runners, scooters. Thats
what I meant.
Q. And you never got the impression Michael Jackson was supervising the bike rid ing, did
you?
A. No.
Q. People on the property who worked for Mr. Jackson take care of that, dont they?
A. Especially security, yes.
Q. And also you expect the parents or the adults in charge to have some responsibility,
right?
26 A. Yes.
Q. You talked about quads, okay. And what did you mean by that?
A. They have those four-wheelers that they can go off, off the road. Thats -Q. And they typically ride on the roads at Neverland, right?
A. Yes.
Q. And who supervises that, typically?
A. Oh, themself. Themselves or security.
Q. You have never thought Michael Jackson was walking around supervising who got into
those vehicles, did you?
A. No, no.
Q. He doesnt seem to supervise any of that, does he?
A. No, he doesnt.
Q. Okay. He assumes staff on the premises will, right?
MR. AUCHINCLOSS: Objection. Objection. No foundation, as to what Mr. Jackson
assumes. Calls for speculation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You told the prosecutor that sometimes Michael Jackson would
play with kids on a daily basis, right?
A. That is correct, yes.
Q. And you would see him playing with kids all over the premises, right?
MR. AUCHINCLOSS: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you see Michael Jackson take these kids to the petting zoo?
A. Yes.
Q. Did you see him take them to the bigger zoo?
A. Yes.
Q. Did you see him take them to the arcade?
A. Yes.
Q. Did you see him take them to the theater?
A. Yes.
Q. How about ride with them on the train?
A. Correct.
Q. Okay. This went on all the time, didnt it?
A. That is correct, yes.
Q. Now, the prosecutor asked you questions about Mr. Jackson appearing intoxicated,
okay?
A. Right.
Q. Now, you never saw him drinking, right?
A. No, I didnt.

Q. And were you aware that there were times when he had a prescript ion drug problem?
A. Yes, I -- yes, I was.
Q. And he had gotten a lot of injections from various physicians?
A. That is correct, yes.
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you know Michael 4761 Jackson had -- excuse me, let me
rephrase. Did you know whether or not Mr. Jackson at various times had a prescription
drug problem?
A. Yes, I did.
Q. And did you know he was treated for that?
A. Yes.
Q. When you saw him appearing intoxicated, you dont know what the cause was, correct?
A. That is correct, yes.
Q. You knew he had suffered severe burns on his body, didnt you?
MR. AUCHINCLOSS: Objection. Foundation; relevance.
THE COURT: Foundation; sustained.
Q. BY MR. MESEREAU: Did you know whether or not, during one entertainment event,
Mr. Jackson suffered severe burns all over h is body?
MR. AUCHINCLOSS: Ob -- Ill -THE WITNESS: Yes.
Q. BY MR. MESEREAU: Did you know he was being treated for that?
MR. AUCHINCLOSS: Objection; vague as to time.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you know whether or not Mr. Jackson was being treated by
physicians with medication because hed been badly burned?
MR. AUCHINCLOSS: Objection; vague as to time.
Q. BY MR. MESEREAU: At any time?
A. Yes.
Q. That was common knowledge at Neverland, was it not?
MR. AUCHINCLOSS: Ill object and move to strike the last answer. Still vague as to time.
THE COURT: Stricken.
Q. BY MR. MESEREAU: During the year 2002, were you aware -- excuse me. During the
year 2002, do you know whether or not Michael Jackson was being treated by various
physicians for health problems?
MR. AUCHINCLOSS: Objection. Vague as to health problems.
THE COURT: Overruled. You may answer.
MR. AUCHINCLOSS: Ill object as to foundation.
THE COURT: The answer -- the question calls for a yes or no answer. You may
answer.
THE WITNESS: Yes.
Q. BY MR. MESEREAU: And during the year 2002, were you aware that Mr. Jackson -MR. AUCHINCLOSS: Objection to the form of the question. Were you aware assumes
facts.
THE COURT: You have to let him finish the question.
Q. BY MR. MESEREAU: During the year 2002, were you aware -- excuse me. During the
year 2002, did you know whether or not Mr. Jackson was taking med ications for a broken
leg?

A. Yes.
Q. During the year 2002, did you know whether or not Mr. Jackson was taking
medicat ions for a foot problem?
A. Yes.
Q. And during the year 2002, did you know whether or not Mr. Jackson had recurring
problems because he had been badly burned?
A. Yes.
Q. During the year 2002, did you know whether or not Mr. Jackson had back problems?
A. Yes.
MR. AUCHINCLOSS: Im going to object as to foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: During the year 2003, did you know whether or not Mr. Jackson
was taking prescription drugs for a leg problem?
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know whether or not Mr. Jackson took prescription drugs
in the year 2003 while you were working there?
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Overruled.
THE WITNESS: Yes.
Q. BY MR. MESEREAU: Do you recall seeing Mr. Jacksons children in h is bedroom?
A. Yes.
Q. They would be in there a lot during the time you worked there, right?
A. That is correct, yes.
Q. You would see his children at the lower level, right?
A. Correct.
Q. You would see them in his bedroom upstairs, right?
A. Correct, yes.
Q. Did you typically spend much time with Mr. Jacksons children?
A. I would say I didnt spend too much time with them because -- but saw them, I mean,
every day there, yes.
Q. Every day?
A. Yes.
Q. And you would mainly see them in the main house?
A. Yes.
Q. Would you see them on the property also?
A. Yes.
Q. But you saw them in his room quite often, didnt you?
A. Yes.
Q. Do you know anything about an alarm system that one has to use to get into Mr.
Jacksons bedroom?
MR. AUCHINCLOSS: Objection; vague as to one has to use an alarm system.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes.
Q. BY MR. MESEREAU: And have you set off that alarm from time to time?
A. No, not really.
Q. Have you heard the alarm go off?
A. No.

Q. Okay. Do you know much about that alarm system?

A. I know about it, but I -- you know, not -- didnt get involved in that too much.
Q. Its not something that you would typically handle?
A. No.
Q. Okay. Okay. Have you seen Mr. Jackson entertain adults at his home in the evening?
A. Oh, yes.
Q. He does that quite often, doesnt he?
A. That is correct, yes.
Q. And when he does that, you often see adults drinking alcohol, dont you?
A. Right.
Q. You see staff serving them alcohol, right?
A. Thats correct.
Q. And theyre free to go into the kitchen area and grab alcohol if they want to, typically,
right?
A. That is correct, yes.
Q. Youve also seen them served alcohol in h is bedroom, correct?
A. Correct.
Q. Youve seen adults sitting in the lower level of his bedro om drinking, right?
A. That is correct, yes.
Q. And typically there would be an order placed by someone, and staff will bring alcohol
into his bedroom for that purpose, right?
A. Right.
Q. Okay. Now, the prosecutor asked you about complaints involving kids in the wine
cellar, right?
A. Right.
Q. During the 20 years you worked at Neverland, that area you call the wine cellar was
always a wine cellar, was it not?
A. That is correct, yes.
Q. And this is the area that you said, close by, has an area which has Mr. Jacksons
memorabilia from tours around the world, right?
A. Correct, yes.
Q. And in that area nearby is where you can see his costumes, his gloves, and things of
that sort, right?
A. That is correct, yes.
Q. And typically kids and adults want to go there and see all these costumes from his very
successful music career, right?
A. That is right, yes.
Q. And once in a while, somebody will bring people down to that cellar area so they can
see all that memorabilia, right?
A. Right.
MR. AUCHINCLOSS: Objection. Misstates the evidence that the memorab ilia is in the
cellar area.
MR. MESEREAU: Thats what he testified to, Your Honor.
THE COURT: No, its not. Rephrase your question.
MR. MESEREAU: Yes, sir.
Q. Lets take the area that weve identified as the wine cellar, okay? You got to go down
the stairs to get there, right?
A. Right, yes.

Q. When you get down those stairs, where do you see the wine cellar when you reach the
foot of the stairs?
A. Its on the wall. Placed on the wall.
Q. There are other areas around the wine cellar which have other purposes in the house,
right?
A. Right.
Q. And doesnt one of those areas have costumes, gloves, and memorabilia from Mr.
Jacksons tours?
A. Not specifically in that area.
Q. Well, its not far away, though, right?
A. Its outside there.
Q. But you can certainly -- from time to time, he has stored stuff there, hasnt he?
A. Yes. I would say that, yes.
Q. And sometimes people have gone down to look at that stuff, right?
A. That is correct, yes.
Q. And theres some other areas at Neverland where that stuff is stored as well, right?
A. The main part, yes.
Q. Because theres a ton of stuff.
A. Yes.
Q. From a long, successful career.
A. Yes.
Q. Now, during the 20 years youve been at Neverland, there have been very few
complaints about children being in the wine cellar, right?
A. That is correct.
Q. Youre talking about maybe a couple over a 20-year period, right?
A. That is correct, during my time there, yes.
Q. Mr. Jacksons policy is not to let kids in the wine cellar, right?
A. That is correct, yes.
Q. The prosecutor talked about young boys from Los Olivos, and you identified their
pictures, right?
A. Right.
Q. And youve seen them there with their parents from time to time, havent you?
A. No, not with their parents.
Q. The parents have visited?
A. Yes, yes.
Q. But they also have come from t ime to time on their own, correct?
A. Themself, yes.
Q. And theyve come from time to time when Mr. Jackson wasnt even there, right?
A. That is correct, yes.
Q. And people on the property know them, correct?
A. Correct.
Q. And generally nobody objects to their visit ing Neverland, right?
A. That is correct, yes.
Q. They sometimes come alone and they sometimes come with their parents, right?
A. Yes.
Q. Theyre really neighbors, arent they?
A. Yes.
Q. And once in a while theyve gotten into some trouble there, correct?

A. That is correct, yes.

Q. Theyve been known as mischievous kids, right?
A. Right.
Q. Theyve been caught in various places around Neverland, havent they?
A. That is correct, yes.
Q. Theyve been caught in rooms, true?
A. Correct.
Q. They were caught playing hide-and-seek in the house, werent they?
A. Right, yes.
Q. Now, if you catch kids playing hide-and-seek in the house or getting into trouble,
typically what do you do?
A. Well, you try to explain to them that -- you know, if you caught them doing something
theyre not supposed to be doing, you just let them know that, you know, thats not what
they should be -- you know, that theres some certain things that, you know, theyre
allowed to do, theres things that theyre not allowed to do, so we let them know.
Q. But like -- lets take these kids from Los Olivos that are neighbors who are allowed on
the property, and sometimes their parents arent there. Who kind of watches them when
they come alone?
A. Pretty much nobody. Theyre on their own.
Q. Do people on the property keep an eye on them, or what happens?
A. Well, you know, I would say yes, security, just for safety reasons, yes. Or the staff
personnel if theyre at the amusement park, yes.
Q. If they go into the main house, which they do from time to time, who would be in the
main house typically, who might see them?
A. I would say that will be the maids, the cooks, yes. Or myself.
Q. And if they start going upstairs into the bedrooms, who are they likely to run into?
A. Well, theyll run into the doors. They cant go in.
Q. Besides the doors, who might they see? Will they see the people who are cleaning?
A. Yes, they might run into maids or somebody else from the house staff. Yes.
Q. And how many kids are we talking about?
A. Were talking about the -Q. Three?
A. Three kids, yes.
Q. All right. And how long have they been coming onto the property, to your knowledge?
Excuse me, let me rephrase that. When you were working there, for how long a period of
time do you remember their coming freely on and off the property?
A. They would come in frequently.
Q. Regularly?
A. Yes.
Q. Would it be in the evening, morning, weekends? What would it be?
A. It would be weekends or days, yes.
Q. And how would they get on? Would they go through the main gate?
A. Yes, they did.
Q. And do people in the main gate know them?
A. Yes.
Q. And do they typically just let them walk onto the property?
A. Yes.
Q. Would somebody drive them anywhere?

A. Well, sometimes they drove to the place, so -- yes, they drove their own car.
Q. And how old were these young boys?
A. Young kids; 15, 16.
Q. 15, 16?
A. Yes, yes.
Q. And theyre the ones that got in trouble from time to time?
A. Right.
Q. All right. Would anyone call their parents up typically and say, Your teenaged kids are
in trouble?
A. Not my knowledge.
Q. Okay. Were they ever asked to leave the property, to your knowledge?
A. Not to my knowledge.
Q. Actually, Mr. Jackson didnt want them to get in trouble with their parents, did he?
MR. AUCHINCLOSS: Objection. Calls for speculation; no foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Let me ask you a few more questions about the Arvizos at
Neverland. You saw the Arvizo children roaming freely around Neverland when they
stayed there, correct?
A. Correct.
Q. Theyd use the amusement rides when they chose, correct?
A. That is correct.
Q. Theyd go into the theater when they wanted to, right?
A. Right.
Q. They jumped on the train when they wanted to, right?
A. Correct.
Q. And they would visit the zoo when they chose, right?
A. That is correct, yes.
Q. Did you ever see the mother supervising the children at Neverland?
A. No.
Q. Did you ever see her keeping an eye on the children at Neverland?
A. No.
Q. When you saw them at the zoo, do you recall the mother ever being with them?
A. No.
Q. When you saw the Arvizo children at the amusement park on the rides, did you ever
see the mother with them?
A. No.
MR. AUCHINCLOSS: Objection; cumulat ive.
THE COURT: Overruled.
THE WITNESS: No.
Q. BY MR. MESEREAU: When you saw the Arvizo children on the train, did you ever see
their mother with them?
A. No.
Q. When you saw the Arvizo children in the theater, did you see the mother with them?
A. No.
Q. But you saw the mother eating in the main house, didnt you?
A. That is correct, yes.
Q. And you saw her walking around the property, right?
A. Right.

Q. Would you describe the Arvizo children as mischievous?

A. At some point.
Q. Well, they got in trouble at the amusement park, didnt they?
A. Yes.
Q. Tell the jury what happened.
MR. AUCHINCLOSS: Objection; 403.
THE COURT: The objection is overruled. But were going to take our break, so well start
with that question when we come back.(Recess taken.)
THE COURT: Counsel? Go ahead.
MR. MESEREAU: Thank you, Your Honor.
Q. Just a couple more questions. You mentioned that the Arvizo family returned to
Neverland a number of times in 2003, right?
A. That is correct, yes.
Q. Do you know how they got to Neverland?
A. I believe they did on the limo.
Q. A limo?
A. Yes.
Q. Was it your impression that the Arvizos had access to a limousine service when they
wanted to?
MR AUCHINCLOSS: Objection; foundation.
MR. MESEREAU: I think there is a foundation, Your Honor.
THE COURT: Ill sustain the objection.
Q. BY MR. MESEREAU: You indicated that on at least one occasion you called a limousine
service so the Arvizos could leave Neverland, right?
A. That is correct. Yes.
Q. And you said on the other occasion you took Michaels Rolls Royce and drove them
yourself, right?
A. Correct.
Q. And that was in the midd le of the night when Janet wanted to leave, right?
A. That is correct, yes.
Q. And I believe you said on other occasions when the Arvizos left Neverland, it was your
understanding they always had a limousine, correct?
A. That is correct, yes.
Q. Do you know who would arrange for the limousines to transport the Arvizos?
A. I called them personally.
Q. You would do it personally?
A. Yes.
Q. How many times do you think you personally called a limousine service to transport the
Arvizos?
A. I think it was around three times. Somewhere around there.
Q. Is there a particular limousine service that you would normally call?
A. Its out of Santa Barbara. And its called -- what is it called? Limo Link, I believe.
Q. Okay. Now, you wouldnt discuss with Michael Jackson the fact that you wanted to call
a limousine service, right?
A. No.
Q. You had enough authority to do that if you thought it was the appropriate thing to do,
right?
A. That is correct, yes.

Q. And was it your understanding that from time to time guests of Mr. Jackson would need
a limousine?
A. Correct.
Q. And you would get a call from someone asking for you to arrange for a limousine,
correct?
A. That is correct, yes.
Q. Actually, Mr. Jackson was pretty generous with arranging for limousines to take his
guests off the property, wasnt he?
A. Correct, yes.
Q. Do you recall Janet Arvizo from time to time leaving the premises to go into town?
A. I believe there was only one time.
Q. And did she talk to you about that?
A. Yes, she did.
Q. Was it your understanding she was getting a body wax that day?
A. That is correct, yes.
Q. And was it arranged for a limousine to take her to the body wax place?
A. No, it wasnt.
Q. How did she get to the body wax place?
A. I sent one of the maids with her.
Q. So you arranged for a maid to drive her to the body wax?
A. That, yes.
Q. That was a salon, right?
A. That is correct.
Q. And was that in Los Olivos, if you know?
A. Los Olivos or Solvang, somewhere in there.
Q. Okay. Okay. She was away for quite a while that day, correct?
A. Correct, yes.
Q. Do you recall it being three or four hours?
A. Somewhere around there, yes.
Q. Now, did Janet tell you she wanted to get a body wax at a salon that day?
MR. AUCHINCLOSS: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Why did you arrange for one of the maids to drive Janet Arvizo
off the premises to get a body wax?
MR. AUCHINCLOSS: Objection. Foundation; hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know why one of the maids drove Janet Arvizo off the
premises to get a body wax?
MR. AUCHINCLOSS: Same objection.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Were you in charge of the maid who drove Janet Arvizo off the
premises to get a body wax?
A. Yes, I was.
Q. Did you ask the maid to do that?
A. Yes, I did.
MR. AUCHINCLOSS: Objection; hearsay. THE COURT: Overruled.
Q. BY MR. MESEREAU: Why did you ask the maid to do that?
A. Well, I figured it was a --

MR. AUCHINCLOSS: Objection. Hearsay; foundation.

THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know which car the maid used?
MR. AUCHINCLOSS: Objection; relevance.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Just a couple more questions. Do you recall -- do you recall Mr.
Jackson traveling to Florida during 2003?
A. Yes.
Q. Do you recall Mr. Jackson traveling to Las Vegas during 2003?
A. Yes.
Q. Do you recall him traveling anywhere else, if you can recall? 4780
A. Pretty much, that I can remember was just Florida and Vegas.
Q. Okay. Finally, the prosecutor asked you questions about some beds in the theater.
Remember that?
A. Correct.
Q. Arent those hospital beds for handicapped kids?
A. Yes, they are.
MR. MESEREAU: No further questions.
REDIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. Mr. Salas, those hospital beds in the theater, does Mr. Jackson use those beds
personally?
A. Occasionally, yes, to watch a movie.
Q. Do other kids who were not handicapped use those beds?
A. Yes, they do.
Q. As far as the limousines go, you testified on direct examination that you were told not
to let the Arvizos off the property unless you got approval; is that correct?
A. That is correct, yes.
Q. And you said that you arranged for three limousines -- three times that you arranged
for limousines to transport the Arvizos off the property?
A. That I can remember, yes.
Q. Okay. Was this all -- those three times, were they all in 2003 during that period of time
youve testified about?
A. I believe it was one time in 2002.
Q. Okay. So the other two times that you ordered a limousine service to transport the
Arvizos, did you get permission from somebody at the ranch to let them off the property?
A. Yes, I did.
Q. Who did you get permission from?
A. I got permission from -- it was Frank, yes.
Q. All right. You talked a little bit about a time at the dinner table when you suspected
that Gavin had been drinking. Do you remember -A. Correct.
Q. -- testifying about that? Was Michael Jackson present at the dinner table that night?
A. No, he was not.
Q. Was Frank present at the dinner table that night?
A. Yes, he was.
Q. And did you ultimately determine whether Gavin had been drinking that night?

A. Didnt really specify that, but I -- just by the way he was acting, I knew that he was
drinking.
Q. Was there another time when you saw Gavin when he appeared to be drinking?
A. That was the only time.
Q. And that only time that you saw him drinking, that he appeared to be intoxicated, what
was he doing that made you think that?
A. The way he was acting, just not normal. Just his reactions.
Q. Had you had occasion to see Gavin a number of times before that or after that when he
was acting normal, in your opinion?
A. Ask the question again.
Q. I guess my question is, did you have a good frame of reference for judging whether
Gavin was acting normal or not?
MR. MESEREAU: Objection. Vague; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: That was the only time I saw that I noticed that.
Q. BY MR. AUCHINCLOSS: Okay. So my question was, did you spend enough time
around Gavin to feel as if you could make a call as to whether or not he was acting drunk
or not? Do you understand that question?
A. Yes, I do. I would say yes, I -Q. Okay. And how was he acting that made you think he was -- how was he acting
differently on that evening that made you think he was drunk?
A. Pretty simple. Just when somebodys drunk, I mean, you can tell by the way they look,
their reaction, of the way they look, the way they talk. Just verbal, the way he was
talking.
Q. Was it obvious to you hed been drinking?
A. I would say yes.
Q. And you said Frank was at the table. Who else was at the table that night?
A. I believe it was Vinnie and some of Franks guests, I believe it was. A couple girls,
something like that.
Q. Was Gavins mother around?
A. No, she was not.
Q. Now, as far as where the kids slept -- and maybe Ill back up, because I dont think I
asked this question. What time of day was it that you saw Gavin where you thought hed
been drinking?
A. I would say it was about around nine oclock, nighttime.
Q. Nighttime?
A. Uh-huh.
Q. Was Mr. Jackson on the property at that time?
A. Yes, he was.
Q. When children slept in Mr. Jacksons bedroom, do you know, personally know, where
they slept in the bedroom, as far as where they slept, upstairs or downstairs? Did you see
it?
A. I didnt see exactly who slept on Mr. Jacksons bed, but I know there was kids there
and -- yes.
Q. So you never spent the night in Mr. Jacksons bedroom, I take it?
A. No.
Q. So you dont know where the kids slept after you left the room?
A. No.

Q. But you were in the room at times when kids were there?
A. Right. Yes.
Q. And in terms of these kids, were they all boys that slept in Mr. Jacksons room?
A. Pretty much, yes.
Q. Now, Mr. Mesereau asked you about the first-class treatment that everyone received at
Neverland. And you basically said that the adults got first-class treatment, too?
A. That is correct, yes.
Q. Okay. So did the kids get the same first-class treatment that the adults did?
A. Absolutely.
Q. Were they basically treated just like the adults?
A. Just like the adults.
Q. And these kids, when they were at Neverland during the 20 years you were there, did
these kids ever have supervis ion?
A. Do you mean by -Q. By Neverland. Any organized supervision of these children while they were at
Neverland?
A. We really didnt have supervision. They had security that would keep an eye on the
guests, or even the Neverland staff working at certain places, they had to make sure that
the kids were safe. Not supervising them, but just for safety.
Q. Okay. So if an emp loyee was around and saw something dangerous, they might
intervene; is that fair to say?
A. Of course, yes.
Q. But the employees, they werent running around supervising these kids where they
were?
A. No.
Q. They were allowed to run around wherever they wanted, do whatever they wanted?
A. Absolutely.
MR. MESEREAU: Objection; leading.
THE COURT: Sustained.
MR. AUCHINCLOSS: Some of this is offered as impeachment.
THE COURT: Well, that was leading, so....
MR. AUCHINCLOSS: All right.
Q. Now, as far as the busloads of children go, were these children treated different ly than
the children who were guests at Neverland?
A. No.
Q. Were the busloads of children allowed to spend the night in Michael Jacksons room?
A. None of those kids spent the night in his room.
Q. Okay. Were they given the access code to the house?
A. No.
Q. Okay. Were they allowed to -- were these children, d id they bring their own supervision
with them, adult supervision?
A. Yes, they did.
Q. Was it organized? Were they organized as to where they would go and how they would
spend their time at Neverland?
A. Absolutely, yes.
Q. Was Mr. Jackson even there when those busloads of kids would arrive or be there?
A. Many times he was there. Many times he wasnt there.
Q. Okay. When he was there, would he always come out or sometimes come out?

A. Sometimes come out.

Q. So there were times busloads of kids would arrive and Mr. Jackson wouldnt even come
out to say hi?
A. Yes. There was times that he -MR. MESEREAU: Objection. Leading; misstates the evidence.
THE COURT: Overruled. The answer is, Yes. Next question.
Q. BY MR. AUCHINCLOSS: As far as Janet, when she was -- when she left Neverland the
first time with her family, in the interview with the sheriffs department, didnt you say
that, The whole family, they were not allowed to go nowhere?
A. Yes. Thats what I said, yes.
Q. And that, They had them there always, and they were with supervision?
A. According to what she told me, yes.
Q. Didnt you say Frank Tyson was one of the individuals involved in the handling of the
Arvizo family?
A. Correct.
Q. And did you say that Salas -- did you say that ranch employees were required to go
through Frank Tyson with questions or problems regarding the Arvizo family?
A. That is correct, yes.
Q. Did you also say that Tyson -- that you believed Tyson would then, in turn, go through
Mr. Jackson?
MR. MESEREAU: Objection; leading.
MR. AUCHINCLOSS: This is impeachment.
MR. MESEREAU: No foundation.
THE COURT: The objection is overruled. You may answer.
Q. BY MR. AUCHINCLOSS: Did you say that Tyson would then, in turn, go through Mr.
Jackson?
A. Correct, yes.
Q. Did you say that the Arvizo family was not being allowed to leave the Neverland Ranch
even though the mother wished to leave with her children?
A. Thats correct, yes.
Q. In the grand jury, when you testified, you were asked this question: You were asked
whether or not you believed Janet Arvizo and her family was being kept against their will.
You said, Yes; is that true?
A. Yes.
MR. MESEREAU: Objection. Foundation; leading.
MR. AUCHINCLOSS: Offered as impeachment.
THE COURT: Overruled. He said, Yes.
Q. BY MR. AUCHINCLOSS: And is that a true statement?
THE COURT: He said, Yes.
MR. AUCHINCLOSS: Okay.
Q. You said -- I believe when Mr. Mesereau was up here, you said that Mrs. Arvizo was
never forcib ly kept at Neverland; is that true? 4789
A. That is correct, yes.
Q. So no one ever used physical force on her?
A. No.
Q. You said that when you took her home, that she told you that she was -- you told Mr.
Mesereau that she was upset with the people at Neverland Ranch?
MR. MESEREAU: Objection; misstates the evidence.

Q. BY MR. AUCHINCLOSS: Upset with Ronald -- I believe it was Dieter.

THE COURT: Do you want to rephrase the question?
MR. AUCHINCLOSS: Yeah.
Q. You told Mr. Mesereau that when you were taking Janet and the children home that
first time, that she was upset with Dieter; is that correct?
A. That is correct, yes.
Q. Didnt you also previously state that she said she was upset with Frank as well, or no?
You tell me.
A. No.
Q. Now, you also told Mr. Mesereau that the -- at that time, when she left Neverland
Ranch the first time, she was not angry at Michael Jackson?
A. That is correct, yes.
Q. Okay. After she left Neverland that first time, did you ever talk to her about whether
she was still angry at Michael Jackson?
A. No.
Q. Did you have much contact with her after that first time?
A. No.
Q. Do you have any idea whether she is angry at Michael Jackson today?
A. I have no idea.
Q. You mentioned that you allowed your daughter Sandra to visit Mr. Jackson at
Neverland.
A. That is correct, yes.
Q. When was that?
A. 91, 92, somewhere around there maybe. Maybe later than that. Im not quite sure.
Q. So early 90s?
A. I would say so, yes.
Q. Was it one occasion?
A. I believe it was about three times.
Q. Three times that she personally spent time with Mr. Jackson?
A. Yes.
Q. Were all three of those occasions in 90, 91, in that early -- early 1990s?
A. It was during the same time, yes.
Q. Did you ever allow your daughter to sleep with Mr. Jackson?
A. She never slept over there.
Q. Okay. Would you ever allow your daughter to sleep with Mr. Jackson?
MR. MESEREAU: Objection. Calls for speculation; leading; foundation.
THE COURT: Its argumentative; sustained.
Q. BY MR. AUCHINCLOSS: Knowing what you know today, based upon all your time at
Neverland, do you believe this place is a healthy place, would be a healthy place for your
daughter to visit?
MR. MESEREAU: Objection. Opinion; foundation; relevance.
MR. AUCHINCLOSS: This was offered as an opinion as to -THE COURT: The objection is sustained.
Q. BY MR. AUCHINCLOSS: Is it true to say that the kids do get hurt at Neverland?
MR. MESEREAU: Objection. Relevance; beyond the scope; leading.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Do kids ever get hurt at Neverland?
MR. MESEREAU: Same objection.

THE COURT: Sustained.

MR. AUCHINCLOSS: Counsel asked the question.
MR. MESEREAU: I never asked that question.
MR. AUCHINCLOSS: Talked about safety.
THE COURT: All right. Quit talking to each other.
MR. AUCHINCLOSS: Yes, sir.
Q. You said that some people invade Neverland or come in from the outside, correct?
A. Correct, yes.
Q. How far is Neverland away from the nearest town?
A. Six miles.
Q. How do these people get out there?
MR. MESEREAU: Objection; foundation.
Q. BY MR. AUCHINCLOSS: If you know.
THE COURT: The foundation is sustained.
Q. BY MR. AUCHINCLOSS: Okay. Do you know how these people get out there?
A. Yes, sir.
Q. How do they get out there?
A. Driving.
Q. Okay. So these people who visit -- who try to get into Neverland have a car?
A. Yes.
Q. Where is the car?
A. They park on the outside of the property.
Q. You also said that Janet complained about being separated from Michael, that Dieter
was separating her from Michael. Yes?
A. Yes. That was her expression, yes.
Q. Didnt she say that she was -- didnt she complain that Dieter was separating her from
Michael Jackson and her children? 4793
A. Not exactly what she said. She said that she was being separated from Michael.
Q. Okay. But didnt she reference her children when she was talking about that?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: You say not exactly. What do you mean?
A. She never mentioned the kids.
Q. Did she ever comp lain about being separated from her kids?
A. No, sir.
MR. MESEREAU: Objection; hearsay.
Q. BY MR. AUCHINCLOSS: When Janet was at Neverland -THE COURT: Wait. There was an objection.
MR. AUCHINCLOSS: Im sorry.
MR. MESEREAU: Ill withdraw the objection.
THE COURT: Go ahead, Counsel. (Laughter.)
Q. BY MR. AUCHINCLOSS: When Janet was at Neverland, did she -- well, let me strike
that. Do you know where Janet would spend most of her time while she was at Neverland?
A. She spent most of her time in the guesthouse.
Q. Do you know where she would take her meals? 4794
A. Many times she -- most of the time she took it in the room. There was times that she
went in the kitchen.
Q. When Mr. Mesereau asked you if things kind of run themselves or keep running at

Neverland when Michael is not there, who is it that makes the determination in general
about how Neverland is run as a ranch? Who is it that makes the ultimate call?
A. Okay, for the place would be run, I mean, we have a staff. W e have a ranch manager.
Q. Uh-huh.
A. And thats how we do it. I mean, thats how they used to do it. Just do it together.
Q. Who tells the ranch manager how he wants that place run?
A. On the major decisions, I guess it comes from L.A. also.
Q. Does Michael have anything to do with how he wants that place run?
A. Im not sure if he has something to do with that, but he will tell you what he likes.
Q. When Mr. Jackson is on the property, do the employees act differently?
A. No. They shouldnt.
Q. Theres no difference between when hes on the property or off the property?
A. No, because the place needs to run the sameway whether hes there or not.
Q. But isnt Neverland Ranch run exactly the way Michael Jackson wants it?
MR. MESEREAU: Objection. Leading and asked and answered.
MR. AUCHINCLOSS: Offered as impeachment.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Who is the person who ultimately makes the determination
as to what happens at Neverland?
MR. MESEREAU: Objection. Its been asked and answered a couple of times.
THE COURT: Sustained.
MR. AUCHINCLOSS: Okay.
Q. Let me back off, then, and go to -- okay, so sometimes someone in Los Angeles makes
the decision, right?
A. Uh-huh.
Q. Who tells the person in Los Angeles what they want?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Have you ever seen guns on Neverland Ranch?
A. Not now, okay.
Q. Not now?
A. Before, at the beginning, yes.
Q. There were guns?
A. Yes.
Q. Tell me about it.
A. That was at the beginning when Mr. Jackson bought the place. Security was carrying
guns.
Q. Was there a period of time when guns were not kept -- not -- the security was not
armed?
A. Yes, it came to the point that I guess Mr. Jackson didnt want any guns at the place,
and nobody was carrying any weapons anymore.
Q. Did that ever change again?
A. No.
Q. Was there a time when a few people carried guns at Neverland?
A. Not that I was aware of.
Q. You said that when the Arvizo children were there, that Mr. Jackson was in constant
meet ings. You also said that he was constantly playing with the children.
A. That is correct, yes.

Q. So he was doing both of those things at the same time or -A. Not at the same time. You know, when he was in meet ings, he was in meetings. When
he had some time free, he was playing with kids or he was by himself.
Q. Okay. Who was he having these constant meetings with? Who was there when he was
having these constant meetings?
A. Hard to remember. Many peop le. 4797
Q. Okay. How about -- was Frank Tyson one of them?
A. Not really.
Q. But he did have meet ings with Frank?
MR. MESEREAU: Objection; asked an answered.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: You also said that Mr.Jackson was -- you answered some
questions about him taking prescriptions, prescription medicat ion.
A. Correct.
Q. Do you know the difference between somebody who is drunk and somebody who is
taking some medication?
MR. MESEREAU: Objection; vague.
THE COURT: Overruled.
Q. BY MR. AUCHINCLOSS: Go ahead.
A. No, I guess I dont have a way of describing that.
Q. Well, were there times when you were serving Mr. Jackson alcohol when he appeared
to be drunk?
A. Yes.
Q. And do you know how often Mr. Jackson would have alcohol?
MR. MESEREAU: Objection; vague as to time.
MR. AUCHINCLOSS: Ill be specific.
Q. During this period in early 2003.
A. He was having a regu lar basis.
Q. Daily?
A. I said regular basis.
Q. Could you smell alcohol on him when you saw him during these periods he appeared to
be drunk?
A. No, I never got so close to him to be able to smell.
Q. You said that Mr. Jacksons policy was not to let kids in the wine cellar. Was this a -A. That is correct, yes.
Q. Was that a written policy?
A. That was a policy, yes.
Q. Was that -- was it okay for kids to be in the wine cellar if he was there?
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. You may answer.
THE WITNESS: I believe when he was there, I guess it was okay for the kids, yes.
Q. BY MR. AUCHINCLOSS: Okay. And did you testify that there were times when he was
in the wine cellar with children?
A. Yes.
MR. MESEREAU: Objection; misstates the evidence.
MR. AUCHINCLOSS: Ill rephrase it.
Q. Were there times when he was in the wine cellar with children?
A. Yes.

Q. You have spoken to myself and various members of law enforcement in preparation for
this case.
A. Correct.
Q. Has anyone ever told you to tell anyth ing but the truth?
A. That is correct, nobody did.
Q. Im sorry?
A. No.
MR. AUCHINCLOSS: Okay. Thank you. No further questions.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Just briefly. During the 20 years you worked at Neverland for Mr. Jackson, it was
always his policy that children are not to be in the wine cellar, true?
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: That is correct, yes.
Q. BY MR. MESEREAU: And Mr. Jackson sometimes would give people tours of his own
home, correct?
A. That is correct.
MR. AUCHINCLOSS: Objection; beyond the scope.
THE COURT: Overruled.
Q. BY MR. MESEREAU: And obviously, as the owner of the home, he can take peop le
anywhere he wants in his home, right?
A. Correct.
Q. Now, when you were driving Janet to Los Angeles, she never asked you to call the
police, did she?
A. No.
Q. When you arranged for the limousine to take the Arvizos to Los Angeles, they never
asked you to call the police, did they?
A. No.
Q. In fact, she never asked you to call the police at any t ime, did she?
A. No, she didnt.
MR. MESEREAU: No further questions.
MR. AUCHINCLOSS: Nothing further. THE COURT: All right. Thank you. You may step
down.

JASON FRANCIA EXAMINATION

THE CLERK: Please be seated. State and spell your name for the record.

THE WITNESS: Jason Francia. And spell my last name? F-r-a-n-c-i-a.

THE COURT: Mr. Francia, Im going to ask you to sit back with the bailiff just for a
moment.
THE WITNESS: Okay.
THE COURT: (To the witness) If youll just have a seat while I instruct, please. (To the
jury) Ah, I can see you again. (Laughter.)
THE COURT: Before -- Im going to give you a special instruction now. One of the things I
want to mention before I give you these special instructions, though, is that I know this
daylight savings time is tough on us. I was noticing a few drooping eyelids along here. If
you start, you know, feeling sleepy or something, hold up your hand, and maybe well
stand up and stretch or something. Its really hard during these time changes, and I know
that, so I just want you to know we can help you on that, too. Okay. Im now going to
instruct you on two different types of evidence which you may hear. One relates to a prior
uncharged sexual offenses. And two relates to a prior conduct -- to prior conduct lead ing
to possible uncharged sexual offenses. First, the instruction for the prior sexual offenses:
If you find that the defendant committed a prior sexual offense, you may, but are not
required to infer that the defendant had a disposition to commit sexual offenses. If you
find that the defendant had this disposition, you may, but are not required to infer that he
was likely to commit and did commit the crime or crimes of which he is accused. However,
if you find, by a preponderance of the evid ence, that the defendant committed a prior
sexual offense, that is not sufficient, by itself, to prove beyond a reasonable doubt that he
committed the charged crime. If you determine an inference properly can be drawn from
this evidence, this inference is simply one item for you to consider, along with all other
evid ence, in determining whether the defendant has been proved guilty beyond a
reasonable doubt of the charged crime. Unless you are otherwise instructed, you must not
consider this evidence for any other purpose. Within the meaning of the preceding
instruction, the prosecution has the burden of proving, by a preponderance of the
evid ence, that the defendant committed sexual offenses other than for which he is on
trial. You must not consider this evidence for any purpose unless you find, by a
preponderance of the evidence, that the defendant committed sexual offenses. If you find
other crimes were committed by a preponderance of the evidence, you are nevertheless
cautioned and reminded that before a defendant can be found guilty of any crime charged
in this trial, the evidence of the whole must persuade you beyond a reasonable doubt that
the defendant is guilty of that crime. This is the second part of the evidence: You will hear
evid ence that is being introduced for the purpose of showing conduct of the defendant
leading to possible sexual offenses other than that for which he is on trial. This evidence,
if believed, may not be considered by you to prove that Mr. Jackson is a person of bad
character or that he has a disposition to commit crimes. It may be considered by you only
for the limited purpose to determine if it tends to show a characteristic method, plan or
scheme in the commission of criminal acts similar to the method, plan or scheme used in
the commission of the offense in this case, which would further tend to show the existence
of the intent, which is a necessary element of the crime or a motive for the commission of
the crime charged. For the limited purpose for which you may consider such evidence, you
must weigh it in the same manner as you do all other evidence in this case. You are not
permitted to consider such evidence for any other purpose. Preponderance of the
evid ence means evidence that has more convincing force than that opposed to it. If the
evid ence is so evenly balanced that you are unable to find that the defendant -- that the
evid ence on either side of an issue preponderates, your finding on that issue must be

against the party who had the burden of proving it. You should consider all of the evidence
bearing upon every issue regardless of who produced it. So, we are -- we have two
possible types of evidence that you may hear, starting now. One relates to prior
uncharged sexual offenses. That evidence, if the burden of proof - preponderance of the
evid ence is met - may be used to show a propensity to commit a similar crime. The
second type of evidence that you may hear is evidence that -- of conduct leading up to
possible sexual offenses. And that may not be used to show a propensity to commit a
crime. It can only be used to show the things that I mentioned to you. I wont go through
them again. Complicated, yes. Ill d iscuss it more with you later. Its just an advantage to
have it given to you in advance of hearing the evidence.
MR. ZONEN: Was the witness sworn?
THE COURT: He was sworn. You may proceed.
DIRECT EXAMINATION BY MR. ZONEN:
Q. Mr. Francia, good afternoon. Sir, weve had to tell everybody so far that you need to
stay fairly close to the microphone because its hard to be heard in the far reaches of the
courtroom otherwise. Tell me, how old are you at this time?
A. 24.
Q. Where do you work? What kind of work do you do?
A. I sell auto parts right now. And I run mentoring program for kind of like the probation
department. Probation department refers kids to me, to my organization, and we mentor
them through them not being truants and not committing crimes again.
Q. Lets start with the auto parts, and then we can go to the other ones.
A. Okay.
Q. What do you do in the auto parts store?
A. I literally sell parts. If somebody comes 4806 to me with a car thats broken, and then
they ask for advice, and I just sell them a starter or an alternator, or so on, so forth.
Q. Youve been doing that for about how long?
A. I did this prior, so six -- probably a little less than a year.
Q. Okay. Lets go to the mentoring program. Who do you work for in the mentoring
program?
A. Pete Taylor. Its through a church that I belong to, but yet its still its kind of own
identity. Its Foursquare Youth Programs. Thats the official t itle.
Q. And the nature of the work, by mentoring, what do you mean?
A. Im the lead mentor. And the ultimate goal is, let me see, the probation department
kind of says these kids need to be mentored. They needed to go through three programs.
Sometimes community service or community service, mentoring, or some sort of jobs
program or something else. And Im one of their steps to get off of probation. So what we
try to do is match them up with a mentor, and thats my job, to try to match them up with
mentors. And I take them out the first and third Saturdays of every month and we try -just hang out with them and show them that theres something more to life than crime, or
than ditching, or than partying, or than drugs, or than anything else. Theres more to life.
We show them theres Frisbee golf. Ive showed the guys how to change the oil and
change a tire. My wife is helping. And she shows them how to cook, make purses with the
girls and -Q. Youve been doing this for how long?

A. Ive been doing this, this exact job, for about six months. This type of work for
probably since I was 18.
Q. Okay. When you were 18, did you start some kind of an internship program dealing
with this?
A. Yeah, I have started an internship with Santa Maria Foursquare Church. W as -- and
was pretty much training to be -- to work with junior high, to high school, to college-aged
people. And I just -- I -- I wanted to be trained in that, because I have a passion for that,
so I started that. I did that for about two and a half years with Santa Maria Foursquare
Church.
Q. Did you ever work as a youth pastor?
A. Yeah. I did that in 2003 to 2004, from my understanding. I cant really remember right
now. Im kind of nervous, just to let you guys know.
Q. Thats okay. W hat is a youth pastor?
A. Well, I was a youth pastor. That was, I guess, my official title. But I worked with 13year-olds to 25- or 26-year-olds. And pretty much -- its kind of like its own little church
4808 within a church. And you work with junior high and high schoolers. And then what I
try to do is address the collegers in a d ifferent format. And then Ive had the college
students help me with the junior highers and high schoolers. So just talk about ethics,
God, morals, and doing good.
Q. Youve been doing htis consistently since age 18?
A. Yeah, pretty much.
Q. Tell us which church this is again, please.
A. The one I was a youth pastor, I did that through Oceano Foursquare. It was really
known as Kings Way a long time ago. But pretty much Oceano Foursquare.
Q. Mr. Francia, youve been living in the Santa Maria area for how long?
A. In the Santa Maria area -- let me see. We moved up here in 88. Then I moved away
when I graduated high school for like four months. And Im still living here now.
Q. All right. You say we moved up here in 88. W ho moved in 88?
A. My mom and I. It was just me and my mom.
Q. Based on what you tell us is your age, can I assume you were born in 1980?
A. Yes.
Q. Okay. What type of work did your mother do when you moved up here?
A. She was working for Michael Jackson.
Q. All right. Is Michael Jackson in this courtroom today?
A. Yes.
Q. And could you -A. Hes right there.
Q. By telling us what hes -A. Hes the light-complected gentleman.
MR. ZONEN: Thank you. Could the record so reflect, Your Honor?
THE COURT: Yes.
Q. BY MR. ZONEN: What type of work did your mother do for Michael Jackson?
A. She was a personal maid. At first she was just a maid. And from my understanding, my
moms just a hard worker and she moved up.
Q. Was she his maid prior to moving up here to Santa Maria?
A. I dont know if she was his full-on, like, personal maid and -- but she was, yeah. Yeah,
she was his maid.
Q. From what period of time in Los Angeles was she working for Michael Jackson?

A. I think 86. But my mom tells me 85. I have no -- its around 86, 85. I dont know.
Q. When did you first meet Mr. Jackson?
A. I was probably six. I think. S ix or seven. And the reason I say that is just it was a long
time 4810 ago.
Q. Did you ever have occasion to go to his residence in Los Angeles?
A. Yeah, the one in Encino, yeah. I went there probably a lot, like 10, 11, 12 times. I
donto know. Often my mom -- it was just me and my mom, so a single mo m and just
me. She needed to babysit me pretty much, so we had nobody else; no dad, no brothers
and sisters.
Q. Your father wasnt in the picture?
A. Correct.
Q. And there was no other kids; is that correct?
A. That is correct.
Q. During the time that you were living in Los Angeles before moving up to Santa Maria,
from the time your mother began working for Mr. Jackson, tell us approximately how often
you went to his residence.
A. Im sorry, can you repeat that?
Q. Tell us approximately how often you went to his residence.
A. Throughout my whole life of my -Q. While living in Los Angeles.
A. Oh.
Q. Before moving to Santa Maria.
A. I went to Encino. He owned a lot of stuff. But I -- theres an Encino, which is like the
big mansion, and then theres the, like, apartment hideaway thing. I think I went to
Encino, which is the big mansion, I dont know, about six, seven times.
Q. Did other members of the Jackson family res ide at that location as well?
A. Yeah. Yeah.
Q. Can you tell us who lived there?
A. Mom and dad, I know that. I think they lived above the garages. I think. Thats where I
met them.
Q. Okay.
A. I think Janet lived there as well. By -- I dont know. Other than that, thats all I
remember.
Q. Were talking about almost 20 years ago; is that correct?
A. Correct. Yeah. That -- yeah.
Q. Did you go to a different location where Michael Jackson lived in the Los Angeles area
as well?
A. Yeah. In the Los Angeles area, yeah, like Ho llywood.
Q. And can you describe that place for us?
A. Yeah. It was -- it didnt have much furniture. It was probably the tenth floor, because
you could look over pretty much a lot of Hollywood and Beverly Hills. I think it was
Beverly Hills. Didnt have a lot of furniture. Had a train set. Had a couple toys, telescope.
Kitchen. But just not a lot of furniture. It was like a condo pretty much.
Q. And the reason that you would go to that location?
A. My mom had to clean everything. My mom was just a clean lady.
Q. Was she the only person cleaning his residence, as far as you knew?
A. No, there was other maids. But from my understanding, just my mom did a kickin job.
She just did a really good job at cleaning, a really good job at working just as a whole.

She was just a good worker.

Q. And there was nowhere to leave you when she went off to clean?
A. Yeah. Sometimes she may -- she would leave me with my aunt, but my aunt had to go
to work as well. Everybody in my family was workers.
Q. Okay.
A. And even -- even -- shoot, even I helped my aunt at times.
Q. Now, on the occasions when you would go to the -- what was it called? The hideout or
hideaway?
A. Yeah, my mom called it the hideout.
Q. Do you know why?
A. Probably because nobody knew about it. I dont think it was registered.
MR. MESEREAU: Calls for speculation.
MR. ZONEN: Withdraw the question.
Q. Did Mr. Jackson ever mention the name of that place to you in any of his conversations
to you?
A. I dont remember.
Q. All right. Was that something you enjoyed doing, going to either of those two places?
A. The mansion I did, just because of the arcade. I was young. It was fun. There was toys.
Q. Tell us about the arcade at the mansion.
A. Shoot. It had an old karate game. It just had a lot of video games in there, and it was
fun for kids. It was -- I think he even had a laser tag set. I dont remember. But he had a
lot of stuff, a lot of toys.
Q. There was a lot that you could do while you were there?
A. At the mansion, yeah.
Q. And you enjoyed doing that?
A. Yeah.
MR. MESEREAU: Objection; leading.
THE WITNESS: Im sorry?
THE COURT: Overruled. Go ahead. Next question.
THE WITNESS: Okay.
Q. BY MR. ZONEN: At the other place, the place in Los Angeles, the hideaway, was that
something you enjoyed doing?
A. Yes and no. There wasnt that many toys. My mom wouldnt let me go out anywhere
else, and there wasnt that many toys. It was a condo, so its not like I could play with the
elevator all day long. There was not that many toys. There was just a train set. A train set
gets boring. It just goes around in circles. And there wasnt that many toys.
Q. Did you ever spend the night at either of those two locations?
A. Encino -- the mansion I didnt, which is in Encino. And the hideaway we did, I believe,
with my mom.
Q. All right. Do you know approximately how many occasions?
A. I dont recall. I dont rememb er.
Q. Were there beds or furniture there?
A. I dont believe so. I think there was an L-shaped couch like one of those that you put in
a corner. There was a chair. I know that, because -- stuff. There wasnt that much
furniture.
Q. How old were you when you moved to Santa Maria?
A. 88 or 89. Eight years old. Yeah. Because I stopped playing baseball. Played baseball
for a little.

Q. When you moved to the Santa Maria area, what job did your mother have?
A. She was -- I believe her title, from what she told me, was Michael Jacksons personal
maid, and she had, like, all the keys. She was the best maid he had, I guess.
Q. Did you ever go to Neverland?
A. Yeah. Yeah, I did.
Q. Tell us approximately how old you were during that period of time.
A. I think when it first opened, it was just -- I went there. They probably had a party
there. How old was I? Probably around nine. Eight.
Q. Approximately how many times do you think you went to Neverland?
A. Five, four. Five or four.
Q. Always with your mother?
A. Yeah. There was no other way to get up there, yeah.
Q. Did you ever spend the night at Neverland?
A. Yes. With -- yeah, I remember d istinctly, because I think I was hearing bats or
something, on the ranch, or something, and I couldnt sleep, so -- but I was sleeping with
my mo m, like in the same room, in the same area with my mo m, and, yeah. I couldnt
sleep.
Q. Were you ever in Michael Jacksons bedroom?
A. Yes.
Q. On how many occasions?
A. Two, I think. Two. Im pretty sure. Once -- one I know for sure, because we were all
laying in the bed watching T.V.
Q. And who is we were all?
A. Michael and a bunch of other kids.
Q. Okay. Do you know how many?
A. I dont. Seven. Six. But I dont -- I dont.
Q. Do you know any of the names?
A. Im really bad at names. Even to this day. I called you Mark earlier.
Q. Thats not me.
A. Yeah, I know.
Q. Do you know how old you were when your mother stopped her employment at
Neverland?
A. Im thinking 11, because I was -- I remember hearing about -- I was playing in the
pool, and she told me, I quit.
Q. You were playing in the pool where?
A. At a friends house, and when I was 11, I was friends with him.
Q. Id like to go back to, if I could, p lease, the period of time in Los Angeles prior to
moving up to Santa Maria. Was there ever an occas ion that you were with Michael Jackson
where something happened that made you feel uncomfortable?
A. Yes.
Q. Did that happen more than once?
A. Yeah.
Q. Do you have a recollection of these events?
A. Yeah.
Q. Lets begin with the first one. What happened?
A. Okay. Well, the first time that I felt uncomfortable with him was in the hideout, which is
the place in Encino -- not in Encino, Im sorry. In Hollywood. And -- shoot. I was seven
and -- I dont know, at seven years old, I dont think -- okay. I may have not felt

uncomfortable, but then now I think about it, that shouldnt have been done. But I didnt
feel unco mfortable.
Q. What happened?
A. I was sitting on his lap, and I was young, and I was small. Im still thin. I was even
thinner then. Sitting on his lap, watching T.V., which thats normal enough in itself. And
then we -- I was kind of facing the T.V., and he was facing the T.V. as well, so my back
was to his chest. And it was -- there was just one chair, and there wasnt much furniture
in that hideout place. And I was just sitting there watching T.V., and so was he. I think we
were watching cartoons. And he just started tickling me, which, cool, shoot, I was a tickle
guy. I tickled him back, but still kind of from the back, kind of reaching around. And then
we went to the floor, I think, but 4818 I cant completely remember right now. But we
somehow got on the floor, tickling still, because Im doing what -- these little kid things,
you know, when you shimmy back and forth. And then Im tickling and hes tickling, and
Im t ickling and hes tickling, and it eventually moved down to -- to -- to my little private
region when youre a little kid. I dont know if you want me to call it specifically
something, but around my crotch area. And I didnt -- you know, youre seven. I didnt
think it was wrong. Well, I d id. Because hes tickling, but Im laugh ing, and Im t ickling
him back, trying to get him to stop, but then Im tickling too much. Im laughing too
much. And eventually it stopped. I dont know how.
Q. Did he actually make contact with your genital area?
A. Not skin to skin, but, yeah. Yeah, he was on my clothes, yeah.
Q. Do you know for approximately how long?
A. Distinctly I cant remember. It was a while, though.
Q. By a little while, can you give us a sense of it?
A. More than three minutes, less than 20. Less than ten minutes, I think.
Q. Okay.
A. But a while. It was -- it was tickling. It didnt end soon. It didnt end fast.
Q. But the amount of time that his hand was actually in the region of your genitalia?
A. I cannot remember.
Q. Okay. And you commented that this was not skin to skin touching; in other words, his
hand directly on either your penis or testicles. Is that -MR. MESEREAU: Objection; asked and answered.
THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: That it was not directly on your genitalia; is that correct?
A. Correct. It wasnt -- he didnt touch me. He was touching on top of the skin, but -- but
not -- on top of my shorts, but still -Q. Do you remember what you were wearing at the time?
A. Probably shorts. I dont remember specifically. I think those orange shorts that my
mom made me, because, again, we were poor, but my mom made me clothes. And I was
always wearing shorts, always wearing shorts.
Q. And she had orange shorts that she had made for you?
A. Yeah, there was orange shorts that she made for me. And then she -- yeah. Q. Were
they shorts you wore a lot?
A. Probably, yeah. Because -- yeah.
Q. Did -- as you think back now, today, of course were talking about quite some number
of years ago, do you remember how you felt at the time this happened, if that was at all
strange for you?
A. You know, I dont. It was -- I dont remember. At seven, it probably -- well, I probably

did think it was weird, but not super weird. Just because youre tickling, and its -- but I
guess that would be weird. My fault.
Q. Was there another instance?
A. Yeah.
Q. Was that also at the hideout?
A. Yeah.
Q. Tell us what happened, please.
A. I was watching cartoons again, and probably in the same room, because I think there
was only one room in that whole place. And we somehow -- I was somehow -- there was a
sleeping bag involved. I dont know -- I think I was on top of it. And I was watching T.V.,
laying down on the ground, and Michael was pretty much behind me, like spooning me. I
dont know how we got there. I was like eight, eight and a half. It was a little while after.
And again with the tickling. But this time it wasnt as long, and I was -- well, Im sorry. It
was longer, but I wasnt laughing as much, I guess.
Q. You were in a sleeping bag, or on a sleeping bag?
A. On, I think.
Q. Okay.
A. On, not in.
Q. All right. Do you remember -- you said this was in the hideout?
A. Yes.
Q. Were there a number of rooms in the hideout?
A. I think there was only one, I think. Yeah. I think there was only one, if I could -- hold
on. Let me -- there was a rest room. There was a kitchen. There was a big main room.
And there was a room off to the left, if youre looking out the window. Yeah, I think there
was only one.
Q. All right. Where was your mother during this time?
A. Probably cleaning. She was always cleaning.
Q. But -A. To this day she cleans.
Q. Do you know in what room at that point?
A. No, I dont. I dont know.
Q. Was she in the room with you at the time?
A. No, she wasnt, or else she probably would have kicked my butt or something.
Q. In the private -- in the prior event that you described, was your mother in the room at
that time?
A. No, she wasnt in the room.
Q. But if you were at the hideout, then she was there; is that a correct statement?
A. Correct. Or sometimes she may have run down to get something to eat. Remembering
now, there was a couple times that Michael actually asked her to get chips, or get
something, or get something from downstairs, or maybe even from the lobby. Thats what
Im thinking.
Q. What was downstairs? Was that a -A. I think there was probably like a restaurant or something downstairs, but I dont really
-- I have no clue.
Q. But the apartment that youre describing is a single floor? Theres no upstairs or
downstairs to it?
A. Oh, yeah.
Q. And this is a large building in Los Angeles?

A. Yeah.
Q. All right. When do you think was the last time that you had been to that building?
A. When was the last time I was there?
Q. Yeah.
A. Im thinking nine, eight.
Q. Age eight or age nine?
A. Yeah.
Q. Even after you moved up to Santa Maria?
A. I believe so. Just because my mom had no one to leave me up in Santa Maria with. We
-- new town.
Q. Let me go back to the second event. In the second event were talking about, you were
in a sleeping bag?
A. Yes.
Q. Was there a bed in that room?
A. No.
Q. Was that Mr. Jacksons bedroom; do you know?
A. I dont know.
Q. Was there a television in that room?
A. Yes.
Q. Was there more than one T.V. in that apartment, to your knowledge?
A. I dont think so.
Q. Were you watching television at that time?
A. Yeah.
Q. Do you remember if it was late at night or midday? Do you have any way of knowing?
A. It may have been midday, but I dont know.
Q. Can you describe the build ing for us in general, in terms of how it was laid out?
A. Almost like a typical apartment or a condo. You walk in the front door, theres a big
living room. Theres -- theres a telescope in there. Theres a bunch of toys. Theres a
couch. And then theres the kitchen.
Q. Okay. The room that has the couch, is that the room where the sleeping bag was?
A. No, the room that has the couch didnt have any furniture but the chair, I think. Im
pretty sure.
Q. And now the sleeping bag itself, on the floor?
A. Yes.
Q. Was it a normal-sized sleep ing bag?
A. I believe so. I would think so.
Q. You used the expression spooning. W hat does that mean?
A. Something that you do with your wife. Something that you do with a girlfriend.
Spooning. Like -Q. Describe the position for us, if you would.
A. Wow. When somebody is holding you and youre laying on your side and theyre
holding you from behind.
Q. Okay.
A. Thanks.
Q. Was that the position that you were in with Mr. Jackson?
A. Yeah.
Q. Were you in front or behind?
A. I was in front.

Q. Do you remember where his arms were?

A. I couldnt specifically tell you.
Q. Was the tickling done again?
A. Yeah.
Q. Was this something that you and Mr. Jackson did frequently, tickling?
A. Whenever something happened.
Q. Okay. On this occasion, when he was tickling you, what happened?
A. We were tickling -- oh, he was tickling me at first, and I was just watching T.V.
Probably cartoons again. And he was just tickling me from behind, and in my genital area.
And I was laughing, and I was trying to tickle him b ack. And -- go ahead.
Q. His hands made contact with your genitalia?
A. From the top of the clothes.
Q. Do you remember what you were wearing on that occasion?
A. Probably shorts again.
Q. Simp ly because you do?
A. Simply because its hot in L.A., yeah, and I always wore shorts. I think every picture I
have -- well, not every, but there was a lot of pictures of me wearing shorts when I was
younger.
Q. Are you mindful of his hand reaching your crotch at the time; you were thinking about
that at the time?
MR. MESEREAU: Objection; leading.
THE WITNESS: I dont even know what he asked me.
THE COURT: Just a moment.
THE WITNESS: I dont understand, yeah.
MR. ZONEN: Thank you.
Q. Was it -- were you aware of it happening while it was happening?
A. Yes.
Q. Okay.
A. Yes.
Q. And how long was his hand there?
A. Two cartoons worth. A cartoon and a half worth.
Q. And you were watching cartoons on televis ion at the time?
A. Yeah.
Q. How long is a cartoon? Its been a while since Ive seen one.
A. Its been a while for me, too. Does anybody here watch cartoons?
Q. Tell us the best of your recollection. We cant let them be witnesses at the moment.
A. A Woody Woodpecker I guess would last four, five minutes.
Q. Okay.
A. Five, six minutes.
Q. So the contact in the area of your genitalia was at least four or five minutes?
A. Yeah.
Q. Did it feel strange to you at the time?
A. Yes and no. No because -- no because its all fun, and its supposed to be innocent,
and youre a little kid, and youre having fun, and -- youre a little kid.
Q. Okay.
A. And yes its not right.
Q. Did Mr. Jackson ever g ive you money?
A. Yeah.

Q. On how many occasions did he give you money?

A. Pretty much at every tickle thing there was money.
Q. Explain that, what you mean by that, at every tickle thing there was money. Explain
what you mean, please.
A. Every time I was being tickled, there was always some sort of money exchanged. Not
exchanged. There was money given. It was just that.
Q. Before, after, during?
A. After. And it was kind of a, Dont tell your mom, about the money.
Q. Well, what would he give you?
A. A hundred-dollar b ill.
Q. A hundred-dollar bill?
A. Yeah.
Q. Did he do this on more than one occasion?
A. Yeah, because I had a lot of money. Well, I didnt have a lot of money. My mom took
the money, because she would find out that I got hundred-dollar b ills, and then shed get
mad at me for taking some strangers -- well, not strangers, but somebodys money.
Q. Do you remember if, in fact, you got the money on both of those two occasions?
A. Yeah. Yeah, I did.
Q. Were there ever any other occasions, whether in Los Angeles or any other occasion or
any other location where something happened that made you feel uncomfortable?
A. Yeah.
Q. And where was that?
A. At the ranch.
Q. Do you remember how old you were?
A. Ten and a half, ten. I was older.
Q. And you have a recollection of this event?
A. Yeah.
Q. Theres water there also, if you need anything.
A. Oh, I was wondering. I thought it was coffee. I was hoping it wasnt.
Q. No, its water. And feel free to take some if you need some.
A. Okay.
Q. You think you were about ten or ten and a half?
A. Yeah.
Q. It was prior to the time that your mother quit her job there?
A. Yeah.
Q. Did you ever go back to Neverland after your mother quit her job there?
A. No.
Q. Do you remember where this event took place, where at Neverland?
A. What, the event?
Q. That made you feel unco mfortable.
A. Yeah. It was in the arcade room. There was a loft area.
Q. Describe what the arcade is.
A. A place where theres a bunch of video games, and there was a pool table, and I think
there was a fireplace. I think that was up in the loft. I think. That was a long time ago.
But, yeah, its Street Fighter, the original one, in there, and pool tables, and a couple of
other video games.
Q. On what part of the arcade were you at the time this happened?
A. I was in the loft.

Q. Upstairs?
A. Yeah.
Q. Was anybody else up there with you?
A. No.
Q. Was Mr. Jackson there?
A. Yeah.
Q. By other people, I mean other people than you and Mr. Jackson.
A. It was just him and I.
Q. Do you recall approximately what time of day or evening it was?
A. No. Nighttime.
Q. Was your mother working that day?
A. Yes.
Q. Were there ever occasions when you were at Neverland and your mother wasnt
working?
A. Yeah, when wed have parties and stuff, but I think shed still work, because shed
always walk around cleaning even though she wasnt dressed for it.
Q. Were there ever occasions when you were at Neverland and your mother was not
there?
A. No, she was always there.
Q. On this occasion, was your mother in the arcade?
A. No.
Q. Was she working that day?
A. Probably.
Q. Do you remember where her assignment would have taken her? Did she go to specific
locations?
A. In the ranch?
Q. Yes.
A. At the ranch area. She was cleaning everything. Q. Okay.
A. She wasnt in the arcade.
Q. Okay. And what happened when you were in the arcade.
A. In the loft?
Q. Yes, please.
A. I think I was playing Sega Genesis.
Q. Tell us what that is, please.
A. Its -- its a video game. I was just a video-game-playing kid.
Q. Okay.
A. There was a video game. There was a T.V. up there, I believe. It was a really big T.V.,
and I was playing, and then he started tickling me, and I think there was -- there was a
couch up there, because we somehow managed to end up on the couch. It took a lot of
counseling to get over, just to let you know.
MR. MESEREAU: Objection. Move to strike; nonresponsive.
THE WITNESS: Im sorry.
Q. BY MR. ZONEN: Lets see if we can restrict our answers just to the questions, if we
can. Ill ask you some questions about that later. You were on the couch. Do you know if
both of you were sitting on the couch?
A. Hold on. We were laying down on the couch. 4832
Q. Okay. How were you laying down? How were you positioned relative to Mr. Jackson?
A. Probably about -- no, it was in the spooning position again.

Q. Okay. Was he behind you or in front of you?

A. Behind me.
Q. And then what happened?
A. We were tickling -- well, he was tickling and I was laughing. And -- and -- and we -- it
was -- he was -- he was tickling me in the.... So much happening right now. Can we take
a break or something?
MR. ZONEN: Can we take just a moment, Your Honor?
THE COURT: Okay. Sure.
MR. ZONEN: Just a break for a moment or two?
Q. Okay.
A. All right.
Q. You were on the couch, and you said in the spooning position?
A. Yeah.
Q. Tell us what happened, please, the best you can.
A. He was tickling me. And then I was wearing shorts again, Im pretty sure, and, yeah,
because he had to have reached under. We were tickling; I was laughing. He reached on
my leg, and Im still laughing, and hes tickling. And then he reached up and -- and to my
privates, yeah.
Q. Did he actually touch your -A. Yeah.
Q. Touch you?
A. Yeah.
Q. Did he touch your penis or your testicles?
A. I think option two, yeah.
Q. Your testicles?
A. Yeah, that one.
Q. For what period of time?
A. I dont remember. Three minutes, two minutes.
Q. Was it tickling?
A. Probably, because I think I was still laughing. But, you know, it may have been the
other hand.
Q. Were you mindful of it at the time? Were you aware at the time he was doing it?
A. Yes.
Q. What were you thinking at the time? Youre now ten and a half years old. What were
you thinking?
A. I should probably go.
Q. How did it end; do you know?
A. Either my mo m -- I dont -- I dont remember how it ended.
Q. Do you have a sense of it?
A. Huh-uh.
Q. Do you remember getting up?
A. No.
Q. Did you think about it afterward?
A. Yeah. No, well, not instantly right afterwards. Youre ten. You dont want to think about
that stuff.
Q. Was Mr. Jackson still giving you money at that time?
A. That time I d idnt get any money.
Q. Did you tell anybody about that right afterward?

A. No.
Q. Did you tell your mother, ever?
A. No. I dont even think to this day she knows.
Q. All right. At some point in time this became known to somebody; is that right?
A. Yeah.
Q. Who did you tell? Who was the first person you told about it?
A. Probably God. But -Q. Lets go to number two, then. Who was the second person?
MR. MESEREAU: Move to strike that comment, Your Honor. Nonresponsive.
THE COURT: Well, its responsive. Overruled. Go ahead.
Q. BY MR. ZONEN: Who else did you -A. Who did I tell? I forgot their names, but there was two detectives. Yeah, I told those
two guys. Q. Before or after your mother had quit her position at Neverland?
A. She had already quit.
Q. All right. At some point in time police came to you and said they wanted to talk to you;
is that right?
MR. MESEREAU: Objection; leading.
THE WITNESS: This is going to be hard for me to get through. Sorry.
THE COURT: Okay. The objection is overruled. You may answer.
Q. BY MR. ZONEN: Go ahead.
A. Yeah, they wanted to come and talk to me. I was 13. I was in eighth grade, I think.
Yeah. I -- yeah.
Q. Around 1993?
A. Yeah. It was 93, I think, yeah.
Q. Did you know in advance that they wanted to speak with you?
A. No. Not until the big day that this crappiness started.
Q. Okay. At some point in time, they showed up?
A. Yeah. They showed up probably around 4:00, because I had judo practice at, like,
6:00.
Q. So it was about -- Im sorry, you had judo practice afterward?
A. Yeah, I had to go to judo practice right after, and I dont think I went because I was
crying.
Q. So you think it was about four oclock in the afternoon?
A. I think they came around four oclock.
Q. Do you remember how many people came?
A. I think two. But I dont remember.
Q. Was your mother present during the course of that interview?
A. No.
Q. Do you know if that interview was tape-recorded?
A. Yeah, it was tape-recorded because I listened to the tapes.
Q. You listened to it recently?
A. Yeah.
Q. Do you know if a transcription had ever been prepared of that interview?
A. A trans -- yeah, it has been.
Q. And did you, in fact, review that transcription as well?
A. Yeah. W hile I was reading it, yeah.
Q. The people who were present during the 4837 course of that interview, you and how
many detectives?

A. Two. Two detectives. Me and two other guys.

Q. They were both men?
A. Yeah.
Q. Had you ever -- did you know them prior to that time?
A. No. No.
Q. Have you seen either one of them since?
A. Yeah, I just bumped into one outside. We were talking a while. I was wait ing for -- to
be called up here.
Q. Okay. Just today, right before you testified you saw one of them?
A. Yeah.
Q. Did you recognize him?
A. No, I didnt. He said, You probably dont remember me. And I said, No. And he told
me who he was. And then I was like, Hey, that was you.
Q. Do you know where they were from, the agency?
A. The police?
Q. Yes.
A. No.
Q. At the time that you were having that conversation?
A. No.
Q. I dont mean now, but at the time you had the conversation with them.
A. No, I just knew they were police officers.
Q. Did you know they were tape-recording it at the time?
A. Yeah, because he showed me and -- he showed me the tape-recording. And the taperecorder was sitting right in front.
Q. Did you know what it was all about at the time you sat down at the table with them?
A. I knew it was about Michael Jackson just because it was on T.V. all the time, and -yeah.
Q. So there was already something going on in the news; is that correct?
A. Yeah.
Q. Okay. Did your mother know that you were entering an interview with them?
A. Yes. She had to have let me go.
Q. All right.
A. My mom knew where I was at all times.
Q. Do you remember where you were for this interview?
A. Yeah. At the juvenile hall, or the sheriffs department.
Q. So it was over in the -- in where, in Santa Maria?
A. Yeah, in Santa Maria. Well, in Orcutt, but -- yeah, in the sheriffs department.
Q. Do you recall how long that conversation was?
A. I dont recall. An hour, hour and a half.
Q. All right. And thats consistent with your having reviewed that tape-recording as well?
A. Right. Right.
Q. And your mother did know that you were going to be there; is that right?
A. Yes.
Q. Was she at the building at the time you were there?
A. I dont think so. I think she was in our little studio apartment still.
Q. Okay. In the course of that interview, did you discuss with them what had happened to
you?
A. Let me drink some water.

Q. Go ahead.
A. Pump?
Q. Its confusing. Theres a button on the top.
A. Im not a coffee drinker, sorry. Its a coffee thing, I think. Im sorry. What was the
question again?
Q. Did you discuss with the detectives what had happened to you with Mr. Jackson?
A. Yes. Eventually. But at first I didnt want to. I was fighting it with everything that I
could.
Q. Why?
A. Because its embarrassing. Its embarrassing now, and Im 24 years old.
Q. Okay. Was it harder then, at age 13?
A. Yeah.
MR. MESEREAU: Objection. Relevance; move to strike; lead ing.
THE COURT: Sustained; stricken.
Q. BY MR. ZONEN: Ult imately -A. It was difficult for me.
Q. -- did you disclose to them the information that you gave us today?
A. Yes.
Q. At some point in time, did you have an interview or were you represented by a private
lawyer?
A. At some point, yeah, in time I was.
Q. Do you remember the name of that lawyer?
A. Yeah, Terry -- Terry Cannon. And Kris Kallman.
Q. There were two lawyers who represented you?
A. Yeah.
Q. Do you know if -- was this after this interview?
A. Yes, it was after this interview. It was like two months after this interview, I think.
Q. Were you ever called for a deposition?
A. I was never called for a deposition.
Q. Did you ever know a young man by the name of Jordan Chandler, or Jordie Chandler?
MR. MESEREAU: Objection; relevance.
THE WITNESS: Did I -MR. MESEREAU: Relevance; foundation; move to strike.
THE COURT: Overruled. You may answer.
THE WITNESS: Did I ever meet him?
Q. BY MR. ZONEN: Yes.
A. I probably did, but I -- I dont remember n ames. Im really bad with names. And Im
not -Q. Do you know if you were being prepared at any time to give a deposition in a case
involving Mr. Chandler?
A. No. What -- prepared by -- I dont know what you mean by prepared.
Q. Did your attorneys ever talk to you about the possibility of your going in and giving a
deposition?
A. No. I dont think so. I dont remember.
Q. At some point in time, was there a settlement of some kind of a case invo lving you and
Mr. Jackson? Were not going to get into the specifics of the amounts, but was there a
settlement?
A. Yes.

Q. Do you know if a lawsuit was ever actually filed?

A. No. I dont think so, no. Because there was a settlement, so there was no lawsuit.
Q. All right. Did you have anyth ing to do with it? In other words, did you say anything one
way or the other about asking to have money?
A. No.
Q. But were you consulted in any way about what was going to happen on that?
A. No.
Q. Okay. Was -- did you go into counseling at this time?
A. Yeah.
Q. And -MR. MESEREAU: Objection; relevance.
THE WITNESS: Oh, Im sorry.
MR. ZONEN: I think its relevant.
MR. MESEREAU: And leading.
THE COURT: Ill allow the question. The question and answer was, Yes.
Q. BY MR. ZONEN: For what period of time did you stay in counseling?
MR. MESEREAU: Objection. Relevance;
MR. ZONEN: I believe its appropriate under People vs. Bledsoe and Shirley.
THE COURT: Go ahead. Ill allow the question.
Q. BY MR. ZONEN: For what period of time did 4843 you stay in counseling?
A. Shoot, like a week after the sheriffs interviewing me, or police, or whoever they were.
And -Q. Thats when it started?
A. Till I was 18, yeah.
Q. Till you were 18?
A. Yeah.
Q. Mr. Francia, recently have you been under surveillance?
A. Yeah.
MR. MESEREAU: Objection. Relevance; 352.
THE WITNESS: We might be going there. I dont know.
THE COURT: Im not sure what the relevance is. Do you want to approach?
MR. ZONEN: Yes, I think so. (Discussion held off the record at sidebar.)
THE COURT: Looks like its time for our afternoon break. (Recess taken.)
THE COURT: For the record, the objection was sustained.
Q. BY MR. ZONEN: Mr. Francia, you stated earlier, you gave the statement, When all
this, and I think you used the word crappiness began. What were you referring to?
A. I guess coming out with it. Just because I had hidden it, and it was stowed away in a
far off place. And thats what I meant. It was time for it to come out.
Q. Were you aware of your mother going on television at some time back in 1993 or 94?
A. I knew about it when she was finally on T.V., yeah. I -- she told me -MR. MESEREAU: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. ZONEN: Were you consulted about that prior to
THE COURT: They cant hear. Who didnt hear back there? Counsel here?
MR. ZONEN: Is it on or off? I cant tell. Is it on? Its on.
Q. Were you consulted by anybody prior to your mother going on television?
A. Was I?
Q. Yes.

A. No.
Q. Okay. Did it cause you problems when that happened?
A. Yeah.
Q. And in what way?
MR. MESEREAU: Objection; relevance.
THE WITNESS: It made -THE COURT: Sustained.
THE WITNESS: Okay.
MR. ZONEN: I have no further questions.
THE WITNESS: Can I get a jacket? Its cold over here. I think I heard them say its cold,
too. Thanks.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. Good afternoon.
A. Hi.
Q. My name is Tom Mesereau, and I speak for Michael Jackson.
A. Okay.
Q. If anyth ing I ask you is not clear, please dont answer. Just say, I dont understand it,
okay? And Ill try to rephrase it. If you ever want to take a break, just say so, and if Judge
Melville lets you, you can. But I dont want you to answer anything I ask you unless its
very clear to you what Im asking you and you feel like you can answer it, okay?
A. Sounds good.
Q. So you know who I am, Im on his side, okay?
A. Okay.
Q. Weve never met before, right?
A. Correct.
Q. And weve never spoken before, right?
A. I dont think so.
Q. Okay. Now, the prosecutor mentioned the fact that your mother, at one point many
years ago, went on the television show Hard Copy, right?
A. Correct.
Q. And at some point you learned about that, right?
A. At some point I learned about what?
Q. Your mom going on the television show Hard Copy?
A. At some point I learned about it, yes.
Q. Okay. And at some point you learned that she took $20,000 to go on the T.V. show
Hard Copy, correct?
A. No.
Q. You dont know anything about that?
A. I do not.
Q. Youve never heard that to date?
A. I have heard of it today.
Q. When did you first learn that your mother have gone on the T.V. show Hard Copy and
accepted $20,000?
A. Right now. Well, it may actually -- two days ago, I think.
Q. You never knew it until two days ago?
A. That is correct. The reason....

Q. Now, at some point, your mother met with someone from The National Enquirer, right?
A. I dont know.
Q. You dont know anything about that?
A. No.
Q. When did you first learn that your mom had gone on the T.V. show Hard Copy to talk
about Mr. Jackson?
A. When did I first learn -Q. Yes.
A. -- that my mom went on T.V?
Q. Yes.
A. On Hard Copy?
Q. Yes.
A. I think it was when I saw it on T.V.
Q. And that would have been when?
A. I have no clue.
Q. Do you have any idea what year?
A. No.
Q. Does more than ten years ago sound right to you?
A. If you told me five years ago, Id say okay. This whole past -- all these incid ents, yeah.
Q. Now, your mother at some point retained lawyers to represent you and she, correct?
A. I dont know if she got them. I dont think she did.
Q. Well, you were a -- really a little boy, right, when lawyers were suddenly with you?
A. Im sorry?
Q. Werent you very little, very young, when lawyers started appearing?
A. I was young when all of this stuff happened, yes.
Q. How old do you think you were when you first met a lawyer involving Mr. Jackson?
A. Were those two detectives lawyers?
Q. No. No, theyre with the sheriffs -A. Theyre just detectives?
Q. And you met them recently, havent you?
A. No, I just met one of them right outside.
Q. Okay. One of the two detectives that first talked to you?
A. Yeah. W e were talking about life.
Q. Okay. Now, when you first met them, you knew they were with law enforcement, right?
A. When I first met them?
Q. Yes.
A. I dont really know who they -- no, I dont -- I didnt think -- yes. I dont know. I didnt
understand the question I guess.
Q. Okay. Just tell me if you dont understand a question.
A. Okay.
Q. You learned at some point your mother went on Hard Copy, correct?
A. I learned at some point that my mom went on Hard Copy.
Q. Yes.
A. Okay.
Q. And you saw it on T.V., right?
A. Right.
Q. And at some point you learned that your mother accepted $20,000 to be on Hard Copy,
correct?

A. You already asked that.

MR. ZONEN: And I so object as asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: When did you first, if you remember, talk to a lawyer about
anything Mr.Jackson allegedly did?
A. What he -- when did I tell somebody or tell the lawyer? Repeat that.
Q. Yeah, when did you first meet a lawyer to talk about your claim regarding Mr. Jacksons
behavior?
A. I dont remember.
Q. Do you know approximately when it was?
A. I think the only -- I dont think I ever told Terry or Kris if he molested me or not.
Q. Okay. Now, Terry is who?
A. Terry?
Q. Terry is the lawyer?
A. Terry is a lawyer.
Q. Thats Terry Cannon, correct?
A. Correct.
Q. And Kris is who?
A. Kris -- I forgot his last name. Hes a lawyer.
Q. You mentioned him in response to the prosecutors questions. Didnt you say Kris was a
lawyer?
A. I dont remember the prosecutors questions.
Q. Do you have a lawyer n amed Kris?
A. Right now? No.
Q. Have you ever had a lawyer named Kris?
A. I believe so.
Q. And do you know Kriss last name?
A. Thats what I just said. I dont remember.
Q. Okay. Now, did I hear you just say you never told either lawyer that you had been
molested?
A. I dont -- Im sorry?
Q. Did I hear you just say that you never told either lawyer youd been molested?
A. I said I didnt know. Thats what I said.
Q. You told the lawyers you didnt know?
A. No, I told you I didnt know.
Q. You told me you didnt know whether or not you had told any lawyer youd been
molested, right?
A. Not any lawyer.
Q. Okay. Im not understanding you.
A. Im not understanding you either.
Q. Let me rephrase the question.
A. Okay.
Q. Did you ever tell Attorney Terry Cannon youd been molested?
A. Yes.
Q. And did you ever tell Attorney Kris youd been molested?
A. Yes.
Q. Okay. Approximately when d id you do that?
A. I dont remember. I was young.

Q. Do you know approximately what year it would have been?

A. Id go with 94 or 93 or 95.
Q. And how old were you in 93?
A. I was 13. Well, yeah. My birthdays May 30th, so -Q. How old were you when you claim Mr. Jackson first tickled you improperly?
A. Seven and a half the first time.
MR. ZONEN: Im going to object as vague when were referring to the claim or the
tickling. MR. MESEREAU: I think I was -- Ill rephrase it if the Court wants me to. I think
I was clear.
THE COURT: The objections overruled. The answer was given.
Q. BY MR. MESEREAU: Are you telling the jury that at some point -- excuse me. Let me
start again. As of today, youre telling this jury youve never told your mother what you
claim Mr. Jackson did to you, right? prosecutors questions, that you had never told your
mother you were molested, that wasnt true, right?
A. I was mistaken.
Q. Okay.
A. Yeah.
Q. Okay. In fact, you had told your mother that you were molested, right?
A. Yeah, I must have misunderstood his question with the -- with the details of it. I never
told my mom that I was molested three times by Michael Jackson. My mom, I dont even
think to this day, knows that I was molested three times and the specifics of it. If she
does, then she does, and that sucks.
Q. Your mother went on the T.V. show Hard Copy in the early 90s, right?
A. Okay. I -Q. Do you know if thats true?
A. She was on Hard Copy.
Q. She was on Hard Copy in 1993, was she not?
A. If you told me 94, Id agree. I dont know. I dont know the exact year. I do not.
Q. Are you telling the jury that before your mother went on Hard Copy, you never
discussed what you claim Mr. Jackson did to you with your mother?
A. Yeah, Im pretty sure that I never told my mom that he molested me before Hard Copy.
Q. And before sheriffs came to talk to you for the first time, had you told anyone that you
had been molested by Michael Jackson?
A. I dont think so, no.
Q. They just kind of came one day and surprised you? (Laughter.)
A. Yeah.
THE COURT: Just a moment, Counsel. (To the audience) Im not going to put up with
that.
THE WITNESS: Thanks.
THE COURT: If theres any laughing again, Ill remove people from the courtroom. Go
ahead, Counsel.
MR. MESEREAU: Thank you, Your Honor.
Q. You have -- you all right?
A. Yeah. I was just a little tense. Sorry.
Q. You have reviewed the tape and transcript of your first interview with the sheriffs,
correct?
A. Yes.
Q. And when did you review that interview?

A. Like when did I listen to the tapes again? Is that what youre asking?
Q. Yes.
A. Sunday.
Q. And how did you get the tape?
A. Chris - I dont know his last name gave them to me.
Q. Is that the lawyer?
A. No. Hes not a lawyer, I dont think.
Q. Is he a sheriff?
A. Its a tall man.
Q. Is he a sheriff?
A. I dont know. I believe so.
Q. How did you run into him?
A. I met him when I met all these gentlemen.
Q. The prosecutors?
A. Correct.
Q. Okay. So Chris was with the prosecutors when you met them last, right?
A. Im sorry?
Q. Chris was with the prosecutors when you spoke to the prosecutors, correct?
A. Yes.
Q. And Chris gave you a tape of your interview from 1993, correct?
A. I believe thats the year, yes.
Q. And if you remember, who was at that interview in 1993?
A. I dont remember. Two men. Detect ives, I believe.
Q. And where did it take p lace?
A. I already answered that to him.
Q. Would you please answer it again for me? Where did it take place?
A. At the sheriffs station, or the probation --I think it was the sheriffs.
Q. Was that in Santa Maria?
A. In Orcutt.
Q. In Orcutt, okay. You were given a copy of the tape to listen to, right?
A. Right.
Q. And you were given a transcript of the tape to read, right?
A. Yeah.
Q. And you did that, right?
A. Yeah.
Q. And a Detective Russell Birchim from the Santa Barbara County Sheriffs Department
was present for that interview, right?
A. I dont remember his name.
Q. Would it refresh your recollection if I just show you a copy of the transcript?
MR. ZONEN: Ill object as to which interview. Talking about the 1993 one, or the recent
one where he reviewed the transcript?
MR. MESEREAU: Im talking about the 1993 one.
MR. ZONEN: Im sorry.
Q. BY MR. MESEREAU: Lets get back to the 1993 interview.
A. Okay.
Q. You have recently reviewed a transcript of that interview, right?
A. In the 93 interview?
Q. Yes.

A. The tape and the transcript?

Q. Yes.
A. Have I reviewed them both?
Q. Yes.
A. Didnt I answer you that already?
Q. Would you please clarify it? Because theres been some confusion.
A. Yes, I have.
Q. You have listened to the tape and youve read the transcript, right?
A. Correct.
Q. But as you sit here today, youre not sure who was at the interview with you in 1993,
right?
A. I was 13 years old.
Q. Would it refresh your recollection if I show you a copy of the transcript with the names
of the people who were with you?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
MR. MESEREAU: Thank you.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that transcript? Mr. Francia,
have you had a chance to look at the transcript I just showed you?
A. Yes.
Q. Okay. Did it refresh your recollection about who was there for that interview?
A. Yeah. I just read it. It said Vince and Russell.
Q. Vince Neglia and Russell Birchim, right?
A. Correct.
Q. Okay. Okay. Now, did someone tell you to review that transcript before you testified?
A. Yes.
Q. Who told you to review that transcript before you testified?
A. Im under some pressure. Mark -- its not Mark. Its Russ. Im so bad with names.
Q. Is it Prosecutor Zonen, who just asked you questions?
A. Yes.
Q. Okay. Okay. D id he tell you youd be asked questions about that?
A. About -Q. What you said in that interview in 1993?
A. Yes.
Q. Okay. Did he tell you to study it carefully and make sure you knew what you said and
didnt say, right?
A. Actually, he d idnt say, Study it carefully.
Q. Did he tell you to read it?
A. He told me to review it.
Q. Okay. Okay. Now, you were how old when you were interviewed in 1993?
A. I think on that, it says the date. I could tell you the -- I could tell you how old I was.
Q. Okay. The date was November 4th, 1993.
A. I was 13.
Q. 13. Okay. Is that the first time you were ever interviewed by any police officer
regarding Michael Jackson?
A. Yes.

Q. Okay. Now, you told the police that you and Mr. Jackson were talking to one another in
that hideout area, right?
A. I -- I was kind of banging my -- I told the police that I was -Q. Talking to Mr. Jackson at a place you described as the hideout.
A. Yes, I have talked to Jackson at the place, at the hideout.
Q. And that was a place where Mr. Jackson used to go when he didnt want the public or
the press or anyone knowing he was there, true?
A. Im assuming that.
MR. ZONEN: Objection as speculative.
THE COURT: Just -Q. BY MR. MESEREAU: Did Mr. Jackson ever tell you -THE COURT: I havent ruled on it.
MR. MESEREAU: Oh, I thought you had, Your Honor. Sorry.
THE COURT: Ill allow the question, and the answer was, I assume that. Go ahead,
Counsel.
Q. BY MR. MESEREAU: Did Mr. Jackson tell you that this was a place that he didnt want
the public or the press following him to?
A. I dont know.
Q. Okay. All right. In that interview, you told the police that you were sitting on Mr.
Jacksons lap, right?
A. Im sorry?
Q. In that interview, you told the police you were sitting on Mr. Jacksons lap, correct?
A. In the 93 11 -- is that this one that youre reviewing right now?
Q. Yes.
A. The one you showed me? Yes.
Q. Yes. And you told them that at one point, he started tickling you and you started
tickling him, right?
A. Yeah.
Q. And then you told the police, I have this blackout. I cant remember anything else,
right?
A. Yeah. I -- I tried to black everything out.
Q. I understand. But I just want to go forward and ask you some questions about it.
A. Oh, okay.
Q. But on that particular date, you told the police that you had blacked everything out
after you and Mr. Jackson started tickling, right, tickling each other, correct?
A. Yeah.
Q. Okay. You told the police you knew that Michael Jackson had a reputation of being nice
to kids, right?
A. Im sorry?
Q. You told the police that Mr. Jackson had a reputation for being very nice to kids, right?
MR. ZONEN: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: What did you tell the police about Mr. Jacksons reputation?
MR. ZONEN: Objection; irrelevant.
THE WITNESS: I dont remember.
MR. ZONEN: And hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You were in that apartment because your mother brought you

there, right?
A. My mom d id bring me there to the hideout.
Q. She brought you there and she was working in the apartment, correct?
A. Yeah.
Q. And how many rooms do you remember there being in that apartment?
A. I remember one, but I could be mistaken.
Q. The first time you claim you were improperly tickled, was that on a chair?
A. Yeah.
Q. And that was when your mom was cleaning the apartment, correct?
A. She wasnt in the room.
Q. She wasnt in the room then?
A. She was not in the room with me.
Q. You sure of that?
A. Yeah.
Q. Well, you told the police you had a b lackout and didnt remember anything after -after you and Mr. Jackson were tickling each other, right?
A. I blocked it out. I didnt blank it out. I just didnt never want to repeat that stuff again.
Q. Okay. Do you remember, in one of your police interviews, the police telling you, This
is what happened, right? And you said, Well, Ill have to work on that? Do you
remember using words like that?
A. No.
Q. Okay. Have you looked at the transcripts of both your police interviews?
A. No.
Q. Okay. Just looked at the one in 93?
A. I believe so.
Q. Okay. Okay. Now, you told the police you didnt want to sit on the floor, right?
A. I dont know what youre talking about right now.
Q. Did you ever tell the police you wouldnt want to sit on Mr. Jacksons floor?
A. Are you talking about the hideout?
Q. Yes.
A. I -- yeah, I remember -- I dont remember saying that. I remember hearing that on the
tape.
Q. You did hear it on the tape, right?
A. Yeah.
Q. And its your voice, right? Right?
A. Yeah.
Q. Okay. You told the police.... Lets talk about the first incident you claim happened,
okay?
A. Okay.
Q. Now, you claim you both were clothed, correct?
A. Yes.
Q. You claim you were sitting in Mr. Jacksons lap, right?
A. On one leg, yeah.
Q. Okay. And you claim he started tickling you, right?
A. Right.
Q. You tickled back, correct?
A. Yeah.
Q. And you were watching cartoons, right?

A. Yeah.
Q. Had you ever watched cartoons with Mr. Jackson before?
A. I dont remember.
Q. Had you ever watched cartoons with him in Encino?
A. Im sorry?
Q. Had you ever watched cartoons with Mr. Jackson in Encino?
A. I dont remember.
Q. Okay. Do you remember either Mr. Jackson tickling you or tickling him at the home in
Encino?
A. I dont remember any of that in Encino.
Q. Where was your mother, if you know, when you say you were improperly tickled?
A. I dont.
Q. Did she come back at some point?
A. I had to have left there with my mother, so I think she did.
Q. And how old were you on that particular day?
A. I answered that already, and I thought seven and a half. Seven, eight.
Q. Okay. You told the jury that you tickled each other and then you went to the floor and
you dont remember after that, correct?
A. I dont remember after what?
Q. You went to the floor.
A. I dont remember after he was playing with my balls.
Q. Well, thats what you said later on. Earlier interviews you denied that, didnt you?
MR. ZONEN: I think were vague now.
THE WITNESS: Yeah.
MR. ZONEN: Ill object as vague.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Early in your interviews, you denied being touched in your
private areas, didnt you?
A. Yeah. I was scared.
Q. They were pretty long interviews, werent they?
A. I believe so. Yeah, they were. They were long in my time. To a kid, an hours a long
time.
Q. Do you remember in your first police interview in 1993 telling the police, Ill just say
this out flat. I dont remember him trying anything with me except for the tickling? Do
you rememb er that?
A. Do I remember saying that?
Q. Yes.
A. No. But Ive heard that on the voice. Yeah, I was fighting them with everything I had.
Q. I understand. I understand. You told the police that at that apartment there was a
humongous T.V., right?
A. In what apartment?
Q. Mr. Jacksons apartment, where you say you were improperly tickled, right?
A. The hideout?
Q. Thats what you call the hideout. Im calling it the apartment. You call it the hideout,
right?
A. Okay. My mom called it the hideout. Thats why I called it the hideout.
Q. You told the police in 1993 there was a humongous T.V., right?
A. I dont know.

Q. You said, It was 46-inch, something like it?

MR. ZONEN: Im going to object as to hearsay.
THE WITNESS: I dont know.
THE COURT: Just a moment. Sustained. You need to wait until I rule on the objection.
THE WITNESS: Oh, sorry.
THE COURT: Go ahead.
Q. BY MR. MESEREAU: Do you remember telling the police in that interview, We started
tickling each other and my mom just grabbed me and, Lets go?
A. I dont remember.
Q. Would it refresh your recollection if I just show you a page of it?
A. Probably would.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: You may.
MR. ZONEN: What page?
MR. MESEREAU: It would be page 26.
MR. ZONEN: Thank you.
THE WITNESS: Okay. I see that.
Q. BY MR. MESEREAU: Have you had a chance to look at that? Does it refresh your
recollection about what you told the police in that interview?
A. No, not really.
Q. Well, on a number of occasions, you told them, We tickled each other and then I left,
didnt you, words to that effect?
A. Yeah. Again, I was fighting with everything I had.
Q. Im not asking you what you were doing. Im just asking if thats true, okay? On a
number of occasions, you said, We just tickled each other and then I left, right?
A. Okay.
Q. Is that correct?
A. Yes. And then I also told them that he molested me.
Q. On many occas ions in that interview you denied being molested, didnt you?
A. Yeah, at first.
Q. And the police kept leaning on you to admit you had been molested, true?
A. It wasnt like a twisting the arm. It was -- I was again fighting. I didnt want to be
embarrassed at school. I d idnt want to be embarrassed anywhere. I was 13.
Q. So you were lying to the police?
A. Yeah. I was at first.
Q. Okay. Now, shortly after this -- let me rephrase that. How long after this did you and
your mother
get lawyers and threaten to sue Mr. Jackson; do you know?
MR. ZONEN: Objection as compound, you and your mother. And vague.
THE COURT: Sustained. Compound.
Q. BY MR. MESEREAU: Do you remember in that interview being asked, Is Mr. Jackson
touchy-feely? And you said, I dont remember. I distinct ly dont remember?
A. I dont remember that interview.
Q. Would it refresh your recollection if I show you that page?
A. If you show me the page, Im still not going to remember.
Q. Well, youve -A. I could -- if it says on the transcript, then Ill say, okay, I said it when I was younger.
But I dont remember right now.

Q. But youve listened to the tape and read the transcript to prepare for today, correct?
A. This is pretty nerve-racking being here right now, so for me to say Im prepared for
this? Im not prepared for this.
Q. Well, I do have to ask you questions, you understand that?
A. I totally understand.
Q. Okay. Now, you told police in that interview, they asked you if Mr. Jackson was touchyfeely, and you said, I dont remember. I distinct ly dont remember. Remember that?
A. Do I remember that? No, I dont remember that.
Q. Might it refresh your recollection if I just show you that page?
A. We just did this again.
MR. ZONEN: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Remember telling the police you just remember the tickling; it
was fun?
A. It was fun to be tickled, to laugh. Thats fun.
Q. Okay. Thats what you told the police in that interview, correct?
A. What Im telling you right now is that its fun to laugh. I dont know what I told them.
Q. Might it refresh your recollection if I just show you a page of transcript?
A. Ill agree with it if it says it on there, but I -- to remember that all right now, I dont
remember.
Q. You told the police Mr. Jackson never kissed you, right?
A. I remember saying that. I remember hearing that on the tape.
Q. And you told them that he just hugged you goodbye when you left with your mom,
right?
A. At first. I believe thats in the very beginning of the transcript.
Q. You were asked if you had met Brooke Shields by the police. Do you remember that?
MR. ZONEN: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you ever meet Brooke Shields?
MR. ZONEN: Objection; irrelevant.
THE COURT: Overruled. You may answer.
THE WITNESS: Heck if I know.
Q. BY MR. MESEREAU: Do you remember whether or not Mr. Jackson was dating Brooke
Shields at that point in his life?
MR. ZONEN: Objection; speculative.
THE COURT: You may answer.
THE WITNESS: When I was -THE COURT: The question is, do you know? Just yes or no.
THE WITNESS: Okay. I dont know.
Q. BY MR. MESEREAU: Now, at this point, do you know whether or not youve ever
obtained money from Mr. Jackson?
A. One more time.
Q. At this point in time, do you know whether or not youve ever obtained money from Mr.
Jackson other than what you just described?
A. Other than the money that he put down my pants?
Q. Yes.
A. Yes.
Q. At some point you and your mother settled a case with Mr. Jackson, correct?

A. I dont remember signing papers.

Q. Youre how old today?
A. Im 24.
Q. And youre telling the jury you dont know whether you and your mother ever reached
a financial settlement with Mr. Jackson?
A. There was a financial settlement.
Q. Okay. And when did you learn about that?
A. I believe I was 17.
Q. Do you remember signing documents in that?
A. At 17, I dont remember.
Q. Okay. Do you remember looking at that agreement?
A. At 17, I did not look at that agreement.
Q. And now, at 17, you knew that your mother had already gone on televis ion attacking
Mr. Jackson, right?
A. When she was on Hard Copy, is that what youre talking about?
Q. Yes.
A. Yes. At 17, I heard she had already been on Hard Copy.
Q. And at some point she met with Attorney Larry Feldman, d id she not?
A. I dont know.
Q. Okay. But at 17, you certainly knew that your mother had hired attorneys who were
threatening to sue Mr. Jackson if they didnt get some money, right?
A. No, I do not.
Q. Didnt know anything about that at 17?
A. Call me a stupid kid. I d idnt know.
Q. Okay. But you certainly learned about it at some point?
A. Yeah. I learned about it at some point.
Q. Which did you learn about the fact that your 4873 lawyers were threatening to go
public and sue Mr. Jackson unless you and your mother got money?
A. All of that stuff I dont know about. I knew that there was a settlement. I dont know
how they fought, or what they argued about, or what they talked about.
Q. Youve never discussed it with your mom?
A. About -- I have never discussed what, the settlement?
Q. Yes.
A. Yes, I have.
Q. Have you ever d iscussed how the settlement came about with your mom?
A. No.
Q. Okay. Okay. And do you remember reading a settlement document?
MR. ZONEN: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You were asked to sign a settlement document at some point,
right?
A. Probably.
Q. And in that document, Mr. Jackson denied doing anything wrong, correct?
MR. ZONEN: Objection; assumes facts not in evidence.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know whether or not in that settlement document you
signed Mr. Jackson denies ever doing anything wrong?
MR. ZONEN: Objection. No evidence he signed it, he viewed a document or signed a

document.
THE COURT: The objection is sustained. He said -- when you asked him if he signed it, he
said, Probably. So you havent established that he signed it.
MR. MESEREAU: Okay.
Q. At the age of 24, and as you sit here today, you dont know if you ever signed a
settlement document with Mr. Jackson?
A. That is correct.
Q. As you sit here today, at the age of 24, do you know if your mother ever signed a
settlement document with Mr. Jackson?
A. I think she did.
Q. Do you know if any money has come your way through a settlement with Mr. Jackson?
A. Money has, yes.
Q. Okay. And when did you first learn about that?
A. I answered that I thought. At 17.
Q. Okay. And youve had many discussions with your mom about that, right?
A. No. We -- me and my mom have a weird relationship. Well, not a weird relationship.
We just dont talk about much stuff.
Q. Okay. Do you remember constantly telling the people who interviewed you in 1993 that
you didnt remember Mr. Jackson doing anything improper?
A. I dont remember now, but I -- in listening to the tapes, I remember when I was -- at
first I was denying everything.
Q. Youve told the police that he tickled you, you tickled him, you both laughed, and then
you went home, right, early in the interview?
A. I think I told him that I b lacked it out or -- yeah.
Q. And you told the police at one point as they tried to get you to say he had molested
you, you said, If I dont remember, I dont remember, right?
A. Yeah.
Q. The police kept trying to tell you to say that Mr. Jackson put his hands somewhere that
was improper, right?
A. No, they didnt.
Q. Do you remember these long paragraph questions where theyd say, essentially,
Admit to us he did something improper?
A. They said, If he d id something, then tell us. Thats what I remember. You could give
me that, and Ill read it.
Q. Would it refresh your recollection if I show you one of the paragraph questions they
asked you?
A. Well, this is -- Im telling you what I remember. Its not going to change my memory.
Q. Its not going to change your memory to look at the transcript?
A. No. What I remember is them telling me, If he did something, then tell us. And I was,
No, Im not gay. I was fighting it again.
Q. You repeatedly told them, I have nothing to tell you. I dont remember anything,
right?
A. Im sorry?
Q. You repeatedly told them you had nothing to tell them because you didnt remember
anything improper?
A. In the very beginning, yeah.
Q. Yes. Now, in your response to the prosecutors questions about the first time you say
you were improperly touched - okay? -

A. Okay.
Q. -- did you say words to the effect, At some point we were on the floor?
A. I believe I did, yeah.
Q. Okay. And then you said, in response to the prosecutors questions, I cant remember
anything after that, right?
A. Im sorry?
Q. After saying that you went to the floor, earlier today -A. Okay.
Q. -- you then said, I dont remember anything after that, correct?
MR. ZONEN: Im going to object as asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember anything that happened after you went to the
floor during the first time you say you were improperly touched?
A. Isnt that the same question that you just asked?
MR. MESEREAU: Your Honor, could the witness be instructed to respond?
MR. ZONEN: Im not certain as to the
THE COURT: Just a moment. (To the witness) The problem we have is you dont get to
object to his questions. If the District Attorney wants to object, he can. If the District
Attorney doesnt object, then you just answer the question.
THE WITNESS: Okay.
THE COURT: Just a moment. Ill have the question read back.
MR. MESEREAU: Thank you, Your Honor.
THE WITNESS: Sorry. (Record read.)
THE WITNESS: After he touched me? Like in my genitalia?
Q. BY MR. MESEREAU: Did you then go to the 4878 floor?
A. I thought we were already on the floor.
THE COURT: Youre asking him a d ifferent question.
MR. MESEREAU: Okay.
Q. Do you want the first question? Do you want the first question read back again? Ill
start again, Your Honor.
THE COURT: Okay.
MR. MESEREAU: Okay.
Q. You said you were sitting in a chair with
Mr. Jackson, right?
A. Okay. I was on his lap, yeah.
Q. You said you were tickling each other at one point, right?
A. Right.
Q. And at one point you said you went to the floor, correct?
A. Right.
Q. Were you tickling each other on the floor, as far as you remember?
A. As far as I remember, I believe so, yeah.
Q. And there was a lot of laughing going on, right?
A. Yeah. Yeah.
Q. And then at some point your mom came b ack, right?
A. Did I say that?
Q. Im just asking you.
THE COURT: Just answer.
THE WITNESS: No, Im literally asking you. No, I dont think I said that.

Q. BY MR. MESEREAU: Didnt she come back at some point and then take you home?
A. She must have, yeah. She had to have taken me home.
Q. In your interview in 1993, the police asked you if Mr. Jackson rubbed your penis, and
you said, No, correct?
A. Yeah.
Q. Right?
A. In the beginning, yeah.
Q. Well, pretty late in the interview, wasnt it?
A. I have no clue.
Q. You said, It was a tickling. He didnt rub me there, correct?
A. Oh. Okay. If were going that -Q. Is that right?
A. Yeah, he was playing with my stuff, not rubbing it. In a stroking manner.
Q. I know the point youre trying to make to the jury, but Im just asking you the facts,
okay?
MR. ZONEN: I think thats argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You told the police that, 4880 He never rubbed me there. It was
just a tickling, correct?
MR. ZONEN: Objection; asked and answered.
THE COURT: Overruled. You may answer.
THE WITNESS: One more time.
THE COURT: Ill have the court reporter.... (Record read.)
THE WITNESS: I dont remember.
Q. BY MR. MESEREAU: Would it refresh your recollection if I show you a transcript?
A. I dont remember. Ill say I dont remember, but Ill agree with what the transcript
says.
Q. Okay. Well, Im not trying to put words in your mouth. Would you like to look at it?
A. Okay.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: All right.
MR. ZONEN: What page, Counsel?
MR. MESEREAU: 45.
MR. ZONEN: Thank you.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that transcript?
A. I did.
Q. Does it refresh your recollection about what you told the police in that interview? 4881
A. No. But in reading it, it said, Well, yeah in the very beginning of that sentence.
Q. It says, Well, yeah, hes not rubbing it, but tickling, right?
A. Thats what it said, I believe.
Q. And you said it was on top of your pants; is that correct?
A. The first time -Q. Yes.
A. -- that he molested me?
Q. The first time you say he molested you, you say it was on top of your pants, right?
A. Pants or shorts. My clothing.
Q. You said he never put his hands in your shorts, right?

A. Right now? Do I say he never -- no, he did it at the very end. The last time he mo lested
me, he did put his hands in my shorts.
Q. Okay. Were talking about the first time.
A. The first time he didnt.
Q. Okay. And how much time elapsed, if you know, between the first time you say you
were
touched and the second time?
A. Im guessing a year.
Q. And how much time elapsed between the second time you claim you were improperly
touched and the third time?
A. Im guessing two years.
Q. Okay. So let me just, for the record, get your ages each time. The first time you were
around seven, right?
A. Sounds about right. Seven, seven and a half.
Q. The next time you were around eight?
A. Eight, eight and a half, or nine. Yeah.
Q. And the third time youre how old, do you think?
A. Ten, ten and a half.
Q. Okay. And did you have any contact with Mr. Jackson in between those three events
youve described?
A. I believe I did.
Q. Now, lets talk about contact between the first event that youve described and the
second. What kind of contact did you have with Mr. Jackson?
A. Actually, between the first time he molested me and the second time he molested me, I
dont think there was contact between those two times.
Q. Now, has someone told you to make sure you use the word molest repeatedly in your
testimony?
A. No.
Q. Have you discussed your testimony with any lawyer before you came in today?
A. No.
Q. Discussed it with your mom before you came in today?
A. No.
Q. Not at all?
A. Me and my mom?
Q. Yeah.
A. I havent -- no. I havent talked to her much.
Q. Does she know youre here today, to your knowledge?
A. Yeah, I think she does.
Q. Youre not sure?
A. Im pretty sure she does.
Q. Okay. Have you talked to her about it?
A. About me coming on the stand?
Q. Yes.
A. No, I have not.
Q. Okay. Now, the prosecutor asked you how long the tickling continued the first time,
right?
A. Okay. Yes.
Q. But you didnt time how long the tickling continued?

A. No, I didnt have a stopwatch.

Q. You dont really know how long it continued, do you?
A. I could go by Woody Woodpecker, but -- I could go by cartoons, but I didnt have a -- I
probably did have a watch on, but I didnt time it.
Q. Youve told the police nothing happened skin to skin, right?
A. At first.
Q. Well, you still say nothing -- there was no touching skin to skin -MR. ZONEN: Objection.
Q. BY MR. MESEREAU: -- in the first event, right?
MR. ZONEN: Withdraw the objection.
THE WITNESS: Are we talking -- yes, we are talking the first event, so -- correct?
Q. BY MR. MESEREAU: Yes. No skin-to-skin touching, correct?
A. Correct. I just sometimes get confused if youre talking first event, second event, third
event.
Q. Unless I say otherwise, lets assume Im talking about the first event. Okay?
A. Okay.
Q. Now, after that first event happened -A. Okay.
Q. -- you claim you never told anyone about it, right?
A. Correct.
Q. After the second event happened, you claim you never told anyone about it, right?
A. After the second time it happened?
Q. Yes.
A. Yes, I did not.
Q. After the third time it happened, you claim you never told anyone about it, and then
suddenly the police came one day, right?
A. Right.
Q. Okay. Between the first and the second event, how often did you see Michael Jackson?
A. Between the first and the second?
Q. Yes.
A. I thought I said none. I didnt think I saw him in between 1 and 2.
Q. You didnt see him at all?
A. I dont think so. I dont remember.
Q. Okay. I mean, your mother still was working for Mr. Jackson, right?
A. Yeah.
Q. And she used to clean his house, right?
A. Clean the mansion, yeah.
Q. And would you go over to the mansion with her, still, from t ime to time?
A. At times, yeah.
Q. Do you recall seeing Mr. Jackson anytime after -- or excuse me, between the first and
the second event?
A. I dont recall it.
Q. Okay. The second event youve described -- actually, let me go back to the first one.
You said you dont remember how it felt, you were too young, right?
A. Im sorry?
Q. Yeah. Going back to the first event.
A. Okay.
Q. Correct me if Im wrong, I think you said, I dont remember how it felt. I was too

young, right?
A. I believe thats what I said, yeah. W hen he was doing his interview or -Q. Pardon me?
A. -- when he was asking me the questions?
Q. Yes. Yes.
A. Yeah.
Q. Okay. And you dont recall -- excuse me. And the year you think that happened was
when? When do you think?
A. The first time?
Q. Yes, please.
A. Im thinking 87, 88.
Q. 87, 88?
A. Yeah, around there.
Q. Okay. 17, 18 years ago, right?
A. Right.
Q. Okay.
A. Well, yeah.
Q. You said that youve done some therapy, right?
A. That Ive gone through counseling, yeah.
Q. Yes. And without going into what you said, because thats confidential -A. Okay.
Q. -- have you done anything, exercises or anything, to try and refresh your memory
about what happened in 87 or 88?
A. No.
Q. Okay. And has any representative of the police department been involved in any of
your counseling sessions?
A. No, I dont think so. Well, there was the one time that the -- that I first met Mr.
Sneddon, I think thats his name. And it wasnt a counseling session. But Mike Craft,
which was my counselor, was there.
Q. Was there with Mr. Sneddon present?
A. I think he was there, but I was 13.
Q. Okay. And to your knowledge, was Mr. Sneddon talking to your counselor?
A. I dont know.
Q. Okay. This is 12 years ago, approximately?
A. In 93.
Q. Okay. Okay.
A. Or 94.
Q. Okay. But you dont know what your counselor or Mr. Sneddon said to each other,
right? You wouldnt know?
A. I wouldnt know.
Q. Okay. Do you know how long Mr. Sneddon and your counselor met?
MR. ZONEN: Objection; assumes facts not in evidence, that they met.
THE COURT: Overruled. You may answer.
THE WITNESS: I dont even know if they met. I dont even -- well, they had to have met
because they were in the same room, if they were in the same room. But I dont know.
Q. BY MR. MESEREAU: Do you know where they were in the same room?
A. Yeah, when they were in front of me.
Q. Do you know where that room was?

A. Yeah, it was in where I got my counseling. It was my counselors office.

Q. So Mr. Sneddon came to your counselors office, correct?
A. Thats what it -- Im telling you this, because I think I remember meeting him there.
Q. Okay. Do you know if your counselors been in touch with Mr. Sneddon?
A. I dont.
Q. Do you know if hes spoken to Mr. Sneddon at any time other than that day?
A. I dont.
Q. Okay. All right. Now, the second time you claim you were improperly tickled, you said
you were lying on top of a sleeping bag, correct?
A. In or on, yeah.
Q. Well, you told the police it was on top. You were not in, right?
A. I think it says that on the transcripts.
Q. Okay. And that was a large sleeping bag that took up most of the floor, correct, as far
as you remember?
A. I cant see a sleep ing bag taking up the whole floor in a room, now, because its
gigantic. But I think I said that when I was younger.
Q. Okay. Do you remember mentioning Steven Segall to the police?
A. Yeah, I do.
Q. And why did you Steven Segall?
A. Why did I mention him? I dont know. Because I played pool against him, I think.
Q. Was that with Michael Jackson?
A. I think he was there.
Q. Okay. Was that at Neverland; do you know?
A. I think it was -- yeah, Im pretty sure it was at Neverland. It was at Neverland.
Q. Now, in the second event that youve described, you also claim that there was no skinto-skin touching, correct?
A. On the second event, I dont -- yes, that is what I claim.
Q. And what you said was that that also began like tickling, correct?
A. Yeah.
Q. Okay. You were tickling each other, right?
A. Im sorry?
Q. You were tickling each other at that point?
A. Yeah, it started off with him tickling me.
Q. Okay. And that was at the -- what you call the hideout as well, right, the second event?
A. Yes.
Q. Okay. Where was your mom at that point?
A. I dont know. Not in the room.
Q. Okay. All right. Youre on the floor, and youre in that position you described, right?
A. What -- when hes kind of spooning in and holding me? Yeah.
Q. And he starts tickling you, right?
A. Correct.
Q. You tickle him back, right?
A. Probably.
Q. Youre watching television, right?
A. Probably, yeah.
Q. Okay.
A. Yeah. W ell, I mean -- Im sorry. I am watching T.V., but I dont know whether Im
tickling him back or watching T.V.

Q. Youre both laughing, right?

A. Probably.
Q. And then you say at some point he improperly tickled you in your private area, correct?
A. Yeah, he did.
Q. Do you remember telling the police it was -- it was no more than a 30-second thing?
A. I dont remember that.
Q. Would it refresh your recollection if I show you a portion of the transcript of your police
interview?
A. It wouldnt. I could look at it again, but it wouldnt make me remember.
Q. Do you want to give it a try?
A. Okay.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. I did.
1Q. Does it refresh your recollection about what you told the police?
A. No.
Q. You dont remember their asking you if it was just like a passing thing, and you said,
Its no more than a 30-second thing?
THE COURT: Counsel, thats not how you refresh recollection. He said it didnt refresh his
recollection.
MR. MESEREAU: Okay.
Q. Do you remember telling the police, when they asked you how long it was, you dont
know, We were just laughing the whole time?
A. No, I dont remember that.
Q. Okay. Okay. Do you remember being asked if anyth ing improper happened at the
ranch, and you said, I was around too many people?
A. Im sorry?
Q. Do you remember police saying to you, Did anything improper ever happen at the
ranch? And you said, I was around too many people?
A. I remember hearing that on the tape.
Q. Okay. But you dont remember saying that?
A. I dont remember saying that.
Q. Do you remember hearing your voice say that on the tape?
A. Correct.
Q. And in that 1993 interview, when it came to talking about what happened at the
arcade, you didnt know if hed really touched you improperly, right?
A. I knew.
Q. Well, you kept responding, I dont know, and then youd say, If he really did touch,
it was in the arcade?
A. No -Q. And you were asked, Do you think he did it? And you said, I dont know?
A. I knew.
Q. But you told the police you didnt know, correct?
A. I dont remember. If you bring that thing to me again, Im going to -- yes.
Q. Would it refresh your recollection to look at it?
A. Yes, bring it over.
MR. MESEREAU: May I approach, Your Honor?

THE COURT: Yes.

THE WITNESS: You should just drop one off. Okay.
MR. ZONEN: What page, Counsel?
MR. MESEREAU: That would be 57 and 58.
MR. ZONEN: Thank you.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at those pages?
A. I did.
Q. Does looking at those pages refresh your recollection about what you have told the
police -A. No.
Q. -- in 93?
A. I was 13. Eleven years ago.
Q. You werent even sure you were tickled at all. Remember that?
A. I dont remember that I -- I knew.
Q. Remember telling the police, You guys are pushy?
A. Yeah. I remember telling the police that.
Q. Okay. And after they kept pushing you, you 4894 finally said, You know, I think he did
tickle me, right?
A. No.
Q. Do you remember that? Do you remember at first saying you didnt know, and then
after -A. Yeah, I remember saying at first, I dont know.
Q. And after telling the police, You guys are pushy, you eventually finally said, Yes, he
tickled me, right?
A. I believe thats how it went.
Q. Okay. You kind of went back and forth during the interview, didnt you? One second
youd say, He t ickled me, and the next second youd say youre not sure, right?
A. I was trying to figure out how to get out of there.
Q. I understand. And you remember exact ly how you felt in 1993 during the interview,
right?
A. The feeling of, yeah, crying and crappiness.
Q. Okay. Do you remember the police kept trying to get you to say hes a molester?
A. No.
Q. Would it refresh your recollection if I show you what one officer said to you about that?
A. Bring it over.
MR. MESEREAU: May I approach?
MR. ZONEN: Perhaps the witness could indicate whether it would refresh his recollection.
THE WITNESS: It wouldnt.
THE COURT: When he said Bring it over, that sort of means like hell see if it refreshes
his recollection.
THE WITNESS: Okay.
THE COURT: Its a shortcut. Go ahead.
MR. MESEREAU: Thank you, Your Honor.
THE COURT: Were down to the last seconds here. Run. (Laughter.)
MR. ZONEN: What page, Counsel?
MR. MESEREAU: 60.
MR. ZONEN: What line, please? Its not numbered. Never mind.

MR. MESEREAU: Towards the bottom. Towards the bottom.

THE WITNESS: Okay.
Q. BY MR. MESEREAU: Youre 13 years old. Youre sitting there, and one officer said to
you -THE COURT: Wait a minute now. Are you going to ask him if it refreshes his memory?
Q. BY MR. MESEREAU: Have you had a chance to look at that transcript? Does it refresh
your recollection that an officer looked at you said -THE COURT: Just a moment, Counsel.
MR. MESEREAU: Okay.
THE COURT: He said, no, it didnt refresh his recollection. All right. This is the end of the
day. (Laughter.)

2005 April 5 (Day 26) J. Francia, C. Hall man, B. Francia

JASON FRANCIA EXAMINATION (Continued)
CROSS-EXAMINATION (Continued)BY MR. MESEREAU:
Q. Mr. Francia, we were discussing yesterday your first interview with two police
detectives which took place on November 3rd, 1993, okay?
Q. Thats where we left off. Now, did you discuss your testimony yesterday with anyone
after you left the courthouse?
A. Yeah.
Q. Who did you discuss it with?
A. My wife.
Q. Anyone else?
A. No.
Q. Did you discuss it with any prosecutor?
A. No, I was kind of nervous. I said, Howd it go? And they smiled and they said, It
went well.
Q. And which prosecutor told you that?
A. I cant specifically remember, but it was one of them.
Q. Okay. Did you discuss anything else with one of them?
A. No.
Q. Did you talk with any sheriff about your testimony?
A. No.
Q. Were you on the phone last night with anyone about your testimony?
A. No. I did tell my pastor this morning that I was on the stand, and if he could pray for
me. But other than that, that was it.
Q. Anyone else?
A. Nope.
Q. Okay. Now, yesterday you told the jury that Mr. Jackson had given you some money,
correct?
A. Right.
Q. And you told them he had given you hundred-dollar b ills, right?
A. Right.
Q. Isnt it true that when you were originally interviewed by the police, you told them that
Mr.Jackson would give you money each t ime you read a book?
A. Yeah, he also said that, as well. Yeah, hed give me $20, I think it was.
Q. And you told the police that you remember him having a room full of books, and you
said every time you complete a book, hell pay you some money, right?
A. I dont remember that, but I remember listening to it on the tape.
Q. But that was your voice on the tape, correct?
A. Yes.
Q. Okay. You also told the police that Mr. Jackson told you one time that if you got As in
school, he would also pay you every time you got an
A, correct?
A. Yes. That is correct. I remember -- I dont remember him saying that, but I remember
it on the tape.
Q. And that was your voice on the tape?

A. Yes, sir.
Q. Telling it to the police, correct?
A. Yes, sir.
Q. Okay. When you met with the prosecutors before you testified, d id anyone tell you not
to mention that when you talked about money?
A. No.
Q. Okay. You just forgot?
A. Im sorry?
Q. You just forgot yesterday?
MR. ZONEN: Objection; argumentative.
THE COURT: Overruled. You may answer.
Q. BY MR. MESEREAU: When you were responding the prosecutors questions -THE COURT: Wait. He has a question pending.
MR. MESEREAU: Oh, Im sorry.
THE COURT: I overruled the objection.
THE WITNESS: Can you repeat the question?
THE COURT: The question was, You just forgot yesterday?
THE WITNESS: I have no idea what youre referring to. I just forgot about what?
Q. BY MR. MESEREAU: About Mr. Jackson paying you money for, one, reading a book -A. No -Q. -- and, two, getting As.
A. I didnt remember that, but I remember saying that on the tape.
Q. Okay. Okay. Now, following your interview with two police officers in November of
1993, to your knowledge, Mr. Jackson was never charged with a crime involving anything
you said, correct?
A. I dont know.
Q. Okay. Did you ever hear anything about that?
A. I -- no.
Q. Okay. To this day, youre not sure if Mr. Jackson was ever charged with any crime
involving -A. I dont know.
Q. -- what you claim happened?
A. No.
Q. Okay. You also were interviewed a second time.
A. Theres a hand being raised behind you guys over there.
Q. You were interviewed a second time on March 24th, 1994. Do you remember that?
A. Again, I personally dont remember, and I didnt even really listen to that tape, so -and I didnt get a transcript for it either, so I didnt even review it.
Q. You were given a tape of your second interview?
A. I was, but I did not listen to it.
Q. And who gave you that tape?
A. It came in the same p acket as tape one and with the transcript.
Q. Do you remember present at that interview was Tom Sneddon?
A. I remember saying that yesterday, yeah. And I also remember saying that I was
unsure if he was there or not.
Q. Okay. But you do remember now he was there, right?
A. I did not say that.
Q. Would it refresh your recollection if I just show you a transcript?

A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Is this a transcript of 94?
MR. MESEREAU: (Nods head up and down.)
THE WITNESS: So these are the people that were there? I -- I cant ask that.
THE COURT: Hes asking you to look at that and see if that refreshes your memory to see
-THE WITNESS: No, it does not refresh my memory.
Q. BY MR. MESEREAU: So you dont remember if you were interviewed by Tom Sneddon
and two district attorneys in 94?
A. I remember Mike Craft being there. That was the only person. And a woman being
there. Other than that, I cannot -- because I think that was the first time I told a woman
what happened.
Q. Do you remember someone named Lauren Weis from the Los Angeles District
Attorneys Office being there -A. I dont. Im really bad at names.
Q. I have to complete the question. Thank you. Do you remember someone named Lauren
Weis from the Los Angeles District Attorneys Office being present at that interview?
A. No.
Q. Do you remember someone named Bill Hodgeman from the Los Angeles District
Attorneys Office being at that interview?
A. No.
Q. And you dont remember whether or not Mr. Sneddon was there, right?
A. I -- correct.
Q. Are you saying he wasnt there, or you just dont remember?
A. I dont remember whether he was there or not.
Q. Do you remember Russ Birchim being there?
A. I do not.
Q. Do you remember your own lawyer, Terry Cannon, being there?
A. I do not.
Q. Do you remember stating in that interview, They made me come out with a lot more
stuff I didnt want to say. They kept pushing. I wanted to get up and hit them in the
head? Do you remember that?
A. No.
Q. Would it refresh your recollection if I show you the transcript of that?
A. Probably not. But you can show it to me 4908 anyway.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
MR. ZONEN: What page, Counsel?
MR. MESEREAU: 30.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page of the transcript?
A. I have.
Q. Does it refresh your recollection about what youve said?
A. No, it does not.
Q. Do you remember anything you said in that interview at the moment?
A. Not really.

Q. Okay. All right. Do you remember in that interview telling the people who were present
that at one point a woman came into a room where you and Michael were present?
A. No, I do not.
Q. Do you remember seeing Janet Jackson on one occasion?
A. I remember saying that, or do I remember seeing her?
Q. Do you remember seeing her?
A. I think I did meet her once.
Q. Do you remember where you met her?
A. I think it was at the mansion in Encino.
Q. Okay.
A. But I really -- like, I think thats where it was.
Q. Okay. Do you remember telling the sheriffs that the first time you were tickled by Mr.
Jackson you think it lasted about 30 seconds?
A. Are we talking the first interview, second interview?
Q. Either one.
A. I do not remember.
Q. Okay. You do remember g iving more information the second time, correct?
MR. ZONEN: Second time? Objection; vague.
MR. MESEREAU: Excuse me. Hes correct. Ill withdraw it.
Q. You do recall giving more informat ion during your second interview than you did in
your first, right?
A. I do not recall.
Q. Okay. How did you meet Attorney Terry Cannon?
A. I cant -- I think I met them at Mike Crafts office.
Q. Excuse me, at whose office?
A. Mike Crafts, my counselor.
Q. Okay. And does Terry Cannon still represent you?
A. I dont think so, no.
Q. Well, you gave an interview with Mr. Zonen in December of 2004, correct?
A. Yes. That was the first time I think I met them.
Q. And Terry Cannon was present, correct?
A. Youre right.
Q. And Terry Cannon at that time was working for the District Attorneys Office in San
Diego, correct?
A. Correct.
Q. But he still came up to act like your lawyer, didnt he?
MR. ZONEN: Ill object to the expression, act like your lawyer; vague. Or
argumentative.
THE COURT: Well, I guess instead of like, it might be as.
MR. MESEREAU: Ill rephrase it, Your Honor.
Q. Mr. Cannon was present at your interview with Ron Zonen on December 6th, 2004,
right?
A. Yes, sir.
Q. At that interview, he was serving as your lawyer, correct?
A. I dont know.
Q. Do you know why he was there?
A. I didnt really know. I was asked by -- actually, I didnt even know how I met you guys.
I was asked to be there, I think, and he was there. 4911

Q. Okay. Did he give you any legal advice before that meeting?
A. Actually, he said, You dont have to answer things if you dont want to, but I think
that was just a -- man advice.
Q. So he was giving legal advice?
A. I dont know if thats legal advice or not.
Q. Did he discuss with you what you were going to say in that interview?
A. No.
Q. Do you remember when that interview began, you requested that your interview not be
tape-recorded?
A. I dont remember that.
Q. Would it refresh your recollection if I show you a report on that interview?
A. Okay. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that report?
A. I read the first paragraph.
Q. And does it refresh your recollection that you requested that your interview not be
tape-recorded?
A. It does not, but I probably said that.
Q. Okay. You dont know for sure, though? 4912
A. No.
Q. Okay. And you had requested that Mr. Cannon be present at the interview, right?
A. Youre going to have to show me the paper probably.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: (Nods head up and down.)
Q. BY MR. MESEREAU: Have you had a chance to look at the report?
A. I did.
Q. Does it refresh your recollection that you wanted Mr. Cannon present?
A. It does not refresh my recollection.
Q. Let me just try and get this straight. You dont know why Mr. Cannon was there,
correct?
A. Correct.
Q. You didnt ask him to be there, right?
A. I dont remember whether I asked for him to be there or not. I probably did, only
because he was a friend of mine and he knows more legal stuff than I do.
Q. Okay. Did you know he was working for a District Attorneys Office at the time?
A. I believe I did, because we kept in touch -Q. Okay.
A. -- after I was 18.
Q. All right. Now, Mr. Zonen began that interview by telling you about the current case
involving Mr. Jackson, right?
A. I didnt understand the question.
Q. Well, let me try and rephrase it.
A. Okay.
Q. At the beginning of that interview, Mr. Zonen gave you his summary of the current
case against Mr. Jackson, right?

A. I believe so.
Q. And he told you about a family named Arvizo, right?
A. Really bad at names. If thats -- he told me about a child molestation.
Q. Okay. That these were the charges against Mr. Jackson, right?
A. I believe so.
Q. Okay. Have you ever met Janet Arvizo?
A. I dont know who that is.
Q. Ever met David Arvizo?
A. I dont know who that is.
Q. Ever met Gavin Arvizo?
A. Oh, that -- I do know who that is. No, I have not met him.
Q. Have you ever met Star Arvizo?
A. I have never met an Arvizo I dont think.
Q. Never met Davellin Arvizo, correct?
A. Right.
Q. Have you ever talked to any of the Arvizo family on the telephone?
A. No.
Q. Okay. But Mr. Zonen was telling you about the Arvizo family, was he not?
A. If thats the childs parents, then yes.
Q. Incidentally, after your second interview, which you dont remember a lot about, to
your knowledge, no criminal charges were ever filed ag ainst Mr. Jackson involving
anything you had told anybody, right?
A. I dont know.
Q. You still dont know?
A. I -- are you talking about 94, the 94 interview?
Q. Yes.
A. Okay. And youre asking if there was criminal charges pressed against Michael?
Q. Im asking you what you know, okay? Youve already ind icated that after your 93
interview, no criminal charges were ever filed against Mr. Jackson involving anything you
said, right?
A. I dont know much. I dont watch the news.
Q. And -- okay. And after your 94 interview, again, no criminal charges were ever filed
against Mr. Jackson involving anything you said, right?
A. I dont know.
Q. Okay. But at your 94 interview, you do remember Terry Cannon being present, right?
A. I dont know. I dont know who was present other than Michael Craft in 94.
Q. Okay. To your knowledge, was it your moms idea for you to have an attorney at that
meet ing?
A. To my knowledge, I dont know.
Q. Okay. And again, just for the record, how old were you -MR. ZONEN: Ill object as vague as to which meeting.
MR. MESEREAU: Hes correct. Ill withdraw it.
THE COURT: All right.
Q. BY MR. MESEREAU: To your knowledge, was it your mothers idea to have an
attorney be present at the March 24th, 1994, interview?
A. To my knowledge, I have no clue.
Q. Okay.
A. When I was 13, I was really protected by my mom, so I didnt know much --

Q. Okay.
A. -- about anything.
Q. And certainly when you were 13, you didnt hire an attorney, someone else did, right?
A. I didnt -- probably.
Q. Okay. Okay. Do you remember meeting with Attorney Terry Cannon, with your mother,
in 1994?
A. I do not remember, but Im sure we did.
Q. Okay. All right. Do you remember meet ing with any other attorneys that your mother
had retained in 1994?
A. Other than Terry Cannon?
Q. Yes.
A. I dont remember. But there was another attorney, which is Kris Kallman.
Q. Okay. And Kris Kallman is the attorney who represented you in a settlement with Mr.
Jackson, right?
A. I dont know whether it was Kris or Terry.
Q. And Kris also represented your mother, who wanted a settlement with Mr. Jackson,
correct?
A. I dont know.
Q. Now, do you know whether or not your mother went to these attorneys after she
learned that Mr. Jackson had settled with someone named Chandler?
A. I do not.
MR. ZONEN: Objection; lack of foundation.
THE COURT: Court reporter, was that an answer on there?
THE REPORTER: Yes.
THE COURT: Ill overrule the objection. The answer was, I do not.
Q. BY MR. MESEREAU: Why didnt you want your interview in December of 2004 with
the prosecutors tape-recorded?
A. I dont know.
Q. You dont have any idea why you made that request?
A. Tape-recording is weird. I dont know. No, I dont.
Q. Okay. Do you remember telling Prosecutor Zonen in the December 2004 interview
regarding the first incident you described - okay? - that you and Mr. Jackson were in a
tickle contest? Do you remember that?
A. I do not. I dont know whether it was the first interview or the second interview that we
talked about Michael molesting me.
Q. Well, actually, in the December interview, you told Prosecutor Zonen that, in all three
instances that you described where you claim you were inappropriately touched, every
incident was preceded by a tickling contest between you and Mr. Jackson, right?
A. I dont know.
Q. Would it refresh your recollection just to show you the report?
A. You can show it to me, but I dont know whether it was the first or the second.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to review that page of the report?
A. I didnt read the whole page. I read that 4918 paragraph.
Q. Does it refresh your recollection about what you told Prosecutor Zonen in that
December 6th, 2004, interview?

A. It doesnt -- I dont -- it doesnt help remembering, but -Q. Well, you told him that all three events that you described were preceded by a tickling
contest, correct?
A. I dont remember.
Q. You and Mr. Jackson were in a contest as to who could tickle the most, correct?
A. I just said I dont remember that. I dont mean to sound like Im wasting your time, but
this is kind of hard being up here, and -Q. No, please dont. Just respond to my questions, if you would, please.
A. Okay. Sorry.
Q. Now, on November 19th, 2004, Prosecutor Zonen and Auchincloss interviewed your
mother at the District Attorneys Office, right?
A. I dont know. Me and my mother dont talk about that stuff much.
Q. Well, you were present, werent you?
A. Now I remember, yes.
Q. Now you remember?
A. Yeah. I was present there.
Q. You not only were present, but you also requested that that not be tape-recorded,
correct?
A. Probably.
Q. You dont know?
A. I dont know.
Q. Would it refresh your recollection to look at that report?
A. No. But bring it on up.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: No, he said it wouldnt.
Q. BY MR. MESEREAU: Youre not willing to look at it?
A. Its not about me willing. Im willing to look at it, but its not going to help.
Q. Well, that was last November you had that interview with your mom and these
prosecutors, correct?
A. Again, this is all difficult.
Q. I know its difficult, but youre saying you dont remember that interview?
A. You just said I met with my mo m and I was there, and I d idnt remember until you said
that, and then I remembered.
Q. Do you remember you and your mom both requested that the interview not be taperecorded?
A. I do not.
Q. Would it refresh your recollection to see what it says in the report about that?
A. Bring it over. It -- yeah. Bring it over.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. MESEREAU: Have you had a chance to look at the page of that report?
A. Yeah, I read the first paragraph.
Q. Does it refresh your recollection about you and your mother both requesting no taperecording?
A. No, it does not.
Q. Okay. You dont remember one way or the other about that?
A. Right.
Q. Okay. Okay. Now, on that particular day, and Im referring to November 19th, 2004,

you were interviewed as well, correct?

A. Was this when my mother was present?
Q. Yes.
A. Okay.
Q. Do you remember you were interviewed on that day?
A. I think I was just there for my mom.
Q. Well, actually, they interviewed your mom first and then they interviewed you second,
correct?
A. I dont remember that.
Q. Okay. They interviewed you for about an hour, didnt they?
A. They may have.
Q. Would it refresh your recollection if I show you the report about that?
A. No.
Q. Youre not willing to look at it?
A. Ill look at it. Ill look at it, but no, it probably wont.
Q. You dont remember an hour interview on November 19th, 2004?
A. Again, the issue is its all kind of blending in together.
Q. You do remember the December interview with Prosecutor Zonen, right?
A. You asked me that -Q. Yes.
A. Go ahead, ask it again. Do I remember the December interview?
Q. Yes.
A. I remember it taking place. I dont remember what specific was asked.
Q. Actually, let me clarify the date.
A. Okay.
Q. Okay. Im talking about the report. You were interviewed on October 18th, 2004, by
prosecutors, right?
A. Im sorry?
Q. You were interviewed on October 18th by prosecutors, correct?
A. Of 2004?
Q. Yes.
A. I believe that was the first time that I met these guys, but I dont know.
Q. And then you were interviewed approximately a month later on November 19th, right?
A. You got a bunch of hands raised behind you.
THE BAILIFF: Mr. Mesereau, could you check if its on? I guess they cant hear you back
there.
THE WITNESS: Sorry, thats what was kind of distracting me.
Q. BY MR. MESEREAU: I had mentioned a December date. Actually, you were
interviewed in October and November of 2004, right?
A. October, November, December. I dont know.
Q. Okay. Do you remember having Terry Cannon -A. Theyre raising their hands again.
THE COURT: Quit hitting my microphone.
MR. MESEREAU: Oh. Okay.
THE COURT: Beat the poor thing -- you know, whats happening, you have a book thats
hitting the off button. I can see from here that you cant see, maybe.
MR. MESEREAU: I think its on, but -THE COURT: Gently.

THE WITNESS: Yeah, its bad to hit mikes.

THE BAILIFF: Actually, its -- when you step back and are at a far d istance, its hard to
hear.
MR. MESEREAU: Okay.
Q. In your interview with the prosecutors on October 18th -A. This is the first one?
Q. Well, first we have 93. Then we have 94.
A. Okay.
Q. Then we have October of 2004, and then November of 2004. Okay?
A. Okay.
Q. In your interview in October of 2004, you were asked about the third incident where
you claim Mr. Jackson tickled your testicles, right?
A. I was probably asked that, yes.
Q. Do you remember you told the prosecutors it lasted for more than ten seconds, but you
dont know how much longer after that?
A. I dont remember saying that.
Q. Would it refresh your recollection if I showed you your report?
A. My report? No, it wouldnt.
Q. Well, the police reports.
A. The police report. Ill look at it, but its probably not going to help.
Q. Are you willing to give it a chance?
A. Yeah.
Q. Think it might help?
A. No. Im sorry. But you can -- Ill give it a shot.
MR. MESEREAU: Okay. May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at the page of that report?
A. I have.
Q. Does it refresh your recollection that you told the prosecutors it lasted more than ten
seconds?
A. It does not help me remember.
Q. Dont remember that at all?
A. No, but I could probably agree with it if it was in the report.
Q. Okay. Before either the October interview or the November interview with prosecutors,
did you discuss what you were going to say in any of those interviews with your mother?
A. No.
Q. You would agree that Attorney Terry Cannon was present at both the October
interview, 2004, and the November interview, 2004, right?
A. I cant remember whether he was there on the November one with me and my mom.
Q. Did you discuss what you were going to say at either interview in advance with
Attorney Terry Cannon?
A. I dont think so.
Q. How did he end up showing up for any of those interviews, if you know?
A. I think he called me and said I might be subpoenaed for this. I cant -- I think Kris
called me and said I might be subpoenaed up here.
Q. Correct me if Im wrong, I think you said yesterday that you never knew that your
mother had gotten $20,000 from the television show Hard Copy to give an interview.

A. I think youre wrong.

Q. Okay. Did you know that before you testified yesterday?
A. Yes.
Q. And when did you first learn that your mother got $20,000 to give an interview with
Hard Copy in the early 90s?
A. I think it was last Sunday.
Q. Okay. And I guess she told you that?
A. No.
Q. Shes never told you that?
A. That she received $20,000? She has never told me that.
Q. Did you know before last week that your mother had been paid to go on the television
show Hard Copy?
A. I think I assumed it.
Q. Okay. But you didnt know for sure?
A. I didnt know for sure.
Q. Never d iscussed it with her?
A. I dont think I did, no.
Q. Okay. All right. Now, you admitted that at the beginning of your first interview with
sheriffs in 93, you said that Mr. Jackson had not touched your genital area, right?
A. I said that at the very beginning.
MR. ZONEN: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: It was only after you were pushed real hard by the sheriffs that
you began to say anything like that, true?
MR. ZONEN: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: And at one point a sheriff actually used a curse word to get you
to say something, correct?
A. I dont remember that, but you could show me the thing.
Q. Okay. But as you sit here today, you dont remember, right?
A. I dont remember the four-letter word. Everybody in junior high cussed.
Q. How about the word bullshit?
A. What about it?
Q. Do you remember a sheriff telling you that?
A. I dont, but I think I remember listening to it on the tape.
Q. Do you remember in that interview one sheriff telling you, Mr. Jackson is a molester,
and the other saying, He makes great music, hes a great guy, bullshit? Do you
remember that?
A. I dont remember that specifically, but I think I remember hearing it on the tape, which
was my vo ice, or his voice.
Q. You do remember a sheriffs voice saying that, right?
A. I dont remember right now of 93, but I remember listening to the tape.
Q. Okay. And a sheriff said that to you, correct?
A. I believe so.
Q. And the sheriffs complained that, Mr. Jackson has a lot of money in that interview,
right?
A. I believe he d id say that, but can I look at the paper?
Q. Sure. May I approach, Your Honor?

THE COURT: Yes.

THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at the transcript?
A. I did.
Q. Does it refresh your recollection about what the sheriffs said to you about Mr. Jackson
in the interview?
A. I dont remember that specifically, but reading it in the transcript, I remember read ing
that in the transcript when I read it on Sunday, when I reviewed the tape.
Q. And even after sheriffs said to you, Hes a molester, hes a great guy, makes great
music, bullshit, he has lots of money, you still said he had never touched your genital
area, right?
A. I believe so. Probably towards the beginning again.
Q. Do you remember the sheriff interviewing you wanted to know whether Mr. Jackson
went under your pants or on top of your underwear, and you said, I dont know?
A. Im sorry?
Q. Do you remember the interviewing sheriff asked you, Have you ever been touched
under your pants or on top of your underwear? And you said, I dont know?
A. Were we talking about a specific incident?
Q. Im just asking about the interview.
A. Oh. Then -MR. ZONEN: Ill object as vague, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember in that interview, when you first said in
response to the sheriffs questions, Mr. Jackson touched me, you had no idea how long
he had ever touched you?
MR. ZONEN: Objection; vague. Which incident?
Q. BY MR. MESEREAU: During any incident?
THE COURT: Do you want to rephrase the whole question?
MR. MESEREAU: Sure.
Q. Do you remember in your first interview with the sheriffs when, after repeated
questioning, you finally said, Mr. Jackson touched me, do you remember not knowing
how long he had ever touched you at any time?
A. I dont remember.
Q. Okay. Do you remember telling the sheriffs that Mr. Jackson, during your tickle games,
used to pinch you in the stomach?
A. Tickling, pinching. Same thing.
Q. Okay. You did tell the sheriffs in your first interview you had never spent the night with
Mr. Jackson, right?
A. I never slept in his bed with him.
Q. Okay. When did you last talk to Attorney Terry Cannon?
A. Yesterday.
Q. Did you talk about your testimony?
A. No.
Q. Did you talk about the case?
A. Nope.
Q. Did he call you -A. Wait, actually, Im sorry, I didnt talk about the case, but I talked about I was being
nervous up here.

Q. Did you call him or did he call you?

A. He called me.
Q. When did you last talk to Attorney Terry Cannon before yesterday?
A. Um -- um, um, um, um. I really cannot remember the specific date.
Q. Now, in your interview of March 24th, 1994, you didnt remember what cartoons you
were watching when you claim you were improperly touched, right?
A. I dont know.
Q. Did you know you were being tape-recorded in that interview?
A. You know what? I dont know. Typically Id remember that.
Q. And do you remember telling the interviewers that Michael Jackson tickled you in your
stomach?
A. No.
Q. You dont remember that?
A. No. Can I review that?
Q. Sure.
A. Is that -- it was being taped then? Or you cant say. Okay, yeah.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
MR. ZONEN: What page, Counsel?
MR. MESEREAU: 58.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: You remember telling the people interviewing you that Mr.
Jackson did tickle you in your stomach, right?
A. I do not remember saying that, but I probably said that.
Q. Okay. Do you remember in that interview when you finally said Mr. Jackson had
touched your penis, that you told the interviewers, He tickled me there? Right?
A. I dont know.
Q. Do you remember you were asked, What did he do with his hands? And you said, He
tickled me. Do you remember that?
A. What did he do with his hands? And I said, He t ickled me?
Q. Yes.
A. Thats kind of vague. Like overall he tickled me, or what are you talking about?
Q. You were asked what Mr. Jackson did with your penis. Do you remember that? And you
said, He tickled me. Do you remember that?
A. He did tickle me.
Q. Okay. You were asked to describe what Mr. Jackson did with his hands, and your
response was, He tickled me, true?
A. I dont know. I was probably crying then.
Q. Would you like to review the transcript, see if it refreshes your recollection?
A. Sure.
MR. MESEREAU: Okay. May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. MESEREAU: By the way, if you dont remember the interview, how do you
know you were crying?
A. Because I usually cry when were talking about the molestation.
Q. Okay. Okay. Again, do you remember saying to the police officers in response to their
question, What did he do with your penis? You said, He t ickled me?
A. I thought you were going to bring me that thing.

Q. Would you like to see it?

A. Yes.
Q. Okay.
A. Okay.
Q. Do you remember describ ing what Mr. Jackson did as tickling?
A. Do I remember describing what Michael Jackson did as tickling?
Q. Yes.
A. Like tickling my penis or -Q. Yes.
A. Are we talking the first or second or third incident?
Q. I dont know.
MR. ZONEN: Well, Im going to object as vague.
THE COURT: The objection is sustained.
Q. BY MR. MESEREAU: Do you remember telling the interviewers in that second
interview in 1994, when they asked you what Mr. Jackson did with your penis, you said,
He didnt really touch it, he was above my shorts? Do you remember that?
A. Are we talking first or second or third?
Q. I believe you were just answering their questions.
MR. ZONEN: Objection; vague.
THE COURT: Sustained. Counsel, youre going to have to direct -- if youre going to
question in this manner, youre going to have to direct it to specific t imes. There were
three interviews.
MR. MESEREAU: Okay. Im sorry, Your Honor.
THE COURT: And youre being unfair to the witness in my opinion.
Q. BY MR. MESEREAU: Okay. Directing you to the second interview that you ever gave
about these events, okay? And that was the interview -A. In 94? 4934
Q. Yes.
A. Okay.
Q. Yes. Okay?
A. I thought we were talking about 2004. Im sorry.
Q. Okay. Thats my mistake, I apologize. Lets talk about the 1994 interview.
A. Okay.
Q. All right? Do you remember being asked the question, Did Mr. Jackson touch your
penis? And you said, He didnt really touch it, he was above my shorts?
A. I do not -THE COURT: Wait. Just a minute.
THE WITNESS: Im sorry.
THE COURT: I want you to approach.
MR. MESEREAU: Sure. (Discussion held off the record at sidebar.)
THE COURT: All right. You may proceed.
Q. BY MR. MESEREAU: Okay. Im going to try and direct my questions to a particular
interview, one of the four that you had, and direct them to one of the three events that
you have described when you claim Mr. Jackson improperly touched you, okay? Now,
directing your attention to the second interview, which is in 1994 - okay? - and directing
your attention to the first event that you have described where you claim Mr. Jackson
improperly touched you - okay? - do you remember -- excuse me. Isnt it true that, when
asked about the first event in that second interview, you said Mr. Jackson didnt really

touch your penis?

A. I dont -MR. ZONEN: What page?
MR. MESEREAU: 60.
THE WITNESS: No, I dont remember.
Q. BY MR. MESEREAU: Would it refresh your recollection if I show you a page of that
transcript?
A. Bring it over.
MR. MESEREAU: May I approach?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. I have. Well, not the tape. Ive read those two little sentences there.
Q. Does it refresh your recollection of what you told the people who were interviewing you
about that first event during the interview in 1994?
A. It does not refresh my memory. But in reading it -THE COURT: Wait. Thats the end of your answer.
THE WITNESS: Okay. Sorry.
THE COURT: Listen to the question and just 4936 answer the question asked.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: You just dont recall saying that, right?
A. Correct.
Q. Could you please describe, to the extent you remember, the sleep ing bag in the
apartment that you called the hideout?
A. Describe the bag itself?
Q. Yes. If you remember. How b ig it was, where it was, et cetera.
A. Near a window. If youre looking at the T.V., to the right of the T.V.
Q. And there was no furniture in the apartment that you remember?
A. I did not say that.
Q. Okay. What did you say?
A. I said that there was an L-shaped couch in the hideout somewhere, in the living room, I
believe.
Q. Okay. And at any time when you claim you were improperly touched, were you sitting
on the couch?
A. No, I never said that either.
Q. During the events that youve described at the hideout -A. Okay.
Q. -- where you say you were improperly tickled - okay? -A. Okay.
Q. -- were you always on top of the sleeping bag?
A. No. The first time I was on a chair.
Q. Okay. The second time you were on a sleeping bag, right?
A. Correct.
Q. Okay. Did both of those instances start out as tickle contests?
A. Yeah.
Q. Okay. And in both of those incidences that youve described, you recall it starting out
as innocent sort of tickling and leading to an improper touching, right?
A. Right.

Q. Okay. Now, youve admitted that Mr. Jackson said he would pay you money for
complet ing a book and also for getting As in school, right?
A. I remember hearing that on the tape.
Q. Do you recall Mr. Jackson saying that to you?
MR. ZONEN: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you recall being paid for reading a book?
A. I wasnt a reader.
Q. Did you ever tell Mr. Jackson, if you 4938 remember, Ive completed a book?
A. If I did, I dont know.
Q. Okay. Do you remember telling Mr. Jackson you got As in school?
A. If I did get an A, it was probably in P.E.
Q. And do you remember telling that to Mr. Jackson?
A. I dont think I ever did. I dont know.
Q. Okay. Now, without going into any amounts, when did you ever receive any money?
A. From Michael?
Q. From a settlement -A. Oh.
Q. -- in your case.
A. From the settlement?
Q. Without going into any amounts, just when did you first receive any money?
A. When I turned 18.
Q. Okay. Without going into any amounts, do you know if your mother has received any
money from
Mr. Jackson?
A. She has.
Q. Do you know approximately when she received money from a settlement?
A. I dont.
Q. Okay. Do you know if it was before you did?
A. I think it was.
Q. Okay. Have you ever been approached by 4939 anyone in the media who wanted to
talk to you about anything involving Mr. Jackson?
A. Yes.
Q. And when did that happen?
A. Geez. When I was in junior high; when I was -- shoot, in 93 -- in 93, 94 I think.
Recently. Well, actually, not recently. A couple years ago. They -- yeah, the media.
Q. Do you know how the media ever heard about you?
A. I dont.
Q. Okay.
A. Actually, I talked to a media guy once.
Q. Who was that?
A. I dont remember. He had a British accent. But I did not say anything about the case,
or anything about Michael. What -Q. And when did this happen?
MR. ZONEN: Im not sure the witness had completed his answer.
MR. MESEREAU: Oh, Im sorry, I thought he had.
Q. BY MR. MESEREAU: Were you finished?
A. No, I wasnt.

Q. My mistake.
THE COURT: Lets just stop. There wasnt any question pending. He was in a narrative for
some reason. Next question.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Do you know approximately when you spoke to a representative
of the media?
A. I dont. I know I was late to class, but I dont. I was in -- probably 92 or 93.
Q. How about in recent -- the last couple years, anyone approach you, to your knowledge?
A. Well, to my knowledge, no. They tried to, but I somehow always evade them. Not on
purpose.
It just happens.
Q. In your second interview in 1994, you were asked, Did you ever have any discussion
with Michael Jackson about whether you should tell anybody about the things you
described? Remember that?
A. (Shakes head from side to side.)
Q. You dont? Okay.
A. No, I dont.
Q. Okay. Do you remember telling the interviewers, when you were asked do you
remember anything that he said, you said, No, Im working on that?
A. No.
MR. ZONEN: Ill object as to which interview; vague.
MR. MESEREAU: In the second interview, Im sorry.
Q. In the second interview -- let me rephrase the question. Ill withdraw it. In the second
interview in 1994 - okay? -A. Okay.
Q. -- that was recorded - all right? - when asked if Mr. Jackson said anything to you about
whether you should discuss what happened, do you remember telling the interviewers,
No, but Im working on that?
A. I do not remember that.
Q. Would it refresh your recollection if I show you the transcript?
A. No. But -- you could bring it over.
Q. Well, I cant unless youre willing to see if it refreshes your recollection.
A. Okay. Bring it over. Ill g ive it a shot. Ill read it just to see if it refreshes my memory.
MR. MESEREAU: May I approach?
THE COURT: Yes.
MR. ZONEN: Page, Counsel?
MR. MESEREAU: Yes. Pages 105, 106.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to review those pages -A. I have.
Q. -- of your transcript? Do they refresh your recollection about what you said on that
subject?
A. No, it does not.
Q. It doesnt.
A. Sorry.
Q. Now, in that interview you indicated that you were aware that another boy had sued
Mr. Jackson seeking money, right?
MR. ZONEN: Im sorry, which interview? Objection.

MR. MESEREAU: Im sorry, the second -- let me rephrase it.

Q. In the second interview that you gave in 1994 - okay? -A. Okay.
Q. -- you indicated that you were aware that someone else had sued Mr. Jackson for
money, correct?
A. I dont remember.
Q. Would it refresh your recollection to look at the transcript?
A. Probably not.
Q. Okay.
A. Both of them are really blurry. It was just hard for me at the time.
Q. Well, let me ask you this.
A. Okay.
Q. Looking back, when is the first time you recall you knew someone else had sued Mr.
Jackson
looking for money?
A. Probably 16.
Q. Excuse me?
A. I was probably 16. Because thats when money started being an issue for me.
Q. Okay. Now, in your last interview with Prosecutor Zonen - and Im talking about an
interview on November 19th, 2004, okay? - Mr. Cannon was present, right?
A. I dont know.
Q. Do you recall Mr. Cannon not wanting a defense investigator present?
A. No, I dont recall.
Q. Did you know anything about that?
A. No.
MR. MESEREAU: Okay. At this time, I have no further questions, Your Honor.
THE COURT: All right. Redirect?
REDIRECT EXAMINATION BY MR. ZONEN:
Q. Mr. Francia, did you get any money from Mr. Jackson for reading a book?
A. I dont think so.
Q. Did you ever get any money from Mr. Jackson for getting As?
A. I dont think so.
Q. Were grades a problem for you when you were in school about that time?
A. Shoot, through all my whole life, grades 4944 were a problem.
Q. Did you -- do you sometimes have difficulty with reading?
A. Yeah.
Q. At this time even?
A. Yeah.
Q. All right. A lot of questions were asked of you by Mr. Mesereau that dealt with that first
interview that took place in 1993, the first time that there was a disclosure. And you
indicated, I believe, that what you said toward the end of the interview was very different
than what you said at the beginning of the interview. Would you explain that for us,
please? Why is that?
A. Why there was a difference in the beginning and -Q. Yes.
A. Because in the beginning, I thought I could hold them off and make them go away. And

they didnt go away. At all. Its kind of an issue when I was 13. I didnt want to tell
anybody that Id been molested; that I didnt want to tell anybody that anything ever
happened to me. Thats weird.
Q. Why?
A. Because youre 13. Thats weird.
Q. What were the issues that you were dealing with at that time about that?
A. In fifth grade, I told my friends that I knew Michael Jackson, and I thought it was cool.
My friends thought it was cool. They didnt believe me. But they thought it was cool. In
junior high, its no longer cool to know somebody that had issues with kids, because then
theyre going to make fun of you. And even at the church, they made fun of me. At the
church, worse than school, they made fun of me.
Q. And you were actually teased?
A. Yeah.
Q. You said yesterday to one of Mr. Mesereaus questions that you told the detective, No,
Im not gay. Did you make that statement to them?
A. I remember listening to it in the tape. I dont recall saying that. But I remember
listening to it on the tape.
Q. Do you recall whether or not that was an issue for you during the course of that
interview, that that was one of your concerns, that people would see you as that?
A. Yes. That was a concern of mine.
Q. You mentioned yesterday to one of Mr. Mesereaus questions that the defendant put
the money down your pants. Would you describe that for us?
A. What do you want to know?
Q. Where did the money go? In other words, 4946 when he -- when he gave you money,
did he hand it to you, or did he do something else? And if so, tell us what that is.
A. He put the money in my shorts, because I pulled it out, and thats when my mom saw - noticed that I had pulled money out of my shorts and she asked me where I got it from.
Q. Do you remember which of the three occasions this was?
A. I cant remember whether it was the first or the second.
Q. But this was back when you were young?
A. Yeah.
Q. Seven or eight?
A. Seven or eight.
Q. You say in your shorts. What are we talking about? In a pocket?
A. I dont think my mo m put pockets on the shorts.
Q. That was a little more complicated?
A. Shes a good seamstress, but I dont think for shorts.
Q. Tell us as best you can recall where would that money have been.
A. That would have been in my shorts.
Q. Im sorry?
A. It would have been in my shorts.
Q. In the inside?
A. In the inside.
Q. Do you know if the money was in your underwear?
A. I dont. I dont know.
Q. Mr. Mesereau asked you yesterday questions about whether you talked to your mother
about what had happened, and if so, to what extent. Did you ever have a conversation
with your mother where you told her that you were molested?

A. I think I told her that I was molested in counseling, because then she shared that she
was molested as well.
Q. Okay. Did you ever tell her the details of the molestation?
A. No.
Q. What had happened, how it happened, how often it happened, any of those types of
details?
A. I dont think so.
Q. To this day, have you ever?
A. To this day. My wife found out on the stand.
Q. The details you had not yet told your wife?
A. Right.
Q. Have you ever told anybody the details other than your therapist?
A. My pastor.
Q. Your pastor?
A. And I dont think I told him the details.
MR. ZONEN: Thank you. I have no further questions.
THE COURT: Recross?
MR. MESEREAU: No further questions, Your Honor.
THE COURT: All right. You may step down.

KRIS KALLMAN EXAMINATION

DIRECT EXAMINATION BY MR. SNEDDON:

Q. Youre an attorney?
A. Yes.
Q. Licensed to practice in the State of California?
A. Yes, sir.
Q. And what is your brief educational background to prepare you for the practice of law in
the State of California?
A. Well, I graduated from Santa Barbara High School. Went to Santa Barbara City College.
Graduated from Cal Poly San Luis Obispo. Went to Pepperdine University Law School.
Q. Do you have a certain area of law that you specialize in?
A. Yes. I am a civil trial lawyer, and for the most part, I represent people that get injured
due to the fault of another person or company.
Q. How long have you been practicing law in the State of California?
A. 29 years.
Q. And how long have you lived in Santa Barbara County?
A. My whole life, except when I was away at college.

Q. And where do you live in Santa Barbara County?

A. I live in Santa Barbara, on the mesa, in the city.
Q. Now, during the time that youve practiced law in Santa Barbara County, have you had
associates that have practiced with you in your firm?
A. Yes.
Q. Are you a sole practitioner?
A. Essentially. Although I currently have two lawyers that office with me and they act as
of counsel. Theyre not employees, but they help me out on cases.
Q. Are you familiar with an attorney by the name of Terry Cannon?
A. I sure am.
Q. And how long have you known Mr. Cannon?
A. Oh, Ive known Mr. C annon for at least 20 years.
Q. And at some point in time prior to today, was Mr. Cannon one of the people who was
associated with you in the practice of -- your civil pract ice?
A. Yes.
Q. And during what period of time was that; do you recall?
A. Well, the relevant period here would have been in the early to mid 90s.
Q. And at that time Mr. Cannon was practicing with you?
A. He was associating with me on certain cases.
Q. And do you recall where Mr. Cannon was residing at that particular point in time?
A. I believe he was living in Santa Barbara.
Q. Now, at some later time, did Mr. Cannon leave your association and take up the
practice of law somewhere else?
A. Yes.
Q. To your knowledge, where was that?
A. In Oregon.
Q. And then after that, did Mr. Cannon come back?
A. He came back to San Luis Obispo County, and then moved to San Diego County.
Q. And at this particular point in t ime, do you know where Mr. Cannon is?
A. Not exactly this moment. But I happen to know that he bought a condominium here in
Orcutt.
Q. And is he, once again, associated with you in the practice of law?
A. Yes, sir.
Q. Now, did you have occasion to represent Jason Francia in some lit igation?
A. He and his mother, yes.
Q. And can you tell us, did you ever prepare a lawsuit on behalf of Jason Francia?
A. We prepared a Complaint, which is a document thats the beginning of a lawsuit, yes.
Q. And when you say we, whos we?
A. Mr. Cannon and myself.
Q. So Mr. Cannon was working with you on that 4952 particular case?
A. Yes, sir.
Q. And after the preparation of that document -- well, with regard to that document, what
were the allegat ions set forth in the proposed Complaint to be filed?
A. Well, its been -MR. MESEREAU: Objection. Hearsay; relevance.
THE COURT: Sustained.
Q. BY MR. SNEDDON: Who was the individual that the Complaint was directed towards?
A. Mr. Jackson.

Q. At some point in time, did you have contact with individuals who were representing Mr.
Jackson over the proposed filing of the criminal -- of the civil comp laint?
A. Yes.
Q. And who did you make contact with?
A. Init ially our contacts were with Johnnie Cochran and his associate, Carl Douglas.
Q. Do you recall approximately when it was when you first made contact with Mr. -- or
when contact was made between you and Mr. Cochran and Mr. Douglas?
A. It was either late 94 or early 95.
Q. Did you, after your conversations with those individuals, file the civil lawsuit?
A. No.
Q. At some point in time later, were you then dealing with other lawyers with regard to
the proposed filing of that civil lawsuit?
A. Yes. At some point, Mr. Jacksons representation was assumed by a lawyer named Zia
Modabber, and a lawyer named Howard Weitzman.
Q. And do you recall approximately when it was that you then began contact with those
particular individuals?
A. I believe it was in mid 1995.
Q. And the purpose of those contacts?
A. Well, the -MR. MESEREAU: Objection. Vague; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: The purpose of the contacts was that they knew that we had a Complaint
that we were about to file in Santa Barbara County Superior Court, and they didnt want
us to do that.
MR. MESEREAU: Objection. Hearsay; foundation.
THE COURT: The answer is stricken. Sustained.
Q. BY MR. SNEDDON: As a result of the conversations between these individuals, did
you pursue your lawsuit?
A. Well, we never filed the lawsuit.
Q. Did you reach an agreement, a settlement agreement?
A. Yes, we did.
Q. Did you reach a settlement agreement in which Jason Francia received monetary
compensation from Mr. Jackson?
A. Yes, sir.
Q. Did you receive -- did you reach an agreement in which Blanca Francia received
monetary compensation from Mr. Jackson?
A. Yes, we did.
Q. During the time that you were representing -- during the time that you had prepared a
Complaint ready to be filed and you were in contact with attorneys representing Mr.
Jackson, can you give the lad ies and gentlemen of the jury an idea of how old Jason
Francia was at that particular point in time?
A. Well, he was about 14 years old. Hes 24 now, as I understand it, and were talking
about things that happened just about exactly ten years ago.
Q. And in your position as a civil litigator, at the time that an individual is of minority, at
the age of 14, how do you deal with representing a person like that?
A. Well, a child -MR. MESEREAU: Objection. Vague; foundation; relevance.
THE COURT: Overruled. You may comp lete your answer.

THE WITNESS: A child, under California law, under the age of 18, is not permitted to
enter into a contract. I suppose he or she could, but it wouldnt be enforceable. So the
only way a child can act legally is through a guardian ad litem. And its normally the
parent and normally the mother.
Q. BY MR. SNEDDON: Was that the case in this particular instance?
A. Yes.
Q. Now, during the course of the time that you were invo lved in obtaining a settlement
from Mr. Jackson on behalf of the Francias, did you deal personally with Jason at any
time?
A. Yeah. Sure.
Q. In what respect?
A. Well, I knew who he was, I met with him. I met with he and his mom. He was a
teenaged boy, and a nice young man.
Q. Now, at some point in time was Jason required to sign some kind of documents in
conjunction with the settlement?
A. Yes. When he turned 18, part of the condition was that he sign a confidentiality
agreement.
Q. Now, with regard to the confidentiality -- and to your knowledge, did he sign that?
A. Yes.
Q. And with regard to the confidentiality agreement, did it have a provision that required
notice to Mr. Jackson in the event that Jason Francia talked to anybody?
MR. MESEREAU: Objection. Leading; move to strike.
THE COURT: Overruled. You may answer.
THE WITNESS: I believe so, yes.
Q. BY MR. SNEDDON: And what was the requirement notice in the confidentiality
agreement with regard to notice to the defense?
A. I believe its five days.
Q. And were you at some point contacted by Mr. Zonen of our department with regard to
interviewing your -- Jason Francia?
A. Yes.
Q. And in that particular case, did you indicate to Mr. Zonen that you would have to do
something before you could agree with that?
A. Yes.
Q. And what was that?
A. Well, Id have to notify somebody on Mr. Jacksons legal staff that they wanted to talk
to him.
Q. And did you do that?
A. Yeah. Yes. Excuse me.
Q. And did you then grant permission for Mr. Zonen to have a conversation with your -with Jason Francia?
A. Yes.
Q. Now, were you present during the conversations between Jason Francia and Mr.
Zonen?
A. I dont think so. I think I was there, and then I think I had to go to another court or
something like that. I dont remember being an integral part of any of those -- if there
was more than one, I dont even know.
Q. And Im talking about the conversations that occurred after you gave notice to the
defense in this case, or gave notice to Mr. Jackson. To your knowledge, was Mr. Cannon

present?
A. I believe so. At least for part of it. Again, Im not certain.
Q. Do you remember when it was that you finally -- the year that you finally reached a
settlement agreement with Mr. Jackson?
A. Yes. Its been a long time. But it was a big deal. And I do remember -MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: The answer is stricken. Nonresponsive.
Q. BY MR. SNEDDON: Just -A. Yes.
Q. And what year was that, approximately?
A. It was either 95 or 96, I believe.
THE COURT: Counsel, well take our break.
THE COURT: Counsel?
MR. SNEDDON: Your Honor, Ive just about completed my examinat ion. But I would
request if we could approach the bench for just one second. I dont want to run afoul of
the Court.
THE COURT: All right. (Discussion held off the record at sidebar.)
THE COURT: (To the jury) All right. Knock it off. (Laughter.)
THE COURT: Okay. Counsel, you may proceed.
MR. SNEDDON: All right.
Q. Mr. Kallman, I think I just have a couple questions left. I think where we were headed
before the break was you told us the approximate year in which the case actually reached
a settlement. And what I wanted to know was, after the settlement of the case, have you
kept in contact with Jason over the years?
A. Yes.
Q. And to your knowledge, has Mr. Cannon kept in contact with Jason over the years?
A. I believe so.
Q. Now, with regard to the lawsuit that was contemplated ag ainst Mr. Jackson at the time,
the basis of the -- of the nature of the representation of Jason Francia involved
inappropriate sexual conduct against Jason by the defendant, Mr. Jackson?
A. Yes.
MR. SNEDDON: Nothing further, Your Honor.
THE COURT: Cross-examine?
MR. MESEREAU: Yes, please. Your Honor.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. My name is Thomas Mesereau and I speak for Mr. Jackson.
A. Pleasure to meet you.
Q. I want to ask you some questions about the settlement agreement you referred to in
response to the prosecutors questions, okay? First of all, you had separate settlement
agreements for the mother, Blanca Francia, and the son, Jason Francia, correct?
A. I believe so. I can tell you, I have not reviewed this material and its been ten years,
but I believe that was the case. Some of this Im going to have to take your word for it.
Q. Well, I can show you a copy if you need it.
A. I dont disbelieve that.
Q. Okay. The settlement agreement with Blanca Francia was entered into approximately
April 1st, 1996, right? 4966

A. I dont know.
Q. Would it refresh your recollection if I show you a copy of the agreement?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Thats what it says.
Q. BY MR. MESEREAU: The settlement agreement with Jason Francia was entered into
approximately June 1st, 1998, right?
A. Dont know.
Q. Would it refresh your recollection if I just show you a copy of it?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Thats what it says.
Q. BY MR. MESEREAU: Okay. Now, that would suggest, wouldnt it, that the mother had
agreed to get money for herself before there was any agreement for Jason to get money
in a settlement, right?
A. No, it was all part of one global settlement.
Q. Then why would there be a two-year difference between the execution of those
settlement agreements?
A. Remember when I told the jury that a minor cant enter into a contract? 4967
Q. Yes.
A. Jason wouldnt have been able to sign before he was 18. My guess is thats probably
when he turned 18, and thats what Mr. Weitzman and Modabber wanted.
Q. And then just for the jurys benefit, why would the mother sign in 96?
A. She was an adult. She could sign.
Q. The point Im making is that she had a separate settlement from her son.
A. Exactly. I mean -- yes. She got money.
Q. Yes. Okay. Now, the prosecutor asked you some questions about provisions in the
settlement agreement, okay? And one of the issues that was carefully negotiated by the
people representing Mr. Jackson was that he deny any wrongdoing in that agreement,
right?
A. Again, the best evidence of that would be whats in the agreement. I dont remember
whats in there.
Q. Okay. Well, let me -- the prosecutor read you a provision, asked you about it. Let me
ask you about this: There was language in that agreement that said, The parties
acknowledge that Jackson has elected to settle the claims solely in view of the potential
impact any litigation could have in the future on his reputation, earnings and potential
income, and not because of any alleged wrongful conduct on his part, right?
A. If youre asking me if thats in the document, Ill have to take your word for it. You
dont need to show it to me. It sounds pretty standard to me.
Q. The agreement further said -- excuse me, let me rephrase that. Both agreements, the
one involving Jason and the one involving Blanca, his mother, both had language which
said, This agreement shall not, in any manner, be construed as an admission by Jackson
that he has acted wrongfully with respect to Francia, B lanca, or any other person, or at all,
or that Francia or Blanca have any rights whatsoever against Jackson or Jacksons
releasees. Sound familiar to you?
A. It sounds like standard language in virtually every release that I deal with. But, yes, it

does sound familiar.

Q. Actually, theres a whole separate paragraph entitled, Denial of Claims by Mr.
Jackson, correct?
A. Dont know.
Q. Would it refresh your recollection if I show you a copy?
A. It would.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: It does refresh my recollection.
Q. BY MR. MESEREAU: Okay. And do you recall that language being in both agreements?
A. I believe so, yes, sir.
Q. Okay. In addit ion to the language that I have read, theres further language which
says, Jackson specifically disclaims any liab ility to, and denies any wrongful acts against,
Francia, Blanca or any other person and may continue to do so publicly, to the extent
reasonably necessary, to respond to any inquiries in this regard. Right?
A. Correct.
Q. It said further, The parties acknowledge that Jackson is a public figure, and that his
name, image and likeness have commercial value and are an important element of his
earning capacity. R ight?
A. Thats true.
Q. And that language was in both settlement agreements, the one involving Blanca
Francia and the one involving Jason Francia, correct?
A. I dont remember that. I will take your word for it. You dont need to refresh my
recollection. It sounds like it should be or would be.
Q. Now, Mr. Kallman, provis ions in which a settling party denies liability are fairly standard
in settlement agreements, right?
A. True.
Q. But the language that I just read to the jury is not standard language in a settlement
agreement, is it?
A. This is not a standard case, or was not. And no, youre right. These were carefully
drafted by a team of lawyers, and we agreed to the terms.
Q. And the reason those terms are different is because Mr. Jackson is an unusual
individual in terms of his need to preserve his reputation and public image so he can earn
a living, right?
MR. SNEDDON: Calls for speculat ion on this. It wasnt drafted by him. No foundation.
MR. MESEREAU: I think it was drafted by this witness.
THE COURT: All right. Ill sustain a foundation.
MR. MESEREAU: Okay.
Q. When you settled these matters - and Im talking about matters involving Michael
Jackson, Blanca Francia, and Jason Francia - you put in language involving denial of claims
by Mr. Jackson that was not standard language in a typical settlement agreement, right?
MR. SNEDDON: Your Honor, Im going to object to the question as lack of foundation;
that he put the language in there.
THE COURT: Well, that was the foundation I was looking for. So Ill allow you to answer
the question as long as you understand the limitations of your answer.
THE WITNESS: Well -THE COURT: If you put the language in.
THE WITNESS: I didnt draft that agreement.

THE COURT: Okay.

Q. BY MR. MESEREAU: Did lawyers from your office draft the agreement?
A. No.
Q. Who drafted the agreement?
A. Somebody in Mr. Modabbers office, the Katten, Muchin, Zavis & Weitzman firm in
Century City.
Q. Did you have any input into the language in the agreement?
A. Only to review it. And if there was language we found objectionable, we could strike it,
I suppose.
Q. Okay.
A. But they wanted that in there, and I didnt find it objectionable.
Q. Okay. Now, you made a statement, I believe, in response to the prosecutors
questions, that if someone from law enforcement wanted to speak to your client, you had
to first notify representatives of Mr. Jackson, true?
A. True.
Q. That -- really, that language is not in that agreement, is it?
A. I dont know.
Q. Then why would you say it?
A. Because thats part -- in one of the agreements, I have to give notice to the defense
team. And Ive given notice once to Mr. Sanger. And then when I got subpoenaed on
Friday, I gave notice to Mr. Modabber down in Los Angeles.
Q. But the notice youre supposed to give to the defense team does not involve requests
by law enforcement to speak to your client, does it?
A. I assume that anybody from law enforcement that wants to talk to my client, there was
a requirement to notify somebody from the defense team.
Q. Nowhere in those settlement agreements is there language to that effect, is there?
A. I have no idea.
MR. SNEDDON: Object as immaterial; irrelevant.
MR. MESEREAU: The prosecutor brought it up on direct, Your Honor.
THE COURT: The objection is overruled. And the answer came in as, I have no idea.
Q. BY MR. MESEREAU: It would be against public policy for a civil litigator to put
language in a settlement agreement preclud ing anyone from cooperating with law
enforcement, wouldnt it?
A. In my opinion, yes.
Q. Lawyers are not allowed to have language like that in settlement agreements, right?
A. Wrong.
Q. Pardon me?
A. No. Its a notice requirement. Its not a preclusion requirement.
Q. When did you last review the notice provisions in these agreements?
A. Probably in 1996 or 1997.
Q. Well, let me ask you this question: Did you talk with Mr. Sneddon about what questions
he was going to ask you before you testified today?
A. No. I mean, we talked, but it was very, very general and I dont think the conversation
was more than five or ten minutes long.
Q. Okay. The notice provis ions that you describe talk primarily about anyone whos suing
Mr. Jackson or if hes contacted by the media, correct?
A. I dont -- not the notice provisions Im thinking about. I think theres a specific
provision -- it may not be in that agreement. Maybe its in another agreement, but theres

a provision that Im supposed to contact either Johnnie Cochran or Zia Modabber or

somebody on the defense team if there was a request to speak or interview my clients.
Q. But never in the agreement did it refer to law enforcement, right?
A. That I dont remember. Its been a long time.
Q. Okay. Okay. Now, you answered some questions about Terry Cannon.
A. Yes, sir.
Q. When did -- excuse me, youre currently associated with Mr. Cannon, correct?
A. He is of counsel to my law firm.
Q. When did he become of counsel to your law firm.
A. Hes been of counsel twice. Once about ten years ago, during this period, and then
again just recently, within the last two months.
Q. So he wasnt of counsel to your law firm in October, November and December of last
year, right?
A. I dont believe so, but I cant be sure.
Q. During October, November and December of last year, he was with the District
Attorneys Office in San Diego, wasnt he?
A. Well, I know he recent ly ret ired from the San Diego D.A.s Office. I dont know precisely
when he retired, but youre right, its been recent.
MR. MESEREAU: Okay. No further questions, Your Honor.
MR. SNEDDON: No questions, Your Honor.
THE COURT: All right. Thank you. You may step down.

BLANCA FRANCIA EXAMINATION

DIRECT EXAMINATION BY MR. ZONEN:

Q. Do you currently live in Santa Barbara County?
A. Yes.
Q. Up in the North County area?
A. Uh-huh.
Q. Are you the mother of Jason Francia?
A. Yes, I am.
Q. What kind of work are you currently doing?

A. Caregiving.
Q. All right. What we need to do, we have a problem here. And its not just with you, a lot
of witnesses. You have to be as close as you can get to the microphone so that you can be
heard all the way to the back of the courtroom. Okay?
A. Okay.
Q. All right. Are you the mother of Jason Francia?
A. Yes.
Q. And what kind of work are you currently doing?
A. Caregiving.
Q. Im sorry?
A. Caregiving.
Q. And what does that mean, a careg iver?
A. Taking care of elderly people. Disabled.
Q. Do you have a couple clients who you work for?
A. Yes.
Q. And are they disabled in some fashion?
A. Yes. I deal with one six years, almost six years, yeah.
Q. Okay.
A. And another one just recently, about a couple of months.
Q. And how long have you been doing this kind of work?
A. On and off, Ive been doing it for about 15 years.
Q. And prior to that, what kind of work did you do?
A. Housekeeping. Housecleaning.
Q. And for what period of time did you do that work?
A. Since I came to the country.
Q. When did you come to the United States?
A. 1975.
Q. And from what country did you come from?
A. El Salvador.
Q. You have been to -- in this country continuously since 1975?
A. Yes.
Q. Have you been back to El Salvador to visit at all?
A. A couple of times.
Q. Your English, how did you learn English? Did you go to school?
A. No.
Q. How did you learn English?
A. Reading, and listening to people, and thats -Q. How old were you when you came to this country?
A. About 21.
Q. Okay. Do you know Mr. Jackson, Michael Jackson?
A. Yes.
Q. Do you see him in this courtroom?
A. Yes.
Q. Would you indicate where he is sitting, please?
A. Hes sitting right there.
MR. ZONEN: Your Honor, could the court record reflect that the witness has identified the
defendant?
THE COURT: All right.

Q. BY MR. ZONEN: How do you know Mr. Jackson?

A. I work -- work about five years.
Q. When did you begin working for Mr. Jackson?
A. 1986.
Q. And where did you begin working for Mr. Jackson, at what locat ion?
A. Havenhurst. Encino, California.
Q. Havenhurst is the name of the street?
A. Yes.
Q. And was there a house on that street -A. Yes.
Q. -- where he lived? All right. What were you doing for Mr. Jackson at the Havenhurst
residence?
A. I was hired to be his personal housekeeper.
Q. Were there other members of the Jackson family living at the Havenhurst residence?
A. Yes.
Q. Can you tell us who they were?
A. At that time Janet and LaToya, and his father and mother.
Q. Would you describe the Havenhurst residence for us, just briefly? A large home?
A. Their whole house? Yeah. He has his separate quarters in the house. But it was in the
same house.
Q. Okay. Was it a large home?
A. Yes.
Q. And his quarters, were you responsible for just his quarters or did you clean in the
whole house?
A. Well, yes, just his quarters. His place. But eventually when he will go out on tour, I will
stay at the house and help the household.
Q. You would clean the rest of the house as well?
A. Uh-huh.
Q. Did Mr. Jackson ever have an add itional residence other than the residence on
Havenhurst?
A. After I was there for about a year, I think, or less than a year, he got another one. Like
-- kind of an apartment, suite. Called it The Hideout.
Q. Where was that; do you know?
A. I know its on Wilshire. And I dont know the other street.
Q. And describe that location for us, if you would.
A. What do you mean?
Q. Tell us what it was like, his apartment.
A. Oh.
Q. Or his residence. How many rooms in it; do you know? Do you recall?
A. Three. It had a master bedroom, and two other rooms, bedrooms.
Q. Did it have a living room?
A. Yes.
Q. I assume a kitchen?
A. Kitchen, and another little room.
Q. Okay. At least a couple bathrooms?
A. I dont remember.
Q. You dont recall -A. No.

Q. -- how many bathrooms?

A. I dont remember.
Q. Its okay. Do you recall for what period of time you cleaned that residence?
A. For about a year.
Q. Was he living at that residence during that time, Mr. Jackson?
A. Yeah, he totally move his -Q. Im sorry?
A. He totally move from Encino to that hide -to that place. He move his office to -- to near that location.
Q. Okay. Was there a bed at that residence?
A. No.
Q. Never?
A. Never.
Q. The whole time that you were cleaning there?
A. Yeah.
Q. Okay. Did you go to a different location after the hideout? Was there yet another
residence?
A. Yeah, he was in process to get a ranch.
Q. Okay.
A. In Los Olivos.
Q. And was that Neverland?
A. Yeah.
Q. Was that the ranch that he actually did purchase?
A. Uh-huh. Yes.
Q. Did he move to that ranch?
A. Eventually, yeah. But he was on and off. They sent me over here before he moved in. I
mean -Q. Im not sure I understood that, They sent me over here before he moved in. Who is
they, first of all?
A. Well, they arrange, Mr. Jackson and Bill Bray and one of the secretaries.
Q. Okay. B ill Bray was who?
A. His personal assistant I guess.
Q. All right. And you said, They sent me here. Where is here?
A. Santa Maria.
Q. Santa Maria. So did you actually move to Santa Maria?
A. Yeah. They pay me to move here.
Q. And did you move with your child?
A. Yes.
Q. Is Jason your only child?
A. My only son.
Q. Did Jason grow up with his father at all?
A. No.
Q. Has he had contact with his father at all?
A. No.
Q. How old was Jason when you moved to Santa Maria?
A. I guess about nine.
Q. About nine years old?

A. Eight or nine, yeah.

Q. Okay. Did you continue working for Mr. Jackson after you moved to Santa Maria?
A. Excuse me?
Q. Did you continuing to work for Mr. Jackson -A. Yes.
Q. -- after you moved to Santa Maria?
A. Yes.
Q. And was that at Neverland?
A. Yes.
Q. All right. What were your responsibilit ies at Neverland? W hat did you do for Mr.
Jackson?
A. To clean his room.
Q. Im sorry?
A. To clean his bedroom. And taking care of his clothes and his personal stuff.
Q. All right.
A. His -- all his -- you know, whatever he needed. And to clean up and arrange all his
clothes, press them, iron them, and, you know, everything.
Q. What was your schedule at Neverland? How often did you work there?
A. In the beginning, I think I was just -- he was there, I will come, you know, and work
for three days, whatever time he will stay there, and then, you know, not to be there for
another two days. But eventually he move to -- like to 9:00 to 5:00.
Q. Five days a week?
A. Five days a week. Six days.
Q. Six days? Did you ever work more than 9:00 to 5:00?
A. Yeah.
Q. Your hours, times, would they vary different days?
A. Yeah. Christmastime and -- you know, whatever time they needed me, because he was
there.
Q. Were there occasions that you would work late?
A. Yes.
Q. And you say six days a week. Was that common?
A. Was that what?
Q. Was that a common event, that you would work six days a week?
A. Yeah.
Q. Okay. During that time, did you ever bring Jason with you to work? And by this time,
Im referring to at Neverland.
A. Yes.
Q. Okay. Did you ever bring Jason to work with you at the Havenhurst residence in
Encino?
A. Yes, it was.
Q. Did you ever bring Jason to work with you at the hideout on Wilshire Boulevard?
A. Yeah.
Q. And why did you do that?
A. Well, the first time I didnt know that I was allowed to do it. But Mr. Jackson asked me
to -- to bring him.
Q. You said the first time. Where was that?
A. At the Encino house.
Q. At the Encino house?

A. Yeah.
Q. Did he say why?
A. He just told me to bring him.
Q. Okay. And did you bring him on occasion?
A. Yeah. From then on, he was there a lot of times.
Q. Okay. How often would you bring him to the residence at Encino?
A. Probably every weekend. And probably twice a month, then, different -- differently. I
dont remember.
Q. Was that schedule more or less at the hideout? Did you bring him to the hideout as
often? More often?
A. Uh-huh.
Q. Less often? What?
A. Not a lot of times, because he was in school, so probably on Saturday or Sundays.
Q. Did you continue cleaning at the hideout even after Mr. Jackson moved to Neverland in
88?
A. Yes.
Q. How often?
A. Probably every week. Sometimes twice a week.
Q. At Neverland, what were your specific responsibilities? What were your obligations?
What did you do at Neverland?
A. Do you mean for him?
Q. Yes, for Mr. Jackson. Yes.
A. Like I said, taking care of his clothes, his room.
Q. Okay.
A. And right after he leave the room, I will have to clean it right away, because sometime
he will stay there, you know, hell come out, and then hell go back in right away.
Q. Okay. Were your responsibilities beyond his room as well? In other words, did you
clean the rest of the house?
A. Yes.
Q. Did you ever clean other buildings at Neverland?
A. Yes.
Q. The arcade?
A. The arcade, yeah.
Q. The theater?
A. The theater.
Q. Okay.
A. Yeah.
Q. Most of the time where d id you work?
A. In the house.
Q. Were there other maids at Neverland -A. Yes.
Q. -- who were -- there were other maids at Neverland?
A. Yes.
Q. Yes, all right. At any given time, how many maids were working at Neverland at any
given time?
A. Maybe about six.
Q. Were there others who had responsibility for cleaning Mr. Jacksons bedroom?
A. No.

Q. You were the only one?

A. Yeah.
Q. Did you have a key?
A. Yes.
Q. Is that the only way you got in?
A. Yeah.
Q. Was there a combination lock at any point?
A. No.
Q. Not while you were there? Is that a key that you carried around with you?
A. Yes.
Q. Okay. Would you just let yourself in?
A. Yes.
Q. How would you announce your presence? How would you let Mr. Jackson know you
were coming in, if, in fact, he was there?
A. Ill knock.
Q. Uh-huh. Now, could you describe the suite that is his bedroom? Its actually more than
one room; is that right?
A. Yeah. Its two rooms. One downstairs and one upstairs.
Q. And is there a hallway that goes into it?
A. Closet.
Q. Im sorry?
A. A closet.
Q. Theres a closet, okay.
A. Yeah.
Q. When you go -A. A walk-in closet.
Q. When you go into his suite, do you go through a door that is locked?
A. No.
Q. All right. Is there any way of securing his bedroom suite?
A. Well, his bedroom suite, with a key -Q. Yes.
A. -- that I would have.
Q. Where is that door, the one that you unlock with the key that you carry?
A. In the hallway.
Q. In the hallway?
A. Yeah.
Q. So you unlock that door and you go through that door. And where do you find yourself
at that point?
A. Yeah.
Q. Im sorry?
A. Yes.
Q. Where are you? As soon as you walk through that door, the door that you unlock,
where are you at that point? Are you in a room or a hallway?
A. In the bedroom.
Q. In the bedroom, all right.
A. Uh-huh.
Q. Was there at that time some kind of an alarm or a bell?
A. Yeah, thats before you get to the door.

Q. Before you get to the door?

A. Yeah, thats in the hallway.
Q. All right. And you would announce your presence when you came in?
A. Yeah.
Q. Were there ever occasions that you would announce your presence and Mr. Jackson
would be in the room?
A. Yeah.
Q. Were there ever occasions where you would announce your presence and he wasnt
there?
A. Yeah.
Q. Did you try to go to his room when he wasnt there to clean?
A. When he was there? When he wasnt?
Q. Yeah, what did you try to do, what was your preference? To clean while he was there,
or to clean while he wasnt there?
A. Ill -- well, sometimes hell be there and Ill be cleaning.
Q. Uh-huh.
A. It didnt matter.
Q. Okay. Where was his bed, incidentally, at that time? Where did he sleep?
A. As soon as you came into the bedroom, thats his bed.
Q. So his bed was downstairs?
A. Yes.
Q. Was there another bed upstairs?
A. Yes.
Q. Which bed did he sleep in?
A. Downstairs.
Q. And you would make -A. Most of the -Q. And you would make that bed; is that right?
A. Yes.
Q. All right. Did he ever have vis itors over at his home?
A. Yeah.
Q. Visitors who stayed?
A. Excuse me?
Q. Visitors who stayed for periods of time?
A. Yes.
Q. Did you know a person by the name of Wade Robeson?
A. Yeah.
Q. Who was Wade Robeson?
A. He was a young kid, a young little boy.
Q. How old was Wade Robeson when you first met him?
A. Probably eight. Seven or eight.
Q. Do you know where Mr. Robeson -- where Mr. Robeson - an eight-year-old - where
Wade Robeson came from?
A. Yes. From a different country. I mean, from another country. Switzer -Q. Do you know which country?
A. No, I dont remember.
Q. But you recall that it was from a different country?
A. Yeah.

Q. Was it an English-speaking country or a country with a different language?

A. Different language.
Q. Did you ever talk to Wade Robeson?
A. A little bit.
Q. Was he there with family?
A. With his mother.
Q. Do you remember -A. I think he has a little sister. I dont remember.
Q. All right. Did Wade Robeson -MR. MESEREAU: Objection. The prosecutor didnt let the witness finish.
MR. ZONEN: Im sorry, I thought she had.
Q. Please go ahead, if you hadnt finished that answer.
A. Excuse me?
Q. I think you said he has a little sister? 4993
A. Yeah. I dont remember, tell you the truth.
Q. Do you have a recollection of a sister?
A. I -- you know, I dont remember, tell you the truth.
Q. Do you remember his mother?
A. His mother, yeah.
Q. Where did she stay when they were there?
A. In the guesthouse outside. They call them the guest quarters.
Q. The guest quarters?
A. Uh-huh.
Q. Do you remember if Wade Robesons father was there?
A. No.
Q. Where did Wade Robeson stay?
A. In Mr. Jacksons room.
Q. All right. In the bedroom?
A. Yeah.
Q. For what period of time was Wade Robeson visiting Mr. Jackson?
A. Weeks.
Q. Weeks?
A. Yeah.
Q. When he would come, would he stay -- whats the longest that he would stay at any
one time?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
MR. ZONEN: Well, let me ask a couple 4994 preliminary questions.
Q. Youve already told us that you cleaned Mr. Jacksons room.
A. Yes.
Q. Were you the only one who cleaned Mr. Jacksons room?
A. Yes.
Q. Did you go into Mr. Jacksons room daily, every s ingle day, when you were working?
A. Yes.
Q. Were you working at that period of time, as you said, at least five and sometimes six
days a week?
A. Yeah.
Q. Would you be the first one in his room in the morning?

A. Yes.
Q. Would you have to fix his bed?
A. There were times when nobody knew that he was going to be there, and they call me
at home, telling me, Hes here, and so you have to come and clean up.
Q. Did you see Wade Robeson there?
A. Yeah.
Q. All right. Did you see him there for days at a time?
A. Yeah. Yes.
Q. Did you see where he was staying?
A. Yes.
Q. Okay. Where was he staying?
A. In Mr. Jacksons room.
Q. All right. Did you see Wade Robesons belongings?
A. Yeah.
Q. What kind of belongings did he have?
A. He had clothes, little suitcase, kids suitcase, and his clothes in there.
Q. All right. Would you wash Michael Jacksons clothing as part of your job?
A. Yeah.
Q. Did you wash Wade Robesons clothing?
A. As well, yes.
Q. Always?
A. Yes.
Q. Whenever he was there?
A. Yes. I find them on the floor, so Ill -- Ill wash them.
Q. And his clothing was found on the floor in where?
A. Different places.
Q. Whose room?
A. Mr. Jacksons room.
Q. All right. Would you find Mr. Jacksons clothing there as well?
A. Yes.
Q. And that was your responsibility, your job, to simply gather up the clothing and launder
it?
A. Yeah. Yes.
Q. And then return it to his room?
A. Uh-huh.
MR. MESEREAU: Objection. Leading; move to strike.
THE COURT: Its lead ing; sustained. Stricken.
Q. BY MR. ZONEN: Was there a place that -- where you kept Wade Robesons clothing
after you laundered it?
A. No, I put them together with his clothes and in his case, his little suitcase.
Q. Now, tell us how often Wade Robeson came to visit. I have two questions and well do
one at a time. Let me tell you both of them. How often he came, and how often -- how
long he stayed each time he came. So lets start with the first one. How often did he
come, Wade Robeson?
MR. MESEREAU: Objection; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: How often did he come?
Q. BY MR. ZONEN: How often did he come to Neverland to visit Mr. Jackson?

A. Uh -MR. MESEREAU: Vague as to time; objection. 4997

THE COURT: Sustained.
Q. BY MR. ZONEN: Well, tell me when he first came. You said he was eight years old. Do
you rememb er what year that was? Excuse me.
A. Probably -Q. Im sorry.
A. 99.
Q. 99 or 89?
A. 89, I mean.
Q. You quit working there when?
A. In 90 -- 91, I think. 91.
Q. 91. All right. So you think it might have been in 1989 that Mr. Robeson visited?
A. 89.
Q. Young Wade Robeson?
A. Yeah.
Q. And were you the one who was working for Mr. Jackson exclusively in his bedroom
during that time?
A. Yes. One occasion I left and somebody else got in charge. The manager -Q. Uh-huh.
A. -- got in charge of cleaning, you know, when I left for vacation.
Q. And for how long was that?
A. Probably about two weeks.
Q. All right. But for the rest of the time, you were there cleaning?
A. Yes.
Q. And during that period of time when W ade Robeson was there, were you able to see
him?
A. Yes.
Q. Were you able to do his laundry?
A. Yes.
Q. Were you able to see him daily? Did you ever actually see him in Mr. Jacksons
bedroom?
A. Yes.
Q. Daily?
A. (Nods head up and down.)
Q. Daily?
A. Yes.
Q. Okay. Now, you said that he first came, you think, in 1999?
A. Uh-huh yes.
Q. How many separate times? When was the last time he came? In other words, how long
after the first visit was the final visit, to your knowledge?
A. I dont remember. It was, I guess, about a year, less than a year before I left.
Q. So were the visits, then, over a period of time of one year?
A. Yeah.
Q. Do you know how many separate times he came during that one-year period to visit?
A. Hell be there for weeks, and then hell leave and come back after two weeks.
Q. And stay for how long?
A. For another week.

Q. Did he generally stay for at least a week?

A. Yes.
Q. Mr. -- Wade Robeson was there for quite some time?
A. Yes.
Q. All right. And during that time, are you aware of him staying anyplace other than
Michael Jacksons bedroom?
A. No. Hell stay there as far as I know.
Q. Now, your obligation, of course, was not just to clean up, but to do the linens?
A. Yes.
Q. The sheets off the beds; is that right?
A. Change.
Q. You said that there were two beds -A. Uh-huh, yeah.
Q. -- at least? Were there more than two beds in his suite or just two?
A. No, just two.
Q. Did you make the beds every single day?
A. Yes.
Q. During the time that Wade Robeson was there, how many beds did you make? One or
more than one?
A. Just that one.
Q. The one that was Mr. Jacksons bed?
A. Yeah. The one upstairs was rarely used.
Q. All of the vis its when Wade Robeson came, was his mother there for all of the visits?
A. Sometimes.
Q. Were there some times that she was not there?
A. Yes.
Q. But Wade Robeson came by himself?
A. Yeah.
Q. Do you know how?
A. Mr. Jackson will bring him.
Q. He would bring him?
A. Yeah.
Q. And during that entire year of visits, did you ever see W ade Robesons father?
A. You know, that I dont remember. I -Q. You dont have a picture of him in your mind?
A. No.
MR. MESEREAU: Objection. Leading; move to strike.
THE COURT: Sustained. Its stricken.
Q. BY MR. ZONEN: Do you have a picture of him in your mind?
A. Of the little boy?
MR. MESEREAU: Objection; asked and answered.
THE COURT: The objection is overruled. But 5001 shes asked for clarificat ion.
MR. ZONEN: Let me change the question, if I can. Ill withdraw the question.
THE COURT: All right.
Q. BY MR. ZONEN: Can you describe Wade Robesons father to us?
A. No.
Q. And I think that you said that there might have been a s ister. Do you recall a sister?
A. I dont remember. So many kids there, I dont remember.

Q. Okay. Was there ever an occasion, to your recollection, where any other child stayed
with Mr. Jackson in his room while Wade Robeson was there?
A. No.
Q. Only Wade Robeson?
A. Yes.
Q. All right. Was there ever an occasion where you walked into his room and you saw
some kind of a separate sleeping arrangement, what you believe to be a separate sleeping
arrangement for Wade Robeson?
MR. MESEREAU: Objection. Vague; leading; foundation.
THE COURT: Ill sustain vague.
Q. BY MR. ZONEN: Did you ever see a sleeping bag on the floor?
A. No.
Q. Did you ever see anything that causes you to believe that Wade Robeson was sleeping
someplace other than in Michael Jacksons bed?
A. No.
Q. Was there an occasion that you went into Michael Jacksons room and came upon
Michael Jackson and Wade Robeson?
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. You may answer.
THE WITNESS: Did I what?
Q. BY MR. ZONEN: Come into Michael Jacksons room and discover that Michael Jackson
was there with Wade Robeson.
A. Yeah.
Q. Okay. Was there an occasion when you went in and they were in the shower?
MR. MESEREAU: Objection; leading.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you ever come in and find them in a situation that made you
uncomfortable?
MR. MESEREAU: Objection; leading.
THE COURT: Overruled.
Q. BY MR. ZONEN: Do you understand what Im asking?
A. That I was what?
Q. Where you were uncomfortable. You found them and you were uncomfortable.
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. You may answer.
THE WITNESS: Well, I came one time and -- in the bedroom.
MR. ZONEN: Uh-huh.
THE WITNESS: And first I thought they were playing.
MR. MESEREAU: Objection.
THE WITNESS: And -MR. MESEREAU: Nonresponsive.
THE COURT: Sustained.
Q. BY MR. ZONEN: All right. The question was yes or no.
A. Yes.
Q. Okay. Tell us what you heard when you first walked into the room.
A. Laughing.
Q. Okay.
A. And playing; like playing around.

Q. Okay. What did you do?

A. I came in, and I -- first I thought that they were playing in the bathtub, Jacuzzi, and I
didnt see them. And then I thought they were outside, playing outside the house; I mean,
in his garden. And I walked and they were in the shower.
Q. You have to explain to us a little bit the layout here.
A. Uh-huh. 5004
Q. Is there a Jacuzzi inside his house, inside his bedroom?
A. Inside his bedroom, yeah.
Q. So explain that for us. Describe to us what you get to first. The shower? The Jacuzzi?
Explain how its laid out.
A. First, you get to the bed. And then you get in the bathroom, they call it the ladies
bathroom, and theres a big Jacuzzi there.
Q. Okay. Was there a door that goes to that bathroom?
A. Yeah.
Q. Was the door open or was the door closed?
A. No, the door is open. It was open.
Q. And what did -- did you look into that door?
A. Which door?
Q. The door that goes to the bathroom.
A. Well, I have to go through there.
Q. Okay.
A. Yeah.
Q. What do you mean, you have to go through there?
A. To get to the bathroom.
Q. And did you do that?
A. Yeah.
Q. What did you see?
A. And then I was going to walk outside to the garden, but then -Q. Okay.
A. -- on my way going, I peek, and it was in the shower.
Q. And what did you see?
A. And I hear this playing around. Thats where he was taking a shower, I guess.
Q. Okay.
A. With little Wade.
Q. What did you see? Tell me what you saw.
A. I -- what I saw, I -- just some clothes on the floor.
Q. You saw clothes on the floor in the bathroom or in the bedroom?
A. No, in the shower.
Q. In -A. By the shower.
Q. By the shower. What clothing did you see on the floor?
A. Underwear.
Q. Underwear?
A. (Nods head up and down.)
Q. More than one pair?
A. Yeah.
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. Next question.

Q. BY MR. ZONEN: How many pair did you see?

A. Two.
Q. Two pair of underwear?
A. Yeah.
Q. Did you recognize the underwear?
A. Yeah.
Q. And how did you happen to recognize the underwear?
A. The -- Mr. Jacksons, I knew they were white. And the little boy, they were colored.
Q. All right.
A. They were little underwear.
Q. Can you describe the little boys underwear?
A. They were little green underwear.
Q. Green underwear?
A. Uh-huh. Had like a neon color.
Q. Neon green?
A. Yeah.
Q. Just in case he lost them? You did his underwear previously, d idnt you? You had
washed his underwear previously?
A. Uh-huh.
Q. Did you know Wade Robesons underwear?
A. Yeah.
Q. Okay.
A. They have little, you know, characters, like Spiderman and things like that.
Q. Childs?
A. Childs.
Q. A small childs underwear?
A. Yeah. 5007
Q. And Mr. Jacksons underwear you washed regularly as well?
A. Yeah.
Q. And his underwear was what type?
A. I dont know. I think they call them briefs.
Q. And what color?
A. White.
Q. Okay. You say you found two pair. Where were they?
A. On the floor.
Q. Okay. And on the floor in the bathroom?
A. Yeah.
Q. Now, how far is the underwear from either the Jacuzzi or the shower?
A. Well, theyre right by -- they were right by the door, by the shower.
Q. Okay. Was water running?
A. Yeah.
Q. Excuse me. And the water was running in the -- in the shower?
A. Yes.
Q. Did you -- did you know that, that the water was running, when you first came into his
bedroom suite?
A. Well, I heard the radio, and then eventually I hear the water going.
Q. Im sorry, I heard the first part.
A. The radio. I heard the radio.

Q. You heard the radio?

A. Yeah, playing. And then eventually I hear the water going.
Q. And then you heard the water?
A. Yeah, because I hear two people, you know, playing.
Q. And you say you heard two people playing. What were the sounds that you heard?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you hear two voices?
A. Yeah.
MR. MESEREAU: Objection; asked and answered.
THE COURT: Leading; sustained.
Q. BY MR. ZONEN: For what period of time did you hear sounds?
A. Maybe about a minute.
Q. Did you recognize the voices that you heard?
A. Yeah.
Q. Whose voices were they?
A. Mr. Jackson.
Q. Did you recognize the second voice?
A. Yeah.
Q. Whose voice was that?
A. The little kid, the -Q. Wade?
A. Wades, little boy.
Q. When you finally reached a spot where you could see in, was your vision obscured by
anything?
MR. MESEREAU: Objection. Leading; assumes facts not in evidence.
MR. ZONEN: Withdraw the evidence -- withdraw the question.
Q. In that bathroom, is there a shower curtain?
A. No.
Q. What is there in that bathroom?
A. A glass door.
Q. A glass door. Is it a glass door that is fogged or is it a glass door that is clear?
A. Its clear, but at that time it was smoky.
Q. Okay. Smoky?
A. Cloudy.
Q. Cloudy? From the shower?
A. Yeah.
Q. All right. When theres no shower going, can you see through the glass?
A. Yeah.
Q. On this occasion when the shower was going, could you see through the glass?
A. No.
Q. Could you see any figure at all? W hat could you see?
MR. MESEREAU: Asked and answered.
THE WITNESS: I saw a figure.
MR. ZONEN: Hold on.
THE COURT: Just a minute. The objection is overruled. I saw a figure is the answer. Go
ahead.
Q. BY MR. ZONEN: Did you see more than one figure?

A. Yeah.
Q. All right. Did you recognize either of the figures that you saw?
A. Mr. Jackson.
Q. All right.
A. And the little kid.
Q. Was one figure larger than the other?
A. Yeah.
Q. Was the second figure the size of Wade Robeson?
A. Yeah. Yes.
Q. What did you do at that point?
A. That he was going to get mad, or -MR. MESEREAU: Objection; nonresponsive.
THE COURT: Sustained.
MR. MESEREAU: Move to strike.
Q. BY MR. ZONEN: What did you do at the time that you saw Mr. Jackson and Wade
Robeson in the shower? What did you do then?
A. I was going to talk to them, but then I thought, No, I better not, so I just went back.
Q. Did you leave the room?
A. I -- yeah, I left the room.
Q. Did you tell Mr. Jackson that you had been in the room?
A. No.
Q. Did you back into the room at a later time?
A. Yeah, to clean the room.
Q. Miss Francia, was there ever an occasion where you saw your son Jason with Mr.
Jackson and you were concerned?
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Go ahead.
A. I was concerned for my son, yes.
Q. Can you tell us when that happened?
A. The first time, it was -- I think it was in Encino.
Q. Okay.
A. That I remember that I walked in, because I had the key to that room, too.
MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE WITNESS: And I walked in -THE COURT: Wait. Just a moment, please. All right. No question was pending, so Ill
strike her answer.
Q. BY MR. ZONEN: All right. It was in Encino. Do you remember when that was?
A. Do you mean the date?
Q. Or the year.
A. Probably 86. I dont remember.
Q. Okay. How old was Jason?
A. Probably about seven or eight, probably. Seven.
Q. Seven. And what did you see that concerned you?
A. Well, I saw little things before that with other kids, and -MR. MESEREAU: Objection; nonresponsive.
Q. BY MR. ZONEN: Just tell us what you saw -THE COURT: Sustained.

Q. BY MR. ZONEN: Just tell us what you saw with Jason.

A. Well, he was sitting on his lap.
Q. Okay. And what concerned you?
A. And I walked in, and he was sitting on his lap, and Mr. Jackson was just reclining,
reclining to the back.
Q. Reclining?
A. Reclining to the back.
Q. Okay.
A. And having my son in his lap.
Q. And where was Jason positioned on his lap?
A. His legs.
Q. Okay. And what did you do?
A. I just told my son to get out. And he was -- I remember he say, No, Im fine.
MR. MESEREAU: Objection. Nonresponsive; move to strike.
Q. BY MR. ZONEN: You told your son to get out?
THE COURT: Just a moment. Stricken.
Q. BY MR. ZONEN: You told your son to get out?
A. Yeah.
Q. Did he do so?
A. No.
Q. What did you do then?
A. I think I push him, and -- oh, he was -- some kind of -- reading a book or coloring. And
Mr. Jackson say, I want him to read, or Im reading a story, something like that.
Q. Did you take your son off of his lap?
A. Yeah. Yes.
Q. Was there another occasion that you were concerned?
MR. MESEREAU: Objection; leading.
THE COURT: Overruled.
Q. BY MR. ZONEN: You can answer.
A. Yeah, I remember one time, too, at the Encino house that I want my son to stay
downstairs, because he -- he will come and -- Mr. Jackson will come and, you know,
probably wanted to be by himself, and I said, You stay here, and I -Q. You said that to who?
A. To my son, you know, to Stay here. Stay here, because Michael is here, and, you
know, he probably want to be by himself. And then he find out -- I guess Mr. Jackson
find out that my son was there, and so he took him upstairs. And I got mad, because my - I told my son not to go with him, but I got concerned because my son -MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: Ill strike the last sentence.
Q. BY MR. ZONEN: Did you go look for your son?
A. No.
Q. When did you next see your son?
A. What do you mean?
Q. On that day, on that occasion.
A. Oh. Well, I -- I did my cleaning, or whatever I was doing, and after, he came -- he
came down.
Q. Okay. Let me ask you about the hideout. At the hideout, you had mentioned that there
wasnt a bed. What did Mr. Jackson sleep in?

A. He sleeps in a sleep ing bag.

Q. All right. The whole time that he was at the hideout?
A. Yeah. There was no bed.
Q. Im sorry?
A. There was no bed there.
Q. Was there ever an occasion that you and your son stayed the night at the hideout?
A. No.
Q. You always left at the end of the day?
A. Yeah.
Q. And did you have an apartment that was someplace in Los Angeles at that time?
A. He?
Q. You.
A. Oh, yeah, I d id.
Q. So during the time that you were going to the hideout regularly -A. Yeah.
Q. -- you had an apartment. And I think that you had testified that even after you moved
to Santa Maria, there were still occasions that you went back to clean at the hideout?
A. Many times, yeah.
Q. Do you know for approximately how long after you moved to Santa Maria?
A. Probably a year.
Q. Okay. Now, what did he -- I asked you what he slept on, and you said a sleep ing bag.
Describe the sleeping bag for us. What kind of a sleeping bag was it?
A. A regular sleeping bag that you sleep on.
Q. Sleep ing bag for one person? For two people? How big?
A. A regular one.
Q. Just a regular sleeping bag?
A. Yeah.
Q. Was that sleeping bag always open, or was it rolled up?
A. It was open.
Q. Always?
A. Well, when I made it, I would try to make it like a bed, you know.
Q. Were there any blankets on the sleeping bag or under the sleeping bag?
A. Yeah, there were blankets.
Q. Which? On the sleeping bag or -A. On the sleeping bag, yes.
Q. Was the sleep ing bag simply on the floor?
A. Yeah.
Q. Was there carpet on the floor?
A. Yes.
Q. Did you ever see Jason on or in the sleeping bag?
A. One time.
Q. Was Mr. Jackson there?
A. Yes.
Q. Were they on the sleeping bag or were they in the sleeping bag?
A. They were on the sleeping bag, yeah.
Q. On top of the sleeping bag?
A. Yeah.
Q. Could you see their body -- bodies, both of them?

A. Not Mr. Jacksons.

Q. Why not?
A. Because it was covered.
Q. Okay. So the sleeping bag covered Mr. Jackson?
A. Yeah.
Q. How about Jason? Where was Jason?
A. He was in the sleeping bag, too.
Q. He was in the sleeping bag. How were they positioned relative to each other? Do you
know what I mean? Were they facing each other? Were they facing away from each other?
Do you recall?
A. I remember this time he was this -- on this side, and my son was on this side. And I
got there about three or four times, and one time he was -- my son was -MR. MESEREAU: Objection; nonresponsive.
THE COURT: Its kind of hard to tell. Maybe you could start with another question.
MR. ZONEN: Yes, I can.
Q. I asked you initially how they were positioned. In other words, were they facing each
other? Were they facing away from each other? Do you recall? When you saw them the
first time.
A. The first time, my son was just laying there.
Q. Okay.
A. But on one time, because I was cooking for Mr. Jackson, I was doing some lunch, or
snacks, or something -Q. Im sorry?
A. I was cooking some snacks.
Q. Snacks. Okay.
A. Popcorn.
Q. Okay.
A. I dont remember.
Q. Are we still talking about the same event, the same day?
A. Yes.
Q. Okay. So when -A. Hmm?
Q. When you first saw your son in the sleeping bag with Mr. Jackson, did you say anything
to your son at all when you first saw him in the sleep ing bag?
A. I told him to come up, outside, and eat, because I wanted to feed him.
Q. Okay. And did he?
A. No.
Q. All right. What did you do?
A. He say, I want to stay here.
Q. Okay. What did you do?
A. And -- well, I got mad. And I said, you know, You got to get out to the kitchen, and
he didnt wanted to.
Q. All right. Were you speaking with him in English or in Spanish at that time; do you
recall?
A. No, I dont remember.
Q. Do you know what language -- what language do you speak with your son now?
A. Spanish.
Q. You speak Spanish?

A. Yeah.
Q. Youve always spoke Spanish with him?
A. Yeah.
Q. His wife does or does not speak Spanish?
A. No.
Q. In her presence, what do you speak?
A. English.
Q. Okay. But he grew up speaking Spanish?
A. Yes.
Q. And hes very fluent in Spanish?
A. Yes.
Q. When you asked him to come out to go eat, in what language was that?
A. I think I said it in Spanish. But then I want Mr. Jackson to understand what I was
telling him to do, and so I guess I said it in Spanish and 5020 English. I dont remember.
Q. So youre not certain at this point?
A. No.
Q. All right. Did he get out of the sleeping bag?
A. No.
Q. What did you then do? Did you leave the room or -A. I left the room and I proceed to do my stuff and -Q. Okay. And what happened then?
A. Then I went back and -- and then he was eating, but he was -- oh, I took something to
eat to him.
Q. Okay. When you came back out, was he still in the sleeping bag with Mr. Jackson?
A. Yeah.
Q. What were they doing in the sleeping bag? I dont mean in the sleeping bag, but what
were they doing in the room?
A. They were watching T.V.
MR. MESEREAU: Objection; foundation.
THE COURT: A time frame?
MR. MESEREAU: Yes.
THE COURT: Sustained.
Q. BY MR. ZONEN: At the time that you first came into that room, was the television on?
A. On, yes.
Q. Do you remember approximately what time of the day it was?
A. Probably was about 2:00, 1:00 or 2:00 in the afternoon.
Q. Was the room light or was the room dark?
A. It was dark. It gets really dark.
Q. But this was about 1:00 or 2:00 in the afternoon?
A. Yeah.
Q. Were there shades on the windows?
A. Draperies, curtains.
Q. Draperies. And were they drawn? Were they closed?
A. Closed.
Q. So the light was not in?
A. No.
Q. Do you remember what they were watching on television?
A. No.

Q. Do you know what Jason used to like to watch at that time?

MR. MESEREAU: Objection; relevance.
THE WITNESS: At that time -MR. ZONEN: Ill withdraw the question.
THE COURT: All right.
Q. BY MR. ZONEN: How old was Jason, to your recollection, at that time, as best you can
recall?
A. Probably like eight. Probably eight. That 5022 was -Q. Im sorry, go ahead.
A. -- before we move here to Santa -- to -- before he moved here to Neverland.
Q. It was before he moved to Neverland?
A. Yeah.
Q. And Jason was born on, if Im not mistaken, May 30, 1980?
A. Yes.
Q. Is that his birth date?
A. Yes.
Q. When you moved to Neverland in 1988, he would have been about eight years old?
A. Yeah.
Q. And you believe this was before?
A. Oh, yeah. Yeah.
Q. Okay. Do you know if Mr. Jackson ever gave Jason money?
A. Yeah.
Q. Do you know on how many occasions?
A. That I remember, because it was -- to me, it was a lot of money for a little kid. At the
hideout he gave him some money.
Q. Do you know how much money he gave him?
A. From what I remember, it was two hundred-dollar bills.
Q. Two 100-dollar bills?
A. Two 100-dollar bills, yes.
Q. When did you first see that money?
A. After -- what happened was that I left the key at his apartment. And we were walking
to get -- take the bus home, back home. My car key, I left it there. And we were going to
walk to -- to the bus stop.
Q. Okay. Were you taking the bus back and forth?
A. No, I was driving. But I left the key, my car key there, and I didnt want to go back and
knock at the door, because -Q. You didnt have your key?
A. Yeah, Mr. Jackson wouldnt open the door.
Q. Okay.
A. So I remember we were walking to the bus stop, and he say -- my son told me he has
money -MR. MESEREAU: Objection.
THE WITNESS: -- in his pocket.
MR. MESEREAU: Nonresponsive.
THE COURT: Just a moment. True, theres no question pending. Its nonresponsive.
MR. ZONEN: All right.
Q. Where were you when you first saw the money?
A. At the bus stop.

Q. Okay. Did he give you the money, your son?

A. No.
Q. All right. How did you see the money?
A. Well, he say he had lots of money and that it was a secret.
Q. Okay. What did you say?
A. And I say, What do you mean, a secret? How much money? But I thought it was
maybe two dollars.
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Spontaneous declaration, Your Honor.
THE COURT: Im going to allow the answer to the question of, What did you say? which
I think is the objection you were making.
MR. MESEREAU: Has to do with third-party statements, Your Honor.
MR. ZONEN: Im sorry.
THE COURT: Im going to ask you to rephrase the question. The question you last asked
where the objection came was, And what did you say? And she did say what she said.
But then she was going to say something else.
MR. ZONEN: Yes. Thank you.
Q. What did your son say to you in response to your statement?
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Thats a spontaneous declaration.
THE COURT: Okay.
MR. ZONEN: Thats what I originally meant.
THE COURT: I will allow it on that basis.
MR. ZONEN: Thank you, Your Honor.
Q. What did your son say?
A. That he has the money; that it was a secret; he wasnt going to tell me.
Q. Okay.
A. But at this point I thought it was maybe two dollars or a dollar.
Q. Did you ask to see it?
A. And I say, I want to see it. And he say, No, because Michael told me that its for me
and not to tell you. But like I say, I thought it was two dollars. I say, How much is it?
And I pull it out of his pocket.
Q. It was in h is pocket?
A. It was in his pocket. He said he put -Q. Do you remember what he was wearing?
A. Pants.
Q. You believe it was pants?
A. Yeah. He says, He put it in my pocket. Dont take it out. So I pull it out, and I said,
$200?
MR. MESEREAU: Objection; nonresponsive.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you reach into his pocket?
A. Yeah.
Q. Did you retrieve it?
A. Yeah.
Q. What was it?
A. It was two 100-dollar bills.
Q. Were there ever other occasions that you were aware of where Mr. Jackson gave your

son money?
A. No.
Q. Was that the only occasion that you recall?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you ever see your son with money on other occasions?
A. Ill give him allowances. And, you know, hell keep it -- you know, a dollar or two.
Q. Do you know who Macaulay Culkin is?
A. Yes.
Q. Who is Macaulay Culkin?
A. The little kid from the movies.
Q. Yes. Did you ever see Macaulay Culkin -A. Yes.
Q. -- personally? Where did you see him?
A. At the Neverland. At the ranch.
Q. Did he visit Neverland?
A. Yes.
Q. How often did he visit Neverland?
A. I dont remember. But it was a few times when I was there.
Q. More than once?
A. Yes.
Q. Over what period of time, from the first time to the last time?
A. Probably six months.
Q. Were you working that entire time?
A. Yes.
Q. Were you working in the same job youve already described for us, as Mr. Jacksons
personal maid?
A. Yes.
Q. Were you cleaning his room?
A. Uh-huh. Yes.
Q. And doing his laundry?
A. Yes.
Q. When Mr. Culkin came -- well, it was Macaulay Culkin. How old was he when you first
saw him, approximately?
A. I think about eight or nine. Probably eight.
Q. Was this before or after Wade Robeson was visiting?
A. After.
Q. Did they ever visit at the same time?
A. No. Not that I can remember.
Q. Did Wade Robeson continue to visit during the time that Macaulay Culkin was coming?
A. I dont remember.
Q. Do you know where Macaulay Cu lkin stayed when he came to Neverland?
A. With Mr. Jackson.
Q. Did Macaulay Culkin come with any other family members that you recall?
A. Yeah, I remember him with his father and mother.
Q. Father and mother?
A. And the other kids.
Q. Other --

A. Brothers and sisters.

Q. Other siblings?
A. Yes.
Q. Do you know how many siblings he had, whether they were boys or girls?
A. No, I dont remember.
Q. Do you know if it was more than one other sibling?
A. Yeah. More than one.
Q. Did he have at least one brother and one sister at least?
A. Yes.
Q. Do you know the total number of brothers and sisters?
A. No. No. Probably five. I dont remember.
Q. I asked you where Macaulay Culkin stayed, and you said with Mr. Jackson. How do you
know
that?
A. Because Ill go to his bedroom and clean up after.
Q. Did you ever see Macaulay Culkin in Mr. Jacksons bedroom?
A. Yes.
Q. Were his possessions there in the bedroom?
A. Yeah. I dont remember.
Q. That you dont recall?
A. No.
Q. Do you recall if you ever washed his clothing as you did Wade Robesons?
A. Yeah.
Q. Would you have washed his clothing if his clothing was someplace other than his
bedroom?
MR. MESEREAU: Objection; calls for speculation.
THE COURT: Sustained.
Q. BY MR. ZONEN: Was it your responsibility to wash clothing from rooms other than Mr.
Jacksons bedroom?
A. No.
Q. If guests did not stay with Mr. Jackson, where would they have stayed?
A. In the guest rooms. They call them the outside guest rooms. You know, theyre like
four -- four guest rooms outside.
MR. ZONEN: Could I have those photographs, please? Oh. Thank you. Im sorry, did you
say something?
MR. MESEREAU: Im going to object as cumulat ive.
MR. ZONEN: Oh, okay. All right.
Q. And I think that you said it was for a number of months that Macaulay Cu lkin stayed?
A. Yeah. W eeks.
Q. I dont mean continuously. But what do you think was the longest period that you ever
saw him there during that few-month period of time?
A. About a week.
Q. Okay. Do you know if he always came with his family?
A. Not always.
Q. How else did he come?
A. How often?
Q. How else, if he was not with his family? W as he with other people?
A. No.

Q. Did he come by himself?

A. Yes.
Q. Do you have a recollection of how many times Macaulay Culkin came to visit Neverland
by himself?
A. Maybe I remember about two times.
Q. All right. How old was Jason during the time that Macaulay Cu lkin was there?
A. At that time he was probably already ten.
Q. Jason was older than Macaulay Culkin?
A. Yeah.
Q. About how much older?
A. Probably a year or two. I dont know.
Q. During the time that Macaulay Culkin staye in Mr. Jacksons bedroom, do you know if
other members of his family also stayed in the bedroom with them?
A. Yeah, I think they did.
Q. On every occasion?
A. Not all the time.
Q. Are you aware -A. When -Q. Im sorry, go ahead.
A. When he was by himself, he was there by himself with Mr. Jackson.
Q. Do you know of any occasions when Macaulay Culkin came to visit when he did not
stay in Mr. Jacksons room?
A. No.
Q. And on those occasions when Macaulay Culkin stayed in Mr. Jacksons room, do you
know if there was ever a separate sleeping arrangement, in other words, a separate bed
or a separate sleeping bag that you would have to clean up?
A. No.
Q. Excuse me, Im sorry. Why did you leave Neverland, your employment at Neverland?
MR. MESEREAU: Objection; relevance.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you leave your employment at Neverland?
A. Yes.
Q. Okay. Did you leave of your own volit ion?
A. Yes.
Q. Do you remember when it was you left Neverland?
A. May, I think.
Q. Of what year?
A. 91. 90 or 91. 91, I think.
Q. May of 91?
A. 91.
Q. All right. So you would have been employed by Mr. Jackson for a period of about five
years?
A. Five years, yeah.
Q. Now, May of 91 your son would be turning 11; is that right?
A. Yes.
Q. Do you know if you left before his 11th birthday?
A. Uh-huh. About.
Q. Did your son have any more association with Michael Jackson after you?

A. After?
Q. Yes, after you left.
A. No.
Q. Did you ever go back to Neverland after you left?
A. No.
Q. Did you ever visit with Mr. Jackson after you left?
A. No.
Q. Were you contacted by law enforcement at some time after you left Neverland, your
employment at Neverland, for an interview?
A. Yeah. 1994 or 93. I dont remember.
Q. 93 or 94? So it was already some time after you left Neverland; is that right?
A. Yes.
Q. At least a year, and probably two?
MR. MESEREAU: Objection; leading.
MR. ZONEN: Let me withdraw the question.
Q. How long after you left your employment at Neverland was it that law enforcement
contacted you?
A. About two and a half years.
Q. Did you contact them or did they contact you?
A. They came to me.
Q. At the time they contacted you, did you know whether or not there was an
investigat ion going on involving Mr. Jackson?
A. Yeah. Yes. I was -- kind of.
Q. Were you expecting to be contacted?
MR. MESEREAU: Objection. Calls for speculation; relevance; foundation.
MR. ZONEN: Goes to her state of mind.
THE COURT: Sustained.
Q. BY MR. ZONEN: All right. Did it come as a surprise to you when you were contacted?
MR. MESEREAU: Objection. Relevance; foundation; lead ing.
THE COURT: And Im going to back up a minute and change my ruling on the question,
Were you expecting to be contacted? She may answer that yes or no. Ill overrule
the last objection.
Q. BY MR. ZONEN: Did you understand that? You may answer the question, Were you
expecting to be contacted?
A. Yes and no.
Q. Did you ultimately give an interview with the sheriffs office?
A. Yes.
Q. At some point in time were you called to give a deposition? Were you subpoenaed to
give a deposition?
A. I was subpoenaed, yeah.
Q. All right. Now, do you know who it was who subpoenaed you to give a deposition?
A. Mr. Feldman.
Q. Was that Larry Feldman?
A. Yes.
Q. Do you know who Larry Feldman represented at that time?
A. Yeah. Another little boy.
Q. Im sorry?
A. Another little boy.

Q. Do you know that persons name?

A. The -- the little boy?
Q. Yes, that he represented.
A. At that time I didnt know. Now -- now I hear -Q. What do you know the name to be?
A. Chandler. Chandler. Something like that. But I dont know. I dont know the first name.
Q. Did you know that child, Mr. Chandler?
A. No. No.
Q. Mr. You dont know how old he was? You dont know how old he was?
A. No.
Q. Did you know his first name?
A. No.
Q. Was this a child you were ever introduced to during the time that you were at
Neverland?
A. No.
Q. And tell us what a deposition is. Having gone through one, what is it?
MR. MESEREAU: Objection; foundation.
MR. ZONEN: Well, let me withdraw that.
Q. Did you, in fact, go through a deposition?
A. Did I went through -Q. Did you have a deposition? Did they take your deposition?
A. Yeah. Yes.
Q. Okay. And did you, in fact, give testimony in that deposition?
A. Yes.
Q. Now, I asked you who it was who subpoenaed you, and you said it was Larry Feldman.
A. Uh-huh.
Q. Were there other lawyers in the room asking you questions as well?
A. Yes.
Q. Who were the other lawyers? Do you remember any of their names?
A. I remember Johnnie Cochran, and there were about five or six.
Q. About five or six lawyers?
A. Yeah.
Q. All in the room at one time?
A. Yeah.
Q. And was Johnnie Cochran asking you questions?
A. Yes.
Q. Were other lawyers asking you questions as well?
A. I dont remember. But I think there was one Waysman or Wiseman.
Q. Weitzman? Perhaps Howard Weitzman?
A. I dont remember his last name. I mean -Q. Do you know on which side Mr. Weitzman was?
A. With Mr. Cochran.
Q. He was with Mr. Cochran?
A. They were the two together, yeah.
Q. Who did Mr. Cochran and Mr. Weitzman represent?
A. Mr. Jackson.
Q. Okay. Was Mr. Jackson present during that deposition?
A. No.

Q. Was he ever there during the deposition at any time?

A. No.
Q. Did that deposition go longer than one day?
A. Yeah.
Q. How many days did it go?
A. Two days.
Q. Do you know how many hours each day you were deposed?
A. No.
Q. Do you know if there were other lawyers sitting with Mr. Feld man, Larry Feldman, in
other words, on his side, other than Mr. Feldman?
A. No.
Q. Was Mr. Feldman the only one asking you questions from that side?
A. Yes.
Q. Have you ever reviewed the transcript of that deposition?
A. No.
Q. Even back then?
A. Not that I remember.
Q. Do you remember what year it was, of that deposition?
A. 94, I think. Or 95.
Q. Was it before or after you had your first interview with law enforcement? Do you recall?
A. After.
Q. It was after? Do you remember approximately how long after?
A. No, I dont remember the date or -Q. Miss Francia, when you had this deposition that went on for two days, and you say that
there were lawyers, a number of them in the room, did you have a lawyer with you?
A. No.
Q. Had you retained a lawyer at that time?
A. Not at that time, no.
Q. Did you give answers to questions that were put to you at that time.
A. Did I answer?
Q. Yes.
A. Yes.
Q. Did you -- did they explain to you that a deposition is the same thing as testifying?
MR. MESEREAU: Objection; leading.
THE COURT: Just a moment.
MR. ZONEN: Ill withdraw the question.
THE COURT: Overrruled.
MR. ZONEN: I wont withdraw the question.
THE COURT: You may answer.
Q. BY MR. ZONEN: Did they explain to you that a deposition was the same thing as
testifying?
A. No.
Q. Did you have to raise your hand to take an oath to tell the truth?
A. Oh, yeah.
Q. And you did do that?
A. Yeah.
Q. All right. Did they ask you questions about -- questions similar to the questions Ive
asked you so far since youve been on the witness stand?

A. (Nods head up and down.)

Q. You have to answer out loud, if you would, please.
A. Yes.
Q. All right. Did they ask you about Wade Robeson?
A. Yes.
Q. Did they ask you if in fact you had seen them in the shower together?
A. Yes.
Q. Do you remember the answers that you gave to those questions?
A. Kind of.
Q. Did you tell one of the attorneys that you did not see Wade Robeson in the shower?
A. Yeah, I probably did.
Q. All right. Was that accurate?
A. Well, at that time I guess I was tired and nervous, I guess.
Q. Did you tell them that you believed Wade Robeson was in the shower?
A. Yes, I told them that.
Q. Did you tell them about the underwear?
A. Yeah.
Q. Did you tell them about hearing the voices?
A. Yes.
Q. Did you tell them about the music?
A. Yes.
Q. Did you do an interview for Hard Copy?
A. Yes.
Q. What is Hard Copy?
A. A program.
Q. A program?
A. Yeah.
Q. A program on what? On television?
A. On television, yeah.
Q. Was that a program that you had seen before that interview?
A. No.
Q. Had you ever watched Hard Copy before?
A. No.
Q. Do you know what kind of -- did you know -- before you were on it, did you know what
kind of a program it was?
A. No.
Q. Were you -- did somebody contact you from Hard Copy?
A. Yeah.
Q. And do you remember who that was who contacted you?
A. That -- the lady who interview me.
Q. Okay. Do you happen to remember her name?
A. Yeah.
Q. What was her name?
A. Diane Dimond.
Q. Diane Dimond. Did you discuss with Miss Dimond what it was she wanted to talk with
you about?
A. Yeah, we kind of talk about it.
Q. Okay. Did you agree to go on television?

A. Yeah.
Q. Was there some discussion with Miss Dimond about whether or not you would be paid
or compensated for appearing on television?
A. Yeah. My friend and I went together.
Q. You went with a friend?
A. Yeah.
Q. Who was your friend?
A. One of -- one of the workers at Neverland.
Q. One of the workers at Neverland?
A. Yeah.
Q. What was her name?
A. Evangeline.
Q. Evangeline?
A. Yes.
Q. And what did she do at Neverland?
A. She was a housekeeper and a cook.
Q. A housekeeper and a cook?
A. And a cook, yeah. And she helped the cook.
Q. Okay. And you were talking with Diane Dimond with Evangeline?
A. Yeah.
Q. All right. Why is that? Why was Evangeline there, or Vangie, was why she there?
MR. MESEREAU: Objection; foundation.
THE COURT: Im not sure what youre looking for, foundation.
MR. MESEREAU: And speculation.
THE COURT: Okay.
MR. ZONEN: Ill withdraw that, then. I understand that objection.
Q. Did you ask Evangeline to be there with you?
A. She was the one who contact, I believe, Diane Dimond.
Q. Did she -- shes the one who introduced you to Diane Dimond?
A. Yeah, she was the one who told me, you know, that she can get everything arranged.
Q. Okay. That she could arrange the interview?
A. The interview, yeah.
Q. And payment as well?
A. Yeah. She say, Ill help you.
Q. What did you understand the interview to be about? What did they want to ask you
about?
MR. MESEREAU: Objection. Calls for speculation.
MR. ZONEN: Withdraw the question.
Q. What was your belief that you were going to be telling them?
MR. MESEREAU: Objection. Leading.
THE WITNESS: About -THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: What was your belief that you would be telling them?
A. About me working there.
Q. Working where?
A. At Neverland.
Q. Okay. Did you think they would be asking you questions about Michael Jackson?
A. No. I mean, that -- not the way they were asking me.

Q. How much money did they represent from Hard 5044 Copy -- how much money did
they represent that they would give you for an interview?
A. How much money they gave me?
Q. Yes.
A. $20,000.
Q. $20,000.
A. Yes.
Q. And what were you going to do for $20,000? What were you going to say in this
interview for
10 $20,000?
A. Well, I -- I thought that it was going to be just talking about, you know, how it was
working for him and how he was.
Q. Did that seem, to you, an unusually large amount of money?
MR. MESEREAU: Objection; lead ing.
THE COURT: Sustained.
Q. BY MR. ZONEN: How much money were you making a year at that time?
A. Less than $20,000.
Q. Less than $20,000?
A. Yeah, probably around 20.
THE COURT: All right. Well take our break. (Recess taken.)
THE COURT: Go ahead.
Q. BY MR. ZONEN: When we left off, I was asking some questions about the interview
with Hard Copy. Did that interview finally take place?
A. Yes.
Q. Did you actually watch it on television when it was screened?
A. No.
THE BAILIFF: Can you turn your microphone on?
Q. BY MR. ZONEN: I asked you about the interview with Hard Copy. You finally did that
interview, did you not?
A. Yes.
Q. Did you watch it on television when it was screened?
A. No.
Q. Have you ever watched it?
A. No. I watch a little b it, you know, when I -Q. Did you receive $20,000?
A. Yes.
Q. Okay. Do you know if your friend Evangeline got any money?
A. She didnt get any money from them, no. I gave her some money.
Q. Was that interview -- was that interview with Hard Copy before or after your interview
with the sheriffs detectives?
A. After.
Q. Was it before or after your deposition with Larry Feldman and Johnnie Cochran? 5046
A. Oh, before.
Q. It was before the deposition?
A. Yes.
Q. Do you remember being asked some questions about the Hard Copy -A. Yes.
Q. -- interview during that deposition?

A. Yes.
Q. Did Mr. Jackson ever have a nickname for your son, for Jason, that he used?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you ever hear Mr. Jackson call your son by a name other than
Jason, his real name?
A. Yes.
Q. What name was that?
A. Rubba.
Q. Rubba, R-u-b-b-a, do you think?
A. I think.
Q. Is that what it sounds like?
A. Yeah.
Q. Did you ever hear him call other kids Rubba?
A. Yes.
Q. Did he call Wade Robeson Rubba?
A. Yes.
Q. Did he call Macaulay Cu lkin Rubba? 5047
A. Yeah.
Q. Did you ever receive any gifts from Mr. Jackson?
A. Yes.
Q. What kind of gifts did you receive from him?
A. I dont remember. They were a lot.
Q. Do you remember any of them?
A. He told me to get whatever I want, you know, like promotional things that hell get
from the companies, or toys for my son.
Q. Do you mean if he had them in his possession?
A. Yeah. He will buy little stuff for me, too.
Q. And he would give them to you?
A. Yeah.
Q. Did he ever g ive you any furniture?
A. Yeah.
Q. What kind of furniture?
A. I remember one time he -- he had a table in the attic, and he say he doesnt want it
there. And I asked him if I could take it, and he said, Yeah, sure. Take it.
Q. The attic where?
A. The attic at Havenhurst.
Q. At Havenhurst?
A. Yeah.
Q. How long ago was that?
A. When I first started there, to work there.
Q. So 86?
A. Yeah.
Q. All right. Any other things that you can remember that he gave you over the years?
A. Toys for my son.
Q. Toys for your son? Did he ever give you money?
A. I dont remember.
Q. You dont remember if he gave you money, or how much, or how often?

A. How often? No, I dont remember.

Q. All right. When you had the deposition with Johnnie Cochran, did he ask you if you ever
took something from -MR. MESEREAU: Objection; misstates the evidence. There were other lawyers involved.
THE COURT: Overruled. You may -Q. BY MR. ZONEN: When you had the deposition -- It was overruled, Your Honor?
THE COURT: It was overruled. Yes.
Q. BY MR. ZONEN: When you had the deposition with Johnnie Cochran, did he or any
other lawyer representing Michael Jackson ask you if you took something from Michael
Jacksons room?
A. I dont remember.
Q. Did they ask you about a watch?
A. Yeah.
Q. Do you remember the watch?
A. Yes.
Q. Did you have a watch from Michael Jackson?
A. Did he have it?
Q. No. Did he ever g ive you a watch?
A. I got it from his room.
Q. What kind of a watch are we talking about?
A. It was a toy watch. You know, like I think it was from one of his commercials or
something.
Q. Did you -A. That I had it, and he look at it, and he say, Oh, thats nice. And I say, Yeah, I got it
from your room. And he didnt -- I told one of the housekeepers that I -- Oh, look what I
got from his room. But I guess I used to get stuff from his room and -Q. Are you talking about promotional things?
A. Yeah. Things like that.
Q. What is a promotional item? What do you mean by that?
A. Like when he make a commercial. I think this watch was from Captain Eo.
Q. Im sorry?
A. I think it was from one of his videos.
Q. Did he have his name on it?
A. Yeah.
Q. Did it have his picture on it?
A. Yes.
Q. What was that watch worth, do you think?
A. About $10, probably.
Q. At some time were you contacted by an attorney or did you retain an attorney?
MR. MESEREAU: Objection; compound.
MR. ZONEN: Ill withdraw the question.
Q. Did you ever retain an attorney?
A. I dont understand.
Q. Oh. Did you ever hire a lawyer?
A. Oh. Did I personally went to a lawyer and say -- no.
Q. Okay. Do you know Terry Cannon?
A. Yes.
Q. Do you know Kris Kallman?

A. Yes.
Q. Do you know them to be lawyers?
A. Yes.
Q. All right. Did either of those two lawyers represent you?
A. Yes, at one time.
Q. Did they represent Jason?
A. Yes.
Q. How did that happen? How did you come into contact with these two lawyers?
A. Well, since I -- I was felt like -MR. MESEREAU: Objection. Relevance; 352.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did Jason get subpoenaed to appear at a deposition?
A. Yes.
Q. How old was Jason at that time?
MR. ZONEN: We forgot the tags. Would you mark the next two exhibits in order, please?
THE WITNESS: Probably about 12.
Q. BY MR. ZONEN: Did he actually get a subpoena to appear at a deposition?
A. No, they told me that they were going to subpoena him.
Q. Was that at the end of your deposition?
A. Yes, they told me they want him and myself at another office. Not there, but another
office. Mr. Cochran told me.
Q. All right. Were you concerned about Jason giving a deposition?
A. At that time, yeah.
Q. Did you think he -MR. MESEREAU: Objection. Leading; move to strike.
THE COURT: Overruled. Next question.
Q. BY MR. ZONEN: What were your concerns about Jason giving a deposition?
MR. MESEREAU: Objection. 352; foundation.
THE COURT: Overruled.
Q. BY MR. ZONEN: You can answer the question. What was your concern?
A. That he -- being so young, that he was going to be embarrassed and teased by other
kids.
Q. All right. At some point in time, did you talk with -- let me change that. At some point
in time, did you agree to file a lawsuit against Michael Jackson?
A. Not at that time.
Q. Do you know if there was some kind of a settlement with Michael Jacksons attorneys?
A. Yes.
Q. Did you receive -- and Im not asking you how much, but did you receive
compensation?
A. Yes.
Q. Did you receive payment?
A. Yes.
Q. Did Jason also receive payment?
A. Yeah. Yes.
Q. When did he receive his payment?
A. I believe it was his 18th birthday.
Q. His 18th birthday? I had asked you a question about the watch from his room. Did Mr.
Jackson ever talk to you about being able to take things if you wanted to?

A. He never told me that.

Q. Did he say anything like that?
A. Oh. No.
Q. There was no conversation about that?
A. He told me that sometimes people gave him things, and that hed display it, and then - you know, and then he would like to get rid of it.
Q. Did you show him the watch?
A. Yeah. At one time I was wearing it, one of his jackets, and he say -- and he told me
that it was his jacket. And I say, Yeah, I was cold. And he say, Oh, thats okay.
MR. ZONEN: May I approach the witness, Your Honor?
THE COURT: Yes.
Q. BY MR. ZONEN: I have two photographs previously shown to counsel. Id like to show
you these two exhibits, if I can. Exhibit No. 781 and Exhibit No. 782. And do you see the
numbers here? This is 781 and thats 782. Im going to put them both in front of you.
A. Uh-huh.
Q. And then Ill go back. 781, would you pick that one up, please, and tell us what that
photograph is? Take a look at it.
A. That was one of his school pictures.
Q. And who is he?
A. My son.
Q. Your son Jason. How old was Jason in that photograph?
A. I would say about ten.
Q. About ten years old? Do you remember that photograph being taken?
A. No.
Q. But you do recognize him?
A. Yes.
Q. Is that an accurate photograph of Jason when he was about ten years old?
A. Yes.
Q. All right. Look at the another one now, please, I think 782. And what is that a photo of?
A. My son and I.
Q. All right. The two of you together?
A. Yes.
Q. All right. Is that photograph dated?
A. Yes.
Q. Whose handwriting is that?
A. Mine.
Q. Okay. And what is the date on that?
A. 1994.
Q. And your son was -- what was the month on that?
A. The month is March.
Q. March? Its written in Spanish, is it not?
A. Yes.
Q. But its March 19 -A. 94.
Q. 94. And how old was he at that time?
A. About 14.
Q. All right. He would turn 14 in May of 94?
A. Uh-huh.

Q. So he was 13 at the time; is that right?

A. 13.
Q. Is that photograph an accurate photograph of your son at that time?
A. Yes.
MR. ZONEN: Your Honor, I would move both of those exhibits into evidence.
MR. MESEREAU: No objection.
THE COURT: Theyre admitted.
MR. ZONEN: Id ask to publish them at this time.
THE COURT: All right.
Q. BY MR. ZONEN: Well start with 781. Could we dim the lights, if we could? And could
you take a look over your shoulder and tell us, is that the photograph that you identified?
A. Yes.
Q. And how old was he at that time again?
A. About ten.
Q. About ten. And then the second photograph, 782. And he was at that point 13?
A. Yes.
Q. All right. Was that about the time that he was being interviewed by law enforcement?
A. Yes, I think.
MR. ZONEN: Thank you. I have no further questions.
THE COURT: Cross-examine?
MR. MESEREAU: Yes, please, Your Honor. If I may take a second, Your Honor, just to set
up.
THE COURT: Yes, you may.
MR. MESEREAU: Thank you.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. Maam, Ill say good morning, but I think its afternoon. Okay? My name is Tom
Mesereau and I speak for Mr. Jackson, okay? We met for the first time at the break, right?
Weve never spoken before that, right?
A. No.
Q. All right. Now, if anything -- if anything I ask you is unclear, p lease dont answer it,
okay? Just say you dont understand. Okay?
A. Okay.
Q. And if you dont understand, Ill try and rephrase it -A. Uh-huh.
Q. -- to make it more understandable, okay? If youre not sure about what Im asking,
just dont answer. Just make sure its clear in your mind what Im asking for, okay? You
know Im on his side, okay?
A. Okay.
Q. Mr. Jackson, all right? Now, you began working for Mr. Jackson in 1986; is that correct?
A. Yes.
Q. And do you know approximately what month that was?
A. No.
Q. Okay. And you stopped working for Mr. Jackson in approximately 1991, right?
A. Yes.
Q. And you never worked for him since you stopped working in 1991, right?
A. No. I never went back.
Q. Okay. Now, you testified that in the apartment owned by Mr. Jackson that you referred

to as The Hideout, there was no furniture, right?

A. Uh-huh.
Q. Was there any bed in there at all?
A. No.
Q. Okay. And approximately when were you cleaning that apartment as part of your work?
A. Do you mean how long would it take me to clean or -Q. No, no, let me rephrase it. During what period of time do you remember you were
going to that apartment and cleaning it?
A. Probably a year. I dont remember.
Q. And would you go to clean that apartment when Mr. Jackson was not there?
A. Yes.
Q. Do you remember Mr. Jackson going on what was called a Bad tour; do you
remember that?
A. Yes.
Q. Do you remember Mr. Jackson produced an album and a videotape called Bad?
A. Yeah. Yes.
Q. And do you remember he was traveling on that tour from approximately September of
1987 to January of 1989?
A. Yes.
Q. And during that period of time he was often out of the country, wasnt he?
A. Yes.
Q. And he told you about where he was going, didnt he?
A. Yes.
Q. He told you he was going to Japan, right?
A. Yes.
Q. Australia, right?
A. Yeah.
Q. And a lot of cities in America, right?
A. Yes.
Q. New York, right?
A. Yes.
Q. Indianapolis? Went to Texas? Georgia?
MR. ZONEN: Ill object as beyond the scope of her knowledge; lack of foundation.
THE WITNESS: I dont know.
MR. MESEREAU: I think shes answering she did know, Your Honor.
THE WITNESS: He told me he was on tour, but -MR. ZONEN: Theres an objection.
THE WITNESS: You know -THE COURT: The only one she said she didnt know were the last two, so Ill overrule the
objection.
Q. BY MR. MESEREAU: So you knew he traveled to Italy on that tour, correct?
MR. ZONEN: Im going to object on lack of foundation or based on hearsay.
MR. MESEREAU: State of mind, Your Honor. Ill be happy to rephrase it if the Court
wants.
THE COURT: The objection is overruled.
Q. BY MR. MESEREAU: Did you know that he traveled to Italy on that tour as well?
A. No.
Q. How about Austria?

A. I dont remember.
Q. And England?
A. I dont remember.
Q. Do you remember he went to a lot of countries -A. Yes.
Q. -- on that tour? And he told you that, didnt he?
A. Yes.
Q. And that tour lasted almost a year and a half, d idnt it?
A. Not really. I didnt stop seeing him for a year and a half.
Q. But he was out of the country much of the time, wasnt he?
A. Yeah.
Q. And he was out of Los Angeles much of the time?
A. Out of -- yes.
Q. Now, you didnt often see him -- excuse me. Let me rephrase that. Do you remember
him staying overnight at the hideout apartment?
A. Yeah.
Q. Okay. And he didnt like to invite other people to that apartment, right?
MR. ZONEN: Ill object as speculative; lack of foundation.
MR. MESEREAU: Ill rephrase.
Q. Do you know whether or not Mr. Jackson liked to keep his presence at that apartment
private?
MR. ZONEN: Objection; speculative.
THE COURT: Overruled. You may answer.
THE WITNESS: I dont know.
Q. BY MR. MESEREAU: Okay. Okay. But you didnt see him invite lots of people to that
apartment, did he?
A. No, I didnt see many people.
Q. Okay. And you were the only one that would clean that apartment, right?
A. Yeah.
Q. And did you used to help Mr. Jackson prepare when he was leaving town for the Bad
tour?
A. Yes.
Q. And what did you used to do for Mr. Jackson to help him?
A. Pack his stuff, his makeup, his clothes, and shine his shoes.
Q. And he went on approximately 123 concerts during that period, didnt he?
A. I dont know.
MR. ZONEN: Im going to object as lack of foundation.
Q. BY MR. MESEREAU: Do you know how many -THE COURT: She said, I dont know, so next question.
Q. BY MR. MESEREAU: Okay. When you used to clean the home at Havenhurst in Encino
-- okay?
Havenhurst is a street, right?
A. Yes.
Q. And that was where Michael Jacksons parents lived -A. Yes.
Q. -- right? Did other family members live there at the time you were cleaning that house?
A. I think Janet was still there. And LaToya.
Q. Okay. So to your knowledge, at the time you cleaned that house, his parents, Janet,

LaToya and Michael were living there, right?

A. Yeah.
Q. And would you go there every day?
A. Yes.
Q. Okay. And were there other people besides you that cleaned the house?
A. Not at that time. They didnt have a housekeeper. I mean, they have one, but it quit
after about two months.
Q. Did you appear to be the primary housecleaner?
A. Well, while Mr. Jackson was on tour, I end up staying, cleaning the house too.
Q. Okay. So when he was out of town, you would still go there to work, right?
A. Yeah.
Q. Now, would you bring Jason there when -A. Yes.
1 Q. -- when Mr. Jackson was out of town?
A. Yeah.
Q. And where would Jason typically be when you worked at the house while Mr. Jackson
was out of town; do you know?
A. Outside in the arcade room. At the house.
Q. Okay. And would you see Mr. Jacksons parents when you used to clean the house?
A. Yes.
Q. Okay. Would you see Janet?
A. Sometimes.
Q. And how about LaToya?
A. Yeah, sometimes.
Q. Okay. And what areas of the house did you used to clean?
A. The whole house.
Q. Okay. Every day?
A. Yeah. If there was nothing else to do.
Q. Now, how long did you work -- excuse me. Let me rephrase that. For how long a period
of time did you clean the house at Havenhurst?
A. While he was on tour, I guess. I dont remember. But it was many months, because Bill
Bray told me that at least its going to be about six months that he was going to be out of
-- out of the country, and either I be laid off or work at the house.
Q. Okay. And did there come a point in time when you stopped cleaning the house on
Havenhurst?
A. Yes.
Q. And approximately when was that, if you remember?
A. No.
Q. Okay. Was it 1986, do you think?
A. No.
Q. 1987?
A. 1987, yeah.
Q. Do you think it was 1987?
A. Yeah.
Q. Okay. When you stopped cleaning the house at Havenhurst, you kept working for Mr.
Jackson, right?
A. Yes.
Q. And what did you do for Mr. Jackson after you stopped cleaning the house on

Havenhurst?
A. Well, went back to my same routine. Cleaning his room and mainly being there. Even if
I didnt have anything to do, he wanted me in his room.
Q. Okay. And which room are you talking about now?
A. His bedroom.
Q. Okay. His bedroom now?
A. In Encino.
Q. In Encino, okay. Okay. So Mr. Jackson would leave town, but always wanted you to still
come to the house and do your work, right?
A. Yes.
Q. And you said that Mr. Bray told you something about you might lose your work?
A. No, no, no. He told me that I either be laid off or -- well, probably its the same thing,
or work at the house.
Q. Okay. Okay. W hen you stopped working at the house on Havenhurst, what were you
doing then for Mr. Jackson?
A. When I stopped working at the Havenhurst -- do you mean at the house?
Q. Yes. You kept working for Mr. Jackson, right?
A. Yes.
Q. And what were you doing then?
A. The same thing I was hired to do for him. Pick up his clothes.
Q. And where were you doing that?
A. Cleaning his room. At the Havenhurst.
Q. No, no, after you stopped working at Havenhurst.
A. Oh.
Q. Okay?
A. Uh-huh.
Q. You worked at Havenhurst for a while, right?
A. Yeah.
Q. And then at some point you stopped cleaning Havenhurst, didnt you; is that right?
A. Yeah, but we still live there -- I mean, he still live there at the Havenhurst.
Q. Okay. Im sorry. Maybe Im confusing you. There was a point in time when you didnt
clean Havenhurst anymore; is that right?
A. Uh-huh.
Q. And approximately when was that, do you think?
A. No, I dont remember.
Q. Okay. You did work at Neverland at one point, right?
A. Yeah, that was back after about three years.
Q. And when you worked at Neverland, were you still working at Havenhurst?
A. When I still working -Q. Im sorry?
A. -- at Neverland?
Q. Yes. Let me rephrase the question. When you were working for Mr. Jackson at
Neverland - okay? - were you still doing work at the home on Havenhurst?
A. No.
Q. You were working full time at Neverland then, right?
A. No.
Q. No?
A. I would go to the hideout.

Q. Okay.
A. And sometime he will tell me to go to Havenhurst to get stuff, or retrieve something, or
-Q. So when you were living at Neverland and working at Neverland, you still would
sometimes go to Havenhurst, right?
A. Yes. Sometimes.
Q. But most of the time you did your work at Neverland, right?
A. Neverland and the hideout.
Q. Okay. Okay. Now, Mr. Jackson was very generous to you, wasnt he?
A. Yes.
Q. He gave you a couple of televis ions; is that right?
A. Yes.
Q. And you would also ask him from time to time if you could take something, and he
would often say Yes, right?
A. (Nods head up and down.)
Q. What are some of the things that you asked him that youd like to have?
A. Knickknacks. And clothes. He gave me a couple of jackets from his tour, I think. I dont
remember. It was -- there were a lot of stuff.
Q. And did he give you any cash himself?
A. I dont remember.
Q. Didnt he give you approximately $5,000 total at one point?
A. I dont remember.
Q. Wouldnt he give you 500 or 300 or $200 at a time?
A. I dont remember.
Q. Do you remember saying that in your deposition with Mr. Feld man?
A. Yeah. I probably did, yeah.
Q. So let me ask you what you remember.
A. Uh-huh.
Q. Do you remember Mr. Jackson giving you 500 or 300 or $200 at a time?
A. He probably did, but at this time I dont rememb er.
Q. Okay. Do you remember saying in your deposition that, in total, he may have g iven
you $5,000?
A. I probably did.
Q. Okay. Does that sound accurate to you?
A. Yeah, probably, I did. It wasnt that much, probably, but I dont remember how much
he gave me.
Q. Okay. But would you ask him for cash sometimes?
A. No.
Q. Would he just volunteer and give it to you?
A. I dont remember that, you know. I dont - I dont -- I think so, but I dont remember.
Q. Okay. Im probably not being clear. Im asking why Mr. Jackson gave you money.
Would you ask him for money once in a while?
A. I think I did -- I dont remember.
Q. Okay. But you do remember him giving you money from time to time, right?
A. Yeah.
Q. Okay. And youre not sure of the total, right?
A. No.
Q. Okay. And did he give you money from time to time during the entire period that you

worked for him?

A. Someone -- yeah.
Q. Okay. And you dont recall him ever saying No if you ever told him you needed some
money, did he?
A. No.
Q. Okay. He always was generous with you with money, wasnt he?
A. Yeah. Yes.
Q. Okay. All right. Now, your deposition was taken in 1993, right? Do you remember that?
A. I dont remember.
Q. Okay.
A. But I think it was 94. I dont remember.
Q. Would it refresh your recollection if I just show you the transcript with a date on it?
Would that help you remember?
A. I mean, Ill read it and -- I know that it was that, but I dont remember.
Q. If you saw the transcript, might that help you remember? Would you like to see it?
A. Yeah. I mean, you can put whatever that you want to and I will say probably.
Q. No, I dont want to do that. Would it help refresh your recollection -A. No.
Q. -- if I just show you the date on the deposition?
MR. ZONEN: Your Honor, Id be prepared to stipulate to the two dates of the transcript.
MR. MESEREAU: Okay. Sure.
MR. ZONEN: And the first date is December 15, 1993.
MR. SNEDDON: Cant hear you.
MR. ZONEN: The first date -MR. SNEDDON: Turn it on.
MR. ZONEN: We make this complicated, dont we? The first date is December 15, 1993.
The date of the second day of the deposition was January 11, 1994. I would so stipulate.
MR. MESEREAU: So stipulated.
THE COURT: All right. Ill approve that stipulat ion.
THE WITNESS: I do remember 94. But I dont remember the dates.
Q. BY MR. MESEREAU: Okay. Okay. Do you remember in your deposition saying you had
never seen Mr. Jackson touch anyone improperly?
A. Yeah, I -Q. Do you remember saying you never saw him touch anyone?
A. Yeah.
Q. You did say that, didnt you?
A. Yes.
Q. Okay. And in that deposition, you told the truth, right?
A. As -- as I recall it at that time, yeah.
Q. You told the truth at that time, right?
A. As I remember it.
Q. Yes. And you were under oath, right?
A. Yes.
Q. Okay. And you said that you had never seen Michael Jackson touch anyone in a sexual
way, right?
A. Yeah.
Q. Okay. And you said at no time while you worked for Michael Jackson did you ever see
him have sexual contact with anyone, right?

A. When I say sexual, I mean sexual.

Q. But you did say under oath that you had never saw Mr. Jackson have sexual contact
with anyone, right?
A. No. No.
Q. Isnt that what you said?
A. Yeah, yeah, thats what I said.
Q. Okay. Now, you mentioned that Mr. Jackson has a Jacuzzi, right?
A. Where at? At the Havenhurst?
Q. Well, lets start with Havenhurst.
A. Uh-huh.
Q. Did Mr. Jackson have a Jacuzzi at Havenhurst?
A. Yes.
Q. And just tell the jury where the Jacuzzi was, please.
A. Its outside his patio.
Q. Okay.
A. Outside of his bedroom.
Q. And did various family members use that Jacuzzi?
A. No.
Q. Did you ever see anyone use that Jacuzzi at Havenhurst?
A. Only Mr. Jackson.
Q. And it was outside?
A. Yes.
Q. Okay. Can you see that Jacuzzi from the house?
A. No.
Q. Can you see it from any windows?
A. Not from the house. From a separate -- from a separate -- from -- I think from up on
the garage, you can see it, but its not a bedroom.
Q. Did you ever see Mr. Jackson in that Jacuzzi at Havenhurst?
A. I remember one time.
Q. One time seeing Mr. Jackson use the Jacuzzi at Havenhurst?
A. Yeah.
Q. Okay. But you didnt see anyone else ever use it?
A. There was a little -- a boy there.
Q. Did you ever see his parents use the Jacuzzi?
A. Whose parents? Michael?
Q. Yeah.
A. No.
Q. Did you ever see Janet use it?
A. No.
Q. Ever see LaToya use it?
A. No.
Q. Ever see anyone use it besides Mr. Jackson?
A. No.
Q. All right. Was there a Jacuzzi at Neverland?
A. Well, inside his bedroom there is a bathroom with a Jacuzzi in it.
Q. Okay. And you saw Mr. Jackson use that Jacuzzi, didnt you?
A. Yeah.

Q. Is it downstairs or upstairs in his bedroom area?

A. Downstairs.
Q. Its downstairs; is that right?
A. His bedroom, yeah.
Q. Okay. Now, the prosecutor asked you questions about Mr. Robeson, okay?
A. Uh-huh.
Q. And did you say that Mr. Jackson was sleeping on a bed in the lower level of his
bedroom?
A. Yes.
Q. Okay. You didnt see him sleeping in th bedroom on the upper level?
A. No.
Q. And was it your belief that during the time you worked at Neverland, that Mr. Jackson
only slept on the bed on the lower level?
A. Yes. There were times that the other bed was used.
Q. Okay.
A. But I never saw him in that bedroom.
Q. So you would see the bed upstairs used, but you didnt know who had used it, right?
A. No.
Q. You would see the bed downstairs used, but you didnt know who used it, right?
A. It was time when it was just one -- one bed was undone.
Q. Sometimes, right?
A. Sometimes.
Q. And sometimes there was a bed upstairs that seemed undone, right?
A. Yeah.
Q. And you were responsible for making both beds, right?
A. Yes.
Q. Okay. Have you ever seen Mr. Jackson lying on his bed watching television?
A. Yeah. A couple of times.
Q. How many times did you see Mr. Jackson lying on his bed watching television?
A. Probably a couple of times.
Q. And you would see him watch videos also, right?
A. Yeah.
Q. Were you often in Mr. Jacksons room when he was watching television?
A. No.
Q. You typically cleaned his room when he wasnt there, right?
A. Yeah.
Q. Is that true?
A. Yes.
Q. And it was your understanding that you were supposed to clean his room when he
wasnt in there, right?
A. No.
Q. Was it your understanding that you werent supposed to go in when Mr. Jackson was in
the room?
A. Yeah. Sometimes Ill unlock his room and hell be there, and he tell me that it was okay
to come in.
Q. Okay. And sometimes you would unlock his door, hed ask you not to come in, right?
A. Yeah.
Q. Most of the time when you cleaned his room at Neverland, he wasnt in it, right?

A. Most of the time when he wasnt in?

Q. Let me rephrase. Let me rephrase. During the time you worked at Neverland, most of
the time when you cleaned his room, he wasnt in there, right?
A. Yeah.
Q. You okay? Do you want some water?
A. Huh?
Q. Do you want some water?
A. No, thats okay.
Q. Was it your understanding that when you cleaned Mr. Jacksons room you were usually
supposed to do it when he wasnt around?
A. Yeah.
Q. Okay. Okay. And if you opened the door and he was in there, you would ask for
permission to come in, right?
A. Yes.
Q. Okay. Now, his bedroom is a very big area, isnt it?
A. Yes.
Q. How would you describe it?
A. Big.
Q. Very big, isnt it?
A. Uh-huh. Yeah.
Q. And how do you get into his bedroom? If youre going -- let me rephrase it. If youre
going into Mr. Jacksons room, what do you have to do to get in?
A. Open the door with a key.
Q. Okay. And is that what you would typically do?
A. Yes.
Q. Was there any kind of a bell that would ring?
A. Yes.
Q. And would the bell always ring when you entered?
A. Yeah. But it -- it doesnt have a -- you know, it would ring just once.
Q. Right. Just one ring? A. And then close, yeah.
Q. Would you then stop it? Would you shut the bell off?
A. I used to unplug it.
Q. You unplugged it. Okay. So youd hear a ring, and then you would unplug it; is that
right?
A. Well, you have to unplug it from the inside of the bedroom.
Q. So youd open the door, right, with a key?
A. Yeah.
Q. The bell would go off, and then you would unplug it, right?
A. When I was there by myself, I used to unplug it.
Q. Okay. Okay. And then it would stop ringing, right?
A. And it would stop ringing, yeah.
Q. And then you would do your cleaning, right? Is that right?
A. No.
Q. Tell me what -A. Ill get there -Q. Yes.
A. -- and then -- once I get there, I unplug it, because when people get close to it, it
rings. But it rings, and then it rings one time, it doesnt ring anymore.

Q. Okay. Okay. To stop it from ringing, you would unplug it?

A. Yeah.
Q. Okay. Okay. A ll right. Now, do you know who Quincy Jones is?
A. Yes.
Q. And whos Quincy Jones?
A. A writer, I think.
Q. Okay. And his daughter used to visit Michael, right?
A. At Havenhurst.
MR. ZONEN: Beyond the scope of the direct, and irrelevant.
THE COURT: Overruled. Go ahead.
THE WITNESS: At Havenhurst?
Q. BY MR. MESEREAU: Yes.
A. I think she was there a couple of times.
Q. Her name was Kidada, right?
A. I dont know.
Q. But you saw her visit Michael, correct?
A. Yes.
Q. Did you ever see -- do you know who Lionel Ritchie is?
A. Yes.
Q. Did you ever see his daughter visit the Jacksons?
A. Not at Havenhurst.
Q. Okay. Did you see her visit Michael?
A. Him I remember visiting.
Q. You remember him visit ing Michael. You dont remember his daughter?
A. No.
Q. Okay. Before you testified today, did you meet with any prosecutor to discuss what you
were going to be asked?
A. Yeah.
Q. And when did that meeting take place?
A. Saturday.
Q. And who did you meet with?
A. I dont remember his name.
Q. Pardon me?
A. Ron, I think.
Q. Prosecutor Zonen?
A. And another one.
Q. Okay. And how long did the meeting take p lace?
A. Couple of hours.
Q. And how many people were there meeting with you?
A. Just the two of them.
Q. Did they tell you what they were going to ask you in court?
A. They -- they went to what I say before.
Q. Did they discuss the questions they were going to ask you today?
A. Kinda.
Q. And did they discuss your answers with you?
A. No. They told me about, you know, what I say in my deposition before, and if I
remember, and there was stuff that I didnt remember.
Q. Did they give you a copy of your deposition to look at?

A. No.
Q. Did they appear to be reading from your deposition?
A. No.
Q. Okay. Did they have any documents they showed you?
A. Yeah. They gave me a paper of things that I say when I talk to another detective.
Q. Okay.
A. Not -- not at my deposition.
Q. Okay. So it was a paper that they gave you to look at?
A. Yeah.
Q. And what was on that paper, if you remember?
A. When I talked to the other detectives, they came, you know, at the beginning.
Q. Okay.
A. The first time.
Q. Do you remember meeting with a lawyer named Larry Feldman?
A. Yes.
Q. And you met with Larry Feld man before your deposition was taken, right?
A. Yes.
Q. And he came out to see you, didnt he? Let me rephrase it. Maybe you dont
understand.
A. Yeah, I understand.
Q. You do?
A. But I dont remember. Yeah, I think he d id. He came to my house, I think.
Q. He came to your house, didnt he?
A. (Nods head up and down.)
Q. And he wanted to speak to you before your deposition was taken by him, right?
A. Yes. Yes.
Q. Okay. And obviously that was quite a while ago, right? Was that around 1993
sometime?
A. Yes.
Q. Okay. Do you remember how much time L arry Feldman spent with you?
A. No.
Q. Do you remember if it was a long time?
A. I dont remember.
Q. Okay. Was that the only time you met with Attorney Larry Feldman?
A. No. Then I was taken to L.A., and I -Q. Did you meet with him again?
A. Yeah, for the deposition.
Q. Okay. And he was giving you some advice during the deposition, wasnt he?
A. I dont remember. I dont think so.
Q. Didnt he advise you from time to time during that deposition?
A. I dont remember. There were a lot of people talking to me at that one.
Q. And he was one of them talking to you, wasnt he?
A. Yes.
Q. And you said that deposition went more than a day, right?
A. Yeah. It was twice.
Q. Okay. And was it after that deposition that you first spoke to an attorney named Terry
Cannon?
A. That was -- that was after. After when Mr. Cochran told me that my son was going to

be subpoenaed and I would have to bring him.

Q. Okay. And then you went to hire an attorney, correct?
A. Then I -- yeah, then I talked to Terry.
Q. Okay. And has he been your lawyer ever since?
A. Yes.
Q. Okay. Has he been your sons lawyer ever since?
A. Yes.
Q. Okay. When did you last talk to Terry Cannon?
A. I think it was December or November. I dont remember. It was in December.
Q. Last December?
A. Last December.
Q. Okay. Okay. And do you remember having a meet ing with Prosecutor Zonen and Terry
Cannon last year?
A. On December? It was -- Zonen? I dont know his last name. He was a tall guy.
Q. Prosecutor Zonen, who you see right here -A. Oh.
Q. -- do you remember meeting with him?
A. Oh. Yeah, I think he was -- he was there, too. Thats when they gave me that
deposition.
Q. Okay. Okay. In your deposition, you said that you had never seen Mr. Jackson molest a
child, right?
MR. ZONEN: Objection; asked and answered.
THE COURT: Overruled.
Q. BY MR. MESEREAU: In your deposition, you said under oath you had never seen Mr.
Jackson molest a child, right?
A. Molest a child? No. Yeah, I say that.
Q. Okay. Was it after that deposition that you were interviewed by Hard Copy?
A. No.
Q. It was before?
A. Oh, before I met with him, with -- at my deposition? No, that interview was before.
Q. So the interview with Hard Copy was before the deposition -A. Yes.
Q. -- right? And thats the interview you were paid $20,000 -A. Yes.
Q. -- to do, right?
A. Yes.
Q. And thats the interview that you had your friend Evangeline help you arrange, right?
A. Yes.
Q. And then after you were paid, you said you paid her some money, right?
A. Yeah.
Q. Okay. Okay. D id you ever talk to anyone from The National Enquirer?
A. No.
Q. Is Hard Copy the only media -A. Yeah.
Q. -- group that you ever met with?
A. Yeah. I guess someone tried to -- someone contacted me from National Enquirer, I
think, and from Los Angeles Time.
Q. In your deposition, you said the people from Hard Copy are not honest, right?

A. Yeah.
Q. When did you last talk to anyone from Hard Copy?
A. When did I -- recently?
Q. Let me rephrase it.
A. Uh-huh.
Q. After your interview with Hard Copy, did you ever talk to them again?
A. No.
Q. Okay. Did you tell Attorney Larry Feldman that you were going to be interviewed by
Hard Copy?
A. No.
Q. And Evangeline worked at Neverland, right?
A. Yes.
Q. Did you tell anyone else who worked at Neverland, besides Evangeline, that you were
going to be paid to interview with Hard Copy?
A. No. Not that I remember.
Q. Now, at some point you learned -- let me rephrase that, excuse me. Let me start
again. After your interview with Hard Copy appeared on television - okay? - at some point
you learned that other employees at Neverland now wanted to be paid to go on television
to talk about Mr. Jackson, right?
A. Did I know that?
Q. Yes.
A. No.
Q. After you hired a lawyer -A. Uh-huh.
Q. -- you learned that other employees at Neverland started hiring lawyers, right?
MR. ZONEN: Ill object. Lack of foundation; speculat ive.
THE WITNESS: I dont remember that.
THE COURT: Wait. The objections overruled.
Q. BY MR. MESEREAU: Did you learn at some point after your Hard Copy interview was
on televis ion, that now other people who worked for Michael Jackson were hoping they
could make money doing media interviews like you did?
MR. ZONEN: Objection; speculative.
THE WITNESS: No, I didnt know that.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Did you discuss your Hard Copy interview with anyone besides
Evangeline at Neverland?
A. I dont remember, no.
Q. Okay.
A. No.
Q. Okay. Who did you work for at Neverland?
A. Did I work for?
Q. Besides Mr. Jackson. I mean, who did you work -- let me rephrase it. Obviously you
worked for Mr. Jackson, but did you report to other people?
A. Did I report to other people? Oh.
Q. As part of your job.
A. I was working as part of the household, housekeepers.
Q. And who did you work with; do you remember?
A. The workers? I dont remember their names. But I -- I --

Q. Okay. Now, the Hard Copy interview was in 1993, right?

A. Yes.
Q. It was in December of 1993, right?
A. Yes.
Q. And you stopped working in 1991, right?
A. (Nods head up and down.)
Q. So after you left -- after you stopped working for Mr. Jackson, you stayed in touch with
some people who worked for Mr. Jackson, right?
A. No.
Q. What about Evangeline?
A. But she wasnt working there no more.
Q. When did she stop?
A. Before me.
Q. Was she in touch with people at Neverland?
MR. ZONEN: Objection; speculation.
MR. MESEREAU: To your knowledge.
THE WITNESS: Not that I know.
MR. ZONEN: Theres an objection.
THE COURT: To her knowledge. Ill limit it. She answered no, not that she knows.
Q. BY MR. MESEREAU: Did you talk to any representative of the media before you had
your deposition taken?
A. Did I -- did I talk -Q. Im -- yes, let me rephrase it.
A. Uh-huh.
Q. And if Im unclear, just tell me, and Ill try and say it again. You said your interview
with Hard Copy was after the deposition, right?
A. No. It was before.
Q. It was before. Okay. How long before it, if you know?
A. About a month.
Q. Okay. Did you discuss the fact that you were going to be interviewed by Hard Copy
with any attorney?
A. No.
Q. Okay. Do you remember Evangeline saying to you, Would you like to go to The
National Enquirer?
A. I dont remember.
Q. Pardon me?
A. I dont remember. I remember a guy called me, but he never told me that someone
refer me or -Q. But didnt Evangeline suggest that you call The National Enquirer?
A. No.
Q. She didnt? She didnt ask you, Do you want me to find The Enquirer?
A. I dont remember that, no.
Q. Would it refresh your memory if I just show you a transcript -A. Uh-huh.
Q. -- of your deposition?
A. Oh, okay.
Q. Can I do that?
A. Yeah.

MR. MESEREAU: May I approach?

THE COURT: Yes.
MR. ZONEN: What page, Counsel?
MR. MESEREAU: 208.
Q. Have you had a chance to look at that page?
A. No. Oh. (Laughter.)
Q. Youve had a chance to look at the page, right?
A. Did I what?
Q. Have you had a chance to read that page of your deposition?
A. Before today?
Q. No, no, today.
A. Oh, yeah.
Q. Okay. I just showed you the page, right?
A. Yeah.
Q. Have you had a chance to look at it?
A. Yeah.
Q. And does it refresh your memory about what Evangeline said to you?
A. You know, tell you the truth, I probably did at that time. And I remember at the time,
but this time I dont remember.
Q. Okay.
BAILIFF CORTEZ: Maam, speak into the mike.
THE WITNESS: Oops.
Q. BY MR. MESEREAU: Didnt you tell Evangeline that you were willing to talk to The
Enquirer?
A. I dont remember.
Q. Okay. Would it refresh your recollection just to look at the page?
A. No.
Q. It wouldnt? So even if you read the page, it wont help, do you think?
A. It wont help me.
Q. Okay. Okay. But you dont remember what you said to Evangeline about talking to The
Enquirer?
A. I dont even remember the who le sit -- I dont remember.
Q. Okay.
A. It was a lot -- at that time, you know, it was -Q. Evangeline called Hard Copy for you, right?
A. Uh-huh. Yeah, I think so.
Q. And she did it for you, right?
A. Yeah, I think she did.
Q. You wanted her to find a way to commun icate with Hard Copy, right?
A. Yeah.
Q. Okay. And you wanted to talk to either Hard Copy or The Enquirer, right?
A. I dont remember if it was either of them, but I remember that I say yeah.
Q. Okay. Okay.
A. Because I think they approach her first, someone approach her. And she said, Well,
they want to talk to you, too. Thats what I got.
Q. Did you have an understanding with Evangeline that if she arranged these interviews
for you, that you would pay her?
A. That I would pay her?

Q. Yes.
A. No.
Q. Did you believe she was just doing it as a friend?
A. Yeah.
Q. Okay. So you didnt have any arrangement with her that you would split the money,
right?
A. No.
Q. You gave her some money later on because you appreciated what she had done for
you, right?
A. Yeah. Yeah, because of the trouble that she was going -- you know, she did, yeah.
Q. Okay. So you gave her money as a friend, right?
A. Yeah.
Q. Okay. There was no understanding before the interview with her how much she would
get?
A. No.
Q. Okay. Okay. Now, Evangeline told you that she had reached Diane Dimond of Hard
Copy, right; is that right?
A. Yes.
Q. And Evangeline arranged for you to meet with Diane Dimond, right?
A. Yes.
Q. How many meetings did you have with Diane Dimond with Hard Copy?
A. I think it was just one.
Q. Do you remember going to the Hilton Hotel?
A. My -- yes.
Q. Is that where you saw Diane Dimond during a meeting?
A. Yes.
Q. And thats the meeting Evangeline went with you to, right?
A. Yes.
Q. You told Diane Dimond during that interview that you never told anyone that you had
ever seen Michael Jackson molesting boys, right?
A. Yes, I believe so.
Q. And it was Evangeline that negotiated how much money you were going to get, right?
A. Yes.
Q. You learned that you were going to get $20,000 from Evangeline, right?
A. From Hard Copy.
Q. Yeah.
A. Not from Evangeline.
Q. Let me rephrase it to make sure you understand.
A. Yeah.
Q. You learned from Evangeline that you were going to get $20,000 for the interview with
Hard Copy, right?
A. Yeah.
Q. Is that correct?
A. Yes.
Q. Evangeline was supposed to speak to Hard Copy about the money you were going to
get, right?
A. Yes.
Q. So she was really your assistant, wasnt she?

A. Yeah.
Q. Okay. If you remember, how long was the meeting at the Hilton Hotel with Diane
Dimond?
A. About three hours, probably.
Q. Okay. Were there other people at that meeting as well?
A. I dont remember. I dont think so.
Q. Do you know if you were g iven a contract to sign?
A. I signed it, but I dont remember at what time I did, if it was during that time or after
the interview.
Q. But you did sign the contract with Hard Copy -A. Yeah.
Q. -- right?
A. Yes.
Q. How did you get that contract?
A. How did I what?
Q. How did you get a copy of that contract?
A. I guess they give it to me.
Q. Okay. Did Miss Dimond give it to you directly or did Evangeline give it to you?
A. No.
Q. Pardon me?
A. Miss Dimond gave it to me, I think.
Q. At the meeting?
A. I dont remember. It was during the -- in the room.
Q. Okay. And you were asked to sign that contract in that room before you left, right?
A. Yeah, I guess so.
Q. Is that what you remember?
A. Thats what I remember. I dont know.
Q. Okay. Okay. The day after you were interviewed by Hard Copy, Miss Dimond called you
again, right?
A. The day after?
Q. Yes. The day after your interview with Hard Copy, Ms. Dimond called you again, right?
A. I dont remember.
Q. Okay.
A. I dont remember her calling me, but I dont remember if it was the next day or -Q. Do you remember her wanting pictures of Michael Jackson?
A. Yeah.
Q. Ms. Dimond wanted you to get her pictures of Mr. Jackson, right?
A. I dont remember.
Q. Do you remember that?
A. I think I give it to her, but I dont remember.
Q. Okay. Do you remember saying to Ms. Dimond you dont have pictures of Michael
Jackson?
A. I dont -- ask that -Q. Im sorry, I may not be explaining it properly. Let me just rephrase the question. Ill
withdraw the question.
A. Uh-huh.
Q. The day after you interviewed with Hard Copy, Miss Dimond called you on the phone,
right?

A. I dont remember.
Q. Well, after the interview with Hard Copy, do you remember at some point in time Miss
Dimond called you?
A. I dont remember.
Q. Okay. Do you remember Miss Dimond ever asking you to get her pictures of Michael
Jackson?
A. I dont remember, but I give it to her sometimes. Or one time, I guess, she got some
pictures of him.
Q. And was that part of your contract with the show Hard Copy, that you would give them
pictures?
A. Yeah -- yes.
Q. Okay. And when they paid you $20,000, was part of what you had to do to give them
pictures?
A. Yes. I guess.
Q. Do you remember sending any pictures of Mr. Jacksons animals to Hard Copy?
A. I think all the pictures I got, I give her, it was me with animals, probably. But it was me
mostly. Not of animals.
Q. Did you send pictures of Mr. Jacksons lion?
A. No.
Q. How about his tiger?
A. Not -- I was in the picture, but it wasnt by itself of the -Q. Okay.
A. -- tiger.
Q. You gave Ms. Dimond a picture of your son with Mr. Jackson, right?
A. With Mr. Jackson? I dont remember, but I -- no, I dont remember.
Q. Would it refresh if I just show you the transcript of your deposition?
A. Uh-huh.
MR. MESEREAU: Okay. May I approach, Your Honor?
THE COURT: Yes.
MR. ZONEN: Page nu mber, Counsel?
MR. MESEREAU: 231.
MR. ZONEN: 231?
Q. BY MR. MESEREAU: Have you had a chance to review that page of your deposition?
A. Yes.
Q. And you said under oath during the deposition that you gave Ms. Dimond a picture of
your son and Mr. Jackson, right?
A. Yes.
Q. Okay. And you could -- you didnt think people would notice your son on the show,
right?
A. Yeah. Probably. Probably, yes.
Q. You said in the deposition you didnt think anybody would recognize who your son was
on the Hard Copy show, right?
A. Yeah. Probably I said that.
Q. Thats what you said, right?
A. I probably -- yes.
Q. Okay. Now, at some point, you called Diane Dimond and she didnt return your calls,
right?
A. Yeah.

Q. You called her because you thought she had lied, right?
A. She had lied?
Q. Yes.
A. I didnt like -- I thought that -- that Hard Copy interview thing was going to be shown
on Hard Copy, and then I see my pictures everywhere, and even in The Nat ional Enquirer,
and thats what I thought that it was. You know, I didnt know that they can sell the story
to someone else. Thats how I felt.
Q. Do you remember telling Ms. Dimond that you had other pictures from Neverland
Ranch -A. I dont remember.
Q. -- that you could get? Do you remember that?
A. No, I dont remember.
Q. Do you remember Miss Dimond telling you she could send a messenger to get other
pictures that you had of Mr. Jackson?
A. I dont remember that.
Q. Okay. You gave Ms. Dimond pictures of Mr. Jackson after your interview, right?
A. I dont remember.
Q. You dont remember if you gave the pictures before or after the interview?
A. No, no, no. After -- of Mr. Jackson? No.
Q. Okay. Im asking you when you gave p ictures to Miss Dimond. Was it before the
interview or after it?
A. Oh. I think it was after.
Q. The prosecutor asked you questions about Wade Robeson. Okay?
A. Uh-huh. Yes.
Q. Do you remember saying in your deposition that you saw Mr. Robeson sleeping in Mr.
Jacksons bed?
A. Yes.
Q. Do you remember you were asked how many t imes you saw that, and you said,
Maybe twice?
A. I dont remember that I say that, but I think thats what it was.
Q. Maybe twice?
A. I remember -- I dont remember what I say at the time, but I think that was the time - I mean, that was the times.
Q. So you think you saw Mr. Robeson in Mr. Jacksons bed maybe twice?
A. Yeah.
Q. And you think you saw Mr. Jackson in a shower with Mr. Robeson one time, right?
A. Yes.
Q. But you said the shower was fogged up and you couldnt really see, right?
A. I saw the figure.
Q. You saw the figure. And you heard a lot of laughing, right?
A. Yeah.
Q. And you thought they were playing, right?
A. Yes.
Q. In your deposition, you said under oath you couldnt tell whether they were touching
each other or not, right?
A. Yeah.
Q. Do you remember meeting Joy Robeson, who is Mr. Robesons mother?
A. Yes.

Q. When did you first meet Joy Robeson?

A. I dont remember.
Q. Do you know about when it was, what year?
A. No.
Q. Okay. You told the jury that you walked into the door at the hideout apartment and
saw your son on Mr. Jacksons lap one time, right?
A. Not at the hideout.
Q. Where was it?
A. Havenhurst.
Q. Okay. And you said your son was reading a book?
A. (Nods head up and down.)
Q. Is that right?
A. Yeah.
Q. Okay. The prosecutor asked you questions about finding money in your sons pants,
right?
A. Uh-huh.
Q. You found the money in his pockets, correct?
A. Yes.
Q. Have you ever seen that Hard Copy interview that you did?
A. No.
Q. Okay. Has anyone from the prosecution tried to show it to you?
A. No.
Q. No? Okay.
A. I saw little hints. One day I got home and they were showing, you know, like little
parts, what they going to show the next day. Thats what I saw.
Q. Okay. Do you remember stating that you thought Michael Jackson was very childlike?
A. Yeah. Yes.
Q. He very often acted like a child, in your mind, right?
A. Yes.
Q. Do you remember saying that he would let his chimpanzee sleep in his room?
A. Yes.
Q. Do you remember that?
A. Yeah.
Q. The chimpanzees name was Bubbles, right?
A. Yes.
Q. And Bubbles would sometimes stay in Mr. Jacksons room, right?
A. Yes.
Q. You talked about Bubbles wearing a d iaper, right?
A. Yes.
Q. You said the monkey didnt like the diaper, right?
A. Yeah.
Q. And you would often clean after the monkey was in Mr. Jacksons room, right?
A. Yes.
Q. You said at one time Bubbles got too old and then there was another monkey, right?
Right?
A. I remember -- I dont remember about the other monkey, but it was Bubbles.
Q. Mr. Jackson and a lot of children used to play with the monkey, didnt they?
A. At Havenhurst he only had Bubbles.

Q. Okay. But children would come and play with the monkey, wou ldnt they?
A. Not at Havenhurst. Just one time.
Q. Where would you see Bubbles?
A. At Havenhurst, I think.
Q. Okay. Did you ever see Bubbles at Neverland?
A. I dont remember. I think it was bigger at that time.
Q. Okay. But he was at Neverland, right?
A. He was at Neverland? I dont remember.
Q. Okay. Okay. But you would often at Neverland see Mr. Jackson playing with kids, right?
A. Yes.
Q. He would play with kids all the time, wouldnt he?
A. Yes.
Q. And kids would often visit Neverland, right? Is that true?
A. Yes.
Q. Did you -- excuse me, let me rephrase that. Do you remember a dance room where Mr.
Jackson used to do dance routines?
A. A what?
Q. Im sorry. Let me rephrase it. Do you remember a dance room -A. Oh, a dance room, yeah.
Q. -- where Mr. Jackson used to practice dance routines?
A. Where at? Neverland?
Q. Anywhere.
A. Yes.
Q. Where was the dance room?
A. Behind the theater. Q. At Neverland, right?
A. Yes.
Q. And you used to see Mr. Jackson go there and practice dance, right?
A. Uh-huh.
Q. You also saw Mr. Jackson teaching children to dance, right?
A. Playing with the kids.
Q. Yes.
A. Yeah.
Q. And he used to teach children how he dances, right?
A. I dont know if it was the children, but I see him with the kids.
Q. Okay. In the dance room, right?
A. In the dance room, yeah.
Q. Okay. Have you ever d iscussed your sons claim that Mr. Jackson improperly touched
him with your son? Have you ever had a discussion about that?
A. At one time, back in 94.
Q. Okay. You talked to your son about what he said -A. Im -Q. Im sorry, go ahead.
A. I say, Whats going on? And he say, I just dont want to talk about it.
Q. This was in 1994?
A. 94, I think so.
Q. Have you ever d iscussed with your son his claims about Mr. Jackson?
A. No.
Q. Never?

A. No. I -- I ask him that I was going to ask his counselor.

Q. Okay.
A. And he say no.
Q. Okay. So youve never discussed -A. No.
Q. -- your sons claims with him?
A. No.
Q. Okay. Have you had a meeting with Prosecutor Sneddon?
A. Yeah, one time.
Q. And approximately when was that?
A. 93, I think.
Q. Okay. Have you met with Mr. Sneddon since 1993?
A. No.
Q. Okay. Have you had any meetings with any sheriffs to discuss your testimony?
A. Other than -- no.
Q. Okay. Have you ever had a meeting with any sheriff about what youre going to say
today?
A. Other than Saturday, that, you know, they told me that I was going to come here.
Q. Okay. Okay. W as any lawyer at that meeting?
A. No.
Q. Okay.
THE COURT: Shall we take our break?
MR. MESEREAU: Okay. (Recess taken.)
THE COURT: Go ahead.
MR. MESEREAU: Thank you, Your Honor.
Q. Miss Francia, Id like to ask you some questions about the deposition you gave on
January 11th, 1994, okay?
A. Uh-huh.
Q. Before you attended that deposition, you had been asked to bring the contract you had
with Hard Copy with you to the deposition, right?
MR. ZONEN: Im going to object as irrelevant.
MR. MESEREAU: Your Honor, I believe the prosecutor introduced the subject of Hard
Copy.
MR. ZONEN: Not a contract.
THE COURT: The objections overruled. You may answer.
Q. BY MR. MESEREAU: Do you remember that? Let me rephrase it.
A. Okay.
Q. Before you appeared at a sworn deposition on January 11th, 1994, you had been asked
to bring a copy of the contract you had with Hard Copy to the deposition, right?
A. I dont remember.
Q. Do you remember at that deposition, you said you had destroyed the contract?
A. I dont remember what I said or -Q. Do you remember saying youd gotten rid of it?
A. I dont remember.
Q. Would it refresh your recollection if I just show you the transcript?
A. Yeah.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.

Q. BY MR. MESEREAU: Miss Francia, have you had a chance to review those deposition
pages?
A. Did I have a -- had I had a chance? No.
Q. Im sorry, no. I just showed you some pages from the deposition, right?
A. Yes.
Q. Did you have a chance to review that portion of the page that I showed you?
A. I havent read any of the deposition paper.
Q. Okay. Did you just read it when I showed it to you?
A. Yes.
Q. And does it remind you that you said you had gotten rid of the contract?
A. Yeah, I probably did.
Q. Okay. Do you remember saying that in the deposition?
A. No, I dont.
Q. Okay. Did you get rid of that contract at some point?
A. Yeah, I dont have it anymore. Yeah, I dont have it.
Q. Did you throw it out?
A. I think I -- yeah, I think I threw it away, or -Q. Did you throw it out before the deposition of January 1994?
A. Yeah, I think I destroy -- I destroyed it.
Q. Okay. Do you remember stating in that deposition that you showed the contract to
Larry Feldman?
A. No.
Q. Do you remember showing that contract to Attorney Larry Feldman?
A. No, I dont remember.
Q. Would it refresh your recollection if I show you the deposition page?
A. Yeah.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. MESEREAU: Miss Francia, have you had a chance to look at that page of your
deposition?
A. No.
Q. Okay. I just showed you a page of your deposition -A. Oh, just now, yeah.
Q. Did you have a chance to read that page?
A. Yes.
Q. Does it refresh your recollection about your saying you let Larry Feldman see the
contract?
A. I dont remember.
Q. Okay. You dont remember showing it to Larry Feld man?
A. No.
Q. Okay. And you met with Larry Feldman, what, twice?
A. Well, first it was here in Santa Maria. He came down.
Q. Okay.
A. And then I met with him when I went there twice.
Q. So is that three meetings you had with Attorney Larry Feldman?
A. Yes.
Q. And that would be in the early 1990s, right?
A. Yes.

Q. Okay. Did you go to him to get some advice?

A. No.
Q. Did you talk to him about what you were going to say on television?
A. No.
Q. Youve talked to Santa Barbara Sheriff Russ Birchim a number of times, havent you?
A. Russ Bir -- it was from Santa Barbara, but I dont remember the name.
Q. Do you know a Santa Barbara sheriff named Russ Birchim?
A. Russ -Q. Do you know a Santa Barbara sheriff named Russ Birchim?
A. I dont remember the name of it, but it was a detective or sheriff.
Q. Do you remember when your son Jason first spoke to any police officer about what he
claims happened with Michael Jackson?
A. I remember one of the times, but I dont know which time it was.
Q. At your deposition, you said that you went on Hard Copy after your son spoke to the
police, right?
A. I dont remember if it was before or after.
Q. Okay. Would it refresh your recollection to just show you -A. Uh-huh.
Q. -- the deposition? May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. MESEREAU: Have you had a chance to look at that page from your sworn
deposition?
A. Yes.
Q. Does it remind you that your son had talked to the police before you went on Hard
Copy?
A. It doesnt -- I dont remember.
Q. Okay. Did you know your son was going to speak to any police officer about Mr.
Jackson?
A. No.
Q. It happened without you knowing about it?
A. I didnt know he was -- they were going to talk to him.
Q. Do you have any idea why the police wanted to talk to your son at that point in time?
A. No, I dont remember. I think when they first talked to him, they came to the house
and asked me if they could talk to him, but I dont remember when was this.
Q. Do you know who told the police anything about your son?
A. I think they -- someone told me that they needed to talk to my son, or they need to
talk to me about my son.
Q. Do you know if Larry Feldman, the attorney, contacted the police about your son?
A. No, I dont know.
Q. Now, you worked approximately five years at the Havenhurst address, right?
A. Altogether -MR. ZONEN: Misstatement of evidence; objection.
THE WITNESS: Altogether -THE COURT: Just a moment. I sustain the objection, Counsel.
MR. MESEREAU: Okay.
Q. You worked for approximately two years at Neverland, right?
A. Yeah.
MR. ZONEN: Objection; misstatement of evidence.

THE COURT: Overruled.

Q. BY MR. MESEREAU: Is that true?
THE COURT: She answered Yes before.
THE WITNESS: Yes.
MR. MESEREAU: Oh, I didnt hear her. Thank you.
Q. Now, while you were at Neverland, you reported to someone named Norma Stakos,
right?
A. Yes.
Q. And who was Norma Stakos?
A. One of the secretaries. She was a secretary.
Q. A secretary to who?
A. Mr. Jackson.
Q. Okay. And you would speak to her from time to time, correct?
A. Yeah.
Q. And do you remember she talked to you in 1991 about the fact that for the third time
your wages had been garnished by a creditor?
MR. ZONEN: Objection; irrelevant.
THE COURT: Sustained.
MR. ZONEN: And hearsay.
Q. BY MR. MESEREAU: Did you ask Miss Stakos on behalf of Mr. Jackson to help you
with any bills you couldnt pay?
A. No.
MR. ZONEN: Objection; irrelevant.
THE COURT: Overruled. The answer was, No.
Q. BY MR. MESEREAU: Did you have a discussion with Miss Stakos about the fact that
she couldnt pay you?
A. No, never did.
Q. You dont know anything about a wage garnishment?
A. Yes.
Q. What do you know about that?
A. That -MR. ZONEN: Im going to object as irrelevant.
MR. MESEREAU: I dont think so, Your Honor.
THE COURT: I thought it was initially, but I changed my mind. So Ill overrule the
objection.
Q. BY MR. MESEREAU: What do you remember telling Miss Stakos about a wage
garnishment?
A. About my taxes, not paying in time, and I need -- you know, they needed to wage how do you call that? - take money out of my paycheck.
Q. Did Miss Stakos help you with that?
A. Well, she was the payroll, so shes the one who took it off of my paycheck. But she
never gave me money, or anybody gave me money to pay that.
Q. Do you remember you owed money to a store called Deardens?
A. Yes.
Q. Okay. And they were trying to garnish your wages, right?
A. Uh-huh. Yeah.
Q. And did you -- you asked Miss Stakos to help you straighten that out, right?
A. Not to straighten it, but to -- you know, just to pay off of my check.

Q. Okay. And did she work with you on that?

A. Yes.
Q. Okay. And she did that for you on a couple of other occasions, right?
A. I remember two times. And I dont remember more than that.
Q. Okay. And she had a problem at one point because you had a phony Social Security
number, right?
A. Yes.
Q. Okay. And she helped you straighten that out, right?
A. No.
Q. You eventually got a proper Social Security number?
A. Yes. Yes.
Q. But you did discuss that with Miss Stakos, right?
A. I dont remember. But they knew that I was illeg al, and Mr. Bray wanted to help me to
get my papers.
Q. Okay. And that got straightened out, didnt it?
A. Yeah.
Q. Okay. Did you know someone named Gayle Goforth?
A. Yeah.
Q. And who was Gayle Goforth?
A. The housekeeper. One of the housekeepers. The head housekeeper of the house.
Q. And did you work with her?
A. Yes.
Q. For how long did you work with her?
A. Probably a year, a year and a half. Maybe a year.
Q. And at one point you admitted going into her
purse, right?
A. Uh-huh.
Q. And you went into her purse to see how much she was being paid, right?
A. Her purse was on top of the -- our desk, and she have her check on top of it.
Q. And you admitted going into her purse, right?
A. Yes.
Q. The purpose was to see what she was being paid, wasnt it?
A. Yes.
Q. Okay.
A. I admitted to Mr. Jackson.
Q. Excuse me?
A. I told Mr. Jackson about it.
Q. Yes. And he -- he didnt get you in any trouble or anything, did he?
A. No.
Q. Okay. Now, you got a coffee table from Mr. Jackson, didnt you?
A. Yes.
Q. And that was a beautiful oak table, right?
A. (Nods head up and down.)
Q. And where did that come from?
A. From Havenhurst.
Q. Okay. Did you ask for that?
A. Yes.
Q. And he said you could have it, didnt he?

A. Yeah.
Q. Did you ask him for the watch that you described before?
A. No.
Q. How did you end up with the watch?
A. I think it was one of the boxes that he get -- he get stuff from the companies, and I got
it from there.
Q. Okay. And at some point did you tell Mr. Jackson you had taken a watch?
A. No, he saw it on me. I show it to him.
Q. And he had no problem with that, right?
A. Yeah.
Q. And you indicated that he used to let you take lots of things from time to time, right?
A. Yeah.
Q. And a lot of those things, I think you described as samples; is that correct?
A. Samples, and gifts, and things that he get from -- for himself.
Q. The oak coffee table had a signature on it, didnt it?
A. A signature? Of him?
Q. Yes.
A. No.
Q. Didnt it have a signature of him?
A. No.
Q. You tried to sell that at one point, right?
A. No.
Q. Still have it?
A. Yeah, its in the garage somewhere.
Q. Okay. When you left Neverland, who did you report to to tell them that you were
leaving?
A. Who did I report?
Q. Yes.
A. I mean, I quit. I just -Q. Yeah. W hen you quit, who did you go to and say, I quit?
A. I told that lady who was working there at that time. Gayle.
Q. And did you give her one days notice?
A. No.
Q. How much notice d id you give?
A. No notice.
Q. Okay. You just left, right?
A. I just left.
Q. Okay. Now, on a couple of occasions you got in trouble for not doing your time card
properly, correct?
A. A lot of occasions.
Q. Huh?
A. A lot of occasions for being late.
Q. Yes, you got in trouble for being late, right?
A. Yeah.
Q. And you got in trouble for not properly doing your time card, right?
A. Yeah.
Q. Okay. But Mr. Jackson never yelled at you or did anything mean to you, did he?
A. No. No.

Q. But you didnt get along with some of the help, right?
A. Yeah.
Q. You didnt get along with Gayle Goforth, right?
A. Yeah.
Q. Shes the one whose purse you went into, right?
A. Yes.
Q. You and she just didnt get along, right?
A. In the beginning we got along very nice.
Q. Do you remember comp laints that you wouldnt let anybody get near Mr. Jackson?
A. That I would get -Q. Do you remember -MR. ZONEN: Ill object as hearsay -THE WITNESS: That I would get -MR. ZONEN: -- and vague.
THE COURT: Just a moment. The objections overruled. Do you want the question read
back? Do you want me to repeat the question for you?
THE WITNESS: Yes, please.
THE COURT: Ill have the court reporter do it. (Record read.)
THE WITNESS: No.
Q. BY MR. MESEREAU: Never heard of that?
A. Complaints that I wouldnt let anybody?
Q. Yes.
A. No.
Q. On the staff at Neverland?
A. Probably that I was the one allowed in his room, that I was -- I just wanted to do that Q. Okay.
A. -- myself.
Q. So you basically wouldnt let other people on the staff get near his room?
A. Yeah.
MR. ZONEN: Objection; misstatement of evidence.
THE COURT: Overruled. The answer was, Yeah.
THE WITNESS: Because he told me that. He told me not to let anyone in h is room.
Q. BY MR. MESEREAU: Okay. Now, the prosecutor asked you about the nickname
Rubba, okay?
22 A. Yes.
23 Q. Rubba is short for Rubber Head, right?
24 A. I dont know.
25 Q. You never heard that?
26 A. I dont know.
Q. Okay.
A. I never hear that before.
Q. And Mr. Jackson used to call his cousins, Levon and Elijah, Rubba, right?
A. He call the kids Rubba, yeah.
Q. He also called kids Rubber Head, or Rubba, right?
A. Yeah.
Q. Hed also use Apple Head, right?
A. I dont know.

Q. Hed use Doo-Doo Head, right?

A. Yeah. I think I hear that one time.
Q. Okay. But its certainly a term that he used quite often, isnt it?
A. Rubba, yeah.
Q. He used it on lots -- he used it for lots of children, includ ing his own cousins, didnt he?
A. Yeah.
Q. Okay. When is the last time you talked toLarry Feldman?
A. After the -- I mean, the last time I went over there and testified, or for the subpoena.
Q. So that was quite a while ago?
A. Yeah.
Q. Okay. Okay. Now, the prosecutor asked you questions about what you said in the
deposition about what you could see in the shower, right?
A. Yeah.
Q. And in the deposition you said under oath that all you could see was a shadow, right?
A. Yeah.
Q. Was that the truth?
A. A shadow, an image, yeah.
Q. Thats all you could see -A. Yeah.
Q. -- in the shower, correct?
A. I hear two voices.
Q. You heard giggling and laughing, right?
A. Yeah.
Q. And all you could see was a shadow through the glass?
A. The glass, yes.
Q. And thats because the glass was fogged up, right?
A. Yeah.
Q. Okay. You only saw one person in the shower, right?
A. I saw him in the shower and the little kid.
Q. But in your deposition you said you could only see one person, but you heard giggling,
right?
A. Yeah, but I hear two people -Q. You heard two people. You could only see one through the glass, right?
A. Mostly, yeah. Mostly.
Q. Do you remember you were asked in your deposition, Did you hear anything else
other than Michael laughing? And you said, No?
A. Yeah.
Q. Was that the truth?
A. Yes.
Q. Do you remember in the deposition saying you never saw anyone else in the shower
but Mr. Jackson?
A. I dont think I say that.
Q. Would it refresh your recollection if I show you the transcript?
A. Okay.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
MR. ZONEN: Page?
MR. MESEREAU: 401.

Q. Have you had a chance to look at that page of the deposition?

A. Yes.
Q. Does it refresh your memory about what you said about the shower?
A. Yeah.
Q. You saw one person, Mr. Jackson, right?
A. Yes.
Q. Or it looked like him through the glass, right?
A. Yes.
Q. And the only voice you really heard was Mr. Jackson, correct?
A. No.
Q. That wasnt correct?
A. I hear two -- two.
Q. You heard laughter?
A. Laughing and -Q. And that was at Neverland, right?
A. Yes.
Q. Okay. Youve seen Mr. Jackson in his Jacuzzi, correct?
A. Correct.
Q. Youve seen him playing in his Jacuzzi, correct?
A. Yeah.
Q. Youve never seen him molesting anyone in his Jacuzzi, right?
A. No.
Q. Let me just make sure thats phrased properly. Youve never seen Mr. Jackson
improperly touch anyone in his Jacuzzi?
A. No.
Q. Never saw that, right?
A. No.
Q. Okay. Have you seen Mr. Jackson at Neverland tickling and playing with children?
A. Yes.
Q. Youve seen him do that often, havent you?
A. Playing, yeah. Playing a lot with the kids.
MR. ZONEN: Ill object to the compound nature of the question, tickling and playing.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Youve seen Mr. -MR. ZONEN: Move -MR. MESEREAU: Oh.
MR. ZONEN: Move to strike the answer.
THE COURT: I think she clarified it in her answer.
MR. ZONEN: Okay. Thats fine.
THE COURT: Go ahead, Counsel.
Q. BY MR. MESEREAU: Youve seen Mr. Jackson tickling children at Neverland, havent
you?
A. Not that I remember, no.
Q. You never saw him p laying in the yard?
A. Playing in the yard, yeah. Not tickling -MR. ZONEN: Objection to the use ofplaying and tickling interchangeably as
compound.
THE COURT: Sustained.

MR. MESEREAU: All right. Ill move on.

Q. Youve seen children at Neverland from an organization called Make-A-Wish
Foundation, correct?
A. Yes.
Q. And children from Make-A-Wish Foundation often used to visit Neverland, right?
A. Yes.
Q. And they would crowd and climb all over Michael Jackson, right?
A. Play with him, yeah.
Q. Well, they would all just surround him, wouldnt they?
A. Yes.
Q. And you would see him play with them often, didnt you?
A. Yes.
Q. You would see those children running around Neverland a lot, correct?
A. Yes.
Q. And Mr. Jackson used to run around with them, didnt he?
A. Yes.
Q. He used to take them to the theater to watch movies, didnt he?
A. Yes.
Q. And children would sometimes sit in his lap in the theater watching the movies, didnt
they?
A. I -Q. Did you ever see that?
A. I never see that. Because I -Q. Im sorry.
A. I was never there when he was there with kids.
Q. Okay. Okay. Now, have you participated in any event -- excuse me, during the time
you worked at Neverland, did you particip ate in any large events when guests would come
to Neverland?
A. In any events, like -Q. Guests, parties, things of that sort?
A. Yeah, we used to have an employee barbecue or -- then we all would come.
Q. Do you remember any other big events at Neverland while you worked there?
A. No.
Q. Do you remember helping set up for guests who would visit?
A. Yes.
Q. That would happen a lot, wouldnt it?
A. Yes.
Q. And when guests were going to visit Never land, what would you do?
A. What do you mean?
Q. Yeah. W hat were your responsibilities when guests would visit Neverland? What kind of
work would you do?
A. Help in the house, help the cooks, help to clean their bedrooms.
Q. Would you clean bedrooms other than Mr. Jacksons?
A. Yeah, the guest rooms.
Q. And you used to see guests stay in the guest quarters from time to time, right?
A. Yes.
Q. Would you see Mr. Jacksons children in the main house when you worked there?
A. If I see who?

Q. Did you ever see any children -A. Oh.

Q. -- staying in the guest main house when you were there?
MR. ZONEN: Objection. Guest main house?
MR. MESEREAU: That didnt come out too well. I withdraw that.
Q. When you worked at Neverland, did you see any children who used to stay there,
besides what youve described?
MR. ZONEN: Stay where? Objection; vague.
MR. MESEREAU: Neverland.
THE WITNESS: Stay where, at the guest rooms?
Q. BY MR. MESEREAU: Yes.
A. No. They will stay in the house, in the main house.
Q. Children usually stayed in the main house, right?
A. Yeah.
Q. And do you know someone named Frank Cascio?
A. Frank Cascio. No, I dont remember.
Q. Do you know a family named Cascio?
A. No. I dont remember.
Q. Do you know someone named Tyson?
A. No.
MR. MESEREAU: Okay. No further questions at this time.
REDIRECT EXAMINATION BY MR. ZONEN:
Q. Miss Francia, you told us that Mr. Jackson had mentioned to you about not letting
people in his room. What exactly was it that Mr. Jackson told you in that regard?
A. Not to let people in; that people want to know about his business all the time, and not
to let anybody get in there.
Q. Did he tell you people in particular?
A. No. Just everybody. Anybody.
Q. Was that something he said to you often?
A. Yeah.
Q. Did you have a key to that room?
A. Yes.Q. Did he tell you he wanted the room kept locked?
A. Yeah.
Q. During the time that you worked for him at Neverland, did you see people coming and
going into
his room?
A. No.
Q. During the time that you worked at Neverland, did that door stay locked fairly
regularly?
A. Closed all the time.
Q. Were there ever people coming and going into his room that he did not give permission
to come and go into the room?
A. No.
Q. Did Wade Robeson come and go into his room at will?
A. Yeah. Kids were allowed to go there.
Q. Other kids were allowed to come into his room?

A. Yeah.
Q. If he was there -- if he was not there, or only when he was there?
A. Kids were there when he was there.
Q. If he wasnt there, they didnt stay in his room?
A. They -- they never came when he wasnt there.
Q. On those occasions that he was traveling, the Bad tour -- Mr. Mesereau was asking
you about his travels during the Bad tour.
A. Uh-huh.
Q. And he mentioned a period of time that exceeded a year and a half that he was on
tour. Was he continuously away from California for a full year and a half, or would he
come and go?
A. Hed come and go.
Q. There were t imes that he would return?
A. Yeah.
Q. And stay?
A. Yeah.
Q. Do you know the longest period of time that he would be away from his residence
during that time?
A. Probably about three months.
Q. Three months? Was the residence both the Encino home and the hideout in L.A.?
A. It was mostly the hideout.
Q. Did that tour extend to the period of time after which he moved to Neverland Ranch, or
was he completed with his tour by then; do you recall?
A. I dont remember.
Q. You told Mr. Mesereau that you had answered a question in the deposition about seeing
a shadow in the shower. What did you mean by that? What is a shadow? Tell me, what is
a shadow?
A. An image.
Q. An image. A ll right. What did you see when you looked into that shower?
A. Mr. Jackson.
Q. All right. Did you see the shadow of Mr. Jackson, or did you see a person that looked
like a shadow?
A. Through the glass.
Q. What did you see through the glass?
A. Mr. Jackson.
Q. The actual person?
A. Yeah.
Q. Okay. You didnt see his shadow cast against a wall, or against the floor?
A. Huh-uh. No.
Q. All right. So what did you mean by the word shadow?
A. His image.
Q. His image. Thats what he looked like?
A. Yeah.
Q. All right. And was the door blurred during that time?
A. Yeah.
MR. ZONEN: Excuse me. These are all next in order, please.
Q. At the time that you looked through the glass into the shower, were you able to see a
second person in there?

A. I want to say yeah, but I dont -- you know, I hear the laughing and the talking and,
you know, playing, and I -- I didnt see the actual person, but it was moving, you know,
with him.
Q. Do you believe that you saw the image of a second person?
A. Yeah.
Q. But not as clearly as Mr. Jackson?
A. Not as clearly, no.
Q. Did you hear one voice or two?
A. Two.
Q. And were you clear about that?
A. Yes.
Q. And did you tell that to Mr. Feldman in the deposition?
A. Oh.
Q. Im sorry?
A. I dont remember.
Q. You dont remember what you said?
A. No.
Q. The deposition was how many years ago?
A. More than ten years, I think.
Q. Okay. The portion that Mr. Mesereau asked you, when he showed you that transcript
about one or two people, do you recall when in the deposition that question was asked of
you? Was it the first
day or the second day of the deposition?
A. I dont know.
Q. Was it toward the end of the deposition?
A. I dont know. I think so. I dont remember.
Q. Before the deposition began, did they ask you if you wanted to testify in either English
or Spanish?
A. I dont think so.
Q. Did they simply assume that you would testify in English?
A. Yeah.
Q. All right. This was 11 years ago?
A. Yes.
Q. Is your English as good as it is now?
A. A little better, I think.
Q. A little better now?
A. Yeah.
Q. Would you have preferred to have testified in Spanish at that time?
MR. MESEREAU: Objection. Relevance; calls for speculat ion.
THE COURT: Sustained.
Q. BY MR. ZONEN: Were you comfortable in English at this time?
A. I wish it would have been in Spanish.
Q. Did you understand all of the questions that were asked of you during that deposition?
A. I was very confused.
Q. Were you confused as to some of the questions?
A. Yeah, and all the lawyers and -Q. There were a lot of lawyers there, werent there?
A. Yeah.

MR. MESEREAU: Objection. Leading; move to strike.

THE COURT: Overruled. Next question.
Q. BY MR. ZONEN: Were you intimidated during that deposition?
MR. MESEREAU: Objection; leading.
THE COURT: Sustained.
Q. BY MR. ZONEN: How did you feel during that deposition?
MR. MESEREAU: Objection -THE WITNESS: I was uncomfortable.
MR. MESEREAU: -- knowledge; foundation.
THE COURT: Overruled. She said, Uncomfortable.
Q. BY MR. ZONEN: You remembered the monkey Bubbles -- excuse me, the chimp, the
chimpanzee; is that right?
A. Bubbles, yes.
Q. Was Bubbles at more than one location?
A. I dont remember that. I think I remember that other little monkey. I think it was a
different one. But I remember Bubbles at Havenhurst. And then he was taken to some
kind of farm or trainer.
Q. Did Bubbles get a little too big?
A. Yeah.
Q. Did Bubbles get rambunctious, wild?
A. Wild.
Q. Did Bubbles ever bite you?
A. Yeah.
Q. On more than one occasion?
A. Twice.
Q. Twice? At some time d id you become a legal res ident?
A. Yes.
Q. And you had told them at Neverland about your status?
A. Yeah.
Q. Is that correct?
A. It was at that time. At that time that I -Q. While you were working at Neverland; is that correct?
A. Yeah.
Q. You mentioned about the coffee table. Where was the coffee table at the time that Mr.
Jackson gave it to you?
A. Havenhurst.
Q. It was at Havenhurst. And where at Havenhurst?
A. It was at his dance floor.
Q. Uh-huh.
A. And on top, in the attic.
Q. In the attic?
A. Yeah.
Q. Was it being used as a coffee table or was it being stored?
A. No, it was being used. It just -- I guess the room was too small, and, you know, it was
just in the way for everybody to -- I mean, for -- I guess for people to be there, and -Q. How did the coffee table end up going to you?
A. Because he wanted it to move out. He wanted it to be moved out, out of there. Q. He
was getting rid of it?

A. Yes.
Q. And you knew that?
A. Well, he said, Move it out of here, and I asked him if I can take it.
Q. And what did he say?
A. And he said, Yeah, take it.
Q. Mr. Mesereau asked you questions about your interview with Hard Copy.
A. Yes.
Q. All right. Were you interviewed by more than one person with Hard Copy?
A. No.
Q. Was that one person Diane Dimond?
A. Yes.
Q. Did you have more than one conversation with her?
A. Do you mean personally?
Q. Yes.
A. Yes, just one.
Q. Was there a conversation, like an interview, and then the interview on televis ion?
A. No, that -- the same day we did everything. She came to the lobby of the hotel, and
then we went upstairs and did it.
Q. She came to the lobby. So it was all on the same day?
A. Uh-huh.
Q. Was the interview done at the hotel?
A. Yeah.
Q. Were there a number of questions that were asked of you during that interview?
A. There were many questions asking about who? Me?
Q. Were there a lot of questions that they asked?
A. Oh. Yeah.
Q. I say they, but actually, was it just Diane Dimond who asked you questions?
A. Yes.
Q. Yes?
A. Yes.
Q. Was anyone else asking you questions?
A. No, I dont remember. I dont think so.
Q. Did you know in advance what the questions were going to be?
A. No.
Q. Were you surprised by what the questions were?
A. Yeah. Yes.
Q. Did you know it was going to be about Michael Jackson?
A. No. I thought it was going to be about me working there.
Q. All right. That was the part that surprised
you?
A. Yeah.
Q. Were you upset about it?
A. Yeah, because then I start to answer, and I felt like I was just there, you know,
answering questions that I didnt know they were going to ask me.
Q. Okay. Did it upset you?
A. Yeah.
Q. Did you tell them you were upset about that?
A. No.

Q. Were you truthful in your answers?

A. Yeah.
Q. Mr. Mesereau asked you if it was true that you told Diane Dimond in this interview that
you never saw Michael Jackson molest a child; is that correct?
A. Yeah.
Q. What else did you tell Diane Dimond in the interview?
A. I dont remember.
Q. Did you tell Diane Dimond about seeing him s leeping with boys?
A. Yeah.
Q. Did you tell her that that concerned you?
MR. MESEREAU: Objection. These are leading questions.
THE COURT: Sustained.
Q. BY MR. ZONEN: Was there any conversation with Diane Dimond regarding any of the
boys that you testified to so far today?
A. Im sorry, repeat?
Q. Was there any conversation with Diane Dimond regarding the testimony youve given
today about any of those boys? You testified about Wade Robeson. You testified about
Macaulay Culkin. Did you discuss either of those boys with Diane Dimond?
A. No, I said -- I think the only -- that I say that I see him is sleeping with the kids and
being in the bathtub with them, playing.
Q. And you told Diane Dimond that?
A. Yeah, I think I did.
Q. Now, this is the bathtub or this is the shower?
A. I dont remember if I told her about the shower. But I rememb er that I told him about
the bathtub and the Jacuzzi, I think.
Q. Im sorry?
A. I told her about the Jacuzzi and the bathtub, I think.
Q. And being there with boys?
A. Being with boys. Yeah, that I will clean up their -- you know, their toys in the bathtub.
Q. Mr. Mesereau asked you on cross-examination if you ever saw Michael Jackson in the
Jacuzzi at the Havenhurst residence; is that correct?
A. Excuse me? Mr. -Q. Mr. Mesereau asked you if you saw Mr. Jackson in the Jacuzzi at the Havenhurst
residence.
A. Uh-huh. Yeah.
Q. And you said, Yes?
A. Yeah.
Q. With a boy; is that true?
A. It wasnt -- yeah.
Q. Mr. Mesereau asked you if you had seen Michael Jackson in bed with W ade Robeson
twice, and you said, Yes?
A. Yeah.
Q. Did you actually see Wade Robeson in bed with Michael Jackson?
A. Yeah. Yes.
Q. And that was on two different occasions?
A. Yes.
Q. That doesnt include the times that you didnt see them in bed, but you cleaned up
after them?

A. Yeah.
Q. When were the two times that you actually saw him in bed with Wade Robeson?
A. When was the two times? Do you mean the dates?
Q. Well, I doubt you could do that, but -- could you do that? Do you know the dates?
A. No. No.
Q. Can you give me -- do you remember the two occasions when you saw them? Do you
remember either of the two occasions?
A. Just simply be in bed with him.
Q. How did that happen, that you were there an they were in bed together? How did it
happen that you saw them?
A. Watching T.V.
Q. They were watching T.V. Were they inside the bed or on top of the bed?
A. Inside the bed.
Q. Do you remember what they were wearing?
A. No.
Q. Do you remember if they were wearing anything?
MR. MESEREAU: Objection; no foundation.
THE WITNESS: No.
THE COURT: Just a moment. Sustained.
Q. BY MR. ZONEN: Could you see any clothing on either one of them?
MR. MESEREAU: Objection; foundation.
THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Could you see any clothing on either one of them?
A. I saw from the waist up, so -- I dont know if they had pajamas or -Q. But from the waist up, were either one of them wearing anything?
A. No.
Q. They were both nude from the waist up?
A. Yeah.
Q. On both occasions?
A. On one occasion I remember.
Q. On one occasion?
A. On one occasion.
MR. ZONEN: May I have those photographs, Counsel? Oh, thank you.
Q. Id like to show you a series of photographs, if I may. These photographs are
numbered consecutively 783 through 789. May I approach the witness, Your Honor?
THE COURT: Yes.
Q. BY MR. ZONEN: Let me begin with Photograph No. 783. Could you take a look at that
photograph?
A. Uh-huh.
Q. Do you recognize the content of that photograph?
A. Yeah.
Q. And what is that of?
A. This is Mr. Jackson.
Q. Oh, you need to use the microphone. I dont think anybody can hear you. 783, then, is
what, please?
A. Mr. Jacksons bed.
Q. Thats his bedroom?
A. His bedroom, yeah.

Q. Is that upstairs or downstairs?

A. Downstairs.
Q. Does this show the bed?
A. Yes.
Q. 784, please, what is that?
A. Thats his bedroom.
Q. Upstairs or downstairs?
A. Downstairs.
Q. 785, what is that, please?
A. His bedroom.
Q. Upstairs or downstairs?
A. Downstairs.
Q. 786, what is that?
A. Thats the Jacuzzi.
Q. Im sorry?
A. The Jacuzzi.
Q. First floor?
A. In the bathroom.
Q. Okay. And can you see where the shower is in that photograph?
A. I can just see the -- right here, the frame, the door frame.
Q. If I were to give you a pen and ask you to draw an arrow to where the shower goes,
would you do that?
A. Yeah. I mean, the -Q. Yes, go ahead. Okay. And for the record, an arrow has been drawn to the far right side
of this exhibit, No. 786. No. 777, can you tell me what that is?
A. Thats the bathroom.
Q. The shower?
A. The shower.
Q. On the first floor?
A. Yes.
Q. No. 788, what is that, please?
A. Thats the shower, thats the security -- I mean, the bedroom -- I mean, the closet.
Q. And thats the garden?
A. And thats the Jacuzzi.
Q. Okay. Now, we were looking at a few different things that you -- were going to go
through this when we present it. But in this photograph, which is No. 788, can you see
both the Jacuzzi and the room that has the shower in it?
A. Yes. Right across from each other.
Q. Okay. And then finally, 789, if youd look at that, please.
A. Yeah, this is the room upstairs.
Q. Thats the bedroom upstairs?
A. The bedroom upstairs, yes.
Q. And that has a bed as well?
A. Yeah. 5147
Q. The photographs that Ive just asked you to look at, which are No. 783 through 789, do
each of these photographs accurately depict the subject matter contained in the
photograph, which means are they accurate? Are the photographs accurate of those
rooms and those locations?

A. Yes.
Q. Okay. Now, are these accurate as of 1993?
A. Do you mean -Q. As of the time that you were there, last there, is it how it looked around the time when
you were there?
A. No.
Q. Okay. Tell me whats different.
A. Well, the T.V. -- like, the bed is the same thing. And the television is the same. Its just
more stuff in it.
Q. Just more stuff in it?
A. Yeah.
Q. Okay. And the one that youre looking at, as you say that, is 783.All right. And 784,
does that appear the same as you last saw it?
A. No.
Q. Whats different?
A. Theres more stuff in it.
Q. More stuff?
A. Yeah. 5148
Q. But the furniture is in the same place?
A. Yes.
Q. 785?
A. Yeah. This wasnt here when I was there.
Q. Im sorry?
A. It wasnt -- it wasnt like when I used to clean it.
Q. How was it different?
A. The paintings and this mannequin.
Q. All right. Im going to withdraw this one. Im going to withdraw 785. 786. Take a look
at 786.
A. Yeah, thats the same. I mean, thats the same, the same as far as the furniture, and
even the towels and -Q. Okay.
A. -- the toys.
Q. 787?A. Its the same.
Q. Okay.
A. Its just crowded.
Q. 788?
A. Yeah, its the same.
Q. And seven -- let me see that again. All right. This was 789 that I showed you and
originally called it 787. Back to 789. So this is the same?
A. Yes.
Q. All right. Here is the real 787, with the shower. Is that the same?
A. Yes.
Q. Okay. And then 787 is the same?
A. Yes.
MR. ZONEN: Okay. Your Honor, Im going to move into evidence 783, 784, 786, 787 and
788 and 789, and withdraw 785.
MR. MESEREAU: No objection.
THE COURT: Theyre admitted.

MR. ZONEN: May I publish these at this time?

THE COURT: Yes.
Q. BY MR. ZONEN: Mrs. Francia, this is a laser pen, and it sheds a laser beam. And you
just go like that. Dont show it in anybodys eyes. The first one is 783. And would you tell
us what that is, please?
A. 783, this?
Q. Yes, that room.
A. Mr. Jacksons bed and -Q. Oh, we have a problem. Unfortunately, youre going to have to turn back to use the
microphone. Take a look at it, and then turn back to use the microphone so we can hear
you.
A. Thats Mr. Jacksons bed, and television. And thats the entrance, the stair that goes to
the stairs, three. And then you go around to th bathroom.
Q. Okay. 784. And tell us what that is, please.
A. Thats the same. This will be the television cabinet.
Q. And this is the first floor again; is that right?
A. Yes.
Q. All right. Now, did you say that there was some things that werent there -A. Yes.
Q. -- at the time that you last worked for Mr. Jackson. Show us what that is.
A. These pictures here.
Q. Those pictures right there. Anything else?
A. This horse.
Q. Okay. Now, Mr. Jackson did not have children of his own at that time, did he?
A. No.
Q. Okay. 786, please. Now, heres the one where I asked you to put an arrow. Do you
recognize the arrow where you put it?
A. Yes.
Q. Show it.
A. Right there.
Q. What does that point to?
A. The shower.
Q. And where is the shower?
A. Right here. About right here.
Q. And you had told us earlier in your -- this is the first-floor bathroom; is that right?
A. Yes.
Q. And you told us earlier in your testimony, that you had to come closer to be able to see
into that room?
A. Yes.
Q. Can you show us in this picture where you were standing at the time that you actually
looked into that room?
A. Probably about right here. So I can see in.
Q. All right. And then you said that there was also a Jacuzzi outside?
A. Its a shower. Right there.
Q. A shower. So is that on the other side of that wall, the back wall?
A. Yes.
Q. All right. Next picture, please. And this, I think, is 787. And what is that?
A. Thats the shower.

Q. All right. Is that the same door that you recall?

A. Yes.
Q. All right. And thats the shower that you gave testimony to. And the last one, please.
Two more. 788. And this is 788. Is that the same bathroom downstairs?
A. Yes.
Q. All right. Do you have a better view of the room that has the shower?
A. Yes.
Q. Show us where that is, with the laser.
A. Right here.
Q. Okay. Thats the toilet that you can see?
A. Yes.
Q. And on the other side of the toilet is the shower?
A. Uh-huh. Right next to it.
Q. All right. Can you show us now where you were standing? Can you put the laser on
where your feet were at the time you were standing?
A. Probably right here. Right here on this corner.
Q. Okay. And then finally, 789. And what is that, please?
A. Thats his -- thats another room.
Q. That was the bed upstairs?
A. Uh-huh. Second floor.
Q. Now, Mr. Mesereau asked you about that bed. Sometimes it is slept in and sometimes
it is not.
A. Yeah.
Q. During that period of time that Wade Robeson was coming and visit ing, was that bed
slept in a lot?
A. No.
Q. Was it slept in infrequently?
A. No, I always -- just only when a lot of kids were there.
Q. Okay. If it was just Wade Robeson, he didnt sleep in that bed?
A. No.
Q. How about Macaulay Culkin?
A. No.
Q. He didnt either?
A. No.
MR. ZONEN: Thank you.
I have no further questions, Your Honor. And these exhibits are in evidence. Yes, they are.
Thank you. No further questions.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Just very briefly. When -- during the time you worked at Neverland, Mr. Jackson would
often have guests in his room, right?
A. Yes.
Q. And people would often hang out on his bed and watch television, correct?
A. Yes.
Q. You would often serve them food, right?
A. Yes.
Q. And you would serve them drinks, right?

A. Yes.
Q. That went on at all hours of the day, correct?
A. Yes.
MR. MESEREAU: No further questions.
THE COURT: All right. Thank you.
MR. ZONEN: And I have no further questions, Your Honor.
THE COURT: All right. You may step down.

2005 April 7 (days 27) Testimonies R. Chacon, A. McManus

RALPH CHACON EXAMINATION

DIRECT EXAMINATION BY MR. SNEDDON:

Q. Mr. Chacon, in order for everybody to hear you, youre going to need to lean into that
microphone, okay? Would you do that for us? A. Yes, sir.
Q. Thank you. Mr. Chacon, did you used to work at Neverland Valley Ranch?
A. Yes, sir.
Q. During what period of time?
A. Between 91 and 94.
Q. And prior to working at Neverland Valley Ranch, where -- what employment did you
have? A. I used to repo vehicles in Thousand Oaks.
Q. Is that where youre from, Thousand Oaks?
A. Born and raised, yes, sir.
Q. And during the time that you were at Neverland Valley Ranch, what was your position?

A. Security.
Q. And could you describe to the ladies and gentlemen of the jury generally what your
responsibilities were as a security officer?
A. Secure Neverland property, front gate, fence lines, around the main house, keeping
intruders out, and also taking care of the temperatures in the animal areas.
Q. What shift did you work at the ranch?
A. Graveyard.
Q. Would you tell us what graveyard, what that entails? What are the hours?
A. From 10:00 till 6:00 in the morning.
Q. Now, do you recall a t ime when you wereworking at the Neverland Valley Ranch in
which Mr.Jackson was the subject of an investigation?
A. Yes, sir.
Q. And what years was that; do you recall?
A. I really dont. I dont recall.
Q. During the time that you were at the ranch, did you get subpoenaed to appear before
the Santa Barbara County Grand Jury?
A. Yes, sir, I did.
Q. Do you recall when that was?
A. I believe it was in 94.
Q. Do you recall the month?
A. Im guessing, could be probably May or something around there. Im not sure.
Q. And do you know an individual by the name of Kassim Abdool?
A. Yes, sir.
Q. Who is Kassim Abdool?
A. He was at that time chief of security at Neverland.
Q. And at the time that you were subpoenaed before the grand jury, were you and Mr.
Abdool carpooling back and forth to work?
A. Yes, sir, we were.
Q. And how long had you known Mr. Abdool?
A. Probably the duration of our employment at Neverland. Probably about three years.
Three, four years. Something like that Q. And to your knowledge, did Mr. Abdool also get
subpoenaed to appear before the grand jury?
A. Yes, sir, he did.
Q. And do you recall where you were directed to appear, which county?
A. Supposed to be in Los Angeles County. But I didnt go to Los Angeles County.
Q. At some time prior to appearing before the grand jury, purs uant to subpoena, were you
contacted by attorneys representing Mr. Jackson?
A. Yes, sir.
Q. On how many occasions?
A. I can remember two occasions that I was called to come before them.
Q. And do you recall who those attorneys were?
A. Mr. Steve Cochran, I believe, and I remember an Eric Mason. Mr. Sanger.
Q. Do you recall where the first meeting occurred?
A. It happened in Mr. Jacksons outside office at Neverland.
Q. And do you recall when the second meeting occurred?
A. It happened in Santa Barbara at Mr. Sangers office.
Q. And were both of these meetings prior to the time you were to appear before the grand
jury, your subpoena date?

A. Yes, sir.
Q. Now, as a result of the receiving a subpoena to the grand jury, did you make contact
with law enforcement?
A. Yes, I did.
Q. And do you recall who it was you contacted?
A. I believe it was Mr. B irchim.
Q. And do you recall what agency Mr. B irchim worked for?
A. I believe it was the sheriff -- Santa Barbara Sheriffs Department.
Q. And when you -- Im sorry. When you contacted Mr. Birchim, did you have a
conversation with him?
A. Yes, sir.
Q. And did you relay to him certain informat ion?
A. I did.
Q. And after that, did you have contact with any other -- was there more than one
meet ing with Mr. Birchim?
A. Im sure there was, but I dont rememb er.But I know there was more than two
meet ings with him.
Q. Now, you told the ladies and gentlemen of the jury that you did not appear before the
Los Angeles County Grand Jury. Did you at some time make a statement under oath with
regard to what you observed?
A. Yes, sir, I did.
Q. And do you recall when that was?
A. I believe it was 94. Im not for certain. Its been a while.
Q. Do you recall whether it was at or about the time when you were supposed to appear
before the grand jury?
A. Oh. Yes, sir. It was probably the day after.
Q. And do you recall where it was that you were interviewed?
A. In Santa Barbara.
Q. And do you recall who was present during the time that you were interviewed?
A. Well, the only ones that I remember is yourself and Mr. B irchim.
Q. And was that statement given under oath?
A. Yes, sir.
Q. Now, during the time that you were emp loyed at Neverland Ranch, did you personally
observe anything that you felt was inappropriate with regard to Mr. Jacksons behavior -A. Yes, sir.
Q. -- or conduct? And do you recall approximately what year that was?
A. I want to say latter 92 or early 93. I am not -- Im not positive.
Q. Do you recall what time of day or night it was?
A. It was -- well, I had come on graveyard shift, so it had to have been about probably
midnight, or before midnight.
Q. And do you recall what the weather was like that night?
A. It was very nice. Very nice weather.
Q. Now, when you first came to work that evening, what were the first things that you
did; do you recall?
A. I would come in and check out the radio. We carried rad ios and a flashlight. I would
check my box for any memos that were generated. Then I would -- we had -- there was
electric golf carts that we had to put on chargers for the night.
Q. At some time that evening, did you see Mr.Jackson?

A. Yes, sir.
Q. And do you recall where Mr. Jackson was the first time that you saw him that evening?
A. He was headed for the Jacuzzi.
Q. And do you know whether or not he was alone or with someone?
A. He was with someone.
Q.And when you say he was with someone, do you know who that was?A. Yes, sir.
Q. Who was that?
A. That was Jordie.
Q. And could you approximate the age of Jordie?
A. I want to say nine, ten years old.
Q. So he was with a child?
A. Yes, sir.
Q. Not an adult?
A. No.
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. Next question.
Q. BY MR. SNEDDON: Now, I may have missed this or I may have asked this. When you
say you saw Mr. Jackson in the company of this child, Jordie, what direction were they
headed?
A. Towards the Jacuzzi.
Q. Is that an area near where you were putting things away?
A. It was close by. But from the area where I was at, the garage area, I had -- I had gone
to the barbecue area, which was close, maybe ten feet, to the Jacuzzi.
Q. And did you -- were you able to see Mr. Jackson and the child in the Jacuzzi?
A. I couldnt see them from where I was standing, but I could hear them in the water.
Q. Now, at some point, did you hear Mr. Jackson speak out? A. Yes, sir.
Q. And what --Your Honor, this is not offered for the truth of the matter, but simply to
explain the conduct that occurs thereafter?
THE COURT: All right.
Q. BY MR. SNEDDON: What did you hear Mr. Jackson say?
A. While in the Jacuzzi?
Q. Yes.
A. They were just -- just laughing, playing. I dont remember what they were saying, but I
know that they were talking and having fun.
Q. At some time d id Mr. Jackson request something from the house?
MR. MESEREAU: Objection; leading.
THE WITNESS: That was before -THE COURT: Just a moment.
MR. SNEDDON: You have to wait for the Judge to rule, Im sorry.
THE WITNESS: Im sorry.
THE COURT: Overruled. You may answer.
Q. BY MR. SNEDDON: Okay. Now you can answer.
THE COURT: Do you want the question read back?
THE WITNESS: No, sir. Well, actually, that was -- I heard them --I heard him when I was
still hooking up the golf carts. He had called for security.
MR. MESEREAU: Objection; nonresponsive.
THE COURT: Sustained.
Q. BY MR. SNEDDON: Okay. So at some point you heard Mr. Jackson yell for security?

A. Yes, sir.
Q. And where were you when that occurred?
A. I was in the garage area.
Q. Now, at some point that evening, did you see Mr. Jackson and the child, Jordie, leave
the Jacuzzi?
A. Yes, sir, I did.
Q. Could you tell the ladies and gentlemen of the jury, were you able to observe where
they went?
A. Yes, sir.
Q. And where did they go?
A. They were going to the outside rest room area by the rec room.
Q. And is the rec room near another building or attached to a building on the premises?
A. Well, its on its -- the rest rooms attached to the rec room. So it sits by itself. Its two
stories.
Q. All right. Are there other facilit ies inside of that building itself?
A. Just a game room, thats all it was.
Q. Do you know what the game room is called?
A. Just -- no, I dont.
Q. Describe the game room, if you would.
A. They had, like, probably maybe 20 different type of computer games, the first floor,
and also with the top, the top floor had different type of games.
Q. Have you been in that build ing before?
A. Yes, sir.
Q. And do you know whether or not that build ing has a cellar?
A. A what, sir?
Q. A cellar?
A. Um, I want to say that had a wine cellar, yes, sir.
Q. All right. In any event, you saw Mr. Jackson and the child heading towards the rest
room area; is that correct?
A. Yes, sir.
Q. Did you watch them the entire time?
A. Yes, sir.
Q. And did you see where they went?
A. They went inside the rest room.
Q. Now, where were you located when you observed this?
A. I was in the barbecue area, where I usually normally observe everything.
Q. Thats a security position youre assigned?
A. Yes, sir.
Q. Now, at the time that you saw Mr. Jackson and the boy go into the rest room area, did
you at some point in time approach the rest room?
A. Yes, I did.
Q. Do you recall from the time that you saw Mr. Jackson and the child go into the rest
room area, how long it was before you approached the area?
A. Probably a half an hour, maybe 35, 40 minutes.
Q. And then could you describe to the ladies and gentlemen of the jury where you went?
A. I went around the rec room that leads right behind the rest rooms. Thats where I
went.
Q. And what did you do when you got there? Well, when you got in that area, did you hear

or see anything?
A. Yes, sir.
Q. And which?
A. Well, I heard first that Mr. Jackson and the boy were inside a shower, the shower room
in there.
Q. How many showers are there in the rest room?
A. There was only one shower.
Q. Lets just stop right there for just a second, before we go any further. Could you
explain to the ladies and gentlemen of the jury the interior of the rest room area?
A. As you go in from the rec room, the womens rest room is on the left and the mens
room is on the right. And as you go in, theres a dressing area, and its open, and it leads
into where the wash basins are at, pretty large area. And then it goes into another smaller
room where theres a toilet and the showers.
Q. And you said showers.
A. Shower. Excuse me, shower.
Q. All right. Now, youve indicated that you heard some people in the shower. Did you
recognize the voices?
A. Yes, sir, I did.
Q. Whose voices did you recognize?
A. Mr. Jacksons and Jordies.
Q. And did you look into the shower area?
A. Not right away. Not the first time that I came around, because I couldnt see anything.
But I started to leave the area when I -- I was thinking, I said, Whats going on here?
You know, Theres a grown man in a shower with a boy.
MR. MESEREAU: Objection; move to strike.
THE COURT: Stricken.
Q. BY MR. SNEDDON: All right. So you left?
A. Right.
Q. How far did you go?
A. I didnt go too far, probably halfway around the rec room.
Q. All right. And did you decide to go back?
A. Yes, sir, I did.
Q. Why did you decide to go back?
A. I wanted to know what was going on in there.
Q. Why?
A. Because it wasnt -- it wasnt right.
MR. MESEREAU: Objection. Relevance; move to strike.
THE COURT: Ill strike the question, Why? And the answer.
Q. BY MR. SNEDDON: Okay. So you went back. When you went back, where d id you go
to?
A. I went back to the same area where the shower was located. There was a window, and
I was able to see and they were no longer in the shower.
Q. So you looked into the window?
A. Yes, sir.
Q. All right. And what did you see -- where did you see Mr. Jackson and the child at this
point?
A. I saw them standing in the nude in the middle area, and Jordie was on the right, and
he was on the left side. Standing, facing each other.

Q. Now, at the time that you saw that, what were the lighting conditions inside of the rest
room?
A. Oh, it was litted up, just that area there. Not where the showers at, but that area, it
was -- the lights were on.
Q. Did you have any difficulty seeing in there?
A. Not at all, sir.
Q. Now, from the point outside looking down inside, what did you see go on between the
defendant, Mr. Jackson, and Jordan Chandler?
A. I saw that Mr. Jackson was caressing the boys hair, he was kissing him on his head,
and his face, his lips. He started kissing him on the shoulders and started going down to
his nipples. Started sucking his nipples. Started going down to his penis and putting it in
his mouth. And about that time I just -- I left.
Q. Okay. You say you saw him go down and do what?
A. He put the little boys penis in his mouth.
Q. Did you actually see that?
A. Yes, sir.
Q. And then you left?
A. Yes, sir.
Q. Where did you go?
A. I went back to the barbecue area.
Q. Do you recall, after you left that area and observed the things youve just related to
the jury, did you see Mr. Jackson with the child again that evening?
A. Yes, sir, I did.
Q. And where were you when you saw them?
A. I was in the barbecue area.
Q. And where -- where were they when you saw them ag ain?
A. They were coming out of the rest room.
Q. Now, from the time that you had left, when you had made your observations -A. Yes, sir.
Q. -- and you left, till the time that they came out of the rest room, how much time had
elapsed during that period of time?
A. Probably 20 minutes or 30 minutes.
Q. Now, when they came out of the rest room, could you describe what was going on?
A. Jordie was mounted on Michaels back, piggybacked, and they were headed for the
back of the -- the kitchen door to the main house.
Q. Did the child, Jordan, have any clothing on?
A. He had -- I believe it was like -- it was a towel. I believe it was a towel. Its the type -like its a rope, but its a towel.
Q. So a cloth robe or towel of some kind?
A. Yes, sir.
Q. Okay. And what was Mr. Jackson wearing, if you recall?
A. Same.
Q. Could you see whether or not the child, Jordan, had any other clothing on or not?
A. No, sir. I didnt observe.
Q. And where did they go?
A. They went inside the house, the main house.
Q. And when they went inside the main house, did you hear or observe anything happen
that you felt was unusual?

A. Yes, Mr. Jackson double-locked the door, the back door, which he normally never did.
Security always went inside to secure the house inside and out.
Q. Now, you say -- you described to the jury that Mr. Jackson was kissing the boy -A. Yes, sir.
Q. -- that you observed. How would you describe the kissing?
A. Well, it was very passionate. Very passionately he was kissing him.
Q. And did you see his hands during the time he was kissing him?
A. Yes, sir.
Q. Where were they?
A. They were all over his body.
Q. All right. I want to show you a couple of photographs, if we might, Mr. Chacon. Ive
shown these to counsel, Your Honor. The photographs are 790, 791, and 792. All right.
Mr. Chacon, lets look at the photographs. First of all, lets start with 790. Do you
recognize that?
A. 790?
Q. Yeah. Im sorry, you have to turn it over on the back.
A. Oh, yes, sir.
Q. All right. Lets start with that. Do you recognize whats depicted in the photograph,
790?
A. Yes, sir.
Q. And what is that?
A. Thats where the swimming pools at, and its -- youre facing at the rec room in front of
you, and to the left is the garage area where the carts -- where I was hooking up the
carts.
Q. Does that photograph depict a portion or some of the route that you took where you
walked to the area that you observed Mr. Jackson and the child, Jordan?
A. Yes, sir.
Q. Now, what Id like you to do is to please take that black felt tip pen that Ive given you
there, and would you please just draw the path that you took thats covered by that
photograph, that portion of it. And does that photograph accurately depict the area of
what you call the rec room at the time that you made the observations of Mr. Jackson and
the child, Jordan?
A. Yes, sir.
Q. All right. Lets turn that one over and go to the next one that has 791 on it, okay? Do
you recognize that?
A. Yes, sir.
Q. All right. What is 791?
A. Its the pool area, and directly in front is the rec room and the rest room. The rest
rooms.
Q. Does the photograph, 791, show the area of the entrance into the bathroom area?
A. Yes, sir.
Q. And does it show the Jacuzzi?
A. Yes, sir.
Q. And does it show the approximate area of the -- where you made your observations?
A. Well, its behind the -- just the other side of the Jacuzzi, yes, sir.
Q. Okay. With regard to that particular photograph -- and Im going to ask you, does it
accurately depict the area as you recall it in 1992 or 93 when you made your
observations?

A. Yes, sir.
Q. All right. Im going to ask you, please, take that black marker, p lease, and if you would
just circle the area that depicts the entrance into the rest room area? And would you
please put an X in the approximate area where it was that you made the observations of
Mr. Jackson and the child? Now, lets take the last photograph, which is 792 for
identification purposes. Do you recognize that photograph?
A. Yes, sir.
Q. And can you tell the jury what that is, please?
A. Its the barbecue area.
Q. Okay. Now, is that the area that you have made reference to in your testimony?
A. Yes, sir.
Q. And does that photograph accurately depict that area as it was back when you were
working at Neverland Valley Ranch?
A. Yes, sir.
MR. SNEDDON: Your Honor, I move that 790, 791, and 792 be admitted into evidence.
MR. MESEREAU: No objection.
THE COURT: Theyre admitted.
MR. SNEDDON: And, Your Honor, could we have the input for the Elmo, please?
Q. BY MR. SNEDDON: This is a laser and Im going to ask you to point to some things.
A. Okay.
Q. All right. This is the exhibit thats been marked as Exhibit 790 for identification
purposes, all right? Do you recognize that, Mr. Chacon?
A. Yes, sir.
Q. Would you show the jury the black line that you placed on this particular exhibit? Okay.
It starts at the left-hand side of the photograph; is that correct?
A. Yes, sir.
Q. And moves - go ahead, just trace it - all the way to almost the right-hand side -- or the
left-hand side of the building, correct?
A. Yes, sir.
Q. Would you tell the ladies and gentlemen of the jury, as you walk down past the side of
that building thats depicted in the far right-hand side of the photograph, Peoples 790,
what is down there?
A. There is a tennis court. Its a sunken tennis court.
Q. And what are the lighting conditions? Is there a path that goes along there?
A. Yes, sir, there is.
Q. What are the lighting conditions along that path?
A. Around the back, there wasnt.
Q. How about along the path itself?
A. Towards the -- behind the rest rooms, there was a path where there was just small
little lights on the ground.
Q. Now, did you have a flashlight with you that night?
A. Yes sir.
Q. Is that part of your standard equipment -A. Yes.
Q. -- that you carry on the graveyard shift?
A. Yes, sir.
Q. The building thats depicted on the far right-hand side of the photograph - yes, sir, the
one youre showing the jury there - what is that building there?

A. Thats the rec room.

Q. And lets go to 791, if we could. All right. Would you show the ladies and gentlemen of
the jury, first of all, what you referred to as a Jacuzzi?
A. Right here.
Q. So thats in the lower left-hand corner of the exhibit, 791?
A. Yes, sir.
Q. Now, where is the entrance to the rest room?
A. Right in there.
Q. And its hard to see, but you drew a circle around that in black?
A. Yes, sir. Right there.
Q. And now, where -- on this photograph, if you can, can you show the approximate area
of where it was that you have made the observations you described to the jury?
A. Well, this is the rest room in front, and on the side, about right in there. The path is
right on the other side on the building there.
Q. On the back side of the building?
A. Yes, sir.
Q. Okay. Now, lets show the next photograph and then Ill come back to this. This is 792
in evidence. Do you recognize that?
A. Yes, sir.
Q. And what is that?
A. Thats the barbecue area.
Q. Okay. Now, with regard to this particular photograph, where were you located in your
position as a security officer on this evening when you observed the defendant and the
child, Jordan, walk into the rest room?
A. I was about right in that area.
Q. So youre indicating to the right-hand side of the barbecue area, just to the right of the
post?
A. Right. Yes, sir.
Q. The post on the -- and were you behind the barbecue itself or on the other side of it?
A. Well -- well, actually, I was like -- I was moving up and down the side of it, on the
other side.
Q. On the outside of it?
A. Yes, sir.
Q. So not in the interior part, but -A. Well, it was in the -- the interior is on the other side also. Because this is in the center.
Q. Just so we can get it clarified, which side of that were you on?
A. I was on -- I believe I was on that other side.
Q. Now, is the area of the -- lets go back to 791 for a second, if we could. You pointed out
the Jacuzzi, and obviously theres a swimming pool also there.
A. Yes, sir.
Q. Now, with regard to that area, is that area lit at night?
A. It is.
Q. Or was it then? Lets put it that way.
A. Yeah, just a bit. Because the sidewalks had these lights, these small lights, as you went
up through the path. And if I rememb er correctly, I guess there was some -- some
lighting, but not that much. But you could see where you were walking, though.
MR. SNEDDON: Okay. All right. You can take that down. I have three more photographs,
Ive shown them to counsel, that have been marked as 793, 794, and 795 for

identification purposes. Id like to show them to the witness.

THE COURT: All right.
Q. BY MR. SNEDDON: Mr. Chacon, Im going to show you the photograph marked as
793. Youve seen that photograph before?
A. Yes, sir.
Q. And do you recognize the person that you believe that that photograph depicts?
A. Yes, sir.
Q. Who is that?
A. Jordie.
Q. Is that a depiction of the child as you recall him back in those days?
A. Yes, sir.
Q. And with regard to 794, it has two photographs on it, one at the top and one at the
bottom. The one at the top is a singular photograph of an individual, and the one at the
bottom has four people in that. Do you recognize the people in that photograph?
A. Yes, sir.
Q. And again, who is that?
A. Jordie.
Q. And in the photograph at the bottom, there are a number of people dep icted. Which of
them do you recognize as Jordie?
A. This one here.
Q. Would you please take that black pen and just put an arrow towards -- start on the
white, down below. Okay. Thank you. And with regard to 795, do you recognize that?
A. Yes, sir.
Q. And again, there are a number of people depicted in that photograph, correct?
A. Yes, sir.
Q. And do you recognize anybody in that photograph?
A. Yes, sir, I do.
Q. Who would that be?
A. Thats Jordie.
Q. By that you mean who, in terms of -- theres one, two, three, four, five people
depicted.
A. The fifth one.
Q. All the way over to the left?
A. All the way over to the left.
Q. Are these accurate depictions of the child as you recall him back in those days?
A. Yes, sir.
MR. SNEDDON: Move that they be admitted into evidence, Your Honor.
MR. MESEREAU: No objection.
THE COURT: Admitted.
Q. BY MR. SNEDDON: Now, Mr. Chacon, are you familiar with a child by the name -- a
young boy by the name of Brett Barnes?
A. Yes, sir.
Q. And have you seen Mr. Barnes before?
A. Yes, sir.
Q. Have you seen him at the ranch before?
A. Yes, sir.
Q. Have you seen him in the company of the defendant before?
A. Yes, sir.

Q. On how many occasions?

A. Numerous occasions. I couldnt give you a figure.
Q. When Mr. Barnes was at the ranch, do you recall whether or not his parents were with
him?
A. At times they were; at other times they werent.
Q. Now, with regard to the child youve described and ident ified as Jordan Chandler, and
the child that you also saw as Brett Barnes, can you tell us what they look like?
A. Well, to me, I always got them confused, because they looked the same, similar. I
know one was a little bit shorter than the other. But, you know, I always got them
confused, but they looked -- they looked alike. Maybe one had hair a little bit shorter than
the other.
MR. MESEREAU: Objection. Nonresponsive; narrative.
THE COURT: Overruled.
Q. BY MR. SNEDDON: Go ahead.
A. But I would get them -- I would -- they just looked the same to me.
MR. SNEDDON: All right. If we could have the Elmo again.
Q. Im going to start backwards at 795. Now, would you use the -- thank you. 518 Thats
the child you identified by the name of what?
A. Jordie.
Q. All right. And now 794. Lets do the bottom one for right now. Now, the bottom one,
you put an arrow; is that correct?
A. Yes, sir.
Q. Which is the child that you were identifying that you recognize as Jordie.
Okay. The one in the middle of the photograph?
A. Yes.
Q. In the front -A. Yes, sir.
Q. -- right? And lets -- let me ask a question about the top photograph. With regard to
that photograph, do you recognize that person?
A. Yes, sir.
Q. All right. Whos that?
A. Thats Jordie.
Q. Okay. And lastly, thats 793 in evid ence. And youve identified that ind ividual as also
Jordie, correct?
A. Yes, sir.
MR. SNEDDON: All right. Thank you. W e could have the lights again.
Q. Now, during the time of your emp loyment at Neverland Valley Ranch -- let me go back
a second, okay?
A. Yes, sir.
Q. With regard to the incidents that you just described to the ladies and gentlemen of the
jury here involving Mr. Jackson and the child youve identified as Jordan, correct?
A. Yes, sir.
Q. Are those -- is that -- is that what you told the grand jury when you were interviewed
back in 1994?
A. Yes, sir, I did.
Q. Now, lets go on for just a moment. Did you see any other incid ents involving Mr.
Jackson and the child you described as Jordan?
A. Yes, sir.

Q. With regard to the second -- and lets just call it the second incident. With regard to the
second incident, do you recall how much time had elapsed between the two incidents?
A. I dont recall, sir.
Q. Could you give us some idea whether it was weeks, months, or years?
A. Could have been weeks. Could have been a month. Im not positive. Its been a while.
Q. Okay. And let me go back just for one second before we move on to the second
incident. Was there another thing that occurred on the evening of the incident where you
saw Mr. Jackson and the child, Jordan, in the rest room together that you had to actually
make a report on?
A. Yes, sir.
Q. And what was -- what was that?
A. Well -Q. What happened?
A. Well, Kassim Abdool and myself, we were going around the house, the back side of the
house checking for anything that was open, the normal security checkup that we would do
around the house. And we observed that the two French doors in the middle of the house
were wide open.
Q. And so a note was made of that to your supervisor?
A. Yes, sir.
Q. Who was your supervisor?
A. Lieutenant Wade. Kassim Abdool had written a report in regards to the French doors
being open and we didnt close them.
MR. MESEREAU: Objection; nonresponsive.
THE COURT: Sustained.
MR. MESEREAU: Move to strike.
THE COURT: After Lieutenant Wade is stricken.
MR. SNEDDON: Okay.
Q. So a report was prepared of that?
A. Yes, sir.
Q. Now, the incident about the French doors being open, was that before or after you had
observed Mr. Jackson?
A. After.
Q. It was later that evening?
A. Yes, sir.
Q. All right. Now we can move on.
On the second incident - were going to call it the second incident just for purposes of what was it -- were you working graveyard again?
A. Yes, sir.
Q. And do you recall approximately what time of the night it was?
A. It was in the evening, after ten oclock when I come on.
Q. Where were you?
A. I was in the pool area. Barbecue area, pool area.
Q. And did you see Mr. Jackson that evening? Let me go back. Did you see Jordan that
evening?
A. Yes, I did.
Q. And the child youve identified as Brett, did you see him that evening?
A. Yes, sir.
Q. Where were they?

A. They were in the rec room, playing with the machines.

Q. Was there any other children in the rec room?
A. Yes, I noticed a little girl, probably five, six years old. I d idnt know who she was, but
Im sure she was probably a sister of one of the boys.
Q. And did you at some point become aware of the fact -- let me ask you this. Prior -when the children were in the rec room playing, to your knowledge, was Mr. Jackson on
the premises?
A. No, sir.
Q. And did you become aware at some point in time that Mr. Jackson was on the
premises?
A. Yes, sir.
Q. And did you at some point see Mr. Jackson on the premises?
A. Yes, sir.
Q. And where was Mr. Jackson the first time you saw him?
A. He was coming out the back of his door -- the back door of his house, the main house.
Q. All right. And describe to the jury what you observed Mr. Jackson to do.
A. He kind of ran up to the rec room, and he was looking in from the outside, and he
spotted Jordie in one of those little -- its like a car you play, a racing car. And Mr. Jackson
went around the area where the rest rooms were at. Theres a back door that goes into
the rec room, and he located Jordie back there, and he went to where Jordie was at and -Q. Lets just stop right there for just a second, okay? You saw him go into the rec room
through a back door entrance?
A. Yes, sir.
Q. At the time you saw him go up to Jordan, where were the other children? Could you
see?
A. Yeah, they were upstairs playing games.
Q. Were the lights on inside of the rec room?
A. Yes, sir.
Q. Did you have any difficulty seeing in the rec room?
A. Oh, no. No, sir.
Q. And where were you located at the time you made these observations?
A. I was around the pool area, almost right directly in front of the rec room.
Q. Now, at that point in time when you saw Mr. Jackson go actually physically into the rec
room, describe to the jury what you saw occur.
A. Well, I saw him enter through the back door of the rec room, and he went over to
Jordie. He bent over and said something to him, and then he kissed him. And then they
got out the back door and they ran over to Mr. Jacksons Moon Rover, and -- that was a
golf cart that he had specially made for himself, and they took off.
Q. When you say he kissed him, did you see where he kissed him?
A. Not exactly, but I know he kissed him.
Q. Now, at some point that evening, did you see Mr. Jackson again?
A. Yes, sir. When they came b ack.
Q. When they came back. And where were you when they came back?
A. I was in the barbecue area.
Q. And when they came back, where did they -- physically, where did you see them when
you -A. They pulled up to what they called the breezeway, which is between the main office and
the main house, the outside office and the main house.

Q. Okay.
A. Behind the back.
Q. And what did -- what -- was anybody else present when they drove up?
A. Kassim Abdool was coming from the security at that time also.
Q. So what did you see occur at that point in time?
A. Well, I saw that Mr. Jackson and Brett -- I mean Jordie got off the cart. And Kassim
noticed that they were back, so he just headed back to the security -- security office. And
Mr. Jackson and the boy were in front of the -- they call it the Peter Pan display. Its a
window where Peter Pan lights up.
Q. Can you describe that? Where is that located, what building?
A. Well, its the -- its where the office is at, behind the main house. Its connected.
Theres a breezeway, but its connected. And theres a display window, or a window where
this Peter Pan display is at, where it lights up and you see Tinkerbell flying around the
window.
Q. Okay. Could you describe to the jury the positions of the child and the defendant, Mr.
Jackson?
A. Well, they were looking at the display, the Tinkerbell lighting up. And he was -- Jordie
was in front, Mr. Jackson was in back, and he had his hands over like this, and -Q. Youre indicating over -A. Over his back, towards the front.
Q. Okay.
A. And then he turned him around, kissed him. It was passionate, but it didnt last that
long. And then his hands went down to his private areas. And then they ran inside the
house.
Q. All right. You say he kissed him, and it was not very long but it was passionate. Where
did he kiss the child?
A. In the mouth.
Q. And when you say his hands went down, 5195 where did they go -- whose hands
went down where?
A. Mr. Jacksons hands went down to his crotch area, the boys.
Q. The boys?
A. Yes, sir.
Q. And what -- how long -- how long do you estimate that this incident took?
A. It was -- it didnt take very long. Probably 10 seconds, 20 minutes. Im not sure.
Q. And then at that point what did you see?
A. They went -- ran inside the back, the inside of the house.
Q. Both the child and Mr. Jackson?
A. Yes, sir.
MR. SNEDDON: Just a moment, Your Honor. Well, I must have misplaced it. Your Honor,
I have one other photograph Id like to have marked as 796 for identification purposes.
And Ive shown it to counsel.
Q. With regard to the exhibit, 796, do you recognize that?
A. Yes, sir.
Q. What is -- what is that?
A. This is behind the house. This is behind the house. This is the office. And this is the
breezeway.
Q. So when you talk about a breezeway in your testimony, this photograph depicts that
breezeway?

A. Yes, sir.
Q. And does it depict the office that you were talking about?
A. Yes, sir.
Q. All right. What I want you to do is, on that photograph, just draw a little arrow and an
O to the building that you indicated is the office okay?
A. Yes, sir.
Q. And then just put a big B in the area that you call the breezeway. All right. Is that
photograph an accurate depiction of the area as you recall it back when you observed
these incidents?
A. Yes, sir.
MR. SNEDDON: All right. Move that it be admitted into evidence, Your Honor.
MR. MESEREAU: No objection.
THE COURT: Its admitted.
MR. SNEDDON: Could we have the lights just briefly, Your Honor?
Q. All right. This is 796, the photograph we were just talking about, okay?
A. Yes.
Q. Would you use that little red laser again, and indicate -- theres the B that you put,
and that is the area that you consider the breezeway?
A. Yes, sir.
Q. And you also put an O with an arrow. Would you find that for the jury. All right. And
thats the area that you described as what?
A. The outer office where the display is on the window.
Q. Okay. All right. All right. Thats good. I just wanted to get those down so everybody
can get an idea of what it was like. All right. We can have the lights again. Now, prior to
the time -- let me ask you this: With regard to the testimony youve just related to the
lad ies and gentlemen of the jury here this morning, did you also describe those incidents
to the -- when you were asked to make a statement under oath?
A. Yes, sir.
Q. When you were subpoenaed to the grand jury?
A. Yes, sir.
Q. Now, prior to the time that you appeared to give a statement under oath as to the
events that you related here this morning, had you ever told anyone about what you saw?
A. No, sir.
Q. Had you ever mentioned it to anybody?
A. No, sir.
Q. Why not?
MR. MESEREAU: Objection; relevance.
THE COURT: Overruled. You may answer.
THE WITNESS: Well, a lot of things went through my mind, but one of the things was
who would believe me?
Q. BY MR. SNEDDON: Why?
A. Well -MR. MESEREAU: Objection.
THE COURT: Sustained.
Q. BY MR. SNEDDON: What else went through your mind?
MR. MESEREAU: Objection.
THE COURT: Sustained.
Q. BY MR. SNEDDON: Have you ever personally met anybody by the name of Blanca

Francia?
A. No, sir.
Q. Have you ever personally met anyone by the name of Phillipe L eMarque?
A. No, sir.
Q. Have you met W ade Robeson?
A. Yes, sir.
Q. And how did you meet W ade Robeson?
A. Just by being on the property and -- and him being on the property.
Q. How often was he on the property?
A. Numerous times, but I cant give you a number of how many t imes.
Q. Mr. Chacon, when you left the ranch as an emp loyee - okay? -A. Yes, sir.
Q. Oh, I had another question before we get there. Were you armed?
A. No, sir.
Q. At the time that Mr. Jackson -- during the time that you became aware of the fact that
Mr.Jackson was under investigation, were there any guards on the ranch property that
were armed?
A. Yes, sir.
Q. And how many?
A. There was about four or five of them.
Q. Were they people who had been employed by the ranch as security officers for -- prior
to that time?
A. No, sir.
Q. Now, when you left the ranch, why did you leave?
A. I was forced to leave -MR. MESEREAU: Objection; relevance.
THE COURT: Overruled. You may answer.
THE WITNESS: I was forced to leave because of the OSS, the bodyguards that came on
the property that were armed, because we would not comply with whatever they wanted
us to do or say, because we didnt -- we didnt -- we went to the grand jury, but they
didnt know what we had said so they had put pressure on us to quit.
Q. BY MR. SNEDDON: Did you ever tell anybody after you went to the grand jury what
you had testified to in front of the grand jury?
A. After?
Q. Yeah. Anybody associated with Mr. Jackson.
A. Yes.
Q. Who was that?
A. Kassim Abdool.
Q. And thats the person you worked with?
A. Yes, sir.
Q. Other than that, anybody else?
A. No, sir.
Q. Did you at some point in time file a lawsuit against Mr. Jackson, you and other
members of the staff?
A. Yes, sir, we did.
Q. And in that particular lawsuit, where was that tried?
A. Santa Maria, right here, sir.
Q. And did you lose that lawsuit?

A. Yes, sir.
MR. SNEDDON: I have no further questions, Your Honor.
THE COURT: Cross-examine?
MR. MESEREAU: Yes, please, Your Honor.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. Mr. Chacon, my name is Tom Mesereau, and I speak for Mr. Jackson.
A. Yes, sir.
Q. Id like to ask you a few questions about that lawsuit you lost. That was the longest
civil trial in the history of Santa Maria, right?
A. I dont know, sir.
Q. It went about six months, didnt it?
A. I believe so, yes, sir.
Q. You sued Mr. Jackson and you wanted $16 million, right?
A. Well, I dont know about the 16 million.
Q. You wanted millions, true?
A. No, sir.
Q. Really?
A. Well, I dont know, sir. Whatever our attorney was -- hes the one who was speaking
for us.
Q. Okay. Well get into that. You sued Mr. Jackson claiming you were wrongfully
terminated, right?
A. Thats correct, sir.
Q. He sued you claiming you had stolen property from him, true?
A. Thats correct, sir.
Q. The jury found you were not wrongfully terminated by Mr. Jackson, correct?
A. But we were, sir.
Q. Answer my question, please. Did the Santa Maria jury find you were not wrongfully
terminated by Mr. Jackson?
A. Yes, sir.
Q. And they also found you had stolen property from Mr. Jackson, correct?
A. But I didnt, sir.
Q. Did the Santa Maria jury find you had stolen property from Mr. Jackson?
A. Yes, sir.
Q. A judgment was entered against you, Mr. Chacon, for $25,000, the value of what you
had stolen, correct?
A. For candy bars, sir?
Q. A judgment was entered against you for $25,000, the value of what the Court found
you had stolen, correct?
A. Well, if a candy bar is worth that much, yes, sir.
Q. Thats not all you owe Mr. Jackson currently, is it?
A. No, sir. I dont owe him.
Q. In fact, Judge Zel Canter of this court, entered a judgment against you and your codefendants for $1,473,117.61, correct?
A. Yes, sir.
Q. He ordered you pay all of Mr. Jacksons legal fees and costs, correct?
A. Yes, sir.
Q. Have you ever paid any of that judgment, Mr. Chacon?

A. No, sir. I filed bankruptcy.

Q. Now, the jury found you not only stole from Mr. Jackson, but you acted maliciously,
correct?
A. No, sir.
Q. Did a judge find you had acted with malice?
A. No, sir.
Q. Is there a judgment against you for acting with fraud against Mr. Jackson?
A. That I know of, no, sir.
Q. Would it refresh your recollection to look at the judgment?
A. Yes, sir.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay. Oh, its there, sir. I didnt know. Yes, sir.
Q. BY MR. MESEREAU: Have you had a chance to look at that judgment, Mr. Chacon?
A. Do you mean right now?
Q. Yes.
A. Yes, sir.
Q. There is not only a judgment against you in favor of Mr. Jackson -MR. SNEDDON: Wait a minute. Im going to object. He asked to refresh his recollection.
He should ask him if it did.
MR. MESEREAU: Sure.
THE COURT: Thats correct.
Q. BY MR. MESEREAU: Have you had a chance to look at the judgment against you, Mr.
Chacon?
A. I looked at that, yes, sir. But I dont remember it.
Q. Does it refresh your recollection that theres a judgment against you for fraud and
malice -A. No, sir.
Q. -- in favor of Mr. Jackson?
A. Yes, sir.
Q. You never heard of that before?
A. Well, probably, but I dont remember.
Q. After a six-month trial, you dont remember?
A. Well, its been 12 years also, sir, or so.
Q. Do you remember stipulat ing and agreeing that you had personally acted with fraud,
oppression
and malice against Mr. Jackson?
A. Probably so, sir.
Q. You did that, didnt you?
A. No, sir.
Q. You didnt stipulate that you had acted with fraud, oppression, and malice against Mr.
Jackson in that case?
A. Well, yes, sir.
Q. After a six-month trial, this is a good way to get even with him, isnt it?
MR. SNEDDON: Argumentative. Object, Your Honor. Move to strike.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you have any motive today, sir, to get even with Mr. Jackson?
A. No, sir.

Q. Do you remember telling a therap ist youd rather get a million dollars from Mr. Jackson
than work?
A. No, sir.
Q. Do you remember being evaluated by a Ph.D. named Dr. Scott Gorsuch?
A. I dont recall, sir.
Q. Do you recall being evaluated by a therap ist in that lawsuit?
A. Probably at one point, but I dont recall it, sir.
Q. Who was your lawyer in that case?
A. Mr. Ring from Santa Barbara.
Q. Do you remember, in response to being called a malinger, you said, Id like just a
million from Mr. Jackson?
A. Thats not true, sir.
Q. Never h appened?
A. No, sir.
Q. Do you recall making statements you didnt want to work again?
A. No, sir.
Q. Okay. After you left Mr. Jackson, you filed for disability, d idnt you?
A. Yes, sir.
Q. You werent disabled, were you?
A. I think it was just unemployment, wasnt it?
Q. Did you file for disability, Mr. Chacon, after you left Mr. Jacksons employment?
A. It was unemployment, I believe it was.
Q. Okay. You had a deposition taken in that case under oath, correct?
A. Yes, sir.
Q. And that was not the first time you had ever been deposed, correct?
A. I dont understand, sir, what youre saying.
Q. You had had your deposition taken in lawsuits before that one, true?
A. No, sir. Not that I recall.
Q. That was the first deposition youd ever had taken that you recall?
A. In my life?
Q. Yes.
A. Yes, sir.
Q. Okay. Do you remember being asked if you were aware that your attorney wanted $16
million for you from Mr. Jackson and you said you understood that?
A. No, sir.
Q. Would it refresh your recollection to show you a page from your deposition?
A. Yes, sir.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Where does it say 16 million? Oh, okay, I see that.
Q. BY MR. MESEREAU: Have you had a chance to look at that page of your deposition?
A. Yes, sir.
Q. Remember you said you were aware that your lawyer had asked for 16 million?
MR. SNEDDON: Im going to ask that counsel be directed to ask whether it refreshes his
recollection before he reads.
MR. MESEREAU: Im sorry. I will withdraw the question.
Q. Have you looked at that deposition?
A. Yes, sir.

