Electronically FILED by Superior Court of California, County of Los Angeles on 02/19/2021 03:12 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by B. McClendon,Deputy Clerk

1 KINSELLA WEITZMAN ISER KUMP LLP

Howard Weitzman (SBN 38723)
2 hweitzman@kwikalaw.com
Jonathan P. Steinsapir (SBN 226281)
3 jsteinsapir@kwikalaw.com
Suann MacIsaac (SBN 205659)
4 smacisaac@kwikalaw.com
Aaron Liskin (SBN 264268)
5 aliskin@kwikalaw.com
Katherine T. Kleindienst (SBN 274423)
6 kkleindienst@kwikalaw.com
808 Wilshire Boulevard, Third Floor
7 Santa Monica, California 90401
Telephone: 310.566.9800
8 Facsimile: 310.566.9850

9 Attorneys for the Defendants

MJJ Productions, Inc. and MJJ Ventures, Inc.
10
KINSELLA WEITZMAN ISER KUMP LLP

TEL 310.566.9800 • FAX 310.566.9850

11
808 WILSHIRE BOULEVARD, 3RD FLOOR

SUPERIOR COURT OF THE STATE OF CALIFORNIA

SANTA MONICA, CALIFORNIA 90401

12 COUNTY OF LOS ANGELES

13

14 WADE ROBSON, an individual, Case No. BC 508502

[Related to Case No. BP 117321, In re the
15 Plaintiff, Estate of Michael J. Jackson (deceased)]
16 Assigned to the Hon. Mark A. Young,
vs. Department M (Santa Monica Courthouse)
17
DEFENDANTS MJJ PRODUCTIONS
18 MJJ PRODUCTIONS, INC., a California AND MJJ VENTURES’ EVIDENTIARY
corporation; MJJ VENTURES, INC., a OBJECTIONS TO THE DECLARATION
19 California corporation; and DOES 4-50, OF ALEX E. CUNNY AND EXHIBITS
inclusive, THERETO
20
Defendants. [Reply Brief and [Proposed] Order re
21 Evidentiary Objections Filed Concurrently
Herewith]
22
Date: February 24, 2021
23 Time: 8:30 a.m.
Dept: Dept. M
24
Action Filed: May 10, 2013
25 Trial Date: June 14, 2021
26

27
28

10386-00226/726738.3
EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.
 1 DEFENDANTS’ EVIDENTIARY OBJECTIONS TO THE

2 DECLARATION OF ALEX E. CUNNY, ESQ.

4 Objection No. 1

5 Exhibit 22 attached to the Cunny Declaration and identified in Paragraph 26 of the Cunny

6 Declaration as a “copy of the statement that Mary Coller-Albert provided to the Los Angeles

7 Police Department”. (Cunny Decl. at ¶ 26 (page 7, lines 23-24), Ex. 22.)

8 Grounds for Objection No. 1:

9 Hearsay (Evid. Code § 1200): The document is being offered for the truth of matters stated

10 therein. The document is double hearsay in that it purports to be a government official’s summary
KINSELLA WEITZMAN ISER KUMP LLP

11 or transcription of statements allegedly made by another person in the course of a (meritless)

TEL 310.566.9800 • FAX 310.566.9850
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

12 criminal investigation. Witness statements taken in criminal investigation are, quite literally, the

13 most classic example of inadmissible hearsay. See Crawford v. Washington, 541 U.S. 36, 40, 43-

14 44, 51-52 (2004) (discussing history of hearsay rule arising from right of confrontation of

15 witnesses in criminal proceedings); People v. Jaramillo, 137 Cal.App. 232, 235 (1934).

16 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

17 for how he has personal knowledge that the document is what he states it is. The declarant

18 attempts to authenticate this document through the deposition of Mary Coller-Albert, but the

19 deponent did not work for the Los Angeles Police Department, did not create the document and
20 cannot authenticate the document. The document appears to be incomplete and does not identify

21 the author or date of creation.

22 Objection No. 2

23 Exhibit 23 attached to the Cunny Declaration and identified in Paragraph 27 of the Cunny
24 Declaration as a “copy of the statement provided by the Quindoys to the Santa Barbara County

25 Sheriff’s Department”. (Cunny Decl. at ¶ 27 (page 8, lines 6-7), Ex. 23.)

26 Grounds for Objection No. 2:

27 Hearsay (Evid. Code § 1200): The document is being offered for the truth of matters stated
28 therein. The document is double hearsay in that it purports to be a government official’s summary

10386-00226/726738.3 1
EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.
 1 or transcription of statements allegedly made by another person in the course of a (meritless)

2 criminal investigation. Witness statements taken in criminal investigation are, quite literally, the

3 most classic example of inadmissible hearsay. See Crawford v. Washington, 541 U.S. 36, 40, 43-

4 44, 51-52 (2004) (discussing history of hearsay rule arising from right of confrontation of

5 witnesses in criminal proceedings); People v. Jaramillo, 137 Cal.App. 232, 235 (1934).

