1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
2 IN AND FOR THE COUNTY OF SANTA BARBARA
3 SANTA MARIA BRANCH; COOK STREET DIVISION
4 DEPARTMENT SM-2 HON. RODNEY S. MELVILLE, JUDGE
7 THE PEOPLE OF THE STATE OF )
8 CALIFORNIA, )
9 Plaintiff, )
10 -vs- ) No. 1133603
11 MICHAEL JOE JACKSON, )
12 Defendant. )
17 REPORTER’S TRANSCRIPT OF PROCEEDINGS
19 WEDNESDAY, MAY 11, 2005
21 8:30 A.M.
23 (PAGES 9804 THROUGH 9881)
27 REPORTED MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304
28 BY: Official Court Reporter 9804
1 APPEARANCES OF COUNSEL:
3 For Plaintiff: THOMAS W. SNEDDON, JR.,
4 District Attorney -and-
5 RONALD J. ZONEN, Sr. Deputy District Attorney
6 -and- GORDON AUCHINCLOSS,
7 Sr. Deputy District Attorney 1112 Santa Barbara Street
8 Santa Barbara, California 93101
11 For Defendant: COLLINS, MESEREAU, REDDOCK & YU BY: THOMAS A.
MESEREAU, JR., ESQ.
12 -and- SUSAN C. YU, ESQ.
13 1875 Century Park East, Suite 700 Los Angeles, California 90067
15 SANGER & SWYSEN
16 BY: ROBERT M. SANGER, ESQ. 233 East Carrillo Street, Suite C
17 Santa Barbara, California 93101
1 I N D E X
3 Note: Mr. Sneddon is listed as “SN” on index.
4 Mr. Zonen is listed as “Z” on index. Mr. Auchincloss is listed as “A” on index.
5 Mr. Mesereau is listed as “M” on index. Ms. Yu is listed as “Y” on index.
6 Mr. Sanger is listed as “SA” on index.
10 WITNESSES DIRECT CROSS REDIRECT RECROSS
11 MARCUS, Joseph 9807-A
13 9810-SA (Further)
15 Macaulay 9813-M 9828-Z 9865-M 9876-Z
1 Santa Maria, California
2 Wednesday, May 11, 2005
3 8:30 a.m.
5 THE COURT: Good morning, everyone.
6 THE JURY: (In unison) Good morning.
7 THE COURT: Counsel? You may proceed.
9 JOSEPH MARCUS
10 Having been previously sworn, resumed the
11 stand and testified further as follows:
13 RECROSS-EXAMINATION (Continued)
14 BY MR. AUCHINCLOSS:
15 Q. Good morning, Mr. Marcus.
16 A. Good morning.
17 Q. I just have a few more questions and we’ll
18 be done.
19 A. Okay.
20 Q. First of all, you mentioned in your
21 testimony yesterday that you were -- I believe you
22 were present when the Britto party was held at
23 Neverland; is that correct?
24 A. That’s correct.
25 Q. And do you recall which month that party
27 A. I believe it was September.
28 Q. September of ‘03? 9807
1 A. I believe so.
2 Q. And do you know who was the organizer of
3 that party?
4 MR. SANGER: I’m going to object. That’s
5 beyond the scope of direct, and relevance.
6 THE COURT: Sustained.
7 Q. BY MR. AUCHINCLOSS: Mr. Marcus, you
8 mentioned that Mr. Salas called you on the night of
9 the 12th, or the early morning hours of the 12th,
10 when the Arvizos left Neverland; is that correct?
11 The 12th of February?
12 A. I believe so.
13 Q. Okay. Are you uncertain of that?
14 A. I’m uncertain of the date. He called me,
16 Q. Did Mr. Salas actually talk to you that
18 A. I believe so. I believe he was at the front
19 gate and the officer actually dialed the number and
20 I believe Jesus got on the phone.
21 Q. So you actually had a phone conversation
22 that night with somebody from Neverland at
23 approximately one o’clock in the morning?
24 A. I thought it was later than one o’clock, but
25 I could be mistaken.
26 Q. Sometime in the early morning hours of that
28 A. I believe so. 9808
1 Q. Finally, during your interview with the
2 investigator when the warrant was served at
3 Neverland back in November of ‘03, at some point did
4 you ask the interviewer to turn the tape-recorder
6 A. Yes.
7 Q. And that was right when you were being
8 questioned about children sleeping in Michael
9 Jackson’s room, wasn’t it?
10 A. Yes.
11 Q. And you never answered that question, did
13 A. I believe I did.
14 Q. Well, wasn’t your next statement, “How many
15 more questions do we have?” after you said, “Could
16 you shut that off a minute?”
17 A. I believe I finished the interview as was
18 directed by the investigator.
