Jackson V AEG Live, July 19th 2013, Transcripts of Katherine Jackson

7/28/2019 Jackson V AEG Live, July 19th 2013, Transcripts of Katherine Jackson

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%s( *o)#so#&*ood morning. +a"ra 0o!inson for the efendants.

%r( Put#a& %nd Marvin P"tnam for the efendants.

Ju!+e& 1hank yo". -o" may !e seated. Plaintiffs, yo" can call yo"r ne2t itness.

%r( Pa#sh& -es. Plaintiffs call atherine Jackson at this time.

Kather#e Ja$.so#6 $alle! as a /t#ess )y the Pla#t""s6 /as s/or# a#! test"e! as "ollo/s&

he $ler.& Wo"ld yo" raise yo"r right hand$ o yo" solemnly state that the testimony yo"'re a!o"t to

give in the ca"se no ending !efore this co"rt shall !e the tr"th, the hole tr"th, and nothing !"t the

tr"th, so hel yo" *od$

he /t#ess& I do.

he $ler.& 1hank yo", ma'am. -o" may have a seat. %nd, ma'am, can yo" lease state and sell yo"rfirst and last name for the record$

he /t#ess& My name is atherine sther Jackson. 3a3t3h3e3r3i3n3e, #3a3c3k3s3o3n.

he $ler.&1hank yo".

Ju!+e& 1hank yo", ma'am. -o" may !egin.

-re$t e7a#ato# )y 5ra# Pa#sh&

4. -es. *ood morning, Mrs. Jackson.

%. *ood morning.

4. First of all, hat is yo"r date of !irth$

%. I as !orn may 5th, 6789.

4. I kno this is not a great :"estion, !"t ho old are yo"$

%. I'm ;8 years old.

4. Is this the first time yo"'ve ever testified in a co"rt ith a #"ry like this$

%. -es.

4. %re yo" nervo"s$

%. -es, I am.


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4. id yo" get a lot of slee last night$

%.


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%. -es, it is. 1he most diffic"lt thing is to sit here in this co"rt and listen to all the !ad things they say

a!o"t my son.

4. %nd hy is that diffic"lt for yo"$

%. Pardon$

4. Why is that diffic"lt for yo"$

%. Well, a lot of the things that have !een said are not the tr"th. =e's not here to seak for himself.

4. /o are yo" here to seak for yo"r son, Michael$

%. I'll try my !est.

4. %nd hy is it that yo"'re here to testify today$

%. Beca"se I ant to kno hat really haened to my son, and that's hy I'm here.

4. %nd do yo" !elieve that yo"r son as a !ad erson, or some of the things that have !een said$ %ndthe efendants have said, >It's "gly,> and they're >*oing to e2ose the "gly of yo"r family and yo"r

son.> Mr. P"tnam said that at the !eginning of the case. o yo" !elieve that's the case$

%r( Put#a& &!#ection, yo"r honor. Misstates the testimony and my comments.

4. Mr. P"tnam said in his oening statement. id yo" sit here, hear his oening statement$

%. -es, I did.

4. id Mr. P"tnam take yo"r deosition for many days$

%. -es, he did.

4. id he ask yo" many :"estions yo" didn't like$

%. -es, he did.

4. %nd ho does it make yo" feel to hear that they're going to tell everyone that yo"r son is a !ad

erson$

%. Makes me feel real !ad, !eca"se I kno my son as a very good erson. =e loved every!ody. =e

gave to charity. =e's in the *"inness !ook of records for giving the most to charity of all of the o

stars. I'm so nervo"s. I'm sorry.

4. &kay. Well, let's talk a!o"t yo" a little !it, Mrs. Jackson. Where ere yo" !orn$

%. I as !orn in Bar!o"r o"nty, %la!ama. % little, small ton.


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4. What as the name of the ton$

%. Bar!o"r o"nty. 1on$ "fa"la as the name of the ton.

4. "fa"la, %la!ama$

%. -es.

4. +et me ask yo"? %nd hat as yo"r 33 ell, ho ere yo"r arents$

%. My father as Prince /cr"se, and my mother as Martha @sha.

%r( Pa#sh& I ant to sho e2hi!it 699A. %ll these have !een given to co"nsel.

4. %nd ho is in that ict"re, ma'am$

%. 1hat's my father. 1hat's my father and Michael and myself.

4. %nd yo"r father's name as Prince /cr"se$

%. -es.

4. /3c3r3"3s3e$

%. -es.


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4. Is Prince a family name in yo"r family, Mrs. Jackson$

%. 1hat name goes all the ay !ack to slavery. =is father, his grandfather, his great grandfather, hisgreat grandfather ere all named Prince.

4. Were yo" leased hen yo" learned that yo"r son as going to name 33 Michael as going to namehis son Prince$

%. -es, I as.

4.


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4. What as yo"r father's name$

%. My father$ Prince.

4. I'm sorry. I asked yo" that already. I'm sorry. I'm nervo"s, too. &kay. %nd hat did yo"r father 33

hat as his m"sical talent$

%. =e layed g"itar. I layed the clarinet in the school !and. My sister layed the cello in the

orchestra. Joseh's side as very talented, also.

4. Who is Joseh$

%. My h"s!and.

4. %nd yo"r h"s!and, hat a!o"t his family side's talent$

%. 1hey ere very talented. =is !rother layed the g"itar. &ne of them layed the sa2ohone. %nd e

alays had m"sic aro"nd the ho"se, and I think that's hat enco"raged my children.

4. id yo" have any health iss"es, Mrs. Jackson, hen yo" ere groing "$

%. -es. I had olio as a child. It as 33 at that time it as called infantile aralysis !eca"se most !a!ies

got it at the time. B"t President 0oosevelt had it, also, and he started the March of imes. %nd that as

!ack in the '59s hen I as in school.

4. %nd ho did that affect yo" hen yo" ere groing "$

%. @hm, I ore a !race from the age of A " "ntil 33

4. -o" ore !races$

%. J"st one !race on my left leg, and ore it " "ntil the age of 7.

4. =o did that make yo" feel as a yo"ngster$

%. I as shy.

4. =o as yo"r son Michael ith children ho had disa!ilities$

%. Michael loved all children, !"t esecially the ones ho co"ldn't care for themselves or hadsomething rong ith them. veryhere he o"ld go, he o"ld go to the orhanages and o"ld go to

the hositals visiting children. =e o"ld alays give money for disa!led children. %nd hen he as

yo"ng, he o"ld alays have someone visiting from make a ish fo"ndation. Michael o"ld send all

day ith them, have l"nch ith them, lay ith them.

4. Mrs. Jackson, I ant to sho yo" e2hi!it 699;.

%r( Pa#sh& %ny o!#ection, co"nsel$ I'm sorry. an't hear yo".


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%r( Put#a&


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4. 1hat yo"r grad"ation ict"re$

%.


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4. I'll #"st move it !ack a little. =oef"lly e can still hear yo".


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%. My oldest as my oldest da"ghter, 0e!!ie. =er name as Ma"reen. Jackie as the second. =is

name is /igm"nd. 1ito, 1ariano as his name. 1hen Jermaine, Marlon, Michael, 0andy and Janet.

4. /o Michael o"ld have !een yo"r Ath child$

%. -es.

4. %nd then yo" had three girls and si2 !oys$

%. -es.

4. Was that easy$

%. fo"r3room ho"se,> is this a fo"r3!edroom

ho"se$

%.


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so he as in a cri! in o"r room.

4. &kay. /o to, to and one$

%. 0ight.

4. %ll right.


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%. *osh, I kno ho to cook otatoes in every ay yo" can think of !eca"se he "sed to ick the

otatoes, clean the field for otatoes and things hen he as laid off. J"st reg"lar food.

4.


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4. 1he mayor of *ary, Indiana, as in the ict"re$ Base!all ict"re$

%. -es. =e sonsored the team.

4. %nd hat as the name of the team$

%. 1he name of the team as atC ittens, and his name as Mayor atC.

4. &kay. %ll right. %nd the one ith the !o tie there$

%. -es.

4. %nd ho is in that ict"re ith Mayor atC$

%. Jermaine is ne2t to Mayor atC, and 1ito is ne2t to Jermaine.

4. id yo" like to go to the games$

%. We alays did, Marlon and Michael. %nd then the girls "sed to sit o"t and atch the !oys lay all

the time. Michael en#oyed it !eca"se he o"ld save his little ennies and nickels, so hen they oened", there as a refreshment stand, and he o"ld alays go there and send his money on that, on

candy and cookies.

4. %nd hat did he do ith all that candy$

%. Well, he didn't eat it all. =e liked to lay >store man.> so he o"ld take it and "t it and set " alittle store, and all the kids in the neigh!orhood o"ld come and !"y from him, and he felt like he as

the store man.

4. %ll right.


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%. keethis day.>

4. =ave yo" sent a lot of time in yo"r life reading the !i!le$

%. -es.

4.


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from the other holidays.

4.


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standing there holding his hand, a !oy of three years old, and crying.

4. rying hen his !rother as sick$

%. rying hen his !rother as sick.

4. id there come a time hen yo" realiCed that yo"r Ath child had an interest in m"sic$

%. -es. =e as !orn that ay. =e 33 hen all the kids as dancing aro"nd, he as in my arms, and he

co"ldn't !e still. =e as dancing, too, to the m"sic. %nd hen he started to alk, he o"ld still dance.

%nd there's a story a!o"t 33 I imagine I've told the story so many times.

4. /hare it ith "s.

%. We had an old, rickety ashing machine, a Maytag. %nd if yo" co"ld remem!er the ashing

machines, hen they ere older, they had the dasher. %nd then they had the rolling 33 yo" rolled yo"r

clothes to dry them o"t, s:"eeCe the ater o"t of them. %nd it as so old and r"sty, "ntil it as done

ashing, it o"ld make a noise, and !y the rotor going, it o"ld make a rhythm noise, like >s:"eaky,s:"eaky, kat"m, kat"m,> something like that, and he o"ld !e don there dancing, s"cking his !ottle

to the s:"eaking of the asher. %nd I kne he as going to !e 33 he #"st loved m"sic, and he loved to

dance.

4. id there come 33

%r( Pa#sh& -o" can take that don.

4. id there come a time hen yo" realiCed that yo"r children had a real m"sical talent$

%. -es. +ike I say, they "sed to sing in their !eds, and they layed m"sic. My father gave 1ito his firstg"itar. %nd Joe's !rother, hich is 1rentEs father, he layed g"itar. /o he o"ld come over, and theyo"ld lay together, and that's hat started 1ito to lay. %nd they loved the temtations, and they

o"ld imitate the temtations all the time.