Q. You were under oath at the time, correct?

A. Yes, sir.
Q. Does it refresh your recollection that you admitted you knew your lawyer h ad asked for
$16 million?
A. No, sir.
Q. In fact, you said you didnt think 16 million was enough, correct?
A. No, sir.
Q. Would it refresh your recollection if I just show you your deposition?
A. Yes, sir.
MR. MESEREAU: May I approach?
THE COURT: Yes.
THE WITNESS: Thats on there.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes, sir.
Q. Does it refresh your recollection that you didnt think $16 million was enough to you?
A. No, sir, I dont.
Q. You didnt say that?
A. No, I mean, I dont -- now I see its written down there, yes, sir.
Q. Well, how much d id you want in the lawsuit, sir?
MR. SNEDDON: Object as argumentative, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: In that lawsuit, you tried to extort Mr. Jackson, didnt you?
A. No, sir.
MR. SNEDDON: Object; argumentative, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember being asked at the beginning of your
deposition, Have you ever been deposed before? And you said, Yes?
A. No, I dont recall, sir.
Q. Might it refresh your recollection to see that page?
A. Yes, sir.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay, sir.
Q. BY MR. MESEREAU: Have you had a chance to look at that?
A. Yes, sir.
Q. Does it remind you that you admitted you had been deposed before?
A. I -- I dont remember. But its down there, yes, sir.
Q. Well, youd been in other lawsuits before this, hadnt -THE COURT: Counsel, I believe its time for our break.
THE COURT: Counsel?
MR. MESEREAU: Thank you, Your Honor.
Q. Mr. Chacon, you mentioned to the jury someone named Kassim Abdool, right?
A. Yes, sir.
Q. And was Kassim Abdool someone you worked with at Neverland?
A. Yes.
Q. And I believe you told the jury that he was the first person you talked to about your
claim that
Mr. Jackson was molesting young men, correct?

A. I believe so, yes, sir.

Q. Kassim Abdool joined you in that lawsuit against Mr. Jackson, correct?
A. Yes, sir.
Q. Kassim Abdool also had a judgment against him in favor of Mr. Jackson for
$1,473,117.61, correct?
A. I believe so, sir, yes.
Q. Kassim Abdool joined you in trying to get millions from Mr. Jackson, right?
MR. SNEDDON: Object as argumentative, Your Honor.
THE COURT: Overruled. You may answer.
Q. BY MR. MESEREAU: Is that correct?
A. No, sir. No, sir.
Q. Oh, he didnt?
A. No, sir.
Q. He wasnt a plaintiff with you in that case?
A. Oh, he was, yes, sir.
Q. Youre saying that Mr. Abdool was not looking for millions like you?
A. No, sir.
Q. How much d id he want, Mr. Chacon?
A. There wasnt an amount, sir.
Q. After a six-month trial, your lawyer d idnt ask the jury to award an amount for you, sir?
A. Youll have to ask Mr. Ring.
Q. You were sitting there, werent you?
A. Yes, sir.
Q. Did you hear him give a closing argument to the jury?
MR. SNEDDON: Your Honor, Im going to object; argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Are you telling this jury today, under oath, you dont know how
much your lawyer asked for in that six-month trial?
A. I saw it earlier when you showed -MR. SNEDDON: Excuse me. Im going to object as argumentative and immaterial.
THE COURT: Sustained.
Q. BY MR. MESEREAU: There was also someone named Adrian McManus who joined you
in suing Mr. Jackson, correct?
A. Yes, sir.
Q. And Adrian McManus had worked at Neverland, right?
A. Thats correct, sir.
Q. And like you and Mr. Abdool, she lost the case, correct?
A. Yes, sir.
Q. A Santa Maria jury ruled against her as well, right?
A. Thats correct.
Q. Now, Adrian McManus was also found to have stolen property from Mr. Jackson, true?
A. No, sir.
Q. Would it refresh your recollection if I show you the judgment?
A. Yes, sir.
MR. SNEDDON: Your Honor, Im going to object as immaterial with regard to this
witnesss testimony; beyond his knowledge; no foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: When did you last talk to Adrian McManus?

A. Probably months; months ago.

Q. Did you talk about this case at all?
A. Only if I knew when I was coming down, and how she was doing.
Q. Is that all you discussed about this case?
A. Yes, sir.
Q. How long was the conversation?
A. Oh, couldnt have lasted more than five minutes, because she was at work.
Q. When did you last talk to Kassim Abdool?
A. I have not, sir, at all.
Q. Not at all?
A. No.
Q. Okay. Whens the last time you talked to him?
A. Probably the time when we left court here. Back then.
Q. Okay. All right. Now, when you sued Mr. Jackson, you had judgments against you in
other cases, true?
MR. SNEDDON: Your Honor, Im going to object as immaterial.
THE COURT: Sustained.
Q. BY MR. MESEREAU: When you sued Mr. Jackson, the wages you were getting from
Mr. Jackson were being partially garnished, correct?
MR. SNEDDON: Your Honor, Im going to object. Same objection.
MR. MESEREAU: Financial motive, Your Honor.
THE COURT: The objection is overruled. You may answer.
Q. BY MR. MESEREAU: Correct?
A. Yes, sir.
Q. They were being garnished because you wouldnt pay child support, true?
A. I was paying child support, sir.
Q. Then why were they garnished?
A. I assume thats the procedure they do when they want child support from you.
Q. You couldnt just send a check yourself?
MR. SNEDDON: Im going to object to that -THE COURT: Sustained; calls for a legal conclusion.
Q. BY MR. MESEREAU: At one point, you asked a Santa Barbara sheriff for money, true?
A. I dont recall, sir.
Q. Do you recall ever asking Mr. Birchim for some money?
A. No, sir.
Q. Are you saying it never happened?
A. I dont recall, sir.
Q. Okay. When did you last talk to Russ Birchim?
A. This morning.
Q. Where did you talk to him?
A. Here at the courthouse.
Q. Did you talk about your testimony?
A. No, sir.
Q. Okay. So youre not denying that you asked him for money and youre not denying he
gave it to you; you just dont remember, right?
A. I dont recall, sir.
Q. When did you first meet Russ Birchim?
A. I believe it was back in 93, I believe. Im not sure.

Q. Ever hear of a company called Commercial Trade?

A. No, sir.
Q. You didnt have a lawsuit with Commercial Trade in 1989?
MR. SNEDDON: Object as immaterial.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know someone named Judge Byrd?
A. No, sir.
Q. Judge Byrd had a judgment against you for a couple thousand dollars, didnt she?
MR. SNEDDON: Your Honor, Im going to object to this and ask the Court to admonish
counsel.
THE COURT: The -MR. MESEREAU: Its all part of the financial motive, Your Honor.
THE COURT: Theres no time frame. The problem youre asking about is when. I dont
know that. So Ill sustain the objection on vagueness.
Q. BY MR. MESEREAU: At the time you sued Mr. Jackson for an amount you dont
remember, isnt it true you had a judgment against you for $2600 by a Ms. Judge Byrd?
5221
A. I dont recall, sir.
Q. Would it refresh your recollection if I show you your deposition where you talked about
it?
A. Yes, sir.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Oh, yes, sir.
Q. BY MR. MESEREAU: Have you had a chance to look at that deposition page?
A. Yes, sir.
Q. Did it refresh your recollect ion?
A. Yes, sir.
Q. Do you know who Judge Byrd is?
A. No, sir.
Q. Okay. Do you know anything about a judgment she ever had against you?
A. No, sir.
Q. Okay. Now, when d id you first tell Kassim Abdool, your co-plaint iff against Mr. Jackson,
about this alleged mo lestation you witnessed?
A. Probably when -- when we -- when we knew that we were going to be subpoenaed to
the grand jury.
Q. And approximately when was that?
A. I believe it was in 94 sometime.
Q. By the way, do you remember testifying that Sheriff Russ Birchim delivered money to
you?
A. I dont recall, sir.
Q. Would it refresh your recollection if I show you your deposition?
A. Yes, sir.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Its down there, but I dont recall that, sir, at all.
Q. BY MR. MESEREAU: Okay. Do you recall saying it?
A. No, sir, I dont.

Q. Dont recall anything about it?

A. No, sir.
Q. Okay. It just is down there, right?
MR. SNEDDON: Im going to object to the comment as argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember testifying under oath you asked Mr. Birchim
for money?
A. I dont recall, sir.
MR. SNEDDON: Thats been asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember asking for money so your wife could relocate?
A. Probably -- probably so, sir. Yes, sir.
Q. Okay. Do you remember wanting other bills paid?
A. No, sir.
Q. Okay. How long after you told Kassim Abdool, your co-plaintiff, about these alleged
acts of molestation did you speak to anyone from law enforcement?
A. I dont recall, sir.
Q. Was it years?
A. Oh, no. No, not years.
Q. How long was it?
A. Could have been weeks, days. Im not certain, sir. Its been a while.
Q. Did you review any documents to get ready to testify today?
A. No, sir.
Q. Anyone send you any documents to look at -A. No.
Q. -- before you testified today?
A. No, sir.
Q. When did you last talk to Mr. Ring about your suit against Mr. Jackson?
A. I havent talked to Mr. Ring in years, sir.
Q. Okay. All right. Now, at the time you filed your lawsuit against Mr. Jackson, you knew
that other former employees at Neverland had sold stories to tabloids about Mr. Jackson,
didnt you?
A. Could you rephrase that, sir?
Q. Sure. At the time you filed your lawsuit against Mr. Jackson, you were aware that other
former employees at Neverland had sold stories to tabloids, correct?
A. I dont understand the others, sir. Which others?
Q. Blanca Francia?
A. No, sir.
Q. Never h eard of it?
A. Oh, yes, I heard of it. But I didnt -- I wasnt aware of that.
Q. Were you aware of anyone else at Neverland who was employed at one point trying to
go to a tabloid to sell a story?
A. No, sir.
Q. Never h eard anything about it?
A. No, sir.
Q. Okay. Did you ever hear anything about Adrian McManus doing that?
A. Well, we went to a tabloid.
Q. Which one?

A. It was The Star.

Q. And who was we?
A. It was myself, Adrian McManus, Kassim Abdool, and I guess that was it.
Q. And approximately when d id you go to this tabloid?
A. We had met at Mr. Rings office in Santa Barbara.
Q. And after you met with your attorney, who represented you in the lawsuit, you went to
a tabloid, correct?
A. Right. Yes, sir.
Q. And you wanted money for a story, true?
A. Yes, sir.
Q. Who did you meet with at the tabloid when you requested money?
A. Can you rephrase that, sir?
Q. Yes, sir. Who did you meet with when you went to a tabloid to request money?
A. Oh, there was myself, Kassim, Adrian, and whoever the reporter was, and Mr. R ing.
Q. Your lawyer was there with you, right?
A. Yes, sir.
Q. You did it with your lawyer because you thought that negative publicity would pressure
Mr. Jackson into paying all of you money, right?
A. No.
MR. SNEDDON: Object as argumentative, Your Honor.
THE COURT: Overruled. The answer was, No. Next question.
Q. BY MR. MESEREAU: You went to the tabloid before the case was tried to a jury, right?
A. I believe so, yes, sir.
Q. Had you filed a case before you went to the tabloid?
A. I dont recall, but I believe so, sir.
Q. Did you sell a story to the tabloid?
A. Yes, sir.
Q. Did you ever hire a broker to help you sell other stories to other tabloids?
A. No, sir.
Q. Did you ever hear anything about McManus doing that?
A. No, sir.
Q. Okay. What other tabloids did you speak to?
A. None, sir.
Q. Just one?
A. Yes, sir.
Q. Just Star?
A. Yes, sir.
Q. But you were aware that McManus went to other tabloids, true?
A. No, sir.
Q. Just Star?
A. Yes, sir.
Q. Did you ever speak to anyone at Inside Edition?
A. No, sir.
Q. Okay. How about any other newspaper?
A. No, sir.
Q. Now, you wanted to sell information about Mr. Jackson alleg edly acting wrongfully with
young men, correct?
A. Yes, sir. To The Star.

Q. And you also wanted to sell informat ion about his relationship with Lisa Marie Presley,
correct?
A. No, sir.
Q. Never d id that?
A. No, sir.
Q. Ever hear of any of your co-plaintiffs doing that?
A. That I recall, I dont recall, sir.
Q. Dont recall it at all?
A. No, sir.
Q. Okay. Was your story printed, to your knowledge?
A. Yes, sir.
Q. Approximately when d id that happen?
A. I dont know the date, sir.
Q. Any idea at all?
A. No, sir.
Q. Okay. Cant even estimate, right?
A. No, sir.
Q. Okay. All right. How long after you told your co-plaintiff against Mr. Jackson, Mr.
Kassim Abdool, about these alleged acts of molestation did you both go to a tabloid?
A. Oh, I -- it wasnt -- it wasnt right away. But I dont recall when it was.
Q. Okay. It was before you went to law enforcement, wasnt it?
A. No, sir.
Q. Was it after it?
A. I believe so, sir. I dont recall.
Q. Okay. Mr. Chacon, in late 93 and early 94, you told other people that Michael Jackson
was innocent of molestation accusations, didnt you?
A. No, sir.
Q. Never told that to anyone at the ranch?
A. No, sir.
Q. Okay. Are you familiar with a tabloid called Splash?
A. Yes, sir.
Q. What is Splash?
A. I believe its a tabloid.
Q. Ever met with someone named Peter Burt from Splash?
A. I dont recall, sir.
Q. Are you saying you dont recall, or you dont -- you didnt?
A. I dont remember, sir, if I d id or not.
Q. So you could have, but you dont remember?
A. Could have, but I dont remember.
Q. Okay. Do you know somebody named Sandy Domz?
A. Yes, sir.
Q. Who was Sandy Domz?
A. She was one of the secretaries at Neverland Ranch.
Q. Okay. Do you recall Sandy Domz ever approaching a tabloid?
A. No, sir.
Q. Dont know anything about it?
A. No, sir.
Q. All right. Do you recall speaking to a book author named Gutierrez?

A. Yes, sir.
Q. And approximately when d id you speak to a book author named Gutierrez?
A. I believe that was before we went to Star, and -- but I dont remember the -- I dont
remember the date or the time.
Q. Okay. Do you remember splitting money from any tablo ids with any other employees
or former employees of Neverland?
A. No, sir.
Q. You never split money for giving information to a T.V. show called Inside Edition?
A. That I recall, no, sir.
Q. So youre not telling the jury you didnt do it, youre just saying, I dont recall?
A. Well, I dont -- I dont think I did it or we did it, no, sir.
Q. You dont know for sure?
A. I just dont recall if we d id or not, sir.
Q. You might have, but you dont remember, right?
A. I dont remember.
Q. Did you ever complain at Neverland that you should be paid more money than you
were getting?
A. No, sir.
Q. Do you remember filing a claim for disability with EDD after you left Neverland?
A. No, sir.
Q. Okay. Are you saying that didnt happen?
A. Well, I filed for unemployment.
Q. Not disability?
A. No, sir.
Q. All right. When is the last time you worked at Neverland; do you know?
A. Its probably mid 94, I believe, or around there.
Q. Now, when you sued Mr. Jackson in Santa Maria, you also sued other people at
Neverland, right?
A. No, sir.
Q. You sued James Van Norman, didnt you?
A. Oh, yes, sir.
Q. You sued Tony Coleman?
A. Yes.
Q. You sued Marcus Johnson, correct?
A. Yes, sir.
Q. And you sued Bill Bray, right?
A. Yes, sir.
Q. And Betty Bailey, right?
A. Yes, sir.
Q. And Andrew Merritt, right?
A. I believe so, yes, sir.
Q. And you were claiming that they had wrongfully interfered with your employment,
correct?
A. Yes, sir, they did.
Q. And are these some of the people that you described as being bodyguards for Mr.
Jackson?
A. Yes, sir, the OSS.
Q. Yes.

A. Yes.
Q. You didnt like the OSS being at Neverland, did you?
A. No, sir.
Q. You wanted to handle all of the security yourself, correct?
A. Well, there was a time that I was in charge, and I knew what I was doing, sir.
Q. And you felt they didnt, right?
A. Well, they shouldnt have interfered with my job.
Q. Okay. And obviously you lost that claim in front of a Santa Maria jury, correct?
A. Yes.
MR. SNEDDON: Object as argumentative, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: The claims against the people in add ition to Mr. Jackson who had
worked at Neverland, you lost those claims, right?
A. Yes, sir.
Q. Now, at the time you sued Mr. Jackson, you had complained that you couldnt pay your
rent, right?
A. No, sir.
Q. Did you ever complain to anyone you couldnt pay your rent?
A. No, sir.
Q. Never complained to any sheriff, right?
A. I dont recall. I dont think so, sir.
Q. Okay. But you dont know for sure?
A. No, sir.
Q. All right. All right. Now, when Mr. Jackson sued you for stealing his property, do you
recall what property he was accusing you of stealing from him?
A. Yes, sir.
Q. What was the property?
A. It was candy bars from the theater. And the other stuff Im not sure of, but I believe
they were referring to my briefcase that had memos, my personal memos from my box at
the security office.
Q. Anything else?
A. No, sir.
Q. Now, the jury found that the material you stole was worth $25,000, correct?
A. No, sir.
Q. Well, they entered a judgment against you for $25,000 for maliciously convert ing Mr.
Jacksons property, true?
MR. SNEDDON: Your Honor, Im going to object to this.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know what the amount was, Mr. Chacon?
MR. SNEDDON: Im going to object. Its the same question, just asked a different way.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You were found to have stolen documents from Mr. Jackson,
true?
MR. SNEDDON: Your Honor, Im going to object; asked and answered.
MR. MESEREAU: I dont think it is.
THE COURT: That question hasnt been asked, but the ruling that I made is that the
issues that you can go into are not the issues of the lawsuit. Its the same as the J.C.
Penney case. You can go into what he said, what he hasnt said, the same exact ruling,

and youre -MR. MESEREAU: Okay.

THE COURT: The area youre in now has to do with the issues in the lawsuit. So I want
you -- thats the line were trying to walk here.
MR. MESEREAU: Okay. Ill move on, Your Honor.
Q. Do you know someone named Linda Allen, Mr. Chacon?
A. Yes, sir.
Q. Who is Linda Allen?
A. She was my land lady in Lompoc.
Q. For how long?
A. Probably about a year. Im not for certain of the length of time.
Q. When you were suing Mr. Jackson, you told Linda Allen you would soon be able to pay
her the back rent you owed, right?
A. No, sir.
MR. SNEDDON: Im going to object to that question. The same 403 ruling.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Did you do that, Mr. Chacon?
A. No, sir.
Q. Did you ever tell Linda Allen, Im going to be a star witness against Michael Jackson?
A. No, sir.
Q. Okay. Ever tell Linda Allen you were going to be on the T.V. show Hard Copy to talk
about Mr. Jackson?
A. No, sir.
Q. Did you ever tell Linda Allen you had a gun permit because you were a star witness
against Michael Jackson?
A. No, sir.
Q. Ever tell Ms. Allen you were going to make two or three million dollars with your suit
against Mr. Jackson?
A. No, sir.
Q. Ever will tell Linda A llen you were going to be driving a 450 Mercedes after you won
your suit against Mr. Jackson?
A. No, sir.
Q. All right. None of that rings a bell, right?
A. No. No.
Q. Okay. Now, in your meeting with the first tabloid that you talked to, okay, where
Abdool was present, who else was there?
A. I believe Adrian McManus, Abdool, myself, Mr. Ring, and whoever represented that
tabloid. I dont know, sir.
Q. Who arranged the meeting?
A. Mr. Ring.
Q. Okay. Do you know someone named Gary Morgan?
A. Ive heard the name before, yes, sir.
Q. Where have you heard the name?
A. Probably -- maybe hes the one that represented the tabloid. Im not sure.
Q. Okay. Did you ever talk to Gary Morgan?
A. I probably did, but I dont recall.
Q. Okay. Do you recall ever being interviewed by someone who claimed to be a media
broker, meaning they could actually get you to various tabloids on

T.V. or in print?
A. No, sir.
Q. Never h eard of anything about that, right?
A. No, sir.
Q. Did you draft a story for the tabloids at Mr. Rings office?
A. Probably, yes, sir. Probably did. I dont -- I dont recall, but I probably did.
Q. Why do you say you probably did?
A. Because its kind of vague. Its been along time, and I guess I did. Im -- I would say I
did, yes, sir.
Q. Well, it hasnt been much longer than the period of time you claim you remember these
events about Mr. Jackson, true?
A. Well, I probably did, sir, draft that -Q. Probably did, or you did?
A. I did.
MR. SNEDDON: Its argumentative.
THE COURT: Overruled. The answer was he did. Next question.
Q. BY MR. MESEREAU: Okay. And did you draft a story for Splash?
A. I believe that was the tabloid, sir.
Q. Okay. And after you drafted it, did you meet with somebody from Splash?
A. Whoever it was. I dont recall, sir.
Q. Were you personally interviewed by somebod from Splash?
A. We all were, sir.
Q. Jointly or ind ividually?
A. Jointly.
Q. Okay. How long was the interview with Splash?
A. Could have been an hour or so. Im not for certain how long.
Q. Do you recall telling anyone that you were using the money from Splash to help fund
your lawsuit against Michael Jackson?
A. Yes, the money went directly to Mr. Ring.
Q. And that was approximately $17,000, wasnt it?
A. I dont know, sir. But whatever it was, he did get it.
Q. So can you estimate what it was?
A. I cant, sir.
Q. Okay. Did you get any money yourself as -A. No, sir.
Q. Do you remember telling people you gave most of it to Mr. Ring, but you took about
500 bucks yourself?
A. Well, we had taken 500 bucks, but we gave it back to Mr. Ring, because he was our
lawyer and he needed money.
Q. Okay. That was to fund the lawsuit where you sought millions from Michael Jackson,
correct?
A. Well, that was the lawsuit, sir.
Q. That was the lawsuit you were trying to fund by selling stories to tabloids, true?
A. No, sir.
Q. No?
A. I really dont understand your question.
Q. Sure, Ill rephrase. You were taking money from tab loids and using it to fund costs of
your lawsuit against Mr. Jackson?

A. Oh. Yes, sir. Im sorry.

Q. And before you went to Mr. Ring, you had told various people that you never saw
anything inappropriate at Neverland, true?
A. No, sir.
Q. You told various people youd never seen Michael Jackson molest anybody, true?
A. No, sir.
Q. So if anybody comes into court and says that, theyre just not telling the truth, right?
A. Thats correct, sir.
Q. Okay. When you first met with representatives of the sheriffs department, did you tell
them everything that you have said today about Mr. Jackson allegedly molesting young
men?
A. Um, when you mean a sheriff, a certain sheriff, or at the sheriffs department, or -- I
dont understand.
Q. Let me rephrase. When you first spoke to a sheriff from Santa Barbara, did you tell that
sheriff everything youve said today in court?
A. No, sir.
Q. The story has changed considerably since your first meeting with a sheriff, true?
MR. SNEDDON: Your Honor, Im going to object to the use of the word considerably as
argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Would you agree that with each interview you do, you add more
lurid facts about Mr. Jackson?
A. No, sir.
Q. You would agree your story about what you claim he did has changed through the
years, has it not?
A. No, sir.
Q. Didnt you just meet with Mr. Sneddon the other day?
A. Yes, sir.
Q. Didnt you tell Mr. Sneddon you had new facts that you forgot in 1993?
MR. SNEDDON: Well, wait a minute. Im going to object to that question. Your Honor,
thats not asked in good faith with regard to the -- I cant do it without a speaking
objection, but if we could approach the bench, because this is not right.
THE COURT: Overruled. The question was, Did you tell Mr. Sneddon you had new facts
that you had forgot in 1993?
THE WITNESS: Yes, I did.
Q. BY MR. MESEREAU: You told Mr. Sneddon that you forgot to say certain things in
1993 about Mr. Jackson allegedly mo lesting young men, true?
A. Yes, sir.
Q. But now you remembered them in 2005, right?
A. Vaguely, yes, sir.
Q. And you said the person that remembered them with you is Kassim Abdool, true?
A. I havent talked to Kassim in years.
Q. Okay. When did you first start work at Neverland, Mr. Chacon?
A. I believe it was in 91, sir.
Q. Okay. You knew that in late 93 and early 94, the med ia was devoting a lot of attention
to stories about Mr. Jackson at Neverland, correct?
A. Well, the media was always at Neverland at some time or other, sir.
Q. Before you chose to go to a tabloid, you knew that others were going to tabloids to try

and 5241 tell stories about Mr. Jackson?

A. No, sir.
Q. You were the first, right?
A. That went to the media, to the tabloids?
Q. Yes.
A. Yes, sir.
Q. And when did you go?
A. It was probably 94 sometime.
Q. But you knew there was a lot of media attention before that, correct?
A. There always has been, sir.
Q. And you knew people were making money doing that, right?
A. No, sir.
Q. Werent aware of that?
A. No, sir.
Q. Thought they were doing it all for free, right, Mr. Chacon?
A. No, sir.
MR. SNEDDON: Object as argumentative, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you think Mr. Jackson is an intimidating-looking individual?
A. No, sir.
Q. Do you remember in your deposition you said you were entitled to damages because
Mr. Jackson stared at you?
A. No, sir.
Q. Remember you said Mr. Jackson stared, and you didnt know how to take it?
A. No, sir.
Q. Would it refresh your recollection if I show you your deposition?
A. Yes, sir.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay. Okay. I remember.
Q. BY MR. MESEREAU: As part of your damage claim, do you remember saying that Mr.
Jackson stared at you continuously?
A. Not continuously, sir.
Q. Well, you said all the time, right?
A. No, sir.
Q. You said no one else saw him staring at you, right?
A. No, sir.
Q. But it bothered you, right?
A. No, sir.
Q. Okay. Why did you say it?
A. I guess just to say it.
Q. Okay. As part of your damage claim, you claimed that employees were threatening you
at Neverland, right?
A. Yes, they were, sir.
Q. All right. And the jury didnt believe that, did they?
MR. SNEDDON: Ill object as argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: When did you start working the graveyard shift at Neverland?

A. Immediately, sir, when I got hired on.

Q. Didnt you gradually work your way into that?
A. Immediately I went to the graveyard. Then they shifted me to swings for a while,
probably a month or so, and then I ended back on graveyard. As a matter of fact, I
preferred to work graveyard, sir, because I had a second job.
Q. Where was the second job?
A. In Lompoc.
Q. What was that?
A. I worked for Waynes Tires.
Q. Do you remember problems with intruders while you worked at Neverland?
A. Yes, sir.
Q. And what problems with intruders do you remember?
A. Them coming on property and -- and we turned them over to the sheriffs department.
Q. And how often do you remember that happening?
A. Probably several times, sir.
Q. Do you recall Mr. Jackson getting nervous about that?
A. No, sir.
Q. Did he seem to care about it, to you?
A. He wasnt even there when we apprehended the people.
Q. He certainly learned about it, to your knowledge, correct?
A. I dont know, sir.
Q. You never talked to him about it?
A. No, sir.
Q. And you were not aware of anyone else telling Mr. Jackson about these problems with
intruders?
A. No, sir.
Q. All right. Sir, Mr. Jackson had some personal security guards because he was worried
about these intruders being caught on the property, right?
A. I dont believe so, sir.
Q. You and the other security people didnt carry any weapons, right?
A. No, sir, we didnt.
Q. And at times, that was a concern of Mr. Jacksons, wasnt it, that his security personnel
there didnt have any weapon to protect him?
A. I dont know, sir.
Q. He had a general policy of not wanting people to carry weapons, true?
A. I dont know, sir.
Q. You dont know at all?
A. No, sir.
Q. Did you ever see any of your security team carrying a weapon?
A. No, sir.
Q. Did you know why?
A. No, sir.
Q. Had no idea at all?
A. No, sir.
Q. Never inquired?
A. No, sir.
Q. When you first joined up, did you ask anybody, Do security people carry weapons at
Neverland?

A. No, sir.
Q. Were you given any manual to refer to when you worked at Neverland?
A. Yes, sir.
Q. And what do you know about that manual?
MR. SNEDDON: Im going to object; vague.
THE COURT: Sustained.
MR. MESEREAU: Its vague, Ill rephrase.
Q. Are you telling the jury that when you started working security at Neverland, nobody
told you, We have a general policy of having security people not carry arms?
A. Well, probably so, because nobody was carrying arms.
Q. Did you have a gun permit at the time?
A. No, sir.
Q. How many meetings did you have with representatives of the sheriffs department
before you think you told all the facts about what you say Mr. Jackson did with young
men?
MR. SNEDDON: Your Honor, Im going to object as argumentative; assumes facts.
THE COURT: Calls for a narrative. You can break that question down.
MR. MESEREAU: Sure.
Q. When was your first meeting with any representative of the sheriffs department
regarding what you claim you saw at Neverland?
A. I dont recall, sir.
Q. Do you know approximately when it was?
A. No, sir, I dont.
Q. Was it after you saw the events you described today?
A. I dont recall, sir.
Q. Well, youve given the jury a detailed description of the events you claim you saw at
Neverland, right?
A. Yes, sir.
Q. But youve forgotten when you talked to the sheriffs, correct?
A. Well, I know I talked to them, but I just dont recall exactly when it was at, sir.
Q. Do you know approximately when it was at?
A. It was in 94, I believe, sometime.
Q. Do you know how many meetings youve had with the sheriffs to date where you have
talked about Mr. Jacksons inappropriate behavior?
A. Well, with the sheriffs, I didnt talk about this, the allegat ions. But with the grand jury,
which I went to testify, that was the first time, and there was sheriffs present there.
Q. You testified before a Santa Barbara Grand Jury, right?
A. Yes, sir.
Q. And after you testified, no criminal charges were brought, right?
A. Right, sir.
Q. You went to Los Angeles and talked to prosecutors -A. No, sir.
Q. -- about what you claim -- you never did that?
A. No, sir.
Q. Didnt you tell Mr. Sneddon on direct examination that you were subpoenaed to a grand
jury in Los Angeles?
A. Oh, yes, sir. But I didnt go.
Q. You didnt go. But you went down to be interviewed under oath instead of going, true?

5248
A. Yes, sir.
Q. And as a result of your interview under oath, no charges were ever brought in Los
Angeles, right?
A. No, sir.
Q. Do you remember testifying how upset you were at Neverland when you learned that
other employees got raises and you didnt?
A. Yes, I believe there was one time.
Q. And tell the jury what that was all about.
A. Probably they had hired two or three security, and they -- I believe they paid them $12
an hour, and we were only getting $9 an hour.
Q. And did you complain about it to somebody?
A. Oh, yes, I did.
Q. Who?
A. Probably the lieutenant.
Q. And what happened?
A. Nothing ever happened.
Q. Was Mr. Abdool upset about that also, to your knowledge?
A. I believe so, yes, sir.
Q. And you and he met and talked about it, right?
A. Pardon me?
Q. You and he met and talked about it, correct?
A. Well, we all talked about that in security.
Q. You lodged a complaint, didnt you?
A. No, sir.
Q. Did you think Mr. Jacksons security guards were being paid more than you?
A. The new ones, yes, sir.
Q. How did you know what they were getting paid?
A. I dont remember. I dont recall, sir, how we found out.
Q. When you told the jury you saw a young boy on Mr. Jacksons back, was that in the
shower?
A. No, it was coming out, going towards his house.
Q. Was he on his shoulders?
A. You know, I dont recall if he was on his shoulders or on his back, like piggybacked,
yes, sir.
Q. When you went to work at Neverland, you were asked to sign a confidentiality
agreement, right?
A. Yes, sir.
Q. And everybody who works at Neverland is asked to sign one, right?
A. Yes, sir.
Q. And the purpose, as explained to you, was that Mr. Jackson doesnt want employees
just running to tabloids and telling stories, right?
A. Yes, sir, I believe so.
Q. When you went to a tabloid, you vio lated the agreement, correct?
MR. SNEDDON: Object, Your Honor, calls for a legal conclusion.
THE COURT: Overruled. You may answer.
THE WITNESS: No, sir.
Q. BY MR. MESEREAU: You didnt violate it all?

A. No, sir.
Q. So you thought going to a tabloid after you left your employment at Neverland was
perfectly consistent with your confidentiality obligat ions to Mr. Jackson, right?
A. I dont think I ever signed a confident iality, sir.
Q. Sure about that?
A. Im not for certain, but I dont recall that I ever d id.
Q. Werent you asked to?
A. I probably was. But at that time they d idnt have one for me.
Q. At the time you and Mr. Abdool and Ms. McManus and your lawyer went to the tabloid,
your lawyer was trying to negotiate to get money from Mr. Jackson, wasnt he?
MR. SNEDDON: Im going to object. Lack of foundation and it assumes -THE COURT: Foundation; sustained.
Q. BY MR. MESEREAU: At the time you and Mr. Abdool and Ms. McManus and your
lawyer went to a tabloid to give a story about Mr. Jackson, do you know whether or not
your lawyer was trying to negotiate money from Mr. Jackson?
A. No, sir.
Q. Do you know whether or not your lawyer was trying to pressure Mr. Jackson by
threatening bad publicity?
A. No, sir.
Q. Did you ever hear of anything like that going on?
A. No, sir.
Q. Okay. So if that went on, youd be shocked, true?
A. Probably not, sir.
Q. Probably not?
A. I guess not, no.
Q. Did you ever explain to Mr. Jackson yourself that you were having trouble making ends
meet financially?
A. No, sir.
Q. Did you explain to anyone at Neverland about that before you left?
A. No, sir.
Q. All right. Without getting into any of your discussions with your lawyer, who of your
group first went to that attorney?
A. Which attorney, sir?
Q. Ring. Mr. R ing.
A. Who first went to Mr. Ring?
Q. Yes.
A. Of us?
Q. Of you. Excuse me, let me rephrase the question. Make it clearer. You, Mr. Abdool, Ms.
McManus sued Mr. Jackson, correct?
A. Yes, sir.
Q. You were represented by a lawyer in Santa Barbara named Mr. R ing, correct?
A. Yes, sir.
Q. And he represented you throughout that six-month trial that you lost, correct?
A. Yes, sir.
Q. Who first approached Mr. Ring about trying to get money from Mr. Jackson?
A. We all did, sir.
Q. Together?
A. We hired him, yes, sir.

Q. Okay. Do you know how you found out about him?

A. I dont recall, sir.
Q. Was he the only lawyer you talked to, or did you talk to some others?
A. I believe he was the only one we talked to, yes, sir.
Q. Do you recall whether you ever told anyone, Mr. Jackson promised me if I did a good
job, I would have a job at Neverland forever?
A. No, sir.
Q. Did he ever say anything like that to you?
A. No, sir.
Q. Did anyone who hired you at Neverland?
A. No, sir.
Q. Okay. You met with Prosecutor Sneddon on April 6th, correct?
A. Yes, sir.
Q. Was anyone else at the meet ing?
A. Yes, sir.
Q. Who?
A. Russ Birchim.
Q. Where did the meeting take place?
A. Here in Santa Maria.
Q. And who arranged the meeting?
A. I believe it was Mr. Sneddon.
Q. Did he call you on the phone?
A. Yes, sir.
Q. Did he tell you where to meet?
A. Yes, sir.
Q. How long was the meeting?
A. Probably less than an hour.
Q. Did you discuss anything you were going to say today?
A. I believe so, yes, sir.
Q. Did Mr. Sneddon tell you what questions he was going to ask you today?
A. Yes, sir.
Q. Did you tell him what answers you were going to give to those questions?
A. No, sir.
Q. Did you tell him anything about how you were going to respond?
A. I just told him that I would speak the truth.
Q. Thats it?
A. Yes, sir.
Q. How long was the meeting?
A. Probably about -- less than an hour.
Q. So during the portion of that hour that you spoke, all you ever said was, Ill tell the
truth, Ill tell the truth, Ill tell the truth, or words to that effect?
A. No, sir. No, sir.
Q. Okay. He told you what questions he was going to ask you, correct?
A. I believe so, yes, sir.
Q. You told him what your responses were going to be, right?
A. Yes, sir.
Q. When was the -- excuse me. Before that meeting, when was the last time you had met
with anyone from the prosecuting office here?

A. I didnt meet with anybody.

Q. Did you talk with anyone on the phone?
A. Yes, sir. I was -Q. Who was that?
A. I believe it was a secretary from Mr. Sneddons office.
Q. And what was that discussion about?
A. When I was supposed to be down here and how to get -- how to get to Santa Maria.
Q. How many meetings have you had with any representative of the sheriffs department
in total to talk about your testimony?
MR. SNEDDON: Your Honor, Im going to object as vague as to time, a time period.
MR. MESEREAU: Ill rephrase it.
THE COURT: All right.
Q. BY MR. MESEREAU: In the last year, how many meetings have you had with anyone
representing the Santa Barbara Sheriffs Department to talk about this case?
A. I havent, sir.
Q. How about phone calls?
A. No, sir.
Q. All right. Youre aware of Mr. Jackson going on tour -- excuse me. Let me rephrase it.
Youre aware that Mr. Jackson periodically went on tour while you worked at Neverland,
true?
A. Yes, sir.
Q. And it was your understanding he always had bodyguards with him, correct, on tour?
A. I understood that, yes, sir.
Q. Okay. You knew he was extremely concerned about his security, right?
A. His bodyguard security or security on the ranch?
Q. Well, Mr. Jackson was extremely concerned about security on the ranch, wasnt he?
A. I dont know, sir.
Q. You dont know?
A. No, sir.
Q. Even with these intruders, youre not sure if he was concerned?
A. Well, Im sure he was concerned, but he was never there when we did apprehend
them.
Q. Okay. You knew he had concerns about his personal security when he went on tour,
right?
A. Oh, yes, sir. Yes, sir.
Q. And at all times that you worked on the ranch, you knew he had personal bodyguards
when he went on tour, right?
A. When he went on tour, yes, sir.
Q. You knew he had personal protection when he went other places for other reasons,
true?
A. I assume so, sir. I dont know.
Q. Do you remember comp laining that Mr. Abdool got a raise when you didnt?
A. No, sir.
Q. Never h appened?
A. No.
Q. When you left Neverland, you just stopped showing up for work, right?
A. Yes, sir.
Q. You stopped showing up for work after you met with Attorney Ring, correct?

A. Probably so, yes, sir.

Q. You were disappointed that you werent getting more money from tabloids, werent
you?
A. No, sir.
Q. Never complained to anybody about that?
A. No, sir.
Q. The first incident you claim you saw Mr. Jackson improperly touch a young man was
when?
A. I dont recall. Between 92 and 93, I believe. Im not for certain.
Q. Do you recall ever telling any representative of law enforcement the month or the
year?
A. No, sir. I dont -- no.
Q. And what shower are you claiming Mr. Jackson used when you say you looked in a
shower and saw him acting inappropriately?
A. It was the outside rest rooms by the rec room.
Q. There were two of them, right?
A. Two rest rooms?
Q. Yes.
A. There was a womens and a mens room, Im sorry.
Q. And which one do you claim you saw Mr. Jackson in?
A. In the mens room, sir.
Q. Had you seen him in that mens room before?
A. Yes, sir.
Q. Okay. By the way, when you went to the Santa Barbara Grand Jury, you didnt tell
them everything you said today, did you?
A. Yes, sir.
Q. Everything?
A. Yes, sir.
Q. Did you tell them everything youve told Mr. Sneddon?
A. Well, that one incident that I recalled I d idnt. I didnt bring that up, no, sir.
Q. How long were you in front of a Santa Barbara Grand Jury?
A. Could have been a couple hours.
Q. And at some point, you called to see if anybody had charged Mr. Jackson with
anything, didnt you?
A. No, sir.
Q. Never asked anyone?
A. No, sir.
Q. Never asked anyone in the sheriffs department?
A. No, sir.
Q. Never asked Mr. Sneddon?
A. No, sir.
Q. To this day youve never asked that question, right?
A. No, sir.
Q. All right. When did you first learn Blanca Francia had sold a story to Hard Copy?
MR. SNEDDON: Your Honor, Im going to object. That question has been asked and
answered and that assumes facts not in evidence.
MR. MESEREAU: Ill rephrase it.
THE COURT: All right.

Q. BY MR. MESEREAU: Did you ever learn that Blanca Francia had told a story for
$20,000 to the T.V. show Hard Copy?
A. No.
MR. SNEDDON: Object. Asked and answered.
THE COURT: All right. He answered it. Its No. Next question.
Q. BY MR. MESEREAU: Did you ever learn she had sold a story to Hard Copy, without
knowing the amount she got?
A. Yes, sir.
Q. When did you learn that?
A. Probably on the news.
Q. On the news when?
A. I dont recall, sir. It was -- it was public knowledge.
Q. Did you see the show?
A. No, sir.
Q. Did you hear about it right after it appeared on television?
A. No, sir.
Q. Were you employed when that was on television?
A. No, sir.
Q. Where were you working at that point?
A. Where was I working? Thats a good question. I believe I was already in Nevada by that
time.
Q. And what were you doing there?
A. I was a substitute teacher at a high school and junior high.
Q. What year was this?
A. 96, 7, 8.
Q. Do you remember learning that security guards at the Jackson home in Encino had sold
stories for $100,000?
A. No, sir, I didnt know anything about that place.
Q. Never h eard anything about that?
A. Well, I know they had security guards, but I never heard anything.
Q. Did you hear anything about security guards at the Encino home selling a story for
$100,000?
A. No, sir.
Q. All right. Ever know someone named Quindoy?
A. I want to say that the Quindoys -- I believe they were chefs, I believe, but Im not
positive.
Q. They were what?
A. I believe they were cooks or chefs there at some property.
Q. Did you know them?
A. No, sir.
Q. Ever talk to them?
A. No, sir.
Q. Did you know they had tried to sell stories to tabloids about Mr. Jackson?
A. No, sir.
Q. Had you ever heard anything about that as you sit here today?
A. Probably have, but I dont recall.
Q. Okay. Now, at some point you claimed you were improperly subjected to electronic
surveillance at Neverland, right?

A. Could you be a little bit more specific, sir?

Q. Sure.
MR. SNEDDON: Your Honor, Im going to object. Im going to object because of the 403
ruling, but more specifically because there ar mult iple defendants in the causes of action.
It may be different as to different individuals.
MR. MESEREAU: Im only talking about him, Your Honor. His claims against Mr. Jackson.
THE COURT: Im going to allow the question, but Im going to do so assuming its not
related to specific allegations in the Complaint, which I already said you cant direct ly go
into.
MR. MESEREAU: Okay. W ell, there were such -- there were such claims, Your Honor.
THE COURT: I know, but were not relitigat ing that issue. But he could have made a claim
or his attorney could have made a claim. Youre asking him not about claims his attorney
made, but claims that he made.
MR. MESEREAU: Yes, I am.
THE COURT: Im going to allow the question with that understanding.
MR. MESEREAU: Thank you, Your Honor.
THE COURT: But you probably have to read it back to him. Do you remember the
question?
MR. MESEREAU: I can rephrase it.
THE WITNESS: No.
MR. MESEREAU: Ill withdraw it.
Q. Do you remember claiming that you were emotionally distressed because you thought
your
telephone conversations were listened in to at Neverland?
A. Yes, sir.
Q. And you never knew whether or not there was a tap on any phone, correct?
A. Yes, I did, sir.
Q. Are you saying you did know there was a tap?
A. Yes, sir, I knew that they had equipment where they were listening in.
Q. Do you remember testifying under oath you didnt know if your phone was tapped?
A. At home or at the ranch, sir?
Q. Either place.
A. Yes, sir.
Q. Did you ever state under oath you didnt know whether your phone was tapped?
MR. SNEDDON: Your Honor, I object to the question as vague as to place.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You claim you had been emotionally damaged because someone
listened in to your calls at Neverland, right?
A. Emotionally damaged. Well, I probably -- probably didnt say that, but I was upset
because they were listening to my personal phone calls, sir.
Q. Okay. And your basis for saying that was that somebody had told you that was going
on, right?
A. No, sir, I knew it was going on.
Q. You had no knowledge of electronic surveillance at the time, did you?
A. Yes, sir, I did.
Q. Did you have a check done on the phones?
A. No, sir.
Q. When is the last time you talked to any tabloid about this case?

A. I have not, sir.

Q. You havent?
A. I havent talked to anyone.
Q. Are you planning to go to a tabloid after you testify?
A. No, sir. I just want to go home.
Q. Did you make a complaint that your employee file was unfairly looked at at Neverland?
A. Yes, sir.
Q. And who did you think had unfairly looked at your employee file?
A. The OSS, sir.
Q. Thats Mr. Jacksons personal security guards?
A. Yes, sir.
Q. Did you have any idea why they were suspicious of you?
A. No, sir.
Q. They were, werent they?
A. I dont know, sir.
Q. Did you ever talk to them about why they wanted to see what was in your personnel
file?
A. Yes, I approached them.
Q. This was around the time you went to a tabloid, wasnt it?
A. No, sir.
Q. This was around the time you went to Mr. Ring, wasnt it?
A. No, sir.
Q. It was very close to the time you left emp loyment at Neverland, wasnt it?
A. I believe so, yes, sir.
Q. Do you remember saying you thought Mr. Jackson should compensate you for the rest
of your life?
A. No, sir.
Q. Would it refresh your recollection to show you your deposition transcript?
A. Yes, sir.
MR. MESEREAU: May I approach?
THE COURT: Yes.
THE WITNESS: Where is the beginning? Oh, I must have, sir.
Q. BY MR. MESEREAU: Have you had a chance to look at that page in your deposition?
A. Yes, sir.
Q. Does it refresh your recollection that you testified under oath that you thought Mr.
Jackson should compensate you for the rest of your life?
A. I must have said that, yes, sir, because its on there.
Q. Now, was it the policy at Neverland to notify the local sheriffs if an intruder was caught
on the property?
A. Yes, sir, thats correct.
Q. Did you personally notify the sheriffs at any time about an intruder being on the
property?
A. No, sir.
Q. Do you recall you personally apprehend ing any intruders?
A. Myself and Abdool, yes, sir.
Q. And what happened?
A. There was an intruder that came behind the pool area. It was a reporter. And we just
apprehended him and took him down to the front gate and probably the security at the

gate called the sheriffs.

Q. The pool area is right next to Mr. Jacksons house, isnt it?
A. Around the area, yes, sir.
Q. And how many people did you apprehend on that occasion?
A. One. One, sir.
Q. How far did that intruder have to travel to get to the pool area?
A. I dont know which direct ion he came in, sir. Could have been -- could have been a
mile, two miles, three miles. I dont know, sir.
Q. And you also were involved in some other situations where intruders tried to get to Mr.
Jackson, correct?
A. Yes, sir.
Q. And please describe those events.
A. Kind of vague, but I believe there was two -- two young people, a male and a female, I
believe, and they were up by -- they were up by the -- by the theater.
Q. The theater would be up near the zoo area?
A. Yes, sir.
Q. And who caught them?
A. I believe it was mobile. I dont know who it was that was on mobile that evening, that
night, but it was mobile patrol.
Q. Did you ever steal a watch from Mr. Jackson?
A. No, sir.
Q. Were you ever accused of that?
A. No, sir.
Q. You mentioned candy bars earlier, remember?
A. Yes, sir.
Q. Do you think the jury awarded Mr. Jackson $25,000 against you because you took
candy bars?
A. Thats what -MR. SNEDDON: Im going to object as argumentative.
MR. MESEREAU: I have no further questions, Your Honor.
THE COURT: Redirect?
MR. SNEDDON: Yes.
REDIRECT EXAMINATION BY MR. SNEDDON:
Q. All right. Lets go back just for a second. Mr. Chacon, were you subpoenaed to be here
this morning?
A. Yes, sir.
Q. Youre under subpoena?
A. Yes, sir.
Q. Did you want to come testify?
A. No, sir.
Q. When you testified before the grand jury, were you under subpoena?
A. Yes, sir.
Q. Did you want to testify?
A. No, sir.
Q. Prior to your appearance before the grand jury, you told the ladies and gentlemen that
you met with attorneys for Mr. Jackson; is that correct?

A. Yes, sir.
Q. And with regard to that conversation, did they want to know what you were going to
say?
A. They did.
Q. And what did you tell them?
A. I said that I got subpoenaed, and if I got subpoenaed, that I would just speak the
truth, but I didnt tell them what I knew, but they wanted to know.
Q. They wanted to know, but you wouldnt tell them?
A. Yes, sir.
Q. But you told them you were going to tell the grand jury the truth?
A. Yes, sir.
Q. And did you do that?
A. Yes, sir.
Q. Now, with regard to Mr. Mesereau saying that you added something to the events that
occurred yesterday when you and I were talking, do you recall him asking you that
question?
A. Yes, sir.
Q. The new information you provided yesterday had nothing to do with the two events
youve described to the jury, had they?
A. No, sir.
Q. There was nothing that changed about that, was there?
A. No, sir.
Q. In fact, the event that you indicated -- there was -- something that you remembered
was something you were told by another person; wasnt that correct?
A. Yes, sir.
Q. And who was that other person?
A. Abdool.
Q. It was in no way connected to the testimony you gave concerning the two incidents you
observed?
A. No, sir.
Q. Now, with regard -- just so the jury has a clear indicat ion of the sequence here, you
were subpoenaed to appear before the Santa Barbara County Grand Jury, correct?
A. Yes, sir.
Q. Now, when you actually gave your statement under oath, was there a line of jurors like
this in the room?
A. Back in ninety -Q. 94, when you came in.
A. Yes, sir.
Q. Now, how long after that was it that Mr. Ring became involved in the civil lawsuit? Let
me
put it this way: After you appeared before the Santa Barbara Grand Jury and gave a
statement under oath, do you recall that?
A. Oh, yes, sir.
Q. And you went back to work at the ranch, did you not?
A. Yes, sir.
Q. And you worked at the ranch, Neverland Valley Ranch, for a while before you left there,
correct?
A. Probably a month or so, or two. Im not positive.

Q. Was it at that point that you became involved in the lawsuit with Mr. R ing?
A. Yes, sir.
Q. Whose idea was it to go to the tabloid for the story?
A. Well, we probably talked about it, but we talked to Mr. Ring about it. I guess it was all
of us in general.
Q. After you -- Mr. Mesereau asked you about your salary at the ranch. Do you recall
that?
A. Yes, sir.
Q. And you spoke about being dissatisfied with the wages that you were getting -A. Yes, sir.
Q. -- compared to some people that had been hired afterward, correct?
A. Yes, sir.
Q. After your conversations with Mr. Sanger and Steve Cochran about your grand jury
appearance, were you offered a raise?
A. Yes, sir, I was.
Q. And it was before your testimony actually occurred before the grand jury, correct?
A. Yes, sir.
Q. So it was in between the time they found out you were going and the time that you
actually appeared they offered you a raise?
A. Yes, sir.
Q. And Mr. Kassim also, right?
A. Yes, sir.
Q. Actually, its Mr. Abdool.
A. Yes, sir.
Q. Now, during the course of the -- let me ask you this: After you testified before the
grand jury and gave your statement under oath about what you saw happen on those two
incidents - okay? - did you receive threats?
A. Oh, yes, sir.
Q. In what form?
MR. MESEREAU: Objection; beyond the scope.
THE COURT: Sustained.
MR. SNEDDON: Judge, its what led to the lawsuit. And counsel was allowed to go into
that.
THE COURT: All right. With that representation, Ill change my ruling.
THE WITNESS: Could you -MR. SNEDDON: Yes.
Q. You said you were threatened. In what form?
A. Verbally, and -- well, verbally, and somewhat physically by someone touching their -Tony Coleman touching his weapon.
Q. Tony Coleman was who?
A. He was OSS.
Q. All right. Would you describe to the jury -- if you have to stand up, do it. Describe to
the jury what Mr. Coleman did.
A. We were in the security office, and we were arguing about an intruder that came in,
and he wanted to do it his way. And I said, If you do it that way, were going to -- its
not the procedure. And then he says, Well, Im going to do it my way because Im here
to oversee you. And he touched -- he pulled his coat back and he touched his weapon,
and he says, Im in charge here. I believe thats the words he used.

Q. Did he at any other time ever use his weapon to indicate a threat towards you?
A. No, sir, that was about the first time.
Q. Did you ever receive any phone calls of any kind that were threatening?
A. Yes, sir.
Q. Did you report those to law enforcement?
A. Yes, I did, sir.
Q. How many occasions did that occur?
A. Several t imes. One time when we first started, somebody says -MR. MESEREAU: Objection; nonresponsive
THE COURT: After several t imes, sustained.
Q. BY MR. SNEDDON: All right. Tell us about those threats that you received.
A. The first time I received it, they said, Im going to kill you.
MR. MESEREAU: Objection; hearsay.
MR. SNEDDON: Your Honor, goes to the state of mind and to the reason for the lawsuit.
THE COURT: Im going to overrule the objection as to state of mind.
Q. BY MR. SNEDDON: Go ahead.
A. Someone called and said, Im going to kill you, and hung up. And then other times we
had calls at the house where they would either laugh or wouldnt say words, but we knew
that someone was -- I believe it was OSS behind this.
Q. Did you as a result -- did you take these things seriously?
A. Oh, yes, sir.
Q. Did you approach anyone with regard to obtaining a gun permit?
A. Yes, sir.
Q. And who did you approach?
A. I asked Mr. B irchim and yourself for a gun permit. So I carried a concealed weapon
permit for about two years, I believe it was.
Q. You indicated that you may have asked Sergeant or now Commander Birchim for
money for your wife -A. Yes, sir.
Q. -- do you recall? Do you remember why that was?
A. Yes, sir.
Q. Why was that?
A. Well, my wifes sister-in-law had just died, and -Q. Thats all right, Ill withdraw the question. Thats okay. Its not important. Mr. Mesereau
asked you about - well turn to a subject a little easier - about my conversation with you
yesterday -A. Yes, sir.
Q. -- with Mr. Birchim being there.
A. Yes, sir.
Q. And you told Mr. Mesereau how long the conversation lasted, correct?
A. Yes, sir.
Q. Was Mr. Birchim present during the entire conversation?
A. Yes, he was.
Q. Were there portions of time before Mr. Birchim got there that you and I talked a little
bit?
A. Yes, sir.
Q. Did we talk about anything about this case?
A. No, sir. We talked about my military experience, and that you knew some people that I

knew where I was born and raised.

Q. Had nothing to do with the case during the time B irchim wasnt there?
A. No, sir.
MR. MESEREAU: Objection; asked and answered.
THE WITNESS: No, sir.
Q. BY MR. SNEDDON: Now, when we were talking yesterday -THE COURT: Sustained. Go ahead (Laughter.)
Q. BY MR. SNEDDON: When we were talking yesterday and Mr. Mesereau asked you did
I tell you what questions I was going to ask you today, do you recall him asking you that
question?
A. Yes, sir.
Q. What was the question that I actually asked you; do you remember?
A. I believe it was the incidents that took place, the two incidents that happened on the
ranch.
Q. And I asked you just to describe them in your own words to me?
A. Yes, sir.
Q. And Sergeant -- or Commander Birchim was there during that entire time?
A. Yes, he was.
Q. Mr. Mesereau mentioned something about an individual called Victor Gutierrez. Do you
remember that?
A. Yes, sir.
Q. Were you ever paid any money by Mr. Gutierrez?
A. No, sir.
Q. Did you ever give him a statement at all?
A. No, sir.
Q. You indicated that the individuals who were on the ranch that were armed were called
the OSS. Was that their official name, or was that a name that the security staff gave
them?
A. I believe thats -- it was used for them as a short title. Office of Special Services, but
they used it as -- just call them OSS.
Q. And with regard to -- you told the jury that they interfered with you on how you did
your job. In what respect? I mean, what was the tension or the friction between the two
of you?
A. They just -- they just interfered in every aspect of our duty as security there. They
would break the beams, the security beams, and they would cause us to run out there
thinking it was an intruder. They would come by and laugh, and just make jokes, and/or
sit out in their vehicle and stare at us inside the security office.
Q. With regard to the lawsuit itself that Mr. Mesereau has asked you a number of
questions about, were you ever consulted about the amount of money that was going to
be sued for?
A. No, sir.
Q. Whose judgment did you leave that decision?
A. Mr. Ring.
Q. Did you leg it -- did you feel, yourself, that you were ent itled to some money from Mr.
Jackson because of the way you were treated on the ranch?
A. Yes, sir.
Q. Do you still feel that way?
A. Yes, sir.

MR. MESEREAU: Objection. Move to strike; relevance.

THE COURT: Sustained; stricken.
Q. BY MR. SNEDDON: You told the jury that you knew that you were being -- your
telephones on the ranch were being monitored, correct?
A. Yes, sir.
Q. How did you know that?
A. It was common knowledge that -- in the main office where Sandy Domz worked at,
there was a computer paper printout that -- you could hear, and it printed out the phone
calls as they were made, either going out or coming in.
Q. Now, just a couple of more questions. With regard to the lawsuit, the trial, the civil
lawsuit, were you -- or did you -- during that lawsuit, were you allowed or permitted to
testify concerning the incidents you told this jury about this morning in that lawsuit?
A. No, sir. As a matter of fact, the judge said if I -- if we -Q. You just werent allowed to?
A. No, sir.
Q. Okay. Mr. Chacon, is there anything that youve told this jury this morning about what
you saw out there on those two incidents that is anything but the truth?
A. Its the truth, sir.
MR. SNEDDON: No further questions.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Mr. Chacon, the prosecutor has just asked you to talk about problems you had with the
OSS, right?
A. Yes, sir.
Q. And the OSS was a nickname someone developed to call Mr. Jacksons personal
bodyguards?
A. They themselves, sir.
Q. You wanted money to be awarded to you from a Santa Maria jury because of your
problems with the personal security guards of Mr. Jackson, correct?
A. Yes, sir.
Q. Your claims were rejected, true?
A. Yes, sir.
Q. You also claimed at the time $16 million wasnt enough for you, right?
A. I probably did, sir. Yes, sir.
Q. The prosecutor just asked you if you knew anything about the amounts you were
seeking, and of course you did, right?
A. Yes, sir.
Q. You wanted money because you claim that people were calling your home and hanging
up, correct?
A. That was part of it, sir, yes, sir.
Q. And a Santa Maria jury rejected that claim, correct?
A. Yes, sir.
Q. You said that someone named Coleman had put his hand on his gun because he didnt
like the way you wanted to handle an intruder; is that correct?
A. No, because he wanted to handle it.
Q. He was a personal security guard, correct?
A. OSS. Not a security guard.

Q. He was carrying a -- well, this group you call the OSS, theyre bodyguards for Mr.
Jackson, right?
A. Yes, sir, they are.
Q. And they were carrying weapons, correct?
A. Yes, sir.
Q. And he was concerned about the intruder, correct?
A. No, sir.
Q. You sued also claiming you should get money because of what Mr. Co leman d id on that
day, correct?
A. He threatened me, yes, sir.
Q. And that was rejected by a Santa Maria jury as well, correct?
A. Yes, sir.
Q. And you wanted money because you said Mr. Jackson stared at you on occasion,
correct?
A. No, sir.
Q. Why did you say it?
A. Just to say it.
MR. MESEREAU: No further questions.
MR. SNEDDON: No questions, Your Honor.
THE COURT: All right. Thank you. You may step down.

ADRIAN MARIE McMANUS EXAMINATION

DIRECT EXAMINATION BY MR. ZONEN:

Q. Ms. McManus, good morning.

A. Good morning.
Q. Without telling us the location or the name of where youre working, describe the kind
of work youre currently doing.
A. I work in a jewelry department where I sell diamonds.
Q. Is this a department store?
A. Yes, sir.
Q. Is it in the Santa Maria area?
A. Yes.
Q. How long have you been working at that department store?
A. Seven years in July.
Q. You work in the diamond department, do you?
A. Yes.
Q. All right. There is such a thing as a diamond department?
A. Yes.
Q. They sell raw d iamonds or finished diamonds or jewelry?
A. Fine diamonds, jewelry.
Q. All right.
A. Its actually a lot of diamonds.
Q. Okay. Have you worked in that department the entire time?
A. No.
Q. Have you worked in other departments in that store as well?
A. Yes.
Q. Prior to that, what kind of work were you doing?
A. I was a merchandise assistant for the cosmetic department.
Q. At the same store?
A. Yes.
Q. For what period of time?
A. Probably the beginning of my employment. Maybe about four years.
Q. And prior to that, what kind of work were you doing?
A. Do you mean like after that or before that?
Q. Before working with this store.
A. I worked for Sears, and I ran -- I was in the cosmetic department.
Q. Did you ever work for Michael Jackson?
A. Yes.
Q. Do you see Michael Jackson in this courtroom?
A. I dont have my glasses. I forgot them upstairs.
Q. How far can you see?
A. I cant see real far.
Q. Can you see me?
A. Yeah, blurry.
Q. I wont ask that question, then. Can you read, in the event we need to show you some
documents?
A. No, I need to get my glasses.
Q. Were going to have a break in a few minutes. Ill reserve all those questions until we
have that break. You did work for Michael Jackson at some point, did you not?
A. Yes.

Q. For what period of time did you work for Michael Jackson?
A. From, I think, August 29th of 1990 through July 31st of 1994.
Q. In what capacity? W hat kind of work did you do for Mr. Jackson?
A. At the beginning I was just a maid, regular housekeeper. Nine months later I was
cleaning his bedroom.
Q. And did you continue that job for the duration of your employment?
A. Yes.
Q. Were you the only person cleaning his bedroom?
A. Yes.
Q. Tell me how that worked. W hy were there not other people involved in cleaning his
bedroom as well?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. ZONEN: What were you told about who would be cleaning his bedroom?
A. I was just told that I was flexible and that I was the one to clean his bedroom.
Q. And that was that entire time after a few months after you commenced working for Mr.
Jackson?
A. Yes.
Q. So it was early 91?
A. I just know it was nine months after, because I started in 90, and -Q. Now, up to that point, you were responsible for cleaning other locations at Neverland;
is that correct?
A. Yes.
Q. What were those other locations? Tell us what your job included.
A. Before that time?
Q. Yes.
A. Cleaning the rec room, the ranch house, the guest units, the hill house, the main
house, except his bedroom at that time.
Q. Do you know who the person was who was responsible for cleaning his bedroom before
you?
A. Blanca Francia.
Q. And did you know Blanca Francia?
A. Yes.
Q. Were you the one who took over that job when she left?
A. Yes.
Q. Did you take over that job as soon as she left?
A. Yes.
Q. Describe to us what those responsibilit ies included, cleaning -THE COURT: Lets take a break. (Recess taken.)
THE COURT: Go ahead.
Q. BY MR. ZONEN: Thank you. Where we left off before the break, I was asking you
about your responsibilities, once you assumed the position of being the personal maid for
Michael Jackson. And before I get to that, do you have your glasses?
A. Yes.
Q. Is Mr. Jackson here in the courtroom?
A. Yes.
Q. Okay. Could you identify him, please?
A. Hes right here.

MR. ZONEN: And the record should reflect.

THE COURT: Yes.
Q. BY MR. ZONEN: What were your responsibilit ies as his personal maid?
A. To pick up after Mr. Jackson, anything to do with his clothes, his -- washing his clothes,
fixing his bed, cleaning his bedroom.
BAILIFF CORTEZ: Im sorry, can you speak more into the microphone?
Q. BY MR. ZONEN: You have to stay fairly close to the microphone to be able to be heard
all the way to the back of the courtroom, if you will. Describe his bedroom suite for us,
please.
A. It was a very big room. There was a second level to it. There was a Jacuzzi on one side
with a bathroom. A closet. Inside that closet was a secret closet. The other side of the
room there was bathroom also, and another walk-in closet, and there was a stairway that
led up to the second level.
Q. Were your responsibilit ies limited to that suite?
A. At one time, yes.
Q. All right. What if Mr. Jackson was gone for a while, if he was on tour, or out of town for
a period of time, what would you do?
A. I still had to pick up the room, as far as keeping it dusted, and brassing, and cleaning
the tub. There was still a lot to do.
Q. Were there responsibilities that went beyond the suite on those occasions?
A. Yes.
Q. Did Mr. Jackson have monkeys during that period of time, or apes, or chimps, or -A. Yes.
Q. -- primates?
A. Yes.
Q. Were they living in his room?
A. They werent living in h is room, but they were brought into his room.
Q. Were there cages for them?
A. Some -- well, when I seen them, they were running around.
Q. Did you ever see cages in his room?
A. I dont recall seeing cages in the room.
Q. Were you, on occasion, required to tend to the monkeys or clean up after the
monkeys?
A. Yes.
Q. And describe what that obligation was.
A. Well, there was a little monkey, a chimp, and -MR. MESEREAU: Objection; relevance.
THE COURT: Relevance, Counsel?
MR. ZONEN: Ill withdraw the question. Let me move on.
Q. Were you the personal maid for the balance of time that you were there?
A. Yes.
Q. All right. Do you know a person by the name -- or did you know a person by the name
of Wade Robeson?
A. Yes.
Q. Who was Wade Robeson?
A. He was a little boy that used to go to the ranch, and he was from Australia.
Q. How old was he when you saw him at the ranch?
A. I dont know exact. Maybe 10, 11.

Q. Now, you have a son, do you not?

A. Yes.
Q. And your son at that time was approximately how old?
A. Maybe ten.
Q. About the same age as W ade Robeson?
A. Yes.
Q. Did your son ever come with you to Neverland Ranch?
A. Yes.
Q. On many occas ions?
A. Yes.
Q. Did your son know Wade Robeson?
A. Yes.
Q. Did they, on occasion, play together?
A. Off and on.
Q. For what period of time did you see Wade Robeson there at the ranch; do you recall?
A. Are you talking about, like, months or -Q. Well, for what period of time d id Wad Robeson visit the ranch?
A. Are you talking about years or just the timing, like?
Q. From the earliest time that you saw him visit to, say, the last time you saw him vis it, if
you can recall, give us a sense of what period of time that was.
A. I would say probably 1992. I dont know how many months.
Q. And did you see him there for a long period of time?
MR. MESEREAU: Objection; vague.
THE COURT: Sustained.
Q. BY MR. ZONEN: How often did he visit during that period of time? In other words, how
many separate times did he come, to your recollection?
A. There were a lot of times. Come maybe for a week or the weekend.
Q. All right. And that was my next question.
A. Sorry.
Q. How long would he stay when he did come?
A. Sometimes a weekend, sometimes maybe a little longer.
Q. And during that period of time, where d id -- where did Wade Robeson stay when he
was at the house, when he was at the ranch?
A. In Mr. Jacksons room.
Q. Were you the personal maid for Mr. Jackson during the entire time that Wade Robeson
visited?
A. I believe so. Yes.
Q. Let me change that again. During the period of time that you were the personal maid,
was W ade Robeson visiting that entire time?
A. Yes.
Q. Okay. I think you said among your responsibilities were to pick up after Mr. Jackson
and wash clothing. Do you have a recollection as to whether or not you saw Wade
Robesons personal possessions?
A. Sometimes.
Q. And I asked you where W ade Robeson stayed, and you said Mr. Jacksons room. Do
you know where he stayed in the room?
A. In the same bed as Mr. Jackson.
Q. Okay. Were there other beds in Mr. Jacksons suite during that period of time?

A. Yes.
Q. Where were the other beds?
A. There was one upstairs in like -- I dont know if youd call it -- in like a loft.
Q. Was that bed ever used?
A. No.
Q. Do you have a recollection of ever changing sheets on that bed?
A. I did, you know, just to keep it kind of up, but not always.
Q. Do you have a recollection of anybody ever seeping in that bed; in other words, coming
in and discovering that those sheets had simply been used, the bed had been used?
A. Yes.
Q. How often?
A. Maybe -- maybe once.
Q. During the entire time that you were the personal maid for Mr. Jackson?
A. I believe so.
Q. All right. Did you know Wade Robesons parents, mother or father?
A. I dont ever remember meeting a father, but I remember the mother.
Q. And where did she stay when they were there?
A. In the guest unit.
Q. Did Wade Robeson have any brothers or sisters who came?
A. Not that I recall.
Q. Do you know if Wade Robesons mother ever stayed in Mr. Jacksons residence?
A. No. I recall her in the guest units.
Q. Did you see Wade Robeson in Mr. Jacksons residence?
A. Yes.
Q. Do you know who Macaulay Culkin is?
A. Yes.
Q. Who is Macaulay Culkin?
A. He was a little boy that used to come to the ranch.
Q. Do you know during what period of time Macaulay Culkin came to the ranch?
A. 1990, maybe, through maybe 93.
Q. He was there for extended periods as well?
A. Yes.
Q. And by extended periods, what do we mean?
A. Sometimes a week. Sometimes longer.
Q. Did he visit frequently during that period of time?
A. Yes.
Q. Was he ever there during the period of time that Wade Robeson was there?
A. I cant recall.
Q. Did Macaulay Culkin have brothers or sisters?
A. Yes.
Q. Do you know how many brothers or sisters he had?
A. Im thinking maybe seven or eight.
Q. It was a large family?
A. Yes.
Q. Did you ever meet his parents?
A. Yes.
Q. Would all of them come to the ranch on occasion?
A. Sometimes.

Q. Were there occasions when Macaulay Culkin came by himself?

A. Sometimes.
Q. And on those occasions when he came by himself, how long, typically, would he stay?
A. The weekend. Sometimes his parents would show up later and theyd be there maybe a
week.
Q. How old was Macaulay Culkin when he was visit ing the ranch during that period of
time?
A. Maybe 11. 10 or 11 maybe.
Q. At the earliest -- you gave us a period of time that was over two or three years. What
was the youngest age you remember seeing him, as best you can recall?
A. Maybe ten.
Q. Okay. Was Macaulay Culkin -- do you know him to be an actor?
A. Yes.
Q. Have you seen things that hes been in, movies or television?
A. Maybe one.
Q. Do you know where Macaulay Culkin stayed when he was at the ranch?
A. In Mr. Jacksons room.
Q. And as I had asked previously, do you know where in Mr. Jacksons room he stayed?
A. In his bedroom, in his bed.
Q. And how do you know that?
A. Because when I wou ld -- when I would go in the room the next day, there was just one
bed that I had to fix.
Q. Do you know if Macaulay Culkin and Wade Robesons visit would overlap on occasion,
when both would be there at the same time?
A. Can you repeat that?
Q. Im sorry?
A. Can you repeat it?
Q. If their vis its would overlap, if they would be there at the same time. Do you have a
recollection of seeing Macaulay Culkin and Wade Robeson there at the same time?
A. I could have.
Q. Do you know where Macaulay Culkins family stayed when they were at the ranch?
A. Usually at the guest units.
Q. And the guest units were a separate build ing?
A. Yes.
Q. Do you know if his brothers or sisters ever stayed overnight in Mr. Jacksons persona
residence, his personal suite?
A. Not that I know of.
Q. Who is Jordan Chandler?
A. Hes another little boy that used to come to the ranch.
Q. Do you know what period of time he used to come to the ranch?
A. Maybe 93.
Q. Was it for as long a period of time as Mr. Culkin, Macaulay Culkin came to the ranch?
A. No.
MR. MESEREAU: Objection; vague.
THE COURT: Sustained.
Q. BY MR. ZONEN: Can you tell us the period of time that Jordan Chandler vis ited at
Neverland? In other words, at what time d id it commence and at what time did it end, if at
all, during your period of employment?

A. Maybe 1993 and maybe through 94. Maybe early, maybe late -- actually, maybe late
93.
Q. Who is Brett Barnes?
A. Another boy that used to come to the ranch.
Q. How old was Brett Barnes when he visited?
A. Probably maybe 11.
Q. For what period of time did Brett Barnes come to the ranch?
A. He was there quite a lot. Mid -- maybe 1993.
Q. Do you know approximately what period of time Brett Barnes would come and visit? In
other words, over what period of time, measured in months, measured in years,
measured in weeks, from the first visit to the last?
A. I would -- Im thinking maybe 1992 through maybe 19 -- late 1993.
Q. When Brett Barnes came to the ranch, did he come with family?
A. Yes.
Q. And who in his family did he come to the ranch with?
A. With his mother and his sister.
Q. Did you ever meet Brett Barnes father?
A. I dont believe there was a father in that picture. I have never seen a father.
Q. Brett Barnes has a sister, you say, who came?
A. Yes.
Q. How old was she?
A. I would say maybe 13.
Q. How frequently did Brett Barnes come to the ranch during that period of time?
A. A lot.
Q. And by a lot, what do we mean? Would it be more than one visit a month?
A. Yes.
Q. And when he came, how long did Brett Barnes stay?
A. Sometimes -- sometimes a week. Sometimes less than a week.
Q. Where did he stay when he came?
A. In Mr. Jacksons room.
Q. Where did he sleep when he was there?
A. In Mr. Jacksons bed.
Q. Do you have a recollection at any time either fixing a bed for Brett Barnes that was
separate from Mr. Jacksons bed or cleaning up after a bed separate from Mr. Jacksons
bed?
A. No.
Q. I had asked you about Jordan Chandler. When he came to Neverland Ranch, did he
come with his family?
A. Jordan came with his mother and his little sister.
Q. Do you know how old the little sister was?
A. Maybe four.
Q. She was a small child?
A. Yes.
Q. Did you ever meet Jordan Chandlers father?
A. I never -- I never met -- I never seen his father around there. I never met him.
Q. During the visits when Jordan Chandler came, where d id his mother and sister stay?
A. In the guest unit.
Q. And where did Jordan Chandler stay?

A. In Mr. Jacksons room.

Q. Consistently?
A. Yes.
Q. Where did Jordan Chandler sleep when he was in Mr. Jacksons room?
A. In Mr. Jacksons bed.
Q. Now, do you have a recollection of these four boys being there at the same time,
Macaulay Culkin, Jordan Chandler, Brett Barnes, and Wade Robeson?
A. Um, I -- I kind of recall Brett being there with Jordie, at the same time. And, you know,
it could have been W ade also, when Brett was there.
Q. Would that have been a common occurrence?
MR. MESEREAU: Objection; vague.
THE COURT: Overruled. You may answer.
THE WITNESS: Not always.
Q. BY MR. ZONEN: Do you understand -- not always?
A. Not always.
Q. Do you have a recollection of specific events of all of them being there together or the
two or the three that you mentioned?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Overruled. You may answer.
THE WITNESS: I just recall seeing them there at the same time, Brett and Jordie.
Q. BY MR. ZONEN: Brett and Jordie?
A. Yes.
Q. Do you know how many times you saw Brett an Jordie there together?
A. At least two times.
Q. During the entire period of time that you worked as Michael Jacksons maid, personal
maid, was it a frequent occasion that there would be one of those four boys there?
A. Yes.
MR. MESEREAU: Objection; vague.
THE COURT: Overruled. The answer was, Yes. Next question.
Q. BY MR. ZONEN: Was there ever an occasion that one of those four boys was there
and did not stay in Michael Jacksons bedroom and bed?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. ZONEN: Was there ever an occasion that you personally witnessed during the
time that you worked as his personal maid when any of those four boys stayed -- and you
were on duty, where they stayed in the guesthouse and not in Mr. Jacksons bed?
A. No.
Q. As part of your obligations and responsibilit ies as the maid, did you clean up in the
bathrooms?
A. Yes.
Q. Was there a Jacuzzi in the bathroom?
A. It wasnt in -- yes, but -Q. Am I describing the room incorrectly or inaccurately?
A. Yeah, because it wasnt really attached. It was just one room where the Jacuzzi was,
and off to the side there was a bathroom and a shower.
MR. ZONEN: Just one second.
Q. During the period of time that you were working as Mr. Jacksons personal maid, did
you ever see behavior by Mr. Jackson toward any of these boys that concerned you?

MR. MESEREAU: Objection; vague.

THE COURT: Overruled. You may answer.
THE WITNESS: Yes.
Q. BY MR. ZONEN: And which of the four boys are we talking about?
A. Macaulay Culkin, Brett Barnes and Jordie Chandler.
Q. All right. Lets begin with Macaulay Culkin. W hat is it that you saw that concerned you?
A. I was coming out of the bathroom by his bedroom, by Mr. Jacksons bedroom. I was
cleaning that bathroom. And when I came out, I saw Mr. Jackson and Macaulay in the
library, and Mr. Jackson was kissing him on his cheek, and he had his hand kind of by his
leg, kind of on his rear end.
Q. Did they know that you were there?
A. I dont know -MR. MESEREAU: Objection; calls for speculation.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you announce your presence to them?
A. No.
Q. Where were you at the time you witnessed this?
A. I was coming out of the bathroom by Mr. Jacksons bedroom.
Q. All right. Is that on the first floor?
A. Yes.
Q. Is that where you were?
A. Yes.
Q. Were they on the first floor as well?
A. Yes.
Q. Did you -- did you note that they were in the room or had come into the room?
A. No.
Q. Were you surprised to see them?
A. Yes.
Q. Had you been cleaning in that room?
A. In the bathroom?
Q. Yes
A. Yes.
Q. How did you come upon them? How did that happen?
A. I was leaving the bathroom, and when I walked out of the bathroom, I looked up and I
saw.
Q. How far away from you were they?
A. I dont know the feet. It was a little d istance.
Q. Between the distance that you and I are at this moment?
A. Maybe a little further.
Q. All right. Lets say to the back rail over here, behind me?
A. Probably a little further. Maybe a little further.
Q. Second or third row?
A. Maybe second row.
MR. ZONEN: Okay. And for the record, could we say thats 30 feet, 25? The second row?
THE COURT: Im not testifying. (Laughter.)
Q. BY MR. ZONEN: How far do you think that is in feet? Do you have any way of
knowing?
A. No.

Q. All right. You did not hear them come into the room?
A. No.
Q. When you got to the position where you saw them, were either of them looking at you?
A. No.
Q. Were either of them facing you?
A. No.
Q. And you testified that you saw Michael Jackson kissing Macaulay Culkin?
MR. MESEREAU: Objection; asked and answered.
THE WITNESS: Yes.
THE COURT: Just a moment.
THE WITNESS: Oh, Im sorry.
THE COURT: The objection is sustained.
Q. BY MR. ZONEN: Where did he kiss him?
A. On the cheek.
Q. And where did he touch him?
A. Kind of like by his leg, and it went to his rear end.
Q. And how long did that last?
A. I dont know how long. I just walked off.
Q. And you say you walked off.
A. Yes.
Q. Walked off where?
A. I went to the laundry room.
Q. All right. Were you in a position where you could do that without being seen?
A. I believe so.
Q. All right. Did you leave the -- literally leave the suite?
A. I was in the rest room and I left the rest room.
Q. Okay. Now, can you describe that for us, how you could do that without necessarily
being seen or detected in his room? You didnt have to walk by them or anything?
A. No. They were at a distance, so I just walked through the hall.
Q. Did Mr. Jackson ever mention to you anything about that?
A. No.
Q. Did you ever mention anything to him about that?
A. No.
Q. Was that the first thing that you had seen in terms of behavior toward a child that
caused you concern?
A. Yes.
Q. Did you see any other incidents that caused you concern in terms of Mr. Macaulay
Culkin?
A. No.
Q. What was the next thing that you saw that caused you concern?
A. Brett Barnes.
Q. And what did you see?
A. Well, I was up in the video room, and Mr. Jackson had me taking videos out of the wall.
There was -- the room was a video room. It was actually a soldier room. And he had me
taking all of the videos out of the wall, and there was like -- I dont know what you call
them, like wood things that would hold the videos, and they had, like, screws in the wall.
So I was pulling those all out because he had heard that you could see down into his
bedroom.

MR. MESEREAU: Objection; nonresponsive.

THE COURT: Sustained.
MR. MESEREAU: Move to strike.
THE WITNESS: So -THE COURT: Just a moment. Ill strike from the point where she said, So I was pulling
those out.
Q. BY MR. ZONEN: All right. Why -- what were you pulling out from the walls?
A. Videotapes.
Q. Why were you doing that?
A. Because Mr. Jackson had heard that you could see down into his bedroom. There was
like a little cubbyhole in the back of the walls up in that room, so he wanted to see if you
could see down into his bedroom.
Q. So did you, in fact, remove videotapes?
A. Yes.
Q. Could you see down into the bedroom?
A. Yes.
Q. Did you show him that, or did he see that with you?
A. He was in his room, and where I was at was above his room, so he came up with Brett
Barnes to that room.
Q. He came up to the room?
A. Up to the video room with Brett Barnes.
Q. While you were there?
A. Yes.
Q. All right. And did you show him that spot while he was there?
A. Yes.
Q. All right. Now, when d id you see him doing something with Brett Barnes?
A. After that?
Q. Yes. Was it right after that?
A. It was kind of right after that, yeah.
Q. And where was he?
A. They were walking back down the stairs, and they went down through the hall by his
bedroom, and I kind of followed because it was very hot up there in that room. And I was
on the landing after you get on the stairs, and I kind of looked over the landing, and he
was walking away with Brett to his room, and I saw him put his hand on Bretts rear end,
and he gave Brett a kiss on the cheek.
Q. In like fashion to what you described you had seen with Macaulay Culkin?
A. Yes.
Q. All right. Which of those incid ents took place first, Macaulay Culkin or Brett Barnes?
A. Macaulay Culkin.
Q. How far away from them were you at that time? How far away from them? How far
away?
A. With Brett?
Q. Yes.
A. Oh, gosh, not that far. Maybe from where Im at to maybe the third row back.
Q. Okay. Im done estimating distances, so well leave it at that. All right. Is that the only
incident that you saw with Brett Barnes?
A. Yes.
Q. Did you see an incident with anybody else?

A. With Jordan Chandler.

Q. And when was that?
A. Asking about the year?
Q. Relat ive to the incident that you saw with Brett Barnes.
A. God, I cant even think of the year. Probably 93.
Q. Was it toward the end of your employment there?
A. Maybe -- maybe -- a little, maybe.
Q. And what did you see?
A. I was up in Mr. Jacksons bedroom and I was -- I was on the second -- the loft area,
and I was dusting. And I heard the chimes go off, so I knew somebody was coming into
the bedroom.
Q. What does that mean, you heard the chimes go off? Where were there chimes?
A. Theres like a sensor, like it rings. Theyre bells that ring when anybodys coming into
Mr. Jacksons room, or if you leave the room, the chimes will go off.
Q. And when they go off, how long do they ring?
A. Until -Q. If you walk through it, it will ring for how long?
A. For a while. For a little while, until I guess people are out of the area where youre
seen.
Q. So once you clear, does it stop?
A. It will stop after, yeah.
Q. And the chimes going off meant what to you?
A. That somebody was coming into the room.
Q. All right. Was that an unusual occurrence while you were cleaning?
A. What, the chimes going off?
Q. Yes. Somebody coming into the room. If you were cleaning there during the day, would
that startle you if that happened?
A. No.
Q. What did you do?
A. Well, I was upstairs, and I -- I heard talking, like voices. So I knew it was probably
Michael and Jordie.
Q. Now, upstairs means -- theres a second bed up there?
A. Yes.
Q. Like a loft you said?
A. A loft, uh-huh.
Q. Were you cleaning at that time?
A. Yes.
Q. Okay. Do you know if the bedroom door was open when you heard the chimes?
A. I believe so.
Q. And what happened then?
A. I kind of looked down from the stairs, from the stairs up there a little, and I saw Mr.
Jackson with Jordie, and they were changing their clothes. Like -- I figured they were at
the water fort. And I looked down and I saw Mr. Jackson kissing on -- on Jordie.
Q. What part?
A. His cheek, and then his mouth, and his hand was on his crotch.
Q. What was Jordie wearing at the time?
A. He had pants on.
Q. How long did that last?

A. I -- when I saw that, I was quiet, and I cant even say how long that lasted.
Q. What did you do?
A. I was kind of shocked, flushed, and I stood quiet where I was at.
Q. You didnt say anything?
A. I didnt say nothing.
Q. For you to go and leave that room where the loft is, you would have to walk down the
stairs, would you not?
A. Yes.
Q. Would you have had to have walked past them?
A. Yes.
Q. All right. What did you do?
A. I stayed up there very quietly, I didnt say anything. I stood very quietly. And I waited
for them to leave the room.
Q. And did they leave the room?
A. Yes.
Q. How was Jordie Chandler dressed at the time?
A. I just remember he had pants on, and they were changing shirts. He had pants on and
so did Mr. Jackson.
Q. And when you said his hand was on Jordie Chandlers crotch, on the outside of the
pants or on the inside of the pants?
A. On the outside.
Q. Was he kissing him the entire time that you were watching?
A. From what I saw, yes.
Q. Where exactly were you at the time that you heard the chimes?
A. Upstairs in the top loft.
Q. And do you know where in that room?
A. Kind of by the stairs. By the stairs. I was dusting the stairs.
Q. So right at the top landing?
A. Yes.
Q. Did you stay up there until Jordie Chandler and Mr. Jackson left the room?
A. Yes.
Q. Did you then go downstairs?
A. Yes. After I heard the chimes go off, I knew they had left, and I waited and then I left.
Q. How long after this happened did you leave your emp loyment with Michael Jackson?
A. Well, I left July. I dont know, like, the months. I know I left July 31st of 94.
Q. Did you ever see any incidents involving Wade Robeson? You told us about Brett
Barnes, and Jordan Chandler, and Macaulay Culkin. Did you ever see an incid ent involving
Wade Robeson?
A. No.
Q. I started to ask you a bit ago about the Jacuzzi. Theres a Jacuzzi thats located in the
master bedroom suite. Describe for us where that is.
A. When you go into Mr. Jacksons room, right when you go down the steps, theres steps
in his room, theres a rest room like on that side, like right-hand side, where if you go
around his bed, theres another area where theres another rest room, and theres a
Jacuzzi.
Q. How large?
A. Oh, God, its big. Its big.
Q. Would it hold more than one person?

A. Yes.
Q. Comfortably?
A. Yes.
Q. Was water kept in that Jacuzzi all the time?
A. No.
Q. What were your responsibilit ies with regard to cleaning the Jacuzzi?
A. I would have to clean the Jacuzzi off and on, run the water in it. But there were times
when I had to let the water out of the Jacuzzi.
Q. All right. And were there things in the Jacuzzi on occasion?
A. Yes.
Q. Like what?
A. Like Mr. Jacksons undershorts, and a little boys undershorts.
Q. Do you know which boys had been staying there during that time?
A. A lot of the little boys were staying there at that time.
Q. You wouldnt know which boys it was, the undershorts?
A. Brett -- it could -- Brett. Jordie. Macaulay. That happened frequently.
Q. Theyd actually be in the Jacuzzi in the water?
A. Theyd be in the water, or sometimes theyd be on the floor by the Jacuzzi.
Q. And these were underpants?
A. Yes.
Q. And you could tell the difference between the boys underpants and Mr. Jacksons
underpants?
A. Yes.
Q. Did you have to clean them?
A. Yes, I washed them.
Q. Did you, on occasion, wash the childrens underwear as well?
A. At times, yes.
Q. If it was left behind?
A. Yes.
Q. Youd pick it up and wash it?
A. Yes.
Q. These four boys during the time that they were staying at Neverland, how did their
behavior -- how was their behavior?
MR. MESEREAU: Objection; vague.
MR. ZONEN: As to behavior or as to boys? Ill object to the objection as vague. Or Ill
reask the question.
THE COURT: Well, its compound, I think.
MR. ZONEN: Ill reask the question.
THE COURT: All right.
Q. BY MR. ZONEN: During the period of time that you were working as Mr. Jacksons
personal maid, did you have an opportunity to observe the behavior of the children who
were frequent visitors at Neverland Ranch?
A. Yes.
Q. And did that include the four boys that were talking about so far?
A. Yes.
Q. Did it include other children who were frequent visitors at Neverland Ranch?
A. Yes.

Q. All right. And Im not asking you questions about busloads of kids who would arrive for
a day and leave at the end of the day. Im asking about the ones who were Mr. Jacksons
personal guests and who stayed for periods of time. Do you understand that?
A. Yes.
Q. All right. Was there anything about that behavior that was unique, in your mind?
MR. MESEREAU: Objection. Vague; relevance; and lead ing.
THE COURT: The thing Im having a problem with is not the vague, but the fact that
youre asking about all of the boys as oppose -- as to their behavior.
MR. ZONEN: Ill make that eas ier.
Q. Macaulay Culkin, what was his behavior like when he was at Neverland Ranch?
A. He was very, very wild.
Q. Describe what you mean by that.
A. For us maids?
Q. Yes.
A. He was a lot of work when he -- when he was around there.
Q. What does that mean, a lot of work?
A. He was destructive. I mean, throwing popcorn at Mr. Jackson. Soda, from the top,
being thrown at Mr. Jacksons head.
Q. The top of what?
A. At the top of the theater. Like a projection room way up on the top.
Q. Did you actually witness that?
A. Yes.
Q. So theres apparently two stories at the theater?
A. Yes.
Q. And is the upper story open in such a way that you can actually have contact with
somebody below you?
A. Yes. They will -- yes.
Q. Open in what way?
A. There were windows up in the top-top. I dont know if you call it a -- I dont know if it
was called maybe a viewing room. And if you were up there, you had to take a stairway to
get up to the top, and you could open these windows.
Q. What did you see him do?
A. He threw sodas. I had just made popcorn, because he asked for popcorn, and he
wanted a soda. So I gave it to him. And he went upstairs, and he dumped it on Mr.
Jacksons head, along with the popcorn.
Q. All right. Did that create a mess?
A. Yes.
Q. Mess for you to clean up?
A. Yes.
Q. Was that a unique event with regard to Mr. Macaulay Culkin?
A. Was it unique?
Q. Well, were you always cleaning up after him?
A. Yeah, but certain kids made it worse. And he was one of them.
Q. All right. Which other kids were a problem?
A. Jordie Chandler.
Q. What did Jordie do?
A. Um -Q. Before I get to Jordie Chandler, let me ask you another incident about the popcorn and

the soda. What did Mr. Jackson say to Macaulay Cu lkin when he poured popcorn and soda
from the second story on top of him?
MR. MESEREAU: Objection; foundation.
THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Go ahead.
A. It was like a joke. It was funny.
Q. He didnt discip line him?
A. No.
Q. He didnt tell him, Thats inappropriate?
A. No.
Q. Nor did he help you clean up, I assume.
A. No.
Q. And Jordie Chandler, describe his behavior for us during the time that he was there.
A. He was rude.
Q. In what way?
A. Very demanding.
Q. In what way demanding?
A. Like if I was in the laundry room washing clothes, hed come and say, Wheres my
shirt? You know, I want my shirt. Just not nice to where you ask, Do you have my
shirt? Just kind of Give it to me now, like that.
Q. Was his behavior like that fairly consistently during the entire time that you were
exposed to him?
A. Yes.
Q. Brett Barnes, how did he behave?
A. That little boy, I -- he was not a rude little boy. He was pretty well-behaved.
Q. The entire time?
A. Yes.
Q. Wade Robeson, how did he behave?
A. He was kind of wild, too. Not as much as Macaulay. Just wild, tear everything up. Leave
messes all over, you know. Just -Q. Were you ever encouraged to discipline these kids in any way?
A. No.
Q. Were you discouraged from doing so?
A. Yes.
Q. In what way?
A. Well, I was told by Norma Stakos that -MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Her state of mind to explain her behavior.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you ever go up to any child and say, Dont do that. Thats
inappropriate?
A. No.
Q. Did you ever see any employee or hear of any employee go up to a child and say,
Dont do that. Thats inappropriate?
A. No.
Q. Other than Brett Barnes, was the behavior of the three children that you described
consistently bad the entire time they were there?
A. Yes.

Q. Did that include t imes when they were in the presence of Michael Jackson?
A. Yes.
Q. Did you ever hear Michael Jackson discipline them in any way or tell them not to
behave in such a destructive fashion?
A. No.
Q. Did you tell anybody about the events that you saw, the three incidents that you
testified to involving those three children, Brett Barnes, Macaulay Culkin and Jordie
Chandler?
A. Yes.
Q. Who was the first person you discussed that with?
A. Lawyers I had. Lawyers.
Q. The lawyer who was representing you?
A. Yes.
Q. Which lawyer was that?
A. Michael R ing.
Q. Had you told anybody about those events prior to that?
A. I believe I talked to Kiki Fournier. I didnt even know -- I think it might have been after
I -- it might have been after I had left.
Q. Now, you worked there, I believe you said, about four years; is that correct?
A. Yes.
Q. All right. Why did you leave there?
MR. MESEREAU: Objection; relevance.
THE COURT: Overruled. You may answer.
THE WITNESS: When Mr. Jackson had that Jordie Chandler mo lestation case, whatever,
bodyguards were brought -- brought to the ranch. They werent the regular security
people. These people were called OSS, Office of Special Services. And there were a lot of
these guys, and they started harassing -MR. MESEREAU: Objection. Narrative; nonresponsive.
THE COURT: Sustained.
Q. BY MR. ZONEN: Well, OSS stands for Office of what?
A. Of Special Services.
Q. All right. Who were these people? Do you know their names?
A. There was one, Jimmy Van Norman. Tony Coleman. Marcus Johnson. Jerome Johnson.
Q. Were these people armed with weapons?
A. Yes. Yes.
Q. And they came to the ranch after the commencement of the Jordan Chandler
investigat ion?
A. Yes.
Q. Did you know when the Jordan Chandler investigation began?
A. Yes.
Q. Was there a search that was conducted at Neverland by Los Angeles Police
Department?
A. Yes.
Q. Were you present at the time that happened?
A. I -- yes, but I -- yes, but I had called in sick that day and I had to go back to the
ranch.
Q. You had called in sick that day?
A. I was sick on that day.

Q. By coincidence, or you knew there was going to be a search?

A. No, I didnt know. I did not know. I just was sick and I called in sick.
Q. And had anybody heard of anything in advance of that search?
A. No.
Q. There had been no talk about that at all?
A. No.
Q. Fair to say there was probably considerable talk thereafter?
A. Yes.
Q. Were you interviewed by anybody from law enforcement during this investigation?
A. Um -Q. I think the question that I asked was, had you been interviewed by anybody from law
enforcement during the course of that investigation?
A. I believe so.
Q. All right. Did you become aware of the fact that there had been a lawsuit filed on behalf
of Jordan Chandler?
A. Yes.
Q. Were you called to testify in a deposition?
A. Yes.
Q. And did you, in fact, give a deposition to attorneys representing both Mr. Jackson and
Mr. Chandler?
A. Yes.
Q. Do you remember who those attorneys were?
A. Larry Feldman, Howard Weitzman, and some lady named, I think, Jan Faye or -Q. Were you still employed at Neverland during that time?
A. Yes.
Q. During the course of that deposition, were you asked if you observed any behavior by
Michael Jackson directed toward Jordie Chandler or anybody else that you thought was
inappropriate or any form of sexual behavior?
A. Yes.
Q. How did you answer that question?
A. I didnt tell the truth.
Q. What did you say?
A. I said I didnt see anything.
Q. All right. Why did you say that in this deposition?
A. Because when -- when I had taken over the job for Mr. Jacksons room, Mr. Jackson
had threatened me.
Q. What did he say to you?
A. He had told me, You know, Adrian, if you ever say or you do something that I dont
like, all I have to do is tell Bill Bray or Norma Stakos, and they will take care of you, but it
wouldnt come from me.
Q. Were you concerned about that statement?
A. I was very concerned with that.
Q. That was what, three years earlier?
A. That was right when I took the bedroom.
Q. Why did you continue to work there after that statement?
A. I dont know. I -- I got caught up, I guess, in -- my husband was laid off, and we had a
house payment, and I just stayed.
Q. What was your salary at Neverland?

A. I worked 40 hours a week, but I started at 7.50 an hour.

Q. What was your salary at the time that you left Neverland?
A. I left at 8.86 an hour.
Q. In the four years, your salary went up $1.80 an hour?
A. Yes.
Q. What hours did you maintain at Neverland? What was your schedule?
A. Sometimes 8:30 to 5:00. Sometimes 8:30 till one oclock in the morning. You never
knew, kind of, when you were going to go home.
Q. Every day you went to Neverland, you didnt know if you would go home at 5:00?
A. Right.
Q. How often was it that you were asked to stay after 5:00?
A. There were a lot of times.
Q. In a week period, how many days in that week would you expect to stay after 5:00?
A. You just never knew. It depended if there were guests. Sometimes it could have been
two times. Three times. You just didnt know when you were going to go home.
Q. And you could stay actually until the early morning?
A. Yes.
Q. And then come back the next day at 9:00?
A. Yes.
Q. Were you ever asked to work weekends?
A. Yes.
Q. If you were asked to work on an evening or on a weekend, and you didnt want to,
would you just simply say, I cant do that tonight?
A. No.
Q. Why?
A. Because you were scheduled and you had to show up.
Q. Now, you started talking about OCC -- OSS.
A little dyslexia here, excuse me. OSS. And you named the people who were involved in
OSS; is that right?
A. Yes.
Q. Up until that time, had there been people armed at Neverland?
A. No.
Q. Were each of those people armed with weapons?
A. I believe so.
Q. How was their behavior toward you?
A. They were terrib le.
Q. How did they behave toward you? What did they do?
A. Jimmy Van Norman would -MR. MESEREAU: Objection; vague as to time and individuals.
Q. BY MR. ZONEN: Lets begin with Jimmy, then. Ill withdraw the question. Ask you
specifically about Jimmy Van Norman. A ll right. And from the time that he came on
working until the time you quit was approximately how many months?
A. I would say maybe six or seven months, maybe.
Q. During that time, was his behavior toward you fairly consistent?
A. Yes.
Q. And describe things he would do to you, or with you.
A. He called my home one morning when I was still kind of asleep, and he woke me up
with a phone call. And I was going to take my son to school that day. It was a Monday, I

remember. And he said, Adrian -MR. MESEREAU: Objection; hearsay.

MR. ZONEN: Goes to her state of mind and explaining her conduct.
THE COURT: The state of mind being why she left?
MR. ZONEN: And commenced a lawsuit.
THE COURT: All right. Ill overrule the objection.
Q. BY MR. ZONEN: All right. What happened in this call?
A. He called my home early in the morning, and he said, Adrian? And I said, Yes? And
he says, You sound different. And I said, Well, I just woke up You know, I hadnt had
coffee. My voice was a little bit rough. And he says something about what kind of
underwear I wear, and when was the last time I got it; that apparently I needed it.
Q. Did you recognize the voice when he called?
A. Yes, I did.
Q. Did he have to identify himself?
A. No, he didnt. But I knew it was him.
Q. What did you do when you said that?
A. I changed the subject, because I thought maybe Mr. Jackson needed something and
maybe he was just calling to -- to get Mr. Jackson to talk to me or something. I didnt
know.
Q. Did he ult imately communicate a message to you from Mr. Jackson?
A. Sometimes -- not him, but sometimes the other ones would.
Q. But on that occasion, that particular call, did he ultimately communicate a
commun icat ion from Mr. Jackson?
A. No, he didnt.
Q. Did he ever tell you why he was calling?
A. No.
Q. Okay. Did you hang up that phone call?
A. Actually, he got another call, and the phone was ringing in the back, which I knew was
a Merlin phone, because I knew the sounds of the phones, and he said, Darn, Ill call you
right back.
Q. Did he call you right back?
A. He didnt call back.
Q. Had you received more than that one phone call from this person, Van Norman?
A. I did receive another call later, and I -- and I dont know the month. Right now I cant
think of the month. And it was Jimmy, and he -MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Same reason.
THE COURT: Well, you know, Im not getting to her state of mind either. All of that
testimony I let in for her state of mind I let in at your request for her state of mind.
MR. ZONEN: Let me withdraw the last question and let me move on.
THE COURT: I need an offer as to why Ive let other testimony in.
MR. ZONEN: Let me withdraw that question right now and move on.
Q. Did you quit your job at Neverland?
A. Yes, I did quit.
Q. Why did you quit?
A. Because I was being sexually harassed. I had death threats. I was being chased in the
house with a stun gun. More like abuse. And mentally I could not deal with it.
Q. Was this all the new collect ion of guards that had been brought in?

A. Yes.
Q. Did you ever talk with Mr. Jackson about what was going on?
A. I dont believe so, with that.
Q. And why not?
A. I believe he left. He had left later, maybe in February. And Marcus Johnson left with
him with the bodyguards, but there was still bodyguards around, so Mr. Jackson wasnt
really around where you could tell him, so -Q. What made you decide to file a lawsuit against Mr. Jackson?
A. When I realized that I didnt have to work in a job where I was being sexually
harassed, and abused, and having to deal with death threats and -Q. Did you talk with Mr. -- who was your attorney? Who represented you?
A. Actually, we had Michael Gray and Michael Barber, and we had Michael R ing and Kelly
Frances.
Q. All from the same firm?
A. At the time, yes.
Q. Who was the lead attorney in that case?
A. Michael Barber. And Michael R ing (sic) ended up, I guess, getting out of it. I dont know
what happened there, but Michael Ring ended up taking over.
Q. Michael R ing?
A. Michael R ing.
Q. Was he the one who tried the case?
A. Yes.
Q. That case went on for quite some number of months, didnt it?
A. Yes, it did.
Q. Did you quit your job before or after seeking counsel from Michael R ing or any other
lawyer?
A. I believe I quit my job first while I went out on doctors care.
Q. You were not the only plaintiff in that suit, were you?
A. No.
Q. Who were the other plaintiffs?
A. There was Melanie Bagnall, Kassim Abdool, Sandie Domz, and Ralph Chacon.
Q. Was there a counterclaim that was filed against you? Were you accused of anything?
A. Yes.
Q. What were you accused of?
A. I believe of -- of, I think, taking Super Soaker water guns. Taking candy, balloons,
posters, sunglasses.
Q. Were you accused of taking a drawing?
A. Yes.
Q. All right. Tell us about the drawing.
A. The drawing, actually, I had found it in the trash outside by the rec room. It was a
trash area there. And I had taken trash out from the house, from the kitchen, and I saw it
in there. There was a bag out there, and it was just open and it was a sketch. It wasnt a
big sketch. It was a small sketch.
Q. About how big?
A. Oh, gosh. Probably -- I dont even know. Maybe about that big. Maybe like that. It
wasnt very big.
Q. Six inches by five inches -A. Yeah.

Q. -- something like that?

MR. MESEREAU: Objection; leading.
THE WITNESS: Yeah, something like that.
THE COURT: Sustained.
Q. BY MR. ZONEN: Can you give us an estimate on the record, the size of it? Because
you were holding your hands out.
A. Maybe three-by-five. I dont know. Something like that.
Q. All right. You said you found it in the trash?
A. Yes.
Q. Where?
A. Outside. Outside by the rec room. There was a trash area back there.
Q. Did you know who did the drawing?
A. I didnt know who did it, but I thought -- well, maybe. I was really -- I dont know who
did it.
Q. Who did you believe did it?
A. Um -MR. MESEREAU: Objection; calls for speculation.
MR. ZONEN: Explains why she took it.
THE COURT: Actually, you know, were having the same problem that when Mr. Mesereau
was asking questions. You seem to be going into the allegations in the Complaint, which -the facts of the lawsuit, which Ive said we cant do. So Im going to ask you to go into a
different area.
MR. ZONEN: All right.
Q. After many months in trial, was there a resolution to that case?
A. Yes.
Q. What happened?
A. We lost.
Q. Each of you?
A. Yes.
Q. As to all counts?
A. Yes.
Q. Was there a judgment against you?
A. Yes.
Q. For a great deal of money?
A. Yes.
Q. How much?
A. 1.6 million.
Q. Did you go into bankruptcy afterward?
A. No.
Q. So that debt still exists today?
A. Yes.
Q. You owe Mr. Jackson $1.6 million?
A. Yes.
Q. Is that for all the attorneys fees and the court costs?
A. Yes.
Q. Have you paid any part of that?
A. A lien was put on my paycheck when I was working at Sears and there was money

taken out, but I dont recall how much.

Q. Okay. Is there a lien currently on your paycheck where you currently work?
A. For the lawsuit?
Q. For this lawsuit.
A. No.
Q. Do you anticipate that will happen?
A. I dont -MR. MESEREAU: Objection. Calls for speculation; relevance.
THE COURT: Sustained.
Q. BY MR. ZONEN: Are you concerned that that will happen?
MR. MESEREAU: Same objection.
THE COURT: Sustained.
Q. BY MR. ZONEN: Had there been a deposition that was taken of you prior to the
commencement of that lawsuit?
A. Do you mean like before, with Jordie Chandler?
Q. Yes.
A. Yes.
Q. In the course of that deposition, did you disclose the events that took place that youve
disclosed to this jury?
A. No, I did not.
Q. Are you talking about the Jordie Chandler lawsuit, deposition?
A. Yes.
Q. Was there a subsequent -- another deposition that was done in the lawsuit of your
case, Kassim Abdool and everyone else against Michael Jackson and everyone else?
A. Yes.
Q. In that deposition, did you disclose what you saw?
A. Yes, I did.
Q. At some point during the course of that lawsuit, either before the commencement of
trial or during, were you involved with others in selling a story to a tabloid?
A. Yes.
Q. Which tabloid was it?
A. Actually, there was a man named Gary Morgan, and he was from Splash.
Q. What is Splash? A. I dont know -- I dont know if hes affiliated with different -- Im not
even really sure. I just know that he sold stuff.
Q. But it was a tabloid?
A. I believe so.
Q. Did you actually have an interview with them?
A. Yes.
Q. Did they give you money?
A. Me personally?
Q. Yes.
A. They were -- well, can I explain, because I dont -Q. Who did the interview? In other words, how many of the plaintiffs involved that youve
identified did this interview?
A. Everybody was there, including our attorney.
Q. Did he participate in the interview as well, your attorney?
A. He was there with -- yeah.
Q. Who is it who negotiated what would be paid?

A. I believe Michael R ing.

Q. Did you have any say in that at all?
A. No, I didnt.
Q. Was it understood that some of the money would be going to you, or all of the money?
A. From what I recall, all of the money went into a trust in Michael R ings name in order to
fight the lawsuit against Mr. Jackson.
Q. Did any of that money actually go to you?
A. At one time, yes.
Q. And how much was that?
A. A thousand dollars.
Q. Do you know how much money in total was turned over to Michael Ring?
A. I would honestly -- I mean, my best recollection, Id say probably maybe 32,000 or
more.
Q. And did that go to finance the lawsuit?
A. Yes.
Q. Were you involved in another lawsuit at that time or prior to that time?
A. Yes.
Q. What was that?
A. Well, it had to do with my husbands sister-in-law.
Q. And what happened?
A. My husband was -- my husband had two half brothers. They had different fathers. And
one of the half brothers was real close with my husband, and he ended up diabetic and he
lost his eyes and his kidneys and they had him on dialysis. He went blind. And he was
married, and his wife and him, I guess they had a very -- a relat ionship that wasnt very
good. From what I understand, she started fooling around with a radio talk show guy, and
she got pregnant -Q. Tell us what happened with regard to the lawsuit.
A. Im sorry.
Q. Who was suing who?
THE COURT: How many lawsuits are we going to cover? (Laughter.)
THE WITNESS: Im sorry. We got sued.
Q. BY MR. ZONEN: Okay. For what? The resolution of his estate?
A. Actually, my husband was left as a beneficiary, and my husband got kind of fed up with
her. And that was a family thing on their side of the family. And I kind of just got drug
into it, but -Q. Did you have counsel representing you in this lawsuit?
A. No, we didnt.
Q. Was it a jury trial?
A. No.
Q. Was it a court trial?
A. Yes.
Q. You were representing yourself?
A. Yes.
Q. Was the other side represented by counsel?
A. Yes.
Q. Was there a judgment entered against you or your husband?
A. I believe 17,000 from each one of us.
Q. Was this from money from the estate?

A. Yes.
Q. Did you pay that?
A. I mad e payments, and I dont even recall how much I made payments for. And then I
couldnt do it no longer.
Q. All right. Did you lose your home in this process?
A. No. We sold our home.
Q. And are renting today?
A. Yes.
Q. Do you know anybody in the Arvizo family? Do you know that name?
A. No.
Q. Do you know a Janet Arvizo?
A. No.
Q. Gavin Arvizo?
A. No.
Q. Star Arvizo?
A. No.
Q. Davellin Arvizo?
A. No.
Q. I had asked you earlier about a drawing. Was that drawing sold to someone during the
course of your litigat ion?
A. Yes.
Q. And who was it sold to?
A. Well, actually, at Michael R ings office, our attorney, Gary Morgan had asked if we had
any photographs or pictures or something, and I said, Well, you know, theres a sketch
that I found, I found in the trash. I told him, You can have it. It was just a sketch. It
wasnt a -- it wasnt a Polaroid, you know, it was just ink. And I gave it to him. And I
guess he went and sold it.
Q. Who sold it?
A. Gary Morgan.
Q. And Gary Morgan is who?
A. Hes from Splash.
Q. Did you get any money for that?
A. Actually, I think that when -- I believe thats where that thousand dollars might have
come from.
Q. From the sale of that picture?
A. I think so.
Q. Did you represent that as a drawing that had been done by Michael Jackson?
A. I believe I might have said it, that I thought it was done by Michael Jackson.
Q. Did you believe it was?
A. I did.
Q. Why did you have it in the first place? Why did you take it?
A. Because I found it in the trash and I figured it was in the trash, so if somethings in the
trash, I mean, somebody might not have wanted it.
Q. Did you take it because you believed he did it or did you take it because you liked it?
A. I took it because I liked it, because I liked to draw and I thought it was pretty neat.
Q. Id like to show you a few exhibits, if I may. Counsel, youve seen these.
MR. MESEREAU: Yeah.
Q. BY MR. ZONEN: Id like to show you Exhibit 797 and 798. What are those two exhibits,

797 and 798?

A. Theyre -- theyre -- its an exhibit of a note that Mr. Jackson had given me on an index
card, along with $300.
Q. Okay. Those are the two exhibits. One is the note and the other is what?
A. The $300.
Q. Its not actually $300 you have in front of you, is it?
A. Half.
Q. Well, its a Xerox or a photocopy; is that right?
A. Right, a Xerox copy.
Q. Explain what that is. Where did that money come from?
A. Well, I have to tell a story in order for that to -Q. Let me ask you a question and see if I can lead you in that direction. W ho gave you the
$300?
A. Mr. Jackson.
Q. When did he give you that $300?
A. After he had read my transcript from the Jordie Chandler deposition.
Q. All right. How did he happen to have your transcript from the Jordie Chandler
deposition?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you give him that transcript?
A. Yes, because he called me at home and asked me -MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: Ill strike after, Yes.
Q. BY MR. ZONEN: All right. Did you have a conversation with Mr. Jackson about your
testimony during the Jordie Chandler deposition?
A. Yes, I did.
Q. And that was the deposition you previously told us wherein you denied that anything
had happened that you had seen; is that correct?
A. Thats correct.
Q. All right. In the course of that conversation with Mr. Jackson, did he ask you if you had
a copy of that transcript?
A. Yes, he did.
Q. Did he ask to see it?
A. Yes, he did.
Q. Did you give it to him?
A. Yes. Yes, I did.
Q. When did you give it to him? How long after that telephone conversation was it that
you gave it to him?
A. I believe it might have been the next day.
Q. And how did you happen to have a copy of the transcript?
A. I had gotten it earlier than usual, than the usual wait for a transcript, and I believe I -I believe I had called Jan, I think her name was Jan Faye, and then they had sent it to
me, but I got it earlier than you would wait for a deposition.
Q. Had you already read that transcript before you gave it to Mr. Jackson?
A. Maybe parts of it.
Q. What was your next conversation with Mr. Jackson?
A. Are you talking about, like, on the phone or --

Q. Well, did you have a follow-up conversation about that transcript?

A. Yeah. He told me that he had read it.
Q. Did he give it back to you, the transcript?
A. Actually, I got it back. I told him I was going to take it.
Q. Did he give you anything?
A. Yes, he did.
Q. What did he give you?
A. The $300 and the little note.
Q. And the note says what?
A. It said, Adrian, thanx for everything.
Q. And the $300 were in what denominations?
A. In 100-dollar bills.
Q. Did you see anything unique about the hundred-dollar b ills?
A. Yes, I did.
Q. What was that?
A. The serial numbers were all, like, in sequence, which was really neat, because I had
never seen anything like that, and I thought that was really neat.
Q. How did you happen to have a Xerox copy of them or a photocopy?
A. Because -- I thought it was so neat that I photocopied it, because I had never seen
anything like that, you know, the sequence of bills like that.
Q. Did you keep the money?
A. Actually, when -- when he gave it to me, I called him up at the theater, he was in the
theater, and I told him I d idnt want the money. And he asked me why. And I said, I just
-- I dont want the money.
Q. He didnt give you the money in person?
A. He gave me the money, but it was in an index card and it was folded.
Q. Okay.
A. And he told me to read it, to open it. It was in his bedroom. He handed it to me in his
room. And I didnt open it right away, because I was cleaning. And he kept saying, Open
it, open it, open it. And I opened it after he left the room, and I saw the $300 and the
note was all attached.
Q. And then you called him?
A. And I called them. He went to the theater and I called him.
Q. All right. What did you say to him?
A. And I told him, I cant take that money. And he said, Why? And I said, I just cant
take it. And he said -- he kept asking, Why? And then he said, Well, then give it to
your son.
Q. Did you do so?
A. I ended up giving my son some of the money, yeah.
Q. Did you keep the balance of it?
A. I kept some money. I dont even recall how much.
Q. The Xeroxes that youre looking at, the one of the note itself, does that accurately
reproduce the note?
A. Yes.
Q. All right. Now, the other one that shows the three hundred-dollar b ills, can you tell us
why it only shows half of the $100 bills?
A. I dont understand the question.
Q. Well, as you look at that exhibit, do you see that only half of each $100 bill is depicted

in that Xerox or that photocopy? Am I right?

A. Yeah, youre right.
Q. And tell me why that is. Tell me why the Xerox doesnt show the entire $100 bill.
MR. MESEREAU: Objection; foundation.
MR. ZONEN: W ithdraw that question.
Q. Do you know why that is? When you -- go ahead.
A. Actually, when I photocopied, I photocopied both sides, you know, like the front side of
the bills and then the back side of the bill. But in what I turned over in my deposition, the
whole bills were there. I dont know why its just half.
Q. Youve never seen that before?
A. Ive never seen this before.
Q. All right. To the extent that those are three $100 bills with consecutive numbers, do
they appear to be the same $100 bills?
A. Yes.
Q. And they are, in fact, $100 bills with consecutive numbers; is that correct?
A. Yes.
MR. ZONEN: I move to introduce both of those exhibits into evidence.
MR. MESEREAU: Ill object; no foundation. She did not recognize the document.
THE COURT: Ill ad mit the documents.
MR. ZONEN: Thank you.
Q. Id like to show you some additional photographs, if I may.
MR. MESEREAU: Could I see those?
Q. BY MR. ZONEN: Showing you a photograph previously identified as 793, do you
recognize the person in that photograph?
A. Kind of looks like Brett Barnes, but Im not sure.
Q. Do you believe that might be Brett Barnes?
A. Kinda, yeah.
Q. Let me show you the photograph in 795. Lets start with 794. Two different
photographs. The first with the child on the top, and the second with a number of children
on the bottom. Start with the photograph with the child on the top. Do you know who that
is?
A. Thats Brett Barnes.
Q. And then the photograph on the bottom, do recognize any of the four people?
A. I cant -- no. I cant tell if thats Brett. He was little. I just
THE REPORTER: Im sorry, I cant hear you.
Q. BY MR. ZONEN: Speak into the microphone.
A. The first photo I believe is Brett Barnes. The second one I cant really tell.
Q. Let me show you Exhibit 795. Do you recognize anybody in that photograph?
A. Brett Barnes.
Q. And where is Brett Barnes in that photo?
A. Right here.
Q. All right. Who is he sitting next to in that photograph?
A. Mr. Jackson.
Q. Do you know the other people in that photograph?
A. I think its Carly in the middle. They look different, though, from when I seen them.
Q. Carly is the midd le person?
A. Yeah, the sister of Brett.
Q. And the mother to her on the right side of her?

A. Right.
THE COURT: Were going to break a little early. Take our afternoon break. (Recess
taken.)
THE COURT: Go ahead.
MR. ZONEN: I have just a couple more questions.
Q. Is there a wine cellar at Neverland?
A. Yes.
Q. And where is the wine cellar?
A. Its in the rec room, the recreation room.
Q. All right. Is that sometimes called the arcade?
A. Yes.
Q. Thats the building thats different from the residence?
A. Yes.
Q. Is there a door that secures the wine cellar?
A. Yes.
Q. Is that door kept locked, or was it kept locked during the time that you worked there?
A. It was always locked.
Q. Was it a key that opened that door or a combination lock?
A. It was a key.
Q. And do you know where the key was kept?
A. In the maids room.
Q. And where was the maids room?
A. In the main house.
Q. In the main house?
A. Yes.
Q. Was there more than one key to the door?
A. I believe there was.
Q. Did you ever have occasion to go down into the wine cellar?
A. Yes.
Q. For what reason?
A. To pick it up, clean. Just to make sure everything was cleaned up in there.
Q. And to do that, you have to first go get the key?
A. Right.
Q. All right. The room where the key was kept at that time, was that a room that was
open to anybody in the public?
A. Well, it was the maids room. The maids were usually in there. I mean, somebody could
walk in there.
Q. But it wasnt a room that was generally one of the rooms on tour when people took a
tour of Neverland?
A. No.
Q. Was it a room that somebody lived in or simply worked in? You said maids room. What
is the maids room?
A. The maids room is just like where the maids would go to take a break. It had a rest
room and
Q. Do you know if there were any other keys at that time?
A. I believe so.
Q. And do you know who else had those keys?
A. I believe security at that time had -- in their office, they had a key to that.

Q. You would pick up in the wine cellar on occasion?

A. Yes.
Q. What would require cleaning in the wine cellar? What do you mean by pick up?
A. Like, to go in there and to make sure that everything is -- sometimes you would have
to brass. There was a lot of brass out there, so wed have to brass, like, the sinks. So they
had -- the faucets were of brass.
Q. All right. Cleaning is what you mean?
A. Just cleaning, yeah.
Q. Im going to show you two photographs already shown to counsel. These two
photographs are No. 786 already in evidence, and No. 799 for identificat ion, not yet in
evid ence. No. 786, first of all, take a look at this photograph and tell us what that is.
A. Thats Mr. Jacksons bedroom where the Jacuzzi is.
Q. Is that the Jacuzzi that you were referring to when you were describing having to clean
that Jacuzzi?
A. Yes.
Q. 799, tell us what this photograph is.
A. This is the theater.
Q. Now, can you actually see windows up on that far wall on the theater?
A. Actually, you have the projection room right here, and there was a window right here, a
room, a bedroom. There was two bedrooms. There was one on this side, and there was
one I believe on the other side. And there was an area where you go up some stairs on
the side and would take you up, up high where youd be like in a viewing room. And the
viewing room would have -- Im trying to think if thats it up there.
Q. Youre pointing right now to what?
A. I believe that is probably the viewing room up above. It was up above the bedrooms.
Q. You were previously describing testimony of popcorn and Coke being thrown through
windows above -A. Right.
Q. -- in the theater.
A. Right.
Q. Are those windows shown in that particular photograph?
A. I believe its up here.
Q. All right. Now, that photograph that youre looking at - which I believe I said was 799 799, is the subject matter of that photograph accurately depicted in the photograph? In
other words, does it accurately portray whats inside?
A. I believe so, yes.
MR. ZONEN: Id move to introduce 799 into evidence.
MR. MESEREAU: No objection.
THE COURT: Its admitted.
MR. ZONEN: If I could publish 799 at this time.
Q. If you could, turn around and look at the screen behind you. And tell us, is that the
photograph that you just viewed, 799?
A. Yes, I believe so.
Q. Is that the theater?
A. Yes.
Q. All right. Now, on the desk in front of you, theres a laser pen, a laser pointer. If you
can do that -- thats not it. Thats it.
A. Okay.

Q. Dont -A. Okay.

Q. Show us the windows that you were referring to.
A. The window from up above?
Q. Yes.
A. It would be up here.
Q. And thats the -- a viewing room?
A. I believe it was a viewing room, yes.
Q. And the stairway to get up there is where?
A. I believe its on -- it used to be kind of like on the side as youre coming in the back out
here. There was a stairway. Its been so long.I know there was a stairway on the side, and
Im thinking somewhere back here, that would take you up to the top.
BAILIFF CORTEZ: Maam, you need to talk into that microphone.
THE WITNESS: Im sorry.
Q. BY MR. ZONEN: So you believe the stairway was on the side; is that what you said?
A. I believe it was on the side.
MR. ZONEN: Thank you. No further questions.
THE COURT: Cross-examine?
MR. MESEREAU: Yes, please. Your Honor.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. Good afternoon, Miss McManus.
A. Good afternoon.
Q. We havent met. My name is Tom Mesereau and I speak for Michael Jackson.
A. Okay.
Q. The prosecutor for the government mentioned a case you were involved in where you
were sued by Rosalie Hill, correct?
A. Correct.
Q. You were sued by Rosalie Hill as the guardian ad litem for two children, correct?
A. Correct.
Q. The children were Shane McManus and Megan McManus, correct?
A. Correct.
Q. And the prosecutor for the government mentioned that you didnt have a lawyer
representing you, right?
A. Correct.
Q. And that case was not tried before a jury, right?
A. Right.
Q. It was tried before a judge of the Santa Barbara Superior Court, correct?
A. I believe so.
Q. That was Judge Richard A. St. John, Judge of the Santa Barbara Superior Court, true?
A. I believe so.
Q. And you and your husband testified before Judge St. John, right?
A. I believe so.
Q. You told them your position under oath, correct?
A. I believe so.
Q. And after you told Judge St. John your position under oath, he found that you and your
husband willfully and maliciously defrauded these children out of the money in the estate,
true?

A. I believe so.
Q. Judge St. John found that that money was to be held in trust for the benefit of those
two children, right?
A. Yes.
Q. He found that you and your husband dissipated those funds, right?
A. I believe so.
Q. He found that you and your husband violated that trust, right?
A. I believe so.
Q. He entered a judgment against you and your husband for $30,000 -- excuse me,
30,584.89, correct?
A. I believe so, but I believe it was -- I thought it was like separate, like -- I thought it
was maybe 17 for me and 17 for my husband. Maybe -- I dont know. Maybe thats right,
what you have there.
Q. Would it refresh your recollection if I just show you Judge St. Johns judgment?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that judgment?
A. Right here? Yes.
Q. Does it refresh your recollection about the amount Judge St. John awarded the
plaintiffs against
you and your husband?
A. Yes.
Q. Okay. It was $30,584.89, which was principal and interest due, correct?
A. I believe so.
Q. And after he entered that judgment, Judge St. John also awarded the plaintiffs
attorneys fees, right?
A. I believe so.
Q. He signed a separate judgment awarding the people who sued you and your husband
$5,085.27 in attorneys fees and costs, right?
A. I believe so.
Q. And in that judgment, Judge St. John also found, again, that you and your husband
had willfully and maliciously stolen the money from those children, right?
MR. ZONEN: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: All right. Now, that lawsuit was before you sued Michael Jackson,
correct?
A. I believe so.
Q. And who did you join with in your suit against Michael Jackson?
A. Kassim Abdool -- do you want the names?
Q. Yes, please.
A. Kassim Abdool, Ralph Chacon, Melanie Bagnall and Sandie Domz.
Q. And in that case you had a lawyer, right?
A. Yes.
Q. In fact, you had a number of lawyers, right?
A. Correct.
Q. And youve already identified the lawyers that represented you and the other people

that sued Michael Jackson with you, correct?

A. Correct.
Q. Now, that case went to a jury, right?
A. Yes.
Q. That was a jury in this courthouse in Santa Maria, right?
A. Yes.
Q. In that particular case, a Santa Maria jury held that you had stolen from Michael
Jackson, right?
A. I believe so.
Q. And they awarded Mr. Jackson $35,000 for what you personally had stolen from him,
right?
A. The sketch that I found in the trash, yes.
Q. That was a sketch he had done of Elvis Presley, right?
A. Well, I thought it looked like Elvis Presley, but I dont really know for -Q. But you tried to sell it to a tabloid, correct?
A. Yes.
Q. You did sell it to a tabloid, correct?
A. Well, I gave it to Gary Morgan.
Q. You sold it to a tabloid, right?
A. I believe he d id.
Q. You dont know for sure?
A. I dont know who he actually really sold it to, but -Q. You certainly inquired at some point, correct?
A. I think I saw somewhere later that it was printed, but I dont remember like what, but
it was printed.
Q. But when you sold it, you believed it was a sketch by Michael Jackson of Elvis Presley,
right?
A. I thought so.
Q. And a Santa Maria jury held that you had stolen that from Michael Jackson, right?
A. Thats what they thought, yeah.
Q. And that was their verdict, true?
A. I believe so.
Q. Okay. There was a find ing that you had acted with fraud and malice against Michael
Jackson in that case, correct?
A. I believe -- you know, its been so long, I dont remember, but probably.
Q. You actually stipulated that you had engaged in fraud, oppression, and malicious
conduct against Mr. Jackson, true?
A. You know what, I dont remember everything. Its been a while, but -Q. Would it -- excuse me. Would it refresh your recollection if I show you that judgment?
A. Sure. Thats fine.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
MR. ZONEN: May I see, Counsel? (Off-the-record discussion held at counsel table.)
MR. MESEREAU: Let me withdraw the question and ask it again.
Q. The jury found you had acted with fraud, oppression and malice against Mr. Jackson,
true?
A. You know what? Honestly I dont really recall. I dont know.
Q. Would it refresh your recollection if you see the judgment?

A. Well, sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to read that judgment?
A. Yes.
Q. Does it refresh your recollection about the jury in Santa Maria finding that you had
acted with fraud, oppression, and malice ag ainst Mr. Jackson?
A. Yes.
Q. Thats what they held, right?
A. Thats what they -- yeah.
Q. All right. Now, the total amount -- excuse me, let me start again. The suit began when
you and the others sued Mr. Jackson, right?
A. Correct.
Q. And after you and Ralph Chacon and Mr. Abdool and Ms. Bagnall sued Mr. Jackson, he
responded with a countersuit, correct?
A. Correct.
Q. And the countersuit was an allegat ion that you had stolen property from him, right?
A. I believe so.
Q. Okay. Mr. Jacksons suit was a response to your suit, right?
A. Correct.
Q. Everything began when you and Mr. Chacon and Mr. Abdool filed the action, right?
A. Correct.
Q. And thats the action where you were represented by Mr. Ring, correct?
A. Correct.
Q. Okay. At the end of the case, there was a judgment signed by Judge Zel Canter of the
Superior Court of Santa Barbara in Santa Maria against you and Mr. Chacon and Mr.
Abdool and Melanie Bagnall and Sandie Domz for $1,473,117.61, right?
A. I believe it was more. I -- I thought it was 1.6 million each person.
Q. Would it refresh your recollection if I just show you -A. Sure.
Q. -- this? May I approach, Your Honor?
THE COURT: Yes.
MR. MESEREAU: Thank you.
THE WITNESS: Okay. All right. Uh-huh.
Q. BY MR. MESEREAU: Have you had a chance to look at that judgment?
A. Yes.
Q. And does it refresh your recollection about the amount?
A. Yes.
Q. Okay. Now, do you recall that Mr. Jackson was entitled to have a hearing on what are
called punitive damages after he won the jury verdict, right?
A. I believe so.
Q. And Mr. Jackson agreed to waive that portion of the trial, correct?
A. I believe so.
Q. He did it in return for one dollar, right?
A. Correct.
Q. Now, the prosecutor asked you some questions about a deposition that you appeared
at in the Jordie Chandler lawsuit, right?

A. Correct.
Q. And I believe you told the jury that you had lied under oath in that lawsuit, correct?
A. Can you repeat that? Im sorry.
Q. Yes, sure. I believe you told the jury that you lied under oath in that lawsuit, correct?
A. What jury? During our trial?
Q. No, let me start the question again. If you dont understand anything I ask you, dont
answer, just ask me. Ill try and rephrase.
A. Okay.
Q. In response to the prosecutors questions, you told the jury that you had appeared at a
sworn deposition in the Jordie Chandler lawsuit, right?
A. Correct.
Q. That was a lawsuit that you knew Mr. Chandlers parents had filed against Mr. Jackson,
right?
A. Correct.
Q. And you appeared and testified under oath in a deposition, right?
A. Correct.
Q. And you were asked questions by a number of lawyers, includ ing Larry Feldman, right?
A. Correct.
Q. That deposition took place on December 7th, 1993, right?
A. Yes. Correct.
Q. When have you last reviewed that deposition?
A. Actually, I never really went through it to really review it.
Q. Im sorry?
A. I never really went through it to review it.
Q. Okay. Before I ask you some questions about that deposition, when did you last talk to
any prosecutor about your testimony in this trial?
A. Last night.
Q. And who did you talk to about your testimony in this trial from the prosecution side?
A. Ron Zonen.
Q. Thats Prosecutor Zonen, who just asked you some questions?
A. Yes.
Q. Okay. Did he talk to you about what you were going to be asked today?
A. No.
Q. Was it a phone call or a meeting?
A. A meeting.
Q. Where did the meeting take place with Prosecutor Zonen?
A. In Santa Maria.
Q. And how long did the meeting last?
A. A little over three hours.
Q. Did Prosecutor Zonen give you anything to review before you testified today?
A. No.
Q. Did you review any documents to prepare for your testimony today?
A. Well, I -- I have my deposition from when I sued Mr. Jackson, and I did go over that.
Q. Now, thats the deposition from your suit against Mr. Jackson, right?
A. Right.
Q. Thats not the deposition that you gave in the Chandler lawsuit, right?
A. Correct.
Q. Now, did you review the deposition you gave in your suit against Mr. Jackson to

prepare for your testimony today?

A. Yes.
Q. But you didnt review your deposition in the Chandler case to prepare for your
testimony today?
A. Correct.
Q. Did Prosecutor Zonen ask you to review that deposition in your suit against Mr. Jackson
to
prepare for your testimony today?
A.No. Q. Did he ask you to review any documents before you testified?
A. No.
Q. You spent three hours with him last night?
A. Yes.
Q. Did that take place at the District Attorneys Office here?
A. No.
Q. Where did it take place?
A. Somewhere in Santa Maria, a home.
Q. Okay. Was Prosecutor Zonen the only one present, besides yourself?
A. No.
Q. Who else was there?
A. During that meeting?
Q. Yes, please.
A. Russ Birchim.
Q. Thats a -- Russ Birchim, a Santa Barbara sheriff?
A. I believe so.
Q. Was anyone else present?
A. Just them in the room.
Q. Okay. And during those three hours, they went over what you were going to be asked
today, right?
A. Well, they went over my depo -- Ron went over my deposition.
Q. Did he point to specific pages in your deposition?
A. No.
Q. Well, your deposition is volume after vo lume after volume, isnt it?
A. Yeah.
Q. How many volumes was your deposition in your suit against Mr. Jackson?
A. You know what? Im thinking I was deposed for eight days. Thats what I think.
Q. Did Prosecutor Zonen bring a copy of that deposition with him to your meeting?
A. I think he had one.
Q. Okay. Did he appear to have all of the volumes to the deposition with him?
A. I really dont know.
Q. Okay. But he had specific parts he wanted to talk to you about, right?
A. Not really specific parts. Just kind of going through it, you know.
Q. Did you go through all those eight days of deposition with Prosecutor Zonen in three
hours?
A. I dont believe so.
Q. Okay. Who chose what portions of the deposition you were going to look at during the
three-hour meeting, if you know?
A. I have no idea.
Q. Okay. Correct me if Im wrong, Prosecutor Zonen had portions of those deposition

volumes he wanted to talk to you about, correct?

MR. ZONEN: Objection as to what he wanted to talk about. Vague and speculative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did Prosecutor Zonen point out certain portions of those volumes
that he wanted -- that he appeared to want to discuss with you?
MR. ZONEN: Objection as to asked and answered and speculative as to what he appeared
to want to ask.
THE COURT: I think you need to cut that question in half.
MR. MESEREAU: Okay. All right.
THE COURT: Ill sustain the objection.
Q. BY MR. MESEREAU: During your three-hour meeting last night with Prosecutor
Zonen, you looked at seven or eight volumes of your deposition, right?
MR. ZONEN: Objection; assumes facts not in evidence that she looked at seven or eight
volumes of anything.
THE COURT: Overruled. You may answer.
THE WITNESS: Im sorry, you lost me. Um, can you repeat it?
Q. BY MR. MESEREAU: Yes, sure. During your three-hour meeting last night with
Prosecutor Zonen, you went through volumes of the deposition you gave in your suit
against Michael Jackson, correct?
A. I dont know if it was volumes. It was just whatever page had opened, you know.
Q. Who opened the pages?
A. It wasnt me.
Q. It was Prosecutor Zonen, wasnt it?
A. Yes.
Q. And he seemed to have certain pages he wanted to talk to you about, correct?
MR. ZONEN: Objection as to what he wanted to talk about. Speculative.
THE COURT: Overruled. You may answer.
THE WITNESS: I have no idea. I just was -- he was just going through it, period. I dont
-Q. BY MR. MESEREAU: And was he asking you questions about what you said in that
deposition?
A. No. He was just reading it.
Q. Okay. Im going to ask you some questions about the deposition you gave in the
Chandler suit -A. Uh-huh.
Q. -- on December 7th, 1993, okay?
A. Sure.
Q. Do you remember you said under oath that you trust Mr. Jackson and you would leave
your son alone with him?
A. I dont recall any of that. I dont recall -- I dont know what I said, because I have not
looked at that.
Q. Might it refresh your recollection if I just show you that page?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance -- excuse me. Have you had a chance to
look at those pages of your deposition?

A. No. Oh, right now? Yes, Im sorry. Sorry.

Q. Does it refresh your recollection about what you said in that deposition?
A. Yes.
Q. You said words to the effect, I trust Mr. Jackson, and you would leave your son alone
with him, right?
A. I believe so.
Q. Okay. You were asked if you ever saw Jordie Chandler in Michael Jacksons bedroom
and you said, No, right?
A. Correct, I believe.
Q. You said you had never seen Brett Barnes sleep in Michael Jacksons room, right?
A. Probably. I cant recall everything in that.
Q. Would it refresh your recollection if I show you?
A. I hate to have you keep coming back, but thats fine.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Yeah.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes.
Q. Does it refresh your recollection about what you said under oath in that deposition?
A. Yes.
Q. You said you had never seen Brett Barnes sleep in Michael Jacksons room, right?
A. Correct.
Q. You didnt recall when you had met Wade Robeson for the first time, right?
MR. ZONEN: Objection; hearsay.
MR. MESEREAU: Ill rephrase it. Ill withdraw it.
Q. Do you remember testifying under oath that you didnt recall when you met Wade
Robeson for the first time?
MR. ZONEN: Objection; hearsay.
THE COURT: Overruled. You may answer.
THE WITNESS: Um, actually, I dont -- I dont recall. I didnt go over that, so I dont -Q. BY MR. MESEREAU: Would it refresh your recollection if you look at that page?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page of your deposition?
A. Yeah.
Q. Does it refresh your recollection about your saying you dont know when you first met
Wade Robeson?
A. Yes.
Q. Do you remember testifying you didnt know how many times Brett Barnes had been to
the ranch?
A. Probably.
Q. Do you know if thats what you said?
A. I believe -- I dont know.
Q. Would it refresh your recollection to look at the page?
A. Sure.
MR. MESEREAU: May I approach?

THE COURT: Yes.

THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes.
Q. And you testified under oath you didnt know how many times Brett Barnes had been to
the ranch, right?
A. I believe so.
Q. Okay. Do you remember testifying under oath that you didnt know where Brett Barnes
slept?
A. I probably did. I dont remember.
Q. Might it refresh your recollection if I show you the page?
A. (Nods head up and down.)
MR. MESEREAU: May I approach, Your Honor?
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes.
Q. Does it refresh your recollection about what you said under oath abo ut whether you
knew where Mr. Barnes slept?
A. Yeah.
Q. And what did you say?
A. I believe I said, I dont know.
Q. Okay. Now, you knew you were under oath in this deposition, right?
A. Yes.
Q. Did Prosecutor Zonen discuss with you last night what you were going to say if
confronted with this sworn deposition in trial?
A. No.
Q. Did the issue of what you had said under oath in the Chandler deposition ever come up
during the three hours you spent last night with Government Prosecutor Zonen?
A. No.
Q. Okay. Do you remember being asked under oath in that deposition if you ever saw
Jordie Chandlers clothes at the ranch?
A. I believe that I do recall that.
Q. Do you remember saying that you saw his mother bring them into Mr. Jacksons room
in a suitcase?
A. Yes.
Q. Do you remember being asked questions by Mr. Feldman about the alarm system in
Mr. Jacksons room?
A. I dont recall that.
Q. Remember telling him, People like to kill celebrities, so you have to be careful with
your life?
A. I dont recall that.
Q. Okay. Would it refresh your recollection if I show you that portion of your deposition?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to review that page?
A. Yes.
Q. Does it refresh your recollection about what you said under oath to Mr. Feldman on

that subject?
A. Yes.
Q. You did say, When youre a celebrity, you live a different life than regular people. I
mean, people like to kill celebrities, so, you know, he has to be careful, you know, with his
life. And then -MR. ZONEN: Im going to object as to hearsay, reading from a deposition thats not
inconsistent with current testimony.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Now, are you telling the jury that throughout this deposition you
committed perjury?
MR. ZONEN: Objection; calls for a legal conclusion.
MR. MESEREAU: I believe it was raised on direction examination by the prosecutor, Your
Honor.
MR. ZONEN: Not issues of perjury.
THE COURT: Ill sustain the objection to the question as phrased.
MR. MESEREAU: Okay.
Q. You told Prosecutor Zonen that you repeatedly lied under oath in that deposition,
correct?
A. Are you -- what are you talking about?
Q. When Prosecutor Zonen asked you some questions today in court, remember that?
A. Okay, yes.
Q. He asked you if you had lied under oath in the Chandler deposition, right?
A. Right.
Q. You said you did, right?
A. Right.
Q. Do you know how many times you lied under oath in the Chandler deposition?
A. I believe the whole time I did not tell the truth on that.
Q. Did you believe you were co mmitting a crime when you did that?
A. I really didnt. I really didnt think of it that way.
Q. Well, let me ask you this: So far, youve admitted you lied under oath in the Chandler
deposition for what, a day?
A. Well, throughout that -- throughout that deposition, yes.
Q. And Judge St. John found that you lied in that trial, right?
MR. ZONEN: Objection. Asked and answered; argumentative.
THE COURT: The objection is sustained.
Q. BY MR. MESEREAU: And the jury found you didnt tell the truth in your suit against
Mr. Jackson, right?
MR. ZONEN: Objection. Asked and answered; and argumentative.
THE COURT: Sustained.
Mr. Mesereau, a few questions back, after you refreshed her recollection with the
transcript about youre a celebrity, I sustained an objection, and I was incorrect.
MR. MESEREAU: Okay.
THE COURT: Do you want to reask that question? Ill reverse my ruling on that.
MR. MESEREAU: Thank you, Your Honor.
THE COURT: So what had happened is shed refreshed her recollection, and then you
wanted to -MR. MESEREAU: Okay.
THE COURT: Go ahead.

Q. BY MR. MESEREAU: Do you remember I showed you the page of the deposition about
what you said about people try to kill celebrities?
A. Yes.
Q. And did that refresh your recollection about what you said on that issue under oath?
A. I believe so.
Q. Okay. And as you recall, what did you say under oath on that issue?
MR. ZONEN: Objection; irrelevant.
THE COURT: Overruled.
THE WITNESS: I forgot.
Q. BY MR. MESEREAU: Would it refresh your recollection if I show it to you again?
A. Yes.
THE COURT: What Im going to do is let you read it to her. Thats what I stopped you
from doing. And Ill allow you to do it.
MR. MESEREAU: Thank you, Your Honor.
THE COURT: And hes going to ask you if this is -- You ask her. (Laughter.)
MR. MESEREAU: Okay. All right.
Q. Ms. McManus, this is what you said under oath: But you have to understand now,
when youre a celebrity, you live a different life than regular people. I mean, people like to
kill celebrities, so, you know, he has to be careful, you know, with his life, and that little
sensor benefits him for his life. Remember saying that?
A. I believe so.
Q. Okay. Now, you werent lying when you said that, were you?
A. No.
Q. In fact, you knew that Mr. Jackson is very nervous about his personal security, isnt he?
MR. ZONEN: Objection. Speculat ive as to what he is nervous about; lack of foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: Repeat it, please.
Q. BY MR. MESEREAU: You knew when you worke at Neverland that Mr. Jackson is
extremely nervous about his security, isnt he?
A. I really dont know.
Q. Well, when you saw his bodyguards, right?
A. Are you talking -Q. Huh?
A. Are you talking OSS or just security from the house?
Q. Let me rephrase it. I think I was too vague on that one.
A. Okay.
Q. During the time you worked at Neverland -A. Uh-huh.
Q. -- was it your understanding that Mr. Jackson is someone whos very concerned about
his personal security?
A. I really dont know. I mean -- I dont know.
Q. You knew he had personal bodyguards to protect him, right?
A. Yeah.
Q. You knew they traveled with him when he went on tours around the world, right?
A. Yeah.
Q. You knew they were often armed, right?
A. Yes.
Q. And you knew that he was always concerned about threats to his personal welfare,

right?
A. I dont know about that. But, I mean, I dont want to answer that, because I dont
know.
Q. Did it ever occur to you that he might be concerned about his personal welfare?
A. I -- I dont know. I -Q. Okay. You testified under oath that twice you saw June Chandler bring her son Jordies
clothes in a suitcase into Mr. Jacksons room?
A. I dont know if it was twice. I know at least once. I dont remember what I said on that.
Q. Would it refresh your recollection if I just show you that page?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page of your sworn
deposition?
A. Yes.
Q. Does it refresh your recollection about what you said on that subject?
A. Yes.
Q. What did you say?
A. Twice.
Q. Okay. You testified that you saw Mrs. Chandler open the suitcase and take clothes out,
right?
A. I -- you know what, I dont recall.
Q. Do you remember saying that she would sit down on the floor, take clothes out of the
suitcase, fold them? Do you remember that?
A. Honestly, no, I dont remember.
Q. Would it refresh your recollection if I show you that page?
A. Yeah. Sorry.
MR. MESEREAU: May I approach, Your Honor?
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page of your sworn
deposition?
A. Yeah.
Q. Does it refresh your recollection about what you said on that subject?
A. Yes.
Q. What did you say?
A. That she would fold the clothes.
Q. That she would bring the suitcase and get on the floor and -A. And fold the clothes, yes.
Q. Remember testifying under oath that you were never there at night when Jordie
Chandler was in the room?
A. You know what, I dont recall.
Q. Remember testifying you said you were never at Neverland at night when Jordie was
there?
A. I dont recall that either.
Q. Would it refresh your recollection if I show you that page?
A. Sure. Probably, yes.
MR. MESEREAU: May I approach, Your Honor?

THE COURT: Yes.

THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page of your sworn
deposition?
A. Yes.
Q. Does it refresh your recollection about what you said about that subject?
A. Yes.
Q. What did you say?
A. That I wasnt there at night with Jordie.
Q. Now, there were many occasions where Jordie Chandler, his mother and sister would
come to the ranch and stay, right?
A. I believe so.
Q. Do you remember what his sisters name was?
A. Lily.
Q. Did you ever talk to Lily?
A. I dont believe so.
Q. Do you know what his mothers name was?
A. June Chandler.
Q. Did you ever talk to June Chandler?
A. Yes.
Q. What were your typical hours working at Neverland?
A. They varied, actually.
Q. Was there a particular time you normally punched in?
A. Sometimes 8:30, sometimes 9:00 in the morning.
Q. Do you remember testifying that you have never seen Mr. Jackson in bed?
A. I dont recall.
Q. Might it refresh your recollection if I show you your deposition?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes.
Q. Does it refresh your recollection about what you said -A. Yes.
Q. -- on that occasion?
A. Yes.
Q. What did you say?
A. That I didnt see him in h is bed.
Q. Youd never seen Mr. Jackson in bed, right?
A. Right.
Q. What was your understanding about when you were supposed to be at Neverland to do
your work?
A. Well, there was a schedule, and we kind of just followed the schedule. But then there
were times that you didnt know when you were going to go home because of the guests
being there late. So you come in at a certain time, but that didnt mean that you were
going to leave at the time that you were scheduled.
Q. So how would you learn what time you had to be there?

A. I believe there was a schedule that was made. You know, like supervisor would make
it. And youd be on the schedule at maybe 8:30 or 9:00, sometimes maybe till 5:30 or
6:00. But then, like I said, if there were guests, you didnt know what time you were
going to go home.
Q. Do you remember testifying you couldnt tell if Mr. Jordie Chandler ever took a shower
with Mr. Jackson, right?
A. A shower with Jackson?
Q. Yes.
A. Perhaps.
Q. Would it refresh your recollection if I show you that page?
A. Yeah.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Yes.
Q. BY MR. MESEREAU: Have you taken a look at that page?
A. Yes.
Q. Does it refresh your recollection about what you said?
A. Yes.
Q. And what did you say?
A. I said I didnt -- I said I d idnt -- I dont know, I just forgot. Sorry.
Q. You said you couldnt tell if Mr. Jackson ever took a shower with Mr. Jackson, right?
A. I couldnt tell. R ight. Right.
Q. You said youd never seen Mr. Jackson in a Jacuzzi, right?
A. In a Jacuzzi, like taking a bath in a Jacuzzi, is that what youre talking about?
Q. You said you had never seen Mr. Jackson in his Jacuzzi?
MR. ZONEN: Ill object as hearsay if its not inconsistent with current testimony, also
vague.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You testified under oath that youd never seen Jordie Chandler
get ready to go to bed, right?
A. Perhaps. Like I said, I havent gone over that, and Im sorry.
Q. Would it refresh your recollection if I show you that page?
A. Yeah.
MR. MESEREAU: May I approach?
THE COURT: Yes.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes.
Q. Does it refresh your recollection about what you said?
A. Yes.
Q. And what did you say about Mr. Chandler on that issue?
A. That I didnt see him ready to go to bed.
Q. And you also said youd never seen him get up in the morning, right?
A. Correct.
Q. The prosecutor asked you a couple of questions about whether Mr. Jackson ever played
with a pet monkey in his bedroom, right?
A. Yes.
Q. And I believe you said he had; is that right?
A. Yes.

Q. Okay. Was that chimpanzees name Max?

A. I believe so.
Q. When you had your deposition taken in the Chandler case, you said youd never seen a
chimpanzee in his bedroom, right?
A. Perhaps.
Q. Would it refresh your recollection if I show you the deposition?
A. Yes.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes.
Q. Does it refresh your recollection about what you said under oath at that deposition?
A. Yes.
Q. And what did you say?
A. I said, No.
Q. You said everybody plays with the chimpanzee but youve never seen it in Mr.
Jacksons room, right?
A. I believe so.
Q. Okay. Did you work at Neverland when Blanca Francia was working there?
A. Yes, I did.
Q. And how long did you work at Neverland when B lanca Francia was also working there?
A. I would think maybe nine months.
Q. Did you share similar responsibilities with Blanca Francia?
A. Are you talking about Mr. Jacksons room, or just as a maid, as an aide?
Q. Let me rephrase it. When you worked at Neverland, what did you understand Blanca
Francias responsibilities to be?
A. Blanca had Mr. Jacksons room. She was his personal maid. Although Blanca did help
out with the other things in the house or the guest units. She kind of did a lot of
everything.
Q. And when you worked at Neverland, what did you understand your responsibilities to
be?
A. Are you talking about the beginning or -Q. Lets start at the beginning, sure.
A. Okay. When I started, I was just a regular maid, like everybody else. I was in the
kitchen helping wash dishes. Set tables. I mean, actually a lot of different stuff. You know,
cleaning the guest quarters, the theater, everything, except Mr. Jacksons room.
Q. When did you begin to clean Mr. Jacksons room?
A. Actually, about nine months after my employment, which was when Blanca quit.
Q. During the first nine months of your employment when Blanca was working there, did
you ever go into Mr. Jacksons room?
A. I cant recall.
Q. Do you recall ever having similar responsibilit ies in Mr. Jacksons house to Blanca
Francia?
A. At times, yeah, maybe.
Q. Were there times when she would clean Mr. Jacksons room on a given day, and on
another day you would clean Mr. Jacksons room?
A. No. No.

Q. Okay. So you didnt go near his room for the first nine months you worked there, right?
A. Correct.
Q. During those nine months, did you and Blanca Francia speak to each other?
A. Yes.
Q. Did you speak to each other often during those first nine months?
A. Yes.
Q. Did you ever learn that Blanca Francia had sold a story to a television show?
A. Um, I heard she did.
Q. Did you hear she had sold a story for money to Hard Copy?
A. I heard she did.
Q. Okay. Did you and Blanca ever d iscuss that subject?
A. No.
Q. How many -- let me rephrase that. You sold the sketch to a tabloid, right?
A. Me personally?
Q. Yes.
A. Not me personally. Somebody else did.
Q. Well, they did it on your behalf, right?
A. Well, I would probably think so. I dont -- yeah.
Q. Well, how did that person get the sketch?
A. Gary Morgan had gone to our attorneys office, Mr. Ring, Michael R ing, and thats where
he got it, from there, at the attorneys office.
Q. Did you bring the sketch to Mr. Rings law office?
A. Yes, I did.
Q. Did you tell Mr. R ing, I took this from Neverland Ranch?
A. No, I -- actually, I dont even -- I dont even think Michael Ring -- I dont even think he
saw it. I dont know if he saw it. I told Gary Morgan that I got it out of the trash. And I
told him he could have it. So thats kind of where that went. And I dont know what Gary Q. Well, you didnt really say he could have it, you sold it?
A. Actually, I told him he could have it. And he went and, I guess, sold it. And then I think
he said something in the tabloid, I dont even know which one it was, something that I
had told him that 5391 I got it out of Mr. Jacksons bedroom in the trash or something to
that -- which was not correct.
Q. Youre telling the jury that Michael Jackson did a sketch of Elvis Presley and you picked
it out of the trash?
A. I found it outside by the rec room in the trash, in the trash. And when I found it there,
I thought, well, it was neat, so I took it. It was in the trash.
Q. Is that one of the items the Santa Maria jury found you had stolen?
A. Well, thats what they -MR. ZONEN: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: When you went to Mr. Ring, did you tell this attorney where you
got the sketch?
A. I dont even recall if I -- he probably heard during the deposition that -- because I think
I was questioned about that during the deposition, and I did say that I found it in the
trash. But I dont remember -- I dont remember telling him about that myself. It must
have been, you know, at the deposition where I said I found it in the trash.
Q. Did you sell that sketch before you went to trial in your lawsuit against Michael

Jackson?
A. Before I went to trial?
Q. Yes.
A. You know what? I dont even know -- I really dont know when that -- the timing. I
dont know if it was during the trial maybe, later during the trial.
Q. Let me ask you this: Youve told the jury the money that came -- excuse me. Let me
rephrase it. Youve told the jury the money that was obtained in return for that sketch
helped fund your lawsuit against Mr. Jackson, right?
A. Correct.
Q. Did you know when you did that that Mr. Jackson was alleg ing that you had stolen that
sketch?
A. Not that I know of.
Q. Let me ask you if this statement is accurate: You took what you were accused of
stealing and sold it for money to fund your lawsuit against Mr. Jackson, right?
A. I took what I found in the trash and gave it to Gary Morgan and he sold it.
Q. And at some point you knew you were accused of stealing that sketch of Elvis Pres ley,
right?
A. I got accused of that, yes.
THE COURT: All right. Lets end for today.

2005 April 8 (Day 28) A.Mc Manus, Phillip Lemaeque Testimony

ADRIAN MARIE McMANUS EXAMINATION (Continued)

CROSS-EXAMINATION (Continued) BY MR. MESEREAU:

Q. Ms. McManus, your -- excuse me. Ms. McManus, your deposition in the Chandler
lawsuit was on December 7th, 1993, right?
A. Correct.
Q. And the Complaint you filed against Michael Jackson, along with Ralph Chacon, was
December 2nd, 1994, a year later, approximately a year later, right?
A. I believe so.
Q. Okay. Would it refresh your recollection just to take a look at the Complaint?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?THE COURT: Yes.
THE WITNESS: Okay. Yeah.
MR. MESEREAU: Thank you.
Q. Now, in that lawsuit, you were suing Mr. Jackson for a number of different claims, and
one of the claims talked about you having appeared at a deposition taken by Larry

Feld man, and the claim said that you were a potential material witness against Jackson in
both the civil suit and a criminal investigation, right?
A. I believe so.
Q. And what that really meant was, by filing that Complaint with that language, you were
essentially threatening Mr. Jackson that you would change your testimony unless you
were paid, right?
A. Im not familiar with a lot of attorney language, so I really dont know how to answer
that.
Q. How much money do you recall you were seeking from Mr. Jackson in that lawsuit?
A. Thats another question I cannot answer.That was dealing with my attorney.
Q. Well, you were in court when he argued to the Santa Maria jury for millions of dollars,
right?
A. I dont even know if I was there at that time. I could have been. I dont remember.
Q. You certainly must have discussed with your attorney during that six-month trial how
much money you were trying to get for yourself from Mr.Jackson, right?
2 A. Honestly, I dont believe anybody knew how
3 much money anybody would be getting out of a trial.
4 Q. But how much did you want?
A. I really didnt want anything. I just wanted justice for what I had gone through.
Q. You didnt want millions of dollars in that lawsuit?
A. I wanted justice. I didnt -- whatever -- I wanted justice.
Q. But your idea of justice was millions of bucks, right?
A. Well, thats not what I call justice.
Q. You file a lawsuit, you go through approximately eight days of depositions, all sorts of
paperwork, and youre in trial for six months. You wanted millions, right?
A. Honestly, a simple Sorry for what we did to you would have been great for me.
Q. Did you ever write a letter to Mr. Jackson saying, Mr. Jackson, I dont want to sue you.
Just tell me youre sorry?
A. No, I did not.
Q. Ever call Mr. Jackson and say, Mr. Jackson, I dont really want to sue you. Just say
youre sorry?
A. I didnt have a number to contact Mr. Jackson.
Q. Okay. When did you first go to the police to tell them you had seen anything improper
about Mr. Jackson?
A. I cant recall the date. I dont remember.
Q. It was after your deposition in the Chandler case, correct?
A. It might have been.
Q. Do you know approximately when you first talked to anyone from the Santa Barbara
Sheriffs Department about your claim that youd seen Mr. Jackson do anything improper?
A. You know, it might have been when I talked to my attorney, Mr. Ring. It might have
been sometime then, that I can recall.
Q. And when you did that, you thought going to the sheriffs would put pressure on Mr.
Jackson to pay money in your civil case, right?
A. No, I did not.
Q. Did you go to the sheriffs with your attorney?
A. I dont believe so.
Q. But certainly you went to an attorney before anyone from law enforcement, right?
A. Actually, I recall going to law enforcement to com -- to complain about the death threat

that I got from James Van Norman and strange circumstances that were going on at
Neverland Valley Ranch.
Q. But that was also to bolster your claim for millions of dollars, right?
A. That was before I even contacted an attorney.
Q. But by doing that, you were setting the stage for a lawsuit for millions of dollars
against Mr. Jackson, correct?
A. No, I was not.
Q. You went to tabloids, a lawyer, and the sheriffs, all to get millions of bucks, right?
A. Youre wrong.
MR. ZONEN: Objection; compound.
THE COURT: The answer was, Youre wrong. Overruled. Next question.
Q. BY MR. MESEREAU: Do you know Leslie Gomez?
A. No, I dont.
Q. Do you know she was the manager of McFrugals?
A. I think I know her as Beaver. Thats the name I think Im thinking of.
Q. You told her you had never seen Michael Jackson act inappropriately with children,
right?
A. Ive never talked to her about Michael Jackson.
Q. You told Leslie Gomez that, The suit by that kid, meaning Mr. Chandler, was a bunch
of bull, right?
A. Ive never told -- Ive never talked to her about anything to do with lawsuits or
anything with Mr. Jackson.
Q. And do you know someone named Ludi Trujillo?
A. Yes, I do.
Q. Ludi Trujillo is your former boss at Gottschalks, right?
A. No, she was not.
Q. Who is she?
A. Shes a girl that worked at Gottschalks. Just a lady.
Q. She didnt have any position above you?
A. No, she did not.
Q. Okay. You talked to her about the Chandler lawsuit, didnt you?
A. No, I did not.
Q. She asked you specifically if Mr. Jackson ever mo lested children, and you told her, Of
course Michael did not, right?
A. No, I did not.
Q. You told her Michael Jackson was a great boss, didnt you?
A. No, I did not.
Q. Do you know someone named Jamie Vail?
A. No, I dont.
Q. Didnt Jamie Vail live across the street from you?
A. Where was this? I dont know the name.
Q. Okay. Do you remember telling someone named Jamie Vail that you loved Michael
Jackson, you love working at the ranch, and you never believed any of the charges
against him?
A. I dont even know that person.
Q. Okay. Do you know who Gayle Goforth is?
A. Yes, I do.
Q. And who is Gayle Goforth?

A. She was a supervisor that worked at Neverland Valley Ranch.

Q. Do you remember Gayle asked you if there was anything to rumors about inappropriate
conduct by Mr. Jackson?
A. She never -- we never talked about that, no.
Q. In the autumn of 1993, you told her there was no truth to those rumors about Mr.
Jackson acting inappropriately, right?
A. No, I did not.
Q. Now, you and Ralph Chacon and Kassim Abdool started meeting secretly at Neverland
to talk about your lawsuit, didnt you?
A. No, we did not.
Q. You and Ralph Chacon and Kassim Abdool began to meet at Neverland to discuss the
possibility of selling stories to the media, right?
A. No, we did not.
Q. Did you ever discuss selling a story to the media with Ralph Chacon?
A. No, I did not.
Q. When you were working at Neverland, did you ever learn that Ralph Chacon was
thinking of selling any story about Michael Jackson to the media?
A. No.
Q. When did you first hear anything about Ralph Chacons willingness to go to the media
with information about Michael Jackson?
A. The only time that we all sold a story was when we were alread y in our lawsuit with Mr.
Jackson, which was with Mr. Ring, our attorney.
Q. Now, at some point, you learned that Blanca Francia had sold a story to Hard Copy,
correct?
A. Yes.
Q. She sold her information before you sold yours, right?
A. I dont recall when Bianca -- Blanca sold the story.
Q. Do you know someone named Charli Michaels?
A. Yes, I do.
Q. Who is Charli Michaels?
A. She was a security guard for Neverland Valley Ranch.
Q. Did you ever hear informat ion that Charli Michaels was trying to sell a story about
Michael Jackson to the media?
A. No, I did not.
Q. To date, have you ever heard anything about that?
A. No.
Q. Ever have a discussion with Charli Michaels about the possibility of making money from
informat ion youd learned at Neverland?
A. No. I only recall talking to Charli about her having sexual harassment with people at
the ranch.
Q. Okay. So you and she never said anything about the possibility of making a buck from
the media, correct?
A. No. No.
Q. Okay. Now, when you were at Neverland, you learned that security guards at the
Encino home of the Jacksons on Havenhurst had sold stories for approximately $100,000,
right?
A. No, I never heard that.
Q. You knew they had sold stories about Michael Jackson, didnt you?

A. No.
MR. ZONEN: Im going to object as asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know someone named Francine Orosco?
A. Yes, I do.
Q. And who is Francine Orosco?
A. She was a maid for Neverland Valley Ranch.
Q. And at some point, she was a personal friend of yours, was she not?
A. We became friends, yes.
Q. Now, you knew that she became a witness against your claims in the lawsuit, right?
A. Yes, I believe so.
Q. She said you were never sexually harassed by anybody, right?
MR. ZONEN: Ill object as hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Didnt you repeatedly tell Francine Orosco that Michael Jackson
was innocent of any charge of molestation?
A. No, I did not.
Q. Do you remember telling Francine Orosco that you were going to get big-time money in
your lawsuit against Michael Jackson?
A. No, I did not.
Q. And you tried to convince her to say that she had seen acts of sexual harassment
involving you, right?
A. No, I did not.
Q. While you worked at Neverland, Francine Orosco visited you at home, did she not?
A. Maybe one time.
Q. And you showed her a room in your house filled with watches, posters, clocks,
sunglasses, T-shirts and other items you had taken from Neverland, correct?
A. No.
Q. You showed her laundry baskets filled with Michael Jacksons clothes that you had
taken from Neverland, right?
A. No, I did not.
Q. Do you remember one time at Neverland when a box of black felt hats came for Mr.
Jackson?
A. I cant recall that.
Q. Do you remember that box of hats had Michael Jacksons name printed on the inside of
the rim of the hats?
A. I know he had hats, but I dont recall the hats being sent there.
Q. Do you remember taking a hat and saying you were going to bring it home?
A. No.
Q. Now, you used to take food home from the theater, did you not?
A. Food, like what are you talking about? Dinners?
Q. Candy?
A. No.
Q. Never took bags of candy home?
A. There was a time when -- you say take, youre saying like -- youre saying Im just
going to take it, that is not correct. There was a time when Gayle Goforth, a supervisor,
went down to the theater and took a lot of the candy from there, because it was expired.
She brought it back to the maids, the maids room, and she let all the maids take candy

that was expired. She also gave it to security. That was the only time.
Q. So you never stole any candy from Michael Jackson?
A. No, I did not.
Q. Do you remember around Christmastime when you worked at Neverland, Mr. Jackson
used to purchase toys for needy children?
A. I believe he d id.
Q. And they tended to be fairly expensive toys, did they not?
A. I really dont know.
Q. You took some of those toys home, did you not?
A. No, I did not. That was Janelle Wahl.
Q. Pardon me?
A. That was Janelle W ahl that would take that.
Q. You never took any Super Soaker guns home?
A. No, sir.
Q. Now, these are the kinds of things the jury found that you had actually done, correct?
A. I dont believe so.
Q. Well, they found that you had stolen from Mr. Jackson, correct?
A. I believe it was what they thought I had stolen was that sketch that I found in the
trash.
Q. And youre saying you didnt steal that either, right?
A. I didnt. I found it in the trash.
Q. Thats the sketch of Elvis?
A. Yes.
Q. You complained at Neverland that you should be paid more, right?
A. I dont believe I d id.
Q. Never said that to anybody?
A. I dont recall saying that.
Q. Okay. And you say you left voluntarily, correct?
A. I left after the harassment and the death threats, yes.
Q. And then you filed a claim for disability with EDD, right?
A. No.
MR. ZONEN: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Ralph Chacon stopped working at Neverland the same day you
stopped, right?
A. I dont believe so.
Q. Kassim Abdool stopped working there the same day you stopped, didnt he?
A. I dont believe so.
Q. All -- excuse me. Now, you sued someone named Bill Bray, correct?
A. Yes.
Q. And who is Bill Bray?
A. He was the -- how would you say it? Maybe the top man for the Office of Special
Services.
Q. You sued Betty Bailey, right?
A. Yes.
Q. And who was Betty Bailey?
A. She was maybe like his right hand.
Q. And you sued Mr. Jacksons personal security people, right?

A. Yes, I did.
Q. You sued Jimmy Van Norman, right?
A. Yes, I did.
Q. Marcus Johnson, right?
A. Yes. Yes.
Q. Tony Coleman?
A. Yes.
Q. And Jerome J.J. Johnson, right?
A. Yes.
Q. And at some point you approached Mr. Johnson about testifying for you, right?
A. No, I did not.
Q. Someone on your behalf did, right?
A. All I know is that I believe that, from what I understand, he jumped onto our side and
decided to tell the truth about what was going on.
Q. And when you say he decided to tell the truth, you dropped your suit against him,
right?
A. I believe we did.
Q. And the jury didnt believe him either, right?
MR. ZONEN: Objection.
THE COURT: Sustained.
MR. ZONEN: He never testified. Assumes facts not in evidence that he testified.
THE COURT: I sustained your objection.
Q. BY MR. MESEREAU: Do you remember when Mr. Johnson got in trouble for sending
an extortion letter to Mr. Jackson asking for three million dollars?
A. I did learn of that through the later part of my deposition, which I knew nothing about.
Q. At the point where you learned about Mr. Johnsons $3 million extortion letter to Mr.
Jackson, were you working with him on your lawsuit?
A. No.
Q. You stole commemorat ive Pepsi cans from Neverland, did you not?
A. No, I did not.
Q. You were accused of that, right?
A. No, I was not.
Q. Do you know someone name Peter Burt?
A. No, I do not.
Q. Never h eard the name?
A. Ive heard of the name, but I do not know him.
Q. Okay. You do know Sandie Domz, do you not?
A. Yes, I do.
Q. Who is Sandie Domz?
A. She was an office administrator, a secretary for Neverland Valley Ranch.
Q. You and the other plaint iffs in that lawsuit decided that she would go to the show Hard
Copy to try and sell a story, correct?
A. Not that I ever recall.
Q. Are you saying that didnt happen, or you just dont remember?
A. That did not happen.
Q. So you never got together and said, Well split money that we could get from Hard
Copy?
A. No, I did not.

MR. SANGER: Inside Edition. (Off-the-record discussion held at counsel table.)

Q. BY MR. MESEREAU: How much in total did Mr. Ring collect on your behalf from
tabloids or media?
A. From what I recall from my deposition, which there were stubs in my deposition, that
showed, Im thinking, maybe 32,000.
Q. Okay. Did any of that go to you?
A. 1,000.
Q. Now, you spent days being interviewed by a book author named Mr. Gutierrez, right?
A. Days being interviewed?
Q. Yes.
A. No.
Q. Were you interviewed by a book author named Mr. Gutierrez?
A. I never was interviewed, but I did meet with him.
Q. And approximately when d id you meet with him?
A. You know, I cannot recall the date.
Q. Well, you certainly had a discussion with him about the fact that he was writing a book,
didnt you?
A. No, I did not.
Q. So when you met with him, you didnt know he was writing a book?
A. No, when I met with him, he was going to try to help us in our lawsuit.
Q. Did you ever learn he was writing a book about Mr. Jackson?
A. I never -- I dont recall him saying that he was writing a book. I dont remember that.
Q. Did you give him informat ion about Mr. Jackson?
A. Um, later I d id.
Q. When you first talked to the Santa Barbara Sheriffs, you didnt tell them about
inappropriate behavior youd seen by Mr. Jackson, correct?
A. Probably not.
Q. You waited to say that in your lawsuit, correct?
A. I dont recall.
Q. Going back to your deposition in the Chandler suit - okay? -A. Uh-huh.
Q. -- you were asked if youd ever seen Wade Robeson at the ranch without one of his
parents, and you said, No, right?
A. I dont -- I have not gone over that, so I do not recall what Ive said or -Q. Would it refresh your recollection to just take a look at the page?
A. Yeah.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes.
Q. Does it refresh your recollection about what you said under oath in that deposition?
A. Yes.
Q. And on that issue, what did you say?
A. No.
Q. You said you had never seen Wade Robeson at the ranch without one of his parents,
right?
A. Correct.

Q. You were asked if you had ever seen Brett Barnes clothes in Mr. Jacksons bedroom,
right?
A. If its there. Like I said, I have not gone over that.
Q. And your response was sometimes his mother would give you his clothes to wash,
right?
A. Yeah, probably.
Q. Is that what you remember saying?
A. Like I said, I have not gone over that in probably ten years.
Q. Would it refresh your recollection to just take a look at that page?
A. Sure
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes, I did.
Q. Does it refresh your recollection about what you said?
A. Yes.
Q. And you said that his mother would give you his clothes, correct?
A. Correct.
Q. You didnt see his clothes in Mr. Jacksons bedroom, right?
A. Um -Q. Excuse me, at that point in time, you said you didnt see his clothes in Mr. Jacksons
bedroom, his mother would give you his clothes, correct?
A. Correct.
Q. You also said youd never seen any of the Culkin boys clothes in Mr. Jacksons
bedroom, right?
A. If its there, thats probably what I said at that time.
Q. Let me just go back a little bit. You said that you saw Macaulay Cu lkin and his brother
at Neverland, right?
A. I probably did.
Q. Would it refresh your recollection to look at that page?
A. Sure.
MR. MESEREAU: Okay. May I approach?
THE COURT: Yes.
THE WITNESS: Okay. Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes, I did.
Q. Does it refresh your recollection about what you said on that topic?
A. Yes.
Q. You said that you had never seen the Culkin boys clothes in Mr. Jacksons bedroom,
right?
A. Yes.
Q. You also told Mr. Feld man that you had never come to Mr. Jacksons room in the
morning and seen anything that indicated somebody may have slept on his floor, right?
A. I dont recall. Sorry.
Q. Would it refresh your recollection to look at that page?
A. Sure.
MR. MESEREAU: May I, Your Honor?
THE COURT: Yes.

THE WITNESS: Okay.

MR. MESEREAU: Thank you.
THE WITNESS: Uh-huh.
MR. MESEREAU: Have you had a chance to look at that?
A. Yes.
Q. Does that refresh your recollection about what you said?
A. Yes.
Q. And what did you say?
A. No.
Q. Do you remember testifying that Mr. Jackson had never given you money?
A. I dont recall that. I dont -Q. Did Mr. Jackson give you money from time to time?
A. No. There was just one time.
Q. Okay. And that was when you told the jury that you got 300 bucks to lie in a
deposition?
A. That -MR. ZONEN: Objection; misstates the testimony of the witness.
MR. MESEREAU: Let me rephrase that.
Q. Did you tell the jury that Mr. Jackson gave you $300 to lie in a deposition?
MR. ZONEN: Objection; misstatement of evidence.
THE COURT: Overruled. You may answer.
THE WITNESS: What I said was the $300 was given to me after Mr. Jackson had read
the transcripts of Jordie Chandler.
Q. BY MR. MESEREAU: Okay. And you interpreted that as a token of his appreciation?
A. Yes, for covering up for him.
Q. Okay. 300 bucks?
A. Yes.
Q. Okay. Do you remember being asked if youd ever seen a wo man in Mr. Jacksons
bedroom?
A. I cant recall that.
Q. You said you had seen June Chandler in h is bedroom, right?
A. I believe to bring in Jordies clothes.
Q. Well, let me just go step by step. You testified under oath in the deposition that you
had seen June Chandler in Mr. Jacksons bedroom, right?
A. To bring in his clothes, yes.
Q. You said you had never seen Mr. Jackson and June Chandler in any romantic
relationship, right?
A. Correct.
Q. You werent aware of her sleep ing with Mr. Jackson, right?
A. No.
Q. But you saw her in his room?
A. To bring in the clothes, yes.
Q. Well, you didnt say to bring in the clothes in the deposition, right?
A. I dont know whats in the deposition.
Q. Would it refresh your recollection to look at that page?
A. Sure.
MR. ZONEN: Ill object as irrelevant and hearsay.
MR. MESEREAU: I think the prosecution raised the issue of what was happening in that

bedroom.
THE COURT: Ill allow you to refresh her recollection.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page of your deposition?
A. Yes, I did.
Q. Does it refresh your recollection about what you said about June Chandler being in Mr.
Jacksons room?
A. Yes.
Q. You said you had seen June Chandler in h is room, right?
A. Yes.
Q. You didnt explain it in terms of her coming there for clothes, or with clothes, right?
A. I guess not, no.
Q. You testified that you had seen Jordie Chandler and Michael Jackson together outside
on a Jet Ski in the water, right?
A. I probably did.
Q. Do you remember that?
A. Slightly.
Q. You indicated you had seen Mr. Jackson in water balloon fights and squirt gun fights,
right?
A. I believe so.
Q. And you saw that once in a while, didnt you, while you worked there?
A. Yes.
Q. He would do that with kids all the time, wouldnt he?
A. Yeah, sometimes.
Q. Was it your impression that Mr. Jackson liked water balloon fights?
MR. ZONEN: Ill object as speculative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You said you had never seen Mr. Jackson hold hands with anyone
at the ranch, right?
A. I dont recall that.
Q. Could I refresh your recollection -A. Sure.
Q. -- by showing you the page?
A. Sure.
MR. MESEREAU: May I, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes, I did.
Q. Does it refresh your recollection about what you said?
A. Yes.
Q. You said youd never seen Michael Jackson hold hands with anybody at the ranch,
right?
A. Correct.
Q. Okay. Now, there was approximately a one-year period between this deposition and
the actual filing of your lawsuit against Mr. Jackson, right?

A. Are you talking about Jordie Chandler?

Q. Well, approximately a one-year period between your deposition in the Chandler case
and the filing of your lawsuit, correct?
A. I believe so.
Q. Now, the Chandler deposition was in December, and the next December you filed your
lawsuit, right?
A. I know the Chandler one was probably December 7th of -- oh, gosh, I dont know if it
was
8 93 or 94. I dont -- Im not -- I dont know the dates.
Q. Okay. We talked about a little earlier that December 7th, 1993, is the deposition in the
Chandler case.
A. Okay.
Q. And your lawsuit is December 2nd, 1994?
A. Okay.
Q. Okay?
A. Yes.
Q. Now, how long after the Feldman deposition in the Chandler case d id you to go a
lawyer to talk about suing?
A. I dont know how long after it was. I just -- I know I left Neverland in the end of July of
94. It might have been -- I dont even want to guess because Im not real -- Im not sure.
Q. You must have had a lot of meetings with Mr. R ing before you actually finalized the
lawsuit, right?
A. I believe so.
Q. And do you know roughly when that started?
A. You know, in my head, I dont know why I keep thinking 1995, but I dont know.
Q. For how many months do you think you and Ralph Chacon and Kassim Abdool met with
Mr. Ring before the action was filed?
A. I really cant answer that, because I really dont know.
Q. Approximately when d id you stop working at Neverland?
A. The exact date -- my last day, I believe, was July the 31st of 94.
Q. Do you recall participat ing in an Inside Edit ion show?
A. I believe so.
Q. And when did you participate in a show about Mr. Jackson for Inside Edition?
A. I believe that had to do when we contacted Gary Morgan. That was all around the same
time, so our lawsuit had already been going on.
Q. Do you remember meeting with representatives of Inside Edit ion?
A. I remember -- I remember those -- the people from Inside Edition showing up at our
attorneys office, so I guess, yeah.
Q. Did you meet with them with your lawyer?
A. Yes.
Q. And was Ralph Chacon in that meeting?
A. You know what, I really cant recall.
Q. Was Kassim Abdool in that meeting?
A. I dont want to say yes, because I cant recall.
Q. But the subject was Mr. Jackson, right?
A. Yes, it was.
Q. Do you remember trying to sell informat ion about Mr. Jacksons relationship with Ms.
Presley?

A. There could have been something of that. Possibly, yes.

Q. You say, Possibly, yes?
A. Yeah.
Q. Well, I mean, you were actually trying to get money from tabloids in return for your
giving them personal information about Mr. Jacksons relationship with Miss Presley, right?
A. We were trying to get money to help with our lawsuit to fight Mr. Jackson.
Q. Do you recall ever going to anyone in the med ia and telling them you had inside
informat ion on Mr. Jacksons relationship with Miss Presley?
A. I dont recall that.
Q. Okay. Do you recall ever g iving information to anyone in the media involving Miss
Presley and Mr. Jackson?
A. I believe we probably did with Gary Morgan.
Q. And he was your media broker, wasnt he?
A. I believe so.
Q. He was the one that you were using and Ralph Chacon was using to find media outlets
to sell information to, right?
A. I believe so.
Q. Okay. And you met him through Attorney Ring; is that correct?
A. Yes.
Q. Okay. Did you ever see any tab loids that quoted you about Mr. Jackson?
A. I -- I could have.
Q. Youre not sure?
A. Im not real, real sure.
Q. Did you ever see any tabloids that quotedyou about Mr. Jacksons relationship with
Miss
Presley?
A. I could have. Its been a long time. I kind of cant remember.
Q. Do you remember Star magaz ine asking you to sign a contract whereby you would give
them informat ion about Mr. Jackson and his relat ionship with his wife, Lisa Marie Presley?
A. I remember something to do with Gary Morgan and something with Star, but I dont
remember everything that was discussed with that.
Q. Might it refresh your recollection if I just show you that document?
A. Sure.
MR. MESEREAU: May I, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that document?
A. Yes.
Q. Does it appear to be a contract with Star magazine?
A. Yes.
Q. And you signed that, correct?
A. Yes.
Q. Okay. And among other things, you agreed to provide information about Mr. Jacksons
relationship with Lisa Marie Presley, right?
A. I believe so.
Q. And Ralph Chacon signed that, did he not?
A. I believe so.
Q. Now, youve heard the name Splash, correct?

A. Correct.
Q. And who was Splash?
A. I really -- all I know about Splash is that it was linked up with Gary Morgan, so I dont
know a lot of this tabloid stuff. I dont know.
Q. Well, Splash was an agency, was it not, that was retained by you to find media
sources, right?
A. If it was retained, it would have been with Michael R ing, my attorney.
Q. Okay. You signed an agreement with Splash News and Picture Agency, right?
A. I believe so.
Q. And was your involvement with Splash always through Mr. Ring?
A. Yes.
Q. Did you ever deal with Splash directly?
A. No, I did not.
Q. How long were you working with Splash?
A. I have no idea. I dont know the dates.
Q. At some point -- at some point did your relationship with Splash end?
A. Im sure it did.
Q. Okay. Do you know approximately when?
A. No, I do not.
Q. Were you giving informat ion to any tabloids or media sources during your trial?
A. Only through Splash.
Q. And that went on during the trial, right?
A. Probably sometime during the trial, yes.
Q. Do you recall trying to sell what you called Mr. Jacksons sex secrets? Do you
remember that?
A. I know something was written about that, but I know sometimes tabloids write other
stuff that they like to put in, so I dont know.
Q. You were quoted in an issue of Star magazine t itled Five of His Closest Servants Tell
All. Kinky Sex Secrets of Michael and Lisa Maries Bedroom, right?
A. I dont believe I said that.
Q. Have you seen that article before?
A. I did during my deposition.
Q. Was that the first time youd ever seen this article?
A. Yes.
Q. You are quoted in the article, correct?
A. I dont know. I could be. I dont know.
Q. Would it refresh your recollection if I just show you -A. Sure, you can.
MR. MESEREAU: May I, Your Honor?
THE COURT: Yes.
THE WITNESS: Kind of hard to see that. Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that article?
A. Yes.
Q. Does it refresh your recollection about you being quoted in that article?
A. Yes.
Q. You were going to tabloids and saying that you were the only person with a key to Mr.
Jacksons bedroom and you had information to sell, right?
A. Um, as Ive said, I know we d id interview -- the interview with Gary Morgan. But a lot

of the times with those tabloids, those tabloids write other stuff and put it in there, and it
makes it look like I said it, when I d idnt say it. So I dont know how to answer that.
Q. Well, did he have authorization from you to quote you with various tabloids?
A. You know what, thats where I dont know. He was dealing with Michael Ring, so I really
dont know. I kind of got stuck in the middle.
Q. Well, at some point you must have known that your quotes were appearing in tab loids
regarding Mr. Jackson, true?
MR. ZONEN: Assumes facts not in evidence that there were quotes.
THE COURT: Sustained.
Q. BY MR. MESEREAU: During the time you were represented by Attorney Ring, did you
learn from time to time that your name and various quotes about Mr. Jackson were
appearing in the media?
A. Just through the Gary Morgan deal. Thats all I recall.
Q. What Im trying to find out is this: Did you sort of leave it to other people to sort of
quote you when they wanted in the media?
A. Actually, sometimes you have no control over what people quote you in the media.
Q. But youre not saying you had nothing to do with these quotes, are you?
A. I cant answer that, because I dont know what was quoted.
Q. Okay. You never learned?
A. No. Huh-uh.
Q. During your trial with Mr. Jackson, were you speaking to various newscasters?
A. Only Gary Morgan is all that I recall, and when we met with Victor Gutierrez, and that
was it.
Q. Would he arrange meetings for you?
A. Victor Gutierrez?
Q. No, Mr. Morgan.
A. I believe he might have, through Mr. Ring.
Q. Was it -- let me rephrase that. Was it typical during your relationship with Mr. Morgan
that he would fax a story to you to have you review it, and ask you to see if you wanted
any changes, and then you would fax it back?
A. What I recall is viewing one -- I dont know what you call it, I dont know if it was a
transcript, and thats the only thing I remember seeing.
Q. Did the group used to meet with Mr. Morgan?
A. The only time we all met was with Mr. Ring at his office.
Q. And you had a number of meetings with Mr. Ring, Mr. Morgan, and the group that was
suing Michael Jackson, true?
A. Maybe two meetings that I can recall.
Q. And Ralph Chacon was at those meetings, right?
A. He might have been at one. I dont know if he was at all of them.
Q. When did you last talk to Ralph Chacon?
A. Its been a while. I dont know, maybe -- I really cant -- its been a while.
Q. When did you last talk to Kassim Abdool?
A. Actually, the last time I spoke with Kassim was during our verdict, when we lost, and I
have not seen him since.
Q. How about Melanie Bagnall?
A. I see her off and on.
Q. Do you recall your being quoted in any Australian newspapers about Mr. Jacksons
private life?

A. No.
Q. Was it your understanding that Mr. Morgan was going to try and use your quotes in
foreign newspapers about Mr. Jackson?
A. I have no idea.
Q. How many television shows do you think you appeared on where you purported to give
private informat ion about Michael Jackson?
A. The only thing that I can recall that I appeared on was maybe with Inside -- I think it
was Inside Edition. There wasnt an interview with me, but I think they captured me
walking, maybe, with -- I dont know if it was Kassim.
Q. Do you recall meeting with any representative of the media while you worked at
Neverland?
A. No.
Q. And youre telling the jury that you never had any discussion with any emp loyee while
you worked at Neverland about what you could make by selling a story?
A. The only thing I recall when I worked at Neverland was one of the maids, Francine
Orosco, had contacted the media. I dont know if it was -- it was one of the tabloids and
they had offered her $2,000, and she was going to come out and talk, but they wanted
her picture. And she was considering doing that. Thats the only thing I ever remember
with that.
Q. Finally, when did you last talk to anyone representing any media outlet about Mr.
Jackson?
A. I have not interviewed with anybody about Mr. Jackson.
Q. I dont mean an interview. I mean when have you last spoken with anyone who
purported to represent the media?
A. I havent really been talking to anybody about anything in the -- with the media.
Q. Has anyone called you from the med ia?
A. I did get a call from somebody from London at my job, and they wanted to interview,
and I told them no.
Q. When was that?
A. Maybe about -- within the last week.
Q. And you didnt interview because there is a court order in this case that youre not
allowed to do that if youre a witness, right?
A. Thats correct.
Q. Did you agree with them that on a future date you may speak to them?
A. I told them that I was not interested in doing any interviews, that I was under a gag
order.
MR. MESEREAU: No further questions at this time.
THE COURT: Redirect?
REDIRECT EXAMINATION BY MR. ZONEN:
Q. Mr. Mesereau asked you some questions about an article that was in a tabloid that
quotes you as saying that you have all kinds of information about kinky sex secrets
between Michael Jackson and Lisa Marie Presley. He showed you that article and asked
you if it refreshed your recollect ion as to whether there was, in fact, such an article, and
you said yes, it refreshed your recollection as to that article. About the quotations in the
article, are they accurate?
A. No, they are not.

Q. Did you ever give information about kinky sex secrets between Michael Jackson and
Lisa Marie Presley to any publicat ion, any med ia, or any reporter?
A. No, never.
Q. Do you, in fact, have information of kinky sex secrets between Michael Jackson and
Lisa Marie Presley?
A. No, I do not.
Q. Have you ever seen Michael Jackson with Lisa Marie Presley?
A. How do you mean, seen?
Q. Was she at the ranch during the period of time that you were there?
A. Yes, she was.
Q. Were they married during that time?
A. No.
Q. Were they visiting one another?
A. I believe so.
Q. Do you have any informat ion at all that Lisa Marie Pres ley ever stayed with Michael
Jackson in his room?
A. No.
Q. Did you ever see any woman stay with Michael Jackson in his room in the four years
you worked for him?
A. No, I did not.
Q. You stated in the deposition that you had never seen Michael Jackson hold hands with
anyone. Is that a correct statement?
A. No.
Q. Have you seen him holding hands with people?
A. Yes.
Q. Who?
A. Brett Barnes. The children that were at the ranch.
Q. You told Mr. Feldman during the deposition that you had never come into Mr. Jacksons
room and seen evidence that somebody had slept on the floor. Was that, in fact, a correct
statement?
A. Thats correct.
Q. In fact, during the time that you had worked there, you had never seen any evidence
that someone had slept on the floor?
A. Correct.
Q. You told Mr. Mesereau about June Chandler unpacking clothing in Mr. Jacksons
bedroom. Did that, in fact, happen?
A. Yes, it did.
Q. Explain that to us, please.
A. June Chandler had gone into Mr. Jacksonsroom and brought in suitcases of Jordie
Chandlers clothes, since he was staying with Mr. Jackson in his bedroom.
Q. I guess that begs the question, Miss Chandler obviously knew that her son was
sleeping in that room, correct?
A. Yes.
MR. MESEREAU: Objection; calls for speculation.
THE COURT: Argumentative; sustained.
Q. BY MR. ZONEN: Did she do this on more than one occasion?
A. I believe so.
Q. Was there a dresser or a drawer set up for Jordies clothing?

A. No. The clothes would just get put anywhere in the room.
Q. Were there any -- was there any occasion that you saw June Chandler in Michael
Jacksons room when she was not attending to her childs clothing?
A. Not that I can recall.
Q. You testified in the deposition that you had not seen Wade Robeson on the property
without a parent. Was that a correct statement?
A. Im sorry, you lost me.
Q. Had you ever seen Wade Robeson at Neverland without a parent?
A. No.
Q. Who was the parent that was always there?
A. His mother.
Q. And you never met the father?
A. No.
Q. Your initial conversations with the sheriffs office, were they at a time that you were
still emp loyed at Neverland Ranch?
A. Yes.
Q. You testified in the deposition that Brett Barnes mother would bring you his clothes to
wash. Was that, in fact, true?
A. At times that was true.
Q. Was that always the manner in which you washed his clothes?
A. No.
Q. In what other ways would you be washing his clothes?
A. If they were left in Mr. Jacksons room, I would take them and wash them along with
Mr. Jacksons clothes.
Q. You have testified in the Chandler deposition that you never saw Jordie and Michael
Jackson in his bedroom together. Was that a correct statement?
A. No, it was not.
Q. Had you seen the two of them together in the bedroom?
A. Yes.
Q. On more than one occasion?
A. Yes.
Q. Had you ever seen them in bed together?
A. Not in bed, no.
Q. You testified that you never saw Brett Barnes sleep in the bedroom with Michael
Jackson. You testified to that in the deposition, the Chandler deposition. Was that a
correct statement?
A. No, it was not.
Q. Had you, in fact, seen Brett Barnes sleep in a bedroom with Michael Jackson?
A. He was staying with Mr. Jackson.
Q. Did you ever actually see either Michael Jackson or Brett Barnes in bed in Michael
Jacksons room?
A. One morning I might have seen them in bed, yes.
Q. Do you have a recollection of that?
A. Yes.
Q. What did you see?
A. I brought breakfast and they were sitting in the bed.
Q. Both of them together?
A. Yes.

Q. Do you recall how they were dressed?

A. I dont recall.
Q. Were they in the bed, under the covers, or -A. Yes.
Q. They were in the bed under the covers?
A. Yes.
Q. You testified that you never saw Jordie Chandler either get ready for bed or get up in
the morning. Were either of those statements true?
A. Yes.
Q. Both of them?
A. Yes.
Q. You testified that you never saw a chimp in h is bedroom. Was that statement true?
A. No.
Q. In fact, youd been bitten by a chimp in h is bedroom; is that true?
A. Yes.
Q. Did you used to clean up after the monkeys?
A. Yes.
Q. Did you ever have to change their diap ers?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes, I did.
Q. BY MR. ZONEN: Did you ever have to clean up monkey droppings on the floors?
A. Not on the floor. Just on the walls.
Q. On the walls?
A. Sometimes monkeys get wild.
Q. You actually have to clean up their -A. Yes.
Q. -- mess on the walls?
A. Yes.
Q. You testified that you had never seen Jordie and Michael Jackson in the Jacuzzi. Is that
a correct statement?
A. Yes.
Q. You had testified yesterday that you had testified in the Chandler lawsuit that you had
no problems leaving your son with Michael Jackson. Was that true?
A. No.
Q. Were you, in fact, concerned about your son and Michael Jackson?
A. Yes, I was.
Q. Did you ever see Michael Jackson with your son behave in a way that concerned you?
A. Yes.
Q. What did he do?
A. Mr. Jackson would rub his fingers through my sons hair.
Q. Did that concern you at the time?
A. A little bit, yeah. I was a little upset.
MR. ZONEN: I have no further questions.
MR. MESEREAU: Very briefly.
RECROSS-EXAMINATION BY MR. MESEREAU:

Q. You tried to sell a story to a tabloid about Mr. Jackson putting his fingers through your
sons hair, didnt you?
A. No, I did not.
Q. You tried to sell stories to tabloids about your sons experiences at Neverland, correct?
A. No, I did not.
Q. Do you recall Mr. Jackson living at Lisa Marie Presleys home during the week, and Lisa
Marie Presley visiting on weekends during the time that you worked at Neverland?
A. No.
Q. You saw her there?
A. Yes, I did.
Q. Okay. Did you ever see Brooke Shields there before Lisa Marie Presley?
A. Yes, I -- I saw Brooke Shields, but I dont know if it was before.
MR. MESEREAU: No further questions.
FURTHER REDIRECT EXAMINATION BY MR. ZONEN:
Q. Where did Brooke Shields stay when she stayed at Neverland Ranch?
A. In a guest unit.
MR. ZONEN: No further questions.
MR. MESEREAU: No further questions.
THE COURT: All right. Thank you. You may step down.

PHILLIP LeMARQUE EXAMINATION

DIRECT EXAMINATION BY MR. AUCHINCLOSS:

Q. Good morning, Mr. LeMarque. Where did you work in 1991?
A. At the Neverland Valley.
Q. And who was your employer?
A. Michael Jackson.
Q. Is he the man seated to my right?
A. Yes.
Q. How long did you work at Neverland?
A. Oh, somewhere around ten months or more. Somewhere like that.
Q. And what did you do at Neverland?
A. Was in charge of the food. Majordomo of the food. And my wife was the cook.
Q. All right. What do you mean by majordomo of the food?
A. Well, in charge of serving the food and preparing and organizing for the guests and so
forth.
Q. And you said your wife also worked there at the same time?
A. Thats correct.

Q. Where did you live while you were living -- or while you were working at Neverland?
A. We were living at the ranch.
Q. Whereabouts at the ranch?
A. It was a house which is maybe -- was by the zoo.
Q. Were you involved in serving the food as well as preparing it?
A. Yes.
Q. And you said you left your employment there after about ten months?
A. Yes, somewhere around ten months.
Q. Why did you leave Neverland? Why did you leave the employment there?
A. There was an issue happening with Norma Stakos, who was Michaels private secretary.
THE COURT: All right. Were going to take a break. (The following proceedings were held
THE COURT: Counsel? Did you wish to address me?
MR. MESEREAU: Yeah, Your Honor. I believe the prosecutor filed a memorandum this
morning regarding impeachment of this witness.
THE BAILIFF: No one can hear you.
MR. MESEREAU: Oh, Im sorry. Your Honor, the prosecutor filed a plead ing this morning
regarding impeachment of this particular witness.
THE COURT: Yes.
MR. MESEREAU: And he has, as I understand it, requested that the defense not mention
the fact that this witness has been in the -MR. AUCHINCLOSS: Ill ask -MR. MESEREAU: -- the pornographic website business.
MR. AUCHINCLOSS: May I object, and just ask that the Court -- the Court is aware of
the issues. I dont think its necessary to publish them.
THE COURT: Thats true. He did -- not in the terms you just stated. For once you want to
use pornographic when no one else wants to. It was the other way around recently. But
what -- your point being?
MR. MESEREAU: Your Honor, we can prove that this witness tried to use tabloid stories
about Mr. Jackson -THE COURT: Whats your argument against his position? I understand what you can
prove. I think his position is well-taken. Whats your argument?
MR. MESEREAU: My argument is that what we would like to show, Your Honor, is that he
tried to use information allegedly about Mr. Jackson to get into this business.
THE COURT: All right. Ill sustain his objection. You cannot impeach him based on the
work he did on that -MR. MESEREAU: Website?
THE COURT: -- website after these incidents. All right. Bring in the jury.
(The following proceedings were held in open court in the presence and hearing

THE COURT: Go ahead, Counsel.

MR. AUCHINCLOSS: Thank you, Your Honor.
Q. Mr. LeMarque, where we left off, we were talking about the reasons that you left your
employment at Neverland.
A. The reason, there was some problem with Norma Stakos, who was Michaels secretary.
Q. What was that problem?

A. She wanted to have my wife to sign an affidavit stating that Bianca had been involved
into looking into purses of other maids. And since my wife didnt see it, she didnt want to
sign it.
Q. When you say Bianca was her name, do you know what her last name was?
A. No, I forgot.
Q. Did she have a d ifferent first name; do you know?
A. Not that I remember.
Q. Okay. And what was this woman Biancas -- what was her job at Neverland?
A. She was the private maid for Michael. She was the only one who could enter his room.
Q. So the affidavit that your wife was asked to sign was a false affidavit?
A. Well, it was false as far as my wife was concerned, because she never saw Bianca
looking into any purses so -Q. Did she believe that Bianca looked into any purses?
A. No, of course she didnt believe it.
Q. Okay. And how much time transpired between the time that your wife was asked to
sign this false affidavit and the time that you were asked to leave Neverland?
A. We were -- we were not asked, really, to leave, but we had a conference with Norma a
few days later, maybe three or four days, and Norma said I guess -MR. MESEREAU: Objection; hearsay, Your Honor.
THE COURT: Sustained.
MR. AUCHINCLOSS: Offered to explain conduct only.
THE COURT: The question was how much time transpired between the signing of the
affidavit, so its not responsive to the question.
MR. AUCHINCLOSS: Thats fine.
Q. So lets go back to that first question. How much time between the time that you -that your wife was asked to sign the false affidavit and the time that you actually left your
employment at Neverland?
A. I would say four or five days.
Q. Okay.
A. Maybe a week. I dont know.
Q. And were you terminated from your emp loyment?
A. No, we came into -Q. Thats just a yes or no question.
A. Yes.
Q. You were terminated?
A. (Nods head up and down.)
Q. Okay.
A. No. Yes and no.
Q. Yes and no. Okay. Thats fine.
A. Common agreement.
Q. Why do you say, Yes and no?
A. Because it was a common agreement that we decided, since we d idnt want to sign the
affidavit, that was not a place for us to work.
Q. Okay. While you were at Neverland during that ten-month period, did you observe Mr.
Jackson to have child vis itors?
A. Yes.
Q. Would these children spend the night at Neverland?
A. Some of them, yes.

Q. Would any of them come with families?

A. Yes.
Q. Would any of them come by themselves?
A. I think on one occasion I saw.
Q. Did you notice whether or not Mr. Jackson would spend time equally with all the child
visitors at Neverland?
A. No.
MR. MESEREAU: Objection; vague.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did Mr. Jackson show any special preference towards the
children that visited him at Neverland?
A. Yes.
MR. MESEREAU: Objection; leading.
THE COURT: Overruled.
Q. BY MR. AUCHINCLOSS: You may answer.
A. Yes.
Q. And was there anything in common that -- the children that Mr. Jackson showed
preference to, was there anything in common that these children shared?
A. Yes.
Q. What was that?
A. Little boys around 10, 11 years old.
Q. How would Mr. Jackson show preference to these 10- or 11-year-old boys?
A. He would spend most of his time with them.
Q. Would he ever buy them gifts?
A. Yes.
Q. Did he buy them more gifts than the other children?
A. Yes.
MR. MESEREAU: Im going to object. No foundation; move to strike.
MR. AUCHINCLOSS: I can ask some additional questions on that.
THE COURT: On the question that he objected on, did he buy them more than any other
children, Ill sustain the foundation.
MR. AUCHINCLOSS: Okay.
Q. Mr. LeMarque, were you ever asked by Mr. Jackson to go out and buy toys as gifts for
these children?
A. Yes.
Q. On how many occasions?
A. I dont -- several times.
Q. Okay. And can you characterize the number of gifts that you would buy, the number of
toys?
A. I would go to Toys-R-Us and pick out toys for boys of 10, 11 years old.
Q. Were you instructed to buy such toys?
A. No, but I figured that was what they were for, so -Q. And when you brought these toys to Mr. Jackson, did you have any occasion to see him
give these toys as gifts to the children?
A. Well, usually they were put into an area or a tabletop where the kids would come in,
you know, tear the papers off and pick up the toys.
Q. Did you see Mr. Jackson give more toys to the boys than the other children?
A. Yeah, they were mainly toys for boys.

Q. Okay. When Mr. Jackson had these children as guests at Neverland, what type of hours
would they keep, in terms of time that they were spending together?
A. Sometimes all day, all night.
Q. Was it uncommon for him to stay up all night with the children?
A. Yeah, it was very common.
Q. Where did the children sleep? And Im talking specifically about the 10- or 11-year-old
boys.
A. Mainly with Michael.
Q. Whereabouts?
A. I dont know, because we couldnt get into his apartment, so -Q. But somewhere in his private -A. In his quarters, yeah.
Q. -- quarters?
MR. MESEREAU: Objection; lead ing.
THE COURT: Well, actually he didnt finish the question. Ill strike the answer and have
you rephrase the question.
Q. BY MR. AUCHINCLOSS: My question was, you said that mainly they would sleep with
Michael, and I was asking if that was in his private quarters.
A. Yes.
Q. During the time that you were employed at Neverland, did you ever see Michael
Jackson sleep with anyone other than children?
A. No.
MR. AUCHINCLOSS: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. AUCHINCLOSS: Mr. LeMarque, I show you Peoples Exhibit No. 721. Can you
identify that for me, please?
A. Yes.
Q. Who is that in that photograph?
A. Macaulay Culkin.
Q. Did Macaulay Culkin visit Neverland while you were working there?
A. Yes.
Q. Was he a guest of Mr. Jacksons?
A. Yes.
Q. Did he spend the night there?
A. Yes.
Q. I show you two photographs which Ive previously shown to counsel. The first one is
Peoples Exhibit 800. Can you identify that for me, please?
A. Yes, this is the arcade.
Q. Okay. And is that a fair representation of the floor plan of the arcade when you were
working there?
A. Yeah.
Q. Are there some differences in terms of the items that are in this picture -A. Yes.
Q. -- than the items that were in the arcade back when you worked there?
A. Yes.
Q. What would that be?
A. Some of the artifacts here were not there. And some of the games have been changed.
I mean they were different, a little bit different.

Q. But the floor plan is essentially the same?

A. The floor plan is the same, yeah.
Q. I show you Peoples Exhibit 801. Same question. Can you identify that for me?
A. Thats the arcade also. Different angle.
Q. And same distinctions?
A. Yeah. Some of the artifacts have been changed and so forth. The pool table was there.
And some of the toy -- the games are different.
MR. AUCHINCLOSS: Okay. Ask that Peoples 800 and 801 be admitted.
MR. MESEREAU: No objection.
THE COURT: Admitted.
Q. BY MR. AUCHINCLOSS: Mr. LeMarque, at some time during your employment, did
you see something involving Mr. Jackson and one of these boys that upset you?
A. Yes.
Q. Do you know the name of that boy?
A. Macaulay Culkin.
Q. And how long had you worked at Neverland when this incident occurred?
A. Well, Im not too sure there. I mean, six, seven months maybe.
Q. Okay. Where did this incident occur?
A. In the arcade.
Q. What was the approximate time of it?
A. Three oclock in the morning. 3:00 or 4:00 or something. 3:30, maybe.
Q. What was it that you brought you to the -- the arcade is the photos that I just showed
you?
A. Yeah.
Q. What was it that brought you to the arcade at approximately three oclock in the
morning?
A. Well, I was called by the security that Michael wanted some french fries.
Q. Okay.
A. So -Q. Were you asleep at the time?
A. Yeah.
Q. Was that uncommon for you to get a food order in the middle of the night?
A. It happened a few times. Not too often.
Q. Okay. Was this a telephone call that you received?
A. Was the -- yeah, I mean, we had the -- one of those remote control, I mean, phones.
Q. Okay. Intercom, or -A. Yeah, on the radio.
Q. Radio?
A. Yeah, radio.
Q. And your instruction was to?
A. Well, yeah, at the time there was always a code for Michael. At the time it was Silver
Fox. So they said that, Silver Fox want some french fries.
Q. Okay.
A. Okay. So -Q. And was there a location you were told to bring these french fries to?
A. Not right away. When they were ready, I just called security ag ain to find out where to
deliver the french fries, and I was told to go to the teepee area. Which Michael wasnt
there, so I called ag ain, and they said that he probably was in the arcade.

Q. Okay. Where was your wife during this time?

A. She was sleeping, home.
Q. Okay. So she stayed in bed and you went down to the kitchen and made the french
fries?
A. Right. Thats correct.
Q. And you said you first heard they were at the teepee. Did you go to the teepees?
A. Yeah.
Q. And those are teepees located on Neverland?
A. Yeah, they are. On the grounds.
Q. And no one was there?
A. No.
Q. When did you learn that they -- that you were to deliver the french fries to the arcade?
A. Well, at that time I called security and I said, Michael is not there. Where is he? And
they told me that he was at the arcade.
Q. Did you go to the arcade?
A. Yes.
Q. What did you see when you went to the arcade?
A. Michael was playing with Macaulay Culkin at one of the games, which was a Thriller, the
games.
Q. Thriller?
A. Yeah. And he was holding the kid because the kid was small, couldnt reach the
controls, so I guess he was holding him with two hands. The kids were up so they could
use the controls of the game.
Q. And what did you see that upset you?
A. His left hand was inside the pants of the kid.
Q. All right. I want you to tell the jury specifically how his hands were configured on the
boys body.
A. Well, his right hand was holding the kid maybe mid-waist, and the left hand was down
into the pants.
Q. Okay. Now, what type of pants was Macaulay wearing?
A. I forgot what they were. They probably were shorts or something.
Q. Were his hands, as far as you could tell, on the inside or the outside of the shorts?
A. They were inside.
Q. Were they coming in the shorts from the top or from the bottom?
A. From the bottom.
Q. Through one of the legs?
A. Bottom.
Q. Which hand was it that he was touching the boy with?
A. Left hand.
Q. When you saw this, what did you do?
A. I was shocked, and I almost dropped the french fries. And there was a game there, T ipTop, and I backed out -MR. MESEREAU: Objection. Move to strike; nonresponsive.
THE COURT: Denied.
Q. BY MR. AUCHINCLOSS: As far as the exact location of his hand, could you see where
his hand was in the vicinity of Mr. Macaulays person?
A. Well, it was in the -- you know, in the crotch area.

Q. The crotch area? And you said they were playing this video game. Did this vid eo game
create any sound?
A. Yeah, there was plenty of sound everywhere. I mean, all the machines were on and
playing music and making sounds.
Q. Do other machines, or did other machines in that video arcade make sounds even
though the werent being played at that time?
A. I think they were. Im not recalling exactly, but it was very noisy.
Q. Okay.
A. Yeah. Everything was noisy there.
Q. And you said you almost dropped the french fries. What happened next?
A. Then I backed out, and -Q. Backed out the door?
A. The door. Went outside, and I closed the door. And I realized that I still had to deliver
the french fries, so then I opened the door. I made a lot of noise to make sure that
Michael could hear me coming in. And I said, Michael, your french fries are here. And he
said, Drop them on this. I forgot where it was, but probably on one of the machine tops.
Q. And did you leave?
A. Yes.
MR. AUCHINCLOSS: May I have the Elmo, Your Honor? Input 4.
Q. All right. Mr. LeMarque, Im showing you Peoples Exhibit No. 800, which you previously
identified as a photograph of the arcade. Does this photograph depict in it anywhere the
door that you entered that room?
A. Yeah. Yes. This one here.
Q. Oh, youve got it. Very good. Youre ahead of me. Could you indicate again for me the
area where it is?
A. I think its around here somewhere. Or here, Im sorry. I dont know. Cant see too
well, that.
Q. Let me show you the photograph -- if I may approach -- just so you can get a better
look at it.
A. I dont know. I think its -- theres a lot of stuff in front of it. Its probably -- Im not
sure where it is. Its probably here.
Q. Okay.
A. Yeah.
Q. Right about there?
A. Yeah.
Q. All right. Ill show it.... Looking at the photograph a little closer, could you identify the
area that appears to be the doorway?
A. Right here.
Q. Okay. Indicating in the very upper portion of the photograph just off center at the
upper edge. All right. So thats the door you entered in. And which direction was it that
you were looking when you came in and you saw Mr. Jackson?
A. From here to here.
Q. Indicating from the left area of where the door is down to the -A. Yeah.
Q. -- lower right-hand portion of the photograph?
A. Yeah. Here to here. Or here to here someplace.
Q. All right. I show you now Peoples Exhibit No. 801. Mr. LeMarque, does that show a
different perspective --

A. Yes.
Q. -- of the same area?
A. Yes.
Q. Is that an approximate perspective of what you would have seen entering that door?
A. Yes.
Q. All right. So tell us, point out for us, if you would, the area where you saw Mr. Jackson
and Macaulay Cu lkin.
A. Somewhere around there.
Q. All right.
A. Or maybe -Q. Indicating -A. Or maybe here.
Q. -- the video games just to the left of what appears to be an espresso machine.
A. This was not there.
Q. Yeah, the espresso machine was not there -A. No.
Q. -- on the pool table?
A. No. Either this. This wasnt there.
Q. All right.
MR. AUCHINCLOSS: I think we can have the lights.
Q. Mr. LeMarque, did you ever tell this story -- or let me back up. After you left
Neverland, or at any time during close in time to the period that you saw these events,
this event you just described, did you ever report it to any authorities, the police?
A. No.
Q. Why not?
A. Because nobody would have ever believed us.
Q. And why do you say that?
A. Because Michael was on the top of everything, and if we had come and said to the
police, they would have said, What kind of proof do you have? So we couldnt -- I mean,
this wasnt possible. It would be impossible to give.
Q. Did you ever consult an attorney or any other person that might have some
background in the law as to what you should do?
A. Yes, and they told us the same thing.
Q. At some time after this event occurred, did -- were you ever approached by any
tabloids?
A. Yes. Many.
Q. And did you ever sell this story to a tabloid?
A. We talked about it. And we had even some guy trying to sell the story for us, some
sleazy guy that tried to make a deal with the tabloid. But at the last minute, we never
took in a penny from anyone, because it was against our principles.
Q. This sleazy guy that youre talking about, Im not going to ask you to mention his
name, but do you know if he ever profited from your story?
A. Yes, he did.
Q. Why do you say that?
A. Because we had an interview with him and our lawyer, Arnold Kessler, and he taped
the conversation while it was a private conversation of the lawyer.
Q. Okay.
A. And he sold the story to the tabloid and he made some money with that story.

Q. Were you tempted yourself to sell your story to the tabloid?

A. Yes, we were tempted for the money, for sure. Everybody would be tempted. But we
never did.
Q. Did you ultimately tell this story to the police?
A. Yes, we did.
Q. They came and interviewed you?
A. Yes.
Q. Were you honest with them?
A. Yeah.
MR. AUCHINCLOSS: Thank you. I have no further questions.
THE COURT: Cross-examine?
MR. MESEREAU: Yes, please, Your Honor.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. Mr. LeMarque, my name is Tom Mesereau and I speak for Mr. Jackson. You signed a
statement in September of 1993 about what you had seen, right?
A. If I signed a statement, I forgot when was that, if I sign a statement.
Q. Do you remember hand-writ ing a statement about what you claimed you had seen -A. I dont remember that.
Q. -- Mr. Jackson doing with Mr. Culkin? Remember saying, I could not distinguish what
he was really doing with his hand, but you thought it was more than fondling?
A. I dont remember that at all.
Q. Would it refresh your recollection if I just show you a copy of the statement?
A. (Nods head up and down.)
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: I guess its correct.
Q. BY MR. MESEREAU: Is that your handwriting?
A. Yeah.
Q. Is that your signature?
A. Yeah.
Q. The date is September 10th, 1993, correct?
A. Correct.
Q. Do you remember saying you couldnt distinguish what he was really doing with his
hand?
A. I dont recall that. But if its written, thats -Q. Its what you wrote, isnt it?
A. I guess.
Q. Well, is it your writ ing or not?
A. Yes, it is.
Q. Okay. And you wrote those words, did you not?
A. I guess I did, but I dont recall.
Q. Okay. Now, you worked at the Neverland Ranch for how long?
A. Maybe ten months.
Q. Did you ever sue Mr. Jackson?
A. No. Not for -- we did sue for money he owed us, because Norma Stakos was supposed
to pay us overtime, and she never d id. And she was supposed to give us some references,

good references for other job, and whenever we apply for a job, she never give the
references and she never sent us the money. So at that time we sued for the money that
was owed to us as overtime.
Q. Excuse me, Im sorry. Did you finish?
A. Yeah.
Q. Where did you file your lawsuit against Mr. Jackson?
A. Santa Barbara court, I think.
Q. Did you hire a lawyer in Santa Barbara to do that?
A. Yes.
Q. What was the lawyers name?
A. Forgot.
Q. How long did the lawsuit go on?
A. It didnt go on for very long.
Q. It settled fairly quickly, d id it not?
A. Yes.
Q. You got money -A. Yes.
Q. -- from Mr. Jackson, true?
A. We got money for time -- overtime due to us, the time we worked there.
Q. You wanted more than that, didnt you?
A. No.
Q. Now, you mentioned a sleazy guy was representing you, right?
A. Yeah.
Q. His name was?
A. He didnt represent us. He never represented us.
Q. You had meetings with him?
A. He was a friend, supposedly a friend.
Q. You had meetings with him, correct?
A. Yes, we did.
MR. AUCHINCLOSS: Objection; argumentative.
THE COURT: Overruled.
Q. BY MR. MESEREAU: His name was Paul Baressi, correct?
A. Thats correct.
Q. How did you meet Paul Baressi?
A. It was an old friend that Stella met years ago.
Q. And Stella is who?
A. My wife.
Q. Do you know how she met Paul Baressi?
MR. AUCHINCLOSS: Objection; relevance.
THE COURT: Sustained.
Q. BY MR. MESEREAU: How many times did you meet with Paul Baressi?
A. I cant recall. Several times.
Q. And Paul Baressi was in the adult film business, right?
MR. AUCHINCLOSS: Objection; relevance.
THE COURT: Sustained.
MR. AUCHINCLOSS: The Courts order.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You said he was sleazy. Why did you say that to the jury?

A. Because he taped our conversation without our own knowledge while we had a
conversation with our own private lawyer, and he sold that story to the tabloid.
Q. He was also trying to broker a deal for you with the tabloids, correct?
A. Well, thats what he said. I can get you a deal, because he had a deal himself
previously by telling stories about other people.
Q. But you had asked him to try and get a deal for you, hadnt you?
A. No, I didnt ask him. He came forwards.
Q. But you allowed him to do that, didnt you?
A. Well, we d idnt allow him. We said, Okay, well listen to it, because we were tempted
by the money, for sure. Everybody would be tempted. But in the last minute, we d idnt do
it.
Q. When -- excuse me. You didnt do it because you found out he had already sold the
story and taken the money himself, right?
A. At that time he d idnt do that. He didnt sell the story yet.
Q. Let me just get this straight. You had discussions with Baressi, right?
A. Uh-huh.
Q. You had phone conversations with Baressi, right?
A. Correct.
Q. You discussed a price youd be willing to accept?
A. No, we didnt discuss price with him.
Q. Pardon me?
A. We didnt discuss price with him.
Q. At one point you discussed the possibility of getting $100,000 with him, didnt you?
A. Thats what he said to us, he probably can get $100,000, so we say we are interested.
Q. You actually upped it to 500, didnt you?
A. I dont remember if that was the case, but we were playing the game with him to see
how far he could go, because we knew by then he was such a sleazy guy we wanted to
see how far he could go. Because we never d id it. We never took a penny from anyone.
Q. You upped the price to 500 from $100,000 at one point?
A. Yeah, to see if we were going to do it.
Q. You couldnt get that kind of money, right?
A. I dont know. We never pursued it.
Q. Mr. Baressi, on your behalf, approached a number of newspapers -A. He didnt work on our behalf, ever.
Q. Sir, I have to finish my question. On your behalf, Paul Baressi approached various
newspapers and televis ion shows to try and get hundreds of thousands of dollars for you
and your wife, right?
MR. AUCHINCLOSS: Objection; assumes facts not in evidence.
THE WITNESS: Thats not true.
THE COURT: Overruled. You may answer.
Q. BY MR. MESEREAU: Isnt that right?
A. Thats not true. Its a complete lie. He was trying to get deals for him, not for us.
Q. Didnt you just tell the jury you were playing along with him to see how much you
could get?
A. Well, at first, yeah, we were doing. But then we realized the guy was so sleazy, we
were not going anywhere with him. So we backed out, and we said, We are not game,
and he kept going, doing it.
Q. Did you have a d iscussion with Paul Baressi where you said, We dont want 100,000.

We wan 500,000? Yes or no.

A. Yes.
Q. Do you remember having a d iscussion with Mr. Baressi where you learned the price
would be higher if the story was Mr. Jacksons hand was in the clothes rather than
outside?
A. That was his own made-up stories, not my story.
Q. That statement was made in your discussion with Mr. Baressi, true?
A. I dont recall that, but I think he did it himself. Thats what he said we could get if the
hands went higher.
Q. Okay. Now, did you ever know anyone named Quindoy at Neverland?
MR. AUCHINCLOSS: Objection; beyond the scope.
MR. MESEREAU: It fits in with the cross-examination, Your Honor.
THE COURT: Thats a good response. (Laughter.)
MR. MESEREAU: I mean, its the same -THE COURT: Fits in with what Im doing. W ell, I dont know the answer. Ill allow the
question and see how it fits.
Q. BY MR. MESEREAU: You and your wife worked at Neverland, right?
A. Correct.
Q. Did you ever know a couple named Quindoy that worked at Neverland?
A. No.
Q. Ever hear the name?
A. Yes.
Q. Had they worked before you?
A. Yes.
Q. You learned that the Quindoys were trying to sell a story to the media, right?
A. No, we never
MR. AUCHINCLOSS: Objection. Relevance; beyond the scope.
THE COURT: Overruled. You may answer. He d id answer. The answer was, Yes, and
then -- Im sorry, the answer was, No, we never.
Q. BY MR. MESEREAU: At one point you were trying to sell your story before the Quindoys
did, correct?
A. No.
Q. Never talked about that with Mr. Baressi?
A. No.
Q. Who was the lawyer you retained when it came to dealing with the media?
A. We had a friend, his name was Arnold -- geez. Im sorry, I have a b lank right now. I
have a b lank with the name.
Q. Was his name Kessler?
A. Yes. Thats correct.
Q. Did he practice law in Los Angeles?
A. Correct.
Q. Did you meet with Mr. Kessler?
A. Yes, we did.
Q. He is not the lawyer that represented you in your suit against Mr. Jackson, is he?
A. We didnt have a suit against Mr. Jackson. We had a suit against the work, as far as
work was concerned. We never sued Mr. Michael Jackson.
Q. You sued somebody.
A. We sued the MJ Corporation for overtime.

Q. That was Mr. Jacksons company.

A. Thats the company, but thats not Mr. Jackson. We didnt sue him.
Q. It was Mr. Jacksons company that hired you, wasnt it?
A. Yes. For overtime.
Q. Okay. This was after you left your employment, true?
A. Thats correct.
Q. Okay. You hired Attorney Kessler, correct?
A. No, we didnt hire him. He was a friend of ours. We ask him advice.
Q. You met with him a number of times about the possibility of selling a story to the
media, true?
A. With Baressi.
Q. So Baressi was your friend, and Kessler was your friend, correct?
A. Yes, thats correct.
Q. And after you met with Kessler, he started calling around trying to sell your story, true?
A. Im not sure what he was doing. I dont know. I never heard of it.
Q. Did you ever learn that he was doing anything to sell your story to anybody?
A. I was -- I dont recall, but I think everybody was trying to sell our stories. Everybody
else was trying to do that, so -Q. And approximately what year was this?
A. I dont recall. 92 or something. I -Q. When did you leave Neverland?
A. The year? I dont recall. 92, probably, at that time. Whatever. Im not sure.
Q. In 1993, Baressi and Kessler were trying to sell your story, true?
A. I guess they were, but I was not aware of it.
Q. But you had many talks with the two of them about that?
A. Yeah, we did earlier. And then we stopped and they kept doing it. I dont know what
they were doing. I couldnt keep track of them.
Q. Okay. When did you last talk to Kessler?
A. About that time. No, as a matter of fact, I talked to him two days ago because of what
happened in the -- with what was going on, and I finally find his phone number, and I told
him what was going on. And he was very upset about it.
Q. Hes still your buddy, right?
A. No, we havent talked since then.
Q. Did you talk to him about what you were going to say in court today?
A. No.
Q. Did you talk to him about this case?
A. Yeah, I said I was going to be on the stand.
Q. Okay. Did you call him or did he call you?
A. We called him.
Q. You and your wife?
A. My wife did.
Q. Okay. Were you on the conversation?
A. No.
Q. Was it just your wife that talked to him, as far as you know?
A. Yeah.
Q. Was she speaking on your behalf?
A. She was just telling him what was going on, thats all.
Q. Okay.

A. There was no behalf. There was just chat-chat.

Q. You knew that Mr. Kessler contacted The National Enquirer about your story, right?
A. No, I was not aware of that.
Q. You knew he contacted The Globe, right?
A. I was not aware of that either. We contacted them.
Q. You knew Inside Edit ion was contacted, correct?
A. Well, they contacted us directly also. So -Q. How about Splash News Service?
A. No.
Q. Okay. When did you last see Macaulay Culkin?
A. At that time. When I was working at the ranch.
Q. So youve never really asked him if he was abused, have you?
A. No.
Q. Youve never heard his side, have you?
A. No.
Q. Have you ever learned any time that he denies this event?
MR. AUCHINCLOSS: Objection; assumes facts.
THE WITNESS: I -THE COURT: Just a moment.
MR. AUCHINCLOSS: He said hes never had any conversation. And foundation. He said
hes had no conversation with Mr. Macaulay.
THE COURT: The objection is sustained.
Q. BY MR. MESEREAU: Okay. Have you followed this case in the media?
A. I dont.
Q. You dont follow it at all?
A. I never watch T.V., barely.
Q. Have you followed this case in the newspaper?
A. I read the newspaper briefly, the highlights, the headlines and so on. But it doesnt
interest me.
Q. When did you last talk to Mr. Baressi?
A. He called my wife two months ago.
Q. Did your wife talk to him?
A. She said, Go to hell.
Q. Im not asking you what she said. (Laughter.)
Q. BY MR. MESEREAU: All right. Okay. Do you know -- are you aware of him still trying to
sell stories on this case?
A. Yeah, hes still doing it.
Q. How do you know hes still doing it?
A. Because its on the -MR. AUCHINCLOSS: Objection. Foundation; hearsay.
THE COURT: The objection is overruled. The question was, How do you know hes still
doing it?
THE WITNESS: Pardon me?
THE COURT: You may answer that question. How do you -THE WITNESS: Im sorry, can you repeat that?
Q. BY MR. MESEREAU: Yes. Ill ask the question again. You told the jury Mr. Baressi is still
trying to sell stories, right?
A. Yes.

Q. How do you know that?

A. My son send me a copy through the Internet two days ago of what was in Splash.
MR. AUCHINCLOSS: Objection; hearsay.
THE COURT: Overruled. Next question.
Q. BY MR. MESEREAU: Have you met with any prosecutor to talk about your testimony
today, before today?
A. Yes.
Q. Who did you meet with?
A. The prosecutor right here.
Q. And is that Mr. Auchincloss?
A. Uh-huh. Thats correct.
Q. When did you meet with him?
A. When?
Q. Yes.
A. This morning.
Q. And where did you meet?
A. We meet in the witness room.
Q. Did he show you any documents?
A. Yes.
Q. What documents did he show you?
A. The documents that was shown here on the screen.
Q. Now, are you aware of an art icle appearing in The Globe newspaper on September
21st, 1993, that quotes you?
A. No. I never saw it.
Q. Never h eard about it?
A. Never.
Q. Are you aware of that article quoting your wife?
A. No.
Q. Okay. So you never heard about that or looked at it, right?
A. No.
Q. Okay. No one ever told you about it, right?
A. No. My friends dont read that kind of newspapers.
Q. Okay. All right. Before you took the stand today, had you ever heard that you were
quoted in an article about Michael Jackson in The Globe newspaper?
A. No.
Q. How many times have you been interviewed by anyone with the sheriffs department
on this case?
A. Just one time in 93 or something.
Q. Just one time?
A. Yeah.
Q. Have you had many phone conversations with anybody from the sheriffs department
about the case?
A. No, not that I recall.
Q. Has anyone ever called you on the phone from the prosecution to talk about the case?
A. No. Just to tell us that we are going to be in court. Thats all.
Q. Now, when d id you last talk to Norma Stakos?
A. The last day that we left the ranch, Neverland.
Q. Did you sue her as well?

A. No.
Q. You just sued Mr. Jacksons company, right?
A. We sued Michael just for the overtime that we -- were owed to us.
Q. Thats over a seven-month period?
A. Seven months what? Im sorry, after -- after we left in -Q. Yes.
A. I guess. I dont recall.
Q. Did you say you hadnt been ever paid for overtime while working at Neverland?
A. Thats correct.
Q. All right. And was that over a seven-month period or nine-month period? I cant
remember.
A. Nine, ten, something like that.
Q. Okay. Had you ever made a claim for overtime while you were working?
A. Yes, we did. We settled with Norma at the time we left. She said she was going to give
us money for the overtime and give us good references. And we sued when she didnt fill
up the part that she said she was going to do.
Q. You felt she was obligated to give you and your wife a good reference for another job?
A. Why not?
Q. What if she didnt think you were competent?
MR. AUCHINCLOSS: Objection; relevance.
THE WITNESS: She said she would do it. She said she was going to give us a good
reference.
THE COURT: Just a moment. Just a moment. The objection is sustained.
Q. BY MR. MESEREAU: You felt that part of your agreement with Mr. Jacksons company
was that if they were contacted by anyone and asked if you were someone you should
work with, they had to give you a good recommendation; is that correct?
A. No.
Q. And you never called the police about what you claim Mr. Jackson did to Mr. Culkin,
right?
A. Thats correct.
Q. Now, you indicated you were asked to sign a document saying that a woman named
Bianca looked inside someones purse, right?
A. Thats correct. I was not, myself. My wife was.
Q. Thats Blanca Francia, right?
A. Yeah.
Q. Did you know her when she worked at Neverland?
A. Yes.
Q. Was she a friend of yours?
A. We didnt have any friends. We couldnt have any friends at the ranch. It was fo rbidden
to be friends with the help. Because everybody was spying on each other, so there was no
way to be friends with anyone.
Q. The spying was because people were looking for stories to sell, right?
A. No, because I think thats -MR. AUCHINCLOSS: Objection; argumentative.
THE WITNESS: Thats not true.
MR. AUCHINCLOSS: Ill withdraw the objection. (Laughter.)
Q. BY MR. MESEREAU: Are you saying its your wife that saw Blanca Francia go into

someones purse?
A. She didnt see her doing it. Thats why she didnt want to sign it.
Q. Okay. Did you ever talk to Blanca Francia about whether or not she did put her hand in
someones purse?
MR. AUCHINCLOSS: Objection; hearsay.
THE WITNESS: I never did myself.
THE COURT: I couldnt hear your objection, Counsel.
MR. AUCHINCLOSS: Ill withdraw it.
Q. BY MR. MESEREAU: Did you ever ask Blanca Francia if she ever d id, in fact, go into
someones purse?
A. No, I never ask myself personally.
Q. Did you ever learn that she had admitted doing it?
MR. AUCHINCLOSS: Objection. Argumentative; assumes facts.
THE COURT: Its overruled. You may answer.
THE WITNESS: Im sorry. Say that again, please.
MR. MESEREAU: Ill withdraw the question and reask it.
Q. Did you ever learn that Blanca Francia admitted she had gone into someones purse?
A. I never heard of anything like this, no.
Q. Okay. What hours did you work at Neverland?
A. There was no set hours. It was whenever Michael was in residence or whenever guests
were present.
Q. And where did you live when you were working at Neverland?
A. At the ranch. I mean, at the Neverland itself, in a private house.
Q. Okay. Now, you told the jury that you went to a lawyer and told the lawyer about what
you claim you saw in the arcade, right?
A. Correct.
Q. Was that while you were working at Neverland?
A. After we left.
Q. You didnt go to a lawyer right away to discuss what you had seen, did you?
A. No.
Q. Do you know what this particular lawyer specializes in?
A. General practice.
Q. Pardon me?
A. General practice.
Q. Okay. Had he represented you before?
A. No. He was just a friend.
Q. Had he given advice to you before?
A. No.
Q. How many meetings did you have with this lawyer about what you claim you saw in the
arcade?
A. I think only one time.
Q. You had phone conversations with him, did you not?
A. Yes.
Q. You had phone conversations about the possibility of selling a story, correct?
MR. AUCHINCLOSS: Objection. Cumulat ive; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Approximately when do you claim you saw Mr. Jackson with Mr.
Culkin in the arcade?

A. The time?
Q. Approximately, yes.
A. Maybe three oclock, 3:00 a.m.
Q. No, let me rephrase it. Its my mistake. Approximately what month and year do you
claim you saw this happen?
A. I dont recall.
Q. You continued to work at Neverland after you saw what you claim you saw, right?
A. Yes.
Q. Was your wife working at Neverland as well?
A. Yes.
Q. You never reported this to anyone there obviously, right?
A. No, we didnt.
Q. You never went to Miss Stakos and said, I saw something improper going on, right?
A. We didnt have to do that. She knew about it.
Q. So she was with you watching it?
A. No.
Q. You said that Mr. Baressi tape-recorded you, right?
A. Thats correct.
Q. Do you know how many times he did that?
A. I have no idea.
Q. Did you ever inquire as to how many times you had been secretly tape-recorded by
him? 5491
A. No, I didnt.
Q. Did you ever ask him?
A. I didnt even know he did it until a few days ago.
Q. Who told you he did it?
A. Well, we heard about it from the news and all that, and this information came out, and
so thats how we find out.
Q. I thought you didnt follow the news about the case.
MR. AUCHINCLOSS: Objection; argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you have any idea how many times youve been quoted in any
tabloid about Michael Jackson?
A. I have no idea.
MR. AUCHINCLOSS: Objection; relevance.
THE COURT: The answer was, I have no idea. Ill allow the question.
Q. BY MR. MESEREAU: Would you agree that with time, your story about what you say Mr.
Jackson did has changed?
A. I dont think so.
Q. When you wrote that handwritten statement that I showed you which had your
signature and handwriting, were you being truthful?
A. I dont recall writing this at all, so I have no reco llection of that.
Q. But you did admit that is your handwriting and signature, true?
A. Looks like my handwriting.
Q. Is it your signature?
A. Yes.
Q. Isnt it true, Mr. LeMarque, that in 1993, you waited till you were out of personal
bankruptcy to start selling the story?

A. My personal bankruptcy was about 18, 19, 20 years ago. Had nothing to do with this.
Q. Did you have any bankruptcy proceeding going on in the 1990s, sir?
A. No, sir.
Q. Okay. Never filed a document in that regard, right?
A. No.
Q. Never were involved in a Chapter 7 action?
A. I was. Twenty years ago.
MR. AUCHINCLOSS: Im going to object as improper impeachment.
THE COURT: Sustained.
MR. MESEREAU: I have no further questions, Your Honor.
REDIRECT EXAMINAT ION BY MR. AUCHINCLOSS:
Q. Just a few questions, Mr. LeMarque. The action that you had against Mr. Jackson 5493
for overtime when you left Neverland, did Norma Stakos promise to pay you for your past
overtime?
A. She did.
Q. When you left Neverland, did she promise to make good references for you in the
future?
A. She did.
Q. When you left Neverland, did you ever receive the overtime p ayment that you were
due?
A. She never did.
Q. Did you go to the California Labor Board to dispute that?
A. Yes. Thats where we went.
Q. Did you have to litigate it?
A. No, she settled right away.
Q. MJJ Productions settled right away?
A. Yeah.
Q. Did you get what you felt you were entitled to?
A. Yes. We had the proof that we had worked overtime, so I had account of all the time
we work, so -Q. And as far as Mr. Kessler, was he working for you? Did you ever have to pay him for
helping you with this tabloid business?
A. He was a friend. W e just asked advice, thats all.
Q. So he was just working as a lawyer friend for you?
A. He was -- yeah.
Q. All right. Im showing you Peoples Exhibit No. 802. Appears to be a copy of the
handwritten note. Is that the note that counsel showed you a few moments ago?
A. Looks the same.
Q. Okay. Id like you to read that over carefully. Take a moment. Just one page.
A. Okay.
Q. Okay? Does that represent a fair summat ion of the facts that you observed in the
arcade during that period of time when you observed Macaulay Culkin and the defendant?
A. Yeah, thats basically what I saw.
MR. AUCHINCLOSS: Okay. Id ask to move 802 into evidence at this time, Your Honor.
MR. MESEREAU: No objection.
THE COURT: Its admitted.

Q. BY MR. AUCHINCLOSS: And in that account, do you tell -- do you depict that Mr.
Jacksons hand is in Mr. Culkins shorts?
A. Thats correct.
MR. AUCHINCLOSS: Thank you. I have no further questions.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. If you would -- Does he have the document?
MR. AUCHINCLOSS: Uh-huh.
Q. BY MR. MESEREAU: If you would, please take a look at that document and read it to
yourself.
A. I did already.
Q. All right. Okay. Now, you made two statements: One on September 10th, 1993, and
one on what looks to be -- well, I guess that would be -- you make a second statement in
the form of a P.S., right? Is that made the same day; do you know?
A. Looks the same.
Q. You first -- theres a signature in the middle of the page. It says, Phillip LeMarque,
September 10th, 1993, correct?
A. Yeah.
Q. Theres another signature towards the bottom of the page that says, Phillip LeMarque,
9-10-93, correct?
A. Yeah.
Q. You first wrote a statement about what you saw and then you added a P.S., correct?
A. Yeah.
Q. Lets look at the statement that appears at the beginning, okay? You say that Mr.
Jackson had his left hand in the kids pants, right?
A. Correct.
Q. You say, I couldnt distinguish what he was really doing with his hand, but obviously it
was more than fondling, right?
A. Uh-huh.
Q. You then signed and dated that, true?
A. Correct.
MR. AUCHINCLOSS: Im going to object if hes just reading part of the statement. Id ask
that the entire statement be read before the signature line.
THE COURT: Overruled.
Q. BY MR. MESEREAU: You said up top the child was not disturbed by the action, right?
A. Correct.
Q. You said they were p laying a game, correct?
A. Correct.
Q. You said the kid was very involved with the game, right?
A. Correct.
Q. You said that Michael Jackson was holding Macaulay while he was playing the game,
correct?
A. Correct.
Q. After you signed and dated that statement, you then chose to add something else,
correct?
A. Correct.
Q. And what you add was that His left hand was in his pants under the shorts, left leg, all

the way to the crotch, correct?

A. Correct.
Q. You added that to what you had said earlier after you had signed your name to what
you had said earlier, true?
A. Yeah.
Q. And when was this thing actually -- when was this statement actually done; do you
know?
A. At the same time. It was just an addendum. Clarification.
Q. Why did you want an addendum to what you had already written down and signed?
A. I forgot at the time why I did it. I dont have any other recollection of that anyway.
Q. You did it because you wanted to sell a story, right?
MR. AUCHINCLOSS: Objection; argumentative.
THE WITNESS: Absolutely false.
MR. MESEREAU: I have no further questions.
THE COURT: Do you want to withdraw your objection, or -MR. AUCHINCLOSS: I think so. Sure, why not?
FURTHER REDIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. Was this document prepared for the police?
A. Yes.
Q. All right. And was it prepared after the police interviewed you?
A. Well, it was prepared. I forgot exactly 5498 when, if it was at the same time or after. I
have no recollection.
Q. But the police asked you to write out a statement?
A. A statement of what I saw.
Q. Okay. Do you recall if they asked you to put in the details, some more details as far as
what you had told them?
A. As much as possible, yes. They wanted more details.
Q. Is that why the P.S. was added; do you know?
A. Yes.
MR. AUCHINCLOSS: All right. Thank you. Nothing further.
FURTHER RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Obviously this statement was written out after you talked to Mr. Baressi, true?
MR. AUCHINCLOSS: Objection; vague.
THE WITNESS: I dont think so.
MR. AUCHINCLOSS: Ill object as a vague question as far as time.
THE WITNESS: I dont think so. Im not sure.
THE COURT: Just a moment. You have to wait until I rule.Overruled. Now, read the
question back to him.
Q. BY MR. MESEREAU: The statement was written -THE COURT: No, the court reporter. (Record read.)
THE WITNESS: Its probably after, yeah.
Q. BY MR. MESEREAU: Do you remember I asked you earlier about that statement, and
you told the jury you didnt recall?
A. I have no reco llection exactly, thats for sure. But now its coming back, you know.

Q. Its coming back when the prosecutor suggested you wrote it for the police, correct?
A. No, its coming back -MR. AUCHINCLOSS: Objection; argumentative. Object ion; argumentative.
THE COURT: All right. Just a moment. You need to wait until the question is completed
before you answer.
THE WITNESS: Okay.
THE COURT: And just hold on a second so if someone wants to object, they can. And
counsel needs to not step on his statements. The court reporter is struggling to keep the
record straight. All right. There actually is -- the objection was made after he answered,
so Im going to overrule that objection. You may ask your next question.
MR. MESEREAU: Okay.
Q. You now recall that you wrote the statement in September of 1993 in a police
interview, right?
A. Im starting to recall. See, Im 70 years old this year, and my memory is faltering.
Q. Okay. I understand. Have you now fully recollected that you wrote this for the police?
A. Its coming back a little bit, and I think that, yeah.
Q. Are you sure?
A. Yeah.
Q. Isnt it true you wrote out the statement, you dated and signed it, and somebody
wanted you to add something else, so you put in an addendum, and then signed and
dated that the same day, right?
MR. AUCHINCLOSS: Objection; asked and answered.
THE COURT: Overruled. You may answer.
THE WITNESS: I dont recall very well when I made this statement, when I wrote it, and I
dont recall why there was an addendum added to the statement.
Q. BY MR. MESEREAU: Okay. And the statement was written approximately how long after
you left Neverland?
A. Whenever the police came, which might be a year after or two years. I dont know.
Q. Well, the statement says September 10th, 1993 -A. Okay. So -Q. -- right? And how long -- how much time had elapsed between your leaving Neverland
and September 10th, 1993, if you know?
A. Probably a year. A little more than a year.
Q. And how much time had elapsed between when you saw what you claim you saw in the
arcade and September 10th, 93?
A. 14 months. 12, 14 months.
MR. MESEREAU: No further questions.
MR. AUCHINCLOSS: Nothing further.
THE COURT: All right. Thank you. You may step down. Call your next witness.
MR. SNEDDON: Your Honor, because of some of the Courts rulings this morning, we have
no further witnesses at this time.
THE COURT: Are you trying to tell the jury they have to go home early today?
MR. SNEDDON: Unfortunately, I am, Your Honor. I apologize for that from the bottom of
my heart.
THE COURT: Thats the bad news. (Laughter.)
THE COURT: You know, I have some photographs of the wildflowers that I took.
(Laughter.)
THE COURT: All right. I can tell youre not interested. Well release you early today. Its -

- I think its been a pretty intense week. It doesnt hurt to get a little time off here. Let me
just remind you of the seriousness of your conduct and the admonitions that Ive made.
The admonitions are that you cant talk to anybody about this case, includ ing each other,
your family members, or anybody. You certainly cant go to anyplace where the events
that you hear about testified to occurred or are alleged to have occurred. You are not to
listen to or read news accounts or watch T.V. concerning the case. And, you know, I dont
think I should need to remind you of this, but I will, just so that I have a clean conscience.
Everybody is watching you, you know. Your behavior, just as my own behavior, is under
scrutiny, just as these attorneys behavior. Everything that happens is reported one way
or another. So please be very serious about the responsibility that youve been given
here. And having that in mind, I would like you to go out and look at the wildf lowers
(Laughter.)
THE COURT: Thank you. And Im going to stay with the attorneys. Theres a couple of
issues that we need to take up, but youre free to go. See you Monday at 8:30. And
remember, Tuesday afternoon youll be off, too.

PROCEEDINGS HOLD IN OPEN COURT OUTSIDE THE PRESENCE AND HEARING OF

THE JURY
MR. MESEREAU: Your Honor, can Mr. Jackson depart, or is he -THE COURT: Listen, the audience may leave if they want to. The Court is going to take
up a couple of motions that have been pending. But anyone in the audience that would
like to leave at this time, feel free to do that. Mr. Jackson, if you would like to leave at this
time, you may do so.
THE DEFENDANT: Thank you.
MR. SANGER: Thank you, Your Honor.
MR. MESEREAU: Thank you.
THE DEFENDANT: Thank you.
THE COURT: All right. During the last week or so, there have been some motions that
have been pend ing. We have -- the first one is defendants motion for a mistrial, or, in the
alternative, restrictive instructions. Ive read and considered 5504 the points and
authorities. Do you wish to be heard?
MR. SANGER: Just briefly, Your Honor.
THE COURT: Now, just because you havent said anything all week -- go ahead. I know
its just been building up and -MR. SANGER: Ill try to behave myself, Your Honor.
THE COURT: All right.
MR. SANGER: The serious matter is, and we did brief it, but it was very brief, because it
was an overnight, sort of a pocket thing.
THE COURT: Very good brief.
MR. SANGER: The briefer the better, I gather. The point being, though, that the lawyers
have to exercise control over the witnesses. They have to admonish the witnesses
properly. It is true a witness can do something contrary to the admonitions. This just
happened to be a series of witnesses who all seemed to have done the same thing with
each other, which is call each other either before or after their testimony. And there were
two particularly egregious instances of witnesses calling immed iately after their testimony

was over to discuss their testimony with the upcoming witness, and that was Miss
Palanker calling Mr. Masada, and then Dr. Katz calling Mr. Feldman. And that seemed to
be such an egregious breach -- there had already been notice of this with the witnesses
talking to each other, Dickerman and Katz, and -- Im sorry, Palanker and Masada, and by
the time we got to Dr. Katz calling Mr. Feldman, it seem to me that that was just too
much. And anybody whos managing these witnesses and preparing them to come in here
should have had a very large shot fired over their bow by virtue of this conduct and should
have ad monished their witnesses. So I feel that it does taint their testimony when you
have two people who are crit ical witnesses, according to the prosecution, like Dr. Katz and
Mr. Feldman, for instance, who are talking about testimony that very seriously impairs the
integrity of the process that the Court is trying to preserve. And therefore, we feel that a
mistrial is the only appropriate remedy. How can the jury otherwise consider this evidence
as it should have been presented without being tainted by other witnesses? If the Court
were to deny that, then we did propose a curative instruction, and we would ask the Court
to take that action at the very least. Thank you.
THE COURT: Whos speaking on behalf of the D.A.?
MR. SNEDDON: Judge, we filed a response in written form, and I dont intend to go
through it. Its in there. And Ill simply point out that unfortunately if Mr. Sanger -- there
is nothing in this record that shows that they were talking about their testimony in this
case. And particularly in the case of Mrs. Palanker talking to Jamie Masada, it wasnt the
subject of the testimony that was the subject of the conversation. It was the subject of
the behavior of the lawyer that was cross-examining her. And Id submit to the Court
there is nothing improper about what these witnesses have done, nor showing that they
discussed their testimony. Some of the conversations, the one involved a request from
one lawyer to the other as to knowledge of whether or not there had been an attorneyclien waiver and that was post-testimonial. It was an after-the-fact. And it seems to me
that certainly one lawyer has a right, when theyre both involved in a case, to find out
whether there was a waiver or not. Ill submit it on the basis of the other information that
we provided to the Court from the transcripts and the authorities.
THE COURT: The motion for mistrial is denied. The record is clear that there has been
some conversation between witnesses. And Ive asked counsel, both sides, to admonish
their witnesses that -- before and after their testimony, unless theyre excused, that they
are not to discuss -- well, what Ive admonished is that they are bound by the protective
order before their testimony and after, unless theyre excused. I dont -- in looking at the
record, I dont see evidence that they vio lated the protective order. That exists -- the lack
of that evidence is that neither side pursued it with any detail as to what the discussions
were. But I dont think that would prevent the defense from commenting in their
argument, if they wanted to, about the fact that they had been discussing their testimony
with each other. And whether or not Ill give a special instruction on that Ill put off until
we decide all of our instructions. Im not leaning in the direction of giving a special
instruction in view of the lack of evidence that there was specific conversations about their
testimony, but I also am not willing to say I wont give that, and we still have a long way
to go in this trial and a lot of witnesses in front of us. So Ill take that issue up on a
discussion, Mr. Sanger, on the -- on whatever -- you may submit the same or different
instructions when you submit your final instructions. And that will be my ruling on that.
The next item would be the D.A.s request for mandatory judicial notice of statutes.
MR. AUCHINCLOSS: Theres a discussion as to whether or not counsel is prepared on t his.
MR. SANGER: Hold on. You dont need to -- unless were addressing the Court, we dont

need to have that....

THE COURT: You know, I can just cut this short.
MR. AUCHINCLOSS: Thats fine.
THE COURT: I dont think Im going to give any instruction on this at this time. Whether or
not Ill give it in the final group of instructions will depend on our discussions at that time.
MR. AUCHINCLOSS: Okay. I guess our request is just based upon the fact that there has
been numerous questions asked and numerous answers given concerning these areas of
the law, and I do think its important that the jury does ultimately understand the letter of
the law, particularly with regard to the recording, the surreptitious recording of
conversations, and that it is legal for police officers to surreptitiously record conversations.
So I dont mind addressing that when we get into instructions, but we will be making that
same 5509 motion at that time.
THE COURT: You may submit those. I dont think its a time to give special instructions on
that. I do give some instructions as we go along. I dont think these are ones that I would
give at this time. And Mr. Sanger, thats, I assume, satisfactory with you?
MR. SANGER: Yes, Your Honor.
THE COURT: The motion to prohibit testimony of 1108 witnesses for failure to comply with
Penal
Code Section 1054.7, do you wish to address that?
MR. SANGER: Well, I think the Court is taking this up now one at a time.
THE COURT: I am.
MR. SANGER: And so as long as the Court is cognizant of that, I dont think we need a
ruling right now. But we are confronted with a number of witnesses for whom we have not
received reports until the very last second, and its causing a problem. Its caused a
problem today.
THE COURT: All right. The next one is the objection to admission of 1108 and 1101
evid ence. And I feel that was adequately argued back when we were arguing about
whether or not I would allow the 1108 and 1101 evidence, and I dont see that any new
issues have been raised there, so Ill deny that objection. Its made a matter of the
record, which is what I think you intended there. In my counting of all the things that
were pend ing that are still out there, that would only leave one thing thats still out there
that hasnt been dealt with, which was the supplemental declaration that Id asked for
from Miss Yu, which she provided me with, Im sure she provided you with. This is a
matter of statutorily sealed declarations. And I still have -- Im still dealing with that. Im
not prepared to hear anything further on it. And Im not prepared to make any rulings on
it. Thats not something Ive had time to deal with, but I just wanted everyone to know
that I know thats still out there. And then I was going to ask you if there is anything else
that I dont have on my list.
MR. SNEDDON: Judge, the only thing that I have -- well, the only thing I have is if I could
ask the Court, do we have some kind of an update with regard to the computers, the Brad
Miller computer and the Evvy Tavasci computer? And I say that to the Court because Im
estimating that were getting -- not close, but I can see the light at the end of the tunnel
with regard to us resting our case, and wed certainly like to have access to that
informat ion before we do.
THE COURT: December or January, something like that?
MR. SNEDDON: I think the lights a little bit brighter than that, Judge.
THE COURT: Okay. I wish -- you know, the person whos been helping me with that has
been Jed, and he doesnt -- I have not been updated, so I cant update you. Does counsel

have any informat ion?

MR. SANGER: The information that we have is that as of, I would say, weeks ago, if not a
month ago - thats off the top of my head - but I believe we provided everything we were
requested to provide maybe two months ago. And I think what happened next is he was
making addit ional inquiries based on the particular narrowing of the request by the District
Attorney, but I have not heard anything further.
THE COURT: Do you know what -MR. SNEDDON: Judge, I have a little different recollection.
THE COURT: Okay.
MR. SNEDDON: Its not different, its just maybe updated. As I recall the last time that we
talked, they had actually done the -- Mr. Roden had actually gone through, I believe it
was - I may be confused about this - one of them. He had gone through and actually
sorted out what the various types that he thought may or may not be privileged and that
those were going to be submitted to the Court. And that he was in the process of doing
that to the other computer. I dont really need an update today, but if maybe on Monday
we could have Mr. Beebe here and get an update with regard to where we stand on that
process, that would be helpful, probably, to both sides.
THE COURT: Well do that.
MR. SNEDDON: That would be fine with me. I just wanted to keep it on the radar screen
for you,
Your Honor.
THE COURT: Ill ask him about that today, and no later than Monday well address it.
MR. SNEDDON: Thank you.
THE COURT: All right. Yes?
MR. ZONEN: The Court has four different SDT returns in the Courts possession from Talk
America, from Varig Airlines, from Vons, and from Santa Ynez High School. Ive consulted
with Mr. Mesereau and Mr. Sanger. We are going to agree that those materials turned
over to the Court in obedience with those subpoenas can be turned over to the District
Attorneys Office. And we will make copies for both of us and immediately return it to the
Court.
THE COURT: Is that your agreement?
MR. SANGER: Yes, Your Honor.
THE COURT: All right. Ill approve that agreement, and you may co llect those items.
MR. ZONEN: Thank you very much.
THE COURT: Thank you. All right. Then anything else?
MR. OXMAN: Your Honor, theres also some SDT returns from the defense.
THE BAILIFF: Cant hear you.
MR. OXMAN: Theres some SDT returns from the defense. Just like permission to copy
them.
THE COURT: They are subpoenas that come within the area that only you are allowed to
see?
MR. OXMAN: Correct, Your Honor.
THE COURT: All right. Had you sought permission to copy them? Is there a problem, or -MR. OXMAN: No, I dont think theres any problem. Just wanted to clarify it and make
sure.
THE COURT: Okay. Thank you.
MR. OXMAN: All right.

MR. ZONEN: W ell agree that our copy can be turned over to us under seal.
MR. OXMAN: Well remain silent, Your Honor.

2005 April 11 (Day 29) Testimonies B. Jones,S. Brown, D. Swingles & J. Chandler

BOB JONES EXAMINATION

DIRECT EXAMINATION BY MR. AUCHINCLOSS:

Q. Mr. Jones, in your employment history, have you ever worked for Michael Jackson?
A. Yes.
Q. And is he the man seated to my right with the long black hair?
A. Yes, he is.
Q. What did you do for Michael Jackson?
A. I was vice-president of communications and community relations.
Q. And when did you begin working in that capacity for Mr. Jackson?
A. 1987.
Q. Can you tell me a little b it about what that title involves in terms of work?
A. Dealing with the media, and the commun ity, and various other assignments.
Q. Such as?
A. Whatever came up. Getting -- arranging to get awards, arranging for coverage in
newspapers, magazines. Assisting in the -- with the fan clubs, et cetera.
Q. All right. Would it be fair to say that you were the man in charge of public relations -A. Yes.
Q. -- for Michael Jackson?
A. Yes.
Q. And how many years did you work for Mr. Jackson?
A. 16 and a half.
Q. And how did your employment come to an end?
A. I received a letter one day saying that, Thank you for your services. Theyre no longer
needed.
Q. Did you ever receive any explanation as to why you were being terminated?
A. That, We were restructuring -MR. MESEREAU: Objection; hearsay.
THE WITNESS: -- and going in a different direction. That was in the letter.
THE COURT: Just a moment. Just a moment, please.
THE WITNESS: I dont know what youre saying.
THE COURT: All right. Im going to overrule the objection, but Ill limit the examinat ion in
that area.
Q. BY MR. AUCHINCLOSS: All right. As far as your understanding as to why you were
being terminated, can you tell us what you believe to be the reason why you were being
terminated?

A. Well, I can only cite the letter that I received.

MR. MESEREAU: Objection. No foundation; and irrelevant opinion.
MR. AUCHINCLOSS: Ill rephrase it.
THE COURT: All right.
Q. BY MR. AUCHINCLOSS: Were you informed as to the reason for your termination with
Michael Jackson as his man in charge of public relations?
A. No, because at all times -MR. MESEREAU: Objection; nonresponsive.
THE COURT: Ill allow the answer, No.
Q. BY MR. AUCHINCLOSS: All right. So you were never g iven an explanation as to why
you were being terminated?
A. At all times -Q. Thats a yes or no, question, sir.
MR. MESEREAU: Objection; nonresponsive.
THE COURT: Overruled. The question was,All right. So you were never g iven an
explanation as to why you were being terminated? Is that true?
THE WITNESS: The letter, yes. The letter. Thats all I can say.
Q. BY MR. AUCHINCLOSS: Okay. Now, one thing we have to be careful about in the
question and answer of your examination is we have to be careful we dont talk over each
other, so the reporter can get everything down.
A. Okay.
Q. And you have to be careful just to answer the question thats asked. All right?
A. Okay.
Q. Thank you. So I believe you testified you were terminated late in 2004; is that correct?
A. Yes.
Q. And since that time have you had any emp loyment?
A. No.
Q. Have you been invo lved in any activity at this time concerning -- during that period of
time since your termination that concerns your years of employment with Michael
Jackson?
A. Yes.
Q. What is that?
A. I went to the State of California and filed a comp laint for my vacation pay.
Q. All right. Other than that, have you been involved in the writing of any memoirs of your
years with Michael Jackson?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled.
THE WITNESS: Is it -THE COURT: You may answer.
THE WITNESS: Yes.
Q. BY MR. AUCHINCLOSS: And can you specifically tell me what youve been doing in
terms of writing those memo irs?
A. Preparing a book.
Q. Preparing a book?
A. Yes.
Q. And what is the subject matter of that book?
A. My -- well, my years and -- my years with Michael Jackson.
Q. During your years of working with Michael Jackson, did you have occasion to spend

time with him personally?

A. Seldom.
Q. Who was it that hired you?
A. Michael Jackson.
Q. Personally?
A. Yes.
Q. And did you ever travel with him?
A. Yes.
Q. On how many occasions?
A. I think on three tours, and perhaps on special occasions for events that I had arranged,
such as the World Music Awards.
Q. Where was the World Music Awards?
A. Monaco.
Q. In Europe?
A. Yes.
Q. And when was that?
A. Now, I cant tell you an exact date. Im not good on dates.
Q. All right. Can you approximate? 5526
A. I would say approximately 92.
Q. How long did that trip take?
A. The trip probably lasted about ten days.
Q. And did you travel with Mr. Jackson to Monaco?
A. Yes.
Q. Did Mr. Jackson bring any guests with him on that trip?
A. Yes.
Q. Who?
A. Jordie Chandler, his mother June Chandler, and her sister -- his -- Jordies sister.
Q. Did you personally see Mr. Jackson and Jordie Chandler together during that trip?
A. Of course.
Q. How often?
A. We -- well, whenever I saw one, I saw the other.
MR. AUCHINCLOSS: If I may approach, Your Honor.
THE COURT: Yes.
Q. BY MR. AUCHINCLOSS: Mr. Jones, I show youPeoples Exhibit 776. Can you identify
that for me, please?
A. Thats Jordie Chandler.
Q. Now, you said whenever you saw Mr. Jackson, you saw Jordie Chandler with him?
A. Yes.
Q. How often would you see Mr. Jackson during that trip?
A. Well, I would say, doo-doo-doo-doo, in Monte Carlo maybe I saw them three or four
times.
Q. Did you travel on the plane with them to Monaco?
A. Most definitely.
Q. Did you travel on the plane with them back to the United States?
A. I -- yes, I traveled on the plane with them from Monte Carlo to Paris, and then back to
the United States.
Q. Did Mr. Jackson attend the World Music Awards?
A. Yes, he did.

Q. Did you see him there?

A. Yes.
Q. Did you ever see Mr. Jackson personally demonstrate any physical affection towards
Jordie Chandler during this period?
MR. MESEREAU: Objection; lead ing.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did you ever see any conduct involving any physical contact
between Michael Jackson and Jordie Chandler?
A. Yes.
Q. How often?
A. On the flight back from -Q. The question is, first of all, how often did you see this?
A. Well, just the one time.
Q. And you started to talk about the flight back?
A. Well, thats when the -- can I make a correct ion?
Q. Yes.
A. Number one, I saw them together at the awards. And then on the flight back from Paris
to
Los Angeles.
Q. Okay. Were they in physical contact with one another at the awards?
A. He sat -- yes.
Q. And can you describe -- were they in physical contact during the flight back?
A. They were embraced into one another on -- sleeping on the airplane from Paris to Los
Angeles.
Q. Now, going to the music awards, what was the nature of the physical contact that you
saw with them at the World Music Awards?
A. Jordie sat on his lap.
Q. Where were you seated?
A. I sat a distance away from June, her daughter, and Jordie and Michael.
Q. How many feet away were you when you were observing Mr. Jackson and Mr. Chandler
together?
A. Oh, I would say approximately 20 feet.
Q. And if you would describe for me in detail what you saw at the World Music Awards
involving Mr. Chandler and Jackson?
A. Well, during the performance, he sat on his lap, Jordie sat on his lap. And the sister sat
on the other lap, but at one time Linda Evans took the girl off of his lap and let her sit on
her lap.
Q. Mr. Jones, during the World Music Awards when you were watching Mr. Jackson and
Jordie
Chandler sitting together, did you ever see Mr. Jackson lick Jordie Chand lers head?
A. No, sir.
Q. Have you been interviewed by police officers concerning this matter?
A. Not that I recall.
Q. Didnt you have an interview with Steve Robel and your attorney and myself last week
in the victim/witness room -A. Yes.
Q. -- concerning this incid ent?
A. Yes, yes, yes.

Q. At that meeting, didnt you tell Mr. Robel and myself and your attorney that you
werent sure if that happened?
A. I was very -MR. MESEREAU: Objection.
THE WITNESS: I was adamant in saying I was not sure that that happened. I could -- I
could definitely say that they were embraced in one anothers arms on the flight, but I
dont recall anything about head licking.
Q. BY MR. AUCHINCLOSS: My question is, didnt you say that you didnt remember that,
but you werent sure whether or not Mr. Jackson licked Jordie Chandlers head?
MR. MESEREAU: Objection. Leading, and argumentat ive, and misstates the evidence.
MR. AUCHINCLOSS: This is impeachment, Your Honor.
THE COURT: The objection is overruled. You may answer.
THE WITNESS: I might have said that. But I dont recall.
Q. BY MR. AUCHINCLOSS: You dont recall whether you said that?
A. No, I dont recall ever seeing any head licking, and I made that as adamant as I could.
Q. All right. So is it your testimony today that you dont have a recollection of the head
licking -MR. MESEREAU: Objection. Argumentative, and asked and answered, and lead ing.
MR. AUCHINCLOSS: I dont think Ive gotten an answer yet.
THE COURT: Well, you havent got the question out, so go ahead and state your
question.
Q. BY MR. AUCHINCLOSS: Im trying to clarify the state of your memory, sir.
A. Sure.
Q. Is it your testimony today that you do not remember whether or not you saw any head
licking?
A. No. I dont remember having seen any head licking.
Q. Okay. So is it fair to say you were not saying it couldnt have happened?
MR. MESEREAU: Objection; argumentative.
THE COURT: Sustained.
MR. MESEREAU: Calls for speculation.
Q. BY MR. AUCHINCLOSS: Are you saying you just simply do not have a recollection of
it?
MR. MESEREAU: Objection. Asked and answered; argumentat ive; and leading.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Mr. Jones, you said youre writing a book in this case?
A. Sure.
Q. What is the title of that book?
A. The Man Behind the Mask.
Q. What is the complete title of that book?
A. The Man -MR. MESEREAU: Objection. Objection. Hearsay; relevance.
THE COURT: Overruled. You may answer.
THE WITNESS: Oh. The Man Behind the Mask. In all honesty, I dont -- I cant tell you
the subtitle.
Q. BY MR. AUCHINCLOSS: You dont recall the name of your book?
A. No, I dont recall the subtitle. I do know An Insiders View of the Rise and Fall of the
King of Pop. Maybe thats it.
Q. Is the name of your book, Michael Jackson, The Man in the Mirror, An Insiders

Account of the King of Pops Spectacular and Catastrophic Fall from Grace?
THE WITNESS: No.
MR. MESEREAU: Objection. Leading; hearsay.
Q. BY MR. AUCHINCLOSS: That is not the title of your book?
A. The Catastrophic -THE COURT: Just a moment. Theres an objection. Its overruled.
MR. AUCHINCLOSS: All right.
THE WITNESS: Catastrophic Fall was taken out. It was a suggested title and I took that
Catastrophic out. And it isnt The Man Behind the Mirror. Its The Man Behind the
Mask. Maybe one of the suggested titles was that other that I did not approve of.
Q. BY MR. AUCHINCLOSS: Is your book presently at the publisher?
A. It is being edited, but the book is not complete. It is far from complete.
Q. Is your book presently at the publisher?
A. Yes, sir.
Q. Whats the name of that publisher?
A. System, I think. My co-writer handled that end of it.
Q. And your book is currently being edited?
A. Yes.
Q. Has it been accepted by the publisher as a prospect for publication?
A. It has been, but it has not been approved by me.
Q. The manuscript that is at the publisher -- well, let me strike that. Is the book that is
being reviewed by your publisher currently an honest account of your years working with
Michael Jackson?
MR. MESEREAU: Objection. Calls for speculation; irrelevant opinion.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Have you reviewed the manuscript that is at the publishers?
A. I have looked at a manuscript that has not been approved by me.
Q. How many times have you looked at this manuscript?
MR. MESEREAU: Objection; relevance.
THE COURT: Im not sure where youre going with this. Are you -- is it your intent to
impeach him with his manuscript, is that what youre -MR. AUCHINCLOSS: Yes.
THE COURT: All right. The objection is overruled.
THE WITNESS: Perhaps Ive looked at it twice and I have -- I have a co-writer.
Q. BY MR. AUCHINCLOSS: Okay. This manuscript that youve looked at, is it fact or
fiction?
A. Its part -MR. MESEREAU: Objection; no foundation. Theres a co-writer. Its not been approved. Its
being edited by some other people.
MR. AUCHINCLOSS: Im talking about the manuscript hes looked at.
THE COURT: Objections overruled.
Q. BY MR. AUCHINCLOSS: Is this a factual manuscript or is it a fictional manuscript?
A. It is factual to a degree.
Q. To what degree is it factual?
A. Its to a degree, because I -- my co-writer also has included things that I didnt approve
of.
Q. Im going to read to you a quote from that manuscript and ask you whether its factual

or fiction.
A. Sure.
MR. MESEREAU: Objection. Can we approach the bench, Your Honor?
THE COURT: Just a moment. Before you can impeach him with the manuscript, you have
to establish a foundation that he, in fact, wrote this part that you want to impeach him
with. Ill allow you to approach the witness and show it to him, but Im not going to allow
you to read in open court something that may have been written by somebody else.
MR. AUCHINCLOSS: Thats fine, Your Honor.
Q. Mr. Jones, I show you Peoples Exhibit No. 803. It appears to be one page of typed -this is a word-processed document.
A. Okay.
Q. And its dated March 7th, 2005. There are two paragraphs below the exhibit number. If
youd read those two paragraphs, Im going to ask you a couple of questions about it.
A. Sure. Hes one of the young -Q. Just a moment. Just read them silently.
A. Oh. Okay. I did not write this. This I did write.
Q. All right.
THE COURT: So did he show you one he wrote and one he didnt write?
MR. AUCHINCLOSS: Yes. And for the record, he indicated -Q. If Im accurate, Mr. Jones, you indicated the first paragraph in the lower portion of the
page you didnt write, but the second paragraph you did write?
A. Yes.
THE COURT: Is that clear to you which he indicated, Counsel?
MR. MESEREAU: I think so, but Id like to talk to the prosecutor first. I think I understand.
Q. BY MR. AUCHINCLOSS: All right. That second paragraph -- Mr. Jones, that second
paragraph is an account of what you observed at the World Music Awards; is that
accurate?
A. Thats what I observed on the airplane.
Q. Okay. In that paragraph, it states -MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: Its impeachment. And I can show it to you, Your Honor.
THE COURT: The objections overruled.
Q. BY MR. AUCHINCLOSS: It states, I looked at what was going on with the king and the
boy. Who is the king in your -A. The king of pop, Michael Jackson.
Q. All right. Others looked at them rather strange, too. They were holding each other
tight, almost in a romantic sense, cooing. There were pecks on the cheeks and licks on the
top of the head. Those are your words, sir, true?
A. Sir -Q. Thats a yes or no question.
A. Yes, with reservations.
Q. Mr. Jones, did you see Michael Jackson lick Jordies head?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Sustained.
MR. AUCHINCLOSS: If I may approach, Your Honor.
THE COURT: Yes.
Q. BY MR. AUCHINCLOSS: Mr. Jones, I show you Peoples Exhibit 804. It appears to be an

e-mail. Can you identify that for me, please?

A. Its from an e-mail that I sent to Stacy Brown, my co-writer.
Q. The cite -- well, I wont quote, but that is your e-mail address at the top?
A. Yes, yes.
Q. And those are your words?
A. If they were sent by my e-mail, yes, they have to be my words.
Q. You dont dispute that those are your words?
A. No.
Q. And I show you Peoples Exhibit No. 805. If youd identify that for me, please. Also
appears to be an e-mail dated the same date, but the time on it
2 is 22:30:17 EDT. The first one, for identificat ion purposes, 804, is dated -- the time on it
is 19:55:32 EDT. Okay. So showing you Exhibit 805, is that one of your e-mails, sir?
A. Well, theyre both from my e-mail.
Q. All right. You wrote them?
A. Yes.
Q. And in the first e-mail, 804 -MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: Offered as impeachment.
THE COURT: All right. Overruled.
Q. BY MR. AUCHINCLOSS: You wrote -- and this -- first of all, let me ask you, is the date
of this e-mail accurate, October 30th, 2004?
A. I would imagine it is, sir.
Q. In that e-mail, you wrote, Stacy: The licking is going to be important because he did it
in this case, too. Are those your words, sir?
A. Apparently so.
Q. And in the e-mail that was dated the same day just a few hours later, did you write,
Stacy: The stuff with Jordie will b ite him big ?
A. If its -- if it came from my e-mail, I wrote it. But I dont -- that sounds a little strange
from my writing.
MR. AUCHINCLOSS: Thank you. I have no further questions.
THE COURT: Cross-examine?
MR. MESEREAU: Yes, please, Your Honor.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. Good morning, Mr. Jones.
A. Good morning.
Q. My name is Tom Mesereau and I speak for Michael Jackson.
A. Sure.
Q. We havent met before, right?
A. No.
Q. Okay. The prosecutor referred to an interview that you had with Sergeant Steve Robel
and another officer on April 7th, 2005.
A. Uh-huh.
Q. Do you remember that?
A. Yes.
Q. And do you remember you were asked by an officer, Um, did you see Mr Jackson
engage in any head licking in the World Music Awards? And your answer was, No, no,

no, right?
A. Uh-huh.
Q. And then you were asked, Um, did you see Mr. Jackson engage in any head licking of
anybody? And your answer was, Never. Remember that?
A. I recall.
Q. Okay. And what you were not -- when you were dealing with your co-writer and
publisher, you were not under oath, were you?
A. No.
Q. And of course today you are, right?
A. Yes.
MR. AUCHINCLOSS: Objection; argumentative.
THE COURT: Overruled. Next question. He answered that.
Q. BY MR. MESEREAU: The reality is, Mr. Jones, you have repeatedly said you dont recall
seeing head licking on the plane, right?
MR. AUCHINCLOSS: Objection; misstates the evidence.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You dont recall seeing head licking by Michael on the plane with
Jordie, do you?
A. I said it, but it was in the -- it appeared in an e-mail. I said I did not recall seeing it,
but it -- apparently so, because it appeared in an e-mail that came from my machine.
Q. Well, in response to the prosecutors questions, you said you had reservations about
that statement -A. Yes.
Q. -- correct? And what are your reservations about that statement?
A. That I just dont recall exactly seeing that. I truly dont.
Q. And would you agree when youre working with a co-writer and a publisher to prepare
a book about Michael Jackson, theres pressure to make things sensational when you can,
right?
A. Yes.
Q. And your publisher and others want a book that can sell, correct?
A. My co-writer. The publisher wasnt involved in that particular end of it.
Q. Okay. And certainly, having worked with Michael all those years, youve seen numerous
attempts by numerous people to sensationalize aspects of Michaels life, right?
A. Correct.
Q. And if youre writing a book about Michael, there certainly is always a temptation to
sensationalize if you dont watch yourself, right?
MR. AUCHINCLOSS: Objection; argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: How is the book being written?
A. Well, I dont quite understand what youre -Q. Let me rephrase it. Its probably a poor question. You have a co-writer?
A. Thats correct.
Q. Did your co-writer ever work for Michael Jackson?
A. No, but my co-writer knows the family.
Q. Okay. And youre both trying to prepare book about your observations and experiences
in the past, right?
A. Yes.
Q. And the prosecutor asked you some questions about what stage its in, right?

A. Yes.
Q. And is there considerably more editing required?
A. Most definitely.
Q. And is it a long ways from being published as far as youre concerned?
A. As far as I am concerned, and Im supposed to have final approval.
Q. And when you have a co-writer on a book like that -- actually, let me make it more
direct. Does your co-writer have responsibility for preparing drafts that you have to then
review for accuracy?
A. That is correct.
Q. Okay. And is it -- would it be appropriate to say that what the prosecutor showed you
has not been approved for accuracy?
MR. AUCHINCLOSS: Im going to object to any further leading of this particular witness,
Your Honor.
THE COURT: Overruled. You may answer. Do you want the question read back?
THE WITNESS: Would you repeat the question, please?
THE COURT: Ill have the court reporter read it back. (Record read.)
THE COURT: Are you talking about Exhibit 803, Counsel, or not?
MR. MESEREAU: Yes, Your Honor.
THE COURT: You need to show it to him, because hes been shown three exhibits.
MR. MESEREAU: I dont know -- are the exhibits in front of you, Mr. Jones?
THE WITNESS: Exhibits? I dont have anything.
THE COURT: Theyre not up there.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: You may.
Q. BY MR. MESEREAU: Mr. Jones, Im showing you what has been marked as Exhibit No.
803, okay? Do you see that?
A. Uh-huh.
Q. That starts off with a title that you said is not accurate and has not been approved,
correct?
A. That is correct.
Q. And you told the prosecutor you had written the words at the bottom of the page that
refer to licking, right?
A. Uh-huh.
Q. And is it your testimony that you have not approved the accuracy of that statement?
A. That is correct.
Q. Okay. Now, the prosecutor showed you an e-mail that you indicated you think you
sent; is that correct?
MR. AUCHINCLOSS: Objection; misstates the evidence.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Do you see that?
A. Personally I dont think this is in the book, this statement.
MR. AUCHINCLOSS: Ill object as nonresponsive.
THE COURT: I guess its without -- his answer shows me its without foundation. So do
you want to ask a foundational question on that?
MR. MESEREAU: Yes.
Q. Mr. -- well, let me just show you. Im looking now at Exhibit 805, okay? And thats the
e-mail the prosecutor referred to.

A. Uh-huh.
Q. And I think you said you believe you sent the e-mail; is that right?
A. Uh-huh.
Q. And are the words in that e-mail accurate as far as youre concerned?
A. Perhaps they are.
Q. You dont know?
A. Because I wrote -- if it came from my e-mail address, I had to write it.
Q. Okay. And -- but you dont know for sure?
A. No.
Q. And are the words on that e-mail words you intend to include in your book?
A. Not like that. My -- my co-writer is handling that, and I have tried to change certain
things in the way things were said on numerous occasions with him.
Q. Would it be accurate to say that neither Exhibit 803 nor Exhibit 805 are accurate as far
as youre concerned?
MR. AUCHINCLOSS: Objection; misstates the evidence -THE COURT: Overruled.
MR. AUCHINCLOSS: -- as far as to 803.
THE COURT: Overruled. You may answer.
THE WITNESS: Well, I dont know which one -- you got three different things there, dont
you?
MR. MESEREAU: Sure. May I approach, Your Honor?
THE COURT: Yeah.
Q. BY MR. MESEREAU: Showing you Exhibit 803 and Exhibit 805, okay?
A. This is three. This is five.
Q. Yes. Okay? Lets talk about 803. Youve already ind icated the title -- what purports to
be the title is not going to be the title of your book, right?
A. Thats correct.
Q. And youve already indicated that the bottom paragraph that you say you wrote is not
accurate; is that correct?
A. Uh-huh. This I wrote.
Q. Yes.
A. Yes.
Q. But youre indicating its not accurate, true?
MR. AUCHINCLOSS: Objection; misstates the evidence.
THE COURT: Overruled. You may answer.
THE WITNESS: Not completely true as far as Im concerned.
Q. BY MR. MESEREAU: Okay. Lets look at the next exhibit, which is Exhibit No. 805. Do
you see that?
A. Yes. This -- this one is true. Im sorry. Yes. Im sorry.
Q. And you wrote that e-mail, correct?
A. Yes. Yes.
Q. And what you said in the e-mail was, in summary, that you might -- and correct me if
Im wrong, that you thought your knowledge of the Chandlers might be an insurance
policy for you?
A. Uh-huh.
Q. Correct?
A. Uh-huh.
Q. An insurance policy of employment, right?

A. Uh-huh.
Q. And what that means is, I might try and hold over Michaels head what I could say
about the Chandlers, right?
MR. AUCHINCLOSS: Im going to object to counsel ascribing any meaning to those words.
THE COURT: Sustained.
Q. BY MR. MESEREAU: What did you mean by insurance policy of employment?
A. Well, I was not -- I did not have a confidentiality agreement.
Q. Okay.
A. Thats what I -- thats what I basically meant.
Q. And did you also mean that, Because Ive spent all these years with Michael, that I
could almost use as a threat writing an expose of him if Im not employed by him?
MR. AUCHINCLOSS: Same objection. And argumentative.
THE COURT: Overruled. You may answer.
Q. BY MR. MESEREAU: Is that sort of what it means?
A. No, not really, because I have never -- I have never sued, I have never sold stories. I
have never -- in the 16 and a half years, Ive never attempted to extort in any manner.
Q. And Im not saying you did. Im just asking you -A. No, no, I did not mean it in that respect.
Q. Okay. Now, when d id you say your work was terminated?
A. June 9th, 2004.
Q. Okay. And where was your office at the time?
A. In my home.
Q. You indicated in response to the prosecutors question that you didnt see Michael very
often, right?
A. No.
Q. And why was that?
A. This was -- this was Michael Jacksons modus operandi from the very beginn ing. I saw
Michael mostly if we were on a tour that my presence -- if I may explain. I have worked in
the entertainment industry prior to working with Michael Jackson for 17 and a half years,
and I know familiarity breeds contempt. And the further you stay away from artists, the
better off you are.
Q. And for that reason, did you not go to Neverland very much?
A. I went to Neverland when I brought groups up, such as the Challengers Boys & Girls
Club. Such as the First AME Church, et cetera. I was not a regular vis itor at Neverland at
all.
Q. Now, who was the first group that you mentioned that you brought?
A. The Challengers Boys -MR. AUCHINCLOSS: Objection. Relevance; beyond the scope.
THE COURT: Sustained.
Q. BY MR. MESEREAU: In a typical year, while you were employed, how often would you
visit Neverland?
A. I havent been to Neverland in years. My visits to Neverland were on a more frequent
basis about five years ago when I was able to get groups approved to go to Neverland.
Q. Okay. And you had an office located where?
A. Before we closed the offices, we were at 9255 Sunset Boulevard.
Q. Okay. And how many years did you spend in that office?
A. I think we were there approximately ten years, I think. I cannot be for certain.
Q. Okay. Now, you indicated at the music awards, the World Music Awards, that at one

point you saw Jordie on Michael Jacksons lap and his sister on Michael Jacksons lap
together, right?
A. That is correct.
Q. Okay. And where was Michael Jackson sitting in that event?
A. He was seated on the front row next to Prince A lbert of Monaco, and -- on one side,
and Linda Evans, the actress, on the other side. And I attempted to get -- I had arranged
for the Chandlers to sit directly behind Mr. Jackson, because I did not feel that the royalty
wanted to be bothered with those guests. But he insisted that they sit with him, so I left it
alone.
Q. Did the mother sit with Michael Jackson as well?
A. Behind.
Q. Okay. So when you saw the brother and sister sitting on Michael Jacksons lap in the
first row, the mother was right behind, correct?
A. Correct.
Q. So this is the first row in full view of everyone at the awards show, correct?
A. That is correct.
Q. There was no effort to hide anything at any time?
A. No.
Q. At some point, did you see the children with their mother behind where Michael
Jackson was sitting?
A. When I brought them in to their seats, they were seated behind Mr. Jackson. Mr.
Jackson moved them up front.
Q. Okay. Did -- when you say he moved them up front, did he move them into seats up
front?
A. He moved them into his seat.
Q. Okay. Okay. So the children moved into his seat to sit with him?
A. With him.
Q. And the mother still stayed sitting behind?
A. That is correct.
Q. And at some point did you see the children go back with their mother or did they
always stay with Michael?
A. No, they stayed up there.
Q. And I think at one point you saw Jordie still sitting on Michaels lap, and Jordies sister
sitting on Linda Evans lap?
A. That is correct.
Q. Please tell the jury what the World Music 5552 Awards show is.
A. The World Music Awards show is a show thats given annually in Monte Carlo for the
best record sales in -- the best worldwide record sales. I had arranged for Mr. Jackson to
be honored by the World Music Awards, and -- because of his record sales. And we had
gone there for that particular purpose, for him to be honored by the World Music Awards.
And to be seen around the world. And I attempted, because perception is 90 percent of
what the public thinks, to get those people off of his lap.
Q. Did the Chandler family seem to remain during the entire show sitting with Michael?
A. Oh, of course. Yes.
Q. Okay. Now, you -- how did you get to Monaco?
A. We flew.
Q. Did you -- fly from where?
A. Los Angeles.

Q. Okay. And were there other stops on that trip?

A. To Paris. We flew from Los Angeles to Paris, and Paris to Nice, and we helicoptered to
Monte Carlo.
Q. Okay. Do you recall attending any other events with Mr. Jackson on the trip to Monaco?
A. Of course, His Royal Highness Prince Albert hosted a reception for visiting dignitaries,
and I was -- he had an event -- when you go there, they have an event each night for
visit ing dignitaries. And there was only one event that Mr. Jackson attended.
Q. And do you recall whether or not the Chandler family were at that event?
A. They were with him.
Q. And that was because Michael insisted that the Chandler family go?
A. I dont know whether he insisted whether they attend or not.
Q. Okay.
A. But all of his guests were invited.
Q. Okay. Were there any other guests of Michael Jackson that you havent named?
A. No, just the Chandler family.
Q. Okay. Now, did you begin writing your book after your employment ended?
A. I had made notes on certain things. Yes, the actual beginning of the writing of the book
started after my employment ended, yes.
Q. And has there been an effort by you or your co-writer to market the book overseas?
A. Well, I would imagine that the publisher has.
Q. Has there been an attempt to market it in the United States?
A. I would imagine that the publisher has.
Q. Okay. And who is in charge of that issue?
A. My co-writer.
Q. Okay. Now, do you typically meet with your co-writer periodically?
A. We talk on the phone. Thats -- thats perhaps one of the reasons there is some
confusion, because our -- hes based in New York and Im based in Los Angeles.
Q. Okay. And do you sort of fax or e-mail manuscripts to one another?
A. We e-mail.
Q. Okay. And do you then typically correct or change what you think is either inaccurate
or inappropriate?
A. Oh, Ive changed millions of things that were inaccurate that I d idnt say.
Q. And how far away from having a product that you think is accurate and comp lete are
you?
A. I would say six to eight weeks.
Q. Okay. Have you come up with a date during which you intend to announce the
availability of the book?
A. No.
Q. Okay. Do you remember in your interview on April 7th, 2005, a police officer asking
you about whether or not there was any licking on the plane by Michael, and you said, I
just dont remember and I 5555 would be lying to say that I did?
A. Of course I recall saying that.
Q. And that was the truth, right?
A. Yes.
Q. Now, on the plane coming back, do you remember where Jordies mother June was
seated?
A. Sure.
Q. Where was she seated?

A. We were all in first class, and on one side of the rear of first class was Michael and
Jordie Chandler. On the total opposite side was June Chandler and her daughter.
Q. Certainly June and her daughter were in a position to observe Michael and Jordie,
correct?
A. That is correct.
Q. So they were seated parallel to one another?
A. Yes.
Q. Nothing that went on was hidden from anybody, correct?
A. No.
Q. And where were you seated in relat ion -A. I was seated at least two front -- two rows ahead of them.
Q. How many times have you been contacted by any representative of the sheriffs or
police department in this case?
A. Well, I was contacted prior to my registration -- I mean, my being served with a
subpoena. And at one point, a Richard Steingard, I approached him about representation
because he had represented me before in this case, and then he came back and said that
he could not represent me any longer. And thats when Attorney Sachs was contacted. So
I had been -- they attempted to serve a subpoena to me, and at that time I did accept the
subpoena at Richard Steingards office, and following which he informed me that he could
no longer represent me.
Q. Have you ever spoken to any prosecutor for the government in this case directly?
A. Who do you mean, the government?
Q. These people. The prosecutors.
A. Certainly. Ive -- Mr. Auchincloss and Steve Robel.
Q. When did you last meet with Mr. Auchincloss?
A. I met with him on Friday when I was told to go home and come back.
Q. Okay. And did you meet with him before that?
A. Of course. You mentioned an April date that Mr. Auchincloss had me to come up.
Q. Okay. Was that April 7th?
A. I guess, sir. I dont -- Im not good with dates, so -Q. You had an interview with Sergeant Steve Robel, right?
A. And Mr. Auchincloss.
Q. Okay. How many meetings did you have with Sergeant Robel, if you know?
A. I only met Sergeant Robel when I was with Mr. Auchincloss. I met them both at the
same time.
Q. Okay. So when you said, I just dont remember and I would be lying to say that I did,
about head licking, Mr. Auchincloss was right there, right?
A. We were -- we were there, yes, we were -- the three of us were in the room.
Q. So he clearly heard you say that, correct?
A. Mr. Auchincloss was in the room with Mr. Robel.
Q. And he tried to misquote you in court today, correct?
MR. AUCHINCLOSS: Objection. This is argumentative; improper.
THE COURT: Sustained.
MR. MESEREAU: No further questions, Your Honor.
REDIRECT EXAMINAT ION BY MR. AUCHINCLOSS:
Q. Mr. Jones, you told Stacy Brown about this head licking incident, true?

A. Apparently I did, sir.

Q. And you have previously stated that the
words on the second paragraph of Peoples Exhibit 803, which Ive shown you - thats the
quotes from the book -A. Uh-huh.
Q. -- the second paragraph - those are your words?
A. Yes.
MR. AUCHINCLOSS: All right. Your Honor, if I may, Id like to admit -THE WITNESS: With -- with -- may I see that, sir, again?
Q. BY MR. AUCHINCLOSS: Yes, you may.
A. Because -- it may be with exception. Oh, yes, those are my words.
Q. All right. So you agree that those are your words. Your Honor, Id like to admit Peoples
Exhibit 803 into evidence at this time.
MR. MESEREAU: Objection. Hearsay; foundation; relevance.
THE COURT: Let me see the exhibit. All right. The objections sustained. Its not going into
evid ence.
MR. AUCHINCLOSS: All right. May I see that?
Q. But so that were clear today about your testimony, is it true that you looked at what
was going on with the king and the boy, they were holding each other tightly, almost in a
romantic sense -MR. MESEREAU: Objection. Asked and answered; move to strike.
MR. AUCHINCLOSS: I believe theres been -THE COURT: Overruled. Go ahead.
Q. BY MR. AUCHINCLOSS: Ho lding each other tightly almost in a romantic sense, cooing.
There were pecks on the cheeks and licks on the top of the head; is that true, those are
your words?
A. I -- I -- with reservation. I know about the -- as I told you -Q. Im asking you are those your words, sir?
A. They apparently are my words. If you have them in an e-mail from me.
Q. Today your testimony is that, The licking is going to be important, you told Stacy
that, because it happened in this case, too. Those are your words as well?
A. I dont recall saying anyth ing about this case. But if it was in an e-mail, I said it.
Q. You acknowledge that those words -- that this is your e-mail address?
A. B7436@aol -Q. And this is -- you acknowledged this is one of your e-mails to Stacy Brown?
A. Nobody else could have done it but me.
Q. So do you acknowledge, based upon all the information that you have today, that you
did, in fact, see Michael Jackson lick Jordie Chand ler on the top of the head, sir? Yes or no.
MR. MESEREAU: Objection; asked and answered.
THE WITNESS: I guess -- yes.
MR. AUCHINCLOSS: All right.
THE COURT: Just a moment. There was an objection.
MR. AUCHINCLOSS: Sorry.
THE COURT: The objection is overruled. The answer was, Yes.
Q. BY MR. AUCHINCLOSS: And your testimony is that this incident happened on a plane
flying back from Europe?
A. On flying back from Paris to Los Angeles.
MR. AUCHINCLOSS: Thank you. I have no further questions.

RECROSS-EXAMINATION BY MR. MESEREAU:

Q. Mr. Jones, on April 7th, you told the police and Mr. Auchincloss youd be lying if you
said you saw Mr. Jackson licking Mr. Chand ler, right?
MR. AUCHINCLOSS: Objection. Misstates the evidence and argumentative.
THE COURT: Overruled. You may answer. Do you want the question read back?
THE WITNESS: I would say since he -- I have to say it has to be true if it came in my email.
Q. BY MR. MESEREAU: But, sir, you just told the police the other day that youd be lying if
you said he did that, right?
MR. AUCHINCLOSS: Same objections.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Right?
A. I -- I, again, have to say what I said. If its in my e-mail, its true.
Q. But you just told the jury you dont recall seeing something like that, correct?
MR. AUCHINCLOSS: Objection. Asked and answered; argumentative.
THE COURT: Overruled.
THE WITNESS: I go back with the same answer. It was in my e-mail. So if it was in my email, Im taking responsibility for the e-mail.
Q. BY MR. MESEREAU: Well, but youve also indicated a nu mber of the things you wrote
are not accurate, true?
A. I didnt write anything. My co-writer wrote those things. But he is -- he has shown me
an e-mail that I wrote and sent to my co-writer.
Q. But, sir, you just told the jury what you told the police last week, which is that youd be
lying if you said you saw that, right?
MR. AUCHINCLOSS: I believe that misstates the evidence.
THE COURT: Overruled. Is that what -- hes really asking you, Is that what you told the
police? Did you tell the police -THE WITNESS: Yes, that is what I told the police.
MR. MESEREAU: No further questions.
FURTHER REDIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. Mr. Jones, you didnt say, I would be lying if I said that. You said, I would be lying if
I said I remembered that; isnt that true?
A. Yes, I did.
Q. And is it fair to say that based on everything you have before you today, you now
remember the incidents that youve testified concerning the licking?
A. I dont remember. But there is an e-mail which provides explicit evidence that the email came from me.
Q. And you believe your e-mails are true; youve testified to that?
A. I would not have just made it up.
MR. AUCHINCLOSS: Thank you.
THE WITNESS: Okay.
MR. MESEREAU: No further questions.
THE COURT: All right. Thank you. You may step down.

STACY BROWN EXAMINATION

DIRECT EXAMINATION BY MR. AUCHINCLOSS:

Q. What is your occupation, sir?
A. Im -- currently Im an analyst for MS-NBC and Im also an author.
Q. All right. As an author, have you had occasion to collaborate with writers in the
creation of books?
A. Oh, yes, several.
Q. Can you give me an example?
A. Well, in 2002, published by Simon & Schuster, I co-authored the book Blind Faith, a
biography of Stevie Wonder and his mom, Lula Hardaway.
Q. Have you worked in the past to -- collaborated in the past with any members of the
family of Michael Jackson in the creation of books?
A. Yes, I have.
Q. Who would that be?
A. That would be his older sister, Rebbie Jackson, and his brother Jermaine Jackson.
Q. And when I say Mr. Jackson, is he the man seated to my right with the long black
hair?
A. Yes.
Q. Were those -- was there ever any attempt to publish those two books that you just

described?
A. The latter two, Rebbie and Jermaine?
Q. Yes.
A. That I -- there was -Q. Were they published?
A. No, they was not published.
Q. Do you know why not?
A. Well, the last one with -MR. MESEREAU: Objection; calls for speculation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Were those books, either of them, pulled from the publisher
by you?
A. Yes.
Q. Why?
A. At the direction of -MR. MESEREAU: Objection. Relevance; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: May I ask foundation or relevance, Your Honor?
THE COURT: The relevance.
MR. AUCHINCLOSS: All right.
Q. Mr. Brown, did you collaborate with Bob Jones or are you collaborating with Bob Jones
in the writing of a book concerning his experiences as an employee of Michael Jackson?
A. Thats correct.
Q. How long have you been doing that?
A. Since last summer.
Q. How did you meet Bob Jones?
A. I met Bob years ago. He was, of course, working for Michael. I was a reporter for the
L.A. Daily News at the time, and we were covering a story about Michaels -- the birth of
Michaels first child. And I had talked about -- everyone had talked about, everyone in the
media, when they want information or comments from Michael on things that -- like
having a baby.
Q. Who approached whom concerning the writing of this book?
A. Last January during the arraignment here, Bob Jones approached me -- we were both
standing outside that day, and he approached me about writing that book.
Q. And youve worked together to prepare a manuscript?
A. Yeah, we did. And we didnt -- you know, I didnt init ially agree to write the book.
Q. Okay.
A. There was some concerns that I had. I didnt want to -MR. MESEREAU: Objection; nonresponsive.
MR. AUCHINCLOSS: Thats fine.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: So did you originally want to write this book?
A. Not originally, no.
Q. Why not?
A. Well, I knew -MR. MESEREAU: Objection. Relevance; calls for speculat ion.
THE COURT: Sustained.
MR. AUCHINCLOSS: It goes to -- offered as credibility.

THE COURT: The objection is sustained.

Q. BY MR. AUCHINCLOSS: Tell me about the collaboration process with Mr. Jones. How
has this book come together?
A. Well, I interviewed Bob, another writer also interviewed Bob as well, about his
experience, not only with Michael. We have to remember Bob worked with a lot of people
including Lionel Ritchie, Rick James, Barry Gordy, the Jacksons as a family.
Q. Uh-huh.
A. So Michael was -- and Bobs mind was seen as just a small part of his story, but
obviously the publisher wanted more about Michael because he is Michael.
Q. When youre collaborating with an individual in the preparation of a manuscript, are
there -- is there a dialogue with publishers to see what kind of book the publisher will be
interested in?
A. Oh, absolutely.
Q. And do you employ a literary agent to try -A. Yes.
Q. -- and market the book?
A. Yes. And in this particular case, we employed quite a few.
Q. Why is that?
A. Well, Bob has problems trusting people.
MR. MESEREAU: Objection; relevance.
MR. AUCHINCLOSS: I can withdraw that.
THE COURT: All right. Ill strike his answer. You can rephrase the question.
MR. AUCHINCLOSS: Thats fine.
Q. How many agents did you work with?
A. Gosh. Its now -- five now.
Q. And you currently -- are you currently employing an agent?
A. Yes, we are. We are currently employing two.
Q. And what are their names?
A. Neil Gudovitz and Bill Gladstone.
Q. In working with Mr. Jones, how did you communicate with one another?
A. We spoke a lot over the phone. We met in person. And a lot of times, because of the
distance, we e-mailed each other.
Q. And so how would it work in terms of his working with you?
A. What would happen is he would send me an e-mail of a lot of his notes that he had
kept over the years. We would talk about them, and then Id start writing. And I would
send him what I write, and he would have to approve it, and then he would 5569 send it
back with any type of changes that needed to be made, and the changes would be -- then
be made.
MR. AUCHINCLOSS: If I may approach, Your Honor.
THE COURT: Yes.
Q. BY MR. AUCHINCLOSS: Mr. Jones -- or Mr. Brown, I show you Peoples Exhibit 803.
Could you identify those two passages for me?
MR. MESEREAU: Objection to the extent it calls for hearsay.
THE COURT: Overruled. Ill allow him to identify them.
THE WITNESS: By identify, read them?
Q. BY MR. AUCHINCLOSS: No, just identify them. Are those two passages that came
from the book that youre working on with Mr. Jones?
A. Thats correct, yes.

Q. And while Im up here, Im going to show you Peoples Exhibit 804. Can you identify
that for me?
A. An e-mail Bob Jones sent to me.
Q. You personally received that from Mr. Jones?
A. Thats correct.
Q. And an e-mail -A. Thats correct. Another e-mail.
Q. Thats Exhibit 805. Thats one he sent you as well?
A. Thats correct.
Q. Now, for the record, are these complete e-mails or did they have some material?
A. Oh, they had a lot of material.
Q. But this is just a portion of them?
A. Yeah.
Q. All right. Did Bob Jones, during your collaboration with him in the writing of this book,
tell you about an incident in which he observed the defendant, Michael Jackson, lick a boy
by the name of Jordie Chandler on the head?
MR. MESEREAU: Objection. Hearsay; and leading.
MR. AUCHINCLOSS: Offered under 1236.
THE COURT: The objection is overruled.
THE WITNESS: Im sorry.
THE COURT: Just answer that yes or no.
THE WITNESS: Yeah. Yes, he did.
Q. BY MR. AUCHINCLOSS: What did he tell you?
MR. MESEREAU: Objection; hearsay.
THE COURT: Overruled. You may answer.
THE WITNESS: Well, he described an incident, they were going to the World Music
Awards in Monaco, I believe it was. And he talked about how strange it was, because
Jordie had a head full of hair, and he said, I thought maybe it would be more -- you
know, It would be understandable if he had a bald head. But he just couldnt understand
the licking of the head when he had a head full of hair.
Q. BY MR. AUCHINCLOSS: He said he saw Michael Jackson lick Jordies head?
A. Correct.
Q. Those two passages that I showed you in Exhibit 803, did you ever share that
manuscript that contained those passages with Mr. Jones?
A. Oh, yeah. Absolutely. Bob had to approve everything that went to the publisher.
Q. So everything that went to the publisher was approved by Mr. Jones?
A. Thats correct.
Q. And did this -- did those two passages that I just showed you go to the publisher?
A. Oh, yeah.
Q. Did you discuss this issue of the licking incident on more than one occasion?
A. Oh, yes, we did. Do you want me to -Q. Go ahead.
A. Yeah, we did. Beginn ing in, I would say, maybe August or September, he and I
discussed it. And we discussed it with another writer, Dennis love, and also our agent and
the publisher.
Q. Okay. You previously mentioned Neil Gudovitz and Bill Gladstone. Was it discussed with
those two gentlemen?
A. Yes.

Q. And your publisher, who would that be?

A. That would be Select Books.
Q. Okay. Specifically who was this issue discussed with?
A. Well, it was discussed not only with -- well, specifically at Select Books?
Q. Yes. And I mean by Mr. Jones himself.
A. We had -- well, I dont know that Bob discussed it with Select. But we discussed it with
Simon & Schuster and Harper Collins in a conference call that we had. Bob discussed it
with them. They d iscussed the entire -- the entire proposal that we put before them, and
that included that.
Q. All right. This e-mail that I showed you, 804 - Ill show it to you again just so youre
familiar with what Im talking about - references that, The licking is going to be important
because he did it in this case, too. Can you tell me, what was the context of that remark?
MR. MESEREAU: Objection. Relevance; foundation; and calls for hearsay.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: What did you understand he was referring to when he said,
this case, too?
MR. MESEREAU: Objection. Foundation; relevance.
THE COURT: Overruled. Excuse me. Sustained.
Q. BY MR. AUCHINCLOSS: Did you stay abreast of the information in the media during
the writing of this book?
A. Yeah, I had to. Its my job.
Q. Okay. Did you -- did you check the Internet sources of news media?
A. Yeah. I look at different newspapers and news outlets throughout the country, and their
take on whats going on as well.
Q. And on October 30th, 2004, had you ever heard of any kind of licking that had gone on
in the case of People v. Michael Jackson thats presently before the Court?
MR. MESEREAU: Objection. Relevance; foundation; hearsay.
MR. AUCHINCLOSS: In the media outlets.
MR. MESEREAU: Improper hearsay.
THE COURT: I guess Im not sure where youre going with what his knowledge is of this
case, how that relates to what Mr. Jones has said.
MR. AUCHINCLOSS: Whether it had been reported in the media from another source he says he kept abreast of all the media sources - or whether this was the first time hed
heard it.
THE COURT: All right. If youll rephrase the question to relate to the relevance that
youre describing.
MR. AUCHINCLOSS: Okay.
Q. My question is this, Mr. Brown: When Mr. Jones wrote you this e-mail on October 30th,
were you aware at that time that there was an alleg ation of licking in the case involving
Gavin Arvizo and Mr. Jackson?
A. I cant say that -MR. MESEREAU: Objection; foundation.
THE COURT: The objection is overruled.
Q. BY MR. AUCHINCLOSS: All right. Go ahead.
A. I cant say that I was, because I -- when Bob told me, it was the first that Id heard of
the incid ent. He had actually heard it first as it pertains to this case, and thats when -that prompted him to share with me that it was going to be important.
Q. Now, he says in that e-mail, The licking is going to be important because he did it in

this case, too. Was that the first time you heard of the connection between the two -A. Yes.
Q. -- cases? Had he talked to you about the licking before that?
A. We had started discussing -MR. MESEREAU: Objection. Relevance; foundation; hearsay.
THE COURT: Ill overrule the objection. But the question is simply whether or not he
discussed this with you before that e-mail.
Q. BY MR. AUCHINCLOSS: So thats a yes or no.
A. That particular e-mail?
Q. Yeah, before that e-mail.
A. The e-mail, no. The incident, yeah.
Q. Okay, the incident. He discussed it before that e-mail?
A. Yeah.
Q. Has Mr. Jones ever indicated to you a fear of testifying in this case?
MR. MESEREAU: Objection. Foundation; relevance; calls for speculation; move to strike.
THE COURT: Sustained. The objection is sustained. Stricken.
Q. BY MR. AUCHINCLOSS: Was there a period of time when Mr. Jones all of a sudden
began to have a loss of recollection or something of that nature regarding this licking
incident?
MR. MESEREAU: Objection. Leading; calls for speculation.
THE COURT: Ill sustain the objection as the question is too broad.
Q. BY MR. AUCHINCLOSS: Okay. At some time during your collaboration with Mr. Jones,
did he
ever try to deny his recollections about this licking incident?
MR. MESEREAU: Objection. Leading; calls for speculation; relevance; foundation.
THE COURT: Ill overrule the objection. The question should be read back to the witness.
(Record read.)
THE WITNESS: Yeah. He had fuzzy recollections about it, yes.
Q. BY MR. AUCHINCLOSS: Was there
THE COURT: Just a moment. Were going to take our break. (Recess taken.)
THE COURT: All right. Go ahead.
MR. AUCHINCLOSS: Thank you, Your Honor.
Q. Mr. Brown, where we left off, I was asking you about this period of time when Mr.
Jones started to have some failure of recollect ion on the issue of head licking. When did
that -- do you recall when that began or when that started?
A. Its been about a month or so now.
Q. Before that time, how many times had you been involved in a conversation where Mr.
Jones talked about the head-licking incident?
MR. MESEREAU: Objection; relevance.
THE COURT: Overruled.
THE WITNESS: I cant tell you exact number of times, but it was more than a couple.
Q. BY MR. AUCHINCLOSS: Okay. And how would you describe this change in his
recollection, if you can?
MR. MESEREAU: Objection; vague.
MR. AUCHINCLOSS: I can be more specific.
MR. MESEREAU: Relevance.
Q. BY MR. AUCHINCLOSS: My question goes to, was it an abrupt change, or was it
something that occurred over a period of time, or something in between?

MR. MESEREAU: Objection. Vague; relevance; foundation.

THE COURT: Overruled. You may answer.
THE WITNESS: I would say it was more abrupt than anything else.
MR. AUCHINCLOSS: Thank you, Mr. Brown. I have no further questions.
THE COURT: Cross-examine?
MR. MESEREAU: Yes, please, Your Honor.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. How long have you known Bob Jones?
A. The year Princess Diana died. I think it was 97.
Q. Okay. And approximately when d id he tell you he intended to write a book?
A. It was about January, a few months before he was terminated.
Q. And youve been interviewed by the sheriffs in this case, right?
A. Thats correct.
Q. And you told the sheriffs that Bob Jones told you hes broke and he needs to make
some money, right?
A. Thats what -MR. AUCHINCLOSS: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Have you gone through different drafts with Mr. Jones?
A. Yes, I have.
Q. On the issue of head licking, did Mr. Jones tell you at one point he had to make money
on this book because he had financial problems?
MR. AUCHINCLOSS: Objection. Hearsay; argumentative.
THE COURT: Overruled. You may answer.
THE WITNESS: He didnt -- Mr. Mesereau, he didnt tell me that in relation to the head
licking. That never came up in discussions of money.
Q. BY MR. MESEREAU: But he told you hes broke and has to get paid for this book,
correct?
MR. AUCHINCLOSS: Objection. Hearsay; argumentative.
THE COURT: Overruled. You may answer.
THE WITNESS: When we first started the book, he said he needs the money. He was just
fired.
Q. BY MR. MESEREAU: And he said he was broke, right?
A. Yes. Thats correct.
Q. You told the police you said he was broke, right?
A. Thats correct.
Q. Okay. Now, how did -- how did the -- let me rephrase that. Obviously at some point
you met with Bob Jones about writing a book, correct?
A. Thats correct.
Q. And where did you meet with him?
A. Well, as I said earlier, he first approached me here at the court, back during the
arraignment.
Q. And did he tell you then he wanted to write something?
A. Thats correct.
Q. And thats before he -A. Thats before his termination.

Q. Okay. And how long before his termination was that, do you think?
A. Well, it was January, so -- the termination was in June. So four, five months.
Q. And did he tell you he was doing it secretly?
A. Well, he didnt say secretly, but he said -- obviously any process with a book, you dont
want everyone to know this is what you are doing. I did, however, myself, tell members of
the family, to get their thoughts on it, because that was my concern, what their thoughts
may be with me doing a book with Bob Jones with -- chiefly it had to be about Michael
Jackson.
Q. Okay. Now, did Mr. Jones tell you he was talking to anyone from the sheriffs
department?
A. Not at that time, no.
Q. When did you first learn that he had spoken to anyone from the sheriffs department?
A. I believe they first contacted him in December of last year.
Q. And based on the prosecutors questions to you, you must have learned at some point
that Bob Jones was saying he couldnt really remember seeing any head licking, right?
MR. AUCHINCLOSS: Objection; hearsay.
THE COURT: Im sorry, I cant read the -THE REPORTER: Learned instead of render.
THE COURT: All right. The objection is Overruled. You may answer.
THE WITNESS: Could you repeat it, sir?
MR. MESEREAU: Ill have it read back. May it be read back, Your Honor?
THE COURT: Yes. (Record read.)
THE WITNESS: Oh, I wouldnt say it was based on the prosecutors -- that. I think it was
simply when I spoke with him, he got a little nervous about that particular vein. I think he
realized that it was going to become a part of this -Q. BY MR. MESEREAU: Well, did you and Mr. Jones discuss the fact that the Arvizos went
to Larry Feldman, the same lawyer who represented the Chandlers?
A. The -MR. AUCHINCLOSS: Objection. Relevance; beyond the scope; and argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Has the name Larry Feldman come up in the book youre writing?
MR. AUCHINCLOSS: Same objection.
THE COURT: Overruled. You may answer.
THE WITNESS: Not by name, but certainly by title and by inference. Bob did say, based
on his notes back in -Q. BY MR. MESEREAU: Well, just -- you just have to answer the question, okay? Ill get
into that -A. Okay.
Q. -- okay? Does the book concern this case in any respect?
A. I would think in some respects.
Q. And is it your plan to market the book while this trial is going on?
A. Well, it all depends on when its finished.
Q. Has he ever talked to you about when he plans to complete the book?
A. Well, I have a lot of say in that, so weve talked about that, and weve always said we
dont want it to be a rush job, and a lot of people want it to be a rush job. The publisher
wants it to be a rush job.
Q. The publisher wants it to be a rough job -A. Rush job.

Q. -- rush job because you can sell it better while the trial is going on, right?
A. Obviously, if it comes out now, it would probably pique some interest because its Bob
Jones, who, you know, has worked for Michael for so long, and its Michael.
Q. Now, have you discussed the amount of money he might make on the book?
A. No, you know, we -- weve been made promises in the past. We dont listen to that. We
dont even speculate on what can be made. Personally, I just enjoy writing, so, you know,
the money aspect -- I think I do pretty well. Its not a big deal to me.
Q. Do you remember you were interviewed by a Santa Barbara sheriff on December 7th,
2004?
A. Around about, yeah.
Q. And you were approached by Sergeant Robel, right?
A. Uh-huh. Yes, thats correct. Im sorry.
Q. And the purpose of the interview was to talk to you about this alleged head-licking
event, right?
A. Im not sure if that was the purpose of the interview. We talked about various things
back in December, but Im not sure that was the purpose of it.
Q. And do you remember Sergeant Robel wanted to know why you had said that Mr. Jones
told you he saw Michael Jackson kiss Jordie, not lick his head?
A. Well, thats not exactly what -- that I remember Sergeant Robel putting to me. There
was a question another investigator had had about whether I said he -- Bob said he licked
or kissed him, and he wanted me to clarify that.
Q. And you had told the investigator that based on your discussions with Bob Jones, he
had said that Michael Jackson kissed Jordie one time, didnt lick his head, right?
A. No, I didnt say that.
Q. Do you remember you apologized?
A. No, no. What happened -- I apologized if it was confused. But what happened was, I
think the investigator had misunderstood and thats what he was calling to clarify. Thats
one of the reasons why he called, to clarify exactly what I said. He said he didnt
remember if I said licking or kissing.
Q. Let me ask you if this is correct.
A. Sure.
Q. Brown apologized for the mistake. Said he had not realized that he told me he was
kissing as opposed to licking. Does that sound accurate to you?
A. Its probably accurate. But again, as Im explaining to you, I explained to Sergeant
Robel when he asked the question, when he asked me about that, I had told the other
investigator, I think it was Zelis, Im -- Im not sure, but I think it was Paul Zelis, the
investigators name, and I think he was the one who had actually made the mistake or -- I
wont even say mistake. He wanted to clarify, is that what I said.
Q. Why did you apologize to him?
A. Well, I apologized for being polite. I mean, its just a polite thing to do, you know. If I
was wrong, I have no problems apologizing.
Q. Now, youre aware that Mr. Jones has indicated he doesnt remember head licking and
has said hed be lying to say that he did. Are you aware of that?
MR. AUCHINCLOSS: Objection; misstates the evidence.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Youre in the process of writing the section of the book that deals
with this trip to Monaco, arent you?
A. No. No, were long since past that.

Q. Well, Mr. Jones has indicated that he has not approved -A. Everything that has -MR. AUCHINCLOSS: Objection. Argumentative; hearsay as to what Mr. Jones said; and
misstates the evidence.
THE COURT: Its an incomplete question, too.
Q. BY MR. MESEREAU: Mr. Jones has final approval over whats in that book, doesnt he?
A. Absolutely.
Q. Would you agree that the more sensational the book, the better the chance of making
money on it?
A. Well, obviously. I mean, weve been told things that nothing surprises them about
Michael Jackson, so -- but its not our intentions to write a book of scandal, if thats what
youre inferring. Its certainly not mine, and I have to write it. And I have people in h is
family who I happen to love very much who Im not going to disappoint.
Q. Theyre not getting any money from the book, are they?
A. The family?
Q. Yes.
A. Why should they?
Q. Theyre not getting any money from the book, are they?
A. Im sorry to respond in that way. No.
Q. The one who is going to make money is Bob Jones, whos broke, right?
A. We both will.
Q. Youre aware that Bob Jones was very upset when he was terminated, arent you?
A. You know what? To be honest with you, he wasnt upset that he was terminated. He
was upset in which the way Randy terminated him.
Q. Im not sure what that means.
A. Well, Bob had -Q. Referring to Randy Jackson, right?
A. Randy Jackson, Im sorry. Bob had felt hed been loyal to Michael for basically half of
Michaels life, or most of Michaels life, I should say. And to get fired by a messenger, you
know, I felt bad, too. In fact, I had spoke to someone in Michaels family about that. I
said, Thats horrible. But he was just upset in the method. He knew that eventually his
time was going to be up just like everyone elses.
Q. In the draft that you and Mr. Jones have written, Mr. Jones says on at least two
occasions that hes never seen Michael Jackson act inappropriately with children, right?
MR. AUCHINCLOSS: Objection; hearsay.
THE COURT: Overruled. You may answer.
THE WITNESS: Well, if it was the exact -- well, I dont remember the exact wording, but
to sa that he saw him molest anybody, no, it does not say he saw him mo lest anybody.
MR. MESEREAU: I have no further questions, Your Honor.
REDIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. Mr. Jones (sic), I previously showed you Peoples Exhibit 803. Did Mr. Jones approve
those two passages?
A. Yes.
MR. AUCHINCLOSS: Ask to move 803 into evidence.
MR. MESEREAU: Objection. Hearsay; foundation.
THE COURT: Sustained.

MR. MESEREAU: Relevance.

MR. AUCHINCLOSS: Offered as a prior inconsistent statement as to the first passage and
a prior consistent statement as to the second.
MR. MESEREAU: Same objection.
THE COURT: The ruling remains the same.
MR. AUCHINCLOSS: All right. Ask at this time to admit the two e-mails, Your Honor,
Exhibits
804 and 805, into evidence at this time.
MR. MESEREAU: Objection. Hearsay; foundation; authenticity; relevance.
THE COURT: Ill take that up later.
MR. AUCHINCLOSS: Okay.
Q. Mr. Brown, you said that Mr. Jones was complaining about his finances on crossexamination.
A. Uh-huh. Yes.
Q. Is this a frequent complaint?
A. Yeah, hes -- well, yeah, hes made a few complaints about that.
Q. Was there a time when he stopped complaining about his finances during this period of
collaboration?
A. Yes.
Q. Was what -- when -- when he stopped complaining about finances, tell me, was there
any relationship in time to that point and the time in which he started to have this failure
of recollection?
MR. MESEREAU: Objection. Relevance; vague; foundation.
THE COURT: Ill sustain vague.
Q. BY MR. AUCHINCLOSS: Can you tell me approximately when in time Mr. Jones
stopped complaining about his finances?
A. Its been about a month or so.
Q. And when in time did he start to have his failure of reco llection?
A. About a month or so.
Q. Did they -- did both of those coincide in time?
A. I would say so, yes.
MR. AUCHINCLOSS: Thank you. I have no further questions.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Mr. Brown, what I think the prosecutor just elicited is the following: When he was
broke, he said there was licking. And when he didnt have financial problems, he said
there wasnt any, right?
A. Well, if thats how you -Q. Right?
A. -- break it down, yeah, I guess.
MR. MESEREAU: Thank you.
MR. AUCHINCLOSS: No further questions.
THE COURT: Thank you. You may step down.

JUNE CHANDLER EXAMINATION

DIRECT EXAMINATION BY MR. SNEDDON:

Q. I want to go back in time a little bit to around 1992 and 93, okay?
A. Yes.
Q. And are you related in some fashion to Jordan Chandler?
A. Yes. He is my son.
Q. Okay. And were going -- you know, I should have done this before we started.
A. Yes.
Q. You have to lean right into that microphone so everybody can hear what you have to
say. Weve had the same problem with everybody, so its not just you.
A. Okay.
Q. You have a very soft voice, so you keep it up, all right?
A. Okay. I will.
Q. Let me start all over again and ask you again. Are you related to Jordan Chandler?
A. Yes, I am. He is my son.
Q. Do you have any other sons or daughters?
A. Yes, I have a daughter.
Q. And her name?
A. Lily Chand ler.
Q. And how old is Lily right now?
A. 17 years old.

Q. Now, in 1992 and 1993, were you married?

A. Yes, I was.
Q. And to whom were you married?
A. To David Schwartz.
Q. And is David Schwartz the father of either of your children?
A. Yes.
Q. Which one?
A. Lily Chand ler.
Q. And prior to your marriage with David Schwartz, you were married to Evan Chandler,
correct?
A. Correct.
Q. And Evan Chandler is the father of Jordan Chandler?
A. Correct.
Q. What is Jordans date of birth?
A. January 11th, 1980.
Q. And to your knowledge, had -- by the time of the events in 1992 and 93, had Evan
Chandler remarried?
A. Yes.
Q. And do you know his wife or did you know his wife at that time?
A. Yes, I did.
Q. And her name is?
A. Natalie Chandler.
Q. And did they have any other children?
A. Yes, they did.
Q. And the childs name?
A. Nicky Chandler. And Emmanuelle Chand ler.
Q. And at the time of 1992 and 1993, can you give us the approximate ages of those
children?
A. As best as I can recall, seven and four.
Q. And who is the oldest?
A. Nicky Chandler, the son.
Q. Okay. Now, I want to show you some photographs. The first photograph we have thats
marked is 793, the next one is 794, and the next one is 795, okay? The first one, 793, Ill
ask you if you recognize the person depicted in that photograph?
A. No, I do not.
Q. Have you ever seen that person before?
A. Not that I recall.
Q. And I want to show you a photograph marked as 794, or Exhibit 794. Do you recognize
the people depicted in that photograph?
A. Not that I recall.
Q. Neither the top nor the bottom?
A. He might look familiar.
Q. Okay. And the bottom photograph?
A. I dont recall.
Q. And with regard to Exhibit No. 795, do you recognize any of the people depicted in that
photograph?
A. I recall this boy and Michael Jackson.
Q. All right. This boy meaning the person on the far left-hand side of the Exhibit 795?

A. Correct.
Q. And do you recall the boys name?
A. Brett Barnes.
Q. Do you recall where you saw Mr. Barnes, or the child Barnes?
A. At Neverland.
Q. Okay. So with regard to the Photographs 793, 794 and 795, none of those photographs
are pictures of your son, correct?
A. No. No.
Q. I want to show you 776; ask you if you recognize that photograph?
A. Yes, I do.
Q. And who is that?
A. Thats my son.
Q. Your son?
A. Jordan.
Q. All right. Thank you. Your Honor, with the Courts permission, Id like to publish these
just so the jury knows what the witness has testified to.
THE COURT: Yes.
MR. SNEDDON: And were going to do it on the Elmo, Your Honor. So if we could have
that. All right, Gordon?
Q. All right. The photograph thats on the board thats 793 is an exhibit of the child with
the long black hair. And that is not your son, Jordan Chandler?
A. No, its not.
Q. All right. And the next exhibit would be 794. And specifically Im going to direct your
attention to the child sitting on the floor with the arrow drawn up to him. Do you
recognize that child?
A. Barely.
Q. Who do you think that -- when you say barely, who do you recognize -A. I would say its probably a younger photo of the boy above.
Q. And do you recognize who the boy above in that photograph is?
A. I think thats Brett Barnes.
Q. Okay. And the last photo is 795. And you indicated the child on the far left-hand side of
the photograph; is that correct?
A. Correct.
Q. The child with the hat next to Mr. Jackson?
A. Correct. Thats Brett Barnes.
Q. Thats Brett Barnes. All right. Thank you. And lastly, the photograph marked as 776,
youve identified that as your child, Jordan, correct?
A. My son Jordan.
Q. Your son Jordan?
A. Yes.
Q. All right. Thank you. We can have the lights again, Your Honor. Now, Mrs. Chandler, do
you recognize the defendant in this case, Michael Jackson?
A. I do.
Q. And have you been in Mr. Jacksons presence before?
A. Yes.
Q. Now, your son Jordan, did you have -- let me go back in time. Did you have an
occasion where you actually met Michael Jackson?
A. Yes, I had an occasion.

Q. For the first time?

A. Yes.
Q. Would you tell the ladies and gentlemen of the jury, where d id that occur?
A. That occurred at my ex-husbands employment, Rent-A-Wreck.
Q. And where is that located?
A. In W est L.A.
Q. And was -- do you remember about approximately when that occurred?
A. It was in the summer of 92. Late summer.
Q. And were you actually at the -- your husbands place of business when Mr. Jackson
showed up?
A. After he showed up, yes.
Q. Okay. You received a telephone call from someone?
A. Yes, from my ex-husband.
Q. And by the way, your ex-husbands name is what?
A. David Schwartz.
Q. Did you ever take Mr. Schwartzs last name?
A. No, I did not.
Q. So youve always been June Chandler?
A. Ive always been June Chandler.
Q. So you received a telephone call and then you went down to his place of business?
A. Yes, I did.
Q. With regard to your son Jordan, did Jordan go with you?
A. Yes, he did.
Q. Was Mr. Jackson there?
A. Yes, he was.
Q. And do you recall how long you were with Mr. Jackson and Jordan that day?
A. Briefly. Five minutes. Ten minutes.
Q. And did -- was there any information exchanged between you and Mr. Jackson that
day?
A. Yes.
Q. And what was that?
A. I said, If you would like to see Jordie or if he could call you or if youd like to speak to
him, here is our number, and you can give him a call.
Q. And you gave that to Mr. Jackson?
A. Yes, I did.
Q. Now, let me go back in time. Before this meet ing that you had at your husbands place
of business in 1992, had Jordan ever expressed, to your knowledge, some admirat ion for
Mr. Jackson?
A. Oh, very much so, yes.
Q. How did he display that admiration?
MR. MESEREAU: Objection; hearsay.
MR. SNEDDON: I didnt ask for a statement, Your Honor. I asked for a display.
THE COURT: All right. Hes not asking for anything that was said. Do you understand the
question?
THE WITNESS: Would you repeat the question, please?
Q. BY MR. SNEDDON: Yes. How did your son Jordan, prior to this meeting that occurred
at David Schwartzs place of business, express -- display his admiration for Mr Jackson?
A. He had a little sparkly jacket that he would wear to parties. He would have a g love like

Michael Jackson, and dance around like Michael Jackson.

Q. And this was all before he met Mr. Jackson?
A. Before he met Michael Jackson, yes.
Q. Now, after the incident occurred where there was an exchange where you gave Mr.
Jackson your telephone number -- and let me go back and ask you a question about that.
Was the telephone number you gave him your home number?
A. Yes, it was.
Q. Did -- to your knowledge, did Mr. Jackson ever call your son Jordan?
A. Yes, he did.
Q. And do you recall, for the ladies and gentlemen of the jury, approximately what the
time span was from the incident that occurred at your ex-husbands place of business to
the time that Mr. Jackson actually called your son?
A. To the best of my recollection, it could have been a month or two after our first
meet ing with Michael Jackson at Rent-A-Wreck.
Q. Were you actually in the room when Mr. Jackson called?
A. I dont recall being in the room, but I might have been.
Q. Do you recall at some time vis iting Neverland Ranch?
A. Yes, I do.
Q. Do you recall approximately when that occurred?
A. I recall around February.
Q. Of?
A. 1993.
Q. 1993?
A. Yes.
Q. So what I want to ask you is, between the time that Mr. Jackson started calling your
son to the time that you went to Neverland Ranch, can you give the jury some idea of the
number of times Mr. Jackson called your son Jordan?
A. To the best of my recollection -MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. SNEDDON: Were you present in the house when these conversations
occurred?
A. Yes, I was.
Q. Did you sometimes answer the phone?
A. Yes.
Q. And Mr. Jackson was on the line?
A. Yes, he was.
Q. And were you also present in the house during the time to observe the length of the
conversations between your son and Mr. Jackson?
A. Yes, I was.
Q. On more than one occasion?
A. Absolutely.
Q. All right. So based upon your observations and the things that you saw and the things
that you heard, give us an estimate of the number of times, that you know of, that Mr.
Jackson called your son Jordan.
A. I would say eight to ten times.
Q. And with regard to those conversations in which you have personal knowledge of the
length of time, could you give the jury some idea of how long these conversations lasted?

A. It was from maybe ten minutes, to an hour, or an hour and a half. It progressed. It got
longer and longer.
Q. Could you describe to the jury what your sons reaction was to these phone calls?
A. He was excited to hear from him. They were talking about things that interested Jordie,
so, um -Q. In those occasions where you picked up the phone and you talked to Mr. Jackson, did
he tell you where he was?
A. No, he didnt tell me. No.
Q. Now, how is it that you and Jordan ended up going to Neverland Valley Ranch for the
first time?
A. We were invited to go to Neverland, because during those conversations, Michael
Jackson said, Would you like to come to visit? W hen I am finished touring, he was doing
a European tour, I think, he said we can come and visit. And my son was very excited to
be able to go up there and see Neverland.
Q. Now, the first time you went to Neverland, you told the jury it was sometime in
February of 1993. How did you get there?
A. I drove.
Q. And who went with you besides Jordan, if anyone?
A. My daughter Lily.
Q. And at this point in time, how old was Lily?
A. Was seven, I think. Seven or eight.
Q. And Jordan was born in 1980, so he was 13 years old at the time you made the first
visit, correct?
A. 12, 13, yes. Yes.
Q. And do you recall whether it was during the week or on a weekend that you visited?
A. On a weekend.
Q. During the time that you were -- during this first visit, do you recall how many days
you were there?
A. Oh, two nights.
Q. Okay. So two nights and at least two days and possibly a third day?
A. Two nights. There was not a third day.
Q. And where did you stay while you were at the ranch?
A. Guest cottage.
Q. Where did you personally stay?
A. The guest cottages at Neverland.
Q. And was there somebody in your cottage with you?
A. Yes, my daughter and my son.
Q. So Jordan stayed with you and Lily in the same cottage?
A. Yes.
Q. And was this during the entire length of this first visit?
A. Yes.
Q. And while you were at the ranch during the first visit, did you see Mr. Jackson?
A. Yes, we did.
Q. And did you spend time with Mr. Jackson?
A. Yes, I did.
Q. Did you spend a lot of time with Mr. Jackson?
A. Yes.
Q. And when you say, Yes, I did, can you tel us about what Jordan and Lily did?A. We

were all either taking rides on the Ferris wheel, playing video games. Jordie and Michael
were playing video games. I was watching. Lily was playing. We looked at his animals that
he had. Just different things that were at Neverland.
Q. Okay. And I think youve described that as being an amaz ing weekend?
A. Yes. Fun.
Q. Now, during the time that you were there on this first visit, do you recall whether or
not you went with Mr. Jackson to a business called Toys-R-Us?
A. Yes.
Q. And could you tell us about that?
A. I guess it was after hours, after Toys-R-Us closed, and Michael said, Jordie and Lily,
you get to go shopping and buy toys, get toys. So we went and -Q. When you say we went, whos we?
A. Lily and Jordie and Michael and I went. And they had fun. They were shopping and
Michael bought lots of things for them. They picked out stuff, and they were showered
with great presents from Toys-R-Us.
Q. And Mr. Jackson paid for all of that?
A. I -- yes, he did.
Q. You didnt, right?
A. No.
Q. Now, after you left Neverland Valley Ranch after this first visit, did you ever go back to
Neverland Valley Ranch?
A. Yes.
Q. And do you recall how much time elapsed between the first time you went there and
the second time you went back?
A. It could be a week later or two weeks after.
Q. And when you went back the second time, do you recall how you got there?
A. I -- to the best of my recollection, I was picked up by Michael Jackson.
Q. When you say picked up by Michael Jackson, in what form of transportation was that?
A. In his car, limo.
Q. And who else was with you when you got picked up? I mean, from your family. Lets
start that way first.
A. It was Lily, my daughter, and Jordan.
Q. So the three of you?
A. My son.
Q. The three of you went back to the ranch?
A. Right.
Q. Was there anybody else in the limo that you recall with Mr. Jackson?
A. Well -Q. Let me go back and make something clear.
A. Sure.
Q. Was Mr. Jackson actually in the limo himself?
A. Yes, he was.
Q. Now, lets ask the question -A. Okay.
Q. -- was there anybody else in the limo other than Mr. Jackson and the three of you?
A. Yes, there was Brett Barnes.
Q. And do you recall where Mr. -- where the child Brett -- let me ask you this: With regard
to Brett Barnes, can you estimate about approximately what age you felt Brett Barnes was

at this point?
A. 11. 10, 11.
Q. So he was a child?
A. He was a child.
Q. And where was Brett Barnes in the car in relationship to Mr. Jackson?
A. Sitting next to Michael Jackson.
Q. Now, on the second visit you went to the ranch, do you recall how long you stayed?
A. A weekend.
Q. And did you spend time -- did you personally spend time with Mr. Jackson that
weekend?
A. Yes, I did.
Q. Did Jordan spend time with him that weekend?
A. Yes, he did.
Q. And did you see Brett Barnes around there that weekend?
A. Yes. I dont really remember, but yes, he was there, too. Yes, he was enjoying that
time also.
Q. And where did you personally sleep during your stay, the second visit to Neverland
Valley Ranch?
A. Guest cottages.
Q. Where did Lily stay?
A. In the guest cottages.
Q. And where did your son Jordan stay?
A. In the guest cottages.
Q. Now, the guest cottages are all located in one general area, correct?
A. Yes.
Q. Theyre all sort of connected into one building?
A. Correct.
Q. With regard to that building, did you ever see Brett Barnes anywhere around the
building and the cottages?
A. Not that I recall.
Q. Now, how did you get home from Neverland on this second visit?
A. We were driven home.
Q. In a limo?
A. Yes.
Q. Was Mr. Jackson present?
A. I dont recall.
Q. Was there ever an occasion where you went to Disneyland?
A. Yes.
Q. And do you recall when that happened in relat ionship to like either one of these first,
second visits?
A. That could have been that weekend, the second weekend that we were at Neverland
that we went -- instead of going to Los Angeles, we went to Anaheim, to Disneyland. It
could have been that weekend.
Q. And who all went to Disneyland?
A. I remember Jordan, Lily, Michael and I, and perhaps Brett.
Q. Now, did you ever have an occasion to visit Neverland Valley Ranch again?
A. Yes.
Q. And do you remember approximately how much time elapsed between the second visit

and the third visit?

A. It could have been a week. A weekend.
Q. And when you went to the ranch on this third occasion, was Mr. Jackson present?
A. Yes, he was.
Q. And where did you sleep?
A. In the guest cottages.
Q. And where did Lily sleep?
A. In the guest cottages.
Q. And where did Jordan sleep?
A. In the guest cottages.
Q. At some point in time during any one of these three visits to -- these three visits youve
described to the jury, did your son request to sleep in Mr. Jacksons bedroom?
A. Yes -MR. MESEREAU: Objection; leading.
THE WITNESS: -- he did.
THE COURT: Overruled. Next question.
Q. BY MR. SNEDDON: And do you recall during which one of the visits it was that the
request came?
A. Oh, the third visit.
Q. And did you allow him to do that?
A. No, I did not.
Q. Did you notice -- I may not have asked this with regard to the third visit, but you
indicated in at least the first visit that Jordan slept with you in your guest cottage, correct?
A. Correct.
Q. In the second visit, did Jordan sleep with you in your guest cottage?
A. Yes, he did.
Q. And the third visit, did Jordan sleep with you in your guest cottage?
A. Yes, he did.
Q. Did you notice anything with regard to what time of the day or night it was that Jordan
finally came to your cottage to go to bed?
A. I assume it was late, after eleven oclock.
Q. Why do you assume that?
A. Because they were playing all day and all night. And it was a weekend. He did not have
school, so he was allowed to stay up later than 11:00.
Q. During any of your visits to Neverland Valley Ranch, did you ever meet any children
from New Jersey?
A. Yes.
Q. Do you remember their names?
A. Frankie and Eddie.
Q. And with regard to Frankie at this point in time, do you recall approximately how old
Frankie was?
A. Around the same age as Jordan, or maybe younger.
Q. And how about Eddie?
A. I dont recall. I dont know which one is which.
Q. Do you recall their last name at all?
A. Cascio.
Q. And do you remember which one of the visits to the ranch was it that you met Frank
Cascio?

A. No, I dont.
Q. Was there -- was there some point in time when you took a trip with Mr. Jackson to Las
Vegas?
A. Yes, there was.
Q. And do you remember when that trip occurred? Just approximately what month, for
instance?
A. The end of March.
Q. Of 1993?
A. Of 93. Correct.
Q. Excuse me, my allergies are acting up today. How did you get to Las Vegas?
A. By jet, private jet.
Q. And who was with you on the jet?
A. My son Jordan, Lily, myself and Michael.
Q. And when you got to Las Vegas, where did you stay, what hotel?
A. The Mirage Hotel.
Q. And when you got to The Mirage Hotel, do you remember what time of day or night it
was?
A. No.
Q. Do you remember how long you stayed in Las Vegas on this occasion?
A. Two or three nights.
Q. Now, when you got to Las Vegas, did you have -- obviously you had a room -A. Correct.
Q. -- in The Mirage. And who was in your room when you first got there? Who was staying
in your room?
A. Jordan, myself, Lily and Michael.
Q. All in the same room?
A. Correct.
Q. Now, did those arrangements change at any point in time?
A. Yes.
Q. And when did they change?
A. The second night things changed.
Q. With regard to things changed, could you tell me what changed first?
A. Well, there were approximately three bedrooms in that suite at the Mirage Hotel. Lily
and I were staying in one bedroom, Jordie had another bedroom, and Michael had another
bedroom. The second night, they were going to see a performance, Cirque du Soleil
performance.
Q. They meaning who?
A. Jordie and Michael -Q. Okay.
A. -- and Lily and I. It was around 11 p.m. at night, and I got a call from somebody at
Cirque du Soleil saying, Where is Michael? And I said, He should be there with my son.
They said, Hes not here.
A little while later, another call, he still didnt show up. They still d id not show up. And
5617 I -- theres a knock on the door and its Michael and Jordan, and they came back
into the suite. Michael -Q. Now, let me stop you right there, okay?
A. Yes.
Q. About what time is it when your son Jordan and the defendant in this case, Mr.

Jackson, showed up?

A. Well, I think the performance started at 11:00, and I would say Jordan and Michael
showed up around 11:30.
Q. Now, could you describe for the jury Mr. Jacksons demeanor at the time that they
came back to the room?
A. He was sobbing. He was crying, shaking, trembling.
Q. Michael Jackson was?
A. He was.
Q. And what about your sons demeanor?
A. He was quiet.
Q. Now, at that point in time, d id Mr. Jackson tell you why he was upset or crying?
A. Yes.
Q. All right. Tell the jury what he said.
A. He said, You dont trust me? W ere a family. Why are you doing this? Why are you not
allowing Jordie to be with me? And I said, He is with you. He said, But my bedroom.
Why not in my bedroom? We fall asleep, the kids have fun. Boys -MR. MESEREAU: Objection. Nonresponsive; narrative.
THE COURT: Narrative; sustained.
Q. BY MR. SNEDDON: All right. Tell us what - Mr. Jackson said that he wanted your son
to sleep with him in h is bed - what you said to Mr. Jackson.
A. What I said to Michael was, This is not -- This is not anything that I want. This is not
right. Jordie should be able to do what he wants to do. He should be able to fall asleep
where he wants to sleep.
Q. Is this you talking or Mr. Jackson speaking?
A. I was saying this. And Michael was trembling and saying, Were a family. Jordie is
having fun. W hy cant he sleep in my bed? Theres nothing wrong. Theres nothing going
on. Dont you trust me?
Q. All right. How long do you think this conversation lasted between you and Mr. Jackson
over where Jordan was going to sleep that night?
A. I would say 20 to 30, 40 minutes.
Q. So it was a back-and-forth conversation; is that right?
A. Yes.
Q. Do you recall how many t imes during that conversation that Mr. Jackson emphasized
the fact that you didnt trust him?
MR. MESEREAU: Objection; leading.
THE WITNESS: No, I dont recall how many t imes -THE COURT: Just a moment.
THE WITNESS: Im sorry.
THE COURT: Overruled. Go ahead. You may answer.
Q. BY MR. SNEDDON: Go ahead.
A. I dont recall how many t imes.
Q. Was it on more than one occasion?
A. Absolutely, yes.
Q. Was it on many occasions?
A. Quite a few.
Q. Do you remember how many times during the conversation that Mr. Jackson
emphasized to you that you were family?
A. Many times.

Q. Did you at some point in time relent and allow your son to sleep with Michael Jackson
in his bedroom?
A. Yes, I did.
Q. And was it after that discussion on that night?
A. Yes.
Q. Is that the first occasion?
A. Correct.
Q. When you were in Las Vegas, do you remember how many of the nights in Las Vegas
that your son Jordan slept with the defendant, Michael Jackson, in Michael Jacksons
room?
A. I would say two occasions.
Q. Now, at some point in time after you had agreed to let your son Jordan sleep with Mr.
Jackson, were you the recipient of a gift from Mr. Jackson?
A. Yes, I was.
Q. Would you describe that to the jury?
A. It was a gold bracelet, and it was given to me by Michael.
Q. And you say a gold bracelet. Had you seen that gold bracelet in a shop of some kind
before?
A. I had seen it before, yes.
Q. And the brand name on that bracelet?
A. Cartier.
Q. Was it expensive, to your knowledge?
A. Oh, I -- yes, it was.
Q. When was it you received this gift in relationship to having agreed to allow your son to
sleep in bed with Mr. Jackson?
A. I think it was the next evening when we were attending a show, a magic show, by
David Copperfield.
Q. Mrs. Chandler, do you recall after Las Vegas where you went, where you personally and
Jordan went? When you came back from Vegas, where did you go; do you recall?
A. After Vegas, I -- it could be back to Disneyland, back to Neverland, or home. Im not
exactly certain.
Q. Was Mr. Jackson with you wherever it was that you went? Did he go back with you, in
other words?
A. Yes, he did.
Q. And did Mr. Jackson continue to spend his nights with your son in the same room, in
the same bed, from Las Vegas, from that point on?
A. Yes.
Q. Were there other visits to Neverland Valley Ranch after you came b ack from Las
Vegas?
A. Yes, there were.
Q. And were there occasions when your son went up to the ranch where you and Lily did
not accompany him to the ranch?
A. Yes.
Q. Do you remember on how many such occasions?
A. I would say two or three times.
Q. And were there occasions also where you and Lily and Jordan also went up to the ranch
after Las Vegas?
A. Yes.

Q. And on those occasions when you went up to the ranch after Las Vegas, where did you
stay?
A. I stayed in the guest cottages.
Q. And where did Lily stay?
A. In the guest cottages.
Q. And where did Jordan stay?
A. In Michael Jacksons bedroom.
Q. Were there ever any occasions that you recall where you actually, when you got to the
ranch, that you would take Jordans suitcase in andtake it into Mr. Jacksons bedroom and
leave it there?
A. Possibly.
Q. So you knew that he was going to be spending the night with Michael Jackson in
Michael Jacksons bedroom at this point in time?
A. Yes.
Q. Now, were there occasions after you got back from Las Vegas -- let me -- where Mr.
Jackson actually was invited to stay at your residence where you lived at this point in
time?
A. Yes.
Q. Now, what city was it that you lived in at this time?
A. Santa Monica.
Q. Were talking about 1993, in the spring, right?
A. Correct.
Q. Okay. Where did you live?
A. Santa Monica.
Q. And at this point in time, was Mr. Schwartz living with you?
A. No, he wasnt.
Q. So in the household was there anybody besides you and Jordan and Lily?
A. My housekeeper.
Q. And was that a full-time housekeeper?
A. Yes, she was.
Q. 24 hours a day?
A. Yes.
Q. Did she live in the house?
A. Yes, she did. She was a live-in.
Q. Thats what I meant. Sorry. Clumsy question. And during this time, did Mr. Jackson
ever spend the night at your residence?
A. Yes, he did.
Q. And do you recall on how many occasions Mr. Jackson spent the night at your
residence?
A. I would say more than 30 times.
Q. And were some of those occasions on consecutive days or nights?
A. Yes.
Q. And how long consecutively do you think that that occurred?
A. Oh. It could be a week or two at a time.
Q. Where did Mr. Jackson stay in the house?
A. In Jordans bedroom.
Q. Are there more than one bed in that room?

A. No.
Q. I am assuming that Jordan was going to school during this period of time.
A. He was.
Q. So Mr. Jackson would spend the night there. What would happen when Jordan would
go to school? To your knowledge, what did Mr. Jackson do?
A. Michael would leave.
Q. And approximately what time wou ld he return?
A. After Jordan came home from school.
Q. And so was this the routine that was followed during the time that Mr. Jackson was
staying at your residence?
A. Yes.
Q. Did you ever -- have you ever been to Disney World -A. Yes.
Q. -- in Orlando, Florida?
A. Yes.
Q. And have you been to Disney World with the defendant in this case, Michael Jackson?
A. Yes.
Q. And do you remember approximately when it was that you went to Disney World with
Mr. Jackson?
A. I would say in May.
Q. Of 93?
A. Of 93.
Q. And when you went to Disney World with Mr. Jackson, who else went with you?
A. Jordan and Lily.
Q. Do you recall where you stayed?
A. I recall The Grand Floridian was one hotel.
Q. And during the time that -- do you remember how many days -- did you go there on
more than one occasion?
A. Yes, we did.
Q. How many occasions?
A. Twice.
Q. And do you recall what the sleep ing arrangements were on the first occasion?
A. Jordie was with Michael and Lily was with me.
Q. And when you say with Michael -A. In Michaels bedroom.
Q. Now, during the time that you visited Disney World in Orlando, would you describe the
nature of the relationship that was going on, that you observed personally, between the
defendant in this case, Michael Jackson, and your son Jordan?
A. The behavior, you say?
Q. Yeah.
A. The behavior with my son was he was not wanting to be with Lily and I anymore, and
he was just with Michael the whole t ime, and he wasnt too happy. Just -- well, I couldnt - I didnt have any communication with him really.
Q. Was this something that you observed for the first time in Orlando or was this
something that you began to observe over a period of time?
A. It was a period of time, and it gradually happened.
Q. Did you notice any change in your son -A. Yes.

Q. -- Jordan?
A. Yes.
Q. What was the nature of the change?
A. Well, he started dressing like Michael. He started acting withdrawn, sort of smartalecky. Not as sweet as he normally was. And withdrawn. He just didnt want to be with
us, Lily and I.
Q. Had you always been close prior to that?
A. Extremely close.
Q. Do you -- I think you answered this, but just in case, how many days did you think you
were in Florida?
A. Oh, I dont really remember, but its probably more than two nights. Two, three nights.
Q. And after you came back from Florida, do you recall where you went?
A. After that, I think the next trip was to Monaco.
Q. In between the time that you went to Florida and to Monaco, do you recall where you
were -- where you were personally staying?
A. No. I guess home.
Q. Do you remember how much time elapsed between the two trips?
A. Not really, no.
Q. Was it more than a month, more than a week? Obviously it was more than a day or so.
A. Yes. It was a couple -- it could be three weeks.
Q. And during that time when you got back from Florida t ill the time that you left for
Monaco, were you with Mr. Jackson?
A. At times.
Q. And the times that you were with Mr. Jackson, was Jordan with Mr. Jackson?
A. Yes.
Q. And when hes with Mr. Jackson, where did he sleep?
A. With Mr. Jackson.
Q. Do you know somebody by the name of Joy Robeson?
A. Yes.
Q. Do you know somebody by the name of Wade Robeson?
A. Yes.
Q. And do you recall where it was that you met Joy Robeson?
A. Yes, I do. 5628
Q. Where was that?
A. That was at Neverland, one of the visits.
Q. Do you recall when it was that you met Wade Robeson?
A. One of the visits to Neverland.
Q. And do you recall approximately which visit it would have been or what month it would
have been that you met these individuals?
A. It could have been my third visit to Neverland.
Q. Did you meet them on more than one occasion?
A. I met Wade on more than one occasion, yes.
Q. And how many times did you meet Joy Robeson?
A. One.
Q. One occasion?
A. That I remember.
Q. There were occasions when Wade Robeson was there that the mother was not there?
A. Correct.

Q. Now, youve indicated to the jury on at least one occasion, perhaps two, that Brett
Barnes was also at Neverland Valley Ranch?
A. Yes, he was there too.
Q. And did you ever meet Brett Barnes mother?
A. No.
Q. So he was at the ranch by himself also?
A. Oh, yes. Yes, he was.
Q. Did you ever meet a Mr. Robeson, the father?
A. No. No, not that I remember.
Q. Did you ever meet a Mr. Barnes at any point?
A. Not that I remember, no.
Q. So no fathers in the picture?
A. No.
Q. Now, prior to the time that you met Joe Robeson for the first time - okay? -A. Yes.
Q. -- on your visit to Neverland Valley Ranch, did you have a discussion with the
defendant in this case, Mr. Jackson, with regard to some warnings that Mr. Jackson gave
you about Joy Robeson?
A. Yes.
Q. What did Mr. Jackson tell you?
MR. MESEREAU: Objection. Relevance.
MR. SNEDDON: I think its an admission of Mr. Jackson with regard to the relationship
with the boys.
MR. MESEREAU: Relevance and hearsay.
THE COURT: Im not sure what youre trying to introduce. Im searching my memory for
that. I dont know, maybe you should approach with counsel.
MR. SNEDDON: Thank you, Your Honor. (Discussion held off the record at sidebar.)
Q. BY MR. SNEDDON: Mrs. Chandler?
A. Yes.
Q. Okay. Now, you had a conversation with Mr. Jackson, is that correct? 5630
A. Yes.
Q. Now, at the time -- and please do not tell us what was said, but did you subsequently
have a conversat ion with Miss Robeson -A. Yes, I did.
Q. -- wades mother?
A. Correct.
Q. Okay. Now, after that conversation, did you develop any concerns about some of the
things that she had told you?
A. I -Q. I think you have to answer that yes orno. We dont want to get into what she said.
A. Yes.
Q. And with regard to that particular conversation, let me ask you this: Had you been
invited by the defendant in this case, Mr. Jackson, to go on a tour with him, you and
Jordan?
A. Yes.
Q. And where were you invited by Mr. Jackson to go on a tour?
A. I dont know where the tour was going. I guess a world tour somewhere in the
summertime.

Q. Do you know where Miss Robeson, Mrs. Robeson, was from, what country?
A. Australia.
Q. Do you know whether one of the stops on that tour was going to be Australia?
A. I think it was, yes.
Q. Okay. Lets talk a little bit about your trip to France.
A. Yes.
Q. Do you recall approximately when that was?
A. I think the middle of May.
Q. And how did you get there?
A. We flew.
Q. And was it on a charter or a commercial airline?
A. Commercial airline.
Q. And you say we, so could you tell us who it was that you went with?
A. My daughter, my son and Michael.
Q. And when you got to France, where in France d id you stay?
A. Monaco.
Q. And how long were you in Monaco?
A. Approximately four days.
Q. And during the time that you were there, where did your son Jordan sleep?
A. In Michael Jacksons bedroom.
Q. Now, did you ever go into that bedroom?
A. Yes.
Q. And were they in bed together on occasion?
A. On occasion, yes.
Q. Now, during the time that you were in Monaco, did you do any shopping?
A. Yes.
Q. And how was it that you -- well, let me put it this way: Who went shopping with you?
A. My daughter.
Q. You and Lily?
A. Yes.
Q. And how many days did you do that?
A. Oh. One day.
Q. And who was paying for the -A. Michael was.
Q. Im sorry?
A. Michael was.
Q. And how did he arrange that?
A. I think I was given a credit card, his credit card.
Q. So you went shopping in Monaco on Michael Jacksons credit card, you and your
daughter?
A. Yes.
Q. Now, during this trip, did either your son or Mr. Jackson get ill?
A. Yes, they both did.
Q. They had the flu?
A. Yes.
Q. And were they in the room together the entire time?
A. Yes.
Q. And when you went to France, did you go to any other country, any other places in

France, other than Monte Carlo?

A. We also went to Euro Disney outside of Paris.
Q. And do you recall how long you were there?
A. A couple of days.
Q. Again, when you say we, youre talking about Jordan and Lily, and was the defendant
with you?
A. Yes, he was.
Q. And you say you spent a couple of days. Where did Jordan sleep?
A. With Michael Jackson.
Q. Now, do you have a brother?
A. Yes, I do.
Q. Whats your brothers name?
A. I have two brothers.
Q. What are their names?
A. Steven Wong and Dale Wong.
Q. And was there a time when one of your brothers -- where do they live? Lets go that
way.
A. One lives in Los Angeles. And the other lives back east in New Jersey.
Q. And was there a time when you went back east for a family wedd ing?
A. Yes.
Q. Do you remember about what month that was?
A. That was in September.
Q. And do you recall who it was who was getting married?
A. Yes.
Q. Who was that?
A. That was my brother Steve and his wife.
Q. And when you went back for the wedding, what city did you go to?
A. We went to New York City.
Q. And when you went back there, who went with you?
A. My son, my daughter, and myself.
Q. And when you first got there, where did you stay?
A. We stayed in a hotel.
Q. Do you remember the name of the hotel?
A. Yes, The Rega Royal Hotel.
Q. And do you know who made the arrangements for that hotel?
A. Yes, I do.
Q. Who was that?
A. Norma Stakos.
Q. And do you know who Mrs. Stakos is? Had you had prior dealings with Mrs. Stakos?
A. Yes.
Q. On a number of occasions?
A. Telephone conversations only.
Q. And who did she work for?
A. She worked for Michael Jackson.
Q. And so she made the reservations for you at the hotel?
A. Yes.
Q. When did you learn that Mr. Jackson was going to be with you in New York? Before or
after you left?

A. Before.
Q. Do you remember how many days before you learned that?
A. Not really, no. I dont remember.
Q. On the day of the actual wedding, was Mr. Jackson there?
A. No, he was not.
Q. When did he show up in relationship to the wedding?
A. After the wedding.
Q. Do you remember how many days he showed up, how many days later?
A. It could be two days later.
Q. Now, when Mr. Jackson got there, did you see him?
A. That evening briefly.
Q. Okay. Now, had something happened during the time that you were in New York with
your son Jordan before Mr. Jackson arrived which caused some problems in the family?
MR. MESEREAU: Objection. Leading and vague.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes.
Q. BY MR. SNEDDON: What was it?
A. Jordan was spending too much time with Michael. I was getting upset. My brother was
also with me, and he was saying -MR. MESEREAU: Objection; hearsay.
Q. BY MR. SNEDDON: Dont tell us what he said, but -A. Okay.
Q. -- could you describe his demeanor to us?
A. Jordan was not with us. He didnt want to be with us. He was very -- he was sullen.
Q. Now, during this time, Mr. Jackson was not there, correct?
A. Correct.
Q. And to your knowledge, from your own personal knowledge, were Mr. J ackson and your
son Jordan in commun icat ion with each other during this period of time?
A. Yes.
Q. By what method?
A. Telephone.
Q. And the frequency?
A. Often. Often. Long conversations.
Q. And was your brother upset by the situation, too?
A. Yes.
MR. MESEREAU: Objection; leading.
THE COURT: Sustained.
MR. MESEREAU: Move to strike.
THE COURT: Stricken.
Q. BY MR. SNEDDON: Could you describe to the -- describe your brothers reaction to this
situation that was -- that existed between Mr. Jackson and your son Jordan.
A. Yes. My brother was happy for Jordan, but he didnt like that Jordie was just spending
time with Michael and not with his family.
Q. Now, when Mr. Jackson showed up in New York, do you recall where he was staying?
A. Yes, he was staying across the hallway from my room.
Q. And when Michael Jackson showed up, where did Jordan sleep?
A. When Michael Jackson showed up, he slept in Michaels room.
Q. Now, when Mr. Jackson showed up the first night, was there an incident that occurred

in your room?
MR. MESEREAU: Objection; lead ing.
THE WITNESS: My room?
Q. BY MR. SNEDDON: Yeah.
A. Yes, there was an incident.
MR. SNEDDON: You have to wait till the Judge rules.
THE COURT: Overruled. You can answer.
Q. BY MR. SNEDDON: Okay, you can answer now.
A. Yes, there was an incident.
Q. Who was involved in the incident?
A. My daughter Lily -Q. Okay.
A. -- Michael and Jordan.
Q. And when you got back to your particular room, did you notice any damage in the
room?
A. Yes, I did.
Q. And what was damaged?
A. I noticed there was damage in the morning. There were two lamps that were broken.
Q. Now, did you at some point talk to Mr. Jackson about what had happened the night
before?
A. Yes.
Q. And with regard to that conversation, did it invo lve Jordan?
A. Yes, it did.
Q. And did it involve you?
A. Yes, it did.
Q. And did it involve Mr. Jackson?
A. Yes, it did.
Q. And the relationship between the two or three of you?
A. Yes.
Q. Would you tell the jury what the conversation was about?
MR. MESEREAU: Objection to the extent it calls for hearsay.
MR. SNEDDON: Your Honor, this involves the defendant and it involves statements that he
makes.
THE COURT: But thats not the question you asked. Ill sustain the objection. Excuse me.
Sustain the objection.
Q. BY MR. SNEDDON: All right. Lets do it this way. What did Mr. Jackson say about the
situation?
A. Why cant we be a family? Why are you objecting to Jordie staying with me? Why cant
we be a family? Why dont you trust me? He was upset that I wanted my son back; that I
-- I didnt like the situation. It was getting out of hand.
Q. Now, youve told the ladies and gentlemen of the jury that Mr. Jackson had given you a
bracelet at one point in time and that you had gone shopping with Mr. Jackson on his
credit card in Monte Carlo. W ere there any other occasions when Mr. Jackson gave you
gifts?
A. Yes.
Q. What else did he give you?
A. He also gave me jewelry.
Q. And do you recall approximately when tha was?

A. I think it was approximately in June.

Q. And what kind of jewelry?
A. A pair of earrings, a necklace, and a ring.
Q. And where were these items when you first saw them?
A. The boxes were open on my bed in Santa Monica.
Q. At your house?
A. Yes.
Q. Was Mr. Jackson staying at your house at that point in time?
A. Not really. Not really. He was there, in and out.
Q. In and out. Okay. Any other gifts you ever received from Mr. Jackson?
A. Yes, a gift certificate to a store.
Q. And the store?
A. To a store.
Q. Yes. The store?
A. Fred Segal.
Q. Now, to your knowledge, was there ever an occasion where your son Jordan and the
defendant in this case, Michael Jackson, were at your ex-husbands house, Evan Chandler?
A. Yes. Yes.
Q. And do you remember on how many occas ions?
A. I would say one or two occasions.
Q. And do you remember the length of the stays on those occasions that Jordan stayed
there?
A. A few days each time.
Q. So during this period of time you had custody of Jordan, correct?
A. Correct.
Q. Now, you told us, I think, that there were two trips to Florida?
A. Yes.
Q. Do you remember when the second trip was?
A. After June. July, early July possibly.
Q. And do you recall how long you stayed there on that occasion?
A. I would say two or three nights.
Q. And where did Jordan sleep on those occasions?
A. With Michael.
Q. Did Lily go with you on that trip?
A. Yes, she did.
Q. Had Jordans behavior or attitude changed in any respect since the first time you
described his change from Florida, the first trip?
A. It was the same. Same.
Q. Fathers Day is in June, okay?
A. Yes.
Q. Do you remember a situation where you were with Jordan, your son, on Fathers Day?
A. Yes.
Q. In 1993?
A. Yes.
Q. Im sure you were with him on other occasions. Do you recall where you were in 1993
on Fathers Day?
A. Yes, I was in New York.
Q. And to your knowledge, in your presence, did Jordan call his father on Fathers Day?

A. Eventually he did, yes.

Q. And initially, did you have a conversation with him?
A. Yes, I did.
Q. Did he want to call his father?
A. No, he didnt.
MR. MESEREAU: Objection. Hearsay; move to strike.
THE COURT: Sustained. Stricken.
Q. BY MR. SNEDDON: As a result of the conversation that you had with your son Jordan,
did he eventually call his father?
A. I think he did, yes.
Q. All right. At some point in time, did you receive a message of some sort from your exhusband Evan about Mr. Jackson?
A. Yes.
Q. And dont tell us what was said, okay? I just want to get the facts and the background
to it. Where were you when you first heard the message?
A. In Michael Jacksons car. In his limo.
Q. And was Mr. Jackson with you?
A. Not when I got that call.
Q. Did the call come d irectly to you or did you access it in some other fashion?
A. From another fashion.
Q. How was that?
A. Answering machine. I dialed in.
Q. So you dialed the answering machine on whose answering machine?
A. My answering machine at home.
Q. And there was a message on the machine from your ex-husband Evan, correct?
A. Correct.
Q. Did you at some point later play that message for Mr. Jackson?
A. I dont recall.
Q. Are you familiar with a person by the name of Anthony Pellicano?
A. Yes, I am.
Q. And who is Anthony Pellicano, to your knowledge?
A. A private investigator.
Q. And was Mr. Pellicano introduced to you by somebody?
A. By Bert Fields and Michael Jackson.
Q. In relat ionship to this voice message that you received on your message machine at
your house, do you recall how many days after that particular 5644 message, you
received that message, that you were introduced to Mr. Pellicano and Mr. Fields by Mr.
Jackson?
A. It could be a week later.
MR. MESEREAU: Objection. Move to strike; misstates the evidence; and no foundation.
THE COURT: Sustained, stricken.
Q. BY MR. SNEDDON: Did you meet Anthony Pellicano through the defendant, Michael
Jackson?
A. Yes.
MR. MESEREAU: Objection; leading.
THE COURT: Overruled. The answer is,Yes. Next question.
Q. BY MR. SNEDDON: Did you meet Bert Fields through the defendant, Michael Jackson?
A. Yes.

Q. Were you present during conversations with Mr. Pellicano and Mr. Fields and Mr.
Jackson?
A. Yes, I was.
Q. And this all occurred after the voice mail had been left on your message machine by
your ex-husband Evan Chandler?
A. Yes, sir.
Q. Now, did the defendant, Michael Jackson, tell you who Anthony Pellicano was?
A. Yes, he did.
Q. What did he say about Mr. Pellicano?
A. He can find out anything. Hes really good at this. Hes really good at investigating. If
youre having a problem, hell get to the bottom of it.
Q. And Mr. Fields, Bert Fields, is what -- you know him by name. What occupation is he
had?
A. Hes an attorney.
Q. And hes an attorney who works for who? Or at this point in time, who did you know he
was working for?
A. He worked for Michael Jackson.
Q. Now, at some point in time, did you go to Mr. Pellicanos office to be interviewed by Mr.
Pellicano?
A. Yes.
Q. And did somebody go with you?
A. Yes.
Q. Who was that?
A. My ex-husband, Dave Schwartz.
Q. And was there anybody else present during this conversation?
A. I dont remember. It could be Bert Fields also.
Q. Now, after that conversation, did you go somewhere else? Do you recall where you
went?
A. To Michael Jacksons home in Century City, apart ment in Century City.
Q. And was Mr. Jackson there?
A. He might have been.
Q. At that particular locat ion, was your son Jordan Chandler there, can you tell us?
A. Yes, he might have been there, too.
Q. Do you recall whether or not or do you recall an incident -- doesnt have to be on that
particular occasion, but do you recall an occasion whether or not your son Jordan Chandler
was ever interviewed by Anthony Pellicano?
A. Yes, he was.
Q. Where did that interview take place?
A. In the Century City apartment.
Q. Were you present?
A. Yes.
Q. Were you present during the conversation?
A. No.
Q. Where were you?
A. Upstairs or in his -- somewhere else.
Q. And do you recall how long that conversation took?
A. Could have been 45 minutes.
Q. Now, after Mr. Pellicano and Mr. Fields were introduced to you by Michael Jackson,

were you involved in some issues involving a change in custody of your son Jordan?
A. Yes.
Q. And were you -- were you presented with some papers to sign?
A. Yes, I was.
Q. And those papers did what?
MR. MESEREAU: Objection. Hearsay; foundation; relevance.
THE COURT: Foundation; sustained.
Q. BY MR. SNEDDON: The papers were presented to you by whom?
A. By Pellicano.
Q. And was Mr. Fields present?
A. I dont think at that time.
Q. Do you recall if the defendant, Michael Jackson, was present?
A. No, he wasnt.
Q. At some point in time did you have a conversation with Michael Jackson about signing
those papers?
A. I dont recall talking to Michael about the papers.
Q. Do you recall giving a statement to an attorney, a Deputy District Attorney with the Los
Angeles District Attorneys Office on September 3rd of 1993?
A. Yes, I do.
Q. And it was Miss Lauren W eis?
A. Yes, it was.
Q. And you gave a rather lengthy statement to Miss Weis?
A. Yes, I did.
Q. Do you recall telling Miss Weis that -MR. MESEREAU: Objection. Leading; hearsay; move to strike.
MR. SNEDDON: Its foundational, or to refresh her recollection.
THE COURT: If you want to refresh her recollection with something, you can approach
her and show the item.
MR. SNEDDON: All right. Counsel, page 95, lines 15 to 19.
MR. MESEREAU: Objection. Foundation, Your Honor.
THE COURT: You have to ask her if it will help refresh her recollection, or it might.
MR. SNEDDON: Can I show it to her first? Thats the way counsels been doing it.
MR. MESEREAU: No, I havent at all.
THE COURT: Actually, hes been asking them if it would refresh their recollection if he
showed them something.
MR. SNEDDON: All right.
Q. Do you recall that conversation?
A. Yes, I do.
Q. And -- and it occurred at a point in time when things were a lot fresher in your mind
than they are now?
A. Yes.
Q. Would it help, perhaps, if you looked at the statement, that it might help refresh your
5649 recollection?
A. Yes.
MR. SNEDDON: May I approach the witness, Your Honor?
THE COURT: Yes.
Q. BY MR. SNEDDON: Just read it to yourself. Start here and right down to here. Hows
that? Counsel, Im having her read lines 11 to line 25.

MR. MESEREAU: Im going to object to that. Thats improper refreshing of recollection

and it hearsay, foundational, to have her just read it.
MR. SNEDDON: Thats all Im asking her to do. Im just trying to help you try to find out
where it is.
THE COURT: All right. Just let her look at it. Counsel knows you can refresh a persons
recollection with anything.
MR. MESEREAU: Your Honor, I thought she was reading it out loud. That was my
mistake. I withdraw the objection.
THE COURT: That would have been improper.
MR. SNEDDON: Weve been down that road before.
THE COURT: All right, Im sorry. Did we -- where are we? (Laughter.)
MR. SNEDDON: I know where we are.
THE COURT: Is it break time yet? No. (Laughter.)
MR. SNEDDON: Im sorry, Judge. Youre going to have to suffer for six more minutes and
youre not getting out of here a minute early. Payback is you-know-what.
Q. All right. Mrs. Chandler, with regard to whether or not the defendant was present, did
that refresh your recollection?
A. Yes, it does.
Q. And do you recall whether the defendant was present?
A. He was present.
Q. And does it refresh -- did the defendant, Michael Jackson, make statements to you with
regard to the particular documents that you were being asked to sign?
A. Yes, he did.
Q. And do you recall what he told you?
A. He was frantic. He was begging me to, Come over and sign this so there wont be any
lawsuits or anything. Just sign it, sign it.
Q. And, in effect, what you signed did what to you personally?
MR. MESEREAU: Objection. Hearsay; foundation.
MR. SNEDDON: Let me go back, Judge. I think I can correct this. 5651
Q. I am assuming you read the document before you signed it?
A. Briefly.
Q. And you understood what it meant when you were sign ing it?
A. Not really.
Q. Okay. You understood -- well, let me ask you this: Did you understand -- if you didnt
understand all of it, you understood some of it, correct?
A. Yes, I did.
Q. Did you understand a part of it that had to do with who was going to have custody for
the children temporarily?
A. Exactly, yes.
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled.
Q. BY MR. SNEDDON: Im sorry?
A. Yes.
Q. And it wasnt going to be you anymore?
A. Exactly.
Q. Did you sign that paper?
A. I did.
Q. Mrs. Chandler, I neglected to ask you about one other incident that occurred at

Neverland Ranch, okay?

A. Yes.
Q. So pardon me if we can go back in time from where we are presently. And then were
almost done, okay?
A. Okay.
Q. Do you recall whether there was ever any occasion where your brother and your sisterin-law ever visited Neverland Valley Ranch?
A. Yes, I do recall.
Q. Do you know approximately when it was that they visited Neverland Valley Ranch?
A. Approximately May.
Q. And do you know how long they were there?
A. For the day.
Q. Just came up for the day?
A. Yes. For the day.
Q. And do you recall, were you with them while they were at the ranch?
A. Yes, I was.
Q. Was Jordan at the ranch?
A. Yes, he was.
Q. Where was Jordan?
A. With Michael.
Q. Now, do you remember about what time it was when you left that day, you personally?
A. Before eight oclock.
Q. Eight oclock --A. P.m.
Q. P.m. Now, do you recall seeing Mr. Jackson and Jordan before you left?
A. Yes.
Q. And where did you see them?
A. They were in Michael Jacksons bedroom.
Q. And do you recall -- did you go into the bedroom?
A. Yes.
Q. Did you go in there with your brother and sister-in-law?
A. Yes, we did.
Q. And when you went into the bedroom, where was Mr. Jackson?
A. In the bedroom with Jordan.
Q. Do you recall where?
A. Could be on the bed.
Q. You dont remember specifically?
A. Not specifically.
Q. Okay. And Jordan, do you recall where he was?
A. On the bed, too.
Q. Now, at some point in time, Mrs. Chandler, your son Jordan Chandler was involved in a
lawsuit, Chandler versus Jackson, a civil lawsuit. Do you recall that?
A. Yes, I do.
Q. And were you a participant in that lawsuit as a representative of your son?
A. Yes, I was.
Q. And who was the lawyer who represented your 5654 son during the majority of that
litigat ion?
A. Larry Feldman.
Q. And to your knowledge, was a lawsuit filed on behalf of your son against the defendant,

Michael Jackson?
A. Yes.
Q. And did you assist or help Mr. Feldman in the preparation of that lawsuit?
A. Yes.
Q. And did you support your son during that lawsuit?
A. I did.
Q. Now, as a result of the lawsuit, did your son -- and please -- dont tell us the amount,
please. Did your son receive monetary compensation from Mr. Jackson?
A. Yes, he did.
Q. Now, also as a result of that lawsuit, did you receive some monetary compensation?
A. Yes, I did.
Q. Did you ever ask to be compensated in any way as a result of what had happened?
A. No.
MR. MESEREAU: Objection. Foundation; and hearsay.
THE COURT: All right. Overruled.
Q. BY MR. SNEDDON: You did not?
A. No.
Q. And where did the idea for you receiving compensation come from, to your knowledge?
MR. MESEREAU: Objection, to the extent it calls for hearsay.
Q. BY MR. SNEDDON: As a result of this lawsuit, did you receive money?
A. Yes, I did.
Q. Did you have to sign something in exchange for that money?
A. Yes, I did.
Q. And what did you sign?
A. A disclosure agreement.
Q. And what does that mean?
A. Confidentiality agreement.
THE COURT: All right. Lets take our break. (Recess taken.)
THE COURT: Go ahead.
Q. BY MR. SNEDDON: Mrs. Chandler, I just have a couple of questions. I want to go
back to something we talked about before. You told the jury that the defendant, Michael
Jackson, gave you a gift cert ificate at one point in time?
A. Correct.
Q. And it was to Segal?
A. Fred Segal is a store in Santa Monica.
Q. Okay. And what was the amount of that 5656 certificate?
A. $7,000.
Q. Okay. Now, lets just go back and finish up the last part of what we were talking about.
With regard to the lawsuit, you signed some kind of an agreement, correct?
A. Correct.
Q. In exchange for that, you were given some money?
A. Yes.
Q. Do you recall, based upon what you know, what the agreement was, what it required of
you?
MR. MESEREAU: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. SNEDDON: What did you give up in return for receiving money?
MR. MESEREAU: Same objection. Hearsay and foundation.