19 Q. Okay. My question is, didn’t you say --
20 after you asked the investigator to shut off the
21 recorder, wasn’t your next answer, “Okay. I” --
22 “How many more questions do we have?” That’s the
23 question I’m asking. Did you say that?
24 A. I believe so.
25 Q. And then she said, “One,” and you said,
26 “Could we just move on to the next question?” Isn’t
27 that what you told the interviewer?
28 A. I believe there was a little bit more to the 9809
1 question, but, yes.
2 Q. Well, did you say something else? Is that
3 what you’re telling us, or is that an accurate
4 depiction of what was stated?
5 A. I believe you have it right in front of you,
6 if you would like to read it.
7 Q. My question is, is that -- is what I’ve just
8 read to you or what I’ve just told you consistent
9 with your recollections of the event?
10 A. Yes.
11 MR. SANGER: I’m going to object. It’s
12 asked and answered.
13 THE COURT: Overruled. The answer is in.
14 Next question.
15 MR. AUCHINCLOSS: Thank you. I have no
16 further questions.
17 THE WITNESS: Thank you.
18 THE COURT: Mr. Sanger?
19 MR. SANGER: Yes, thank you.
21 FURTHER REDIRECT EXAMINATION
22 BY MR. SANGER:
23 Q. Just very briefly on that. This interview
24 that you had with the police officers, did you
25 understand that that was voluntary, that you did not
26 have to talk to them if you didn’t want to?
27 MR. AUCHINCLOSS: Objection; relevancy.
28 THE COURT: Sustained. 9810
1 MR. SANGER: On relevancy? Okay. I’m
2 trying to understand. I apologize, Your Honor. Let
3 me think for a second.
4 Q. The interview we’re talking about is the
5 police officers at the ranch during the search,
7 A. Yes.
8 Q. What was your understanding of whether or
9 not you were required to submit to an interview?
10 MR. AUCHINCLOSS: Objection; relevancy.
11 THE COURT: I’ll allow the question.
12 You may answer.
13 THE WITNESS: I was trying to cooperate as
14 much as possible with the investigation on that day.
15 Q. BY MR. SANGER: Did you know whether or not
16 you had to talk? Do you know if you had an option
17 not to talk?
18 MR. AUCHINCLOSS: Same objection.
19 THE COURT: I’ll allow the question.
20 THE WITNESS: Yes.
21 Q. BY MR. SANGER: And did you agree to go
22 ahead and talk with them?
23 A. That is correct.
24 Q. And when you asked if they could turn off
25 the tape-recorder, did they accommodate you? Did
26 they turn it off?
27 A. No.
28 Q. You knew that they were continuing to record 9811
1 you; is that correct?
2 A. That’s correct.
3 Q. And you went on from that point. Do you
4 recall how long the interview lasted on tape after
5 that point in the conversation?
6 A. Probably five -- maybe five, ten more
8 Q. And the officers continued to ask you
9 questions; is that right?
10 A. I believe one or two more questions.
11 Q. Okay. And you answered them?
12 A. Yes.
13 MR. SANGER: All right. Okay. I have no
14 further questions.
15 MR. AUCHINCLOSS: No further questions.
16 THE COURT: All right. Thank you. You may
17 step down.
18 THE WITNESS: Thank you.
19 THE COURT: Call your next witness.
20 MR. MESEREAU: Yes, Your Honor, the defense
21 will call Macaulay Culkin.
22 THE COURT: For counsel’s information, there
23 was a motion to limit filed by the defense on this
24 witness, and --
25 MR. ZONEN: Your Honor, we’re not going to
26 be asking those questions.
27 THE COURT: All right. Thank you.
28 Come forward, please. When you get to the 9812
1 witness stand, please remain standing.
2 Face the clerk here and raise your right
5 MACAULAY CULKIN
6 Having been sworn, testified as follows:
8 THE WITNESS: I do.
9 THE CLERK: Please be seated. State and
10 spell your name for the record.
11 THE WITNESS: Macaulay Culkin.
12 M-a-c-a-u-l-a-y; C-u-l-k-i-n.
13 THE CLERK: Thank you.
15 DIRECT EXAMINATION
16 BY MR. MESEREAU:
17 Q. Good morning, Mr. Culkin.
18 A. Good morning.
19 Q. You are an actor from New York, right?
20 A. That is correct.
21 Q. Would you please summarize your career?
22 A. Summarize my career?
23 Q. Yes, please.
24 A. I started working at the age of four doing
25 stage and things like that. And done a number of
26 things; films, things like that. Kind of worked
27 till I was about 14, took a break there for a while,
28 and just started working again recently. 9813
1 Q. Do you know the fellow seated at counsel
2 table to my right?