4. 1emtations as a ell3knon gro" at the time$

%. %t Moton. -es.

4. &kay. What is Moton$

%. Pardon$

4. What is Moton$

%. Moton is a record comany hich signed my children " later on.

4. &kay. id yo" have a television$

%. &h, my goodness, yes, e had a 1G, !"t e had an old 1G. %nd sometimes it o"ld !reak don.


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%nd at the time there ere t"!es in 1Gs, and yo" co"ld go to the dr"gstore and take yo"r old t"!e andget another and come !ack and "t it in. B"t then later on, the 1G o"ld !reak don, and then e had

a 1G man. =e o"ld come and take it aay, and sometimes e didn't have the money to get it !ack.

%nd that's hen the children first started singing. We o"ld sing together, sing old co"ntry songs, folksongs. 1hings like that.

4. id yo" like co"ntry m"sic$

%. I gre " on co"ntry m"sic.

4. Is that from %la!ama$

%. 1hat's hen 33 e lived in ast hicago, and my father o"ld listen to that, an old co"ntry 33 I

mean, it as a co"ntry station coming o"t of hicago called the >s"ertime frolic.> and on theeekends e o"ld listen to the grand ole ory. /o e alays had m"sic in the ho"se.

4. I ant toadvertise them, so hat is the name$> %nd I told her, >1he Jackson Brothers .> %nd she said, >Well,

let's c"t that a little short and name it the Jackson .> %nd I tho"ght it so"nded !etter, so I as for it.

4. %nd that's ho the name came a!o"t$

%. 1hat's ho the name came a!o"t.

4. id there come a time hen yo" realiCed or even realiCed that Michael might have

%. /ecial talent himself$

%. -es. When Michael as in kindergarten and had started school, he as alays singing in the ho"se

anyay from a tiny kid all the ay ". /o they ere having a contest 33 not a contest. I'm sorry. =avinga rogram at school. %nd the teacher had sent a note home and told me Michael as in the rogram. /o


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I and Michael's grandfather, Joseh's father, ent don to school. %nd he 33 and I as thinking, >=ois he going to go " there #"st at five and sing$>

4. =o old as he$

%. Five years old. %nd he sang >lim! very Mo"ntain.> and I as so nervo"s hen he alked o"t on

the stage, !eca"se he as alays shy. %nd he started singing the song, and he sang it ith s"ch clarityand didn't miss 33 not flat or anything. Joe's father sat there and cried like a !a!y. +ooked aro"nd, and I

as crying, too. =e got a standing ovation for his erformance. %nd he asn't nervo"s, and I as

shocked. %nd I think he m"st feel more at home on stage.

4. =o did that make yo" feel$

%. I felt 33 I as ro"d of him !eca"se I didn't think he co"ld do it.

4. id there ever come a time hen it as disc"ssed of Michael #oining his !rothers in their gro"$

%. Well, that haened hen he as a!o"t si2 years old. %nd he as singing, and even after he hadsang >lim! very Mo"ntain,> I told Joseh 33 !eca"se Jermaine as the lead singer. %nd I told him

Jermaine needed hel, and I told him Michael co"ld hel him. =e didn't !elieve me, so I forced him to

listen. %nd that's ho Michael got the #o!. %nd then after that, he !ecame leader hen they !ecamerofessionals. Moton made him a lead singer.

4. %nd did the Jackson ever lose any contests$

%. When they ere at home$

4. -es.

%. Playing against high schools$ 1hey did. 1hey lost once. %nd I think that they ere sick of seeingthe Jacksons in. /o it as another team, and it as one of the !oys that !elonged to this other gro"

ho lived ne2t door to "s, and they on that year.

4. &kay. I ant to sho yo" e2hi!it 6968. %nd is that the gro" early on$ (indicating)


20/89

%. -es. 1hose are my !oys.

4. %nd here is Michael$

%. Michael is the little kid to the right of "s.

4. I'm sorry$

%. =e's on the right.

4. =ere$ (indicating)

%. 0ight there.

4. Who is that$ (indicating)


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%. 1hat's Jermaine.

4. (indicating)

%. 1hat's o"r dr"mmer, Johnny Jackson. 1he Jackson and Johnny.>

4. >and Johnny>$

%. -es.

4. &kay. /o there's si2 eole$

%. /i2 eole.

4. Who is this$ (indicating)

%. 1hat's Marlon, 1ito and Jackson.

4. %nd hen e sa 1J. %nd 1a#, they're 1ito's children$

%. 1hey're 1ito's children, yes.

4.


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4. %nd ho did yo" get the money to !"y the instr"ments$

%. Well, e saved it. I "sed to alays arg"e and f"ss ith Joe a!o"t, >I need more rooms. I need more

rooms.> and hen e o"ld save money, e'd !"y more instr"ments. We'd !"y amlifiers and thingslike that.

4. %nd ho made the cost"mes !ack then$

%. I did.

4. -o" s"ed them yo"rself$

%. -es, I did.

4. +et me look at e2hi!it 6965, lease (indicating). What are those called, those s"its$

%. =omemade s"its.

4. &kay. id yo" make those s"its$


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%. -es.

4. I g"ess that's hat they're called.

%. 1hat's hat they're called.

4. %ll right. %nd ho long did a homemade s"it last$

%. 1hey gre o"t of them m"ch too fast, !eca"se e had to save money to !"y more s"its !eca"se I

asn't going to attemt that anymore.

4. &kay. %nd at some oint in time, after they had !een inning some of these contests, did they ever

get a gig, I g"ess yo"'d call it, here they o"ld get aid$

%. -es. 1hey had gotten to here the 1emtations or *ladys knight or someone came aro"nd to

hicago to lay at the theaters, I g"ess the oners of the theater o"ld alays call "s, and the !oys

o"ld !e on stage ith them. 1hey o"ld lay, and e got aid that ay.

4.


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records.

4.


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4. %nd do yo" kno ho old he as there, Michael$

%. =e as a!o"t five.

the v!eo $lp $o#t#ues to )e playe!4

4. Is this Moton$

%. -es. 1hat's Moton.

4. id they go to an a"dition$

%. -es. 1hat's the a"dition.


4. What is this$

%. 1hat's on one of those television shos.

4. d /"llivan$

%. 1hat's d /"llivan there.


4. Is that Michael$

%. %nother television sho. I don't remem!er hich one.


4. Who is that$ Janet$

%. Michael and Janet.

4. id yo" make those o"tfits$

%. Pardon$

4. 1hey had that cartoon series$

%. -es.


4. Where is this$


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%. Moton .

4. %nd do yo" remem!er here this as$

%. Pardon$

4. o yo" remem!er here this as filmed$

%. I think that as in Pasadena somehere.


4. Is one of the !rothers 33 this as the re"nion$

%. -es. Jermaine left the Jacksons hen they left Moton. =e as married to Barry *ordon's

da"ghter.

4. Barry *ordon, the oner of Moton$

%. &ner of Moton.

4. =e didn't leave$

%. =e didn't leave. /o Moton , that's hen they re#oined them.


he /t#ess& %nd that's Jermaine h"gging them, and they ere hay that he as !ack.

4. &kay. /o as a mother, hen yo" sa Michael erform like that, ho did yo" feel$

%. =o did I feel$

4. -eah.

%. I felt very ro"d.

4. When he did these secial erformances, ere yo" s"rrised to see ho he did in these secial

events$

%. -es. secially one time hen he as 65. =e sang solo on one of the aard shos. %nd that as

very good, I tho"ght. I as most ro"d of him.

4. Were yo" there$

%. -es, I as.

4. =ave yo" ever heard of the %cademy %ards$


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%. -es. It as at the %cademy %ards.

4. %nd I have a cli of that. o yo" kno hat song Michael sang$

%. =e sang Ben. It's a song a!o"t a rat. %nd it's a song from a Movie.

4. %nd Michael, hen he ent to erform, yo" said he as a!o"t 65$

%. =e as 65 at the time.

4. %nd he as yo"nger than his son Prince is no$

%. -es.

4. %nd ere yo" nervo"s a!o"t it$

%. I as a little !it, !"t he did ell.

4. &kay. Well, let's 33 e2hi!it 696H. -o" remem!er ho introd"ced Michael (indicating)$

%. -es. &ne of my favorite actors.

4. Who is that$

%. I'm so nervo"s, I can't remem!er. I kno ho he is very ell, !"t 33

4. 1his as Michael at 65$

%. -eah.

a v!eo $lp s playe!4

4. Was Michael singing that song again$

%. -es. =e's older. %s yo" can see, his voice has changed there.

4. id he like that song, Ben$

%. -es, I do.

4. id Michael like that song$

%. -es, he liked that song !eca"se he liked rats. 1hat song is a!o"t a rat. %nd I can remem!er a storythat e ent to Beverly =ills to have dinner, and e ere eating, and Michael ket "lling his coat "

and "tting cr"m!s into his ocket. %nd I said, >hat are yo" doing$> and he held it ", and he had a

rat in his ocket, and he as feeding it. %nd I as really "set ith him.


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4. =o a!o"t 33 !y the ay, the actor, yo" heard of that movie Ben3="r$

%. &h, yes. %nd isn't that af"l.

4. harlton =eston$

%. 1hank yo". I can't think of his name, !"t I love him.

4. id Michael like animals$

%. -es, he did. B"t one thing he didn't like ere dogs.

4. Why not$

%. Well, he had a !ad e2erience ith dogs. &ne year hen he as a kid, Johnny Jackson, o"r

dr"mmer, ent on vacation, so he left his it !"ll ith "s to take care of. %nd Michael and 0andy as

laying ith the dog 33

4. =old on one second.

%. I'm too close$

4. Why don't yo" "sh it forard a little more.

%. =o is that$ Is that !etter$

4. Better.

%. Is that !etter$ &kay. Where as I$

4. -o" ere telling "s a!o"t dogs.

%. &h, yes. %nd Johnny left the it !"ll ith "s to take care of. %nd Michael and 0andy as laying

ith the it !"ll, and Michael discovered d"ring their lay, the dog got mad. %nd I don't kno hy hegot "set, !"t Michael discovered that, so he ran and #"med on to of the #ee. %nd 0andy as teasing

Michael, >&h, yo"'re scared of a little old dog.> %nd he said, >For real, 0andy. 1hat dog is mad.> %nd

so 0andy ent over teasing the dog, and the dog t"rned on him. /o 0andy tried to #"m on the Jee,and !efore he co"ld get aay, he took a !ig ch"nk o"t of his arm and o"t of his heel. When he #"med

o"t at him, took a ch"nk o"t of his heel. %nd I r"shed him to emergency, !"t he !it don to the !one.