THE COURT: Sustained.

Q. BY MR. SNEDDON: Did you read the agreement before you signed it?
A. Yes.
Q. And who presented it to you?
A. Larry Feldman.
Q. Did he go over it with you before you signed it?
A. Yes.
Q. And you understood what you were signing?
A. Yes, we did.
Q. And you read the document?
A. Yes.
Q. And what did it require you to do in order to obtain money from the defendant, Mr.
Jackson? You personally.
A. We couldnt -MR. MESEREAU: Objection. Hearsay and foundation.
THE COURT: Sustained.
Q. BY MR. SNEDDON: Have you ever written any books -A. Never.
Q. -- about what happened?
A. No, I have not.
Q. Did any interviews?
A. Never.
Q. Made any money selling anything -A. No.
Q. -- about your experience?
A. No.
MR. SNEDDON: Nothing further.
THE COURT: Cross-examine?
MR. MESEREAU: Yes, please, Your Honor.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. Mrs. Chandler, my name is Tom Mesereau and I speak for Michael Jackson, okay?
A. Yes.
Q. If anyth ing I ask you is not clear, please dont answer. Just say you dont understand
it, and Ill try to rephrase it, okay?
A. Okay.
Q. Now, in response to the prosecutors questions, you said you entered into a stipulat ion
regarding custody of your son Jordie, correct?
A. Correct.
Q. And in response to the prosecutors questions, you said you did it because Michael
Jackson told you to do it, right?
A. One of the people. He was one.
Q. Well, do you remember signing a sworn declaration regarding that stipulation?
A. I remember signing something about custody of Jordie.
Q. Do you remember signing a sworn declarat ion in which you said the only reason you
signed the stipulation was because your ex-husband wouldnt return Jordie to you if you
didnt, right?
A. Correct.

Q. And you said further, you thought the stipulation was merely for a one-week visitat ion
period, right?
A. Correct.
Q. Nowhere in that declaration did you say anything about Michael Jackson telling you to
sign anything, right?
A. Thats not correct.
Q. Would it refresh your recollection to look at your declaration?
A. Id be happy to.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. MESEREAU: Miss Chandler, have you had a chance to look at that sworn
declaration?
A. Yes, I have.
Q. Does it refresh your recollection about what you said in the declaration?
A. Sort of.
Q. Isnt it true you said the only reason you signed it was because your ex-husband told
you that if you didnt sign the stipulation, you would not have Jordan returned to you,
right?
A. Thats correct.
Q. You said that was the only reason, correct?
A. Thats not the only reason.
Q. Well, you signed it under penalty of perjury, did you not?
A. I wasnt asked who else was asking me to sign it.
Q. Who prepared the declaration for you to sign?
A. Evan Chandlers attorney.
Q. Were you represented by counsel when you signed this declaration?
A. Oooh. I might have been.
Q. You actually were, werent you?
A. I -- I dont recall.
Q. You were represented by counsel because you were trying to set aside the stipulation
in court, right?
MR. SNEDDON: Well, Your Honor, Im going to object to that. Thats misleading as to
point and time, and vague.
MR. MESEREAU: Its not misleading at all.
MR. SNEDDON: Wait a minute, Counsel. Judge, I object as vague as to time as to when
she was represented.
THE COURT: All right. Ill sustain the objection. Its an argumentative question.
Q. BY MR. MESEREAU: Miss Chandler, at some point you hired a lawyer to help you set
aside that stipulation, right?
A. I dont know if that was the reason why an attorney was hired, if it was for that reason.
Q. And your attorney prepared your declaration, true?
A. I dont recall.
Q. Do you recall if the stipulat ion was ever set aside by your attorney?
A. I dont recall.
Q. Do you recall being represented by an attorney named Freeman?
A. Yes, I do.
Q. And who is Mr. Freeman?
A. Hes an attorney that represented me for a short time.

Q. Do you recall asking Michael Jackson if he would loan David Schwartz four million
dollars?
A. Never.
Q. You say you never did that?
A. Never d id that.
Q. Okay. Do you recall your ex-husband David Schwartz asking you to do that?
A. Never.
Q. Do you recall him being five million dollars in debt around the time you were
associating with Michael Jackson?
A. No.
Q. Dont recall that at all?
A. Not at all.
Q. Okay. When you sued Michael Jackson, you sued through Larry Feldman, true?
A. I did not sue Michael Jackson. Jordan Chandler and his family were -- that was his
family. We did not sue Michael Jackson.
Q. Okay. So you never sued him yourself, youre saying?
A. I dont believe thats how it was worded.
Q. Okay. Do you recall meetings with your attorney about that lawsuit?
A. Yes, I do.
Q. Now, you -- you and Jordans father Evan were divorced in 1985, true?
A. Correct.
Q. And you obtained sole custody of Jordan, right?
A. Yes.
Q. And you had an informal arrangement where Evan could have custody or at least
visitation rights of Jordie from time to time, correct?
A. Correct.
Q. What year did you marry David Schwartz?
A. 1985.
Q. Now, is it correct that he became Jordans stepfather?
A. Correct.
Q. And for how long was he Jordies stepfather?
A. For approximately six to eight years.
Q. What year did he cease to be Jordies stepfather?
A. When we divorced.
Q. And what year was that?
A. 1994.
Q. And how old is Jordie now?
A. He is 25 years old.
Q. Can I ask you when you last spoke to him?
A. 11 years ago.
Q. At one point, David Schwartz sued Michael Jackson, correct?
A. I dont recall.
Q. Do you recall him suing Michael Jackson claiming that Michael had interfered with his
business?
MR. SNEDDON: Your Honor, Im going to object as immaterial; irrelevant; calls for
hearsay.
THE WITNESS: I dont recall.
THE COURT: Its vague as to time.

MR. MESEREAU: Okay. Ill rephrase it, Your Honor.

Q. Around the time you and Evan and Jordie sued Michael Jackson with Attorney Larry
Feld man, do you recall your ex-husband, David Schwartz, also suing Michael Jackson?
MR. SNEDDON: Same objection, Your Honor.
THE WITNESS: I dont recall.
THE COURT: Overruled. You may answer.
THE WITNESS: I dont recall.
Q. BY MR. MESEREAU: Okay. Do you recall, in response to your lawsuit, Mr. Jackson suing
for extortion?
MR. SNEDDON: Your Honor, Im going to object to that question.
THE COURT: Sustained. Foundation.
Q. BY MR. MESEREAU: You sued Michael Jackson, right?
A. Jordan Chandler sued Michael Jackson.
Q. Were you listed as a plaint iff?
A. Yes.
Q. And in response to your suit, Mr. Jackson sued for extortion, true?
A. I dont recall.
Q. Okay. Were you and Evan and Jordie all represented by Larry Feldman?
A. Yes, we were.
Q. Do you know approximately when that suit settled?
A. I guess in 95.
Q. Do you recall Evan suing Mr. Jackson a second time?
A. No.
Q. Dont know anything about that?
A. Nothing.
Q. Never h eard about it?
A. No.
Q. Do you know who Attorney Barry Rothman is?
A. Yes.
Q. Who is Attorney Barry Rothman?
A. He was Evan Chandlers attorney.
Q. Do you recall Attorney Barry Rothman also suing Michael Jackson?
A. No, I dont.
Q. Okay. Now, during your trips with Michael Jackson, do you recall the name Sony ever
being ment ioned?
A. Yes.
Q. And in what context was Sony mentioned?
A. The gifts that Michael Jackson gave were from Sony. Sony recorders. We flew on the
Sony jet. Thats what I remember.
Q. And do you recall, around the time you were associating with Michael Jackson, that
Michael Jackson had an endorsement deal with PepsiCo?
A. Yes.
Q. And to your knowledge, that was the most lucrative endorsement deal anyone in the
music business had ever entered into with PepsiCo, correct?
A. I didnt know that.
MR. SNEDDON: Your Honor, thats immaterial and irrelevant.
THE COURT: Foundation; sustained.
Q. BY MR. MESEREAU: Do you recall learning from Michael Jackson that he owned an

interest in The Beatles catalog?

A. Yes.
Q. Did you discuss that with Mr. Jackson?
A. Never.
Q. Did you discuss his deal with PepsiCo with Mr. Jackson?
A. No.
Q. When you filed your lawsuit against Mr. Jackson, your attorney was threatening to ruin
Mr. Jacksons music deals, correct?
A. No. Not that I recall.
Q. You dont recall that at all?
A. Not at all.
Q. Do you recall participat ing in settlement negotiations?
A. Yes.
Q. And when you participated in settlement negotiations, where did you used to meet?
A. Larry Feldmans offices.
Q. When did you last talk to Larry Feldman?
A. Oh, a few days ago.
Q. Did you talk about what you were going to say in court?
A. No.
Q. Did you talk about what he said in court?
A. Briefly.
Q. Did he call you or did you call him?
A. I called him.
Q. Before this discussion a few days ago, when was the last time before that you had
spoken to Larry Feldman?
A. Oh, um, maybe two months before that.
Q. And did you talk to him about this case in that discussion?
A. Yes.
Q. Did you talk to him about what you were going to say?
A. No.
Q. Did you call him or did he call you?
A. I called him.
Q. Did you talk on the phone with him or did you meet with him?
A. Yes, talk on the phone.
Q. Before that discussion, when had you last spoken to Attorney Larry Feldman?
A. Perhaps ten years ago.
Q. Okay. But you never discussed anything about this case in those discussions, right?
A. No.
Q. And you never talked about what you were going to be asked in this courtroom in any
of those discussions, right?
A. Not to that effect, no.
Q. Did Mr. Feldman tell you he represents the Arvizos in either of those discussions?
A. I dont know what that is.
Q. Okay. So he never talked about his representing anyone associated with this case,
besides you, right?
A. Correct.
Q. Now, you said something in response to the prosecutors questions about your son
changing the way he dressed at one point, right?

A. Correct.
Q. Didnt your son used to try and dress like Michael Jackson before he even met him?
A. When he was very young.
Q. Did you meet with the prosecutor before you testified today?
A. Yes.
Q. When did you meet with the prosecutor to talk about anything you said today?
A. Two days ago.
Q. And where was that meeting?
A. In downtown L.A.
Q. And who did you meet with?
A. With my attorney.
Q. And who is your attorney?
A. Brad Barnholtz.
Q. Who else did you meet with?
A. Tom Sneddon.
Q. Okay. How long a discussion was that?
A. Oh, perhaps an hour and a half.
Q. Did you talk about what you were going to say today?
A. Yes.
Q. Did Mr. Sneddon go over some questions that he was going to ask you?
A. Yes.
Q. Did you ever go over some answers that you were going to give?
A. Yes.
Q. When had you met with Mr. Sneddon before that meeting?
A. Never.
Q. Have you talked to him on the phone?
A. Yes.
Q. How many times?
A. Once or twice.
Q. Okay. Now, where did you first meet Michael Jackson?
A. At Rent-A-Wreck. The business of my ex-husband.
Q. And that was the day that Mr. Jackson had a problem with his car, right?
A. Yes.
Q. Okay. And when did you see him after that init ial meet ing?
A. I guess maybe approximately a few months after that.
Q. The first meeting was approximately August 92, right?
A. Correct.
Q. Okay. And when do you think the next meeting was?
A. Perhaps maybe in February.
Q. Okay. And again, how did that meeting happen? Who called who?
A. How did the meet ing -Q. The second meeting. The first time you s aw him when he had a problem with his car,
right?
A. Correct.
Q. And then there was a meet ing after that?
A. Right.
Q. How did that happen?
A. Through phone conversations with my son. And he -- and Michael Jackson invited us to

Neverland.
Q. Okay. How did you get to Neverland?
A. By car. By my car. I drove.
Q. Okay. And did you stay over at Neverland that first time?
A. Yes, I did.
Q. How long did you stay?
A. I would say for two nights. One or two nights.
Q. Okay. And your daughter was there as well, right?
A. Yes, she was.
Q. Okay. And you said that you, your daughter, your son, stayed in the guesthouses,
correct?
A. Correct.
Q. Now, what did you do during the day during that visit, during the two days you were
there?
A. We watched movies. We went on rides. We visited his zoo. Things like that.
Q. Okay. And how did you get home? Did you drive?
A. Yes, I did.
Q. When did you next talk to Michael Jackson after that?
A. Oh, I think probably the day after we got back.
Q. Did he call you?
A. Yes.
Q. Okay. Did you talk to him?
A. Yes.
Q. And when did you get together again?
A. Perhaps a week later. A week or two later.
Q. Did you go to Neverland again?
A. Yes, we did.
Q. How did you get there?
A. He drove. His -- sorry, his chauffeur drove.
Q. Okay. And did you stay over -A. Yes.
Q. -- on that second trip?
A. Yes.
Q. And how long was your stay over there?
A. A couple of nights.
Q. Okay. Do you remember what you did on that second trip?
A. Same thing.
Q. Okay. Did you see Michael very often on the first trip?
A. The whole time, yes.
Q. Did you see him -A. Yes.
Q. -- very often on the second trip?
A. Yes.
Q. When you said you went to the zoo and did these fun things, was Michael always with
you?
A. The first and second time?
Q. Yes.
A. Basically, yes.

Q. Okay. Did you have dinner in the main house with Michael?
A. Yes.
Q. And of course your children were there too, right?
A. Correct.
Q. After that second trip, when did you next have contact with Michael, if you remember?
MR. SNEDDON: Your Honor, Im going to object to the use of the first name.
THE COURT: All right.
MR. MESEREAU: Ill say Michael Jackson, Your Honor.
Q. After your second visit to Neverland, did you have further contact with Michael
Jackson?
A. Yes, I did.
Q. And please explain what your next contact was all about.
A. I dont know if that was the time we again went to Neverland or we had taken a trip to
Las Vegas.
Q. Now, in your discussion with the Los Angeles District Attorney in 1993, you talked
about your visits with Mr. Jackson, right?
A. Correct.
Q. Have you looked at that transcript recently?
A. Yes.
Q. When did you last look at the transcript?
A. Briefly, today.
Q. And how did you get a copy of it?
A. Through Mr. Sneddon.
Q. Okay. Did he ask you to read it today?
A. Did he ask me to read it today?
Q. Yes.
A. No.
Q. Did he ask you to read it at any time?
A. Yes, he did.
Q. And when was that?
A. Last week.
Q. Did he give you anything else to read before you testified?
A. Thats it.
Q. Okay. And did you read it from cover to cover?
A. Tried.
Q. Pardon me?
A. Yes.
Q. Okay. Okay. You told the District Attorney in Los Angeles when describing your first trip
there, Michael Jackson wasnt the superstar. He was a regular person, and we couldnt
believe how nice he was, right?
A. Correct.
Q. And you said that after you got there, he offered to let you stay over, correct?
A. Correct.
Q. Your plan initially wasnt to stay over, right?
A. Correct.
Q. You said that first night, Jordie actually knocked at your door and said he was going to
stay with you, right?
A. Correct.

Q. So the first night he stayed with you and your daughter, right?
A. Correct.
Q. Okay. Now, when d id you go to Toys-R-Us with Michael Jackson?
A. Could have been the first visit or the second visit.
Q. Okay. And did Michael Jackson offer to take you there?
A. Yes.
Q. And he did take you there, right?
A. Yes, he did.
Q. Did he drive or did you have a driver take you there, do you know?
A. We must have had a driver.
Q. Okay. Now, at one time, did you visit Roy Disneys widow with Michael?
A. Never.
Q. Okay. At some point you told the Los Angeles District Attorney that Michael was visiting
Roy Disneys widow in Beverly Hills; do you remember that?
A. Not really, but I dont recall.
Q. Do you recall telling that to the Los Angeles District Attorney?
A. I dont recall.
Q. Would it refresh your recollection to let you see that page?
A. Yes.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Thank you.
Q. BY MR. MESEREAU: Have you had a chance to look at that?
A. Yes.
Q. Does it refresh your recollection about what you told the Los Angeles District Attorney?
A. Yes.
Q. And what did you tell them about that?
A. I said that I was -- we had left and Michael was -- I had left Neverland with Jordie and
Lily, and he was going to visit Roy Disneys widow.
Q. Okay. Now, was that while you were visiting Neverland?
A. After we left.
MR. SNEDDON: Object as to vague as to time as to what visit.
MR. MESEREAU: Ill rephrase it.
Q. During what visit did Michael Jackson tell you he had to visit Roy Disneys widow?
A. The first visit.
MR. SNEDDON: Object as to hearsay.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Was it the first visit?
A. I think so.
Q. Do you recall if you and your family stayed at Neverland while Mr. Jackson left the
premises?
A. I dont recall that.
Q. Okay. Do you recall him making a trip like that?
A. Yes.
Q. Okay. You talked about gifts that Mr. Jackson gave you, okay?
A. Okay.
Q. Did you ever ask for any of those gifts?
A. No.

Q. Did he just give them to you on his own initiative as far as youre concerned?
A. Yes.
Q. Okay. Tell us all the gifts you recall him giving you.
A. A gold bracelet. A pair of earrings. A necklace. A ring. A gift certificate to a boutique.
Thats what I recall.
Q. Okay. And you said he gave you his credit card to use?
A. Yes.
Q. Did he do that more than once?
A. He might have, yes.
Q. And do you recall what you bought with Michael Jacksons credit card?
A. I know I -- I think two handbags.
Q. Anything else?
A. Not that I recall, no.
Q. Okay. How many nights do you recall Mr. Jackson staying at your house?
A. To the best of my recollection, 30 nights.
Q. And approximately what time period was that, if you know?
A. Beginning the midd le of April till the end of May.
Q. Were you at your house on every evening that Michael Jackson stayed over?
A. Yes.
Q. You said something to the effect, I believe, that Mr. Jackson would leave during the
day?
A. Correct.
Q. Do you know where he went?
A. Not really. I -Q. Did you ever ask him?
A. Sometimes.
Q. Okay. And where did he tell you he was going?
A. Going home.
Q. To Neverland?
A. Working. No, not to Neverland. I think his hideout, to his place that he calls The
Hideout in Century City.
Q. Thats the place you vis ited, correct?
A. Correct.
Q. How many times were you at that apartment?
A. Approximately three or four times.
Q. Okay. When you went to the apartment that youve described as Michael Jacksons
hideout, were you always with your son?
A. Yes.
Q. Were you ever with anyone else?
A. Not that I recall.
Q. Okay. You indicated you met someone named Brett Barnes at Neverland, right?
A. Correct.
Q. Do you know when you first met him? 5679
A. It could have been the second time that we were going to Neverland.
Q. And he was actually in the limousine that Michael Jackson sent to pick you up, right?
A. Correct.
Q. Was that the first time you had met him?
A. Yes.

Q. Okay. Was that the trip you went to Disneyland?

A. It could be, yes.
Q. And was Brett Barnes with you on that trip?
A. I would assume so. Im -- I dont recall.
Q. Do you know if his mother was there on that trip?
A. No.
Q. So it was you, Michael Jackson, your two children, and Brett, right?
A. Perhaps Brett.
Q. Youre not sure?
A. Exactly.
Q. Did you go back to Neverland after the trip to Disneyland?
A. I dont recall.
Q. Okay. You indicated you met someone named Joy, right?
A. Correct.
Q. And when did you meet someone named Joy?
A. Later on, in -- could be May. April or May.
Q. And where did you meet her?
A. At Neverland.
Q. Okay. Was she staying there when you stayed there?
A. Yes.
Q. And did she have a son, to your knowledge?
A. Yes, she did.
Q. And who was that?
A. Wade.
Q. Okay. How often did you see Joy Robeson and Wade Robeson at Neverland?
A. I remember seeing Joy once. And Wade, I -- it could be a few times. I dont recall.
Q. When you were at Neverland at the same time that they were there, did you associate
with them?
A. Yes.
Q. Okay. And what did you do with them?
A. I had dinner with Joy, where we talked. And with W ade, if we went -- if there was a
movie playing, I guess he was with us also.
Q. When Michael Jackson used to stay at your home, were you in the middle of a divorce
proceeding?
A. No.
Q. Were you separated?
A. Yes.
Q. Did you used to discuss your problems with David Schwartz with Michael Jackson?
A. Yes.
Q. You actually had a lot of discussions, didnt you?
A. Not a lot.
Q. You told him it was a poor relationship, didnt you?
A. What was a poor relationship?
Q. Your relationship with David Schwartz.
A. I told whom? Im sorry.
Q. Michael Jackson.
A. Oh. No. I -- I dont -- I didnt get into my relat ionship about David Schwartz to Michael.
Q. So you never discussed it with Michael Jackson?

A. I just said that we were separated and these were not wonderful times for us.
Q. And you would discuss with him from time to time the problems you were having,
wouldnt you?
A. No. No, I wouldnt.
MR. SNEDDON: Object as irrelevant, Your Honor, not to mention hearsay.
THE COURT: Overruled. The answer was, No. Next question.
Q. BY MR. MESEREAU: During those 30 nights that Michael Jackson stayed at your house,
did he have d inner at your house?
A. Yes.
Q. And was it usually you, he, your son and daughter at dinner?
A. At times.
Q. Who else would join you for dinner?
A. Thats it.
Q. Did you ever have dinner yourself, without your children, just with Michael Jackson?
A. No.
Q. Have you ever traveled with Michael Jackson without your children?
A. No.
Q. When did you go to Las Vegas with Michael Jackson?
A. Around the end of March.
Q. And what was the purpose of that trip?
A. I guess Steve Wynn, the owner of the Mirage Hotel, invited Michael to come and stay
and vacat ion in Las Vegas for a few days.
Q. And did you meet Mr. Wynn while you were there?
A. Yes, I did.
Q. How long were you in Las Vegas for that trip?
A. Two or three nights.
Q. And again, how did you get there?
A. Steve Wynns jet.
Q. And did his jet take you back home afterwards?
A. Yes.
Q. All right. When you went to Las Vegas on Steve W ynns jet, had Michael Jackson begun
to stay over at your home?
A. No.
Q. Did Michael Jackson begin to stay at your home after that trip to Las Vegas?
A. Yes.
Q. Now, did you travel with Michael Jackson to any other cities in America during this
period of time?
A. Yes.
Q. Where did you travel to?
A. To Florida and New York.
Q. Was that Orlando, Florida?
A. Correct.
Q. And when did that trip happen, approximately?
A. Oh, approximately April, I guess.
Q. And what was the purpose of that trip, if you know?
A. To go to Disney World.
Q. Did you do that?
A. Yes, we did.

Q. How long a trip was that?

A. A couple of days.
Q. And then did you come back?
A. Yes.
Q. The rooms in your hotel, describe the rooms,
if you would.
A. I dont remember The Grand Floridian, what the rooms were like.
Q. And did you have your own room?
A. Yes.
Q. Did Michael Jackson have his own room?
A. Yes, he did.
Q. And did your children have their own room?
A. Im not sure.
Q. Do you know where your children stayed?
A. Yes.
Q. Where did they stay?
A. Jordie, my son, stayed with Michael, and Lily stayed with me.
Q. And did you ever object, during that trip, to your son staying with Michael?
A. No.
Q. You never suspected anything improper was going on on that trip, correct?
A. Correct.
Q. You mentioned some children from New Jersey that you met at Neverland, right?
A. Correct.
Q. And who were they again?
A. Frank and Eddie Cascio.
Q. Okay. And did you ever meet their parents?
A. No.
Q. When did you first see them at Neverland?
A. I dont recall. Could be the third visit to Neverland. Fourth visit.
Q. When was the first time your son Jordan asked if he could sleep with Michael Jackson?
A. I would say starting the third visit to Neverland, second or third visit to Neverland,
because there were always boys around and staying in his bedroom, and why couldnt he?
And thats when he started asking.
Q. And was it your understanding that there were a lot of kids hanging around Michael
Jacksons bedroom?
A. Yes.
Q. Did you see -A. Boys.
Q. Excuse me. Did you see a lot of kids at Neverland while you were there?
A. A lot of Michaels -MR. SNEDDON: Excuse me. Object as to vague.
MR. MESEREAU: Ill rephrase it. Lets go through the first trip.
Q. Did you see a lot of kids at Neverland during your first trip?
A. No.
Q. Did you see a lot of kids at Neverland during your second trip?
A. No.
Q. How many other children at Neverland did you see on your first trip?
A. No other kids on the first trip.

Q. How many kids at Neverland did you see on your second trip?
A. One.
Q. How about your third trip?
A. Third -- Frank and Eddie Cascio.
Q. Any other children on the third trip?
A. It could have been Macaulay Culkin also.
Q. Okay. Did you meet Macaulay Culkin at Neverland?
A. Yes.
Q. Macaulay Culkin doesnt look at all like your son, does he?
A. No.
Q. Did you meet Macaulays parents?
A. Father.
Q. At Neverland?
A. Yes.
Q. And that was, you think, the third trip?
A. Could be. Could have been.
Q. Did you ever see him at Neverland ag ain?
A. Yes.
Q. When did you next see Macaulay Culkin at Neverland?
A. Fourth or fifth visit.
Q. Was anyone else from his family there; do you know?
A. His brothers were there.
Q. Okay. Was it your understanding that the Culkins were good friends of Michael
Jackson?
A. That Macaulay Culkin was good friends with Michael Jackson.
Q. What about his family? W as it your understanding his family were close friends of
Michael Jackson?
A. Not close friends.
Q. Did you really know?
A. It didnt appear that they were close friends, no.
Q. Do you know if his parents used to visit Neverland?
A. His father used to visit Neverland with Macaulay.
Q. Did you hang out with them when you were at Neverland?
A. Did I hang out with -Q. The Culkins.
A. No.
Q. Then how would you know whether or not they were close with Michael Jackson?
MR. SNEDDON: Your Honor, Im going to object as argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: When you were in Las Vegas with Mr. Jackson, you went to Cirque
du Soleil, correct?
A. No, I did not.
Q. Did your son?
A. Yes, he did.
Q. And did your daughter go as well?
A. To Cirque du Soleil?
Q. Yes.
A. No, she did not.

Q. Did you have any problem at that time letting your son go to Cirque du Soleil with Mr.
Jackson?
A. No.
Q. And did your son stay with Mr. Jackson that evening, to your knowledge?
A. To my knowledge, yes.
Q. Okay. You told the prosecutor that Mr. Jackson got upset at one point about your not
trusting him, right?
A. Correct.
Q. And he said words to you to the effect that, Were family, right?
A. Correct.
Q. You suggested that you let Jordie sleep wherever he wants to sleep, right?
A. Yes.
Q. And you told him, Look, Ive had two husbands that I cant trust, right? 5689
A. Correct.
Q. You said, I think youre a wonderful person, but I cant let my trust down, right?
A. Correct.
Q. And you described Michael as saying that he was going to take care of you, right?
A. No.
MR. SNEDDON: Your Honor, excuse me, Im going to object as vague as to point in time
of the conversation.
MR. MESEREAU: Sure. Sure.
Q. When was the conversation where Michael got upset because he didnt think you
trusted him?
A. In Las Vegas in the hotel room.
Q. Okay. You said to Michael, Ive had males in my life that, you know, have disappointed
me. How can I have you in my life and youre saying that youre going to take care of us,
that youre so wonderful, everythings going to be okay, how am I going to do that?
MR. SNEDDON: Your Honor, Im going to object to counsel reading from the document.
MR. MESEREAU: I havent finished the question yet, Your Honor.
MR. SNEDDON: Well, hes reading -THE COURT: Well, all right, what is the question?
MR. MESEREAU: I was going to ask her if she made that statement.
THE COURT: All right. You may.
Q. BY MR. MESEREAU: Did you make a statement to that effect?
A. Yes.
Q. And Michael said to you he wanted a family to just treat him like a regular person,
right?
A. Correct.
Q. He said he didnt want to be like a stranger, right?
A. Correct.
Q. And he asked you to trust him, right?
A. Yeah.
Q. Do you remember telling the District Attorney in Los Angeles that when you talked to
your ex-husband Evan about Michael Jacksons relationship with your family, that Evan
saw this as a wonderful means for Jordie not having to worry for the rest of his life?
A. Would you repeat your question?
Q. Yes. Didnt you tell the Los Angeles District Attorney that your ex-husband Evan, the

father of Jordie, told you that the relationship with Michael was a wonderful means of
Jordie not having to worry for the rest of his life?
A. Yes.
Q. And to you, that meant Michael Jackson supporting you financially for the rest of your
life, correct?
A. No.
Q. Thats what you thought your ex-husband meant by it, true?
MR. SNEDDON: Calls for speculation.
THE WITNESS: Speculat ion.
THE COURT: Sustained. Sustained. (Laughter.)
Q. BY MR. MESEREAU: Just asking you what you thought, not what your ex-husband
thought.
A. Well, Im speculating also. I would be speculat ing if I answered.
Q. Well, if someone says to you, This is a wonderful way not to have to worry for the rest
of our life, doesnt that suggest that maybe someone is thinking about Michael Jackson
supporting you?
MR. SNEDDON: Your Honor, Im going to object. We just went through this. Calls for
speculation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: When did you go to France and Monaco with Michael Jackson?
A. In May.
Q. Did he invite you?
A. Yes.
Q. Did he invite your whole family?
A. Jordan and Lily, yes.
Q. At one point you said that Michael Jackson stayed at your ex-husbands house when
Jordan was there, correct?
A. Correct.
Q. And to your knowledge, was your ex-husband at the house when Michael Jackson
stayed there?
A. Yes.
Q. How many days, to your knowledge, did Michael Jackson stay at your ex-husbands
house?
A. Approximately four to seven days.
Q. To your knowledge, was that consecutive or were they periodic visits?
A. Consecutive.
Q. And do you recall anything about your ex-husband wanting Michael Jackson to finance
a wing on his house?
A. Yes.
Q. And to your knowledge, Michael Jackson never did that, right?
A. No.
Q. Now, at that point in time, Jordans father Evan was writ ing a screenplay, right?
A. Correct.
Q. And to your knowledge, he was spending a lot of time on that screenplay, right?
A. Yes.
Q. And you were complaining that he wasnt spending enough time with his son, right?
A. Correct. Q. At the time you were happy that Michael was around, because Jordans
father was not spending time with him, and you were separated from David, correct?

A. True.
MR. SNEDDON: Im going to object as to vague as to what time, time period. W e have
several months here.
MR. MESEREAU: W ell, I can -THE COURT: Sustained.
MR. MESEREAU: Okay.
MR. SNEDDON: Move to strike the answer.
THE COURT: Stricken.
Q. BY MR. MESEREAU: Did there come a time when you were happy that Michael Jackson
was around, because your ex-husband Evan was spending time writ ing a screenplay and
you were separated from David?
A. Correct.
Q. Approximately what -- when was that?
A. In the beginning I was happy.
Q. Okay. When did Michael go to Cartier and buy you that jewelry?
A. When we went to Las Vegas.
Q. Was he with you when he did that?
A. No.
Q. Did he do it on his own?
A. He did it with Jordie.
Q. Okay. And did he come back and give it to you?
A. Yes.
Q. Okay. Now, you described that to the Los Angeles District Attorney as a love bracelet,
did you not?
A. Yes.
Q. Is that what it was?
A. Yes.
Q. What is a love bracelet?
A. Its a bracelet thats a gold bracelet and thats what its called.
Q. Okay. Had you ever told Michael Jackson you liked that kind of jewelry?
A. No.
Q. Were you surprised when he bought it for you?
A. Yes.
Q. Okay. Now, you mentioned that during that trip, you went to the David Copperfield
show; is that right?
A. Correct.
Q. And who went to that show?
A. Jordan, Lily and Michael.
Q. Did the four of you have dinner that night together?
A. I dont recall.
Q. Okay. Did Michael give you his cred it card on that trip?
A. No.
Q. Okay. At some point did you all see an Exorcist movie?
A. No.
Q. Do you recall anyone watching an Exorcist movie?
A. I was told Jordan and Michael watched an Exorcist movie.
Q. All right. Did you ever object to Jordie sleeping in Michaels room on that trip?
A. Yes.

Q. And what did you say?

A. Jordie, when you come home, go to your bed. Go to your own bed. Come to our bed,
not to Michaels bed. He said, Mom, I want to stay there. And I was very upset about
that.
Q. Now, this was before the approximately 30 nights that he stayed at your home -A. Yes.
Q. -- in Santa Monica, right?
A. Correct.
Q. And you did allow him to stay at your home in Santa Monica, right?
A. Afterwards.
Q. Now, you mentioned in your interview that when Michael Jacksons not working, hes a
lonely person, correct?
A. Correct.
Q. And you also mentioned that the Cascios owned a restaurant, true?
A. True.
Q. How did you know they owned a restaurant?
A. I was -- I dont recall how I knew.
Q. And do you remember telling the District Attorney that Michael would help Jordie with
his homework?
A. Correct.
Q. Would he do that at your home?
A. Yes.
Q. You also said he played a lot like a child, correct?
A. Correct.
Q. And he seemed to play at Neverland a lot like a child, correct?
A. Yeah, yes.
Q. You mentioned Tommy and Merdie. Do you remember that?
A. Yes.
Q. And who are Tommy and Merdie?
A. Merdie; are my brother and sister-in-law.
Q. Okay. At some point you stayed in Santa Monica with them, correct?
A. Yes.
Q. Was Michael Jackson there?
A. He was there.
Q. Did Michael Jackson stay with you at their home?
A. No.
Q. Did he stay at their home?
A. No.
Q. Did he stay at your home?
A. Not that time, no. Not at that time.
Q. And you stayed in Santa Monica with Tommy and Merdie?
A. Meredith. Merdie.
Q. Merdie, okay. You stayed with them at one point, right?
A. They stayed with me.
Q. Oh, they stayed with you?
A. Yes.
Q. Was Michael Jackson there that night?
A. I dont recall, no.

Q. Okay. To your knowledge, did Michael Jackson ever meet Tommy and Merdie?
A. I dont recall.
Q. Okay. Now, when Michael Jackson was staying at your home in Santa Monica during
those 30 days that you mentioned, was Jordan in school?
A. Yes, he was.
Q. Was he going to school each day?
A. Yes, he was.
Q. Okay. You mentioned Steve and Jo Ellen. Do you remember that?
A. Do I remember ment ioning -Q. Mentioning Steve and Jo Ellen to the District Attorney?
A. Yes.
Q. Who are Steve and Jo Ellen?
A. Steve is also my brother, and his wife Jo Ellen.
Q. Did they vis it you in Santa Monica during the time that Michael Jackson was staying
over?
A. No.
Q. You said that they witnessed Michael Jackson and Jordie in the bedroom, didnt they?
A. Correct.
Q. When was that?
A. At Neverland.
Q. Did they stay there?
A. No.
Q. Okay. Did they go into Michael Jacksons bedroom?
A. Yes, they did.
Q. And did you go into Michael Jacksons bedroom?
A. Yes.
Q. How many times do you think you went into Michael Jacksons bedroom at Neverland?
A. It stopped after maybe the tenth time.
Q. Okay. Describe, if you would for the jury, what Michael Jacksons bedroom looks like?
A. Lots of dolls. Lots of playthings. It looks like a boys room, big boys room. Lots of toys
and things.
Q. Is it a big area?
A. Yes.
Q. How big would you describe it as, if you can?
A. Oh, its a long time ago.
Q. Was it kind of huge?
A. Well, theres an upstairs and a downstairs. Yes, its kind of huge.
Q. When you used to visit Michael Jacksons bedroom, would you see other people in
there?
A. Yes.
Q. Who do you remember seeing in there?
A. The Cascio brothers. Macaulay. Brett. Wade.
Q. And you saw their parents in there, too, didnt you?
A. No.
Q. Did you ever see Macaulays father in there?
A. In the bedroom?
Q. Yes.
A. No.

Q. And why were you in the bedroom those ten times?

A. Because Im Jordies mother. Im allowed to go into the bedroom.
Q. Were you dropping clothes off?
A. Oh, I might have. I dont recall.
Q. Did you ever sit down and watch T.V. or anything in there?
A. Yes.
Q. How often did you do that?
A. A few times.
Q. Did you ever have food delivered to you in Michael Jacksons bedroom?
A. I dont recall.
Q. Okay. Did David Schwartz, to your knowledge, ever vis it Neverland?
A. No. No.
Q. Okay. When you were in Monaco with Michael Jackson, what did you do?
A. We went to an awards ceremony. We -- well, Jordie and Michael -- Jordie and Michael
were sick, so Lily and I went shopping and drove around. We were driven around.
Q. Did Michael Jackson pay for the whole trip?
A. Yes, the trip was paid for. I dont know who paid for it.
Q. To your knowledge, did Michael Jackson pay for it?
A. No. No. It was an awards. I think he was given tickets to attend this award because he
was receiving some kind of -Q. Who paid for your hotel room, if you know?
A. I dont know.
Q. Now, you indicated that at one point Jordie and Michael had the flu, right?
A. Correct.
Q. And where did you find out they had the flu?
A. In the hotel room.
Q. And were they staying in the same room at that point?
A. Yes, they were.
Q. Did you ever complain about that?
A. Yes.
Q. And what happened?
A. The room was boarded up. I couldnt get in there. It started to get weird now. Things
started to go downhill pretty quickly.
Q. Did you ever take your son and leave on your own?
A. No.
Q. After you got back from Monaco, did Michael Jackson spend nights at your home?
A. Yes.
Q. Were the 30 nights youve described after you got back from Monaco?
A. No.
Q. How many nights after you got back from Monaco do you think Michael Jackson stayed
at your home?
A. Oh, perhaps a week or two.
Q. And this was a point where you were getting upset that your son wanted to spend all of
his time with Michael Jackson, right?
A. Yes.
Q. Now, while you were in Monaco, you never saw Michael Jackson and your son ever take
a bath together, right?
A. No.

Q. You never saw them shower together, right?

A. No.
Q. And when did you go to France on that trip?
A. I think that was in May.
Q. And what was the purpose of that trip, if you know?
A. To get an award. He was receiving an award.
Q. Was that after the trip to Monaco or before?
A. Im sorry?
Q. Was that after the trip to Monaco?
A. What was? What are you asking?
Q. The trip to France you described. Was there a -A. That is the trip.
Q. Thats the trip?
A. Yes.
Q. It was all in Monaco?
A. Monaco, yes.
Q. Did you ever go anywhere else?
A. We went to Euro Disney also, outside of Paris.
Q. Was the trip to Euro Disney after you were in Monaco for the awards or before it, if you
know?
A. To the best of my recollection, it was after the awards.
Q. And how much time did you spend on that portion of the trip?
A. I would say a couple of nights.
Q. Okay. Now, one point you visited Evan Jordans father, at his home when Michael
Jackson
was there, right?
A. I dont recall.
Q. Do you recall seeing Evan and Michael in a squirt-gun-type fight?
A. That was my home, sir.
Q. That was your home?
A. Yes.
Q. So Evan had come to your home at that point?
A. Correct.
Q. Okay. And Evan, Michael and Jordie were in a squirt gun fight, right?
A. Along with his other son Nicky.
Q. Okay. And you got upset a little bit at that, right?
A. Yes.
Q. Okay. How did you learn that Michael Jackson was going to stay over at Evans hous e?
A. Through my son Jordan.
Q. And approximately when d id that occur?
A. After the trip to Monaco, I think.
Q. How many visits, to your knowledge, did Michael Jackson make to Evans house?
A. To my knowledge -- to the best of my recollection, one or two visits.
Q. Okay. And to your knowledge, did he spend the night there?
A. Yes, he did.
Q. To your knowledge, did Jordan spend the night there?
A. Yes, he did.
Q. And to your knowledge, was Evan there both nights?

A. To the best of my knowledge, yes.

Q. Jordan never missed school while Michael Jackson was staying at your home, right?
A. To the best of my recollection, no, he did not miss school.
Q. Okay.
A. There might have been one or two days where he missed, but -Q. Okay. You said that Michael Jackson saw you in New York at one point?
A. Yes.
Q. And when was that?
A. In June, the middle of June.
Q. Was he staying at the same hotel you were at?
A. He arrived after we were there, yes.
Q. Did you know in advance he was going to be staying at the same ho tel?
A. Yes.
Q. And how did you know he was going to be staying at the same hotel as you and your
children?
A. His secretary informed me.
Q. Did he pay for those hotel rooms, to your knowledge?
A. I dont know who paid for the hotel rooms.
Q. Did you?
A. No.
Q. And which hotel was this?
A. The Rega Royal Hotel in New York City.
Q. And how long did you stay at that hotel -A. Oh, perhaps -Q. -- on that trip?
A. -- four nights.
Q. Okay. Was Mr. Jackson there during the four nights, to your knowledge?
A. Part -- part of those nights, yes.
Q. Okay. And did you introduce Mr. Jackson to other members of your family on that trip?
A. I dont recall.
Q. Did you mention your brothers were there on that trip? 5706
A. They were in New York, yes.
Q. Okay. Did they come to your hotel; do you know?
A. I dont recall.
Q. Okay. Do you know whether or not Michael met your brothers on that trip?
A. I dont recall that, no.
Q. Okay. And what month are we in now, if you know?
A. June. In June.
Q. Okay. And just to clarify, the first time Mr. Jackson ever stayed at your home in Santa
Monica was what month?
A. In April.
Q. Okay. Do you remember telling Michael Jackson, Youre like a magnet?
A. I dont recall.
Q. Do you remember telling Michael Jackson, Youre like Peter Pan. Everybody wants to
be around you and spend 24 hours?
A. Yes.
Q. You told him, Lily would too, except shes not old enough?
A. Yes.

Q. Now, you said there was an incident in a room in New York, right?
A. Correct.
Q. And did you actually see what happened?
A. No.
Q. When did you learn what happened in the room?
A. In the morning I saw lamps, two lamps were broken.
Q. Okay. And Michael told you he had kicked the two lamps, right?
A. My son said that Michael Jackson did a karate kick and kicked the lamps.
Q. Actually, Michael told you that, too, didnt he?
A. I dont recall.
Q. Would it refresh your recollection to show you what you said to the District Attorney?
A. Thank you. Yes.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Correct.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes, I have.
Q. Does it refresh your recollection -A. Yes.
Q. -- about what you said? Michael told you he kicked the two lamps practicing karate,
right?
A. Correct.
Q. And he said he would pay for it, right?
A. Correct.
Q. And you said to him, Lily told me a d ifferent story, right?
A. Correct.
Q. But Lily told you they were just playing, correct?
A. Correct.
Q. Now, when do you remember meeting Bert Fields for the first time?
A. Sometime in August.
Q. Was Michael Jackson still spending evenings at your home in August?
A. No.
Q. When had he stopped spending evenings at your home, if you know?
A. I would say late June.
Q. And had you heard of who Bert Fields was before that meeting?
A. No.
Q. You werent aware hes one of the best-known entertainment lawyers in Los Angeles?
A. I was told that by Michael Jackson.
Q. And how long was your meeting with Bert Fields?
A. I dont recall. It could be an hour.
Q. And thats where Mr. Pellicano was present?
A. I dont recall.
Q. Okay. Is that the only time youve ever met with Bert Fields, to your knowledge?
A. I dont recall.
Q. In the sworn declaration you filed regarding your attempt to set aside that stipulation,
is there any reason why you didnt mention Mr. Fields, Mr. Pellicano or Mr. Jackson in that
declaration?
A. Is my -- I dont understand the question.

Q. Thats where you said the only reason you signed the stipulation was because of what
your ex-husband threatened you with.
A. Correct.
Q. But you told the jury initially that the reason you signed it was because Michael
Jackson wanted you to sign it, true?
A. Correct.
Q. Thats not contained in your declaration, is it?
A. No.
MR. SNEDDON: Objection. Asked and answered and argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You didnt mention Mr. Fields or Mr. Pellicano either in that
declaration, right?
MR. SNEDDON: Same objection, Your Honor.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Right?
THE COURT: You may answer.
THE WITNESS: Correct.
Q. BY MR. MESEREAU: When had you separated from David Schwartz?
A. Around August of 92, approximately.
Q. Do you remember comp laining that Evan, Jordans father, had promised him money for
helping him write the screenplay?
A. Yes.
Q. And you complained that Evan had not paid Jordan the money he owed him, true?
A. I didnt complain. It was a statement.
Q. Well, you asked him to pay him the money, right?
A. No, I did not.
Q. You didnt tell him he owed your son $5,000?
A. It was a discussion.
Q. Okay. Did you want him to pay him that money?
A. It would have been a nice thing, yes.
Q. He didnt do it, did he?
A. No, he did not.
Q. Now, you mentioned a gift certificate for $7,000 -A. Yes.
Q. -- that you got from Michael Jackson, right?
A. Yes.
Q. And did you go to Fred Segal and use that gift certificate?
A. Yes.
Q. What did you get with it?
A. Oh, clothes, jewelry. Thats it.
Q. Thats it?
A. Yes.
Q. Okay. Before today, when is the last time you ever saw Mr. Jackson?
A. Oh, ten years ago.
Q. Okay.
A. Eleven years ago.
Q. Have you talked to Evan at all about what youre saying in court today?

A. No.
Q. When is the last time you spoke to him?
A. Ten years ago.
Q. To your knowledge, did Michael Jackson ever stay at David Schwartzs home?
A. No.
Q. Did he ever vis it there, to your knowledge?
A. No. Not that I recall.
Q. Other than the first time when you met Mr. Jackson at David Schwartzs rental car
company, do you recall ever seeing Michael Jackson meeting with David Schwartz?
A. No.
Q. Do you remember Evan threatening David physically?
A. Yes.
Q. And when did that happen?
MR. SNEDDON: Your Honor, Im going to object as immaterial.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Approximately when did you get settlement money from the
settlement with Michael Jackson?
A. Oh, I would say approximately October of 93.
Q. Have you received any settlement money since then?
A. No.
Q. You mentioned to the District Attorney inLos Angeles a meet ing Michael Jackson had
with Elizabeth Taylor and Nelson Mandela. Do you remember that?
A. Correct.
MR. SNEDDON: Your Honor, I object as immaterial.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember, was Jordie with Michael at that meet ing?
A. I dont recall.
Q. David Schwartz was also at the apartment that Michael Jackson owned in Century City
that you called The Hideout, right?
A. Correct.
Q. And approximately when was that meeting?
MR. SNEDDON: Your Honor, Im going to object as vague as to time. What meeting?
MR. MESEREAU: Ill rephrase it.
Q. When, to your knowledge, did David Schwartz visit Michael Jacksons home in Century
City that you call The Hideout?
A. It could be late August, early September.
Q. Who else was there when you got to the apartment?
A. I dont recall who else was there.
Q. Do you remember in your meeting with Mr. Pellicano telling Mr. Pellicano, Well, its
Michael Jackson. I know Evan. It could be money. It could be?
MR. SNEDDON: Object as hearsay, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you ever personally tell Mr. Pellicano that Evans concerns
could be only about money?
MR. SNEDDON: Same objection, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Was your lawyer, Michael Freeman, at that meet ing with Mr.
Pellicano?

A. I believe so.
Q. Is that the same meeting Bert Fields was present?
A. I dont recall, but possibly. Qu ite possibly.
Q. If your lawyer, Michael Freeman, was at the meeting, you must have been able to get
legal advice about what to sign, right?
MR. SNEDDON: Im going to object to that question. Assumes facts and calls for
speculation. Can I throw in argumentative, too?
THE COURT: The objection is sustained.
Q. BY MR. MESEREAU: Did you ask Attorney Michael Freeman to be at the meeting?
A. No. I dont recall.
Q. Do you know how he got there?
A. I dont think he was there.
MR. SNEDDON: Im going to object to that question. She has not said he was there.
Assumes facts.
MR. MESEREAU: She did. She did.
THE WITNESS: I dont recall him being there.
THE COURT: Just a moment. Objection sustained.
Q. BY MR. MESEREAU: Who is Michael Freeman?
A. An attorney. My attorney.
Q. And when did you first meet Michael Freeman?
A. Oh, I dont recall when.
Q. Did he represent you at some point during the time period youve described today?
A. At some point, yes.
Q. And he was your personal lawyer -A. Correct.
Q. -- is that right? You mentioned -- actually, let me ask you this: Did you mention Norma
Stakos earlier?
A. Yes, I did.
Q. Where did you meet Norma Stakos?
A. Ive never met Norma Stakos.
Q. Have you ever spoken to her?
A. Yes.
Q. In what context did you speak to Norma Stakos?
A. By telephone, about where we should meet, or when Michael Jackson is coming in to
New York, or things like that.
Q. Did she seem to be the person that arranged your trips?
A. Everything. Everything.
Q. Did she seem to be the person who would get plane tickets, for example?
A. Absolutely, yes.
Q. Would she be the person who would arrange transportation on your trips with Michael
Jackson?
A. Yes.
Q. Okay. Do you remember at your meet ing with Mr. Pellicano, that Mr. Pellicano said,
This is all extortion?
MR. SNEDDON: Your Honor, Im going to object to that question. Calls for hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Now, at the time you met Mr. Fields and Mr. Pellicano, to your
knowledge, did Evan have his own attorney?

A. I dont recall.
Q. At some point during the time you were represented by Larry Feldman, do you recall
Evan also having another lawyer?
A. I dont recall that.
Q. Do you recall the name Barry Rothman?
A. Yes.
Q. And where did you first hear about Barry Rothman?
A. Before Larry Feldman. That was Evans attorney.
Q. Now, at some point were you represented by Attorney Gloria A llred?
A. Two seconds. For two seconds.
Q. It was a little bit more than that, wasnt it?
A. Two hours.(Laughter.)
Q. You and Evan and Jordan were represented byGloria Allred initially, correct?
A. Init ially.
Q. You had meetings with her, correct?
A. One or two, yes.
Q. And then you went to Attorney Larry Feldman, right?
A. He came into the picture, yes.
Q. Okay.
A. Yes.
Q. Do you know approximately when Gloria A llred represented you, Evan and Jordie?
A. Before Larry Feldman.
Q. Do you know approximately -A. No.
Q. -- what year that was?
A. Yes, 94.
Q. Okay. Were you referred to Gloria Allr ed by someone?
A. No.
Q. How did you wind up being represented by her?
MR. SNEDDON: Your Honor, Im going to object as immaterial.
THE COURT: Sustained.
Q. BY MR. MESEREAU: How many times did you meet with Mr. Pellicano?
A. Approximately three t imes. Three to four times.
Q. Do you know where those meetings took place?
A. As far as I recall, in his office.
Q. Did you travel to his office?
A. Yes, I did.
Q. Were you there with your attorney, Michael 5718 Freeman, ever?
A. I dont think so, no, no.
Q. Did you have discussions with Mr. Pellicano?
A. Yes.
Q. Did you ever believe he was your investigator?
A. Yes.
Q. And when was that?
A. When we had meet ings.
Q. When you had meetings with Mr. Pellicano, you had already retained Michael Freeman
as you lawyer, hadnt you?
A. I dont think so, no.

Q. What month do you think you first saw Mr. Pellicano?

A. In August. Approximately August.
Q. The declaration I referred to earlier was signed on August 10th, 1993, correct?
A. Okay. Yes.
Q. And its on Freeman & Golden, Lawyers, stationery, correct?
A. I guess so.
Q. Would it refresh your recollection if I show you the declarat ion?
A. Thank you.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Thats correct.
Q. BY MR. MESEREAU: (Indicating.)
A. Thank you.
Q. Have you had a chance to look at the declaration?
A. Yes.
Q. And does it appear that that declarat ion was signed August 10th, 1993?
A. Yes, it was.
Q. And its on Freeman & Golden, Lawyers, stationery, correct?
A. Correct.
Q. And your lawyer helped you prepare this declarat ion, true?
A. Correct.
Q. Was Michael Freeman representing you in your domestic dispute with Evan?
A. No. I dont recall. I dont recall.
Q. When did he stop representing you, if you know?
A. Shortly thereafter. Not -Q. Okay. Now, was Michael Freeman representing you when Gloria Allred was representing
you?
A. I dont recall.
Q. Was Michael Freeman representing you when Larry Feldman was representing you?
A. No.
Q. Do you recall at one point meeting with Robert Shapiro?
A. Yes.
Q. And when was that?
A. In Larry Feldmans office.
Q. How many meetings did you have with Robert Shapiro?
A. I dont recall.
Q. Do you know why he was at the meet ing?
A. I -- I think as part of Michael Jacksons legal team.
Q. Who, Robert Shapiro?
A. I think so. I dont recall.
Q. Okay.
A. It was so long ago.
Q. Well, he was there because Michael Jacksons attorneys were claiming extortion, right?
A. I dont recall.
Q. Robert Shapiro was there because hes a criminal defense lawyer, right?
MR. SNEDDON: Your Honor, excuse me. I want to interpose an objection before the next
question comes out. Speculation. She says she doesnt have any recollection of this, so
why Mr. Shapiro --

THE COURT: Stop talking. Youre just supposed to give your grounds for the objection.
MR. SNEDDON: Im sorry. Object. Speculation.
THE COURT: All right. Overruled. The question -- the last question, would the 5721 court
reporter read it back, please? (Record read.)
THE COURT: You may answer.
THE WITNESS: Correct.
Q. BY MR. MESEREAU: Do you remember also in your meetings, meet ing -- excuse me, let
me rephrase that. In the meetings youve described with Larry Feld man, Michael Freeman,
Robert Shapiro, do you also remember a lawyer named Richard Hirsch being present?
MR. SNEDDON: Your Honor, Im going to object as to all those people and compound.
THE COURT: Its vague. Well take our break now. (Recess taken.)
THE COURT: Mr. Mesereau.
MR. MESEREAU: Thank you, Your Honor.
Q. Just very briefly, you and Evan hired attorneys and tried to negotiate a financial
settlement before you ever talked to any police officer, right?
A. No.
Q. You were negotiating for money before you ever reported anything to any police officer
in Los Angeles, correct?
A. Not correct.
Q. Do you know the dates you hired your attorneys?
A. After we spoke with the police.
Q. Youre saying that under oath?
A. Thats what I believe, yes.
Q. You dont know that for sure, do you?
A. Im sure.
Q. Your negotiations went on long before you ever went to any police officer in Los
Angeles, true?
A. False.
Q. Do you know when you first went to any police officer?
A. After the police, after we spoke to the police.
Q. It was after you spoke to Larry Feldman on a number of visits, correct?
A. Not correct.
Q. It was actually Larry Feldman who contacted the police, wasnt it?
A. No.
Q. You didnt talk to any prosecutor in Los Angeles before you retained Gloria A llred,
correct?
A. Yes. Correct.
Q. You didnt talk to any police officer in Los Angeles before retaining Gloria Allred,
correct?
A. Can you backtrack a bit? Can you -Q. You retained Gloria A llred before you eve contacted any police officer in Los Angeles,
true?
A. Not true.
Q. Who did you contact in the LAPD before you hired Gloria Allred?
A. The police department. LAPD.
Q. You didnt give any police statement before negotiations had already begun to settle
the case, true?
A. Not correct.

Q. Did you call them yourself?

A. Did I call?
Q. The police yourself?
A. Department of Children Services.
Q. How about police?
A. No. Department of children Services.
Q. Im asking you about the police.
MR. SNEDDON: Its argumentative, Your Honor.
THE COURT: Overruled.
Q. BY MR. MESEREAU: You were negotiating for money -THE COURT: Just a minute.
MR. MESEREAU: Oh, pardon me.
THE COURT: All right. She did answer it before the objection. Go ahead, Counsel, next
question.
Q. BY MR. MESEREAU: You said you contacted Department of Children Services, correct?
A. Yes.
Q. Thats not the police department, is it?
MR. SNEDDON: Thats argumentative, Your Honor. And assumes facts not in evidence.
THE COURT: Sustained; argumentative.
Q. BY MR. MESEREAU: And you contacted Department of Childrens Services after first
talking to a lawyer, true?
A. Not correct.
Q. In fact, you personally never called the police department, ever, about anything
involving Mr. Jackson, true?
A. True.
Q. When did you first hire Gloria Allred?
A. After we spoke to the District Attorney.
Q. When did you first hire Larry Feldman?
A. After the police were notified, Department of Childrens Services, and Lauren Weis, the
District Attorney.
Q. Your strategy was to negotiate a settlement before ever contacting law enforcement,
true?
A. No strategy, sorry.
Q. And one of the levers you were trying to hang over Mr. Jackson was bad publicity if he
didnt pay, right?
A. Incorrect.
Q. Okay. When you talked to Mr. Sneddon, did he ever show you the dates when you
contacted your first lawyer in this case?
A. No.
Q. When you talked to Mr. Sneddon, did he ever show you the dates before any contact
was ever made to a police officer?
A. No.
Q. Do you know when your civil case was first filed?
A. Im not sure of the exact date.
Q. Do you know who filed it?
A. Im not exactly sure. Sorry.
Q. Okay. Do you know when you first contacted Department of Childrens Services?
A. Sometime in August.

Q. You dont know when you hired Gloria A llred, correct?

A. Correct.
Q. Do you know if Gloria Allred contacted Department of Children Services?
A. I dont know that.
Q. Do you know when Evan first hired Barry Rothman?
A. I do not know that.
Q. He hired Barry Rothman before any report was made to DCFS, correct?
A. I dont know.
MR. SNEDDON: Im going to object. Calls for speculation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: When did you first hire Attorney Michael Freeman?
MR. SNEDDON: Object as asked and answered.
THE COURT: I believe she said she didnt know.
MR. MESEREAU: Okay. No further questions.
THE COURT: All right.
REDIRECT EXAMINAT ION BY MR. SNEDDON:
Q. Mrs. Chandler, do you know whether or not in Los Angeles, that the Los Angeles Police
Department has sworn peace officers attached to the Child Abuse Unit in the Department
of Child Services?
A. Correct.
Q. Sorry?
A. Yes, I do.
Q. Were those the people that you talked to when you were interviewed?
A. Yes, they were.
Q. And do you have a recollection at this present time as to specifically when in August
you interviewed with them?
A. Specifically, no.
Q. Would it refresh your recollection if I showed you a document about that interview?
A. Yes.
MR. SNEDDON: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay. Thank you.
Q. BY MR. SNEDDON: Does that refresh your recollection?
A. Yes, it does.
Q. With regard to -- Im sorry, to when you were interviewed by members of the Los
Angeles Police Depart ment?
A. Yes, it does.
Q. And what was the date on that?
A. 8-7-93.
Q. Now, lets go back, if we can. And just to clarify, you were not the one who originally
contacted the -- made the report?
A. Correct.
Q. Do you know who did, of your own knowledge?
A. Of my knowledge, it was Jordan Chandler, my son.
Q. Now, lets go back for just a second. Mr. Mesereau asked you about a meeting on
Saturday involving your attorney and myself. Do you recall that?

A. Yes, I do.
Q. And was there also another person that was present with us that I brought along?
A. Yes.
Q. Do you remember the persons name?
A. No, I dont remember his name, but he was a detective.
Q. With the sheriffs department?
A. With the sheriffs department.
Q. So he was also present during that entire meeting?
A. He was -- absolutely, yes.
Q. All right. Now, he also asked you about conversations that you and I had on the phone.
Do you recall that?
A. Correct.
Q. And that we had talked a couple of times on the phone?
A. Correct.
Q. And with regard to those conversations, the first conversation we had, do you recall the
substance of that conversation?
A. That I would be subpoenaed and for -- testifying.
Q. And did I indicate to you that I wanted to talk to you, to do an interview with you?
A. That we would be speaking later on, yes.
Q. Okay. And did you -- did you have to check with somebody to make sure that was okay
because of the confidentiality agreement?
A. Yes.
Q. And who was that?
A. Larry Feldman.
Q. So is that one of the phone calls that you had with Mr. Feldman, was to make sure -A. Yes.
Q. -- to make sure it was okay for you to talk to me?
A. Correct.
Q. Now, Mr. Mesereau asked you about some countersuit that Michael Jackson alleged
against you and members of your family. Do you recall that question?
A. Yes.
Q. Did you ever pay a penny to Mr. Jackson in any lawsuit to settle anything?
A. No. No.
Q. Now, you indicated that these two children from New Jersey that you mentioned, the
Cascios, do you remember the name of the restaurant in New Jersey that they allegedly
owned?
A. Aldos Restaurant.
Q. You talked with Mr. Mesereau about the incident that occurred in New York where the
lamps got broken and the karate kicks and all that?
A. Correct.
Q. Okay. Did you subsequently learn that the version of what happened was not truthful?
MR. MESEREAU: Objection; lead ing.
THE WITNESS: Correct.
THE COURT: Sustained. The answers stricken.
Q. BY MR. SNEDDON: Did you subsequently -- can you tell us how you eventually -- let
me put it this way: Did you ultimately learn other information about that incident?
A. Yes.
Q. You personally?

A. Yes.
8Q. And did you determine from that information that the original version wasnt correct?
A. Correct.
Q. We talked a little bit in your direct examination about the change-in-custody agreement
that Mr. Jackson asked you to sign. Do you recall that?
A. Yes.
Q. Okay. And you said you did sign it?
A. I did.
Q. Now, after having signed that document, did you ever get custody of your child back?
A. No.
Q. Mr. Mesereau asked you about your son Jordan and about some things you may or may
not have seen with regard to taking showers. And I want to ask you a few questions about
that, okay?
A. Yes.
Q. During the time that you were -- you stayed at Neverland Valley Ranch, and your son
slept in Mr. Jacksons room - okay? - did you ever see your son come back to the guest
cottages to take showers?
A. No.
Q. During the time that your son was in Monaco and stayed in Mr. Jacksons room for
several days in a row, did you ever see your son come back to take showers in your
room?
A. No.
Q. During the time that you were in Florida and Mr. Jackson and your son spent the time
together and he was sleeping in Mr. Jacksons room, did you ever see your son come back
to your room to take showers or to clean up?
A. No.
Q. And if I were to ask you that same question with regard to baths - okay? - would there
be any different answers?
A. No.
Q. Or with regard to seeing your son getting dressed in the morning, would there be any
different answers?
A. No.
Q. Now, with regard to the meeting that Mr. Mesereau talked about, where you were at
the hideout, Mr. Jacksons hideout, the Century City place -- in Century City? I dont know
where it is.
A. Yes, it is.
Q. And were talking about the evening that you described where Mr. Pellicano was talking
to Jordan downstairs and you were upstairs with David Schwartz.
A. Correct.
Q. You told us that lasted about 45 minutes?
A. Yes, it did.
Q. Do you recall whether or not Mr. Jackson was present during that conversation?
A. I dont recall him being there.
Q. Now, if I show you your statement that you gave to the Los Angeles District Attorneys
Office, might that refresh your recollection to that event?
A. Yes.
MR. SNEDDON: May I, Your Honor?
THE COURT: Yes.

MR. SNEDDON: Page 90, Counsel.

THE WITNESS: Thank you.
Q. BY MR. SNEDDON: Does having seen that statement refresh your recollection as to
whether or not Mr. Jackson was present with Mr. Pellicano during Jordans conversation or
interview?
A. Yes, it does.
Q. And was he?
A. Yes, he was present.
Q. You told the jury that its been 11 years since youve had any conversations with your
son Jordan, correct?
A. Correct.
Q. Is that by your choice?
A. No.
Q. You told the jury that as a result of the conversation with Mr. Jackson in Las Vegas
where he urged you to trust him - okay? -A. Yes. Ill be okay. Thank you.
Q. -- that during that conversation in Las Vegas where Mr. Jackson urged you to trust
him, do you recall that?
A. I do.
Q. Do you regret ever doing that?
A. Very much so.
MR. SNEDDON: Nothing further.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Briefly, do you recall Evan hired counsel in June to start negotiating with Mr. Jackson?
A. No, I dont recall.
Q. Do you recall being in any meet ings with Evan and his counsel in June to try and settle
the matter?
A. No.
Q. Do you recall Mr. Pellicano making settlement offers to Evan on your behalf in June?
A. No, I dont.
Q. Do you recall any contact between Evan and lawyers in May?
A. No.
Q. Okay. You never discussed that with Evan at the time?
A. No.
Q. Didnt you have a lot of -- were talking about 1993. Didnt you have a lot of contact
with Evan at that point about hiring counsel?
A. No.
Q. And werent you in a dispute with Evan at that point over custody?
A. Yes.
Q. Okay. And when did that dispute begin, if you know?
A. In August of 93.
Q. But you had had problems with Evan for months before that, had you not?
A. Not -- not terrible.
Q. And you dont know when he hired his attorney?
A. No, I dont. No, I dont.
MR. MESEREAU: Okay. No further questions.

MR. SNEDDON: Nothing further, Your Honor.

THE COURT: All right. Thank you. You may step down.

DWAYNE SWINGLER EXAMINATION

DIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. What is your current occupation, sir?
A. Right now I do stand-in work, movie sets.
Q. Okay. And what kind of -- stand-in work, what does that -A. Stand in for stars. Its called second team. They dont use the stars to get the lights
bright. They use stand-ins.
Q. I see. During the year 2003, at some point during that year, did you -- were you
employed by Michael Jackson?
A. Yes, sir.
Q. Is he the man seated to my right with the long black hair?
A. Yes, sir.
Q. Thank you. When did you begin working for Mr. Jackson?
A. In June of 2003. Early June of 2003.
Q. And what was your -- what was your assignment for Mr. Jackson?
A. Supervisor of Neverland.
Q. How did you come to get that position?
A. I met Michael at a studio, Marvin Gayes studio in Hollywood.
Q. What were you doing at the studio?
A. My cousin was engineering Michaels music session, and Michael need ed someone to
whistle on a track, so my cousin called me and said, Would you like to come down and
whistle on Michaels track? And I said, I cant whistle that well, but I would love to come
down and meet Michael Jackson.
Q. Okay. Are you yourself a musician?
A. Yes, I am.
Q. And you met Mr. Jackson on that date?
A. Yes, sir.
Q. Can you tell me about -- was that in 2003?
A. Yes, it was.
Q. About what month was it, if you recall?
A. That was probably early -- sometime in April.
Q. And how did it come about that you were offered employment?
A. I hung out at the studio with Michael and his kids, and Chris Carter, maybe four, five
days in a row, three, four days in a row, while they were working on the session.
Q. Who did you understand Chris Carter to be?
A. Michaels personal security.
Q. And so somebody offered you employment?
A. On the last day there, Chris Carter asked me to come outside. So I walked outside with
him, and at that time he told me that, you know, Michael likes you. He would love to
bring you aboard. What are you currently doing right now?
Q. Were you availab le?
A. Yes.

Q. Did they tell you what type of job they wanted to hire you for?
A. Init ially they hired me to be security, along with Chris Carter, to travel with Michael.
Q. And how did that work out?
A. Well, that didnt work for me because I had triplets. I got three-year-old triplet boys,
so....
Q. All right. So traveling wasnt an option?
A. No. Actually, Michael was the one who said, If he has triplet boys, then I dont want
him to be traveling with me all the time.
Q. So you said you became ranch manager?
A. Yes.
Q. How did that come about?
A. I guess Michael suggested to Chris, If he has triplets, hell be away from his kids a lot.
So maybe we should offer him another job, and thats when supervisor of Neverland
came up.
Q. So who offered you that position, I guess is my question?
A. I guess Michael. But Chris Carters the one who told me about the position.
Q. At some time d id you discuss with Mr. Jackson personally your emp loyment?
A. I dont understand the question.
Q. Did you ever have a d iscussion with Mr. Jackson about your employment as ranch
manager?
A. Yes, I did.
Q. Did he ever d iscuss with you the terms by which you could be terminated if he was
dissatisfied with your work?
A. He didnt discuss with me personally. But Chris Carter and Joe Marcus did.
Q. And did you have an understanding about how you could be terminated?
A. Yes.
Q. And what was that?
A. Grounds of giving up information of where Michael Jacksons whereabouts are, and, you
know, there was a rule on the ranch -- I dont know if it came d irect ly from Michael, but,
you know, Chris told me and Joe Marcus told me as well, that you can never say no -MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: Okay, lets just back up a minute.
Q. I think what my question is, did you know -- did you have some indication from Mr.
Jackson as to who had authority to terminate you?
A. Yes.
Q. And who was that?
A. From my understanding, it was only supposed to be Michael Jackson.
Q. Okay. At some point during 2003, were you terminated?
A. Yes.
Q. Tell me about that. How did that come about?
A. I had -MR. MESEREAU: Objection; vague as to time.
THE COURT: Ill ask you to clarify the time.
MR. AUCHINCLOSS: Okay.
Q. When were you terminated?
A. Early August 2003.
Q. And how long had you been working at that point for Mr. Jackson?
A. Maybe five, six weeks.

Q. When did you start work?

A. I was hired in the end of April, early May. But I had to go back to Michigan for a couple
of weeks, so the hiring process took awhile. You know, background checks, physicals.
Q. When did you start going to Neverland?
A. In May.
Q. In May?
A. Yeah.
Q. And when did you start getting a paycheck?
A. In June.
Q. Okay. And what were you doing there in May?
A. I just came out to the ranch to check things out to see the position that I would be, you
know, filling.
Q. In May, was it understood that you would be the ranch manager?
A. Yes.
Q. And did you go up there and receive some instruction from anybody as to what the
duties were, in May?
A. I received, well, sort of from Joe Marcus, some instruction, but not as much as I did
once I started in June.
Q. What was Mr. Marcuss assignment at that time?
A. Ranch manager.
Q. So he was ranch manager and you were going to take it over?
A. No. Ranch manager, you deal with the majority of the workers outside, the garden, the
landscapers, things like that. The carnival, the festival, whatever.
Q. What was Joe Marcus doing?
A. What do you mean?
Q. Well, you said Joe Marcus was ranch manager.
A. Right, that was his position. Ranch manager, you deal with all the emp loyees basically
outside of the house.
Q. And your position was going to be?
A. Supervisor. Deal with the employees and Michael and the kids in the house.
Q. Oh, in the house?
A. Yes.
Q. So house manager?
A. House manager.
Q. All right. Good. So you began work in June, but you went up there for how many weeks
to get some training?
A. Not really training, just sort of to come check things out, and to see who -- you know,
what position I would be taking and where the office was, and things like that.
Q. And when was it you were terminated?
A. In early August.
Q. And how did that come about?
A. I had had a meeting with Michael about transferring my position. And I liked working
for him. I wanted to work for him somewhere in Los Angeles, because my triplets were
only one years old at the time. So I was missing them, them being in Los Angeles and me
being here, and me staying the night at Neverland often. Wasnt working for me. So I had
a one-on-one meeting with him to be transferred.
Q. And how did your termination come about?
A. I --

Q. Let me ask you this: Were you terminated?

A. Yes, I was.
Q. And how were you terminated?
A. I was terminated by Joe Marcus. He -- I arrived at Neverland one morning for work and
he told me -- he had changed the locks on me. And then I went into -- I mean, some -one of the employees -- one of my employees in the house told me Joe came to change
the locks. And I said, Why? And they said, I dont know. And I had already been told
by the guard at the gate that Joe -MR. MESEREAU: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: So the locks were changed. Did you go talk to Mr. Marcus?
A. Yes, I did.
Q. What did he tell you?
MR. MESEREAU: Objection; hearsay.
THE WITNESS: He told -MR. AUCHINCLOSS: I can go back to my last question, I guess. Ill withdraw that
question, Your Honor.
THE COURT: All right.
Q. BY MR. AUCHINCLOSS: And how specifically -- I want you to go directly to the answer
on this question. How specifically did you learn that you were terminated?
A. I -MR. MESEREAU: Objection; asked and answered.
THE COURT: Overruled. You may answer.
Q. BY MR. AUCHINCLOSS: Go ahead.
A. I learned directly from Joe Marcus that my services would no longer be needed at
Neverland, and that he didnt have to give me a reason. Because I -Q. You asked him for a reason?
A. Yes, I did. I didnt think I had done anything wrong. Well, I know I hadnt done
anything wrong.
Q. Okay. So youd been at Neverland for a little over a month, and youd worked there for
a few weeks before that time as well?
A. Well, not worked. But like -- I wasnt getting paid for that time. That was just to come
out there and check the ranch out.
Q. During the time that you were at Neverland, d id you have personal interaction with
Michael Jackson?
A. Yes.
Q. On how often a basis?
A. If he was there. All the time, if he was there.
Q. More than once a day?
A. Yes.
Q. And who was responsible for handling Mr. Jacksons appointments while he was on the
ranch?
A. At Neverland, I would take the -- all the phone calls. It didnt matter who it was calling;
mother, father, business person.
Q. So if he had an appointment for a day, would you take that -- would that be part of
your duties?
A. Yes.
Q. To schedule those appointments?

A. Yes.
Q. Did you have occasion to observe visitors of Mr. Jackson that were child visitors?
A. Yes.
Q. Did you see child vis itors spend the night at Neverland?
A. Yes.
Q. Did you see child vis itors spend the night in Mr. Jacksons room?
A. Yes.
MR. MESEREAU: Objection. Leading; and vio lates the Courts order.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Who did you see visit
Mr. Jackson who was a child visitor?
MR. MESEREAU: Im going to object. Violates the Courts order.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: When you were at Neverland, did you interact with Mr. Jackson
about issues dealing with activit ies on the ranch?
MR. MESEREAU: Objection; vague.
THE COURT: Overruled.
THE WITNESS: Issues dealing with activity on the ranch?
Q. BY MR. AUCHINCLOSS: Well, whatever -- lets back up. What were your duties as
house manager?
A. To answer all the phone calls. To, you know, schedule the maids. To help the maids out
with cleaning rooms and suites. And basically to, you know, take care of whatever Michael
and the kids needed.
Q. And in terms of the day-to-day issues in terms of running the ranch, can you
characterize how -- Mr. Jacksons degree of involvement?
A. As far as -- I mean -MR. MESEREAU: Objection. Vague; and relevance.
THE COURT: Overruled. You may answer.
THE WITNESS: Mr. Jackson is in total charge of the ranch.
Q. BY MR. AUCHINCLOSS: Why do you say that?
A. Well, when I was terminated, because of my previous conversation with Chris Carter
that only Michael Jackson could terminate me, I called Evvy, which is Michaels personal
assistant -MR. MESEREAU: Objection. Nonresponsive; hearsay.
MR. AUCHINCLOSS: Thats fine.
MR. MESEREAU: And relevant as to time.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: So when you were on the ranch, did you have occasion to see
Mr. Jackson in terms of making orders at the ranch?
A. Yes.
Q. Did he make orders?
A. Yes. He made some to me.
MR. MESEREAU: Continuing relevance objection, Your Honor, as to time.
THE COURT: Time?
Q. BY MR. AUCHINCLOSS: During the time that you were ranch manager, during that fiveweek period.
A. Yes.
MR. MESEREAU: Thats the objection, Your Honor. The time periods irrelevant.

THE COURT: All right. Thats overruled.

Q. BY MR. AUCHINCLOSS: Go ahead. You can answer that question.
A. Yes, I observed it. He made some to me personally.
Q. Did you have occasion to see individuals, his other employees, in terms of their
relationship with Mr. Jackson?
A. Meaning like Joe Marcus and Grace and those?
Q. I mean -- lets talk about your employees. Did you have employees that were working
under you as house manager?
A. Yes.
Q. Who?
A. Cooks?
Q. Yeah, just generally speaking.
A. Cooks, housekeepers, maids.
Q. Okay. And had some of these people been working at the ranch longer than you had?
A. Yes. The majority of -- all of them.
Q. And did you have occasion to see their interaction with Mr. Jackson?
A. Yes.
Q. And what level of service did Mr. Jackson expect?
MR. MESEREAU: Objection. Relevance; vague; no foundation.
THE COURT: Its vague; sustained.
Q. BY MR. AUCHINCLOSS: Can you characterize the demeanor of the employees around
Mr. Jackson when they were in h is presence?
MR. MESEREAU: Objection. Vague; relevance. Particularly the time period.
MR. AUCHINCLOSS: Ill be specific.
Q. During the time you were ranch manager, or house manager.
MR. MESEREAU: Same objection.
THE COURT: Overruled.
THE WITNESS: Can you ask me the question again?
Q. BY MR. AUCHINCLOSS: Yeah. My question is, can you characterize the demeanor -how did these people act, these employees, when they were around
Mr. Jackson in his presence?
A. I mean, they act like they liked him. Mr. Jackson was nice to people.
Q. Did they act like theyd speak their mind around him?
MR. MESEREAU: Objection; lead ing.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did they act -- did they act comfortable around him?
MR. MESEREAU: Objection. Leading; vague; relevance; and foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Do you know if -- do you know if Mr. Jackson would fire people
at Neverland?
MR. MESEREAU: Objection. Foundation; relevance.
THE COURT: Foundation; sustained.
Q. BY MR. AUCHINCLOSS: Well, you yourself were fired; is that correct?
A. Yes, sir.
Q. Do you know who fired you?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Who -- when you were working with Mr. Jackson, did you have

occasion to see individuals who were emp loyees of his that were closer than other
employees? MR. MESEREAU: Objection. Vague; leading; relevance; foundation.
MR. AUCHINCLOSS: Objection, Counsels fishing for a reason to object to that question.
MR. MESEREAU: I object to the colloquy, move to strike.
THE COURT: Ill sustain the vague objection to that question.
Q. BY MR. AUCHINCLOSS: Did you se7 employees -- did you see any employees that
spent more time with Mr. Jackson than other employees?
MR. MESEREAU: Objection. Leading; vague; foundation; and relevance.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes, I did.
Q. BY MR. AUCHINCLOSS: Did you see -- well lets go ahead and make a list. Who did you
see that spent more time with Mr. Jackson than other employees?
MR. MESEREAU: Objection. Relevance; foundation; vague.
THE COURT: Overruled. You may answer.
THE WITNESS: Vase -- Grace, Im sorry. Grace, Chris Carter. Those are the two that I
think spent most of the time with Mr. Jackson.
Q. BY MR. AUCHINCLOSS: Did you ever see an individual vis it the ranch by the name of
Dieter Weizner?
A. I would have to see a picture to be sure.
MR. MESEREAU: Could we approach, Your Honor? Wed like a proffer.
MR. AUCHINCLOSS: Be happy to make one.
THE COURT: I dont really need that. I - its clear to me where....
Q. BY MR. AUCHINCLOSS: I show you Peoples Exhibit No. 17, Mr. Swing ler. Can you
identify that for me, please?
A. I cant say Ive seen that gentleman.
Q. You havent seen him?
A. No.
Q. Did you see -- did you previously have a conversation with Detective Bonner about the
facts of this case?
A. Yes, sir.
Q. And in that conversation, did you identify -- just a moment, if you would, please. Did
you identify a number of individuals that you thought were within Michael Jacksons inner
circle?
MR. MESEREAU: Objection. Leading; and vague.
MR. AUCHINCLOSS: Its impeachment.
THE COURT: Sustained.
MR. AUCHINCLOSS: Im sorry?
THE COURT: Its vague.
Q. BY MR. AUCHINCLOSS: Did you identify Dieter W eizner as a member of Michael
Jacksons inner circle?
MR. MESEREAU: Objection. Leading; and foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: In my conversation with Detective Bonner?
Q. BY MR. AUCHINCLOSS: With Detective Bonner, 5752 did you not identify Dieter
Weizner specifically as a member of Michael Jacksons inner circle?
A. I cant -- I cant really recall, because I dont know the face. I never seen the face
before. The name I know. The face I dont.
Q. Do you know the name Dieter W eizner?

A. Yes.
Q. Did you meet a man by the name of Dieter W eizner?
A. Looking at the face -Q. Im not asking you about the face.
MR. MESEREAU: Objection. Hes arguing with the witness. Leading and foundation.
THE COURT: Overruled.
Q. BY MR. AUCHINCLOSS: Did you meet a man by the name of Dieter Weizner?
A. I cant remember.
Q. Did you meet a man -- well -A. Like I say, the name sounds familiar. I know Ive heard the name. Maybe I spoke with
him on the phone a few times there, but the face didnt -MR. MESEREAU: Objection. Calls for speculation; move to strike; nonresponsive.
Q. BY MR. AUCHINCLOSS: Did you meet a man by the name of Ronald Konitzer?
THE COURT: Theres an objection pending.
THE BAILIFF: Judge, can you turn the microphone on?
THE COURT: All right. The objection is overruled. And you had another question. Go
ahead.
Q. BY MR. AUCHINCLOSS: Did you meet a man by the name of Ronald Konitzer?
A. I cant -- by the name -- I would have to see a picture.
Q. Did you meet two German businessmen?
A. Yes.
Q. Did they meet with Mr. Jackson?
A. Yes.
Q. On how many occasions?
A. Three or four.
MR. AUCHINCLOSS: Thank you. I have no further questions.
THE COURT: Cross-examine?
CROSS-EXAMINATION BY MR. MESEREAU:
Q. My names Tom Mesereau. I speak for Mr. Jackson.
A. How you doing, sir?
Q. Good. Good. Weve never spoken before, right?
A. No.
Q. You worked for a five-week period?
A. Four and a half, five weeks, yes, sir.
Q. Four and a half, five weeks. How many days a week did you work?
A. Six or seven.
Q. And the prosecutor asked you about how many meet ings Mr. Jackson had with two
German individuals, right?
A. Yes, sir.
Q. Do you really know how many meetings there were?
A. Around, Im guessing, three to four.
MR. MESEREAU: Okay. Move to strike the testimony, Your Honor.
THE COURT: Denied.
Q. BY MR. MESEREAU: Youre guessing three to four, but you dont really know, right?
A. No, I couldnt say. I couldnt pinpoint it. I wasnt -Q. You werent in the meetings, right?

A. No.
Q. You dont remember what they looked like, right?
A. I do remember what they looked like if I saw a picture of them, yes.
Q. Well, the picture the prosecutor showed you, you couldnt identify, right?
A. Yes, sir.
Q. Okay. Now, you wanted to be transferred to Los Angeles; is that correct? 5755
A. Yes. Yes, sir.
Q. And did you tell -- excuse me, who did you talk to about the transfer?
A. Mr. Jackson.
Q. Okay. And you explained that the commute and the hours were just too much to raise
your family?
A. I just wasnt seeing my kids, and they were one years old.
Q. And did you ask Mr. Jackson to be transferred somewhere in Los Angeles?
A. Yes.
Q. Okay. And where was that?
A. I just asked him to be transferred to any business in Los Angeles that he had.
Q. But you really didnt even know if there was a job available in Los Angeles, right?
A. No, thats why I was asking.
Q. Okay. R ight. Okay. And approximately when did you ask him; do you know?
A. Maybe three weeks into the job.
Q. Okay. And Mr. Jackson was always nice to you, wasnt he?
A. Yes, sir.
Q. And as far as you know, there may not have been a job available in Los Angeles, right?
A. He told me there was one.
Q. He told you there was one?
A. Yes, sir.
Q. Where did he say?
A. A&R, his record label.
Q. Pardon me?
A. A&R of his record label.
Q. Had you ever worked at a record label before?
A. No, I hadnt.
Q. All right. But at some point you learned that you werent being hired, right?
A. No. As a matter of fact, I saw Michael again at his birthday party in Los Angeles and he
told me I was still hired.
Q. Okay. But it never came through, right?
A. No, Im still waiting for my paycheck now.
Q. Okay. Youre trying to write a book about your experiences at Neverland, correct?
A. Well, no, Im not trying to write a book about my experiences at Neverland.
Q. Well, didnt you -- excuse me. Did you say Michael Jackson has a record label?
A. He told me he had a record label.
Q. Okay. Do you know that he doesnt have one?
MR. AUCHINCLOSS: Objection; assumes facts.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know whether or not he really has a record label?
A. I was just told by him he had a record label.
Q. Okay. All right. Now, you prepared notes for a book called Entering Neverland, Secrets
Behind the Gate, right?

A. Does it have my s ignature on it? Because I know that within the last month or two, I
started jotting down information to myself and somehow my informat ion come up missing
out of my house, but whatever.
Q. Did you prepare notes for a book titledEntering Neverland, Secrets Behind the Gate -A. No.
Q. -- By Dwayne Swingler, Head Supervisor of Neverland Ranch, Summer of 2003, did
you prepare that?
A. No.
MR. AUCHINCLOSS: Objection; asked and answered.
THE COURT: Overruled. The answer is, No.
Q. BY MR. MESEREAU: Are you aware of anything like that?
A. No.
Q. You didnt -A. Am I aware of it? What do you mean?
Q. Yeah. Have you written out anything for a book called Entering Neverland, Secrets
Behind th Gate, by Dwayne Swingler?
28 A. No, I havent written anything, or titled anything, or signed anything, or spoke to
anybody about, This is my deal.
Q. Have you talked to a group called News of the World?
A. Have I?
Q. Yes.
A. Yeah, I spoke with one lady one time, yes.
Q. And to your knowledge, who is News of the World?
A. To my knowledge, its a news med ia overseas.
Q. And why were you speaking to them?
A. Because I was interested in maybe possibly writing down some informat ion to -- to
cash in on something like everybody else was, because Michael wasnt -- I hadnt received
the paycheck from A&R at the time.
Q. Okay. Did you enter into a nondisclosure agreement with News of the World?
A. No, I did not.
Q. Have you ever seen one?
A. No, I did not.
Q. Did you ever talk to someone named David Han-Schmidt?
A. The same time I spoke with the News of the World lady, hes the one that contacted
her andcontacted me.
Q. And to your knowledge, who is David Han-Schmidt? 5759
A. He said that he was a med ia agent. I dont even know how he got my phone number.
Q. When did you last talk to David Han-Schmidt?
A. He -- as a matter of fact, he called me today.
Q. And to your knowledge, is he with a public relations company?
A. I really dont know what he did. He never clarified that with me. He said he was an
agent, he was a producer, he was in public relations. I basically ended the situation.
Q. To your knowledge, did anyone ever send you a nondisclosure agreement regarding
News of the World?
A. No. I havent signed any nondisclosure agreements, and I havent taken any money
from anyone.
Q. How many discussions have you had with David Han-Schmidt?
A. Three. Four. Cant remember.

Q. And when was the last one with him? Today?

A. He called me today, because he said he heard that I was coming to testify.
Q. Okay. Have you ever put together any notes for a possible book on the computer?
A. Excuse me?
Q. Have you ever put any notes for a possible book on your computer? 5760
A. No, I havent.
Q. Have you ever written any notes out for a possible book?
A. I told you I jotted down some information on a piece of paper, and thats all Ive done.
Q. Did you ever ask any public relations person to put together a proposal for you?
A. No, I havent.
Q. But youre thinking of doing it, right, like everybody else?
A. Yes, I was thinking about doing it.
Q. Okay. Okay. Have you ever seen -- excuse me. Has anyone ever brought to your
attention that somebody has prepared notes for a possible book in your name?
A. David.
Q. David Han-Schmidt?
A. Yes.
Q. Did he prepare them, to your knowledge?
A. He just said he received papers. I dont know -- like I told you, I dont even know how
he got my phone number.
Q. Okay. If I showed you these papers, might it refresh your recollection about where
they came from?
A. No, it probably wouldnt, because I never typed any papers or wrote out -- the only
thing I did was write down notes, jotted down notes on a piece of paper.
Q. Okay. And that was about your experience during the five weeks at Neverland?
A. That was about my experience totally, not just the five weeks at Neverland. That was
my experience with Michaels manager and everything.
Q. Okay. Did you ever write down on those notes the words Secrets Behind the Gate?
A. No, I did not.
Q. Okay. Did David Han-Schmidt tell you how he got your name?
A. No, he did not.
Q. Okay. Did you ever ask him, Why did you call me?
A. Well, actually, he started the conversation off, and he just, whew, went straight to
talking about a lot of money, so I was listening to him about a lot of money first.
Q. Did he promise you a lot of money?
A. Thats what he promised, yes.
Q. Okay. How much money did he promise?
A. He never said figures. He just said, you know, You can make a lot of money. You
know, Why arent you telling anyone your story? Thats what he said to me.
Q. Its your understanding that hes located in Phoenix, Arizona?
A. Yes. Thats where he said hes from.
Q. Okay. D id he ever tell you he was going to prepare a possible manuscript for you?
A. He asked me would I like him to, and I said no. Like I told you, I terminated the
conversation when he told me what he wanted to do.
Q. Okay. And did he want some scandal sheet about Michael, something like that?
A. Actually, hes for Michael. Hes pro Michael.
Q. Did he want you to write something about Michael?
A. He wanted to speak on Michaels behalf, yes.

Q. Okay. And how often -- in those three conversations, did you talk about money each
time?
A. No, I did not.
Q. Okay. Have you ever spoken to Miss Carol Maung, M-a-u-n-g, who is the U.S. editor of
News of the World?
A. I spoke with her. I spoke with her when she was with David when I got there.
Q. And did she fax you anything or e-mail you anything?
A. Fax me anything or e-mail me anything?
Q. Yes.
A. No, sir.
Q. Okay. All right. When you were at Neverland working -A. Yes.
Q. -- you had no direct contact with any member of the Arvizo family, right?
A. The Arvizo family?
Q. Yes.
A. No, sir.
Q. That means you didnt have any contact with the Arvizos?
A. Yes.
Q. Okay. Do you remember meeting Dominick Cascio at Neverland?
A. Yes, sir.
Q. And hes the -- did you speak to him?
A. Often.
Q. Okay. And to your knowledge, hes a father?
A. Hes a father?
Q. Yes.
A. I didnt know he was a father.
Q. Okay. Did he ever talk to you about work he did?
A. Did Dominick ever talk to me about work he did?
Q. Yeah.
A. Some work at the restaurant that his family owned.
MR. MESEREAU: Okay. I have no further questions, Your Honor.
MR. AUCHINCLOSS: Counsel?(Off-the-record discussion held at counseltable.)
MR. AUCHINCLOSS: Maybe we should approach. Your Honor, may we approach?
THE COURT: For what?
MR. AUCHINCLOSS: Concerning the materials that counsel is using to cross-examine the
witness on.
THE COURT: All right. (Discussion held off the record at sidebar.)
MR. AUCHINCLOSS: If I could just have a moment, Your Honor.
THE COURT: Yes.
MR. AUCHINCLOSS: I think I can finish with this witness, Your Honor. Just one question.
REDIRECT EXAMINAT ION BY MR. AUCHINCLOSS:
Q. Mr. Swingler, do you know if David Schmidt has any affiliation with Michael Jackson?
A. I just know that he has a website; that hes, you know, pro Michael Jackson.
MR. AUCHINCLOSS: All right. Thank you. I have no further questions.
MR. MESEREAU: No further questions, Your Honor.
THE COURT: All right. Thank you. You may step down.
THE WITNESS: Thank you, sir.

THE COURT: Do you have another witness?

MR. AUCHINCLOSS: (To Mr. Sneddon) Go ahead.
MR. SNEDDON: You.
MR. AUCHINCLOSS: Do you want me to do it? (Laughter.)
MR. SNEDDON: Were trying to figure out which one of us should take responsibility for
telling you No. (Laughter.)
MR. SNEDDON: And being the great delegator I am, Im leaving it up to Gordon.
MR. AUCHINCLOSS: We have no further witnesses, Your Honor. We just anticipated that
there would be -- it would take a little longer to get through these witnesses today.
THE COURT: All right. Theres a couple of items that we can take up. Ill go ahead and
excuse the jury.(To the jury) Remember the admonitions Ive given you and Ill see you
tomorrow morning at 8:30. But its a half day tomorrow, remember. How could you
forget, right (The following proceedings were held in open court outside the presence and
THE COURT: All right. First, there was -- my understanding is that the special master will
have the report available tomorrow morning for you on the computer hard drives.
MR. SNEDDON: On both of them, Your Honor?
THE COURT: Yes. Theyre working on some last-minute details. So it will be availab le
tomorrow morning.
MR. SNEDDON: Now, at that point, then, Your Honor, does it need to go to you for final
decision, or is that the decision?
THE COURT: I dont know. I havent read the report. I was handed a rough draft of one by
my research attorney this morning -- well, not the morning, a few minutes ago. And I
asked him to talk to Mr. Sanger about an issue. So I cant answer your question.
MR. SNEDDON: Okay.
THE COURT: I suspect it doesnt need to go beyond whats been done by the special
master, so -MR. SNEDDON: Okay.
THE COURT: But I wont know till Ive looked at it. The second thing is that both of you
have submitted points and authorities on Janet Arvizo. The District Attorneys Ive read.
And I just received the defense, so I havent had time to read yours. When do you expect
to call Janet Arvizo?
MR. ZONEN: Either tomorrow or Wednesday. Depending on if we finish the witnesses
scheduled before her tomorrow. If not -THE COURT: They cant hear behind you. (To the audience) He said either tomorrow or
Wednesday.
MR. ZONEN: As early as tomorrow.
THE COURT: As early as tomorrow. Okay. Well, Im not really prepared to deal with that
issue. Well have to deal with it before shes called, but Ill need to study the material
youve given me, the defense has given me.
MR. ZONEN: Thank you.
THE COURT: Was there anything else pending?
MR. SANGER: On that issue, Your Honor, as I explained to you, as I explained to your
clerk, we were served with their papers this morning. We thought they might call Ms.
Arvizo today.
THE COURT: Right.
MR. SANGER: So we put something together very quickly, and I would like to have an
opportunity to explain to the Court a little more, in a little more organized fashion, where

this goes, now that weve had a few more minutes to think about it.
THE COURT: Ill make sure you have that opportunity. MR. SANGER: Okay. Thank you.
THE COURT: All right. Then well recess until tomorrow morning. (The proceedings
adjourned at 2:30 p.m.)__

2005 April 12 (days 30) Jay Jackson testimony (Gavi n step father)

JAY D. JACKSON EXAMINATION

DIRECT EXAMINATION BY MR. ZONEN:

Q. Sir, what is your current occupation?
A. I am in the -- Im on active duty with the Army reserve.
Q. How long have you been in the Army reserve?
BAILIFF CORTEZ: Speak right in here, please.
THE WITNESS: Thank you. Ive been in the Army reserve for 23 years, some of that
active duty, some of that reserved part time.
Q. BY MR. ZONEN: Most recently youve been on active duty for what period?
A. About five years.
Q. All right. Were you in Desert Storm?
A. The first one, yes, sir, I was.
Q. And what position did you hold at that time?
A. I ran a prisoner of war camp processing area. We ran enemy prison of war through the
prisoner of war camp.
Q. In which country?
A. In Saudi Arabia.
Q. Your current rank with the Army reserves is what?
A. Major.
Q. And what are your responsibilities?
A. Currently Im working in a command where we do mobilizations, we mobilize soldiers to
go to war.
Q. Are you currently married to Janet Ventura Jackson?
A. Yes, sir, I am.
Q. She has taken your name after your marriage; is that correct?
A. That is correct.
Q. Do you have children together?
A. We do. We have one. A little boy.
Q. And do you have other children living in your household?
A. Yes, sir, we do. Three additional children.
Q. And they are who?
A. Gavin, Star and Davellin.

Q. When did you first meet Janet Arvizo?

A. Back in July of 2002.
Q. How did you meet her?
A. I was working one Saturday, and she came -- she knocked on the door, and I -- its a
secured facility, and I let her in. She had Star with her.
Q. All right. What were the children involved in at that time, the boys?
A. Theres a Sea Cadet Command right there that is for children between the ages of, say,
11 and 18 years old. And she was bringing her children there for that program.
Q. And both of them were involved, Star and Gavin?
A. Yes, they were.
Q. All right. Then thats how you met her?
A. That is how I met them.
Q. And began dating after that?
A. We talked. I met her. She said -- I was sitting in the hallway and walked by her, and
got into a conversation, and then -- I got her phone number, I think. And then about a
month later, we talked on the phone for about a month. And then a month later she was
telling me that Gavin and Star were graduating from the Sea Cadet program, a little twoweek training or one-week training. And so we decided that our first date we would go
down there for that graduation, and we did.
Q. And youve been married how long now?
A. Oh, goodness. May 29th will be one year.
Q. Id like to direct your attention back to February of 03, 2003.
A. Okay.
Q. Will you tell us in what neighborhood you were living at that time?
A. The mid-Wilshire district, also known as Korea Town.
Q. And the street that you were living on was what?
A. St. Andrews Place.
Q. Was Janet Arvizo living with you at that time?
A. She was.
Q. Was she living with you full time at that time?
A. No, she wasnt. She had a place over on Soto Street in East L.A.
Q. And the boys, where were they living?
A. The same place. Both places.
Q. All right. Do you remember or do you recall where they were attending school at that
time?
A. Well, I dont know the name of the school, but it was in East L.A. And then because
there was a lot of problems at that school - they were, you know, being pushed into
getting into gangs, and there was some altercations - we thought it was a good idea if we
enrolled them in John Burroughs, which is a real good school in the mid-Wilshire district.
Q. And that was closer to your home; is that right?
A. Yes, sir, it was. Very close.
Q. And did you do that?
A. Sir?
Q. Did you do that, enroll them at John Burroughs?
A. Yes, sir, we did.
Q. That is John Burroughs Middle School?
A. That is John Burroughs Middle School.
Q. Was your address, then, on St. Andrews Place the address that was used?

A. That is correct, yes, sir.

Q. Did Janet Arvizo maintain the Soto Street address?
A. She did, sir.
Q. For what period of time?
A. Through about November of 04, I believe.
Q. Had you ever gone to Neverland?
A. Ive been to Neverland one time.
Q. And when was that; do you recall?
A. It was in -- it was before November of 02, so it was in the summer, I believe, of 02. I
was still living in West L.A., and we were invited by Chris Tucker and his girlfriend; that
they were having a little-baby birthday party.
Q. Were you the only ones invited to Neverland for that occasion?
A. Oh, no, sir. There was two busfuls of people.
Q. You met the bus where; do you recall?
A. It was -- you know, I think it was the Beverly Hills Hilton or something like that. It was
one of the hotels in the local area.
Q. Did you spend the day at Neverland?
A. Yes, sir, we did.
Q. Did you spend the night at Neverland?
A. We left in the evening, late in the evening.
Q. And then returned back to Los Angeles?
A. That is correct.
Q. How many people, approximately, to your recollection, attended that party?
A. 40 or 50, maybe.
Q. Did you see Michael Jackson at any time during that occasion?
A. No, sir, I did not.
Q. Had you ever met Michael Jackson?
A. No, sir, not until today.
Q. At some point in early February of 2003, did you become aware of the fact that a
documentary was being shown on television?
A. Im not sure if I knew at that moment, but I know that Janet received a call from either
Michael or somebody in his entourage asking him to go to Miami -- asking her to go to
Miami, and with the kids.
MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: Ill strike after the word moment.
Q. BY MR. ZONEN: Did Janet Arvizo and the children go to Miami?
A. Yes, they did. 5780
Q. Do you know what prompted that?
A. Um -MR. MESEREAU: Objection. Foundation and hearsay.
MR. ZONEN: Yes or no; does he know.
THE COURT: I sustained the objection. Im sorry.
MR. ZONEN: Oh, Im sorry. I didnt hear.
Q. Do you know on what day they left for Miami?
A. I just know approximately it was early February.
Q. Had there been any discussion in the household about Michael Jackson prior to going to
Miami?
A. No, sir, not really.

Q. Had there been any problems in the household that dealt in some fashion with either
Neverland or Michael Jackson prior to Janet Arvizo going to Miami?
A. No, sir, not at all.
MR. MESEREAU: Objection; vague.
THE COURT: Overruled. The answer was, No, sir, not at all. Next question.
Q. BY MR. ZONEN: Had there been any discussion about Michael Jackson prior to her
going to Miami in your household, say, within a week or two prior to their departure?
A. No, sir.
Q. And could you tell us approximately what percentage of the week Janet Arvizo was
living at your home as opposed to her residence on Soto Street?
A. Three or four days a week.
Q. Is that during the time that the kids were at school?
A. Yes, sir. Thats correct.
Q. Did Janet Arvizo have parents living in the Los Angeles area?
A. Yes, sir. In the El Monte area.
Q. And had you visited their home on occasion?
A. Yes, sir.
Q. And El Monte is where in Los Angeles County?
A. I -- Im not sure exactly. I mean, its in -- El Monte is in -- its in -- I mean, Los Angeles
area. Im not sure exactly how to -- because Im not from California, I really cant lay out
where everything is from.
Q. We do hear an accent in your voice. Where are you from?
A. Virginia.
Q. Is that where you grew up?
A. Yes, sir, I did.
Q. Did you know in advance that Janet Arvizo and her children were going to be going to
Miami?
A. No, sir, I didnt. I received -- excuse me one second. 5782
Q. Go ahead.
A. Janet just told me that she was going to my -MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: Ill strike after I didnt.
MR. ZONEN: Im sorry, I dont have the ability to read it. Im not hearing everything
youre saying at the moment.
THE COURT: Im sorry. The question was, Did you know in advance that Janet Arvizo
and her children were going to be going to Miami? No, sir, I didnt. Then after that I
struck his answer.
Q. BY MR. ZONEN: When did you first learn that they were going to Miami?
A. I believe Janet told me right before they were ready to leave that they were going.
MR. MESEREAU: Objection. Nonresponsive; hearsay; move to strike.
THE COURT: Overruled.
MR. ZONEN: And the answers in?
THE COURT: The answers in.
THE WITNESS: Janet -- should I -THE COURT: No.
THE WITNESS: No? Thank you.
Q. BY MR. ZONEN: Well move on to the next question. And did they, in fact, leave that
day?

A. That day or the next day, yes, sir. Within a day or two, yes.
Q. Did you have conversations -- without getting into the content of them, did you have
conversations with Janet Arvizo while she was in Miami?
A. I believe she called me, yes, sir.
Q. Did you have conversations with any of the kids while they were in Miami?
A. No. No, sir.
Q. Without getting into the content, did you know the purpose of the trip to Miami?
A. I knew that they were going to be going there to do a press conference.
Q. Did you know -- again, without getting into the content, did you know what the
purpose of the press conference was?
A. Im not sure that I knew exact ly at that time, but I knew very shortly thereafter what
was going on with the documentary.
Q. Did you understand that it had something to do with the documentary?
A. I believe I may have known, but I didnt know the specifics.
Q. All right. Was there, in fact, a documentary about Michael Jackson shown on television
that you saw within a few days thereafter?
A. Yes, sir, I did.
Q. And how did you know that it was going to be on television?
A. I believe I saw something on T.V. that sai it was coming on.
Q. Did you know in advance that that documentary would feature any of Janet Arvizos
children?
A. I believe that there was some indication that -- yes, that the children were going to be
on there.
Q. Did you watch the documentary in its entirety?
A. Yes, sir, I did.
Q. Did it, in fact, feature Janet Arvizos children?
A. It did, yes, sir.
Q. At the time you watched that documentary, was Janet Arvizo and her children in
Miami? Were they in Miami?
A. Yes, sir, they were in Miami.
Q. At some point in time were you contacted by reporters from any news agency,
presumably reporters from the news agency?
A. I wasnt contacted by them. But I did talk to several -- two reporters, British reporters,
at Janets Soto Street apartment.
Q. Do you remember when that was?
A. It was right -- I guess right after -- it was right before the documentary aired in the
United States.
Q. All right. And what did they want to do with you?
A. They -- well, when I was -- I took Janet and the kids back to that Soto Street
apartment. And Davellin was at the apartment, and she said that -- either two journalists
or two guys had just knocked on the door asking for Janet. I saw them at the end of the
hall. I walked down to ask them what they were -- who they were with, and what they
wanted.
Q. All right. What did they tell you?
A. They said that they were with a Brit ish tabloid, and that they wanted to do a story on
the family as it pertained to Michael Jackson.
Q. All right. Did they actually use the word tabloid?
A. Im not sure if they did. I think I found that out later.

Q. That may have been your conclusion?

A. It may have been, yes, sir.
Q. I cant imagine a reporter saying theyre with a tabloid.
A. Right.
Q. Did they say to you what it was exactly that they wanted to talk to you about?
A. They didnt say specifically, no. They just said that they wanted to have a conversation,
they wanted to do an interview with the family, and they wanted to take some
photographs of the family.
Q. And did you understand this to relate to Michael Jackson in some fashion?
A. Yes, sir.
Q. Did they tell you that thats what they wanted to do?
A. Yes, sir, they did.
Q. Now, I believe you said this was prior to the screening of the documentary Living
With -A. Yes, sir, it was.
MR. MESEREAU: Objection; misstates the evidence.
THE COURT: Sustained.
Q. BY MR. ZONEN: Was this prior to the screening of the documentary -A. Yes, sir, it was.
Q. -- that you saw? The documentary were talking about, can you tell us the name of it, if
you recall?
A. Living with Michael Jackson.
Q. Was it a documentary that featured a man by the name of Mart in Bashir?
A. Yes, sir, it did.
Q. At the time you talked to these two reporters, did you have a sense of what was going
on at that point?
A. No, sir, I did not.
Q. Did you either request payment for an interview or did they offer you payment for an
interview?
A. Well, I said -- again, we have to put it in context. They -MR. MESEREAU: Objection.
MR. ZONEN: Let me withdraw the question.
THE WITNESS: Okay.
Q. BY MR. ZONEN: Tell us what the discussion was with regards to payment.
A. The discussion was -- I asked them what was it that they were going -- how they were
going to compensate the family -Q. Okay.
A. -- for doing this. And he said -- he said, We can probably give them four to five
hundred dollars.
Q. What did you say?
A. I said, I dont think thats going to happen.
Q. What did you understand -- what did you think that they wanted to ask this family?
A. I dont think I really knew. I believe that they were looking for something negative on
Michael Jackson as it related to the children.
Q. Did you know anything negative about Michael Jackson at that time?
A. No, sir, we did not. I did not.
Q. Had Janet Arvizo or her children at any time expressed any kind of negative comment
to you about Michael Jackson up to that point?

A. None.
Q. Were you aware as to whether or not the children had visited Neverland prior to that
date?
A. I knew they had a relationship with Michael Jackson.
Q. Did you have any reason to believe that relationship was anything but positive?
A. Thats all I believed it was.
Q. Did you tell those two reporters that?
A. I did.
Q. All right. And was that before or after or during the conversation about payment?
A. Im not real clear. It was a back-and-forth about that. But I said, you know, If youre
looking for dirt, you know, This -- I dont believe theres anything negative to say.
And they continued to ask for it. And they said, Let me get back with my boss and well
get back to you tomorrow. And I dont know if I gave him my phone number, or whether
he got it, or -- I probably gave it to him. Although some reporters tend to be able to find
your phone number.
Q. All right. Did you ask for more money than three or four hundred dollars ?
A. No, I just said that wasnt going to be acceptable.
Q. And what did you mean by that?
A. Well, I think I was -- you know, I was intrigued by it. I have never had anybody come
up asking to pay for any kind of story of any kind. And maybe I was -- I was the one that
initially asked, you know, Is there any compensation for the family? But I think that I
just thought that was the standard in the industry. I meant no malice by it.
Q. Did they tell you at any time during this initial interview that it had something to do
with the documentary that featured in England?
A. That featured what, sir?
Q. That was shown in England, that was aired on televis ion in England.
A. They mentioned something about a documentary in England, but they really were
vague.
Q. And did you have any other independent information about it at that time?
A. I did not.
Q. Did you have a follow-up conversation with them?
A. I did.
Q. And when was the follow-up conversation?
A. I believe it was the next day, or the day after that.
Q. Was this before or after Janet Arvizo and her children went to Miami?
A. They had not left yet.
Q. Okay. Had you told Janet Arvizo about your initial conversation with these two
reporters?
A. I mean, while Janet and the family were in the apartment. But no, I did not talk to
them specifically about any conversation I was having with the British reporters.
Q. All right. Do you know the name of the reporter or reporters who you talked to on this
first occasion?
A. David Gardner, Garner or Gardner, and Alec Byrne.
Q. And then you said there was a follow-up conversation over the telephone?
A. Right.
Q. Perhaps a day or two later?
A. Perhaps -- yes, it was a day or two later.
Q. Do you recall with which person this conversation took place?

A. Im sorry, sir?
Q. With which person did you have this -A. My conversations were with David Gardner.
Q. Did Mr. Gardner talk more about wanting to have an interview with the family?
MR. MESEREAU: Objection; lead ing.
MR. ZONEN: Ill withdraw the question.
Q. What did Mr. Gardner say?
A. He continued to say he wanted to have an interview with the family and that he was
going to offer additional money; that his boss, I guess, had allowed something like
$15,000, and that he wanted to bring them to a hotel or somewhere and do a full spread
with them. And I declined that.
Q. You declined $15,000?
A. I did.
Q. To say nice things about Michael Jackson?
A. Well, you know, at that time I -- I really -- wasnt really in a position to make that
decision. I knew Janet wouldnt do that.
MR. MESEREAU: Objection; move to strike.
MR. ZONEN: W ell -MR. MESEREAU: Nonresponsive.
THE COURT: Thats stricken. After the word decision, thats stricken, the last sentence.
Q. BY MR. ZONEN: Why did you say no?
A. The more I thought about it, the less I liked the idea.
Q. Why? What was it that didnt appeal to you? $15,000 seems like a lot of money.
MR. MESEREAU: Objection. Admonish the prosecutor not to make gratuitous remarks.
THE COURT: Dont make gratuitous remarks. (Laughter.)
MR. ZONEN: Im admonished.
THE COURT: And that goes for all of you. (Laughter.)
Q. BY MR. ZONEN: What about $15,000 didnt you want to have?
A. Sir, I dont think -- you know, at that time I remember going through the thought
process of, you know, this would be -- we could use this money. But, you know, the more
I thought about it, these children were going to be on television, and it wasnt -- it just
wasnt going to be an appropriate thing to do to this family.
Q. All right. Now, in the course of this conversation, this was also prior to your viewing
Living with Michael Jackson?
A. That is correct, sir.
Q. Was it prior to your knowing about Living with Michael Jackson?
A. Yes, sir.
Q. All right. Did you ever communicate with Janet Arvizo this particular offer?
A. I did not.
Q. All right. Did you ever make any kind of a counteroffer for more money?
A. No, I did not.
Q. Were there any other discussions with this reporter after this phone call?
A. Yes, he -- you know, after they left for Miami, I received a phone call from him. And I
said -- you know, he continued to want to have a conversation about doing an interview.
And I told him, Sir, I cant -- you know, The family is noT even in the area now. Theres
nothing that I can do. He continued to call. He called again. Several months later, he
says, Well, Id just like to have a cup of coffee with you. I said, Im not interested in
that. And then when the raid on Neverland occurred, again he called me back, and in

some ways made a threat. He said, you know, I havent given your information to any
other organizations. And I said, Sir, this is a military phone line. Please do not call here
again. That was the last consideration I had with him.
Q. Have you had a conversation with any other reporters attempting to get a story from
you?
A. I have not had any detailed conversations. I have had a numb er of reporters contact
me. How they get my number I do not know. But they called my office primarily. And they
have shown up at various -- at various locations like my apart ment.
Q. Have you accepted money from anybody?
A. Zero. We have not accepted a penny.
Q. For any kind of a story?
A. For anything.
Q. Have you given a story to anybody?
A. No, sir, I have not.
Q. Have you promised a story to anybody?
A. No, sir.
Q. Have you made arrangements to accept money in the future in exchange for a story?
A. No, sir.
Q. Do you have any intention of giving a story in the future?
A. No, sir.
Q. Do you have any intention of accepting money for a story in the future?
A. No, sir.
Q. Now, when they left for Miami, they being Janet Arvizo and here children, when did
you expect them to return?
A. I didnt have a specific date, you know. They were -- they knew Michael, and if thats
what they were going to do, I wasnt going to get involved with all of that. But I didnt
anticipate them being gone more than three or four days.
Q. When you saw Living with Michael Jackson, did any part of that documentary disturb
you?
A. Yes, absolutely. The -MR. MESEREAU: Objection. Relevance; move to strike; and leading. 5795
THE COURT: Leading is overruled. Relevancy is sustained.
Q. BY MR. ZONEN: All right. Where did they go? Did they return to Los Angeles after their
trip to Miami?
A. Yes, sir. They came back from Miami and I believe went straight to Neverland.
Q. All right. So they didnt come to Los Angeles?
A. No, sir.
Q. Did -A. Not that Im aware of.
Q. Were you contacted by Janet Arvizo?
A. I was contacted by her on a couple of occasions.
Q. Now, during the course of the conversations that you had from her, can you tell us
approximately how many phone calls you had from her while she was at Neverland?
A. During this period of time?
Q. Yes.
A. I cant tell you the specific number. But it was -- it was several phone calls that I
received from her over a two- or three- or four-day period.
Q. Okay. How did she sound to you?

A. She was distressed.

Q. Had she been distressed prior to going to Miami?
A. No, not at all.
Q. Had there been any noticeab le problems in your family prior to her going to Miami?
A. No, sir.
Q. Were the kids healthy?
A. Yes, sir.
Q. Were the kids in school?
A. The kids were in school.
Q. In the course of her conversations with you over the telephone, did she tell you why
she was distressed?
A. She did not.
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: That would be state of mind.
MR. MESEREAU: And foundation.
THE COURT: I think Ill allow the yes or no answer to whether or not she told him.
That doesnt get to the real issue.
MR. ZONEN: Yes.
Q. Was that a yes or no?
A. Could you repeat the question, please?
Q. Did she tell you -- well, maybe the court reporter should repeat the question. (Record
read.)
Q. BY MR. ZONEN: Yes or no.
A. Yes. Yes.
Q. What did she tell you was the reason for her distress?
MR. MESEREAU: Objection. Hearsay; relevance; foundation; relevance.
THE COURT: Sustained.
Q. BY MR. ZONEN: During the period of time that you had conversations with her, did she
appear to you to be any less stressed as time went on?
A. Yes, sir.
Q. At some point in time, did she return to Los Angeles?
A. Yes, sir, she did.
Q. With her children?
A. Yes, sir, with her children.
Q. Did they go to your home or some other location?
A. They went to El Monte. They went to her mothers house.
Q. And did you visit them soon thereafter?
A. I picked them up. Yes, sir, I did.
Q. How long did they stay in the Los Angeles area?
A. Several days, probably three or four days. Youre talking about at my apartment or at
her mothers?
Q. At -A. Total?
Q. At her mothers and at your apartment.
A. I would say three to four days, but thats speculation.
Q. During that period of time, were you getting any telephone calls at your apartment?
A. She -- Janet was talking to me -- oh, okay. What happened was that I went and picked
her up from El Monte, brought her back to the house, and then I started receiving phone

calls from a gentleman by the name of Frank.

Q. All right. Did Frank have a last name?
A. Tyson, I believe. But at the time I think I only knew Frank. I dont think I knew his
last name.
Q. How many conversations did you have with Frank Tyson?
A. During that time, I d idnt have many conversations with Frank. I might have picked up
the phone and passed it to Janet. I believe that there was one -- one phone call maybe
that I actually talked to him in any detail.
Q. And the phone -- excuse me, Im sorry. In that detailed conversation that you had, do
you rememb er the content of that conversation?
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: It would be a statement in furtherance, Your Honor.
THE COURT: All right. Ill ad mit it for the limited purposes that we discussed earlier on the
conspiracy charges, the statement in furtherance of the conspiracy.
Q. BY MR. ZONEN: The question was, do you recall the content of that conversation?
A. The content of the conversation was, is that Frank wanted to know what kind of car I
drove.
Q. All right.
A. And I asked him why he wanted to know what kind of car I drove. And he said his
girlfriend in New York was doing some kind of survey on what people drove in Los
Angeles. I thought it was quite strange. But at this point I didnt really understand what
was happening, so I gave him that informat ion.
Q. All right. And you told him what kind of a car you drove; is that correct?
A. Yes, sir, I did.
Q. Did you ultimately have an opportunity to view surveillance tapes?
A. Yes, sir, I did.
Q. And were they surveillance tapes of you?
A. Yes, sir, they were.
Q. And were they surveillance tapes of you in the car that you described?
A. Yes, sir, they were.
Q. Can you tell us how many phone calls were coming from Frank during the time that
Janet Arvizo was staying at your house after her first return from Neverland?
A. She was receiving phone calls continuously. 5800
Q. What does that mean, continuously?
A. Every 15 to 20 to 30 minutes.
Q. Throughout the day?
A. Yes, sir.
Q. Were they always from Frank?
A. They seemed to be from Frank.
Q. Were you able to hear any portion of the conversation?
A. Janet was -MR. MESEREAU: Objection; hearsay.
THE WITNESS: -- somewhat emotional.
THE COURT: Nonresponsive. Sustained.
Q. BY MR. ZONEN: Were you able to hear any portion of the conversation? Yes or no.
A. Yes.
Q. All right. Do you know if those conversations went on for long periods of time?
A. They did.

Q. Without getting into the content of her end of the conversation, tell us what her mood
was like, what her manner or her demeanor was like.
A. She was emotional. She was crying. And she was sitting in the closet having these
conversations with Frank and -- I mean, I can tell you what I heard, but -Q. Lets not go into that at the moment. You said she was sitting in the closet?
A. She was -- its a long closet in the bedroom back in the back of the room. And she
would sit in the closet. She was -- she would be -- she was very distressed.
Q. All right.
A. She was crying.
Q. Were you able to hear her end of the conversation?
A. I only heard bits and pieces, but, yes, sir.
Q. What could you hear her saying?
A. She at that -MR. MESEREAU: Objection; hearsay.
MR. ZONEN: As to her state of mind.
MR. MESEREAU: Same objection.
THE COURT: Lets see, shes -- all right. Ill overrule the objection and allow her statement
in for her state of mind.
Q. BY MR. ZONEN: What did you hear, her comments?
A. I heard her comments that she was very disturbed about two gentlemens treatment of
her, one being a gentleman named Ronald and another being a gentleman by the name of
Dieter.
Q. Did she, in fact, return back to Neverland?
A. She did, sir.
Q. Do you recall if a person -- do you know a person named Brad Miller?
A. Yes, sir, I met him one time.
Q. Can you tell us who Brad will Miller is?
A. As far as I understood, Brad Millers a security detail for Michael Jackson.
Q. When and where did you meet Brad Miller?
A. Brad Miller showed up at the house one evening during this period of time when Janet
and the children were there. And I asked Janet who he was, and she said he was a
security detail for Michael Jackson. He came in and did an aud iotaped interview of the
family.
Q. Do you have a sense of when that was? If you dont know the date, say so.
A. Yeah, I dont know the date.
Q. Do you know how many days Janet Arvizo and her children were back in Los Angeles
by the time Brad Miller came by?
A. Probably two or three days.
Q. Which residence was it that he came to?
A. My residence on St. Andrews Place.
Q. Did you have a conversation with Brad Miller prior to his arrival at the apartment?
A. No, sir, I did not.
Q. Did you know in advance that he was going to be coming to the apartment?
A. No, sir, I did not.
Q. Did you know in advance the purpose of his visit to the apartment?
A. No, sir, I did not.
Q. When he came to the apartment, did you talk with him?
A. I was cordial, offered him a drink. But no, sir, not other than that.

Q. Did he explain to you his presence in the apartment?

A. No, I dont think so.
Q. Tell us what happened with Brad Miller when he was at the apartment.
A. He showed up at the apartment. Janet seemed to be anticipating his arrival. I asked
what he was coming for. She said -- I guess they were going to do an interview of some
type, an audio interview. Im not even sure if that was said. But he showed up and there
was a phone call. There was a phone call between him and, I guess Frank, because he
passed the phone to Janet, and Janet talked to him, to Frank. And then they came in, and
they sat down around the table. Its a coffee table in the living room. And they all circled
around it, and they had an interview.
Q. Was that interview tape-recorded, to your knowledge?
A. Yes, sir, it was.
Q. Did you see the tape-recording?
A. Yes, sir.
Q. Who did you believe Brad Miller worked for?
A. Michael Jackson.
Q. Did you have a sense of the purpose of tha interview?
A. I did not.
Q. Did you listen to any part of the interview?
A. I was up and down throughout the entire time, so I really did not. I think -- I assume it
was in relat ion to the Living with Michael Jackson, and that it was just to buffet his story
that nothing had happened.
Q. All right. Did you at any time ask him any questions about what was going on?
A. No, sir, I did not.
Q. Did you ask him any questions about the two men that Janet had expressed concern
about?
A. No, sir, I did not.
Q. Were you expecting that Janet Arvizo and the children would be returning to
Neverland?
A. You know what? At this point Im not even sure I knew that. You know what? Janet had
this relationship with Michael -MR. MESEREAU: Objection; nonresponsive.
Q. BY MR. ZONEN: The answer was you didnt know?
A. No, sir, I did not know.
THE COURT: Ill strike the last sentence. Go ahead.
Q. BY MR. ZONEN: At the time that you were in the apartment during this interview, did
you not know whether they would be returning?
A. No, sir, I did not.
Q. How long did that interview go for?
A. Probably two hours, two hours and 15 minutes, something like that.
Q. Do you have a recollection of any part of that interview, the content of that interview at
all?
A. Not really, sir, I dont.
Q. Did Janet Arvizo and her children return to Neverland after that interview?
A. Yes, sir, they did. I believe it was like the next day.
Q. Your apartment on St. Andrews Place was how large?
A. Its about 1100 square foot, one bedroom.
Q. One bedroom and a living room?

A. Yes, sir.
Q. And at times all of you were staying there at that apartment?
A. Yes, sir.
Q. When they went back to Neverland, did you know in advance that they were going?
A. I mean, at the last minute, I believe I knew that they were going.
Q. Do you know how they got to Neverland?
A. Sure. Someone came and picked them up.
Q. You said, At the last minute. What does that mean?
A. It means that I -- you know, she wasnt telling me specifically what was happening.
And I wasnt asking. So I think she might have told me that they were leaving, but I really
-- Im not clear that they were leaving.
Q. All right. When they went back to Neverland, do you know if they went back during the
day or in the evening?
A. Seems to me that they went in the afternoon.
Q. And when was the next time you saw Janet Arvizo or her children?
A. That same night Janet came back. Late at night.
Q. Without her children?
A. Without her children.
Q. All right. What was her mood or her affect at that time?
A. She was very emotional.
Q. Did you ask her where the children were?
A. I assumed that they were still at the ranch.
Q. Did you talk about what had happened?
A. She didnt want to talk about it.
Q. Do you know what day it was that she returned? Do you have a sense of it?
A. Early February, but I really dont have a date.
Q. Do you know how much time had gone by since the Miami trip at this point that she
came back?
A. Maybe a week.
Q. Now, when she came back, how long was it before you saw the kids next?
A. At that point, I didnt see them for probably three weeks. I dont know. It was a long
time.
Q. Was there a meet ing at your house involving the department of -A. I stand corrected, sir. Can I go back on the last statement?
Q. Yes. Go ahead.
A. They -- they apparently did a CPS -- a Department of Child & Family Services interview
after Janet left to go do the video that night. The next morning they all showed back up,
and I did see the children but it was briefly.
Q. Now, you mentioned a couple of things were going to talk about in order.
A. Okay.
Q. First is the video.
A. Okay.
Q. At some point in time, did you become aware of the fact that Janet was -- Janet Arvizo
was going to be doing a video?
A. I did.
Q. When did you learn about that?
A. Well, when Janet came back by herself, she was very emotional. And then the next day

Frank started calling again, just continuously.

Q. Let me stop you for one second. The same Frank who was calling the first time?
A. Yes, sir, the same Frank.
Q. The person you mentioned as Frank Tyson?
A. Frank Tyson.
Q. And you said before he was calling continuously?
A. That is correct.
Q. Was he calling more continuously, less continuously, or about -A. I would say now its more continuously.
Q. And what does that mean in terms of actually how many phone calls he was making?
A. You know, I cant tell you a number of phone calls, but I can say he was calling every
15 or 20 minutes. I mean, I even told him -- I would tell him certain times, Shes not
available. Call back later today, or, Ill have her call you. Fifteen minutes later he calls
again.
Q. Did he tell you who he was in any of these phone calls?
A. I dont think he did specifically. I knew he worked with Michael Jackson.
Q. Did he tell you why he was calling?
A. Well, he always wanted to speak -MR. MESEREAU: Objection; hearsay.
MR. ZONEN: It would be in furtherance of.
THE COURT: First he has to answer the question. It was nonresponsive. Ill have the court
reporter read back the question.
MR. ZONEN: The question actually is yes or no. (Record read.)
Q. BY MR. ZONEN: That would be yes or no.
A. Yes.
Q. What did he say?
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Statement in furtherance of.
THE COURT: Im going to admit the statement with the same limited purpose for the last
one.
THE WITNESS: Okay.
Q. BY MR. ZONEN: What did he say?
A. He at one point asked me, How can I get Janet to come back up to the ranch? And
another time he asked me, he said, We need her to sign a contract to do this video. And
he said, We really have got to hurry on this, because its going to air tomorrow. Its got
to be in to be finalized by tomorrow. So he was really pushing that issue, and so I had a
conversation with him about that.
Q. Had you -- prior to that conversation, had you had a conversation with Janet Arvizo
about a video?
A. No, I had overheard her talking to Frank on the phone about it. I mean, at one point
she was asking them to bring her children home.
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Reflects her state of mind.
THE COURT: Just a moment. The question was, Had you -- prior to that conversation,
had you had a conversation with Janet Arvizo about the video? Answer, No. He then
proceeded to not answer, so Ill strike that after, No. You may ask another question.
Q. BY MR. ZONEN: But you had some knowledge about what this video was about?
A. Yes, sir, I believe I d id.

Q. And did that knowledge -- from what source was that knowledge?
A. I believe mostly from Frank.
Q. And did Janet Arvizo speak with you about that video at all?
A. No, sir.
Q. Did you overhear any conversation between Janet Arvizo and presumably Frank on the
telephone?
A. Yes, sir, I did.
Q. And did you overhear a conversation that specifically addressed the video?
A. Yes, sir. She said she didnt want to do it.
Q. Im sorry, she what?
A. She said she did not want to do it.
MR. MESEREAU: Move to strike; nonresponsive; and hearsay.
THE COURT: Stricken after, Yes, sir.
Q. BY MR. ZONEN: All right. When you had a conversation with Frank about this video, did
you ask him any questions about it?
A. Yes. I said -- he said he wanted to do -MR. MESEREAU: Objection; nonresponsive.
THE COURT: Sustained.
Q. BY MR. ZONEN: Some of these questions really call for a yes or no.
A. Okay, sir.
Q. And then we can get into content thereafter.
A. Okay.
Q. I believe the question was, did you have a conversation with Frank about this video?
A. Yes, sir, I did.
Q. All right. Did Frank tell you what the video was about?
A. Yeah, I believe he did, sir.
Q. What did he tell you?
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Statement in furtherance of.
THE COURT: All right. Ill admit this for the limited purposes of the conspiracy. You may
answer.
THE WITNESS: Im not clear exactly. I know Frank said some things to me about the fact
that we needed to have this -- they needed to do this prior to it going to the editor or
something, to get it
4 out there, and it was a rush to get it done. And thats really what I would say.
Q. BY MR. ZONEN: Did he tell you or did you understand that this video would go on
television?
A. I did, yes, sir.
Q. Did you talk to him about this contract that he wanted Janet Arvizo to sign?
A. Yes, sir, I did.
Q. What did you say to him?
A. What is this contract?
Q. Im sorry?
A. I said, What is this contract? What is in this contract?
Q. And what did he say?
A. He -MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Same response.

THE COURT: You know, the last time you told me that, the response wasnt what you
represented, so -MR. ZONEN: Actually, I would refer the Court to Overt Acts 11, 12 and 13, and I believe it
does refer to those overt acts.
THE COURT: Depends on what he says in his answer, doesnt it? Thats the problem. Not
your question, Counsel.
MR. ZONEN: Let me withdraw that last question.
THE COURT: No, lets have a discussion for a moment.
MR. ZONEN: Okay.
THE COURT: I just want to give you an example here. Did Frank tell you what the video
was about? Yes, I believe he did. What did he tell you? Objection; hearsay. Statement
in furtherance of conspiracy. The Court: All right. Ill admit it for a limited purpose. A.
Im not clear exactly. And then he went on to say something else. If youre going to offer
a statement in furtherance of the conspiracy, then you need to know what statement hes
going to make when you ask the question. Do you understand what Im saying?
MR. ZONEN: Yes.
THE COURT: Im not going to agree in advance to that kind of response.
MR. ZONEN: I think the best thing we need to do is to withdraw the last question and
proceed to another question.
THE COURT: All right.
MR. ZONEN: I will do that.
Q. Did you have a conversation -- did you ask for a copy of the contract?
A. I did, yes, sir.
Q. All right. Did he send you a copy of the contract?
A. No, sir, he did not.
Q. Did he agree to send you a copy of the contract?
A. No, he did not.
Q. Did you have a conversation with Frank about payment for this video?
A. Yes, sir.
Q. What did you say to him?
A. Well, after I asked him to send the contract to me by e-mail, and he kind of changed
the subject, I asked him, What are you offering this family to do this? I had seen on T.V.
that they were making money on this -- this video, and I felt that they were taking
advantage of this family. So I said, What are you offering them? He said, Well, were
offering them protection. And that struck -MR. MESEREAU: Objection. Objection; nonresponsive.
MR. ZONEN: And I believe that statement -MR. MESEREAU: And hearsay.
THE COURT: Thats overruled.
Q. BY MR. ZONEN: He said something to you about protection?
A. Yes, sir, he did.
Q. What did he tell you about offering the family protection?
A. He said he was offering the family protection. And I said, Frank, the family doesnt
need any protection. Who are you protecting them against?
Q. Did he answer that question?
A. He did not. He moved on to the next point.
Q. At any point in time during this conversation, did he tell you who the family needed
protection from?

A. No, sir, he did not.

Q. Did he tell you what kind of danger the family was in?
A. No, sir, he did not.
Q. Did he tell you who were posing threats to the family?
A. No, sir.
Q. And did you ask him those questions?
A. I did.
Q. All right. Then you said he moved to the next subject?
A. Yes, sir.
Q. Now, again, you had asked him for compensation for the family?
A. Well, I -- yes, I did. And he said he was going to give them a tutor. Well, we found out
they didnt ever get any kind of schooling.
MR. MESEREAU: Objection. Nonresponsive; hearsay; move to strike.
THE COURT: After Yes, sir, I did, Ill strike the rest of the answer.
Q. BY MR. ZONEN: Did Frank offer you or Janet Arvizo or her children anything in
exchange for this video?
A. He said he was going to offer a college education, and a house. Well, they didnt need a
house. And theyre in eighth grade. They didnt need a college educat ion.
MR. MESEREAU: Objection; move to strike.
THE COURT: The last sentence is stricken. Let me -Q. BY MR. ZONEN: What did you say to Frank in response to that offer?
A. I said, Thats fine, Frank. What are you offering them monetarily? I was very
suspicious of him at this point.
MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: Thats -- that last remark is stricken. And the last answer, Im striking the
last three sentences, not the last one sentence.
Q. BY MR. ZONEN: All right. He had made you an offer of a house?
A. Yes, sir.
Q. All right. And you said no?
A. Basically said no.
Q. Okay. Did you ask him for any monetary payment in exchange for that video?
A. I asked him what he was offering financially or monetarily.
Q. And did he answer to that specific question?
A. No, sir, he did not.
Q. Did he tell you whether or not they were going to be paid?
A. No, he actually said, Are you trying to blackmail us?
Q. Had you made any demands from him?
A. No, sir.
Q. Were you personally familiar with any informat ion that could be used for blackmail?
A. No, sir.
Q. What did you tell him when he said that?
A. Why are you saying that? That makes no sense. It has nothing to do with what were
talking about here.
Q. Did you tell him that you believed they were going to be profiting fro m this?
A. I did. I said, Youre going -- you know, Its being blasted all over the T.V. that
theyre going to be doing this Take Two video, a response to the Martin Bashir Living with
Michael Jackson. And theyre advertising that the familys going to be on there, and you
want her to sign this contract, but you wont show me the contract. And you -- he wanted

me to have her -MR. MESEREAU: Objection. Nonresponsive; move to strike.

THE COURT: Okay. After there, where he started, You want me to sign the contract,
Ill strike that. Thats the last sentence.
Q. BY MR. ZONEN: Did he ever send you a copy of the contract?
A. No, sir, he did not.
Q. Did he ever read you a copy of the contract?
A. No, sir, he did not.
Q. Did you ever have a d iscussion with Janet Arvizo about the video?
A. No, sir, I did not.
Q. At some point in time, do you know if she actually did the video with or without her
children?
A. Yes, sir, I believe she did.
Q. And was that after this discussion with Frank?
A. Yes, sir.
Q. Do you know how long after this discussion with Frank?
A. He continued to call, and at some point 5819 Janet accepted it or moved -MR. MESEREAU: Objection. Nonresponsive; move to strike.
Q. BY MR. ZONEN: The question was how long after, if you know?
A. Within a day.
Q. Did the phone calls from Frank continue during that -THE COURT: The ruling on that is I will strike the answer as requested. Go ahead.
Q. BY MR. ZONEN: Okay. During that period of time, that day that followed your
conversation with Frank, did he continue to call the apartment?
A. Yes, he did.
Q. And the calls were talking about were to your apartment on St. Andrews?
A. Thats correct.
Q. Was there anybody else calling other than Frank?
A. Not that Im aware of.
Q. Do you know where the children were during this time?
A. I believe they were at Neverland.
Q. Now, you had mentioned that you did see them during the course of an interview with
the Department of Child & Family Services; is that correct?
A. That is correct.
Q. All right. Can you tell us where that interview took place?
A. It took place in my apartment.
Q. Were you there at any time during that interview?
A. No, sir, I wasnt.
Q. Did you greet any of the people as they came?
A. No, sir.
Q. Were you there earlier at the time that Janet Arvizo and the children arrived?
A. About the time I was getting up to go to work, they arrived at the apartment. I was
there a short period of time and went on to work.
Q. Do you know approximately what time that was that they arrived?
A. Well, I get up probably about six oclock in the morning, so thats my guess.
Q. So they were just arriving at six oclock?
A. That -- it might have been a little earlier, but Im not positive on that. Depends on what
I had to do at work that day.

Q. Now, was Janet Arvizo arriving with them or had she already been at your apartment?
A. No, she was arriving with them.
Q. Do you know when it was that she had left your apartment prior -A. The night before.
Q. The night before?
A. Late at night. I dont know. Around eleven oclock, twelve oclock.
Q. Do you know if she drove herself or if someone came to get her?
A. Someone came and got her.
Q. Do you know who that was?
A. I dont. Im not sure. I think I went outside -- I know I went outside to help her get in
the car, but I dont know who the driver was at this time. I cant put my finger on who it
was.
Q. Were you there at the time that any of the people from the Department of Child &
Family Services arrived?
A. No, sir.
Q. Were you gone that entire day?
A. I was gone the entire day.
Q. When you got back, who was present at your apartment?
A. No one.
Q. Not even Janet Arvizo?
A. Janet, I believe, may have been there.
Q. Did Janet Arvizo remain that night?
A. I believe she stayed that night, and then either -- yeah, I believe she left the next
morning.
Q. Were the kids gone already?
A. They were already gone.
Q. By the time you got home that day?
A. Yes, sir.
Q. That night, what was her mood like?
A. I dont really remember.
Q. Did Janet Arvizo say anything to you about Brazil?
A. Yes, sir, she did.
Q. What did she say?
MR. MESEREAU: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you know if there was a trip to Brazil in the planning?
A. Yes, sir, I did.
Q. Was Janet Arvizo enthusiastic about going to Brazil?
A. No, sir.
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: State of mind.
THE COURT: Calls for a conclusion. Sustained.
Q. BY MR. ZONEN: Did she say to you that she was enthusiastic about going to Brazil?
MR. MESEREAU: Objection; hearsay.
THE COURT: Sustained.
MR. MESEREAU: And leading.
Q. BY MR. ZONEN: How long were they gone after they left, after this meeting with the
Department of Child & Family Services?

A. About three weeks.

Q. A long period of time?
A. Yes, sir, a long period of time.
Q. Did you know in advance they were going to be gone that long?
A. No, sir, I did not.
Q. Did you have conversations with Janet during that period of time?
A. Yes, sir, I did.
Q. Over the telephone?
A. Yes, sir.
Q. What was her mood like over the telephone?
A. Distressed. Disturbed.
Q. When was the next time that you saw her?
A. The next time that I saw her was at a nail salon.
Q. All right. Explain that to us.
A. Well, over that period of time Janet had been calling, and she was hanging up on me,
and very short conversations, and very disturbed.
MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: Its responsive, but it calls for a narrative, so Ill sustain the objection.
MR. ZONEN: Okay.
Q. During the course of your conversations, would you describe the nature of the
conversations you had with her? Without getting into the content of them, just the nature
of them.
A. The nature of the conversations was, is -Q. Go ahead.
A. I can tell you how she was -- appeared, how she felt. She was -MR. MESEREAU: Objection; nonresponsive.
THE WITNESS: Im not sure I understand the question.
MR. ZONEN: Let me withdraw the question.
THE WITNESS: Yeah.
MR. ZONEN: Because I think the question might be difficult to answer.
Q. Did she sound concerned over the telephone?
A. Yes.
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. Next question.
Q. BY MR. ZONEN: Were they long conversations?
A. Not normally, no.
Q. Did she express concerns to you in the course of these conversations?
A. Yes, sir.
MR. MESEREAU: Objection. Leading and asked and answered.
MR. ZONEN: Overruled. Next question.
Q. BY MR. ZONEN: What did she say to you that she was concerned about?
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Her state of mind.
THE COURT: Ill ad mit it for that purpose.
Q. BY MR. ZONEN: What did she say to you that she was concerned about?
A. Well, she said that she was not being able to see her children; that they were following
her around wherever she went off Neverland; that she was -- either had a chaperone or
that somebody was following her. At one time when she was in a hotel --

MR. MESEREAU: Objection. Narrative; nonresponsive.

THE COURT: Sustained. Im going to instruct the jury that that statement that was
admitted just now was not admitted for the truth of the matter asserted by Janet, but for
her state of mind as she related to him. Next question.
Q. BY MR. ZONEN: Do you know if during this period of time Gavin was seeing a doctor on
a regular basis?
A. Yes, he was.
Q. How often was he seeing his doctors?
A. Im not clear. I think probably every month or so.
Q. Do you know when his appointments were around that time?
A. I dont really. I know that he was having them scheduled, but I wasnt sure when he
had to go.
Q. All right. And I think you said the next time you saw her was at a beauty parlor; is that
right?
A. That is correct.
Q. How did you happen to see her at a beauty parlor?
A. She called me at work and -- I hadnt talked -- I hadnt actually seen her in a long
time, and she called me at work and said -MR. MESEREAU: Objection; hearsay.
THE WITNESS: (To a juror) Bless you.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did she notify you where you -- where she was?
A. She called me at work.
Q. Did you go to that location?
A. Yes, sir, I did.
Q. Was anybody else there -- was she there at the location?
A. Yes, she was.
Q. Was anybody else at that location?
A. When I came in, she was sitting there by herself.
Q. All right. At some point -- without getting into the content, did you have a conversation
with her?
A. Yes, sir.
Q. Is this the first time that youd seen her in a few weeks?
A. Yes, sir.
Q. Was any -- and then I think you said somebody else came. Who came?
MR. MESEREAU: Objection; misstates the evidence.
MR. ZONEN: W ithdraw the question.
Q. Who did you see then?
A. I saw Vinnie and Gavin come in the back door of the nail salon.
Q. Is Vinnie somebody you knew prior to that day?
A. No, sir.
Q. Were you introduced to him at that time?
A. I was either introduced or he introduced himself. Im not positive. Im not clear.
Q. Can you describe Vinnie to us?
A. He would be a white male.
Q. About how old?
A. Young. Younger.
Q. How old is younger?

A. 25. I dont -- thats just speculation.

Q. Did he tell you who he was, Vinn ie?
A. Im not sure.
Q. Was there a discussion with Vinnie about Janet Arvizo returning to Neverland?
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Statement in furtherance of.
THE COURT: All right. Ill admit it for the limited purpose in furtherance of the conspiracy.
THE WITNESS: Could you ask me the question again, please?
THE COURT: Go ahead, the court reporter. (Record read.)
THE WITNESS: Yes.
Q. BY MR. ZONEN: And what did Vinnie say about that?
MR. MESEREAU: Same objection.
THE COURT: Okay. Same ruling, then.
Q. BY MR. ZONEN: Go ahead.
A. He said that -- he said, No, you cant do that. And I said, Are you saying that I
cannot take her out of here? And he said, I got to check on that. And he walked outside
and immed iately got on his cell phone, followed by Gavin.
Q. Gavin fo llowed him?
A. Correct.
Q. What was Gavins behavior like at that time?
A. Cocky.
Q. Cocky?
A. Yes.
Q. Explain that, please.
A. I dont know. He was -- its hard to explain. He was -- just walked in. He strutted in
with Vinnie. And it wasnt the sweet, loving Gavin that I knew. 5829
MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: Just a moment. Overruled. The answer is -- Hold on just a moment, here, if
you would please. Go ahead. Thank you.
MR. ZONEN: May I proceed?
THE COURT: Yes.
Q. BY MR. ZONEN: All right. You described Gavins response. Was Gavin behaving
differently than he had been prior to -- well, prior to -- the early part of February when
they went to Miami?
A. Yes, he was.
Q. In what way was he behaving different ly at this point?
A. Again, he was acting very cocky. He -- kind of rude, actually.
Q. Did he greet you at all when he saw you?
A. I dont think he wanted to see me. I dont think that he -- he was very surprised when
he saw me there. And he may have greeted me, but he was certainly not a loving -- it was
almost like, What are you doing here?
Q. Your relationship with him prior to Miami, how would you describe that relat ionship?
A. Father-like.
Q. You had a good relationship with him?
A. Very good relationship.
Q. Now, we were talking about Vinnie and his comments. He said that he had to go out
and call somebody. Did he call somebody?
A. Yes, sir, he did.

Q. Did he continue to have a conversation with you while he was on the phone with that
person?
A. Yes, sir. I asked him -- I asked him, you know, Is there a problem here? And he said,
Oh, no, theres no problem. Im working on that right now.
Q. Did he say anything about where Janet Arvizo or Gavin would be going?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. You may answer.
THE WITNESS: Did he say where she was going to go?
THE COURT: Read the question back.
MR. ZONEN: Let me redo that question, if I can.
THE WITNESS: Please.
Q. BY MR. ZONEN: Did he say anything to you about where he wanted Janet Arvizo or
Gavin to go?
A. He didnt.
MR. MESEREAU: Same objection.
Q. BY MR. ZONEN: Did you say anything to -THE COURT: Just a moment. The objection was overruled. The answer was, He d idnt.
Next question.
Q. BY MR. ZONEN: Was there a discussion involving Vinn ie about where everybody would
be going?
A. It wasnt Vinnie. It was -- Gavin came in after that and said something to me.
Q. All right. In Vinn ies presence?
A. No, Vinnie was still outside.
Q. Okay. Where finally did Janet go?
A. Janet left with me.
Q. And where did Gavin go?
A. Gavin left with Vinnie.
Q. To your understanding, where?
A. Back to Neverland.
Q. The other two children, were they there?
A. They were still at Neverland, no, sir.
Q. And did you go home with Janet?
A. Yes, sir, I did.
Q. And home is the St. Andrews residence?
A. Yes, sir, it was.
Q. What was Janet Arvizos mood like when you were back at the house at St. Andrews?
A. She was distressed. She was saying there was a problem.
Q. All right. Did you make an effort at some time to find out -MR. MESEREAU: Objection. Objection. Nonresponsive; move to strike.
THE COURT: Sustained. Ill strike the last sentence of what she said.
Q. BY MR. ZONEN: Did you make an effort with Janet Arvizo to get the children back from
Neverland?
A. Yes, sir.
Q. What did you do?
A. Well, at one point I called her father, and said, I want to go to Neverland and get
these children out of there. And then at -- and he -- well, I dont believe that he was -MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Tend ing to explain their actions.

THE COURT: The question was what did he do. So I will overrule the objection and strike
the last sentence.
Q. BY MR. ZONEN: All right. Ultimately was there a decision made to make a phone call by
somebody in the family to Neverland?
A. Yes, Janet called someone. Either Frank or Vinnie.
Q. All right. And what did she represent to them?
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Explaining the conduct.
THE COURT: Explaining what conduct?
MR. ZONEN: Hers.
THE COURT: Sustained.
Q. BY MR. ZONEN: Were the children returned to either your house or some other
location? When did you -A. Im drawing a blank. Im not sure I understand whats going back and forth here.
Q. When was the next time you saw the children?
A. The next time I saw them was the next night at her -- Janets parents house.
Q. Were you present at the time any phone calls were made to Neverland by either Janet
or her parents?
A. No, sir.
Q. Who brought the children to her parents house?
A. I dont -- I do not know, because we waited for them to arrive before we went to her
parents house.
Q. When you got there, were they still there, the people from Neverland?
A. No, sir, they were not.
Q. Whoever had brought them there had left by that time?
A. That is correct.
Q. Describe Gavins behavior at the time that you got there.
A. Gavin didnt want to see me. He stayed back in the back room. There was some crying
coming from the back room.
MR. MESEREAU: Objection. Nonresponsive; hearsay; move to strike.
THE COURT: Overruled.
Q. BY MR. ZONEN: Who was crying in the back room?
A. I believe it was Davellin.
Q. Did you talk with Gavin at all?
A. No, I did not.
Q. Was he friendly to you?
A. No, sir.
Q. Did he talk with you at all during that day?
A. No. No, sir.
Q. Was there any discussion about returning to Neverland?
A. No, sir.
Q. Did any of the kids ask to be returned to Neverland?
MR. MESEREAU: Objection. Leading and asked and answered.
THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Go ahead.
A. Im sorry? THE COURT: Court reporter. (Record read.)
THE WITNESS: The only thing I remember is they said that Michael -- I mean Gavin
couldnt see me, because if he d id, he couldnt return to Neverland to see Michael.

Q. BY MR. ZONEN: Gavin said that?

A. Yes, sir, he did.
Q. How would you contrast Gavins behavior at that time as against his behavior prior to
the Miami trip?
MR. MESEREAU: Objection. Improper opinion; vague.
THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Go ahead.
A. Night and day. It appeared to me hed been brainwashed in s ome way.
MR. MESEREAU: Objection.
Q. BY MR. ZONEN: Just tell us what his behavior was.
A. He was vague, he was angry.
MR. MESEREAU: Objection.
THE COURT: Just a moment. Just a moment.
THE WITNESS: Yes, sir.
THE COURT: The last response is stricken. The jurys admonished to disregard it. Ask him
another question.
Q. BY MR. ZONEN: Just tell us what his behavior was like at this time.
A. Angry.
Q. In what way?
A. He was just mean. He was yelling. Are we talking about the night that he was at -Q. That night and even beyond.
A. Even beyond. He became mean. He was using curse words.
MR. MESEREAU: Objection; vague.
THE WITNESS: He had never done before.
THE COURT: Just a moment.
THE WITNESS: Yes, sir.
MR. MESEREAU: Vague and nonresponsive.
THE COURT: Im going to strike the last sentence again. The problem here is that youre
required to listen to the question and just answer it. And every answer you give, you add
something to it, which causes counsel to object, and me to rule, which is causing a great
disturbance in your testimony. If you want to keep doing it, you can. But you cant
imagine how it sounds to everybody else. So Im going to admonish you to pay attention
to what the question is, and then just answer the question. Nothing further. All right?
THE WITNESS: Yes, sir.
Q. BY MR. ZONEN: Was he saying things or using speech different from the type of speech
he used prior to the Miami trip?
A. Yes, sir.
Q. In what way?
A. He was using curse words.
Q. He had not used curse words before in the house?
A. No, sir.
Q. Was this in the presence of his grandmother?
A. I dont remember if it was that night. But he did over the next few days period of time.
Q. Did his behavior in time return to what you considered to be normal, what it was prior
to the Miami trip?
A. Over several months, yes, sir.
Q. Did you and Janet Arvizo put the boys into some kind of tutoring?
A. Yes, sir, we did.

Q. What tutoring program was that?

A. Its called JEI Learning Center. We immediately put them in after they got back from
Neverland.
Q. Was that a private school?
A. No, its not a private school. Its just to assist children who -- who need additional
assistance getting their level up in a certain area.
Q. What was the purpose for doing so, putting them into JEI?
A. Because they had been out of school for almost two months and we wanted to bring
their skills back up to the level they should have been.
Q. And did they attend JEI tutoring?
A. Yes, sir.
Q. Did the boys resume their activities with military scouting?
A. With the Sea Cadets, yes, sir.
Q. When did that resume?
A. Almost immed iately.
Q. Are they still active in military scouting?
A. Yes, sir, they are.
MR. MESEREAU: Objection; relevance.
THE COURT: Overruled. The answer was, Yes.
THE WITNESS: Yes, sir, they are.
Q. BY MR. ZONEN: And that involves attendance at military camps how frequently?
A. They go every week, about every Sunday. And then they have field exercises that they
attend probably every month or two months. Theyre over the weekends.
Q. Are all three children living with you today?
A. Yes, sir, they are.
Q. Would you describe Gavins behavior today?
MR. MESEREAU: Objection; relevance.
THE COURT: Asked and answered, I believe. Sustained.
Q. BY MR. ZONEN: Is he still involved in scouting today?
MR. MESEREAU: Objection; relevance.
MR. ZONEN: Could we approach sidebar?
THE COURT: The -MR. ZONEN: Is that a Yes?
THE COURT: No. Im trying to -- Ill overrule the objection. I think that was asked and
answered. But rather than waste time looking, go ahead.
MR. ZONEN: A ll right.
THE WITNESS: Yes, sir. Theyre still involved with it, with that.
MR. ZONEN: Thank you. I have no further questions.
THE COURT: All right. Well take our break two minutes early. Give me time to recover.
(Laughter.) (Recess taken.)
THE COURT: Mr. Mesereau?
MR. MESEREAU: Yes. Thank you, Your Honor.

CROSS-EXAMINATIONBY MR. MESEREAU:

Q. You indicated that you saw behavioral changes in Gavin from when you knew him
initially to when he left Neverland for the last time, correct?

A. Yes, sir.
Q. Did you know anything about his school history?
A. I didnt. I dont think I knew a lot about it, no, sir.
Q. Did you know anything about his disciplinary record in various schools with various
teachers?
A. I know that when he was with me that he had some problems at John Burroughs.
Q. Did you know anything about his history before?
A. Not that Im aware of, no, sir.
Q. All right. Now, you indicated in response to the prosecutors questions that you knew
about a Miami trip that Janet and the children took, correct?
A. That is correct.
Q. And that was approximately when, to your knowledge?
A. Early February.
Q. I believe you said that while Janet and the children were on that trip to Miami you had
these discussions with some people who purported to be representatives of a British
tabloid, correct?
A. That would have been prior to her leaving.
Q. Okay.
A. Although, sir, they did call me back after she left, but I was not talking to them.
Q. But they contacted you on a number of occasions, you say, right?
A. That is correct.
Q. Okay. Now, at one point you indicated that you spoke to Frank Tyson and wanted to
know what the family was going to get out of the rebuttal video, right?
A. Yes, sir.
Q. And you actually mentioned at one point to Tyson that, Youre making millions out of
this. What is this family going to get? Right?
A. In -- in essence, I d id say that.
Q. And I believe you said that Mr. Tyson offered a house and a college educat ion; is that
correct?
A. First he offered protection. Then he said he was going to offer a tutor. Then he was
going to offer a house and a college education.
Q. And you, in effect, said to Mr. Tyson, Thats not enough, right?
A. That would be incorrect.
Q. First you said, You guys are making millions and this familys not getting anything,
right? Right?
A. Are you asking me the question now to answer?
Q. Yes.
A. Okay. I said basically that, I understand that theyre making four to five million dollars
on this documentary. In my perception, that you should compensate this family for
helping out in this video.
Q. And at the end of that conversation, you in effect communicated to Frank a house is
not enough, right?
A. That was not the way it came across, no, sir.
Q. Okay. Did you accept the house?
A. I still dont have it, no. I dont see the house yet.
Q. Are you still looking for it?
A. Im not even looking for it.
Q. Okay. And are you telling the jury that there was no response to your comment that, in

effect, somebodys making four to five million dollars and the familys not getting any
money?
A. His response was, Well, how about -- Im going to protect the family. Were going to
protect the family.
Q. Right.
A. Were going to give them a house. Were going to give them a college educat ion. And
I said, Frank, but what are you going to do financially or monetarily for this family?
Q. Right.
A. They had already been taken advantage of in the first documentary and received
nothing.
Q. Okay. And you never really got a response to that question except discussion about a
house, correct?
A. Again, sir, what Ive said, yes.
Q. Okay. You told the jury that it was your understanding that Janet and the family went
to Miami to do a press conference, right?
A. That is correct.
Q. Do you remember your first interview with any sher iffs department representative in
this case?
A. Yes, sir, I do.
Q. Do you remember it was approximately on November 25th, 2003?
A. Yes, sir.
Q. It was with a sheriff named Zelis, correct?
A. Paul Zelis.
Q. Do you remember you told him that it was your understanding that the purpose of the
Miami trip was to do a rebuttal video?
A. I did write that, yes. I mean, I did see that, yes.
Q. When did you last read that transcript?
A. Ive read the transcripts over the last several days.
Q. You told Mr. Zelis they were going to film some kind of rebuttal for Michael, and when
she returned she said no rebuttal had ever been done, right?
A. That is correct.
Q. And you said that Janet believed Michael Jackson is innocent, right?
A. At what point, sir?
Q. At that point.
MR. ZONEN: Im not sure what point that is. Ill object as vague.
THE COURT: Sustained.
Q. BY MR. MESEREAU: When -- excuse me. You told Sheriff Zelis -A. Yes.
Q. -- that when Janet and the children went to Miami - okay? -A. Yes, sir.
Q. -- your understanding was they were going to film some kind of rebuttal for Michael
Jackson -A. Or press conference, right.
Q. -- Right? No, you said rebuttal.
A. I said rebuttal, but its the same thing. It was going to be a press conference that they
were going to do to rebut what was being done -- what had been -- what was going to be
said in the Living with Michael Jackson.
Q. You said they were going to film a rebuttal, right?

A. Yes, sir.
Q. And you said at that time Janet believed Michael Jackson was innocent, correct?
A. That is correct, sir.
MR. ZONEN: Ill object as to vague. What time?
Q. BY MR. MESEREAU: The time of the Miami trip, right?
A. Before they left for Miami, yes, sir, they did.
Q. Okay. Okay. And you told Mr. Zelis that the family was upset that they never did a
rebuttal in Miami, right?
A. I dont recall that. You would have to show it to me.
Q. Okay. Did you ever say anything to that effect?
A. I dont remember that, sir. You could show it to me and refresh my memory.
Q. Do you recall the attitude of the family when they returned from Miami?
A. I didnt see the family when they immediately returned from Miami.
Q. When did you next see them?
A. I saw them when the family came home about a week later from Neverland.
Q. Was it your understanding that any rebuttal was done in Florida?
A. It was my understanding nothing was done in Florida.
Q. They just sort of flew there for a day and flew back?
A. They flew there, were there several days, I guess, and then came back, yes.
Q. And you indicated to Mr. Zelis that you had seen both television documentaries, the
Bashir documentary and a rebuttal documentary, correct?
A. No, I dont believe I said that. I told him that I had seen the Living with Michael
Jackson.
Q. Do you remember telling Mr. Zelis you saw both of them?
A. I dont.
Q. Would it refresh your recollection if I just show you the transcript?
A. Sure. Yes.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
MR. ZONEN: W hat page, Counsel?
MR. MESEREAU: 9 of 37.
MR. ZONEN: Thank you.
THE WITNESS: Okay. Where are we at? Okay. Yes, sir.
Q. BY MR. MESEREAU: Have you had a chance to look at the transcript?
A. I saw that one sentence, yes.
Q. Does it refresh your recollection about what you told Mr. Zelis?
A. Not overly, no. No, sir, it doesnt. I saw the sentence that said I said I saw both. Thats
all I saw.
Q. Do you recall that thats what you told them?
A. Im really -- really unsure.
Q. Did you see both of them?
A. Yes, sir, I did.
Q. Now, you told Mr. Zelis that because Janet and the children were taped in the middle of
the night, that they couldnt get it in time to put it on the show, correct?
A. That is correct. And I may have heard that from T.V. Im not sure where I heard that
because they were supposed to be on that show according to the previous advertisements
for the Take 2 video.
Q. And they never were on it?

A. And they were not on it.

Q. But youre still waiting for a house?
MR. ZONEN: Objection; argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You said you thought Bashir was slandering Michael Jackson,
correct?
A. At that time, I think so, yes, sir.
Q. Okay. Youve said you were really upset about that, right?
A. Yes, sir.
Q. You had not met Michael Jackson then?
A. No, sir, I had not.
Q. And as you said, youve never met him?
A. Never met him.
Q. Until you see him today, correct?
A. Correct.
Q. Did you meet Chris Tucker?
A. I did.
Q. And when did you meet him?
A. When we went to Neverland.
Q. Did he ever contact you?
A. No, sir, he contacted Janet.
Q. Did you meet him the first time on the Neverland property?
A. The first time I saw him was on the bus prior to arriving -- leaving for Neverland.
Q. And was it your understanding that Janet and the family went to Miami on his plane?
A. That was my understanding.
Q. Okay. To your knowledge, were Janet and the children in contact with Chris Tucker on
a regular basis during this time period?
A. While they were in Miami, I have no idea.
Q. How about before Miami?
A. Prior to Miami, yes, they had a very good friendship.
Q. Do you know when Janet last talked with Chris Tucker?
A. I do not specifically.
Q. Okay. Now, I believe you said the British reporters talked to you before the Bashir
documentary aired in the United States?
A. That is correct.
Q. To your knowledge, was that after the Bashir documentary aired in England?
A. I think so.
Q. Okay. And how many discussions do you think you had with them?
A. I cannot tell you that for sure. Depends on if youre taking it from the beginning all the
way through the raid of Neverland. Three or four.
Q. Three or four discussions with these same British reporters?
A. And then thats speculation. It may have been five or six.
Q. Okay. Five or six discussions with the same British reporter, right?
A. One gentleman. D avid Gardner.
Q. Okay. And who does David Gardner work for, if you know?
A. I think its The Daily Mail or something. I believe thats correct.
Q. Now, in these five or so discussions, have you ever discussed Mr. Jackson?
A. Im sure his name was brought up.

Q. Have you ever g iven them informat ion about Mr. Jackson?
A. No, I wouldnt have known information about Mr. Jackson.
Q. Well, you could have gotten something from Janet, couldnt you?
A. Other than that he was a nice guy.
Q. Well, are you saying youve had five conversations with this fellow, but never gave
them any information and never talked about getting money?
A. There was conversation about money.
Q. You went back and forth with him a little b it on money, did you not?
A. That would be true.
Q. And never could reach an agreement, correct?
A. That is correct.
Q. When was the last time you talked to Gardner?
A. Gardner called me right after the Neverland raid, and wanted to see if he could get an
interview with the family again. And I just said no. He said, Well, I have it -- he said,
you know, I havent given your phone number to any other organizations yet, as if he
was implying that he would if I d idnt work with him.
Q. Who else have you been contacted -- excuse me. What other media representative or
alleg ed med ia representative has contacted you about this case?
A. Roger Friedman has called my office. People Magazine has called my office. People
Magaz ine showed up at the gates of my job. Theres been a number of them.
Q. Have you talked to any representative of the media besides Mr. Gardner?
A. No, sir.
Q. Now, you mentioned that Frank talked about a contract, right?
A. That is correct.
Q. And you wanted to see the contract, correct?
A. Absolutely.
Q. To your knowledge, did Janet ever sign a contract?
A. I have no idea.
Q. Did you ever talk to her about it?
A. I did not.
Q. To this day youve never asked Janet -A. I did not, sir.
Q. Did you sign any agreement?
A. No, sir.
Q. You learned at some point she and the children had filmed a rebuttal video, true?
A. That is correct.
Q. And when did you learn that?
A. Im not sure.
Q. Do you have any idea at all?
A. I really dont. Im unsure when I learned that.
Q. You indicated in response to the prosecutors questions that the CPS interview -A. Correct.
Q. -- the Child Protective Services interview was the morning after Janet and the children
filmed footage for a rebuttal video, right?
A. That is correct.
Q. And you saw Janet that morning, correct?
A. I did.
Q. Would it be reasonable to say that when you saw her that morning, you learned she

and the kids had filmed a rebuttal video?

A. I dont know that we -- I dont think we talked about it. In fact, Im pretty sure we did
not.
Q. Well, you told the prosecutor you knew what time approximately they left the night
before, right?
A. I knew what time Janet left, which was late at night, yes, sir, I did.
Q. And you were with her when she left, true?
A. And you know what? Maybe I did know that she was heading to do that, but Im not
really clear right now.
Q. Okay.
A. Im not trying to be evasive. I just -- Im not clear.
Q. Yet, when you think back to Janet leaving that evening -A. Right.
Q. -- you dont remember if she told you why she was leaving at that time?
A. She may have. Like I say, Im really unclear.
Q. Okay. And then you saw her come back the next morning?
A. That is correct.
Q. You must have asked her where shed been, true?
A. I dont think so.
Q. Did she spend the next evening at your home, to your knowledge?
A. She did.
Q. Do you remember seeing her that evening?
A. I -- this is -- I worked very late that 5858 night. I was in Command and General Staff
College and I had a pap er or something I had to do. I stayed late at night. I got home
fairly much -- I believe I went to bed. The next morning I got up, and I guess she left.
Q. Okay. But to this day youve never asked her, Did they have you sign a document
before you and the kids filmed the rebuttal video?
A. No, sir.
Q. Now, youve had a number of discussions with representatives of the Santa Barbara
Sheriffs Department, right?
A. Correct.
Q. And youve had a number of discussions with representatives of the District Attorneys
Office, right?
A. Yes, sir.
Q. And youve met with Mr. Zonen, the government prosecutor, on a number of occasions,
right?
A. That would be correct.
Q. And in those discussions, you have spoken about your desire to see any contract before
Janet or the kids signed anything, right?
A. That is correct.
Q. Have you ever d iscussed your interviews with any sheriff, representative of the sheriffs
department, any prosecutor or representative of the 5859 prosecutors agency with Janet?
A. No, sir.
Q. You indicated that at some point, you were present for an interview conducted by Brad
Miller; is that correct?
A. That is correct.
Q. And you indicated that -- actually, you indicated a couple of times to the jury that it
was your understanding that Brad Miller worked for Mr. Jackson --

A. That is correct.
Q. -- correct? Did you ever learn in that interview that Brad Miller worked for an attorney
named Mark Geragos?
A. No, sir.
MR. MESEREAU: Okay. At this point, Your Honor, wed like to play the tape of that
interview, which is in evidence.
THE COURT: All right.
MR. SANGER: Its Exhibit 5000.
MR. MESEREAU: Exhibit 5000.
THE BAILIFF: Are you playing it off of your computer?
MR. SANGER: Playing it off the DVD, I think.
THE BAILIFF: Input 4, Your Honor.
THE COURT: Excuse me? 5860
THE BAILIFF: Input 4.
THE COURT: Does it go through the PC?
THE BAILIFF: No, its going through the DVD. Did you push the proper -MR. SANGER: I certainly hope so. Theres no video, Your Honor.
MS. YU: Its an audio.
MR. SANGER: Its only audio, yes.
THE COURT: Whats the length of the audio? Whats the length of the DVD?
MR. SANGER: I think its about 20 minutes.
MR. ZONEN: Its about 20, 25 minutes playing the entirety.
MR. SANGER: Yes. May we proceed?
THE COURT: Yes.
THE BAILIFF: Input 1. Were going to play it through the PC, Judge.
MR. SANGER: Just take a second while it loads the program.
THE BAILIFF: Do you have it in the right format for -MR. SANGER: I hope so.
THE BAILIFF: Did you push the right -- is it coming out of your computer?
MR. SANGER: Best-laid plans, Your Honor. Okay. Its coming out of the computer, and we
got to make it come out of the sound system I think this will work well enough, its pretty
clear, if we just try it this way. Lets see how this works. (Whereupon, a portion of an
audio CD, Defendants Exhibit 5000, was played for the Court and jury.)
MR. SANGER: Your Honor, excuse me. Could we stop for one second? The bailiff just told
me what we forgot to push over here, and I think we can make it run through the
machine -- I mean, throug the loudspeaker, I say bold ly. Well find out. Which number do
we turn this to?
THE BAILIFF: (Ind icat ing).
MR. SANGER: 2?
THE BAILIFF: You have it all hooked up to Laptop 2, right?
MR. SANGER: Laptop 2.
THE BAILIFF: And the master audio switch is in your computer?
MR. SANGER: The what?
THE BAILIFF: The master audio is in your computer?
MR. SANGER: Thats on PC. Thats on 2. So we have it on 2, and thats not still not
working.
THE BAILIFF: Youre not hooked up to the master audio.
THE COURT: Why dont you just do it the way you were. We could hear it okay.

MR. SANGER: Okay. All right. Well try it again. Im going to resume, Your Honor.
(Whereupon, a portion of an audio CD, Defendants Exhibit No. 5000, was played to its
conclusion for the Court and jury.)
Q. BY MR. MESEREAU: Major Jackson, you heard the date that Mr. Miller articulated as
February 16th, 2003, correct?
A. That is correct.
Q. And do you note that at the beginning of the interview and at the end of the interview,
Mr. Miller said he was a private investigator working for Attorney Mark Geragos, correct?
A. I did.
Q. And you said Attorney Mark Geragos was an attorney for Mr. Jackson, correct?
A. Youre right.
Q. Does that refresh your recollection that Mr. Miller told you he worked for Mr. Geragos
at that interview?
A. No, sir, it doesnt.
Q. You dont recall hearing that at all?
A. I dont. And it wouldnt have mattered to me or meant anything to me if I had heard.
Q. Im not asking you what it meant to you. Im just asking you
MR. ZONEN: That is argumentative, and Ill object.
THE COURT: Overruled. Next question.
Q. BY MR. MESEREAU: You sat there for the entirety of that interview, did you not?
A. I was in the apartment, yes, I was.
Q. You sat there for the entirety of the interview, right?
A. Incorrect.
Q. Do you remember testifying to a grand jury in Santa Barbara County in this case?
A. I do.
Q. Do you remember being asked, The interview that Brad Miller d id, was that an
interview that you were able to watch in its entirety? W ere you there?A. Yes, sir, I was.
I sat on the couch, yes, sir. Do you remember answering?
A. Yes, sir, I do.
Q. Are you now changing that?
A. Its not an issue of changing. I mean, I was in the apartment, sir.
Q. Did you tell the Santa Barbara jury that you listened to that interview in its entirety?
MR. ZONEN: Objection. Misstatement of evidence. The statement was watch.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Do you recall telling that to the Santa Barbara Grand Jury?
MR. ZONEN: W hich page, please?
MR. MESEREAU: 889.
THE WITNESS: Sir, youd have to show me.
MR. MESEREAU: May I approach the witness, Your Honor?
THE COURT: Yes.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that page of transcript?
A. I have.
Q. Does it refresh your recollection about what you told the Santa Barbara Grand Jury
under oath on that issue?
A. Correct. Sure.
Q. Did you tell them that you watched it in its entirety?
A. I didnt see that. You have to show me again.

Q. Pardon me? Oh. May I?

A. Yes, sir. I see where I said I sat on the couch, yes, sir.
Q. Okay. Let me just go through this again. Have you had a chance to read that question?
A. I have.
Q. Does it refresh your recollection about what you told the Santa Barbara Grand Jury?
A. Yes, sir.
Q. Did you tell the Santa Barbara Grand Jury in response to the question, The interview
that Brad Miller did, was that an interview that you were ab le to watch in its entirety?
Were you there? A. Yes, sir, I was. I sat on the couch, yes, sir.
A. Yes, sir, but I was not sitting on the couch the entire time. It was a play on words. I
said it, but you know what? I wasnt sitting there the entire time. I was throughout the
apartment. I sat at my desk in the bedroom on many occasions.
Q. So what you told the grand jury is incorrect?
A. It was not that I was trying to lie.
Q. I didnt ask you that. Is what you told the Santa Barbara Grand Jury under oath
incorrect?
A. It would be incorrect.
Q. Okay. Now, you were also asked by the prosecutor if you saw any prompting by Mr.
Miller regarding what to say or what answers to give. Do you remember that?
A. Yes, sir.
Q. You said you didnt know of any prompting. You didnt know of any effort to tell Janet
or the kids what answers to give, correct?
A. I agree, yes.
Q. Now, youre aware that the rebuttal video was filmed February 20th?
A. I dont remember the specific date.
Q. Okay. But you do remember the Miller interview being on the 16th, correct?
A. Because you told me, yes, sir.
Q. And I believe you said that Janet -- well, actually, let me rephrase that. Obviously,
Janet and the children are at your apartment for that interview, right?
A. That is correct.
Q. Were they there the night before?
A. Yes, sir, they were. I believe they were.
Q. Were they there on the evening of the 16th, to your knowledge?
A. The night that they did the interview?
Q. Yes.
A. Yes, sir, they were.
Q. Do you know if they were there at your place the next day?
A. Seems to me they left the next day.
Q. And do you know where they went?
A. I believe they went back to Neverland.
Q. Okay. Now, did you know on the 20th that there was going to be an interview with
Child Protective Services at your apartment?
A. I believe I did.
Q. And how did you learn that?
A. Im not sure how I figured that out, other than maybe hearing Janet saying it on the
telephone to Frank.
Q. Well, Janet returns home that morning and sees you, correct?
A. Thats correct.

Q. Youre on the way out to work, right?

A. Right.
Q. Do you recall her telling you, Were going to be interviewed by Child Protective
Services?
A. No, I dont.
Q. Do you know why the interview with Child Protective Services was at your apartment?
A. No, I dont.
Q. At the time of the interview with Child Protective Services, were Janet and the children
living with you?
A. They were living with me, between there and Soto.
Q. Okay. And approximately how much of the time were they living with you?
A. Three, four days. It could have been as many as five days.
Q. Okay. And the rest of the days would be either at Soto or -A. Or their grandmothers house.
Q. Okay. Or they could be at Neverland, correct?
A. Well, no, they actually didnt go to 5868 Neverland, other than during this period right
here, that Im aware of.
Q. Okay. Okay. Now, you said words to the effect that the kids were hardly in school at
one point, right?
A. During the period that they were at Neverland.
Q. Okay. Were they in school during the period they were spending part of their time at
your place?
A. Yes, sir.
Q. All right. Were they in school on February 16th, 2003?
A. I dont believe so, sir.
Q. They were living at your place at least the night of the 15th and the 16th, correct?
A. I would say so.
Q. But they werent going to school, correct?
A. That would be correct.
Q. To your knowledge, were they going to school earlier that month?
A. Prior to leaving for Miami, they were going to school.
Q. Okay. So at some point theyre going back and forth to Neverland, right?
A. They came back once or twice.
Q. They were living at your place when they come back, correct?
A. Okay. Right.
Q. Sometimes theyre living at their grandparents place, right?
A. I dont think youre saying this properly.
Q. Okay. Tell me -- correct me, if you will.
A. They left for Neverland -- they left for Miami.
Q. Yes.
A. Basically they came back one time. And then when -- in March something, the whole
family came back. So during that period of time, Mr. Jackson -- according to what Frank
was saying and what Janet was saying is they were going to have a tutor. There would not
be a reason for me to put them back into school for one day when in fact they may be -- it
looks like they were leaving to go back to Neverland.
Q. Okay. So on the 16th and the 15th when they were staying at your place, you assumed
they were being tutored?
A. I believe that they were.

Q. Did you ask Janet -A. Or that they were going to be, yes.
Q. Did you ask Janet if they were being tutored?
A. I dont think I did ask Janet.
Q. At some point they were back at your place within a few days, because the rebuttal
video was on the 20th, right? 5870
A. The rebuttal video, and then they showed up that night -- or, excuse me, the next
morning, and then they were gone by the time I got home from work that night.
Q. Okay. And are you asking Janet at this point in time, Janet, are the kids being
tutored?
A. No, I was not.
Q. Did you ever ask Frank to pay for tutoring?
A. No.
Q. And you never spoke to Mr. Jackson, so you never asked him, right?
A. That would be correct.
Q. Okay. And you had already been to Neverland, so you knew there was an amusement
park and a zoo and a lot of things that appealed to kids, right?
A. Sure.
Q. And you must have assumed that when the kids went to Neverland, they were having a
fun time, right? Given the amusement park and the way Neverlands portrayed, right?
A. That would be an assumption.
Q. Okay. But you personally never tried to find out if they were being tutored at all at
Neverland, true?
A. That would be true.
Q. Now, you mentioned at some point there was an effort to get Gavin out of his local
school because he was being pressured to join a gang, true?
A. Correct. Janet dealt with that.
Q. And when was that change of -- excuse me. When did that change of schools occur?
A. Probably around the time that I moved into the St. Andrews apartment.
Q. And when was that?
A. In November of 02. Lets see. Yeah.
Q. So in November of 02, Gavins pulled out of a school because he is in some way being
pressured to join gangs, correct?
A. Both boys.
Q. Both boys in November of 2002 are taken out of their school because of gang
influence, right?
A. Actually, that would be -- let me see, I got to get my timeline, because I met Janet in
02. It would have been November -- November of 02. I guess thats correct.
Q. Okay. Thats November of 02 -A. Yeah, that would have been correct.
Q. -- before the trip to Miami in 03, right?
A. Thats correct.
Q. And when do you remember the trip to Miami being?
A. February of 03.
Q. Okay. And approximately when d id you tell the jury you suddenly noticed that Gavin
was not acting like a nice kid?
A. When I -- when he showed up at the beauty parlor or what they call the nail salon.
Q. Okay. And thats approximately when?

A. Sometime in early March.

Q. Where was the beauty parlor or nail salon?
A. On Wilshire Boulevard.
Q. Is that near where you work?
A. Within about five minutes.
Q. You work at Wilshire and Federal, correct?
A. I did, yes, sir.
Q. Federal is the cross street to Wilshire, true?
A. That is correct.
Q. And there is a federal build ing at Wilshire and Federal, correct?
A. Thats incorrect.
Q. Is there a federal building nearby?
A. No, sir. Theres one nearby.
Q. Where is it?
A. The next couple blocks down.
Q. Its a large federal building, true?
A. That is correct.
Q. And its a building that has the FBI office in it, true?
A. A federal building. FB I sounds good.
Q. Ever been in that building?
A. No, I havent.
Q. Okay. But its two blocks from where you work?
A. Yes, sir.
Q. Okay.
A. Past the V.A.
Q. And Wilshire and Federal is not far from the 405 freeway, correct?
A. That would be true.
Q. How long -- do you still work there?
A. I dont work in that location, no, sir.
Q. How long did you work in that locat ion?
A. Three years.
Q. And what were the years were talking about?
A. October of 01 through August of 04.
Q. Okay. So during the entire period that you testified about this morning, youre working
at that location, right?
A. Thats correct.
Q. And did you work there five d ays a week?
A. No, probably about 17 days straight without a day off.
Q. Okay. And where was the salon again? A few blocks away from where you worked?
A. Probably about five or six blocks down Wilshire Boulevard.
Q. And where on Wilshire, if you remember?
A. By the McDonalds. Im not sure. There was an Italian restaurant right there. I dont
have a street crossing.
Q. So would it be accurate to say that the salon is a couple of blocks from your military
base, right?
A. Five or six blocks.
Q. And its a few blocks away from the federal build ing, right?
A. That would be correct.

Q. Which you agree houses the FBI and other federal agents, correct?
A. About three miles away, four miles away.
Q. All right. To your knowledge, how long was Janet in the beauty salon on that particular
occasion?
A. Im really not sure. I would speculate an hour or two hours.
Q. And you went and visited the salon yourself, true?
A. I did.
Q. Did you drive there?
A. I did.
Q. Parked your car, right?
A. I did.
Q. Walked into the salon, correct?
A. That is correct.
Q. And saw Janet when you walked in?
A. Janet was sitting there, right.
Q. Was Janet getting a treatment of sorts?
A. Nothing that I saw at that point.
Q. Do you know if she already had some attention there?
A. You know what? I really dont know. I really dont know. I assume she did based on the
fact that she was there, but I dont know.
Q. You spoke to Janet, right?
A. Yes, I did.
Q. You then saw Gavin and Vinn ie come in, right?
A. Correct.
Q. You spoke to Gavin, right?
A. I spoke to -- yeah, I spoke to Gavin.
Q. To your knowledge, was that salon in the Brentwood area of Los Angeles?
A. I believe thats what they call the Brentwood area.
Q. Was this near a cross street called Barrington?
A. I would think that Barrington is close, yes.
Q. Okay. Now, thats a very -- Barrington and Wilshire is a very commercial-type area,
isnt it? You have store after store after store?
A. Yes, sir, thats correct.
Q. And Wilshire, for anyone who doesnt know, is a main thoroughfare through Los
Angeles, true?
A. That is correct.
Q. And if you keep going west for a few miles, you end up in Santa Monica, right?
A. That would be correct.
Q. And thats Santa Monica at the ocean, right?
A. Thats correct.
Q. Okay. And do you think Janet was at the salon for a couple hours?
A. You know what? Thats speculation. I really dont know how long she was there. She
called me from the salon.
Q. And how long were you at the salon?
A. Probably 25 minutes at the most.
Q. And then did you go back to work?
A. No. I went home.
Q. Where did you go?

A. I went back home.

Q. Okay. Anyone go back home with you?
A. Janet.
Q. Okay. Do you know approximately when that was?
A. Six oclock in the evening. Im guessing.
Q. And did Janet spend the evening at your apartment?
A. She did.
Q. What did she do the next day, to your knowledge?
A. The next day I believe she had a Family Court appearance.
Q. Okay. And did you go to Family Court with her?
A. No, sir, I went to work.
Q. Do you know if anybody went to Family Court with her that day?
A. I understand Vinnie did, but I dont know that to be a fact.
Q. Now, Family Court, to your knowledge, was in downtown Los Angeles, correct?
A. I believe so.
Q. And it goes without saying that in Family Court, you have bailiffs and police and state
employees, true?
A. Sir -- yes, sir.
Q. Do you know how long Janet was in Family Court that day?
A. Sir, I dont.
Q. Okay. Did she talk to you that day? BAILIFF CORTEZ: Sir, Im sorry, I need you to
speak into the microphone.
THE WITNESS: Okay. Yes, sir, she got home before I did, I believe.
Q. BY MR. MESEREAU: Did she stay at your home that evening, to your knowledge?
A. She did, yes, sir.
Q. And you saw her that evening?
A. I did.
Q. Approximately what time d id you see her after she returned from Family Court? 5878
A. Yes, I got home a little early because we called the Department of Child & Family
Services.
Q. Okay. All right. And the next day, was Janet with you?
A. I was at work.
Q. Where was Janet the next day, to your knowledge?
A. Im not sure where she was. I assume she was at home.
Q. Okay. Do you recall Janet ever going back to Neverland after that day?
A. No, sir, I dont.
Q. Okay. Do you know if she did?
A. No, sir, I dont think she did.
Q. Okay. Do you know if the children ever left Neverland after that date?
A. After the day that they were brought to their grandmothers house?
Q. Yes.
A. No, they did not.
Q. Okay. Were they brought to their grandmothers house before or after you saw Janet at
the salon, if you know?
A. No, it was after.
Q. Okay. So, you meet Janet at the salon. She goes home with you, right?
A. Correct.
Q. The next day she goes to court in downtown Los Angeles, correct?

A. That is correct.
Q. She comes back that night and is with you?
A. Right.
Q. And approximately when do you think the children are returned to the grandparents?
A. I believe the next day.
Q. Do you know how they got to the grandparents?
A. I dont know. Somebody from Jacksons entourage gave them a ride, I believe.
Q. Okay. Is that something you just heard from somewhere?
A. I believe so. I didnt see it.
Q. Okay. All right. And to your knowledge, there never was any trip to Brazil, right?
A. To my knowledge, no, but there was a claim that they were going to be taken to Brazil.
Q. I understand your point, but nobody ever went to Brazil, true?
A. That would be true.
Q. All right. How many times do you think you talked to Frank Tyson?
A. I spoke to Frank Tyson two times.
Q. And where did you speak -- excuse me. Where were you when you spoke to Frank
Tyson?
A. In my apartment.
Q. Okay. And Frank would call your apartment?
A. Continuously.
Q. Okay. Did you know where Frank was when he called your apartment continuously?
A. No, sir, I didnt.
Q. Okay. Did he -- did you speak to Frank in person or on the phone when you were
talking about the family not getting anything financial out of the rebuttal video?
A. Right, Ive never met Frank, so it was on the telephone.
Q. Do you know approximately when that discussion took place?
A. After Janet returned by herself from Neverland.
Q. And if you know, approximately when is that?
A. Mid February. Probably within a week after she left.
Q. So was this discussion before or after you meet her at the salon in Brentwood?
A. With Frank?
Q. Yes.
A. Prior to.
Q. Prior to?
A. Yes, sir.
Q. Okay. All right. And you indicated that Frank asked you if you were trying to blackmail
them, correct?
A. That is correct.
Q. Okay. And you certainly said, Were not, right?
A. Thats correct.
Q. You just thought the family should be properly compensated, right?
A. That would be correct.
Q. Okay. Did you ever threaten that the family wont be available to be filmed unless
theyre paid properly?
A. No, sir, I didnt.
Q. All right. How did you determine that somebody was going to make five million dollars
on
that rebuttal video?

A. I believe it was on television. They were talking about it, that the family was going to
be on there and that Jackson was making so many millions of dollars. Im not sure of the
specific dollar amount. It was a large sum of money.
Q. You did tell one of the sheriffs that you had learned about that on the Internet at one
time, correct?
A. That may have been. That may have been the way I heard it. Im not sure.
Q. Would it refresh your recollection just to show you a transcript of your police interview?
A. Please.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: Yeah. Correct.
Q. BY MR. MESEREAU: Have you had a chance to look at that page of transcript?
A. Yes, sir, I have.
Q. Does it refresh your recollection about where you said you learned that somebody was
going to make millions of dollars on that documentary?
A. Correct.
Q. You said the Internet, correct?
A. I did.
Q. Now, were you following issues related to Mr. Jackson and the Bashir documentary on
the Internet?
A. Not that Im aware of. I d id later, but I dont think I did at the time. I may have just
seen it on one of the Internet sites, CNN or MS-NBC.
Q. Okay. And in that interview with Paul Zelis, you said that Frank said, Were planning
on giving them a house. Were planning on giving the boys a college education, right?
A. Correct.
Q. And you told Mr. Zelis you were concerned that these things were not going to be in
any kind of a contract, right?
A. That is correct.
Q. And you asked Frank to include this stuff in a contract, right?
A. I dont know that -- no, I didnt ask him to put it in a contract. I said I would like to see
the contract. Then it went from protection, to tutor, to house, to all of these things that I
wasnt asking him about.
Q. Well, you were asking him about a contract because you wanted the family to be
properly compensated in a contract, correct?
A. I asked him if I could see the contract. I asked him if he could e-mail it to me.
Q. And he didnt respond?
A. He never d id. He d idnt respond.
Q. All right. Did you discuss with Janet at any time, We want to see if were going to be
properly compensated in a contract?
A. I did not.
Q. Never even discussed the subject with her?
A. No, sir, I didnt.
Q. Did you ever discuss that subject with any of the children at any time?
A. No, sir.
Q. Did you ever tell Janet or the children,Dont let them film you. W e havent had an
appropriate contract signed?
A. Oh, no, sir. The phone was passed to Janet. She ended up talking to them on the
phone, him on the telephone, and they ended up going and doing it. There was no

contract that Im aware of -- Q. Okay.

A. -- at all.
Q. While you were talking to Frank about proper family compensation in a contract, were
you also talking to these reporters for the British tabloids?
A. No, sir.
Q. Did it ever cross your mind that if you or Janet entered into some deal with a tabloid, it
might destroy your ability to get compensated in the rebuttal video?
A. No, sir, that was never an issue.
Q. Do you know if Janet ever spoke to Mr. Jackson about all of these media sources
contacting her to make a deal?
A. I dont know.
Q. All right. You heard her voice on the Brad Miller interview tape -A. Correct.
Q. -- a few minutes ago. You heard her saying that she was essentially under siege by
media people, correct?
A. Her mother was, actually.
Q. Well, she said she was and her parents were, correct?
A. Okay.
Q. She talked about Celebrity Justice and Extra and other shows, true?
A. They may have been showing up. 5885
Q. Okay.
A. I just heard them calling.
Q. To your knowledge, did she attempt to discuss any of this with Mr. Jackson?
A. I dont know what she talked to with Mr. Jackson.
Q. Now, she says on that tape that she and the family are being besieged by media, right?
A. Okay.
Q. And that is February 16th, 2003, correct?
A. Okay.
Q. And within certainly the next couple of days, youre in a discussion with Frank about
proper compensation and a contract, true?
A. Okay.
Q. That doesnt happen, to your knowledge, right?
A. That is correct.
Q. Theyre filmed on the 20th, right?
A. Okay.
Q. The next day theyre at your home to be interviewed by Child Protective Services,
right?
A. Correct.
Q. And to your knowledge, in the middle of all this turmoil, there now is a claim that
molestation began sometime on the 20th. Is that your knowledge?
MR. ZONEN: Objection. Speculative. Lack of foundation. No personal knowledge.
THE COURT: Foundation; sustained.
Q. BY MR. MESEREAU: Have you discussed this case with Janet at all?
A. No, sir.
Q. How long have you lived with Janet?
A. Since -- for sure, since March of 03.
Q. Have you discussed this case with Gavin at all?
A. No, sir.

Q. Have you discussed this case with Davellin at all?

A. No, sir.
Q. And have you discussed this case with Star at all?
A. No, sir.
Q. Have you ever seen the rebuttal videotape that appeared on televis ion?
A. That appeared? What do you mean?
Q. The one that was on television. You saw that, didnt you?
A. The Take 2?
Q. Yes.
A. I did see it, but I really dont remember a who le lot of it.
Q. Was that a Maury Povich -A. Thats right. That was the Maury Povich one.
Q. To your knowledge, has Janet ever seen the Bashir documentary?
A. No, not to my knowledge.
Q. To your knowledge, has Janet ever seen the Maury Povich rebuttal?
A. Not to my knowledge.
Q. Okay. Have you ever d iscussed with Janet why she and the children dont appear in the
rebuttal T.V. show with Mr. Povich?
A. No, sir.
Q. Never even broached the subject with her?
A. No, sir. No, sir.
Q. How long have the children lived with you?
A. Same period.
Q. Same period you just gave for Janet?
A. Thats correct.
Q. Okay. Now, at some point you moved to West Los Angeles, right?
A. That would be correct.
Q. And when was that?
A. In November of 03.
Q. And how long did you live there?
A. Till about July of 04.
Q. And just to -- excuse me. Let me rephrase that question. Do you know how long Janet
kept an address on Soto Street in East Los Angeles?
A. I believe that she did away with the address once the people took her stuff away from
her 5888 apartment.
Q. Im asking you how long she lived -A. That would have been in March of 03, yeah.
Q. March? Okay. Have you ever been present in any meeting that Janet has ever had with
an attorney?
A. Yes, sir.
Q. And -A. Yes, sir.
Q. And how many meetings where Janet met with a lawyer have you been present at?
A. The only one that I can remember is the one with Bill Dickerman.
Q. And do you know when that was?
A. Sometime in April. 03.
Q. Is that April of 03?
A. It was either -- yeah, it was late March or April of 03, I believe.

Q. Where did that meeting take place, if you know?

A. At his office.
Q. Okay. Did you drive Janet to the office?
A. I believe I did.
Q. Was someone named Jamie Masada present?
A. No, sir.
Q. Do you know who Jamie Masada is?
A. I know who Jamie is, yes.
Q. Do you know him personally?
A. Yes, I do.
Q. When did you last talk to him?
A. Its been quite a while. I really dont have a specific date.
Q. How many times have you met with him?
A. I have met Jamie and have had a couple of social occasions at my house. Maybe four or
five total.
Q. Okay. Is that the house in West Los Angeles?
A. That would be the house in West Los Angeles.
Q. So that would be between November of 2003 and July of 2004?
A. It would have been from the time that I met Janet in July of 02 through present day.
Q. Okay.
THE COURT: Counsel?
Q. BY MR. MESEREAU: So the last time you saw -THE COURT: Counsel? Are you ready to quit?
MR. MESEREAU: Okay. Yes, Your Honor.
THE COURT: All right.

2005 April 13 (Day 31) Jay Jackson & Janet Arvizo Cross Examination

JAY D. JACKSON CROSS-EXAMINATION (Continued)

CROSS-EXAMINATION (Continued) BY MR. MESEREAU:
Q. Major Jackson, you testified that at one point you met Janet at a salon in Brentwood,
correct?
A. Yes, sir.
Q. Were you in uniform?
A. Yes, sir, I was.
Q. Were you on active duty at that point?
A. Yes, sir.
Q. And were you working during the time period that you visited Janet at the salon in
uniform?
A. I had just left my job for the day.
Q. Okay. Now, Janet began to live with you on a regular basis during what month and
year?
A. Regular basis would have been sometime after November of 0 -- lets see here. 02, I
believe.
Q. And she certainly was living with you from January through June of 2003, correct?
A. That is correct, less the period of time between February and March where she was
gone to Neverland.
Q. Okay. But when she wasnt visiting Neverland, it was your belief that Janet and the
children were living with you, correct?
A. They were living between my house -- my apartment and the Soto Street apartment.
Q. And most of the week, I believe you said approximately five days, they would live with
you, correct?
A. Three to five days. It depended.
Q. Okay. And did you ever tell any interviewing sheriff in this case that you were
supporting Janet and the children during that period of time?
A. I dont recollect that. Youd have to -Q. Were you doing that?
A. There was probably in some ways I was.
Q. In what way were you supporting Janet and the children during the period from
January through June of 2003?
A. Well, of course they were sometimes staying in my house, my apartment. There was
food. And she used my car sometimes. Thats -- you know, thats the best I can think.
Q. Did you ever pay her rent?
A. I did pay her rent for her based on the money that she received.
Q. And the money that she received was through welfare, correct?
A. I believe -- assistance of some form.
Q. And you were allowing her to deposit her public assistance checks into your bank
account at Bank of America, correct?
A. Two times that occurred, I believe.
Q. It actually occurred more than two, did it not?
A. Two is what I remember. But if you say it was three, okay, fine, Im not -- you know,

Im not going to argue with that.

Q. Now, she received a welfare check from the County of Los Angeles in the amount of
$769 on January 2nd, 2003. Do you remember that?
A. I remember a couple of welfare checks. I dont remember the dates, sir.
Q. Would it refresh your recollection to just see that check?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes. THE WITNESS: And that was the deposit. It shows it being a deposit,
correct? Not just cashing? MR. MESEREAU: Im not allowed to talk. THE WITNESS: Okay. I
see it went into the Bank of America.
Q. BY MR MESEREAU: Have you had a chance to look at the documents I just showed
you?
A. Yes, sir.
Q. And did you see a check from the County of Los Angeles addressed to Janet Arvizo
dated January 2nd, 2003, in the amount of $769?
A. Yes, sir.
Q. And isnt it true that you took that check, endorsed it, and deposited it into your Bank
of America account? Right?
A. Yes, sir.
Q. Now, your Bank of America account lists your home address at 450 South St. Andrews
Place, No.307, in Los Angeles, correct?
A. That would be correct.
Q. And that was the address that you described as being in Korea Town area of Los
Angeles, true?
A. That is correct.
Q. The welfare checks going to Janet Arvizo were addressed to her address at 802 North
Soto Street, correct?
A. Correct.
Q. Okay. So you did that in January. You also did that -- excuse me. Let me rephrase. She
received a welfare check in -- on February 15th, 2003, that you also endorsed and
deposited into your Bank of America account, correct?
A. Yes, sir.
Q. And that check was in the amount of $769, true?
A. Excuse me, yes, sir.
Q. That check also was addressed to Janet Arvizo at 807 -- excuse me, I said 802 before -807 North Soto Street, Los Angeles, true?
A. Yes, sir.
Q. Now, at some point, Janet became a signatory to your bank account, correct?
A. Yes, sir.
Q. She wasnt a signatory to your bank account in January and February of 2003, right?
A. I dont believe she was. Im really not sure when she actually did become a signatory. I
know she did.
Q. Now, in January and February the account was strictly in your name, true?
A. That would -- I believe that would be correct, yes, sir.
Q. Okay. Now, on May 19th of 2003, Janet received a welfar e check in the amount of
$528.61 that you also appear to have deposited into your account. Do you remember
that?
A. I dont.

Q. Okay. Would it refresh your recollection just to see that check?

A. Sure. MR. MESEREAU: May I approach, Your Honor? THE COURT: Yes. MR. ZONEN:
May I see that, please? THE W ITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that document?
A. Yes, I have.
Q. And that is a check addressed to Janet Arvizo by the County of Los Angeles dated May
19th, 2003, correct?
A. That is correct.
Q. And you appear to have endorsed that check, correct?
A. Yes, sir.
Q. And on that check, Janet Arvizos address is 12643 Raymer Street, El Monte, California
91723. Do you see that?
A. Yes, sir. I wou ld believe that thats not a welfare check. I believe its maybe some type
of public assistance. But I dont believe its welfare.
Q. Was it a disability check?
A. I dont know. But I dont believe that was welfare. I believe she cut that off after the
Jackson people closed her apartment.
Q. Okay. Now, approximately -- lets see.Well, on May 5th, 2003, she also got a check
from the County of Los Angeles for $203.54. Do you remember that?
A. No, I dont. It may be -- it may be child support. Im not sure.
Q. Would it refresh your recollection if I show it to you?
A. Sure. Yes, sir. I believe thats child support.
Q. Youve had a chance to look at that document, correct?
A. Yes, sir.
Q. The document is -- its a check from the County of Los Angeles in the amount of
$203.54, right?
A. Thats correct.
Q. Its addressed to Janet Arvizo at 12643 Raymer Street in El Monte, correct?
A. That would be correct.
Q. And you did endorse that check as well?
A. Yes, sir.
Q. Okay. On May 5th, 2003, Janet Arvizo received a check in the amount of $268.48. Are
you aware of that?
A. Im sure it is, if youve got it there. Im sure its child support.
Q. And you endorsed that check as well -A. Okay, sir.
Q. -- true? Okay. Now, at some point did you learn that Janet Arvizo wrote to the Los
Angeles County welfare authorities and said, Stop sending me welfare?
A. I believe she did, yes.
Q. Did you actually see the note she wrote?
A. No, I dont think I did. But I believe that she did. I think she told me she did.
Q. Now, you would agree that you were provid ing some financial support during January
and February of 2003 to Janet and the family, correct?
A. You know what? She was depositing those checks into my account and that was
probably what she was using for support.
Q. Okay. You were paying utility bills also for Janet, were you not?
A. Was I paying utility bills?
Q. Yes.

A. I may have paid a utility bill.

Q. Did you help the family out financially during -- excuse me, let me rephrase. During
January and February of 2003, were you providing any financial assistance to Janet Arvizo
and her children?
A. If I provided support to them during that period, it would have been from that welfare
check.
Q. So let me get this straight. You know Janet had a bank account at that point, didnt
she?
A. No, sir, I did not.
Q. Did she have an account anywhere, to your knowledge?
A. Not that Im aware of. In fact, she was cashing her checks that she was receiving at
one of these check cashing -- and thats the reason it costs 6 or 8 or 10 percent to cash it.
So I asked her, I said, Lets cash it through my account and that way you dont lose that
money.
Q. Okay. Okay. Do you recall writing any checks on your own to Janet during those first
two months?
A. I dont, sir.
Q. Do you know -- do you recall writ ing checks to Janet at all during the early part of
2003?
A. I dont.
Q. Okay. Did you ever provide any financial assistance to the children during Janu ary,
February or March of 2003?
A. I dont recall. If I d id, I would have
Q. So your position is that the only money you gave Janet during January and February of
2003 was welfare money she had given you?
A. That would be my impression. I was not -- I dont know any rules with regards to
welfare. I wasnt concerned about that. She was my girlfriend, they were her children. If I
gave them any money it was because it was out of the goodness of my heart.
Q. I understand that. My question to you is, Janet deposited welfare checks and then child
support checks into your bank account at Bank of America in Los Angeles, correct?
A. Correct.
Q. And this was starting in approximately January of 2003, true?
A. That would probably be true.
Q. And are you saying under oath, Major Jackson, that the only money you took out of
that account and ever gave to Janet and the children was Janets own money?
A. Could you restate the question, please, a different way?
Q. Sure. If its not clear, Ill -A. Please.
Q. -- rephrase it. Are you saying under oath that between January 2003 and May of 2003,
the only money you gave Janet Arvizo out of your bank account was money she had put
into your account?
A. Sir, I think I answered that, and that is, is that I dont know that answer. And that if I
did give her money that would have been above and beyond what she was receiving, that
would have been coming from me out of the goodness of my heart. Because she was my
girlfriend and I did love her children.
Q. Okay. And did she tell you at some point, I want to deposit welfare checks into you,
Major Jay Jacksons back account?
A. No, sir. Im the one that said, Why dont we put it into my account because its -- it

will save you a little b it of money, from what little bit of money you do get.
Q. Okay. Did you ever look at any of Janet Arvizos welfare applications to Los Angeles
County?
A. No, sir.
Q. Did she ever ask you to prepare one of those applicat ions?
A. No, sir.
Q. Do you know whether or not she was honest on any applicat ion she sent to Los Angeles
County involving requests for public assistance?
A. Janets pretty honest, but I dont know that to be a fact.
Q. Okay. Now, during -- May I take just one second, Your Honor, to look through --THE
COURT: Yes.
Q. BY MR. MESEREAU: During the time that Janet Arvizo was living at your home -A. My apartment.
Q. Your apartment. That was your home, right?
A. Its where I lived.
Q. Okay. And were talking about the period starting in January of 2003, you were being
paid by the United States Government, correct?
A. That would be correct.
Q. And your base pay was $5,310.60, correct? MR. ZONEN: Ill object as irrelevant.THE
COURT: Overruled. THE WITNESS: Sir, I dont have that in front of me. But if thats what
my LES says, then thats correct.
Q. BY MR. MESEREAU: Would it refresh your recollection if I just show you the document
we subpoenaed from the Army?
A. Sure. MR. MESEREAU: May I approach, Your Honor? THE COURT: Yes. THE WITNESS:
Yes. Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that document?
A. Yes, sir.
Q. Have you seen that document before?
A. I see my LES monthly.
Q. Okay. And let me restate the amount. The amount went up. Well, the amount of base
pay you were receiving effect ive January of 2003 was $5,528.40 per month, correct?
A. That would be correct.
Q. Okay. The amount of base pay you received in February of 2003 from the United States
Government was also $5,528.40 per month, correct?
A. Yes, sir.
Q. And the amount of base pay you received from the United States Government in March
of 2003 was $5,528.40 per month, correct?
A. Yes, sir.
Q. And the amount of base pay you received in April of 2003 from the United States
Government was $5,528.40 per month, correct?
A. Yes, sir.
Q. Okay. Do you recall whether or not you ever requested any type of housing allowance
or assistance from the United States Government because Janet Arvizo and her three
children were living with you?
A. It would not matter. I could not request assistance from the government unless I
married her.
Q. Okay.
A. So that would have occurred in May of 04.

Q. Okay. So you didnt do it anytime in 2003?

A. No, sir, I wouldnt have been able to. It wouldnt have mattered if I did it, and I
wouldnt have done it.
Q. Okay. Okay. W as it your understanding Janet Arvizo had no other bank accounts on her
own -- excuse me, thats a poor question. Let me rephrase. Was it your understanding,
Major Jackson, that in the months of January, February, March and April of 2003, Janet
Arvizo did not have any bank account?
A. Yes, sir. That would be my recollection.
Q. Okay. Do you know if she ever had an account at a bank called Providian?
A. No, sir.
Q. Okay. Did you ever discuss with Janet Arvizo whether or not she had ever obtained any
money from a J.C. Penney settlement?
A. She -- no, sir, she did not talk about it. I started learning about it through the news.
Q. Okay. Do you know whether or not, during January, February, March or April of 2003,
Janet Arvizo was making any deposits in her mothers account at Sanwa Bank?
A. Im not aware of that, sir.
Q. Were you ever aware of any account that Janet Arvizo had set up at any bank involving
moneys she had obtained for the benefit of Gavin?
A. No, sir.
Q. Okay. And were you ever involved in any fund-raising efforts for Gavin?
A. No, sir.
Q. Okay. Now, are you saying that the money you received every month during January,
February, March or April was not used for the benefit of Janet or the children? MR.
ZONEN: Objection; vague. His paycheck? MR. MESEREAU: Yes. Ill rephrase it. Counsels
correct.THE WITNESS: Please.
Q. BY MR. MESEREAU: The base pay you earned from the United States Government in
January, February, March and April of 2003 was never used directly or indirectly for the
benefit of Janet or the children, correct?
A. Cannot answer that question with accuracy.
Q. Okay. You testified yesterday that at one point Janet Arvizo went to court in downtown
Los Angeles to deal with her domestic issues involving her ex-husband David, correct?
A. Yes, sir.
Q. Do you know approximately when that was?
A. That would have been right around the time of -- it would have been in the middle of
March.
Q. Okay. Would that be March of 2003?
A. Yes, sir.
Q. Did you know -- excuse me. Did you know 5908 whether or not Janet Arvizo filed an
income and expense declarat ion in that court case that youve just described?
A. No, sir, I do not.
Q. Okay.
A. I did not. Im not even sure what that is.
Q. Was any of the welfare money or child support money that was deposited into your
bank account during January, February, March, April of 2003 ever used for your benefit?
A. No, sir.
Q. Okay. And do you know whether or not Janet Arvizo ever disclosed to welfare
authorities and the County of Los Angeles that you were help ing her pay rent?
A. I do not know. I just know that when the apartment got taken away from her by

Michael Jacksons assistants, she apparently at that time wrote a letter to them and just
cancelled her welfare.
Q. Thats not really answering my question,now, is it? Thats something that you just
wanted to tell the jury, correct?
A. Okay. MR. ZONEN: Objection; argumentative. THE COURT: Counsel -- MR. MESEREAU:
I withdraw it.
Q. Lets talk about the checks you wrote to Mr. Trujillo when you were paying her rent at
her apartment.
A. All right.
Q. Do you know whether or not Janet Arvizo ever disclosed the rental payments you were
making on her behalf to welfare authorities in Los Angeles?
A. Sir, I believe that those checks that I wrote to Mr. Trujillo for her apartment on Soto
Street were in relat ions to the welfare checks that she was receiving in the January,
February time frame.
Q. So what youre saying, Major Jackson, under oath to this jury, is that you can
guarantee that the rent checks you wrote to Mr. Trujillo on behalf of Janet Arvizo to pay
rent came d irectly from her welfare checks; is that true?
A. I remember -- you need a yes or no?
Q. Yes.
A. Okay. I cant answer that yes or no.
Q. Okay. All right. Do you know whether Janet Arvizo ever disclosed the financial
assistance you were giving her on her income and expense declaration that she filed in
her domestic case - domestic relat ions case with David?
A. Did I not answer that already, sir? I said I dont even know what that document is, so I
did not know that.
Q. Okay. And you didnt help her ever prepare a document like that, correct?
A. No, sir, I did not.
Q. Okay. Do you recall during January, February, and March of 2003 whether or not Janet
Arvizo was depositing any checks into your account other than welfare and child support?
A. Well, she probably -- the child support began at some point after that, but Im not sure.
Im not clear when that started, so I dont want to say it started in March. But it was soon
thereafter, I think.
Q. Do you recall, during January, February, March and April of 2003, endorsing for deposit
any checks written to Janet Arvizo that were other than welfare and child support?
A. Not that Im aware of.
Q. Okay. During January, February, March and April of 2003, were you aware of any bank
account Janet had set up at a bank called W ashington Mutual in Los Angeles?
A. No, sir.
Q. During January, February, March and April of 2003, to your knowledge, was Janet
Arvizo driving an automobile?
A. No, sir, she was not.
Q. Did you ever learn at some point that she had purchased an automobile?
A. I -- I believe at some point she later told me that she had put some money down on a
car and then opted out of it.
Q. Do you know when that was?
A. I dont.
Q. Okay. During January, February, March and April of 2003, to your knowledge, did Janet
Arvizo ever obtain any disability assistance from the state?

A. Not that Im aware of.

Q. Okay. And during January, February, March and April of 2003, to your knowledge, did
Janet Arvizo ever obtain any food stamp assistance?
A. I did see food stamps, yes, sir.
Q. Okay. And was that during the time she was living with you?
A. That was the time that she was visiting me at Bundy, and that was prior to November
of 02.And Im not sure exactly when that stopped.
Q. Okay. Were you -- excuse me. Did you know Janet Arvizo in November of 2001?
A. No, sir, I did not.
Q. Okay. When did you first meet her?
A. July of 2002.
Q. Now, in January, February, March and April of 2003, were Davellin, Gavin and Star
living at your apartment at least part of the week?
A. Well, during -- of course in February and March they were gone almost the entire time.
At least through the middle of March. But January, some of February and March, Davellin
was not living with us, and Star and Gavin were living with us when they were -- when
Janet was there.
Q. Okay. All right. And what I think youve told the jury is that Janet wanted to keep the
Soto Street apartment but Mr. Jacksons people prevented that; is that what youre
saying?
A. I know that -- I believed that we wanted to keep the apartment, so that is what I say,
is that before she was whisked off to Miami, our intention was for her to keep the Soto
Street apartment.
Q. Okay. When the Soto Street apartment was no longer rented by Janet, did she and the
children live with you full time?
A. When the Jackson people shut down the apartment, she moved into my apartment
after she left Neverland.
Q. Okay. Did you ever wonder why someone on welfare wanted two residences?
A. No, sir.
Q. Did you ever discuss with any prosecutor before you testified in this trial your having
deposited Janets welfare checks into your account at Bank of America?
A. No, sir. It wouldnt have been an issue.
Q. How do you know?
A. Its not an issue. MR. ZONEN: Objection; argumentative. THE COURT: Sustained. THE
WITNESS: What does that have to do with anything?
Q. BY MR. MESEREAU: Have you ever d iscussed with any prosecutor before you testified
in this trial anything about Janets obtaining welfare assistance while she lived with you?
A. Wasnt my concern, sir.
Q. Has any prosecutor or sheriff ever showed you before you testified in this trial any
documents relating to any kind of public assistance Janet Arvizo was receiving at any time
from the County of Los Angeles?
A. No, sir, not that I recall.
Q. And has anyone associated with any prosecutor ever spoke to you on the phone about
Janet Arvizos receiving public assistance while associated with you?
A. Not that I can rememb er, no.
Q. Okay. To your knowledge, was Janet Arvizo receiving any welfare checks in the year
2002?
A. I dont know, sir.

Q. Do you recall depositing any of Janet Arvizos welfare checks into your bank account
during the year 2002?
A. If you have that, then I guess I did. I just dont remember.
Q. Okay. Did you have any discussion with Janet at any time about why welfare checks
were going through your sole account?
A. Please restate the question.
Q. Sure. Did you ever have any discussions with Janet Arvizo at any time as to why
welfare checks were being deposited into your sole account?
A. Any check that would have been deposited in my account would have been to save her
money from putting it through one of those check cashing places that charge 6 to 8 to 10
percent.
Q. Did you ever wonder why Janet didnt have her own bank account, to your knowledge?
A. No, sir, I didnt. MR. MESEREAU: No further questions at this time. THE COURT: All
right. Redirect?
REDIRECT EXAMINATION BY MR. ZONEN:
Q. Mr. Jackson, Major Jackson, good morning.
A. Good morning, Mr. Zonen.
Q. Do you recall the phone number that you had when you were living at the St. Andrews
apartment? This is a challenge, isnt it?
A. Yes, it is.
Q. Would it help you to recall that phone number if I were to show you a phone bill?
A. Yes, sir, it would. MR. ZONEN: May I approach the witness? Im just going to show you
something.THE WITNESS: Okay. Yes, sir. That is.
Q. BY MR. ZONEN: Tell us what that phone number is.
A. Oh, great. (213) -- (213) 739-9279.
Q. You now remember that?
A. Yes, sir, I do. But dont walk away and ask me again.
Q. Mr. Mesereau had asked you questions about checks that you deposited into your
account. Do you know where your wife, then your girlfriend, Janet Arvizo, was depositing
checks that she was receiving for public assistance at that time?
A. She wasnt. She wasnt depositing them, as far as I know. She was cashing them at
check cashing places.
Q. Do you know which places she was going to?
A. Not always. Sometimes wed be going down the road and wed stop at one of them on
the side of the road.
Q. Did you have a d iscussion with her about the cost of doing that?
A. Yes, I did. That was the whole issue. I said, Theyre charging you 6 or 8 percent to do
that. Why dont you just deposit it into my account and Ill either write the check for your
bills or Ill give you the money. Im not sure which one I did.
Q. Mr. Mesereau asked you about paying her rent.
A. Yes, sir.
Q. How were you doing that? Where was the money coming from that you were writing
checks?
A. From my Bank of America account.
Q. All right. And then the money that was coming into your account from the welfare
check?

A. Yes, sir.
Q. Was that covering it?
A. Yes, sir. I believe the check was like 425.
Q. Give us a sense. The rent was about how much per month?
A. 425.
Q. And the public assistance check was about how much?
A. 700-some.
Q. And then did you write checks for utilities as well?
A. I believe I did. But Im not absolutely positive.
Q. Was that covered as well by the amount of the welfare checks?
A. Yes, sir, it was.
Q. Do you know how she was paying her utility bills before?
A. I dont.
Q. Did you ever see a checking account in her name?
A. No, sir, I did not.
Q. Did you ever see her sit down and write a check?
A. No, sir, I didnt.
Q. Did you ever see her with her own car during the time that you were dating her?
A. No, sir.
Q. Do you know how she was getting back and forth?
A. Bus.
Q. When you met her -- you met her at a -- one of the kids military events, is that
correct?
A. Thats correct. Where I worked.
Q. And where you were working at that time was where?
A. Its at 311 COS-COM in Los Angeles, West Los Angeles, in the Sea Cadet Command and
located within the building.
Q. And what would be involved in taking a bus from where she was living at that location?
A. You know what? I dont know how long it would take. But it was quite a long distance,
so probably several hours to get there.
Q. At any time during the time that you were dating, did you see her drive her own car?
A. No, sir, she never had her own car.
Q. You said that both of you wanted to maintain the Soto Street apartment in East Los
Angeles?
A. That is correct.
Q. Tell us why.
A. Primarily it gave her a good place to go to when she was visiting her mother. She had
some stuff that she had in the apartment that she was storing. And basically she just
didnt want to give that apartment up because she really didnt feel that she was living
with me. She was living there. But she was visiting me.
Q. Do you know when it was that she sent a letter that discontinued her welfare?
A. I dont, sir. I dont know exactly. I just heard about it.
Q. If I were to show you a copy of that letter, would that refresh your recollection?
A. It may. Im not sure.MR. ZONEN: May I approach the witness? THE COURT: Yes. THE
WITNESS: Actually, I have seen that letter.
Q. BY MR. ZONEN: Does that letter refresh your recollect ion?
A. Yes, sir.
Q. And what is your recollection?

A. You know, just -- I rememb er the letter, but Im not even sure when I saw it.
Q. Do you remember when you stopped depositing welfare checks into your account?
A. I dont know exactly when I stopped, because there were -- the child support payments
coming in, so I was not concerned about it. I didnt know there was an issue with a
welfare check versus a child support check versus anything else.
Q. Were the child support checks of a different amount than the welfare check?
A. Yes, sir, they were.
Q. Was the welfare check pretty consistently in the seven hundred --THE COURT: Theyre
not hearing you, Counsel. MR. ZONEN: Im sorry.
Q. The question previously was --THE BAILIFF: Is your microphone on? THE COURT: He
had his book on it. MR. ZONEN: I had the book on it, Im sorry. I apologize.
Q. The welfare check, was that a fairly consistent amount every month?
A. Yes, sir. I believe it was 700-something dollars a month.
Q. The child support check, would that vary or was that consistent as well?
A. That varied. Always low.
Q. The amount -- the check that Mr. Mesereau showed you that was in May -A. Yes, sir.
Q. -- did you believe that was a child support check?
A. Im sure its a child support check. MR. ZONEN: Your Honor, Im going to ask the Court
take judicial notice of the fact that February 15, 2003, is a Saturday, February 16, 2003,
is a Sunday. And I have a copy of the calendar to furnish the Court. MR. MESEREAU: Sure.
Sure. THE COURT: No objection? MR. MESEREAU: No objection, Your Honor. THE COURT:
All right. Ill take judicial notice of those dates and days.
Q. BY MR. ZONEN: You were asked yesterday by Mr. Mesereau whether or not the
children went to school on February 15 and February 16 of 2003. Did the children
traditionally attend school on Saturday and Sunday?
A. No, sir.
Q. Id like to ask you questions about your discussion with Frank, wherein he offered you
a house, and he offered you childrens education, subsequently then asked if you were still
waiting for a house.
A. Right.
Q. Tell me about your view of that offering of a house. How did you take it at the time he
offered it?
A. The time -- the way I took it was, he wasnt offering to show me the contract. The
bottom line was I really did not believe him. I did not believe that he was going to give us
a house. I did not believe that he was going to give a co llege education. All of this was
just -- just talk. Thats the way I felt about it at the time.
Q. Why did you want to see the contract?
A. I wanted to see what it is -- what it was that the family was being required to do, and
what rights they were signing away.
Q. You had the opportunity to listen to the tape of the Miller interview, that interview that
took place in your home on presumably the 16th of February?
A. Yes, sir.
Q. At the very beginn ing everybody introduced themselves and you were not one of them;
is that correct?
A. Thats correct.
Q. Were you a witness to that particular event?
A. I did watch parts of it.

Q. Were you not asked to introduce yourself?

A. No, sir, I was not.
Q. Were you still in the room at that time?
A. Yes, sir, I was in the room.
Q. Did you leave the room at different times?
A. I did, sir.
Q. At one point you were asked by Mr. Mesereau whether or not you stated to the grand
jury that you watched the entire proceedings?
A. Correct.
Q. At another time he said, Did you state to the grand jury whether you had listened to
the entire proceedings?
A. Correct.
Q. Did you listen to the entire proceedings?
A. No, sir. In fact, when they played, I d idnt really know much of anything was on there. I
dont recall.
Q. Im sorry. Is there anything that you heard on that tape that you do recall?
A. The only thing that I do recall is something -- they were praising Michael Jackson,
saying he didnt touch them, something to that effect.
Q. At any time did you make an attempt to discuss with Janet Arvizo at the time, during
this February and March period when she was at Neverland, what was going on?
A. Janet did not talk much. She would not explain to me why she was emotional, why she
was crying. She wouldnt tell me what was going on during this period.
Q. Did you make an attempt to contact police during that time?
A. Yes, sir, I did.
Q. Who did you call?
A. After a short phone call with Janet where she appeared to be under duress, I made a
phone call to the Santa Barbara Police Department. It was late at night. And they
transferred me to the Santa Barbara Sheriffs Department.
Q. And did you talk with a deputy at the sheriffs department?
A. I talked to a sergeant.
Q. Do you know his name?
A. McCadden, I think. McCadden or something like that.
Q. Did you tell him about what was going on?
A. I was confused. I did not know what was happening. I talked to him. I init ially tried to
explain to him that I had a family that was at Neverland, and they appeared to be under
duress. He didnt want to believe -- you know, Is this a crank phone call? What was going
on? You know, I tried to say, Look, Im in the military. Im not playing. This is -- They
are -- They were on T.V. Basically he finally said, Well, why didnt she call 9-1-1? And
I said, Well, I dont know why she didnt call 9-1-1, because she kind of hung up on me,
and she made some kind of statement like, Oh, my gosh, here he comes, and she hangs
up on me.
Q. Major Jackson, the next day, did they call you back, from the sheriffs office?
A. Yes, sir, they did.
Q. And was Janet home at that point?
A. Janet was back in El Monte.
Q. And did you indicate to him that everything was under control?
A. I did. He said, Is she back? I said, Yes, she is. And that ended the conversation.
Q. On a couple of occasions Mr. Mesereau referred to your house in W est Los Angeles?

A. Correct.
Q. Did you have a house in West L.A.?
A. No, sir. I had a two-bedroom apartment.
Q. Was this an apartment that you lived in with Janet Arvizo?
A. Yes, sir, I did.
Q. And how many of her children?
A. Two of her children. G avin and Star.
Q. And where was Davellin living at that time?
A. She was living with her grandmother.
Q. Did she visit?
A. Yes, she did. Pretty much every weekend.
Q. So she was there for the weekend?
A. Yes, sir.
Q. You indicated just now that -- or earlier this morning, that at some point, Janet Arvizo
became a signatory to your account?
A. Yes, sir.
Q. Do you know when that was? Were you already married?
A. You know, Im not clear on that. It may have been after we got married. But Im just
not sure.
Q. Mr. Mesereau asked you about amounts of money that you were making and described
it as base pay. W hat does that mean, base pay?
A. Base pay is -- in the military, youre given base pay, which is your -- basically your
salary, which is taxable. And then youre given a housing allowance, which is nontaxable.
And youre also given a food allowance, which is nontaxable.
Q. The base pay that was described, was that the amount of money that you received
before or after taxes?
A. Before taxes.
Q. So taxes are deducted from that amount of money?
A. Yes, sir.
Q. Mr. Mesereau asked you about a Washington Mutual account established in 2003. Are
you aware of any such account?
A. No, sir.
Q. Did Janet ever mention to you a Washington Mutual account?
A. No, sir.
Q. Did she ever write a check on it in your presence?
A. No, sir. I never saw a checkbook.
Q. Im sorry?
A. I never saw a checkbook.
Q. You never saw a checkbook.
A. So I know nothing about it. MR. ZONEN: Thank you. I have no further questions.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Major Jackson, you called the police on Tuesday, February 11th, 2003, correct?
A. I dont have the specific date in front of me, but I believe it was right around that time,
yes, sir.
Q. You told the police your girlfriend had flown to Florida with her children, right?
A. Miami, correct.

Q. Okay. You told the police that youd received several telephone calls from her during
the last few days, right?
A. Correct.
Q. Okay. And you were concerned about her welfare, correct?
A. That is correct.
Q. You then -- after discussing the situation with the police, you and the police officer
concluded that Janet appeared to have unfettered access to a phone, true?
A. That she had called me, absolutely, yes, sir.
Q. Okay. And after your init ial call, you received a call back from the police, true?
A. After talking to the police, Janet called me back and I told the police officer to call me
back.
Q. Okay. And a police officer called you back, correct?
A. He did.
Q. You told the police officer in that conversation that Janet didnt think a 9-1-1 call was
needed, true?
A. I did not tell him that.
Q. Would it refresh your recollection if I show you a copy of the police report?
A. Ive seen the police report.
Q. Youre aware of what the police officer says you said, correct?
A. I am.
Q. And youre saying you never told the police officer, Ventura does not think a 9-1-1 call
is needed at this time?
A. I told the police officer that Janet said she was going to be leaving the property in a
vehicle at twelve oclock, and that could the police intercept the vehicle. And his response
was, is, We cannot intercept a vehicle.
Q. Do you remember telling the police officer in that second conversation, Jackson said
he did not think Ventura was in any danger?
A. No, sir, I dont.
Q. Would it refresh your recollection if I show you the police report?
A. Ive seen -- Ive seen the police report.
Q. Youve seen the words he wrote about what you told him?
A. Yes, sir.
Q. So you know the police officer claims you said, Ventura is not in any danger, correct?
A. Correct.
Q. And youre denying saying that, true?
A. Im denying saying that.
Q. Okay. Now, you told the jury at one point Janet left the property, correct?
A. Please repeat the question.
Q. Yes. At one point, after your call to the police, Janet left the property, right?
A. That is correct.
Q. And when was that?
A. She called me early in the morning, so it was sometime that night.
Q. Okay. And is that the night of the day you made the phone call?
A. I mad e the phone call late at night, so it was early that morning.
Q. And -- okay. So early that morning, she left Neverland?
A. She left Neverland.
Q. And how did she leave Neverland; do you know?
A. I dont know for sure. I know she went to El Monte.

Q. And you also learned that shortly after that, she went back to Neverland, right?
A. After that she came back to my apartment.
Q. And did she then go back to Neverland again?
A. She received a bunch of phone calls from Frank.
Q. Please answer my question, Major.
A. Yes, sir, she did go back to Neverland.
Q. Okay. And approximately when d id she go back to Neverland again?
A. It was probably a couple of days. I dont
24 have a specific -- it was probably two days.
Q. Okay. So you call the police. They dont do anything?
A. Correct.
Q. You deny what they claim you said to them, that she wasnt in danger, correct?MR.
ZONEN: Objection. Argumentative and asked and answered. THE COURT: Sustained;
asked and answered.
Q. BY MR. MESEREAU: She leaves the next day from Neverland, right?
A. She leaves in the middle of the night.
Q. Okay. And goes to El Monte?
A. Correct.
Q. And then to your place, right?
A. Not that day, the next day.
Q. And then goes back to Neverland, right?
A. Bunch of phone calls, and she -Q. Goes back?
A. Goes back to Neverland.
Q. And then when does she leave Neverland again, to your knowledge?
A. She leaves Neverland that same day, same night. She comes back late at night, by
herself.
Q. And does she ever go back to Neverland again?
A. After some phone calls, about every 15 minutes getting phone calls from Frank -Q. Im just asking you the question, Major, did she ever go back to Neverland again?
A. Yes, sir, she did.
Q. After your calls to the police, she leaves Neverland and goes back three times; is that
correct?
A. She left Neverland -- Id have to count it up.
Q. Sound like three times to you? MR. ZONEN: Objection. Asked and answered;
argumentative. THE COURT: Overruled. You may answer. T HE WITNESS: Okay. I believe
it was two times. One time she returned with her family. The same night she showed back
up, and then she returned again to Neverland.
Q. BY MR. MESEREAU: How many times after your call to the police do you believe Janet
left Neverland?
A. The night that she -- that I made the phone call to the police, she left that night. Came
back to my apartment. Went back to Neverland, and came back again that night, so there
was two times.
Q. Did she ever go back a third time, to your knowledge?
A. She did go back.
Q. So then she then left a third time?
A. Youre giving me the numbers here. Lets see. She -- she came back, she left
Neverland, went to El Monte. All right. So thats leaving Neverland once.

Q. Right.
A. She came to my apartment.
Q. Right.
A. Lots of phone calls. Went back to Neverland. Came b ack that night. Okay. Again, bunch
of phone calls, and she returned back to Neverland. So that would be three times, yes.
Q. Okay. And every t ime she left Neverland, how was she transported? Do you have any
idea?
A. How she left Neverland?
Q. Yes.
A. I dont have any idea, no, sir.
Q. Do you know who drove her every time she left Neverland?
A. I think I learned this after the fact, but I think Chris Carter brought her to my
apartment when she came by herself.
Q. Every time she left Neverland someone employed by Mr. Jackson drove her, correct?
A. I -- Im not clear on that, but I think thats probably true. MR. ZONEN: Objection;
speculative. MR. MESEREAU: Okay. No further questions. MR. ZONEN: Id ask to reopen
on an area that is beyond the scope of the redirect examination,very briefly. T HE COURT:
All right.
FURTHER REDIRECT EXAMINATION BY MR. ZONEN:
Q. Major Jackson, following Janets return to your home on the final occasion -A. Yes, sir.
Q. -- in March at this point, were you witness to any contacts from anybody by the name
of Johnny?
A. Johnny, yes, sir, I was.
Q. All right. And who do you understand Johnny to be?
A. Johnny was supposedly either a security detail for Michael Jackson or somebody -somebody that worked for Michael Jackson.
Q. And where did you see him?
A. I saw him on several occasions.
Q. And where was the first one?
A. The first time, I believe, is once the family returned back to my apartment on St.
Andrews Place, Johnny apparently was showing up at the apartment and banging on the
door, and the family was scared. She -- Janet called me at work. And I rushed home, and
I got into the apartment and -- I mean, the kids were holding knives. They were scared to
death. And then all of a sudden we get a knock on the door and I opened the door, its
Johnny. So I slammed the door behind us, because I was concerned what he may do. And
him and I were standing right nose to nose looking at each other, and Im like, What do
you want? And he said, I just want to know how the children are. I said,Well, the
children are fine. Get off the property.So he kind of looked at me and just walked away,
so he left that day.
Q. Whens the next time you saw him?
A. Again, my wife called me from -- at work, and at that time I guess she was my
girlfriend, and said, Johnny is back.So I came back home. Came home again, and this
was early evening. It was dusk. I pulled into the -- into the carport, and the -- and the
garage door closes. Its like a chain-link fence. And I look out, and across the street is this
guy trying to hide behind a car. And from a distance, it looks like Johnny. So of course --

MR. MESEREAU: Objection. Nonresponsive and narrative. THE COURT: Narrative;

sustained.
Q. BY MR. ZONEN: Did you go out to look at the person behind the car?
A. Yes, sir, I did. I walked out towards him and he immediately took off.
Q. Were you able to see him?
A. He had the same makeup and build of Johnny, but I cannot say for a fact it was
Johnny.
Q. Did you see what kind of car he was driving?
A. No, sir, I did not. He ran behind a building and took off.
Q. When was the next time you saw him?
A. The next time was, Janet was concerned about the children going back to school
because the Jackson folks had her passports for the children. So she did not want -- let
me back up. She went to the school. She was scared the children would be taken. MR.
MESEREAU: Objection. Objection; move to strike. THE COURT: Stricken.
Q. BY MR. ZONEN: Tell us the next time you saw Johnny.
A. I saw Johnny at John Burroughs Middle School.
Q. About how long was this after Janet and the children returned to your home?
A. Two or three days.
Q. Where did you see him at the school?
A. I pulled in with Janet, we parked. I walked up to the breezeway where the children
come out, because we didnt want them to be snatched, and - MR. MESEREAU: Objection.
Move to strike; nonresponsive. THE COURT: Sustained. The last parts stricken.
Q. BY MR. ZONEN: You walked up to the breezeway. What did you see?
A. Okay. I was standing there wait ing for the children. Janet came running up to me and
she said, Johnny is here. So I immed iately ran out back to the car, grabbed a camera
out of the car, because I wanted to get some kind of documentation that this guy was
stalking this family. And I ran up to his car, and he was in an old 280Z or 280ZX. And I
was -- I was kind of -- my adrenaline was flowing, so I didnt turn the camera on, but I
ran up to him and I acted like I was taking pictures of him. And, you know, John
Burroughs, its a very tight situation there. Once you get in, you can hardly get out, and
so hes slinging the gears back and forth, trying to get away, but he cant get out, because
its all blocked up. So I continued to take pictures of him, then I ran back over to the
school, and I saw one of the counselors by the name of Mr. Davies. And I said, Mr.
Davies, there is a guy out here who is stalking Gavin and Star. And I dont know whether
he saw that guy or not.
MR. MESEREAU: Objection. Nonresponsive; narrative. THE COURT: As to the last
sentence, Ill strike it. THE W ITNESS: Okay. So --THE COURT: Ask the next question. MR.
ZONEN: Yes.
Q. Did you point out Johnny to Mr. Davies?
A. Yes, sir, I did.
Q. Were you actually in a position where you could see Johnny at that time?
A. Let me back up. I d id not point him out. I said, There is a guy out in the parking lot
driving a 280Z that is stalking the children.
Q. Okay. Did you give him a description of that vehicle?
A. Yes, I did.
Q. Okay. Including the color of the vehicle?
A. And -- Im sure I did. I cant remember now in my mind. And maybe it was a d irty gray
or blue, but thats speculation at this point. I dont remember the color.

Q. Did you give him a description of Johnny at all?

A. Yes, sir, I did.
Q. All right. Did you see Johnny again thereafter?
A. I dont think I saw Johnny again.
Q. Were you or Janet Arvizo receiving phone calls during that period of time after the kids
finally and ultimately returned home? MR. MESEREAU: Objection; leading. THE COURT:
Overruled. You may answer. THE W ITNESS: I know Janet was receiving some phone
calls.
Q. BY MR. ZONEN: All right. At which residence?
A. At the St. Andrews apartment.
Q. That was your residence at the time?
A. Thats correct, sir.
Q. Were you answering any of those calls?
A. No, sir, I was not.MR. ZONEN: Your Honor, if I could approach the witness. THE
COURT: All right.
Q. BY MR. ZONEN: Id like to show you Exhibit No. 26 for identification not yet in
evid ence. Can you tell us who this person is?
A. That looks like Johnny.
Q. Do you know his last name?
A. I dont.
Q. How do you know his first name is Johnny?
A. Janet and the children said theres this guy, Thats Johnny out there.
Q. Is that, in fact, him?
A. That is.
Q. Does that photograph accurately depict the subject matter contained -- in other words,
is this an accurate, although not terribly complimentary, photo of Johnny?
A. Yes. MR. ZONEN: Move 26 into evidence, please. MR. MESEREAU: No objection. THE
COURT: Its admitted. MR. ZONEN: I have no further questions.THE COURT: Mr.
Mesereau? MR. MESEREAU: Yes, thank you, Your Honor.
FURTHER RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Mr. Jackson, at some point you learned that Johnny was an investigator hired by
Attorney Mark Geragos to see if your family and a bunch of lawyers were trying to extort
Michael Jackson, true?
A. That would be incorrect.
Q. You never called the police on Johnny, true?
A. No, sir, I did not.
Q. And how many times do you think youve seen Johnny?
A. I have probably seen Johnny three times.
Q. When was the first time?
A. The first time would have been the night that he showed up at the apartment and I
confronted him out in front of my apartment door.
Q. Okay. And then you say he took off?
A. He just walked away.
Q. Okay. MR. MESEREAU: No further questions. THE WITNESS: Thank you. MR. ZONEN:
Your Honor, could I publish that photograph, No. 26? THE COURT: Yes. THE BAILIFF:
Input 4, please.

Q. BY MR. ZONEN: If you could turn around and look behind you. Is that, in fact, Exhibit
No. 26, the person you identified as Johnny?
A. Yes, sir. MR. ZONEN: Thank you. No further questions. MR. MESEREAU: No further
questions, Your Honor. THE COURT: You may step down.

JANET ARVIZO EXAMINATION

DIRECT EXAMINATION BY MR. ZONEN:

Q. Mrs. Jackson, are you formerly known as Janet Ventura and then Janet Arvizo?
A. Yes, sir.
Q. And you currently go by Mrs. Jackson?
A. Yes.
Q. And you are married to Jay Jackson?
A. Yes.
Q. Based on advice of counsel, have you advised the District Attorneys Office that you will
be asserting the Fifth Amendment privilege as to any question asked of you about welfare
recipience or applicat ions for welfare during the period of time that you were on welfare?
A. Yes.
Q. Up until the time that you discontinued welfare?
A. Yes. MR. ZONEN: No further questions. THE COURT: Have you consulted an attorney
regarding your claim of privilege here? THE W ITNESS: Yes, sir. THE COURT: Is your
attorney going to be here
today? THE WITNESS: No, sir. THE COURT: Did you discuss the claim of privilege at
length with him? THE W ITNESS: Yes, sir. THE COURT: Do you believe you have sufficient
knowledge to make the claim? THE WITNESS: Yes, sir. THE COURT: Do you feel you need
any other legal advice concerning your claim of privilege?THE W ITNESS: Pardon me? THE
COURT: Do you need any other legal advice? THE W ITNESS: No. THE COURT: Whats the
District Attorneys intention as to how to deal with this? MR. ZONEN: Your Honor, my
understanding is that this witness will answer all questions put to her other than questions
of her welfare application, questions that she answered in her welfare app licat ion or in
receipt of welfare benefits. We intend on proceeding with our direct examination. Were
not going to ask her any questions about welfare recipience. And Im assuming that the
assertion of the Fifth will be done at this time. And I dont believe that -- well, our position
is stated thereafter in our plead ings. THE COURT: All right. Do you, in fact, make a claim
under the Fifth Amendment of the United States Constitution against self-incrimination?
THE WITNESS: Yes, sir. THE COURT: And to what areas do you relate that claim, are you
making that claim? THE WITNESS: To what he said. THE COURT: Id like to hear it from
you.THE WITNESS: Of everything to do with the welfare; the application, the process. THE

COURT: During what time period? THE W ITNESS: The period of when I began till I ended.
THE COURT: But when was that? THE WITNESS: Oh, Im sorry. That was approximately
October -- approximately October 2001 to November 2000 -- no, apologize. March 2003.
THE COURT: So the claim would involve -- the claim of privilege would invo lve claims
made between October of 2001 and March -- through March of 2003? THE WITNESS: Yes,
sir. THE COURT: Has the District Attorney considered giving this witness immun ity on that
issue? MR. ZONEN: We have -- were not terribly interested in giving a grant of immunity.
THE COURT: All right. We have -- points and authorities have been filed. And my thought
is theres no reason for you to ask her any questions. But if you think there is, tell me
why. MR. SANGER: I dont believe -- Mr. Mesereau will be hand ling the witness, but Im
handling this legal issue, if we can b ifurcate that, Your Honor. As far as the questions right
now, I dont think theres any point in asking additional questions. The factual issue is set
out. THE COURT: All right. What Im going to ask you to do is to step down from the
witness stand, and just sit behind counsel while we have argument on this issue. THE
WITNESS: Thank you. MR. ZONEN: Your Honor, before we proceed, the Court will note
that Detective Victor Alvarez is currently in court. As the Court knows, Steve Robel is out
on -- Sergeant Robel is out on family emergency for the week. And weve asked the
Courts indulgence to allow us to have a separate investigator here during the balance of
the week.And I believe the Court has said we could do that subject to the consent of the
defense, and theyve agreed. MR. MESEREAU: W e dont object to that. MR. SANGER: We
didnt object to that. But we did talk to Mr. Zonen about this, and we do have two
investigators, one in Los Angeles, and one up here. Neither one is going to be here
routinely, but we had asked their consent to allow those two investigators to -- either one
to come in just one at a time. Mr. Zonen would not object to that, if thats all right with
the Court. THE COURT: All right. Your agreement is fine with me. MR. SANGER: Thank
you, Your Honor. THE COURT: Maybe -- knowing you, its not likely youre going to
complete your argument in two minutes, is it? (Laughter.) MR. SANGER: Not with that
kind of encouragement, Your Honor. (Laughter.) THE COURT: Lets take our break. And
then well have our argument.(Recess taken.)
(The following proceedings were held in open court outside the presence and hearing of
THE COURT: Mr. Sanger? MR. SANGER: Yes, sir. I think the best place to look
for the organization, such as it is, of our argument is in our supplemental brief that we
filed yesterday that goes through the analys is, really, of the remedies, because thats the
problem that we have. The first -- the first issue, I think, is pretty clear, but a witness
cannot take the Fifth on a material issue and have their testimony considered by the jury.
I think the law is very clear on that. So if the People call someone and they say, We want
to get out A, B and C, and then after we get that information out, the defense is not
going to be allowed to confront and cross-examine on D, E and F, the entire testimony
would be stricken. Quite often this comes up when the witness takes the stand, testifies,
and in the middle of cross-examination wants to take the Fifth, and the Court at that time
has no choice but to strike the entire testimony, because you cant allow a witness to pick
and choose what he or she is going to be subject to on cross-examination. If thats the
case, then obviously the remedy at this point is to not allow the witness to be called at all.
The question of materiality, which we briefly -- Ill address a little more fully just because,
obviously, we didnt have a lot of time to file things on either side, obviously, the welfare
applications in this case are extensive, and they cover in detail the particular issues that
relate to things that have come out through Major Jacksons testimony and pertain to the
precise time period that were talking about here, the time period during which Miss Arvizo

and her children were importuning Mr. Jackson to assist them through 2000 and 2001, on
into 2002, and of course during the critical periods in 2003, from early February to mid
March. During this period of time, Miss Arvizo was not only accepting welfare, food
stamps, disability unemployment, but she was also making applications to the Family Law
Court. In her extensive statement under oath and specific questions under oath, she in
essence denies that she has any bank accounts, whereas we know she had bank accounts
as a result of a substantial settlement from J.C. Penneys; that she has any money, and
for the same reason, thats false; that shes received any money from anyone, and we
know thats false from other testimony we have so far; that she is living with anyone, and
we know thats false, based on the testimony of Major Jackson that shes receiving any
assistance in that regard; that she has a vehicle to drive, whether or not she owns it. And
there are extensive questions that are answered in a way that is clear that it is perjury,
and that is a felony. It is also fraud. And as a matter of constitutional right, a defendant is
allowed to confront and cross-examine and is entit led to confront and cross-examine a
witness who seeks to testify against him. This witness seeks to make all sorts of
alleg ations, as we understand it, against Mr. Jackson. He has a right, through his counsel,
to vigorously cross-examine this witness and show that she has committed acts of perjury
and acts of fraud, to show that she is not credible, number one. And number two, to show
she is doing this during the very same period that she is making alleg ations in this case
against Mr. Jackson. In addit ion to that, there are a number of very specific factual t ie-ins
beyond the fraud and the perjury and the credibility. There are factual t ie-ins that we
would not be allowed to explore, were the District Attorney to get his wish and allow her
to just testify unscathed. Factual tie-ins include allegations that she could not -- that she
was imprisoned somehow, and at the same time she is making app lications, she is
receiving welfare checks. Shes able to deposit them. She is able to fax a letter telling the
welfare depart ment that she no longer wishes to receive welfare, which we maintain is
tied to her belief that she is going to be making money and having security based on what
shes trying to establish with Mr. Jackson. All of those things, were the District Attorney to
get their wish, would be excluded and we would not be allowed to confront and crossexamine her on these inconsistent acts that are inconsistent with her allegations. We also
have some acts, such as the paying of rent on the Soto Street apartment, and the Court
has alread y heard Major Jacksons somewhat, Id say, incredible, but, I mean, certainly it
didnt make sense to me, remarks about needing to have the two residences. Additional
informat ion comes out about that and will come out that, in fact, she got Brad Miller to
pay her rent, she got Jay Jackson to pay her rent, and she got the Trujillos, who own the
place, to forgive her rent, based on her claims that she was not able to afford the rent
because of Gavins illness. So those acts of multip le fraud with regard to that location
presumably would come within this same ambit, at least portions of it. Even if were
allowed to ask part of that, a good portion of that cross-examination would be precluded.
Having said that, and without belaboring that any further, unless the Court has questions,
thats the materiality. Theres just no question these are material issues, particularly in a
criminal case where you have a constitutional right to confront and cross-examine. THE
COURT: But you wouldnt be precluded from proving those items through other
witnesses.You would only be precluded from asking her those questions that relate to the
welfare fraud. MR. SANGER: Right. And weve addressed that issue briefly --THE COURT: I
know. MR. SANGER: -- in here. And the answer to that, I think, is that, you know, the
right to confront and cross-examine is extremely important because of a variety of things.
Number one, it comes at this stage of the proceedings. If the prosecutions position were

adopted, and we were not allowed to inquire, and the jury is not allowed to know about
any of this, they would see a witness get up there, be relatively unscathed as to a major
part of the -- of the issue with regard to her credibility and as to major issues with regard
to activit ies that she engaged in during this period of time. We would then be denied the
right to confront and cross-examine. Theres a great quote that we presented to the Court
to the effect that thats a very effect ive part of the process, the legal process in general,
and it is a constitutional part of the criminal legal process to vigorously cross-examine.
That is one of the aspects of our system that helps us try to obtain the truth and get to
the bottom of things. If we were not allowed to do that, timing-wise, we would not be able
to even present this until after the People rested. So, we would be in a position where this
jury is going to hear this, they would not be allowed to hear anything to the contrary, she
would leave the stand unscathed, and then eventually, through laboriously presenting
custodians of records and presenting other evidence from other sources, we would
eventually build the case that we have to show that she, in fact, committed welfare fraud.
It comes, you know, certainly a day late or a month or two months or three months late in
the proceedings. And I believe constitutionally, were deprived of that very important
right, and thats why that right exists. We dont have to wait until two or three months
later to put on evidence incrementally. Were allowed to confront her right off the bat and
say, Isnt it a fact that this happened? Now, in addition to that, Mr. Sneddon, in his
opening statement, got up and told the Court, and told the jury, that she was going to
take responsibility for her welfare fraud, and that it wasnt that big a deal anyway, but she
would take responsibility. Shes done things that were wrong or that she was not proud of,
But, you know, lad ies and gentlemen, dont worry about that, because shes going to
take responsibility and tell you honestly what happened here.Well, if the People were to
get their way, the prosecution was going to get its way in this case, she would not do
that, and that would not happen. Whats more harmful to our situation, from the -- from
Mr. Jacksons standpoint, is that based on those statements made by the prosecution in
opening, Mr. Mesereau, on behalf of the defense and Mr. Jackson, got up and made a
substantial statement, a series of statements in his opening statement to the effect that
we were going to prove X, Y and Z, and that is going to be now swept under the rug, as it
were, if the prosecution were to get its way, until such time as we could then present this
incrementally during the defense. So it would be extremely prejudicial and it would -- it
would be a denial of confrontation. So that is why I believe that we get past that point. I
believe that based on the case law and the Constitution, we just cant carve out safe
harbors for a witness and allow that witness to testify to what the prosecution wants and
not testify to other relevant matters, some of which have already started to come in
through Mr. Jackson, or Major Jackson. Now, that takes us to the next point: What does
the Court do? And I think that the only remedy at this point is to strike her -- or not strike
her testimony, but to disallow it. You cant have a half cross-examined witness in a
criminal case. If the Court does that, we then get to the next problem, which is what do
we do with this trial as it stands now? And weve suggested that the only remedy is to
declare a mistrial, because the prosecution has said they were going to present this. We
have spent a good deal of time in opening focusing on Janet Arvizo as a witness and her
lack of credibility. She is also the kingpin of what they claim was going to be their case for
conspiracy. She is the basis for a lot of what they are claiming will be t ied up later to
establish co-conspirators for the purpose of all the conditional admissions of testimony
that the Court has allowed. Can we unring this bell if she doesnt testify? Even were the
Court to grant an 1118.1 motion at the end of the prosecutions case on conspiracy, it

would contaminate the entire trial. So I think that the remedy, if the Court excludes her
testimony, which it has to do, is to then grant a mistrial. Now, the reason I raise that at
this point is that we have suggested that if the Court were going to deny a mistrial -- this
is convoluted, but I think we have to go full circle and come back. If the Court were to
deny a mistrial, there might be a way to handle this. Were not prepared to concede that
its going to do the trick and that its constitutionally adequate. But if the Court were to
deny a mistrial, one way to handle this would be to allow the witness to testify and to take
the Fifth in front of the jury. Now, its not for the purpose of embarrassing Miss Arvizo. But
more importantly, she is not a stakeholder. She has no stake in whether or not the jury
hears that shes taking the Fifth. If she were a lit igant in the case and a stakeholder in the
case itself, the Court might say, Well, thats unfair, in the context of requiring her to
either take the Fifth or, as in the Pacers case, for instance, lose the ability to litigate a civil
case. Under -- the Courts familiar with Pacers. I mean, the balancing was, you cant make
somebody lose their civil case or choose to waive their Fifth Amendment right to win it.
But thats where the person who was facing that issue is a stakeholder in the lit igation.
Miss Arvizo is not a stakeholder in this litigat ion. Therefore, asserting the Fifth, as shes
just done in public, in front of the world, is no different than asserting the Fifth in front of
the jury, for her. It does not affect her. She is not a stakeholder in the litigation. What it
does is some sort of rough justice which would allow the jury to understand that the
promises made by Mr. Mesereau at the time of his opening statement are promises that
we intend to keep. And that while we are not permitted to go into this now, because shes
asserting the Fifth, we -- it is a clear message to the jury that this is an issue thats still
alive, and to keep an open mind, and we will be presenting evidence at a later time. There
was, of course -- and I dont want to comment on the content of stipulations, but I
understand that Mr. Mesereau indicated that there might be some way to stipulate around
this. And I just throw that out, not -- were not trying to force the prosecution to stipulate.
But just as a possible remedy, another remedy would be to enter into some kind of a
stipulation, if the prosecution were willing to do it. Absent those remedies, it seems that
following the law and looking at the Constitution on confrontation, the only choice that the
Court has to -- the only choice the Court can make at this point is to exclude her entire
testimony, and then the chips fall where they may, either a motion for a mistrial is made,
and granted or denied, and then we go on to the next step. The reason I address the
motion for mistrial issue is because I think its only fair to look at the horizon and see
what happens, which might prompt everybody to resolve this some other way, whether
its by the Courts order or by stipulation. Unless the Court has questions, Ill respond to
the prosecution. THE COURT: All right. Mr. Zonen? MR. ZONEN: Your Honor, weve very
thoroughly briefed this issue and Im going to be very brief in my argument. Theres
nothing that theyre seeking to do in the course of this trial for purposes of impeaching
her testimony by way of bringing in this information that they cannot do even in the
absence of Miss Arvizo or Mrs. Jackson testifying to these matters. They have all the
documentation necessary to be able to present the information that Mr. Mesereau said in
his opening statement that they would be presenting, and all of this information can be
adequately presented to the jury and in a very thorough way. She has a right,
constitutional right, not to answer questions that would incriminate her. To a large extent,
to some extent certainly, this is a problem of their own creation. Prior to the
commencement of this trial, the defendant hired an attorney to present to the Los Angeles
District Attorneys Office a compilat ion of material, along with a demand letter that she
immed iately be prosecuted for this matter. So the fact that shes now asserting the Fifth is

certainly -- and theyre denying that they did it, even though we have now shown that
that same lawyer has filed writs to the California State Supreme Court on behalf of
defendant as well. Its certainly a right that she has to assert the Fifth as to any question
that could tend to incriminate her. Theres little question but that issues dealing with this
matter could tend to incriminate her. Certainly the matter is currently before the Los
Angeles District Attorneys Office. She has a right to do that. She has a right to do that
outside the presence of the jury. The only reason that it would be done in front of the jury
would be to prejudice her in her assertion of a constitutional right, and case law clearly
states that that is not to be done. This is a collateral matter entirely, has nothing to do
with any activity that took place in Neverland, has nothing to do with any activity that
took place at any other location involving the defendant, such as Miami. It has all to do
entirely with credibility issues. And to that extent, since it is entirely with credibility issues,
it is out of the gamut of any of those cases that talk in terms of court-imposed immunity.
And finally, the issue of a mistrial should be, of course, denied. There is no issue that
cannot be presented to this jury in some other fashion. And so that would not be an
appropriate remedy. W ell submit it on our plead ings. MR. SANGER: May I respond,
briefly? THE COURT: Let me ask him a question first. MR. SANGER: Mr. Zonen or myself?
THE COURT: Mr. Zonen. MR. SANGER: Okay. THE COURT: The one issue is, if I deny the
defendants request to prevent her from testifying, should she be required to claim the
privilege in front of the jury? MR. ZONEN: I believe theres adequate cases that say that is
not an obligation for a witness. And the motive in this case purely is for the jury to be able
to surmise some negative connotation to asserting a constitutional protection. And I think
that the case law is pretty clear that that is just not the implication that theyre supposed
to be given from the assertion of a constitutional right. THE COURT: All right. Mr. Sanger?
MR. SANGER: I was going to respond to that precise remark that Mr. Zonen made, and
therefore to the Courts question, which is Mr. Zonen said its -- she has a right to assert
the Fifth Amendment. Theres absolutely no question about that. We all believe in the Fifth
Amendment. And thats the law of this country.She does not have a right not to assert it
in front of the jury. That is not her right. That is a judicially created rule that is not hard
and fast, but it was created to not allow unfairness in front of the jury. It has nothing to
do with the witness, again, unless the witness is a stakeholder, which shes not. That
would come under the Pacers kind of analysis. So she does not have a right not to say it
in front of the jury. She said it in front of the entire world here on the stand. So the
question is, can the Court fashion a remedy that may work? And we believe that that is at
least a possibility, depending on how the Court does it. You know, were not in a position
to concede it. And the only other thing Id say, quickly,is that with regard to this being
reported to the L.A. D.A., it was reported to the L.A. D.A. by somebody whos not a
member of this particular defense team, and thats what we said. W e didnt mean to imply
anything else. However, Mr. Sneddon got up and said it was a crime. Certainly people are
prosecuted for much less in Santa Barbara than what this person has done by way of
welfare fraud, and its reasonable for anybody to report it if they want to. I think thats a
red herring. The real issue comes down to what is the Court going to do about it? Just
exclude her testimony entirely? W hich leaves us with a can of worms and possibly a
mistrial. Or can we find some other way around it? And thats where we are. And I submit
it to the Court for a decision. THE COURT: Thank you, Counsel. Neither of you cited People
vs. Hecker, 219 Cal.App.3d 1238, which is a 1990 case, where an appellate court
reviewed a striking of testimony where a witness claimed the Fifth Amendment and
indicated that that was, you know, too drastic of a solution for the problem. The appellate

court in that case observed that it might have been appropriate for the Court to have
permitted the witness to testify, allow the jury to draw negative inferences from his
invocation of the Fifth Amendment. And I think the instructions in the Hecker case are
powerful instructions to this Court. Therefore, the Court will deny the defense motion to
prevent her from testifying, which also leads us to the -- takes us right on past the motion
for a mistrial, which is denied also. The next question becomes should she be required to
claim the Fifth Amendment in front of the jury, and I have a suggestion here. Id like one
member of each team to come forward and pick up my suggested jury instruction, and
what -- the total intent of this instruction is to advise the jury of the problem that has
arisen in this case because of the assertion of the Fifth Amendment. So looking at the
suggested instruction on top -- and youll notice theres two instructions. Immediately
behind that is CALJIC 2.25, which what I would intend to do is blend these instructions, so
-- MR. SANGER: Your Honor, your intention would be to read this instruction before she
testifies? THE COURT: Right. MR. SANGER: Okay. THE COURT: What I would intend to do,
if you will follow me and follow along, and well read it right now out loud, because Im
going to interject CALJIC 2.25 in here, so I would tell the jury, In a hearing held outside
your presence, the Court has determined that the Rules of Evidence preclude the parties
in this case from examination or cross-examination of Janet Arvizo on the subject of
possible welfare fraud.Then I would interject 2.25, When a witness refuses to testify in
any matter relying on their constitutional privilege against self-incrimination, you must not
draw from the exercise of this privileg e any inference as to the believability of the witness
or any other matter at issue in this trial. Then going back to this instruction, This is a
ruling that was not anticipated when the attorneys made their opening statements to you.
Those statements, however, are not evidence. You should not consider the failure of the
prosecution or the defense to cover this subject area in the examination or crossexamination of this witness as having any evident iary significance or any importance in
your ultimate decision on the case, nor should you speculate as to the possible reasons for
the Courts decision. Evid ence of possible welfare fraud may still at some point be
presented in this case, but it will not be introduced through the testimony of this witness
So thats what I would propose. So, in essence, Im not -- shes not required to make the
claim in front of the jury, but I tell the jury that shes made that claim, and the same
effect, and I explain to them why. And, you know, I have a deep concern that both sides,
but primarily -- well, I shouldnt say primarily. Be careful how I say this. But both sides
were relying on the fact that evidence of possible welfare fraud was going to come in and
both made pretty strong statements in their opening statement about it, and I dont want
to gloss over that with the jury. I think it needs to be brought to their attention so that -and heres where I feel the more strong side is, so the defense -- so theyre not wondering
why the defense isnt producing the evidence that Mr. Mesereau stated he would produce
in his opening statement. So thats my proposal. MR. SANGER: Could I be heard on just a
couple of technical issues? THE COURT: Yes. MR. SANGER: I dont know how technical
they are, but --THE COURT: Probably pretty technical. MR. SANGER: Well, its actually
fairly substantial in one sense. But the proposed instruction says possible welfare fraud,
and the other thing that we specifically talked about was perjury. And wed ask the Court
to add perjury to -- welfare fraud and perjury. Theres probably other things, but at
the very least that covers the broad areas. The other suggestion that I would have is that
the Court -- that the first sentence in the suggested instruction - and weve had all of a
minute and a half to consider this, okay? - but the first sentence that the Court suggests
before reading the refusal of a witness to testify doesnt really indicate that the witness

has refused to testify. It says, The Courts determined that evidence -- the rules of
evid ence preclude the parties....Now, understanding that our prior motions were denied,
and so this is without conceding that, we would ask that the Court indicate that the
witness has refused to answer certain questions and the Court has granted the witness
that privilege. And then that moves into your 2.25, which explains what the refusal and
the privilege is, and that the actual exercise of the privilege cannot be considered. And the
reason I suggest that is that otherwise - well, I understand what the Court was doing with
this - otherwise, it appears -- it may appear to the jury that theyre not to consider whole
area for some reason, and what youre really saying is they cant consider the refusal and
theassertion of a privilege. COURT: Right. MR. SANGER: Id just ask that that be clarified
in that first sentence. Thank you. COURT: Did you want to say anything in response?
ZONEN: I have no objection to the inclusion of the word perjury, but -- I have no
objection to the inclusion of the word perjury, but as to the balance of it, I think the
content of the instruction as drafted is adequate. COURT: Okay. I think this is how I would
like to do it. I think it solves the problem not exactly the way you wanted me to, but
taking the suggested instruction paragraph starting with In a hearing..., Im going to
add a sentence before that sentence. So the first sentence would read: The witness,
Janet Arvizo, has made a claim of privilege under the Fifth Amendment of the United
States Constitution. Then I go into, In a hearing held outside your presence, the Court
has determined that the rules of evidence preclude the parties.... And then the next
sentence is, When a witness refuses to testify to any matter relying on a constitutional
privilege..., so it all comes together there. Okay? MR. ZONEN: Yes. MR. MESEREAU: Your
Honor? THE COURT: Yes, sir. MR. MESEREAU: I would be cross-examining the witness,
and could I just ask a question? If the prosecution tries to -COURT: They cant hear you in
the back. MR. MESEREAU: Sure. Ill go up there.Your Honor, Ill be cross-examining the
witness, and I suspect the prosecution is going to try to ask questions to create the
impression that shes never asked anybody for money, which we can prove is not true.
The -- that raises the question of, if they open that door, if they try and create that
impression, the question then becomes what can we do to counteract it through proper
use of cross-examination? Theyve already suggested in their calling other witnesses that
this woman is pristine pure and its all her husband who was only asking for money.
ZONEN: Judge, weve gone beyond the argument in this matter. And Im going to object
to the use of dual counsel as to this motion as well. THE COURT: I think thats good. I
think well just deal with that -- MR. MESEREAU: Okay. COURT: -- when we get to it. MR.
MESEREAU: If we could have the opportunity to approach sidebar, if necessary, on that, I
would ask the Courts indulgence in that regard. Because I think an issue might come up
and we do have to defend our client, Mr. Jackson, vigorously and professionally, and it
does raise a thorny issue. COURT: Ill deal with that as it comes up. MR. MESEREAU:
Okay. Thank you, Your Honor. COURT: In a sense, what Mr. Mesereau was saying is that,
you know, the claim of privilege is bind ing on everybody, and the prosecution as well as
the defense have to stay away from those areas that would cause her to have to make
continual claims in front of the jury. Thats what this is about. Both sides are restricted in
their questioning to areas outside of the alleged welfare fraud and resultant possible
perjury. And thats how I take your remarks, Mr. Mesereau. If they dont respect those
lines, then what do you do? And well deal with that as it arises. All right. What were
going to do is were not going to recess. Im going to step off to bench. Well have the jury
brought in immediately, and then well start. I dont want the witness in the witness stand,
because Im going to instruct the jury from the witness chair. The witness has already

been sworn. Ill advise the jury of that. Since she is now known as Mrs. Jackson, are we
going to refer to her mainly, for the most part, as Mrs. Arvizo for the purposes of the
examination, or -- ZONEN: Shes requesting that I address her as Mrs. Jackson. COURT:
Well, thats fine. I d idnt ask you what she wanted. (Laughter.) COURT: I said, are we
going to address her as Miss Arvizo, Mrs. Arvizo? MR. MESEREAU: We would request
that, Your Honor. THE COURT: The reason being, theres so many documents, tapes and
things, and Im concerned about the confusion to the jury of the names. Thats all.
ZONEN: Whatever is the Courts direction. COURT: Ill allow you to address the issue with
the witness in front of the jury, so that they understand that Im not going to require that
people address her as Mrs. Jackson in the trial,because I dont want to have that
problem of confusion over names. All right? ZONEN: Okay. MR. MESEREAU: Thank you,
Your Honor. COURT: Bring in the jury.
(The following proceedings were held in open court in the presence and hearing
COURT: (To the jury) Here I am again. (Laughter.) COURT: Im going to
read you again some instructions, and remind you that at the end of the case, I will fully
instruct you on all of the law involved in the case, but Im instructing you at this time to
specifically deal with a specific problem thats arisen in the evidence of the case. So Id
like you to listen carefully to this. The witness, Janet Arvizo, has made a claim of privilege
under the Fifth Amendment of the United States Constitution. In a hearing held outside
your presence, the Court has determined that the rules of evidence preclude the parties in
this case from examination or cross-examination of Janet Arvizo on the subject of possible
welfare fraud. W hen a witness refuses to testify to any matter relying on the constitutional
privilege against self-incrimination, you must the exercise of this privilege any inference
as to the believability of the witness or any other matter at issue in this trial. This is a
ruling that was not anticipated when the attorneys made their opening statements to you.
Those statements, however, are not evidence. You should not consider the failure of the
prosecution or the defense to cover this subject area in the examination or crossexamination of this witness as having any evident iary significance or any importance in
your ultimate decision on the case, nor should you speculate as to the possible reasons for
the Courts decision. Evidence of possible welfare fraud and perjury may still at some point
be presented in this case, but it will not be introduced through the testimony of this
witness. You may call your witness to the stand. MR. ZONEN: W ell call Janet Arvizo
Jacksonto the stand, please.
DIRECT EXAMINATION BY MR. ZONEN:
Q. The name that youre currently going by is what name, please?
A. Janet Jackson.
Q. And you were previously Janet Arvizo; is that correct?
A. Yes.
Q. And your maiden name is Janet Ventura; isthat right?
A. Yes. Correct.
Q. To the extent that you may, at different times in this proceeding, be referred to by any
of those three names, that would be you; is that correct?
A. Yes.
Q. And you understand that there are documents that will be admitted and shown to you
under the name Janet Arvizo?
A. Yes.

Q. And you understand that youll be addressed as Janet Arvizo at different times during
this proceeding as well?
A. Yes.
Q. You are currently married to whom?
A. Jay Jackson.
Q. And what does Jay Jackson do?
A. Hes a major in the Army.
Q. And with whom do you reside at this time?
A. With my husband and my four children.
Q. And your four children include the three who have already testified in this proceeding?
A. Yes, sir.
Q. Star, Gavin and Davellin?
A. Yes.
Q. And you have a baby at home; is that right?
A. Yes.
Q. And how old is he?
A. Hes eight months.
Q. Id like to direct your attention, please, back to the year 2000, as best I can. Can you
tell me if, during that period of time, you were first introduced to Michael Jackson?
A. Im sorry, say that again.
Q. When did you first meet Mr. Jackson?
A. In August of 2000.
Q. All right. And is Michael Jackson here in the courtroom at this time?
A. Yeah.
Q. And is he the man with the long dark hair?
A. Uh-huh.
Q. Sitting to my right?
A. Yes.
Q. What were the circumstances of your introduction to Mr. Jackson?
A. My sons illness.
Q. Your son was suffering from what illness at the time?
A. Cancer.
Q. How is it that you happened to meet Mr. Jackson?
A. It was either two -- one of two people. I never knew who.
Q. Somebody arranged an introduction?
A. Yes.
Q. Was your son actively ill at that time?
A. Yes.
Q. What type of treatment was he receiving?
A. Chemotherapy.
Q. Was there a time that you and other members of your family were taken to
Neverland?
A. Yes.
Q. And Neverland is a ranch in Santa Barbara County, is it not?
A. Yes.
Q. All right. Do you remember when that was, what month, what year?
A. August 2000.
Q. Did somebody take you there?

A. We were picked up, yes.

Q. Do you know who that person was?
A. His limo.
Q. All right. And who among your family members went to Neverland back then?
A. My ex-husband David and my three children.
Q. And the three children are the ones weve already identified?
A. Yes.
Q. Okay. How old was Gavin at that time?
A. Gavin was ten.
Q. Had he already undergone surgery for his cancer?
A. Yes.
Q. And was he going through chemotherapy at the time?
A. Yes.
Q. Can you describe his condition at the time of that first visit to Neverland? How was he
doing at that time?
A. He was at that point where walking was kind of difficult for him. He would walk, I dont
know,when you -- kind of like a toddler walk.
Q. All right.
A. And he would tire easy.
Q. Was he taking medication at the time?
A. Yes.
Q. And -A. The chemotherapy.
Q. And as a consequence of the surgery, has he since been taking medication?
A. Yes.
Q. Whats the nature of the medication that he takes?
A. His -- one of his kidneys is malfunctioning, and so that -- he takes one medicine for
that so he doesnt end up losing that kidney. He sees a specialist for that, but theres a
possibility that he could lose his kidney.
Q. Okay. Whats the other medication?
A. The other one is in replacement of his spleen, and thats for -- its -- its a medical
word, but I really dont know what it means. They call it prophylactic, and thats so -because theres certain bacteria that, if Gavin is exposed to those bacterias, its certain
death.
Q. Its an antibiotic of sorts?
A. Yes.
Q. Its for his immune system?
A. This is what theyve explained to me. I dont know.
Q. During that first visit, do you recall how many days you stayed at Neverland?
A. No, I couldnt tell you.
Q. Do you know if it was more than one night?
A. Oh, yes.
Q. Can you tell us if it was as long as a week?
A. No. Definitely no.
Q. And where did you stay during that first visit at Neverland?
A. Me and David stood in one room. And my children were supposed to stay in another
room together, but it ended up just being Davellin.
Q. You and your husband then, David?

A. Yeah.
Q. And Davellin in one room?
A. Yes.
Q. And where did the boys stay?
A. With Michael.
Q. In his house?
A. Yes.
Q. Do you know where in his house that he stayed?
A. I know -Q. Let me ask the question more specifically.
A. Sure.
Q. Do you know from personal observation -- in other words, did you see where they
stayed? Not from what anybody told you, but did you see where they stayed?
A. No.
Q. During that first visit, did you ever go into Mr. Jacksons residence?
A. His residence -- theres an area where theres a -- like a kitchen area where everybody
can go into, but the -- but -- its -- its open, you know, to that area, eating area.
Q. And thats the area you went into?
A. Yes.
Q. Did you go into his personal residence, his bedroom or his bedroom suite?
A. No.
Q. Have you ever been to -A. No.
Q. -- his residence, his personal residence, meaning his bedroom suite?
A. Thats right.
Q. And the answer is no, you had not been?
A. No.
Q. All right. During the period of time that you were there, did your sons ever stay in the
guest cottage?
A. No.
Q. To your knowledge? To your recollection?
A. No.
Q. Did you then return, at the conclusion of that visit, back to your home?
A. Yes.
Q. Where was your home at that time?
A. Okay. Its -- can I explain to them?
Q. Well, try to focus on the question as best you can.
A. Okay.
Q. Did you have a res idence at that time?
A. Yes.
Q. Did you have actually more than one place where you or other members of your family
were staying?
A. Me and the children, when Gavin -- right after he would have --MR. MESEREAU:
Objection; nonresponsive. ZONEN: You have to listen to the question. WITNESS: Okay.
ZONEN: Does the Court want to rule? COURT: I thought you were going to take care of it.
ZONEN: I was. COURT: Well, go ahead.
Q. BY MR. ZONEN: Listen to the question as specifically as possible, okay? Was there
more than one residence that you and your family were staying in during this period of

time?
A. I dont know how to answer that without explaining it.
Q. Did you have a res idence that you were paying rent on?
A. Yes.
Q. Where was that?
A. In East L.A.
Q. Was there another residence that any member of your family was staying in?
A. At my moms.
Q. Where was your moms residence?
A. In El Monte.
Q. And who was staying at your moms residence?
A. Gavin and David.
Q. Okay. And why was Gavin -- why were Gavin and David staying at your mothers
residence in El Monte?
A. Because Davellin and Star were still going to school. I got three kids, you know. Only
because Gavin has cancer doesnt mean the other ones, theyre off. They got to go to
school.
Q. All right. But -A. And so -Q. -- why was Gavin staying at your mothers?
A. Sterile room.
Q. Tell us -A. Because in my bachelor apartment, theres no divided rooms, bedrooms.
Q. All right. So what did Gavin -- what special needs did Gavin require that necessitated
him staying at your mothers?
A. A sterile room after chemotherapy.
Q. Could he or was he being exposed to your other two children?
A. Yes, my other two kids were still going to school, so they had to be separated for that
moment, because the children could have p icked up some other germs, which at the time
Star was nine, and -Q. So your then husband David and Gavin stayed at your mothers?
A. Yes.
Q. And the rest of you stayed at where?
A. East L.A.
Q. And the East L.A. was the Soto Street residence that -A. Yes.
Q. -- weve heard something about; is that correct?
A. Yes.
Q. Describe that residence for us.
A. Ive lived there for about five years.
Q. Tell us what it looked like, the residence.
A. Um -Q. How many rooms?
A. It was my home.
Q. All right. But how many rooms? Was there a bedroom?
A. No.
Q. Was there a living room?
A. No. It was just a room and a wall to divide the kitchen.

Q. Okay. So theres a kitchen and one room?

A. Yeah.
Q. Its a studio; is that right?
A. Yeah.
Q. And all of you lived in that residence?
A. Yes. And it had a rest room, too.
Q. And it had a bathroom?
A. Yes.
Q. And a kitchen?
A. Yeah. BAILIFF: Could you lean forward so we can hear?
Q. BY MR. ZONEN: Were not picking on you. We need to have everybody, all of the
witnesses, speak directly into the microphone so you can be heard.
A. Yeah.
Q. And for what period of time was this your residence? From when to when?
A. For five years. From 1998 to 2003.
Q. Okay. Theres some Kleenex up there, if you need some, as well, I believe, in front of
you. Now, during the period of time that Gavin was ill, did he stay at that residence on
Soto Street at all?
A. No.
Q. Was he going to school during that year that he was ill?
A. He -- the whole entire time while he had cancer he did not attend school one single
day.
Q. Was he either at your mothers residence or at the hospital?
A. Yes.
Q. And did he periodically return to the hospital for treatment?
A. Yes.
Q. Can you tell us approximately within, say, a 30-day period how much of that time he
would have spent at the hospital, how often of that time he would have spent at your
mothers residence?
A. He didnt just stay for the chemotherapy. He was hospitalized -- sometimes because he
had fevers, he had to get hospitalized. Any -- any fragility in his health, he had to be
hospitalized.
Q. So give us a sense. Of the 30-day period, what percentage of that might he have spent
in a hospital?
A. Sometimes. Sometimes more than half.
Q. All right.
A. Sometimes.
Q. How long did the chemotherapy go on?
A. Almost a year, but quite not a year.
Q. Was there a point in time where doctors determined that he was in remission?
A. Yes.
Q. And approximately when was that?
A. It was about in May, but for sure -- yeah.
Q. In May of when?
A. In May of 2001.
Q. May of 2001?
A. Yes.
Q. Was there some kind of demarcation, a test or something that they did?

A. Yes.
Q. And what was that?
A. They did a full checkup, and they concluded that it was not -- it was in remission.
Q. Okay.
A. And then thats when -- he had to have a little thing going through his heart, his main
artery, because he was receiving such strong dosages, so he had to have the strongest
artery.
Q. And that was removed?
A. Yes, that was removed.
Q. All right. Is he in remission today?
A. Yes, he is.
Q. Is he healthy today?
A. Outside the -- the two specialists that see him continuously, his oncologist, his
nephrologist, hes a healthy boy, but hes got medical concerns.
Q. And still sees a doctor?
A. Yes.
Q. And still takes medicat ion?
A. Yes. And then the scare we just had where he had a very serious test. MR. MESEREAU:
Objection; nonresponsive. ZONEN: Ho ld on. No objection to that. COURT: Ill allow the
Yes and strike the rest of the sentence.
Q. BY MR. ZONEN: All right. Now, you described that first visit to Neverland back in
August of 2000; is that correct?
A. Yes.
Q. All right. When was the next time you went to Neverland?
A. Me?
Q. Yes.
A. Oh, let me see. Um -- um -- September 2002, because Chris had invited me, Chris and
Aja. MR. MESEREAU: Objection; nonresponsive.
Q. BY MR. ZONEN: The answer (sic) simp ly is when was the next time you went?
A. Oh. September of 2002.
Q. Did your son or both of your sons or your two sons and daughter return to Neverland
at an earlier time than that?
A. Yes.
Q. Excuse me. When was the next time -- when was the next time that they went back to
Neverland, to your recollection?
A. Okay. The boys?
Q. Yes.
A. The boys went right after the initial visit in August of 2000. But Davellin d idnt go.
Neither did I.
Q. Did your then husband David go?
A. Yes, with David.
Q. And were they transported there?
A. Yes.
Q. And why didnt you go?
A. I felt it was more important for Davellin to focus on her school. She was already
starting high school, ninth grade.
Q. So you stayed home with Davellin?
A. Yes.

Q. And were there any other visits -A. And because of the little incident that Dave did over there.
Q. Youve had problems with David over the years of your marriage; is that correct?
A. Yeah.
Q. Do you know how many visits your children had to Neverland after the init ial visit, and
approximately when they were?
A. Okay. The first initial visit in August, and these are all approximate, August of 2000.
Then the boys, when they returned with David, right after that. Then in the spring of
2002, with Chris. And then Michael invited them immediately back up. And then with
Chriss -- the family birthday party that Chris had, Chris and Aja. And then the filming of
this stuff -- 5992
Q. All right.
A. -- in September.
Q. All right. Youre not -- all right. Lets see if we can work this out a little bit. We have the
initial visit August of 2000.
A. Yes.
Q. And then you said they returned, your husband David and the two boys, soon
thereafter?
A. Yes.
Q. And by soon, are we talking about within a week or two?
A. Oh, yes.
Q. Okay. And do you know for what period of the visit they stayed, for how long?
A. And this is approximate, okay?
Q. Sure. Sure.
A. Pardon me?
Q. Approximately how long they stayed for the second visit.
A. Oh, I couldnt tell you.
Q. Would you know -A. Just days.
Q. -- if it was more than one night?
A. Oh, definitely, yes.
Q. Was it less than a week?
A. Yes.
Q. And you were at home with Davellin?
A. Yes.
Q. And was home at that time the Soto Street address?
A. Yes.
Q. Now, were there any other visits in that year, the year of 2000, to either Neverland or
a vis it with Michael Jackson at someplace other than Neverland?
A. Yes. Michael had invited Gavin and David to go to the Universal Hilton in Studio City,
and thats -- and in this time it was only Gavin in the hotel.
Q. Okay. Gavin and only Gavin, or Gavin and his father?
A. Only Gavin and David.
Q. So his father went, but not his brother or his sister?
A. No.
Q. And you didnt go?
A. No. No.
Q. Was that an overnight visit?

A. No, it was a day visit.

Q. And they returned that same day?
A. Yes.
Q. All right. Was there any other visit in 2000 that youre aware of?
A. No.
Q. Was there any visit in 2001 that you were aware of?
A. Zero.
Q. No visits to Neverland during that time?
A. No.
Q. All right. Now, during that init ial period when your son met Michael Jackson, did you
have any telephone calls with Mr. Jackson at all?
A. Me?
Q. Yes.
A. In 2000?
Q. Yes. In 2000.
A. No.
Q. Do you know if Mr. Jackson was having conversations with your son over the
telephone?
A. Yes.
Q. Do you know where those conversations took place? And I mean your sons end of the
conversation, where he was at the time of those conversations?
A. Sometime in the hospital, but mostly at my moms house. Gavin had his own room.
And he had his own telephone line, his own -- his own answering machine, because
usually they -- the doctor had suggested that sometimes when we use a phone, we can
easily pass viruses or anything on the telephone.
Q. So he had a telephone that only he used?
A. Yes.
Q. That was at your moms house?
A. Yes.
Q. Now, did you ever -- were you ever present during any of these conversations?
A. Sometimes. Sometimes, but not -- theyd go on forever, so Id -- you know, I have to
go do other things.
Q. Approximately how long were these telephone conversations?
A. Hours.
Q. Literally hours?
A. Yes.
Q. And how frequent were they? In other words, how many conversations would they
have in, say, a week period of time?
A. They were frequent. I couldnt -- I couldnt be able to tell you. But I know that after he
met him, it was more.
Q. And did these phone calls go on for a length of time?
A. Yes.
Q. In other words, over weeks?
A. Yes.
Q. Approximately how many?
A. I cant remember.
Q. Now, you said that after that third visit at the hotel, there were no other visits -A. Uh-huh.

Q. -- that either or any of your children had with Michael Jackson during the balance of
2000 or 2001?
A. Correct.
Q. Do you know why that was?
A. Well --MR. MESEREAU: Objection. WITNESS: Because me. MR. MESEREAU: Calls for
speculation; foundation; and hearsay. COURT: Overruled. You may answer. WITNESS:
Okay. What was the question?
Q. BY MR. ZONEN: Do you know why that was?
A. Because I just felt a little bit uneasy. Thats all. He didnt do nothing, you know. You
know, it just felt -- it just felt uneasy.
Q. Did you do something to stop communication between your son and Michael Jackson?
A. Um -- um, yeah, I just expressed I was uneasy about it.
Q. Okay. And you said no visits in the year 2001 as well?
A. Thats right.
Q. When was the first visit in 2002?
A. That was with Chris Tucker and Aja. They had built so much credibility with me, they
took my -- it was like everything was -- like doing family activit ies together, and so when
Chris had asked me that he wanted to take the children to Neverland, I felt it was okay,
because Chris -- you know, theyre decent people, Chris and Aja.
Q. Chris Tucker is somebody who befriended your son -A. Yes.
Q. -- during the time he was ill?
A. Yes.
Q. Did he actually know him prior to that?
A. No.
Q. There were a number of celebrities that did know your children -A. Yes.
Q. -- prior to your son Gavin becoming ill.
A. Yes.
Q. And who were they?
A. Well, let me see. I dont know if you call them famous or something, but theyre
famous to me.
Q. People who had befriended your child -A. Yes.
Q. -- or children prior to Gavin becoming ill?
A. For example, Wheezy. Her name is Louise Palanker. To me, shes famous.
Q. Who else?
A. Jamie, George Lopez, Fritz. And then Jamie had -- Jamie had, like, guests, comics that
came, and celebrities, and so they would -- they met them there.
Q. The introduction to Chris Tucker was by whom?
A. By Jamie.
Q. Was that during the time that your son was ill?
A. Yes.
Q. And did Jamie Masada often visit your son at the hospital?
A. Oh, yes. Yes. Almost daily. My son even -- my -- Jamie would try to -- there came a
point where Gavin wasnt eating because he was vomiting b lood, because he was a very
sick boy. And so Jamie was trying to get him to eat, and hed --Gavin had vomited on him,
and that didnt keep him away. He still kept coming.

Q. Okay. Now, the visit to Neverland in 2002 with Mr. Tucker, do you know who arranged
that?
A. Chris.
Q. And did he in fact take the kids there?
A. Yes.
Q. All right. How many kids went on that visit?
A. On the baby boys birthday party?
Q. The first visit in 2002.
A. Oh, I see. The best I can remember, Chris -- this is another thing, too. Chris was
working on a movie that he was trying to put together called The Pres ident. And he took
his writer, Kelly. And he took the kids because he says theyre funny and they give him
ideas, you know, by them joking around with him.
Q. Okay.
A. So -Q. When do you think that first visit was?
A. The return, with Chris?
Q. The first visit in 2002 with Chris Tucker.
A. That was in spring.
Q. In spring?
A. Yes.
Q. All right. Now, the next visit to Neverland was approximately when?
A. Michael had invited the kids right after.
Q. Did he call the house?
A. Yes. Evvy did.
Q. Evvy called. Did she speak with you?
A. No.
Q. Who did she -- with whom did she speak?
A. Gavin.
Q. Do you know approximately how long that was after that first visit with Chris Tucker?
A. I cant remember right now, but -- I think it was Michael, too, but -- unless I know for a
fact, Ill tell you, but thats the best I can remember.
Q. And did the kids in fact go at that time?
A. Yes.
Q. This is now still spring of 2002?
A. Yes. Right after they were there with Chris.
Q. Was your husband still in the picture at that time, David?
A. No.
Q. Had you already separated?
A. Yes. Id been separated from David since May of 2001.
Q. From the time of that separation, has David had contact with your children?
A. No.
Q. Was there an order that prohibited him from doing so?
A. Okay. During the summer, even though he was -- he had done the things he had done,
during the summer I still tried -- I thought it was my fault, so I tried to encourage. I
figured -- I figured he -- he can have some kind of -- start becoming or having a father
relationship with them in the summer. But that ended when those criminal things -Q. Was there a criminal prosecution of David?
A. Yes.

Q. Did -- was there actually more than one?

A. Yes.
Q. All right. One invo lving you, and one involving Davellin?
A. Yes, two different years.
Q. Following those prosecutions, was there any contact between David Arvizo and your
children?
A. No, except for that one time that he had violated the restraining order with Davellin.
Q. And you were in court?
A. Yes.
Q. Other than being in court -A. Yes.
Q. -- was there any contact?
A. And then that violat ion of the restraining order with Davellin.
Q. All right. Now, then the visit back to Neverland by your children -A. And this is all as best as I can remember.
Q. In 2002, when Mr. Jackson or Evvy called - now, who did you understand Evvy to be?
A. Oh, his personal assistant, and his personal secretary, and his personal everything.
Q. Did you ever meet Evvy in person?
A. Never met her.
Q. You had conversations on the phone?
A. Yes. A lot of conversation with her on the phone.
Q. Did you have a conversation with her on this occasion to arrange a return trip to
Neverland with your children?
A. Yes.
Q. Did you go?
A. Not me. I didnt talk to her. It was Gavin that talked to her.
Q. Gavin d id. All right. And did they in fact go back to Neverland?
A. Yes.
Q. Just the three of them?
A. Yes.
Q. Do you know how long they stayed at Neverland?
A. I think it was a couple of days.
Q. Do you know when this was, this return visit?
A. Right after the visit that they had gone with Chris and his writer.
Q. Do you think that was still in the spring?
A. That was definitely spring, 2002.
Q. Do you have a sense of what month that would have been?
A. No.
Q. Did anybody tell you that at that visit there might be a person filming a documentary?
A. No. That was spring. Now, this is -- then we go -- the baby boys birthday party is
about September. And then right after that is the -- that I come to find out now, thats
when they did the filming for the Bashir tape.
Q. So Im wrong on this one, but lets move on.
A. Thats okay.
Q. It was -- apparently the next visit in 2001 was what, now?
A. Whats that?
Q. We have one where the three kids went on invitat ion from Evvy in spring.
A. Yes. That was --

Q. They were gone approximately how long?

A. About a couple of days, and that was right after being with Chris.
Q. Okay. And then they returned back to your home?
A. Yes.
Q. All right. And where are you still living at this point?
A. East L.A.
Q. This is the Soto Street address?
A. Yes, Soto Street address.
Q. Is Gavin at this point back at your residence with you?
A. Yes, yes, yes.
Q. Hes no longer living in the -A. No, no, no, no.
Q. Now, at some point around this period of time, you meet Jay Jackson; is that correct?
A. Yes.
Q. When did you meet Jay Jackson?
A. I met him -- I met Jay in July of 2002, but just met. You know, the children were
attending this Sea Cadet program in his base. I dont know if you call it base, but its -its -- I dont knowthe appropriate -- correct thing. I used to do something. Its
disrespectful, but its funny. I would tell him thats the Sea Cadet Headquarters,but it was
actually an Army base.
Q. The base was where, now?
A. In W est L.A.
Q. Would you take the children there?
A. Yes, I did.
Q. The children were just the two boys?
A. Yes, just the two boys. But I was --Davellin was involved with the LAPD Explorer
program, but I was trying to see if Davellin would be interested in that, too.
Q. And is Davellin still involved in LAPD Explorers?
A. Yes. Well, to this day, no. Right now shes pretty busy. Shes going to work and going
to school.
Q. But she was with the LAPD Explorers?
A. Yes.
Q. For some period of time?
A. Yes.
Q. Now, this program, the Navy Sea Cadets, how is it that the boys became involved in
that?
A. Okay. Someone had gone to their school and kind of explained what this program was.
And then I got interested, because in the packet it said a lot of interesting things to do to
help them with hopefully becoming a better person, so -- and leadership skills, so -Q. Was there a charge for it?
A. There was a cost, depending on -- depending on your -- if you wanted to volunteer/no
volunteer. Not volunteer for everything, but -- you know, in the little thing.
Q. But there wasnt a mandatory fee requirement for this?
A. As far as I know, there wasnt.
Q. Now, you would bring the boys to that location?
A. Yes.
Q. And how often did they go?
A. They went -- well, Gavin -- Gavin and Star volunteered for just about everything

possible.
Q. Okay. But how often do you think you would take them there?
A. Okay. Twice a month, but because the boys were volunteering just about for
everything, it would be more than twice a month.
Q. All right. And the location where you took them was where?
A. In W est L.A.
Q. Did you have a car during this period of time?
A. No, I didnt.
Q. From the time of your separation from David Arvizo, did you ever have a car during
that time?
A. From like when -- let me see. About the end of spring or the beginning of summer of
2001, they had -- the car that they had given Gavin they took back.
Q. There was a vehicle -- actually, my question was after your separation with David
Arvizo.
A. Yeah. It still stood for about one more month, about.
Q. So you had that car for about a month after your separation?
A. Yeah, probably less than a month, but Im approximating.
Q. What kind of a vehicle was this?
A. It looked just like O.J. S impsons car. It was the white -- I mean -Q. A white Bronco?
A. Yeah. Yeah.
Q. All right.
A. Exactly. I mean, even to almost the year, but Im not -- you know, it may be off, the
years.
Q. And where did this vehicle come from?
A. From him.
Q. Was it brought back by David Arvizo?
A. What do you mean?
Q. Did he return in this vehicle from Neverland?
A. No, no. It was delivered to my moms house.
Q. And then at some point in time, was the vehicle returned?
A. Yes.
Q. Why was it returned?
A. Well, the -- the little thing when you turn it on and off wouldnt work. Sometimes it
would work, and sometimes it wouldnt. And where I live, you cant leave a car too long,
because different streets are assigned parking things and they would tow the car away.
And Michael had said if anything ever got broken, to send it back and hell have it
repaired. But it never came back.
Q. Did something break?
A. Yes. I had taken it to a place on Valley Boulevard and they had told me that the -- an
alternator was -- I dont know what it is, but they said an alternator.
Q. Okay. Some cars have those, I understand. The car was then returned to Mr. Jackson?
A. Yes, sir.
Q. And did you ever see that vehicle again?
A. Never seen it again.
Q. Did you ever have a conversation with Michael Jackson?
A. Yes.
Q. Did you ever have a conversation with Michael Jackson prior to 2002?

A. Prior to 2002?
Q. Yes.
A. No.
Q. Even that first visit to Neverland?
A. No.
Q. Was he there on that first visit in August of 2000?
A. Yes. Yes. Yes.
Q. Did you meet with him at all?
A. Yes.
Q. Did you talk at all?
A. No. David was doing all the talking.
Q. Were you present with Mr. Jackson at different times during that visit?
A. Yes. Yes, I was.
Q. Subsequent to that visit, after that visit, did you ever have a telephone conversation
with Mr. Jackson?
A. No.
Q. Up until your return to Neverland with Chris Tucker in the spring of 2002, did you ever
have a conversat ion -A. I didnt go to the spring 2002.
Q. You didnt go on that one?
A. Yeah. It was just my kids.
Q. When was the next one that you went to?
A. Me? To Chris and Ajas baby boys birthday party.
Q. And we were actually in the process of going chronologically through the different
visits. Is that, in fact, the last one, Chris and Ajas birthday party?
A. Yes.
Q. And this was for their son?
A. Yes.
Q. What year birthday?
A. I cant remember, but he was little.
Q. He was a baby?
A. Well, not a baby, but little.
Q. All right. Who went to that?
A. Preschool age.
Q. Preschool, all right.
A. Yes.
Q. Who went to that?
A. The baby boy birthday party?
Q. Okay.
A. Just about all of Chriss family. His mom and his dad. Everybody. All his family,
practically. He flew them in from Atlanta.
Q. And among your family, who went?
A. Me, my three kids, and Jay had also came.
Q. Now, were you at this time in a relat ionship with Major Jackson?
A. Not really.
Q. Were you dating?
A. I was kind of a little bit, you know, hesitant.
Q. Okay.

A. I met him in July. But all we did was have phone conversations. It wasnt our first -- he
considered it our first date. I really considered it just a ride to the boys graduation from
Sea Cadet.
Q. Okay. He did tell us that, and we wont tell him that you told us otherwise. All right.
Now, this visit to Neverland, was it overnight?
A. No.
Q. Did you return that same day?
A. Yes, and Chris had taken us on two of his buses.
Q. And the buses came and left from where?
A. From -- he had -- he had asked us all to meet outside this hotel, and then thats where
we had left.
Q. Was Michael Jackson there during that birthday party?
A. No. No.
Q. You didnt see him at all?
A. No.
Q. When was the next time that your children went to Neverland after that?
A. For the filming. But make it very clear, I wasnt -- now I know.
Q. The question was when was the next time?
A. Its still in September.
Q. It was in September of 2002?
A. Yes.
Q. How did they happen to go to Neverland?
A. Because Evvy and Michael had called them over. And right before that, Gavin had -had done a biopsy. So, you know, I thought -- I thought he was inviting him because of
the biopsy.
Q. The biopsy result was favorable?
A. Yes.
Q. And all of you were rejo icing in his remission? A. Yes. Yes. MR. MESEREAU: Objection;
leading. THE COURT: Sustained.
Q. BY MR. ZONEN: Now, from whom did you receive a telephone call?
A. From -- from Evvy.
Q. And do you know if Michael -A. But I didnt talk to them. Evvy -- they hardly talked to me. It was always Gavin.
Q. So there was a phone call that came from Evvy?
A. Yes.
Q. How did you become aware of the fact that they were being invited back?
A. Because Gavin had said that Evvy and Michael had invited them over to go have a day
of fun.
Q. Okay.
A. And I figured -- I figured that Chris had communicated to Michael that he had -- you
know, about his biopsy.
Q. Okay.
A. Because Chris and Aja were very involved with my kids.
Q. Was this a topic of discussion in the household at the time, the biopsy?
A. Yes. Yes.
Q. Now -A. Because we were very fearfu l at that time that Gavin might lose his kidney.
Q. Okay. Now, you said a day of fun.

A. Yes.
Q. Was it anticipated that this would only be for one day?
A. Yes, but they ended up sleeping there.
Q. Were they there longer than one night?
A. No, just one night.
Q. Overnight?
A. So they actually ended up staying two days and one night.
Q. And you did not go?
A. No, I did not go.
Q. And did you have any telephone communication with Michael Jackson personally with
regard to that trip?
A. No.
Q. Did you have any telephone communication with Evvy during that trip?
A. No.
Q. Do you know her last name, incidentally?
A. Yes, Tavasci.
Q. Tavasci, all right. Did the children come home at the end of that second day?
A. Yes.
Q. Now, when d id you learn that there was a film crew that had been at Neverland?
A. Until he made me aware.
Q. He being Mr. Jackson?
A. Yes. Way in February.
Q. All right. So your children didnt discuss with you that?
A. No.
Q. And you didnt know about it?
A. No.
Q. Now, prior to your children going to Neverland on that particular visit, did either Mr.
Jackson or Evvy or anybody else from Neverland notify you personally that there was
going to be a film crew there?
A. No.
Q. Did anybody ask you to sign any documentation with regards to your children
appearing in a film?
A. No.
Q. Did you know anything about it at all?
A. No.
Q. Now -A. But I know now.
Q. Okay. That was during the -- I think yo said the fall, September.
A. Yes. September.
Q. Am I right about that? I want to make sure I am.
A. Yes, 2002.
Q. And when was the next visit after that one, if you recall?
A. Of 2002?
Q. Yes.
A. The filming. W hen he called me up.
Q. All right. So there was no -- there were no more visits in 2002?
A. No. Zero.
Q. Now, lets move on to 2003.

A. Okay.
Q. Did you receive a call from Michael Jackson?
A. Oh, yes.
Q. Did that call come to you or did it come to another member of your family?
A. To Gavin.
Q. At some point in time did you get on the telephone with Mr. Jackson?
A. Yes.
Q. Had you had any other conversation with Mr. Jackson prior to that day?
A. Prior to this day?
Q. Yeah. Prior to that day.
A. Zero.
Q. Zero. All right. Now, weve already talked about that first visit where you were face to
face with Mr. Jackson.
A. Yes.
Q. Was there ever any occas ion other than that first visit back in August of 2000 where
you were face to face with Mr. Jackson up until this phone call in February of 2003?
A. Zero.
Q. Was there ever any occas ion where you had a telephone conversation with Mr.
Jackson?
A. Never. Except -Q. Listen to the whole question. Were going to drive the reporter nuts if we dont let each
one finish.
A. Im sorry.
Q. Okay. Prior to this telephone conversation in February -A. Okay.
Q. -- was there ever any occasion at all where you had a conversation with Mr. Jackson
over the telephone?
A. No.
Q. Now, do you know the date of this telephone call?
A. Ive come to find out per the investigation, but I still always forget. The only way I
know is because he had told me about it, and it had aired in England prior to it airing
here. So consider the time d ifference and all that. So definitely before it aired here, and
after it aired over there.
Q. In England, all right. Tell me what you think is the date of that first appearance, if you
know. If you dont know, just say so.
A. No, I dont know.
Q. Was it early February?
A. Yes.
Q. Now -A. I mean, it -- every time they tell me, I - I remember, but -Q. Its all right. Its all right. Now, at the time of this telephone conversation from Mr.
Jackson, were you aware of the documentary titled Living with Michael Jackson?
A. No, not the documentary.
Q. All right. This is prior to your telephone -- were talking about prior to your telephone
call from Mr. Jackson
A. Yes.
Q. Did you have any personal knowledge that a documentary had been prepared -- listen
to the question -- that a documentary had been prepared and was titled Living with

Michael Jackson?
A. No.
Q. Were you aware that such a documentary had actually been shown in England?
A. No.
Q. Had your kids mentioned to you at any time prior to this conversation with Mr. Jackson
-A. No.
Q. -- that they had particip ated in a filming of some kind?
A. No.
Q. Had the name Martin Bashir been raised in your household up to that point?
A. No.
Q. Did you know who Martin Bashir was?
A. No.
Q. All right. The telephone call from Mr. Jackson in early February that went to Gavin -A. Uh-huh.
Q. -- did you at some point get on the telephone with him?
A. Yes.
Q. What did he tell you?
A. He had told me that -- well, this is -- Gavins talking to him first. He had told me that
Gavin was in danger, and that there had to be a press conference because of this Bashir
man.
Q. All right. Now, did you know what he was talking about, this Bashir matter?
A. No.
Q. Did you ask him to explain that?
A. No.
Q. Did he offer any explanation as to what that was?
A. No. At first I was telling him, No, no, no, no, no, no, because he wanted him to come
to Miami. But when he told me, you know, Janet, David -Q. Mrs. Arvizo, why dont you hold on a second. Were going to take it question by
question.
A. Okay, sure.
Q. Listen carefully to the question asked, all right?
A. Okay.
Q. Did he explain to you at any time what this documentary was?
A. No. Not there, not on the phone.
Q. I understand -- were just talking about the phone conversation right now.
A. Oh, okay.
Q. Did he ment ion the name Mart in Bashir in this phone conversation?
A. He just said Bashir.
Q. Okay. Did you know what that meant -A. No.
Q. -- at that time? He said to you that your child was in danger?
A. Yes.
Q. What did he say with regards to your child being in danger?
A. That he was receiving death threats.
Q. Did -A. That he was in danger.
Q. Did that alarm you?

A. Yes.
Q. Did you believe what he said at that time?
A. Its until he -- until he started telling me that the children had shared with him about
how David was a bad guy, because my guard was here (indicat ing). And when he started
telling me those things, oh, waarrrrr.
Q. All right. Well get to that in just a second.
A. Okay.
Q. But right now with regards to your son being in danger -A. Okay.
Q. -- did he describe the nature of the danger to you ?
A. Just death threats because of this Bashir thing.
Q. Did he tell you who the people were who were issuing the death threats?
A. No.
Q. Did he use the word death threats or the term death threats?
A. He said he was in danger.
Q. And did he mention any of your other children in that regard?
A. No. Not until we got there.
Q. How long was your conversation with Mr. Jackson?
A. Well, long enough to convince me.
Q. And approximately how long was that? Can you say that it was longer than ten
minutes?
A. I wouldnt be able to tell you.
Q. Now, at some point you said he started talking with you about your ex-husband.
A. Yes.
Q. What did he tell you with regards to your ex-husband?
A. He told me that the children had shared with him what the children had gone through.
And then he had told me that he understands, and that he doesnt want the children nor
me around David anymore; that hes a bad guy. And -- you know. And to me -- you
know.
Q. All right. So he was -- he was giving you informat ion -A. Yeah.
Q. -- about your ex-husband?
A. Yes.
Q. Now, what was your response to hearing that? How did you respond to that?
A. I was, like, wow, he understands.
Q. Now, had your kids ever told you that they had talked with him about David Arvizo?
A. No. Thats -- no.
Q. Did that surprise you that he had that kind of information?
A. Yes, but I believed him. I believed him. And maybe they did, maybe my kids did.
Q. What did he ask you to do on this -- in this telephone call?
A. That Gavin -- that he needed Gavin to do a press conference, and he could protect
him.
Q. Did he say where he was calling from, Mr. Jackson?
A. Miami.
Q. And did he tell you where this press conference was going to be?
A. In Miami.
Q. Did he tell you what he wanted Gavin to say in this press conference?
A. No. I dont remember.

Q. Did you agree that Gavin could go to Miami?

A. No.
Q. What did you tell Mr. Jackson?
A. Well, I told him that if my son is in danger, then me and my kids have to go.
Q. Did you ask him at any time if he contacted the police?
A. No.
Q. Did you have any discussion with him about what he was doing to remedy this
problem, this problem of danger?
A. No, I just trusted him.
Q. And I believe that you said -- in your answer again to the question of whether your son
would go to Miami, what did you say?
A. No. MR. MESEREAU: Objection; asked and answered. WITNESS: I said no. ZONEN: Ill
withdraw the question. Ill withdraw the question. COURT: All right.
Q. BY MR. ZONEN: Did you come to an agreement with Mr. Jackson as to who was going
to go to Miami?
A. Yes, my kids and me.
Q. And my kids, did you mean all three?
A. Yes.
Q. Why did you want to do that?
A. Well, because if Gavins going to be -- you know, if theres death threats, then I guess
we all have to be together.
Q. Did he agree to that?
A. Yes.
Q. Did he say -A. And actually, hes the one that was going that route.
Q. All right. And that was my next -A. Because I had told him no.
Q. That was my next question. Who is it who suggested that the whole family -A. Him.
Q. You need to wait until the question is asked in its entirety.
A. Okay.
Q. Who was this that suggested that the whole family go to Miami?
A. Michael.
Q. Did you then agree to that?
A. Yes.
Q. Did he tell you when he wanted you and the -- and your children -A. (Indicating) like that.
Q. You need to wait till the question is asked.
A. Okay.
Q. Did he tell you when he wanted you and your children to go to Miami?
A. Now.
Q. And by now, you meant immed iately?
A. Immediately.
Q. All right. Was there some arrangement that was made either by Mr. Jackson or by
some other person -A. Him -- oh, sorry.
Q. -- or by some other person to get to you Miami?

A. Yes, Michael and Evvy.

Q. Did somebody contact you after the telephone call with Mr. Jackson?
A. Yes, Evvy.
Q. Yes. What was the arrangement that you were going to have to get to Miami?
A. That Gary Hearn, his personal, like, driver, the person who takes care of his cars, was
going to fly with us on a commercial air flight to Miami.
Q. And where were your children at the time of this conversation?
A. Okay. Davellin was in school. And the boys were not in school.
Q. Did you have to make arrangements to get Davellin out of school?
A. No, actually Gary went to go pick her up after school.
Q. And from where did he pick her up?
A. From -- from -- I dont remember. I think it was -- I think it was my moms. I think he
went to go pick her up from my moms or East L.A., one of those. Best person to ask that
is Davellin.
Q. Do you know where you were at the time of this phone call from Mr. Jackson?
A. Yes.
Q. Where?
A. Our phone in East L.A. had been disconnected. And so I had received a message from - from Evvy that they had to be able to make contact, so I was in Jays house.
Q. Where did that message come to?
A. What -Q. The message that you received from Evvy was forwarded through whom?
A. It was both, Evvy and Michael, to Jays.
Q. To Jays house?
A. Yes, because I had no phone at that time.
Q. All right. Did you return a phone call -A. Yes.
Q. -- or did they reach you there?
A. They actually -- it was a combination of everything.
Q. All right. Explain that.
A. They contacted me there, and I returned phone calls from there to Evvy.
Q. To Evvy.
A. Yes.
Q. And then Mr. Jackson personally called?
A. Yes.
Q. And that was the conversation that both you and your son -A. And Evvy had also left messages at my moms house before that. COURT: All right,
Counsel. Lets take a break. ZONEN: Thank you. COURT: Go ahead. ZONEN: Thank you.
Q. Where we left off, you were talking about the telephone call from Mr. Jackson.BAILIFF:
Turn your microphone on, please. ZONEN: Thank you.
Q. Where we left off, we were speaking of the telephone call with Mr. Jackson and the
arrangements for the trip to Florida before that. Let me ask you a couple other questions.
A. Okay.
Q. Had you been contacted prior to that phone call from Mr. Jackson in that early part of
February by any member of the media or the press?
A. Yes.
Q. All right. Had you personally been contacted?
A. What happened, this is how it happened: Two reporters -- they said they were two

reporters. Who knows? Okay. They had gone to my moms house. My mom only speaks -my mo m only speaks Spanish. Thats it. These two men, one of them was the speaker,
kept telling my mom, Gavin, cancer, and speaking in English. And the only two things
that stood out in my mom, even though she knows only Spanish, like certain words mean
something to her. And so they said, Gavin, cancer; Gavin, cancer, and that stood out.
So my mom called me immed iately, you know, Whats wrong with Gavin? And she -- I
go, No, nothings wrong, Mom. Theyre at school. And she goes, Well, theres two men
here telling me about Gavin and cancer.And so she didnt know, so I thought maybe
some -- some med ical -- some -Q. Let me stop you for a second.
A. Sure.
Q. This conversation was how long prior to the phone call from Mr. Jackson?
A. With -- I dont understand.
Q. The conversation with your mother about these two people who arrived.
A. Okay. They were still there while my mom was on the phone.
Q. I know. But this conversation was how long prior to your conversation with Mr.
Jackson. W as it the same day?
A. It was -- it was within hours that Evvy contacted me next.
Q. All right. Now, are these the only two members of the press who contacted your
family?
A. Yes.
Q. And anybody else from the media contact your family?
A. Oh, yeah. Afterwards.
Q. Afterwards?
A. Yes.
Q. But prior to your trip to Miami -A. Prior to my trip, yes, thats it.
Q. Did you ever actually speak with these two people?
A. Well, my mom passed me the phone, and I spoke to him. And he says, We just
happened to see your son in England. And I go, No, if my -- I just dropped off my son
at school. And if hes in England, hes in big trouble, you know. And so -- and he was
very vague. And I said, You scared my mo m. She only speaks Spanish, so please dont
continue talking to her.
Q. Did you have an interview with either of these two people?
A. No. MR. MESEREAU: Objection. THE W ITNESS: No MR. MESEREAU: The witness had
not completed her response, I dont think, Your Honor.WITNESS: No. MR. ZONEN: You call
it. THE COURT: Why dont you just ask another question. ZONEN: Thank you.
Q. Did you actually have a conversation with either of those two people over the
telephone?
A. Yes. One of them.
Q. All right. Did that person identify himself by name?
A. I think his name -- he said, Im a reporter from England. I just flew in and I have to fly
out immed iately.
Q. All right. Did he tell you what his name was?
A. I think it was -- I cant -- I think it was Mr. Garner. I think thats what it was.
Q. Garner or Gardner?
A. I think it was, yes.
Q. Did he tell you what publicat ion he was with?

A. No, he just said, Im a reporter from England. I just flew in, and I have to fly back
immed iately.
Q. Did he tell you that he wanted to have an interview with you?
A. No.
Q. Did he discuss any particular issue with you?
A. He was very vague. What he wanted was for me to meet -- to -- to have a conversation
with him, and -- but because he was vague, I didnt want to talk to him.
Q. Okay.
A. So I told him, Youre scaring my mom. And thats not my house, thats my moms
house. I live in Los Angeles.
Q. All right.
A. And that was it.
Q. All right.
A. As best as I can recall.
Q. This was a telephone conversation from which phone?
A. From my moms.
Q. You happened to be there at the time of the call?
A. No, no. Im over here in Los Angeles. My mo m called me because she was scared,
because these two guys were saying Gavin -- and a whole conversation. But the only
thing that jumped out in my mom was Gavin and cancer.
Q. And then you called back from where?
A. There was no call b ack.
Q. All right. They called you when you were at your moms?
A. No, no.
Q. Tell us -A. I was in Los Angeles. My mom was courteous and polite, you know. Handed her the
phone, because I wanted to know what the nature of their visit, why they were saying
Gavin, cancer.
Q. They were there in person?
A. Yes, yes. At my moms house.
Q. All right. Now, during the course of this conversation, did you discuss Michael Jackson
at all?
A. No.
Q. Did they tell you they wanted to talk about Michael Jackson?
A. No. MR. MESEREAU: Objection; leading. W ITNESS: No. All they said was --COURT:
Overruled. WITNESS: -- they had seen Gavin in England.
Q. BY MR. ZONEN: How long was this conversation you had with him?
A. Just minutes. With the information that I just told you, if you want to time it, its about
that long.
Q. Was that the only conversation that you had with either one of them?
A. Thats correct.
Q. On this day, prior to going to -A. That day, only day.
Q. Never h ad any conversation -A. Never.
Q. -- thereafter?
A. Zero. Double zero.
Q. At some point in time, did your then boyfriend, Jay Jackson --

A. Yes.
Q. -- tell you that he had had conversations with reporters?
A. Now I know, per this investigation. I know a lot of things now per this conversation.
Q. Listen to the question, okay? On that day prior to your going to Florida, did Jay Jackson
tell you that he had conversations with reporters?
A. No.
Q. Did you have any conversation with Jay Jackson prior to going to Florida about any
reporters at all?
A. No.
Q. Were you aware -- did any other reporter try to contact you prior to going to Florida?
A. No.
Q. In the course of this conversation with this person, Gardner or Garner, did he mention
anything about a documentary?
A. No.
Q. Did he ment ion to you anything about your child having been on televis ion?
A. He had said, I have just seen Gavin in England.
Q. All right. And you werent certain what that meant?
A. Yeah.
Q. All right. Now, when you were speaking with Mr. Jackson on the telephone -A. Uh-huh.
Q. -- did you ask Mr. Jackson about whether or not your child had been on television?
A. No, I didnt ask him.
Q. You didnt him ask that question?
A. No.
Q. Did he offer any information about that?
A. No, not really. He was vague.
Q. In the course of your conversation with Michael Jackson, did he ment ion anything
about this documentary having -A. He said only the Bashir -Q. Listen to the entirety of the question.
A. Okay.
Q. Did he say anything to you about this documentary that had aired in England?
A. No.
Q. Did he ment ion the name of it, Living with Michael Jackson?
A. No.
Q. Did he ment ion Mart in Bashir?
A. He didnt say Mart in Bashir. He saidBashir.
Q. All right. Did you ask him who that was or what that was about?
A. No. Until Miami. I found out more things.
Q. All right. Now, you then flew to Miami, Im
assuming.
A. Yes.
Q. And with whom did you fly to Miami?
A. With Chris and the kids and me.
Q. Do you know -- and Chris is Chris Tucker?
A. Yes.
Q. Do you know how he became invo lved at this stage?
A. Evvy contacted him.

Q. Evvy contacted him?

A. Yes, but I didnt know about this until I got to the sidewalk, which Gary Hearn had
meet us, and he says, Guys, theres a change of plans, and that was it.
Q. Did he then take you to a private -A. No, he took us to Chriss house, and we spent some time there in Chriss house
because we were waiting for Davellin to come. Thats when we flew on a private jet.
Q. All right. And did you know that you were going to be taking a private jet?
A. Not until Gary told me.
Q. And the private jet took you straight to where?
A. Miami.
Q. And once in Miami, did they take you to a hotel?
A. Yes.
Q. Which hotel did they take you to?
A. The Turnberry.
Q. Can you describe that hotel for us?
A. It looks like a Las Vegas kind of hotel, except -Q. Is it fancy?
A. Yeah. W ithout the slot machines.
Q. Without the slot machines. All right. Now, did you meet up with Mr. Jackson when you
got there?
A. No. No. We got right there until -- you know that time between -- before morning time
where its really, really dark? Thats the time we arrived. So we went straight to -dropped off Chris in his room, and then we went to our room. And our room was right
underneath his room. And Chris, they had set him up in a completely different building,
away from me and the kids.
Q. All right. And your -- were you in a suite of some kind?
A. It was a -- it was two rooms connected. You know, I dont know if you know the hotels
where you lock it and then theres two separate rooms? Well, they had unlocked it.
Q. Excuse me. Im sorry.And you were there with the three children?
A. Yes.
Q. Now, when d id you see Michael Jackson after arriving?
A. In the daytime.
Q. Had you talked with anybody during the course of the trip about this danger that Mr.
Jackson had spoken to you about?
A. No. No.
Q. When you got to the hotel, did you have a conversation finally with Mr. Jackson?
A. Yes.
Q. How long had you been at the hotel before you met up with Mr. Jackson?
A. Hours. Because we had arrived during that time and it was -- it was -- it was already
the day of.
Q. Who else was present during the course of this conversation?
A. Okay. The conversation?
Q. Yes.
A. Just me and the kids and him.
Q. Did he talk with you about the issue of this danger to the children?
A. Yes.
Q. What did he say?
A. He spoke to all three of my kids and me, and he spoke in a very normal voice, very

male vo ice. This is where I became aware that all three of my children were in danger.
Told me to trust him, believe him, hes a father figure, be like -- like a father to all three
of my kids. Basically telling us hes going to protect us, protect my kids; to do everything
that Ronald and Dieter tell him, because this is whats going to fix the problem. He even
had told me that he has read -- he knows what to do in this situation, because hes read
hundreds of books on psychology, and he knows -- he knows what to do in these kind of
things, of what kind of frame of mind that these people that were threatening my children
are. He had -- he had cried. I just thought, you know, what
a nice guy, you know.
Q. Hold on one second. This conversation took about how long?
A. Oh, gosh. About maybe a -- about 45 minutes.
Q. All right. Did you ask him specifically about the nature of the threats to your children?
A. No, I was just like -- I was just like a sponge, believing him, trusting him.
Q. Did he tell you the nature of the threats to your children?
A. Because of the Bashir thing.
Q. But did he tell you who these people were?
A. No.
Q. At any point in time did he say to you that the police were or were not being
contacted?
A. No.
Q. Did he ask anything of you or your children while you were there in this meeting?
A. In this meeting, no. No.
Q. Do you know why you were in Miami?
A. To do a press conference. Q. Did he talk with you about a press conference -A. No.
Q. -- during this meeting? He said something about Dieter and Ronald?
A. Yes.
Q. Were Dieter and Ronald people who you knew prior to that day?
A. No.
Q. Did you meet them that day?
A. Yes. ZONEN: All right. Your Honor, if I
could approach the witness, please. COURT: Yes.
Q. BY ZONEN: Im showing you two exhibits, if I can, No. 17 and No. 18 - all right? - in
evid ence. If youll take a look at No. 17, can you tell us who that is?
A. Thats Dieter.
Q. And do you know Dieters last name?
A. Ive come to find out per this investigation.
Q. Just tell us -A. Dieter Weizner.
Q. All right. No. 18, do you know who this person is?
A. Ronald Konitzer.
Q. And those were the Ronald and Dieter that -A. Yeah. Those Germans.
Q. And, in fact, are they German?
A. Yes.
Q. How do you know that?
A. Because they told me, and plus they speak German.
Q. Spoke among themselves in German?

A. Yes, yes.
Q. Did you meet them that day?
A. Yes.
Q. Is there anything else that Mr. Jackson told you in the course of that meeting with
him?
A. Oh, that he loves us; that he cares about us; that were family; that we were in the
back of the line, now were in the front of the line, and because hes going to take care of
us, protect us from these killers. Let me see. What else? That hes -- that hes not just a
father figure to Gavin, to Star and to Davellin. Let me see. What else? And hes family to
me and hes family to the kids. Let me see. What else?
Q. Do you know if Mr. Jackson had ever had --MR. MESEREAU: Objection. The witness has
not completed her answer yet. THE W ITNESS: Oh, theres still more. When it pops up, Ill
let you know. COURT: Go ahead and ask your next question.
Q. BY MR. ZONEN: Do you know if Mr. Jackson had ever had such a similar conversation
with your children?
A. With my kids?
Q. Yes. Prior to that day.
A. Prior to the Bashir thing?
Q. Yes, where he talked about being family.
A. Yeah. In the initial vis it in August, in 2000, all his -- like, all his people, for examp le,
Evvy was the No. 1 one that was pointing out that, I want you to see Michael as like
family, all --We see him and view him only as a father figure,so -Q. Do you know if Mr. Jackson has ever said something like that to your children prior to
Miami?
A. Actually, in a conversation with Gavin over the phone, thats when Gavin had told me
one of the conversations.
Q. All right. Did you then have conversations with either Dieter or Ronald?
A. Prior to this?
Q. No. I think you had said that you never met them prior to that.
A. Yeah, thats right.
Q. After your conversation with Mr. Jackson, and he gave you some direction with regards
to Dieter and Ronald, what specifically was it that he told you to do with Dieter and
Ronald?
A. To listen and do everything they say, because theyre going to fix the problem.
Q. Now, did you then have a conversation with either Dieter or Ronald?
A. Yes, I did.
Q. Was it one or the other, or both?
A. Both.
Q. Was it at the same time or separately?
A. This was the same time.
Q. All right. And do you remember where you were when that conversation took place A.
In Miami.
Q. Were you in the hotel?
A. Yes, in his room.
Q. In Mr. Jacksons room?
A. Yes.
Q. Was Mr. Jackson present?
A. Yes, he was. And he had sat me down, and he said, Sit down right here, and those

two sat next to me.

Q. Okay.
A. And then Michael was there.
Q. Who did the speaking?
A. Who did the speaking first?
Q. Yes.
A. Because they were all speaking.
Q. Well, all right, thats a valid point. Who is it who began the conversation?
A. Well, Michael.
Q. And what did he say when all of you were together?
A. He said, This is Ronald and Dieter.Because he had already had that 45-minute initial
meet ing.
Q. I understand.
A. And thats the point where he had taken off the jacket and handed -- and physically
placed it on Gavin.
Q. All right. Well, let me ask you about that for a second. This was in the hotel room?
A. Yes.
Q. On the first day of your visit?
A. Yes.
Q. And it was the date of the flight, actually; is that right?
A. Yeah, because we had arrived there right before -Q. In the morning?
A. Yeah.
Q. Now, he was wearing a jacket during the course of this conversation?
A. Yes. Yes.
Q. And he took the jacket off?
A. Yes.
Q. And did what with it?
A. Yes.
Q. What did he do with the jacket?
A. It was kind of like a -- it was after he was done with the conversation. He took off his
jacket, and then he put it on Gavin. He told me he wanted him to wear it and not to take
it off.
Q. Was Star there as well?
A. Yes.
Q. Was Davellin there as well?
A. Yes.
Q. And both Dieter and Ronald were there at that time?
A. No, no. In the initial meeting with him?
Q. Yes.
A. Ron and Dieter were nowhere in sight of the hotel room.
Q. But at the time he handed your son his jacket, were either of them there?
A. No.
Q. Ronald or Dieter?
A. No.
Q. Now, lets get to the conversation when Ronald and Dieter are there.
A. Yes.
Q. Can you tell us what Ronald said during the course of that conversation? MR.

MESEREAU: Objection; hearsay. MR. ZONEN: Statement in furtherance. COURT: (To the
jury) All right. Im allowing this particular testimony for purposes limited to possible
conspirator statements. You may only consider it for those purposes in accordance with
my earlier instructions.
Q. BY MR. ZONEN: I believe it was Ronald I had 6045 asked you about. Tell us what
Ronald said during this conversation.
A. Well, in this conversation, all they wanted to know was basically of -- of who I am,
where I lived, my brothers, my mother. Just basically information from me and the kids.
Thats all.
Q. Did you give them that information?
A. Yeah, I did.
Q. At some point in time -- and was that with Dieter, as well, during that conversation?
A. Yeah. Yes.
Q. Did they give you any direction?
A. No. There was just -- they were just, you know, wanting information about me and my
kids. And I had seen nothing incorrect about that, or wrong, because, you know, we just
had that powwow with Michael.
Q. Did either one of them in this initial conversation talk to you about a danger that your
children were experiencing?
A. In this one, no. No, they were just like absorbing all the informat ion that they possibly
could have.
Q. They were getting information from you?
A. Yes. From me and my kids. About our past, our present.
Q. Was Mr. Jackson present during the entirety -A. Yes.
Q. Please wait till the questions answered (sic) in its entirety.
A. Okay.
Q. Was Mr. Jackson there during the entirety of that conversation?
A. Yes.
Q. Did he offer any other information during that conversation that you havent told us
about
yet?
A. Best I can remember, no.
Q. How long did you stay in Miami?
A. Okay. Arrived there at that night, was there that day, that night they showed the
Living with Michael Jackson thing, which I wasnt allowed to watch, none of the children,
and then the next day we left.
Q. All right. So you were there two nights?
A. Yeah.
Q. And then the next day you flew back?
A. Yes.
Q. Lets go back to that first day. Now,youve described that first conversation that took
place with your kids, Mr. Jackson, Dieter and Ronald.
A. Uh-huh.
Q. Did you have any subsequent conversations, any other conversations that day with
either Ronald -A. No.
Q. -- or Dieter?

A. They were busy at work, I know now.

Q. But did you have a conversation with either one of them that day?
A. No. After that, after they absorbed all that informat ion, no.
Q. All right. Now, the next day, did you have any conversation with either Michael Jackson
or Dieter or Ronald?
A. Just almost -- almost the whole day thats when we had stayed in Michaels room.
Q. You were there in Michaels room that entire time?
A. Yeah.
Q. All right. Did Mr. Jackson talk with you during the course -- was Mr. Jackson there
during that day?
A. Yes.
Q. So he was in the room with you and your three children?
A. Yeah.
Q. For a good part of the day?
A. Well, the whole ent ire time, Michael was there with the kids.
Q. All right. Did you ever leave the hotel?
A. No, I never left the hotel.
Q. Had you ever been to Miami before?
A. Never been there.
Q. Did you want to go see the city at all?
A. No.
Q. Did you express a desire to leave the hotel? MR. MESEREAU: Objection; lead ing.
WITNESS: No. I just wanted to focus there --COURT: Just a moment. Just wait till I
rule after theres an objection.WITNESS: Okay. COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Did you at any time leave the hotel during the two nights that you
were there?
A. No.
Q. Did you ever leave your room during that time?
A. Yes, I did. When I was in Michaels room,and then thats the best I can remember.
Q. Did you ever go out to eat?
A. Well, the morning of -- Chris was eating with the kids. They were having breakfast. By
the time I had gotten there, they were already done. So all I had was, I think -- please
dont quote me on this -- I know a lemonade and I think a some cheese that they had,
like samples.
Q. Did you leave your room to go to a restaurant at all?
A. No, except for that. When I had arrived, Chris and the kids were already leaving.
Q. Did you leave your room or Michaels room,Michael Jacksons room, for any reason
during that time that you were there?
A. No, outside what I just told you, as best as I can remember.
Q. Did you at any time go to a spa?
A. Not me.
Q. Did other members of your family?
A. Yes. MR. MESEREAU: Objection; leading. WITNESS: With Chris. COURT: Just a
moment. Overruled. You need to slow down when Im ruling. WITNESS: Okay.
Q. BY MR. ZONEN: Which members of your family went to a spa?
A. And I think thats what it was, okay?
Q. Okay.
A. Because Chris wanted to go get a massage, so he took Davellin and Gavin and Star

with him.
Q. All right. And did they have some type of service at the spa as well?
A. Yes.
Q. Why didnt you go?
A. I was concerned. When are we going to, you know, take care of my kids from being
killed?
Q. Did they talk to you about this press conference on the second day?
A. No, they didnt.
Q. Neither one of them mentioned that to you?
A. No.
Q. Did they talk about anything that they wanted to do on this second day?
A. No. No press conference.
Q. Did you have any conversation with either Dieter or Ronald on this second day about
anything?
A. Yeah, the -- the two papers. One that Ronald wanted me to sign that had nothing
written on there, and then when I asked him, What is it? No, no, no. Got to hurry up.
Were running out of time, and, You want your kids to be killed.And so I signed it. And
then the next time was Dieter. Dieter had said that what Ronald did didnt work. And he
had a pre -- pre something, a paragraph that was pre-written.
Q. All right.
A. And then he, in my writing, asked me to write some things, and then he had me sign
underneath that. MR. ZONEN: Counsel? I showed you this earlier. May I approach the
witness? THE COURT: Yes.
Q. BY MR. ZONEN: Im going to show you an exhibit numbered one -- excuse me,
numbered 807 for identification, not yet in evidence. Would you take a look at that
document, please?
A. Uh-huh.
Q. Do you recognize that document?
A. Yes. Not -- just my signature.
Q. All right. Is your signature actually on that document?
A. Yes. Its actually in two different places.
Q. Do you have a recollection of signing that document?
A. Not with this on here, and not with this on here.
Q. All right.
A. And definitely I didnt sign my name twice on the same p iece of paper. And there was
no line right here.
Q. All right. Well, let me ask you this question: Is any of that your handwriting; any of it?
A. Just my signature and my -- my printed name.
Q. So the printed name, the handprinted name, is your handprinting?
A. Yes, sir.
Q. And the signature thats above that is your signature?
A. Yes, it is.
Q. Theres a second signature. Is that yours as well?
A. Yes.
Q. Now, do you have a recollection at all of signing a document twice?
A. Not -- no, two different situation -- two different things. Two different papers. MR.
ZONEN: All right. Your Honor, Im going to move this exhibit into evidence at this time.
MR. MESEREAU: No objection. THE COURT: All right. Its admitted. MR. ZONEN: And may

I publish this? THE COURT: You may.

Q. BY MR. ZONEN: Id like to read -- the very top part appears to be typed in. Would
that be correct?
A. Yes.
Q. All right. Let me read this to you out loud. Oh, you can make it larger? Perfect. I
confirm that Theodore Goddard is authorized by me to file this complaint on behalf of my
son, Gavin Arvizo. The date is Miami, February 7th, 2003. Do you believe -- do you
believe that you were in Miami on February 7th?
A. I think so.
Q. All right. Do you know who Theodore Goddard is?
A. No.
Q. Were you ever told who Theodore Goddard is?
A. No.
Q. Have you ever seen a document that had this sentence preprinted on it?
A. No, not when I was in Miami. Now, per you guyss investigation -Q. Stop right there. Thats the signature thats directly underneath it?
A. Yes.
Q. Put it down a little bit so we can get the top -- no, no, the other way. Yes. Just put it
down. We have it now with the signature thats below it. And youre telling us that that
handwrit ing is yours -A. Yes.
Q. -- and the signature is yours?
A. Yes.
Q. Do you remember a line being there?
A. No, I dont.
Q. You didnt draw a line in there?
A. No, I didnt.
Q. And you have no recollection of a line being there at the time you signed it?
A. I have no reco llection of a line being there.
Q. All right. Lets move down.Okay. Mrs. Arvizo also learned that Davellin and Star have
been on T.V. without her consent. Please act accordingly.And then theres a signature.
Did you sign that?
A. I didnt sign that, but that is my signature.
Q. All right. The paragraph that says -- that begins with, Mrs. Arvizo also learned..., is
that your handwriting?
A. No. Thats my handwriting -- thats my printing up there.
Q. All right. And the -A. Theres a difference.
Q. Okay. And that particular paragraph, have you ever seen that paragraph before?
A. Never.
Q. Now, do you have a recollection of signing any document twice?
A. On the same piece of paper? No.
Q. Did anybody ever talk to you about a lawsuit while you were in Florida?
A. No.
Q. Did anybody ever mention an attorney in England?
A. No.
Q. Did anybody talk to you about your being represented or your son being represented?
A. No.

Q. While you were there on this first day of conversations that you had with Dieter or with
Ronald or with Mr. Jackson, did anybody talk to you about the presentation of Living with
Michael Jackson?
A. No.
Q. Did you at any time learn what that was?
A. Afterwards.
Q. All right. Now, you had mentioned earlier that there was going to be a showing of -A. Yes.
Q. -- Living with Michael Jackson?
A. Yes.
Q. Do you remember when that was presented in the United States, on what day?
A. No. When I was there with him all day -Q. Yes.
A. -- that night.
Q. It was that night?
A. Yes.
Q. Of the first full day that you were in Miami?
A. Yes.
Q. All right. Did you want to go watch that?
A. Yeah, I wanted to go see what has caused my kids to -- you know, all of a sudden
theres death threats on them.
Q. Now, you said kids.
A. Yeah.
Q. Earlier -A. Yeah.
Q. Hold on, hold on. Earlier, when you were in Los Angeles, you had mentioned that the
threat was directed toward Gavin.
A. Yes.
Q. Did that change?
A. Yes.
Q. All right. What changed? Who told you that it had changed?
A. Michael.
Q. What did he say?
A. That now it was all three of my kids.
Q. All right. Mr. Jackson told you all three of your children were in danger?
A. Yes.
Q. All right. Now -A. And thats where that whole 45-minute speech -Q. When did you learn that there was going to be this presentation of a documentary
titled Living with Michael Jackson?
A. After -- after Ronald and Dieter extracted all this informat ion from me, then
afterwards.
Q. Did you know what that was? Did somebody explain to you what that was?
A. No.
Q. Did somebody explain to you that your children were in it?
A. They had mentioned that my children were in it.
Q. Did anybody tell you the manner in which they were depicted in that?
A. No.

Q. Did anybody say anything about this documentary in terms of whether it was
complimentary or not complimentary?
A. No. Zero.
Q. With whom had you talked about Living with Michael Jackson?
A. At this point, the initial meeting. Then the Ronald and Dieter with Michael. Afterwards,
let me see, they kept pulling Gavin into -- Ronald, Dieter and Gavin (sic) kept pulling
Gavin into a room by himself. I was thinking theyre talking about the press conference.
Then Michael kept pulling Gavin into a room all by himself over and over. So it was in the
midd le of the pulling Gavin into the bedroom.
Q. Okay. All right. Now, at some point you knew this was going to be on T.V.; is that
right?
A. Yes.
Q. Yes. Who was it who told you it was going to be on T.V.?
A. Actually -- actually, I had overheard Michael with Ronald and Dieter talking. I
overheard it.
Q. All right. But when did you first learn that your children were involved in this
documentary?
A. When I overheard it.
Q. All right. So they had mentioned that?
A. Yes.
Q. All right. Now, did you make an effort to go view it?
A. Yes, I did.
Q. Did you know what time it was going to be on?
A. Yes. Because I overheard it.
Q. Did you, in fact, view it?
A. No, I didnt.
Q. And why not?
A. Because when I ran down, Davellin had called me to the room and told me that Michael
was angry, to, Come now, so I went back up.
Q. All right.
A. And then Michael had talked to me and told me he didnt want me to see it.
Q. But he told you that?
A. Yes.
Q. Did he say why?
A. No.
Q. Did you ask him why?
A. No, I just -- you know, Im thinking, Theyre going to take care of my kids from these
killers. I better -Q. Were you concerned at all about the content of that documentary?
A. Its until afterwards, I found out.
Q. Im talking about now in Miami.
A. In Miami? No. I was clueless.
Q. Did you make any questions or any inquiries as to how your children were depicted in
that video?
A. Afterwards, yes.
Q. But in Miami.
A. In Miami, no.
Q. You didnt ask either of the Germans?

A. No.
Q. And you didnt ask Mr. Jackson?
A. No.
Q. And you didnt watch it?
A. No, I didnt.
Q. To this day, have you seen this documentary in its entirety?
A. Only the clips, the clips that the media elects to put on there, little clips.
Q. But you have not -A. But this is now.
Q. But you have not watched it in its entirety?
A. No, I dont want to watch it. Now I dont want to watch it.
Q. From the beginning to the end, you have not seen it?
A. No.
Q. Did you have any other conversations on this full day that you spent the day in Michael
Jacksons hotel room with Mr. Jackson, that you havent told us about already?
A. With Michael?
Q. Yes.
A. No, no. Just that -- you know, the lovey-dovey 45-minute meet ing.
Q. All right. Did you have any other conversations with Dieter or with Ronald?
A. No. After the lovey-dovey meeting, then the Ronald and Dieter meeting with him, and,
no, afterwards, no. Well, this is the best as I can remember. Oh, yeah, you know, when I
came back up from the -- from that when I went down there trying to see the Bashir
thing, so, yeah, I did.
Q. That conversation youve already told us about with Mr. Jackson, all right. Now, the
next day, did you have any conversations with Mr. Jackson?
A. No. No.
Q. All right. Did you head back to California?
A. No. Yeah, California, but not my home.
Q. Okay. Where did you think that you were going to be going when you returned?
A. Well, I figured Im going back to my home.
Q. Did you ever have a press conference while you were there?
A. In Miami?
Q. Yes.
A. No.
Q. Did they ever explain to you why you didnt?
A. No.
Q. Did either Ronald or Dieter talk about an alternative to a press conference?
A. No.
Q. Did Mr. Jackson speak to you about an alternative to a press conference?
A. No.
Q. Did you make any inquiries of anybody as to why you werent having one?
A. No. When I did start to ask questions now, thats when a lot of craziness started
happening.
Q. All right. Well, specifically with regards to Ronald or Dieter, did you make any inquiries
of them?
A. Yes, I did. And so -- and they basically would shut me down every time, because
theyre the ones taking care of everything.
Q. What do you mean by shut you down?

A. When Id ask, you know, like why d idnt we do the press conference, and it was like,
Arghh, you stupid woman, you know, and just -- it just -- it escalated.
Q. All right.
A. I -- go ahead.
Q. And their behavior -A. Escalated.
Q. -- escalated?
A. Yes.
Q. Escalated in what way?
A. Well, do you want me to go all the way to the end?
Q. Just tell me what they were saying to you. What did they say to you?
A. That they know best. Theyre the damage control team. And you wouldnt want to hear
the way they said it.
Q. Tell us what they said. Tell us what they said to you.
A. Well, Ronald telling me that he could have me erased if I make him angry. Just
different things like that.
Q. All right. Were you frightened by the things they were telling you?
A. Yes. They terrified me.
Q. Did you go back to Mr. Jackson and tell him?
A. When we initially got there to Miami, I talked to him, and his response was, Do
everything Ronald and Dieter tell you.
Q. But during -A. And that was it.
Q. During this period of time that you were at the Turnberry Hotel in Miami -A. I -Q. Hold on, hold on. You have to wait till the questions asked. During this period of time
that you were in Miami, and during this period of time that you were having conversations
with Ronald and Dieter and they were threatening you and saying things that were scary
to you -A. Not until we got at Neverland they did that.
Q. Thats my question.
A. Yeah.
Q. Did these conversations take place in Miami?
A. No, no. In Miami they were just, you know, ab -- extracting all the information
possible. Scaring me, that -- the scare was from other people, and getting -- acquiring
those two signatures.
Q. Okay. So neither one of them had threatened you personally?
A. No, not in Miami.
Q. And you have mentioned that one of them called you a stupid woman -A. Yes.
Q. -- while you were there. Who was there?
A. Actually, both of them, but Ronald did first.
Q. The other one did as well?
A. Yes.
Q. That was still in Miami?
A. No, no, this is in Neverland.
Q. All right. Its back at Neverland.
A. Miami, theyre just like, you know, Oh" you know, Were here to help you, protect

you, protect the kids.

Q. Did you fly back with everybody else?
A. At first it wasnt going to be like that.
Q. Did somebody talk to you about your flying separately?
A. Yes.
Q. Who was that?
A. Big Mike, or his head security of traveling.
Q. Do you know his real name?
A. I dont know his real name.
Q. Is that the name he goes by?
A. Thats what they were calling him, B ig Mike, and he said, Im Big Mike.
Q. Is he big?
A. Yeah, he is big.
Q. Okay. Is he the one who told you you were flying separately?
A. Yes.
Q. Where did you -- how did you understand your children would be flying?
A. Okay. He had -- he had called me and talked to -- to my room and told me that Michael
didnt want me flying back with my kids; that he wanted only my kids, and that I was
going to have to take the next-day flight out with their security. And I was like, No. And
then hes saying,Yes. And then I started crying on the phone, and because Im -- you
know, these are my kids, you know, whats going on? I expressed to him, I said, you
know, remember how you wanted -- did I express to him --I did, to Mike, Big Mike -Q. Now, you -A. -- my concerns.
Q. Did he then tell you you would be flying with everybody else, or did somebody else tell
you?
A. No, Big Mike said -- after I started crying on the phone, and he says, Im going to talk
to the boss, and Ill see what I can do.
Q. Did somebody then call you back?
A. And then Big Mike called me back and said then I could fly with the kids back to -- with
Michael and just to stay quiet.
Q. Did you, in fact, fly with them back?
A. Yes, I did.
Q. Do you know how long that flight was?
A. No, it was just hours. I dont know. MR. ZONEN: Would you put another exhibit tag on
this, please?
Q. Do you remember who any of the other people were who were on that plane?
A. Yes, I do.
Q. Tell us who they were.
A. Okay. Baby Rubba. Marie Nicole. All three of his children. Patty and Grace. A doctor
that they called -- I now know per -- theres a lot of things now I know per this
investigat ion, but back then I didnt know. I just knew him as Dr. Farsha. And my kids.
Michael. Me. One flight attendant. And thats the best I can remember.
Q. All right. Baby Rubba is who?
A. Ive come to find out now that his name is Al, A ldo, but back then he was only known
as Baby Rubba.
Q. Is he related to Frank?
A. Yes.

Q. Is Frank somebody you met prior to this time?

A. Prior to -Q. Did you know who Frank was at this time of the flight going back?
A. I had initially met him in August of 2000. Okay. Then on this -- in the Miami trip, he
didnt even talk to me. Not once.
Q. All right. But -- let me ask you this question.
A. Okay.
Q. You met him in August of 2000. That was your first trip to Neverland?
A. Yes.
Q. And he was there at that time?
A. Yes.
Q. He was introduced to you as Frank?
A. Yes.
Q. At some point in time, did you meet him in Miami? W as Frank there?
A. Yes, but he didnt talk to me at all in Miami. Zero conversation.
Q. But you saw him there?
A. Yes, I did.
Q. And was he introduced to you as the brother of Aldo and Marie Nico le?
A. No, he wasnt. Its the children that told me that that was his brother.
Q. Prior to your going back -- I assume all three of your kids are on this flight.
A. Yes.
Q. And I assume all three of your kids are with you in the hotel -A. Yes.
Q. -- in Miami.
A. Yes.
Q. Did Davellin go to New York?
A. Davellin?
Q. Yeah.
A. No.
Q. Was she on a shopping spree in New York with Marie Nicole?
A. Never.
Q. Youve never heard about this, have you?
A. No. Theres a lot of things I havent heard, and they just pop up.
Q. Was Davellin a friend of Marie Nicole prior to Florida?
A. No.
Q. Had never met prior to Florida?
A. Never.
Q. Where did you think -A. And in Miami, Baby Rubba and Marie Nicole were very -- like away from my kids. Its
until they went to Neverland that they were all, you know -- 6069
Q. Together?
A. Together, yes.
Q. All right. Now, where did you think this plane was going to go?
A. Well, I thought -- I just thought that maybe it was going to land in Los Angeles, and
then, you know, Im -- you know, and thats it.
Q. Did they tell you it wasnt going to Los Angeles?
A. No, they didnt tell me.
Q. How long did you think you were going to be in Miami when you flew to Miami?

A. Well, just enough to do the press conference - my kids are in school - and come back.
Thats it.
Q. Did you expect to be back after the press conference?
A. Yes. You know, take care of the problem, thats it.
Q. Excuse me just one moment. Do you know what day of the week it was that you
actually flew to Miami?
A. No, but it was a school day.
Q. It was a school day?
A. Because Davellin -- they had to wait till Davellin got out of school. And I had the boys,
you know.
Q. And the next day that you were in Miami, was that a school day as well?
A. I -- yes, I believe so. Im not sure.
Q. Had any arrangements been made to accommodate their absence from school?
A. No.
Q. Did you have any expectation that they were going to be absent from school for an
extended period of time?
A. No.
Q. All right. When did you first learn you were not flying back to Los Angeles?
A. On the flight.
Q. Where did they tell you you were going to be going?
A. Neverland. MR. ZONEN: May I approach the witness, Your Honor? THE COURT: Yes.
Q. BY MR. ZONEN: I show you Exhibit 808. Do you recognize what this diagram is?
A. Yes.
Q. All right. And what do you understand it to be?
A. The inside of the airplane.
Q. Excuse me. Tom, do you have a pen that will write on that? Do you have a reco llect ion
of where you were sitting at that time?
A. Yes. Some things are just burned in here.
Q. All right. So you know where you were sitting. Do you have a recollect ion of where Mr.
Jackson was sitting?
A. Yes.
Q. Do you have a recollection of where your children were sitting?
A. Yes.
Q. At different times during the course of this flight, did people get up and move around?
A. Baby Rubba, Marie Nicole were running all over the place. His kids were running all
over the place.
Q. Anybody else?
A. The -- the flight attendant was very busy.
Q. She was very busy?
A. Yes, very busy.
Q. Take a pen, if you would, please. Heres --lets do blue.
A. Okay.
Q. And if you could, put your initials in the seat where you were, please. All right. And can
you tell us where Mr. Jackson was seated?
A. Ill put his init ials or -Q. Put his init ials. Do you remember where Gavin was seated? Put Gavin.Do you
remember where Star and Davellin were seated? Shall we go on? Do you remember where
everybody else was?

A. Yeah.
Q. How about Baby Rubba, where was he?
A. Okay, over here. Thats why they were --can I write the rest?
Q. And Marie Nicole, yes.
A. And Paris and Prince. And -Q. Paris and Prince being Mr. Jacksons children?
A. Yes. And then Grace was right here.
Q. Grace is the nanny?
A. Yes. Pattys right here.
Q. Is Patty a nanny as well?
A. Yes. And Farsha, Dr. Farsha, right here.
Q. Okay.
A. And the flight attendant all over the place.
Q. Okay. All right. Is this an accurate depiction of the interior of that flight?
A. Yeah. I guess.
Q. And are the names of the different people accurately depicted where they were sitting?
A. Yes.
Q. Would you, on -- at the bottom of this, just write your first name, right at the bottom,
so well know whose exhibit that is. Good. Nice large letters. All right. Your Honor, Id
move to introduce this Exhibit 808 into evidence. MR. MESEREAU: No objection. THE
COURT: Its admitted.MR. ZONEN: May I publish this? THE COURT: You may.
Q. BY MR. ZONEN: This is the interior of this exhibit; is that correct?
A. Yes. Yes.
Q. Okay. Im going to hand you the laser, if I could, please. Press that little button right
there.
A. Okay.
Q. Now, youve indicated by the names Gavinand MJ, Star and Davellin -A. Yes.
Q. -- as your three children and Mr. Jackson; is that correct?
A. Yes.
Q. Would you show us where MJ is? Thats Mr. Jacksons seat. And does that face
directly ahead towards Davellins seat?
A. Yes, right there.
Q. And Gavin was next to him?
A. Yes.
Q. And that faces directly to Stars seat?
A. Yes.
Q. Okay. There is a JJ as were further to the right. Is that you?
A. Me.
Q. All right. And that would stand for?
A. Janet Jackson.
Q. Janet Jackson. Okay. Okay. Now, which direction was that seat facing?
A. It faces in that direction.
Q. All right. You were not able to -- from the vantage point of where you were seated, you
were not able to see -A. And then not only that, theyre really like, big in the back of me.
Q. The seats, you mean?
A. Yes.

Q. And youre not hugely tall, are you? Were you not able to see over the top of that seat,
then?
A. Yes. Theyre not like these chairs. They go past.
Q. It was up above your head?
A. Yes. MR. ZONEN: All right. Lets move that down. Yes, this direction. THE W ITNESS:
And so do theirs, too. Not just mine. MR. ZONEN: Perfect. Right there.
Q. Tell us where Dr. Farshshian was.
A. Yes.
Q. And he was facing you?
A. Yes.
Q. And Patty and Grace?
A. Right here.
Q. And lets move in the other direction. And we have what appears to be four people on
that.
A. Yes.
Q. Would you describe that seat? What -A. Its kind of like a couch.
Q. Okay. Are there armrests at all?
A. I dont remember that, but I just remember that it looked like a couch.
Q. All right. And the four of them were on that seat?
A. Yes.
Q. Now, theres another seat thats up above that -A. Right here.
Q. -- what appears to be a couch. And who sat there?
A. I dont know.
Q. Was the stewardess seated at any time?
A. No, no, the stewardess always sat in the back, because Grace would get mad at her
and throw her in the back.
Q. All right.
A. Like she had to be working, because -- and if you were not working, you go back.
Q. All right. Now, was there a person seated in that seat, the one that was directly above
from where the couch is?
A. I dont remember.
Q. Do you know if there was another person on the plane you dont recall?
A. I dont recall. But thats -- you know, I dont -Q. All right. We can take that off, and if we could turn the lights back on. Now, at some
time while you were on that plane, did you see an event that caused you concern?
A. Yes.
Q. What did you see?
A. Um, okay. (To the jury) Please dont judge me.
Q. If you could, just answer the question. Tell us what it was that you saw.
A. (To the jury) Please dont judge me. At that time I was -- I hadnt slept for so long.
When everybody had fallen asleep -- and it was hours into the flight. I hadnt gotten up,
and so -- and I figured this was my chance to look and see what had -- what was going on
back there. So I got up, and thats when I saw Michael licking Gavins head. I thought it
was me. I thought I was seeing things. I thought it was me. When we got off the airplane
and I asked my son, I asked him, Are you okay? He said, Im okay. And that was it.
Q. Do you know if Gavin was awake or asleep at the time?

A. He was asleep at the time.

Q. How could you tell?
A. Because his head was on his chest.
Q. Okay. Where was Mr. Jacksons arms at that time?
A. Like this.
Q. He had an arm around Gavin?
A. Yes.
Q. Now, I want you to describe what it was you saw. You said you saw him lick him. What
part of his head?
A. Like this, over and over.
Q. All right. What part of his head was it? Point to your head where it was.
A. Right here.
Q. Actually in h is hair?
A. Yes.
Q. And do you mean the side of his head?
A. Yes.
Q. Okay. And you said, over and over. How many times did you see that?
A. It was just over and over.
Q. All right. Are we talking about a few seconds worth or a few minutes worth? What?
A. I couldnt tell you.
Q. All right. Did you say anything to anybody -A. No.
Q. -- at that time?
A. I looked around to see if anybody was awake, to see if anybody was seeing what I was
seeing. And everybody was asleep, that I could see. Like I took a look at Patty and Grace,
and I took a look at Farshshian. They were asleep.
Q. Did you say anything to anybody at that time?
A. No.
Q. Did you ever say -A. I was never going to tell nobody.
Q. Did you say anything to anybody at any time about that event?
A. No.
Q. Who was the first person you discussed that with?
A. I didnt discuss it with anybody until like way, way after, way after Neverland -Q. Okay.
A. -- when Star had told me what he had seen.
Q. All right.
A. And then there was like -- everything went, like, backwards.
Q. Okay. Who was the first person that you told of your observation?
A. Me? I think it was the police.
Q. All right. So you had not told anybody about this -A. No.
Q. -- until a conversation with the police?
A. No.
Q. Do you remember where in this flight that happened, where during the flight?
A. After everybody had gone to sleep.
Q. Could you tell me how many hours into the flight that was?
A. No. Everybody was just sleeping, that I could see.

Q. Where did you -A. Even the flight attendant, she was like this. She was way, way at the end, and she was
like this.
Q. Okay. THE COURT: All right, Counsel. Well take our break. Is it time? MR. ZONEN: No.
THE COURT: Its not? (Laughter.) THE COURT: All right. Go ahead.
Q. BY MR. ZONEN: When did you learn what airport you landed in?
A. To this day, I still dont know what airport I landed in. I just know it was near
Neverland.
Q. Was it a small airport?
A. I couldnt tell you, because the car -- as soon as we got off the airplane, the car was
right there.
Q. Were you actually in a building when you got out of the plane or were you out on the
tarmac?
A. I dont know what tarmat is.
Q. The ground where the airplane -A. Yeah, when you got off the airplane, there was that big old long car.
Q. So you were outside when you got out of the plane?
A. We got out of the airplane, and the car was there.
Q. You got into the car?
A. Yes.
Q. And you went to Neverland?
A. Yes.
Q. Do you know how long of a drive it was to get from the airport to Neverland?
A. My best estimate is less than an hour. Definitely less than an hour.
Q. Did you know where you were going?
A. Yeah. On the airplane, thats when I found out we were going to Neverland.
Q. Did you have luggage with you and -A. Yes.
Q. -- and clothing and things like that?
A. Yes.
Q. Okay.
A. And I now know how to travel. Before I used to take just like everything, you know.
Q. All right. Now, when you got out of the plane and you went to Neverland, at some point
did you go to a residence in Neverland?
A. Yeah, Michaels house.
Q. Where did you stay that night?
A. In one of the guesthouses.
Q. Do you know approximately what time it was that you arrived at Neverland?
A. Very, very late. Again, like before morning-time.
Q. Do you mean late at night or into the middle of the night?
A. No, past the middle of the night.
Q. So its almost until dawn?
A. Yeah. And please -- also the time change. Theres a time change.
Q. All right. So did you at that point go to bed?
A. No. He had us -- he had the car stop like way at the beginning, and then we all had to
walk in the freezing night into Neverland.
Q. So you walked some distance to get -A. Yes.

Q. Along the driveway?

A. Like the pathway.
Q. All right. And did you go straight to a cottage?
A. No. We went straight into the house. And then from the house, we got our -- all our
bags, and then thats where my garbage bag was missing I had tied up to my red sports
bag.
Q. So you had a plastic garbage bag -A. Yes.
Q. -- that contained items?
A. With my stuff. And then I had put -- in the Turnberry bag, I had put my shoes inside
there, my Timberland shoes, so they wouldnt dirty the rest of my stuff.
Q. There was a Timberland bag that I assume -A. No, no. No, no. My Timb erland shoes.
Q. Im sorry, the Turnberry bag.
A. Yes, that I put my Timberland shoes in there so it wouldnt dirty the rest of my stuff
inside the garbage white bag. It was one of those big ones that I tied really tight to my
red bag. luggage that you brought with you when you went to Miami?
A. Me personally.
Q. So all of your stuff was in a garbage bag?
A. Yes, plus the red bag.
Q. Plus the red bag. But the red bag was a Turnberry Hotel bag?
A. The red bag was my bag.
Q. It was a separate bag that you had with you?
A. Yes. And the white garbage bag was tied to the handles of my red bag.
Q. Okay. All right. And that -A. I mean so tight that you have to -- I dont know when you -- if you know, but when
you tie a plastic bag so tight you cant untie it anymore, thats how tight I had it.
Q. It was not there when you got to Neverland?
A. No. No, it wasnt.
Q. And you had possessions inside of that bag?
A. Yes, I did.
Q. Did you report that to anybody?
A. Yes, immediately. I told Jesus, and then Jesus contacted Chris.
Q. Chris was -A. And then he told -- Michael became aware. And Michael said, Its okay. W ell replace
everything in there.
Q. Okay. You told Chris. You told Jesus.
A. Jesus.
Q. Jesus is Jesus Salas?
A. Yes. And Jesus then contacted Chris. And then they also looked all over in the hotel,
that maybe some -Q. Where did you stay that night when you finally went to -A. Neverland, in the guesthouse.
Q. Where was Davellin?
A. In -- in one of the guesthouses.
Q. All right. Where were the boys?
A. With Michael.
Q. Do you know where with Michael?

A. In -- now I know, okay.

Q. At the time d id you know where they were?
A. At the time, no.
Q. You knew they were in the house?
A. Yes.
Q. Did you ever walk into the house during the nighttime?
A. No.
Q. Did you ever make an effort to contact either of the boys while they were inside the
house?
A. No.
Q. Did you take your meals inside the house?
A. Me?
Q. Yes. During this time?
A. During -- yeah, you need to specify. During -- prior to leaving with Jesus, in the kitchen
area.
Q. All right. Now, when you got there on this -- at this hour, you spent the night there and
presumably woke up and left your room the next day.
A. Yes.
Q. Do you have a sense of what time that was when you finally came out?
A. I think it was -- I think it was mid-morning. I think it was morning, mid-morning.
Q. Was Davellin with you?
A. No, Davellin was with Marie Nicole, Baby Rubba.
Q. Did Davellin stay the night in your room?
A. Not in my room. In a guesthouse.
Q. In a d ifferent guest cottage?
A. Yes.
Q. Do you know where Marie Nicole or Aldo stayed, or Baby Rubba?
A. Oh, Marie Nicole stood in the room -- they have a bed over there above the theater.
Theres a bed. Thats where she slept. And Aldo and the boys, they slept with Michael.
Q. Were you expecting to go back to Neverland?
A. No.
Q. Did anybody -A. It wasnt until in the flight did I find that out.
Q. Did anybody ask you if you would go back to Neverland?
A. No, nobody asked me.
Q. Did you want to go to Neverland?
A. No, I needed the kids -- like I told you, they were in school. And I just -- just do this
press conference, take care of this, and thats it.
Q. Had they talked about some press conference? And by they, I mean either Ronald or
Dieter or Michael Jackson.
A. No.
Q. Now, once you were back at Neverland, did you see either Ronald or Dieter?
A. Yeah. Not immediately. The next day, Dieter came. Ronald came days after, like I think
a day or two or something like that. Im not quite sure. But it was Ronald the next day,
and then Dieter afterwards. I mean -- I apologize. Dieter first. Then Ronald.
Q. Was Mr. Jackson there during that few days afterwards?
A. Yes.
Q. How long did you stay at Neverland before you finally left?

A. Well, I stood until Jesus helped me.

Q. All right. Id like to show you an exhibit, if I may. Is this in evidence? (Off-the-record
discussion held at counsel table.) MR. ZONEN: Madam Clerk, let me just confirm that 405
is not in evidence. THE CLERK: It is not. MR. ZONEN: Not? Not in evidence. May I
approach the witness, Your Honor? THE COURT: Yes.
Q. BY MR. ZONEN: Showing you an exhibit at this time for identificat ion not in evidence,
No. 405, Id like you to take a moment and read it, if you would, please.
A. Okay.
Q. Its a full page. Take your time to go ahead and read it to yourself.
A. Okay.
Q. When youre done, just set it down.
A. Okay.
Q. You have completed read ing this; is that correct?
A. Yes.
Q. All right. Do you know who Bell Yard is?
A. No.
Q. Does this appear to be a press release?
A. I dont know.
Q. All right. Are you quoted in this document?
A. Yes.
Q. Have you ever made those quotes?
A. No.
Q. Did anybody ever interview you as to the content of this document?
A. No.
Q. Have you ever seen this document before?
A. No. Right now.
Q. This is the first time youve seen it?
A. Yes.
Q. All right. Its attributed to Janet Ventura-Arvizo; is that correct?
A. Yes.
Q. The date is Sunday, the 9th of February, 2003?
A. Yes.
Q. Did anybody contact you on that date about releasing any kind of a press conference -a press release?
A. No. MR. ZONEN: Your Honor, I would move to introduce 405 into evidence. MR.
MESEREAU: Objection. Hearsay; no foundation. THE COURT: I dont think there is a
foundation. I was looking. It was identified on March 2nd, but I cant recall who identified
it. MR. ZONEN: It was Ann Gabriel, I believe. Let me withdraw the introduction of this
until we can do this at another time, for the convenience of the jury. We can debate the
issue at that time. THE COURT: That would be good.
Q. BY MR. ZONEN: How many days did you stay at Neverland?
A. I cant remember. Unt il Jesus helped me.
Q. Give us a sense of it. Two days? Five days?
A. No.
Q. Do you have a sense of it at all?
A. No, I dont have a sense of it.
Q. Okay. And you say that Jesus helped you leave?
A. Yes, he did. And he got into it before that.

Q. Hold on. Listen to the question that I ask and only answer that question, if you would.
Okay?
A. Okay.
Q. Now, did you ask anybody to -- did you ask anybody to take you back to Los Angeles
before going to Jesus?
A. No.
Q. Did you express to anybody a desire to leave Neverland?
A. Yes.
Q. To whom did you -A. To Ronald and Dieter.
Q. To Ronald and Dieter?
A. Yes.
Q. Was Mr. Jackson present during the entirety of that time?
A. Yes.
Q. For the period of time until Jesus took you -A. Yes.
Q. -- home? When you asked Ronald and Dieter to leave, what did they tell you?
A. That I had -- no, because I had to do the rebuttal.
Q. Ahh, all right. A rebuttal?
A. Yes.
Q. Was this the first time that you had any information about a rebuttal?
A. Right on.
Q. All right. And who was it who first spoke to you about a rebuttal?
A. It was Ronald and Dieter.
Q. Together?
A. Yes. First it was Ronald. And then it was Dieter, and then it was both, and they -- you
know, they took turns.
Q. You had multiple conversations with them?
A. They were preparing us for that.
Q. Okay.
A. Which I d idnt know.
Q. What do you mean, preparing for you that?
A. They had this -- this thing that I guess --they had extracted all the information from
us. It was like a script.
Q. They got information from you. Do you mean about your family?
A. Back in Miami.
Q. All right. But -A. And whatever else they did.
Q. Did anybody ever talk to you about a rebuttal while you were in Miami?
A. Never.
Q. So it wasnt until you got to Neverland?
A. Yes.
Q. Who was the first one to broach that subject with you?
A. Dieter.
Q. Did Michael Jackson talk to you about doing a rebuttal?
A. No. When I spoke to him, he said, Do everything that Ronald and Dieter tell you, and
it will fix everything.
Q. Did you have any conversation back at Neverland with Michael Jackson at all?

A. The initial -- when I first got there, I expressed it to him, and he said, Do everything
that Ronald and Dieter tell you to do.
Q. What he had previously said in -A. Yes.
Q. -- Miami -A. Yes.
Q. -- he said again?
A. Yes.
Q. Did you express to him your concerns at that point about Ronald and Dieter?
A. No.
Q. Did you have concerns about Ronald and Dieter at that point?
A. Yes. It escalated towards the middle-end.
Q. What did either one of them tell you about this rebuttal? What did they tell you that
was going to be?
A. In answer to -- in answer to everything of the Living with Michael Jackson. They were
concerned about how he looked. They werent concerned about my children, me, anything
else. Only him.
Q. Did they explain to you what the rebuttal had to do with your childrens safety?
A. Yeah, That - this is another phrase - that would appease the killers. I heard that so
many times here, its just -Q. All right. Somebody actually used the word killers?
A. Yes.
Q. Who?
A. Him. Michael. Ronald. D ieter. Later on, Frank, Vinnie. And you know what? They ended
up being the killers.
Q. All right. I want you to listen to the question thats being asked, and only ask that
question -- answer that question.
A. Okay.
Q. Answer this question only, all right? Now, who was the first person who mentioned to
you killers?
A. Michael.
Q. Where was that?
A. That was in Miami.
Q. Now, the rebuttal, did you know what you were doing a rebuttal to?
A. On all -- the answer to the questions of this Living with Michael Jackson, Martin
Bashir.
Q. Now, you hadnt seen it; is that correct?
A. I hadnt seen it.
Q. Did somebody explain to you the content of that?
A. No. They just -- it was a script, and that was it, and expressed -- worked with us daily,
numerous times, on what to do, what to do in between the outtakes, what to do before,
and thats it.
Q. Who was it -- who talked to you about a script?
A. Dieter.
Q. Did he show you one?
A. Yes.
Q. Something in writing; is that correct?
A. Yes.

Q. Did he present this script to you that you were actually able to read it?
A. Yes.
Q. What types of things were on the script?
A. Just glowing things about Michael.
Q. Did he say to you why glowing things about Michael would protect your children?
A. Yeah, That that would appease the killers.
Q. All right. Now, did you tell them that you would do this rebuttal?
A. No. Prior to Jesus, it was a no.
Q. And why did you say no?
A. Because I told them, Whats wrong with the truth? And thats it.
Q. All right. Now, did you -A. I had no problems saying something nice, you know.
Q. Did they tell you -A. But when I had a 45-minute powwow when I got here, I believed everything he said.
Q. Did they tell you that this rebuttal would have not just you, but your children in it?
A. At Neverland?
Q. Yes.
A. Yes.
Q. So who was it who told you that the rebuttal would feature all of you?
A. Ronald and Dieter.
Q. Why did you go to Jesus?
A. Because after asking them to leave so many times and they wouldnt let me leave. And
then they were all working on a positive PR for Michael. They also wanted to point out how
they were doing things for the mother and the kids. It was -- they were going to use it -it went back and forth, and then they were going to use it in lieu, like -- also, like, they
dont think that they were going to put out there. Theyre crazy. So that was -Q. You dont remember the question, do you?
A. No.
Q. I dont either.
A. I thought there was -Q. Why did you go to Jesus?
A. To help me.
Q. Okay. And did you talk to him about helping you?
A. Yes.
Q. All right. And in what language did you speak with him?
A. I spoke to him both in English and Spanish.
Q. Why is that? Why did you speak in Spanish?
A. Well, because I was very concerned about anybody hearing.
Q. What did you ask Jesus to do?
A. To help me leave, me and the kids.
Q. What did he tell you?
A. He says -- because I had told him that they werent letting me go. And he says that,
No one should ever be held if they dont want to stay there.
Q. And did you leave?
A. Yes, I did.
Q. All right. Now, during that period of time that you were at Neverland before you left
with Jesus, did you go anyplace out of Neverland?
A. Yes, I did.

Q. Where did you go?

A. Ronald and Dieter said, like I told you about Michaels positive PR, and they wanted to
show that hes doing things for the mother and the kids. And, you know, so -- they had
me so wrapped up. I believed everything they said.
Q. Miss Arvizo?
A. Yes.
Q. Where did you go?
A. Okay. I went to, like, a beauty place. And, oh, but get this.
Q. Miss Arvizo?
A. Im paying for it.
Q. Miss Arvizo?
A. Thats right.
Q. Where did you go?
A. Okay. I went and got my legs waxed.
Q. Okay.
A. And the key thing there -Q. Hold on, hold on.
A. -- Ill pay for it, because it was in rep lacement of my things.
Q. All right. I want you only to answer the question thats asked of you.
A. Okay.
Q. I want you to listen to the question thats asked. Would you do that?
A. Sure.
Q. Okay. You went to a beauty salon of some nature; is that right?
A. Yes. Yes.
Q. Did you have a body wax?
A. No.
Q. All right. You had your legs waxed?
A. Yes.
Q. What else?
A. Thats it.
Q. All right. Whose idea was it to do that?
A. Ronald and Dieter.
Q. How did they come up with a beauty parlor?
A. Because they wanted to show that they were doing something for the mother. Positive
PR.
Q. Okay. Now, you said you paid for it.
A. Yes.
Q. In what way did you pay for it?
A. Because I -- I told them, The only way I m going to do that is if you deduct that from
the things that were lost or stolen. W ho knows?
Q. Okay.
A. In replacement of that.
Q. Was that agreed to?
A. Yes.
Q. All right.
A. They said, Okay.
Q. Who is it who took you there, to a location?
A. Chris.

Q. It was Chris Carter who took you there?

A. Yes. And then their little surveilling people.
Q. There were other people that came with you?
A. Yes. Yes, their little surveilling filming people.
Q. Where were your children during that time?
A. With Michael.
Q. Did you -A. The boys were with him, you know.
Q. Did you return back to Neverland?
A. Yes, I did.
Q. Okay. Was that the day that you left?
A. I think it was, because I figured, you know what? Thats it. Thats enough. They got
their
positive PR, and now maybe I can go.
Q. You went to Jesus?
A. No. After, the Germans are following me every sing le place.
Q. Then you went to Jesus?
A. I waited till they fell asleep, and then I went to Jesus.
Q. Did Jesus agree to take you off the property?
A. Yes. Yes.
Q. Did he drive you and your children home?
A. Yes.
Q. Where did you go?
A. To my moms. They had me scared about going to my mom -- to my own place.
Q. What did they tell you about your place?
A. That the killers had been there, that it had even been broken into. I believed
everything they said. Now -- now I dont.
Q. This is the Soto Street residence?
A. Yes.
Q. All right. Did -- did you ask Jesus to take you to your parents place?
A. Yes.
Q. And did he, in fact, take you there?
A. Yes.
Q. Did you tell either of the two Germans, Dieter or Ronald, where your residence was?
A. The East L.A.? Yeah. Oh, they took care of all of that in Miami. Found out every detail.
Q. They knew where the Soto Street residence was?
A. Yeah. And plus, you know, Michael knew before that.
Q. Okay. He had picked up your children from that residence?
A. Yeah, and I had lived there for almost already five years.
Q. All right. Now, when you went to your mothers residence, you stayed there how long?
A. I cant remember. But I remember Frank convincing me that its too scary to stay
there.
And I figured my parents are old, and so I went to Jays house.
Q. With your children?
A. With my children.
Q. All right. Did -A. But I still didnt want to go back to Neverland.
Q. So you went to Jays house?

A. Yes.
Q. And you stayed there for approximately how long; do you know?
A. I dont know.
Q. Were you getting any telephone calls while you were at either your mothers house or
at Jays house?
A. Yes, a lot.
Q. From whom?
A. From Frank. And then Michael had called once and spoke to the boys, and to Gavin.
Q. Mr. Jackson?
A. Yeah. At this point, I think hes still a -Q. Mr. Jackson phoned personally?
A. Yes.
Q. Was this at your mothers house or was this at your -A. My moms house.
Q. Do you know how long after you returned from Neverland it was that Mr. Jackson called
your mothers house?
A. Almost immed iately. And spoke to both boys. And then to Gavin. But Frank, oooh, all of
the time.
Q. You say all of the time. What does that mean?
A. Oh, gosh, a lot.
Q. What was he saying?
A. That he loves us, Michael loves us, and, you know, loves -- he wants to protect us. Im
in so much danger, me and the children. Just -- just everything in those kind of topics.
Q. Did he describe the danger?
A. Yeah, he said that, You dont know, Janet. Were receiving constant death threats here
about the children. You know, I believed him.
Q. And he was telling you this in your conversations?
A. Yes. Yes.
Q. All right.
A. But there was so many conversations.
Q. When Mr. Jackson actually phoned -A. Yes.
Q. -- did you talk with him at all?
A. No. No, Frank had already done the legwork for him, let him know.
Q. The question was only whether or not you had spoken with Mr. Jackson.
A. No.
Q. When you went to Jay Jacksons home, this is the one on St. Andrews Place?
A. Yes.
Q. In mid-Wilshire in Los Angeles?
A. Yeah, he has a -- had a one-bedroom apartment.
Q. Did the phone calls continue there?
A. Yes.
Q. Were you calling Frank back? Was he leaving messages? Were you returning his call?
A. The ones I returned, probably maybe -- at that time, before returning to Neverland? I
think maybe -- maybe once. Once or three times. Very -- definitely less than five. The rest
were all him.
Q. Did you believe there was a danger to -A. And thats maybe.