3 A. Yes, I do.
4 Q. Who is that?
5 A. That’s Michael Jackson.
6 Q. Is he a friend of yours?
7 A. Yes, he is.
8 Q. How long has he been a friend of yours?
9 A. I first met him when I was nine or ten years
11 Q. And how did you meet him?
12 A. He kind of called me out of the blue one
13 time, just said, “Hey,” you know, “This is Michael
14 Jackson.” And this is after the “Home Alone” movie
15 had come out. So it’s kind of like -- it was like,
16 “I think I understand kind of what’s happening, and
17 I’d like to get together and talk.”
18 Q. And he’s still your friend?
19 A. Yes, he is.
20 Q. When did you last talk to him?
21 A. I talked to him about three days ago.
22 Q. And at some point, did you visit Neverland
23 for the first time?
24 A. Yeah, it was after he had called that first
25 time. He invited us, me and my family, over there
26 to hang out.
27 Q. And did you and your family go to Neverland?
28 A. Yes, we did. 9814
1 Q. Did you hang out?
2 A. Yes, we did.
3 Q. How long did you hang out there with him?
4 A. I think the first trip we were there for
5 about three or four days. It was me and my younger
6 brother and my mother and my father.
7 Q. How many times do you think you visited
9 A. More than a dozen times from basically when
10 I was about 10 to when I was about 14 years old.
11 And I kind of took a break there for a while, just
12 didn’t go. I just never found myself on the West
13 Coast, so I never found myself going there. And
14 then went a couple times between when I was 17 and
15 now, just a handful of times.
16 Q. And when was the last time do you think you
17 visited Neverland?
18 A. About a year or so ago.
19 Q. Okay. And you maintained a friendship with
20 Mr. Jackson all those years?
21 A. Yes, I have.
22 Q. Okay. Do you consider him a close friend of
24 A. Yes.
25 Q. Let’s go to your first trip to Neverland,
26 okay? You say you were there with your family?
27 A. Uh-huh.
28 Q. And who in your family are you referring to? 9815
1 A. My brother Kieran and my mother and my
3 Q. Okay. And what do you remember about your
4 first visit to Neverland?
5 A. It was big. It was -- it was -- I had never
6 seen anything like it before. Especially
7 considering it was someone’s house. It was -- you
8 know, it wasn’t exactly what I was expecting.
9 Because you’re nine or ten years old, you don’t
10 really pay attention to what people say or whatever,
11 you know, those kind of things. So -- you know,
12 everything is lit up.
13 And he was a nice guy. I remember he
14 laughed because I referred to all the Ninja Turtles
15 by their first names, and things like that. And so
16 it was one of those kind of things where it was just
17 very -- it was very casual, really.
18 Q. Did you and your family have a good time?
19 A. Yes.
20 Q. What are some of the things you did at
21 Neverland with your family?
22 A. Saw a movie in the movie theater. Rode on
23 the amusement park rides, and -- just everything,
24 you know. Just used the facilities, basically.
25 Q. How many times do you think your family has
26 been to Neverland?
27 A. About the same amount of times. When I was
28 younger they were there virtually every time I was 9816
2 Q. And you have a sister?
3 A. Yes, I do.
4 Q. And did she visit?
5 A. I have two.
6 Q. Hmm?
7 A. I have two of them.
8 Q. Did they visit Neverland as well?
9 A. Yes, they have.
10 Q. How many times do you think they’ve been to
12 A. Not as often, just because they were really
13 never on the West Coast as often as I was. But
14 whenever they were in town and I was going, they
15 would love to go as well.
16 Q. Have you seen Michael Jackson outside of
18 A. Yes.
19 Q. Where have you seen him?
20 A. Whenever. I’d be staying at a hotel and
21 he’d come and pick me and my brothers up, and we’d
22 sneak into a movie theater like in the middle of the
23 night -- in the middle of, like, you know, a movie,
24 because that was the only way you could really see
25 an actual movie in an actual movie theater with him.
26 Just a number of occasions.
27 Q. Have you seen Michael in New York?
28 A. Yes, I have. 9817
1 Q. Okay. How many times, do you think?
2 A. Handful of times. Four times. Five times.
3 Something like that.
4 Q. How about in Los Angeles?
5 A. Yeah, in the City of Los Angeles, too.
6 Q. Other than Neverland, New York and Los
7 Angeles, have you seen Michael Jackson anywhere
9 A. Yeah. He was in London when I was out there
10 doing a play. And he was out there for, I don’t
11 know, maybe a week or so. We hung out two times,
12 three times.
13 Q. Now, in London, what did you do with Michael
15 A. Hung out with his kids. We had -- we had a
16 dinner with a group of people, most of whom I had
17 not met before, but just -- it was a nice, casual,
18 sit-down dinner. And just saw the kids, things like
19 that. I always liked seeing the kids.