%nd I don't kno ho he took that ch"nk of meat o"t of his arm like that. +ike some!ody took a sharsoon and d"g it o"t. %nd I co"ld see his !ones and everything. %nd so Michael has !een afraid of dogs

ever since.

4. %nd at some oint in time, desite his fear of dogs, did he get a dog for his children$

%. -es, he did.

4. %nd hat kind of dog as that$


29/89

%. % chocolate +a!rador.

4. What as the name of the dog$

%. enya. %nd e still have him.

4. %nd hen Michael assed aay, in addition to getting a la!, did yo" get some other ets, too$

%. I inherited almost a Coo. -es. 1here as a arakeet and arrot. Ferrets, mice. /o m"ch I can't think

of it.

4. Besides singing and dancing 33

%. %nd to cats. 2c"se me. %nd I don't like cats.

4. Besides singing and dancing, did Michael like to do other things$ raing$ %rt$ %nything like

that$

%. an yo" reeat$ I didn't hear.

4. &kay. I'm sorry. =o are yo" doing$ -o" doing okay$

%. -es.

4. &kay. %ll right. In addition to singing and dancing, did Michael like to do other things$ %ny art$

%nything like that$

%. &h, yes. Michael as a very good artist. =e did a lot of art in school. %nd some of his ict"res have!een sold since. %nd he rites songs.

4. %ll right. %nd did Michael like to sit aro"nd and atch 1G$

%.


30/89

4. %t some oint in time yo" mentioned that the Jackson left Moton e2cet for Jermaine.

%. -es. 1hey left Moton, and I think they ent to ic records at that time.

4. o yo" kno ho many records they'd sold !y that time$

%. With Moton$ I can't remem!er e2actly. B"t at ic, I think their first record ent do"!le

latin"m.

4. 0emem!er hat that as$

%.


31/89

4. Is that Michael$

%. 1hat's Michael.


4. %ll right.


32/89

4. With yo"$

%. =e as still at home.

4. =ayvenh"rst$

%. -es.

4. %ll right. %nd did Michael ever ant to !e knon as something other than Michael Jackson$

%. Well, he had 33 !y a certain time in his life he didn't ant to !e knon as Michael Jackson, !eca"se

that as little Michael Jackson from the Jackson . =e anted to !e knon as MJ.

4. &kay.

%. Why, I don't kno.

4.

%nd did there come a time hen he came o"t and did something as MJ$

%. Well, !y the time he as on Moton , and he did the Moonalk, that changed things.

4. &kay. Well, let's 33 ho 33 ere yo" there$

%. -es.

4. =o did the crod react to Michael that night$

%. &h, my goodness, I can't 33 do e have a thing of it$

4. -es, I do have one. +et's take a look at 696;. %nd the Moonalk, had Michael ever done this in

"!lic$

%.


33/89

4. Was Michael having a lot of s"ccess$

%. Pardon$

4. Was Michael having a lot of s"ccess$

%. -es.

4. id it go to his head$

%.


34/89

%. -es. =e 33 " over the garage, like I said, he "sed to ractice all the time. =e'd lock that room ",

and he told "s not to come in. %nd he took all my ict"res 33 !eca"se I as ondering, >Where are my

ict"res going$> =e took all the ict"res, enlarged them, and instead of allaer, he #"st "t them allaro"nd the all and invited the hole family over hen he got ready to oen it ". %nd he said, >=ere's

yo"r s"rrise. ome in.>

4. id he have eole come hel him do this$

%. Well, eole heled him enlarge them and all of that, yes.

4. B"t the ork of "tting " the ork and the design and everything$

%. =e heled and 33 yes, he did.

4. %ll right. +et's look first at e2hi!it 6967 (indicating). Is this a la:"e that Michael gave yo"$

%. -es.

4. It says? >To take a picture is to capture a moment to stop time, to preserve the way we were, the

way we are. They say a picture speaks a thousand words, so with these photographs, I will recreate

some wonderful magical moments in our lives. Hopefully this journey into the past in picturesque

form will be a stimulant to create a brighter, successful tomorrow. Michael ackson.> Is that in yo"r

ho"se in =ayvenh"rst$


35/89

%. -es. It's still there.

4. %nd did Michael rite that and "t that " for yo"$

%. -es, he did.

4. Where is that in the home$

%. It's over the garage, and it's 33 I think it's to rooms " there. =e did the hole "stairs that ay.

4. &kay. +et's look at it. 2hi!it 699 (indicating). %nd did Michael reare this for yo"$

%. -es, he did.

4. =o did it make yo" feel$

%. I felt ro"d. =e as alays giving me things.


4. &kay. Is Michael singing 33 hat song is he singing here$

%. >-o" %re !"t 33


4. Why don't yo" tell "s hat yo"'re looking at$

%. -o"'re looking at a ict"re that he had taken !efore they left *ary, Indiana. 1hat's my father there.

4. We're looking at the alls of the room$

%. 1hat's 0e!!ie hen she as at high school. Joe laying the g"itar. Myself and Janet, +a 1oya.

4. We can see there's like a indo, and there's the alls.

%. -es.

4. Michael did all this for yo"$

%. -es.

4. %nd he made all the allaer. 1here's yo"r driver's license.


4. Who is that$


36/89

%. 1hat as me, and that's ith the :"een.

4. %nd that's the ceiling " there$

%. -es.

4. Michael "t all that " there$

%. verything as covered ith ict"res.


4. %nd Michael made all that for yo"$

%. -es.

4. -o" still have it that ay$

%. -es.

4. %ll right.

Ju!+e& /hall e take a 63min"te !reak "ntil 66?99$

%r( Pa#sh& -es, yo"r honor. 1hat o"ld !e great.

Ju!+e& +et's do that. Break "ntil 66?99, and then e'll come !ack.

he ury e7ts the $ourtroo4

5rea.4

he ury e#ters the $ourtroo4

Ju!+e& atherine Jackson vers"s %* +ive. -o" may contin"e.


37/89

%r( Pa#sh& 1hank yo", yo"r honor.

4. Mrs. Jackson, did Michael ever thro a dinner arty for yo" hen he serenaded yo"$

%. -es.

4. oes this em!arrass yo"$

%. -es.

4. &kay. +et's look at e2hi!it 69H.


4. Where is this$ o yo" remem!er this dinner arty$

%. -es, I do.

4. Who as sitting ne2t to yo"$

%. It as my favorite ianist.

4. Who is that$

%. Floyd ramer, concert ianist.

4. Is this song that Michael sings, is this one of yo"r favorites$

%. -es, it is.

4. Is that Floyd$

%. Pardon me$

4.


38/89

4. %t home.

%. &h. I don't "nderstand the :"estion.

4. &kay. Fair eno"gh. id Michael like m"sic videos$

%. &h, yes.

4. id yo" talk a!o"t those ith him$

%. &h, yes.

4. What o"ld yo" talk a!o"t$

%. We talked a!o"t the 33 they ere really short movies, and I o"ld alays tell him 33 hen he made

his first movie, he said, >!ell, mother, the second one is going to be better than the first.> %nd I as

ondering 33 I o"ld tell him, >How are you going to top that"> %nd he said, >#ou$ll see.> %nd the

ne2t one as 1hriller, and he did to the first one. %nd he invited me don to here he as doinganother short movie, and it as *host. I don't think it toed thriller. B"t it as f"nny.

4. &kay. +et's take a look at that. 2hi!it 696 (indicating). -o" ent to the set of this$

%. -es.

4. %nd ho is that$

%. I'm here to see my son, Michael.> %nd he said, >Mother, it's me.> I anted himto get him for me.

%r( Pa#sh& %ll right. Is that a video$ J"st a ict"re$ &kay.

4. =ello. =o are yo"$>

and he said, >It's me, mother.> B"t he had to do it.

4. /o he o"ld go o"t and knock on eole's doors ith the s"it on$


39/89

%. -es.

4. =e'd get the door slammed in his face$

%. +ots of times. B"t they never kne ho it as, so that as good.

4. %ll right. /o then in 67;; did Michael "rchase the


40/89


41/89

4. %nd e sa a lot of animals that Michael had there$

%. +ots of animals. F"nny story is 33 kids liked to go to h"ck . heese.

4. h"ck . heese$

%. -es.

4. +ike iCCa$ +ike a lot of kids r"nning aro"nd$

%. % lot of kids r"nning aro"nd. /o *race had them at h"ck . heese, and the lady there, she as

asking them, >o yo" like animals$ o yo" have any animals$> %nd the kids said, >-es. We have an

elehant, and e have giraffes,> %nd #"st naming all the !ig animals. %nd the lady t"rned to *race andsaid, >on't they have great imaginations$>


42/89


43/89

%. Well, I kno he as taking ain ills. %nd hen he said >a!"sing them,> I didn't kno. Beca"se at

that time I had seen Michael so many times, gone to his home "nanno"nced and called him, he didn't

kno I as calling him, I never heard or seen him in that ay. /o I don't kno ho to !elieve it.

4. id yo" or yo"r children ever try to have any tye of intervention of any kind ith Michael$

%. -es. I ent ith them on an intervention once, !eca"se 33 I didn't ant to go, !eca"se I didn't

!elieve it then that he as a!"sing dr"gs. B"t I had heard it from them, and they had heard it, also. B"t

I ent !eca"se they ket telling me, >it o"ld mean m"ch more, mother, if yo" o"ld go.>

4. /o yo" ent$

%. /o I ent.

4. %nd did Michael say he had a ro!lem$

%. When e got there, Michael as fine.

4. id yo" hear of other times that eole tried doing interventions ith Michael$

%.


44/89

4. What as that for$

%. 1hat as s"osed to !e for my H9th anniversary, !"t it as the rong time. I think Janet #"st

named it that so e co"ld have an anniversary or a arty.

4. Were yo" ever asked !y anyone to sign anything saying Michael had any iss"es in 99A$

%. id I ever$ -es, I did. B"t yo" kno hat$ I really don't remem!er that thing. B"t I did sign

something.

4. id yo" see Michael 33 in Peole magaCine or something$

%. -es.