Q. Did you believe there was a danger to your children at that time?
A. Yes, I believed them. (To the defendant) I believed you.
Q. Did Frank, in any of his conversations with you, tell you who it was who posed a danger
to your children?
A. No. The killers, you know. Now when somebody knocks, I say, Okay, its either a
subpoena or a killer.
Q. All right. Did he ever discuss any other matters with you over the telephone?
A. Yeah. Yeah, how much that Michael loved the kids and me. And then about doing this
video. And I had told them no, because Dieter and Ronald had scripted it, and so they
wanted us to say exactly what they wanted us to say for -- what they wanted us to
exactly say.
Q. During this period of time that you were back in Los Angeles - all right? - after Jesus
drove you away from Neverland, d id the kids go back into school?
A. No.
Q. Why not?
A. Because I really believed them. I did.
Q. Believed that there was what?
A. Killers.
Q. Danger?
A. And then afterwards, I came to find out from Mr. Davie that honestly no reporter ever
came to my childrens school.
Q. Were you dealing with reporters at all during this period of time after you came home?
A. When I came home, all I saw was my moms tables filled with offers, filled with
different offers. Vacation, money, cars. You name it, it was there. It was there. And so
before I had gone to my moms Ronald, Dieter, Michael had filled my head that there was
reporters all over the place, and the killers were, you know, every place I was. I really
believed them. And so when I got my to moms and saw the table filled, you know, I
thought they were telling
the truth.
Q. Hold on. Now, the table was filled with what, documents?
A. Yeah.
Q. What kind of documents?
A. Letters. Different letters making offers, making -- for a story, interviews.
Q. With you?
A. With the children, with me, or both.
Q. All right. Did anybody actually call and contact -- and talk to you while you were
there?
A. The phone was ringing like crazy, so I would pick it up and pretend it wasnt me, you
know, just in case it was one of my parents family members, because my mothers
mother has Alzheimers, so my mom and her sister, or a combination, they take care of
her, so, you know -Q. All right. Did you have an opportunity to look at any of those documents?
A. Yes, I did.
Q. All right. And I think that you said that there were offers amongst them?
A. Yes. Yes, there were.
Q. Offers for money?
A. Money, cars, vacations. Just you name it.
Q. Any of them contain dollar amounts?

A. Yes, they did.

Q. How much?
A. One was 100,000 cash.
Q. To do what?
A. To give a story about Gavin.
Q. All right. Did you assume that it was a story about Gavin with regards to Michael
Jackson?
A. Yeah. They were very clear on what they wanted. There was -- the only people that
were vague was those two reporters way in the beginn ing.
Q. Okay. But these offers dealt -A. They were very clear.
Q. In other words -A. And some were just, you know, Basically we want to talk, thats all. Not all of them.
Some of them were just, I want to talk. Thats all.
Q. Did you call any of these reporters?
A. No, I didnt.
Q. Did you have a telephone conversation with any of these reporters?
A. No.
Q. Did you commun icate -A. Other than the one that said Gavin and all that stuff.
Q. I understand. Did you communicate with any reporters to the extent of telling them
that you were willing to do a story -A. No.
Q. -- and accept payment?
A. Huh-uh, huh-uh.
Q. Did you accept payment from any reporter?
A. No.
Q. Have you given a story to any reporter?
A. No.
Q. And to this day have you?
A. Till this day.
Q. Do you have any arrangement to do a story at some time in the future?
A. No.
Q. Do you intend to give a story?
A. Huh-uh. THE COURT: Is it time for a break? MR. ZONEN: I believe so.THE COURT: Lets
take one.(Recess taken.) THE COURT: Go ahead.
Q. BY MR. ZONEN: Miss Arvizo, Ive been asking you about a series of phone calls that -THE BAILIFF: Turn on the microphone, please.
Q. BY MR. ZONEN: Miss Arvizo, Ive been asking you about a series of telephone calls
that you received from Frank, and I asked you, I believe, if anybody else had called you
about this same issue. Your answer was what?
A. About -Q. About this matter of returning back to Neverland.
A. Yeah, Michael.
Q. And, okay, anybody else beyond that?
A. Beyond Frank?
Q. Yes.
A. No.

Q. Did he ever talk about any other matter other than that issue, the danger to the
children
returning to Neverland -A. Yeah.
Q. -- and the rebuttal?
A. Yeah. And also, you know, about the media, that they were all bad people. And, you
know, they -- they made me believe that. (To the audience) I think different of you guys
now. That -- thats what they made me believe about you guys, but, you know, you guys
are basically good guys, too. You guys are the good side. Its okay.
Q. Miss Arvizo, at some point in time, did you have an opportunity to listen to a taperecording of one of those telephone calls?
A. Yes, I did. Yes.
Q. Were you aware that one of those telephone calls was actually tape-recorded?
A. No, I wasnt aware.
Q. Do you recall who it was who played that tape-recording for you?
A. The D.A.s Office at the grand jury.
Q. All right. Was it just prior to the grand jury that you heard it for the first time?
A. It was right prior to the grand jury.
Q. All right. And was it played during the grand jury?
A. It was played during the grand jury.
Q. And you had an opportunity at that time to listen to that tape-recording in its entirety,
did you not?
A. Yes.
Q. All right. Do you remember what specific phone call that was?
A. It wasnt one specific phone call. It was many conversations, and the masters of
choreography blended it all into one tape.
Q. I want you to just answer the question that I ask you, all right? It was more than one
telephone call; is that true?
A. Yes.
Q. How do you know that?
A. Because Im the one talking.
Q. You simply remember that it was -A. That, and also the key thing such as, you know, my being at my mo ms, being at Jays,
theres a difference. My children all not being there, and then Gavin being there. Just
different little clues. Since I was the one talking, I knew. And also, one key thing. The
original phone number that -- that Frank had given me was very different than the
conversation that ended up being on the tape. And that -- that number was actually
towards more over here rather than in the beginning.
Q. Im not certain I understood that. There was -A. There were many conversations blended onto one tape and made as if it was only one
conversation. So youre going to hear a series of different conversations all blended into
one.
Q. You said there was a phone number that Frank gave you. What did that mean?
A. That phone number, the 201 number, was not the one that was originally given to you,
it was a different number, thats why I know.
Q. 201 being the area code?
A. Yes, sir.
Q. Did you dial that number to talk to Frank?

A. No. Not at that time.

Q. At any time during this period while you were in Los Angeles, before returning to
Neverland?
A. Okay. Before returning to Neverland, Im seeing -- Im being generous. Maybe if -maybe less than three, less than five. And I -Q. Less than three, less than five what?
A. Of if I ever returned a phone call.
Q. You think you might have returned -A. I may. I may.
Q. You might have returned a phone call to him?
A. Yes.
Q. And perhaps as many as three or five?
A. And Im guessing one. 6111
Q. Do you have -A. But, yeah -- after.
Q. Do you have a specific recollection of ever returning a phone call to him?
A. I dont remember. It was -- because he was calling so much, there was no need for me
to return
7 a phone call -Q. All right.
A. -- at that period.
Q. Was he leaving either voice mail messages or answer phone messages when he
called?
A. At that time, I was picking up the call, and there was also some phone messages.
Q. Did you -- can you give us a sense of how many conversations you were actually
having with Frank in any given day?
A. With Frank? Okay. On the -- oh, God, no, I cant.
Q. Was the subject of the video, doing the rebuttal, was that something that was
frequently
discussed in those phone calls?
A. This is when he was pulling me back in. MR. ZONEN: Your Honor, we have marked -we
have marked Exhib it No. 809 as a tape. Actually, its on the form of a CD that we would
like to play at this time. (Whereupon, a CD, Plaintiffs Exhibit No. 809, was played for the
Court and jury.) MR. ZONEN: Your Honor, we have a transcript, and we will furnish a copy
of that transcript tomorrow morning. BAILIFF CORTEZ: The microphone, sir. THE COURT:
Again. MR. ZONEN: We have a transcript of that tape as well. We will furnish the Court a
copy of that transcript as a separate exhibit tomorrow morning. THE COURT: All right.
Q. BY MR. ZONEN: Ms. Arvizo, youve now listened to this tape. Is this, in fact, the same
tape that you previously listened to?
A. Yes.
Q. And you have listened to this tape as well during the course of the grand jury
hearings?
A. Yes.
Q. You believe that this is a compilation of a few telephone calls?
A. Yes.
Q. What were your feelings about Frank at the time of these phone calls? What did you
think of him?

A. Well, I -- I thought he was a good guy. And he ended up being the worst one out of all
of them.
Q. At the time of these telephone calls, you
27 had trust in him?
A. Yes, because he was repeating the same things. Not identical, but he was repeating the
same things that Michael had told me in the Miami thing; that we were family. He had said
that family never leaves family behind.
Q. Did you believe that to be the case?
A. I did. I believed him.
Q. Michael Jackson you had only met on one previous occasion?
A. Thats right. But because he was going -- I knew vio lence, and so when he presented to
me that there was a violence to my son and my kids, I thought, you know, what a nice
guy.
Q. Did you believe Frank with regards to the things that he told you in these telephone
calls?
A. Im sorry, what did you say?
Q. Did you believe Franks representations to you during the course of these phone calls?
A. Yeah, I did. I did.
Q. Did you believe that you would be sheltered from the Germans if you returned?
A. No, I didnt return until he told me that they were fired. I believed everything he said.
Q. What did he tell you specifically about the Germans?
A. That Michael had them fired. He found out how they were treating the kids and me, so
that Michael fired them.
Q. He asked you on a few occasions during these telephone calls if it would be okay to
post a 24-hour guard outside your home.
A. Yeah.
Q. Is that the case?
A. And I said no.
Q. Did you tell him no repeatedly?
A. Yes. There was many conversat ions.
Q. Did you ever have a guard posted outside your house?
A. Never.
Q. Why did you turn that offer down?
A. Because I didnt want my parents to know. I had always hidden everything from my
parents.
Q. You didnt want your parents to know what?
A. Because I didnt want them to get scared, because theyre older. Ive never told my
parents about anything. I mean, they barely know now many things.
Q. All right. Now, I think you said that there was never a guard that came; is that true?
A. Thats right.
Q. When did you decide to return back to Neverland?
A. When -- when Frank convinced me.
Q. In the tape, he mentions a couple times about doing a video. Is that the rebuttal video
that you referred to?
A. Yes. And every time I said no.
Q. On one occasion in here, you do tell him that youd be willing to do that, do you not?
A. Yeah, as long as its not a script, because the Germans wanted to me to say exactly
what they dictated.

Q. Were you willing to say something at that time that was positive -A. Yes.
Q. -- about Michael Jackson?
A. I was.
Q. At that time, did you have anything to say about Michael Jackson that was negative?
A. No.
Q. Did you tell him youd be willing to do that?
A. Yes.
Q. You have references in this interview, or, excuse me, conversation or conversations
about Michael Jackson and Frank being family.
A. Yes.
Q. What was that about? A. Because I believed him.
Q. Im sorry?
A. I believed him.
Q. And Frank was also making those representations to you?
A. Yes. I wanted friends so bad.
Q. You wanted friends?
A. I did.
Q. And why is that?
A. Because David always told me nobody loved me.
Q. You had talked about David with Frank on these conversations, did you not?
A. Yes, I did.
Q. Did you tell him everything that had happened with regards to -A. He already had known. I was just gathering. (To the defendant) I was still trying to
help
you. I was gathering paperwork to prove of David committing these crimes on me and my
kids and my animals.
Q. You were gathering up paperwork for what purpose?
A. To give it to you.
Q. You need to address the question only.
A. Michael.
Q. Why were you gathering up paperwork for Mr. Jackson?
A. Because David was interview after interview and after interview; so they could know
that hes a liar.
Q. All right. You need to explain this to me. David is David Arvizo -A. Yes.
Q. -- your former husband?
A. Yes.
Q. You say he gave interview after interview after interview?
A. Yes.
Q. With whom?
A. With different reporters. This is what Ronald and Dieter had told me.
Q. And somebody had spoken to you about the interviews that David Arvizo is doing?
A. Ronald and Dieter did at Neverland.
Q. And what did they say to you about those interviews?
A. That David was talking bad stuff about me and the children.
Q. About you and the children?
A. Yes.

Q. All right.
A. And about Michael.
Q. Did somebody ask you to gather up paperwork about David?
A. No, I was just trying to help.
Q. And why did you gather up paperwork for them about David?
A. Just the paperwork, the restraining orders, everything that the court had given me.
Q. What was your purpose for doing that?
A. Well, so that we can have proof that this -- everything that this man is saying from his
mouth is untrue. David.
Q. What time was it during the day or evening that Jesus Salas drove you back to your
parents house?
A. I think -- I dont know. Maybe about one- something a.m.
Q. It was in the early morning hours?
A. Yes. About 1:15.
Q. Did you talk with Michael Jackson before being driven back to your parents house?
A. No.
Q. During the entire time that you were in Los Angeles, either at your parents house or at
Jay Jacksons residence, were the phone calls continuous during that time?
A. Yes.
Q. What finally was it that caused you to decide to return to Neverland?
A. When Frank had said that Michael had fired the Germans.
Q. Was there an understanding about whether or not you would be doing a video once you
got back?
A. No.
Q. You hadnt talked about that?
A. No. At that point, no. It was just -Q. What was your belief about whether or not you would be doing a video?
A. There was -- there was none. He had said that I didnt have to do it after all.
Q. Did you express to him some reservations about doing it?
A. No, he -- I had told him that the Germans wanted to dictate exactly what we wanted to
say, so I was -- I told him no. And so afterwards, towards when -- the end, Frank had said
that, okay, that I didnt have to do it at all, me and the kids.
Q. Did you go back to Neverland?
A. Yes, I did.
Q. Do you know approximately what time of the day or evening it was?
A. The daytime. Gary came for us.
Q. Before going back to Neverland, did you have an interview?
A. Yes.
Q. With whom?
A. With Brad Miller.
Q. Did you know who Brad Miller was?
A. No.
Q. Had you ever seen him before?
A. No.
Q. Was it prearranged that you would have an interview with him?
A. Yes. Yes.
Q. And who had arranged that?
A. Frank.

Q. Now, you were still in Los Angeles; is that right?

A. Yes. In Jays apartment.
Q. And how long prior to that interview was it that you had arranged it or Frank had
arranged it with you?
A. Hours.
Q. So it was the same day?
A. Same day.
Q. Did he tell you the purpose for this interview?
A. Yeah. He had called me like in a state of panic, and he was telling me, Quick, Janet,
quick. We need you to talk to Bradley Miller because hes a P.I., and he just saw -- he
just saw David make contact with the killers. And then hes -- he told me about how
important it is to say nice things about Michael and that Michael was going to protect me
and the kids.
Q. Did you believe it?
A. I believed it.
Q. Did you feel the kids were in danger at that time?
A. Yes, I did.
Q. Why did you agree to have an interview with Brad Miller?
A. Because I believed him.
Q. At which locat ion was this interview?
A. In Jays apartment.
Q. And did he arrive by himself, Mr. Miller?
A. Yes, he did.
Q. Did he identify himself to you?
A. Yes, he did. Michaels P.I.
Q He told you he was a P.I.?
A. Michaels P.I.
Q. Youve had an opportunity to listen to a tape-recording of that interview, have you
not?
A. Yes, I have.
Q. Do you recall at some point during the course of that interview him turning the tape
off?
A. Yes.
Q. Do you know why?
A. I had walked in for that second, and then I had walked back out right after he had
turned it back on, and he said that -- that -- heres that phrase, to say nice things about
Michael, because that would appease the killers. That phrase is burned in my brain.
Q. And were you in the room during the entirety of that interview?
A. No. I kept coming in and out, because Jay in the beginning, he was kind of like very -now hes softened up, but before, he was very military, very -- everything had -everything was organized, everything was -- his things were his things. And so I noticed
that he was kind of getting a little upset, because he was walking back from the -- from
the living room where we were at into his bedroom, so I was kind of nervous that he was
getting upset, so Q. So you were checking on him periodically?
A. Yes. Yes.
Q. Do you know how long that interview went?
A. It -- I since have seen the transcript to it, and it shows an ending time, and the ending
time is inaccurate. Its incorrect.

Q. What do you think is the length of that interview?

A. The length of the interview from when he was there is -- its about an hour, a little over
an hour, but the time that it has on the transcript doesnt reflect that.
Q. Did Mr. Miller explain to you why he was there?
A. Yes. For what Frank had said. The same purpose.
Q. Did he give you any instruction as to what to say before turning on the tape-recorder?
A. Yeah, he fed us. Sometimes we would rewind, stop, rewind, stop. And so he was
feeding us, but everything I said, I said it with my heart.
Q. All right. And you said nice things about Mr. Jackson, did you not?
A. Yes, I did.
Q. And did you believe those things at that time?
A. Yes, I did.
Q. You would have said those things even if he hadnt rewound the tape-recorder?
A. Thats right.
Q. Did you then go back to Neverland?
A. Yes, I did.
Q. Did Mr. Miller talk to you about going back to Neverland?
A. No, he didnt.
Q. Who was it who made the arrangements for you to return to Neverland?
A. Frank.
Q. Do you know if that was the next day?
A. That was the next day.
Q. When you got back to Neverland, what did you see?
A. And another thing, too, that I seen, which I wasnt that correct on, I noticed that there
is --the only way I can know this is because when Chris Carter brought me back,
immed iately the phone -- the phone stuff was subpoenaed, so on the day that I used
Chris Carters phone is the day that -Q. Were jumping ahead of ourselves.
A. Well, okay. I feel the date may be incorrect also. But the only reason is because I found
out afterwards of that phone call.
Q. Were going to get there. Were going to get there. Youre back in Los Angeles. Who is
it who brought you back to Neverland?
A. Gary Hearn.
Q. Did you go with your children?
A. Yes, I did.
Q. Do you know what time it is, approximately, that you arrived at Neverland?
A. I think it was the afternoon.
Q. What did you see when you got there?
A. Ronald and Dieter.
Q. Did that surprise you?
A. Minutes -- minutes into being inside the house.
Q. Which house?
A. Michaels house.
Q. Did you go to his house soon after arriving at Neverland?
A. Yes.
Q. Did you see if Michael Jackson was there?
A. Yes. I saw him. He went straight to my kids.
Q. And where did your kids go?

A. With him to his office.

Q. All three of your kids?
A. Yes. And then I saw Davellin, and then she went back in. But they were in his office.
Q. Did you speak with Mr. Jackson at the time that you arrived?
A. No.
Q. Did you see the two Germans, Dieter and Ronald, immed iately?
A. Yes.
Q. What did you do when you saw them?
A. I knew now that Frank had been lying to me the whole entire time.
Q. What did you do when you saw them?
A. I told them that I had an emergency and I have to go back home, me and the kids
have to go back home.
Q. And who did you say that to?
A. I said it to Ronald and I said it to Dieter.
Q. What did they say?
A. They said no, I couldnt; that the kids have to stay. If I have an emergency, I can go,
but the kids had to stay. And that at this point is when they had pointed out to me that
my outside phone calls are being monitored, that Im being watched, listened to, and they
can make my kids disappear.
Q. Was this the first time -A. And that anybody -- anybody I told -- and at this time Im like, what am I going to tell?
That were walking across the grass? You know, what am I going to tell? And that anybody
that I told, their life was going to be in danger.
Q. Did you make a decision at that time as to whether you would leave?
A. Yes.
Q. What was that decision?
A. Because thats the only way I could get out because the other time it took -- it took a
long process for me to leave. And this time, Jesus had told me he couldnt help me.
Q. What was that decision that you made? To leave?
A. To leave.
Q. To leave, all right. Did you speak to anybody else other than Ronald and Dieter about
leaving?
A. Yeah, well, Jesus, I asked him for help. We went from the -- from the video place, tried
to talk -- I tried to talk secret with him in Spanish because I was talking to him in English
and thats when Dieter had walked up, and then I -- and then I tried to talk to him in
Spanish. And we went to the train station, and we went up -- up to the -- way up on the
top, and I tried to talk to him, plead for him to help me, and he said he couldnt help me
anymore, because when I had -- when I had left, the whole house turned into chaos.
Q. Did you ask him specifically to take you back to Los Angeles?
A. Yes, I did. Me and the kids.
Q. He told you no? What did he tell you?
A. That he couldnt; that to ask Chris for help, because he doesnt know, and -- and I
found out that everybody was on a need-to-know basis; that not unless they stumbled
upon the problem or they were pulled into it, other than that, everybody was clueless.
Q. Okay. All right. Did you go talk to Mr. Carter?
A. Well, what happened was, when -- I was going to look for him, but I didnt have to -have to look for him, because I happened to see him, so --and that was Jesuss advice.
Q. Did you know Chris Carter from a prior visit?

A. Yes, from when I was there. Hes Michaels personal bodyguard.

Q. Was he somebody who had been nice to you in the past?
A. Yes, he was.
Q. Did you go up and ask him if you could leave?
A. Yes.
Q. Did you ask him if your children could as well?
A. I did mention it to him, but thats when I seen the Germans again, so I completely, you
know, pshooo, played it off; it was just an emergency.
Q. Did he say he would take you?
A. Yes, he did.
Q. And did you leave?
A. Yes, I did.
Q. Did you leave with your children still at Neverland?
A. Yes.
Q. Why did you do that?
A. Because I did. Because of the reasons that I just told you.
Q. Now, you mentioned earlier that in the drive back to Los Angeles, you used Mr. Carters
cell phone?
A. Over and over. And I used the phone inside your car.
Q. Who were you calling?
A. Calling Jay over and over. But -- and I was praying in the car. And -Q. Were you scared?
A. Yes.
Q. What were you worried about?
A. That they were going to make true on everything that they had said.
Q. Were you able to reach Jay on the telephone?
A. No.
Q. Where did Mr. Carter take you?
A. To Jays.
Q. And did he drop you off there?
A. Yes.
Q. Do you recall at approximately what time you arrived?
A. Oh, I dont know, but that -- that telephone call is -- you could see it on the
subpoenaed phone record.
Q. Whatever time that is would be the time that you were in the vehicle?
A. Thats the time. Thats the time.
Q. Do you remember how many phone calls you made to Jay during that time?
A. A lot of them.
Q. At one time during the course of this phone conversation or conversations that we just
listened to, Frank mentions a trip, going someplace; says youll be dancing every night.
Do you remember that conversation?
A. Yes, I do.
Q. Did you have more than one conversation with Frank about going someplace?
A. Yeah. They wanted us to leave the country.
Q. Did they tell you where they wanted you to go?
A. Well, this is in Neverland, when I -- and I found out that they were monitoring my
phone calls inside Neverland. They had first mentioned Austria. And so I had mentioned it
to -- to Jay, I think it was Jay, over the phone, and then they came in hollering, because

nobody was supposed to know. Then they found out that I had -- that I knew Spanish and
was a Spanish-speaking country, and the end result was Brazil, so I knew that they
wanted me out of the country since then.
Q. All right. They were talking about going to Brazil?
A. Yes.
Q. Theyd actually begun that conversation prior to Jesus taking you out?
A. Prior to Jesus.
Q. And during the phone calls that you had with Frank, did he mention that?
A. Yes.
Q. Did he ment ion it more than once?
A. Yes.
Q. Did he ment ion it often?
A. Yes.
Q. Did he ever ment ion locations other than Brazil?
A. No. It ended up being Brazil.
Q. Did he tell you why he wanted you to go to Brazil?
A. At first -- everything -- everything evolved. At first, it was to keep me and my children
safe from the killers. Then -- then it just evolved into that, into -- and one of the
maximum points was until they had damage-controlled everything for you.
Q. No, you need to address us, okay?
A. I mean for Michael. And it escalated to that there was no definite time of return, until
they fixed everything for you, for Michael.
Q. Now, at some time after you came back to Jays residence, at some point around that
time, did you become aware of the fact that the Department of Child & Family Services
wanted to talk with you?
A. Immediately.
Q. Do you remember if that was before or after you went back to Neverland?
A. When Chris Carter brought me back, immediately like that, so then I said yes, Im
going to use this as an excuse to get my children out; that I need them for that. Oh, they
went into high gear now, more.
Q. Hold on. W ell get there. Well get there okay? Now, who was it who called you from
the Department of Child & Family Services?
A. On the phone I spoke to three ladies at three different times, because I was trying to
meet with the Child Protective Services by myself, in their office, because I figured -because I believed what the Germans had said. So I figured, you know what? Maybe
inside their office, you know, its going to be safe to express to them that my children are
still there and theyre not letting them out.
Q. Did you ask somebody among them if you could interview with them at the office?
A. Yes, and they said no. They were not helpful.
Q. Who is they?
A. Karen Walker. LaVerne. And I think -- I dont know whether its Jackie or Yvonne. She
goes by two -Q. There were two people that you had spoken with?
A. Three.
Q. All on the telephone?
A. Yes.
Q. Same conversation or different conversations?
A. Different conversations, because I couldnt make them aware over the phone that -

because I believed that my phone calls were being monitored - that they were over there.
Q. Did you know why they wanted to meet with you?
A. No.
Q. Did they tell you why?
A. No.
Q. Did they tell you whether or not it had something to do with Michael Jackson?
A. No. They said that it -- that they would let me know in the meeting.
Q. All right. Did -A. They didnt let me know of any allegations till the meeting.
Q. Did not discuss this video, the Living with Michael Jackson?
A. Nothing.
Q. Were you aware, prior to your meeting with Child Protective Services or, as they call it,
their Department of Child Family Services, whether or not that meeting had something to
do with this documentary Living with Michael Jackson?
A. Not until they had the actual meeting.
Q. Okay. Now, did you tell anybody at Neverland about the fact that youd been contacted
by representatives of the Department of Child & Family Services?
A. Yes. I had called the administration office. I had called -- I had called -- I had called
Jesus. Jesus did not return a -- not a single phone call of mine. And the administration
offices, their business offices did not return any of my phone calls. And then so there was
contact made between Frank and me.
Q. All right. Now, Frank then called you back?
A. Yes. I dont know whether he called -- I cant remember this fact, but maybe by the
phone records you can.
Q. Okay.
A. I dont know whether they told him to call me or I called him. I dont know. But at that
point I was completely desperate.
Q. Did you -- did they -- by they I mean the people from Ch ild -- the Department of
Child Family Services, DCFS, did they request of you to have your children present during
that interview?
A. Yes.
Q. Did they tell you that that was necessary?
A. Yes; that they have to see them themself.
Q. All right. Did you communicate that to Frank?
A. Yes.
Q. Did you tell anybody else that; that you needed to have the children there?
A. No, thats all. My one conversation was now only with Frank.
Q. All right. And tell me about the conversation that you had with Frank about this
interview with DCFS?
A. Im sorry, did you say -Q. Did you have a conversation in particular with Frank?
A. No, not a. Many.
Q. Many, all right. Do you remember any ofthese conversations?
A. Yeah. That -- I mean, my kids, because of this meeting.
Q. What was Frank telling you during that time?
A. At first, it was no, unless I do the video. Then it evolved into -- it evolved into more.
Q. Well, what more? I mean, what specifically was he telling you about the video and the
children?

A. Well, it evo lved. Right before the video, it evolved into that if I did a good job, I
wouldnt have to leave the country.
Q. At some point in time did you agree to do a video?
A. Yes, I did.
Q. Did somebody say to you that the video needed to be done before the interview?
A. Yes.
Q. Who was that?
A. Frank.
Q. What specifically did he tell you about that?
A. That I had to do it.
Q. You had to do it before?
A. Yes.
Q. All right. Now -A. The meeting could not take place prior to the video. The video had to take place prior
to the meeting.
Q. Do you have a recollection at this time of the dates that these particular events -A. Yes.
Q. In other words, if I were to ask you specifically the date of the initial phone call from
the Department of Child Family Services.
A. Oh, no, that I wouldnt be able to tell you. I need your help on the phone records.
Q. Do you know the date?
A. But I know it was like that, immediately.
Q. Immediately after you returned?
A. Yes, with Chris Carter.
Q. Do you know the date that was scheduled for the interview?
A. Yes, that I do. The 20th.
Q. And what day was that? The 20th?
A. The 20th. I -Q. And do you know what day of the week that is?
A. I think that was a Thursday. I think. I think so. I -- I think so. Thursday and the 20th
go together in my mind. MR. ZONEN: If the Court will once again take judicial notice that
the 20th -- Im sorry, I gave you my calendar. I believe it is a Thursday, but could the
Court check and perhaps we could take notice of that. THE COURT: Thursday is the 20th.
MR. ZONEN: It is a Thursday, then MR. MESEREAU: May I just see it for a second? MR.
ZONEN: He doubts you? MR. MESEREAU: Thursday is the 20th. Thank you. So stipulated.
THE COURT: All right. Is this a good place to stop? MR. ZONEN: Yes, Your Honor. THE
COURT: Is it time to stop? Okay. Well stop. See you tomorrow morning at 8:30.
Remember the ammonit ion

2005 April 14 (day 32) Cross Exam J Arvizo. Next Witnesses...

JANET ARVIZO EXAMINATION (Conti nued)

DIRECT EXAMINATION (Continued)BY MR. ZONEN:

Q. When we left off yesterday, we had been talking about the interview with Brad Miller
that took place at your then boyfriends house, Major Jackson; is that correct?
A. Yes.
THE BAILIFF: Is your microphone on?
MR. ZONEN: Yes. Just need to be closer, okay.
Q. When was it that you returned back to Neverland after that interview?
A. The next day.
Q. And did you return back with your children?
A. Yes, I did.
Q. Did you have an understanding about that with Frank?
A. Yes.
Q. When was that conversation? When did that conversation take place?
A. Every day, many conversations. Even on that day, the next day.
Q. Was there a conversation with Frank after the interview with Brad Miller?
A. Yes. Even during.
Q. Even during?
A. Yes.
Q. Did he call during that?
A. Yes, he did.
Q. And did you speak with him during that?
A. Yes.
Q. All right. Tell me about the understanding that you had with Frank about returning to
Neverland.
A. That the Germans had been fired, and -- and me and the kids were coming back, and
we didnt have to do the video at that point.
Q. And thats when you went back to Neverland; is that correct?
A. Thats when I went back.
Q. Now, there was going to be a DCFS interview; is that correct?
A. Yes.
Q. And that was going to be on the 20th?
A. Yes.
Q. Tell us about the conversation that you had with Frank about the rebuttal video.
A. Okay.
Q. And specifically in time after you had learned that there was going to be an interview
with
your children with DCFS.
A. First, he had told me, no, that he wasnt going to bring the two kids back. It evo lved
and
that made me very stressed. And then he says the only way they ll bring back the kids if I
do the video. And then it evolved into that I wouldnt have to leave out of -- leave the

country.
Q. You were already having conversations with Frank about leaving the country?
A. Oh, yeah, that had been since -Q. And had the location of where you were supposed to go already been resolved?
A. Yes, Brazil.
Q. Brazil? All right. You then went back to Neverland, youve already described. And then
you then turned around and went back to Los Angeles; is that correct?
A. Yes.
Q. Now, the rebuttal video took place where?
A. At Hamids house.
Q. Can you tell us when it took place?
A. The 19th until the 20th, like past 11-something at night, all the way into the a.m.
hours.
Q. The 19th of February being a Wednesday, I think weve already established.
A. Yes.
Q. So it was late at night?
A. Yes.
Q. Into the morning hours?
A. Yes.
Q. Where did it take place?
A. In Hamids house.
Q. And Hamid is who?
A. His personal videographer.
Q. Had you met Hamid before that day?
A. I dont think so.
Q. Do you know Hamids last name?
A. Moslehi.
Q. Moslehi?
A. Yes.
Q. How did you get to Hamids house?
A. Vinnie drove me.
Q. Do you know where Hamid lives?
A. And thats the first time that I met Vinn ie.
Q. Thats the first time you met Vinnie?
A. Yes.
Q. Do you know where Hamid lives, or at least lived at that time?
A. No. I just know we drove a long way, and I met -- they said something about San
Fernando Valley, but I really dont know where he lives.
Q. Do you know how long it took to drive from Jacksons apartment to Hamids residence?
A. No, I couldnt tell you.
Q. Could you describe Hamids residence to us?
A. Yeah, I can.
Q. Go ahead and do so.
A. He has a bedroom. Rest room. The dining area, but he had -- to me, I assumed it was
a dining area, but he had, like, some kind of table there, and then this open area and the
kitchen. But everythings, like, in -- open.
Q. All right. Now, were your kids there?
A. Yes.

Q. Were they there when you arrived?

A. Yes.
Q. Do you know how your kids got there?
A. My understanding is that Hamid took them there himself.
Q. All right. And you say somebody namedVinnie took you; is that right? 6148
A. Yes.
Q. Do you know Vinnies last name?
A. Amen.
Q. A-m-e-n?
A. Yes. Yeah.
Q. All right. You had never met Vinnie before?
A. No.
Q. Did he introduce himself to you in some fashion?
A. Well, actually, Frank did the introduction before.
Q. Frank did the introduction in person?
A. No, no, no. No. Frank, over the phone, told me about Vinnie.
Q. All right.
A. And then Vinnie had shown up.
Q. So you knew in advance somebody named Vinnie was coming?
A. Yes.
Q. Did Frank tell you who Vinnie was?
A. Yes.
Q. What did he say about Vinnie?
A. That hes one of Michaels people.
Q. Did he arrive with anybody else or by himself?
A. By himself.
Q. Do you know approximately what time it was?
A. It was about -- I dont know. My best estimate, probably about 11:00.
Q. Do you know why this video was done at Hamids house in the San Fernando Valley?
A. Yeah. I didnt want to go back to Neverland.
Q. Did you say that to somebody?
A. Yes, I said it to Frank.
Q. All right. Now, at the video at Hamids house, tell us who else was present.
A. Oh. In Hamids house, Brad Millers there, on top of the film crew, Hamid, Vinnie, and
Frank continuously on the telephone.
Q. All right. So Miller was there, Brad Miller?
A. Yes.
Q. Was he already there when you arrived?
A. Yes.
Q. Hamid, I assume, was already there?
A. Yes. My kids.
Q. Vinnie came with you?
A. Yes.
Q. Your three kids?
A. Yes.
Q. Anybody else that you can recall?
A. Yeah.
Q. Who else?

A. Christian. The one whos asking the scripted questions.

Q. Christian was there?
A. Yes.
Q. Were either of the Germans there?
A. No. No Germans.
Q. But there were scripted questions?
A. Yes.
Q. Were these questions that you had already seen?
A. Yes.
Q. And who had shown them to you?
A. Dieter.
Q. And when was that?
A. In Neverland.
Q. Was that prior to your leaving Neverland?
A. Yes. Prior to leaving with Jesus. And it continued afterwards with Frank on the phone.
Q. So Frank went over the questions as well?
A. Yes.
Q. What essentially was it that they wanted you to say?
A. Basically hes a -- you know, a father figure, everything in an answer to this Bashir
thing.
Q. All right. But what specifically was it that they asked you to say?
MR. MESEREAU: Im going to object to the word they as vague.
THE COURT: Just a moment, please. Sustained.
MR. ZONEN: Im sorry, I didnt hear.
THE COURT: The word they.
MR. ZONEN: Oh, yes, thats fine.
Q. Lets start with Frank. Tell us what exactly it was that Frank wanted you to say in this
video.
A. What I got in trouble for or what I ended up actually saying?
Q. No, no. Tell us, in advance of doing this video, what was it that Frank wanted you to
say on this video?
A. That hes a wonderful father.
Q. Did he use the word father?
A. Yes. Basically, in summary, that hes a wonderful father.
Q. Now, with regard -- in regard to his own children or in regards to your children?
A. To my children.
Q. Did you feel that that statement was accurate?
A. I was confused. I was confused, and I was sad at that moment.
Q. What was your confusion?
A. Well, because I -- I -- as things evolved, I ended up finding out who were the bad
guys.
Q. Im asking you, now that you had this conversation with Frank -A. I was confused with him, because I still believed his init ial meet ing in Miami. But I was
still -- and I was sad and confused as to why everything was happening. I didnt know
why.
Q. Did you, in fact, say on the video that you thought he was a father figure to your
children?
A. I think so. Many times. In d ifferent ways.

Q. Did you mean it when you said it?

A. I was confused. I was sad. So basically I was acting.
Q. What would you have been willing to say on his behalf at that time if you had not been
given a
script?
MR. MESEREAU: Objection; calls for speculation.
MR. ZONEN: Relevant for her state of mind.
THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Do you understand the question?
A. Yes. Nice things.
Q. Nice things like what?
A. Nice things of everything; that I believed him in the initial meeting that he had told me
in Miami.
Q. Up to this point, had you had any reason to be concerned about Mr. Jackson?
A. No. I was just sad and confused. 6153
Q. The incident that you saw on the plane returning -A. Yes.
Q. -- him licking Gavin -A. Yes.
Q. -- was that something that you were thinking about at the time of this video?
A. No, I -MR. MESEREAU: Objection; lead ing.
THE WITNESS: I thought it was -THE COURT: Sustained. Just a moment. The answer is in, but Ill sustain the objection.
Next question.
Q. BY MR. ZONEN: What was your thought process with regards to that licking incident?
MR. MESEREAU: Objection. Leading; foundation.
THE COURT: Based on her answer to the question that I sustained the objection to, Ill
sustain this objection.
MR. ZONEN: A ll right.
Q. Did you have any concerns about Mr. Jackson at all during the course of that video?
A. I said I was confused and I was sad, and thats it. And the prior incident on the
airplane, that had already been out of my mind.
Q. Did they talk to you about how you would 6154 dress for this video, or makeup, or
anything like that?
A. No.
Q. Did you do all that on your own?
A. No. Right there, inside the -- when I had arrived there, V innie had told me to go ahead
and put some more on, and -- but Frank -- and that was per Franks instructions to
Vinnie.
Q. Hold on a second.
A. Because Vinnie had given him like an update to how I looked.
Q. Now, did somebody talk to you in advance of your going to Hamids house -A. Yes, yes, at Jays house.
Q. You have to let me finish the question.
A. Oh, okay.
Q. Did somebody talk to you in advance of your arrival at Hamids as to how you should
dress, how you should wear your hair, or how you should wear makeup?

A. To put on makeup, because usually I dont put on makeup.

Q. And who was it who talked to you about that?
A. Frank.
Q. And that was over the telephone?
A. Yes.
Q. Did you have any further discussion with anybody at Hamids house about makeup or
hair or dress?
A. Well, Vinnie had given Frank an update as to how I was. And then Vinnie, per Franks
instructions, told me to put some more on.
Q. Some more what?
A. Makeup.
Q. How about clothing, who made the decision as to what clothing you would wear?
A. Nobody.
Q. You made that decision on your own?
A. I just -- yeah, yeah.
Q. Do you know what time that video started?
A. I think it was about -- I think it was about 3:00 a.m. Im not sure.
Q. Do you know what time it was that you arrived at Hamids house?
A. No. It was already the a.m. hours.
Q. What time did you -- what time was your meeting with the Department of Child &
Family Services?
A. It was scheduled at 9:00, and but it started around 10:00.
Q. And youre talking about the next morning?
A. Yeah. And I hadnt slept all night.
Q. All right. The -- the video then ended at approximately what time?
A. I wouldnt be able to tell you. I wouldnt
be -- but it was definitely -- it was already 6156 morning, a.m. hours.
Q. Did you have any sleep at all that night?
A. Zero. Zero sleep.
Q. Before the video, did you have a conversation with anybody over the telephone?
A. Before the video?
Q. Yes.
A. Yeah.
Q. With whom?
A. With Vicky Poderevski.
Q. How -- tell me how that came about.
A. Brad Miller dialed the phone, his private investigator. And he handed it to me, and this
woman was on the phone.
Q. Did he tell you in advance that he was dialing that number?
A. No.
Q. Did he tell you in advance who he was calling?
A. No. And that was scary.
Q. When he -- so the first time you knew you were getting on the phone with somebody is
when he handed you the phone?
A. Yeah, he dialed the number and handed it to me.
Q. Did he tell you who the person was?
A. No. Zero.
Q. Or why he wanted you to talk to this person? A. No.

Q. And the person at the other end of the line identified herself as who?
A. Vicky Poderevski, an attorney for Michael Jackson and Geragos.
Q. And what did she tell you?
A. I came to find out per the investigation now, but this is what they told me then.
Q. Im asking you what you understood at the time -A. Okay.
Q. -- not what youve learned since.
A. Okay.
Q. All right? At the time of this conversation, what did Miss Poderevski tell you?
A. That she was an attorney for Michael Jackson and Geragos.
Q. And what did she recommend to you?
A. She recommended that she be present at the CPS meeting.
Q. And what did you say?
A. No.
Q. Did she talk to you about who would pay her bill at all?
A. No.
Q. Was there any discussion about payment?
A. No.
Q. Why did you say no, if she was offering her services?
A. Because I -- in the past, I had spoken to, not these same exact people, but a different
department -- same department but different group of people, and different city. And they
were nice people.
Q. And that was in -A. Actually, it was a person. Nice person.
Q. When was that?
A. That was when David had been arrested. They had sent someone from that
department. But totally different city. Totally different building.
Q. All right. But your experience with them was what at the time?
A. It was positive. And you know what I liked about her, is that she was concerned about
my kids, not me.
Q. Youre talking about the prior experience?
A. The prior one.
Q. All right. Did you have concerns about the meeting the next morning?
A. Yes, I did.
Q. What were your concerns?
A. That my children were going to be taken away from me.
Q. Did somebody tell you that?
A. Yes.
Q. Who?
A. Vicky.
Q. Did you, in fact, have somebody present with you at that time?
A. At the CPS meeting?
Q. Yes.
A. Not by my choice.
Q. Now, who is it that took you to the meeting with the Department of Child & Family
Services?
A. Vinnie. Vinn ie took my children and me back to Jays.
Q. Was anybody else present during that time?

A. No.
Q. I mean in the car coming back.
A. No.
Q. Just Vinnie, you and your children?
A. Yeah, and then another car following us.
Q. All right.
A. There was always -Q. Do you know approximately what time in the morning it was you arrived back at Jays
house?
A. I think it was -- it was about one hour prior to Jay going to work.
Q. So Jay was still there when you arrived?
A. Yeah.
Q. Had you told Jay in advance that there was going to be that meeting at his house?
A. I think so.
Q. Did Jay stay for that meeting?
A. No.
Q. Tell us, at the point that everybody arrived at the apartment, how many people did you
have at the apartment?
A. Vinnie, me, the children, and then that -- those people that were following us.
Q. Excuse me.
A. But they -Q. Im sorry, do that one more time for me. I didnt hear. Who was there?
A. Me, Vinn ie and the children, and those people that were following us.
Q. You, Vinnie, the children, the people in the other car?
A. Yes.
Q. Was it just one other car?
A. Yes.
Q. At some point in time, did you see who those people were -A. No.
Q. -- or who they were?
A. No.
Q. Who actually went into the apartment with you?
A. Vinnie.
Q. Was Aja there at that time?
A. In -- in the meeting? Are we talking about the meeting now?
Q. Were at Jays house now.
A. Okay.
Q. Weve left Hamids house, all right?
A. Okay.
Q. And I think you said you arrived about an hour before Jay went to work.
A. Yes. And my children -Q. Can you tell us what time that was, if you can recall?
A. I dont know. The best I can recall is maybe 5:00 or 6:00 a.m. Thats the best -- and
thats just an estimate.
Q. The people who were in the other car, did they go into the apartment with you?
A. No. No.
Q. At what time did the people from the Department of Child Care Services arrive, Child
Family Services?

A. Okay. The meeting was scheduled for about 9:00, but it didnt start until about 10:00.
So I dont know. Its within that time bracket, because -- can I -- can I continue?
Q. Let me -- Ill go ahead and ask.
A. Okay.
Q. Tell us who was there at the time that the workers from the Department of Child
Family Services arrived.
A. Before the CPS people arrived?
Q. Yes, before. Just before.
A. Okay. I know him as CPS, DCFS, different names. But theyre all the same people to
me, okay? Asaf had arrived before those three lad ies did, before Aja did.
Q. And Aja?
A. Yes. Aja arrived just about the same time as the ladies did.
Q. Was Vinnie still there?
A. Vinnie, no, no.
Q. Vinnie had left?
A. Yes.
Q. So he wasnt in the apartment?
A. No. But he was within the area, now its my understanding.
Q. But you didnt see him in the apartment?
A. No, I didnt.
Q. Was Asaf in the apartment?
A. Asaf was inside the apartment way before the CPS people were.
Q. Did Aja arrive?
A. Its almost as if Vinnie went out, Asaf came in, like that.
Q. All right. How did Aja happen to be there?
A. Per Franks instruction, it was in -- per my -- my suggestion -- his suggestion, my
suggestion, it was kind of like a compromise.
Q. Well, did you call Aja? 6163
A. Yes, I did.
Q. The Aja were referring to is Chris Tuckers girlfriend; is that right?
A. Yes.
Q. And your relationship with her up to that point you would describe as how?
A. Real nice.
Q. Why did you want her to be there?
A. Well, it was -- like I said, it was kind of like a compromise going back and forth with
Frank until finally, I had to pick someone that he approved of, and he approved of Aja.
Q. Why were you picking anybody, picking somebody to do what?
A. Because Frank wanted an independent person there, an independent person, because
thats per how they use their choreography, they pull in unsuspecting people until they
stumble upon it.
Q. Why did you want Aja there?
A. I trusted her.
Q. Why did you want anybody there?
A. I was okay meet ing with the CPS people by myself, but it was per Franks instructions,
and then it ended up being a back-and-forth compromise that he approved of her.
Q. Did Frank tell you who he wanted to be present during this meeting?
A. No. He suggested Chriss girlfriend, and 6164 then it went back and forth, and I -- I -go ahead.

Q. Chriss girlfriend being Aja?

A. Yes. And so I figured it would be okay. So there was a period of compromising who.
Q. Is Asaf somebody you knew prior to that day?
A. No.
Q. That was the first time you met him?
A. Yes.
Q. Do you know Asafs last name?
A. No. I never learned it.
Q. Did you see him ag ain after that day?
A. Asaf?
Q. Asaf.
A. I -- I think -- I think I did see him briefly. I dont remember clearly, but I think it was a
period between -- when I was in the Calabasas area. And thats briefly. I cant remember
that. Thats my best -- I think that was the only other time.
MR. ZONEN: Madam Clerk, is Exhibit No. 24 in evidence?
THE CLERK: It hasnt been identified yet.
THE WITNESS: (To a juror) Bless you.
THE CLERK: It hasnt been identified yet.
MR. ZONEN: May I approach the witness, Your Honor?
THE COURT: Yes.
Q. BY MR. ZONEN: Id like to show you two 6165 exhibits at this time, if I may. Exhibit
No. 19 already in evidence, do you know who that is?
A. Vinnie Amen.
Q. Exhibit No. 24 for identification?
A. Asaf.
Q. All right. Is this photograph an accurate photograph of Asaf?
A. Oh, yes, it is.
MR. ZONEN: Okay. Move to introduce -THE WITNESS: Its burned in here, their faces.
MR. ZONEN: Move to admit Exhibit No. 24.
MR. MESEREAU: No objection.
THE COURT: Its admitted.
MR. ZONEN: May I publish No. 24, Your Honor?
THE COURT: Yes.
Q. BY MR. ZONEN: Miss Arvizo, if you could face the screen and tell us if thats, in fact,
Asaf.
A. Thats Asaf.
Q. Did Asaf tell you who he was?
A. Michaels security.
Q. Did you have a conversation with Asaf at some point that morning before the arrival of
the workers from the Department of Child & Family Services?
A. Yes.
Q. And did he give you any particular instructions?
A. Yes. To play -- he was verifying that I was going to play the vid -- the DVD. He told me
that if I put Michael in a bad light, that they know where my parents live. He wanted to
hear the allegations read in front of him. Let me see. What else? He was verifying that I
would do -- carry out Carrie -- Vickys instructions and Franks instructions.
Q. All right. You mentioned a DVD, play a DVD.

A. Yes.
Q. What was that?
A. Thats of Michael and Gavin.
Q. Had you ever seen that DVD before?
A. No. Prior to the Miami, never.
Q. Did you know that that DVD had actually been prepared?
A. No.
Q. All right. Did you see it for the first time?
A. For the first time in Miami.
Q. You saw it in Miami.
A. Yes.
Q. So they showed it to you there?
A. Yes.
Q. What was the circumstance of their showing you that DVD in Miami?
A. I dont know. I dont know.
Q. Well -A. Evvy -- Evvy had given it to Gary, and Gary had given it to Gavin while we were still at
Chriss house.
Q. All right. And did they give any instructions at that time as to what to do with it?
A. No, none.
Q. Now, that DVD then went to Miami?
A. Yes.
Q. And you saw it for the first time in Miami?
A. I saw it, like, complete in Miami, but a little bit at Chriss house.
Q. Explain to us the content of that DVD.
A. Its of my son when hes barely being ill, and Michael and Star.
Q. The two of them walking together?
A. Yes.
Q. Is Star in it on occasion?
A. Yes. Stars in there for a little bit.
Q. Now, did you keep that DVD from Miami?
A. Yes, I did.
Q. And did you have it in your possession?
A. Yes, I did.
Q. All right. Now, on the occasion of the visit from the Department of Child & Family
Services, did you play that DVD to them?
A. Yes, I did.
Q. Whose idea was it to do that?
A. Asaf, but he was verifying with Frank and Vicky had gave me instructions to do. But
mostly Frank.
Q. But you had that DVD in your possession?
A. Yes, I did. And this is as best as I can remember.
Q. Thats okay. Did somebody give you a tape-recorder during this interview?
A. Oh, yeah.
Q. Who was that?
A. Asaf. But I didnt know that he had a tape-recorder until after.
Q. Well, tell me what the circumstances were with the tape-recorder. What happened with
that?

A. Okay. When Asaf found out he was being kicked out, thats when he told me, Can I
talk to you for a second? And he pulled me into Jays bedroom. And then he gave me -he gave me instructions, but it was already on, it was already working. What I was trying
to find out was that I didnt have to push anything because it was already working. He
gave me instructions about to, Take her here. Talk to her here. Leave it here. And you
could also hear in there that that period of week was very stressful for me, because Karen
had also -- they -- the CPS knew that I was -Q. Lets back up a little b it now.
A. Okay.
Q. Before Asaf talked to you about a tape-recorder -A. Uh-huh.
Q. -- did you have a discussion with anybody among the Department of Child and Family
Care Services about having other people present during this interview?
A. Yes, and I was referring that to Aja.
Q. Who did you ask to have present in the interview?
A. Aja.
Q. Did you ask to have Asaf present?
A. No. Only Aja. I trust Aja.
Q. Did Asaf ask you to ask them to allow him to remain?
A. Yes.
Q. Did you ask them to allow Asaf to remain?
A. No. I was -- hopefully I was -- I was hoping that the CPS would make that call so Asaf
wouldnt hear it come from my mouth. So I was referring to Aja, but I had to, per Asafs
order.
Q. Did you know that there was a tape-recorder in the room at the time -A. No.
Q. Hold on. Hold on. Listen to the question. Did you know that there was a tape-recorder
in the room prior to your discussion with the social workers about who would be present
during the interview?
A. No.
Q. At some point in time, did somebody tell you from the social workers who would be
allowed to be present during the interview?
A. Yes.
Q. All right. And what was that resolution? Who was allowed to be present?
A. Just me and the children.
Q. Not Aja?
A. Not Aja.
Q. Not Asaf?
A. Not Asaf and not the baby.
Q. All right. Tell us when it was that Asaf then had a conversation with you about a taperecorder.
A. When -- after that.
Q. All right. Now, what exactly did Asaf say to you? What did he do?
A. Can I talk to you for a second? And told me that -- told me that it was working, that I
didnt have to push anything. Told me to talk -- to, you know, in the room, Leave it here.
Talk to her here. Take it here. And you could also hear in there when I was -- I got very
scared when I thought the DVD of Gavin and Michael were missing. Because that was one
of the orders that I had to do.

Q. Did he then hand you a tape-recorder?

A. Yes, he did, after he said, Can I talk to you for a second?
Q. Now, what did you do with this tape-recorder?
A. He put it on the desk. And I just went ahead like -- that was -- I just played along with
him, Yeah, yeah, sure, uh-huh. You know, basically that kind of behavior.
Q. What was your intent -A. But I didnt say those words. My behavior -- that was my behavior.
Q. At the time that he gave you the tape-recorder, what did he ask you to do with it, in
terms of where to keep it, where to place it?
A. He placed it on the desk area.
Q. Okay.
A. Just to, Leave it here. Talk to her here. Take her here. Because Karen had said she
was going to talk to each one of us individually, so he assumed that it was going to be in
the bedroom. And he also -- you know.
Q. Karen being one of the social workers?
A. Yes, Karen was the supervisor. 6172
Q. Do you know her last name?
A. Karen Walker.
Q. Did you have any concerns about the tape-recorder?
A. Yes.
Q. What were your concerns?
A. That these people are going to be illegally taped.
Q. Did you think there was an illegality problem?
A. Yes, because she had just said, This is confidential.
Q. All right.
A. And I wasnt aware at that time that he had the tape-recorder.
Q. All right. Now, did everybody finally leave the room, in terms of Aja and Asaf?
A. Okay. Asaf didnt leave until I had came out of the rest room. I thought he had already
-- I thought he had already gone. So you could even hear me on the tape-recorder,
because I was going to tell the lady there -- I figured he had already gone. So I -- I
started telling her, because the lady -- one of the women had pulled me -- well, not pulled
me, was talking to me also in the area where the tape-recorder was. And so Im -- I was
going to start to tell her, and then theres Asaf right there. And I just -- you can hear my - my voice. 6173
Q. Okay. Did Asaf tell you anything about any other tape-recorders?
A. Yes.
Q. What did he say?
A. After I turned it off, came out of the rest room, and then he was still -- Jays
apartment, it was very long. It was like an apartment house, but its only one bedroom.
So he was in a distance where a wall was covering, but he can hear.
Q. Whos he?
A. Asaf. Asaf can hear. And so thats when he called me over. And at this point he told me
that theres another one in the room. So I didnt know whether it was a tape-recorder or a
monitoring device. I didnt know what it was. But there was certainly another one in the
room.
Q. When the interview finally began, who was present in the interview room?
A. When -- the three lad ies, me and my children.
Q. And were all of you interviewed together?

A. Yes.
Q. At any time did they separate you from the children or each of the children from each
other?
A. No. No. I carried out Vickys instructions.
Q. And what were those instructions?
A. Not to let the children be separated, interviewed separately. Ask what are my rights,
what are the childrens rights. Have the allegat ions read before -- before the meeting.
Just, you know, different things like that.
Q. Did you play or record the entire conversation?
A. Me?
Q. Yes.
A. No, I turned it off.
Q. You turned it off when?
A. I turned it off when I thought he had already gone, and he was there.
Q. Why did you turn it off?
A. Because its illegal to tape people without them knowing.
Q. At some subsequent time, did you have an opportunity to listen to a recording that you
believed to be that recording?
A. There?
Q. Let me try that one more time.
A. Okay.
Q. At some later time -A. Yes.
Q. -- sometime after the meeting -A. Yes.
Q. -- did you have an opportunity to listen to a tape-recording?
A. Yes. At the grand jury, the D.A.s Office, right before the grand jury, I was like -- it was
like hours before, hours. And they only had two minutes -- about two minutes worth of
that DCFS tape. And I told them, you know, Theres more. Theres more to this tape. So
he -- so the D.A.s Office had -- had me explain to them how much more there was. And I
said, Because thats not all of it. Theres still more.
Q. All right.
A. I was monitored continuously by those people.
Q. The first tape that you listened to at the time of the grand jury was a tape from what?
A. From a -- I dont know whether its a media report, area, I dont know what you
properly call the show. Abrams Report.
Q. Television?
A. Yes.
Q. Something that had played on television?
A. Yes. Yes.
Q. And after having listened to that, what was your view of whether or not that was the
entirety of the conversation?
A. That was not its entirety.
Q. Since then, have you had an opportunity to listen to another tape?
A. Yes.
Q. What is your opinion about that other tape?
A. This one is accurate.
Q. Up until the point where you turned it off?

A. Yes.
Q. Okay. Well, through the time, the entirety of the tape?
A. Yes. And he turned it on when the CPS people arrived. Not prior.
Q. Okay. Can you make out the different voices in this tape?
A. Yes, I can.
Q. And how many different voices are there in this tape?
A. The three ladies from Child Protective Services. Aja. And my three children. You kind of
can hear the baby a little bit. Thats their -- hes a toddler. And you can hear Asaf. You
can hear him say hes Michaels security.
Q. And during the course of that time, did you play the video that they had asked you to
play?
A. Yes, I did. And I got scared, because I thought -- I thought it went missing. I thought I
misplaced it, so I got really scared because that was one of the instructions.
Q. All right. Now, did you say positive things about Michael Jackson?
A. Yeah, I had to. At this point now, its a -- now its a have-to. Because everythings
evolving. And he had said that -- to put Michael -- dont say anything that would put
Michael in a bad light, because they knew where my parents lived, he knew where my
parents lived. And this is prior to the tape-recording.
Q. Miss Arvizo, did you know why Child Protective Services were at your house, those
social workers?
A. No, I did not know why. And they didnt even want to tell me on the phone when I was
trying to talk to them.
Q. At some point in time after they arrived, did they explain why they were there?
A. They didnt explain it until I was alone with the children.
Q. Did Miss Poderevski, in her conversation with you, tell you why, her opinion, they were
there?
A. No. She just told me to -- to basically drive it home for him being a good father.
MR. ZONEN: Thank you. Were going to play it at this time. Your Honor, we have marked
for identification a CD, a tape-recording, No. 810, 8-1-0, and we would like to play that at
this time.
THE COURT: Do you have a transcript of that?
MR. ZONEN: W e do. And well -- I have it here, but well have a copy for the Court before
the session is over today, along with the one from yesterday that I promised you.
THE COURT: How long is the tape?
MR. ZONEN: Im sorry?
THE COURT: How long is it?
MR. AUCHINCLOSS: 19 minutes.
MR. ZONEN: 19 minutes, Your Honor. May we begin?
THE COURT: Yes.
THE WITNESS: And this is all the best that I can remember. (Whereupon, a portion of a
CD, Plaintiffs Exhibit No. 810, was played for the Court and jury.)
MR ZONEN: Were pausing it a moment.
Q. Miss Arvizo, what is the music that were hearing right now?
A. That is from the DVD, the background music to the DVD that Michael and Gavin were
in, and a little bit of Star was in there.
Q. This goes for approximately what, six minutes?
A. I think so.
MR. ZONEN: A ll right. Lets go ahead. (Whereupon, a portion of a CD, Plaintiffs Exhibit

No. 810, was played for the Court and jury.) 6179
MR. ZONEN: W ere stopping the tape momentarily.
Q. Miss Arvizo, can you tell us what that sound was that we were hearing just prior to
stopping this tape; do you know?
A. No, I dont know. I dont know.
Q. Do you have a recollection of that sound from the time of this event itself?
A. No, I dont. But it sounds like tape. But I dont know.
Q. Was that taped to you at any time?
A. No.
Q. Were you able to see the tape-recorder prior to him giving it to you, before he gave it
to you?
A. Yes.
Q. Where was it?
A. The best I can remember, he took something out of his pocket, so I dont know.
Q. Do you remember what he was wearing at the time?
A. Yeah.
Q. Were talking about Asaf, right?
A. Blue shirt.
Q. He had a shirt?
A. Blue shirt, long-sleeved, co llar.
Q. Did he have a jacket on at all?
A. No, just a blue shirt.
Q. And prior to him taking it out, did you see 6180 that tape-recorder?
A. No. So I dont know if he -- you know, where.
Q. There was a single mans voice, a deep voice, that came on just before we turned off
the tape.
A. Yes.
Q. Who was that?
A. Asaf.
Q. Was he the only male in that room at that time?
A. He was the only male. And plus my two boys and plus the toddler, Ajas baby.
Q. He was the only adult male in the room at the time?
A. Yes, he was the only adult male.
MR. ZONEN: Lets go ahead and resume. (Whereupon, a portion of a CD, Plaintiffs Exhibit
No. 810, was played for the Court and jury.)
Q. BY MR. ZONEN: Miss Arvizo, the tape just ended?
A. Yes.
Q. How did it end?
A. I turned it off.
Q. We heard some rustling sound within the last couple of minutes before it ended.
A. I was trying to figure out -- it was like some very high-tech thing, and I couldnt figure
out 1 where the off was. And I -- I tried my best. And so I -- that -- and even when I
turned it off, I was unsure that I had turned it off. So what I did, I put it inside a closet
and I put two towels completely covering it.
Q. In what room were you at the time you did that?
A. In the bedroom.
Q. All right. And where were the workers at this time?
A. They were in the -- okay. Like I said, Jays apartment was -- even though its a one-

bedroom apartment, they call it apartment houses. Its long. So they were way over there
in the living room. And thats when -- afterwards Asaf was still in there. He was there
present with the CPS people.
Q. All right. At the time that you turned off the tape-recorder, were the CPS workers in
the same room with you?
A. Me? No.
Q. Did you have to move the tape-recorder to a different room before you turned it off?
A. No, it was all within the bedroom.
Q. And was the interview going to be held in the living room or in the bedroom?
A. Asaf had assumed that it was going to be in the bedroom, and they said to, Take her
here. Talk 6182 to her here. Leave it here.
Q. So at one point prior to this, you asked to go to the rest room; is that correct?
A. Yes.
Q. Did you actually go to the rest room?
A. No, I was just pretending I was in there.
Q. And the purpose for that was what?
A. So -- to create some -- some -- so I can have some privacy so I could turn off the tape.
Q. That is what you wanted to do?
A. Thats what I wanted.
Q. Now, in the course of this interview, they represented that this was going to be a
completely confidential interview; is that right?
A. Yes.
Q. And that none of these records or documents would become public; is that correct?
A. Exactly.
Q. And, in fact, what did happen with these documents?
A. All this stuff got leaked.
MR. MESEREAU: Objection; foundation.
THE WITNESS: All of it.
THE COURT: Sustained.
MR. ZONEN: Ill lay the foundation.
Q. Did you see any of these records in the public forum at some subsequent time?
A. Yes. Every single sheet of paper that was 6183 ever created from my children, about
my children or me from the DCFS people, was all over.
Q. All over where?
A. All over the world.
Q. On television?
A. On television. Internet. Every single p lace.
Q. How long after this interview was it that that happened?
A. Right after he was arrested.
Q. He being Mr. Jackson?
A. Michael. Mr. Jackson.
Q. How long did this interview go on after you turned off the tape-recording?
A. After I had turned off -- I used the rest room. Turned off the tape-recorder. And then I
got extremely frightened, because I saw him still there with the CPS people. And thats
when he called me over. And I went over there, the separate area out of the bedroom,
and thats when he had told me that he had placed another one -- the ladies are still
distracted with my kids. And so thats when he had talked to me and told me about that
there was another one there. And Im like, Where? I had been in the rest room.

Where.
Q. Did he tell you?
A. No, he didnt tell me where this one was at. Q. Did he tell you whether it was open or
hidden? Did he say anything about it?
A. No.
Q. Do you know whether or not there was a second one in that room?
A. No, I dont know.
Q. To this day you dont?
A. To this day I dont know.
Q. Did Asaf finally leave and go outside?
A. Yes.
Q. Did Aja go outside?
A. Aja had left almost immediately. Aja and the baby.
Q. In what room did the interview finally take p lace?
A. It took place in the -- okay, the dining and the living room, its combined. But it just
looks like, you know -Q. There is some conversation with you and the social worker thats on this tape; is that
correct?
A. Yes.
Q. All right. Where did this conversation take place? Where was the tape-recorder during
that conversation?
A. In the bedroom.
Q. So they were with you initially in the bedroom?
A. No, no, no. Im sorry, Im thinking about when the lady was talking to me by myself.
Q. Yes.
A. And I tried to tell her, and thats when Asaf popped up.
Q. Yes.
A. That part, when theres one person talking to me is -- towards the end is in Jays
bedroom.
Q. And that person came into the bedroom with you?
A. Yes, she came into the bedroom.
Q. Do you know who that person was, what her name was?
A. I dont remember her name, but I can -- I can tell you who -- who it is by the
description.
Q. By the description?
A. Yes, I can.
Q. There were how many social workers there at the time?
A. Three.
Q. Did one appear to be a supervisor to you?
A. Yes, she -- Karen Walker.
Q. And the person who had the conversation with you that is picked up, was that Karen
Walker or one of the others?
A. You could pick up Karen Walker in the beginning. But this one was not Karen Walker in
the bedroom.
Q. All right. To the extent that this 6186 tape-recording goes on for approximately 19
minutes, does this tape-recording accurately capture the conversations?
A. Yes. And Asaf began taping when the CPS women walked in.
MR. ZONEN: Your Honor, we would move to introduce into evidence Exhibit No. 810 with

the representation that the transcript will be furnished within the day.
MR. MESEREAU: No objection.
THE COURT: Its admitted.
Q. BY MR. ZONEN: How long did that interview go on with Child Protective Services or
Department of Child Family Services?
A. Yeah, I couldnt tell you, Mr. Zonen.
Q. At -- presumably this conversation ended at some point in time, did it not?
A. Yes.
Q. Did they make any representations to you, they being any of the social workers?
A. The three women?
Q. Yes.
A. They were just concerned about Mr. Jackson. They just didnt want to be sued by
Michael Jackson. They had not a single sheet of paper in front of them. They didnt even
take a single piece of note from me or my children.
Q. Do you know if they tape-recorded the 6187 conversation?
A. No, I dont know.
Q. You didnt see a tape-recording?
A. I didnt see anything.
Q. They didnt tell you they were tape-recording?
A. They didnt tell me.
Q. None of them had notes that they were taking?
A. None of them had a single sheet of pad, notepad, pencil, pen, pulled out. All they kept
telling me was that they didnt want to be sued by Michael Jackson, over and over.
Remember I told you there was a difference of people? The one that had been brought out
way, way -- her sole concern was my children. But in these, their sole concern was
Michael Jackson.
Q. Did they ask any questions of your children in your presence?
A. Yes, they did.
Q. Did they ask them if anything had happened to them when they were at Neverland?
A. Not really.
Q. What did they ask them?
A. It was just -- it was more of a -- of a pep talk.
Q. What did your children say to them in their presence? 6188
A. They basically said happy things about Michael. And them being together.
Q. And did you do the same?
A. Yes, I did.
Q. Did you tell them that he was a father figure to your children?
A. Yes, I did. Almost identical to the scripted video. But not as long. It was kind of like -it was extremely short.
Q. All right. Presumab ly they left at some time after?
A. Yes.
Q. Who was still present among the ones that youve previously identified after the social
workers left?
A. Aja, the baby, Asaf, me, the children, then Vinnie was there now. After the CPS women
walked out.
Q. Excuse me. Did Asaf talk to you after the social workers left?
A. Yes. He was making sure that me and Aja had no private time. And he had told me,
Hold on. Vinnie wants to tell you something. And he escorted Aja and the kids out to

Ajas car.
Q. Now, did Asaf in your presence retrieve the tape-recorder?
A. I think -- I remember h im walking into the bedroom, but thats the -- because what
happened was when -- after -- when the CPS women came, I ran into the bedroom and I
put it back in the same place that he had placed it.
Q. All right. And did he then retrieve it?
A. Yes.
Q. And he retrieved it from the same place?
A. From the same place.
Q. All right. Did he make any effort to listen to it in your presence?
A. No.
Q. Did you tell him that you had stopped it?
A. No.
Q. Or attempted to stop it?
A. I -- yeah, I tried and -- but I did end up turning it off. Because I was pushing.
Q. Did he say anything to you at all about whether or not this tape had run the entire
time? Did he make any inquiries of you?
A. No.
Q. Did you have any conversation with Asaf at all following the moment when the social
workers left?
A. Well, Vinnie was there now. And he told me that Vinnie had -- that Vinnie had to talk to
me.
Q. All right.
A. While he escorted Aja and the children out to Ajas car.
Q. So there was no additional conversation?
A. No additional conversation. This is the best I can remember.
Q. With Asaf?
A. With Asaf. He told me that Vinnie had something to tell me.
Q. Did you then talk with Vinnie at that point?
A. Yes.
Q. What did Vinnie say to you?
A. That I had done -- that I had not done an adequate job on the video, and we were
going to have to proceed with leaving out of the country.
Q. Is this the first time that anybody talked to you about your performance or the
performance of the children in the rebuttal video?
A. Yes, it was Vinnie.
Q. And he said it wasnt adequate?
A. Thats right.
Q. Did he give you any specifics as to what was not adequate in this interview?
A. Yeah, that I -- I was supposed to stick strictly to the script. I went out of -- the things I
got in trouble for, because of God, the Child Welfare Services thing, and Gavins cancer.
Q. All right. Now, we have seen this video a couple times already.
A. Okay.
Q. Lets go back. These are things that Vinnie specifically told you?
A. Yes.
Q. Lets start with the first one. What did he say about references to God?
A. Okay. I was supposed to say that Michael healed Gavin.
Q. And did you not say that?

A. I did not say it exactly like they wanted me to. Instead I said -- Dieter had also
presented to me to say, Via Gods Grace, because I was so, No, its God who healed
Gavin, not Michael healed Gavin God did. And so then I was supposed to say that
sentence plus that, them.
Q. And what did he say about the other two issues that you had mentioned?
A. That I was supposed to make no issue -- see, the whole video, plus the outtakes, was
also scripted. It wasnt -- it wasnt -- it was the -- the whole thing, from outtakes, to video
filming, to everything, every single thing was part of the choreography.
Q. What did he say to you specifically, V innie? What did he say to you about the other two
issues that you mentioned?
A. Well, I d idnt say about Gavins cancer, thats why they repeatedly -- I wasnt on target
about that, what they wanted.
Q. What did he want you to say more about Gavins cancer? 6192
A. Well, how they had scripted it.
Q. How was that? How was it different than what you actually said?
A. Well -Q. Do you recall?
A. The best I can remember is that I said Gavin -- about -- I totally was not on script
about Gavins cancer. I said from my heart.
Q. All right. And what was the third thing?
A. The Child Welfare Services, I was supposed to make no commentary about that at all.
Zero.
Q. And you did?
A. And I did.
Q. Now, where d id everybody go after this took place and the social workers were gone?
Where did the kids end up going at that point?
A. Okay. The kids and Aja went to Neverland, and they were also being followed, and Aja
dont know shes being followed.
Q. Just tell us where they went. They went back to Neverland?
A. Yes, they went to Neverland.
Q. Did they get any sleep that night at all?
A. The children?
Q. Yeah.
A. They must have slept about one hour. About one hour.
Q. Where? 6193
A. At Jays.
Q. At Jays house before the workers got there?
A. Before the workers got there. And me? Zero.
Q. Did you have to wake them up?
A. Yes, I did.
MR. ZONEN: Excuse me. Your Honor, Id like to approach the witness, if I can, to show a
couple of exhibits alread y shown to counsel, defense counsel.
THE COURT: All right.
MR. ZONEN: Before I do that, I need a stapler.
Q. Id like to show you Exhibit No. 811. And then Im going to show you 812. Lets start
with 811 here.
A. Okay.
Q. 811 is a collection of four pieces of paper stapled together; is that correct?

A. Yes.
Q. Have you ever seen any of those documents before?
A. Yes.
Q. All right. Tell us what those documents are.
A. This is when we got off the car at Hamids house, Vinnie had told me that I had to sign
these releases. And this was part of it. 6194
Q. Now, are these the releases, in fact, that were given to you?
A. Yes.
Q. And did you, in fact, sign that release?
A. Yes, I did.
Q. And why did you do that?
A. Because this is all part of what they requested.
Q. All right.
A. In order -- in order for us not to leave the country and for my children to be let go and
not have to deal with this anymore.
Q. Did you consult with an attorney before signing that release?
A. No.
Q. Did you have any discussions with Vicky Poderevski about that release?
A. No.
Q. Was there any other attorney that was brought to the -- to the -- to the house to -A. No.
Q. Did you ever talk with Mark Geragos about that release?
A. No. Ive never even spoke to Mark Geragos.
Q. Never h ad any conversation?
A. Zero conversation.
Q. Did you ever meet Mark Geragos?
A. Never. 6195
Q. Did you have some discussion with either Vinnie or anybody else there about the
nature of that release before signing it?
A. No.
Q. Id like you to look at the next exhibit thats -- incidentally, before you turn back,
theres four pages there.
A. Yes.
Q. Tell us how each of those pages differ from one another.
A. I -- I dont understand your question.
Q. All right. Is the -- are the signatures the same on each one?
A. Of -- no. Theyre all different, except Vinnies. Vinnies is the same on all of them.
Q. And whose are the other signatures? Is one of the signatures yours?
A. My three children and myself.
Q. Do you have a recollection of your three children actually sign ing those releases?
A. Yes, I do.
Q. Were you present at the time?
A. Yes, I was.
Q. Was anything explained to them at the time they signed it?
A. No.
Q. Did you encourage them to sign it?
A. No.
Q. Who was it who presented the releases to them?

A. Vinnie.
Q. And, in fact, Vinnies signature is on each of them as well?
A. Yes.
Q. All right. Do you recall if any of your children asked any questions about those releases
before signing them?
A. They didnt.
Q. Did anybody talk to you about whether or not releases signed by a child would be
legally binding?
A. Im sorry?
Q. Did anybody talk to you about the question of whether or not releases that are signed
by a child -- wait till the question is asked.
A. Okay.
Q. That releases signed by a child would be legally binding? Did that discussion come up
at all with Vinnie?
A. No.
Q. Or with anybody else?
A. No.
THE COURT: All right. Well take our break.
THE COURT: All right. Counsel?
MR. ZONEN: Thank you, Your Honor.
Q. We were looking at Exhibit 811, which I think you still have in front of you.
A. Yes.
Q. All right. And are those accurate copies
THE BAILIFF: Oh, microphone, please.
Q. BY MR. ZONEN: We were looking initially at 811. Those are the four documents that
are stapled together. And youve already testified as to what they were -A. Yes.
Q. -- and when they were signed. Are those accurate duplicates of the documents signed
that evening by you and your three children?
A. Yes.
MR. ZONEN: And, Your Honor, I would move to introduce 811 into evidence.
MR. MESEREAU: No objection.
THE COURT: Its admitted.
Q. BY MR. ZONEN: Now, prior to your signing it or even subsequent to your signing it, was
there any subsequent conversation with Vinnie or anybody else about money that would
be received?
A. No.
Q. Did you discuss with an attorney anything about money?
A. No.
Q. Did they offer you money?
A. No.
Q. Did you ask for money?
A. No.
Q. And I think that you had already said that that was not part of the conversation that
you had with Vicky Podberesky.
A. Exactly.
Q. And did they offer you any other legal assistance, anybody else to talk -MR. MESEREAU: Object to the word they as vague.

MR. ZONEN: Ill withdraw the question.

Q. Did Vinnie tell you about any other lawyers who might be available for you to discuss -to talk
about this release?
A. No.
Q. Was there ever any representation by them that they would pay you or your children
for your participation in this video?
A. No.
MR. MESEREAU: Objection to the word them as vague.
MR. ZONEN: Ill withdraw the question.
Q. Was there ever any representation by Vinnie that you would be paid for your
participation in this video?
A. No.
Q. Did you ever request of Vinnie that you be paid for your participat ion in the video?
A. No.
Q. Did you ever have a d iscussion about being paid for this video with any emp loyee of
Michael Jackson?
A. No.
Q. Did you ever talk with Michael Jackson about it?
A. No.
Q. Did you expect to be compensated for it?
A. No.
Q. Did you have a conversation prior to doing this video with Jay Jackson about whether
or not you should be compensated for this video?
A. No.
Q. Did Jay Jackson have a conversation with you where he reviewed the content of a
conversation he had with Frank?
A. No.
Q. Were you aware that he had had a conversation with Frank about this video?
A. No.
Q. Now, Id like you to look at the other document thats right in front of you. Its No. 812.
Have you seen that document before?
A. Ive seen it per your investigation and over there at Neverland.
Q. Okay. When was the first time you saw that document?
A. I think the best I remember was in Neverland.
Q. And do you know who it was that showed that document to you?
A. It was Frank and Vinnie.
Q. Was that before the video was done?
A. No.
Q. It was after the video was done?
A. Yes.
Q. Did somebody hand that to you and ask you to sign it?
A. Yeah.
Q. All right. Who was that who handed it to you?
A. By this time my sign ing days were over.
Q. Tell us when that was, approximately.
A. That was in Neverland after -- after the Chris Carter thing.
Q. Okay. Now, the person -- Im sorry, who was it again who handed that to you?

A. Frank and Vinnie.

Q. Were they both together at the time?
A. Sometimes together.
Q. But on the first occasion that you saw this document -A. Frank.
Q. -- it was Frank? Did you see that document on more than one occasion?
A. Wait. Best I remember. It could have been V innie. Vinn ie or Frank. I dont know.
Q. Take a moment. Take a moment.
A. Uh-huh. I think -- the best I can remember, I think -- yeah, the best I can remember
was Vinnie, then Frank, then both. Thats the best I can remember.
Q. Lets start with Vinnie, whether he was first or second. Do you remember what Vinnie
specifically said to you about that document?
A. Sign here.
Q. Did he explain what it was?
A. No.
Q. Did he explain what it was for?
A. No.
Q. Did he give you any detail at all about that document or why he wanted you to sign it?
A. No.
Q. How about Frank? When he talked to you individually, what did he say about that
document?
A. Nothing. Just, Sign it.
Q. Do you remember when this was relat ive to the video that you had already done?
A. After.
Q. Do you know approximately how long after?
A. No, I wouldnt be able to tell you.
Q. Okay. Did Frank give you any direct ion as to why he wanted you to sign that
document?
A. No.
Q. And when the two of them were together and spoke to you about that document, did
either one of them, in the course of that conversation, say anything to you about why
they wanted you to sign it?
A. No.
Q. All right. Now, the document that you have in front of you -A. Yes.
Q. -- has your name preprinted; is that correct?
A. Uh -Q. At the bottom of the page?
A. Oh, I see. Yeah. At the bottom.
Q. And was that how it was at the time that they had handed it to you?
A. Yes.
Q. Did you, in fact, refuse to sign that document?
A. Yes.
Q. You never did?
A. Huh-uh.
Q. In the course of your -A. I got in trouble for that.
Q. -- discussions with either Vinnie or Frank about your signing or not signing that

document, did you make a demand for money?

A. No.
Q. Did you ever ask them for money?
A. No.
Q. Did you tell them why you didnt want to sign the document?
A. Because my signing days were over. Thats it.
Q. What does that mean?
A. They had me sign a bunch of different things -Q. Were there -A. -- over the course of from Miami to this. Im talking in total. And thats it. You know,
Let me go. Let my kids go. Thats all I wanted.
Q. All right. Ult imately you did not sign that document?
A. No.
Q. Did you see if there were similar copies of that document but with the names of your
children?
A. Yes. Yes.
Q. Did they show them to your children at all?
A. I -- they may have. They may have. Because they had a period of time when they were
alone with
the children.
Q. Do you know from personal knowledge? In other words, did your children ever sign
those documents in your presence?
A. In my presence, never.
Q. All right. Do you have any informat ion, one way or the other, as to whether or not they
ultimately signed that release on 812?
A. I dont know about this release.
Q. Okay. Is that, in fact, an accurate copy of the release that was shown to you at
Neverland?
A. Yes.
Q. Were you shown that release on more than one occasion?
A. Yes.
Q. On how many separate occasions were you shown that release?
A. I wouldnt be able to tell you, Mr. Zonen.
Q. Can you give us a sense of it?
A. No.
Q. Okay. More than once?
A. Yes.
MR. ZONEN: Your Honor, I would move to introduce 812 into evidence at this time.
MR. MESEREAU: No objection.
THE COURT: Its admitted.
MR. ZONEN: Just one moment, Your Honor, please. (Off-the-record discussion held at
counsel table.)
MR. ZONEN: May I approach the witness, Your Honor?
THE COURT: Yes.
Q. BY MR. ZONEN: Miss Arvizo, Im showing you No. 814 for identification. No. 814 for
identification. Id like to -- Id like you to take a look at this, please. Take a mo ment and
look at it.
A. Uh-huh. Okay.

Q. Is that a document youve seen before?

A. Yes.
Q. Where did you see that before?
A. I think I seen this in -- I think I seen this in Neverland.
Q. Okay. Is that your handwriting?
A. No.
Q. Do you know whose handwriting it is?
A. This is Vinnies.
Q. Was that drafted in your presence?
A. I dont think so.
Q. Turn the document over, if you would.
A. Oh, my God.
Q. Excuse me. Tell us what that is on the other side of the document.
A. Its the same one.Q. In other words, its -BAILIFF CORTEZ: Your microphone, sir.
MR. ZONEN: Okay. Were back on.
Q. Ive now asked you to turn this document over on the other side.
A. Yeah.
Q. And what is it on the other side?
A. Its the same one.
Q. Its the copy of exhibit number what?
A. Yes.
Q. Im sorry, exhibit number what? Tell us what exhibit that is. I think its 812. No?
A. Yes, 812.
Q. So the back side of the one that I just showed you which has Vinnies handwriting -A. Yes.
Q. -- is, in fact, a copy of 812?
A. Yes.
Q. Is it the one that has your name preprinted or one of the kids?
A. Its mine, preprinted.
Q. Did Vinnie ever show you that document, the written one?
A. I dont -- I cant remember. I -Q. Do you have a recollection of having seen it at some point in time?
A. Yes, I think so. At Neverland.
Q. Did you ever sign a handwritten document?
A. A handwritten document?
Q. Yes.
A. No.
Q. Is your signature on that document?
A. No, it isnt.
Q. But your name is on it?
A. But my name is on it.
Q. Does that appear to be some form of a model release?
A. It says, This model release....
Q. Was there ever a discussion between you and Vinnie or you and Frank about coming up
with some kind of a release that was suitable for you?
A. No.
Q. The release that youre holding in your hand right now, the printed form on the back of

that page, that was presented to you before or after you did the video rebuttal?
A. After.
Q. You can go ahead and put those down.
A. Okay.
Q. Miss Arvizo, 812 that I showed you initially, the one that does not have something on
the back -A. Okay.
Q. -- is that, in fact, an accurate copy of the release that was given to you by both Vinnie
and Frank?
A. Yes.
MR. ZONEN: Id move -- is 812 in evidence already?
THE COURT: Yes.
MR. ZONEN: It is in evidence. Okay. Never mind.
MR. ZONEN: Tom, do you want to stipulate to this coming in?
MR. MESEREAU: No.
MR. ZONEN: Then Ill lay the foundation. Excuse me.
Q. After the social workers left and your kids went back to Neverland, where did you go on
that
day?
A. Well, that began the process of getting the passports and visas. The first step was
getting the birth certificates.
Q. All right. And did you, in fact, get birth certificates that day?
A. On that day was the application. And when I arrived there, I had to do -- they -- I had
to write a little kind of paragraph stating that it was an emergency; that I had to get out - something about out of the country. I dont recall, but they wanted it fast enough.
Q. Did they say -- who is they?
A. Michaels people.
Q. Well, somebody in particular had you write something?
A. Vinnie. And Frank over the phone. Frank never left our side, whether he was on the
phone or in person.
Q. Vinnie asked you to write something that stated it was an emergency?
A. Yes.
Q. Did he tell you what that was for?
A. Well, thats what -- the information that he had got, because he had asked the birth
certificate people that he needed it immed iately. And they had told him, No, the only way
we can do it, if theres an emergency. And so he had told me that to write its an
emergency.
Q. Who was it who told you, Youre going to Brazil now?
A. Frank, Vinnie.
Q. What did you tell them in response to whether or not you wanted to go to Brazil?
A. They knew I d idnt want to go.
Q. Did you tell them that?
A. Yes, I did.
Q. Tell us why you didnt want to go.
A. I didnt want to go because first, first and main reason, is Gavins doctor is here. He
has to see an oncologist and a nephrologist. He depends on those doctors , first. And
second, I waited a lifetime to find someone I could give a valentine to, and that was Jay.
Q. You didnt want to leave that relat ionship?

A. No, I didnt.
Q. Did you tell this to either Vinnie or Frank?
A. Yes.
Q. What did they say?
A. Well, the part about no, no going to Brazil. Not the part about Jay.
Q. Did you talk to either Vinnie or Frank about medical issues?
A. Yes. I told him I couldnt -- you know, Im trying to negotiate for mine and my
childrens freedom -Q. Uh-huh.
A. -- by saying, you know, Sorry, I cant go, you know. The doctors are here. And
nope, still got to go.
Q. Okay. Why did you ultimately agree to go? I mean, why not just say, Im not going?
A. Because of my parents life, my -- and Jays life.
Q. What does that mean, your parents life and Jays life?
A. Well -Q. What did that have to do with going to Brazil?
A. That they were going to be killed.
Q. Who told you that?
A. Frank. Frank became the worst out of all of them.
Q. Did you have any additional conversations with either Dieter or Ronald?
A. No, the Germans are out of the picture. Theyre no longer in the picture. Slowly -- there
was a transition period where Ronald and Dieter were replaced by Frank and Vinnie. Frank
and Vinnie took the spots of Ronald and Dieter. The Germans are out of the picture now.
Q. Did you tell them that you were going to go to Brazil?
A. No.
Q. Did you start doing things toward going to Brazil?
A. Yes.
Q. All right. And you started to mention something about birth certificates.
A. Yes.
Q. Okay. Now, on this -- was it the same day as the interview that you had with the
department -- with the social workers that you went and started gathering up materials?
A. Yes. Same day.
Q. What materials did you gather?
A. The only thing was the birth certificate application. They -- they assumed that we were
going to get the application on the spot, and so -MR. ZONEN: Counsel? (Off-the-record discussion held at counsel table.)
MR. ZONEN: May I approach the witness, Your Honor?
THE COURT: Yes.
MR. ZONEN: D id you want these separate from the notebooks at the time we introduce
them?
THE COURT: Im sorry?
MR. ZONEN: I think Ive made the decision already. Ill withdraw that question.
Q. Im going to show you three items that are part of one exhibit. We will ultimately staple
it together. At the moment its three separate pages. And this exhibit number is No. 259.
Id like you to look at the three different pages. Do you know what this is?
A. Yes, this is an application for the birth certificate.
Q. All right. And have you seen these documents before?
A. Yeah. This is on -- when we did the application thing, when we had a paper.

Q. At the time you actually got the applications?

A. Yes, yes.
Q. And who were you with when you got those applications?
A. Vinnie, and the people that were following us. I always had a crew following us.
Q. There were others in a separate car?
A. Yes.
Q. Do you know who was in the separate car?
A. No, I never knew. And that was the scar part. Vinnie would always point them out to
me.
Q. Go ahead and look at this document now, which is No. 259.
A. Yes.
Q. And are those, in fact, applicat ions for each of you?
A. Yes.
Q. All right. Whose signature is on those applications?
A. Theres no signature. Just printed.
Q. Its just printed out?
A. Yes.
Q. Is any of that your handwriting?
A. Yes, its all my writ ing.
Q. And then each of the names are on here; is that correct?
A. Yes.
Q. And each of the childrens names are of here?
A. Yes.
Q. Are those, in fact, accurate copies of those applicat ions for birth certificates?
A. I feel they are.
Q. Do you remember where it was they were deposited?
A. In Norwalk. Its by the 605 freeway.
Q. Okay. Now, the third document in here tit led The Registrar Recorder -A. Yes.
Q. -- does have a signature on it, does it not?
A. Yes.
Q. And whose signature is that?
A. Thats mine. This is that emergency thing.
Q. All right. And that you recall signing?
A. Yes. Yes.
Q. And the date on it is what, now?
A. The date on it is February 20th, the day of the CPS meeting. Afterwards.
MR. ZONEN: I would move to introduce into evidence Item No. 259.
MR. MESEREAU: No objection.
THE COURT: Its admitted.
MR. ZONEN: May I approach through here, Your Honor?
THE COURT: Yes.
MR. ZONEN: If you would staple them together as one exhibit.
THE COURT: When you previously marked that exhibit, you meant it to have three pages
when you prepared your notebook?
MR. ZONEN: Yes.
Q. Miss Arvizo, Im going to show you now Exhibit No. 2-6-0. No. 2-6-0. 11 pages,

separate. We will staple them together as one exhibit, No. 2-6-0. Id like you to turn
through the pages of that exhibit, please. And when youve gone through each of the
pages, let us know.
A. Read them?
Q. You dont need to read it in its entirety.
A. Oh, okay.
Q. Just gain familiarity with them.
A. Okay.
Q. Have you seen these documents before?
A. Yes.
Q. All right. Im going to separate them no and Im going to show you four specific p ages
on here of the documents.
A. Okay.
Q. Take a look at those four pages. Tell me what they are.
A. It says up here, Application for U.S. Passport.
Q. All right. Are these, in fact, four pages of applicat ions for a passport for you and you
children?
A. Yes. This isnt my writing.
Q. All right. Thats my next question. Lets begin with -- and perhaps what we can do is
we can nu mber these. This exhibit is 260. Were going to 6221 number these four pages
specifically 260-A, B, C and D. And if I can have four tags for that. Well, lets do it as
separate tags. 260-A, B, C and D. And then well distinguish them that way. Lets start
with the -THE COURT: Do you realize that exhibit is in, already admitted in its entirety?
MR. ZONEN: W ould you prefer to distinguish these four pages from the other -- oh, its
already in evidence?
THE COURT: Its in evidence in its entirety.
MR. ZONEN: Can we just label it with a pen, then, those four pages on the outside of the
vinyl cover, A, B, C and D? Can we do that?
THE COURT: All right. They have numbers within them, dont they?
MR. ZONEN: I -THE COURT: 821 and 822?
MR. ZONEN: Do they?
THE COURT: They do in the book you gave me. Thats in the bottom in the right-hand
corner.
MR. ZONEN: Yes, they do.
THE COURT: Could you just reference those numbers?
MR. ZONEN: I sure can.
THE COURT: All right.
MR. ZONEN: I sure can. Let me just have a moment to make sure I have the right
numbers. (Off-the-record discussion held at counsel table.)
MR. ZONEN: Your Honor, the numbers that Im looking at in the lower right-hand corner,
mine are in red, is that what you have in your notebook?
THE COURT: Theyre not in red, but -MR. ZONEN: Are those numbers Q-1, Q-2, Q-3 and Q-4?
THE COURT: No.
MR. ZONEN: Okay. Thats my concern.
THE COURT: Go ahead the way you were going to do it. Thats fine.

Q. BY MR. ZONEN: Lets do it the way -- were just going to take one, two, three and four,
four documents. And lets start with the first one, and write -- on the vinyl on the lower
left hand, just write A, the letter A. And this one is whose application, please?
A. This one is mine.
Q. All right. Is your signature on it?
A. Yes, my signature is on it.
Q. Is the content of the application your handwrit ing or your printing?
A. No, it isnt.
Q. Do you know who filled this out?
A. Vinnie did.
Q. Did he fill it out in your presence?
A. No, he told me he did.
Q. And where was it that he had you sign it Where were you? Not on the document.
Where are you at the time he had you sign it?
A. I think it was when I was in the motel.
Q. And in this particular one, No. A, does this application have on it a destinat ion?
A. Yes, it does.
Q. What is that destination?
A. The Destination says, Countries to be visited: Italy, France.
Q. Did anybody talk to you about going to Italy or France?
A. No. No.
Q. Did you notice that at the time that you signed that applicat ion -A. No.
Q. -- that it said Italy or France?
A. No.
Q. Was there any discussion about going to someplace other than Brazil at the time that
you signed that document?
A. No. Only Brazil at that time.
Q. All right. Now, lets go to the next one and mark a B on the second one in the lower
hand, on top of the vinyl. And whose picture is that, please?
A. Thats my daughter Davellin.
Q. On the first one, A, is your picture as well, is it not?
A. Yes, it is.
Q. Do you know where those pictures were taken?
A. Yes. I think -- I dont know. I think I remember its a Walgreens. I think. I may be off.
My best estimate is a Walgreens.
Q. They took you there?
A. Yes, Vinnie.
Q. Vinnie took you there?
A. Yes.
Q. Was that a Walgreens someplace near Neverland or someplace in Los Angeles?
A. Here. No, somewhere right here in Neverland. Here in Neverland, I think.
Q. Here in Santa Barbara County?
A. Yes, thats the best that I can remember.
Q. Again, the handwrit ing on this one, or the printing on this one, is that your daughters
printing?
A. No, it isnt.
Q. Is there a signature on there?

A. Yes, it is.
Q. And whose signature is that?
A. I dont know if its my daughters signature. I dont know.
Q. Were you present at a time that that was handed to your daughter?
A. Yes.
Q. Does that appear to be your daughters signature?
A. I wouldnt be able to tell you that.
Q. Okay. Whats the destination on that particular application?
A. This one says, Italy, France.
Q. All right. Move to the next one. And lets mark that one C. Whose picture is that,
please?
A. Thats my son Gavin.
Q. All right. And the applicat ion handwriting is whose?
A. Vinnie.
Q. Is there a signature on that?
A. No, there isnt, of his.
Q. So is there a signature at all?
A. Thats mine.
Q. Okay. And where it says on there Gavin Anton Arvizo -A. Thats printing.
Q. Its printed?
A. Yes.
Q. Thats your signature?
A. Yes.
Q. Gavins signature is nowhere on there?
A. No, it isnt.
Q. Did you sign that at the time you signed the other one?
A. Yes.
Q. The destination on that is what again, please?
A. Italy, France.
Q. Move to the next one, please. And this would be D. Who is that?
A. Thats Star.
Q. The handwriting on that is whose, please?
A. The handwriting is my name.
Q. The handwriting is your name?
A. Yes.
Q. All right. And the signature on that is whose?
A. It is mine.
Q. All right. Did Star sign that at all?
A. No.
Q. And the destination of that is what?
A. Italy, France.
Q. If you havent already labeled that as D, please go ahead and do that, lower left.
MR. ZONEN: Your Honor, as to the collection of these documents, which I would ask to be
bound together and admitted as No. 260, I believe already in evidence; is that correct?
THE COURT: Thats correct.
MR. ZONEN: Are any of these subsections, A, B, C or D, not yet in evidence?
THE COURT: No, the whole package is in.

MR. ZONEN: The whole package is in, all right. May I approach through here?
THE COURT: Yes.
Q. BY MR. ZONEN: Item No. 261, currently in evidence, I believe -THE COURT: Correct.
Q. BY MR. ZONEN: -- is a collection of one, two, three, four, five, six, seven, eight, nine -ten different pages. Id like you to take a moment and just look through them to gain
familiarity with each of them. Have you seen any of these documents before?
A. Yes.
Q. I wou ld like to show you specifically a couple pages in here. Lets go ahead and mark
each of these A through, on the vinyl as we did before, so we can distinguish one page
from the other. Just mark A on the first page here, and then were going to skip through
it.
A. Okay.
Q. The second page well mark B. Put it right there, if you can. W hat is this, No. B,
please?
A. It says, Visa Applicat ion Form.
Q. All right. And is your picture on that?
A. Yes.
Q. Is there handwriting on that application or printing?
A. Printing.
Q. Is that your printing?
A. No.
Q. Did you not fill that out?
A. No.
Q. Is there a signature on there anywhere? Is that your signature?
A. No, it isnt my signature.
Q. Do you know whose signature it is?
A. Its Vinnies.
Q. Is the signature in Vinnies name or is it in your name?
A. His name.
Q. But nowhere on there is your signature?
A. No.
Q. Okay. Now, the photograph thats on there is, in fact, your photograph; is that right?
A. Yes, it is.
Q. Do you remember where that photograph was taken?
A. No, I dont.
Q. Does it list the names of your parents?
A. Yes, it does.
Q. And are their names accurately listed on there?
A. Yes, they are.
Q. First, midd le and last name as to both your parents?
A. Thats correct.
Q. Did you ever see this document prior to the grand jury?
A. This one?
Q. Yes.
A. I dont remember that.
Q. I mean, d id you see it -- did Vinnie ever show you that document?
A. Oh, no. Vinnie never showed me this.

Q. Were you aware at the time that there was an app lication process under way for visas
to go to Brazil?
A. Yes.
Q. He had told you that?
A. Yes.
Q. Did he tell you anything about the applications that would go with it?
A. No. I was aware where Brazil was in the future.
Q. Lets mark this -- lets mark this next page 261-C. Do you know what that document
is?
A. It says something itinerary.
Q. For flights?
A. Yes.
Q. Is your name on that document?
A. Yes.
Q. Where is your name?
A. It says, Miss Janet Arvizo, and it has a -Q. Go ahead.
A. The address is 111520 Trent -- I guess its CT.
Q. Court?
A. Trent -- 111520 Trent Court, Calabasas, California 93102.
Q. Have you ever lived at such an address?
A. I never lived in such an address.
Q. Do you know whose address that is?
A. No, I dont.
Q. Did you know the address for Hamid?
A. I think it was somewhere -- I heard something like San Fernando Valley.
Q. All right. Did anybody ever mention that particular address in your presence?
A. Never.
Q. Did anybody tell you that there was a flight it inerary to Brazil in effect?
A. No, not something like this.
Q. Is there a date on that in terms of the flight out?
A. Yeah.
Q. Can you read it?
A. Yes. It says up here, Date, February 25th, 2003.
Q. All right. The last one was 261-C. Were now going to 261-D, if youd write that in
smaller print right there.
A. D?
Q. 261-D.
A. Oh, 261-D.
Q. Tell us what were looking at there.
A. Were looking at my son Star.
Q. All right. Thats his photograph?
A. Yes.
Q. Taken at the same time and place as yours?
A. I figure so.
Q. The handwriting on that application is yours? The printing, rather?
A. The print, its not mine. Its Vinnies.
Q. The signature at the bottom left?

A. Vinnies.
Q. Its in his name? His signature, his name?
A. Yes.
Q. All right. That one is D. Lets make this one 261-E. Tell us what that is.
A. This is my son Gavin.
Q. Is that the same application for a visa?
A. Yes, it is.
Q. It appears to be the same as the other two youve discussed so far?
A. Yes.
Q. Again, the same handwriting?
A. Its printing.
Q. Im sorry?
A. Printing, the same printing. Printing.
Q. And the signature on the lower left?
A. It is Vinnies.
Q. All right. That photograph of Gavin is the photograph that was taken at the same time
as yours?
A. I figure so.
Q. Do you recall that?
A. I dont remember. This set of pictures, I thought it was -Q. Do you remember any other occasion that pictures were taken of you or your children
for purposes of some official document?
A. No, I dont remember the order.
Q. So this would be F, 261-F, if you could write that perhaps right here in small print.
A. Okay.
Q. Tell me what were looking at now.
A. Were looking at my son Gavins birth certificate.
Q. All right. 261-G. And what is that document?
A. This is mine and my ch ildrens child custody -- I dont know what -- exactly what the
title, but may I read this?
Q. Read the title.
A. Yes, sir. It says, Child Custody and Visitation Order Attachment.
Q. All right. Tell us what that is, to your understanding. What do you believe that
document is?
A. Okay. To my understanding, this is something to do with the restraining order.
Q. Was there any discussion with either Vinnie or Frank about having to have a legal
document?
A. Yes.
Q. And that attested to your custody of your children?
A. Yes.
Q. Do you believe that thats what that document is?
A. Yes, it is.
Q. Who is it who asked you to get that?
A. Vinnie and Frank.
Q. Did they explain to you why you needed such a thing?
A. For the -- the processing of the passports.
Q. Do you know where you got that document?
A. I think -- I dont remember whether I had -- no, I did, I did. I think I -- yeah, because I

always carried one with me all the time, the restraining order.
Q. Do you think that that came from your collection of materials from your restraining
order?
A. Yes, yes, yes, yes. But you asked me from where, so I dont know exactly where, but I
always made it a point to have it with me.
Q. Why did you carry a copy of the restraining order -A. Because if -Q. Let me finish the question. Why did you carry a copy of the restraining order with you
at all times?
A. Because of David.
Q. Okay. Thats 261-G youre looking at. Thats the custody order. 261-H would be who,
or what?
A. Oh. This is a birth certificate for my son Star.
Q. Thats 261-H.
A. H?
Q. Yes. 261-I is the next one. And what is that?
A. This one is a visa applicat ion form, and my daughter is on it.
Q. This is for Davellin?
A. This is for Davellin.
Q. All right. The printing on that form is whose printing?
A. This is Vinnies.
Q. All right. The signature on the bottom is whose?
A. Vinnies.
Q. The photograph in the document is whose?
A. It is Davellin, my daughter.
Q. And the photograph was current for that time; is that correct?
A. Yes, it is.
Q. That was a photograph of her at about that age?
A. Yes.
Q. J, which would be 261-J.
A. Okay.
Q. Tell me what that is.
A. This is a birth certificate for my daughter Davellin.
MR. ZONEN: Your Honor, Im not certain that 261 is in in its entirety or if at all. If not, I
would move to introduce into evidence at this time 261.
THE COURT: 261 is in evid ence.
MR. ZONEN: Its in evidence.
Q. On the 20th and the 21st, do you remember where you stayed the night of the 20th; in
other words, after you were with Vinnie gathering up the birth certificates?
A. For most of the part on the 20th, I stood in Jays apartment by myself.
Q. And then that night, did you spend the night in Jays apartment?
A. Thats what Im talking about.
Q. Your children were where?
A. They were already in Neverland.
Q. The next day, did you meet up with Vinnie again?
A. Yes.
Q. Do you recall where you went on that next day, the 21st?
A. The next day, the best I can rememb er is Marc Schaffels house, and he -- and Vinnie

picked upp the passport applications from his house. Thats the best I can remember.
MR. ZONEN: Could I approach the witness, Your Honor?
THE COURT: Yes.
Q. BY MR. ZONEN: Im going to show you No. 806. This is in a clear evidence bag which
has a separate number of 1732. The court exhibit for identif icat ion, No. 806, pulling out
the content.
A. And Im being followed this whole entire time.
Q. Thats okay. Thank you. Inside this exhibit are five p ieces of paper. Would you take a
look at those, please? Are those, in fact, duplicate copies of birth certificates -A. Yes.
Q. -- of you and your children?
A. Yes. Those are originals.
Q. And the cover letter Affidavit to Amend Record?
A. Yes.
Q. County of Los Angeles?
A. Yes.
Q. And Im handing you four items now. Take a look at those.
A. Finally. Finally.
Q. Well, just look at them one at a time and tell us what they are.
A. These are -Q. Go ahead and look at all four first. What are they?
A. Theyre my passports.
Q. Now, had you ever seen those documents before today, those passports?
A. No.
Q. All right. Is this what you understood to be the passports that they applied for at the
time?
A. Yes. I had seen them when Vinnie was holding on to them -Q. At some point in time -A. -- in Neverland.
Q. Lets go ahead and put these separate. I dont know if 806 is not in evidence. I would
move to move 806 into evidence at this time.
MR. MESEREAU: No objection.
THE COURT: Its admitted. 6238
THE WITNESS: These are the ones that Bill wrote for that I wanted.
Q. BY MR. ZONEN: Bill is Bill Dickerman?
A. Thats right.
Q. You just looked at those four passports. And those four passports are of you and your
children; is that correct?
A. Yes.
Q. Now, did you mention that you had seen them at some time previous?
A. Yes.
Q. When was that that you saw them?
A. In Neverland.
Q. And do you remember when at Neverland it was?
A. Yes. Afterwards.
Q. And in whose possession were those passports?
A. Vinnie.
Q. How is it that you happened to see them in Vinnies possession?

A. Because he was rummag ing through his like, I dont know what. I dont know. It kind of
looks like a suitcase, but its not a suitcase. Its a bag that you open up like this, and he
was rummaging through the things. And thats where I seen my passports. And I told him,
Could I have them? And he said, No.
Q. How did you know that they were your passports?
A. Because he was rummag ing through all these things, and then I happened to see them,
and I said, Is that my passports? And he said, Yes.
Q. Okay. Did you see more than just the cover of them?
A. No, I -- just the cover.
Q. But you asked him if they were yours?
A. Yes.
Q. And he said?
A. He said, Yes.
Q. Did you ask to have them?
A. Yes.
Q. And what did he say?
A. He said, No.
Q. Did he say why he wasnt giving them to you?
A. No, he just said, No.
Q. Now, at some later time, you retained an attorney by the name of Bill Dickerman?
A. Yes, I did.
Q. All right. And did he request, by way of letter that was shown to you, to have these
passports returned?
A. Yes, he did.
Q. Were they, in fact, ever returned to you?
A. No, they were never returned to me.
Q. Prior to today?
A. Prior to today.
Q. Have you ever seen them?
A. I havent seen them.
Q. Where did you stay after you left on the 21st? Where did you go after the 21st of
February; do you recall?
A. Neverland. After Marc Schaffels application, I went to Neverland.
Q. Let me ask you about Marc Schaffel. Who is Marc Schaffel? Who do you understand
Marc Schaffel to be?
A. They just -- I know now per the investigation, its different.
MR. MESEREAU: Objection.
Q. BY MR. ZONEN: Hold on. At the time, did you know the name Marc Schaffel?
A. No, I didnt. But I had spoken to a Marc when the Germans were there.
Q. All right.
A. Marc -Q. In person -A. Marc Schaffel.
Q. All right. In person or over the telephone?
A. Over the telephone.
Q. Did this person identify himself to you?
A. Yes. He said he was Marc Schaffel.
Q. He said he was Marc Schaffel?

A. Yeah, and then thats the one that I told about the audio you can hear. And I said he
was very unkind, because he was saying I had to do the video, and I thought he was one
of the Germans.
Q. This was a person you spoke to prior to doing the rebuttal video?
A. Yes.
Q. And he was talking to you about the video?
A. No. He said I had to do the video. And this is before Jesus.
Q. All right. Now, at some point on the 21st you were taken to a home?
A. Yes.
Q. Did somebody tell you that was Marc Schaffels home?
A. Yes, Vinnie did.
Q. Did you meet Marc Schaffel?
A. No, I didnt.
Q. To this day, have you ever seen a picture of him?
A. To this day Ive never met him.
Q. All right. What were you doing at Marc Schaffels house?
A. Picking up the applications for passports.
Q. Were you with your kids or by yourself?
A. No, I was by myself.
Q. With Vinnie?
A. With Vinnie and the people that would -Q. Youre saying there was another car of people?
A. There was always someone following us.
Q. Did you know who those people were?
A. I didnt know at the time.
Q. Could you tell how many people were in that car?
A. Yes, sometimes there was two. And sometimes there was three. And sometimes there
was one.
Q. Did you recognize any of them at any time?
A. No.
Q. You already knew Asafs appearance.
A. Yes.
Q. Did you know if Asaf was ever one of them?
A. No, I just happened to see Asaf one other time, and - I think so - that was during that
Calabasas period.
Q. All right. Where did you go on the 21st? Where did you stay after that?
A. On the 21st, I stood at Neverland.
Q. And for how long were you at Neverland?
A. Until the 25th.
Q. And on the 25th, you went where?
A. To the hotel. I dont know if its hotel, motel, in Calabasas.
Q. All right. Do you remember the name of it?
A. I think its Country Inn & Suites.
Q. In Calabasas?
A. Yes.
Q. All right. Let me go back to that period of time from the 21st to the 25th that you were
at Neverland. Where did you stay during that time?
A. In the guesthouse.

Q. And were your children there as well?

A. Yes.
Q. Where did Davellin stay?
A. In the guesthouse next to me.
Q. Not your unit?
A. And -- and I dont mean to say guesthouse. Its actually one building divided into
four, and theyre actually just bedrooms.
Q. Four separate units in a building?
A. Four separate units?
Q. Yes. And you had one of the units?
A. Yes.
Q. And Davellin had another?
A. Yes.
Q. Where were the boys?
A. The boys were in the house.
Q. And thats Gavin and Star youre referring to?
A. Yes, yes.
Q. They were staying in the house?
A. Yes.
Q. Did they stay in the house the entire time?
A. Yes.
Q. Do you know if Michael Jackson was there during that period of time?
A. At that time, I dont know.
Q. Do you have a recollection of seeing him during that time?
A. At that time, I dont remember.
Q. Were you seeing your sons throughout that period?
A. No.
Q. The 21st through the 25th?
A. No.
Q. Where were you during the day?
A. In the guesthouse.
Q. Did you ever leave?
A. Not really.
Q. Where did you take your meals?
A. In -- in there.
Q. In the guesthouse?
A. Yes, I did.
Q. Did you ever go into the main house for meals?
A. No. No.
Q. Did you ever walk around the property?
A. Um, I think in that whole period from when I returned, from the 21st on, Im being
generous if I say -- if I may, my best estimate, if I say twice.
Q. Twice what?
A. I walked out into Neverland. And thats my best -- and were talking about the period
from the 21st on.
Q. Were you having -- were you spending time with your sons during that four-day
period?
A. No.

Q. On the 25th, where did you go?

A. On the 25th?
Q. Yes. The 25th of February.
A. Okay. The 25th of February, went to my sons doctors appointment. Then from there, I
went to -- to Jamies, and then from there the hotel.
Q. All right. Lets talk about the first two that you mentioned.
A. Okay.
Q. There was an appointment you had, I assume with Gavin; is that right?
A. Yes, I did. And Vinnie was there.
Q. And Vinnie went with you?
A. And the people that were following us.
Q. And another vehicle behind you?
A. Yes.
Q. And did you go with your other two children?
A. All three of my kids.
Q. All of your kids went?
A. Yes.
Q. The doctors appointment was where?
A. In Kaiser. That was his cancer specialist, his oncologist.
Q. And did they make another appointment for him or for testing at that time?
A. Yes. Yes, they did.
Q. What was that appointment?
A. That was -- I dont know what the correct medical term is, but Gavin has to go -- yes,
he is a healthy boy, but hes got a lot of medical issues, and they have to watch out for -and so they -- I dont know what this one is called. I dont know whether its called a CT
scan, ultrasound. The main purpose of that was to check his kidney, because theres a
constant concern that Gavin could possibly lose his kidney.
Q. Is this a concern that exists today?
A. It still exists today.
Q. All right. Now, the -- he had an appointment with the doctor. So he actually visited
with the doctor on the 25th?
A. Yes.
Q. During that visit, where d id Vinnie go?
A. Oh, Vinnie was right there.
Q. What is right there?
A. With us, with me, the whole ent ire time with us. And usually our doctor visits, me and
the kids are always like a group, you know.
Q. All right.
A. Because when I go to the doctors appointments, yes, I -- you know, Sergeant Mommy.
But Im always like this, weak in my knees, because I never know what is going to
happen, I have to have, after the vis it. So prior to the visit, I am hold ing my breath.
Q. Did Gavin actually have an examination with the doctor?
A. Yes.
Q. I assume that was separate from where Vinnie was.
A. Yes.
Q. Were you present during -A. No, Vinnie was right there. Vinnie had expressed to me that there was something they
could listen to me.

Q. I dont understand what right there means.

A. Right there. Right outside the doctors room.
Q. Is that where you were?
A. Yes.
Q. So he was with you?
A. And he was with the kids.
Q. All right. And the kids were there, too?
A. Yes.
Q. Is this a waiting room of some kind?
A. No, it isnt. Its actually the hallway outside the doctors room.
Q. When you left the doctors office on the 25th, did you have an appointment to have an
appointment to return to the doctor at some time in the future?
A. Yes. I -Q. Was that for an examination or a test?
A. No, that was a test. Purely a test. No doctor visit whatsoever.
Q. And what day was that?
A. March 10th.
Q. What was the test?
A. I dont know. Like I told you, Mr. Zonen, I dont know whether it was one of those CT
scans or ultrasound. The main purpose of that test was to check on his kidney.
Q. All right. Was that the day that you were supposed to turn in a sample of -- a collection
of his urine?
A. Yes.
Q. Now, lets go back to this, now, again.
A. A 24-hour collection.
Q. A 24-hour collection. Were going to cover this in just a moment. Lets go back to the
25th.
A. Okay.
Q. You said that you had a doctors appointment with all of you, and then you went to,
you said, The Laugh Factory?
A. Yes, I did.
Q. What was your reason for going to The Laugh Factory?
A. Okay. We were already on Sunset Boulevard. And the Laugh Factory is not that far
from Kaiser, so I tried to -- I tried to -- Im -- Im trying -- all along through this period,
Im trying to reach people to help me, to let them know the best that I knew at that time,
because it kept evolving into more and more escalation.
MR. MESEREAU: Objection; nonresponsive.
THE WITNESS: Okay. Thats my answer, though.
THE COURT: Just a moment, please.
THE WITNESS: Yes.
THE COURT: I think it was nonresponsive.
MR. ZONEN: I think it was.
Q. Now, you were going to go to The Laugh Factory. Excuse me, Im sorry. Were you
expecting to meet somebody at The Laugh Factory?
A. Yes.
Q. Who were you expecting to meet at The Laugh Factory?
A. I was expecting to meet just Jamie. And I think that Jamie on his own called Mr.
Dickerman.

Q. Did you know who Mr. Dickerman was prior to that day?
A. Yes.
Q. And how did you know who Mr. Dickerman was?
A. Because Jamie had told me that Mr. Dickerman could possibly maybe help put a stop to
Gavins being ridiculed and called gay and all these 6250 things.
Q. Do you mean the television show?
A. Yes, because they were making no effort.
Q. Did you understand Mr. Dickerman to be an attorney?
A. Yes, I did.
Q. Did you understand him to be Jamies attorney, Jamie Masadas?
A. Yes, I did.
Q. Did you tell V innie in advance that you were going to go visit with a lawyer?
A. No, I didnt.
Q. Why not?
A. Because I was -- there was -- there was consequences, consequences for going out of
their plan.
Q. Okay. When you arrived at The Laugh Factory, what did you tell Vinnie was the
purpose of going to The Laugh Factory?
A. Just -- just visit Jamie.
Q. Did you tell him who Jamie was?
A. Yeah, I had told him Jamies a good friend, and thats about it. And so the second I
went in there, there was -- in two minutes I had to leave.
Q. All right. You went in there. Did you go in with any of your children?
A. I think it was one of them. He had two of them stay with him. And then now Franks on
the phone going crazy because Im talking to Jamie, so -Q. Hold on a second. Hold on a second. Youre inside The Laugh Factory right now?
A. Yes.
Q. How do you know Franks on the phone with anybody?
A. Because Davellin came in running and said,Mommy, lets -- Franks on the phone,
and hes mad and hes going crazy.
Q. All right. How long were you inside talking to Jamie at that time?
A. My gosh, it was like -- not that long. Not that long.
Q. What is not that long? Five minutes? Ten minutes? 20 minutes? Give us a sense of it.
A. My best estimate -- my best estimate, less than maybe ten minutes.
Q. Less than ten minutes?
A. yes.
Q. All right.
A. And thats my best estimate.
Q. Where did you go after that? This is the 25th. Where did you go after that?
A. Then they -- then Vinnie had told me that -- do you just want me to tell -- not what
happened prior?
Q. Yes, just where did you go after you left 6252 The Laugh Factory?
A. The motel.
Q. The motel in Calabasas?
A. Yes. Or hotel, the Country Inn.
Q. How many days did you stay in Calabasas?
A. The 25th through the 2nd of March.
Q. Thats a 28-day month, February.

A. Yes.
Q. So you were there five days?
A. Yes.
Q. 25th, 26th, 20 -A. And I didnt know I was going to stay there.
Q. Did they tell you why you were there as opposed to going back to Neverland?
A. Yes, Vinnie had said that the killers had arrived at -- at Neverland, so we werent going
to be able to go back. We had absolutely no kind of piece of luggage with us. Nothing.
That was a complete surprise.
Q. So -A. Yes.
Q. -- where did Vinnie say you were going after the Calab asas hotel?
A. After?
Q. Yes.
A. Not during?
Q. Well, while you were at Calabasas at that hotel, Vinnie told you that it was not safe to
go back to Neverland?
A. Thats right.
Q. All right. Did he tell you where you were going to go?
A. We were going to a motel.
Q. And after the motel?
A. After -- now, what are you talking? During?
Q. You said you were going to go to a motel. You were in a motel.
A. Yeah, thats it.
Q. Did he tell you you were going -- how long did he tell you you were going to have to
stay at that motel?
A. No, he didnt. It was always one day. One day. Every day everything changed.
Q. You had no other clothing with you?
A. No.
Q. All your clothing -A. No clothing.
Q. -- was at Neverland?
A. Was at Neverland.
Q. At some
A. Every piece of clothing was at -- in Neverland that I had with me.
Q. At some point in time did you go shopping?
A. Yes.
Q. Where did you go shopping?
A. And this is -- again, I had told them this is to replace -- because I wouldnt accept
anything from them. It was only in replacement. They said it was not -- not safe to return,
so they were going to replace the childrens items, and thats how they tricked us.
Q. All right. Ult imately how long did you stay at that hotel at Calabasas?
A. From February 25th to March 2nd.
Q. And during that time, on how many of those days did you go shopping for clothing?
A. One day.
Q. Was there any discussion during that five-day period of time as to when you were
going to be going to Brazil?
A. Yes. It was -- we were going to Brazil. Thats it.

Q. Did they give you a day? Did they say in a week? In a month? Did they say when?
A. No. No, the second they get them, the second were going to go.
Q. The second they get what?
A. The second they get all of this covered.
Q. The documentation that they needed?
A. Yes, uh-huh.
Q. Did you believe at that time that you were actually going to go to Brazil?
A. Yes. And this is the period when I called Wheezy, Louise Palanker.
Q. You called her from the hotel in Calabasas?
A. No, I didnt. I dont know where I was. I dont know where I was, but I called her
during this period. That I can remember clear.
Q. All right. Who was at the hotel during this five-day period, other than you and your
three children?
A. Frank. Vinnie. Johnny. This -- another guy that I never saw that always would stand
outside my window. And then these other people that I never came to find out who they
were.
Q. How many other people are we talking about?
A. Like I said, sometimes in the car there was one, sometimes there was two, and
sometimes there was three.
Q. Were they there all the time?
A. Yes.
Q. Or one of them all the time?
A. Yes. Oh, there was -- nobody left my side at all.
Q. Were Frank and Vinnie with you the entire time?
A. No. It was these people that were all the time.
Q. Somebody named Johnny you just mentioned.
A. Yes.
Q. All right. What does he look like?
A. Hes -- hes big.
Q. Im sorry, I asked you about Johnny.
A. Hes big.
Q. Big?
A. Yes.
Q. What color hair does he have?
A. Its a light color.
Q. Was he there the entire time?
A. Yes, the entire time.
Q. And day and night?
A. Day and night.
Q. Was there some -- if you walked out of your door, did you always see somebody there?
A. Yes. Absolutely. Outside my door, and outside my window, and wherever we went.
MR. ZONEN: If I could approach the witness, Your Honor.
THE COURT: Yes.
Q. BY MR. ZONEN: Showing you No. 26, please, would you tell us who this is?
A. This is Johnny.
Q. Thats Johnny?
A. Yes.
Q. During this period of time d id you have telephone calls with anybody else?

A. Me?
Q. Yes.
A. But my phone calls were being monitored and listened to.
Q. Somebody told you that?
A. Yes.
Q. Who?
A. Frank and Vinnie.
Q. Did you believe that to be true?
A. Yes, I did believe them.
Q. Notwithstanding that belief, did you make phone calls from the hotel?
A. Yes, I did. What I did, I tried to give -- drop clues to every person. I figured -- I figured
by all -- this was all going to be resolved by Gods miracles, and I figured one day -- there
will be one day that all these people could give clues as to when me and my children
would have d isappeared, clues, clues, and this way this puzzle would have been put
together.
Q. Who did you call during that period of time when you were at the hotel?
A. I called my mom, but I tried to like whisper to her in Spanish, and she said, Que? And
so -- and -Q. Your moms a little hard-of-hearing, isnt she?
A. Yes, so -- so that didnt help me.
Q. All right. Did you tell your mother you were going to Brazil?
A. No, I dont think so.
Q. She didnt know?
A. No.
Q. Who else did you call?
A. But Aja did.
Q. You called Aja during this period of time?
A. Yes, yes. I sneaked it in there.
Q. You called her from where?
A. From the hotel.
Q. Okay. And you say you sneaked it in. W hat does that mean?
A. Yes, yes. Like, you know, I was letting her -- I was talking and kind of dropping people
clues. Oh, you know, just kind of making -Q. Hold on a second. The question was, how did you sneak a call in? W hat does that
mean?
A. Okay. No, no, all my conversations were being monitored and listened to, all of them.
What Im trying to say is, I sneaked it in a way where I -- I said it to her, hoping that
nobody had listened in on what I had told her.
Q. Who else did you call besides Aja, your mom and Louise?
A. Aja, my mom, Louise -- but I didnt call Louise from the hotel. I dont remember where
I called her from.
Q. Okay.
A. Um -- um, I think it was one of my cousins. My mom.
Q. Did you call Jay during that period of time?
A. Yes, I called Jay. I hadnt called him for days.
Q. And you did call him from that hotel?
A. Yes.
Q. All right. Did you call the police during that time?

A. No.
Q. Why not?
A. Because my calls are being monitored, they were being listened to, my parents are in
danger, Jays in danger, and who could possibly believe this?
Q. What do you mean by, Who could possibly believe it? What was your concern in that
regard?
A. That nobody would believe me. And thats because Frank said nobody would believe
me.
Q. Did you, in your conversation with Jay from the hotel, tell him what was going on?
A. No.
Q. Did you tell him you were going to Brazil?
A. I told him the same way I tried to talk to Aja. Everything was always broken. It was
never complete. So in my -- in the midst of a regular conversation, Id throw something
in, hoping that it hadnt been heard, and yet that this -- that part could stick in
somebodys mind, and hopefully one of these days this puzzle could be put together. I
tried.
Q. After five days there, where d id you go?
A. Back to Neverland.

Q. So this is now on the 2nd of March; is that right?

A. Yes.
Q. And how long did you stay at Neverland from the 2nd of March?
A. Till March 10th.
Q. During that eight-day period of time, where d id you stay?
A. Like I told you, Mr. Zonen, from the 21st on, when I was at Neverland, I just stood in
the room. Thats it. And that was per their order.
Q. Was there somebody around?
A. Yes. Either Frank or Vinnie, or both. But this guy Joe, he was really scary. You know
whats more scary? When youre not spoken to and youre just watched. That was really
scary.
Q. Do you know Joes name?
A. I dont know his last name, but hes -- he is extremely loyal to him, to Mr. Jackson.
Q. What does he look like, Joe?
A. He is tall, kind of balding, a little bit of hair you can see.
Q. Do you mean a shaved head?
A. Yes.
Q. Do you know his last name?
A. I dont know his last name.
Q. Did you ever hear it before?
A. No. Always -- the last names I wou ld always find out by accident. They never told me
their last names. Only when I would overhear them.
Q. What was it about Joes behavior that frightened you?
A. That -- that this particular specific time, for example, they would stand right outside my
window, and Frank and Vinnie would talk to him, and then theyd turn around, Joe would
go like this (indicating), and hed go back and like this (indicating) and just stand there.
Q. Was Chris Carter there during that time?
A. Chris Carter. Um, I dont know. I dont know. I stood there inside the room.

Q. Was Jesus there during that time?

A. Yes. And whenever Jesus would -- whatever, come into my room, Id go -- you know,
right there in my room Id try talk to him, and he would tell me, I cant help you.
Q. Where were your boys during this time, from the 2nd to the 10th?
A. From the 2nd to the 10th, they were -- they were with Michael. This time I did see him.
Q. Could you tell if he was there the entire time, from the 2nd -A. Oh, yes.
Q. Who are we talking about now?
A. Yes, because Id see him. Theyre running around with my kids like crazy, crazy nuts,
you know. You know, I -Q. All right, wait. You said him. Who is him?
A. Mr. Jackson.
Q. All right. And they were running with him. Who are they?
A. My boys.
Q. Like nuts, explain that to me. What does that mean?
A. Yeah, you know, I could see through my window at a distance. I know theyre my kids,
but theyre this little. When you see someone really far, theyre about this little, and I see
him this much bigger. Its clearly them, them rid ing around in a go-cart and -- goodness
gracious.
Q. Was there something about your boys behavior at that time that was alarming you?
MR. MESEREAU: Objection; lead ing.
THE WITNESS: No guidelines.
THE COURT: Just a minute. Overruled. You may answer.
THE WITNESS: No guidelines.
Q. BY MR. ZONEN: What does that mean, no guidelines?
A. Theres no guidelines. Theres -- thats 626 it. Ive lost my kids.
Q. Did you have any contact with them during this period of time?
A. No.
Q. And no guidelines. How were they actually behaving? Tell us how they were behaving
at that time.
A. Doing everything they wanted with Mr. Jackson.
Q. All day long?
A. All day long, all night long.
Q. Where were they staying at night?
A. With Mr. Jackson.
Q. All right. Did you ever go into Mr. Jacksons residence at night?
A. No.
Q. Were you able to go into his residence?
A. No. From -- like I told you, Mr. Zonen, from the period of the 21st on, no. Id be
generous if I say, as my best estimate, two times.
Q. Did you tell the social workers from the Department of Child & Family Services, did you
tell them that you would check on your children inside the house throughout the night?
A. With the DCFS meeting, if you take a smaller version of the video that we did on that
same day, if you make it smaller, thats what -- thats what was discussed.
Q. Right. But did you, in fact, tell them that?
A. I could have. I could have.
Q. Did you know where your children -A. And then but dont forget about the other additional tape-recording thing that Asaf had

left there.
Q. Okay. Did you know where the boys were sleeping inside the house?
A. No. At that time. Now I know.
Q. At the time, where do you believe that they were sleeping?
A. I believed that the children stayed with children. Thats what I believed.
Q. Do you mean his own children?
A. Well, with other children, because -- just children. Thats what I believed.
Q. Did you ever ask Gavin or Star where exactly in the house they were sleeping during
that time?
A. At that time, no.
Q. Did you ever have any conversations with Michael Jackson during that period of time
from the 2nd of March until the 10th of March?
A. No. Zero. They were having too much fun.
Q. Did you have any conversations with either Vinnie or Frank during that period of time?
A. Oh, God. A lot of them.
Q. And -A. I didnt have conversations. They -- they were coming at me.
Q. And what types of things were they telling you at that time?
A. And just following their orders. Oh, this is one of the things when they were trying to
make me sign that -- that waiver.
Q. That waiver.
A. And I said, No, no, Im sorry, but my signing days are over.
Q. Were your children in school during this period of time that they were at Neverland?
A. No, no school.
Q. Were they getting any private instruction while they were at Neverland?
A. No. See -Q. No, did you complain about that to anybody?
A. I brought it to Mr. Jacksons attention -THE REPORTER: And to whose attention?
THE WITNESS: To Mr. Jackson, on that first -- prior to that meeting with Jesus.
Q. BY MR. ZONEN: During the initial stay?
A. Yes, the initial -Q. Early in February?
A. Yes.
Q. What did Mr. Jackson say to you about your children getting tutoring or schooling?
A. That Ronald and Dieter would fix everything. 6266
Q. Now, during this subsequent stay from the 2nd to the 10th of March of 2003, did you
complain about them not getting any schooling during that time?
A. No. My comp laining -- my speaking days were over, because the second I would say
something, Ahh.
Q. The second you would say something, somebody would do something?
A. Yes. Frank would holler at me.
Q. Were you aware that there was a private school located near Neverland?
A. No.
Q. Did you ever ask them to send the children to a private school?
A. No.
Q. At some point in time did your children visit a dentist while they were at Neverland?
A. Yes.

Q. For what purpose?

A. Remember how I told you I kept trying to do -- do things, Mr. Zonen, about ways -ways of getting out of there? And so I had told them that if I didnt get -- if I didnt get the
orthodontists teeth -- braces removed, that they will -- the social workers were going to
call the police. And originally, Ronald and Dieter, way when 6267 the Germans were
involved, they had said that it was bad PR for the police to get involved for Mr. Jackson.
So I used that, and I told them that they were going -- if I didnt get the braces removed,
that they were going to call the social workers.
Q. All right.
A. So I used that, because what I was trying to do was go to my orthodontist, so this way
it was someone I knew that could possibly believe me.
Q. All right. Now, whose idea was it to go to a different orthodontist?
A. Their idea.
Q. And did you, in fact, go to a different orthodontist?
A. Yes. And get this: After the orthodontist was closed, no other patient was there. It was
after hours, and with that scary guy Joe, and being put on notice that I was being listened
and monitored. So again, I, the mother, failed again.
Q. All right. Now, did they take off the braces at that time?
A. Yes, they took off the braces.
Q. Were they, in fact, ready to have their braces removed?
A. They were not ready to take off the braces. My children were supposed to have -- I
think one of them was, I think two years of orthodontistry. And the other one had -- Star
needed -- required orthodontic care, and I think it was about three years. And so we -the kids only had -- at that period, I think they only had them on for -- oh, I think they
only had had them on at a period of six months at that time. And thats my best
estimates. So they werent supposed to be taken off.
Q. Why didnt you simply change your mind about it and say, No, we wont take them
off?
A. Then they would have known then that Im trying to escape. Because every time I tried
to leave, there was huge consequences.
Q. Did you have a talk with anybody at Neverland about moving out of your apartment on
Soto Street?
A. This was -- it was an evolvement of different things. First evolvement was when -because the killers had gone to my apartment, I had to move out and different things. But
this only came after -- after they found out that I had in my home Michaels letter, a
rabbit that he had given my son, which he wanted him to call him Michael, just different
pictures. So my apartment was meaning less to them until they found out that Michaels
things were there.
MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE WITNESS: Thats my whole answer.
THE COURT: Just a moment. Just a moment. Its sustained.
Q. BY MR. ZONEN: Lets back up a couple notches if we can.
A. Okay.
Q. The first conversation that you had about moving out of the apartment on Soto Street
was with whom? Just tell me the name.
A. With Ronald and Dieter.
Q. That was with Ronald and Dieter?
A. Yes. Way back.

Q. So that was way back?

A. Yes.
Q. And did they talk to you at that time about moving out of the apartment?
A. Yes.
Q. At some point in time, did you tell -- did you tell somebody that in your possessions at
that apartment -A. Yes.
Q. -- were letters from Michael Jackson?
A. Yes.
MR. MESEREAU: Objection; leading.
THE COURT: Overruled.
Q. BY MR. ZONEN: That answer was Yes?
A. Yes.
Q. With whom did you have that conversation?
A. With Ronald and Dieter.
Q. Now, in fact, where were those letters?
A. In my apartment.
4 Q. And where in your apartment were they?
A. Okay. They were in different places. But one specific place that I remember is, I had a
clay pot and it was Gerbera daisies, artificial Gerbera dais ies. They werent real. So when
you lift it up, its empty, because the artificial flowers do not belong to that pot. You can -you can easily lift it up and out.
And I had placed them there. The -- and the reason that I had placed them there is
because Davi is very sneaky. He does things, so I didnt want David to get his hands on
them.
Q. The letters were from Michael Jackson to whom?
A. To Gavin. Purely to Gavin.
Q. Had you read those letters?
A. Who?
Q. You.
A. Me? Yes. Yes.
Q. Why did you keep them at all, those letters?
A. Because they -- Michael had sent them, and they said I love you to Gavin, and, Love
you, Apple Head, and Doo-Doo Head. Just -- I just kept them, you know, along with all
these other things that I had ever received from other people.
Q. You had other letters there as well?
A. Yeah. From other people, too.
Q. Now, did you tell either Dieter or Ronald where those letters were?
A. No, I didnt. I just said they were in my apartment.
Q. Did you tell them that anything else was in your apartment that had come from
Neverland or from Michael Jackson?
A. Yeah. Pictures. And then the rabbit. I was a little pretend rabbit, not a real rabbit.
Q. All right. A rabbit from Neverland?
A. Yeah, it was just a rabbit that came in a gift basket.
Q. Where was that kept?
A. That was out in the open.
Q. Now, you said Ronald and Dieter talked to you about moving out of the apartment?
A. Yes.

Q. At some point did either Frank or Vinnie talk with you about moving out of the
apartment?
A. Oh, yes.
Q. Who was the first, between the two of them, to the best of your recollection?
A. Frank, on the phone, telling me it was so dangerous.
Q. At some point in time did you move out of the apartment?
A. Yes, I did.
Q. Who did you tell that you were willing to move out?
A. I didnt tell them that -- that yes, for sure. That I would think about it.
Q. Who is it that you told that to?
A. To Frank. But it wasnt a Yes. I would think about it.
Q. Were you ultimately moved out of that apartment?
A. Yes. And this time I had said, No. I thought about it, and then it was a No.
Q. Do you recall if you signed anything that reflected your willingness to move out of that
apartment?
A. I didnt sign a thing.
Q. Did you have a conversation with anybody about moving out?
A. Yeah. Frank and Vinnie. And then Ronald, Dieter in the beginn ing.
Q. All right. Now, was there any rent that was owed on that apartment at that time?
A. Thats another thing that they had found out. It had slipped out -Q. Hold on just one second.
A. Okay.
Q. The question was, was there any money that was owed on that apartment?
A. At that current time, it was -- no.
Q. How long had you lived in that apartment?
A. Five years.
Q. Was there any point in time during that five-year period where you did not pay rent?
A. Yes.
Q. And when was that?
A. That was when Gavin was ill.
Q. And for how many months was that?
A. That was two months.
Q. And what did the landlord say about that?
A. One -- one month he gave -- he gave us. And the second one was owed to him, and he
had told us to pay it when we can and its okay.
Q. All right. One month was simply grat is; it was given to you -A. Yes.
Q. -- for free?
A. Yes.
Q. And the second month you owed?
A. Yes.
Q. How much money was -- what was the rent for that apartment?
A. My apartment rent was 425. But I was current to the point that -- since 2000. That was
since 2000.
Q. All right. So at the time that you were at Neverland for this period between the 2nd
and the 10th -A. Was already 2003. And I was still current on my month (sic), every month.
Q. How about that one month that you were going to pay back at a later t ime? Was that

ever paid back?

A. No. Never.
Q. So there was still a -A. Yeah, its something that I knew.
Q. There was still 400-plus dollars that -A. No, it was actually -- it was two months that werent paid. But he said one was okay,
and one was -- but it was two.
Q. Well, tell me, what was the amount that was owed at -A. 850 from the year 2000. Nothing current. My rent was paid current.
Q. All right. 850 would reflect two months; is that right?
A. Yes.
Q. And that was -A. Of the year 2000.
Q. Didnt you say that one of those months was forgiven?
A. Yeah, thats what he said. But I didnt -- I still didnt -- you know.
Q. It was either 425, one month, or 850 for two months?
A. It was for two months, but he had voluntarily said that one month is okay.
Q. All right.
A. But -Q. Did you believe you owed 850?
A. Yeah.
Q. All right.
A. Yes, I did.
Q. Do you know if somebody paid off the balance of the rent that was owed?
A. Yes.
Q. Do you know who that was?
A. I came to find out -- it had slipped out of Vinnie that they didnt want no one to be able
to -- to miss me or the kids, or start raising questions as to where the kids were. And
usually because of -- this is what Vinnie said; that they would possibly start looking for me
because I hadnt paid my rent.
Q. Do you know if somebody paid off that balance?
A. Yes, I became aware of that.
Q. Do you know who it was that paid it off?
A. No, I dont. That part I dont know.
Q. It wasnt you?
A. No.
THE COURT: Counsel? Take a break. (Recess taken.)
MR. ZONEN: May I approach the witness, please?
THE COURT: Yes.
MR. ZONEN: Yes, please. Madam Clerk, is 276 in evidence? I dont believe it is. 276.
THE CLERK: It hasnt been identified yet.
Q. BY MR. ZONEN: All right. Im showing you now Exhibit No. 276, which is two separate
sheets, the second one having two documents in it, front and back. And do we have that
pen that you had initially? And again, on the vinyl of 276, not on the document itself,
perhaps right here, tell us what -- lets mark A for 276-A. And is that an envelope?
A. Yes, it is.
Q. To whom?
A. To me.

Q. From whom?
A. From my old landlord.
Q. Okay. At the Soto Street address?
A. Yes.
Q. And the address to where that was sent?
A. The address where it was sent was my mothers home address.
Q. In El Monte?
A. In El Monte.
Q. Lets go to the second document, No. B. And mark that B, if you would, please, on
the vinyl again.
BAILIFF CORTEZ: You have to speak into the microphone.
THE WITNESS: Oh.
Q. BY MR. ZONEN: And does that appear to be a letter?
A. Yes.
Q. Is your name typed on the end of that letter?
A. Yes, it is typed.
Q. And is that your signature above it?
A. No, its not my signature.
Q. Would you read the content of that letter, please. To yourself.
A. Oh. Okay. Okay.
Q. All right. What does that letter purport to do?
A. What does -Q. What does the letter say?
A. Oh. It says basically -- should I read it or just tell -- summarize?
Q. Go ahead and read it.
A. It says, I, Janet Arvizo, who have lived in Apartment 208, have spoken to Yolanda
about ending my lease. As of March 1st, 2003, my apartment is cleaned and I have
officially moved out as per the conversation. This letter is official notification of the
monthly lease on Apartment 208s termination.
Q. And what is the date of the letter itself?
A. March 4th, 2003.
Q. Did you, in fact, sign that letter?
A. No, I didnt.
Q. Turn the letter over, this document, No. B, over. Is there another letter on that?
A. Yes, there is.
Q. Is your name on that?
A. The printed name is on it.
Q. Is there a signature above your printed name?
A. Yes, theres a signature.
Q. Is that, in fact, your signature?
A. It is not my signature.
Q. Read that letter to yourself.
A. Okay. Okay.
Q. And what does that document say?
A. It says, As per my conversation with Yolanda, the official final liab ilit ies owed to the
management is an amount of $850. This is an official receipt of this liability owed to the
building manager and fully absolves me of any further payment. Upon signing this form,
the management of the apartment building on 807 North Soto Street, Los Angeles,

California, for my apartment, Apartment 208, recognizes payment in full, and no other
moneys to be received by the management of this building from me, Janet Arvizo. And I
am fully free of any debts owed to the management.
Q. All right. Were these letters sent to you?
A. Yes.
Q. Were they sent -- who sent these letters to you?
A. The landlord did.
Q. Was that after you had already moved out?
A. Yes.
Q. Who is it you were talking to about moving out of your apartment? In other words, who
at Neverland was it that you were talking to about moving out?
A. Frank and Vinnie.
Q. At some point in time did you give them the key to that apartment?
A. I think they had taken the key from me.
Q. Im -A. I think, maybe. I dont know.
Q. Do you have a recollection of how they go the key?
A. No, I dont remember.
Q. What were your feelings about moving out of your apartment at that time?
A. Remember how I said I would think about it? Well, at this time now its a no.
Q. All right. Did you tell them no, you didnt want to move out of your apartment?
A. Thats correct.
Q. Do you know where your possessions went to after they moved you out?
A. No, I do not.
Q. Did they ever tell you where your possessions were moved to?
A. No, they didnt. Thats another reason why I needed Mr. Dickermans help after I left
Neverland.
Q. Did anybody tell you that they were put into storage?
A. No.
Q. Did you ever return to that apartment on Soto Street after you left Neverland at the
time?
A. No.
Q. Did you talk to anybody at Neverland about the boys being withdrawn from school?
A. Until afterwards.
Q. Im sorry, afterwards of what?
A. Until after they had checked Davellin out.
Q. All right. Now, Davellin was going to school where at the time?
A. She was going to school at Roosevelt High School, which was down the street from my
Soto Street apartment.
Q. So that was in East Los Angeles?
A. In East L.A. Its even on Soto Street, the high school.
Q. Now, let me back you up just a little bit, before you went off to Miami
A. Okay.
Q. I think you had testified that you were living part time at Jay Jacksons apartment in
mid-Wilshire.
A. I was visiting.
Q. And part time at Soto Street?
A. I lived in Soto Street.

Q. The address that you used for the boys to go to the school that they were in on
Wilshire -A. First they attended Hollenbeck.
Q. Okay.
A. They attended Hollenbeck. This is a school down the street from Soto Street. And
because the boys were not involved in any gangs, they kept getting beat up, because they
wouldnt join any gangs. And so I told Jay about it, and so moved them to another school
within the same L.A. school district.
Q. And the school that you moved them to was which one?
A. John Burroughs.
Q. And John Burroughs is located where?
A. Its near Jays apartment.
Q. Did you use Jays address to be able to do that?
A. Yes, I did.
Q. And -A. And also they became aware of that afterwards, but it was already on the record and
they were okay with it.
Q. Okay. Now, where were you actually residing during that period of time prior to going
to Miami?
A. In my East L.A. apartment.
Q. All right. Would you spend the nights at Jays apartment as well?
A. Yes, sir, I did.
Q. Can you give us a sense of how many nights a week you would be at the East L.A.
apartment and how many nights a week you would be at Jays apartment, on average?
A. Depending if Jay had to work late or -- it all depended upon Jays work.
Q. All right. Now, when you stayed at Jays apartment during the week, where d id Davellin
stay?
A. She always stood in -- and this is what would happen: Wed all stay there in East L.A.
Shed go to school, and then Id take off on the bus to drop off the boys. And then Id go
to Jays apartment, clean h is apartment, do anything to -- just make myself serviceable.
Q. All right. On the nights that you actually stayed overnight at Jays apartment -A. Yes.
Q. -- during the week, where would Davellin stay?
A. Okay. When that would happen, I would -- I would contact my parents, and so since
my dad has like a swing shift -- hes a truck driver, my dad. I wou ld let my parents know,
and then so theyd go by the apartment and go pick up Davellin.
Q. All right. Let me move you back now to this period from the 2nd to the 10th of March,
and back at Neverland again.
A. Okay.
Q. Did you have a d iscussion with anybody at Neverland about checking your kids out of
school?
A. Yes. After Davellin was checked out.
Q. All right. Did you have a d iscussion with anybody about checking Davellin out of school
-A. No. No.
Q. -- before you checked her out of school?
A. No.
Q. Did Davellin check out of school?

A. They checked Davellin out of school.

Q. Did you know that they were doing that in advance?
A. No, I did not know.
Q. And that was from Roosevelt School?
A. That was Roosevelt. 6284
Q. In East L.A.?
A. East L.A., yes.
Q. Now, was Davellin out of school this entire period of time?
A. Yeah. Theyre off track. So I dont know if theyre familiar here with track.
Q. Well, let me see if we can figure this out. From the period of time in early February
when you first went to Miami -A. Theres a portion -Q. Hold on. Theres no question pending.
A. Im sorry.
Q. From the time you went to Miami in early February until the 10th of March, was
Davellin going back to high school at all?
A. I think thats -- I think -- I cant remember, but I think Davellin was off track. Off
track means you dont go to school during that period.
Q. This is one of those schools where students -A. Yes.
Q. -- attend -A. Its year-round school.
Q. Its one of those schools where students attend at different times?
A. Yes.
Q. And its sometimes not necessarily in the summert ime -A. Yes.
Q. -- they are out of school?
A. Yes. And I think thats the best I can remember.
Q. Now, as to the boys, did you have a conversation with anybody at Neverland about the
boys being checked out of school?
A. Okay, this is when Frank and Vinnie ho ller at me that I have to sign this paper. Thats
why it came to a point where my signing days were over. I had to sign a paper for them
to check out the boys, but with Davellin, they d id it without my signature. They did it
themself.
Q. Id like to show you a document now, or a couple documents. If I may approach the
witness, Your Honor.
THE COURT: Yes.
Q. BY MR. ZONEN: Exhibit No. 271 -- do you have a pen there?
A. Yes, I do.
Q. Exhibit No. 271 for identificat ion, not in evidence, for identification, mark that first one
on there A, and then were going to move on to the second one. Lets go to 271-B. Mark
that B, and tell me what that is.
A. This one?
Q. Yes.
A. Okay. It says, Checkout sheet.
Q. From where?
A. From John Burroughs.
Q. All right. Is --

A. The boys -- my boys school.

Q. John Burroughs Middle School?
A. Yes.
Q. Is this for one of your sons?
A. Yes. This is for Gavin.
Q. All right. Is there a date on that?
A. It says March 6th, 2003.
Q. Is there a signature on that document?
A. Yes, there is. It says, Parents signature.
Q. And whose signature is it?
A. Its Vinnies.
Q. All right. It says date of birth on there?
A. Yes.
Q. Is that Gavins birth -A. That is Gavins birth date.
Q. Does it indicate where the new address is going to be for this child, for this student?
A. Yes. It says -- City is Phoenix. The state is Arizona.
Q. All right. Is this in your handwriting at all?
A. Not in my writing at all.
Q. Did you ever see this document?
A. Ive never seen this document before.
Q. All right. You -- before today or before the grand jury?
A. Before -- I think it was the grand jury. I think that time. Or before -Q. But at the time all this was happening -A. At that time, no.
Q. Back on March 6th, 2003 -A. No.
Q. -- did you ever see that document?
A. No.
Q. Now, did anybody talk to you about moving to Arizona, to Phoenix?
A. No. Except in that letter, the one -- the letter with the Phoenix, Arizona, that you
showed me.
Q. Oh, all right.
A. That one.
Q. But conversations?
A. Conversation, no.
Q. Nobody had a conversation with you at Neverland about you moving to Phoenix,
Arizona?
A. No, no. Zero.
Q. Did either Vinnie or Frank ment ion Phoenix, Arizona, to you?
A. No. Zero.
Q. Did either of them indicate where they wrote on these checkout forms where they were
moving you to?
A. It says right here, New address.
Q. But in conversations that you may have had with Vinnie and Frank at the time?
A. No, no, it was Brazil.
Q. This is B. Lets go to C, if we can, right here. Mark that one C.
A. This is what Im talking about.

Q. All right. Would you take a look a moment at that document?

A. Okay.
Q. Have you ever seen that document before?
A. Yes, this is the one with -Q. Is your signature on that?
A. Yes, this one has my signature.
Q. And read that document.
A. It says, I, Janet Arvizo, allow Vincent Armenta to check out my son Gavin Anton Arvizo
from John Burroughs -- I mean, from Burroughs Middle School. He will be placed in
another school district in Phoenix, Arizona, where a current new residence is being
sought.
Q. That is your signature?
A. Yes, it is.
Q. And written -- typed below is the name Janet Arvizo?
A. Yes.
Q. Is this the letter youre referring to?
A. Yes, this is what I was talking about.
Q. Now, at the time that you signed that, did you talk to them about, Whats the business
with Phoenix, Arizona?
A. And they said this way nobody would be able to find me or the kids.
Q. This is C. Lets go to D, please.
A. Okay.
Q. Go ahead and write D on that. What is D?
A. D is my drivers license. Oh, thats another thing they had.
Q. Just tell us what it is right now.
A. My drivers license.
Q. And who else?
A. Vinnies drivers license.
Q. At some point in time did somebody tell you that they needed a copy of your drivers
license?
A. No, they took my drivers license.
Q. All right. Who is they?
A. Frank and Vinnie.
Q. Well, did both of them take it?
A. Yes. Yes. Frank was present when Vinnie took it. So -Q. Tell me what you mean by took it. What did they do?
A. They said, Let me have your driver license.
Q. And did you hand it over to them?
A. Yes, I did. At that point I was doing everything they said.
Q. Was it about this time that you did that?
A. Yes. Yes, I did.
MR. ZONEN: Oh, Im sorry. Ill do that.
Q. Exhibit No. 272. At this time No. 272. Would you tell us what that is, please?
A. Its John Burroughs Middle School Checkout Sheet.
Q. Thats for who?
A. For my son Star.
Q. Is this the same form as the one that we had previously looked at for Gavin?
A. Yes. And it says, Star David Arvizo.

Q. His full name is on there?

A. Yes, his full name is on there.
Q. This one also states youre going to Phoenix, Arizona?
A. This one also states Im going to Phoenix, Arizona.
Q. Put an A on that. So thats 272-A. And well turn it over.
A. And the parents signature is not mine.
Q. There is a spot for parents signature?
A. Yes.
Q. And whose signature is that?
A. Its not mine. Its Vinnies.
Q. Did he sign his own name?
A. Yes, he did. And it says, Date of birth: 12-11-1990.
Q. Is that, in fact, Stars birthday?
A. Yes, it is.
Q. And Vinnie, Im assuming, is not his parent?
A. Yes, its -- oh.
Q. This is A. This is B.
A. Yes.
Q. Right here. Mark B on that, please. And that document, is that the same document;
however, the letter, thats signed by you, except this one is for Star?
A. Exact -- exactly.
Q. And that is, in fact, your signature?
A. Yes, it is my signature.
MR. ZONEN: Your Honor, I would like to move into evidence Exhib it -- Exhibit No. 276,
which would be A and B, which is the envelope as well as the letter dealing with the
landlord. And I would so move at this time.
MR. MESEREAU: No foundation.
THE COURT: Its admitted.
MR. ZONEN: Im sorry, the Courts ruling?
THE COURT: It is admitted.
MR. ZONEN: A ll right. I would also move to introduce into evidence 271, as to B, C, D,
and 272-A and B.
MR. MESEREAU: No objection.
THE COURT: Its admitted.
MR. ZONEN: May I publish a few of these documents at this time?
THE COURT: Yes.
MR. ZONEN: Lets start with 271-B and C.
MR. AUCHINCLOSS: May we have Input 4, Your Honor?
Q. BY MR. ZONEN: Now, this is the John Burroughs Middle School Checkout Sheet; is
that right?
A. Yes.
Q. And whos the student?
A. The student is Gavin Anton Arvizo.
Q. And the printing on that -- the handwritten printing on that, is that yours?
A. No, it isnt.
Q. All right. Was this filled out in your presence?
A. No.
Q. And again, this is a document you did not see until a court proceeding in Santa

Barbara?
A. Correct.
Q. Parents signature, thats Vinnies?
A. Yes.
Q. And the date of birth; is that right?
A. Yes.
Q. And this is the document that indicates Phoenix, Arizona?
A. Yes.
Q. Lets go to the next one, please. Exhibit C from that same exhibit, is this the letter,
then?
A. Yes.
Q. And that is your signature?
A. It is my signature.
Q. And then 276-B on the front side -- what happened to our laser? Put it on so both
signatures are on there. And then the second down here, where it says Janet Arvizo, is
that your signature?
A. No, it isnt.
Q. All right. Do you know if that is Yolanda Lozaldes signature?
A. Yes, it is.
Q. And then turn it over. This is the second letter that you identified. And that signature
here, is that your signature?
A. No, it isnt.
MR. ZONEN: Okay. You can turn on the lights.
Q. Id like to move you ahead to the 10th of March, if I may.
A. Okay.
Q. You told us that you had a preexisting schedule requiring a vis it again back at Kaiser
Hospital; is that right?
A. Yes.
Q. And what exactly was it that Gavin had to do in preparation for that visit?
A. He had to -- okay, well, actually the creatinine clearance, Mr. Zonen, had to be turned
in immediately. The creatinine clearance, that had to be turned in immed iately after the
doctors visit, which was way back in February, February 25th.
MR. MESEREAU: Objection, Your Honor. Nonresponsive; move to strike.
THE COURT: Sustained. Stricken.
Q. BY MR. ZONEN: I want to be very specific about the questions that I ask -A. Okay.
Q. -- and the answers that you give.
A. Okay.
Q. The purpose of the visit on the 10th of March was for what?
A. Just to check his kidney.
Q. And was there a requirement that he had to furnish a urine sample?
A. That was required since February 25th. 6295
Q. Okay. And why -A. I had to do that the next day.
Q. Why didnt you do it on February 25th?
A. Because they didnt let me. They didnt want me to go back to Kaiser to turn it in.
Q. Did he have an examination that had to take place on the 10th as well?
A. Yes.

Q. And the examination was to do what?

A. Was to check his kidney.
Q. All right. Did they, in fact, do that at that time?
MR. MESEREAU: Object to the word they. Move to strike.
THE COURT: Sustained. Stricken.
Q. BY MR. ZONEN: Did he have an examination of some kind at Kaiser Hospital on the
10th?
A. Yes.
Q. And what was the examination that he had?
A. To check the inside of his kidney.
Q. Were you present during that exam?
A. Yes.
Q. And did that exam take place?
A. And so was Vinnie.
Q. And that exam took place?
A. Yes.
Q. Now, the creat inine clearance, tell us what that is, please. 6296
A. The creatinine clearance is a 24-hour urine collection to check on Gavins kidney.
Q. And was there some piece of equ ipment that he had to have to collect it in?
A. Yes. Its a big, giant jug that -- its made to collect urine.
Q. Now, Im told that this is not a used exhibit.
A. Okay.
Q. And this is No. 349. Can you tell us if this Exhibit No. 349 is similar or dissimilar -A. Its similar, but its not it.
Q. Its not the same?
A. No.
Q. Tell us how that is different from the one that you had.
A. Okay. It doesnt have this, this thing, at all. Its just completely closed.
Q. All right. Is the configur -- and the thing that youre saying, this thing -A. The cap. The cap.
Q. The cap is different on it?
A. Yes.
Q. All right. Now, the cap on the one that you had, did it close in the same fashion?
A. It closed. Its completely closed, sealed.
Q. So there wasnt a part that you could open up?
A. There is no part that you can open up like that.
Q. On the one that you had, did it twist closed?
A. Yes.
Q. In the same fashion?
A. Yes. Yes.
Q. Was it
A. Its similar, the bottle, though.
Q. The bottle and the size was similar?
A. Yes.
Q. The cap on the one that you had, did it close to the same extent?
A. Completely sealed, because -Q. You need to wait until the question is asked in its entirety.
A. Okay.

Q. The top, did it seal closed to the same extent that this one does?
A. Yes.
Q. So it twisted closed?
A. Yes.
Q. All right. The one that you had, was it as secure as the one that this is?
A. Yes.
Q. Okay. All right. Now, was the color the same?
A. Yes, just about.
Q. All right. Where did you get that particular container, the one that -A. At Kaiser at the laboratory.
Q. All right. Was that on the 25th?
A. That was on the 25th. And I was supposed to do that -Q. Did you have a specific time schedule for returning it?
A. Immediately.
Q. All right. And it wasnt done until the 10th?
A. It wasnt done.
Q. All right. Whose idea was it to do it around the time of the 10th?
MR. MESEREAU: Objection; foundation.
THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Go ahead and answer.
A. Every time -- I had done these creatinine clearance already for years, since the year
2000.
MR. MESEREAU: Objection; nonresponsive.
THE COURT: Sustained.
Q. BY MR. ZONEN: Again, you need to listen to the question.
A. Okay.
Q. Whose idea was it to do it the 10th, you or somebody else?
A. I had kept having Gavin do the urine clearance, and every time there was an excuse
why it couldnt get turned in. It was lost; it was -- the urine wasnt continued -MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE WITNESS: Thats my answer.
MR. ZONEN: No, you need to listen to the question.
THE COURT: Sustained.
Q. BY MR. ZONEN: Who decided to do it on the 10th?
A. I did.
Q. All right. That was the question.
A. But there was many times before -Q. Hold on.
MR. MESEREAU: Move to strike as nonresponsive.
MR. ZONEN: Hold on. W ell take care of it.
THE COURT: Sustained.
Q. BY MR. ZONEN: You need to listen to the question being asked. Did you then give this
container to Gavin to do this urine collection?
A. It had been given to him since the 25th.
Q. So he had it in his possession?
A. Yes. Yes.
Q. All right. Did you have a conversation with Gavin about him co llecting his urine? 6300
A. Yes.

Q. At about that time?

A. Yes.
Q. Was it at least 24 hours prior to your going back to Los Angeles?
A. Yes, it had to be.
Q. Did you talk with him about collecting the urine during that time?
A. Yes. From the doctors.
Q. Yes. And, now, this is something he had done previously; is that right?
A. Yes. For years already.
Q. Now, to your understanding, did he begin collecting his urine?
A. He started collecting it from -- from like -- I think it was from the 2nd on, when we
returned to Neverland. Because from the 25th to the 2nd when we were in the hotel,
Frank had taken them away from us, because we werent going to go to the doctors
anymore.
Q. I didnt understand that. Frank actually took one of these containers away?
A. Yes, he took it away from Gavin.
Q. At the hotel?
A. At the motel.
Q. You had one of these at the hotel?
A. Yes.
Q. Did you have a conversation with Gavin at Neverland about turning in this urine?
A. No, I didnt. I had told Vinnie and Vinnie had told Gavin. It was like I said; no more
contact with my children from when we returned to -Q. At some time prior to your going back to Los Angeles, did Gavin call you?
A. Yes. On March 10th.
Q. All right. Did he say something to you concerning the urine?
A. Yes.
Q. What -A. It was about 4 a.m.
MR. MESEREAU: Objection. Nonresponsive and hearsay.
THE COURT: Ill strike after, Yes.
Q. BY MR. ZONEN: What did he tell you about his urine sample?
MR. MESEREAU: Objection. Hearsay.
MR. ZONEN: It would be a spontaneous declaration and an excitable utterance.
MR. MESEREAU: No foundation.
MR. ZONEN: It also explains the conduct of the parties thereafter.
THE COURT: Ill overrule the objection.
Q. BY MR. ZONEN: All right. What did he say to you about the urine sample?
A. He called me about 4 a.m., and -- he had phoned into the guesthouse, into the room I
was. And he had told me, Mommy, we need to reschedule, because this was the end -Q. Just tell us what he said.
A. Okay. Every t ime I wanted to do a creatinine clearance, they would always say no.
Finally, I was using this appointment -MR. MESEREAU: Objection. Nonresponsive; move to strike.
Q. BY MR. ZONEN: You need to tell us -- the question specifically is, what did Gavin tell
you?
A. Gavin had called me about 4 a.m., and he had told me that Michael was scared because
he had drank some Jesus Juice; that it was going to be detected in his urine. And thats
when I told him, Baby, what do you mean.

THE COURT: Wait, stop. He just asked what Gavin said.

THE WITNESS: Oh, okay.
THE COURT: Just stop.
Q. BY MR. ZONEN: Did you know what Jesus Juice was?
A. I had asked what Jesus Juice was.
Q. Did he tell you what Jesus Juice was?
A. Wine.
Q. Was this the first time you knew that he had been -A. This is the first time.
Q. You need to listen to the question. Was this the first time you had learned that Gavin
was drinking alcohol?
A. Yes.
Q. When did you leave to go to the hospital?
A. From 4 a.m., I didnt sleep anymore. It was -- I tried to get them up about 6:00.
Nobody could find Gavin, so we left there in the morning.
Q. What do you mean, Nobody could find Gavin?
A. They couldnt find Gavin.
Q. Did -A. The security people. And they said that, Theyre with Michael, and that was it; that
they needed Jesuss help to locate Michael with the boys.
Q. All right. Now, how did you find Gavin that morning? How were you able to find Gavin?
A. Well, finally Jesus brought him over.
Q. At what time was that?
A. That was -- I dont know. I dont know. We were supposed to leave Neverland at 7:00,
and I know we didnt because -MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE WITNESS: I cant -- so it had to be after 7:00, because we didnt leave at -THE COURT: Just a moment.
THE WITNESS: Okay. Yes, sir.
THE COURT: Ill strike that. Ask the question again.
Q. BY MR. ZONEN: Do you know what time it was you left Neverland?
A. No. It was after 7:00, my best estimate.
Q. Were you up from four oclock in the morning?
A. Yes.
Q. Was Gavin with you when you left?
A. Yes. And so was Vinnie.
Q. Did you have the container of urine with you?
A. Yes.
Q. Who was holding on to the container?
A. Gavin handed it to me.
Q. So you were holding on to it during the drive?
A. Yes. Oh, yes, I was.
Q. Where were you sitting in the car?
A. I was sitting in the front of the car, in the front seat, and Gavin handed it to me.
Q. All right. Did you hold on to it for the length of the drive?
A. Yes, I did.
Q. Where was Gavin sitting?
A. Gavin was laid out, passed out in the back seat.

Q. He was asleep?
A. In deep sleep.
Q. And was it Vinnie who was driving?
A. Yes. It was Vinnie.
Q. Anybody else in the car?
A. No. Just me, Vinnie, and -- me, Vinnie and Gavin, and -- and those people.
Q. At some point in time, did you stop on your way to the hospital?
A. Yes.
Q. Why did you stop?
A. I -- I had to go -- I had to use the rest room really bad, because I had been drinking
the whole entire t ime to keep me up, so I wouldnt fall back to sleep.
Q. Drinking what?
A. I kept drinking coffee.
Q. Okay. You had to use the rest room?
A. Yes.
Q. Where did you stop?
A. I stopped at Dennys, and I tried to hold it so much.
Q. Did you -- do you know where it was that you stopped?
A. No.
Q. The location?
A. No.
Q. Do you know how long you were in the car at the time that you stopped to use the rest
room?
A. I dont know. My best estimate, maybe halfway.
Q. Did you then go into the restaurant?
A. Yes, I went into Dennys.
Q. When you came back out, where was the car?
A. Gone.
Q. How long did you wait for the car to return?
A. Maybe about -- maybe about not more than five minutes. It was just minutes.
Q. Was Gavin still as leep in the back?
A. He was asleep.
Q. All right. And did you talk to Vinnie about where he had been?
A. Yeah. I asked him, Where did you go? He says, Oh, I went driving around. Im
thinking, Weve just been driving for a long time. Why would you need to drive any
more?
Q. Did you get back in the car and proceed to the hospital?
A. Yes.
Q. Did you notice the urine sample at that time?
A. Yes.
Q. What did you notice about the urine sample?
A. I noticed that the bag had been moved a little bit, okay?
Q. It was in a bag?
A. Yes, in a paper bag, okay? So then I said, Okay, so then I picked it 6307 up. And
when I p icked it up -- when it had urine, its heavy. And it was light. And there was only -do I continue?
Q. You -A. There was only this much urine in it.

Q. All right. Did you ask Vinnie -- was the top sealed back on?
A. It was sealed back on and it was like a little bit wet.
Q. All right.
A. And it wasnt closed tight, though, because when Gavin had handed it to me, its
customarily that I always check the cap.
MR. MESEREAU: Objection. Move to strike; nonresponsive.
THE COURT: Stricken.
Q. BY MR. ZONEN: When you noticed that the container was missing, did you say
anything to Vinnie?
A. The container wasnt missing. It was -Q. The content of the container was substantially less than before; is that right?
A. Yes. I asked him -- it was only this much in there.
Q. How much had been in there up to that time?
A. Almost this way.
Q. And by this way, you mean about 90 -A. About this full.
Q. About 90 percent full?
A. About this full. And then there was this much after I went to Dennys.
Q. Maybe 10 percent full?
A. About this much.
Q. Okay.
A. I dont know percent.
Q. Thats okay. All right. Did you ask him what happened?
A. Yes. I said, What happened?
Q. What did he say?
A. And he didnt answer me. And then he just commented, Oh, it must have fallen.
Q. Im sorry?
A. He said -- he commented -- because he didnt answer me. And then he said, It must
have fallen. And thats it. I knew at that point, zip the lip.
Q. All right. But were you able to tell -MR. MESEREAU: Move to strike; nonresponsive.
THE COURT: Stricken.
Q. BY MR. ZONEN: Were you able to tell whether urine had spilled into the car or not?
A. There was no urine odor, wasnt wet, nothing like that.
Q. You werent able to see any evidence that urine spilled inside -A. Thats right.
Q. Listen to the question in its entirety. You werent able to see any evidence of urine
having been spilled anywhere inside the car?
A. Thats correct.
Q. Did you ask Vinnie to explain how it happened?
A. I asked him what happened. He didnt answer. But afterwards he had commented.
Q. What did he comment to you about?
A. It must have fallen.
Q. Did you continue on to Kaiser Hospital?
A. Yes, I did. And I stood quiet.
Q. And did Gavin, in fact, have the test that he was supposed to have at that time?
MR. MESEREAU: Objection; foundation.
MR. ZONEN: Ill withdraw the question.

Q. Did Gavin go into the hospital -A. Yes.

Q. -- with you?
A. Yes.
Q. Was Vinnie there?
A. Yes.
Q. Was the urine sample turned in?
A. Yeah. I turned it in and -MR. MESEREAU: Objection. Nonresponsive; move to strike.
MR. ZONEN: The question is, was it turned in, and she said yes.
THE COURT: The objection is overruled.
Q. BY MR. ZONEN: All right. Where did you turn it in?
A. In to the laboratory.
Q. Did you talk with anybody there about the content of the bottle?
A. They said -MR. MESEREAU: Objection; hearsay.
Q. BY MR. ZONEN: The question is, did you -A. Yes.
Q. Yes or no? Okay. And did you at that time turn it in?
A. Yes.
Q. Prior to your leaving the car to go to the rest room, how tight was the top of that
container -A. It was -Q. Wait till the question is answered (sic).
A. Okay.
Q. How tight was the top of the container screwed onto the container?
A. It was tight.
Q. Was that your habit and custom each time?
A. It was a habit and custom, because I always had to travel with the urine on a bus, so -Q. Do you know how long you were at the hospital, Kaiser Hospital, with Vinnie and with
Gavin?
A. Well, when I went to go try to turn that in to the laboratory, and then we went to the
appointment, which was in a d ifferent building.
Q. All right. And after you left that building, where d id you go?
A. Then I went to the apartment.
Q. You went to whose apartment?
A. Jays apartment.
Q. Was Jay there?
A. Jay was not there.
Q. Was Vinnie with you?
A. Vinnie was with me.
Q. Was Gavin with you?
A. Gavin was with me. But they didnt go into the apartment.
Q. How long did you stay at the apartment?
A. Long enough to ask Jay to meet me at the nail shop.
Q. All right. Did you call Jay from the nail shop or from the apartment?
A. I called him from the apartment and told him to -- you know, because since theyre
monitoring my phone calls, like I told you how I would speak to people. And then I told

him, Oh, why dont you meet me in -- at the nail shop.

Q. All right. Did you then go to the nail shop?
A. I did go to the nail shop.
Q. Was he there when you got there?
A. No, he wasnt there.
Q. Did you have whatever they do at a nail shop done?
A. No. I had used the -- their phone. I had waited for Vinnie to cross the street, and thats
when I did it.
Q. What do they do, manicures at a nail shop?
A. They do manicuring and waxing there.
Q. Did you have any of that done?
A. I had done only a leg wax.
Q. Did you have a manicure?
A. No.
Q. Where was Vinnie while you were having a leg wax done?
A. Okay. He had came in -Q. No, no. Where was Vinnie when you were doing -A. Me, Vinn ie and Gavin, when we originally arrived at the nail shop, we were all three
together.
Q. And while you were having this procedure -A. No.
Q. -- where was he?
A. First Vinnie checked the area out. And then I told her, I came here for a leg wax.
Q. While you were having the leg wax, where was Vinnie?
A. Then he saw that I was going to do the leg wax, and then thats when he walked across
the street.
Q. So he left?
A. Yes.
Q. Where was Gavin?
A. With him.
Q. He was with him?
A. Yes.
Q. Did Jay eventually arrive?
A. Thats when I called Jay to come.
Q. So you called him a second time -A. Yes.
Q. -- from the beauty salon?
A. Yes.
Q. And did he, in fact, come?
A. Yes, he did.
Q. Now, did you go back with Vinn ie?
A. No.
Q. At some point in time, did Vinnie come back and see Jay?
A. Oh, yeah.
Q. What happened?
A. He turned red.
Q. Vinnie d id?
A. Yes.

Q. All right. Did Vinnie say something to Jay or to you?

A. He said, Okay. Lets go now, Janet.
Q. What did you say in response to that?
A. I told him that I kind of wanted to stay since I had a Family Court appointment the next
day. And so I told -- I used that as a reason why I could stay, me -- me and Gavin.
Q. All right. Did you want to stay with Gavin?
A. Yes.
Q. Your other two children were still at Neverland?
A. Yes. But I had to do everything as if -- not to raise suspicion.
Q. Did you say something to Vinnie specifically that you were not going back?
A. Yes.
Q. What did he say?
A. No. Thats not part of the plan.
Q. Now, was Gavin standing there at the time?
A. Yes.
Q. How was Gavin behaving?
A. At that time hes just -- hes just observing.
Q. All right.
A. Its until he talks to Frank that he gets -- he becomes distressed.
Q. Are you aware as to whether or not Vinnie got on the phone with anyone?
A. Yes, he did. He goes, I got to cal Frank.
Q. And did he, in fact, call Frank?
A. Yes, he did.
Q. Did he have a conversation with Frank in your presence?
A. Yes, he did.
Q. Were you able to hear what he was saying to Frank?
A. No, but Gavin got on the phone calls.
Q. You noticed that Gavin was on the phone as well?
A. Yes, because Vinnie wanted to talk to Frank -- to Gavin. Frank wanted to talk to Gavin.
Q. Was Jay Jackson there during this conversation?
A. Yes.
Q. Was Jay Jackson in uniform?
A. Yes.
Q. And what kind of a uniform does he wear during the day?
A. His military uniform. A camouflag e.
Q. Camouflage. Thats his daily uniform; is that right?
A. Yes. Thats his work uniform.
Q. At some point in time, was it decided who was going to go back to Neverland and who
was going to stay?
A. Jay got upset that Frank -- that Vinnie had 6316 said no. So then Jay starts -- he starts
becoming a little bit -- I dont know if confrontational is a correct word. I dont know.
But a little -- you can see that hes upset. So I -- and then thats when Frank -- another
time he goes out right there, right outside the nail shop door. And then thats when I tell
Jay, I said, Please, Jay, please, Davellin and Star are there. Just play along. Just play
along.
Q. So who went back to Neverland?
A. Vinnie and Gavin.
Q. Why did you agree for Gavin to go back to Neverland?

A. Well, because. When Vinnie came back, I said, Vinnie, V innie, I just want to spend
some time alone with Jay. You know, that kind of stuff. Thats all. You know, well -Well see each other back in -- in the Family Court. You know, you just bring all my
kids, and Ill go back. I just kind of want to spend some of that kind of time, quality time,
with Jay. So then when -- when he saw me behave that way, then he says, Okay. He
agreed to that.
Q. All right. Family Court?
A. Yeah.
Q. All right. Tell us about Family Court. Did you have an appearance in Family Court ?
A. Oh, yes.
Q. And when was that appearance scheduled for?
A. It was the next day.
Q. And had you already told them about that -A. Yes.
Q. -- the Family Court appearance?
A. Yes.
Q. Who is it that you told about the Family Court appearance?
A. Frank and Vinnie knew.
Q. Did you know whether or not your children had to be at that appearance at Family
Court?
A. I knew that they didnt have to be there. But again, its like that orthodontist visit. I
had said they had to be there.
MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: Ill strike after, I knew they didnt have to be there.
Q. BY MR. ZONEN: The question was whether you knew whether or not the kids had to be
there. And the answer was you knew?
A. I knew they d idnt have to be there.
Q. They didnt have to be there. Did you tell Frank or Vinn ie -A. No, I didnt tell them that. I told them that they had to be there.
Q. And who was it you told, Frank or Vinnie or both?
A. Both.
Q. What was the purpose of the Family Court session on the 11th?
A. Because I was finally going to be awarded support.
Q. All right. It was a spousal support, or a child support -A. Spousal support, child support, all that.
Q. Were you represented by an attorney during that time?
A. Yes, I was.
Q. Who was the attorney?
A. Michael Manning.
Q. Family law lawyer?
A. Yes. That Ive had for years, already years.
Q. All right. Did Vinnie represent that he would or would not bring the children back for
this appearance?
A. He said he will bring all three of my kids back.
Q. Did you spend the night in Los Angeles?
A. Yes, I did.
Q. The next day was the Family Court appearance?
A. Yes. And now Ive told Jay everything that night.

Q. So you had a complete conversation?

A. Told him everything.
Q. All right. Now, did you have an understanding with Vinnie as to how you would get to
the Family Court appearance the next day?
A. Yes. The condition -Q. Yes or no.
A. Oh. Yes.
Q. Okay. Youre doing better.
A. Okay.
Q. All right. Now, at what time was that appearance?
A. The appearance, I dont remember, but maybe 8:00 or -Q. It was a morning appearance?
A. It was a morning.
Q. How were you going to get to the court appearance?
A. The condition was Vinnie was going to pick me up and take me there.
Q. And the kids?
A. With him.
Q. All right. Did Vinnie arrive the next morning?
A. He did. He went all the way to Neverland and arrived early that morning.
Q. All right. When he arrived, did he have the kids with him?
A. He had no kids with him.
Q. Did he explain to you why the kids werent there?
A. He said I had to go back.
Q. He said you had to go back?
A. I had to go back.
Q. All right. Did you go to the Family Court appearance with Vinnie?
A. I did.
Q. And at the conclusion of the Family Court appearance, where did you go?
A. I went back to -- I went back to Jays.
Q. Did he take you back to Jays?
A. He took me back to Jays.
Q. You did not go back to Neverland?
A. I didnt go back to Neverland.
Q. Did you ever go back to Neverland?
A. I never went back to Neverland.
Q. Now, this is now the 11th of March; is that right?
A. Yes, it is.
Q. Did you engage in some effort at this point to get your kids delivered to Los Angeles?
A. I did.
Q. All right. What was this effort? What did you do?
A. When Jay came home, we called Karen Walker, the supervisor of the -- I dont know.
CPS, DCFS, that. And I and Jay both talked to her, and she 6321 said, Its out of my
hands. Its out of my hands. Go get yourself some leg al help. Im sorry, I cant help you.
Thats what she said.
Q. Was Karen -A. Karen Walker said that.
Q. Hold on. W as Karen W alker one of the three that had been to Jays -A. Yes.

Q. Listen to the whole question. Was Karen Walker one of the three workers who had been
to Jays apartment on the day of that interview on the 20th?
A. Yes.
Q. Now, after you called Karen Walker, what did you then do?
A. She didnt help us, me or Jay. W e both talked to them, and so we were trying to find a
way where we can go get the kids where they wouldnt do anything before we got the
kids.
Q. What did you decide to do?
A. For my parents to play sick. My -- specifically my dad.
Q. So did you have one of your parents call Neverland?
A. Okay. When Jay returned to work, he called from his work, because now hes aware
that our phone calls are being monitored.
Q. So he called from work to whom?
A. To my parents.
Q. And talked with who, your father?
A. With my dad, and -- well, my dad and mom but my mom speaks only Spanish, so my
dad told my mom.
Q. Okay. And in that process communicated to them this plan?
A. Yes. Yes.
Q. Now, were the kids at some point in time then delivered to your parents house?
A. Yes, I negotiated for my kids. I told them I would give them myself in exchange for my
parents being able to see my children.
Q. Who did you talk to?
A. To Frank.
Q. And did you tell him that; that you would -A. Yes.
Q. -- go back to Neverland?
A. Yes, I negotiated for one hour. One hour. And I got two. And then I got a day. And then
I finally got two days.
Q. All right. So by the time you got off the phone with Frank, it was understood that your
kids would visit for how long?
A. For two days.
Q. And that was a conversation that you had with Frank?
A. With Frank.
Q. And you were placing that phone call to Frank, or he called you? Which?
A. Let me see. I had orig inally -- as Jays calling my parents, Im calling Frank. And Im
letting him know.
Q. So you called Frank?
A. Yes.
Q. And you called from which telephone?
A. From Jays apartment.
Q. And you called Frank on the number that you had for him?
A. I think -- I dont know whether it was his number or Neverland number, but on the
other line was Frank, on the other end of the line.
Q. Were your kids, in fact, delivered to your parents?
A. Yes.
Q. Was it that day or the next day?
A. That day.

Q. Were you present at the time -A. And I was made aware that our every step is being watched.
MR. MESEREAU: Objection. Move to strike; nonresponsive.
THE COURT: Stricken.
Q. BY MR. ZONEN: Were you there at the time your kids were delivered to your parents
house?
A. No, I was -Q. Do you know what time it was that you finally saw your kids?
A. In the evening.
Q. Did you go with Jay?
A. Yes.
Q. All right. At the time you got to your parents house, who is present? Who was there?
A. My mom and dad and my three children.
Q. How were your children behaving at that time? Let me be more specific. How was
Gavin behaving at the time you got there?
A. They were not my kids anymore.
Q. Well, describ e Gavins behavior specifically, how he was behaving.
A. He didnt want to talk to Jay.
Q. Were talking about Gavin right now.
A. Yeah.
Q. Describe Gavins behavior specifically.
A. Angry, violent. Yeah.
Q. Did you tell him that he was not going back to Neverland?
A. Yeah.
Q. And you say angry and vio lent. What do you mean? Describe what he was doing or
what he was saying.
A. Just hollering, telling me that -- yelling at me at the top of his lungs that Michael loves
him, and that he had to go back.
Q. All right. Were you the one telling him he wasnt going back?
A. Thats right.
Q. How long did his behavior continue that way?
A. For hours.
Q. How long was it before his behavior was back to normal?
MR. MESEREAU: Objection. Assumes facts not in evidence; no foundation.
THE COURT: Overruled.
Q. BY MR. ZONEN: You can answer the question.
A. It took a long time.
Q. And what is that, a long time? Give me a sense of it.
A. I cant.
Q. Are we talking about days or weeks or months?
A. It took weeks.
Q. Weeks? When did you tell either Frank or Vinnie that none of you were going back to
Neverland?
A. Excuse me. I d idnt call Frank or Vinnie. We contacted Jesus the very next day.
Q. You contacted Jesus?
A. Yes.
Q. Did you tell him?
A. Yes.

Q. All right. What happened after you told Jesus?

A. And we werent coming back. And the only reason we contacted Jesus was because
when the children were leaving, Frank had taken away all of the new clothes that they had
purchased, plus some of my childrens clothing also in the -- in the removing the new
clothes, because Frank had told them that they had to come back if they wanted their new
clothes.
Q. When they came to your mothers house, do you know if they actually had anything
with them when they came?
A. Gavin wasnt allowed to bring nothing. Zero.
Q. And how about the other two?
A. The other two did bring their luggages and my bag with them.
Q. Did you start receiving telephone calls or visits?
A. Yes.
Q. All right.
A. Immediately.
Q. And in terms of visits, who was it who came to the house?
A. It wasnt visiting. It was -- it was following us in a very, very visual way. Knocks.
Throwing rocks. Following us. Very -- they werent hiding about it. They were in-my-face
type of attitude.
Q. Do you know -A. To come back.
Q. Are we talking about people who now are new, people-you-hadnt-seen people, or -A. Okay.
Q. Wait till the question is answered (sic).
A. Okay.
Q. Are you talking about people you hadnt seen before or people that you were familiar
with?
A. People that I hadnt seen before. And also, in addition to that, new ones.
Q. Among the people that you had seen before, tell us who they were.
A. The people that I seen before was Johnny, Frank and Vinnie. And then some other
people.
Q. You actually saw Frank and Vinnie at some location?
A. Yes, yes.
Q. Where?
A. At Jays apartment. And I knew it, because I looked through the peephole.
Q. Did you stay at your parents house?
A. No.
Q. Did you go to Jays?
A. Jays.
Q. Did you stay anyplace but Jays thereafter? 6328
A. Only Jays. And I enrolled Davellin, because I believe in, you know -Q. No, the question is whether you stayed at some other location.
A. No, just Jays.
Q. For what period of time did you stay at Jays?
A. From that point on, till now.
Q. Your Soto Street apartment was now vacated?
A. Gone.
Q. You said that you saw Frank and Vinn ie at Jays. Did you actually talk to them?

A. No. I didnt open the door.

Q. You saw them through the peephole?
A. Yes, I did.
Q. Both of them together or on different occasions?
A. Well, on this occasion they were both together.
Q. Were they saying anything to you?
A. Yeah. Open the door. Just knocking.
MR. MESEREAU: Objection. Move to strike; vague.
THE COURT: Sustained.
Q. BY MR. ZONEN: Do you know who it was who was talking to you through the door?
A. Frank. I could see him through the -- I could see everything.
Q. Were you able to hear his voice?
A. Yes.
Q. You could hear what he was saying?
A. Yes.
Q. And did you recognize his voice?
A. Yes.
Q. Did you engage either one of them in conversation through the door?
A. No. Zero.
Q. Did you acknowledge to them that you were there?
A. No. Didnt even want to let them know that I was there. But they knew. Because Frank
was saying, I know youre in there.
Q. Were you receiving telephone calls as well?
A. Yes.
Q. Continuously?
A. Continuously.
Q. Were you answering any of the calls?
A. No. No more answering.
Q. Did you have any conversation with Vinnie or Frank?
A. No.
Q. Did you ever see Johnny?
A. Yes.
Q. Okay. Where did you see Johnny?
A. On my front door. And also there was one time when I was watching through the
peephole, he had slipped a note through the side of Jays apartment. Before -- before they
had put this thing around there, it was open all the way around, and so he slipped a note
through there. And I saw him writing it.
MR. ZONEN: May I approach the witness?
THE COURT: Yes.
Q. BY MR. ZONEN: Exhibit No. 277, please, for ident ification, have you seen that exhibit
before?
A. Yes, I have.
Q. Is that the note that you just described?
A. Yes, this -- this is the note.
Q. And how do you know that it was Johnny who left that note?
A. Because Im looking at him while hes writ ing it. Im looking at him as hes slipping it in.
Q. Okay. And he left that note where?
A. At Jays apartment.

Q. And thats the note you then turned over to law enforcement?
A. Yes, I did.
MR. ZONEN: Move to -THE WITNESS: I put it in -MR. ZONEN: Move to admit that exhibit into evidence, please.
MR. MESEREAU: No objection.
THE COURT: Its admitted.
MR. ZONEN: Your Honor, may I publish that note, please?
THE COURT: Yes.
Q. BY MR. ZONEN: Now, it appears theres something on the front and on the back; is that
correct?
A. Yes.
Q. What is the back part? Im assuming thats the back. What does that say?
A. It says, To Star or Gavin.
Q. And then on the front it says?
A. It says, Please call Frank, Vinnie, at emergency, 1-805-686-5466. And it says Now,
and its underlined.
Q. The top parts in red. Now is in what co lor?
A. Blue.
Q. And the back, To Star or Gavin, is?
A. In black.
Q. Is that the front of the note thats 277 Exhibit 277? Miss Arvizo, is that, in fact, what
were looking at, the same thing?
A. Yes. Yes.
Q. And Im going to turn it over at this time. And this is the part that says, To Star or
Gavin?
A. Yes.
Q. Now, in response to that note, did you call 6332 either Star or Gavin?
A. No. No.
Q. Im sorry, did you -- did you call either Frank or Vinn ie in response to that?
A. No more. And then -Q. Do you recall at this point you had any conversations with Frank or Vinnie?
A. No more.
Q. For what period of time did this continue, the phone calls and things like that?
A. It -- it went for months.
Q. You said at one point stones were thrown?
A. Yes. At my moms house.
Q. Did you ever see who was doing that?
A. No, I didnt. Davellin saw him.
Q. All right. But you were not present at the time it happened?
A. No. It was my mo m and Davellin present.
Q. Now, I think that you had also said that people were fo llowing you?
A. Yes.
Q. How did you become aware of the fact that people were fo llowing you?
A. Because now they were in my face.
Q. And explain what that means.
A. Meaning before, everything was being done a little bit -- a little bit secretly. And now it
was -- I mean, it was more int imidating than it was 6333 before. Thats the best I can

say.
MR. MESEREAU: Objection. Move to strike; nonresponsive.
THE COURT: Overruled. Next question.
Q. BY MR. ZONEN: Could you tell who it was who was following you?
A. Yes. Johnny. And then some of those other people that I had told you I never came to
know who they were. And this is the first time I also saw a female and -- because the rest
were always male. And then -Q. Did you recognize any of them, other than Johnny?
A. Only Johnny. And then -- and then they were replaced by some other people.
Q. How were you aware of the fact that people were fo llowing you? I mean, what is it that
you noticed specifically?
A. Well, Im in the lane, they change the lane. Im in a lane, they change a lane. I get off,
they get off. I go to my under -- Jays underground parking, theyre right there. When Im
-- when Gavin went to church, one of these -- theres -- theres -- I dont know what kind
of camera, but its kind of like this, right there. Just right there, showing me that theyre
doing it.
Q. All right. Now, at some point in time, were you actually shown video images of yourself
and your family?
A. Barely now. Just the other day. Mr. Zonen showed it to me.
Q. All right. Did you see other images at the time of the grand jury?
A. No -Q. Okay.
A. -- I didnt.
Q. You have no recollection of seeing other images?
A. No.
MR. ZONEN: A ll right. Your Honor, Exhibit No. 813 is a DVD. Ive consulted with counsel.
Weve agreed it can be played at this time. Theres no sound, so theres no transcript.
Q. Now, youve had an opportunity to view these images in advance; is that correct?
A. Yes. Yes, Mr. Zonen.
Q. And you have recognized the people in it; is that correct?
A. Yes.
THE COURT: How long is it?
MR. ZONEN: Im sorry?
THE COURT: How long is it?
MR. ZONEN: Five minutes. Five, six minutes. About that, I think. If we can, lets go ahead.
Q. Excuse me one second. Part of this, as well, is of your apartment on Soto Street, is it
not?
A. Yes.
Q. There appears to be people moving your things out?
A. Yes.
Q. And thats at the very end of it?
A. Yes.
MR. ZONEN: Let me revise it. I think its more like ten minutes.
THE COURT: Is this the PC, No. 1?
MR. AUCHINCLOSS: It is, Your Honor.
THE COURT: Youre ready?
MR. AUCHINCLOSS: Yes.
MR. ZONEN: W ere ready. (Whereupon, a portion of a DVD, Plaintiffs Exhibit No. 813, was

played for the Court and jury.)

MR. MESEREAU: Your Honor, they added the title to that. I didnt approve that. Thats
nothing weve seen before. Mr. Zonen added it. Its not part of the original, so we object
to this.
MR. ZONEN: W ell, I -- all right.
MR. MESEREAU: W e object on foundation and authenticity and that its been tampered
with.
THE COURT: All right. The -MR. ZONEN: Id like to be heard on that issue.
THE COURT: You may, but -- maybe what well 6336 do -MR. ZONEN: A ll right. There is -THE COURT: I think well -- I think well excuse the jury, and let you discuss it with me.
That way theyll get a little extra break here.
(The following proceedings were held in open court outside the presence and hearing of
THE COURT: Okay.
MR. ZONEN: Are we back in session?
THE COURT: We are back in session. Mr. Mesereau.
MR. MESEREAU: Yes, Your Honor.
THE COURT: Maybe you want to -- can you move it back to the opening screen so we can
look at what the objection was about?
MR. ZONEN: W hile hes doing it, I can explain what the understanding was that we had
that preexisted the showing.
MR. AUCHINCLOSS: Its up, Your Honor, if you go to Input 1.
THE COURT: This is what you were objecting to, Mr. Mesereau?
MR. MESEREAU: Yes, Your Honor.
MR. ZONEN: I explained -THE COURT: Could I have Mr. Mesereaus objection, so I fully understand it?
MR. MESEREAU: Yes, Your Honor. This particular wording is not part of the origina l tape.
Its been added by the prosecution. It was not disclosed to me. It was done to influence
the jury. Theres been no foundation laid that these are Brad Millers surveillance tapes at
all. The numbers have been added by them.
THE COURT: So, to be specific, what were looking at is the Brad Miller Surveillance
Videotape, Item 811, 812, 816 and 815, and that was not on the -MR. MESEREAU: No, not -THE COURT: -- not on the DVD that you saw?
MR. MESEREAU: Not that I have seen. They have laid no foundation to prove that Brad
Miller arranged to have these tapes made. They have thrown different names around,
Johnny and Asaf, et cetera. They have not ever proven who these people actually worked
for. They havent proven who did the surveillance. They havent laid a foundation to where
they found these tapes and whether or not theyve been tampered with. Theres no
authenticity. Theres no foundation. Theres no logical connection, and they basically
tampered with the tapes by adding these words.
THE COURT: Was there an agreement.
MR. MESEREAU: Not to have this. Thats a surprise to me.
THE COURT: All right.
MR. ZONEN: W ell, counsel knows that theyre not tampered with at all. And furthermore,
we had a d iscussion in advance of showing this where I explained to counsel that there

were two witnesses who will subsequently lay a foundation. The first witness who will
testify that these -- that this is a compilat ion of tapes that were -- its -- its put now onto
one DVD that were, in fact, a compilat ion of tapes that were seized from - guess where? Brad Millers office. And the second witness will be the one who actually seized the tapes
from Brad Millers office. A ll right. Now, the content of the surveillance thereafter is
identical. Nobody has touched anything on there, and counsel knows that. My -MR. MESEREAU: I dont know that.
MR. ZONEN: I had asked him if it would be agreeable that we could show this in advance
of the other two witnesses laying the foundation; one, that they were seized from Brad
Millers office; and number two, that they were comp iled into one DVD for ease of showing
at this time, and he agreed to that. My suggestion at this time is that you instruct the jury
to disregard this frame on it, and we will commence the showing from the point where
6339 the car is in -- in session.
MR. MESEREAU: W e object on foundational and authenticity, Your Honor. And wed ask
that the individual tapes be played, not their concoction.
MR. ZONEN: W ell, you know, I had asked his permission and he gave it to me to do so.
MR. MESEREAU: To play videotapes.
MR. ZONEN: W ait a second. I am relying upon his representation of what he said he was
agreeing for us to do.
THE COURT: Sounds like he thought you were going to play two separate -MR. ZONEN: No, he didnt. I made it -MR. MESEREAU: Yes, I did. Nowhere was this ever described to me.
MR. ZONEN: I made it very clear that we comp iled it into one DVD. Now, this I did not
say. This I didnt know was going to be shown.
THE COURT: Whats the -- whats the compilation? Is it a serial, just the first one and then
the second one?
MR. ZONEN: Yes; one right after the other.
THE COURT: You intermixed the two?
MR. ZONEN: W e can show it to you right now. It only takes a couple minutes, if youd like
to see it.
THE COURT: I thought you said ten minutes.
MR. ZONEN: The bulk of it is the cleaning out of the apartment, which is one separate
tape, but the initial surveillance is less than five minutes, of different segments of
surveillance.
MR. MESEREAU: I might suggest, Your Honor, that the cleaning out of the apartment, as I
understand it, was to show what was being moved in or out, and its not a surveillance
tape. That is their concoction.
MR. ZONEN: Once again, this was something counsel approved of.
MR. MESEREAU: No, I d idnt.
MR. ZONEN: Hes lying. Thats simply not true.
MR. MESEREAU: Hes lying.
THE COURT: All right.
MR. ZONEN: Ill take a polygraph.
MR. MESEREAU: Youll fail it.
THE COURT: Just a moment. I dont want to hear anything like that. You dont accuse
each other of lying. Theres a misunderstanding here. Youve added something. And thats
not professional conduct. I wont put up with that. Do you understand, Mr. Zonen?
MR. ZONEN: Yes.

THE COURT: And you are not to respond to him. You two talk to me.
MR. MESEREAU: I apologize, Your Honor.
THE COURT: Now, I think what well do is, I will explain to the jury that the initial t itle of
the tape was added by the District Attorney, and theyre to disregard that; that this is
compilat ion of two separate videos, and that its being entered with -MR. ZONEN: Let me have just one moment, please. Let me have one moment.
MR. MESEREAU: If I may, Your Honor, its four videos theyre made to look like one.
Theyre not one at all.
MR. ZONEN: Let me have just one moment.
THE COURT: All right. (Off-the-record discussion held at counsel table.)
MR. MESEREAU: If I may address the Court, Your Honor.
THE COURT: Wait till hes through with his conference.
MR. MESEREAU: Sure. (Off-the-record discussion held at counsel table.)
MR. ZONEN: Your Honor, were going to play the original ones. Were going -- as soon as
we get it. We will not play this one. We will do the originals. We dont have them here.
Were going to make arrangements to get them as quickly as we can.
THE COURT: All right. I think I -- I think I find that to be an acceptable way to proceed. I
do want to tell the jury, though, when they come back in that the initial tit le they saw
was, in fact, added by you, and not part of the seized tapes. They were tapes, right?
MR. ZONEN: Yes. The original videotapes have been transposed to a DVD.
THE COURT: Okay.
MR. MESEREAU: Thank you, Your Honor.
MR. SNEDDON: Ron? Can I just have one moment?
THE COURT: Yes. (Off-the-record discussion held at counsel table.)
MR. ZONEN: The problem that were dealing with at this moment is that all of the
detectives are currently at a funeral, and Im not sure that were going to be able to get -are we -THE COURT: Let me tell you, what well do is, you know, well start our break now that we
normally take at 1:15. So, the jurys already out, so we wont bring them back in. And
well just start our break, and take a -- lets take a 20-minute break, and then you can
decide how youre going to proceed on the break. What we do know is youre not going to
-MR. ZONEN: I will be not showing this one. I will show the originals.
THE COURT: And I do want to remember, when they come back in, to tell them to
disregard the opening title. And -- okay? Any objection to that?
MR. MESEREAU: No, Your Honor.
THE COURT: All right. Lets start our break, then.
MR. AUCHINCLOSS: Can you go to Black Screen, Your Honor? Thank you.
(The following proceedings were held in open court in the presence and hearing

THE COURT: Go ahead.

MR. ZONEN: Your Honor, were going to withdraw this exhibit at this time and were
going to play it tomorrow morning.
THE COURT: (To the jury) All right. On the exhibit that we started to show you just
before the break, there was a label, a heading on it, and the label was not part of the
seized exhibit. It was added by the District Attorney as a title, and Im going to instruct

you to disregard that label and do not consider it in any way in your deliberations in the
case. And youll -- you will see the material but it will come in in a different form than it
was going to come in today. All right. You may proceed.
MR. ZONEN: Thank you.

DIRECT EXAMINATION (Resumed) BY MR. ZONEN:

Q. Miss Arvizo, by the time that you got back to El Monte and then back to your residence
in Los Angeles, how long had the children been out of school?
A. About less than two months. Less than.
Q. Did they have any instruction during that period of time at all?
A. None. Zero.
Q. Did you have, during that period of time, a conversation with either Michael Jackson o r
Vinnie or Frank about them getting tutoring?
A. Yeah. W e had to go to Brazil if we wanted to get tutored.
Q. Who was that you had a conversation with?
A. With Frank and Vinnie.
Q. At different times or together?
A. Different times, together.
Q. What did Frank tell you specifically about tutoring?
A. That if I wanted a tutor for my children, that we had to leave the country and go to
Brazil; that they could provide a tutor there. Everything was always Brazil.
Q. All right. Was there any mention by either 6345 Frank or Vinnie that a tutor had
already been arranged in Brazil?
A. I cant remember that.
Q. All right. Did either one of them tell you where specifically in Brazil you were going to
be going?
A. Yes.
Q. Where?
A. In Brazil, it had to be in a place where there was no American hotels, no hotels, so no
one could notice me and my children.
Q. Did they tell you whether any of them, meaning Frank or Vinnie, would be going with
you to Brazil?
A. Yes. Frank and Vinnie and Brad Miller and Marc Schaffel had already prepared an
apartment full of surveillance and everything there. This is what Frank and Vinnie told me.
Q. Did they tell you what city in Brazil?
A. No. They did tell me that it was away from any hotel.
Q. Did they tell you what size city or community or town you would be going to?
A. No.
Q. Did they tell you how long you would be there?
A. Until they did damage control for Mr. Jackson. And I followed everything that they said.
There may be a possibility that I could come back, depend ing on what I did.
Q. Did they actually tell you in terms of days or weeks or months?
A. At this point, no. It was until they decided.
Q. Did they tell you whether or not Mr. Jackson would be joining you there in Brazil?
A. No. Mr. Jackson would not be joining us there.
Q. Did either of them say that specifically?

A. Yes.
Q. Who?
A. Frank and Vinnie. And remember, this is an evolution, different times -MR. MESEREAU: Objection; move to strike her comments.
THE COURT: Ill strike the last sentence.
Q. BY MR. ZONEN: Do you recall when the conversation was specifically with Frank about
whether or not Michael Jackson would be joining you there?
A. That was towards the end. There was going to be just me and my kids, and -- in the
apartment that Brad Miller, Marc Schaffel had prepared full of high-tech monitoring
surveilling system, surveilling me and the kids, and -Q. Did your two sons and Davellin enroll back 6347 in school again?
A. Yes, I enrolled them back in school.
Q. Which school did the boys enroll in?
A. The boys re -- I reenrolled them back into John Burroughs.
Q. Did you continue living at the St. Andrews apartment?
A. I now began living in the St. Andrews apartment.
Q. Full time?
A. Full time in a one-bedroom apartment, now with Jay.
Q. Where did Davellin reenro ll in?
A. I enrolled her in a high school near my moms out in El Monte.
Q. This is a different high school -A. Different high school.
Q. Hold on. W ait till the question is asked. This is a different high school than the one
prior to going to Miami?
A. Thats correct, its a different high school now.
Q. And which high school was it in E l Monte?
A. Now its Mountain View High School.
Q. And did she live with your parents?
A. Now my daughter began living with my parents.
Q. Where does she live now?
A. My -- my daughter lives with us now.
Q. Were you able to get your possessions back?
A. Until the police got involved.
Q. Did you know -- by possessions, I mean your possessions from the Soto Street
address.
A. Thats correct.
Q. What did you have at the Soto Street address at the time that it was moved from that
location?
A. All my stuff. All my stuff from my apartment.
Q. What do you mean by stuff?
A. My furniture, the -- what was still there, because some -- some of these things got rid
of.
Q. All right.
A. Our clothing. Our -- Let me see. What else?
Q. Did you have furniture?
A. No. The only thing that they left in there was my kitchen table with my kitchen chairs.
Q. All right. But was there some understanding with either Frank or Vinnie or somebody
else that your possessions would either be stored or moved?

A. No. At this point it was a no. Remember I said I wou ld think about it? And then I finally
said no.
Q. When you finally got your possessions back, was what was returned to you everything
that existed in the apartment?
A. No.
Q. What was missing?
A. What was missing was all of -- everything to do with Mr. Jackson. Everything.
Q. How about furnishings, furniture?
A. My kitchen table, my chairs were returned back to me.
Q. Okay.
A. My childrens clothing, my clothing. My pictures that were hanging on my wall.
Q. Were returned?
A. Were returned.
Q. Okay.
A. And -- but all the stuff that Mr. Jackson had given Gavin were gone.
Q. Did you have kitchen appliances of sorts?
A. Yes, I did.
Q. Pots and pans?
A. Yes, I did.
Q. Silverware?
A. Yes, I did.
Q. Plates?
A. Yes.
Q. Cups?
A. Yes.
Q. Was that all returned?
A. Yes.
Q. Prior to going to Miami had you moved any of your possessions to Jays apartment?
A. No.
Q. Did you seek help from anybody in an effort to get your property back?
A. Yes, I did.
Q. Who?
A. From Mr. Dickerman.
Q. Before contacting Mr. Dickerman, did you contact anybody from Neverland to -A. No.
Q. Wait till the whole questions asked.
A. Uh-huh.
Q. Before contacting Mr. Dickerman, did you contact anybody from Neverland in an effort
to get your property returned?
A. No way.
Q. Did you have any other conversations with anybody from Neverland after you left?
A. No.
Q. Did you know where your possessions were?
A. No, I didnt.
Q. Did Mr. Dickerman write a number of letters on your behalf?
A. Yes, he did.
Q. Did you read those letters?
A. Yes, I did.

Q. Had you noted -- had you seen your passports prior -- well, you answered that you had
seen them with Frank; is that right?
A. No. Vinnie.
Q. Im sorry, with Vinnie.
A. Yes.
Q. Were your passports among the items that were requested to be returned?
A. Yes.
Q. And I assume they were not returned to you?
A. They werent. They werent.
Q. Were there other personal items that were requested returned?
A. Yes. The childrens clothing. Thats one of them.
Q. Was there something else that you wanted Mr. Dickerman to do on your behalf?
A. Yes. For Michaels people to stop following us; that we did not want to go back. To get
the message, Please, leave us alone.
Q. Was that communicated in the form of a letter as well?
A. Yes, it was.
Q. And do you know to whom those letters were sent?
A. To Mr. Geragos.
Q. Mark Geragos?
A. Yes.
Q. Do you know if your children were still appearing on television in that production
Living with Michael Jackson?
A. Yes, they were.
Q. How do you know that?
A. Because Mr. Dickerman had told me, Jamie had told me.
Q. Others were telling you -A. Others were telling us.
Q. -- that it was still being featured?
A. Yes.
Q. Did Mr. Dickerman on your behalf attempt to get your children off television?
A. Yes, he did.
Q. At some point in time -- Id like to move back one second, if I could. I believe that you
had testified that the workers, the social workers from the Department of Child & Family
Services, that interview was conducted on the 20th in the morning hours; is that correct?
A. Yes.
Q. Did you see any of them the next day?
A. Yes, I did. On the 21st I did.
Q. Who did you see on the 21st?
A. I saw Karen Walker, the supervisor.
Q. What was the purpose of that meeting?
A. She had called -- like I had mentioned before, all my phone calls was being monitored
every day, 24 hours a day. Monitored, listened, surveilled, watched, followed. Everything.
She had came -- she requested that I sign a paper that said I understood the language in
English. Bilingual form.
Q. All right.
A. Over the phone. So I went ahead, I said, Yes, please come.
Q. And did you sign that document?

A. Yes. She came, she met me outside. And I tried to run around on her drivers side to
try to talk to her secretly, and at that time Im being followed right here, and Vinnies
right here, so I was unable to communicate to her. So when I ran around this way, now
Vinnie comes up and talks to her, and Im trying to talk where -- behind him to her.
Q. Was she in her car at the time?
A. She was in her car.
Q. Do you know what kind of a car she was driving?
A. I cant remember.
Q. Do you know cars at all?
A. Yeah, I do.
Q. Was it a sedan, or some other kind of car?
A. No, no. It was kind of like a little -- kind of like a little -- I dont know if its called a
little SUV. I dont know. Kind of like a Range Rover type of thing. 6354
Q. Did you commun icate to her anything other than the fact you spoke both English and
Spanish?
A. No. But when Vinnie was talking to her, telling her that -MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: Ill strike after, No.
Q. BY MR. ZONEN: Did Vinn ie say something to Karen Walker in your presence?
A. Yes, he did.
Q. All right. Where was Vinnie standing at the time?
A. Right there on the passenger-side window, talking to her.
Q. And where were you?
A. I was right here.
Q. I dont know where here is.
A. Right behind him off to the side.
Q. You were on the passenger-side window as well?
A. Yes.
Q. And next to Vinnie?
A. Yes, sir.
Q. What did Vinnie say to Karen Walker that you were able to hear?
A. Vinnie told Karen Walker that the children were being put in school immediately.
Because Karen Walker asked him, were the children going to be put 6355 in school. And
he said yes, the next day.
Q. This was on the 21st of February?
A. Yes, which was a Friday.
Q. And the kids were not put in school thereafter?
A. They werent put in school.
Q. Did you seek a tutorial for your children or a tutoring program once you were back out
of Neverland?
A. Yes, I did.
Q. Where did you seek to do that?
A. After the children -- we were out, and I reenrolled the children in John Burroughs. I
took them to a place called G -- I apologize, JEI Learning Center to bring them up to
speed for all those weeks that they had missed school.
Q. How did you select JEI?
A. I was looking, actually, for a learning center somewhere in the vicinity of John
Burroughs so they would waste no time from attending school all day and then go there.

And then thats where I found it.

Q. Excuse me, Im sorry. At some point in time, were you introduced to an attorney by the
name of Larry Feldman?
A. Yes.
Q. Who is it who introduced you to Larry Feldman?
A. Bill Dickerman.
Q. Do you recall when it was you were introduced to Larry Feldman?
A. Yes, when Michaels people wouldnt stop following us.
MR. MESEREAU: Objection; move to strike.
THE COURT: Stricken.
Q. BY MR. ZONEN: Tell us the date, if you recall, of your first meeting with Larry Feldman.
A. I cant remember.
Q. Tell us approximately how many weeks after you finally -- after your children left
Neverland it was that you actually met with Larry Feld man, if you recall.
A. No, I cant remember.
Q. Whose idea was it to go to Larry Feldman?
A. Mr. Dickermans.
Q. After you saw Larry Feldman, d id he refer you to somebody else to see?
A. Yes.
Q. Who was that?
A. He referred us to see Dr. Katz.
Q. Is that Dr. Stan Katz?
A. Yes.
Q. What kind of a doctor did you understand Stan Katz to be?
A. Something with mental.
Q. Psychologist or psychiatrist?
A. Yes.
Q. Do you know which one he was, psychologist or psychiatrist?
A. No, I dont.
Q. Did each of you meet with Dr. Katz?
A. Yes, we did.
Q. And by each of you, who are we referring to?
A. Me and my three children. Davellin, Gavin and Star.
Q. Did you know why you were meet ing with him?
A. Yes, because Mr. Feldman -MR. MESEREAU: Objection.
THE COURT: After Yes, Ill strike that.
Q. BY MR. ZONEN: What was your understanding of why you were meet ing with Mr. -- Dr.
Katz?
A. Because basically my house was a cuckoo house now.
Q. At the time that you went to Mr. Feldman, did you have any understanding of
accusations of sexual abuse -A. No.
Q. -- to Gavin?
A. No.
Q. Had Gavin talked to you up to that point about anything that had happened at
Neverland to him?
A. Um --

MR. MESEREAU: Objection; hearsay.

THE COURT: Overruled. You may answer yes or no.
THE WITNESS: Yes. Gavin -Q. BY MR. ZONEN: No, just yes or no.
A. Oh, yes.
Q. Gavin did have a conversation with you?
A. No, it wasnt a conversation. It was like an erupted volcano.
Q. Hold on. At some point in time, did you actually sit down with Gavin and have a
conversation with him about what took place at Neverland?
A. No. It was always broken, always.
Q. At some point in time, did you sit down and have a conversation with Star about what
happened at Neverland?
A. He, too, it was always broken. I would always hush them up. Id say, Just forget
Forgive, forget. Forgive, forget.
Q. Did you have any belief at the time you went to Mr. Feldman that either of your boys
had been molested?
A. No, not molested. But I was aware of things.
MR. MESEREAU: Move to strike the comments.
THE COURT: Strike the last sentence.
Q. BY MR. ZONEN: Did you go to Mr. Feld man because you believed your children were
molested?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. You may answer.
THE WITNESS: My children -- Gavin was like an erupted volcano, all the different things.
MR. MESEREAU: Objection; nonresponsive.
THE COURT: Sustained. Stricken.
THE WITNESS: Thats my answer.
Q. BY MR. ZONEN: Let me withdraw the question and let me ask it again.
A. Okay.
Q. Why did you go to Mr. Feldman?
A. Because as time progressed, I was find ing out more and more. I -- I thought it was just
alcohol.
Q. Were you concerned about the fact that your child had been given alcohol?
A. Yes.
Q. That was something -A. That was enough for me.
Q. Was that something you told Mr. Feldman?
A. Yes.
Q. Why were you concerned about your child having been given alcohol?
A. Because he only has one kidney -MR. MESEREAU: Move to strike.
THE WITNESS: -- and its malfunctioning.
THE COURT: Just a minute. You have to wait when theres an objection.
THE WITNESS: Okay. Okay.
THE COURT: All right. The objection is overruled. And the answer was, Because he only
has one kidney. Next question.
Q. BY MR. ZONEN: During the course of your interview with Dr. Katz, did you tell Dr. Katz
that you believed that your child had been mo lested?

MR. MESEREAU: Objection; lead ing.

THE COURT: Overruled. You may answer.
THE WITNESS: I dont remember what I told Mr. -- Dr. Katz. But -- I dont remember,
because as time went by it was progressing.
MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: I dont remember, Ill leave that part in. Strike the rest of it.
Q. BY MR. ZONEN: At the time of your meeting with Dr. Katz, did you believe that your
child had been molested?
MR. MESEREAU: Objection. Asked and answered; and leading; and foundation.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you ever come to a conclusion that your child had been mo lested?
MR. MESEREAU: Objection. Asked and answered; foundation; and lead ing.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes. When I was told by the D.A., police office -MR. MESEREAU: Objection. Move to strike; nonresponsive.
THE COURT: Ill leave the Yes and strike after that.
Q. BY MR. ZONEN: I just want you to tell us when, not the circumstance. But when did
you come to the conclusion that your child had been molested?
A. Okay, when. I dont remember when.
Q. Was it before or after your meeting with Dr. Katz?
A. Oh, its way after.
Q. Was it before or after your initial meeting with one of the detectives from the sheriffs
office?
A. It was after the police, the police form a trust bond with Gavin -MR. MESEREAU: Objection. Move to strike; nonresponsive.
MR. ZONEN: The question is simply when.
THE COURT: Just a moment. Just a moment.
THE WITNESS: Yes.
THE COURT: All right. Ill leave the answer, It was after the police, and strike the rest of
that sentence. Next question.
Q. BY MR. ZONEN: Approximately how long after your initial conversation with detectives
was it?
A. I cant remember. But it was after the police got involved.
Q. Okay.
A. But I was aware of things.
Q. Thats all. Just -MR. MESEREAU: Objection; move to strike.
THE COURT: Stricken.
Q. BY MR. ZONEN: When did you finally get your possessions back?
A. Until the police got involved. Yeah.
Q. Where were your possessions moved to at that time?
A. They were moved into another storage area, because I -- I no longer had a place now.
MR. MESEREAU: Objection. Move to strike; nonresponsive.
THE WITNESS: I -- okay.
THE COURT: Overruled. Next question.
Q. BY MR. ZONEN: Did you have an opportunity to go through your items after they were
ultimately returned?
A. Yes. With the police there.

Q. All right. And where was that that you went through all of your items?
A. I immediately went to the clay pot that I told you where I had -Q. Just tell us where it was that you looked at these items. Where is the location where
the items were where you looked at them?
A. Dinos Storage.
Q. Do you know where that is?
A. I cant remember.
Q. Okay. Was it someplace in Los Angeles County, to your knowledge?
A. Yeah. Yes.
Q. Now, at that location, did you go through all of your -A. Oh, God, no. I think it s somewhere near, like, Calabasas area. Somewhere like that.
Q. In the valley somewhere?
A. Yeah, in that area.
Q. San Fernando Valley?
A. Yes.
Q. Now, at that location did you go through all of your items to see what was there and
what was not there?
A. Yes.
Q. Were you able to find any of the letters that Mr. Jackson had sent to Gavin?
A. I immediately went to the clay pot. Lifted it up. Gone.
Q. Was everything missing from the clay pot?
A. Everything was missing.
Q. Were there any other items besides letters that were missing?
A. Yes. Pictures, and that rabbit.
Q. By pictures do you mean photographs?
A. Yes.
Q. And these are photographs of what?
A. Of Michael with the children.
Q. And then you said a rabbit.
A. Yes.
Q. Youre talking about a doll of some kind?
A. Yes. Yes.
Q. And from where did this rabbit come from?
A. From Michael, from Mr. Jackson.
Q. And what became of that?
A. Gone.
Q. Do you recall the jacket that you referred to that was given to Gavin by Mr. Jackson?
A. Yes, I do.
Q. What happened to that jacket?
A. I turned that over to Mr. Sneddon.
Q. And did you identify that jacket before the grand jury?
A. I dont remember if I did that. I dont remember.
Q. Can you describe that jacket for us?
A. Yes, I can. Its black with -- Mr. Jackson said it was crystals on the back.
Q. Something that glittered? 6365
A. Yes. Mr. Jackson said it was real crystals.
Q. Was there anything else that was given to any of your children by Mr. Jackson during
the time that they were with him during the months of February or March?

MR. MESEREAU: Objection; foundation.

THE COURT: Sustained.
Q. BY MR. ZONEN: Did you ever see a watch?
A. Yes. Mr. Jackson told Gavin that it was a $75,000 watch.
Q. And where did you see that watch?
A. On his wrist. On Gavins wrist.
Q. At -A. Mr. Jackson took it off of his wrist and placed it onto Gavins wrist.
Q. Were you watching that happen?
A. I dont think I did. I dont think I did I just know afterwards this is what I found out.
MR. MESEREAU: Objection. Move to strike; no foundation.
THE COURT: Sustained. Stricken.
Q. BY MR. ZONEN: Where did you first see that watch?
A. I first seen it when -- I think when Gavin got off the airplane. And then the rest of the
time when they were at Neverland.
Q. Did he wear that watch while you were at Neverland? 6366
A. Yes, he did.
Q. Can you describe the watch for us?
A. Oh, it was gold, and it had stuff that looked like diamonds on the face. Thats the best I
can remember.
Q. For how long did Gavin wear that watch?
A. Every day until -- every day. Every day, I think, prior to going back to Neverland. I
think so. I dont remember. Im doing my best estimate.
Q. When he took the watch off, what happened to the watch?
A. Oh, he didnt take it off while he had it on at Neverland at all.
Q. At some point in time did he stop wearing the watch?
A. Yeah. W hen we got back, I took it off. You know, Stop wearing this ridiculous watch.
Q. Okay. What did you do with the watch?
A. I think I had -- I think I had Jay -- I left it at Jays apartment.
Q. And ultimately where d id the watch go?
A. I gave it to the police.
Q. Mr. Sneddon?
A. Yes, Mr. Sneddon. The police.
Q. The police. Do you remember who it was you gave it to?
A. Let me see. Okay. Yes, I did. I gave it to the attorneys, because I didnt want it in my
house. And then -Q. Which attorneys?
A. I gave it to Mr. Dickerman, and then we ended up giving it to Mr. Feldman, and then
the police retrieved it from Mr. Feldmans office, the -- yeah.
Q. While you were at Neverland, did anybody talk to you about finding you a place to live
ultimately after Brazil?
A. No. The -- it was at Brazil.
Q. No, but did anybody ever talk to you about getting a house for you or apartment or a
condo or something like that?
A. The condition was that we had to leave the country.
Q. Im sorry. The question was, did somebody talk to you about getting a house or an
apartment at some time?
A. Only if we left the country.

Q. Does that mean the answer is yes, somebody did -A. Yes.
Q. Okay. Now, this conversation was with whom?
A. With Frank and Vinnie.
Q. At the same time?
A. Yeah.
Q. Okay. Were both of them talking to you?
A. Yes. They were trying to get me to leave the country.
Q. And this was still while you were at Neverland?
A. Yes.
Q. What did they say specifically about getting you a house or an apartment, or what -A. If I left the country, I can have that.
Q. You could have what?
A. A house and an apartment to go back and forth. But, no, I didnt want to leave the
country.
Q. I dont understand, a house -- I dont understand. What does that mean, to go back
and forth?
A. Thats what they said. Frank and Vinnie came up with different things every time. But
the key here, that is consistent, is that, You got to leave the country.
Q. Conditioned upon going to Brazil?
A. Yes.
Q. What did they say specifically about a house or an apartment? What did they say?
A. If I left the country I could have that.
Q. You could have what?
A. A house and an apartment.
Q. Did they say why you would need both a house and an apartment?
A. They said something like to go back and forth. This way theres still -- I have that
burned in my brain, appeas ing the killers. This way, if the killers showed up at the
apartment, I could go to the house; from the house to the apartment.
Q. Did they tell you Michael Jackson would be purchasing that for you or renting that for
you or what the arrangement would be financially?
A. That Mr. Jackson would do it if I left the country.
Q. Did you understand that you would actually own this?
A. No.
Q. They didnt say one way or the other whether -A. No, they just said as I told you.
Q. You didnt ask whether this would be something in your name or somebody elses
name?
A. No.
Q. Or whether youd have to pay rent on it?
A. I knew I d idnt want to leave the country. I dont care what they promised me.
Q. Did either Frank or Vinnie make any other representations to you in terms of money, or
college educat ion, or anything else that they would be giving you if you went to Brazil?
A. No.
Q. Did he make any representations of what they would be giving to you even if you didnt
leave for Brazil?
A. No. Zero.
Q. During the period of time from the time that you were contacted by Michael Jackson

back in early February of 03 to the time that you left Neverland and your children left
Neverland on around the 11th of March, did you ever ask anybody from Neverland,
whether it was Michael Jackson or Vinnie or Frank, for money?
A. No. Zero.
Q. Did you ever ask any of them for money prior to that time -A. No.
Q. -- on February 4th?
A. Thats not my nature.
Q. Did either or any of them at Neverland make an offer to give you money?
A. No.
Q. Did you receive money from any of them?
A. Nope.
Q. And by receiving money, I mean at any time since you first visited Neverland back in
August of 2000 until you ultimately left and had no further communication with them.
A. No.
Q. Did you ever have a conversation with anybody at Neverland, whether it was Michael
Jackson or Vinnie or Frank or anybody else, about the subject of whether money would be
given to you?
A. No.
Q. Did you ever ask anybody at Neverland, whether it was Michael Jackson or anybody
else, to support you for the rest of your life?
A. No.
MR. ZONEN: Could counsel and I approach the bench briefly about the exhibit?
THE COURT: All right. (Discussion held off the record at sidebar.)
THE COURT: Okay. Were ready to go.
Q. BY MR. ZONEN: Miss Arvizo, are you intending on filing a lawsuit against Michael
Jackson?
A. No.
Q. Are you intending on filing a lawsuit against Michael Jackson on behalf of your children?
A. No.
Q. Are you intending on doing it anytime during this proceeding or anytime thereafter?
A. No.
MR. ZONEN: Your Honor, I have no further questions at this time. I do intend to play the
video once the particulars are worked out on it. And
THE COURT: All right. What we agreed to at the sidebar here was the District Attorney
needs to prepare the three or four tapes that he was going to show earlier that was
compiled into one. Hes going to show them separately based on an earlier ruling I mad e.
And rather than have Mr. Mesereau start late in the afternoon with cross-examination and
then be interrupted with that, were going to recess early. (To the jury) I knew youd be
unhappy about that. Ill see you tomorrow morning at 8:30. Remember the admonit ion.

2005 April 15 (Day 33) Janet Arvizo Cross Exami nation & Videos

JANET ARVIZO EXAMINATION (Conti nued)

DIRECT EXAMINATION (Continued) BY MR. ZONEN:

Q. Yesterday I asked a few questions about your testimony with regards to your being
followed at times. Did you ever see people actually filming you?
A. Yes.
Q. Do you remember where and when you saw people filming you?
A. At Jays home. My childrens school. At church. Everywhere.
Q. And I had asked you if you recognized any of those people. Did you recognize any of
those people?
A. Yes, I did.
Q. And could you tell us the names of any of the people you saw?
A. One of them was Johnny, and I think one other time was Asaf, and then there was one
to three people. And then after we left, permanently left Neverland, thats the first time I
ever saw a female, in addit ion to a group of males.
Q. Prior to coming into court today, on a couple of different occasions did you have an
opportunity to view videotapes of different persons being filmed out on the street and at
other locations?
A. Yes, I did.
Q. Did you recognize the people who are the subject of those films?
A. I sure did.
Q. And who were they?
A. My mom, my dad, my daughter.
Q. Davellin?
A. Davellin. My boys, Gavin and Star. And my now husband Jay Jackson. MR. ZONEN:
And, Your Honor, were prepared to play it at this time. THE WITNESS: And myself.
Q. BY MR. ZONEN: You were among them?
A. Yes. THE COURT: All right. MR. ZONEN: We need a moment. Excuse me. Just one
moment. Your Honor, Im sorry, we need to reboot the computer. Its going to take a
moment. THE COURT: Whats the exhibit number on this? MR. ZONEN: Im going to

withdraw the other exhibit, the DVD, and were going to do this as three separate DVDs.
THE COURT: Actually, I dont think you can withdraw it. There were objections made
concerning it. It will have to remain in evidence. MR. ZONEN: Thats fine. THE COURT: Not
in evidence, but it will have to remain as an exhibit. Not in evidence. MR. ZONEN: All
right. Then well simply give three new exhib it numbers to these three DVDs. THE COURT:
While thats being done, could I ask counsel to, each of you, file a response to the special
masters report Monday so that I know what your positions are on that? MR. MESEREAU:
Yes, Your Honor. THE COURT: And a response from the defense to the supplemental
motion that was served on me today, probably due today. MR. MESEREAU: I have not
seen that, Your Honor. MR. SANGER: We received a motion this morning. Is that what
youre referring to? THE COURT: Yes. MR. SANGER: Is that what youre referring to? THE
COURT: They cant hear you.MR. SANGER: W e received a motion this morning, if thats
what youre referring to.THE COURT: Yes. You might respond to that by Monday also. MR.
SANGER: Monday at 3:00. THE COURT: At what?
MR. SANGER: At 3:00. Or Monday morning at 8:00? THE COURT: Yes. That would be
good. MR. ZONEN: Your Honor -- THE COURT: You ready? MR. ZONEN: Almost. MR.
AUCHINCLOSS: Some technical difficulties. I think what well try to do, Your Honor, is play
it on the DVD player, so wed ask you to go to Input 4.BAILIFF CORTEZ: Sir, your
microphones off. 6382
MR. ZONEN: W e also have the VCR here. We can do it on that. Either way well be able to
do
it this morning, if the computer doesnt work. In the meantime, could I wrap up a little bit
of old business? Exhibits 809 and 810 that are already in evidence are tapes in the form of
a DVD and a CD -- CV -- CD. And the Court was waiting for transcripts from the People.
We have those transcripts and they are now numbered 809-A and 810-A, and a copy has
been furnished to the defense. Ill submit that to the Court at this time.THE COURT: All
right. And youre offering 809 at this time? MR. ZONEN: 809 is not in evidence. We are
offering it into evidence. Thats right. THE COURT: All right. Thats admitted. And 814, did
you mention that? THE CLERK: 814 is the one that had writing on the back. They were
going to do it later. MR. AUCHINCLOSS: Can we go to Input 1 --or Input 4, Your
Honor?(Whereupon, a portion of a DVD, Plaint iffs Exhibit No. 815, was played for the
Court and jury.)
Q. BY MR. ZONEN: Miss Arvizo, weve now -- this frame is stalled at this spot here. Can
you tell us what were looking at?
A. Youre looking at my mo ms house.
Q. This is in El Monte?
A. This is in El Monte.
Q. All right. The building -- the front portion of the building -- do you have the laser? This
front portion, is this portion your parents house, as well?
A. Yes, it is.
Q. What is it?
A. Thats the garage area.
Q. Thats a gate thats in front of the house along here?
A. Yes. MR. ZONEN: All right. Lets go ahead and proceed. Excuse me just one second
before we start. MR. AUCHINCLOSS: It just went dark. But I can back it up. MR. ZONEN:
Lets start here.
Q. On February 14 of 03, do you know where you were on that day?
A. I think -- to my best estimate, I think I was already at my moms house. I think that,

to my best estimate, is when Jesus had brought me back. MR. ZONEN: Okay. Lets go
ahead and advance it. THE W ITNESS: And notice the time. 6:40 a.m. MR. MESEREAU:
Objection. THE COURT: Sustained. No question pending.
Q. BY MR. ZONEN: All right. This is still your parents house?
A. This is still my parents home.
Q. And the last entrance on there was 10:35 a.m.?
A. Yes.
Q. All right. THE COURT: Just for the record, what number is the exhibit youre showing
now? MR. ZONEN: 815, Your Honor. This is 815.
Q. BY MR. ZONEN: Do you now recognize the picture that youre looking at?
A. By the shape of the tree, the shape of the top of the garage and the white area above
the garage door, thats my mothers home. This is after my -- Jesus had brought us back.
Q. And the -- on this frame are the words and numbers February 15, 03, 6:09 a.m. Go
ahead. (Whereupon, a portion of a DVD, Exhibit 815, was played for the Court and jury.)
MR. ZONEN: Go ahead and stop.
Q. This frame now reads February 15, 03, 1:04p.m. Miss Arvizo, what are we looking at
right now?
A. Youre looking at my parents home from a different angle. And this is still my best
estimate from when Jesus helped me and my children come out of Neverland.
Q. The building that were looking at right now - and Im pointing with the laser in front is that the garage?
A. Yes, it is.
Q. And your parents residence over here to the left?
A. Yes, that is the complete home.
Q. All right. And the entryway into the -- is from the garage over here?
A. No. This way.
Q. Over this way?
A. Yes.
Q. On this side, to the left is the garage?
A. Yes, it is. (Whereupon, a portion of a DVD, Exhibit 815, was played for the Court and
jury.)
Q. BY MR. ZONEN: Now, this says in the lower right February 15, 03, 3:07 p.m. And
what are we looking at here?
A. You are still looking at my parents home.
Q. Theres the one right there.
A. Okay.
Q. Show us, please, where your parents house is.
A. This is -- right here is the door, my parents front door. Right here.
Q. The red car that we see in the driveway, is that -A. That is the neighbors car. 6386
Q. And your parents garage, can you see it?
A. Its right here. Heres the white of the top of the front of the garage. Theres the garage
door. You walk around this way, and right there is the front door. MR. ZONEN: Okay. Go
ahead. (Whereupon, a portion of a DVD, Exhibit 815, was played for the Court and jury.)
Q. BY MR. ZONEN: Who is this person?
A. This is my father.
Q. And go ahead and point the laser so we can see where he is.
A. And I think -- MR. ZONEN: Advance it a little bit. THE W ITNESS: Right -- right there.

MR. ZONEN: Okay. Go ahead. (Whereupon, a portion of a DVD, Exhibit 815, was played
for the Court and jury.) MR. ZONEN: Stop right there.
Q. That person walking by, who is that?
A. This is my mother.
Q. And right now were looking at the lower right-hand corner of the frame, it says
February 15, 03, 3:51 p.m. Go ahead. (Whereupon, a portion of a DVD, Exhibit 815, was
played for the Court and jury.) MR. ZONEN: Stop right there.
Q. Were looking at a new frame that says February 15, 03, 8:12 p.m. Do you recognize
the subject matter of what youre able to see?
A. Yes, I do.
Q. What is that, please?
A. This is now the underground parking of Jays apartment building.
Q. Is that the one on St. Andrews?
A. Yes, it is. MR. ZONEN: Your Honor, were going to the tapes at this time.The next tape,
Your Honor, is 816. THE COURT: 816? MR. ZONEN: Yes. MR. AUCHINCLOSS: Can we go to
Input 4, Your Honor? Or Input -- yes, Input 4.Thank you. (Whereupon, a portion of a
CD, Plaintiffs Exhibit No. 816, was played for the Court and jury.)
Q. BY MR. ZONEN: This now says February 19, 03, at 5:56 p.m. Whose car is that?
A. This is Jay Jacksons car, my husband.
Q. Can you tell whos driving?
A. This is my husband whos driving.
Q. And the location now?
A. This is the underground parking of Jays apartment on St. Andrews. MR. ZONEN: Go
ahead. (Whereupon, a portion of a CD, Plaintiffs Exhibit No. 816, was played for the Court
and jury.) MR. ZONEN: Stop it.
Q. Were now looking at a frame that reads February 19th, 03, at 6:01 p.m. Can you tell
what were looking at here?
A. Yes, youre looking at my husband Jay Jackson.
Q. Do you know where he is? Can you tell?
A. He is in an area called Larchmont. Its in -- theres different -- its kind of like a -different eating places. Different -- a marketplace in Larchmont. Near where Jay Jackson
used to live.
Q. Its in Los Angeles?
A. Yes, it is. (Whereupon, a portion of a DVD, Exhibit 816, was played for the Court and
jury.)
Q. BY MR. ZONEN: Let me stop at this moment and ask you a question.
20 A. Yes.
Q. I believe that you had testified before that it was at the end of the day of the 19th that
you went to Calabasas for the video; is that correct?
A. That is correct.
Q. Do you know where you were at approximately six oclock in the evening?
A. I was inside Jays apartment. MR. ZONEN: Go ahead. (Whereupon, a portion of a CD,
Plaintiffs Exhibit No. 816, was played for the Court and jury.)
Q. BY MR. ZONEN: Are we still following your husband?
A. Yes, you are still -- theyre still fo llowing my husband. MR. ZONEN: Okay. (Whereupon,
a portion of a CD, Plaintiffs Exhibit No. 816, was played for the Court and jury.)
Q. BY MR. ZONEN: The frame that weve stopped is February 21, 03, 2:04 p.m. Tell us
who were looking at here.

A. This is me and -Q. Hold on a second. The question is simply, who are we looking at? Thats you; is that
right?
A. Yes.
Q. And do you have a recollect ion of having a conversation with somebody in a Range
Rover on that day?
A. Yes, I do.
Q. With whom did you have a conversation?
A. I had a conversation with Miss Karen Walker.
Q. And Karen Walker you ident ified previously as the social worker?
A. Yes.
Q. Do you remember the nature of that conversation?
A. Yes, I do.
Q. Now, was it your testimony previously that Vinnie was somewhere in that area?
A. Yes. MR. ZONEN: Go ahead and play. (Whereupon, a portion of a DVD, Plaintiffs
Exhibit No. 816, was played for the Court and jury.) MR. ZONEN: Stop.
Q. Miss Arvizo, who is that?
A. This is Vinnie.
Q. All right. Were now where it says February 21, 03, at 2:04 p.m. And the timeline on
the lower left of this frame reads 11:33:11. (Whereupon, a portion of a DVD, Exhibit 816,
was played for the Court and jury.)
Q. BY MR. ZONEN: Is that Vinnie?
A. This is Vinnie.
Q. And this reads 11:45:29 is the time segment on the lower left-hand side, February 23
at 2:04 p.m. Go ahead. (Whereupon, a portion of a CD, Plaintiffs Exhibit No. 816, was
played for the Court and jury.) MR. ZONEN: Stop just a second.
Q. Were now at February 21, 03, at 3:05 p.m. It reads the time is 11:50:18. Can you tell
us what were looking at right here?
A. Yes, I can.
Q. What is this?
A. This is the vehicle that I was in with Vinnie. I remember the -- that little light thing
going across. And I remember the seat being above me. And thats Vinnies hair on top of
-Q. Go ahead and show us with the laser Vinnies hair. And then -- are you in the seat?
A. Right there. Im in there. But the seats higher than me. MR. ZONEN: Okay. Go ahead.
(Whereupon, a portion of a CD, Plaintiffs Exhibit No. 816, was played for the Court and
jury.)
Q. BY MR. ZONEN: Santa Monica Boulevard is whats now showing, the street sign; is
that correct?
A. That is correct.
Q. And do you remember being on Santa Monica Boulevard?
A. Yes. MR. ZONEN: Go ahead. (Whereupon, a portion of a DVD, Plaintiffs Exhibit No.
816, was played for the Court and jury.)
Q. BY MR. ZONEN: Who is that?
A. This is me. And in the vehicle is Vinnie.
Q. Vinnies driving and youre getting in?
A. Yes.
Q. And this is on the 21st of February, 03?

A. Yes.
Q. And the time reads at 4:15 p.m. Go ahead. (Whereupon, a portion of a DVD, Plaintiffs
Exhibit No. 816, was played for the Court and jury.) MR. ZONEN: Stop.
Q. Are you in that frame?
A. Im right here. This is Vinnie right there. This is Vinnie right there. And Im right behind
this man. Right there. You can actually see us walking up behind this couple.
Q. That couple have nothing to do with you?
A. This couple has nothing to do with me. MR. ZONEN: A ll right. Go ahead. Or, hol it.
Q. Do you know where you are at this point?
A. At this moment I dont know where were at.
Q. Or on what street?
A. I dont remember. MR. ZONEN: Okay. Go ahead. (Whereupon, a portion of a DVD,
Exhibit 816, was played for the Court and jury.) MR. ZONEN: Your Honor, the next tape
were going to look at is 817. THE COURT: All right. (Whereupon, a portion of a DVD,
Exhibit 817, was played for the Court and jury.)
Q. BY MR. ZONEN: It reads March 17, 03, at 2:02 p.m. Can you tell us what were
looking at right now?
A. Yes, I can.
Q. And what are we looking at?
A. This is my daughter. And beyond that is my parents home.
Q. Show us where your daughter is in the picture. And the home? Now, where would you
and your family have been on March 17, 03?
A. On March 17, 03, my boys, myself, are with Jay. My daughter is with my parents. We
have permanently now left Neverland. MR. ZONEN: Okay. (Whereupon, a portion of a
DVD, Plaintiffs Exhibit No. 817, was played for the Court and jury.)
Q. BY MR. ZONEN: This is a close-up of your daughter looking back; is that right?
A. That is correct.
Q. And show us the house where shes going to.
A. Its right here. Right here.
Q. Is 2:02 about the time that shed be arriving back at school?
A. Yes, it is. I enrolled my daughter and my sons almost immediately into school.
Q. Shes wearing a backpack. Is that the type of backpack she traditionally took to
school?
A. That is correct. MR. ZONEN: Go ahead. (Whereupon, a portion of a DVD, Plaintiffs
Exhibit No. 817, was played for the Court and jury.)
Q. BY MR. ZONEN: And shes looking back a second time; is that correct?
A. Yes, she is looking back and she looks frightened. MR. MESEREAU: Objection; move to
strike her comments. THE COURT: Stricken. (Whereupon, a portion of a DVD, Plaintiffs
Exhibit No. 817, was played for the Court and jury.)
Q. BY MR. ZONEN: Is that the name of the street that your parents home is on?
A. This is the name of the street my parents live on. MR. ZONEN: We have a fourth tape
as well.
Q. Miss Arvizo, did you have an opportunity to take a look at a tape of the cleaning and
moving of materials from a residence?
A. Yes.
Q. Did you recognize the residence?
A. Yes.
Q. Whose residence was it?

A. It used to be my apartment.
Q. Is that the Soto Street address?
A. It is the Soto Street address.
Q. And the items that were being packed up, to the extent that there were still items left,
did you recognize those items?
A. Yes, I did recognize them.
Q. Whose items were those?
A. Theyre mine.
Q. Of any of the people who appear at any time in that film, did you recognize any of
them?
A. I did recognize someone to be, I think, Asaf.
Q. Was he the one who is the photographer or the videographer?
A. Asaf is the one who did the tape-recording of the Department of Child Family Services.
Q. Hold on a second. The question is, in the course of the -A. Oh.
Q. -- the film that you saw previously, youre about to see -A. Oh, okay.
Q. -- is he the one holding the camera?
A. That is correct.
Q. At one moment he appears in a mirror, is that correct?
A. Yes, he is. MR. ZONEN: Lets go ahead and play this one. (Whereupon, a portion of a
DVD, Plaintiffs Exhibit No. 818, was played for the Court and jury.) 6396
Q. BY MR. ZONEN: Which room is that?
A. This is our room that me and my children and my ex-husband used to live in.
Q. And sleep?
A. And sleep in. MR. ZONEN: Go ahead. THE COURT: Is this 818? MR. ZONEN: Yes, Your
Honor. (Whereupon, a portion of a DVD, Plaintiffs Exhibit No. 818, was played for the
Court and jury.)
Q. BY MR. ZONEN: Is that the picture that you saw before?
A. Yes, it is.
Q. And at some point, were you able to hear his voice as well?
A. Yes. MR. ZONEN: Lets resume (Whereupon, a portion of a DVD, Plaint iffs Exhibit No.
818, was played for the Court and jury.)
Q. BY MR. ZONEN: Was that Asafs voice?
A. That is Asafs voice.
Q. The deeper voice?
A. Yes, it is.MR. ZONEN: All right. (Whereupon, a portion of a DVD, Plaintiffs Exhibit No.
818, was played for the Court and jury.) MR. ZONEN: Your Honor, I have no further
questions. THE COURT: Cross-examine? MR. MESEREAU: Yes, please, Your Honor. THE
COURT: That was Exhibit 118. THE CLERK: 818.
THE COURT: 818. Are you offering that, or -- MR. ZONEN: Im sorry, Your Honor ?THE
COURT: Are those exhibits being offered? MR. ZONEN: Yes, they are, Your Honor. The
numbers are 815, 816, 817 and 818. MR. MESEREAU: Thank you, Your Honor. THE
COURT: Are there any objections to those exhibits? MR. MESEREAU: No objection at all.
THE COURT: All right. Theyre admitted.MR. MESEREAU: Your Honor, Mr. Sanger is
obtaining the tape of the phone conversation between Miss Arvizo and Frank Cascio, and
Im going to begin with that. And also, the prosecutor lodged a transcript with the Court
this morning of that phone conversation, which, with the Courts permission,Id like to

hand to the witness as we play that tape. THE COURT: All right. MR. MESEREAU: Thank
you, Your Honor.May I approach? THE COURT: Yes. The tape should be 809.

CROSS-EXAMINATION (Continued) BY MR. MESEREAU:

Q. Miss Arvizo, as you know, my name is Tom Mesereau and I speak for Michael Jackson.
Now, you heard the prosecutor for the government play a recorded phone conversation
between you and Mr. Frank Cascio, correct?
A. Yes.
Q. And you didnt know that conversation was being recorded, correct?
A. No.
Q. And to your knowledge, it was probably recorded by Mr. Cascio, correct? MR. ZONEN:
Objection; speculative. THE COURT: Sustained. Foundation.
Q. BY MR. MESEREAU: Before it was played in court, when did you last hear that
recorded phone conversation between you and Mr. Cascio?
A. I think it was during the grand jury. I think thats when it was.
Q. And you have in front of you a transcript of that phone conversation, correct?
A. Yes.
Q. Have you read any transcript of that phone conversation before today?
A. I think so.
Q. And who provided you with a transcript to read?
A. When I came -- the D.A.s Office.
Q. At this point, Miss Arvizo, Id like to play that recorded conversation for the jury, and at
various points Im going to ask my co-counsel, Mr. Sanger, to stop the recording, and Im
going to ask you questions about what Mr. Cascio says and about what you say. Okay?
A. Okay. MR. MESEREAU: With the Courts permission, well play the phone conversation,
Your Honor. THE COURT: And this is Exhibit --MR. SANGER: 809, Your Honor. THE
COURT: Okay. THE W ITNESS: And this is more than one conversation blended, put
together. MR. MESEREAU: I know your position. THE W ITNESS: Okay. MR. MESEREAU:
Well go through it. THE WITNESS: Okay. THE BAILIFF: Are you on Input 1, Your Honor?
Can you check that switch and make sure its
over, the audio switch?
BAILIFF CORTEZ: I hear something. THE BAILIFF: Is it where it was? BAILIFF CORTEZ:
No, its just a little b it --THE BAILIFF: It should work. BAILIFF CORTEZ: I hear it. MR.
SANGER: Is it going through the microphone? MR. MESEREAU: Start it again. THE
BAILIFF: I can turn it up here. MR. SANGER: This happened last time. We were told there
was a switch up there, but.... One more try, Your Honor. Im sorry THE BAILIFF: Did you
plug it into the defense? MR. SANGER: Its plugged into the defense.Plugged into the
back. Thats on. One, two, thats on. We can play it again with the speakers. THE COURT:
I think thats the best thing to do. THE BAILIFF: Theyre coming right over.MR. SANGER:
Your Honor, I dont know if the Courts willing to wait for just a moment. I hear theyre
coming right away THE COURT: W ould you like me to? MR. SANGER: It would be a lot
better to hear it through the system, I think.
THE COURT: All right. Well wait. 6401
MR. SANGER: Thank you. THE BAILIFF: We check this every day. They should be here any
minute, Judge.
Q. BY MR. MESEREAU: While were waiting, Miss Arvizo, let me ask you a few questions

about whats said in this conversation. Youre telling the jury under oath, that you never
wanted any kind of security provided to you by Frank, correct?
A. Yes.
Q. And you never made any statements to Frank that you needed any kind of protection,
correct?
A. Uh-huh. Thats correct.
Q. And when Frank offered you any type of security at your home, you always declined; is
that correct?
A. Thats correct.
Q. Because you never felt you needed any security of any kind from him, right?
A. No, what I said was I didnt want my parents to be scared.
Q. Are you telling the jury you didnt want any security from Frank?
A. Thats correct.
Q. And in no conversation with him did you ever say anything to that effect, right?
A. Thats how I feel.
Q. And did you ever tell Frank that your home
was being, in effect, bombarded by med ia people?
A. This was after a conversation with him.
Q. Did you ever tell Frank your home was, in effect, being bombarded by media people?
A. Yes, because I believed them after they had told me, and, yes, I saw it for my own self
in my parents home.
Q. So you saw media people bombarding your home?
A. Yes. With all the mail that was left on the table.
Q. And did you ever tell anything like that to Frank?
A. Yes, I did.
Q. Okay. THE COURT: W ould you pause so they can try to.... (Discussion held off the
record.) MR. SANGER: May I try it just to -- THE COURT: Yes. MR. SANGER: Thank you
very much. MR. MESEREAU: I think were all set, Your Honor. Thank you. THE COURT: All
right. Go ahead.
Q. BY MR. MESEREAU: Miss Arvizo, do you recall telling Frank with respect to the
rebuttal interview with you and your family that the Germans only want you to talk about
one charitab le act of Michael, but you want to talk about more than that?
A. What is your question?
Q. Do you recall telling Frank that you didnt like what the Germans were asking you to
say on the rebuttal video, because they only wanted you to talk about one charitab le act
of Michael and you wanted to talk about much more than that?
A. Thats incorrect.MR MESEREAU: Okay. Could we p lay the --THE WITNESS: Theres more
than that.MR. MESEREAU: I understand. Youll have your chance to talk about it. MR.
SANGER: Ready? MR. MESEREAU: Yes. THE WITNESS: Because they wanted me to do a
choreograph that me and Michael had done a charity act to German orphans. And I wasnt
going to do that, to say that that had happened. MR. MESEREAU: At this time were going
to play the conversation, Your Honor. Thank you. (Whereupon, a portion of a CD,
Plaintiffs Exhibit 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, youre telling Frank that you love his family, correct?
A. Yes.
Q. Youre telling Frank that, in effect, Were
27 all family, right?
A. Yes. Because of Michaels init ial lovey-dovey meeting.

Q. Just please answer my question, Miss Arvizo. The prosecutor will then ask you
whatever he wants. I just want direct answers to my questions, all right? Is that all right
with you?
A. If you could simplify the questions, that would be easier for me.
Q. I will try to make them as clear as I can. And if you dont understand, dont answer me.
Just ask me to try and restate it. Okay?
A. Okay. Thats fair enough.
Q. You told Frank Cascio in this conversation, Were all family, true?
A. I said, Its like were family. True.
Q. Did that mean in your mind that your family, Franks family, and Mr. Jacksons family
were all united?
A. Let me see. It says right here, I love you so much. You dont know how much I love
your little s ister and your little brother. Thats what it said.
Q. And then later on, it says, Its like were family, you know, Frank?
A. Yeah.
Q. Okay.
A. Like were family.
Q. And when you said that you meant it, true
A. Yes, I believed what he said in the init ial meet ing in Miami.
Q. I understand, it all comes from Miami, correct?
A. Correct.
Q. Doesnt come from your being at Neverland with the Cascio family, does it?
A. No.
Q. Were you ever at Neverland with the Cascio family?
A. With the whole entire family? No.
Q. With the children?
A. With the children, no, never before at Neverland, before Miami.
Q. So one trip to Miami and youre calling everyone family, correct?
A. Correct. MR. MESEREAU: Okay. Lets keep going. (Whereupon, a portion of a CD,
Plaintiffs Exhibit No. 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, you say to Frank, Its like were family, you know, Frank?
And he says, I know. And you say, You know. And people dont understand that,
correct?
A. Correct.
Q. And when you said, People dont understand that, what did you mean?
A. Well, I thought they were honest people. And, for example, people 50 and over have a
tender spot in my heart, and so its loving someone without knowing them. Thats what I
mean.
Q. So what youre saying is in your mind you were family with the Cascios because you
loved them without knowing them; is that correct?
A. Correct. MR. MESEREAU: Okay. (Whereupon, a portion of a CD, Plaintiffs Exhibit No.
809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, you say, Its like crazy here. Do you see that?
A. I said, it goes, Um, (inaudib le), bleep, are like crazy here, so I really couldnt tell you
what was before there.
Q. Lets go two lines down.
A. Okay. (Whereupon, a portion of a CD, Plaint iffs Exhibit No. 809, was played for the
Court and jury.)

Q. BY MR. MESEREAU: You say to Frank, Are like crazy here, And he says, Who? And
you say, The reporters and stuff. Right?
A. Correct.
Q. And please tell the jury what youre talking about.
A. Well, in my moms table, when I arrived from Neverland, from Jesus helping me, there
was a table filled with offers, many different offers requesting interviews, some people
offering cars, to various denominations, and just a variety of things. And the phone
ringing over and over and over.
Q. Okay. And people were coming to your house, true?
A. And some -- some of the reporters just wanted to talk. But it was all there.
Q. They were looking for you at times, correct?
A. Mostly my children. Mostly Gavin specifically. MR. MESEREAU: Okay. Lets keep going.
(Whereupon, a portion of a CD, Plaintiffs Exhibit No. 809, was played for the Court and
jury.)
Q. BY MR. MESEREAU: Now, youre talking to Frank after you say Chris took you and,
Jesus helped me leave, correct?
A. Correct.
Q. So the things youre saying to Frank on this tape -A. Has been manipulated.
Q. Oh, I understand your position, because well go through that.
A. Okay.
Q. And what youre saying is youve had someone look at this tape and decide its all been
jumbled up together; right? Is that your position?
A. My position is I had the conversation. I know when I left, the first time I left with Jesus,
the second time I left with Chris, two different events.
Q. Okay.
A. Thats why I know.
Q. But what you say is, Ya know, ya know, Frank, when I asked to leave on Sunday
night, and then Frank coughs, and then its inaudible, and it says, And, ah, Chris took
me and, ah, Jesus helped me leave. Do you see that?
A. Yes, I do.
Q. And obviously this conversation is happening after Jesus helps you leave?
A. Correct.
Q. And its after Chris helped you, correct?
A. No.
Q. Why did you say then, Chris took me and then Jesus helped me leave?
A. Because Chris -- this tape has been manipulated. But also on that day -- Chris was the
one who took me to go do the leg wax.
Q. Okay. Now, Chris was part of Michael Jacksons personal security group at Neverland,
true?
A. Correct. His personal bodyguard.
Q. Yes. Hes the one who took you for a body wax, correct?
A. Incorrect.
Q. Who took you for a body wax?
A. No one ever.
Q. Well, you went for a body wax when you were at Neverland, did you not?
A. Inaccurate.
Q. Never d id it?

A. Never d id it.
Q. Never went to a salon in Los Olivos and met someone there who treated you, correct?
A. I had a leg wax done.
Q. In Los Olivos?
A. In Los Olivos.
Q. And that was the day you claim Jesus helped you escape from Neverland, true?
A. That was the day that the Germans said that they wanted to do positive PR for Michael.
And I figured this is what they have and thats it. I could go now and it was still a no.
Q. The body wax you had in Los Olivos was the day that you claim Jesus helped you
escape from Neverland, true?
A. His statement is inaccurate. He keeps continuously saying body wax. There is no
body wax.
Q. What did you have at the salon in Los Olivos on the day you claim you escaped from
Neverland?
A. A leg wax.
Q. Okay. Okay. And how did you get to the salon to have the leg wax?
A. I didnt get them to do anything. They had already arranged it, the Germans , for their
positive PR for Michael. With the film crew following us.
Q. How did you get to the salon in Los Olivos from Neverland to have your leg wax?
A. Chris took me.
Q. So when you say, And, ah, Chris took me, and, ah, Jesus helped me leave, youre
talking about Chris, who is part of Mr. Jacksons security detail, taking you to Los Olivos to
the salon, right?
A. For Michaels positive PR.
Q. I understand what your position is, but Im asking you a direct question. On the day
you claim Jesus helped you escape from Neverland, thats the same day Chris took you to
a salon in Los Olivos for a leg wax, correct?
A. Well, if he wants to get that technical, it was the next day, because it was closer to 1
a.m.
Q. Well, how do you escape from Neverland with Jesus and then have Chris take you for a
leg wax?
A. Chris took me to have a leg wax in the afternoon. After midnight, about 1 a.m., is when
Jesus helped me and my children leave.
Q. Okay. And to -A. The next day.
Q. -- to get back to my initial point, this phone conversation is happening after you say
Jesus helped you leave from Neverland, isnt it?
A. These multiple conversations are happening after Jesus helped me leave. MR.
MESEREAU: Okay. All right. Lets keep going. (Whereupon, a portion of a CD, Plaintiffs
Exhibit No. 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, youre telling Frank Cascio -A. Just a moment, Mr. Mesereau. Where are we? Im trying to -Q. Were on the third page.
A. Okay.
Q. Okay? There are no numbers on the lines, but were on the third page. If you look
about midway through -A. Okay.
Q. -- you will see your comment, And, ah, Chris took me, and ah, Jesus helped me

leave. Do you see that?

A. Okay. But we played the tape a little b it further.
Q. Yes, we did. Yes, we did. And weve stopped two quotes down.
A. Okay.
Q. We stopped where it says, And thats how I feel. Do you see that?
A. Oh, goodness gracious.
Q. Do you see it? Do you want me to point it out to you?
A. Please. MR. MESEREAU: May I approach, Your Honor? THE COURT: Yes. THE WITNESS:
Okay. Good. Thank you.
Q. BY MR. MESEREAU: Youre talking to Mr. Cascio after Jesus helped you leave, and
youre telling him, My family, so as far as me and the kids, we are family, and thats how
I feel. Do you see that?
A. Yes, it says, My family -Q. Yes.
A. -- (inaudible), and then it says, So as far as me and the kids, we are family,
inaudible, and thats how I feel. MR. MESEREAU: Okay. Lets keep going. (Whereupon, a
portion of a CD, Plaintiffs Exhibit No. 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, Frank says to you, People out there are so evil. And you
reply, Yes, yes, Frank, they are, they are. He says to you, Theyre so evil, and you go,
Yes, I know, I know. R ight?
A. Correct. MR. MESEREAU: Okay. Lets keep going. (Whereupon, a portion of a CD,
Plaintiffs Exhibit No. 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, you start to talk about David, correct?
A. Yes.
Q. And you say, Theyve been replaying over and over the news over here and on the
radio. The father said making him so, so credible, you know, even the father said. David - he was -- theres nine criminal charges for what he did to that kid, you know. And for
what he did to me. He doesnt pay child support and, ah, he has a restraining order to
stay away from me and the kids. R ight?
A. Correct.
Q. And youre talking about your former husband David Arvizo, right?
A. Correct.
Q. Okay. And youre talking about a criminal case against him, right?
A. Correct.
Q. And that was a situation where the police were notified, right?
A. Two different criminal cases that both he pled guilty on 2001 and 2002.
Q. And one of them was an allegat ion that he had molested Davellin, true?
A. Not an allegation. Information.
Q. Okay. But, I mean, he was -- you know, you reported him to the police on a couple of
occasions, true?
A. No. That was --Hes incorrect. I was there. He was arrested for domestic vio lence. In
the process of being investigated for that, thats when they found out that theres more -that this man had caused more harm not just on me, but also my children, and so that
sparked an investigation on what he had done to my kids.
Q. And you did report him for having falsely imprisoned your family, true?
A. It was -- I give them the information and they did whatever they did with it.
Q. And you did report him for having molested Davellin, true?
A. They -- hes inaccurate. They asked a history about David, and the event hes referring

to is something that happened way over ten years ago.

Q. Okay. In answer to my question, there was a report made that David had molested
your daughter Davellin, true?
A. It was a one-sentence statement, and they were asking for the history of David.
Q. Was a report made that your former husband David had molested your daughter
Davellin? Yes or no.
A. That was in the midst of all the informat ion that they were gathering about David, so,
yes.
Q. Okay. Now, it mentions a restraining order, correct?
A. On which particular restraining order are we talking about?
Q. Im going to ask you about that.
A. Okay.
Q. Did you get a number of restraining orders against your former husband David?
A. Yes, that were issued through the Family Court and the criminal courts.
Q. And how did you do that?
A. Well, when David was arrested for domestic violence finally, the criminal courts issued
something that they do routinely, a restraining order.
Q. And at some point he was reported for having violated a restraining order, correct?
A. That is correct.
Q. And how did that happen? Please tell the jury how the case against him for violating a
restraining order came about.
A. Well, my daughter came home, told me what happened. So then I called -- I let them
know, the investigating officer, what had happened. THE COURT: Counsel? MR.
MESEREAU: Yes, Your Honor. THE COURT: Counsel? MR. MESEREAU: Thank you, Your
Honor.
Q. Miss Arvizo, we were talking about the domestic problems you had with David, okay?
And you said that you had obtained two restraining orders against him at various times,
right?
A. I didnt obtain them. It was through the court system that they were issued.
Q. One for the criminal court system, correct?
A. Which I think, as best I can remember, is that they routinely issue them.
Q. And one through the Family Court system; is that correct?
A. Correct. That my family attorney requested.
Q. And who was your family attorney at that point?
A. Mr. Michael Manning.
Q. Okay. And when the issue came up about David Arvizo violat ing a restraining order,
you went to court, true?
A. No.
Q. Did you ever appear in court for any hearing involving allegat ions that David had
violated a restraining order by talking to Davellin?
A. I think that was in the course of the --they didnt have a, what youre trying to say,
that there was a separate issue. It wasnt a separate issue. It was -- as best as I can
recall, it was within the midst of the domestic vio lence that he was arrested that he did
upon me.
Q. And the violation of the restraining order that was alleged against him had to do with
his showing up at school and talking to Davellin, true?
A. It had to do with the fact that he violated the restraining order.
Q. The violation of the restraining order had to do with David showing up at school and

talking to Davellin, right? MR. ZONEN: Your Honor, Ill object; lack of foundation. THE
COURT: Overruled. You may answer. THE W ITNESS: David, a grown man, was given a
restraining order, and he vio lated it.
Q. BY MR. MESEREAU: Let me repeat the question again. If its not clear, tell me.
A. Its not clear.
Q. Okay. What was the nature of the violat ion?
A. What do you mean?
Q. Didnt David go to Davellins school -A. Yes.
Q. -- see Davellin outside of school and ask her to go into his car and talk to him?
A. He called -- my understanding, because I wasnt there -- the best who could explain it
would be Davellin.
Q. You dont know what happened?
A. I do know, but the best one who could explain it would be Davellin.
Q. What do you know about it, Miss Arvizo?
A. Okay, my understanding is that David had called her over into the car, and he wouldnt
let her go until he finished his conversation with her and until he was satisfied. Then he let
her go. Thats my understanding. But the best one who could explain it is Davellin.
Q. You attended court with Davellin when there was a hearing with a judge on whether or
not David had violated that restraining order, right?
A. Again, that was in the midst of the domestic violence that he had done upon me.
Q. Did you attend court when there was a hearing on whether or not David had violated
the restraining order?
A. I think I understand what youre trying to say, but if not, please make me aware.
Q. Okay.
A. I feel that he is trying to say that I was present when these proceedings were
happening in the midst of the domestic violence. That is inaccurate. She went behind a
closed door with a judge, a court reporter, and a -- David, Mr. Halpern, h is attorney. And
thats where they had the hearing, some kind of hearing, understanding, talking. I dont
know what that process would be called. Because he had violated the restraining order.
Q. And you were in court that day, right?
A. They did it behind closed doors, in the judges chambers, and I was not allowed to be
present.
Q. You were in court that day, true?
A. I was in the courthouse, in the courtroom. But in the judges chambers when that took
place, I was not present. And there was a court reporter reporting everything there.
Q. And who was with you in court that day?
A. On that day was just -- it was me and Davellin, I think.
Q. Was Carol Lamir ever in court with you?
A. With me? No. Shes my ex-husbands, David Arvizos, best buddy.
Q. Was she ever in court with you for any proceeding involving domestic violence?
A. With me, never. But with David. David. Thats his girlfriend.
Q. Okay. Now, youve told the jury about your experience in obtaining restraining orders
involving David, right?
A. I dont understand what youre trying to say.
Q. Youve just told the jury about your history of getting restraining orders against David,
right?
A. Not history, not experience, but what happened after he committed these crimes.

Q. You never went to any court at any time and tried to get a restraining order against Mr.
Jackson or anyone you thought was associated with him, right?
A. I was hoping it will just go all away. And Mr. Dickerman handled everything.
Q. You thought you were being falsely imprisoned, right?
A. Correct.
Q. You thought -A. I didnt think it. I knew it.
Q. You thought you were being extorted, true?
A. What do you mean?
Q. Did you think you were the victim of extortion by Mr. Jackson or any people associated
with him?
A. Please be more clear.
Q. Do you know what extortion means?
A. No, I dont.
Q. Okay. Did you think you were being restrained against your will by either Mr. Jackson
or anyone you thought was associated with him?
A. Yes.
Q. Did you think you were being -A. I didnt think it. I knew it.
Q. Did you think you were being kidnapped by Mr. Jackson or anyone associated with
him? MR. ZONEN: Calls for a legal conclusion. Objection. THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you think you were being held against your will by Mr.
Jackson or anyone associated with him?
A. Did I think it?
Q. Yes.
A. I knew it.
Q. And did you think you were the victim of either force or fear created by anyone
associated with Mr. Jackson?
A. I knew it.
Q. Yet, you never went into court to get any restraining order at any time regarding Mr.
Jackson, true?
A. I was too scared of him.
Q. Okay. And at the time you claim you were being held against your will, you had a
number of lawyers who had represented you at that point, true?
A. I dont understand what youre saying.
Q. Well, you had a lawyer who, you just told the jury, had represented you in your
domestic dispute with David, correct?
A. Correct.
Q. At some point you visited Mr. Dickerman with Jamie Masada, correct?
A. Uh-huh.
Q. You had a number of meetings with Mr. Dickerman and Jamie Masada, correct?
A. Correct.
Q. At some point, Mr. Dickerman referred you to an attorney named Larry Feldman,
correct?
A. This is after the fact.
Q. Is that true?
A. Correct.
Q. Never h ave you ever sought a restraining order against Mr. Jackson or anyone

associated with him, right?

A. Thats correct. (Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played for the
Court and jury.)
Q. BY MR. MESEREAU: Okay. Frank Cascio says to you, Do you know everything that
David is saying is completely false. Do you see this?
A. Yes, I do.
Q. And you say, Oh, I know, I know. Thats why Im getting -- excuse me, Thats why
Im -- Im getting all those information. Oh, for example, ah, there was like year and a
half ago, a year and a half ago, they did an investigation of me and David.W e understand
that -- that Michael Jackson, and Chris Tucker are involved with you and the kids, and
they said -- and the kids spoke up and they said, Theyre family to us. If we didnt have
Michael, if we didnt have Michael, we wouldnt have a father, a father figure in our life.
And then the social worker, (inaudible), it says, (possible keys typing), okay, Ill give the
person here a call named David Arvizo. And she documented it and everything and so Im
returning the note paper so you can have all these papers.Do you see that quote?
A. Yes.
Q. All right. Youre referring to an investigation of you and David, correct?
A. Yes.
Q. What investigation are you talking about?
A. Okay. Remember how I told you about the Child Protective Services, that there was
different people, not this group, the one that was in a different building, which was a
female. This is how -- my childrens state of mind at that point,because Michael had been
kind to them in the initial meeting when we first met in August. That stood with them.
Yeah.
Q. Well, okay. So you met Michael Jackson in August of what year?
A. Of 2000. And also Evvy, his personal assistant, made sure that we -- that the children
felt and saw everything as a family environment and to see him as a father figure. This is
Evvy Tavasci, his personal assistant.
Q. When you were involved in the investigation you just described -A. Yes.
Q. -- how many times had you seen Michael Jackson?
A. Me personally by this time, once.
Q. You had seen Michael Jackson one time, and when youre being investigated by the
Department of Children & Family Services, you tell them that Michael is like a father to
your kids and your family, true?
A. No. Inaccurate. It says, And the kids spoke up and they said Theyre family to us.
The children continue speaking and say, If we didnt have Michael -- if we d idnt have
Michael, we wouldnt have a father. My kids said that.
Q. A father figure in our life, correct?
A. Yes, thats the children.
Q. Were you there when the kids said that to the representatives of the Department of
Children & Family Services who were investigating you?
A. Thats correct.
Q. One meeting with Michael and -A. Not me.
Q. -- and youre calling him family and a father figure, right?
A. Yes, per Evvy Tavascis, his personal assistant, request. And also Michael had also
pointed that out to the children in August of 2000.

Q. Im asking about you.

A. Okay, me?
Q. Youre being investigated by DCFS, true?
A. Yes. Me and David. Because when David was arrested for domestic violence -remember how I told you that this particular social worker, I was very impressed, because
she didnt care about me All she was interested was in my children. And thats what I
thought and was hoping that these three, who were only solely concerned about being
sued by Michael Jackson, would have had that same position. Then all this wouldnt have
happened.
Q. Miss Arvizo, were talking about a DCFS investigation, by your own words, that was a
year and a half before youre quoted in the conversation, correct?
A. This is correct.
Q. That has nothing to do with what you just told the jury.
A. This has everything to do with it. This is -- this, 2003. The DCFS was about -- about
2001. So Im giving a best estimate on this conversation.
Q. Youve met Michael one time and youre using him to defend yourself in the
investigat ion?
A. No. Incorrect. Inaccurate. We had -- in my apartment, we had a series of different
pictures. And the social worker h ad pointed out, because the pictures that they had taken
out of my apartment when they did that little move, they were there displayed amongst
many celebrit ies, many people. People that even donated blood were up there.
Q. Now, you told the jury when the prosecutor for the government was asking you
questions that youd always had good relationships with the Department of Children &
Family Services, correct?
A. Whos the government?
Q. These guys.
A. Okay.
Q. Okay? Do you remember telling the jury that you had always had good relations with
the Department of Children & Family Services?
A. Thats correct. Prior to this CPS meeting which they were not concerned with my
children, they were just concerned about being sued by Michael Jackson, it was a positive
experience. Like I said, they cared solely about my kids.
Q. And was it a positive experience with the Department of Children & Family Services
when you were investigated a year and a half before this conversation with Frank Cascio?
A. Thats what Im talking about. In the year 2000, when David was arrested, they
initiated a Child Family Services -- I dont know, one of those -- its the same people, I
feel, had came out to make sure that I was a good mom and make sure that the children
were in a safe environment.
Q. And you used the name Michael Jackson and the name Chris Tucker in that
investigat ion?
A. Thats incorrect.
Q. So, are you not telling the truth when you say that to Frank?
A. No, no, you said if I used them. Thats inaccurate. Like I said, there was pictures on my
walls of different people that had been kind to my children. Amongst them was Michael,
Chris, celebrit ies, other people, and people that had donated blood. And it was her
question that she asked that sparked my children to answer that. At that moment was a
time that -- that was their mindset.
Q. You were investigated by the Department of Children & Family Services in the 1990s

when Gavin alleged you had abused him. Remember that?

A. Yes, I do.
Q. Okay. Did you have a good relationship with the Department of Children & Family
Services at that time?
A. Yes, I did.
Q. Okay. He accused you of abusing him and then he changed his mind, right?
A. No, thats inaccurate.
Q. Why dont you tell the jury what happened in the investigation in the 1990s.
A. I feel -- if Im correct, I feel that what hes talking about, it was a time when Gavin was
I think in kindergarten. I think it was kindergarten. Im not sure. And the nurse, or
something like that, had said to Gavin -- and this is the best I can recall it, had said -about Gavin going home. And then Gavin says, No, I dont want to go home, because he
didnt want to go home from school. And so he had told them that -- that if he went
home, he would get in trouble or something like that. I dont remember very clear. And so
the Department of Child Family Services came out, verified that my son was in a safe
environment, and that was it. It was another positive experience.
Q. He had accused you of abusing him and then changed his story, didnt he?
A. No, its inaccurate what youre saying.
Q. You just said that to the jury, that he accused you of abuse, right?
A. And its okay. He was a kindergartner. He was a kindergartner. And the way -- the
nurse or teacher, whoever it was - this is the best I can recall - had communicated it that
way to the Department of Child Family Services. And that was it. This -- its okay.MR.
MESEREAU: Okay. Lets keep going.Thanks. (Whereupon, a portion of a CD, Plaintiffs
Exhibit 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Okay. Frank says to you, Janet, can you do me a favor? You see
whats going with everything, and it seems like youre, like, hiding from everybody, right?
And you go, Yes. See that?
A. Yes, I do.
Q. Who were you hiding from?
A. Well, from the people that they said that were out to kill my children.
Q. You were also hiding from the med ia, werent you?
A. No, the media -- I was -- I was a little b it unclear, because Michael had said that
theyre all bad people.
Q. You had said they were bad people.
A. Well, because Michael in the initial meeting in Miami had said that, and so did the
Germans.
Q. I see. Okay.
A. So I believed them. I -- you know, Im incompetent. I dont know -- I dont have
experience with this, so I believed him.
Q. Im sorry. Do you remember making repeated statements that the media were
harassing your family, your parents, your children, and you?
A. I dont see anywhere I say here harassing.
Q. Did you ever say that to anyone at any time, Ms. Arvizo?
A. In this conversation I dont think I said,and prior to this I never did. This is per these
conversations, and this is multip le conversations.
Q. I understand your position. Im asking you a general question. Did you at any time,
while these events were occurring, ever say to anybody, The media is harassing my
family, my children, my parents, and me? Yes or no.

A. Well, like you said, its general, so Im going to generally answer. Prior to these
conversations, which are mult iple conversations, no.
Q. I understand your position.
A. Its no.
Q. So you never said -- you never complained to anyone about the media harassing you
at any time, other than in this conversation.
A. You know -Q. Is that true?
A. No. Thats correct.
Q. Okay. This was the first and only time you ever comp lained about the media harassing
you and your family?
A. And that was because, in the init ial meeting
in Miami, Michael had pointed out that the media were bad people, which I come to find
out different now, and that the Germans had said theyre bad people. I believed them.
When I got to my moms and I saw all those offers and the constant phone calls, then it
just confirmed in my mind to what they had told me. And thats it. Theyre just doing their
job. And thats okay.
Q. Then why did you tell Frank they were harassing you at your home?
A. I didnt say they were harassing me.
Q. Never said anything like that in this conversation, true?
A. No, I didnt say harassing.
Q. Okay. All right. (Whereupon, a portion of a CD, Defendants Exhibit No. 809, was
played for the Court and jury.)
Q. BY MR. MESEREAU: Now, you tell Frank about the offers you received, right?
A. Uh-huh.
Q. And you, in effect, tell him youre not going to accept any of them, right?
A. Correct.
Q. And then you say -A. Because thats not in my nature.
Q. I understand that. Well get to the J.C. Penney case and a few other things. MR.
ZONEN: Objection; move to strike. THE COURT: Stricken. MR. ZONEN: Its a gratuitous
comment.MR. MESEREAU: Withdrawn.
Q. You say here, I know were family, Frank.Me, you, me, my kids are family. You, Marie
Nicole, my kids, Baby Rubba are family. Michael, Marie Nicole (inaudible), (Frank coughs).
You, me, are family and my parents. Thats all I got. So thats why when these German
people..., and then its inaudible. Do you see that?
A. Thats correct.
Q. Now, this conversation is taking place after you say you escaped from Neverland with
Jesus, true?
A. Correct.
Q. Youre still calling Michael your family, correct?
A. Thats correct, yes.
Q. You didnt escape from Neverland at all, did you?
A. Oh, yes, I did.
Q. And how many times did you go back after your first escape?
A. Be more specific, please.
Q. How many times did you return to Neverland after your first escape?
A. After I was convinced by Frank, believing that they were good people, I went back

probably -- well, theyve broken it down for you guys in a period of two days. So, let me
see. I went back with -- with Chris immediately. Came back that same day. And then
when Vinnie took me back, and thats it. I think. Im trying to be summarizing those two
days worth of information.
Q. Well, its a total of approximately three escapes, isnt it?
A. Are you including the one where I permanently left and never went back?
Q. Yes, and maybe its four escapes. How many times do you escape from Neverland?
A. Im asking you. Im asking you. Please.
Q. Im asking you how many times, in your mind, you escaped from that dungeon
Neverland? MR. ZONEN: Im going to object as argumentative. THE COURT: Sustained.
Q. BY MR. MESEREAU: How many times did you escape from Neverland, Miss Arvizo?
MR. ZONEN: Objection; asked and answered. THE COURT: Overruled. You may answer.
THE WITNESS: Thank you. With Jesus. With Chris. And then the last time. And thats the
best I can remember.
Q. BY MR. MESEREAU: And during the period of these escapes, youre constantly
referring to Michael as family to you, right?
A. Prior? MR. ZONEN: Objection; vague as to during the period of.MR. MESEREAU: Ill
rephrase it, Your Honor.THE COURT: All right. MR. MESEREAU: Ill withdraw it.
Q. Between the first and the last escape from Neverland, you were still referring to
Michael as your family, right?
A. Prior to Jesus taking me, my kids and me, back to El Monte to my parents house, I
thought he was still a good guy. I was confused and I was sad at that moment because I
did not know the events or whats happened. Now I know a lot. But in that period I only
thought it was the Germans. Thats it. Now, after, when Chris brought me back, I knew
now things are problematic, things that are arising, so Im still clueless. But as time
evolves, Im finding out more and more things. Now today, I know different.
Q. Ms. Arvizo, getting back to the leg wax that you had on February 11th, 2003, the day
of your escape, you had a full leg treatment, a brow treatment, a lip treatment, a face
treatment and a bikini wax; is that correct?
A. Thats incorrect.
Q. Would it refresh your recollection to look at the receipt?
A. It wouldnt refresh my recollection because I know my recollection. Its solely a leg
wax. If theyve manipulated it, thats what they have done.
Q. The total cost was $140, correct?
A. Like I say, it was only a leg wax.
Q. Would it refresh your recollection to just look at the copy of the receipt?
A. Im telling you, it was only a leg wax. He has the ability to choreograph everything.
Q. How about you, Ms. Arvizo?
A. No.
Q. Okay. You dont want to even look at the receipt?
A. No, because Im telling you, it was only a leg wax.
Q. And who paid for that?
A. I paid for it. The reason is, they deducted it from the items they lost or stolen that
were
taken from me from the Miami trip.
Q. Who paid for your treatment at the salon?
A. I did, because that was their effort in replacing the items that were lost and stolen from
the bags that I had in Miami.

Q. Did you pay the person at the salon your own money?
A. Like I said, the condition here was that they were deducting it from the items that they
had lost or stolen from me.
Q. Did you pay the person at the salon any money?
A. I just answered that.
Q. Did you take money of your own and give it to anyone at the salon on that day, Miss
Arvizo?
A. No.
Q. Who did?
A. I dont know. I dont know. That was taken care of by the Germans in the process of
doing their positive PR, which there was a film crew. It would be good to show that.
Q. Well talk about that. Okay.(Whereupon, a portion of a DVD, Plaint iffs Exhibit 809, was
played for the Court and jury.)
Q. BY MR. MESEREAU: Now, Frank asks you to be interviewed for a documentary about
Michael Jackson, correct?
A. Correct.
Q. This is after your escape with Jesus, correct?
A. Yes, it is.
Q. And he tells you hed like to do a documentary and would like you to say nice things actually, he used the word beautiful - about Michael, right?
A. This is correct.
Q. And you say, Oh, I would. Thats all I have to say. Frank says, You -- and then you
say, Me and the kids, thats all we have to say.Correct?
A. This is correct. In this period, I only thought it was the Germans that were problems.
Q. Are you still telling the jury that everything you said nice about Michael on the rebuttal
tape was from a script?
A. Yes.
Q. And if it hadnt been for that script, you wouldnt have said beautiful things about
Michael, right?
A. Could you say that again?
Q. Are you telling the jury that when you did the rebuttal video, you and the kids, and you
said nice things about Michael Jackson, you were doing it all from a script? Yes or no, Miss
Arvizo.
A. Well, you lost me now.
Q. I will rephrase it.
A. Okay.
Q. In this conversation that you didnt know was recorded -A. Correct.
Q. -- Franks asking you -A. That was illegally recorded.
Q. Thank you. In this conversation where you are recorded -A. Illegally.
Q. I understand your position.
A. Okay.
Q. -- you tell Frank that all you and your family had to say in a documentary are beautiful
things about Michael Jackson, true?
A. Yes. That is correct.
Q. Yet, youve also told the jury that when you did the documentary, all the good things

you said about Mr. Jackson were scripted, correct?

A. In the document -- in the thing, the rebuttal that they did, the whole entire thing --I
know I have a problem speaking. Im trying to do my best. The whole thing, from the
beginning to the end, including outtakes, it was all scripted material. All of it. You didnt
have to do that at this point. I would have done it on my own. But -- prior to that,
because I thought it was only the Germans. But from the period that they did this, now
this is scripted, now things have elevated. But in this, at this moment in time, yes, I would
have. But now? Have another rebuttal, and Ill speak freely. Have another audiotape with
Brad Miller. Ill speak freely now.
Q. I understand. But at this point in time after your first escape, you had nothing but nice
things to say about Michael Jackson?
A. That is correct. I only thought it was the Germans.
Q. And you were ready to do a documentary about Michael Jackson where all you had
were beautiful things to say, correct?
A. And only if the things wouldnt have been dictated of exactly what to say. Only if.
Thats the only problem I had; that they want -- they wanted me to say things that were
scripted, exactly what they wanted to say. Because I -- I felt whats wrong with telling the
truth? And at that moment, that was the truth.
Q. And everything you said -A. And now I know different. It was happening right underneath my nose.
Q. Miss Arvizo, everything you said on that rebuttal tape was scripted; is that what youre
saying?
A. Every single thing.
Q. We will get to the rebuttal.
A. Even the outtakes. MR. SANGER: Ready? MR. MESEREAU: Yeah. (Whereupon, a portion
of a CD, Plaintiffs Exhibit 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, you complained to Frank that the Germans are trying to
dictate to you what to say, right?
A. I didnt complain. I expressed myself.
Q. Is that what you expressed to him?
A. Yes. Because they were trying to dictate to me exactly what to say. For example, also
the charitab le act. They wanted me to say that me, Michael, my children had went to
Germany and gave to German orphans. Thats what they said. Im not going to do that.
Whats wrong with the truth at that point? I thought he was a good guy. Now I know
different.
Q. Miss Arvizo, at any time in that rebuttal tape, did you talk about going to Germany and
dealing with orphans, per the script?
A. No. Obviously they eliminated that.
Q. Okay.
A. Or maybe I forgot. I dont know.
Q. I understand.
A. I was -- like I told you, I got in trouble for not doing exactly what they said, so thats
why the process of leaving out of the country had to happen.
Q. Right. I understand.
A. Youre correct, I did an inadequate job. Im a poor actress. Youre right.
Q. I think youre a good one.MR. ZONEN: Im going to move to object Ask the Court to
admonish counsel. THE COURT: Ill ad monish counsel not to make those remarks. MR.
MESEREAU: I will --THE COURT: Admonish the jury to disregard such a remark. I expect

more professional behavior from you. MR. MESEREAU: I apologize, Your Honor. I withdraw
it. THE COURT: (To the witness) And you must only answer his questions. Youre not to
get into arguments with him. Its as much your fault. Do you understand that? THE
WITNESS: Yes, sir.
Q. BY MR. MESEREAU: You said that to Frank, that what you say in the documentary has
to come from the heart, right?
A. Yes. I said -- yes, I did. I said, Think with your heart, not your head. Because our
heart has a lot of pure things in there.
Q. And when you said the things you said about Michael Jackson on that rebuttal video,
you were, in fact, speaking from the heart, right?
A. It was all scripted. MR. MESEREAU: Okay. Lets keep going. (Whereupon, a portion of a
CD, Plaintiffs Exhibit 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, you said you didnt like someone named Mark Ratner,
right?
A. Uh-huh.
Q. Mark Ratner was a director on the Rush Hour movie, true?
A. Incorrect.
Q. Who was Mark Ratner?
A. I came to find out afterwards that it was Marc Schaffel.
Q. Well, you talked about Mark Ratner.
A. There is no Mark Ratner. Theres only Brett Ratner.
Q. And -A. And I hadnt -Q. And who is Brett Ratner?
A. And I havent spoke to Brett Ratner since my children were with Chris, since 2001. I
think --wait, 2000 -- I think it was January of 2001.
Q. Brett Ratner was the director on the Rush Hour movie, right?
A. Yes.
Q. And where did you first meet him?
A. I met him for about -- Chris had taken the children to -- thats when he was doing the
filming for Rush Hour 2. It was on the set.
Q. Did you ever see him at Neverland?
A. I never saw him at Neverland.
Q. Did you ever learn that Gavin had seen him at Neverland?
A. Yes, I came to find out that afterwards.
Q. And did you learn that Gavin had asked him to take Gavin to Florida to see Michael?
Did you ever learn that?
A. You are -- you are -- I have a lot of thoughts in my heart about you. But hes incorrect.
Q. Did you ever learn such a thing? Yes or no.
A. What I learned afterwards is that Brett Ratner, while I was over here in Los Angeles,
and Dieter had cornered my son, including with Michael, to have him sign a p iece of
paper. Thats what I learned while I was over here in Los Angeles.
Q. Did you ever learn that Gavin wanted to go to Florida to see Michael, and Brett Ratner
wouldnt permit it?
A. Thats incorrect.
Q. Okay.
A. Because Brett Ratner, Dieter and Michael were all there in Michaels house.
Q. Were you there?

A. My children were there.

Q. Were you there?
A. I wasnt there.
Q. Now, you talk about the Germans keep trying to push Michael Jackson to drink. Do you
see that?
A. Yes. How foolish I was. I thought he didnt drink. And they choreographed the little
scene in front of me where they were pretending like he doesnt drink, and he doesnt
even drink Pepsi, and I fell for that. I did. Now I know a lot of things.
Q. You complained that the Germans are trying to get Michael Jackson to drink alcohol,
right?
A. Yes. Like I said, I fell for it, their little choreography. I thought he didnt drink. They
pointed out he didnt drink an ounce of alcohol, not even Pepsi, and I fell for it. Yes, I did.
Q. When you fell for this, how many times had you stayed at Neverland?
A. This is the period before I left with Jesus. This is this period.
Q. When you fell for this, how many times had you stayed at Neverland?
A. This is the period before I left with Jesus.
Q. Okay. And did you watch the people you refer to as the Germans trying to get Michael
to drink?
A. Yes. Michael was part of this choreography. Michael had pointed out that he doesnt
drink, and the Germans said he doesnt drink and that he doesnt even drink Pepsi. He
was going, No, no.And now I know different. Now I know that Neverlands all about
booze, pornography and sex with boys. MR. MESEREAU: Move to strike her comments as
self-serving. THE COURT: Theyre stricken. The jury is admonished to disregard those
remarks. (Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played for the Court
and jury.)
Q. BY MR. MESEREAU: Now, Frank says there are evil people out there, and you agree
with him,correct?
A. Yes, I believed him.
Q. Okay. And he talks about making some arrangements because youre not safe, right?
A. Thats correct.
Q. And you thank him, correct?
A. Let me see. Im just being appropriate.
Q. Youre just being -A. I have manners.
Q. Youre just being well-mannered?
A. Im just having manners, because as you can recall, I had left -- I believed what he had
said. MR. MESEREAU: Your Honor, can I move to strike her comments? THE W ITNESS: So
I went to Jay Jacksons house instead of going back. THE COURT: Just a moment. All
right. Ill strike after she said, Im just having manners.
Q. BY MR. MESEREAU: When you agreed with Frank that he should make arrangements
because you werent safe, you were just being well-mannered, correct?
A. At this point, Im being only well-mann ered, and I d idnt agree. I was -- he was
convincing me.
Q. I see. Okay. All right. (Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played
for the Court and jury.)
Q. BY MR. MESEREAU: Now, you get back on the line with Frank and he says, How can
I get in touch with you, because I know sometimes your lines are always busy.And you
say, Yeah, its like people are calling like crazy, you know? Who are you referring to?

A. This is correct. A lot of people were calling. They were interested in my son Gavin.
Q. And you were complaining to Frank about that, correct?
A. No, Im not complaining. This is in the midst of a conversation. I didnt call him. He
called me. Many times.
Q. Did you ever complain to Frank that people were calling you like crazy?
A. I stated to him -- the word here is, Yeah, its like people are like calling crazy, you
know. MR. MESEREAU: Lets keep going. (Whereupon, a portion of a CD, Plaintiffs Exhibit
809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, Frank says to you, Im going need to get through to you
and talk to you, because I want to get you out of there. Its -- I dont think -- I dont want
you -- I dont think its safe. And Miss Arvizo, you respond, Its not. Its like its crazy.
Can I read you one of the letters? Its like there are all kinds of things, and its of no
interest to me, because family never leaves family behind. Do you see where you said
that?
A. Yes, I do.
Q. You dont refer to any death threats at all, do you?
A. No, I dont.
Q. You say its not safe, and you talk about all the letters youre getting. No reference to
one single death threat -A. Thats because -Q. -- is that correct, Miss Arvizo? Just please answer my question, if you can.
A. Yes, thats correct.
Q. Okay.
A. You dont have to raise your voice. Im here listening.
Q. Im sorry. Im sorry. And then you say, Family never leaves family behind, you know,
right?
A. Thats correct.
Q. You still consider Michael to be your family, right?
A. Thats because of the initial meeting where he said -Q. Yes or no?
A. -- Family never leaves family behind.
Q. You still considered Michael -A. At this point?
Q. -- to be part of your family?
A. He called himself family, and it -- basically, like I said, people 50 or over have a tender
spot in my heart. Sometimes --MR. MESEREAU: May I object to the colloquy? Move to
strike THE COURT: Sustained. Do you want to read the question back? Read the question
to her. (Record read.) THE WITNESS: I considered him to be like family. MR. MESEREAU:
Okay. (Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played for the Court and
jury.)
Q. BY MR. MESEREAU: Frank says to you, Ms. Arvizo, For your safety, and if we were to
put a secur -- maybe have somebody 24 hours outside your house, protecting your house
from people, would you mind if we do that? And your answer is, No. R ight?
A. My answer is, No, I dont want that. MR. MESEREAU: Keep going. (Whereupon, a
portion of a CD, Plaintiffs Exhibit 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, Ms. Arvizo, after Frank says, Maybe have somebody 24
hours outside your house, protecting your house from people, would you mind if you do
that? And you say, No, you then talk about how your childrens school is bombarded;

correct?
A. Yes, this is because Michael and the Germans had told me that.
Q. Well, you didnt say that now, did you?
A. I did say that.
Q. Youre in Los Angeles when you make this comment, arent you?
A. No, its correct. Im telling you -- you want to know the information. You werent there;
I was. Michael and the Germans had told me that. MR. MESEREAU: May I ask -- would the
Court instruct the witness just to respond to my question? THE WITNESS: I am
responding. THE COURT: You must listen to the question and answer the question, and
not try to advance beyond the question.THE WITNESS: Okay.
Q. BY MR. MESEREAU: You say to Frank, So I have my kids here, and the school is
completely cooperating with giving, like, me to work. He says, Okay. And you say, My
childrens school is like bombarded, correct?
A. This is correct.
Q. Frank goes, I know, right?
A. Thats correct.
Q. Then you say, I didnt go to the other apartment. Its like crazy over there, correct?
A. This is correct. MR. MESEREAU: Lets keep going. (Whereupon, a portion of a CD,
Plaintiffs Exhibit 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: You then tell Frank about the apartment in East Los Angeles,
correct?
A. This is correct.
Q. You tell him its on North Soto Street, right?
A. Thats right.
Q. And after telling him that your childrens school is, like, bombarded, and that the other
apartment, its like crazy over there, you tell him that you didnt go to Soto Street. You
went straight to your moms house, true?
A. This is -- this is correct. I told him I came straight here to my moms house from
Neverland, to my moms house, because I believed what the Germans and Michael had
said.
Q. Okay.
A. And Im repeating what they said -Q. I see.
A. -- to Frank.
Q. Thats your explanation for those comments,correct?
A. This is -- this is accurate information. MR. MESEREAU: Okay. Lets keep going.
(Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, Miss Arvizo, after talking about how your childrens school
is bombarded, and its crazy over at Soto Street, and that youve gone to your moms
house and didnt go to Soto Street, Frank says to you, What if we wereto take you to a
church up there? Because its just really important. Youre going to have to have
somebody stay outside your house and watch you, your house, protect and make sure
nobody comes to your house. Oh, I want to take you up to the ranch just for your safety
and your family. And your response to that statement is, Do you have a cell nu mber,
Frank? And he says, Yes. At no time do you say you dont want any of that protection,
do you?
A. At no time does it say a Yes.
Q. Your response to his statement about giving you protection is, Can I have your cell

number? Right?
A. I just said, Do you have -- and prior to that, you said something about church. I have
never missed Ash Wednesday. Never. MR. MESEREAU: Objection; move to strike. THE
WITNESS: And when I was in Neverland, they didnt take me to church. I missed Ash
Wednesday. THE COURT: Just a moment. I will strike that, those remarks. But, Counsel,
your question was so long and lengthy, on wonders what one should comment on in it.
MR. MESEREAU: Okay. THE COURT: And Ill ask you to refrain from that type of question.
Its causing problems here. MR. MESEREAU: Yes. Ill rephrase it, Your Honor.
Q. Miss Arvizo, referring you to Frank Cascios statement, it begins with What if we
were..., do you see that?
A. Okay.
Q. He says to you, What if we were to take you to a church up there, right?
A. Thats correct.
Q. Because its just really important, right?
A. Uh-huh.
Q. And it says -- it says, Inaudible, right?
A. Yes.
Q. And then he says, Youre going to have to take somebody -- excuse me. Youre
going to have to have somebody stay outside your house and watch you, right?
A. Correct.
Q. He says, Your house, right?
A. Uh-huh.
Q. Then he says, Protect and make sure nobody comes to your house, right?
A. Correct.
Q. Oh, I want to take you up to the ranch just for your safety and your family. Do you
see that?
A. Correct.
Q. And your response to that is, Do you have a cell number, Frank? R ight?
A. Thats it.
Q. And he says, Yes.
A. And its not -Q. Right?
A. And its not a yes from me.
Q. And its not a no either, is it? MR. ZONEN: Its argumentative; objection. THE
WITNESS: Hes convincing me.THE COURT: Excuse me, Counsel? MR. MESEREAU:
Objection; argumentative. THE COURT: Sustained. MR. MESEREAU: Lets keep going.
(Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played for the Court and jury.)
Q. BY MR. MESEREAU: Going further into this taped phone conversation -A. And notifying that theres also numerous tape breaks.
Q. I understand. You say to Frank, Is there a way I can get back to you, Frank? Do you
see that?
A. Yes, I see that. Im being polite.
Q. I understand. And Frank -A. Because I not once - and when you see those subpoenaed phone records - called him
back during this period.
Q. And you say, Call you -- Your Honor, may I move to strike the witnesss comments?
THE COURT: Im not going to strike it. The last question listed is you just saying, I
understand, and then she starts talking. So there was no question and --MR. MESEREAU:

Okay.
Q. Miss Arvizo, you say to Frank, Is there a way I can get back to you, Frank? Correct?
A. Correct.
Q. Frank says, Call you if there is an emergency, right?
A. Correct. And theres also a tape break.
Q. Yes. And then you say, Okay, I have no control (another phone is heard ringing)
Frank. People call and call. So when they call, it sounds busy to whoever else. Do you
see that?
A. This is correct.
Q. Frank says, Okay. And then you say, This is my mo ms number.
A. Yes, I was at my mothers house.
Q. You gave Frank your moms phone number, true?
A. I gave Frank my moms phone number? No.
Q. All right.
A. He himself had it.
Q. Okay. (Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played for the Court
and jury.)
Q. BY MR. MESEREAU: You said to Frank, Dont worry, Frank, were a family, okay? Do
you see that?
A. Oh, I see it right here.
Q. Frank says, Okay. Do you see that?
A. Yes.
Q. You say, Michaels family to me. Then its inaud ible. My kids call him Daddy Michael.
Do you see that?
A. Thats correct. This is correct.
Q. Then he says, But -- but Janet, you understand like how we have to protect you and
Michael, Gavin and your kids. Thats why Im so concerned. Do you see that?
A. Yes.
Q. And then you respond to Frank, Thats why the German people said, You need no
protection.Youre nobody -A. Yes.
Q. -- you know? And you say -- and Frank says, No, thats not true, correct?
A. Correct. Do you want me -Q. Id like to ask you just some questions, if I can, all right?
A. Okay. Sure.
Q. You complain to Frank that the German people said you didnt need protection, because
youre a nobody, right?
A. No. Its -- it says, Thats why the German people say, I need no protection. Youre
nobody, you know?
Q. And then Frank then responds, No, thats not true, correct?
A. Correct. Correct. But do you want information on this statement?
Q. Did the German people tell you you dont need protection, youre a nobody? A. Yes,
they sure did.
Q. Well move further on.
A. When they had me sign the paper -Q. Correct?
A. Oh, then he doesnt want you to know.THE COURT: Just a moment. Just a moment.
Listen to the question and answer it. Youre going beyond the question. Ive asked you not

to do that. THE WITNESS: Okay. This is just so hard, Judge. For two years Ive been
waiting. THE COURT: Ill strike that remark. Go ahead, Counsel. MR. MESEREAU: Lets go.
(Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played for the Court and jury.)
THE COURT: Counsel? Im sorry to break your concentration, but I want to explain
something to the jury. MR. MESEREAU: Sure. THE COURT: If you need to start over on
that, you can. (To the jury) During the course of this trial, quite often I have said, Ill
strike that.The purpose in doing that is twofold: One is to tell you youre not to consider
that, whether its testimony, whether its remarks by an attorney, whether its remarks by
a witness. And it also is reflected in the record. Later, when youre decid ing this case and
youre in the jury room, you may want to have testimony read back. And when testimony
is read back to you, you dont -- thats not there. It is stricken at that time, so the court
reporter reads it to you, she sees that its stricken, she doesnt read all of that to you. So
it may seem strange that I just say Strike that. But what it really means always is, if I
say strike it, dont consider it. Dont discuss it in your deliberat ions. Its sort of like
asking you to unring a bell that youve heard ring, but as intellects, we are -- you know,
we are capable of deciding the case on information thats admissible and not on
informat ion thats not admissible, right? Everybody on the jury understand that? THE
JURY: (In unison) (Nods head up and down.) THE COURT: All right. MR. MESEREAU:
Thank you, Your Honor. THE COURT: Did you want to -- since I interrupted you, did you
want to play that section back, or are you okay? MR. MESEREAU: I think were okay, Your
Honor. Appreciate it. Thank you.
Q. Miss Arvizo, you constantly complain about the German people in this conversation,
right?
A. This is correct.
Q. And going back to the portion that we just played, Frank tells you the following: No,
dont. Listen, ah, you dont have to talk to them. Just talk to me, talk to Michael, and I m
going to arrange everything. But its either were going to have to have somebody at your
house this weekend or were going to have to take you to the ranch. This way Michael -Michael wants to see you. Hes -- he was almost -- he didnt know what happened. He
thought he did something and he was trying to get in touch with you. And I said, Dont
worry, Ill take care of this. So -- And your response to that statement is, Tell him hes
our family, right?
A. That is correct.
Q. You never object to having security at your house, as Frank proposes, right?
A. I didnt -- I never said Yes.
Q. Okay. (Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played for the Court
and jury.)
Q. BY MR. MESEREAU: Going further, you keep complaining about the German people.
A. Uh-huh.
Q. Frank says to you, You dont have to talk to them, right?
A. Correct.
Q. You say, I thought like everything, my family was in jeopardy, correct?
A. This is correct.
Q. Frank responds, No, right?
A. Yes.
Q. And your response to that is, Meaning us being with Michael and Michael being with
us, correct?
A. Yes.

Q. What you said to Frank was you were concerned about your family not being with
Michael and Michael being with your family, true?
A. I said, I thought like everything, my family, was in jeopardy.
Q. And then you say, Meaning us being with Michael and Michael being with us?
A. Yes. I will never say no to love. MR. MESEREAU: Objection. Objection to her -- move to
strike the remarks. THE COURT: Im sorry, I dont understand the question or the answer.
Would you just ask another question? MR. MESEREAU: Ill ask another question, yes, Your
Honor.
Q. Frank says, You dont have to talk to the German people, and you say to him, I
thought like everything, my family, was in jeopardy, right?
A. Yes.
Q. And then you say, Meaning us being with Michael and Michael being with us, correct?
A. This is correct.
Q. After your escape with Jesus, you still want Michael to be with your family, and your
family to be with him, true?
A. Yes. I thought it was all --MR. MESEREAU: Objection, Your Honor. THE WITNESS: I
believed what he said in Miami. THE COURT: Just a moment. All right. Go ahead with your
next question. (Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played for the
Court and jury.)
Q. BY MR. MESEREAU: Going further into this tape, okay?
A. With the numerous tape breaks.
Q. I understand. Now, Frank says, We need to protect you and your family, so Ill call you
in one hour to see if youre okay, right?
A. Okay. Did you go farther up, higher, or -Q. Well, lets see, the pages arent numbered. So it starts at -- the top of the page starts
with, ...to do in a couple of hours.... Do you see that?
A. Okay, this is from this previous page.
Q. Do you see that?
A. And then on top. Okay. Okay.
Q. Yes. The first full quote from Frank Cascio on that page, okay?
A. Okay.
Q. Frank says, Im going to call you just to see how youre doing, because we need to
protect you and your family. So Ill call you in one hour to see if youre okay. And you
say, Okay, right?
A. Uh-huh. This is correct, being polite.
Q. At no time do you disagree with the continually repeated idea that your family needs
some protection, right?
A. And at no time do I request it. (Whereupon, a portion of a CD, Plaintiffs Exhibit 809,
was played for the Court and jury.)
Q. BY MR. MESEREAU: You tell Frank youre at your moms house. He says to you, This
is the number to your moms house, question mark, and you say Yeah, correct?
A. This is correct.
Q. Are you still telling the jury you never wanted Frank to have the number to your moms
house?
A. Hes calling at my moms house. He asked me, Is this your moms house? I never
gave it to him. He already had it.
Q. Okay.
A. Im at my moms house.

Q. And you have no idea how Frank got th number to your moms house, true?
A. Thats correct.
Q. Okay. Now, going back a little bit -A. Oh, yeah, now I know how.
Q. I understand. Going back a little bit, I told them when people neglected us, rejected
us, they dont know..., and then theres a tape break. It says,Um, Baby Rubba. W hat
were you referring to when you said, People neglected us and rejected us?
A. My husband, my ex-husband David Arvizo, with his family.
Q. Were you referring to anyone else?
A. No. Nobody else.
Q. Do you remember in the rebuttal video where you accused the Department of Children
& Family Services of neglecting your family?
A. Maybe it was -- maybe it was put in another context, but thats what I meant. My ex
in-laws.
Q. Theyre the only people youre referring to, right?
A. Thats exactly right.
Q. Okay. Now, in that rebuttal tape, you also talk about your family being spit on and
discriminated against and things like that, correct?
A. Yes. Yes.
Q. And are you only referring to Davids famil when you say that?
A. Part of it is Davids family. And David. Mostly David.
Q. And whos the rest of it?
A. Mostly David, h is family. And just different things like that. Different experiences.
Q. But in that tape you talk about more peopl than David and his family.
A. Are we talking about this tape or -Q. Im asking about the rebuttal tape now okay?
A. Okay.
Q. You talk about -- excuse me, in that tape, you say words to the effect, Weve been
spit on, weve been fried, weve been rejected because of our race, and a whole bunch of
things, right? Youre not referring to Davids family when you say that?
A. Are you missing the point that it was all scripted?
Q. Im asking you a question, Miss Arvizo. Could you please answer it?
A. Okay. Remember in the initial meeting in Miami how I was just telling everything about
-- to the Germans? Well, obviously they were in the works in doing the script since back
then.
Q. So when you say words to that effect in this conversation -A. This conversation.
Q. -- the Brad Miller interview and the rebuttal video, youre only referring to Davids
family?
A. Brad Miller audiotape and this is referring to Davids -- David mostly, with his family.
But in the rebuttal, like I said, it was all scripted. All of it. It was the information that they
had extracted from me and my children. And its pretty obvious that its very ingrained,
the experiences that I have felt and gone through with my ex family, which is Davids
family.
Q. Okay.
A. And they put it in with their little script.
Q. Okay. (Whereupon, a portion of a CD, Plaintiffs Exhibit 809, was played for the Court
and jury to its conclusion.) MR. MESEREAU: Your Honor, I think that completes the

recording of the phone conversation. THE COURT: Okay.

Q. BY MR. MESEREAU: Now, Miss Arvizo, you filed for divorce from David approximately
five days after you settled the J.C. Penney case, correct?A. I filed for divorce after David
was arrested for domestic vio lence. MR. MESEREAU: Your Honor, may I ask the Court to
instruct the witness to answer the question? THE WITNESS: Well, your question was about
-- THE COURT: Just a moment. Would you read the question back to the witness? (Record
read.)

THE WITNESS: I dont know about that. He wanted a history as far as when, and Im
telling you, I filed for divorce the day after -- not the day after, but after David finally was
arrested for domestic violence.
Q. BY MR. MESEREAU: In your case against David for domestic vio lence, you told the
Los Angeles Police Department that he had been abusing you for many years, true?
A. This is correct.
Q. You told the Los Angeles Police Department that he had been abusing you since you
were married, correct?
A. This is correct.
Q. Had David been abusing you from the time you were married?
A. This is correct.
Q. You told the Los Angeles Police Department that for approximately 17 years, he had
been physically and emotionally abusing you, right?
A. This is correct.
Q. You also said he had been abusing your children for the entire marriage, correct?
A. This is correct.
Q. But in the J.C. Penney case, when you wanted money, you said the opposite about
David, didnt you?
A. Thats incorrect. When David was arrested, I went to Rothsteins office, who was in
charge of the civil -- civil proceed ings, of the civil J.C. Penneys lawsuit, and I told him
David has finally been arrested. I want to correct this statement that me and my children
were unable to say because he was still part of our life. And I went to their office, and
they told me that they would take care of it. And thats why when the police asked me to
waive this information of my civil lawsuit, I did happ ily. And yet these Rothstein people did
not do that. I told them to inform J.C. Penneys and Tower Records that that information
was incorrect right after David was arrested. I finally was liberated to say what actually
had been going on for years.
Q. Miss Arvizo -A. So youre inaccurate.
Q. Well, Miss Arvizo, do you remember having your sworn deposition taken in the J.C.
Penney case?
A. Yes.
Q. And that was a case that you had filed claiming you were sexually abused by J.C.
Penney by the security guards in a public parking lot, correct?
A. I gave the civil lawyers the informat ion about what happened, just as I told the police
department, the West Covina Police Department. Now, how they write their statement,
how they do these paperworks, I dont know. But its only one story. And its been
repeated over and over. How they put it in this paperwork, I dont know. I wasnt the
attorney.

Q. Miss Arvizo, you gave a sworn deposition in that case where you were p laced under
oath, correct?
A. This is correct.
Q. And you filed a claim for monetary damages against J.C. Penney, correct?
A. This is correct.
Q. You were claiming that you had suffered physical injury because of what J.C. Penney
security guards did to you, correct?
A. Tower Records.
Q. Correct?
A. This is correct.
Q. And to prove your claim for monetary damages, you had to explain that your physical
injuries were solely the result of what J.C. Penney and Tower Records had done to you,
correct?
A. This is correct. And they had me explain, to the millisecond, of the process while I was
being hurt.
Q. Your deposition was taken on December 18th, the year 2000, correct?
A. Yes, while I was still married and David was with me and my children. Yes, thats
correct.
Q. And what year did you file for divorce from David?
A. Approximately in 2001. When David was arrested.
Q. And on December 18th, the year 2000, you were asked under oath, Has David Arvizo
ever struck you, and you said, No.
A. This is correct.
Q. You were asked under oath, Has David ever struck your children? You said, No. We
goof around a lot, though, play. Correct?
A. Yes. This is correct.
Q. You were not telling the truth under oath when you made those statements, correct?
A. But prior to settlement, I had went to the -- to Rothsteins office and I requested that
they fix that, after David was arrested, because I finally could open my mouth. And this -I want you to have a picture of this. MR. MESEREAU: Move to strike, Your Honor. THE
WITNESS: This is when Gavin is going through chemotherapy. THE COURT: Just a
moment. Just a moment. Ill strike her answer to that.
Q. BY MR. MESEREAU: Further in that deposition --THE COURT: Just a moment. MR.
MESEREAU: Oh, Im sorry. Pardon me. THE COURT: Do you want to go back to the
question you asked? The answer has been stricken.MR. MESEREAU: Yes, if we could have
it read back, Your Honor, Id appreciate it. (Record read.) THE WITNESS: This is correct.
Q. BY MR. MESEREAU: Further, in that deposition, you were asked, Have you had any
marital problems at all other than related to this incident at J.C. Penney? And you said
No.
Right?
A. This is correct. I was -- by the time that David had gotten arrested, I was never going
to tell anything that he had done to me or my kids. Never.
Q. You lied under oath to increase the amount of money you could get from what you
claimed J.C. Penney and Tower had done to you, right? MR. ZONEN: Objection;
argumentative. THE COURT: Sustained.
Q. BY MR. MESEREAU: Now, in that deposition, you were asked when you decided to file
a lawsuit, correct?
A. Correct.

Q. You said you decided to file a lawsuit against J.C. Penney and Tower Records two
weeks or two or three weeks prior to the expiration date. Remember that?
A. I dont understand what your question is.
Q. Well, Im just going to ask you about your answer. And I can show you the page, if you
want to see it.
A. No, I just dont understand your question. I dont know whether youre making a
statement or an actual question.
Q. Then thats my mistake. Ill rephrase it.
A. Okay. Thats okay.
Q. In your deposition under oath, in the J.C. Penney case, you were asked the question,
When did you decide to file a lawsuit? Do you remember that?
A. Yes. Yes.
Q. And your answer was, Two weeks or two or three weeks prior to the expiration date.
A. This is correct. If its on there, it is correct.
Q. Then you were asked, Was that before or after the criminal charges had been
dropped? Remember that?
A. Yes.
Q. And you said, Way after, correct?
A. Yes.
Q. When you used the words expiration date,you were referring to the deadline that you
had to file charges -- excuse me, file a lawsuit before, correct?
A. Thats what I was explained.
Q. You would lose your right to file a civil suit if you didnt file it by a certain date,
correct?
A. Thats what I was explained by the civil attorneys.
Q. And -A. If theres anything that sounds worth -- worth of any intellig ence there, thats what I
was informed. No credit to me. Only to the civil attorneys.
Q. Well, you knew enough to say under oath that you filed your civil case before the
deadline, right?
A. Because of attorneys had made me aware of that.
Q. Are you aware of the deadlines that you or your children have to file claims against Mr.
Jackson?
A. We will never file a claim against Mr. Jackson. I want justice here.
Q. Are you aware, Ms. Arvizo, of the deadlines you have to file a civil claim against Mr.
Jackson? Yes or no.
A. I think so. Im not interested, so I dont ask.
Q. I understand. And in this case you werent interested until after the criminal
investigat ion was over, correct?
A. I wanted an apology. MR. ZONEN: Which case is counsel referring to? Vague. MR.
MESEREAU: I will rephrase it. The prosecutor is correct.
Q. In the J.C. Penney case, you waited till after a criminal investigation was over to file
your civil claims, true?
A. I wanted an apology.
Q. You wanted over $100,000, didnt you?
A. I didnt get over $100,000.
Q. You got 152,000 in the settlement, Miss Arvizo, didnt you?
A. In -- in my hand, I d id not get $150,000. MR. MESEREAU: May I ask the witness be

instructed --MR. ZONEN: I think she just answered. THE WITNESS: I answered. THE
COURT: It was -- your question, your last question, was basically whether she got a
certain amount, and shes trying to answer that.
Q. BY MR. MESEREAU: The settlement to you and -- THE COURT: Just a minute. Let her
finish the answer. THE W ITNESS: In my hand, I received only $32,000. Thats it. In my
hand. And thats my best approximation.
Q. BY MR. MESEREAU: Miss Arvizo, what did Gavin get in his hand from that
settlement?
A. I dont remember, because its been put away where its to be untouched by me.
Q. What did Star get in his hand in that settlement?
A. Still nothing. I dont know, because its -- its something thats untouched by me. Its
for them.
Q. What did David get in h is hand from that settlement?
A. Thats -- youre going to have to ask David, and yet he was not injured whatsoever.
Q. The total was over $152,000 that your family was given in the settlement, true?
A. That you have to ask my civil attorneys. And I think his statement may be correct.
Q. Okay. You claimed in that case that you had bruises from what the security guards did
to you, right?
A. It is correct.
Q. After you had resolved that case and obtained money, you claimed that you were
bruised by David, true?
A. I had always been bruised by David for years. But I never told anyone until after David
was arrested. That was the pivotal point in my life. Not until David was arrested did I say
anything about bruises in my whole ent ire life, and that was only with people of authority.
Thats it.
Q. When you were seeking money from J.C. Penney and Tower Records, you testified
under oath on December 18th, the year 2000, that you never had any black and blue
marks prior to the incident at J.C. Penney, correct?
A. Yes, this is correct. I was too embarrassed to ever tell anyone.
Q. You made that statement because you wanted any injury you ever had to be attributed
to J.C.Penney and Tower Records, right?
A. Incorrect. What J.C. Penneys and Tower Records did to me was one day, one situation,
one incident. Thats it.
Q. If you had testified truthfully under oath and said that your bruises were from David,
the amount of monetary damages you could get from J.C. Penney would have been
lowered, true?
A. This is incorrect. I would have never told anyone until David got arrested that I -- that
David was giving me these bruises. Never. People would see me with bruises and I would
never, never, never tell them.
Q. Did you lie under oath in your deposition in the J.C. Penney case?
A. I tried to remedy that when I had gone to my -- after David was arrested, I went to
Rothsteins office. And I requested that they inform Tower Records and J.C. Penneys that
I would like to make that correct statement because the statements that were there were
incorrect. But finally me and my kids could finally say what was really happening for
many, many years.
Q. Mrs. Arvizo, the problem you had was that when you made alleg ations later on against
David that he had abused you for 17 years, there was deposition that had previously been
taken where you said the opposite under oath, right?

A. Youre -- its too long. Theres a yes and no and yes and no, and now I dont know. THE
COURT: Lets take a break.(Recess taken.) THE COURT: Mr. Mesereau? MR. MESEREAU:
Yes, thank you, Your Honor.
Q. Miss Arvizo --THE BAILIFF: You need to turn your microphone on, please. MR.
MESEREAU: Oh, thank you. THE COURT: You missed a good show of hands there. Give it
to him again, would you? Look, look, look. (Laughter.)
Q. BY MR. MESEREAU: Miss Arvizo, did you tell the jury that David was not honest in the
J.C. Penney case?
A. Me?
Q. Yes.
A. Okay. Ask the question again.
Q. Ill rephrase it. Did you tell the jury words to the effect that your ex-husband David did
not tell the truth in the J.C. Penney case?
A. Are we talking about the grand jury or the civil lawsuit?
Q. The civil lawsuit.
A. Did I tell a jury?
Q. Did you tell this jury today that David did not tell the truth in the J.C. Penney civil
suit?
A. We werent talking about David. I was telling you what I -- David had done to me and
the children.
Q. David sued J.C. Penney with you, correct?
A. This is correct.
Q. David claimed he was injured in that parking lot with you and your children, correct?
A. To my -- what I was aware of is that he wasnt injured. And thats it.
Q. But he was suing, with you, for monetary damages for being injured, right?
A. I came afterwards. David -- when I walked up to the situation, he was being hit by
these
people. So I dont know what happened prior to me arriving there. So Im unaware.
Q. During the time you had your deposition taken in the J.C. Penney lawsuit -A. Yes.
Q. -- did you consider David to be an honest person?
A. No.
Q. Do you remember testifying under oath in the J.C. Penney lawsuit that, David is
extremely honest. Hes too honest?
A. If thats on there, then thats correct. Whatevers on the deposition is correct.
Q. Do you remember saying that under oath?
A. If its on there, then it is.
Q. Would it refresh if I just show it to you?
A. Im just asking, if it is on there, its correct.
Q. Okay. I have to get a response from you as to whether you said that or not, okay?
A. If its on there, its correct. And it would be a yes, if its on there.
Q. Would it refresh your recollection just to show it to you first? Would that help?
A. Its a yes.
Q. Your answer is yes?
A. Yes.
Q. You did say under oath that, David is extremely honest. Hes too honest?
A. Yes.
Q. And you werent telling the truth when you made that statement under oath, correct?

A. Anything to do with David, no. Thats why I went to the civil attorneys, to try to correct
that after he was arrested.
Q. Let me get this straight, now. You went to the civil attorneys to try and change your
testimony after you collected a settlement?
A. Incorrect. The settlement still had not been corrected, accepted or settled. Anything
like
that. It was still prior.
Q. Now, you claimed you were assaulted in a public parking lot by J.C. Penney security
guards, correct?
A. Plus Tower Records.
Q. And Tower Records, right?
A. Thats right.
Q. You said you thought you were going to die, correct?
A. Yes.
Q. Did you think you were going to die in a public parking lot when you were assaulted by
these security guards?
A. Yes, I did, because it came to a point where I couldnt breathe.
Q. Okay. You testified the security guards were doing belly flops on top of your body,
right?
A. Thats what I was told.MR. ZONEN: Ill object as beyond the scope of the 402 hearing.
THE COURT: The objection is overruled. Do you want to read the question back to her?
MR. MESEREAU: Yes, please, Your Honor. Thank you. (Record read.) THE W ITNESS: This
is correct.
Q. BY MR. MESEREAU: And you also claimed that security guards in a public parking lot
pulled your breasts out of your blouse and squeezed your nipple between 10 to 25 times,
correct?
A. No, they didnt pull my breasts out.
Q. What did you claim happened?
A. In the course of me getting beat up, I was laying flat on the floor. My breasts had came
out of my bra.
Q. Did you testify under oath that your nipple was squeezed by one of the guards 10 to 25
times?
A. At this moment, the attorney, who was the defense attorney, wanted me to describe
everything by the millisecond, even though, in my depositions, I keep saying, over and
over, It was like this. It was like this. And instead, he wanted me to go millisecond per
millisecond, so I described it the best I could as it was happening. But if you fast-forward,
that would have been fast.
Q. And how did you describe the sexual assault?
A. Like I said, the wording as far as how the civil attorneys did, that was their choice of
words. There was only one, how I described it, and thats how they put it in.
Q. Please tell the jury how you were sexually assaulted.
A. Well, to me - me - I feel that my breast area and anything to do with my -- with down
there, my private area, is considered my sexual organs. Thats how I see it and how I feel
about it. So if you place your hands on me in that area, Im going to say that.
Q. And please tell the jury how you were sexually assaulted in that public parking lot.
A. Okay. When I was laying on the floor, while theyre beating on me, one of the Tower
Records guys, who incidentally -- this can be verified. I think he was also fired for doing
this to some other people after this, so -- but this person, while I was laying on the floor

getting beat up, he had his hand over and over on my breast and on the front area of my
private area. My pants were on. There was no intercourse, no rape, no nothing like that. I
was just trying to describe that his hands were on my breasts, which I think I repeated ly
kept saying I just wanted his hands off of me, and thats it.
Q. Do you remember testifying your nipple was squeezed 10 to 25 times?
A. Yes. Again, it was he wanted me -- to humiliate me, like hes trying to do at this
moment,
and making me to say it millisecond per millisecond.
Q. You testified to these facts to get money, true?
A. It was a civil lawsuit, yes, it was.
Q. Now, you claim in that lawsuit that Gavins cancer was made worse by the security
guards, true?
A. I dont think so. I think -- I think I said something that Gavin was having the
chemotherapy at this time when they wanted the deposition to occur.
Q. You also claim that Stars cyst was made worse by the security guards, correct?
A. Incorrect.
Q. Did you ever make such a claim?
A. Incorrect.
Q. What did you say about Star in that situation?
A. I think -- and this is the best I can remember, and were talking 1998 here when this
happened. This is the best I can try to remember. Hes got a big, giant book right there,
and I have nothing in front of me. And, let me see, I think what happened was when we
went to the doctors, they did -- they put him in this tube, and when it came out, they
ended up telling me that Star has a cyst on his brain, but this is something that is -- that
Star has. Thats it. Has nothing to do with J.C. Penneys lawsuit. Im -- of course, getting
hit on the head doesnt help if youve got a cyst on your brain.
Q. Do you know someone named Mary Holzer?
A. Yes, I do.
Q. Please tell the jury who Mary Ho lzer is.
A. Mary Holzer is a giant Michael Jackson fan. And shes also a -- an office manager. This
is my understanding. She told me she was an office manager for Rothstein civil law -- civil
law firm.
Q. And who is the Rothstein civil law firm?
A. The Rothstein civil law firm is a firm that was responsible for the lawsuit.
Q. Do you remember, after you had settled that case, telling Mary Ho lzer that you lied in
the case?
A. That is inaccurate.
Q. Okay. Do you remember telling Mary Holzer that Davids brother is in the Mexican
mafia?
A. Thats incorrect.
Q. And that he sells drugs here and in Las Vegas?
A. Thats incorrect.
Q. You said, Hes going to come after you and your daughter if you ever tell anyone what
Im revealing to you?
A. Incorrect.
Q. Okay. So that never happened, right?
A. That never happened.
Q. And if Mary Holzer comes into court and says that, shed be lying; is that correct? MR.

ZONEN: Objection; argumentative. THE WITNESS: Yes, she would. Yes, she would. THE
COURT: Just a moment. The objection to the question is sustained. The question and
answer are stricken.
Q. BY MR. MESEREAU: How many lies under oath do you think you told in your
depositions in the J.C. Penney case?
A. Like I said, I tried -- after David was arrested, I went to the Rothstein office and I
pointed out to them, prior to a settlement agreement, that I would like to correct the
statements that were inaccurate, because finally David was arrested. Finally, we and my
children could speak. And Rothstein, includ ing with Mary Holzer, said, Dont worry. Well
take care of it.And they didnt. So I considered their firm a -- liars.
Q. But not you, right?
A. Thats correct.MR. ZONEN: Objection; argumentat ive. THE COURT: Sustained. The
remarks stricken. Youre admonished not to make those remarks.MR. MESEREAU: Yes,
Your Honor.
Q. You testified in that deposition in the J.C. Penney case that you had worked as an
undercover agent. Do you remember that?
A. Me?
Q. Yes.
A. Yes.
Q. Where did you -A. I dont think the way youre using it is correct.
Q. Remember you said you had worked in internal security?
A. What hes trying to say, hes trying to make it bigger than it is. I used to be a lost
prevention agent way back in -- I think it was 1990. Were talking about 15 years ago.
Thats my best estimate. I used to work at Vons. Just, you know, people that took an
orange, took a banana, things like that.
Q. Remember you were asked the question, And you were an undercover type of agent?
And you answered, Yes?
A. Yes. Thats what they called it. It was loss prevention agent. You wore plain clothes and
you stopped people when they take items without purchasing them from the market, from
Vons market.
A grocery store.
Q. How long did you work in that capacity?
A. I think I worked there for -- my best estimate, best estimate, maybe - this was about
15 years ago - maybe about one year. Maybe. My best estimate. This is having to recall
15 years ago. Please, this is an approximation of dates.
Q. You testified in that case that security agents in the public parking lot punched you,
correct? MR. ZONEN: Which case are we talking about? Vons? THE WITNESS: Yes. MR.
MESEREAU: J.C. Penney case. Was there a case against Vons? I havent have said that,
Your Honor.THE COURT: Youre right, you shouldnt have. The District Attorney, youre
admonished to object according to the legal standards for objections. MR. ZONEN: The
objection is vague, then, Your Honor. THE COURT: Its a little late. Im not going to allow
you to engage in that type of conversation with each other or with the witness. MR.
MESEREAU: I apologize. THE COURT: Do you want me to shut the trial down this
afternoon? MR. MESEREAU: No, Your Honor, I dont.THE COURT: Then lets start taking
this seriously and act correctly. MR. MESEREAU: Yes, Your Honor. THE COURT: Go ahead.
Q. BY MR. MESEREAU: In the J.C. Penney case, you claimed under oath that you were
punched with closed fists in the parking lot of J.C. Penney, correct?

A. Yes.
Q. You also claim that you were punched with handcuffs, like they were brass knuckles,
correct?
A. Read -- what are you talking about? If I said that I was beat up, that includes
everything they did. You know, he wants me to recall something that happened in 1998
and break it down while hes got a big, giant book right here.
Q. In the J.C. Penney case, d id you claim under oath that you were punched with
handcuffs as if they were brass knuckles?
A. I remember -- I remember seeing the female having the handcuffs inside her fingers
like this.Thats what I remember seeing.
Q. And after being punched all these times in the parking lot, you said you thought you
were going to die and it was like you were in a cave in a tunnel. Do you remember that?
A. Yes, it did feel that way. It did feel that way.
Q. You said security guards were punching Gavin and Star, correct?
A. Can you please read -- bring me that where it says that?
Q. Okay.
A. Because my son -- both of my sons were hurt.
Q. Were they hurt by security guards?
A. No, bring me -Q. Were they hurt by security guards?
A. Yes, they were.
Q. Okay. You said Gavin didnt get up. He just laid on the floor, right?
A. I think -- hes being general. My son was pushed and -- by one of them, causing his
elbow to fracture. He ended up having a fracture, so -Q. And you said Gavin had cancer in both his lungs, right?
A. Now, are we going at that time?
Q. Yes, at that time.
A. Okay. Hes mixing up the facts purposely. W hen my son was deposed in 2000, he had
cancer. And they had -- progressively it went to both of his lungs. At that time when both
my boys -- the summer of first grade when this happened with J.C. Penneys, no, he did
not have cancer. But when he was deposed, yes, he did.
Q. And he had cancer in both of his lungs at that point, right?
A. Yes.
Q. Okay.
A. Stage IV.
Q. Do you know an attorney named George Owen Feldman?
A. No, I dont know him.
Q. Has George Owen Feldman ever represented you, to your knowledge?
A. Never.
Q. Would it refresh your recollection if I just showed you a document you signed with his
name on it?
A. Sure. Go ahead. MR. MESEREAU: May I approach, Your Honor? THE COURT: Yes. THE
WITNESS: Okay. And I think thats something that your office, Mr. -- Mr. Sneddons office
-THE WITNESS: Oh, okay. I was ready to -- THE COURT: Just a moment. THE WITNESS:
Okay. THE COURT: Go ahead, Counsel. MR. MESEREAU: Okay.
Q. Have you had a chance to look at that document? A. Yes, I have.
Q. Does it refresh your recollection about who George Owen Feldman is?
A. Ive never been represented by George Owen Feldman, but I understand what hes

trying to say,the paperwork.

Q. So you never have been represented by that lawyer, right?
A. Never. MR. ZONEN: Objection; asked and answered. THE WITNESS: Never. THE
COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember testifying under oath in the J.C. Penney
deposition that you werent interested in suing?
A. I wanted an apology.
Q. Did you ever withdraw your suit for money?
A. No.
Q. Are you telling the jury that you blame your descriptions of what happened to you on
your attorneys?
A. What?
Q. Are you telling this jury that you blame the way you describe your injuries in that case
on your lawyers?
A. No. Like -- Im going to try to make out what hes trying to say. However I spoke to
them and however they communicated to the court, thats how it was.
Q. Did you testify under oath the way your lawyers told you to? Is that what youre
saying?
A. What?
Q. Did you testify under oath in that deposition the way your lawyers told you to?
A. No.
Q. Are you blaming your descriptions about what happened to you in the parking lot on
your lawyers? MR. ZONEN: Object ion. Vague as to descriptions.THE COURT: Overruled.
You may answer. THE W ITNESS: Okay. Im going to try -- Im trying to feel for what hes
asking. How I communicate -- communicated to him, to them, is once. As I told the
police, I told them. Now, what they -- how they put it on paper, I have no control of that.
He was not -- I wasnt one of the knights of the round table sitting there and coming up
with proper words what to say. Thats it. One story. Thats it. The same one I told to the
police.
Q. BY MR. MESEREAU: When did you meet Michael Jackson?
A. I think it was, my best estimate, August of 2000.
Q. Do you remember signing a document prepared by the Santa Barbara Sheriffs
Department on December 18th, 2003?
A. Okay, I think -- is it the paper you just showed me?
Q. Yes. But I have a -A. I cant answer unless you tell me exactly. You know, there was a lot of paperwork.
Q. Would you like to see it?
A. Well, Im asking you, please, is it the same one that you just came up here and showed
me?
Q. It is.
A. Okay. Then, yes. Ive signed many paperworks of theirs.
Q. Let me ask you the question again.
A. Okay.
Q. Do you recall signing a document prepared by the Sheriffs Department of Santa
Barbara County on December 18th, 2003?
A. I think so.
Q. Would it refresh your recollection just to look at the date and your signature?
A. No. Thats -- is that the one that you just showed me?

Q. It is.
A. Then -- then, yes.
Q. You did sign that document -A. Yes.
Q. -- on December 18th -A. Yes.
Q. -- 2003?
A. Yes.
Q. All right. Now, do you remember signing a document prepared by the sheriffs
department that said the following: From t ime to time, between January 1st, 2000, and
the present date, I consulted one or more of those lawyers concerning Michael Jacksons
interact ion with me and my children at Neverland Ranch in Santa Barbara County and
elsewhere, in this and other states, and concerning the return of some furniture stored by
or in the name of Brad Miller at Dinos Storage in North Hollywood, Los Angeles
County.Do you remember signing a document that had those words?
A. Do you want me to have the document, like --weve had this discussion over since
August. MR. MESEREAU: Object, Your Honor. THE WITNESS: Since August, the same
thing --THE COURT: Just a moment. I want you to answer the question. The question is,
do you remember signing that document? THE WITNESS: Yes. Yes.
Q. BY MR. MESEREAU: And the document said that you had started investigating Michael
Jackson sometime between January 1st, 2000, and the date you signed the document,
which is December 18th, 2003, right?
A. Yes. If thats -- those words are on there.
Q. Why would you start investigating Michael Jackson around January 1st, 2000, if you
didnt meet him t ill August 2000?
A. Okay. Let me explain something to you. An this has already been discussed, and he
knows the answers. This was discussed at the end of September. MR. ZONEN: Im going
to object to this part of the answer as nonresponsive. THE COURT: Sustained. THE
WITNESS: This -- when the sheriffs were doing their investigation, they wanted to know
every sing le detail about me. George Owen Feldman is -- I think hes associated in the
same law firm of Rothstein. So the -- the police department did an extensive, extensive
search on me as a person, and so they want -- they put everything in a general form so
they can have access to everything about me and my past, because they wanted to verify
and make sure that what they were going to do towards this goliath was going to be
accurate and truthful. And
thats why this -- this paper was made in such a general way.
Q. BY MR. MESEREAU: Are you now telling the jury that George Owen Feldman d id
represent you?
A. No, he didnt represent me.
Q. At any time?
A. No, he didnt represent me. He is one of the people inside the civil law firm. But my
understanding -- my understanding was that it was only the Rothstein -- Rothstein and
another attorney named Adler, another attorney named Ramieri. That was my
understanding, and it still is today.
Q. Let me try and ask the question again - okay? - in a clearer form, because perhaps I
was not clear. And I apologize if I wasnt. You signed a document that said from time to
time between January 1st, 2000, and the date you signed the document, you were
investigat ing Michael Jackson through various lawyers, correct?

A. Okay. Theres more information on that paperwork which he purposely has taken out of
context. Its -- certain events are attached to specific attorneys. Certain situations are
attached to certain attorneys. Like I said, the police wanted to do an extensive, thorough
investigat ion on me prior to doing it on him. So they wanted everything about me. So
they made it in a general form. But he keeps taking it out of context. MR. MESEREAU: I
dont want to offend the Court, Your Honor. I dont think I actually got an answer to that,
but I will leave it to the Courts discretion. THE COURT: Ask your next question. MR.
MESEREAU: Yes, Your Honor.
Q. You did sign this document, correct?
A. Yes, I did. MR. MESEREAU: I would move it into evidence, Your Honor. THE COURT: Its
admitted.MR. ZONEN: I will object, given the prior ruling dealing with confidentiality of the
--MR. MESEREAU: Its redacted. MR. ZONEN: Perhaps we could argue this at the next
break or the conclusion of the proceedings. THE COURT: All right. Ill withhold ruling on it,
on its admissibility, till --MR. MESEREAU: Shall I submit it to your clerk, Your Honor? THE
COURT: Have you numbered it? MR. MESEREAU: I have not. THE COURT: Will you do that
now, so we have a record of what youre talking about? THE CLERK: 5007. THE COURT: 50 --THE CLERK: 5007. THE COURT: All right. Ill withhold ruling until we hear from the
District Attorney. MR. MESEREAU: Yes, Your Honor, at this time wed like to play the
rebuttal tape.MR. SANGER: Exhibit 340. THE COURT: 340. Are you ready? (Whereupon, a
portion of a DVD, Plaintiffs Exhibit 340, Disk 1, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, Miss Arvizo, you are laughing at various times during this
tape. Was that something that you scripted in advance?
A. I was nervous. Brad Miller was standing right next to the camera, right in front of me.
Q. Was the laughing something that you scripted in advance?
A. Yes. Also, Dieter wanted that included.
Q. Is everything that your son is saying memorized?
A. Everything -- they took all the informat ion from us, information that did exist, back
from
Miami, and information that they had already, they studied us and got background
informat ion --MR. MESEREAU: Move to strike, Your Honor. THE WITNESS: -- and then
they put it all together. THE COURT: Just a moment. THE WITNESS: I answered your
question. THE COURT: I think that could be answered yes or no. The question is, Is
everything that your son is saying memorized? THE WITNESS: Everything is -- is going
according to what Dieter had scripted. THE COURT: Go ahead.
Q. BY MR. MESEREAU: Is it memorized?
A. I think so.
Q. Okay. (Whereupon, a portion of a DVD, Plaint iffs Exhibit 340, Disk 1, was played for
the Court and jury.)
Q. BY MR. MESEREAU: Ms. Arvizo, were the words you just articulated on that tape all
memorized?
A. Yes.
Q. Were you lying on this tape?
A. No. Im a poor actress. Thats why they started the proceeding to go do the passport
and the visa. Thats what Vinnie had communicated to me; that what I did was
inadequate.
Q. You were not lying on this tape?
A. Acting.
Q. Let me rephrase the question.The jury just heard the words you expressed on the tape,

right?
A. Correct.
Q. Were they lies?
A. Acting. MR. MESEREAU: Your Honor, may I request that the witness be instructed to
answer the question? THE COURT: Well, the question was, Were they lies? And she said,
Acting.MR. MESEREAU: I can rephrase it, Your Honor.
Q. When you said what the jury just heard you say on this tape, were you telling the
truth?
A. I was acting. I dont know how you want me to define it. I mean, youre not going to
call Halle Berry and say, Are you Catwoman? Shes going to tell you shes acting. Shes
just acting. Shes not a liar. I was acting. Thats it.
Q. Are the words you said on that tape the truth? MR. ZONEN: Objection; asked and
answered. THE COURT: Sustained. (Whereupon, a portion of a DVD, Plaintiffs Exhibit 340,
Disk 1, was played for the Court and jury.)
Q. BY MR. MESEREAU: Ms. Arvizo, was what you just said about Michael Jackson being
fatherly the truth?
A. Everything on here was choreographed by Dieter and Ronald, specifically Dieter, and
its all acting. And I failed at that.
Q. Are the words you spoke true or false?
A. The words I spoke were part of a script.
Q. Were you telling the truth or not?
A. I was acting.
Q. Was Gavin telling the truth or not, as far as you were concerned?
A. As far as - MR. ZONEN: I think thats speculative. Ill object.THE COURT: Its overly
broad. Ill sustain the objection.
Q. BY MR. MESEREAU: Was it your belief that Gavin was acting in this tape?
A. Yes, because I had seen Dieter work with my children prior to Jesus taking us back to
my mo ms house. I had seen Dieter work with me and my children.
Q. Did you believe that what Gavin was saying was true or false?
A. I believe, like I told you, Dieter had worked with us continuously on this script.
Q. Did you believe what Gavin said was the truth or not?
A. I believe what he was saying was keeping to the script. (Whereupon, a portion of a
DVD, Plaintiffs Exhibit 340, Disk 1, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, Ms. Arvizo, you said that you and your children were
neglected and spit on, right?
A. Yes.
Q. And who were you referring to?
A. They took elements of my life and my childrens life which were truthful and
incorporated it into their script. And this happened in the initial meeting in Miami. They
already had -- they were alread y in the works on this. It took me a while to find out. And
its taken many other people to find out later, too.
Q. Who neglected your family?
A. In this script, everything is scripted. But if youre making a general question, you
already have the specifics on that.
Q. When you said your family was spit on, who were you referring to?
A. On this rebuttal thing, everything is scripted. They took elements of mine and my
childrens life which were true and incorporated in here.
Q. When you said, Everybody tossed us aside,who were you referring to?

A. This is all scripted here.

Q. When you said, We werent in the right zip code, and we werent the right race, what
were you referring to?
A. This was all scripted. For those answers, you need to ask Dieter.
Q. But wouldnt you agree that on numerous other occasions you said exactly the same
thing?
A. Thats correct.
Q. You even said words to that effect on that phone call you had with Frank when you
didnt know you were being recorded.
A. Thats correct.
Q. And your answers werent scripted there, were they?
A. No, they werent. They -- like I said, they took elements of mine and my life -- mine
and my childrens life and put it into this script.
Q. Well, not referring to what you say on this tape, but referring to what you said on other
occasions when you didnt know you were being recorded, what did you mean when you
said, Our family has been neglected and spit upon, et cetera? W hat were you talking
about?
A. Outside this rebuttal, were talking about David.
Q. Okay. (Whereupon, a portion of a DVD, Plaint iffs Exhibit 340, Disk 1, was played for
the Court and jury.)
Q. BY MR. MESEREAU: Now, Ms. Arvizo, you had been very critical of David for not
defending you and your children like a father should, correct?
A. He would have to defend us from his own self.
Q. Were you critical of David for not defending you in the J.C. Penney case the way you
thought he should?
A. I was not critical.
Q. Never were?
A. No, I was just -- he just stood there.
Q. Didnt you say that you had -- excuse me. Let me rephrase the question. Didnt you
say on one occasion that you would forgive David for not acting like a man in that parking
lot?
A. I dont remember clearly, but I can -- I can
20 try to recall for you.
21 Im getting beat up on the floor. And the
22 history is David had always been beat ing me up. And this one moment that he could
have done something for me, he allowed these people to beat on me while I was laying
flat on the floor, while he stood like a coward on -- it was like a little sidewalk. Thats
where he stood. If thats what you want -Q. Okay.
A. -- thats the best I can recall.
Q. Now, you say in this tape about -- excuse me. Davellin says in this tape, about Michael,
The fact that he stood up and defended us, thats a father. Was that just scripted?
A. Okay. All this on the video, plus the outtakes, everything is scripted. Michael, when we
arrived in Miami, he had like a 45-minute lovey-dovey meet ing with us.
Q. Okay. And they started scripting it in Miami?
A. They must have. They must have started all this stuff way before I was even called up - up to Miami. They must have.
Q. So they were script ing you in Miami, but you didnt know what they were doing, right?

A. Like I said, were going to have to call Ronald, Dieter, all of them in here to find out
what
they were up to. Or Michael, he could come up here.
Q. Were you being scripted in Miami without knowing it?
A. I dont know. I dont know.(Whereupon, a portion of a DVD, Plaint iffs Exhibit 340, Disk
1, was played for the Court and jury.)
Q. BY MR. MESEREAU: Miss Arvizo, is what you just said memorized?
A. Yes. And -- yeah. (Whereupon, a portion of a DVD, Plaintiffs Exhibit 340, Disk 1, was
played for the Court and jury.)
Q. BY MR. MESEREAU: As far as you were concerned, was everything Gavin just said
memorized?
A. As far as Im concerned. Like I say, I pointed out, Dieter had worked on us, with us.
And also, I would like to maybe help you remember, this was --MR. MESEREAU: Could I
get a yes or noanswer, Your Honor? THE COURT: Yes. Do you want the question read
back? THE W ITNESS: Sure, please. (Record read.) THE W ITNESS: Yes. (Whereupon, a
portion of a DVD, Plaintiffs Exhibit 340, Disk 1, was played for the Court and jury.)
Q. BY MR. MESEREAU: Now, Ms. Arvizo, you say that because youre with Michael, you
dont have money problems, correct?
A. Scripted. And remember, this is being filmed at 3 a.m., right before the CPS meeting.
Q. Now, you say that everything the jury has just watched and heard on this videotape
was memorized and rehearsed, right?
A. Yes. And while I was over here, in Jay Jacksons apartment they had their claws in my
three kids.
Q. How long did it take all of you to memorize all the words that the jury just heard you
say?
A. Well, they worked -- Dieter -- while I was there, in my presence, Dieter worked, well,
with us daily, and about on the average of ten times a day. And then when I came over
here, and the children were over there, who knows how many times. That you would have
to get from my children.
Q. Lets talk about you only. You said you sat down with Dieter ten times a day, correct?
A. My best estimate.
Q. And where did you do that?
A. In one of the guesthouses, the one that looked like the little boys room. That one.
Q. This is the first time, after numerous police interviews and after going to the grand
jury, that youve ever said, I met with Dieter ten times a day to memorize my words,
right?
A. No, I said, Many times daily.
Q. Okay.
A. Thats my words, but you want specific answers.
Q. So you said everything the jury just heard was memorized, and Im just asking you
how long it
A. How long?
Q. Do you think.
A. Well, I d idnt do a good job.
Q. How long do you think it took you to memorize all of this?
A. I couldnt give you an answer.
Q. Was it all memorized word for word?
A. I did my best.

Q. And was it all written out in advance?

A. Yes, it was.
Q. So how -- how many pages were in this script, if you know?
A. Well, at the end of the video right here, you can see Christian have the script himself.
And probably Bradley Miller also had it, because he was standing right next to the
cameraman right in front of us. Brad Millers job was to report to Dieter if we d id
everything we were supposed to do.
Q. Was everything written out word for word in advance?
A. Yes.
Q. Okay.
A. Theyre very detailed.
Q. And you just memorized every page, true?
A. I did my best.
Q. Okay.
A. And I failed. MR. SANGER: That was the end of that first disk. We have the second disk.
THE COURT: I understand. You ready? MR. MESEREAU: Yes, Your Honor. MR. SANGER:
Oh, weve got to -- just a second. THE COURT: Do you want me to put it on Black?MR.
SANGER: Oh, you can leave it on. I just wanted to squelch the high-pitched tone that
would be otherwise heard. THE COURT: That was pretty good of you to remember that.
(Whereupon, a portion of a CD, Plaintiffs Exhibit No. 340, Disk 2, was played for the Court
and jury.)
Q. BY MR. MESEREAU: Miss Arvizo, was what you just said memorized word for word?
A. Yes, I tried to do my best. MR. MESEREAU: Do you want to take a break at this point,
Your Honor? THE COURT: That would be good. Thank you (Recess taken.) THE COURT:
Mr. Mesereau? MR. MESEREAU: Yes, thank you, Your Honor.
Q. Miss Arvizo, before we continue with the tape, Id like to clarify something. Did you tell
the jury earlier that even the outtakes were scripted?
A. Yes. Everything. The whole entire -- from the moment we got to Hamids house, Brad
Miller there -- was there, Michaels P.I.
Q. So when you said about Gavin, He was doing gang signs. That was what he was doing.
Hes --he shot out to his friends on the west side, was that all scripted?
A. Everything; everything was scripted.
Q. Okay. We can continue. THE BAILIFF: You need to push the DVDbutton. MR.
SANGER: I pushed DVD. Im going to pause for a second. Shall we just pick up? W e
missed ten seconds, but Ill just go ahead.
Q. BY MR. MESEREAU: Now, Miss Arvizo, this is the portion of the videotape where you
refer to the Department of Child Social Services, right?
A. Yes.
Q. And you told the jury that you were criticized for referring to them in the videotape,
right?
A. As I told you before, I got in trouble by - because I mentioned -- I went off the script
with God, cancer, and the Child Welfare Services, those three things -Q. Okay.
A. -- specifically, V innie told me.
Q. So now youre off the script -A. Yes.
Q. -- when you criticize the Department of Child Social Services, right?
A. Yes.

Q. You were speaking of your own free will when you said that, correct?
A. Yes.
Q. And when you said, So where are all these people that -- that have all of a sudden this
care and concern throwing the child advocacy group on me, the Department of Child
Social Services, you were telling the truth, correct?
A. At that point where I went off, God, the Child Welfare Services, and the cancer, so that
one word.
Q. Were you criticizing the Department of Child Social Services?
A. No. That one word I went off the script, and so I got in trouble for it.
Q. Were you criticizing the Department of Child Social Services?
A. No. That was part of the script, the child advocacy.
Q. That was part of the script?
A. Yes. I added the -- the Child Welfare Services in a way that was off the script.
Q. And why were you criticizing that agency?
A. Well, I had the Child Welfare Services meeting that morning, and it blurted out, so I got
in trouble for it.
Q. Were you worried about the meeting?
A. No -- yeah, I was worried about the meeting, so I got in trouble for that.
Q. So you were being crit ical of DCFS, correct?
A. No, no, I wasnt. That came out.
Q. It came out, but you were -A. No, the word, the one word, Child....MR. MESEREAU: We can move on. /
(Whereupon, a portion of a DVD, Plaint iffs Exhibit 340, Disk 2, was played for the Court
and jury.)
Q. BY MR. MESEREAU: Ms. Arvizo, everything said in this interview was memorized,
correct?
A. Everything was except for what I got in trouble for. Those are the three things. I was
supposed to say that Michael healed Gavin --MR. MESEREAU: Your Honor, could I -- could
the Court admonish the witness to just answer the question? THE COURT: Yes. Just
answer the question. THE WITNESS: I thought I was answering it. THE COURT: Yes, go
ahead.
Q. BY MR. MESEREAU: Everything was memorized word for word, right?
A. Yes, except when I blurted out the little meeting that I was going to have in a matter of
hours. I wasnt supposed to blurt that out. And I did. I failed.
Q. Now, you told the jury yesterday that during this period of time where you claim your
family was falsely imprisoned, that you never reported it to the police, correct?
A. Correct.
Q. And you told them that you didnt report it to the police because you thought no police
officer in Los Angeles would believe you, correct?
A. Thats correct.
Q. And because you thought no police officer would ever believe you, you never talked
about being held against your will, right?
A. Is that a question? MR. ZONEN: Objection; vague. To whom? MR. MESEREAU: Let me
rephrase it.
Q. What is the period of time that you claim you and your family were held against your
will by people associated with Mr. Jackson?
A. From -- approximately from February to March.
Q. And --

A. Thats my best estimate.

Q. And what date was this rebuttal video, if you know?
A. This was -- the best I can remember is being taken there on the 19th about 11 p.m. at
night, approximately. And then it went into the morning of the 20th, was filmed at about 3
a.m. And that morning, about nine oclock, was the meet ing.
Q. During the time you claim your family was held against their will, were you in contact
with any police officers?
A. No.
Q. Do you know a Los Angeles police officer named Andrew Lassak?
A. Officer Lassak, yes, I do.
Q. Who is Officer Lassak?
A. Officer Lassak is a friend.
Q. How long has he been your friend?
A. Hes been my friend since I think approximately -- let me see. Oh, you know,
afterDavid was arrested from domestic violence. That period of, I think, about 2001.
Q. And during the period of time you claim you were being held against your will, you
were commun icat ing with Andrew Lassak, correct?
A. No, thats incorrect.
Q. Well, do you remember an interview you had with the Santa Barbara Sheriffs
Department where you mentioned Andrew Lassak?
A. Yes.
Q. Remember while you were discussing what Vinnie was doing, you told the interviewer,
Hes one of the LAPD officers that I had told him about things that were happening? Do
you rememb er that?
A. I dont think youre saying it correctly. Youre leaving things out from the beginning and
in front of that.
Q. Would it refresh your recollection to see what you told the Santa Barbara sheriffs when
you were interviewed?
A. No. You dont need to -- Im saying to you,youre not saying it completely to the
jurors.What hes trying to say is I was -- after I met with Mr. Dickerman and Mr. -- in the
process of that, of the attorneys, I tried to reach Officer Lassak. And in between that was
when I had contacted him in order to get help to let him know what was going on. And
then in the midst of that, thats when the sheriffs, the Santa Barbara sheriffs got involved,
and the Santa Barbara sheriffs, which is on my police report, stated that he didnt need to
get involved, that it happened over here, so therefore theyre the ones that are going to
take over the investigation.
Q. During the time you claim you were falsely imprisoned, you had phone conversations
with Andrew Lassak, correct?
A. Incorrect.
Q. Okay.
A. But during the police interview, yes.
Q. He is with the Hollenbeck Divis ion, correct?
A. That is correct.
Q. The Hollenbeck Division of the Los Angeles Police Depart ment is the division where
your Soto Street address is, right?
A. That is correct.
Q. Okay. And youre saying you never told anyone from the Santa Barbara Sheriffs
Department that you were in communication with Andrew Lassak during that period of

time?
A. When we were having a police interview, Officer Lassak happened to call because I was
trying to put in a call, like I said, between the attorneys and the Santa Barbara sheriffs.
This period was Officer Lassak, way after Neverland, because finally I was able to make
contact with him.
Q. Do you remember telling Officer Lassak, Something big is happening. I cant talk
about it. I have lawyers?
A. I never said something like that.
Q. So if he said you said that, that wouldnt be true? MR. ZONEN: Objection.
Argumentative; speculative. THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you know an LAPD officer named Patrick Metoyer?
A. Yes, I did.
Q. When did you meet Patrick Metoyer?
A. Officer -- the same time Officer Lassak, I met him.
Q. And what year would that be?
A. That would be in 2001.
Q. Did you know a Sergeant Milt Hernandez from the LAPD?
A. And Officer Metoyer is no longer working for LAPD.
Q. Did you know a Sergeant Milt Hernandez from the LAPD?
A. That -- that name doesnt sound familiar.
Q. Do you remember talking to him? Hes with the Hollenbeck Divis ion.
A. I think what youre trying to refer to is someone who was there as a watch commander
or something like that. But not a friend. Hes not a friend.
Q. When did you first meet him? MR. ZONEN: Whos him? Object ion; vague.MR.
MESEREAU: Milt Hernandez.
Q. When did you first meet him?
A. If its the same --MR. ZONEN: Objection; assuming facts not in evidence that she ever
met him. MR. MESEREAU: Ill rephrase it, Your Honor.
Q. Did you ever meet Sergeant Milt Hernandez from the Hollenbeck Divis ion?
A. No, never.
Q. Did you ever speak to him on the phone?
A. If its the same person, I think it was inquiring about the LAPD Explorers, because I was
interested in moving Davellin from the Wall Street Central Divis ion up to the Hollenbeck
Division, if thats -Q. And approximately when d id you talk to him, if you remember?
A. I dont remember.
Q. You said you first met LAPD Officer Andrew Lassak -A. And this is the best I can remember.
Q. You said you first met LAPD Officer Andrew Lassak in 2001; is that correct?
A. That is correct.
Q. And how did you meet him?
A. I think it was because of a call or something like that.
Q. And what are you talking about?
A. Thats the best I can remember.
Q. You said its a call about something?
A. Yeah, thats the best I can remember.
Q. Did you call him?
A. No, I didnt.

Q. Did he call you?

A. No.
Q. Did you ever ask him to assist you or your family in anything?
A. No.
Q. Did you ever ask him to drive you home?
A. Not me personally.
Q. Did he ever drive you home?
A. I think so, yes. In the LAPD car, yes. I do recall that.
Q. And when did LAPD Officer Andrew Lassak drive you home?
A. He drove me home because I had -- both my feet were operated.
Q. And how did you get in touch with him?
A. I think there was a call, a request for help, and he helped me out. I dont really recall.
Q. He drove you home from the welfare depart ment, didnt he?
A. Yeah, I think so. Yeah. Yes.
Q. Okay. And through him, you met a numb er of LAPD officers, did you not?
A. Yes. Just met, not friends.
Q. And they were in the Hollenbeck Division where your Soto Street home was, correct?
A. Thats correct. And I dont know any of their names.
Q. And you met all these officers in approximately 2001, right?
A. This is correct.
Q. You also met some officers from the Metropolitan Transportation Authority, also called
MTA, right?
A. This is correct.
Q. And who did you meet from the MTA -- excuse me, let me rephrase that. What police
officers did you know from the MTA?
A. That department, to the best I can remember, was dissolved. Its no longer. They were
all sent out to different departments, because that was -- that had ended. But I did get to
meet - which I completely lost contact with them - I think it was a female officer and a
male officer. No, actually -- yeah. That was the initial officers I met, yes. But theyre no
longer existent.
Q. How do you know that?
A. Because I drove -- I rode the bus frequently and I never got to see them again
anymore. They were substituted by private security. Because LAPD used to run the metro
department.
Q. Did you ever meet a Sergeant Chiu from the Rampart Division?
A. Sergeant Chiu. That name doesnt sound familiar.
Q. How about a Cindy Garcia?
A. I may have. But it doesnt sound familiar.
Q. How about a Detective Angulo, A-n-g-u-l-o, from the Hollenbeck Divis ion?
A. It doesnt sound familiar. Because of Officer Lassak, I got to meet a lot of officers, but
they werent my friends. Just when he was doing his patrol, he would stop by and he
would have someone with him. He was -- what are those officers called when theyre -oh, he was training officer. So he constantly had someone he was training.
Q. And at one point you had LAPD Officer Lassaks cell phone number, didnt you?
A. Yes, I did.
Q. Do you remember the number?
A. No, I dont.
Q. And he did some nice things for you and your family, didnt he?

A. Yes, he -- he was our friend.

Q. Please tell the jury the nice things that LAPD Officer Andrew Lassak did for you and
your family. MR. ZONEN: Im going to object as irrelevant. THE COURT: Sustained.
Q. BY MR. MESEREAU: Ms. Arvizo, the truth is, you knew a lot of police officers near
where you lived, you could have called any of them and said you were the victim of crime,
and you didnt, right?
A. It would have been helpful, but Officer Lassak was recently married in about June. And
out of respect I figured hes got a new wife, and its best that I dont communicate with
him. So I lost communication the day he got married, right before.
Q. Did you ever hear of a group called B ig Brother or Adopt-a-Family?
A. No, but -- no, but I came to find out now that maybe those kind of things are -Q. Im sorry?
A. Thats what I told you.
Q. Okay. When you were interviewed by Santa Barbara sheriffs -A. Yes.
Q. -- did you ever ment ion that you had met Andrew Lassak and a bunch of other officers
through a group called Big Brother or Adopt-a-Family?
A. I think that was Officer Robel or Officer Zelis that mentioned that. It wasnt I that said
that.
Q. Excuse me. Let me rephrase that. Did you ever participate with LAPD Officer Andrew
Lassak in any type of group involving family support in East Los Angeles?
A. Okay, Officer -- I think I know what youre referring to if -Q. Yeah, whatever -- please tell the jury whatever it is.
A. Okay, Officer Lassak -- usually all the department -- this is what was explained to me.
Each officer personally picks someone, someone from the community or someone they
like, or anything, and they put their name into some kind of -- I dont know how it works,
but this is how I came to understand. That they put their name into some --something,
and then they pick families out of there. And thats it.
Q. And was your family chosen to participate?
A. Yes. Officer Lassak put me and my kids in there.
Q. Approximately when was this?
A. This was in -- I dont remember. But it was Christmas.
Q. Do you know approximately what year?
A. No, I wouldnt be able to tell you that, but I know it was Christmas.
Q. Was it before you think you met Michael Jackson?
A. No, it was after. Because I -- like I said, I met Officer Lassak after David was arrested.
Q. And for the jurys benefit, approximately when was David arrested?
A. About -- I dont know. My best estimate, September, October of 2001. Thats my best
estimate.
Q. And in your interview with the Santa Barbara sheriffs, you said that Mr. Lassak would
come with different officers and make jokes, right?
A. Yes. He would -- like I said, Officer Lassak, even though he was a corporal, hes also a
training officer. And he would bring different officers, and he would stand in the doorway,
and hed make jokes with the kids.
Q. Now, which doorway was this?
A. My front door to my apartment.
Q. Okay. And you said hed get a big kick out of the kids telling him jokes, right?
A. Yes.

Q. And do you know who the officers are that he used to bring to your front door?
A. I wouldnt be able to tell you, because the majority of them never came twice. They
just would come once.
Q. How many would he often bring -- excuse me, let me rephrase that. How many officers
would Mr. Lassak bring to your house at one time?
A. Well, whoever he was training at that time.
Q. Whats the largest number of officers he ever brought to your house?
A. Well, him and the other person he was training.
Q. And did you ever go to the police department to see him, where he worked?
A. I dont think so.
Q. Did you used to see Officer Lassak driving around the Hollenbeck Division?
A. Yes, I did.
Q. And you were a friend of his for a number of years, werent you?
A. Up until he got married. Because when he got married, I felt its a new marriage, and
out of respect, he needs to dedicate himself to his wife. And I dont think it would be very
respectful for me to be a friend when hes supposed to be dedicating his time to his new
wife.
Q. Okay. Do you remember the names of other officers in the Hollenbeck Division that you
knew around the time Officer Lassak used to come to your doorway?
A. Only Officer Lassak.
Q. Did Officer Lassak ever arrange any type of fund-raiser for your family?
A. No, outside from him putting -- putting us in that Christmas thing, thats it. No fundraiser.
Q. Now, what Christmas thing was this?
A. It was -- every officer picks somebody and they put it in like a bag, and thats it.
Q. Okay. And where did this take place?
A. In the Hollenbeck Division.
Q. And what location did this Christmas event take place?
A. In the Hollenbeck Division.
Q. Okay. Was that at the police station?
A. I think it was.
Q. Did you bring your children to the police station?
A. I didnt go.
Q. Did your family participate in that event?
A. Yes.
Q. How?
A. Officer Lassak had came by and told the kids that on this day they were going to have
like a Christmas party. And thats it.
Q. And who went to the Christmas party from your family?
A. Davellin, Gavin and Star.
Q. Okay. And this is after 2001, right?
A. It definitely has to be, because it was --I met Officer Lassak after David was arrested,
and thats my best estimate.
Q. When is the last time you spoke to Attorney Larry Feldman? Dont say what you said.
Thats confidential. But when was the last time you spoke to Attorney Larry Feldman?
A. I -- I wouldnt be able to tell. I couldnt remember.
Q. Have you been in any commun ication with him in the last month?
A. Let me see. Let me see. No. Its only the times that I was receiving subpoenas from

your office was -- yeah, thats the best I can remember.

Q. Have you talked to him in the last couple weeks?
A. I dont think so. Ive been here.
Q. Have you talked to Attorney Larry Feldman in the last couple of weeks?
A. Let me see. You know what? When was -- when did he testify?
Q. I cant answer questions.
A. Oh, okay. Im only saying that would help me remember. Because it was before that
time.
Q. Have you talked to Attorney Larry Feldman while this trying has been going on?
A. Oh, yes, yes.
Q. How many times?
A. Oh, I wouldnt be able to tell you that. Just about every time you sent a subpoena.
Q. Okay. Would it be accurate to say that while this trial has been going on youve talked
to him more than once?
A. Oh, yes. Every time they sent a subpoena.
Q. Okay.
THE COURT: Counsel, there may be a little ambigu ity there as to, while the trial has been
going on. MR. MESEREAU: Oh, okay. I understand. THE COURT: What the trial is to
some people is different than others. MR. MESEREAU: Sure. Let me rephrase it.
Q. Youre aware that Attorney Larry Feldman testified in this trial, right?
A. Yep. Yes.
Q. How did you know that?
A. Because I had seen Accusers Mothers Attorney Testifies. I seen that, something like
that.
Q. Okay. Within the last few months, youve been in contact with Attorney Larry Feldman,
have you not?
A. Yes, yes.
Q. Youve been in contact with him on a number of occasions? A. Yes, every time they
sent a subpoena over.
Q. Okay. Okay. Now, I think youve answered this question, but let me just be specific.
A. Okay.
Q. All of these officers you met through LAPD, Officer Andrew Lassak, starting with the
year 2001, none of them were ever contacted by you about false imprisonment, right?
A. Thats correct.
Q. None of those -A. Until when I tried afterwards between Mr. Dickerman and the Santa Barbara sheriffs.
And on your thing they said, Dont talk to any other officers but their department so the
investigat ion wouldnt be compromised.
Q. Before you went to Attorney William Dickerman, you never contacted any of these
officers or trainees that you knew in your neighborhood about anything you claim Michael
Jackson was doing?
A. Thats correct. I was afraid to talk on the phone, because they were monitoring,
listening and surveilling me and following me. Thats correct.
Q. Even when you were at your parents home, you never called LAPD Officer Andrew
Lassak and complained, right?
A. Because at this point I didnt have his phone number.
Q. When did you lose it?
A. When he got married, out of respect, I seized my communication with him.

Q. Well, youd been to the Hollenbeck Division Police Department before, right?
A. Yes, I had.
Q. Did you ever contact anyone from the Hollenbeck Division Police Department and
complain about Michael Jackson?
A. Well, I no longer belong to their division. I know -- because my apart ment, because of
them, is no more existent there, so Im not their problem anymore.
Q. You still could have called them, couldnt you?
A. I didnt. Because of being monitored,followed, surveilled, listened to.
Q. You didnt call them from Jay Jacksons apartment, right?
A. Thats correct.
Q. You didnt call them from your parents home in El Monte, correct?
A. Thats correct.
Q. You didnt call them from Soto Street while you were living there, correct?
A. Thats correct. But I told the Santa Barbara Sheriffs Department.
Q. After you went to Attorney Larry Feldman, right?
A. No. Before. Jay Jackson called in about February and thats when we communicated.
That was our first communication.
Q. You didnt fill out a police report with any police department about anything until you
went to Attorney Larry Feldman, right?
A. We made contact with sheriffs, Santa Barbara sheriffs, back in February. They were not
helpful to us. So there was this big gap until afterwards.
Q. When did you first meet Attorney Larry Feldman?
A. After Mr. Bill Dickerman introduced me to him.
Q. Do you know about when that was?
A. I wouldnt be able to tell you. But they could tell you best.
Q. To your knowledge, how long has Attorney Larry Feldman been giving you advice?
Dont say what the advice is. Im just asking you, as far as you know, how long has
Attorney Larry Feldman been giving you advice?
A. Im a little confused by the question, because hes helped more than gave me advice,
when you guys have been bomb -- giving me all those subpoenas.
Q. I understand.
A. That they even wanted my school records all the way till I was a kindergartner myself.
MR. MESEREAU: Move to strike, Your Honor. THE COURT: Just a moment. Thats
stricken.Do you want to rephrase the question? MR. MESEREAU: Yes.
Q. If you know, for how many years has Attorney Larry Feldman been giving you advice?
THE WITNESS: Your Honor, Im having difficulty with it. Im telling you, help and
advice to me is different. THE COURT: Shes asking you to clarify the question. Thats -Q. BY MR. MESEREAU: What you say to an attorney is confidential, and Im not asking
you about your conversations. Okay? Im just asking you how long, in your mind, Attorney
Larry Feldman has been helping you. Well use the word help.
A. Okay. Well, he felt that your defense team was bullies. MR. MESEREAU: Objection.
Objection. THE COURT: Sustained. MR. MESEREAU: Move to strike. THE COURT: Stricken.
MR. MESEREAU: Your Honor, could the witness be admonished to answer the question?
THE COURT: Ask the question again or have the question read back, please. (Record
read.) THE WITNESS: Okay. Every time they -- they were sending me the subpoena, for
example, requesting all my school records, all the way till I was a kindergartner, hes been
helping me.
Q. BY MR. MESEREAU: Let me ask it one more time. But if Im not clear, just tell me.

A. Okay.
Q. What year did you meet Attorney Larry Feld man?
A. In 2003.
Q. You knew some police officers from the MTA, did you not?
A. Yes, I did. I did meet them, but it was not a close contact, as I was with Officer Lassak,
which I stopped because he had gotten married, and that was it. And they no longer were
in existence, because a private security company took over the metro bus division. So I
lost complete contact of them.
Q. And MTA means Metropolitan Transportation Authority, correct?
A. Yes. Theyre underneath the ground. Theyre police officers that were underneath the
ground taking care of the trains that run -- I dont know whether theyre train or metro
rail. I dont know the correct -Q. And you knew a number of officers with the MTA, correct?
A. When that was dissolved, my -- as far as my relationship was with them, every time
me and my children rode the trains, when we would see them wed say hello. But past
that, once they were -- I dont know what the word is. When they were gone,no more, I
didnt see them anymore.
Q. And how many officers from the MTA do you think you knew, when you knew them?
A. It was about two. A male and a female, and the rest were by sight. Every time wed see
them, wed say hello. But there was definitely more than two that I recognized by face.
Q. And were they stationed in the Hollenbeck area?
A. No, they werent stationed in the Hollenbeck area.
Q. Where were they stationed?
A. They were stationed -- to my understanding, they were stationed right there,
underneath the ground in the train rail system.
Q. And didnt these MTA officers help your family out also?
A. Well, I dont know if you call it help, but they also did some Christmas thing.
Q. And what was that?
A. They -- they took a liking to the kids, because they saw the kids go off and on the
trains, and so -- and that was it.
Q. And approximately when d id this happen?
A. Christmastime.
Q. Approximately what year, if you know?
A. I dont remember. But I do remember Christmastime.
Q. Was it after 2001?
A. Oh. Oh, yes, yes. After -- after David was arrested, me and my kids became free to
have -- to go beyond having friendships.
Q. And after David was arrested, it would be accurate to say that you and your kids had a
lot of friends who were police officers, right
A. The only one we could say is Officer Lassak. Thats it. The rest were just people that we
met, but completely lost contact with.
Q. And through Major Jay Jackson, did you meet anyone in the United States Army?
A. Not really. I -- no. I dont even go to -- when Jay would have, like, gatherings from the
Army, I prefer not to go. Even to his -- even to his going-away luncheon, because I knew
I wasnt smart enough to be in that kind of group. THE COURT: Counsel, is this a good
place to stop? MR. MESEREAU: Yes, Your Honor. Thank you. THE COURT: All right. Were
going to recess for the weekend. Remember next Wednesday afternoon, were not going
to be in session. Ill see you Monday at 8:30. Remember the admonitions. Dont talk to

anybody. Dont read anything. Enjoy the weekend. MR. SANGER: When are we not in
session? THE COURT: Wednesday afternoon. MR. SANGER: Wednesday afternoon were
not in session. Were here Monday.

2005 April 18 (Day 34) T. Mesereau end J. Arvizo Cross Examination

JANET ARVIZO CROSS-EXAMINATION (Continued) BY MR. MESEREAU

CROSS-EXAMINATION (Continued) BY MR. MESEREAU:
Q. Ms. Arvizo, throughout January, February, March and April of 2003, you were being
represented by counsel in proceedings related to your ex-husband David, correct?
A. Of what year?
Q. 2003.
A. Yes.
Q. And without going into much of the detail, you were represented by a lawyer who
youve mentioned already named Michael Manning, correct?
A. For what?
Q. For your request for spousal support, your issues involving David Arvizo and your
domestic proceeding, correct?
A. This is correct.
Q. And documents related to your requests for spousal support from David and other
issues related to your divorce were being periodically filed by Attorney Michael Manning,
correct?
A. I dont understand his question very well, but something about spousal support and
child support, that was in effect for already almost -- almost, my best estimate, for almost
three years. We had been wait ing for that court date for years already. Thats my best
estimate.
Q. And how long do you recall Michael Manning representing you?
A. I think, my best estimate, since 2001. I was way at the bottom of his list because I -he was providing his services for free.
MR. MESEREAU: Move to strike.
THE COURT: Stricken after the date.
Q. BY MR. MESEREAU: So would it be accurate to say, based on what you remember,
Attorney Michael Mann ing was representing you in 2001, 2002, 2003, and 2004 on issues
related to your ex-husband?
A. Yes.
Q. And various income and expense declarations, various declarations, various documents
were periodically being filed with the court by Attorney Manning on your behalf, right?
A. If I clearly -- if I understand his question, I think with Mr. Manning, that was handled in
a bulk, and I think it was probably in the first meeting that I had ever met with him, and I
held onto those things. Thats the best I can remember. So he did it when he had time
because, like I said, I was at the bottom of his list.
Q. Would it be accurate to say that this lawyer filed documents on your behalf on October
15th, 2001, October 16th, 2001, November 6th, 2001, January 10th, 2002, April of 2002,
June 25th, 2002, January 6th, 2003, January 23rd, 2003, March 5th, 2003, and that there
was a hearing on March 11th, 2003, involving your issues with David? Does that sound
accurate to you?
A. I dont know what hes trying to say. But like I said, in the init ial meet ing with him, to
the best of my recollection, it was handled like in a package, he had like a package
already made. So when he had time, he went ahead and took care of it himself. Because

he made me aware, since he was doing it for free, it was as he could, so I had to be
patient.
Q. Would it refresh your recollection if I just showed you all those filed documents that
were filed with the court?
A. Yes. He filed them accordingly to when he had time, because I was not a paying
customer.
MR. MESEREAU: Move to strike.
THE COURT: After Yes, Ill strike.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. MESEREAU: Miss Arvizo, have you had a chance to look at those court
documents?
A. Just the date on them, the same ones he just said.
Q. Do they refresh your recollection that your attorney was filing documents throughout
those years on your behalf?
A. Like I said, he went -- according to when he had time, yes, thats correct.
Q. All of those years, this attorney was representing you in your domestic problems with
your ex-husband David, right?
A. Yes.
Q. Okay. I think it goes without saying that this lawyer was representing you during the
time period you claim you were being harassed and falsely imprisoned by Mr. Jacksons
associates, correct?
A. Yes.
Q. And I think youve already said, you never told this lawyer at any t ime that anyone in
your family was being held against their will, correct?
A. Are you -- is that attorney-client privilege? Because hes still my attorney.
Q. If youre asserting the privilege, I will not ask any further into that.
A. Yes, please.
Q. Okay. Is Attorney Michael Manning still representing you?
A. No, hes not.
Q. Okay. Now, you indicated to the jury that this attorney was representing you for free;
is that correct?
A. Yes, this is correct.
Q. Didnt your attorney at one point file documents with the court asking that your ex husband pay your fees?
A. Yes, this is correct.
Q. Now, in the -- just to set the record straight on dates, it appears that your divorce
action was filed October 15th, 2001. Does that make sense to you?
A. The best I can remember is after David was arrested and the first day he presented
himself at the criminal courts is when Michael Manning handed him already the documents
for divorce.
Q. Okay.
A. Thats the best I can remember how it happened.
Q. And do you recall approximately when he was first arrested?
A. I think he was arrested either the end of September -- I think my best estimate is the
end of September, but it could have possibly been the beginning of October. But the best I
can remember is the end of September.
Q. Now, on October 4th, 2001, you went to the Hollenbeck Division with Davellin, Star,

and Gavin to report problems with David, right?