20 Q. And you’re talking about Michael’s kids?
21 A. Yes.
22 Q. And what have you done with Michael Jackson
23 in Los Angeles?
24 A. Same kind of thing. We used to hang out.
25 He had an apartment there that was actually in the
26 city, so we’d go visit there. Just kind of -- it
27 was a little more convenient, and it was smaller.
28 It wasn’t as, you know, far away. It wasn’t the 9818
1 daunting three-hour drive, you know. When you’re
2 ten years old, that’s an awfully long drive to get
3 out there. So sometimes when he was in the city, we
4 would just hang out at his apartment.
5 Q. Now, you’ve spoken to him on the phone
6 through the years, correct?
7 A. Yeah.
8 Q. How many times do you think you’ve spoken to
9 him on the phone?
10 A. I couldn’t really count. Couldn’t say.
11 Over 100 times probably.
12 Q. And have you called Michael Jackson
14 A. Yeah.
15 Q. Has he called you?
16 A. Yeah.
17 Q. Has he called your family, to your
19 A. Yeah.
20 Q. And has your family called him?
21 A. Yes.
22 Q. You’re aware of the allegations in this
23 case, correct?
24 A. Uh-huh. Yes.
25 Q. You heard about some of the allegations
26 about whether or not Mr. Jackson improperly ever
27 touched you, right?
28 A. Yes. 9819
1 Q. Did Mr. Jackson ever molest you?
2 A. Never.
3 Q. Did Mr. Jackson ever improperly touch you?
4 A. Absolutely not.
5 Q. Has Mr. Jackson ever touched you in any
6 sexual type of way?
7 A. No.
8 Q. Has he ever touched you in any offensive
10 A. No.
11 Q. What do you think of these allegations?
12 A. I think they’re absolutely ridiculous.
13 Q. When did you first learn that these
14 prosecutors were claiming that you were improperly
16 A. When did I first learn that?
17 Q. Yes.
18 A. I -- somebody called me up and said, “You
19 should probably check out CNN, because they’re
20 saying something about you.”
21 Q. And did you check it out?
22 A. Yes, I did.
23 Q. And what did you learn?
24 A. I learned that it was a former cook had done
25 something to me, and there was something about a
26 maid or something like that. It was just one of
27 those things where I just couldn’t believe it. I
28 couldn’t believe that, first of all, these people 9820
1 were saying these things or -- let alone that it was
2 out there and people were thinking that kind of
3 thing about me.
4 And at the same time it was amazing to me
5 that they -- that nobody approached me and even
6 asked me whether or not the allegations were true.
7 They kind of just were -- threw it out there just
8 like -- they didn’t even -- they didn’t even
9 double-check it basically. I mean, even if they
10 assumed that they knew the answer, what got me was
11 that they didn’t even ask.
12 Q. Now, are you saying these prosecutors never
13 tried to reach you to ask you your position on this?
14 A. No, they didn’t.
15 Q. Do you know if any police officer from Santa
16 Barbara has ever tried to call you to see what the
17 truth is?
18 A. No.
19 Q. Are you aware that they claim they are
20 going to prove that you were molested by Michael
22 A. Excuse me?
23 Q. Are you aware that they claim they can
24 prove --
25 MR. ZONEN: I’ll object as leading, Your
27 THE COURT: Sustained.
28 Q. BY MR. MESEREAU: Have you ever been to 9821
1 Michael Jackson’s bedroom?
2 A. Yes.
3 Q. And when did you first see Michael Jackson’s
5 A. I think it was probably the first trip.
6 Q. And did you go in there with your family?
7 A. Uh-huh.
8 Q. And what do you recall about Michael
9 Jackson’s room?
10 A. It was large. It was -- it was a very
11 comfortable place. He had paintings and all those
12 kind of things on the wall. It was -- you know, it
13 had two bedrooms and it was two stories high. It
14 was -- you know, it’s not what you normally
15 associate with a bedroom.
16 Q. And have you and your family stayed in that
18 A. Yes.
19 Q. How many times, do you think?
20 A. Handful of times.
21 Q. How many times do you think you’ve stayed in
22 Michael’s room?
23 A. A handful of times.
24 Q. How about your sister?
25 A. Not as often.
26 Q. How about your brother?
27 A. Whenever I was there, my little brother was
28 kind of always tagging along with me, so he was 9822
1 usually anywhere I was.
2 Q. Where else at Neverland have you been with
3 Michael Jackson?
4 A. Everywhere, essentially. We were always
5 hanging out together, just like I said, and using
6 all the facilities; the zoo, the arcade, or the
7 movie theater, wherever.
8 Q. Have you spent a lot of time at Neverland
9 with Michael Jackson?