6 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

7 for how he has personal knowledge that the document is what he states it is.

8 Objection No. 3

9 Exhibit 24 attached to the Cunny Declaration and identified in Paragraph 28 of the Cunny

10 Declaration as a “copy of the declaration of Charli Michaels, dated February 15, 1994”. (Cunny
KINSELLA WEITZMAN ISER KUMP LLP

11 Decl. at ¶ 28 (page 8, lines 13-14), Ex. 24.)

TEL 310.566.9800 • FAX 310.566.9850
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

12 Grounds for Objection No. 3:

13 Hearsay (Evid. Code §§ 1200, 1291, 1292): Under Sections 1291 and 1292, for evidence

14 of former testimony to be admissible, the declarant must be unavailable. There has been no such

15 showing of unavailability here. See also L&B Real Estate v. Superior Court, 67 Cal.App.4th 1342,

16 1348 (1998) (ten-year old deposition testimony inadmissible on summary judgment in part based

17 on lack of assurance that witness could still testify competently to the evidentiary facts to which

18 he or she previously testified). To the contrary, Ms. Michaels was deposed in this matter, and

19 Plaintiff is relying on her testimony.

20 Objection No. 4

21 Exhibit 25 attached to the Cunny Declaration and identified in Paragraph 29 of the Cunny
22 Declaration as a “copy of the statement provided by Donald Starks to the Los Angeles County

23 District Attorney’s Office, as dated on October 1, 1993”. (Cunny Decl. at ¶ 29 (page 8, lines 24-
24 26), Ex. 25.)

25 Grounds for Objection No. 4:

26 Hearsay (Evid. Code § 1200 et seq.): The document is being offered for the truth of

27 matters stated therein. The document is double hearsay in that it purports to be a government
28 official’s summary or transcription of statements allegedly made by another person in the course

10386-00226/726738.3 2
EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.
 1 of a (meritless) criminal investigation. Witness statements taken in criminal investigation are,

2 quite literally, the most classic example of inadmissible hearsay. See Crawford v. Washington, 541

3 U.S. 36, 40, 43-44, 51-52 (2004) (discussing history of hearsay rule arising from right of

4 confrontation of witnesses in criminal proceedings); People v. Jaramillo, 137 Cal.App. 232, 235

5 (1934).

6 Notably, although it has been transcribed, there is no indication that the statement was

7 taken under oath and under penalty of perjury. Even if it were, the requisite showings have not

8 been made to admit any such former testimony under Evidence Code Section 1292. See L&B Real

9 Estate v. Superior Court, 67 Cal.App.4th 1342, 1348 (1998).

10 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

KINSELLA WEITZMAN ISER KUMP LLP

11 for how he has personal knowledge that the document is what he states it is. The declarant
TEL 310.566.9800 • FAX 310.566.9850
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

12 attempts to authenticate this document through the deposition of Donald Starks, but the deponent

13 did not work for the Los Angeles County District Attorney’s Office, did not create the document

14 and cannot authenticate the document.

15 Objection No. 5

16 Exhibit 26 attached to the Cunny Declaration and identified in Paragraph 30 of the Cunny

17 Declaration as a “copy of the statement provided by Charli Michaels to the Santa Barbara County

18 Sheriff’s Department on April 15, 1994”. (Cunny Decl. at ¶ 30 (page 9, lines 7-9), Ex. 26.)

19 Grounds for Objection No. 5:

20 Hearsay (Evid. Code § 1200): The document is being offered for the truth of matters stated

21 therein. The document is double hearsay in that it purports to be a government official’s summary
22 or transcription of statements allegedly made by another person in the course of a (meritless)

23 criminal investigation. Witness statements taken in criminal investigation are, quite literally, the
24 most classic example of inadmissible hearsay. See Crawford v. Washington, 541 U.S. 36, 40, 43-

25 44, 51-52 (2004) (discussing history of hearsay rule arising from right of confrontation of
26 witnesses in criminal proceedings); People v. Jaramillo, 137 Cal.App. 232, 235 (1934).