4. id yo" see Michael in May at the family gathering$

%. When$ In '97$

4. -es. I ant to sho yo" e2hi!it 636. Is this the family ict"re$ (indicating)

%. -es, it is.

4. %nd ho did yo" think Michael as at that time$


45/89

%. %t that time, to me, Michael looked okay. +ater I 33 hen I sa it, I sa he as thinner. Beca"se he

as dressed in a #acket and all, I didn't notice that he as very thin.

4. +et me ask yo" this? an yo" descri!e 33 okay. +et's look at Michael.

%r( Pa#sh& an e Coom in on him$ 1here he is.

4. Who's got the hat on$

%. 1hat's +a1oya.

4. &kay. %nd Michael is ne2t to +a1oya$

%. @h3h"h.

4. >yes>$ &kay. 1hat's good. an yo" tell "s, Mrs. Jackson, can yo" descri!e yo"r relationshi ith

yo"r son Michael$

%. Michael and I ere very close. Michael, he as the tye of son, a mother o"ldn't ant a !etter sonthan Michael.

4. Was he shy$

%. Michael as very shy.

4. id he rite a oem for yo"$

%. -es, he did. =e rote several oems for me.

4. I'm going to sho yo" e2hi!it 698, a oem he rote called >Mother.> >Mother> 33 did Michaelrite this for yo"$


46/89

%. -es.

4. >Mother dear, you gave me life. 'ecause of you, no struggle or strife. #ou gave me joy andposition, cared for me without condition.> %nd it goes on. =o did yo" feel$ In the end, it says? >(o

matter where I go from here, you$re in my heart, my mother dear.> =o did that make yo" feel hen

Michael gave that to yo"$

%. Well, it made me cry, for one thing. %nd I felt very 33 I felt loved. I kne he loved me.

4. %nd after Michael died, did yo" find another oem that he had ritten for yo"$

%. -es. =e had scri!!led that on some ieces of aer, and Jermaine gave it to me framed. =e m"sthave fo"nd it, and he framed it and gave it to me.

4. +et me sho yo" e2hi!it 695 (indicating). %nd this is in Michael's handriting. >a reflection of amother's heart is in the glimmer in her children's every>


47/89

%s( Cha#+& Page .

%r( Pa#sh& It's easier to read. 1his is entitled, >Mother, my &uardian )ngel*!y Michael Jackson?


48/89

>The reflection of a mother$s heart is in the glimmer in her children$s eyes. Her every emotion and

feeling is somewhere in her child$s character. (oblemen are what their mother$s made them. !hy

does my mother cry" )re those happy tears or tears of sorrow" +h, please, &od, let them be happy

tears. )ll my success has been based on the fact that I wanted to make my mother proud, to win her

smile of approval.>

When yo" received that, Mrs. Jackson, ho did yo" feel$

%. I cried.

4. %nd ere yo" financially deendent on yo"r son Michael hile he as alive$

%. -es. Michael took care of me. My every need, my every ant. =e gave me everything.

4. 1he necessities of life, he rovided for yo"$

%. -es.

4. id he give yo" gifts$

%. %ll the time.

4. ars, #eelry, mo!ile homes, things like that$

%. -es.

4. id he give yo" money$

%. -es.

4. id he give yo" cash$

%. %lays.

4. Why not checks$

%. =e never rote checks.

4. id Michael rovide yo" ith moral s"ort$

%. -es.

4. an yo" tell "s ho have yo" !een affected !y the loss of the love, comanionshi, affection,s"ort, !y the loss of yo"r son, Michael$

%. 2c"se me. an yo" reeat$


49/89

4. /"re. 1he loss of yo"r son, Michael, the s"ort, the love, ho has that affected yo"$

%. When a mother loses a child, yo" 33 no one knos "ntil it haens

to them. 1hat's the orst thing that can haen to a erson, losing a child. I lost my mother, my fatherand my sister. I'm the only one left. B"t hen I lost Michael, I lost everything. =e as the most loving,

don to earth, he loved every!ody. Gery h"m!le. Gery h"m!le. I don't ant to !e moonalking at the age of 9.> and I tho"ght it asf"nny. %nd most of "s say things like that. I "sed to think that 9 as very old. I imagine yo"'ve said

that yo" didn't ant to !e in a co"rtroom racticing la at the age of 9, !eca"se yo" think that 33 !"t at

the age 33

4. =ere I am.

%. B"t at the age of 9, it's not as !ad as 33 yo" kno, yo"ng eole think that a 93year3old is an old

oman, and !y the time yo" get 9, yo" don't even feel old. I can vo"ch for that.

4.


50/89

4. Who ere yo" calling$

%. I called 0andy Phillis, and I called doctor 33 hat's the name$

4. r. 1ohme$

%. 33 r. 1ohme, first. %nd I told him, >Michael can't do those shos. 1hey have to change thesched"le of it.>

4. /o yo" ere #"st concerned a!o"t the sacing o"t of the concerts$

%. I as concerned a!o"t that. If they saced it o"t, he co"ld have done many shos.

4. id yo" visit Michael ever at the arolood home$

%. -es.

4. id yo" go there !efore he had his ress conference in ngland$

%. -es.

4. Before the ress conference, did yo" go in his !edroom$

%. -es.

4. Were there any doors locked at that time$

%.


51/89

4. !here is Michael" I

want to go see him.> %nd no!ody anted to tell me. %nd so they took me to a room, and I as sittingin there aiting. %nd so I g"ess they ere !ack there de!ating some!ody to come. %nd so Frank ileo

came and told me that Michael had a reaction. %nd I said, >!ell, how is he"> %nd no!ody said

anything at first. 1hey looked so f"nny. %nd I said, >!ell, did he make it" id he make it"> %nd Franksaid, >(o.>

4. What did yo" do$

%. I as 33 everything ent dark, and I #"st heard screaming.

4. id yo" see Paris and Blanket and Prince at this time$

%.


52/89

and said, >&randma, where are we going">

4. It's okay. We're going to get thro"gh this. id Paris say something to yo"$

%. Pardon$

4. id Paris say something to yo", Mrs. Jackson$

%. -es, she did. /he looked " at me and said, >&randma, where are we going"> %nd I told her,

>#ou$re going home with grandma.>

4. %ll right. I ant to sho 33 move off that 33 698836. 1his is a ict"re at the memorial service

(indicating). Is that yo" ith Blanket and Paris$

%. -es.

4. &kay. =as it !een a diffic"lt ad#"stment for the children itho"t their father$

%. 1he to !oys ad#"sted fine. I o"ldn't say >fine,> !"t 33 !eca"se yo" never kno ith theirthinking. B"t Paris had the hardest time. B"t I tho"ght she as the !ravest !eca"se 33 she had so many

ict"res of Michael. When I told her I as going to decorate her !edroom, and I !o"ght everything and

decorated. %nd I had some of my ict"res for her !edroom. %nd she said, >I have ict"res.> and she hada!o"t five !ig ict"res of Michael, and she said, >I ant these to over my !ed> and over her desk. /he

had them all over her room. %nd I as ondering, >=o co"ld she do that$> Beca"se I didn't ant to

see himD every time I sa him, I felt so sad. 1hen after e moved, she #"st had a collage. =er holeall, like the one yo" sa of the ho"se that Michael did for me. =er !edroom as #"st Michael's

ict"res.

4.


53/89

4. an yo" tell he misses his father$

%. &h, yes, he does.

4. she "t it in a illo, and she "t a !ell

aro"nd it, and she sat it on her !ed, and that's the ay she anted it.

4. =o has Paris !een affected !y the loss of her father$

%. &h, my goodness. /he 33 one of my grandchildren told me that she o"ld tell them that she anted

to go here daddy as.

4. /he had a hard time$

%. /he had a very hard time at first.

4. =as she had to get medical hel$

%. Pardon$

4. =as she had to get medical hel$

%. -es.

4. *o to the hosital$

%. -es.

4. =as she had a really hard time ith the loss of her father$

%. -es.

4. =o a!o"t Blanket$

%. Blanket as yo"ng. =e as seven hen Michael died. =e's 66 no. =e's come a long ay.

4. =o often as he ith his father$

%. veryhere Michael ent. 1he other kids ere in school, so everyhere Michael ent, he tookBlanket ith him.

4. +et me sho e2hi!it 698H36 (indicating). Is that Blanket$


54/89

%. 1hat's Blanket.

4. =e still have long hair$

%. -es.

4. oes he like long hair$

%. =e don't ant to c"t it !eca"se that's the ay Michael liked it. =e's 66, !"t he's going to have to c"t

it sooner or later.

4. -o" don't ant him ith long hair$

%. I don't ant the long hair, !"t he doesn't ant to c"t it so I'm not going to do it to him yet.


55/89

4. +et's talk a!o"t Michael !eing a father. o yo" kno if he anted to !e a father$

%. My goodness. More than anything else.

4. id yo" have occasion to talk ith him and o!serve him ith children$

%. -es. 1alked to him a lot.

4. =o o"ld yo" descri!e Michael as a father$

%. =e's one of the !est fathers. -o"'d !e s"rrised. -o" o"ld really !e s"rrised at hat a good father

he as. =e cooked for them. =e did all these things. %nd he never cooked !efore, !"t the kids think it's

the !est food they ever tasted.

4. id Michael's riting of m"sic change at all after he had children$

%. -es, it did.

4. =o$

%. Well, his m"sic as more, I sho"ld say, loving, more meaningf"l. =e rote from his heart more. It

#"st changed his life, and it reflected in his m"sic.

4. Is there a song that he rote that's very secial to yo" after his children ere !orn$

%. %fter$

4. %fter the children.

%. Were !orn, yo" said$

4. -eah.

%. I can't think of anything like 33 /eechless.

4. I kno heWrote that song, /eechless$

%. -es.

4. What is that song a!o"t$

%. 1hat song's a!o"t the love a erson had for their children. %nd hen it comes to descri!ing it,yo"'re seechless, !eca"se there are no ords to comare to ho yo" feel.

4. %nd did Michael rite that song in a long time or a short time$


56/89

%. In 5 min"tes.

4. o yo" kno here he as$

%. =e as somehere on the road. %nd *race told me

%r( Put#a& &!#ection. alls for hearsay, yo"r honor( S8 PNA%:4

Ju!+e& /"stained. *race told her.

%r( Pa#sh& 1hat's fine. 1hat's okay.

4. +et's ask? id yo" go thro"gh some videos and ict"res to make something, a tri!"te to Michael of

him ith his children ith the song that he rote a!o"t children$

%. -es.