10 A. Yes.
11 Q. Have you played at Neverland with Michael
13 A. Yes.
14 Q. What have you done with him?
15 A. Like I said, we used everything. We’d play
16 video games. We would fill up a bunch of water
17 balloons and toss them around. Just things like
18 that. It was just good old fun, just like a bunch
19 of, like, kids basically having a good time.
20 Q. Have you been to the arcade with Michael
22 A. Yeah.
23 Q. Do you recall playing any games with Michael
24 Jackson in the arcade?
25 A. Yeah, sure.
26 Q. And do you recall this going on anytime of
28 A. Playing video games? 9823
1 Q. Yeah.
2 A. Yeah. Absolutely.
3 Q. What time of day would you play video games
4 with Mr. Jackson?
5 A. Anytime. You know, sometimes -- I mean,
6 sometimes I fell asleep in the arcade and I’d wake
7 up and just start playing, you know. It was one of
8 those kind of things where, you know, you’d be up
9 half the night, you’d be -- you know, you’d be kind
10 of in and out of all these places.
11 So it was never really any kind of specific
12 time that we spent there, but it was, you know, kind
13 of just -- we were always kind of just either there,
14 or at the theater, or just driving around in the
15 golf carts, or something like that.
16 Q. Do you recall your family being with you in
17 the arcade?
18 A. Yes.
19 Q. Do you recall them being with you in the
21 A. Yes.
22 Q. Do you recall your family being with you in
23 the theater?
24 A. Yeah.
25 Q. Did you ever have any reason to think your
26 family was being excluded by Mr. Jackson from
27 anything you did at Neverland?
28 A. Could you repeat that? 9824
1 Q. Sure. Did you ever get the feeling that
2 your family was being excluded from anything you did
3 at Neverland?
4 A. Absolutely not.
5 Q. Did you get the contrary feeling, that they
6 were always invited to be with you any time you were
8 MR. ZONEN: Objection; leading.
9 THE COURT: Sustained.
10 Q. BY MR. MESEREAU: Did you ever think Mr.
11 Jackson was somehow trying to exclude your family
12 from his room?
13 MR. ZONEN: Objection; leading.
14 THE COURT: Overruled.
15 You may answer.
16 THE WITNESS: Could you repeat the question?
17 THE COURT: I’ll have it read back.
18 (Record read.)
19 THE WITNESS: Absolutely not. It was a real
20 open-door policy just with the entire ranch.
21 Q. BY MR. MESEREAU: Okay. That applied to
22 your family as well as you?
23 A. Yes, everyone.
24 Q. Okay. Have you ever traveled with Michael
26 A. Yes.
27 Q. Where did you travel to?
28 A. We took a trip, I was going with some family 9825
1 friends. We were going to Bermuda, and I said,
2 “We’re going.” And he said, “Is it all right if I
3 tag along?” And I said, “Yes.” So we did that.
4 After that, we ended up in -- we decided to
5 fly back to Orlando, because the family friends that
6 I was traveling with, that’s where they were from.
7 So we went there, went to Disney World for a day or
8 two, and ended up flying back with my family.
9 And I’ve also -- he was doing a charity
10 event a couple years back in Washington D.C., and so
11 I -- I hitched a ride with him on his plane back to
12 New York.
13 Q. And did Mr. Jackson ever do anything
14 improper to you on any of these trips?
15 A. No.
16 Q. Ever see him do anything that you found
17 disturbing on any of these trips?
18 A. Absolutely not.
19 Q. Has Mr. Jackson ever hugged you?
20 A. Sure.
21 Q. Have you ever hugged him?
22 A. Absolutely.
23 Q. Were you ever suspicious of any of these
24 hugs as being something sexual in nature?
25 A. No, it was always very casual. It was just
26 the way I hug any of my friends.
27 Q. Did you ever see Mr. Jackson hug your
28 sister? 9826
1 A. Sure.
2 Q. Were you ever suspicious of his hugging your
4 A. No.
5 Q. Ever see Mr. Jackson hug your brothers?
6 A. Yeah.
7 Q. Ever see them hug him?
8 A. Yes.
9 Q. Did you ever think anything suspicious was
10 going on when your brothers hugged Mr. Jackson?
11 A. No, it was always just how you kind of
12 greeted him, greeted almost anyone basically that
13 you were close with.
14 Q. Do you know someone named Wade Robson?
15 A. Yeah, I’ve met him.
16 Q. Where did you meet him?
17 A. When we were shooting the “Black and White”
18 video. He was one of the dancing kids. So I met
19 him and hung out with him after the shoot.
20 Q. Did you ever see Mr. Jackson do anything
21 improper with Wade Robson?
22 A. No.
23 Q. Have you been in contact with Wade Robson?
24 A. No, I haven’t.
25 Q. When’s the last time you think you talked to
27 A. Was back then when we hung out, when I was
28 10 or 11 years old. 9827
1 Q. Do you know someone named Brett Barnes?
2 A. I think so. But I’m not really sure if I
3 do. I mean, I’ve heard the name before, and I’ve --
4 I think it’s the same Brett that I know, but I
5 couldn’t be 100 percent.