27 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

28 for how he has personal knowledge that the document is what he states it is. The declarant

10386-00226/726738.3 3
EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.
 1 attempts to authenticate this document through the deposition of Charli Michaels, but the deponent

2 did not work for the Santa Barbara County Sheriff’s Department, did not create the document and

3 cannot authenticate the document. The document appears to be incomplete and does not identify

4 the author or date of creation.

5 Objection No. 6

6 Exhibit 31 attached to the Cunny Declaration and identified in Paragraph 35 of the Cunny

7 Declaration as a “copy of the December 16, 1987 memorandum of Jolie Levine”. (Cunny Decl. at

8 ¶ 35 (page 10, lines 10-11), Ex. 32.)

9 Grounds for Objection No. 6:

10 Hearsay (Evid. Code § 1200 et seq.): The document is being offered for the truth of
KINSELLA WEITZMAN ISER KUMP LLP

11 matters stated therein.

TEL 310.566.9800 • FAX 310.566.9850
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

12 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

13 for how he has personal knowledge that the document is what he states it is.

14 Lack of Foundation (Evid. Code § 403): The declarant does not have foundation to testify

15 as to what these documents are or the parties to such documents.

16 Lack of Personal Knowledge (Evid. Code § 702): The declarant does not have personal as

17 to what these documents are or to identify the parties to the documents.

18 Objection No. 7

19 Exhibit 32 attached to the Cunny Declaration and identified in Paragraph 36 of the Cunny
20 Declaration as a “copy of an undated memorandum by Jolie Levine to Jane AA Doe”. (Cunny

21 Decl. at ¶ 36 (page 10, lines 13-14), Ex. 32.)

22 Grounds for Objection No. 7:

23 Hearsay (Evid. Code § 1200 et seq.): The document is being offered for the truth of
24 matters stated therein.

25 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

26 for how he has personal knowledge that the document is what he states it is.

27 Lack of Foundation (Evid. Code § 403): The declarant does not have foundation to testify
28 as to what these documents are or the parties to such documents.

10386-00226/726738.3 4
EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.
 1 Lack of Personal Knowledge (Evid. Code § 702): The declarant does not have personal as

2 to what these documents are or to identify the parties to the documents.

3 Objection No. 8

4 Exhibit 38 attached to the Cunny Declaration and identified in Paragraph 42 of the Cunny

5 Declaration as a “copy of the Declaration of Jordan Chandler”. (Cunny Decl. at ¶ 42 (page 12,

6 lines 2-4), Ex. 38.)

7 Grounds for Objection No. 8:

8 Hearsay (Evid. Code § 1200 et seq.): The document is being offered for the truth of

9 matters stated therein. Moreover, the requisite showings have not been made to admit any such

10 former testimony under Evidence Code Section 1292. See L&B Real Estate v. Superior Court, 67
KINSELLA WEITZMAN ISER KUMP LLP

11 Cal.App.4th 1342, 1348 (1998).

TEL 310.566.9800 • FAX 310.566.9850
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

12 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

13 for how he has personal knowledge that the document is what he states it is.

14 Objection No. 9

15 Exhibit 39 attached to the Cunny Declaration and identified in Paragraph 43 of the Cunny

16 Declaration as a “copy of the Santa Barbara County Sheriff’s Department Report, regarding

17 Jordan Chandler”. (Cunny Decl. at ¶ 43 (page 12, lines 9-10), Ex. 39.)

18 Grounds for Objection No. 9:

19 Hearsay (Evid. Code § 1200): The document is being offered for the truth of matters stated
20 therein. The document is double hearsay in that it purports to be a government official’s summary

21 or transcription of statements allegedly made by another person in the course of a (meritless)

22 criminal investigation. Witness statements taken in criminal investigation are, quite literally, the

23 most classic example of inadmissible hearsay. See Crawford v. Washington, 541 U.S. 36, 40, 43-
24 44, 51-52 (2004) (discussing history of hearsay rule arising from right of confrontation of

25 witnesses in criminal proceedings); People v. Jaramillo, 137 Cal.App. 232, 235 (1934).
26 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

27 for how he has personal knowledge that the document is what he states it is. The document
28 appears to be incomplete.