4. %nd did yo" 33 hat's the name of the song$

%. >seechless.>

4. &kay. I'm going to mark 69. %nd I'm #"st going to lay it.

Pla#t""s; e7h)t #o( 102


57/89


58/89

4. If I ere to tell yo" that it as in /etem!er of 969, o"ld that so"nd right to yo"$

%. 1hat's a!o"t right.

4. %nd yo" !ro"ght this las"it on !ehalf of yo"rselfD correct$

%. -es.

4. %nd yo" also !ro"ght it as the g"ardian to Mr. Jackson's three childrenD correct$

%. -es.

4. %nd as it yo"r choice, Mrs. Jackson, to !ring this las"it$

%. -es, it as.

4. %nd did yo" ever talk to Mr. Jackson's children a!o"t hether or not to !ring this las"it$

%. I never talked to the children a!o"t it.

4. &kay. /o this as yo"r decision aloneD correct$

%. -es.

4. id yo" ever disc"ss it ith any of yo"r children rior to !ringing the las"it$

%. %fter.

4. %fter. %nd hat a!o"t ith yo"r h"s!and, Joe Jackson$ id yo" disc"ss it ith him$

%.


59/89

%. My family's famo"s. I haven't lived a very "!lic life !eca"se I as alays in the !ackgro"nd.

4. B"t yo" have given intervies on ateline, haven't yo"$

%. -es, I have.

4. &n 99$

%. -es.

4. H9 Min"tes$

%. -es.

4. &rah$

%. -es. 1hat as after my son died.

4. %nd hat a!o"t 33 yo"'ve come o"t ith !ooksD correct$

%. Pardon$

4. -o"'ve come o"t ith !ooks, ma'am$

%. -es.

4. Incl"ding the story of yo"r life$

%. -es.

4. -o"'ve gone on !ook to"rs$

%. -es.

4. %nd so hen yo" say that yo"r life is rivate, I #"st ant to "nderstand hat yo" meant !y that.

%. I don't "nderstand yo"r :"estion.

4. Well 33

%. What 33

4. 2c"se me, ma'am$

%. My life is rivate as m"ch as I can kee it rivate.

4. %nd yo" said a co"le times that yo"'re nervo"s, and I as hoing to "nderstand hy, ma'am. Why


60/89

are yo" nervo"s$

%. I'm " here talking in front of all these eole. I don't kno them. %nd I imagine anyone o"ld !e

nervo"s at first. I'm a little more calm no.

4. &kay. %nd yo" said that yo" !ro"ght the las"it !eca"se yo" anted to search for the tr"thD is that

right, ma'am$

%. -es.

4. %nd is that hat yo"'re hoing ill come o"t of this las"it$

%. I ant to find o"t, and I think I oe it to my son to find o"t hat really haened to him. I've had 33

heard a lot of stories, and I kno and I even heard from my grandchildren after my son died that myson as !eing ress"red, and he as asking for his father. %nd the kids o"ld tell him he didn't kno

hat to do. My son as sick, and no!ody is like 33 I can't think of 33 enny &rtega said they o"ldn't

even hand him a hot c" of tea, and they kne he as sick. %nd instead of calling 33 no!ody said,

>+et's call the doctor. +et's see hat's rong ith him.>


61/89

%. -es.

4. %nd, ma'am, hen yo" talk a!o"t eole calling the doctors, I mean, yo"'ve heard eole testifya!o"t trying to reach the doctor or reach the doctor or call the doctor$ id yo" hear that, ma'am$ id

yo" hear the testimony$

%r( Pa#sh& Gag"e and am!ig"o"s as to time.

he /t#ess&


62/89

%. Mr. Jackson as sick, and he co"ldn't rehearse.

4. Well, for e2amle, yo" heard the testimony, did yo" not, ma'am, here it talks a!o"t the fact that he

didn't like to rehearse for the dangero"s to"r$

%. -es.

4. %nd did yo" hear the testimony here he said he didn't like to rehearse for the history to"r$

%. laCy,> yo" don't remem!er hat that asD is that correct, ma'am$

%r( Pa#sh& &ther than hat she already testified to$

%r( Put#a& @h3h"h. -es, sir.

he /t#ess&1hank yo".

4. Is that correct, ma'am$


63/89

%. What's correct$

4. 1hat hen yo" said that it's hard to sit here and listen to these !ad things, one mentioned the idea 33

the email here Mr. *ongaare said that he as laCy, and I'm asking yo" if yo" can remem!er hatother !ad, "ntr"e things yo"'ve heard in the last 6 eeks$

%. 1hey called him a freak.

4. %nd yo"'re talking a!o"t the email 33

%. 1hey ere making f"n of him. >Finally get a chance to meet the freak.>

4. %nd are yo" talking 33

%. %nd yo" kno 33

4. -o"'re talking a!o"t an email from someone ho isn't a arty to this las"itD correct, ma'am$ 1hat

as some!ody o"tside of the efendants in the las"it ho said that. o yo" remem!er that, ma'am$

%r( Pa#sh& I'm going to o!#ect. It's not o"tside the defense. It's the general co"nsel layer.

%r( Put#a&


64/89

4. %nything else, ma'am$

%. My son is dead. =e's not here to talk for himself, so anything !ad that's said a!o"t him h"rts very

m"ch.

4. B"t 33

%. %nd some eole love doing that to him.

4. oing that to yo"r son$

%. -es.

4. In fact, that as one of the hard things for yo", I'm s"re, the last fo"r years of all the !ad things thatere said a!o"t yo"r sonD correct, ma'am$

%. -es.

4. %nd that's !eca"se eole didn't kno the Michael Jackson yo" kneD correct, ma'am$

%. 1r"e.

4. 1hey only kne hat they sa e2ternallyD they didn't kno hat he as act"ally like rivatelyD

correct, ma'am$

%. -es.

4. In yo"r attorney's oening statements, he said that yo"r son, Michael Jackson, as a dr"g addict.

-o" remem!er hen he said that$

%r( Pa#sh& &!#ection. Misstates hat I said.

Ju!+e& &verr"led. 1he #"ry ill remem!er hatever yo" said.

4. 0emem!er that, ma'am$

%.


65/89

%. -es, it o"ld !e hard to listen to.

4. /o that as hard to listen to as ellD correct, ma'am$

%. I don't even remem!er him saying that, to tell yo" the tr"th.

4. -o" don't, ma'am$

%.


66/89


67/89

%r( Put#a& I accet the sti"lation. I ant to kno if she kne that.

%r( Pa#sh& It's irrelevant.

Ju!+e& /"stained. 1he sti"lation acceted. 1he #"ry has to accet it. It's tr"eD it's sti"lated. %nd it's

also 6?99. /o 6?89.

he ury e7ts the $ourtroo4

Ju!+e& &kay. 6?89.

Lu#$h )rea.4

he "ollo/#+ pro$ee!#+s /ere hear! # ope# $ourt6 outs!e the prese#$e o" the ury4&

%r( Pa#sh& Ms. Jackson got less than three ho"rs slee, she as sleeing at l"nch, I think an ho"r or

so ill ro!a!ly !e her limit. Mr. P"tnam s"ggests ho"rs, so I don't think e'll finish today. I informed

Mr. P"tnam of that.

Ju!+e& &kay. We'll do as m"ch as e can.

%r( Pa#sh& &kay. I #"st don't ant her to !e too tired.

he "ollo/#+ pro$ee!#+s /ere hel! # ope# $ourt6 # the prese#$e o" the urors4&

Ju!+e& atherine Jackson vers"s %* +ive. -o" may contin"e ith cross e2amination

%r( Put#a& 1hank yo", yo"r honor.

Co#t#ue! $ross e7a#ato# )y %arv# Put#a&

4. Mrs. Jackson, yo" remem!er earlier, !efore l"nch, I indicated if yo" had to sto at any time, e

co"ld, right, ma'am$

%. -es.

4. %nd I've !een told that yo"'d like to go only a!o"t another ho"r todayD is that correct, ma'am$

%. -es.

4. /o I'm going to try to get a little !it in thereD and then in a!o"t an ho"r, e'll !reak. %ll right,

ma'am$

%. -es, thank yo".

4. /o here e left off, yo" had indicated that in 33 in !ringing this las"it, yo" hadn't soken to yo"r

grandchildren and yo" hadn't soken to yo"r si!lings and yo" co"ldn't remem!er conferring ithanyone else !efore yo" !ro"ght the las"it e2cet yo"r attorneysD is that correct, ma'am$


68/89

%. -es.

4. %nd this as in /etem!er of 969$

%. I don't remem!er, !"t yo" remind me.

4. &kay. If I ere to reresent to yo" that it as /etem!er 6, 969, o"ld that so"nd right, ma'am$

%. /o"nds right.

4. %nd can yo" recall that this as !efore there had !een a criminal trial of r. onrad M"rray$

%.


69/89

%r( Pa#sh& B"t if she disc"ssed it ith her attorneys 33

Ju!+e& Well, hat yo" can do is erhas hrase it, >indeendent of any conversations yo"'ve had 33>

%r( Put#a& I'd !e hay to. %!sol"tely, yo"r honor.

Ju!+e& If there is no indeendent, then 33

4. /o, Mrs. Jackson 33 ell, let me ask it this ay? id yo" consider anything in !ringing this las"it

indeendent of yo"r disc"ssions ith yo"r attorneys$

%. -es.

4. -o" did. %nd did that incl"de the criminal trial of r. onrad M"rray$

%. %fter atching.

4. %fter atching$

%r( Pa#sh& &!#ectionD the las"it as filed. =e said !efore the criminal trial, so ho co"ld it have

anything to do ith this$

%r( Put#a& 1hat's hy I'm asking.

Ju!+e& &verr"led.

he /t#ess& I don't "nderstand a lot of things yo"'re saying. I hear yo", !"t 33

%r( Put#a& +et me try to !reak it don for yo" a little !it. &kay, ma'am$

4. -o" filed yo"r las"it in /etem!er of 969, correct$

%. -es.

4. %nd if I "nderstand correctly, yo" didn't consider anything 33 yo" didn't have conversations ith

anyone other than yo"r attorneys a!o"t !ringing that las"it, correct$

%. J"st 33 #"st the attorneys.

4. J"st the attorneys, right, ma'am$ 1here as no!ody else yo" talked a!o"t yo"r considerations in!ringing a las"it rior to !ringing the las"it, correct$

%. orrect.