6 Q. And if the person you think is Brett Barnes,
7 do you recall seeing him at Neverland?
8 A. If it -- yeah, if it’s the person I’m
9 thinking of, yeah.
10 Q. Did you ever see Mr. Jackson do anything
11 improper with him?
12 A. No, I’ve never seen him do anything improper
13 with anybody.
14 MR. MESEREAU: Okay. No further questions.
15 THE COURT: Cross-examine?
18 BY MR. ZONEN:
19 Q. Mr. Culkin, good morning.
20 A. Good morning.
21 Q. Sir, isn’t it true that both in 1993 and in
22 2003 law enforcement attempted to gain access to you
23 to have an interview with you and on both occasions
24 your representatives refused to have -- allow you to
25 have an interview with law enforcement? Isn’t that
27 A. Not to my knowledge.
28 Q. You’re not aware of any effort by law 9828
1 enforcement either in 1993 or currently within the
2 last couple years to be able to get an interview
3 with you?
4 A. Not that I know of, no.
5 Q. Isn’t it true that your attorney just within
6 the last couple weeks issued a notice that you would
7 not be giving any statements to either side prior to
8 your giving an inter -- prior to your testifying in
10 A. Could you repeat that?
11 Q. Isn’t it true that just within the last
12 couple weeks your attorney notified us that you
13 would not be giving an interview to either side of
14 this case prior to your taking the witness stand
15 and testifying?
16 A. You’re -- can you repeat that one more time?
17 Q. Mr. Culkin, did you talk to anybody from the
18 defense prior to coming into court today?
19 A. Did I talk to anybody from the defense?
20 Q. That’s right.
21 A. I talked to Tom Sneddon yesterday.
22 Q. You talked to Tom Sneddon yesterday?
23 A. Sorry. Excuse me. Mr. Mesereau.
24 Q. You talked to Mr. Mesereau yesterday?
25 A. Yes.
26 MR. SNEDDON: I’m the one with the short
28 THE WITNESS: Yes, sorry about that. I went 9829
1 to his office yesterday for about a half an hour to
2 get my -- like, figure out where I was staying and
3 all that kind of stuff.
4 Q. BY MR. ZONEN: Did you give him an interview
5 at that time?
6 A. No, not really. He kind of walked me
7 through the procedure, what I would have to be going
8 through for the day.
9 Q. And did you talk to him about anything
10 substantive, any of the issues about your
11 association with Michael Jackson?
12 A. No, we didn’t.
13 Q. Were you aware that an attorney of yours had
14 contacted us and told us that you would not be
15 giving a statement to either side? Is that true?
16 A. I think so, yes.
17 Q. Was that your decision or your lawyer’s
19 A. I think I just took what he had to say and
20 agreed with it.
21 Q. So you decided all along you were not going
22 to talk to either side?
23 A. Essentially, yeah. I wasn’t really planning
24 on testifying.
25 Q. But you’re complaining that we didn’t
26 interview you?
27 A. I’m just saying it was something that -- I
28 said I kind of just -- all of a sudden I turn on the 9830
1 television or look on the Internet and there was
2 those things out there, and it was just surprising
3 to me.
4 Q. Mr. Culkin, are you completely unaware of
5 the fact that law enforcement has made a number of
6 efforts to gain access to you to talk to you?
7 A. Like I said, I’m unaware.
8 Q. No one among your representatives has ever
9 gone to you and said, “Law enforcement would like to
10 speak with you”?
11 A. Never.
12 Q. How old were you when you went to Bermuda?
13 A. I must have been around 11 years old.
14 Q. How long had you known Michael Jackson at
15 that time?
16 A. About a year or two.
17 Q. That trip was with the Goldstein family; is
18 that right?
19 A. That sounds right.
20 Q. That sounds right? You don’t recall?
21 A. It was 15 years ago.
22 Q. You don’t recall with whom you went to
24 A. I remember it was my friend Brock and his
26 Q. All right. And Brock’s last name is
27 Goldstein; is that correct?
28 A. That sounds right. Like I said, it was 15 9831
1 years ago. And it wasn’t -- I haven’t really talked
2 to them since then almost.
3 Q. And how is it that Mr. Jackson ended up
4 going to Bermuda with you?
5 A. I told him I was going, and he seemed
6 excited. And I said, “Would you like to come
7 along?” So he said, “Let’s go to Bermuda.”
8 Q. You’re an 11-year-old child, but you felt it
9 was okay to invite Mr. Jackson to attend a trip that
10 you were going on with another family?
11 A. Yeah. I mean, and they were fine with it,
12 from what I remember.