10386-00226/726738.3 5
EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.
 1 Objection No. 10

2 Exhibit 40 attached to the Cunny Declaration and identified in Paragraph 44 of the Cunny

3 Declaration as a “copy of the recorded statement of Jordan Chandler by the Los Angeles County

4 District Attorney’s Office, on September 1, 1993”. (Cunny Decl. at ¶ 44 (page 12, lines 17-19),

5 Ex. 40.)

6 Grounds for Objection No. 10:

7 Hearsay (Evid. Code § 1200 et seq.): The document is being offered for the truth of

8 matters stated therein. The document is double hearsay in that it purports to be a government

9 official’s summary or transcription of statements allegedly made by another person in the course

10 of a (meritless) criminal investigation. Witness statements taken in criminal investigation are,

KINSELLA WEITZMAN ISER KUMP LLP

11 quite literally, the most classic example of inadmissible hearsay. See Crawford v. Washington, 541
TEL 310.566.9800 • FAX 310.566.9850
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

12 U.S. 36, 40, 43-44, 51-52 (2004) (discussing history of hearsay rule arising from right of

13 confrontation of witnesses in criminal proceedings); People v. Jaramillo, 137 Cal.App. 232, 235

14 (1934).

15 Notably, although it has been transcribed, there is no indication that the statement was

16 taken under oath and under penalty of perjury. Even if it were, the requisite showings have not

17 been made to admit any such former testimony under Evidence Code Section 1292. See L&B Real

18 Estate v. Superior Court, 67 Cal.App.4th 1342, 1348 (1998).

19 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

20 for how he has personal knowledge that the document is what he states it is. The document

21 appears to be incomplete.
22 Objection No. 11

23 Exhibit 41 attached to the Cunny Declaration and the statement in Paragraph 45 of the
24 Cunny Declaration identifying Exhibit 41 as a “copy of the photographs seized by the Los Angeles

25 Police Department”. (Cunny Decl. at ¶ 45 (page 12, lines 25-26), Ex. 41.)
26 Grounds for Objection No.11:

27 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

28 for how he has personal knowledge that the document is what he states it is. The declarant

10386-00226/726738.3 6
EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.
 1 purports to rely on the testimony of Federico Sicard, but the testimony does not authenticate the

2 document, nor does he testify that he recognizes the document as a “copy of the photographs

3 seized by the Los Angeles Police Department” as the declarant describes the exhibit.

4 Lack of Foundation (Evid. Code § 403): The declarant does not have foundation to testify

5 as to whether the photographs were purportedly “seized,” and the cited deposition testimony does

6 not address most of the photos.

7 Lack of Personal Knowledge (Evid. Code § 702): The declarant does not have personal

8 knowledge regarding whether the photos were “seized,” and the cited deposition testimony does

9 not address most of the photos.

10 Objection No. 12
KINSELLA WEITZMAN ISER KUMP LLP

11 Exhibit 42 attached to the Cunny Declaration and identified in Paragraph 46 of the Cunny
TEL 310.566.9800 • FAX 310.566.9850
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

12 Declaration as a “copy of settlement agreement between Michael Jackson and Jordan Chandler”.

13 (Cunny Decl. at ¶ 46 (page 13, lines 7-8), Ex. 42.)

14 Grounds for Objection No. 12:

15 Hearsay (Evid. Code § 1200 et seq.): The document is being offered for the truth of

16 matters stated therein.

17 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

18 for how he has personal knowledge that the document is what he states it is. Moreover, the parties

19 to the agreement are not parties in this litigation.

20 Settlement Communication (Evid. Code §§ 1152): The document appears to be a

21 confidential settlement agreement and is designated as “Confidential Settlement.”

22 Objection No. 13

23 Exhibit 44 attached to the Cunny Declaration and identified in Paragraph 48 of the Cunny
24 Declaration as a “copy of a document entitled, ‘Plaintiff’s Motion for Admission of Evidence of

25 Defendant’s Prior Sexual Offenses,’ which is believed to have been filed in the Superior Court of
26 California, County of Santa Barbara on December 10, 2004”. (Cunny Decl. at ¶ 48 (page 13, lines

27 24-27), Ex. 44.)

28

10386-00226/726738.3 7
EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.
 1 Grounds for Objection No. 13:

2 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

3 for how he has personal knowledge that the document is what he states it is. Moreover, Plaintiff’s

4 request for judicial notice of this document must be denied. The document is not a certified copy,

5 and declarant only contends that he “believe[s]” it was filed.

6 Hearsay (Evid. Code § 1200): The document is being offered for the truth of matters stated

7 therein.

8 Secondary Evidence Rule (Evid. Code §1523): The document purports to describe the

9 contents of other documents and evidence not before the Court.