4. %nd hen yo" ere thinking a!o"t hether or not to !ring that las"it, as a consideration at that

time the fact that r. onrad M"rray as going to !e having a criminal trial$

%r( Pa#sh&


70/89

co"ld something else !e a factor$

Ju!+e& If it's indeendent of the attorneyclient 33 yo" need to make it clear to her so she's 33 the fear is

that she's going to inadvertently disclose comm"nications ith her attorney, so 33

%r( Put#a& +et me !e very clear, Ms. Jackson. I don't ant to kno anything that yo" disc"ssed

ith yo"r attorneys ever. %ll right, ma'am$ Before the las"it or after the las"it. 1hat's not hat I'masking for. What I'm trying to determine, ma'am, is yo"r indeendent considerations, hat yo" yo"rself

tho"ght a!o"t o"tside of those conversations ith yo"r attorneys.

4. Was there anything that yo" considered e2cet hat as given to yo" !y yo"r attorneys in terms of!ringing this las"it$

%r( Pa#sh& I'm going to o!#ect to >What as given to yo".> I mean, e #"st disc"ssed 33 there 33 Io!#ect to the :"estion, >given to.>

Ju!+e& &verr"led.

he /t#ess& I'm getting conf"sed the ay he's asking the :"estions.

4. Was there anything yo" tho"ght a!o"t other than yo"r disc"ssions ith yo"r attorneys hen yo"decided to !ring this las"it, ma'am$

%. 0eeat yo"rself.

4. &f co"rse. Was there anything other than yo"r disc"ssions ith yo"r attorneys that yo" considered

in deciding to !ring this las"it in /etem!er of 969$

%. Before conrad M"rray's trial$

4. It as, in fact, !efore r. onrad M"rray's trial, ma'am, yes.

%. I don't remem!er.

4. %ll right. %nd is it fair to say as yo" sit here today, ma'am, that yo" don't remem!er hether r.

onrad M"rray's trial as !efore or after yo" !ro"ght yo"r las"it$

%. -o"'re the one that got me conf"sed.

4. =o did I get yo" conf"sed$ id I get yo" conf"sed 33

%. I #"st don't remem!er.

4. id I get yo" conf"sed !eca"se I let yo" kno that the las"it ith r. onrad M"rray as afteryo"r las"it$ Is that hat conf"sed yo"$

%r( Pa#sh& First of the all, there's no las"it.


71/89

%r( Put#a& riminal trial.

%r( Pa#sh& It's also irrelevant.

%r( Put#a& I don't !elieve it's irrelevant, yo"r honor.

%r( Pa#sh& 0elevant for hat$

Ju!+e& &verr"led. &kay. Why don't yo" #"st sti"late that that's the time frame$

%r( Pa#sh& We already did. 1hey kno hen the case as filed. =e's already testified.

%r( Put#a& Move to strike, yo"r honor, his comments.

%r( Pa#sh& Mr. P"tnam has already said the dates. We're not dis"ting the dates. %gain, there's no

iss"e a!o"t that.

%r( Put#a& I'm trying to "nderstand her reasons s"ort !ringing the las"it, yo"r honor.

%r( Pa#sh& =er reasons for !ringing 33

%r( Put#a& I'm s"re yo"'d like to say hat they are. %nd hat I'm trying to determine is if there's

anything indeendent of the conversation she had ith these attorneys that as relevant to !ringing this

las"it.

Ju!+e& Well, yo"'ve asked a co"le of times. I'll let yo" ask it one more time, !"t yo"'ve asked a

co"le times already. B"t 33

%r( Put#a& %nd I haven't gotten an anser yet, I'm trying to fig"re o"t a ay to ask it 33

%r( Pa#sh& /he has ansered the :"estion.

Ju!+e& %sk it one more time.

4. Mrs. Jackson, e2cet for conversations that yo" had ith yo"r attorneys, as there anything

indeendent of that that yo" considered hen deciding to !ring yo"r las"it 33 this las"it in

/etem!er of 969$

%. I don't remem!er.

4. /o this las"it starts in /etem!er of 969. o yo" remem!er that once the las"it started, each of

the sides asked the other side for information and gave each other doc"ments$ o yo" remem!er

anything a!o"t that, ma'am$

%. -es.

4. %nd do yo" recall yo"r roviding any doc"ments to the efendants in this case, yo" yo"rself,ma'am$


72/89

%. an yo" reeat yo"r 33

%r( Pa#sh& -o" mean thro"gh her attorneys$

%r( Put#a& -es, thro"gh her attorneys.

Ju!+e& Make it clear. Beca"se she's not going to !e alking over to yo"r office and handing them to

yo", so make it clear that 33

4. Mrs. Jackson, did yo" rovide any doc"ments to yo"r attorneys so that they co"ld give them to "sin the three years !eteen the start of this las"it and o"r !eing at trial in this las"it$

%. My doc"ments$

%r( Pa#sh& Wait a min"te. Wo"ldn't that !e attorneyclient rivilege, hat she rovided to "s$

Ju!+e& &verr"led.

he /t#ess& -es.

4. -o" gave some doc"ments$

%.


73/89

%r( Pa#sh& 1hat's okay.

Ju!+e& Well, I #"st o"ld make a s"ggestion. J"st try to !e clear ith some of the :"estions !eca"se,o!vio"sly 33 !reak them don a little !it, esecially hen she's it's toard the end of the day, and

she's getting tired.

%r( Pa#sh& It's very fast, the :"estions.


74/89

agreement that e laced on the record, and that time eriod hasn't e2ired yet.

%s( Ste))#s& Monday as the day she as s"osed to revie. 1he imression I got from her

co"nsel as that she o"ld !e availa!le to testify ne2t eek. I'm not ositive, !"t e sho"ld confirmthat, !eca"se if she is 33 and there are some iss"es ith her testimony that e may !e addressing, !"t 33

Ju!+e& Is she going to !e designated or aearing live$

%s( Cha#+& We have to check ith her attorney, deending 33 #"st so the co"rt knos, she has a very

serio"s l""s condition 33

%r( Pa#sh& Is this rivileged, rivacy for her$

%s( Cha#+& I g"ess I sho"ldn't state it, !"t I'll "t it in a !rief "nder seal, !"t she has some severehealth iss"es, and I have to address them ith her attorney.

%s( Ste))#s& -o"r honor, I don't think there's any ay she co"ld aear !y designation. 1he hole

"rose of her deosition, if yo"'ll recall, as she as not deosed d"ring discovery. /he testified sheactively evaded discovery. /he then 33 Plaintiffs said they anted to add her to the list. %arently at

the time they said they had !een comm"nicating ith her for a co"le of months.

%s( Cha#+& an e add some!ody$>

Ju!+e& I remem!er.

%r( Put#a& %nd yo" said, >-o" can add them as long as yo" get to deose them.> it as not that

they get to deose them and then "t her on not live.

Ju!+e& Why didn't yo" cross, then$

%s( Cha#+& /he did, for ho"rs.

%s( Ste))#s& I asked :"estions, yo"r honorD !"t it as an e2loratory deosition ith 33 my

"nderstanding 33 e can arg"e this 33

%r( Pa#sh& We don't need to arg"e this right no.

%s( Ste))#s& =ere's the iss"e, yo"r honor, in a n"tshell. I as trying to get hat the sense of her


75/89


76/89

Ju!+e& I as s"rrised to see -o"ng there !eca"se Plaintiffs have never mentioned -o"ng !efore.

%s( Ste))#s& We ere, too, yo"r honor. %nd e filed an o!#ection today !eca"se e !elieved that

o"ld !e c"m"lative. B"t e don't ant to !egin o"r case itho"t knoing that they've finished theirs.

Ju!+e& /ometimes yo" have to.

%r( Pa#sh& It haens like every trial.

Ju!+e& 1hey're not alays that nice and neat and tied " in a !o.

%r( Pa#sh& %nd they already did start their case.

%s( Ste))#s& B"t e'd like to have some idea, yo"r honor, is there one itness o"tstanding$ 1o$Fo"r$

Ju!+e& 1hat's fine.

%r( Pa#sh& 1hey already did start their case. 1he ay these things go, they had to call itnesses in

o"r case, if e recall that. /o hen they say, >We don't ant to start o"r case,> they already started it a

long time ago !y calling o"t of order to itnesses !eca"se of sched"ling.

Ju!+e& -es. 1he oint !eing 33

%r( Pa#sh& I "nderstand the oint.

Ju!+e& 33 they ant to kno ho many yo" have left.

%r( Pa#sh& 1hat's not a ro!lem.

%s( Ste))#s& We're not trying to !e infle2i!le if there's legitimate sched"ling iss"es.

%r( Pa#sh& 1he only iss"e that I kno right no, other than 33 Ms. 0aram!a, o"ld !e it. I don't

kno of any other.

Ju!+e& &rtega.

%r( Pa#sh& &rtega and 0aram!a.

%s( Ste))#s& /o not Ms. -o"ng$

%r( 5oyle& We're going to revie yo"r o!#ections and let yo" kno.

%r( Pa#sh& &ther than that, that I kno of at this oint, s"!#ect to ortega, nothing else.

Ju!+e& What is roma -o"ng$

%s( Ste))#s& % defense =0 e2ert. We intend to call her live in o"r case at resent, and I've told


77/89

Plaintiffs' co"nsel that.

Ju!+e& /o yo" ant to call her in yo"r case$

%s( Ste))#s& 1hey ant to "se a small ortion of her video deosition to !olster their on =0 e2ert

o"t of conte2t. It's c"m"lative of testimony !y Mr. 1rell and Ms. /earight and a !it of detective

martineC. 1here's no "rose to that. We've o!#ected to it as c"m"lative, e've also rovided co"nterdesignations sho"ld the co"rt 33

Ju!+e& 1hat so"nds c"m"lativeD and if they're going to call her in their case 33

%r( Pa#sh& 1hey didn't say there ere.

%r( 5oyle& We think their e2ert said some things that are helf"l to "s. If they'resaying their e2ert is c"m"lative to o"rs, hy can they call her$ B"t I ill look at their o!#ections.

%nd, also, they kee saying, >We intend to call her at resent.> if they 33 I already told

Ms. /te!!ins if they are committing to calling her, e don't even need to fight this fight. B"t they, of

co"rse, are not committing to doing that.

%s( Ste))#s& -o"r honor, hat I told Mr. Boyle is at resent e 699 ercent intend to call her.