13 Q. Well, did you consult with them before you
14 invited Mr. Jackson to come along?
15 A. To be honest, I don’t remember.
16 Q. All right. The Goldsteins have a child who
17 at that time had appeared in a movie with you; is
18 that right?
19 A. I don’t remember him being in the film. He
20 lived in the same community as me when I was
21 shooting the film “My Girl.” And it was just kind
22 of a community like -- it was almost -- it wasn’t
23 exactly a gated community, but it was off of, like,
24 the Universal lot. And he was just a neighborhood
25 kid that I got friendly with.
26 Q. You became friendly with Brock during the
27 course of the filming of that film; is that right?
28 A. Yes. 9832
1 Q. And you used to spend time at their home?
2 A. Yes.
3 Q. And you would spend the night at their home
4 as well; is that correct?
5 A. Yeah.
6 Q. And when they were planning a trip to
7 Bermuda, they invited you to come along?
8 A. Yeah.
9 Q. They consulted with your parents in advance
10 and your parents agreed; is that true?
11 A. Yeah.
12 Q. All right. You then invited Mr. Jackson to
13 come along as well; is that correct?
14 A. From what I remember, yes.
15 Q. All right. You did not tell either Mr. or
16 Mrs. Goldstein that you had done that in advance of
17 that trip?
18 A. Like I said, I don’t remember that.
19 Q. Now, you invited Mr. Jackson or Mr. Jackson
20 invited himself? Which was it?
21 A. To be honest, I don’t remember. I do -- I
22 think it was something like, “I’m going to Bermuda.”
23 You know, “We’re going to have a good time.” I
24 don’t remember how exactly it went over, whether it
25 was, like, “Oh, is it all right if I come?” Or if
26 it was, “Why don’t you come along.” I honestly
27 don’t remember.
28 Q. Did Mr. Jackson travel with you to Bermuda 9833
1 or did he meet you there?
2 A. I honestly don’t remember.
3 Q. When he got there, he gave you a watch, did
4 he not?
5 A. I think that’s when he gave me the watch.
6 Q. It was a Rolex?
7 A. Yes.
8 Q. He gave a Rolex to an 11-year-old child?
9 A. Yeah. But it wasn’t -- it wasn’t anything
10 all that crazy to me. I didn’t see it as anything
11 like that. I was not a person without means, so it
12 wasn’t anything that was all that awe-inspiring. I
13 mean, my father had a Rolex. It was that kind of
15 Q. Did he give a Rolex to Brock as well?
16 A. I don’t remember.
17 Q. Did he give any gift to Brock?
18 A. I don’t remember.
19 Q. Isn’t it true that the Goldstein family, the
20 parents, Mr. and Mrs. Goldstein, felt excluded by
21 the presence of Mr. Jackson; that he was attempting
22 to and succeeded in taking you away from the family
23 in terms of the events that were being -- that they
24 were doing?
25 MR. MESEREAU: Objection; calls for
27 MR. ZONEN: It’s exactly in response to the
28 question that counsel asked. 9834
1 THE COURT: You’re asking him for the
2 Goldsteins’ feelings. The objection is sustained.
3 Q. BY MR. ZONEN: Did they tell you that they
4 felt that they were being excluded from activities
5 with you?
6 A. Not that I remember.
7 Q. Did they complain to you at all about the
8 fact that Mr. Jackson was dominating your time?
9 A. I don’t -- not that I remember.
10 Q. Did Mr. Jackson suggest that you go with him
11 to different locations in Bermuda separate from the
12 Goldstein family?
13 A. Excuse me?
14 Q. Did Mr. Jackson suggest to you that you go
15 with him to locations in Bermuda without the
16 Goldstein family?
17 A. Not that I remember. Like I said, this
18 whole trip was 15 years ago. And I was nine or ten
19 years old. And if I knew I was going to have to be
20 testifying about it, I’m sure I would have made an
21 effort to remember.
22 Q. How old are you now?
23 A. I’m 24.
24 Q. You’re 24. And you’re saying it’s 15 years
26 A. 13, 14, 15 years ago. I honestly don’t
27 remember exactly how old I was.
28 Q. You were somewhere between nine and -- 9835
1 A. 11, yes.
2 Q. And you met him when you were nine?
3 A. I think that’s about right, yeah. So it
4 must have been when I was about 10 or 11.
5 Q. You had known him for at least a year at the
6 time you went on that trip?
7 A. Yeah, for at least a year.
8 Q. All right. And then the question about
9 whether you have a recollection about Mr. Jackson
10 asking you to go with him to locations without the
11 Goldstein family, at this time you do not recall the
12 answer to that question?