A. The Hollenbeck Division is composed of two different separate buildings. The
Hollenbeck Police
Department is a separate building from the Hollenbeck detective center. And if you walk
there, its quite a distance. But on car, its quite fast. And theres even, I think, a bridge, a
freeway bridge that separates both things, and theyre even on separate side of the
buildings. Separate side of the street, I mean.
Q. And you know that police department quite well, correct?
A. Ive never gone to the police department. Ive only gone to the detective center.
Q. And on October 4th, 2001, you did go to the Hollenbeck detective section, correct?
A. I dont remember the date, but I do remember the event.
Q. Would it refresh your recollection if I just show you a report to refresh your memory on
the 6551 date?
A. If you say the dates on there, then that should be correct. That should be accurate.
Q. I cant testify. Can I just show it to you?
A. Well, if its on the paper, its correct.
Q. Okay. Would it refresh your recollection if I just show it to you?
A. Okay. Come on over.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes. But, Counsel, shes conceded the date. So what are you doing?
MR. MESEREAU: If the Court permits, Ill just read the date into the record.
MR. ZONEN: Your Honor, Ill stipulate to the date as being the date of the event.
THE COURT: Without stipulation, shes conceded whatever date is on there is accurate. So
lets move along.
MR. MESEREAU: Yes, Your Honor.
Q. The date on the report is October 4th, 2001.
A. Okay.
Q. And you recall going to the detective divis ion to speak about your problems with David,
correct?
A. Yes. The detective there had invited me, if I wanted to come on over, to come on over,
because our phone had been -- our interview had been by the phone. 6552
Q. Now, you got to the detective division and asked to talk to a detective, correct?
A. Yes. I think it was the same one that I had been talking to.
Q. And you told the detective you wanted to show the detective a videotape and
numerous photos of you and your children spending time with various celebrit ies?
A. Yes, because he had a hard time believing that a woman in East L.A. with her children
knew such -- knew -- knew them. And hes a detective, so, you know, he was curious.
Q. Did you bring the photos of celebrities with you?
A. Yes, I did.
Q. And what photos of celebrities did you bring to the detective division of the Hollenbeck
Division?
A. I think it was -- I think it was mostly of Chris. Chris and Aja.
Q. And according to the detective, you laughed and appeared happy at the meeting,
correct?
A. Yes, because finally me and my children are getting some sense of freedom.
Q. It says you seemed happy as you showed him informat ion about various celebrities,
correct?
A. Well, it was a video of Chris and the children together. And Aja.

Q. Now, before you testified has anyone showed you any police reports to review?
A. Yes, they have shown them to me.
Q. And whos they?
A. The D.A.s Office.
Q. Okay. And when did they do that, approximately?
A. Approximately, probably -- I think it was days ago, yes.
Q. Okay. Did you meet over the weekend with anyone from the prosecution?
A. Yes, I did.
Q. Who was that?
A. Mr. Zonen.
Q. And when did you meet Mr. Zonen?
A. Yesterday, with a detective present.
Q. And did you go over documents?
A. No.
Q. Did you talk about your testimony?
A. Yes.
Q. How long was the meeting?
A. With me? Probably about -- about ten minutes.
Q. Okay. And the whole meeting was ten minutes?
A. Yes.
Q. Okay. And where did it take p lace?
A. At -- in -Q. Dont give your address if its your home. Just say its, you know, at a residence.
A. No. Are you okay?
BAILIFF CORTEZ: I apologize.
THE WITNESS: I dont know what you -Q. BY MR. MESEREAU: Was it at a residence?
A. No. No, it wasnt.
Q. Was it at an office?
MR. ZONEN: Ill object to the location, Your Honor.
THE COURT: Hes just trying to get a general statement. Its overruled. You may answer.
THE WITNESS: Where Im staying.
Q. BY MR. MESEREAU: Okay. Okay. And they came to see you?
A. Yes.
Q. And the meeting was only ten minutes?
A. It was ten minutes.
Q. Okay.
A. I think he must have been on his way back to the office, I guess.
Q. Okay. In your -- in one of your domestic vio lence disputes with David, do you
remember signing a declaration that your children -- your boys sleep with baseball bats
because theyre afraid of David?
A. Yes.
Q. And was that true?
A. Yes.
Q. Okay. And when did your boys begin sleeping with baseball bats, if you know?
A. To the best that I can remember, its when David and Mr. Halpern, his attorney, were
making the -- parading on the circuitry of the T.V., you know, making their rounds on T.V.
And so it resurfaced a lot of things that they had been already feeling. But it intensified in

2003.
Q. So because of the T.V. appearances by David and his lawyer, your sons began sleeping
with baseball bats; is that what youre saying?
A. It began then. It began. Its the best I can remember.
Q. Now, did the -- now, excuse me, did you say a prosecutor showed you various police
reports?
A. Not yesterday.
Q. Not yesterday?
A. No.
Q. But at some point?
A. Yes. Yes.
Q. Did the prosecutor show you another police report where you reported David for
domestic vio lence and told the police that Michael Jackson, Kobe Bryant and Fritz Coleman
are going to help you?
A. Thats because David was calling me whore, and he said -- David said that he was
going to tell everybody that I had sex with them. And so if they wanted to do that, they
can go verify with them that Im not having sex with any of those people. Q. That wasnt
in your police interview, was it?
A. I did speak to the detective about it.
Q. So when you told the detective, Michael Jackson, Kobe Bryant and Fritz Coleman are
going to help me in my action against David, thats what you were referring to?
A. Not action against David. That they can go ask basically them themself that Im not
having sex with them.
Q. Okay. But youve seen the report, and nowhere in the report does it ever say that you
told the police officers that there are accusations that, Im having sex with these
celebrit ies, correct?
A. Well, I dont think thats considered a crime.
Q. So when the police officer just mentions that quote, in your mind you should have also
said, I told him the reason for the quote was that there were false accusations about me
having sex with these celebrities, correct?
MR. ZONEN: Ill object. That question is ambiguous.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Had you ever told Michael Jackson anything about your domestic
problems with David?
A. No.
Q. Had you ever told Kobe Bryant anything about your domestic problems with David?
A. No.
Q. Had you told Fritz Coleman anything about your domestic problems with David?
A. No.
Q. And again, in looking at the report, you know that theres nothing in that report about
these false accusations of sex, you know that, correct?
MR. ZONEN: Objection; asked and answered.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Do you know that?
A. I dont think it was considered a crime.
Q. Would it refresh your recollection just to see the report?
A. I dont need to see the report. Im telling you thats what happened and thats it.
Q. Okay. Now, you had a hearing -- excuse me let me rephrase that better. Based on

reports you made to the police, David Arvizo was charged with domestic violence a couple
of times, right?
A. I dont know what youre talking about. What -Q. Ill be happy to rephrase. Based on accusations you made about David Arvizo being
abusive and violent, he was prosecuted, right?
A. I dont under -MR. ZONEN: Ill object as speculative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you recall David Arvizo being prosecuted for crimes related to
domestic vio lence?
A. Yes.
Q. And as far as you know, why was he prosecuted?
A. Because he did the crime.
Q. And was he reported for those crimes, to your knowledge?
A. He was investigated.
Q. And do you know how the investigations began?
A. Yes, because the best I can remember is I was outside getting beat up and some
children called the police.
Q. Now, do you recall, in -- excuse me. At some point you spoke to a city attorney,
correct, from the Los Angeles County City Attorneys Office, correct?
A. Okay. Which case are we talking about?
Q. One of your domestic -- one of the domestic violence cases that were filed against your
ex-husband David. Do you recall talking to someone named Soriano?
A. Okay, yes.
Q. Okay. And do you recall talking to Mr. Soriano about a photograph that had you holding
a knife? Do you remember that?
A. I didnt talk to him about it. He asked me, because David and Mr. Halpern, the ones
that theyve sold to the tabloids, presented it to me.
Q. And you didnt deny there was a photo of you with a knife like this, right?
A. Of course there was.
Q. And you had an explanation for that photograph, right?
A. Of course.
Q. And please tell the jury what that explanation is.
A. In the tabloids they have blurted out -- well, they phased out the running -- I think it
was running water, dishes -- full of dishes in the sink, my son sitting in the background
doing his homework. I was washing the dishes at the time. And David had asked me, he
goes, Hey, Janets like the movie. This is the best I can remember. And he said, Here,
and it was all done in jokingly, and he snapped a picture. Well, were talking about one of
those throw-away camera pictures. And my son is clearly in the background doing his
homework, holding up his paperwork. Its the best I can remember.
Q. And you would agree youre photographed with a knife like this?
A. Yes, I am.
Q. And it all is play acting, right?
A. No, it was done jokingly.
Q. Okay. Some other photographs surface of you with something else you were holding,
correct?
A. That was a broom. You know, when you sweep like this from left to right, depending,
yes. And they also -- Mr. Halpern and David also sold that to the tabloids.

Q. And that was meant in jest also, correct, the photo of you with a broom?
A. Those pictures were taken in, hmm, I think -- I think in 1999. The best I can
remember. 1999. No, goodness, I think 1998, actually. Seven years ago. That is the best
I can remember.
Q. Now, around October 16th of 2001, you filed documents with the Superior Court
through your attorney, Michael Manning, in which you claimed David had threatened to kill
you and the kids, right?
A. I dont think its the word -- the way youre saying it is word for word. But David,
many, many years, had already threatened me. A lways.
Q. And didnt you say in documents filed with the court David said he would kill you and
the kids?
A. I think what is -- I dont think hes saying it word for word. But David had always
threatened me and the kids, always.
Q. Did he threaten you with death?
A. He always would.
Q. And you indicated that David said that if you cause him trouble, he would have one of
Rays, his brother, people kill you and the kids, right?
A. Yes. David had said that for years, many, many years to me.
Q. Who is Ray?
A. Ray is Davids brother, who is a convicted drug dealer.
Q. And did Ray himself ever threaten you and the children?
A. Ray never, never threatened me. It was all per Davids own word.
Q. At some point did you mention in one of your interviews that you had been abused in
your own home growing up?
A. Never.
Q. Okay. Did you ever mention anything about your father being abusive?
A. Absolutely never.
Q. And you didnt tell that to anyone, correct?
A. Never.
Q. Okay. Did all the abuse in your home come from David himself?
A. Always.
Q. Okay. Do you recall the meet ing with Brad Miller at Jay Jacksons residence?
A. I think so.
Q. And do you recall Mr. Miller mentioning to you and Jay Jackson and your family that he
worked for Attorney Mark Geragos, who represented Michael Jackson?
A. No, I didnt recall that. And it wasnt important to me because when he had walked in
at the door, he said he was Michaels private investigator. And also Frank had told me that
Brad Miller was Michaels private investigator. So all that mumbo-jumbo he was saying, it
wasnt brought to my attention until we had a -- here, I was here in this courtroom, and I
think it was September. So hes doing the same thing he did in September.
Q. When -- Move to strike, Your Honor.
THE COURT: Ill strike after, No, I didnt recall that.
Q. BY MR. MESEREAU: When you learned that Brad Miller was an investigator, did it ever
occur to you that you were being investigated?
A. No. Because Frank had told me that he was Michaels private investigator and he was
here to help me and the kids. And I believed him. I believed too much of them.
Q. He said he was an investigator for Mark Geragos in front of Major Jay Jackson, did he
not?

A. Jay repeatedly kept coming in and out of his bedroom.

Q. Did Brad Miller, as far as you remember, ever tell Major Jay Jackson in Major Jay
Jacksons home that he was an investigator for Mark Geragos, who represented Michael
Jackson?
A. No.
Q. Do you recall ever d iscussing with Jay Jackson the fact that Brad Miller was a privat
investigator?
A. No. Its just thats how he introduced himself.
Q. Did you ever discuss with Jay Jackson either before or after that interview who Brad
Miller was?
A. There was no -- I dont know what hes trying -- its so broad, but, the answer to that
question is no, as Im understanding it.
Q. After the interview was completed, did you ever d iscuss with Jay Jackson who Brad
Miller was?
A. No.
Q. And did Jay Jackson ever ask you, Janet, he said hes an investigator. Who is he?
A. No.
Q. Did you ever learn that Asaf worked for Attorney Mark Geragos?
A. On the tape -- on the tape-recorder that Asaf illegally was taping the Child Protective
Services, he also says my son -- I think my son there, Star, asks him, and he points out
that hes Michaels security, or Star asks him, Are you Michaels security? And he clearly
says by his own mouth, Yes.
Q. Did you ever learn that Johnny was a private investigator working with Miller?
A. Johnny told me he was Michaels security.
Q. So it never occurred to you at any time that Attorney Mark Geragos had anyone
investigat ing who you were and who your family was?
A. Well, first of all, why would he have a criminal defense attorney -MR. MESEREAU: Move to strike.
THE WITNESS: -- if theres no criminal investigation under its way?
THE COURT: You may answer that yes or no. Did it occur to you?
THE WITNESS: Can you -MR. MESEREAU: If we could have it read back.
THE W ITNESS: Could you ask it differently? Because I answered you what I thought was
the answer that you were looking for.
Q. BY MR. MESEREAU: Did it ever occur to you that Attorney Mark Geragos had hired
investigators to investigate who you and your family were and what your plans were?
A. Criminal defense attorney, no. Now I know hes a criminal defense attorney. No.
Q. And you never discussed with Major Jackson who these people are and what theyre
doing, correct?
A. No. I believed everything Frank had told me. I believed everything Michael had told me.
I believed them. I trusted them, thats why were here today.
MR. MESEREAU: Move to strike, Your Honor.
THE COURT: Ill strike everything after No.
MR. MESEREAU: At this time, Your Honor, with the Courts permission, wed like to play
the audiotape of the Brad Miller interview, Exhibit 5000.
THE COURT: Would you remind us how long that tape is?
MR. SANGER: Its 34 minutes and 24 seconds.
THE COURT: Are you going to interrupt the tape with questions or just play it again?

MR. MESEREAU: I was going to interrupt with a couple of questions. Not too many.
THE COURT: Cant you just go to the points in the tape that -- instead of having us sit
here 6566 again, listen to that whole tape?
MR. MESEREAU: I can do that, Your Honor.
THE COURT: All right. Do it.
Q. BY MR. MESEREAU: Miss Arvizo, do you recall -- the interview beg ins with Mr. Miller
saying the following: All right. This is a tape-recorded statement conducted with the
Arvizo family, conducted by Brad Miller. Today is Sunday, February 16th, 2003. Its now
9:47 p.m. on that evening. And as I told you, my name is Brad Miller. Im a licensed
private investigator working on behalf of the Law Firm of Geragos & Geragos, specifically
for an attorney by the name of Mark G eragos, who is an attorney for Michael Jackson. And
this conversation is being tape-recorded with your permission, correct, Janet? And your
answer is, Yes. Do you recall Mr. Miller telling you he worked for Mark Geragos?
A. In September it was brought to my attention, this mumbo-jumbo. Up to that point I
had only believed he was Michaels private investigator.
Q. Do you recall towards the end of that recorded interview, Mr. Miller asks you the
following: A ll right. Well, I thank you guys. I think this has been very helpful. So lets
wrap this up. Its now about 10:25, Sunday night, February 16th, 2003. As Ive told you,
my name is Brad Miller. Im a private investigator working on behalf of Mark Geragos,
whos an attorney for Michael Jackson. And this conversation has been tape-recorded with
your permission, correct, Janet? Answer, by you, Yes. Do you recall that?
A. I didnt pay attention to that.
THE COURT: Counsel, do we have a transcript yet for that?
MR. MESEREAU: Yes, we do, Your Honor. I dont think weve lodged it with the Court, but
we do have one.
THE COURT: Would you lodge it with the Court, please?
MR. MESEREAU: Ill see if I can -THE COURT: Later today is fine.
MR. MESEREAU: Okay. Yes, we will.
Q. Where was Jay -- excuse me, where was Major Jay Jackson during that interview?
A. My husband -- in the beginning, we were just -- it was a new relationship. And at that
point I think he must have been in his bedroom, because you saw him kind of detached,
what was going on.
MR. MESEREAU: Move to strike, Your Honor.
THE COURT: Stricken. You just need to answer the question. Listen to it carefully, and
then just answer the question. Dont volunteer additional informat ion. Would you -- do
you want to restate it or do you want the court reporter to read it back?
MR. MESEREAU: If the court reporter would read it back, Id appreciate it. Thank you.
(Record read.)
THE WITNESS: The majority of the time, in his bedroom.
Q. BY MR. MESEREAU: Do you recall Major Jay Jackson sitting during the majority of that
interview on the couch?
A. The majority of that interview he was in h is bedroom.
Q. Now, is it your -- let me rephrase that. Are you claiming that what you said in this
interview on February 16th, 2003, was scripted?
A. I already told him before. Everything that was on the Bradley Miller audiotape was from
my heart, from the initial lovey-dovey meeting that I had in Miami. I believed him and I
trusted him. So, its -- the best I can say, its most -- its all accurate.

Q. You were asked by Mr. Miller, What was Mr.Jacksons role in his recovery? referring to
Gavin and his cancer. Do you remember that?
A. Uh-huh.
Q. And you said, Like a father, like a father to him. Do you remember that? 6569
A. Yes.
Q. Brad Miller said to you, What would Michael do? And your answer was, Everything a
loving father, unselfish, kind, then inaudib le, exhib its unconditional love, correct?
A. All of the Bradley Miller audiotape, its all correct and accurate. Thats how I felt.
Q. Now, your son Gavin also spoke in that interview, correct?
A. Yes.
Q. And as far as you know, he was telling the truth, right?
A. Theres -- there was a few times that I had stepped out, because I was feeling a little
bit concerned as to why and -- how Jay was feeling, because it was a new relationship
with me that I was beginning with Jay, so I was getting a little concerned as to why Jay
kept coming in and out. So theres periods in there that Im not present when theres
being audiotape.
Q. Gavin said that Michael would always put a smile on his face. Do you remember that?
A. I have since read the -- the transcript of the audiotape. And like I said, everything
there is accurate. Everything there is correct. Thats how they were feeling at that
moment and at that time.
Q. And you were there when Gavin said Michael didnt come to the hospital but he would
call him on the phone, correct?
A. Pardon me?
Q. You were present at the interview when Gavin said Michael d idnt come to the hospital.
He would call on the phone, right?
A. Yes. He did -- Michael never once came to the hospital. But there was long hours of
conversations, hours and hours.
Q. And you said in that interview, And thats one thing the role Michael was, he wasnt
just a father figure to Gavin, he also was to Star and Davellin, because he knew that all
three of them needed him and he was -- um, is family to me. And he also realized that I
needed him. Correct?
A. Yes. This is stemming from the initial meet ing that I had in Miami that he gave me a
reinterpretation of what his role was. This is from Michael in Miami.
Q. So this is from your heart and its the truth, correct?
A. Yes, it is. It is.
Q. You talked about David being charged with child endangerment and terrorist threats,
right?
A. If thats on there, yes.
Q. Would it refresh your recollection? I can show it to you.
A. Yes.
Q. And Davellin said that David had broken her tailbone, correct?
A. Yes, he had.
Q. And that was true, correct?
A. Yes. Yes. With his big old foot. Kicked her right -Q. Gavin said that David hit him during his cancer treatment?
A. Oh, yes.
Q. And that was also true, right?
A. Yes.

Q. And Star said that David hit him where he has a cyst, correct?
A. Yes.
Q. You said that David would even abuse the dog, right?
A. Yes. He hurt many of our little animals.
Q. You mentioned a ferret and a dog, right?
A. Yes.
Q. Okay.
A. Yeah.
Q. You talked about, They had filmed -- when they had filmed the beautiful story about
Michael and my son, David was there present. Do you remember that?
A. Yes. Yes.
Q. What were you referring to when you talked about the beautiful story about Michael
and my son?
A. It was the DVD thats titled Michael and Gavin. I had never seen it prior to this time,
but Michael had informed me that it was a beaut iful story. So this is a -- all stemming
from the Miami meet ing, that 45-minute lovey-dovey meeting that I had with Michael.
Q. So when you talked about the beautiful story, you hadnt seen it; is that true?
A. I had never seen it prior to Gary giving it to Evvy -- I mean Evvy giving it to Gary and
Gary giving it to us.
Q. You said that David was mad one day because you and Michael were dancing, right?
A. Yes. And this was -- this was Davids character. You know, I couldnt wear makeup.
Couldnt shave my legs. You know, just different things. So, yes, it was a -- I was happy
to see Gavin dancing, because Gavin at that point had like a toddler walk. And, to me,
that made me happy. And we were at a 20-foot distance and yet I still got beat up for
that.
Q. But you said that, Me and Michael were dancing, correct?
A. Yes, me, Michael, the children. You dont take it out of context or make it dirty. He was
-- me, Michael, the children, other guests there. It 6573 was inside this -- what is it? -bumper cars area, and they have the ab ility to play the music really loud, so -- and thats
what -- thats just what it was all about.
MR. MESEREAU: Move to strike the comments, Your Honor.
THE COURT: Denied.
Q. BY MR. MESEREAU: Where were you and Michael dancing?
A. It was inside, just the children, me, Michael and other guests there, under a tent in the
bumper car area.
Q. And when did this happen?
A. That happened in the initial meeting in August of 2000. And I was happy to see that
Gavin was actually trying to dance. He wasnt able to dance. But because he had a toddler
walk, to me, that was a big step.
Q. Did you tell the jury last week you had never had a conversation with Michael Jackson
until Miami?
A. Yes, I never had a conversation with Michael. Michael didnt talk to me in the initial vis it
with him.
Q. You danced with him, but you never talked to him?
A. Thats right. It wasnt me and him solely under the blue sky night. It was me, him, my
children, other guests, under a tent in the bumper car area, which they had the ability to
play the music really loud.
Q. The first time you visited Neverland, do you recall having dinner in the main house at

Neverland?
A. Yes.
Q. Do you recall Michael Jackson being there?
A. Yes.
Q. Do you recall a discussion about where Gavin was going to sleep?
A. It wasnt a discussion with me. It was a discussion with David.
Q. And approximately when d id that dinner take place?
A. Dinnertime.
Q. Approximate month and year?
A. Approximate, August 2000.
Q. And you never spoke to Michael Jackson at that dinner table?
A. No. David was present.
Q. How long did the dinner last?
A. I guess maybe -- maybe 20 minutes worth. Maybe.
Q. Getting back to the Brad Miller recording, you said the following: In my observance
and their interaction, and Gavin with Michael and Star, with Michael and Davellin, with
Michael is that, as a father figure, he provides for them. He provides 6575 them with a
sense of humor. Hes very funny. And a sense of direction and guidance. And you meant
what you were saying, correct?
A. Yes, I did. This is my observance of what I saw in Miami. But now I know different what
was happening and I was -- and I was clueless.
MR. MESEREAU: Move to strike the comments.
THE COURT: Ill strike after Yes, I did.
Q. BY MR. MESEREAU: You said, Michaels everything that an ultimate father is, and
thats what the children have always prayed for, is a father, and that God has blessed
them with. And me, Ive always wanted family, so hes family to me. You said that from
your heart, correct?
A. Yes. He put on a good show in Miami.
MR. MESEREAU: Move to strike the comment.
THE COURT: Strike the -- after Yes.
Q. BY MR. MESEREAU: And you said, In being what I endured in 17 years, I would be the
most sensitive to any little thing. And Michael has never, absolutely never, made me feel
in any way, form, shape or matter that anything was anything different other than Gavin
as a son to Michael, Star as a son to Michael, Davellin as a daughter to Michael, and
Michael father, like a father to all three of them. Do you remember saying that?
MR. ZONEN: W hat page are we on? 6576
MR. MESEREAU: 12.
MR. ZONEN: Thank you.
Q. BY MR. MESEREAU: Do you remember saying those words?
A. Yes, and now I realize how stupid I was.
MR. MESEREAU: Move to strike.
THE COURT: Ill strike after, Yes, but whats the point? I mean, on the questions here,
youre asking her whether she said things. Weve heard the tape, we know what she said.
Do you have specific areas you wanted to ask her about?
MR. MESEREAU: Yes, Your Honor.
THE COURT: Getting her to say again that she said those things doesnt seem to be
getting us somewhere here, to me.
MR. MESEREAU: Ill tie it up, Your Honor.

Q. Ms. Arvizo, do you remember telling the jury that you were rehearsing with the people
you refer to as the Germans for the February 20th interview?
A. Yes.
Q. This interview with Brad Miller is February 16th, 2003, correct?
A. Yes.
Q. Youve told the jury it wasnt rehearsed, correct?
A. Thats correct.
Q. Are you saying in the next four days you rehearsed for the February 20th video? 6577
A. Prior to Jesus, it was many times daily in Neverland with Dieter. First it was Ronald,
Dieter, and then it became Dieter hands on. And as you can see, maybe youve -- its
been played approximately five or six times here, and Im sure theres many people that
can recite it now. Imagine me working daily, D ieter hands on, with me and my kids, many
times in one day, how thats possible.
MR. MESEREAU: Move to strike.
THE COURT: Ill ask you just to answer the question again. The question was, Are you
saying in the next four days you rehearsed for the February 20th video? And whats your
answer to that question?
THE WITNESS: It had already done -- been done prior with Dieter on a daily basis.
THE COURT: All right. Ill strike her other answer. Next question.
Q. BY MR. MESEREAU: Youre saying youd rehearsed with Dieter before, but what you
said on this interview with Brad Miller was from the heart, right?
A. Yes.
Q. All right. When did you first meet Jamie Masada?
A. The best I can remember, I think it was -- it was definitely before Gavin became ill.
Q. And how did you meet him?
A. Through -- the best I can remember, it was -- I had seen a flyer at a public school that
was, you know, talking about a comedy camp.
Q. Did you bring your children to Jamie Masadas comedy camp?
A. Yes, I did.
Q. Okay. And did your children attend the comedy camp?
A. Yes. Yes, they did.
Q. Did you attend with them?
A. Yes. Every single time. I did.
Q. Now, do you recall any of your children getting on stage and performing about how
poor your family was?
A. Yes, I do.
Q. And do you recall telling Jamie Masada that your children dove into a fountain for
coins?
A. No.
Q. Do you recall telling George Lopez your children dove into a fountain for coins?
A. No. It may have been David maybe. If theyre saying that, it may have been David.
MR. MESEREAU: Move to strike.
THE COURT: Stricken after No.
Q. BY MR. MESEREAU: Jamie Masada introduced you to various celebrities, right?
A. Not just me, the whole group, the whole -- everybody. Everybody that was attending.
6579
Q. And did you meet various celebrities through Jamie Masada?
A. Yes.

Q. And who did you meet?

A. There were guest comics. And me personally, I d idnt get to meet them. The only
people I did get to meet was -- personally was George Lopez. This is the best I can
remember. Louise Palanker. Fritz Coleman. Sully McCullough. Thats the best I can
remember. Those are the people that I personally met. And of course Chris Tucker and his
fiancee, girlfriend, I dont know how they are now, but thats the best I can remember. Me
personally.
Q. And approximately what month and year was this?
A. The best I can remember, it was all prior to Gavin becoming ill. The only one that we
met after Gavin was ill was Chris Tucker. And with Aja. This is the best I can remember.
But all the other ones that have already came up here, it was prior to Gavin becoming ill.
Q. In your deposition in the J.C. Penney case, and Im referring to December 18th, 2000,
you indicated that you had filed a state disability claim because you were depressed.
Remember that?
A. Um, yes.
Q. You were asked what caused the depression. You said it was not your marriage, I was
just sad about being a nobody. Do you remember that?
A. Im still a nobody.
Q. Would you just answer the question. Isnt that what you said?
A. If its on there, thats correct.
Q. Would it refresh your recollection if I just show you that?
A. There was many things why I was sad. Most of all, the man that I was married that
didnt love me or my kids.
MR. MESEREAU: Move to strike.
THE COURT: Strike that answer. Im not quite sure what the question is at this point,
however.
MR. MESEREAU: Ill rephrase; I can restate it, Your Honor.
Q. You testified under oath, Ms. Arvizo, that you filed a state disability claim because you
were depressed, and when asked why you were depressed, you said, I was sad about
being a nobody, right?
MR. ZONEN: Objection; compound.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember being questioned about why you had filed a
state disability claim?
A. No, I dont. But what hes talking about -MR. ZONEN: Ill object as nonresponsive.
THE COURT: Sustained. 6581
Q. BY MR. MESEREAU: Do you remember filing a state disability claim?
A. Not at that time. It was years and years and years prior to what hes saying now.
Q. Do you remember why you filed that state disability claim?
A. Depression.
Q. And the depression was because you felt you were a nobody, right?
MR. ZONEN: Ill object as irrelevant; immaterial.
THE COURT: Overruled. You may answer.
THE WITNESS: Im still a nobody. But now Im with somebody thats just a regular
person.
MR. MESEREAU: Move to strike, Your Honor. Id just request the witness be asked to
respond to the question.

THE COURT: Ill strike the answer. Are you asking her if thats the reason she gave on the
form?
MR. MESEREAU: In the deposition, Your Honor.
THE COURT: I think you need to make that clear. Its not clear.
MR. MESEREAU: Okay. I will do that.
Q. Ms. Arvizo, in your deposition in the J.C. Penney case on Monday, December 18th,
2000, you had admitted you had filed a state disability claim, correct?
A. Yes. Years prior.
Q. You said you filed a claim for depression, true?
A. Yes.
Q. You were asked if your marriage had caused depression. Do you remember that?
A. No, I dont remember that.
Q. Would it refresh your recollection if I just show you those pages?
A. No. But if its on there, its correct.
Q. You were asked was it your marriage, and your answer was, No, I was just sad about
being a nobody, correct?
A. And Im still a nobody.
Q. In your effort to obtain money in that lawsuit, you didnt want anyone to think you had
had any depression from -- caused by David, correct?
A. Thats incorrect.
Q. When did you last see Brad Miller?
A. When did I last see Brad Miller?
Q. Yes.
A. When he was standing right next to -- next to the camera, in the rebuttal video. Right
there. Heres the camera. Heres Brad Miller. Right there. I think. Thats my best
remember -- my best recollection.
Q. The interview with the DCFS was the morning after the rebuttal video.
A. Oh, thats right. He did come afterwards and -- thats -- go ahead.
Q. Was Brad Miller at the meeting with the representatives of the Department of Children
& Family Services?
A. No, he wasnt present there when they were there.
Q. So was the last time you saw him, that you can recall, where you did the rebuttal
video? Was that the last place you saw him?
A. He did come afterwards, after the lad ies had left. The lad ies were no longer in my
apartment. He d id come afterwards.
Q. Was it your idea to have the DCFS interview at Major Jacksons home?
A. I think so.
Q. Why?
A. I dont remember.
Q. Were you living at Major Jacksons home -A. No.
Q. -- when you had that interview?
A. No.
Q. Did you represent to the social workers from the DCFS that that was your home?
A. No, I told them this was my boyfriends home.
Q. Did you tell him that your children ever stayed there?
A. I did tell them that we vis ited there.
Q. Was your intent to make them think thats where your children lived?

A. Absolutely not. They know where I lived. I lived in East L.A. on Soto Street. They knew
that.
Q. Now, I believe you told the jury that at that interview was someone named Aja Pryor,
correct?
A. Aja Pryor, yes.
Q. And Aja Pryor at the time, as far as you knew, was actor and comedian Chris Tuckers
fiancee, right?
A. At that time thats what I felt. They do have a baby together.
Q. And her baby was there for the interview, right?
A. Yes.
Q. And after the interview was over, you drove somewhere with Aja Pryor, didnt you?
A. Incorrect.
Q. Did you ever drive with Aja Pryor anywhere after the interview?
A. No.
Q. Did Aja Pryor ever drive you to Neverland at any time?
A. No.
Q. How often did you used to talk to Aja Pryor during this time per iod?
A. Often.
Q. Would you call her?
A. Yes.
Q. Would she call you?
A. Were talking about a friendship that had gone on for years. So can you specify the
time period?
Q. Sure. Lets say between January of 2003 and April of 2003.
A. Okay. Prior to Neverland, it was back and forth phone calls. During Neverland, it was -there was no return phone call that she can call me back on.
Q. Do you recall Miss Pryor ever driving your children to Neverland?
A. Yes.
Q. When was that?
A. That was right after the CPS interview, when Asaf had escorted Aja and the children to
the car. And they were being followed.
Q. Did you ask -- Move to strike the comments.
THE COURT: Denied.
Q. BY MR. MESEREAU: Did you ask Miss Pryor to drive your children to Neverland after the
DCFS interview?
A. No.
Q. Do you know why she did that?
A. That was already prearranged.
Q. How was it prearranged?
A. Well, it was already in a conversation prior, per Franks instructions.
Q. Did you ever ask Aja Pryor for the keys to Chris Tuckers car?
A. No.
Q. To your knowledge, did Davellin ever do that?
A. No.
Q. Do you recall ever being in a call with Davellin where you and Davellin asked Aja Pryor
to the keys to Chris Tuckers automobile?
A. No.
Q. Do you recall discussing going to Brazil with Aja Pryor?

A. Like I had told you, remember those conversations that I would have and try to slip
something in? So at the end of the -- all these people could put this puzzle together as to
where me and my children were finally at.
Q. Do you recall telling Aja Pryor that you were excited to go to Brazil?
A. No.
Q. Do you recall invit ing Aja Pryor to go to Carnaval in Brazil with you?
A. No.
Q. Whens the last time you saw Aja Pryor?
A. I think it was the CPS meeting. I think that was the last day.
Q. Id like to ask you some questions about some of the interviews you gave the sheriffs
in Santa Barbara, okay?
A. Okay.
Q. Im just going to go through those interviews. You indicated in one interview that you
were studying to be an orthopedic technologist, correct?
A. Yes.
Q. And was that true?
A. Yes.
Q. And where were you doing that course of study?
A. I was doing that at a vocational school in Orange County.
Q. And what years did you attend there?
A. I attended approximately in 2003.
Q. Did you finish that course?
A. No.
Q. How long did you go to school there?
A. Probably summer and attempted to try to finish fall.
Q. You mentioned to the sheriffs that you knew Carol Lamir, correct?
A. Yes. Thats Davids girlfriend. 6588
Q. Well, before you thought she was Davids girlfriend, you knew her in another capacity,
correct?
A. Yes, David and I both knew her.
Q. And how did you know her?
A. Through -- she doesnt like to call herself grandmother, but she actually is the
grandmother to -- to one of the children that was taking tap dance lessons where my
children were.
Q. And you met her at that school, correct?
A. This is correct.
Q. Okay. Did you stay in touch with her for any length of time after you met her at that
school?
A. David did.
Q. Did Davellin ever stay at her house, to your knowledge?
A. Davellin stood, I think, when Gavin had gotten ill, I think for less than one month. And
I came to find out that all she wanted Davellin was to clean her house. And so I put a stop
to that.
Q. To your knowledge, how many evenings did Davellin stay at Carol Lamirs house?
A. I cant remember. But the best one who could remember that would probably be
Davellin. W ere talking five years ago.
Q. Do you know if she spent weeks there?
A. I dont think so.

Q. Did you often know if she was going to stay there?

A. Of course.
Q. Would she ask your permission to stay there?
A. No, she didnt want to go to her house anymore. And I came to find out is because all
Carol wanted her was to clean her house.
Q. But you dont know approximately how many nights Davellin stayed at Carol Lamirs
home, right?
A. No. Please. My son had cancer, I....
Q. Do you know approximately what year Davellin was staying at Carol Lamirs home?
A. Yes, this was when Gavin had cancer, in 2000.
Q. Did you ever tell Aja Pryor that your family was being held against their will?
A. Yes.
Q. When was this?
A. I think -- I think it was during the hotel period. Thats the best I can remember. I -- I
tried to reach different people.
Q. And you specifically remember telling her that you were being held against your will?
A. Yes.
Q. Do you remember ever asking her to call the police?
A. No. That was another thing I slipped in, and I was always hoping that these people
would call themself. This way the call d idnt come from me. Quick slip-in.
Q. Now, during the DCFS interview, Ajas present at Major Jacksons home with three
social workers from Los Angeles, correct?
A. Yes.
Q. You never say anything about your being held against your will, correct?
A. Thats correct. Because Asaf had already told me -- he already had warned me prior to
them -- the ladies coming in.
Q. You saw Major Jackson when you arrived that morning, correct?
A. Yeah -- I think so. But it was a new relat ionship with Jay, and he was a -- now he has
softened up, but back then was very completely organized.
Q. The first time you visited Neverland, did you tell the jury you didnt know where your
sons were the first evening?
A. Which -- are you talking the police report?
MR. ZONEN: Ill object as vague.
MR. MESEREAU: Ill rephrase it if its unclear.
THE COURT: All right.
Q. BY MR. MESEREAU: The first time you, your husband and your son -- excuse me, you,
your husband and your children visited Neverland, do you remember when that was?
A. Yes.
Q. And approximately when was that?
A. In August of 2000.
Q. Do you remember where your son stayed that first evening?
A. In Michaels house.
Q. How did you know they were staying in Michaels house?
A. Because Gavin had asked.
Q. Did you hear Gavin ask?
A. Yes, I did.
Q. Do you know approximately where he made that request?
A. No, I dont remember.

Q. Did he make that request at the dinner table, to your knowledge?

A. You know, I -- I cant remember that part.
Q. Did you -A. Were talking five years ago.
Q. Did you have any discussion with Michael Jackson about where your sons were going to
stay that evening?
A. I didnt -- he didnt talk to me. I didnt talk to him. It was David talking to Michael.
Q. So as far as you know, the first night you were there, your sons were staying
somewhere in the main house, but you didnt know where, right?
A. This is correct.
Q. And you assumed that David knew where; is that correct?
A. I assumed that children stay with children. Thats what I assumed.
Q. Did you see your sons the next day?
A. Yes.
Q. Did you ask them where they had stayed that evening?
A. No, I didnt. They had told me that they had played, and that was good.
Q. Did you then stay at Neverland a second night?
A. I think so. Yes. Yes, yes.
Q. And was it your belief that your sons stayed in the main house that night?
A. Yes, they did.
Q. Did you see them the next morning?
A. Yes.
Q. Did you ask them where they had spent the evening?
A. No. I didnt -- now I know a lot of things. Now I know -MR. ZONEN: Objection; nonresponsive.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you stay at Neverland a third night during that first visit?
A. I dont remember how many days we stayed there, but I know it was just days. And
thats it. Youre going to walk me through each room -- I mean each door, each day, and I
dont know.
Q. Do you think you stayed more than two nights at Neverland during that first visit?
A. Definitely more than two, but definitely less than -- less than a week. It was just days.
But I cant remember, it was five years ago.
Q. Did you ever at any time ask your sons during that first trip to Neverland where they
had spent the night?
A. No. No, I didnt. But Ive learned things now -MR. ZONEN: Objection; nonresponsive.
THE COURT: Sustained.
MR. MESEREAU: Move to strike.
THE COURT: Stricken.
Q. BY MR. MESEREAU: In one of your initial interviews with the sheriffs, you talked about
Michael Jackson giving a big g ift for Gavin, which was a car, correct?
A. Yes. It looked exactly like the O.J. Simpson truck.
Q. Was it an SUV?
A. It was -- it was an old car. It looked like just the O.J. Simpson Bronco thing.
Q. It wasnt a Bronco, was it?
A. Oh, no. No. Thats incorrect. Thank you. Youre right. It was a laptop computer. The
truck came afterwards.

Q. Okay. Im focusing on just the truck. Okay?

A. Okay. Because you had mentioned the truck, so -Q. Well, you said it looked like Mr. S impsons Bronco, but it was really a Chevy Blazer,
wasnt it?
A. No. I think it was a Ford Bronco.
Q. At some point, didnt you refuse to return the registration to that car?
A. I didnt have no registration.
Q. Did you ever keep any of the papers associated with that car?
A. No, a VIN number.
Q. Did you ever tell the sheriffs in any interview, I have the papers associated with that
car?
A. I have papers that -- I wrote down the VIN number.
Q. Anything else?
A. No, thats it.
Q. You were upset that that Blazer was returned, werent you?
A. No.
Q. You never were upset?
A. No.
Q. Did you ever think it was wrongfully kept by Mr. Jackson?
A. No. What I thought was wrong is that they wanted Gavin to come back alone to pick it
up, thats what I thought. That was the uneasy part.
Q. Did you ever complain to anyone that,Michael Jackson said he would repair the car
and we never saw it again?
A. No, I didnt complain. That was just information that -- the police wanted to know
every detail, so that was the best I can recall. And were talking about in 2001. This is
four years ago.
Q. Now, at some point, you said that Mr. Jackson gave your son a laptop computer, right?
A. Yes, he did.
Q. And do you know approximately when that was?
A. That was the first visit that we had gone to in August of 2000.
Q. And did you actually see that computer?
A. Yes.
Q. And was that returned at some point also?
A. Yes, it was.
Q. Do you remember telling the sheriffs that you had kept the VIN number and
registration?
A. Okay. Now I know the difference. It was only VIN number. The paperwork of the VIN
number. Thats all.
Q. So when you said reg istration, it was a mistake?
A. Yes. Its VIN number, that big long number.
Q. All right. And you also complained about Michaels people taking the computer back,
correct?
A. No, I didnt complain. I had just made them aware, thats all.
Q. And when you say you made them aware, who were you talking about?
A. The police.
Q. Okay.
A. Because they wanted every detail that I can possibly remember, so it was just
informat ion.

Q. Okay. You never comp lained to any sheriff that the computer had been returned when
it really belonged to Gavin?
A. No. It was informat ion.
Q. Okay.
THE COURT: Counsel?
MR. MESEREAU: Oh, okay.
THE COURT: Take our morning recess THE COURT: Counsel?
MR. MESEREAU: Yes, thank you, Your Honor.
Q. Ms. Arvizo, you mentioned to the sheriffs in one of your initial interviews that Michael
had sent gifts to Gavin, correct?
A. Yes.
Q. And what gifts do you recall Michael Jackson sending to Gavin when Gavin was ill?
A. When Gavin was ill?
Q. Yes.
A. Go through the whole list?
Q. Sure. Whatever you can remember.
A. The best I can remember is the computer, the -- I think it was a Bronco - I just have a
picture of it - white, Christmas gifts, and that was all, when he was sick.
Q. And what -A. Thats the best I can remember.
Q. Do you remember anything being delivered at the hospital for Gavin from Michael
Jackson?
A. Yes, a big gift basket.
Q. Okay. Do you remember toys like Play Station 3, things like that, being delivered to
Gavin for Michael?
A. Okay, I was incorrect in saying Play Station 3. It was a Play Station 2, and that was
during Christmastime.
Q. Is that all the gifts you remember Gavin ever receiving from Michael Jackson?
A. This is the best I can remember, when Gavin was sick.
Q. When Gavin wasnt sick, do you remember other gifts being given?
A. Yes. Michael would send things through -- through like a courier, messenger,
something like that, give baskets, and was saying, I love you, Gavin.
Q. Do you remember telling the sheriffs that when Michael Jackson gave those gifts and
those messages, you assumed he was trying to cure him, because Gavin was ill? Do you
remember saying that?
A. No, I dont think thats exactly correct how youre saying it. But I feel when Gavin was
sick, there were just things that were get-you-well gifts, I guess, I dont know. The only
thing that made me uneasy was -MR. MESEREAU: Objection; move to strike.
THE COURT: Overruled. And you interrupted her answer.
Q. BY MR. MESEREAU: Do you remember telling the sheriffs Michael Jackson would leave
messages at your home for Gavin?
A. Yes. He would leave -- what kind of messages? Phone messages?
Q. Yeah. Hell say things like, Ill never forget you, and things like that, right?
A. Okay. The best I can remember, Gavin had his own private phone number, own
answering machine, because his room had to be sterile. And Michael knew that it was his
private -- private phone line. And thats where Michael would leave the phone messages.
Q. And you told the sheriffs when you were discussing those messages, referring to

Michael Jackson, Hes saying it out in the open. You know, you know, hes saying it
probably because hes ill, trying to cure him. Do rememb er that?
A. Yes. That again is my own cluelessness.
MR. MESEREAU: Move to strike.
THE COURT: The part after Yes? AfterYes, is that -MR. MESEREAU: Yes, Your Honor.
THE COURT: All right. Ill strike it.
Q. BY MR. MESEREAU: Now, you learned at some point that Star, your son Star, had done
a video at Neverland with Mr. Jackson, correct?
A. Yes.
Q. And when did you learn about that video?
A. I think in Miami. Thats when I learned that.
Q. And have you ever seen that video?
A. Ive never seen that video.
Q. Okay. When Star was at Neverland making that video, did he ever d iscuss it with you?
A. No.
Q. Youve described your first trip to Neverland, okay? When was your second trip to
Neverland?
A. I think it was the -- Aja and Chriss baby boys birthday party that Aja and Chris took
their -- almost their entire whole family. He had them flown in from Atlanta, Georgia.
Q. And approximately when was that trip?
A. That was approximately -- I think it was early September in 2002.
Q. After your first trip to Neverland, your children went back with David on a couple of
occasions, did they not?
A. Not my children. My two boys. They went -- do you want me to say?
Q. Sure.
A. Okay. The initial visit, the best I can remember - always, please, dates, best I can
remember - is August 2000. And then both my boys returned with David to Neverland.
Davellin did not return. Davellin stood with me. So -MR. MESEREAU: Okay. Your Honor, we have lodged with the Court a transcript of the Brad
Miller interview, and I believe its Exhibit.
THE COURT: Thank you.
THE CLERK: Is it received into evidence?
THE COURT: No.
Q. BY MR. MESEREAU: During -- let me get this straight now. You went the first time with
David and your children, and there were a couple of times after that that David just took
your sons, correct, to Neverland?
A. It was one other time.
Q. Okay. Was there just one other trip with David and the sons alone?
A. Yes.
Q. All right. And when do you think that was?
A. That was right after, also.
Q. And how long a trip was that, if you remember?
A. The best I remember, it was also -- it was also days.
Q. Do you know where your sons stayed, during that trip, in the evening?
A. No, I dont. The best -- you can probably ask the boys.
Q. Did you ever ask them yourself where they had stayed during that next trip with
David?

A. No.
Q. Did you ever ask David where they had stayed during that trip?
A. No.
Q. Before 2003, how many times did you personally visit Neverland?
A. Before 2003?
Q. Yes.
A. Before 2003, best I can remember was the init ial visit that I went. I think it was August
2000. And then with Chris and Ajas baby boys birthday party in early September 2002.
Q. Now, during Chris and Ajas birthday party,Mr. Jackson was not present, right?
A. Yes. Mr. Jackson was not present.
Q. And did you stay in the guest quarters?
A. Not at all. It was only a day visit. It was a birthday party. Thats all it was.
Q. You came in that morning and left that evening?
A. Yes.
Q. Now, at some point your children are at Neverland when the Bashir documentary was
filmed, right?
A. Yes.
Q. And do you recall approximately when that was?
A. Approximately -- this is the best I can remember. Gavin had done -- had a biopsy done
on his kidney. Then the baby boys birthday party. And then the film that I now know -am aware of.
Q. How did your children get to Neverland when the Bashir documentary was filmed, if
you know?
A. Yes. Michael p icked them up from my East L.A. apartment. He had a driver, and then
they went over there. They stood the night, and they came the next day.
Q. Did Chris Tucker introduce you to other celebrit ies?
A. No. Not me. David, yes. And the children.
Q. To your knowledge, what celebrit ies did Chris Tucker introduce David to?
A. I dont know.
Q. To your knowledge, what celebrit ies did Chris Tucker introduce your children to?
A. I think one of them was Jackie Chan. And thats the best that Im aware of. Thats it.
Q. Do you recall Chris Tucker introducing your children to Mike Tyson?
A. Oh, thats correct. Yes. Chris took the children to Mike Tysons house.
Q. Now, was it in Las Vegas?
A. Yes, this was in Las Vegas.
Q. Were you there during that trip?
A. Theres actually more than one trip there.
Q. Okay. Did you take more than one trip to Las Vegas with Chris Tucker?
A. No.
Q. Did you take any trips to Las Vegas with Chris Tucker?
A. One.
Q. Was that the trip when your children met Mike Tyson?
A. No.
Q. Did you ever meet Mike Tyson?
A. Never.
Q. Okay. Did you at some point meet Louise Palanker?
A. Yes, I did.
Q. And where did you meet Louise Palanker?

A. Through the comedy camp. Through Jamie.

Q. At some point do you recall Louise Palanker writing a check for $10,000 to you?
A. What time period are we talking about? At any time?
Q. Sure.
A. This was when Gavin had become ill.
Q. And do you recall that check being written to Janet Arvizo?
A. Yes, I became aware of that.
Q. And do you recall it being deposited into your mothers account?
A. It was cashed through my moms account.
Q. Did you cash that check?
A. No.
Q. Did you endorse that check?
A. Yes, I think I did.
Q. Okay. And do you recall at some point a second $10,000 check being written by Louise
Palanker to David Arvizo?
A. Yes, I did.
Q. And do you recall that check being deposited into your mothers account?
A. It was cashed through my moms account.
Q. At that point in time, did you have any bank account?
A. At that point in time, no, I didnt.
Q. At that point in time did David have any bank accounts?
A. No, he didnt. Well, actually, I think -- no. The best I can remember, no, I dont think
so. I dont know.
Q. At that point in time, had you set up any bank account for Gavins benefit?
A. No.
Q. At some point did you set up a bank account for Gavins benefit?
A. Yes, I think so.
Q. Do you know when that was?
A. I think that was in -- the best I can remember, maybe October. Maybe November.
Thats the best I can remember.
Q. And did you personally deposit money into that account?
A. Yes.
Q. And was that money that you raised at The Laugh Factory?
A. No.
Q. Was that money that you got from fund-raisers for Gavin?
A. With -- attached to The Laugh Factory?
Q. No. Let me rephrase the question. The money that you deposited into the account you
set up for Gavin, do you remember that account?
A. I -- I dont think I personally deposited things. They were deposited.
Q. Okay. That was an account set up at -- was it Washington Mutual?
A. Yes.
Q. And that was across from The Laugh Factory, wasnt it?
A. Pardon me?
Q. Was that bank near The Laugh Factory?
A. Theres Washington Mutuals everywhere.
Q. Was this particular branch near The Laugh Factory where you opened the account?
A. No, it wasnt.
Q. Where was it?

A. The best I can remember, it was -- it was done, I think, in -- well, near the Hollenbeck
Division.
Q. And you made deposits for the benefit of Gavin, right?
A. I think the majority of them, they were deposited on their own.
Q. So people went to the bank and deposited money on their own into Gavins account?
A. I think so, yes.
Q. Did you ever deposit any money into that account for Gavins benefit?
A. The best I can remember, I dont think so.
Q. All right. Now, when the $10,000 check that Louise Palanker wrote to you was placed
into your mothers account, you say that it was basically -- cash was taken out
immed iately; is that correct?
A. The best I can remember, I think there had to be a wait ing period or something like
that. And then it could be cashed.
Q. And you endorsed the check, right?
A. Yes, I think so.
Q. And did you get some of the money?
A. No, everything was handed to David. David loved having the sense of authority, and I
was like his personal secretary.
Q. So youre saying none of that money went to your benefit, right?
A. It was -- like I said, David had the authority. I was like Davids personal secretary.
Q. Okay. So youre telling the jury that you never spent any of that money for yourself,
correct?
A. Im telling the jury I was as -- like Davids personal secretary.
Q. Did any of that money go to the benefit of Gavin, to your knowledge?
A. I think so.
Q. Do you know so?
A. I think so.
Q. Youre not sure?
A. No, I think so.
Q. Okay. What do you think it went to?
A. I -MR. ZONEN: Objection; asked and answered.
THE COURT: Overruled. You may answer.
THE WITNESS: I think it went to credit cards, to food, to -- just different things. Whatever
David would instruct me to do.
Q. BY MR. MESEREAU: And the second $10,000 check that Louise Palanker wrote was also
-A. I was talking -- I was referring to both.
Q. Okay.
A. So its going to be the same information.
Q. Okay. Let me just go through the second one, make sure. Louise Palanker wrote the
first check for $10,000 to Janet Arvizo. It was deposited for cash, and you believe it was
spent on matters related to Gavin, correct?
A. No. There was -- Louise Palanker, there was no strings attached. It was just to the
family.
Q. And youre not sure whether -- what that was spent on. You think credit cards, right?
A. Were talking five years ago. And the best I can remember, it was to the family, and I
did everything that David instructed me to do.

Q. Let me ask you about the second $10,000 check from Louise Palanker.
A. Again, Im lumping both of them. Because it was both the same thing.
Q. So as far as the second $10,000 check goes, you pretty much did what David asked
you to do with the money, right?
A. Thats correct.
Q. All right. And other than credit cards, youre not that sure what it was spent on, right?
A. No.
Q. You think maybe food, right?
A. I think so.
Q. Okay.
A. And whatever David kept for his pocket.
Q. And you never kept any for your pocket, right?
A. No.
Q. Okay. Were you employed at that point?
A. Yes, I was.
Q. And where were you working then?
A. I was a waitress.
Q. Okay. Where was that?
A. The Bonaventure Hotel.
Q. And is that when Gavin was in the hospital?
A. Yes.
Q. Okay. And did you work there full time?
A. Yes, I did.
Q. Okay. Did you learn at some point about some fund-raisers that went on at The Laugh
Factory for the benefit of Gavin?
A. I came to find out everything afterwards.
Q. Did you know those fund-raisers were going on when they actually happened?
A. I dont think so. Were talking five years ago.
Q. So youre not sure whether you knew they were even going on when they happened,
right?
A. No, I would find out afterwards.
Q. Now, were you in touch with Jamie Masada at this point in time?
A. Just a little bit.
Q. Was he a friend of yours at that point in time?
A. Yes, he is a friend of mine. And he was a friend of mine at that point.
Q. And he still is a friend of yours, right?
A. He still is a friend.
Q. All right. And you had met him when your kids were going through the comedy camp,
right?
A. Yes.
Q. You knew him to have assisted Gavin when Gavin was ill in the hospital, right?
A. Yes.
Q. You were in touch with him at that point in time, right?
A. Yes.
Q. But youre not sure if you knew when these fund-raisers were going on?
A. Thats correct. I would find out afterwards. And not because David told me, but
because Jamie would tell me.
Q. Do you recall Fritz Coleman, the newscaster, help ing with any fund-raiser?

A. No.
Q. Do you recall David -- excuse me. Do you recall George Lopez ever trying to help
Gavin?
A. No.
Q. Knew nothing about that?
A. No.
Q. Okay. Never met with him and thanked him for what he had done for your family?
A. No. I thanked him through Ann Lopez, because Ann Lopez would pray with me on the
phone.
Q. Did you ever meet with George Lopez and give him a g ift and thank him for what he
had done?
A. I had given him a mustard seed faith amulet, because he had told me that he had lost
his key chain, so I had given mine, the one I would carry.
Q. Okay. So when -- excuse me. When any fund-raisers were being planned at The Laugh
Factory for Gavin, you were not involved, right?
A. That is correct.
Q. And Jamie Masada didnt tell you what he was planning, right?
A. This is correct.
Q. Okay. Louise Palanker never told you what she was planning, correct?
A. This is correct.
Q. And you dont even know who attended those fund-raisers, right?
A. This is correct.
Q. Because you never discussed a fund-raiser with Louise Palanker, right?
A. This is correct.
Q. Never d iscussed a fund-raiser with Fritz Coleman, right?
A. This is correct.
Q. And never discussed a fund-raiser with Jamie Masada, right?
A. This is correct.
Q. Do you recall ever speaking to someone at a local newspaper in El Monte about Gavins
illness?
A. Yes.
Q. And who did you speak to about Gavins illness?
A. The best I can remember, I think her name was Christie. And she had expressed to me
-- I felt sorry for her, because she had told me that -- she was an elderly lady and she
was trying to start a new career and -- start a career in journalism, because she never
had had the chance. So when she expressed herself like that, I went ahead and spoke to
her about my sons illness.
Q. So you were really doing her a favor is what youre saying.
MR. ZONEN: Objection; argumentat ive.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Are you saying you were trying to help this person with her career;
thats why you spoke about Gavin?
MR. ZONEN: Objection. Argumentative and irrelevant.
THE COURT: Just a minute. Ill sustain the objection as argumentative.
Q. BY MR. MESEREAU: Do you recall asking Miss Causer to put an article in her newspaper
so you could raise money for Gavin?
A. I think how this came about, if -- Im trying to understand his question -- was I went
ahead and spoke to her about my sons illness because the editor there is Davids good

friend of his sister, and it was David and his sister that went to this editor and brought this
about. I purely wanted to speak to her only about my sons illness because she had
expressed to me that she was an elderly lady trying to start a new career.
Q. Did you tell this lady that it cost $12,000 per chemo treatment for Gavin?
A. What I told this lady was that it was $1200 for the -- its called Neupogen injections.
Gavin had to have these injections right after chemotherapy. So when it appeared that
way, it was a typo. They added an extra zero, first of all. And then second, I had
expressed to her that continuously were experiencing miracles, and that when -- that
David had went to the -- to the -- where they were processing the Neupogen injections.
They made him aware how much this would cost if it would have came out of anybodys
pocket. But, no, at no time did I say it was costing us a single penny. So I told her
basically that it was a miracle of God that it was being covered.
Q. Youre telling the jury that you told her it was $1200 for a treatment, and there was a
typo that said 12,000?
A. No -- thats correct. $1200 for the Neupogen injections, not for the treatment
injections. And if you want to be completely -- thats part of his care.
Q. Did you see the article that appeared in the Mid Valley News?
A. Yes, I did.
Q. And did you ever complain about what was in the article?
A. David said he was going to take care of it, because Davids sister is the editors real
good friend, and Davids sister and the editor and David had -- this is where that had
originated.
Q. You told Miss Causer that several celebrit ies were doing fund-raisers to help pay for
Gavins chemotherapy, d idnt you?
A. I think what I told her was that they were helping. And to me, help meant sitting by
Gavin, feeding him the water -- the cantaloupe, things like that. Thats what I meant by
help.
Q. Did you tell Miss Causer that various celebrities were doing fund-raisers to help pay for
Gavins chemotherapy?
A. No.
Q. Did you complain to Ms. Causer that the first article about Gavin did not mention the
bank account at Washington Mutual?
A. No.
Q. And did you ever complain to Miss Causer about the typo which said chemo cost
12,000 per treatment?
A. David said he was going to take care of it because the editor was Davids sisters good
friend.
Q. Do you recall Miss Causer visiting your address on Ramer Street?
A. She did come to where my sons sterile room was, and that would be my mothers
home.
Q. And do you recall her bring ing a turkey?
A. No, she didnt bring a turkey.
Q. Do you recall anyone from that newspaper ever bring ing you a turkey?
A. No.
Q. And did you ever complain to anyone at that newspaper that a turkey wasnt enough.
You wanted, in effect, money?
A. Thats incorrect.
MR. ZONEN: Im going to object as to the content of an article as impeachment.

THE COURT: The objection is overruled. You may answer. She was interrupted. Have the
question read back.
THE WITNESS: I heard -- I remember it. Its incorrect.
Q. BY MR. MESEREAU: You do remember the article appearing, though, right?
A. The one by -- the one that you guys encouraged to be put out there?
Q. No, the one that you encouraged to appear in the Mid Valley News.
A. The one that I helped the lady with, yes. But it didnt say nothing about no turkey
dinner there.
Q. Did you do anything to help arrange for any fund-raisers for Gavin at any t ime?
A. No.
Q. Did you ever ask anyone for any assistance at any time for Gavin?
A. No.
Q. At some point you said to the sheriffs you did not trust Chris Tucker, correct?
A. Hes taking that out of context.
MR. ZONEN: Ill object as irrelevant, the question, and nonresponsive; move to strike.
THE COURT: The objection is overruled.
THE WITNESS: Chris Tucker -THE COURT: Just a moment. Read the question back to her. (Record read.)
THE WITNESS: Thats incorrect. Hes taking it out of context. Chris Tucker is a decent
person. It was in response to afterwards, Chris Tucker was budding around with Michael
afterwards. Thats all that was referring to. I didnt trust, because he may have innocent ly
commun icated something to Michael, and since I already had -- was in the process of
deprogrammiz ing my children from being brainwashed, that I didnt want Chris Tucker to
commun icate something innocent ly to him, and that was it. Chris Tucker has always been
a decent person to my children.
MR. MESEREAU: Move to strike.
THE COURT: After Thats incorrect is stricken.
Q. BY MR. MESEREAU: Now, you indicated at one point that Brett Ratner -- excuse me.
You indicated at one point that Brett Ratner met your family, true?
A. Yes.
Q. And did you personally meet Brett Ratner?
A. I personally didnt -- was not introduced to him, but I knew that he was the director.
Q. And how did you learn who he was?
A. Because Chris Tucker had pointed him out to me; that he was the director.
Q. Have you ever met him to this day?
A. I never was introduced.
Q. Have you ever talked to him on the phone?
A. Ive never talked to him on the telephone.
Q. Okay. Do you know how many fund-raisers took place at The Laugh Factory to help
your family?
A. No.
Q. Do you know, as you sit here today, when any fund-raisers at The Laugh Factory took
place for your family?
A. As I sit here today how many?
Q. Yes.
A. No.
Q. Do you know approximately when any fund-raisers took place at The Laugh Factory for
your family?

A. No.
Q. Did you ever see Jamie Masada at the hospital when Gavin was ill?
A. I think -- I think maybe once. I think maybe once.
Q. And did you ever discuss with Jamie Masada efforts being made to raise money at The
Laugh Factory?
A. No.
Q. Do you recall Fritz Coleman, the newscaster, visit ing your home in East Los Angeles?
A. Yes, I do. This was before my son was ill.
Q. Were you there during the visit?
A. Yes, I was there.
Q. Were you ever aware at any time that Fritz Coleman h ad tried to raise some money for
your family?
A. No.
Q. Whens the last time you saw Fritz Coleman?
A. Let me see. I think the best I can remember was -- I think he was at the hospital and
he was already leaving when I was arriving. I think thats the best I can remember. So it
was a matter of just minutes.
Q. Okay. Did you ever speak to comedian George Lopez about Gavin?
A. Yes.
Q. And approximately when d id you speak to comedian George Lopez about Gavin?
A. I think -- I think when he first became ill, and then the next time when he was visiting
Gavin. And thats -- I gave him the mustard seed amulet key chain.
Q. Did you ever know anything about George Lopez trying to put together a fund-raiser
for Gavin?
A. No.
Q. Did you ever discuss with Louise Palanker ways to raise money for the family?
A. No.
Q. Do you know why Louise Palanker wrote her first $10,000 check to Janet Arvizo?
A. I think thats because David requested that way.
Q. Okay. You dont know for sure, right?
A. Well, I believe Wheezy, because shes the one that wrote the check for the money.
Q. Okay.
A. Wheezy is Louise Palanker.
Q. Were you the signatory on the bank account at Washington Mutual, which was set up
for the benefit of Gavin?
A. What does signatory mean?
Q. Were you the one who would actually -- could sign to withdraw money from the bank?
A. Yes. David requested it that way because David owed his brother in the thousands of
dollars, so he wanted to point out to his brother Ray that I was the one that -- thats it.
Q. Was he a signatory on that account, to your knowledge?
A. No, he wasnt.
Q. Did you ever withdraw any money from the account?
A. Yes, I did.
Q. How much do you think you withdrew?
A. Well, everything that had always been put in.
Q. Do you remember roughly how much was in there at any time?
A. No. I cant remember.
Q. Were there thousands of dollars in there, to your knowledge?

A. There was thousands. And I went ahead and gave all that information to the police and
the D.A.s Office.
Q. Did you ever withdraw any money yourself from that account?
A. Yes, of course I did.
Q. Did you withdraw thousands of dollars from that account?
A. Yes, I sure did.
Q. Was any of that money used for medical expenses?
A. No, there was no need for medical expenses in the hospital, because everything was
covered through Kaiser.
Q. Okay. And were you ever aware that anyone donated money to that account to help
with medical expenses?
A. No.
Q. Now, youve told the jury you told someone at the Mid Valley News about $1200 per
type of treatment, correct?
A. And I was expressing to her that -- that thank God our family is experiencing a lot of
miracles, and that was covered.
Q. And you never mentioned the word chemotherapy to that person, true?
A. I think I did. It was -- it was a little story about my son being ill.
Q. Did you ever mention the cost of chemotherapy to Miss Causer?
MR. ZONEN: Im going to object as asked and answered.
THE COURT: Overruled. You may answer.
THE WITNESS: I think what I was telling her was a story complete about the miracles that
we were experiencing. Thats it.
Q. BY MR. MESEREAU: Did you know the article was going to be published?
A. Yes.
Q. Did you see it when it was published?
A. Yes, I did. And thats when David said he was going to take care of it.
Q. And based on what you read, did you think it was a request for assistance?
A. No.
Q. Okay. Now, did you go with Chris Tucker to Knotts Berry Farm?
A. No.
Q. And did your children?
A. Yes.
Q. Do you know when that was?
A. Yes. They went with Chris, Aja, David and the children.
Q. Do you know approximately when that was?
A. When Gavin was ill.
Q. Were you talking to Aja Pryor on a regular basis at that point?
A. I dont think so.
Q. Okay. When did you start communicating with Aja Pryor on a pretty regular basis?
A. Our friendship -- probably -- it just grew very slowly, to the point where we were -- we
were 6629 speaking almost -- almost maybe a few -- four times a week. But it started out
very slow. Q. D id you ever tell Aja Pryor that all of the money that came from the fundraisers for Gavin was spent on Davids drug habit?
A. I dont think so. It may have -Q. No?
A. It may have probably -- I know the children and I had conversations with her. So -Q. Did you ever tell Aja Pryor that the money from the fund-raisers for Gavin was spent

on Davids drug habit?

A. I dont think so.
Q. Do you know for sure?
A. Im for sure more towards I dont think so.
Q. Isnt it true that after you told Aja Pryor that the money for the fund-raisers was spent
by David on drugs, she went to her bank and got a $600 check for you and the family?
MR. ZONEN: Objection. Compound and assuming facts not in evidence.
THE COURT: Ill sustain the compound.
Q. BY MR. MESEREAU: Do you remember Aja Pryor going to a bank and getting a $600
cashiers check for you and the family?
A. Hes incorrect.
Q. Did she ever do that?
A. Youre letting me answer? Okay. Aja was leaving out of town to Atlanta, Georgia. She
had told me -- I had -- me and the children had bought her, Chris and the baby some
Christmas gifts. Aja then told me, Janet, I dont have time for shopping. Please buy the
children some Christmas gifts. Shes flying out -- out of town to go to Atlanta, Georgia.
And thats what happened.
Q. But you never mentioned to Aja anything about fund-raisers for Gavin, true?
A. No.
Q. You never mentioned to Aja that money from fund-raisers went to support Davids drug
habit?
A. I dont think so.
Q. Do you remember telling Aja that David was taking money from fund-raisers for Gavin?
A. I dont think so.
Q. Do you remember having a d iscussion about fund-raisers for Gavin with anybody?
A. No.
Q. Do you remember receiving any money from Chris Tucker?
A. I became aware of this afterwards, now, through the police investigation, that he had
wired some money into the account.
Q. Which account?
A. The Washington Mutual.
Q. That was the account you were a signatory on, correct?
A. Youve explained signatory. So its still the same meaning the way youre using it,
correct?
Q. Yes, it is.
A. Yes. Yes. Which I withdrew the money and gave it to David.
Q. And youre saying -- telling the jury under oath that you never knew Chris Tucker had
wired that money into that account until the police told you?
A. Thats correct.
Q. Do you know approximately when this was?
A. Now, per the police investigation, I think it was -- I think it was in December or
January. I think it was within those time -- months.
Q. And you had received -A. And at that point, thats when Chris and -- David was going everywhere with Chris.
Q. And thats the point in time where you were associating quite a b it with Aja, right?
A. No, our friendship did not begin with Aja until -- until David was out of the picture. I
hardly even spoke to Aja. My friendship did not begin with her until David was out of the
picture.

Q. And where did the 2,000 from Chris Tucker go, if you know?
A. Well, yeah, I withdrew it and gave it to David, and thats when David had gone to Las
Vegas.
Q. So, to your knowledge, you gave that money to David and it wasnt used for the
benefit of Gavin, right?
A. This is correct.
Q. Do you recall any discussion with Aja or Chris Tucker about your family getting the use
of one of Chriss cars?
A. Okay, say that again.
Q. Do you recall any discussion with Chris Tucker or Aja about your family using one of
Chriss vehicles?
A. Okay. Im -- I dont know what hes asking.
MR. ZONEN: Ill object as nonresponsive, or vague. She doesnt understand the question.
THE COURT: Overruled. Ill have the question read back.
THE WITNESS: Okay. (Record read.)
THE WITNESS: Its incorrect the way hes saying it. Chris -- Aja had her birthday. Chris
had taken the children to go pick out a brand-new Mercedes for Aja. The children picked
out the color for Aja, and Chris went ahead and purchased it. And that was Chriss gift,
birthday gift, to Aja. And so the car that Aja was driving, months later, Chris and Aja gave
it to me and the children for a Christmas gift, but I never have driven it. I dont have it. I
dont have ownership of it. But thats what hes referring to.
Q. BY MR. MESEREAU: Did you ever ask anyone if you could use that car?
A. Never.
Q. Did you ever complain to anyone that you were supposed to be able to own that car?
A. Never.
Q. How did you learn about the car?
A. Well, because Chris had given me the keys and told me, This is a Christmas gift. This
is Ajas old car, but we -- Aja and me want you and the kids to have it, because Aja had
been given for her birthday a brand-new Mercedes.
Q. Didnt you complain to Aja that you had no car to drive?
A. No, I didnt complain to Aja. It was okay for me. I drove -- I was on the bus
continuously.
Q. Did you ever tell Chris you needed a car to drive?
A. Never.
Q. And never told that to Aja either, right?
A. No.
Q. Did you ever know why Chris Tucker would even discuss letting you use his car?
A. He would never let me use his car. Like I said, he gave it to me and the kids as a
Christmas gift, because it was Ajas old car that was just sitting in her driveway. No one
had no -- no need for it.
Q. To your knowledge, did Davellin ever call Aja Pryor on your behalf asking for the keys
to the car?
A. No, Chris had already g iven me the keys.
Q. And you think he just came over there one day and just said, Heres a gift?
MR. ZONEN: Objection; argumentat ive.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know why Mr. Tucker was giving a gift of a car to you?
MR. ZONEN: Objection. Asked and answered and speculative.

THE COURT: Sustained.

Q. BY MR. MESEREAU: Do you recall Davellin telling Aja Pryor words to the effect, I cant
wait until you get another new car. Then I can have the Mercedes? Do you recall that
ever?
A. No.
Q. Do you recall complaining to Aja Pryor about the Germans?
A. Yes. I made her aware. Thats another thing I slipped in. I tried. I tried my best.
Q. You told her you didnt like these German people around Michael Jackson, correct?
A. No.
Q. Well, you did comp lain about them to her, right?
A. I didnt complain. I made her aware. I tried to make d ifferent people aware so me and
my children could get help.
Q. You told Aja Pryor you didnt like the Germans, right?
MR. ZONEN: Objection; asked and answered.
Q. BY MR. MESEREAU: You never complained to Aja Pryor about being held against your
will at any t ime, did you?
MR. ZONEN: I believe there was an objection, Your Honor.
MR. MESEREAU: Oh.
THE COURT: He changed the question, so -THE WITNESS: I made her aware that they were not letting us go.
Q. BY MR. MESEREAU: To your knowledge, did she ever do anything about that?
A. I dont know.
Q. After she drove your children to Neverland, did you speak to her?
A. No.
Q. How did you know your children got to Neverland?
A. Because they had -- Michaels people had tabs on them. They were being followed.
Q. How did you know your children got to Neverland?
A. Because Frank told Vinnie and Vinnie told me.
Q. And did you ever tell it to Aja Pryor after she drove the children?
A. No. On that day, no.
Q. Do you remember telling Mrs. Pryor that you had errands to run and asked her to drive
your children to Neverland?
A. Me?
Q. Yes.
A. No.
Q. Okay. Did you tell Aja Pryor about your friendship with Marie Nicole?
A. Never.
Q. Ever tell Aja Pryor you liked the Cascio children?
A. No.
Q. Ever talk with Aja Pryor about Miko Brando?
A. No.
Q. Do you know who Miko Brando is?
A. Yes.
Q. Who is Miko Brando?
A. He would die for Michael. Thats who he is.
Q. Who is Miko Brando, if you know?
A. I think -MR. ZONEN: Objection; lack of foundation.

THE COURT: Overruled.

MR. ZONEN: And relevance.
THE COURT: Overruled. You may answer.
THE WITNESS: I think I met him once. He had actually came to bring
THE COURT: Just a minute. The question is, who is Miko Brando?
THE WITNESS: Hes one of Michaels damag e control, personnel assistant. He has a lot of
titles.
Q. BY MR. MESEREAU: Do you know if hes related to the late Marlon Brando?
A. This I became aware.
Q. Okay. What did you become aware of?
MR. ZONEN: Ill object as speculative; lack of foundation; and relevance.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you meet Miko Brando at Neverland?
A. Yes. Once.
Q. Approximately when was that?
A. When he came to deliver Mr. Jackson some things.
Q. Was it your understanding he was the son of Marlon Brando?
MR. ZONEN: Objection; asked and answered.
THE WITNESS: At that time, no.
Q. BY MR. MESEREAU: Did you ever have a discussion with -THE COURT: Just a moment. The objection is sustained. The answer is stricken. Next
question.
Q. BY MR. MESEREAU: Did you ever have a discussion with Miko Brando?
A. No.
Q. But you met him, right?
A. Yes.
Q. Okay. And was it your understanding that he worked at Neverland?
MR. ZONEN: Objection; asked and answered.
THE COURT: Overruled. You may answer.
THE WITNESS: Okay. It was my understanding that he had multiple roles, mult iple titles.
One being damage control. Another one, positive PR. Another one personal assistant. He
wore many hats.
Q. BY MR. MESEREAU: Do you remember telling Aja Pryor that you had learned that
Michael Jackson was not going on the Brazil trip?
A. No.
Q. Do you remember ever telling Aja Pryor that once you learned Michael Jackson was not
going on the Brazil trip, you didnt want to go?
A. No.
Q. And its your testimony you never discussed the Brazil trip at any time with Aja?
A. Im -- like I said to different people in the midst of the conversation, I tried to slip
something in as to what was happening.
Q. Do you recall complaining to Aja Pryor that Michael Jackson was making money on the
Maury Povich show and your family was getting nothing?
A. Never.
Q. Do you recall commenting to Mrs. Pryor that a college fund was being set up for Gavin
by Michael Jackson?
A. No.
Q. Do you remember telling Aja Pryor, What good will a college fund do for my son? He

may not be alive in ten years? Do you remember saying that?

A. No.
Q. Do you remember telling Aja Pryor that you had not signed releases for the rebuttal
video?
A. Hes incorrect. No.
Q. Did you ever discuss the rebuttal video with Aja Pryor?
A. No.
Q. Ever complain to Aja Pryor that phone calls were being monitored at Neverland?
A. I informed her that the phone calls were being monitored. Like I said, I tried to make
people aware of what really was happening in there.
Q. Did you make your lawyer, Michael Mann ing aware at any time?
A. Yes, I did.
Q. Michael Manning never called the police, right?
A. Thats right.
MR. ZONEN: Objection; lack of foundation.
THE COURT: Sustained. The answers stricken.
Q. BY MR. MESEREAU: Did you ask Louise Palanker if you could meet her at a Vons?
A. I think I did. Thats when I was in a period of -- a period -- in the Calabasas period.
Q. Did you ask Louise Palanker if you can meet her at her home?
A. I think I did. I was trying anything possible to leave the grasp of him and his people.
Q. Do you know when you first met Bill Dickerman, the attorney?
A. I think I met him approximately -- the best I can remember is the 25th, because it was
the same day that I had that visit, and it was on the way to over there.
Q. Do you remember comp laining to Aja Pryor that you were being kept away from
Michael Jackson?
A. No.
Q. Did you ever complain to her that the Germans were keeping you away from Michael
Jackson?
A. No. What I was telling her was that they were keep ing -- maybe youre taking that out
of context; that I wasnt able to see my children anymore.
Q. Did you ever complain to anyone that the people around Michael Jackson were
separating Mr. Jackson from you and your family?
A. No, no. They were separating me from my children. By the end, I had no control of my
kids anymore. I had lost them.
MR. MESEREAU: Move to strike.
THE COURT: Denied.
THE WITNESS: Your Honor? Im sorry, but I have to go to the rest room.
THE COURT: All right.
THE WITNESS: Ive been holding it here.
THE COURT: All right. Would you take her back there?
MR. MESEREAU: Can Mr. Jackson go as well?
THE COURT: Were not taking a break. Just to the witness. Lets see, Mr. Mesereau,
maybe someone from the District Attorney on the hard drives, if youll approach the
bench. Maybe we could discuss that for a moment.
MESEREAU: If I could, Your Honor, Mr. Sanger would -COURT: Yes. Whoever. Thats fine. (Discussion held off the record at sidebar.)
WITNESS: Thank you.
COURT: Are you ready?

WITNESS: Thank you.

COURT: Excuse me. Go ahead, Mr. Mesereau.
MESEREAU: Thank you, Your Honor.
Q. Ms. Arvizo, to this date, have you ever watched the Maury Povich rebuttal video?
A. No.
Q. Ever discussed it with anybody?
A. No.
Q. And did I hear you correctly that you said you had never actually watched the entire
Bashir documentary?
A. Thats correct. In Miami I wanted to see it. Now I dont want to see it.
Q. Did you ever discuss the Bashir documentary with anyone?
A. No.
Q. Now, you indicated that you saw Mr. Jackson licking your sons head on a plane, right?
A. Yes. This is correct.
Q. And you told the jury you at first did not believe what you were seeing, right?
A. Yes.
Q. After that flight, did you ever allow your children back to Neverland?
A. Yes.
Q. How many times?
A. Well, the whole ent ire time until we permanently left in March.
Q. If you can recall, how many times did you let your children go back to Neverland after
you claim you saw your sons head being licked?
A. The whole entire time until March.
Q. And how many times would that be, back and forth?
A. The best -- I cant remember, but weve already walked through that.
Q. Do you think it was four times you let your children go back to Neverland?
A. They were there the whole entire time except for that time that Jesus had taken us out.
Poor judgment on my part.
MESEREAU: Move to strike.
WITNESS: I know now.
COURT: Just a moment. Strike the last sentence. Go ahead.
Q. BY MR. MESEREAU: Would it be safe to say youre not sure how many times your kids
returned to Neverland after the head-licking incident?
A. The only time my children were out -- out of their grasp was when Jesus had let -taken me and my children to my moms house. But the rest of the time, they were -- even
if they were outside, Michaels people were still on my children. So if you want to get very
specific, my children only made it out of there once. Because all the other entire time,
Michaels people were on them.
Q. How many times did they go back and forth to Neverland after
ZONEN: Objection; asked and answered.
COURT: He wasnt allowed to finish his question. Go ahead, Counsel.
Q. BY MR. MESEREAU: Did your children go back and forth to Neverland after the Jesus
incident?
ZONEN: Objection; asked and answered.
COURT: Overruled. You may answer.
WITNESS: Okay. Except for that time with Jesus, the rest of the entire time, Michaels
people were on my children.
Q. BY MR. MESEREAU: When did you first learn that Gavin claimed hed been drinking

alcohol at Neverland?
A. The day I never went back. Thats the day. And its burned in here.
MR. MESEREAU: Move to strike.
THE COURT: Denied.
Q. BY MR. MESEREAU: Do you know what day that was?
A. Yes. I will never forget the date. It was March 10th. 4 a.m., to be exact.
Q. You had never had any indication that Gavin had ever touched alcohol before that day,
correct?
A. This is correct. I know different now.
MESEREAU: Move to strike.
COURT: Strike the last sentence.
Q. BY MR. MESEREAU: Do you remember telling the Santa Barbara sheriffs in an
interview, Theres plenty of police out there that can protect my kids?
A. Hes -ZONEN: Vague as to time; objection.
COURT: Sustained.
Q. BY MR. MESEREAU: When did you first tell anyone that there were threats to kill your
family from people associated with Michael Jackson?
A. I think I -- I think the best I can remember -- the best I can remember -- lets see. The
best I think I can remember is Mr. Dickerman.
Q. Was that in a meeting with Jamie Masada?
A. I dont remember that. I just remember being -- when I finally was able to say
everything was with the Santa Barbara Sheriffs Offices -- officers.
Q. Do you know approximately what month that was?
A. I think -- the best I can remember, finally I think it was in July. I think. Thats the best
I can remember.
Q. And that was after you had met with Larry Feldman, correct?
A. Oh, yes.
Q. It was actually long after you had first met with Attorney Larry Feldman, right?
A. My -- my meet ings with Mr. Feld man, he couldnt make out -- we were basically all, you
know, cuckoos after him. You know, it was all cuckoo. Our whole home environment was
cuckoo. So he basically wanted to make heads and tails. He just basically wanted to help.
Q. And your discussion about anyone threatening to kill your family first occurred long
after you met Attorney Larry Feld man, true?
A. I wanted to tell that to the sheriffs. wanted to tell that to the police officers, let them be
the first. I remember asking Mr. Dickerman that I wanted to share that information with
the police.
Q. And in none of Mr. Dickermans letters involving your family did he talk about threats
to kill, correct?
A. Because I expressed to him that I wanted to tell the police, because that would have
gave them the opportunity to see that I was trying to make contact with the police.
Q. Do you remember going shopping while you were staying at the Calabasas Inn?
A. Yes.
Q. And tell the jury where you went shopping.
A. I think it was -- I think it was an outlet store, and also a Robinsons-May. And this is
what with their positive PR film crew following us.
ZONEN: Objection; nonresponsive.
COURT: Sustained as to the last sentence.

Q. BY MR. MESEREAU: While you were shopping, you didnt ever complain to anyone you
were being held against your will, true?
A. Incorrect. I called Wheezy.
Q. Did you call the police?
A. No.
Q. If you could call Wheezy, why couldnt you call the police?
A. Because I couldnt. I was hoping she would.
Q. Which phone did you use to call Wheezy?
A. I dont remember.
Q. Was it a cell phone?
A. I had no cell phone at that time.
Q. Was it a phone in the hotel?
A. I dont think so.
Q. Was it a phone at the shopping center?
A. I dont remember.
Q. You didnt dial 9-1-1, did you?
A. Thats correct. But I have now.
Q. After meeting with two attorneys, correct?
A. Hes incorrect. 6648
Q. When you appeared for the Department of Childrens & Social Services interviews, did
you believe you, yourself, were being investigated?
A. Can you be more clear?
Q. Sure. Sure. When you had the meeting with the Department of Children & Social
Services representatives at Major Jacksons home, did you believe you were being
investigated?
A. Um -Q. Yes or no, if you could, please.
A. Yes.
Q. Okay. And did you believe you were being investigated because someone had made a
complaint about the Bashir documentary?
A. All this I came to find out after the meeting. But before the meeting, I had no
understanding whatsoever.
Q. So you didnt know why you were there?
A. This is correct.
Q. Did you ever tell the sheriffs that you were there because somebody complained about
the Bashir documentary called Living with Michael Jackson and wanted the mother
investigated?
A. Yes, I came to find this after.
Q. Do you remember at the beginning of your interview with the Department of Children &
Family Services you asked what your rights were?
A. Yes.
Q. And why did you do that?
A. Because that was Vicki Podbereskys instructions.
Q. Vicki Podberesky was the lawyer that you had spoken to, right?
A. This is the attorney who put fear in me right before the video, and she claimed she was
Michael Jacksons attorney and Geragoss attorney.
Q. The fear she put into you was you better handle it properly or you could lose your
children, correct?

A. The fear that she put in me was that I could possibly have my children ripped away
from me forever and probably wont see them for a long time. Thats the fear she put in
me.
Q. Did you tell her you had been investigated on other occasions by the Department of
Children & Family Services?
A. No. Brad Miller, his P.I., dialed the phone number, gave me his cell phone, and there
she was.
Q. And did you speak to her?
A. Yes, she spoke to me.
Q. Did she give you advice about how to handle a meeting with the Department of
Children & Family Services, to your knowledge?
A. Because I declined - she wanted to be present - she had gave me information, and now
I know why. They wanted all -ZONEN: Objection; nonresponsive.
COURT: Sustained.
Q. BY MR. MESEREAU: How long was your interview with the Department of Children &
Family Services?
A. Well, let me see. Asaf arrived there. He tape-recorded the meeting illeg ally, and then
maybe a total of -- maybe a total of about -- maybe about, total, about 35, 30, 40
minutes. Because the time frame of Asaf tape-recording the meeting was about 20
minutes.
Q. By the way, on one of your sheriffs interviews, do you recall saying that there are no
clocks or calendars at Neverland?
A. What I remember was that -- what I was trying to communicate, that in my bedroom, I
had no -- no -- none of these things in my bedroom.
Q. You told them at Neverland there are no clocks, correct?
A. Yes. Because I was in the guesthouse. For the end part of the time, I wasnt allowed to
come out anymore.
Q. Are there no clocks at Neverland?
A. On the ground, yes, there is.
Q. Now, the people you claim were telling you that your family were going to be killed are
Frank, Vinn ie, Dieter, and Ron, right?
A. Right. Ronald and Dieter were replaced by Frank and Vinnie. But the init ial meet ing was
with Michael. Michael told me. But what started it off was Michael.
Q. Telling you your family was going to be killed
A. Yes.
Q. is that what youre saying?
A. First it was Gavin, and then it went to my three children, in Miami.
Q. Do you recall ever telling a sheriffs investigator that Miller told you that Mr. Jackson
was buying you a house and an apartment?
A. I dont remember saying that.
Q. Would it refresh your recollection if I just show you a page of the transcript of your
interview?
A. What I think hes referring is totally different. Hes taking it maybe out of context. But,
yeah, bring it on over.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
MR. ZONEN: W hat page is that, Counsel?

MR. MESEREAU: Its nine of this interview. The interview is August 13th, 2003.
MR. ZONEN: Oh, thank you.
THE WITNESS: Yeah. This is what I had talked to you about already; that we had to leave
the country.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. I just looked at the highlighted words. I didnt read anything.
Q. Does it refresh your recollection about what you told the sheriffs?
A. Thats because we had to leave the country.
Q. Did you tell the sheriffs that Brad Miller told you that they were buying you a house
and an apartment?
A. What I was trying to point out to the police department was this is what they were
trying to do in order for me to leave the country. And theres no house and no apartment,
because I dont want to leave the country. And because theyre lies. What I was trying to
point out is they were using different tactics.
MR. ZONEN: Ill object as nonresponsive.
THE COURT: Sustained.
THE WITNESS: Because they wanted me out of the country.
MR. ZONEN: Objection; nonresponsive.
THE COURT: I had sustained the objection.
Q. BY MR. MESEREAU: Did you think you were getting a house from Michael Jackson?
A. No, I was pointing out to the police that they were trying to do everything possible to
get access into my apartment, to go clean it up, to go remove all the letters and items
that Michael had given Gavin. This is what I was trying to point out to the police. And
second, that they wanted me and my children out of this country really bad.
Q. Did you tell the jury that the plan was for you to go to Brazil and never come back?
A. Thats -- thats what their plan was ult imately. That they were going to decide -depending if they did positive PR, cleaned all the mess for Michael, then they were going
to decide at that point in time if I could return. If.
Q. Did you ever see any documents that said it was a two-week trip?
A. That dont matter.
Q. Did you ever see any documents that said the trip to Brazil was a two-week trip?
A. Dont -- and if you look at the documents, its not going to be within the time frame
that I was supposed to leave. They choreograph everything.
Q. Did anyone ever ment ion to you in any form, verbal or in a document, that this was a
planned two-week trip?
A. No, it wasnt. I know that.
Q. Did you ever see a document that said that?
A. Never. But like I said, they choreograph everything.
Q. Okay. So when you told the sheriffs that Brad Miller said they were buying you a house
and an apartment, you were not suggesting you wanted one, right?
A. That is correct.
Q. Okay. Did you tell the Department of Social Services that your children were being sent
to a private school?
A. No, I didnt. Vinnie himself, straight from his mouth, told Karen Walker.
Q. That your kids were going to a private school?
A. Yes. This is another lie.
Q. Okay. Did you believe Vinn ie when he said that?
A. No. Thats why I was behind Karen Walker saying, No. I was going like that.

Q. Is that when you didnt tell Karen W alker you were held against your will?
A. This is correct.
Q. Now, you make some references in some of your sheriffs interviews to speaking in
code. Do you remember that?
A. Yes.
Q. And what code were you speaking in?
A. This is what Ive already explained to the jurors, is that in the midst of my
conversations Id try to slip something in, or I would say one word, say another sentence
and say another word, hoping that when a person would sit or think, theyd say Wait a
minute, that word doesnt match this. I was constantly trying to leave clues for people.
Q. Did you leave any clues for Major Jay Jackson when you stayed at his home?
A. Yes, I tried. I tried. Yes. When I finally left the nail shop, thats when I finally told him
everything. Because Asaf had pointed out that there was another tape-recording being -and Frank and Vinnie told me they can hear everything, so I believed them. I believed
them.
Q. So you believed Jay Jacksons phones were being tapped?
A. Yes.
Q. Did you believe the phones at the salon were being tapped?
A. When I finally was able, I told him, Come on over, and then that was it. Permanently
left Neverland forever, thank God.
Q. Did you believe the phones at the salon were being tapped?
A. No. Thats why -- I didnt know what they could do. Because they said I was being
constantly listened and monitored, so I went ahead and tried.
Q. Do you remember visiting a fed eral building to get a passport?
A. Yes.
Q. Who were you with?
A. Vinnie, the people that were fo llowing us.
Q. Do you remember walking into that federal building to get your passport?
A. Yes. Vinnie and the people that were following us, yes.
Q. Do you remember speaking to anyone in that federal building as you got your
passports?
A. No. I just stood by Vinnie and the children, and thats it.
Q. Did you see any federal employees or agents in that federal building?
A. Yes, and I wanted to reach for them so bad.
Q. Did you complain to any of them that you were being held against your will?
A. No, because at that point my parents lives were at risk. And until I can see my parents
and tell them what was the danger, I couldnt say a single thing. They had full control of
me.
Q. Did you complain to anyone in that federal building that any crimes were being
committed against you or your family?
A. No, I did not.
Q. Did you ever try to dial 9-1-1 to reach any police officer?
A. No. But I have now.
Q. Now, youre aware that in your family law proceeding, your ex-husband David claims
that you sat down and scripted your children in the J.C. Penney case, correct?
A. Yes. Amongst many things David has said.
Q. Did you ever sit down and rehearse your children about what to say in depositions in
the J.C. Penney case?

A. Hes giving me too much credit. No.

Q. To your knowledge, did your children always tell the truth when they testified under
oath in the J.C. Penney case?
A. Except for the part about David.
Q. What about the part about your injuries? Did they tell the truth, to your knowledge?
A. Yes.
Q. Okay. Now, that was when -- that was a situation where Gavin was caught running out
of the store with something that wasnt paid for, correct?
A. This is what I came to understand, because I wasnt present when that happened.
Q. And you told the police that Gavin was just trying to trick his father into paying for
those goods, right?
A. No, I did not tell them that.
Q. What did you tell them the reason Gavin did that was?
A. At that point, when I talked to the police, I had -- I wasnt aware of what happened.
Q. Did you ever learn that that was the reason why Gavin left the store with unpurchased
goods?
A. Yes, I came to find out afterwards. The police told me themself.
Q. Now, did you ever learn about an incident with George Lopez where there was a claim
that money had been taken from Gavins wallet?
A. I came to find out afterwards by Jamie.
Q. And did you talk to George ever about that event?
A. No.
Q. Ever talk to his wife about that event?
A. No.
Q. Ever talk to David about that event?
A. No.
Q. Ever talk to Gavin about that event?
A. No.
Q. Now, you told the sheriffs that Mr. Jacksons people had done background
investigat ions on Jay Jackson. Do you remember saying that?
A. Yes.
Q. And how did you know that anyone associated with Mr. Jackson had done a background
investigat ion on Jay Jackson?
A. His dear damage control people and Frank told me that.
Q. They told you they had checked out who Jay Jackson was?
A. Yes, Frank told me that.
Q. Okay. So you were aware that Mr. Geragoss employees were doing investigations into
who you were and Jay Jackson
A. No, youre incorrect.
Q. -- was, correct?
A. Frank had told me that they had done all this information so they can choreograph their
story. Thats why.
Q. In that recorded phone conversation you had with Frank which we played on Friday,
you never ment ion anything about killers, do you?
A. Im sure I did. And since he had control of that, illegally taping, Im sure they either
erased it, manipu lated it or took it off. But if it was left to me, I would have left it on
there. But it didnt benefit him to leave it on there.
Q. You never mention killers in that recorded phone conversation, do you?

A. Im sure I did. But Frank had control of the tape.

Q. Okay. Do you recall a blood drive at Neverland for Gavin?
A. Yes, I was the one responsible for that. Anywhere where I can gather 50 people or
more, Kaiser was willing to go and take their own bloodmobile, because it benefitted not
just Gavin many, many children and hospital patients. So I was continuously asking for
anybody that can gather more than 50 people, that Kaiser themself would go over there.
Q. And Mr. Jackson allowed you to use his property for a blood drive, correct?
A. All his employees gave blood. All of his employees that wanted to could donate blood.
Not just to Gavin, but to many people, because they were trying to find O negative, C and
B negative blood for Gavin.
Q. And to your knowledge, Mr. Jackson allowed you to do this blood drive on his property,
correct?
A. Yes, this is correct.
Q. And approximately when was this blood drive?
A. Oh, when Gavin was ill in 2000.
Q. Okay.
A. But, you know, he wasnt the only one. There was many church groups. Many, many
people that had gathered. And the bloodmobile would go out to those particular places.
Q. At one point you told the sheriffs that you didnt think Michael was really involved in
that, right?
A. Yes, and Ive also communicated to you. In the beginning, I thought it was only the
Germans, but now I know different per their hard work, investigat ive working, that it was
different.
MR. ZONEN: Im going to object as nonresponsive and also object to the question as
vague. Involved with what?
MR. MESEREAU: I can rephrase it, Your Honor.
THE COURT: Well, now the time to object to the question is long gone, but Ill sustain the
objection to the last part of the answer. Next question.
Q. BY MR. MESEREAU: Did you work with someone named Grace at the blood drive for
Gavin?
A. No, I didnt work there. All I had done was ask Grace if she could ask permission,
because like, rememb er, thats another indicator that I didnt talk to Michael himself.
MR. ZONEN: Objection; nonresponsive.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember complaining to the sheriffs in an interview about
Michael Jackson, Heres a man that has so much wealth, and yet did not even hire my
children a single tutor when theyre supposed to be in school. Do you remember
complaining about that?
A. I didnt complain to him. I was trying to point out to the police that these were the
things that now Im aware of that he really didnt care about children. He just cared about
what he was doing with the children.
Q. Do you remember saying that to the sheriffs?
A. Like I said, I gave him information. Everything possible that I could possibly do to let
them know that the children -- all this time had passed, and they were not educated.
Q. Now, how much time are we talking about where you think Michael Jackson should
have hired a tutor for your kids?
A. No, I dont think he should have tutored -- hired a tutor. I think -- I think he should

have just let me and my kids go.

Q. When you said to the sheriffs, Heres a man who has so much wealth, and yet did not
even hire my children a single tutor when theyre supposed to be in school, what were
you referring to?
A. That hes managed to fool the world, and I was one woman inside there. Thats what I
was commun icat ing; that what he puts out in the world is not who he really is. Now,
because of this criminal case proceed ings, now people know who he really is.
MR. MESEREAU: Move to strike.
THE COURT: Denied.
Q. BY MR. MESEREAU: Have you done any investigation into Michael Jacksons actions
around the world for children?
MR. ZONEN: Objection; argumentat ive.
THE COURT: Its not argumentative, but its not material.
MR. MESEREAU: Okay.
THE COURT: Well take our morning recess.
MR. MESEREAU: Okay. (Recess taken.)
THE COURT: All right. Mr. Mesereau, you may proceed.
THE BAILIFF: Turn your microphone on, please.
MR. MESEREAU: Oh, Im sorry.
Q. Miss Arvizo, when the prosecutor was asking you questions about the Brazil trip, he
showed you an itinerary, which is in evidence. Do you remember that?
A. Yes.
Q. Its a typed itinerary giving departure and arrival times, correct?
A. This is correct.
Q. And he showed it to you. Do you remember that?
A. Yes.
Q. And you identified it as something you were aware of, right?
A. I came to find out after.
Q. Well, the itinerary says youre leaving Los Angeles for Sao Paulo, Brazil, on March 1st,
2003, right?
A. Okay.
Q. It says youre returning from Sao Paulo, Brazil, to Miami on March 6th, 2003, correct?
A. Uh-huh.
Q. And it says youre leaving Miami for Los Angeles on March 7th, 2003, correct?
A. Uh-huh.
Q. That was the itinerary you were shown about the trip, correct?
A. Yes.
Q. Did you ever see any plane t ickets that were actually purchased for the trip?
A. No. Just like my visa and passports.
Q. And you never discussed that trip with anyone other than who, Frank and Vinnie?
A. This is correct. Frank, Vinnie, and the init ial meeting, in that 45-minute meet ing where
Michael said if things got so bad we would have to leave the country.
Q. And you never told Jay Jackson about the Brazil trip?
A. I didnt tell Jay anything until when I permanently left Neverland. Thats when I told
Jay.
Q. Okay. Did you tell Jay Jackson you had gotten passports?
A. I told Jay everything after we came out of -- permanently out of Neverland.
Q. Did you tell Jay Jackson youd gotten a visa?

A. I told Jay everything after we had left permanently out of Neverland. Thats the best I
can remember.
Q. Now, at some point, you must have met with, it appears to be Vinnie, and filled out
some of those documents, correct?
A. Vinnie never left our side the majority of the time.
Q. Excuse me?
A. The majority of the time, Vinn ie never left our side.
Q. And did you sit down with him and fill out the documents so you could apply for a visa?
A. No.
Q. Do you know where he got the information that went onto those forms?
A. They had already studied me. They already had acquired all the information they
wanted, needed.
Q. Did you ever sign any forms; do you know?
A. Yes, I did. Yes, I signed them.
Q. And where did you sign those forms?
A. I think -- the best I can remember, I think actually there at the facility.
Q. Which facility is this?
A. Where they were doing the -- where they were doing the -- processing it.
Q. Is that a federal facility, to your knowledge?
A. Yes, it is.
Q. Did you sit down and do -- work that out with Vinnie? Is that how it worked?
A. It was already filled out by Vinnie.
Q. And did you and your children sit down with him and sign anything, to your knowledge?
A. No, we didnt sit down.
Q. Okay. But you -- what I think youre saying, and correct me if Im wrong, you
completed those documents at the federal facility, right?
A. Incorrect.
Q. Is that incorrect?
A. Thats incorrect.
Q. All right. Where did you just tell the jury you sat down to finish those forms?
A. Never sat down. Vinnie had already all that informat ion pre filled out. All I d id was sign
it. And thats the best I can remember.
Q. Okay. And then you took a trip to the -- was it a consulate you went to?
A. No.
Q. What buildings did you go to to get your passport, visa, and all the documents you
needed to take this trip to Brazil?
A. Everything was done in steps. First it was the birth certificate. Then the passport. And
then the visa.
Q. Do you know how many buildings you went to to get all this done?
A. Three different buildings.
Q. And which -- identify those buildings, if you can remember.
A. The birth certificate, the passport and the visa place.
Q. And was it always you, Vinnie and your children?
A. Yes, plus the people that were following us. They never left our side.
Q. Did these people that you have not identified who were following you ever enter the
buildings?
A. Yes, they did.
Q. So they were just mixing in with the crowds in the buildings?

A. Yes.
Q. And is that what prevented you from ever telling any officer or employee, Help us,
were being kidnapped?
A. Mostly because my parents life were now in danger.
Q. Now, you told the sheriffs at one point you thought your family might disappear in a
hot air balloon from Neverland, correct?
A. Hes taking it out of context. I had informed the police that -- that Frank and Vinnie had
expressed to me that they had many ways to -- and also Ronald and Dieter, remember,
and Ronald and Dieter were replaced by Frank and Vinnie, and that they had many
various ways to make my children disappear. And I was expressing it, but hes minimizing
it.
Q. Did you tell the sheriffs that you thought your family might disappear in a hot air
balloon from Neverland?
A. Again, hes minimizing it. I told him what I told the police what Ronald and Dieter,
Frank and Vinnie had said; that they had various ways to make -- transporting my
children and making them disappear. And what was most terrifying is when it was towards
the end, now they had the passport, plus visa.
Q. Did you ever mention a disappearance in a hot air balloon? Yes or no.
A. I mad e them aware that they had a variety of ways of getting my ch ildren out and that
was one of them. This isnt me. This is what your Frank and Vinnie said, plus your Ronald
and Dieter. So Im just communicating to the police what I was told.
Q. And some of them -- somebody mentioned to you disappearance in a hot air balloon,
right?
A. This is one of a variety of ways.
Q. Okay. Now, you said you went to the child support hearing, correct?
A. Yes.
Q. Your lawyer, Michael Manning, was there, right?
A. Yes.
Q. And the night before, you stayed at Major Jacksons, correct?
A. This is correct.
Q. And the night after the hearing you stayed at Major Jacksons, correct?
A. The night of the hearing, yes.
Q. And you never complained to anyone at the courthouse about these problems youve
identified, right?
A. This is correct.
Q. And I think you told the jury, correct me if Im wrong, that you never told Jay Jackson
about these problems either the night before the support hearing or the night after it,
right?
A. The night of March 10th.
Q. Is that correct?
A. This is correct. I told him that night everything.
Q. You told him the night of the hearing?
A. The March 10th, which was the day before the hearing.
Q. Okay.
THE COURT: You know, Counsel, Im going to ask you to refrain from saying, You told the
jury. You told the jury. Everything that she says here she told the jury.
MR. MESEREAU: Okay.

THE COURT: Its just an improper reference on your behalf. You ask her for the facts, and
theyll listen to it.
MR. MESEREAU: I will do that, Your Honor.
Q. You appeared at a hearing in this courthouse on September 17th, 2004. Do you
remember that?
A. Yes, this is correct.
Q. And at that point in time, you were represented by Attorney Larry Feldman, true?
A. No.
Q. Would it refresh your recollection if I just show you the transcript?
A. I think what Im clear on, he was helping us every time something was happening.
Q. I asked you, You are represented currently by Mr. Feldman, correct? And you said,
Yes, right?
A. Yes. Yes.
Q. Now, when you first hired Attorney Dickerman, one of the things you wanted him to do
was stop any use of your childrens likeness or photos in any media-type event, correct?
A. Yes. This is correct.
Q. And did you say earlier that you were invo lved in a proceeding in England against
Bashir that you didnt know about?
A. This is correct. Mr. Dickerman came to find out afterwards.
MR. ZONEN: Ill object as nonresponsive beyond, This is correct.
THE COURT: Sustained. 6671
Q. BY MR. MESEREAU: Are you saying that you were a party to a lawsuit in England that
you knew nothing about?
MR. ZONEN: Objection. Speculative; lack of foundation.
THE COURT: Overruled.
THE WITNESS: This is correct.
Q. BY MR. MESEREAU: And when did you find out that you were represented by a lawyer
in England in a lawsuit against Bashir and his company?
A. That Michael was involved in.
Q. Im sorry, excuse me?
A. That Michael was involved in. I came to find out this.
THE COURT: The question was when. W hen did you find out?
THE WITNESS: Oh. Summer. In about the summer.
Q. BY MR. MESEREAU: And what summer was that?
A. 2003.
Q. Okay. And did you come to learn that some statements had been attributed to you in
some British newspapers about the Bashir documentary?
A. Yes, I came -- I came to find out a lot of things through this investigation, what they
were doing.
Q. Did you ever see a document that was titled Recommended Statement by Janet
Ventura to the UK Sunday Telegraph?
A. I dont know what youre talking about. But I know that Ronald and Dieter were heavy
at work.
Q. Okay. Do you know if they were preparing any statement to be released quoting you?
A. I came to find out that Ronald and Dieter were using my children, like Michael was
using my children. Everybody was exploiting and using my children. Now Ive came to find
out many things.
Q. Okay. And let me rephrase the question. Did you ever find out that anybody had

prepared a statement attributed to you to be released to a British newspaper?

A. I gave no authority, no interviews, no nothing.
THE COURT: Just a minute. Hes asked you -THE WITNESS: Okay.
THE COURT: -- two or three times if you know about a statement. Thats the only question
hes asked you. Do you or not?
THE WITNESS: No.
Q. BY MR. MESEREAU: Did you have any communication during the first three months of
2003 with an attorney named David LeGrand?
A. No, I didnt.
Q. Okay. Did you ever even hear his name during that period?
A. Yes, I did.
Q. And when did you first learn about an attorney named David LeGrand?
A. Okay. Michael had called over the 60 Minutes, Ed Bradley. This was all part of the
choreography. And Dieter pointed this out, and Ronald over the telephone, that this
interview was never going to take place. It was just per Michaels choreography. And that
Ed Bradley was a dishonest man and they were using him for their choreography. And
David LeGrands purpose -- Michaels attorney was there as part of their choreography, to
let them know that this interview was not going to take place. He was used. Thats what
happened.
Q. Did you -- Im sorry, go ahead.
A. No, its okay.
Q. Did you ever tell anyone to include the following words in a recommended statement
by you to the Sunday Telegraph newspaper in Eng land -A. No.
Q. -- The relationship that Michael has with Gavin, Star and Davellin is a beautiful, loving
father, son and daughter. He is their Daddy Michael. And to me and my children, he is our
family. He cares for them as a good, loving father. Michael is their only father figure who
loves and cares about them. They are not fatherless, because 6674 they have their Daddy
Michael. My family consists of unconditional love. Did you ever tell anyone to use those
words?
MR. ZONEN: May I see the document, please, Your Honor?
MR. MESEREAU: Sure.
MR. ZONEN: Go ahead.
Q. BY MR. MESEREAU: Did you ever give words to that effect to anyone to be used in a
statement by you?
A. I think Im recalling something. Remember how they put those two -- that page that
had, like, two signatures on there? And I told you that one of my -- them, one of them
was my signature, but it had been moved, I can tell, because of where it was.
MR. ZONEN: Im going to object as nonresponsive to the question of whether or not she
used those words.
THE COURT: Ill sustain that objection. But Im going to ask counsel to simplify the
question a little bit. Its a little cumbersome the way it stands.
MR. MESEREAU: Okay. May I approach, Your Honor?
THE COURT: Yes.
MR. MESEREAU: Thank you.
THE WITNESS: Here it is. There it is. Uh-huh.
Q. BY MR. MESEREAU: Have you had a chance to look at that document?

A. Yes. Yes, I have.

Q. Have you had a chance to read those words?
A. This is where they took my signature from.
Q. Okay. Have you had a chance to look at it?
THE COURT: Just a minute. Just look at the words that counsel wants you to look at.
Would you show her which paragraph youre -MR. MESEREAU: Yes, Your Honor.
THE WITNESS: Yes. Yes, yes.
THE COURT: Youre showing her two paragraphs?
MR. MESEREAU: Yes, Your Honor. I am. Well, Im showing her -THE COURT: Which one are you going to ask her the question about?
MR. MESEREAU: Im showing her one sentence in one paragraph and a -- well, its really
one, buttheres some handwritten stuff that Im asking her to look at.
THE COURT: Well, you need to address with her what youre trying to show her so that
she can answer any questions.
MR. ZONEN: Your Honor, could we mark this item as an exhibit?
THE COURT: No. He was refreshing her memory with it.
Q. BY MR. MESEREAU: Ms. Arvizo, Im just asking you if you know where the following
words came from.
A. Yes, from Dieter.
Q. Okay.
A. Dieter had -- they added that second paragraph right now. But all it was was -THE COURT: Just a minute. Theres no question pending.
THE WITNESS: Oh, okay.
Q. BY MR. MESEREAU: Okay? Do you remember the words I read?
A. No, you didnt read any.
Q. Okay. Let me just read them and see if you know where those words came from.
A. Okay.
Q. Okay? The relationship that Michael has with Gavin, Star and Davellin is a beautiful,
loving father, son and daughter. He is their Daddy Michael. And to me and my children, he
is our family. He cares for them as a good, loving father. Michael is their only father
figure, who loves and cares about them. They are not fatherless, because they have their
Daddy Michael. My family consists
of unconditional love. Have you heard those words before?
A. Yes. This is when -- when Mr. Zonen was doing his -- when he was speaking with me, I
had told you that my signature had been moved, because Dieter had a pre -- preprinted
paragraph, and then in my -- in my own writ ing, he had me write something. So, yes, that
is right before we left Miami.
Q. Well, if you knew about this, did you know about the lawsuit?
A. No.
Q. So you did know about a statement that was supposed to be attributed to you to
appear in a British newspaper, right?
A. No. No, no, no.
Q. Do you know whose writing that is that I just showed you?
A. This is my writing that Ive already told the jurors.
Q. So you wrote those words, correct?
A. Yes, per Dieters dictation.
Q. You wrote those words on a statement to be released Friday, February 7th, 2003,

correct?
A. No. It wasnt a statement that was going to be released. What Ronald had done -Dieter had told me that what Ronald had done did not work to appease the killers. And
theres that phrase, and thats a quote.
Q. And theres a heart thats written in between the printing, and thats a heart that you
wrote, correct?
A. Yes.
Q. And then you see XOXOXO, meaning Love, right?
A. Yes. Thats -Q. And thats your writing, correct?
A. Yeah. Thats correct. I used to be that kind of person. Now Im like this (indicating)
hold up. Im putting one hand over my heart.
Q. And your writing is inserted into a printed statement, right?
A. Yes. They have -- by the way, hes shown me the paper. That bottom paragraph was
not there.
Q. Are you saying that you wrote these words and put a heart and put XOXOXO in
Florida?
A. Yes. This is correct.
Q. And does the date February 7th, 2003, sound right to you?
A. It must be right.
Q. Okay. And the printed portion of the statement says, I am appalled at the way in
which my son has been exploited by Martin Bashir and Granada Televis ion, correct?
A. Thats what Dieter had written.
Q. And thats the way you felt, right?
A. No. They had told me that this would -- what Ronald had did does not work and this
would appease the killers. So I was fooled.
Q. Well, are you saying you didnt know this was to be released in England?
A. Exactly.
Q. And youre saying you didnt know that there was going to be a lawsuit in England in
which you, your children, and Mr. Jackson were going to sue Bashir and Granada
Television?
A. This is correct. Money doesnt buy happiness. Thats why when I found out through Mr.
Dickerman -MR. ZONEN: Objection; nonresponsive.
THE WITNESS: -- I put a stop to it.
THE COURT: Sustained. Theres no question pending.
Q. BY MR. MESEREAU: Did you ever see an article that appeared in a British newspaper
the next day, February 8th, 2003, that quoted you?
A. No.
Q. Did you ever talk to anyone who claimed to represent a British newspaper at any time?
A. I think -- I think when those two people that had came before we left to Miami that had
scared my parents, and they kept saying, Gavin, cancer; Gavin, cancer.
Q. Ms. Arvizo -- oh, sorry. Miss Arvizo, did you ever tell anyone that you were living in a
stable with hay and horses in Bakersfield?
A. No.
Q. Ever say anything to that effect to anyone?
A. No.
Q. Did you ever hear or learn that you were quoted as saying that?

A. Yeah. I came to find out a lot of things.

Q. When did you find out that you were quoted as saying that you and your family were
so poor you were living in a stable with hay in Bakersfield?
A. Just recently. Ive never lived in Bakersfield.
Q. Did you ever learn that Jamie Masada had quoted you as saying that?
MR. ZONEN: Ill object as lack of foundation and assumes facts not in evidence that Jamie
Masada said she lived in Bakersfield.
THE COURT: Sustained; foundation.
Q. BY MR. MESEREAU: Now, the document that you just admitted adding language to, was
that presented to you at the hotel in Florida?
A. Yes, it was.
Q. And you read that before you inserted all these words?
A. No, I didnt. I completely trusted them.
Q. Did you know it was supposed to be a recommended statement by you?
A. What?
Q. Did you know the document you were inserting words into was titled A Recommended
Statement by you?
A. No. I didnt read it. I completely trusted them.
Q. Well, why would you add language to an already existing paragraph if you didnt know
what was in the paragraph?
A. Because Dieter dictated that. Everything was -- at that point was like a state of panic.
Thats how Ronald and Dieter were behaving.
Q. So you just filled out what you were told to fill out and never read a thing, correct?
A. Yes, I completely trusted them. I did.
Q. Let me get back to what you told the social workers on the 20th, okay? You told them,
My children are never solely alone with Michael Jackson, true?
A. Incorrect.
Q. You didnt tell that to them?
A. Thats correct.
Q. Okay.
A. And let me remind you -MR. ZONEN: Objection; no question pending.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You told the social workers, Mrs. Arvizo, Theres always someone
around, right?
A. Incorrect.
Q. You told them, When we go to Neverland, we are always around people, right?
A. Incorrect.
Q. You said, Sometimes I stay in the visitors quarters, but mostly I am in the main
house, right?
A. Incorrect.
Q. You said, Gavin, Star and Davellin have all been in Michaels room, right?
A. Yes, I did.
Q. You said, Yes, Gavin and Star have been with Michael on his bed watching T.V., right?
A. Incorrect.
Q. You told the social workers, As to the alleg ations that they share a bed, it is no?
A. What?
Q. Did you tell that to the social workers?

A. Repeat that, please.

Q. The words are, As to the allegations that they share a bed, it is no.
A. Incorrect. These social workers, all they were interested was not being sued by Michael
Jackson.
MR. ZONEN: Objection; nonresponsive.
THE COURT: Sustained.
THE WITNESS: They didnt have -THE COURT: Just a minute. Theres no question pending.
THE WITNESS: Okay. Okay.
Q. BY MR. MESEREAU: In that interview with the social workers, you said, There are
always children in Michaels room, right?
A. Incorrect.
Q. You told the social workers, On or about September 15th, 2002, the day in question,
Gavin and Star were in Michaels room watching T.V. and they made smores in a firep lace
in Michaels room?
A. Incorrect.
Q. Never said anything like that to the social workers?
A. No, no. They didnt even have no pad or pen with them when they were sitting at the
kitchen table.
Q. You told the Los Angeles social workers, all three of them, that, Michael s lept on the
floor with blankets and a sleeping bag while Gavin and Star slept in the bed, right?
A. Incorrect.
Q. You told the social workers, Im usually up walking around the house all night long,
right?
A. No.
Q. You told the social workers, The room is open and there are no doors to shut,
correct?
A. Incorrect.
Q. You told the social workers, It makes me sick that someone would accuse Michael of
doing harm to my son and other children when he has never been anything but wonderful.
You said that, didnt you?
A. Incorrect.
Q. You told the social workers, He has been like a father to them, right?
A. Yes.
Q. Told the social workers, My children have never felt uncomfortable in his presence,
right?
A. Incorrect.
Q. You told the social workers, Michael has been a blessing, right?
A. Huh-uh.
Q. You told the social workers, I was not aware that the taping with Mr. Bashir would be
aired?
A. That I did.
Q. You told them, We did not sign any consent to have my children on this interview,
right?
A. This is correct.
Q. You further told them, When my children would go to visit Neverland, there was
always somebody present, right?
A. Incorrect.

Q. You told them, On several occasions, Michaels friend, Chris Tucker, and his family
were there, right?
A. I informed them that my children had been there, had had that visit that Ive already
expressed to you over and over.
Q. You told the social workers, In September of 2002, Chris Tucker accomp anied Gavin,
Star and Davellin in Neverland Ranch, right?
A. Thats the birthday party that I was talking to you about.
Q. You told them, Our last visit to Neverland together was on February 19th, 2003; is
that right?
A. Incorrect.
Q. You said, The children are welcome there any time, right?
A. Incorrect.
Q. You said, I do not always go to Neverland with the children, right?
A. This is correct.
Q. You told them, Michael is like a father to my children, right?
A. This is correct.
Q. You said, Hes like family, correct?
A. This is correct.
Q. You said, He gives advice to my children, and that is something they never had with
their father, right?
A. That is correct, because of the initial meeting.
Q. You said, He loves them and I trust them with him, right?
A. Yes. What a fool I was.
Q. You said, Michael is so kind and I feel that he is misunderstood, right?
A. So kind, but I didnt say misunderstood.
Q. You further said, Michael was an important part of Gavins recovery from cancer,
right?
A. Incorrect.
Q. You said, Gavin met Jamie Masada at The Laugh Factory about three years ago and
made a wish to meet Michael Jackson, true?
A. No. I said Gavin had spoke to Jamie and said he was one of three people that he
wanted to meet.
Q. Did you tell them you felt that the paternal grandparents had deserted your children?
A. Does that mean like Davids family? Im asking you if thats what it means. Unless you
want to clear -- can you make it clearer, please?
Q. All I can ask you is, did you say, Mother feels that the paternal grandparents have
deserted the children?
A. Oh.
MR. ZONEN: Ill object as vague.
THE COURT: Shes asked for a definition of paternal.
THE WITNESS: Yes.
THE COURT: She didnt use the word. Its not suggested she used the word. Thats a
conclusion of one of the social workers. So would you help her?
MR. MESEREAU: Yes, I will, Your Honor.
Q. Yes, I think the way youve defined it would be correct.
A. Yes. Yes. Davids family didnt want nothing to do with my kids.
Q. Do you remember telling those social workers the media has been taking everything
out of context and youre appalled at the negative attention your children have been

receiving?
A. No. What I told her is that -- told them that I didnt understand what was happening.
Q. Did you tell them that youve been having a d ifficult time personally and financially?
A. No.
Q. You told them about your prior involvement with the DCFS, right?
A. Oh, yes. Yes, I did.
Q. Your children were interviewed on that day, right?
A. Yes.
Q. Were you there when they were interviewed?
A. Yes, I was.
Q. And just in summary, you heard them say glowing things about Michael Jackson, right?
A. Yes, they did. Yes.
Q. And at some point, you learned that this investigation was closed, right?
A. Yes, I came to find out.
Q. Approximately when d id you find out the investigation was closed?
A. Well, when Jay and me paged Karen Walker after the Family Court day and we asked
her for help. And she said, Its out of my hands. Its out of my hands. Weve already done
the report. Go get legal help. I cant help you. W hen I told her that my son had been
given alcohol, that we were being held, that they were taped, gave her all this
informat ion, and she said, Its out of my hands, thats when I found out the report was
done.
Q. And approximately what date was that?
A. That was the 11th, March 11th.
Q. And did you call her?
A. Yes, I did.
Q. Okay. Did you file a report?
A. Well, I spoke to the supervisor. She was the supervisor, Karen Walker.
Q. Were you being represented by Attorney William Dickerman at that point?
A. No.
Q. When did you first start being represented by Attorney William Dickerman?
A. After she didnt help me.
Q. He didnt write to the DCFS at any time, did he?
A. No, he didnt. But Mr. Feldman did.
Q. And that was, what, months later? To your knowledge.
A. I cant....
Q. Okay. Did you ever read any of the letters Attorney Dickerman was sending to Attorney
Mark Geragos?
A. Yes, some of them I d id.
Q. And did you assist Mr. Dickerman in preparing those letters?
A. I didnt assist him. I told him what was happening. He wrote them himself.
Q. And was it your belief that Mr. Dickerman was writing Mr. Geragos to complain about
injustices that had been done to you and your family?
A. What Mr. Dickerman was doing was giving us help, as retrieving our visa, our
passports, everything that belonged to us. Where is my storage? Where is my items?
Things that belonged to me. Requesting that my childrens clothing be returned. Because
when Frank rummaged through the childrens clothing, he took all the new clothing that
they had purchased. But when they were doing that, they also took my childrens own
clothing and kept all of Gavins clothing. And Frank said that if they wanted them, they

needed to come back to Neverland. Just different things like that. And for your people to
stop following us, and to make you aware that we wanted nothing to do with you
anymore.
Q. In none of his letters did he ever ment ion anything about alcohol or child molestation,
true?
A. Because that was information for these guys right here, for the police.
Q. How many months later?
A. Because I didnt want Geragos to know that we were headed towards -- straight to the
police.
Q. Do you know when you first met with Dickerman?
A. I believe -- I think it was the 25th of February.
Q. Pardon me?
A. I believe I met him, but he was not my attorney, February 25th. Just met him for
minutes. Minutes. Thats it.
Q. How many meetings did you have with Mr. Dickerman?
A. Prior to leaving out of Neverland, once.
Q. How about after you left Neverland?
A. After I left Neverland? Well, all these -- in order to -- I think -- the best I can believe, I
think it was two. It was two. Thats the best I can remember.
Q. How long did Mr. Dickerman represent you?
A. Well, until Mr. Feld man and Mr. Dickerman kicked me to the curb because I didnt want
to tell them all the information that I was telling the police. Because the police told me not
to tell them because that would compromise the investigation. And so I didnt tell them
nothing. Mr. Feld man was clueless, and so was Mr. Dickerman.
Q. But you werent speaking to the police until long after you met Larry Feldman, true?
A. Yes, because I wanted to ensure that these people werent following us anymore.
Q. You didnt go to the police until months after you first started meeting with Attorney
Larry Feldman?
A. This is correct. I wanted to just hopefully -- maybe we could have the ability to just -maybe it would disappear. But the more things were happening, the more I was becoming
aware.
Q. So you had gone to at least two lawyers about your alleged problems with Mr. Jackson
for months before you ever spoke to anyone with the Santa Barbara Sheriffs Department,
right, Ms. Arvizo?
A. Yes, this is correct.
Q. And the first report of any allegation of child molestation to the sheriffs came from Mr.
Feld man, did it not?
A. Let me see. Well, actually -- actually, Mr. -- my husband, Jay Jackson, tried to reach
the police. And then when me and -- me and Jay both contacted the supervisor, Karen
Walker, then -- and she said to go get legal help. And also, as things are moving in dates,
Im starting to find out more and more. Now I know why he had a criminal defense
attorney, but I didnt know because there was no investigation underway.
Q. There had been an investigation since February that was publicly announced by Santa
Barbara, right?
A. Well, I wasnt aware of that.
Q. Youre claiming that in the midd le of all of these efforts to falsely imprison your family,
restrain your family, get you to Brazil, deal with the media, all of a sudden child
molestation starts, right?

MR. ZONEN: Objection. Argumentative and compound.

THE COURT: Sustained on compound.
Q. BY MR. MESEREAU: Do you remember meeting with someone named Bowen from the
DCFS?
A. No. Is she the one, or he, that leaked all the information from the DCFS to everybody?
Q. You remember meeting with three women from the DCFS on the 20th, right?
A. Yes, I do.
Q. And there was Karen Walker, right?
A. Yes.
Q. Was there -- Irene Peters one of the ladies?
A. That sounds familiar.
Q. How about Jacqueline Bowen?
A. I dont -- I dont remember the -- all I remember is Miss Karen Walker, Jackie and
someone named Yvonne. So I dont know.
Q. And you complained to Miss Peters about the Bashir documentary, right?
A. No, I didnt. I told them that there was no consent. Thats all.
Q. And you were upset about that, right?
A. No, I said there was no consent.
Q. Do you remember comp laining that you could not get any assistance from Michael
Jackson regarding tutoring or home schooling because of all the media attention?
A. No. Thats incorrect.
Q. Do you remember saying you were having a d ifficult time s chooling your kids because
of the media attention?
A. Thats incorrect. Because I reenrolled my children back into that school the second we
finally got to leave Neverland permanently.
Q. Do you remember telling Miss Bowen you were having a hard time contacting Michael
Jackson in regards to helping with the tutoring due to the problems the children were
having at school?
A. Thats incorrect.
Q. You never said that to Ms. Bowen of the DCFS?
A. No, the meeting was so small with them, that I remember all they were interested was
not being sued by Michael Jackson.
Q. And how long was that meeting, if you remember?
A. Okay. Well, let me see. Here we go. Twenty minutes -- about 20 minutes of Asaf taping
it. So about maybe after that, maybe about ten minutes sitting with them. 10, 15
minutes. 15 minutes would be generous. So about a total of -- altogether maybe 30, 35
minutes, 40 minutes. 40 minutes would be a stretch. That would be making it generous.
They came in there for one thing only. You know, one thing: Not to be sued by Michael
Jackson.
MR. ZONEN: Ill object as nonresponsive.
THE COURT: The last two sentences are stricken.
Q. BY MR. MESEREAU: Do you remember asking Karen Walker if she could talk to
Michaels people to see if they could provide schooling for your kids?
A. No.
Q. Do you remember asking Miss Walker if she would write a letter on your behalf so your
kids could get schooling?
A. No.
Q. And do you remember telling Ms. Walker youre not going to take a trip to Brazil?

A. Do I?
Q. Yes.
A. I mad e no mention to them of leaving the country. I made her aware afterwards, when
Jay and I paged her, what they were trying to do.
Q. Now, at some point, did you sign any documents which suggested your children should
be taken out of their school?
A. I -- not suggested. It was. I didnt sign the one for Davellin, which they had done
before they had taken the children out. The one for the boys I did sign, because that was
afterwards.
Q. And the document you signed was designed to give your permission to take your sons
out of school, correct?
A. This is correct.
Q. And what school did you think they were leaving?
A. I didnt know. I just did what they said. Thats it. At that point, the end point, I was
doing what they were saying. Thats it.
MR. ZONEN: Objection; nonresponsive to the question.
THE COURT: Ill strike after, I didnt know.
Q. BY MR. MESEREAU: During the point in time when you signed that document
authorizing your sons to be taken out of school, did you talk to anyone at the school?
A. At that time, no. I wasnt even present.
Q. But clearly you knew your children were going to be leaving their school, right?
A. This is correct.
Q. And what school did you believe Gavin was leaving?
A. They were going to be nowhere. We were headed out -- out of the country. This was for
their purpose of no one being able to trace my children nor me. We were headed out.
Q. What school did you believe Gavin was leaving when you signed that document?
A. Well, if it was up to them, they were going to be in no school.
MR. ZONEN: Your Honor, I dont believe the witness understands the question.
MR. MESEREAU: I can try to rephrase it, Your Honor, if its unclear.
THE COURT: Well just have the court reporter read it back. She hasnt said she doesnt
understand. Read it back. (Record read.)
THE WITNESS: Zero.
MR. ZONEN: I dont believe the witness understands the question.
THE WITNESS: I dont understand.
MR. MESEREAU: Ill try to rephrase it.
Q. You signed a document -A. Yes.
Q. -- authorizing the school to release Gavin as a student, right?
A. Gavin and Star. The boys.
Q. Which school were you talking about?
A. That they were attending?
Q. Yes.
A. They were attending John Burroughs.
Q. And you knew that a document was prepared to allow Davellin to leave school, right?
A. No.
Q. Did you know that Davellin was going to leave school?
A. No. Davellin, I had no knowledge of.
Q. So you thought you were going to Brazil, but you only thought Gavin and Star were

leaving school?
A. No, no. I signed that paper because they had me sign it.
Q. To your knowledge, did Gavin and Star actually leave that school?
A. Well, they were checked out by Vinnie. I wasnt there. When I finally got permanent ly
out of Neverland, I reenrolled them immediately into the same school.
Q. Well, when you got out of Neverland at that point, you knew you were not going to be
involved with Mr. Jackson ever again, correct?
A. He gave my son alcohol. Please.
Q. Did you know that?
A. He gave my son alcohol. That was enough for me. But as time progressed, I found out
more and more and more. So no way, no way.
Q. Well, as time went on, the story just kept getting bigger and bigger, didnt it?
MR. ZONEN: Objection. Argumentative; asked and answered.
THE COURT: Its argumentative. Sustained.
Q. BY MR. MESEREAU: Did you know that Major Jay Jackson had asked for monetary
compensation for your family from Frank?
A. No.
Q. Did you know that Jay Jackson had said words to the effect, You guys are making
millions. And this family should get their proper piece of the action?
MR. ZONEN: Objection; misstatement of the evidence.
THE COURT: Overruled. You may answer.
THE WITNESS: Okay. Ive come to find out now. But, no, I didnt then.
Q. BY MR. MESEREAU: So at that point in time, you never d iscussed with Major Jay
Jackson your familys right to have any compensation if they appeared in a rebuttal video?
A. This is correct. There was a new relationship with Jay.
Q. And based on the fact that you now are aware of this, do you believe he kept you silent
on that issue?
A. I dont understand your question.
Q. Youre saying that Jay Jackson never told you that he approached Frank and said, How
much is the family going to get?
A. Im aware now, because of the investigations, but I didnt know then. And thats it.
Q. Did you know at any time that Major Jackson was discussing the possibility of selling a
story to a British tabloid?
A. I think youre saying it incorrect. barely found out as Ive been up here. But the way
hes saying it isnt the way its been said to me by the D.A.s Office.
Q. Did you know at any time that Major Jackson was in discussions with representatives of
a British tabloid about the possibility of selling a story?
A. No.
Q. He never discussed that with you at any time?
A. No. Not at all. Till this day he still hasnt.
Q. Did you ever have a d iscussion with Frank about your getting any home in the
Hollywood Hills?
A. No.
Q. Did you ever have a d iscussion with Frank about the possibility of a college educat ion
for Gavin being paid for by Michael Jackson?
A. No.
Q. Now, you believe your signature was forged on some documents making you a party to
a lawsuit in Britain, right?

A. My signature, per their investigation, is accurate. I signed a blank piece of paper in

Miami that Ronald had presented to me. But that signature is mine.
Q. Did you ever receive any communications from any lawyer regarding the lawsuit in
England?
A. After we were permanently out, Mr. Dickerman commun icated to me that this was
going on. And they even offered me money to stay in it, and I said no.
Q. When you left the apartment on Soto Street, did you personally sign any documents
that say youre going to leave?
A. No.
Q. Did you ever sign any documents involving rent that was owed or not owed?
A. No, I did not.
Q. Did you ever talk to the landlord and say you were leaving?
A. Yes, I did.
Q. And was that Yolanda?
A. Yes.
Q. Okay.
A. And I -- this is another person that I tried to slip something in -MR. MESEREAU: Move to strike.
THE WITNESS: -- leaving -- that I told her I was leaving the country.
THE COURT: Just a moment. Just a moment, please. Stricken.
Q. BY MR. MESEREAU: Was that Yolanda Lazalde?
A. Yes. Thats where I slipped in Im leaving the country. This is another one of the
people that I was trying to reach out to.
Q. This was another one of your clues that you were leaving?
A. Pardon me? Yes. Yes, it was.
Q. Now, was Ramon Trujillo also the landlord?
A. Yes.
Q. Okay. Did you communicate with Ramon Trujillo that you were leaving the apartment?
A. No, I had no communication with him.
Q. Okay. You told Miss Lazalde that you were leaving the apartment, but gave no reason?
A. I did not tell her that. I told her I was leaving the country, but thats it. Jay Jackson had
went and paid my current rent.
Q. To your knowledge, did anyone other than Jay Jackson pay rent that you owed?
A. No. It was from my funds that he went and did me the favor to go pay the rent,
because I couldnt.
Q. My question is, and it may not have been clear, are you aware of anyone other than
Jay Jackson paying rent that you owed on that apartment?
A. I came to find out, through that, what Mr. Zonen submitted into evidence, that they
had done that. And then I also came to find out that Frank and Vinnie had said that this
was a way for no one to start searching for where me and the kids might be.
Q. Now, at this point in time, you thought that Mr. Jackson, one of the best known people
in the world, was trying to just kidnap your whole family, right?
MR. ZONEN: Object as argumentative.
THE COURT: Sustained.
Q. BY MR. MESEREAU: At this point in time, you thought Michael Jackson was arranging to
kidnap your entire family, right?
MR. ZONEN: Objection to the use of kidnap; lead ing.
THE COURT: Overruled. You may answer.

THE WITNESS: All I know is what I saw and what I knew. They were making me, my
children leave the country. Thats all I knew.
Q. BY MR. MESEREAU: You were leaving the country for one week, right?
A. No. Till they decided when. And as long as I did what they told me.
Q. Do you know someone named Katie Bernard who worked at Neverland?
A. No.
Q. Now, are you aware of Katie Bernard driving you to the spa in Los Olivos when you had
the wax?
A. That was Chris Carter.
Q. You dont recall Katie Bernard doing that?
A. No, it was Chris.
Q. Are you aware of a Katie Bernard ever dropping you off the next day to have your hair
done?
A. Never happened.
Q. Do you remember telling Katie Bernard how good Michael Jackson had been to your
family and what a great guy he was?
A. No, I dont even know Katie Bernard.
Q. Okay. Are you aware of Katie Bernard paying for your spa treatment?
A. No. And it was a leg wax.
Q. Did you ever call Kat ie Bernard and ask her to arrange for Gavin and Stars braces to
be removed by a dentist?
A. No. That was taken care of by Frank and Vinnie.
Q. Did you ever tell Kat ie Bernard that you were being hassled by a Los Angeles dentist
for payment and you wanted her to arrange to have your two sons braces removed?
A. No.
Q. Did you ever tell Kat ie Bernard you wanted her to return the braces to the L.A. dentist
because you couldnt afford to pay for them?
A. No.
Q. Do you remember ever calling Katie Bernard and saying you wanted to go shopping for
clothes while you were at Neverland?
A. No.
Q. Did you ever know someone at Neverland named Rafael Camacho?
A. No.
Q. Do you recall Rafael Camacho occasionally driving you to places off the ranch property
while you were staying at Neverland?
MR. ZONEN: Ill object as lack of familiarity by the witness. She says no, she doesnt know
him.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know whether or not anyone who worked at Neverland
ever drove you to various places off the ranch property while you stayed at Neverland?
A. No. They even mad e me miss Ash Wednesday, and I had never missed it before.
Q. Whos they?
A. Michaels people.
Q. Okay. Did you ask for someone to drive you to church on Ash Wednesday?
A. They knew I wanted to go to church. But at that point, that was it.
Q. But did you actually ask for someone to drive you to a local church on Ash Wednesday?
A. Yes, I did.
Q. Who did you ask?

A. I asked Frank and I asked Vinn ie, and they said no.
Q. Did you ever know someone named Modesto Camarena at Neverland?
A. No.
Q. Did you ever know someone at Neverland named Hector Elenes?
A. No.
Q. Did you know someone at Neverland named Francisco Fuentes?
A. No.
Q. Ever complain to Francisco Fuentes that you were struggling financially?
A. I dont even know Francisco Fuentes.
MR. ZONEN: Ill so object as lack of foundation.
THE COURT: Lack of foundation; sustained.
Q. BY MR. MESEREAU: Ever know someone at Neverland named Tammy Gewehr, G-e-we-h-r?
A. No.
Q. Ever know someone at Neverland named Gayle Goforth?
A. No.
Q. Ever know someone who worked at Neverland named Maria Gomez?
A. No.
Q. Ever tell Maria Gomez that you thought Frank and Vinnie were separat ing you from
Michael Jackson?
MR. ZONEN: Objection. Lack of foundation, that she knows this person.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you ever tell anyone at Neverland that Frank and Vinnie were
separating you from Michael Jackson?
A. No.
Q. Did you ever tell anyone at Neverland that you had financial problems?
A. No.
Q. Did you ever know someone who worked at Neverland named Curtis Gordon?
2 A. No.
Q. Did you ever know someone at Neverland named Patty Hankins?
A. No.
Q. How about Chris Hernandez?
A. No.
Q. How about Ryan Hester?
A. No.
Q. Ever know someone who worked at Neverland named Anthony Hudley?
A. No.
Q. Did you ever know someone who worked at Neverland named Charlie K irchhoff?
A. No.
Q. Ever know someone who worked at Neverland named Julio Mag ana?
A. No, I dont. But I remember when I had called to Neverland to make contact with my
kids, because I was already out, I asked him his name and he said his name was Julio. So
that was it. But thats the name. It sounds familiar.
Q. Do you know someone who worked at Neverland named Christy Mann?
A. No.
Q. Did you ever know someone named Shane Meredith?
A. No.
Q. During any of your trips to Neverland, did you ever meet someone named Samuel

Moreno?
A. No.
Q. Did you ever meet someone named Jonathan Bruce Richards?
A. No.
Q. Did you ever meet someone named Manuel Rivera during your trips to Neverland?
A. No.
Q. During your trips to Neverland, did you ever comp liment Michael Jackson?
A. No.
Q. Ever complain to anyone that you wanted your children on televis ion with Michael
Jackson?
A. No.
Q. Now, you did argue with Ronald Konitzer at Neverland, right?
A. I didnt argue with him.
Q. Did you ever argue with Dieter?
A. I didnt argue with them.
Q. Did you ever know someone at Neverland named Brian Salce, S-a-l-c-e?
A. No.
Q. Ever know an employee at Neverland named James Silva?
A. No.
Q. While you were vis iting Neverland, did you ever meet Javier Velasco? 6709
A. No.
Q. Did you ever tell anyone at Neverland that your children loved Michael Jackson like a
father?
A. No. Once at Neverland, all that stopped. Especially when hes running around like crazy
with my kids.
Q. Did you ever complain to Javier Velasco that Michael Jackson had promised to take
care of you, and you knew now it wasnt going to happen?
MR. ZONEN: Lack of foundation that she ever knew Javier Velasco.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you ever complain to anyone at Neverland that Michael
Jackson had promised to take care of you, and now you knew it wasnt going to happen?
A. No.
Q. Ever meet someone named Angel Vivanco?
A. No.
Q. Did you ever know someone named Jason Wolcott at Neverland?
A. No.
Q. Did you ever meet someone named Christian Robinson?
A. Yes. Hes the one that did the -- the rebuttal video. Hes the one that had the scripted
questions and you could even see him hold ing it. And hes the one that also picked up
mine and my childrens birth certificate.
Q. Now, when you say scripted questions, do you mean he had the questions in advance
that he was going to ask you on the rebuttal video?
A. Yes. Thats my understanding. I may be wrong.
Q. And were they the questions you believe he was asking you when you filmed the
rebuttal video?
A. Yes.
Q. Where did you first meet him?
A. Right there.

Q. Was that at Hamids house?

A. Yes.
Q. Was that the first time you had ever seen him?
A. Yes.
Q. And that would have been the -- what, the day of the 20th?
A. The day of the 19th, going into the 20th. From 19th, about 11-something, till like a.m.
hours of the 20th.
Q. And approximately what time do you think you met Christian Robinson?
A. Oh, well, when I got there.
Q. Now, did someone tell you whose house you were going to?
A. Yes. Vinnie.
Q. Okay. So you knew it was owned by someone named Hamid, right?
A. Yes. And also Frank on the phone.
Q. Your understanding was that the purpose of that video was to make Michael Jackson
look good, right?
A. Thats correct.
Q. And you knew for quite a while that efforts were being made to put together a
television show in response to the Bashir documentary, right?
A. Thats what I came to find out. And I wanted no part of it, and thats why I left with
Jesus, me and my children.
Q. Did you ever hear your sons say to Mr. Robinson they wanted to be famous on the T.V.
show?
A. I dont think so.
Q. When is the last time you saw Christian Robinson?
A. It was just that day. Thats it.
Q. Okay. Now, do you remember when you testified before the grand jury, you were
shown a number of documents involving expenditures that were made for you and your
family at one point by Frank and Vinnie?
A. Yes, this is correct.
Q. And when you were in the grand jury room, you did acknowledge that what was on
those documents had been spent for you, Gavin, Star and Davellin, true?
A. Hes taking it out of context. Another thing: What applied to me and my kids was pretty
accurate, but what applied to Frank and Vinnie, youre going to have to talk to them about
it.
Q. When you stayed at Neverland, it was your understanding that any costs involved were
paid for by Michael Jackson, true?
A. We were on his -MR. ZONEN: Objection; vague. Costs involved with what?
MR. MESEREAU: Ill be happy to rephrase it.
Q. When you and your family visited Neverland, you were often transported back and
forth by someone that you thought was hired by Mr. Jackson, correct?
A. We were not often transferred back and forth.
Q. Well, how many visits do you think your family made to Neverland in total?
MR. ZONEN: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: How did you get to Neverland the first time your family went?
MR. ZONEN: Objection; asked and answered.
THE COURT: Overruled.

THE WITNESS: How did we get there the first time?

Q. BY MR. MESEREAU: Yes.
A. Which time?
Q. Let me rephrase the question. Most of the time when you or your family went back and
forth to Neverland, the transportation was arranged by someone at Neverland, true?
A. Yes. This is correct.
Q. And it was your belief that this transportation was paid for by Mr. Jackson, correct?
A. Yes, this is correct.
Q. And you mentioned someone named Evvy Tavasci whom you knew, right?
A. Yes, I never met her. It was only solely per the telephone.
Q. You used to call her sometimes, didnt you?
A. No, she called us.
Q. Did you ever call her yourself?
A. In returning her phone message.
Q. Did you ever ask Evvy Tavasci to do anything for you or your family?
A. Never.
Q. Okay. Ever give her any ideas about ways Michael Jackson could help you or your
family?
A. Never. I had friends. If I wanted some help I could ask my own friends, and yet I never
did.
Q. Ever ask Evvy Tavasci to arrange any trip for you or your family?
A. Never.
Q. To your knowledge, did she ever do anything like that?
A. Well, she -- when Michael had contacted us for the Miami stuff.
Q. Well, you traveled to Miami on Chris Tuckers plane, right?
A. No, not Chris Tuckers plane.
Q. Did you travel to Miami with Chris Tucker?
A. Yes, I did. And that was per Evvys arrangement. Evvy and Michael had called Chris and
got him pulled into this mess.
Q. Did you hear -- did you watch Michael Jackson call Chris?
A. No, I didnt.
MR. ZONEN: Objection; argumentat ive.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you ever observe Mr. Jackson calling Chris Tucker at any time?
A. Well, its my understanding in Miami, and Chris had told me there at his house, that
Evvy and Michael had contacted him. This is why I became aware.
Q. Did you ever request to travel to Florida with Chris Tucker?
A. No.
Q. Did you ever meet anyone at Neverland named Julio Avila?
A. I think I already said this.
Q. You did not.
A. They -- when I had called and I was already out of Neverland, I called wanting to speak
to my kids. And the person that I was speaking to, I asked them what their name was,
and they said their name was Julio. I think thats -Q. Did you ever speak with anyone named Alex Byrne?
A. No.
Q. Do you know who Alex Byrne is?
A. No.

Q. How about Nancy Catullo?

A. No.
Q. Did you ever speak to Nancy Catullo about setting up a bank account for Gavin?
A. No.
MR. ZONEN: Object ion. No foundation she knows a Nancy Catullo.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you ever seek advice from anyone about setting up a bank
account for the benefit of Gavin?
A. No.
Q. Now, you spoke to Dr. Alex Farshshian, did you not?
A. No, I didnt.
Q. Did you ever meet him?
A. Yes, I did. But we werent introduced. I just knew because I heard them calling him
that.
Q. He was the physician who was on the plane -A. Yes.
Q. -- on the flight back from Miami, true?
A. Yes, I am aware of that.
Q. Did you exchange any words with him at all?
A. No.
Q. Ever meet someone at Neverland named Romero Ruvalcaba Garcia?
A. No.
Q. How about Gary Hearn?
A. Gary Hearn, the extent of my conversations with him was when he would pick up the
kids, and when he told us, Guys, theres been a change of plans, and he took us to
Chriss house. So its just -- he was a driver.
Q. Do you remember him driving your family from Neverland and making various stops to
buy things for you and your family?
A. No.
Q. That never happened?
A. That never happened.
Q. Ever meet someone related to Mr. Jackson named Rio?
A. No.
Q. Did you ever meet someone related to Mr. Jackson named Simone?
A. No. But I did see other children there.
Q. Do you know Arlene Kennedy?
A. Yes, I know Miss Kennedy.
Q. And who is she?
A. Miss Kennedy is someone that I got to meet. Shes the owner of the tap dance school
where my children had attended tap dances. I think my children only attended there for
less than -- Im being generous if I say five months. It was only months. But my
relationship with Miss Kennedy and Mr. Kennedy continued. Shed come and pick me up
and take me to like, for example, a Christian crusade to the Anaheim Convention Center.
Shed come and pick me up and take me to a variety of churches in South Central. Wed
pray a lot on the phone. Shed continuously come and pray for Gavin in the church. I
mean, at -- at the hospital. And then wed request churches to pray for Gavin. She took a
trip to another country and she inscribed Gavins name on somewhere where they could
pray continuously. Its a place where they pray 24 hours. So my relationship with Miss

Kennedy was mostly that of spiritual.

Q. And she ran the dance school your children attended, right?
A. Yes, for less -- my children -- for about five months, thats all. And thats the best I can
recall. No more than five months. But my relationship with Miss Kennedy went on for
years, and Mr. Kennedy.
Q. And your children did attend the school on a scholarship -A. No.
Q. -- because they didnt have funds, right?
A. No.
Q. That never happened?
A. That never happened.
Q. Okay. Now, you called her from Neverland Ranch, did you not?
A. Yes, I did. This was another person that I tried to reach.
Q. You called her after the airing of the Bashir video and said you were at the ranch
because the press was causing problems, right?
A. No.
Q. You told Miss Kennedy that you wanted to get out of the country, correct?
A. No. She would know, too, that theres no way, because she knows the extent of my
sons medical needs. He needs medical care. I know he looks, on the surface, healthy, but
he does have some serious medical issues.
Q. You complained to Miss Kennedy that people around Michael Jackson keep everything
from him and he doesnt have a clue about anything, correct?
A. No. 6719
Q. Never said that?
A. Never said that.
Q. Did you ever tell Miss Kennedy that the people around Michael Jackson keep him in the
dark?
A. No.
Q. Do you recall Miss Kennedy telling you, Go to Michael Jackson directly with these
concerns?
A. No.
Q. How many times do you think you called Arlene Kennedy from Neverland Ranch?
A. I think maybe once.
Q. Are you sure about that?
A. Yeah. I think it was only once.
Q. Only one time?
A. Yes, I did.
Q. You called her many times and never indicated your calls are being monitored, right?
A. No, I called -- I think I called her once. And when I knew that they were listening, I
wouldnt be able to say that, when I felt -- but, yes, I did tell everybody possible when I
could.
Q. Now -A. Because I knew I was being monitored. I knew it.
Q. I understand. You mentioned that you knew Carol Lamir, right?
A. Yes. Thats Davids girlfriend and part of his damage control team in the past. She had
to do something to reinstate herself, and this is it.
Q. When did you first meet Carol Lamir?
A. At the dance school.

Q. That was years before you ever met Mr. Jackson, wasnt it?
A. Yes, this is correct. But she made it very aware.
Q. For how many years did you know Carol Lamir before you ever met Michael Jackson?
A. Let me see. I think my children attended tap there in -- my best recollection is maybe
three years.
Q. And at some point, your understanding is that Carol Lamir arranged for Mr. Jackson to
speak to Gavin, right?
A. My understanding is David has -- had and still has a very close relat ionship with Carol
Lamir, extremely close. David would even go cook at her house. David would even go
spend nights over there. And my understanding is that David was the one that
commun icated to me that Carol Lamir felt that she was the one that introduced Michael
and Gavin, the family. And Jamie, I heard it from Jamie, that he felt it. So I never h ave
known. It was either one of two people. Thats how I feel till this day.
Q. Was it your understanding that Carol Lamir arranged for Mr. Jackson to provide your
family with an automobile so that you could get to the hospital?
A. I wasnt involved with that. All I know is that David and Carol Lamir were, and still are,
very close.
Q. Do you know who first informed Mr. Jackson that you wanted an automobile so you
could travel back and forth to the hospital?
A. I didnt need an automobile. I d idnt ask for an automobile. David and Carol Lamir
were, and still are, very close.
Q. When did you first learn that Mr. Jackson had provided an automobile so you could
travel back and forth to the hospital?
A. When it was delivered to my moms house. I knew it came from him.
Q. Did you ever inquire as to why it was being delivered?
A. No, I didnt.
Q. To your knowledge, did Miss Lamir ever refer you to a woman named Nancy Catullo?
A. No.
Q. And youve indicated you knew Davellin was staying at her house, right?
A. Yes. Until I found out that all Carol wanted my daughter was to clean her house. Thats
it. A little housekeeper.
THE COURT: Lets take our break. (Recess taken.)
THE COURT: Counsel?
MR. MESEREAU: Thank you, Your Honor. Your Honor, the last document I showed the
witness weve marked as Exhibit No. 5008. And I would move that it be admitted into
evid ence.
MR. ZONEN: W hich document is that, Your Honor?
THE COURT: Thats the document you showed her earlier to refresh her recollection?
MR. MESEREAU: Yes, Your Honor.
THE COURT: All right. Thats admitted.
MR. ZONEN: No objection.
THE COURT: You moved it in earlier, Counsel, yourself.
MR. ZONEN: Yes, I understand.
MR. MESEREAU: Im sorry, Your Honor, was that admitted?
THE COURT: Yes, it was.
MR. MESEREAU: Oh, it was. Oh, thank you. Im sorry.
Q. Ms. Arvizo, when did you last see Carol Lamir?
A. I last saw Carol Lamir when she acco mpanied David to Davids criminal domestic

violence proceeding. Thats when I last saw her. And they were holding hands.
Q. Did you ever tell her that David did not provide for the family and you had no food?
A. No.
Q. Did you ever tell her that you had no insurance and needed money to pay Gavins
medical b ills?
A. No.
Q. Ever tell Louise Palanker that David had threatened to kill you?
A. I dont think so, but that is something that David always did.
Q. Pardon me?
A. Thats something that, you know, was customary, part of his own violence.
Q. He would always threaten to kill?
A. But I dont think I told Wheezy that.
Q. Did you ever tell anyone that David often threatened to kill members of your family?
A. I dont think so.
Q. Ever tell the police that?
A. I dont think so. I told them what David would tell me, and that was about his brother
Ray, but Ray had never done that, or said that to me.
Q. Did you ever meet someone named Richard Ramey?
A. No.
Q. Do you know Marian Arvizo?
A. Yeah, thats the one thats friends to the editor of the Mid Valley News. And David,
thats -- theyre -- David and Marian are in cahoots about many things. Such as like the -Q. Im sorry.
A. I came to find out -- a lot of things.
MR. ZONEN: Im going to object as exceeding the scope of the question.
THE COURT: Nonresponsive do you mean?
MR. ZONEN: Yes.
THE COURT: Sustained.
Q. BY MR. MESEREAU: How long have you known Marian Arvizo?
A. The last time I seen Marian Arvizo was when she also went to Davids criminal domestic
violence proceeding. And prior to that, I hadnt seen Marian since, let me see, maybe
when my children -- when my daughter was, I think, two years of age.
Q. Do you recall Marian Arvizo organizing some blood drives for Gavin?
A. No.
Q. Did you ever hear anything about that happening?
A. No. All I know is that shes -- shes the editors friend.
MR. ZONEN: Objection; nonresponsive.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you ever meet someone named Mrs. Marie Triggs? 6725
A. No.
Q. Are you aware of Mrs. Marie Triggs ever trying to organize blood drives for Gavin?
MR. ZONEN: Objection. No foundation that she knows the person.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Regardless of whether you know the person, did you ever learn
that Marie -- someone named Marie Triggs had helped organize some blood drives for
Gavin?
A. No.
Q. Do you remember ever comp laining to Marian Arvizo that you didnt want her to

arrange blood drives for Gavin?

A. No.
Q. Ever tell Marian Arvizo, I dont need your blood. What I need is money?
A. No.
Q. Okay. When did you last see Marian Arvizo?
MR. ZONEN: Objection; asked and answered.
THE COURT: Sustained.
THE WITNESS: I already said.
Q. BY MR. MESEREAU: Ever know of a blood drive being held in Claremont, California, for
Gavin?
A. No.
Q. How about a blood drive being arranged through Vons warehouse where David used to
work?
A. No.
Q. Do you know -- I think I may have asked you Im not sure whether I asked this
question or not, Your Honor. Do you know someone named Bruce Richards?
A. No.
Q. Now, while you were at Hamids home, and before you began the filming of the rebuttal
video, do you recall making some phone calls?
A. No. I made no phone calls.
Q. Do you recall ever being on the phone with anybody before the video was shot?
A. No. The only -- when Brad Miller had dialed the phone and Miss -- Vicki was on there.
Q. Was that at Hamids house?
A. This was at Hamids house.
Q. Did you only talk to Vicki Podberesky that one time?
A. This is the one time.
Q. Okay. Do you know Violet Silva?
A. No.
Q. Now, which employees at Neverland, other than Jesus and Chris, do you recall
meet ing?
A. Thats it. I gave the police every possible information that I could, and thats it.
Q. I want to just clear something up that I said on Friday. The J.C. Penney settlement -excuse me. Let me rephrase it. That agreement to settle was approximately September of
2001, right? 6727
A. I dont think so.
Q. When do you think you settled that case?
A. When -- I think it was -- I know it was after David was arrested.
Q. Actually, he was arrested five days after the agreement was signed, right?
A. Okay. No, David was arrested. Then he was out on bail. And so -- no, it had to be after
he was arrested. Thats the best I can remember.
Q. The agreement was signed September 24th, 2001, right?
A. Okay. I may not understand what his -- the legal words is. Im talking about the end
result, the end result when the J.C. Penneys attorneys and Tower Records attorneys
stood with my civil attorney, and thats what Im talking abo ut. And to my understanding,
thats when the judge approved it. I dont know. So thats what Im talking about. Me and
you may be talking about something different.
Q. Okay.
A. Because I know there was different proceedings prior to that.

Q. But around that time, David was arrested, correct?

A. Yeah, because, you know, he did what he did.
Q. And a couple of weeks after the agreement was signed, you filed for divorce against
David, right?
A. I -- when David showed up to the criminal court proceedings on the first day -MR. ZONEN: Objection; nonresponsive.
THE WITNESS: I already answered that so many times.
THE COURT: Just a moment, please. Sustained. Do you want the question read back,
Counsel?
MR. MESEREAU: Yes, please, Your Honor. (Record read.)
THE WITNESS: I dont know how to answer that. All I know is that David was arrested.
And the first day that he showed up where I was at the criminal proceedings, thats when
he was handed my -- the filed divorce file. And Ive never gone back with him ever again,
so it was serious. That was it. That was enough.
Q. BY MR. MESEREAU: After he was arrested, you were in a leg al d ispute with him as to
how the settlement money would be divided, correct?
A. Incorrect.
Q. Did you go to any type of mediation procedure to settle how much each member was
going to get of the 152,000?
A. No. Thats incorrect.
Q. You dont recall any discussion among lawyers about that, right?
A. Thats incorrect.
Q. Okay. When did you and David agree how much each party was going to get?
A. There was no -- there was no back and forth with that. They -- the civil law firm, they
decided that. But I know -- but I am aware of this, though: Davids -- Mr. Halpern, his
wife -MR. ZONEN: Im going to object as nonresponsive.
THE WITNESS: -- was demanding -THE COURT: Just a moment. Theres no question. Go ahead.
THE WITNESS: Okay.
Q. BY MR. MESEREAU: Okay. David got approximately $5,000 from that settlement,
correct?
A. Thats correct.
Q. Okay. Id like to ask you about purchases made on your behalf by anyone associated
with Michael Jackson, okay? Do you recall a dinner at Outback Steakhouse on February
21st, 2003?
A. No. That didnt happen. I know where I was February 21st.
Q. You never were there with Frank or Vinnie, correct?
A. This is correct.
Q. Okay.
A. As a matter of fact, on the surveillance video, you can see your guy following us. 6730
Q. Well, you were being investigated, werent you?
A. No.
Q. Okay. Youre not aware of Mr. Geragos ever hiring people to investigate you?
MR. ZONEN: Objection; lack of foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: So you never went to Outback Steakhouse, right?
MR. ZONEN: Objection; asked and answered.

THE COURT: Sustained.

Q. BY MR. MESEREAU: Do you recall going to Robinsons-May on February 21st, 2003?
A. No. Thats incorrect. I know where I was February 21st.
Q. Did you ever go into Robinsons-May in Thousand Oaks on February 21st, 2003?
A. No. I remember the day. I think it was the 26th.
Q. You went to Robinsons-May?
A. I think it was the 26th. The same day that my children had gone.
Q. And do you know who paid that bill?
A. That was Vinnie. I think that was Vinnie.
Q. And do you remember what was purchased?
A. No, I cant remember. I think it was -- I think it was a couple of outfits. I think so.
Q. For who?
A. This was for me.
Q. And you were -A. I think so.
Q. Do you recall the bill being approximately $92.24?
A. No, I think it was more like -- I dont know. It was around that price range, though.
Q. And do you recall what clothes you bought?
A. No, I cant remember, because they took them away. They rummaged through the
things when I had finally got out. And not only did they take the things that they had
purchased, but they also took some of our items back. And thats why Mr. Dickermans
letter, it states Childrens clothing. I didnt care about mine.
Q. Would it refresh your recollection if I just show you the receipt -A. It dont matter.
Q. -- as far as the clothes you bought?
A. Ive already seen it.
Q. Do you know what clothes you purchased?
A. And Im acknowledging that on the same day that my childrens things were purchased,
the same items were.
Q. Okay. Do you know what clothes you bought?
A. No, I dont remember.
Q. Would it refresh your recollection to look at the receipt?
A. Sure. If you have the receipt -MR. MESEREAU: May I approach, Your Honor?
THE WITNESS: -- of the 26th.
MR. ZONEN: May I see the receipt, please? This is not the 26th. Your Honor, I believe the
witness has requested the receipt from the 26th.
THE WITNESS: Thats right.
Q. BY MR. MESEREAU: You dont want to see one from the 21st?
A. No.
Q. You deny being in Robinsons-May on the 21st, right?
A. This is correct. I know where I was the 21st.
Q. Do you recall going to Lisas Beauty Supply on the 21st?
A. Thats incorrect.
Q. Have you ever been to that store?
A. No.
Q. Never got hair products there?
A. No.

Q. How about a store called Pacific Sunwear, did you ever go there?
A. I dont think so. I think it was just the -- I think it was -- the best I can remember, it
was in an outlet area. It was a Jockey store, and I think it was a Levi store. And then the
luggages.
Q. And you think you went -- A. On that same day, Robinsons-May. I think -- thats the
best I can remember.
Q. Do you think you went to Robinsons-May on the 25th?
A. No. No, it was the same day, the 26th.
Q. Did you go to Robinsons-May on the 25th?
A. No.
Q. Did you go to Anchor Blue on the 25th?
A. No.
Q. To your knowledge, did Mr. Jackson ever pay for clothing for you at Anchor Blue?
A. No.
Q. How about at Robinsons-May?
A. On the 26th, yes. Which they kept.
Q. And you never went to Pacific Sunwear on the 26th of February, right, 2003?
A. No. The best I can remember is the Levi outlet store, the Jockey outlet store, and then
that luggages. Thats the best I can remember.
Q. Do you recall -A. And Robinsons-May.
Q. Im sorry. Are you finished?
A. Yes.
Q. Do you recall purchasing luggage on February 26th, 2003?
A. Yes.
Q. And what luggage do you recall purchas ing?
A. They were -- they were black.
Q. Do you recall asking for a particular kind of luggage?
A. No.
Q. Okay. And the cost was approximately $127.40, right?
A. I think so. And also -- Vinnie had purchased also for Frank and Vinnie.
Q. For themselves?
A. Yes.
Q. Okay.
A. In that luggage store.
Q. For that trip to Brazil?
A. Yes.
Q. Do you recall going to Banana Republic on February 26th, 2003?
A. No.
Q. Never went there?
A. Never went there.
Q. Do you recall going to the Gap outlet in Camarillo on February 26th, 2003?
A. No. The best I can remember, it was the Levi outlet, the Jockey, the luggage, and the
Robinsons-May. Thats the best I can remember.
Q. Do you recall charging up $436.77 at the Levi outlet on February 26th?
A. That sounds about correct.
Q. Do you recall eat ing at the Woodland Hills Black Angus on February 26th? 6735
A. I think that -- I think thats correct.

Q. And who did you eat there with?

A. It was Frank, Vinn ie, the three kids, myself, and they were filming that for Michaels
positive PR.
Q. And the bill was $175.34, approximately, right?
A. I never saw the bill. I never saw the bill.
Q. All right. Do you recall shopping at The Foot Locker on February 26th, 2003?
A. No. Thats incorrect.
Q. Didnt go there?
A. No.
Q. Didnt get any shoes for your son there?
A. No.
Q. Okay. Do you recall going to Abercrombie & Fitch on February 26th, 2003?
A. No.
Q. Didnt go there at all, right?
A. Thats correct.
Q. Okay. And you do recall Robinsons-May in Canoga Park on February 26th, right?
A. I dont know what city it was, but it definitely was February 26th. Some things just -are just stuck in there.
Q. Would it refresh your recollection if I just show you the receipt?
A. Like I said, if it happened February 26th, then it did happen.
Q. Okay. Do you know what clothes you bought there on that day?
A. No, I cant remember.
MR. ZONEN: On what day? Objection; vague.
MR. MESEREAU: February 26th, 2003.
MR. ZONEN: W here is this?
MR. MESEREAU: Robinsons-May in Canoga Park.
Q. Do you know what clothes you bought there?
A. No, I cant remember. But besides that, Frank had taken all the clothes that they had
purchased. And when he was rummaging through our bags, he also took some of my
childrens clothing that belonged to them that they did not purchase.
Q. Were you shopping with Frank or Vinnie on February 27th, 2003?
A. No.
Q. Didnt go to Robinsons-May on February 27th?
A. No.
Q. Didnt go to Rite-Aid?
A. No.
Q. Didnt go to Anchor Blue, right?
A. No.
Q. Okay. Do you recall going to Hsongs Barber Shop on February 28th?
A. No.
Q. Do you recall going to Adidas on February 27th of 2003?
A. No.
Q. Do you recall going to Old Navy on February 27, 2003?
A. No.
Q. Now, do you recall going to Robinsons-May on February 27th, 2003?
A. February 26th. Its burned inside my memory.
Q. And where was that Robinsons-May located?
A. Right next to -- right next to the hotel where we were at.

Q. Was that across the street?

A. No.
Q. Do you recall ever going to Canoga Park during this period of time?
A. I dont know what the city was. I just know that it was near there. Thats all.
Q. Do you recall going to Anchor Blue on March 1st?
A. No.
Q. How about Robinsons-May on March 2nd for cosmetics?
A. No.
Q. How about Lovely Nails on March 10th?
A. March 10th is the nails -- the nail shop.
Q. And that was for a manicure and a pedicure, correct?
A. No.
Q. It was a $115 bill paid by Mr. Jackson, true?
MR. ZONEN: Objection; lack of foundation.
THE WITNESS: No.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you recall -- let me rephrase this. Do you recall sending any
employees to do shopping for you while you were there?
A. No.
Q. So that never happened?
A. Never happened.
Q. Okay. Where was Lovely Nails located?
A. Right by Jays work.
Q. And do you know who paid that bill?
A. Vinnie did.
Q. Do you recall Gavin getting a haircut during that period of time?
A. No.
Q. Do you recall ever asking Frank or Vinn ie to buy cosmetics for you?
A. No, that didnt happen.
Q. Never h appened?
A. No.
Q. Did you ever go to any store where you could pick out cosmetics that they would
purchase?
A. No.
Q. What restaurants do you recall eating at with Frank or Vinnie?
A. The Black Angus one. And it was one meal, while we were in the hotel. It was one meal
per day. And they were filming the whole thing. So Black Angus is one of them. But thats
the best I can remember. And we had to stay in the hotel.
Q. So youre saying you were limited to one meal a day while you were filming?
A. Yes. This is correct.
Q. And where were you filming?
A. I wasnt filming. Your people were filming. And when wed go eat. At Black Angus was
one of them.
Q. Let me get this straight. Youre staying at the hotel, right?
A. Yes.
Q. And youre saying youre limited to one meal a day, right?
A. Yes.
Q. While youre being filmed; is that correct?

A. No, not while we were being filmed. They would film the event. They would film the
dinner for Michaels positive PR.
Q. So a dinner was filmed at Outback Steakhouse?
A. If in that time period, it falls within that time period, it did happen. But the best I can
remember is only -- what he just said, is Black Angus. I do remember that.
Q. And who do you remember eat ing at Black Angus with?
A. Frank, Vinnie, my three children, me, yes.
Q. Do you recall around November 9th, 2001, buying an automobile?
A. November 9th?
Q. Yes.
A. Of what year?
Q. 2001.
A. No.
Q. Did you buy an automobile around that period of time?
A. No, I didnt.
Q. Okay. Were you taking the bus all the time then?
A. Yes.
Q. And you -- again, just for the record, you moved in with Jay Jackson approximately
December of 2002; is that right?
A. Thats incorrect. I moved when they took my place away.
Q. Okay.
A. And that was in March of 2003.
Q. Were you spending time at Jay Jacksons home starting December of 2002?
A. I visited Jay throughout -- since I first met him. He was my -- it was a new
relationship. I really liked being with him, me and the kids.
Q. And did you start spending a good portion of the week there approximately December
of 2002?
A. No.
Q. When did you start spending days at Jay Jacksons home?
A. Again, this is like three years ago now probably. Well, when you guys took my place
away. I had nowhere else to go.
Q. Were you spending most of the week at Jay Jacksons home before the Soto apartment
was vacated? Yes or no.
A. I would ride the bus with my children on the metro rail. Id take them to school. And
then Id go and -- to Jays apartment and make myself serviceable with cleaning his
house, do just something, and then go pick up the kids. And he would let me know how
long he was going to be at work. If he was going to stay longer, then Id just go home.
Q. Do you know approximately -- let me rephrase that. You first met Psychologist Stanley
Katz in May of 2003, true?
A. I think so. I think so.
Q. You met him through Larry Feldman, right?
A. Yes. This is correct.
Q. And you told the jury that at some point you first learned about any molestation
through the Santa Barbara police, right?
A. I already felt and were aware that things were a mess. But it was confirmed when the
police and the D.A.s Office made me aware. Mr. Robel had explained to me that Gavin
had entrusted something with him -MR. MESEREAU: Objection. Move to strike; nonresponsive.

THE COURT: Sustained.

Q. BY MR. MESEREAU: You claim you first learned about any alleged molestation in
September of 2003, correct?
A. I dont understand what hes saying, but I was becoming aware of things through Gavin
and Star, little by little by little.
Q. You claim that you learned about any alleged mo lestation in September of 2003 from
Prosecutor Sneddon, Sheriff Klapakis and Sheriff Robel, right?
A. Yes.
MR. MESEREAU: I have no further questions.

REDIRECT EXAMINATION BY MR. ZONEN:

Q. Ms. Arvizo, good afternoon.
A. Good afternoon. 6743
Q. Mr. Mesereau had asked you about a Mary Holzer. Who is Mary Holzer?
A. Mary Holzer, she is the last -- what I know, shes the office manager of the Rothstein
civil law firm, and shes a humongous Michael Jackson fan.
Q. What do you mean by that?
A. Well, when she was taking me back and forth to the various visits, because I didnt
have a car, she was continuously asking, requesting, begging to meet Michael Jackson.
Q. Did you ever tell Miss Holzer that the injuries that you sustained after the J.C. Penneys
incident were given to you by your husband?
A. Never.
Q. Is it the case that the injuries that you sustained in the J.C. Penneys case were
received by you by your husband?
A. If the -- on the day the J. -Q. Yes.
A. Say it again.
Q. Is it the case that the injuries that you suffered during -- that the injuries that you had
were received by your husband and not by J.C. Penneys?
A. I kind of dont understand.
Q. Let me ask that question again.
A. Okay.
Q. Were you injured during the J.C. Penneys arrest?
A. Yes.
Q. Now, what happened in that arrest?
A. The J.C. Penneys and Tower Records injured me and both my boys.
Q. How did that happen?
A. Well, they clobbered me.
Q. How did you happen to be there?
A. Well, because I was -- I had already gotten a loss prevention agent job for Oshman
Sporting Goods.
Q. Where was Oshman Sporting Goods?
A. It was inside the mall.
Q. Were you at Oshman Sporting Goods?
A. Yes, I was.
Q. Was your husband with you?

A. No, he wasnt.
Q. Were either of your two children with you?
A. No, they werent.
Q. Where did they go?
A. They went with David.
Q. And Mr. Mesereau had asked you if, in fact, you had learned your son Gavin had
walked out of the store with items. How old was your son Gavin at that time?
A. I think my best -- they were in the summer of first grade, and I think -- I think both -I think either -- I think it was six and seven. Six and seven, I think.
Q. This was before Gavin was ill with cancer; is that correct?
A. Yes, way before Gavin was ill.
Q. At some point, did you learn that he had walked out of the store with something?
A. Yes.
Q. What was the item he walked out with?
A. Two school uniforms and two school uniform pants.
Q. Was David Arvizo with him at that time?
A. Yes, he was.
Q. All right. Now, what was the first thing you saw or learned that day?
A. Well, the first thing I saw was David getting hit by a male and a female. And this is -- I
dont know if you know malls. Like -Q. Just tell us what you saw.
A. -- way far.
Q. Just tell us what you saw. What did you see?
A. I walked out and I saw that David was getting hit by a male and a female.
Q. Did you know who they were?
A. No, I didnt know.
Q. Were they wearing uniforms?
A. No, they werent.
Q. Did you have any reason to believe that they were security?
A. No, I didnt.
Q. What did you do?
A. Well, I figured, you know, they might think -- I might be able to startle them with my
two phrases, and those two phrases are also burned here. I told them, What are you
doing? Whats going on? Because I figured by saying that, that would spook them and
they would run.
Q. What happened?
A. Instead they turned around and just clobbered me.
Q. Were you arrested by them?
A. Yes, I was.
Q. Were you injured by them?
A. Yes, I was.
Q. Hold on just one second. Where were you injured and how were you injured?
A. Okay. The best I can remember is they broke my hand, my left hand. They made some
-- like a little bump here, pop out, from my wrist. They, you know, hit -- punched all over
my body. Lets see. They did significant muscle damage on my back. Hit my face. A ll over
my body. Thats the best I can remember.
Q. Where did you have bruises on you?
A. My legs. My arms. A little bit on my face. But thats -- thats the best I can remember.

Q. Were you arrested that day?

A. Yes, I was arrested.
Q. Were you taken to jail?
A. I was taken to jail.
Q. Was David Arvizo taken to jail?
A. Yes. David was taken to jail.
Q. Were you charged with any criminal offense?
A. Yes.
Q. What were you charged with?
A. I was charged with burglary, assault and battery, and petty theft.
Q. Did you ever actually go inside J.C. Penneys?
A. I never even went inside that store.
Q. Were those charges ultimately dismissed?
A. Yes.
Q. Was the lawsuit with J.C. Penney filed before or after the charges were dismissed?
A. It was after.
Q. Did you have photographs that were taken of your injuries?
A. Yes.
Q. After you were released from jail, what did you do?
A. After I was released from jail, the best I can remember is I remember the -- the jail
person giving me the car keys, so I walked over to the mall parking lot. The best I can
remember is I picked up the car. My children at this point had already been taken by my
parents, because the police officer d id not want to take custody of my children. So they
waited for my parents to arrive before I even went to the jail. Right there in the parking
lot, the police handed over my two boys. And -- but after I came out of jail, and then I -- I
dont know whether this came first or after, I went to go do a drug test, because thats
what I went to go pick up at the -- at Oshmans. I had already been given the job. I just
had to do -- it was -- they said it was a mere technicality. All I had to do was submit to an
alcohol -- I mean, what they -- those drug tests. And -Q. Was that a urine exam?
A. Pardon me?
Q. A urine test?
A. Yes, it was.
Q. Where did you have to do that?
A. It was really close to the mall, right there.
Q. Did you do it that night?
A. Yes, I did it. And they time-stamped it.
Q. Where was your husband at that time?
A. At that time, I believe hes still in jail.
Q. All right. The kids were where?
A. The kids are with my parents.
Q. Do you know approximately what time it was?
A. At this time?
Q. Yes.
A. No, I dont. I know it was right before I ended up going to Kaiser.
Q. All right.
A. Which that was also time-stamped.
Q. Did you have a car at that time?

A. At that time, yes, it was a mini-van.

Q. And where was the vehicle?
A. The vehicle was at the -- still at the shopping mall.
Q. All right. And then where did you go with the -- did you get the vehicle at some point in
time?
A. Yes, I did.
Q. I believe that I walked over and went and picked it up myself. Do you know
approximately what time it was that David Arvizo was released from custody that night?
A. No, I dont. I just know that it was minutes before we went to Kaiser.
Q. All right. Did you, in fact, go to Kaiser that night?
A. Yes, I did.
Q. Did you do that soon after David Arvizos release?
A. Yes, like that.
Q. Did he inflict any injury on you at any time from the time he was released from custody
to the time -A. No.
Q. -- that you arrived at Kaiser Hospital?
A. No, he didnt.
Q. All right. And did they attend to you injuries when you got to Kaiser Hospital?
A. Does that mean like -Q. Did they treat your injuries at that time?
A. Yes, they did. They did.
Q. You said your kids were picked up by your parents at that time?
A. Yes, at the shopping mall. They didnt even take them -- the police wanted to release
the children right there to my parents. They didnt want to take them into custody.
Q. Were either of your children injured in the course of that altercat ion?
A. Yes, they were.
Q. Which children were injured?
A. They broke Gavins arm. They gave him a b lack eye. Star, they gave him a concussion.
Thats the best I can remember.
Q. Was there a settlement on behalf of Star and Gavin?
A. What does that mean?
Q. In other words, did they receive money?
A. Yes, they did.
Q. Do you recall how much they received, approximately?
A. No, I dont recall. Ive never touched it. Its still sitting there.
Q. I believe you just said there was an amount of money that was received by both Star
and Gavin.
A. Yes.
Q. You dont recall at this moment how much that was?
A. No, I dont. Thats -Q. Did one receive more than the other?
A. Yes.
Q. Was that reflective of the injury?
A. I think so.
Q. Which one? Which of your children received the greater amount?
A. Gavin did.
Q. I think you said it went into a bank account; is that correct?

A. Yes.
Q. And is it still there?
A. It is still there.
Q. How long will it remain in that bank account?
A. Till they become adults.
Q. Id like to show you two exhibits, please, No. 820 and 821. Take a look at those two
exhibits, if you would.
A. Okay. Okay.
Q. Are those exhibits familiar to you?
A. Yes, they are.
Q. All right. And do they reflect the amount of money that was received by each of those
two children?
A. Yes. It is correct.
Q. Can you tell us, then, how much money it was for each one?
A. Gavin is -- to the dollar? To the penny?
Q. Yes.
A. Okay.
Q. As long as its in front of you.
A. Okay. Gavin is 25,595. And Stars is $8,576.
Q. Have either you or your husband had -- your ex-husband David had access to that
money at all?
A. No.
Q. And thats per the conditions of that settlement; is that correct?
A. Yes, this is correct.
Q. Tell us how much you received on that.
A. Myself?
Q. Yes.
A. The best I can remember, myself, I received 32,000.
Q. All right. And how much did David receive?
A. David received 5,000.
Q. All right. Now, the total judgment on that was something over 150,000; is that right?
A. This is correct.
Q. What happened to the rest of the money?
A. The attorneys -- it went all to the attorneys.
Q. Were there medical expenses as well?
A. I think so. I -- it came -- it was disbursed from the law office. What they did with it,
they would know best.
MR. ZONEN: May I approach the witness, Your Honor?
THE COURT: Yes.
Q. BY MR. ZONEN: Im showing you a collection of documents that are numbered 819 for
identification. 819, a series of photographs. And theres actually 19 pages in here. Excuse
me, 16 pages. 16 pages. Take a look at that, if you could, and lets start with each one of
those pages. Can you tell us the content of the subject matter of that first page?
A. It is me. I do have a bra on. And it shows bruises on my arms and my legs.
Q. Go ahead and go to the next page. And the two top photographs are who, please?
A. Theyre both of me.
Q. And they show injuries where?
A. On my legs, on my arms, and then wearing that thing on my wrist.

Q. And the thing on your wrist is a brace?

A. Yes. First it was the cast, and then it went -- they did that after they cleaned it up.
Q. Okay. And then the two bottom photographs on the second page of this exhibit.
A. Theyre both of Gavin.
Q. Okay. And what injury did Gavin have?
A. He had a broken arm.
Q. Okay. Was it at his elbow?
A. I think it was his elbow. Im -- or up here. I dont remember very clear. It was either up
here or his elbow.
Q. Okay. How old was Gavin?
A. The best I can remember, six or seven.
Q. Okay. Go to the next page, please.
A. Okay.
Q. No. 3 reflects what, the two top photos?
A. Its of my hand, and myself sitting down.
Q. And the two bottom photos?
A. Of me with the bruises.
Q. All right. And the bruises are where in those photos?
A. My arms and my legs.
Q. Go to the next page, please, No. 4. And where are the bruises in these four
photographs?
A. On my arms and my legs.
Q. The front or back of your legs?
A. The back.
Q. All right. Go to the next page, please, No. 5, and tell us what these photographs depict.
A. Theyre of my legs.
Q. No. 6, page six, what do these photographs depict?
A. Still on my legs.
Q. And these are bruises on the bottom and top portion of your leg?
A. Yes.
Q. Go to the next page, No. 7. What does that reflect?
A. Bruises still on my arms and legs.
Q. All right. Next page, please.
A. And I think this is Gavins arm up here.
Q. So on page seven of the four photographs in that -- on that -- depicted on that page,
the upper right, you believe, is Gavins elbow?
A. I think so.
Q. All right. Go to the next.
A. Okay.
Q. Four pictures on page eight, what are they?
A. Theyre of myself.
Q. Okay. And the two top ones, or the top one on the left, what does that depict?
A. The top left is a full b ack side of how I looked.
Q. And it shows bruising where?
A. On the back of my arms, and the back of my legs.
Q. Okay. And on the right side at the top, what does that depict?
A. My arms from the front side.
Q. Okay. And then the bottom picture on the left?

A. Of my wrist.
Q. And then the picture on the right?
A. Of my face, right cheek.
Q. What kind of bruise did you have on you right cheek?
A. Like a -- like this.
Q. All right. Go to the next page. This is page nine. Lets turn it on its side. Tell us what -the picture of the little boy, which little boy is that?
A. This is Gavin.
Q. And that shows his arm?
A. Yes.
Q. And then the two other pictures?
A. This was the scrape that he had on this arm, and it shows his black eye.
Q. Okay. And then the other two pictures apparently are -- no, go back.
A. Oh.
Q. On the same page, which is page nine, there are two other pictures. That is of you?
A. Of my legs.
Q. And then the four photographs on page ten?
A. Theyre all the same. And theyre just showing my upper arms.
Q. Okay. And page 11?
A. My upper half and one of full body.
Q. Okay. So these are -A. Showing bruises.
Q. -- bruises, upper chest and your upper arms?
A. Yes.
Q. Okay. Page 12?
A. A front view of me.
Q. Okay. Page 13, one photograph.
A. Of Gavin.
Q. And thats his arm?
A. Yes.
Q. Page 14?
A. I think this is because its showing a scrape on that arm.
Q. Okay. Page 14, four photographs of what?
A. Of right here.
Q. The wrist?
A. Yes.
Q. Page 15?
A. My son Gavin.
Q. Thats Gavin?
A. Yes.
Q. With his arm?
A. Yes. Yes.
Q. And finally, page 16?
A. This is Gavin with his broken arm.
Q. All right. When were those photographs taken?
A. Immediately.
Q. By immediately what do you mean? That day, or the next day, or when?
A. I think it was -- the best I can rememb er, I think it was -- I think it was the next day

right after we had taken -- I think it was after the boys had received medical services. I
think thats the best I can remember.
MR. ZONEN: Your Honor, Im going to move to introduce these photographs, which is
Exhibit 819, into evidence at this time.
MR. MESEREAU: No objection.
THE COURT: Theyre admitted.
MR. ZONEN: May I have just a moment, please? Your Honor, Id like to publish these
photographs, or some of them. Id like to publish these photographs at this time.
THE COURT: All right.
Q. BY MR. ZONEN: Lets start with the two on the top of page two of this exhibit. And Miss
Arvizo, go ahead and look at this. These are the top of page two. And describe for us,
please, what were looking at, the injuries. First start with the pictures on the left.
A. Thats me. This is me sitting down and showing the bruises from -- from this, this part
right here, my legs and my lower half.
Q. All right. And the picture on the right?
A. Yes, my legs.
Q. Its page six of that exhibit. Tell us specifically what were looking at here, please.
A. Kind of like a little diagonal view of my legs.
Q. And that shows the bruises where on your legs?
A. On my -- the front part of my calf area.
Q. All right. And on both legs?
A. Yes. On both legs. And you can see a little bit of the back part of my thighs.
Q. Also page six on the lower left-hand corner. Can you describe what were looking at in
that photograph?
A. Bruising on the back side of me. And theres that -- the thing over my hand.
Q. And on your left hand?
A. Yes.
Q. And this is page number seven. On page number seven, would you tell us, please, what
were looking at on that photograph?
A. Thats from a sitting position, I think its di -- I think its diagonal in the other direction
of the bruises on my arms and my legs.
Q. On both legs -- both arms?
A. Both arms.
Q. And both legs?
A. Yes.
Q. Exhibit No. 8, No. 8 of this exhibit, tell us what that one is, please.
A. This is a -- a back side of me. And then you can see a little bit of the -- of the
underarm, showing that, showing my right arm.
Q. And what are we looking at on this picture?
A. I had -- I had bruising and a little bit of swelling right here, my right cheek.
Q. And thats also Exhibit No. 8.
THE COURT: I think youre referring to the page number.
MR. ZONEN: Yes, page number. Exactly.
Q. That was who now?
A. This is Gavin.
Q. And he had his hand at that time in a sling; is that right?
A. Yes, he did.
Q. And a cast?

A. He had a cast.
Q. We can have the lights back on. You were asked some questions about a car that had
belonged to Chris Tucker. Did Chris Tucker ever actually offer you a vehicle?
A. Chris Tucker gave it to me and the kids as a Christmas present from him and Aja. It
was Ajas old car, but Chris had taken the kids to buy Aja a birthday present, as a surprise
birthday present, and he had the kids pick Ajas new color of her car for her birthday.
Q. Now, did you actually ever drive that car?
A. I never drove that car.
Q. Did you ever take possession of it?
A. I never took possession of the car.
Q. Do you remember when it was that he offered you the car or gave you the car?
A. It was for Christmastime. And he hadnt seen me and the kids, neither did Aja, so the
first time he got to see us was at his home, and thats when he gave it to me.
Q. Did -- you say he gave it to you. But how is it you never took possession of it?
A. Well, because he says, Heres the keys. And this is yours and the kids Christmas
present.
Q. And -A. It was Ajas old car.
Q. But tell me why you didnt drive away with it.
A. Because. In Miami -- remember way in the beginn ing I had told you that I had tied a
garbage bag which I had p laced my Timberland shoes inside a Turnberry bag and I tied it
so tight to my red sports bag that the only way you can take this bag off was by ripping
it? Thats it. And that disappeared. I didnt see it till -Q. Are you telling us that had the keys in it?
A. Yes, that had the keys in it.
Q. All right. Now, again, that was early February when you went to Miami?
A. Thats correct.
Q. Where was the car between Christmas and early February?
A. At Ajas house.
Q. All right. Did you -- you took the keys, but you never got the car?
A. Thats correct. On that day was when Chris had told me that Aja and Chris had been
looking for us to give us a Christmas present.
Q. All right. So when exactly was it that they gave you the keys?
A. The day I went to Chriss house.
Q. To go to Miami?
A. To go to Miami, yes.
Q. Okay. All right. So it was not a Christmas gift to you. It was a Christmas gift to Aja?
A. No.
2 Q. The new car?
A. No. I dont know if I explained it correct ly. Aja had gotten a brand-new Mercedes for
her birthday. This was now Ajas old car, which was just sitting in her -- in her driveway.
So Chris and Aja decided that they wanted to give me and the children this car for
Christmas, but they were unable to locate us.
Q. All right. It wasnt until the -A. Until -Q. He went to Miami?
A. Yes, thats correct.
Q. So the keys you took, but you never got the car?

A. Exactly.
Q. Did you ever have a conversation with either Aja or Chris Tucker after you got back
from Miami -A. Well -Q. -- about the car?
A. With Chris, never again.
Q. You never had another conversation with Chris?
A. I never had.
Q. And with Aja?
A. With Aja, I think so. I think it was -- I think it was, yeah, I was able to tell her, Thank
you.
Q. Did you ever see the keys again?
A. I never saw the keys again.
Q. You never took the car, never drove the car?
A. No, they disappeared with my garbage bag.
Q. Now, the vehicle that was a gift to Gavin from Mr. Jackson, do you know the difference
between a Bronco and a Blazer?
A. No, I dont.
Q. If I were to ask you to describe one against the other, would you know?
A. No, I wouldnt be able.
Q. Do you remember what co lor it was?
A. I do remember that. It was white.
Q. Do you know what the letters SUV stand for?
A. No. No.
Q. If somebody were to say SUV to you, does that -A. The best I can -Q. Hold on. Does that conjure up in your mind some kind of a vehicle?
A. Yes.
Q. SUV?
A. Yes.
Q. What kind of a vehicle?
A. Kind of like a half truck, half pickup with enclosure, like a camper, all fused together.
6765
Q. Okay. Was it that kind of vehicle that Mr. Jackson gave you?
A. Yes.
Q. Do you know the difference between a GMC and a Ford?
A. No, I dont.
Q. Do you know what the letters GMC stand for?
A. No.
Q. Did somebody tell you it was a Bronco?
A. Yes.
Q. Who?
A. David did.
Q. All right. Now, this car actually did come into your familys possession; is that right?
A. Yes, it did.
Q. Did you ever get any documentation on it; in other words, a registration of some kind,
or a pink slip?
A. No.

Q. Do you know what -- when I say pink slip, do you know what that means?
A. Yes, I do know that.
Q. And registration, do you know what that means?
A. Yes.
Q. Have you ever actually bought a car yourself?
A. No. Let me see. I think a long, long, long time ago, I may have been a co-signer, I
dont know, of a red Nissan Sentra.
Q. Did you ever actually walk into a car dealership by yourself and pick out a car and
purchase it?
A. By myself, never.
Q. On this particular case, I asked you about documentation, a pink slip or a registration,
and you said, I think, they d id not give you that; is that right?
A. Yes, thats correct.
Q. So you were talking about a document with a VIN number on it.
A. Yes.
Q. What was that?
A. Okay. I had -- there was a -- like a long number thing, and I had written it down on a
piece of paper.
Q. So you wrote the number yourself?
A. Yes, I did.
Q. And tell me why you did this.
A. Because -- just so I know that that was the car that belonged to that. Thats all.
Q. But you did that at a time that you had the car in your possession?
A. Yes.
Q. All right. How long was -THE COURT: All right. Counsel, well end for today. Remember the admonit ions.

2005 April 19 (Day 35) End J Arvizo Testimony plus B. Barron

JANET ARVIZO REDIRECT EXAMINATION

REDIRECT EXAMINATION BY MR. ZONEN:
Q. Yesterday, there were a number of questions that were asked about that taperecording of the phone call, or series of phone calls, between Frank and you that you
listened to in court early in your testimony, and you had testified previously that you
believed it was a compilation of a few different calls; is that correct?
A. This is correct.
Q. All right. Now, at any time during the series of telephone conversations that you had
with Frank after you had left Neverland on that first occasion, did you talk with him about
the specific issue of danger?
A. Yes.
Q. And what specifically did you tell him?
A. The death threats about my children.
Q. How often did you bring up that subject in the course of those conversations?
A. Every single time.
Q. You were asked some questions about attorneys that you had seen over the last
number of years, and why you might have contacted an attorney to deal with Mr. Jackson.
Do you remember those questions from Mr. Mesereau?
A. Yes, I do.
Q. Its a little confusing because apparently you have at one time or another dealt with
two attorneys by the same name, Feldman; is that correct?
A. This is correct.
Q. The attorneys that you went to with regards to the J.C. Penneys lawsuit. What was the
name of that law firm?
A. The law firm was called Rothstein & Feldman.
Q. All right. Now, the Feldman that were referring to, is that Larry Feldman?
A. No. That is not Larry Feldman.
Q. Its a different Feldman?
A. It is a different Feldman.
Q. Do you know his first name?
A. I come to know now that his name is George Owen Feldman.
Q. Did you actually deal with Mr. Feld man, George Feldman?
A. Ive never dealt with George Owen Feld man.
Q. Who are the attorneys from that law firm, Feldman & Rothstein, who you actually dealt
with?
A. From that law firm, dealt with Mr. Rothstein, Anthony Ramieri, and a Michael Adler.
Q. Now, did you contact Feldman & Rothstein?
A. And -Q. Not Larry Feldman?
A. There was one more, but he was with Michael Adler.
Q. Did you contact the law firm of Feld man & Rothstein for purposes of dealing with
Michael Jackson in any way?
A. No.

Q. When was the first time issues of Michael Jackson or actions involving Michael Jackson
came up with a lawyer?
A. Mr. Dickerman.
Q. And then Larry Feld man thereafter?
A. Then Larry Feldman thereafter.
Q. There were questions that were asked of you by Mr. Mesereau as to the amount of
money that Louise Palanker gave to you or your family. Did you ever ask Louise Palanker
for money?
A. No.
Q. How many separate checks were turned over to your family by Louise Palanker?
A. It was two checks in the amount of $10,000.
Q. All right. Were you present at the time either of those checks were written?
A. I wasnt present.
Q. Were you present at either time the checks were g iven to you?
A. No.
Q. Did you know in advance that David was going to be given that money?
A. No.
Q. Did he discuss it with you in any way prior to him getting the money from Louise
Palanker?
A. No.
Q. Did you assist in cashing or depositing either of the two checks?
A. No.
Q. Were you aware that one of them was written to you?
A. Yes.
Q. Did you have to endorse that one, sign it?
A. Yes, I did.
Q. Theres been a lot of testimony so far about 6776 the cleanroom at your mothers
house for Gavin while he was ill. The money that came to create that clean room came
from where?
A. From Wheezy, Louise Palanker.
Q. Did you have any conversation with Louise Palanker, either before or after that check
was given to you, about how that check would be used?
A. No.
Q. Were you given any money by Fritz Coleman?
A. No.
Q. Did you ever ask for money from Fritz Coleman?
A. No.
Q. Were you given any money by George or Ann Lopez?
A. No.
Q. Did you ever ask for money from either George or Ann Lopez?
A. No.
Q. Were you present at any time when that issue of a wallet became the subject of
discussion between George Lopez and your husband, your then husband David Arvizo?
A. No.
Q. Were you aware of that at the time that it happened?
A. No.
Q. When did you first learn about that incident?
A. I think I heard it from Jamie. And this was after David was no longer with us.

Q. At some point in time, did you learn that there was an unnamed benefactor who was
prepared to give you money?
A. Yes.
MR. MESEREAU: Objection. Leading and beyond the scope
THE COURT: Overruled. The answer was, Yes. Next question.
Q. BY MR. ZONEN: Who is it who told you about that?
A. Jamie.
MR. MESEREAU: Objection. Leading; beyond the scope.
THE COURT: Overruled.
MR. ZONEN: The answer is in
THE COURT: The answer was, Jamie.
Q. BY MR. ZONEN: Was that Jamie Masada?
A. Yes, that was Jamie Masada.
Q. What was your response to this offer of money?
A. I told him, No, thank you; that all I wanted was friends and prayers.
Q. Do you know the name of the person who was this benefactor?
A. I never knew.
Q. Do you remember when that took place?
A. This was -- the best I can remember, it was after all this Neverland stuff happened.
Thats the best I can remember.
Q. Did you ever ask Jay Leno for money?
A. No.
Q. Did you ever meet Jay Leno
A. Ive never met Jay Leno.
Q. Did you ever have a telephone conversation with Jay Leno?
A. Ive never had a telephone conversation with Jay Leno.
Q. Were you ever present at the time your son made any telephone calls to Jay Leno or
had a conversation with him?
A. No.
Q. Were you present at any of the fund-raisers that took place at The Laugh Factory?
A. No.
Q. Mr. Mesereau asked you questions about medical insurance covering Gavins illness
during that period of time. Did his med ical insurance cover all of the expenses of his
illness during that period of time?
A. Yes. This is correct.
Q. Did you ever tell anybody that -- that insurance was not covering the medical
expenses?
A. No.
Q. Were you ever concerned about whether the medical insurance would continue?
A. I was concerned because David wasnt working. He didnt want to go back to work.
Q. Did you express that concern to anybody, to your recollection?
A. To my recollection, I dont think so.
Q. At one point you purchased an automobile -- or, excuse me. At one point -- let me do
that one more time. You were asked a question by Mr. Mesereau as to whether or not you
purchased an automobile. Did you actually take steps towards purchasing an automobile?
A. Yes, I did.
Q. What was it that you did toward purchasing an automobile?
A. Okay. I had -- I had called a car dealership from a phone booth, from the phone book.

And the person -- they transferred me over to the sales department. And the gentleman
who spoke on the phone sounded really nice. So I figured thats the way Im going to go,
through this dealership, through this man. And then -Q. Which dealership was it?
A. I think it was -- I dont remember. But I remember it was -- I think it was Hollywood
Ford. I think it was. Thats the best I can remember. 6780 And so I had a -- I dont know
whether it was a travelers check or a cashiers check, one of those things made out to
that, in that amount, but I then changed my mind and I had it cancelled. But I -- so I
never did purchase a car.
Q. Okay. You had a travelers check that you actually mad e out for a certain amount of
money?
A. Yes, I did.
Q. Were you able to cancel that check?
A. Yes, I was. I -- yes. I didnt follow through with the purchase of the car.
Q. You were asked questions about conversations with Mr. Jackson by Mr. Mesereau. Prior
to the phone call on the 5th of February, or the date that you received that phone call
from Mr. Jackson when he was in Miami, invit ing you to come to Miami, had you had any
conversations with Mr. Jackson prior to that day?
A. No.
Q. Had you asked him for any money?
A. No.
Q. Prior to that date?
A. No.
Q. Or since that date?
A. No.
Q. Did you receive any money from him?
A. No.
Q. What was the state of your -- what was your life like prior to that phone call?
MR. MESEREAU: Objection; vague.
MR. ZONEN: Let me change the question.
Q. On the 4th of February, the day before you received that phone call, were there any
problems that you were dealing with at that time?
MR. MESEREAU: Objection; vague.
THE COURT: Sustained.
Q. BY MR. ZONEN: Were your children healthy prior to that?
A. Our life prior to Mr. Jacksons -Q. No, just limit it to just the question.
A. Okay.
Q. Were your children healthy in early February?
A. Yes.
Q. Gavin was dealing with no medical issues other than the ones that he deals with on a
regular basis?
A. This is correct.
Q. How long had you been in a relationship with Mr. Jackson at that time, Major Jackson?
A. It was a new, promising relationship with him.
Q. Were you aware, prior to Mr. Jacksons telephone call to you, that he was even in
Miami?
A. No.

Q. Did you express any desire to anybody to go to Miami?

A. No.
MR. ZONEN: Your Honor, finally, this might be beyond the scope of the cross-examination
in which I would ask the Courts indulgence to reopen. Ive advised Mr. Mesereau of this.
We neglected to show part of the surveillance tapes. We missed it on Friday. And Id like
to show the last part of it. Its about 60 seconds worth, if I could do that at this time.
MR. MESEREAU: Beyond the scope, Your Honor.
THE COURT: All right. Ill allow you to reopen.
MR. ZONEN: Thank you.
Q. You had previously seen some surveillance tapes prior to coming into court and then
you saw some surveillance tapes on Friday. This is an additional footage Id like to show
you at this time. And then were going to stop the tape and have you identify it. If you
could turn down the lights, please.
THE COURT: Its going to be on Input 1?
MR. AUCHINCLOSS: Yes, Your Honor. And were on Input 1, Your Honor?
MR. ZONEN: Bob, did you rewire this?
THE COURT: I think you all ought to go together and hire a teenaged boy to handle this
for you. (Laughter.)
MR. ZONEN: Any teenaged boy.
MR. SANGER: You dont have that hooked up.
THE BAILIFF: Do you want to play it off the DVD?
MR. AUCHINCLOSS: I think well just play it off the DVD. Well need Input 4, Your
Honor. (Off-the-record discussion held at counsel table.)
MR. AUCHINCLOSS: Your Honor, Im just going to fast-forward through a portion of it that
weve already seen.
MR. ZONEN: W ere ready, Your Honor. Go ahead and stop it.
Q. Miss Arvizo, do you recognize those people?
A. Yes.
Q. And who is that?
A. This is now my now husband, Mr. Jay Jackson, and my two boys, Gavin and Star.
Q. And they appear to be carrying something. What is that?
A. Yes. This is -- theyre carrying their military uniforms.
Q. From the laundry?
A. Yes, from the cleaners.
Q. Do you know what street theyre on?
A. Yes, actually, this is right near Jays Army base, which is way far from where Jay was
living.
Q. In West Los Angeles, do you mean?
A. Yes.
MR. ZONEN: And for the record, the date on the lower right-hand corner is March 20th,
03, and the time was 3:47 p.m. Go ahead, p lease. And stop it.
Q. Theyre stopping now. The date on the lower right-hand corner, March 21, 03, at 8:01
a.m. Do you know whos in that car?
A. Yes, I do.
Q. Who is that?
A. This is me.
Q. All right. And that car is -A. And my boys.

Q. That car is your family car?

A. This at the time was -- Im now married to Jay, but that was Jays car.
Q. Okay. The -- do you know where you are?
A. Yes, I am.
Q. Where is that, in this slide?
A. Yes. Right here, I am dropping off the children at their school. Gavin and Star. Im
parked right there in front of their school.
Q. Is the school John Burroughs Middle School?
A. This is John Burroughs Middle School.
Q. And would 8:01 a.m. be consistent with about the time that you would drop them off at
school?
A. Yes, this is consistent.
Q. Lets go ahead and -- March 21st was a day, in fact, that they went to school?
A. Yes, I had already by this time immediately reenrolled them back into John Burroughs
Middle School.
MR. ZONEN: Go ahead. Go ahead, stop it.
Q. It now says March 22nd at 5:10 p.m. Do you know what were looking at here?
A. Yes, this is Jay Jacksons apartment. Where you see that little rag or shirt, rag, shirt,
hanging off the balcony, thats his apartment. His -- I dont know -- whats that called?
Balcony. Thats what it is, balcony. And right beyond the palm you can see me, Im
standing right there.
Q. And again, this says March 22nd, 03, at 5:10 p.m.
A. So if you look closer to the wall where the palm is, right above the palm, thats me.
MR. ZONEN: Stop it for just one second.
Q. Ive asked to stop it one more time. Just a couple of questions. Behind this apartment
building, what is there? In other words, is it a parking lot or something thats right
behind? Let me ask it differently.
A. Okay.
Q. Are we looking at the back of the apartment or the front?
A. Yes, you are looking at the back of the apartment building.
Q. Standing up on the balcony where you appear to be, what can you see looking down?
A. You can see the street. You can see other apartments. And beyond that, you can see
the actual -- like a little eating area, market area, stuff like that.
Q. Okay.
A. This was Korea Town.
Q. Can you tell, based on looking at this picture, where the person would be who is taking
the photograph?
A. Yes. Based on this angle, they would be right there, on the street, because right there
is an actual city street.
Q. Do you know the name of the street right there?
A. No, I dont. Its just the back side of the apartment building. The apartment building is
surrounded by three public city streets. And thats one of them.
Q. Were you aware -- I mean, now that you know the date, March 22nd, were you aware
at that time you were being filmed actually at that time?
A. No. Its by -- by -- sometimes I would see them and sometimes I wouldnt.
Q. But on this particular occasion -A. But on this particular occasion, I did not see them.
MR. ZONEN: Go ahead. Your Honor, we have no further questions.

THE COURT: Mr. Mesereau?

MR. MESEREAU: Yes, please.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Miss Arvizo, the day after you claim you were beaten severely in the J.C. Penney
parking lot, you returned to J.C. Penney, true?
MR. ZONEN: Objection; exceed ing the scope of the redirect examination.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Now, you told -- the prosecutor asked you about -- excuse me. Let
me rephrase it. The prosecutor asked you about what happened to you in the parking lot
in his redirect examination, okay? And Id like to explore some more of those facts, all
right? You were in a pub lic parking lot, what time of day?
A. I was in a public parking -- I dont know if you know a mall. Way, way, way at the end.
And this particular area where were talking about, theres actually no windows, no
anything. Its almost empty.
Q. It was a public parking lot at J.C. Penney, true?
A. Incorrect. It was a mall parking lot, which was at the furthest distance where this
Tower Records sits independently. And theres no windows or no -- nothing of view. So its
kind of like in a -- the farthest away, where -- its almost isolated, that area.
Q. Is that where your car was parked?
A. Yes, this is where the car was parked.
Q. Is that where Gavin ran to with the items that were not paid for?
A. I wouldnt know that. I wasnt there.
Q. Well, at some point, you saw something going on near the automobile, correct?
A. Thats incorrect.
Q. Did you ever see something going on near your automobile in the parking lot?
A. No.
Q. Did you see something going on at some point that concerned you?
A. Thats too vague. Everything concerned me.
Q. Well, at some point, did you walk out of a building and see some activity around Gavin
and 6789 David?
A. When I had came out of the mall, I had to walk the farthest distance of the parking lot
an thats where I saw D avid getting beat up by this male and this female. But, no, I did
not see Gavin.
Q. Didnt you tell the jury the other day that nothing happened to David?
A. As far as to the extent that happened to me, no. But I did see him getting hit by this
male and this female.
Q. And for how long did you see David being hit by a male and a female?
A. The best I can remember, its from when I had view of to where I walked up to them.
Q. How far away from the car was David when you saw him being beaten up by J.C.
Penney security people?
A. Well, initially I didnt see where the car was. I just saw David. Its until afterwards did I
become aware where the car was located.
Q. Did you ever learn that Gavin had the car keys with him?
A. I was explained that afterwards.
Q. And where were you coming from?
A. I was coming from having had accepted a job for loss prevention from Oshmans.

Q. Now, you claim that at one point one of the J.C. Penney security guards twisted your
neck, correct?
A. This is correct.
Q. You said the person got behind you, put a hand on your chin, grabbed your hair and
twisted your neck, true?
A. This is correct.
Q. Okay. You said your head was being pulled from side to side, front and back, correct?
A. This is correct. And these are things that are happening all in a fast motion. But this
attorney, defense attorney, wanted me to break it down to millisecond to millisecond.
Q. Did you break it down from millisecond to millisecond?
A. I tried to do my best.
Q. Okay. Did you tell the truth?
A. Of course.
Q. Okay. Now, you said one of the J.C. Penny security guards was calling you Bitch,
bitch, right?
A. I think so.
Q. Would it refresh your recollection to see your -A. Im saying I think so. Im saying yes.
Q. Now, J.C. Penney security guards were assaulting you, if you remember?
A. The best I can remember, it was two males and a female, and then that other one from
that other store. Thats the best I can remember. And were talking about this event that
occurred almost seven years ago.
Q. You walked over to where you saw David being struck, correct?
A. Yes, I did.
Q. And you claim you never struck anyone, true?
A. This is correct.
Q. You claim you never resisted in any shape or form, right?
A. This is correct.
Q. You were just attacked by these people for no reason, right?
A. Yes, this is correct.
Q. You said your head was being twisted like the exorcist, correct?
A. Yes.
Q. You said that someone struck you with their knee, right?
A. Yes.
Q. You said at some point you were -MR. ZONEN: Im going to object as hearsay, unless its inconsistent with current
testimony. The deposition would be hearsay.
THE COURT: Overruled. You may proceed.
Q. BY MR. MESEREAU: You said you were dragged on the ground, true?
A. Yes.
Q. And who dragged you?
A. I remember how he looked, and it was one -- it was one of the J.C. Penneys people.
Thats the best I can remember.
Q. Now, you were handcuffed at one point, right?
A. Yes, I was.
Q. And you were then dragged with the handcuffs, right?
A. Yes.
Q. And you had trouble breathing, right?

A. Yes.
Q. You fell and you were dragged and dragged and dragged, right?
A. Yes.
Q. That was in public view, correct?
A. Like I said, this area is the furthest of the shopping parking mall and its actually almost
behind this building, Tower Records. And on this side of the build ing, there is no windows.
So, yes.
Q. Was it a public parking lot?
A. Yes.
Q. Was it a parking lot attached to a mall?
A. Yes.
Q. Was J.C. Penneys in that mall?
A. J.C. Penneys was on the other side of the mall.
Q. Was Tower Records in the mall?
A. No, Tower Records is an independent building, and thats where these people did what
they did.
Q. Now, you said your head, neck, arms, hand, fingers, back, butt, thighs and calves were
all injured, right?
A. This is correct.
Q. Do you know approximately what time this happened?
A. Okay. Like I said before, this is something that happened seven years ago, and the
best I can remember, it was in the afternoon. Actually, the afternoon.
Q. Do you know what day it was?
A. No. I cant.
Q. Well, you arrived sometime between 6:00 and 6:30, correct?
A. That sounds about right.
Q. And was it during the week or a weekend, if you remember?
A. I wouldnt be able to tell you that.
Q. Now, you said that David was driving around the parking lot and delaying what you
were doing because you were kissing him over and over, right?
A. The best I can remember -- the best I can remember is that David couldnt find a
parking space close to the mall. And so, yes, I was. I was happy to have a job.
Q. And you said that your appointment was delayed because you were driving around the
mall with David kissing him, correct?
A. Like I said, there was no parking near the entrance area. So he was trying to find a
parking space.
Q. There was no parking because the lot seemed pretty full, true?
A. No. The -- since I was just going to run in and out to go pick up the drug test, and we
were on our way to go wash clothes, so thats why.
Q. But you testified under oath you were driving around the lot because David -- because
you kept kissing David, right?
A. He was my husband.
Q. Did you say that?
A. That -- yeah, that he was my husband.
Q. Was that your testimony?
A. Yes.
Q. Now, yesterday, you said Gavin was six or seven, correct?
A. Its approximately six, seven, maybe -- the boys are about a year difference. So

depending if we count back seven years, so maybe six, seven, seven, eight, about there.
Because you didnt ask me specifically. You said boys, I think.
Q. Well, you testified on December 14th, the 6795 year 2000, that Gavin was eight years
old when this happened, right?
A. When -- when -- hes mixing up things purposely. My son was deposed right in the
midd le of chemotherapy and radiat ion treatment. And that -- and at that age, he was ten
years of age. But when this happened, he must have been -- the boys are a year apart.
He was either six or seven, seven or eight. And this is the best I can remember. The
deposition was done when my son Gavin was ten and my son Star was nine.
Q. Do you remember testifying that Gavin was eight years old when that incident
happened?
A. This was seven years ago. The best I can tell you is either the boys were six and seven,
or seven and eight. Theyre only a year difference. So -- Im not really good at math, so if
you would like to subtract seven years from now, thats about when.
Q. Now, you testified that one of the security guards, a female, kept using the F word at
you, right?
A. I think so. I believe so.
Q. That she was going to F you up, right?
A. I think so, yes.
Q. And she said -- you testified she called you an F asshole, right?
A. I think so, yes.
Q. Would it refresh your recollection to see your testimony?
A. No, Im saying yes, I think so.
Q. And you testified she did this for no reason, right?
A. Thats how I felt. Thats my opinion.
Q. They didnt know -A. Because definitely I d id not go inside the store. And definitely I did not do what they
were claiming that I had done, which was burglary, petty theft and assault and battery.
Q. And this woman said this to you when you walked over to what was happening to
David?
A. I think they were just overzealous security. And so they did what they did. I think they
themself were in the moment.
Q. Now, you said you were hit with a closed fist, correct?
A. Yes.
Q. By this woman; right?
A. Yes.
Q. You said you saw David being choked, correct?
A. Yes, I did.
Q. Now, you also mentioned that a male security guard assaulted you, correct?
A. They all assaulted me.
Q. And at some point you hit the ground, right?
A. Yes.
Q. Okay. And while this happened, the security guards kept cursing at you, right?
A. I believe it was only the -- one of the males, and the female.
Q. You indicated that one of the security guards took his badge and twisted it into your
face, correct?
A. I think so. But at that time I couldnt tell there was a badge.
Q. Well, you testified that he took a badge, twisted it into your face and said to you, For

the tenth time, and did it, right?

A. Yes, I came to find out afterwards that thats what it was.
Q. You testified you thought you were going to die, right?
A. Yes, it did feel that way.
Q. And at no time did you resist any of this assault, right?
MR. ZONEN: Objection; asked and answered.
THE COURT: Overruled. You may answer.
THE WITNESS: This is correct.
Q. BY MR. MESEREAU: And you said at some point you were face down on your stomach,
right?
A. Yes.
Q. And you said at no time did David ever come over to help you, right?
A. Yes. This is correct.
Q. You said he just stood there on the sidewalk, right?
A. Thats right. He just stood there on the sidewalk.
Q. You said that the woman was hitting you over the head with her handcuffs, right?
A. Yes.
Q. And you said she was pulling your hair, right?
A. This says -- if -- yeah, thats the best I can remember.
Q. And you said the male security guard is the one who grabbed your breasts and touched
you in your private areas, right?
A. This is correct.
Q. You also said he was kicking you, right?
A. I think so. Yes.
Q. And the woman was kicking you as well, right?
A. Yes.
Q. And you said you had no idea why you were being assaulted this way, right?
A. This is correct.
Q. You said you were being choked, correct?
A. Yes.
Q. You said you were kneed by one of the two guards, right?
A. Yes.
Q. You said they all scratched you, correct?
A. Yes. I did receive scratches.
Q. You said you were hit with handcuffs that were like brass knuckles, right?
A. They had -- I was trying to describe where they were on their hand.
Q. You said that you were smashed like a cockroach, correct?
A. Probably so.
Q. Did you say that?
A. I probably did, trying to -- for them to get a visual.
Q. You said that the male was holding on to your breast with one hand, right?
A. This is correct.
Q. You said they were hitting you all at the same time everywhere, correct?
A. Yes.
Q. You said that Star was assaulted for no reason, right?
A. Yes.
Q. You said Gavin was assaulted for no reason, right?
A. Thats right.

Q. And how many security guards do you remember being in the parking lot with your
family?
A. Okay. The best I can remember is first it was the male and female. Then another male.
Then another male. And then way towards the end, there was another male, but that
other male d idnt do a single thing. Thats the best I can remember.
Q. You said everything became like an echo, like a cave in a tunnel, correct?
A. Yes. It did.
Q. And thats when you thought you were going to pass away, correct?
A. Pass out.
Q. Well, you said you thought you were going to die, right?
A. Yes, but youre taking it -- hes mixing up words. I did feel that way.
Q. And you said they took Gavin and they shoved him into some vomit, right?
A. Yes.
Q. And you said at some point Gavin just laid there, right?
A. He did.
Q. Okay. Were you handcuffed standing up or when you were on the ground; do you
know?
A. I -- I remember that. And the best is -- yes, I was laying down when they handcuffed
me.
Q. And you said at one point you were called an F- ing wetback, right?
A. Yes.
Q. And you said they were all laughing while they d id this, right?
A. Yes, they were.
Q. And you said Gavin and Star were following while you were dragged, right?
A. Oh, yes. Oh, that is -- that is burned right there.
Q. You said at one point your breasts were outside your blouse and Gavin helped you
redress, right?
A. Gavin and Star. My breasts were outside of my bra, and the boys -- because I was
handcuffed, the boys got my breasts, put them inside my bra and buttoned me up. So,
yes, it was my boys.
Q. And you said that one of the security guards told you, I hate blacks and I hate
Mexicans, right?
A. One of the security guards, that was his focus.
Q. Is that what you claim that one of them said?
A. I think so. But, you know, Im -- since -- this is seven years ago. This is the best I can
remember. And since he takes things out of context and mixes words around, Im -- you
know, but that does sound correct.
Q. You said under oath, Gary said, I hate blacks and I hate Mexicans, right? 6802
A. Yes.
Q. You were asked how you felt about the fact that clothes were taken without being paid
for and thats when you said, David is extremely honest. Hes too honest, right?
A. Yeah.
Q. You said Gavin helped you get your cell phone out of your pocket, right?
A. Yes, I remember that.
Q. And you were both dialing 9-1-1, right?
A. Yes.
Q. And at some point, all of you were arrested, right, you and David and the children?
A. The children were never arrested.

Q. Did they go to the station with you?

A. No, they never went to the station.
Q. Where did they go?
A. They -- when I was standing outside, the police officer did not want to take the boys
into custody. So he had the station call my parents. My parents came. And my -- and the
officer gave the boys to my parents and thats from right there. Then I was taken to the
police station after my parents came from there, from the area, and took the children with
them.
Q. And you went to the station, correct?
A. This is correct.
Q. Your photograph was taken, right?
A. Yes.
Q. Did your photograph show bruises on your face?
A. I dont think so. I had makeup on at the time.
Q. Do you remember testifying that at the station, you didnt show bruising, you showed
marks, correct?
A. This is correct.
Q. You said, As days went by, they started getting darker and changing colors, you know,
every day, every week, right?
A. Yes.
Q. Okay?
A. Yes. Yes.
Q. You said you had no black and blue marks prior to the incident, right?
A. Yes, this is correct.
Q. Now, the prosecutor asked you questions about a woman who worked at the law firm
that represented you named Mary Holzer, correct?
A. Yes.
Q. And you told Mary Ho lzer that the photographs in the J.C. Penney case were the result
of Davids beatings, not anybody at J.C. Penney, right?
A. Thats incorrect.
Q. You said your hand was broken, correct?
A. Yes. Right here.
Q. You said they stomped on your hand, correct?
A. I think so. I think so.
Q. Would it refresh your recollection if I show you that page?
A. No, Im saying I think so, so thats a yes.
Q. You didnt ask that anyone in your family be taken to a hospital, right?
A. Yes, I did. I asked -- I asked the officer and the officer said, Were going to just
process you. It shouldnt take long. And then you can go to the doctors.
Q. Do you remember testifying, your response to the following question: Did you urge
anybody at any time, includ ing to the police, that either of your sons be taken to the
hospital or receive emergency treatment? And the answer was, No? Do you remember
that?
A. Yes.
Q. And you were asked, Why is that? You didnt think there was an emergency? You
said, At that point I could breathe again. And since my mom knows how to fix
everything, you know -- Q. You were going to leave it in her hands? You said, Yes,
right?

A. Yes. Yes. 6805

Q. All right. You said youre not a doctor, and you didnt have any reason to think you
needed emergency treatment, right?
A. Thats correct. But theres also somewhere in the deposition where I stated -- what I
had asked the J.C. Penneys people, for them to call the paramedics or something like that
- this is the best I can remember - and he declined it. And its in there.
Q. And you testified at the time you just wanted the J.C. Penney guards arrested. You
didnt want any lawsuit, right?
A. Show me that.
Q. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
THE WITNESS: So this is correct, then.
MR. ZONEN: Ill object as vague to the question, at the time. At the time of the
deposition or the time of the event?
THE COURT: Youre refreshing her memory. Go ahead.
THE WITNESS: Thats right. At -THE COURT: Wait. Just a moment.
Q. BY MR. MESEREAU: Have you had a chance to look at that page?
A. Yes.
Q. Does it refresh your recollection about what you said in that deposition under oath?
A. Yes.
Q. You said you wanted them arrested, you werent interested in suing, right?
A. Thats correct. At that moment, that second, when the officers came, thats what I
wanted.
Q. You later changed your mind and decided to file a suit, correct?
A. Because the time had already expired for these people to be arrested.
Q. You claim you had a back injury, right?
A. Yes, I did.
Q. You said prior to this event you had never had a back injury before?
A. This is correct.
Q. Okay. You were asked if you knew whether or not David was aware that Gavin was
going to run out of the store with the unpurchased items, and you said, I didnt have to,
no. I know Davids honest character, right?
A. Yes.
Q. You testified that in the parking lot, your breasts were fondled for minutes, not
seconds, right?
A. Thats how I felt.
Q. You said your pelvic area was touched for minutes, correct?
A. Thats how I felt.
Q. You said you were hit with closed fists, right?
MR. ZONEN: Objection; asked and answered.
THE WITNESS: Yes.
Q. BY MR. MESEREAU: And you said the security guard spit intentionally -MR. ZONEN: There was an objection to the last question, Your Honor.
THE COURT: Overruled.
Q. BY MR. MESEREAU: You said the security guards at J.C. Penney spit intentionally into
Stars face, correct?

A. I think so.
Q. Would it refresh your recollection if you see that?
A. I think so. I think so meaning yes.
Q. Did you say that under oath?
A. I dont know if -- this is seven years ago, so I dont know whether it was Star or Gavin,
so thats why Im saying yes, I think so. But since he said Star -Q. Would it refresh your recollection to look at the deposition transcript?
A. Okay. Im saying to you, because hes saying this, I said yes, I think so -THE COURT: Just a moment.
THE WITNESS: Okay.
THE COURT: He asked you a question whether it would refresh your recollection to look at
the transcript.
THE WITNESS: Its okay. I remember it happening to one of my boys. And hes specifying
-THE COURT: Maam, youre not answering my question.
THE WITNESS: Okay.
THE COURT: Do you want -- will it refresh your recollection to look at the transcript?
THE WITNESS: Its a yes.
Q. BY MR. MESEREAU: You also said the security guards started spitting pumpkin seeds at
your family, correct?
A. Oh, yeah, I remember that. Thats right there, burned.
Q. And at that point in the deposition is where you said that David Arvizo had never struck
you or your children at any time, right?
A. Yes, this is correct.
Q. When did you first go to a lawyer after this incident?
A. I think it was about a year later.
Q. So a year after the incident you change your mind and decided you did want to sue,
right?
A. That was too long ago, the question.
Q. Well, during the time of the alleged events you described, you said you werent going
to sue anyone and then you changed your mind, right?
A. There was a criminal proceed ings. I was charged with crimes. I was charged with
burglary, petty theft, assault and battery. That process took months. And those people
needed to apologize.
Q. So you only sued for an apology?
A. Yes, I did.
Q. At one point didnt your lawyer ask for millions of dollars?
A. No.
Q. But you accepted 152,000, right?
A. No. On -- in my hand, what I received, was only about 32,000. Thats it.
Q. Now, did you talk to the prosecutor last night about what you were going to testify to
today?
A. I -- on the telephone he spoke to me that he would like to show these surveillance
videos, and thats it.
Q. Did the prosecutor talk to you last night about Louise Palanker?
A. Yes, he did.
Q. Do you remember testifying yesterday you didnt know what happened to the money
Louise Palanker gave you and David?

A. This is correct.
Q. But last night you talked to the prosecutor and now you remember it was used on the
room for Gavin?
A. No. He refreshed my memory as far as what it was. Thats all.
Q. Now, you said today -- excuse me. Let me rephrase. You said today that you never
asked for any money to help Gavin, right?
A. This is correct.
Q. To your knowledge, the only person in your family that ever asked for money to help
Gavin was David, right?
A. Yes. This is -- now I know.
Q. But on the Washington Mutual account, which was set up to take funds for Gavin, you
were the signatory, right?
A. Yes.
Q. You were the one who withdrew money from the account, correct?
A. This is correct.
Q. So youre on that account for Gavin which you have no knowledge of any fund-raisers,
right?
A. This is correct.
Q. Youre the signatory on that account, but you dont know why anybody even deposits
money into it, correct?
MR. ZONEN: Thats argumentative. Objection.
THE COURT: Overruled. You may answer.
THE WITNESS: Okay. Can you ask it differently?
Q. BY MR. MESEREAU: Sure. Youve said you had no knowledge of any fund-raisers for
Gavin, correct?
A. This is correct.
Q. You said you never asked anybody for any financial help at any time, right?
A. This is correct.
Q. You said you never asked anybody for financial help to assist Gavin, right?
A. Yes, this is correct.
Q. Yet at the same time, you set up a bank account -A. Is this a question or a statement, what youre starting right now?
Q. Yet at the same time, you set up a bank account for Gavins benefit with you being the
signatory, correct?
A. Yes, I did follow Davids instructions.
Q. And you have no idea why anybody put any money into that account, correct?
A. This is correct.
Q. You just saw the money there and withdrew it, right?
A. Yes. I was Davids personal secretary.
Q. Never asked a question of anybody, Where did this money come from? Right?
A. Thats correct.
Q. Just assumed it was for you to withdraw, right?
A. No. I did what David told me.
Q. And you said yesterday you couldnt remember what any of that money was spent on,
right? A. This is correct.
Q. And you had no idea that Chris Tucker was going to wire some money into that
account, right?
A. Yes, this is correct.

Q. And all your discussions with your friend Aja Pryor, who was his fiancee, the issue of
Chris Tucker giving money never came up, right?
A. This is correct. Like I testified yesterday, I didnt become friends with Aja until after
David was completely out of the picture. While Gavin was sick we hardly even spoke. The
one I spoke most to was Ann Lopez.
Q. And in your discussions with Ann Lopez, you never learned that George Lopez was
planning to put together a fund-raiser for Gavin, right?
A. Yes, this is correct.
Q. And in all your discussions with Jamie Masada, you never learned that he was putting
any fund-raisers together for Gavins benefit, right?
A. Yeah, this is correct.
Q. And in any of your discussions with Fritz Coleman, you never learned that Fritz
Coleman was help ing to assist your family with Gavins illness, right?
A. Yes, this is correct.
Q. No one told you about any of this, right?
A. Thats right.
Q. You never knew that comedians showed up at The Laugh Factory on a number of
occasions to help raise money for Gavin, right?
A. This is correct.
Q. You never knew that Gavin was in the lobby with his father accepting funds, right?
A. This is correct.
Q. Now, you said you began to buy a car and then changed your mind, correct?
A. Yes. This is true.
Q. And approximately when was that?
A. The best I can remember, the best, because I never even stepped foot in the
dealership, was the fall of 2001. I think -- no. No, no, thats incorrect. I apologize. It was
definitely the fall. No, it was, the fall of 2001. Thats the best I can remember.
Q. And was the company that you were going to purchase an automobile from Ho llywood
Ford?
A. Yes, it was.
Q. Did you go to Hollywood Ford yourself?
A. I never went to Hollywood Ford.
Q. How did you communicate with Hollywood Ford?
A. I looked in the phone book, and I -- I got their phone number from there, and I called.
Q. Do you recall using any money that had been donated for Gavins benefit on cosmetic
surgery?
A. No, I used a credit card.
Q. Was it your credit card?
A. Yes. My credit card. Which is still outstanding.
MR. ZONEN: Im going to object as exceeding the scope of the redirect.
THE COURT: Sustained.
Q. BY MR. MESEREAU: The prosecutor mentioned the room that was constructed for Gavin
at your parents house, okay? Do you remember him asking you questions about that?
A. Yes, I believe so.
Q. And thats the room that today you say Louise Palankers money was spent on, right?
A. This is what Mr. Zonen made me aware, refreshed my memory yesterday.
Q. Did you hire a contractor to fix up that room?
A. No.

Q. Do you know if anyone did?

A. I now know that David did hire, through Wheezy, through Louise Palanker. I know now.
Q. Did you have anything to do with a contractor fixing up that room for Gavin?
A. No.
Q. Did you ever meet a contractor who was fixing up that room for Gavin?
A. No.
Q. Did you even tell a contractor what to do to fix the room up for Gavin?
A. No.
Q. Did you have any involvement at all in making sure that room was fixed up properly to
help Gavin with his illness?
A. I think so. Its my moms house. It started with it being in my moms house.
Q. Did you ever see it being repaired?
A. No. I was with my two other children.
Q. Do you remember when it was repaired by a contractor so that it would be an
appropriate room for Gavin?
A. No.
Q. You never had a discussion with anyone about what the requirements were for Gavin in
that room?
A. No.
Q. That was all David, too; is that correct?
A. Yes, this is correct.
Q. So David was the one who was telling the contractor what the specificat ions were for
this renovated room, right?
A. Yes, this is correct.
Q. And David was the one telling the contractor what Gavins requirements were to make
sure he didnt get exposed to germs and things of that sort, right?
A. I think so.
Q. Was all David, right?
A. Yes. I wasnt there. I was with my two other kids.
Q. It was done at your parents home but David was the one taking care of everything,
right?
MR. ZONEN: Objection; asked and answered.
THE WITNESS: Yes, thats correct.
THE COURT: Sustained. Just a moment. Next question.
Q. BY MR. MESEREAU: Now, in response to the prosecutors questions, you said that you
never obtained any of the money from the first Louise Palanker check, correct?
A. Yes, this is correct.
Q. That was a $10,000 check written to Janet Arvizo, correct?
A. Yes.
Q. Was that presented to you by David?
A. No.
Q. Well, who presented the check to you?
A. I -- I think this is how it went. I endorsed it, give it back to David, and that was it.
Q. You just said -- excuse me. Who gave you the check to begin with?
A. David had me endorse it, and thats it.
Q. And you know -A. I think so. Thats how it happened.
Q. Did you know David was going to deposit the check into your parents account?

A. Now I understand, this is my understanding, that my mother cashed it for him.

Q. You didnt know that was going to happen at the time?
A. No, I was with my two other kids.
Q. Well, you saw a check for $10,000 -A. Yes.
Q. -- made out to Janet Arvizo, correct?
A. Yes.
Q. And you knew it was made out to you by Louise Palanker, correct?
A. Yes.
Q. And youre saying that David asked you to endorse it, but didnt tell you where it was
going?
A. This is correct.
Q. And you never knew until recently that it was deposited into your parents account?
A. Yes. This is correct.
Q. Okay. When did you first learn it had been deposited into your parents account?
A. It wasnt deposited, it was cashed. Just with a lot of events that are occurring now.
Q. And you never knew where any of that money went, true?
A. This is correct. I was -- I did what David told me. I was like his personal secretary.
Q. Did you ever learn that Louise Palanker had written a second check for $10,000 to
David?
A. I am aware now.
Q. Did you know at the time?
A. At the time, no.
Q. Well, you were communicating with Louise Palanker a lot at that point, werent you?
A. Yes, I was.
Q. Wheezy was your friend, correct?
A. Still.
Q. And you were talking to her quite often, were you not?
A. I feel -- I feel I was.
Q. Yet, Wheezy never mentioned she was contributing $20,000 to your family?
A. Yes, thats correct.
Q. Wheezy never mentioned she was writing a $10,000 check to you?
A. This is correct.
Q. Wheezy never mentioned she was writing a $10,000 check to David?
A. This is correct.
Q. You never knew anything about this, right?
A. Yes, this is correct. At that time, David -- David was more in control of all these
previous friendships that I had had.
Q. By the way, do you recall Davids using Vons to cash checks?
A. No.
Q. Did you ever learn that David would go to Vons and cash checks?
A. No.
Q. Okay. To your knowledge, did David have his own account anywhere at that time?
A. No.
Q. He had no bank account at all?
A. No.
Q. Did he use a credit union at Vons?
A. Maybe. I dont know.

Q. But you never heard anything about that, right?

A. No.
Q. Now, in one of the police reports involving Davids domestic violence, you said you had
been abused by him throughout your marriage, true?
MR. ZONEN: Objection; exceeding the scope of the redirect.
THE COURT: Sustained.
MR. MESEREAU: It would have to do with her injuries, Your Honor.
THE COURT: All right. Ill allow the question.
MR. MESEREAU: Thank you.
Q. Do you remember telling the police, when David was arrested, that throughout your
16-year marriage he had physically abused you?
A. Yes. Finally I said something.
Q. You told the police that he would hit you on all parts of your body, right?
A. Yes, he did.
Q. You said he forced your head under water, right?
A. Yes, he did.
Q. You said he prevented you from wearing makeup, right?
A. Thats correct.
Q. And in a number of interviews with the police, you said he had beaten you throughout
that marriag e, right?
A. Yes, he did.
Q. Yet, in the J.C. Penney case, you said none of your bruises or injuries had anything to
do with David, right?
A. Thats correct.
Q. When you testified under oath in the J.C. Penney case that init ially you werent bruised
but as time went on they got blacker and blacker, what did you mean?
A. Well, that I had -- even though I had -- I did have visible abrasions, that even though
these people had hit me, it wasnt immediate. I could see them.
Q. Did your attorney have those photographs taken that the prosecutor introduced int o
evid ence yesterday?
A. Yes.
Q. You didnt go to a lawyer till a year later, right?
A. No. Hes incorrect. Those photographs were taken immediately with the criminal court
proceedings. That stuff, criminal case, whatever. Had nothing to do with the civil case. I
had those photos already. W ell, actually, my -- the defense attorney had those photos.
Q. Who hired the photographer?
A. Actually, I think it was -- I dont remember very clear. I dont remember very clear. But
it was per the defense attorneys actions, ways, I dont know what you would call it,
suggestion. I dont know.
Q. It wasnt taken -- excuse me. Those photos were not taken by the police, correct?
A. This is correct.
Q. They were taken at the direct ion of a lawyer, correct?
A. Yes. This is correct. A defense attorney. Not a civil lawyer.
Q. Where were those photos taken?
A. That I do remember. Its at -- its a place in El Monte. I dont remember the name, but
its El Monte.
Q. Was it an office of a photographer?
A. No, its actually one of those, like, one-hour photo places.

Q. Who took you there?

A. I think it was David. Yes, I think it was David.
Q. Do you know when he took you there?
A. Immediately.
Q. But didnt you testify in the deposition you didnt have these bruises immediately?
A. No. Thats right. When the -- when the defense attorney had told us, then thats the
time.
Q. Who went there to get their photographs taken?
A. I believe it was me and David. And then I think Gavin was -- the boys were with us. I
think so.
Q. And were you doing this all at the direction of David?
A. No. I was doing it in the direction of the defense attorney.
Q. And what was this defense attorneys name?
A. Mr. Fountain.
Q. The prosecutor asked you questions about Attorney Bill D ickerman. You first met
Attorney Bill Dickerman on February 21st, 2003, correct?
A. Incorrect. I remember the date. It was February 25th.
Q. Did you ever tell anyone that you met with Bill Dickerman on February 21st?
A. No.
Q. Have you ever d iscussed with Bill D ickerman the date you first met him?
A. No.
Q. Are you aware of Gavin telephoning Jay Leno at any time?
A. No.
Q. Never h eard anything about that?
A. No. Ive heard now.
Q. Did Gavin ever tell you, I tried to reach Jay Leno?
A. No.
Q. Were you ever standing in the background during a phone call that Gavin made to Jay
Leno?
A. No.
Q. Have you ever spoken to Jay Leno?
A. Ive never spoken to Jay Leno.
MR. MESEREAU: If I may just take one second, Your Honor, Ill be ready to wrap this up.
THE COURT: Yes.
Q. BY MR. MESEREAU: Were you aware of Gavin making any attempt to contact celebrities
by phone?
A. No.
Q. To your knowledge, did Gavin ever try to contact any celebrity from your home?
A. No.
Q. Did you ever contact any celebrity from your home?
A. No.
Q. Did you attempt to contact any celebrities at any time?
A. No.
MR. MESEREAU: No further questions.
FURTHER REDIRECT EXAMINATION BY MR. ZONEN:
Q. Ms. Arvizo, did you earlier testify that you had contacted George Lopez when your son

became ill?
A. Yes.
Q. All right. Did you contact any other people when your son became ill to notify them
that he was ill?
A. I think I contacted Jamie Masada, Louise. These are all previous people that I had
already known before Gavin had become ill. And thats it. Thats the best I can remember.
Q. When did you first learn that Gavin had been injured in the altercation at J.C.
Penneys?
A. Okay. My parents had came and picked up the children from the parking lot, because
the officer did not want to take them to the police station. And so it was my mom who
called me up and told me that -- that shes tried everything, everything, first aid, and that
was still not enough for the kids to feel better.
Q. You say she called you up. Where did she call you?
A. She called me -- at that time I had a cell phone.
Q. But where were you at the time? At what time was this?
A. I was staying in the place that we were staying in.
Q. Okay. Im asking you when. So had you already been arrested and released from jail?
A. Yes.
Q. And had you already gone to the hospital?
A. Yes.
Q. For your own injuries?
A. Yes.
Q. So at the time that you were being arrested at J.C. Penneys in the parking lot, were
you aware that Gavin was injured at that time?
A. I had seen them, the way they had hit both the boys, but I figured my mom, you know,
could do what she always does, and in first aid, just like when they fall or scrape or
anything, that she can tend to them. So thats what I figured. I didnt think it was beyond
what my mother could care for. But my mom made me aware that it was beyond her
capability.
Q. Did you know at the time that you were arrested that your son Gavin had a broken
elbow?
A. No, I didnt.
Q. Did you know at the time that you were arrested that you had a broken bone in your
hand or wrist?
A. No, I didnt.
MR. ZONEN: Thank you. I have no further questions.
THE COURT: All right. Well take our morning break. (Recess taken.)
THE COURT: Any further questions, Mr. Mesereau?
MR. MESEREAU: No, Your Honor.

VICTOR ALVAREZ EXAMINATION

DIRECT EXAMINATION BY MR. ZONEN:
Q. Detective A lvarez, youve previously testified in these proceedings, have you not?
A. Yes.
Q. And identified yourself as a detect ive with the Santa Barbara County Sheriffs Office?

A. Yes.
Q. Youre going to be testifying to a number of different items this morning, although
fairly rapid ly. Is that your understanding?
A. Yes.
Q. Now, the last time that you were on the witness stand testifying, or perhaps one of the
last few times you were on the witness stand testifying, you were testifying to some items
that you had personally seized from Neverland Ranch during the course of that search
back in November of 02; is that correct?
A. Yes.
Q. November 18, 02, am I right?
A. 03.
Q. Im sorry -A. It would be 03.
Q. Im sorry, 03. Okay. November 18 of 03. Exactly. At the time of your testimony, you
had one particular item had fallen out of a bag and was not present in court at the time it
was presented to you. Is that your recollection?
A. Yes.
Q. Id like to show you Court Exhibit 822. Court Exhibit 822, and specifically -occupational hazard here -- specifically Sheriffs No. 304-B. Would you take a look at this
item and tell us if you recognize that item?
A. Yes.
Q. Is that an item that you seized?
A. Thats correct.
Q. Is that the item that fell out of the bag?
A. Yes.
Q. Okay. And just describe it for us, please.
A. It is a -- appears to be a paperback. It is titled, The Art of Dave Nestler, N-e-s-t-l-e-r.
Q. Was that taken to another detective who then booked it into evidence?
A. The title is Wicked Intentions and -- yes.
Q. Im sorry, there were two questions. The title of the magazine again was what, please?
A. Wicked Intentions.
Q. And that magazine was then booked in by whom?
A. I believe it was Detective Padilla.
MR. ZONEN: Okay. I would move to introduce that item into evidence at this time, Your
Honor.
MR. SANGER: I need to cross-examine on that, if I may, please, before the Court rules.
THE COURT: All right.
MR. SANGER: Thank you.
THE COURT: Ill withhold ruling on that.
MR. ZONEN: Okay. Ill proceed with other exhibits, if I may.
Q. Detective A lvarez, did you have an 6837 opportunity to review a number of VHS videos
and compare them as against a number of DVDs?
A. Yes.
Q. All right. I would like to show you each of the DVDs and each of the videos and ask you
if, in fact, they are duplicate copies of one another, if I may.
A. Sure.
MR. ZONEN: May I approach the witness?

THE COURT: Yes.

Q. BY MR. ZONEN: Let me beg in with four court exhibits, and the four court exhibits are
No. 815, a DVD; 816, a DVD; 817, a DVD; and 818, a DVD. Have you seen those four
previously?
A. I have.
Q. And can you tell us if you viewed the contents of those four?
A. I have.
Q. And what is the subject matter of those four DVDs?
A. These are surveillance tapes.
Q. Is one of a residence on Soto Street?
A. One is a residence on Soto Street.
Q. And the other three?
A. Of Ramer Street. One of Jay Jackson. One of Davellin.
Q. Okay. Did you -- were you in court on Friday where some of those surveillance tapes
were played?
A. Yes, I was.
Q. And are those, in fact, the same as the ones that youre currently holding?
A. They are.
Q. All right. Now, did you have an opportunity to compare them as against videotapes?
A. I did.
Q. Let me now show you exhibits for identificat ion, please, No. 823, No. 824, No. 825 and
No. 826. And could you take a moment and look at each of those four VHS videos?
A. Yes.
Q. Do those four correspond to the four DVDs youve already identified?
A. They do.
Q. Are they duplicates of them?
A. The DVDs are actual exact copies of the VHS tapes.
MR. ZONEN: Thank you. No further questions.
CROSS-EXAMINATION BY MR. SANGER:
Q. Exhibit 822, Detective -A. Yes. The magazine.
Q. The magazine. Its just a separate magazine?
A. Yes.
Q. Thats marked as 822, correct?
A. Thats correct.
Q. And youve indicated that it was actually 304-B as designated by the sheriffs
department. Was that your testimony?
A. Yes. Thats -- it came from Item 304, the original item, and this is -- this was found
with Item No. 304.
Q. Okay. So really it was not booked into sheriffs department evidence as 304-B, was it?
A. I believe it was.
Q. Okay. On your booking form, your sheriffs department booking form, the one that was
filled out by Detective Pad illa -A. Correct.
Q. -- that would be the form that he used to designate by number the various items that
were seized; is that correct?

A. Yes.
Q. And he indicated that the contents of that one bag were 304?
A. Right.
Q. All right. He did not designate it 304-A or B, correct?
A. Not at that time.
Q. Okay. Now, I think youve told us -- and I dont want to be redundant, but I think I
asked you about your training and experience when you were on the stand previously -A. Correct.
Q. -- is that correct? And I dont know if I went into detail, but let me ask quickly, if I can,
you were trained at a police academy; is that right?
A. Yes.
Q. Which police academy?
A. Allan Hancock.
Q. Allan Hancock, all right. Thats a POST Academy?
A. Thats right.
Q. And you have also had inservice training; is that correct?
A. Yes.
Q. And you were also a bailiff in Depart ment 9, or whatever number it was over the years,
Judge Lodges department down in Santa Barbara; is that correct?
A. Yes.
Q. So you had an occasion to see how evidence was handled in court, correct?
A. Correct.
Q. And you had an occasion to see countless witnesses, police officers, detectives, crossexamined with regard to the chain of custody; is that right? 6841
A. Correct.
Q. And in your training and experience, both your POST Academy training and your
inservice training and your experience as a police officer or a sheriff, youre aware that
chain of custody is important; is that correct?
A. Correct.
Q. And when an item is seized originally by your department, specifically the sheriffs
department, it is given a sheriffs booking number, correct?
A. Correct.
Q. And its put usually into an evidence bag, assuming its the kind of object that can be
put into a bag; is that correct?
A. Yes.
Q. That bag is sealed; is that right?
A. Correct.
Q. And the idea is to come into court and open the bag, and say, Sure enough, heres the
same contents that were put into that bag originally, right?
A. Yes.
Q. You would agree that it is not a proper police practice to lose an item from a bag; is
that right?
A. This wasnt lost.
Q. Okay. It wasnt here when the item was in front of the jury when you testified
originally, was it?
A. No, it wasnt.
Q. It fell out of the bag?
A. It was in the box.

Q. Okay. Fell out the bag, right?

A. Yes.
MR. ZONEN: Objection; argumentat ive.
THE COURT: Overruled. Next question.
Q. BY MR. SANGER: And you would agree its not a proper police pract ice to have things
fall out of the bag before youre standing in front of the jury or sitting in front of the jury
and introducing the contents of the bag, correct?
A. Whether its proper or not, I -- I dont know, but it happened.
Q. When do you believe that somebody gave this item the designation of 304-B?
A. Originally what happened was at the init ial search of Neverland Ranch, all these items
were put -- for example, 304, there were more than one item. Later on, as these items
were opened, they were given As, Bs and Cs, depending on what was searched and what
was found.
Q. Okay. Detective Pad illa gave it the number 304, correct?
A. As a group, yes.
Q. Who gave it -- to your knowledge, do you 6843 know who actually gave it a
designation 304-B?
A. Id say it was Detective -- or Sergeant Bonner.
Q. All right. So you were not -- you did not give it the number 304-B; is that correct?
A. I did not. I gave it the original number, 304.
Q. Did you ever see that item between the time you handed it to Detective Pad illa and the
time that you found it was in the box?
A. Yes.
Q. When did you see it?
A. When Sergeant Bonner was itemiz ing the items.
Q. So you saw him -A. This is not the second time I have seen this.
Q. You saw it when Sergeant Bonner actually gave it a designation 304-B?
A. Thats correct.
Q. And then your understanding was it was supposed to be put back in the bag, 304,
right, to preserve the chain of custody?
A. Either in 304 or designated as 304-B in its own container.
Q. In any event, when you took the stand, 304, the bag that you thought contained 304-A
and B, only contained A and not B; is that correct?
A. Correct.
Q. Now, this particular item, which you told us is The Art of Dave Nestler, is that a book
of art by that particular individual?
A. Yes.
Q. All right. And that is an item that, to your knowledge, is legal for an adu lt to purchase
commercially, correct?
A. Yes.
Q. Im not talking about copyrights. What Im talking about -A. Yes, yes.
Q. -- its something that somebody could buy. If they can find it in a store, right, an adult
can buy it? Theres nothing illegal about that, right?
A. Yes.
Q. And theres nothing illegal about an adult possessing that?
A. I dont think so.

Q. All right. Thank you. Now, let me just ask you, the second part of your testimony
pertained to these videos, and you have related the videos to the DVDs. The actual -A. Or the DVDs to the video. Either way, yes.
Q. Okay. Am I missing something there?
A. The DVDs are made from the original videos.
Q. You said you related them. That was my word.
A. Yes.
Q. Okay. On the stand you said these DVDs were taken from these videos, right? Thats,
in essence, what youre saying?
A. Yes.
Q. There we go. And in that regard, the videos -- your understanding is that these video
were located in Brad ley Millers office; is that correct?
A. Correct.
Q. And Bradley Miller is a private investigator that worked for Mark Geragos, correct?
A. Correct.
MR. ZONEN: Objection; speculat ive.
THE COURT: Overruled. The answer is, Correct.
MR. ZONEN: Lack of foundation.
THE COURT: Proceed.
MR. SANGER: Thank you.
Q. The -- youve looked at the videos, correct?
A. I have.
Q. And they appear to be surveillance films of some sort, correct?
A. Yes.
Q. They appear to be taken from a public place, a p lace where a person would lawfully be,
a street or sidewalk; is that correct?
A. Yes.
Q. And that is consistent with what private investigators do from time to time, correct?
A. Im not a private investigator.
Q. No, sir. But youve seen private investigators surveillance videos before, have you not?
A. I have.
Q. And sometimes private investigators, for whatever reason, do surveillance videos,
correct?
A. Yes.
MR. SANGER: All right. Thank you. I have no further questions.
REDIRECT EXAMINAT ION BY MR. ZONEN:
Q. The magazine thats in front of you, I think its right below your hands at the moment.
A. Yes.
Q. What is the Court number again on that? The one that weve identified as 304-B,
sheriffs number?
A. 822. Exhibit 822.
Q. Where in Neverland did you find that particular exhibit?
A. This was in -MR. SANGER: Im going to object. Thats beyond the scope of direct, actually.
MR. ZONEN: Then I would move to reopen on that question if thats the case.
THE COURT: It is the case. Ill allow you to reopen.

MR. ZONEN: Thank you.

Q. Where exactly was it that you found that?
A. This was along with Item 304.
Q. Yes.
A. And it was in the master bedroom downstairs bathroom, next to the sink area by the
tub. Theres a sink. Theres a tub. It was in the middle there.
Q. Was it something that was contained in a drawer or in a suitcase or in any kind of a
closed container?
A. I believe it was out in the open.
Q. It was in the open at the time? Now, you said the magazine wasnt lost, it was in the
box. Tell us what you mean by that.
A. As we brought the exhibits into the courtroom, it was actually placed in one of the
boxes that we carried it in. So it just -Q. And what happened with the magazine?
A. It was in the box and wasnt presented in court.
Q. Okay. Fell out of the -- what was it originally contained in within the box?
A. If its labeled 304-B, then it was in plastic and must have just fell out of the plastic.
Q. And did you then retrieve it from the box?
A. I did.
MR. ZONEN: Thank you. No further questions.
MR. SANGER: No further questions, Your Honor.
THE COURT: You may step down.
MR. ZONEN: As to Exhibit No. 822, we would move that into evidence at this time.
MR. SANGER: Ill submit it.
THE COURT: Its admitted.
MR. ZONEN: And well call Maria Ventura to the stand.
THE COURT: Shes on her way. Counsel, the in-camera hearing that was requested, I
think well conduct that at about ten minutes before the next break. I think ten minutes is
a sufficient amount of time for that in-camera hearing. So that will extend the jurors
lunch by ten minutes and shorten yours by every minute you take over ten. (Laughter.)
MR. SNEDDON: Why are you looking at me, Judge? I have a guilty conscience maybe.
THE COURT: You must have a guilty conscience.
MR. SANGER: Your Honor, could you give us a little more -THE COURT: Mr. Mesereau knows.
MR. MESEREAU: Oh, oh, oh. I know what it is.
THE COURT: Come forward, please. When you get to the witness stand, please remain
standing. Face the clerk here and raise your righ hand.

MARIA VENTURA EXAMINATION

DIRECT EXAMINATION BY MR. ZONEN:

Q. Miss Ventura, are you the mother of Janet Arvizo?
A. Yes, sir.
Q. Do you have other children as well?
A. Yes.

Q. Does Janet Arvizo have children?

A. Yes.
Q. And how many children does she have?
A. Three.
Q. All right. These are the three children from her marriage with David Arvizo?
A. Yes, sir.
Q. Does she have a child also with her marriage to Jay Jackson?
A. Yes.
Q. And that child is how old?
A. The little one?
Q. Yes, the little one.
A. Eight months.
Q. Okay. Now, the three older children, the children who are the children of Janet and
David Arvizo A. Yes, sir.
Q. -- are their names Davellin, Star and Gavin?
A. Yes.
Q. And those three are your grandchildren?
A. Yes.
Q. Do you talk with those three children on a regular bas is?
A. Well, theyre my kids.
Q. Does that mean yes, you do?
A. Yes.
Q. All right. And do the children speak enough Spanish that theyre able to communicate
effectively with you?
A. Yes.
Q. Id like to direct your attention back to the early -A. You can speak louder, because I cant hear. I cant hear.
Q. I wou ld like to direct your attention back to the early part of 2003, January and
February of 2003.
A. Thats fine.
MR. AUCHINCLOSS: Its not you. Its the interpreter.
MR. ZONEN: I was wondering why -THE WITNESS: What did you say?
MR. ZONEN: Thats what happens when trials go on long enough.
Q. Miss Ventura, can you hear me now?
A. Yes, I do. It was for her.
Q. I understand. (Laughter.)
Q. I wou ld like to direct your attention back to the early part of 2003.
A. Thats fine.
Q. Were you aware as to where your daughter and her three children were visiting during
that period of time?
A. Yes.
Q. And where was that?
A. Neverland. I cant say it very well, but there, Neverland.
Q. Is Neverland a place where you had once visited?
A. Never.
Q. Did you know what Neverland was prior to that time of January and February and

March of 2003?
A. No.
Q. Did you know who Michael Jackson was prior to February of 2003?
A. No.
Q. Do you know who Michael Jackson is today?
A. We all know, because you see it on T.V.
Q. All right. Now, did you ever see a documentary on televis ion that was titled Living with
Michael Jackson?
A. No.
Q. Did you ever see anything on T.V. that featured your grandchildren, where your
grandchildren were shown on television?
A. No. I only see parts of it in the Mexican channel, because those are the channels I
watch.
Q. Did you ever see any shots at all of your grandchildren on television?
A. Lately, just little clips, short little clips on 52 and 34.
Q. Did you become aware of the fact that your grandchildren had been featured on
television in a documentary?
A. No.
Q. At some point in time, did you have a numb er of reporters or press who came to your
home?
A. Oh, yes. My door, my mailbox. They opened my mailbox.
THE INTERPRETER: Okay, okay. (Laughter.)
THE WITNESS: They even opened my mailbox. They yelled at me. I even h ad to call the
police several times. They parked everywhere. The worst ones were the 52, Channel 52.
The light was so bright they seemed like a soccer field. The police came and told them to
take that away. And that reporter, she said no, because she had to do a report. Another
police officer came and he did make them to turn it off, and then they -- six oclock p.m.,
they turned it on again.
Q. BY MR. ZONEN: Do you know what it was that caused all of these reporters to come to
your home?
A. Yes.
Q. What was it?
A. The participation of that man, the involvement of that man.
Q. All right. Did you -A. They wanted to find out what I knew from new talk, but I didnt know anything. I found
out later when I watched all those reports, all those newscasts, everything.
Q. At some point in time, did your children come to your home from Neverland?
A. Yes.
Q. Did you do something to facilitate their coming to your home, to cause them to come
to your home?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled.
THE WITNESS: I had to lie and say that I was ill so that they could come.
Q. BY MR. ZONEN: Who did you -A. Because those children love me very much, because I raised them.
Q. Okay. The children specifically, who was it who you told that you were sick?
A. The truth is I dont remember. The one thing I know is that my children called me.
MR. MESEREAU: Objection; nonresponsive.

THE COURT: Sustained.

Q. BY MR. ZONEN: Was it -MR. MESEREAU: Move to strike.
MR. ZONEN: Im sorry?
MR. MESEREAU: Move to strike.
THE COURT: It wasnt stated, so it doesnt need to be stricken.
Q. BY MR. ZONEN: Was it one of your grandchildren who called you?
A. Yes.
Q. Do you remember which of the three?
A. No.
Q. Do you remember if it was one of the boys as opposed to Davellin?
A. Yes. Yes. I dont remember if it was Gavin or Star.
Q. Did you tell that grandchild that you were sick?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled.
THE INTERPRETER: Im sorry, Your Honor.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes.
Q. BY MR. ZONEN: Why did you do that?
A. So that they could come.
Q. Okay. Were you, in fact, sick at the time?
A. No. Well, no. Well, yes, actually, because I do have arthritis and thyroid problems and
things.
Q. All right.
A. High cholesterol. I mean, I can make you a longer list. (Laughter.)
Q. Its not necessary. Did they, in fact, come, the three children?
A. Yes.
Q. Do you know if it was the same day or at a subsequent time, at a later time?
A. They called me in the afternoon. Later in the afternoon they called me and they said,
Mom -MR. MESEREAU: Objection; hearsay.
13 THE COURT: Overruled. You may comp lete your answer.
THE WITNESS: They call me mo m, because they do call me mom, so they asked me if
I was sick. And I said yes, because I was -- I was desperate and I was anguished because
I hadnt seen them, and I would get a heart attack from not seeing them.
Q. BY MR. ZONEN: And did they arrive that day or soon thereafter?
A. The following day, I believe, is when they came.
Q. All right. Do you know who it was who delivered them to the house?
A. No. Because my house is like this, the entrance is right here, so they had to walk. 6857
Q. All right. Did they come into the home, the three children?
A. Yes.
Q. This is your El Monte home, the home in El Monte?
A. Yes. My house.
Q. The person who -- how long have you lived in that house?
A. 36 years.
Q. And your husband -A. Approximately. More or less.
Q. Your husbands name is what, please?

A. David.
Q. And David has been married to you for how many years?
A. Hes been my only boyfriend and my only husband and hes still with me.
Q. How old were you when you met him?
A. 20. 20.
Q. And David does what kind of work?
A. Hes a trucker.
Q. And he has worked in that capacity for how long?
A. His whole life, since I met him.
Q. Is he still working?
A. Yes.
Q. And hes still a trucker?
A. Yes.
Q. For which company does he work?
A. Im not -- Im going to say it, but I dont know if its right. Ralphs?
Q. A grocery store chain?
A. Yes, the markets.
Q. All right. Going back to when the three children arrived at your house, did you see the
person who drove them to the house?
A. No.
Q. Did that person walk them to the door?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. You may answer.
THE WITNESS: Why are you saying that?
Q. BY MR. ZONEN: Did that person -A. No, Im saying him. Why does he say to wait? Is it -Q. Because he can. (Laughter.)
THE WITNESS: Im sorry.
THE COURT: Okay.
MR. ZONEN: Let me change the question.
Q. Did you see at any time the person or persons who delivered your three children to
your home?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. ZONEN: Do you know who the person was who delivered the children to the
house?
A. Miguels people.
Q. Is Miguel Michael Jackson?
A. Yes. Its Miguel in Spanish.
Q. Thank you. Miss Ventura, when your children came into the house, was your daughter
Janet and her then boyfriend Jay at your home at the time that the three grandchildren
arrived?
A. No. I received them by myself.
Q. At some time later that day or at another day, did Janet and Jay arrive at your home?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes, they came later.
Q. BY MR. ZONEN: Was it the same day or a different day?

A. Yes. The same day.

Q. The same day. All right. Would you describe for us how the children were behaving at
the time that they arrived from Neverland?
A. Those children that came were not my grandkids.
Q. Explain that to us, please.
A. The -- their entire life, my grandkids and I were very close. Their happiness, their
sadness, their games, all of that. I was always very important for all three of them. When
they came back, they didnt talk to me the same way. They were different kids. And -and even up till now Gavin is not the same child.
MR. MESEREAU: Objection. Nonresponsive; move to strike.
THE COURT: Overruled.
Q. BY MR. ZONEN: After the three children returned from Neverland to your home, did
you receive any phone calls at your home?
A. Many. Many, many. Day and night. I had a red telephone, and it had a square like that.
And in that little square sometimes it said Neverland, and some other time Frank, or I
dont know. And the voice would say, Gavin, Star, Davellin, somebody answer.
MR. MESEREAU: Objection; nonresponsive.
THE COURT: Excuse me. Sustained.
Q. BY MR. ZONEN: Could you actually hear messages being left on your phone?
A. Yes.
Q. Were there -- was -- were there voices on the messages asking for your grandchildren?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. Just a moment.
THE WITNESS: Yes.
THE COURT: Have you offered her some water? Im -- Yourself too, if you -THE INTERPRETER: I have my bottle. Thank you.
THE COURT: Go ahead.
Q. BY MR. ZONEN: Could you tell if it was one voice or more than one voice leaving
messages on the phone?
A. Sometimes it said on there Neverland.
Q. Okay.
A. And some other times it was that Frank. What really hurts me is that my
granddaughter erased it. Otherwise -- she always liked to -- well, one of the phones broke
down, and she tried to make, out of two phones, make one.
MR. MESEREAU: Objection; nonresponsive.
THE COURT: Sustained.
MR. ZONEN: A ll right. The latter part of the answer, Your Honor, youre referring to?
THE COURT: Well leave the first two sentences in.
Q. BY MR. ZONEN: You told us what you were able to see on the screen on the phone, and
you told us you were also able to hear a voice.
A. Yes.
Q. Is that your -A. Yes. The phone had a little square, and then you could hear the person talk.
Q. All right.
A. And I never allowed the kids to pick up the phone because I was always watching out
for that. You know, I would also get calls very late at night, maybe thinking that I was
asleep. But ever since that time when they came, when they were no longer the same
kids, I couldnt sleep anymore because I was always watching out for that phone.

Q. Let me ask you some questions about the messages. Were the messages always left in
English?
A. Yes.
Q. Were you able to understand the messages?
A. No. What I understood is as soon as I saw Neverland -MR. MESEREAU: Objection; nonresponsive.
THE COURT: Sustained.
Q. BY MR. ZONEN: What were you able to understand of the messages?
MR. MESEREAU: Objection; hearsay.
MR. ZONEN: Its not for the truth of the matter.
THE COURT: Ill allow the question.
THE WITNESS: What I understood is that it said Neverland and that they were calling
my grandkids. Thats what I understood.
Q. BY MR. ZONEN: You were able to hear the names of the kids being called?
A. Yes.
Q. All right. Could you tell if it was the same voice each t ime or if it was a different voice?
A. The same one.
Q. Give us a sense of how many times this person called.
MR. MESEREAU: Objection; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: The number of times I cant tell you, but I know that it was very often.
Q. BY MR. ZONEN: Over what period of time did the calls continue? In other words, was it
over days, over weeks, or months? How would describe the length of time that the calls
continued?
A. A long time. I couldnt tell you days or whatever, because I just -- I didnt keep track of
days, hours. And I watched my grandkids until my daughter took them, took the boys.
And Davellin stayed with me.
Q. Did you ever become aware of the fact that there were people watching you?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled.
THE WITNESS: All around my house there was a lot of cars. There was a lot of people.
Q. BY MR. ZONEN: Did anybody ever come to the door and attempt to contact you or the
children?
A. Many people came to the door of my house. Cameras. I was -- I was hiding. I was
almost like a prisoner. I had to hide. I couldnt even stick my face out like that, because
everybody would just come on, come on over.
Q. Within a week or two after your grandchildren returned to your home, did anybody
come to the door, knock on the door, and inquire about the children?
A. Yes. All the time. All the time.
Q. Anybody throw stones at your house?
A. Yes. Once. Im speaking slow so that you can be talking. I was sitting down watching
the soap operas, because Im always watching my soap operas. That T.V. I have in the
dining room. Davellin sleeps -- or used to sleep in the bedroom that goes out -- thats out
to the street. But sitting like this, heres the dining room and there was her bedroom. But
I was sitting down when I heard, bbrrr, something like that.
MR. ZONEN: (To the interpreter) That was well done. (Laughter.)
THE WITNESS: But I thought to myself, well, it must be the kids just out in the street.
But, no, then again, and again. And then by the third time is when I stood up --

MR. MESEREAU: Objection. Nonresponsive and narrative.

THE COURT: Narrative; sustained.
Q. BY MR. ZONEN: What did you then do?
A. I stood up and I walked around. And Davellin just rushed out of the bedroom, and she
asked me, Mama -- Mom, did you hear that? So I told her, Yes, somebodys throwing
rocks at the house. We both went up to the door. And when we went out like that, we
saw a man standing next to the car. It was a small car. I dont know if it was black or
blue, because it was getting late.
MR. MESEREAU: Objection. Narrative; nonresponsive.
THE COURT: Sustained.
Q. BY MR. ZONEN: After you saw the vehicle, did you see the person near the vehicle?
A. Yes.
Q. Could you -A. Right at the time that my granddaughter and I went out, we turned like that, because
right at the time, a rock was coming on its way, and it hit right on the window of
Davellins bedroom.
Q. While you were standing watching?
A. Yes. Right at the time that we went out, like that.
MR. MESEREAU: Objection. Narrative; nonresponsive.
THE COURT: Sustained.
MR. ZONEN: Perhaps we could get the translation of the last -- I dont know if the
interpreter translated the last statement.
THE COURT: Well, I sustained the objection, narrative, so -MR. ZONEN: Let me back you up a couple steps.
Q. You actually saw somebody throw a stone?
A. Yes.
Q. Was it the person standing next to the car?
A. Yes.
Q. Can you describe that person for us, as best you can?
A. I know that it was a man that was standing there, and he had a cap. Right at the time
that we saw the man, Davellin and I, I told Davellin, Call the police.
MR. MESEREAU: Objection, Your Honor. Narrative.
THE COURT: Sustained as to the last sentence.
Q. BY MR. ZONEN: Were you standing with Davellin at the time you saw the stone being
thrown?
A. When he threw -- when he threw the last rock that I saw that hit Davellins bedroom
window, we were both standing there.
Q. Did you then contact law enforcement?
A. Thats when I told Davellin to run and call the police.
Q. Did you -A. And so that man very quickly got in the car and took off.
Q. And did you, in fact, call the police?
A. No.
MR. ZONEN: May I have just one moment, please, Your Honor?
THE WITNESS: I dont really remember, but, yes.
MR. ZONEN: Thank you, Your Honor. I have no further questions.
MR. MESEREAU: No questions, Your Honor.
THE WITNESS: But the other day --

THE COURT: Thank you. There are no other questions. You may step down.
MR. ZONEN: Im sorry, Your Honor, I need to call the next witness. I neglected to do that.
Your Honor, we will not be needing the interpreter any further. Whos doing this, you or
Bob?
MR. MESEREAU: Bob.
THE COURT: Counsel, maybe youd like to take this moment to explain the scheduling
issue that you were going to raise while were waiting for the witness.
MR. SNEDDON: Approach the bench?
THE COURT: No, its all right. You can just tell us. Go ahead and tell us. I mean, its not a
private matter.
MR. SNEDDON: I think it is, because it involves some evident iary issues.
BAILIFF CORTEZ: Your microphone, sir.
THE COURT: All right. Approach the bench. (Discussion held off the record at sidebar.)
THE COURT: Please remain standing. Face the clerk and raise your right hand.

WILLIAM F. CALDWELL
DIRECT EXAMINATION BY MR. ZONEN:
Q. Sergeant Caldwell, your current occupation, please?
A. Im a sergeant for the Santa Barbara Sheriffs Department.
Q. Youve been in the Sheriffs Department in Santa Barbara County for how long?
A. 27 years.
Q. What is your current position?
A. Im a detective sergeant in the Coastal Station.
Q. Im sorry, which station?
A. Detective sergeant in the Coastal Station, Carpinteria area.
Q. Youve held that particular position for how long?
A. Four years.
Q. Were you involved, among other detectives, with searches that were executed on the
18th of November, 2003?
A. Yes, sir.
Q. The area where you searched was what, please?
A. It was the office of Bradley Miller, a private investigator in Beverly Hills, California.
Q. And do you remember the address?
A. I dont. 211 South Beverly Drive, No. 108, I believe.
Q. Very good. In Beverly Hills?
A. Yes.
Q. All right. Can you tell us at approximately what time you conducted that search?
A. At approximately 9:30 in the morning.
Q. And how many of you went to conduct that search?
A. Three of us.
Q. And who were they?
A. Investigator Tonello from the District Attorneys Office and Detective Forney from the
sheriffs department.
Q. The three of you. And did you have any uniformed officers with you at that time?
A. Yes. Officer Roy Tinkler from the Beverly Hills Police Department.

Q. When you arrived at that location, was anybody at the office?

A. No, sir.
Q. Was the office closed and locked?
A. Yes, it was.
Q. Were you able to gain entry into the office?
A. Yes.
Q. And how were you able to do that?
A. We contacted the property manager who ran the building, and she provided a key for
entrance into the outer door of the office.
Q. And did that get you through the outer door into the office?
A. Yes.
Q. Did you at some time, either prior to or after gaining entry into the outer door, make
an effort to contact Brad Miller?
A. Yes.
Q. And how did you do that?
A. I previously obtained Mr. Millers cell phone number and I tried to call it and I left a
message on his voice mail on the cell phone.
Q. Were you able to get ahold of him?
A. No.
Q. Did you attempt to gain entry into the inner doors in the office?
A. Yes.
Q. How many inner doors were there?
A. A total of three.
Q. And where did they lead to?
A. One of the offices was open. The door led to a secretarial area, and then the other two
doors were locked.
Q. All right. Were you able to gain entry into the two rooms that were locked?
A. Yes.
Q. How did you do that?
A. Through use of a sledgehammer.
Q. What does that mean?
A. We forcibly opened the door by pounding on the door with a sledgehammer.
Q. How were you able do that? What -- kind of give us a sense of whats involved. Weve
all seen it on T.V., but I dont know that weve ever -MR. SANGER: Im going to object. Relevance, Your Honor.
THE COURT: Sustained.
MR. ZONEN: Sustained as to the entirety of that question or just the comments at the
end?
THE COURT: The entirety.
Q. BY MR. ZONEN: Did you gain entry into that office?
A. Yes, sir.
Q. And what were the two rooms that you gained entry into?
A. One of the offices was the office of Bradley Miller, the private investigator, and the
second room was a conference room.
Q. All right. Did you seize a number of items from that location?
A. Yes.
Q. All right. Did you have something to do with the documentation of the items that were
seized?

A. Yes.
Q. Tell me what your role was in that.
A. My role was to complete the property form at the scene. Detective Forney would bring
me the items, and I would number them and list the items on a property form, and put
them in bags, and numbe the bags.
MR. ZONEN: Excuse me. Im sorry.
Q. I wou ld like to show you three exhibits currently marked for identification No. 831,
832, and 833. If I may approach the witness, Your Honor.
THE COURT: You may.
Q. BY MR. ZONEN: If you would look at those three photographs and please tell us what
they are.
A. Exhibit 831 is a photograph of a cabinet with a television and VCR and a number of
video and audiotapes. Exhibit 832 is a blow-up of some audio tapes. And Exhibit 833 is a
blow-up of some VHS video cassette tapes.
Q. Now, the audiotapes and the videotapes, the VHS tapes that you can see in 832 and
833, are they also visible in 831?
A. Yes, sir.
Q. And can you describe in that photograph where they are?
A. Theyre located on a shelf above the VCR, which is standing on top of the television.
Q. Were items seized from that general location -A. Yes.
Q. -- as depicted in 831?
A. Yes.
Q. And among the items that were seized, can you just describe what they were, please?
A. Videotapes and audiotapes.
Q. Id like to now show you a series of tapes, if I can. If I could approach the witness with
all of them.
THE COURT: All right.
Q. BY MR. ZONEN: I would like to show you, if I can, Exhibit No. 823, and that is Court
Exhibit 823.
A. Okay.
Q. Can you tell us what this item is?
A. Its a videotape. Its entitled, Arvizo 2-19 and 2-21. And it says, Re MJ. And its my
Evidence Item No. 811. It was seized from this cabinet that Ive talked about earlier.
Q. And who was it who actually seized it from the cabinet?
A. Detective Rod Forney.
Q. Did you see it in the cab inet?
A. Yes.
Q. Court Exhibit No. 824, please. Take a look at that, Court Exhibit No. 824, and tell us
what that is.
A. Its a VHS cassette tape. Its entitled, To Brad Re Arvizo. Its my evidence Item No.
812. And it was seized from the top shelf, as ind icated in the photo.
Q. No. 825, please, Court Exhibit No. 825, tell us what that is.
A. This is a VHS video cassette tape. Its entitled, Arvizo Move, 3-5-3. MJJ. And its my
Evidence Item No. 815. And this, as well, was seized from that same location, the cab inet
above the television.
Q. Showing you Item 826, please.
A. This is a VHS video cassette tape. Its entitled, To Brad, Jeanette, March, Johnny.

Theres a phone number, 1-866-256-6275. And its marked, the other side, MJJ, Arvizo,
2003. Its my Evidence Item No. 816. And it was seized from the location as indicated,
the cabinet above the television.
Q. Item 827, Court Exhibit Item 827, tell us what that is.
A. This is an audio cassette tape. Its marked MJ or labeled MJ. Its my Evidence Item
No. 817. And it was seized on that same shelf above the televis ion.
Q. Court Exhibit No. 828, please tell us what that is.
A. This is an audio cassette tape. Its entitled, Michael Jackson. Its my Evidence Item
No. 818. Its also labeled on the side, Michael Jackson, and it says, Arvizo, ST, MT, 216-03. And it was seized from that same location on the shelf above the televis ion.
Q. Item 829, p lease tell us what that is.
A. This is a mini video cassette tape. Its marked Arvizo Move. Its my Evidence Item
819. And it was seized, as well, from the shelf in the television cabinet, the same locat ion.
Q. Now, as the person who weve described previously was the scribe, what was your
obligation with regards to those items?
A. My obligation was to collect them from Detective Forney, to note the location that he
seized the items from, to number the items, and to log the items in on an evidence sheet
and to place them in those respective bags and seal them.
Q. And did you do that as to each one of those items?
A. I did.
Q. The three photographs that Ive handed you, tell us again the court exhibit number of
those.
A. 831 is a photograph depicting the cabinet and the television, the VCR and the tapes on
the top shelf. Exhibit No. 832 is a blow-up or an enhancement of the audio cassette tapes.
And Court Exhibit 833 is a blow-up or enhancement of the video, VHS tapes.
Q. The content of those three photographs, are they accurately depicted in those
photographs?
A. Yes.
MR. ZONEN: I would move to introduce into evidence 831, 832 and 833.
MR. SANGER: No objection.
THE COURT: Theyre admitted.
MR. ZONEN: I have no further questions.
CROSS-EXAMINATION BY MR. SANGER:
Q. Sergeant Caldwell.
A. Mr. Sanger.
Q. How are you?
A. Very well, sir. Thank you.
Q. Good. Youve been a detective for how many years total?
A. 16 or 17 years.
Q. So 27 years in the sheriffs department, correct?
A. Yes.
Q. 16 or 17 of those as a detective, correct?
A. Yes.
Q. Four years as the detective sergeant in charge of the Carpinteria substation or whats
now called the Coastal Station, correct?
A. Yes, sir.

Q. And Vic -- Victor Alvarez is a detective who works under your supervision; is that
correct?
A. Yes, sir.
Q. And your assignment in this case came from whom?
A. Well, initially from Lieutenant Kitzmann and Lieutenant Klapakis.
Q. All right. So the two lieutenants, Kitzmann and Klapakis, assigned you, in essence, to
be a scribe on the search of Brad Millers office; is that correct?
A. Well, they didnt make that individual assignment. I made that assignment to myself.
Q. All right. Lets put it this way: They assigned you to go do the Brad Miller search in this
case; is that correct?
A. Yes, sir.
Q. Did they assign you, with your background and experience, to do anything else in this
case other than the Brad Miller search?
A. Yes.
Q. What else?
A. A search of a storage locker in W est Los Angeles.
Q. All right. That was related to the Brad Miller search; is that correct?
A. Yes, sir.
Q. All right. So other than the Brad Miller search and that spin-off, you were not assigned
to do anything else in this investigation relating to Mr. Jackson; is that correct?
A. Yes.
Q. Now, with regard to the location that you searched, you understood that to be the
office of a private investigator; is that correct?
A. Yes.
Q. And you knew, before you went in, that Bradley Miller was the owner of the premises
or was the person whose offices you were searching, correct?
A. Yes.
Q. And you knew Bradley Miller was, in fact, a licensed private investigator, correct?
A. I was told that, yes.
Q. And had somebody else done some background work on that and presented you with
it?
A. I believe that informat ion was contained in the search warrant affidavit, yes.
Q. All right. And at the time you searched, did you know who Bradley Miller was working
for? Of your knowledge, did you know who he was working for?
A. I -- at one point I was told that he worked for Mr. Jackson.
Q. Okay. And later you found out he worked for Mr. Geragos, correct?
A. Yes.
Q. All right. Now, Mr. Geragos, at the time and currently, was a prominent lawyer in
Beverly Hills; is that correct?
A. Yes.
Q. All right. And Bradley Miller had an office in Beverly Hills, correct?
A. Yes.
Q. During the course of the search, you determined that there was a connection between
Mr. Geragos and Bradley Miller, correct?
A. When you say connection Im not clear on the question, sir.
Q. Well, lets put it this way: In all your experience in law enforcement, youre aware that
private investigators often work for lawyers, correct?
A. Yes.

Q. All right. And in the course of your doing your search, you ran across correspondence
indicating that there was a connection between Mark Geragos and Bradley Miller, correct?
A. Yes.
Q. All right. Now, you mentioned that on one of the tapes there, there was a reference -maybe more than one, but at least one of the tapes theres a reference to, quote, Michael
Jackson -A. Yes.
Q. -- correct? Youre familiar with the manner in which private investigators work, to a
certain extent, correct?
A. To a certain extent, yes.
Q. Youve never been one?
A. No, sir.
Q. All right. But you have certainly dealt with a lot of private investigators during your
career, correct?
A. Yes.
Q. And a lot of your colleagues in years gone by, who retired from law enforcement, have
become private investigators, correct?
A. Yes.
Q. All right. And private investigators, when theyre working for a lawyer, are usually
assigned to work on a particular case; is that correct?
A. Yes.
Q. And often they will give the name of their -- the client of the lawyer -- let me withdraw
that. Often the name of the lawyers client will be the designation that they will p lace on
their materials; is that correct?
A. My answer would be a guess. I dont know one way or the other.
Q. Its not unusual for people on either side of the -- of the matter, either a private
investigator working for a defense lawyer or law enforcement, to refer to, for instance,
the Smith case, am I right?
A. Thats correct.
Q. So youd refer to matters pertaining to an investigation relating to Mr. Smith as being
the Smith matter, right?
A. Yes.
Q. Okay. That does not, in and of itself, imply that Mr. Smith had any particular control or
direction over anything that -MR. ZONEN: I would object to this as speculative and beyond the scope of this witnesss
expertise.
MR. SANGER: I didnt finish the question, but the Court got the gist of it, I suppose.
THE COURT: Go ahead and finish.
MR. SANGER: All right. Let me try to start it over.
Q. The fact that, for instance, hypothetically, based on your training and experience, the
name Smith appeared on a file or a videotape, or something of that sort, would not
necessarily mean that Mr. Smith had any control or direction with regard to what the
private investigator is doing; is that correct?
THE COURT: Ill sustain the objection.
MR. SANGER: All right. Very well. No further questions.
REDIRECT EXAMINAT ION BY MR. ZONEN:

Q. You mentioned the presence of an affidavit. Was that an affidavit to a search warrant?
A. Yes.
Q. And did you have that search warrant with you?
A. I had the search warrant with me, yes, sir.
Q. And had you reviewed the affidavit prior to the execution of the search?
A. I did.
Q. That was a search warrant authorized by a judge in Santa Barbara County; is that
correct?
A. Correct.
MR. ZONEN: No further questions.
MR. SANGER: Im going to move to strike the last question and answer, Your Honor, as
beyond the scope of direct and irrelevant.
THE COURT: It is beyond the scope, but Ill allow the question. Do you want any
examination on the issue?
MR. SANGER: No, Your Honor. Thats fine.
THE COURT: All right. Thank you. You may step down.
MR. ZONEN: W ell call Detective Rod Forney to the stand.
THE COURT: You know, were just going to start -- in a couple minutes were going to
start the in-camera hearing, so have the next witness availab le at quarter to 12:00.
MR. ZONEN: Thank you.
THE COURT: Well excuse you a little early for lunch; be in a few minutes. The nature of
the hearing that were going to have is going to be in camera, in chambers, and Ill have
the court reporter and an attorney from each side come back. And Mr. Jackson may
attend or may not attend, as you deem -- whatever you request, Mr. Mesereau.
MR. MESEREAU: Okay.
(Whereupon, proceedings were held in chambers and, having been ordered s ealed by the
Court, are omitted herefrom.)
(The following proceedings were held in open court outside the presence and hearing of

THE COURT: Mr. Sneddon, you had indicated you had a scheduling issue you wanted to
raise outside the presence of the jury?
MR. SNEDDON: I do.
THE COURT: Go ahead.
MR. SNEDDON: Your Honor, there are several issues I want to address the Court on, and
some of it is going to be some good news for the Court and some of it is going to be bad
news for the Court, or end up being bad news for me, one or the other. But in any case, I
wanted to alert the Court to several issues. The first one that I want to alert the Court to
is, for scheduling purposes, that we believe, under our estimation, that we will probably
by complet ing our evidence by the end of next week, so that the defense is prepared to
know that thats -- we estimate we will be done by the end of next week. The second
issue involves -- I wanted to alert the Court, because I had a conversation with the
attorney from Las Vegas last night, that one of the witnesses who you signed an order of
transportation on, Mr. Carter, who is scheduled to be here either Thursday or Friday, that
the lawyer indicated to me that he was going to invoke his Fifth Amendment rights with
regard to the charges which are currently pending against him in Nevada. And that raises

several issues to the Court, and to us personally, with regard to his testimony. And I
thoroughly intended to have for the Court this morning a memorandum of the issues
involved. And the reason I dont is because Mr. Franklins computer blew up, and playing
around with it trying to get the two documents that I had prepared and should have been
here this morning and filed by 8:30 didnt -- arent done yet. And my last estimate is
theyre working on the computer to free up the stuff thats in there. I dont understand it,
but a 15-year-old teenager probably does. So in any case, those were issues I wanted to
bring to the Courts attention that are issues before Mr. Carter testifies. And thats why I
had the order changed from Thursday to Friday. In add ition to that, there are several
outstanding issues that were going to ask -- one of the other things that we were going to
file at 8:30 this morning was to calendar with the clerk a hearing, like we did on the 1108,
that its now time, since Mrs. Arvizo has testified, to revisit the issues the Court postponed
on the testimony of the domestic violence expert that we filed briefs on and counsel for
the defendant filed briefs on. And so before we can go forward on that front, we need to
get some rulings from the Court on that, as well as, the Court knows, the issue that I filed
and you asked that counsel for the defense did a brief yesterday on Mr. Abdool. So thats
a long way of saying that the good news is, I believe that were about to the point where
we can close off our case next week. The bad news, which I was saving for last, is I dont
think we have enough witnesses to complete this week. And Im very concerned about our
ability to bring anybody in on Friday particularly. And the reason for that is that a lot of
the witnesses that are on for next week are people who are co ming from -- involve
telephone records and things of that nature, which we had to give advance warning and
are not local people. And we had to line it up in terms of their transportation and in terms
of their ability to stay in order to try not to spend extra money having people fly and
cancel trips and pay penalties on flights and stuff like that. And we believe that we can put
all of those people on on Tuesday. Well have witnesses on Monday. But I believe that -that also, like I said, we cant go forward on some of these until we get some rulings. And
the last thing is that we want to look at those disks, because that could impact what we
do in the future. And not having had an opportunity to look at those and its not simply
something that we can simply turn over to investigators and say, Look at these things, I
think we, as the lawyers involved in the case, are going to need an opportunity to do that.
So I guess what Im telling the Court is that -- that we will be ab le to go forward as the
Court has asked us to in the past, and thats consecutively with witnesses, but I believe
on Friday that we will have a very difficult time rustling up anybody for that date. We did
not anticipate certain things that have happened in this courtroom today or yesterday,
and so thats where we are. And thats the status on everything. And as you know, weve
only -- one time since we started our case did we finish early. So Ithink weve fo llowed the
spirit, if not the letter, of the Courts rulings. And I think we just have reached a point
where trying to get the caboose in line for the finish has been a little more difficult than
keeping the train on track to this point.
THE COURT: Do you have enough witnesses for tomorrow morning?
MR. SNEDDON: At this particular point in time, we believe we do. It will be close, but I
think, you know, the Court wanted us to get that three hours in, so -- but its a local
witness. So if you were contemplating something else, I could push that witness off to the
next day or something.
THE COURT: Well, I think the jurors would be happier with a three-day weekend than with
an interruption in the middle of the week. I dont know that, but I think so.
MR. SNEDDON: I agree with you.

THE COURT: So then the -- so, Mr. Mesereau, before I start saying anything, do you want
to be 6889 heard?
MR. MESEREAU: Your Honor, we plan to call a lot of witnesses and we could run into some
scheduling problems and we may be asking for some consideration, so I think the least we
could do is be considerate in this regard. Because I think anyt ime youre putting on a
lengthy case, you can run into scheduling difficulties. So
THE COURT: Are you saying that you sympathize with Mr. Sneddon? (Laugher.)
MR. MESEREAU: I believe -- I think we should take Friday off, Your Honor.
THE COURT: How about the motions? I think the domestic vio lence one, we have all the
material. I just needed to know where we were. You may want to make some add itional
points on that, each side, before I ru le. But as far as the written work done, its done, I
think.
MR. MESEREAU: And there are some other issues, Your Honor, I think, like the motion
Miss Yu filed, which is important to our case.
THE CLERK: Cant hear, Judge.
THE COURT: They cant hear you in the back.
MR. MESEREAU: The motion that Miss Yu filed dealing with examinat ion on sexual conduct
-THE COURT: Oh, yeah.
MR. MESEREAU: -- is an important one to us.
MR. SNEDDON: Judge, could I give you two other things to factor into your
contemplation?
THE COURT: Yes.
MR. SNEDDON: We anticipate filing, no later than tomorrow morning, two other motions
for reconsideration on issues that the Courts addressed. Theyre short, brief motions, but
weve almost got them finished.
THE COURT: All right. Well, I think the way that I would like to handle it, then, would be
that we take whatever evidence you have -- today, how much evidence do you have for
today?
MR. SNEDDON: How much we have today, Your Honor? I think -- I think well probably
finish the day out.
THE COURT: Okay.
MR. SNEDDON: I wasnt short today. I mean, we could get ten minutes short or
something, but think well be here the rest of the day.
THE COURT: Lets finish the day out with evidence. And then what I would do is, if we
finish early with evidence on Thursday, well start the motions. I think we could all do with
Friday off, so if we can hear -- if we can get to the end of the evidence and still have the
motions before Friday, that would be a good thing, so lets make that our goal.
MR. SNEDDON: I can arrange that, Judge. 6891 I can drop one witness off the bottom.
THE COURT: You can do that?
MR. SNEDDON: I can do that, Your Honor.
THE COURT: Okay. So lets do that. Lets figure that well use today, tomorrow, and -- half
of tomorrow and Thursday, and well go dark Friday, but well have the motions done
before we leave. Thats a condition.
MR. SNEDDON: Okay.
THE COURT: We will hear the motions before Friday.
MR. MESEREAU: Thank you, Your Honor.
MR. SNEDDON: All right.

ROD FORNEY
DIRECT EXAMINATION BY MR. ZONEN:
Q. Sir, what is your current occupation?
A. Im a detective for the Santa Barbara County Sheriffs Office.
Q. Youve been so employed for what period of time?
A. For the sheriffs department, approximately 11 years.
Q. And as a detective?
A. As a detective for approximately five years.
Q. And your current assignment is what?
A. As a detective in the Coastal Operations Bureau, which is in Carpinteria.
Q. Were you called to assist on the execution of a search warrant back on the 18th of
November, 2003, at an office in Beverly Hills?
A. Yes, I was.
Q. Do you happen to remember the address?
A. It was 211 South Beverly Drive, and it was Suite -- or Room No. 108.
Q. Do you recall whose office it was?

A. Yes, sir, I do.

Q. And whose office was it?
A. Bradley Millers.
Q. And your responsibilities that day were what?
A. To seize evidence.
Q. All right. And did you, in fact, seize evidence at that time?
A. Yes, I did.
Q. Now, theres three photographs in front of you. Go ahead and grab those and take a
look at those photographs. Are those, in fact, Exhibit Nos. 831, 832 and 833?
A. Yes, they are.
Q. And can you tell us what those are, 831, 832 and 833?
A. Theyre photographs of items I had seized from Mr. Millers office.
Q. All right. And in front of you are a series of objects. May I approach the witness, Your
Honor?
THE COURT: Yes.
Q. BY MR. ZONEN: Id like to show you each of these items, please, consecutively by
number, and tell me if you recognize these items. Starting with Court Exhibit 823.
A. Yes, I recognize that.
Q. Is that an item that you seized? 6894
A. Yes, it is.
Q. And turned over to Sergeant Caldwell?
A. Yes, I did.
Q. And does that have a sheriffs number associated with it?
A. Yes, it does.
Q. And what is that number?
A. Which -- theres numerous numbers that are associated with it. This is Item No. 811
and its Tag No. 122980.
Q. Okay. Lets -- well do the item numbers on this case. That was Item No. 811; is that
right?
A. Yes, it is.
Q. In this case, the court number is 824. And tell us what it is, please.
A. Its Item No. 812, another videotape.
Q. Its a videotape. And you seized that item as well?
A. Yes, I did.
Q. And Item No. 825, and this is Court Exhibit 825, what is that?
A. This is actually Item No. 815, and its a videotape.
Q. When you say 815, do you mean Sheriffs No. 815?
A. Thats correct.
Q. And its a videotape as well?
A. Yes.
Q. And the next one is Court Exhibit 826. Tell us what this is.
A. Its Sheriffs Item No. 816. And its also a videotape that I seized.
Q. All right. And the next one would be Court Exhibit No. 827. What is that?
A. Okay. This is an audiotape that I seized. It is item -- Sheriffs Item No. 817.
Q. And then the next one? Quick, before it falls out of the bag. Court Exhibit No. 828?
A. This is Sheriffs Item No. 818. And its another audiotape that I seized.
Q. All right. And then Court Exhibit No. 829, what is this?
A. Its item -- Sheriffs Item No. 819. And it is a small videotape, dig ital videotape.

Q. And each of these items that you seized and turned over to Sergeant Caldwell, from
where did you retrieve those items?
A. I retrieved them from like an entertainment unit in the conference room of Bradley
Millers office.
MR. ZONEN: Your Honor, the three photographs are currently in evidence. May I publish
them at this time?
THE COURT: Yes.
MR. ZONEN: W e have to switch over toInput -- is it 4?
THE BAILIFF: Ill get it.
Q. BY MR. ZONEN: The exhibit is 831 that were looking at at this time. Tell us, please, in
which room in Mr. Millers office is this?
A. It would be what I would refer to as the conference room.
Q. All right. And can you tell us what were looking at in this photograph?
A. Were looking at the videotapes and audiotapes that I had seized.
Q. This is Item No. 833 currently on the board. Can you tell us what this is?
A. Those are some of the tapes that I had seized that were in the same location.
Q. And then finally 832?
A. Those are also tapes that I had seized from the same location.
MR. ZONEN: Thank you. I have no further questions.
CROSS-EXAMINATION BY MR. SANGER:
Q. Detective Forney.
A. Yes.
Q. How are you?
A. Fine, thank you.
Q. Good. How long have you been a detective?
A. Approximately five years.
Q. And how long have you been a deputy sheriff?
A. A deputy sheriff for 11 years total.
Q. Eleven total including the five as a detective?
A. Yes, and then another 14 as a police officer.
Q. And with what department?
A. Bakersfield Police Department.
Q. Okay. Did you have assignments there other than patrol?
A. Yes, I did.
Q. Were you assigned to detectives at any time?
A. I was sort of a street-level vice/narcotics unit and also traffic as a motor officer.
Q. Okay. So would you just tell us -- thats 20-some years anyway?
A. 25 years.
Q. All right. And you were assigned to work on the case regarding Mr. Jackson; is that
correct?
A. Yes, I was.
Q. And your assignment was to go to the premises of Bradley Miller in Beverly Hills and
execute a search warrant; is that right?
A. Thats correct.
Q. Were you assigned to do anything other than that?
A. No.

Q. All right. Youre familiar -- based on your training, youve had training through a POST
academy, I take it, right?
A. Thats correct.
Q. And then youve had inservice training at two different departments you work at, right?
A. Yes.
Q. And you would agree that chain of custody is a pretty important aspect of handling
evid ence; is that correct?
A. Thats correct.
Q. And thats what we have all these bags for with tape on them and init ials and dates and
all that; is that correct?
A. Thats correct.
Q. Okay. Mr. Zonen made a remark about something falling out of a bag. You want the
evid ence to be in the bag that it was put in so that you can show that there is a chain of
custody, correct?
A. Thats correct.
Q. And so you wouldnt want to, for instance, find a random piece of evidence at the
bottom of a box that fell out of its bag, would you?
A. No.
Q. All right. All right. Now, let me just ask you a question or two about the pictures that
were up on the board, and I wont put them back up. But basically, when you did this
search, you realized you were searching a private investigators office; is that correct?
A. Thats correct.
Q. In the course of searching that office, you found things that seemed to be consistent
with this being an office of a private investigator; is that correct?
A. Thats correct.
Q. There were -- there was office equipment and computers, correct?
A. Yes.
Q. And there were -- there were videotapes -A. Yes.
Q. -- is that correct? There were audiotapes?
A. Yes.
Q. There were tapes other than the tapes that you seized in this particular investigation; is
that correct?
A. Thats correct.
Q. And you would agree theres nothing unusual about investigators having surveillance
tapes; is that correct?
A. Thats correct. Yes.
MR. SANGER: All right. Okay. Thank you. No further questions.
MR. ZONEN: Oh, I have no further questions.
THE COURT: Thank you. You may step down.

MICHAEL DAVY EXAMINATION

DIRECT EXAMINATION BY MR. SNEDDON:

Q. Mr. Davy, were going to need you to scoot up closer to that microphone, if you can.

Its been a constant problem. But you have to lean into it so everybody can hear what you
have to say, okay?
A. Okay.
Q. Youre retired, are you not?
A. Yes.
Q. And what did you do before you were lucky enough to retire?
A. I worked for the Los Angeles City School District as a teacher, a counselor and an
administrator.
Q. For how long were you employed by the school district?
A. 32 years.
Q. During the time that you worked for the school district, were you at some point in time
assigned to John Burroughs?
A. Yes.
Q. And what grades does John Burroughs cover?
A. Sixth, seventh and eighth.
Q. So its three years, then?
A. Right.
Q. And what is the size of the school, approximately, when you were there?
A. When I was there it was about 2400.
Q. Now, during the year 2002 - okay? - the school year 2002-2003 - all right? - what were
your assignments at John Burroughs?
A. I was a grade-level counselor.
Q. And for how long did you -- were you assigned that responsibility?
A. I worked there about -- I worked there five years, and I was in that assignment for
about three and a half years.
Q. At some point during the school year of 2002-2003, were you reassigned some other
responsibilities within John Burroughs?
A. Yes.
Q. And what were your -- what was your new assignment?
A. I became an administrator in charge of attendance.
Q. All right. Now, lets go back to the first one. You were a counselor?
A. Right.
Q. Did you also have teaching responsibilities?
A. No.
Q. Full-time counselor?
A. Yes.
Q. And how many other counselors were there in the school; do you recall?
A. Yes. Theres one for each grade level, and there was a special needs counselor, so
there was three -- a total of four counselors.
Q. During the time that you were a counselor and working at John Burroughs, did you
meet two students by the name of Gavin Arvizo and Star Arvizo?
A. Yes.
Q. And did you meet their mother?
A. Yes.
Q. Do you recall her name?
A. Yes.
Q. What was that?
A. Janet Ventura.

Q. So she was known to you as Janet Ventura?

A. Right.
Q. And were the boys known to you as Ventura or Arvizo?
A. Arvizo.
Q. Now, at some point in time you were assigned as an administrator, correct?
A. Correct.
Q. What are the responsibilities or what were those new responsibilities to you as
administrator?
A. It was to process students during the enrollment process, and to process them if they
were leaving the campus, leaving the school, transferring 6904 to another school or
school district. And it was also to make monthly reports to the district on our status, our
attendance status. And to find out where kids were that were not coming to school.
Q. At some point during the school year of 2002 and 2003, you transitioned from
counselor to administrator, correct?
A. Correct.
Q. Can you tell us approximately when that transition occurred?
A. Well, the person that I replaced went out on leave, so I was just temporarily filling that
persons job in the early parts of January, February, and March. And at some point, that
person retired and I took the job permanently.
Q. So the earliest point would have been January, February, March of 2003?
A. Right.
Q. Okay. Let me show you a photograph, if I might. Just take a look at it for a second.
Ive handed you a photograph that I believe has the number 338 on the tag; is that
correct?
A. Yes.
Q. All right. And in that photograph, do you recognize anybody in the photograph?
A. I recognize Star and Gavin, and I assume the third person is their sister, but I never
met her.
Q. Okay. But the two males in the photograph 6905 are Star and Gavin?
A. Right.
Q. Okay. Now Im going to ask you a few questions about Star and Gavin, okay?
A. Okay.
Q. To your knowledge, were they attending John Burroughs during some portion of the
school year during 2002-2003?
A. Yes.
Q. And during the time that they were at the school, were you a counselor to them?
A. Yes.
Q. Or lets take them one at a time. Were you a counselor to Gavin?
A. Yes.
Q. Were you a counselor to Star?
A. Yes.
Q. So that would have been what grade?
A. Seventh. Seventh grade.
Q. Seventh. Now, later, when you were in charge of attendance, did it come to your
attention that Star and Gavin were not attending school?
A. Yes.
Q. And as a result of that information, what did you do? What course of action did you
take?

A. I notified our pupil services counselor that I was unable to reach the house by phone,
and I asked him to go out there and make a home visit. 6906
Q. Does this gentleman -- is this a male or a female?
A. Its a male.
Q. And whats his name?
A. Stephen Coffman.
Q. Okay. And did you ever hear b ack from Mr. Coffman as to whether or not he was able
to make contact with the family?
A. Yes, he reported back the same day that he was unable to make contact, and that he
had left his card there, and that he had talked to neighbors, but was unable to find out
where they were.
Q. At some point after this conversation that you had with Mr. Coffman, did you receive a
telephone call from Janet Arvizo?
A. I did.
Q. Now, lets go back just in point in time. Prior to this telephone call - okay? -A. Yes.
Q. -- had you met Mrs. Arvizo personally?
A. Yes.
Q. Mrs. Ventura, I guess, as she was known to you.
A. Yes.
Q. And on how many occasions did you meet Mrs. Ventura?
A. Numerous. She came up to school regularly.
Q. And how would you describe her in terms of her cooperation with you and the school?
A. She was very supportive of our efforts.
Q. Now, at the time that you received a telephone call from her after Mr. Coffman had
gone out to her house and been unable to locate her -okay? -A. Yes.
Q. -- with regard to that telephone conversation, did you find anything unusual or
different about that telephone call with Mrs. Ventura than your previous contacts with her?
MR. MESEREAU: Objection. Vague and leading.
THE COURT: Sustained. Sustained.
MR. SNEDDON: On which ground, Your Honor? Just so I know.
THE COURT: Vague.
Q. BY MR. SNEDDON: During the course of your conversation with Mrs. Ventura after Mr.
Coffman went out to the house, how would you describe her demeanor?
A. It wasnt forthcoming.
Q. Was that unusual, in your opinion?
A. Yes.
Q. And when the subject -- would you tell us what the subject matter of the conversation
was?
A. Right, I -MR. MESEREAU: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. SNEDDON: With regard to the conversation that you had with Mrs. Ventura okay? - did it involve the attendance of the kids at school?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled.
THE WITNESS: Yes.

Q. BY MR. SNEDDON: And as a result of the conversation with Mrs. Ventura, did you give
her some information that was necessary with regard to the kids future attendance at
school?
A. Yes.
Q. All right. What did you tell her?
A. I -- they had been gone more than ten days, and I said that I needed her to bring them
back to school or check them out. And she said to me that -MR. MESEREAU: Objection; hearsay.
MR. SNEDDON: Your Honor, its offered as circumstantial evidence with regard to her
state of mind at this particular point in time.
THE COURT: The objection is sustained.
Q. BY MR. SNEDDON: Okay. So without telling us what she said, would you tell us what
you said to her, what instructions you gave her?
A. Right. I told her that I needed the students to either return to school or to check out.
And she said it was not -Q. You cant tell us what she said.
MR. MESEREAU: Objection; hearsay.
Q. BY MR. SNEDDON: She said something in response to that, correct?
A. Yes.
Q. And then did you say anything back to her?
A. I told her we cannot keep the kids in -- on our books as students at the school for any
longer than we already had. And that if it was going to be an extended stay, they were
going to be gone for a while, they needed to be checked out. And when they were
available to come back to school, we would check them back in.
Q. All right. And did you give Mrs. Ventura some directions as to what was necessary to
check the children out of school?
A. Right.
Q. Tell us what you told her.
A. I asked her to come in and check the students out. She said that wasnt -MR. MESEREAU: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. SNEDDON: Okay. So you asked her to personally come in and do it?
A. Yes.
Q. Okay. And she said something back to you?
A. Right.
Q. And as a result of that, did you give her further direction as to what procedurally would
have to be followed to get those children out of school?
A. Right.
Q. Tell us what you told her.
A. I ind icated that if she was unable to come, that we needed someone with a note from
her, and her drivers license, and that person needed to be able to have an I.D. also. And
that we needed the textbooks returned, and to do it quickly, to do it soon.
Q. All right. At that point in time, did you become aware of the fact that somebody came
to check the children out of school?
A. Yes. She said that somebody would come in a day or two.
Q. And did you write a note to somebody to expect this to happen?
A. I wrote a note to my secretary that a person would be coming with her I.D. and his I.D.
and pay for the books, and to direct that person to the book room to pay for any

textbooks that werent there.

Q. Now, did you at some point actually meet somebody who came to check the boys out
of school?
A. I did.
Q. And do you remember the name of that person?
A. Yes. It was Mr. Amen. Vincent Amen.
Q. All right. And did you personally deal with him on the check-out procedure?
A. The secretary gave him the paperwork and made copies of his I.D. and Miss Venturas
drivers license, and she kept the note that was sent along with him. And, you know, I
spoke to him briefly, but I d idnt handle the nuts and bolts of it. The secretary did.
Q. And were some books paid for on that particular occasion?
A. Books were paid for, yes.
Q. By whom?
A. By Vincent Amen.
Q. All right. Im going to show you some exhibits. Counsel, it will be 271 and 272. I want
you to take a look at the exhibit thats been marked as 271-A and ask if you recognize
that.
A. Yes.
Q. That exhibit is actually in evidence. And how do you recognize it?
A. Its my note to the secretary.
Q. Thats in your handwriting, correct?
A. Yes.
Q. Whats the date of that note?
A. February 5th. Im sorry, I dont have my glasses on. March 5th.
Q. Im sorry, I couldnt hear you.
A. March 5th.
Q. All right. Was that note prepared at the time of -- that date?
A. I think it -- I prepared it the day that I had the phone call.
Q. Okay.
A. I had the conversation.
Q. All right. Turn the next page to page B, if you would. Do you recognize page B?
A. Yes.
Q. And with regard to page B, what is that?
A. Thats a school form that we use when students check out.
Q. And for what student is that?
A. This is for Gavin Arvizo.
Q. And does it indicate the destination?
A. It does.
Q. As what?
A. Phoenix, Arizona.
Q. All right. Lets go to C, if we can. And this is 271-C. What is that document?
A. It is a note from Miss Arvizo.
Q. Thats a document that you indicated she needed as part of the process if she was
going to have somebody else check them out?
A. Yes.
Q. Okay. And lastly, 271-D, whats that? 6913
A. These are copies of Miss Arvizos -- or Miss Venturas I.D., drivers license, and Mr.
Amens drivers license.

Q. Okay. Now, lets move to 272, if we can. All we need you to do is just flip this over.
Thank you. And 272-A, which is in evidence, what is that?
A. Its the check-out sheet for Star Arvizo.
Q. And is the destination indicated on that also?
A. Yes. Phoenix, Arizona.
Q. And the next page, which would be 272-B?
A. Its a note from Miss Ventura to check out Star.
Q. Okay. And on the last page, on the back side of that is what?
A. Thats the school form where the teachers sign the students check-out form and put a
grade there.
Q. And does that indicate that books were paid for on that form?
A. It does.
Q. All right. Ill take that. Thank you. During the time that -- I want to make it more
particular, but -- well, during the year -- the school year 2002 and 2003 - okay? - at John
Burroughs, was there an instructor there by the name of Mr. Geraldt?
A. Yes. Mr. Geraldt, yes.
Q. Geraldt. And how long have you known Mr. Geraldt?
A. Five years.
Q. And had you worked at the same school with him -A. Yes.
Q. -- during that five-year period?
A. Right.
Q. And what was Mr. Geraldts position with the school?
A. He was a classroom teacher, and he also handled the detention room. And in the
mornings, he didnt have a home room. He processed students that were late to school.
Q. Did the manner in which Mr. Geraldt interacted with some of the students and parents
at the school cause problems?
A. Yes.
Q. In what respect?
A. He had a kind of paramilitary demeanor about him. He was kind of a drill instructor, in
your face, you know. Kind of shouty, loud, and, you know, You need to do this and -just aggressive.
Q. And did that cause problems with some of the students?
A. It did.
Q. Did it cause problems with some of the parents?
A. It did.
Q. And did the school have to take actions towards him to try to calm down his behavior?
A. Yes.
Q. Now, at some point -- I didnt ask you this, but I should have. The documents that -71 (sic) and 72 (sic) that show that Gavin and Star were checked out of the school, those
were comp leted on the day that the children were checked out?
A. Yes.
Q. Thats correct?
A. Yes.
Q. That would have been in March of 2003?
A. Right.
Q. Now, did Gavin and Star come back to John Burroughs later?
A. Yes.

Q. Do you remember approximately when it was?

A. About three weeks later.
Q. Now, do you recall an incident in which a person by the name of Major Jay Jackson
came to contact you?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes.
Q. BY MR. SNEDDON: And do you know who Major Jay Jackson is?
A. I do.
Q. Where did you first meet Mr. Jay Jackson, Major Jay Jackson?
A. I met him in my office when I was having a conference with Gavins mother, and he
attended with her.
Q. Now, on the particular day when Major Jackson approached you, do you remember
approximately when that was in relationship to the kids coming back to school, Gavin and
Star?
A. Yes.
Q. All right. Tell the jury -A. It was -- it was shortly thereafter. Within a few days or a week.
Q. And where were you when Major Jackson approached you?
A. I was in front of the school.
Q. Im sorry?
A. In front of John Burroughs.
Q. And could you describe his demeanor at the time that he approached you?
A. All right. He was agitated. He said that there was a -MR. MESEREAU: Objection; hearsay.
MR. SNEDDON: Its offered to explain the conduct of this witness in response to the
informat ion that was provided.
THE COURT: Ill sustain the hearsay objection.
Q. BY MR. SNEDDON: All right. I dont know if we got an answer to the first part, so Ill
just start over again. And dont tell us what Major Jackson told you, okay?
A. Okay.
Q. Would you describe his demeanor when he first approached you?
A. He was agitated.
Q. All right. And without telling us what he said, did he say something to you -A. Yes.
Q. -- that caused you to do something?
A. Yes.
Q. All right. As a result of the information that you received from Major Jackson, what did
you do?
A. I went down to the street and approached a car that had a gentleman in it that was
videotaping students.
Q. Did you actually see the camera?
A. Yes.
Q. And where was the camera at the first point that you saw it?
A. In the drivers hand.
Q. And in what direct ion was it pointed?
A. Out the windshield.
Q. Now, lets pause for just a second, if we can, and go back. At what point in the school

day was it that Major Jackson approached you?

A. It was dismissal t ime.
Q. Can you describe to the jury what its like at John Burroughs at dismissal time in terms
of the traffic flow?
A. John Burroughs is situated in a residential area between two major streets. And at
dismissal time, the only way out of the school is through the front or the north and south
end of the school. You cant exit the back of the school because theres houses back there.
So the vast majority of these 2400 kids leave out the front or the side, but they end up in
front of school. And theres school buses out there, and there are parents, a lot of parents
there to pick up their students. So you have a traffic jam for about 15 or 20 minutes
where the traffic flow is very, very slow. Only about five or six cars can go through the
light at a time, because the students crossing the street hold up traffic. So it would take
you -- it will take you 15 minutes to go from one end of the block to the other at dismissal
time.
Q. Now, at the time that you approached this car, do you remember what kind of a car it
was?
A. Generally, yes.
Q. Tell us.
A. It was a Nissan sports car.
Q. And where was this car in terms of the relationship with this traffic flow at the point?
A. It was in grid lock. It was in front of school in the grid lock.
Q. Were you actually able to go up to the driver of the car?
A. Yes. Yeah, thats -Q. Did you have a conversation with the driver of the car?
A. I walked up to the driver and I told h im that he couldnt videotape students. And he -- I
said, I need you to stop videotaping students. And he said, Okay, and set the camera
down on the seat or the floor of the car.
Q. Did you write down the license number of the car?
A. I did not.
Q. Was there any school security available to you on this particular day?
A. On that particular day, the school police officer was not present. And I gave him a note
the next day describing the car and telling him the situation.
MR. SNEDDON: No further questions.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. My name is Thomas Mesereau. I speak for Mr. Jackson. When did you first meet the
Arvizo family?
A. Fall of 2002.
Q. Okay. And was that when Gavin and Star entered your school?
A. Yes.
Q. And Gavin and Star entered your school approximately November of 2002, right?
A. Yes.
Q. What grades were they in?
A. Seventh.
Q. Okay. They both were in seventh?
A. Yes.
Q. Okay.

A. I think Gavin had lost a year. Hes older, but he had lost a year from his health
problems.
Q. Okay. And had you known them before they entered your school in November of 2002?
A. No.
Q. Had you known anyone else in the family before they entered your school in 2002?
A. No.
Q. Gavin was consistently a discip linary problem, correct?
A. Correct.
Q. His behavior was disruptive and challenging, in your own words, correct?
A. Correct.
Q. Gavin would routinely act up in class, right?
A. Correct.
Q. He would display poor cooperation with students and teachers, right?
A. Right.
Q. He would create situations in which he had an aud ience to view his poor behavior,
right?
A. Yes.
Q. His grades were low throughout his education, right?
A. They were at John Burroughs.
Q. Yes. Pardon me.
A. Yes.
Q. His grades at John Burroughs were consistently low, correct?
A. Yes. Yes.
Q. And you felt he didnt apply himself in a constructive manner in school, right?
A. Yes.
Q. You had a number of parent meetings with Gavin, Janet and Jay in which Gavins poor
behavior was discussed at length, correct?
A. Correct.
Q. And you felt that Gavin was the kind of young man who could handle himself with
adults, right?
A. He thought he was the kind of person.
Q. You felt he could handle himself with adults also, didnt you?
A. He was -- he was pretty glib, yes.
Q. You did actually write a report -- excuse me, not write a report. You gave an
interview where you actually made that statement, did you not, about Gavin; that he can
handle himself with adults?
A. Yes.
Q. Okay. You looked at his school records at one point, correct?
A. You know, I dont recall that.
Q. Do you recall conclud ing that Gavins grades at your school were very similar to his
grades at other schools he had attended?
MR. SNEDDON: Your Honor, Im going to object. It calls for hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you yourself ever look at Gavins grades from other schools
and compare them to the grades he got at your school?
A. You know, I dont recall that.
Q. Do you remember being interviewed by a Sergeant Steve Robel of the Santa Barbara
Sheriffs Office?

A. Yes.
Q. Do you remember telling Sheriff Robel that you saw a consistent pattern of poor grades
from school to school with Gavin?
MR. SNEDDON: Your Honor, Im going to object. Its hearsay. It calls for reliance on
hearsay records.
THE COURT: Overruled.
THE WITNESS: You know, I honestly dont recall it.
Q. BY MR. MESEREAU: Might it refresh your recollection to look at a police report about
your interview?
A. Okay.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. MESEREAU: Mr. Davy, have you had a chance to look at that report? Does it
refresh your recollection about what you told Sheriff Robel about that issue?
A. Yes.
Q. And what did you tell him?
A. That he had consistently underperformed in his academic pursuits.
Q. Do you recall that you were asked if you had seen any change in Gavins demeanor,
attitude or academic performance from the period prior to 6924 February 2003 to the time
Gavin returned to school on March 17th, 2003?
A. Yes.
Q. Do you recall your saying you had seen no definitive change in Gavins demeanor,
attitude or academic performance during that period?
A. Yes.
Q. Now, Gavin had a truancy counselor, correct?
A. Well, are you talking about Mr. Coffman?
Q. Yes.
A. Well, Mr. Coffman was an it inerant. He came to school two or three days a week and
dealt with -- he would get computer readouts of people who had long-term absences.
Q. Okay. Is the appropriate label for him truancy counselor?
A. No, its pupil service and attendance counselor.
Q. Okay. And you said he would come three days a week?
A. Yeah. Oftentimes schools have to buy that time. So sometimes the school would buy
two days and another school would buy three days, so he would split the assignment.
Q. Okay. And did you discuss issues involving Gavin with Mr. Coffman?
A. I dont know about issues. I asked him to go to Gavins house. 6925
Q. Okay. And the purpose was to talk to the family about why Gavin wasnt going to
school?
A. Right. At that point in time.
Q. Okay. Now, you indicated to the prosecutor that at some point someone named Vinnie
Amen came to the school to check Gavin and Star out; is that correct?
A. Correct.
Q. And Mr. Amen provided the school with a copy of his identification, correct?
A. Correct.
Q. And he gave the school a copy of his New Jersey drivers license for the school files,
right?
A. Right.
Q. And to your knowledge, did he sign anyth ing when he was checking these two students

out; do you know?

A. I dont know.
Q. But your understanding was that Janet had given him permission to check out Gavin
and Star, right?
A. Right.
MR. SNEDDON: I object, Your Honor. It calls for a conclusion.
THE COURT: Sustained.
Q. BY MR. MESEREAU: In your response to the prosecutors questions, correct me if Im
wrong, did you say something to the effect that the school had 6926 permission from
Janet to allow Mr. Amen to check out these two students?
MR. SNEDDON: Your Honor, Im going to object. Calls for hearsay.
MR. MESEREAU: His state of mind, Your Honor. I believe he testified to it on direct.
THE COURT: The objection is sustained. I believe you objected to the same testimony.
MR. MESEREAU: Okay.
Q. At some point, was it your understanding that Mr. Amen did, in fact, check out the two
students?
A. Yes.
Q. Okay. And what would the normal procedure be for allowing someone not in the family
to check out a student?
A. A permission slip written by the parent.
Q. Okay. And did you follow the normal procedure when Mr. Amen was checking out Gavin
and Star?
A. Yes.
Q. Do you know how many meetings you had with Ms. Arvizo about Gavins poor
behavior?
A. Not an exact number, no.
Q. And when Gavin was checked out of the school, how long had he been attending that
school, if you remember?
A. Well, just months, since November. So November to late February.
Q. And would it be accurate to say that even though he was only there a few months, it
became read ily apparent that he was a disciplinary problem, right?
A. Yes.
Q. The disciplinary problems began -- excuse me. The discip linary problems with Gavin
began in November of 2002, right?
A. I dont recollect the first time.
Q. But certainly around that time, correct?
A. Probably.
Q. Now, what typically is the procedure you follow at this school if somebody has a
discip linary problem?
MR. SNEDDON: Object as immaterial, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you recall Gavin being late to class?
A. Not specifically, but Im guessing that he was.
MR. SNEDDON: Object. Move to strike. Speculation. That part beyond the -THE COURT: Its stricken.
Q. BY MR. MESEREAU: Would it refresh your recollect ion to look at some school records in
that regard?
A. Sure.

MR. MESEREAU: May I approach, Your Honor?

THE COURT: Yes.
Q. BY MR. MESEREAU: Mr. Davy, have you had a chance to look at those records?
A. Yes.
Q. Do they refresh your recollection about disciplinary problems you had at your school
with Gavin Arvizo?
A. Yes.
MR. SNEDDON: Excuse me, Your Honor. Im going to object to the question. That wasnt
the question that he was refreshing. I wont talk any more, but I dont believe thats the
question.
THE COURT: Thats correct. Its not.
MR. MESEREAU: Let me rephrase my question, Your Honor. Ill withdraw that one.
Q. Mr. Davy, does the document you just looked at refresh your recollection about Gavin
being late to class?
A. Yes.
Q. And was that a problem with him while he attended your school?
A. On occasion, yes.
Q. Do you recall a problem with Gavin banging on doors at your school?
A. Yes.
Q. Do you recall Gavin being consistently warned about his bad behavior?
A. Yes.
Q. Do you recall problems with Gavin arguing with teachers?
A. Yes.
Q. Do you recall problems with Gavin arguing with students?
A. No, I dont.
Q. Would it refresh your recollection just to look at those records again?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. MESEREAU: Have you had a chance to look at that record?
A. Yes.
MR. SNEDDON: Your Honor, before counsel asks his next question, I want to interpose an
objection to lack of foundation as to whether hes aware of those records. Has he ever
seen them?
MR. MESEREAU: Just refreshing recollection, Your Honor.
THE COURT: All right. The objection as to lack of foundation is overruled.
Q. BY MR. MESEREAU: Do you recall, Mr. Davy, problems with Gavin arguing with another
student?
A. From those records, yes.
Q. Do you recall a problem with Gavin having a negative impact on his class?
A. Yes.
Q. Do you recall problems with him ju mping around, quote, like retarded people?
A. Yes.
Q. Do you recall problems with Gavin mumb ling in class?
A. Yes.
Q. Do you recall your having to detain Gavin for discip linary problems?
A. Yes.
Q. And what is the detention procedure that you would have used with him?

A. Well, basically you have to stay after school for an hour.

Q. Okay. And do you recall a problem with him that required lunch detention?
A. Well, a number of people can assign detention, so I dont recall that. But Im guessing
that he served lunch detention.
Q. Would it refresh your recollection if I just show you the records?
A. If its there, it happened.
MR. MESEREAU: May I approach, Your Honor?
THE COURT: I think the problem that we have is that I overruled an objection by Mr.
Sneddon about foundation, but the -- when counsel asks you if it refreshes your
recollection, that doesnt mean that you then testify about whats in the record. It means
do you independently -- now do you independently remember this? For example, Do you
know if he was late for school? And you say, I dont remember. Then he says, Well,
will this refresh your recollection? And you look at it. And thats asking you, Do you -Now do you rememb er seeing him be late for school, not What does the record say?
THE WITNESS: Okay, I misunderstood that.
THE COURT: Okay. So -THE WITNESS: The fact -THE COURT: You dont need to come back to it. But the point were at is, you want to ask
him if he can refresh his recollection about -- what was it?
MR. MESEREAU: About Gavin having been detained at lunch.
THE COURT: Okay. Would looking at these records help you refresh your recollection
about being detained at lunch?
THE WITNESS: No, simply because oftentimes those are reflections of deans entries or
another counselors entries.
MR. SNEDDON: Judge, could I -- Excuse me, Counsel.
THE COURT: Yeah.
MR. SNEDDON: I dont want to be burdensome, 6932 but I think that I would move to
strike -BAILIFF CORTEZ: Microphone.
MR. SNEDDON: I dont want to be burdensome, but I move to strike all of the questions
that hes used to refresh recollection until the proper foundation can be established that
this witness actually remembered that, as opposed to some record.
MR. MESEREAU: I believe, Your Honor, the witness has said he remembers it and spoke to
a sheriff in an interview and made those conclusions.
THE COURT: Well, the problem thats come up is whether or not he was refreshing his
memory to things he actually can remember, or if he was just telling you what you
showed him in the record. So what Ill do is go back and sustain the foundation objection
that he made before you asked him these series of questions relating to Gavins behavior
and strike those answers. And then you can proceed again to see -MR. MESEREAU: Okay.
THE COURT: -- what he remembers and what was just in the record.
Q. BY MR. MESEREAU: Mr. Davy, I want to go back over some questions I asked you
earlier. Now, you were interviewed by Sheriff Steve Robel of the Santa Barbara Sheriffs
Office approximately December 4th, 2003. Do you remember that?
A. Yes.
Q. And that was at your school in Ho llywood, right?
A. In Hancock Park, yeah.
Q. And for the purpose of that interview, you obtained Gavins cumulat ive school files and

his discip linary file, correct?

A. I did. But one of the things that you need to understand is that there was another office
that also handled discipline, other than the counseling office. And so some of the records
that I think youre referring to came out of that office.
Q. Okay. But you did tell Sergeant Robel that you had obtained Gavins cumulative school
files and his discip line file from Bonnie Murrow, right?
A. She took my place when I transferred, so she wasnt there at that time.
Q. Do you recall telling Sergeant Robel that you had obtained Gavins cumulative school
files and his discip line file from Bonnie Murrow?
A. I believe that was after I left the school.
Q. Okay. But you did obtain those files, correct?
A. I went to obtain them. I think they were under subpoena.
Q. Do you recall meeting with Sergeant Steve Robel in a principals office to review and
discuss the files contents?
A. Yes.
Q. And you did, in fact, discuss those contents with Sergeant Robel, right?
A. Yes.
Q. You gave Sergeant Robel a brief history of the schools Gavin had recent ly attended,
true?
A. True.
Q. They were LeConte Middle School for sixth grade, right?
MR. SNEDDON: Your Honor, Im going to object as hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Had you counseled Gavin in your position at Burroughs?
A. Yes.
Q. And what had you counseled Gavin about?
A. Disruptive behavior in the classroom.
Q. Why did you counsel Gavin about his disruptive behavior in the classroom?
MR. SNEDDON: Your Honor, this has been asked and answered.
MR. MESEREAU: If its in the record, Your Honor, I dont have a problem. But I wasnt sure
if -- youd asked me to go over this again.
MR. SNEDDON: Not this. Sorry, I apologize.
THE COURT: The objection is overruled.
Q. BY MR. MESEREAU: Why did you counsel Gavin?
A. I was receiving referrals from his classroom 6935 teachers.
Q. Were they negative referrals?
A. Yes.
Q. Were they consistently negative referrals?
A. Yes.
Q. Was it normal procedure when you received consistently negative referrals about a
student that you try to counsel that student?
A. Yes.
Q. Did you have many counseling sessions with Gavin about his poor behavior?
A. Yes.
Q. And do you know approximately how many you had?
A. Probably a half a dozen.
Q. Did you counsel him individually or with others present, if you know?
A. Individually.

Q. Is that the normal procedure for that type of counseling?

A. Yes. Oftentimes with a parent, too, present.
Q. Did you also counsel Gavin with any parent present?
A. Yes.
Q. And what parent was typically present for those meetings?
A. Miss Ventura. And sometimes Miss Ventura 6936 and Mr. Jackson.
Q. Okay. Did you tell Ms. Ventura that Gavins behavior was disruptive and challenging?
A. Yes.
Q. Did you tell Ms. Ventura that Gavin would routinely act up in class?
A. Yes.
Q. Did you tell Ms. Ventura that he displayed poor cooperation with students and
teachers?
A. Yes.
Q. Did you tell Ms. Ventura that Gavin would create situations in which he had an
audience to view his poor behavior?
A. Yes.
Q. And did you tell Ms. Ventura that his grades were consistently low throughout his
schooling?
A. I think she knew that.
Q. Okay. Do you recall meeting with Jay Jackson to talk about Gavins poor behavior?
A. With -- with Miss Ventura present.
Q. Yes. But you did meet with Miss Ventura and Jay Jackson to talk about Gavins
consistently disruptive behavior, right?
A. Yes. Yes.
Q. And Gavin was present at those meetings, correct?
A. Correct.
Q. And you told Ms. Ventura that you had seen no definit ive change in Gavins demeanor
or attitude or academic performance from the period prior to February 2003 to the time
following his return to school on March 17th, 2003, right?
A. Right.
Q. Now, you indicated that at some point, Mr. Coffman went to Gavins home; is that
correct?
A. Thats correct.
Q. Do you know where that was?
A. Not offhand. I mean, we use school records for that. I dont have access to that right
now.
Q. To your knowledge, did Mr. Coffman find anyone home?
A. No.
Q. Did you meet with Mr. Coffman to talk about that issue?
A. Yes.
Q. Was it Mr. Coffmans responsibility to try and locate Ms. Arvizo?
A. Yes.
Q. And at some point, to your knowledge, he did locate her, correct?
A. Well, what they typically do is talk to neighbors and leave business cards with people.
And at some point she contacted me.
Q. She contacted you and gave her permission to have Mr. Amen check out her sons,
correct?
A. Correct.

MR. SNEDDON: Object. Calls for a conclusion. Its the same question that was asked
before.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you recall a problem with Gavin Arvizo singing in the
classroom?
A. No.
Q. Would it refresh your recollection to look at these school records?
A. Like I said, those records may have been written by someone else.
Q. Okay. Well, the question would be if you remember.
A. No, I do not.
Q. Is it possible they wou ld refresh your recollection about that, since you counseled him
on those issues?
A. I didnt -- I wasnt the only person that counseled him.
Q. Well, let me ask you this: You dont remember an issue of him singing in class, right?
A. Right.
Q. If you look at some records, might they refresh your recollection about that problem?
A. Well, it will refresh my memory that it happened, but that I may not have hand led it. I
dont know who wrote those records.
Q. Im only asking you about your memory about whether it happened, okay?
A. I dont have a recollect ion.
Q. Might it refresh your recollection to look at the records?
MR. SNEDDON: Im going to object to the question. He says -- its asked and answered.
THE COURT: All right. The witness is just trying to follow my instructions. Go ahead and
show him the record.
MR. MESEREAU: Thank you, Your Honor.
Q. Have you had a chance to look at that school record?
A. I have.
Q. Does it refresh your recollection about any problem in that regard?
A. No.
Q. Okay. Do you recall problems with Gavin disrupting test-taking?
A. No.
Q. Is that something you recall counseling him about?
A. My general recollections of counseling him were disruptive behavior. Specifically
whether it was testing or singing, whatever, it doesnt -- I cant speak to that.
Q. Okay. Did you talk to various teachers at the school about Gavins consistently
disruptive behavior?
A. Yes.
Q. How many teachers did you talk to about his disruptive behavior, if you remember?
A. Well, Im sure I spoke to the ones that were writing referrals.
Q. Were a lot of his teachers writing referrals?
A. The students at that grade level were in a group of teachers that had the same
students all day. So generally if one teacher had a problem in that group, they all had a
problem.
Q. Now, the prosecutor asked you questions about a teacher named Geraldt; is that
correct?
A. Geraldt.
Q. And I believe you said words to the effect you thought he was somewhat -- acted in -somewhat in a paramilitary kind of way?

A. Yes.
Q. What did you mean by that?
A. Well, he had a kind of drill instructor demeanor, I mean, when he was dealing with
students that were late to class or misbehaving.
Q. But Gavin had many other teachers besides Mr. Geraldt complaining about him, didnt
he?
A. In fact, I dont think he had Mr. Geraldt as a classroom teacher. I think he probably had
him for his ROTC, his extracurricular -Q. So the disruptive behavior that youve been 6941 talking about was disruptive behavior
in the classroom, correct?
A. Correct.
Q. And those were classroom teachers that were referring these problems to you, right?
A. Correct.
Q. Now, you said Mr. Geraldt taught a -- was it an after-school type of program?
A. Well, he was an eighth grade science teacher, but he also had an ROTC class that
sometimes met after school and on Saturdays. And he also ran the detention room after
school.
Q. And did you think he was too strict in the ROTC program?
A. I dont know if he was too strict in his ROTC program.
Q. Okay. But you mentioned his paramilitary behavior. Was that in the ROTC program?
A. No, that was in his dealing with students on the yard or in the morning when they were
coming in late.
Q. Okay. Okay. Do you recall him interacting with Gavin at all?
A. I do not recall that.
Q. If he had, would it be because Gavin was late?
MR. SNEDDON: Object; calls for speculation.
THE COURT: Sustained. 6942
Q. BY MR. MESEREAU: Was one of Mr. Geraldts functions to deal with late students?
A. Yes.
Q. And how would that work? I mean, if someone was late, how would they get to Mr.
Geraldt?
A. Well, he did not have a home room which met first thing in the morning, so Mr. Geraldt
was assigned to process students at the front door that were late coming in.
Q. So he would simply wait at the front door?
A. Yeah. Everybody had to pass through the front door. People with passes or notes from
home would proceed on. People that didnt would be processed by him.
Q. And the procedure -- excuse me. The procedure he followed if he met someone at the
front door who was late was what? What would he do?
A. Well, he would write them a detention slip.
Q. Okay. And would that detention slip be handed to the student?
A. Yes.
Q. And was there a procedure dictating what the student should do with that detention
slip?
A. Yes.
Q. And what were they supposed to do with the detention slip?
A. One, they were supposed to get it signed by their parent and do their detention. It was
an NCR paper, so we kept the copy.
Q. Would the detention typically be done that day?

A. No.
Q. When would it typically be done?
A. The next day after the parents were notified.
Q. And was the proof that parents were notified their signature on the slip?
A. Yes.
Q. Would someone actually talk to the parent directly?
A. Somebody from school?
Q. Yes.
A. Not unless they didnt do the detention.
Q. Okay. Now, you do recall problems with Gavin being late, correct?
A. My recollection is more clear on the discipline inside the classroom, the disruption in the
classroom.
Q. Okay. Now, when d id you -- excuse me. Have you spoken to any prosecutor about your
testimony today?
A. Yes.
Q. And when was that?
A. Last night.
Q. Okay. Who did you speak to?
A. Mr. Sneddon.
Q. Okay. Did he call you?
A. Yes.
Q. And you spoke to him about what you were going to be asked today?
A. We -- he just looked at my grand jury testimony and had questions about that.
Q. Okay. And did he ask you questions about what you would be saying today?
A. No, he was just clearing up what I had said, making him understand what I said during
the grand jury testimony.
Q. Have you reviewed your grand jury transcript?
A. I have.
Q. And how did you get it?
A. I got it online.
Q. Okay. And so you and Mr. Sneddon discussed what you said before the grand jury last
night, right?
A. Yes.
Q. Okay. How long a discussion was that?
A. Twenty minutes.
Q. Okay. Did you and Mr. Sneddon discuss Gavins poor record for discipline in that call?
A. Briefly.
Q. Excuse me?
A. Briefly.
Q. Okay. Did you and Mr. Sneddon discuss your interview with Sheriff Robel?
A. No.
Q. You did discuss Mr. Geraldt, correct?
A. Correct.
Q. Did Mr. Sneddon bring up the name Geraldt in that conversation?
A. Yes.
Q. Did he tell you he would ask you questions about Mr. Geraldt today?
A. I dont think so. He just wanted me to tell him about it.
Q. In that conversation, did you inform Mr. Sneddon that Mr. Geraldt had not actually

been a classroom teacher for Gavin?

A. I dont think so.
Q. Okay. Did you talk about Mr. Geraldts responsibilit ies at the door of the school?
A. Yes.
Q. Did you talk about his responsibilities in the ROTC program?
A. Briefly.
Q. Okay.
THE COURT: Counsel?
MR. MESEREAU: Yes, Your Honor.
THE COURT: Well take our break.
MR. MESEREAU: Yes. (Recess taken.)
MR. MESEREAU: Thank you, Your Honor.
Q. Mr. Davy, you met the gentleman who ident ified himself as Vinn ie Amen, didnt you?
A. Yes.
Q. And you expressed surprise at how young he seemed to be, right?
A. I believe so.
Q. And you described him as business-like, real cooperative and wearing dressy casual
clothes, right?
A. Right.
MR. MESEREAU: I have no further questions, Your Honor.
THE COURT: Counsel?
MR. SNEDDON: No questions.
THE COURT: All right. Thank you. You may step down.

JANET WILLIAMS EXAMIN ATION

DIRECT EXAMINATION BY MR. SNEDDON:
Q. Ms. Williams, youre now retired; is that correct?
A. I am.
Q. And before your retirement where did you work?
A. I worked for Santa Barbara County Sheriff.
Q. And how long had you worked for them?
A. A little over 29 years.
Q. I think the bailiffs about to tell you to scoot into that microphone. In case we missed
it, how many years?
A. 29 years.
Q. And at the time of your retirement, what was your assignment?
A. I was working investigat ions at Coastal Station, which is located in Carpinteria.
Q. And how long had you been at that particular assignment?
A. Ten years.
Q. And prior to that, where were you assigned?
A. I was assigned to the main station in Goleta.
Q. In what capacity was that?
A. Jail, patrol, investigat ions, variety of assignments.
Q. All right. Now, prior to the time that you retired in November, the 18th of 2003, were
you assigned to participate in the execution of a search warrant at Neverland Valley

Ranch?
A. Yes.
Q. And during the course of your responsibilities on that particular day, did you -- were
you responsible for seizing certain items of evidence?
A. Yes.
Q. And in particular, were you at one point in time assigned to search the downstairs area
of Mr. Jacksons bedroom suite?
A. Yes.
Q. And in that area, did you find some items that you seized?
A. Yes.
Q. And could you just generally describe the area that you took these items from?
A. The area appeared to be similar to a sitting room. It had a piano, large screen
televisions and chairs, and some books. Fireplace. That kind of 6949 area.
Q. All right. Im going to show you a photograph. Counsel, its 90 and its in evidence.
MR. SANGER: W hat number?
MR. SNEDDON: Nine -- 9-0.
MR. SANGER: Thats fine. Thank you.
Q. BY MR. SNEDDON: Now, with regard to the exhibit that I placed in front of you, which
is a photograph, which is Peoples 90 which is in evidence, do you recognize the area
thats depicted in that photograph?
A. Yes, I do.
Q. When and where was the first time that you saw -- or were in that particular location?
A. It would have been the day of the search.
Q. And do you see depicted in the photograph, Peoples 90, the area from which you
obtained some items that you seized and then had booked into evidence?
A. Yes.
Q. And I gave you a red pen. Would you put an arrow to the area where you obtained the
items from?
A. An arrow on the photograph?
Q. Yes. Yes, mark on the photograph. Now, in that photograph -- let me get the
photograph for just a second. I was looking for the laser.
MR. ZONEN: Oh, heres the laser. Gordon? Your Honor, could we have the input, I think
four?
MR. AUCHINCLOSS: Input 4.
Q. BY MR. SNEDDON: All right. Ms. W illiams, with regard to the photograph that we have
on the board, which is Peoples 90 in evidence, can you point out to the ladies and
gentlemen of the jury the arrow that you placed on that exhibit. Use the laser, if you
would. I think you might be pointing it the wrong way.
A. Could be. Oh. Found the right button, sorry.
Q. All right. So its the one that comes down on the right-hand side of the photograph.
And below that, directly below that are a number of boxes and books; is that correct?
A. Yes.
Q. Is that the area from which you seized certain items?
A. Yes.
Q. Okay. In this particular room -- well, thats okay. Ill do it another way. I think we can
have the lights for right now, Your Honor. (Off-the-record discussion held at counsel
table.)
MR. SANGER: All right. Go ahead.

Q. BY MR. SNEDDON: All right. Im handing you a bag, a plastic bag that has the number
590 on it, 590 marked for ident ification purposes. And inside the bag are four books that
have been marked 59-A (sic), B, C and D. So Im going to ask you some questions about
these, okay?
A. Yes.
Q. Now, with regard to 590-A, do you recognize that book?
A. Yes.
Q. And where was the book the first time that you saw it?
A. The book was inside one of the boxes that was -- that I depicted by the arrow.
Q. Now, there are a number of boxes there. Do you recall which one of the boxes that 59A (sic) came out of?
A. I do not.
Q. But it was from one of those boxes?
A. Yes.
Q. Okay. Now, is that book in the same condition as when you seized it on that particular
day?
A. It appears to be.
Q. All right. Now, lets go to 59-B -- 590-B Okay. Do you recognize that exhibit? 6952
A. Yes.
Q. And when and where was that the first time you saw it?
A. Inside one of the boxes from the same area.
Q. And do you remember what specific box it was in?
A. I do not.
Q. Do you recall whether it was with the Exhibit 59 -- 590-A?
A. I do not.
Q. All right. Lets go to the next one then, 590-C. Do you recognize that?
A. Yes.
Q. And where was that book the first time you saw it?
A. In one of the boxes from the same area.
Q. Is that the same condition as when you first saw it?
A. It appears to be.
Q. All right. And then lets go to 590-D, like in David. All right. Do you recognize that
book?
A. Yes.
Q. Is that one of the books you seized?
A. Yes.
Q. From the same area?
A. Same area, yes.
Q. And do you recall whether it was with the other -- any of the other books, A, B or C?
6953
A. I dont remember.
Q. With regard to that book, does it appear to be in the same condition as when you first
saw it?
A. Yes.
MR. SNEDDON: All right. Your Honor, I move that 590-A through D be admitted into
evid ence.
MR. SANGER: Submit it.

THE COURT: Theyre admitted.

MR. SNEDDON: Im going to display these, Your Honor.Q. 590-A, now, this particular book
is titled, Bob and Rob. After you took it out of one of those boxes that are depicted in
the photograph, Peoples 90, what did you do with this particular book?
A. I took it to the area where Detective Pad illa was preparing the documents showing the
items that were being seized.
Q. He was designated as what we call the scribe?
A. Yes.
Q. What you call the scribe?
A. Yes.
Q. Okay. All right. Lets put up 590-B. With regard to this particular exhibit, Before the
Hand of Man, what did you do with that after you seized it?
A. The same procedure, I took it over to Detective Padilla for scrib ing in.
Q. Okay. 590-C. This is a book called Room to Play. And you obtained that from the
same areas, correct?
A. Yes.
Q. And what did you do with it after you obtained it?
A. I took it to Detective Pad illa.
Q. All right. And lastly, 590-D. That was also found in those boxes?
A. Yes.
Q. And you also took that to the detective?
A. Yes, I did.
MR. SNEDDON: All right. Thank you. Lights are fine. (Off-the-record discussion held at
counsel table.)
MR. SNEDDON: Your Honor, Ive handed counsel for his examination a clear p lastic bag
which has inside of it a white binder. This exhib it has been marked as 591 for
identification purposes.
Q. Im going to ask you to look at 591. Now, yesterday, I asked you to take a look at that
exhibit, correct?
A. Yes.
Q. And you did take a look at that exhibit, correct?
A. Yes.
Q. And inside of the Exhibit 591, which has the white b inder, there are two items, two
magazines, correct?
A. Yes.
Q. Are those magazines that you seized on November 18th?
A. Yes.
Q. From where?
A. From the same area as the books that weve previously discussed.
Q. The books in 590?
A. Yes.
Q. And with regard to the two exhibits that -- the two magazines that are inside the
Exhibit 591, are they in the same condit ion now as when you first viewed them?
A. No.
Q. In what respect are they d ifferent?
A. Theyve been disassembled. They were intact at the time that I seized them.
Q. But they are the same two magaz ines that you took?
A. Yes.

MR. SNEDDON: All right. Move that 591 be admitted into evid ence, Your Honor.
MR. SANGER: I will submit it, Your Honor.
THE COURT: Its admitted. (Off-the-record discussion held at counsel table.)
MR. SNEDDON: Your Honor, I have a clear plastic bag which has on the outside of it
Exhibit No. 834. Thats on the outside of the bag. And from inside the bag there are four
magazines that have been marked consecutively as 592, 593, 594 and 595. And Ive
shown them to counsel for his examination. And Im going to approach the witness.
THE COURT: Yes.
Q. BY MR. SNEDDON: First of all, theres the bag thats marked as 834, and the four
magazines, 592 through 595. Do you recognize those?
A. Yes.
Q. And those were also exhibits that I had you look at yesterday; is that correct?
A. Yes.
Q. And youve had a chance to go through them; is that correct?
A. Yes.
Q. And with regard -- lets take them one at a time. 592, where was it the first time that
you saw it?
A. It was inside one of the boxes that I labeled on the photograph.
Q. Now, the title of these magazines -- or this magazine is?
A. This is The Nudist.
Q. All right. And they must be from a long time ago because theyre 15 cents.
A. It says March 1935.
Q. All right. Now, do you remember where in those boxes that you found the Exhibit 592?
A. No.
Q. Which one of the boxes?
A. No, I do not.
Q. Lets go to 593. Do you recognize that?
A. Yes.
Q. Is that another one of the magazines that you took out of those boxes?
A. Yes.
Q. And are 592 and 593 in the same condition as when you first saw them?
A. Seems to be, yes.
Q. And this ones called Sunbather; is that correct?
A. Correct.
Q. Lets go to 594. Thats also a nudist -- the title is The Nudist, correct?
A. Yes, it is.
Q. Where did you find that particular item?
A. In one of the boxes.
Q. All right. And then lets -- I mean, is it in the same condition as when you found it?
A. Yes.
Q. And 595? Its another of The Nudist, correct?
A. Yes, it is.
Q. Is that in the same condition as when you saw it?
A. Yes.
Q. And where did you see it first?
A. One of the boxes.
Q. Now, with regards to the Exhibit 592, 593, 594 and 595 - okay? - can you tell us

whether those exhibits were all together in the same box or in different boxes? Do you
have a recollection about that?
A. I dont remember.
Q. Now, with regard to those exhibits, 592, 3, 4 and 5, what did you do with them after
you seized them from the box or boxes that you found them?
A. I took them to Detective Padilla for scribing and booking.
MR. SNEDDON: Your Honor, Id move that 592 through 595 be admitted into evidence, as
well as the bag that contains it, which is 834.
MR. SANGER: Ill submit it. THE COURT: Theyre admitted.
Q. BY MR. SNEDDON: Miss Williams, Im now asking you to look at three books, and the
first one is numbered 596, 597, and I believe 599. Would you take a look at those for me,
if you would. Do you recognize those exhibits?
A. Yes, I do.
MR. SANGER: Counsel, you didnt show me those, I dont think.
MR. SNEDDON: I apologize. I was trying to be too efficient.
Q. All right. Lets start with 596, Man, A Sexual Study of Man. Where was that the first
time you saw it?
A. This was inside one of the boxes.
Q. And the same locat ion as the other item?
A. Yes.
Q. All right. And is it in the same condition as when you first saw it?
A. Yes.
Q. All right. And the next one, 597, The Golden Age of Neglect. Do you recognize that?
A. I do.
Q. Is that one of the items that you seized?
A. Yes.
Q. Where was it when you saw it the first time?
A. This was also inside one of the boxes.
Q. And do you recall whether it was in the same box as any of the other items that you
previously identified?
A. I dont remember.
Q. Okay. And with regard to 599, do you recognize that?
A. Yes.
Q. And where was that the first time you saw it?
A. Inside one of the boxes.
Q. And the same area?
A. Yes.
Q. The boxes that youve previously talked about?
A. Yes.
Q. Is that in the same condition as when you first saw it?
A. Yes.
MR. SANGER: All right. Your Honor, I move that 596, 97 and 99 be admitted into
evid ence.
MR. SANGER: Submit it, Your Honor.
THE COURT: Theyre admitted. All three.
MR. SNEDDON: All right. We need the lights out again and Input 4 again.
Q. 596 is the book, Man, A Sexual Study of Man. Now, with regard to that particular
book, after you seized it, what did you do with it?

A. I took it over to Detective Pad illa to have it scribed and booked into evidence.
Q. All right. And 597, do you recognize that?
A. Yes.
Q. Okay. And with regard to that particular item, what did you do with it after you seized
it?
A. I took it to Detective Pad illa for scribing and booking into evidence. 6961
Q. All right. And the last item, which is 599, did you follow the same procedure with
regard to that particular book?
A. Yes, I did.
MR. SNEDDON: All right. Thank you. You can turn the lights on. Thank you. (Off-therecord discussion held at counsel table.)
MR. SNEDDON: Your Honor, I have a bag thats been marked as Peoples 835 for
identification purposes. And inside of the bag are Exhibits 598 and then Exhibit 600
consecutivelythrough 613. So its 598 and then 600 through 613. And Ive shown them to
counsel. And may I approach the witness, Your Honor?
THE COURT: Yes.
Q. BY MR. SNEDDON: All right. Ms. Williams, Im showing you the exhibit thats been
marked. Its a plastic bag, 835. You see that?
A. Yes.
Q. And then I took out -- from 835, I took 598 and then 600 through 613. Now, did I ask
you yesterday to look at all of those magazines contained in there?
A. Yes, you did.
Q. And do you recognize those magazines? Lets just do 598 first. Do you recognize 598?
A. Yes.
Q. Where was 598 the first time that you saw it?
A. It was in one of the boxes that I mentioned earlier.
Q. And the title of the magazine?
A. The Nudist.
Q. All right. So why dont we take 5 -- is it in the same condition as when you first saw it?
A. Yes.
Q. Lets put that one aside. Now, with regard to 600 through 613, were you asked to look
through those magazines?
A. Yes, I was.
Q. And those magazines are basically the same magaz ines, The Nudist, and then theres
a few other different ones in there?
A. Yes.
Q. And were those all magazines that you found in the downstairs area of Mr. Jacksons
bedroom?
A. Yes.
Q. And where in that area?
A. Within the boxes earlier mentioned.
Q. Okay. And were those also items that you gave to Detective Padilla to be scribed and
booked into evidence?
A. Yes.
Q. And are the ones that you looked at and the ones Im talking about now, 600 through
613, are they in the same condition as when you first saw them on the 18th of November,
2003?
A. Yes.

Q. All right. Lets put those back in here. And I move that 598 and 600 through 613 be
admitted into evidence, Your Honor.
MR. SANGER: I will submit it.
THE COURT: Theyre admitted. (Off-the-record discussion held at counsel table.)
MR. SNEDDON: Your Honor, I have a brown paper bag with a sheriffs evidence booking
tag on the front of it, and Ive had affixed to it the Exhibit No. 836 to the brown bag. And
contained inside of the brown bag are Exhibits 614, 615, 616, 617, 618 and 619 for
identification purposes. And Ive shown them to counsel and hes examined them, Your
Honor. And Id like to approach again.
THE COURT: All right.
Q. BY MR. SNEDDON: These exhibits Ive handed you came from the bag marked Exhibit
836, okay? And again, yesterday, I had you examine the items that came out of that bag,
Item 836, correct?
A. Yes.
Q. And those bags -- actually, those items have been chemically treated, correct?
A. Yes.
Q. With regard to the first exhibit, 614, its a binder. And did you have an opportunity to
examine that item yesterday?
A. Yes.
Q. And inside of that binder, 614, did you recognize the item inside?
A. Yes.
Q. And what was that?
A. It was a mag azine.
Q. And was it the same type of variety of the others that youve identified?
A. Yes.
Q. At the time that you saw it yesterday, was it in a different format as when you first saw
it?
A. Yes.
Q. How is it different now than when you first saw it?
A. It is -- has now been disassembled and chemically treated.
Q. Other than that, are the contents of the binder, the white binder thats been marked as
614, the same as the magazine that you picked up on November 18?
A. It appears to be, yes.
Q. Put that aside, and lets just go to 615, if we could. And 615, inside the plastic bag, do
you -- I had you examine that item yesterday, too, correct?
A. Yes.
Q. And what is the title of that document? Here, let me. I got my hands dirty. Ill do it.
A. It is The Nudist.
Q. So these are the like kind of magazine that weve previously -- youve previously
identified?
A. Yes.
Q. And other than having been chemically treated and disassembled, is the Exhibit 615
the same exhibit that you seized from Mr. Jacksons bedroom?
A. Yes.
Q. All right. Lets go to 616. Do you recognize that? You were asked to look at it
yesterday, correct?
A. Yes.
Q. And its the same type of magazine, Sunshine and Health, The Nudist, as 615 is,

correct?
A. Yes, it is.
Q. Other than being chemically treated and disassembled, is it in the same condition as
when you first saw it in Mr. Jacksons bedroom?
A. Yes.
Q. Now, these items, 614, 615 and 616, where were they found?
A. They were found in the boxes that Ive ment ioned earlier.
Q. Okay. Do you remember whether they were found in the same box es with the other
items or in different boxes?
A. I dont remember.
Q. Okay. Go ahead and put that up there. And lets go to 617. Do you recognize that?
A. Yes, I do.
Q. And thats another magazine of the same brand, correct?
A. Yes, it is.
Q. Same tit le?
A. Yes.
Q. And it has also been chemically treated, correct?
A. Yes.
Q. And disassembled?
A. Yes.
Q. Have you had the opportunity to examine the contents of that yesterday?
A. Yes.
Q. And is that also a magazine that you obtained from Mr. Jacksons bedroom?
A. Yes.
Q. And from the same area that you previously told the jury?
A. Yes.
Q. Put that up there. Is it in the same condit ion, other than the chemical treatment and
its disassembled, as when you first saw it?
A. Yes.
Q. All right. The next item is 618. Do you recognize that?
A. Yes.
Q. And where was that the first time you saw it?
A. Within one of the boxes from the same area.
Q. And with regard to that exhibit, whats different about it now than when you first saw
it? And by that exhibit, I mean 618.
A. This one has also been chemically treated and disassembled.
Q. Other than that, its the same?
A. Yes.
Q. All right. Would you put that up on top. And lets go to 619. Do you recognize 619 for
identification purposes?
A. Yes.
Q. And where was that the first time that you saw it?
A. From within one of those boxes.
Q. And that one has also been chemically treated and disassembled, correct?
A. Yes, it has.
Q. Other than that, is it in the same condition as when you first saw it?
A. Yes.
Q. All right. And with regard to these items that weve had marked for identificat ion

purposes 614 through 619, were these also given to Detective Padilla, the scribe?
A. Yes, they were.
MR. SNEDDON: Your Honor, I move that 614 through 619 be admitted into evidence, as
well as the bag which contains these exhibits, which is 836.
MR. SANGER: Submitted.
THE COURT: Theyre admitted.
MR. SNEDDON: Were almost there. (Off-the-record discussion held at counsel table.)
MR. SNEDDON: All right, Your Honor. At this time Ive had marked for identificat ion
purposes a bag, a brown bag, with, again, a sheriffs evidence tag with the number
#366 at the top. And the number here is 837. And from inside of that bag Ive
withdrawn two exhibits. One is a magazine. And its identification is 620 for identification.
The title is Eden, E-d-e-n, and the exhibit number 621 is The Nudist Ive had marked
for identification purposes. And then lastly -- and Ive shown those to
28 counsel for his examination. And lastly, I have a brown bag, again with a sheriffs
evid ence tag on it, with the number 359 in b lack in the upper right-hand corner. Inside
the bag Ive withdrawn the contents and shown to counsel a book called PooChi,__________6 P-o-o-C-h-i. Im sure Im not pronouncing it correctly. But thats as
good as it gets. And may I approach again, with your permission?
THE COURT: Yes.
Q. BY MR. SNEDDON: Okay. Now, with regard to the Exhibit 837, thats the brown bag,
okay? W e have 620 and 621. So let me ask you the questions. 620, where did you find it?
A. I found this within one of the boxes.
Q. And is it in the same condition today as when you first found it?
A. Yes.
Q. This one hasnt been treated or disassembled, correct?
A. Correct.
Q. All right. And then 621, where did you find that?
A. Within one of the boxes.
Q. And with regard to 621, is it in the same condition as when you first saw it?
A. Yes.
Q. Now, with regard to 620 and 621, did you give those also to Detective Padilla?
A. Yes, I did.
Q. All right. If I can have those back. And these are in the same condit ion as when you
first seized them?
A. Yes.
Q. If I didnt ask you, where did you seize these two items, 620 and 621, from?
A. They were from within one of the boxes.
Q. And lastly, 538 (sic). Im taking out of the bag a book and handing it to you, the
contents of 538 (sic). Do you recognize that book?
A. May I look at that?
Q. Absolutely.
A. Yes, I do.
Q. Do you recall where that item was the first time you saw it?
A. Yes, I do.
Q. Where?
A. This was located in a bookcase that is on the far wall of the den area.
Q. Okay. Im going to come back up and show you Exhibit 90. Do you recognize the area
where you found Exhibit 838?

A. Yes.
Q. All right. Would you put an arrow to it? And would you just write 838 up there? 6971
THE COURT: I think youd earlier called that 538. Am I correct?
MR. SNEDDON: The book, Your Honor? Its 838.
THE CLERK: He misspoke.
MR. SNEDDON: I misspoke?
THE COURT: Im sorry, I just want the record to reflect that when you said 538, you
meant 838.
MR. SNEDDON: I did, Your Honor. Thank you.
Q. All right. For the record, on Exhibit 90 you put a red arrow and an 838 to the right of
the red arrow; is that correct?
A. I did.
Q. And that is the location where you found Exhibit 838?
A. Yes.
Q. And is that exhibit in the same condition as to when you found it -A. Yes.
Q. -- on November 18th?
A. Yes, it is.
Q. Did you also give that to Detective Pad illa?
A. Yes, I did.
MR. SNEDDON: Okay. Thank you. Move that Item 837 and the contents, which are 620
and 621, and 838 and the contents, be admitted into evidence, Your Honor.
MR. SANGER: Submitted, Your Honor.
THE COURT: Theyre admitted. MR. SNEDDON: I believe thats it. No further questions.
THE COURT: Mr. Sanger?
MR. SANGER: Thank you, Your Honor.
CROSS-EXAMINATION BY MR. SANGER:
Q. Detective Williams, how are you?
A. Fine, thank you.
Q. You -- and youre retired, correct?
A. Yes.
Q. May I still call you detective? Is that okay?
A. Im happy with it.
Q. When did you retire exactly? You said that, and I missed it.
A. February of last year.
Q. February of -A. 2004.
Q. 2004, okay. You were active duty and still working actively for the sheriffs department
in November of 2003; is that correct?
A. Yes.
Q. All right. Now, Detective Williams, I think you said youve been a sheriffs officer for 29
years; is that right?
A. Yes.
Q. Okay. And in fact, if Im not mistaken, you were one of the first two female officers in
the Santa Barbara Sheriffs Department; is that correct?
A. No.

Q. Okay. Close to it, in any event?

A. Close.
Q. Theres a story behind there that I havent got quite right. But in any event, you have a
long career with the sheriffs department; is that right?
A. Yes.
Q. And you have been a detective for how long?
A. I was a detective two different periods. The last time in Coastal Station, which was ten
years. And then prior to that, it was at the main station, which was for nine years.
Q. Okay. And part of what you did as a detective was specialize in sex crimes; is that
right?
A. Yes.
Q. All right. So you have a great deal of experience being the lead detective in sex
offenses; is that right?
A. I have some experience, yes.
Q. Well, when you say some, are you being modest? Youve had quite a number of cases
where youve been the lead officer -A. Yes.
Q. -- in sex cases, correct?
A. Yes.
Q. All right. And in this particular case, your assignment was to assist on one of the
searches that was occurring on November 18th, 2003; is that correct?
A. Yes.
Q. And you were then -- you were then not asked to do anything else. You were given no
other
9 assignments in this case; is that correct?
A. Thats correct.
Q. Now, if I understand what you did, you focused your attention on that first floor. And
could I have the exhibits? Id like 590, if you have it there.
MR. SNEDDON: Its up there.
MR. SANGER: Oh, its up there? May I approach to retrieve it?
THE COURT: Yes.
MR. SANGER: May I put this back up on the screen, Your Honor?
Q. Now, youve already told us that this is the first floor. But just so were oriented, for
people who are not oriented already, the boxes of books that you referred to under the
arrow are to the right of a television, large screen T.V. console; is that correct?
A. Yes, it is.
Q. All right. And theres additional -- an additional p art of the room to the left on this
picture that you cant see in the picture; is that correct?
A. Yes.
Q. And did you search that entire area?
A. Yes.
Q. Behind the piano -- in fact, do you have the pointer there still? Okay. Would you be
kind enough to point to the piano? Okay. By the way, on the piano, was there a letter
from Steven Spielberg sitting there?
MR. SNEDDON: Object as immaterial, Your Honor.
THE COURT: Overruled. You may answer.
THE WITNESS: I dont remember.
Q. BY MR. SANGER: All right. Behind the piano that you just pointed to is an alcove area;

is that correct?
A. Yes.
Q. Can you point to that? And there are quite a number of books in that area as well,
correct?
A. Yes.
Q. And thats where you found 838; is that right?
A. Yes.
Q. Most of the books in that area are art books; is that correct? Or art and entertainment
kind of books?
A. I believe so. I dont remember exact ly, but I believe there were quite a number of
those.
Q. All right. And then on the -- where youve drawn the other arrow to the boxes, and you
indicated you found the other exhibits that youve talked about today, there are -- there
were a number of boxes there; is that correct?
A. Yes.
Q. You dont know whether those boxes were coming or going or had been sitting there,
do you?
A. Correct.
Q. You dont know whether or not Mr. Jackson had even looked inside those boxes, do
you?
A. Correct.
Q. All right. Now, Mr. Jackson is an artist; is that correct? A performer?
A. Hes a performer, yes.
Q. And hes an artist. He writes and composes music and choreographs dance, that sort of
thing; is that correct?
MR. SNEDDON: Im going to object as immaterial; lack of foundation.
THE COURT: Overruled. You may answer.
Q. BY MR. SANGER: Is that correct?
A. Yes.
Q. And you saw a tremendous number of books that pertained to that sort of thing, art
and dance and entertainment, music, correct?
A. I remember seeing books of that nature, yes.
Q. Do you know if people send books to Mr. Jackson?
MR. SNEDDON: Object; calls for speculation.
MR. SANGER: Its a yes or no, Your Honor.
THE COURT: Yes, you may answer yes or no.
THE WITNESS: I dont know if people send him books.
Q. BY MR. SANGER: All right. Now, of all of the books that you have identified -- and Im
not going to go through by number here. But out of all of the books that youve identified,
there are no books in that group that are unlawful for an adult to purchase; is that
correct?
A. I dont think there are.
Q. All right. And none of those books are unlawful for an adult to possess in his home; is
that correct?
A. I believe youre correct.
Q. You mentioned that -- lets put it this way: You saw a number of these books. Let me
see if I can take them out, here.
THE COURT: Are you through with the picture up there?

MR. SANGER: Yes, Your Honor. And then Ill -- thank you.
Q. Ill just refer you for the moment to Exhibit -- the bag is 835 and the contents are 598
and following. Do you remember those magazines? Would you like me to bring them to
you?
A. I remember them basically, yes.
Q. Okay. These magazines are, I think you said, from 1931; is that correct?
A. Theyre from different years; 1935, 37, that era.
Q. Thats true, actually. These are from 1935. And the title of the publication is The
Nudist; is that correct?
A. Yes.
Q. These appear to be collectors items, do they not?
A. They could be.
Q. All right. And you have no information as to whether or not Mr. Jackson even knew that
they were in the box; is that correct?
MR. SNEDDON: Object. It calls for speculation.
THE COURT: I was going to say she could answer yes or no, but anybody Ive ever
said that to has never answered yes or no. (To the witness) Dont answer that yes or
no. (Laughter.)
THE WITNESS: But I should answer?
THE COURT: Yes.
THE WITNESS: So, may I ask what the question was again, please?
Q. BY MR. SANGER: I think His Honor is kidding with you. You can answer yes or no.
Do you have any informat ion as to whether or not Mr. Jackson ever saw these nudist
magazines?
A. I dont have any informat ion that he did or did not see them. (Laughter.)
MR. SANGER: There you go.
THE COURT: Someone following my instructions.
Q. BY MR. SANGER: Now, in the part of Mr. Jacksons house that you searched, do you
know how many books were there total?
A. No, I do not.
Q. Were there thousands?
A. There were many books.
Q. Okay. At least hundreds?
A. Yes.
Q. All right. And you went to some other places in the residence other than that particular
room, did you not?
A. Yes.
Q. What other places did you go to?
A. The second story, a pantry-like room, a large room with mult iple games and toys, and
two bedrooms.
Q. All right. And you saw books elsewhere in the house besides where you were searching
here in this room; is that correct?
A. Some books.
Q. Did you -- in order get to that room, you had to walk down a hallway, right?
A. To the den area. Is that what youre talking about?
Q. Yes.
A. Yes.
Q. And that hallway was lined, f loor to ceiling, with bookshelves filled with books; is that

correct?
A. I dont remember.
Q. Okay. Thats fair enough. And there was a library just off of that hallway as well. Did
you take a look in that library?
A. No.
Q. Okay. Now, you said you did go upstairs, because you went into Mr. Jacksons sons
room; is that right?
A. Yes.
Q. And right up there by his sons room is an alcove that is filled with childrens books; is
that correct?
A. Yes.
Q. All right. And again, there are hundreds of books up there; is that right?
A. Yes.
Q. Did you have occasion to go to the arcade where there is a room that is basically filled
with books?
A. Are you talking the same room thats the second story of the main residence?
Q. No, its a different building. The arcad e building.
A. I did not go there.
Q. All right. Of all the books that you saw, you seized the ones that you felt might be of
some evidentiary value based on what you understood this case to be about; is that
correct?
A. Yes.
Q. All right. Im going to ask you to take a look at 599, and see if we can.... May I
approach, Your Honor?
THE COURT: Yes.
Q. BY MR. SANGER: Im going to show you 599. That appears to be a book of photographs
that were taken some time ago; is that correct?
A. May I look through it?
Q. Yes, please. They appear to be old photographs?
A. They look like they could be old photographs. They have the sepia tone into them.
Q. All right. And you said that as far as you know, theres nothing illegal about an adult
possessing that book in the United States, or in California, lets say?
A. Yes.
Q. The United States in general, okay. Were you aware that that particular author, that
photographer, was prosecuted and acquitted during the Nazi regime prior to World War II
for those very photographs?
MR. SNEDDON: Your Honor, Im going to object as immaterial.
THE COURT: Sustained.
Q. BY MR. SANGER: Lets put it this way: As you look at that, that appears to be a historic
book, a book of recording historic photographs; is that correct?
A. I dont know what you mean by that.
Q. All right. Did you do any research as to any of the authors of any of these books?
A. No.
Q. All right. So in other words, that day you were there, your job was to look at things and
see if they appeared to be within the search warrant and you seized them?
A. Yes.
Q. All right. All right. Let me show you -- let me ask you, before I show you something
else, you seized some other things that have not been introduced into evidence here; is

that correct?
A. Yes.
Q. All right. You seized some paperwork from Mr. Jacksons sons room; is that right?
A. I believe so.
Q. Okay. And you seized some other things. You seized a Christmas invitation from Liza
Minnelli; is that correct?
A. Yes.
Q. All right. Now, Im also going to show you Exhibit 838. May I approach, Your Honor?
THE COURT: Yes.
MR. SANGER: And Ill take this back, if I may.
Q. Thats 838. Before I ask you about it, your procedure in searching through all these
books and boxes and things was to -- was to find books that, by their cover, looked like
they would warrant some further interest on your part, right?
A. Usually I would open up the books to try to see what was inside also.
Q. Okay. But you didnt flip through every 6984 single book in that room?
A. No.
Q. All right. So first of all, youd look at something that looked like it might be a book that
had something to do with sex. Is that pretty much what you were looking for?
A. Yes.
Q. All right. And then once you found that book, you would look through it and see if you
felt that it was the type of book that you thought should be seized in this case, correct?
A. Yes.
Q. All right. And youve indicated you seized some other items besides that, but when it
came to these books that related to some sexual topic, you would actually look in them
and make a determination that you should take it, correct?
A. Yes.
Q. All right. Now, on No. 837 -- Im sorry, what is that? 838, the bag 838, and inside the
bag is the book, right?
A. Yes.
Q. And you seized -- have you looked inside the book?
A. Yes.
Q. Okay. Now, again, youre an experienced sex crimes detective, correct?
A. Yes.
Q. So youre not shocked by seeing pictures of the human body; is that right?
A. I can still be shocked.
Q. Okay. Were you shocked by that book thats called Poo-Chi, P-o-o-C-h-i?
A. Yes.
Q. And you described it as -- if I get your exact -- do you recall how you described it?
A. How I described it?
Q. Yes. Did you describe it as a book containing photographs of the female groin area?
A. I may have. Im not sure if I did or if thats the way Detective Padilla understood what I
said.
Q. All right. Well, did you say something like that to him?
A. Probably.
Q. And does that appear to be what you described to him?
A. Well, some of it looks like it, yes.
Q. Okay. So the question is, is that pretty much what you told Detective Padilla, that you
have a book that appears to be photographs of the female groin area?