1here's alays the ossi!ility 33 I don't kno, it's the end of /etem!er and e're trying deserately toc"t 33 something may haen. I don't think e're going to get to that oint, !eca"se o"r intention is to

finish in a"g"st, as e said the other dayD and I !elieve Ms. -o"ng ill !e called d"ring that eriod.

1hat is my reresentation at this time. B"t her testimony, o!vio"sly, is not c"m"lative of Ms./earight's. It's contrary to Ms. /earight's. 1hey've gone thro"gh and cherry3icked a co"le of

oints o"t of conte2t to try to !olster Ms. /earight. It's not roer and it's c"m"lative.

Ju!+e& If that's the case, ro!a!ly not going to allo it in yo"r case. It's c"m"lative.

%r( Pa#sh& B"t yo" haven't heard anything.

Ju!+e& -o"'re right, I haven't looked at it.

%r( 5oyle& May!e a sol"tion is if they don't call her, e raise it later, lay this short video cli.

Ju!+e& +ike re!"ttal$

%r( Pa#sh& I as reading the transcrit 33 #"st I ant to clear something " !eca"se I asn't here

hen there as a hole disc"ssion a!o"t r. Bron's testimony. %nd I read the ro"gh transcrit, and

Mr. P"tnam as :"estioned !y the co"rt, >%re yo" calling r. M"rray$> and the ro"gh transcrit said>We don't intend to call r. M"rray "nless e are re:"ested to.>

%r( 5oyle& >@nless yo" re:"est it, yo"r honor.>

%r( Pa#sh& %nd no the other transcrit has !een changed to say something different. /o hat I

o"ld #"st like is some clarification on that iss"e. Beca"se I tho"ght yo" asked Mr. P"tnam, and I

asn't here, so I'm only reading the transcrit 33 !eca"se this hole r. M"rray 33 I as reading thearg"ment, and I tho"ght it said, >Mr. P"tnam, are yo" calling r. M"rray$>


78/89

Ju!+e& I did ask that.

%r( Pa#sh& &kay. %nd Mr. P"tnam gave a resonse on the recordD and hat I o"ld like 33 !eca"sethe to transcrits are different, I o"ld like to kno hat is the resonse.

%s( Ste))#s& -o"r honor, e didn't ask for any modification of the ro"gh, so I o"ld ass"me thefinal transcrit is hat the co"rt reorter took don and hat as act"ally said.

Ju!+e& What did the final say$

%r( 5oyle& It says >e 33 I 33 I ersonally do not intend to call r. M"rray "nless it's re:"ested, yo"r

honor.> hat does that mean$

%r( Pa#sh& B"t ho is going to re:"est it$

%r( Put#a& I don't think I o"ld say that, !"t I don't kno 33

Ju!+e& ven if yo" did, hat's the significance$

%r( Pa#sh& I don't kno. If e're going to rest 33

Ju!+e& -o" have a do"!t as to hether they are going to call him or not$

%r( Pa#sh& 1hat's all I ant to kno is the anser to the :"estion.

Ju!+e& I think the anser to the :"estion is ro!a!ly no. 1he anser has to !e no. I don't kno hothey're going to get M"rray o"t of c"stody and in here.

%s( Caha#& It also attri!"tes it to me, and I did not anser that :"estion.

%r( Pa#sh& 1hat's hat I'm saying. 1here seemed to !e an error in the transcrit, and that's hy I'm

asking, for hatever reason.

Ju!+e& I'd !e s"rrised if 33

%s( Ste))#s& +et's look at the final transcrit.

%r( Pa#sh& Well, hat is the anser$ -o" can #"st clarify it and then e don't have to orry a!o"t it.

%r( Put#a& -o"r honor asked me if my resent intention as to call himD and as I indicated, my

resent intention as not to call him.

%r( Pa#sh& 1hat asn't the :"estion, hether it as yo"r resent intention.

%r( Put#a& /he said, >o yo" intend to call.> I ass"me she meant at that oint.

%r( Pa#sh& verything is like that ith them.


79/89

%r( Put#a& Well, I s"sect she asn't saying a month from no, might I intend. /he had to indicate

hat did I intend to do at the time. In my case, I do not intend to call 33

Ju!+e& Well, let's o"t it this ay. If yo" intend to call r. M"rray, there's a hole heck of a lot of other

things that need to !e done !efore that ill haenD a very lengthy hearing, his attorney has to !e

resent, there has to !e all kinds of things that have to !e done !efore he co"ld testify.


80/89

%s( Ste))#s& If I "nderstand correctly ith regard to Ms. -o"ng, Plaintiffs are not going to call her

no. If e do not call her in o"r case, they may raise the iss"e again, e'll still o!#ect to it as

c"m"lative and raise it at that time.

%r( 5oyle& 0eserving all rights, yes.

%s( Caha#& Based on the reresentation that e're going to finish ith Ms. Jackson, and Mr. &rtega

and Ms. 0aram!a ill !e dealt ith searately, e've !een rearing to arrange itnesses for ne2t

eek. In the conte2t of that, e reared some deosition designations. %s yo"r honor may remem!er,

hen e started the case, Plaintiffs' co"nsel designated 9 deositions, and e had 5; ho"rs to doco"nters, designations and o!#ections to those. 1hey all got lodged ith the co"rt, and then they ere

"nhay ith the designation co"nted as 33 e had a difference of oinion. %nd on may 6st, yo"r honor

said, >Well, hatever yo" ant to do ith the designations, Plaintiffs, in essence, I'll give yo" a eekto revise hatever yo" ant, and then e'll do that.> so !"t !efore that haened, e had essentially a

five3day rocess that as disc"ssed and agreed to at the final stat"s conference here deositions ere

rovided, there as 5; ho"rs to do co"nter designations and o!#ections, another 5 ho"rs to do

resonses or o!#ections to the co"nter designations, and then they o"ld !e filed and r"led on. &nMonday evening, in rearation for ne2t eek, e sent Plaintiffs' co"nsel fo"r deosition designations.

&ne as one that e had sent them !ack in may, !ack hen they said, yo" kno, >We don't ant to

deal ith these d"ring o"r case, !"t e'll get hatever yo" need done :"ickly hen it's time forefendants to start their case.> one of them didn't need to !e modified !eca"se it had !een sent over

revio"sly. 1he other three, they had for three days. We got one !ack at the end of the day yesterday.

%fter a lengthy e2change of emails ith Plaintiffs' co"nsel, they gave "s a second one aro"nd 66?89 lastnightD and e haven't gotten the the to that e have have gotten !ack, hich are r. Farshchian and

r. /a"nders, e've lodged the transcrits and given the com!ined charts to yo"r honor. I think one

as #"st filed at l"nch. We o"ld ask if yo" co"ld lease try to look those over :"ickly, e'd areciatethat, !eca"se e'd like to lay those videos ne2t eek.

Ju!+e& I'll !e looking over them as soon as I can.

%s( Caha#& We don't kno hen e'll !e getting the third one !ack, r. aCakhi.

%r( 5oyle& 1hey gave "s fo"r at 69?89 on Monday, e've given them three of the fo"r !ack, and I gotthe fo"rth one in my email hile Mrs. Jackson as on the stand, I haven't looked at it yet. o I need to

address the ream!le that she gave$ 1hat's really not acc"rate, a!o"t the 5; ho"rs and all that st"ff. B"t

if I don't need to address it, I on't.

%s( Caha#& What e o"ld like, yo"r honor, is some clarity going forard !eca"se e didn't e2ect

that three short designation, giving them three days, o"ld !e a ro!lemD and e #"st need to make s"rethat e're not going to !e "tting yo"r honor "nder "nd"e ress"re or interr"ting the flo of o"r case,

and so may!e e need to reesta!lish an aroriate time frame.

Ju!+e& Well,ho many more designations, deo 33

%s( Caha#& We act"ally have :"ite a lot !eca"se e have so many hysicians and eole ho are o"tof state. 1hey are largely short. Most of them are !eteen half an ho"r to an ho"r. %nd e're hay to


81/89

send them on a rolling !asis. 1here's one more that e o"ld like to !e a!le to lay ne2t eek that ehaven't sent over yet, e can do that today. B"t I think e #"st need some clarity on the rocess to

make s"re that the co"rt has eno"gh time, that e have eno"gh time, and that Plaintiffs have eno"gh

time so that as e're sending them on a rolling !asis, e have some kind of ass"rance that e'll !egetting them !ack on a reg"lar !asis.

Ju!+e& Mr. Boyle 33

%r( 5oyle& Whatever the r"le as, e're fine ith.

%s( Caha#& 5; ho"rs.

%r( Pa#sh& It as five days, according to Ms. /trong.

%s( Ste))#s& %t one oint, e had a to3art system. %fter there as some concern ith the initial

timeta!le, hich as 5; ho"rs, it as then set " that it o"ld !e 5; ho"rs for riority and five days for

non3riority. I don't kno hether that's orka!le ith 33 if it is, e can 33

%r( 5oyle& 1hey're trying to shorten the time on "s, hich is fine. We said e'll ork hard ith them

to hel. 1hey gave "s fo"r at 69?89 on Monday night, e got three of the fo"r !ack, e're getting the

fo"rth !ack, all ithin the five3day eriod that Ms. /trong demanded. /o this is a non3iss"e that 33 Ithink hat they're asking yo" is they ant a shorter time frame, is hat they're asking, !"t they're

afraid to ask it.

%s( Caha#& I o"ld ask that e have the same arrangement that Plaintiffs had and they made "s do 33

e did 6; sets of co"nter and o!#ections on 5; ho"rs notice in a one3eek eriod, and that re:"ired a

lot of o"r time to 33

Ju!+e& %re yo" asking they do the same$ -o" ant to do 6; 33

%s( Caha#&


82/89

the ones that e sent over this eek ere, altho"gh e gave them A ho"rs, and five days for anythingthat's not a riority, and e ill send them on a rolling !asis 33

Ju!+e& Is that acceta!le or not$ If not, hat's yo"r alternative$

%r( Pa#sh& I o"ld say three days is fine 33

Ju!+e& -o"'re not doing it. Isn't Mr. Boyle doing it$

%r( 5oyle& Most it.

Ju!+e& Mr. Boyle has !een doing all this ork on the deos.

%r( Pa#sh& 1hey can't send it at 69?59 at night, yo"r honor. It sho"ld !e !"siness ho"rs.

Ju!+e& I'm s"re they get it as soon as they can.

%r( Pa#sh& %ll of a s"dden fo"r of them come Monday night at 69?59$

%s( Caha#& My email as at ;?6 .M., for the record.