10 Objection No. 14
KINSELLA WEITZMAN ISER KUMP LLP

11 Exhibit 45 attached to the Cunny Declaration and identified in Paragraph 49 of the Cunny
TEL 310.566.9800 • FAX 310.566.9850
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

12 Declaration as a “copy of checks made out from Defendants to an individual referred to as ‘Jane

13 AA Doe’”. (Cunny Decl. at ¶ 49 (page 13, lines 7-8), Ex. 42.)

14 Grounds for Objection No. 14:

15 Hearsay (Evid. Code § 1200 et seq.): The document is being offered for the truth of

16 matters stated therein.

17 Improper Authentication (Evid. Code §§ 1400-1401): The declarant offers no explanation

18 for how he has personal knowledge that the document is what he states it is. Moreover, some of

19 the documents included within Exhibit 45 do not reference Defendants, and the documents appear
20 to have been altered to reference “Jane AA Doe.”

21 Lack of Foundation (Evid. Code § 403): The declarant does not have foundation to testify
22 as to what these documents are or the parties to such documents.

23 Lack of Personal Knowledge (Evid. Code § 702): The declarant does not have personal as
24 to what these documents are or to identify the parties to the documents.

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EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.
 DATED: February 19, 2021 Respectfully Submitted,
1

2 KINSELLA WEITZMAN ISER KUMP LLP

4 By:
Aaron Liskin
5
Howard Weitzman
6 Jonathan P. Steinsapir
Katherine T. Kleindienst
7 Attorneys for Defendants
MJJ Productions, Inc. and MJJ Ventures, Inc.
8

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KINSELLA WEITZMAN ISER KUMP LLP

11
TEL 310.566.9800 • FAX 310.566.9850
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

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10386-00226/726738.3 9
EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.
 PROOF OF SERVICE
1
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
2
At the time of service, I was over 18 years of age and not a party to this action. I am
3 employed in the County of Los Angeles, State of California. My business address is 808 Wilshire
Boulevard, 3rd Floor, Santa Monica, CA 90401.
4
On February 19, 2021, I served true copies of the following document(s) described as
5 DEFENDANTS MJJ PRODUCTIONS AND MJJ VENTURES’ EVIDENTIARY
OBJECTIONS TO THE DECLARATION OF ALEX E. CUNNY AND EXHIBITS
6 THERETO on the interested parties in this action as follows:

7
John C. Manley Attorneys for Plaintiff Wade Robson
8 Vince W. Finaldi
Alex E. Cunny Phone: 949-252-9990
9 Manly, Stewart & Finaldi Fax: 949-252-9991
19100 Von Karman Ave., Suite 800 Email: vfinaldi@manlystewart.com
10 Irvine, CA 92612 jmanly@manlystewart.com
acunny@manleystewart.com
KINSELLA WEITZMAN ISER KUMP LLP

11 kfrederiksen@manlystewart.com
TEL 310.566.9800 • FAX 310.566.9850
808 WILSHIRE BOULEVARD, 3RD FLOOR
SANTA MONICA, CALIFORNIA 90401

12  BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the

persons at the addresses listed above and placed the envelope for collection and mailing, following
13 our ordinary business practices. I am readily familiar with Kinsella Weitzman Iser Kump LLP's
practice for collecting and processing correspondence for mailing. On the same day that the
14 correspondence is placed for collection and mailing, it is deposited in the ordinary course of
business with the United States Postal Service, in a sealed envelope with postage fully prepaid.
15
 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the document(s)
16 to be sent from e-mail address mlaw@kwikalaw.com to the persons at the e-mail addresses listed
above. I did not receive, within a reasonable time after the transmission, any electronic message
17 or other indication that the transmission was unsuccessful.

18  BY OVERNIGHT DELIVERY: I caused said document(s) to be enclosed in an envelope

or package provided by the overnight service carrier and addressed to the persons at the addresses
19 listed above or on the attached Service List. I caused the envelope or package to be placed for
collection and overnight delivery at an office or a regularly utilized drop box of the overnight
20 service carrier or delivered such document(s) to a courier or driver authorized by the overnight
service carrier to receive documents.
21
I declare under penalty of perjury under the laws of the State of California that the
22 foregoing is true and correct. Executed on February 19, 2021, at Los Angeles, California.

23
24 /s/ Michelle Law
25 Michelle Law
26

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10386-00226/726738.3 10
EVIDENTIARY OBJECTIONS TO DECLARATION OF ALEX E. CUNNY, ESQ.