A. Probably.
Q. All right. And, Detective, as you look at that a little more carefully, those are pictures of
armp its and other bodily fo lds, that are not from genital areas, that are made to look like
that as a spoof of some sort; is that correct?
A. Some of them could be. And some of them I dont know.
Q. All right. And once again, theres nothing illeg al about owning that book, is there?
A. Not that Im aware.
Q. And you dont know if Mr. Jackson even ever saw that before, do you?
A. I do not know.
MR. SANGER: Okay. Thank you. I have no further questions.
MR. SNEDDON: No questions.
THE COURT: All right. Thank you. Youre excused.
THE WITNESS: Thank you.
THE COURT: Well take our recess. Remember, tomorrows a half day. See you tomorrow
at 8:30. (The proceedings adjourned at 2:30 p.m.)

2005 April 20 (Day 36) Testimony of Brian Barron

BRIAN BARRON DIRECT EXAMINATION

BRIAN BARRON
DIRECT EXAMINATION BY MR. AUCHINCLOSS
Q. Who do you work for, please?
A. Currently I work for the City of Guadalupe as a police officer.
Q. How long have you been a police officer?
A. About six and a half years.
Q. And for the City of Guadalupe that entire time?
A. Correct.
Q. At some time in your past, were you an emp loyee of Neverland Ranch?
A. Yes.
Q. And what did you do for Neverland Ranch?
A. I was a security officer there.
Q. How long were you a security officer at Neverland?
A. For about five, five and a half years.
Q. Was that continuous or sporadic?
A. It was sporadic. It was over three periods of time.

Q. Can you characterize approximately what those three periods were?

A. I started in the fall of 1997. Worked for about a year. I was in the police academy at
that time. I then got hired by Guadalupe Police D epartment. Left the ranch for about a
year. And then went back again about nine or ten months after that, and was there for
about three years, three and a half years. And when did you ultimately leave your
employment at Neverland?
A. It was about April or May of last year.
Q. And whose decision was that to leave?
A. Mine.
Q. Tell me what your duties were as a security officer at Neverland Ranch.
A. Our duties consisted of the ranch itself, securing the ranch itself, the guests on the
ranch, the owner of the ranch, and anything that had to do with the ranch as far as first
aid, security. Anything that we could do to help, we would do. But mostly it was to secure
the ranch, the owner, and the guests that were there, the employees.
Q. Did you have set days and hours that you worked?
A. Generally, yes. Hours, yes. At times the days werent always set, but hours, yes.
Q. So during your time working there, did you always work days or nights? Or you tell
me.
A. Generally I worked nights for the entire time I was there.
Q. And tell me what a night shift would consist of.
A. Night shift would consist of 6 p.m. to 6:30 a.m. And then we would do rotating shifts at
the front gate. And then we would do -- which would be
about four hours per person at the gate. And then secure the ranch after youve done your
-- before or after youve done your gate time.
Q. So if you would, if you can, give me a descript ion of an evening of work at Neverland
Ranch from the time that you check in to the time that you finish your evenings work and
you go home. And Im interested in particularly where you go, where you are on the ranch
at various times.
A. Okay. If I were to get there at 6 p.m. and were to take the first shift at the gate, I
would be at the gate from 6 p.m. till about 10:15. And that would be checking in and out
people who are coming in and off the property, answering phones, doing whatever was
necessary there.
Q. So when youd come to work, theres a gate that is -- approximates the perimeter of
the property, is that -A. Correct.
Q. Or is that inside the property?
A. No, that would be the guard house at the front gate. So youd come in the gate there
are theres a guard.
Q. Okay. Theres a house there, a guard house?
A. Yeah.
Q. And when youd come to work, would you just check in at the gate and stay there, or
would you go to the main house first and go back to the gate?
A. Sorry. Wed go to the main house first, get any pass-on information that was going to
happen that we needed to know that had happened on the prior shift or the things that we
needed to know from the oncoming shift. That would be just speaking with the officers
who were there at the house office. Security office.
Q. And where is that located?
A. If you can imagine the entire house property, and if you were looking at it from the

front, it would be on the far left. Sorry, it would be on the far left of the building. Theres a
main house, a walkway, Mr. Jacksons office, video library, and the security office.
Q. So the security office is contiguous to the main house structure?
A. By way of a breezeway.
Q. Okay. And access to the security office, is that an exterior door or an interior door?
A. Its an exterior door.
Q. Does it have any interior connection to other parts of that structure?
A. No.
Q. When you go in the security office, how many rooms are there?
A. Theres two.
Q. And could you describe them for me?
A. First room would be -- had a desk in it. Had a computer in it. So it technically had two
desks in it, one on each side of the wall. There was a window that faced out towards the
front property, the front lawn area of the house. And then as -- that would be basically the
inside of that room. There was also in that room a grease board that we put pass-on
informat ion on, guest information on. And then as you go into the next room, it was
basically a break room. There was lockers, refrigerator, and a table to eat on.
Q. What was the computer used for in the first room you mentioned?
A. Mostly what we used it for was generating our forms that we use on a daily basis,
accident forms. It wasnt really used for much. We would create, like, reports on that
computer, security reports, anything that had to do with us. If there was a -- you know,
we noticed damage to something on the property, we would write it up on the computer
there. But that was mostly what that computer was used for.
Q. All right. So moving back to our chronology of a day in the life of a security guard. You
check with the main office. If you have gate duty, you go out to the gate. What next?
A. If you dont have gate duty, then you would start your regular patrols. First thing you
would do when you got on the property was make sure --you know, we would know who
was there, if we had guests, if the owner was on the property. And we would check all of
the doors around the house first. Wed do a check of the house area, make sure all the
doors were locked, everything was in order. If build ings needed to be opened, that those
buildings were opened around the house area. And then we would -- after completing that
check, we wou ld do a similar check to the rest of the properties on the residence, any
other buildings on the residence.
Q. If youre on patrol, would you be doing continuous checks?
A. Hourly checks.
Q. And what would you be doing between those checks?
A. Stuff to keep busy. We did a lot of training. The fire department, theyre trained
regularly, and we wou ld assist with that. We were all basically part of the same group.
Q. How many security guards are on duty during an evening shift?
A. When I was working there, it was between three and four.
Q. How many on a day shift?
A. About the same.
Q. And as far as the next thing youd do in your evenings work, would you continue to do
these security checks throughout the evening?
A. Thats correct.
Q. How many would you do in an evening?
A. If we d id one an hour, 12. If we did more, just -- it would depend on need.
Q. Okay. And where would a security check take you on the property?

A. Everywhere.
Q. Would different officers check out different areas?
A. No. Wed check all -- being there would only be two of us at the house. If there was
three of us working, there would be one of us at the gate and two of us at the house
office. If there were guests or anyone on the property that was in -- at the house area, we
would -- one of us would stay there, and the other one would check all the doors on the
residence, all the build ings -- on the property, excuse me, everything.
Q. As far as checking the doors of the main residence, would you have -- did you have a
key to the main res idence?
A. Yes.
Q. And what door did that open?
A. The back door.
Q. Okay. As far as -- did -- the main residence has a punch card that can -A. A key pad.
Q. -- that can give you access? Like a telephone pad.
Q. Did you have the code to that key pad?
A. No.
Q. Did you have the code to the key pad that gave access into Mr. Jacksons private suite?
A. No.
Q. Did any of the security guards, as far as you know?
A. Not that Im aware.
Q. When youd work in the security guard booth at the entrance to the property, tell me
about what your duties would be there.
A. Duties there were generally letting people on and off the ranch. We had paperwork that
would allow us -- that we would know ahead of time who was allowed to come on the
ranch, whether that would be guests, or it would be general deliveries, contractors, things
of that nature. We would know who was coming and who was supposed to be there for
that day, so we would have those people come on and off. We also checked in all the
employees and checked out all the employees, times they were in, t imes they were out.
Every time they came or left the property. Answering phones was a large part of it. The
majority of the phone calls that came in, especially in the evening time, they all came
basically through us. Q. When you were conducting your duties as a security officer at
Neverland, did you have occas ion to see the owner of the property?
A. Yes.
Q. And that would be Mr. Jackson?
A. Yes.
Q. Is he seated to my right, the man with the black hair?
A. Yes.
Q. And how much would you see Mr. Jackson on the property, assuming -- let me strike
that question. How often would you see Mr. Jackson on the property during those times
when he was visitingNeverland or staying at Neverland?
A. Daily. At least.
Q. Okay. And would you be able to see him --would you see him interacting with guests
when they were on the property?
A. Occasionally.
Q. Would you ever talk to Mr. Jackson personally?
A. Only if I needed to.
Q. Okay. And how often would you have contact with him?

A. Not on a regular basis. Only if there was something pressing that he needed to know or
we needed to ask him. We tried to let him have his privacy when he was there.
Q. You mentioned forms that are prepared on the computer. Are there daily logs that are
kept at Neverland?
A. Yes.
Q. What are the daily logs?
A. The daily logs that we kept at the gatehouse, where those logs were kept always, was
the employee entry list, the daily activity list, which would include, like I said, anybody
other than employees coming on and off the property, which would mean anything -general contractors, deliveries, anything like that, any guests that were on the property.
Also our time checks for all of the -- we would call in the start of a check of the ranch, a
security check, all the doors, and we would call in anything that would happen that we
would find out of the ordinary and log that at the gate. And then the end of that check
also.
Q. Were these logs used during the entire I believe four years that you said you worked
there?
A. About five years. Yes.
Q. Five years you worked there?
A. They changed. At times they looked different, but they were basically the same.
Q. What about accident reports? You mentioned those. How are they prepared?
A. In the same fashion. We would -- initially we would let whoever was at the gate know
that we found something or something had happened, somebody had wrecked one of the
golf carts or fallen down, whatever the case may be. We would let -- either the gate would
let us know, because they called the gate, or we would let the gate know, because we
were notified at the house. And then we would prepare that form after the conclusion of
whatever was going on.
Q. How often would you have to prepare accident reports?
A. Not often. I didnt prepare very many. The day shift usually prepared more, because
more things -- theres more people, more activity on the ranch, more employees. More
guest activity during the daytime generally. But, you know, a couple times a month.
Q. You mentioned theyd be prepared if a golf cart was wrecked?
A. Uh-huh.
Q. Would that be a common occurrence?
A. It happened -- it seemed to happen a lot more than it needed to, yeah.
Q. Why do you say that? MR. SANGER: Objection, calls for speculation, Your Honor. THE
COURT: Sustained. Q. BY MR. AUCHINCLOSS: Okay. Was there --tell me, was there a
difference in the attitude and demeanor of employees when Mr. Jackson was on property
as opposed to when he was off?
A. Yes.
Q. How would you describe that?
A. Tense.
Q. Can you elaborate on that? Why would emp loyees be tense?
A. Well, they would have to get there earlier usually. Theyd have more work to do. He
was --hes very -- at least the way I feel, is hes very -- like a perfectionist, everything has
to be right. His property, his prerogative to be that way. But there was a lot more work to
be done. Everybody just seemed to be walking on pins and needles a little bit more just to
make sure things were right. MR. AUCHINCLOSS: Mad am Clerk, do we have a notebook
with Exhibits 300, et seq.? THE CLERK: Yes. MR. AUCHINCLOSS: Thank you. May I

approach, Your Honor? THE COURT: Yes.

Q. BY MR. AUCHINCLOSS: Mr. Barron, I show you a black notebook that appears to
have numerous records in it. It is labeled as Exhibits 300 through 335. Id like you to take
a moment and look at that. I dont really want you to look at every exhibit, but -A. Thats all right.
Q. If you could just kind of thumb through it quickly.
A. They look very familiar.
Q. All right. Have you looked at a notebook like that?
A. Yes.
Q. And can you identify those records for me, please?
A. Yes. They are the employee in-and-out logs, the gate activity logs, and the daily entry
access logs.
Q. And are these the type of logs that you were talking about when you said that you
personally would prepare records at Neverland?
A. They are the logs.
Q. Okay. Now, just to help us a little bit with the various types of forms here, looking at
Exhibit No. 300, the first page, can you tell us what that is, please?
A. Thats an accident or damage report.
Q. All right. And is that the type of report that would be prepared by a security officer in
his
normal duties at Neverland Ranch?
A. Yes.
Q. Did you yourself ever prepare these reports?
A. Yes.
Q. Does this look to be an authentic copy or an authentic document as far as an accident
damage report?
A. Yes.
Q. Would these reports, the accident damag e reports, be prepared in the normal course of
your duties as a security officer at Neverland Ranch?
A. Yes.
Q. When would these reports be prepared in relat ion to the accident that they are
describing?
A. Generally right after, or very soon after the -- whatever happened happened.
Q. And is the information -- does the person who prepares these reports have a duty to
accurately describe what is in the report itself?
A. Yes.
Q. Moving on to Exhibit 301, it appears to be -- it appears to be a daily log.
A. Uh-huh.
Q. Is that, in fact, what it is?
A. Yes.
Q. And tell me what type of daily log this is.
A. This would be the employee in-and-out entry and exist list. So the time you were in
and time you were out, if you were there overnight. You notice theres CO here, carryover, you were carried over from the midn ight hour to the next day.
Q. Okay. And there are numerous names on there?
A. Yes.
Q. Are those the names of the employees at Neverland?
A. Yes.

Q. And the written in information, in and out, depicts the time that they checked in and
the time they checked out?
A. Correct.
Q. Again, this is a report thats prepared in the ordinary course of your duties as a security
officer?
A. Yes.
Q. And does the security officer have a duty to accurately record the information in this
report?
A. Yes.
Q. And is it prepared at or near the time of
the entries that are made?
A. At the time.
Q. Okay. Now, there appears to be a -- turning over page 301, on the back of it and on
the next page there appears to be a report entitled Daily Entry Access.
A. Correct.
Q. Tell me what that is.
A. That would be the entry and access of anybody who normally would come on the ranch.
Most of these on the top part of it are deliveries, and then those on the bottom would be
the guests who are on the ranch.
Q. Okay.
A. For that day.
Q. Again, the same question. Are those parts of your duties as an officer at the ranch?
A. Yes.
Q. And are they prepared at or near the time of the events recorded in that report?
A. At the time.
Q. And your duty is to prepare those reports accurately?
A. Yes.
Q. Okay. Now, Im also seeing -- looking at a report now that is on the back page of
Exhibit No. 302.
A. Uh-huh.
Q. Its entitled Gate Activity Log. Tell me what that is, please.
A. The gate activity log is, like I was explaining earlier, when something happens or
theres some information that officers need to know or anybody else who may need to
know, we wou ld write it down on the gate activity log. The top part of that paperwork is
the officer who was working the gate and the time that they were there. And then the
center part is, again, that information that would be necessary for officers to know or to
pass along to other people who are coming on and off the ranch, and that information is
written down at the time its given and then theres a time that its given. If it says, CO,
which again is carry-over, that would mean thats something that needs to be on this list
for an extended period of time, so that were aware of it. And then the bottom portion is
the time we start our checks of the ranch, and then the time we finish the house checks,
and then the exterior
patrols also.
Q. Okay. I hate to be redundant, but I have to ask you the same questions. Is that
prepared in the ordinary course of your duties as a security officer at the ranch?
A. Yes.
Q. Is it a document that is -- that your duty is to accurately describe the gate act ivity at
the time that it is happening or contemporaneous with the information thats in that log?

A. Yes.
Q. And you yourself have filled these logs out and are familiar with how these are
prepared?
A. Many of them, yes.
Q. All right. And I asked you previously if you had reviewed a book similar to this. Theres
one more page here that I think Ill ask you about. Looking at 320, there is a security
clearance and guest information form.
A. Correct.
Q. Tell me what that is.
A. That would be given to the gate. For instance, this one was given hopefully the day
before, so its June 18th of 02, telling us that the next day this gentleman would be
coming onto the property, that did he not need to sign a confidentiality form, and then
what he was going to be doing or where he needed to go.
Q. Okay. So before youd let somebody on the ranch, would one of these have to be filled
out if they were not already a guest or employee?
A. Yes.
Q. And were you notified beforehand whether to let a guest onto the property or not?
A. Yes.
Q. Would guests be allowed on the property if you did not have a form authorizing their
admission?
A. No.
Q. Showing you Exhibit 333, there appears to be an emergency medical report.
A. Uh-huh.
Q. What is that, please?
A. That would be if someone was injured, one of the firefighters, who were for the most
part all EMTs, would complete one of these forms for the ranch purposes to have record of
whatever the accident -- where they had been injured had happened.
Q. Okay. And same questions there, duty to accurately prepare that informat ion?
A. Yes.
Q. Youre familiar with how that informations prepared?
A. Yes.
Q. You filled those out yourself?
A. I think maybe one I filled out for the EMT that was working on the person, just
handwrit ing for them. I never d id one of my own.
Q. These are prepared at or near the time of the event thats recorded?
A. Yes.
Q. And theres a duty to accurately depict the information on there?
A. Yes.
Q. And then Im showing you lastly a Neverland Valley Medical Report Log. Have you ever
seen one of those?
A. Yes.
Q. Tell me what that is.
A. That is a log of all the med ical reports that were done for the year. So all of them had
their incident report number, the date, who took it, the time it was taken, the name of the
person, what was -- what happened, the injury, and then what type of treatment they
were given.
Q. Okay. The person filling that form out had a duty to prepare it accurately?
A. Yes.

Q. Prepared at or near the time of the act, condition or event thats depicted in the form?
A. Yes.
Q. And youre familiar with how those are prepared?
A. Yes.
Q. Okay. And then Im showing you -- I dont think weve gone over one of these yet,
have we?
A. Again, thats the same, its just a different looking form. Its the blanket routine form,
the guest form, and then ranch -- again, a lot of these forms changed. This is the same
form as one of the earlier forms that we looked at.
Q. This is a form in Exhibit 335. Its on the back page of one -- well, on the second page,
there appears to be one. So this is a similar form as far as guest activity?
A. Its the exact same, its just written different. MR. SANGER: Excuse me, Your Honor.
335 has a number of pages, as far as I can tell. What page are we talking about? MR.
AUCHINCLOSS: I had said the second page. Turn the page over and its on the back sideof
the first page. MR. SANGER: May I approach, Your Honor? I think the book that we were
given may be out of order in 335. THE COURT: Yes, go ahead. MR. SANGER: Thank you.
MR. AUCHINCLOSS: Do you have 335? It should be the second page. MR. SANGER: You
have it on the back side. MR. AUCHINCLOSS: We doubled it up. MR. SANGER: All right.
Thank you.
Q. BY MR. AUCHINCLOSS: So all the questions Id asked you before would apply to this
one as well -A. Yes.
Q. -- that youve spoken about, guest activity logs and such?
A. Yes.
Q. Okay. And I previously asked you if you had a chance to review these records. Would
your
testimony be the same concerning all of the records that are contained in this notebook
regarding the accuracy of the information, the duty to prepare accurate informat ion? All
these records were prepared at or near the time of the events that were recorded?
A. Yes.
Q. And youre familiar with their method and mode of preparation?
A. Yes. MR. AUCHINCLOSS: Your Honor, Id ask that Exhibits 300 through 335 be
admitted at this time. MR. SANGER: And I take it theyre offered as a business record. MR.
AUCHINCLOSS: They are. MR. SANGER: I have no objection to that foundation. THE
COURT: All right. Theyre admitted as business records. MR. AUCHINCLOSS: Thank you.
Q. Mr. Barron, you said when you were doing your daily duties, conducting your daily
duties as a security guard, youd have occasion to see Mr.Jackson on the property?
A. Yes.
Q. Would you have occasion to see him interact ing with his guests?
A. Occasionally, yes.
Q. Would you have occasion to see guests when they werent interacting with Mr. Jackson
on theproperty?
A. Yes.
Q. Do you know an individual by the name of Frank Tyson or Cascio?
A. Yes.
Q. Who is Frank Tyson or Cascio?
A. From what I originally knew, he was a friend of the family -- of Mr. Jacksons family, or
a

friend of Mr. Jackson. His family, his parents and brothers and sister were friends. At
some point I believe he became an employee of Mr. Jackson. What his exact duties were I
dont really know. But he was -- at some point, he became an employee.
Q. And do you have a time frame for when he was an employee, approximate?
A. I would say probably around -- maybe around the year 2000, right around in there.
Q. Okay.
A. And whether he still is or is not, I dont know, but -Q. Did Frank Cascio ever live at Neverland?
A. He stayed there a lot. Whether he lived there or not, as far as his primary residence,
Idont know. But he was there quite often.
Q. Would he stay there longer than a month?
A. Yeah. At times I think he would, yes.
Q. Did you have occasion to observe his relationship with Mr. Jackson?
A. Not on a real personal level, between the two of them, no.
Q. Did you see them together?
A. Yes.
Q. Would Mr. Cascio ever spend time in Mr. Jacksons bedroom?
A. I have no idea. MR. SANGER: Objection; calls for speculation, Your Honor.
MR. AUCHINCLOSS: Ill withdraw that question. And you can strike the answer, thats
fine.
MR. SANGER: So moved. THE COURT: All right. So granted.
Q. BY MR. AUCHINCLOSS: Do you feel that you could -- you have sufficient information
to describe their relat ionship?
A. Yes.
Q. And how would you describe their relat ionship?
A. I would describe it --MR. SANGER: I would object as no foundation. I believe he said he
didnt observe their relationship. THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: When you said you observed them together, where would
you observe them?
A. Generally on the ranch, in the movie theater. Id seen them riding the quads on
theranch before. Just doing general activities. In the park, Id seen them in the park
before, the theme park.
Q. How many times do you think youd seen them before, approximately, if you can
estimate? MR. SANGER: Im going to object as vague as to time.
Q. BY MR. AUCHINCLOSS: During the entire period of time that you were a security
guard.
A. Maybe 75 to 100 times. I mean, in passing I would see them together.
Q. And did you -- how many times -- if you could estimate, how many nights during that
period of time, five-year period of time, did Frank Cascio spend at Neverland?
A. Oh --MR. SANGER: Well, Im going to object as lack of foundation. THE COURT:
Sustained. Q. BY MR. AUCHINCLOSS: You said that you were familiar with the logs in
terms of who was staying on the property?
A. Yes.
Q. Was that part of your daily duties?
A. Yes.
Q. When Frank Cascio visited the property, would he be noted in that log as a visitor
spending the night?
A. Yes.

Q. On how many occasions, could you estimate, did Frank Cascio spend the night during
that five-year period? MR. SANGER: Im going to object as lack of foundation. THE
COURT: Overruled. You may answer. THE W ITNESS: Hundreds.
Q. BY MR. AUCHINCLOSS: Who is Vinnie? Do you know an individual -- let me start with
that. Do you know an individual who vis ited Neverland named Vinnie?
A. Yes.
Q. Who was Vinnie?
A. As far as I know, Vinnie was a friend of Frank.
Q. And do you know the period of time when Vinn ie visited Neverland?
A. No, not offhand I dont.
Q. Do you know approximately -- did Vinnie spend the night at Neverland?
A. Yes, I do know that he spent the night occasionally at Neverland Ranch.
Q. Do you know how many nights he spent?
A. No.
Q. Do you know an individual by the name of Marc Schaffel?
A. Yes.
Q. How do you know Mr. Schaffel?
A. Just from his coming to the ranch.
Q. Do you know how often he would visit the ranch? MR. SANGER: Vague as to time.
Q. BY MR. AUCHINCLOSS: During the period of time that you were a security guard.
A. Not very often, but he would come probably three or four times a year maybe.
Q. Do you know an individual by the name of Ronald Konitzer?
A. I know the name.
Q. Okay. Did you ever meet him?
A. Not that Im aware of.
Q. How about Dieter W eizner?
A. Yes.
Q. Did you meet Mr. Weizner?
A. Yes.
Q. Where did you meet him?
A. At the ranch.
Q. And if you can characterize, again Im asking for your best estimation, if you can
provide
it, how many t imes did Mr. -- did Dieter visit the ranch?
A. Several t imes. He was there -- he would stay sometimes for a couple of days, and then
hed be gone for a while and come back. It wasnt a regular thing that he was there. For a
short period of time it was, maybe two or three months I believe he was there on a
somewhat regular basis, but generally it was off and on.
Q. Can you characterize the period of time that you observed Dieter on the ranch in terms
of the five years you were there?
A. It would have been -Q. Beginning time to when you left.
A. Probably sometime in 2002 to 2003.
Q. Okay. Now, did you have occasion to see children visit the ranch?
A. Yes.
Q. How were children treated at the ranch?
A. Well.
Q. What do you mean by that?

A. It was a fun place to go. They got to do pretty much whatever they wanted, for the
most part. Not all of them. But they were treated quite well.
Q. Are you familiar with some visitors to the ranch who were local residents of Los
Olivos?
A. Yes.
Q. Do you know their names?
A. Um, I cant remember right now.
Q. How many were there?
A. Three.
Q. Were they boys or girls?
A. Boys.
Q. What ages?
A. Teenage.
Q. Were any of them related?
A. Two of them were.
4 Q. And how often would they visit the ranch?
A. For a short period of time quite regularly. MR. SANGER: Do you have numbers on
those? MR. AUCHINCLOSS: 45, 46, and 47.
Q. Mr. Barron, I show you Peoples 45. Does that look -- can you recognize that?
A. Yes, I recognize that.
Q. And who would that be?
A. His name -- their names are completely -Q. Is that one of the people youre talking about?
A. Yes.
Q. How about 46?
A. Yes.
Q. Is that one of the boys youre talking about?
A. Yes.
Q. 47?
A. Yes.
Q. Okay. Did you have occasion to see how those young men conduct themselves at the
Neverland property?
A. Yes.
Q. How would you describe their conduct?
A. Destructive.
Q. And why do you say that?
A. Whenever they were there, we had broken carts. Damaged carts. They at some point
egged --threw eggs at my security chiefs car, insid e, outside, were talking dozens of
eggs. There just always seemed to be something broken or some problem when they were
there.
Q. Do you know if they ever got in trouble for this type of conduct? MR. SANGER:
Objection; lack of foundation. THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: You mentioned a grease board at the security office.
A. Yes.
Q. And what specifically was that grease board used for?
A. Specifically it was for guest information, names of people who were in which guest unit
or where they were staying on the ranch. And then a pass-on board, just write notes on
the board for the oncoming shift or something that happened, just so that it was

remembered. Anything that we needed to remember on a daily bas is could have been put
up on that board.
Q. Who was your supervisor?
A. I had -- Violet Silva was the security chief, and then Curtis Gordon was a supervisor
and Julio Mag ana was a supervisor.
Q. Did you have any supervisorial capacity as security guard?
A. Yeah, I had a shift supervisor. Curtis and Julio would work generally day shift. And then
when I was there in the evening, I would be the shift supervisor. They were supervisors to
me, but I wou ld be in charge of the shift at night.
Q. Okay. At some point -- and let me just make -- be clear. What do you mean when you
say grease board?
A. A white -- a white board that you use the wipeab le ink markers on.
Q. Okay. So like a chalkboard or similar but you can -A. Similar, yes.
Q. -- but you can wipe the ink off?
A. Yes.
Q. At some point during your employment at Neverland, did you see a directive on that
board concerning Gavin Arvizo?
A. Yes.
Q. Do you know who Gavin Arvizo is?
A. Yes.
Q. First of all, tell us how you know Gavin Arvizo.
A. Because he was a guest at the ranch.
Q. Okay. So you knew him by sight?
A. Yes.
Q. And tell us what that directive was.
A. It simply stated, Gavin is not allowed off property.
Q. Can you tell me the approximate time that --your best recollection as to when that -when that directive appeared on the grease board?
A. It was early part of 2003, January, February.
Q. Do you know the exact date?
A. No.
Q. Do you know how long it was on the grease board?
A. I remember it being approximately a week.
Q. Okay. If Gavin Arvizo appeared at the front gate during this period of -- well, let me
back up, first of all. What did that directive mean to you in terms of a security officer?
A. That we werent to allow him off property without some sort of permission from a
supervisor.
Q. Okay.
A. That would be -- I would check first.
Q. Okay. So if Gavin Arvizo appeared at the gate, walking out of the ranch, would you let
him pass?
A. No.
Q. If Gavin Arvizo appeared at the gate being driven out by Jesus Salas, would you let him
pass?
A. I would check first with the ranch manager. Q. So would you say you wouldnt let him
pass before getting authorization?

A. No. MR. SANGER: Well -- Ill withdraw it.THE COURT: All right. MR. AUCHINCLOSS:
Thank you. I have no further questions.
CROSS-EXAMINATION BY MR. SANGER:
Q. Mr. Barron, how are you?
A. Good.
Q. Youre a sworn peace officer; is that correct?
A. That is correct.
Q. And you went to the Allan Hancock Po lice Acad emy?
A. Yes.
Q. And you have been a police officer, an act ive duty police officer with the Guadalupe
Police Depart ment for how long?
A. Six and a half years.
Q. And during the entire time that -- Im
sorry, during the entire past six and a half years consecutively, you have been a police
officer, correct?
A. Thats correct.
Q. So at no time during the last six and a half years have you not been a sworn peace
officer?
A. Correct.
Q. You worked at Neverland while you were going to the academy, correct?
A. Thats correct.
Q. And then after you finished the academy, you got a job with Guadalupe as a sworn
peace officer, correct?
A. Correct.
Q. And when was that?
A. The day I started with Guadalupe?
Q. Sure.
A. September 28th of 1998.
Q. Okay. So since September of 1998 to the present, youve been a sworn peace officer?
A. Correct.
Q. And sometimes you worked at Neverland Ranch as a security person as well; is that
correct?
A. Correct.
Q. So you were moonlighting, as it were?
A. Yes.
Q. And at some point you were aware that there was a raid on Neverland; is that correct?
A. Yes.
Q. Were you there that day?
A. No.
Q. After you learned there was a raid at Neverland, did you have a discussion with your
chief of police at Guadalupe?
A. Yes.
Q. As a result of that discussion with the chief of police, did you determine that you should
resign your position as a security guard?
A. Yes. It was more like step away from it for a while.
Q. Okay. In other words, between you and your chief, you decided theres an ongoing
criminal investigation, as a peace officer, you probably should not also be working at the

ranch; is that correct?

A. At that time thats what I decided, yes.
Q. And when was that, approximately? Was that right after the raid?
A. I was on vacation at that time, at the time of the search warrant. And then so shortly
after I came home from vacat ion.
Q. All right. So sometime maybe end of November?
A. What day was the raid?
Q. November 18th, 2003.
A. Yeah. Correct. I think I came home from vacat ion the last couple days of November, so
shortly after that. Maybe the first week of December.
Q. All right. And you did not cease your employment -- I was going to say quit, but you
actually stepped away for a while, you took a leave?
A. Yes.
Q. You did not do that because you had seen anything unlawful at the ranch; is that
correct?
A. Thats correct.
Q. And in fact, had you seen anything unlawful at the ranch from 1998 to the time that
you stepped away from the job, you would have been duty-bound to report that, correct?
A. Absolutely.
Q. And in fact, as a sworn peace officer, you probably -- if you saw a criminal activity, you
probably would have been duty-bound to either investigate or even make an arrest; is
that correct?
A. Yes. To a point.
Q. Okay. At the very least report it?
A. Correct.
Q. All right. And you had no -- you found no need whatsoever to do that the entire time
that you were there; is that correct?
A. Thats correct.
Q. The people at Neverland Ranch that you worked with were made aware that you were
a police officer; is that correct?
A. They all knew.
Q. All right. There was no secret?
A. No secret.
Q. And you were given access to every part of the ranch that any other security officer
was given access to; is that correct?
A. Thats correct.
Q. You reported, you said, to Mr. Magana and Mr. Gordon?
A. Correct.
Q. And then Violet Silva was the chief of security at the time; is that correct?
A. Correct.
Q. Did you have a good relationship with Violet Silva?
A. Very good.
Q. And was she a professional chief of security?
A. Yes.
Q. All right. Now, I know that a lot of times law enforcement might look at security guards
as --somewhat cynically, is that true?
A. Absolutely.
Q. Did you feel that this security department was run in a professional fashion?

A. Yes.
Q. To a certain extent, the security department included the use of various police
procedures; is that correct?
A. To a small extent, yes.
Q. General radio etiquette, for instance?
A. Yes.
Q. Making sure that you logged things in appropriately?
A. Correct.
Q. Did Violet Silva, for instance -- lets take her. Did Vio let Silva insist that the people
under her command, as it were, keep accurate records?
A. Yes.
Q. All right. Did Violet Silva insist that the people under her make sure that the various
places
on the ranch were secure?
A. Yes.
Q. And there was a regular detail, or a regu lar -- let me withdraw that. There was a
regular procedure to go through and check the various locations during the evening and
the night to make sure that the ranch was secure; is that correct?
A. Thats correct.
Q. Now, during the time you were there, was there a risk that intruders would get onto
the ranch?
A. Absolutely.
Q. Did any intruders get onto the ranch during the time that you were there?
A. Yes.
Q. Were there ever occasions that you were aware of that intruders actually got to the
house?
A. Yes.
Q. Did any intruders actually get into the house?
A. Yes.
Q. Were law enforcement officers called eventually to deal with those intruders?
A. Yes.
Q. In fact, that was the protocol, if you found somebody trespassing, to call for law
enforcement?
A. Correct.
Q. Now, I understand you were law enforcement, but you would call the sheriffs
department at that point, correct?
A. Yes.
Q. And I may be going a little fast and then youre kind of stepping on the end of my
questions, and I may be asking too quickly. It makes it hard for the court reporter.
A. I apologize.
Q. Thats all right. I apologize. Well just slow down a little bit, both of us. All right. Now,
you explained the situation out there and I just want to go over it in a little more detail.
There are basically two main security posts, stationary posts at the ranch; is that right?
A. Thats right.
Q. Theres the gate, which is the little house right by the big front gates, correct?
A. Correct.
Q. Now, at that little house, and the big front gates, theres -- or in the -- in the little
house theres a computer and a desk; is that correct?

A. Thats correct.
Q. Telephone?
A. Yes.
7 Q. Is the phone often answered by -- at that phone?
A. Yeah. A lot.
Q. All right. So people calling into the ranch, particularly at night, the phone will ring
there, and the security guard at that phone will answer it; is that correct?
A. Thats correct.
Q. All right. And then the phone -- the phone can be -- or the call can be forwarded from
that phone to other phones?
A. Any -- basically any phone on the ranch.
Q. And the phone thats at the gate is a regular telephone within that -- let me back up.
Theres a system and the phones are pretty -A. Its a multiline phone.
Q. Theyre pretty much identical phones throughout the ranch?
A. Yes. I believe theyre all the same.
Q. So this is -- this is not a big phone with a lot of buttons on it. Its a smaller phone; is
that correct?
A. Thats correct.
Q. So you get an incoming call and then you would forward it by using a code to fo rward
it; is that correct?
A. Transfer it to whatever extension it needed to go to.
Q. All right. The gates at the guard house there are big iron gates, is that correct, the
front gate?
A. Well, maybe on the inside. Theyre wood.
Q. Or wood gates. Im sorry, I think you are right. Theyre big wooden gates, in any
event?
A. Yes.
Q. And theyre anchored by, I think, stone walls on either side; is that correct?
A. Yes.
Q. If you stand at the gates looking out to Figueroa Mountain Road, to the road there, and
you were to go to the left of the guard house -A. Okay.
Q. -- as youre looking out to the left of the guard house, how far does the stone work
extend, roughly?
A. Maybe 20, 25 feet. 30 feet maybe at the max.
Q. Okay. And after that 30 feet, what kind of fencing protection do you have?
A. Very little. Two-plank ranch fencing. Its nice. It looks like -- but its maybe about
four feet tall.
Q. And two rails?
A. Two rails and then posts however many feet.
Q. And theres no wire on that or anything else, correct?
A. No.
Q. So people can pretty much hop over that if they want to?
A. Yes.
Q. All right. As you go around the rest of the ranch theres -- as you get farther away from
the gate, at some point theres some fencing, cattle-type fencing; is that correct?
A. Cattle, barbed wire fencing.

Q. All right. Now, you mention that there was another location which was up by the house,
I think, for -- another stationary locat ion for the guards; is that correct?
A. The house security office, correct.
Q. And thats not in the house itself?
A. No.
Q. Its at the end of the building thats adjacent to the house; is that correct?
A. Correct.
Q. And in there, you have a -- an initial room that includes a desk and the computer and
so on; is that correct?
A. Thats correct.
Q. And theres a rack of battery chargers for the portable radios?
A. It may be in that room, now. It was in the other room before when I was there.
Q. Okay. In any event, theres the initial room that you walk into, and then behind it is
sort
of a break room; is that correct?
A. Correct.
Q. Its got a few lockers; is that right?
A. Thats right.
Q. The break table and some chairs, right?
A. Yes.
Q. Is that where that board is that you were telling us about?
A. No. It was in the first room.
Q. In the first room. All right. Now, let me ask you something: The gate logs that you told
us about that are among the documents that you authenticated from Exhibit 300 to 335 -I realize theres some other documents that arent gate logs in there -A. Yes.
Q. -- but the gate logs that are in those documents, those gate logs are used to
commun icate information to the various guards who are on duty or who come on duty; is
that correct?
A. Yes.
Q. All right. Now, I realize -- or let me ask you this: You had previously told law
enforcement that you believed that this -- what you called or what Mr. Auchincloss called
a directive, that this note about Gavin Arvizo was on the grease board?
A. Yes.
Q. And are you aware that none of the other officers recall seeing it on the grease board?
MR. AUCHINCLOSS: Objection. That assumes facts not in evidence. T HE COURT:
Sustained.
Q. BY MR. SANGER: Are you aware of any other officer who claims to have seen that on
the grease board?
A. Yes.
Q. Okay. Is it possible that this particular notation was, in fact, on a gate log instead of
the grease board?
A. Im sure it was on a gate log.
Q. Okay. And in fact, its on the gate log for February the 19th; is that right?
A. I dont know the date that its on there.
Q. You remember seeing it on the gate log; is that correct?
A. No.
Q. Okay. You said it was on the gate log?

A. I now know that it was on the gate log.

Q. Okay. All right. Do you have the book up there, the --MR. AUCHINCLOSS: Its right
here. MR. SANGER: This is the official book. All right.
Q. Now, you say youre aware its on the gate log. Did somebody show it to you?
A. I was told.
Q. By the prosecution?
A. Yes.
Q. Okay. And who told you that?
A. The District Attorney.
Q. Which one?
A. Auchincloss.
Q. Mr. Auchincloss.
A. Thank you. Sorry. MR. SANGER: Okay. Your Honor, what Id like to do, Im going to
take this page out of the book, the entire book has been admitted, and there are exhibit
tabs, official court exhibit tabs on the first page of each exhibit. So I am taking a page out
of 334. And at the bottom, this page says MJ 00154. And Id ask permission to put this
up on
the screen, if I may. THE COURT: You may. MR. SANGER: Thank you.
Q. Ill back up, first of all. Ill represent to you I just took that -- as I said to the Court, I
took that out of the book here. Thats one of thevarious pages. Does that appear to be a
gate activity log?
A. Yes.
Q. And theres a number up on the top which well focus in on a little more. It says 2-1903. Its a little fuzzy there, but -A. Correct.
Q. And the purpose of this gate activity log would be to record pretty much
contemporaneously activities that occurred during the security shift; is that true?
A. Thats correct.
Q. And its also for the purpose of recording information that should be communicated to
other officers on other shifts; is that correct?
A. Yes.
Q. All right. Now, Im going to, with any luck, focus in so we can read it, but well see
about that. Okay. Do you see there, it says -- three lines up from the bottom, on the
midd le of the page, it says 1752.
A. Yes.
Q. What does 1752 represent?
A. 5:52 p.m.
Q. Military time. So its 5:52 in the afternoon, correct?
A. Correct.
Q. That would be the time that somebody recorded the information on that, on that line
adjacent to it; is that correct?
A. Correct.
Q. And the line adjacent to it says, The kids are not to leave per Joe. Kids meaning like
Gavin, Star, et cetera, correct?
A. Correct.
Q. All right. Were you aware that that particular evening was the evening that these
children were to go down to Los Angeles? MR. AUCHINCLOSS: Objection; assumes facts.
MR. SANGER: Thats --THE COURT: Foundation; sustained. MR. SANGER: Well, I asked if

he was aware. Should I rephrase it? Let me do it this way, Your Honor. I wont make that
request.
THE COURT: The foundations a little different, too. Go ahead and rephrase it.
Q. BY MR. SANGER: All right. Lets do it this way: A couple of questions. Just in general,
if children are on the ranch, are guests at the ranch and theyre staying there and theres
not a parent present, would it be the policy of the ranch not to allow those children to go
off of the ranch property without supervision?
A. Correct. MR. AUCHINCLOSS: Ill object as vague as to children.THE COURT:
Overruled. You may answer. THE W ITNESS: Yes, we would not let them go off the
property by themself.
Q. BY MR. SANGER: So at this time do you know whether or not there was a parent at
the ranch with Gavin, Star -- well, it was Gavin, Star, etcetera. So well say with Gavin
and Star.
A. I dont know for sure. I dont believe there was.
Q. All right. So that would be a reasonable instruction for security in general, correct? MR.
AUCHINCLOSS: Objection. Argumentative; calls for a conclusion.
THE COURT: Sustained on argumentative.
Q. BY MR. SANGER: It would not be out of the ordinary, then, to not let children such as
Gavin and Star leave the ranch without approval or without supervision, correct?
A. Correct.
Q. And based on your experience, if children or any guests were scheduled to leave as a
group, would it be appropriate for security to be alerted so that the people would be there
to leave in the vehicle that was assigned to take them? Does that make sense? It was a
long question.
A. Would it be appropriate to have security notified -Q. Yeah.
A. -- if they were going to be leaving?
Q. Yes.
A. It would have been appropriate. It didnt happen very often, but -Q. So if there was a bus or a limousine that was going to leave and certain kids were
going to be on it, thats something that security could well be advised of, correct?
A. Should well be advised of. We werent always advised.
Q. Werent always advised. But if you were advised, youd feel that was appropriate,
right?
A. Yes.
Q. Okay. Im going to put that page back where I found it. Close the book so I dont mix
things up, and well come back to it in a moment.All right. Now lets work backwards just
little bit here. You were asked about Frank Cascio, correct?
A. Correct.
Q. And was he also known by another name?
A. Frank Tyson.
Q. Frank Tyson. Okay. Frank?
A. Frank.
Q. As far as Frank Cascio, Frank Tyson was concerned, was he there -- you said he stayed
over, as far as you could tell, quite a number of times, right?
A. Right.
Q. And the District Attorney asked you if this was logged in the logs when he might be
staying over.

A. Correct.
Q. Did you go back and look at the logs and add up the times?
A. No.
Q. All right. So youre really not answering that question based on reviewing the logs; is
that right?
A. I reviewed the logs, but did not write down or memorize how many times hed been
there.
Q. All right. So your general impression was that he stayed overnight quite a number of
times, correct?
A. Yes.
Q. And did Frank Cascio have any other family members who you were aware of?
A. Yes.
Q. And did they often stay over?
A. Yes.
Q. Did his father come out and visit from time to time?
A. Yes.
Q. Did his brother and sister visit from time to time?
A. Yes.
Q. Any other family members you can recall?
A. His mother had been there.
Q. Okay.
A. I think he had two brothers.
Q. All right.
A. I believe.
Q. Very good. So his brothers, his sister, and both of his parents would stay over from
time to time; is that correct?
A. Yes.
Q. All right. Now, were there times during your -- your span there, when Frank Cascio or
his family might be there, and then there would be a period of time where he wouldnt be
around and he or his family would come back at some later time?
A. Meaning that -Q. That was a bad question.
A. Im sorry, I dont understand the question.
Q. Fair enough. Just tell me. In other words, you say he was there -- from the time that
you were employed to the time that you left the ranch, you said he was there many t imes,
maybe you saw him 75 to 100 times with Michael Jackson, he stayed over many times,
right?
A. Yes.
Q. Was this continuously or were there periods of time where the Cascios might be
visit ing, and then months might go by before theyd come back?
A. Yes, thats correct.
Q. And did -- you were yourself gone for
5 periods of time; is that correct?
A. Yes.
Q. You next had somebody named Vinnie. Did youknow his last name?
A. No, I dont know it.
Q. You said, well, he spent the night occasionally, I think. Do you know when that was?
A. The actual dates of when? Or --

Q. If you know them.

A. No, I dont know the actual dates of when.
Q. In general, when did you see Vinnie?
A. Generally I saw V innie when Frank was there.
Q. And when did you start seeing Vinnie?
A. Probably in 2002, right around there. I dont know the exact time frame.
Q. Maybe late 2002?
A. Could have been, yes.
Q. All right. So you didnt really see him theentire time that you were working there?
A. No.
Q. He was a more recent visitor?
A. Yes.
Q. Same with Marc Schaffel. You said he was not there -- or he did not spend the night
very often. You recall seeing him every once in a while?
A. Every once in a while. Granted I worked two, three days a week, so I wasnt there all
during the week.
Q. I understand.
A. But occasionally he was there, yes.
Q. And was he there continuously during a period of time or off and on, or two different
distinct periods of time?
A. I remember h im being there just off and on, odd times. He would just come out and -he may stay the night, he may leave that day.
Q. You mentioned Ronald Konitzer and you said you recognized the name, but you
couldnt really put a face to that name; is that correct?
A. I dont believe I could, no.
Q. You remember Mr. Konitzer being listed as a guest; is that correct?
A. Yes.
Q. You remember seeing the name anyway -A. Yes.
Q. -- in the context of being a guest. Do you remember Mr. Konitzers wife andchildren
being listed as guests?
A. I dont remember that, no.
Q. All right. Now, if they were guests, theres a good chance they would be in the guest
logs; is that correct?
A. Thats correct.
Q. And then you mentioned Dieter Weizner. You said you saw him visit ing several times;
is that correct?
A. Thats correct.
Q. And do you know when this period of time was? W as this the entire time from 1998?
A. No, it would have been later into when I worked there, probably around, again, late -mid, late 02, end of 2002, into 2003.
Q. Into 2003. Okay. Now, in general, besides intruders, which we talked about, actual
trespassers and people who intrude, were there other concerns for security on the ranch?
A. Meaning -Q. Well, for instance, was one of the concerns that this was Michael Jacksons home and
that his privacy should be preserved?
A. Yes.
Q. So there were confidentiality agreements that new visitors would sign when they came

to the gate; is that correct?

A. Correct. Correct. Im sorry, yes.
Q. I didnt know if the court reporter got it.
A. Im sorry.
Q. And one of the reasons for the confidentiality agreements was -- or one of the
provisions was that people not take pictures when theyre at the ranch; is that correct?
A. Thats correct.
Q. And you understood the reason for that to be that people would sell pictures if they
could; is that right?
A. I understood the reason to be we were told not to let them do it. What they did with
them is -Q. You understand that -- there was a concern about people getting cameras on the ranch
to take pictures to sell them to the tabloids?
A. Im sure that there was.
Q. And some of the intruders that you caught had cameras with them; is that correct?
A. Yes.
Q. Did you -- were you aware of an armed intruder getting onto the ranch?
A. Armed with what?
Q. With a gun.
A. No.
Q. The ranch itself you understood to be Mr. Jacksons home, right?
A. Yes.
Q. And one of the things that security was instructed to do was to accord Mr. Jackson
respect as a person who is trying to live in his home, correct?
A. Absolutely.
Q. So the idea was to not unduly approach him or burden him, or take up his time while
hes trying to -- while hes trying to be at home, correct?
A. Thats correct.
Q. And have you ever worked for any other celebrities or people of that sort?
A. No.
Q. But that made sense to you, didnt it?
A. Absolutely.
Q. All right. When you say that when Mr. Jackson was there people were on pins and
needles, did you mean by that to suggest that Mr. Jackson was a harsh or mean boss of
some sort?
A. No.
Q. Just -- the structure of the people there, through the various commands and different
departments, made everybody aware that when Mr. Jacksons on property that you need
to on your best behavior, right?
A. Yes.
Q. And you didnt see anything wrong with that, did you?
A. No. Not necessarily, no.
Q. Okay. And you felt personally that -- I suppose you probably felt you should be on your
best behavior at all times; is that right?
A. Yes.
Q. But you didnt have any objection to everybody being, you know, particularly careful to
be prepared and ready to perform their duties when the owner is on the property, right?
A. I had no objection to that. No.

Q. Now, you said people worked harder when Mr.Jackson was there, right?
A. They worked more, for sure.
Q. Okay. Now, theres sometimes Mr. Jackson was not there when there were b ig events
that were scheduled; is that right?
A. Thats correct.
Q. There were family days?
A. Yes.
Q. And youve gone to family days, have you not?
A. Several of them.
Q. Do you have family? I wont go into details. But did you bring family members with
you?
A. Yes.
Q. And this is something that Mr. Jackson did for his employees; is that right?
A. Thats right.
Q. Basically opened up the whole property, the employees could bring their children, their
friends or their close friends or relatives certainly, and could enjoy the rides and all the
other amenities at Neverland; is that right?
A. Thats right.
Q. Mr. Jackson would sometimes be there and sometimes not; is that right?
A. Thats right.
Q. And then there were other days when he would have large groups of either, for
instance, disadvantaged children or children who were sick or just children in general who
would come to be hisguest at the ranch; is that correct?
A. Thats correct.
Q. During those times, Mr. Jackson was often not on the property; is that right?
A. Often not on the property?
Q. Yes.
A. Thats right.
Q. And he was sometimes on the property; is that correct?
A. Yes.
Q. Whether he was on the property or not, the entire staff was instructed to treat all of
the
people, adults and children, as guests, as if they were guests at somebodys private
home; is that correct?
A. Thats correct.
Q. The only difference is that there would be certain boundaries, you cant go into certain
parts of the house and that sort of thing; is that correct?
A. Thats correct.
Q. But other than that, if the kids want something, if the adults want something,
everybody is there to serve; is that right?
A. Thats right.
Q. Now, you mentioned that the security guards often did the job of other -- let me
withdraw that. You mentioned the security guards worked with the fire department from
time to time; is that correct?
A. Basically they were the same department.
Q. All right. And you had at least one fire truck there?
A. Yes.
Q. Was there a time when you had more than one?

A. Well, there was a time when there was --when I was there, there was a time that there
was more than one, one was not working.
Q. Okay.
A. But there were two. And then prior to me being there, yes, there was, I believe, more
than one.
Q. Eventually they turned one of those fire trucks into a water truck, I think.
A. Water tender, yes.
Q. There you go. But they have one operating professional fire truck there; is that
correct?
A. Not in the sense -- fire rescue, like a brush truck. It would be not like a large city fire
truck. But, yes, a working -- held water, medical equipment.
Q. All right. Not a hook and ladder, but something that was an emergency vehicle -A. Yes.
Q. -- that could be used to tend to emergencies on this ranch, correct?
A. Correct.
Q. And anywhere from somebody being injured, to having a brush fire, to anything else
that was needed on an emergency basis; is that right?
A. Yes.
Q. And both the people who were assigned as security officers and those assigned as
firemen were somewhat interchangeable in these tasks. If it needed to be done, you all
would respond and do it; is that correct?
A. That is correct.
Q. Now, there were a number of people who were in the fire department from time to time
who eventually became employed in other fire departments; is that correct?
A. Yes.
Q. All right. So this was an area where people could work, gain addit ional experience in
order to go work someplace else; is that right?
A. Yes.
Q. And did you feel -- as a professional law enforcement officer, did you feel that the -that the operation was run professionally?
A. Yes.
Q. All right. Now, the duties of security and fire you said were pretty much merged. But in
addition to those duties, you also had duties to attend to the needs of guests and Mr.
Jackson, oranybody else who required some assistance on the ranch; is that correct?
A. Yes.
Q. And they were not always law enforcement duties or fire duties, correct?
A. Generally, no.
Q. Generally not. So, if somebody needed something, you or anybody else that worked
there -- say a guest needed something, you or anybody else that worked there was
expected to respond as favorably as possible; is that right?
A. Yes.
Q. All right. THE COURT: Counsel? Take our break. MR. SANGER: Okay. Thank you.
(Recess taken.)
Q. Across the street from Neverland on Figueroa Mountain Road, there are two schools; is
that correct?
A. Thats correct.
Q. What kind of schools are they?
A. One is a boarding school, and one is like a -- an elementary school, I believe.

Q. Okay. And are these private schools?

A. Yes.
Q. People are there during the day?
A. Yes.
Q. So theres activity, at least during the school year; is that correct?
A. Correct.
Q. All right. February and March of 2003, those schools would have been open; people
would have been there?
A. Yes.
Q. Parents coming and going?
A. Yes.
Q. Teachers?
A. Yes.
Q. Administrators?
A. Yes.
Q. Now, you told us about the security staff that you were a member of, correct?
A. Correct.
Q. And you told us about the fire department?
A. Correct.
Q. Did Mr. Jackson also have personal security or personal bodyguards?
A. Yes.
Q. And are these people who traveled with him?
A. Yes.
Q. You did not travel with Mr. Jackson; is that correct?
A. No.
Q. So your duties were pretty much restricted to the ranch. I shouldnt say restricted. Its
a big ranch, but you were there at the ranch, correct?
A. Yes.
Q. If he went to Los Angeles or Miami or went on tour or anything else, you would not go
with him; is that correct?
A. No.
Q. And who would go with him?
A. Whomever was his personal security at the time. It did change.
Q. All right. So he did have people who were generally experienced in going on the road
and protecting a celebrity under those circumstances; is that correct?
A. There were times when he did, yes.
Q. Okay. There were some times when you thought his personal security may not have
been A. Yes.
Q. -- quite as -- okay. All right. Now, do you remember Janet Arvizo?
A. I know she was there. I do not remember her face until yesterday.
Q. All right. But you remember her being there and you rememb er having some contact
with her; is that correct?
A. Yes.
Q. And you remember Gavin Arvizo?
A. Yes.
Q. You remember Star Arvizo?
A. Yes.
Q. And in general, did Janet Arvizo ever appear to not want to be at the ranch?

A. In general, I couldnt answer. MR. AUCHINCLOSS: Objection. Im going to object on the

basis of foundation. THE COURT: Sustained.
Q. BY MR. SANGER: All right. Would it be your opinion, based on your seeing her there
at the ranch, that what stood out in your mind was that Mrs. Arvizo appeared that she
wanted to be there? MR. AUCHINCLOSS: Objection. Same objection. THE COURT:
Sustained.
Q. BY MR. SANGER: All right. What kind of contact did you have with Janet Arvizo?
A. Probably talked to her on the phone once or twice. Other than that, relatively none.
Q. When you talked to her on the phone, did it appear that she wanted to be there at the
ranch?
A. Yes.
Q. And Janet Arvizo had access to the house, full access to the house; is that correct? MR.
AUCHINCLOSS: Objection. Foundation. THE COURT: Overruled. You may answer. THE
WITNESS: I dont know.
Q. BY MR. SANGER: Okay. Do you recall testifying before the Santa Barbara Grand Jury
on April the 12th, 2004?
A. Yes.
Q. Do you recall telling the grand jury that Janet Arvizo was one of the people who had
access; she would have access to the house?
A. Yes.
Q. And when you were -- when the District Attorney said, Okay, you said, No question.
A. Yes.
Q. Is that correct? And she had full access to the house because her children were there;
is that correct?
A. Yes.
Q. All right. Now, did you have any personal observations about the behavior of Gavin and
Star?
A. No.
Q. They appeared -- from what you could see, they appeared to want to be at the ranch;
is that correct? MR. AUCHINCLOSS: Objection. Foundation. THE COURT: Sustained.
Q. BY MR. SANGER: Did you see them from time to time at the ranch?
A. Seldom.
Q. Was there any indication -- from the seldom times that you saw them, was there any
indication that they did not want to be at the ranch?
A. No.
Q. You indicated that part of the security --part of securitys job was to monitor who was
coming onto the property, correct?
A. Correct.
Q. And that was recorded, to a large extent, in the gate logs; is that correct?
A. Yes.
Q. Were you aware that in addit ion to just plain interlopers, that there would be people
who would try to gain some kind of introduction to Mr. Jackson to get into his favor? MR.
AUCHINCLOSS: Objection. Ambiguous; foundation. THE COURT: Overruled. You may
answer.
THE WITNESS: How do you mean?
Q. BY MR. SANGER: Well, were there people who seemed to be trying to get close to Mr.
Jackson?
A. Yes.

Q. And sometimes Mr. Jackson really wouldnt want those people to be around him,
correct?
A. Correct.
Q. So if they were allowed on the ranch, they were to be treated courteously?
A. Yes, yes.
Q. But nevertheless, you were to try to help Mr. Jackson not be bothered by people; is
that right?
[A. Thats right.
Q. And Mr. Jackson, of course, during the time you were there, and now, for that matter,
is an international celebrity, an artist, a very well-known person, correct?
A. Yes.
Q. And there would be people who would basically be trying to get into his good graces; is
that right? MR. AUCHINCLOSS: Objection. Foundation. THE COURT: Its argumentative.
Sustained.
Q. BY MR. SANGER: All right. Now, let me ask you one other thing before we get to the
gate logs and some of the other documents you identified. You were actually asked -- let
me put it a different way. You were contacted by the Santa Barbara County Sheriffs Office
in December of 2003; is that correct?
A. Thats correct.
Q. And in particular, Detective Bonner of the Santa Barbara Sheriffs Department
contacted you; is that correct?
A. Correct.
Q. And he did an interview of you to determine if youd seen anything unlawful and so on;
is that correct?
A. Thats correct.
Q. But then he asked that you work as an informant; is that correct?
A. Yes.
Q. And you were at that time a sworn peace officer of the Guadalupe Police Department ,
correct?
A. Thats correct.
Q. And he basically wanted you to go back to work for Mr. Jackson in December of 2003 to
be an informant, correct?
A. Thats correct.
Q. And at that time, you know that the raid had already occurred on Mr. Jacksons house,
correct?
A. Correct.
Q. You knew Mr. Jackson had a lawyer, had counsel, right?
A. Yes.
Q. And you were being asked to go in as a law enforcement informant into his ranch, at
his home, and inform for the sheriff; is that correct? MR. AUCHINCLOSS: Objection. Asked
and answered. THE COURT: Overruled. You may answer. THE WITNESS: Yes.
Q. BY MR. SANGER: And you refused to do that; is that right?
A. Yes.
Q. What Id like to do now is go through some of the exhibits that youve identified and
ask you, based on your training and experience, to interpret the documents, okay? To the
extent you were there, you made an entry, and then you can contribute that as well and
say, Yes, I actually wrote that.
A. Yes.

Q. But to the extent that you introduced these documents, you said they were kept in the
ordinary course of business, Id like you to explain what they mean, if you could.
A. Okay. MR. SANGER: So Im going to start with Exhibit 300, and, Your Honor, if this
procedure is acceptable, Id like to do this without asking each time -- or I can. W hatever
the Court wants me to do. What I propose to do is identify the document by exhibit
number. If there is more than one page to the exhibit, Ill indicate which page of the
exhibit. If -- in the Exhibits 334 and 335, there are hundreds of pages, so Ill refer to the
Bates stamp number on the bottom of the page for that purpose. And if that procedure is
acceptable, what Id like to do then is put each of these up on the -- not all of them, but
each of the ones I want to point out on the overhead projector, and Ill just make
reference to it at the time. THE COURT: Thats a fine procedure.MR. SANGER: Okay.
Thank you. In other words, I wont ask leave each t ime. Ill just do it. THE COURT: Thats
good. MR. SANGER: Thank you. Okay. In that case, with the Courts permission in
advance, Ill put Exhibit 300 up. THE BAILIFF: Can you put Input 4? MR. SANGER: Or
well put up Mr.Auchinclosss....THE COURT: That was Input 4.
Q. BY MR. SANGER: What Im going to do, I hope, is put it up in a way so we can show
the exhibit tag number, if such exists, and then Ill g ive you an opportunity here to see
what the document is, best we can. If you want me to -- this was printed pretty large, so
we can do it this way, if you want me to scroll it up or down. If youd like me to approach
and give it to you, if you cant read it, Ill just walk up and show it to you. So just let me
know.
A. Okay.
Q. This is Exhibit 300. And it appears at the top to be an accident damage report, okay?
A. Okay.
Q. And I think you told us that was kept in the ordinary course of business; is that
correct?
A. Correct.
Q. And the accident damage report appears to have been generated on a computer; is
that right?
A. Correct.
Q. In other words, its not just a form thats handwritten in, but somebody generated the
whole thing on a computer, correct?
A. Yes.
Q. And the format is such that it appears to be a standard format, and then you put in
particular information based on the particular incident; is that correct?
A. Thats correct.
Q. All right. Now, what would be the purpose of this particular accident damage report?
Let me rephrase that. What does this accident damage report refer to?
A. One of the golf carts. Q. All right. And from that report and from the records, and based
on your training and experience, can you explain what happened and why this report was
written?
A. I can read it.
Q. Okay. Well, lets do it this way, because well start this way and then the other ones
will
speak for themselves. Theres a date up there at the very top, right?
A. Yes.
Q. 6-21-02.
A. Yes.

Q. Would that be the date of the incident?

A. Yes.
Q. And then you have a date at the bottom. Would that be the date the report was
written?
A. Yes.
Q. And theres a time, 1610, so 4:10 in the afternoon, correct?
A. Correct.
Q. And the time at the top would be 1530, which would be 3:30 in the afternoon, correct?
A. Correct.
Q. All right. So this report is designed to document the fact that Gavin Arvizo was involved
in crashing a golf cart into the theater fountain; is that correct?
A. Thats correct.
Q. And the cause of the accident was recorded as reckless driving; is that correct?
A. Thats correct.
Q. All right. Now, you told us that youre supposed to be very courteous to the guests, no
matter who they are, where theyre from or whatever. Is it appropriate, however, for
security officers to warn guests, particularly children, if theyre involved in unsafe
behavior?
A. Yes.
Q. And based on this report, does it appear that there was a warning given to Gavin
Arvizo about driving the golf cart?
A. Yes.
Q. And the warning was to slow down or the golf cart would be taken away; is that
correct?
A. Correct.
Q. So based on your experience in these records, that would indicate that an officer gave
that warning to Gavin Arvizo?
A. Yes.
Q. All right. Were you aware of other incidents involving Gavin or Star Arvizo that involves
destruction of property or accidents or that sort of thing?
A. No.
Q. Okay. Did you review these records to see if you could find such evidence?
A. Not for that purpose, no.
Q. Okay. Thats fair enough. Actually, I d idnt see that. I dont think it was on my copy.
Maybe it was. On the back of 300 is a photograph. Does that appear to be a Polaroid-type
photograph?
A. Yes.
Q. Is that the front of a golf cart?
A. Yes.
Q. And it kind of looks like a car.
A. Well, you couldnt hold golf clubs on them. Theyre more of a car.
Q. Its essentially the frame of a golf cart and its got a little fiberglass car body on it?
A. Correct.
Q. And this one, I think, is the Batmobile one; is that -A. We call it the Batman cart.
Q. The Batman cart, okay. In any event, this photograph is taken to show damage that
was associated with that report; is that correct?
A. Thats correct.

Q. Im going to go to Exhibit 301.And just so nobody gets too nervous, Your Honor, Im
going to try to -- Im going to keep these in order, but its too hard to put them back on
the sprocket there, and Ill do that when were through, if thats all right. THE COURT:
Yes. MR. SANGER: 301 consists of a number of pages. And in the book, I would say its
page four.Its the back of the second sleeved page. No, Im sorry, its the back of the first
sleeved page, so it would be page two, I suppose. And let me put this up, if I may. Do you
want to see it first? MR. AUCHINCLOSS: Uh-huh.
Q. BY MR. SANGER: All right. Exhibit 301 is the front, and then the back of the sleeve is
the next page. And well use this document for the purpose of orienting everybody to the
way this works. At that time, there was a form that looked like this, correct?
A. Correct.
Q. And that form was changed slightly as time went on; is that correct?
A. Yes.
Q. But essentially youve got -- at the top, you have the blanket Routine Authorized
Entries. Thats people who might be making deliveries, that sort of thing; is that correct?
A. Thats correct.
Q. I see up there, for instance, Santa Barbara Surfacing. Looks like somebody may have
been thereto do some surfacing work on the roads; is that correct?
A. I dont know what they were doing, but, yes.
Q. Okay. Just as an example, all right. And then I see -- looks like it says Santa Ynez
Ford.It is a little hard to see.
A. Santa Ynez Feed.
Q. That would make more sense. Santa Ynez Feed. That would be, for instance, you
would assume somebody came on at 11:30 to deliver some feed, and by 11:57, or
whatever that says, they went back out the gate, correct?
A.Correct.
Q. And the in-and-out times on this are recorded at the time somebody comes in the gate,
right?
A. Yes.
Q. And the time they leave, right?
A. Yes.
Q. So when somebody comes in the gate, the gates are opened if theyre allowed to have
access?
A. Right.
Q. They stop the car or the truck right there by the guard house, correct?
A. Right.
Q. And the guard comes up and greets them?
A. Yes.
Q. And will write down who the person is and write down the exact time that it is at that
moment; is that correct?
A. Yes.
Q. And when they leave, the same thing occurs in reverse. Theyre stopped before the
gate. The guard will record whos in the vehicle and the time that theyre leaving; is that
correct?
A. Well, yes. We would make sure its the same person, and then we wouldnt record their
name again, but we would just record their time out.
Q. Their time out, okay. So if somebody came in with three people and only left with one,
youd want to know about that?

A. Yes.
Q. All right. Now, we have the guest names down there. And guests would be people who
are guests of the owner staying at the ranch, correct?
A. Correct.
Q. And they might be guests who stay all day and they might be guests that are coming
and going that same day; is that correct?
A. Thats correct.
Q. All right. Now, I dont know if its the glare or what. Its a little hard to read. Can you
read it from there?
A. For the most part.
Q. Okay. R ight at the top of Guests, it says, Grace; is that correct?
A. Yes.
Q. And it says, C/O. And that means?
A. Carried over. They were carried over from the previous 24-hour period.
Q. So, in other words, theres no entry time for Grace, because Grace was already there?
A. Already there at midnight the night before. This was prepared at midnight the night
before.
Q. And theres no indication that Grace left, so one would assume that she would still be
there the next day?
A. At midnight of this day, this would be completed, and that CO, carry-over, would be
put in the out box. So she would continue to be carried over for the period.
Q. So lets look down the list. And the third person on the list appears to have gotten
there at 1205; is that correct?
A. Correct.
Q. And that would be five minutes after noon; is that correct?
A. Correct.
Q. And then left at 1440 hours, which would be 2:40 in the afternoon; is that correct?
A. Yes.
Q. Can you tell me who that person is?
A. I cant read that. MR. SANGER: All right. May I approach with a copy? THE COURT:
Yes.
Q. BY MR. SANGER: Now that you have it in front of you, can you read the name?
A. Yes.
Q. What does it say?
A. M. Bashir.
Q. So Mr. Bashir came there at five minutes after noon and left at about 2:40, or left at
exactly 2:40, correct?
A. Yes.
Q. Let me leave that with you just for the moment, just in case you have trouble read ing
the rest of it.
A. Uh-huh.
Q. On that same day, it appears Chris Tucker arrived; is that correct?
A. Yes.
Q. And Chris Tucker arrived at?
A. 1500, or 3 p.m.
Q. So 3 p.m. And it appears that at the same time Chris Tucker arrived, a numb er of other
people came through the gate; is that correct?
A. Yes.

Q. And those people include Gavin Arvizo?

A. Yes.
Q. Star Arvizo?
A. Yes.
Q. There are a couple of other people there, and then I think there are three other people,
and then theres something that says, Gavellin. Or what do you think it says?
A. Well, it looks like maybe Aubrey.
Q. Below that. Right below that.
A. Gavel -- yeah, Gavellin. I --Gavellin.
Q. Gavellin. Do people always get the spelling right at the gate?
A. Not always, no.
Q. Okay. You try your best, but sometimes you just spell it the way you thought you
heard it?
A. The way it sounds, yeah.
Q. All right. So those people, plus Adrian, Kelly Bond and Aubrey, or Audrey, whatever
that says, all those people seem to have come at three 7076 oclock on the dot, correct?
A. Yes. Q. All right. Now, it appears that Mr. Tucker
4 and the Arvizos did not leave -- and Ill ask you to assume, just for the sake of this
question, that Gavellin is an Arvizo. But those three people came at three oclock and
they did not leave that day; is that right?
A. Correct.
Q. All right. Let me retrieve my book, if I may. Thank you. I guess I was asking
permission of the Court to approach there, to be specific. Im now going to go to Exhibit
302, and this would be what appears to be the third page of 302 in the exhibit, the official
exhibit book. So this does not have a tag on it, but the first page does. And Im sure I
would be corrected if I were wrong. This is 302 Im putting up, the third page. So lets
start up here, first of all. This is on 6-22, the date following the day that we just saw; is
that correct?
A. Yes.
Q. And we look down here, and we see that it appears that Chris Tucker, Gavin, Star, and
the other people we talked about, and then this Gavellin, all show that they are carried
over; is that correct?
A. Correct.
Q. And theyre carried over not only from the day before, but they appear to be carried
over to the next day.
A. Correct.
Q. And if we look at 303 -- and well take pag e two of 303. Its on the back of the
envelope here. So thats 303, and Ill turn it over, and thats the guest names. And once
again, Chris Tucker, Gavin, Star, and Gavellin are all carried over as guests; is that
correct?
A. Correct.
Q. And Im sorry, thats the next day, 6-23; is that correct?
A. Yes.
Q. We go to 304, Exhibit 304. Looking at page two of 304, page two, 6-24-02?
A. Yes.
Q. And again, we show Chris Tucker, Gavin, Star and Gavellin all carried over; is that
correct?
A. Yes.

Q. And it doesnt show any check-out time for them or any time they went by the gate; is
that correct?
A. No. Thats correct.
Q. And then 305, this would be the third page, 6-25-02. And it shows Chris Tucker, Gavin,
Star. And I dont see Gavellin on there or Davellin or anyth ing else like that. But it
shows that Chris Tuckers group left at 7:54 in the morning; is that correct?
A. Correct.
Q. So they would have been there overnight and then they left together?
A. Correct.
Q. Okay. Now, if we skip ahead timewise to --its Exhibit 306, and its page two of 306, it
says6-29-02 on the top, and it appears that Gavin, Star, and Davellin, or Davellin, and a
limo driver all showed up at 46 minutes after midnight; is that correct?
A. Correct.
Q. And Gavin, Star and Davellin all stayed there overnight that day, correct?
A. Correct.
Q. And the limo driver got a cup of coffee and left, looks like.
A. Yes.
Q. Okay. And then going to Exhibit 307, about 6-30-02, we have Gavin, Star and Davellin
all staying overnight at the ranch, correct?
A. Correct. MR. SANGER: All right. Excuse me just one second. (Off-the-record discussion
held at counsel table.) MR. SANGER: Excuse me, Your Honor. sorry. I just had to clear
something up.
Q. Okay. I want to -- just because its in sequence in the exhibits, let me show you 308,
and this is a different kind of a form. And well be ab le to go a lot quicker here. And
actually, well skip quite a ways ahead in a moment, just so everybody has something to
anticipate. 308, okay, and Ill try to get as much of a wide angle as I can and still read it.
Do you see that? It says, Security Clearance and General Informat ion?
A. Yes. Guest Information.
Q. Or, Im sorry, I cant read it. All right. I can read it here. Guest Information.And this
is informat ion about the people who were arriving. And actually, this dates back a little out
of sequence. It dates back to 6-21-02, correct?
A. Correct.
Q. And basically this is information so you know how to treat the guests and what they
can do; is that right?
A. We know whos coming and what theyre able to do.
Q. Okay. So this tells you the estimated time of arrival; is that correct?
A. Correct.
Q. And you never know exactly if somebodys going to arrive on time, but it gives you a
heads-up, right?
A. Right.
Q. And it shows Chris Tucker, Gavin Arvizo, Star Arvizo, Adrian, Kelly, Gavellin and
Aubrey, it looks like. So on 6-21, this was telling you these people are really going to
show up, right?
A. Yes.
Q. And then at the bottom, it says Mr. Jackson has cleared the guests to have full access,
correct?
A. Correct.
Q. So Chris Tucker and his guests are allowed to have full access to all of these activit ies;

is that right?
A. Thats right.
Q. And those activities include the hill house, pool, spa, water fort, dance studio, and then
quad runners; is that right?
A. Yes.
Q. And what were the quad runners?
A. ATVs.
Q. Were people supposed to keep those on the property?
A. They were property of the ranch.
Q. But, I mean, they werent supposed to go drive on Figueroa Mountain Road.
A. Correct.
Q. And they definitely were not supposed to go into Los Olivos.
A. No.
Q. All right. And then theres scooters, right?
A. Uh-huh.
Q. Golf carts?
A. Yes.
Q. Jet skis. The main house. And written in is horseback riding?
A. Yes.
Q. So Mr. Jackson, according to this record, kept in the ordinary course of business, had
cleared the guests to have full access to all of those activities?
A. Yes.
Q. And those guests would be Mr. Tucker and the Arvizos and his other guests; is that
correct?
A. I believe Mr. Tucker, there, says he was the driver. Whether or not he had access to
that stuff at the same time, probably, but -Q. Do you know who Chris Tucker is?
A. Yes.
Q. Okay. Who is Chris Tucker?
A. He was an employee of the ranch.
Q. Okay. Are you thinking -A. Or of Mr. Jackson.
Q. Are you thinking of Chris Carter? 7082
A. Im sorry. Chris Tucker. Excuse me. I apologize.
Q. Chris Tucker is the actor?
A. Chris Tucker is the actor, yes. Im sorry.
Q. Do you remember him visit ing the ranch?
A. Yes.
Q. And you would assume Chris Tucker would have -A. Chris Tucker, Im sorry. Thank
you.
Q. He would have full access to -A. Yes, he would.
Q. All right. Now, if we go to Exhibit 309, you may recall -- lets show 309. There we
go.You may recall that when we went through the gate logs, it appeared that Gavin, Star
and Davellin came back and Mr. Tucker was not there; is that correct?
A. Correct.
Q. Now, when they came back this time, theyre estimated to arrive sometime in the
evening. And if Im not mistaken, I think they got there very early in the morning the next

day. But here, Mr. Tucker is not there. They were not cleared for the quad runner or the
jet skis; is that correct?
A. Yes.
Q. And they were not cleared for horseback riding; is that correct?
A. Correct.
Q. Based on your experience and understanding of these records kept in the ordinary
course of business, who would have given those instructions?
A. Those instructions there?
Q. Yes.
A. They would -- this would have come to us through the administration office.
Q. All right. So somebody in the chain of command above decided that, under these
circumstances, that these children should not have access to the quads or the jet ski?
A. Correct.
Q. All right. Well go to Exhibit 310. And this will be the second page of 310. And it
appears that -- 7-1-02. And it appears that Gavin, Star and Davellin stayed overnight,
correct?
A. Correct.
Q. And then they left at 2114 hours, which would be 9:14 in the evening, correct?
A. Correct.
Q. Now, then we skip ahead in time to September the 15th, which is the next record in
the exhibit book which was presented to you by Mr. Auchincloss. And that shows 9-15-02;
is that correct?
A. Thats correct.
Q. And on 9-15-02, we have Chris Tucker, Gavin, Star, sister, it looks like it says Chriss
nephew; is that correct?
A. Correct.
Q. Theres a star there. What does that mean?
A. Probably means that the time was either not written down when they came in, or it was
-- at that time, whomever was checking people in the gate failed to write them in, or we
just didnt know when they came in.
Q. Okay. So every once in a while somebody makes a mistake, true?
A. Yes.
Q. That will happen. And then it shows on that day, which is 9-15-02, Mr. Tucker and his
group, including Gavin, Star, sister, and Chriss nephew, all stayed overnight; is that
correct?
A. Correct.
Q. Im going to go to Exhibit 312. 9-16-02. And here we have a record that Chris Tucker
and his group stayed overnight. It also shows bus driver,correct?
A. Yes.
Q. Do you remember if Chris Tucker had a bus?
A. I dont know if he personally had a bus. I dont remember.
Q. Well, looks like the bus driver left with Chris Tucker and the rest of the party at 6:54 in
the morning; is that correct?
A. Yes.
Q. Now, do you know if Mr. Jackson was at the ranch at these various times that weve
covered so far?
A. I dont know.
Q. Okay. Now, 9-26 -- Im sorry, this would be Exhibit 313, the second page. 9-26 at the

top, 02. And I think you can read this, but if you cant, just tell me. I dont know if I made
it better or worse. Okay. All right. Looks like Martin Bashir arrived at two oclock in the
afternoon and left at 6:13; is that correct?
A. Yes.
Q. And it looks like he probably arrived with some other people there. Theres three other
people, correct?
A. Correct.
Q. We see -- we see Gary Hearn arrived at 2:30; is that correct?
A. Yes.
Q. All right. Looks like somebody adjusted that, but that was the way it was entered at the
time; is that correct?
A. Correct.
Q. All right. And it looks like -- now, first of all, Gary Hearn is who?
A. Garys a driver.
Q. Hes a driver for Michael Jackson and for Neverland; is that correct?
A. Yes.
Q. He often drives a limousine or whatever car is appropriate to transport people,
correct?
A. Correct.
Q. And Gary Hearn seems to have arrived with
7 Gavin, Star, and Davida or Davila or something, whatever that says, right?
A. Yes.
Q. All at the same time. And then it appears that they were there from 2:30 and stayed
overnight; is that right?
A. Correct.
Q. And then Im going to put up 314, the second page. And it shows Gavin, Star, and
Davida - I think thats what it says - stayed over that night as well, correct?
A. Correct.
Q. And then Im going to put up 315, page two, for 9-28, okay? Im going to go down to
the bottom, and it looks like Gavin, Star, and Davida, or whatever that says - all right? stayed overnight, but they left at four oclock in the afternoon; is that correct?
A. Thats correct.
Q. And it appears that Gary -- down at the bottom, thats probably Gary Hearn; is that
correct?
A. Most likely, yes.
Q. And Gary Hearn came and went, but he came in about three oclock, and then left at
exactly four oclock; is that correct?
A. Yes.
Q. So based on that, you would assume that he drove the -- Gavin, Star, and whoever
Davida is; is that correct?
A. Yes.
Q. And it looks like it -- its really hard to see what that says there, but it does look like
theres an entry, and I just want to clarify it so I dont get confused. It says something
like Maxim Bahit?
A. Your guess is as good as mine.
Q. All right. Its not Martin Bashir,though?
A. It doesnt look like Martin Bashir to me.
Q. All right. Now, if somebody checks out --in other words, I say checks out. If

somebody goes through the gate, out, and then they go to dinner or to town or whatever,
and they come back, when they come b ack, they should be logged back in again with the
time?
A. Yes.
Q. Does that sometimes not happen?
A. For employees? Sometimes.
Q. For anybody.
A. Yeah, Im sure theres times when it happens.
Q. All right. Now, Im going to skip way ahead, and you guys are going to be happy to
hear that, to Exhibit 331. Okay. Im sorry. Better yet, 333. And Im going to put 333 up.
This is the second page of it. And theres a -- wide angle here. Okay. A medical report log;
is that correct?
A. Correct.
Q. And that logs in various medical emergencies or skinned knees or anything else that
happens that requires somebody to respond?
A. Each medical report for the year.
Q. And on the other side, actually the front side of 333, theres a medical report for Star
Arvizo; is that correct?
A. Yes.
Q. Can you read that?
A. Not well. Actually, that really hurts my eyes. If you could bring it up, that would be
great.
Q. Actually, I dont blame you. May I approach, Your Honor? THE COURT: Yes.
Q. BY MR. SANGER: Im giving you a copy of that page. Can you take a quick look at it
there? And what I want to ask you is, basically, does this document reflect that Star
Arvizo apparently had a fall on a scooter, slid on some loose gravel or something?
A. Yes.
Q. And he had minor scrapes to his left knee, right ankle and right knee?
A. Yes.
Q. So that sort of thing was documented carefully at Neverland, and thats an example of
it; is that right?
A. Yes. MR. SANGER: All right. May I approach to retrieve that, Your Honor? THE COURT:
Yes.
Q. BY MR. SANGER: All right. Im now going to go to Exhibit 334. For the benefit of the
Court and everybody else, its probably about 90 pages, and so this is a part where Im
going to refer to -- Ill just put the first page up so we can see it here, 334, and its again
one of the logs, which I believe here actually starts February 1 of 03, correct?
A. Yes.
Q. All right. And now Im going to refer to a Bates stamp number, which is a number in
the lower part of the document, generally the lower right corner, and I believe in all of
these it starts out with MJ and two zeroes and then a number. And I will refer to that so
were on the same page. THE COURT: Okay.
Q. BY MR. SANGER: And Im going to skip to page 116. Thats MJ00116. And Im going
to show you this here. Now, this appears to be the format that was being used in 2003; is
that correct?
A. Correct.
Q. And I think its a little different, at least a little different than some of the forms that
were used because under Guest Information you also have Ranch Vehicle Information

-A. Yes.
Q. -- showing when people come in and out. On this particular document -- oops, sorry.
Lets try here. This is for February the 6th, 2003; is that correct?
A. Correct.
Q. And it appears that at 2243 hours -- lets see. 2245 hours, it should be 10:45 at night,
it says, Owner and guests; is that correct?
A. Yeah. Could I see that page? I -- I would assume it does. MR. AUCHINCLOSS: May I
see that? MR. SANGER: May I approach? THE COURT: Yes. THE WITNESS: Based on the
paperwork that we fill out, we would not have put owner orMr. Jackson or anything
that would represent him on this paperwork. In the time that I worked there, I have never
done that, that I can remember. It could be -- it could be, Owner and guest, which I
didnt write it, but definitely could be.
Q. BY MR. SANGER: Okay. Thats fair enough. Ill ask you about that a little more so it
makes sense. MR. AUCHINCLOSS: Could I see that again? MR. SANGER: Sure.
Q. This is Mr. Jacksons home, right?
A. Correct.
Q. And so you were not -- not only not required to, but you were really not supposed to
write down Mr. Jackson comes and goes and log him in like somebody else; is that right?
A. That is correct.
Q. Okay. You saw what you thought said, Owner and guest, may have said, Owner and
guest, youre not sure -A. No.
Q. -- but it would not be typical for you to write down Owner?
A. Ive never done it. The whole time I was there, Id never done it.
Q. Thats fine. And it does -- it looks like it says, Guest.
A. Yes.
Q. All right. It doesnt say who the guests are?
A. No.
Q. And thats somewhat unusual, isnt it?
A. If someone had come in with Mr. Jackson, we dont routinely stop his vehicle and look
in his vehicle. Again, its privacy for him. We try to bother him as little as possible. So if
someone had -- if that is Owner and guest and someone had come with him, we would
not have just stopped his vehicle and, for the most part, asked who was in there, unless
we really felt it was necessary. MR. SANGER: Do you want to leave that on? MR.
AUCHINCLOSS: Yeah. MR. SANGER: Okay. All right. I wont put it here. Ill --MR.
AUCHINCLOSS: Yeah, thats fine.
Q. BY MR. SANGER: I want to see if we can reconstruct this a little bit. Where it just
says, Guests, there are no names?
A. Correct.
Q. So does that suggest to you that those guests were probably in a vehicle with Mr.
Jackson?
A. It could have -- yes, it could have been.
Q. All right. And now were going to go to --and Im sorry, that was on 2-6, February 6,
2003, correct? Ill put it up again if you want.
A. Yes. Thats correct.
Q. All right. February 6th, 2003. Do you know if Mr. Jackson was returning from Miami
that night?

A. I dont know.
Q. Okay. All right. And youre welcome to look at this whole exhibit, if you want me to
bring the book down so you can see it, if you feel you need to look at the pages in order
or anything, okay? Im going to put up 2-7-03, which is MJ00120. And that is still a part of
Exhibit 334, okay? And you can see were referring to the 120"down there on the bottom,
just so were all oriented. Thats what we call the Bates stamp number. This is for 2-7-03;
is that correct?
A. Yes.
Q. All right. Now, if you look at the guests -- and Im going to bring it a little closer and
give everybody a head ache, all right? If you look at the Guests, it appears that theres
an M. Nicole Cascio -A. Yes.
Q. -- who stayed overnight; is that right?
A. Yes.
Q. And it looks like a Dr. Farshshian stayed overnight; is that correct? 7094
A. Yes.
Q. Actually, Im going backwards. Hes at the top of that list, right?
A. Right.
Q. It looks like he left at 8:30 in the morning, right?
A. Right.
Q. And then he may have come back at 10:15?
A. Yes.
Q. Okay. So lets go down to -- to Marie Nico le, or it says, M, something, Nico le
Cascio.
You assume thats Marie Nicole?
A. Yes, uh-huh.
Q. So -- it says stayed over or carried over, so that would tell you she stayed overnight; is
that right?
A. Yes.
Q. Now that you think about that in conjunction with the whatever-it-was and guests,
does that suggest that Marie Nicole Cascio was probably one of the guests that came in
the day before?
A. Do you have the other pages for this?
Q. I have -A. Theres usually like three pages per day.
Q. Yes. Yes. Youre welcome to look at them. We have to be careful because weve got the
book apart, and I want to put it back. So we have to keep it in the same order here.
Before I do, Ill let you see the whole thing, but its safe to say youve got Gavin Arvizo,
Star Arvizo, looks like Daviella now, Arvizo, Aldo Cascio, and Mom Arvizo, right?
A. Correct.
Q. And those are all carry-overs. So that would mean, to you, that they were there -A. The night before.
Q. -- the night before?
A. Prior to midnight of that day.
Q. Of this day, which was 2-7 -A. Correct.
Q. -- 03. Okay. And it also appears that they then continued to stay overnight on the 7th;
is that right?

A. Yes. MR. SANGER: Okay. So now having said that, if its all right with the Court, Ill
approach with the book so that the witness can see everything in context.
Q. And Ill just speak loud for a moment, if I can. The pages are in the exact order of the
exhibit, so keep them in that same order, if you would.
A. Yes. At some point they came in on the 6th and were there on the 7th.
Q. All right. And as you look at that --before I come up and retrieve it, as you look at that,
theres no specific record where those particular individuals, that is, the Cascios and the
Arvizos, were logged in by name as coming in.
A. No.
Q. Other than perhaps just that reference to Owner and guest, or whatever it says; is
that correct?
A. Correct. MR. SANGER: All right. May I approach to retrieve the book, Your Honor? THE
COURT: Yes. MR. SANGER: Okay. Thank you, sir.
Q. Now, Im going to go to page 121 of the same exhibit. It will still be 334 until further
notice, if thats all right. So its -- it says 121, MJ00121 at the bottom. And then this is -at the top, rather than Guest, there are a number of people who are listed there. And
this is -- theres no date at the bottom of this, correct?
A. Correct.
Q. So you need to try to ascertain the date by figuring out where it falls within the context
of the other documents, right?
A. Correct. The -- it would have been, again, with at least one, most likely two other
pieces of paper that -- gate logs.
Q. All right. And for the purpose of -- well, Ill withdraw that. This shows that at the ranch,
there were quite a number of people; is that correct?
A. Yes.
Q. And it says, CBS Entertainment there; is that correct?
A. Yes.
Q. Now, it appears that on that list -- I wont read them all, but on that list is Ed
Bradley;
is that right?
A. Yes.
Q. Are you familiar with Ed Bradley of CBS?
A. Yes.
Q. And Jack Sussman, is he a producer at CBS? You dont know?
A. I have no idea.
Q. Thats okay. There are a number of other people associated with CBS there, right?
A. Yes.
Q. And it indicates that all the people associated with CBS, at least down to the point that
its recorded -- let me withdraw that. It looks like Jack Sussman arrived at 9:40; is that
right?
A. Yes.
Q. Doesnt show that he was checked out?
A. No.
Q. Okay. We assume hes not still there.
A. Yes.
Q. Okay. You got Ed Bradley. Can you read that?
A. Yes. The times?
Q. Yeah, the times.

A. 10:30 to -- its either 18 or 1900. So 6 or 7 p.m.

Q. And then the rest of them are 10:30 to 7 p.m., is that correct?
A. Yes.
Q. 10:30 to 7 p.m. Were you on duty that day?
A. I dont know.
Q. Do you remember there being a large group of people?
A. I dont remember being there when CBS was there.
Q. All right. Thats fair enough. All right. Now we go to page 123, which is dated -- by that
I mean MJ00123, which is dated 2-9-03, correct?
A. Yes.
Q. And here we show on the 9th of February, 2003, that you have Gavin Arvizo, Star
Arvizo, Davellin Arvizo. It shows they were all -- if you just look at those entries, they
were all carried over from the night before?
A. Correct.
Q. And then it shows that they left at about 1:30 -A. Yes.
Q. -- and apparently left with the person right before there, whose name is, oh, Marie
Nicole.
A. Yes.
Q. That says Marie Nicole right above Gavin Arvizo?
A. Yes.
Q. So they all left at 1:30. Doesnt tell you where they went; is that correct?
A. Thats correct.
Q. And then they came back at 4:15 in the afternoon?
A. Yes.
Q. It does appear that there are two other people down at the bottom, Anna Ruiz and
looks like Silvana Ruiz. Do you see those?
A. Yes.
Q. Looks like they left at 1330, which is 1:30, and came back at 4:15, right?
A. Correct.
Q. And it says limo there. Does that mean they went by limo?
A. Yes.
Q. And you dont know how the Arvizos traveled
on that occasion, do you?
A. No.
Q. You would assume that somebody gave them a ride, though?
A. Yes.
Q. Okay. And then it shows next theyre carried over -- that being the Arvizos -- theyre
carried over. They stayed overnight; is that correct?
A. Yes.
Q. And then we have page MJ00126, which shows 2-10-03, correct?
A. Correct.
Q. And here we see the Arvizos and Marie Nicole staying overnight; is that correct?
A. Thats correct.
Q. And it shows there Mrs. Arvizo, as well, under Anna Ruiz, correct?
A. Yes.
Q. And it appears that they stayed overnight. Not only were they overnight the night
before, but theyre staying overnight the next night; is that correct?

A. Yes.
Q. So thats the 10th. Now, did the -- did the procedures change at some point to where
you would start logging in where people were staying at the ranch?
A. Yes.
Q. All right. I want to show you 2-11-03, which is 00129, Bates stamp number 129. Okay,
2-11-03, correct?
A. Yes.
Q. And here on 2-11 -- oops, sorry -- it appears that Dieter W eizner was staying in Guest
Unit No. 4.
A. Yes.
Q. And he stayed overnight?
A. Yes.
Q. If you go down to the next, it shows Janet Arvizo.
A. Yes.
Q. All right. Im sorry, when I said the next, I meant to say skip one. It goes down
toJanet Arvizo, Guest Unit No. 2.
A. Yes.
Q. Stayed overnight, or she was staying overnight, correct, from the night before?
A. Yes.
Q. But on this day, and again, this day being February the 11th, then Arvizo leaves at
5:04 in the afternoon, correct?
A. Correct.
Q. And she comes back at three minutes to 8:00?
A. Correct.
Q. Okay. It shows, Gavin and Star, house?
A. Yes.
Q. That means theyre staying at the house, according to this?
A. Yes.
Q. And then it shows -- now, what does that say now?
A. It looks like Daniella.
Q. Okay. Seems this name changes continuously. But anyway, whoever that is, D. Arvizo,
whatever it says there, is staying in Unit No. 2; is that correct?
A. Yes.
Q. And then Marie Nicole is staying in the doll room, right?
A. Yes.
Q. Thats in the house?
A. Correct.
Q. And Aldo, her brother, is staying in the house; is that correct?
A. Yes.
Q. Now, Ronald Konitzer is there in Unit No. 1, correct -A. Yes.
Q. -- is that right? And his wife and two children are also staying there at the ranch in Unit
No. 1; is that correct?
A. Yes.
Q. Now, Units 1, 2, 3 and 4 are the four guest units that are right by the lake; is that
correct?
A. Thats correct.
Q. And theyre just across the front --

A. Grass.
Q. Yeah, the front entrance.
A. The driveway.
Q. The driveway for the entry of the house. Theyre right across from the front of the
house in a build ing that has four units in it?
A. Yes.
Q. All right. So according to this, Ronald Konitzer, his wife and children, are staying in 1.
Davellins in 2 with Janet. And there are these other two people. Dieters in 4. And this
Mark Lester, whoever that is, is in 3, right?
A. Right.
Q. Now, excuse me one second. I think it got cut off here. Hold on. Yeah, okay. On this -at the bottom here, same page, were still on 129 for February 11th, 03, at the very
bottom, you have Ranch Vehicles, right?
A. Yes.
Q. And Im going to direct your attention to the one just before the bottom. It says
Katie, and its kind of cut off, but its Katie Bernard; is that correct?
A. Yes.
Q. Do you know who Katie Bernard is?
A. Yes.
Q. Who is she?
A. Shes a secretary for the ranch.
Q. Works at the ranch?
A. Yes.
Q. Is she a nice person?
A. Very nice.
Q. It says, Black van, right?
A. Yes.
Q. And what is the black van?
A. Black van. It would be the -- its a ranch vehicle that usually Gary drives.
Q. Okay. So its a vehicle thats used to drive people places, if the guests want to go to
town or do something else, or go to the airport or whatever, it can be used for that,
correct?
A. Yes.
Q. All right. Now, it looks like Katie Bernard checks the black van out and then she leaves
at four minutes -- at 5:04; is that correct?
A. Correct.
Q. So it appears that she is taking Janet Arvizo off the ranch, correct?
A. They at least left at the same time.
Q. If its down to the minute, theyre either right in the same car or one right behind the
other.
A. Yes.
Q. But usually its the same car, right?
A. Yes.
Q. It would be 1705 by the time you get to the next car, probably, right?
A. Yes.
Q. Now, it looks like K atie Bernard was gone long enough to, say, go to town, drop
somebody off and come back, right?
A. Yes.

Q. All right. Now we go to 2-12. And this is page 132, 00132, and it shows February the
12th, 2003; is that correct?
A. Thats correct.
Q. All right. Now, here, lets start with the guests. And I take it -- I think its obvious to
everybody, the Xerox machine evidently cut off the edge of the page there, correct?
A. Yes.
Q. Here it appears that there are a number of guests overnight, including Gavin, Star, and
Davellin, however her name is spelled, all right?
A. Yes.
Q. Well call her Davellin, all right?
A. Okay.
Q. It appears that they stayed overnight, correct?
A. Yes.
Q. And then it appears -- and Janet as well, correct? It says Janet, Gavin, Star, Davellin?
A. Yes.
Q. They all stayed overnight, and then they all left at 1:38 in the morning; is that right?
A. Thats right.
Q. So when they went to the gate, whoever was driving them stopped the vehicle and
said, Were leaving. And we have Janet, Gavin, Star and Davellin here, correct?
A. Yes.
Q. So the person at the gate, the guard at the gate, could check all these people out at
that date?
A. Yes.
Q. There was no secret spiriting of people away. This was checking right out at the gate?
MR. AUCHINCLOSS: Objection; argumentative. MR. SANGER: That probably was. Ill
withdraw it. THE COURT: All right. Ill sustain the objection. MR. SANGER: There we go.
Q. In other words, this is done according to procedure. A car comes up; the driver
identifies the people in the car?
A. Either the driver or the security officer.
Q. Or the security officer looks in and sees who it is, and he opens the gate and they go,
right?
A. Correct.
Q. All right. If you look at the bottom here, we also have something that says, Salas,
and it just says, u-s Salas, but your bet would be thats Jesus Salas, correct?
A. Yes.
Q. Just got cut off by the Xerox machine. And he checks out the Rolls Royce, right?
A. Correct.
Q. Do you know what kind of Rolls Royce that is?
A. I dont know which one exactly that is. There was a couple. They were older.
Q. Nice car?
A. Nice, yes.
Q. Nice car, all right. And he checked it out according to the ranch procedures, correct?
A. Correct.
Q. And he checks out -- it goes out at 1:38, correct?
A. Yes.
Q. He does whatever he does, and he gets back, in the Rolls Royce, by 9:08 in the
morning, correct?
A. Yes.

Q. Now, Gary Hearn was there. Hes a driver, correct?

A. Yes.
Q. And he was staying overnight; is that right?
A. Yes.
Q. Okay. I think Im going to go to 135. Hold on one second. Excuse me, Your Honor. Im
sorry. Let me skip ahead a little bit. Okay. Im going to go to 149. Show the bottom first.
149. Now, it says 2-17 through 2-26-03. Is that a typical way to do this?
A. It has -- Ive seen it done. I think it says 2-20, but -Q. 2-20, youre right, Im sorry. 2-17 through 2-20?
A. The reason we would do something like this would be if we knew we were going to
have guests for a certain period of time.
Q. So you have here -- and let me do this, first of all, so we can see it, and then Ill focus
in a little better for you. At the top where it says -- ordinarily youd put your service
people and whatnot up there, thats crossed out and it just says, Guest List and the
whole page is used for Guest List?
A. Yes.
Q. Down through the first two parts of it, in any event; is that right?
A. Yes.
Q. And on the guest list -- let me see if we can get closer and read it. Can you find the
one that I did? MS. YU: Yeah. MR. SANGER: Let me borrow that.
Q. 2-17 through 2-20, it shows -- well, it looks like David ia Arvizo was staying overnight,
had been staying overnight; is that correct?
8 A. Stayed overnight at least once.
Q. All right. And then it shows out at 1951; is that correct?
A. Yes.
Q. Do you know what day she left at 1951, 7:51 in the evening?
A. No.
Q. All right. And then you have Gavin is also staying overnight and leaves at 1951,
correct?
A. Yes.
Q. And you have Janet, who leaves at 2145?
A. Yes.
Q. And then, again, Star is 1951?
A. Yes.
Q. And here it shows that the Arvizos are staying -- it says -A. I would assume its Dance Studio.
Q. Staying at the dance studio?
A. Yes
Q. All right. And it shows the Cascios, Aldo and Marie Nicole, are staying at the main
house; is that correct?
A. Yes.
Q. And then theres a number of other people there who are staying in the guest units
down there. We dont have to go through all of the names, but I see Ann Konitzer and kids
is in one. A. Yes.
Q. With Ronald Konitzer?
A. Yes.
Q. And there are other people staying in the other units, right?
A. Yes.

Q. Okay. Now, if we go to MJ00151, it says 2-18. And it doesnt show all those guests that
you showed -- Im sorry, it does not show all the guests that were shown on page 149
that we just looked at; is that right?
A. Correct.
Q. So since the other one said 2-17 through 2-20, you would assume that some or all of
those people were continuing to stay overnight; is that correct?
A. Yes. We most likely had that one that you just showed without the guests, we had that
for every day -Q. Okay.
A. -- up through that period, because we would still need to have written down
somewhere where those people, or general deliveries, contractors or whatever, were still
coming in.
Q. If we go to 155, which is for 2-19, it doesnt show all those other guests that were
listed, correct?
A. Correct.
Q. But it does show some new guests, for instance, fan club people there?
A. Yes.
Q. Who apparently came onto the ranch for a while; is that correct?
A. For the day, it looks like.
Q. Okay. Now, Im going to go to 2-20-03, which is 157. And again, if you want to look at
any of the pages in between, youre welcome to do it. Im trying to pick out the ones that
count here, but you can look at anything you want. So this is 2-20-03, and this shows
guests as of 2-20. It shows Aja Pryor coming in at 1420 hours.
A. Yes.
Q. Along with Dustin Tucker. Is that her son?
A. I dont know.
Q. Okay. Aja Pryor is Chris Tuckers girlfriend? Or you dont -A. I have no idea.
Q. Okay. Do you know who Aja Pryor is at all?
A. No
Q. In any event, whoever they are came in at 1420. At the same time, Gavin, Star and
Davellin came in at 1420 hours; is that correct?
A. Yes.
Q. So evidently they left sometime before the time that they returned on 2-20, right?
A. Yes.
Q. And I showed you that other page where it said 2-17 to 2-20; is that correct?
A. Yes.
Q. And it showed some out times, but it didnt tell you the day?
A. Right.
Q. So if somebody were to have left, say, on the 19th, the time was there, but you
wouldnt have the day to determine whether it was the 19th, the 17th, or what?
A. If thats how that particular paper was kept, yes. I dont know exactly what was going
on, why -- Im sure we had the extra sheet because we had so many people.
Q. All right. THE COURT: One thing you need to do is to keep referring to the page
number. MR. SANGER: Did I fail to do that on the last one? THE COURT: I dont -- I dont
think you did. Maybe I missed it, but -MR. SANGER: Okay. Im sorry. The one that I just
put up was 00157. THE COURT: Yes. MR. SANGER: And that is for 2-20-03. THE COURT:

You did refer to it. I just missed it. Im sorry. Is this a good place to stop? MR. SANGER:
Fine, Your Honor.

2005 April 21 (Day 37) Barron, Cleaven, Sutcliffe, Rooney, Moelle, Klapakis

BRIAN BARRON CROSS-EXAMINATION (Continued)

THE COURT: Good morning, everyone.
THE JURY: (In unison) Good morning.
COUNSEL AT COUNSEL TABLE: (In unison) Good morning, Your Honor.
MR. SANGER: Good morning, Your Honor.
THE COURT: Mr. Sanger?
MR. SANGER: Thank you, Your Honor. Could we please have the document screen again,
please? There we go. All right. With the Court's permission, we'll resume with Exhibit 334.
And the Court may recall this is a series of a couple hundred documents and they have
the Bates stamped number on the bottom, so we'll be referring to those by the MJ00
three-digit number, sometimes four-digit number. Is that all right, Your Honor?
THE COURT: You may do so.
MR. SANGER: Thank you.
CROSS-EXAMINATION (Continued) BY MR. SANGER:
Q. And in that regard, Mr. Barron, or Officer Barron, we had gotten to this period of time,
just before we stopped yesterday, where the gate log showed from 2-17 to 2-20. Do you
recall that?
A. Yes.
Q. And that was not the usual mode of recording. Usually it was day by day; is that
correct?
A. That's correct.
Q. All right. So I'm going to show you 149 here again. Even though we had gotten up to
2-20, I want to go back to that period for a couple of other entries, all right? So just to
remind us where we were, I have MJ00149 up on the board. And that is the one that said
2-17 through 2-20-03, correct?
A. Correct.
Q. And at the top, that had the extensive list of guests and where they were s taying,
correct?
A. Correct.
Q. And then it shows CO, so it's carry-over for the Arvizo family, and then it has times
out, but those times out are not necessarily coordinated with a particular day; is that
correct?
A. Correct.
Q. All right. Now, I'm going to refer to 00152 and put that up on the board, if I may.
Shows, at the bottom, 152. Do we have our laser pointer, by any chance? If you have it.
152. And then up at the top there's an entry that I'm going to -- I'm going to push the
wrong button. I'm sorry. There we go. Sorry. I'm going to push the -- that button. See if
you can read that entry. Do you have it there?
MS. YU: No, somebody took it out.
MR. SANGER: All right. That's all right.
Q. Are you able to read the top entry there after I stop moving it? Just a second. There we
go. Can you read that entry?

A. At 3:05?
Q. Yes. Would you like to have another copy up there?
A. I think -- I believe it says Marie Nico le, Danielle, A ldo are staying upstairs theater.
Q. Okay. And this particular gate log is dated 2-18-03, correct?
A. Correct.
Q. Now, what would be the purpose of that particular entry; do you know?
A. So we would know where they were.
Q. So that would be a reference to where that particular guests were staying on that
particular day; is that correct?
A. That's correct.
Q. So as of 3:05, those guests had decided to stay in the upstairs theater, correct?
A. Correct.
Q. All right. We'll skip ahead, then, to -- I don't want to get this out of order. We'll skip
ahead to 155. Now, I'm going to show you 155. And I'll try to speak up when I come back
here? If anybody can't hear, raise a hand so the Court and bailiff know. That's for 2-1903, correct?
A. Correct.
Q. And on this, I want to direct your attention to the top part of this one. It appears to
indicate Hamid, a photographer.
A. Yes.
Q. Okay. And by the way, there's a column that says, CONF. What does that mean?
A. Confidentiality, if they need to sign one or not.
Q. So a person who has been there doesn't have to sign that agreement each time they
come in, correct?
A. Correct.
Q. And the agreement basically says, I'm not going to disclose private things about Mr.
Jackson's residence; is that right?
A. Correct.
Q. Okay. And it shows that Hamid and apparently a couple other people, a Mark Adams
and a Ray Dominguez, arrived at 1620 hours, is that correct, 4:20 in the afternoon?
A. Yes.
Q. And departed at 2010 hours, which would be 8:10 in the evening, correct?
A. Yes.
Q. Now, other -- let me ask you, did you have a chance to review these logs since you
testified yesterday?
A. No.
Q. All right. I'm going to show you now 157. And I think this was really the last one that
we put up yesterday. And this shows -- let me back this up a little b it. 00157 is for 2-2003, correct?
A. Correct.
Q. And this one shows that the Arvizos returned to the property at 1420 hours, or 2:20 in
the afternoon, on the 20th of February, 2003, correct?
A. Yes.
Q. And it also shows that Aja Pryor and something Tucker, that's cut off there, returned at
the same time?
A. Yes.
Q. So it indicated all those people came to the gate at the same minute, correct?
A. Yes.

Q. And generally that would ind icate they came in the same vehicle?
A. Generally, yes, it would.
Q. All right. Now, if we go to the next page, which would be 00158, which I'll put up, that
show 158 at the bottom. If we look at the top, that's also for 2-20-03, correct?
A. Yes.
Q. And you indicated there usually are three pages per day; is that right?
A. Generally, yes.
Q. Generally. So this is just another page for that same day?
A. If it's dated the same day, then yes.
Q. Yeah. And what I would like to do is direct your attention to -- see if I can get it in
there so you can still read it. If you look at the entrance for 1420 -A. Yes.
Q. -- that's the same time that was indicated on the preceding page that the Arvizos, Aja
Pryor, and Destin Tucker arrive; is that correct?
A. Yes.
Q. And here the entry indicates Jesus S., so let's start with that. That would be Jesus
Salas; is that correct?
A. Correct.
Q. Jesus Salas cleared Aja Pryor, Dustin Tucker, Gavin Arvizo, Star Arvizo, Davellin Arvizo
3 to come in, correct?
4 A. Correct.
Q. And the purpose of that entry is what, that type of entry?
A. That type of entry is generally for, first of all, whomever's at the gate to know to let
someone in if they don't have prior -- you know, if we haven't been given a list of
somebody who's coming in that day, and then to let the oncoming shift know that they're
there.
Q. So that would be further evidence in these logs that all of those people just mentioned,
Pryor, Tucker, and three Arvizos, came back to the ranch at 1420 hours on February the
20th, correct?
A. Correct.
Q. Oh, I'm sorry, there was one other thing on that. It also looks like Shane Brando ran
over somebody's foot with a cart, is that true, at about 1815 hours?
A. If that's what it says, I'm assuming it's true.
Q. And then 1924, it looks like Shane Brando hit Gavin Arvizo with a cart?
A. Yes.
Q.And here the entry indicates Jesus S., so let's start with that. That would be Jesus
Salas; is that correct?
A. Correct.
Q. Jesus Salas cleared Aja Pryor, Dustin Tucker, Gavin Arvizo, Star Arvizo, Davellin Arvizo
to come in, correct?
A. Correct.
Q. And the purpose of that entry is what, that type of entry?
A. That type of entry is generally for, first of all, whomever's at the gate to know to let
someone in if they don't have prior -- you know, if we haven't been given a list of
somebody who's coming in that day, and then to let the oncoming shift know that they're
there.
Q. So that would be further evidence in these logs that all of those people just mentioned,
Pryor, Tucker, and three Arvizos, came back to the ranch at 1420 hours on February the

20th, correct?
A. Correct.
Q. Oh, I'm sorry, there was one other thing on that. It also looks like Shane Brando ran
over somebody's foot with a cart, is that true, at about 1815 hours?
A. If that's what it says, I'm assuming it's true.
Q. And then 1924, it looks like Shane Brando hit Gavin Arvizo with a cart?
A. Yes.
Q. And then the cart was taken away, all right?
A. Yes.
Q. Okay. So, again, somebody in security or somebody on the staff, when they saw that
there was a safety issue, exercised supervision over guests of the ranch; is that correct?
A. Correct.
Q. And it shows Gavin is Code 4, right?
A. Yes.
Q. And then it says, Received EMT care from, what does that say, K-10 and K-13?
A. No, it's R-10 and R-13.
Q. R-10 and R-13, are those designations for people that worked on the ranch?
A. R is Robert. It's a call sign over the radio, so we're not using each other's name.
Q. So whoever it was who responded from the fire department came down to give him
some sort of emergency care to make sure he's okay, is that right?
A. Yes. Robert 10 gave the care. Robert 13 wrote it down.
Q. There you go. When it says, Gavin, Code 4, Code 4 means no further assistance
required, okay?
A. Yeah, he's okay.
Q. If you say, in police talk basically, Code 4, you mean no further assistance,
everything's okay?
A. Correct.
Q. All right, good. We're going to skip ahead here to 160. I'm putting up 160. Now, that's
for 2-21-03; is that correct?
A. Yes.
Q. And at the bottom, it shows, Vincent Black, yes, 22 -- I think that says 55,
2255, correct?
A. Yes.
Q. So that would indicate -- even though it's written on the bottom, it would indicate, sir,
that Vincent Black arrived, had to sign an agreement, right?
A. Yes.
Q. And that he arrived at 2255 hours, correct?
A. Pull the paper down a little more.
Q. Certainly. Would you like to look at a -- would it be easier to look at a full sheet?
A. Yes, my eyes haven't adjusted from yesterday yet.
MR. SANGER: All right. May I approach, Your Honor?
THE COURT: Yes.
MR. SANGER: Excuse me. Does anybody want to see this? I'm just going to show him my
copy.
MR. AUCHINCLOSS: Go ahead.
THE WITNESS: Mr. Black did need to sign a confidentiality, and he was checked in at 2255
It's on the bottom, because there's no more room for guests here.
Q. BY MR. SANGER: All right. So, the fact that it's put in the margin is of no significance

other than the fact you ran out of room on the form, right?
A. Yes, and the officer didn't want to start a new sheet.
Q. For ecological reasons, I assume?
9 A. Sure.
Q. It says CO next to the 2255, so that means Mr. Black checked in at 10:55 at night,
he came through the gate at 10:55 at night, and then he stayed to the next day, correct?
A. Correct.
Q. And below it, it says Janet Arvizo, correct?
A. Correct.
Q. That tends to indicate that Janet Arvizo came in at 2255 hours as well; is that correct?
A. Yes.
Q. And she was not required to sign a confidentiality agreement?
A. No.
Q. And then she also stayed overnight that night; is that correct?
A. Yes.
Q. And if we go up here, higher on the sheet, we see among the guests who were there
on this day, the 21st of February, you also had Aja Pryor, correct?
A. Yes.
Q. And then Destin Tucker, correct?
A. Yes.
Q. And then the Arvizo children, Gavin, Star and Davellin?
A. Yes.
Q. And it shows that the Arvizos were there from the night before, and they continued on
to the next day without checking out; is that correct?
A. That's correct.
Q. Okay. And then, of course, there are other people that are listed on the list. We won't
go through each one. There are other guests there that day?
A. Yes.
Q. All right. There you go. May I approach to retrieve that?
THE COURT: Yes.
Q. BY MR. SANGER: Now, we'll go to page 164, if I may. It's MJ00164. Show that. And
that's for February 22nd, 2003; is that correct?
A. Okay.
Q. It's hard to read. Maybe counsel would agree that when you look at it closely it says
the 22nd. If not, let me approach. May I approach, Your Honor?
THE COURT: Yes.
MR. SANGER: I'll tell you what -MR. AUCHINCLOSS: I can't read it on mine.
MR. SANGER: Let's do this.
THE WITNESS: Is there a date on the top or just one on the bottom?
Q. BY MR. SANGER: No, there's just one on the bottom. But let me show you the -- let me
show you that page. May I approach with that page? I'm going to show you page 00164,
and ask you to take a look -- excuse me, take a look at the date at the bottom, and see if
you can tell the date from that.
A. I'll agree it's the 22nd.
Q. All right. Thank you. And it would be in order, correct? There should be other pages
pertaining to the 22nd in the book, correct?
A. Yes.

Q. All right. Okay. So there's the date. And I'm putting 00164 back up on the screen. And
do you see there is the entries for Gavin, Star, Davellin in the guest information?
A. Yes.
Q. Okay. Gavin, it shows -- under Limo/POV, it shows #2. What does that represent to
you?
A. To me that would represent he was staying in Guest Unit 2.
Q. And it shows Star Arvizo, ditto, is also in Guest Unit 2; is that correct?
A. Yes.
Q. And they were both staying overnight. They had been there and they stayed over to
the next time period, to the next 24-hour period, correct?
A. Correct.
Q. If you look at Davellin, what does that say?
A. Upstairs viewing.
Q. And upstairs viewing would be the room in -- one of the rooms in the theater; is that
correct?
A. Yes.
Q. So that indicates that she was staying in the upstairs viewing part of the theater; is
that correct?
A. Yes.
Q. And if you look up at the third entry up there, you have Cascio, comma, Marie Nicole;
is that correct?
A. Yes.
Q. And it shows that she was also staying in the upstairs viewing in the theater; is that
correct?
A. Yes.
Q. All right. And she also stayed overnight, correct?
A. Yes.
Q. Okay. And down at the bottom it shows Janet Arvizo, correct?
A. Correct.
Q. And it shows No. 4. Is that Guest Unit No. 4?
A. Yes.
Q. Now, is Guest Unit No. 4 the guest unit that Elizabeth Taylor likes to stay in when she
visits?
A. I have no idea.
Q. Okay. Is it a nice guest unit?
A. Yes.
Q. And it shows Janet Arvizo was staying overnight. She had been there at midnight, and
she was there at the next cutoff, which would be the next midnight; is that correct?
A. Correct.
Q. Okay. We'll go to MJ00166, and that's 2-23-03; is that correct?
A. Yes.
Q. Now, on this date, we have the Arvizos shown again as staying at the ranch; is that
correct?
A. Yes.
Q. And they were all staying -- they had all been there and they were all staying overnight
as guests again, correct?
A. Correct.
Q. And Gavin and Star are in Unit 2; is that right?

A. Yes.
Q. Davellin's at the theater upstairs?
A. Yes.
Q. And Janet is in Unit 4?
A. Yes.
Q. All right. And Marie Nico le Cascio is also in the theater upstairs, the same place as
Davellin; is that correct?
A. Correct.
Q. Now, it's possible for people at Neverland to -- for guests at Neverland to request the
services of staff people there; is that correct?
A. Yes.
Q. And in a sense, it's almost like a hotel as far as service is concerned; is that right?
A. That's correct.
Q. If somebody wants to call and have coffee brought to them or breakfast or anything,
they can simply call and that will be done for them; is that correct?
A. Yes.
Q. If somebody wants to call and have their laundry done, for instance, if they have
laundry or cleaning that needs to be done, somebody would come and pick it up and take
care of it for them; is that right?
A. That's correct.
Q. If somebody wants to have a wake-up call, they can make a request for a wake-up
call; is that correct?
A. Yes.
Q. So I'm going to show 167 here, if I may. 167. By that I mean 00167, and the top is 223-03. And here this shows that a wake-up call is requested for Unit 4 at seven o'clock in
the morning; is that correct?
A. Yes.
Q. All right. Let's skip ahead. I like to say that. It gives everybody a false sense of
progress here. We are getting there. Skip ahead to 171, if I may. 00171 is 2-24-03,
correct?
A. Correct.
Q. Okay. Now, there's a number of entries I'd like to -- a number of entries I'd like to
focus on here. First of all, let's look at -- Gavin and Star Arvizo were staying in Unit 2,
correct?
A. Correct.
Q. Davellin is again at the theater?
A. Correct.
Q. Janet Arvizo is in Unit 4; is that right?
A. Yes.
Q. Okay. Now, it appears that the Arvizos were there overnight from the night before,
correct?
A. Yes.
Q. And then it appears that they all left at 1634 hours, which would be 4:34 in the
afternoon; is that right?
A. Yes.
Q. And then it appears that Gavin and Star and Janet came back at 2005, which would be
8:05 p.m.; correct?
A. Correct.

Q. And then they stayed overnight till the next day, right?
A. Correct.
Q. And then Davellin came b ack at 1855, which would be 6:55, five minutes to 7:00 in the
evening, correct?
A. Yes.
Q. So it looks like they all left together, but Davellin came back a little earlier, and Janet,
Star and Gavin stayed out and did something else and came back later, right?
A. Yes.
Q. All right. Now, if we look down on this sheet -- and by the way, do you know if Gavin
and Star were taken to the dentist at some point?
A. I don't remember that.
Q. All right. This is not a day that you were particularly on duty, was it?
A. Which day?
Q. This day, which is 2-24-03.
A. You'd have to show me the other log.
Q. That would be 172. Let me put that up. This is 00172. And can you tell whether or not
you were on duty that day?
A. No. Not according to that.
Q. I'm going to put 00171 back up. And let's see if we can figure this out. It looks like
from the top that the whole Arvizo family left at 1634 hours. And then if you look down at
the bottom, it says, Employee vehicle, and the second entry shows Vinnie, Arvizos 4,
correct?
A. The second entry down?
Q. Yes.
A. No, that would be on the first entry. Frank, Vinnie.
Q. Frank and Vinnie. Okay. That's fair enough. That says, Frank and Vinnie, brown
dually. Was there a -- or some kind of dually. Is there a dually?
A. Yes, it's a brown dually.
Q. Okay. And a dually, as most people know here, has got dual wheels in the back of the
truck?
A. Correct.
Q. It looks like they went out in a brown dually at 11:05 in the morning and got back at
3:11 in the afternoon, correct?
A. Yes.
Q. Okay. And the next entry, the one I was focusing on -- and it seems to be cut off just a
little bit there. The second one says, it looks like Vinn ie, does it not? Or, i-n-n-i-e,
7136 a little bit of a first letter got cut off?
A. Could I see your sheet? I -Q. You can see mine, sure. If it's all right with the Court. May I approach?
THE COURT: Yes.
THE WITNESS: It doesn't look like Vinnie to me.
Q. BY MR. SANGER: What does it look like?
A. Chris.
Q. Oh, Chris? Okay. Anyway, you see -- I'm going to move away - because I'm not
supposed to talk up here - so I don't have to walk back and forth. You see where it says,
Arvizos 4?
A. Yes.
Q. And whatever that says before, it might be Chris, it might be anything, but whatever

it is, after Arvizos 4, it then says, Pontiac, right?

A. Yes.
Q. So somebody took a Pontiac out. Was that a ranch vehicle?
A. I don't recall a Pontiac. It doesn't mean there wasn't one. I don't recall a Pontiac.
Q. Do you remember Vinn ie was driving a Pontiac, if he brought a Pontiac to the ranch?
A. I have no idea.
Q. Did Vinnie at that time -- do you recall Vinn ie having some kind of a vehicle that he
brought to the ranch?
A. No, I -- I don't recall his vehicle whatsoever.
Q. Okay. You don't recall either way, whether he brought one or didn't bring one?
A. No.
Q. All right. In any event, somebody with four Arvizos took a Pontiac and left at 1634,
correct?
A. Yes.
Q. If we look up at the top, that's consistent with the check-out at the gate, 1634, of the
family; is that correct?
A. Correct.
Q. And then whoever that was with the Arvizos came back at 1855 hours, correct?
A. Yes.
Q. If we look up at the top, it would appear that whoever came back with that vehicle
brought Davellin back; is that correct?
A. Yes.
Q. And so Janet and the boys remained out until 2005 hours, right?
A. Right.
Q. And if we look at the next entry, we've got Joe Marcus, right?
A. Right.
Q. Joe Marcus is the ranch manager; is that correct?
A. If he still is. He was at that time, I believe, yes.
Q. That's fine. As of the time, he was the ranch manager, correct?
A. Yes, he was.
Q. And do you know Joe?
A. Yes.
Q. Is he a good guy, decent guy?
A. Yes.
MR. AUCHINCLOSS: Objection; relevance.
THE COURT: Sustained.
Q. BY MR. SANGER: Okay. You get along with Joe Marcus?
A. At times.
Q. All right. At times not, I gather. All right.
A. Well, I d id at the time.
Q. You did at the time?
A. At the time, yes, I d id.
Q. And had Joe Marcus, to your knowledge, been at the ranch for a long time?
A. Very long.
Q. In fact, his father had been the ranch manager for the prior owner; is that right?
MR. AUCHINCLOSS: Objection; relevance.
THE COURT: Sustained.

Q. BY MR. SANGER: All right. Now, it shows Joe Marcus has -- took a gray van; is that
right?
A. Yes.
Q. And was the gray van one of the ranch vehicles?
A. Yes.
Q. And it appears that he left at 1759 hours, which would be one minute to 6:00 in the
evening; is that correct?
A. Correct.
Q. And then came back at 2005 hours; is that right?
A. That's right.
Q. And when you look at the -- put two and two together here, the Arvizos, Janet and the
two boys, came back at that time. It would appear that they came back with Joe Marcus;
is that right?
A. Yes.
Q. We'll go to 174. And 174, MJ00174, was from February the 25th, 2003; is that correct?
A. Correct.
Q. And here we see that the Arvizos, Gavin and Star, stayed overnight, correct?
A. Yes.
Q. And they were in Unit 2; is that right?
A. That's right.
Q. And then Davellin and Janet were in Unit 4; is that correct?
A. Correct.
Q. The Arvizos, all four of them, stayed overnight?
A. Yes.
Q. And then they left at 7:25 in the morning -A. Yes.
Q. -- is that correct? So at 7:25 on the morning of February 25th, they leave the ranch?
A. Yes.
Q. And if you look down a little farther, it says, Vinnie, who is apparently staying in the
video library, he stayed overnight and he left at 7:25 in the morning?
A. Yes.
Q. So it looks like Vinn ie and the Arvizos left together at that time, correct?
A. They left at the same time. If they left together, I don't know, but they definitely left at
the same time.
Q. All right. Now, let's go to 180. This will be 00180 that I'm putting up. And this skips
ahead now to February the 27th, .03, correct?
A. Correct.
Q. I'm going to direct your attention in this case to Frank Cascio.
A. Yes.
Q. It appears that Frank Cascio returned to the ranch on February the 27th, .03, at 1735
hours or 5:35 in the afternoon; is that correct?
A. Correct.
Q. And we'll go to 00181. 181. February 27th. This is another one of those sheets that
pertains to the same day; is that correct?
A. Yes.
Q. And at 735 -- I'm sorry, 1735 hours, the same time that was shown on the previous
sheet, it shows that Jesus Salas cleared Frank Cascio to come on the property; is that
correct?

A. Yes.
Q. That's just further indication that Frank Cascio came back to the property at 1735
hours on that day?
A. Yes.
Q. All right. And I'll put up 183. And this is 00183 on February the 28th, .03. And directing
your attention to the third line down under Guest Information. It shows Frank Cascio; is
that correct?
A. Yes.
Q. So on February the 28th, it shows that he had been on the ranch from the previous
day, and continued to stay on the ranch to the next day?
A. Yes.
MR. SANGER: Okay. Your Honor, I'm now, with the Court's permission, going to go to
Exhibit 335 and proceed in the same fashion. That's a couple hundred pages. So I'm going
to pick out a few of those pages and make reference to the Bates stamp number, if that's
all right
THE COURT: That's fine.
MR. SANGER: Thank you.
Q. Just so we're oriented here, there's the Court's Exhibit No. 335 that starts on page
MJ00185, and the date on that page is March 1, 2003, correct?
A. Yes.
Q. And that was not a leap year, so February had 28 days; is that right?
A. Yes.
Q. Okay. So the next day, from the last page we showed, would be 3-1; is that right?
A. Correct.
Q. And in the back they're in these envelopes, back to back, here. I'm going to show you
186, which also says 3-1-03.
A. Yes.
Q. And it looks like somebody's trying to give February 29 days there, but tried to correct
it?
A. Looks that way.
Q. And I want to focus your attention on the last line there of the guest information log
where it says, Frank Tyson, and that means that Frank was staying at the video library,
and he stayed overnight; is that correct?
A. Correct.
Q. And it didn't -- it didn't show that he checked out that day?
A. No, it doesn't.
Q. All right. I do see at the bottom, it says Frank/Chris took a gray van from 1:30 in the
afternoon to 4:30. Is that an indicat ion that Frank Tyson or Cascio went out with Chris?
A. Yes.
Q. Okay. There was not another Frank there at the time, that you're aware of?
A. Not that I'm aware of, no.
Q. But they came back, right?
A. Yes.
Q. And so Frank, as far as you can tell, was an overnight visitor that night as well?
A. As far as it shows. Didn't show that he left. Doesn't show that he was carried over, so
very possibly.
Q. And then let's go to -- Okay, Your Honor, this is the exhibit as it exists from the way it
was presented by the prosecution. This particular page does not have a Bates stamp

number on the bottom. I'll show it to counsel. This does not have a Bates stamp number.
It follows Bates stamp number 33673 and precedes Bates stamp number 33675.
THE COURT: I see that.
MR. SANGER: So I'm going to put that page up.
THE COURT: All right.
MR. SANGER: And I'm going to hope if focuses. There we go.
Q. Okay. So no Bates stamp number, but it does say 3-2. So that's March the 2nd, 2003,
correct?
A. Yes.
Q. And on March the 2nd, 2003, Frank Tyson, it shows, stayed overnight from the night
before, correct?
A. Excuse me, correct.
Q. And then it shows 1630 that he left; is that right?
A. On -- that who left?
Q. Frank Tyson. Am I not reading it correctly?
A. I'm sorry, I was -- yes. Six -Q. Let's take our time here. I'm sorry if I confused you -A. I apologize, I had to work last night.
Q. You worked last night?
A. Yes.
Q. Okay. I apologize, I'm sorry that you have to be here after doing that. All right. We'll
try to get you through this here. But take a look at it again, take your time. Looks like it
says, ank, a-n-k, Tyson.
A. Yes.
Q. That's Frank Tyson, right?
A. Yes.
Q. And where it says 3625, are those the phone -A. Phone extensions.
Q. And those phone extensions are where?
A. In the video library.
Q. So it's another way of saying that's where he was?
A. Correct.
Q. It shows he stays overnight and then it shows 1630, it appears that he left; is that
correct?
A. To me, it looks like 20 from here.
Q. All right. Whatever it says, that would be the time that he left, according to this log; is
that correct?
A. Correct.
Q. And down at the bottom it says, Frank Tyson again, and it shows out. That means
he took a ranch vehicle of some sort and left; is that right?
A. It should, if it was put there.
Q. All right. And that, I think, says 1305?
A. Yes.
Q. So 1:05 in the afternoon. And then it shows in, meaning he came back at 3:30 in the
afternoon, right?
A. Yes.
Q. All right. And it looks like at 4:30 or 4:20, whatever that says, he may have left again;
is that correct?

A. Yes.
Q. Now, there's a star next to his name, and what does that mean?
A. Most likely that he came back and the person at the gate didn't record the time he
came in.
Q. All right.
A. But if there was a star there, most likely whomever was at the gate knew that he was
there.
Q. That he came back on the property but they just didn't record the exact time?
A. They didn't record the exact time.
Q. If you look up above that, we see what I think says, n-n-i-e.
A. Yes.
Q. And that shows that probably Vinnie; is that correct?
A. Probably.
Q. All right. Arrived at 1430 hours. It should be 2:30 in the afternoon.
A. Yes.
Q. And that he left at 1630 hours, correct?
A. Yes.
Q. And then there's a star, indicat ing he came back and somebody forgot to put it down?
A. Correct.
Q. So if we put those two together, it looks like Frank Tyson and Vinnie probably left at
the same time, around 4:30 in the afternoon; is that right?
A. Yes.
Q. All right. Now, we also see that the Arvizo family came back, and we have Gavin, Star,
and Davellin -- whose name is now recorded as Davida or something; right?
A. Yes.
Q. -- and Janet all came back at about 2:30, apparently with Vinnie.
A. Yes.
Q. All right. I'm going to go to 033667, which is dated 3-3-03, correct?
A. Correct.
Q. And this shows that -- excuse me one second. (Off-the-record discussion held at
counsel table.)
Q. BY MR. SANGER: This shows -- just going down the list, on this particular date, which
is 3-3-03, Vinnie was there, stayed overnight, and then he left at ten minutes after noon;
is that correct?
A. Yes.
Q. It doesn't show that he came back that day?
A. No.
Q. Then you have Gavin, Star, Davellia and Janet Arvizo all staying overnight both from
the night before and till the next night, right?
A. Correct.
Q. This shows both the extensions and the room numbers, or the unit numbers in some
cases, right?
A. Yes.
Q. So Gavin was staying in Unit 3, which is Extension 20 on the phone; is that right?
A. Correct.
Q. Star was staying in Unit 4, which is Extension 21, is that correct?
A. Correct.
Q. We'll skip one there and go to Janet Arvizo was staying in Unit 4, also at Extension 21,

also?
A. Yes.
Q. Now, Davellin was staying -- first it said Extension 3. I'm sorry, it said, Unit 3. That's
scratched out and it says, Extension 50; is that correct?
A. Yes.
Q. And Extension 50 is out at the theater; is that right?
A. Been a while. I -- I know 48 is. So it could be, yes. I don't remember which one 50 was
at.
Q. But in any event, wherever 50 is, it's not one of the guest units?
A. No.
Q. So it's someplace else on the ranch, right?
A. Yes.
Q. And that shows that she was staying at whatever room was associated with Extension
50; is that correct?
A. Yes.
Q. All right. Now, there are also -- and throughout, we've been not commenting on
everybody who was staying there, but if you look down at the bottom there, it says Rio
and Simone.
A. Yes.
Q. And you know who they are?
A. Yes.
Q. Does it appear that Rio and Simone arrived at about eight o'clock at night on the 3rd of
March?
A. Yes.
Q. And then they stayed overnight; is that right?
A. Correct.
Q. And who are Rio and Simone?
A. They are cousins, I believe, of Mr. Jackson.
Q. Okay. And I'm going to go to 189. 00189, and that's for 3-4-03; is that correct?
A. Correct.
Q. And on 3-4-03, we have Gavin and Star up at the top, staying overnight?
A. Yes.
Q. From overnight to overnight, there's no check-out time; correct?
A. Yes. Well, they were there overnight.
Q. Yeah.
A. At least one night.
Q. All right. In other words, it doesn't show that they left. Usually you'd show carry-over
for out, but it just didn't show that, so you don't know. We'll look at the next day.
A. Yes.
Q. All right. The best way to do it. And look at the next day and see if they're still there,
right?
A. That would be the best way.
Q. In any event, they're at 20 and 21. So those are guest units, right?
A. Yes.
Q. And then we have Davellin, and she was staying at that Extension 50, wherever that is,
right?
A. Yes.
Q. That's somewhere other than the guest units and it may be the theater?

A. I believe it's one of the rooms in -- there's two bedrooms in the theater.
Q. All right. And the other bedroom in the theater is 51, is it not?
A. I believe so.
Q. All right. So it shows that she was there from overnight; is that right?
A. Yes.
Q. And then it shows that she went out at 2:25 in the afternoon, right?
A. Yes.
Q. And came back at 6:01 in the evening?
A. Yes.
Q. And it appears, if we do some detective work there, down at the bottom, Chris Carter
took the gray van out and apparently was driving -- was the driver of the van, and drove
her out at 1425 and back at 1801, the same times; is that correct?
A. Yes.
Q. And then Rio and Simone were also on the ranch; is that correct?
A. Correct.
Q. And it looks like they had been staying overnight, right?
A. Right.
Q. And that they went out with Davellin driven by Chris Carter at 1425 and came back at
1801, at the same time; is that right?
A. Yes.
Q. And it looks like R io was staying in the same room as Gavin; is that correct?
A. Yes.
Q. All right. So that's 3-4, and now they're -- we're going to go to -- we're going to go to
191.
Just for the record, Your Honor, it's not a big thing, but it's just a thing. As I'm paging
through here, I'm seeing that these are a little bit out of order. It goes from 188 to 193 to
191 in the exhibit book. I don't know that there's any significance, but I just -THE COURT: It's the same in my copy.
MR. SANGER: That's fine.
Q. So we go to 191, and that shows for 3-5, March the 5th, 2003, correct?
A. Yes.
Q. And here we show, once again, Gavin in 20, guest unit?
A. Yes.
Q. Star, guest unit?
A. Yes.
Q. Both there from overnight, and no indication that they left; is that correct?
A. Correct.
Q. We have Davellin -- and I'll persist in saying Davellin, even though it's spelled
countless ways in these logs; is that all right?
A. That's fine.
Q. You knew eventually her name was Davellin, is that correct?
A. Yes.
Q. So we have Davellin again at 50, which is apparently in the theater; is that right?
A. Yes.
Q. And she stayed overnight, or she had been staying overnight, and there's no indication
she checked out; is that right?
A. Correct.
Q. And then you have Janet, who's staying in one of the guest units; is that correct?

A. Yes.
Q. And again, she was staying from overnight and there's no indication that she checked
out, correct?
A. Correct.
Q. And then you have Rio, who is apparently staying in the same guest unit as Gavin; is
that correct?
A. Correct.
Q. And Rio was there from overnight, and on this date, March the 5th, it appears that both
Rio and Simone left about 7:30 in the evening; is that correct?
A. Yes.
Q. Okay. Let's go to 195. Showing MJ00195. That's for 3-6-03; is that correct?
A. Yes.
Q. Here we show Janet Arvizo is now in Unit 4, which is Extension 21, correct?
A. Correct.
Q. And she had been staying overnight?
A. Yes.
Q. And then we have Davellin, who's in Unit 3. She had been staying overnight, correct?
A. Yes.
Q. And in fact, Gavin and Star are also shown in Unit 3, staying overnight; is that correct?
A. Correct.
Q. I'll put up MJ00198, which is for March the 7th, so once again the next day. And let's
take the easy ones first. We have Gavin, Star and Davellin Arvizo, they show they're in
Unit 3, which is Extension No. 20, right?
A. Yes.
Q. And that they were there overnight, and they continued to remain overnight, correct?
A. Correct.
Q. Then you have Janet Arvizo, who was logged in for Unit 4. It's crossed out. Do you
have any idea why it was crossed out?
A. No.
Q. And then there's a star and a star; is that correct?
A. Correct.
Q. And what does the star tend to mean?
A. Generally it means there was no time given, written in, no time given written out, so it
wasn't written out. The fact that it's crossed out can mean that she wasn't there. I don't
know.
Q. It shows she was there the day before?
A. Yes.
Q. All right. And then if we look here, we see that Frank and Vinnie -- it says, Vinnie
Black. That's the same Vinnie. There was one Frank and one Vinnie throughout this,
right?
A. Yes.
Q. So Frank and Vinnie, if I may use the first names, are staying in the video library, and
they were there at the beginning of the day, at midnight, and they were there at midnight
the next -A. Next day, yes.
Q. Next day, right?
A. Yes.
Q. Okay. Now we go to 2001. 2001, I'm sorry. Too many numbers. Sorry. 00201, which is

3-8 of .03, correct?

A. Correct.
Q. The next day. And on that day, the logs show that we have Gavin, Star, and Davellin as
well as Frank and Vinnie all there the entire 24-hour period?
A. Correct.
Q. So they didn't come; they didn't go. All right. Now we go to -- oops. Again, these seem
to be a little bit out of order. 204 comes before 203. But in any event, I'm going to put
204 up, which is 3-9-03. So that's the next day.
A. Yes.
Q. And on this day we have Gavin, Star, Davellin, all there the entire t ime, correct?
A. Correct.
Q. And then you have Frank and Vinnie, who were there from the night before, and they
seem to leave at about 3:43 in the afternoon, correct?
A. Correct.
Q. And then they come back at -- the two of them come back at the same time, at about
8:43 at night, correct?
A. Yes.
Q. And then they stay overnight; is that right?
A. Yes.
Q. We also on that day have other guests of course, but we have Rio and Simone arriving
at ten minutes after noon, correct?
A. Yes.
Q. And then they stayed overnight?
A. Yes.
MR. SANGER: Now, may I approach the witness with the book?
THE COURT: Yes.
MR. SANGER: Let me put that page back first. Let me just say it out loud if I'm going to
say it to the prosecutor. What I'm going to show the witness, keeping the pages in order
and hoping not to trip and drop them all over the place, we have page 203 and then we
have page 33697, and then there's page 121, which is followed by page 33698, and I
want to ask the witness if that page, 121, belongs in the sequence here. And that's what I
intended to approach him to do, if that's all right with the Court. And that gives counsel an
idea of why I'm doing it.
MR. AUCHINCLOSS: Sure.
THE COURT: All right.
MR. SANGER: Thank you.
Q. Okay. Now, I'm not supposed to talk up here, but I just want to tell you this. Obviously
these pages, we're going to keep them in the same order. It's just too hard to put them
back in the binder as we went along. Here we have page 121 and I'm going to ask you if
that belongs in that particular position, and I'm going to ask you to take a look towards
the beginning of the book. And I'll try to give you a better indication, when I get back to
my book, as to where that page may have come from.
MR. AUCHINCLOSS: Can I just interrupt? (Off-the-record discussion held at counsel table.)
MR. SANGER: I don't think this is the biggest thing in the world, but if you look at 121
7158 that's in the book right there where you're looking at it -A. Yes.
Q. -- does that appear to be in the correct sequence? Forget about the numbers at the
bottom.

A. Right.
Q. That will just confuse us for the moment.
A. This looks like one of the pages that we looked at yesterday.
Q. In fact, if you look back to -- hesitant to have you flip that because it might fall apart.
A. I'll do my best.
Q. If you look back at Exhibit 334, and now look at the bottom -A. Any idea how far back that is?
Q. 334 is just -Okay. May I approach again? It might be
THE COURT: Yes. He's referring to an exhibit number, not the page numbers now.
THE WITNESS: Oh, I'm sorry. I'm sorry.
Q. BY MR. SANGER: No, no, it's not your fault. Okay. There's Exhibit 334, and now -- if I
may, I'll just speak here briefly -- if we look at the bottom, and you flip forward to 121,
which is MJ00121, does that look like that's the same page?
A. Yes.
Q. All right. And -- all right. May I have the book back? Do you want to look at it,
Counsel? Okay. Thank you. And -- okay. And this is just the way the exhibit is, so we have
to leave the exhibit the same way here. I'm now going to put this copy of 121 up on the
board, just so we're all oriented. There's no date on it; is that correct?
A. Correct.
Q. And you've gone back and you've seen -- this is a second copy of a page we looked at
yesterday; is that right?
A. That's right.
Q. And that was really the page from February the 8th of 2003 -- oops, let me make sure
I said that right. I'm sorry, February the 7th of 2003, correct, when CBS Entertainment
was at the ranch with Ed Bradley and Jack Sussman, and so on?
A. I don't know from yesterday, but if that's the date that it says on the paper, then that's
the day that it was from.
Q. I will represent that's in between the pages for February the 7th in Exhibit 334.
A. Yes.
Q. All right? Okay. So that has nothing to do with the current sequence then, in March. A ll
right?
A. Correct.
Q. Now, on -- on the -MR. AUCHINCLOSS: Counsel?
MR. SANGER: Yeah.
MR. AUCHINCLOSS: Just for point of reference -- it's between the 7th and the 9th. So it's
not keyed to the 7th.
MR. SANGER: Counsel is saying it's between the 7th and the 9th. Suffice it to say it's in
the book in February and we can let the exhibit speak for itself. It doesn't have a date on
it. Is that all right, Your Honor?
THE COURT: Yes.
MR. SANGER: All right. Thank you.
Q. Now, for this particular time period -THE COURT: For a minute I thought the clock was going backwards. (Laughter.)
THE COURT: Go ahead.
MR. SANGER: We'd like to start with February 7th, if we could, please.
THE COURT: All right.

MR. SANGER: And do it all over again.

THE WITNESS: No, we wouldn't.
Q. BY MR. SANGER: No, we wouldn't. I think we all agree with that. We are almost
through, which is always a terrib le thing to hear from a lawyer. But I think it's true in this
case. All right. I'm going to show you now 033698. We're back on Exhibit 335, okay? So
we're going to put this up. Now, I will represent to you, and counsel can d isagree if he
wants, there does not appear to be the regular guest information page for -MR. SNEDDON: Can't see it.
MR. SANGER: I know. It will focus in moment.
Q. There does not appear to be the regular guest information page on March the 10th in
this set where it lists who's staying at the ranch.
A. Okay.
Q. I'll just represent that. And this -- I'm hoping while I'm talking it's going to focus.
There we go. Okay. But this appears to be one of the other pages for March the 10th,
2003; is that correct?
A. Yes.
THE COURT: Can we take a break here?
MR. SANGER: Fine.
THE COURT: Counsel?
MR. SANGER: Your Honor, could we have the screen, please?
Q. Where we left off was MJ0033698 is the identifying number on the bottom, and on the
top it says, 3-10-03. And what I'm going to do, with the Court's permission, is I'm going
to put this back in the book where it was and approach the witness, if I may.
THE COURT: All right.
MR. SANGER: I had time during the break to put all the pages back in the clamps so they
won't fall all over the place. And before I get up, what I'm going to do -- ask you to do,
we had established that this page, 33698, with Jack Sussman on the top, was out of
order, and that was really from February, right?
A. Right.
Q. I'm going to give you the book -- we have to leave it the way it was anyway. I'm going
to give you the book here, and I'm going to ask you to look in this time period, and see if
you have the guest information page for March the 10th, 2003, or if that page seems to
be missing from this, all right?
A. All right.
Q. And you're welcome to flip back and forth, do whatever you want, and then we'll -- I'm
not 7167 going to ask you to look through the entire book, but in the general vicinity.
A. In the general vicinity after it, I don't see it.
Q. Look before.
A. I don't see it.
MR. SANGER: May I approach?
THE COURT: Yes.
MR. SANGER: Thank you. Thank you, sir.
THE WITNESS: Uh-huh.
Q. BY MR. SANGER: Okay. So that brings us back to putting that same page back up,
which is 033698, all right? And we looked at that and that does appear to be from the
10th; is that correct?
A. Correct.

Q. But since the guest information log page is not there, I'm going to ask you to take a
look at this, which is part of the gate activity log. And at 2145 hours, there's an indication
there that Janet Arvizo did not return with Vinnie and Gavin. Do you see that?
A. Yes.
Q. All right. So trying to fill in the gaps on a page that's missing, it appears, from that
entry, that Vinnie and Gavin Arvizo came back to the ranch at 2145 hours, correct?
A. Yes.
Q. And that Janet Arvizo did not come back at that time?
A. Correct.
Q. And we can't tell from that anything about Star and Davellin, but at least we can tell
that much, correct?
A. Correct.
Q. All right. And by the way, the -- just to save some time here, I'll put that same page
back up
again. When these -- when these entries are made on this page, they are made
contemporaneously with the event that's occurring; is that correct?
A. Correct.
Q. So when it says Time there, 2145, that would be the time the gate officer noted
that Vinnie and Gavin had returned; is that correct?
A. According to this, it would be that Janet did not return with -Q. With them.
A. -- Vinnie and Gavin.
Q. So Vinnie and Gavin returned, Janet's not in the car or whatever, and that would have
been at45 hours, correct?
A. Yes.
Q. Okay. Now, having said that, let's go to 0033701, which is for March the 11th, the next
day. And here we have Gavin, Star, and Davellin, whose name is yet spelled a different
way, all staying in Unit 3; is that correct?
A. Yes.
Q. All right. And it looks like they were there overnight from the night before, correct?
A. Yes.
Q. And then it appears that they all left at 1645 hours?
A. Yes.
Q. To go someplace off the ranch, correct?
A. Yes.
Q. And they came back at 1829 hours, correct?
A. Correct.
Q. So they returned to the ranch at that point and there's no indicat ion that they left
again, so you would assume they were there again overnight; is that correct?
A. Correct.
Q. If you look down at the bottom of that page, it appears that Chris Carter checked out
the gray van, correct?
A. Correct.
Q. And he was out and in earlier in the morning, but if you look at the last two entries
there, he left at 1645 hours, and he came back at 1829 hours, correct?
A. Correct.
Q. So it appears that he gave a ride to the Arvizos?
A. Yes.

Q. All right. And then we'll go to the next page. Excuse me. And, Your Honor, this page,
for the record, in the book is the next exhibit page to Exhibit 30 -- or, I'm sorry, 335. It's
the next exhibit page following MJ033701. The number seems to be cut off at the bottom.
I take it it's the same way in the Court's book.
THE COURT: Yes.
MR. SANGER: So I'm referring to the numberless page.
THE COURT: You can see half of it, can't you?
MR. SANGER: Well, that's an optimistic view of this. Let's see if we can get this to focus.
That's all I can see on mine. Is that what the Court is seeing in your book?
THE COURT: Mine's a little clearer.
MR. SANGER: The next page is about half. I'm wondering if we're looking at the same
page.
THE COURT: 702.
MR. SANGER: I believe that's the next page, Your Honor. This is -- well, I don't want to
argue with the Court. I don't know what you're looking at, but that's what we have, and
it's the same in my copy that was given to us by the government.
THE COURT: Okay. It is a different page. I don't have the beginning page -MR. SANGER: All right.
THE COURT: -- which is all right. That's the official exhibit book. So you go ahead with it.
MR. SANGER: All right. So in the official exhibit book, this follows MJ033701 and there's
just the very top of a number there.
Q. And what it is, for the record, is the gate activity log for 3-11-03, correct?
A. Correct. I'm sorry.
Q. I'm sorry. I was talking to the Court, and now I'm talking to you, so, all right. It's a
little hard to read there, but -- and I'm happy to bring it to you to look at. But it does
appear that on the third line down, it says C/O.
A. Yes.
Q. And that would, again, be continued from the night before; is that right?
A. That's right.
Q. And it says Janet Arvizo did not return with Vinnie and Gavin; is that correct?
A. Correct.
Q. So it's another notation in the logbook for the next day that from overnight from the
day before, Janet Arvizo did not return; is that right?
A. That's -- it's just to let the next shift know that that was written on the page before.
Q. All right.
A. Or the day before.
Q. Okay. Now I'm going to go to MJ033703, and this is the last page that I'm going to
show you.
A. Excellent.
Q. Sigh of relief that caused a veritable windstorm up here by the podium.
Okay. That's not going to focus. There we go. Okay. MJ033703, this is on March the 12th,
2003, the next day?
A. Yes.
Q. All right. And on this day, we see Gavin, Star, and Davellin, and it shows that they
stayed in Unit 3; is that correct?
A. That's correct.
Q. And that they had been there overnight, correct?
A. Yes.

Q. And it shows at 12:15, or 15 minutes after noon on that day, March 12th, 2003, that
they left; is that correct?
A. Yes.
Q. And it shows further that -- if you look there, it says, Frank, video library, stayed
overnight, in essence, and stayed overnight. And right below that it says, Vinnie, video
library. He was there from the night before. And it shows at 12:15 he apparently left at
the same time as Gavin, Star, and Davellin, correct?
A. Correct.
Q. And he was gone from the ranch from 15 minutes after noon until 7:49 at night, when
he returned to the ranch -A. Yes.
Q. -- correct? And then he stayed overnight following that; is that correct?
A. Correct.
MR. SANGER: And I have no further questions. Do you want this book here?
MR. AUCHINCLOSS: Yes, please.
REDIRECT EXAMINAT ION BY MR. AUCHINCLOSS:
Q. Unfortunately I'm going to have to return to these records, but I'm going to give us a
little bit of a break, ask you a few questions beforehand.
A. Certainly.
Q. Mr. Sanger asked you about the intruders on the ranch.
A. Yes.
Q. Can you characterize what -- any generalities concerning what type of intruders they
would be? What would their purpose be to try and get onto the ranch?
MR. SANGER: I'm going to object. That's vague.
MR. AUCHINCLOSS: I'll begin by asking you a foundational question. I'll withdraw that
question.
Q. Was there anything that these individuals had in common, any generalities you could
make in terms of their motive to be on that property?
A. Yes.
Q. What was that?
A. To see Mr. Jackson in the ranch.
Q. So these were fans?
A. Yes.
Q. Predominantly not physically threatening to Mr. Jackson?
MR. SANGER: I object. Calls for speculat ion and lead ing.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did these fans, in your opinion as a security guard and based
on your observations of them, appear to present any physical threat to Mr. Jackson, in
general?
MR. SANGER: Objection; lack of foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did you see these intruders on the ranch on occasion?
A. Yes.
Q. How many occasions?
A. Several. Not many came on the ranch while I was working.
Q. During the five years you were there?

A. Yes. We did have -MR. SANGER: Objection, Your Honor. The witness is trying to answer the question.
Q. BY MR. AUCHINCLOSS: How many were there?
MR. SANGER: Excuse me.
THE COURT: I think the last question was, During the five years you were there?
Answer, Yes, we did have..., and then you were interrupted.
THE WITNESS: We did have intruders throughout my working there. When I was working,
at the times that I was working, maybe a handful, five to ten.
Q. BY MR. AUCHINCLOSS: Okay. And in ter ms of -- in terms of staying on top of the
potential security threat from fans entering the ranch, were you generally apprised when
other intruders entered the property when you weren't there?
A. Yes.
Q. So this was part of your job as a security officer to be aware of who might want to get
on the property?
A. Yes.
Q. All right. And during the course of your employment during this five-year period, can
you state whether or not these intruders in general appeared to present any physical
threat to Mr. Jackson?
A. In general, not much physical threat. There were a few, a couple, that we felt could.
Maybe not to him, but we were not just there to protect him. I mean, there was lots of
other people on the ranch.
Q. Okay. And what do you mean when you say they might not present a threat to Mr.
Jackson, but might present a threat to someone else?
A. For the most part, if Mr. Jackson was inside a build ing, he would be fairly secure.
Q. Uh-huh.
A. We didn't have a dozen security guards to post at every door or anywhere -- I mean
everywhere that we could possibly have an intruder on the ranch. But there were -- there
were a few that we were concerned with when they were seen in the area or did happen
to get on the ranch.
Q. Okay. In terms of Frank Cascio, you've testified that you've seen him with Mr. Jackson
about 75 to 100 times. He's visited the ranch over 100 times. Is that accurate?
A. Absolutely.
Q. Are there any guests that you're aware of that you would say had visited Mr. Jackson
on more occasions than Mr. Cascio?
A. Possibly Miko Brando and his family.
Q. Okay. Anybody else?
A. I can't think of any right off the top of my head.
Q. And would Mr. Cascio typically be on the property -- well, let me strike that. Would Mr.
Cascio always be on the property when his siblings were with him?
A. Not always. But most of the time.
Q. Who is Miko Brando?
A. Marlon Brando's son.
Q. In terms of his relat ionship with Jackson, is he an employee?
A. I think so. I don't know. I'm sure -- I know that they're friends. I don't know for certain
if he is employed by Mr. Jackson.
Q. Okay. You said that you were certain that Janet Arvizo had access to the house. Did
you ever see her in the house?
A. No.

Q. Do you have any personal knowledge to base that statement on?

A. She was a guest. Her children had access to the house. I would just, as a security
guard at that time, put two and two together and say she had access to the house.
Q. So that's an assumption?
A. Yes.
MR. SANGER: Objection. Leading; argumentative.
THE COURT: Overruled.
Q. BY MR. AUCHINCLOSS: You testified that typically, ideally I should say, that you would
be notified when guests would be leaving Neverland?
A. Ideally, yes.
Q. Would that -- and that would include children as well as adults?
A. Yes.
Q. And that rule was -- is it fair to say that that rule was -- generally was not really
enforced or followed very often?
MR. SANGER: I will object, Your Honor. First of all, it's vague. And secondly, if it wasn't
vague, it wou ld be leading.
MR. AUCHINCLOSS: Well, I'll strike the question and ask another one.
Q. Can you tell me whether that rule was followed or not?
A. Not often.
Q. In terms of being allowed off the property, you talked a little b it about children,
whether or not they'd be allowed off the property. If a 16-year-old walked up to the gate
and said, I want to take a walk down the road, would you allow them to do so?
MR. SANGER: Objection. Calls for speculation; incomplete hypothetical.
THE COURT: Overruled. You may answer.
THE WITNESS: If they wanted to take a walk down the street?
Q. BY MR. AUCHINCLOSS: Yeah.
A. I don't see why not.
Q. So you wouldn't question their leaving, exit ing the ranch for purposes of taking a walk?
A. No.
Q. And as far as ATV use, you said those were not allowed off the property?
A. That's correct.
Q. So if -- did that rule apply to adults as well as children?
A. Anyone.
Q. Anyone. Okay.
A. Yes.
Q. So if Chris Tucker drove up on an ATV, on one of these quads, you'd say, Sorry, you
can't go off the property?
A. Correct.
MR. SANGER: Objection. Calls for speculation and relevance.
THE COURT: Overruled. The answer was, Correct. Next question.
Q. BY MR. AUCHINCLOSS: Neverland Ranch, is that in the County of Santa Barbara?
A. Yes.
Q. Now, as far as having access to Mr. Jackson, the employees having access to Mr.
Jackson, can you characterize for me the degree with which he valued his privacy on the
ranch?
A. In my opinion, his privacy was most important on the ranch.
Q. Okay. So why do you say that?
A. He never specifically told me that his -- that he wanted his privacy, but that's what we

were there for was to help him have his privacy on the ranch. I tried to impose on him as
little as possible, only if needed be. And that was something that I was taught as I was
trained at the ranch, to let him have his own time. And if we needed to speak to him, we
would. If not, we wouldn't. We'd pass it through a chain of command.
Q. Okay. So if Mr. Jackson was, let's say, in the dance studio -A. Yes.
Q. -- and you knew he was in the dance studio -A. Yes.
Q. -- would you avoid that area; I mean, let him kind of have his space there?
A. Yes.
MR. SANGER: Wait a second. I'm going to object. I'm sorry. Move to strike the answer.
For purpose of objecting, the question was vague and compound.
THE COURT: Overruled.
Q. BY MR. AUCHINCLOSS: Were you encouraged or discouraged in engaging with guests
in conversations?
A. Discouraged.
Q. Discouraged?
A. Yes.
Q. What about privacy for the guests?
A. Same as Mr. Jackson.
Q. Were you aware that Mr. Jackson -- were you ever aware that Mr. Jackson would have
young boys sleep in his room with him?
MR. SANGER: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: You mentioned that you were -- you would report something
illegal if you saw it?
A. Yes.
Q. Were you allowed into Mr. Jackson's bedroom when he had guests in there?
A. No.
Q. Do you know of any employees that were allowed access into his bedroom to see what
was going on in there when he had guests in there?
MR. SANGER: Objection; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: I know that Joe Marcus had access to his room. Or the house manager,
whomever that was at the time. Whether or not they were allowed to go in when he had
guests in his room, I don't know.
Q. BY MR. AUCHINCLOSS: You just know that he had the key, the code; is that what
you're saying? Or you tell me.
MR. SANGER: Objection; leading.
THE COURT: Overruled. You may answer.
THE WITNESS: I know that Joe Marcus was able to get into the -- Mr. Jackson's room.
Whether he had a key or had the key pad, I would assume he had both.
Q. BY MR. AUCHINCLOSS: Who did Joe Marcus report to?
A. Mr. Jackson.
Q. Directly?
A. I believe so, yes.
Q. Okay. Anybody outrank Joe Marcus on the ranch?
A. When he was ranch manager, no.

Q. Okay. Do you know if there were guests allowed on the property without Mr. Jackson's
approval?
MR. SANGER: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Are you aware of any instances, personally aware of any
instances, where an individual was allowed on that property, Neverland Ranch, if Mr.
Jackson -- and Mr. Jackson did not want them there?
A. At the time of them coming on?
MR. SANGER: Objection. Foundation and vague.
Q. BY MR. AUCHINCLOSS: Yes.
THE COURT: Overruled. You may answer.
THE WITNESS: No, generally Mr. Jackson would be the one who allowed people to come
on the property. There was sometimes when somebody would show up and we would call
whomever was in charge, like Jesus Salas or Joe Marcus, and he would make a decision
whether or not they could come on. But for the most part, from what all I remember,
those are people who have been allowed on the property prior to that occasion.
Q. BY MR. AUCHINCLOSS: Was Frank Tyson one of these people?
A. Yes.
Q. So during your evening rounds as a security officer, would you ever have occasion to
see Mr. Jackson during the late and early morning hours?
A. Yes.
Q. Would you ever have occasion to see him with his guests during the late and early
morning hours?
A. Yes.
Q. Were his guests during these periods ever children?
A. Yes.
Q. How often?
A. Often.
Q. Okay.
A. Often. I don't know how to say how often, but often.
Q. And the assignments and guest logs. There are certain rooms that are assigned to
certain guests. Does that mean that that individual who was assigned to that unit
necessarily slept in that unit on that given night?
A. No.
Q. Why do you say that?
A. Because -- well, one of the biggest reasons is we would receive the phone calls in the
evening hours for guests at the front gate. And nine times out of ten, we had to try
several extensions to find that person. The first one you would try would always be where
on the log it said they would be, if it were a guest unit or in the theater or wherever it said
they may be. We went through several d ifferent places. So you would try that first. But it
was -- often we had to go through more than one extension to find someone.
Q. Were there any instances where you'd see children sleep ing in areas of the ranch
where they were not assigned?
A. Yes.
Q. How common was that?
A. Um, it happened. It wasn't uncommon. It wasn't something that happened every time,
but it definitely happened.
Q. Okay. Who is Dr. Farshshian? Do you know that name?

A. I know he's a doctor. I don't know what he's a doctor of. And I know he came to the
ranch often.
Q. Do you know if Dr. Farshshian would ever come to the ranch without Mr. Jackson?
A. I don't know if he did or didn't.
Q. As far as the -- as far as the individual you've named as Chris Carter -A. Yes.
Q. -- you previously identified him as what?
A. Chris Carter?
Q. Yes, and his relationship to Mr. Jackson.
A. As a security guard, I believe personal security guard.
Q. And how often would you see Mr. Carter with Mr. Jackson?
A. Together?
Q. Yes.
MR. SANGER: I'm going to object. Vague as to time.
MR. AUCHINCLOSS: That's fine. I'll refine that question.
Q. When did you first see Chris Carter start to visit Neverland?
A. Oh. Probably in either late 2001 or early 2002.
Q. And was he employed as a security guard for Mr. Jackson at that time?
A. Yes.
Q. Now, you've ment ioned that there are security guards that are personal guards and
security guards that are guards on the ranch.
A. Yes.
Q. The difference is what?
A. Guards on the ranch generally don't travel with Mr. Jackson.
Q. So Chris Carter would be someone who traveled with Mr. Jackson?
A. Yes.
Q. When Mr. Jackson -- well, let me strike that. When Mr. Carter was on the ranch, would
he ever spend any time just as a guest of the ranch, generally speaking?
A. No.
Q. So if Mr. Carter visited -- was on the ranch, would it be fair to say that Mr. Jackson
would generally be with him?
MR. SANGER: Objection; leading.
MR. AUCHINCLOSS: I can rephrase it.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: When Mr. Carter was on the ranch, generally where was Mr.
Jackson?
A. On the ranch.
Q. Okay. Now, you've mentioned during direct examinat ion that there was this grease
board with a message from somebody that says Gavin is not to leave the property.
A. Yes.
Q. And Mr. Sanger has shown you one of the exhibits that says Gavin and Star are not to
leave the property.
A. Yes.
Q. Is there a relationship between the logs that you looked at and the information that
you would normally find on that grease board?
A. Yes, at times there -Q. Would one normally track the other?
A. Yes.

Q. And why is that?

A. So that -- because we don't all -- let's say 7188 there's three of us on duty at the ranch
as security guards. Because we're not all at the front gate at the same time -- for
instance, if we all worked 6 p.m. to 6 a.m., we're not all going to work the gate at 6 p.m.
to 6 a.m. So there would be one at the gate, or two or three, however many more, at the
house, so that both areas of the security, both offices of the security had the same
informat ion.
Q. Okay. So all the security guards would be on the same page working to fulfill those
directives?
A. Correct.
Q. Now, I believe the directive that appears in the log, if I remember correctly -- let me
just find it here. If I could have the Elmo, Your Honor. The date on this particular exhibit is
2-19-03. And this is the one that has, The kids are not to leave per Joe. Let's get the
entire statement in there, and I believe that's at 5:52. Now -MR. SANGER: Your Honor, I'm sorry, just for the record, could we have the page number?
MR. AUCHINCLOSS: Oh, yes. Certainly.
MR. SANGER: And the exhibit number.
MR. AUCHINCLOSS: That's a good point. This is Exhibit No. 334 and it's page number 154.
Q. Have you ever seen a d irective like this on one of the logs before that told the security
guards not to let a child off the property?
A. No.
Q. Have you ever seen a d irective before like the one you saw on the grease board that
said, Do not let Gavin off the property?
A. No.
Q. During your five years, did you ever see anything of that nature during your
employment?
A. No.
MR. SANGER: Objection; asked and answered.
MR. AUCHINCLOSS: I said before, and this contemplates the entire period.
THE COURT: All right. The objection is overruled. It's answered.
Q. BY MR. AUCHINCLOSS: As far as this date goes, February 19th, are you aware whether
or not Janet Arvizo was scheduled to return to Neverland on that particular day?
A. I'm not aware if she was.
Q. All right. I have a few questions about the logs and I'll be done. Beginn ing with the log
for 334, Exhibit 120, we've had considerable testimony about this particular page. Now,
first of all, let me ask you, based upon your review of the logs and your experience in
working with these logs, how would you characterize the degree of accuracy that is
recorded?
MR. SANGER: I'm going to object. Are we talking about this particular page or are we
talking about -MR. AUCHINCLOSS: In general.
THE WITNESS: In general, they were -- can I answer?
THE COURT: Sure.
THE WITNESS: Sorry. In general they were accurate. Obviously we make mistakes
spelling names. There was that issue. But they were accurate.
Q. BY MR. AUCHINCLOSS: And as far as this particular page goes, which is at the bottom,
2-7-03, this shows that the Arvizos are a carry-over from the previous day?
A. Yes.
Q. And if we go back to the preceding day, we have -- I'm now showing you 2-6-03. We

have this guest information -MR. SANGER: Your Honor, excuse me. Could we have a page number?
MR. AUCHINCLOSS: Yes, thank you. That same exhibit, 00116.
Q. Now, if Gavin, Star, and Davellin were on the property, if the Arvizos were on the
property on 2-7-03 as a carry-over, shouldn't they be reflected in this document on
February 6 somewhere in Guest Informat ion?
A. Yes.
Q. So how do you explain that?
MR. SANGER: Calls for speculat ion, Your Honor.
MR. AUCHINCLOSS: Not necessarily.
MR. SANGER: And lack of foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: Either it was completely overlooked or they weren't there.
Q. BY MR. AUCHINCLOSS: Would you agree there clearly is an error in the logs
somewhere on those two pages?
A. Yes.
Q. Now, as far as the Owner and guest notation there that you see, I believe you were
shown that by Mr. Sanger, and you responded that there was something odd about that?
A. Yes.
Q. What is it that you find curious about that entry?
A. What strikes me is that we would never -- I would never, and I don't believe anyone
else would ever write Owner down, Owner and guest, on one of these logs. Again, for
his privacy. We never logged him in or out.
Q. Okay. Would you sometimes make a notation if he was to be expected on the property?
A. On one of these sheets?
Q. On a sheet somewhere; just that, Mr. Jackson is expected to come today, or
something of that nature.
A. No, that was generally verbal.
Q. Okay. But as far as an entry on -- in this particular fashion, you've never seen this
before?
A. No.
Q. Never seen it during your five years there?
A. No.
Q. Do you recognize that handwriting at all?
A. No. I can barely read it. But, no, I don't recognize it.
MR. AUCHINCLOSS: All right. If I could just have a moment, Your Honor.
THE COURT: Yes.
Q. BY MR. AUCHINCLOSS: Do you know an individual by the name of Klein?
A. Is there a first name?
Q. Doctor?
A. Dr. Klein. I remember the name of Dr. Klein.
Q. Okay. And did that have any relationship to your employment at Neverland?
A. Yes.
MR. SANGER: I'm going to object. It's beyond the scope of cross.
MR. AUCHINCLOSS: I believe counsel showed him a document that had Dr. Klein's name
on it.
THE COURT: All right. Overruled.
Q. BY MR. AUCHINCLOSS: And how do you know Dr. Klein?

A. Just that he came to the property.

Q. Do you know what his relationship was to Mr. Jackson?
A. No.
Q. Do you know if he would be a guest of Mr. Jackson's when Mr. Jackson was not
present?
MR. SANGER: Objection. Lack of foundation, Your Honor, and relevance.
THE COURT: Overruled. You may answer.
THE WITNESS: I don't recall if he was ever there without Mr. Jackson being there.
Q. BY MR. AUCHINCLOSS: Okay. W hen one of the Rolls or the Bentleys would leave the
property, can you tell me whether or not Mr. Jackson would generally be associated with
the use of that vehicle, such a vehicle?
MR. SANGER: Objection. Vague and lack of foundation.
THE COURT: Sustained on vague.
Q. BY MR. AUCHINCLOSS: W hen you were conducting your daily duties at the security
guard booth
A. Yes.
Q. -- would you see Mr. Jackson coming and going onto the property?
A. Yes.
Q. Would he typically be in a vehicle?
A. Yes.
Q. Would you see an occasion where the Bentley or the Rolls was used?
A. Yes.
Q. Would you be able to see if Mr. Jackson was in that vehicle?
A. In the Rolls, the older Rolls Royces, yes, because there wasn't as dark a tint as on the
Bentley. The Bentley was very dark tinted.
Q. Can you tell me, were those cars generally used when Mr. Jackson was being
transported somewhere?
A. The Bentley in particular, yes.
Q. And I'm going to direct you to Exhibit No. 191, and/or I should say Exhibit 335, page
number 191, if I can find it. It's not in order. Here we go. That's the wrong exhibit. I'm
sorry, Your Honor. That actually co mpletes my redirect. Thank you.
RECROSS-EXAMINATION BY MR. SANGER:
Q. I know you want to go home.
A. Yes, sir.
Q. I'll try to get you out of here. First of all, you had occasion to meet Michael Jackson
from time to time, correct?
A. Yes.
Q. Had a chance to talk with him from time to time, correct?
A. Yes.
Q. And you felt it was appropriate to respect his privacy at his home, correct?
A. Correct.
Q. There was nothing weird about allowing a celebrity to have private t ime at his home,
was there?
A. No.
Q. And in fact, how many employees were there at the ranch, roughly, during the time
you worked there?

A. Probably around 80. Between 80 and maybe 100.

Q. So if 80 or 100 people came up and spent a minute with Mr. Jackson every time, every
day, he would have no privacy, correct?
MR. AUCHINCLOSS: Objection; argumentative.
THE COURT: Sustained.
Q. BY MR. SANGER: Okay. In other words, with that many people or even with a few
people, it would be important to allow a person whose home it was to spend time at their
home and not be bothered by people who are employed there to work for him, correct?
MR. AUCHINCLOSS: Same objection.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes.
Q. BY MR. SANGER: Okay. Now, in the course of knowing Mr. Jackson in the context that
you just described, Mr. Jackson is sensitive to the sun; is that correct?
MR. AUCHINCLOSS: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. SANGER: Were you aware that he took measures to try to avoid direct
sunlight?
MR. AUCHINCLOSS: Objection; exceeds the scope.
MR. SANGER: Not at all. Dr. Klein.
THE COURT: Overruled. (Laughter.)
THE WITNESS: Was I aware -Q. BY MR. SANGER: That he took measures to avoid direct sunlight.
A. Yes.
MR. AUCHINCLOSS: Object as to foundation.
THE COURT: Overruled.
MR. SANGER: And the answer's in, Your Honor?
THE COURT: Yes.
MR. SANGER: Thank you.
Q. Were you aware that Dr. Klein was the dermatologist treating Mr. Jackson's vitiligo?
A. No.
Q. Were you aware that he was a dermatologist?
A. I was aware that he was a doctor.
Q. And you believe he was Mr. Jackson's doctor for one problem or another; is that
correct?
A. Yes.
Q. All right. Now, there was testimony on direct and then redirect again about this
notation on the grease board and the notation in the logs on page -- it was 154 of Exhibit
334 about -- the notation on the grease board you recall was specific to Gavin. Gavin
should not leave the property; is that right?
A. Gavin is not allowed off property.
Q. That's your recollection of what was on the grease board, correct?
A. Yes.
Q. And your recollection of what was in the log is what, in fact, was shown to you in
Exhibit 334, page 154. May I, your Honor?
THE COURT: Yes.
Q. BY MR. SANGER: Page 00154, and again, it says -- the whole quote is, The kids are
not to leave per Joe. Kids meaning like Gavin, Star, et cetera, right?
A. Right.

Q. And this was on the log of - you can see in there - 2-19-03, correct?
A. February 19th.
Q. February 19th, 2003, correct?
A. Yes.
Q. And that was that time period where you had so many people on the ranch that you
had this master list on 2-17, and then the regular posting of guests didn't resume again
until after 2-20. You resumed again on 2-21-03, correct?
A. Yes.
Q. All right. So it was not possible to track everybody's movements on and off the ranch
during that period of time; is that correct? They weren't all logged in and out as they
should have been?
A. Not possible to -Q. Track whether or not people left and came back on the ranch between that 2-17 and 220 when they were all kind of lumped together?
A. I believe there's even a note on the bottom of that page that that's going to be carried
over through those periods. I believe it would be easy to keep track of who comes and
goes on the property. In answer to your question, no, I believe that it could be tracked -Q. Okay.
A. -- who was coming and going.
Q. All right. And I'm going to -A. Maybe not by paperwork, but it could have been done.
Q. Okay. It could have been done, but the paperwork here is somewhat deficient in that
regard, isn't it? Let me put up 149, which is the page that said 2-17 through 2-20. And
that's where we had everybody there on that big list, correct?
A. Correct.
Q. And, for instance, it shows for the Arvizo family, the kids, it shows carried over from
the day before, and it shows 1951 hours out, and it doesn't show back in.
A. Well, if you lift -- scoot the page back so we can see the bottom.
Q. Certainly.
A. If I were working the gate at this time period and I saw that note on the bottom, List
until guest departs, C-1, which is for Charles 1, which was Curtis Gordon, who was a
supervisor, I would take that to mean that they came in on -- or the carry-over happened
on the 17th, and their time out was on the 20th.
Q. Okay. I understand. So your interpretation of this, if this were accurate, is that the
Arvizos did not leave until the evening of the 20th, 1951 for the children, and 2145 for
Janet, correct?
A. Correct.
Q. So again, everybody gets this, but 7:51 at night and 9:40, whatever that says, at night
for Janet, correct?
A. Yes.
Q. Now, were you -- are you aware, as you sit there right now, that the Arvizos were in
Los Angeles on the evening of the 19th?
A. No.
MR. AUCHINCLOSS: I'm going to object as to the form of the question being -- assuming
facts.
THE COURT: The answer is, No. Next question.
Q. BY MR. SANGER: And if they were in Los Angeles on the evening of the 19th, there is
no indicat ion in these logs that they left the ranch for that purpose; is that correct?

A. That's correct.
Q. All right. And, now, turning to 154 again, which we've all seen, 2-19, it says 1752, so
that's 5:52, just before six o'clock in the evening on the 19th. If the Arvizos were
supposed to be available for the purpose of going to Los Angeles for a videotaping, would
it be reasonable for the gate to be advised that the kids should not leave the ranch?
MR. AUCHINCLOSS: I'm going to object as argumentative and assuming facts not in
evidence.
THE COURT: Sustained as argumentative.
MR. SANGER: All right.
Q. Let's put it this way: In other words, as part of the duties of somebody at the gate,
would you feel it was an appropriate instruction that somebody not -- whether it's an adult
or a child, that somebody not leave the ranch if they're expected to be available to get
into a car to go somewhere?
MR. AUCHINCLOSS: Objection. Argumentative; calls for a conclusion.
THE COURT: Sustained.
MR. SANGER: All right.
Q. Now, whatever that notation is for, was that notation placed there in a place on these
gate activity logs where any and all of the security staff would be able to read it?
A. Any and all that were working that day, yes.
Q. Okay. And was it -- are these records kept as permanent records ?
A. I believe so.
Q. All right. So presumably months later, years later, somebody could go back and find
that notation, right?
A. Yes.
Q. This is not a secret communication that was designed to be destroyed after people
received the information, correct?
A. Correct.
Q. Okay. It was left as a permanent memorial to something that was instructed or
something that was communicated to the security staff; is that right?
A. Yes.
Q. And when you talk about this grease board, any message that was on the grease board
was put there so that anybody on the security staff could see it; is that correct?
A. Correct.
Q. And anybody else that consulted the records could also see it, obviously; is that right?
A. These records.
Q. I'm sorry, you're right. You're up all night and I'm getting confused, so let me clarify it.
First of all, the grease board. Anybody that came into the security office could see that
grease board and would be able see what was up there, right?
A. Yes.
Q. And that was right in the front room, correct?
A. Correct.
Q. The doors are often open?
A. When someone comes in and out.
Q. There's windows there?
A. Yes.
Q. Administration people can come down and do often come down into the security office,
correct?
A. Correct.

Q. So there's people that would work up in the administration build ing, the ranch
manager, the ad ministrative assistants and so on, correct?
A. Yes.
Q. Firemen could go in there and see that, correct?
A. Yes.
Q. You of course could see it, and you were a sworn peace officer, right?
A. Correct.
Q. All right. And then similarly, with regard to those records, the gate log records, those
were maintained so that people from the administration could review them, correct?
A. Correct.
Q. And again, firemen and other security officers could review them?
A. Yes.
Q. So this was not a secret?
A. No.
Q. Thank you. Now, you indicated that sometimes assignments got -- let me withdraw
that. The question was about room assignments. Was there really a room assignment
system?
A. Yes, at times there were.
Q. Okay.
A. Especially with the guest units.
Q. Who assigned people guest units?
A. Generally it would be the -- whomever was in charge of the house, or at times who was
in charge of the housekeeping, or the ranch manager.
Q. Okay. So was it your understanding that those -- that somebody like that would
actually tell the guest, You are assigned to this unit?
A. Yes.
Q. Okay. And if guests wanted to stay someplace else, for instance, somebody said, Boy,
I'd really like to have Unit No. 4, would an effort be made on the part of the staff to allow
that person to have that unit?
A. I never was invo lved in that.
Q. Fair enough. If somebody wanted to stay, for instance, out at the theater rather than a
guest unit, would they be accommodated, for the most part?
A. For the most part, yes.
Q. All right. Now, sometimes somebody might be assigned, say, to a guest unit and they
would decide, Well, I'd really rather stay out at the theater. That could happen, right?
A. Sure, it could happen.
Q. They might ask permission of somebody, whatever happens; they end up staying out
at the theater on Night No. 1?
A. Okay. Yes.
Q. And it's -- it's generally -- it generally becomes known where the guests are staying; is
that correct?
A. Eventually, hopefully.
Q. Okay.
A. Yes.
Q. But guests may make requests for food or other services on a -- well, let me ask that.
They may do that from time to time?
A. Yes.
Q. In fact, it's very common for people to call for food or drink or something and have it

delivered to where they are?

A. Yes.
Q. And security eventually beco mes aware of where people are, either through them
requesting services, or phone calls coming in for them, or something else, right?
A. Yes.
Q. And so if somebody is logged in repeatedly in the same unit in the security logs, that
would tend to indicate that security is now pretty much aware that that's where the
person is staying; is that right?
A. Yes.
Q. All right. Now, you remember Davellin, do you not?
A. Vaguely.
Q. Vaguely. Do you remember -- and you remember Marie Nicole?
A. Yes.
Q. During this time period, do you remember Davellin and Marie Nicole hang ing out
together?
A. Yes, I believe I do.
Q. And they seemed to be good friends; is that correct?
A. Yes.
Q. And did they seem to be having fun?
A. Yes.
Q. All right. And they'd walk around the property and have a good time?
A. Sure.
Q. All right. And do you recall Davellin and Marie Nicole staying out at the theater during
this period of time?
A. Yes, I do.
Q. So in addition to the log entries, you personally recall them being out -- staying out in
that area; is that correct?
A. Yes.
Q. Okay. And I believe one last area I want to ask you about here that was brought up by
Mr. Auchincloss. You have experience as a police officer, and also experience being a
security guard for Mr. Jackson, a major celebrity, and I'm going to ask you, drawing on all
of that, do you assume that intruders are not going to be a danger to anybody?
A. No.
Q. In fact, you assume they're going to be a danger?
A. Yes.
Q. You have to do that. And you're aware of celebrity stalkers, are you not?
A. Yes.
Q. And you're aware of instances where celebrity stalkers, even though they were fans,
did harm to celebrities, correct?
A. Yes.
Q. And did harm to people around celebrit ies, correct?
A. Yes.
Q. Were you aware that one of the intruders actually got into the train room upstairs in
Mr. Jackson's house?
MR. AUCHINCLOSS: I'll object. Assumes facts.
THE COURT: Overruled You may answer.
THE WITNESS: The third floor of the house?
Q. BY MR. SANGER: Yes.

A. Yes.
Q. And you would consider that to be a serious intrusion into Mr. Jackson's security, would
you not?
A. Yes.
Q. Were you aware that one of the intruders was possessing a handgun?
A. No.
Q. A number of these intruders were actually arrested, the sheriff was brought on, and
they were arrested and taken away; is that correct?
A. Correct.
Q. And some of the repeat intruders were actually prosecuted by the District Attorney's
Office; is that right?
A. Yes.
MR. SANGER: Okay. Thank you. No further questions.
FURTHER REDIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. Generally speaking, based on your experience and not on what you anticip ated, what
did these intruders want?
MR. SANGER: I'm going to object. That's -- that's vague.
THE COURT: Overruled. You may answer.
THE WITNESS: What did they want?
Q. BY MR. AUCHINCLOSS: Yeah. Why did they want to come on Neverland?
A. They wanted to see Mr. Jackson.
Q. Just see him?
A. See him.
Q. Maybe meet him?
A. Yes.
Q. That's all?
MR. SANGER: Objection. Calls for speculation, Your Honor.
THE COURT: Argumentative; sustained.
Q. BY MR. AUCHINCLOSS: As far as the grease board goes, you previously testified that
that instruction was on the board for approximately a week?
A. That's about the length that I remember it being there.
Q. Did you take that instruction seriously for the entire week?
A. Yes.
Q. Did you consider that to be an order to not let Gavin off the property for that entire
period of time?
A. Yes.
Q. And can you tell me, based on your experience and training at Neverland, who would
have authority to make such an order on the grease board and in the logs?
A. Well, ultimately Mr. Jackson.
Q. Okay. And who would do -- who would ultimately? How would the chain go? Who put
stuff up on the board?
A. Generally one of my supervisors.
Q. And who was your supervisor?
A. Either Curtis Gordon, Julio Magana or Violet Silva.
Q. And who do they report to?
A. Joe Marcus.

Q. And who does he report to?

A. Mr. Jackson.
MR. AUCHINCLOSS: Thank you. No further questions.
FURTHER RECROSS-EXAMINATION BY MR. SANGER:
2Q. Now, when you say report to, you have absolutely no evidence whatsoever that Mr.
Jackson himself gave an instruction that Gavin was not to go off the ranch; is that true?
MR. AUCHINCLOSS: Objection; argumentative.
THE COURT: Overruled. You may answer.
THE WITNESS: I have no knowledge of him giving that.
Q. BY MR. SANGER: All right. And the fact that people report -- Mr. Jackson owns the
property, to your knowledge, correct?
A. To my knowledge, yes.
Q. Okay. And the fact that people ult imately report to the owner of the property does not
mean that they get every instruction that they communicate down the line from the owner
of the property, correct?
A. Correct.
Q. So it's entirely possible, based on your understanding of this chain of command, that
somebody somewhere in the midd le, up or down, in this chain of command decided to put
this on the grease board, correct?
A. It could have happened, yes.
Q. And you certainly never saw Mr. Jackson come in and write anything on the security
grease board himself, correct, sir?
A. That's correct.
Q. And you never saw Mr. Jackson write anything himself into the gate logs; is that
correct, sir?
A. Correct.
MR. SANGER: Okay. Thank you.
MR. AUCHINCLOSS: One last question.
FURTHER REDIRECT EXAMINATIO BY MR. AUCHINCLOSS:
Q. Are you aware, during the course of your employment at Neverland, of any motive,
reason, why Joe Marcus, Violet Silva, Curtis Gordon, Julio Magana, any of these
individuals, any -- are you aware of any reason why they would want to have Gavin Arvizo
kept on the Neverland property?
A. No.
MR. SANGER: Calls for speculation, Your Honor.
THE COURT: Sustained.
MR. AUCHINCLOSS: Thank you. No further questions.
MR. SANGER: And move to strike the answer. I think it did come in or was said.
THE COURT: I'll strike the answer.
MR. SANGER: Thank you. He had no questions. There were no questions, so I have no
questions.
THE COURT: You're free to go.
THE WITNESS: Thank you, sir.

STEPHEN CLEAVES EXAMINATION

DIRECT EXAMINATION BY MR. SNEDDON:
Q. You're a sergeant employed by the Santa Barbara County Sheriff's Department,
correct?
A. That's correct.
Q. How long have you been with the department?
A. 25 years.
Q. And your current assignment?
A. I'm working special operations.
Q. And you live in Santa Ynez?
A. That's correct.
Q. And on November the 18th of 2003, were you part of a group of people who executed a
search warrant at Neverland Valley Ranch?
A. I was.
Q. And what was your particular responsibility on that day?
A. To supervise a group of investigators that went and searched the security offices for
files.
Q. And when you say security office, where was that located on the premises?
A. It was part of the main residence at the far west end, I believe that is.
Q. Was it directly connected to the residence or was there a breezeway between the two
buildings?
A. I believe there's a breezeway.
Q. Now, when you got to the security office, you said that you were assigned a particular
responsibility in that office.
A. That's correct.
Q. What was the responsibility?
A. To look for files or computers. Specifically, we had a list of names that we were looking
for that -- of persons who came on or off the ranch.
Q. And did those names include the Arvizo family?
A. Yes, they did.
Q. And other individuals?
A. They did.
Q. Now, did you actually participate in looking through the records yourself?
A. I did.
Q. And from where did you obtain the records?
A. There were several boxes of -- cardboard boxes that had files stored in them in that
room, and we ultimately went through each one of those boxes and then pulled the files
with the names that we were looking for.
Q. So with regard to the search that occurred, all of the boxes and all the files contained
in that security office were viewed by you or other members -- or the people working with
you in that task?
A. That's correct.
MR. SANGER: Objection. Calls for speculation; lack of foundation; and leading.
THE COURT: Overruled. Next question.
Q. BY MR. SNEDDON: Did you personally, as a result of your efforts in looking through
these materials, take into your custody and control certain exhibits?

A. I did.
Q. And do you recall just approximately how many -- well, first of all, what were the
nature of the items that you actually took into your custody and control?
A. Mine were files, and they were related to the gatehouse log entries and/or any medical
injury incident reports. I believe all of mine were directly related to the entry logs, though,
for the ranch.
Q. And when you went through the items and you saw items that you felt were items that
you wanted to seize pursuant to the search warrant, what did you do with those items?
A. As we went through the box, we would collect the items that we wanted to seize and
set them aside, comp leted the box, and then we took the items over to Deputy Moeller,
who was our seizing officer, and turned them over to him. He assigned them an item
number and packaged them for evidence.
Q. And that's what you did with regard to the items that you took?
A. That's correct.
Q. Now, do you recall whether or not any of the documents that you went through
personally that day involved any records beyond December 31st of the year 2002? In
other words, did you find any records for the year 2003?
A. I -- I don't believe so, no.
MR. SNEDDON: No further questions.
CROSS-EXAMINATION BY MR. SANGER:
Q. Sergeant Cleaves, in your 25 years with the Santa Barbara Sheriff's Department, what
kinds of duties did you have?
A. Started off in patrol, working down in Goleta. Was transferred to Solvang, Santa Ynez.
Worked there for a number of years. Went back down to special operations, where I
worked vice, narcotics, gangs, and then was assigned to the helicopter crew. Was
promoted to sergeant, transferred to Santa Maria. From Santa Maria, back to Santa Ynez.
From Santa Ynez, back to Santa Maria. And then back to Santa Ynez, and I'm currently
working in special operations.
Q. Special operations is a -- is that a detective assignment?
A. It is.
Q. All right. And in this particular case, the extent of your assignment in this case was
essentially to assist with this search and look for some records in the office?
A. That's correct.
Q. And did you search anyplace other than the security office?
A. Our search also -Q. I'm sorry. I was vague. Let me clarify the question. Did you personally search anyplace
other than the office?
A. I did.
Q. Where else did you search?
A. The garage immed iately to the rear of the security office. And the video library that was
upstairs above that office.
Q. You did not search the administration build ing; is that correct?
A. No.
Q. In fact, there was not a warrant to search the administration building, correct?
A. I don't know. I just searched the area that we were asked to search.
Q. So did you review the warrant?

A. I did.
Q. And you were given a briefing -A. Yes.
Q. -- the morning of the search?
A. Yes.
Q. Is that correct, sir?
A. Yes, yes.
Q. And prior to your searching, you were given a copy of a protocol; is that right?
A. A protocol.
Q. It was a -- I forgot the name of -- a memorandum, in any event, that explained what
the case was about and what you were looking for?
A. We received the warrant, we read the warrant. And my assignment was to do the
security wing, and that's what we did.
Q. Do you remember whether or not you got a little packet that included an outline of
what the case was about and who the significant parties were and that sort of thing?
A. I don't recall that. I do recall getting a list of names that we were supposed to look for
in the security office.
Q. And you got a copy of the affidavit for the search warrant?
A. Right.
Q. So you had a chance to familiarize yourself with that; is that correct?
A. Yes, sir.
Q. And the affidavit would have been something that explained to the judge issuing the
warrant, would have explained what your department thought the case was about, and
why you should be allowed to search, correct?
A. True.
Q. Correct?
A. Yes.
Q. And -- all right. Did you have a copy of the warrant itself, see a copy of the warrant?
A. We did get a copy of the warrant and we did read it, yes.
Q. Was it your understanding, from all of that information, that the warrant was for the
main residence, correct?
A. Yes.
Q. And it was for the security office, correct?
A. Yes.
Q. And it was for the separate building that was described as an arcade; is that correct?
A. I don't specifically recall that.
Q. All right. In any event, it was not for every building on that ranch, was it?
A. I don't have that specific knowledge.
Q. All right. In any event, to your knowledge -- well, let me withdraw that. Aside from
where you said you looked, which would have been the security office, and then in that
same building, which was part of the garage, correct?
A. Correct.
Q. You looked in the garage?
A. Correct.
Q. And then you went upstairs in that same building and you looked in the video library,
correct?
A. Correct.
Q. All right. Other than that, you did not search any other part of that ranch, you

personally, for records, correct?

A. No, I did not.
Q. And are you familiar with Brian Barron?
A. I know the name. A security guard.
Q. Were you aware that he was a sworn peace officer?
A. At the time of the search I don't believe so.
Q. You're aware -A. I hadn't paid attention.
Q. You are aware now; is that correct?
A. Yes.
Q. And if he has indicated that records are accurate, as presented to him in court by the
prosecutor that pertain to these gate logs, would you have any reason to believe that he
was incorrect?
MR. SNEDDON: Your Honor, I'm going to object. Calls for speculation; no foundation.
THE COURT: Sustained.
MR. SANGER: Okay. I have no further questions.
MR. SNEDDON: Nothing further.
THE COURT: Thank you. You may step down.

TIMOTHY SUTCLIFFE EXAMINATION

DIRECT EXAMINATION BY MR. SNEDDON:
Q. Actually, just to clarify things, you're the same Timothy Sutcliffe who testified
previously in this case?
A. Yes, I am.
Q. That was a long time ago, but -- now, everybody probably recalls this, but just for the
purposes of refreshing people's recollections, you're employed by the Santa Barbara
County Sheriff's Department?
A. That is correct.
Q. And your current assignment is?
A. I work for the Criminal Investigations Division in the Forensics Unit.
Q. And was that your assignment back on November 18th of 2003?
A. Yes, it was.
Q. Now, on that particular date, were you assigned to assist Sergeant Cleaves in the
review of certain records and files in the security office of Neverland Valley Ranch during
the execution of a search warrant?
A. Yes, I was.
Q. Now, tell me what you did on that particular day with regard to the records in the
security office.
A. We were given a list of names of individuals that -- to search for specific items. We
were checking through the security documents, which were gate logs and guest lists, for
those particular names, and I did find some of those items.
Q. And with regard to the items that you found, what did you do with them?
A. As I collected those items, I then gave those to Detective Moeller, who listed them on
the SH-451 property form.
Q. Now, prior to testifying here today, I asked you to review the logs that you personally

took on the occasion of the execution of that search warrant on November 18th. Do you
recall doing that?
A. That's correct.
Q. And I specifically asked you to review those logs to see whether or not you found the
name of Janet Arvizo on any of those documents that you took.
A. That's correct.
Q. And with regard to the documents you took, you found the name of the Arvizo children
listed, did you not?
A. Yes, I did.
Q. And on the documents that you reviewed, d id you find the name of Janet Arvizo listed
as a guest at the ranch during any of those occasions?
A. No, I did not.
Q. Now, the records that you found, describe to the jury the process that you went
through personally to take the records.
A. There were several boxes of records, and there was a filing cabinet, and I had selected
a specific box to go through of records. And as I was pulling the records out, looking over
each individual record searching for those individuals' names, then I would set those
aside. And when I was done with a particular box or file, I'd hand those to Detective
Moeller so he could enter those into the 451 form.
Q. All right. Now, lastly, with regard to the logs and the documents that you actually took
on this particular occasion, did you find or take any logs that went beyond the date of
December 31st of 2002?
A. Can I check my -Q. Do you need to refresh your recollection on that?
A. Yes, I do.
Q. What document are you doing that from?
A. The SH-451 form.
Q. All right. Please take a look at it and see if it refreshes your recollection. That's just for
the documents you took, now.
A. Correct. Yes, just the last entry is 12-2 of .02.
Q. Nothing with regard to the year 2003?
A. No.
MR. SNEDDON: Thank you. No further questions.
CROSS-EXAMINATION BY MR. SANGER:
Q. Detective Sutcliffe, how are you?
A. Good morning.
Q. The logs that you saw were located in the security office; is that correct?
A. That's correct.
Q. All right. And that is, once again, the office at the end of the building that has the
garage on the first floor and the video library on the second floor; is that correct?
A. That's correct.
Q. Did you search the administration building? Do you know where the administration
building is?
A. No. If you could tell me where it is.
Q. Up on the hill.
A. No, I did not search the administration building.

Q. Okay. Did you -- did you -- and you were briefed before you went out there to do the
search; is that correct?
A. That's correct.
Q. The search warrant did not include the administration building, did it?
A. I don't recall on that.
Q. Okay. And you did not search the office at the gate; is that correct?
A. No, I did not.
Q. You said the last record you have an entry for in your sheriff's booking form is
December 2, 2002; is that correct? Is that what you just said?
A. Can I check?
Q. Sure. Certainly. I thought I was wrong. But you need to look. That's fine. Okay.
A. Yes, 12-2 of .02.
Q. Okay. That's the last record you seized; is that correct?
A. That's the last -- the latest date.
Q. That's the last date or the latest date that you seized, correct?
A. That is correct.
Q. That is not the latest date that you saw?
A. I don't recall any further than that.
Q. Do you recall seeing records there at that office that went through the end of 2002?
A. Yeah, I -- I recall. I think there was some 2003 records as well.
Q. Some 2003?
A. But I didn't seize those, no.
Q. In any event, you just seized the records up to the date -- let me withdraw that. You
just seized the records that had entries for the names that you were looking for, correct?
A. Correct.
Q. And you did not make any record of the last date of any records that were there; is
that correct?
A. I don't understand the question, I'm sorry.
Q. That's fine. You did not make a note of the last -- the most recent record that was
there present in the office; is that correct?
A. The only ones I'm real familiar with are the ones I collected. And the last date of the
items I collected was -- the latest date was 12-2 of 2002.
Q. Okay. My question was, you did not make a note of the latest date that was present in
the office, did you?
A. No, I did not.
Q. And your recollection was, however, that you did not have the current logs for 2003,
correct?
A. I recall that there was some 2003 logs. I just remember dates for 2003, but I don't
recall what exactly they were.
Q. Okay. You didn't have logs -- this was November 18th, 2003, that you're there, right?
A. Correct.
Q. You didn't have the logs for November 17th, for instance, did you?
A. Not that I'm aware of.
Q. All right. And you did not locate the current logs for the recent months of 2003 in your
searching, correct?
A. I personally did not, no.
MR. SANGER: All right. I have no further questions. Thank you.

REDIRECT EXAMINAT ION BY MR. SNEDDON:

Q. Well, let's just get this straight so everybody understands it. You were only authorized
by the warrant to seize documents through the time that the Arvizo family was there, isn't
that correct, through March of 2003?
A. That's correct.
Q. So there would be no reason to look for documents in April, May, June, July, Novemb er
of 2003?
MR. SANGER: Objection. That's leading and it's also argumentative.
THE COURT: Sustained.
Q. BY MR. SNEDDON: In the execution of the search warrant, are you bound not to review
the records that go beyond the period authorized by the judge in the warrant?
A. Yes.
Q. Now, with regard to whatever document you may have seen in 2003 that would have
been within the time limit of the warrant itself, did you personally see anything within
2003?
A. No.
MR. SANGER: Excuse me, I'm going to object to that question. The way it's phrased is -it's vague and it's also compound, if I understand it at all.
THE COURT: Sustained.
Q. BY MR. SNEDDON: Did you personally see any documents during your examination of
the records covering the month of January 2003?
A. I don't recall the specific month. I just remember seeing 2003s. Seems to me that
there was some, but I don't recall any specific information about 2003.
Q. In the execution of the warrant, if you'd seen something during the time period set
forth in the warrant, in other words, January, February, March of 2003, and it contained
the name of any of the parties that you were looking for, would you have taken it?
A. Yes, I would have.
MR. SNEDDON: Nothing further. No further questions.
THE COURT: Thank you.
MR. SNEDDON: Investigator Rooney.
THE COURT: We'll take our break.
MR. SNEDDON: Okay. (Recess taken.)

TIMOTHY ROONEY EXAMINATION

DIRECT EXAMINATION BY MR. SNEDDON:
Q. Mr. Rooney, you're employed by the Santa Barbara County District Attorney's Office,
correct?
A. Yes, sir.
Q. How long have you been with the District
Attorney's Office?
A. 16 years.
Q. And in what capacity are you employed by the District Attorney's Office?
A. Senior criminal investigator.
Q. Before that, did you have law enforcement experience?

A. 11 years with Santa Barbara Police Department.

Q. Okay. Now, on November the 11th of -- November the 18th, I'm sorry, November
18th, 2003, were you assigned to particip ate in the execution of a search warrant on
Neverland Valley Ranch?
A. Yes.
Q. And what were your -- was part of the assignment that you were given that day to
participate in the review of some documents and logs in the security office?
A. Yes.
Q. And were you working in conjunction with other people in doing that?
A. Yes, sir.
Q. I'm not sure that mike's working. You might want to try that one there.
A. Okay.
Q. And who was it that you were working with in processing these documents?
A. Sergeant Steve Cleaves from the sheriff's office, Deputy Moeller from the sheriff's
office, Tim Sutcliffe from the sheriff's office, Shelly Sweeton, a criminal investigator with
the District Attorney's Office, and myself.
Q. And from where did you obtain the materials that you personally went through?
A. From the security area.
Q. And were they in some form of containers?
A. Yes.
Q. What kind?
A. Some were retrieved from files that were in file cabinets and boxes.
Q. Now, what is the process that you used in -- first of all, were you given a list of names
of people to look for on these logs and records?
A. Yes.
Q. And what was the nature of the records that you were looking through?
A. Records consisted of logs of people going in and out of the ranch, employees, guests,
business vendors.
Q. And you had a list of names to look for; is that correct?
A. Yes, sir.
Q. And during the course of your examination of the documents that you personally
examined, did you have occasion to remove some of those documents?
A. Yes, I did.
Q. And after you removed them, what did you do with them?
A. I notified Deputy Moeller and he scribed them, took them from my possession and
documented them.
Q. So he took them from you, you gave them to him and he documented them -A. Yes.
Q. -- is that correct?
A. Yes, sir.
Q. Now, have you had a chance to review the documents that you took on that particular
day -A. Yes.
Q. -- generally speaking?
A. Yes, I have.
Q. Do any of those documents include documents after the date of December 31st of
2002?
A. I don't believe so.

MR. SNEDDON: No further questions.

CROSS-EXAMINATION BY MR. SANGER:
Q. It's still morning. We always have to check here. We get kind of out of sequence. Did
you write a report in this case?
A. No, sir.
Q. Your assignment, among other things, was to look through those documents; is that
correct?
A. Yes.
Q. Were you assigned to do anything else in this case?
A. I help ed search the video movie room that he had.
Q. The video library?
A. Yes, the library.
Q. I'm sorry.
A. The video library at the ranch.
Q. I didn't mean to talk over you.Okay. The video library was upstairs in the same building
as the security office?
A. Yes.
Q. And you also were assigned to stand watch over the guest units until somebody came
to search them?
A. Yes.
Q. Okay. Other than that, did you do anything else in this case?
A. I went to the back employee area and stood by till somebody came -- from the sheriff's
office came and contacted the employees.
Q. Okay. Did you search the administration build ing? Let me ask the foundational
question. Do you know where the administration building was on the ranch?
A. No, sir.
Q. Okay. You were down at the main residence on the adjoining building with the video
library and the security office, correct?
A. Yes, sir.
Q. You did not go up on the hill to an administration building to search there, did you?
A. Yes, that's the build ing I was referring to in the back. I didn't search there, but I stood
by with the employees until somebody from the sheriff's office relieved me. I d id not
search that area.
Q. You're saying the back. Do you mean right behind the house?
A. Up high where you're talking about.
Q. What does that building look like?
A. I don't remember.
Q. Was it an industrial-looking building?
A. I believe so.
Q. Okay. So we're then talking about the is that the building that has a fire truck up
there?
A. There were no fire trucks when I was up there, I don't believe, but other employees'
vehicles.
Q. All right. Okay. In any event, you did not search inside of that administration building;
is that correct?
A. That's correct.
Q. And you're aware at the front gate there is an office at the gatehouse; is that correct?

A. Yes, there is.

Q. Did you search the office at the gatehouse?
A. No, sir.
MR. SANGER: Okay. Thank you. No further questions.
MR. SNEDDON: Nothing further.
THE COURT: Thank you. You may step down.

STEVEN MOELLER EXAMINATION

DIRECT EXAMINATION BY MR. SNEDDON:
Q. All right. Mr. Moeller, you're going to have to scoot up to that microphone there.
A. Can you hear me?
Q. That's perfect. That's as good as it gets in here. All right. You're a deputy employed by
the Santa Barbara County Sheriff's Department?
A. I am.
Q. How long have you been with the department?
A. 30 years.
Q. And what are your current duty assignments?
A. Currently I'm attached to the Aviation Bureau of the sheriff's department.
Q. And on November the 18th of 2003, you are one of the people who participated in the
execution of a search warrant at Neverland Valley Ranch; is that correct?
A. That's correct.
Q. And on that particular occasion, were you assigned some responsibilit ies in connection
with the execution of that warrant at the security office?
A. Yes, I was.
Q. And what were those responsibilities?
A. To go through various documentation looking for specific names on the list, and doing a
basic search of that security office.
Q. All right. And were you assigned a particular responsibility with regard to any of the
documents that were found during the course of that search?
A. Yes. I was a scribe.
Q. What's that mean?
A. That means that I -- for the search team, once they find something that they believe
they want to hold as evidence, they turn it over to me, I assign it a number, and then I fill
out the property sheet.
Q. And then after you assign it a number and you fill out the property sheet, what do you
do with it? What did you do with it on this occasion?
A. The evidence?
Q. Yes.
A. Bagged it.
Q. Okay. And then after you bagged it?
A. I turned it over to the evidence officer.
Q. All right. Now, you were working with some other officers in the security office who you
provided the scribe responsibilit ies for. Now, who were the other officers you were
working with in there?
A. There was Sergeant Steve Cleaves, Detective Sutcliffe, Detective Rooney, and

Detective Sweeney.
Q. And as they -- as they gave you the particular item and you assigned a number to it,
did you make out what's called an SH-451 form?
A. I did.
Q. What is that, for the jury?
A. Basically that takes the evidence that's turned over, any description of that evidence,
and we log who located that evidence and what locat ion.
Q. All right. I want to show you a series of exhibits, with the Court's permission. I can
approach the witness, if I might.
THE COURT: Yes.
MR. SNEDDON: And Counsel, this is 300 through -MR. SANGER: 334.
MR. SNEDDON: 334. Excellent.
Q. I'm going to ask you to examine the items 300 through 334, which basically ends
where that yellow tag is.
MR. SANGER: Your Honor, I'm going to object to this procedure as cumulative, in that
there's already a foundation and these documents were admitted.
MR. SNEDDON: I have other questions about the documents that I'm going to ask.
THE COURT: I'm not going to rule on your objection, because I don't know -- he's just
asked him to look at the records. So I don't know if it's cumulative or not.
Q. BY MR. SNEDDON: Okay. Have you looked at all those documents?
A. I have.
Q. Now, with regard to the very last one, this is People's 333, it's in evidence, it's the one
-- yeah, flip that over, because I'm going to ask you a question about -- no. Flip it this
way.
A. Okay.
Q. With regard to that particular document, in the upper left-hand corner is a number
written in ink; is that correct?
A. That's correct.
Q. And do you recognize that number?
A. Yes.
Q. Okay. Did you put that number on there?
A. I did.
Q. Okay. Now, go back one more document, if you would. That document -- excuse me.
With regard to the exhibit we were just talking about is in small numbers, black ink,
correct?
A. That is correct.
Q. Now, go back one more.
MR. SANGER: May I approach, Your Honor? I'm not sure I'm following this.
THE COURT: Yes.
MR. SNEDDON: It's the same as in yours.
MR. SANGER: It's a different colored ink on that one. This is not colored.
MR. SNEDDON: It's black.
MR. SANGER: I see, okay. That was the first number? Can I just ask where the second
number was?
THE WITNESS: 602?
MR. SNEDDON: That's on 601.

THE WITNESS: 601.

MR. SNEDDON: In the upper left-hand corner of the document.
MR. SANGER: All right. Thank you.
Q. BY MR. SNEDDON: Moving back, the next document has, in the upper left-hand corner,
what number in b lack?
A. 6-3-5.
Q. Is that your handwriting?
A. Yes.
Q. Now, the handwriting with regard to 635 compared to 601 is significantly larger, is it
not?
A. It is.
Q. Okay. And with regard to the review of the documents that I asked you to do in front of
the jury here, those all have large print on them like the 6 -- like the one that's marked as
People's 332, correct?
A. Correct.
Q. So even though they're smaller in size in one case and bigger in others, it's the same
handwrit ing, your scribe?
A. It is.
Q. Do you have your SH-451 form -A. I do.
Q. -- with you? Don't look at it yet. I'm going to ask you a question.
A. Okay.
Q. And if you have to look at it, I'll let you do that.
A. Oh. Okay.
Q. With regard to the items that were given you from No. 300 through 332 - okay? -A. Okay.
Q. -- were any of those documents beyond the date of January 1st, 2003?
A. I don't believe so.
Q. Did you -- would your SH-451 help you refresh your recollection to that effect?
A. It might.
Q. Make sure you're certain of that. Let me just ask you a question. Your report, your SH451, is listed by item number, correct?
A. Correct.
Q. So it doesn't necessarily correspond, without individually looking at every page, as to
which is which?
A. Correct.
Q. So why don't we just turn all the way back, just momentarily to get the place on this,
to Item No. 300 -- or Item 301. How's that? Just turn the book to 301.
A. 301.
Q. Okay. And that corresponds to your Item No. 614, correct?
A. Correct.
Q. Just run consecutively to 614 down to the end of your documents.
MR. SANGER: I'm going to object, Your Honor.
MR. SNEDDON: Let me do it another way.
MR. SANGER: Sorry. Go ahead.
Q. BY MR. SNEDDON: Just please review your form for right now.
A. Okay.
Q. And, now, does that refresh your recollection as to whether or not items -- the

evid entiary items 301 through 332 were all items from the year of 2002?
A. With the exception of one.
MR. SANGER: I'm going to object, Your Honor. The exhibits speak for themselves. We're
getting a report about the exhibits.
THE COURT: He just asked him to refresh his recollection. If I understand your objection
correctly, I'll overrule it.
MR. SANGER: Well, the objection was -- the question was, what is the dates on the
exhibits, not in his report.
THE COURT: He asked him to review the item and see if it refreshed his recollection.
Q. BY MR. SNEDDON: This would be only through Items -- your Item 635?
A. Correct. 2002.
THE COURT: I think what's happened is the question is in two stages. So I'll ask you to
break the question down to two separate questions.
MR. SNEDDON: Yes, Your Honor. I will do that.
Q. Does reviewing your SH-451 form refresh your recollection as to whether or not the
Exhibits 301 through 332 are all from the same year?
A. Correct.
Q. And that year would be what?
A. 2002.
Q. And there was a single document which is Exhibit 333, correct?
A. Correct.
Q. One-page document. That was from the year 2003?
A. Correct.
MR. SNEDDON: Nothing further.
MR. SANGER: The only problem is the book that was given to me has a two-page
document. Maybe it's two sides of one page. May I just inquire?
CROSS-EXAMINATION BY MR. SANGER:
Q. 333, is that two pages, or is it one page with two sides, or what is it?
A. Two sides.
Q. Actually -A. Well -Q. -- one piece of paper?
A. No, two pieces of paper.
Q. So basically, then, the answer would be Exhibit 333 is two pages that pertain to 2003?
A. Correct.
Q. Without getting too complicated here, you have a number of records which include gate
logs from 2002?
A. Correct.
Q. And then you have two pages, which is Exhibit 333, that are not gate logs; is that
correct?
A. No, they're not.
Q. Okay. So you have -- those are a Neverland Valley Fire Depart ment Emergency Medical
Report from 2003, correct?
A. Correct.
Q. And then there's a Neverland Valley Medical Report Log from 2003?
A. That's also correct.

Q. So those medical reports are from 2003. The gate logs that you scribed in during the
search were from 2002?
A. Correct.
Q. There you go. Now, by the way, is your assignment with the Aviation Bureau, is that a
-- does that mean you're up in the air full time in a helicopter or a plane?
A. Yes.
Q. That's where you are at all times?
A. As much as -Q. As much as you can, probably?
A. As much as the county can afford.
Q. When did you first get that assignment?
A. Approximately six years ago.
Q. All right. So at the time you were -- you were assigned to do this, you were taken out
of the air to come down to the ground and help out?
A. Actually, during that year that the search warrant occurred, I was temporarily with the
narcotics unit for about eight months.
Q. So you were working as a detective?
A. I was.
Q. And you have prior experience as a detective in the department?
A. No.
Q. That was your only time as a detective?
A. Yes.
Q. All right. Now, you were briefed on this search before you went out to the ranch,
correct?
A. Correct.
Q. And you received a copy of the search warrant, correct?
A. Correct.
Q. And you were aware of the structures that were covered by the search warrant; is that
correct?
A. Correct.
Q. And that would be the main house, correct?
A. Correct.
Q. The security office, correct?
A. Correct.
Q. And then the arcade building?
A. Yes.
Q. Did you search the administration build ing?
A. I did not.
Q. Do you know where that administration build ing was?
A. No.
Q. Were you aware there was an industrial-looking build ing up on the hill?
A. If that's by the fire department -Q. Yes.
A. -- area, yes.
Q. You're aware of that building?
A. I'm aware of that build ing, yes.
Q. But you did not search it?

A. I did not.
Q. And you're aware of the gatehouse or the office next to the gate, the very front gate on
Figueroa Mountain Road, correct?
A. Yes.
Q. And that was an office that was not searched as well; is that correct?
A. I did not search that.
MR. SANGER: All right. Okay. No further questions.
MR. SNEDDON: Nothing further, Your Honor.
THE COURT: You may step down.

JEFF KLAPAKIS EXAMINATION

DIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. Good afternoon, Lieutenant Klapakis.
A. Good afternoon.
Q. You've previously testified in this case that you were a lieutenant assigned to the
Michael Jackson case. During the month of January in 2004, did you serve a search
warrant on the home of F. Marc Schaffel?
A. Yes.
Q. And where did you serve that warrant?
A. In Calabasas, California. At his residence.
Q. What was the date of the -- that the warrant was served?
A. January 31st, .04.
MR. SANGER: Before we go any further -- yes, all right. Before we go any further, could
we approach the bench briefly?
THE COURT: Yes.
MR. SANGER: Thank you. (Discussion held off the record at sidebar.)
THE COURT: (To the jury) Before we have any further testimony, I have to hear some
motions, and not just as to this witness, but to several witnesses that the District Attorney
is anticipating calling. And there's -- I don't see any way that we could complete those this
afternoon, so I'm going to have to let you go home.
THE JURY: (In unison) Oh. (Laughter.) THE COURT: I knew you would be disappointed So
you don't come back.
THE JURY: (In unison) Oh.
THE COURT: And I'll see you Monday at 8:30. Remember the admonit ions. Let me just
say one thing to you. This is not unusual. When you get to the end of either side of the
case, things -- it starts stuttering. Every case I've ever had, those -- the witnesses that
are left are the ones that have something that I have to do, and it's just not unusual. I
don't want you to think it is. It just sort of -- cases don't just ride out to the end smoothly
and stop. At least not in my court. They always go bump, bump, bump. That's where we
are; bump, bump, bump. So I'll see you next Monday.I'm going to just leave the stand for
a moment until you're ready to start the motions.
(The following proceedings were held in open court outside the presence and

MR. SANGER: Your Honor, before you start on the motion, I asked Mr. Dunkle to come
over and sit in, because so many of these things were filed at the last minute and he's
worked on responses, so I'd like to have him here. And he'll be here in a few minutes, but
we can start without him, of course.
THE COURT: That's fine. All right. The first item on the calendar is the plaintiff's motion in
limine re admission of expert testimony on Battered Women's Syndrome. I deferred
ruling. I would like to have Mr. Sneddon, whoever is handling the motion here, explain to
me why this witness is necessary, what you intend to prove.
MR. AUCHINCLOSS: This is my motion, Your Honor. And given the enormity of the
evid ence concerning Janet Arvizo's 16-year abusive relationship at the hands of her
husband, and given the fact that the charges and facts of this case fall immediately upon
the end of that 16-year relationship, both sides have made the issue of this relationship
central to this case. The defense has even attempted to use this relationship to show that
Miss Arvizo was somehow fraudulent in the J.C. Penney case by attempting -I won't concede that they were successful, but they attempted to lead the jury to believe
that some of her injuries were, in fact, caused by her husband. So there doesn't seem to
be any contention that both sides agree that this woman suffered at the hands of her
husband.
THE COURT: I guess the issue that I want discussed is what is the relevance here. The
code section says that if you show relevance and you have an expert that will so testify -MR. AUCHINCLOSS: Very well. I'll go straight to the point. False imprisonment. Child
endangerment. Personal verbal attacks. Death threats. Isolation. Hopelessness. Emotional
abuse. These are all the central issues of domestic violence. They are also the central
issues in this case. Domestic violence evidence, expert evidence by a Battered Women's
Syndrome expert, is designed to debunk misperceptions about women who have suffered
this posttraumatic stress disorder. Women who have been raped, women who have been
beaten, women who have been abused do not act in a -- in a predictive manner. There are
many misconceptions about how Janet Arvizo should act, given the stimulus of the
defendant's conduct in this particular case. Specifically -- these are problem areas for this
jury that this expert will help them now to wade through. Specifically, why did she return
to her abusers at Neverland? The jury needs to understand that. Victims of domestic
violence virtually always return to their abusers. Why didn't she go to the police? Why
doesn't she report this? Victims of domestic violence -- this expert will testify, victims of
domestic vio lence, when they're threatened, when they're abused, when they're taken
advantage of, they virtually never go to the police. Why didn't she make greater attempts
to leave? W hy didn't she just walk away? Those are the questions of people who wonder
why these women stay in these domestic violence relationships. This expert will help this
jury understand this issue. Why she's still susceptible, why she's so gullib le. Common
traits in domestic vio lence cases. Why was she so easily manipulated? Domestic vio lence
victims are routinely manipulated by the men who abuse them. Why did she continue to
trust in people who had proven they were untrustworthy? Another common trait, this
learned hopelessness. That's the terminology that the experts use, learned
hopelessness; that they become eternal believers in, Well, you know, if I just tow the
line, if I just do what I'm told, if I don't make any waves, if I don't make any fuss,
everything will be okay. Why did she act so helpless? A common question that we all
have of victims of domestic vio lence and a common trait that's certainly associated with
this disorder. Why did she have -- continue to have hope and faith in Jackson when
Jackson's people were conducting this conspiracy around her? Again, this sense of hope,

trying to find some light at the end of the tunnel, trying to believe, wanting to believe.
She wanted to believe that Jackson could help her, even when all the evidence was
contrary. Why does she lie under oath? Now, here's an important point. The defense has
placed that fact in the center of their attack on Janet Arvizo.They've charged her with
perjury. They made a big deal about it. They questioned her extensively about that. And
this expert will come forward and tell you that victims of domestic violence virtually
always or routinely lie under oath and protect their abusers. And that's exactly what she
did in this case.
THE COURT: But I'm having trouble keeping up with you here. Are you talking at this
point about her lying under oath in depositions about whether her ex-husband was
abusive or not?
MR. AUCHINCLOSS: Yes, I am.
THE COURT: But just before that, you were attributing the -- it wasn't -- you were sort of
placing Mr. Jackson in the position of a husband, weren't you?
MR. AUCHINCLOSS: Well, I am. I'm p lacing -THE COURT: You made a big jump there.
MR. AUCHINCLOSS: Well, I did. And I'm saying that Mr. Jackson was in a position where
he could exploit the vulnerabilities of a woman who suffers from posttraumatic stress
disorder. Now, the statute itself says that the common misperceptions regarding Battered
Women's Syndrome is admissible to help the jury understand the nature and effect of the
physical, emotional, mental abuse on the beliefs, perceptions and behavior of vict ims of
domestic vio lence. Janet Arvizo's beliefs, her perceptions and her behavior in this case
have been called into question by the defense. And those beliefs, perceptions and
behaviors were altered, permanently probably, during those 16 years of being a battered
wife. Now, there are some interesting parallels here, even though Mr. Jackson is not in a
position of being a typical classic father figure in a family. I mean, there's the family
overtones. There's the I'm-going-to-take-care-of-you overtones. There's certainly some
interesting parallels here. But this is primarily to help the jury understand why Janet
behaves the way she does. Many questions are asked about this, and questions that have
been focused on by the defense. And Janet behaves the way she does because of her
history as a victim of domestic violence. Because of the stimulus that's provided, death
threats, she reacts that way when she gets death threats. When she's scared, when she's
upset, she doesn't go to the police. When she's feeling hopeless, she locks herself in a
room and sits there on Neverland and doesn't go out and see anybody. She is -- is she
paranoid? Yes, as most victims of domestic violence are.
THE COURT: The thing I'm having trouble with is that the case where this usually arises is
in a case where a -- if it's a husband -- let's use that as an example. A husband is charged
in court with abusing his wife, and she testifies, and there's a lot of inconsistencies
because she didn't report it, or at other times she said he was abusive, he wasn't abusive,
that type of thing, and you have -MR. AUCHINCLOSS: Well -THE COURT: -- the testimony to explain her -- it's not too different from the Child Abuse
Accommodation Syndrome, where the child doesn't accurately report and you bring in an
expert to suggest why that would be, you know, in the total scheme of things.
MR. AUCHINCLOSS: And you're exactly right.
THE COURT: In this case, that's not the situation at all. I mean, she's -MR. AUCHINCLOSS: This is an unusual hybrid. I couldn't agree more. But as you pointed
out, there's two tracks here for admissibility. One deals with the conduct of the defendant,

and trying to understand Janet's conduct, which I think is just -- just something that this
jury absolutely has to have to help them understand Janet. She suffers from a
posttraumatic stress disorder. They should be apprised of that and the classic
symptomology, which is completely counter intuit ive. And we don't want this jury to make
this decision based on misconceptions. And there are an abundance of misconceptions of
how women should be behave and how they actually do behave when they've been
abused by domestic partners. But the other side, the other track, which is completely
independent of this and which this evidence should come straight in on, is to explain why
she didn't tell the truth under oath. It goes straight to that issue, which the defense has
chosen to make a centerpiece on their attack on Janet. So for the jury to understand why
did she perjure herself, why did she lie about her husband, that's a highway to bring this
type of evidence in so that the jury can understand, that's normal. Women who are -- who
are abused do that. It shouldn't be held against her, and it shouldn't be
used against her the way this defense intends to do, and the way they tried to do when
they examined her, and the way they ultimately will do when they argue this case. So on
one hand, the defense has asked for it. They've asked -- they should have all the evidence
on what the reasons why she perjured herself. But on the other hand, it's -- there are
many enigmas about why Janet acted the way she did, and those enigmas are largely
explained when people understand that she is a classic -- she's exhibiting the classic
symptoms of posttraumatic stress disorder. And I might point out finally, just that under
the code, under the section here, this is not exclusively used in the case of Battered
Women's Syndrome where there's a domestic vio lence, where the husband is charged and
the woman is the victim. I mean, the code itself says whenever it's relevant. So it's not
a matter of whether it's normal or not. The question is, is it relevant? Does it have a
tendency in reason to prove -THE COURT: Well, it's just that it's -- the relevancy is very clear under the typical
scenario.
MR. AUCHINCLOSS: Yes.
THE COURT: It's not so clear here.
MR. AUCHINCLOSS: But even in the cases, the cases don't always just go to that classic
scenario. Sometimes it's used on the other side of the coin. Sometimes it's used to show
why the woman assaulted the man.
THE COURT: Well
MR. AUCHINCLOSS: And there's case law on that as well.
THE COURT: Yeah, and -MR. AUCHINCLOSS: So -THE COURT: I chose the example of the man assaulting the woman because that's the
scenario we have in front of me.
MR. AUCHINCLOSS: Sometimes it's used to show that the defendant -- it's not only used
to show the victim suffered from post-traumatic. Somet imes it's used to show the
defendant suffered -THE COURT: Oh, I see what you're saying.
MR. AUCHINCLOSS: When the woman is charged with murder, for instance, and an expert
is introduced to show she suffered from Battered Women's Syndrome. So there are other
cases. But I agree with you, it's not always simple, but we are not always confronted with
simple facts for the applicat ion of the law. But I will say that it is abundantly clear that,
under the defense's own intent and their own tactic in this case, they made it relevant, at
a minimum, by charging her with perjury and parading that out in front of this jury. So I

would submit there are two very strong reasons that make this evidence high ly relevant.
And I don't think you can -- you can dispute the fact that many of her -- much of her
conduct is counterintuitive, that -- and that it does fit within a p attern that is prevalent
among women who are victims of this.
THE COURT: But you're saying that the expert's going to testify that not only does the
spousal abuse accommodation theory explain why a person doesn't report, prosecute, et
cetera, a person who is physically abusing them, and will say that that's equivalent to this
case where -MR. AUCHINCLOSS: Yes, she will say that. She will say that this -- this disorder, the
symptomology of this disorder, is not isolated to the home. When they walk out of the
home, they carry this disorder with them. When they are confronted in the world with the
stimulus, the similar stimulus that they have in the home, such as death threats, such as
false imprisonment, such as threats of child abduction, such as trying to obtain control,
any act of power, isolation and control, which we have here, when they're confronting
these types of influences, they react the same way they do in the home. The
posttraumatic stress disorder goes with them wherever they go. And that's what this
witness -- this expert witness will testify to. She will testify to that these types of
incidences are -- are Janet suffering from this syndrome. That this type of behavior is -and not specifically, but generally, because this will be general testimony, as it should be.
It's to demystify the area. But she'll testify that women do not leave this disorder when
they walk out of the house or even when they leave their husband. So -THE COURT: Okay. Mr. Sanger, are you going to discuss this?
MR. SANGER: Yes, sir. Yes, sir. We briefed it, and I think the Court has hit one of the
major points on the head, is that this isn't relevant to this kind of a case. But responding
to what Mr. Auchincloss said in an effort to answer the Court's question, we didn't make
her perjury relevant. She has committed perjury, I think it's pretty clear, in this court
from the stand. And she has said things that are preposterous, that are absolutely counter
to the other evidence in the case. And that's not because she's a battered woman. That's
because she lies for gain. I don't want to be unnecessarily harsh, but let's face it, that's
what this is about. She took the Fifth so that she has that protection to not be cross examined. But the Court is going to allow us to bring in evidence that she lied for gain on
repeated declarations for money and got that money and continued to get that money,
and lied and cheated her way through life. That is what she does. That has nothing to do
with being a battered woman. Now, the People say, well, they should bring this in and
because Mr. Auchincloss says she's really suffering from posttraumatic stress disorder,
which is interesting, because they specifically asked to exclude Dr. Hochman's testimony,
who indicates that she is basically an antisocial personality disordered patient, person,
who coaches her children to lie. Remember, Dr. Hochman was the one that said that, and
that she lies for gain, and lied for gain in that case in the J.C. Penney's case itself. But he
made a d iagnosis after actually seeing her and evaluating her and testing her. If they're -MR. AUCHINCLOSS: I'm going to object that that misstates the evidence, and this should
be a legal argument rather than a factual one.
MR. SANGER: Well -THE COURT: Overruled.
MR. SANGER: If they bring in PTSD and say that's what this is all about, and she can get
up and say whatever she wants, obviously it proves too much. It's not relevant to this
case. It's not relevant to the facts of this case, despite the heroic effort to stretch it. But it
would prove too much. Anybody who claims that they were assaulted by their husband

could come into court, lie in the trial proceedings before the Court, lie in countless other
proceedings, and under oath, and then say, I get a pass. Now, there's nothing funny or
nothing to be minimized about being the victim of any kind of vio lence, whether it's
domestic vio lence or any other kind of vio lence. But it proves too much to say that
therefore this witness, who Your Honor heard for five days -- and we'll address this maybe
in an 1118.1 motion at some point here. But without prejudging that, Your Honor heard
this witness for five days. That is not the behavior of a shy, hopeless - what were the
words? - a hopeless person who can't stand up for herself. She was perfectly willing to
take Mr. Mesereau on as aggressively as possible. She has taken other people on in her
history in that very same way. W hen she wants something, she will get it. There is
nothing -- nothing shy about that woman that was on the tape that was trying to keep
herself situated as close to Michael Jackson as possible, while denying that Jay Jackson
even existed. There is nothing shy about this woman at 7264 any time. And she'll get up
here and blatant ly lie. If the Court says, Well, you can -- if any court said, Well, you
can bring in an expert to say this person gets a pass and they can lie, what's the point of
cross-examination? W hat's the point of coming into court and having the jury hear these
things? Now, it simply proves too much. It's not relevant to the facts of this case. If they
do intend to bring in something like that and claim that it shows PTSD, and therefore she's
not able to tell the truth, what does that tell us? But if they're able to do that, then we
should, of course, be able to bring in Dr. Hochman to say he knows exactly why she
doesn't tell the truth.
THE COURT: Don't you think there's relevance, without conceding your position, though?
I'm having trouble with you, just like I am with the District Attorney. There's two areas
we're talking about. One area, the claim is that she was the victim of abuse by David
Arvizo. And as the District Attorney pointed out in his argument, neither side seems to be
-- that's not an area of contest in this case. You know, when it occurred, and all that, may
be, but not that it actually occurred. So then we have the actual impeachment by the
defense of her testimony that Mr. Arvizo was abusive by you, the defense, bringing in the
depositions of the J.C. Penney case where she denies that he's abusive. And I don't want
to go into the evidence at length, but there was a considerable amount of evidence
relating to her responses in the J.C. Penney case, and then the -- you know, the final,
ultimate statement by her that if she, you know, was at the point that he was finally
arrested and removed from her presence, that she was able to go to her attorney and
explain some of the untruths that she told. That's one area. Now, what's your argument,
without drifting, please, as to the relevance of her -- of expert testimony explaining the
Spousal Abuse Accommodation Syndrome in regard to that issue?
MR. SANGER: Or Battered Women's Syndrome.
THE COURT: Yes.
MR. SANGER: So, if I'm understanding the Court, the -- taking the argument -- and I
understand the Court's advancing for the purpose of discussion, taking the argument -THE COURT: You're giving me a d iscussion, yes.
MR. SANGER: Taking the argument that, while the testimony might not be admissible with
regard to Mr. Jackson and any other conduct associated with people at Neverland, the
argument may be relevant to explain what happened with David Arvizo and why she may
have lied in the J.C. Penney's lawsuit.
THE COURT: Yes.
MR. SANGER: Okay. First of all, under 352, let's start there, the Court has to make the cut
at some point on evidence that is going to come in to explain what is an issue in the case,

but it is no the core issue in the case. And the Court has made that determination with
regard to Dr. Hochman, for instance, that we cannot bring in what we considered to be
probative evidence. The Court did not say it was not probative. The Court said that you
were going to exclude it, I take it, in part, on the grounds that it would be -- I believe the
Court said on the grounds that we're not going to have a complete trial within a trial on all
aspects of it. So there does have to be a cut of some sort. And it seems to me that's a
place where we can start with the discussion. Can they -- in a trial where Mr. Jackson is
on trial for his liberty over what these people alleged ly did, we're going to have an expert
come in, whose testimony should really be limited to this very small area. Now, I
understand if the Court were to do that, Mr. Auchincloss would not be allowed, nor would
anybody on that side be allowed to argue that this testimony explains away her perjury in
this case or her perjury in other respects. But Your Honor would propose that somehow
the jury be limited to that. And so under 352, besides the undue consumption of time, you
have the potential for prejudice to this defendant, to whom this witness would not apply at
all, but the jury would not be capable of making that very surgical line, if you make a line
surgically, but make that line very specifically. So it would cause prejudice, and it wou ld
cause undue confusion to the jury, besides the undue consumption of time. Now, I want
to address the relevance issue even more specifically, but I started with 352, because I
think that really answers the question. But going more specifically beneath that, to
whether or not it's probative at all on this, Your Honor said we don't dispute that she was
abused by her husband. There's already been reference to the fact that there was a
photograph taken of her where she was appearing to assault her husband with a knife.
And she said it was all a game, but I will represent to the Court that we have a number of
witnesses who say that she was the violent one in the marriage, and was, in fact, striking
not only her husband but other family members, and she's -MR. AUCHINCLOSS: I'm going to object that this is all irrelevant as to what she -- what
Janet Arvizo is and what she may have done.
THE COURT: Overruled. Go ahead.
MR. SANGER: And we have a number of witnesses who we could call for that. Whether we
will call them -- I'm representing they've been interviewed and that's what they say.
Whether we will call them is a question of trial strategy and tactics, depending on where
this all goes, of course. And there's evidence that -- well, suffice it to say, without going
into the detail, there's evidence from third-party witnesses and family members to that
effect. Given that, if the Court allows her to now shore up her credibility as to why -- sort
of a strange phrase, shore up her credibility as to why she perjured herself -THE COURT: That's a phrase you've been choosing. I mean -MR. SANGER: What the prosecution would be saying -- Your Honor argued this for them, I
suppose, because we're talking about this narrow issue. What the prosecution would be
saying on this part of it, I suppose, is, Look, of course she lied in J.C. Penney's because
her husband's abused her and she's afraid. So then when she -- when she testified, she
not only testified that her husband never beat her and she loved her husband, and they
had a hide-away love nest, and there was all these other things that went along with that
deposition, but she also felt compelled to testify that she was sexually mo lested and all
the other things that came out in that deposition that were just inherently preposterous.
And they would argue, Well, she's a battered woman, so she tends to lie about
everything if she lies about anything.
THE COURT: The expert on the Battered Women's Syndrome, doesn't the expert in that
situation just explain why a person who's been the subject of abuse might not report it,

might not report it accurately, might at one time say one thing about it and other times
about another? That explanation doesn't extend to everything a person says thereafter to
anybody, does it?
MR. SANGER: Well, it shouldn't, but I heard Mr. Auchincloss just argue that it does.
However, focusing on the Court's argument, the question is what would the expert bring
to this? The expert is not going to be able to substantiate the argument that Mr.
Auchincloss made, and that's my point. The expert's not going to be able to say that she
committed perjury just in general because she's hopeless. The expert can simply say
there are syndromes where a woman, or a man, or anybody that's subject to a Battered
Person Syndrome, usually a wo man, hence the name, but where a person is subject to
this syndrome, they are beaten down, they're dependent on the person, they feel
hopeless. And the theory goes, therefore they don't necessarily avail themselves of
conventional means to resolve the problem. They tend to go back to the person, things
that Mr. Auchincloss said are common -- I won't adopt them all, but those that I'm
repeating are common denominators in the expert testimony. And that will explain the
traditional case where, in fact, a woman doesn't go report it, and when asked, after being
beaten, says, No, I wasn't beaten. It just doesn't explain the facts in this case. When I
say, this case, I mean the J.C. Penney's case. It certainly doesn't explain anything in
this case. But in the J.C. Penney's case, it just doesn't explain the facts that are in that
case, where she will go in for gain and make up a big story about all sorts of things for
gain. And then remember, Your Honor, she doesn't -- it's not that she's afraid to report
her husband. She reports her husband five days after they get a settlement by mediation,
while they are still deciding how the money's going to be split between them. And during
the months that ensue, they can't decide, the insurance company files an interplead er -- I
don't know if they actually filed, but stated in correspondence they're going to file an
interpleader because they don't want to have anything to do with it. She reports him then
for sexual abuse. And he finally says, I give up I'll just take 5,000 for my divorce lawyer
and you can have the rest. And that's not a battered woman.
THE COURT: You're really not addressing the issue. But -MR. SANGER: I'm trying.
THE COURT: Let me ask you the other question.
MR. SANGER: I'm sorry.
THE COURT: The area I cut you off on -- I just wanted to hear the argument related to my
hypothetical, so I cut you off from arguing why it shouldn't apply, if the expert actually
purported to be able to apply it to the -- a situation outside of the marriage or the
relationship such as the Michael Jackson connection that she has. I'll let you argue that a
little bit, because I wouldn't let you argue it.
MR. SANGER: All right. And not wanting to decline that invitation, could I make jus t one
closing remark on the other issue?
THE COURT: If it relates to my question, yes.
MR. SANGER: And I want to tie it to the question. I think that is the question, is Your
Honor says if it was limited to that issue, I suppose the question is how do you limit it to
that issue? And that's why I come back to the 352, which is if you let in a battered woman
expert on that, then we have all this other evidence as to whether or not she was actually
battered, and whether or not she was behaving in accordance with a Battered Women's
Syndrome, which would open that whole area substantially more than the Court, I think,
intends to have it opened at this point. Having said that -- that was the point of going on
about the additional facts with regard to that point. Having said that, the -- the greater

argument, as it pertains to Mr. Jackson, who, after all, is the person we're representing -we're not taking David Arvizo's side or not. You know, that's something that either did or
didn't happen. The question is whether or not Janet Arvizo is telling the truth in this case
when she's accusing Michael Jackson and other people at Neverland and elsewhere of
doing things to her. And this syndrome, as it's typically described in the testimony, would
have no applicat ion to this picture, despite Mr. Auchincloss's argument that basically
explains perjury in general. Not only that, we still do not have an offer, specific offer of
proof or a report of anything from a Battered Women's Syndrome expert. And as far as I
know, they haven't elected which one of the number that they listed on their list they
were going to actually call. So we don't know what they're going to say. We have to
assume they're going to say no more and probably no less than they generally will say in
domestic vio lence cases or cases in which the parties, whichever one is the victim of the
ultimate offense, where the parties are husband and wife or boyfriend and girlfriend, and
they have that kind of a relationship. So if they give that kind of testimony, that kind of
testimony will not apply to this. That means that they are expecting to call somebody who
is either going to say that, and therefore there's no relevance, or they're going to call
somebody who's going to expand on the theory beyond any measure upon which it's been
approved to explain that somehow this can give an account of what happened here for
five days.
THE COURT: Have you ever seen a case where it's been applied, this testimony, to
anything other than the people involved in the relationship?
MR. SANGER: I have never seen such a case. I have never seen such a case reported. And
let me just ask very quickly. Did you see a report of this?
MR. DUNKLE: No.
MR. SANGER: And Mr. Dunkle, who is religiously researching some of these things,
particularly the last-minute motions, has tried to read every case there is on all of these
things.
MR. AUCHINCLOSS: If the record could reflect, Mr. Dunkle shrugged his shoulders.
THE COURT: Clearly he said, No. R ight? I heard him absolutely say, No.
MR. SANGER: I'm a battered defense attorney.
THE COURT: The way he was shrugging his shoulders was in fright. It was, Don't ask
me. (Laughter.)
MR. DUNKLE: That's correct.
MR. SANGER: As a battered defense attorney, I may not be able to hear him clearly. I
guess that's -THE COURT: Okay.
MR. SANGER: The point is, I just don't see how it can apply. If the Court has any other
questions, I'll answer them. Otherwise, I'll submit it, Your Honor.
MR. AUCHINCLOSS: Two comments.
THE COURT: I'll let you make your two comments, but let me ask you the same question.
Do you have any case where this has been allowed or used other than between the two
parties and the typical domestic violence situation?
MR. AUCHINCLOSS: I don't have a reported case.
THE COURT: Do you have any unreported case?
MR. AUCHINCLOSS: Um -THE COURT: Oh, you're not supposed to cite those, are you?
MR. SANGER: Rule of Court 977, but the delay answered the question.
THE COURT: You should have let him make his answer and then move to strike.

MR. AUCHINCLOSS: But the bottom line -- one of my two important points is, number
one, this is apples and oranges to Dr. Hochman, who would testify specifically about Janet
Arvizo. This is not going to be testimony about Janet Arvizo.
THE COURT: No, I understand that.
MR. AUCHINCLOSS: This is just general testimony. Mr. Hochman would testify about
specifically Janet Arvizo and it's inadmissible for that purpose.
THE COURT: You're getting -MR. AUCHINCLOSS: Putting that aside, I want to make that point, because it's not
prejudicial to the defendant. It's not about the defendant. It's merely some information
that the jury can use or not use. It's up to them. If they think it applies to this case, no
problem. If they don't think it applies, they're the arbiters. So in terms of prejudice, really
it's -- all it is is informing the jury of the truth about a certain syndrome. Secondly, as far
as this thing about perjury, I've never said that this gives her a pass to commit perjury.
And Battered Women's Syndrome does not provide any exculpation of an individual who
lies under oath except for the individual who lies about their mate. That is the one area,
when they say, He didn't beat me. W hen they say, He d idn't do anything. When they
say, He's a great guy. Oh, he's a good person. He's an honest person. When they say
those things, that's where they do get a pass, and that's the only area. And that's what
this witness would testify to. And that's why it's so -- it's so important and so probative in
this case. Thank you.
THE COURT: This is an area that has caused me a great deal of concern. Probably why I
didn't rule on it initially, I wanted to hear all of the evidence before making the ruling. And
I think this type of evidence is valuable in domestic vio lence cases for jurors to help
understand the dynamics of a particular relationship involving violence, but I'm not going
to allow it in this case. It may or may not explain her -- or a person's conduct in a similar
case, such as the J.C. Penney case, which was not a domestic vio lence case between her
and her husband either, as this one is. And I think it would be a mistake for me to allow
that type of evidence on what is a peripheral issue in this case, i.e., whether or not she
told the truth in the Michael Jackson -- in the J.C. Penney depositions. The Court will also
find, under 352, that in this case the prejudicial effect far outweighs the probative value of
the information, in that the jury might well confuse the purpose of the testimony, which
would be -- the only way I could see it at any time wou ld be to explain the relationship of
the abused and abusing couple. And I also think that, under 352, to allow the evidence
would force the defense to approach the abuse in a different area, a different way, which
would cause an undue use of time and prolong the trial unduly. So for all those reasons,
the Court will deny the use of the expert on the Spousal Abuse Syndrome. The next issue
we'll take up is the plaintiff's supplemental motion for admission of additional evidence
pursuant to Evidence Code Section 1108.
MR. SNEDDON: Judge, I'll be brief. I just want to correct a couple of misconceptions in the
response by the defense to this motion. Mr. Kassim was on the original witness list and
has been since the beginning of this trial. Secondly, the discovery with regard to Mr.
Kassim's statement was provided, along with all the other materials, back in October of
2004 of the statements that he made to police in 1994 -- in 1994, in May, during the
course of the first investigation involving Mr. Jackson. These have been known to the
defense since that period of time. With regard to the motion itself, I will ind icate to the
Court that he was not on the list of the 1108, because in my view, with regard to the
observations that he made, as I've indicated in the brief, they were corroborative of the
testimony of Mr. Chacon and did not involve the actual seeing of any misconduct on the

part of any individual. And frankly, it didn't dawn on me that he couldn't just come in and
testify to those events. However, when the Court asked me to do it and put it in writ ing
and defer his testimony, I was more than glad to do so. But this -- so this is not
something that we're trying to bootstrap into something we didn't plan to do a long time
ago. He's been on the witness list, items have been discovered, and so we filed a
supplemental motion. And I believe that the evidence is probative and is admissible under
the code section and certainly is -- sets a stage and corroborates the testimony of Mr.
Chacon in terms of the fact of the defendant being with the children that were ment ioned
by Mr. Chacon, and the events as mentioned by Mr. Chacon, and then the corroboration of
the incid ents by finding the swimming trunks in the rest room when he went to turn the
lights off immediately after the defendant went from that position to the house. I'll answer
any other questions that the Court has, but that was -- I wanted to explain those
differences between our position and the defense's position on the factual issues in terms
of what was and was not provided.
THE COURT: Okay. Counsel?
MR. SANGER: Yes, I don't know that there's -- that there is a dispute, nor did we intend to
say there was a dispute about what Mr. Sneddon said. All of the people that they could
find in the Abdool, Chacon, McManus, Domz and Bagnall vs. Jackson case, the civil case,
all of those plaintiffs were listed as potential witnesses in this case on the December 6th
witness list, as I recall. If it wasn't that one, it was the oneshortly thereafter. That was not
our complaint. Our complaint was that Abdool was not listed in the 1108 -- specific 1108
motion where the government spelled out what they intended to prove. It has been and
continues to be our contention that the government is required to turn over witness
statements of witnesses who talk to the government, whether it's police officers or district
attorneys. And our concern is that we had reports from 1994. We've had testimony, of
course, from this Mr. Abdool in 1996 or .7, and that was involving the case I was involved
in in representing Mr. Jackson, but we don't have any current reports. And it's just hard to
imagine that any of these witnesses -- and I'm taking just a moment, because this applies
to other witnesses that will come up, that any of these witnesses from times gone by
would just be called to the stand cold, without even so much as a reinterview. So that was
our concern, so that was what we were trying to express. And without anything new, and
without anything by way of an offer in the original 1108, all we have now is the new offer,
which is not based on declarations, as so many of these motions are. They're just things
that are said in the motions, and the government wants to call Mr. Abdool for that. This
goes far afield. The Court will limiting the testimony under 1108, recognizing, I believe,
that 1108 evidence can be very distracting to the jury for the same 352 reasons that
we've discussed before, and the Court made an effort to limit it, my belief was, to people
who saw some actual acts or purported to see some actual acts that would amount to
actual evidence as opposed to circumstance and innuendo. And not to go on about all the
details of Mr. Abdool's testimony and whether or not it's been refuted by his own words,
which I can indicate to the Court it has been, but aside from that, you're talking about a
tangential witness to shore up another witness who has testified here, and we're turning
the into more than it should be turned into. This still remains a balancing act, and the
Court has discharged that duty to balance by attempting to limit the 1108 testimony so
the jury could hear what might be important to hear for the purposes set forth in 1108
and not to allow evidence to overtake the significance of the actual evidence in t his case
of guilt or innocence. And so I think that expanding it any further would be a mistake, and
I think it would be -- it would be harmful, be prejudicial, for all the reasons under 352,

consumption of time, confusion to the jury, and prejudice to the defendant. Thank you.
MR. SNEDDON: Your Honor, I just want to make one comment and I'll -- with regard to
Mr. Sanger's position. I think that the -- there's three incidents, and I tried to be specific
about the incid ents involved in the offer of proof. And clearly, my take on it, and has been
from the beginning, that the first two incidents that really frankly involve relevancy issues
more than anything else, and that they are like having mult iple people see the same
events and you're allowed to call people in to testify to certain portions of what they saw
during the course of those events. Clearly, I think the third incident is one that is more
akin to the 1108 and 1101 kind of evidence that's been before the Court. But clearly, I
think the first two incidents are ones that are more, in the sense, relevant because they
corroborate Mr. Chacon as to significant events that he's testified to in this case. And
there's been a -- an attempt by the defense to claim that this evidence was fabricated
based upon his involvement in later suing Mr. Jackson. And I think in fairness to Mr.
Chacon, when there's a witness out there who can testify that he was also there that night
and he also saw the same things that Mr. Chacon saw, in terms of the setting for the
event and placing Mr. Jackson with the child at the time that Mr. Chacon says, that that's
highly relevant evidence that this jury should be presented with. So I think there's a
difference in the basis for which the first two incidents would be admissible as opposed to
the third. And I'll submit it.
THE COURT: You know, I want to take a couple of minutes to read the briefs again on this.
I'll take a five-minute recess. (Recess taken.)
THE COURT: What department is this? Where are we? (Laughter.)
THE BAILIFF: 8.
THE COURT: Okay. On this plaintiff's motion for admission of additional evidence pursuant
to 1108 and 1101(b), I am going to deny the request to allow the -- what I'll refer to as
the bedroom incident, which is your third incident. I think I will allow the evidence relat ing
to the -- what you call the bathroom incident, the swimming trunks. And the second one,
the hug, that will be allowed under 1101. Then the next item on the Court's agenda is the
admissibility of certain testimony of several of the defense proposed witnesses. I have a
way of sort of streamlining this one. I can't tell how to rule without knowing why you
would offer a certain witness in what regard. This is evidence that what you want to do is
produce employees who will declare that they never saw Mr. Jackson touch a child
inappropriately or something, you know, some type of evidence. And it's, generally
speaking, negative evidence, you know. We can call a million people who never saw him
do that. But if there's some way of advising me and the prosecution in advance that a
particular witness was in a particular situation, it makes that not seeing something
germane, then we have a different situation, right? Do you understand what I'm saying?
MR. SANGER: Yes.
THE COURT: If you could give me the facts as to a -- I don't know, maybe it would be a
situation where the District Attorney had a witness that said, I saw such and such
happen, and you had a witness that was there in the vicinity that didn't see such and
such happen, then that becomes relevant.
MR. SANGER: Yes.
THE COURT: Does my streamlining really work?
MR. SANGER: No, it didn't work, Your Honor.
THE COURT: All right.
MR. SANGER: I'm here to prove that point.
THE COURT: Go ahead.

MR. SANGER: No, I understand what the Court's saying. Certainly that streamlined
version -- I think there's no question -- if they say at eleven o'clock in the morning on the
1st of whatever, somebody was standing outside the theater and something untoward
happened, and we have an employee, for instance, who was working in that vicinity at
eleven o'clock and was vigilant, and we can say he was looking around and he never saw
any such thing happen on that particular day, clearly that's relevant. I mean, that
wouldn't be a question. So to the extent it's streamlined to that extreme, I mean,
obviously -THE COURT: That's an extreme situation.
MR. SANGER: But I think that the kind of evidence that we are talking about is much more
-- is much broader than that. There will be evidence of that sort. But there's also evidence
of people who, for instance, worked at the park, the amusement park, saw children on a
regular basis, saw Michael Jackson with children on a regular basis, some of whom saw
the Arvizo children, some of them who did not see the Arvizo children, per se. They may
have seen them, but they didn't see anything particular with regard to those children one
way or another, but were able to say that they have seen Mr. Jackson on a regular basis
with children and never seen him do anything inappropriate. There are also people who
would say that they did not see children who were -THE COURT: Do you think that's character testimony? Now you're having people testify to
a trait of character. Do you want to put his character in issue for the trait of, you know,
whatever?
MR. SANGER: Well, in essence, his character has been put in issue and that was part of
what we briefed. 1108 evidence is -- the way 1108 is written and the way it's been
interpreted, although we have thought -- I say we. You know, the defense bar in general
and a lot of legal scholars have thought that it really went overboard. It's been interpreted
as propensity evidence. That's character evidence. If they're allowed to introduce some
evid ence of some events from 12, 13, 15 years ago for the purpose of showing
propensity, which is what 1108 allows, we should be able to counter that by saying, no,
there is no propensity. And when they've been allowed to introduce evidence of children
running amuck, this is not character as to Mr. Jackson, but you've heard the testimony
elicited by the prosecution that there are children running amuck and totally unsupervised
and out of control. Some witnesses say that. And other witnesses say, other than
particular children, like the Arvizos, for instance, children were not running amuck, there
was supervision, a certain amount of decorum. I think those are relevant. That's not
character evidence as to Mr. Jackson. That is -- that is evidence that's directly offered to
refute the evidence that was put in by the prosecution. So if we take those two different
categories and talk about those -- let's take the last one first. Let's assume -- let's assume
we put on a witness who worked at the ranch in the public areas and saw children on a
regular basis and said, I've seen children on a regular basis there. I have not seen any
children under the influence of alcohol. I had the opportunity to observe. Of course there
could be a foundation objection. But assuming that there is a foundation, survives that,
they have an opportunity to observe and they say, during the relevant time periods, I
saw dozens, hundreds of kids, whatever it is, and nobody was under the influence,
that's evidence we should be allowed to present, because it directly refutes evidence that
was presented by the prosecution. If we have evidence that -- so that's that category, and
I think that's pretty simple. If we have evidence with regard to Mr. Jackson behaving
appropriately with children and providing -- you know, not doing anything inappropriate in
his contact with them, that counters the 1108 evidence, the propensity evid ence.

THE COURT: Well, I think what I'll do is I'll let you -- what I would do is let you, as to each
witness - and we're not going to do it now, but either in through some written paragraph
or through some offer of proof before they're called - tell me the basis, because I see
some of those, but, you know, the example you just gave me, an employee who worked
in the area of -- observed all these children, never saw any of them drinking, you know, if
you had the ability and it was an area where they wou ld be seen if they were drinking,
you know, then I think I could -- I would go along with that employee. But, you know, if
he's a ranch hand and comes in and out of the ranch occasionally and says he never saw
anyone, we're starting to talk about people who wouldn't have an opportunity.
MR. SANGER: And that would be a foundation issue.
THE COURT: So I think I need a better -- and I would allow the D.A. to address each one,
too. It's not just showing me, but -- the general scheme of things, there has to be
something specific here to make it relevant. Just plain negative testimony isn't going to
get it.
MR. SANGER: I understand. So what the Court is saying, we have to show a foundation
for the observation; that if the foundation is that there's adequate opportunity to observe
and that it's relevant to the area or the time period.
THE COURT: Yeah. Something that makes the fact they didn't see it relevant.
MR. SANGER: Right.
THE COURT: Which is -- and I think your alcohol examp le is a good example of something
that I would allow.
MR. SANGER: All right. And -- and I don't want to argue with the Court, and I'm not, but
as far as -THE COURT: And just like you're not supposed to talk over there by the witness stand, so
you always remind yourself of that right before you start talking. (Laughter.)
THE COURT: That saves me from reminding you. (Laughter.)
MR. SANGER: It provides a warning, actually.
THE COURT: Yes. Could I go direct to contempt from there? Or -- go ahead. (Laughter.)
MR. SANGER: Well, I'm just a little concerned that we're sort of in the position of having
to make an offer of proof on all these defense witnesses.
THE COURT: Just the ones relating to the negative testimony.
MR. SANGER: Yeah. And there may be -- I mean, we'll have witnesses who'll have
percipient testimony on very particular things for which there would be no question. And
they might also say something like that. It puts us in a position of just about every
witness that worked at the ranch that we're going to call, because we're not going to call
people that spent their entire time up at the administration build ing or over at the zoo -THE COURT: I don't think it's burdensome to ask you to give me less than a paragraph.
Just something.
MR. SANGER: Not overburdensome to me, but Mr. Dunkle, he's young, so he can take it. I
say that facetiously. If the Court requires it, obviously we'll do it.
THE COURT: I think I do.
MR. SNEDDON: Judge, can I have 30 seconds on this issue?
THE COURT: Well, I thought you were winn ing, but if you want to -MR. SNEDDON: No, I'm winn ing, but I want to make something very clear that I think
needs to be very clear on the record on this issue that may have not been clear from Mr.
Sanger's remarks, but what's abundantly clear from the Court. I couldn't agree more with
the Court, and I couldn't agree more based upon the defense's own case, the Calpine
case. That if they attempt to put people on the witness stand to testify to Mr. Jackson not

-- not seeing Mr. Jackson molest some kid, that is opinion -- lay opinion testimony of
character and opens the door for us to do the have-you-heards. And I want to make it
clear now, so that -- so they don't say I'm doing something different later, that's not -that has nothing to do with 1101 or 1108. That's for everything that contests the
credibility of that witness's lay opinion with regard to Mr. Jackson's character trait for
deviancy or nondeviancy. And so I just want to make it clear today that if that's where
they go, that's where we're going.
MR. SANGER: I want to make it clear that that's not clear, because what Mr. Sneddon said
was lay opinion. If you bring somebody up to talk about an opinion, that's one thing. But if
you say, Did you see specific conduct during the relevant time period, that's not opinion
as to character. And when we talked about 1108 being a type of character evidence, it is
propensity evid ence. It's not opinion.
THE COURT: It's not character evidence under the leg islative approach.
MR. SANGER: That's correct.
THE COURT: It is propensity evidence, and it's an unusual statute, and California is one of
the few states that has it. But it's been held constitutional, and we go by it.
MR. SANGER: And there it is.
THE COURT: But it's not character evidence.
MR. SANGER: I mean, I was speaking in general terms. When you respond to propensity
evid ence, which says there was conduct that occurred, and you respond by showing that
there is conduct that is inconsistent with that, that is not a lay opinion that's offered as
character evidence. So Mr. Sneddon getting up making the remarks, it was welcome,
because if there is any question -THE COURT: I think he was responding to your -- you argued more broadly than I think
you performed. In other words, you argued, Well, Judge, 1108's character evidence, so
we can put on character evidence.
MR. SANGER: Yes.
THE COURT: That's what you argued.
MR. SANGER: That's why I say, I welcome that, because when I was saying it, I d idn't
mean it -THE COURT: I was just tipping you off, you know.
MR. SANGER: Well, there you go. But in any event, just so we're clear -THE COURT: Okay.
MR. SANGER: -- Your Honor, it is not character evidence. This is our position. It's not
character evidence to bring in specific acts.
THE COURT: You're telling me that you're not going to offer character evidence.
MR. SANGER: That's correct.
THE COURT: All right.
MR. SANGER: And if we do, we will and we'll let you know. But what we're talking about
here is not character evidence.
THE COURT: Now you're telling me you might offer character evidence.
MR. SANGER: Speaking as the -- as a member of a group, we have to decide at some
point, and if -- in other words, to be serious about it -THE COURT: I won't hold you to anything. Don't worry about that.
MR. SANGER: Okay. If we introduce character evidence, it will be of a different character.
THE COURT: I think the discussion just got way off track on the character evidence issue,
and I think I probably started it. Okay. The next item is the motion to quash the subpoena
for Manuel R amirez. My thought on this is that I'm going to deny the motion to quash, but

I'm going to ask the defense if they can accommodate this person. He's in the military. He
needs to move on. Can you put him somewhere at the beginn ing of your case?
MR. SANGER: I had offered to do a conditional exam, and I say that's an offer. The
prosecution opted to seek to quash first. I don't know that they would -- given the Court's
ruling, that they would refuse to do a conditional exam, but that may be one way to take
care of it. And we can talk about that. If that doesn't work, we will try to accommodate
him.
THE COURT: Counsel, you're -- you stood up after I ruled.
MR. ZONEN: Actually, I was standing before, but I'll be happy to go sit down at this point,
if you would like. I'm not agreeable to a conditional exam. They want to do that because
they have no idea what this person's going to testify to. That's why they want to do a
conditional exam. He doesn't have any information on this particular case, and he was
subpoenaed because he's the boyfriend of the victim's sister. That's all. Now, if they want
to put him at the very beginn ing and put him on the witness stand, they can do that. They
won't. They're not going to call him as a witness in this case because they have no idea
what he's going to say.
MR. SANGER: We do have an idea, and if Mr. Zonen tells us that this witness is not saying
something, he's making a representation that he has a statement of a witness he hasn't
turned over. I think it's rhetoric. But if it's more than rhetoric, I want that statement of
this witness that he has nothing to say, because I believe, from all the evidence that
we've presented, he does.
THE COURT: There appears to be evidence that he has something to say, and that's why I
denied the motion to quash. And now back to my question. Can we accommodate this
young man somehow? He's in the military, we're holding up his transfer, and I would like
to help him get on with his life in the Marine Corps -- is it the Marines?
MR. SANGER: Yes, sir.
THE COURT: They won't let him go anywhere until this subpoena is taken care of.
MR. SANGER: I understand. We will talk. There's a colonel who is representing him, and
we will communicate with the colonel and see what we can do.
THE COURT: All right. The next one is the defendant's motion to admit evidence of alleged
sexual conduct which, in accordance with the Penal Code, had been filed -- or Evidence
Code had been filed under seal. Who is going to speak first?
MS. YU: Thank you, Your Honor. I didn't realize we can have a hearing on this, because I
thought it was under seal.
THE COURT: It is under seal, and I've read the points and authorities. And if you have
anything to say, you have to say it without -MS. YU: The issue presented by this motion, Your Honor, is critical to the defense,
because it really presents whether Gavin and Star are telling the truth when they say Mr.
Jackson inappropriately touched Gavin or masturbated Gavin, because we're here to seek
the truth. And the truth of the matter is that they themselves engaged in the very act that
they are accusing Mr. Jackson of having committed. They themselves -THE COURT: What I was trying to ask you when you interrupted me was not to mention
the acts that -MS. YU: I'm sorry. About the date in particular?
THE COURT: I just asked if you had any further legal argument on it. I know what's
involved.
MS. YU: No, Your Honor.
THE COURT: All right. Anything from the People?

MR. AUCHINCLOSS: Yes. One thing that I think is very important for the Court to focus on
in the analysis of whether to conduct a hearing, move forward under 782, is to make
certain that we do not obviate the intent and purpose of 782 in the method in which we
proceed. One of the complications in this case at the present time is the fact that the
victim has been cross-examined about this subject matter. The reason that's complicated
is because if the victim answers in the affirmative, then the evidence co mes in doing an
end run around 782. In other words, 782 is obviated if the victim admits the conduct. If
the victim denies the conduct, then the defense says, Well, we want to get it in because
we want to impeach him with this conduct, irrespective of 782. Now, the intent of 782 is
specifically to allow this evidence in when the conduct itself is credib le or deals with -goes to the credibility of the victim in the case. Not to impeach him about some
statement. But when that conduct impeaches the victim for purposes -- I shouldn't use
the word impeaches, but when that conduct imputes the credibility of the victim by
virtue of its relevancy, it has some similarity, some aspect that helps the jury understand
whether or not this victim's being truthful. Now, the cases on this which we've cited, the
first one -- I don't know if we cited this case, but it's of course before we get to the next
stage of 782, which is an open hearing, calling witnesses, that the defense has a burden
to show affirmatively under oath the relevance of the complaining witness's ascribed
sexual conduct and they must show that this is not evidence that's just designed to
deprecate the character of the victim. Secondly -- and that is People v. Rios at 161
Cal.App.3d 905. Secondly, the case of People vs. Woodward, at 116 Cal.App.4 281, says
that the conduct itself must be similar to the charged crime. Now, I won't go into the
facts, but I suggest to the Court that this is not similar conduct in terms of the actual act
itself. There may be a similar description of events, but there is one that involves two
people and one that involves one. Finally, one case that we did cite for the Court is the
Harlan case, which specifically states that this type of conduct is not relevant. It's not -- it
doesn't go to the blameworthiness of the victim. So going back to my original problem, if
we look at the conduct itself that we're -- that the defense is trying to get in, under
Harlan, the courts hold that that conduct, in and of itself, is not really relevant to the
credibility of a vict im in a child mo lest case. The reason it's not relevant is because it's
common and it's something that could be ascribed to any child victim. So if this conduct is
not relevant, I suggest it would be unjust and unfair to let it in to impeach the victim's
statement denying this conduct. It's a little convoluted, but if you follow me, if we do that,
if we say that the defense gets to cross-examine the victim about it, and the victim denies
it, then the protections of 782 are completely obviated and the purpose is ignored. So our
point is, is that really the only way that they can get this evidence in is by showing that
this type of conduct is sufficiently directly relevant to the facts of this case, even assuming
it's true. And the case of Harlan specifically states that this type of -- this type of conduct
does not pass muster and should not be admissible. Thank you.
MS. YU: This conduct is relevant, Your Honor. It is relevant because Mr. Jackson is
charged with masturbation, and that is the very act that deals with this particular motion.
And it goes directly to the credibility as to whether they're telling the truth. Did they, in
fact, do it themselves, or are they blaming now Mr. Jackson for the very act that he never
did? Star got on the stand and he -- he testified under oath that he looked at these adult
materials outside the presence of Mr. Jackson, when in fact they looked at the adult
materials, they looked at other explicit materials, and engaged in the very act that they're
blaming Mr. Jackson for. It is credible to this case.
THE COURT: All right. Thanks.Normally Evidence Code Section 782 does require a hearing

outside the presence of the jury to determine what the complaining witness would say
about that. But in this case, the complaining witness has already been questioned on the
behavior, so the necessity of a 782 hearing is dissipated. We don't need one now. I find
that the evidence is relevant based on the -- particularly in view of the amended
declaration as to the time frame, which I thought was critical to the relevance. So the
evid ence will be allowed. Let's see, the next item is Mr. Jackson's request for clarification
of the Court's order known to prosecution and unknown to defense. The Court did provide
you with a copy of the minute order of March 11th, 2005. And I don't want to hear
argument on this.
MS. YU: Okay.
THE COURT: This is for my clarificat ion. I don't see any need for it. But I have ordered
that the defense may not attack Gavin's credibility with evidence that he maintained an email account with the password Sexy on it. That's prohibited. And the second one was -stated that I would only permit the informat ion that was submitted with respect to Rio's
testimony, which was referred to as the male witness in the minute order. So that's -that's -- I don't think any further clarification is necessary. It's -- is there?
MS. YU: I'm sorry? I apologize. MR. MESEREAU: Is there any other clarificat ion that's
necessary? MS. YU: No, Your Honor. I believe we're informed about the password. That
was the only clarification.
THE COURT: They're all waving at you. So that takes care of the clarification.
MS. YU: We were seeking clarification as to Mr. Mesereau's cross-examination of Gavin on
the e-mail account, as well as the passwords, because he did testify about the various
passwords.
THE COURT: But I prohibited this area.
MS. YU: Yes.
THE COURT: All right. The next item was the plaint iff's memorandum regarding
admissibility of evidence of criminal charges pending against witness Chris Carter.
MR. SNEDDON: Judge, let me take this opportunity to indicate to the Court that Mr.
Carter's attorney, Mr. Segal, is here - he's in the front row. Jeff Segal - and might want to
address the Court with regard to his advice he's given his client with regard to this case. I
will indicate to the Court that -THE COURT: Counsel, if you'd like to come in.
MR. SEGAL: Thank you, Your Honor.
THE COURT: Someone will g ive up a seat for you, I'm sure.
MR. ZONEN: W hy don't you sit up here at the table.
MR. SNEDDON: I just want to indicate to the Court that the representations that have
been made in the brief with regard to the fact, the key fact, one of the key facts, I think,
in the Court's determination about how much can be brought before the jury in this
particular case, Mr. Carter is testifying and he's testifying on his own, and he has not been
promised anything at all with regard to his testimony.
MR. SANGER: Well, on that issue, the reported decisions are replete with cases where the
representation was that there was no promise of leniency. And we've had very little t ime
to respond to this, so I'll ask leave to do this off the cuff, but if the Court wanted some
citations to the cases, I could certainly give them. The cases are numerous where there
has been no promise of leniency, or that's been the representation, and then when it
comes time for sentencing, the witness later, in his own case, receives a lenient sentence.
There are a number of habeas corpus cases where habeas corpus was granted based on
that exact scenario. I am not disputing at the moment what Mr. Sneddon has just said,
but the fact of the matter is, that anybody who's facing both state and federa charges and

very serious charges, bank robbery and robbery charges, may well have an inclination to
please whatever government official comes before him. And here we have the District
Attorney of the entire County of Santa Barbara who is handling this case. There's no
question this is a very high-profile, big case. There is no question that a person might
believe that by cooperating with Mr. Sneddon in the case of the century de jour, which will
be superseded, I'm sure, by some other case next week or next month, but right now
that's the way it was perceived and it would be perceived to a witness like this, he may
feel, by cooperating, that somehow this is going to redound to his benefit with other
prosecutors. We went back to the Gilio case, because that's sort of the root of all of this.
The United States Supreme Court made it clear that the potential for influence of a
witness's testimony is not up to the District Attorney to decide. It's up to the jury. And
therefore, the defense should be allowed to explore that, to know about it. This is Gilio
and that's the genesis of these cases. And the jury should be allowed to know about it so
that they can evaluate whether or not there's any influence. It's just -- even though this
has alread y happened with Janet Arvizo, I mean, this is extremely unusual that the
prosecution would come forward and say, We want to avoid -- We want a witness to
testify for us, but we want to prohibit the defense from fully confronting and crossexamining that witness. And the Court has fashioned a remedy with regard to Janet
Arvizo, which obviously was over objection, but this is beginning to add up, because
following this motion, they've got yet another motion. They've got another witness they
want to call who wants to take the Fifth and the jury's not supposed to know about it. This
is getting to be pretty weird, to put it in legal terms. All right? It's very, very unusual. It's
gone beyond unusual to weird. I mean, you just cannot put a defendant in a position
where the historic right to confront and cross-examine is being cut off or circumvented not
only once, but twice and three times. This particular situation is particularly egregious. I
mean, we've got somebody who's charged with bank robbery, and, you know, this is -this is not something that the defense should -THE COURT: So what are you asking?
MR. SANGER: Well, I think if the witness is going to -- as we said with regard to Mrs.
Arvizo, if the witness is going to be taking the Fifth, then their entire testimony is subject
to being stricken. I know the Court has cited the Hecker case, and -THE COURT: Well, I think that's a little different situation with Miss Arvizo.
MR. SANGER: Well, what I was going to say with regard to -- with regard to the cases -and I don't know what the Court meant. Maybe I should find out what you just meant by
that remark, if I may.
THE COURT: I think we're dealing with a little d ifferent situation here. But what did you
want to say about the case?
MR. SANGER: I'm trying to guess what the Court is getting at. What I was going to say
was that this is a witness called by the prosecution. It's not a complaining witness. And
maybe that's the distinction the Court was looking at.
THE COURT: (Nods head up and down.)
MR. SANGER: Okay. This is a witness they want to call. None of the cases that are cited
by the prosecution really stand for the proposition that they're advancing. It is true that in
the lead ing case that they cite, the defense sought to call a witness just to have the
witness take the Fifth in front of the jury to gain that kind of impact. And that's not what
we're talking about here. We're talking about the prosecution calling a witness and being
immunized from confrontation. One of the things Hecker said, and I'm not conceding this
at all. I think if these witnesses, these two witnesses -- if we could address both at the

same time, but certainly we can start with this one and equally it applies to Miss
Montgomery. If they're going to take the Fifth, then they take the Fifth out of the
presence of the jury and they go home, and that's it. I would point out that Hecker said,
which is the case the Court cited to us, that one of the remedies there, in a different
situation admittedly, but one of the remedies there would be to allow somebody to take
the Fifth and to have adverse comment made about that. Because again, it's -- as I
argued in the Arvizo matter, these people are not stakeholders. And certainly these two
witnesses we're now talking about are not stakeholders. If Miss Arvizo had any stake, it's
the mother of a complaining witness, I mean maybe. But these people have absolutely no
stake, and their asserting the Fifth Amendment should not hurt them in their own affairs,
if they were suing somebody or if they were being prosecuted and they're defending their
own case, but there's no reason why they should be immunized from confrontation in this
case, and there's no interest that they can assert -THE COURT: Let's hear from his attorney.
MR. SANGER: All right. Thank you.
THE COURT: Would you state your name, please?
MR. SEGAL: Yes. Good afternoon. My name is Jeff Segal, and I represent Chris Carter. Mr.
Carter has no dog in this fight. If he is called by the People or by Mr. Jackson, he is
prepared to testify truthfully, so long as he can do that without risking self-incrimination.
He is charged with very serious crimes in Las Vegas. He denies that he was involved in
committing those crimes. And the issue in all of those crimes is the identity of the
perpetrator. So I have instructed Mr. Carter to exercise his Fifth Amendment privilege with
respect to any questioning about the alleged criminal act ions in the State of Nevada, or
anything that might tend to implicate him in any of those crimes. With respect to whether
he does that in front of the jury, or outside the presence of the jury, that's for the parties
in this litigat ion to address. So long as Mr. Carter's rights are fully protected, you know, I
have no other point to make on that issue. So he is prepared to testify with respect to his
knowledge and involvement with Mr. Jackson, but he cannot do that if it means selfincrimination. So he will be -- he will be asserting his Fifth Amendment privilege. With
respect to any agreement for leniency or expectation for leniency, I certainly don't have
that expectation. There is no agreement with either Mr. Sneddon's office or with any of
the prosecutors in Nevada. And I have no expectation that there would be any leniency
down the road.
THE COURT: If he -- what if -- if he was asked the simple question whether or not charges
are pending against him, in other words, not whether he committed them, but, Is it true
you're charged with -- I don't know what it is, robbery, or whatever it is, in Nevada.
MR. SEGAL: Your Honor, I believe in an abundance of caution that he should not be
required to answer even those questions. I think there may be another way to introduce
that evidence before the jury, either by stipulation of the parties, or by the introduction of
some kind of court record, but I would strongly prefer that Mr. Carter is not asked those
questions, even that question, in front of the jury. I have no objection to that being
admitted in court. I have no standing to object to that. But I would instruct him to
exercise his Fifth Amendment privilege even as it relates to what crimes he's charged with
in Nevada.
THE COURT: All right. Anything further by either side?
MR. SANGER: If I could just clarify one thing, just to say we object in Santa Barbara to
analogies of dogs in fights, I think, but we might say no horse in this race. However, there
is a horse that this witness does have in this race, and he's charged with federal offenses.

State offenses would be the same, but federal offenses in particular, the 5K1 downward
departure is something that a person would argue if they came to sentencing, and there's
no question that to be competent, as I'm sure Mr. Segal is, he would argue for a 5K1
downward departure under the United States sentencing guidelines. And the guidelines, as
the Court is probably aware, have really been -THE COURT: Held unconstitutional.
MR. SANGER: More or less. Under Booker and Fanfan, the two cases Booker and Fanfan,
the guidelines have been opened up because they're found to be guidelines now, which
was, actually, the title, as to opposed to actual requirements, and so therefore any kind of
mitigation can be brought before the Court and would be brought before the Court. And I
would actually expect Mr. Segal, as I believe he's the lawyer on the federal case -- Is that
correct?
MR. SEGAL: In both cases.
MR. SANGER: In both cases, okay. I would expect Mr. Segal, as a federal practitioner,
unless he's confident he's just going to win the case, he'd be looking, as we all would in a
case like that, to the consequences at the time of sentencing and would be looking to
present evidence of mitigat ion. So there is a horse in the race or a dog in the fight, if we
take the analogy that was used by Mr. Segal, and we need to have the opportunity to
confront this person in front of the jury if he's going to testify, and say, Look, it's a fact
that you know that you're -- that you're facing serious charges, and that's going to color
your testimony, isn't it? and go into that kind of a cross-examination with him. S imp ly
sanitizing it and saying, well, you can bring in evidence through a docket or something, or
from some other witness that, yes, he's facing these charges doesn't do what crossexamination does. And the cases we cited before on cross-examination, it is a -- it is a
very effective tool in getting to the heart of somebody's testimony and allowing the jury,
the contemporaneous trier of fact, to see how that person performs and how things like
that might affect their assessment of credibility. So I'd submit as to this witness and also
the other one, to save some time, if it does, that either they take the Fifth or they don't,
which is certainly their right. But if they take the Fifth as to anything, then they should be
precluded from testifying as to everything.Thank you.
THE COURT: Anything further, Mr. Sneddon?
MR. SNEDDON: No. I guess my only comment would be -- I guess I shouldn't have said
No. I should have said Yes. I do have a brief comment, and my brief comment to the
Court is, first of all, I haven't heard any reason why the two cases we cited, the Bento
case, B-e-n-t-o, and the Dyer case, D-y-e-r, don't apply to this situation. And I just can't
sit there and let it go unsaid that Mr. Jackson's not the first person in the world that's ever
had a case where somebody comes in and claims the Fifth. That's why we have cases like
this, and there's a lot of them on the dockets. And it's -- it's -- two of the three people
were people associated with Mr. Jackson and we just happened to call them as witnesses.
They're in our case, but they're associates of Mr. Jackson. So I find it unfortunate that
they have to do that, but I don't think that this -- this sin should be laid at our doorstep.
It's just a fact that we have to bring to the Court's attention, because counsel
representing those people have ind icated in their representation of them they have to do
it. It's that simple.
THE COURT: All right. What I'm going to do is allow him to testify, and I'm going to
preclude the defense from inquiring into the circumstances of the crimes in Nevada for
which Mr. Carter is charged. I will allow, through some form, the fact that he is -- that he
has those pending charges in Nevada and that he is incarcerated. How we tell the jury

that I'm open to suggestion.

MR. SANGER: Could I address that issue?
THE COURT: Yes.
MR. SNEDDON: I'll make it very simple, stop Mr. Sanger from addressing the Court. I'll be
willing to work out a stipulation with Mr. Sanger which would satisfy the Court. If we can't,
then we'll come b ack to the Court.
MR. SANGER: I think we should be allowed to ask the question, not -- and not in an
excessive fashion, but ask two or three direct questions to the witness, and he should -- if
he wishes to take the Fifth, he should take the Fifth in front of the jury, and it should be
subject to adverse comment under the Hecker case.
THE COURT: Well, I've already ruled that you're not to ask him any questions to force him
to make a claim of the Fifth Amendment in front of the jury. And that suggestion that you
turn around and do that flies in the face of the ruling I just made.
MR. SANGER: I apologize. I didn't understand that. So -THE COURT: I'll give you an opportunity to work something out. If not, I'll do something,
tell them myself personally. I'll g ive you time. You can tell me Monday whether you've
reached agreement on how he's -- how the jury is to be advised. The next item is the -shall we take up the other claim of privilege? That's the plaint iff's motion in limine to
exclude evidence under the surrender flight. Is that ..

CYNTHIA C. MONTGOMERY EXAMINATION

MR. NICOLA: Should I bring the witness in, Your Honor, or would you like to hear
argument first?
THE COURT: The witness isn't here? Maybe we should bring her. Is she close?
MR. NICOLA: She's right outside.
THE COURT: Okay. Let's have her come in.
MR. NICOLA: Should she take the stand, Your Honor?
THE COURT: No. Let's see here. You're Miss Montgomery?
MS. MONTGOMERY: Right.
THE COURT: She's right there?
MR. NICOLA: She's right there.
THE COURT: Why don't you step forward, please. You don't have counsel with you, do
you?
MS. MONTGOMERY: No.
THE COURT: It's my understanding that -- well, before I state what my understanding is,
do you wish -- I'll have counsel address me. Do you want to address me on the issue?
MR. NICOLA: If I may, Your Honor.
THE COURT: You can sit down for a second. I'm sorry.
MR. NICOLA: We filed this motion with two alternatives. One is to preclude any mention of
the November 20th, 2003, flight, because it's simply irrelevant. What happened on that
flight and the conduct of anybody involved with that flight or thereafter is simply not
relevant to any issue that Miss Montgomery will testify to or any other issue in this case.
And insofar as the defense has certainly made it a habit to bring things up in their crossexamination which are marginally relevant to attack credib ility of witnesses, this is a
particularly thorny issue, because Ms. Montgomery has, in fact, been advised by her
attorney not to answer any questions with respect to conduct arising out of the November

20th surrender flight, as we've called it. And her attorney may have many reasons for
that. To presume it's kind of guilty conscience or knowledge of guilt or anything adverse is
not fair. And certainly the courts have said that's not a proper inference to draw. With
respect to perhaps drawing an analogy as to the previous motion the Court heard, we -THE COURT: Would you -- would you come forward, please? You know what I'd like to do,
I don't know what instructions your counsel's given you, but what I would like to do is
have you sworn and have you state under oath that you intend to invoke the Fifth
Amendment so there's no question about what you're doing. That's the only reason.
EXAMINATION BY THE COURT:
Q. Miss Montgomery, if any questions were asked to you concerning the travel on charter
jets and the booking of flights by Michael Jackson or Michael Jackson's companies, what
would your answer be? Would you be claiming the Fifth Amendment?
MR. NICOLA: I don't think she understood the question, Your Honor.
Q. BY THE COURT: All right. I'm just asking you a general question. If you were
questioned at all about arranging chartered flights for Michael Jackson or his company
during the time period from, let's say, 2002 through 2004, would you claim the Fifth
Amendment?
A. Um, only on Novemb er 20th of 2003.
Q. Only on that -A. Correct.
Q. -- flight? Is that the flight you were going to question her about?
MR. NICOLA: No. That's the flight that we wish to exclude from evid ence under 352 and
relevance.
THE COURT: Okay. That's the flight you're going to question her about?
MR. SANGER: Yes, Your Honor, and all the circumstances surrounding it, including the
lawsuit, her cross-complaint against Mr. Jackson that she is litigat ing for money, and the
fact that she came forward and offered to be an informant, a confidential informant, and
brought forth a friend of hers who she offered as a confidential informant, who in fact was
enlisted by the police to surreptitiously tape-record phone calls. That kind of cooperation,
that level of cooperation was, we believe, direct ly dictated by the fact that she's under
federal investigation and engaged in a lawsuit surrounding the same facts both as a
defendant and as a cross-complainant.
THE COURT: What's the -- what are you calling her for? What is the purpose of the
testimony that you wish -MR. NICOLA: Well, as a general proffer, Your Honor, Ms. Montgomery was the defendant's
travel coordinator for a period of some time, during the relevant period of time. Say late
2002 through approximately September, she arranged private flights for Mr. Jackson.
She's aware of the people that he flew with and continued to fly with after the conduct
alleg ed in the 288 counts, which is circumstantial evidence of a continu ing conspiracy.
She's going to offer testimony about Count 1, with respect to the Arvizos getting, through
Mr. Schaffel, short-set one-way tickets to Brazil, with a date to leave of nearly
immed iately after the rebuttal video was filmed, things of that nature. With respect to the
November 20th, 2003, flight, we didn't intend to introduce at all or ask her any questions
at all. And we understand that the existence of a civil lawsuit is certainly something that
the defense can argue creates a bias within the witness as she testifies. However, the
underlying facts of the lawsuit appear to be largely irrelevant. It's almost like a witness --

mind you, there are no charges. She has not been charged. There's no evidence that she's
being actively investigated, only that an investigation is being conducted. Under those
circumstances, it's akin to asking a witness, Isn't it true that you're being audited by the
IRS? And the implication there is that you violated some kind of federal tax statute. It's
just simply not relevant.
MR. SANGER: Interesting. Because this actually is a progression along a continuum. Your
Honor said the Janet Arvizo was different than Chris Carter, and Chris Carter is actually
different than this, so I suppose this tests the hypothesis here. In this particular case, Mr.
Sneddon said two of the three witnesses -- I forgot what his words were. Two of the three
witnesses are associates of Michael Jackson, something like that. This witness is not in
any sense an associate of Michael Jackson. She was in business for herself. But more
importantly, Michael Jackson is the victim in her criminal activity. The FBI has an active
investigat ion. They've interviewed people, and they've seized evidence ind icat ing that Xtra
Jet and Miss Montgomery have engaged in -MR. NICOLA: Your Honor, I'm going to object at this point. I don't think Mr. Sanger's
doing this for anybody's benefit except for the people behind us. If he has -MR. SANGER: That's absolutely not true, and if there's a legal objection -THE COURT: The objection is overruled.
MR. SANGER: All right. She -- they surreptitiously videotaped Michael Jackson and
attempted to sell the tape, and that's how they got caught, and Michael Jackson is the
victim of this person. So we really have a continuum here of some sort, or maybe it comes
back to a circle, depending on how you look at Janet Arvizo's activit ies. But certainly here
he's -- he is a victim. And if Michael Jackson, the victim of this conduct of surreptitiously
taping and attempting to sell that tape, if Mr. Jackson were convicted in this case with the
help of Miss Montgomery, it would certainly help her in her civil case where she has filed a
cross-complaint against Mr. Jackson. Excuse me one second. Yes. (Off-the-record
discussion held at counsel table.)
MR. SANGER: I mean, was that not clear? I'm sorry. I'm sorry, it's the end of the day. Mr.
Mesereau is saying the Court understands that Mr. Jackson in the civil case is the plaintiff.
I think I said this. And I think the Court knows it. He's the plaintiff.
THE COURT: I understand.
MR. SANGER: He has sued Xtra Jet. And she, Miss Montgomery, has cross-complained
against Mr. Michael Jackson. The point is, she has a big stake in the outcome of this case
because it would directlyimpact her civil case and may or may not impact the underlying
criminal case. But all of that behavior on the part of Miss Montgomery and Xtra Jet also
gives a tremendous amount of content and context, both content and context, to her
activities in volunteering, going to the police, the sheriff here in Santa Barbara any
volunteering that she had information. Her informat ion that she offered was primarily
hearsay, double or triple hearsay, and she offered to be helpful and she was considered to
be a confidential informant for about eight or nine months. The Court may remember that
we complained that we didn't get discovery about Miss Montgomery and about Mr.
Provencio that they had compiled in January, and we d idn't get it until October or
something. And the government got up and said, Well, we didn't give that to you because
they were confident ial informants. We didn't want to tell you what they were doing. They
came forward, and she really didn't have much firsthand or anything firsthand, but she
then got the government in contact with Mr. Provencio, who she continued to contact. And
he eventually was told to tape-record conversations with other people, not with Mr.
Jackson, so -- I

don't think he knew Mr. Jackson. But that was -- that was being used, and in fact, they're
seeking to call him as another witness in this case. So I think we have to have the right to
confront and cross-examine this woman on her bias. She's involved in lit igation. And the
underlying basis of the litigation is the illegal not only taping of Mr. Jackson as a celebrity
and making him a victim of this, but attempting to sell that tape.
THE COURT: Well, the case is -- this is a different situation than the other two, as you
pointed out. Each are distinctly different approaches. And the -- in this case, the Court's
going to exclude the testimony entirely. I believe that the District Attorney has the ability
to produce the evidence that she would testify to through other means, and the claim of
the privilege here would be a total deprivation of the right to cross-examination. So her
testimony is ordered excluded based on her claim of privilege under the Fifth Amendment.
Let's see, we're through with our day. There's one motion left. I guess we could take that
up Monday morning, unless everyone wants to meet tomorrow.
MR. SANGER: I think there are two.
THE COURT: Hold up your hand if you want to meet tomorrow. My bailiff is holding up....
THE COURT: Oh, I skipped 9 and 10, too. I don't want to go on now because the court
reporter has to do her daily transcript, and we're all -- I guess 9 and 10 -MR. SANGER: I think there's 9, 10 and 12.
THE COURT: Yeah, on 9 we're going to have a longer hearing. I need more informat ion on
those documents. So I'm not -- I wouldn't -- that's not a short issue. The admissibility of
the state of Gavin's testimony by Chris Carter, if I could have resolved that by saying no,
we wouldn't have had to deal with the Fifth Amendment problem. So you know my ruling
on the admissibility of that statement is that he can give that evidence. But I think we'll
take up the other issues on Monday, then.

2005 April 25 (days 38) B. OXMAN fired by Mesereau. Testimonies continued

COUNSEL AT COUNSEL TABLE:

(The following proceeding is held on open Court)
THE COURT: Let's see. There was an issue you wanted to address, Counsel?
MR. MESEREAU: Yes. Yes, please, Your Honor. Thank you. Your Honor, I was informed
by the prosecution this morning that they want to call Cindy Montgomery as a witness. As
the Court may recall, the Court essentially disqualified Miss Montgomery last week
because she's going to assert a Fifth Amendment privilege on certain issues related to a
secret taping of Mr. Jackson on a plane. The prosecution informed me this morning after I
got to court that they have decided to grant her immun ity. This is a surprise to the
defense, and I was not prepared to examine her today. I have materials on Miss
Montgomery that are not with me
today, and it would be prejudicial to the defense for them to suddenly decide to immunize
her and call her without us being aware of that. The second issue, Your Honor, has to do
with a witness named Hamid, who the prosecution intends to call today. We were given
proper notice that he was to testify, but we were notified last night by Prosecutor
Auchincloss that there is a tape of an interview that we have not heard and certainly have
not had a chance to transcribe. So because we have not been able to do that, we'd
request that Hamid not testify today. I am told by Ms. Yu, who spoke to Mr. Auchincloss,
that the tape is apparently not that lengthy, but we could not transcribe it in t ime,
obviously, and I would need that for cross-examination. Based upon the information given
to Ms. Yu by Mr. Auchincloss, there could be some significant information of value to us in
that tape. They're the two requests, Your Honor.
MR. AUCHINCLOSS: Your Honor, I'll go ahead and address the Hamid issue first. Mr.
Nicola will talk about Miss Montgomery. Mr. Moslehi was interviewed on Saturday by
myself and Detective Robel, and he gave us information on four points, basically that were
summarized in four sentences, that I provided to the defense yesterday. Detective Robel
recorded that conversation on a digital recorder. He came back to Santa Maria yesterday
and downloaded it and made a CD copy of that. And yesterday afternoon when he had
finished that, we contacted the defense and tried to set up a meeting place where we
could provide them with that tape. That didn't work out. It was -- the evening kind of
became -- it became somewhat late and Miss Yu said she couldn't make it to deliver that
document, or that tape. I also provided Mr. Sanger an e-mail with a copy of the four bullet
points and I told Miss Yu yesterday the substance of those four points. So that's where we
stand. Mr. Moslehi is a witness that -- probably our lengthiest witness today. So he was
anticipated to take up most of the day. And I'll just say that the discovery was certainly
timely in the fact that we turned it over as soon as we -- as soon as we obtained it.
THE COURT: All right.
MR. NICOLA: Good morning, Your Honor. I filed a declaration, a motion for
reconsideration, and had those documents served on the defense by fax on Friday
morning, and we filed it with the Court Friday morning, as well, with respect to Ms.
Montgomery. And essentially in the declaration I believe I laid out that we received late
notice on Wednesday that Ms. Montgomery would assert the Fifth on Friday -- or on
Thursday, excuse me. We didn't have time to contact the U.S. Attorney and see their

stance. On Thursday, after the Court's ruling, I was in touch with both Miss Montgomery's
attorney and the U.S. Attorney. A decision was made at that time to offer use immun ity
for Miss Montgomery since she was claiming the Fifth. And upon hearing Thursday
afternoon that everybody was okay with that, including the U.S. Attorney, I filed my
motions as quickly as I could Friday morning. I know we faxed them to Mr. Sanger's
office. I have no knowledge whether he received them or Mr. Mesereau did, but we did file
it, and there is a proof of service on file.
MR. SANGER: I see that we have six pending matters and then I was handed some more
material just this morning. So we just may need time to sort this out, Your Honor. I think
we're all trying to do this as efficiently as possible. On the Montgomery issue, we received
sometime on Friday -- and I don't think it was in the morning. I didn't see it until the end
of the day. Of course we were not in session, so it was sent to me. But there was a motion
to grant her use immun ity, which, as I understand it, is something that the People are
going to have to apply to the Court for, and then the Court has to determine whether or
not to grant it, and the witness has to decide whether or not to testify based on use
immunity, because there's a question as to whether or not this Court can bind the U.S.
Attorney. I heard the prosecution just say something about being in contact with the U.S.
Attorney, and my recollection is - and it may be faulty - that that was not concluded as of
the time they filed their papers. The papers indicated that they were intending to make
the motion, but there was no indication from the U.S. Attorney that they were going to
abide by any grant of immun ity that this Court made. So that is an issue that obviously
needs to be heard, and there's several parts to it. Our part, whether or not the Court
grants immunity -- I mean, we're not here to argue one way or the other on a grant of
immunity. The Court can do that based on other criteria. The -- as far as the Hamid
material is concerned, I d id not get the four points. I believe Miss Yu got the four points
just as of the end of the day last night. We got the tape or the interview just this morning,
so obviously I don't know how long it is. If it's an hour long, we need an hour to listen to
it. We have not heard his most recent interview. So I -- I don't think that we can proceed
with Mr. Moslehi without having an opportunity to hear the latest interview or, you know,
take some other -- I think that's all we can do is hear it before he testifies. I would
indicate that, just so we're all on the same page, if I may, Your Honor, quickly, the other
matters that are pending would be the Marc Schaffel matter, which I think the Court has. I
was given some new material for Exhibit 420 by the prosecutor just this morning, at 8:30,
which is one of the exhibits that we have objected to, and so there will need to be a
hearing on all of that at some point. And I don't know if they intend to call him later today
or tomorrow or when, but before he's called. That was a matter from last week that has
been carried over, and we'll need to have a ruling on that. And then we have the motion - the People's motion to present the testimony of Alexander Manchester, to which we
object, and we filed an objection on Friday. And by the way, we filed our objection - I
think the Court has it - on Thursday, on the first motion I addressed, which is the Schaffel
exhibits. We addressed just now the Cindy Montgomery issue of immun ity. The fourth one
would be a motion by the prosecution to present testimony of Debbie Rowe. We filed an
opposition -- that was received Thursday. We filed an opposition Friday. I take it the Court
has that. And then five, there was a motion for reconsideration of admitting some material
the Court had excluded. That motion was filed on Thursday, and we filed our opposition on
Friday. And then the last thing is there was a proposed jury instruction on Chris Carter's
taking the Fifth that we had discussed on Thursday. The Court had discussed that and said
we should present something. We sent that to the District Attorney's Office on Friday for

review and comment. We received no response. So we filed our proposed jury instruction
this morning for the Court's consideration and I gave another copy to Mr. Auchincloss. So
I show those six matters as still pending, in add ition to anything else that might come up
here.
THE COURT: I didn't see the proposed jury instruction. Did we get that? I haven't seen
it.
MR. SANGER: We wanted the prosecution to have an opportunity to respond, so we gave
it to them on Friday. We just filed it this morning, and gave it to your secretary, Ms.
Wagner, this morning, I think 15 minutes ago.
MR. SNEDDON: Judge, I wouldn't worry about it. Mr. Carter is not going to be testifying.
THE COURT: Okay. I won't worry about it. (Laughter.)
MR. SANGER: Five matters, then.
THE COURT: On the issue of the Attorney General, who spoke to the Attorney General on
the use immunity?
MR. NICOLA: The U.S. Attorney's Office, Your Honor, and Cindy Montgomery?
THE COURT: Yes.
MR. NICOLA: I spoke to them. They are not offering her use immun ity. They didn't
oppose us offering use immunity. Our contact with them is merely a formality between
offices.
THE COURT: What rights does that give her with them?
MR. NICOLA: Well, I believe that a state court's grant of use immun ity under the legal
standard that we set forth in our brief covers her in federal court. They're not allowed to
use her statements, her derivative evidence from that against them. Her attorney is here
today, and he would, of course, oppose her being compelled to testify on that very basis.
But we served him as well with that motion. He won't contest that. I spoke to him this
morning. And whatever the Court's ruling is with respect to that, then that's the Court's
ruling.
THE COURT: Is he here right now?
MR. NICOLA: He is not.
MR. SNEDDON: He's upstairs.
MR. NICOLA: Shall I bring him down?
THE COURT: I think he should be here if we're d iscussing his client.
MR. NICOLA: Certainly. It will be just a moment, Your Honor. Your Honor, do you wish
the witness to be in here as well?
THE COURT: Yes.
MR. NICOLA: Your Honor, they are present.
THE COURT: All right. Just a second. All right. On the testimony on Cindy Montgomery, is
counsel for Miss Montgomery present?
MR. MOORE: Yes, I am, Your Honor. Bob Moore. Good morning.
THE COURT: Mr. Moore, the issue that I had talked to the District Attorney about before I
realized you weren't in the courtroom was what the U.S. Attorney's position was on your
client's use immun ity through the state court.
MR. MOORE: I don't believe he's taken a position.
THE COURT: What's your position, then?
MR. MOORE: My position is if she testifies here, she's exposing herself to prosecution. I'm
not saying a crime was committed or that she was involved in it, but she might say
something that's incriminating.
THE COURT: Is there any protection under the federal court system once a use immunity

is granted here?
MR. MOORE: The People have cited a couple of cases, which perhaps support that.
However, I'm concerned about the language in the code, 1324. It says, and I quote, The
Court shall order the question answered or the evidence produced unless it finds that to
do so would clearly -- would be clearly contrary to public interest or could subject the
witness to a criminal prosecution in another jurisdiction. And I think that language is
meaningful. We have the federal jurisdiction. If a crime occurred, it may have occurred in
Los Angeles County. It may have also occurred in Rivers ide County and in Las Vegas. And
those are additional jurisdictions which have not been addressed.
THE COURT: Isn't the use immunity provision clear in terms of prosecution under
California law? I mean, we're really one jurisdiction under California law. It's the federal
jurisdiction that I would -- that I'm concerned about.
MR. MOORE: And so am I.
THE COURT: There's no federal statute similar to the California statute that covers this?
MR. MOORE: 1324, do you mean? I'm not sure, Your Honor.
THE COURT: Have you yourself discussed it with the U.S. Attorney's Office?
MR. MOORE: Yes, I spoke with him on Frid ay. And he took no position, which leads me to
believe that there could be a prosecution down the road.
THE COURT: All right. Thank you.
MR. MOORE: Thank you, Your Honor.
MR. NICOLA: May I address the Court on that legal issue, Your Honor?
THE COURT: Yes.
MR. NICOLA: May I borrow your brief?
MR. MOORE: Sure.
MR. NICOLA: Your Honor, I also left my -- the papers I filed on Friday upstairs. And Mr.
Moore has allowed to let me use the one I faxed to him Friday. Your Honor, we believe our
authorities are directly on point with respect to this issue. The Supreme Court ruled quite
some time ago that the Fifth Amendment privilege is of Constitutional significance,
obviously. And immun ity from prosecution for a witness who's compelled to testify under a
grant of use immunity or derivative immunity or even transactional immunity transcends
between the state courts and the federal courts. The case is absolutely clear about that
issue. And when -- when the Supreme Court looked at the federal statutes, they analyzed
them within the context of one jurisdiction granting use immunity to a witness who may
further be subject to prosecution or an investigation in federal court. It was very specific
to that. And congress has passed other statutes which are not inconsistent with California
law. With respect to the California courts, they've been following the Supreme Court line
of cases now for quite some time. The case in particular was Nelson, and the fact pattern
in Nelson is fairly identical to the one that we've -- we have confronting us in here; a
witness believes that part of their activity with respect to what they may testify to could
subject them to some kind of prosecution federally. And the Nelson court ruled that
because of the Waterfront case, Murphy v. Waterfront, the issue has been well settled.
The same kind of fact pattern, a witness in state court testifying to something they're
worried about in federal court. And the Nelson court upheld the contempt order for those
witnesses refusing to testify. So we believe that we're on pretty firm ground here. And
we'd request that the Court sign that use immun ity order.
MR. MOORE: May I respond briefly, Your Honor?
THE COURT: Yes.
MR. MOORE: As I mentioned earlier, to the extent that if the crime occurred, it may have

also occurred in the State of Nevada, which is a separate jurisdiction. And the code -- the
language in the code says if you believe that the prospective witness could be exposed to
prosecution in a different jurisdiction, that's a different jurisdiction. Federal court is a
different jurisdiction. The People have cited cases that seem to indicate -- and they're
somewhat old, but indicate that that immunity would be respected by the federal court.
They cited nothing to say that the State of Nevada, if a crime occurred there, is bound by
the immunity you might give her today. Thank you, Your Honor.
THE COURT: Do you want to address the Nevada issue, Counsel?
MR. NICOLA: May I, Judge? The United States Supreme Court authority is binding on
every court in the country, whether it's in Nevada, Alaska or California. The Waterfront
holding is good law and has been for, I believe, nearly 40 years. And part of the
reasoning, the broad reasoning that the Supreme Court gave it back three or four decades
ago - I forget the exact date of the publication of that opinion - was that to require every
jurisdiction within the umbrella of the United States jurisprudence to grant use immunity
before any prosecutorial agency could use the testimony of that witness in their case is
unduly burdensome on government in its most legitimate function, which is the prevention
of crime and justice. So given that being the state of Supreme Court law in this country,
we believe that Mr. Moore, if charges were filed against his client, based on anything she
may say from this witness stand under compelled testimony by the Court, he should have
no problem whatsoever avoid ing that evidence from being used against her, if, in fact, it
does incriminate her for something. That's all speculat ion, but we understand the statute
invites a small amount of speculation with the Court. We believe that your grant of use
immunity compelling her to testify will preclude any jurisdiction, including Nevada,
although I can't cite a case aside from the Supreme Court case that we cited previously,
from using that testimony or any derivative evidence from that against her.
THE COURT: There's one area of the law that concerns me if I compel her to testify, and
she testifies, and the law is that that testimony cannot be used against her, which I think
that is what the law is. What is the law in regards to impeachment in the federal court? If
she testifies and testifies contradictory in a federal proceeding, is the testimony that was
compelled here admissible for impeachment in substantive purposes against her?
MR. NICOLA: Your Honor, my understanding of federal law is unless it's a voluntary
statement, she can't be impeached in a federal court. It cannot be used against her in the
federal court.
THE COURT: They can't hear you in the back.
MR. NICOLA: I'm sorry, Your Honor. I thought I was speaking up. The use immunity -the use immunity law essentially and intellectually merges all the courts. The Supreme
Court fails to see the distinction between any jurisdiction. So essentially a grant of use
immunity makes that -- that statement or any use of it, even impeachment purposes or
getting a search warrant based on the statement that was given in court, completely
untouchable. It cannot be used, period. It's not a voluntary statement. It's a compelled
statement. And it's protected under the U.S. Constitution according to Waterford (sic). It
cannot used against Miss Montgomery in any fashion, by anyone.
THE COURT: All right. Anything you want to add, Counsel?
MR. MOORE: I'm not sure that's an accurate statement. If she were to say something
inconsistent, it could be used. It's my opinion. Perhaps I'm wrong, Your Honor.
THE COURT: What do you base your opinion on?
MR. MOORE: Well, I'm kind of shooting from the hip right now. It's a question I didn't
expect. So I apologize.

THE COURT: That's called lack of authority.

MR. MOORE: Perhaps. No authority I can think of at the moment, though. And with
respect to counsel's statement earlier about the federal case law he cited governing all the
states, what the case says, in Daly I think it was, it says that the testimony given in state
-- compelled testimony given in state court cannot be used in a federal prosecution. That's
what it says. Doesn't say it can't be used in a federal prosecution or in any other
jurisdiction.
THE COURT: All right. Thank you.
MR. MOORE: Thank you.
THE COURT: Let's take up the motion to present testimony of Alexander Montague.
MR. MOORE: Just before I leave, Mr. Sanger has been kind enough to give me a case,
Harris v. New York, that says that impeachment can be used.
THE COURT: Do you have a citat ion on that?
MR. MOORE: No. U.S. Supreme Court. I'm sorry.
THE COURT: That's the old Harris case. (Laughter.)
MR. MOORE: Yes, Your Honor, the old Harris case.
THE COURT: Yes.
MR. MOORE: We all know it well.
THE COURT: Maybe you'd like to run out - we have a law library here - find it, and come
back. I'll withhold any ruling until you find that.
MR. MOORE: I will do my best.
MR. ZONEN: Your Honor, the motion is a motion by the People to present the testimony of
Alexander Manchester. We've outlined in the brief what it is we expect that Mr.
Manchester will be testifying to. The relevance deals with three specific aspects of his
testimony. First, he'll be testifying as to dozens and dozens of telephone calls that were
made by the defendant to his child, this was back in, I believe, 1998 or 1999, I don't
recall which, at the earliest stages of his becoming acquainted with this child. Telephone
calls that were made all hours of the day, all hours of the night. And that testimony is
entirely consistent with the testimony of both Gavin Arvizo, his mother, about the
telephone calls received by Gavin, as well as the testimony of June Chandler in terms of
the level of obsessiveness with which the defendant pursued a relationship with her child,
Jordan Chandler, back in 1993. In that regard, the testimony of Mr. Manchester is entirely
corroborative of those three witnesses. Secondly, he was prepared to testify to a visit that
he had with Mr. Jackson at Neverland Ranch where he was in the theater and lost track of
his child and Mr. Jackson, for an hour and a half he spent looking for his child, and
eventually found the child up in Mr. Jackson's bedroom under circumstances outlined in
the brief. That, plus his statements to Mr. Jackson thereafter complaining about that
particular event resulting in Mr. Manchester being threatened, physically threatened,
physically confronted by a couple of Mr. Jackson's security people. And the notifying Mr.
Jackson of that particular event certainly places Mr. Jackson on notice of the fact that staff
at Neverland have been and continue to be vigilant in their protection of Mr. Jackson to
the extent of using violence and threatening violence. Specifically, Mr. Manchester was
threatened that harm could come to him and his family from fans in a manner that is
entirely consistent with the threats that were given to Janet Arvizo. We believe that those
three specific areas of testimony are relevant for purposes of corroboration and are not so
uniquely remote in time from the events that took place in this case, and are right on
point in terms of the types of testimony given by a numb er of witnesses in this case.
Submit it.

MR. SANGER: We filed a brief response to this, but -- and I think we really covered it. I
mean, the fact of the matter is that this is offered as 1101(b) evidence, not as 1108. It
obviously could not come in under the Court's prior rulings on 1108. It is a big stretch on
all of those points to say that this is conduct that would qualify under 1101(b). It is
extremely remote in time. This is a witness who has been, in essence, clamoring to be a
part of this case. And there are people like that, and they should be viewed with some
distrust. This man's child was interviewed and consistently denied that anything
inappropriate had happened. There's no evidence that anything inappropriate had
happened. And yet we have this man, who is a self-proclaimed, perhaps actually is some
sort of royalty down the line, who just insists he wants to be a part of this case. And I
don't think this qualifies under any stretch of the imagination. It's way too remote in time.
Despite Mr. Zonen's rhetorical efforts to make it similar, it isn't similar. The fact that some
security guard did something in 19 -- in the 1990s, and Mr. Jackson may or may not have
been aware of it, doesn't mean that it can be used against Mr. Jackson in this case. And it
really comes down, in essence, to one thing. And I was almost just going to submit it
without saying anything, but I want to -THE COURT: But you just couldn't do that.
MR. SANGER: I couldn't do that. Now I'm trying to justify it.
THE COURT: I knew you couldn't do that.
MR. SANGER: Some of these last-minute motions share something in common, and that is
sort of a desperation to come in and dirty up the case and make Mr. Jackson look bad as
opposed to really bear on something that is actually relevant to this case. The Court has
now heard the testimony of Janet Arvizo and some of the other testimony that makes the
story of the complaining witnesses in this case highly improbable, to say the least. And it
just isn't right to allow the government to come in at the last minute and try to pull in
strings on things that are not relevant and are not proper 1101(b) or 1108 evidence. So
I'll submit it on that, Your Honor.
MR. ZONEN: Mr. Manchester -- it's our desire that Mr. Manchester be a witness in this
case. It's hardly Mr. Manchester's desire. He'd be happy to be left well enough alone. He
has been on our witness list from day one. He was subject to an interview at the earliest
stages of this investigation. And we're talking about within weeks after the execution of
the search warrant at Neverland. This informat ion has been turned over to the defense.
It's been well over a year, probably closer to a year and a half, that they've had this
informat ion, or longer. We certainly indicated that we intended on calling him from the
very earliest stages, if not just the investigation, but certainly the trial as well, and he was
on our witness list from day one. Now, this motion is being filed at this stage because it is
corroborative of the testimony of other witnesses, and it was appropriate to wait and see
how they testified before doing this, but nothing comes as a surprise. These materials and
reports were turned over to the defense early on. And it is corroborative of all of them. It
is -- does come in as well under 1101, but also it is, under California's constitution, that all
relevant evidence is admissible, and this is clearly relevant evidence. It's corroborative of
each of the three different witnesses. Submit it.
THE COURT: All right. The Court's going to deny the motion to introduce Alexander
Manchester's testimony. It doesn't comply with my previous ruling that there had to be
some connection of evidence of grooming activities with actual molestation, and there's no
consistency in the other parts of it that would lead the Court to admit it under 1101. So
that motion is denied. The motion that -- on the admissibility of Gavin's statement to
Chris Carter, that's no longer an issue, is it?

MR. SNEDDON: You ruled on that already, Your Honor. You ruled that it was admissible,
but it's no longer an issue.
THE COURT: I think I said I intended to admit it at the end of the court day, didn't I?
MR. SNEDDON: Yes, Your Honor.
THE COURT: But I didn't want to rule out a statement from someone, or an argument if
someone wanted to make it.
MR. SANGER: Chris Carter -MR. SNEDDON: It's not necessary, Your Honor.
THE COURT: It's not necessary.
MR. SNEDDON: It's not at this point.
THE COURT: I just wanted to be sure. Okay. And the issue on the admissibility of the
defendant's adult books from 1993 seizure, have you responded to that?
MR. SANGER: Yes, sir, we filed something on Friday on that.
THE COURT: Do you wish to add anything more to that? Either side?
MR. ZONEN: I'm sorry, was the Court addressing the prosecution?
THE COURT: Yes.
MR. ZONEN: On ly to the extent of saying that it is our recollection that the Court had
indicated that the Court would reconsider the issue with regards to the .93 seizure subject
to resolution of the 1108 motion. That, of course, has been resolved. These books were
seized -- we are only asking to introduce two books of all the items that were seized
during that period of time.
THE COURT: Where are those books?
MR. ZONEN: W e have them here in Santa Maria. W e could have them before the Court
within an hour, if the Court would like to see them.
THE COURT: I'd like to see them.
MR. ZONEN: A ll right. We'll make arrangements to get them over here to you.
MR. SANGER: And, Your Honor, your comments suggest that you don't have the
opposition in front of you. Could I give you -THE COURT: I don't have it in front of me. Thanks.
MR. SANGER: Let me just give you a copy.
THE COURT: I'm going to reserve ruling on that until I see the books. The testimony of
Debbie Rowe. Do you wish to be heard on that?
MR. ZONEN: Your Honor, very briefly. The facts are outlined in the People's brief on that
matter, but Miss Rowe had -- virtually at the same time that Miss Arvizo was submitting to
a tape-recorded interview or vid eotaped interview for purposes of rehabilitat ing the
damages to the defendant caused by the Bashir documentary, Miss Rowe was doing
exactly the same thing. It was also a highly scripted interview that was being conducted.
And there was the virtual ident ical incent ive for her to do so, participate in the interview.
And not just participate in the interview, but participate in the interview with enthusiasm
was the suggestion in statement that she would be allowed to have visitation with her
children. Something she did not have at that time. That was, in part, of course, an
incentive for her to participate in that interview. We believe that the fact that they used
the same types of scripted questioning for purposes of conducting this interview, that her
performance was the same level of over-the-top type of performance that we saw from
Miss Arvizo, and the fact that the children were used as pawns to create that level of
incentive is relevant in this case. Submit it.
THE COURT: What about the fact that the defense raises that the Maury Povich footage
has not been seen by the jury?

MR. ZONEN: W ell, nor -- the Maury Povich tape is not relevant in this proceeding as
having anyth ing to do with her interview, except to the extent that segments of her
interview are in it. We're not planning on playing the Maury Povich interview. If we wish -THE COURT: How does the jury understand the context of what you're presenting?
MR. ZONEN: W ell, they have the -- we have the interview of Debbie Rowe separate. The
entire interview was about three hours long. We haven't decided if we intend on playing
all of it, any of it or none of it.
THE COURT: The interview by -MR. ZONEN: The Ian Drew interview of Debbie Rowe, which was done at the same time.
Marc Schaffel was present, Rudy Provencio was present. A number of the people who were
involved in the interview with the Arvizo family were involved in this interview as well. And
a number of them were present at that time, and there was discussions about what to do
and how to do it. Many of them are witnesses to those events as well, including Debbie
Rowe's attorney, Iris Finsilven. But it's not necessary to play the Maury Povich film in that
most of it has nothing to do with the Debbie Rowe interview. It's simply other information
about Michael Jackson, his history, his life, his performances, his music, other people in
his life, his father and allegat ions of abuse, things like that. But there is a separate video
of the entirety of the Debbie Rowe interview. Only segments of it were actually shown on
the Maury Povich film. But we have the entire thing on video and are able to play the
entire thing if it's appropriate to do so, if it's requested by either side, if the Court feels its
appropriate. Or we could do it in segments, or we could do none of it and just have
testimony about it. The interview is about three hours and two minutes, I believe, in its
entirety.
THE COURT: Counsel?
MR. SANGER: This, once again, is reaching. First of all, Debbie Rowe gave up her parental
rights, which is a totally different situation than we have here. There's an ongoing family
law matter that persists, even as we speak today, in Los Angeles over this, over the
relationship and her attempt to get some -- possibly some visitation or some other benefit
from that. However, we keep hearing scripted performances, and there are no scripts. The
only thing that has ever come up in this case, and will be clearly shown, if it isn't already,
by the time we get through, is that there were questions that were written out in advance.
And anybody that does any kind of an interview for televis ion is going to script out
questions in advance, just as lawyers script out questions or question areas before they
get up and ask witnesses on the stand, so interviewers script out their questions. There's
nothing untoward about that. There was no scripted response to anything, despite Janet
Arvizo's preposterous testimony on that. Everybody else will testify consistently with
common sense that there was no script of answers. So it doesn't show a darned thing in
that regard. And as we pointed out, and the Court's already commented, the Maury Povich
show is not in evidence. I don't think there's any way we can get it into evidence. We
don't intend to offer it. And as a result, unless Debbie Rowe testifies, of course, so how is
her performance on that tape relevant, as much as the prosecution would like to make it
relevant. And I'm hearing they'd like to play parts of her tape, which just creates, under
352, if we even get to that point, if there is any probative value to this, it's far exceeded
by the consumption of time, the confusion of the jury and the prejudicial effect. Because if
they bring that in and they play even part of the Debbie Rowe tape, we'll p lay the three
hours. There's no question that Debbie Rowe was spontaneous in her remarks, and it goes
on and on. I think the Court saw the Maury Povich part of it, where she even answers at
one point, Look, and she uses some term that would not ordinarily be appropriate on

television, kind of laughs about it, and says, I just want to get to the point. Here's what
it's all about. That is her demeanor on the rest of that tape. She is giving an interview
based on how she felt at the time. However, if the Court allows the prosecution to get into
this, besides playing the three-hour tape or a large portion of it - not as a threat, but
because it will show the context of her answering questions in a very spontaneous fashion
- we will have to get into this whole business with Ian Drew, and h is fight with Marc
Schaffel, and Marc Schaffel's fight with Ian Drew, and all these -- the -- all that
surrounded this. Debbie Rowe's on tape. In fact -- and she surreptitiously tape-recorded
conversations that she had with Ian Drew that go on for hours where she is not upset at
Michael Jackson, doesn't say anything bad about Michael Jackson as far as this -- the case
is concerned. She says a few callous things, I might point out. But other than that, her
focus is she doesn't like Marc Schaffel. And so she's fighting with -- or working with Ian
Drew to fight about Marc Schaffel. All of this will come out to show -- it will have to come
out because it shows the context in which she would be testifying here. She has been
extremely upset with Marc Schaffel for some other reason and has had an agenda that's
clear on all of her taped remarks, including the ones she taped of herself talking. It's very
clear that she has some agenda with regard to Marc Schaffel that has nothing whatsoever
to do with Michael Jackson. She regards him as just being pretty much a victim in Marc
Schaffel's machinations. So if she's going to testify, we're going to have to bring that out.
Again, it's not a threat. But I want the Court to understand the context. There really is a
tremendous amount of material, tape-recorded material, by Debbie Rowe and by others in
the group that the prosecution is trying to present here which indicate that there are -there are many other agendas on this case. I don't know if you get to 352 because I just
plain don't see the relevance, forgetting about the giant can of worms that it would open.
I just don't see the relevance to these proceedings. So I'd submit it, Your Honor.
MR. ZONEN: Your Honor, all of these people are interconnected in a number of different
levels throughout this case. And the Court has been very good over the last number of
months as we've proceeded through this trial in being able to separate what's relevant
and what's not relevant and keep everybody on point, and on focus, and I think that we
can do that in this case as well. I mean, the fact is, is that she had a scripted interview
that she gave. And part of the incentive for that interview was the suggestion that she
would be able to have vis itation with her children. Yes, it is true that some years ago, she
gave up her parental rights. She had misgivings about doing that, particularly after this
Indictment came down. She went back to court and was successful at reversing that
decision. So her parental rights have been reinstated since then and now the litigat ion
that they're involved in is compelling visitat ion with these children. To that extent, the
children have been appointed counsel and that counsel has not yet had an opportunity to
visit with them, to my understanding. I don't see that that's an issue that would or
necessarily should come into evidence in this particular case, except to the extent that she
was promised visitat ion with her children if she did this video. That hasn't been given to
her and is something she wanted to have. She did want to see those kids. To that extent,
it's one more example of how this group of people used children as a pawn to compel not
just participat ion in these videos for Mr. Jackson's benefit, but an enthusiastic response as
well. Now, there will be obviously some level of questioning as to what's enthusiastic
within reason, what's enthusiastic outside of reason. We expect that. But that's part of the
give and take of the lit igation process. We think that we can control, with fair measure,
how far afield we go in terms of relat ionships between Schaffel and Ian Drew or any of the
other people who are involved in this case. And at some point in time, some of these

things become too collateral. And the Court has been very good at recognizing that and
putting the kibosh on it, and I expect that will happen in this case as well. I think that I've
mentioned in the pleading, and it's worth mentioning again, her part icipation in this video
was at the behest of Mr. Jackson personally. Init ially she was contacted by Mr. Konitzer,
one of the co-conspirators, but ultimately it was Mr. Jackson who made the init ial phone
call and brought her into this.
THE COURT: All right. I think we've argued every issue except the problem with the
foundation of documents of Marc Schaffel, the ones seized from his office. On those, it
seems to me that we have to sort of do admissibility on a case-by-case basis as the
documents come up as opposed to -- some of the offers are made without evidentiary -- I
mean, they're just that, they're offers without true evidentiary basis. I find it kind of hard
just to go through and make rulings on all of them in advance.
MR. AUCHINCLOSS: Well, our primary foundation will be laid with the officers who seized
those documents in Mr. Schaffel's home. And as I mentioned in our brief, I think that
authentication will be sufficient when the Court looks at each document and considers
where it was found. As to putting on separate foundations for each document, those
foundations are going to be primarily laid in terms of hearsay - certainly secondary
evid ence is really not an issue here of hearsay and relevance in light of the totality of the
circumstances of the case, which the Court has before it. And most of those arguments
will be -- will be handled in consideration of the evidence that is presently before the
Court as to how they specifically are relevant.
THE COURT: Well, my examp le would be Exhibit 401, you say Rudy Provencio will verify
the signature.
MR. AUCHINCLOSS: Yes.
THE COURT: Those are the kind of items that you say are going to happen.
MR. AUCHINCLOSS: And that's fair.
THE COURT: We don't know if they're going to happen.
MR. AUCHINCLOSS: But there really are only a couple of witnesses left that will testify
with any specificity about these documents. Mr. Provencio is one of them. So he's
certainly one person who's going to figure in on these foundations. So if you'd like -THE COURT: I understand the basic seizure issue that you're raising, but that's not the -you know, that just says they're seized legally. Now you have to prove the connection to
the case.
MR. AUCHINCLOSS: Except for -THE COURT: It seems to me that you're going to be able to do that, but I'm not going to
rule in advance based on your representation that that's going to happen, that they're all
admissible. It's like any other evidentiary issue. It's not till I hear the actual foundation
and I hear the witness that I make that ruling.
MR. AUCHINCLOSS: Yes. Well, I guess I'm just preparing the Court for the fact that we
have basically only -- I mean, the first foundation -- first foundational step is the one
which we -THE COURT: The seizure.
MR. AUCHINCLOSS: -- is the seizure. And we'll go from there and deal with it piecemeal, if
that's the Court's desires.
THE COURT: And that allows you to -- unless you want to address something separate
from that.
MR. SANGER: Let me just address a little more of a generic concern that I have, because
the way we saw this, and given the fact that the Court's of course very familiar with this

case by now, but Your Honor has not had a chance to see everything that we've seen.
Okay? So I just want to share with the Court, my belief is that if the prosecution is
allowed to start going down this road in front of the jury, that we're going to have a lot of
wasted time and we're going to have some potentially prejud icial material get in front of
the jury just to have the Court say there's no foundation. We understand that this stuff
was by and large seized -- maybe all of it in this segment 400 to 420, was seized by law
enforcement, in one form or another. We're now told that there was a disk of hard copies
as opposed to a disk of direct e-mails, but that was this morning. W e'll take a look at that.
But assuming for the moment that it was all seized from Mr. Schaffel's possessions
somewhere, do we go to the point where we start marking things? We have somebody like
Rudy Provencio giving a lot of testimony about his alleged connect ions with Mr. Schaffel,
which would otherwise be irrelevant, only to find out that -- and I think it's -- it would be
a fairly -- let's take a fairly easy ruling. There's a Pendaflex file label that -- as I
understand, it's a Pendaflex file label that says something like, Fires Burning. How in the
world could that be admissible unless -- it's not admissible. I mean, it just doesn't make
any sense that that would come in at all. That's hearsay. We don't know who made the file
label. The fact it's in Mr. Schaffel's possession in an office that he shared with a number of
people, so what? It just doesn't come in. But are we going to have testimony about that
and spend a lot of time? For the most part, and I think entirely really, these exhibits are
based on that kind of speculation. It's stuff found in Mr. Schaffel's files in an office which
the government knows was shared by a number of people during the relevant time period.
So there's no way to authenticate it. And Rudy Provencio is apparently the person they're
going to rely on. He's the person that volunteered to be an informant for the government,
and tape-recorded conversations ad nauseam with all sorts of people that meant nothing,
turned the tapes over to government. And one little thing they want to call him in here for
is really speculation that somehow these documents, which he's not going to say he saw
before, are probably legitimate because they came from Mr. Schaffel's stuff. And I think if
the Court has a chance to see that in the big picture, we save a lot of time by resolving it
now. If the government had one or two or three things that they thought did not come
within that category, then maybe we should hear that and we should focus on those. But I
see this is taking quite a bit of time for no apparent reason. That's why we tried to
address it up front. Thank you.
MR. AUCHINCLOSS: Just one final remark. This case, the conspiracy case, the evidence of
the conspiracy deals with words, just as in a drug case, the evidence in a drug case is the
drugs. You find the drugs in the home of the individual, those drugs come in as evidence
of the crime. In a conspiracy, we're dealing with communications between the parties,
with the knowledge that the individual p arties have, the relationships between the parties,
the various motives that may be pushing them forward through this conspiracy, and
evid ence of the criminal act itself. So that's where these documents come in. And I don't
think it's very genuine to say that we don't know whose documents these are. They're Mr.
Schaffel's documents, found in his personal files, found with all his other files in his home,
in his filing cabinet, in h is office, and in his locked closet. So there's no issue as to whose
records these are. And we've gone through the records and taken out the ones that are
relevant to this case showing the relationship between the parties, showing the evidence
of the conspiracy and the commun icat ions, and the criminal acts themselves, the Arvizos,
specific involvement with the Arvizos. So that's the nature of the relevance and where
we're head ed with all this evidence.
THE COURT: The attorney is not back yet on -- that was looking for the Harris case? Does

anyone -- I'd like someone to communicate with him and have him come back in.
MR. SANGER: We could ask -MR. SNEDDON: I'll take that responsibility, Your Honor.
MR. SANGER: We won't fight over that. I was going to offer. But that's all right.
MR. SNEDDON: Mr. Nico la has gone to get him, Your Honor.
MR. MESEREAU: Excuse me, Your Honor.
THE COURT: Yes.
MR. MESEREAU: We have found the citation, Your Honor, if the Court wants it.
THE COURT: Counsel?
MR. MOORE: Yes.
THE COURT: Did you find your case?
MR. MOORE: I did. If the Court would like the citation, it is 401 U.S. 222. Would you like
the lawyer's edition?
THE COURT: No, that's fine.
MR. MOORE: Thank you.
THE COURT: What's the -MR. MOORE: What the case says -- and I apologize, a rather quick read, Your Honor -but Ms. or Mr. Harris was not properly mirand ized, and ultimately the decision is that the
nonmirandized statements can't be used to convict, but they can be used to impeach. And
I think that's the holding in the case.
THE COURT: Well, that's the underlying case that caused me to -MR. MOORE: Yes, Your Honor.
THE COURT: -- raise the issue. But does the case go to the issue of immunity or is that
just the -MR. MOORE: It talks about Miranda.
THE COURT: Okay. That's -- all right. Thank you.
MR. MOORE: Anything further, Your Honor?
THE COURT: No.
MR. MOORE: Thank you. Does Your Honor want me to remain at counsel table, or -THE COURT: Just for a moment.
MR. MOORE: Thank you, Your Honor.
THE COURT: All right. The Court is going to grant the People's motion and grant the
request for use immunity as to Cynthia Montgomery. I do not know if I have the original
document for signing of the use immunity that you provided but.... Do you have that,
Lorna?
THE CLERK: No, I don't. Carrie has it.
MR. NICOLA: I believe Carrie has two copies, Your Honor. We'd request two original
copies so that I may serve the United States Attorney in Los Angeles with that, so they're
clear on that issue.
THE COURT: Okay.
MR. NICOLA: I believe defense counsel also wanted to delay her testimony. I didn't hear
the Court address that issue.
THE COURT: I don't think they did. They wanted to delay -MR. SANGER: Mr. Moslehi.
THE COURT: -- Mr. Moslehi's testimony.
MR. MESEREAU: Also Miss Montgomery's, Your Honor. I didn't know she was even an
issue. I didn't come here today prepared to examine her. If I could have a day -THE COURT: They can't hear you.

MR. MESEREAU: If I could have just a day, Your Honor, I'd be prepared to do her
tomorrow. I just didn't know it was even an issue.
THE COURT: They say they served you last week. They served me. Why didn't you -MR. MESEREAU: I -- Did you get it?
MR. SANGER: We got it Friday at the end of the day.
MR. MESEREAU: I was not notified of it.
MR. SANGER: I got it Friday at the end of the day. That's all I can say. And -THE COURT: So what witnesses are you prepared to go forward on?
MR. SNEDDON: We have Mr. Abdool here and ready to testify. He will be the first
witness, Your Honor.
THE COURT: How long will that be?
MR. SNEDDON: I'm expecting direct examination to be in the neighborhood of a half
hour, 40 minutes at the most. After that, we intended to call Mr. Moslehi, and then we
intended to call Cynthia Montgomery, and then we intended to put on the officers with
regard to the search of the Schaffel residence and the items that they took. And we felt
that would take the entire day and probably -- if probably not more than that, frankly,
given we knew that the Court was going to have to spend some time on rulings today. But
at this point, clearly we have one witness here ready to go, and that's Mr. Abdool. And
then the rest is contingent upon what -- the position that the Court takes on the defense
request. I should say we're also ready to go forward to get the officers here on the
Schaffel search. And we could do that during the time that Mr. Abdool's on the stand. We
were going to put them after the civilian witnesses, but we can get those people here,
Your Honor. So -- and we would, obviously, if you told us. So that would -- those are the
options available to the Court.
THE COURT: All right. Well, I think I will g ive the defense time that they have requested
on both the witnesses so that they can hear the tape and prepare their examinations. So
I'll have Cynthia Montgomery testify tomorrow -- I mean, I'll put off her testimony one
day, and the same with the other witness that you have the tape on.
MR. SNEDDON: Mr. Moslehi, Your Honor?
THE COURT: Mr. Moslehi. I'll put that off until tomorrow to give the defense time to
review that. So we'll go forward with Abdool and then the officers today.
MR. SNEDDON: All right. We'll get those officers in here, and -MR. MESEREAU: Thank you, Your Honor.
THE COURT: This is our -- Counsel?
MR. MOORE: I was just going to inquire, Your Honor. Ms. Montgomery is up from Los
Angeles and flew me up this morning. Can we get some sort of a time indication as to
tomorrow? Would it be first off?
THE COURT: What would be most convenient for you - since I'm putting it over till
tomorrow - to be first or later?
MS. MONTGOMERY: First thing tomorrow.
MR. MOORE: Most convenient would be to do it today, Your Honor. But not having that as
a choice, first up tomorrow would be -THE COURT: Can you accommodate him there?
MR. SNEDDON: I would say that's okay. We haven't checked with the other civilian
witness, but we can do that.
THE COURT: Well, if you can't, let him know.
MR. SNEDDON: I will. I will check at the
break. But as of right now, let's just assume that that is correct. We'll put her on first and

Mr. Moslehi second. Okay?

THE COURT: All right. This is the normal time for our break. We'll take our break, and
then we'll expect to have the jury in at....

KASSIM ABDOOL EXAMINATION

(The following proceedings were held in open court in the presence and hearing

THE COURT: (To the jury) Sorry to keep you all waiting back there, but we just had a lot
of legal issues to take up this morning, and because of that, I'm not sure, but the day may
be somewhat shortened. Do you expect us to go the entire day today, or -MR. SNEDDON: I would think -- I would think that would be probably not the case. But
you never know.
THE COURT: Okay. That's what I thought. You never know.
MR. SNEDDON: I'd hate to raise somebody's expectations and then have them looking at
me at 2:15 saying, W hy are we still here?
THE COURT: I understand. (To the jury) Some of the witnesses that were going to testify
today I put off until tomorrow, is basically what we're dealing with. And so they're calling
some witnesses that were going to appear later in the day, and we're not exactly sure how
much time it will take.
MR. SNEDDON: I will say this, Your Honor. I think we're going to have a full week,
though, from here on out.
THE COURT: Full week?
MR. SNEDDON: Yes, sir.
THE COURT: All right. Let me just -- so that -- before you start, let me just give you a
ruling on the motion on -- I'll call it the motion regarding Rowe. That motion is granted. I
will ad mit testimony in that case. I will look for ways to restrict the length of that
testimony. We'll talk about that later.
MR. SNEDDON: All right. That would be fine, Your Honor. Thank you. THE COURT: All
right. You may call your next witness.
MR. SNEDDON: Kassim Abdool.
18 Mr. Abdool, would you come forward, please.
THE COURT: When you get to the witness stand, please remain standing. Face the clerk
here and raise your right hand.

THE WITNESS: I do DIRECT EXAMINATION BY MR. SNEDDON:

Q. Mr. Abdool, I think you're going to have to scoot up as close as you possibly can to the
microphone so everybody can hear you.
A. That okay.
Q. Sounds a little better. You have a very soft voice, so try to keep it up. Thank you. Mr.
Abdool, you live in Lompoc; is that correct?
A. Yes, sir.
Q. And you're employed with the school district?
A. Yes, sir.
Q. And did you at one time used to work at Neverland Valley Ranch?
A. Yes, sir.
Q. And from what period of time did you work at Neverland Valley Ranch?
A. .91, .92, .93.
Q. Do you recall when in .91 you came to work there?
A. No. It may be about the middle of the year. I'm just guessing.
Q. And do you recall when in 1993 or .94 was it that you left?

A. It was part of .94. In the middle of .94.

Q. When you worked at Neverland Valley Ranch, what were your -- what was your
position there?
A. When I left or when I -Q. No, during the time that you were employed at Neverland Valley Ranch, what was your
position at the ranch? What were your job responsibilities?
A. To secure the ranch, to provide security for Mr. Jackson.
Q. So you were part of his security team?
A. Yes, sir.
Q. Did you have a rank at that point in time?
A. I started off as a basic security guard and I went up to the head of security.
Q. What were the range of responsibilities that you had at the ranch during the time, let's
say --let's narrow it down now to 1993 and 1994, okay?
A. Okay.
Q. Were you the head of security at that point in time?
A. Just part of .93, I think. Maybe a few months.
Q. What were your responsibilit ies during .93 and .94?
A. To supervise, make sure the buildings are locked. Make sure whatever Mr. J ackson
wants, to provide for him. Provide security for the guests.Sometimes they may need
luggages to their units. We'd help with that. Make sure no intruders come on property.
Those type of things.
Q. Now, what was the time -- during .93 and .94, what were the hours that you worked?
A. I think during most of my employment at the ranch, I worked the graveyard shift.
Almost for all those years.
Q. And graveyard shift means -- what time do you come on and what time do you leave,
generally?
A. Generally from about 10 p.m. to 6 a.m. I work most of the time that shift.
Q. Now, during the time that you worked at Neverland Valley Ranch, did you become
acquainted with an individual by the name of Ralph Chacon?
A. Yes.
Q. In what capacity? How did you get to know Mr. Chacon?
A. He was also a security officer at the ranch.
And he worked on the shift I worked on also.
Q. Did you know Mr. Chacon prior to the time that you came to work at Neverland Valley
Ranch?
A. No, sir.
Q. And since the time that you left the employment of Neverland -- well, let me save that
question for later, okay? W as Mr. Chacon, to your knowledge, employed at the ranch
during the same period of time that you were employed there?
A. Yes. I think he started working at the ranch maybe a couple of months after I started in
.91.
Q. And was he working there during .93 and .94?
A. Yes, sir.
Q. Part of .94?
A. Yes.
Q. During the time that you were employed in security for -- at Neverland Ranch, did you
get to know a young child by the name of Jordan?
A. Yes, sir.

Q. Did you know Jordan's last name?

A. Chandler.
Q. And did you see the child Jordan Chandler on the ranch on more than one occasion?
A. Yes, sir.
Q. And can you give us an idea approximately how many t imes you saw him on the
ranch?
A. He was there -- he was there for many times. I can't give a number of times.
Q. During the time that the child Jordan Chandler was on the ranch, was the defendant in
this case, Mr. Jackson, on the ranch?
A. Yes, sir.
Q. During the times that Mr. Jackson and the child Jordan Chandler were on the ranch,
were theChandler parents present on all occas ions?
A. No, sir.
Q. How many occasions do you believe that Jordan Chandler, to your knowledge, was on
the ranch with Mr. Jackson only?
A. Only?
Q. Yeah.
A. Maybe a couple times, I think. Two, three times. I'm talking about coming on the ranch
with Mr. Jackson alone.
Q. So arriving with Mr. Jackson -A. Yes.
Q. -- alone?
A. Yes, sir.
Q. During the time that you were on the ranch, could you describe -- well, when the child
Jordan Chandler was on the ranch, did you have an opportunity to see him on a number of
occasions?
A. Yes, sir.
Q. Could you describe his general behavior while he was on the ranch?
A. I don't think he ever spoke to me. He just kept, you know, a distance. I don't recall
ever speaking to him.
Q. All right. Did you have an opportunity to -- to observe how he acted on the ranch?
A. Well -MR. MESEREAU: Objection; vague.
THE COURT: Sustained.
Q. BY MR. SNEDDON: Did you have -- do you have carts on the ranch?
A. Golf carts?
Q. Golf carts.
A. Yes, sir.
Q. Did you have any problems with Mr. -- the child Chandler and the golf carts?
A. Yes. I remember one problem, yes.
Q. What was that?
A. I think he crashed it once.
Q. Were there any other occasions that you had problems with Mr. Chandler, the child
Chandler?
MR. MESEREAU: Objection; asked and answered.
THE WITNESS: No, I don't recall -THE COURT: Just a moment. Overruled. You may answer. Go ahead.
THE WITNESS: What's the question, sir?

MR. SNEDDON: Let me rephrase it.

Q. During the time that you had an opportunity to observe the child Jordan Chandler on
the ranch, how would you describe his behavior?
A. Kind of wild. Kind of wild behavior. You know, driving -- driving wild a little b it.
Q. Anything else?
A. He would keep to himself. He wou ld not associate with the security members or talk to
them.
Q. During the time that you were employed at Neverland Ranch, did you meet a child by
the name of Wade Robeson?
A. Yes, I know him.
Q. And during the time that you were at the ranch, did the child Wade Robeson visit the
ranch?
A. Yes, sir.
Q. And when he did, was Mr. Jackson on the ranch?
A. Yes, sir.
Q. And with regard to Mr. -- with regard to the child Wade Robeson, would you describe
his behavior?
A. Same type of behavior. You know, driving around wild, but they would not have
conversation with us.
Q. With regard to -- do you know a child by the name of Brett Barnes?
A. Yes, sir.
Q. Did the child Brett Barnes visit the ranch while you were there?
A. Yes, sir.
Q. On more than one occasion?
A. Yes, sir.
Q. And was Mr. Jackson there on those occasions?
A. I don't recall all the occasions, but I know that Mr. Jackson was there when Brett
Barnes was there, sir.
Q. Do you recall whether or not Brett Barnes' parents were always present when he was
on the ranch with Mr. Jackson?
A. No, I don't recall that, sir.
Q. With regard to your capacity as security for Mr. Jackson at the ranch, were you given
instructions with regard to how you were to interact with the children who misbehaved on
the ranch?
MR. MESEREAU: Objection; lead ing.
THE COURT: Just a moment. Overruled. You may answer.
THE WITNESS: I don't understand your question.
Q. BY MR. SNEDDON: Were there rules that were given to you as an employee at the
ranch in terms of what you were or were not to do when children misbehaved at the
ranch?
A. No, I don't recall rules.
Q. Were you given any -- can you tell us whether or not you were given any instructions
as to what to do when somebody did something?
MR. MESEREAU: Objection; vague.
Q. BY MR. SNEDDON: Did something wrong.
THE COURT: Rephrase the question.
MR. SNEDDON: All right. I'll start all over again.
Q. Were there any instructions given to you during the time that you worked at the ranch

as to what you were to do to try to control any children who got out of control at the
ranch?
A. I don't recall instructions. I don't recall any instructions, sir.
Q. During the time that you were at the ranch, do you recall an incident that involved you
and Mr. Chacon with regard to some French doors being left open?
A. Yes, sir.
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. You may answer -- he did answer, Yes. Go ahead.
Q. BY MR. SNEDDON: Now, with regard to that particular night - okay? - did you see Mr.
Jackson that night?
A. Yes, sir.
Q. Did you work the graveyard shift that night?
A. Yes, sir.
Q. Was Mr. Chacon working with you that night?
A. Yes, sir.
Q. And do you recall approximately when it was you saw Mr. Jackson for the first time on
that particular evening?
A. It would have been after 10:00, 10:15 or so.
Q. At some point that night did you see Mr. Jackson go to the Jacuzzi?
A. Yes, sir.
Q. And where is the Jacuzzi located?
A. The Jacuzzi's located outside the house, in the back of the house, near the swimming
pool area. There's a barbeque area, and a Jacuzzi and a swimming pool area, and an
arcade room on the other side.
Q. And when you saw Mr. Jackson going to the Jacuzzi area, was he alone or was he with
somebody?
A. No, he was with the boy.
Q. What boy?
A. Jordie.
Q. And could you see how they were dressed?
A. Yes, sir.
Q. How were they dressed?
A. They were dressed with bathing -- you know, bathing pants. But they were bare back.
And they had like bathing trunks. Pants that reached just above the knee.
Q. That went down to the knee?
A. Yeah, like loose-fitting pants.
Q. Do you recall where you were at the time that you saw Mr. Jackson and the child
Jordan going towards the Jacuzzi?
A. I was -Q. Where were you?
A. I was near the office area, somewhere closer to the back of the house.
Q. Now, at some point -- let me ask you this: At the time that you saw Mr. Jackson and
the child Jordan walking towards the Jacuzzi, did you know where Ralph Chacon was
situated or positioned?
A. I -- I had an idea where he was, but he was more in the barbeque area, I think.
Q. Was that his ordinary assignment?
A. Yeah. Normally they would go in that back area where no one could pretty much see
them.

Q. What were the lighting conditions like at this particular point in time at night out
around the swimming pool and the Jacuzzi?
A. It -- you know, like around the pool, yo have these pool lights. Around the Jacuzzi, you
have the Jacuzzi lights, and maybe some small lights in the flowers. I would say it would
be like d im lighting.
Q. Now, at some point later, did you hear Mr. Jackson say something to someone?
A. Yes. Mr. Jackson called me.
Q. And did you respond to him?
A. Yes, sir.
Q. As a result of what Mr. Jackson told you, did you do something?
A. Yes, sir.
Q. What did you do?
A. I went to the chef, his name is Bucky Black. Bucky.
Q. Okay.
A. I went to the chef. He was still on property that night, and I asked him to get two
sodas for Mr. Jackson.
Q. All right. Did you take the sodas to Mr. Jackson or -A. No, I did not take them.
Q. Now, later, when was the next time that you saw Mr. Jackson?
A. I saw Mr. Jackson going to the bathroom area.
Q. What bathroom area are you talking about?
A. It's -- it's a bathroom maybe that's kind of joined -- you know, joined onto the arcade
room.
Q. And when he was going to the bathroom area, was he alone or was he with someone?
A. I recollect he was with Jordie.
Q. And do you recall how they were dressed?
A. No. I don't recall exactly how they were dressed. My best recollection, they were in
bathing trunks, but to be specific, no.
Q. And did you see them actually go into the rest room area or were they just walking
towards that area?
A. I recall they were walking towards the rest room area.
Q. Now, at some point in time, did you see Mr. Jackson again later that evening?
A. Yes, sir.
Q. And where was he when you saw him?
A. He was near the back door of the main house. About -- about maybe five, eight yards
or so from the back door.
Q. And was he alone or was he with somebody?
A. He was with Jordie.
Q. And where was Mr. Jackson in relationship to Jordie? Where was Jordan?
A. He was like piggybacking. You know, piggyback, when you put someone on your back.
Q. Who was on whose back?
A. Jordie was on Mr. Jackson's back.
Q. Do you recall what Mr. Jackson was wearing, if anyth ing?
A. He was wearing -- he was bare back and he had a towel around his waist.
Q. And how about the child?
A. The child had like a towel-like robe, you know, like a bathrobe. Like, you know, it's
towel material. It was thrown over him, over the child.
Q. And where were they when you first saw them?

A. I'd say five, eight yards from the back door.

Q. Okay. And did you see where they went?
A. They went into the house.
Q. And did you see or hear anything at that point in time?
A. Yes, sir.
Q. What?
A. I heard the two locks on the back door, the screen door and the back door lock. You
know, clack, when someone close it.
Q. Now, was that -- anything unusual about that?
A. Yes, sir.
Q. What?
A. I never recall Mr. Jackson locking the house. We normally go and lock the house. We go
and lock the theater, lock the game room when he goes to bed.
Q. So that's your responsibility?
17 A. Yes.
Q. And you're familiar with how that door locks?
A. Yes.
Q. And that there's a double -- that there's a double lock there to secure it?
A. It's not a double -- from my -- from what I remember, it was two doors, like a screen
door and a solid door. And the two doors -- I heard the two doors, you know, lock.
Q. So it's not a double door -- double lock on one door. It's two doors that have separate
locks, as you recall?
A. I don't know it had a double lock. I can't remember. But I remember it was two doors.
That's my recollection.
Q. All right. And each had a lock?
A. Yeah.
Q. Okay. Now, what I'd like to know is, from the point that you saw Mr. Jackson -A. Yes, sir.
Q. -- walking towards the bathroom area that's attached to the arcade - okay? - with
Jordan, to the time that you saw him later with Jordan on his back, just before he entered
the door to the house - okay? - how much time had elapsed, approximately?
A. I would say maybe half an hour or so. Half an hour. That's an average. Could be a little
bit more. But I would say half an hour.
Q. Now, after you saw Mr. Jackson and the child enter the house, and the door was -- the
doors were locked - okay? - did you have an occasion where you went to the rest room
area that you had -- that's attached to the arcade?
A. Yes, sir.
Q. And why did you go there?
A. I was securing the arcade room and the rest room area, locking them up.
Q. And did you actually physically go into the rest room?
A. Yes, sir.
Q. And when you went into the rest room, what did you see?
A. The lights were on, as far as I recollect.
Q. Okay.
A. And it's -- the ground is like -- I don't think it's like concrete. It's like cobblestone, you
know, the blue cobblestone.
Q. Okay.
A. That's my recollection. And the ground was wet, and there were two bathing pants on

the ground close to each other.

Q. Now, were these the same trunks that you had seen Mr. Jackson and the child Jordan
Chandler wearing?
A. Yes. It seemed to be the same trunks.
Q. And could you explain to the jury, where were the trunks in relat ionship to each other?
A. The trunks were like maybe about this far apart.
Q. You're indicating about -A. About three -Q. -- a foot and a half, three feet?
A. They were this far apart. Two feet apart. Two, three feet. And they were near to -closer to the door area when you walk in.
Q. Close to the front door, the entrance door?
A. Yeah. That's what I recollect, yeah.
Q. Did you notice anything with regard to the floor?
A. Yeah, the floor was wet.
Q. Now, I think in the beg inning or earlier on in your testimony, you indicated that there
was an incident about the French doors being unlocked - okay? - that particular evening
where there was some French doors or some big doors that were unlocked?
A. Yeah, there were some doors unlocked in the house.
Q. Was this, again, part of your security routine, to check -A. Check and secure, yes.
Q. Where are these doors located in terms of, if you were to walk through these doors,
what room in the house would you be in?
A. If you walk -- if you were to walk through the ones that were open?
Q. Yes, sir.
A. You would come into a big living room area, and then there's a little corridor, and then
Mr.Jackson's bedroom is right there.
Q. And with regard to these particular doors, how -- could you describe them to the jury?
A. They're like -- you know, like tall doors. Not regular - what would I say? - rectangular
doors. They were like tall doors, like ten feet tall with an archway.
Q. Okay.
A. Huge doors. And they were -- so they had like bolts, you know, big bolts. I don't recall
them having locks, these doors -Q. Okay.
A. -- like the other doors that I found unlocked. And so you would probably have to climb
up and, you know, bolt these heavy copper bolts into the frame, and to bolt the bottom.
So each door --if you have two doors opening like that, each door would have two bolts.
One on top, one below.
Q. So you'd have to go inside the house to actually secure the house?
A. Yes, you have to go inside.
Q. And then you have to walk through of the house to get out of the house?
A. You have to walk through the house, yes.
Q. Was Mr. Chacon with you when you observed these to doors to be unlatched?
A. Yes, sir.
Q. And did you give Mr. Chacon some instructions with regard to what you wanted him to
do with these doors?
A. Yes, sir.
Q. What was that?

A. I told him that we were going inside to secure the doors. We need to go in and lock
them.
Q. And did he do that?
A. No, sir.
Q. Did you ask him on more than one occasion to do it?
A. I think a couple times, from what I remember, yeah.
Q. Did he say why he wouldn't do it?
A. He said he's not going in the house.
Q. Was that unusual for him to disobey an order from you?
A. Yeah. Yes, sir.
Q. Do you recall any other occasion where he ever d id that?
A. No.
Q. Now, with regard to the incident that you've just described for the ladies and
gentlemen - okay? - the one with Jordan, the child Jordan Chandler, and the Jacuzzi and
going into the arcade rest room - okay? -A. Okay.
Q. -- do you have an idea of approximately when that occurred?
A. That would have been somewhere in the middle of .93 or so.
Q. Was Mr. Jackson, to your knowledge, just returning from some trip?
A. Oh, yeah, he had returned from a trip overseas.
Q. Do you know where?
A. No. He was on a tour, I guess.
Q. Where?
A. He was singing overseas and he came back. He was over there for a long time.
Q. Okay. Now, on the ranch during the time 1993 - okay? -A. Okay.
Q. -- was there a thing called a Peter Pan display?
A. Yes, sir.
Q. And where was the Peter Pan -- I can't even say it. Where was the Peter Pan display
located?
A. It was in the back of the house outside Mr. Jackson's office. He had an office in the
back of the house.
Q. Okay.
A. You know, a -- how would I describe -- you have the main house. You have a
breezeway.
Q. Okay.
A. You have Mr. Jackson's office there. And then on the other side, you have the arcade
room, the swimming pool, the Jacuzzi, the barbeque area. So the display, I don't recall if
it was inside of the window or outside of the window, you know, but it was like on a short
-- like a -- when you look in the window, it was like a lighting display. But it's been so
long, I can't recall if it was inside of -- inside of the office or outside of the office.
Q. Now, on an occasion while you were working at Neverland Valley Ranch, did you see an
incident occur involving the defendant Michael Jackson and the child Jordan Chandler?
A. Yes, sir.
Q. And was this incident before or after the incident that you've described or the occasion
which you described finding the swimming trunks basically next to each other in the rest
room?
A. I don't recall, sir. I don't recall if it was before or after.

Q. All right. Now, on that particular day or on that particular occasion, did you see Mr.
Jackson and the child Jordan Chandler together before you saw them at the display? MR.
MESEREAU: Objection; leading. THE COURT: Overruled. You may answer. T HE W ITNESS:
I don't recall.
Q. BY MR. SNEDDON: Where were -A. Are you talking on this particular evening?
Q. Yes.
A. I don't recall if I saw them before I saw them at that time.
Q. Okay. And so, then, what would have been the first time you saw them?
A. It probably would have been when I came onto the night shift, so I would guess
approximately after 10:00. 11:00, 12:00.
Q. All right.
A. It was pretty late in the night.
Q. And when you saw them at the Peter -- did you see them at the Peter Pan display?
A. Yes, sir.
Q. Now, prior to them being at the Peter Pan display, d id you see where they came from?
A. Okay. Yes.
Q. Where did they come from?
A. They had come down from the hill area, probably from where the theater was, and they
drove down a small hill and drove in the back of the house. The back of the security area
there's a garage, and then swung around, and that's where the Peter Pan display is. So
they drove in the back of the house.
Q. You say they drove. What were they driving?
A. As far as I remember, it was a small golf cart.
Q. And were they both in the same cart or in different carts?
A. My recollection, they were in the same cart.
Q. Now, at the time that you saw them in front of the Peter Pan display, could you tell us
what you observed? First of all, let me ask you this: Let's --where was the child Jordan
Chandler in relationship to Michael Jackson? Where were they positioned?
A. Jordan was standing in front of Mr. Jackson, and Mr. Jackson was standing behind him.
You know, like if I'm standing here and someone is standing here, but we are both facing
the same direct ion. They were looking at the -- at the display.
Q. And what did you observe about Mr. Jackson's conduct in relat ionship to the child at
that time?
A. When I turned -- you know, I turned to walk away. I went to ask him a question. When
I turned to walk away, and on the side, I saw Mr. Jackson giving him a little kiss on the
side here, and he was kind of like hugging him. I just saw that maybe a couple seconds.
Q. And then you kept going?
A. Yeah, I kept going.
Q. You didn't watch what happened after that?
A. No.
Q. Now, was Mr. Chacon working that night?
A. Yes, sir.
Q. Now, in May of 1994, you were subpoenaed to appear before the Los Angeles grand
jury?
A. Yeah, okay. I think that's the time.
Q. You recall going down to Los Angeles?
A. Yes, sir.

Q. And you recall testifying in front of the grand jury?

A. Yes, sir.
Q. You recall receiving a subpoena before you were to go down there?
A. Yes, sir.
Q. And what was your attitude towards receiving the subpoena to go to the grand jury?
MR. MESEREAU: Objection. Vague; relevance. MR. SNEDDON: Goes to his bias, Your
Honor, his motive for testifying. THE COURT: Overruled. You may answer. THE WITNESS:
You want me to answer?
Q. BY MR. SNEDDON: Yes.
A. I didn't want to go.
Q. Now, prior to going down to Los Angeles to testify, did you have a meeting with
attorneys who represented Mr. Jackson?
A. Yes, sir.
Q. And who were those attorneys?
A. It was Mr. Steve Cochran, Mr. Jackson's attorney. It was also a private investigator.
Q. And do you recall where that meeting occurred?
A. Yes, sir.
Q. Where was that?
A. Mr. Bob Sanger's office in Santa Barbara.
Q. And at the time that you were at that meet ing, did the attorneys for Mr. Jackson offer
you certain services? MR. MESEREAU: Objection. Misstates the evidence. One attorney
was mentioned. MR. SNEDDON: Okay. I'll rephrase it if that's the problem.
Q. At the time that you met at Mr. Sanger's office with the private investigator and Mr.
Steve Cochran, did he offer you services?
A. I don't recall. But he gave me some advice.
Q. Well, did you have a lawyer representing you at that time?
A. No, sir.
Q. Did they offer to represent you? MR. MESEREAU: Objection; leading. THE COURT:
Overruled. You may answer. THE W ITNESS: He offered to be down with the grand jury if
we needed advice, attorney.
Q. BY MR. SNEDDON: Can you tell us --A. I think -- I vaguely remember now that -- I
think he remembered -- he offered, you know, to represent us, represent me.
Q. Do you recall whether or not you were ever offered any transportation down there?
MR. MESEREAU: Objection; lead ing. THE COURT: Overruled. 7 THE W ITNESS: Yes, sir.
Q. BY MR. SNEDDON: Were you?
A. Yes, sir.
Q. Did you ever use Mr. Steve Cochran's services?
A. No, sir.
Q. Were you asked what you were going to say in front of the grand jury by Mr. Cochran?
A. Yes, sir.
Q. Did you tell them?
A. I don't recall telling him, sir.
Q. Did you tell them what you were going to do?
A. I told him I was going to say what I know. I speak the truth.
Q. Now, between the time that you received the subpoena to appear before the Los
Angeles County Grand Jury and the time that you actually testified at the Los Angeles -before the Los Angeles County Grand Jury, did you receive a raise?
A. Yes, sir.

Q. And how much of a raise d id you receive?

A. About a thousand dollars a month more. Or maybe a little bit more than that.
Q. Was this a proposal that you had made to them? Had you requested the raise?
A. Yes, sir.
Q. And how long prior to the time that you went down to Los Angeles to testify had you
requested that raise?
A. A few months. Couple months, maybe. I'm guessing. I -- it was before.
Q. Now, after you testified in front of the Los Angeles County Grand Jury, did you receive
any threats? MR. MESEREAU: Objection. Leading; foundation. THE COURT: Overruled. You
may answer. THE WITNESS: Yes, sir.
Q. BY MR. SNEDDON: In what fashion? In what form did you receive threats? Mr.
Abdool, there's some water up there if you'd like some water. Take your time.
A. Yes, sir.
Q. What were the nature -- describe what threats you received.
A. People would call at home and threaten to kill me and my family. A lot of phone calls
coming to the house.
Q. Was there always somebody on the other end of the line when you picked the phone
up? MR. MESEREAU: Objection; leading. THE W ITNESS: They would stay on the line
sometimes. THE COURT: Overruled. You may answer. THE W ITNESS: They would stay on
the line sometimes, yes. Just stay on the line.
Q. BY MR. SNEDDON: Did you report these threats to law enforcement at the time that
they occurred?
A. Yes, sir.
Q. Mr. Abdool, do you know what the witness protection program is?
A. I know -- I heard about it. I don't know exactly what it entails.
Q. Did you ever request to be -- for you and your family to be put in the witness
protection
program? MR. MESEREAU: Objection. Leading; move to strike. THE COURT: Stricken. It's
leading.
Q. BY MR. SNEDDON: At any time did you ever request of law enforcement protection?
MR. MESEREAU: Same objection. THE COURT: Overruled.You may answer. T HE W ITNESS:
Yes, sir.
Q. BY MR. SNEDDON: And what did you request?
A. I requested to be put in that program, the witness protection program.
Q. Now, with regard to the -- with regard to the Neverland Valley Ranch, was there a
change in terms of additional security people who were brought onto the ranch during the
time that Mr. Jackson was under investigation back in 1993?
A. There was not a change. There was addition,some more people came on.
Q. And did you folks on the ranch have a name for those people, or was there a name that
was associated with them?
A. Yes, sir.
Q. What was that?
A. The OSS, Office of Special Services.
Q. Were they armed?
A. Yes, sir.
Q. Were you armed?
A. No, sir.
Q. The regular security staff was not?

A. No, sir.
Q. How would you describe the atmosphere at the ranch with these people who are armed
on the ranch?
A. It was very tense. I would say in the beginn ing -- you know, they were big people, and
they were armed. And I've seen them drink on property, so you'd be concerned about
your security on the ranch. I also heard them make threats to people on the ranch. MR.
MESEREAU: Objection. MR. SNEDDON: Well, that was going to be my next question. MR.
MESEREAU: Move to strike.
2 THE COURT: Stricken. Next question.
Q. BY MR. SNEDDON: Did you at any time ever hear them make threats to people on the
ranch? MR. MESEREAU: Objection. Hearsay; move to strike. THE COURT: Overruled. You
may answer. THE WITNESS: Yes, sir.
Q. BY MR. SNEDDON: And did they do that to you also?
A. Not directly, no.
Q. Okay. Did they do it indirectly or what you thought was indirect ly?
A. Yes, sir.
Q. In what fashion? MR. MESEREAU: Objection. MR. SNEDDON: Oops. Sorry. I'll wait. THE
COURT: You said, Objection. I didn't hear your -- MR. MESEREAU: Leading and calls for
speculation. THE COURT: Sustained.
Q. BY MR. SNEDDON: In what fashion? MR. MESEREAU: Same objection. THE COURT:
That was your last question. MR. SNEDDON: That --THE COURT: Really, you have to take
the last two questions to understand my ruling that you were lead ing. MR. SNEDDON: I
thought the first one was, but I didn't think the second would be, In what fashion? But I'll
start over, Judge. That's no problem.
Q. You indicated that you thought that you had been intimidated indirectly. Could you
describe for the jury in what fashion that occurred? MR. MESEREAU: Objection. Misstates
the evidence, lead ing, and foundation, and calls for speculation. THE COURT: I think what
I'm asking you to do is to go back and form a foundation for the question you're asking
before you ask in what fashion. MR. SNEDDON: Okay.
Q. Were you ever indirectly intimidated on the ranch? MR. MESEREAU: Objection.
Leading; foundation. THE COURT: Overruled. You may answer.
Q. BY MR. SNEDDON: You may answer. Were you ever indirectly intimidated on the
ranch?
A. Yes, sir.
Q. And do you remember who the person or persons were that were invo lved?
A. Yes, sir.
Q. Who were they?
A. On couple occasions it was one person, and at other times it would be two, three of
them, of the OSS officers.
Q. Could you describe in what manner you were indirectly intimidated by these people?
A. Are you saying things that they would say?
Q. You tell us. What was the nature of it? MR. MESEREAU: Objection. Foundation and
hearsay. THE COURT: Overruled. You may answer. THE WITNESS: I remember one of
them, his name was Van Norman. He would say how they would beat people when they
were overseas. You know, when they were on tour with Mr. Jackson, how they would beat
people, and he knew a hit man in Europe. And I remember once there was a fan at the
front gate and he came down and put his gun and pointed it at her head. She was outside
the gate. And also --MR. MESEREAU: Objection; narrative. THE COURT: Sustained.

Q. BY MR. SNEDDON: Was there any other indirect incidents directed directly at you?
A. Yes, sir.
Q. All right. What was that?
A. After I testified at the grand jury, when I'm sitting in my office, they would just pass
outside my office and just stare at me. They would not come in and talk to me. They
would just walk past outside the door.
Q. Are there occasions they displayed their firearms to you? MR. MESEREAU: Objection;
leading. THE COURT: Sustained.
Q. BY MR. SNEDDON: Let's move on to another subject, if we can. Were you involved in
a civil lawsuit against Mr. Jackson?
A. Yes, sir.
Q. And do you recall approximately when that lawsuit was filed?
A. .95, .96. Something around there.
Q. So this was at least a couple of years after your testimony, or at least one year after
your testimony before the Los Angeles County Grand Jury?
A. Yes.
Q. During the course of the time that you were involved in that lawsuit, did you give a
statement to the media?
A. Yes, sir.
Q. And describe how that came about.
A. I think it was in the attorney's office.
Q. The attorney?
A. Our attorney's office, yes.
Q. Who's that?
2 A. Mr. Ring.
Q. Okay. And that's where the interview occurred?
A. Yes, sir.
Q. And was it your idea to have the interview?
A. No, I don't think so. I don't recall that.
Q. Did you understand that as a result of the interview, that someone was going to pay
someone some money?
A. Yes, sir.
Q. Did you receive any of the money?
A. No, sir.
Q. Did you understand how that money was going to be used?
A. Yes, sir.
Q. For what purpose?
A. To carry on the civil case.
Q. Against Mr. Jackson?
A. Yes.
Q. And do you know who it was that set up that interview?
A. No, I don't recall.
Q. Now, one last question. Between the time that you received your subpoena to appear
before the Los Angeles County Grand Jury - okay? -A. Okay.
Q. -- and -- let me go back and start over again, okay? You received a subpoena to
appear before the Los Angeles County Grand Jury, correct?
A. Yes, sir.

Q. Now, between the time that you received that subpoena and the time that you actually
appeared before the grand jury to testify, okay?
A. Okay.
Q. We're talking about that time frame.
A. Yes.
Q. Did you have a conversation with Mr. Chacon, Ralph Chacon, about what he saw the
night that you found the swimming trunks side by side in the rest room?
A. Yes, sir.
Q. And did he tell you what he saw?
A. Yes, sir. MR. MESEREAU: Objection; hearsay. MR. SNEDDON: I haven't asked that yet.
I'm sorry, Your Honor. THE COURT: Overruled. MR. SNEDDON: Okay. No further
questions. THE COURT: Cross-examine? MR. MESEREAU: Yes, please, Your Honor.
CROSS-EXAMINATION BY MR. MESEREAU
Q. Good morning, Mr. Abdool.
A. Good morning, sir.
Q. My name is Thomas Mesereau. I speak for Mr. Jackson.
A. Okay.
Q. If anyth ing I ask you is unclear, if you don't understand it, please don't answer and just
ask me, and I'll try and rephrase it, okay?
A. Okay.
Q. Now, you told the prosecutor that on one occasion you met at Mr. Sanger's office in
Santa Barbara, correct?
A. Yes, sir.
Q. And you told the prosecutor that present were Attorney Steve Cochran, correct?
A. Yes, sir.
Q. And an investigator, right?
A. Yes, sir.
Q. And you told the prosecutor that in response to questions asked of you by Mr. Cochran
and the investigator, you said you would tell the truth,correct?
A. Yes, sir.
Q. In your discussions with them, you told the truth, correct?
A. I don't recall having discussions with them.
Q. Well, you met at the office, true?
A. Yes, sir.
Q. Approximately how long was the meet ing?
A. There were two meet ings that day.
Q. Do you know when these meetings took place?
A. A date are you talking about? I don't recall the date.
Q. Okay. Do you recall approximately when those meetings took place?
A. It was just within a week before going to the grand jury.
Q. And do you know approximately when you went to the grand jury?
A. It was a Monday.
Q. Was it in 1993, do you think?
A. .90 -- early .94 maybe.
Q. Would it be approximately May of 1994, do you think?
A. Okay.

Q. And you met with Mr. Cochran and the investigator at some point before you testified
before the Los Angeles County Grand Jury in May of 1994, right?
A. Yes, sir.
Q. How many meetings did you have with any representatives of Mr. Jackson before you
testified before the Los Angeles County Grand Jury in May of 1994?
A. Two meetings.
Q. Okay.
A. Three. Three meetings.
Q. And you told the truth -A. Yes.
Q. -- in all of your discussions at those meetings, correct?
A. Yes, sir.
Q. You told the truth about what you had observed at Neverland, right?
A. Yes, sir. MR. SNEDDON: I'm going to object, Your Honor. Assumes facts not in evidence
that he said anything to them. THE COURT: Sustained. MR. SNEDDON: Move to strike.
THE COURT: Stricken.
Q. BY MR. MESEREAU: In any of those three meetings, did you utter a word? MR.
SNEDDON: That's vague. THE COURT: Sustained. MR. SNEDDON: Object.
Q. BY MR. MESEREAU: In any of those three meetings, did you speak?
A. Yes, sir.
Q. Did you speak about what you had observed at Neverland?
A. I don't recall speaking about what I observed.
Q. Do you recall speaking about Mr. Jackson in those meetings?
A. No.
Q. Do you recall speaking about your employment at Neverland?
A. I don't recall, sir.
Q. Do you recall speaking about your background before you ever worked at Neverland?
A. I don't recall. I may have. I don't recall.
Q. Do you remember signing a statement, Mr. Abdool, in one of those meetings?
A. No, I don't recall that.
Q. Do you recall signing a statement on January 13th, 1994?
A. No, sir.
Q. Would it refresh your recollection if I show you -A. Sure.
Q. -- a statement? May I approach, Your Honor? THE COURT: Yes. MR. SNEDDON: Can I
see it first, Counsel? Okay. Thank you. MR. MESEREAU: Your Honor, it's a two-page
statement. Could I request that the witness just read it to himself? THE COURT: Yes. THE
WITNESS: Yeah, okay. MR. MESEREAU: There's another page, too.THE WITNESS: Yes.
Q. BY MR. MESEREAU: Mr. Abdool, have you had a chance to look at and read that
statement?
A. Yes, sir.
Q. Does it refresh your recollection about what you signed?
A. Yes, sir.
Q. And that is your signature on this statement, correct?
A. Yes, sir. Yes, sir.
Q. In fact, in the beginning of the statement, you corrected the spelling of your last name
in your own handwriting, correct?
A. Yes.

Q. You said you'd worked at Neverland Ranch

16 since June of 1991, correct?
A. Okay.
Q. Is that approximately when you started work?
A. Yes, sir.
Q. You said during your employment at the ranch, you worked in the security department
and that you were currently working as a shift supervisor, right?
A. Yes. MR. SNEDDON: Your Honor, I'm going to object to the use of the reading of the
statement into the record. It's hearsay and it's not used to refresh his recollection. THE
COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember sign ing a statement?
A. Yes, sir.
Q. Do you remember what you said in the statement? MR. SNEDDON: Well, vague as to -he stated it's two pages long, so it's --THE COURT: Do you mean outside of his having just
read it now, or what? MR. MESEREAU: Yes. Well --THE COURT: You gave it to him to
refresh his memory. MR. MESEREAU: Yes, I did.
Q. Does the statement you read refresh your recollection about the statement you
signed?
A. Yes, sir.
Q. Okay. And that is your signature on the statement, correct?
A. Yes, sir.
Q. You told representatives of Mr. Jackson that you'd never seen Mr. Jackson touch any
child in a sexual manner or in any way that could be construed
24 as sexual, correct?
A. That's what I wrote, yeah. I signed to that, yes.
Q. You said you'd never seen Mr. Jackson unclothed or in the company of unclothed
children, correct?
A. Yes. I mean, when I say unclothed, naked. If you have on pants, that's not unclothed.
Q. But you said you'd never seen Mr. Jackson unclothed or in the company of an
unclothed child, correct?
A. Yes.
Q. You said you'd seen Mr. Jackson play with children, right?
A. Yes, sir.
Q. You said he plays as if he's a child himself, correct?
A. Yes. MR. SNEDDON: I'm going to object to reading the document into -- it's hearsay.
THE COURT: Sustained. MR. MESEREAU: Cross-examinat ion --impeachment, Your Honor.
THE COURT: Well --MR. MESEREAU: I believe on cross-examination --THE COURT: Some
is and some isn't. You're reading the whole thing, so you're not being ver discerning in
your impeachment. MR. MESEREAU: Well, I'm not going to read the whole thing. THE
COURT: There was certain questions that he was asked that you can do that with. You're
reading a lot more into it. You'd have to lay the foundation for each remark.
Q. BY MR. MESEREAU: Okay. Do you remember sign ing a statement that discussed what
you'd seen of Jordie Chandler at Neverland?
A. I remember signing a statement. I believe that statement that I signed was not at Mr. - when I met with the attorneys. That was a statement that was prepared by the
investigator in his handwriting. Yes, I did sign it.
Q. And you also corrected the statement before you signed it, true?
A. My name, I corrected it, yes.