Ju!+e& It's a !"sy trial day.

%s( Caha#& We're all orking aro"nd the clock, e're doing things as soon as e can, and I anted toget them to them Monday night as oosed to t"esday morning to give them more time to get it !ack to

"s.

%r( 5oyle& It as kind of a !"sy eek for "s, yo"r honor.

Ju!+e& I "nderstand. -o"'re !"sy trial layers, I get it. What I'm trying to get is hether 33 Mr. Boyle,hat can yo" ork ith$ an yo" ork ith that sched"le$

%r( 5oyle& I can ork 33 three days o"ld !e refera!leD !"t if they are dying to fill a slot ith a

itness, #"st like they've done, they tell "s, >look, e really ant to lay this one on 2 day,> e ill "tit " and do it in to days.

%s( Caha#& A ho"rs for all the co"nters and o!#ections is fine for "s, yo"r honor.

Ju!+e& If there's an emergency, he said 33

%r( Pa#sh& %ll right. Forget it.


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%r( Pa#sh& =o do yo" kno I'm not doing that$

Ju!+e& Beca"se he's the one that's doing all the deos.

%r( Pa#sh& &kay, yo"r honor.

%r( 5oyle& =o a!o"t three and five$ If they have a non3riority, they're ro!a!ly not going to lay itanyay.

%s( Caha#& We're only sending ones e intend to lay.

%r( Pa#sh& %s of today. Present intention.

Ju!+e& /o, Mr. Boyle, I ant yo" to recite hat yo"r agreement is.

%r( 5oyle& 1hree days riority, five days non3riority. %nd if they have an "rgent thing here they

ant it and it's a short one sooner than three days, e'll ork ith them and try to get it done.

%s( Caha#& 1hat's fine, yo"r honor.

Ju!+e& &kay. 1hank yo".

%r( Pa#sh&


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Ju!+e& /o yo" may have to call m"ltile itnesses$

%r( Put#a& -es. 1he reason e're asking a!o"t the sched"le, making s"re the three and five and

everything, is e're trying to make s"re e can do this as efficiently as ossi!le. %nd e're hoing tocall many each day !eca"se e ant to get thro"gh this. 1hat's the resent intent, hich is also hy on

the front end e're trying to set it " to "nderstand hat the arameters are so e can roerly

sched"le 33 a n"m!er have !een in a holding attern !eca"se e had told almost all of them to free "the time eriod a!o"t a month ago. /o it's a little later, so e're having a little more tro"!le than e

e2ected in trying to get eole into certain sots.

%r( Pa#sh& If they ask "s, e're certainly illing to ork ith them on sched"ling a itness. =avinghad the ress"re on "s, e "nderstand it's diffic"lt. We're more than illing to ork ith them on any

sched"ling iss"es. If they need a video done in 5 ho"rs !eca"se they don't have someone the ne2t day,

e're illing to ork ith them !eca"se it's also o"r intention to get this done as :"ickly as ossi!le.We're more than hay to ork ith them.

%s( Ste))#s& &n the s"!#ect of Plaintiffs' case, yo"r honor, the one o"tstanding iss"e, then, o"ld !e

Mr. 1aylor's deosition. &!vio"sly, e think yo"r tentative is correctD and I don't kno if Plaintiff stillanted to "se that deosition or if they anted to arg"e that. B"t e if they anted to do that, e

sho"ld do it !efore their case closes.

Ju!+e& +et's talk a!o"t it no.

%r( Pa#sh& an e get o"r st"ff together$

Ju!+e& -es.

%r( Put#a& In terms of o"r sched"le, hen ill e kno if yo"'re calling Ms. 0aram!a on

Monday$

%s( Cha#+& %s soon as I can find o"t. I ill email #essica. Is that okay$

%s( Ste))#s& -es. &!vio"sly, e need some time to re, so 33

%r( Pa#sh& We're going to tell yo" ithin the 5;3ho"r r"le, right$ By 7?89 tomorro. Is that the 5;3

ho"rs$

%r( Put#a& -esD and then I ill let yo" kno as soon as I can thereafter if yo" ill then !e resting

yo"r case e2cet for o"tstanding itnesses.

Ju!+e& 1his hole thing a!o"t yo" have to rest 33

%r( Pa#sh& 1hat's not ho it orks.

Ju!+e& 1hey don't have to formally rest for yo" to start calling yo"r itnesses.

%r( Put#a& I agree, yo"r honor.


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Ju!+e& /o if I tell yo" yo" "t on a itness, yo" "t on a itness.

%r( Put#a& %nd I ill do that, yo"r honor.

Ju!+e& 1hey don't have to formally rest. /ame thing 33 ait a min"te. Why are yo" to talking hen

I'm trying to address 33

%s( Cha#+& I'm sorry.

%r( Put#a& -es, yo"r honor.

Ju!+e& In order to move the trial along, e take the itnesses as they come. &kay$ %nd they'll rest

hen aroriate. It's not going to affect anything. It's #"st a formality. 1here are motions for nons"it,

that 33

%r( Put#a& 1here are motions that come in.

%r( Pa#sh& B"t they'll still do the motions anyay. It doesn't matter.

Ju!+e& /o !e reared, is all I'm saying, and don't e2ect them to rest cleanly. 1here's going ossi!le a

dangling itness o"t there. It doesn't really make any difference.

%r( Put#a& 1hat's hat e're trying to ask, yo"r honor. We're trying to ask 33 e e2ect something

to !e dangling o"t there, and I'd like to kno hat that is.

%r( Pa#sh& I o"ld say this. I o"ld !e ready to call itnesses as soon as yo" think yo"'re going to

finish ith Ms. Jackson, #"st in case.

%s( Ste))#s& %s Ms. hang as #"st ointing o"t 33 I did say that I o"ld !e fle2i!le and ork ithMs. 0aram!a ith any sched"ling iss"esD !"t at the same time, e o"ld like her to go as soon asossi!le !eca"se since she's art of Plaintiffs' case.

%s( Cha#+& I aologiCe to the co"rt. I didn't mean to !e talking hen yo" ere talking. I as trying to

ork something o"t ith Jessica 33 ell, Ms. /te!!ins Bina, and I as reminding her of a conversatione had here e told the co"nsel !eca"se e kne she had treatment, she co"ld have more time if she

needed to revie the transcrit. It's three vol"mes, !eca"se it ent on three different days. /o !asically

she 33 she has to revie it, and I ill find o"t, and I ill comm"nicate directly ith her, and e illork together as e told her e o"ld.

%s( Ste))#s& %t the close of the last day, yo"r honor 33 these ere artial days, I got a!o"t fo"r and ahalf ho"rs. B"t at the close of the day, Ms. 0aram!a and her co"nsel reresented that they o"ld

revie the transcrit on Monday and sign off on it !y Monday. I don't have any reason to !elieve that's

not the case. %t this oint, erhas Ms. hang knos something I don't.

%s( Cha#+& I kno nothing. I've !een here.

%s( Ste))#s& I e2ect the deosition transcrit ill !e finaliCed on Monday so she can go 33


86/89

%s( Cha#+& I'm #"st reminding every!ody that e had indicated if she needs more time, e're hayto ork ith her. /o I have no idea, she has no idea. I ill find o"t and comm"nicate ith the other

side.

%r( Pa#sh& Who is her layer$

%s( Cha#+& an "n!ar.

%r( Pa#sh& Why don't yo" #"st call him$

%s( Cha#+& I ill. an I !e e2c"sed, yo"r honor, to ork on that$

Ju!+e& -es. id yo" get all the items yo" needed for the ro!ert 1aylor motion$

%r( Pa#sh& -es, I think so.

%r( 5oyle& -es.

Ju!+e& 1his is a hile ago.

%r( 5oyle& -o"r honor, e read yo"r tentative and "nderstand the co"rt's osition. &"r osition issimly that Mr. 1aylor testified to an inconsistent statement of Mr. 1rell regarding %* emloying r.

M"rray. Mr. 1aylor as asked :"estions, "-o this was -hawn Trell telling you that )& !as

employing r. /onrad Murray on the instruction of 00* Answer,*of Michael.*Question,*of Mr.

ackson"*Answer,*/orrect.*/o that as o"r intention for "sing Mr. ay elementary, along ith

some other things regarding the ins"rance. It as a different case, o!vio"sly. It as a case that %*

=ad !een involved in. We !elieve their interests ere still reresented !eca"se of their o3efendantas still in the case at the time of this deosition, reresented !y co"nsel, ho also reresented %* In

that litigation. /o e !elieve they, in essence, had reresentation at that deosition hich, "nder ther"les, o"ld allo "s to "se that in o"r case.

%r( Pa#sh& -o"r honor, #"st 33 in 667, it looks at the interest of the arty as to hether or not a

deosition can !e "sed !eca"se

%* as a arty in the case. 1hey ere also reresented at the time !y the same layer that contin"edin the case.

%r( Put#a& 1hat's not tr"e.

%r( Pa#sh& 2c"se me. Mr. P"tnam as act"ally involved in that case as the layer for %* after, I

!elieve, he came in for another la firm or to. insella WeitCman as in that la firm reresenting%* for a eriod of time, then Mr. P"tnam, and it's the same interests. %nd Mr. 1rell denies all the

these statementsD and this gentleman, ho has no interest in this case, testifies "nder oath hat Mr.

1rell told him. It's clearly relia!le.

Ju!+e& Well, I think I "nderstand hy yo" ant to "se itD !"t the :"estion is can yo".

%r( Pa#sh& @nder 667, I !elieve they had the same interest. 0emem!er, they're !oth 33 "nder Mr.1rell 33 and Mr. *ongaare, I !elieve, testified a!o"t the ins"rance and ho Michael 33 remem!er they


87/89

ent thro"gh the contract, and Michael had an o!ligation to get the ins"rance, and they ere !othtogether, had the same interest to have the ins"rance$ /o no there's this claim over the ins"rance, they

have no differing interests, they !oth had the idea to get the claim, to get the money from the ins"rance

comany, and "nder 33

Ju!+e& I'm not s"re that's the interest that they're talking a!o"t. 1hey're talking a!o"t the interest in the

cross3e2amining at the deosition. 1hat's the interest at iss"e, not that their interests are somehoaligned re3litigation.

%r( Pa#sh& B"t r. M"rray, if yo" r

Documents

Jackson V AEG Live, July 19th 2013, Transcripts of Katherine Jackson