Q. You said you'd never seen Mr. Jackson engage in anything sexual with Jordie Chandler,
correct?
A. Yes.
Q. And you said that no one working at the ranch had ever complained about Mr. Jackson
doing anything sexual with children, correct?
A. Right. No, that was before I went to the grand jury, before I think, before I met with
Mr. -- in Mr. Sanger's office.
Q. The date was January 13th, 1994, right?
A. Right.
Q. Okay.
A. So that was about -- months before I think I went to the grand jury.
Q. You said you were the father of two children.
A. Yes, sir.
Q. That you had no problem leaving them alone with Mr. Jackson, correct? MR. SNEDDON:
I'm going to object to the question. It's hearsay. It's an improper use of the document.
THE COURT: Sustained.
Q. BY MR. MESEREAU: At any time did you ever tell any representative of Mr. Jackson
that you are the father of two children, ages 9 and 13, and you would have no problem
leaving them alone with Mr. Jackson? MR. SNEDDON: Same objection, Your Honor. THE
COURT: Overruled. THE WITNESS: I probably did. I have no reason to say no.
Q. BY MR. MESEREAU: Would it refresh your recollection if I just show you that portion
of it?
A. If it's there, it's there, yeah. MR. MESEREAU: May I approach, Your Honor? THE
COURT: Yes.THE WITNESS: Right. Okay. Yeah, I signed to that.
Q. BY MR. MESEREAU: You've had a chance to look at that document?
A. Yeah, I've looked at it, sir.
Q. And you did make that statement, that you were the father of two children, 9 and 13,
and they had both visited the ranch, right?
A. I signed it, the statement. It's not my writing. It's -- I didn't write that statement.
Q. But you signed it?
A. Yes.
Q. After correcting it, correct?
A. I corrected my spelling of my name. I didn't sign -- I didn't write that statement, sir.
That's not my writ ing.
Q. Does your signature appear on both pages of that statement?
A. Yes, that's my signature. I signed that document.
Q. Okay. Now, the prosecutor alluded to a lawsuit that you and Ralph Chacon and Adrian
McManus and others filed against Michael Jackson, correct?
A. Yes, sir.
Q. In that lawsuit, you also sued the security guards that you called the OSS, right?
A. Yes, sir.
Q. And one of the security guards you sued was James Van Norman, right?
A. Yes, sir.
Q. He's the fella you just testified to threatening you, correct?
A. Yes.
Q. Okay. And that was the longest civil trial in the history of this courthouse in Santa
Maria,
California, right?

A. I don't know.
Q. It was a six-month trial, approximately, was it not?
A. Yes, sir.
Q. And at the conclusion of that trial, Mr. Jackson prevailed, right?
A. Yes, sir.
Q. And you ended up with a judgment against you for $1,473,117.61, correct?
A. I don't know the figure, but that sounds correct.
Q. Would it refresh your recollection if I just show you the judgment?
A. It's fine. I accept it.
Q. All right. And the security guards that you sued also prevailed -A. Yes.
Q. -- in that lawsuit, correct?
A. Yes, sir.
Q. And it's your understanding that Mr. Jackson won the case, was awarded costs, and
was awarded all of his attorney's fees against you, correct?
A. Yes, sir.
Q. All right. Did you ever pay him any of that
27 money?
A. No, sir.
Q. Do you know approximately when you filed that case?
A. I think maybe .95, 1995. I'm not sure.
Q. Would it refresh your recollection if I just show you the Complaint? It has a date of
December 2nd, 1994. Does that sound correct?
A. Okay.
Q. You sued Mr. Jackson for many different claims, correct?
A. Yes, sir.
Q. You sued him for emotional d istress, correct? Right?
A. If it says that. I don't recall all the comp laints.
Q. Well, you said you'd been intimidated during your employment, right?
A. Yes, sir.
Q. And you testified in the case, correct?
A. Yes, sir.
Q. And you testified that you had suffered emotional distress and various medical
problems because of the way you were treated at Neverland, true?
A. Yes, sir.
Q. And your attorney was a gentleman named Mr. Ring, correct?
A. That's correct.
Q. When did you first go to Mr. Ring to talk about suing Mr. Jackson and the security
people of the ranch?
A. It would be after I -- we stopped work at the ranch. That's my recollection.
Q. And approximately when was that?
A. I don't recall, sir.
Q. Do you know the year you left your employment?
A. .94.
Q. Okay. Do you remember being discip lined while you were working at Neverland for
stealing Mr. Jackson's gasoline?
A. For stealing Mr. Jackson's gasoline?
Q. Yes.

A. No, first time I -- no.

Q. You were counseled by a security chief named Mr. Wegner, spelled W -e-g-n-e-r,
correct?
A. That's his -- yeah, that's the correct spelling.
Q. Do you remember being discip lined because you had filled your car up with Mr.
Jackson's gasoline?
A. Mr. Jack -- where would I get his gasoline from to fill my car up? No.
Q. Would it refresh your recollection to show you that disciplinary report?
A. Sure. Yeah. MR. MESEREAU: May I approach? HE COURT: Yes.THE WITNESS: Okay.
Yeah.
Q. BY MR. MESEREAU: Have you had a chance to look at that disciplinary report?
A. Yes.
Q. Does it refresh your recollection about that issue?
A. Right. I remember that, yeah.
Q. Okay. A report was filed to that effect, correct?
A. Right. Right.
Q. That you had improperly filled your own vehicle with Mr. Jackson's gasoline.
A. No, not improperly fill my vehicle. I used my vehicle to go to -- I think to Solvang to
run an errand, and I -- it was replaced for me, the three gallons of gasoline.
Q. Okay.
A. I remember that, yeah. I did not steal the man's gasoline. And that's why I refused to
sign it, because I was having problem with the chief at that time.
Q. You were counseled on the violation, true?
A. Yes. I told you I went -- I used my vehicle and -- and -Q. You were told a violation would be part of your permanent record of employment at
Neverland, true?
A. I don't recall. Probably.
Q. Okay. There are gasoline pumps on the ranch, true?
A. Yes, sir.
Q. Okay. Staff, particularly security staff, are not supposed to be filling their own vehicles
with Mr. Jackson's gasoline, correct? MR. SNEDDON: I'm going to object as
argumentative. THE COURT: Sustained. It's a foundational sustaining.
Q. BY MR. MESEREAU: Did you know the policy on whether or not security staff are
supposed to use Mr. Jackson's gasoline for their own personal use?
A. I don't know if there's a policy, but of course you can't use his gasoline for your
personal use. And as I said, sir, I d id not use it for my personal use.
Q. You're not supposed to fill your tank with it, correct?
A. I didn't fill my tank. I put, what, three gallons of gasoline. I vaguely remember that,
yes,
that happened.
Q. All right.
A. I'm not denying it.
Q. Were you ever disciplined on any other occasion that you recall?
A. I don't recall.
Q. Okay. Do you know one way or another whether you were disciplined on any other
occasion?
A. I don't recall. That one he told me, it even surprised me. I had forgotten about it. It
was a non issue as far as I was concerned.

Q. Now, you claimed in your lawsuit that you had been disabled because of what
happened to you at Neverland, true?
A. Disabled -- emotionally disabled, yes.
Q. Yes. And you obtained a number of what are called d isability certificates from a
physician because of your disability, correct?
A. Yes, sir.
Q. And did you apply for state disability; do you know?
A. What is state disability? I -Q. Well, there are various ways to file for disability, correct?
A. Well, like unemployment?
Q. Or disability. You claimed that you could not work because of all the emotional
problems you had resulting from your work at Neverland, correct?
A. Yes, sir. MR. SNEDDON: Your Honor, excuse me, I'm going to object that the question
is vague as to whether he's talking about -- I don't want to go any further, but it's vague
as to what point in time or what document he's referring to. MR. MESEREAU: I'm not
referring to a document, Your Honor. MR. SNEDDON: Well, then it's vague. MR.
MESEREAU: I'll rephrase.
Q. It was your position when you filed the lawsuit against Mr. Jackson and the security
guards that you should get millions of dollars because you had been emotionally disabled,
correct?
A. Yes, sir.
Q. You claimed you were so distraught and depressed that you couldn't work, true?
A. Yes, sir.
Q. And you were actually examined by physicians in that regard, true?
A. Yes, sir.
Q. And at one point an insurance company refused to pay you any benefits because they
said you weren't disabled, right? MR. SNEDDON: Your Honor, I'm going to object. It's
hearsay. THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you remember T IG Insurance concluding that you, Mr.
Abdool, are not medically disabled? MR. SNEDDON: Your Honor, I'm going to object and
I'm going to ask the Court to admonish counsel. That's the same question, and he just
asked it with a new start to it. THE COURT: The objection is sustained. MR. MESEREAU:
Okay.
Q. The jury in your civil suit completely rejected your claims that you were emotionally or
medically damaged by anything at Neverland, true?
A. Yes, that's correct.
Q. And you never got the millions you were seeking, correct?
A. That's correct, sir.
Q. Do you know approximately when that suit ended?
A. I know it was five, six months. I don't have the date, no.
Q. Now, as head of security at Neverland, you were concerned about media people coming
on the property, true?
A. Yes, sir.
Q. And one of your jobs was to try and keep med ia people away from Mr. Jackson, right?
A. Keep anybody away from -- from the property, any intruders.
Q. But you were particularly concerned about tabloid-type people, correct?
A. I would say generally anyone, any type of intruder.
Q. But weren't you particularly concerned about media attempts to get to Mr. Jackson?

MR. SNEDDON: Object; asked and answered. THE COURT: Overruled. You may answer.
THE WITNESS: I -- we were concerned -- I was concerned with any intruder on the
property.
Q. BY MR. MESEREAU: Okay. And would that include the media?
A. Yes, sir.
Q. Would that include people who write for tabloids?
A. Yes, sir.
Q. And was it your understanding that Mr.Jackson was very concerned about his privacy
when it came to the media? MR. SNEDDON: L ack of foundation; object. THE COURT:
Overruled. You may answer. THE W ITNESS: Yes, sir.
Q. BY MR. MESEREAU: Were you still emp loyed at Neverland when you first spoke to
representatives of the media about Mr. Jackson?
A. No, sir.
Q. How long after you left your employment did you talk to representatives of the media
about Mr. Jackson?
A. I don't recall, sir.
Q. You talked to somebody named Gary from an organization called Splash, correct?
A. Right.
Q. And it was your understanding that you would be quoted in a tabloid called The Star,
right?
A. It wasn't me. It was the attorney's office.
Q. But your understanding was that you were going to be quoted in an article in a tabloid
called The Star, right?
A. Okay, yes.
Q. And you were interviewed along with Ralph Chacon, correct?
A. Yes.
Q. You were interviewed with Adrian McManus, correct?
A. Yes, sir.
Q. How many meetings did you have with that tabloid?
A. I think it was just one meeting.
Q. Okay. Do you know what they paid for the interview?
A. No, sir.
Q. Did you ever hear they paid $15,000 for that interview?
22 A. I probably did. I don't recall that
23 exactly.
24 Q. And what you chose to do was rather than not
25 put the money in your pocket, you chose to use it to
26 fund your lawsuit against Mr. Jackson where you
27 wanted to get millions, right?
www.mjfacts.info28 A. Yes, sir. 7433
www.mjfacts.info1 Q. Obviously, it turned out to be a poor
2 investment, right?
3 MR. SNEDDON: Objection, Your Honor.
4 Argumentative.
5 THE COURT: Sustained.
6 Q. BY MR. MESEREAU: Does July 31st, 1994,
7 sound like the approximate t ime you stopped working
8 at Neverland?

9 A. Yes.
10 Q. Okay. How long after you stopped working do
11 you think you and Chacon and McManus got together
12 and met with the attorney about filing a lawsuit?
13 MR. SNEDDON: Object; assumes facts not in
14 evidence.
15 MR. MESEREAU: I'll rephrase it.
16 Q. Did you and Ralph Chacon and Adrian McManus
17 at some point get together and decide to jointly
18 file a lawsuit against Mr. Jackson?
A. I don't recall Adrian McManus. I recall Melanie Bagnall.
Q. Do you know who Adrian McManus is?
A. Yeah, she -- she probably came on at some time after we spoke. That's my
recollection.
Q. And all of you sued the private security people that you called the OSS, right?
A. Yes, sir.
Q. And you all claim that these people had terrorized you and caused damages to you
A. Yes, sir.
Q. And that claim, again, was rejected completely by the jury, right?
A. Yes, sir.
Q. Who were the other people that you claim were causing severe d istress to you and
Ralph Chacon and the others who joined in your lawsuit? MR. SNEDDON: Your Honor, I'm
going to object to the question as compound with regard to other people. THE COURT: I'm
not sure what you meant, Counsel. MR. MESEREAU: I'll rephrase.
Q. You testified earlier that one of the things you were concerned about was private
security guards of Mr. Jackson consuming alcohol, correct?
A. One of them I saw drinking alcohol.
Q. One individual?
A. Yes.
Q. Okay. And who was that?
A. Van Norman.
Q. Okay. And you also complained about someone carrying a firearm, correct?
A. I -- I don't recall specifically. I probably did.
Q. Well, you testified that you saw somebody point a firearm at a fan, correct?
A. Yes. Yes.
Q. And who was that?
A. Van Norman. That's my recollection.
Q. Now, you never comp lained to Mr. Jackson about Mr. Van Norman carrying a firearm,
true?
A. No. Never.
Q. And you never complained to Mr. Jackson about Mr. Van Norman drinking alcohol,
correct?
A. Never. No.
Q. And you never complained to Mr. Jackson about any of these private security guards
threatening anyone, right?
A. That's correct.
Q. And, in fact, you never complained to Mr. Jackson about any of them doing anything
wrong at any time, true?

A. True.
Q. Did you, if you remember, sign a confidentiality agreement when you went to work at
Neverland?
A. Yes, I think I recall -- I think I d id one, yeah.
Q. And was it your belief that as a condition of your working at Neverland, that you were
not supposed to take information about Mr. Jackson's life and exploit it in the media?
A. That's correct, sir.
Q. Yet, when you left your employment, that's exactly what you did, correct?
A. Yes, sir.
Q. Did you and Ralph Chacon discuss what tabloid you were going to sell a story to?
A. I don't recall, no.
Q. Did you ever get together with Adrian McManus and discuss what information you and
she were going to sell to a tabloid about Mr. Jackson?
A. Oh, I don't think so. I think we just gave an interview and she spoke and I think I
probably spoke, too.
Q. Did you learn that any of the information you sold had actually been printed about Mr.
Jackson?
A. Yes.
Q. And how did you learn that?
A. I recall -- I think I saw the tabloid. I think I saw it, yeah.
Q. Now, you actually hired a guy named Gary to be an agent to get more tabloid
opportunities, correct?
A. Yes, we -- we used him as a broker or something like that.
Q. Yeah, he was a broker to go to various tabloids around the world to see if he could sell
stories, correct?
A. Yes, sir.
Q. Now, to your knowledge, did Gary get a commission from whatever he brought in; do
A. No.
Q. But you did this with the approval of your attorney, right?
A. I wouldn't use approval. But he explained to us that we needed the money. So if you
say
approval, yes.
Q. And part of the reason for doing all this was to put pressure on Mr. Jackson to settle
that case and give you people money, right?
A. No. I don't think so, no. We needed the money. We had no money to go ahead with the
case.
Q. The plan was to do what you could to make Mr. Jackson want to get rid of this case,
right? MR. SNEDDON: Object as asked and answered, Your Honor. THE COURT:
Sustained.
Q. BY MR. MESEREAU: And you actually had your photograph taken by Gary, true?
A. I don't recall. But probably, yeah.
Q. And the purpose of the photograph was to have that photograph appear in tabloids,
right?
A. Yes, sir.
Q. Now, did you and the other plaintiffs in that civil case have a nickname that you used
for yourselves?
A. No, I don't think so. I don't recall that.
Q. Well, did you ever call yourselves The Neverland 5 or something like that?

A. No.
Q. Did you ever see an art icle with a name like that?
A. I've heard that, yeah.
Q. But that's not a nickname you people were using yourselves, correct?
A. No, I didn't give myself that name.
Q. Okay. You also gave interviews about Mr. Jackson in front of this courthouse, true? MR.
SNEDDON: Your Honor, I'm going to object as vague as to when in time. MR. MESEREAU:
I'll rephrase it, Your Honor.
Q. Around the time you were pursuing your civil lawsuit against Mr. Jackson, you had to
come to this courthouse from time to time, right?
A. Yes. Yes, sir.
Q. And you did give some interviews to reporters at this courthouse, right?
A. I vaguely remember I think I spoke to reporters outside, yes.
Q. Okay. And do you remember meeting with your broker in a lawyer's conference room
in this
courthouse?
A. No, I don't recall that.
Q. Do you remember meeting with Gary in a lawyer's conference room here when your
photograph was taken?
A. No, I -- I would think that the photograph was taken in our attorney's office in Santa
Barbara.
Q. Okay.
A. It may have. I don't recall, but I would think it was Santa Barbara.
Q. Would it refresh your recollection if I just show you a -A. No, it's fine.
Q. -- a page of your deposition?
A. It's fine. If I said it, I said it, yeah.
Q. You remember your deposition being taken in that case, true?
A. Yes.
Q. In fact, there are volumes of that deposition, right?
A. What I'm saying is, if it's there, then that's correct, but I couldn't recall.
Q. Now, the plan init ially when you hired the broker named Gary was to put together a
fund of money to pay costs in the lit igation, correct?
A. Yes, sir.
Q. And to your knowledge, that's what your lawyer spent that money on, right?
A. Yes, sir.
Q. Okay. Do you remember what you were interviewed about by the tabloids?
A. No, it's been a long time. I don't recall.
Q. Do you remember being interviewed about Mr. Jackson's relationship with Lisa Marie
Presley?
A. Specifically me, I don't recall that, no.
Q. Do you recall being there when Chacon and McManus were talking about that?
A. I don't --MR. SNEDDON: Object as immaterial, Your Honor. THE COURT: Overruled.
You may answer. THE W ITNESS: I don't specifically recall exactly what questions and
answers were given, no. It's been over 13 years. I don't recall. But, yeah, there was an
interview.
Q. BY MR. MESEREAU: Was Gary at the interview?
A. Yes.

Q. Okay. Who else was there, if you remember?

A. I think Melanie Bagnall, Ralph Chacon, myself, Adrian McManus. I'm not sure about
SandyDomz. I'm not sure.
Q. Okay.
A. I don't recall anymore.
Q. And do you remember you were quoted in an article ent itled, K inky Sex Secrets of
Michael and Lisa Marie's Bedroom?
A. I don't recall being quoted in that article. But if it's there, the article -- it may not be
me
saying it, but if it's there, if it's quoted there, it's quoted there.
Q. Would it refresh your recollection if I just show you the title? MR. SNEDDON: Your
Honor, I'm going to object. It's immaterial. He stated he didn't have anything to do with
it. Lack of foundation. It's hearsay. THE COURT: Well, I will let him refresh his recollection
with it, but we'll take a break first. MR. MESEREAU: All right. (Recess taken.) THE COURT:
Counsel? MR. MESEREAU: Thank you, Your Honor.
Q. Mr. Abdool, you described for the prosecutor what you say you observed of Mr.
Jackson's behavior with Jordie Chandler, right?
A. Yes, sir.
Q. Now, when you saw what you've described, you did not automatically call any police
officer, correct?
A. That's correct.
Q. And you were a former police officer yourself, correct?
A. Yes, sir.
Q. You had been a police officer in -- was it Trinid ad?
A. Yes, sir.
Q. How long were you a police officer in Trinidad?
A. Three, four years or so.
Q. Okay. And you were trained to use fire arms,et cetera, correct?
A. Yes, sir.
Q. And at one point you carried a concealed weapon, right?
A. Yes, sir.
Q. Were you carrying a concealed weapon during the time you worked at Neverland?
A. No, sir.
Q. Approximately when do you recall seeing Mr. Jackson with Jordie Chandler? Can you
tell me approximately when you say you saw this? MR. SNEDDON: Your Honor, I'm going
to object as to which occasion. Vague. THE COURT: Sustained.
Q. BY MR. MESEREAU: Let's take the first occasion you described - okay? - dealing with
the Jacuzzi, all right?
A. Uh-huh.
Q. Approximately when do you think you saw that?
A. I can't give an exact date, but I recollect when he came back from overseas. So it
would have been probably around the middle of .93 or so.
Q. Okay.
A. I'm just guessing. I -Q. And you described another incident.
A. Yes.
Q. The prosecutor asked you about the Peter Pan statue, right?
A. Yes.

Q. And approximately when do you think that happened?

A. I don't recall, but it would be in that time frame, you know, maybe after. I don't recall.
Q. Okay. This is sometime in .93, do you think?
A. .92, .93, yes. It's difficult for me to give you a date.
Q. Now, are you familiar with a -- an event at Neverland called Family Day?
A. Yes.
Q. And what is Family Day at Neverland?
A. Family Day is when the emp loyees are invited to bring their family.
Q. And you participated in Family Day with your family, correct?
A. Yes. On maybe two, three occasions, yeah.
Q. You participated on Family Day at Neverland with your family in 1994, didn't you?
A. I don't -- I think it was Appreciation Day. Employee Appreciat ion Day it was called.
Q. Okay. And you brought your family to Neverland in 1994 to participate in that,
correct?
A. Yes. Yes, sir.
Q. This was after the events you claim you saw that you have just described?
A. Yes, sir.
Q. Do you know someone named Sandy Domz?
A. Yes, sir.
Q. Who is Sandy Domz?
A. Sandy Domz used to work at the ranch administration office.
Q. And did you work with her?
A. I worked on the ranch, but not with her.
Q. Was she working at the ranch while you were working at the ranch?
A. Yes, sir.
Q. Okay. And you and Sandy Domz met with a T.V. show called Inside Edition, did you
not?
A. It's possible, yeah.
Q. Do you remember doing that?
A. I know we gave interviews. Maybe televis ion, yes. It's been about 13 years.
Q. I'm sorry?
A. It's difficult to remember.
Q. She was the spokesperson for a group, that included you, that gave various interviews,
right?
A. I don't recall, but that's probably correct, yeah. I'm not going to deny that.
Q. And one of them was with the T.V. show Inside Edition, right? MR. SNEDDON: Your
Honor, I'm going to object to the question. It calls for lack of foundation that he was -that he was involved. MR. MESEREAU: Your Honor, he said he was invo lved. MR.
SNEDDON: Well --THE COURT: Overruled. You may answer. Do you want the last question
read back? THE WITNESS: Yes, please. (Record read.) THE WITNESS: What I'm saying is,
if that's a fact, yes, I don't deny it. But I don't recall specifically Inside Edition or who. But
I'm saying -Q. BY MR. MESEREAU: You recall various T.V. shows, correct?
A. T.V. shows or T.V. show, or newspapers or newspaper, I don't -- yes. But I gave
interviews or interview, yeah.
Q. And you and Sandy Domz split some of that money, right?
A. What's the word? Sweat?
Q. You and Sandy Domz split some of the money that you got from television, did you

not?
A. No, sir.
Q. Did it all go to the attorney fund?
A. As far as I know.
Q. But Sandy Domz was not -- excuse me. Did Sandy Domz arrange these meetings or did
they all go through Gary, to your knowledge?
A. I don't recall.
Q. Okay. All right. Do you remember meet ing for several days with a book author named
Gutierrez?
A. I met once with him. Not several. Just once.
Q. It was a long meeting, was it not?
A. Probably, yeah. Two, three hours.
Q. Now, these meetings with various representatives of the media, were they going on
during the lawsuit?
A. I don't recall the specific one, but -- I gave interviews during the lawsuit, yes. I don't
deny that.
Q. While you were doing this in 1994, you knew that security guards at the Jackson family
home in Encino had gotten $100,000 for selling stories, correct?
A. No, I don't recall that.
Q. You never discussed that with your cohorts?
A. No. I may have. I don't recall. I don't recall that one, no.
Q. Okay. You've ind icated you never spoke a word with Jordie Chandler, right?
A. Yeah. I mean, I may have said -- you know, he asked for something, but conversationwise, I don't recall having any conversation with him.
Q. Did you ever see his mother at Neverland?
A. Yes.
Q. Did you see her on a number of occasions?
A. Yes, she's been there on a few occasions, yes.
Q. You said you worked with Ralph Chacon, correct?
A. Yes.
Q. And how long did you work with Ralph Chacon?
A. I worked most of my time at the ranch on the graveyard shift. Ralph Chacon may have
worked a substantial time, too, graveyard shift. But he was on another shift, also.
Q. Was he a friend of yours?
A. Yeah, we got along pretty good. I would say a friend, yeah.
Q. You mentioned someone named Brett Barnes, right?
A. Yes, sir.
Q. Did you ever see relat ives of Brett Barnes at Neverland?
A. I don't recall. Maybe -Q. Do you recall his mother?
A. -- maybe yes; maybe no. I don't recall.
Q. Do you recall ever seeing his sister?
A. No, I don't recall.
Q. Okay.
A. I may have.
Q. Now, you indicated that you didn't know if there were any rules should a child get out
of line, or wild, or anything like that. You said there were no rules that you were supposed
to follow?

A. I recall there were no procedure if a child -- I don't recall anything like that.
Q. Well -A. Of course, if they're doing something really bad, you know, you have to stop that, but Q. Well, you said Jordie Chandler crashed a golf cart at one point, right?
A. Yeah, I remember he hit the golf cart at one -Q. Did you take care of him?
A. I think there was an accident report written. That's what I -- vaguely.
Q. Well, what did you consider your responsibilit ies as head of security to be?
A. To provide security for Mr. Jackson and his guests, you know, the property and so on.
Make sure that intruders don't come on the property. That type of thing.
Q. Now, the prosecutor asked you if you had been head of security, right?
A. Yes, sir.
Q. And you answered yes, right?
A. Yes. For the last part of my employment, yes.
Q. And how long a part of your employment were you head of security?
A. Maybe three months. Three months, four months.
Q. Three months?
A. Yeah.
Q. So that would be the last three months that you worked in 1994, right?
A. Yeah.
Q. Okay. So you became head of security long after you claim you saw Mr. Jackson act
this way with Mr. Chandler, correct?
A. That's correct.
Q. And before you were head of security, what was your position?
A. I was a sergeant, supervisor of the -- of a shift.
Q. Now, you said that the Jacuzzi is located outside the house, right?
A. The one I'm talking about. Maybe there's one inside. I don't know.
Q. But there's one outside the house?
A. Yes, sir.
Q. Is that in the back of the house?
A. It's in the back of the house.
Q. Okay. And what else do you see near the Jacuzzi in the back of the house?
A. There's the Jacuzzi. There is a large swimming pool. On the other side, there is a huge
barbeque area with a roof, but it's not, you know, boarded, no sides.
Q. That Jacuzzi is in open view, right? It's not hidden by anything?
A. There's some little shrubs in that area. But it's not hidden, no.
Q. Yeah. It's a pretty open area, isn't it?
A. Pretty much, yes.
Q. And guards who are walking around Neverland or driving, can see it, correct?
A. No. If you're driving, you probably cannot see it.
Q. But if you're walking around, you can?
A. Well, how can I answer you? W e were told not to go near Mr. Jackson and his guests,
so we would not walk where he was.
Q. There are hills above, correct?
A. Yes.
Q. You could actually look down, can't you?
A. If you look down with binoculars or so, you could probably see.

Q. And there are offices on the hill, true?

A. Not in that area, no.
Q. Which area are you talking about when you say a hill?
A. You said Jacuzzi?
Q. Yes.
A. In relation to the Jacuzzi, if you go way down, maybe 2-, 300 yards, in that area, there
is the administration office, the gardeners.
Q. Right.
A. But they cannot see the Jacuzzi area.
Q. They can see the pool area, can't they?
A. No.
Q. Can't see it at all, even if they look?
A. Even if they look. Because the arcad e and the trees in that area are going to be
blocking that area.
Q. The pool area is a pretty wide open area, isn't it?
A. Yeah, but there's a big building blocking it. You can't see through.
Q. But guards do walk around, do they not?
A. Yes, when -- but not when we have guests and stuff. They don't want us walking
around when they're swimming.
Q. Okay. But you stay there when guests are there because you're supposed to protect
the guests, true?
A. Generally if guests are around there, you don't stay close where -- you know, to watch
them. You would stay maybe like in the breezeway or in a dark area. But you don't -- you
know, you don't go close to the guests.
Q. But part of your responsibility was to make sure that guests are properly treated,
true?
A. Yes, but we were instructed not to have close contact with Mr. Jackson or his guests, to
keep away, g ive them distance.
Q. Well, to observe what you say you observed, you would have had to get close to Mr.
Jackson, true?
A. Are you talking about the Peter Pan display?
Q. Talking about the Jacuzzi.
A. Yeah. W ell, he called me for a couple of drinks, for a couple of sodas.
Q. Right.
A. I was walking and he says, Security, security. So I went to him, and he said, Can you
bring two sodas? And I spoke to the chef about it.
Q. Obviously, Mr. Jackson didn't seem to be afraid to have you see what he was doing.
A. I did not go near him. I was a distance when he asked me for the sodas.
Q. He called you, right?
A. He called me, that's correct.
Q. Okay. Now, typically how many hours would you work on a shift?
A. How many -- pardon me?
Q. How many hours would you work on a shift?
A. Areas?
Q. No, hours, time.
A. Hours. Eight hours. Maybe a little bit more if it's needed, if we're short.
Q. And at the time that you say Mr. Jackson locked his house, what shift were you
working?

A. The night shift, the graveyard shift. I think it was from like 10:00 to 6:00 in the
morning.
Q. 10:00 to 6:00 in the morning?
A. Yes.
Q. Now, how often did you work that graveyard shift?
A. I worked that graveyard shift, I'm just estimating, pretty much all my employment. I
would say 75, 80 percent of my emp loyment.
Q. And do you recall ever seeing Mr. Jackson outside in the evening?
A. Yes, sir.
Q. Did you ever see Mr. Jackson walking late at night?
A. Yes, sir.
Q. Ever see Mr. Jackson driving late at night?
A. Yes, sir.
Q. And you would sometimes see Mr. Jackson at 3:00 in the morning, correct?
A. Yes, sir.
Q. Because Mr. Jackson's known to be by himself sometimes at 3:00 in the morning,
right?
A. I don't recall seeing him by himself three o'clock in the morning.
Q. He would take walks or he would drive, correct?
A. I don't recall him by himself at three o'clock in the morning.
Q. But you've seen him late at night on his property, true?
A. Not alone, but with guests.
Q. Have you seen him late at night on his property?
A. That's correct.
Q. Have you ever seen him driving on his property alone late at night?
A. No, I don't recall. But I really don't recall Mr. Jackson driving alone.
Q. And you've seen him with guests late at night, right?
A. Yes, sir.
Q. 3:00 in the morning was not unusual at times, right?
A. I would say not unusual. That would be unusual. Hardly ever. Maybe all my
employment I've seen him outside that time maybe two or three times or so.
Q. And, sir, he has gone back into his house late at night and locked it, hasn't he?
A. That evening, that night? Before?
Q. He has done that at various times when he goes out late at night, hasn't he?
A. I don't recall that, sir.
Q. Okay.
A. He may have, but I don't recall.
Q. But you didn't check every time he went out late at night to see if he locked the door
when he went back into the house?
A. Yes, you have to check. You have to check the whole property to make sure the
property is secured.
Q. But he routinely locks that door when he comes back in the wee hours of the morning,
sir?
A. No. No, sir, I'm telling you.
Q. Okay.
A. I know that is a fact.
Q. So when he brings guests back into his house at 3:00 or 4:00 in the morning, he never
locks it, is what you're saying.

A. Mr. Jackson doesn't lock the property, even his house. We walk around and lock the
house.
Q. Sir, you didn't check every time he went back into his house late at night to see if it
was locked? MR. SNEDDON: I'm going to object as argumentative and asked and
answered. MR. MESEREAU: All right. THE COURT: Sustained.
Q. BY MR. MESEREAU: Now, where is the Peter Pan display in relation to the house?
A. If you have the -- you have the house, the main house -Q. Yes.
A. -- there's a breezeway. On like a b ig archway, there's Mr. Jackson's office. So the
Peter
Pan display would be if you're driving to the back of the house, and you come around to
the side of Mr. Jackson's office -Q. Uh-huh.
A. -- the Peter Pan display, as far as I can recall, would be on that window. So it would be
to the back of the house. Would be 10, 15 yards or so.
Q. Okay. Now, you indicated you had requested a raise several months before you got
one, right?
A. That's what I recollect, yeah.
Q. And you had requested a raise to a Mr. Bray, correct?
A. I remember requesting a raise to the administration. I'm not sure if it's directly to Mr.
Bray, you know, but to the head of Mr. Jackson's company. I knew he had put Mr. Bray in
there.
Q. I'm sorry. You had complained that you were very underpaid, true?
A. Well, I said I should be paid the amount that the last chief of security was being paid.
That's what I recollect.
Q. Right. And didn't you also complain that others were getting paid more than they
should, like the private security guards? A. I don't recollect that. I recall telling them that
some officers were working for more money than some, and they should come up to be
equal. So the new officers were making more money than the old officers we hired on. I
think it's fair that they should get the same amount of money.
Q. Did you put the request in writing?
A. I recall so, yes. I vaguely recall that.
Q. And were you interviewed about that request?
A. By Mr. Bray, yes.
Q. Okay. Now, people in your security group did not like Mr. Jackson's private security
people, did they?
A. I can't speak for everybody. But in the beginning, I got along with them in the
beginning.
Q. But didn't a lot of tension develop between the two groups?
A. Yeah. It developed as time went on, yes.
Q. And your group would not travel with Mr. Jackson, right?
A. No. We were just security for the ranch.
Q. The other group would travel with him when he went on tour, right?
A. That's correct. That's my understanding.
Q. They would travel with him to various cities, correct?
A. That's my understanding, yes.
Q. And when they returned -- excuse me. When Mr. Jackson returned, they would come
with him, right?

A. No, that's the first time they came on property.

Q. Well, sometimes one or two would travel on a flight with him, correct?
A. I don't know. I've never been on a flight with him. But I'm talking about Neverland
Valley Ranch.
Q. Right.
A. When Mr. Jackson came back in .93 or .94, that's the first time I've seen any one of his
OSS officers there.
Q. But he had security people in the past when he went on tours, throughout his life,
providing security for him?
A. That's my understanding, yes.
Q. Okay. And he's had security problems his whole career because he's so famous, right?
A. Yes, I know that.
Q. Now, you said Van Norman pointed a gun at a fan; is that true?
A. Yes.
Q. Did you watch that?
A. Yes. He, like, put -- like through the gate.
Q. And you were upset with that?
A. I was frightened, you know.
Q. And never made a complaint to anybody?
A. No. Who can you complain to?
Q. Well, you're a former police officer. You could call the local police, couldn't you?
A. Yes, I could have. But in the conditions there, you can't talk. When you're in that ring
of
that employment, you don't talk.
Q. Where were you living at that time?
A. Lompoc.
Q. On one of your trips back or forth to Lompoc, you could have called a police officer,
correct?
A. That's correct.
Q. Now, do you remember in your civil trial a tape was produced that you claim had some
threats on it?
A. I vaguely remember. I remember there was a tape, yes.
Q. And it turned out to be a tape involving your son and some music. Do you remember
that?
A. Could be, yeah.
Q. There was no threat at all, correct?
A. Probably, yeah. I don't recall, but it's fine. MR. MESEREAU: Okay. No further questions,
Your Honor.
REDIRECT EXAMINATION BY MR. SNEDDON:
Q. Mr. Abdool, with regard to those occasions where you saw Mr. Jackson out at night at 3
a.m.,was he with little boys on any of those occasions?
A. Yes, sir.
Q. Mr. Mesereau asked you why you didn't complain to Mr. Jackson about certain events
that were happening on the ranch with regard to these OSS individuals. Do you recall
those series of questions?
A. Yes, sir.

Q. Why did you not complain to Mr. Jackson about that?

A. I felt they were more like attached to him, because he'd be talking with them and they
would go meet him personally and talk to him. So I was -- I
was scared to, you know, go to him and complain about the people who were close to
him.
Q. Now, Mr. -- Mr. Mesereau asked you about this gasoline incident.
A. Yeah.
Q. And do you remember he showed you the form, it was December of .93?
A. Yeah. Okay.
Q. And was it after that point, after this incident where you wouldn't sign for having done
anything wrong, that you became -- they promoted you to head of security?
A. Yes, sir. May I explain about the gasoline?
Q. Pardon?
A. May I explain about the gasoline?
Q. If you'd like to.
A. Yeah. W hat happened, I remember going to work that evening, and I had very little gas
in my car. And I ran an errand, you know, to somewhere in Solvang with my personal car.
And when I came back, I put three gallons of gasoline to -- you know, for whatever I
used, because I had very little gas to go home after. And I told Mr. Wegner about it. I told
him about it. I told him I took three gallons of gas. I didn't hide it. And, you know, we had
-- in the ending, we had -- our relationship was not good.
Q. But in any case, after that incident they still promoted you?
A. To head of security, yes.
Q. Okay. Now, with regard to some timing issues here, were you still employed at the
ranch at the time that you testified before the Los Angeles County Grand Jury?
A. Yes, sir.
Q. Mr. Mesereau asked you a lot of questions about interviews that you gave and your
participation in a jo int interview with some -- with a magaz ine.
A. Yes, sir.
Q. Did you ever say anything during those interviews that you said that was untrue?
A. I don't recall the interviews. It's hard --it's 13 years ago. It's hard for me to recall what
I said or what was -- what I was quoted as saying.
Q. Well, I'm not interested in what you were quoted, because we all know how we can be
misquoted. But with regard to what you have said, would you have said anything that was
untrue?
A. No, no. MR. MESEREAU: Objection. Calls for speculation THE COURT: Sustained.
Q. BY MR. SNEDDON: Do you have a reco llection of ever saying anything to any of those
people, interviews, that was untrue?
A. No. MR. MESEREAU: Objection. THE WITNESS: I --MR. MESEREAU: Objection.
Relevance; foundation; calls for speculation. THE COURT: Overruled. You may answer.
Q. BY MR. SNEDDON: That means you can answer.
A. Can you say the question again?
THE COURT: He said, No, so -- MR. SNEDDON: So just leave the answer in, Your Honor?
That's fine.
Q. And lastly, since this case has been in the news - okay? - the present case -A. The .9 -Q. This case.
A. Okay.

Q. The current case against Mr. Jackson.

A. Yes, sir.
Q. And before you were subpoenaed to testify in this case, were you approached by
members of the press to give interviews?
A. Within the last year and a half, yes.
Q. And were you offered substantial amounts of money to do that? MR. MESEREAU:
Objection. Leading; foundation. THE COURT: Overruled. You may answer. THE W ITNESS:
People have not talked money figure. They have come to my house. They have called me
at work. They want to do interviews. They want to write books. Many reporters in the last
year and a half have approached me.
Q. BY MR. SNEDDON: Have you talked to any of them?
A. I pretty much chase them away. I tell them, I don't want to talk about it. I don't want
to get involved in this.
Q. And you're here today because you were subpoenaed to come, correct?
A. Yes, sir. MR. SNEDDON: Nothing further.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Mr. Abdool, you're subject to a gag order in this case, correct?
A. That's correct.
Q. You're not allowed to talk to the media, right?
A. That's correct.
Q. You were informed of the gag order by the prosecution, correct?
A. Yeah. About two, three months ago, yes.
Q. Well -A. I'm talking about before that.
Q. Well, even before that, you knew that you were a potential witness in the case, didn't
you?
A. Yes.
Q. When did you first talk to any prosecutor about your testifying in the case?
A. Mr. Sneddon called me about three weeks ago, I think.
Q. Did you ever talk to any sheriff about this case?
A. No. No.
Q. Never g ave interviews at all?
A. Yes, I talked to sheriffs long ago. 12, 13 years ago, I think.
Q. Okay.
A. But recently, no. Mr. Sneddon called me about three weeks ago. That's the first contact
I had with the sheriffs.
Q. Did he tell you there was a gag order on the case?
A. The officer that serve me -Q. Yes.
A. -- the subpoena at my house told me there was a gag order. MR. MESEREAU: Okay. No
further questions. MR. SNEDDON: Nothing further, Your Honor. THE COURT: All right.
Thank you. You may step down.

JEFF KLAPAKIS EXAMINATION

DIRECT EXAMINATION BY MR. AUCHINCLOSS:

Q. Good afternoon, Lieutenant Klapakis.
A. Good afternoon.
Q. You've previously testified that you were assigned to the case of People v. Michael
Jackson as the lead investigator?
A. I was the lieutenant in charge of the case, yes.
Q. All right. And I think where I left off questioning you, I asked you if, in the month of
January, 2004, you served a search warrant on the home of Frederic Marc Schaffel?
A. Yes, I did.
Q. And what day was that?
A. I believe it was January 31st, .04.
Q. Who was with you when you served that warrant?
A. I had several of my detect ives, John McCammon, Craig Bonner, Vic Alvarez, Sergeant
Robel. They arrived at differing times. I believe Sergeant Robel was doing something else
and he arrived shortly thereafter. Paul Zelis.
Q. And were you directed by the Court to seize certain documents pursuant to that search
warrant?
A. Yes. MR. SANGER: I'm going to object to the Court directing him. He was permitted by
the Court to do that. MR. AUCHINCLOSS: It was an order is what it is. THE COURT: Well,
you're both right. Next question. MR. AUCHINCLOSS: All right. Thank you. If I may
approach, Your Honor. THE COURT: Yes.
Q. BY MR. AUCHINCLOSS: Lieutenant Klapakis, I show you a notebook that is marked
as original exhibits 400 to 420, F. Marc Schaffel files. Under the Tab 400, there appears to
be a single page that says -- entitled, Work Agreement with Neverland Valley
Entertainment. Can you identify that document for me, please?
A. Yes, this is a document we found pursuant to that search warrant at Schaffel's house,
and it's a work agreement between Michael Jackson --MR. SANGER: Objection, Your
Honor. That's nonresponsive. Motion to strike. THE COURT: Stricken.
Q. BY MR. AUCHINCLOSS: And this document is noted as Exhibit 400 on the first page;
is that correct?
A. Yes.
Q. Where was this document seized from?
A. It was found in a master bedroom closet in Mr. Schaffel's house.
Q. Okay. Was there any box or file cabinet, anyth ing of that nature that you located that
file in?
A. No, I believe it was loose in the closet.
Q. And now I show you Exhibit 401. It appears to be a four-page document; has Exhibit
Tab 401 on the front page, and there appears to be a fax sheet on the front of that to
Tom Byrne.
A. Yes.
Q. Can you identify that document for me, please?
A. Yes. This is a document I found in a locked closet within a guest bedroom of Mr.
Schaffel's house. And it was in a filing cab inet.
Q. Okay. Was there anybody living in that guest bedroom?
A. No. MR. SANGER: Calls for speculation. THE COURT: Sustained. MR. SANGER: Move to
strike the answer. THE COURT: Stricken.
Q. BY MR. AUCHINCLOSS: All right. Did you see anybody else's personal belongings in

that room?
A. No.
Q. And you said that the closet was locked.Tell me about that.
A. It was -- I believe it was a deadbolt lock on a closet in that bedroom.
Q. How did you get into the closet?
A. One of my detectives is familiar with how to pick locks, and he picked the lock.
Q. And tell me about the filing cabinet that it was seized from.
A. There were, I believe, seven filing cab inets in this closet. And I believe it was in the
sixth
filing cabinet, one of the drawers.
Q. And can you identify for me the nature of documents that were found in those filing
cabinets along with this document?
A. Yes. MR. SANGER: I'm going to object. Calls for hearsay. MR. AUCHINCLOSS: I'm
asking for a generality. MR. SANGER: Then it's vague. THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Were you able to determine the identity of the individual
whose documents were in those cabinets based upon the totality of everything that you
searched? And maybe I'll back away from that and ask, first of all, did you have occasion
to peruse the contents of those various file cabinets?
A. Yes.
Q. And was there any indicia of ownership located in those file cabinets? MR. SANGER:
Objection. Calls for speculat ion. THE COURT: Calls for a conclusion. Sustained.
Q. BY MR. AUCHINCLOSS: Was there anybody's name associated with the documents in
those file cabinets?
A. Yes. MR. SANGER: Objection. Vague; calls for speculation; lack of foundation. THE
COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did you have any indication that those file cabinets belonged
to anybody other than the owner of that home? MR. SANGER: Objection, Your Honor. This
calls for speculation. There's a lack of foundation proven. It's an opinion or conclusion.
THE COURT: Well, I'll sustain the objection. MR. AUCHINCLOSS: All right.
Q. Did you know if -- could you tell, based upon your -- well, let me strike that. Did you
do a walk-through of that house?
A. Yes.
Q. Did you locate any other occupants?
A. No.
Q. Any occupants whatsoever?
A. The house was vacant. Not vacant, but nobody was there. Unoccupied. Excuse me. MR.
AUCHINCLOSS: Thank you. I have no further questions. MR. SANGER: I'll let you take
your stuff. May I proceed, Your Honor? THE COURT: Yes.
CROSS-EXAMINATION BY MR. SANGER:
Q. Okay. Now, first of all, you said something in response to a question about a search
warrant. Your office applied for a search warrant, correct?
A. Several.
Q. Okay. We're talking about this particular case.
A. Then yes.
Q. And what date was the search warrant applied for?
A. I believe it was applied for on the same date.

Q. What date was that?

A. I believe it was January 31st, .04.
Q. And at that time, when you applied for the warrant, you understood you were asking
the Court's permission to search a private area, right?
A. A residential home.
Q. Which would be a private -- otherwise a private area, correct?
A. Yes.
Q. All right. And that is not -- you were not -- let me withdraw that. It was not your
understanding that any court, on its own volition, told you you ought to go search this
area; is that right? MR. AUCHINCLOSS: Objection. Calls for a legal conclusion. THE
COURT: The objection is overruled. You may answer. THE WITNESS: I'm not quite sure I - could you repeat the question? MR. SANGER: Okay. Could we ask it be read back? THE
COURT: All right. (Record read.) THE W ITNESS: If I understand your question correctly,
did the Court ask us to go do this? The answer is no.
Q. BY MR. SANGER: All right. As part of law enforcement, you decide where you want to
go, you ask permission, and you either get it or you don't when you ask for a warrant,
correct?
A. Yes. That's an easy way to say it, sure.
Q. All right. Now, when you searched the --these premises, approximately how many
documentswere ultimately booked into evidence?
A. Do you want a guesstimate?
Q. Your best estimate, yes.
A. Hundreds.
Q. Thousands?
A. It's very possible there were thousands.
Q. Now, you're the lieutenant in charge of this investigat ion, correct?
A. Yes.
Q. And therefore, your -- part of your responsibility is to know what is booked into
evid ence, correct?
A. That's pretty vague. I mean, it's -- I'm not going to know everything that -- on every
document that goes in, no. The answer would be no.
Q. But you have a general idea of how many documents were seized in January, correct?
A. Generally? And I said hundreds, possibly a thousand.
Q. Hundred, possibly a thousand?
A. Yes.
Q. Were any other documents seized from Mr. Schaffel on any other occasions?
A. Yes.
Q. And how many documents were seized?
A. No, actually we seized -- I'm not sure we seized documents, but we seized computers
on a different occasion.
Q. All right. And when was that?
A. I believe it was a few days afterwards. But again, I'm not sure. I wasn't present during
that search.
Q. And your understanding, as the lieutenant in charge of this investigation, that the
computers contained tens of thousands of documents? MR. AUCHINCLOSS: Objection.
Beyond the scope, and relevance. THE COURT: Sustained.
Q. BY MR. SANGER: Okay. Now, based on your role as the lieutenant in charge of this
investigat ion, were you aware from your investigation that Mr. Schaffel had employed

other people?
A. I'm aware that he worked with other people, yes. Whether they were employed by him,
that -Q. Were you aware from your investigat ion that other people had been given office space
within Mr. Schaffel's house? MR. AUCHINCLOSS: Objection. Foundation; hearsay. THE
COURT: Overruled. You may answer. THE W ITNESS: I'm aware that Mr. Schaffel also used
his home as an office at times.
Q. BY MR. SANGER: And he had other people working for him there in his house?
A. I believe that they did work out of his home at times, yes. MR. SANGER: There you go.
Thank you. No further questions. MR. AUCHINCLOSS: I have no further questions. THE
COURT: You may step down. THE W ITNESS: Thank you. MR. AUCHINCLOSS: Call
Detective Craig Bonner as our next witness.THE COURT: When you get to the witness
stand, you may be seated. You're still under oath.

CRAIG BONNER

DIRECT EXAMINATION BY MR. AUCHINCLOSS:

Q. Before I begin asking you about some files regarding a search warrant, I'm going to

cover a couple of other items.

Pursuant to your -- you previously testified you're a detective in the People v. Jackson
case, correct?
A. That's correct.
Q. And pursuant to your investigation, were you asked to compare a sheriff's office item
number, a tape, Item No. 817, with a Court Exhibit No. 827? This would be a phone call
that has been admitted into evidence referred to as the Frank/Janet phone call.
A. That's correct.
Q. Did you compare those items as to their similarity or identical -- the identical
informat ion on those two -- I shouldn't say documents. I believe they're two tapes, right?
Or CDs?
A. That's correct. Well, the original is a tape. The exhib it is a CD.
Q. Okay. So the S.O. No. 817 is a tape that was seized pursuant to this case?
A. That's correct.
Q. And you compared that with the Court CD, Item No. 827?
A. That's correct.
Q. Are they one and the same, as far as the --as far as the voices and informat ion that's
on those two audio medias?
A. Yes, they are.
Q. Same question for Sheriff's Office Item No. 818, and Court Exhibit No. 828, which is
the Miller interview of the Arvizo family. Did you compare those two items?
A. Yes, I did.
Q. Again, was 818 a tape?
A. Yes, it was.
Q. 828 is a CD?
A. Yes.
Q. And they're one and the same in terms of the information that's on them?
A. Yes, they are.
Q. Okay. (Off-the-record discussion held at counsel table.) MR. SANGER: Could we have
just a moment, Your Honor, please? MR. AUCHINCLOSS: I need an exhibit number.
Q. Detective, pursuant to your duties in this case, were you asked to do a photographic
documentation of grand jury exhibits?
A. Yes, I was.
Q. And what was the nature of that task?
A. On July 20th, I went to the Superior Court in Santa Barbara where the exhibits that
were lodged into the court from the grand jury proceedings were being held. I then
photographed certain exhibits at that location, including every page of magazines that
were booked in. MR. AUCHINCLOSS: Okay. And if I might approach again, Your Honor.
THE COURT: Yes.
Q. BY MR. AUCHINCLOSS: Detective, I show you a envelope with Exhibit 53, GJ Pics
written on the outside. It appears to contain a document with Item 317 on the top. It is
held together by a green paper clip and there's three pages to it. And then there appear to
be a number of photographs that are following that, along with photographs of the
contents of Exhibit 470 face page. Can you identify that for me?
A. Yes, I can.
Q. What is it? MR. SANGER: Well, there's one problem. I think I missed the court exhibit
number for what is being shown the witness. MR. AUCHINCLOSS: Exhibit 843.
Q. All right. Can you please identify that for me, Detective?

A. Yes, I can. When I went to the court, specifically one of the items that I photographed
the contents of was Item 317, the black briefcase. That's also the Grand Jury Exhibit No.
53. I did that with a digital camera. All of those photographs were downloaded onto a CD.
These pictures are the printed photographs that I took of the materials. This document
corresponds to these pictures and tells the reader which picture corresponds to which
item, and to what the current exhibit number is for this trial. In addit ion to that, I also
went in and I handwrote in the sheriff's department item number for each p icture. MR.
AUCHINCLOSS: Okay. Ask to admit Exhibit No. 843 at this time, Your Honor. MR.
SANGER: I'm going to object to it. Number one, it contains some extraneous materia l,
other than the photographs of the grand jury exhibits. Number two, that it's cumulative.
These pages of these magazines have already been markes and shown to the jury
countless times in d ifferent contexts or for different reasons. This being yet another set,
it's cumulat ive. MR. AUCHINCLOSS: And I'm willing to make an offer as to the specific
reason for this, if you wish. THE COURT: Okay. MR. AUCHINCLOSS: Shall we do it at
sidebar? THE COURT: All right. (Discussion held off the record at sidebar.) THE COURT: All
right. Based on the offer of proof, I'll admit it. MR. AUCHINCLOSS: All right. If I could
have the Elmo, please.
Q. All right. So what was the date that you conducted this photo essay of evidence? MR.
SANGER: Asked and answered, and photo essay is vague and ambiguous. THE COURT:
Sustained.
Q. BY MR. AUCHINCLOSS: When did you do these photographs?
A. July 20th.
Q. All right. All of them were taken on that day?
A. Yes.
Q. And I show you the first page of the three-page document that I previously identified.
And if you'd tell me what this, explain this document to me, please.
A. This is -- I prepared this by order sequence of the pictures. It will tell you the evidence
item number, that's the sheriff's department number, as well as the trial exhibit number
for the item that is pictured.
Q. Okay.
A. That's by sequence of the pictures.
Q. All right. And there's three pages of that, correct?
A. Correct.
Q. Two and a half? Well, almost three.
A. They're the same material. They're in different order for researching purposes.
Q. All right. I need you to explain that for me. I'll show you the first one again. MR.
SANGER: Actually, Your Honor, I apologize, I should have brought this up, but we have
not been provided a copy of this, of these, of any of this, but specifically these three
pages. And it appears that counsel's not familiar with them either. Could we please have a
copy so we can look at them closely while we go through here? THE COURT: Do you have
a copy for them? MR. AUCHINCLOSS: No. THE WITNESS: I have an extra copy. MR.
AUCHINCLOSS: Thank you, Detective. THE COURT: Go ahead. MR. AUCHINCLOSS: May I
proceed?
Q. Okay. Now, this one has the notation in the right-hand portion of the document, Order
by picture sequence?
A. That's correct. So -Q. And what does that mean?
A. It means that if you follow along with the pictures, this document is going to follow as

the pictures go along.

Q. Do you mean in terms of the -A. So if you start, page one, with the first picture, it's a picture of Item 317-J.
Q. Okay. And did you make that notation on each of the pictures that is in this exhibit?
A. Yes, I did.
Q. Okay. The second page, that's, Order by S.B.S.O. item number. What does that mean?
A. It's the same data that has been reconfigured so that if somebody wants to go and
quickly look based upon the sheriff's department item number, that they can do that, and
they can correspond that with the trial exhibit number.
Q. Okay. And then lastly, you have, Order by criminal trial exhibit number.
A. Again, the same data. This time it had been arranged so that you can quickly look,
based upon a trial exhibit number, and know what the sheriff's department number is.
Q. Okay. So all of these three documents have the same information in different
configurations?
A. That's correct.
Q. All right. Now, I'm just going to show you the first page of this group of exhibits and
just ask you to explain to me what you did. Okay. These are an example of the
photographs you took?
A. Yes, they are.
Q. And explain this exhibit to me.
A. The easiest way -- it's a printout in order of the pictures as they were taken. You can't
really see it too well, it's a little fuzzy, but317-J is written above this picture.
Q. We're going to give you a laser pointer so it's a little easier for you, and I'll blow this up
a little b it.
A. Okay. This is Item 317-J. I have notated that above the picture. Same thing for this
one. If you were to -- I'll skip down to this picture right here. This is 317-A, and the order
goes like this.
Q. And these are -- this is the -- I believe you testified to this, but this is the grand jury
exhibit that was presented to the grand jury?
A. That's correct.
Q. All right. Detective, did you participate in the execution of a search warrant in the case
of People v. Jackson on January 31st, 2004?
A. Yes, I did.
Q. And whose home did you serve that search warrant on?
A. Marc Schaffel or Frederic Schaffel.
Q. And did you seize documents pursuant to that search warrant?
A. Yes, I did. MR. AUCHINCLOSS: If I might approach again, Your Honor. THE COURT:
Yes.
Q. BY MR. AUCHINCLOSS: All right. Detective, I show you the notebook that I've
mentioned as Exhibit 400 through 420. And showing you Exhibit 402, which appears to be
a Neverland Valley Entertainment -- What more can I g ive is at the top of it. I'm sorry. I'm
a little ahead of myself here. I'm going to first show you Exhibit 404, which appears to be
a two-page document --three-page document. The first page appears to be entitled,
Messages. Did you seize that document pursuant to the warrant?
A. Yes, I did.
Q. Then there are two more pages attached to that or behind that, the first of which is
entitled, MJJ Productions Working Group List. Appear to be phone numbers. Did you also
seize those documents, those two documents?

A. Yes, I did.
Q. Where did you seize those?
A. Those were seized from an upstairs bedroom closet. It was a small walk-in closet that
was locked, and within that were a number of filing cab inets. One of these cabinets in
particular had a drawer that was pretty much filled with materials related to this case. We
seized -- or I seized that entire drawer, and that is where this document came from.
Q. Did it come out of a specific file?
A. I believe it came out of the Stuart Backerman file.
Q. A file that had Stuart --MR. SANGER: I'm going to object to hearsay content. There's
no foundation for any of this. MR. AUCHINCLOSS: I'm just asking where it was located.
THE COURT: The objection is overruled.
Q. BY MR. AUCHINCLOSS: Moving to 405; let's see, it appears to be a one-page
document with Bell Yard at the top of it. Did you seize that pursuant to the execution of
this warrant?
A. Yes, I did.
Q. And where was that document seized?
A. This came out of the same file drawer.
Q. Moving on to 406, it appears to be a 14-page document. The first document has Hale
Lane at the top of it. Appears to be a fax sheet. Did you seize this 14 -- these 14 pages?
A. Yes, I did.
Q. And where did they come from?
A. Again, out of the same file drawer.
Q. 407, it appears to be a ten-page document, and the first page appears to be an e-mail
entitled, Spain Deal. Can you look through those documents and tell me if you seized
those pursuant to the search warrant that you've been discussing in this?
A. Yes, I did.
Q. And where were those documents seized from?
A. Those were on top of the filing cabinets.
Q. Okay. Were they located inside any particular file?
A. There was a file titled, Ronald.
Q. 408 appears to be four pages, and I think we've withdrawn that, so I'll move on. 409,
that's my next witness. 410, did you seize that document? This appears to be a four-page
document, starts off with a phone number sheet, two pages of yellow paper, lined paper,
and then a -- looks like a fax.
A. Yes, I did.
Q. Were those seized pursuant to the warrant?
A. Yes, they were.
Q. And where were they seized from?
A. They were seized from, again, on top of the filing cabinets and they were in a file-held
address book.
Q. Moving on to 411. This is a two-page document. Appears to be some kind of a
computer printout with Enterprise Rent-A-Car on the top page of each one. Did you seize
those documents?
A. Yes, I did.
Q. Where did they come from?
A. They came from that large filing drawer that we seized, and a -- specifically a file in
that drawer that said, Enterprise Rental.
Q. From the locked closet?

A. Yes.
Q. And the file said, Enterprise Rental?
A. Yes.
Q. Moving on to 412, it appears to be a five-page document, a Hale L ane fax sheet on the
first one; Gabriel Media on the second one; Appearance and Consent, third; MJJ
Productions on the fourth. The fifth appears to be a signature page. BAILIFF CORTEZ:
They can't hear you, sir. MR. AUCHINCLOSS: The fifth appears to be a signature page.
THE WITNESS: I seized these documents.
Q. BY MR. AUCHINCLOSS: Where did you seize them from?
A. These were seized from within that same file drawer. Specifically a file t itled, Artist
Release, or Artist releases.
Q. Okay. Moving on to 413, it appears to be a ten-page document. The first page -- the
first five pages appear to say, Appearance, Consent and Release on them. The next page
is a yellow lined page. And the next page appears to have six pages paper-clipped
together, all contained in one plastic liner, all right? So we've got, looks like, 11 pages
total in there. Did you seize those documents?
A. Yes, I did.
Q. Okay. Where did they come from?
A. They came from within that large filing drawer and in a file folder tit led, Model
Releases.
Q. And showing you what's noted as page seven, there appears to be several documents
that are paper-clipped together. Were those documents paper-clipped in that fashion
when you found them?
A. I believe so, yes.
Q. All right. Moving on to 414, it appears to be an eight-page document that -- and we
have -- I believe we've withdrawn that. So I'll go to 415, which appears to be 47 pages of
various records. The first one appears to be -- has Living with MJ, Take 2 at the top. Did
you seize those 47 pages, Detective?
A. Yes, I did.
Q. And where did those come from?
A. These were contained within a b lack binder which I found on a shelf above the filing
cabinets.
Q. Moving on to 417, skipping 416, it appears to be a 12-page document, at least 12
plastic-lined -- or, I'll double-check this. It does appear to be 12 pages. All right. Can you
identify that for me, please? Or I should say, did you seize those pages from the home of
Marc Schaffel during the execution of this warrant?
A. Yes, I did.
Q. Where did they come from?
A. They came from that same locked walk-incloset in a folder that was up above the filing
cabinets.
Q. And going now to -- oh, one question that I neglected to ask you. Did that come from
a
particular file?
A. I believe it was the David Gardner LeGrand file. MR. SANGER: Can we just specify for
the record what that meant? MR. AUCHINCLOSS: My question went to Exhibit 417. Its
location was in the file drawer. My question was --MR. SANGER: I understand. You pointed
to a page, and I didn't know if you were sing ling out a page or you meant the whole
exhibit. MR. AUCHINCLOSS: No, I meant the whole exhibit. MR. SANGER: I'm sorry to talk

directly to counsel, but we worked it out.

Q. BY MR. AUCHINCLOSS: Is that clear to you -A. Yes.
Q. -- that all those documents came from the David Gardner LeGrand file?
A. Yes, it is.
Q. Skipping 419 for the time being, going to 420, which appears to be a 28-page
document, or 28 separate pages, various -- look to be various e-mails, did you seize those
documents pursuant to the warrant on Mr. Schaffel's home?
A. Yes, I did.
Q. Where did they came from?
A. They came out of the same large filing drawer from the locked closet.
Q. Moving on to 421, it appears to be a ten-page document. First page says at the top,
Law Office -- Law Offices of Armstrong, Hirsch, et cetera. It appears to be a fax sheet with
an agreement attached to it. Did you seize those items, Detective, pursuant to your
warrant?
A. Yes, I did.
Q. Where did they come from?
A. They came from on top of the filing cabinets.
Q. That were in the locked closet?
A. Yes.
Q. 422. It appears to be a letter of intent from Royalty Advanced Funding. BAILIFF
CORTEZ: Still can't hear you, sir. You have to --MR. AUCHINCLOSS: Okay.
Q. It appears to be a letter of intent from Royalty Advanced Funding. Let's see. I'm going
to have to count these pages. It appears to be 19 pages. Did you seize those documents
pursuant to your search warrant?
A. Yes, I did.
Q. And where were they seized from?
A. They were also on top of the file cab inets.
Q. And same location, locked closet?
A. Yes.
Q. Did they come out of any specific file?
A. I believe they came out of a file tit led, Royalty.
Q. And lastly, 423, it appears to be seven pages. The face page looks to be an e-mail
followed by various correspondence. Did you seize those documents?
A. Yes, I did.
Q. Where did they come from?
A. They came out of the large filing drawer that we seized.
Q. Okay. Once again, the locked file closet?
A. Yes.
Q. And were they associated with any particular file?
A. I believe it was called Foreign Rights. MR. AUCHINCLOSS: All right. Thank you,
Detective. No further questions. MR. SANGER: May I have one moment, please, Your
Honor? May I proceed, Your Honor? THE COURT: Yes.
CROSS-EXAMINATION BY MR. SANGER:
Q. Let's talk about the grand jury pictures here, first of all. Are you aware that one of the
fingerprints that was identified sometime ago in this trial was located on a magazine that

was in that briefcase?

A. I don't know. I've heard that. I don't know which one.
Q. Okay. You've heard that?
A. Yes.
Q. And so you did not go through to compare your numbers to see if the 317 sheriff's
exhibit number matched up with the particular item on which a fingerprint was identified?
A. No.
Q. Basically what you're saying here with regard to all these grand jury pictures that
we've just heard about is, you went to the grand jury clerk, right?
A. Correct.
Q. And you had her pull out the briefcase, correct?
A. Yes.
Q. And this -- this was theoretically the way the briefcase was delivered to her by the
grand jury when they were through; is that right?
A. Theoretically, correct.
Q. And so if she did her job, she would have kept it intact, and then it would be there, you
would open it up, and the contents would be the way that she got it from the grand jury,
correct?
A. Yes.
Q. There was no way for you to know what was done with the briefcase at or during the
grand jury proceedings; is that correct?
A. No.
Q. I'm sorry, I said, Is that correct? So that's my fault. Was there any way for you to
know what was done to the briefcase and the contents at or during the grand jury?
A. No, there's not.
Q. All right. And when you recovered the briefcase from the clerk, did you ascertain from
her that she and staff members had gone through the exhibit without wearing gloves?
A. No.
Q. Did you do anything to, from that moment forward, preserve the exhibit so that
fingerprints could be analyzed?
A. Yes, I wore gloves.
Q. And did you ask that the clerk wear gloves in the future when handling that exhibit?
A. I didn't know that she hadn't.
Q. Okay. All right. Very well. Let me ask you -- Miss Frey, we're fine on that. THE CLERK:
Okay. MR. SANGER: Thank you. Thank you for looking.
Q. Let me ask you about some of these exhibits that you had identified from the residence
of Mr. Schaffel. And I want to ask you, first of all, if you were aware that persons other
than Mr. Schaffel had been working out of his house.
A. Yes.
Q. Now, you identified most of the exhibits in this book that's placed before you; is that
correct?
A. Yes.
Q. And by that I mean, just now you went through and you said, Sure enough, I seized
those items, correct?
A. Correct.
Q. What percentage, if you can g ive us an estimate, of the materials that you seized does
this book represent?
A. 5 to 10 percent.

Q. Okay. So there were thousands of pages -A. Yes.

Q. -- that you seized, correct?
A. Yes. 7495
Q. And you seized thousands of pages from tens of thousands of pages of documents and
materials,maybe more than that, that were in these various offices or file cab inets or
whatever the location was within this house, correct?
A. Correct.
Q. Now, you indicated in your direct testimony -- for instance, if you would look at Exhibit
421, please. It's in front of you there. 421 in the book. You indicated that this was a fax
with a number of sheets attached to it. The first thing I want you to do is ask you to turn
to page two of that exhibit, 421, and note that there's a handwritten number on the top.
A. 8012?
Q. Yes, sir. Is that a number that was there, or is that something that was placed there?
A. That number has been there. We didn't put that there.
Q. All right. So that's a number that just was on the document. You seized it. There it
was.
A. Yes.
Q. All right. The District Attorney asked you if the document was attached to the fax. Was
the document, in fact, attached to the fax cover?
A. I don't know.
Q. Okay. In fact, if you look at it, can you tell whether or not the document actually
belongs to that fax?
A. Being that it didn't get -- or it was not sent to me, I wouldn't absolutely know that. I
know that I seized all of these documents from that file -Q. All right.
A. -- in his residence.
Q. And I'm just trying to clarify the question about the document attached to the fax. It's
attached as it's sitting there. You don't know whether or not it was physically stapled or
attached at the time, correct?
A. No.
Q. And if you look, there's no fax header on the first page and there are fax headers on
the subsequent pages, correct?
A. Correct.
Q. Now, I want to go back to an exhibit. Let me just find it here. 414. Let me see if I have
the right one. Yes. 414. Now, the District Attorney indicated -- when you got to 414, he
started to ask you about that and he said, W e're withdrawing that exhibit, or That's
withdrawn; is that correct?
A. Yes.
Q. I'd like to ask you about 414, and so I'm going to ask that it be marked for
identification as 414. In other words, it's already been premarked by the prosecution, but
I think I need to say on therecord that we're asking this be identified on the record, if
that's acceptable to the Court. And itstarts out with what appears to be a Xerox of -- at
least the one I have is a Xerox of two --MR. AUCHINCLOSS: I'm going to object to the
admission of any evidence on that document on the basis of hearsay, including the
document's name. THE COURT: All right. As to 414, it is a marked exhibit, and it cannot
be unilaterally -- how do you say that? THE JURY: (In unison) Unilaterally. THE COURT: All
right. Let's take a break. Withdrawn. (Recess taken.) THE COURT: As for the rest of the

objection, he's doing the same thing. MR. AUCHINCLOSS: And I --THE COURT: He's laying
a foundation, which he's allowed to do. MR. AUCHINCLOSS: And I have no objection to
that. I'll just ask -- I'll stipulate to identification and ask --BAILIFF CORTEZ: Your mike is
off, sir. MR. AUCHINCLOSS: Stipulate to identification and ask that counsel not read the
name of the exhibit. The Court can look at that exhibit and appreciate my reasons for
that. MR. SANGER: Didn't the Court just rule I could do it? I'm confused. THE BAILIFF: Is
your microphone on? MR. SANGER: It was, but I guess I wasn't close. THE COURT: Say
that again. You're confused? MR. SANGER: I'm confused. THE COURT: Okay. MR.
SANGER: And I think the District Attorney was going to stipulate to that. That's what he
said. MR. AUCHINCLOSS: So stipulated. THE COURT: You may proceed. MR. SANGER:
Okay. Thank you.
Q. The question pending was -- or I don't know if there was a question pending, but let
me ask you, look at 414. The first page has what appear here to be copies of -- what do
we call those these days? Floppy disks?
A. That will work.
Q. That's beginning to be like an 8-track these days, I suppose. Anyway, it's -- you have
the actual disk there; is that correct?
A. That's correct.
Q. And there's a notation on those two disks that say --MR. AUCHINCLOSS: And that's
what I'm objecting to. I'll stipulate they're two disks that he found. THE COURT: Actually,
you are not allowed to proffer stipulations in open court if the --MR. AUCHINCLOSS: All
right. THE COURT: Go ahead, Counsel.
Q. BY MR. SANGER: Did the disk say on them Janet expense backup and Janet cash
expense?
A. Yes, they do.
Q. That's followed by a number of pages that indicate Register at the top -A. Correct.
Q. -- is that correct? Now, as to 414 and the two disks, where did you locate those?
A. 414 -- well, the only thing I located was the two disks.
Q. I see. All right. Where did you locate the two disks?
A. They were in that same filing cabinet drawer that was seized from the upstairs locked
closet.
Q. All right. And you see 414, the printed pages. Are those pages that were printed out
from the disk subsequent to your seizure?
A. In a manner of speaking. They had to be imported into Quicken and bring it up as a
check reg ister, and then print that.
Q. Did you do that?
A. Yes, I did.
Q. All right. Good. So the rest of 414 -- you have the two disks, and then the rest of it,
the printed pages, is it your opinion that these pages accurately reflect at least a part of
the content of the two disks?
A. That's correct.
Q. Now I'm going to refer to Exhibit 416. That is another one, if I'm not mistaken, that the
District Attorney indicated that he was not going to address. And let me ask you to take a
look at 416. It's been marked for identificat ion, and the first page on 416, it says,
Summary of petty cash expenditures; correct?
A. Yes. Yes.
Q. And that's approximately two pages. And then it appears that the subsequent pages

are receipts and other evidence of expenses that were incurred; is that correct?
A. That's correct.
Q. Did you find these documents from 414 -- let me withdraw that. Did you find these
documents that are -- I'm going to withdraw that. Did you find these documents which
comprise 416 in your search?
A. No.
Q. Did somebody else find it?
A. No.
Q. Do you know where they came from?
A. I believe they came --MR. AUCHINCLOSS: Objection. That's a yes or no question. THE
COURT: That's true. Yes or no.
Q. BY MR. SANGER: Do you know where they came from?
A. Yes.
Q. Where did they come from? MR. AUCHINCLOSS: Objection. No foundation. THE
COURT: Sustained.
Q. BY MR. SANGER: How do you know where they came from?
A. In meetings that we've had, I've came to know where these items came from.
Q. Okay. As a part of your job being an investigator in this case, you've determined where
these items were orig inally obtained; is that correct? Is that what you're saying? Let's put
it this way: Did you personally seize these from any location anywhere?
A. No.
Q. Did you witness them being seized?
A. No.
Q. So you were informed where they were seized from?
A. Yes.
Q. There you go. All right. Now, you wanted to -- at the break, you indicated you wanted
to clarify part of your testimony.
A. Uh-huh. Yes.
Q. And I believe it was with regard to we had made reference to Exhibit 421, and I believe
you wanted to clarify part of your testimony with regard to Exhibit 421.
A. Correct.
Q. Are you turned to it there?
A. Yes.
Q. That's the exhibit where I asked if the cover went -- the fax cover went with the
document.
A. Correct.
Q. And you were not sure. And then I had asked you about the numbers on the top of the
document, number 8012, and then it seems to be successive numbers up to 8020, with a
number sign in front; is that correct?
A. Correct.
Q. Just handwritten at the top, right?
A. Yes.
Q. Did you determine, during the break, whether or not those numbers were in fact on the
documents when you actually seized them?
A. Yes, I did.
Q. And were they on the documents when you actually seized them?
A. No, they were not.
Q. Do you know who put those documents (sic) on?

A. District Attorney personnel.

Q. So you seized them, booked them into evidence; is that right?
A. Correct.
Q. Sometime, apparently, they were withdrawn from evidence, from the booking -- I'm
sorry, from the sheriff's evidence, right?
A. Correct.
Q. And the District Attorney at some point had them and wrote numbers on them; is that
right?
A. Correct.
Q. And I take it, if you look at 422, there are numbers again written on the top, which are
not necessarily in sequence. In fact, I could drop the word necessarily. They're not in
sequence at all, it appears; is that correct?
A. Correct.
Q. But there are numbers that I think all start with the number 8?
A. Correct.
Q. Four-digit numbers. Were those numbers on those documents when you seized them?
A. No, they were not.
Q. And your understanding is that they were later added by the District Attorney's Office?
A. Correct.
Q. If we turn to 423, would that similarly be the testimony on 423? I see that the first few
pages do not have a number, but it appears that maybe starting on page five, there's a
number starting with seventy - well, it's actually 7802 is the number. And there's some
numbers following that that are not in sequence. Those numbers all starting with 7, are
those numbers that also were added in that same fashion, to your knowledge?
A. Correct. MR. SANGER: Okay. I have no further questions.
REDIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. As far as those numbers go, Detective, do you know if those numbers were added to
the original documents?
A. No, they were not.
Q. Okay. So these -- do you know if these documents were ever scanned into a CD
format?
A. Yes.
Q. Were they assigned JPEG numbers, or numbers?
A. Yes. 7505
Q. And do you know if those numbers coincide to the scanned numbers? MR. SANGER:
That's lead ing. MR. AUCHINCLOSS: Do you know? THE WITNESS: I don't. THE COURT:
Overruled. The answer?
Q. BY MR. AUCHINCLOSS: Do you know?
A. I don't.
MR. AUCHINCLOSS: Okay. As far as Exhibit 420 goes, Your Honor, I spoke with counsel
about this earlier. And I asked to have marked as an additional exhibit 420-A. I neglected
to ask this witness about those particular changes that were made to that exhibit when I
had him on direct, and with the Court's permission, I'd just like to ask a foundation about
420-A.THE COURT: Okay.
Q. BY MR. AUCHINCLOSS: All right. Let me bring up the notebook as well, or you still
have the original?

A. I have it.
Q. Okay. Detective, we've established that some of these documents are scanned
duplicates of documents that were seized; is that correct?
A. This is the end of it.
Q. Did you hear my question?
A. Yes.
Q. Is that correct?
A. Yes.
Q. And as far as 420 goes, do you know if 420 was also scanned into a CD format?
A. Yes, it was.
Q. Okay. And did you do that? Or, actually, not scanned. I believe pictures were taken. Do
you know whether it was scanned or pictures?
A. Both. MR. SANGER: I'm going to object as leading and asked and answered, actually.
MR. AUCHINCLOSS: I'll -- well --THE COURT: Overruled. Next question.
Q. BY MR. AUCHINCLOSS: Do you know if it was scanned or pictures?
A. Both.
Q. Okay. Some were scanned; some were taken pictures of?
A. Some were taken p ictures of. All of them were scanned.
Q. Did you have anything to do with the picture-taking?
A. Yes, I did.
Q. What did you have to do with that?
A. During a review of these evidence items after having seized them, I took photographs
of certain ones which we thought were pertinent to the investigation.
Q. All right. Did you download those photographs to a CD?
A. Our forensics personnel did.
Q. Okay. Do you know if those were provided to the D.A.'s Office?
A. Yes, they were.
Q. And when you took photographs of those documents, do you know if you photographed
every --for instance, let me g ive you an example. When you had a picture of -- or a
document that comprised more than one page, did you always photograph each page of
that document?
A. No.
Q. And why was that?
A. I would have only taken photographs of the ones that appeared pertinent. In other
words, if there were multiple pages stapled together or multiple pages together and only
one of them was pertinent, I only took a photograph of that one pertinent page.
Q. Okay. And during the course of the review of this notebook, did you look at 420 to see
if each of those e-mails or documents that are in that exhibit contained all relevant pages
for each of those documents? Do you understand the question?
A. Can you ask that again, please?
Q. The question is, did you review the --these -- the evidence notebook in this case that
deals with Exhibits No. 420 through -A. Yes.
Q. I believe we've got 440; is that right? 420 through -- 400 through 422, I think, at this
point.
A. Yes, I did.
Q. Okay. And did you find that Exhibit No. 420
6 had some pages missing?

A. Yes.
Q. And did you then go back to the evidence and cull out the missing pages so that it
would be a comp lete exhib it?
A. Yes.
Q. I show you Exhibit 420-A. Can you identify that for me, please?
A. These are the pages that I went and pulled out of the actual evidence item to
correspond with these photographs or images.
Q. Okay. So is 420 pretty much an identical copy of 420-A, except for 420-A has some
additional missing pages?
A. Yes.
Q. All right. Thank you. I'd ask -- actually, we're going to hold off on admission of this
additional evidence at this time. Those are all the questions that I have right now, Your
Honor. MR. SANGER: Do you want to take your book? MR. AUCHINCLOSS: Yeah. Thanks.
RECROSS-EXAMINATION BY MR. SANGER:
Q. Okay. 420-A is now what you feel to be a more complete set of documents than 420; is
that correct?
A. Correct. And they are the original documents. MR. SANGER: All right. May I approach,
Your Honor? THE COURT: Yes. MR. SANGER: I was given a copy.
Q. All right. So 420-A are original documents. In other words, they were documents that
you found in the condition they were actually in -A. Correct.
Q. -- during the search. They aren't photocopies. They aren't photographs.
A. Correct.
Q. They aren't scanned.
A. No.
Q. All right. There are paper clips on there. Why are the paper clips on them? Does that
mean anything? Let me put it this way: Did you put the paper clips on them?
A. No, these paper clips aren't on the documents themselves. They're on the sleeve.
Q. All right. Did you put the paper clips on the sleeves?
A. Did not.
Q. Okay. Now, with regard to 420, how did you -- where did these come from? You
photographed them? Or you scanned them, or what? I'm not clear.
A. These are either the photographs or the scans. All of the Schaffel evidence was
scanned. W e also took certain photographs of them.
Q. Okay. I must say, I looked in there, and maybe I'm wrong, but I didn't see anything
that
looked like a photograph of a document as opposed to
a photocopy or scan. Am I wrong? In 420.
A. Well, I don't know what -- how these items -- this was done by the District Attorney's
Office that put together the court exhibit book here.
Q. Okay.
A. What I did is, I went and found the actual evidence item that I seized to correspond
with this exhibit book.
Q. Basically you're saying you don't know how 420 was generated at all; is that correct?
A. I know where the items came from. I don't know how they got into here.
Q. All right. And then you don't know what the paper clips mean on 420-A?

A. No. MR. SANGER: All right. Thank you. No further questions.

FURTHER REDIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. Would you look at those documents and see if you can ascertain any reason for the
paper clips to be on those documents? MR. SANGER: I'm going to ask -- that calls for
speculation and asked and answered. He says he doesn't know. MR. AUCHINCLOSS: He's
reviewed the documents as far as completeness, and he's testified as to that issue as to
whether the documents had missing pages, and I'm -- my question goes to that issue.
MR. SANGER: And I object to a speaking --THE COURT: Yeah. I'll sustain the objections.
MR. SANGER: Thank you. MR. AUCHINCLOSS: All right. I have no further questions. THE
COURT: Anything further, Counsel? You may step down. MR. AUCHINCLOSS: Call
Detective V ic Alvarez, Your Honor, and he will be our last witness today. THE COURT:
Come forward, please. When you get to the witness stand, you may be seated. You're still
under oath.

VICTOR ALVAREZ EXAMINATION

DIRECT EXAMINATION BY MR. AUCHINCLOSS:

Q. If I may approach, Your Honor. Detective Alvarez, did you participate in the search of

the home of Fred Marc Schaffel in Calabasas, California, on January 31st, 2004?
A. Yes.
Q. Did you seize certain documents pursuant to that search?
A. I did.
Q. Calling your attention to the black notebook which contains an exhibit that is marked
as 402, there is a document that's dated 11-12-01 and appears to be a balance sheet. It's
two pages. And as soon as I locate it, I'd like to ask you if this was a document that you
seized.
A. Yes.
Q. And you tell me, where -- did you seize that pursuant to the warrant of Mr. Schaffel's
home?
A. I did.
Q. Where did you seize it from?
A. It was in the upstairs office area of the residence.
Q. Okay. Was that area locked at all?
A. No.
Q. Okay. And from where in that upstairs office did you seize that document?
A. This was in the desk area of the upstairs office.
Q. Did it come from a file with any specific notation, if you recall?
A. I don't think so.
Q. Okay. Looking at Exhibit 403, which appears to be -- I believe we have 13 pages, plus
a -- 12 pages, plus a -- looks to be a file d ivider. Did you seize that file d ivider and those
documents pursuant to your search of Mr. Schaffel's home?
A. Yes, I did.
Q. Where did they come from?
A. These were also on -- in the office area upstairs on the desk.
Q. There appears to be a file d ivider, a plastic file divider, with Fires Brewing on it. Did you
seize that as well? MR. SANGER: I'm going to object to that, because they already laid the
foundation without bringing in content, so this is irrelevant, and no foundation for content.
THE COURT: Overruled. Proceed.
Q. BY MR. AUCHINCLOSS: Did you seize that as well?
A. That's correct.
Q. And where did that come from?
A. This was also on the top of the desk in the office area, second floor of the residence.
Q. Do you know where the contents of that file -- were there documents inside that file?
A. Yes.
Q. And can you tell me their relationship to the documents that you just identified?
A. Yes. They appear to be e-mails.
Q. Do you know if those documents came from that file?
A. Yes, they did.
Q. Okay. The one designated with that particular file marker?
A. Correct.
Q. That's my question.
A. Correct, yes.
Q. Moving on to 409, which appears to be a one-page document, that has at the top
Phone Number, singular. It appears to have some phone numbers on it. Did you seize that
document, Detective?
A. Yes, I did.

Q. And you seized that from Mr. Schaffel's home?

A. I did.
Q. Where did it come from?
A. This was also on top of -- in the office area, second floor of the residence, near -- on
top of the desk, the desk in the room there.
Q. Okay. And then finally call your attention to Exhibit 419, which appears to be three
pages of plastic sleeves with a check -- checkstub and check copy, it appears to be. Did
you seize those documents at the search of Mr. Schaffel's home on that day?
A. I did.
Q. And can you tell me where they came from in Mr. Schaffel's residence?
A. They also came from the office, the second floor of the residence.
Q. Okay. Whereabouts?
A. These were also on the desk area of the residence, or of the room. MR. AUCHINCLOSS:
Okay. Thank you. No further questions. Actually, I do have one additional question, I'm
sorry.
Q. On a different matter, Detective, pursuant to your investigation in this case -A. Yes.
Q. -- did you interview a witness by the name of Cindy Bell?
A. I did.
Q. Did you question her concerning her involvement as a witness in this case?
A. I did.
Q. Did you question her specifically about the issue of serving alcohol as part of her duties
as a flight attendant for Xtra Jet?
A. Yes.
Q. Did she tell you whose idea -- well, first of all, let me ask you a question. Did she tell
you anything about Coke or about wine in Diet Coke cans?
A. Yes.
Q. What did she tell you?
A. She said she serves white wine in a Diet Coke can for Mr. Jackson.
Q. When he's a client of Xtra Jet?
A. Correct.
Q. Did she tell you whose idea that was to put white wine or wine in a Diet Coke can?
A. Yes.
Q. What -- whose idea did she say it was?
A. She said it was either Michael Jackson's or Dr. Farshshian's. MR. AUCHINCLOSS: Okay.
Thank you. No further questions. You know, I do have one additional question I neglected
to ask. MR. SANGER: I was going to say No questions so we can go home, so I'll have to
wait and see what happens. THE COURT: He was going to say No questions. MR.
AUCHINCLOSS: Oh, I'm sorry.
Q. I neglected to ask you the date of that interview, if you can approximate it.
A. I don't remember.
Q. Do you remember the approximate month?
A. I don't.
Q. Okay. Was it -A. It's on -- it's documented on my report.
Q. Do you have your report with you?
A. I don't.
Q. You don't. Well, you might get to come back and tell us what date that was, then.

MR. SANGER: Move to strike, Your Honor. THE COURT: Stricken. MR. AUCHINCLOSS: I'll
withdraw it. Okay. Thank you. MR. SANGER: In light of those questions, Your Honor, I
have no questions.

2005 April 26 (Day 39) C. Montgomery, J. Klapakis, H. Moleshi

CYNTHIA C. MONTGOMERY EXAMINATION

THE COURT: Good morning, everyone.
COUNSEL AT COUNSEL TABLE: (In unison) Good morning, Your Honor.
THE JURY: (In unison) Good morning.
THE COURT: Counsel, are you ready to proceed?
MR. NICOLA: We are, Your Honor. We'd be calling Cynthia Montgomery. And she's on her
way in.
THE COURT: When you get to the witness stand, please remain standing. Please face the
clerk and raise your right hand.
DIRECT EXAMINATION BY MR. NICOLA:
Q. There's some water right there. You were asking about that this morning.
A. Okay. Thanks.
Q. Could you scoot closer to that second mike there?
A. Better?
Q. Try to keep your voice up so everyone can hear you. Could you tell the jury, please,
what profession you're in.
A. I'm a travel consultant. Can you hear me?
THE COURT: That was a little low.
THE BAILIFF: Actually, she needs to move closer.
BAILIFF CORTEZ: There you go. That's fine.
Q. BY MR. NICOLA: Move it up. Why don't we try that again. What's your profession?
A. I'm a travel consultant.
Q. Okay. Do you have your own business?
A. Yes, I do.
Q. And what is it called?
A. Class A Travel. A lso Uniglobe Travel.
Q. Class A Travel and Unig lobe Travel?
A. Correct.
Q. You're still very soft-spoken.
A. I don't mean to be. Can you hear me now?
Q. Where are you based out of?
A. Las Vegas. Oops, excuse me.
Q. Is that where your family is?
A. My husband, yes.
Q. How long have you been a travel consultant?
A. 21 years.
Q. And what kind of clientele do you service?
A. 90 percent of my clientele is in the entertainment industry. Primarily musicians.
Q. We can still barely hear you.
A. Primarily musicians. My clientele is based on the entertainment industry.
Q. Okay. And has it always been based on the entertainment industry for clients?
A. For the last 15 years, 16 years.

Q. Do you have any experience arranging transportation outside of the United States?
A. Yes, I do.
Q. Does that include air travel?
A. Yes, it does.
Q. And do you have some amount of experience dealing with foreign embassies and
securing visas and passports and things of that nature on behalf of your clients?
A. Yes, I do.
Q. Are you familiar with the entrance requirements, meaning the visa requ irements, for a
U.S. citizen to get into Brazil by air?
A. Yes, I do. Yes, I am.
Q. Have you arranged for accommodations for any of your clients in the past?
A. Yes, I have.
Q. Okay. Do you know the defendant in this case?
A. Yes, I do.
Q. Mr. Jackson?
A. Correct.
Q. And how do you know him?
A. Through Mr. Schaffel.
Q. Okay. I'd like to show you -MR. SANGER: Tom.
MR. NICOLA: Oh, Mr. Mesereau?
MR. MESEREAU: (Nods head up and down.)
MR. NICOLA: May I approach, Your Honor?
THE COURT: Yes.
Q. BY MR. NICOLA: Showing you Exhibit No. 16, do you recognize that individual?
A. Yes, I do.
Q. And who is that?
A. Marc -- Frederic Marc Schaffel.
MR. NICOLA: Your Honor, we'd move 16 into evidence at this time.
MR. MESEREAU: No objection.
THE COURT: It's admitted.
Q. BY MR. NICOLA: Does Mr. Schaffel go by the names Fred or Marc?
A. Yes, he does.
Q. And what do you call him?
A. Fred.
Q. Fred. Okay. And how do you know Mr. Schaffel?
A. Through a man by the name of Steven Doolittle. They were business associates.
Q. How long have you known Mr. Schaffel?
A. I believe almost 20 years.
Q. 20 years? Are you two friends?
A. Not anymore.
Q. Okay. Had you been friends for the majority of that 20 years?
A. Yes.
Q. And you met Mr. Jackson through Mr. Schaffel?
A. That's correct.
Q. At some point in time did Mr. Jackson become a client of yours?
A. Yes, he did.
Q. And around when was that?

A. The latter part of 2000.

Q. Okay. And what did you do for Mr. Jackson in that period of time, just very generally,
please?
A. Arranged for his private jet transportation.
Q. Okay. And did you cease working for him in that capacity for some period of time in
2002?
A. Yes, I did.
Q. Okay. And when did you resume your duties, your activities, with respect to arranging
Mr. Jackson's private air travel?
A. I believe the latter part of 2002. I can't be certain of the date.
Q. Okay. Later in the year?
A. I believe so.
Q. During the period of time that Mr. Jackson was a client of yours, did you have occasion
to meet any of his associates?
A. Yes, I did.
Q. Did you meet a man named Dieter W eizner?
A. Yes, I did.
Q. Did you know what his capacity was with respect to Mr. Jackson?
A. Yes, I do.
Q. What is that?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. NICOLA: How d id you know Mr. Weizner?
A. I met him through Mr. Schaffel.
Q. Okay. Is it Weizer or Weizner?
A. Dieter Weizner, is the way I was told to pronounce it.
Q. Okay. And was he associated with Mr. Jackson, to your knowledge?
A. Yes.
MR. MESEREAU: Objection; lead ing.
THE COURT: Sustained.
Q. BY MR. NICOLA: Do you know what the relationship was between Mr. Weizner -Weizner. Weezner -A. Weizner.
Q. -- and Mr. Jackson?
A. Could you repeat that? I'm sorry.
Q. Did you know what the relat ionship was between them?
MR. MESEREAU: Objection; foundation.
THE COURT: Overruled. You may answer that question. It should be answered yes or
no.
THE WITNESS: Yes.
Q. BY MR. NICOLA: Okay. And how did you come to that knowledge?
A. By Mr. Schaffel and being around them.
Q. Okay. Did any of that information come from Mr. Weizner?
A. I was with Mr. Weizner on certain occas ions.
Q. With Mr. Jackson present?
A. Twice.
Q. Okay. And did Mr. Weizner represent himself to you as having any business relationship
with Mr. Jackson at the time?

A. Yes.
Q. And what was that?
A. He was -- he owned the merchand ise company for Mr. Jackson.
Q. Okay. I'd like to approach and show you Exhibit No. 17 and 18. Do you recognize the
man in Exhibit 17?
A. I do.
Q. And who is that?
A. Dieter Weizner.
Q. In addit ion, do you recognize the man in Exhib it 18?
A. I do.
Q. And who is that?
A. Ronald Konitzer.
Q. How do you recognize Mr. Konitzer?
A. I met him in Las Vegas.
Q. Okay. And through whom did you know him?
A. Mr. Schaffel.
Q. Do you know a man by the name of Frank Cascio?
A. I do.
Q. Have you met him before?
A. Once.
Q. I'd like to show you Exhibit No. 20. Do you recognize the man in Exhibit 20?
A. I do.
Q. And who is that?
A. Mr. Cascio.
Q. Did you ever have occasion to meet a man by the name of Vinn ie or Vincent Black?
A. No.
Q. Okay. How about Vinnie or Vincent Amen?
A. I don't recall meeting him. I know who he is.
Q. Did you ever make flight arrangements for Mr. Amen?
A. Yes, I did.
Q. Did you ever make flight arrangements for Mr. Cascio?
A. I did.
Q. How about Mr. Konitzer?
A. Yes, I did.
Q. How about Mr. Weizner?
A. Yes, I did.
Q. When you made these travel arrangements, were they in connect ion with flights that
Mr. Jackson was also taking?
A. Sometimes.
Q. Okay. How about if they were by private jet?
A. Sometimes.
Q. Okay. And at other times what kind of arrangements did you make for those men?
A. Commercial flights.
Q. Okay. Now, with respect to the period of late 2002 and up to late September of 2003,
did you have multip le occasions to make flights for Mr. Jackson where Mr. Konitzer or Mr.
Weizner were also on the same flight?
A. Yes, I did.
Q. Okay. Who made arrangements for those flights? In other words, who contacted you to

set the flights up?

A. There would have been two people.
Q. Let's start with the first person.
A. Michael's assistant, Evvy Tavasci.
Q. And did she contact you through a company that she was working in? Was there a
company name associated with Evvy Tavasci?
A. Yes.
Q. What was that?
A. MJJ Productions.
Q. Okay. So Ms. Tavasci would contact you and then what would happen?
A. I would arrange for jets or commercial flights per her instructions.
Q. She would send you instructions about where Mr. Jackson wanted to go?
A. Correct.
Q. And then you would do what?
A. I would make a phone call to reserve a jet for him.
Q. Okay. Was there a company that you worked with primarily in reserving a jet for Mr.
Jackson?
A. Yes.
Q. And what was that company?
A. Xtra Jet.
Q. Okay. Did Miss Tavasci ever contact you to arrange travel for Mr. Amen, Mr. Cascio, Mr.
Konitzer, or Mr. Weizner that did not involve commercial aircraft? Excuse me -A. Yes.
Q. Excuse me, private aircraft.
A. No.
Q. Who was the second person that contacted you to arrange travel?
A. Fred Marc Schaffel.
Q. And did he work through a company?
A. Yes.
Q. And what was the name of that company?
A. Neverland Valley Entertainment.
Q. Okay. And was that his company, to your knowledge?
A. And Mr. Jackson's.
Q. A joint company?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
MR. MESEREAU: Move to strike.
THE COURT: Strike the answer.
Q. BY MR. NICOLA: Just a yes or no question: Do you know who the principals of
Neverland Valley Entertainment were?
A. Yes.
Q. And how did you come to that knowledge?
A. Through Mr. Schaffel.
Q. Was it something Mr. Schaffel told you?
A. Yes.
Q. What did he tell you about the principals of Neverland Valley Entertainment?
MR. MESEREAU: Objection. Hearsay and foundation.
THE COURT: Sustained.

MR NICOLA: W e'd be offering them under admissions, Your Honor, of agents.

THE COURT: Excuse me?
MR. NICOLA: We'd be offering them under admissions of agents, Your Honor.
THE COURT: The objection is sustained.
Q. BY MR. NICOLA: Okay. When Mr. Schaffel contacted you, was it always on behalf of
Neverland Valley Entertainment?
MR. MESEREAU: Objection; lead ing.
MR. NICOLA: Let me rephrase it. I'd like to clean that up, if I may, Your Honor.
THE COURT: Go ahead.
Q. BY MR. NICOLA: When Mr. Schaffel contacted you with respect to making flights or
travel arrangements, was it always through Neverland Valley Entertainment?
A. Could you be more specific?
Q. Certainly. For travel arrangements -- did Mr. Schaffel ever call you to make travel
arrangements for Mr. Jackson?
A. Yes.
Q. And did he do that through Neverland Valley Entertainment?
A. Most of the time, yes.
Q. Most of the time, yes. Did he ever make those arrangements for Mr. Jackson through
MJJ Productions?
A. Yes.
Q. Okay. Let's talk about how the arrangements were made. If Mr. Schaffel or Miss
Tavasci called you and wanted to arrange a flight for Mr. Jackson, who would be
responsible for paying the bill for that flight?
MR. MESEREAU: Objection; foundation.
THE COURT: Sustained.
Q. BY MR. NICOLA: Do you know how billing was arranged?
A. Yes, I do.
Q. Okay. Please explain that to the jury.
A. Um -MR. MESEREAU: Same objection. Foundation.
THE COURT: Sustained.
Q. BY MR. NICOLA: How -- do you know how the billing was arranged for the private
flights for Mr. Jackson that you arranged?
MR. MESEREAU: Objection. Foundation and assumes facts not in evidence, no personal
knowledge.
THE COURT: Sustained.
Q. BY MR. NICOLA: Do you have personal knowledge of how the billing was arranged for
the private flights that you set up for Mr. Jackson?
A. Yes.
Q. Explain that for the jury, please.
MR. MESEREAU: Same objection. Foundation.
THE COURT: Sustained.
Q. BY MR. NICOLA: Who was billed -- or did you do the billing for the private flights that
you set up for Mr. Jackson?
A. I did the billing.
Q. You did the billing?
A. Correct.
Q. Okay. Who did you charge for those flights?

A. Two different accounts. Neverland Valley or his business managers, Whitman Fox.
Q. Neverland Valley Entertainment and who else?
A. Bernstein Fox & Whitman Company.
Q. Did you ever bill MJJ Productions?
A. I might have.
MR. MESEREAU: Move to strike. Speculation.
THE COURT: Sustained.
Q. BY MR. NICOLA: Do you have any reco llection of whether or not you billed -THE COURT: I'll strike that. I'm sorry, I just wanted the record to reflect I struck that.
MR. NICOLA: Oh, I'm sorry, Your Honor.
Q. Do you have any recollection of billing MJJ Productions directly?
A. I might have.
MR. MESEREAU: Move to strike; speculation.
MR. NICOLA: Let me ask you a different question.
THE COURT: Stricken.
Q. BY MR. NICOLA: Did you ever pay for those flights prior to being reimbursed?
A. Yes.
Q. Okay. Could you explain how that would come about?
A. Well, I act as an agent, second party. I would be invo iced by Xtra Jet and, in turn, I
would invo ice one of the companies. I've -Q. Okay. So Xtra Jet would send you the bill?
A. That's correct.
Q. And that's how you would know the billing was arranged?
A. That's correct.
Q. Then you would send an invoice to which companies to get payment?
A. Depending on which company I was instructed to bill. Either Neverland Valley or MJJ or
Bernstein Fox.
Q. And who would -A. -- invoice MJJ. Sorry?
Q. Who would you receive billing instructions from?
A. Either Mr. Schaffel or Miss Tavasci.
Q. As part of your responsibility in arranging flights for Mr. Jackson to keep the flight
manifests as part of your records?
A. It's an FAA requirement.
Q. Okay. Could you tell us how a flight manifest is transmitted to you with respect to
these flights that we're talking about?
A. Either verbally or via fax or e-mail.
Q. Okay. And was that the same as the reservations, the information came to you from
Mr. Schaffel or Miss Tavasci?
A. Correct.
MR. NICOLA: Okay. If I may approach the witness again, Your Honor. Mr. Mesereau,
Exhibit 251, 253 and 254. Now I'm going to approach.
Q. Mrs. Montgomery, I've placed in front of you a three-ring binder, which is opened to a
page that has an exhibit sticker on the bottom right-hand corner, Exhibit No. 251; is that
correct?
A. Yes.
Q. Do you recognize that document?
A. I do.

Q. Okay. And can you please turn the pages and review each of the documents in that
section labeled 251. Did you go on to page 252?
A. Did I go to page 253?
Q. 252.
A. No, I did not.
Q. Okay. Do you recognize Exhibit 251, ma'am?
A. Yes, I do.
Q. What is that?
A. It's a flight manifest. It's a bill from Xtra Jet, it's a passenger trip sheet, and it's a trip
report from the pilots.
Q. Okay. How do you recognize those documents in Exhibit 251?
A. The first page is addressed to me from Evvy. The second page is the trip sheet from
Xtra Jet, which I always get after a flight is terminated. I have an invoice here made out
to my company. And I have the pilots' report.
Q. Are the items in Exhibit 251 records that are kept within the normal course and scope
of your business as a travel consultant?
A. Yes, they are.
Q. Okay. And do you regularly rely upon the contents of those documents in Exhibit 251 in
the regular course and scope of your business?
A. Yes.
Q. Okay. And is the information contained within the documents in Exhibit 251 recorded at
or near the time of the event purported?
A. Yes, they are.
MR. NICOLA: Okay. We'd move 251 into evidence, Your Honor.
MR. MESEREAU: Objection. Foundation, hearsay, and authentication.
THE COURT: All right. It's admitted. It's a business record.
MR. NICOLA: Thank you, Your Honor.
Q. Now, with respect to the first page dated June 6th, 2003, of 251.
A. Yes. Yes.
MR. NICOLA: May I have Input 4, Your Honor? Counsel, do you object to this exhibit?
MR. MESEREAU: No.
Q. BY MR. NICOLA: Mrs. Montgomery, if you would take a look over your shoulder, please.
And is that the first page of -- a copy of the first page that you have there in Exhibit 251?
A. Yes, it is.
Q. Okay. And is this an example of how Miss Tavasci would contact you with respect to
setting up a flight for Mr. Jackson on a private aircraft?
A. Yes, it is.
Q. And this particular request came to you on June 6th of 2003?
A. That's correct.
Q. There appears to be two columns with names, and that -- are those names provided to
you by Miss Tavasci in the regular course of setting these flights up?
A. The normal course.
Q. Okay. The M. Jackson on the top and the Marc Schaffel on the bottom, are these
typically the ways you would set the flights up for Mr. Jackson, using Marc Schaffel's
midd le name, Marc, and Mr. Jackson's first initial, M.?
A. It's the way Evvy would transmit it to me.
Q. Okay. Were there ever occasions when the flight instructions from Ms. Tavasci with
respect to who's going to be on the flight, were there ever occasions when those

instructions were changed?

A. Yes.
Q. Okay. The flights again, p lease. If you could turn the page, please, to Exhibit 253,
please. And flip through the documents in Exhibit 253 and review them, please.
A. Okay.
Q. Okay. Do you recognize those documents?
A. I do.
Q. Okay. And do they relate to a flight that you arranged for Mr. Jackson and his
entourage on September 12th of 2003?
A. I do. I recognize it.
Q. Okay. Are the contents of Exhibit 253 records of similar nature as Exhibit 251, kept
within the normal course and scope of your business, et cetera?
A. Yes.
Q. Did you rely on these documents as well within the regular course of your business?
A. Yes.
Q. And are these copies of your actual records for this flight?
A. Yes.
MR. NICOLA: We'd move Exhibit 253 into evidence, Your Honor.
MR. MESEREAU: Objection. Foundation, hearsay, authenticity.
THE COURT: They're admitted.
MR. NICOLA: If I may have the Elmo again, Your Honor.
THE WITNESS: Can I ask you something? If you're going to show the one with my
address, can you block it out, please?
MR. NICOLA: The witness has asked that a particular address on this document be blacked
out.
BAILIFF CORTEZ: Microphone, sir.
MR. NICOLA: I had the mike off. Do you object, Mr. Mesereau?
MR. MESEREAU: No.
MR. NICOLA: May I have a sticky, p lease?
Q. And is your business name up here on this exhibit?
A. Yes, it is.
Q. I'm sorry, Mrs. Montgomery. May I have Input 4, Your Honor? These are difficult to
work, I'll tell you that right now. Okay. Now, Exhibit 253, this was a flight on September
16th of 2003, and the customer name up there appears to be Class A Travel Services.
That's one of your companies?
A. Yes, it is.
Q. Okay. Did you receive a flight manifest for that particular trip?
A. Yes, I did.
Q. If you'd turn to page -- the second page of Exhibit 253. Is there a handwritten
passenger list?
A. Yes, there is.
Q. Okay.
A. May I reiterate something? I no longer do business as Class A Travel, just for the
record.
Q. You do business as a different company?
A. Now I do, correct.
Q. Okay.
A. It's a former company.

Q. But back in the period of time that we're talking about, late 2002 through September of
2003, you did business as Class A Travel and Uniglobe?
A. Back in that period of time, Class A Travel and Travel 21.
Q. Okay. Is Mr. Jackson's name on this list, obviously?
A. Yes.
Q. And was it uncommon for you to get a handwritten passenger list such as this?
A. This is from the pilot of the plane company.
Q. And these are records that you also keep for billing purposes?
A. There's times where I would have these records, yes.
Q. If you could turn to the fourth page. Let me show that, Your Honor. Now, is this
document the actual request from Miss Tavasci for you to set up a flight on the 16th?
A. Yes, it was. Yes, it is.
Q. And the names on her list, the passenger names are a little bit different; isn't that
right?
A. That's correct.
Q. Would that happen on occasion?
A. All the time.
Q. Okay. And finally, if you'd turn to the next page, there appears to be yet another list of
individuals for the same flight.
A. That's correct.
Q. And what is the purpose of this document?
A. It was for the U.S. Customs.
Q. Was this an international flight?
A. Yes, it was.
Q. Where did it go?
A. To Canada.
Q. Okay. And then it came back to the U.S.?
A. That's correct.
Q. Do you see the bottom name written on there, Ronald Konitzer?
A. Yes, I do.
Q. Is it uncommon for you to receive records from Xtra Jet with additional names on the
list handwritten?
A. No, it's not.
Q. If you could turn to Exhibit No. 254, please, and page through those.
A. Okay.
Q. Do you recognize the contents of Exhibit 254 as records that you kept within the
regular course and scope of your business?
A. I do.
Q. Okay. Was the information recorded in those documents recorded at or near the time
of the events recorded in Exhibit 254?
A. Yes.
Q. And are they records that you normally rely upon in the course of your business?
A. Yes.
MR. NICOLA: We'd move Exhibit 254 into evidence, Your Honor.
MR. MESEREAU: Objection. Hearsay, foundation, and authenticity.
THE COURT: They're admitted.
Q. BY MR. NICOLA: Now, 254 contains informat ion with respect to two individual flights;
is that correct?

A. Yes.
Q. And the first three pages relate to a flight from Boca Raton to California on February
25th,
2003; is that right?
A. Yes.
Q. Okay. I'd like to show you the first page of that exhibit, if I may, with Input 4. Now,
is this an example that -- a flight that Mr. Schaffel set up for Mr. Jackson?
A. It appears to be that way, yes.
Q. Do you have a specific recollection of this flight from Boca Raton to -- is that Van Nuys,
VNY?
A. Yes, it is.
Q. That's in California?
A. Correct.
Q. Do you have a specific recollection of this?
A. I do.
Q. How did that flight get set up, if you remember?
A. I received a phone call from Mr. Schaffel and -- saying he needed an airplane.
Q. Okay. From Florida to California?
A. Correct.
Q. On the 25th -A. Right.
Q. -- of February of 2003?
A. Right.
Q. Did you receive a passenger list for that flight from anyone?
A. On the third page, it could be the manifest from Evvy. Yes, this is the passenger
manifest for this flight.
Q. Okay. And did that come to you in a different format?
A. No. Normal procedure. E-mail.
Q. Okay. The passengers on this Xtra Jet flight were Mr. Jackson, appears to be two of his
children, correct?
A. That's correct
Q. Do you know who Grace Ru -- I can't say that last name.
A. Rwaramba, I believe.
Q. Rwaramba?
A. Yes.
Q. Do you know who that individual is?
A. Yes, I do.
Q. How do you know who she is?
A. I was told.
Q. Is she a frequent flyer with Mr. Jackson?
A. I believe so.
Q. How about Patricia Chavez?
A. Also I know who she is.
Q. Mr. LaPerruque, Mr. Crawford and Mr. Carter, are you familiar with those individuals?
A. With the exception of Daniel Crawford, yes.
Q. How do you know Mr. LaPerruque?
A. Because I was told who he was.
Q. Did he frequently fly with Mr. Jackson?

A. I can't be certain.
Q. Okay. How about Mr. Carter?
A. Yes.
Q. Did he fly with Mr. Jackson frequently?
A. Yes.
Q. Are you familiar with the names Marie Nicole Cascio and Aldo Cascio?
A. Yes.
Q. And are they related to Frank Cascio, to your knowledge?
A. Yes.
Q. Were they also frequently on Mr. Jackson's private aircraft?
A. I won't say frequently.
Q. Not frequently?
A. Correct.
Q. Okay. Before we turn to the second flight that's contained within Exhibit 254, if we
could discuss the bottom entry here where it says, Catering. W ere you responsible for
arranging the catering on Mr. Jackson's private aircraft?
A. Yes.
Q. How would you set the catering up?
A. I would call it in to -- I would call it in to Xtra Jet to the representative I worked with
there.
Q. Okay. And were you familiar with what Mr. Jackson wanted on his flights?
A. Yes.
Q. He was your client?
A. Yes.
Q. Okay. It was important for you to please him, I suspect?
A. Of course.
Q. Okay. Would you inform Xtra Jet in writing or verbally as to what should be catered for
Mr. Jackson?
A. I would forward the manifest -- or the request from Evvy as well as verbally instruct
them.
Q. Were there standard instructions that just were not relayed to you from Miss Tavasci in
writing?
A. Yes.
Q. Could you describe one of those requests?
A. She always wanted -MR. MESEREAU: Objection; hearsay.
THE WITNESS: She told me -THE COURT: Just a minute.
THE WITNESS: Sorry.
THE COURT: Just a minute.
MR. NICOLA: Just a minute.
THE COURT: Sustained.
Q. BY MR. NICOLA: Okay. Without telling us the content of your conversation with Ms.
Tavasci, she would relate the special needs, or any needs for the particular flight, correct?
A. Yes.
Q. Okay. With respect to serving alcohol on Mr. Jackson's private aircraft, Xtra Jet's
private aircraft that you arranged for him, did you ever make arrangements for alcohol to
be served to Mr. Jackson?

MR. MESEREAU: Objection. Leading and foundation.

THE COURT: Overruled. You may answer.
THE WITNESS: Yes, I did.
Q. BY MR. NICOLA: Okay. Did you ever make specific instructions as to how Mr. Jackson
should be served alcohol?
A. Yes, I did.
Q. With respect to wine, did you ever instruct any Xtra Jet employees on how to serve Mr.
Jackson wine?
A. Yes, I did.
Q. Okay. Prior to making those instructions, did you receive information from a Lauren
Wallace about how Mr. Jackson wanted his wine served to him?
A. Yes, I did.
Q. Okay. And did you know Lauren W allace as a flight attendant?
A. Yes. She is.
Q. Was she the primary flight attendant for Mr. Jackson during your period of service?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled.
THE WITNESS: Yes.
Q. BY MR. NICOLA: Yes, she was?
A. Yes, she was.
Q. Okay. And in what period of time did you receive the instructions from Ms. Wallace?
A. Through the course that we handled his private flights.
Q. Okay. Do you recall what Miss Wallace told you specifically about how Mr. Jackson was
being served his wine?
A. Yes, I do.
Q. Can you please relay that to the jury?
MR. MESEREAU: Objection; hearsay.
THE COURT: Overruled. You may answer.
THE WITNESS: She told me -Q. BY MR. NICOLA: Could you speak up, please.
A. Lauren W allace told me that Mr. Jackson had requested that his wine be put into soda
cans, and then if she was ever unable -- you can't always ensure that we're always going
to have the same flight crew. To respect his privacy and to relay the message to anyone
other than her if she was not flying to -- how to serve him.
Q. Okay. So Ms. Wallace told you that was Mr. Jackson's request to her?
A. That's correct.
Q. Could we turn back to Exhibit 253, please? And the last page appears to be an invoice
for a flight on March 25th of 2003.
A. You said Exhibit 253?
Q. I'm sorry, I meant 254.
A. Okay.
Q. Please turn to the last page of Exhibit 254.
A. Correct.
Q. Okay. Are there handwritten notes all over that exhibit?
A. Yes, there are.
Q. Is that your handwriting?
A. Yes, it is.
MR. NICOLA: If I may have Input 4, Your Honor. Thank you.

Q. Now, in the upper left-hand corner, does that exhibit show a billing address for MJJ
Productions of Provident Financial Management?
A. It does.
Q. Did you cross that out?
A. I did.
Q. And why was that?
A. He had terminated his relationship with them.
Q. And you were told to bill another entity; is that correct?
A. Correct.
Q. Did you write that entity's name on the bottom of the document?
A. I did.
Q. And was that Bernstein, Fox & Whitman?
A. Correct.
Q. Okay. Did you ever have occasion to keep a passenger profile for Mr. Jackson -A. Um -Q. -- in writing?
A. There is a document that I'm aware of in writing.
Q. Would you turn to Exhibit No. 252.
A. Okay.
MR. NICOLA: I believe I'm finished with the Elmo, Your Honor.
Q. Now, Exhibit 252 appears to be a passenger profile for Mr. Jackson?
A. That's correct.
Q. Did you generate that document?
A. Verbally.
Q. You verbally generated that document?
A. I did.
Q. And for what purpose?
A. For the purpose of his -- it would be on file for Mr. Jackson for his specific needs on
board his flights.
Q. Now, are the contents of Exhibit 252 consistent with your instructions to the flight
crews of Xtra Jet with regard to how Mr. Jackson should be taken care of with respect to
catering?
A. Could you repeat that, please?
Q. Have you read through the exhibit?
A. Yes.
Q. Okay. Are the instructions in there consistent with the instructions that you gave Xtra
Jet?
A. They're more specific.
Q. Okay.
A. Mine were general. These are specific.
Q. Is there a specific reference to putting white wine in D iet Coke cans in every flight?
MR. MESEREAU: Objection. Hearsay; foundation.
THE COURT: Sustained.
Q. BY MR. NICOLA: Did you go by the name Cindy Greenberg?
A. I did.
Q. Back when Mr. Jackson was your client?
A. Some of the time.
Q. Okay. And were you listed as one of Mr. Jackson's contact people along with Evvy?

A. Yes.
MR. NICOLA: Okay. If I may approach Madam Clerk. This is next in order, and this is next
in order.
THE CLERK: Mr. Sneddon has the stickies.
MR. NICOLA: Mr. Sneddon has the stickies?
MR. SNEDDON: They're right there.
Q. BY MR. NICOLA: I'm off like a herd of turtles today. I'd like to show you Exhibits 848
and 849, please.
A. Okay.
Q. Okay. Do you recognize the contents of Exhibit 848?
A. I do.
Q. And that appears to be a two-page document, front and back?
A. Yes.
Q. Okay. Is that a document that you generated?
A. Yes.
Q. And did you do that in the normal course and scope of your business?
A. I did.
Q. And are the entries -- let me ask you this a different way: Is the information in that
exhibit recorded at or near the time that the information was recorded?
A. A little vague.
Q. I asked the same question two different ways. Does the information accurately reflect
the entries that you made? You actually entered this informat ion, correct?
A. That is correct.
Q. And can you describe what the exhibit is for the jury? Just generally, and we'll get
more specific.
A. It's called a PNR, a passenger name record. It's a reservation made through an airline
computer system reflecting someone's flights that they would take. A reservation,
basically, with names, itinerary.
Q. You personally entered this information into the computer system and this is a printout
of what you entered?
A. Yes, it is.
Q. Okay. Is it a record you keep in the -- that you keep and rely upon in the ordinary
course of your business?
A. Yes.
MR. NICOLA: We'd move 848 into evidence, Your Honor.
THE COURT: Are you looking for the document, Mr. Mesereau?
MR. MESEREAU: Excuse me, Your Honor?
THE COURT: He mad e a motion to introduce 848 into evidence. I didn't know if you were
looking for the document or....
MR. MESEREAU: No, it was produced this morning by the prosecutor. No objection, Your
Honor.
THE COURT: All right. There's no objection. I'll admit it.
Q. BY MR. NICOLA: Okay. With respect to Exhibit 849, is that also information that you
entered consistent with 848 only with respect to a different client and a different flight?
A. Correct.
Q. Are those reservations for Mr. Fred Schaffel?
A. Correct.
MR. NICOLA: Okay. We'd move that into evidence as well, Your Honor.

MR. MESEREAU: No objection.

THE COURT: It's admitted.
MR. NICOLA: May I have the Input 4, please?
Q. I'll show you the first page of Exhibit 848. It works better that way. With respect to
generating this reservation, do you recall having a conversation with Mr. Fred Schaffel on
or around February 25th of 2003?
A. I do.
Q. And how did that conversation begin; do you recall?
A. He called me and asked me to make -MR. MESEREAU: Objection; hearsay.
THE COURT: Sustained.
MR. NICOLA: Statements in furtherance, Your Honor.
THE COURT: Well, the question was, How did that conversation begin? And the answer
was, He called me..., and then she started to volunteer the information. So the objection
is sustained.
Q. BY MR. NICOLA: Okay. Did he ask you to do something for him?
A. Yes.
Q. And what did he ask?
MR. MESEREAU: Same objection.
MR. NICOLA: Our offer of proof is in furtherance.
THE COURT: I'll ad mit this document under the previous instructions, limited to the use of
conspiracy evidence. Remember those conditional instructions I gave you earlier? All right.
Go ahead. It's admitted under those provisions.
MR. NICOLA: Okay, Your Honor.
Q. You can relay what he asked you to do for him, please.
A. He asked me to make flight arrangements for four passengers to Brazil.
Q. Okay. And are the names of those four passengers listed on this document?
A. Yes, they are.
Q. Did you personally highlight the lines within that exhibit prior to court?
A. Yes, I did.
Q. Okay. And are the names listed on this reservation easily available to you to read to
the jury?
A. Yes, they are.
Q. Please do so.
A. Arvizo, Janet; Arvizo, Davellin; Arvizo, Star; Arvizo, Gavin.
Q. Did Mr. Schaffel tell you where he wanted the Arvizos to fly to?
A. Yes, he did.
Q. Where?
A. To Brazil, Sao Paulo.
Q. You're going to have to speak up.
A. Sao Paulo, Brazil.
Q. Okay.
A. South America.
Q. Did he make a specific request as to what kind of tickets he wanted -A. Yes, he did.
Q. -- for the Arvizos? He did?
A. One-way tickets.
Q. Okay. Is it possible for U.S. cit izens to get into Brazil with a one-way ticket?

A. No, it's not.

Q. Why is that?
A. For visa reasons, you must have a return ticket to enter the country.
Q. Okay. Did you make arrangements for return tickets for the Arvizos?
A. I did. I chose the date.
Q. You chose the date for their return?
A. I did.
Q. Was that done arbitrarily or did you discuss that with Mr. Schaffel?
MR. MESEREAU: Objection; lead ing. 7562
THE COURT: Overruled.
THE WITNESS: I chose a date arbitrarily, and then I called him to tell him what I had done
and the reason why I did it.
Q. BY MR. NICOLA: Okay. When you finished making these arrangements for the Arvizos
to travel to Brazil, how many days' notice did you give the airline before the flight?
A. Just a couple days.
Q. Okay. The flight was scheduled to leave on what date?
A. March the 1st of 2003.
Q. And you made the reservation on the 25th of February, 2003?
A. That's correct.
Q. What was the cost going to be for that flight?
A. For a party of four, 15,092.
Q. Were you flying them first class?
A. No.
Q. Those are coach prices?
A. Coach. They were open tickets, basically. You know, they're expensive.
Q. Did Mr. Schaffel ask you to do anything with the reservations once they were made?
A. Yes, he did.
Q. What did he ask you to do, please?
MR. MESEREAU: Objection; hearsay.
MR. NICOLA: Same offer of proof, Your Honor.
THE COURT: All right. I'm going to admit this for the limited purpose. Go ahead.
THE WITNESS: To fax over the itinerary. Because they needed passports.
Q. BY MR. NICOLA: If you'd take a look at the board behind you, there appears to be in
the far right, in yellow high lighter, an address for Miss Janet Arvizo that begins at least
with 11520, what I believe is Trent. Do you see that on your original document?
A. I do.
Q. Okay. Was that information provided by Ms. Arvizo or Mr. Schaffel?
A. Mr. Schaffel.
Q. Did you ever speak to Ms. Arvizo about these flight arrangements?
A. Not to my recollect ion, no.
Q. Okay. How about any members of her family?
A. No.
MR. NICOLA: If I may have just a moment, Your Honor. I just have a few more questions,
if that's okay. I don't need the inputs anymore, Judge. Thank you.
Q. Now, with respect to the reservations you made for the Arvizos to travel to Brazil on
March 1st of 2003, assuming they made that flight that left on March 1st, 2003, was there
any requirement for them to make the return flight on the date that you chose?
MR. MESEREAU: Objection. Foundation; calls for speculation.

THE COURT: Overruled. You may answer.

THE WITNESS: No.
Q. BY MR. NICOLA: To your knowledge, would they have been able to stay in Brazil
indefinitely?
MR. MESEREAU: Objection. Relevance; calls for speculation; foundation.
THE COURT: Sustained; foundation.
MR. NICOLA: Okay. I believe I have no further questions at this time, Judge.
THE COURT: Cross-examine?
MR. MESEREAU: Yes, please, Your Honor. If I may, Your Honor, I'm just trying to locate
one book.
THE COURT: Go ahead.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. Miss Montgomery, we have not spoken before, correct?
A. No, we have not.
Q. And as you know, I'm Tom Mesereau, and I speak for Michael Jackson, okay?
A. I understand.
Q. If I say anything that's not clear to you, please don't answer it, just let me know you
don't understand the question, and I'll try and rephrase it, okay?
A. Absolutely.
Q. All right. You are testifying under what is called immunity, correct?
MR. NICOLA: Objection. Misstates the evidence, Your Honor. It's use immunity.
THE COURT: The objection is overruled.
Q. BY MR. MESEREAU: Is that correct?
A. I believe I am, yes.
Q. And you received a grant of immun ity yesterday, true?
A. Verbally, I believe I did.
Q. Okay. And immun ity means you cannot be prosecuted for statements you make in
court today, true?
A. Correct.
Q. Your position was if you did not receive a grant of immunity, you would not testify,
correct?
MR. NICOLA: Objection; relevance.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Is that true?
A. Um, per my lawyer's instructions. That's what he requested.
Q. And who is your attorney?
A. Robert Moore.
Q. And he is from Los Angeles, true?
A. Yes.
Q. Your position, through your attorney, was that unless you were immunized from any
prosecution based on what you said today, you would not testify as a witness, correct?
A. That's what he asked me to do, yes.
Q. And that's what you agreed to do, correct?
A. That's correct.
Q. When your lawyer made that request in this court, you were present, true?
A. Yes.

Q. And to your knowledge, a legal grant of immunity means no one, particularly in the
federal government, can come after you for anything you say today under oath, true?
A. To the best of my knowledge, yes.
Q. And the reason you wanted that legal grant of immun ity is because currently there is
an FBI investigation into allegations that you and others secretly videotaped Michael
Jackson on an Xtra Jet flight, true
A. I am a witness for that case, yes.
Q. My question to you is, the reason you wanted a grant of legal immunity was because
you know the FBI is currently investigating allegat ions that you and others secretly
videotaped Michael Jackson on an Xtra Jet flight, true?
A. I can't answer that yes or no.
Q. Are you saying that you've never heard of any FBI investigation into that subject?
A. No. I've spoken to the FBI voluntarily twice.
Q. Then you're aware of the investigation, correct?
A. Pertaining to the allegation, correct.
Q. Okay. How long have you known Frederic Marc Schaffel?
A. Approximately 20 years.
Q. Have you done business with him before?
A. Yes.
Q. What business have you done with him before?
A. Travel arrangements.
Q. Have you done that for him for 20 years?
A. No.
Q. How long have you made travel arrangements for Marc Schaffel?
A. I couldn't be certain of that.
Q. What's your estimate?
A. Whenever he needed a flight. Ten years, maybe? 15 years?
Q. When did you last talk to him?
A. November 20th, 2003.
Q. Are you aware that Mr. Schaffel is currently suing Mr. Jackson for millions of dollars?
A. Yes.
Q. You also are currently suing Mr. Jackson, correct?
A. Not for millions of dollars. Yes.
Q. You also are currently suing Mr. Jackson, correct?
A. Yes. He's suing me.
Q. Mr. Jackson is suing you for invasion of privacy, correct?
A. I believe so.
Q. Are you represented by counsel in Mr. Jackson's suit against you for invasion of
privacy?
A. I am.
Q. And who is your lawyer on that case?
A. Robert Moore.
Q. And who is representing you in your suit against Mr. Jackson?
A. Mr. Moore.
Q. Okay. Now, you're awar e that if Mr. Jackson is convicted in this case, Mr. Schaffel will
have a much eas ier time winn ing his suit, right?
MR. NICOLA: Objection. Calls for speculation and it's argumentative.
THE COURT: Sustained; speculat ion.

Q. BY MR. MESEREAU: If Mr. Jackson in convicted in this case, you would have an eas ier
time winning your suit, wouldn't you?
A. No, I would not.
MR. NICOLA: Same objection, Your Honor.
THE COURT: Sustained.
MR. NICOLA: Move to strike the answer.
THE COURT: Stricken.
BAILIFF CORTEZ: Your microphone, sir. Your microphone, sir.
Q. BY MR. MESEREAU: The lawsuit Mr. Jackson has filed against you has to do with an
Xtra Jet flight on November 21st, 2003, correct?
A. No, sir. It's November 20th.
Q. Okay. My mistake.
A. But to answer your question, yes.
Q. So November 20th of 2003 was the flight?
A. Yes.
Q. That's the flight that is the subject of controversy in the litigation, true?
A. That's correct.
Q. All right. And you said you last talked to Mr. Schaffel around that time; is that true?
A. Yes, it is.
Q. Mr. Schaffel wasn't on that flight, to your knowledge, true?
A. Yes. No, he was not on that flight.
Q. But you're aware that Mr. Jackson was secretly recorded -A. I learned that after.
Q. -- and videotaped on that flight, true?
A. I learned it after the fact.
Q. Are you the one who made arrangements for Mr. Jackson to fly on that particular
flight?
A. I mad e arrangements like I normally do for him.
Q. And did you make arrangements for Mr. Jackson to fly on an Xtra Jet flight on
November 20th, 2003?
A. Yes, I did.
Q. Did you ever talk to Mr. Schaffel about those flight arrangements?
A. Yes, I did.
Q. And you're aware that not only was Mr. Jackson secretly videotaped on the flight but
someone tried to sell that videotape, right?
MR. NICOLA: Objection. Calls for hearsay and relevance and vague as to someone.
THE COURT: Sustained.
Q. BY MR. MESEREAU: The allegations against you in that case are that Mr. Jackson was
secretly videotaped and recorded and that efforts were made to sell that for profit, true?
MR. NICOLA: Objection; calls for hearsay.
MR. MESEREAU: State of mind, Your Honor.
MR. NICOLA: Then relevance.
MR. MESEREAU: And bias.
THE COURT: The objection is overruled. I'm going to have the question read back so you
can understand the question. (Record read.)
THE WITNESS: I believe so. I have not read the suit against me.
Q. BY MR. MESEREAU: The reservations for that flight were made through a company
called Travel 21, Inc.; is that true?

A. Yes.
Q. Was that your company?
A. I was -- I leased space from that company.
Q. Okay. Well, was the reservation made through the company Travel 21, Inc., to your
knowledge?
A. That's how I did the billing on that particular flight.
Q. But you made those reservations, true?
A. I did.
Q. You directly made those reservations with Xtra Jet, correct?
A. I did.
Q. And at some point before you made those reservations, you were asked to use a
different company, correct?
A. A different billing company or a different plane comp any?
Q. A different plane comp any.
A. Yes, I was.
Q. You insisted on using Xtra Jet, correct?
A. I didn't insist. It was to my client's better -- for his better being.
Q. It was your recommendation that Mr. Jackson fly on Xtra Jet during the flight on
November 20th, 2003, correct?
A. It was my -- I discussed it with Mr. Schaffel and we thought it was in the best interest
of our client to use Xtra Jet, yes.
Q. So you and Mr. Schaffel mad e the arrangements for the flight, right?
A. I mad e the arrangements, but I had discussed it with Mr. Schaffel.
Q. Okay. When did you learn that -- excuse me. Let me rephrase that. When did you first
learn that Mr. Jackson had been secretly vid eotaped and recorded on that particular flight
with Xtra Jet?
A. November 21st of 2003.
Q. To your knowledge, has Mr. Schaffel been invo lved in any efforts to sell that videotape
or audiotape?
A. Not to my knowledge.
Mr. Mesereau, I don't believe there's audio.
MR. NICOLA: Objection, no question pending.
THE WITNESS: Sorry. Okay.
MR. NICOLA: Rules.
Q. BY MR. MESEREAU: Were you going to say you don't believe there's an audio
recording?
A. To the best of my knowledge. I don't know of any audio recording.
Q. But you know of a video recording?
A. I do.
Q. Have you seen it?
A. In the FBI building, yes.
Q. To your knowledge, how long will your grant of legal immunity last for?
A. I have no idea, sir.
Q. You haven't learned through your counsel -MR. NICOLA: Objection.
Q. BY MR. MESEREAU: -- how long you'd be immunized from any prosecution based on
what you say today?
MR. NICOLA: Objection, Your Honor, that is vague.

THE COURT: It violates a privilege.

Q. BY MR. MESEREAU: For -- let me rephrase that. When did you begin booking flights for
Mr. Jackson?
A. I believe in 2000 -- the latter part of 2000. May have been 2001.
Q. You said you met Mr. Jackson twice, correct?
A. Yes.
Q. And where did you first meet Mr. Jackson?
A. On his ranch.
Q. Approximately when was that?
A. September of 2003.
Q. Did you stay at the ranch?
A. Overnight?
Q. Yes.
A. No.
Q. When was the second time you ever met Mr. Jackson?
A. In Las Vegas.
Q. And approximately when was that?
A. And it was several times. October of 2003.
Q. Typically any flights that were booked through you were arranged for someone other
than Mr. Jackson. Excuse me, let me rephrase that. Typically any flights that you arranged
for Mr. Jackson came through, I think you said Evvy or Mr. Schaffel; is that correct?
A. Yes.
Q. Now, how many flights do you think you booked at the direction of Evvy?
A. Ninety-nine percent of them. Private jets.
Q. How many flights do you think you booked at the direction of Mr. Schaffel?
A. One percent.
THE COURT: Do you want to take a break, Counsel?
MR. MESEREAU: Oh, yes, Your Honor.
THE COURT: Sorry for the delay. The court reporters are having a little problem with the
computer that runs their court reporting equipment. Go ahead, Counsel.
MR. MESEREAU: Thank you, Your Honor.
Q. Miss Montgomery, I want to clarify a couple of questions I asked about your grant of
legal use immunity, okay?
A. (Nods head up and down.)
Q. The kind of immunity you've been granted by the Court is called use immun ity, true?
A. Yes.
Q. And use immunity means that anything you say in court today cannot be used against
you, correct?
A. Correct.
Q. You could, however, still be prosecuted for perjury, correct?
A. To the best of my knowledge, correct.
Q. And the grant of use immun ity that you have grew out of concerns about a possible
prosecution over the secret videotaping of Mr. Jackson on that Xtra Jet flight, correct?
A. Yes.
Q. And you were sued by Mr. Jackson and others, correct?
MR. NICOLA: Objection. This has been asked and answered, Your Honor.
THE COURT: Overruled. You may answer.
THE WITNESS: I sued him, and then he sued me back.

Q. BY MR. MESEREAU: You also have been sued by Attorney Mark Geragos who was on
that flight, correct?
A. I believe so. I have not seen, actually, the lawsuit.
Q. Is it your understanding that Mr. Jackson and his then attorney, Mr. Geragos, were
secretly videotaped on an Xtra Jet flight?
MR. NICOLA: I believe that has been asked and answered. Object on those grounds.
MR. MESEREAU: Not with Mr. Geragos, Your Honor.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes.
Q. BY MR. MESEREAU: Okay. And that is, in fact, the flight you booked, correct?
A. I booked the flight.
Q. That's the flight you booked with the assistance of Mr. Schaffel, correct?
MR. NICOLA: Objection, Your Honor, that has been asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Now, you indicated you met Mr. Jackson for the first time in
approximately September of 2003, true?
A. Formally.
Q. Formally?
A. Correct.
Q. When did you first meet Mr. Jackson in person?
A. I've been introduced to him backstage at a concert.
Q. And when was that?
A. I don't recall. Many years ago.
Q. Okay. Do you know how many years ago that was?
A. I couldn't tell you that.
Q. You didn't really have a d iscussion with him at that point, did you?
A. No.
Q. Okay. And were you attempting to try and get Mr. Jackson's business at the time?
A. In September of .03?
Q. The first time you met him.
A. No.
Q. Were you in the travel business at that point?
A. Yes.
Q. Was it ever your goal to obtain Mr. Jackson as a client?
A. When Mr. Schaffel approached me with it, of course.
Q. And when did Mr. Schaffel approach you with the idea of booking flights for Mr.
Jackson?
A. When he became an associate of Mr. Jackson's.
Q. When did Mr. Schaffel first approach you about booking flights for Mr. Jackson?
A. I couldn't recall specifically.
Q. Do you know approximately when it was?
A. It was sometime in the year 2000.
Q. Had you been booking flights for Mr. Schaffel before that date?
A. Yes.
Q. And I believe you said you have booked flights for Mr. Schaffel for approximately,
what, 10, 15 years?
A. I believe so.
Q. Okay. Now, are you the only one, to your knowledge, during that period that was

booking flights for Mr. Schaffel?

A. No.
Q. Were other people booking flights for Mr. Schaffel as well?
A. In my office, or -Q. Anywhere.
A. Well, I can only speak for my office. There was someone else that could have done
them.
Q. And who else could have done it in your office?
A. One of my assistants.
Q. Would you have known about the flight if your assistant did it?
A. Absolutely.
Q. To your knowledge, during the 10 or 15 years that you booked flights -- excuse me.
For the 10 or 15 years that you or your company booked flights for Mr. Schaffel, was it
your understanding that you were the exclusive travel agent for Mr. Schaffel?
A. Absolutely not.
Q. Who else was booking flights for Mr. Schaffel at the time?
A. I'm not privy to that information.
Q. Well, how do you know someone else was?
A. I -- I didn't say that I did. I have no idea. I have no knowledge. Other than in my
office, I said I have no knowledge.
Q. Okay. So as far as you know, during the 10 or 15 years that you or your office booked
flights for Mr. Schaffel, you were the only people doing that, correct?
A. I don't believe that's what I said. I booked flights for him. Somebody in my office could
have booked flights for him. I have no other knowledge if he went through another agency
or directly through the airlines. I have no knowledge of that.
Q. And during those 10 or 15 years, you have booked flights for Mr. Schaffel to Brazil,
have you not?
A. Yes, I have.
Q. You have booked many flights for Mr. Schaffel to Brazil, have you not?
A. I don't -- I mean, without looking at the documents, I'm sure I have.
Q. Why are you sure you have?
A. I recall a few trips.
Q. He has traveled to Brazil extensively through the years, has he not?
A. I believe he has.
Q. How close a friend were you of Mr. Schaffel during the time you had a friendly
relationship with him?
A. We would socialize on occasion. Travel together.
Q. And would that be -- would the socializ ing be in Las Vegas primarily?
A. No.
Q. Where would it be?
A. Hawaii.
Q. Okay. Now, when you met Mr. Jackson at Neverland in September of 2003, Mr.
Schaffel was there, correct?
A. Yes, he was.
Q. And you were there because Mr. Schaffel was conducting a fund-raiser, correct?
A. Yes, he was.
Q. And you were assisting Mr. Schaffel in that fund-raiser, correct?
A. I did.

Q. And Mr. Schaffel arranged for the fund-raiser to take place at Neverland, true?
A. Yes.
Q. Okay. And then you say you met Mr. Jackson about a month later; is that true?
A. Yes.
Q. Okay. And approximately when was that? Was that October?
A. Yes.
Q. And where was that, if you know?
A. Yes, I do. The Four Seasons Hotel in Las Vegas.
Q. Okay. Have you ever spoken to Mr. Jackson on the telephone?
A. No.
Q. When you arranged the flights you testified about earlier, you have never spoke to Mr.
Jackson in any phone call about arranging those flights, true?
A. That's true.
Q. And it was Mr. Schaffel who talked to you about the flight to Brazil that was supposed
to involve the Arvizos, correct?
A. Yes.
Q. Were plane tickets ever purchased for that flight?
A. No.
Q. When did you last talk to Mr. Schaffel about that proposed flight?
A. Sometime probably in February of 2001.
Q. Did you ever talk -A. The year.
Q. I'm sorry.
A. The year. I'm sorry.
Q. Did you ever talk to any member of the Arvizo family about that flight?
A. No. Not that I'm aware of, no.
Q. And at some point you learned that that flight was going to be cancelled, correct?
A. Yes.
Q. And you learned the flight was going to be cancelled before you had a chance to buy
any flight ticket, correct?
A. Yes.
Q. And certainly, it goes without saying, you never sent any bill for any tickets or anything
related to that flight, correct?
A. Correct.
Q. And that's because Mr. Schaffel talked to you about what he wanted, but the flight
never happened, right?
A. He said he had a change of plans.
Q. Okay. Now, around the time the plans were changed, to your knowledge, did Mr.
Schaffel go to Brazil?
A. Yes.
Q. Did you arrange the flight for Mr. Schaffel to go to Brazil?
A. I did.
Q. Did you arrange to purchase the tickets for Mr. Schaffel to go to Brazil?
A. Indirectly.
Q. Okay. To your knowledge, did Mr. Schaffel go to Brazil alone?
A. I don't know.
Q. Okay. And do you know approximately when Mr. Schaffel's flight to Brazil took place?
A. Around the same time. March the 1st.

Q. Okay. Do you remember whether you arranged a round-trip for Mr. Schaffel in March of
2003?
A. I did.
Q. And to your knowledge, did he then return to the United States at some point?
A. I can't swear that he actually took the flight.
Q. Okay. But you bought tickets for him, correct?
A. Indirectly. I made reservations for him.
Q. And to your knowledge, he actually did go to Brazil, right?
A. I can't testify to that, Mr. Mesereau. Sorry.
Q. Okay. Okay. You never learned one way or the other?
A. I can't recall if he did.
Q. Okay. Do you know someone named Cindy Bell?
A. I do.
Q. And who is Cindy Bell?
A. She's a flight attendant for Xtra Jet.
Q. And did you ever make arrangements for Mr. Jackson to fly anywhere with Cindy Bell?
A. Yes, I believe so.
Q. And what are you referring to?
A. A flight -- she was a stewardess on one of his flights.
Q. Had you met her personally?
A. No.
Q. Have you spoken to her on the phone?
A. I have.
Q. And you've also spoken to Lauren Wallace on the phone, right?
A. Yes.
Q. And have you met Lauren Wallace personally?
A. Yes.
Q. Okay. Now, I believe your lawsuit against Mr. Jackson has to do with your using your
credit card to pay for the Xtra Jet flight that he was secretly videotaped on; is that
correct?
A. No.
Q. What is your suit against Mr. Jackson for; how much money?
A. I believe the suit is for $50,000.
Q. Okay. And aren't you claiming in the suit that you charged on your credit card costs
that were -- should have been borne by Mr. Jackson?
A. No.
Q. Well, what are you -A. There's no credit card in question here.
Q. Did you pay for a flight involving Mr. Jackson?
A. I did.
Q. And how did you pay for that flight?
A. In cash.
Q. And was that the flight where he was secretly videotaped?
A. Yes.
Q. And did you actually go to Xtra Jet and give them cash?
A. I did.
Q. And where did you go to Xtra Jet and pay cash?
A. Santa Monica, California.

Q. Did you go to their offices?

A. I did.
Q. Okay. And you personally arranged for that flight, true?
A. I did.
Q. Did you get a receipt from Xtra Jet?
A. I -- I'm not sure. I probably did. At that time -Q. Are you saying -- excuse me. Are you saying you handed $50,000 in cash to Xtra Jet?
A. No, I didn't say that. I hand the lawsuit is a different amount than what I gave Xtra
Jet.
Q. Are you suing Mr. Jackson because you claim you should be reimbursed by Mr. Jackson
for money you spent on his behalf?
A. Correct.
Q. And was the money you claim you spent on his behalf cash that you paid?
A. I have paid part of it, I did that day, part of it in cash.
Q. You say part of it in cash?
A. That's correct.
Q. Okay. Did you give Xtra Jet that cash?
A. I did.
Q. Who did you give the cash to at Xtra Jet?
A. Jeffrey Bohr.
Q. And who is he?
A. The owner of Xtra Jet.
Q. Okay. And was he a friend of yours?
A. I would say more of a business associate.
Q. And you went to Santa Monica to have a meeting with him, true?
MR. NICOLA: Objection. Relevance, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Are you suing Mr. Jackson for money you paid in cash?
MR. NICOLA: Objection, Your Honor. This is -- asked and answered.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Are you suing Mr. Jackson for charges you made on a credit card?
A. No.
MR. NICOLA: Objection; asked and answered.
THE COURT: Overruled. Next question.
Q. BY MR. MESEREAU: Okay. How long have you had a relationship with the company Xtra
Jet?
A. Um, for a couple of years.
Q. And who has been your primary contact at the company called Xtra Jet?
A. Brian -- at the time it was Brian Kranitz.
Q. Okay. And it was your recommendation that Mr. Jackson fly with Xtra Jet, true?
A. No.
Q. Well, it was certainly your recommendation that he fly on Xtra Jet on the day he was
secretly videotaped, true?
A. That's true.
Q. Now, on that particular day when Mr. Jackson was secretly videotaped on Xtra Jet, you
also flew on a different Xtra Jet flight, correct?
A. I did.
Q. And on that particular day, Mr. Jackson was flying from Las Vegas to Santa Barbara,

true?
A. Yes.
Q. And you flew on a separate Xtra Jet flight from Las Vegas to Santa Barbara; is that
correct?
A. Yes. In part.
Q. And other people were with you on your particular flight on Xtra Jet on that day, true?
A. Yes.
Q. Did you arrange for those people to be on that flight with you?
A. Only one.
Q. Did you learn at some point that photographers were on that flight that you were on?
A. No.
Q. Okay. To your knowledge, were any media people on the flight that you were on?
A. No.
MR. NICOLA: Objection, relevance, Your Honor.
THE COURT: Overruled. The answer is in. No. Next question.
MR. MESEREAU: Yes, Your Honor.
Q. Now, the prosecutor has showed you some itineraries that you've testified you used in
your business of making flight arrangements for Mr. Jackson, right?
A. Yes.
Q. And I believe you said that 99 percent of the time Evvy would give you the information
you needed to make those flight arrangements, correct?
A. Yes.
Q. And your understanding was that you would make the flight reservations for Mr.
Jackson, right?
A. Yes.
Q. You'd also make the reservations for others who traveled with Mr. Jackson, right?
A. I would -- she would give me the manifest with their names on it.
Q. Yes. And you would ensure that all of those individuals were allowed to be on the flight
that you booked, right?
A. It was an FAA requirement. I had no -- I couldn't allow or disallow anything.
Q. Well, but the plans for Mr. Jackson and others to fly were primarily made by you, right?
A. I was -- I submitted -- I was given a list, I submitted a list, and I had no control of who
was on that flight.
Q. Well, I don't mean to suggest that. But certainly if you were told by Evvy -A. Uh-huh.
Q. -- that she would like you to make a flight reservation for whatever it may be, let's say
five people, you would arrange for all those five people to be on a particular flight, true?
A. Yes.
Q. Okay. And would the cost billed by Xtra Jet go up the more people that were on the
flight?
A. No.
Q. It was a set fee each t ime, true?
A. Correct.
Q. So if Mr. Jackson were with two people or six people, it made no difference in terms of
cost, correct?
A. Other than the catering, it made no difference.
Q. Okay. And would you arrange the catering as well?
A. Yes.

Q. And are you the person who would arrange for a particular type of food to be served on
the flight?
A. Yes.
Q. All right. And how were you compensated for making these arrangements?
A. Xtra Jet would bill me back.
Q. Okay. And what was your understanding with Xtra Jet as far as what you would be
billed?
A. It was discussed prior to making the
reservations.
Q. Would you -- excuse me. Let me rephrase that. Did you have a set fee that you would
be billed by Xtra Jet or did you negotiate it different ly for each flight?
A. Well, each destination carries its own price -Q. Okay.
A. -- depending on where he was going.
Q. So there was a -- in effect, a form or schedule of what the cost of the flight would be,
depending on where it went, true?
A. Absolutely.
Q. And how were you compensated?
A. I received commission.
Q. Okay. And would the commission be a percentage of the total cost of the flight?
A. Usually, yes.
Q. All right. Now, if Xtra Jet sent you a bill, would you then typically forward that bill to
whoever you thought should pay it?
A. Yes.
Q. And you've indicated that you sent some bills to MJJ Productions, right?
A. Yes.
Q. And you sent some bills to Neverland Valley Entertainment, right?
A. Yes.
Q. Now, the prosecutor asked you some questions about who owns those companies,
correct?
A. Yes.
Q. You don't have any idea whatsoever who actually owns stock or any other interest in
Neverland Valley Entertainment, true?
A. I wouldn't say that that's true at all. I would say I was told about Neverland Valley
Entertainment.
Q. Only by Mr. Schaffel, correct?
A. Yes.
Q. And certainly it was always your understanding that Mr. Schaffel was trying to promote
a relationship with Michael Jackson for his own benefit, true?
MR. NICOLA: Objection. Calls for speculation, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You never spoke to Mr. Jackson about whether he owned any
interest whatsoever in Neverland Valley Entertainment, did you?
A. No.
Q. Your information about Neverland Valley Entertainment came primarily from Mr.
Schaffel, true?
A. And one of the bookkeepers.
Q. How long would you say you were a friend of Mr. Schaffel?

A. I believe I said almost 20 years.

Q. Okay. Did you know whether or not Mr. Schaffel would try and get reimbursed for
anything his company allegedly spent for Mr. Jackson?
A. Yes. Yes.
Q. Did you have knowledge that Mr. Schaffel would sometimes send bills to Mr. Jackson's
accountants?
MR. NICOLA: Objection. Relevance; calls for speculation; lack of foundation.
THE COURT: Overruled. You may answer yes or no.
THE WITNESS: Yes, I have knowledge.
Q. BY MR. MESEREAU: And did you have any knowledge at the time that Mr. Schaffel was
sending bills to Mr. Jackson's accountants for money allegedly spent on the Arvizos?
MR. NICOLA: Objection, Your Honor. That lacks a foundation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you ever learn whether or not Mr. Schaffel was sending bills to
Mr. Jackson's accountants seeking reimbursement for money he claimed he spent on the
Arvizos?
MR. NICOLA: Your Honor, that calls for speculation. Lacks foundation.
THE COURT: Overruled.
THE WITNESS: I know that he -- I'm sorry. I have some knowledge.
Q. BY MR. MESEREAU: Pardon me?
A. I have some knowledge.
Q. Okay. When you sent bills to Neverland Valley Entertainment, your understanding was
that Mr. Schaffel owned some interest in that company, true?
A. Absolutely.
Q. And you also knew that Mr. Schaffel was sending bills to Mr. Jackson's accountants on
behalf of Neverland Valley Entertainment claiming he was owed reimbursement, true?
A. Yes.
Q. And you say, as you sit here today, you've never learned Mr. Schaffel has sued Mr.
Jackson claiming he's owed millions?
MR. NICOLA: Objection, Your Honor. That's argumentative, calls for speculation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: The prosecutor showed you some documents involving travel plans
that came to you from Evvy Tavasci, correct?
A. Yes.
Q. And your understanding was that Evvy Tavasci was a personal assistant to Mr. Jackson,
right?
A. Yes.
Q. And she was employed by MJJ Productions, right?
A. As far as I understood, yes.
Q. And your understanding was that MJJ Productions was a company owned by Michael
Jackson, correct?
A. Yes.
Q. Now, you would often make travel arrangements for Mr. Jackson and members of his
family, true?
A. Yes.
Q. And did you meet other members of his family at any t ime, to your knowledge?
A. Um, cousins.
Q. And who were they?

A. Elijah Jackson. People that were in Vegas.

Q. And to your knowledge, who was Elijah Jackson?
A. I believe to be a cousin or a nephew.
Q. Okay. Did you ever meet Grace R waramba?
A. Yes.
Q. And where did you meet Grace R waramba?
A. Officially on the tarmac in Santa Barbara.
Q. And your understanding was that she was a nanny for Mr. Jackson's -A. Correct.
Q. -- children, correct?
A. Correct.
Q. Did you ever meet his children?
A. I don't recall.
Q. How about Levon Jackson?
A. I can't recall that either.
5 Q. Okay. How about P.K. Jackson?
A. That's one of the children.
Q. P.M. Jackson? Never met them?
A. To the best of my knowledge, no. Best of my recollection, no.
Q. You met the nanny but not the children, right?
A. Right.
Q. And how about Patricia Chavez?
A. No.
Q. But you remember booking flights for these individuals, right?
A. The names are very familiar.
Q. Okay.
A. Sure.
Q. Do you recall making any special arrangements for the dietary needs of his children?
A. Diet -- special dietary needs. Just what Evvy would tell me to order.
Q. So pretty much she made those decisions, not you?
A. That's correct.
Q. She'd forward the information to you, you would then call Xtra Jet and arrange for it to
happen; is that right?
A. Yes.
Q. All right. When did you last book a flight for Mr. Jackson, to your knowledge?
A. November 19th, 2003.
Q. Do you ever remember booking flights for the Cascio family?
A. I do.
Q. Did you ever meet the Cascio family?
A. Just the son.
Q. Okay. Ever meet the parents?
A. No.
Q. To your knowledge, are you the only one in your family suing Mr. Jackson?
A. Yes.
Q. Is it you individually, or your company, or both?
A. As an individual.
Q. Okay. The company did not sue Mr. Jackson; is that true?
A. Yes, that's true.

Q. And when did you file that suit, if you know?

A. I believe 2004.
Q. Was it filed in Los Angeles?
A. Yes.
Q. To your knowledge, is the case currently going forward?
A. Yes.
Q. Okay. Are you familiar with an individual named Michelle Christina?
A. Not that I recall.
Q. How about a company called Oneness, O-n-e-n-e-s-s?
A. Yes.
Q. And when did you first become familiar with a company called Oneness?
MR. NICOLA: I'm going to object, Your Honor. It doesn't appear to be relevant. It's
beyond the scope of direct.
MR. MESEREAU: I will -- I will tie it up, Your Honor.
THE COURT: All right. Overruled.
Q. BY MR. MESEREAU: You get involved in charitable fund-raisers from time to time,
correct?
A. Yes.
Q. Is that part of what your travel company does?
A. I donate through my travel co mpany.
Q. Do you ever help to arrange charitable fund-raisers?
A. Yes.
Q. And is that one of the things your company does?
A. Like I just said, I donate travel for charit ies. 7605
Q. Okay. And you became familiar with a company Oneness while doing just that, right?
MR. NICOLA: I'm going to renew my objection, Your Honor, on relevance grounds.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Are you claiming that because Mr. Jackson owes you money,
you're not going to pay a company called Oneness?
MR. NICOLA: Objection. Your Honor, there's -THE COURT: Sustained.
Q. BY MR. MESEREAU: How many fund-raisers have you been involved in for Marc
Schaffel?
A. One.
Q. Just one?
A. Yes.
Q. Okay. Have you ever assisted in promoting Mr. Schaffel's company in any way?
MR. NICOLA: I'm going to object. Your Honor, this is not relevant.
THE COURT: Overruled. You may answer.
THE WITNESS: I'm sorry?
Q. BY MR. MESEREAU: Have you ever assisted Mr. Schaffel in any public relations efforts
involving his company?
A. His company being Neverland Valley?
Q. Any company he owns.
A. Not that I -- I mean, I'm not sure I'm understanding where -- what the question is.
Have I promoted his company?
Q. Yes.
A. I would say no to that.

Q. Okay. But the fund-raiser you claim you met Mr. Jackson at was a fund-raiser arranged
by Mr. Schaffel, true?
A. Yes.
Q. And you were assisting him with that, true?
A. Yes.
Q. Okay. Were you assisting him in raising money?
A. Yes.
Q. Have you done that on other occasions?
A. Yes.
Q. How many times have you assisted Marc Schaffel in raising money, to your knowledge?
A. Just that one time.
Q. I'm sorry if I misunderstood.
A. Just that one time.
Q. Okay. Never on any other occasion?
A. Not that I'm aware of.
Q. Okay. Have you ever had any kind of a financial interest in any projects involving Mr.
Schaffel?
MR. NICOLA: Objection, Your Honor. It's vague, lacks a foundation and not relevant.
MR. MESEREAU: Bias, Your Honor.
THE COURT: Overruled. You may answer.
THE WITNESS: No.
Q. BY MR. MESEREAU: Have you ever done any business with Mr. Schaffel other than
arranging flights and helping him with that one fund-raiser?
A. Not to my knowledge.
Q. When did you first meet with any representative of the prosecution about your
testimony?
A. Sometime in the year 2004.
Q. Were you contacted by any representative of the prosecution for purposes of that
meet ing?
A. I received a phone call.
Q. Okay. And who called you?
A. I believe it was Lieutenant Jeff K lapakis.
Q. And how many meetings do you think you've had before today with any member of the
prosecution to discuss this case?
A. Specifically the prosecution or the detectives?
Q. Let's start with the prosecution.
A. I met with them -- I just met them last week.
Q. For the first time?
A. Yes.
Q. Were you with your attorney?
A. No.
Q. When did you first notify the prosecution that you would not testify in this trial unless
you were granted legal immun ity?
A. I did not do that.
Q. Who did it?
A. My attorney.
Q. Do you know when he first did that?
A. I can't be certain of that.

Q. Okay. Do you have any idea at all?

A. I think it was Thursday maybe.
Q. Okay.
A. I have no idea.
Q. Okay. Did you ever personally, on your own initiative, call any sheriff to give
informat ion about Mr. Jackson?
A. I did.
Q. And when did you do that?
A. After I saw the 60 Minutes Ed Bradley special.
Q. Okay. Did you then meet with any representative with the sheriff's department?
A. Not at that time, no.
Q. How many times have you personally called the sheriff's department to volunteer
informat ion about Mr. Jackson?
A. About Mr. Jackson?
Q. Yes.
A. I couldn't tell you a numb er.
Q. How many interviews do you think you've had with any representative of the sheriff's
department about Mr. Jackson?
A. Several.
Q. How many do you think?
A. In person, three or four.
Q. Have you ever had any discussion with anyone about what you were going to say in
court today linked to the prosecution?
A. Yes.
Q. Who?
A. Mr. Nicola and the sergeant and the lieutenant.
Q. Did you discuss with Mr. Nico la what questions you were going to be asked in court?
A. Yes.
Q. And did you and he discuss what your responses were going to be?
A. To tell the truth.
Q. Say anything more than that?
A. Just tell the truth. Be honest.
Q. That's all he said, right?
A. To relax.
Q. Okay. So he went over questions he was going to ask you, and all you said in response
was, I'll tell the truth, I'll tell the truth, right?
A. To answer the questions pertaining to the evidence that I am responsible for doing,
correct.
Q. Did you ever discuss with Mr. Nico la of the prosecution the fact that you had legal
immunity?
A. After my attorney called him, I did.
Q. And did you and he ever go over what legal immunity means?
A. Yes. We touched on it.
Q. And when did you do that?
A. I believe that day, Thursday.
Q. Okay. And that would be last Thursday, correct?
A. Correct.
Q. Did you and he discuss any document that gave you legal immunity from being

prosecuted for what you said in court?

A. No.
Q. Did you and your attorney ever meet with Mr. Nicola regarding your grant of legal
immunity?
A. Mr. Nicola was introduced to my attorney yesterday morning for the first time. I wasn't
privy to their conversation.
Q. So you'd never had a meet ing with Mr. Nico la and your attorney present, correct?
A. Not a meeting, no.
Q. Okay. To your knowledge, have you ever been invo lved in any secret ly recorded
telephone conversations concerning this case?
A. Yes.
Q. How many conversations, to your knowledge, have you been involved in that were
secretly recorded?
A. One.
Q. Did you know that conversation was going to be recorded?
A. I was asked to record it, yes.
Q. Was that by the representatives of the sheriff's department?
A. Yes.
Q. And did you call someone knowing that that call was going to be secretly recorded?
A. I did.
Q. Okay. And approximately when was that?
A. 2004, the beginning -- I'm not sure. I'm sorry.
Q. Do you have any idea?
A. Not without reviewing documents, no, sir.
Q. Okay. The round trip that you -- excuse me, let me try and find the right word. You
and Mr. Schaffel discussed a round trip to Brazil involving the Arvizos, correct?
A. Yes.
Q. And you put together an itinerary for that round trip, right?
A. I mad e a reservat ion for that trip.
Q. And in the course of making the reservation, you actually had an itinerary with dates,
correct?
A. Yes.
Q. There was a departure date, true? And there was a return date, right?
A. True.
Q. The trip you were arranging was for how many people?
A. Four.
Q. You separately had arranged a Brazil trip for Mr. Schaffel, correct?
A. Yes.
Q. You arranged a separate trip for Mr. Schaffel around the time that you and he
discussed arranging a trip for the Arvizos, correct?
A. Yes.
Q. And when you used to get tickets for Mr. Schaffel, how wou ld you typically arrange to
pay for those tickets?
A. He would send me a check or put it on his credit card.
Q. Did he ever send you a check invo lving a trip for the Arvizos?
A. I couldn't tell you for sure. I'd have to look at documents.
Q. To your knowledge, was there ever a charge made on any cred it card for a trip to Brazil
involving the Arvizos?

A. Not to my knowledge.
Q. Okay.
A. No.
Q. And at no time did you ever arrange any trip to Brazil for Mr. Jackson, right?
A. That's right.
Q. And at no time did you ever speak to Mr. Jackson on the phone about any trip to Brazil,
right?
A. I've never spoken to Mr. Jackson on the telephone.
Q. And you've never spoken to him in person about any trip to Brazil at any time?
A. That's correct.
MR. MESEREAU: I have no further questions at this time.
THE COURT: Counsel?
MR. NICOLA: Thank you, Your Honor.
REDIRECT EXAMINAT ION BY MR. NICOLA:
Q. Mrs. Montgomery, did you actually review the Judge's order granting you use immunity
during the break?
A. I did.
Q. Okay. And do you understand use immunity does not protect you from lying on the
witness stand; isn't that correct?
A. Absolutely.
Q. You indicated with respect to the events of November 20th of 2004 -- 2003. Thank you
for that -- with respect to the events of November 20th, 2003, you've cooperated with the
FBI?
A. I have on several occas ions.
Q. Okay. And was it your idea to request immunity in this case?
A. No, it was not.
Q. It was your attorney's?
A. Absolutely -- yes.
Q. Were you present in court yesterday when immun ity for you was discussed amongst all
the attorneys and the Judge?
A. Yes, I was.
Q. Did your attorney actually object to that?
A. Yes, he did.
Q. Again, was that your idea or his?
A. It was his idea.
Q. You mentioned that you contacted law enforcement for the first time after seeing an Ed
Bradley 60 Minutes interview?
A. Yes, I did.
Q. Was that broadcast on television?
A. It was.
Q. Was there something about that that caused you to pick up the phone and call the
police?
MR. MESEREAU: Objection; relevance.
THE COURT: Overruled.
Q. BY MR. NICOLA: You may answer.
A. Yes. A statement Mr. Jackson made.

Q. What was that statement?

A. That he was mishandled by the authorities upon his arrest.
MR. MESEREAU: Objection; relevance.
THE COURT: Overruled. It's redirect of questions you asked.
Q. BY MR. NICOLA: Would you answer that question again? I believe you were cut off.
THE COURT: I'll just have the question and statement read back. Read the question and
answer, please. (Record read.)
Q. BY MR. NICOLA: Were you present at his arrest scene?
A. I was -- yes. When he was put into handcuffs, yes, I was.
Q. Was that the tail end of that November 20th flight in 2003?
A. It was close to the tail end of it.
Q. Okay. And you witnessed the events?
A. I did.
Q. Felt what Mr. Jackson said on the television was not true?
MR. MESEREAU: Objection. Move to strike; foundation.
THE COURT: Sustained. It's stricken.
Q. BY MR. NICOLA: Did you see Mr. Jackson being mishandled by anybody?
MR. MESEREAU: Objection. Relevance; foundation.
THE COURT: Sustained.
Q. BY MR. NICOLA: Could you tell us on approximately how many occas ions you contacted
Lieutenant Klapakis?
A. How many times I contacted him? Through the course of this investigation?
Q. Yes.
A. Many.
Q. You talk to him frequent ly, correct?
A. I do.
Q. And did you always relay to him information that you had firsthand knowledge of?
A. I did.
Q. Okay. Did you also relay to him things that you had heard from other sources?
A. Yes, I did.
Q. Did you ever actively try to hide anything from Lieutenant Klapakis when he inqu ired
with you about facts you may know about the case?
A. No, I did not.
Q. Did you hide anything from the FBI when they interviewed you about the November
20th flight?
A. No, I did not.
Q. I'd like to clean something up in your cross-examination. You actually testified that the
flight arrangements you made for the Arvizos to Brazil occurred in 2001. That actually
occurred in 2003?
A. Yes, it did.
Q. Could you take a look at Exhibit No. 848 again, please, and just confirm that?
A. February 25th, 2003.
Q. And the day of their flight was March 2nd?
A. March 1st of 2003.
Q. And you indicated on cross-examination that at some point Mr. Schaffel called you and
said there was a change of plans regarding the Arvizos' trip?
A. Yes, he did.
Q. Do you recall his tone of voice when he spoke with you?

A. I'm not sure I recall his tone of voice.

Q. Do you recall anything about that conversation that caused you to take particular note
of it?
A. Normal for Schaffel's behavior.
Q. Normal behavior for Mr. Schaffel?
A. Uh-huh. I would say yes to that.
Q. Is there anything that can help you pinpoint the date of when he contacted you and
said there had been a change of plans?
A. I don't recall a date that he would have told me to cancel the reservations.
Q. Do you know even whether that occurred after the flight was scheduled to leave?
A. Reservations, if you don't ticket, will fall out of the computer system after -- 24 hours
after the scheduled departure date.
Q. Is there any ind ication on Exhibit 847 of a cancellation date?
A. 848?
Q. 848, I'm sorry.
A. No. They were never physically cancelled.
Q. Okay. The information regarding the address for Mrs. Arvizo -A. Yes.
Q. -- Mr. Schaffel give you that address?
A. Yes.
Q. Would you read that whole address into the record for us, please?
A. Ms. Janet Arvizo, 11520 Trent Court, Calabasas, California 91302.
Q. Okay. And he gave you each part of that address?
A. Yes.
Q. To your knowledge, and with your experience in dealing with securing visas for clients
that travel outside of the country, do you know the different levels of visas that are
available for travel into Brazil specifically?
A. You have to call each consulate every time you book into a country, find out the
specific needs.
Q. And with your contact specifically with respect to Brazil and Mr. Schaffel traveling down
there, did you have knowledge from your contacts with the consulate as to whether they
issued 30- or 60- or 90-day visas?
A. I called to inquire at the time I made the reservations, yes.
Q. So you called to inquire on the Arvizos' reservation as well?
A. I called because they needed passports, so I needed to know how -Q. Do you recall what the length of the visa was they were requesting?
A. I don't recall that.
Q. If you asked for a 30-day visa, but you overextend your stay, do you know what
happens?
A. Well, if -- customs, if they catch you, they will kick you out of the country.
Q. Okay. But they have to catch you first?
A. Yes. They would catch you trying to depart the country, actually. They would see that
your visa had expired, if it did expire.
Q. You mentioned that you secretly recorded on telephone conversation. Do you recall
which detective asked you to do that?
A. Two detectives. One lieutenant, one sergeant.
Q. Okay. And was that something that you did willingly?
A. Yes.

Q. They didn't pressure you or threaten some kind of prosecution against you if you didn't
do that?
A. No.
Q. Has anybody at this table, anybody you've met from law enforcement or the
prosecution, ever threatened you or tried to coerce you and get you to say anything that
was not truthful?
A. No.
Q. Does this grant of use immunity protect you from lying on the witness stand?
A. No, it does not.
Q. Do you understand if you do, you can be prosecuted for perjury, correct?
A. Yes, correct.
Q. Your suit against Mr. Jackson, you are suing for the cost of the flight from Las Vegas to
Santa Barbara, plus other expenses?
A. Correct.
MR. NICOLA: Okay. Your Honor, I have no further questions.
THE COURT: Mr. Mesereau?
MR. MESEREAU: Yes.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. The prosecutor asked you questions about what your attorney said in court yesterday,
right?
A. Yes.
Q. And you were present yesterday when your attorney made those comments on your
behalf, true?
A. Yes.
Q. Your attorney expressed a concern in open court that you might be prosecuted in
Nevada, true?
A. I believe he said that.
Q. Your attorney also expressed concerns that you might be prosecuted in federal court,
true?
A. I believe he said that.
Q. And because of his fear that you might be prosecuted, he didn't want you to testify at
all, correct?
A. It's his job to do that.
Q. Because of his fears that you would be prosecuted, he didn't want you testifying at all,
true?
A. I've had a conversation with my attorney. I don't believe he has any fears of my
prosecution.
Q. Did your attorney express concerns yesterday in this courthouse in your presence and
on your behalf that you might be prosecuted in Nevada and also by federal authorities?
MR. NICOLA: Object. Objection, Your Honor, calls for hearsay and speculation.
THE COURT: Sustained.
Q. BY MR. MESEREAU: It's a concern that you might be prosecuted that resulted in your
demand for a leg al immun ity, true?
MR. NICOLA: Objection; misstates the evidence.
THE COURT: Overruled. You may answer.
THE WITNESS: No.

Q. BY MR. MESEREAU: Your position yesterday in this courtroom was, If I don't get
immunity, I don't testify, right?
A. That was my attorney's position.
Q. But you had nothing to do with that?
MR. NICOLA: Objection, that's argumentative, Your Honor. Calls for hearsay.
THE COURT: Sustained.
MR. MESEREAU: No further questions.
MR. NICOLA: May I inquire, two, from here, Your Honor?
THE COURT: No.
MR. NICOLA: From here?
THE COURT: Yes.
FURTHER REDIRECT EXAMINATION BY MR. NICOLA:
Q. Is it your understanding that if you did something wrong on November 20th you can
still be prosecuted either in Nevada or federal court?
A. Yes, it's my understanding.
MR. NICOLA: Okay. I have no further questions.
MR. MESEREAU: No further questions.
THE COURT: Thank you. May step down.

JEFF KLAPAKIS EXAMINATION

REDIRECT EXAMINATION BY MR. NICOLA:
Q. Do you recognize the document labeled 848 in front of you, Exhibit 848?
A. Yes, I do.
Q. Were you present during a meeting with Cindy Montgomery, Cynthia Montgomery,
where she explained the contents of that document for you?
A. Yes, I was.
Q. Did she explain to you how the address for Janet Arvizo was placed on that bill and who
the source of the information for that was?
A. Yes, she -MR. SANGER: Objection.
MR. NICOLA: It's a yes or no question.
MR. SANGER: I'll withdraw it, as long as he goes no further.
Q. MR. NICOLA: Just yes or no.
A. Yes.
Q. Okay. Are you trained to search for addresses and verify whether or not they exist?
A. Yes.
Q. Does the address listed on 848 for Janet Arvizo in Calabasas exist?
A. No.
MR. NICOLA: Nothing further.
CROSS-EXAMINATION BY MR. SANGER:
Q. You were the officer who first had a formal interview with Miss Montgomery; is that

correct?
A. Yes.
Q. And that was on January 13th, 2004?
A. Well, my first contact with her was in November of .03.
Q. Oh, that's true. Okay. As far as a formal interview, though, you didn't have a fo rmal
interview unt il that time?
A. I've had several interviews with her. I'm not quite sure of the date, sir.
Q. You were aware that prior to that, she had called and volunteered some information.
She had talked to somebody else in the sheriff's department; is that right?
A. Yes.
Q. And as a result of her calling and volunteering information, you then called and talked
to her?
A. Yes.
Q. And you had a rather extensive interview with her; is that correct?
A. Phone interview, yes.
Q. Phone interview. And following that, arrangements were made to meet with her on
January 22nd, 2004, correct?
A. I believe it was in January. But I'm not quite sure of the date.
Q. And that was a date in which you met with 7626 her and with her attorney, Robert
Moore; is that right?
A. Yes.
Q. And she then volunteered information about Mr. Schaffel; is that right?
A. That's correct.
Q. And she volunteered information about other people associated with Mr. Schaffel; is
that correct?
A. Yes.
Q. And she offered to make a pretext telephone call to one of those people; is that
correct?
A. She did agree to do that, yes.
Q. And she made the call and it was tape-recorded for the benefit of the sheriff's
department; is that right?
A. Yes.
MR. SANGER: I have no further questions.
REDIRECT EXAMINATION BY MR. NICOLA:
Q. To your knowledge, Lieutenant, are members of police agencies investigating crimes or
their agents - for example, citizens who agree to work with them - allowed to tape-record
telephone conversations during the course of an investigation?
MR. SANGER: I'm going to object to the form of the question. Calls for speculation, and/or
irrelevant informat ion.
THE COURT: Overruled.
THE WITNESS: Yes, they are.
MR. NICOLA: Okay. Nothing further.
RECROSS-EXAMINATIONBY MR. SANGER:
Q. All right. So just to clarify that under -- your understanding of California law is that if

law enforcement, a peace officer, authorizes somebody to make a call and tape-record it,
that that permits them then to do so; is that right?
A. That is my understanding of California law.
Q. In other words, it would be unlawful otherwise for just an ordinary cit izen to taperecord a telephone conversation without the consent of both parties to the conversation;
is that right?
A. That's correct. You need law enforcement direct ion.
Q. Yes. So there's a law enforcement exception to that rule - all right?
A. Yes.
Q. -- that allows -- that allows law enforcement to tape-record in California, to tape-record
a conversation without the consent of the other party, correct?
A. Yes.
Q. And that's been interpreted to allow a law enforcement officer to empower another
person, a civilian, to make a call and tape-record it without the consent of the other party
as long as law enforcement said it was okay; is that right?
A. That is my understanding of California law, yes.
Q. Okay. And in this particular case, did you -- did your office -- whether it was you in
particular or not, did your office participate in making this pretext call that was taperecorded?
A. I participated in it.
Q. Okay. So this wasn't just saying, If you want to tape-record somebody, go do it. It
was you actually sitting there getting the tape-recorder set up on the phone and having
her place the call in your presence; is that right?
A. That's correct.
Q. Okay. And it was your understanding at that time that she was attempting to be helpful
in the case against Mr. Jackson; is that right?
A. She was helpful in this investigation, yes.
MR. SANGER: Okay. No further questions.
MR. NICOLA: No further questions, Your Honor.
THE COURT: You may step down.

HAMID MOSLEHI EXAMINATION

DIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. What is your occupation, sir?
A. I do still photography and video production.
Q. And what training and experience have you had that qualifies you to -- for that
profession?
A. Training; like what do you mean by that?
Q. Well, I mean, what is your background that qualifies you for that position, to be a
professional photographer and videographer?
A. Well, I majored in art directing, actually. But then now I started, like, experience
hands-on in photography, and then I got into video production, so I became one.
Q. All right. How long have you been a professional photographer/videographer?
A. Since 1990 I would say.
Q. Okay. The microphone I'm going to have you use is the one on the left there, okay?

A. Sorry.
Q. And tell me a little bit about the type of photography that you do and the type -- we'll
start with the type of photography that you do.
A. I do, like, documentaries. I do events. And kind of news style, too.
Q. Okay. When I say photography, I'll -- my intention will be to cover still photography
as well as videography, okay?
A. Okay.
Q. When you say documentaries, are you talking about videos?
A. That's correct.
Q. What about production of videos? Editing, this type of thing? Do you participate in that
activity?
A. Sure. I do, like, pre-production, and then production, and post-production, which
contains some editing work.
Q. Okay. What are the distinctions between pre-editing -A. Pre-production is mostly planning for the production. Production, it's the shooting itself.
And post-production is editing it and putting the final touches together.
Q. Do you have any emp loyees for your business?
A. I hire, like, independent contractors.
Q. On an as-needed basis or -A. That's correct.
Q. Have you ever -- well, let me back up. How do you work with an individual who hires
you in terms of the legal arrangement? Do you ever act as an emp loyee?
A. No. They're mostly independent contractor. Basically they work per project. So I give
them a call, check their schedule. If they are available, then I book them.
Q. And what type of independent contractors do you use? What -A. Freelance people mostly.
Q. But specifically what tasks do you assign them?
A. It could be sound, it could be assisting, it could be lighting, grip, all sort of thing.
Q. What's a grip?
A. A grip is the guy who put, like, stands together or, you know, carries heavy equipment
around, and things like that.
Q. Have you ever been contracted by MJJ Productions for any of your photography work?
A. MJJ Production has used my services from 1996, I believe, till 2003.
Q. And what type of services have you provided to MJJ Productions?
A. Still photography and video production.
Q. How many projects have you worked on with MJJ Productions?
A. I would say between maybe 40 to 50 projects.
Q. And if you can tell me, give me an examp le, or a couple of examples, of the nature of
the work that you do for MJJ Productions.
A. Could you be more specific to that? Like -Q. Well, do you ever receive still photography assignments?
A. Sure.
Q. What type?
A. It could have been a birthday party. It could have been family portrait pictures. It could
have been concert.
Q. Okay.
A. Or documentaries.
Q. Same question for videography.

A. Same.
Q. Same answers?
A. Same answers.
Q. Okay. When you work for MJJ Productions, how do you become aware that there is a
job for you there? Who informs you that MJJ Productions wants to employ your services?
A. Typically I would get a call from Mr. Jackson's personal assistant at MJJ Production. And
basically I would check my schedule. Upon my availability, I would book that job and take
it from there.
Q. What do you understand MJJ Productions to be?
A. I believe it's Michael Joe Jackson Productions.
Q. Okay. Michael Jackson's production company?
A. Yeah.
Q. Okay. And when you say Michael Jackson, you're referring to the gentleman seated in
-- at the table to my right?
A. That's correct.
Q. And when you shoot video work, what type of documentaries? You mentioned that you
would shoot video documentaries. Give me an example.
A. For example, Mr. Jackson would take a trip to London to do -- for, like, a fund-raising
event. And I would shoot basically fans, media, everything that goes around it. And
including the event itself.
Q. Would Mr. Jackson ever personally call you to set up one of these contracts that you'd
do for him?
A. Maybe a few times.
Q. Okay. And when I say contract, I mean you're a contractor, contracted employment?
A. That's correct.
Q. Okay. Did you ever do any public relat ions type of photography for Mr. Jackson?
A. In what sense? Like -Q. Videos or still photographs that were going to be used for public relations purposes.
A. Sure.
Q. How many times, if you can approximate?
A. Maybe 20, 25.
Q. Did you interact with Mr. Jackson when you were shooting those projects?
A. Sure.
Q. Can you tell me what his level of interest was and involvement -- well, let's start with
his interest. When you did those projects, can you characterize how involved -- let's strike
that question. We'll go right to involvement. How invo lved would Mr. Jackson be with you
when you would be shooting a project that was for public relat ions purposes?
A. How involved? Like what -Q. Would he interact with you?
A. Sure.
Q. And what would his level of interaction be in terms of what he wanted concerning the
specific project?
MR. MESEREAU: Objection; vague.
THE COURT: Overruled.
Q. BY MR. AUCHINCLOSS: Do you understand the question?
A. Please repeat that question one more time.
Q. My question is, what would his level of interaction be with you regarding the video
project that you're shooting for public relat ions purposes?

A. Mostly technical. Like lighting, camera angles.

Q. He would talk to you about that?
A. Sure.
Q. All right. Would he tell you what angles he wanted?
A. He would look at the monitor and then make some suggestions as to what he likes it to
be.
Q. What about the finished product? Would he be interested or involved with you
concerning what the finished project would look like?
A. Sure. Sometimes.
Q. All right. Were you ever present when he was shooting a music video?
A. Yes.
Q. What was -- was he involved in that process, if you know?
A. Of the story? Or -Q. The shooting of it. How involved would he be with the part of the project that you
observed?
A. I'm sure he would be involved with the director as far as the story of the music video,
and also with the director of photography for the look of the picture.
Q. As far as the finished product would go, can you characterize Mr. Jackson's level of
interest in terms of how that finished product would come out?
MR. MESEREAU: Objection; vague.
THE COURT: Overruled. You may answer.
THE WITNESS: Very perfectionist, I would say.
Q. BY MR. AUCHINCLOSS: Okay. And why do you say he's a perfectionist?
A. Because he would make comments that would make sense, changes, and using a level
of perfectionism I would say.
Q. Were you familiar with a project that was -- that involved Martin Bashir that was
entitled, Living with Michael Jackson?
A. Say that, your question, one more time.
Q. Are you aware -A. Oh, yes, I am.
Q. -- of a video called Living with Michael Jackson, a documentary?
A. I am.
2 Q. Do you know if Mr. Jackson was involved in
3 the production part of that documentary?
4 A. Production of it?
5 Q. Yes.
6 A. Meaning -7 Q. The cutting, the editing. I'm talking about
8 the whole production. Do you understand the word
9 production?
10 A. I do understand the word production.
11 Q. Okay.
12 A. When you say involved, because Mr. Jackson
13 was the subject of this documentary.
14 Q. I know.
15 A. Now, technically, was he involved
16 technically with it?
17 Q. Yes.

A. In some level.
Q. And what level was he involved?
A. Mostly the look of the camera and the picture.
Q. Okay. And did you participate at all in the making of that video production?
A. The Martin Bashir, right?
Q. Yes.
A. Yes, I did.
Q. In what capacity?
A. I was called from Mr. Jackson's office to 7638 come to Neverland and s upervise a
production or a shoot that is taking place by Martin Bashir. I was -- usually my duties are
to make sure that Mr. Jackson looks good in that monitor or a picture of it. That includes
camera ang les, lighting, other technical things. And that's what my involvement was for
that documentary.
Q. Okay. What does the term personal videographer mean?
A. A personal videographer would be someone who creates video images for another
person.
Q. And is it uncommon in the world of celebrities for celebrities to have their own personal
videographer?
A. Actually, it's called a personal DP. This stands for Director of Photography.
Q. All right.
A. It is common that celebrities have their own DP that they bring on a shoot, because
that person is familiar with that, with the image of that celebrity, and it could help to
create a good-looking picture.
Q. And during the period of time that you worked as a contractor for Mr. Jackson, were
you his personal DP?
A. I worked on certain projects that I acted as a personal DP for Mr. Jackson.
Q. Was there anybody else during that time who was working with him as a personal DP?
MR. MESEREAU: Vague as to time.
MR. AUCHINCLOSS: That's fair.
Q. During -- I believe you said that you began working with him in .97?
A. 1996.
Q. 1996. And when did you finish, stop working with him?
A. I believe early 2003.
Q. Okay. So during that period, are you aware if he had any other personal DPs?
A. At the beginning there was another gentleman that also had the same kind of position.
Q. Uh-huh. And then at some point, did you become the only personal DP for Mr. Jackson?
A. That's correct.
Q. When did that occur?
A. I think towards .97. 1997.
Q. Okay. So from .97 to 2003, were you Mr. Jackson's personal DP?
A. That's correct.
Q. And did you ever travel with Mr. Jackson?
A. Yes, I did.
Q. Did you ever go on tour with Mr. Jackson?
A. Yes, I did.
Q. Did you ever go to places at Mr. Jackson's behest, at his request, to meet him and do
video shoots?
Now, as far as the Martin Bashir video, you said that you participated in -- well, let me

strike that. Did you participate as a personal DP in any of the video shoots involving
Michael Jackson for the Martin Bashir special?
A. Yes, I did.
Q. How many?
A. I'm sorry.
Q. Help yourself.
A. I think three sessions.
Q. Do you know the dates?
A. To my best memory, I think it was July 30th of 2002, July 31st of 2002, and the last
session was mid-January of 2003.
Q. And on these individual shoots, what were your duties?
A. The very first session, I took some still photographs and I hired a crew to do like a
behind-the-scenes footage.
Q. Where was this first one that occurred on July 30th? Where did that shoot take place?
A. At Neverland Valley Ranch.
Q. All right. And you took some stills?
A. That's correct.
Q. Okay. Any video shooting on that day?
A. Yes.
Q. Did you help out with that at all?
A. Well, I hired a crew to do video and sound as a behind the scene, so, yes, there was a
video and the still photography that day.
Q. And as far as the videographer for the actual special, the Martin Bashir special, did you
do the video for that?
A. I help ed Mr. Bashir's crew for lighting purposes.
Q. Okay. So Mr. Bashir had his own crew for that shot -- that shooting, and you assisted
with lighting?
A. Well, yeah, my duty were to light Mr. Jackson.
Q. Did you also help out with camera angles?
A. Yes.
Q. And what's your goal when you try to assist in lighting and camera angles? What are
you trying to do?
A. I try to make my subject the best that they can look.
Q. Okay. What occurred on the 31st -- first of all, let me back up. Where did that shoot
occur?
A. The 31st?
Q. Yes.
A. Neverland Valley.
Q. And what did you do at Neverland Valley on that date?
A. The second day, basically it was supposed to do just -- to be an interview only. So I
helped Mr. Bashir's crew put up lighting. I d id the lighting for Mr. Jackson. And I also
recorded it on a separate camera.
Q. Did you record anything on a separate camera the first day?
A. Well, I had a crew the first day, which they were shooting behind-the-scene footage.
Q. So you had a separate camera both days?
A. They were different cameras, yes.
Q. Okay. And then you had another shoot in mid-January of .03. Where did that shoot
occur?

A. Florida.
Q. Did you -- and I take it you flew to Florida to make that appointment?
A. That's correct.
Q. How did you become aware that that -- on the trip to Florida, how did you become
aware that your services were going to be requested?
A. I believe I received a call from Mr. Jackson's assistant from MJJ Productions, and they
informed me that there's going to be another interview with Martin Bashir of Mr. Jackson
in Florida.
Q. Okay. And what did you do to help out on that particular shoot?
A. Mostly lighting for Mr. Jackson.
Q. Did you do any behind-the-scenes video footage on that?
A. Yes, I did some footage of behind the scene and still photos.
Q. During the course of your work for Mr. Jackson, have you ever shot any videotape of a
family with the last name of Arvizo?
A. Yes, I did.
Q. On how many occasions?
A. Approximately three.
Q. Do you remember the approximate month and year that those three video shoots took
place or -A. Each of them?
Q. Yes.
A. I believe the first one was October of 2000. Or, I'm sorry, the first one was September
2000, if I remember correct ly. The second was -- the second one was October of 2000, if I
remember correctly. And I believe the last one was February 19 of 2003.
Q. Were you present -- well, let me ask you, first of all, did you see the Martin Bashir
special?
A. Living with Michael Jackson?
Q. Yes.
A. Yes.
Q. Did you see the segment in which Gavin Arvizo appears in that documentary?
A. Well, there's two versions. There's an ABC version and a BBC version. I saw the ABC
version.
Q. Okay.
A. And I saw Gavin with Mr. Jackson in a scene.
Q. Were you present when that scene was shot?
A. No, I was not.
Q. Okay. Let's go back to the first video that you did for Mr. Jackson on -- involving the
Arvizo family. You said it was September 2000. What was that shoot about? First of all,
tell me, if you can recall, who contacted you.
A. If I remember correct ly, I received a call from MJJ Productions, Mr. Jackson's personal
assistant, and they informed me that Mr. Jackson wants me to go to Neverland to shoot
some footage.
Q. And you arrived at Neverland?
A. That's correct.
Q. Did you have any crew with you?
A. I believe I had one assistant, if I remember correctly.
Q. And what did you do at Neverland on that particular occasion?
A. I was told by Mr. Jackson to get some footage of Gavin and him walking around at

Neverland.
Q. Is that the first time you met Gavin?
A. I believe so.
Q. Did you meet any other members of the Arvizo family on that trip?
A. His brother.
Q. Do you recall his name?
A. Star.
Q. So tell me how you went about your task of getting video footage. How did that
happen, specifically?
A. I believe I was told by Mr. Jackson to just get some coverage, footage of Mr. Jackson
and Gavin walking around the Neverland.
Q. Were these shoots scripted at all?
A. No.
Q. How did you go about getting this video footage?
A. I would basically decide what angle, how, where, you know, to shoot this footage.
Q. And who would decide the arrangement of the subjects and what the subjects would be
doing?
A. Sometime Mr. Jackson will direct me as far as what shots he wants. But most of the
time he would leave it up to me.
THE COURT: All right. Let's take our break. (Recess taken.)
THE COURT: Counsel?
MR. AUCHINCLOSS: Thank you, Your Honor.
Q. BY MR. AUCHINCLOSS: Mr. Moslehi, where we left off, we were talking about the
September 2000 video that you shot of Gavin and Michael Jackson. Now, my last question
really deals with the -- dealt more with the subject -- what the individual subjects of that
video were doing. First of all, let me ask you, who were the individual subjects in that
video?
A. Mr. Jackson.
Q. Yes.
A. Gavin. I believe there was a shot of three of them, with Star, the brother.
Q. All right. Anybody else who appeared in that video?
A. Not that I remember.
Q. And in terms of what Mr. Jackson was doing in that video, who decided that, what he
was doing, in terms of whether he was standing in a place, walking, that kind of thing?
A. Well, Mr. Jackson asked me to shoot some footage, and while he was walking with
Gavin, I will decide whether to get an over-the-shoulder shot, which is a back shot, or run
in the front and get a front shot.
Q. Okay. I understand that you were in charge of shooting the photography, the video,
and that you made a decision about camera angles, right?
A. Sure.
Q. And but in terms of what Mr. Jackson was doing when you shot those photographs, did
you direct him, or did Mr. Jackson do that on his own?
A. You mean the video, right?
Q. Yes. What he was doing.
A. He was walking with Gavin, I guess.
Q. Did you understand my question?
A. No, I'm sorry. Go ahead.
Q. Who made that decision, what Mr. Jackson was doing, what he did in that vid eo? Who

decided -A. Himself. Mr. Jackson himself.

Q. So you didn't tell him, Go stand over there. And now I want you to walk across -A. No.
Q. Okay. He decided. Let's talk about the second video. You mentioned that was in
October of the same year; is that right? 2000?
A. As I remember, yes.
Q. Who were the subjects of that video?
A. Well, the video was a pilot. A pilot is like a little sample of an idea. Mr. Jackson -- well,
I had a meeting with Mr. Jackson, and he informed me that he likes to do a program
called Neverland Channel.
Q. Okay.
A. Which is like -Q. So this was a little pilot -MR. MESEREAU: Objection. I don't think the witness completed his response, Your Honor.
MR. AUCHINCLOSS: Then I believe we were getting nonresponsive. But -- THE COURT:
Well, you can ask him another question. Go ahead.
Q. BY MR. AUCHINCLOSS: All right. So going back to my original question, who were the
subjects of that video?
A. The host of the video was Star, Gavin's brother.
Q. Okay. And who else appeared in that video?
A. Some other kids, including Gavin, and some animals.
Q. How long did that video take to shoot?
A. A good 16-hour day it was.
Q. 16 hours?
A. Yeah. One day.
Q. Did Star exhibit any natural talent in terms of his ability to host this program?
A. Natural talent meaning?
Q. Talent.
A. Was he be able to do this right, or -Q. Correct.
A. Not really.
Q. Tell me what you mean.
A. Well, first of all, dealing with kids and animal in production is really tough.
Q. Uh-huh.
A. But when you deal with both of them, is just another situation that it's really tough to
shoot. Star did not have enough, I guess, rehearsal or talent to do this video right, so we
had to take a lot of takes and that kind of thing. Is that what -Q. Yeah, that's the question. For instance, how many takes would it take -- how many
different takes would you run before you got a good shot of Star doing what you wanted
him to do?
A. Well, I -- if I remember correctly, I never ended up getting a really good shot that I
was looking for. But it would take like 15 takes, maybe, just to get a little piece so I can
probably fix it in editing and put a piece together.
Q. All right. What were Star's shortcomings, if you could characterize them, in his ability
to be the host of this program?
MR. MESEREAU: Objection; relevance.
THE COURT: Overruled. You may answer.

THE WITNESS: May I answer?

THE COURT: You may.
THE WITNESS: Well, the way he was basically acting in front of a camera, and, you know,
just like his skills, I guess. It wasn't -- it wasn't professional.
Q. BY MR. AUCHINCLOSS: Okay. W ere you the producer of this particular video?
A. Yes, I was.
Q. Okay. Were there any other individuals who were invo lved in this, other than yourself?
A. Crew-wise? Like other
Q. Any fashion.
A. Yes.
Q. Was there a crew?
A. Yes, I hired a crew to shoot this.
Q. What about in the production of it? Was there anybody else who was involved in t he
production of it?
A. Well, production is like really the crew who shoot the footage, or sound, that kind of
stuff. Is that what your question -Q. I mean pre-production -A. Oh, pre-production.
Q. -- production or post-production. Anybody else involved in any production aspect?
A. Well, the pre-production was mostly me and Mr. Jackson.
Q. Okay.
A. Production was me and my crew.
Q. Okay.
A. And post-production was me.
Q. Okay. Was Frank Cascio involved in this production at all?
A. Yes, he was.
Q. In what fashion?
A. Co-producer.
Q. And what does that mean?
A. Like somebody who coordinates things. For example, he would practice with the talent,
in this case Star, go through his lines. That kind of thing.
Q. When you say Mr. Jackson helped you with pre-production, what did you mean by that?
A. As I said, we had a meeting with -- I had a meet ing with Mr. Jackson, and Mr. Jackson
explained to me what he wants to create for this look, or for the story of it. So that's part
of the pre-production.
Q. Okay. D id you go through what was going to be said by Star or the individuals who
were appearing?
A. With Mr. Jackson?
Q. Yes.
A. I -- I don't think so.
Q. Okay. Did you go through what the individual shoots would involve? Any specifics about
what the program -- that program or pilot would be about?
A. We covered certain style of the coverage, if I remember correct ly.
Q. Okay.
A. With Mr. Jackson.
Q. Who is Frank Cascio?
A. Frank is a friend/associate of Mr. Jackson.
Q. Do you know Frank Cascio?

A. Yes, I do.
Q. How long have you known him?
A. I believe I saw him at the tour, which was 1996.
Q. I'm sorry?
A. In 1996, Mr. Jackson did a tour. And if I remember correctly, Frank was there.
Q. Where was that tour?
A. It was a world tour.
Q. Were you present during the entire tour?
A. Yes, I was.
Q. And where did that world tour go?
A. We went to a lot of different countries. I would say 40, 50 countries. 40, 50 countries.
Q. How long did the tour take?
A. It was a year -- well, eight months in a year-and-a-half period.
Q. Was Mr. Cascio there the entire time?
A. On and off.
Q. What percentage of time would you say he was on the tour with Mr. Jackson?
A. I would say maybe 30 percent.
Q. All right. I'd like to show you some photographs at this time. If I may approach, Your
Honor.
THE COURT: Yes.
Q. BY MR. AUCHINCLOSS: All right. Mr. Moslehi, I show you People's Exhibit 338. Can you
identify that for me, please?
A. These are the Arvizo kids, or Star, Gavin and I believe Davellin.
Q. All right. I show you People's Exhibit 844. Can you identify that for me, please?
A. Mr. Jackson and Frank.
Q. Did you take this photograph?
A. I believe I did, yes.
Q. When was that photograph taken?
A. If I remember correct ly, December, November of 2002.
Q. People's Exhibit 27, do you recognize that individual?
A. Yes.
Q. Who is that?
A. I believe his name is Christian Robinson.
Q. People's Exhibit 41, can you identify that ind ividual for me?
A. I believe he's Marlon Brando's son, Miko Brando.
Q. Okay. People's Exhibit 39, can you identify that individual?
A. I believe he's Joe Marcus, the property manager.
Q. Property manager for where?
A. Neverland.
Q. People's Exhibit 42, have you ever met this individual?
A. Yes. His name is Stuart Backum (sic). Something like that.
Q. Okay.
A. He was a spokesman of Mr. Jackson for a short period of time.
Q. Do you recognize this individual in Exhibit No. 23, People's Exhibit 23?
A. I believe he's Brad Miller.
Q. Okay. People's Exhibit 18, do you recognize that individual?
A. Ronald Konitzer.
Q. People's Exhibit 17, can you identify that one for me?

A. Dieter Ron -- Weizner.

Q. People's Exhibit 19?
A. I believe Vinn ie A men.
Q. People's Exhibit 16?
A. Marc Schaffel.
Q. People's Exhibit 845 appears to be a photograph of a number of individuals. Do you
recognize this photograph?
A. Yes.
Q. And what is it a photograph of?
A. Marc Schaffel, Mr. Jackson, and I believe that individual in the back is Rudy. I'm not
sure about his last name. Provencio.
Q. Do you know the other two individuals in the photograph?
A. No, I don't.
Q. Okay. People's Exhibit 846 appears to be a similar photograph. Can you identify that
for me?
A. Yes. Michael Jackson. Nick Carter. Frank. Schaffel.
Q. Frank Cascio?
A. Frank Cascio. Or Schaffel. And Rudy.
Q. Okay. And the other two individuals who you didn't know?
A. I didn't.
Q. Okay. One final photograph of a similar subject. Please identify that. I should say the
second -- the last one I showed was 846. This is 847.
A. I see Mr. Jackson, Marc Schaffel, Aaron Carter and Rudy. And I believe the other
gentleman is Brad Buxer.
Q. Okay. These three photographs, 847, 846 and 845, were you present when these
photographs were shot?
A. Actually, I think these are freeze frames of a video, if I'm correct.
Q. Yes.
A. Yes, I was.
Q. Okay. So you actually observed these shots as they were being taken?
A. That's correct.
Q. And Exhibit 193, can you identify that for me?
A. That's my house.
Q. Okay. That's one of the rooms in your home?
A. That's correct.
Q. Which room?
A. Well, it's a billiard room.
Q. All right. And 194?
A. That's like a living room.
Q. In your home?
A. In my house.
MR. AUCHINCLOSS: All right. Your Honor, at this time I'd like to admit into evidence
Exhibit 847, 846, 845, 16, if it hasn't been admitted, 42, 39, 41, 27 and -- I should say 27
and 844.
MR. MESEREAU: No objection.
THE COURT: All right. They're admitted.
Q. BY MR. AUCHINCLOSS: All right. You mentioned a few names that I'd like to ask you
some questions about. And if I could have the Elmo, Your Honor. First of all, I'll show you

People's Exhibit 844. Is that the photograph that you said you shot of Mr. Jackson and
Frank Cascio?
A. That's correct.
Q. And where was that shot taken? 7657
A. I believe we were at Neverland Valley.
Q. All right. And do you know what the purpose of this shot was?
A. I think it was just documentary.
Q. I show you Exhibit No. 23. You've identified this subject as Brad Miller.
A. That's correct.
Q. Have you met Mr. Miller?
A. Yes, I believe I did.
Q. Where did you meet Brad Miller?
A. At my house.
Q. And when did you meet Brad Miller?
A. I believe it was February 19, 2003.
Q. Exhibit 16, who is that, please?
A. Marc Schaffel.
Q. Exhibit 42?
A. Stuart. Again, I'm not sure what his last name.
Q. How did you meet Stuart?
A. At Mr. Schaffel's house, I believe.
Q. During what time frame? When did you first meet him?
A. I would say between February 10 -- approximately February 10 of 2003 till February 18
of 2003.
Q. Showing you Exhibit 39 at this time, who is that?
A. I believe it's Joe Marcus.
Q. And you know him to be associated how with Mr. Jackson?
A. I believe he's the property manager of Neverland Valley.
Q. Exhibit 41, who is that?
A. Miko Brando.
Q. How did you meet Miko Brando?
A. I believe I met him at Neverland.
Q. People's Exhibit 17 you've identified as Mr. Weizner?
A. Dieter Weizner.
Q. Okay. 18, is that Mr. Konitzer?
A. Ronald Konitzer.
Q. And 27, who is that?
A. Christian Robinson, I believe.
Q. All right. Finally, showing you People's Exhibit 845, you've identified this as a video
still?
A. This is a freeze frame of a video.
Q. Okay. Can I have the laser pointer, please? If you could use that laser pointer, Mr.
Moslehi, and show us, identify for us -- we know Mr. Jackson. You identified Mr. Schaffel
in that photo. And you've also identified two ind ividuals that you could not -- that you did
not recognize. Would you point the photo -- or the laser at those two individuals?
Indicating in the center and indicating to the right corner. And the individual who you've
identified as Rudy, indicating on the left side in the white T-shirt. Showing you 847, please
point out the various individuals in this photograph for us.

A. And name them?

Q. That you recognize.
A. Oh. Marc Schaffel.
Q. Yes.
A. Mr. Jackson.
Q. Yes.
A. Aaron Carter.
Q. Who is Aaron Carter?
A. He's an entertainer or a musician or a singer.
Q. Okay.
A. I believe that's Rudy.
Q. Yes.
A. And I believe that's Brad Buxer.
Q. Okay. Who is Brad Buxer?
A. Mr. Jackson's musical director.
Q. All right. Same question for Exhibit No. 846. Would you identify the subjects in that
photograph?
A. Mr. Jackson.
Q. Yes.
A. Nick Carter.
Q. Who is Nick Carter?
A. Aaron Carter's brother, which is another musician or singer. Entertainer.
Q. All right.
A. I believe that's Frank.
Q. Yes.
A. I believe that's Schaffel.
Q. Uh-huh.
A. And I believe that's Rudy.
Q. Okay. Appearing in the left-hand corner with the T-shirt?
A. That's correct.
Q. And the individuals in the center of the photograph, you don't recognize them?
A. I do not.
Q. All right. Thank you. Okay. Mr. Moslehi, at some time during the early part of 2003,
you said that -- well, let me strike that. In 2003, did you perform some video services for
Michael Jackson in the early part of 2003?
A. Yes, I did.
Q. And I believe you, first of all, characterized that you did some assistance in the Mart in
Bashir documentary in January; is that correct?
A. Mid-January of 2003.
Q. Okay. Subsequent to that, did you perform some more -- some additional video
services for Mr. Jackson?
A. Yes, I did.
Q. All right. And could you describe the first one? First, let me strike that. How many
projects or individual shoots did you involve yourself in at the request of Mr. Jackson for
the remainder of 2003?
A. I would say five or six projects.
Q. Okay. Tell us about the first one. Tell me what -- first of all, what was the subject
matter of the first shoot, the first of those shoots?

A. Well, I believe the very first project, if I'm not wrong, it was the Martin Bashir, which
was -Q. Yes.
A. -- mid-January of 2003.
Q. Yes. And what was the next one?
A. Next one, I believe, was a shoot in Florida which never took place.
Q. Okay. Let's start with that one. Well, let me ask you this, first of all: Prior to that shoot
in Florida, did you do any video -- any other video production between the shoot -between going to Florida and the Martin Bashir documentary?
A. I'm not sure.
Q. All right. Do you recall doing a video shoot on February 5th, 2003?
A. I think there was an interview with Debbie Rowe.
Q. All right. Where did that interview take place?
A. At Marc Schaffel's house. Calabasas.
Q. When did you first learn that that was a project that Mr. Jackson wanted you to shoot?
A. Maybe a day before.
Q. Who informed you of that?
A. I'm not sure. Could have been Mr. Jackson's personal assistant or his new managers.
Q. Okay. Who were his new managers at that time?
A. Ronald and Dieter.
Q. When did you first learn that Ronald and Dieter were Michael Jackson's new managers?
A. I believe I had a meet ing with them in late 2002. I would say November, December.
Q. Uh-huh.
A. And they informed me that they were going to take the management from, I guess, the
beginning of the year.
Q. Did Mr. Jackson ever confirm that, that they were his new managers?
A. Not directly, but somehow indirectly.
Q. What do you mean?
A. Once I called Mr. Jackson to ask him a question, and he asked me to call Dieter.
Q. Okay. Did he indicate what -- who Dieter was, to why he wanted you to call Dieter?
A. Why Mr. Jackson wanted to know -Q. Why Mr. Jackson wanted you to call Dieter. Did Mr. Jackson tell you?
A. Well, I think Dieter had the answer for whatever question I had.
Q. I'm not asking what you think. I'm asking you if Mr. Jackson told you why he wanted
you to call Dieter.
A. He didn't specifically told me why, but he just advised me to call D ieter.
Q. Do you know what the subject matter was? Do you remember the subject matter of
that conversation?
A. I don't remember.
Q. So you were instructed to do a video shoot of Debbie Rowe?
A. That's correct.
Q. And where did that shoot take place?
A. At Mr. -- at Marc Schaffel's house.
Q. Who told you to show up at Marc Schaffel's home?
A. It could have been either Mr. Schaffel or Dieter.
MR. AUCHINCLOSS: Just a moment. (Off-the-record discussion held at counsel table.)
Q. BY MR. AUCHINCLOSS: All right. Going back to this video shoot, what was the purpose
of it?

A. The Debbie Rowe?

Q. Yes.
A. I believe it was like a response for what the Martin Bashir documentary was about.
Q. Had the Martin Bashir documentary aired in the United States at that time?
A. I don't think so. I'm not sure.
Q. All right.
A. If I remember correct ly, that documentary was aired on the 6th of February.
Q. Okay. Did you see the Martin Bashir documentary?
A. Yes, I did.
Q. Where did you see it? W here were you when you saw it?
A. I was in Florida.
Q. Do you specifically remember whether you shot the Debbie Rowe footage before you
went to Florida?
A. I believe, yes. The day before.
Q. The day before?
A. The day before.
Q. All right. So whatever day you went to Florida, the day before that, you shot the
Debbie Rowe footage?
A. That's correct.
Q. Now, tell me, who was at Marc Schaffel's
3 home at the time this footage was shot?
A. There was Debbie, another lady, the interviewer, which I forgot his name, Schaffel,
Christian Robinson, me, and my crew.
Q. And what was Mr. Schaffel's role in this shoot?
A. I believe some sort of producer.
Q. Okay. And specifically what did he do?
A. He would have, like, a questionnaire in h is hand to let the interviewer -- what to ask.
Q. What did this questionnaire look like?
A. Pieces of paper.
Q. Did the interviewer -- who was the interviewer?
A. I forgot his name.
Q. This is the fellow you can't rememb er his name?
A. That's correct.
Q. And the interviewer, did he have any paper in his hands when he was asking the
questions?
A. During the interview, I don't remember seeing him having any paper in his hand.
Q. Would he ever confer with Mr. Schaffel about how this interview would proceed?
A. Prior to this shoot or during the shoot?
Q. At any time.
A. They had some interactions as far as, you know, what kind of questions to ask and so
on.
Q. And how many times did they interact about how this interview was going to be
conducted?
A. Approximately?
Q. If you can recall, yeah, approximately.
A. Six, seven times, maybe.
Q. How many times before the interview started did they have discussions of that nature?
A. I'm not sure.

Q. And this interview, after you finished shooting it, what did you do with the footage?
A. Mr. Schaffel took it.
Q. Did he take it on that day?
A. Yes.
Q. It was in video format?
A. That's correct.
Q. Okay. So you said the next day after that shoot, you went to Florida?
A. That's correct.
Q. What city in Florida?
A. Miami.
Q. And why did you go to Florida?
A. I was informed that there's going to be some sort of video shoot.
Q. Who informed you of that?
A. Either Mr. Jackson's personal assistant or Dieter.
Q. And when you say his personal assistant, do you mean Evvy?
A. That's correct.
Q. How long has Evvy been his personal assistant, as far as you know?
A. Years. Maybe 15 years. Something like that.
Q. Okay. She was his personal assistant when you began in .96?
A. That's correct.
Q. And were you informed of what the nature of this video shoot was going to involve in
Florida?
A. No, I was not.
Q. Were you informed of what type of equipment you would need?
A. Video equipment.
Q. Anything else?
A. Well, I usually take, like, my still camera, too.
Q. Did you have any emp loyees with you?
A. No.
Q. Okay. So tell me the arrangements that you made before you left for Florida, if any.
A. Since I couldn't take anybody with me, if I remember correct ly, I called a rental house,
which they rent equipment and -- video equipment, and booked some equipment so when
I get there, I have the proper equipment that I need. Then basically I grabbed all my
equipment that I could carry by myself and flew to Florida.
Q. Where did you go when you arrived in Florida?
A. I believe one of Mr. Jackson's drivers picked me up and they drove me to Mr. Jackson's
hotel.
Q. Which hotel was that?
A. I don't remember the name of the hotel.
Q. And where did you go when you arrived at the hotel?
A. To my room.
Q. Okay. Did you meet with anybody at the hotel on that day?
A. I met with Dieter and Ronald that day.
Q. Where did that meeting take place?
A. I believe at their room.
Q. And what did that meeting consist of? What was it a meeting about?
A. Mostly about just them taking over the management; they're the new managers, and
the way they liked to conduct business from now on.

Q. Okay.
A. And also we had discussion about my unpaid invoices.
Q. Okay. Did you have some unpaid invoices at that time?
A. I'm sorry?
Q. Did you have some unpaid invoices -A. Yes, I did.
Q. -- that were owed by MJJ Productions?
A. Yes, I did.
Q. What kind of figure are we talking about at that time? How much money was owed to
you, approximately?
A. About $250,000.
Q. How long had you been owed that money?
A. Well, this was like a year and a half worth of unpaid invoices, so it kept adding up.
Q. Would you bill as the invoices would accrue?
A. I'm sorry?
Q. Would you make bills out and send them to Mr. Jackson's company -A. That's correct.
Q. -- as the bills would accrue when you do the work?
A. Yeah, I would finish the work and render an invoice and mail it to Mr. Jackson's office.
Q. So, did you have any discussions with Mr. Konitzer and Mr. Weizner about what you
were to do in Florida?
A. I asked them what the purpose is. I guess they didn't know or they didn't want to let
me know, but I was never informed specifically why I went there. But at one point I was
informed that it's not going to happen.
Q. When did that happen?
A. I believe was either the same day that I got there or it could be the same -- the day
after.
Q. Who told you that it wasn't going to happen?
A. I believe D ieter.
Q. Did you see any other individuals there that you recognized from the previous shoot at
Debbie Rowe's -- at Marc Schaffel's house involving Debbie Rowe there in Florida when
you were there?
A. If I remember correct ly, there were -- I only met with Ronald and Dieter and Mr.
Jackson's bodyguard.
Q. Who was that?
A. At the time I believe it was Mike and another gentleman.
Q. What was the -- what was their involvement, the two bodyguards? What did they have
to do with this meeting?
MR. MESEREAU: Objection; foundation.
MR. AUCHINCLOSS: Maybe I'll start over again.
Q. Was the meeting with the bodyguards separate from the meeting with Mr. Konitzer and
Mr. Weizner?
A. Well, it wasn't a meeting with them, but I met them there. I mean, I saw them there.
Q. Okay.
A. You know.
Q. Did you talk to them?
A. Yeah. Casually.
Q. Did you ever see the individual who was the interviewer in the Debbie Rowe shoot in

Florida while you were there?

A. Not that I remember.
Q. Sorry?
A. Not that I remember -Q. Okay.
A. -- seeing him there.
Q. Did you see Mr. Jackson while you were in Florida?
A. I don't believe I d id.
Q. Did you receive any other instructions while you were in Florida from Mr. Weizner or
Mr. Konitzer?
A. Well, I informed them about having some footage of Martin Bashir, behind-the-scene
documentary. And after discussing certain matters, they advised me to call Marc Schaffel.
Q. Did you call Marc Schaffel?
A. Yes, I did.
Q. While you were in Florida?
A. I believe so.
Q. Did you receive any instructions from Mr. Schaffel?
A. He wanted me to come back to L.A. so I can show him the footage.
Q. Okay. Did you do so?
A. Yes, I did.
Q. When did that occur?
A. I believe the day after.
Q. So you fly back to Los Angeles. You didn't do any photography at all in Miami?
A. No.
Q. And then the next day you meet with Mr. Schaffel?
A. That's correct.
Q. And what did Mr. Schaffel -- what was that conversation about with Mr. Schaffel?
A. If I remember correct ly, I explained to him that I have -- I have certain footage of
behind the scene that I shot during Martin Bashir production, and that I have made some
agreement and arrangement with Dieter and Ronald in regard to usage of this footage,
and they asked me to see you. And then I showed him the footage, and that was it.
Q. Okay. Did you receive any further instructions from Mr. Schaffel during the month of
February concerning any other shoots, video shoots?
A. Some additional footage of Mr. Jackson's family interviews, some of Mr. Jackson's
archival footage and so on.
Q. I'm talking specifically about new video footage that you shot in the month of February
-A. Okay.
Q. -- at the request of Mr. Schaffel. Did you shoot any such video?
A. Well, there was some -- I mean, there were a few projects within the same one project
-Q. Okay.
A. -- which contained footage and creating a new footage of certain people.
Q. Let's begin with what the nature of this new one project was. What was the purpose of
this new one project?
A. Was like -- was a rebuttal documentary of the Martin Bashir documentary.
Q. And who did you take new video footage of for purposes of that documentary?
A. I believe we shot Mr. Jackson's parents, including his brother.

Q. Where did that take place?

A. At the Encino place in California. Mr. Jackson's house. Joe Jackson's house in Encino.
Q. Okay. And do you know what date that video was shot?
A. Approximately February 15.
Q. All right. Any other video footage that you shot for this rebuttal film or this rebuttal
documentary?
A. We're talking new footage, right?
Q. Yes. New footage.
A. Well, we shot some footage of the Arvizo 7674 family, but it never got used. Never got
aired on the FOX.
Q. Okay. So let's talk about that. You were -- were you assigned to shoot video footage of
the Arvizo family for purposes of this rebuttal video?
A. That's correct.
Q. Who assigned you to that task?
A. I believe was Marc Schaffel.
Q. Okay. Do you know?
A. I think it was Marc Schaffel.
Q. Okay. And were you instructed the nature of this video, what this video footage would
be about involving the Arvizo family?
A. Well, this footage were supposed to be used in that rebuttal documentary that Martin
Bashir basically orig inally did. So -Q. Okay. Was this rebuttal film -- did this rebuttal film have a public relations purpose?
A. Sure.
Q. What was the public relat ions purpose?
A. Well, to make Mr. Jackson look good.
Q. Okay. And so what was the purpose -- or let me strike that. Were you ever informed as
to what the purpose of taking video footage of the Arvizo family was? What was the
purpose for taking footage of the Arvizo family?
A. Well, in the Martin Bashir documentary there was a shot of Gavin, I believe, and Mr.
Jackson holding hands, which it created some sort of controversy about it. And we were
trying to show that basically there was nothing between Mr. Jackson and Gavin that they
were saying on the media and news and stuff like that.
Q. I'm not sure I understand. There was nothing that -- that they were saying?
A. Well, just to rebuke (sic) that shot that -- basically Mr. Jackson holding the hand of
Gavin. W e were putting this family in front of a camera just to see what they have to say
and use it in that rebuttal documentary.
Q. Did you discuss this video-shooting with Mr. Schaffel?
A. Of the Arvizo family?
Q. Yes.
A. Sure.
Q. Was it anticipated at all that this video would be a positive thing for Mr. Jackson?
A. Sure.
Q. How so? How was it anticip ated that this was going to be good for -- make Mr. Jackson
look good?
A. Well, the footage that I shot of Martin Bashir during Martin Bashir production, there
were a lot of segments or scenes that Mr. Bashir was 7676 saying -Q. I'm going to interrupt you as not -MR. MESEREAU: Objection to interrupting the witness.

MR. AUCHINCLOSS: It's nonresponsive.

MR. MESEREAU: It is responsive, I believe Your Honor.
THE COURT: It is. I'll allow you to finish the question -- or the answer. Do you want me to
have the part read that you answered?
THE WITNESS: I'm sorry, say that again?
THE COURT: I'm going to allow you to finish your answer. Do you want to hear the first
part of your answer?
THE WITNESS: I forgot what I was talking about.
THE COURT: Read him the part of his answer.
MR. AUCHINCLOSS: I'm sorry, Your Honor, my question dealt with the previous question
of the video of the Arvizos. It was not a general question about the video, the whole
video.
THE COURT: I'll let her read the question.
MR. AUCHINCLOSS: All right. (Record read.)
THE COURT: Now you can finish your answer.
THE WITNESS: (Continuing) -- that Mr. Bashir was saying good thing about Michael
Jackson. 7677
Q. BY MR. AUCHINCLOSS: Okay. I'm going to go back to my -- what I intended to ask or
make. How was the Arvizo family footage anticipated -- how was
4 it anticipated that this would help Mr. Jackson to look good, in your discussions with Mr.
Schaffel?
A. Well, I mean, at that time, I don't think, there was no footage of the Arvizo, but we
were supposed to shoot this footage.
Q. Right. I'm talking about the planning of it. You planned to shoot the Arvizo family,
correct?
A. Correct.
Q. The plan was to do a video, a rebuttal video, that would make Mr. Jackson look good?
A. Overall, the plan of the rebuttal documentary was to make -- basically make Mr.
Jackson look good.
Q. Was shooting the Arvizo family something you did to try and make Mr. Jackson look
good in this rebuttal film?
A. Well, at the time, I d idn't know how the final piece would look, because we were still in
the production phase of this whole production. Once it's edited and you look at it, then
you can, you know, basically decide whether that's going to make him look good or not.
Q. Let's just move on. The -- where was this -- originally where 7678 was this video shoot
to take place?
A. At Neverland.
Q. And whose idea was that?
A. I believe was Marc Schaffel.
Q. Okay. Did you ever go to Neverland to do this shoot?
A. Yes, I did.
Q. When was that?
A. February 19, 2003.
Q. Did you bring any assistants with you, any assistants with you?
A. I took two people, crew, with me.
Q. What time did you arrive at Neverland?
A. I would say late afternoon, early evening. 7:00-ish, kind of. 6:00-ish.
Q. Did you contact any members of the Arvizo family at Neverland that day?

A. I saw the three kids at Neverland, and I told them that, We're supposed to shoot an
interview with you guys.
Q. Okay. The three kids, Gavin, Star and Davellin?
A. That's correct.
Q. Was Janet at Neverland that day?
A. She was not.
Q. Was there any plan to shoot this video with Janet in it?
A. Yes, it was.
Q. So did you make an effort to determine where Janet was?
A. I asked the kids where their mom is.
Q. Okay. What happened next?
A. They said, She's not here.
Q. What did you do after that?
A. I asked them if they know where she is, because we're supposed to set up this lighting
and camera equ ipment and do the interview. They -- I believe they told me that, She's
not here, and they're going to -- I asked them if they can call her to see if she's going to
do it or not, or what's the schedule.
Q. During that period, did you have any contact with Mr. Schaffel concerning this problem
of the mother not being there?
MR. MESEREAU: Objection. Misstates the evidence; move to strike.
THE COURT: Overruled. You may answer.
THE WITNESS: Did I have any conversation with Schaffel? I believe so.
Q. BY MR. AUCHINCLOSS: Okay. Tell me about it. Did you contact Mr. Schaffel?
A. I believe either he called me or I called him. I'm not sure. But there was a conversation
saying that, Janet, the mother, is not here.
Q. And what was Mr. Schaffel's -- did Mr. Schaffel have a solution to this issue?
A. I guess not at -MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: Offered in furtherance.
THE COURT: First of all, that requires a yes or no answer.
MR. AUCHINCLOSS: Okay. Fair enough.
Q. Did Mr. Schaffel have a solution of this issue of Janet not being there where you
intended to shoot the video involving the entire family?
A. Not at the time, I guess. It was just information going back and forth.
Q. Okay. At some point while you were at Neverland, did you talk to Janet Arvizo on the
phone?
A. Yes, I did.
Q. Had you previously met Janet Arvizo?
A. Yes, I believe I did.
Q. Okay. When had you previously met her?
A. Where?
Q. Where, let's say where?
A. At Neverland Valley.
Q. Okay. Was that during one of the shoots that you had done with the Arvizo family
before, the Arvizo kids?
A. The year 2001?
Q. Yes.
A. I don't think so.

Q. Okay.
A. It was maybe a birthday party of Mr. Jackson's kids or things like that.
Q. Okay. Did you make any efforts to get Janet to come to Neverland to do the shoot?
A. If I remember correct ly, I had a conversat ion on the phone with her.
Q. Yes.
A. And I asked her whether she was going to do it or not so that I know what my schedule
would be for that day.
Q. Okay. Did she want to do this video shoot?
MR. MESEREAU: Objection. Foundation; calls for speculation.
MR. AUCHINCLOSS: It's offered -THE COURT: Foundation; sustained.
MR. AUCHINCLOSS: Okay.
Q. Did she describe to you whether or not she was willing to do the rebuttal video shoot?
A. I believe at the beginn ing she was not happy to do this rebuttal video.
Q. Okay. Did she tell you why she didn't -- was not happy about it?
A. Um -MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: Offered for state of mind.
THE COURT: Well, the question is, did she tell you why she was not happy? But without
telling us any more, did she? Did she tell you that, whether or not she was happy?
THE WITNESS: She told me that she's not happy.
THE COURT: Okay. So the Court will allow that for the limited purposes of her state of
mind at that time.
Q. BY MR. AUCHINCLOSS: So my follow-up question, did she tell you -- and this is yes
or no. Did she tell you what she was unhappy about, why she was unhappy about doing
the rebuttal filming or video?
A. I believe yes, she did.
Q. What did she tell you?
MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: Offered for state of mind.
THE COURT: I'll ad mit this, her statement, for the limited purpose of her state of mind,
not the truth of the matter asserted in the statement. You may answer.
Q. BY MR. AUCHINCLOSS: All right. Go ahead and answer that question.
A. Did she tell me why she didn't want to do it?
Q. Yes.
A. She said since -- if I remember correctly, she said since the rebuttal documentary of
Mart in Bashir has aired, her life turned upside down because of the, you know, media and
press following her, and that kind of stuff. And if I remember correctly, she said, The last
thing I want to do is do another video, you know, and expose myself to more hassle.
Q. Did she want her children to be in another video?
A. I'm not sure.
Q. Was that any part of her concern?
A. Yeah, yeah.
MR. MESEREAU: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did you make any efforts to persuade her to make this vid eo?
A. If I remember correct ly, I told her that we're doing this rebuttal documentary and -Q. That's really a yes or no question.

A. I'm sorry, say that again, the question.

Q. Yeah. Did you make any efforts to persuade her to do the rebuttal video, the rebuttal
video involving -A. Yes.
Q. -- this segment?
A. Yes.
Q. And what was your purpose in doing that?
A. So I can get the production done.
Q. Okay. How long did you talk to her on the phone?
A. I would say 20 minutes, approximately 20.
Q. And was that 20 minutes largely -- did that deal with anything other than persuading
her to agree to do the video? Did you talk about anythin else?
A. She talked -- me or her or both parties?
Q. No, you said you were having a conversation. She's reluctant; true? You're persuading
her. Was there anything -- any discussion, other than her coming to do the video, during
that 20-minute phone conversation?
A. Not that I remember.
Q. All right. When you finished the phone conversation, had Janet Arvizo agreed to do
anything?
A. I believe she agreed to do this video finally.
Q. Do you have a specific recollection whether she agreed to it or not?
A. I believe she did.
Q. What did she say? Did she say -- you tell me.
A. I believe she said that she's going to do it. I mean, after we hung up, my
understanding was that this is going to happen at one point.
Q. Where was it going to happen?
A. I didn't know at the time.
Q. So she said she'd do it, but she didn't say she would do it that day?
A. Well, there was not specific conversation about how, when, where it's going to happen.
But I think, if I remember correctly, the conversation end up that it's going to happen. My
understanding, if I remember correctly at the time, was that she's coming to Neverland to
get it done.
Q. Okay. So at the end of the conversation, you believe Janet's agreed and she's going to
come to Neverland to do the film?
A. As I remember, yes.
Q. About what time is it at this point?
A. I would say 9:00-ish, 10:00-ish, at night.
Q. At some point did you learn or decide -- let me strike that, start over. At some point
did you decide that the filming was not going to take place that night at Neverland?
A. I'm sorry, say that again. Me deciding, or -Q. Yes.
A. Well, I was informed it's not going to happen at Neverland.
Q. Okay. Who informed you of that?
A. I believe it was Marc Schaffel.
Q. You believe?
A. Well, Marc Schaffel, I think. It was Marc Schaffel.
Q. And how did you hear from Marc Schaffel that that was not going to take place at
Neverland that night?

A. I believe it was a phone conversation.

Q. So you had -- was this the first phone conversation? Second? You tell me.
A. I believe could be second.
Q. And did you receive some instructions from Mr. Schaffel regarding the filming on that
second phone conversation?
A. If I remember correct ly, he informed me that Janet, the mom, is going to -- is going to
be in L.A. She's in L.A. Therefore, we're going to shoot this in L.A. He asked me if I can
shoot that in my house. I respond to him that if we can shoot it at his house, but then he
said he doesn't want them to remember where he lives. So we ended up shooting at my
house.
Q. Mr. Schaffel said he didn't want who to know where he lived?
A. I believe the family.
Q. So what did you do then?
A. I informed my crew that this production will not take -- this shoot will not take place at
Neverland. I let them know that they should pack the equipment. And then I got the three
kids and we drove back to my house Q. After you spoke to Mr. Schaffel and learned that
the shoot was going to take place at your house, did you have a conversation with Joe
Marcus, the Neverland Ranch manager?
A. If I remember correct ly, I -- when I arrived at Neverland, I let him know why I'm there,
to shoot this interview. Then later, I informed him that it's not going to happen here at
Neverland, it's going to be at my house, and I'm taking the kids with me.
Q. Did you tell him that you were going to do the shoot with the mother and the kids?
A. I believe so.
Q. What was Mr. Marcus's reaction when you told him that you wanted to take the kids off
of Neverland?
MR. MESEREAU: Objection; hearsay.
MR. AUCHINCLOSS: Offered in furtherance.
THE COURT: All right. I'm going to admit it for the limited purposes previously discussed
on the conspiracy issue.
Q. BY MR. AUCHINCLOSS: What did Mr. Marcus tell you when you informed him that -- of
your intent to take the children -A. I believe he said -Q. -- to your home?
A. I believe he said, They're not allowed to leave the property.
Q. You believe that or did -A. I did -Q. Do you remember what he said?
A. I remember he said, They're not allowed to leave the property.
Q. At some point did you confront him with the intent or did you confront him with the
necessity to have the children go down to your home to complete the video shoot?
A. Well, at one point I believe I informed him that the video that we were supposed to
shoot at Neverland, it's not going to take place, and it's going to be at my house.
Q. Uh-huh.
A. So the kids are coming with me.
Q. Did he agree to anything at that time during that first conversation with you in terms of
letting the kids off the property?
A. He agreed?
Q. Yes. Did he agree with you about anything during that first conversation you had with

Joe Marcus where he told you that the kids are not allowed off of the property?
A. What do you mean, did he agree? Do you mean letting them go with me, or -Q. Yes.
A. I don't remember hearing anything from him.
Q. Okay. What did you do then?
A. Then I let the kids know that within, like, 15 minutes we're going to take off, So get
your stuff ready.
Q. What did you do in the next 15 minutes?
A. If I remember correct ly, I went to help my crew so we can pack the car, the equipment
back to the car, and take off.
Q. Did you see Joe Marcus again before you left Neverland?
A. I believe I did.
Q. Did you talk to him about getting the kids off the property?
A. I'm not sure if I had a conversation with him about that, but he saw me leaving.
Q. All right. So you were allowed to leave Neverland when you drove off the property,
when you wanted to leave the property?
A. Yeah, that's right.
Q. And how much time went by between the time that you first told Joe Marcus -- or when
Joe Marcus first told you the kids are not allowed off Neverland and the time that you
actually drove off of Neverland?
A. I would say approximately half an hour.
Q. When you went down to the theater to collect your equipment, where was -- where did
Joe Marcus go, or where was he?
A. I don't know.
Q. Did he come with you?
A. No.
Q. Do you know if he had any conversations with anybody during that meantime?
A. I'm not sure.
Q. All right. So you took the kids, personally you loaded them up in one of the vehicles?
A. That's correct.
Q. How many vehicles?
A. I took two vehicles of mine to Neverland.
Q. Okay. And which vehicle did the kids go in?
A. I had a Suburban for the equipment and the crew, and a B MW for myself, basically.
Q. Okay. Which one did the kids go in?
A. The BMW.
Q. And you drove that?
A. That's correct.
Q. And did you drive straight to your home?
A. That's correct.
Q. About what time was it when you ultimately arrived at your home?
A. Approximately 11:00-ish.
Q. And what did the children do during the drive down from Santa Barbara?
A. We had some little conversat ions, and they went to sleep.
Q. Your home is in Calabasas?
A. West Hills.
Q. West Hills. So you arrived at your home about 11:00. What did you do then?
A. I immediately started loading equipment to the area that I was going to shoot, and let

the kids play with video games and things like that.
Q. Do you have some video games at your home?
A. Yeah.
Q. Some fancy ones?
A. Not really.
Q. Okay. So they played video games?
A. That's right.
Q. All three of them?
A. I guess the guys. She was -- I don't know what she was doing. I don't remember
exactly. But she was there, too.
Q. Did they stay in one area of the house during that period?
A. Yeah.
Q. And were your two assistants still with you?
A. Yes, they were.
Q. Was there anybody else at the house when you first arrived, other than you, your
assistants and the Arvizo kids?
A. No. Just us.
Q. Did someone arrive at the house shortly thereafter?
A. Yes.
Q. Who was that? Who was the first person to arrive?
A. I believe was Christian Robinson, and another gentleman by the name of Paul, which is
an associate of Marc Schaffel.
Q. Had you met Paul before?
A. Yes.
Q. On what occasion?
A. In the year 2001, Mr. Jackson did the project What More Can I Give? And Paul was
involved somehow with that production helping Schaffel.
Q. Did you set up your equipment for the shoot?
A. At my house, yeah.
Q. During that period, did anybody else show up at the house after Christian and Paul
arrived?
A. Another gentleman; I believe was Brad Miller.
Q. Did he arrive by himself?
A. I believe so, yes.
Q. Had you ever seen Brad Miller before?
A. No.
Q. Have you ever seen him since that night?
A. No. On T.V., I guess, once.
Q. And he arrived by himself?
A. I believe so.
Q. Did you have any understanding of what Brad Miller was doing at your home that
night?
A. No. And I remember asking Christian who this guy is, and they said, Don't worry about
it. It's just a private detective.
Q. Have you ever done any video shoots where there was a private detective invited to
watch at a home that the shoot occurred at?
A. No.
Q. Did you ever see Brad Miller do anything that evening?

A. He was walking around my house.

Q. Did anybody else arrive at your home?
A. Vinnie and the mother.
Q. Janet Arvizo?
A. That's correct.
Q. Do you know about what time they arrived?
A. I would say towards midnight.
Q. All right. So how was the preparation going at this point for the video shoot?
A. Well, me and my crew were setting up the lighting. Mainly I'm doing the lighting,
background, sound and that kind of stuff. They're bringing the equipment in. Sorry. And
Janet was getting her makeup done. And the kids were just, you know, playing with
games and stuff like that.
Q. Did anybody do Janet's makeup for her?
A. I don't believe -- she did her own makeup.
Q. And how did you feel at this point about this scene, if you can characterize it in terms
of the time, the people? Was there anything unusual about this?
A. Well, timing was a little -- you know, kind of getting late. Also having Brad Miller in my
house, I didn't really feel comfortable.
Q. Had you met Vinn ie before?
A. Yes.
Q. And prior to the shooting of the video, did you become aware of any problems that
Janet had, any add itional problems that Janet expressed concerning the shooting of the
video?
A. I think there was a problem with the contract or the release that they were asking her
to sign.
Q. Okay.
A. And if I remember correctly, V innie asked me to use my fax machine and that kind of
things.
Q. And you say they were having a problem with her?
MR. MESEREAU: Objection; misstates the evidence.
Q. BY MR. AUCHINCLOSS: Well, I believe you said, ...They were asking her to sign. Who
were they?
A. I believe it was Paul and Vinn ie and potentially Christian Robinson.
MR. AUCHINCLOSS: Okay. So if I could have the Elmo briefly, Your Honor.
Q. I'm showing you again Exhibit No. 194 which you previously identified as your home.
Can you identify that perspective for me?
A. Yeah, this is a view of my living room.
Q. And does this area -- does this photograph depict any area of the part of your home
that was used in the video shoot?
A. That's correct.
Q. Which area? Explain it to me.
A. This is where I set up the background.
Q. Uh-huh.
A. I believe the family were sitting approximately in this area. And my camera was like -it's off of this frame, but about this area.
Q. You've indicated the background was in the center of the carpeting, the carpet, or I
should say rug?
A. Right about there.

Q. And then the seating area was at the front, between the two carpets?
A. About there.
Q. The two rugs. And then your camera was down outside the frame of the picture?
A. Outside this frame.
Q. Below it.Okay. And where were the boys and Davellin during the period of the
downtime when you were preparing the video shoot?
A. That's my T.V. set-up, so that's where they were sitting. It's like a little coffee table and
a little video game stuff.
Q. Where was the discussion that was taking place between Janet, Paul, Vinnie and
possibly Christian?
A. In the other room, which is out of this frame.
Q. Showing you Exhibit 193, would you identify that area?
A. That's, well, like a b illiard room, kind of.
Q. Is that the area you're saying that the conversation took place in?
A. That's correct.
Q. Now, you said you have a fax machine?
A. That's correct.
Q. Where is your fax machine in your home?
A. Upstairs. I have three rooms upstairs, and one of them's an office.
Q. Do you know which of those individuals went upstairs? I believe you said Vinnie went
and used the fax. Anybody else?
A. Not that I remember. I think it was Vinn ie.
Q. Thank you. So how much time passed between the time that Janet arrived at your
home and the time that you started shooting the video?
A. I would say a couple of hours, approximately.
Q. How much time went by in which Janet was -- how long did this discussion take place
between Janet, Vinnie, Paul and possibly Christian?
A. I would say half an hour.
Q. How much time d id it take for you to set up the video equipment?
A. I would say hour to hour and a half.
Q. Did you hear any of the conversation between Janet and these other parties about the
consent form?
A. Did I hear any conversation?
Q. Yeah. You told us the general context of the conversation. Did you hear any specifics
about what the issue was about signing this consent?
A. No, I did not.
Q. Can you tell me what Janet's demeanor was? What was her -- what was her mood like?
How did she act about this?
A. About the -MR. MESEREAU: Objection; foundation.
MR. AUCHINCLOSS: Well, that's fine. I can lay a better foundation.
Q. You mentioned that Janet had a problem with signing the consent form.
A. That's correct.
Q. Why do you say that? What do you base that on?
A. Because I observed that they're looking at the contract, and she was going through it,
and there was some, I guess, words that she was not happy with or the content of this
contract. And then at one point Vinnie asked me to use my fax machine, I guess to get
faxed in or out, to redraft that contract, some sort.

Q. During that period of time that you were observing Janet and these individuals, did you
have a chance to see what her demeanor was like? Do you know what I mean by
demeanor?
A. Yeah, like an attitude?
Q. Yeah. W hat was her attitude like?
A. Um -Q. Did you have a chance to notice that?
A. I was very busy setting up equipment, so I didn't really pay attention to each
individual's, you know -Q. Right.
A. -- attitude or whatever. She was, I guess, normal. I guess. I don't know.
Q. Did she seem happy about it?
A. Um -Q. About this thing they wanted her to sign?
A. She wasn't happy about the assignment, or I mean the contract that she wanted to
sign, as I understood.
Q. So ultimately you do the video shoot?
A. Yes.
Q. Do you know if she signed anything that night?
A. I believe she did.
Q. Did you see her sign something?
A. No, I did not.
Q. Okay. Why do you say you think she did?
A. Because it looks like Marc's people were happy.
Q. Okay.
A. So -Q. So you do the video shoot. Was it a continuous shoot or were there segments?
A. I believe we shot one-hour interview, and each of these professional tapes are 30
minutes. I don't believe there were so many cuts in it, so we continued rolling camera,
basically. Maybe one or two cuts in between, if any.
Q. So how much video footage did you shoot total?
A. I would say approximately an hour.
Q. At the conclusion of the -- of this project, when you finished shooting it, what
happened? After you finished it, you've got the videotape. What happened next?
A. Well, we wrapped equip ment and everybody left.
Q. Okay. Did you see who left with whom?
A. Not specifically, no.
Q. Did you provide the videotape that you had shot to anybody, any member of the group
that had come from -- well, did you give that tape to anybody that night? Let me just put
it that way.
A. No, I didn't.
Q. Did anybody want that tape?
MR. MESEREAU: Objection. Calls for speculation; vague; foundation.
MR. AUCHINCLOSS: I can ask the question a little better.
THE COURT: All right.
Q. BY MR. AUCHINCLOSS: Did somebody ask you for that tape?
A. I believe Paul, Marc Schaffel's associate.
Q. Was there a discussion with Paul about him getting the tape that night?

A. He asked me to turn him -- turn over the tapes to him.

Q. Yes.
A. And I refused.
Q. Did anybody else ask you to turn those tapes over, other than Paul?
A. Maybe Christian.
Q. Okay.
A. I'm not sure.
Q. Why did you refuse to turn the tapes over?
A. Well, first of all, I wanted to make a copy so in case -- as insurance, to have a second
copy of that tape. Also, there was some other issues that were not resolved by then, so I
kind of kept the tape for that.
Q. At the conclusion of the evening, did you spend some time with Janet, any t ime
privately with Janet?
A. Yes, I did.
Q. When did that occur in relationship to the end of the video shoot and everybody
leaving?
A. It was towards the end of when everybody was leaving. At the end of the shoot.
Q. Do you remember who was still at the home at that time?
A. Everybody was there.
Q. Did you have a purpose in meeting her separately?
A. Yeah.
Q. What was your purpose?
A. I -- I remember I gave her, like, a loan.
Q. Okay. What was -- let me back up. During the period of time that you first became
acquainted with the Arvizos to the time of this shoot, how many separate meet ings would
you say you had with the Arvizo family?
A. Including the kids?
Q. Yeah.
A. Six, seven.
Q. Did you get to know them?
A. Yeah.
Q. How did you feel about the Arvizo family?
MR. MESEREAU: Objection. Vague; foundation; relevance.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did you at some point that night decide to give Janet Arvizo a
loan based on your own desire?
A. Did I decide?
Q. Yeah.
A. Yeah.
Q. You did.
A. Yeah.
Q. Did Janet Arvizo ever ask you for any money?
A. No.
Q. Did she ever request anything from you?
A. No.
THE COURT: All right. W e'll take our break now.
MR. AUCHINCLOSS: All right. (Recess taken.)
Q. BY MR. AUCHINCLOSS: Okay. I think where we left off, we were talking about --

THE BAILIFF: Is your microphone on?

MR. AUCHINCLOSS: It is now, yeah.
Q. We were talking about the end of the video shoot and your having this private
conversation with Janet. When you had that private conversation with Janet, did you give
her some money?
A. That's correct.
Q. And I think I've already asked you, did she ever ask you for that money?
A. No.
Q. Whose idea was it to give Janet some money?
A. It was mine.
Q. During that period of time that you were with the Arvizo family, did you form any kind
of affection for this family during this period of time?
MR. MESEREAU: Objection; relevance.
MR. AUCHINCLOSS: Goes to his -MR. MESEREAU: And leading.
THE COURT: All right. The objection is overruled. You may answer.
THE WITNESS: I kind of felt sorry when I -- about the whole family, about Gavin being -you know, being sick, and, you know, close to dying from cancer, and that kind of thing.
So -- and then over the video shoot that we had in, I believe, October 2000, I worked
with Star and Gavin very closely, so we became kind of, you know, buddies -Q. BY MR. AUCHINCLOSS: Okay.
A. -- in a way.
Q. Okay. Were those the reasons why you did this act?
MR. MESEREAU: Objection; lead ing.
MR. AUCHINCLOSS: I'll strike that.
Q. Did what you have just described have anything to do with your decision to give Janet
some money?
A. I'm sorry. Repeat that question one more time.
Q. You just described that you had some affection for Gavin and Star and you were sad
about the hardship of Gavin's cancer. Did your feelings towards the Arvizo family have
anything to do with your decision to give them -- give Janet some money?
A. Yeah.
Q. Okay. And how much money d id you give Janet?
A. $2,000.
Q. Did you envision that she would pay this back some day?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled.
THE WITNESS: Can I answer that?
Q. BY MR. AUCHINCLOSS: Yes, you can answer it.
A. Well, I told her that, This is a loan, a personal loan, from me to you, and pay me
whenever you have the money.
Q. And did you have a date that you envisioned getting this money back by?
A. No. I left it up to her.
Q. During the period of time that you were working on this rebuttal film, and I mean the
entire film, not just the portion with the Arvizos, did you work with -- did you spend any
time at Mr. Schaffel's home?
A. Yes, I did.
Q. What did you do at Mr. Schaffel's home?

A. Mostly rough editing, meaning I wou ld go through Mr. Jackson's archival footage, find
certain footage from concerts to some other material. And while we were creating this
new footages for the interviews, then I wou ld make a rough cut. And then the production
company who was assigned to do this entire video, Brad Lachman Productions, would do
the final edit ing.
Q. During this period of time, did you ever have an opportunity to overhear Mr. Schaffel
talking on the phone?
A. As I remember, there were a couple of times that I had, like, questions that I wanted
to ask Marc Schaffel, and I would walk from the room where we set up the equipment, like
the editing equipment, to his office, and, you know, he would be on the phone or things
like that.
Q. Did you ever hear him making any remarks concerning getting people out of the
country?
MR. MESEREAU: Objection. Leading; foundation; move to strike.
THE COURT: Overruled. You may answer.
THE WITNESS: If I remember correctly, one occasion I walked into the room, and I think I
heard Schaffel saying, We're going to get them out of the country.
Q. BY MR. AUCHINCLOSS: Do you remember hearing that?
A. To my best recollection, yes.
Q. Was there anything about the context of that conversation that struck you as unusual?
A. Not at the time.
Q. Did you know what he was talking about?
A. Not at the time.
Q. Did you know who he was talking to?
A. No.
Q. So at some point you said that during 2003, you were -- you ended your relationship
as Mr. Jackson's personal DP; is that correct?
A. Well, Mr. Jackson stopped calling and using my service.
Q. Okay. Was there a specific date that was associated with that change?
A. I think after that rebuttal documentary, 7707 The Footage You Were Never Meant To
See -Q. Yes.
A. -- I guess after that, basically that was the last project that Mr. Jackson used my
services.
Q. Were you ever terminated?
A. Terminated -- well, they just stopped using my service.
Q. Were you ever informed that your services were no longer required?
A. I received a letter from -Q. That's yes or no.
A. Yes.
Q. Okay. So tell me, do you remember what date that was?
A. I believe it was February 21st of 2003.
Q. And when did The Footage You Were Never Meant To See, that rebuttal video, when
did that air on the network?
A. I believe it was February 20th of 2003.
Q. Did you watch it on T.V.?
A. Yes, I did.
Q. Did Mr. Jackson ever contact you after that?

A. If I remember correct ly, the day after, he called me. Mr. Jackson called me.
Q. And what was the substance of -- what was the purpose of that phone call?
A. He thanked me for my good work.
Q. Did you have any conversations with him -- well, let me strike that. Does Mr. Jackson
still owe you the $250,000 that had been promised?
A. Part of this is paid, but there's still a substantial amount of unpaid invoices that has not
been paid yet.
Q. Did you bring that up with Mr. Jackson?
A. I -- I believe I had one conversation to him about my invoices not being paid. But I had
hundreds of conversation with his personal assistant, his accountant, all his agents,
including his managers, and his lawyers.
Q. Okay. My question is, did you bring that up to Mr. Jackson on the 20th when he called
you -- or was it the 21st -A. The 21st.
Q. -- the 21st when he called you and said you did a good job on the rebuttal video?
A. I believe I mentioned that for the very first time that my invoices are not being paid.
Q. Okay. Later that day, did you receive a communication from Mr. Jackson's attorney?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. Yes, go ahead.
THE WITNESS: Yes, I did.
Q. BY MR. AUCHINCLOSS: What was his name?
A. David LeGrand.
Q. And can you tell me what the substance of that communication was?
MR. MESEREAU: Objection; hearsay.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Can you tell me.... It's offered in furtherance, Your Honor.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Is that the day that you were terminated?
MR. MESEREAU: Objection. Misstates the evidence; move to strike.
MR. AUCHINCLOSS: That's fair.
Q. Is that the day that you were informed -THE COURT: Stricken. Go ahead. Next question.
Q. BY MR. AUCHINCLOSS: Is that the day that you were informed that your services were
no longer required by Mr. Jackson?
MR. MESEREAU: Objection; misstates the evidence.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Were you ever informed that your services were no longer
required by Mr. Jackson?
MR. MESEREAU: Objection; asked and answered.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: When were you informed that your services -- when were you
informed that Mr. Jackson no longer needed your services?
MR. MESEREAU: Objection. Misstates the evidence; leading; move to strike.
THE COURT: Overruled. You may answer.
THE WITNESS: I believe was February 21st, by a letter.
Q. BY MR. AUCHINCLOSS: Okay. How did you receive that letter?
A. By fax.
Q. Was it before or after you spoke with Mr. Jackson on the phone?

A. After.
Q. Did you continue to make any efforts to have your outstanding bill paid by Mr.
Jackson?
A. Yes, I did.
Q. What did you do?
A. I mad e several communications between Mr. Jackson's accountant, managers, personal
assistant, and his lawyer, David LeGrand. I have provided them with my invoices, and I
basically let them know that, you know, my invoices are not being paid and they are due
immed iately. And it was failed.
Q. Did you ever make an attempt to contact Mr. Jackson again personally about your
outstanding invoices?
A. I remember I made a conversation with Mr. Jackson's personal assistant, Evvy, and I
explained to her that my invoices wer e promised to be paid at certain date, and they are
not, and that I'd like to make a meeting with Mr. Jackson to discuss these matters.
Q. So did you attempt to meet with Mr. Jackson?
A. I did.
Q. When was that?
A. The meeting was supposed to be, I believe, February 26th of 2003.
Q. And how did you go about attempting to contact Mr. Jackson on that date?
A. I believe I spoke to Evvy, Mr. Jackson's personal assistant, and I was informed that Mr.
Jackson will come to L.A. from Florida at certain date, and that I can meet with Mr.
Jackson, have a meeting with him and go through these issues.
Q. Did you go to Neverland that day?
A. I did.
Q. And was Mr. Jackson there?
A. When I arrived at Neverland, Mr. Jackson was not there.
Q. What did you do?
A. I talk -- I spoke to, I believe, Joe Marcus, and I told him the reason I'm in Neverland,
to meet with Mr. Jackson. And he informed me that Mr. Jackson is on his way, coming
home right now, so why not just wait for him.
Q. Did you wait for him?
A. Yes, I did.
Q. Did Mr. Jackson show up?
A. I saw Mr. Jackson arriving, yes.
Q. Did he arrive with anybody?
A. I believe with his entourage, like Miko and bodyguards, and I think maybe his own kids.
Q. You previously mentioned Miko, identified his picture. Is he a part of Mr. Jackson's
entourage?
A. Sometimes he travels with Mr. Jackson.
Q. Do you know what his relationship is with Mr. Jackson?
A. I would say friend/associate, some sort. Personal assistant kind of.
Q. All right. So where were you when Mr. Jackson arrived at Neverland?
A. I was wait ing for Mr. Jackson outside the main house in the little catering area, and just
waiting for him so he can -- you know, so I can have this meeting with him.
Q. And did you see him?
A. I saw Mr. Jackson coming in.
Q. Did he see you?
A. I believe he did.

Q. Could he have missed you?

MR. MESEREAU: Objection; calls for speculation.
MR. AUCHINCLOSS: That's fair.
Q. Where were you standing in relat ionship to Mr. Jackson when he walked in his house?
A. Again, I was behind the main house on the north side of the main house. There's a little
catering area, kind of, a little bar kind of. It's not like a liquor bar, but like a little catering
bar area.
Q. Okay.
A. I was just waiting. There were two tables there. I was just sitting and waiting.
Q. Was that in clear view where Mr. Jackson walked?
A. I believe, yeah.
Q. You could see him clearly?
A. Yeah.
Q. How far away were you from him?
A. I would say 30 feet, 40 feet.
Q. Did he acknowledge you?
A. Um, that I'm there?
Q. Yeah. Did he even -- did he acknowledge that you were there in any way?
A. Mmm -MR. MESEREAU: Objection. Foundation; calls for speculation.
THE COURT: Overruled.
THE WITNESS: I don't remember whether he saw me, I mean eye contact or not, but I
felt like that he knows that I'm here.
Q. BY MR. AUCHINCLOSS: Okay. D id he wave, say anything to you, do anything to
acknowledge your presence?
A. Not at that moment.
Q. Did he do it at some other time?
A. Well, I -- I received a call.
Q. Okay. So Mr. Jackson walks inside -- did he go inside his house?
A. He was going inside his house.
Q. Okay. And you were still sitting where you were sitting?
A. That's correct.
Q. What happened after that?
A. They informed me that there's a phone call for me.
Q. How much time passed between the time that Mr. Jackson walked into his house and
you were informed that there was a phone call for you?
A. I would say five to ten minutes.
Q. Did you go inside and take this phone call?
A. Yes, I did.
Q. Who was it from?
A. Evvy called me, Mr. Jackson's assistant.
Q. And what was the purpose of this call?
MR. MESEREAU: Objection. Foundation; hearsay.
THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did you do something after you talked to Evvy?
A. I left the property.
Q. Has Mr. Jackson ever paid you the money he owes you?
A. Not in full.

Q. Have you had to take legal action to try and get your money?
MR. MESEREAU: Objection. Leading; assumes facts not in evidence.
THE COURT: Overruled. You may answer.
THE WITNESS: Yes, I have filed a lawsuit.
Q. BY MR. AUCHINCLOSS: After you terminated or after you stopped working the last time
for Mr. Jackson, did you become aware that you were -- at any time that you were being - that there was surveillance on you?
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled. You may answer.
THE WITNESS: Did I know about surveillance being conducted on me? No.
Q. BY MR. AUCHINCLOSS: Did you give anybody permission to take your video, take
videotapes of you?
A. No.
Q. And prior to your testimony today, did you review a DVD on this computer to my left of
an Exhibit No. 815? Did you review that?
A. Yes, I did.
Q. Is that image an image of you?
A. Yes, it is.
Q. Is that an imag e that you permitted or allowed anybody to take?
MR. MESEREAU: Objection. Leading; foundation.
THE COURT: Overruled. You may answer.
THE WITNESS: No, I did not give permission to anybody to follow me or take pictures of
me.
MR. AUCHINCLOSS: Your Honor, there's one last unpublished portion of 815 that I'd like
to publish for the jury at this time. We've previously ad mitted the rest of that DVD.
THE COURT: All right. Is that on the computer, or is it on -MR. AUCHINCLOSS: That's on the computer, so I'd ask for Input 1. (Whereupon, a
portion of a DVD, Plaintiff's Exhibit No. 815, was played for the Court and jury.)
Q. BY MR. AUCHINCLOSS: Mr. Moslehi, whose vehicle is that? We're looking at a -appears to be a large SUV in the center frame of this picture.
A. It seems to be my vehicle.
Q. And who is the individual that I've stopped -- where I've stopped this video at? Who is
the individual that seems to be approaching that vehicle?
A. It seems to be me.
Q. Okay. (Whereupon, a portion of a DVD, Plaint iff's Exhibit No. 815, was played for the
Court and jury.)
MR. AUCHINCLOSS: That's it. Thank you, Mr. Moslehi. No more questions.

CROSS-EXAMINATION BY MR. MESEREAU:

Q. Mr. Moslehi, my name is Thomas Mesereau, and I speak for Mr. Jackson.
A. Nice meeting you.
Q. Same here. You gave an interview on April 23rd of this year with Sergeant Steve Robel,
correct?
A. Where was this?
Q. I'm not sure where. My understanding is that you were with your attorney, Mr.
Dowling, correct? And you met with Sergeant Steve Robel of the Santa Barbara sheriffs.

Do you recall that recent interview?

A. You said the 24th of 2004?
Q. The date that I have is April 23rd. Do you recall a recent interview with a Santa
Barbara sheriff?
A. Of this year, 2005?
Q. Yes.
A. I believe so.
Q. Okay. And your lawyer was present, correct?
A. I don't remember my lawyer being present.
Q. Is your lawyer's name Mr. Dowling?
A. Alan Dowling.
Q. Alan Dowling, okay. And when -- let me restate all this. You recently interviewed with a
Santa Barbara sheriff, correct?
A. That's correct.
Q. And when do you think that interview was?
A. Recent-recent or -Q. The most recent interview you gave to a Santa Barbara sheriff.
A. The most recent was, I guess, two days ago.
Q. Right. Okay. And to your knowledge, was that with a Sergeant Steve Robel of the
Santa Barbara Sheriff's Office; do you know?
A. I believe I was talking to another gentleman. Maybe he was present in and out or -kind of things.
Q. Okay. Where did the interview take p lace?
A. This interview took place at Santa Barbara District Attorney's Office. 7719
Q. Okay. Do you know if any representative of the Santa Barbara District Attorney's Office
was present at the interview you gave?
A. Yeah. I think, ag ain, at the beginning, I was talking to Mr. Auchincloss. Then Mr. Robel
came in and out.
Q. Okay.
A. And, yeah, Mr. Alan Dowling was there, too.
Q. Right. Okay.
A. Yeah. I'm sorry.
Q. And the purpose of the interview was to inform the prosecution for the first time that
you had given money to Janet Arvizo, right?
A. The purpose of the interview was I guess an overall of what's going to be taking place
in this courtroom -Q. Okay.
A. -- when I take the stand.
Q. And in the interview, you admitted that you now recalled that you had given $2,000 to
Janet Arvizo, right?
A. During that interview, yes.
Q. Yes. And you indicated to the Santa Barbara sheriffs that Janet had not ever directly
asked you for money, right?
A. That's correct.
Q. But you also indicated with your attorney that Ms. Arvizo had described to you her
financial situation from time to time, correct?
A. If I remember correct ly, I had one conversation with Janet Arvizo which took place at
Neverland, and this was right after the Martin Bashir documentary.

Q. Yes.
A. And at that time, there were some discussions as to her life is upside down, and, you
know, she can't work and things like this.
Q. But at some point she led you to believe that her family was having some financial
difficult ies, true?
A. What I understood from that conversation is that she couldn't work and that they had
to, you know, move around because of the media and the press following them.
Q. Right. She led you to believe at one point that she was out of money, right?
A. We never discussed money with her. I mean, she was just explaining to me what has
happened to her since the Mart in Bashir documentary.
Q. But you got the impression at one point that she needed financial assistance, correct?
A. Um, that she needed financial assistance?
Q. Well, let me restate the question.
A. Yes.
Q. In that interview you had with the Santa Barbara sheriffs on April 23rd, 2005, your
lawyer spoke to Sergeant Robel, correct?
A. That's correct. Alan Dowling.
Q. And he did so in your presence, right?
A. That's correct.
Q. And on your behalf, your lawyer indicated that you had learned about Janet Arvizo's
dire financial circumstances, correct?
MR. AUCHINCLOSS: I'm going to object -- I'm going to object as to any comments about
this lawyer as hearsay.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Was one of the -MR. AUCHINCLOSS: And I'll move to strike the question.
THE COURT: It's not necessary. Go ahead.
Q. BY MR. MESEREAU: Was one of the purposes of that meeting for you and your lawyer
to explain why you gave $2,000 to Janet Arvizo?
A. One of -- yes.
Q. And on your behalf, your lawyer did at one point explain why, true?
A. I believe so.
Q. And at some point, it was your belief that Janet Arvizo was out of money, right?
A. Again, if I rememb er correctly, we d idn't specifically talk about money. She was mainly
complaining about her life being upside down because of this Martin Bashir documentary,
and not being able to work.
Q. And the impression you got was that she needed some financial assistance, right?
MR. AUCHINCLOSS: Objection; asked and answered.
THE COURT: Overruled. You may answer.
THE WITNESS: Could you repeat that again, please?
Q. BY MR. MESEREAU: Yes. You got the impression that Janet and her family could use
some financial help. That's why you made a loan, right?
A. Sure.
Q. Okay. You based your conclusion that Janet needed financial help on what she had said
to you from time to time, right?
A. Could you repeat that one more time?
Q. Sure. Let me restate it completely. You didn't just give her $2,000 for no reason, right?
A. That's correct.

Q. You thought she could use it, right?

A. That's correct.
Q. You thought she needed it based on things she had told you about she and her family,
right?
A. Sure.
Q. She didn't directly ask for it at any time, right?
A. No, she never asked for it.
Q. But she led you to believe that their lives had been turned upside down and she
needed some financial help, right?
MR. AUCHINCLOSS: Objection. Compound; misstates the evidence; asked and answered.
THE COURT: Overruled. You may answer.
THE WITNESS: Could you repeat that one more time? I'm sorry.
Q. BY MR. MESEREAU: Yes, okay. At some point -- let me restate the question. I'll
withdraw the previous question.
A. Okay.
Q. At some point after numerous discussions with Ms. Arvizo, you formed the conclusion
that she and her family could use some financial help from you, right?
A. After one conversation with her that night, February 19th, on the phone, I felt that they
could use some financial assistance.
Q. Okay. And because you had reached that conclusion, you gave her $2,000, correct?
A. That's correct.
Q. You called it a loan, but you didn't expect to be repaid, correct?
A. Well, actually, I've been expecting to be paid. But if not, I can live without it.
Q. Okay. I mean, realistically when you gave it to her, did you expect her to repay it?
A. I did.
Q. Did you -A. I mentioned, This is not a gift. It's a loan. It's from me.
Q. Okay.
A. And pay me whenever.
Q. Okay. And has she ever repaid it?
A. No.
Q. Okay. Now, is the conversation where you spoke to her and then concluded she could
use some financial help the 25-minute conversation?
A. Approximately.
Q. Okay. And to your knowledge, where was Janet Arvizo when you had this
approximately 25-minute conversation?
A. At what location she was, you mean?
Q. Yes. If you know.
A. I don't remember.
Q. And did she call you?
A. No.
Q. Did you call her?
A. No.
Q. Where were you when you had the 25-minute conversation?
A. At Neverland.
Q. Okay. And do you know approximately what date that conversation took place?
A. I believe it was February 19, 2003.
Q. Okay. So the impression you got that Janet could use a little help was formed before

the rebuttal video was filmed at your home, true?

A. That's true.
Q. The rebuttal video was filmed at your home the next day, right?
A. Well, the morning after.
Q. Okay.
A. Once, you know, it goes over midnight, the date changes.
Q. Now, are you familiar with a company called I Films, Inc.?
A. That's my company.
Q. Is that still your company?
A. Yes, it is.
Q. And the services you provided to either Mr. Jackson or Mr. Jackson's company has been
on behalf of I Films, Inc., right?
A. That's correct.
Q. Okay. And that's a corporation, obviously, right?
A. That's correct.
Q. Okay. And I believe you said you've been providing services for Mr. Jackson for a long
time, correct?
A. From 1996 to 2003.
Q. Okay. All right. And when you've provided services for Mr. Jackson, you have
periodically gone to different locations to provide the service, correct?
A. That's correct.
Q. And you have typically sent an invoice not long after you provide the service, right?
A. That's correct.
Q. All right. At some point you dealt with a company called Brad Lachman Productions,
Inc., right?
A. That's correct.
Q. And to your knowledge, who is Brad Lachman Productions, Inc.?
A. It's a production company that FOX hired to put the rebuttal documentary together.
Q. Okay.
A. Final edit ing.
Q. And was it your understanding that that rebuttal documentary was being done by FOX
Television?
A. What do you mean, by FOX Televis ion?
Q. Well, you ment ioned FOX, correct?
A. Yeah, it was supposed to be aired by FOX.
Q. And to your knowledge, was FOX involved in the production in any way?
A. Could have been.
Q. Okay. When you were doing the filming, was it your belief that FOX was somehow
involved at that point?
A. Well, I never met anybody from FOX Television to discuss certain matters, but most of
the communications came from Brad Lachman Productions.
Q. Okay. And you signed an agreement with Brad Lachman Productions on approximately
February 14th, 2003, right?
A. I don't remember.
Q. Would it refresh your recollection if I just show you that document?
A. Sure.
MR. MESEREAU: May I approach, Your Honor?
THE WITNESS: Okay.

Q. BY MR. MESEREAU: Have you had a chance to look at that document?

A. I never been provided with that document.
Q. But do you see your signature on the document?
A. It seems to be my signature.
Q. Okay. Do you recall what the purpose of that document was?
A. There was an interview of me being used in that rebuttal documentary.
Q. Okay. And when you were interviewed, who did your interview, if you know?
A. Brad Lachman Productions. 7728
Q. Okay. Did they choose an interviewer to actually interview you?
A. I believe they d id.
Q. And do you recall where your interview took place?
A. In a hotel.
Q. Okay. And was that prearranged by somebody?
A. I believe so.
Q. Okay. And I gather the purpose of that interview was to allow you, who had known
Michael Jackson, to say good things about him?
A. Well, actually that interview was supposed to be the rebuttal, to be used for the
rebuttal documentary that we were working on titled, Footage You Were Never Meant To
See.
Q. Right.
A. To respond to some of the comments that Martin Bashir made.
Q. And the reason you were interviewed was that when Mart in Bashir was filming his
interview with Michael Jackson, you were also filming that interview, true?
A. That's correct.
Q. And Bashir had arranged to film the interview separate and apart from what you were
doing, right?
A. There were two different cameras and two different angles.
Q. Yes. And you were filming it at the request of Mr. Jackson, right?
A. No.
Q. Who were you filming it at the request of?
A. Myself. There was no request as far as me recording it. I decided on my own.
Q. But certainly Mr. Jackson knew you were there, right?
A. Yes.
Q. And you were right next to Mr. Jackson doing your filming while Bashir was doing his
filming of Mr. Jackson, right?
A. That's correct.
Q. And your intention was to make sure you had a full copy of all the questions and
answers between Bashir and Michael Jackson?
A. Repeat that question one more time.
Q. Yes. Maybe I wasn't clear on that. Your intent was to try and film a complete copy of
the interview between Bashir and Michael Jackson, right?
A. Actually, my intention was just to document this interview on my camera.
Q. Yes, okay. And one of the purposes was not to allow Bashir to have exclusive
possession of what he had done in that interview, right?
A. Would you repeat that one more time?
Q. Sure. I'm sorry if I'm unclear. If you hadn't filmed Mr. Bashir's interview with Michael
Jackson, logic suggests that the only person that would have had a copy of that interview
would have been Bashir, right?

A. Well, you see, there were like two different cameras, one single scene. So meaning if
there was not my camera in there -Q. Yes.
A. -- the only other camera that would have been in there would have been Mart in
Bashir's camera.
Q. Yes. And if that had been the case, Mr. Bashir could have selectively used, or not used,
whatever parts he wanted and he would have had control of all the product, right?
A. Yes.
Q. And when you saw the Bashir documentary, you knew that there were parts where Mr.
Bashir had said positive things about Michael Jackson that he had left out of his
documentary, right?
A. That's correct.
Q. And the reason you were being interviewed by Brad Lachman Productions was because
the intention was to have some of those parts that you had filmed appear in the rebuttal
video, right?
A. That's -MR. AUCHINCLOSS: I'm going to object; relevancy and beyond the scope. 7731
MR. MESEREAU: I believe he opened the entire door, Your Honor.
THE COURT: The objection's overruled.
Q. BY MR. MESEREAU: In fact, the title of that documentary on televis ion was, The
Michael Jackson Interview: The Footage You Were Never Meant To See, right?
A. That was the title of the rebuttal video,that's correct.
Q. And the words The Footage You Were Never Meant To See were supposed to apply to
footage you had?
A. That's correct.
Q. That Bashir had never used, right?
A. That's correct.
Q. That included footage where Mr. Bashir was complimenting Mr. Jackson on what a
parent he was, right?
A. That's right.
Q. Compliment ing Mr. Jackson on what a good person he was, right?
A. That's correct.
Q. He was complimenting Mr. Jackson on his wonderful role in the world involving
children, right?
MR. AUCHINCLOSS: Objection; hearsay.
THE COURT: Overruled.
Q. BY MR. MESEREAU: Right? 7732
A. Do I answer?
THE COURT: Yes.
THE WITNESS: Yeah.
Q. BY MR. MESEREAU: He had footage about Mr. Jackson wanting an internat ional day in
honor of children, right?
A. I'm sorry. Say that again.
Q. Mr. Bashir, in his interview, talked to Mr. Jackson about Mr. Jackson's desire to have a
day around the world in celebrat ion of children, right?
A. Yeah.
Q. And your belief at that time was that Mr. Bashir had presented a very distorted view of
that interview with Mr. Jackson, correct?

MR. AUCHINCLOSS: Objection; calls for a conclusion.

MR. MESEREAU: State of mind, Your Honor.
MR. AUCHINCLOSS: Relevance.
THE COURT: Overruled. You may answer.
THE WITNESS: Say that one more time.
Q. BY MR. MESEREAU: Yeah, I'm sorry. Sorry. Your role in the televis ion show titled, The
Michael Jackson Interview: The Footage You Were Never Meant To See, was to talk about
the footage you had in that interview that Bashir didn't use, right?
A. That's correct.
Q. And that was footage that was very positive about Mr. Jackson, true?
A. Most of Martin Bashir's comments were positive.
Q. Yes. And the agreement you signed with Brad Lachman Productions related to the fact
that you yourself were going to appear in that documentary, right?
A. That's correct.
Q. So your role in that documentary was not just filming people. It was actually appearing
yourself, right?
A. At one point, yes. I basically did an interview to appear in that with the permission of
Mr. Jackson.
Q. Okay. That's why you signed an agreement with Brad Lachman Productions, Inc., right?
A. Just for that interview.
Q. Yes.
A. For my interview, yes.
Q. Okay.
A. Not the footage.
Q. But the consent was to use your likeness and your words in the show, right?
A. My imag e, my voice in the show.
Q. Yes. Okay. And you signed that on February 14th, 2003, right?
A. Again, I don't -- I don't think I have the copy of that, but if that's what it says, I believe
so.
Q. Okay. And that is what it says, and you think that's accurate?
A. I'm sure. If you tell me, I believe you.
Q. Okay. You believe that's accurate, the date I showed you, right?
A. I didn't pay attention to the date. I was just looking at my signature.
Q. Would it refresh your recollection just to see the date?
A. Sure.
MR. MESEREAU: May I approach?
THE COURT: Yes.
THE WITNESS: Sure.
Q. BY MR. MESEREAU: Have you had a chance to look at the document?
A. No. (Laughter.)
THE WITNESS: Oh, right now? Oh, I'm sorry. I thought you were talking about the entire
thing.
Q. BY MR. MESEREAU: Okay. Have you had a chance to look at the date on the document?
A. I looked at the date of the document just right now, yes.
Q. And does it refresh your recollection that it was signed on February 14th, 2003?
A. I believe so.
Q. All right. Now, I gather from what you've said that you decided at some point that your
role in this rebuttal documentary titled, The Michael Jackson Interview: The Footage You

Were Never Meant To See, was to be both participant and help film portions of it, right?
A. Would you repeat that one more time?
Q. Yeah, and I think -- I think you've said this. You were both interviewed to appear in it,
and you also were doing footage yourself?
A. Sure.
Q. Okay. Okay. And I believe you told the prosecutor that the footage you took of the
Arvizos you decided to retain yourself at some point, right?
A. Well, I -- well, what happened is, it remained in my possession and it was not turned
over that night.
Q. Okay. Okay. And one of the reasons was you wanted to make sure you got paid, right?
A. One of the reasons, if I remember correct ly, was that Mr. Jackson's managers, his
agents, they promised me certain things.
Q. Right.
A. And they did not fulfill their promise.
Q. So you thought you would get paid either that night or the next day, right?
A. Yes.
Q. And that didn't happen?
A. That didn't happen.
Q. So you were retaining control of the video to make sure you were paid properly, right?
A. Well, I figured I did everything that I promised them, but they not fulfill their promise,
so I'm going to stop doing whatever I was doing until I get paid.
Q. Okay. Now, how many interviews did you do yourself to help prepare the rebuttal
show?
A. How many interviews I shot, or -Q. Yes, how many did you shoot? You, yourself.
A. Of other people?
Q. Yes.
A. For that rebuttal documentary?
Q. Yes. You did the Arvizos, obviously.
A. We did Arvizos. We did Mr. Jackson's parents. I believe Debbie Rowe.
Q. Okay.
A. Mr. Jackson's makeup artist.
Q. That's Karen Faye?
A. Karen Faye.
Q. Okay.
A. That's what I remember right now.
Q. Do you recall whether or not you did an interview with Mr. Jackson's physician? Pardon
me, I'm sorry, that's not -- that's not phrased well. Do you recall whether or not you
filmed any footage of an interview with Mr. Jackson's physician?
A. Do you have a name? Because Mr. Jackson has a lot of physicians.
Q. Do you recall doing anything like that?
A. No.
Q. Okay.
A. Not any physicians that I remember.
Q. And were you involved with Brad Lachman Productions while you were doing these
filmings?
A. I had some involvement with them.
Q. Okay. And what was the involvement you had with Brad Lachman Productions?

A. Providing footage to them from Mr. Jackson's archival office and some new footage that
we were shooting.
Q. Okay. Okay. Now, was it your understanding that you would be paid for the actual
interview you did?
A. No.
Q. Okay. You were expecting payment for the film footage that you did, right?
A. For my services.
Q. Yes, okay. All right. And I believe you testified that the footage of the Arvizos that you
did never appeared in that television documentary, right?
A. That's correct.
Q. Did you, yourself, deal with anybody from 7738 FOX when it came to preparing this
documentary?
A. I don't believe so.
Q. Do you recall at one point complaining that Mart in Bashir had used footage of you in his
televised interview with Mr. Jackson?
A. Did I ever comp lain?
Q. Yes.
A. To who?
Q. To anyone, that you had appeared in this documentary without your permission.
A. I discussed with some people that I was in that documentary without my permission,
but I wasn't really complaining, because, you know, it's just -Q. But your position certainly was that you had appeared in the Bashir documentary
without any permission from you, right?
A. I did not sign anything to Martin Bashir to use me in that video, but then he did and -you know, it was okay with me.
Q. Did you ever send a letter to anyone complaining about the fact that Bashir had used
you in his documentary without your permission?
A. Send any letter?
Q. Yes, about the unauthorized use of your likeness by Bashir.
A. I received a letter from Mr. Jackson's lawyer asking me to sign that document that
you're talking about.
Q. Okay.
A. But I never did.
Q. You never did, okay.
A. I never d id.
Q. Okay. But your position at the time was he had used your likeness without any
authorization from you?
A. He never ask me if we can do that, but he used it.
Q. Now, he was not some friend of yours, was he, Mr. Bashir?
A. We became friends, kind of.
Q. Okay. Did you remain friends?
A. I'm sorry?
Q. Did you remain friends?
A. After the air -- after the airing it?
Q. Yes.
A. I guess not.
Q. Okay.
A. I've never seen the guy again.

Q. Okay. All right. Around March of 2003, you were represented by a law firm na med
Greenberg Traurig, correct?
A. March 2003, that's correct.
Q. And Greenberg Traurig is a large law firm with different offices around the country,
right?
A. That's correct.
Q. And they were representing you in your desire to get paid, right?
A. That's correct.
Q. All right. And you were asking to be paid for the work you did, right?
A. For my services and out-of-pocket expenses.
Q. But you were also asking for more money than that, correct?
A. What do you mean by that?
Q. Well, your lawyer claimed that you were promised you would be compensated above
and beyond the moneys set forth in your invoices, right?
A. Mr. Jackson's managers, Ronald and Dieter -Q. Right.
A. -- they promised me percentage of the net profit of this -- of this documentary.
Q. Yes. So your position was that you not only should be paid what was in your invoices,
but that you should be given a profit percentage of what was made on the whole show,
right?
A. They promised me that all my invoices for the last year and a half that has not been
paid at the time, approximately $250,000 -Q. Right.
A. -- will be paid in full, plus a percentage of the net profit.
Q. Yes. And obviously they never came through with that, did they?
A. They never fulfilled their promise.
Q. Okay. And at some point did you learn that they had been caught stealing close to a
million dollars from Mr. Jackson?
MR. AUCHINCLOSS: Objection; assumes facts not in evidence.
THE COURT: Sustained.
Q. BY MR. MESEREAU: At some point did you ever learn that they were stealing anything
from Mr. Jackson?
A. No.
Q. Okay. But you were dealing with -- excuse me, I'm going -- sorry. Your lawyers were
dealing with a lawyer for Mr. Jackson named David LeGrand, right?
A. That's correct.
Q. And to your knowledge, Mr. LeGrand had an office in Las Vegas?
A. That's correct.
Q. Okay. Did you ever talk to him personally yourself?
A. Yes, I did.
Q. And at some point you turned that over to your lawyers, right?
A. To my lawyer, yes.
Q. To deal with him d irectly?
A. Yes.
Q. Okay. Now, when you say that Dieter and Konitzer promised you a net profit's interest
in that rebuttal documentary, what did you believe a net profit's interest meant?
A. A percentage of, like, the gross sales or net profit of it, some sort.
Q. Is that what Dieter and Konitzer promised you?

A. That's correct.
Q. The two of them?
A. That's correct.
Q. All right. And you took the position that you owned a copyright interest in the footage
you had done, right?
A. What footage?
Q. The footage that you did to put together the T.V. documentary about The Footage You
Were Never Meant To See, right?
A. That's correct.
Q. All right. And what did you mean by your having a copyright interest?
A. I'm the author of this footage, and because no payment has ever made for those, I'm
claiming ownership of it.
Q. Okay. Okay. So you claim that you owned an interest in footage that was used in that
television documentary, right?
A. That's correct.
Q. And did you ever see that television documentary?
A. The Footage You Were Never Meant To See?
Q. Yes.
A. Yes.
Q. And that was narrated by Maury Povich, correct?
A. That's correct.
Q. Okay. When did you first meet Dieter?
A. The very first time?
Q. Yes.
A. 1996.
Q. So you knew Dieter before he was doing anything for Mr. Jackson, correct?
MR. AUCHINCLOSS: Objection; assumes facts.
THE COURT: Overruled. You may answer.
THE WITNESS: I met Mr. Dieter during the History tour, Mr. Jackson's world tour, and his
position was merchandising.
Q. BY MR. MESEREAU: Okay. He said he was trying to merchandise something involving
Mr. Jackson, correct?
A. He was doing the merchand ising of that tour, I believe.
Q. Okay.
A. With a promoter.
Q. With a promoter you said?
A. Yeah.
Q. And who was the promoter, if you know? 7744
A. Avram.
Q. Okay.
A. Forgot his name. Mr. Avram.
Q. After you met him in 1996, did you do any business with Dieter, other than what you
have described today?
A. After 1996?
Q. Let me rephrase it. Bad question. You met him in 1996, right?
A. That's correct.
Q. After you met him in 1996, did you do any business with him?
A. Until like from 1996 till sometime -- I mean, are you giving me a time frame or --

Q. Yes. Between the time you first met Dieter in 1996 -A. Okay.
Q. -- and the events you've described today -A. Okay.
Q. -- did you personally do any other business with him?
A. Business meaning financial business-type of -- no. No.
Q. Did you have any involvement with him at all between the time you met him in 1996
and the events you've described today?
A. When you say invo lvement, what do you mean by that? 7745
Q. Were you in communication with him at all?
A. Sometimes.
Q. And when did you start communicat ing with him after you first met him in 1996?
A. Well, just an example would be we're on the tour, and he's doing merchandising -Q. Right.
A. -- and we will just see each other and say Hi at a venue, let's say, and he would show
like the new jackets that he designed and things like that.
Q. Okay.
A. Basically that kind of -- that kind of, you know, interaction.
Q. Right. After the tour ended, when did you next communicate with Dieter?
A. I would see Dieter once in a while -Q. Okay.
A. -- with Mr. Jackson.
Q. Okay. And that would be in Los Angeles?
A. Various locations.
Q. And your understanding was that he was trying to merchandise memorab ilia, jackets,
things like that, involving the name Michael Jackson, right?
A. For the tour.
Q. Yes. Okay. Your understanding was he was trying to merchandise products, correct?
A. That's correct.
Q. Products like jackets, right?
A. Sure.
Q. Jackets that were supposed to be associated with Michael Jackson, right?
A. Sure.
Q. Okay.
A. Mr. Jackson's name would be on it.
Q. Right. Right. And when did you first meet Konitzer, if you know?
A. I believe late 2002. I would say in November, December 2002.
Q. Okay. You didn't meet him when you first met Dieter, right?
A. No.
Q. Okay. Okay.
THE COURT: All right. Let's take our afternoon recess. 8:30 tomorrow morning.
Remember the admonitions. (The proceedings adjourned at 2:30 p.m.)

2005 April 27 (Day 40) H. Moleshi, T Paulsen, D. Rowe & others

HAMID MOSLEHI CROSS-EXAMINATION (Conti nued)

CROSS-EXAMINATION BY MR. MESEREAU:

Q. Mr. Moslehi, yesterday you mentioned that you had decided to give Janet Arvizo a
$2,000 loan on approximately February 19th, 2003, right?
A. That's correct.
Q. And you said you did that based upon a phone conversation with Ms. Arvizo that lasted
about 25 minutes, right?
A. That's correct.
Q. You didn't give her the actual check till the next day after you had filmed the Arvizo
family in what is often referred to as the rebuttal portion, right?
A. Towards the end of it, after the interview, yes.
Q. Yes. Now, obviously, if you were filming the Arvizo family in that tape, you heard what
Janet was saying, correct?
A. Oftentimes I wasn't paying fully attention to what she was saying because I was mostly
concerned about, you know, lighting, camera, that kind of stuff. But, yeah, I heard some.
Q. But you heard a number of the things that Janet Arvizo said in that footage, correct?
A. Some, yes.
Q. And did you hear her saying words to the effect that her family had been spat upon and

abused and not treated properly by various people?

A. I believe so.
Q. And would it be accurate to say that your phone conversation with her the previous day
plus what you heard her say in that tape-recording influenced you to give her $2,000?
A. In some effect, yes.
Q. Okay. Now, in your phone conversation with Ms. Arvizo on February 19th, 2003, did
she ever tell you that she was living with and being supported by a Major Jay Jackson?
MR. AUCHINCLOSS: I'll object as assumes facts not in evid ence. Compound, as well. MR.
MESEREAU: I'll rephrase it if the Court would like. THE COURT: All right.
Q. BY MR. MESEREAU: When Ms. Arvizo on the 19th of February 2003 in your
approximately 25-minute phone conversation discussed her financial s ituation, did she
ever tell you she was living with Major Jay Jackson?
A. I don't remember her making a comment as far as where she lives and who she lives
with.
Q. In that conversation, did she ever tell you that she was being supported by a Major Jay
Jackson? MR. AUCHINCLOSS: I'll object as assuming facts not in evidence. MR.
MESEREAU: Strictly a question. THE COURT: The objection is overruled. You may answer.
THE WITNESS: Um, did she mention whether she lives or being supported by Jay
Jackson?
Q. BY MR. MESEREAU: My first question was, did Janet Arvizo in your phone conversation
on February 19th, 2003, ever mention to you that she was living with a Major Jay
Jackson, and I believe you said, No.
A. I believe -- I don't remember having that conversation.
Q. My next question is, in that same phone conversation did Janet Arvizo ever ment ion
that she was receiving any financial support from a Major Jay Jackson?
A. I don't remember having that conversation.
Q. In that phone conversation, did Ms. Arvizo ever mention that her family had obtained
an approximately $152,000 settlement from J.C. Penney?
A. No.
Q. In that phone conversation, did Miss Arvizo ever mention that her family had received
any money from fund-raisers at The Laugh Factory?
A. No. MR. AUCHINCLOSS: I'll object and move to strike, as to the last question, as vague
as to time. THE COURT: Overruled.
Q. BY MR. MESEREAU: In that phone conversation of February 19th, 2003, did Ms.
Arvizo ever ment ion that any celebrities had at any time g iven her family money? MR.
AUCHINCLOSS: Objection; vague as to time. THE COURT: Overruled. THE WITNESS: Do I
answer? No.
Q. BY MR. MESEREAU: And in your phone conversation on February 19th, 2003, did Ms.
Arvizo ever ment ion that she had set up a bank account for the benefit of her son Gavin
from which she withdrew thousands of dollars? MR. AUCHINCLOSS: Objection; assumes
facts not in evidence. THE COURT: Sustained.
Q. BY MR. MESEREAU: In that phone conversation on February 19th, 2003, did Ms.
Arvizo ever ment ion that she had set up a bank account for the benefit of her son Gavin?
A. No.
Q. And in that same phone conversation, did she ever mention that her family had ever
obtained any vehicle from Michael Jackson?
A. No.
Q. Did she ever say in that phone conversation any benefits, financial or otherwise, that

she or her family had received from Michael Jackson?

A. No.
Q. Did she ever say anything about someone named Louise Palanker g iving the family
$20,000?
A. No.
Q. Did she ever say anything about Fritz Coleman, a newscaster in Los Angeles, trying to
raise money for the family?
A. No.
Q. Did she ever say anything about Chris Tucker giving $2,000 to the family?
A. No.
Q. Did she ever say anything about Chris Tucker giving the family the use of a vehicle at
any time?
A. No.
Q. Now, you indicated that when you went to Neverland to pick up the family -- excuse
me. Pardon me. Let me rephrase that. Poor question. You indicated that you drove to
Neverland for the purpose of filming the family at Neverland, right?
A. That's correct.
Q. And you indicated that when you got there, to your knowledge, the children were there
but Janet Arvizo was not, correct?
A. That's correct.
Q. And I believe you said you spoke to Joe Marcus about your desire to take the children
to Los Angeles to do the filming, correct?
A. After Janet not being there, there was a decision made that the interview will take
place in L.A.
Q. Okay.
A. And I informed Joe Marcus about that decision.
Q. And to your knowledge, who was Joe Marcus?
A. Joe Marcus is Neverland Valley property manager.
Q. And had you met him before?
A. Yes.
Q. And was it your understanding he had worked at Neverland for a long period of time?
A. That's correct.
Q. And your understanding from Mr. Marcus was that he didn't have the authorization to
let the children get in your car and drive off to Los Angeles, correct?
A. What I remember is that I told him about the plan of taking the kids to Los Angeles for
an interview, and if I remember correct ly, he said that they're not allowed to leave the
property.
Q. And at some point, he came back to you and said he had the authority to let you drive
the kids to L.A., correct?
A. If I remember correct ly, it just happened that I took the kids and I don't remember
having any more conversation. But he was aware of me taking the kids with me.
Q. Okay. So did you assume at the time that Mr. Marcus knew the children were on the
property, without the mother, and that Mr. Marcus needed some type of authorization to
just let them go off with you? MR. AUCHINCLOSS: Objection; requires speculation. THE
COURT: Sustained. Q. BY MR. MESEREAU: How much time elapsed between Mr. Marcus
telling you that he didn't have authority to let the kids go and your actually taking the kids
with you?
A. Approximately 30 minutes.

Q. Okay. And did you assume that within that 30-minute period Mr. Marcus telephoned
someone to find out if he could let these children leave the property?
A. I assume that's what he did, yes.
Q. Okay. And you then, approximately 30 minutes later, put the three children in your car
and drove them to Los Angeles, right?
A. That's correct.
Q. Had you ever had those three children in your car before?
A. No.
Q. Now, when you went to Mr. Marcus and told him you wanted to take the three children
to Los Angeles, did he ask you if you had the authority to do so?
A. I don't remember.
Q. Did you tell him you had the mother's permission to put her three children in your car
and drive them to Los Angeles?
A. I don't remember.
Q. Okay. But I assume at some point you thought you had the mother's permission to do
that, correct?
A. That's correct.
Q. Okay. And at some point in time, you earned that Janet Arvizo did not want to return
to Neverland for the filming, right?
A. That's correct.
Q. You learned that Janet Arvizo wanted the filming to take place somewhere in Los
Angeles County, correct? MR. AUCHINCLOSS: Objection; assumes facts. THE COURT: I'll
sustain the objection as vague. MR. MESEREAU: Okay.
Q. At some point before you put the three children into your automobile and drove them
to your home, was it your understanding that the mother approved your doing that?
A. Yes.
Q. And I gather you then drove the children directly to your home; is that right?
A. That's correct.
Q. When you got to your home, was Janet Arvizo there?
A. No.
Q. At some point after you arrived at your home with the three children, d id Janet Arvizo
arrive?
A. That's correct.
Q. Okay. And as you testified, the filming then took place at your home, right?
A. That's correct.
Q. Now, you indicated that an investigator named Brad Miller was there, right?
A. That's correct.
Q. And did you learn that he was working for Attorney Mark Geragos?
A. I did not know who he was working for.
Q. Okay. Did you assume he was investigating somebody?
A. I didn't know why he's there.
Q. Okay. Did he ever explain to you why he was there?
A. No.
Q. Okay. But he must have identified himself as a private investigator, right?
A. No. What happened is I asked one of the gentlemen of Marc Schaffel's people who this
guy is, and they said he's a private investigator.
Q. Okay. But you never really knew if he was investigating the Arvizos, or Schaffel, or
you, or anybody, right?

A. I didn't know.
Q. Okay. Now, you've been interviewed by representatives of the District Attorney's
Office, correct?
A. That's correct.
Q. And have they ever discussed with you who Mr. Miller is in those interviews?
A. On November 18, 2003, I was served with a search warrant. On that search warrant, it
says that any document that could show any relationship between me and Brad Miller.
Q. Okay.
A. And there were some other questions about that.
Q. And other than him being at your house that night, you really had no relationship with
him, right?
A. No.
Q. And if he was putting anyone under surveillance, you weren't aware of it, right?
A. No.
Q. Okay. And at some time you learned that he had actually done a few minutes of
surveillance on you, right?
A. Recently I learned that.
Q. You learned that from the prosecution, correct?
A. That's correct.
Q. Okay. Now, obviously yesterday, the prosecutor played that little bit of footage, and
you identified yourself and your automobile, right?
A. That's correct.
Q. And where did that footage take place, if you know?
A. That's what I was wondering yesterday. I don't -Q. It was not at your home, right?
A. No.
Q. It was somewhere else?
A. That's correct.
Q. It appeared that you were going to a parked vehicle that you owned?
A. I believe so.
Q. But you're not sure where that was?
A. No.
Q. Okay. Okay. D id you ever see Investigator Brad Miller after that evening you filmed the
Arvizo family?
A. Did I see him again?
Q. Yes.
A. No.
Q. So that was the first and only time you've ever seen the guy?
A. That was the first and the last time I ever saw him.
Q. Did he ever call you after that and ask you anything, to your knowledge?
A. No.
Q. Okay. But you're saying Marc Schaffel told you he was a private investigator?
A. One of his guys.
Q. Okay. Not Schaffel himself?
A. Not Schaffel himself.
Q. Okay. Okay. But whoever told you that didn't tell you that he was employed by
Attorney Geragos, correct?
A. No.

Q. All right. Did you learn that at some point, that Mr. Miller was a private investigator
hired by Attorney Mark Geragos? MR. AUCHINCLOSS: Objection; asked and answered.
THE COURT: Overruled. You may answer. THE WITNESS: I heard on the T.V.
Q. BY MR. MESEREAU: Okay. Okay. A ll right. Let me get back to the financial
disagreement you had regarding your filming the Arvizo family, okay?
A. I'm sorry, repeat that, please.
Q. The concerns you had about being properly compensated for the work that you had
done, okay?
A. Unpaid invoices?
Q. Yes. I want to ask you some questions about that. At the time you filmed the Arvizo
family for purposes of the rebuttal documentary, did you know when the documentary
was supposed to air on television?
A. Yes.
Q. And what was your understanding about when that rebuttal documentary with Maury
Povich was supposed to air on television?
A. February 20th of 2003.
Q. That didn't give you much time to get the footage you filmed to the network that was
going to actually air the show, did it?
A. No. In fact, we missed the deadline.
Q. Yes. Originally, was the plan for you to film the family, get immediately paid and get it
to the network? Was that the initial plan?
A. The initial plan was to finish this rebuttal documentary by midnight of 19 -- February 19
of 2003, to be aired for the 20th. And the day after it's aired I was supposed to get paid in
full.
Q. Okay. And I believe you testified that you withheld the footage because you hadn't
been immediately paid, correct?
A. Well, I held the footage because of other reasons. I had to make a copy of it. And also,
since we missed the deadline, there was no reason to rush to deliver these tapes anyway.
Q. But by withholding the footage, it was clear to you that it could never be on the
televised documentary, right?
A. Sorry, say that again?
Q. By withholding the footage the way you did for the reasons you've expressed, it was
obvious to you that it could never appear on the documentary, right?
A. Well, as I said, we missed the deadline anyway, so there was no way that those
footage could have been used in the rebuttal documentary.
Q. But your understanding about why you were to film the family was that there was a
desire to possibly use that footage in the T.V. documentary, correct?
A. Well, originally we were supposed to shoot this on 19, February 19, to be delivered by
midnight to the production company. Since we passed that deadline, I knew that it's not
going to be used for the rebuttal documentary.
Q. Now, yesterday, you testified that Dieter and Konitzer had promised you a profit
participation in the televised documentary, correct?
A. A percentage of the revenue.
Q. Now, correct me if I'm wrong, I think yesterday you used the firm -- used the term,
excuse me, a percentage of gross profits; was that true?
A. Yeah, gross profit.
Q. Okay. Because there is documentation that talks about your claim that you had a net
profits interest as opposed to a gross profits interest?

A. Well, maybe I'm not qualified to distinguish the difference between the two, but there
was an agreement that once -- once this documentary is aired, there would be a
percentage of the sales, amount of the gross sales, to me for my work.
Q. And was that percentage of gross sales supposed to include gross sales all over the
world?
A. That's correct.
Q. And in your mind, that could be many millions of dollars potentially, right?
A. At the time, I didn't know what was the sales.
Q. Okay. And you're saying that Dieter and Konitzer gave you an oral agreement to that
effect, right?
A. That's correct.
Q. There was nothing ever reduced to writing about your having a percentage interest in
profits associated with that show, right?
A. They promised me that they will put this in writing, but they never did.
Q. Okay. Now, in light of the fact that the footage of the Arvizo family could not appear in
that documentary, did you still think you were entit led to that percentage interest?
A. Sure.
Q. In light of the fact that the footage could not appear in that documentary, did you still
feel you were ent itled to your normal fees and costs?
A. Well, the Arvizo family footage was not the only one, the only footage to be used in
that rebuttal documentary. There was some other footage created by me that was
supposed to be used in there.
Q. And an example of that footage was your own personal interview, right?
A. As far as profit goes?
Q. Yes.
A. Could you be more specific?
Q. Sure. Sure. Let's talk about all the work you did on the rebuttal show that was hosted
by Maury Povich, okay?
A. Okay.
Q. The work you did was a personal interview, right?
A. Personal interview of -Q. You.
A. I did not do that myself.
Q. But you spoke yesterday about a personal interview -A. No, I did not shoot that interview. In other words, I did not shoot myself to be
interviewed. Somebody else shot me.
Q. Yes. But certainly you did grant an interview that somebody else shot for purposes of
that documentary, right?
A. That's correct.
Q. And you also obviously did a shoot of the Arvizo family for the purposes of that
documentary, right?
A. Sure.
Q. What else did you do for the purposes of preparing that documentary?
A. As I remember correct ly, I put 250 hours in a matter of 11 days, 250 hours in a matter
of days, oftentimes 20 -- 20 hours a day to finish this rebuttal documentary.
Q. And that included footage of other family members of the Jackson family, correct?
A. The Jacksons' family members interview, other footage that I provided, and edited for -

Q. Right.
A. -- for the purpose of this documentary.
Q. All right. Now, other than the Arvizo footage, did you provide the other footage you did
to the network?
A. Other footage of?
Q. Family members. Did you provide that in a timely fashion so it could be used in the
documentary?
A. When you say family members, are you talking about Mr. Jackson's family memb ers?
Q. Yes.
A. Okay.
Q. So that was given in time to be included in the documentary, correct?
A. That's correct.
Q. The only footage you did that was not provided in time to include in the documentary
was the footage of the Arvizo family, right?
A. The only footage that was not provided?
Q. Well, let me -- I'm probably confusing you. Don't intend to. The Arvizo family footage
never got there in time, right?
A. That's correct.
Q. The other footage you did did get there in time, right?
A. That's correct.
Q. Okay. If you knew that the footage of the Arvizo family was not going to get there in
time, why did you continue to do it?
A. Well, since we set up all the equ ipment and everything, might as well shoot it.
Q. Okay. And your position after you shot it was, I want to make a copy of it, and I'm not
handing it over to anybody till I'm properly compensated, right?
A. No, first my thought was I'm making a copy of it, just for insurance. In case something
happens to the tapes, there's a copy of it. But the morning after when Ronald and Dieter
and other of Mr. Jackson's agents refused to talk to me about this unpaid invo ices issue, I
decided that I'm not going to do anything until I get paid.
Q. Uh-huh. Okay. Your position was you weren't going to do anything until you got paid
your normal fees and costs that were owed, plus you had a documented percentage
interest in profits coming from the show, right?
A. All the unpaid invoices and the percentage that they promised me.
Q. Yes. Okay. Now, your lawyers at Greenberg Traurig, the law firm you retained, wrote a
letter to David LeGrand on March 5th, 2003, that I showed you yesterday, okay?
A. I don't think you showed me a letter of my lawyer.
Q. Oh, may I -- would it refresh your recollection if I just show it to you?
A. Sure. MR. MESEREAU: May I approach, Your Honor? THE COURT: No, you haven't
asked him a question that requires any refreshing of memory.
Q. BY MR. MESEREAU: Okay. Do you recall a letter from your lawyers that was written
to David LeGrand on March 5th, 2003?
A. There was a lot of letters wrote. I don't recall which one you are referring to.
Q. Do you recall one written on March 5th, 2003?
A. I don't remember a specific date.
Q. Would it refresh your recollection if I just show you a copy of that letter?
A. Sure. MR. MESEREAU: May I approach? THE COURT: No. You haven't asked him a
question that requires refreshing of memory. MR. MESEREAU: I thought -- he doesn't
know the date, Your Honor. I was just going to refresh him on that. All right.

Q. How long after you completed the footage of the Arvizo family did you retain a law firm
to represent you?
A. Could you repeat that again?
Q. Yes. You filmed the Arvizo family on the 20th, right?
A. Yes.
Q. You withheld the footage - okay? - for various reasons that you've identified?
A. Sure.
Q. And you went to a law firm to represent you shortly after that, correct?
A. What do you mean shortly after?
Q. Well, within a couple of weeks, true?
A. Approximately.
Q. The law firm was a firm by the name of Greenberg Traurig, correct?
A. That's correct.
Q. And Greenberg Traurig wrote a letter to Attorney David LeGrand, who you have spoken
about before. They wrote him a letter on March 5th, 2003, identifying your position on
compensation, right?
A. I believe so.
Q. Okay. Do you know for sure?
4 A. Well, again, I don't have my records here, so I don't know what -- what letter you're
referring to.
Q. Okay. Would it refresh your recollection if I show that to you?
A. Sure. MR. MESEREAU: The letter of March 5th, is that permitted, Your Honor? THE
COURT: Yes. MR. AUCHINCLOSS: So what number? THE WITNESS: Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that document?
A. Well, my lawyer was in touch with Mr. LeGrand, so most of the communications were
between my lawyer and Mr. LeGrand.
Q. But you've looked at that document I showed you, right?
A. Right now I looked at it.
Q. And you see a date of March 5th, 2003?
A. It says March 5th.
Q. Okay. Do you know approximately when you hired a lawyer to represent you on this
particular issue?
A. I don't remember.
Q. Okay. It was shortly after you filmed the Arvizo family, correct?
A. When you say shortly, what do you mean?
Q. Within a couple weeks? W ithin two weeks?
A. Approximately.
Q. And had you made any verbal requests to Dieter and Konitzer to fulfill what you say
their promises were before you went to a lawyer?
A. I'm sorry, say that again?
Q. Had you spoken to Dieter and Konitzer between the filming of the Arvizo family and the
time you retained the law firm of Greenberg Traurig?
A. Yes, I spoke with them.
Q. Did you try to get things resolved with them?
A. Yes, I did.
Q. And I gather you could not do that?
A. Negative.
Q. Okay. Now, you were asking to be compensated for projects you had done since 1999,

right?
A. There were unpaid invoices -Q. Yes.
A. -- from .99, 2001, and I believe 2002 and 2003.
Q. Right. One of them had to do with your filming the Air Force visiting Neverland,
correct?
A. I don't have my records, but it could be.
Q. Would it refresh your recollection if I just show you your outstanding -- a record of
your outstanding invoice?
A. Is that one of the outstanding?
Q. Yes.
A. It is, for sure? Okay. I mean, I don't have my records. I do have records that shows
what has been paid, what has not been paid.
Q. Okay.
A. But right now I don't have nothing in front of me to be able to tell you whether that
specific invoice has been paid or not.
Q. Would it refresh your recollection if I just show you a record of your invoices?
A. Please. MR. MESEREAU: May I approach? THE COURT: Yes. MR. AUCHINCLOSS: What
number, Counsel? THE WITNESS: Are you referring to this one? Okay.
Q. BY MR. MESEREAU: Have you had a chance to look at that document?
A. Yes.
Q. Does it refresh your recollection about your outstanding invoices at that time?
A. What you showed me, it's a summary of all the unpaid invoices at the time.
Q. Okay. And some of the work you had done you had provided and some of it you had
withheld pending payment, true?
A. I don't remember.
Q. Well, the -- you had done an interview with Michael Jackson, correct?
A. I did an interview with Michael Jackson?
Q. Well, you, in your invoices, refer to the Bashir interview with Michael Jackson in
Florida,correct?
A. Okay.
Q. You had filmed that interview yourself, right?
A. That's correct.
Q. And you were withholding that footage until you were paid, correct?
A. No.
Q. Well, the schedule your lawyer provided indicated that, didn't it?
A. Well, this footage that you're talking about, it's been aired already. So that means I
have provided that.
Q. Okay. Do you recall your lawyer saying you were going to withhold that footage until
you were paid on March 5th, 2003?
A. Do I recall if my lawyer were saying that I'm going to withhold -Q. Yes.
A. -- the footage until I get paid?
Q. Yes.
A. That footage was not withheld.
Q. Okay.
A. Because it was aired already on February 20th -Q. So that --

A. -- by FOX.
Q. So you weren't withholding anything in that regard?
A. Well, that footage, no.
Q. The only footage you say you're withholding is the footage of the Arvizo family?
A. Again, I don't have my records, but if you tell me, I'll take your word.
Q. Do you recall filming in London, in New York, some footage dealing with Sony?
A. I do remember that.
Q. And were you withholding that footage until you were paid?
A. Again, I don't have my records to tell you whether I have turned over those footage or
not.
Q. I'm talking about March 5th, 2003. Do you recall whether your position was you were
going to withhold footage dealing with Sony in New York and London until you were paid?
A. I don't understand your question.
Q. Okay. Let me rephrase it. As of March 5th, 2003 -A. Okay.
Q. -- the Arvizo footage that you have described was not the only footage you were
refusing
to deliver until you were properly paid, right?
A. Well, I mean, I -- can you refresh my memory by making an examp le of it?
Q. Would it refresh your recollection to look at this summary of invoices your lawyer
sent?
A. Sure. MR. MESEREAU: May I approach? THE COURT: Yes. THE WITNESS: When it says,
No, not necessarily means nothing has been turned over. Maybe not like the original
copy, but there has been copies that has been delivered already. In fact, if you look at
that summary, you'll see under the Martin Bashir footage, it says, No, but it was
provided, a copy of that footage anyway.
Q. BY MR. MESEREAU: Okay.
A. Because it was aired on February 20th.
Q. Okay. Do you recall any money ever being wired to you in partial payment of what you
felt you were owed for the work you did?
A. There was one payment made after -- I believe a month after what they promised me.
Q. Do you know how much that was?
A. 200,000.
Q. Okay. Who wired you the 200,000; if you know?
A. I believe it was from David LeGrand's office.
Q. Okay. And do you recall how much you felt you were still owed after you received the
200,000?
A. I believe my invoices were over $300,000.
Q. Okay.
A. For a period of a year and a half, which 200,000 was paid.
Q. Okay. And you, to this day, never turned over the Arvizo footage to anyone, correct?
A. Correct.
Q. The Arvizo footage was seized by sheriffs representatives when they did a search of
your home, right?
A. That's correct.
Q. Now, when d id you last talk to Janet Arvizo?
A. February 20th of 2003.
Q. Okay. So that was the last day you saw her or spoke to her, right?

A. As I remember, that's correct.

Q. Okay. Have you ever spoken to any of her three children since that day?
A. No.
Q. Okay. Now, the prosecutor asked you questions about Dieter and Konitzer cla iming
they managed Mr. Jackson's affairs, right?
A. I was informed by Mr. Ronald and D ieter, Konitzer and Weizner, that sometime in
probably approximately December of 2002, they going to take over the management of
Mr. Jackson.
Q. And you were instructed by Konitzer not to call Michael Jackson, right?
A. At one point, yes.
Q. He asked you to only call him and not call Michael Jackson or Evvy, correct?
A. That's correct. MR. AUCHINCLOSS: Objection; hearsay. MR. MESEREAU: Your Honor,
it's in response to the doors opened by the prosecution on that issue. THE COURT: The
objection's overruled.
Q. BY MR. MESEREAU: Approximately when d id Konitzer tell you, Don't speak to
Michael Jackson or Evvy?
A. I believe was like approximately February 21st.
Q. Okay.
A. Late February, I mean of 2003.
Q. And did he do that in person or on the phone?
A. I believe there was an e-mail and a phone.
Q. Okay. And he told you that he was going to clean up the mismanagement in Mr.
Jackson's business affairs, right?
A. That's correct.
Q. He told you he was in charge of all restructuring, right?
A. They told me that they going to take over, and, you know, make things smoother.
Q. Right.
A. Operation.
Q. And did you honor his request that you not contact Mr. Jackson?
A. Um, I don't remember.
Q. Okay. Do you remember whether or not you ever telephoned Mr. Jackson after Mr.
Konitzer told you, Don't call him; just talk to me?
A. I believe I spoke to Mr. Jackson.
Q. Okay. And do you know when that was?
A. I believe it was February 21st of 2003.
Q. Okay.
A. I believe.
Q. And you think that was after Konitzer told you, Don't ever call Mr. Jackson; just
contact me?
A. Could have been.
Q. Did you talk to Mr. Konitzer after he made that request?
A. Yes, I believe I did.
Q. Okay. Did you ever see him in person after he made that request to you?
A. I believe I did.
Q. Okay. Do you know where that was?
A. In Santa Monica in a hotel.
Q. Okay. Now, at some point did you learn that Weizner and Konitzer had been fired? MR.
AUCHINCLOSS: Objection. Assumes facts; hearsay; foundation. THE COURT: Sustained on

assumes facts.
Q. BY MR. MESEREAU: Did you ever learn whether or not Ron Konitzer continued to be
involved in Mr. Jackson's affairs?
A. After -Q. The 20th.
A. Yeah. That was my belief, that he still continued.
Q. And did you ever learn from him at any point that he was no longer involved with Mr.
Jackson's affairs?
A. Not from him.
Q. Did you learn from someone else? MR. AUCHINCLOSS: Objection; hearsay. THE
COURT: Sustained. MR. MESEREAU: Okay.
Q. Do you recall a lawsuit in England that was filed by attorneys representing Mr. Jackson
over the Bashir documentary?
A. I have heard about it, but I've never seen the lawsuit itself.
Q. Was it true that after Bashir did his footage, you asked him to provide you copies of his
footage?
A. Repeat that question one more time?
Q. Yes, I'm sorry if it's unclear. Did you ever ask Bashir or any agent of Bashir to provide
you copies of Bashir's footage?
A. Yes, I did.
Q. And when did you do that?
A. The very first day I met him.
Q. Okay. Now, it was understood that you were going to do your own footage at the same
time, right?
A. That's -- well, the first day.
Q. But you were also asking Bashir to give you some of his footage, right?
A. All his footage.
Q. All right. And did he respond to you?
A. He said -- he promised he will.
Q. Did he ever do that?
A. No.
Q. Did you ask him verbally or in writing; do you know?
A. Verbally.
Q. And that was face to face?
A. That was face to face.
Q. All right. And was that at Neverland?
A. That's correct.
Q. Okay. And was that before any of the filming began? 7783
A. That's correct.
Q. Now, he never objected to you doing your filming, correct?
A. He wasn't happy, but he had no choice.
Q. Okay. How much of Bashir's footage -- excuse me, let me rephrase that. How much of
the material that Bashir filmed did you film as well? Did you film everything that he
filmed?
10 A. No.
11 Q. Okay. What did you actually film yourself?
A. Two interviews and one sightseeing at Neverland.
Q. To your knowledge, what did Bashir film that you didn't film yourself?

A. Well, since I was not present at all the sessions that Mr. Bashir did, I really don't know
how much he shot.
Q. Okay. But other than your request that he give you some of his footage, you didn't
participate in any lit igation involving Bashir, right?
A. Legal litigation?
Q. Yes.
A. No.
Q. Okay. And you knew lit igation was going on in England, did you not?
A. I have heard from Mr. Jackson's personal assistant that there's going to be a lawsuit
against Mart in Bashir and Granada T.V. in regard to this documentary.
Q. Okay. During the filming of the Arvizo family at your home, you said you were sort of
in and out of the room where the filming was being done?
A. While I was setting up, yeah, I was going from garage to the place where the interview
was supposed to take place.
Q. But while the interview was actually conducted, were you present at all times?
A. During the filming, yes.
Q. Okay. And approximately how long did that filming last, if you know?
A. Approximately an hour.
Q. How long were the children at your house before the filming actually began,
approximately?
A. Two to three hours.
Q. And how long was Janet Arvizo at your house before the filming actually began?
A. Approximately one hour.
Q. Who did the questioning during the interview?
A. Christian Robinson.
Q. Had you worked with him before?
A. Yes.
Q. Okay. How many times had you worked with Christian Robinson before?
A. On one project.
Q. All right. And was it your understanding that he had a list of questions he was going to
ask during the interview?
A. I saw him having a list of questionnaire, yes.
Q. And was it your understanding that he was asking questions from the questionnaire?
A. I believe so.
Q. Okay. And you observed the Arvizo family responding to those questions, true?
A. That's correct.
Q. Before the filming began, d id you see Mr. Robinson meet with any member of the
Arvizo family?
A. I'm sure he did. But I did not observe that.
Q. Did you see him going over the questions with any member of the Arvizo family?
A. Could have been.
Q. You're not sure?
A. I'm not sure.
Q. Okay. Typically when you film an interview like this, the person doing the interview has
a list of questions, correct?
A. Most of the time.
Q. And you've filmed numerous interviews like this in your career, right?
A. That's correct.

Q. Okay. During the two to three hours that the Arvizo children were at your home before
the interview, you never watched them memorizing anything, did you? MR.
AUCHINCLOSS: Objection; requires speculation. THE COURT: Overruled. You may answer.
THE WITNESS: Repeat that again.
Q. BY MR. MESEREAU: Yes. During the two to three hours that the Arvizo children were
at your home prior to the start of the interview, you never saw them memorizing words,
did you?
A. No.
Q. In fact, what you saw them doing was mostly playing and having fun, right?
A. As I remember.
Q. Before Janet Arvizo started the interview, you didn't watch her memorizing words, did
you?
A. No, I didn't.
Q. You said that Janet was there for about an hour, right -A. Approximately.
Q. -- before the taping began, okay? And I think you said that she was in a discussion
about some type of contract, right?
A. I believe there was a release to sign.
Q. Okay. And was she talking to someone about that release?
A. Yeah.
Q. Who was she talking to, if you know?
A. I think she was talking to a few people. V innie, Christian Robinson, and possibly Paul.
There's a gentleman by the name of Paul, I believe it's Hugo or something like that. I
don't know his last name, but -Q. And did you see a document that you thought was a contract or a release?
A. I saw a document, but I never looked at it.
Q. Okay. And did it appear that Janet and these other individuals were discussing the
document?
A. Yes. They were d iscussing the document.
Q. Did you actually hear Janet and these individuals discussing this document?
A. Did I hear or see?
Q. Yes. Well -- excuse me, let me rephrase. Did you hear what you believed was a
discussion between Janet and these individuals about that document?
A. Yeah.
Q. Okay. Did you see Janet and these individuals discussing that document?
A. I believe I saw some.
Q. Okay. Did you ever see Janet on the phone during that period of time?
A. Could have been. I'm not sure.
Q. Okay. At some point, did you watch Janet sign that document?
A. I don't remember seeing her sign ing it. But it was towards the end of the interview, and
I -- my understanding was that she signed it.
Q. Okay. And correct me if I'm wrong, but did you say something yesterday about there
being changes made to the document?
A. I believe there was some changes being made to the document.
Q. And what made you believe that?
A. Because Vinnie asked me to use my fax machine so he can fax some documents back
and forth I believe with Schaffel.
Q. Okay. And why did you think Janet at some point signed the document?

A. Because there was no other discussion about it.

Q. Okay. Did you see -- but you never saw anybody actually sign it, true?
A. I didn't see her sign it.
Q. Okay. Now, did you say at some point Schaffel told you he didn't want the Arvizos to
know where he lived?
A. That's correct.
Q. Did he tell you he was suspicious of the Arvizos? MR. AUCHINCLOSS: Objection;
hearsay. THE COURT: Sustained.
Q. BY MR. MESEREAU: Did Schaffel ever discuss with you why Investigator Brad Miller
was there?
A. Schaffel himself?
Q. Yes.
A. No.
Q. Did anyone else there ever tell you that the investigator was investigating the Arvizo
family?
A. No.
Q. What did you see Brad Miller doing while the tap ing went on?
A. Well, during the taping I was paying attention to, you know, my work. But before that,
he was walking around my house.
Q. Okay. Did he appear to be taking notes at all, to your knowledge?
A. During the filming?
Q. Let me start again. At some point Miller arrived at your house, right?
A. Correct.
Q. And did he knock on the door?
A. Yes, he did.
Q. And did you answer the door?
A. Yes, I did.
Q. And did he identify who he was at that point?
A. I said, Who are you? And he said, I'm for the interview.
Q. Okay. Did he say he was a private investigator?
A. No, he did not.
Q. Did he give you his card?
A. No, he did not.
Q. Okay. And why did you let him in?
A. Um, because I -- why did I let him in? Um, I thought he was with Marc Schaffel's
people, and since they were there already, I thought they were expecting him. Maybe it's
delivering something or -- I don't know. But being kind and polite, I let him in.
Q. Yes. Okay. So he was there the whole time, as far as you know?
A. Yes.
Q. Do you know when he left?
A. At the end of the interview.
Q. Okay. Do you know if he left with anybody?
A. I did not see him leaving with who -- with anybody.
Q. Did you ever see him recording anything in your house?
A. No, I did not see him recording anything.
Q. Did you ever see him writing anything down?
A. I did not. Could have been. I don't know.
Q. And did you ever see him photographing anything while he was in your house, to your

knowledge?
A. Not to my knowledge.
Q. Okay. Now, when Janet -- excuse me. Before Janet Arvizo was filmed, she used your
rest room and began to apply her own makeup,right?
A. She used my -Q. Rest room -A. Yeah.
Q. -- and applied her own makeup for the filming, correct?
A. I believe so.
Q. And you never saw anybody coaching Janet on what to say, correct?
A. No, I did not.
Q. You never saw anyone coaching the children on what to say in the interview, right?
A. I did not see anything.
Q. I believe you testified yesterday that, in your opinion, Janet Arvizo had a problem with
a draft contract, right? MR. AUCHINCLOSS: Objection to the use of the word contract.
MR. MESEREAU: W ell, I'll change the -- I'll rephrase it.
Q. You recall Janet looking at a three-page nondisclosure contract, right?
A. I never -- MR. AUCHINCLOSS: I'll make the same objection. THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you ever tell a representative of the Santa Barbara Sheriff's
Department during an interview that Vinnie brought a three-page nondisclosure contract
for Janet to sign? MR. AUCHINCLOSS: Calls for a legal opinion. THE COURT: No, he's
asking if he told the sheriff that, so the objection is overruled. You may answer. THE
WITNESS: I don't remember being so specific about three-page or nondisclosure
agreement. If I had said anything about that, about that document, it would have been a
release. I don't remember saying that it was a three-page confidentiality or some sort of
title for the document.
Q. BY MR. MESEREAU: Would it refresh your recollection to just show you a police report
summary of your interview?
A. Sure. MR. MESEREAU: May I approach, Your Honor? THE COURT: Yes. THE WITNESS:
Um, I don't -- MR. MESEREAU: I have to first ask you a question.
Q. Have you had a chance to review that document?
A. No, I never have, that document.
Q. Have you had a chance to review the document that I just showed you?
A. No, I did not, I never obtained that document that you just showed me.
Q. Okay. Did you just look at that document?
A. I looked at that document. I do not remember saying three pages nonconfidentiality
contract.
Q. Okay. Okay. Now, Vinn ie at some point asked you to sign a document, did he not?
A. I believe so.
Q. And you refused to sign a document presented to you by Vinnie, correct?
A. That's correct.
Q. Okay. Do you know what that document concerned?
A. That was a three-page non -- a confidentiality document, which he left it at the house.
Q. The FOX TV special, The Footage You Were Never Meant To See, appeared on
February 20th, 2003, on television, right?
A. That's correct.
Q. Did you watch that show?
A. Yes, I did.

Q. Okay. Did some of the footage you had done of the Bashir interview appear on that
documentary?
A. Yes, it did.
Q. Did your interview, your personal interview, appear in that documentary?
A. Yes, it did.
Q. Was it your understanding that additional documentaries were going to be made to put
Mr. Jackson in a favorab le light?
A. Another after The Footage You Were Never Meant To See, I had no knowledge of
that.
Q. You never understood there was to be a two- or three-part series in that regard?
A. No. Nobody informed me anything on that.
Q. Okay. Do you recall being at Neverland on approximately February 8th, 2003, to meet
people from 60 Minutes?
A. I believe so. I think it was a Saturday, if I'm not wrong.
Q. Do you remember meeting someone named Ed Bradley at Neverland?
A. Yes.
Q. And do you remember meeting Mr. LeGrand on that day?
A. Yes.
Q. Do you remember meeting other people from CBS on that day? 7795
A. Yes.
Q. And why were you at Neverland on February 8th, 2003?
A. I was there as a personal DP, which stands for Director of Photography, for Mr.
Jackson, for his lighting and the look of his picture.
Q. Was anything filmed on February 8th, 2003?
A. I don't believe so.
Q. Do you know why?
A. No.
Q. Okay. How long were you there that day, if you remember?
A. A few hours.
Q. Do you remember seeing Janet Arvizo there that day?
A. I don't remember.
Q. Would it refresh your recollection just to look at the police report summary of your
interview?
A. Sure. MR. MESEREAU: May I approach, Your Honor? THE COURT: Yes. THE WITNESS: I
don't remember making that statement about Janet.
Q. BY MR. MESEREAU: How many times do you think you have seen Janet Arvizo at
Neverland?
A. I would say two or three times.
Q. Okay. Do you know approximately when?
A. At various times.
Q. Okay. Approximately when do you think the first time you saw Janet Arvizo at
Neverland was?
A. Between 2000 and 2003. It could have been 2001. I don't know.
Q. Okay. Did you meet her for the first time when the 60 Minutes crew was at Neverland?
A. I don't remember seeing her that day.
Q. Okay. When do you think you first saw her, ever?
A. It could have -- again, it's between the year 2000 and 2002, I would say. It could -like approximately 2001. I don't know.

Q. And was your first meeting with her at Neverland, to your knowledge?
A. Yes.
Q. Okay. And do you recall whether or not her children were there when you met her the
first time?
A. I think they were.
Q. Okay. And you indicated in response to the prosecutor's questions you developed a
friendship with the Arvizo family?
A. Well, as I said, in the year 2000, I d id two projects that Arvizo kids, David or Star and
Gavin, were involved. One of the project I was directing. And within that project I had a
lot of conversations and interactions with David and Gavin. So I kind of got to know
them.
Q. Did you stay in touch with them on a social level?
A. No.
Q. When you weren't talking to them at Neverland, did you call them on the phone?
A. From Neverland, calling them?
Q. Let me rephrase it. I'll ask a better question. Aside from the instances where you saw
them in person, did you have a relat ionship where you would call them from time to
time?
A. I don't think so.
Q. Did they call you from time to time?
A. I don't think so.
Q. Okay. So your only involvement with them was either at Neverland or when they came
to your home; is that right?
A. That's correct.
Q. You didn't see them during your trips to Florida, right?
A. No, I didn't.
Q. Okay. Now, you indicated that you had met one of Marlon Brando's sons; is that
correct?
A. Yes.
Q. And who did you meet that was a son of Marlon Brando?
A. Miko Brando.
Q. And when did you first meet him?
A. .97, .98. 7798
Q. Did you see him often at Neverland?
A. Sometimes.
Q. Was it your understanding that he was a friend of Michael Jackson?
A. Friend and associate.
Q. Okay. And when did you last see him?
A. Last time, end of February of 2003.
Q. Okay. Now, you did an interview with a woman named Debbie Rowe, didn't you?
A. That's correct.
Q. And that was footage that you filmed for purposes of the rebuttal documentary, right?
A. At the time I don't think there was a rebuttal documentary. My understanding was she
was responding to some of the comments that Bashir made on his documentary.
Q. And that interview took place at your home, correct?
A. No.
Q. Where did that take place?
A. At Marc Schaffel's house in Calabasas.

Q. Oh, okay. Okay. Do you know approximately when that interview took place?
A. I believe early February 2003.
Q. So it took place before you filmed the Arvizo family, right?
A. That's correct.
Q. Did you meet Ms. Rowe at Marc Schaffel's house?
A. I met her at -- well, not for the first time, but, yeah, I saw her.
Q. But when you filmed her for purposes of responding to the Bashir documentary, you
traveled to Schaffel's home, correct?
A. That's correct.
Q. And when you got there, was Debbie Rowe present?
A. Or she came afterwards.
Q. You didn't bring her there, right?
A. No.
Q. So your understanding on February 20th was that Schaffel had no problem with Debbie
Rowe knowing where he lived, but he didn't want the Arvizos to know where he lived,
right?
A. That could be so, yeah.
Q. But he never told you why he didn't want the Arvizos to know where his house was?
A. No.
Q. Now, it was no secret that the purpose of the rebuttal documentary was to put Mr.
Jackson in a positive light, right?
A. Sure.
Q. Everyone knew that was the purpose, right?
A. Yeah.
Q. It was meant to be a response to the Bashir documentary, right?
A. That's correct.
Q. It was meant to show things that Bashir had left out of his documentary that were
positive about Michael, right?
A. That's correct.
Q. You actually had volunteered to provide footage that Bashir had left out of his show,
right?
A. Did I volunteer?
Q. Yes. It was partly your idea to include your footage in the response to Bashir, right?
A. Um -Q. Let me rephrase it if it's unclear.
A. Please. Q. At some point following the airing of Bashir, you came forward and said, I
have footage of what positive things Bashir said about Michael, right?
A. This, I believe, was prior to the airing it. Prior to the airing the ABC version of Martin
Bashir in the United States.
Q. Yes. Okay. Let me restate the question. You saw the Bashir documentary at some
point, right?
A. At one point, yes.
Q. When you saw it, you realized he had left out a lot of footage where he praises Michael
Jackson, right?
A. No.
Q. Well, he had footage where he praised Michael Jackson for being a good parent, right?
A. Well, I mean, let me correct -Q. Sure.

A. Okay. The timing of how you're putting it is kind of off.

Q. Oh, okay.
A. I was told by Mr. Jackson's personal assistant at one point, before this documentary,
the ABC version of the Martin Bashir was aired in United States; that Martin Bashir is
going to air his own version in London through BBC, I believe. At that point I brought up
the fact that I have some footage of the behind the scenes. So at that time I have not
seen the Martin Bashir footage yet.
Q. Okay.
A. Am I clear?
Q. At that particular time, you were the only one that had a copy of your footage, right?
A. That's correct.
Q. Okay. And did you talk to representatives of FOX about including your footage in the
FOX documentary?
A. No.
Q. Okay. Who did you talk to about including your footage in that show?
A. Well, this is how it happened: I talked to Mr. -- Miss Evvy Tavasci, which is Mr.
Jackson's personal assistant. I informed her that I have footage of the behind-the-scene
and other footage of the interview.
Q. Uh-huh.
A. And I offered her to look at it. And she refused. She said, It's okay. Don't worry. Mr.
Jackson has obtained lawyers and they're going to take care of this matter. I took the
footage with a video camera and a play-back machine to the office of Miss Tavasci to show
her what I have. She still refused to look at them, and she indicated that I should not be
worried about it, and Mr. Jackson's lawyers will handle the situation. Then -Q. And what did you do next?
A. Next, I believe I spoke to Mr. Jackson and he asked me to call Dieter -Q. Okay.
A. -- about the matter.
Q. Right.
A. I spoke to Dieter, and I told him what I have, and he informed me that I'm going to go
to Florida for another type of filming, and we're going to discuss this matter with him.
Q. And it was after that that you flew to Florida, right?
A. Yes.
Q. And you flew to Florida expecting to do some filming, right?
A. That's correct.
Q. And at some point in Florida you learned that there was a change of plans and there
would be no filming; is that correct?
A. That's correct.
Q. How long were you in Florida for that trip?
A. I think a day, one day maybe.
Q. Do you know approximately when that was?
A. I don't have my records here. But I believe it's like February 6th and 7th. Something
like that.
Q. Do you remember hearing anything about a press conference that was cancelled in
Florida?
A. Did I hear that there was a press conference that was cancelled?
Q. Yes.
A. No.

Q. Okay. Do you recall any talk about a press conference in Florid a?

A. I asked what is the purpose of this filming -Q. Yes.
A. -- and they never give me a specific answer. But my understanding was that it could
have been either a press conference or a response in a video format from Mr. Jackson to
Mart in Bashir documentary.
Q. Okay. Now, how long after you got to Florida did you find out there was a change of
plans and you were not going to be filming anything?
A. I think hours after that.
Q. Okay. Did you spend the night in Florida on that trip?
A. Yes, I did.
Q. Where did you stay?
A. At the hotel.
Q. The Turnberry?
A. I don't remember the name of the hotel.
Q. Okay. And did you fly back on your own the next day?
A. Yes.
Q. Okay. And when you were in Florida for that trip, did you see Mr. Jackson?
A. No.
Q. Did you see any of the Arvizos?
A. No.
Q. Did you see Chris Tucker?
A. No.
Q. Did you see Dieter or Konitzer?
A. Yes.
Q. And where did you see them?
A. In their room.
Q. Okay. THE COURT: Okay, Counsel. Let's take a break. THE COURT: You may proceed.
MR. MESEREAU: Thank you, Your Honor.
Q. Mr. Moslehi, I believe you testified that you had approximately six or seven meetings
with the Arvizo family at various times. Does that sound right?
A. Approximately.
Q. Okay. And I believe you testified that Janet Arvizo told you in the phone conversation
of the 19th of February, 2003, that she was being hassled by the media; is that right?
A. That's correct.
Q. And she was not happy about that, correct?
A. That's correct.
Q. And in your interviews with representatives of the Santa Barbara Sheriff's Department,
you have discussed your various discussions with Janet, correct?
A. Could you refresh my memory?
Q. Sure. Sure. Maybe I'm not being clear. In your interviews with representatives of the
Santa Barbara Sheriff's Department, you have discussed conversations you had with the
Arvizos,correct?
A. Janet and the kids?
Q. Yes.
A. Yeah.
Q. And in your discussions with representatives of the prosecution, you have discussed
conversations you had with the Arvizos, right?

A. Sure.
Q. At no time did Janet Arvizo tell you she thought she was going to be murdered, right?
A. No.
Q. She never said that to you, right?
A. No.
Q. At no time did Janet Arvizo tell you there were death threats on she and her family,
right?
A. That's correct.
Q. At no time did Janet Arvizo tell you she or her family were being falsely imprisoned,
right?
A. That's correct.
Q. At no time did Janet Arvizo ever complain to you that Mr. Jackson was giving alcohol to
her children, right?
A. That's correct.
Q. At no time did Janet Arvizo ever complain to you that Mr. Jackson was improperly
touching any of her children, right?
A. That's correct.
Q. At no time did Janet Arvizo tell you her children were being abused by Mr. Jackson,
right?
A. That's correct.
Q. At no time did Janet Arvizo ask you to call the police on her behalf, right?
A. That's correct.
Q. Now, you testified that at Mr. Jackson's request, you did a video at Neverland called
Neverland Channel, right?
A. That's correct.
Q. And was it your understanding that was supposed to be a videotape featuring Star
Arvizo as sort of the narrator?
A. Well, initially my understanding was that we're going to do a pilot - a pilot is like a
sample of an idea in a video format - of an idea that Mr. Jackson have.
Q. And you did film that entire video, right?
A. That's correct.
Q. And the understanding was that Mr. Jackson would pay for your services in filming that
video, right?
A. That's correct.
Q. You also testified that you did a video of Mr. Jackson with Gavin, right?
A. The 2000?
Q. Yes.
A. Yeah.
Q. And it was your understanding Gavin was recovering from cancer, correct?
A. Well, Gavin had cancer. I'm not sure whether he was recovering or not, but -Q. But your understanding is he was ill?
A. Yes.
Q. And your understanding was that Mr. Jackson also agreed to pay for your services in
doing that video, right?
A. Customary, sure.
Q. Yes. At no time was it ever your belief that the Arvizos were supposed to pay for any of
these videos?
A. That's correct.

Q. Okay. Now, you currently have a lawsuit against Mr. Jackson, right?
A. Unpaid invoices, yes.
Q. Right. You're seeking unpaid invoices and some other benefits, right?
A. Like?
Q. Well, you're asking that invo ices be paid. You're also -A. Damages.
Q. Yeah. You're also talking about a profits interest that you claim Dieter and Konitzer
promised you, right?
A. That's correct.
Q. Now, in your lawsuit, you're also asking for damages related to a -- excuse me. You're
also seeking damages related to some footage of what you call Michael Jackson's Private
Home Videos,correct?
A. I believe so.
Q. And that was another FOX special that was done about Michael Jackson, right?
A. I believe so.
Q. And it's your belief that some of your work appeared in that show as well, right?
A. Yes.
Q. And it's your belief that you should be paid for your services in that regard, right?
A. For -- sure.
Q. Yes. Was it your belief that footage you did was going to appear both in the Povich
documentary and in another show done by FOX called Michael Jackson's Home Videos?
A. No. I was never been informed that there is a second documentary.
Q. Do you know, as you sit here today, whether or not there was a second documentary?
A. I did not know there was a second documentary. Meaning nobody informed me that
there's a follow-up, .nother piece of documentary called Michael Jackson's Home
Videos.
Q. Did you learn at some point that that had happened?
A. Yes.
Q. When did you learn that there had been a second documentary called Michael
Jackson's Private Home Videos?
A. I believe I've learned that watching T.V., been advertised.
Q. Okay. And that show appeared in approximately April of 2003, right?
A. Approximately.
Q. Did you watch that show on television?
A. Yes, I did.
Q. Okay. Your belief is you're entitled to a profit participation in whatever revenues were
generated from that show as well, right?
A. Well, I guess we have to talk to my lawyer in regard to that.
Q. Okay.
A. Because that's a technical question. I'm not a lawyer to make that kind of -Q. Okay. But your lawsuit is currently active, right?
A. It is.
Q. Okay. And your claim is that the agreements you had about being compensated for
your services and having a profit particip ation in these television shows were primarily
based on what Dieter and Konitzer told you, right?
A. Well, the invoices, it's part of customary transactions between me and MJJ
Productions.
Q. Right.

A. But the percentage was between Ronald, Dieter and me.

Q. Okay. And you don't know whether Dieter or Konitzer ever discussed a profit
participation with Michael Jackson, right?
A. With Mr. Jackson himself?
Q. Yes.
A. I'm not sure.
Q. They just told you talk to them and don't talk to Mr. Jackson, right?
A. That's correct.
Q. Okay. Now, I believe you said that approximately February 21st, 2003, Michael Jackson
called you to thank you, right?
A. That's correct.
Q. Now, obviously when he called you to thank you, he hadn't seen what you had filmed,
right?
A. Filmed what?
Q. Well, the footage you did of the Arvizos, he could not have seen, true?
A. Oh, of the Arvizo family footage.
Q. But nevertheless, he called you and thanked you for what you had done, right?
A. After seeing The Footage You Were Never Meant To See, I believe that's why Mr.
Jackson called me, to thank me.
Q. He was talking about the Bashir footage that you had done; is that correct? MR.
AUCHINCLOSS: Objection; requires speculation. MR. MESEREAU: I'll rephrase it.
Q. When Mr. Jackson called you to thank you on February 21st, was it your understanding
that he was thanking you about what you had done in the Bashir interview? MR.
AUCHINCLOSS: Objection; speculation. THE COURT: Overruled. You may answer. THE
WITNESS: My understanding for that thank-you call was that Mr. Jackson saw the rebuttal
documentary, the entire Footage You Were Never Meant To See, and because of what
I've done -Q. BY MR. MESEREAU: Yes.
A. -- he's calling to thank me.
Q. But he obviously, at that point, had never seen your film of the Arvizo family, right?
A. No.
Q. Because you had control of that, right?
A. That's correct.
Q. You had never released that, right?
A. That's correct.
Q. And he was thanking you for what was on that Maury Povich documentary, true? MR.
AUCHINCLOSS: Objection; asked and answered. THE COURT: Sustained. MR. MESEREAU:
No further questions, Your Honor. THE COURT: Counsel? MR. AUCHINCLOSS: Thank you,
Your Honor.
REDIRECT EXAMINATION BY MR. AUCHINCLOSS:
Q. During the period of time that you were working with the Arvizos on this rebuttal film,
you've told us about Christian Robinson, Brad Miller, Paul being present, Vinnie being
present, you and your crew. As far as you know, was anybody else invo lved in this
rebuttal video?
A. Being involved or being present at my house?
Q. That's a good question. Let's add a few names. You mentioned that Frank was involved

in it; is that correct?

A. He was invo lved with it, yes.
Q. And Mr. Schaffel was involved in it?
A. That's correct.
Q. And Mr. Konitzer was involved in it?
A. I'm -- sure.
Q. He talked to you about it, right?
A. I think most of the conversation was going through Dieter than Ronald in regard to
that.
Q. Was Ronald present in that conversation?
A. It was a phone conversation, so I don't know whether Ronald was listening to that or
not, or whether they had conversation within themselves.
Q. Okay. But you also mentioned a conversation you had in Florid a with Ronald and
Dieter?
A. That's correct.
Q. Did they discuss filming the rebuttal film at that time?
A. At that time, the discussion was about what I had already filmed of Mart in Bashir.
Q. Okay.
A. There was nothing on the table as far as project goes.
Q. Okay. So as far as the project goes, they just told you to talk to Mr. Schaffel? MR.
MESEREAU: Objection. Leading; assumes facts not in evidence. MR. AUCHINCLOSS: I'll
strike the question.
Q. So as far as the project goes, what did they direct you to do?
A. Once we discussed what I have as far as the footage that I shot of Martin Bashir
interview with Mr. Jackson, and once we agreed to certain terms,they informed me and
advised me to go to L.A. and talk to Marc Schaffel.
Q. Okay. And the purpose of this, you've testified, was to make Michael Jackson look good
ultimately, the whole rebuttal film?
A. That's correct.
Q. Okay. So other than the names I've mentioned, were -- were there any other people
involved in this enterprise of making the entire rebuttal film, as far as you know?
A. Um -- okay, can we go through those names one more time? Just so I don't
misunderstand.
Q. Okay. Mr. Jackson, Ronald, Dieter. We've got Mr. Schaffel, Frank, Vinnie, Christian,
Paul -- MR. MESEREAU: Objection to the question. I don't think it's -- I think it's a
compound question. MR. AUCHINCLOSS: I'm asking him for other names. THE COURT:
He's clarifying an earlier question. Overruled. Go ahead.
Q. BY MR. AUCHINCLOSS: Paul. Brad Miller. You and your crew.
A. Well, there was another production company called Brad Lachman Productions -Q. Okay.
A. -- which FOX hired to put the final editing together.
Q. Very good. Anybody else other than that?
A. Not that I remember right now.
Q. When you were engaging in the production or the putting together the various videos
that were going to make up this rebuttal film, what were the issues that you were trying
to address specifically?
A. Comments that Martin Bashir made on his own documentary.
Q. Were there comments that Mr. Jackson himself made that you were attempt ing to

address?
A. On the Martin Bashir documentary?
Q. In your rebuttal, yes.
A. Well, we tried to clarify certain statements that Mr. Jackson made which, for examp le,
if Martin Bashir would have continued rolling, I mean, or editing that -- let me try this
again.
Q. Sure.
A. There were certain statements that were made by Mr. Jackson in the Martin Bashir
documentary -Q. Uh-huh.
A. -- that the way it was edited, what happened is Mr. Jackson sounded different than if
they would have continued another two or three seconds of that statement.
Q. Give me an example.
A. Um -- um -- THE COURT: Counsel, I have to ask a question. Why are you going into an
area that I told the defense they couldn't go into? My objection's sustained. MR.
AUCHINCLOSS: Okay. Thank you, Your Honor. I'll move on.
Q. What was the level -- well, let me ask you this: W as there any sense of urgency in the
creation of this rebuttal film? MR. MESEREAU: Objection; vague. THE COURT: Overruled.
You may answer. THE W ITNESS: We tried to get it as soon as possible.
Q. BY MR. AUCHINCLOSS: Okay. And why was that? MR. MESEREAU: Objection;
foundation. THE COURT: All right. I'll sustain the foundation objection. MR.
AUCHINCLOSS: Okay.
Q. Do you know why there was a sense of urgency in creat ing this film?
A. My opinion? Or was there any discussion from any party?
Q. Did you discuss the timing issues of this film with any of the people that I've mentioned
previously that were involved in it?
A. Well, once this project was sold to FOX, they set up a date, deadline to be aired.
Q. Okay.
A. So basically, based on that date, we'll try to squeeze everything in there and finish it.
Q. And that date was?
A. February 20th.
Q. Midnight February 20th; is that right?
A. Well, the deadline to provide the footages was I believe the 19th, February 19 of 2003,
to be aired on February 20th, 2003.
Q. In terms of the Martin Bashir special, was there any editing done by Mr. Bashir that
was problemat ic, that you saw, that misrepresented Mr. Jackson's statements about him
sleeping with children? MR. MESEREAU: Objection. Foundation; leading; Court order. THE
COURT: The objection is sustained. It's the area I told you not to go into. MR.
AUCHINCLOSS: All right.
Q. Was that area one of the areas that you felt you needed to work on? MR. MESEREAU:
Same objection. THE COURT: Sustained. MR. AUCHINCLOSS: All right.
Q. As far as the -- I want to talk now about the activities that occurred at your home when
the Arvizos were being filmed. You mentioned that Janet was -- expressed some
reluctance to sign this release; is that correct? MR. MESEREAU: Objection; misstates the
evid ence. THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did Janet express any reluctance to sign this release?
A. What I saw is that there was a con -- a conversation and a discussion between Janet
and Vinnie and other parties about this release or document that was presented to her.

Q. Did that discussion cause any delay in the shooting of the filming?
A. A little bit. A little b it.
Q. How many minutes of delay, would you say, if you can characterize it?
A. I would say 15 minutes.
Q. And you said that Vinnie used your phone number?
A. My fax.
Q. Your fax number.
A. Or they could have used my phone, too.
Q. Do you know if he used your phone number?
A. To call somebody?
Q. Yes.
A. I remember my phone being used, but I didn't know who's calling who or what. But I
remember my phone being used.
Q. Do you know the number (310) 283-5866?
A. That's my cell phone number.
Q. That's your cell phone number, okay. As far as the use of your fax machine, do you
know if Vinn ie made any documents that came from your fax machine?
A. I believe that he either received or send some faxes through my machine.
Q. When Janet had finished with negotiating or talking with Vinnie, Christian and Paul, you
mentioned that Vinnie, Christian and Paul seemed happy previously, correct?
A. It seemed to me that the matter has been resolved, but -Q. Did Janet seem happy, or could you tell? You tell me.
A. Well, when we started filming, she appeared happy. But I don't know, prior to, whether
or not she was happy or not. I don't know.
Q. Was there a change in her demeanor from before filming to when the cameras started
rolling?
A. Repeat that one more time.
Q. Was there a change in her demeanor from before the cameras were ro lling and she's in
your home for this however -- I guess you said it was over an hour -- to the time the
cameras started rolling, was there a change in Janet's demeanor?
A. She seemed more energetic when the cameras are rolling.
Q. You were asked if you saw any coaching, and you said, No.
A. Not that I remember seeing any coaching.
Q. Do you know if she was coached?
A. I don't know that.
Q. Do you know whether or not -- did you keep your eye on her the entire time that she
was in your house?
A. The entire house? No.
Q. Was there an opportunity for her to be coached? MR. MESEREAU: Objection.
Foundation; calls for speculat ion. THE COURT: Calls for a conclusion. Sustained.
Q. BY MR. AUCHINCLOSS: You mentioned that you went to Neverland at one time for
the filming of 60 Minutes, correct?
A. Yes.
Q. And was that cancelled?
A. Yes.
Q. Do you know why?
A. I don't.
Q. As far as the entire documentary, this rebuttal documentary, you mentioned that you

were to receive some points?

A. Percentage.
Q. A percentage?
A. Yeah.
Q. When you spoke to Ronald and Dieter, was it contemplated that this documentary was
a for-profit enterprise?
A. For profit?
Q. Yeah, would make money.
A. Sure.
Q. Do you know if it made money?
A. I think it did, yes.
Q. Do you know how much it made? MR. MESEREAU: Objection; foundation. THE COURT:
Sustained.
Q. BY MR. AUCHINCLOSS: Do you know how much -- was there any discussion about
how much this documentary was anticipated to make with Dieter and Ronald?
A. Well, FOX -- MR. MESEREAU: Objection; foundation. THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Did you have a discussion with Dieter and Ronald about the
profitability or the amount of money that this documentary or rebuttal could make?
A. Did I have any conversations with them that this documentary will make -- well, we
knew there was going to be some money made off of it.
Q. Yes.
A. But we didn't know how much at the time.
Q. Did you have an idea? MR. MESEREAU: Objection. Foundation and Court order. MR.
AUCHINCLOSS: It's a yes or no. That's fine, Your Honor. I'll move on.
Q. Now, as far as the -- the Arvizos being taken off -- the Arvizo children being taken off
of Neverland, you answered a few questions for counsel concerning that issue when you
took the children off Neverland. And you said there was a period of time, I believe it was
about a half an hour, between when you first talked to Joe Marcus and he said the
children were not allowed off the property and the time when you actually left; is that
right?
A. I believe so, yeah.
Q. Did you see where he went during that half hour at all?
A. No, I didn't.
Q. If you wanted to contact Mr. Jackson when he was away from Neverland, how would
you do it?
A. I would either call his bodyguards or his office.
Q. Okay. Why would you call his bodyguard?
A. Well, that's the fastest way to get to Mr. Jackson.
Q. Does Mr. Jackson carry a cell phone?
A. I don't believe so.
Q. Do his bodyguards carry cell phones?
A. I think they do.
Q. Have you seen this?
A. Yes.
Q. If he wants to make a call, do you know what he does in terms of use of a cell phone?
MR. MESEREAU: Objection; foundation. THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: Have you seen Mr. Jackson ever use a cell phone? MR.
MESEREAU: Objection. Foundation; calls for speculation; beyond the scope. THE COURT:

Overruled.
Q. BY MR. AUCHINCLOSS: Have you seen Mr. Jackson ever use a cell phone over the
years you've
20 known him?
A. Dialing it, or just talking on it?
Q. Talking on it.
A. I've seen him talking on the cell phone.
Q. Whose cell phone would he use?
A. I'm assuming his bodyguards', but I can be wrong.
Q. Okay. So after this half hour passed and you left the property, did Joe Marcus offer any
resistance?
A. No.
Q. Did he seem to be okay with you taking the children off property?
A. Sure.
Q. You said that you had a conversation at Neverland with Mrs. Arvizo, and your sense
was that she approved of you taking the children to your home. I believe that was your
testimony. You correct me if I'm wrong. Is that accurate?
A. If I remember correct ly, after I had a conversation with her, my understanding was
that she's going to participate in this rebuttal documentary, but she's not going to be at
Neverland, so therefore we went to L.A.
Q. Okay. So that was on the evening of February 19th?
A. That's correct.
Q. And your deadline was midn ight on February 19th; is that correct?
A. That's correct.
Q. Was an arrangement made with Brad Lachman Productions that if you got the Arvizo
film to them by midnight, they would still be able to incorporate it into the final production
of the rebuttal film?
A. If I remember correct ly, if we had any add itional or new footage that we wanted to put
into this documentary, should be delivered no longer than midnight 19 -- February 19.
Q. Okay. If you delivered it on February 19th before midn ight, was it your understanding
there was still t ime to get it into the final version?
A. Yes.
Q. And your testimony is that you didn't make that deadline?
A. Yes, we missed that.
Q. When you originally talked with Dieter and Ronald about being paid the money that you
were owed, was it understood that upon the completion of the Arvizo film, you would be
paid, the filming of the Arvizos?
A. Upon airing The Footage You Were Never Meant To See.
Q. Okay. And the Arvizo footage was just part of that?
A. That's correct.
Q. All right. Did you anticipate that you would be getting a payday - in other words, a
payment of all the money that was owed to you - after the 20th of February?
A. I was expecting the 21st, by midday, I would receive my payments in full, plus what
they promised me.
Q. Okay. Are you aware of whether or not this documentary was also sold all over the
world?
A. It is sold all over the world.
Q. Okay. This rebuttal film was sold all over the world?

A. That's correct.
Q. In terms of the filming of the Arvizos, the footage that you obtained, is this footage -was this footage at the time, did you consider it to be valuable? MR. MESEREAU:
Objection; vague. THE COURT: Sustained.
Q. BY MR. AUCHINCLOSS: At the time that this footage was filmed, you understood that
it was not going to make it into the Brad Lachman production, correct?
A. Well, I was hoping that I can get it done by midnight.
Q. Okay.
A. But once we passed the deadline, I figured it's not going to happen.
Q. And you shot it anyway because of what?
A. Well, because I was told to, and also I wanted to do my job. I mean, I had a
responsibility and I wanted to do that.
Q. And who specifically told you to shoot that footage?
A. I believe it was arranged through Marc Schaffel and Dieter, those people.
Q. Did you discuss with anybody the fact that you weren't going to make the deadline and
that you should go ahead and shoot it anyway?
A. I don't remember discussing the deadline with anyone. This was just in my mind.
Q. Okay. So that was your decision to go ahead and shoot it anyway?
A. Well, I figured since I had my crew and equipment ready, if they are happy to
participate, get it done at least.
Q. Was there a discussion at the shooting about the deadline; that it had to be done by
midnight?
A. I think I mentioned to one of these guys that, Guys, we're not going to make it
anyway. But -Q. Do you know if either Christian or Paul or Vinnie knew about the deadline?
A. I'm not sure about Vinnie, but I'm sure Christian and Paul should have known about the
deadline.
Q. And I believe your testimony is that Christian wanted the video to take with him?
A. They wanted to take the tapes that night, yes.
Q. Even though it was too late to put it on the -A. That's correct.
Q. All right. If you -- are you familiar with the value of footages such as this, you know,
footage concerning a family that is of public interest on the open market? MR. MESEREAU:
Objection. Vague; Court order. MR. AUCHINCLOSS: I'm unfamiliar with the Court order,
but -- THE COURT: I'll sustain the objection. It's the restrictions I've placed on financial
informat ion. MR. AUCHINCLOSS: All right.
Q. You testified that you gave Janet Arvizo $2,000, considered it a loan, and were asked a
number of questions about financial condit ions involving Janet Arvizo. Would it have made
any difference to you in giving Janet Arvizo this $2,000 if you learned that some people
gave her some money three years earlier based upon Gavin's illness? Would that have
made any difference to you? MR. MESEREAU: Calls for speculation and misstates the
evid ence. THE COURT: Overruled. You may answer. THE WITNESS: Um, can you repeat
the question one more time?
Q. BY MR. AUCHINCLOSS: My question is, you gave her this $2,000.
A. Okay.
Q. You previously stated you were concerned about Janet. Her world was upside down is
what you've said. Would it have made any difference, would it have prevented you from
doing this act of generosity or kindness if you knew that years earlier she had received

some money for charitable -- from charitable ind ividuals to help Gavin? Would that have
made any difference?
A. I believe, depending on the timing and the amount of money, it could have been.
Q. Okay. So let's say she got $20,000 to help Gavin with his illness in terms of creating a
safe room for him, that type of thing.
A. Three years prior?
Q. Yeah. W ould that have made any difference to you?
A. For 20,000 three years prior, no.
Q. And what about if she got a civil judgment for about 30,000 three years prior, would
that have made any difference?
A. Three years -- MR. MESEREAU: Objection; misstates the evidence. THE COURT:
Overruled. You may answer. THE W ITNESS: Three years, 30,000, no.
Q. BY MR. AUCHINCLOSS: Okay. You were asked if she told you some things about her
circumstances at the time. Did Janet confide in you anything other than the fact that her
world was upside down at that time?
A. I don't remember.
Q. Okay. Did you have a relationship with Janet where she would sit down and confide
with you details about her problems, other than what you've stated?
A. Did I have a relationship? Such as -Q. Is she the type of person that would sit down and confide in you personal things?
A. I believe because I worked with her kids a lot during a few other productions, she kind
of felt comfortable to just empty herself of whatever she had in mind, I guess, at that
time.
Q. And did she do that in that phone conversation with you at Neverland?
A. Did she did that on that conversation?
Q. Yeah. That you had when you were at Neverland.
A. I believe the way she was expressing her, you know, personal life matters, in this case
being upside down because of the media, I felt like, you know, she needs a shoulder to
cry, kind of things.
Q. Did she do that any other time?
A. No.
Q. When you were -- well, I want to go through this time period of February 20th to the
21st. And I want to talk particularly about your conversation with Mr. Jackson on that.
First of all, when you talked to Mr. Jackson after the filming -- or after the airing of the
rebuttal film, you mentioned that you talked to him about some financial problems that
you were having with him and his production company.
A. I believe what I d iscussed with him is that my invoices are not being paid.
Q. Yes.
A. And also some other issues.
Q. Did you talk to him about the fact that you were also promised some -- a percentage of
the rebuttal film?
A. I don't think I went that far. But I just wanted to keep it simple and, you know, short
with him, just so, you know, whomever he needs to call, please call, because I'm not
being paid.
Q. Did you explain that you hadn't been paid in years, or over a year, I guess it was?
A. I'm not sure whether I mentioned the period of time that I'm not getting paid, but I
said that my invoices are not being paid, and I -Q. Did you mention the amount of money that was owed to you?

A. I don't remember.
Q. Okay. And what did he tell you to do about these problems?
A. He asked me to call David LeGrand, his lawyer.
Q. And did you call David LeGrand?
A. Yes, I did.
Q. And you told him about the problems?
A. Well, he knew the problem. I told him that, Mr. Jackson wants to talk to you, so why
don't you call Mr. Jackson.
Q. Okay. Did you mention to him that it was about finances?
A. I -- well, I don't remember specifically on that conversation whether I spoke or not. But
during the day, during the whole entire day, I'd been calling them and asking, you know,
What is it with my payment? So they were well aware of that I'm not being paid, that
they have not made the payment.
Q. Sometime later in the day, d id you receive a fax from David LeGrand that same day?
A. I believe it was the 21st, yes. MR. AUCHINCLOSS: If I may approach, Your Honor. THE
COURT: Is that a marked exhibit? MR. AUCHINCLOSS: Yes, it is.
Q. Mr. Moslehi, I show you Exhibit No. 851. Appears to be a two-page document with a
fax page on the first, and the top being -- at the top of each page are the words Hale
Lane. Do you recognize that document?
A. Yes, I do.
Q. What is it, please?
A. This is a letter from David LeGrand dated February 21st, 2003. It was faxed to me. And
is telling me that my services are no longer required. And then also Mr. Weizner and -MR. MESEREAU: Objection; hearsay.
Q. BY MR. AUCHINCLOSS: Okay. I'll ask you, is this the document that you received
from Mr. LeGrand in response to your conversation with him that he should call Mr.
Jackson?
A. That's correct.
Q. And was a copy of this letter -- does this letter indicate a copy was sent to Mr.
Jackson?
A. Um -- MR. MESEREAU: Foundation. THE WITNESS: It says carbon copy -- THE COURT:
Just a moment. THE WITNESS: I'm sorry. MR. AUCHINCLOSS: This is offered as
foundation. THE COURT: All right. Overruled.
Q. BY MR. AUCHINCLOSS: Does it indicate that a copy was sent to Mr. Jackson?
A. This letter is signed by David LeGrand and it's carbon copy, cc, to Michael Jackson,
Ronal Konitzer, John Genga.
Q. And the facsimile page on the front, the first page, does it also indicate that copy was
sent to Mr. Jackson at Neverland Valley Ranch?
A. That is correct. MR. AUCHINCLOSS: All right. Offer 851 into evidence, Your Honor. MR.
MESEREAU: Objection. Foundation and hearsay. THE COURT: I need to see the document.
MR. AUCHINCLOSS: Yes. It is offered as an authorized admission, as well as it is offered
for nonhearsay purposes to show knowledge on behalf of the defendant. There is one
further authentication issue that I will mention; that this is defense discovery to the
People, so this is a copy of a document that's in the defendant's possession. THE COURT:
That doesn't authenticate anything. The only foundational issue that I just have a
quandary about is how he knows that this is from -- who it purports to be from. MR.
AUCHINCLOSS: It's a response to -- THE COURT: No, how the witness knows, not how
you know. MR. AUCHINCLOSS: No, I mean his testimony is that he called Mr. LeGrand

that day and received this letter. THE COURT: I'd like to hear from -- I'll allow you to -before I rule on the foundation issue, I'll allow you to ask him any other questions you
have on that issue to -- MR. AUCHINCLOSS: Thank you. THE COURT: -- authenticate
that.
Q. BY MR. AUCHINCLOSS: Mr. Moslehi, how long after the conversation with Mr.
LeGrand on the 21st -- first of all, let me ask you, did you receive this communication,
Exhibit 851, before or after you spoke to Mr. LeGrand on the phone?
A. After.
Q. How much time after?
A. A few hours.
Q. And this document references a communication regarding future -- your business
affairs that is -- that you are to have with Dieter W eizner and Ronald Konitzer on February
24th, 2003. Are you aware of that?
A. I'm sorry, um -Q. If I may show you the exhibit again. Page two, paragraph two. MR. MESEREAU:
Objection. I'm not sure what the procedure is. THE COURT: Excuse me. MR.
AUCHINCLOSS: Well, I'm -- THE COURT: Why are you showing him the document?MR.
AUCHINCLOSS: I'm sorry. I'm sorry. I'll go about it the proper way.
Q. Would -- does this letter have a paragraph in this ind icating that you are to
commun icate with Ronald Konitzer and Dieter on February 24th, 2003?
A. Yes, it does.
Q. Did you commun icate with them on that date?
A. And prior, yes.
Q. Did you discuss this letter with them?
A. Yes, I did.
Q. Did they appear to understand and know about it?
A. They were playing games with me.
Q. Okay. But did they pretend that they didn't know about this letter, or did they -- MR.
MESEREAU: Objection. Leading; foundation. MR. AUCHINCLOSS: I'll strike the question.
THE COURT: Sustained. MR. AUCHINCLOSS: May I ask the next question? THE COURT:
Yes.
Q. BY MR. AUCHINCLOSS: What do you mean they were playing games with you?
A. I would call D ieter, and Dieter would say call Ronald, and they were not responding to
my phone calls properly. And they told me this was probably a misunderstanding, or -you know, games.
Q. All right.
A. They were not sincere about their statements or, you know, whatever they had in
mind. MR. AUCHINCLOSS: I wou ld offer 851 into evidence at this time. MR. MESEREAU:
Same objection. THE COURT: How did you know that that letter came from Mr. LeGrand?
THE WITNESS: Because it was faxed from his office, and it had a cover sheet and it's
signed by Mr. LeGrand. THE COURT: Did you recognize that signature? THE W ITNESS: I
believe it was the first time I saw Mr. LeGrand's signature, but I had every reason to
believe that that was from Mr. LeGrand. THE COURT: All right. I'm going to reserve ruling
on that. I have some problems with your foundation. MR. AUCHINCLOSS: Okay. I'll ask a
couple more questions along those lines.
Q. Have you subsequently received any faxes from Hale Lane, Attorneys at Law?
A. After that?
Q. Yes.

A. Yes, I have.
Q. Did they look identical in terms of the appearance of the fax letterhead?
A. Yes, they did.
Q. Have you subsequently received letters from David LeGrand?
A. After that one?
Q. Yes.
A. I believe maybe I received one or two, and then he started communicat ing with my
lawyer.
Q. Okay. As far as those letters go, did they match, did the signature match?
A. I never tried to look into the signature, see if it matches. Once I received that
letterhead, I had every reason to believe that it's coming from David LeGrand.
Q. Did you -- this is a fax letter with a fax letterhead. Did you subsequently receive this
letter by way of U.S. Mail?
A. I don't believe so. MR. AUCHINCLOSS: Okay. Thank you. No further questions. THE
COURT: All right. MR. MESEREAU: May I see that exhibit? MR. AUCHINCLOSS: Uh-huh.
RECROSS-EXAMINATION BY MR. MESEREAU:
Q. Mr. Moslehi, if you had known that Janet Arvizo was living with someone who earned
close to $80,000 a year, would you have loaned her that $2,000? MR. AUCHINCLOSS:
Objection; assumes facts. THE COURT: Overruled. You may answer. T HE WITNESS: If I
knew that Janet Arvizo was living with another husband or just a person that has
$80,000?
Q. BY MR. MESEREAU: Who was supporting her and who earned close to $80,000 a
year, would you have loaned her the 2,000?
A. Well, at the time, my state of mind was different. I don't know. Today, probably not. Q.
Okay. Now, the letter that the prosecutor just showed you, which purports to be from the
Hale Lane law firm, is dated February 21st, 2003, right?
A. That's correct.
Q. And you claim you did receive this letter, right?
A. That's correct.
Q. And in the letter, you were asked to return tapes, photos and other property of MJJ
Productions by a certain date, correct?
A. Yes, it is.
Q. The date you were supposed to return those properties was February 24th, 2003,
correct?
A. I -- I'm not sure. I don't have it in front of me, but if you say so, I take your word.
Q. Okay. And the letter suggested that your invoices will be addressed, correct?
A. I'm not looking at the document, but if you say so, I take your word.
Q. And at some point after this letter was received, you obtained or received payment of
$200,000, correct?
A. I believe a month after I received that letter, approximately a month after, I received.
Q. So approximately late March 2003, you received payment of $200,000, true?
A. That's correct.
Q. You never returned the tapes or photos referred to in the letter, true?
A. What does it refer in the letter?
Q. Any tapes, photos or other property of MJJ Productions, or Michael Jackson or his
affiliates.

A. I don't -- after 21st, I don't believe so.

Q. Okay. To date, you haven't turned over all the tapes you did for Mr. Jackson, true?
A. Since my invoices were not paid in full, no. MR. MESEREAU: Okay. No further
questions. THE COURT: Was that 851 that you were quoting from? MR. AUCHINCLOSS:
Yes. THE COURT: All right. I'll admit it. MR. AUCHINCLOSS: No further questions. MR.
SANGER: Your Honor, we do have a motion, and it probably ought to be heard before this
witness leaves the general vicinity. THE COURT: You have no other questions of this
witness? MR. MESEREAU: No, Your Honor.

TERRY PAULSEN EXAMINATION

DIRECT EXAMINATION BY MR. NICOLA:
Q. Would you mind scooting up by that microphone, please?
A. Okay.
Q. And swivel that towards your mouth so that everybody can hear you. How are you this
morning?
A. Fine.
Q. Ms. Paulsen, who are you emp loyed with?
A. Huntel Systems.
Q. What is your position with Huntel Systems?
A. I'm a senior billing analyst.
Q. How long have you been working in that capacity with Huntel?
A. 27 years.
Q. And are you here today as the custodian of records for some documents from Huntel
Systems?
A. Yes.
Q. What kind of documents?
A. They're phone calls made from an aircraft, telephone calls.
Q. Air-to-ground telephone calls?
A. Yes.
Q. Pursuant to a search warrant, did you provide the documents that I'm going to hand
you marked as Exhibit 850, previously shown to counsel?
A. Yes, these are ones I provided.
Q. Could you describe those documents briefly for the jury, please?
A. It's phone calls made from an aircraft on February 7th, 2003.
Q. And the company that bill was sent to?
A. It was sent to Xtra Jet out of Santa Monica, California.
Q. With respect to the contents of that exhibit, is that generally a phone bill?
A. Yes, it is.
Q. Okay. And is your company a company that bills for phone calls made from aircraft to
the ground?
A. Yes.
Q. Does the document reflect information that's made in the regular course of the
business of Huntel?
A. Yes, it is.
Q. And Huntel is a telecommunications provider?

A. Huntel is -- we're the billing vendor.

Q. Okay. Is it part of your business to keep track of the kind of records that you're -A. Yes, it is.
Q. Okay. Now, the entries in the phone record, do they begin on a particular page in that
exhibit?
A. They begin on page four.
Q. Okay. Is there a page two or a page three in Exhibit 850?
A. No, there is not.
Q. Okay. Do you recall what is actually contained in the record of page two and three?
A. One of it is just information on paying your bill by a cred it card. The other was phone
calls that did not pertain to the date that we were requesting to provide.
Q. Is it customary to provide only what is reflected in the search warrant, as far as your
company is concerned?
A. Yes.
Q. And their request was for February 7th, 2003?
A. February 7th or 8th, but there weren't calls on the 8th.
Q. Is the information on that document relied upon by your company in the regular course
of its business?
A. Yes, it is.
Q. Okay. And do you rely on it being accurate?
A. Yes, I do.
Q. And briefly describ e for the jury how the information in those phone records is
generated.
A. When a customer makes -- or is flying in an airplane and they make a call, it goes from
the airplane to a ground station, out a landline to the party that's being called. And when
the call's completed, then the ground station records that in its memory. And once a
week, we go into the system, we -- through a modem telephone line, computer program,
we get that information out. And once a month, we process that into a telephone bill so it
puts it in a format that can print on a bill, reads the information that's taken from the
ground station.
Q. Does the ground station have an identifying number that shows up on the bill?
A. Yes, it does. MR. NICOLA: And, well, Your Honor, at this time I would offer 850 into
evid ence as a business record. MR. SANGER: No objection. THE COURT: It's admitted.
Q. BY MR. NICOLA: What I'm going to do, Miss Paulsen, is use the Elmo. Input 4, if
you don't mind, Your Honor. THE COURT: All right.
Q. BY MR. NICOLA: If you would turn to line 25, I would just like to show you a sample
line from this. If you could just start with the number 25 and explain to the jury what the
items mean as you go from left to right as you look at the exhibit,please.
A. Okay. Each call has its own item number. The date would be 2-07; would be it was
made February 7th. They called El Monte, California. The phone number, the 626 number,
is the number that they called. 6:57 p.m. is the time that they hung up from the call. So
the call was made one minute prior to that, and one minute tells you how long the call
lasted. CCD just means, years ago when these numbers were issued to companies, they
were called calling cards. So it just -- CCD is calling card. Then the -- there's two
charges per phone call, or the call's broken out into two different sections. One is the land
time, and that's from the time, if I called you, you picked up the phone. From the time
you pick up the phone till you hang it up, that's the land time. The air t ime is what is
actually charged, and that's the time from when I p ick up the phone in the airplane and I

hang up the phone. That's the air time. So there's two different times. the number called
which two calls go together. So in this case, Call 25 and 26 would go together. It was
made over Troy, Alabama, and the phone number under that would be the phone number
for Troy, Alabama.
Q. Is the number for the Troy, Alabama, place a ground station?
A. Pardon?
Q. Is that what you would call a ground station?
A. The ground station phone number.
Q. How does the wireless phone on the aircraft decide which ground station it's going to
repeat at; do you know?
A. Okay. As you're flying, the transmitter in the phone will pick up the strongest signal on
the ground station. The ground station sends up signals, and it picks up the strongest one.
So you don't have a choice of what station you're going through. It just picks it up and
places a call. So if you're flying near Troy, it's going to pick up the Troy, Alabama, ground
station.
Q. Now, with respect to the date stamp specifically on Item 25, it says 6:57 p.m. Is that
6:57 p.m. in any particular t ime zone? Or can you explain that for the jury, please?
A. The time zone is the time zone that the ground station is located in. So if you're flying
over Troy, Alabama, that would be the time of day at Troy, Alabama. If you're flying over
Los Angeles, California, it would be the Los Angeles time, so there could be a difference in
the time zones.
Q. Okay. Miss Paulsen -- I wasn't done with the Elmo. If I could direct your attention,
please -- and if I could have Input 4 again, Your Honor -- to Line No. 40.
A. Okay.
Q. And is that a call p laced to Santa Ynez, California?
A. Yes.
Q. You can read the area code and the number, please.
A. The area code is (805) 688-9979.
Q. And the time of that call, please?
A. Is 8:39 p.m.
Q. And where is the aircraft now?
A. The aircraft is over Artesia, New Mexico.
Q. Okay. Could you please flip to the second page of the exhibit?
A. Page five?
Q. Yes. And just tell the jury what time the last call was recorded from that aircraft.
A. Line Item 71?
Q. Yes, please.
A. It was placed at 9:28 p.m. on February 7th over Grand Canyon, Arizona. MR. NICOLA:
Okay. Thank you, Miss Paulsen. No further questions, Your Honor. MR. SANGER: Could I
have that? MR. NICOLA: Certainly. MR. SANGER: Just leave it up on the thing. MR.
NICOLA: Oh, on the -- MR. SANGER: Your Honor, I'm going to put this back up on the
Elmo and....
CROSS-EXAMINATION BY MR. SANGER:
Q. Okay. It's your understanding that this reflects telephone calls made fro m an airplane
that are eventually connected through to some land line somewhere, correct?
A. Yes.

Q. And when I say landline, it could be connected to a cell phone ultimately; is that
right?
A. It would still go through a landline to a cell phone. I mean, it goes out the ground
station, however the ground station sends it out.
Q. When you're talking about Troy, Alabama, there's some ground station there, and
essentially you're now hooked up with the phone system that we would hook into if we
pick up the kind of phone we pick up in the courtroom, right?
A. Right.
Q. And wherever that phone system then directs the call is the ultimate destination,
right?
A. Right.
Q. All right. And so just so we're all clear, you got two lines per call, right?
A. Right.
Q. And the one line shows the number that's called -- actually both lines show the number
that's called, correct?
A. Correct.
Q. And then the second line shows the charge to the airline; is that right?
A. Right.
Q. Now, first of all, the billing goes to a particular airplane or a particular company?
A. Particular co mpany.
Q. And so the company that owns the airplane will get the bill?
A. Yes.
Q. All right. Can you tell which airplane that belongs to that company was the source of
the telephone call?
A. No, I cannot.
Q. So if an airplane -- private charter airplane company might have several p lanes, and
their phone bill will not distinguish between one airplane and another; is that correct?
A. It will distinguish between one phone number and another, but not one airplane and
another.
Q. All right. And on the airplane, you have no idea how big these airplanes are; is that
true?
A. They're private aircraft. I'm -- I would assume like a jet or something, but I do not
know, no.
Q. Yeah. So you're making some assumptions, but you don't know how many people, for
instance, would be on the airplane, right?
A. No.
Q. And you have no way of determining what person on the airplane made the call,
correct?
A. No, I don't.
Q. So let's assume hypothetically that an airplane had two pilots, 11 passengers, and a
crew member. Assume that as a hypothetical. Of those 14 people, would you have any
way to determine from your records who made these phone calls?
A. No.
Q. Now, I do note that there are some phone calls, a number of them that are -- if we
look at the exhibit, and this is Exhibit 850, I believe; is that correct? You have the actual
exhibit in front of you.
A. Yes.
Q. And what's on the board is a copy of the same exhibit?

A. Yes.
Q. So if we look up at the top there where it says, Minute, or M- I-N -A. Uh-huh, yes.
Q. -- what is the minimum unit of time that will be recorded on your bill?
A. The minimum is -- you'll see there's a couple that are short-term charges that are 20 to
30 seconds. But the minimum usually is 30 seconds. But 20 seconds on.
Q. Okay. So on this particular bill, the minimum that we see on that page -- and I'm
taking this off so I can see it up close. The minimum charge -- or, I'm sorry, the minimum
recorded in the columns on this exhibit is one minute; is that right?
A. Right. So it rounds up to a minute.
Q. All right. So if there's a shorter call, it's still going to show up as one minute on the -in that column there; is that correct?
A. Anything over 30 seconds will.
Q. And you also, from this bill, do not know if two people were actually able to talk to each
another during these phone calls; is that correct?
A. It will connect. If it doesn't connect, it doesn't register.
Q. Okay. It connects to another phone, right?
A. Right.
Q. Now, this is basically a cell phone in the air, right?
A. Similar to a cell phone.
Q. And when you're flying and using one of these phones, you have to basically hit the
repeater down on the ground in order to make a connection, correct? Do you know what I
mean, or am I using the wrong word?
A. If you can, yeah, rephrase that for me.
Q. Well, you said it's like a cell phone in the air.
A. Right.
Q. So while you're flying along, your signal from the cell phone in the air has to hit -A. A ground station.
Q. -- the ground station. And that's called a repeater, is it not, or do you know? Or a cell
site?
A. I have no idea.
Q. Okay. Whatever it's called, you got to hit that thing, otherwise it doesn't work, right?
A. Right.
Q. And when you hit it, there are places where you will -- you'll hit it and you'll make a
connection, but you will not have a clear enough connection to actually talk; is that
correct?
A. There's that possibility, yes.
Q. So it's, in that sense, like a cell phone; that you can have bad reception, and you can
be saying, Can you hear me now? And somebody on the other side is saying, What?
Right?
A. True.
Q. Okay. So you do not know, from all these phone calls, how many actual conversations
occurred between human beings where they could hear each other and commun icate; is
that correct?
A. No. MR. SANGER: Okay. Thank you very much. No further questions, Your Honor.
REDIRECT EXAMINATION BY MR. NICOLA:

Q. You mentioned that sometimes the airline charges will be together and you need to
look at the actual time of a call that goes out?
A. Uh-huh. MR. NICOLA: If I could have the Elmo just one more time, Your Honor. THE
WITNESS: Excuse me. MR. NICOLA: I think we have an example here, line -- THE COURT:
I'm going to break now for the argument. (To the jury) Go ahead and take your recess.
MR. NICOLA: Oh, the motion. THE COURT: You may step down. MR. NICOLA: Step down.
(The following proceedings were held in open court outside the presence and hearing of
MR. AUCHINCLOSS: Your Honor, would you like the witness to leave the
courtroom? THE COURT: No. She may well want to. She's free to do so, but she doesn't -she's not required. MR. NICOLA: Are we back in session at 11:45, Your Honor? THE
COURT: At the end of our break, yes. Go ahead. MR. SANGER: On behalf of Mr. Jackson,
we are making a motion for mistrial based on prosecutorial misconduct. And the grounds
for that motion for mistrial are that the Court ruled, as Your Honor reminded me, at a 402
motion that we would not be allowed to play this tape in its -- in the prosecution's case-inchief. THE COURT: Correct. MR. SANGER: I made another motion contemporaneous in
time, having felt that it was appropriate to do so. The Court summarily, and I think
clearly, denied the motion. THE COURT: And correctly. No, all right, go ahead. (Laughter.)
THE COURT: You don't have to say that. MR. SANGER: I'm going to assert my Fifth
Amendment rights on that. I said that humorously, for the record. THE COURT: I took it
humorously, for the record. MR. SANGER: Thank you. The serious part here, though, is
that Mr. Auchincloss deliberately overreached. And the harm is, that having -- the Court
having made such a clear ru ling, he attempted to gain benefit from the Court's ruling that
he wasn't entitled to. Your Honor said we couldn't go into it, so he got up and went into it,
and that was clearly inappropriate to start with. And it seemed calculated and intentional.
Now, I can't read his mind. But I can't figure out how he could have missed that, after we
just had a hearing on it. Your Honor made an admonition -- and unfortunately my
Livenote is not hooked up today, so I can't quote verbatim, but Your Honor has it. You
gave an admonition to Mr. Auchincloss not to do that, and you explained to him exactly
why; that you had just ruled, and it's not appropriate for him to go into that same area.
He persisted and asked at least two more direct questions that just flew right in the face
of the Court's ruling. And the questions were not innocent questions that were going
around to try to get to something else. They were even more focused, to telegraph to the
jury exactly what he wanted them to hear. And he wanted them to hear that, in his
opinion, the issue with regard to, as I think he said, something like sleeping with boys was
not one of those areas that this witness felt was unfairly portrayed. And he knew that he
could get away with that because the Court was, at the very least, going to sustain the
objection. We already couldn't go into it. There's nothing we could do about it. The bell
has been rung, and this jury heard it. I think the harm is particularly significant, because
it's been our position that clearly those statements were the statements that were grossly
misrepresented by Mr. Bashir in the way he edited the film. So as a result of that, a
tremendous amount of prejudice has occurred. It was deliberate on the part of the
prosecutor. I say that, and that's my interpretation of what I saw. I don't think there's
another reasonable interpretation. It's -- there's no other remedy, other than to grant a
mistrial and say this is prosecutorial misconduct. It shouldn't have been done. As a result
of their willful misconduct, a mistrial has to be granted. And that's our motion. If the Court
denies that, then we would of course ask the Court to entertain some other remedy which
I'd ask to be heard on later, but I'm making a motion for mistrial, and I think it should be
granted. Thank you. THE COURT: Counsel? MR. AUCHINCLOSS: To begin with, the

questions that I was asking this witness about did not focus upon the material that was
produced in the video, The Footage You Were Never Meant To See. And those questions
were not designed and obviously were not intended to ask him about what was on that
final production. My question went directly to an issue that defense counsel spent five
pages questioning this witness about on cross-examination yesterday. And I have a couple
of those items highlighted, and if the Court would allow me, I'd like to project them from
the official transcripts. THE COURT: Just read them to me. MR. AUCHINCLOSS: All right.
First of all, Your Honor, counsel started by asking the question of this witness: And the
reason you were being interviewed by Brad Lachman Productions was because the
intention was to have some of those parts that you had filmed appear in the rebuttal
video, right? And I objected. I say, I'm going to object. Relevancy and beyond the
scope. Mr. Mesereau: I believe that he opened the entire door, Your Honor. The Court:
The objection is overruled. Mr. Mesereau: In fact, the title of that documentary on
television was, The Michael Jackson Interview: .The Footage You Were Never Meant To
See,' right? W e go on. He questions him extensively about The Footage You Were Never
Meant To See,including charities and Mr. Bashir's remarks. We get to an area here that's
particularly interesting in which counsel says: And your belief at that time was that Mr.
Bashir had presented a very distorted view of that interview with Mr. Jackson, correct?
Mr. Auchincloss: Objection; calls for a conclusion. Mr. Mesereau: State of mind, Your
Honor. Mr. Auchincloss: Relevance. The Court: Overruled. Now, this is an area that was
clearly gone into by the defense, and my questions went directly to that question that
defense counsel asked of this witness, that the -- that Martin Bashir presented a very
distorted view, and my questions went directly to those remarks. THE COURT: You went
from the general concept, which I allowed, to the specifics, which I was not allowing. The
motion for a mistrial is denied. All right. We'll take our break. MR. SANGER: Your Honor,
just -- if I may -- THE COURT: I'll let you address the issue of alternative remedies. I
thought you said you wanted to do that later. MR. SANGER: Well, later. Whenever you
want. THE COURT: I will. I'll let you do that. MR. SANGER: Okay. (Recess taken.) MR.
MESEREAU: I don't think Mr. Sanger is here, Your Honor. I think he was intending to
present some potential remed ies to the Court. THE COURT: Yes, that's what I thought he
was going to do. They're waving at you. MR. MESEREAU: Oh, okay. No, I said Mr. Sanger
doesn't appear to be here, and I think he wanted to present some alternative remedies to
the Court. And unfortunately, I don't know where he is. (Laughter.) THE COURT: Perhaps
we should just call the jury in and we could take up that issue later. Maybe he's doing
some research on that. MR. MESEREAU: Yes, Your Honor. Thank you. MR. NICOLA: He
may wish to recross after I redirect Miss Paulsen. He may wish to recross. THE COURT:
This is his witness? MR. NICOLA: Yes. THE COURT: So we have to wait for him no matter
what. MR. NICOLA: If you say I could be back on Friday, I'll go look for him right now,
Judge. Maybe he's in the law library? MR. MESEREAU: I really don't know. A VOICE FROM
THE AUDIENCE: There he is. THE BAILIFF: Yea. (Laughter.) THE COURT: I'm sorry. I
came out; I didn't know you were not here yet. MR. SANGER: I apologize. I had to go
back to my office and get something here. THE BAILIFF: I'm sorry, I thought he was here.
Sorry. MR. SANGER: Do you want to address the -- THE COURT: If you're prepared. I
came on so that you could do that. I don't know if you wanted to do it now or later. I
mis interpreted what you had said earlier, so.... MR. SANGER: That's fine, Your Honor. The
reason I wanted to bring it up sooner rather than later is that if the Court fashioned a
remedy that invo lved Mr. Moslehi, he would be here; and if you didn't, he could leave. So
let me just address it quickly. The motion for mistrial having been denied, and without

conceding anything in that regard, our alternative request would be to either have,
number one, an admonition to the jury that it was inappropriate to continue to as k those
questions and that you had precluded the defense from getting into it, and make it very
clear that those -- the questions, as the jury's been instructed, are not to be considered
unless there's an answer. But in this particular case, because you had already made
rulings very clearly, you want to make sure that there's no unfair inference drawn, even if
it's a subconscious or subliminal one. So some instruction to that effect, a curative
instruction of some sort to try to get us back to square one and unring the bell. Absent
that -- THE COURT: You're to disregard any subliminal messages you received during the
last session? (Laughter.) MR. SANGER: I'm sure we could word something more artfully
than the concept that I just floated there, but I think there is something that could be
done by way of a curative instruction to try to unring that bell. And I think it was
unfairness and it was a matter of seizing on what the Court has just ruled on, and I think
that's the big harm. It's not a matter that -- it's a matter that the prosecution had
objected to our bringing that tape in and then sought to gain the benefit of the Court's
continued ruling. If the Court does not do that, then I would ask -- or in the alternative,
either way, I'd ask the Court to allow us to now just play the outtakes, and that's -- THE
COURT: That's where I thought you were going. MR. SANGER: I didn't want to disappoint.
(Laughter.) MR. SANGER: And it's a fair way to do it, Your Honor. The outtakes are the
outtakes. And if the jury sees that, they'll be ab le to form their own opinion and they
won't be dealing with subliminal matters. They'll be dealing with liminal matters. I'll
submit it. THE COURT: (To Mr. Auchincloss) You can sit down. You know, I don't believe
that Mr. Auchincloss seized the moment to take advantage of you after objecting. You
know, I think there was a disconnect from -- in his brain somewhere about -- because he
was worried about the earlier examination that had been done. And I just don't believe he
was trying to do something to confront the Court or affront the Court. And I think I, you
know, saved the day by objecting myself, stopping it. So the jury has -- knows that I did
not think that was proper. They got the message loud and clear. I've never done that
before in this trial, so it was a very loud message I sent. So I think that's sufficient in this
case. So, do you have your witness here if we bring in the jury? MR. NICOLA: Yes, Your
Honor. THE COURT: All right. And, you know, the issue of the playing those tapes still
remains for your part of the case. That may well be. So if there's a foundational issue
here, you had suggested that the prosecution might agree. I would like that out of the
way, because I don't think -- if all we need is to have him come back, when all you want
to do is play the tapes, we wouldn't want to have to do that. You may want him back, too.
I don't know. But if that's something we could agree on, playing those outtakes without a
further foundation from him, if either of the parties desire, I think that would be a good
thing to do. But you can talk to each other about that. MR. SANGER: Very well, Your
Honor. MR. AUCHINCLOSS: And is it permissible for Mr. Moslehi to leave? He's waiting for
us. THE COURT: Yes. MR. AUCHINCLOSS: Thank you. THE COURT: But you understand
my issue on -- MR. AUCHINCLOSS: I do. And I think that's something -- THE COURT: -whether you want to agree to a foundational issue that he took those tapes. We've all
watched them. MR. AUCHINCLOSS: I'm certain if it's merely authentication, we can come
to some agreement. THE COURT: Okay. I'll leave while you bring the jury in (The following
THE COURT: All right, Counsel. Proceed, please. MR. NICOLA: Thank you, Your Honor.
May I have -- Input 4 is already on.
Q. Miss Paulsen, if I could d irect your attention to Item 29 and 30. There appear to be two

air link charges right behind each other. Is that an example of what you testified to on
direct as having to look for the corresponding number to figure out which charges go
together?
A. Yes, it is. Item 27 and 29 would go together. And Item 28 and 30 would go together.
Q. Okay. And Item 27 is registered in the bill as a two-minute call to the same telephone
number as Item 25; is that correct?
A. Yes.
Q. Okay. Once a call gets past one minute, does it register automatically in your system
as a two-minute call?
A. Anything over one minute, if it goes over a minute, it registers as two minutes. MR.
NICOLA: Thank you, Mrs. Paulsen. I have nothing further. MR. SANGER: Nothing further,
Your Honor. THE COURT: All right. Thank you. You may step down.

GABRIEL DOMINGUEZ EXAMINATION

DIRECT EXAMINATION BY MR. NICOLA:
Q. Are you here as a custodian of records for the telephone company T-Mobile?
A. Yes.
Q. How long have you been employed with T-Mobile, please?
A. For over four years.
Q. And have you testified before as a custodian of records for T-Mobile?
A. Yes.
Q. Approximately how many occasions?
A. Over 60 or 70 times.
Q. Is that your primary role with T-Mobile?
A. It is one of them.
Q. You go to court and authenticate the records that were asked for pursuant to subpoena
and search warrant?
A. Yes.
Q. Okay. With respect to this particular case, did your company send records pursuant to
search warrant for phone records for the following individuals: Christopher Carter;
Franchesco Cascio; Vincent Amen; Evelyn Tavasci; and Christian Robinson?
A. Yes.
Q. In front of you is Exhibit 452. Do you recognize that?
A. Yes.
Q. How do you recognize that?
A. I recognize this to be subscriber informat ion and billing records, or called detail records,
for the people you just mentioned.
Q. Is there a table of contents in that exhibit?
A. Yes.
Q. Have you compared the contents of the exhibit with the table of contents?
A. Yes.
Q. Have you looked through the entire exhibit prior to your testimony today?
A. Yes.
Q. Generally, and I mean this with respect to all the documents in that exhibit, save the
table of contents, are they records that are made in the regular course of T-Mobile

business?
A. Yes.
Q. Now, with respect to the specific subscriber information within those exhibits, is the
informat ion recorded on the subscriber report made by persons under a duty to record the
informat ion accurately at or near the time that the information is relayed to them?
A. Yes.
Q. Would you explain to the jury what a subscriber record is?
A. A subscriber record is a customer's name, address, Social Security number, and any
identifying information for that customer.
Q. Why do you need that information?
A. For billing purposes.
Q. I'd like you to turn specifically to Tab No. 1, and is that the information for one
Christopher Carter?
A. Yes.
Q. Okay. And Tab No. 2, please, is that the information for Franchesco Cascio?
A. Yes.
Q. Tab No. 3, please, is that the information for Vincent Amen?
A. Yes.
Q. Tab No. 4 and Tab No. 5 respectively, Evelyn Tavasci and Christian Robinson? MR.
SANGER: I'm going to object. That's compound. THE COURT: Overruled. THE W ITNESS:
Yes.
Q. BY MR. NICOLA: Okay. With respect to the contents of Tab 1, the records pertaining
to Christopher Carter, are there also bills which include phone tolls?
A. Yes.
Q. Are those records also kept in the regular course of T-Mobile business?
A. Yes.
Q. Do you regularly rely upon those records in generating revenue?
A. Yes.
Q. Do you rely on their accuracy?
A. Yes.
Q. Mr. Dominguez, with respect to Christopher Carter, is the phone number listed on the
table of contents the same phone number that appears on the record within Tab No. 1 of
Exhibit 452?
A. Yes.
Q. And with respect to Franchesco Cascio, is the phone number listed on the table of
contents the same as the phone number listed on the pages of Tab 2?
A. Yes.
Q. How about with Vincent Amen; same question with respect to Tab 3?
A. Yes.
Q. Okay. And I have the same question for Evelyn Tavasci, Tab 4.
A. Yes.
Q. And Christian Robinson, Tab 5?
A. Yes.
Q. Do the phone tolls for each of the individuals that we've just named extend from a
period of January through March of 2003?
A. Yes.
Q. Okay. With respect to the Christian Robinson subscriber information in Tab 5, is there
also another name in the subscriber report?

A. Yes.
Q. And what is that, please?
A. Site LLC.
Q. Is there another document right behind that that has the name Christian Robinson on
it?
A. Yes.
Q. And what is that document?
A. That is the front page of a bill.
Q. Okay. What does it say on the top left-hand corner?
A. The top line says, Site LLC. Second line says, Attention: Christian Robinson. MR.
NICOLA: With the Court's permission, we'd offer this into evidence so we can project it.
MR. SANGER: Your Honor, before you rule -- THE COURT: Yes. MR. SANGER: -- my
understanding is they're offering the entire book as an exhibit. Is that correct? MR.
NICOLA: That is correct. MR. SANGER: And I object, because the entire book -- there's
material in at least the book that was given to me that has not been covered by the
prosecution, and I would like an opportunity to approach the witness and see what is in
that book. THE COURT: You may. MR. SANGER: Thank you. Your Honor, can I have a
moment to speak with counsel for just a -- THE COURT: Yes. (Off-the-record discussion
held at counsel table.) MR. NICOLA: W e're having a -- trying to explain the different table
of contents, Your Honor. THE COURT: That's fine. MR. SANGER: It's more than that. There
are things that were removed from the book and we're just trying to figure out which book
is right. And there we go. Based on what I've now seen, I will withdraw -- if I objected, I'll
withdraw it. Otherwise, I'll submit it. THE COURT: All right. I'll admit it. MR. NICOLA:
Thank you, Your Honor. May we have Input 4, please?
Q. If you could turn to the subscriber record for Christopher Carter located under Tab No.
1, and is this the account information that it contains for Mr. Carter for the phone number
that appears at the very top of the exhibit, (702) 234-9059?
A. Yes.
Q. And is the work telephone number gathered at the time that the account is opened?
A. Yes.
Q. And for this exhibit, it is -- or for this account, it is (818) 910-5505? THE COURT: I just
cut the screen on this. You're showing a person's Social Secur ity number and address, and
I don't think you should be doing that. MR. NICOLA: A little brain dead right now. I
apologize.
Q. Can you turn to, in your book, the exhibit that begins with -- I believe it's 29 of 32 for
Chris Carter's number. Okay. It's the exhibit in Mr. Carter's bill that begins with roaming
charges, 29 of 32. Do you have it in front of you?
A. Yes.
Q. Is the first entry on that dated 1-31-03, Miami, Florid a?
A. Yes. MR. SANGER: Just one second before we do this. Before we do this, let me just
have a moment. MR. NICOLA: Maybe we should kill that. (Off-the-record discussion held
at counsel table.) MR. SANGER: Now, having resolved that, I guess I have a belated
question. We had raised it earlier with regards to Mr. Jackson's phone numbers. I mean,
we are putting everybody's phone numbers up on the board. MR. NICOLA: May we
approach so we can -- I have a solution for that that will take two seconds to discuss at
sidebar. THE COURT: All right. (An off-the-record discussion was held at sidebar.) MR.
NICOLA: May I proceed with the Elmo, Your Honor? THE COURT: Yes. MR. NICOLA:
Excuse me, the Input 4.

Q. We were talking about the -- this document in the T-Mobile exhibit. If you could just
explain generally the highlighted area and what they mean for the jury, please.
A. The first column shows the date that that call took place. The following column under
Call Destination, that shows the city called. And that's also an outgoing call. Column
after that shows the time that that call took place. The Number Called is either the
number called or received. And then the duration.
Q. Okay. How do we know if a call has been received?
A. If a call has been received, it would show incoming. So if you look at where it says,
January 31st, 2003, at 6:27 p.m., that's an incoming call, and that's how you can tell it's
an incoming call, because it says so.
Q. Sometimes the incoming call will record in there and sometimes it will not?
A. Um -- explain.
Q. Well, if it's an incoming call, will the -A. Where the number doesn't show up, it's because the person is blocking their number or
our system did not catch a date and incoming number.
Q. Let me ask you about the code highlighted parentheses A. What does that mean?
A. If you were to look at the bottom of the page, there's a legend that displays the call
type and what the A would stand for. A stands for call wait ing.
Q. Okay. Let me move that up. MR. SANGER: Your Honor, I'm very sorry. This is -- this is
-- yeah, I understand. This is somewhat piecemeal here. THE COURT: Did you want me to
black out the screen while you -- MR. SANGER: Could you please, Your Honor? This -- this
-- I don't want to argue in front of the jury, but the availability -- this witness is not being
called, as I understand it -- I don't think there's relevance to these phone records. And I
know I submitted it. And now that I'm hearing what is being presented from these
records, I think I should object to this exhibit or move to strike this exhibit based on
irrelevancy, at least this Tab No. 1, unless there's something that's going to connect it up
at some point in this case. THE COURT: I assume you are entering this information for a
purpose. MR. NICOLA: We are, Your Honor. And I don't want to argue this in front of the
jury. THE COURT: Okay. I'm going to allow -- I'm going to deny the motion to strike and
go forward. MR. NICOLA: Thank you.
Q. Okay. The different call types are listed on the bottom of the billing page?
A. Yes.
Q. And A is for call waiting?
A. Yes.
Q. For those of you who don't know how call waiting works, can you explain that real
quickly for us?
A. When someone receives an incoming call, they'll hear a tone telling them then there's a
call on the other end. What they would do then is they would switch over to the other line,
and they could speak to the other person. And when they're finished, they can terminate
that call and continue with the phone call they -- they init ially originated or whoever called
them originally.
Q. So the subscriber is on the phone?
A. Right.
Q. Another call comes in; he hears a beep?
A. Right.
Q. Pushes a button; can talk to the other person on the phone without hanging up on the
first one?
A. That's correct.

Q. Okay. What about call forwarding?

A. Call forwarding. Call forwarding works -- if you wanted to receive a call, but you wanted
to forward it to a different number, someone calls you, that number, then that call then
goes to the number that you forwarded it to.
Q. Okay. Say, someone has their home phone number forwarded to their cell phone.
Would that register as an incoming call on the cell phone?
A. It would -- on the record, it would show the incoming number from the person that's
calling. It wouldn't show the number where it's being forwarded to.
Q. And if you forward your cell phone to a different number, will the number that called,
that was forwarded, show up on the bill?
A. No.
Q. With respect to the G in parentheses, what is that code for?
A. Voice mail.
Q. So if somebody is checking their voice mail, it will show up on the bill as voice mail
retrieval?
A. Yes.
Q. And then get charged for that?
A. Yes, if they go over their allotted minutes.
Q. Are there different sections of this particular bill for Mr. Carter? For example, this one
here has a header called Roaming Charges.
A. Yes. There would be another bill, just the regular billed charges of calls that he made
while he was in his home area.
Q. Okay. And with respect to the charges listed under this heading, Roaming Charges,
can you tell us where the phone that was being used to dial out, say, to this number here,
the 305 number, where that phone was?
A. In the Miami/Dade area, or Southern Florida.
Q. And how can you tell that?
A. On the top left-hand corner above the date, it says, Miami/Dade.
Q. Right there where I'm pointing?
A. Yes.
Q. Now, if it is not under a Roaming Charges section in the bill, where does Call
Destination correspond to?
A. The Call Destination doesn't actually correspond to the physical locat ion of the
outgoing number that they're calling. A few years ago the area code and prefix used to
correspond to a specific geographic area. Now, with cell phones, they can be pretty much
anywhere.
Q. Okay. If you could turn to page 4 of 23 on the March 5th bill. Are we looking at the
same page here?
A. Yes.
Q. Okay. So where it says, 2-9-03, Santa Ynez, California, the time and the phone
number, is that under one of the regular billing headers?
A. Yes.
Q. Okay. So the call was not placed from Santa Ynez, as far as the bill is concerned?
A. Right.
Q. Okay. And, now, is Santa Ynez a region that just shows up on the bill because of a -A. Because of the area code and prefix.
Q. And that destination tied in with the phone number that was dialed?
A. No.

Q. How does that work?

A. The area code and prefix are the first six numbers. The area code, being 805 the prefix
being 688, that belongs to Santa Ynez.
Q. Okay. If you can move on, please, to the documents in Tab 2 for Franchesco Cascio, do
those records show a work telephone number for him of Area Code (818) 905-0386?
A. Yes.
Q. Okay. If you'd turn to page -- or Tab 3, please, for Vincent Amen. If you could turn to
the bill dated February 21st, 2003. (Off-the-record discussion held at counsel table.)
Q. BY MR. NICOLA: I'd like to show you an example of an incoming call with respect to
the phone call which registered 2-11-03, 2:30 p.m, that's highlighted. Do you see that?
A. Yes.
Q. What does the F mean?
A. F means mobile-to-mobile. The number that is being dialed or received is another TMobile customer.
Q. Okay. Does that work outside of your calling network?
A. Yes.
Q. So if someone with AT&T Wireless on a mobile phone dials the owner of this cell phone,
will their number show up here?
A. Yes, but it wouldn't have an F behind it.
Q. So this is within the same calling area?
A. No, it's within the same company. They're both T-Mobile customers.
Q. So there's no charge?
A. There's no charge, because they can either be within their allotted minutes, or if they
have part of their price p lan all T-Mobile to T-Mobile, calls can be free.
Q. Okay. I'd like you to turn to the next tab, please, the records for Ms. Evelyn Tavasci.
I'm going to take this down. On the subscriber record, do you see the home telephone
number of Miss Tavasci?
A. Yes.
Q. And is that the same number that is listed in Christopher Carter's subscriber
informat ion as being a work number?
A. Yes. MR. NICOLA: Thank you, Mr. Dominguez. Your witness, Mr. Sanger.
CROSS-EXAMINATION BY MR. SANGER:
Q. Good afternoon.
A. Good afternoon.
Q. We always have to look at the clock when we say that, because we don't know when
it's noon around here. THE COURT: Some of us. (Laughter.) MR. SANGER: Oh. Some may
be painfully aware, I suppose.
Q. All right. You have testified to some records that are in front of you there, and the fact
that -- let me withdraw that. These particular telephones are mobile telephones. They're
cell phones, right?
A. Yes.
Q. Okay. So these are not phones that are associated with a particular address. I mean,
you have a billing address and that sort of thing, but they're not stuck someplace, right?
A. No.
Q. Secondly, you mentioned that the Tab No. 4, Evelyn Tavasci phone, and the Tab No. 1,
Christopher Carter phone, have a similar -- or have the same number on the - what would

you call it? - subscriber database; is that right?

A. Yeah, the one has the number for being the work, and the other has it for their home
telephone number.
Q. Just to make this a little more clear, the actual telephone number for the records -- in
other words, you have billing records behind each tab, right?
A. Right.
Q. Are the billing records for Tab No. 1 for the same telephone number as Tab No. 4?
A. No.
Q. Okay. And all that you show there is that in the subscriber database where you have
other telephone numbers for people, this telephone number ending in 5005 shows up in
both of those bases; is that correct?
A. One shows up in the work telephone slot, because that was the number that they gave
when they signed up for their account as to what their work telephone number was. The
other one shows that number as being their home telephone number, because that was
the information they gave when they set up the account as that being their home
telephone.
Q. And obviously you're here as custodian of records. You weren't there when these were
signed up. You don't know who did it, right?
A. No.
Q. Is it common for a company or an organization to purchase a number of telephones
from your company?
A. Yes.
Q. And they would have similar subscriber informat ion for more than one telephone on
occasion; is that correct?
A. Yes. For a large corporation, yes.
Q. All right. And finally, the fact that these phone records -- these billing records are billed
to a particular person, it says, Statement For up in the right-hand corner; is that
correct?
A. Yes.
Q. The fact that it says, Statement For, Christopher Carter or Franchesco Cascio or any
of the others, does that the mean that those particular individuals were using the
telephone on that day?
A. No, it does not. MR. SANGER: Okay. Thank you. I have no further questions. MR.
NICOLA: Nor do I, Your Honor. THE COURT: Thank you. You may step down.

ANNE MARIE SIMS EXAMINATION

DIRECT EXAMINATION BY MR. NICOLA:
Q. What company do you work for?
A. SBC.
Q. You're here about telephone numbers.
A. Yes.
Q. Surprise. How long have you been with SBC?
A. It will be 25 years in May.
Q. We placed in front of you Exhibit 451, I believe; is that correct?
A. Yes.

Q. And are you familiar with the contents of Exhibit 451?

A. Yes.
Q. Okay. Now, with respect to your role here as custodian of records for Pacific Bell, how
long have you been working for them in that capacity?
A. Two years.
Q. And have you testified on a number of occasions as a custodian of records?
A. Yes.
Q. Have you had an opportunity to look at the records contained within Exhibit 451 prior
to today's date?
A. Yes.
Q. And is there a table of contents in the front portion?
A. Yes.
Q. Okay. Have you compared the informat ion under the subscriber name and the
subscriber phone number with the records which are contained within that exhibit?
A. Yes.
Q. Did you find that they corresponded?
A. Yes.
Q. And is the table of contents accurate?
A. Yes.
Q. With respect to generally the entire exhibit, are the records in there, save the table of
contents, records which are made in the ordinary course and scope of the business of
Pacific Bell?
A. Yes.
Q. And is the information contained within Exhib it 451 recorded at or near the time of the
events that they purport to relate?
A. Yes.
Q. And is this exhibit -- excuse me, are the contents of this exhibit records that you
normally rely upon in conducting the business of Pacific Bell?
A. Yes. MR. NICOLA: We'd move this into evidence at this time, Your Honor. THE COURT:
It's admitted. MR. SANGER: Excuse me, Your Honor. I was going to ask counsel and he
started too soon. May I just approach and -- THE COURT: I'll withdraw my ruling until
you've had an opportunity to look at them. MR. SANGER: Just take a quick look at them.
Thank you. MR. NICOLA: Ahh. MR. SANGER: May I borrow that for a second? I'll submit it,
but again, relevance has not been demonstrated as yet. THE COURT: All right. They're
admitted, subject to that same proviso. MR. SANGER: Thank you. MR. NICOLA: Thank
you, Your Honor.
Q. In Tab No. 1, I believe there are the records of Ms. Evvy Tavasci.
A. Yes.
Q. Is that correct?
A. Yes.
Q. And the phone lines that you'll be referring to contained within Exhibit 451, are they
cellular phones or are they hard lines that go into houses,
A. They're landlines, wire lines. 7898
Q. Do you have two phone numbers listed for Ms. Tavasci's home? You don't have to tell
us what they are. Are they within the table of contents?
A. Yes.
Q. Okay. And is the one ending in 0088 the second line into that home?
A. Yes.

Q. And the one ending in 5005 the primary line?

A. Yes.
Q. Are there specific billing information records within the exhibit for Evvy Tavasci, Tab
No. 1, for the period between approximately January and March of 2003?
A. Yes.
Q. If you could move to Tab No. 2. Are those the billing and subscriber information
records for Ms. Aja Pryor?
A. Yes.
Q. And if you could move to Tab No. 3. Contained within that tab, do you find the billing
and toll information for a business entitled, Neverland Valley Entertainment?
A. Yes.
Q. And are there five separate phone lines going into that business that you have record
of?
A. Yes.
Q. And are all those phone numbers reflected in the records within Tab No. 3?
A. Yes.
Q. I have the same question about exhibit number -- excuse me, Tab No. 4 in Exhibit No.
451. Is that the subscriber and billing records of one Miko Brando?
A. Yes.
Q. Okay. Moving on to Tab No. 5, please, subscriber and billing records for David Ventura?
A. Yes.
Q. I wou ld like to show you a page from that, if I may. If you could turn to the March 12th
section of the bill. It would be a long-distance call. Okay. Do you have a call to Santa Ynez
on that date?
A. On what date?
Q. Did I say March 12th? March 14th.
A. March 14th, yes. On March 14th?
Q. Yes.
A. Oh, yes.
Q. You do?
A. Yes. MR. NICOLA: If I may have the Input, Your Honor.
Q. Okay. Is that the page you're looking at in the exhibit?
A. Yes.
Q. Perhaps we can just go over this one page. Is the phone number connected to David
Ventura (626) 575-6162, this one up here?
A. Yes.
Q. On this bill, can you explain these groups of numbers up here? The 8-1 of 9, what does
that mean?
A. When we're looking at telephone accounts or bills in the computer, the screen can only
show a third of the page, so -- or, you know, just a portion of the page that prints out on
the actual customer's bill. So this would be like eight -- the eighth page, the first part of
the screen in the computer.
Q. Okay. So -A. And then there would be nine pages altogether.
Q. So this is part of page nine of the bill; is that right?
A. It would be, I believe, page eight. I don't know.
Q. Page eight out of nine pages, I'm sorry.
A. Right.

Q. It's confusing. That's why I'm trying to -A. You're confusing me.
Q. Okay. So this is the eighth page, first computer screen -A. Right.
Q. -- out of nine pages?
A. Right.
Q. Now, the call you were referring to, is that Item No. 10 listed down here?
A. Yes.
Q. So on MR14, is that March 14?
A. Yes.
Q. This is the 2003 bill at 2:15 p.m. A call was placed to that number down there?
A. Yes.
Q. That's (805) 688-9788?
A. Yes.
Q. Would you please turn to the page immediately preced ing that in the exhibit? Is that
page No. 7-4 of 9?
A. Yes.
Q. On the Ventura bill there appear to be calls both on February 13th and February 14th
to a number in Morristown. And does that NJ stand for New Jersey?
A. Yes.
Q. And the number dialed was (201) 213-0763?
A. Yes.
Q. Can you tell over here under the Minutes column whether those are completed calls
or not?
A. Yes.
Q. How can you tell that?
A. Because they were printed on the bill.
Q. Okay. So if I call this number but hang up before someone else picks up the phone, it's
not going to show up on my bill?
A. Correct.
Q. Okay. And do you use the round up, take-whatever-you-can-get-from-the-consumer
system of counting minutes?
A. Yes.
Q. So a two-second call -- excuse me. I couldn't resist.
A two-second telephone call with this company, completed, will cost a minute, correct?
A. Yes.
Q. Okay. So it's a little different than some other systems?
A. Yes.
Q. A three-minute one-second call will register as four minutes, correct?
A. Yes.
Q. The most you can say about any of these numbers over here under Minutes is that
this call, Item No. 9, lasted between three and four minutes; is that accurate?
A. Yes.
Q. Okay. If we could go back to the table of contents, please. And Tab No. 6, are those
the records for one Jay Jackson?
A. Yes.
Q. And is the telephone number for Jay Jackson (213) 739-9279?
A. Yes.

Q. Moving on to Tab 7, MJJ Productions, is the phone number for MJJ Productions listed as
(310) 278-3383?
A. Yes.
Q. Okay. And how about the information for one Chris Tucker in Tab No. 9? Without telling
us the phone number, is his information within Tab No. 9 is that information accurate?
A. Yes.
Q. I'm going to ask you now about, in order, The Country Inn at Calabasas. Oh, yes. I'm
sorry. Is their subscriber information under Tab 10?
A. Yes.
Q. How about the next tab, Number 11, the L.A. City Board of Education, specifically
Burroughs Junior High School? Is the subscriber informat ion and telephone number in
there as well?
A. Yes.
Q. And finally, No. 12 and 13, Kaiser Foundation and Enterprise Rent-A-Car respectively.
A. Yes. MR. NICOLA: Okay. I have no further questions, Your Honor.
CROSS-EXAMINATION BY MR. SANGER:
Q. Good afternoon. Let's start with Tab No. 9, and -- yeah, let me borrow that. And I'm
going to ask you if you correlate a particular telephone number to Chris Tucker.
A. Yes.
Q. Yes? And does that number end in 1861?
A. Yes.
Q. All right. And in fact, it's (818) 757-1861. That's Chris Tucker's number; is that right?
A. Yes.
Q. All right. And I'm going to ask you to turn now to Tab 9. And with the Court's
permission, I'm going to put up on the board -- I'm sorry, wait a second. Tab 6. Tab 6.
With the Court's permission, I'm going to put up on the board a page from that exhibit,
which appears to be February 8th at the top and then it says, 3-3 of 6. Let's see if we
have the same thing there. Are you looking at that page in the book?
A. Yes.
Q. All right. So we're on the right page. Okay. Just a second. Oop, there it goes. All right.
Sorry. This -- first of all, page six would be the phone number for Jay Jackson up in the
upper left-hand corner; is that correct?
A. Yes.
Q. And that shows his phone number right up here, the upper left-hand corner above his
name, correct?
A. Yes.
Q. The entry on line 16 is for February 4, 2003, correct?
A. Yes.
Q. And at 6:11 p.m., it appears that a call -- is this made to or was received from?
A. Made to.
Q. Okay. So the call was made to Reseda, California, to Chris Tucker's phone number,
correct?
A. Yes.
Q. And it lasted -- is that the amount of time right there, four -A. Yes.
Q. Four-minute call? All right. And then it appears that at 6:14 p.m., another call was

made to Chris Tucker on February 4, that same number, that lasted about four minutes,
correct?
A. Yes.
Q. Now, you could not tell from the billing records, from this billing record, whether or not
this particular b illing record -- whether or not Chris Tucker called -- well, let me withdraw
that. On this record, we see the two calls are made to that Chris Tucker number, correct?
A. Yes.
Q. All right. I'm going to ask that -- if you leave it on for a second, Your Honor, I'm going
to flip to another page. I'm going to ask that you go back to Tab 5, and I'm going to go to
the page -- it's actually the first page that was shown to you by the prosecutor and the
two pages after that. So it will be the March 26th, 2003, 8-1 of 9, 8-2 of 9. And then we'll
go to the next page in the exhibit, in the way mine's organized anyway, which is the April
26th, 2003, 5-4 of 5. Is that the next page in your exhibit?
A. I -- I have 2-1 of 5 and then 5-4 of 5.
Q. Okay. Well, I'm going to go to 5-4 of 5. So we've got those three?
A. Yes.
Q. Let's start with the first one. If I may, Your Honor. THE COURT: Yes.
Q. BY MR. SANGER: I'm going to put up thi spage. And this shows us that this is the
telephone of David Ventura, correct?
A. Yes.
Q. All right. And it appears that on March the 12th -- and I'll just note that apparently
there's some pen marks here that aren't on the actual exhibit, if I can be excused for that,
but it's on my copy. Quite frankly, I must have done it, or somebody did. Other than that,
look -- just look at the printed page here. On March 12, somebody at David Ventura's
number is calling a number in Buellton two different times, at 5:08 p.m. and 7:02 p.m.,
right?
A. Yes.
Q. And then there's a number on March the 12th at 11:25 p.m. That's 35 minutes before
midnight right?
A. Yes.
Q. And somebody, at half an hour or so before midnight, is calling Guadalupe, California,
and calling a number there, correct?
A. Yes.
Q. And talking for 35 minutes, correct?
A. Yes.
Q. There are a couple more calls on the 13th to Santa Ynez. And then on the evening of
the 13th at 6:45 p.m., somebody at David Ventura's number is calling that same number
in Guadalupe again. Do you see that?
A. Yes.
Q. And talking for 64 minutes. Right?
A. Yes.
Q. And when it's 8:45, that's the start time of the call, correct?
A. Yes.
Q. So that call went on from 8:45 in the evening to 9:49, if I add it correctly, in the
evening; is that right?
A. Yes. Yes.
Q. Thank you. You have to say yes or no for the court reporter there. Okay. Now, I'm
going to -- and then the District Attorney already asked you about the last one, a call to

Santa Ynez at 2:15 p.m. Let's go to the next page, if we may, with the Court's permission.
And this is the next page of the phone bill, or the next computer s creen of the phone bill;
is that right?
A. Yes.
Q. And again, this is David Ventura's telephone. Somebody in David Ventura's house on
March the 14th, at 8:12 p.m., calls that same number in Guadalupe, talks for -- or is
billed for a minute. So it was connected and it lasted less than 60 seconds, right?
A. Yes.
Q. All right. And then at -- on the 16th, which would be one minute after midn ight on the
early morning of March the 16th, there's a call to the same number from David Ventura's
phone to that Guadalupe phone number, same number, right?
A. Yes.
Q. Lasts 26 minutes, correct?
A. Yes.
Q. Okay. And then March the 16th, that was just one minute after midnight, the first thing
in the morning. The next one is later that night at 10:14 p.m. on March the 16th.
Somebody's calling that same number in Guadalupe, California, right?
A. Yes.
Q. Six minutes.
A. Yes.
Q. Right?
A. Yes.
Q. And then on the 17th, there are three telephone calls here that I'm pointing to, on lines
14, 15 and 16, and they are respectively at 6:28, 8:51 and 8:57 p.m. So somebody's
trying to call someone at that same number in Guadalupe, and apparently conclud ing the
call within a minute?
A. Yes.
Q. All right. And then on March the 18th, somebody from Mr. Ventura's phone calls
Guadalupe at 3:26 p.m., talks to someone at that same number, presumably, for 22
minutes, correct?
A. Yes.
Q. And then at 9 -- almost 9:30, 9:29 p.m. on 7910 the 18th, there's another call to that
same Guadalupe number for 26 minutes; is that correct?
A. Yes.
Q. Okay. Now I'm going to go to the next page I referred to. I'll put it up and I'll describe
it. It's the next page in my book, but wherever it is in the official book it is. It's identified
by the number at the top, April 26th, 2003, correct?
A. Yes.
Q. And 5-4 of 5, correct?
A. Yes.
Q. And this is David Ventura?
A. Yes.
Q. Now, here it shows a series of calls on 3-19 and 3-20 and 3-21. So March 19th through
March 21st, correct?
A. Yes.
Q. And this is still 2003, right?
A. Yes.
Q. And somebody is calling from the Venturas' telephone, calling that very same number

at Guadalupe; is that right?

A. Yes.
Q. And without going too laboriously through this, the calls are in the evening of 3-19 at
7:10 p.m. for 36 minutes?
A. Yes.
Q. And then that would have taken it from 7:10 7911 to 7:46. So about 15 minutes later,
at 8:01 p.m.,there's another call to the same number for another 17 minutes, correct?
A. Yes.
Q. And then at 10:50 p.m. is another call for three minutes -A. Yes.
Q. -- correct? And the next day, at 2:57 p.m., there's a three-minute call?
A. Yes.
Q. And later that evening, at 7:52, there's a three-minute call, correct?
A. Yes.
Q. And then on 3-20, at 7:55 p.m. So it -- if I'm right, it looks like that three-minute call,
there was a hang-up and a call right back; is that right?
A. Yes.
Q. So -- and that call then lasts for 20 minutes; is that right?
A. Yes.
Q. And then the next day, at 9:37 at night, there's a call to that same number in
Guadalupe from the Ventura residence for one minute; is that right?
A. Yes.
Q. Thank you. Oh, and before I leave, all -- I think the District Attorney asked you this,
but just to be sure. All of these phones are landlines, so they're -- they're all connected by
a wire to the wall?
A. Yes.
Q. So the location that's indicated for the telephone is the location where that telephone
actually is?
A. Yes. MR. SANGER: Okay. Thank you. No further questions. THE COURT: Counsel? MR.
NICOLA: No redirect, Your Honor. Oh, I'm sorry. I do have one question.
REDIRECT EXAMINATION BY MR. NICOLA:
Q. With respect to a completed call on the phone bill, is there any way to -- any way to
tell whether the call actually went to voice mail or whether it was live conversation?
A. No. MR. NICOLA: Okay. Thank you. THE COURT: You say yes better than any witness
I've ever had. (Laughter.) THE WITNESS: Thank you. THE COURT: You're excused. THE
WITNESS: Thank you. MR. NICOLA: Thank you, Your Honor.

JOSEPH SHEBROE EXAMINATION

DIRECT EXAMINATION BY MR. NICOLA:
Q. Any chance you're here to talk about phones?
A. I am.
Q. Which company, please?
A. Verizon Wireless.

Q. Are you here as the custodian of records for Verizon Wireless?

A. I am.
Q. How long have you been with Verizon Wireless?
A. A little over seven years.
Q. What is your current position?
A. I currently supervise a specialty customer service group called the Executive Relat ions
Team.
Q. Okay. With respect to this particular case, were you sent here by your agency to testify
about search warrant information that you sent to the court in People vs. Jackson?
A. Yes, sir.
Q. Do you recognize the contents of Exhibit No. 456?
A. Yes, I do.
Q. Go ahead and look through that, please. Have you had an opportunity to see Exhibit
456 prior to your testimony today?
A. I have.
Q. Okay. And is there a table of contents?
A. Yes, there is.
Q. Okay. And is that a two-page table of contents?
A. Yes, sir.
Q. Have you compared the informat ion contained within each of the tabs with the
corresponding information on the table of contents for each entry?
A. I have.
Q. And is the table of contents accurate with respect to what is actually within Exhib it
456?
A. It is.
Q. Does Exhibit 456 contain subscriber information for the following individuals under Tab
No. 2: Deborah Rowe?
A. Yes.
Q. Jesus Salas?
A. Yes.
Q. Franchesco Cascio?
A. Yes.
Q. Paul Hugo?
A. Yes, sir.
Q. Okay. Does Exhibit No. 456, Tab 2, accurately reflect the telephone numbers for each
of those subscribers?
A. It does.
Q. Okay. Moving to Tab No. 3, does Tab No. 3 include the billing -- excuse me, the
account summary for Mr. Cascio for the billing period of February of 2003?
A. Yes, sir, it does.
Q. Okay. Is that a phone number, (201) 213-0763?
A. Yes.
Q. Tab No. 4, does that contain what is -- what we put on the exhibit as an
incoming/outgoing February 2003 heading for the number 213-0763?
A. Yes.
Q. Is that actually a document that's a switch record?
A. Yes.
Q. Could you explain what a switch record is for the jury?

A. Sure. A switch record is basically more -- it's not like a billing statement. It's the record
that -- that the cell towers produce when a call is placed that we use kind of as a back
end.
Q. I don't think they heard the last part of that.
A. Kind of as a back end. It's not something that's produced for the customer. It's the
records that we use internally that then feeds to the billing system, which then generates
a particular b ill.
Q. Do you keep those particular records for a period of time?
A. Yes, although I'm not sure of the exact amount of time we keep those for.
Q. Is it longer than a couple of weeks?
A. Absolutely.
Q. Okay. Tab No. 5 are the contents of Mr. Cascio's March 2003 bill for the same phone
number, 213-0763?
A. Yes.
Q. And the Tab No. 6 , does that contain the switch records for the same period of time?
A. Yes, the same time.
Q. And Tab No. 7, does that include Mr. Cascio's account summary for April of 2003, the
same phone number?
A. Yes, it does.
Q. Moving down to the next entries are Tab 10?
A. Uh-huh.
Q. Is there a Tab 11?
A. Not in the table of contents. There is in here.
Q. Are there two Tab 10s on the table of contents?
A. Yes, there are.
Q. Would you take a look at the second Tab 10 and see if the contents should be marked
as Tab 11, please?
A. Yes.
Q. Okay. Would you change that on the table of contents? Do you have a pen? So we do
go now Tab 10 and Tab 11?
A. That's correct.
Q. Okay. And is that the account information for one Ms. Deborah Rowe?
A. Yes, it is.
Q. For February and March respectively?
A. Yes.
Q. Are the contents of Exhibit 456 records which you keep in the ordinary course of
Verizon Wireless business?
A. They are.
Q. Is the information contained within Exhib it 456 recorded at or near the time of the
events purported to be -A. Yes, they are.
Q. -- purported to be in the exhibits?
A. Yes, they are.
Q. All right. And does Verizon Wireless regularly rely upon the documents within 456 to
conduct their business?
A. We do. MR. NICOLA: We move that this exhibit be moved into evidence, Your Honor.
MR. SANGER: May I approach and take a look? THE COURT: Yes. MR. SANGER: Subject to
a motion to strike if it's not connected, based on the prior ruling to the Court, I'll submit

it. THE COURT: I'll admit it with that proviso. MR. NICOLA: Thank you, Your Honor.
Q. Would you please turn to Frank Cascio's February billing statement, please, under Tab
3?
A. Okay.
Q. And could you please turn to what is marked as page 23 of 35?
A. Okay.
Q. This blacked-out section up above, is that something that your company does prior to
sending the records in?
A. Yes.
Q. Makes it hard for us to do this. Can you read what the fourth column header is? Is that
called Origination?
A. Yes, it is. Yes, it is.
Q. If I go back down to the fourth column -A. Uh-huh.
Q. -- the number 926, is that a telephone call item number?
A. It's actually 936.
Q. Okay.
A. But, yeah. Yes, it is.
Q. Could you just read for us what, going from left to right, what these columns mean?
A. Sure. Item No. 936, the date the call was placed was February 1st at 12:16 a.m. The
O under Rate Period is for off peak, meaning a night or a weekend. Call Orig inat ion is
Miami, Florida. Then the phone number that was called. W ould you like me to read the
number?
Q. No. We can see it.
A. Okay. The phone -- the location of that phone number is Beverly Hills, California. The
duration was ten minutes. It was placed on a weekend. The Home Air Time Charges
Included, that's basically in relation to the calling plan that was chosen. And then the two
charges on the right are both zero.
Q. Okay. So the first geographical location is where the call was placed from?
A. That's correct.
Q. And the second geographical location is where the phone number is registered to?
A. That's correct.
Q. Okay. Could you explain what the -- the codes beginning with W, RMW and CW
mean?
A. Sure. The RMW is a voice mail retrieval. You can also tell that just to the left of
that,where it says Voice Mail. That's another way. And the C -- the W under the
CW is the weekend. The C I'm not exactly 100 percent sure of.
Q. Is there a legend in the phone bill that would assist you?
A. Yeah. There should be. There is. It's call waiting.
Q. Okay. Do you find that on page 34 of 35 on the February 7th, 2003, bill?
A. 34 of 35, yeah.
Q. Okay. Is that what you're looking at?
A. Yes, sir.
Q. Is there a three-way calling feature with Verizon Wireless?
A. Yes.
Q. Is that encoded somewhere on this legend, or does that have a separate -A. It would have a separate, but it's not on the legend that you have up there, though.
Q. What is the code for three-way calling?

A. I'm not sure.

Q. Can you find that for us? I think we're going to probably take a break here in a couple
of minutes.
A. Okay. Thank you.
Q. Go ahead, if you can look through the record. If you'd like, we'll move on to something
else, and during the break you can find that code for us, okay?
A. Okay. THE COURT: We'll take a break. MR. NICOLA: Now? THE COURT: We'll go ahead
and take a break. MR. NICOLA: Thank you, Judge. (Recess taken.) THE COURT: Go ahead,
Counsel. MR. NICOLA: Thank you, Your Honor.
Q. Mr. Shebroe, just prior to the break, I asked you if you knew what the code was for the
three-way calling off the top of your head. Did you find your cheat sheet to help you?
A. Yeah.
Q. What is the code for three-way calling?
A. The code letter O.
Q. Is there a code for call forwarding?
A. For call forwarding? The letter F. MR. NICOLA: I believe that's all I have. THE COURT:
Mr. Sanger?
CROSS-EXAMINATION BY MR. SANGER:
Q. Okay. Mr. Shebroe, how're you doing?
A. Good. How are you?
Q. I'm fine. All of these phones are cell phones; is that correct?
A. That's correct. MR. SANGER: Okay. No further questions.

JEANNE MULCAHY EXAMINATION

DIRECT EXAMINATION BY MR. NICOLA:
Q. Good afternoon, ma'am. And which phone company are you here to testify about?
A. I'm with Cingular Wireless, and we also acquired AT&T Wireless, so both companies.
Q. You purchased that with cash, right?
A. Yes.
Q. Because two seconds equals one minute?
A. Sure. Yes.
Q. I placed in front of you Exhibit No. 53 and Exhibit No. -- excuse me, 453 and 454?
A. Uh-huh.
Q. Have you been through those two exhibits prior to coming to court today?
A. Yes, I have.
Q. Okay. And what is Exhibit 453, please?
A. They're the records that were requested from AT&T Wireless.
Q. Pursuant to search warrant?
A. Yes, sir.
Q. Have you been through the contents of Exhibit 453 to check it for accuracy?
A. Yes, sir.
Q. Within Exhibit 453, Tab No. 3, do we find the billing information, the bill, for one Paul
Hugo?

A. Yes.
Q. And within Exhibit 453, Tab 4, do we find the billing informat ion for MJJ Productions,
Miko Brando?
A. Yes.
Q. And under Tab 5, is the account information there for Rudy Provencio?
A. Yes.
Q. Under Tab 6, is there subscriber informat ion for MJJ Productions/Paul Hugo and Rudy
Provencio?
A. Yes.
Q. And under Tab 7, those -- are those records for tolls of MJJ Productions/Miko Brando?
A. Yes.
Q. And under Tab 9, do we find some billing and financially labeled party informat ion for
the following people or entities: MJJ Productions/Miko Brando?
A. Yes.
Q. MJJ Productions with five telephone numbers associated?
A. Yes.
Q. And three entries for one Evvy Tavasci with telephone numbers ending in 8984, 4676
and 9111?
A. Yes.
Q. Okay. Are the records contained within Exhib it 453 kept in the normal course of
business?
A. Yes, they are.
Q. Are the entries within Exhibit 453 mad e at or near the time of the events they purport
to record?
A. Yes.
Q. And does AT&T Wireless rely on these documents in the performance of their
business?
A. Yes.
Q. With respect to Exhibit 454, are the documents contained within 454 Cingular Wireless
records?
A. Yes.
Q. And are they records for the following two individuals, Ann Kite under Tab No. 1?
A. Yes.
Q. Evvy Tavasci at Tab No. 2?
A. Yes.
Q. Okay. Now, prior to the merger of AT&T and Cingular -- well, excuse me, one bought
the other, right?
A. Yes.
Q. Which agency did you work with?
A. AT&T Wireless.
Q. AT&T Wireless, okay. Are you familiar with the Cingular Wireless records?
A. Yes, I am.
Q. And their billing cycle?
A. Yes.
Q. And is it with respect to that knowledge that you come here and testify as a custodian
of the records that have the Cingular label on them?
A. Yes, sir.
Q. Okay. Are these records also kept within the normal course and scope of the business

of AT&T Wireless/Cingular?
A. Yes.
Q. And with respect to the documents in 454, are they recorded at or near the time of the
events?
A. Yes.
Q. And does Cingular/AT&T rely on these documents in the regular course of their
business?
A. Yes.
MR. NICOLA: Your Honor, at this time we would offer 453 and 454 into evidence. MR.
SANGER: Same request, Your Honor. THE COURT: All right. They're admitted with the
same provision.
Q. BY MR. NICOLA: If you could please turn to Exhibit 454, Tab No. 1, and what appears
to be labeled Field Usage for one Ann Kite. May I have the Elmo, please, Your Honor?
I'm just going to lay this on the projector. MR. SANGER: I think you have to open it. MR.
NICOLA: I keep thinking it's a copy machine.
Q. Okay. Can you just give us an example of how you would read this bill across, from left
to right, please, top line?
A. The first area is the number; and then the electronic serial number; rate plan; an
abbreviation of the amount; called locations; description, whether it's incoming, or the
number that was dialed if it was outbound; the date; the time; duration; and charges; and
the roamer system that was being used to processed calls.
Q. Okay. Do you know what the codes are for three-way calling if they're availab le for
these mobile phones?
A. I believe it's usually 3 -- 3W.
Q. 3W ; three-way?
A. Yes.
Q. Makes more sense than an O, right?
A. Yes.
Q. I'd like you to turn to Exhibit 453, please. I'd like to show you a different format bill.
Why don't you turn to page one of the Paul Hugo account under Tab 3. I'll lay this on the
Elmo. And these records appear to be in a different format, correct?
A. Correct.
Q. Could you explain to us, please, just starting at Item No. 1, what the columns mean
across?
A. Sure. It's the date; the time of the call; the number called; the general area that the
call was placed to; quantity of minutes; the rate that was charged; and just the charge
description.
Q. And the calling plan?
A. Uh-huh, yes.
Q. Is the code for a three-way call on this bill also 3W, or is that different?
A. I believe so.
Q. Okay. Could you please turn to the next page on the Paul Hugo exhibit?
A. Yes.
Q. Are there sections of your bills which ind icate where a p arty may be while they're
placing phone calls using these wireless phones?
A. I don't believe on this bill.
Q. Are you looking at what I'm looking at?
A. Oh, I'm sorry. Under the Roamer Usage, yes, that's the detail of when you're

roaming. Sorry.
Q. Okay, I'm going to guess this means the phone was in Brazil.
A. Correct.
Q. And on Item No. 2, does that entry mean that while in Brazil, this number called, on
March 2nd at 6:05 p.m., the phone number (201) 233-0063?
A. Yes.
Q. Okay. If I could show you just one more format bill. Please turn to Tab 4. And is that
the service information and toll record for MJJ Productions, Service User Miko Brando?
A. Yes.
Q. If you could turn to what is marked as page 48. I believe it's the first page in that
exhibit.
A. Yes.
Q. Okay. And yet another way to track phone calls. Is that in the same format, just
spaced differently?
A. Yes, it's the same format.
Q. And is the first group of numbers the phone number of the user?
A. Yes.
Q. Okay. And then the fourth column in from the left, or, actually, the next phone number
you would see would be the number dialed, correct?
A. Yes.
Q. And then the date and the time entry in the middle of this bill now, right?
A. Correct. MR. NICOLA: Okay. Thank you, Miss Mulcahy. Your Honor, I have no further
questions. THE COURT: Counsel?
8 MR. SANGER: No questions. (Laughter.) THE COURT: Doesn't get any better than that.
(Laughter.)

For prosecutor DEBORAH ROWE JACKSON EXAMINATION

DIRECT EXAMINATION BY MR. ZONEN:

Q. Do you refer to be called Miss Rowe?
A. Debbie, please.
Q. All right. But in court, we're a little more formal.
A. Oh.
Q. In terms of surnames, do you go by Miss Rowe?
A. Yes.
Q. Do you know the defendant, Michael Jackson, seated to my right with the long, dark
hair?
A. Yes, I do.

Q. How do you know Mr. Jackson?

A. We've been friends and we were married.
Q. When were you married to Mr. Jackson?
A. From 1997 to 1999.
Q. All right. We've -A. Sorry.
Q. The acoustics are not quite what they could be in this courtroom, so you have to stay
close to
the microphone and keep your voice up. Is that all right?
A. Okay.
Q. All right. You were married to Mr. Jackson between which periods of time again,
please?
A. I believe 1997 to 1999.
Q. For what period of time did you know Mr. Jackson prior to that?
A. Probably 20 years or more.
Q. Were you friends with Mr. Jackson?
A. Yes.
Q. Are you the mother of his two children?
A. Yes, I am.
Q. The two oldest children?
A. Yes, I am.
Q. And their names are what?
A. Michael Joseph Jackson, Jr., and Paris Michael Katherine Jackson.
Q. And when were you divorced from Mr. Jackson?
A. October -- I believe October 1999.
Q. Did you have -- did you ever live with Mr. Jackson during the course of your marriage?
A. We never shared a home.
Q. Did you live with Mr. Jackson prior to that marriage?
A. We never shared an apartment.
Q. At the time that the marriage was dissolved, was there an understanding or an
agreement as to
child custody?
A. I'm sorry?
Q. Was there an understanding or agreement as to child custody?
A. Yes.
Q. And who had custody of the two children?
A. Michael did.
Q. Did you have visitation of the two children?
A. Yes, I did.
Q. And what was the extent of the visitation as determined by that divorce?
A. Every 45 days for eight hours.
Q. All right. Did you, in fact, see the two children every 45 days for eight hours?
A. I tried.
Q. All right. Were there difficulties in being ab le to do so?
A. Yes.
Q. What kinds of difficult ies?
A. There were times that the children and Michael would be out of the country, and I was
working at the time, and if they were in South Africa, I would not have enough time to fly

to where they were and then return home in time to be at work.

Q. Were you able to make up that eight-hour period when they returned?
A. No. It was pushed off until the next 45 days.
Q. For what period of time did that continue, that custody arrangement?
A. I believe a year and a half.
Q. At some point in time did you voluntarily agree to give up parental rights as to those
two children?
A. Yes.
Q. And when was that, can you tell us?
A. I believe 2001.
Q. And why did you do that?
A. The visitations were not comfortable. We were hooked up at a hotel. I was -- when I
would bring things to do, finger-painting, coloring or whatever, the nanny was always very
concerned with the children getting dirty. I would bring T-shirts or something to put over
their clothes, and the environment was very sterile. It wasn't a quality relationship.
Q. Did you ask to have more time with the kids?
A. Yes. MR. MESEREAU: Objection; leading. THE COURT: Overruled. The answer was,
Yes. THE WITNESS: I'm sorry. THE COURT: Next question. That's all right.
Q. BY MR. ZONEN: And was that request granted?
A. No.
Q. And tell me why you made the decision to give up parental rights as to the two children
at that time.
A. I didn't believe that -- MR. MESEREAU: Objection. Relevance; opinion. THE COURT:
Sustained.
Q. BY MR. ZONEN: At some point in time -- when was the last time that you saw the two
children?
A. Two and a half, three years ago. I'm not sure. I don't remember the dates.
Q. Did you receive a call from anybody in the early part of February of 2003 requesting
your assistance on behalf of Michael Jackson?
A. Yes. MR. MESEREAU: Objection; leading. THE W ITNESS: I'm sorry. THE COURT:
Overruled. You may -- it's answered, Yes. Next question.
Q. BY MR. ZONEN: From whom was that telephone call?
A. Originally -- MR. MESEREAU: Objection; hearsay. MR. ZONEN: I asked who it was. THE
COURT: Overruled. You may answer as to who it was. THE W ITNESS: Originally my
former boss's partner called me and said that I needed to call my old boss; that he
needed to speak with me; that Michael needed my help with something.
Q. BY MR. ZONEN: Who was the old boss you're referring to?
A. Arnold Klein.
Q. What kind of work was that that you were doing for Mr. Klein?
A. He's a dermatologist. I was an assistant for him.
Q. For what period of time were you his assistant?
A. From 1979 to 2000 or 2001.
Q. What kind of work did you do for Mr. -- Dr. Klein?
A. I assisted him with surgeries and patients.
Q. Without getting into the content of that telephone call, did you, in fact, call Dr. Klein?
A. Yes, I did.
Q. And did you have a conversation with him?
A. Very brief.

Q. Did that conversation lead to a conversation with yet another person?

A. Yes. He wanted me to speak with Marc Schaffel. MR. MESEREAU: Objection; hearsay.
THE COURT: Sustained. MR. MESEREAU: Move to strike. THE COURT: Stricken.
Q. BY MR. ZONEN: That conversation led to a conversation with yet another person; is
that correct?
A. Yes, it is.
Q. Who was that person with whom you then had a conversation?
A. Marc Schaffel.
Q. Do you know Marc Schaffel?
A. Not before this conversation.
Q. Was that the first time you had ever spoken with Mr. Schaffel?
A. Yes.
Q. Prior to that conversation, did you know who he was?
A. No
Q. Had you -- had you ever heard his name prior to that day?
A. No.
Q. Did you, in fact, call Marc Schaffel?
A. The call was placed between Dr. Klein and myself.
Q. All right.
A. I don't hand out my phone number.
Q. Ult imately, Marc Schaffel contacted you, or Dr. Klein arranged the conversation? How
was that?
A. Correct. Dr. Klein arranged the conversation. I did not feel comfortable with a threeway, and told Mr. Schaffel that I would call him if he gave me his number.
Q. All right. Did Mr. Schaffel, in fact, have a conversation with you?
A. Yes, he did.
Q. Do you recall when that conversation took place?
A. It was early in February, in the morning.
Q. And what was the nature of that conversation? MR. MESEREAU: Objection, hearsay.
THE COURT: Sustained.
Q. BY MR. ZONEN: Would you tell us if -- prior to that conversation, were you aware of a
documentary that was titled, Living with Michael Jackson?
A. No.
Q. Were you aware of a person by the name of Mart in Bashir?
A. No.
Q. As a consequence of this conversation with Marc Schaffel, did you then have a
conversation with the defendant?
A. Yes.
Q. And how long after your conversation with Mr. Schaffel was your conversation with
Michael Jackson?
A. Probably 30 minutes.
Q. Who called who?
A. They called me back, because they could not get ahold of Michael immediately. MR.
MESEREAU: Objection. Nonresponsive; hearsay; move to strike. THE COURT:
Nonresponsive. W ho called who is the question? MR. ZONEN: Right. THE COURT: I'll strike
the answer.
Q. BY MR. ZONEN: Were you contacted by somebody with regards -A. Marc Schaffel, yes.

Q. Marc Schaffel called you?

A. And Ronald Konitzer.
Q. You then had a conversation with Ronald Konitzer as well?
A. For a brief moment. Michael was with him.
Q. Did Michael Jackson then get on the telephone?
A. Yes, he did. MR. MESEREAU: Objection; leading. THE COURT: Overruled.
Q. BY MR. ZONEN: What did Mr. Jackson say to you in the course of this conversation?
A. He told me there was a video coming out, and it was full of lies, and would I help. And I
said, as always, yes. I asked him if he was okay. I was very upset.
Q. When was the last time you had talked with Michael Jackson?
A. The day of our divorce.
Q. And how long prior to that, to this conversation you're now referring to, was that day of
your divorce?
A. October 12th.
Q. Of what year, please?
A. .99.
Q. All right. So we're now talking about February of 2003; is that correct?
A. Yes.
Q. Now, he asked you for some kind of assistance; is that correct?
A. Yes.
Q. What exactly did he ask you to do, if anything?
A. He asked if I would work with Ronald and Dieter to help him, and I said yes. And I
asked him how he was. I asked him how the children were. And I asked if I could see
them when everything settled down.
Q. What did he tell you?
A. He said yes.
Q. All right. Had you had any communication with Mr. Jackson in the preceding period of
time with regards to the children?
A. No.
Q. Had you sent any letters to him at all requesting that you be able to see them at some
point in time?
A. No.
Q. Did you want to see the children?
A. Very much.
Q. All right. The conversation that you had from where he was calling?
A. No. I was told by Marc that they had to call Europe. MR. MESEREAU: Objection.
Hearsay; nonresponsive; move to strike. THE COURT: It's nonresponsive. Stricken.
Q. BY MR. ZONEN: You had mentioned that Ronald Konitzer had called back; is that
correct? Did I get that right?
A. Marc Schaffel called me b ack. Ronald had called Marc, or Marc had called Ronald. I
don't know who placed that call.
Q. At some point in time you actually spoke with Ronald Konitzer?
A. Yes.
Q. Did you know Mr. Konitzer prior to that day?
A. I think I met him years ago when Michael was on tour. I don't -- he said that I had met
him. I d idn't remember. I d idn't have a face and I didn't recognize the voice.
Q. All right. And did you carry on -- without getting into the content of the conversation,
did you, in fact, have a conversation with Mr. Konitzer before your conversation with

Michael Jackson?
A. He just said, Michael needs your help -- hearsay.
Q. BY MR. ZONEN: The question is yes or no.
A. Yes. THE COURT: Sustained. THE WITNESS: Sorry.
Q. BY MR. ZONEN: The conversation that you had with Michael Jackson was
approximately how long in length?
A. Two and a half minutes, maybe.
Q. Were you at home at that time?
A. Yes, I was.
Q. You said that you had asked him how he was and how the children were?
A. Yes.
Q. What did he tell you specifically about the -- whatever it was, the performance that was
coming on television or the documentary, how did he describe it to you? MR. MESEREAU:
Objection. Leading and assumes facts not in evidence. THE COURT: Sustained as to
assuming facts.
Q. BY MR. ZONEN: What did he tell you about what was going to happen?
A. That there was a bad video coming out. I did not -- he didn't go into any more detail
about that.
Q. Did you ask him what it was about?
A. No.
Q. Did you ask him if it dealt with him personally, Mr. Jackson?
A. I assumed it did.
Q. Okay. Now, he asked you for some assistance; is that correct? MR. MESEREAU:
Objection; asked and answered. THE COURT: Overruled. You may answer. THE WITNESS:
Yes.
Q. BY MR. ZONEN: And did he describe to you in any detail or particularity what it was
he wanted you to do?
A. No, he did not.
Q. Okay. Did he tell you to follow anybody's direction?
A. He asked me -- MR. MESEREAU: Objection; leading. THE W ITNESS: I'm sorry. THE
COURT: Sustained.
Q. BY MR. ZONEN: What did he tell you to do?
A. He asked me to work with Ronald, Dieter and Marc.
Q. All right. You just told us about Ronald. Is Dieter somebody you knew prior to that
day?
A. I don't remember.
Q. Do you know Dieter's last name?
A. Weizner or Weizer.
Q. Okay. And you don't recall at this time whether you had ever met him prior to that
date, the time of that phone call?
A. No.
Q. Now, did you ask any directions as to how you were going to work with him or what
you were going to do?
A. I told them that I needed a release of confidentiality, and that until that was done, I
wouldn't be able to do anything.
Q. You told Mr. Jackson that?
A. No, I'm sorry, I told Marc Schaffel, Dieter and Ronald.
Q. All right. Let's go back to the conversation again with Mr. Jackson --

A. Okay.
Q. -- before you hung up the phone or before your telephone conversation ended. You
said specifically about the children. Tell me what it was that he told you about the children
with regards to visitation. MR. MESEREAU: Objection; asked and answered. THE COURT:
Overruled. You may answer.
Q. BY MR. ZONEN: Go ahead.
A. When -- when -- I said, Are you -- Are you okay? Are the children okay? And he
said, Yeah, we're okay. And I said, Can I see you when everything -- and the children
when everything is over with? And he said, Yes.
Q. Did you want to see Mr. Jackson and the children?
A. Absolutely.
Q. Did he give you any other direction as to when that might be? MR. MESEREAU:
Objection; leading. THE COURT: Overruled. You may answer. THE W ITNESS: No.
Q. BY MR. ZONEN: Did that conversation end at that time, or was there anything else
that you discussed in the course of that conversation?
A. Michael and I?
Q. Yes.
A. No, we didn't discuss anything else. The phone was handed back to Ronald.
Q. All right. Your conversation then continued with Ronald?
A. Correct.
Q. All right. What was asked of you at that point by Ronald? MR. MESEREAU: Objection;
hearsay. MR. ZONEN: As explaining her conduct thereafter, not for the truth of the
matter. THE COURT: All right. I'll allow the hearsay for that limited purpose.
Q. BY MR. ZONEN: What was explained by Ronald thereafter?
A. That they were going to do a special - I don't know if they used the word rebuttal - to
counter whatever this video was.
Q. And what was asked of you?
A. Would I help. MR. MESEREAU: Objection; assumes facts not in evidence. THE COURT:
Sustained. MR. MESEREAU: And leading.
Q. BY MR. ZONEN: Was anything said by Mr. Weizner as to your involvement?
A. What -- I don't understand. What do you mean by that?
Q. Well, in the telephone call that continued -- maybe I'm confused. Was it Konitzer or
was it Weizner?
A. Konitzer.
Q. It was Konitzer, all right. Ronald Konitzer. What exactly was it that Mr. Konitzer then
said to you about what you were supposed to do? MR. MESEREAU: Objection; hearsay.
THE WITNESS: To -- MR. MESEREAU: Assumes facts not in evidence. MR. ZONEN: Again,
to explain -- THE COURT: Sustained.
Q. BY MR. ZONEN: Was there a conversation with Mr. Konitzer at that point about
anything that you were then going to do? MR. MESEREAU: Objection; leading. THE
COURT: Overruled. MR. ZONEN: That was overruled? THE COURT: Yes.
Q. BY MR. ZONEN: Go ahead and answer.
A. What was the question? I'm sorry. THE COURT: I'll have the court reporter read it back
to you. THE WITNESS: Thank you. (Record read.) THE W ITNESS: I was supposed to work
with Marc Schaffel, and that was when I told them that we had to have the paperwork
done -- MR. MESEREAU: Objection; nonresponsive. THE COURT: The second part of the
answer I'll strike. Leave the first part in.
Q. BY MR. ZONEN: All right. With regards to working with Marc Schaffel, was there any

other statement that was given to you by Mr. Konitzer at that time? MR. MESEREAU:
Objection; leading. MR. ZONEN: Hardly suggests the answer. THE COURT: Overruled. You
may answer. THE WITNESS: That I would be working with Marc on whatever project that
had been decided.
Q. BY MR. ZONEN: All right. Did you, in fact, then have a conversation with Marc?
A. Yes.
Q. When did that conversation take place? Marc Schaffel.
A. After the connection was broken between Michael and Ronald and myself.
Q. That same day?
A. It was the same conversation. Marc had us on two lines. So when he hung up the one
line, Marc and I were still on another line.
Q. Was Marc Schaffel part of the conversation that you had with -- in other words, was it a
conference call between Marc and you and Ronald Konitzer?
A. Correct.
Q. So he was privy to the conversation that was taking place at that point?
A. He set it up.
Q. All right. Was he part of the conversation while you were talking with Mr. Konitzer? In
other words, did he periodically say things as well?
A. I don't remember.
Q. What did Mr. Schaffel want you to do? MR. MESEREAU: Objection. Hearsay; assumes
facts not in evidence. MR. ZONEN: Same exception. THE COURT: Foundation, sustained.
Q. BY MR. ZONEN: In the course of this conversation, did Mr. Schaffel make requests of
you? MR. MESEREAU: Objection; leading. THE COURT: Overruled. You may answer. THE
WITNESS: Nothing specific. I couldn't discuss anything at that point.
Q. BY MR. ZONEN: Did you advise him that you needed to do something?
A. Yes.
Q. And what was that?
A. We needed to agree on a confidentiality release between Michael and myself.
Q. Was there such an agreement that you had between you and the defendant?
A. Eventually.
Q. Well, prior to this conversation, was there some kind of a confidentiality contract that
you had with Mr. Jackson?
A. Yes.
Q. And when did you and Mr. Jackson enter into that agreement?
A. At the time of our divorce.
Q. And did that restrain you from having conversations with people about something or
other? What did it restrain you from doing, this confidentiality agreement? MR.
MESEREAU: Objection. Foundation; leading; relevance. THE COURT: Sustained.
Q. BY MR. ZONEN: Did you know what the confidentiality agreement was? Have you ever
read it?
A. Yes.
Q. And you read it at or about the time that you entered into this divorce with Mr.
Jackson?
A. Yes, I did.
Q. All right. Did that confidentiality agreement keep you from doing something?
A. Yes, it did.
Q. What did it keep you from doing? MR. MESEREAU: Objection. Foundation; leading;
relevance. THE COURT: Overruled. You may answer. MR. MESEREAU: 352.

Q. BY MR. ZONEN: Go ahead and answer the question.

A. The confidentiality agreement said that I could not speak with the press, public,
anyone, regarding Michael or the children or our lives together.
Q. Were you able to get an exemption from that agreement?
A. Yes.
Q. Did you have an attorney working on that?
A. Yes.
Q. What is your attorney's name?
A. Iris Joan Fins ilver, F, as in Frank, i-n-s-i-l-v-e-r.
Q. Has Miss Finsilver been your attorney for some time?
A. Yes.
Q. Did she represent you in your divorce with Mr. Jackson?
A. Yes, she did.
Q. Ult imately when that exemption was executed, were you then able to speak with Mr.
Schaffel about what you were expected to do?
A. Yes.
Q. And what was it that you were expected to do? MR. MESEREAU: Objection. Assumes
facts not in evidence; foundation. THE COURT: Sustained.
Q. BY MR. ZONEN: All right. Did you have a conversation with Mr. Schaffel after the
execution of this exemption?
A. Yes.
Q. All right. In the course of that conversation, were you told things by Mr. Schaffel with
regards to doing something on behalf of Michael Jackson? MR. MESEREAU: Objection;
leading. THE COURT: Sustained.
Q. BY MR. ZONEN: What did Mr. Schaffel tell you in this conversation? MR. MESEREAU:
Objection; hearsay. MR. ZONEN: For the same exception. THE COURT: All right.
Overruled.
Q. BY MR. ZONEN: Go ahead.
A. That we would be doing an interview.
Q. Did he tell you where or when?
A. He said that it would probably be at his home in Calabasas and within two or three days
of when everything was settled.
Q. All right. Now, when was it exactly that you had this conversation with Mr. Schaffel
about doing the interview relat ive to this first phone call from Mr. Jackson?
A. Do you mean when we were going to do it? Or when we scheduled it?
Q. When you scheduled it.
A. We didn't schedule it till after the documents had been signed.
Q. Okay. And how long did that take before you were able to create and sign documents?
A. I would like to say that it was probably only two days. It seemed a lot longer. There
was a lot of faxing back and forth.
Q. Was there some urgency in doing it soon? MR. MESEREAU: Objection; leading. THE
COURT: Sustained.
Q. BY MR. ZONEN: Did anybody ask you to do it at a particular time?
A. Mr. Schaffel.
Q. What did he say with regards to that?
A. As soon as he could arrange -- MR. MESEREAU: Hearsay. MR. ZONEN: Same exception.
THE COURT: Overruled. You may answer. THE W ITNESS: As soon as he could arrange to
have whatever he needed, I believe, for the interview.

Q. BY MR. ZONEN: And was there a date finally set for the interview?
A. Yes.
Q. Do you know what that date was?
A. I don't know exactly. Beginning of February, I believe.
Q. Are you aware as to when or if the screening of Living with Michael Jackson ever
actually aired in the United States?
A. I know that it aired. I don't know when it aired. I d idn't watch it.
Q. Do you know when, relative to the airing of that production, your interview took place?
A. I know in relation to when it took place in Europe, but not here.
Q. When did it take place relative to the European airing?
A. The day before I gave my interview.
Q. Did that interview take place at Mr. Schaffel's residence?
A. My interview?
Q. Yes, your interview.
A. Yes, it did.
Q. Can you tell us who was present during that interview?
A. Hamid, who is Michael's photographer; Rudy; Christian; Marc; Stuart Backerman, who I
think was Michael's PR person; and Iris came with me.
Q. Up until the time that you arrived at Mr. Schaffel's home to do this, had Mr. Schaffel
told you that you would get any benefit from doing this interview? MR. MESEREAU:
Objection. Leading and hearsay. MR. ZONEN: I'm sorry? THE COURT: Sustained.
Q. BY MR. ZONEN: Were you going to be paid for this interview?
A. No.
Q. Were any promises made at all?
A. Just that I -- MR. MESEREAU: Objection. Leading and hearsay. THE COURT: Sustained.
MR. MESEREAU: And vague. THE COURT: Hearsay, sustained. Hearsay. MR. ZONEN: On
hearsay. We would offer it again as to tending to explain her actions and her response,
and not for the truth of the matter stated. THE COURT: The objection's sustained.
Q. BY MR. ZONEN: Did anybody offer you anything in response to your doing this? MR.
MESEREAU: Objection; leading. THE COURT: Overruled. You may answer. T HE WITNESS:
Do you mean quid pro quo?
Q. BY MR. ZONEN: Yes.
A. No, I was excited to see Michael and the ch ildren when all this was over.
Q. Why did you do this interview?
A. I promised him that I would always be there for him and the children.
Q. Did anybody mention your children in the course of either doing this interview or
leading up to the interview? MR. MESEREAU: Objection. Asked and answered and lead ing.
THE COURT: Overruled.
Q. BY MR. ZONEN: You can answer that question.
A. Can you explain what you mean?
Q. Did anybody mention anything about your children with regards to -- relative to this
interview -- MR. MESEREAU: Objection.
Q. BY MR. ZONEN: -- leading up to the interview or during the course of the
interview? MR. MESEREAU: Vague; compound; and leading and foundation. THE COURT:
Rephrase. It's an extended question now.
Q. BY MR. ZONEN: All right. Specifically, you had conversations with Mr. Schaffel, did
you not -A. Yes.

Q. -- prior to the interview?

A. Yes.
Q. Did you have a numb er of conversations prior to the interview?
A. No.
Q. How many conversations did you have with him prior to the interview?
A. One to set up the day and time, and one for directions on how to get to his house.
Q. All right. Prior to actually arriving at his house, did he talk to you about your children at
all?
A. He said the kids were fine; that Michael was going to be okay.
Q. All right. Did he make any representations to you about visitation? MR. MESEREAU:
Objection. Leading; foundation; hearsay. THE COURT: Overruled. You may answer. THE
WITNESS: When I expressed excitement for seeing the children and for seeing Michael
again and possibly reconnecting, he seemed to be very happy.
Q. BY MR. ZONEN: All right. During the course of your being at the house conducting this
interview, did you talk with Mr. Schaffel any further about your children?
A. Yes.
Q. All right. What did he say with regards to your children while you were at his house?
MR. MESEREAU: Objection; hearsay. MR. ZONEN: Same exception. I will add also it's a
statement in furtherance. THE COURT: I reject that as a reason, but let me look. All right.
I'll allow the question for the limited purpose of explaining her action after that. Do you
want the question read back? THE WITNESS: I can't see that far, yes, please. THE
COURT: Okay. (Record read.) THE WITNESS: That they were fine; that Michael was going
to be okay; that it was -- he was happy for me that we were all going to get to see each
other again, and how big the kids have gotten, and how beautiful they were, and how
strong-headed Paris is and -- about like me.
Q. BY MR. ZONEN: What was your expectation with regards to your children in terms of
your completing this interview? MR. MESEREAU: Objection. Leading; foundation. THE
COURT: Sustained.
Q. BY MR. ZONEN: Did you have any expectations with regard to your kids at all? MR.
MESEREAU: Objection; leading. THE COURT: Overruled. THE WITNESS: Yes.
Q. BY MR. ZONEN: What was that? What were your expectations?
A. To be reintroduced to them and to be reacquainted with their dad.
Q. You wanted to be reacquainted with Mr. Jackson as well?
A. Yes.
Q. Why?
A. He's my friend.
Q. Let me ask you about the interview. For what period of time were you at Mr. Schaffel's
home?
A. I was at his house about ten and a half hours, but the taping was about nine.
Q. Was your attorney with you?
A. Yes.
Q. The entire time?
A. She stayed downstairs when Ian Drew arrived. And I was concerned about someone
being able to say that -- MR. MESEREAU: Objection. Nonresponsive and hearsay. THE
COURT: Sustained.
Q. BY MR. ZONEN: The question was whether or not she was there the entire time. Was
there a period of time -A. She was in the house.

Q. Okay. She was in the house, but at some times not with you?
A. Correct.
Q. All right. Now, prior to the start of this interview, had you talked with anybody about
the content of this interview, in other words, what was going to be asked of you?
A. No. MR. MESEREAU: Objection. Assumes facts not in evidence, leading and foundation.
THE COURT: Overruled. Do you want the question read back? THE W ITNESS: No. No, I did
not want that.
Q. BY MR. ZONEN: Did you know what it was you were going to be saying?
A. No.
Q. Did you know what it was -- the questions, what questions would be asked of you?
A. No.
Q. Did you know whether or not it had anything to do with this video or this television
show?
A. All I knew, it was whatever was being put out about Michael could be hurtful to him and
the children, and I don't know if I was supposed to run interference. I don't know what the
basis was for my interview.
Q. Did you ask him about the content of the television show?
A. No.
Q. Did you ask anybody about the content of the questions that would be put to you?
A. Absolutely not.
Q. Did you know that it would be questions put to you? In other words, it would be in the
format of an interview?
A. Yes.
Q. Who had told you that?
A. Mr. Schaffel.
Q. Who was present at the time when this interview commenced?
A. Iris. Stuart. Rudy. Christian was in and out. It was either Christian or Rudy that was in
and out. Marc. Myself. And Ian Drew.
Q. Iris is Iris Finsilver, your attorney?
A. Yes.
Q. Stuart is who?
A. Stuart Backerman, I was told, was a spokesperson for Michael.
Q. Had you ever seen Mr. Backerman prior to that day?
A. No.
Q. Had you ever heard his name prior to that day?
A. No.
Q. Were you introduced to him that day?
A. Yes.
Q. Did you actually have a conversation with him?
A. Nothing other than, Nice to meet you, and very casual. Nothing important to say.
Q. You said Rudy. Who is Rudy?
A. He was Marc's go-fer boy. MR. MESEREAU: Objection; foundation. THE COURT:
Overruled.
Q. BY MR. ZONEN: Marc's -- say that again?
A. Go-fer boy.
Q. Go-fer? Somebody who did things for Mr. Schaffel?
A. Yes.
Q. Do you know Rudy's last name?

A. No, I don't. I'm sorry.

Q. Do you recall if you were told his last name at any time?
A. No, I was -- I was introduced to everyone on a first-name basis. I knew Hamid from
before.
Q. All right. Rudy was or was not somebody you knew prior to that day?
A. No.
Q. Christian, if I'm reading my handwrit ing correctly -A. Yes.
Q. -- was the name you mentioned?
A. Yes.
Q. Was Christian somebody you knew prior to that day?
A. No.
Q. Was his name given to you at that time?
A. I don't remember if I was introduced to him or if someone had said, Christian will get
it. I knew it was his name, because -- I don't remember being formally introduced to
him.
Q. All right. You don't recall an acquaintance with him prior to that day?
A. No.
Q. You mentioned Ian Drew.
A. Yes.
Q. Who is Ian Drew?
A. He was someone that was going to interview me.
Q. And was he somebody you knew prior to that day as well?
A. No.
Q. Did you have any preliminary conversation with him prior to the commencement of this
interview?
A. Absolutely not.
Q. Was that by your choice?
A. Yes.
Q. And why is that? Why was that? MR. MESEREAU: Objection. Foundation; 352; leading.
THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Go ahead.
A. Because I didn't want anyone to be able to come back to me and say that my interview
was rehearsed, that someone told me what to say. Mr. Jackson knows no one can tell me
what to say. I tend to speak my own mind, and I didn't want the interview to be construed
as something other than what it was, which was a cold interview.
Q. At some point in time, were you given any kind of a list of questions? MR. MESEREAU:
Objection. THE COURT: Overruled. THE W ITNESS: It was offered to me and I declined it.
Q. BY MR. ZONEN: All right. Who offered you the list?
A. Ian Drew.
Q. Why did you decline it?
A. Again, it was a cold interview, and I wanted to keep it that way.
Q. Was anyone else in the room during the course of the interview?
A. Everyone was. Rudy and Christian were in and out, but the main people who were
there was Hamid, Iris, Stuart, Marc and myself.
Q. All right.
A. And Ian.
Q. Did you know Hamid prior to that?

A. Yeah, I did.
Q. Was that Hamid Moslehi?
A. Yes.
Q. And you recognized him when you got there?
A. Oh, yes.
Q. He had been Mr. Jackson's videographer for some time?
A. Yeah, for a long, long time.
Q. Was the location of this interview in Calabasas, California?
A. Yes.
Q. Do you happen to know the date?
A. It was the day before that documentary was to air. I don't know the date.
Q. Miss Rowe, in the course of the interview that took place, I think you said over about
the next nine hours -A. Yes.
Q. -- were you truthful in the answers that you gave?
A. Can you rephrase that?
Q. Did you tell the truth? Did you answer all those questions truthfully and honestly?
A. No.
Q. All right. Why is that? MR. MESEREAU: Objection. Foundation; opinion; relevance. THE
COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Why is that?
A. Because my personal life is my personal life and no one's business. And it pretty much
doesn't matter. I could call something black. In the media, it will be called white.
Q. Do you remember the questions that you were asked?
A. Not all of them.
Q. Do you remember some of the questions that you were asked?
A. I would have to see the tape again.
Q. Did you have an opportunity to review the tape recently?
A. Yes.
Q. All right. How many hours of tape did you review?
A. To scan over? It was probably two and a half hours of it, but I wasn't really paying
attention. I found myself very boring and dull.
Q. Do you mean as the subject matter of the tape?
A. Yeah.
Q. It went for, I think you said, about two and a half hours?
A. That I -- that I saw, I think it was a three-hour tape, but I didn't watch the entire
video.
Q. Do you have a belief as to whether or not it was an edited version of what had taken
place?
A. It had to be. It was a nine-hour interview. And if there's only three hours, there's six
hours someplace.
Q. Were you asked questions about Mr. Jackson?
A. Yes, I was. MR. MESEREAU: Objection. Leading; hearsay. THE COURT: Overruled.
Q. BY MR. ZONEN: What questions that were asked of you about Mr. Jackson did you not
give honest answers to?
A. Can you be more specific?
Q. I can. Did he ask -- were you asked questions about Mr. Jackson and his parenting of
your two children? MR. MESEREAU: Objection. Leading; move to strike. THE COURT:

Overruled.
Q. BY MR. ZONEN: Did you understand the question? Would you like to hear it again?
A. Yes, I was asked the question. MR. ZONEN: May the court reporter repeat the question,
Your Honor? THE COURT: I think she understood the -- THE WITNESS: I understood the
question, and I said, Yes. MR. ZONEN: Oh, I'm sorry. THE COURT: She answered your
question. MR. ZONEN: I'm sorry.
Q. Were those the questions, or among the questions, that you did not answer honestly?
MR. MESEREAU: Objection; lead ing. THE COURT: Overruled. You may answer. THE
WITNESS: Yes.
Q. BY MR. ZONEN: When was the last time you had actually seen Mr. Jackson related to
your two oldest children?
A. The day that we signed our divorce papers.
Q. Did you have any informat ion at all about his parenting skills with your children?
A. Just -- yes, I did. I -- when I was seeing the children, I spoke with the nannies before
we divorced. I saw him with the children. I've seen him with the kids the whole time I've
known him. THE COURT: Counsel, we'll take our afternoon break. Before we break, I just
want to ask you a question, Mr. Sanger. MR. SANGER: Yes, sir. THE COURT: Would you
stipulate that the phone records could be released so they can be redacted as I ordered?
MR. MESEREAU: Yes, sir. THE COURT: All right. I'll release the phone records that went in
evid ence today to the District Attorney so they can be redacted and returned to the Court
immed iately. MR. SANGER: I take it they'll g ive me the copy of the redacted -- THE
COURT: And you're ordered to give the defense a copy of the redaction. Thank you. We're
in recess until tomorrow morning. And I'll see you at 8:30. MR. NICOLA: Mr. Sanger -- can
we talk with him for a second? MR. SANGER: If the Judge wants us. (The proceedings
adjourned at 2:30 p.m.)

2005 April 28 (Day 41) D Rowe,JJ Finsilve,Danko & others

DEBBIE ROWE JACKSON DIRECT EXAMINATION (ZONEN)
DIRECT EXAMINATION BY MR. ZONEN:
Q. Miss Rowe, good morning.
A. Good morning.
Q. We left off, we were discussing the interview that you had back in February of 2003 at
Marc Schaffel's home in Calabasas. And you recallthat interview, do you not?
A. Yes.
Q. And I believe that you had testified yesterday that you were at his residence for some
time over nine or ten hours; is that correct?
A. Yes.
Q. Approximately how long were you at his residence?
A. We started early in the morning and finished around 9:00, 10:00 at night.
Q. Was your attorney there the entire time?
A. Yes.
Q. Was she in your presence the entire time?
A. No, she was not.
Q. Were there times when you were separated from her?
A. Yes.
Q. All right. What was the purpose of that?
A. To -- I didn't want to see the interviewer before the interview. And the best way to do
that was to leave where everything was that was happening in the living room off to the
side of the main entrance of the house, so Mr. Schaffel and I went upstairs in his office.
Q. And did you have a conversation with Mr.Schaffel at that time?
A. Yes.
Q. Did you discuss the interview?
A. No.
Q. At some point in time, did you take a look at a script?
A. No. MR. MESEREAU: Objection; leading.
THE COURT: Overruled. The answer was, No.
Q. BY MR. ZONEN: All right. At some point in time, did you see one in somebody else's
possession? MR. MESEREAU: Objection; leading. THE COURT: Overruled. THE W ITNESS:
Mr. Drew had questions; I assume they were questions. He had a number of pages and
asked if I wanted to see them. And I said no.
Q. BY MR. ZONEN: Do you know how many questions were on that script?
A. He told me 105.
Q. Do you know if he went over all of those questions during the course of that interview?
A. My understanding is we did.
Q. And the number of hours that you spent in actual interview was approximately what?
A. Nine.
Q. Was Mr. Schaffel there the entire time?
A. Yes.
Q. Was Mr. Schaffel saying anyth ing during that time?
A. He was hearing sounds in the background, thought it was being picked up on audio,
wanted to change what the back -- MR. MESEREAU: Objection; hearsay. THE COURT:
Overruled.

Q. BY MR. ZONEN: Go ahead.

A. Wanted to make sure what the background looked like and everything. He occasionally
-- not occasionally, frequently would interject to rephrase a question or an answer. And
I told him if that did not -- MR. MESEREAU: Objection. Nonresponsive; narrative. THE
COURT: Sustained at this point.
Q. BY MR. ZONEN: Tell us specifically what he said to you with regards to either
questions or answers. MR. MESEREAU: Objection. Calls for a narrative; hearsay;
foundation. THE COURT: Sustained as to narrative. MR. ZONEN: All right.
Q. Tell us if he -- let me change that. With regards to answers to your questions, did he
make any co mments as to answers to your questions?
A. Yes.
Q. What kinds of comments did he make?
A. He -- MR. MESEREAU: Objection. Vague; foundation; calls for a narrative. THE COURT:
Overruled.
Q. BY MR. ZONEN: Go ahead and answer the question, if you recall.
A. He would ask me if I would rephrase an answer or he would ask Mr. Drew to rephrase a
question.
Q. And what types of questions or answers would he ask you to rephrase? MR.
MESEREAU: Objection; vague. THE COURT: Sustained.
Q. BY MR. ZONEN: Do you remember any specific questions that he asked you to
rephrase? MR. MESEREAU: Objection. Misstates the evidenc e and vague. THE COURT:
Overruled. You may answer.
Q. BY MR. ZONEN: You can answer.
A. I don't remember a specific -- there were so many, I don't remember any specific. I
remember at the end he wanted us to add stuff to clarify what he thought might be
misunderstood or something.
Q. And did you, in fact, make changes in your interview in accordance with his request?
A. Only if it didn't change the meaning of what I had to say.
Q. And what was the meaning of what you had to say? MR. MESEREAU: Objection; vague.
THE COURT: Sustained.
Q. BY MR. ZONEN: All right. What is it that you were intending to represent in this
interview?
A. Michael as a wonderful person and as a great father and generous and caring.
Q. All right. Did you have information as to Michael Jackson as a wonderful father?
A. As I've known him?
Q. Yes.
A. Yes.
Q. When was the last time you'd actually talked with him?
A. In 1999.
Q. All right. This was in early 2003; is that correct?
A. Correct.
Q. When was the last time you saw him interact with the children?
A. I'm sorry, 1999.
Q. In the course of this interview, did you represent yourself as still being part of the
family?
A. Yes, I did.
Q. Was that true?
A. No, it was not.

Q. Why did you do it?

A. To protect the children and to try to keep the media and questions away and out of
their focus. And to make sure that I could do whatever I couldeven at a distance.
Q. Did you feel that you were enthusiastic during this interview?
A. I -- MR. MESEREAU: Objection; leading. THE COURT: Sustained.
Q. BY MR. ZONEN: How did you approach this interview in terms of your affect?
A. I was excited to do it.
Q. Why?
A. Because I would get to see my children and possibly renew a relationship with Mr.
Jackson.
Q. Why did you want to do that?
A. They're my family.
Q. Did you consider them your family?
A. Yes.
Q. Did you consider Mr. Jackson to be your family to the same extent as your children?
A. I don't think anyone is as much as your children, but, yes.
Q. How long had it been since you had seen your children?
A. About two and a half years.
Q. At the conclusion of the interview, did you have a conversation with anybody about
when you would be able to see your children?
A. Mr. Schaffel said that he was excited, and that we'd be going up to Neverland soon.
And I said, Fine. I said, Let me know as soon as youcan.
Q. Was that something that you wanted to do?
A. Very much. Very much.
Q. When was the last time you had been to Neverland?
A. Years. I couldn't tell you. Probably .99, .98.
Q. Did you make any contact with anybody about seeing your children within the next,
say, 30 days or beyond? MR. MESEREAU: Objection; leading. THE COURT: Overruled. You
may answer. THE WITNESS: Mr. Schaffel. I would call -Q. BY MR. ZONEN: How often -- I'm sorry?
A. I would call him almost weekly. I didn't want to be a noodge, or piss him off, so I
wouldcall him and chat him up, and say, By the way, you know, Are they back? You
know, When can I see them? Because it was my understanding they were out of town.
Q. For what period of time did you continue to contact Mr. Schaffel about that? MR.
MESEREAU: Your Honor, we object. Make a motion to exclude. MR. ZONEN: I'd like to
respond to it, even if at sidebar. THE COURT: The objection is overruled. You may
answer.
Q. BY MR. ZONEN: Go ahead.
A. About nine months.
Q. Did you ever see your children?
A. No, I did not.
Q. To this day, have you seen your children?
A. No, I have not.
Q. Have you gone back to court?
A. Yes.
Q. Have you reinstated parental rights -A. Yes.
Q. -- for yourself? MR. MESEREAU: Objection. Leading; foundation. THE COURT:

Sustained. MR. MESEREAU: Relevance.

Q. BY MR. ZONEN: What did you accomplish in court? MR. MESEREAU: Objection.
Leading; foundation; relevance; vague; and calls for improper opinion. THE COURT: The
objection to What did you accomplish... is sustained as vague. That question is vague.
Q. BY MR. ZONEN: All right. Were you able to get a ruling in regards to your custody of
your children? MR. MESEREAU: Objection; relevance; motion to exclude. THE COURT:
Overruled.
Q. BY MR. ZONEN: Go ahead.
A. Not regards to custody, but my parental rights were reinstated.
Q. At this time you have parental rights again, is that right?
A. Yes, I do.
Q. Have you seen your children?
A. No, I have not.
Q. Are you still in court making an effort to do so?
A. Very much so. Actively.
Q. Have you ever seen yourself on television or any part of that interview that was
conducted at Mr. Schaffel's house?
A. Yes.
Q. Where did you see it?
A. I reviewed it last night. I hadn't seen it. I didn't watch it when it was on television, so I
saw a video last evening.
Q. All right. That was the same video that you had reviewed once previously?
A. Yes.
Q. But on the occasion last night, you viewed it with greater detail?
A. Yes.
Q. Did you ever see the Maury Povich film that was featured at a later time?
A. I don't remember watching it.
Q. Did you ever receive any money for your participation -A. No.
Q. -- in this interview?
A. No.
Q. What was your motivation to participate in this interview?
A. To see my children. MR. ZONEN: Thank you. I have no further questions. THE COURT:
Cross-examine? MR. MESEREAU: Your Honor, we'd like to renew our motion to exclude
testimony into these areas. THE COURT: I'll give you an indicated, subject to full
argument, but at this point I would probably not grant that motion. THE WITNESS: Good
morning, Mr. Mesereau.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. Good morning, Ms. Rowe. We've never spoken before, correct?
A. No, we have not.
Q. Okay.
A. I'm Debbie. (Laughter.)
Q. The prosecutor asked you some questions about your, for lack of a better word, current
dispute with Michael Jackson in Family Law Court, correct?
A. I wouldn't call it a dispute, but if that's the legal term, okay.
Q. Well, the prosecutor asked you about whether you obtained rights or not - okay? - and
I believe you said you have obtained parental rights but not custody rights; is that true?

A. I corrected him, and said that my parental rights had been reinstated -Q. Okay.
A. -- when he mentioned custody.
Q. Okay. Okay. Now, when d id you first meet Mr. Schaffel?
A. When Mr. Jackson asked me to do the interview.
Q. Okay. And did you first meet him at the interview?
A. Yes. Personally -- I had spoken to him on the phone. But personally, yes.
Q. And I gather you developed some type of friendship with him; is that true?
A. I wouldn't call it a friendship. More of an acquaintance. More than an acquaintanceship,
but not a friendship.
Q. And you were calling him approximately every week; is that true?
A. For about three months, yes.
Q. Okay. And at some point you were in contact with the Santa Barbara sheriffs about this
case correct?
A. They had called me, yes. And I did not return the first call.
Q. And eventually, you developed somewhat of a dialogue with Santa Barbara sheriffs
about this case, right?
A. When they caught me on my cell phone on my way home from Palm Springs, yes, the
number they got from Marc Schaffel.
Q. And you agreed to make what you called some pretext phone calls for the sheriffs,
correct?
A. Correct.
Q. And a pretext phone call means basically you agreed to work with the sheriffs,
telephone people and talk to them while the sheriffs were recordingthose calls; is that
correct?
A. Correct.
Q. And the idea was that the people you would call would not know they were being
recorded, right?
A. Correct.
Q. Only you and the sheriffs would know there were recordings, right?
A. Correct.
Q. Now, how many of these pretext phone calls do you think you made with or for the
sheriffs?
A. I think there were a total of four to six. I'm not sure.
Q. And who were those pretext phone calls with?
A. Marc Schaffel. Ian Drew. And I think I may have tried to do one with Dieter.
Q. Were you able to do that one?
A. I don't remember.
Q. Okay. So the only people you recall actually speaking with when they didn't know the
call was being recorded are Schaffel and Drew; is that right?
A. And Dieter, if I d id one with him, he wouldn't have known.
Q. Now, Schaffel and Drew were there when you were interviewed?
A. Yes, they were.
Q. And when you arrived for the interview had you ever spoken to Mr. Drew before?
A. No, I had not.
Q. Did you meet him for the first time at the interview?
A. Yes, I did.
Q. So you met Ian Drew for the first time at Marc Schaffel's home, right?

A. Correct.
Q. And after you met him, did you develop an understanding as to whether or not Mr.
Drew would have a role in your interview?
A. I was told he was the one that would be doing the interviewing.
Q. And did he, in fact, do that?
A. Yes, he did.
Q. Okay. And is he the one that had the list of questions you've described?
A. Yes, he did.
Q. And I believe you said you thought there were about 105 questions, right?
A. He told me there were 105.
Q. Mr. Drew told you that?
A. Yes, he did.
Q. Did he ever show you the list of questions?
A. He offered to.
Q. And you refused, right?
A. Correct.
Q. You refused because you wanted to give a spontaneous type of response to whatever
he asked you, right?
A. Correct.
Q. Okay. And I think it's fair to say that your responses were very favorable about Michael
Jackson, right?
A. Yes.
Q. You answered questions for approximately nine hours; is that true?
A. Yes. It was a very long day.
Q. And you were asked all sorts of questions about what kind of person Mr. Jackson was,
right?
A. Yes.
Q. You were asked about what kind of a father he was -A. Yes.
Q. -- right? You were asked whether or not he was a good family person?
A. Yes.
Q. You were asked about whether he was a good friend of yours, right?
A. Yes.
Q. And you, throughout that nine-hour period, were very positive about Michael Jackson,
right?
A. Yes.
Q. And when you got there for the interview, your understanding was you were going
there to help do a very positive, favorable piece about Michael, right?
A. Correct.
Q. And your understanding was that one of the purposes of this interview was to
counteract the negative stuff that appeared in the Bashir documentary, right?
A. I didn't know what the video was. I had never heard of Bashir. It was regarding
somethingthat had played in Europe and was going to be played in the United States. I
didn't want to see the video. I didn't want to see the transcripts from the video. I didn't
want to know anything about it.
Q. Okay. Okay. But you knew there was -- the purpose was to respond to something in
the mediathat had been negative about Michael, right?
A. Negative, twisted, misunderstood, whatever it was.

Q. Okay. And I believe you testified you were more than eager to help Michael in this
area, right?
A. Absolutely.
Q. And as far as you're concerned, you did help him, right?
A. I hope I did.
Q. You spoke favorably about him and some of your comments were placed on a T.V.
documentary,right?
A. The show that -- whatever it was that aired for it, yeah. I think they said the Povich
thing.
Q. And you kept calling Mr. Schaffel for a number of months?
A. Yes.
Q. And you would see him from t ime to time, right?
A. No, I never saw him. I saw him one time -Q. You had lunch with him one time?
A. He set me up. Yes, I had lunch with him one time.
Q. Where was that?
A. The Ivy.
Q. Okay. And you say Schaffel set you up?
A. Yeah.
Q. And what do you mean by that?
A. Apparently there was a meeting going on with Michael and some of his people, and I
later found out that Schaffel and Dieter were not included. And so Marc had called me up
and said, Do you want to go to lunch? And I said, Sure. I said, Do you want me to
meet you in the valley halfway? Do you want to come over here? I'll p ick you up. You
know, What do you want to do? And he said, Well, why don't I pick you up. And I said,
Fine. Where are we going to go? And he said, The Ivy. Is that okay? I said, Sure. I
never had any problems at The Ivy before. So we went to The Ivy.
Q. And would Schaffel call you from time the time?
A. Yes.
Q. Okay. And you have previously commented that you thought Mr. Schaffel was using
Mr. Jackson, true?
A. Oh, yeah.
Q. You thought he was using him, manipulat ing him? MR. ZONEN: I'm going to object as
lack of foundation. She said she just met him. Also improper opinion. THE COURT:
Overruled.
Q. BY MR. MESEREAU: You told the sheriffs that, in your opinion, Marc Schaffel was
continually trying to take advantage of Michael Jackson, true?
A. Correct.
Q. And you thought he was manipulat ing Michael Jackson to make lots of money, right?
A. Yes.
Q. Now, you met Dieter at some point, true?
A. Yes.
Q. And when did you meet Dieter?
A. I don't remember if I met him anytime before The Ivy incident, but I met -- he was
with us at lunch.
Q. Okay. And did you meet Konitzer at some point?
A. Years ago on tour, when he was doing Those Cool Sunglasses.
Q. During the period of the interview -- I say during the period. That's a little bit vague.

Let me withdraw that. Around the time of the interview, did you talk to Konitzer at all?
A. I spoke with him when I spoke with Mr. Jackson to arrange it. And he and Dieter and
Marc had been on the phone. They had been on the phone to tell me about problems that
were going on, yes.
Q. And you've also made statements to the sheriffs that you thought Dieter and Konitzer
were manipulating Michael Jackson, correct?
A. Yes.
Q. You thought Dieter and Konitzer were taking advantage of Michael Jackson, true?
A. Yes.
Q. And you thought they were trying to manipu late Michael Jackson to make a lot of
money, right?
A. Yes.
Q. Was it your perception, based upon what you observed of Schaffel, Dieter and Konitzer,
that those three were working together
A. Oh, yeah.
Q. You definitely got that impression?
A. Oh, yeah.
Q. Okay. And was it your impression that those three were working together to find ways
to use Michael Jackson's name so they could profit?
A. Yes.
Q. And at one point you told the sheriffs that you thought Michael Jackson was, in some
ways, very removed from what those guys were doing, right?
A. In my past knowledge, he's removed from the handlers, the people who are taking care
of business, and they make all the decisions. There's a number of times they don't consult
him.
Q. And you thought these three guys, Schaffel, Dieter and Konitzer, were doing just that,
didn't you?
A. Very strongly.
Q. Do you recall if around this time you even tried to warn Michael Jackson about Schaffel,
Konitzer and Dieter?
A. I did. I tried to go through my -- my ..I'm sorry, my old boss. And actually, when I
didcall, I was told that, Be careful of Marc.
Q. And your old boss was Dr. Klein?
A. Arnold Klein, yes. K-l-e-i-n.
Q. What you're saying, you tried to communicate with Michael, through Dr. Klein, to warn
him about what these three characters were doing to Michael?
A. Or to look and see if he was aware of what was going on, if he even knew that I was
still trying to see the children.
Q. Okay. And one of the problems you had was that because of the custody issues, you
were supposed to talk through attorneys, right?
A. Correct.
Q. And that created a problem in your ability to communicate with Michael, right?
A. It was difficult, yes.
Q. Okay.
A. It was easy with Mr. Spiegel, Lance Spiegel.
Q. And Mr. Spiegel was a prior lawyer for Mr. Jackson?
A. For family, yes.
Q. Okay. Okay. Now, approximately when did you -- when were you divorced from Mr.

Jackson? Was it 1999?

A. Yes.
Q. And at that point you gave up custody of the children?
A. No, not at that point. A year and a half later.
Q. Okay. A year and a half later you gave up custody of the children, and you had the
visitation rights that you identified yesterday, right?
A. Right. No, I'm sorry, I misunderstood. I gave up custody at the divorce. I gave him full
custody. I had vis itation - I'm sorry, I misunderstood - every 45 days.
Q. Approximately how long was your marriage to Mr. Jackson?
A. Three and a half years.
Q. Okay. And I believe you said yesterday you've stayed his friend, right?
A. I've always considered him my friend.
Q. And you still do, right?
A. Yeah. If he'd talk to me. Sorry.
Q. And without question, the communicating through lawyers has created problems with - #A. Have you met Mr. Hall? Extreme problems.
Q. Okay. Okay. You're blaming the lawyers for a lot of that, right?
A. Have you met Mr. Hall? You don't want to.
Q. Okay. All right. How many times did you meet Dieter personally?
A. Like -- I know for sure the one time.
Q. Did you talk to Dieter on the telephone?
A. Yes.
Q. How many times do you think you talked to Dieter on the telephone?
A. I think once or twice.
Q. Okay.
A. I don't remember. They weren't eventful calls.
Q. Did he call you or did you call him?
A. He's -- I know he called me once, and I believe I called him.
Q. Now, did you learn at some point -- excuse me. Before I get into that, how many calls
do you think you had with Drew, if any?
A. From when to when?
Q. Oh, around the time of the interview.
A. I met Mr. Drew, he went back to Florida, I d idn't see him for about a year. When he
came back to Los Angeles, he called me and said he was back in town.
Q. Did you develop a friendship with him?
A. Yeah.
Q. Okay. Now, did you learn at some point that Schaffel was trying to make millions of
dollars from the footage of your interview?
A. Yes, I -- MR. ZONEN: I'm going to object as lack of foundation. THE COURT: Overruled.
THE WITNESS: Yes.
Q. BY MR. MESEREAU: How did you learn that Schaffel was trying to make millions of
dollars from the footage of your interview?
A. He told me he was paid for it. He told me that part of the money that was made from it
went for a debt that Mr. Jackson had owed him. I later found out that he took -- he told
Ronald and Dieter that I wanted $100,000 for doing the interview. And I believe a check
was cut - not to me. I wouldn't have taken it - and he kept it.
Q. And how did you learn this information?
A. Some of it was from Ian. Some of it was from Marc himself.

Q. And at one point Schaffel told you he was going to sue Michael Jackson, didn't he?
A. Yes, he did.
Q. He told you he wanted over a million dollars from Michael Jackson, true?
A. He said Michael owed him a million dollars.
Q. And approximately when d id Marc Schaffel tell you he was going to sue Michael
Jackson?
A. Six months ago maybe. It may have been longer than that, but I'm not really good with
-- if you could give me something to refer to at a time, I could say yes, it happened then.
But I think it was about six months ago. And then he told me, about three months ago,
that he and his lawyer were filing papers.
Q. And did you ever learn at some point that he had actually sued Michael Jackson?
A. He told me that they'd filed the papers.
Q. Okay. Did Schaffel ever ask you for assistance in his suit against Michael Jackson?
A. No.
Q. Did he ever ask you for information to help him in his business dealings with Michael
Jackson?
A. I wouldn't have given it to him.
Q. Okay. Did he ever ask you for help, though?
A. I'm sorry?
Q. Did Schaffel, in your mind, ever ask you to help him in his business dealings with Mr.
Jackson?
A. No. He just bragged about either how he took advantage of an opportunity that I'm
sure he knew nothing about or how he was going to do this, that or the other thing to
make sure that Michael's career was saved, and things of that nature.
Q. Did Schaffel tell you that he was involved
8 in business matters with Dieter?
A. Yes.
Q. Did Schaffel tell you he was involved in business matters with Konitzer?
A. Yes. In Europe.
Q. Okay. And did you ever get the impression he was not giving Michael Jackson all the
informat ion about what he was up to?
A. He was like everybody else around Mr. Jackson. Yeah, he wasn't telling him everything.
Q. Why did you think Schaffel was calling you?
A. To placate me. To say that, Oh, no, I'm working on it. You'll be seeing the kids.
Michael's very excited about it. Everything's going to be great. They're still in Florida. You
know, As soon as they get home you guys will be together.
Q. And you didn't think he was being truthful, right?
A. Obviously he's full of shit. Sorry. I'm sorry, Your Honor.
Q. You consider Marc Schaffel a liar, don't you?
A. Yes.
Q. You consider Dieter a liar, don't you?
A. Yes.
Q. You consider Konitzer to be a liar, don't you?
A. Yes.
Q. Did Mr. Drew appear to you to want to interact with Schaffel? MR. ZONEN: I'll object as
speculative. THE COURT: Sustained.
Q. BY MR. MESEREAU: You met Mr. Drew at Schaffel's residence, right?
A. Yes.

Q. And you were introduced to him through Schaffel, right?

A. Yes.
Q. Was it your belief at that time that the two of them had some type of business
relationship?
A. Marc told me that Ian was a plant at one of the tabloids to run interference for bad
publicity for Michael.
Q. And did you believe that?
A. I didn't know, didn't care, didn't want to be there, but was there for the kids and for
him. I -- you know, I wanted to get in and get out. I'm having about as much fun here as
I had there.
Q. Was it your understanding that Schaffel was using Ian Drew for a particular purpose?
A. Yes.
Q. And that purpose was to sew publicity that he wanted in the tabloids?
A. To get information out. I don't know if I knew that it was -- if I knew that it was The
Globe then that he was the plant for, or if Marc told me shortly thereafter. I think Marc
told me at the day, the day that it was, so I knew that I was supposed to expect
something coming out in the tabloids.
Q. Right.
A. Shockingly was misinterpreted.
Q. And was it your impression that Schaffel was using Drew to promote Schaffel's
business interests?
A. If I'm considered a commodity to Mr. Jackson, then yes.
Q. And as far as you were concerned, Schaffel was using you as a commodity, right?
A. Schaffel was talking out both sides of his mouth, telling me one thing, telling Mr.
Jackson something else.
Q. You thought he was using the two of you, didn't you?
A. Yes.
Q. Schaffel bragged to you about the large sums of money he was going to make off of
Michael Jackson, didn't he?
A. Yes, he did.
Q. He bragged about making millions of dollars off of Michael Jackson, didn't he?
A. Yes, he did.
Q. He did that many t imes, didn't he?
A. Constantly.
Q. Did Dieter brag as well about the millions he was going to make off of Michael
Jackson?
A. He wasn't as -- he was more subtle about it and spoke of it as plans for Michael, not
actually to take from Michael. So it's a matter of semantics, I'm saying, you know, I'm
going to do it for Michael.
Q. Did Konitzer brag about all the money he was going to make off of Michael Jackson?
A. He had big plans. So -- but they -- I didn't speak with him as often as I spoke with
Marc. So those conversations weren't about that with Ronald. It was getting this project
started and how they were going to -- how everything was going to be much better. And
then I think I had another conversation with Ronald and Dieter afterwards when they
called to say that everything was fine with the video, and Thank you, and Things will be
fine. We have b ig plans, and stuff like that. I think there's only two times I spoke with
Konitzer.
Q. Did Dieter ever tell you that he any Konitzer were going to take over all of Michael

Jackson's affairs?
A. That was their plan, because he'd been mishandled.
Q. Did Dieter ever tell you, Don't call Michael Jackson. If you have any question about
him, talk to me?
A. I wouldn't be allowed to call him. But if I had any concerns I would -- he said, you
know, Please call me.
Q. Did Schaffel ever show you any written agreements that he said concerned projects he
was going to do with the Jackson name?
A. The song. Didn't show me the contract, but that was one thing that he spoke to me
about is that they were doing a song for Clear Channel or something.
Q. How many times have you been to Schaffel's home?
A. Once for the interview, and once to pick him up, and I have to remember where we
were going. W e had to drop a friend of his off in Hollywood someplace. Oh, we went to
see Parviz, this guy Parviz. That's what we did.
Q. Okay. And did Schaffel talk to you about an attorney named Mr. Geragos?
A. Uh-huh.
Q. Did he tell you that he had picked Mr. Geragos?
A. I don't know who picked him, but whoever did made a huge mistake. Come on. He
pleads out or loses.
Q. Well, in your discussions with the sheriffs, you made negative comments about Mr.
Geragos, didn't you?
A. Oh, yeah.
Q. And didn't you also comment that you thought Mr. Geragos was doing -- MR. ZONEN:
I'm going to object as hearsay and speculative and irrelevant and beyond the scope of the
direct. THE COURT: Sustained.
Q. BY MR. MESEREAU: Do you know why you were asked by the sheriffs to record phone
conversations with Ian Drew? MR. ZONEN: Objection; speculative. THE COURT:
Sustained.
Q. BY MR. MESEREAU: Did any representative of the sheriff's department ever tell you
why they wanted you to record phone conversations with Ian Drew?
A. It was very frustrating working with the sheriff's department. They don't give you any
informat ion. That's why I wanted to find out for myself what was going on.
Q. And did you ever record conversations yourself and then just give those recordings to
the sheriff?
A. No, that's illegal.
Q. You just did it always with a sheriff involved with you?
A. Yes.
Q. Okay. When did you last talk to Mr. Schaffel?
A. Conversation-conversation? Probably two weeks ago. Probably right before he got the
transcripts from the conversation. But he had sent me e-mails that I had not opened.
They're still on my account before I came up here.
Q. So a couple of weeks ago you talked to him?
A. Spoke with him, yes.
Q. Okay.
A. He was out of town and wouldn't be back for a couple of weeks. He said there was a
family crisis or something. I was hoping his family wasn't ill.
Q. Did you call him?
A. I don't have a cell phone number for him anymore. I lost it. So when he was in town,

the conversations were less and less after I had spoken with the sheriff's department and
found the information out that I had found and the way I had been treated. And it's a little
difficult for me to be civil to someone that I dislike.
Q. Well, I gather you tried your best to let Mr. Schaffel think he could still co mmunicate
with
you?
A. Yes.
Q. Up until two weeks ago, right?
A. Yes.
Q. Was that at the request of the sheriffs?
A. No, that was more me. If he d id get in touch with me, I did tell them.
Q. And when did you last talk to Ian Drew?
A. He got promoted from his job just after the first of the year. I had dinner with him.
There's
a group of us that go out on Wednesday nights, and I think it was a month ago that I last
talked to him. It was getting close to my uncle's birthday, so we did -- everybody has to
come on this Wednesday night to not miss my uncle's birthday.
Q. Your last communicat ion with Dieter was when?
A. Oh, a long time ago. Not within the last year, I don't think. Well, I think The Ivy
incident was the last time that I spoke to him. I may -- oh, no, no, no, no. I did try to call
him. Sorry. I did try to call him afterwards. And I may have made the one phone call. I
don't remember if I made it or not. I haven't seen any of the stuff. So if there's something
there, I'd be happy to look at it and tell you what was done and what was said and what
was meant, if you'd like.
Q. I'm just asking you.
A. Blonde. I don't remember the day, you know. I think I d id, but I can't totally swear to
it.
Q. How about Konitzer. When do you think you last talked to him?
A. If I did, it was very shortly after the video.
Q. Okay. Would it be accurate to say that your impression was that Schaffel, Konitzer, and
Dieter were trying to profit off problems Mr. Jackson had? MR. ZONEN: I'm going to object
again as speculative and lack of foundation. THE COURT: Sustained.
Q. BY MR. MESEREAU: Did Schaffel tell you that he and Dieter and Konitzer were going
to make a lot of money off of the problems that came out of the Bashir documentary?
A. They said they were going to fix the problem and bragged that they had made money.
MR. ZONEN: Objection; nonresponsive. They said. THE COURT: Overruled.
Q. BY MR. MESEREAU: That bothered you, didn't it?
A. Yeah.
Q. Did you ever tell Schaffel, I don't like what you're doing to Michael, or words to that
effect?
A. If I had said that, then I wouldn't have been able to find out what he was doing and try
to get word to whoever was handling him, You guys are going to get screwed.
Q. So what you were trying to do was make Schaffel think he could maintain a friendship
with you, but what you really wanted to do was get information from him?
A. Yeah. He was out to hurt Michael, in addit ion would hurt my children.
Q. And did you feel Dieter was trying to hurt Michael and also your children?
A. I think they're opportunistic vultures.
Q. Would that be Dieter, Konitzer and Schaffel?

A. Okay. You can do them alphabetically if you'd like.

Q. You're talking about the three of them, right?
A. All of them.
Q. Who else are you referring to as vultures, besides those three?
A. If it's a personal opinion, does it count? MR. ZONEN: I'm going to object as beyond the
scope of the direct examination and speculative and improper opinion. THE COURT:
Sounds like she's got a long list. I think I'll sustain the objections (Laughter.) THE
WITNESS: Thank you.
Q. BY MR. MESEREAU: Okay. Ms. Rowe, at some point, did you learn that Santa Barbara
sheriffs had recorded a discussion with you?
A. You did? You did? No, I didn't know that.
Q. Okay.
A. Damn you guys. You don't share anything.
Q. Did you ever learn that any discussion you had with the Santa Barbara sheriff was, in
fact, recorded?
A. Well, if -- if you're referring to I was with them and, yeah, they were recording, so
that's what I thought was recording. Did you bug my phone?
Q. So at some point you knew they were recording -- at some point you knew they were
recording a discussion with you -A. Yes.
Q. -- right?
A. It was a discussion with me with Marc Schaffel or with Ian Drew.
Q. Okay. How about with you just alone with an officer?
A. Oh, when I was speaking with an officer, yes, there was a -- an interview that was
done.
Q. Okay. And where did that interview take place, if you know?
A. Calabasas. And I can't give you the name of the place because I don't remember.
Q. Do you know what officer that was?
A. Officer Steve Robel. Sergeant Steve Robel, actually.
Q. Do you know approximately when that interview took place?
A. Not off the top of my head, no.
Q. Do you recall, at one point, you mentioned the possibility of going to The Enquirer? Do
you rememb er that?
A. Me?
Q. Yes. I don't know if it was -- you were joking or not, but do you recall saying
something like that?
A. It would have been totally joking and sarcastic and, Let's see if we can mess with
them.
Q. Well, you talked about at one point Ms. Arvizo's orchestrating lawsuits. Do you
remember
that?
A. Yeah.
Q. And you referred to the J.C. Penney case, correct?
A. Probably.
Q. Did you do your own research into what Janet Arvizo had done in the J.C. Penney
case?
A. Just by asking people who had heard something on the news. And I hadn't sat down at
the computer and actually properly researched it, no.

Q. And you told the officer that you -- MR. ZONEN: I'm going to object as hearsay and
irrelevant, exceeding the scope of direct. THE COURT: Sustained.
Q. BY MR. MESEREAU: When you spoke to the officer in that interview, were you trying
to in some way protect Michael from the Arvizos?
A. Yes.
Q. And that's because you thought the Arvizos were taking advantage of Michael, right?
MR. ZONEN: I'm going to object as lack of foundation, exceeding the scope of direct. THE
COURT: Sustained.
Q. BY MR. MESEREAU: At one point you told Officer Robel that Schaffel had made seven
and a half million dollars off your interview. Do you remember that?
A. Yes.
Q. Did Schaffel tell you that?
A. Yes.
Q. Did you have any reason not to believe that he'd made seven and a half million?
A. I don't know what shows go for. Michael doesn't do interviews, so I'm sure that
anything that was televised or produced was worth a lot of
2 money.
Q. Did Schaffel offer you any of that money?
A. No, and I wouldn't have taken it.
Q. Did you know -- did you have any idea why Schaffel told you he made seven and a half
million off your interview?
A. He likes to brag. Look what I have. Look what I've done.
Q. Did Schaffel tell you any of that money went to Dieter?
A. He didn't. The way he spoke about it was all him.
Q. Did he tell you any of that money went to Konitzer?
A. No, again, all to him.
Q. Was it your understanding that Schaffel, Dieter and Konitzer worked together or -what was your understanding of their relat ionship?
A. Michael had a previous relationship with Dieter and Ronald, so if Marc wanted to get in
touch with Michael he could go through them, if he couldn't get ahold of him himself. But I
think Marc felt that he handled everything in the United States. And that they were
involved in the European things and in marketing or something.
Q. Did you think Dieter, Konitzer and Schaffel were co mpeting with each other at all?
A. There was some -- MR. ZONEN: I'm going to object as irrelevant, exceeding the scope
of direct. MR. MESEREAU: Sustained.
Q. Did Schaffel ever tell you he was in any company with Dieter and Konitzer? MR.
ZONEN: I'm going to object as exceeding the scope of direct and hearsay. THE COURT:
Sustained.
Q. BY MR. MESEREAU: Do you remember telling the officer who interviewed you,
Michael is very, very easily manipulated especially if he's scared?
A. Yes.
Q. You were trying to tell the officers that Michael was being taken advantage of by these
people, weren't you?
MR. ZONEN: Objection; asked and answered. THE COURT: Overruled. You may answer.
THE WITNESS: I'm sorry?
Q. BY MR. MESEREAU: You were trying to tell the officer that you thought Michael was
being taken advantage of by these people, right?
A. Yes.

Q. Now, you indicated in your interview you were there for about nine to ten hours, right?
A. Yes.
Q. How much of that time do you think you were answering questions?
A. It was -- we were on that stupid couch for seven hours, with no breaks except to
change film.
Q. And was that you and Mr. Drew?
A. I was on the couch. Drew -- Ian was opposite me, either in a chair -- I think he was in
a chair.
Q. Okay. So if you think you know, how many hours of actual interview do you think there
was with you?
A. The full seven hours. Except for the -- the time that it took to change videotapes.
Q. Okay.
A. I'm sorry. We didn't break for anything.
Q. And you have before today, I believe you said last night the most recent time, seen a
DVD of what purports to be that interview, right?
A. It's not the whole interview.
Q. And is that about two and a half to three hours long, the one you saw?
A. It was about three hours.
Q. And who gave you that DVD to watch?
A. I asked for a copy from Mr. Zonen.
Q. And you watched it last night, right?
A. Yes, I did.
Q. And correct me if I'm wrong, I think what you're saying is that many hours of your
interview don't appear in that DVD, right?
A. I don't see how I could have sat there for seven hours and only had three hours on
tape. I don't remember any breaks except for when the cameras were -- the film was
being changed. I interrupted the interview to tell them the film was -- the camera was
blinking, the light. I d idn't want to be in the middle of the statement and have to start
over again, to tell them that the lights were blinking, to change the film. I saw cuts in that
film, in that tape, that were -- had nothing with me saying, It's blinking, take it off, so
there's -- there is stuff missing from that video.
Q. When Schaffel told you he'd made seven and a half million dollars off your interview,
did he ever tell you who he made the money from?
A. I think he said it was FOX Network. And someone in Europe. But I don't remember who
it was in Europe.
Q. And was it your understanding that he kept all the footage of your interview?
A. Yes. It was all taken upstairs to a bedroom where they did the editing that night.
Q. Okay. How did you know they did the editing that night?
A. I was there for about an hour when they were doing it.
Q. Were you upstairs in the bedroom while they were doing it?
A. Yes.
Q. And who is they?
A. Marc was in and out. I don't remember -- I think it was Christian that was doing the
editing. Ian told me he was going to be there all night to get the video done.
Q. Now, Mr. Jackson wasn't there for any of that interview, was he?
A. No.
Q. Were you being asked to assist in the editing upstairs?
A. No, I wanted to see what they were putting down. I'm a bit of a control freak.

Q. So did they ever object to you being upstairs and watching what they were doing?
A. No, it just got to be too late and too long a day and I had to go home. I had school.
Q. But during the hour that you were upstairs watching the editing, what did you see
them do?
A. The very beginning of the interview talking about Michael, me speaking about Michael
and what kind of a person he is. And the -- I gave them a list, not a written list, but a
verbal list of things that I wanted included to make sure.
Q. In that interview, what kind of a person did you say Michael was?
A. Generous. To a fault. Giving and kind.
Q. Anything else do you recall saying?
A. Good father. Great with kids. Put other people ahead of him. Things like that.
Q. If you can, do you remember anything else you said about Michael?
A. He's a brilliant businessman. There's different Michaels. There's, like, my Michael.
Q. Do you want some water?
A. And the Michael that everyone else sees.
Q. And that would be the public Michael?
A. Yes.
Q. That would be Michael the entertainer, right?
A. Michael the entertainer, yeah.
Q. When did you first meet Michael?
A. In the .80s.
Q. And how did you meet Michael?
A. Through my office when I worked with Dr. Klein.
Q. Okay. And what was your position with Dr. Klein at the time?
A. I was an assistant.
Q. And Michael went to Dr. Klein for various treatments, right?
A. Yes.
Q. And do you recall when he first went to Dr. Klein?
A. Yes. The very first day, yes. I was not his nurse then.
Q. And what was the treatment he was receiving; do you know? Was it a skin condition he
had? MR. ZONEN: I'm going to object at this point. The question is, What was the
treatment he was receiving? MR. MESEREAU: I'll withdraw it. I'll withdraw it. THE COURT:
All right. It's withdrawn.
Q. BY MR. MESEREAU: You met him in the early .80s?
A. Yes.
Q. And you continued to know him through the .90s until you were married, right?
A. Yes.
Q. And how long did you work for Dr. Klein?
A. From .79 to 2001, I think it was, or 2000.
Q. Okay.
A. I don't remember the exact dates.
Q. Okay. Do you recall ever going on tour with Michael?
A. Uh-huh.
Q. And when did you first go on a tour with Michael?
A. What was the tour after Bad? Was it the History tour, or Dangerous? It was the
Dangerous tour, I'm sorry. MR. ZONEN: I'm going to object to communications between
the witness and the defendant and ask that that be stricken. THE W ITNESS: Sorry. THE
COURT: Stricken.

Q. BY MR. MESEREAU: Let me try and ask it again. What was the first tour that you
went on with Michael?
A. Dangerous.
Q. And approximately when was that?
A. I don't remember. That was -- all those tours. And they all just ran together, because it
was a long schedule.
Q. Okay. Was it in the .80s or .90s; do you know?
A. I think it was in the early .90s.
Q. Okay. And where did that tour go to?
A. I think it started in Bangkok, and went throughout Asia, Japan, S ingapore. Then there
was a break. And then it went to Europe. I did go to the last concert in Gutenberg, I think
on the tour previous to that. Because Gutenberg wasn't on the Dangerous tour.
Q. And were you traveling with Michael along with his physician?
A. Yes.
Q. Okay. And you then went on another tour after that?
A. Yes.
Q. And what tour was that?
A. History.
Q. Okay. And approximately when was that?
A. It seemed like it was right after Dangerous, within a year or two after Dangerous. It
could have been a little b it longer than that.
Q. And you were on that tour along with the physician as well, right?
A. We were married when that was going on.
Q. Okay.
A. So, no. Klein would come every once in a while, but I was there every three weeks to
see
little Michael and Michael and to see how everybody was, because I was still working. I
couldn't more often than that.
Q. When did you first meet Mr. Sneddon?
A. The day before yesterday. Two days ago. When did I come up here? I came up here
Tuesday.Today's Thursday. I came up here Tuesday.
Q. I mean, your first time you ever met Mr. Sneddon was the early .90s, wasn't it?
A. I don't remember. I remember I did a deposition. I thought it was for a woman. I don't
remember. I don't remember any of that part. I tend to block out unpleasantries. I don't
remember any of that part. I don't remember if Mr. Sneddon was there or not.
Q. Okay.
A. I think -- I think I just met him.
Q. Okay. Do you know when you were first contacted about this particular case by anyone
associated with the sheriffs or the prosecution?
A. It was -- there was a voice mail on my car phone, which I don't give out because it's
stupid to give out a car phone if you're not in the car all the time. And they had gotten it
through -- somehow probably through Schaffel, because that's how the tabloids got it.
Because Marc Schaffel handed out that phone number, becaus e that was the only one he
had, because I had to call release from that line to call his house. So there was a message
left, and I did not return the call. And then on a trip back from Palm Springs, probably
eight or nine o'clock at night, it was dark, I'm going to guess it could have been a little b it
later, but eight o'clock or 9:00 the phone rang, and I thought it might have been someone
-- something wrong with one of my animals or something. And I answered it, and it was

Sergeant Robel.
Q. Okay. And do you know approximately when that was?
A. I don't. I'm sorry.
Q. Was it like a year ago?
A. Oh, yeah. Yeah. Yeah.
Q. Now, you said Schaffel was giving information to the tabloids?
A. Yes.
Q. Was he giving information to the tabloids about Michael Jackson, to your knowledge?
A. He was leaking information.
Q. To your knowledge, was he trying to profit from the tabloids with information about
Michael Jackson?
A. I don't think monetarily. I think maybe through manipulation, you know, Maybe I can
stop this, or I can talk to so and so and fix it.
Q. Has it been your belief that Schaffel has been trying to create problems for Michael
Jackson so he could profit from them? MR. ZONEN: Objection. Asked and answered and
speculative, lack of foundation. THE COURT: Sustained.
Q. BY MR. MESEREAU: Did Schaffel ever tell you in your conversations that he was going
to generate crises around Michael Jackson so he could then find ways to profit?
A. Just this lawsuit. And I don't know the details of the lawsuit.
Q. Did he tell you he intends to make millions from his lawsuit against Michael Jackson?
MR. ZONEN: Objection; asked and answered. THE COURT: Sustained.
Q. BY MR. MESEREAU: Did he tell you whether or not Dieter or Konitzer are still doing
business with him when you last talked to him?
A. When I was speaking with him, he didn't say anything about business.
Q. But he said -A. He was more concerned about self-preservation at this point.
Q. He said he's still talking to them?
A. I think he is, yes. I think he is. I don't know. MR. ZONEN: The question is did he say.
THE WITNESS: I don't -- THE COURT: Is that an objection? MR. ZONEN: That's an
objection, nonresponsive. THE COURT: Sustained. Stricken.
Q. BY MR. MESEREAU: You met with Mr. Zonen last night; is that correct?
A. Yes.
Q. Did you have a long meeting with him?
A. I watched the video there. And I spoke with him for maybe 20, 25 minutes.
Q. Did Mr. Zonen talk to you about what he was going to ask you today?
A. No.
Q. He just asked you pretty much to watch the video?
A. Yes.
Q. And where did this meeting take p lace? Don't give me an address, if it's where you
were -A. Oh. It's in an office that they had.
Q. That's the District Attorney's Office?
A. Yes.
Q. Okay.
A. I don't know the address. So I'm lost.
Q. When was the last time any representative of the sheriff's office asked you to record
somebody?
A. I want to say last year. THE COURT: Let's take our break. MR. MESEREAU: Yes, Your

Honor.THE COURT: Counsel? MR. MESEREAU: Thank you, Your Honor. Your Honor, we
have no further questions, and we withdraw our motion. THE WITNESS: Thank you.
REDIRECT EXAMINATION BY MR. ZONEN:
Q. How many conversations did you have with Ronald Konitzer?
A. One or two.
Q. Over the telephone?
A. Yes.
Q. And the length of each of those conversations?
A. Minutes.
Q. Minutes? Did you ever see Ronald Konitzer interact with Michael Jackson?
A. Not since I had met him in Europe on tour years before.
Q. So you're talking about conversations that may have taken place when, in the early
.90s?
A. Yes.
Q. All right. Since the early .90s, have you seen him interact with Mr. Konitzer?
A. Physically, no. Just on the phone.
Q. Did you hear him interact with him on the telephone, in other words, conversations
where you were present?
A. When Mr. Schaffel was setting up the interview -Q. Yes.
A. -- Ronald was there with Michael.
Q. Was that the only conversation that you had, were party to -A. No.
Q. -- involving Mr. Jackson and Mr. Konitzer?
A. No. There was one or two after that. Just -- after the interview, thanking me, saying
everything was going to be fine, and I don't recall if there was another one after that.
Q. Was Mr. Jackson involved in those conversations?
A. No, he was not.
Q. That was just a conversation with you and Mr. Konitzer?
A. No, Marc would have been on the phone. He did not have my phone number.
Q. All right. So it was a conversation involving you, Marc Schaffel and Ronald Konitzer?
A. Yes.
Q. And the subject of that conversations was what?
A. Superficial. About the video.
Q. Nothing about Mr. Jackson's business affairs?
A. No. Not with Michael on the phone, no.
Q. Did any of them talk to you about issues dealing with the Martin Bashir video?
A. Before or after the interview?
Q. After the interview.
A. When the interview aired, it did, and they said that the interview that I had done would
help deflect and do damage control.
Q. Did they say that to you more than once?
A. Yes.
Q. Did Mr. Konitzer say positive things to you about your involvement in this interview?
A. About my possible involvement?
Q. No.

A. I'm sorry.
Q. Did he say positive things to you about your involvement?
A. Yeah. Yeah.
Q. Did he say that you were helpful?
A. Yeah.
Q. Did you believe that you were?
A. Yeah.
Q. Was that your intent?
A. Yes.
Q. All right. Do you still like Michael Jackson?
A. I have very strong memories and feelings for the Michael that I have known but haven't
seen since 1999. But those are based on my feelings. We haven't spoken.
Q. All right. Is it the case that the sum total of your communication with Mr. Jackson since
1999, six years ago, was a two-and-a-half-minute conversation that you described?
A. Correct.
Q. And that was a conversation where he asked you to participate in this video; is that
correct?
A. To work with Ronald, Dieter, and Marc.
Q. Is it clear to you that he understood that you wanted to see your children?
A. Yes.
Q. All right. Did he ever call you to say that -A. No.
Q. -- or to invite you up to come see the children?
A. No, he didn't.
Q. Who do you believe is responsible for your not being able to see the children? MR.
MESEREAU: Objection. Relevance; foundation. THE COURT: Overruled.
Q. BY MR. ZONEN: You can answer the question.
A. He's their father. Ultimately it's his decision. I don't want to believe that. I want to
believe that it's other people. I want to believe it's Marc Schaffel threatening him that I
want to take the children, things like that.
Q. How long has Marc Schaffel been involved with Michael Jackson? When do you believe
was the end of Mr. Schaffel's involvement with Michael Jackson?
A. I think The Ivy incident was probably what tore it.
Q. All right.
A. Marc told me he was on the outs and wanted to do what he could to get back in.
Q. When did he file the lawsuit against Michael Jackson?
A. I don't know how long it takes to actually get to court when you file a paper, or
whatever, but he had talked about it about three months ago.
Q. All right.
A. So I don't know if he was filing the papers then, if he was getting ready to file the
papers.
Q. All right. But your understanding is that Marc Schaffel hasn't had anything to do with
Michael Jackson for a number of months now; is that correct?
A. Correct.
Q. All right. And yet you're still being denied access to your children? MR. MESEREAU:
Objection. Leading; relevance; foundation. THE COURT: Overruled.
Q. BY MR. ZONEN: Is that true?
A. We're -- yes, yes.

Q. All right. Well, then who do you think is responsible for that, if it's not Marc Schaffel?
MR. MESEREAU: Objection. Relevance; foundation; lead ing; and opinion. THE COURT: It's
argumentative. Sustained.
Q. BY MR. ZONEN: Tell us, in your opinion, who is responsible at this time for your not
being able to have access to your children? MR. MESEREAU: Same objection. THE COURT:
Overruled.
THE WITNESS: When I was first promised to see the kids, when Michael -- he called me,
for me to show up when they were at that age of three and four, four and five, I could be
introduced as a friend, as a friend of daddy's. And you don't confuse a child by saying,
Oh, this is your mother. I can't do that now. They're too old. To do something like that,
it would be too traumatic. I would not walk in and say, Hey, I'm your mom, you know,
Want to go out? It's -- it's so much more complicated than that when reintroducing
yourself to children who may or may not remember me.
Q. BY MR. ZONEN: Are you saying that you believe that Mr. Jackson is amenable to your
seeing your children; it's just a question of how? MR. MESEREAU: Objection. Leading;
argumentative; no foundation. MR. ZONEN: It's impeachment, Your Honor, as to the
leading issue. MR. MESEREAU: Improper opinion. THE COURT: The objection is overruled.
Do you want the question read back? THE WITNESS: No. Thank you. I'm hoping in my
heart that he is. But we haven't spoken, so I don't know. I get to deal with Abrams and
Hall.
Q. BY MR. ZONEN: Why do you believe he hasn't spoken with you? MR. MESEREAU:
Objection. Leading; argumentative; foundation; relevance. THE COURT: Overruled. THE
WITNESS: I don't know if he is concerned about this case. I don't know what his concerns
are, if he thinks I'm going to take the children from him. I don't know. I haven't spoken to
him. I don't know.
Q. BY MR. ZONEN: How many conversations have you had with Dieter Weizner?
A. The last conversation I had with Dieter I think was at The Ivy.
Q. And how many conversations prior to that?
A. One or two.
Q. You said that you were set up, is that correct, at that -A. In my opinion -Q. -- lunch?
A. -- yes.
Q. What does that mean, set up?
A. You don't go to lunch and then call the paparazzi to come and take a picture of you
while you're trying to have a salad, and then someone runs across the street and almost
gets hit by a car because they're taking my picture.
Q. You didn't mention that in cross-examinat ion when you said that to Mr. Mesereau.
A. Oh, sorry. I thought -Q. Is that what it was that you believe to be the set-up?
A. Yes, because Michael was having a meeting with his -- some group of people at the
Beverly Hills Hotel or something. And Marc and Dieter were not included. So they were
going to show him.
Q. All right. What does the presence of paparazzi have to do with that?
A. I'm assuming because Marc Schaffel could not get to Michael, that if someone were to
see it on T.V. or something, then it would be detrimental to him.
Q. How long has Michael Jackson had an association with Ronald Konitzer?
A. I know that he knew him in the .90s doing marketing and things like that in Europe. I

don't know, I haven't -- I haven't had any involvement with Michael since .99, so I don't
know.
Q. All right. You offered the opinion that you believe that this group of people are taking
advantage of him.
A. Yes.
Q. Have you ever actually seen them interact with him?
A. No.
Q. Are you aware of any of the transactions that have taken place between Mr. Konitzer
and Michael Jackson?
A. Just when Konitzer was on the phone with Michael to tell me that it was okay to work
with these people to do what needed to be done for the project.
Q. And would you consider that to be a conversation for Mr. Jackson's benefit? MR.
MESEREAU: Objection. Foundation; vague. MR. ZONEN: It's her opinion. THE COURT:
Sustained.
Q. BY MR. ZONEN: The conversation that you had over the telephone with Mr. Konitzer
involving your involvement in a rebuttal was supposed to defuse a difficult situation that
Mr. Jackson was in; is that correct?
A. That was my understanding.
Q. So that was for his benefit, for Mr. Jackson's benefit?
A. Correct. MR. MESEREAU: Objection; argumentative. Same objection. Foundation;
opinion. THE COURT: Overruled. THE W ITNESS: Correct.
Q. BY MR. ZONEN: And that's correct. How many conversations have you been party to
between Mr. Konitzer and Mr. Jackson?
A. Just the one.
Q. That was the only one?
A. Yes.
Q. So you don't really know what extent of communicat ion they had between each other;
is that correct? MR. MESEREAU: Objection. Assumes facts not in evidence; foundation;
move to strike. THE COURT: Overruled. THE WITNESS: Only what I was told.
Q. BY MR. ZONEN: Ahh. And told by whom?
A. By Marc.
Q. Only Marc; is that right?
A. And Dieter.
Q. Okay. Marc is the person you believe to be an inveterate liar; is that correct?
A. Yes.
Q. He told you that he was making seven and a half million dollars off of this production,
the Maury Povich production?
A. Correct. MR. MESEREAU: Objection; assumes facts not in evidence. THE COURT:
Overruled.
Q. BY MR. ZONEN: Is that correct?
A. Yes, that's what I was told.
Q. Did you believe he was profiting from that production?
A. Yes.
Q. Did you understand that production to be a production for profit?
A. I didn't care.
Q. But did you understand it to be a production for profit?
19 A. If I assumed that, you know, if you're going to make it and sell it, yes, it's for
profit.

Q. And you understood it was being sold?

A. Yes.
Q. You understood it was being marketed?
A. Yes.
Q. And that, in fact, was Marc Schaffel's job, was to market that film?
A. Yes.
Q. And your involvement in it was to make it more marketable; is that true?
A. Correct.
Q. Do you think it was inappropriate for Marc Schaffel to make a profit off that film? MR.
MESEREAU: Objection. Improper opinion; calls for speculation; foundation. THE COURT:
Sustained.
Q. BY MR. ZONEN: In your opinion, should he have mad e some profit off that film? MR.
MESEREAU: Same objection. THE COURT: Sustained.
Q. BY MR. ZONEN: Do you have any reason to brief that Michael Jackson didn't receive
any profit off that film? MR. MESEREAU: Same objection. THE COURT: Sustained.
Q. BY MR. ZONEN: Are you aware that Michael Jackson was given over a million dollars
in cash by Marc Schaffel during that period of time? MR. MESEREAU: Objection. Assumes
facts not in evidence; foundation; move to strike. THE COURT: Sustained.
Q. BY MR. ZONEN: Now, I'd asked you your number of conversations with Dieter
Weizner. Is Weizner somebody you knew back in the early .90s as well?
A. He said I'd met him. I don't remember. I met a lot of people when Michael was on tour.
There was a ton of people involved.
Q. Did you have a face-to-face conversation with Dieter W eizner in 2003?
A. For the inter -- at The Ivy. Not for the interview or anything.
Q. And The Ivy was just the lunch that you had with them?
A. Yes.
Q. Did you stay and actually have a lunch?
A. I was -- yeah, I was a wreck. They moved us inside until it was completely out of
control, and it had -- I had to leave.
Q. So you didn't really have a conversation with him?
A. We did talk.
Q. About what?
A. About how they were going to -- that the people that were on the other side of town
were inching them out and not including them, and that this would show them and get
their attention because I was with -- with them.
Q. All right. Now, this was in 2004; is that right?
A. I think -- I don't remember the date.
Q. This is well after the Indictment was returned against Mr. Jackson; is that correct?
A. No. It was -- I believe it was before.
Q. Were you -1 A. I don't -- I don't remember the date.
Q. Were you already involved in h aving given informat ion to law enforcement regarding
this investigation?
A. I think so. I don't remember.
Q. You described Mr. Jackson as a brilliant businessman.
A. Yes.
Q. Is that a true statement?
A. In my opinion, yes.

Q. During the years that you knew him, you understood him to be very talented at the
business end of his career; is that correct?
A. I thought so.
Q. He was successful in making an awful lot of money during the years you knew him; is
that right?
A. Yes.
Q. And he knew Mr. Konitzer and Mr. Weizner for over ten years, didn't he?
A. I don't know how long they'd known each other. I don't remember when they met. I
remember meet ing -- like I said, I remember meeting Ronald when he was showing
marketing things to Michael. I don't even remember what city we were in.
Q. But it was the early .90s, was it not?
A. Yeah. Yeah. It would have had to have been. So, yeah, I guess that would be ten
years.
Q. Would the same be true as to Dieter W eizner?
A. I don't remember meeting Dieter. Even though he said I did, I don't remember.
Q. So when did you understand Mr. Weizner's involvement with Michael Jackson to begin?
A. The man carried six cell phones. I wasn't quite sure what -- I wasn't sure if he was a
liaison, if he was doing the European marketing working with Marc Schaffel doing the
American things. All I knew is that the three of them were -Q. Who are we talking about right now?
A. Ronald, Marc and Dieter were involved in -- directly in the video and saving Michael
after this documentary came out.
Q. All right. Is there anything that you saw that was put out to any of the tabloids or any
of the newspapers by any of the three of them that you felt was negative to Michael
Jackson?
A. What do you mean?
Q. Well, you talked about Mr. Schaffel giving information out to the tabloids; is that right?
A. Yes, but he did it to -- he said he could run interference. That was why he had Ian
Drew as a plant at The Globe, to run interference, because -- I didn't know this, but I
guess the magazines are all owned by the same company and they shuffle the stories
around.
Q. What kind of interference?
A. To keep bad stories or gossip, or whatever, out, so he would release good information
to someone he thought was more reputable.
Q. Bad stories about whom?
A. Michael.
Q. All right. So the work that they were doing was trying to boost his reputation?
A. Correct.
Q. And improve his reputation?
A. Correct.
Q. Not destroy him.
A. After this documentary, correct.
Q. All right. Was it your understanding that the more money Michael Jackson was capable
of making translated to the more money those three men were capable of making? MR.
MESEREAU: Objection. Foundation; relevance. THE COURT: Sustained.
Q. BY MR. ZONEN: Did you know Frank Cascio?
A. Yes.
Q. How did you know Frank Cascio?

A. I met his family years ago.

Q. Years ago?
A. Yeah.
Q. How old was Frank Cascio when you met his family?
A. It was just after little Michael had been born. He must have been midd le teens maybe.
He was the oldest of the boys.
Q. You didn't know him or whom involved in Mr. Jackson's relationships or business
affairs?
A. No.
Q. He was a teenager?
A. This is years ago. We're talking -Q. Yes.
A. Yeah. No, no, no.
Q. Did he visit Mr. Jackson regularly?
A. The family came up -- I knew him with the family, when Mr. and Mrs. Cascio were there
with the kids, with the boys.
Q. Did you understand Frank Cascio's relationship with Michael Jackson to be very close?
A. He was close with all the Cascios.
Q. Did you know Vinnie Amen?
A. No.
Q. You made the statement, If I'm considered a commodity of Mr. Jackson. What did
that mean? MR. MESEREAU: Objection. Misstates the evidence. She was talking about Mr.
Schaffel. THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Do you remember making that statement?
A. Yes.
Q. What did that mean?
A. I was sellable.
Q. Do you mean in conjunction with your giving this interview?
A. Yeah. I don't do interviews.
Q. Did you ever give an interview for the press?
A. I did a couple of things with Chuck Henry in the late .70s. He was a newscaster for NBC
in Los Angeles.
Q. You've given no interviews other than that?
A. Not personally, no.
Q. Did you believe that made you more marketab le?
A. To do the interviews?
Q. Yes.
A. I don't want to be marketable.
Q. I didn't ask that. I said, do you believe that it made you more marketab le; in other
words, for somebody else?
A. Yeah.
Q. Do you believe that you were asked to participate in this interview because it wou ld
make the film more marketab le? MR. MESEREAU: Objection. Calls for speculation;
foundation. MR. ZONEN: It's her opinion. MR. MESEREAU: And improper opinion. THE
COURT: Sustained for speculat ion.
Q. BY MR. ZONEN: Did any of the three of them, Konitzer or Weizner or Schaffel, talk to
you about your participation in this video in terms of mentioning that it would make the
film more marketab le?

A. Yes, and that it would help Michael.

Q. Help Michael Jackson in terms of its marketability?
A. Of the damage control from the Bashir document -- documentary thing, show. MR.
ZONEN: Thank you. I have no further questions. MR. MESEREAU: No further questions,
Your Honor. THE COURT: All right. Thank you. You may step down.

IRIS JOAN FINSILVER EXAMINATION

DIRECT EXAMINATION BY MR. ZONEN:

Q. You're not used to being on that side of the witness stand, are you?
A. No, I'm not.
Q. What is your occupation?
A. I'm a lawyer.
Q. How long have you been an attorney?
A. I was admitted to the bar of Michigan in or about 1986.
Q. In then California?
A. In California, I believe I was admitted in 1989.
Q. What kind of a practice do you have?
A. Family law.
Q. And family law means what?
A. Divorce, custody, child custody, support, family matters.
Q. All right. Is Debbie Rowe Jackson your client?
A. Yes.
Q. How long has she been your client?
A. Since in or about 1996.
Q. Did you represent her in her divorce with Michael Jackson?
A. Yes, sir.
Q. Do you continue to represent her?
A. Yes, sir.
Q. Were you present at the filming of an interview that took place in Calabasas at the
residence of Marc Schaffel back in February of 2003?

A. Yes, sir.
Q. Prior to doing that, had you engaged in any legal work to be able to allow Deborah
Rowe to participate in that interview?
A. Yes, sir.
Q. What was the purpose of that?
A. It was -- she had signed a confidentiality agreement, and in order for her to speak of
Mr. Jackson, she would have to be released from the confidentiality agreement for the
express purpose of speaking about Mr. Jackson.
Q. Did you draft that waiver of confidentiality?
A. I think it was a mutual effort between Mr. Jackson's lawyers and myself. It was in fact,
yes.
Q. But it was one that was drafted as a document?
A. Yes, sir.
Q. And was it one that required signatures?
A. Yes, sir.
Q. Whose signatures were required on that document?
A. Mr. Jackson's and Deborah Rowe Jackson's.
Q. And did Debbie Rowe sign the document?
A. Yes, sir.
Q. And to your knowledge, did Mr. Jackson sign the document?
A. Yes, sir.
Q. And following the signing of that document, did Miss Rowe participate in an interview?
A. Yes, sir.
Q. Were you present during the interview?
A. Yes, I was.
Q. Were you present during the entirety of the interview?
A. Yes.
Q. Approximately how long did that interview last?
A. Well, I can tell you the whole day was about nine hours. And I can't exactly tell you
how long the filming took place. It was many hours of filming throughout a nine-hour
day.
Q. All right. Was there a man by the name of Marc Schaffel present?
A. Yes, sir.
Q. Did you know Marc Schaffel prior to that day?
A. I had never met him prior to that day.
Q. Did you know his name prior to that day?
A. I believe I did.
Q. In what context?
A. In that he would be -- MR. MESEREAU: Objection. Relevance and foundation. THE
COURT: Overruled.
Q. BY MR. ZONEN: Go ahead. THE COURT: Go ahead.
Q. BY MR. ZONEN: Oh, you don't need to be told that, do you?
A. In that he would be part of the interview that was going to be taking place, so that's
how I heard of his name. And I knew that we were going to be going to Marc Schaffel's
home, where the filming was conducted.
Q. And was that where it was conducted, at his home?
A. Yes, sir.
Q. Was he present during the interview?

A. Yes, sir.
Q. Was he present during the entirety of the interview?
A. Yes.
Q. Did he periodically make comments with regards to the answers or questions that were
given? MR. MESEREAU: Objection; leading. THE COURT: Overruled. You may answer. THE
WITNESS: Thank you. Yes.
Q. BY MR. ZONEN: Did you hear any representations from Mr. Schaffel at any time during
the course of the filming that dealt specifically with the subject of Ms. Rowe's children?
A. Yes. MR. MESEREAU: Objection; leading. THE COURT: Overruled. The answer was,
Yes. Next question.
Q. BY MR. ZONEN: What were those representations? MR. MESEREAU: Objection;
hearsay. MR. ZONEN: Relevant for prior stated purposes. THE COURT: Overruled. You
may answer.
Q. BY MR. ZONEN: Go ahead.
A. I heard him, in connection with her answers, when she would give a favorab le answer,
Oh, Michael will be very, very pleased about this. You're really helping him out of a big
jam, and you'll go to Neverland and you'll see Michael and your kids.
Q. On how many occasions did he give an answer of that nature?
A. I recall two specific times. There may have been more. I just -- MR. MESEREAU:
Objection; move to strike. THE COURT: The last sentence is stricken. MR. ZONEN: Thank
you. I have no further questions. THE COURT: Mr. Mesereau? MR. MESEREAU: No
examination, Your Honor. THE COURT: Thank you. You may step down.

ANDREW R. DIETZ EXAMINATION

DIRECT EXAMINATION BY MR. SNEDDON:
Q. Mr. Dietz, you have a business -- you're going to have to lean into that mike. Okay?
A. Good morning.
Q. Good morning. Do you have a business?
A. Yes, I do.
Q. And what is the name of your business?
A. Air Apparent, Inc.
Q. And where is your business located?
A. Los Angeles, California. 8058
Q. And what is the nature of the business?
A. It's a retail travel agency.
Q. And basically could you describe for us what that means? What's a retail travel agency
do?
A. We arrange transportation.
Q. And any other services you provide in add ition to transportation?
A. Not that I can think of.
Q. In connection with that transportation, you make reservat ions at hotels and things like
that?
A. Yes. Certainly.
Q. Now, in that particular business, what is your position?
A. I'm the president.

Q. And how long have you been associated with that business?
A. Since 1980.
Q. Now, is one of your clients MJJ Productions?
A. Yes.
Q. And how long has MJJ Productions been a client of yours?
A. I believe around 15 years.
Q. And what is the nature of the business services that you provide to MJJ Productions?
A. We arrange hotel, air transportation, commercial air transportation, car reservations for
many of the people that he employs and engages in work for himself.
Q. What is the -- can you describe to the jury what the business relationship is in terms of
how the services, once they're provided, how they're invoiced and paid and how that
works?
A. A call -- I think if you're asking how is business conducted -Q. Yes.
A. -- a call's typically made and a reservation is usually made, a ticket is usually
generated. It's then invoiced and sent to the client.
Q. Now, at the time that the ticket is made, do you have to -- do you have to pay for the
ticket yourself?
A. The minute the ticket is issued, it's my obligation to pay the carrier.
Q. Okay. I guess that was the question. And then you pay it and then invoice the client?
A. Correct.
Q. And then the client repays you?
A. Correct.
Q. Was that the type of business arrangement that you had with MJJ Productions?
A. Yes.
Q. Now, at some point back in 2004, did members of the sheriff's department come to
your business and execute a search warrant with regard to your records?
A. Yes, they did.
Q. And those records involved MJJ Productions; is that correct?
A. Yes.
Q. And the time period covered by that was March -- February and March of 2003?
A. I believe that's correct. MR. SNEDDON: Your Honor, may I approach the witness? THE
COURT: Yes.
Q. BY MR. SNEDDON: All right. Mr. Dietz, I'm going to hand you a book, and there are a
number of exhibits in the book. And the first exhibit I'd like you to look at begins with 223
and I'd like you to look just quickly through 249, and ask you if you examined those
documents yesterday, just to ensure they're the documents that you examined.
A. Through what number?
Q. 249.
A. Did you say 239?
Q. 249.
A. I believe these are all the records that we reviewed last night.
Q. And those records are records from your business; is that correct?
A. That is correct. BAILIFF CORTEZ: Excuse me, sir. THE WITNESS: That is correct.
Q. BY MR. SNEDDON: And these records generally 8061 deal with what type of
transactions?
A. Airline reservations, or airline tickets.
Q. And are they records dealing with your business relationships with MJJ Productions?

A. They are invo ices which reflect transactions that we did.

Q. I think you're going to have to lean into that mike a little bit.
A. Those are invoices that relate to tickets that were issued to MJJ Productions.
Q. Now, are these generally the records that are kept in the regular course of your
business?
A. Yes, but not in the manner in which they were given to you.
Q. What do you mean by that?
A. I mean the invo ices are separated from the copies of the tickets.
Q. Okay. We'll get to that. But both of those documents are kept in the regular course of
your business; is that correct?
A. Yes.
Q. And the transactions that are reflected in those documents, do those reflect
transactions that were made at or about the time that those events occurred?
A. I believe they do.
Q. By people who are in your organization who are responsible for documenting those?
8062
A. Yes.
Q. Let's turn -- if you could get that exhibit book and put it back in front of you, I'm going
to ask you a couple of questions.
A. Okay.
Q. With regard to -- let's turn to Exhibit No. 224, if we can.
A. Okay.
Q. All right. On -A. 2-2-4?
Q. Yeah, 2-2-4. 224.
A. Gotcha. All right.
Q. 224 has two pages in it, correct?
A. Yes.
Q. Now, with regard to the first page, what is the title of that document?
A. It's called an Itinerary/invoice nu mber.
Q. Do you recognize that document?
A. Yes, I do.
Q. Can you explain to us how that document's generated?
A. An agent in the office will book a reservation. The reservation system will then, at the
agent's queue, ticket the reservation for the itinerary in question, and then an e-ticket is
basically created for a passenger to be picked up at Los Angeles International Airport.
Q. And then with regard to that particular document, how do you use that in your
business?
A. To collect money.
Q. To collect money. That's the invoice part of it?
A. That's the invoice part. The itinerary part is related to the -- for the accountant,
business manager, to see the nature of the -- see the actual details of the flight, as would
the ticket show you the same things, as relates to dinner or how long the flight was,
things like that.
Q. All right. So these are generated at or about the time of the transaction,
contemporaneous with the transaction?
A. Yes. In most cases.
Q. And you say the invoice part of it. How does it serve as an invoice? How do you use

that in your business practice?

A. I mail them out for my services, and I expect them to get paid in a timely manner.
Q. Okay. Now, the second part of that Exhibit 224 has what is called an agent coupon,
correct?
A. Correct.
Q. All right. Would you explain to us what the agent coupon is?
A. The agent coupon I believe represents our copy of the transaction for purposes of
maintaining it for our regulatory people. In the airline business, you have to report your
weekly sales of airline tickets.
Q. So that would be a record used by you to be audited -A. We present the, quote, auditor's coupon, and we retain the agent coupon. A ticket
has many different -- has flight coupons, as well as agent coupons, passenger coupons,
and auditor coupons.
Q. And how is the document -- agent coupon generated or prepared?
A. It's one of -- as I just stated, it's I think a five-part document.
Q. But internally that document is generated within your business?
A. Within our reservation system.
Q. Now, within your company, with regard to the agent coupon document, are those
located in a separate place in your business?
A. Yes.
Q. So they're not located exactly with the invoice and the itinerary informat ion?
A. Definitely not.
Q. But they're both located and kept for business purposes?
A. Correct.
Q. And are the exhibits contained in the ones that you reviewed, 223 through 239 (sic),
are those records regularly relied upon by you to conduct business?
A. I believe they are, yes. MR. SNEDDON: Your Honor, I'd move to admit 223 through 249
into evidence as business records. MR. SANGER: No objection. THE COURT: All right.
They're admitted. MR. SNEDDON: And with the Court's permission, I'd like to remove a
couple of the documents to publish. THE COURT: All right. MR. SNEDDON: To ask some
further questions. I don't need the lights just yet, Your Honor.
Q. There are two other documents that I want to show you before we go through the
publication process. And I'm showing them to counsel. These have been marked, Your
Honor, as 852, which is a three-page document from Air Apparent, and 853, which is a
five-page document, or five p ages in the document, which is also an Air Apparent record.
And may I approach? THE COURT: Yes.
Q. BY MR. SNEDDON: Mr. Dietz, I'm going to hand you the exhibit marked as Exhibit
852. I'd like you to take a look at that for just a moment.
A. Okay.
Q. Go ahead and take a look at the pages in that document. They're multip le pages. Do
you recognize those?
A. Yes.
Q. Those are also documents that were obtained through the search warrant?
A. I believe so.
Q. And those are also records that are kept in the normal course of your business?
A. I believe so.
Q. And it is also, just for the record, an itinerary/invo ice record, correct?
A. Correct.

Q. And let me show you 853 and ask you if you recognize that. And the pages attached,
there are five pages.
A. Yes.
Q. Do you recognize those documents?
A. Yes, I do.
Q. And you were able to compare those documents to your actual business records to
ensure that they were part of the records that were taken pursuant to the search warrant,
correct?
A. Yes.
Q. And with regard to those records, they were also made at or about the time of the
transaction?
A. Yes.
Q. By personnel -A. Yes.
Q. -- in your office and kept in the normal course of business?
A. Yes.
Q. All right. Thank you. Your Honor, I'd move to admit 852 and 853. MR. SANGER: No
objection. THE COURT: They're admitted. MR. SNEDDON: All right. Now, Your Honor, if we
could have the Elmo, I'd appreciate it.
Q. The document that's up there is 223, which is in evidence, okay? Now, do you
recognize this document?
A. Yes.
Q. Now, at the top of the document I'm indicating a customer number. Are the individuals
that you service assigned a customer number?
A. Yes.
Q. And that number carried over to all the business transactions that you conduct with
that particular individual or company?
A. Several accounts have different companies -- there is different -- there are some
accounts that have different customer numbers.
Q. In other words, an individual or a business may have more than one account with you?
A. Correct.
Q. Okay. But wherever they are billed to, that number is used, either on one of the
accounts or on another account with regard to that business or individual?
A. The MJJ Productions had more than one account.
Q. Correct. Now, the information at the top, it says, MJJ Productions. What is that
informat ion in terms of how you conduct your business?
A. That's the mailing -- that's the mailing address that we've been requested to send
invoices to.
Q. And with regard to the next line down, it says For, and has Gavin Arvizo, Star
Arvizo,
Janet Arvizo. Do you see that?
A. Yes.
Q. And what does that information reflect?
A. I believe it reflects the passengers' names.
Q. And obviously the next says, Travel Itinerary. This is the itinerary that was explored
for these individuals; is that correct?
A. Correct.
Q. And lastly, it ind icates whether the ticket is a one-way ticket or a round-trip ticket,

correct?
A. Correct.
Q. In this case, this particular itinerary that was looked into was a one-way ticket for
those individuals?
A. Correct.
Q. Now, with regard to this particular document -- look in the book, if you would, to the
document in front of you that's 224, okay?
A. Yeah.
Q. On that particular document, the heading on it is Itinerary and Invoice, correct? On
224?
7 A. Yes.
Q. And this particular document only reflects the itinerary on the date of February the
5th,
correct, of 2003?
A. Correct.
Q. What is the difference, if there is one, in the use between the document reflected in
223 and the document that you just spoke about in 224?
A. Well, the itinerary typically is a document which you would fax to somebody or e-mail
somebody to inform that -- to more or less confirm with the person that requested the
transportation that, This is the itinerary request -Q. Okay. And -A. -- correct? And then we expect, you know, That's right. Ticket it.
Q. And with regard to the travel itinerary, I want to go back to the date underneath where
it says, Travel It inerary, on 223, it says, 05 February, .03. That would be the date of
travel?
A. That's correct.
Q. Okay. We can take that one down. All right. This is Exhibit 852, all right?
A. Yes.
Q. Could you explain to us what this particular document is that is displayed as 852 and
that has the heading It inerary/Invoice Number?
A. This is primarily what I refer to as an invoice. And as I was relat ing before, besides
showing you how much the tickets cost, it also provides an itinerary for the passenger, or
for the person paying the bill, so that they can see that -- whatever flight informat ion they
want to see from that.
Q. All right. Now, in this particular document, 852, it reflects that the customer -- it has a
customer number, correct?
A. Correct.
Q. Is that the customer number for one of the accounts for MJJ Productions?
A. Yes.
Q. And then the To section on this particular document, 852, is where you would send
the bills to?
A. That's correct.
Q. Right below are a couple of names. What are those names? Why are those names on
that itinerary?
A. That probably represents the passengers flying.
Q. And then under Travel Itinerary, then that is the flight information, correct?
A. That is correct.
Q. And then on the Travel Itinerary it has, above -- on the line where I'm showing, it

shows air -- American Airlines Flight 1245, and then it has across there Business. What
does that reflect?
A. The type of service. Business class.
Q. Business class. And to your knowledge, how many types of services or classes are
there on ordinary domestic flights?
A. Primarily coach and f irst class. They throw in business as well.
Q. And then down at the bottom it would be the total amount due on this particular
invoice?
A. That's correct.
Q. All right. The second page of the Exhibit 852, what is that?
A. That's a copy -- that's the agent coupon.
Q. This is what you told the jury about earlier in your testimony?
A. Yes.
Q. And with regard to this particular document, the information that is on this document,
does it give flight information?
A. Yes.
Q. And does it give the name of the individual on it?
A. Certainly.
Q. So in this case, it says, Christopher Carter, correct?
A. Correct.
Q. And it also contains the amount of money that's paid?
A. Correct.
Q. All right. The third and last document of page 852 is another agent coupon, correct?
A. Yes.
Q. It reflects a different name on it; is that right?
A. Correct.
Q. And the name being?
A. Danny Crawford.
Q. And these two names are the same names that are on the front page of the
invoice/it inerary that you earlier talked about as Exhibit 852. I don't know if you have that
in front of you. We can put that back up. Here it is. Same two names under the For
section, F-o-r, in 852, correct?
A. The first one said Christopher Carter. That makes sense. The second one said Danny
Crawford.
Q. And they correspond to the agent coupons that go with this document?
A. Yes.
Q. The flight information matches up; is that correct?
A. That's -- hold on one second. If you go back to the ticket, I can tell you.
Q. All right. Put the agent coupon back up. You may want to heighten that up a little bit.
A. I'm trying to look first. BAILIFF CORTEZ: Okay. THE WITNESS: Can't see the flight
informat ion. J. American A irlines. I'm sorry, I'm not that familiar with these documents.
MR. SANGER: Your Honor, excuse me. I'm sorry. MR. SNEDDON: Let me -- MR. SANGER:
I couldn't hear the witness's last answer. MR. SNEDDON: There was no question pending,
I don't think. MR. SANGER: He was asked to look at the -- he said something about, I'm
not -- sounded like he said, I'm not familiar, and I couldn't hear what he said. THE
WITNESS: I said -- do you want me to answer? THE COURT: He said that he wasn't that
familiar with the document. MR. SANGER: Thank you, Your Honor. THE WITNESS: What
are -- what do you want me to tell you about this document? MR. SNEDDON: Let me just

put that down. Let's put 852 back up. This is....
Q. All right. On the document, 852, it has two airline t icket numbers, correct, in the lower
left-hand corner?
A. I can tell you if they're the same tickets numbers for sure -Q. You have to turn into the microphone.
A. I can tell you if they're the same numbers if you go back.
Q. You got ticket numbers on the invoice and itinerary.
A. That I can see. 465, 466.
Q. Okay. And then if you put up the other two -A. 466 and 465.
Q. They match?
A. That matches.
Q. So they go with that flight?
A. I believe they do.
Q. All right. Wasn't supposed to be that hard. It's hard to see from here. No problem. Let's
try 853. All right. Now, this 853 is another document that's an itinerary/invo ice, correct?
A. Yes.
Q. For March 2nd?
A. Right.
Q. And it reflects that there are four people who are supposed to travel under this
invoice?
A. Yes.
Q. And four tickets issued down in the lower left-hand corner, correct?
A. Yes.
Q. With ticket numbers associated with that flight?
A. Yes.
Q. All right. Now, I'm going to put up the first agent coupon for that flight. And I'll tell you
what I'm going to do. I'm going to come up there and hand you 852, the first page. Make
this easier.
A. Yes. Thanks.
Q. Now, looking at 852, and the front part of it that has the ticket informat ion for it, and
looking at the exhibit -- agent coupon, which is part of that exhibit, does the ticket
number on the front of that invoice match the agent coupon on the Exhibit 853? Or -853, yes.
A. Yes.
Q. All right. Let's put the second one up. And -- excuse me. That was for an M. Jackson,
correct?
A. Yes.
Q. All right. Let's put the second one up, the second agent coupon. Now, this particular
agent coupon has stamped in the midd le of it Void, v-o-i-d, correct?
A. Correct.
Q. And could you look at the front of the document, the first page with regard to the ticket
number? Does the ticket number on the agent coupon for a Michael LaPerruque match the
ticket number on the front of the invoice for this particular document, 853?
A. Yes.
Q. Now, with regard to your business practices, what does it mean when you have an
agent coupon that has Void on it?
A. The ticket was not used.

Q. And how is it that you become informed, in your normal business practices, that the
ticket was not used?
A. In our normal business practices?
Q. Right.
A. Either they don't show up at the airport, or somebody calls in and tells us to cancel the
reservation.
Q. Are you also -- are you given any information from the airlines themselves that reflects
whether the person was on the flight or not?
A. No -- yes. For e-tickets, the person has to pick up the e-ticket.
Q. And if they don't, then you're notified?
A. Then we're notified.
Q. And -4 A. To the best of my knowledge.
Q. And the particular stamp Void that's on the ticket agent -- or the agent coupon, on
this one for Mr. LaPerruque, is that placed on there by your staff in the regular course of
your business in the performance of their responsibilit ies?
A. Yes. Yes.
Q. Is this document used to adjust any billings that may have occurred where a ticket
wouldn't be used?
A. Certainly.
Q. Let's go back to the document you have in front of you, which is 853, okay?
A. Uh-huh.
Q. So we're all on the same page. 853 is a billing for four tickets in the total amount of
what?
A. $6,644.
Q. And if this ticket -- if this particular ticket to Mr. LaPerruque isn't used, then you have
to adjust your billings accordingly; is that correct?
A. Yes.
Q. All right. Let's go to the next one. The next agent coupon involves an individual by the
name of Marie Cascio. Do you see that?
A. Yes.
Q. And on the exhibit that you have in front of you, the itinerary invoice, does the name
Marie Cascio appear?
A. Yes.
Q. And is the ticket number assigned to her on the exhibit number of the first age, 853,
the same as the ticket number on the agent coupon that the jury's looking at?
A. Yes.
Q. And again, this one is stamped with Void, correct?
A. Correct.
Q. Meaning she did not take the trip?
A. She did not make that trip.
Q. All right. Let's put up the last one. The last agent coupon associated with the invoice
853 is an Aldo Cascio, correct?
A. Yes.
Q. Does the ticket number on this particular document, the agent coupon, match up with
the ticket number on the first page of 853?
A. Yes.
Q. And again, this one is stamped with Void, correct?

A. Yes.
Q. Indicating the person did not make the flight?
A. Yes. MR. SNEDDON: I think we can have the lights, Your Honor. Thank you. I have two
more documents, Your Honor, that I'd like to have marked for identification. 854 and 855
for identification purposes. I'm showing themto counsel. He's seen them. THE COURT: All
right.
Q. BY MR. SNEDDON: All right. Mr. Dietz, I'm going to take this back so we don't lose it.
You can swing around there. I'm going to show you a document that -- it's actually a
three-page document, front, back and then front, entitled, Client Summary, and ask you
to look at that document. Do you recognize that document?
A. Yes, I do.
Q. And does that document for the time period of - may I have it back just a second, just
to make sure I've got this right? - February 5th, 2003, through February 12th, 2003,
reflect the summary of the transactions that -- and services provided by your company to
MJJ Productions?
A. Not this in front of us. This is only two pages.
Q. No, the back page. MR. SANGER: I'm sorry, I can't hear the witness. MR. SNEDDON:
He said -Q. Lean into it and say what you said.
A. I'm sorry, I thought we did more transactions than this in that time frame. There must
be another client summary.
Q. This is only for the 5th to the 12th.
A. Okay. MR. SANGER: Objection. Leading and argumentative. THE COURT: Overruled.
Q. BY MR. SNEDDON: Go ahead and take the paper clip off and look at all three pages.
Have you looked at all three pages?
A. Yes.
Q. Okay. You -A. But they only reflect activity through February 12th, when this is for February 1st
through March 31st.
Q. Okay. But the caption at the right is -- has a larger period, correct?
A. That's right.
Q. All right. Now, I want to show you -A. And there's transactions that you've shown me that are clearly not on here.
Q. Now I want to show you Exhibit 855.
A. Okay.
Q. And take the clip off and look at them front and back, if you would.
A. Okay. Okay.
Q. You've seen those documents before, correct?
A. Yes.
Q. You saw them last night?
A. Correct.
Q. Are those the other transactions that you had in mind between this time period in
question?
A. Yes. MR. SANGER: Objection; calls for hearsay. THE COURT: Overruled.
Q. BY MR. SNEDDON: And this particular document, which is 13 pages in length, covers
the period 2-12-03 -A. Uh-huh.
Q. -- correct? And ends at the end of March of 2003, correct?

A. Uh-huh. Yes.
Q. Now -- all right. Why don't you keep these for just a second. All right. Now, Mr. Dietz,
with regard to the Exhibit 854, does that have an account number on it?
A. 854. Yes, it does.
Q. What's the account number?
A. 1359.
Q. What's the customer?
A. MJJ Productions, Inc. 8082
Q. You're going to have to lean into the mike.
A. MJJ Productions, Inc.
Q. All right. Now, let's look at Exhibit 855, if we can.
A. Okay.
Q. What's the billing account on that particular series of transactions?
A. MJJ Productions, Inc.
Q. That's the customer?
A. That's the customer.
Q. What's the account number?
A. 1656.
Q. It's a different account from the other -- from Exhibit 854, correct?
A. That's correct.
Q. Now, with regard to the information that is reflected in those client summary forms okay? - the information reflected in those, is that information that you keep in the normal
course of your business? MR. SANGER: I'm going to object, Your Honor. There's a lack of
foundation as to who prepared these and where they came from. MR. SNEDDON: W ell,
that's what I'm trying to do. THE COURT: The objection is overruled. You may answer.
Q. BY MR. SNEDDON: Is the informat ion 8083 contained in these documents, Client
Summary, information that you utilized in your business to bill clients and to keep a
history on the services you provide to those clients?
A. Is the information?
Q. Yes.
A. Yes, the information is.
Q. And then that information, in this particular case with regard to MJJ Productions'
accounts during this time period, was put into this format, correct? MR. SANGER:
Objection; lack of foundation. THE COURT: I don't know what the question -- really what
you're asking him. Maybe you do, but I don't. MR. SNEDDON: If you don't, the jury
doesn't, so I better start over again.
Q. The documents that you have, let's start with them individually. 854, the Client
Summary for 854, okay?
A. Yes.
Q. All right. Did your -- did your business prepare those documents?
A. Yes.
Q. And -- you have to lean into the microphone.
A. Yes.
Q. And did your business -- did the information contained on the document, 854, come
from business entries of documents that you maintained in the regular course of your
business, information that you maintained?
A. Yes. It's a computer-generated report. It's something we made up. It's something that
the computer generates based on the subpoena we received, which was to give us all the

transactions that occurred between February 1st and March 31st.

Q. And between the documents 8 -- in 855, the document 855, look at that. That's a
Client Summary?
A. Uh-huh.
Q. Is that the same -- would you make the same statement with regard to that document?
It's information generated from your computers?
A. That's correct.
Q. And -A. For the purposes of the subpoena.
Q. Correct. Now, with regard to those particular documents, do they cover the
transactions that are reflected in the Exhibits 223 through 249?
A. I haven't had time to do that, but I would assume they do.
Q. Well, yesterday -- MR. SANGER: Excuse me. Move to strike as speculation. THE
COURT: Sustained. Stricken.
Q. BY MR. SNEDDON: Yesterday, you were asked to look at those Client Summary forms
and compare them with certain transactions to confirm whether or not particular invoices
were sent in certain amounts for certain flights, correct? MR. SANGER: Objection; leading.
THE COURT: Overruled. THE WITNESS: Can you say that again? THE COURT: I can have it
read back to you. Just a moment. (Record read.) THE WITNESS: Yes, we briefly looked at
this Client Summary for a few -- for a few -- I would say for less than 30 seconds. And I
referred -- I actually remember going back to it once or twice with respect to one or two
invoices on it.
Q. BY MR. SNEDDON: Right.
A. Rather than every one on them. So I couldn't attest to every one. In general -Q. We discussed in general -A. We discussed the ones you've already brought up.
Q. Let's just establish that, okay?
A. Okay. MR. SANGER: I want to move -- Mr. Sneddon's comments about what he
discussed, move to strike those. MR. SNEDDON: I don't have a problem with that, Judge.
I'll just ask the question. THE COURT: All right. Go ahead.
Q. BY MR. SNEDDON: Mr. Dietz, with regard to the Documents 854 and 855 -A. Yes.
Q. -- yesterday you and I discussed how those documents were prepared, correct?
A. Yes. MR. SANGER: Objection; leading. THE W ITNESS: Yes. THE COURT: Overruled. The
answer is, Yes. Next question.
Q. BY MR. SNEDDON: And then I asked you to take those documents and look at a
couple of specific flights, did I not?
A. Yes. MR. SANGER: Objection. Leading, Your Honor. THE COURT: Overruled.
Q. BY MR. SNEDDON: Now, with regard to the transaction reflected in the Document 853
-A. Okay.
Q. -- all right? - were you asked to look at your Client Summary form to determine
whether or not the invoice reflects a charge of 6,000 -- whatever it is, $6,600 for those
four people, or whether it reflects a flight of one person?
A. It reflects -- I believe it reflects the price of one person. MR. SANGER: I'm going to
move to strike that answer on the grounds that it's based on hearsay. And there's no
foundation. MR. SNEDDON: Your Honor, I think he's -- the records are before the Court,
and he's simply using this to verify the authenticity of those records. MR. SANGER:

Objection to speaking responses. MR. SNEDDON: Well -- THE COURT: Well, it seems to
me you haven't offered them as business records. MR. SNEDDON: I was getting there. I
was trying to lay the foundation for that, as to the relevancy first, and then I was going to
go into that. Perhaps if you -- THE COURT: I think if you go to the business record
foundation first, and then they're either admitted or not admitted, then you're -- if they're
admitted, then you can question him in the way you're questioning him. MR. SNEDDON:
All right. THE COURT: And I know I might be not quite understanding still the record that
he's looking at. MR. SNEDDON: Let me ask one other question. It might help the Court
guide us through this. THE COURT: All right. MR. SNEDDON: Make it a little clearer. 8088
Q. Mr. Dietz, you're going to have to lean into the microphone there, okay?
A. Uh-huh.
Q. Mr. Dietz, with regard to the Exhibit 853 - okay? - that's the one that has the void
tickets on it.
A. Yes.
Q. -- does your business maintain information that would reflect the adjustment as to
whether or not the original invoice is sent to your client for payment or some subsequent
amount is sent to reflect the voids?
A. The original invo ice may have definitely been mailed out. Actually, no, I know that it
was not mailed out. It was adjusted to reflect that one passenger -- that only one e-ticket
was issued.
Q. Now, going to the Client Summary form, okay?
A. Yes.
Q. Do the Client Summary forms contain information maintained by your business in the
normal course of business to reflect the transactions that occurred on the exhibits that I
showed you, 223 to 249?
A. Yes.
Q. And that information is kept in the normal course of your business, correct?
A. The information on that summary is.
Q. Yes.
A. Yes.
Q. And with regard to the mode and time of the preparation of that information as it's
placed into your computer, it's made at or about the time of the transactions; is that
correct? MR. SANGER: Objection. That -- there's a lack of foundation. That's the
connection. Lack of foundation. THE COURT: Overruled. You may answer. THE W ITNESS:
Can you repeat the question? THE COURT: Yes. (Record read.) THE WITNESS: Yes and
no.
Q. BY MR. SNEDDON: Yes and what?
A. Reservations can be made. It's only -- an invoice is generated only when the
reservation is turned into a ticket.
Q. Right. And that's what we're talking about here.
A. Okay. MR. SANGER: Objection. Move to strike counsel's comment. MR. SNEDDON: W ell
-- THE COURT: Overruled. Go ahead.
Q. BY MR. SNEDDON: Just so there will be no question about it, the exhibits we're
talking about, except for the one exhibit, 223, all reflect transactions that occurred,
correct, tickets were issued?
A. Except for -- MR. SANGER: I'm sorry, I have to object. What exhibits are we talking
about, except for 223? Vague. MR. SNEDDON: I'll clarify it.
Q. I asked you to look at the documents 223 through 249, and then I asked you to look at

852 and 853, correct?

A. Yes.
Q. All right. Are those all transactions that occurred between you, Air Apparent, your
company, and MJJ Productions?
A. Yes.
Q. And with regard to the information contained on those transactions, is that the
informat ion that's downloaded to your computers?
A. Yes.
Q. And you use that for your business purposes?
A. Yes.
Q. And with regard to the exhibits, now getting back to 854 and 855 - all right? -A. Yeah.
Q. -- they contain a client summary - correct? -A. Yeah.
Q. -- of all of those transactions from information that was loaded into your computers at
or about the time of the transactions?
A. Correct. MR. SNEDDON: All right. I move they be admitted. MR. SANGER: And I would
object. MR. SNEDDON: Let me ask one more question. I want to ask one more question,
and this may take care of it.
Q. With regard to the Client Summary form - okay? - and the information that's on that
form - okay? - does that information -- from that information, are you able, in the due
course of your business, to be able to provide invoices to clients to be paid that may be
different than the original invoices that were sent out?
A. Yes. MR. SNEDDON: All right. Now I move they -- THE WITNESS: But not in that form.
Q. BY MR. SNEDDON: I understand that. But that's what the information is used for,
correct, the information that's in your computer?
A. Yes. MR. SANGER: I'm going to object. It's leading; argumentative; statements of
counsel. THE COURT: Overruled.
Q. BY MR. SNEDDON: I think the point you're trying to make -- and I think you made it,
but let's
28 just make sure that the jury understands. What you're -- MR. SANGER: Move to strike
comments of counsel, Your Honor. THE COURT: Sustained.
Q. BY MR. SNEDDON: The Client Summary form was a form that was produced specifically
to respond to the search warrant, correct?
A. Yes.
Q. That form itself is not something that you use ordinarily, correct?
A. Yes.
Q. All right. But the information on the form is all information that you house at your place
of business to conduct business, correct? It was just downloaded into a different format?
A. I -- yes. MR. SANGER: Objection. Well -- I was going to object, compound. THE
COURT: Sustained. MR. SNEDDON: All right. We'll break it up.
Q. Is it information that you maintain at your place of business to conduct business?
A. Is what, the -Q. The information on those forms.
A. Yes.
Q. Is that input into your computer?
A. Yes.
Q. All right. And is that information --

A. That's the output. That is the output from input.

Q. Well, let's go back. It's a matter of semantics.
A. Okay.
Q. The information on the form is the output?
A. Correct.
Q. The information that went into the computer is the input?
A. Correct.
Q. The information that's input is information that you keep in the normal course of your
business?
A. Yes.
Q. It happened to be output into this format for this trial?
A. Yes.
Q. But reflects information that you keep?
A. Yes. MR. SNEDDON: All right. Now I move that they be admitted. MR. SANGER: And I
object and request either to have an opportunity to voir dire or ask the Court to reserve
ruling until cross. THE COURT: Well, I think he needs to ask him some questions about
this, so I'll let you voir dire now, rather than wait. I don't think that's productive. MR.
SANGER: That's fine. That's why I 8094 offered. Thank you.
VOIR DIRE EXAMINATION BY MR. SANGER:
Q. Mr. Dietz, how are you doing?
A. Good. How are you doing?
Q. I'm doing fine, thank you. On 854 and 855, it's my understanding that you had not
seen those document before they were shown to you by the District Attorney; is that
correct?
A. Um, before last evening?
Q. Yes.
A. I might have looked at them in preparat ion for coming up here.
Q. You're not sure?
A. I'm not sure.
Q. And those are not documents that you downloaded from your computer; is that
correct?
A. I don't believe I downloaded them. I believe one of my accounting staff did.
Q. Okay. So you're assuming that that was something somebody on your accounting staff
did; is that correct?
A. I'm pretty certain that it's something that somebody did on my accounting staff.
Q. You have not had an opportunity to verify whether or not the billing amounts, the
invoice amounts to the particular client, are accurate in each regard on those two exhibits;
is that correct, sir?
A. Do you mean the invo ices to the statement?
Q. Yes. In other words -A. To the Client Summary that's been presented?
Q. Let me withdraw it. Your question indicates that my question was not clear.
A. All right.
Q. On 854 and 855 -A. Yeah.
Q. -- these client billing summaries --

A. Yeah.
Q. -- they show invoice amounts to the client, correct?
A. Correct.
Q. You have not had an opportunity to determine whether or not the invoice amounts
shown on those documents are accurate in each case; is that correct?
A. Not in each case.
Q. And these documents, as far as you knew, were prepared for the purposes of this
litigat ion; is that right?
A. Yes. MR. SANGER: I have no further questions on voir dire, and I object. THE COURT:
Does that material on the printouts on 854, 855, is that a compilation of the material
that's in your computer on this particular account? THE WITNESS: Yes. THE COURT: All
right. Your objection is overruled. They're admitted as a compilation. But after that -- MR.
SNEDDON: I should have let you ask the questions, Your Honor. We'd be way ahead of
the game. THE COURT: Well, I've just got to start this break early. That was so painful.
(Laughter.) (Recess taken.) THE COURT: All right. Mr. Sneddon, go ahead.
Q. BY MR. SNEDDON: Mr. Dietz, I p laced in front of you the document that's in evidence.
That's 853, all right? And does that document have or bear an invoice nu mber?
A. Yes, it does.
Q. What is that invoice number?
A. 0143505.
Q. And the amount of money that's indicated on that invoice number is what?
A. $6,644.
Q. For four tickets?
A. Correct. MR. SNEDDON: I'm going to place on the Elmo, Your Honor, if I might have it
for just a moment, page six of Exhibit 855. No, the other one. Back. Back. There. All
right.
Q. The information contained on page six of Exhibit 855 has the date in the far left-hand
corner; is that correct?
A. Correct.
Q. And moving down the date to March 1st, 2003, in the second column over, what does
the number 143505 refer to?
A. The invoice number.
Q. And with regard -- MR. SANGER: Excuse me.
Q. BY MR. SNEDDON: -- to the far right-hand side of the exhibit at the top, it bears the
word fare, correct, f-a-r-e?
A. Yes.
Q. And with regard to the flight on Invoice No. 143505, you billed $1,661, correct?
A. Yes.
Q. Is the invoice number and trip reflected on page six of the Exhibit 855 the same trip
that's represented by the invoice number on 853?
A. You got me there. Where is 855?
Q. 853, the one in your hands. 855 is the one on the board.
A. Okay.
Q. Is that the same trip?
A. That is the same trip, but the invoice was -- the ticket was issued the weekend. It was
changed over the weekend, or reservations were cancelled. Flights were issued, e-tickets
were issued. Three of the passengers did not travel -Q. So this --

A. -- on this itinerary.
Q. Okay. So 855 reflects the fact that only one person traveled on that itinerary that's
been marked as 853 that's in your hand, correct?
A. Correct.
Q. I couldn't hear you.
A. Correct. MR. SNEDDON: All right. No further questions. MR. SANGER: Can I have the
exhibits, please? MR. SNEDDON: I was going to put them back together again. If you
want to have them, here. MR. SANGER: Why don't we keep them out for now, please. MR.
SNEDDON: The rest of them are up there. MR. SANGER: May I approach to retrieve the
exhibits? THE COURT: Yes. MR. SANGER: I'm just a little concerned, Your Honor. Mr.
Sneddon said he was going to put them back together, so I think I will give them to Mr.
Sneddon so they get in the right position there. MR. SNEDDON: They're all in order except
for the one that was taken away from me. MR. SANGER: All right. There it is.
CROSS-EXAMINATION BY MR. SANGER:
Q. All right. First of all, on -- with regard to these summaries you just saw up on the
board, particularly you took a look at one of the pages, I think it was page six, and it
showed the amount that was billed, and it showed it was billed for one person to travel,
right?
A. Yes.
Q. Say a word so the court reporter can get it down.
A. Sorry.
Q. That's okay. You are assuming that that record was accurately placed into the
computer database by whoever entered these things; is that correct?
A. Correct.
Q. All right. And you noted from the other actual tickets that it appeared that three of the
tickets, the ones for the Cascios, I believe, were voided?
A. Yes.
Q. Okay. There was the Cascios and LaPerruque, correct?
A. Yes.
Q. They were vo ided. You look at that, and you pretty much figure, well, as far as your
company was concerned, the person that traveled on that particular day was Mr.
Jackson?
A. I would not necessarily assume that.
Q. Okay. I was going to ask you how you would come to that conclusion. So you're saying
you don't know that?
A. Correct.
Q. All right. Now, I want to show you -- you have the book in front of you there -A. Yeah.
Q. -- with the exhibits in the 200 series. And I'd ask you to turn to Exhibit 223, and I
believe that that is a two-page exhibit; is that correct?
A. Yes, it is. MR. SANGER: All right. And, Your Honor, with the Court's permission, I wou ld
like to put the copy I was given of those two pages up on the -- on the board, if I may.
THE COURT: Okay. MR. SANGER: Or up on the machine.
Q. And I'm going to show you the first page of exhibit -- the 223. And that's already been
up there before, but I'll ask you to look at that again. And this appears to be an itinerary
that was generated somehow, correct?

A. Yes.
Q. That's not your usual format for itineraries that are generated, is it?
A. For itineraries, I believe it is.
Q. Okay. All the other itineraries that you have shown for Exhibits 224 through 249 are
generated on letterhead, with a different font, in a different format; isn't that correct?
A. Yes, they're associated with an invoice.
Q. All right. Now, this particular one was not associated with an invoice because it was not
sent -- an invoice was not sent for payment on this flight; is that correct?
A. I cannot tell from what I see here.
Q. All right. Do you know whether or not that flight took place?
A. I do not know.
Q. All right. And ordinarily when flights are booked through your agency by MJJ
Productions, who is it that contacts you to book the flights?
A. Evvy.
Q. All right. And I'll tell you what. I'm going to ask you to just turn around and look this
way, and I'll d irect your attention to the board in a second when we put the next one up,
but it's hard for everybody to hear you.
A. Okay.
Q. So Evvy Tavasci is ordinarily the person who would be contacting your agency,
correct?
A. Yes.
Q. All right. And she contacts your agency not just for Mr. Jackson's travel arrangements,
but for other employees of MJJ Productions, correct?
A. Definitely.
Q. Okay. And to your knowledge, if some other employee of MJJ Productions needs to
travel for some business-related purpose, they would contact her, and she would in turn
contact you; is that correct?
A. Yes.
Q. When you make a flight arrangement for Evvy Tavasci, or at her -- at her request, do
you fax a confirmation?
A. I'm not sure. I don't know our daily practices.
Q. You're not the person that actually does it?
A. Not at all.
Q. You just own the place?
A. Yes.
Q. There you go. All right. Well, let me show you this anyway and see if this is -- this is
the second page I'm going to put up of this exhibit, and I'd like you to read the top -- no,
I'm kidding. (Laughter.)
Q. BY MR. SANGER: I'd like you just to look down at the bottom there. There's a TX Result
Report.
A. Yes.
Q. Is that a fax report?
A. Yes, it is.
Q. Now, I am going to focus in on that a little bit more here. Give you a fair chance. Do
you recognize the telephone or the fax number that that was sent to as being a fax
number associated with anybody?
A. I do not.
Q. Okay. And it appears that this fax -- just go a little wider there. The result on the right

is that it did not go through. It's NG, correct?

A. That's what it looks like to me.
Q. And it says, Redial, all failed, right?
A. That's what it looks like to me.
Q. Now, your business has regular commun icat ions -- during this period of time, your
business had regular communications with Evvy Tavasci, correct?
A. Yes.
Q. And you had a good fax number for her, correct?
A. Yes.
Q. Is there any ind ication in these two documents -- and you can actually look at the
documents in front of you, since I just have a copy here.
A. Okay.
Q. If you look at these two documents that are marked as 223, is there any way to
determine the time of day on February 5th that these tickets were requested?
A. Requested?
Q. Yes.
A. No. Prior to 11:31.
Q. You know it's prior to 11:31, because that's when the fax first was attempted, the fax
that didn't work, correct?
A. That's correct.
Q. And ordinarily, your people would be pretty prompt if they were setting up a ticket for
the same day. And I believe this is a ticket for the same day, right? You can take a look at
your -A. Yes, it looks like that way. Yes, for a flight at two o'clock in the afternoon.
Q. The flight was to depart at two o'clock in the afternoon of February the 5th?
A. Correct.
Q. So if somebody were doing this and faxing it out at 11:51 in the morning, they
probably had made the arrangements very shortly before that; is that correct?
A. That is correct.
Q. All right. Now, the fact that on the top of -- you keep looking at what you're looking at
there.
A. They didn't necessarily make the reservation at the time they called it in. I mean, on
this day. They could have -- they could have made the reservation prior to this date.
Q. Okay.
A. If that's the question.
Q. Well, that's fair enough. You look -- well, you're looking at your copy there. You're on
the first page?
A. Uh-huh.
Q. And at the top -- at the top there, it says, To MJJ Productions, and Attention: Evvy,
Personal and Confidential?
A. Uh-huh.
Q. Does that mean that Evvy was actually the person that called this in?
A. Not necessarily.
Q. Somebody could have called it in and then you would be dealing with Evvy Tavasci at
MJJ Productions, correct?
A. Yes.
Q. So, in essence, from the records that you have before you, you do not have any idea
who called in this request for tickets?

A. Let me clarify. Most of the tickets, to my knowledge, were ordered or confirmed by

Evvy.
Q. I understand.
A. Some of them were called in by other employees of MJJ Productions.
Q. Okay.
A. But nothing was done without, typically, getting Evvy's authorization.
Q. So theoretically, before this flight -- before the tickets would actually issue on this
flight, you would need to have Evvy's confirmation, correct?
A. Typically, yes.
Q. Maybe Narcisse, who also worked there, correct?
A. I'm not sure if Narcisse is on the -- she definitely is calling some things in. I'm not sure
if she's a part of the approval process.
Q. But going back to my question originally, here, you cannot tell who actually called this
in. In other words, somebody else -- somebody else entirely different could have called..
MR. SNEDDON: I'm going to object. Calls for speculation, Your Honor. THE COURT:
Overruled. THE WITNESS: I cannot tell who called this in.
Q. BY MR. SANGER: All right. And then if you look at the air fare there, that's economy air
fare, $1,180.50 per person, right?
A. Yes.
Q. Does that tend to indicate to you that this was a flight that was scheduled at the last
minute?
A. I -- I can't speculate on that. I think it was -- I mean, my gut feeling is yes, but -Q. All right.
A. I don't know if it was called in last minute.
Q. Okay. I'm going to take that down for a moment.
A. You know, it might have been contemporaneously, only because ticket fares are good
for only, you know, for a 24-hour period per se. So the fare is only good for -- for a
certain time frame, and then it will move on. So -Q. Now, you testified to some other documents as to who might have been -- I'm sorry,
you testified to other documents as to whose names were on particular tickets or potential
tickets. You do not actually know who flew on a particular day; is that correct?
A. I do not.
Q. And, of course, if you -- if somebody booked flights independent of your agency, you
would not know about those flights; is that correct?
A. That is correct. 8108 MR. SANGER: Okay. I have no further questions. And I have the
exhibits that were handed to me. I'm just going to leave them here.
REDIRECT EXAMINATION BY MR. SNEDDON:
Q. Mr. Dietz, are you familiar with the regulat ions that were put in place as a result of
9/11?
A. Yes.
Q. And given the regulations that are in place as a result of 9/11, in your opinion, based
uponyour experience in the travel industry, that another person cannot travel on a ticket - that a person cannot travel on a ticket not issued to them without proof of
identification?
A. That's my understanding. MR. SNEDDON: Nothing further. MR. SANGER: No furr
questions. THE COURT: Thank you. You may step down.

JEFFREY SCHWARTZ EXAMINATION

DIRECT EXAMINATION BY MR. NICOLA:

Q. Would you tell the jury, please, who you're employed with?
A. My employer is Talk America.
Q. And what is Talk America?
A. We're a C-lite local and long-distance Internet telephone provider.
Q. Are you here to testify today as their custodian of records?
A. I am. MR. NICOLA: May I approach the witness, Your Honor? THE COURT: Yes.
Q. BY MR. NICOLA: I've placed in front of you Exhibit 458, and I ask you if you
recognize that document, and if you do, what is it, please?
A. I do. It's subscriber informat ion from a customer of Talk America, Jay Jackson.
Q. And does that Exhibit 458 also contain toll records for the period of January, February
and March of the year 2003?
A. It does.
Q. Is the information contained within that exhibit material that is generated within the
regular course and scope of the business of Talk America?
A. It is.
Q. Okay. And is the material that is in there, the information that is in that exhibit,
collected at or near the time of the ind ividual toll calls?
A. Yes, it is.
Q. And is it relied upon to conduct the business of Talk America?
A. Yes, it is. MR. NICOLA: Your Honor, we would offer 458 into evidence at this time. MR.
SANGER: I just have a technical question. There's a different 458 that we were provided.
Has that been withdrawn or -- MR. NICOLA: That was never identified. MR. SANGER:
Never provided to the Court? MR. NICOLA: No. MR. SANGER: Oh, okay. I'm just now
informed by counsel that what was provided to us was not provided to the Court or
marked. So.... MR. NICOLA: W e used a different exhibit number for this. MR. SANGER: So
based on that, I have no objection. THE COURT: It's admitted. MR. NICOLA: Thank you,
Your Honor. May I please have Input No. 4, Your Honor?
Q. Mr. Schwartz, I would just like to go to the first page of the toll records of that exhibit.
I'm going to project a few items up onto the screen, and if you could please explain them
to the jury once they're up there, okay?
A. Okay.
Q. Let's begin with the headings in the columns entitled A, B, C, D, et cetera. And I'm just
going to point with the laser. If you can speak next to that second mike, please, it would
be more convenient for you, and everyone will be ab le to hear you. Could you tell the jury
what's in this section, the first line, Section A, please?
A. That's a number where the call would orig inate from.
Q. Is that the number that corresponds to the subscriber?
A. Yes, it does.
Q. The customer?
A. Yes, that's correct.
Q. Okay. And is that a mobile phone number or is that a landline?
A. That's a landline.

Q. Do you provide local service for that, or did you during the time period in question?
A. We did not.
Q. Okay. What kind of service d id you provide to that particular land line?
A. We provided LD service only.
Q. And LD, for those of us who don't know?
A. Long distance.
Q. Long-distance service. What's in Column B?
A. Column B is where the call would have terminated.
Q. What does that mean?
A. That means where the receiver would have been picked up on the other end.
Q. The number that was dialed by the person at the 9279 number?
A. That's correct.
Q. Okay. Column C, is that the date of the call?
A. The date and the time.
Q. Do you know whether the time stamp is based on a particular time zone?
A. It is on the time zone where the call originated from.
Q. So if the phone number is registered in Los Angeles, it's going to be in Pacific Coast
time, correct?
A. Correct.
Q. The next column seems to indicate a place.
A. That is the origination column date.
Q. Okay.
A. That is the origination which corresponds to the Column A.
Q. Column E appears to be the state, obviously, correct?
A. Correct.
Q. Correct?
A. Correct, I'm sorry.
Q. And of course there's Column H and Column I. What is Column H, please?
A. Column H is actually the duration of the call, from the time the call is received until the
call was terminated.
Q. So that's the actual time that the call lasted?
A. Correct.
Q. And what is this over here, Column I?
A. That would be the time that the call was billed for.
Q. Okay. For example, in this column, H, on the second line, a 34-second call results in
one minute worth of billing?
A. Correct. That is correct. Common practice in the telecommunicat ions industry.
Q. We've heard that, yes. I'd like to direct your attention, please, to the middle of this
chart, if I may. Beginn ing with the entry on line 25 -A. Okay.
Q. -- this would be the calling number, Mr. Jackson, correct?
A. That would be the origination of the call for Mr. Jackson, correct.
Q. And this number here, (201) 213-0763, is the number that was placed -- or dialed by
whoever was using this phone?
A. Placed and terminated at that number, correct.
Q. Okay. And does this call on Item No. 24 -- excuse me, Item No. 25 indicate the call
was a completed call?
A. Yes.

Q. How can you tell that?

A. By the duration of the call.
Q. Over here, the 6:32?
A. That's correct.
Q. Which on the bill appears to be what, seven minutes?
A. What line are we looking at? 25?
Q. Yes, right where the pointer is.
A. That's correct. Well, six minutes and 32 seconds. Billed for seven minutes.
Q. Okay. And that's how Cingular bought AT&T. Okay. Here we go. Line No. 27, same
number, to Morristown, New Jersey?
A. Correct.
Q. And that call lasted 15 seconds, correct?
A. Correct.
Q. Now, is that a completed call, if it lasts 15.3 seconds?
A. Yes. Any call -- I'm sorry.
Q. Explain that, please.
A. Well, any call that is entered into the record, if the call was not answered, if there was
not an answer on the telephone, there wouldn't be a record for the call because the call
would not have terminated. But once the call is received and answered, regard less of one
second or 20 seconds, or as far as ten minutes, there would be a record of the call.
Q. Okay. So does that mean that this call was either answered on the other end or it got
forwarded to voice mail or something like that?
A. Any one of those possibilities is possible, correct.
Q. Okay. And this 15 seconds also costs a minute, right?
A. That is correct also.
Q. Going down the list to Item No. 28 on the left, same number was dialed to Morristown,
New Jersey, at 11:53?
A. That's correct.
Q. Is this military time?
A. Yes.
Q. So the next call down here at 1320 hours, that's actually 1:20 p.m., correct?
A. That's also correct.
Q. And the 1:20 p.m. call lasted one minute and eight seconds?
A. And billed for two minutes, if that's what you're asking, yes. Yes, it did.
Q. This is my favorite one right here. The next call appears to be the same number, is that
correct, on line 30?
A. Yes. That's correct.
Q. And that call was placed at 1324, 1:24 in the afternoon, correct?
A. Yes, that's correct.
Q. To Morristown, New Jersey, for a period of 2.4 seconds?
A. That's correct.
Q. Immediately thereafter, at 1334 hours, that number was called again, correct?
A. That's correct.
Q. And that call lasted 3.1 seconds?
A. That's also correct.
Q. And in total, that was two minutes, in telephone company t ime, right?
A. That's also correct, yes.
Q. You can tell I enjoy this, huh? The remainder of these calls, at 1539 hours, Item 32,

Item 33 at 1407 hours, Item 34 at 2036 hours, Item 35 at 2043, and Item 36 at 2048,
were all to the same phone number in Morristown, New Jersey, right?
A. That is correct.
Q. And they were all co mpleted calls?
A. That is correct also.
Q. Now, I believe I misspoke and called 1359 1539. So Item 32 is actually a call p laced at
1359 or nearly two o'clock in the afternoon, right?
A. That's correct.
Q. Okay. Now, beginning with Item 36 -- 37, excuse me, on February 16th, 2003, at 4:07
in the afternoon, was a call p laced to a phone number in Wyckoff, New Jersey?
A. That's correct.
Q. And what does your record reflect that phone number to be?
A. (201) 847-7576. 8118
Q. Now, you have no way of knowing whether the receiving phone call -- excuse me, the
number dialed is a cellular phone or a land line, correct?
A. You could gather the information. I do not know. You could gather the information if
you had to gather it. You could do that.
Q. By some kind of a cell site?
A. Or a customer service record. You could request what we call a CSR, which would be
a Customer Service Record, for the receiving call.
Q. How long are those records kept?
A. I believe a record should be kept for eight years, is what a telephone record is required
to be kept, so -Q. Okay. Would the subscriber information on this end of the phone call also tell you
whether it's a cell phone or a land line?
A. Yes, it could.
Q. Okay. Now, beginning with Item 37, and continu ing down to Item 41, there appear to
be four -- four calls in a row between four o'clock in the afternoon and approximately
10:23 the following day, February 17th, to the same number in Wyckoff, New Jersey; is
that correct?
A. That's correct.
Q. And were those completed calls?
A. Yes, they were.
Q. Proceed ing to Item 42, was a different number called on February 17th of 2003 at
11:24 in the morning?
A. Yes. Different between 41 and 42 is what your -- is the question?
Q. Yes.
A. Yes, different.
Q. Is that the same phone number that was called on the 15th to Morristown, New
Jersey?
A. Yes, it is.
Q. Okay. And was that a completed phone call?
A. Yes.
Q. And how long did that one last?
A. Item 42?
Q. Yes, please.
A. It looks like 17 minutes and 39 seconds, billed for 18 minutes probably.
Q. There you go. Okay. And the item right below 42 is 43.

A. Right.
Q. Could you tell us about that phone call includ ing the location and duration, please?
A. It looks like it was 26 minutes and 15 seconds to Wyckoff, New Jersey. The (201) 8477576 number.
Q. Would you turn the page, please? Okay. I'm trying to get this up there. How about we
just do it verbally. Items 45 through 48 -- excuse me, 45 through 47, are they all
telephone calls placed from the Jackson residence, Jay Jackson residence, to the
telephone number in W yckoff, New Jersey?
A. Yes, they are.
Q. And were they all co mpleted phone calls?
A. Yes, they were.
Q. And did they occur between February 18th of 2003 and February 19th of 2003?
A. Yes, they did. MR. NICOLA: Your Honor, I have no further questions of this witness.
CROSS-EXAMINATION BY MR. SANGER:
Q. Mr. Schwartz, how are you?
A. Pretty well.
Q. Good. I think you need to kind of list more towards that microphone, if you could.
A. This one?
Q. Yes, please. The phone records that you just testified to are in the name of Jay
Jackson; is that correct?
A. Yes, that's correct.
Q. And there's a billing address in Los Angeles; is that correct?
A. That's correct.
Q. Is this a land-based landline phone or is this a mobile phone? 8121
A. It's a land-based phone.
Q. Is it your understanding this is a residence phone?
A. It is. Our company only provides LD service to residence phones. We don't provide any
type of cellular service.
Q. So this particular phone number -- let me see if I can put one of these up here. Your
Honor, with the Court's permission, I'll put up page -- I guess it's really just page one. I'll
put up my copy of page one and see if this looks like your copy of page one of Exhibit
458.
A. That is.
Q. All right. So you can look at yours, because it's a little hard to read.
A. Okay.
Q. But look up here first just so you can see what I'm pointing at. I'm going to point on
the screen at a phone number up there. Is that the phone number that is associated with
this account?
A. Yes, it is.
Q. And the account is for Jay Jackson, correct?
A. That's correct.
Q. Now, I'm going to ask you to tell us what the -- well, let me ask -- Your Honor, I need
to ask for the actual phone number. It's up there. Is that all right if I do that? I don't want
to -- THE COURT: Yes. It was the other information that we were concerned about, the
Social Security numbers, that kind of thing. MR. SANGER: That's fine. Thank you. I just
want to make sure.

Q. Can you read that phone number from the exhibit?

A. From your exhibit or my exhibit?
Q. You have the official exhibit. I'm putting up a copy.
A. All right. Yes, I can.
Q. Please read it.
A. (213) 739-9279.
Q. All right. Now, your phone company provided service, provided long-distance service to
that number; is that correct?
A. That's correct.
Q. Does that mean anytime that the phone was picked up and a call was made on that
telephone number ending in 9279, anytime the phone was picked up and a long-distance
call was made, it wou ld be automatically billed to your carrier?
A. That's correct.
Q. Is there a way to bill it to some other carrier?
A. No.
Q. All right. So I'm going to put up page two with the Court's permission. And if you can
look in the book there so you can actually read it. But I'll also help you to stay closer to
the microphone, because we have that microphone issue here. These records start when?
A. On page one is what we're talking about?
Q. Yeah. I mean the records you just -A. January 1 of .03.
Q. January 1 of .03. And these appear to be the comprehensive re cords for that period of
time; is that correct?
A. They are, correct.
Q. All right. Now, do you know what carrier this customer, Jay Jackson, had for his regular
telephone services?
A. It would -- probably -- I don't know specifically. It would probably be Pac-Bell.
Q. Pac-Bell. Okay. So if we had seen, for instance, on February 4th a Pac-Bell record
showing a call from this number to Reseda, two calls to Reseda on February 4th, they
were logged in on the Pac-Bell statement, those calls would not necessarily show up here;
is that right?
A. I'm not sure I understand your question.
Q. Well, let's do it this way. I'll just ask you to look at yours, because I can't read mine
from the thing there. If you look at the entries -- I'm going to put that page back up
again, Your Honor, if I may. Now that I've seen it, I'll do it this way here. I'll just try to
look at the particular entries here. If you look at the entries for -- starting at the top, it
starts with 1-1-03, correct?
A. Correct.
Q. And it goes through the month of January. There is a total of 11 calls through January,
correct? Well, no, I'm sorry, there's a total of nine calls. It starts on line 3 and goes to line
11, correct?
A. Right.
Q. And -A. 1-20-03 would be the last call in Janu ary.
Q. Okay. And then as far as your carrier is concerned, the next charge you have is on 2-403, correct?
A. To Newport News, Virginia.
Q. That is a call to Newport News, Virginia.

A. Talking about line 12, correct?

Q. Line 12, correct.
A. That's correct.
Q. And then on 2-5-03, there's a call to Naples, I suppose.
A. I'm sorry. Yeah. Naples, Florida, correct.
Q. All right. Now, I'm going to show you Exhibit 451, and I'm going to have to ask the
clerk for that, if I may, p lease. Should be a book. May I inquire of the government to see
if they have that book there, by any chance? We're looking for an Exhibit 451, which is the
Pac-Bell records. You don't have it there at the counsel table is what I was inquiring. MR.
NICOLA: I don't. It was released for us to redact per the Court's instruction. I didn't bring
it down with me. T HE COURT: She couldn't hear what you said. MR. NICOLA: I'm sorry,
Your Honor. I took that per the Court's instructions to redact. I haven't brought it back.
THE COURT: Try to blame it on me, will you? (Laughter.) THE COURT: That's the book you
have. MR. NICOLA: Yes. It's one of several. MR. SANGER: Okay. May I confer with
counsel, see if we can find a way around this? THE COURT: Yes. (Discussion held off the
record at counsel table.) MR. SANGER: Your Honor, with the stipulation of counsel, we'll
use my copy and the one that was provided to me of 451, Tab 6. It's already been
received into evidence. And that's what we'll use in a second, if I may. THE COURT: All
right. Good.
Q. BY MR. SANGER: Okay. Mr. Schwartz, let me ask you, how long have you worked in
the phone business?
A. Nine years.
Q. And are you familiar with phone billing records in general?
A. Yes, I am.
Q. And how many comp anies have you worked for in that period of time?
A. Just one.
Q. Which one is that?
A. Talk America.
Q. Has Talk America been in ex istence all that time?
A. Yes, that's correct.
Q. Oh, okay. All right. I'm going to show you a phone record that has been admitted into
evid ence, which is 451, Tab 6, and it's page three of Tab 6. And this was -- I think I can
say for your benefit, to orient you, this was provided by a Pac-Bell representative. And I'll
put that up if I may, Your Honor. THE COURT: Yes.
Q. BY MR. SANGER: Now, this is -- I'll let you take a look at that for a second and see if
you can orient yourself and get a feel for that. That is -A. It looks like a phone bill. 8127
Q. There you go. All right. And if you look in the upper left-hand corner, the indication is
that this phone bill pertains to this phone number, (213) 739-9279.
A. Okay.
Q. See that? Is that the phone number that's referred to on your Exhibit 458, the Talk
America exhib it that's in front of you?
A. It is.
Q. I think you have to lean into the microphone.
A. Yes, it is.
Q. Oh, that one works, too. All right. Okay. And I guess what I was referring to is there
are a couple of entries here for February the 4th at 6:11 p.m. and then 6:14 p.m., both
four-minute calls to a number apparently in Reseda, an (818) number. And my question

to you is, assuming this is the same telephone, why would there be two calls billed to
Pacific Bell on that date and another long-distance call to - where did we say? - Newport
News billed to Talk America on the same date?
A. Why would there be?
Q. Yeah.
A. So you're asking why a long-distance call would show up on a local phone bill?
Q. Yes.
A. I'm not familiar with the geography of
California, but Reseda may be within the latta, and it may not reflect as a long-distance
call.
Q. Could you turn around and talk into the mike there, please. You said -- I think
everybody heard, but you said within the latta?
A. Correct.
Q. And what is a latta? I'm afraid to ask.
A. For lack -- I guess to -- a layman term would be an area code or a geographic area in
which the phone call would be billed in, so -- do you want me to explain it or -Q. Go ahead.
A. A latta is the area where the phone call -- you'd be charged different rates when you
went across a latta. And once you cross a latta, it would be considered a long-distance
call.
Q. All right. So your local phone bill might have a call that crosses a latta but does not
invoke your carrier's business?
A. That's correct.
Q. All right. So if I then put 458 back up, and this is page two, the calls that we've just
referred to there are not inconsistent with your carrier provid ing service during that same
period of time; is that right?
A. No.
Q. Okay. Thank you. I just have a couple of more questions here. And let me look at this
first. Yes, all right. I'm going to put this up and we'll again try to orient ourselves. Okay.
You're welcome to look at the actual exhib it in front of you, but I'm going to refer to Line
17, 18, and 19 from February the 11th, 2003. Do you see those?
A. I do.
Q. Okay. And your bill would reflect only outgoing calls, I suppose, unless somebody
called collect, correct?
A. Outgoing only, that's correct.
Q. So it appears on February the 11th, 2003, there were three outgoing calls to Santa
Barbara; is that correct?
A. That's correct.
Q. And those three calls were at 2322 hours, which would be 22 minutes after eleven
o'clock at night, correct?
A. Correct.
Q. And the next -- that's to one number. And then the other two calls are to the same
number. I d idn't say that correctly. The first call is to a -- one number. And the second
two calls are to the same number?
A. The first one's to 2300, and the second two are
Q. And the second two were placed at 11:23 at 8130 night and 11:49 at night, correct?
A. Yes. MR. SANGER: Let me have just one more second, if I may, Your Honor, please. All
right. I have no further questions.

CRYSTALEE DANKO EXAMINATION

DIRECT EXAMINATION BY MR. NICOLA:
Q. I've placed in front of you Exhibit 454, correct?
A. That's correct.
Q. Do you recognize that exhibit?
A. Yes, I do.
Q. Have you had an opportunity to review it and its contents before you came to court
today?
A. Yes, I have.
Q. Can you tell the jury, please, what exhib it four fifty -A. Five.
Q. -- five is? Excuse me.
A. Yes, these are Sprint cell phone records and landline records, including subscriber
informat ion and billing information.
Q. And are the contents of Exhibit 455 those which are regu larly made in the course of
your business?
A. Yes, they are.
Q. Would you open up Exhibit 455 in the index, please?
A. Yes. (Off-the-record discussion held at counsel table.) MR. NICOLA: Okay. Just want to
make sure we're all on the same page.
Q. With respect to Exhibit 455, did you compare the contents of the table of contents with
the information contained in the corresponding tabs within the binder?
A. Yes, I have.
Q. Okay. MR. SANGER: We're not on the same page. We're not on the same page, I'm
sorry. There is no -- there's no -- there's no table of contents on this one. MR. NICOLA:
You can use mine. MR. SANGER: Okay. Thank you. Let's see what you did here. MR.
NICOLA: You ready? MR. SANGER: Excuse me just one second.
Q. BY MR. NICOLA: I'm sorry.
A. That's okay.
Q. With respect to the information contained in Tab No. 1, is that subscriber informat ion
for a firm listed in the table of contents?
A. Yes, it is.
Q. Okay. And are there telephone numbers that your records show connected with that
firm?
A. Yes.
Q. And are they also on the table of contents?
A. Yes, they are.
Q. Would you read those telephone numbers into the record, please?
A. (702) 362-5118; (702) 222-2500; (702) 365-6940.
Q. If you would turn to Tab 1 of your exhibit, and does the first page of the exhibit list the
same name that is under Subscriber Name in the table of contents?
A. Yes, it does.
Q. If you would turn to page two. And what is page two?
A. It is listing information, listing address and names for the information on the front
page.

Q. Do those names correspond to the 222-2500 number?

A. Yes, they do.
Q. And is one of those names a David LeGrand?
A. Yes, it is.
Q. Would you please turn the page and go to the page marked 3 of 11. Are you there?
A. Yes, I am.
Q. And on page 3 of 11 of what appears to be a February 21, 2003, phone bill, is there a
list of telephone numbers which include the 362-5118 and 365-6940 numbers listed in the
table of contents?
A. Yes.
Q. Okay. And do all those telephone numbers belong to the firm of Hale Lane Peek
Dennison and Howard?
A. Yes, they do.
Q. If you would turn to Tab 2, please. Now, does Tab 2 contain the subscriber informat ion
for a business entitled, Geragos & Geragos?
A. Yes, it does.
Q. And is there a telephone number on the table of contents which corresponds to the
number you have on record for Geragos & Geragos?
A. Yes.
Q. And what is that number?
A. (213) 864-2100.
Q. If you would turn to page two, the second page, do you find an additional number for
the business Geragos & Geragos?
A. Yes.
Q. And what is that number?
A. (213) 625-3900.
Q. Turning to Tab No. 3, does Tab No. 3 contain subscriber and billing information for one
Vincent Amen?
A. Yes, it does.
Q. Is there a cellular number associated with Mr. Amen in your subscriber records?
A. Yes.
Q. And what is that number, please?
A. (201) 838-4345.
Q. If you would turn, please, to Exhibit No. -- excuse me, Tab 4 in Exhibit 455. Do you
have in Tab 4 the subscriber information for one Frederic Marc Schaffel?
A. Yes, I do.
Q. And do the numbers in the table of contents correspond to the subscriber informat ion
in your Sprint records?
A. Yes, it does. 8135
Q. Is there an additional telephone number in your subscriber informat ion for Mr. Schaffel
that is not on the table of contents? If you would look at page one.
A. Yes, there is.
Q. And what is that number?
A. (818) 876-0029.
Q. And can you tell if that is a cellular number or a landline?
A. I cannot tell by these records.
Q. If you would turn briefly to Exhibit No. 5. Does Exhibit 5 contain the subscriber
informat ion for a Maria Farshchian?

A. Yes, it does.
Q. F-a-r-s-h-c-h-i-a-n?
A. Yes, it does.
Q. Okay. And does the Tab No. 5 also contain the toll records -- excuse me, the billing for
the period of January, February and March of 2003?
A. Yes, it does.
Q. Are the records contained within Exhibit 455 records which Sprint regularly relies upon
in the normal course and scope of their business?
A. Yes, they are. MR. NICOLA: Your Honor, we would offer 455 into evidence at this time,
please. MR. SANGER: On these, we have the objection of relevance as to, in particular,
some of the subscribers. It's the same objection that I made previously, that there's no
foundation to show relevance. And I think the Court -- THE COURT: I'll admit them,
subject, as I did the others, to the District Attorney tying up the relevance. MR. SANGER:
Thank you. MR. NICOLA: Thank you, Your Honor. Your Honor, may I publish? THE COURT:
Yes.
Q. BY MR. NICOLA: Mrs. Danko? It's Missus?
A. Yes.
Q. If you would please turn to the billing information for Fred Schaffel and find the page
that corresponds to February 7th of 2003, please.
A. Okay.
Q. Have you found it?
A. Yes.
Q. Okay. Does the billing for February 7th of 2003 begin on page eight of the February 21
bill?
A. Yes.
Q. Okay. I'd like to talk to you about a code on your bills which is denoted as CW.
A. Yes.
Q. Okay. On line -- excuse me. On Line No. 194, there's a CW next to the date and time
stamp of 10:17 a.m., entitled Incoming. Can you explain to us how an incoming call -what an incoming call on your system means, call waiting?
A. Yes. Our subscriber was on the phone. Either he had received an incoming call or he
had made an outgoing call. Either way, he was on a phone call. And during that phone
call, he received another call. And when he received that second call, he answered it. And
that's what indicates here, an incoming call. And a CW over there is what ind icates the
call waiting was used.
Q. Okay. Now, after he received, he or she -A. Or she.
Q. After the call came in at 10:17 a.m., can you tell whether or not your subscriber stayed
on the phone with the call immediately preceding?
A. For one minute or less.
Q. Okay. How can you tell that?
A. Our corporation bills in one-minute increments, and one minute is listed here next to
the call waiting ind icator.
Q. So this could have actually been a 2.4-second call?
A. Yes.
Q. My question, however, is, if the caller was on the phone to this number at 10:16 a.m.,
and it lasted for six minutes, did this call actually interrupt this call?
A. Yes, it does.

Q. Okay. So the Entry 193, did that continue after the entry on 194?
A. Yes, it did.
Q. If you could please turn to page nine, and I'd like you to begin at line 215. I'll project
that. There appears to be the same call -- excuse me, the same code here a number of
times. CW and CW ?
A. That's correct.
Q. There's also this code right here, what does that mean, the 3W ?
A. The 3W indicates that a three-way call was initiated.
Q. And how does that work on your system?
A. You would need to be on the phone call in the first place, just like the call wait ing
situation. In this situation, if you look at 2-7 at 3:13 p.m., there was an outgoing call. Our
subscriber had made an outgoing call and was on the phone for approximately 14
minutes. During that time frame, at 3:22, our subscriber called out and conferenced in
another number.
Q. Let me stop you for a minute. Where are you? Which line item?
A. I'm on line 230.
Q. Would you look at line -A. Sorry.
Q. -- 218? 8139
A. That's kind of hard for you to see. How about line 217?
Q. Okay. Explain how that came about.
A. Our customer had received a call, and inco ming call, at 3 -- at 1:13 p.m., and that
lasted for seven minutes. During that call, they mad e a call out, three-waying into the
(702) 222-2520 number.
Q. Okay. Would you expect, in a three-way call, that when the user of Mr. Schaffel's
phone dialed the 222-2520 number, that would show as an incoming call on their system,
if they record such things?
A. The receiver?
Q. Yes.
A. Yes. MR. NICOLA: Okay. I think I have no further questions. Thank you. THE COURT:
Counsel? MR. SANGER: No questions, Your Honor. THE COURT: Good. You may step
down.

JENNIFER SIMMONS EXAMINATION

DIRECT EXAMINATION BY MR. NICOLA:
Q. Good afternoon, Miss Simmons. I'd like to hand you Exhibit No. 450, and ask if you
recognize that, please.
A. Yes.
Q. What is it?
A. It's records of Nextel statements from Tavasci, Evvy; MJJ Productions.
Q. These are records of Nextel Phone Company?
A. Correct.
Q. Do you work for them?
A. Yes, I do.
Q. For how long?

A. Six years.
Q. And are you here today as their custodian of records?
A. Yes.
Q. He's going to adjust your microphone.
A. Oh.
Q. Are you familiar with the contents of Exhibit 450?
A. Yes.
Q. And is there a three-page table of contents?
A. Yes.
Q. Have you gone through the subscriber information, the corresponding telephone
numbers that are listed out in that table of contents?
A. Yes.
Q. And have you confirmed the accuracy of the entries on the table of contents?
A. Yes.
Q. With respect to Tab No. 1, does that contain account statements for the telephone
numbers (310) 901-7487 and (818) 402-7087 for the billing period of February of 2003?
A. Could you repeat the second number? The first one was correct.
Q. (818) -A. Uh-huh.
Q. -- 402-7087?
A. Yes.
Q. Okay. I have the same question about those two phone numbers in Tab No. 2, and I
ask if the contents of Tab No. 2 are the billing statements for the month of March for
those two numbers? 8142
A. Yes.
Q. And the same question with respect to those telephone numbers and the April billing
statement. Are those contained within Tab No. 3?
A. Yes.
Q. Is the bill address under Tab No. 1, 2 and 3 - you can look at Tab 1 first - Evelyn
Tavasci -A. Yes.
Q. -- MJJ Productions, P.O. Box 6034, Sherman Oaks, California?
A. Yes.
Q. Is that the same on exhibits -- excuse me, the bills on Tabs 1, 2 and 3?
A. Yes, they are.
Q. With respect to Tab No. 4, can you describe what is in that exhibit, please?
A. This is a subscriber history, a description of each unit. It will show the unit's phone
number; the user name of that unit that's listed in our bill; the radio I.D.; an IMSI I.D.,
which is for our network to identify each unit for billing purposes; a serial number, which
is a SIM identification, which tells what piece of equipment it is, as well as the effective
date of the activation, and if there was an expiration, meaning a cancellation of that unit,
if it cancelled. It also includes the account number for the bill, the billing name, and the
billing address.
Q. Are there a number of phones -- excuse me, phone numbers registered to an Evelyn
Tavasci -A. Yes.
Q. -- that are listed in the table of contents under Tab No. 4?
A. Yes.

Q. Did you confirm that each one of those telephone numbers corresponds to the
informat ion in Tab No. 4?
A. Yes.
Q. And with respect to the billing information, do all the bills appear to go to the address
at P.O. Box 6034 -A. Yes, they do.
Q. -- Sherman Oaks, California? Are some entitled, Ms. Evelyn Tavasci, Attention: MJJ
Productions?
A. Yes.
Q. And some are not, correct?
A. Correct.
Q. But they're all going to the P.O. Box at 6034?
A. Yes.
Q. I'd like you to turn, please, to Tab No. 5.
A. Actually, there is no Tab No. 5 in this one.
Q. Oh, I'm sorry.
A. That's all right.
Q. It's actually Tab No. 7. Does Tab No. 7 contain four additional phones registered to an
Evelyn Tavasci?
A. Yes.
Q. And are those phone numbers accurately printed on the table of contents on Exhibit
450?
A. Yes.
Q. Are the billing statements attached for the February billing cycle of the year 2003?
A. Yes.
Q. Okay. With respect to the final two tabs, No. 8 and No. 9, are the numbers listed in the
table of contents and registered to an Evelyn Tavasci contained within the Tabs 8 and 9
for the months of March and April of 2003?
A. For 8 and 9, yes.
Q. And you confirmed both of those -A. Yes.
Q. -- sections before you came to court?
A. Uh-huh.
Q. Now, with respect to the contents of Exhibit 450, are these all records which record the
informat ion contained at or near the time of each of the events recorded?
A. Yes. Yes.
Q. Nextel is just a wireless company, correct?
A. Correct.
Q. And none of these telephones are landlines?
A. Right, they are all wireless.
Q. Okay. And does Nextel rely on the informat ion contained within Exhibit 450 in the
regular course of their business?
A. Yes, they do. MR. NICOLA: We would offer Exhibit 450 into evidence. MR. SANGER: I
have the same objection. THE COURT: All right. They're admitted, subject to connection
later. MR. NICOLA: Thank you, Your Honor. I have no further questions. MR. SANGER: I
have no questions, Your Honor. THE COURT: Thank you. Call your next witness.

JOE J. CORRAL EXAMINATION

DIRECT EXAMINATION BY MR. NICOLA:
Q. I'd like to show you Exhibit 457 and Exhibit 459, please. Do you recognize Exhibit
457?
A. Yes, I do.
Q. And what is it, please?
A. It's telephone records that were subpoenaed from Verizon.
Q. Do you work for Verizon?
A. Yes, I do.
Q. For how long?
A. Approximately 27 years.
Q. And are you here to testify as Verizon's custodian of records with respect to the
California and I think it's New York records?
A. Yes, I am.
Q. And are the New York records kept in Exhibit 459?
A. Yes, they are.
Q. Okay. With respect to Exhibit 457, is there a table of contents with a number of entries
corresponding to tabs in the exhibit?
A. Yes, there is. MR. NICOLA: Would you give us just a moment. MR. SANGER: Just one
second, Your Honor, please. THE COURT: Why don't we take our break now. (Recess
taken.) THE COURT: Go ahead, Counsel. MR. NICOLA: Thank you, Your Honor.
Q. Mr. Corral, we just started talking about the two exhibits in front of you. Why don't we
start with the New York exhibit. Is that Exhibit 459?
A. Yes.
Q. And contained within that exhibit, is there subscriber information and toll records for
Franchesco Cascio?
A. Yes.
Q. Does he have a billing address in New Jersey?
A. Yes.
Q. Are the records contained in Exhibit 459 those kept within the normal course and scope
of the business of Verizon?
A. Yes, they are.
Q. And is the information contained within that exhibit gathered at or near the time of the
event?
A. Yes, they are.
Q. And does Verizon rely upon those records to conduct their business?
A. Yes, we do. MR. NICOLA: Your Honor, we would move 459 into evidence at this time.
MR. SANGER: Same objection. I take it same ruling. THE COURT: Same ruling, yeah. I'll
allow it with the proviso that it's connected up later.
Q. BY MR. NICOLA: If you would please turn to Exhibit 457. Are those the records for
Verizon California?
A. Yes, they are.
Q. And with respect to the ten numbers listed in the table of contents, are those
landlines?
A. Yes, they are.
Q. I didn't ask you, but is it a landline in Exhibit 459 as well?
A. Yes, it is.

Q. Okay. And listed within Exhibit 457, is there a table of contents that lists five sections
where the subscriber is the Neverland Ranch?
A. Yes.
Q. Have you examined the exhibit and all of its contents prior to your testimony today?
A. Yes, I have.
Q. And are the numbers listed for Neverland Ranch which are listed on the table of
contents - those telephone numbers appear on your records contained within Tabs 1, 2, 3,
4 and 6 - do those numbers correspond to the information contained within those tabs?
8149
A. Yes, they do.
Q. Do your records show that the numbers listed for Neverland Ranch were active during
the period of January through April of 2003 -- excuse me, through March of 2003?
A. Yes, they do.
Q. So those phone lines were active during that period of time?
A. Yes.
Q. If you would turn your attention, please, to the contents of Tab No. 5. Is that
subscriber and billing information for one Rudy Provencio?
A. I'm sorry? Could you repeat the question?
Q. Are the contents of Tab No. 5 the subscriber and billing informat ion for Rudy
Provencio?
A. Yes.
Q. And is the corresponding telephone number for him (301) 473-5702?
A. Yes, it is.
Q. Okay. I'm going to show you some records, if you could please turn to page 22. May I
publish, Your Honor? THE COURT: They're admitted, are they? Have these been -- MR.
NICOLA: Oh, I'm sorry. The rest of the foundation.
Q. Are the contents of Exhibit 457 records which are kept within the ordinary course and
scope of your business?
A. Yes, they are.
Q. And are the entries recorded at or near the times of the events recorded?
A. Yes.
Q. And are they records which Verizon regularly relies upon in the normal course of their
business?
A. Yes, they do. MR. NICOLA: We'd make our proffer at this time, Your Honor. THE
COURT: Are you asking that they be admitted? MR. NICOLA: May we admit 457 in
evid ence at this time, Your Honor? MR. SANGER: Same objection. THE COURT: All right.
Same ru ling. It's admitted.
Q. BY MR. NICOLA: If you could turn to Tab 4, page 22 at the bottom, if I could direct
your attention to this section of the phone bill. And maybe give us a little interpretation of
what all this means, this string of numbers and letters and numbers. Start right here
where it says, 0204, if you could.
A. Yes, it's a record of billable calls, and in this case, the first call on the very top shows
the date, which would be 0204, or February 4th. The call that was mad e to would be
Canoga Park - that's an abbreviat ion CANO - in California.
Q. Okay.
A. The time right after that is in military time, which would be 2234, which would convert
to 10:34 p.m.
Q. Okay.

A. The numbers after that would be the number that was called, which would be (818)
876-0029.
Q. Okay. Is there a header co lumn at the top of this? I'll focus on that so you can see that
one more clearly.
A. Yes. It basically states calls billed to (310) 473-5702.
Q. And that corresponds to the subscriber's phone number, correct?
A. Yes, it does.
Q. Now, this column up here that says Date, Call, et cetera, that corresponds with the
numbers down this -- these columns here?
A. Yes, they do.
Q. Okay. So when someone wants to read these records, if they want the phone number
dialed, they go to the end of this block and count backwards to get to the area code,
correct?
A. Yes. Or, on the very top, where it says, MPA, which basically is the area code, that's
where you can start, and in this case it's (818). MR. NICOLA: Okay. Your Honor, I have no
further questions. THE COURT: Cross-examine? MR. SANGER: Your Honor, I have no
questions. THE COURT: Thank you. Call your next witness. MR. NICOLA: We have no
other witnesses, Judge. THE COURT: Those are all the witnesses for today? MR. NICOLA:
It is. THE COURT: (To Mr. Sanger) Do you want to go back and cross-examine? We've got
some extra time. (Laughter.) THE COURT: (To the jury) I'll see you tomorrow morning at
8:30. Counsel approach for just a moment. I want to talk to you about our schedule for a
moment. (To the jury) You can go ahead.
(Discussion held off the record at sidebar.)
(The following proceedings were held in open court outside the presence and
hearing of th
THE COURT: All right. Let me just put this on the record. We're going on the record. The
Court was just inquiring of counsel about the schedule tomorrow, and there's anticipated
to be three witnesses tomorrow. Some will be outside the presence of the jury and some
will be in the presence of the jury. Do you think it will be a full day tomorrow? Or what's
your anticipat ion? MR. SNEDDON: I anticipate it will not be, Your Honor. But from there
on, it will be. THE COURT: They can't hear you back there. Go ahead. MR. SNEDDON: And
I anticipate it will not be a full day tomorrow. I anticipate on Monday and Tuesday we will
complete our case, and we will go all the way through without a break until we finish. THE
COURT: And then you now anticip ate we'll complete the People's case Tuesday? MR.
SNEDDON: I believe, depending on cross-examination, but we will not have any more
breaks. We will have all our ducks in order for those two days. THE COURT: Then the
Court was addressing with counsel Exhibits 809-A and 810-A, which are the
transcripts for -- 809-A is the transcript for the CD tape of the phone conversation
between Janet Arvizo Jackson and Frank. And 810-A is the transcript of the tape, CD,
made during the Los Angeles Protective Services interview. And they were previously
accepted into evidence, and the Court's pulling them from evidence and having them
lodged as transcripts, which is the proper procedure when you file a transcript with the
Court. Unless the parties stipulate the transcript may go to the jury, the transcript doesn't
go to the jury. So we're just correcting that. The other transcripts all were lodged
properly, and those were the only two that we found that were taken into evidence. MR.
SNEDDON: That's fine with us, Your Honor. THE COURT: Is there anything else to take up

before we recess for the day? MR. SNEDDON: No, sir.MR. MESEREAU: No, Your Honor.
THE COURT: All right. Court's in recess.

2005 April 29 (Days 42 ) I. Drew prosecution shows to Jury a book found in 1993
LOL

THE COURT: Lets see. I understand that the District Attorney has requested the out-ofpresence hearing on the foundation on the books.
MR. ZONEN: Yes, Your Honor.
THE COURT: What exhibit number is that?
MR. ZONEN: No. 841 and 842.
THE COURT: All right. I did review those materials, as I had requested. I d id get the
materials, and I looked at those books and indicated that there must be further
foundation. Are you prepared to go forward with that?
MR. ZONEN: I am, Your Honor. Foundation with regards to where seized, do you mean?
THE COURT: Yes. Connecting -MR. ZONEN: Yes, were prepared to do that at this time. Well call Detective Rosibel Smith
to the stand.
THE COURT: When you get to the witness stand, remain standing and face the clerk.

ROSIBEL FERRUFINO SMITH EXAMINATION

DIRECT EXAMINATION BY MR. ZONEN:
Q. Tell us your current occupation.
A. Im a police detective for the Los Angeles Police D epartment currently assigned to the
Threat Management Unit of the Detective Support Division.
Q. How long have you been a police officer for the City of Los Angeles?
A. For a little over 20 years.
Q. And your current assignment invo lves what?
A. Aggravated stalking cases, criminal threats of elected officials, and workplace violence
incidents within the City of Los Angeles.
Q. Did you work also as a sex crimes prosecutor -- sex crimes detective?
A. Yes, I did.
Q. For what period of time?
A. For nine years.
Q. All right. Which period of nine years was that?
A. From 1988 to 1997.
Q. Did you have occasion to conduct and execute search warrants during that time?
A. Yes, I did.
Q. In August of 1993, did you participate in the execution of a search warrant at
Neverland Ranch in Los Olivos, the County of Santa Barbara?
A. Yes, I did.
Q. And did you seize objects from that residence during that search?
A. Yes.
MR. ZONEN: May I approach the witness?
THE COURT: Yes.
Q. BY MR. ZONEN: Im going to show you three objects at this time. Exhibits No. 841 and
842; would you take a look at those two objects, please?
A. Okay.
Q. Do you recognize those two books?

A. Yes, I do.
Q. Did you seize those two books?
A. Yes, I did.
Q. From where?
A. These books were seized from a cab inet within Michael Jacksons closet in the master
bedroom.
Q. All right. Describe his bedroom for us, please.
A. The bedroom is a very large -MR. SANGER: Your Honor, I think it would be cumulative at this time, wouldnt it?
THE COURT: Sustained.
Q. BY MR. ZONEN: All right. Tell us where in his bedroom this particular closet is.
A. It was off to the side of the main bedroom. There were -- actually, there were two
closets on either side of the room, and this would have been the side where the Jacuzzi
was located.
Q. Now, this is the first floor of his bedroom suite; is that right?
A. Thats correct.
Q. Was there a bed in that bedroom suite?
A. Yes.
Q. Im going to show you Exhibit No. 856.
A. Okay.
Q. Do you recognize that photograph?
A. Yes, I do.
Q. And that photograph is what?
A. This is a photograph that was taken during the search warrant of Neverland Ranch, and
it depicts the file cabinet that the books were seized from.
Q. All right. And is that file cabinet depicted in that photograph?
A. Yes, it is.
Q. How many drawers in that file cab inet?
A. Four.
Q. In which drawer were those two books seized, from which drawer?
A. From the third drawer.
Q. Was that file cab inet locked?
A. Yes, it was.
Q. How were you able to unlock it?
A. We were ab le to get the key from -- the maid brought the key over to the home and we
were ab le to unlock it at that time.
Q. Do you remember which maid that was?
A. I believe it was Blanca Francia.
Q. Thank you. Is that photograph -- does that photograph accurately depict the subject
matter contained within it?
A. Yes, it does.
MR. ZONEN: Move to introduce 856 into evidence.
MR. SANGER: For the purposes of?
MR. ZONEN: For the purposes of this hearing.
MR. SANGER: For this hearing, I have no objection.
THE COURT: Then its admitted for the purposes of the hearing.
MR. ZONEN: And I have no further questions as to foundation for this witness.
THE COURT: Cross-examine?

MR. SANGER: May I approach the witness to take a look at the exhibits, please?
THE COURT: Yes.
MR. SANGER: And I have no questions for the purpose of this hearing.
THE COURT: All right.
MR. ZONEN: I would move to introduce into evidence 841, 842 as well.
MR. SANGER: Well, and I suppose thats the purpose of the hearing, Your Honor. We had
previously objected, and -- excuse me one second. We still object on the grounds that this
is remote in time. We have books from -- seized in 1993 with regard to events that
alleg edly occurred in 2003, so the probative value of these books is minimal at best, and
its outweighed by the confusion to the jury, prejudicial effect, and everything else.
Theres got to be some connection in time. Its just plain stale to bring in something from
that far back and try to use it by way of not much more than innuendo at this time. These
books were not shown to anybody. Theres no evidence they were shown to anybody. No
evid ence they were shown to minors. They were locked in a cabinet.
THE COURT: What about the Memro case, People vs. Memro, cited by the prosecution?
The only relevance I see would be to the 1108 evidence that was introduced as these
books could be viewed as supportive of the other 1108 evidence. Thats what I think their
purpose of introducing the books is.
MR. SANGER: Well, I think that is. I mean, I cant imagine what else it would be. Thats
what Im saying. In other words, theres no evidence that these books, or any of the other
books, the actual books that were seized, many of which, or all of which the Court has
allowed from the 2003 time period, theres no evidence that they were shown to any of
the people in this case. Not shown to minors. They werent used for any purpose. Theyre
just shown -- theyre -- Im sorry. They were offered to show that Mr. Jackson had these
materials in h is house. I think the Courts now heard all the testimony. I think its very
minimal weight even for the 2003 materials. And so my concern is that while Memro
might talk about allowing this kind of evidence to show that the -- that the individual had
this evidence in h is possession at the time of the offense, this isnt the time of the offense.
This is ten years before. And its locked in a file cab inet. So not only do you not have it
being used for any untoward purpose, but its simply possessed and its possessed in a
secure fashion, and its possessed ten years before any events in this case. It just seems
to me that at some point the Court has to draw the line. And the Court has, of course,
been drawing lines throughout this trial as to what has the kind of probative value that
should come before the jury and what doesnt. And I think that, given the fact that the
only materials that theres any evidence were shown or seen by minors in this case are
adult heterosexual magazines that are lawful to possess by adults, the fact that they have
attempted to introduce from a giant library of books any book that might have a page or
two or five or ten of individuals who are not fully clothed is -- I think its just an effort to
prejudice the jury. So -THE COURT: But the Memro case isnt about showing the material to anybody. Its about
having the material and allowing it to be introduced as evidence that the defendant may
have some proclivity to the type of sexually explicit material that were dealing with. So
its not a question -- you know, one of the issues in this case presently is about whether
he showed children that material. But another reason the materials admissible is that it
relates to his state of mind. And thats why theyre offering it, according to their proffer.
MR. SANGER: Right. I understand that. And maybe Im not being clear. But what Im
saying is, yes, there is no showing that it applies to the other purpose. So therefore, its
evid ence to show that its being offered to show that the person who possessed it has an

interest in these materials. And if thats all it is, then my position is that because its ten
years old, the probative value is very, very weak.
THE COURT: If its offered to show that he had that interest at the time of the 1108
alleg ations, thats the probative value.
MR. SANGER: And -THE COURT: And you say thats -MR. SANGER: And Im saying thats very, very weak.
THE COURT: I just want to be sure were seeing it the same way, and I think we are.
Okay.
MR. SANGER: Yes. And I apologize for not being more direct in answering the Co urts
questions. But I guess what Im saying, at some point you have to draw the line there. In
other words, this case really isnt about 1993. 1108 only allows that to come in for really a
limited purpose.
THE COURT: True.
MR. SANGER: And now we are embellishing the limited purpose thats already pretty
remote. And as the Court acknowledged from the beginning, the real question is whether
or not this kind of material is going to be so prejudicial when the jury is considering the
strength of the case that was presented as to the charged events. And the strength of the
case presented as to the charged events is, I submit, much weaker than it was led to -the Court was led to believe at the time of the 1108 ruling. In other words, Your Honor
had heard some of the evidence, but you hadnt heard all of the evidence. Youve heard
more evidence and its gotten worse for the prosecution. Their current case is very weak.
This is just an attempt to further bolster that with what is remote. And I understand the
Courts theory, and -- the prosecutions theory, lets put it that way, and the Courts
acknowledgement of that theory. And thats my point; it is remote. Its to bolster 1108.
And 1108 is to bolster this case. Its too far afield.
THE COURT: Okay. I understand your argument now.
MR. SANGER: Yes. Thank you, Your Honor.
THE COURT: Do you wish to respond, Mr. Zonen?
MR. ZONEN: If the Court would like, yes. Just briefly, Your Honor, the books that were
seized in 1993 were seized at a time that was contemporaneous with the evidence
presented pursuant to 1108. There were four young boys who were involved in Michael
Jacksons life. Its interesting and unique that the maid who was called to open up this file
cabinet was, in fact, the mother of one of those victims at that time. Those books -- one
of the books -- both of the books are pictorial essays of adolescent boys. One of them,
about 10 percent of the photographs are completely nude boys. And the other one, 90
percent of the photographs are completely nude boys. The possession of those books by
Mr. Jackson, we believe, is evidence of a prurient interest in adolescent boys and its
exactly contemporaneous with the state of the evidence as to all of the 1108 witnesses.
Therefore, we believe it adequately corroborates within the meaning of People vs. Memro.
Wed ask that it be admitted.
THE COURT: All right. I want to think about this issue a little further. Im not ready to
make a decision on that.
MR. SANGER: Your Honor, could I -- I know we go back and forth, and I cant really tell
who started and if I get a brief rebuttal. But could I be permitted to make one remark?
THE COURT: Yes.
MR. SANGER: Thank you. When the Court looks at the evidence, Id ask the Court to look
at the inscription in the inside of the first book, which is Boys Will Be Boys. And I dont

know -THE COURT: Do you want to get the book for me and Ill look at it?
MR. SANGER: Yes. I take it I may approach.
THE COURT: You may, yes. You may retrieve the exhibits. Bring both of them. You might
as well bring both of them. Officer, I think I let you sit there a little longer because I
wasnt sure that someone might want to ask you another question. But I dont think thats
necessary, so you may step down.
THE WITNESS: Thank you, sir.
MR. ZONEN: Your Honor, if were going to -- if the debate is going to go beyond the
location of where the books are seized -THE COURT: Cross-examination is over. The arguments not there in that area. Am I
missing something?
MR. ZONEN: No. My understanding was the debate was over the location of the books.
THE COURT: No, no. The debate -- I said I wanted further foundation. I wanted to look at
the books, and I wanted foundation. There was no debate. That was my request.
MR. ZONEN: Thats fine.
THE COURT: Now I have what I want. I still have to make a decision.
MR. ZONEN: Thats fine. Thats fine.
THE COURT: Now, what was your reference?
MR. SANGER: I dont know which number is which, but the one thats entitled Boys Will
Be Boys.
THE COURT: Yes.
MR. SANGER: Which I think is 841, but Im not positive.
THE COURT: Its 841.
MR. SANGER: Okay. On 841, if you look at that, it appears to be Mr. Jacksons own
inscription, and he says, Look at the true spirit of happiness and joy in these boys faces.
This is the spirit of boyhood, a life I never had and will always dream of. This is the life I
want for my children. M.J. The other book, which would be 842, appears to be inscribed
by a female fan, and it appears to have been sent to Mr. Jackson by a fan of some sort.
Thats the interpretation I take from that inscription.
THE COURT: Well, there is an inscription, To Michael. From your fan.
MR. SANGER: Yes.
THE COURT: Love -- XXXOOO - I was going to interpret that, but I wont - Rhonda. I
know what I mean when I put XXXOOO.
MR. SANGER: And I have noted Your Honor has never put that on any of your rulings in
this case. (Laughter.)
THE COURT: I cant top that. All right. Then that hearing -- at this point, Im going to take
that under submission, and well rule on that before the People rest. And if youre about to
rest and I havent ruled it, tell me. Remind me.
MR. ZONEN: D id you mean rest the case or rest today?
THE COURT: Rest the case.
MR. ZONEN: A ll right. The witnesses are here today. Are they not going to be testifying
today? If they are not, I will go ahead and excuse them.
THE COURT: They cant hear you.
MR. ZONEN: Im sorry.
THE COURT: What witnesses?
MR. ZONEN: The witness who seized the book presumably would be testifying as to where
and what she seized in the course of the trial before the jury.

THE COURT: Oh, I see. You need it for that purpose?

MR. ZONEN: Yeah. If were not going to do that today, Ill go ahead and excuse her and
have her come back.
THE COURT: No, we can do that today.
MR. ZONEN: W e could put her to the end of the witness list.
THE COURT: We could put her to the end of the morning.
MR. ZONEN: Your Honor, there was one other matter, a motion that was filed by an
attorney who represents one of the witnesses to be called today. Did the Court want to
address that at this time?
THE COURT: Yes. Thats the Drew witness?
MR. ZONEN: Yes, Your Honor.
THE COURT: Is that witness present?
MR. ZONEN: The witness is present, out of the courtroom, and counsel is present before
you.
MS. SAGER: Good morning, Your Honor. Kelli Sager on behalf of Ian Drew, a nonparty
reporter.
THE COURT: Good morning.
MS. SAGER: We had filed a short memorandum with the Court concerning Mr. Drews
testimony largely to give the Court some guidance and background, which I understand
has alread y come up once in this case, as to the scope of the reporters privilege under
the California Constitution and the First Amendment and the common law. Mr. Drew is
being called by the prosecution, 817 as I understand it from Mr. Zonen, to repeat
informat ion that has been published by him in a television broadcast. And I assume that
Mr. Zonen still intends to limit his questioning to the published material. It nonetheless
raises an issue as to cross-examination. And in the Foss case, which we cited in our
papers, if it appears that the defendants cross-examination would intrude into privileged
areas, then its advised that the Court address that at the outset, because it may be that if
the defendant is not going to be permitted to cross-examine into those areas, that the
original testimony should not be permitted either. In either case, I just wanted to make
sure the Court was apprised that the witness does intend to assert his rights as to
unpublished information or confidential source informat ion and to ask the Courts
permission to be making objections on his behalf.
THE COURT: Well, you have my permission to do that.
MS. SAGER: Thank you.
THE COURT: You know, I thought your points and authorities were well done and
complete. One of the things that you mentioned in your points and authorities was that
theres a preference to have a hearing outside the presence of the jury before the
testimony is proffered to the jury so the Court can determine whether or not the evidence
should be allowed.
MS. SAGER: Thats correct, Your Honor.
THE COURT: Based on the right of the defense to cross-examine. Mr. Mesereau, you wish
to say -MR. MESEREAU: Yes, please, Your Honor. Your Honor, as the Court knows, the witnesss
name came up during the testimony of -THE COURT: Just a moment. Would someone create a seat there so she
doesnt have to stand.
MS. SAGER: Thank you. Thank you, Your Honor.
MR. MESEREAU: This witnesss name came up during the testimony yesterday of Debbie

Rowe.
THE COURT: Right.
MR. MESEREAU: And she did testify, among other things, that he had actually interviewed
her at Schaffels house during the subject interview that was talked about yesterday. This
witness was secretly recorded on a number of occasions by Debbie Rowe at the behest of
the sheriffs and he also gave a police interview where he talked extensively about various
aspects of the case, including Mr. Schaffel and others. Clearly, he had a career motive in
doing this. Clearly, there were financial considerations involved, considerations involving
advancing his career, and clearly he wanted to be involved in this case. If you look at the
secretly recorded conversations, you can gather a lot of his motives to do what hes doing.
And to permit him to testify as a prosecution witness and not allow the defense to go into
those types of incentives to do various things, say various things, appear in various
places, would be highly prejudicial to the defense. So allowing him to just hide behind a
journalistic privilege every time his motives and veracity are impeached or contradicted or
questioned would be prejudicial to us. He put himself right in the middle of this
investigat ion intentionally, willing ly, and knowingly. Met with Mr. Klapakis for an interview,
talked about his knowledge of various individuals and various occurrences in the case as
he understood them. Was recorded on a number of occasions by the sheriffs because they
thought he had information of significance, conducted the interview. How can they
possibly, if he gets caught in a problem, say journalistic privilege? I think that would be
highly inappropriate and very prejudicial to the defense. Thank you, Your Honor.
MS. SAGER: Your Honor, if I could just briefly respond to Mr. Mesereaus comments.
Under Penal code Section 632, I believe any recordings of Mr. Drew that were done
without his knowledge would not be admissible for any purpose. As a reporter, hes
engaged in conversations with a great number of people, including Miss Rowe, as she
testified to, in the course and scope of his duties as a reporter. The fact that those
conversations may have been secret ly recorded without his permission, without his
knowledge, cannot waive any privilege that he has as a journalist as to information hes
attempting to gather. Hes reported on Mr. Jackson. He did an interview with Miss Rowe,
which everyone has a tape of. And as I understand it, the issue about that interview has
already been d iscussed, there have been other witnesses who have testified, and the tape
of the entire interview is available. So theres nothing Mr. Drew can add to that equation.
As to his -- what Mr. Mesereau described as an interview with detectives, when detectives
showed up, as I understand it, at Mr. Drews office to subpoena him, he was asked about
statements that he had made on televis ion, and again referred to those statements that
he had already made on televis ion, the published statements. He didnt have an attorney.
He didnt have anyone advis ing him of his rights at that point, and again, I dont think that
could be viewed as a knowing waiver of his rights. Nor is that a publication within the
meaning of Article I, Section 2(b) of the California Constitution. He was not disseminating
informat ion to the public in any conversation he had with the detective who was serving
him with a subpoena. As I understand it, theres one statement that the prosecution
intends to ask Mr. Drew about, and that was in this particular television broadcast
concerning a conversation that he had with one of Mr. Jacksons -- I dont know how you
would describe him, someone that Mr. Jackson knew. That person is certainly a witness
who could testify as to that. As I understand, its about whether the family at issue left the
ranch at some point in the middle of the night. I dont believe thats disputed. So its
difficult for me to see what Mr. Drew can add to these proceedings in any case, and
certainly nothing that would justify invading his privilege by opening him up to questions

about conversations he had during the course and scope of his news-gathering activities.
THE COURT: Mr. Zonen?
MR. ZONEN: Your Honor, we intend to limit our inquiry to information that was disclosed
by Mr. Drew on national television. Its published information, therefore its not protected
by the shield law.
THE COURT: Well, but thats not the issue, is it? I mean, that -MR. ZONEN: Thats one issue. The next issue is the question of whether or not crossexamination -THE COURT: Right.
MR. ZONEN: -- is important for impeachment. We believe that the information that we are
going to be asking him is about a statement made by another person, one of the
unindicted co-conspirators, to the effect that the Arvizo family had fled from Neverland,
and therefore Mr. Drew would not be able to conduct an interview that he expected to do.
I dont know that the content of that information requires an extensive cross -examination
into collateral areas. I think it can be adequately cross-examined as to that statement
alone without going too far beyond the published information.
THE COURT: Well, I think what well do is you can call your witness, you can ask him the
questions, and then Ill understand what youre going to ask him in front of the jury and
what his answers are going to be -MR. ZONEN: Okay.
THE COURT: -- and then well see what -MR. ZONEN: Shall we do that at this time? 8181
THE COURT: -- what Mr. Mesereau wants to do. Yesterday he filed a motion to prevent
someone from testifying and later withdrew it, so....
MR. ZONEN: He might wish to do that today.
THE COURT: I dont know. Call your witness.
MR. ZONEN: D id you wish to do that outside the presence of the jury at this time?
THE COURT: Absolutely. Thats the point.
MR. ZONEN: Yes. Were prepared to do that. Would you call Mr. Drew down, please.
MS. SAGER: As I believe the District Attorney knows, Mr. Drew is not in the courthouse.
He was told to be here at ten oclock.
THE COURT: Oh, okay.
MS. SAGER: I was asked by Mr. Zonens office last night to show up early in case the
Court wanted to hear argument on that.
THE COURT: Thats not a problem. We can do the hearing later.
MS. SAGER: Okay. I will go outside, though, and call him, Your Honor, and tell him to
come directly to the courthouse, and hell be available whenever the Court can then hear
him.
THE COURT: If hes going to be here at 10:00, thats fine.
MR. ZONEN: I dont know that our other witness will necessarily go to ten oclock. If were
not going to be dealing with -THE COURT: I thought you were going to try to get other witnesses for me.
MR. ZONEN: W e are not able to do that. The witnesses we had I think were the ones that
we identified yesterday.
THE COURT: But I was told you would attempt to get other witnesses to fill the day.
Because I didnt give you permission for a short day today, or no day.
MR. ZONEN: I apologize to the Court. We are not able to do that.
THE COURT: Go ahead and call your client, please.

MS. SAGER: Ill do that. Thank you, Your Honor.

MR. ZONEN: W e have a witness whos ready to proceed at this time.
THE COURT: All right. You can bring in the jury.

CRAIG BONNER EXAMINATION

THE COURT: Good morning again.
THE JURY: (In unison) Good morning.
THE COURT: Its getting to be a habit, isnt it? Counsel, call your next witness.
MR. ZONEN: W ell call Detective Craig Bonner to the stand.
THE COURT: I believe you were already sworn. You may be seated.
DIRECT EXAMINATION BY MR. ZONEN:
Q. Youve already testified previously, I believe, on a couple of occasions already.
Detective, youve already testified previously on a couple occasions. Theres an exhibit
thats in front of you. Could you take that exhibit, please? And is that Exhibit 827?
A. Yes, it is.
Q. And does that correspond to the Sheriffs No. 817?
A. Yes, it does.
Q. Do you recognize that exhibit?
A. Yes, I do.
Q. What is that exhibit?
A. It is an audio cassette tape which contains a recording of Janet Arvizo and Frank Tyson,
or Cascio.
Q. This is a telephone conversation; is that correct?
A. It appears to be, yes.
Q. Was that tape-recording delivered to a lab in Los Angeles County?
A. Yes, it was.
Q. And what lab was that?
A. The Aerospace Corporation and/or the National Law Enforcement and Corrections
Technology Center.
Q. The purpose for delivering that tape to that lab was what?
A. To have them analyze it, and to determine if there were any breaks or stops that
occurred within that recording.
Q. Who was it who delivered that tape to the lab?
A. I did.
MR. ZONEN: Thank you. No further questions.
CROSS-EXAMINATION BY MR. SANGER:
Q. The National Law Enforcement Technology and -- whatever it was -A. Corrections and Technology.
Q. Corrections and Technology. This is actually a private company, is that right?
A. It is.
Q. And they market their services to law enforcement; is that correct?
A. I believe they have a grant through the government that they get paid to assist law

enforcement.
Q. Okay. Its a private company, but they market their services to law enforcement?
MR. ZONEN: Objection; asked and answered.
MR. SANGER: Asked, but not answered.
THE COURT: Overruled.
MR. SANGER: Thank you.
THE WITNESS: I dont believe they market their services, no.
Q. BY MR. SANGER: They let you know that they exist and theyre availab le to do work; is
that correct?
A. Thats correct, yes.
Q. They get paid by doing the work?
A. Not by us, no.
Q. They get paid by this grant?
A. I believe so, correct. 8186
Q. Thats your understanding? All right. Now, did you seize this particular item that you
took down?
A. No, I did not.
Q. So you took it out of the evidence locker?
A. Correct.
Q. At the sheriffs department?
A. Correct.
Q. And you delivered it down to the -- to the lab; is that right?
A. Yes.
Q. And then you stayed for a while while some work was done; is that correct?
A. That is correct.
Q. Not all the work was done while you were there?
A. No.
Q. You left it?
A. Left the item?
Q. Yes.
A. No.
Q. What did you do?
A. I remained with this item until they had brought it into their system, and then I
retained this item and brought it back to the sheriffs department.
Q. All right. So they made a copy to do the rest of their work?
A. They brought it in digitally. Im not real savvy on it, but basically they p layed it into
their system, which brought it into a computer, and then they utilized that material that
was saved onto the computer.
Q. Okay. In other words, that is an audiotape. Thats a regular cassette, little reel-to-reel
cassette?
A. Correct.
Q. Magnet ic tape, correct?
A. Correct.
Q. And while you were there, they d id some analysis of the actual tape?
A. Correct.
Q. And then while you were there, they copied it into digital format of some sort?
A. Correct.

Q. And then you took the actual tape and you brought it back?
A. Yes.
Q. All right. Now, what is your understanding as to the source of the original tape?
A. This tape came from the office of Brad Miller.
Q. Okay. In other words, as one of the detectives working on the case, you are familiar
with the source of various items of evidence; is that right?
A. Yes.
Q. And that was something that was seized during the search warrant execution at Brad
Millers office, correct?
A. That is correct.
Q. In other words, it was not offered to law enforcement as a piece of evidence that was
helpful to Mr. Miller or helpful to Mr. Jackson, or helpful to anybody; is that correct?
MR. ZONEN: Im going to object as beyond the scope of the direct examination and
beyond the scope of his personal knowledge. And relevance.
THE COURT: Sustained.
Q. BY MR. SANGER: Okay. It was something that was -- that was simply seized during a
surprise search, right?
MR. ZONEN: Objection. Irrelevant; beyond the scope of his knowledge.
MR. SANGER: Well, thats the question.
THE COURT: Sustained. Argumentative.
MR. SANGER: All right. Its still my last question. No further questions.
MR. ZONEN: No further questions. I will call Dr. Harry Koons to the stand.
THE COURT: You may step down. Remain standing, raise your right hand, and face the
clerk here.

HARRY KOONS EXAMAMINATION

DIRECT EXAMINATION BY MR. ZONEN:
Q. What is your current occupation?
A. Im a scientist.
Q. Youre a scientist in what capacity?
A. Im a scientist at The Aerospace Corporation in El Segundo, California. Its the Space
Science Applications Laboratory. And our company is a -- well, it hosts an FFRDC, which is
a federally funded research and development center, which primarily assists the Air Force
and national security agencies in their space programs.
Q. All right. Do you also have a second company titled The National Law Enforcement and
Corrections Technology Center?
A. Yes. Thats also hosted by The Aerospace Corporation and its funded by the National
Institute of Justice.
Q. Lets start with the first one, The Aerospace Corporation. What is your position there
with The Aerospace Corporation?
A. Im a d istinguished scientist.
Q. What kind of work do you do with the Aerospace Corporation?
A. On the Air Force side, I have flown instruments on spacecraft to make measurements
in the magnetosphere of what we call p lasma waves, and Im also an expert on the space
hazards to spacecraft.

Q. All right. I think the other microphone is on as well.

A. Shall I just talk in the middle?
Q. You need to be close to one or the other, but whichever is more comfortable.
A. Either one is okay.
Q. All right. What is your education, your qualificat ions, please?
A. I have a bachelors of science in physics from the Massachusetts Institute of
Technology, and a Ph.D. in geophysics also from the Massachusetts Institute of
Technology.
Q. How long have you worked with The Aerospace Corporation?
A. I joined them right out of graduate school in 1968.
Q. Give us a sense of what type of work you do for Aerospace Corporation. How do you
spend your day?
A. I have a million hats. I spend most of my time either -- working on scientific papers. I
spend 20 percent of my time on the forensics audio. I spend about 40 percent of my time
working with the program offices on trying to help them with their problems on their
space programs. Theres almost no way I spend a given day.
Q. Now lets turn to the National Law Enforcement and Corrections Technology Center. Tell
us what that is and how that happens to be associated with The Aerospace Corporation.
A. It began in 1995. There was a -- an initiative by the Nat ional Institute of Justice to find
a way of helping local law enforcement agencies in their work. They recognized that a lot
of agencies didnt have a lot of funding for detailed forensics work, and so they issued a
proposal for organizations with more capabilit ies to help them. And so Aerospace
responded with a proposal, and out of that was formed the National Law Enforcement and
Corrections Technology Center at Aerospace.
Q. And what kind of work do you do with the National L aw Enforcement and Corrections
Technology Center?
A. I personally am responsible for the audio forensics work.
Q. Is there other forms -- are there other forms of forensic work that are done by that
center as well?
A. Yes. Video forensics and also crime scene analysis. We have a large capability in our
support for the Air Force, electron microscopes and very sensitive equip ment that can be
used to analyze materials. And so its essentially a matrix organization that if the Law
Enforcement Center needs something in the laboratories, they go to the person in the
laboratories. The video and the audio efforts have been more or less continuous since its
inception.
Q. All right. What is it that you do with regard to audiotapes?
A. Primarily what we do is we enhance the audio to allow for a transcription. Most people
would call this clarifying the audio. We also, from time to time, are asked to look at the
tapes for special reasons. Some of them, for example, are to identify the number of
gunshot wounds -- or not wounds. Gunshots that were fired at a scene that was
recorded. At other times to try to identify the number of people that were present during
the recording. Weve been asked to try to determine where a recording was made based
upon background sounds that were heard on the tape.
Q. All right. Are you able to make determinations as to whether a tape is a first-generation
or second-generation tape? Is that something that can be done?
A. We can -- we can do that, in some cases, by looking at the content of the -- of the
tape, yes.
Q. Are you able to determine whether there are breaks in a tape?

A. Yes. Normally we can determine if there are breaks in the audio in the tape.
Q. Are you able to determine, on occasion, whether a tape is a compilation of prior other
mult iple tapes?
A. Normally we can do that, yes.
Q. How do you do those things?
A. Each one is done in a different way. Lets start at the back and work forward. If you
have a co mpilat ion of a multiple of tapes, youll have different background audio on the
different segments. And, for instance, if one segment, at the extreme, if it was made in a
restaurant, and another section was made out on a street with passing cars, and another
section was made in a home with a television on, that you can look at the backgrounds of
each of these tapes and identify the background in the ways that you see, and you can
see where these different sections are on the tape. You ask -- what was the second one?
Q. The second one was breaks in a tape.
A. Breaks. Okay. For breaks in a tape, you again look at the background, and when you
have a -- a discontinuity, or a break in the tape, youll normally have -- the tape will start
and stop, start up again, stop, start up again, and you can see signatures of this on the
waveforms on the tape. You will also find lines in the background. By line, I mean a
constant frequency. For instance, one line which appears on many tapes is a power line at
60 hertz, and if that power line is discontinuous you could say that the tape was started
and stopped when the power line disappears and reappears.
Q. I think the first question that was asked to you was multiple generat ions of tapes.
A. Yeah, mult iple generation is more difficult. Normally, with the capabilit ies we have,
when a tape is started and played, and stopped and started again, that -- theres an erase
head on the tape-recorder, and the erase head erases the material that was on the tape
prior to that. Now, some laboratories have the capability of going in and examining the
material of the tape itself, and they may be ab le to identify if the tape was started and
stopped. We can only look at the content of the tape. And normally what we would do
when were asked a question like that is we would look at the beginning of the tape and
we would look at the end of the tape and see if theres material which is not contiguous
with the material in the middle of the tape, and also look at the end of the tape to see
whether, if the present material that was recorded, lets say, is recorded on only one half
of the tape. And then if the tape was previously used there would still be material on the
second half of the tape, unless somebody recorded -- erased it all the way to the end.
Q. Doctor, when did you begin doing forensic analysis of audiotapes?
A. 1995.
Q. How many do you think you have done since that time?
A. About 200 cases, give or take 10 or 20.
Q. Have you ever had occas ion to testify in court as to your analysis of those tapes?
A. No, I havent. Ive been subpoenaed twice before and I have not testified in court.
Q. This is your first occasion?
A. Yes.
Q. I hope youre comfortable this morning.
A. Im fine.
Q. Doctor, did you have an occasion to analyze a tape that was presented to you by
Detective Craig Bonner from the Santa Barbara County Sheriffs Office?
A. Yes, sir.
Q. Could you tell us approximately when that was?
A. They brought the tape to us on June 1st of last year. And according to our logbook,

which I may want to refer to later -- but according to our logbook, they stayed with us
while we digit ized the tape. Digitizing means taking a copy of the audio from the tape and
putting it onto a computer. That was done by a technician and I was standing there while
he did that. And then we gave the tape back to Craig Bonner. We went up to my office
and we looked at it for a period of time. I dont remember how long it was. There was
another gentleman with him, I believe, and then they left. And about a month later, I
went through and did a detailed analysis of the tape and wrote a letter, which I sent to
him at the time.
Q. All right. The work that you do is off the digital copy of that tape, then; is that correct?
A. Thats correct.
Q. And the process of making a dig ital copy of a tape, does that in any way transform the
original tape?
A. No.
Q. It wouldnt affect the integrity of the content of that tape?
A. No. There would be no effect on the tape at all.
Q. What was your assignment in this case as to the digital copy of that tape? What was
your assignment?
A. Our assignment was to determine if there were any breaks in the audio.
Q. Just for purposes of clarity to make sure that were on the same topic, did you have an
opportunity to actually listen to the tape as well?
A. Yes, partly. We were listening to the tape, but partly we were looking at pictures of the
image of the audio on the screen. I have listened to about 90 percent of the tape.
Q. Is this a tape of what appears to be a telephone conversation between two people,
predominantly two people?
A. Okay. Two people.
Q. An adult woman and an adult man and a child?
A. And a child, yes. Three people.
Q. Predominantly the adult woman and the adult child -- the adult man?
A. Thats right.
Q. All right. Doctor, what did you do with this tape? The copy, that is. What were you
seeking to do and what did you do?
A. Well, the primary thing we were asked to do was to determine if there were any breaks
in the audio. And the first thing that I did was I -- I put an image of the audio on the
screen and just looked at the entire tape at one time. And my impression was that it was
relatively continuous. And -- because the background appeared to be about the same level
from the beginning of the tape to the end. Theres 22 minutes of audio on the tape. Its a
30-minute tape. And then I went in and I started at the beginning and I looked at the
segments which were one minute long. And the first thing I noticed was that, I think it
was 13 seconds or so into the tape, there appeared to be a discontinuity. And so I blew
that up and I took a look at it, and there was, in fact, a gap at that time period. And so
having seen one, then I sort of had some idea what I should look for if there were others
like that one. And so I moved along through the tape, and I identified a number of these - these gaps. The gaps are very short on the tape. Theyre about two seconds each.
Q. All right. Tell us what you were able to determine with regards to gaps in the tape.
A. We found 34 gaps. And they had a characteristic signature. And the signature was very
close to the same as when the tape was first started. And by this I mean that if you start
an audiotape, there are wheels that take up reel on the feed reel that have to turn, and it

takes a little while to get those to turn, a little while being a second or so. And during
that time period when the amplifier is trying to put a voltage onto that tape, it makes a
little signature that looks a little bit like this, and its a couple tenths of a second long. And
if you look at the beginning of the tape, you get that signature very clearly the first time
its turned on. There was no audio in front of it and you see that signature. And what I
found, then, was a very similar circumstance, not identical each time. But each time there
was a gap, there was a signature that looked just like that one at the beginning.
Q. What would cause a gap in a tape?
A. Can I refer to my notes on this?
Q. Yes. Please, go ahead.
A. At the time I was analyzing it, I made a note of what I thought might be causing these.
And instead of trying to remember it, Id like to see if I can find it in here and -Q. Go ahead and take a look and read it, but dont read it out loud.
A. Yeah. Okay. It was July 2nd, and I made a note -MR. SANGER: Im going to object. Theres no question pending.
THE COURT: Sustained.
Q. BY MR. ZONEN: What Id like you to do is go ahead and read the notes that you have
made quietly to yourself.
A. To myself.
MR. SANGER: And then after he does that, I would like to see what notes hes referring to.
MR. ZONEN: I have no objection. THE WITNESS: Okay. MR. SANGER: May I approach,
Your Honor? Hang on, one second. Your Honor, could we approach for a moment, please?
THE COURT: Yes. (Discussion held off the record at sidebar.) THE COURT: Im going to
take a brief recess to give counsel an opportunity to look at the notes before further
examination, so Ill see you in a few minutes. (Recess taken.)
THE COURT: All right, Counsel.
MR. ZONEN: Thank you, Your Honor.
Q. Dr. Koons, we left off, I was asking some questions about breaks in this -BAILIFF CORTEZ: Your microphone.
Q. BY MR. ZONEN: Dr. Koons, when we left off, I was asking you some questions about
the breaks in this tape, and I think you proffered the opinion that there were 34 breaks; is
that correct?
A. Thats correct.
Q. All right. And then I had asked you what types of things or occurrences could cause
breaks of such a nature, and you had referred to some notes and youve read some notes.
A. Yes.
Q. All right. Are you prepared at this time to answer that question?
A. Yes, I am. I hope I can remember all four of them. I identified four things that could
cause breaks such as this. So one is the pause button on the tape-recorder. If you press
the pause button and you press it again to restart it, you would get a break in the tape.
Another would be a press-to-talk telephone that, I dont know if -- you may not be
familiar with these in the home context very often, but in a classified context, you have a
telephone with a button on the handle, and the only time you can hear a person speak is
when the button is pressed. Another is the mute button on the telephone would cause
the audio to go out, and then, when you unmute it, to come back in again. And I dont
remember the fourth one.
Q. All right. Would it help to look at you notes again to see what it was?
A. Yeah, probably. Oh, a voice-activated line; that if you have a vo ice activation on your

recorder, the recorder will stop and start. It will start whenever it hears a loud -- a signal
such as a person beginning to talk, and it will stop when a person stops talking.
Q. Would that tend to explain breaks in a first-generation tape?
A. Yes, it would.
Q. Would it explain breaks in a second-generation tape?
A. No. It really cant do that, because a second-generation tape is not made with a
microphone. Its made by copying or using wires from one tape-recorder to -- the source
to the destination tape-recorder.
Q. Lets talk about the first generation, then, if we could. Is it your understanding or does
it appear that this is a tape-recording of a telephone conversation?
A. Yes, I believe it is.
Q. How do people generally tape-record telephone conversations?
MR. SANGER: Objection. Calls for speculation; no foundation.
MR. ZONEN: Im not asking this specific time, but simply how is it done that telephone
conversations are taped.
THE COURT: The foundation is sustained.
Q. BY MR. ZONEN: Do you know how people tape-record telephone conversations?
A. Yes, there are two basic ways to do it.
MR. SANGER: Im going to move to strike as nonresponsive beyond Yes.
THE COURT: Stricken.
Q. BY MR. ZONEN: You said, Yes.
A. Yes.
Q. During the course of the work that you have done over the last ten years, have you, in
fact, tape-recorded telephone conversations?
A. Yes.
Q. And have you examined conversations that have been tape-recorded?
A. Yes.
Q. And does your study require that you look into the manner in which the conversations
are tape-recorded as well?
A. Yes.
Q. And would that be important to your analysis?
A. Yes.
Q. Okay. What are the ways in which telephone conversations are tape-recorded?
A. There are two ways. One, you place a small microphone on the handset. And thats
usually not a very good way, because its not strongly coupled into the conversation on
the phone. The second is to put a sensor in-line with the handset. You have these modular
plugs that plug into a modern handset, and you have a device that you plug in-line there,
and so it picks up the conversation going in both directions very well.
Q. Now, can you tell by listening to a tape-recorded conversation what method was used
to tape-record that conversation?
A. Yes.
Q. Do you have a sense of what method was used in this case?
A. I believe it was the in-line sensor.
Q. Why is that?
A. Because of the quality. It had a good pickup at both ends of the conversation.
Q. Now, when we talk about first-generation or second-generation tape, what are we
talking about?
A. A first-generation tape is called a virgin tape, where the first audio is recorded onto the

tape. A second-generation tape is one of two things. Its either an overrecording of that
one, or its taking the material on the first tape and recording it onto a second tape.
Q. All right. Now, can you tell whether this recording is a first- or second-generation tape
or subsequent to that?
A. Theres -- theres some evidence that its a second-generation tape.
Q. And what is the evidence that you saw?
A. The evidence is the first piece of recording, the first 13 seconds or so of recording, is
very different than all of the other, which suggested that the -- that the tape had been
used for something else and the second recording started later in the tape.
Q. Can you tell whether or not this is a tape that is a compilat ion of multiple
conversations?
A. I personally cannot determine that.
Q. It could be or could not be?
A. It could be or could not be.
Q. All right. Now, is it possible that this could be a tape-recording of a single conversation
but where pieces have been taken out, portions of the conversation deleted?
A. If its a second-generation tape, yes. If its a first-generation tape, probably not.
Q. Okay. Lets -- go ahead and explain that to us. Lets see, whats the first probability, or
the first possibility? The first-generation tape.
A. Okay. If its -Q. Tell us what you mean when you say probably not in terms of first generation.
A. Okay. If its a -MR. SANGER: Im going to object to this line of questioning as no foundation.
THE COURT: Overruled. You may answer.
Q. BY MR. ZONEN: Go ahead.
A. If its a first-generation tape, you can usually identify it by the length of the -- of the
pauses. For example, if you press the pause and then you go some distance, it usually
takes longer than on a second-generation tape. And also, you can tell by the context of
the material thats recorded on the tape where the breaks occur in it.
Q. All right. In this particular case, you suggested a greater likelihood of second
generation?
A. Yes.
Q. All right. And then we were asking some questions -- I was asking some questions
about pauses on a second-generation tape and whether or not this could be simply copied
from another tape. Explain how you would have those types of breaks then, please.
A. The -- the way that you -- you make a high-quality second-generation tape with
material from other tapes, if thats what you mean -Q. Yes.
A. -- is you would pick the section that you want to record, you would turn on the two
tapes and record a section, and then you would pause the one youre recording onto. And
then you would go to either another tape or another place on the first tape, and you would
set it up so that youre about to record it again, and you begin it a little ahead of time,
and you hit the pause button to start it recording again, and you can record a second
recording onto the tape. You can take any number of tapes, then, and put them onto one
tape that way.
Q. What you effectively can do, then, is take portions of an original tape and put it on a
second tape, and leave out whatever portions you wish to leave out?
A. Thats correct.

Q. Do you have any way of knowing whether the tape you analyzed was, in fact, the
product of that kind of conduct?
A. Not really.
Q. I -A. No.
Q. All right. You have no way -- let me reask that question.
A. From the analysis that we do, you cannot determine that.
Q. Okay.
A. You would have to use the context to determine that.
Q. All right. In other words, reading the content of it?
A. Yes. Now, can I elaborate?
Q. Yes, please.
MR. SANGER: Im going to object. Theres no question pending and theres no foundation
based on what was just said.
THE COURT: Foundation is -- no question pending is sustained.
Q. BY MR. ZONEN: All right. Explain to me exactly what the limitations are in terms of
what youre able to do.
A. We are able to -- to look at the audio in several formats on the computer screen. And
normally what we look for for breaks are discontinuities in the background or
discontinuities in the amplitude. In this case, we found -- we found both, but the -- the
type is such that it could be generated by either a pause button on a -- going to a
second-generation tape or possibly a pause button on a first-generation tape.
Q. All right.
A. Its only the context of the conversation would tell you which it is.
Q. You cant tell whether, again, this is first generation or second generation, other than
the clues that you have already testified to?
A. Thats correct.
Q. All right. Doctor, Id like you to look at Exhibits No. 857 and 858 that are before you.
Tell us what those two documents are.
A. May I start with the second one?
Q. 858?
A. Yeah.
Q. Yes. Please go ahead.
A. 858 is a record of the amplitude of the signal from the tape for 1.8 seconds beginning
at two minutes and about 37 seconds into the tape. And in the center of the picture, it
shows a section where, first of all, the level goes almost to zero, and then its at a very
low level. Then theres a transient at the turn-on and then its followed by speech. So
theres speech at the beginning, speech at the end, and the transient in the midd le is what
I have been calling a break.
Q. And the other exhibit, 857, what is that?
A. 857 is the same time period with a different depiction. This shows what we call an
audiogram, or a spectrogram, and it shows the intensity as a 8215 function of frequency
and then with time runn ing along the horizontal or X axis, and it shows in the background
the same break as a lightening of the signal. So this is two different ways of looking at a
break at exactly the same time period on the tape.
Q. How did you generate those two exhibits?
A. We use a software tool called Adobe Audition, and that is actually listed up on the -- on
the menu line on the screen. And this is a screen capture where we take the image from

the screen and we capture it and we save it as a file on the disk. So this is what we were
looking at at the time.
Q. So this is actually the equivalent of a photograph, or a copy of -A. A photograph of the screen. An image of the screen.
Q. Yes. Of exactly the image that you look at -A. Thats correct.
Q. -- when you make your determinations -A. Thats correct.
Q. -- and analysis?
A. Yes.
Q. And this is for a relatively small period of time, is it?
A. 1.8 seconds it says on here.
Q. And in 1.8 seconds, does it generate sufficient informat ion that you can actually see
and identify a break at that time point?
A. Yes, the -- yes.
Q. You talked to us about the signature. You used that term early on in your testimony.
What does that refer to?
A. The signature is shown on both of these. Its shown best on 858, and thats the -- there
is a -- a wave in the line at 238, just before 238.1 seconds, which is what happens when
you turn this particular tape-recorder on.
Q. All right. Are these breaks relatively short in duration?
A. Theyre very short. This one is only about a second long.
Q. The other 33 breaks in this telephone conversation, are they comparab le to that one as
well?
A. Yes.
Q. What does that suggest to you, that all of the breaks are roughly comparable and fairly
short in duration?
A. That they were -- I think in this case, in addit ion to the signature, they were all made
in the same way.
Q. All right. Would it be difficult to have relat ively short breaks if you are stopping and
starting a tape-recording during the course of a conversation?
A. Well, the breaks would still be short. Its the context thats different.
Q. Oh, I see. The content of the conversation itself. Okay. The two exhibits that weve
been referring to, 857 and 858, do they accurately depict the content contained in those
exhibits? In other words, are they an accurate depiction of what you looked at during the
course of your examination?
A. Yes, they are.
MR. ZONEN: Your Honor, I would move to introduce 857 and 858 into evidence.
MR. SANGER: No objection.
THE COURT: Theyre admitted.
MR. ZONEN: And may we publish those two at this time?
THE COURT: Yes.
Q. BY MR. ZONEN: In front of you should be a laser that I left -- you have it. Good. Go
ahead, please, and tell us what it is that youre looking at.
A. Yes, were looking at an image of -- do I have to talk close to this?
MR. SANGER: We havent identified which exhibit is up there, for the record.
MR. ZONEN: 858. Thats Exhibit 858 thats currently being shown.
Q. And yes, Im sorry, I know thats an awkward position, but you do have to continue to

speak through the microphone.

A. They wont be able to see through me. This is an image of the screen when we were
analyzing the tape, and the time runs along the bottom axis here. Its virtually impossible
for you to read it, but it starts at two minutes 36.994 seconds. That means two minutes
and essentially 37 seconds into the tape. Its very difficult to read this little number down
here, but that says that the view is 1.8 seconds long. So the time from here to there is
1.8 seconds. The signature is the amplitude of the signal, and its centered at the center,
about zero. And the best analogy that I can make with this is, if there are peop le here that
are old enough to remember what a vinyl record is, this is very much like the groove in
that vinyl record; that the needle would be moving along here, and so it would move
faster here, and hardly move at all here, and then it goes through a big bump, and then
more here. And by -- on a vinyl record, it reproduces the audio in the same way that the
voltage that were displaying here, when its passed through a speaker on a computer,
reproduces the speech.
Q. Do you see the signature that you refer to?
A. Yes. The signature extends from here to here, right in -- right in the center, and this is
the primary signature which Ive been calling the turn-on signature.
Q. And the break that you refer to?
A. Yes, the break is really this entire t ime period, that during this time period the audio
turned off, right here. Its very low here. And then this is the turn-on signature when the
reel started to come back up to speed. And then theres normal speech after about this
time here. So this is all a transient that occurred during what I call the break in the tape.
Q. All right. Lets go ahead to 858, if we can.
A. Okay. This is exactly the same -MR. SANGER: Excuse me, Your Honor.
MR. ZONEN: W e need a question.
MR. SANGER: I think this is 857. Am I wrong?
THE WITNESS: Yes, this is -MR. ZONEN: Forgive me. My dyslex ia is acting in. This is 857. The last one, then, was
858, if we could correct the record accordingly.
Q. Please go ahead and tell us about 857.
A. Yes, this is the same time period, starting at 236.994 and extending for 1.8 seconds
across the axis here. And whats displayed on the vertical axis now is frequency. And the
best way to explain this is if you look at this signature over here, this is a word that a
person has spoken, and what you can see is the fundamental of their vo ice box and then
the harmonics of their -- of their voice. And you can also see that over here and over
here. And this is the time period which was very qu iet where I said that the tape had
turned off. And you can see that the noise at the bottom, which is ind icated by the yellow,
has gone away. The blue indicates the lowest volume at that frequency; the green, an
intermediate volume; the yellow, a louder volume; and the red, the loudest volume. And
the frequency scale is on the left over here. Its impossible to read it there. This is 500
hertz -- oop, no, I think you want to.... Okay. Yes, okay. So this is a thousand hertz, and
it goes well above what most peoples hearing is at, at ten kilohertz up here. Take it back
to the full.... So if you can remember what I showed on the preceding exhibit, this is the
period when it went very quiet. This is a period where there was just a little bit of low
frequency noise here. This is the transient, and this is the beginning where it begins to
have speech again over here. So this is the characteristic signature, on this particular
media, of a break.

Q. Doctor, you had mentioned something about a voice-activated tape-recorder. What is a

voice-activated tape-recorder?
A. A voice-activated tape-recorder is a tape-recorder which, if the room goes silent, turns
off. And if somebody speaks in the room or theres a noise in the room, the tape-recorder
turns back on again.
Q. Does there generally have to be a period of silence before the tape-recorder is
activated or deactivated?
A. Yes, it usually takes quite a bit of time before it deactivates, because it doesnt want to
miss speech. And so they have a circuit that waits a long time, in terms of seconds, for
the silence to decide to turn off, but then they usually turn on very rapidly because they
want to get the first words.
Q. Okay. Doctor, do you have an opinion as to whether this tape is the product of a voiceactivated tape-recorder and then those breaks would have been caused by silence in the
conversation?
A. My opinion is its not voice-activated.
Q. And why is that?
A. Because the turn-off occurred too rapidly after the speech right here. This is only a few
tenths of a second.
MR. ZONEN: A ll right. We can turn the lights on and turn off the projector at this time.
Q. Doctor, just a couple of final questions. Do you have an opinion as to the nature of the
equipment that was used in this particular case?
MR. SANGER: Im going to object as either asked and answered or its vague.
THE COURT: Overruled.
Q. BY MR. ZONEN: Go ahead, please. And I guess by equipment, I mean both
telephones and tape recorders.
MR. SANGER: Then its compound.
THE COURT: Just a minute.
THE WITNESS: I really have -THE COURT: Ill sustain the objection.
Q. BY MR. ZONEN: Lets talk about telephones. Does it make a difference to you in terms
of your analysis of what type of phones are used?
A. Only in the sense of whether it was voice-activated or not.
Q. Okay.
A. But otherwise, no.
Q. Or the recording equipment?
A. No.
Q. Okay. Do you have a sense of where the recordings took place?
A. No.
Q. All right. Is there any information that would be -- let me rephrase that just for one
second. In terms of resolving the question of whether or not this is multiple conversations
as opposed to a single long conversation, are you able to hear any unique dynamics in the
sounds that would send to suggest that there were recordings at different locations?
A. No.
Q. Are you able to tell one way or the other?
A. No.
MR. ZONEN: Okay. I have no further questions.
THE COURT: Cross-examine?

CROSS-EXAMINATION BY MR. SANGER:

Q. All right. Dr. Koons, the bottom line to this is that you had a tape which you analyzed,
and you believe that the tape -- the recording process was stopped several times during
the course of the recording; is that right?
A. Yes, sir.
Q. All right. You dont know if it was stopped for five minutes, or ten minutes, or for a
second; is that correct?
A. Thats correct.
Q. And you didnt really listen to the tape to hear the context when you did your initial
analysis of this tape; is that correct?
A. Yes.
Q. Recently you decided to listen to the tape to see if you could kind of hear what the
people were saying, right?
A. Right.
Q. And when you listened to the context, as far as you could tell, it seems to be pretty
much a continuous conversation, correct?
A. Most, but not all of it.
Q. The first 13 seconds you had a question about; is that right?
A. Yes.
Q. All right. And, now, when you looked at the sonographic, if Im using the right term,
analysis, that was pretty much consistent with what you heard when you listened to it like
the rest of it; is that right?
A. Yes.
Q. In other words, you pretty much have the same background noise. Youve got the
same level of speech that goes throughout the entire tape; is that correct? With the
exception of the first 13 seconds.
A. Thats correct.
Q. And you had speculated in your bench notes -- in fact, you said, Speculate on causes,
right?
A. Right.
Q. And you said, Pause on tape-recorder; voice-activated line; push-to-talk phone; mute
button, right?
A. Right.
Q. Now, what is an AGC?
A. An AGC is an automatic gain control circuit, and the point of an AGC is to try to make
the audio level uniform on a tape. If you have, for instance, a conference with people
sitting around a large table, and you have a tape-recorder in the middle, that the person
closest to it will be naturally louder than the person at the end of the table, and the
automatic gain control, when it hears a period when the audio is weak, tries to push it up
and amplify it, and if its strong, it brings it down a little b it so its uniform on the tape.
Q. And you determined that you did not think this was an automatic gain control function
that was causing these apparent breaks; is that correct?
A. Thats correct. There is no automatic gain control on this recorder.
Q. So as it stands, you really dont know what happened, but there was some kind of
break?
A. Yes, there are breaks.

Q. All right. You also indicated that theres a signature to these breaks, simply meaning
that they appear to have been caused by the same mechanism; is that right?
A. Thats right.
Q. And from what you could tell by looking at it, it appeared to be some kind of a
mechanical
function that caused this break; is that right?
A. Thats right.
Q. All right. In other words, somebody pushed a button, either hit a stop button on the
recorder, or a mute button, or a pause button, something like that?
A. Can I elaborate on that?
Q. Yes.
A. More specifically, by mechanical, I meant that it had something to do with probably
the rotation of the wheels on the -- the drive on the tape-recorder rather than the button
itself. That the wheel will take a little longer or a little shorter to take up slack, for
example, at the beginning and end of the tape and the middle of the tape. And so there
are many different mechanical things like that, rather than the button itself.
Q. Okay. Well -- all right. Thats fair enough. In other words, the way these cassette tapes
work is that theres a magnetic head -A. Uh-huh.
Q. -- that will alter the tape itself magnetically -A. Yes.
Q. -- when input occurs; is that correct?
A. Yes.
Q. So somebody talks; its translated into energy that affects the magnetic head, that in
turn affects the tape; is that right?
A. Thats correct.
Q. So as the tape turns by the head, thats how you record it, right?
A. Right.
Q. And if you stop the tape from turning, it stops recording?
A. Yes.
Q. All right. And so your determination is that at some point it looks like this tape was
stopped from time to time?
A. Right.
Q. Now, you said you couldnt tell if it was first generation or second generation; is that
correct?
A. Thats true.
Q. And you did not do an analysis of the actual tape?
A. Physically.
Q. Physical analysis of the tape. All right. And there are labs that can do that?
A. I believe so, yes.
Q. All right. So you just looked -- once you digitized it, you just looked at the actual
electronic remnants of whatever it was that was done to this tape? In other words -A. I dont want to use the word remnants, but, yes.
Q. I was trying to think of a better word.
A. I know what you mean.
Q. The electronic imprints or whatever it was.
A. Its the signature of the electronic signal on the tape.
Q. If you actually look at a tape, sometimes you can determine that there are erasure

marks or theres other actual physical -A. Right.

Q. -- marks on the tape; is that right?
A. We did not do that.
Q. Did not do that. And I take it, from your analysis, you have no way of determining who
it was that stopped this tape from turning from time to time?
A. No.
Q. And you have no idea how long the tape stopped; is that correct?
A. Thats correct.
Q. Its even possible that there could be a malfunction in the tape machine, is it not?
A. Possibly. But they were not random.
Q. All right. So you dont know how long the tape stopped; in other words, if somebody
stopped the tape, got up, went out of the room, came back, or something?
A. Thats true. Yes.
Q. It could have been just a second that was not recording, couldnt it?
A. Yes.
MR. SANGER: All right. Okay. Thank you. I have no further questions.
REDIRECT EXAMINAT ION BY MR. ZONEN:
Q. Doctor, explain to us what you mean by not random.
A. If you have -- if you have a random process, the -- the distribution of the stops will
obey a statistical function called a Poisson function, and these do not fit that function.
Theyre almost uniformly spaced throughout the tape, except at the end, where they
become more rapid ly in the last minute.
Q. All right. Do you have an opinion as to whether the breaks in this particular tape are
caused by a malfunction of the recording device?
A. My opinion is they are not.
MR. ZONEN: Thank you. No further questions.
RECROSS-EXAMINATION BY MR. SANGER:
Q. Actually, I didnt notice that. So let me ask you about that. You actually -- in your
bench notes there, you broke down the times. Are you saying theres essentially a uniform
time gap between the tape -- between the -A. Between the gaps.
Q. Between the gaps?
A. Not uniform. Its not periodic. But they -- there is a group at the end which is out of
character with the other ones, which suggest that its not random. There were a bunch
that occurred in the 21st minute and most of the other minutes had only one or two.
Q. I see what youre saying.
A. There was also one period around six to ten minutes where there was no gap at all. So
its not random.
Q. Okay. When you say its not random, do you mean its -A. Random means a throw of the dice did it.
Q. Okay. So because there are groupings, you feel that theres some causation?
A. Thats right.

Q. So if there was a mechanical problem of some sort, it would have to be a mechanical

problem that was more prevalent at one point?
A. Than the others, right.
MR. SANGER: All right. Okay. Thank you. No further questions.
MR. ZONEN: No further questions.
THE COURT: Thank you. You may step down.
MR. ZONEN: Your Honor, the next two witnesses require a Court ruling.
THE COURT: The Court will ad mit Exhibits 841 and 842 and make a finding that the
probative value exceeds the prejudicial effect under 352.
MR. ZONEN: Im sorry, I didnt hear the last part of your ruling.
THE COURT: It was just a finding under 352.
MR. ZONEN: And the finding was its admissible?
THE COURT: They are admissible. They are ad mitted.
MR. ZONEN: Thank you. Well call Detective Rose White to the stand, please.
MR. SANGER: Is there a limiting instruction that goes along with that, Your Honor?
MR. ZONEN: Smith. Im sorry, Smith.
THE COURT: We could do one.
MR. SANGER: Your Honor, would it be possible to approach briefly to discuss that?
THE COURT: Yes. (Discussion held off the record at sidebar.)
THE COURT: I think the next two witnesses are going to involve these exhibits, are they,
or the next one?
MR. ZONEN: The next one witness.
THE COURT: (To the jury) The next witness is going to involve testimony about two
books, Exhibits 841 and 842. And I want to advise you that these exhibits fall within the
same instruction I gave you regarding the 1108 evidence, Code Section 1108 evidence
relating to the alleged prior sexual acts.
Remember those instructions I gave you sometime ago? This material is connected to that
and has the same limitation. At the end of the trial, well reiterate that instruction for you
so that its -- this wont be the last time you hear the instruction.
MR. ZONEN: W ell call Rose Smith to the stand, Detective Smith, please.
THE COURT: Youve already been sworn. You may be seated.
DETECTIVE SMITH: Thank you, Your Honor.

ROSIBEL SMITH EXAMINATION

DIRECT EXAMINATION BY MR. ZONEN:
Q. The jury hasnt heard who you are yet. Youve already been sworn in, but tell us who
you are, please.
A. Yes. Im Detective Rosibel Smith. R-o-s-i-b-e-l. S-m-i-t-h. Im a police detective with
the City of Los Angeles, Los Angeles Police Department, currently assigned to the Threat
Management Unit of the Detective Support Division.
Q. How long have you been an officer with the Los Angeles Police Department?
A. For a little over 20 years.
Q. And your current assignment is what again, please?
A. The Threat Management Unit of the Detective Support Division, and we are responsible
for investigating stalking cases, criminal threats and workplace violence.

Q. How long have you been in that unit?

A. For six years.
Q. And prior to that, what work did you do?
A. Prior to that, I worked a station called Rampart Detectives, and then prior to that
Juvenile Divis ion.
Q. Have you worked as a sex crimes investigator?
A. Yes, I have.
Q. For what period of time?
A. For nine years.
Q. And which nine-year period?
A. From 1988 to 1997.
Q. As part of your responsibilit ies as a sex crimes investigator, did you conduct and
execute
search warrants?
A. Yes, I did.
Q. In August of 1993, did you execute a search warrant at Neverland Ranch in Santa
Barbara County?
A. Yes, I did.
Q. Did you do that with others?
A. Yes.
Q. A few others, I would assume?
A. There were several others, detectives and officers at the location, yes.
Q. And do you remember which -- where on the property at Neverland Ranch that you
personally conducted a search?
A. In the master bedroom of Mr. Michael Jacksons residence.
Q. All right. Now, the -- Id like you to look at three exhibits that are in front of you at this
time, Exhib it No. 841 and 842 already in evid ence.
A. Okay.
Q. Tell us what those two exhibits are. Lets start with the first one, 841.
A. 841 is a hard-cover book entitled, Boys Will Be Boys.
Q. And what is that a book of?
A. Its a book depicting images of young boys. Some are clothed. Some are nude. And
various stages of dress. Depicts them in various positions, at play, swimming, jumping.
So....
Q. Is there an inscription in the front of that book?
A. Yes, there is.
Q. Is that an inscription in a persons handwriting or printing?
A. Yes.
Q. Did you seize that book?
A. Yes, I did.
Q. From where did you seize that book?
A. From a file cabinet in the master bedroom of Mr. Jacksons residence.
Q. Now, Mr. Jacksons residence is a -- the bedroom portion of his residence is actually a
suite; is that correct?
A. Yes.
Q. Is there an upstairs and a downstairs?
A. Yes, there is.
Q. And the portion from where you seized these items, was that from the upstairs or the

downstairs?
A. It was from the downstairs portion of the bedroom.
Q. And can you -- can you tell us where specifically it was seized from?
A. It was seized from a file cabinet within a closet in the master bedroom.
Q. Lets go ahead to the next exhibit, 842, and tell us what that is, please.
A. This is another book, hard-cover book, entitled, The Boy; A Photographic Essay.
Q. Can you tell us what this is, please?
A. And again, this is a book depicting images of young boys, again in various stages of
clothing and undress. Some appear to be be nude. And again, various poses; playing,
swimming, jumping.
Q. Is there an inscription in the front of that book as well?
A. Yes.
Q. Now, Detective, those two items, were they seized from the same locat ion?
A. Yes, they were.
Q. And I think youve already described that location; is that correct?
A. Yes.
Q. Id like you to look at another exhibit thats before you, which is 856 in evidence.
A. Okay.
Q. What is 856?
A. 856 is a photograph of the search warrant. We, as law enforcement, are requ ired to
photograph the location that we serve the warrant on. And this is the photograph of the
file cabinet where the books were seized from.
Q. All right. And in that file cabinet, are there multiple drawers?
A. Yes, there are.
Q. Do you actually know from which drawer those books were seized?
A. Yes, I do.
Q. Which drawer was that?
A. They were seized from the third drawer.
MR. ZONEN: Your Honor, may I publish that exhibit? Its already in evidence.
THE COURT: Yes.
Q. BY MR. ZONEN: Describe for us, please, the photograph that were looking at.
A. To the rear of the photograph is the file cab inet containing the four drawers. The third
drawer is where I seized the books from. So its partly covered by, looks like maybe a
briefcase of some sort, or something there.
Q. All right. Detective, how were you able to get into the closet? How were you able to get
into the file cabinet?
A. The closet was -- actually, the room was locked. And we had to get keys for the room,
as well as for the file cab inet, to get access into the room and the file cabinet itself.
Q. Were you able to do that?
A. Yes, we were.
MR. ZONEN: Thank you. I have no further questions. You can turn the lights on.
MR. SANGER: Leave it. Leave it.
MR. ZONEN: Do you need this?
MR. SANGER: Yeah.
CROSS-EXAMINATION BY MR. SANGER:
Q. Detective Smith, how are you?

A. Fine, thank you, sir. How are you?

Q. You mentioned, Detective, that you were -- that youre currently assigned to a unit
with the Los Angeles Police Department that investigates a number of things, and I think
you said threats?
A. Yes.
Q. Okay. And one of the things you mentioned is stalking; is that correct?
A. Thats correct.
Q. And do you, in the course of your duties, investigate celebrity stalkings?
A. Yes.
Q. All right. And many times celebrities, in your experience, you find are stalked by fans;
is that right?
A. Yes.
Q. And is this -- does this pose a danger to the celebrities?
A. It could, yes.
Q. So you take those seriously?
A. Absolutely.
Q. In fact, somebody may claim to be a fan, and they come out -MR. ZONEN: Im going to object as exceeding the scope of the direct examination.
THE COURT: Sustained.
MR. SANGER: All right. Very well.
Q. Your assignment back in 1993 was working with the detectives division in sex crimes;
is that correct?
A. Yes.
Q. Thats Los Angeles Police Department?
A. Yes.
Q. So you got a warrant -- I say you. Your department got a warrant to search Mr.
Jacksons home in Santa Ynez, in Los Olivos, California; is that correct?
A. Thats correct.
Q. Thats not within the City of Los Angeles, I take it?
A. No, it is not.
Q. And you got a warrant issued by a Los Angeles judge?
A. Yes.
Q. All right. And the people that came with you at that time, among others, were fellow
Los Angeles police officers; is that correct?
A. Yes.
Q. And you ended up seizing these books that you talked about in the course of that
search in 1993; is that right?
A. That is correct.
Q. Now, these two books -- I think -- are they still up there in front of you?
A. Yes, they are.
Q. Those two books are not unlawful to possess by adults in California; is that correct?
A. That is correct.
Q. And do you have any idea how Mr. Jackson came into possession of those books or how
they ended up in this locked file cabinet?
A. From the inscription in Exhibit No. 842, it appears that possibly a fan, somebody named
Rhonda, possibly gave the book to him. And the other one, I do not know.
MR. SANGER: All right. Your Honor, may I approach and retrieve the books?
THE COURT: Yes.

MR. SANGER: Thank you. Your Honor, Id like to put the book up on the screen, if I may.
THE COURT: Yes.
Q. BY MR. SANGER: Ill put the cover up there, first of all. And it says, The Boy; A
Photographic Essay, and this is -- this is Exhibit 842, correct?
A. Yes.
Q. All right. You referred to the inscription, and Im going to put the inscription up on the
board. Im not going to put the whole one up because it doesnt fit yet. But in any event,
this is on the -- I know theres a word for it, but its on the first actual page of the book,
whatever you call it, right inside the cover; is that right?
A. Thats right.
Q. Okay. And you were -- based on this inscription, it appeared to be a book that was
presented to Mr. Jackson, or to his people, by a fan; is that correct?
A. It appears to be, yes.
Q. And then down at the bottom, it looks like it says, 1983, and that could be Chicago,
but I dont know. Or is it something else? What do you think?
A. I -- its really hard to read. It could possibly be Chicago, but Im not certain.
Q. But in any event, 1983 is the date?
A. Yes.
Q. At the time that you did this -- that you did this search in 1993, did you determine that
Mr. Jackson not only received, but kept a tremendous amount of material from fans that
was sent to him? Im not just talking about books, but just things in general that Mr.
Jackson received. Did he seem to have a lot of things that had been sent to him by fans, if
you can remember?
A. I do recall him -- or locating letters, notes, from fans.
Q. All right. So even back then, in 93, you were -- or I shouldnt say even. He had a lot
of fans sending him things. That was your understanding as you were doing this search; is
that correct?
A. Yes.
MR. SANGER: All right. Now, with the Courts permission, Id like to put up 841. Thats the
other book.
THE COURT: Yes.
MR. SANGER: If I may.
Q. And this is the cover. We cant get the whole thing on at once, but its 841 up in the
corner, for the record, and it says, Boys Will Be Boys, and it has a picture there; right?
A. Yes.
Q. Thats the cover. And by the way, this is a commercially -- both of these are
commercially availab le books; is that correct?
A. Yes.
Q. Okay. And when you open this book up, it actually says -- lets look right over here. Im
going to try to talk loudly while Im holding this. It says on the flyleaf, Book Adventures,
Inc., and the copyright 1966. Do you see that?
A. Yes. Down at the bottom.
Q. All right. And then if we look up here, at the top, again the first page -- Im sure
somebody who knows books knows the correct word for that. But the very first page, up
at the top it says, OP -- OP 88. That means Out of print, 88, does it not? Or do you
know?
A. Im not certain what that means.
Q. And somebody has written up there, Very scarce.

A. Yes.
Q. Do you see that? That was there on the book when you seized it; is that right?
A. Yes, it was.
Q. And theres some initials that look like MJ up in the upper right-hand corner?
A. Yes.
Q. Now, could you read the inscription for the record, please? And Ill move it up as you
go along.
A. Look at the true spirit of happiness and joy in the boys faces. This is the spirit of
boyhood, a life Ive never had and will always dream of. This is the life I want for my
children. MJ.
MR. SANGER: Thank you. I have no further questions.
MR. ZONEN: I have no further questions.
THE COURT: Thank you. You may step down.

IAN DREW EXAMINATION

MR. ZONEN: May his counsel sit at the counsel table?
THE COURT: Yes, for this hearing. Please remain standing and raise your right hand. Face
the clerk over here.
THE COURT: Counsel?
MR. ZONEN: May I proceed?
THE COURT: No, just a moment. Im sorry, I want to interrupt you. Im not sure that I
made that finding on the record or at sidebar on Exhibits 841 or 842, both of them, but I
previously had reviewed the books and made a finding, preliminary finding, that there
were photographs within each book that could be determined to be sexually explicit
photographs by a trier of fact, and then I made a finding on -- under 352, which I know is
on the record. Now you may proceed with this witness.
MR. ZONEN: Thank you, Your Honor.

DIRECT EXAMINATIONBY MR. ZONEN:

Q. Sir, what is your current occupation?
A. Editor at US Weekly Magazine.
Q. What does that mean? What do you do?
A. Everything from reporting on stories, to coordinating stories, to a wide array of
covering the celebrity news.
Q. How long have you worked in that capacity?
A. Um, about two and a half years.
Q. And how long with US Magaz ine specifically?
A. Oh, no. At US Magazine, two and a half years, excuse me. And in the capacity about
three and a half years.
Q. What is your -- are you a journalist?
A. Yes.
Q. What is your training and experience as a journalist?
A. I have about three and a half years experience. And I started working at a small

newspaper and then moved up to different publicat ions, and have been at US Weekly the
longest.
Q. If I can direct your attention back to February of the year 2003. Were you working with
or for Michael Jackson at that time?
A. No.
Q. Were you working for anybody who was working with or for Michael Jackson?
A. No.
Q. All right. Did you have any association with either Marc Schaffel or Ronald Konitzer or
Dieter Weizner?
MS. SAGER: Im going to object, Your Honor, to the extent thats calling for unpublished
informat ion. I think the question is vague.
THE COURT: They cant hear you. Is your microphone on?
MS. SAGER: Sorry, Your Honor. Im objecting to the question as calling for unpublished
informat ion and as vague.
THE COURT: Sustained on both grounds.
Q. BY MR. ZONEN: Were you called upon t conduct an interview of a family, includ ing a
mother of children by the name of Janet Arvizo?
A. No.
Q. Were you expecting to do an interview with Janet Arvizo?
A. Yes.
Q. Did that interview ever take p lace?
A. No.
Q. Who was it that was coordinating that interview with you?
A. Ronald Konitzer and Marc Schaffel.
Q. Did you know either Ronald Konitzer or Marc Schaffel prior to that day?
A. Yes.
Q. What is it that you were supposed to be doing with regards to this interview?
A. Interviewing them for a print magaz ine.
Q. Do you know what the subject matter was going to be of that interview?
A. How Mr. Jackson did not do anything inappropriate with the family.
Q. Who is it who retained you to do that?
A. Marc Schaffel and Ronald Konitzer.
Q. Were you expecting to get paid for that interview?
A. I did not get paid through them. I got paid through a magazine.
Q. All right.
A. I was on staff at a magazine at the time.
Q. All right. Was this an article that would appear in a magazine?
A. Uh-huh.
Q. Would it include photographs?
A. That was hoped for.
MS. SAGER: Object to the extent its unpublished information, Your Honor, since there
was not an interview published.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you ever meet with Janet Arvizo or her family?
MS. SAGER: Same objection, Your Honor.
THE COURT: Sustained.
Q. BY MR. ZONEN: Did you know who they were?
MS. SAGER: Same objection, Your Honor, to the extent that nothing has been published

on that subject.
THE COURT: Sustained. This is -- all objections are under the shield law at this time?
MS. SAGER: Yes, Your Honor.
Q. BY MR. ZONEN: Did you have a conversation with Ronald Konitzer as to whether or not
that interview would take place?
A. Yes.
Q. What did Mr. Konitzer tell you?
MS. SAGER: And, Your Honor, Ill only object to the extent that if it includes informat ion
that has not been published, that the witness should not be required to reveal anything
unpublished. To the extent that there has been published information on that, we are not
objecting.
MR. ZONEN: And let me preface the question with one other....
Q. Mr. Drew, did you appear on national televis ion and discuss this very topic?
A. I believe so.
Q. Was the national presentation through Court TV?
A. I believe so.
Q. Were you interviewed by someone by the name of Diane Dimond?
A. I was.
Q. Have you ever seen that presentation?
A. Yes.
Q. And you did recognize yourself as well as Miss Dimond?
A. Yes, I did.
Q. And did you discuss the subject matter of this very interview on national television?
A. I believe so. I believe so. Again, I do so many television interviews as part of my job,
so remembering what I said in each one is a little difficult, but I believe so.
Q. All right. Did you, in fact, discuss the reason why this interview was not going to take
place?
A. Yes.
Q. And what was the reason that the interview would not take place?
MS. SAGER: And again, Your Honor, I will only object to the extent that theres any
informat ion that has not been published. But to the extent Mr. Drew has revealed any
portion of that on national television, were not objecting.
THE COURT: So can I take this as an instruction by yourself to your witness to only
divulge material that hes previously divulged on television?
MS. SAGER: Yes, Your Honor. Thank you.
THE COURT: Ill accept that.
Q. BY MR. ZONEN: Can you answer the question?
A. I was told that the family was unavailable.
Q. And what does unavailab le mean?
A. I was told that they had disappeared from the ranch in the midd le of the night.
Q. And who had told you that?
A. Ronald Konitzer.
Q. In fact, he used the word escaped, didnt he?
MS. SAGER: Same objection, Your Honor.
MR. MESEREAU: Objection; lead ing.
THE COURT: Overruled.
MS. SAGER: Your Honor, we would object to the extent that the word -- whatever words
were used in the interview are the words that were used, and any other words should be

unpublished information.
MR. ZONEN: The objection was overruled?
THE COURT: Well, Im to take that as an instruction to the witness, because the objection
is -- its not really an objection. Shes saying, If something happened, I object. If not, I
dont. So I cant -MS. SAGER: I understand, Your Honor.
THE COURT: I could rule if it happened, okay? And if not, no. I think the better way is for
you to instruct your witness. And he knows, to the best of his recollection, what hes said
and what he hasnt said. And then if theres an issue there, well deal with it.
MS. SAGER: Thank you, Your Honor. And I would instruct Mr. Drew not to answer with
respect to any words that were not used in his discussion of what Mr. Konitzer said.
THE COURT: Do you have any idea what the question was youre supposed to answer?
THE WITNESS: Could you rephrase, please? Thank you.
Q. BY MR. ZONEN: What exactly did Ronald Konitzer tell you about the disappearance of
the
Arvizo family?
MS. SAGER: Again, Your Honor, with the same instruction to the witness, only to answer
as to what he said on national television on that subject.
THE COURT: Can we just -- can you give him that standing instruction that he would tell
you or indicate to you, or us, if were getting into an area he hasnt discussed, so you
dont have to keep interjecting yourself?
MS. SAGER: Thats fine, Your Honor. I dont know that Mr. Drew has a copy of the
transcript of the interview in front of him. And thats the only reason Im issuing this same
objection.
THE COURT: Go ahead.
MR. ZONEN: A ll right.
MR. MESEREAU: Excuse me. Your Honor, am I allowed to participate in this area of
objections? Im not sure.
THE COURT: Youre not sure?
MR. MESEREAU: W ell, I think I can. But I know youre trying to determine whats the
scope of the privilege. Im objecting to what hes saying for other reasons. And Im going
to object on hearsay as far as what he said on an interview.
MR. ZONEN: To the extent that they are statements from the unindicted co-conspirator,
Mr. Konitzer.
THE COURT: Well, I think -- hes asking me a question. Yes, you can object, because what
were testing here is what the jury will hear, of course, and then what you can crossexamine on. So if you object to something and it doesnt come in, theres not an issue
about cross-examination.
MR. MESEREAU: Okay. Thank you. Im objecting on hearsay.
MR. ZONEN: The answer is its a statement in furtherance of a conspiracy from one of the
unindicted co-conspirators, Mr. Konitzer.
THE COURT: I dont know what the question was now.
Q. BY MR. ZONEN: What specifically did he say with regard to the disappearance of this
family? Would it be helpful if the witness was given a transcript of the television program?
We can do that.
THE COURT: Well, you have to ask the witness that question. Thats the question that,
would it refresh your recollection if -MR. ZONEN: I dont believe hes -- well --

THE WITNESS: Its a simple enough question, I think. I was told that they had
disappeared; that they couldnt keep them there anymore.
MR. MESEREAU: Objection. Objection.
THE WITNESS: And -THE COURT: Just a moment. Let him complete it.
THE WITNESS: And I believe the word escaped was used, but again, I dont -- I cant
say word for word. But from -- the best of my recollection, yes, I heard the word
escaped.
THE COURT: Okay. Now, I made you wait, but you have an objection of hearsay.
MR. MESEREAU: Im objecting to double hearsay. What the prosecutor is asking is, What
did you say in an interview about what somebody else said?
MR. ZONEN: No, I d id not.
THE COURT: Hes asking what Mr. -MR. ZONEN: Konitzer.
THE COURT: -- Konitzer said. That is hearsay. Now, the question is, was it in the
furtherance of the conspiracy? I dont see that it is, so Ill sustain the objection.
MR. ZONEN: I ask to make an offer of proof.
THE COURT: Yes, you may.
MR. ZONEN: This was -- he was prepared to do the interview of the family, the interview
that ultimately was done on the evening of the 19th into the morning hours of the 20th by
a different interviewer, and this was going to be done in furtherance of the promotion of
the rebuttal film, the portion that was to be contained in the Maury Povich film. The family
took off. That was in conjunction with the movement off of Neverland Ranch about that
time. It was Mr. Konitzer who was attempting to arrange this, this filming, who then called
him and notified him that this filming would not take place because the family had
escaped. Its a reflection of the state of mind of the co-conspirator; that the family acted
in conformity with the testimony as we presented it. So the objection -- or the exception
to hearsay would be both a statement in furtherance of conspiracy, and a statement
consistent with the state of mind of the co-conspirator.
THE COURT: I dont get that. If the information is -- I mean, all of the things you said
could be in furtherance of the conspiracy, except we get to this one statement, which is,
basically, Wheres the family? Well, they escaped. That is -- thats not in furtherance of
the conspiracy. If anything, it might reveal the conspiracy.
MR. ZONEN: The fact that he says they escaped, they disappeared in the middle of the
night, reflects, as to Mr. Konitzer, a state of mind consistent with the fact that this family
was being kept there against their will, or at least as to the mother. So that would be an
admission on his part that the family, in fact, was being kept against their will. And to the
extent that that statement was made during the course of the conspiracy, which it was, it
was mid-February, then that statement would be an adoptive admission as to each of the
unindicted co-conspirators, including the defendant.
THE COURT: All right. You just changed horses in mid-stream.
MR. ZONEN: I sure did.
THE COURT: Do you want to address the -MR. MESEREAU: Yes, Your Honor. I mean, first of all, I think the Court has an obligation to
take into account the whole context of the statement, when it was made, and the purpose
that apparently it was made for, in decid ing whether it might even be reasonably
construed to be in furtherance of a conspiracy.
THE COURT: I think he conceded suddenly that its not in furtherance. Now hes asking

that it come in as an admission, some sort of admission.

MR. MESEREAU: No, its a hearsay statement by someone whos never been charged with
a crime, who isnt in the courtroom. Its not an admission. They didnt even charge any of
these people, except Mr. Jackson.
THE COURT: Dont -- wait, wait. Talk to me.
MR. MESEREAU: Its not an admission. Thats just grabbing for something that doesnt
exist. The only way it could possibly get in would be an except ion to the hearsay rule,
which the Court has, I think, found does not exist.
MR. ZONEN: If I could respond very briefly, Your Honor. Konitzers state of mind certainly
is an issue in this case as one of the unindicted co-conspirators named specifically in the
Indictment returned by the grand jury. To that extent it would be relevant. But it is also
admissible as either an admission, given the fact that he is an unindicted but named coconspirator, or a declaration against interest, specifically penal interest, if we were to
consider him as an unnamed party to this action.
MR. MESEREAU: Your Honor, again, hes not here. Hes not charged. Hes not present.
Hes not testifying. We cant cross-examine him. Its not an admission. And its clear
hearsay. If it cant come in under alleged co-conspirator hearsay by someone whos never
even been charged with a
conspiracy, it just cant come in.
THE COURT: Well -- just a minute. You know thats not the law. The law is that
statements by co-conspirators, whether theyre here or with us today or not, can come in.
Thats not the issue. Thats -- hes -- youre not addressing the issue. But just give me a
moment to think here.
MR. MESEREAU: Your Honor, if there was a co -THE COURT: Just a moment, please. Okay. I think what you were going to say is, if it
were a co-defendant and one co-defendants admission was attempted to be introduced in
a trial of both of them, that it couldnt be introduced in front of the jury. And I agree with
you, if it were any other crime but conspiracy.
MR. MESEREAU: But, Your Honor, I dont believe it would come in as an admission. I
believe it would come in under co-conspirator hearsay or it couldnt come in.
THE COURT: They either are trying to help you or they cant hear. (Laughter.)
MR. MESEREAU: Oh.
MR. ZONEN: I would object to the first of those choices.
MR. MESEREAU: W hat I said to Your Honor is in that event, it would not still co me in as an
admission. It would have to come in as an exception to the hearsay rule and be deemed
by the Court co-conspirator hearsay.
THE COURT: Well -MR. ZONEN: Can I ask -THE COURT: Im going to -MR. ZONEN: Can I ask this one question? If, in fact, among the overt acts -- if, in fact,
among the overt acts would be acts of this family leaving Neverland Ranch, and to the
extent that this person is one of the unindicted co-conspirators, and the overt acts include
their efforts to return the family to the ranch and to return the family to this video
presentation, then his statement that they had fled the ranch and escaped would certainly
be statements in furtherance of the conspiracy in terms of their efforts to renew their
activities to bring them back onto the ranch. It would also be an admission on the part of
a co-conspirator to the extent of what they were trying to do, and it would be a reflection
of that partys state of mind that thats what they wanted to do, was keep them on the

ranch until the point that they were able to do this particular interview, and thereafter to
Brazil.
MR. MESEREAU: I think I said what I can say, Your Honor. I dont think it can come in in
either event.
MR. ZONEN: And Ill submit as well.
MS. SAGER: And, Your Honor, we really dont have a dog in this fight. I want to make sure
the record is clear that -THE COURT: They cant hear you, so you have to speak into the microphone.
MS. SAGER: We dont have a dog in this fight, but I just want to make sure the record is
clear as to what this witness testified about was not the video interview of the family. He
was a mag azine reporter who was asking for an interview of the family. And I dont want
it to be confused with some conspiracy theory about what was or wasnt done with the
video and what they were doing with that. That is not what Mr. -THE COURT: Im not -- you have to have been here for 49 days or so. (Laughter.)
MS. SAGER: I understand, Your Honor.
THE COURT: Thats not a problem.
MR. ZONEN: W here does that metaphor come from? This is the second Los Angeles lawyer
talking about dogs and fights.
THE COURT: I dont know. Ive used it before. But after hearing someone chastised, Ive
decided Ill never use it again. I think its admissible as to the state of mind of the coconspirator, so Im going to allow it.
MR. ZONEN: Thank you. I have no further questions.
MR. MESEREAU: May I cross-examine, Your Honor?
THE COURT: Yes.
MR. MESEREAU: Okay. Thank you.
CROSS-EXAMINATION BY MR. MESEREAU:
Q. You gave an interview to Lieutenant Klapakis and another Santa Barbara sheriff named
Robel on August 4th, 2004, correct?
A. Yes.
Q. Do you know how long that interview was?
A. No. I didnt think it was that long, but it was probably a lot longer than it was.
Q. You waived privileges when you gave that interview, correct?
MS. SAGER: This is a question thats a legal question, not a question for this witness as to
whether he waived privileges. He did not have counsel. He had not been advised of rights.
THE COURT: Sustained.
Q. BY MR. MESEREAU: You gave that interview freely and voluntarily, correct?
MS. SAGER: Same objections, Your Honor. He was being served with a subpoena, had no
counsel.
THE COURT: Just a moment here. All right. As to the objection that he had no counsel
present, thats overruled. The question pending, which you may answer, is, did you give
that interview freely and voluntarily?
THE WITNESS: I guess. I didnt know it was an interview, and I didnt know that it was
being documented in any way.
Q. BY MR. MESEREAU: You were not served with a subpoena for purposes of that
interview, were you?

A. I dont know why I was served with a subpoena. I just got it in the mail.
Q. You did not attend that interview because you were subpoenaed to do so, right?
MR. ZONEN: Objection.
THE COURT: Maybe he doesnt know which interview youre talking about.
THE WITNESS: I didnt think I was attending any interview.
Q. BY MR. MESEREAU: Did you interview on August 4th, 2004, with Lieutenant Klapakis
and Sergeant Robel of the Santa Barbara Sheriffs Department?
A. I had a conversation with them.
Q. Where did the conversation take place?
A. Outside of my office.
Q. And did those two officers meet you outside of your office?
A. They did.
Q. Did you speak to them?
A. I did.
Q. You were not subpoenaed to speak to them, were you?
A. No.
Q. You spoke to them about facts concerning this investigation, true?
A. Yes.
Q. You told them you were a freelance journalist who was currently working for US Weekly
Magaz ine, right?
A. Thats not true. Ive only worked as a staffer at US Weekly.
Q. Did you tell them you were a journalist in that interview?
A. Yes.
Q. Did you tell them you were doing some work for US W eekly Magazine?
A. Yes.
Q. After you told them you were a journalist, you continued to interview with them, right?
A. Yes.
Q. You gave them statements about Marc Schaffel, true?
MS. SAGER: Your Honor, to the extent that this is unpublished information that Mr. Drew
has gathered in the course of his job as a journalist, I would still assert the shield law,
which applies unless he has published information. And the statute and the Constitution
specifically say, disseminated informat ion to the public. And Im quoting. So any
discussion he may have had with law enforcement officials would not fall within the scope
of published information as its defined in Article I, Section 2(b).
MR. MESEREAU: If I may respond, Your Honor.
THE COURT: Yes.
MR. MESEREAU: He gave a free, voluntary interview with two sheriffs. He knew they were
taking notes. He knew they were going to make a report. He knew it was part of this
investigat ion. He knew that the reports were likely to be circulated. They have been
circulated. They are not under any particular special form of privilege. They have been
produced to the defense. They are available to use at trial. He knew the information he
gave could be used in the investigation.
THE WITNESS: Thats not true. I didnt know any of that. I knew some of that.
MS. SAGER: Ian. Actually, I was going to object, Your Honor, but I was going to let Mr.
Mesereau finish first.
THE WITNESS: Okay.
MR. MESEREAU: He gave extensive information about Schaffel, Konitzer, his discussions
with them, his perceptions of them. And its very clear from the interview he knew exact ly

what he was doing.

MS. SAGER: And, Your Honor, I would point out two things. One is Mr. Mesereau, with due
respect, has not established any of the things that he just said as to what Mr. Drew knew
or didnt know. Hes merely asserted them. Second, were talking about a waiver of a
constitutional right, First Amendment right and state constitutional right. And I dont think
Mr. Mesereau has established either that Mr. Drew understood or had any reason to know
when he was in that conversation that there was later going to be a position taken that,
by talking to the police officers at all, that he was waiving his constitutional rights.
THE COURT: Are there any cases on this scenario where a person talks freely to the law
enforcement and then claims the shield law in court?
MS. SAGER: I dont know of a case in California, Your Honor, that deals with this particular
issue. The Playboy case, which we cited in our papers, does deal with the difference
between revealing informat ion publicly and any other information that may be related
thats not revealed publicly, and they draw a very strict line. The language of Article I,
2(b), talks about information that is disseminated to the public. Everything else is defined
as unpublished information.
THE COURT: What about -- I didnt read the Playboy case. What was the disclosure in the
Playboy case?
MS. SAGER: In the Playboy case, there was 8267 an interview published with Cheech and
Chong that had some information that they had given during the course of an interview
with a Playboy -THE COURT: But nobody understood what they said. (Laughter.)
MS. SAGER: Everybody bought it for the article, too. (Laughter.)
MS. SAGER: The argument was made, in subpoenaing all of the informat ion from Playboy,
that they had already revealed, in fact, what was said in the interview because they wrote
an article about it. And the Court of Appeal in the Second Appellate District said only what
is actually revealed in the article disseminated to the public has been revealed, even
though there were discussions with Mr. Cheech and Mr. Chong, even though there was
some information published.
THE COURT: Are you familiar with that case, Counsel.
MR. MESEREAU: I am not, Your Honor. But I would -- I havent completed my
examination of him yet, so I dont think -- I think its rather premature to conclude we
cant establish that he didnt know what he was doing or didnt know he was -THE COURT: The question, though, is what questions he has to answer right now while
youre trying to complete your examination. Thats the problem. And -MR. MESEREAU: W ell, Your Honor, if I cant cross-examine him on the issues he wants to
testify on direct about, then I dont think he should be allowed to testify as a witness.
MS. SAGER: And, Your Honor, Id only point out that we did not brief the issue of waiver,
because it did not come up, but theres certainly a long line of cases about the waiver of
constitutional rights needs to be knowing, not simply a voluntary conversation, but a
knowing waiver of your rights. And if Mr. Drew is asked, I expect he could answer the
question as to whether he knew and understood that, by any conversation he had with
these officers, he was waiving all rights he might have under the California shield law and
the Constitution.
THE WITNESS: Can I actually say, I was told by the officers and I actually had the
understanding that -THE COURT: Just a moment.
THE WITNESS: All right.

THE COURT: The way we have to do this is we rely on your attorney to help -THE WITNESS: Okay.
THE COURT: -- what she wants to bring out. You -- thats the -- you have a very
competent attorney, so I think you should -MS. SAGER: Thank you, Your Honor.
THE WITNESS: Thank you.
MS. SAGER: And I just would add, Your Honor, that I dont disagree with Mr. Mesereau
about whether Mr. Drew should have to testify at all. I do think getting into crossexamination will lead into areas that are covered by the privilege, which is the reason we
put that in our brief. It is a problem when you have reporters called as witnesses, because
even if one side tries to limit what they asking to published informat ion, it is inevitab le
the cross-examiner will attempt to get into other areas that are not published and that do
delve into reporters constitutionally protected informat ion.
MR. MESEREAU: If I may, Your Honor.
THE COURT: Yes.
MR. MESEREAU: There is information in the police reports that suggests that it was the
conclusion of the investigating sheriffs that Mr. Drew has been a business associate of Mr.
Schaffel. The Court already knows, because its in evidence, that he did conduct an
interview of Debbie Rowe at Mr. Schaffels residence, presumably at the
behest of Mr. Schaffel. And there is considerable evidence in the police reports that he has
relationships with Konitzer and others. Now, if hes going to be called to testify to what
Mr. Konitzer says to him, it would terribly prejud ice our ability to defend if we couldnt
extensively cross-examine on veracity, on bias, on a motive to make a statement for a
particular reason, and also his relationship with these people. If we cant do that, he
should be precluded from testifying.
MS. SAGER: And the problem again, Your Honor, is journalists have relationships with a
number of people. They may be getting information from a lot of different sources. And
the fact that they get information from people that they may later want to publish, thats
something that is tremendously protected under the First Amendment. And to allow
counsel to cross-examine into what informat ion he may or may not have gotten from
people who may have been confidential sources, may have been on-the-record sources
but were not ever published, really opens up the privilege widely, and for something that
in this case, frankly, is a tangential issue. And theres some question about whether this
particular statement has any relevance here, g iven that I dont believe its disputed that
the family left when they left, why they left. And the circumstances of that, are not within
this witnesss personal knowledge. So what his impressions were, what he interpreted the
remark to mean is not something that would be admissible. So the remark itself that they
left is really not all that important compared to the constitutional issues.
THE COURT: Actually, the substance of what he said is important. Thats not a good
argument. But -MR. MESEREAU: If the Court will permit, Your Honor, could we have a few minutes to try
to research that case? Because Im not -THE COURT: The Playboy case?
MR. MESEREAU: Yes.
THE COURT: Yeah, it wouldnt hurt for me to look at it.
MR. ZONEN: Do we need the actual evidence from that case?
THE COURT: Lets -MS. SAGER: As I said, Your Honor, we did not brief the issue of waiver extensively, so

were happy to do that for the Court if thats going to be an issue thats -THE COURT: That might not be necessary if each of us have a chance to look at the case.
Lets see. The next recess is scheduled for -- I dont want to make the same mistake I
made earlier, so why dont we just take our 11:30 recess, and then everybody who
doesnt have to read cases can eat. Okay? And well come back at the end of our 11:30
recess. (Recess taken.)
THE COURT: All right. You wanted time to look at that case?
MR. MESEREAU: I d id look at it, Your Honor. It deals primarily with civil matters,
obviously. And I think -THE BAILIFF: Can you turn your microphone on, please?
MR. MESEREAU: Pardon me I did look at the case, Your Honor, and I believe it clearly
deals with civil matters. I think what the Court in our discussion has identified are really
three issues to be analyzed. The Court did analyze the first issue, and that had to do with
the question of whether this was admissible or not. We did do a little bit of research. I
dont know if the Court will allow me to even address that again, or if you would, I wou ld
refer the Court to a local case called Saling, which holds that, Although it has been held
that statements which merely narrate past events are not to be deemed to be made in
furtherance of a conspiracy..., and then it does say that the Court has to do a balancing
analysis. The cite is 7 Cal.3d at 852. So we would certainly renew our objection to the
admission of the statement the witness purportedly wants to testify to. Number two, the
question is, does the shield law app ly? And if the shield law is deemed by the Court to
apply, I believe you still have to then do another balancing test to determine, in a criminal
trial, if the defendant, to get a fair trial, has a right to crack what is being shielded. And I
would refer the Court to the case of Delaney vs. Superior Court, 50 Cal.3d 785. Its a
1990 case. And you have a holding that, To overcome a prima facie showing by a
newsperson that he is entitled to withhold information under the shield law, a criminal
defendant must show a reasonable possibility the informat ion will materially assist his
defense. A criminal defendant is not required to show that the information goes to the
heart of his case. Now, I think the prosecutor has basically admitted that he thinks the
purported testimony goes to the heart of his conspiracy allegation. He believes it goes to
the heart of his conspiracy allegation as it appears in the Indictment and as it appears in
the alleged overt acts in the Indictment, according to the prosecutor. The question we
have, or the question for the Court is, if hes allowed to bring in this hearsay statement, or
I think the Court considered it an admission as well, what are we allowed to do if we want
to cross-examine him? And I think its pretty clear that the witness and his attorney are
attempting to preclude any type of examination into his relat ionships with the people he
wants to testify about, relationships which he identified and articulated to two police
officers. And I renew my claim that we would be severely hamstrung and prejudiced in our
ability t examine him for the truth of what he is saying and his motives for saying what
hes saying if we couldnt go into that. So where we are right now, Your Honor, is, I think
theres an argument that its shielded based on the case the Court read, but there is a far
stronger argument that the defense must go into that information if the witness is allowed
to testify. So perhaps the better solution, weighing all of these issues, is disqualify him
from testifying, and then there is no argument that the defendant is being unfairly
hamstrung in his ability to confront and cross-examine. And I dont think -- one thing I
will say to the Court, in his interview to the police, it appears as if hes giving all of the
informat ion.As I understand, a lot of these cases dealing with the shield law, they have to
deal with information gathered by the reporter that the reporter doesnt want to disclose.

Here, youve got police interviews where basically the police appear to be saying nothing,
giving him no information at all, and he is voluntarily allowing himself to be interviewed,
near his place of business, about Schaffel, about Konitzer, et cetera, about the Arvizos.
THE COURT: But, see, thats the material hes gathered. Its not -- he wasnt gathering
from the police, or if he tried, he apparently failed. He was -- he had already gathered his
informat ion, and he was telling the police what hed gathered.
MR. MESEREAU: Uh-huh.
THE COURT: And -MR. MESEREAU: But it does involve more than that, Your Honor. He admitted to the police
working out of Schaffels home for weeks, for example. Things like that are part of that
interview and are part of the information his lawyer wants to shield. And it would just -- it
would just eviscerate our ability to probe and test for credibility on cross-examination if
we couldnt go into those relationships and that information. THE COURT: Well, under
Delaney, you have to show -- the defense has the burden of showing that the information,
the unpublished information that he has, would materially assist the defense. And -MR. MESEREAU: As I just said, Your Honor, I believe the holding is just if we show a
reasonable possibility it will help us to assist the trier of fact in determining whether this
witness should be believed or whether this witness has a motive to lie or a motive to gain
financially by appearing in this trial, by saying what hes saying, given his past
associations, his past admissions and statements to various people. If we cant go into
that, we are severely prejud iced.
THE COURT: Well, what is the information that you claim that he has that would materially
assist the defense? And it says you must make a specific showing that the nondisclosure
would create a substantial probability of injury to the defendants right to a fair t rial. What
is that information that you think is that valuable?
MR. MESEREAU: His relationships with Konitzer; when he met him; how many times he
spoke to him. Did he have any financial connection with Konitzer? To his knowledge, was
Konitzer involved with Schaffel when he was involved with Schaffel? What business
relationship or financial relat ionships did he have with these two people? Why was he
trying to get information from them? What did he intend to do with the information? When
did he last talk to them? Did he, in fact, talk to the police voluntarily and give information
to try and be part of this case, because he is a journalist and he can profit that way? I
mean, there are lots of questions that I would want to go into about his relationship
THE COURT: Theres lots of questions, but the -- what is the information you would get
that would -- its not the questions that prove the point. Its the answers.
MR. MESEREAU: Yes. Yes. Well
THE COURT: So what are you offering -- what are you proffering to me in the way of
informat ion he has? Not questions you have.
MR. MESEREAU: Hes had a falling-out with Schaffel, who he had a business relationship
with. He worked out of his house for three weeks. He saw a contract at Schaffels saying
Schaffel was going make millions of dollars. He was not allowed to participate in that. He
had a falling-out with Konitzer. Is he now trying to basically assist the prosecution in
incriminating Konitzer? He has a lot of relationships with these two characters that I would
think we have to be able to go into to show his motive to lie.
THE COURT: Youre making an offer of proof that those facts are -- if he were forced to
testify, he would say that he had not been able to enter into multi-million dollar deals with
them, et cetera, et cetera?
MR. MESEREAU: W ell, he may deny it. But if he does, I would explore it further and show

hes not telling the truth.

THE COURT: Okay. Well, what I want to know is what you know he has to say, not what
you suspect from your questions.
MR. MESEREAU: Well, Your Honor, Ive never interviewed him.
THE COURT: You have the police interview.
MR. MESEREAU: Yes, I do.
THE COURT: That would be of some assistance, I would think.
MR. MESEREAU: Yes, Your Honor. He worked out of Schaffels residence for approximately
three weeks. He learned that Schaffel was trying to enter into a contract with FOX for $7.5
million regarding the Rowe interview. He conducted the Rowe interview. He told the police
the Rowe interview was not scripted. He apparently didnt make any money off of the
Rowe interview and apparently wanted to. He had -- he met Konitzer, who was also
involved in the Rowe interview. He had a relationship with Konitzer. They apparently
talked on a number of occasions. He was in Florida with these individuals.
THE COURT: I think what we should do is -- you know, some of those things may not be
subject to the shield law. Some may. The District Attorney has finished his examination.
Ive made the ruling, which Im not changing, on the state of mind that -- so now the
question arises under Delaney. So, in order to find out where we really are under Delaney,
I think you have to ask the witness some questions, and we have to see which ones he
answered and which ones he claims are unpublished and he has a privilege, and Ill have
to look at the case from that standpoint.
MR. MESEREAU: Okay.
MS. SAGER: And the only thing I would like to add, Your Honor, is under the Delaney test,
the test that -THE COURT: You need to -MS. SAGER: Im sorry, Your Honor. Im not used to using these microphones. Under the
Delaney test, its not only the threshold test, which is what Mr. Mesereau presented, of
whether the information sought is reasonably likely to materially assist the defense. Thats
simply the threshold. Assume he gets past that. Then the Court engages in a balancing of
all the other factors in Delaney. Its not simply enough that he meet that one test.
THE COURT: Thats right. Then we look to see the balance, I agree. So you may question.
MR. MESEREAU: Thank you, Your Honor.
Q. Mr. Drew, do you know someone named Marc Schaffel?
A. I did.
Q. You did?
A. Uh-huh.
Q. When did you first meet Marc Schaffel?
MS. SAGER: Your Honor, Id object to the extent that reveals unpublished information.
And also point out, Your Honor, that really has very little relevance to the one statement
that Mr. Drew has been asked about by the prosecution that was published. Youre now
talking about an entirely different individual, not even the ind ividual that he has spoken to
that he talked about in his interview.
MR. MESEREAU: W ith all due respect to counsel, thats not true, Your Honor. I will link the
relationship he has with Schaffel and Konitzer to the impeachment Im trying to
demonstrate. But I could ask the questions on Konitzer, and Ill see if hes going to assert
the privilege to those. Maybe that would narrow it. Shall I do that, Your Honor?
THE COURT: Let me think. Hes already testified that the -- that he was working for
Konitzer when he did the interview, right?

MS. SAGER: Actually, I dont believe thats 8281 correct. I believe he testified he was
working for a magaz ine and the interview was set up through Mr. Konitzer and Mr.
Schaffel, not that he was working for them. And in fact, I think he testified -- and counsel
will correct me if Im wrong. I believe he was asked was he paid anything by them, and he
said no. Nor was he working for Mr. Jackson at any point.
THE COURT: All right. For purposes of where we are in the hearing, Ill sustain the shield
objection on that question.
Q. BY MR. MESEREAU: Do you know someone named Ronald Konitzer?
A. Yes.
Q. And how long have you known Ronald Konitzer?
MS. SAGER: Same objection, Your Honor, to the extent that thats not been published, the
extent of the length of their relat ionship or knowledge. Simply the fact that he knows him
has been published.
THE COURT: Well, I think I need you to be more clear in your objection. Youre saying to
the extent that that has not been published. I mean, you have to make a claim that
thats not been published; that, Your Honor, that has not been published, so I know
that. I dont really know that, the way youre stating it.
MS. SAGER: I apologize, Your Honor, and the only reason Im couching it the way I am is
because Mr. Mesereau seems to believe that some things are publications which I dont
agree with and the Court hasnt ruled on. There is an interview that does not contain the
informat ion that Mr. Mesereau is asking about and thats the publication that were looking
at. That information is not published, as far as Im aware.
THE COURT: Well, I dont think you can limit it to that interview. I mean, if hes published
it anywhere, in any magazine, or any news, or T.V., or -- you know, the definit ion really
doesnt even involve media. If its -- I guess if its dissemination to the public, he could do
it personally walking around the mall over there. So we have to -- when you claim hes
being asked to reveal something that he hasnt published, it has to be he hasnt published
it. Not that he didnt talk about it in the interview with the -- which interview are we
talking about?
MS. SAGER: The Court TV interview, Your Honor.
THE COURT: The Court TV interview that he was interviewed on. That is not the only place
that he could have published. He may have published it nowhere else, but we need to be
clear. We arent limiting this to that.
MS. SAGER: I understand, Your Honor. And so my objection is that Mr. Mesereau is calling
for information which is unpublished within the meaning of the shield law.
THE COURT: All right. For purposes of this hearing right now at this point, just to see
where were going, I will sustain the claim under the shield law.
Q. BY MR. MESEREAU: When did you first meet Ronald Konitzer?
MS. SAGER: Same objection, Your Honor. Thats unpublished informat ion.
THE COURT: All right. For purposes of this hearing right now, Ill sustain that claim under
the shield law.
Q. BY MR. MESEREAU: Where did you first meet Ronald Konitzer?
MS. SAGER: Same objection, Your Honor.
THE COURT: All right. And Ill make the same ruling for purposes of this hearing.
Q. BY MR. MESEREAU: When you first met Ronald Konitzer, who else was present?
MS. SAGER: Same objection, Your Honor.
THE COURT: Ill sustain the objection under the shield law.
Q. BY MR. MESEREAU: When you first met Ronald Konitzer, in your mind, what was the

purpose of the meeting?

MS. SAGER: Same objection, Your Honor. Also that Mr. Drews state of mind is not at
issue here.
MR. MESEREAU: I think it is on cross, Your Honor.
THE COURT: Ill sustain it under the shield law.
Q. BY MR. MESEREAU: How many times have you met with Ronald Konitzer?
MS. SAGER: Same objection, Your Honor, as to unpublished information.
THE COURT: Ill sustain the objection under the shield law.
Q. BY MR. MESEREAU: Have you ever discussed Michael Jackson with Ronald Konitzer?
MS. SAGER: And I would object to the extent that it seeks information that has not been
published.
THE COURT: Thats an insufficient objection. Ill overrule it.
MS. SAGER: I understand, and the only reason Im couching it that way is the question, as
phrased, is ambiguous. But Ill object to the question as calling for information that is not
published.
THE COURT: All right. Ill sustain that under the shield law for this hearing.
Q. BY MR. MESEREAU: Have you ever had a discussion with Ronald Konitzer about the
possibility of interviewing the Arvizo family?
A. Yes.
Q. When did that discussion take place?
A. It took place the week after the Debbie Rowe interview.
Q. When was the Debbie Rowe interview?
A. I believe, from my recollect ion, it was March of 2003.
Q. Were you at the Debbie Rowe interview?
A. Yes, I did the Debbie Rowe interview.
Q. Are you the person who asked Debbie Rowe questions in that interview?
A. Yes.
Q. Youve told the police that interview was not scripted, correct?
MS. SAGER: Your Honor, and Id again object that this is not published information.
MR. ZONEN: And I would also interject an objection that it exceeds the scope of the direct
examination.
THE BAILIFF: You guys have to use the microphone.
MR. ZONEN: I would object that it exceeds the scope of the direct examination.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Was the Debbie Rowe interview scripted?
MS. SAGER: Same -MR. ZONEN: Objection; exceeds the scope of the direct examination.
4 MS. SAGER: Also unpublished, Your Honor.
THE COURT: Sustained on both grounds.
Q. BY MR. MESEREAU: Was Ronald Konitzer at the Debbie Rowe interview?
MS. SAGER: Objection, Your Honor. Calls for unpublished information.
THE COURT: Sustained under the shield law.
Q. BY MR. MESEREAU: Now, you said, in response to the prosecutors questions, that Mr.
Konitzer referred to the Arvizo family leaving Neverland Ranch, right?
A. Yes.
Q. And your first response to the prosecutors question was that Konitzer told you that
they had disappeared from Neverland Ranch, correct?
A. Yes.

Q. After being further asked questions by the prosecutor, you said that Konitzer had used
the word escape, right?
A. I said I believed he had used the word escape. I remembered it.
Q. You didnt use the word escape when you first responded to the prosecutors question
about what Mr. Konitzer had said, right?
A. I think I did. I think it was all within 8287 the same sentence, from my recollection.
Q. You said disappear, did you not?
A. That was part of it, too.
Q. Now, how long did your discussion with Konitzer take place on that particular occasion?
MS. SAGER: Objection, Your Honor. Calls for unpublished information.
THE COURT: All right. Sustained under the shield law.
Q. BY MR. MESEREAU: Were other things said by Mr. Konitzer to you on the occasion
when you claim he made that statement?
MS. SAGER: Same objection, Your Honor. Calls for unpublished informat ion.
THE COURT: Sustained.
Q. BY MR. MESEREAU: How long did that discussion last?
MS. SAGER: Same objection, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you say something to Mr. Konitzer in that discussion?
MS. SAGER: And Ill object, Your Honor, to the extent that it calls for informat ion that has
not been published. It was one word, I believe, Mr. Drew has published, which Ill let him
answer.
THE COURT: All right. Answer the one, the word, following your attorneys instructions.
MS. SAGER: If you recall. 8288
THE WITNESS: I dont. I dont remember.
Q. BY MR. MESEREAU: Where did the discussion take place?
MS. SAGER: Same objection, Your Honor. Calls for unpublished informat ion.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Who else was there with you and Konitzer?
MS. SAGER: Same objection, Your Honor. Also assumes facts not in evidence.
THE COURT: Under the shield law objection, Ill sustain the objection.
Q. BY MR. MESEREAU: Was anyone else there with you and Mr. Konitzer?
MS. SAGER: Calls for unpublished information, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you arrange for the discussion where you claim Mr. Konitzer
made that statement?
MS. SAGER: I believe its vague, Your Honor, but its information that is published, so Ill
let the witness answer, if he recalls.
THE WITNESS: Yes, I was trying to get an interview, so I think I -- I think I made the
phone call, because Im pretty dogged about that usually.
Q. BY MR. MESEREAU: Where were you when you made the phone call?
MS. SAGER: Calls for unpublished information, Your Honor.
THE COURT: Sustained.
Q. BY MR. MESEREAU: Did you call Konitzers number?
MS. SAGER: Same objection, Your Honor.
THE COURT: Sustained.
MR. MESEREAU: Your Honor, I believe at this point its pretty clear I wouldnt be able to
cross-examine the witness on any of this; we would be prejudiced. And I believe, under

the Delaney case, the witness should be disqualified from testifying. Im not being allowed
to cross-examine on anything regarding the bona fides of what he said and in what
context it was said, who was there, where it took place. And again, I would refer the Court
to the holding in the Delaney case. All we have to show is a reasonable possibility the
informat ion will materially assist the defense. And the material assistance would be in
examining the veracity, the motives, the bias of this witness.
MS. SAGER: And, Your Honor, I believe under the Foss case, that disqualificat ion of the
witness is the appropriate measure to take rather than allowing any counsel to get into
informat ion that clearly is protected by the shield law, so that even published information
should not be presented if then, to allow cross-examination, would delve into
constitutionally protected information.
THE COURT: Mr. Drew?
THE WITNESS: Uh-huh.
THE COURT: Im looking at the testimony youve already given. What I want to do is read
to you what you said about the -- just that one sentence is all were talking about. I want
to read to you that sentence, and I want to ask you a couple of questions about why you
said that sentence.
THE WITNESS: Okay.
THE COURT: But to do that, I want to read it to you, so Im going to ask you to listen to
this: The question by Mr. Zonen was, What specifically did he say with regard to the
disappearance of this family? Would it be helpful if the witness was given a transcript of
the television program? W e can do that. I say something, and then Mr. Zonen says
something. And then Mr. Zonen says, Well, as a question mark, and you say, Its a
simple enough question, I think. I was told that they had disappeared, that they couldnt
keep them there anymore. Theres some objections. And you say, And I believe the
word escaped was used. But again, I dont -- I cant say word for word. But from the best
of my recollection, yes, I heard the word escape. First of all, what youve already
answered, does that accurately reflect your recollection of that conversation?
THE WITNESS: Uh-huh. Yes.
THE COURT: What is your -- if you can answer this, what is the failure of your recollection
about the word escaped?
THE WITNESS: No, its to the best of my recollection. When I was talking to Mr. Konitzer,
I was simply trying to get -- I was on a deadline trying to get an article done, so I wasnt
paying attention word for word, knowing that in a trial two years later I would have to
remember each part of it. I remember the tone of his conversation more than I remember
even the exact words.
THE COURT: Okay. Thanks. Mr. Mesereau, is there anything in the police reports that you
have that you would like to represent to me -MR. MESEREAU: First of all, Your Honor, as the Court knows, in many of my prior crossexaminations of witnesses, I have asked them when they -- excuse me, if they ever met
with any representative of the Santa Barbara Sheriffs Department; who initiated the
meet ing; what was said; who said what; did the sheriffs say anything to you about the
case? And the reasons are obvious. We want to establish if, in fact, the prosecution or its
agents have tried to infect any witness with information of a specific nature or give them a
perspective on the case or try and indoctrinate them in some way. We also want to
establish if the witnesses have said anything to the sheriffs which suggests a desire to be
involved in this case or a desire to -THE COURT: I think you didnt let me finish my question.

MR. MESEREAU: Oh. Im sorry. Pardon me.

THE COURT: The question I wanted to ask, is there anything in the police reports that he
said in the interview with the sheriffs department or any law enforcement people that you
want to show me or advise me of? You know, as opposed to the questions that you would
ask, any information contained therein that you believe is, you know, material that would
-MR. MESEREAU: Yes, Your Honor. I mean, first of all -THE COURT: -- materially assist your defense if he were to testify to it?
MR. MESEREAU: Yes, Your Honor. There is the business relationship between this witness
and Schaffel and Konitzer, as I would like to establish, is that he had a relationship with
them. He was invo lved in their efforts to make money off of Michael Jackson. The
THE COURT: Thats -- just to be clear now, thats in the police report?
MR. MESEREAU: Yes, Your Honor. He conducted the Debbie Rowe interview. He was
working out of Schaffels residence. He was promised he could interview the Arvizo family.
He had a financial interest in working with Schaffel and Konitzer. He then was apparently
told, Youre not going to be interviewing the Arvizo family because they left Neverland.
And then the question is, what kind of relationship did he continue to have with them?
What money did he expect to make? Who was supposed to pay him for doing all of this?
Did he think he was going to be involved in the FOX contract? He did tell the sheriffs that
he saw, in fact, a FOX contract at Schaffels residence during the approximately threeweek period of time that he worked out of Mr. Schaffels residence. And the question
would be, why d id he look at the contract? How did he know it said $7.5 million from FOX?
What interest did he think he had? Has he had a falling-out with Konitzer? When did he
last talk to any of these people? He did not obtain this so-called quote in isolat ion, and he
didnt obtain it in a casual, unexpected occurrence or meet ing. He obtained it, if he d id,
within the context of an ongoing business relationship with Konitzer and Schaffel, who the
prosecution allege are unind icted co-conspirators. And the motives for coming forward and
making this allegation on T.V. and in court are fertile ground for cross-examination where
the scope of cross-examination is very broad to show any type of financial motive,
financial b ias, or a bias to say anything that hurts his former co-business partners, which
in fact they were. So we would be severely hamstrung if we could not go into thes e
relationships and these motivations. Now, he told the police that when he interviewed
Debbie Rowe, he was working out of Schaffels residence for approximately three weeks.
He said that during that period of time, he saw the FOX contract. He just told the Court
that when he got this information from Konitzer, he had a deadline. How did that deadline
relate to why he was talking to Konitzer to begin with? What project were they still
involved in, if any? And clearly his police interview, which was conducted by him, as I said
before, on a voluntary basis, talks about how he met these characters, how he stayed in
contact with them, where he called them from, how the interview with the Arvizos he
thought he was going to do related to the interview with Debbie Rowe. Its all part of the
same package. And, Your Honor, there are tapes where he and Debbie Rowe complain
about Schaffel and Konitzer. There is the issue of his falling-out with them. Its all
interconnected.
THE COURT: Okay. Do you want to be heard, Mr. Zonen?
MR. ZONEN: Your Honor, the police report in this matter is four pages of text, and I think
it would be appropriate for the Court to review it, and I would invite the Court to review it
to make the determination as to whether -- would you like me at the podium?
THE COURT: Yes.

MR. ZONEN: The Court specifically made the inquiry as to whether or not theres
informat ion contained in the police report as might justify extensive cross-examination of
this witness with regards to information given by the witness to detectives in the course of
that interview. Rather than debate what is and what isnt, its a very brief report. Its only
four pages of large script. And I would ask that the Court read it to make a determination
as to whether or not that would assist the Court in its judgment. Once again, the
prosecution is offering one sentence in this case. Its a conversation that took place
between this witness and another person, one of the unindicted co-conspirators, to the
extent this that person said to this witness, Theyve left, and the words of how they left.
Its effectively one or two sentences. I do not believe that that warrants and justifies
extensive cross-examination on the relationships and interrelat ionships between each of
the five un indicted co-conspirators and this witness and any of the co-conspirators among
themselves at any point in h istory. I also dont believe it justifies an examination into his
involvement in the interview with Debbie Rowe, which was an entirely separate interview
and separate people involved. As to the question of what he can be cross-examined on in
the course of the interview with the -- the interview -- the two-sentence conversation
with Mr. Konitzer, I think that he can be cross-examined on information that would shed
light on what was going on at that time and the accuracy of that statement, and it is a
statement that is relatively noncontroversial. It is not the type of thing that a thorough
examination of the relationships of these parties would necessarily disprove or as to
motivat ion. And so I believe that until the defense satisfies the burden, which they have,
for the purposes of showing that there is information out there, and theyre not simp ly on
a fishing 8297 expedition, but that there is concrete information that would somehow
show that this statement was never made, or, if it was made, had a different meaning, or
in fact was a statement thats entirely different from what it was as its represented by
this witness, and I believe that they can do that within the limitations of the Court and
within the limitations imposed by the shield law. I have the report to turn over to the
Court, if thats permissible.
MR. MESEREAU: If I may, Your Honor, there are other reports as well. Theres a number
of pretext phone calls where he discusses the same issues identified in that police
interview. I suspect Miss Sager is going to say theyre privileged, but they do relate to the
same facts. They give us a good-faith basis, in addition to what I just told the Court, to
inquire into his relationship with Konitzer and Schaffel, and what his expectations were,
what happened to the money he thought he was going to get, et cetera. I think the Court
would have to look at those as well. There arent that many of them and I have them with
me. I also have transcripts of those pretext phone calls.
THE COURT: And do both of you agree and stipulate that I can review those reports in
conjunction with reaching a decision on this?
MR. ZONEN: Yes.
MR. MESEREAU: Yes, Your Honor.
THE COURT: All right. Would you provide those to me?
MR. MESEREAU: Yes.
MS. SAGER: Your Honor, we have not been provided with those reports, and for purposes
of arguing this motion, it would greatly assist me, if the Court is going to consider them, if
we also were allowed to review them.
THE COURT: Certainly.
MR. ZONEN: I will do so.
THE COURT: You can step down. Theres no sense in sitting there while were trying to

figure this out.

MR. ZONEN: How clean are your copies?
MR. MESEREAU: Theyre pretty clean.
MR. ZONEN: Do you just have yellow high lights?
MR. MESEREAU: Yeah, but also -- there are transcripts as well.
MR. ZONEN: You dont have material written into them?
MR. MESEREAU: Not really, no.
MR. ZONEN: Okay.
MR. MESEREAU: It may take a mo ment. Im just trying to staple these reports together,
Your Honor.
THE COURT: All right. I think what Id like to do, Lieutenant, would it work all right, when
I take these back to read, if I declare a recess? And then you can -- so these folks dont
have to sit in here? Is that all right? And then we can bring them back in. It looks like Im
going to be a few minutes reading.
LIEUTENANT McKINNY: Thats fine, Your Honor.
THE COURT: That would give them five minutes notice to bring them back into the
courtroom, or let them, excuse me, back in the courtroom.
MR. MESEREAU: Your Honor, I might add that this witnesss name comes up in other
reports dealing with interviews with other individuals and investigations into other
individuals. Information regarding this witness was seized at Schaffels house, for
example. So I dont want to suggest that the scope of examination or the good-faith basis
for questions about his relationship with these people are purely based on what Im g iving
you. Theres other stuff, too.
THE COURT: Okay.
MR. MESEREAU: May I approach?
THE COURT: Yes. All right. Then well take this recess.
THE COURT: Counsel, would you like to retrieve the police reports?
THE BAILIFF: I can get them.
MR. MESEREAU: Thank you, Your Honor.
THE COURT: All right. The Court is going to make the following order: That the Court finds
that the probative value of the statement offered by Mr. Drew is questionable; that if the
statement was introduced into evidence, the statement might lend itself to proving
somewhat the conspiracy, but the only value I see of the statement -- the only evident iary
value of the statement would be to prove Konitzers state of mind, which is not Mr.
Jacksons state of mind, and may very well not be appropriate to admit under any
circumstances. Because even though its a co-conspirators state of mind, it would be
unlikely helpful in proving Mr. Jacksons involvement. It wouldnt prove his involvement.
In addition to that, there is some real vagueness in the statement as recalled by the
witness, since he does not recall exactly what was said, but more the sense of what was
said, and isnt sure where the word escaped fit in. Considering these items, in balancing
under Delaney, the Court does not believe that the shield law is overcome in this case.
The shield law then remains in effect. That effectively bars the defense from crossexamination on the statement which Ive already determined to have some questionable
value. Therefore, the Court finds the only appropriate remedy is to deny the Peoples
request to admit the statement.
MR. ZONEN: Your Honor, we have no further witnesses for the day.
THE COURT: What I would like to do is excuse the jury. Theres two ways to do that.
Probably the cruelest way would be to --

MR. ZONEN: Send the bailiff in there?

THE COURT: -- file them in here and then tell them. In fact, I dont think I could face
them. (Laughter.)
THE COURT: No, I better face them, though. Lets bring them in.
MS. SAGER: Your Honor, is Mr. Drew excused?
THE COURT: Ill be a man about this. Yes. Youre excused.
MS. SAGER: Thank you.
THE COURT: Its my custom to not be on the bench when the jury comes in, so I think Ill
leave.
(The following proceedings were held in open court in the presence and hearing of the jury

THE COURT: Good afternoon.

THE JURY: (In un ison) Good afternoon.
THE COURT: (To counsel) You tell them. (Laughter.)
THE COURT: Because of rulings that Ive made today, we have no further witnesses. I am
advised by the District Attorney that they have two days left in their case, Monday and
Tuesday, and they will be full days, without delays. So I apologize for keeping you here all
day today like this. I didnt anticip ate, of course, the length of time that was going to be
involved, and I tried very hard not to do that to you. I know how crummy it is to sit back
there and not have anything to do and not know whats going on, and its just one of my
things I just dont do. And we have gone through a lot of days without doing that to you,
so Ill try to get through a lot more before it happens again. So Ill see you next week.
Courts in recess. (The proceedings adjourned at 1:25 p.m.)