13 A. I don’t, no.
14 Q. Did Mrs. Goldstein at times tell you that it
15 was not okay for you to go away with Mr. Jackson by
17 A. Could you repeat that?
18 Q. Didn’t Mrs. Goldstein tell you it was not
19 okay for you to go away with Mr. Jackson by yourself
20 without somebody from the Goldstein family being
21 there? Didn’t she tell you that?
22 A. Gosh, I don’t remember those kind of --
23 those kind of details. I remember -- I could tell
24 you the hotel room, what it looked like. I could
25 tell you, you know, if it was on the beach, and
26 things like that. But I can’t tell you -- I don’t
27 remember a lot of these specific details, because
28 there just wasn’t anything that eventful going on, 9836
1 besides that.
2 Q. But you don’t remember her telling you
3 specifically that she was not going to allow you to
4 go places with Mr. Jackson by yourself unaccompanied
5 by another member of their family?
6 A. Not that I remember, but I don’t know.
7 Q. How long did you stay in Bermuda?
8 A. I don’t know. It could have been, like,
9 about a week or so.
10 Q. Did Mr. Jackson stay with you in Bermuda the
11 entire time?
12 A. From what I remember, he was there the whole
14 Q. Was he there with any other adult
16 A. How do you mean?
17 Q. Did he come with another person, man or
18 woman, a companion?
19 A. I don’t think so, no. I mean, he might have
20 had some security with him but I’m not sure.
21 Q. Other than security, did he come with a man
22 or woman with whom he intended to travel purely for
24 A. No.
25 Q. Was it your belief that he was there to
26 visit with you?
27 A. Yeah, to visit, and spend some time in
28 Bermuda. 9837
1 Q. All right. And to spend a week or more with
2 a ten-year-old child?
3 A. To spend a week or more with me, yes.
4 Q. And had he ever done that prior to that
5 date, gone traveling with you?
6 A. Not that I remember, no. We never really --
7 I mean, besides when he was in Los Angeles, and I
8 was, he’d come visit me. But we never really went
9 on, like, trips.
10 Q. Do you still have that Rolex watch?
11 A. I think I do have it somewhere, yes.
12 Q. You don’t wear it any longer?
13 A. It doesn’t fit.
14 Q. It’s a woman’s watch; is that correct?
15 A. Not that I know of. It was small. It was a
16 small watch, and the band is very small on it, so
17 like I said, it doesn’t really fit me anymore.
18 Q. Did Mr. or Mrs. Goldstein comment to you
19 about anything at the time that watch was given to
21 A. Not that I remember.
22 Q. In your presence, did they tell Mr. Jackson
23 they thought that was an inappropriate gift?
24 MR. MESEREAU: Objection. Hearsay; calls
25 for speculation.
26 THE COURT: Sustained.
27 Q. BY MR. ZONEN: Had you taken any trips with
28 Mr. Jackson prior to the Bermuda trip? 9838
1 A. No, we never really took any, like, trips or
2 vacations, really. Like I said, it was something --
3 when I was in Los Angeles we would hang out. Or if
4 he was in New York, we’d get together.
5 Q. Did you travel with Mr. Jackson anywhere
6 prior to the Bermuda trip where you stayed overnight
7 in a hotel with Mr. Jackson?
8 A. I don’t think so, no.
9 Q. Prior to the Bermuda trip, did you go
10 anywhere outside of California with Mr. Jackson?
11 A. Did we go anywhere outside of --
12 Q. I asked you, did you go anywhere --
13 A. I know --
14 Q. Did you go anywhere with Mr. Jackson prior
15 to the Bermuda trip?
16 A. Could you repeat that again?
17 Q. Prior to the Bermuda trip, did you travel
18 anywhere with Mr. Jackson?
19 A. Not that I remember. Not like we would be
20 somewhere and then travel somewhere else, besides
21 being in Los Angeles or going to Neverland or when
22 he was in New York, that kind of thing.
23 Q. In Bermuda, did you change hotels because of
24 Mr. Jackson’s arrival?
25 A. I don’t remember, but probably, because we
26 were staying in a larger hotel with -- I think it
27 was just a larger hotel, kind of beyond the means of
28 what we were kind of expecting to stay in. 9839
1 Q. Prior to staying in Bermuda, had you ever
2 spent the night alone with Mr. Jackson?
3 A. How do you mean “spend the night”?
4 Q. Did you ever share a bed with Mr. Jackson
5 prior to going to Bermuda?
6 A. Yeah, I mean, I’d fallen asleep in the same
7 bed as him.
8 Q. Did you ever do that, fall asleep in the
9 same bed as Mr. Jackson prior to going to Bermuda
10 where none of your brothers or sisters were present?
11 A. It’s possible. But like I said, usually my
12 brother was tagging along with me. But I fell
13 asleep basically everywhere in that ranch, or
14 anywhere else when I was hanging out with him. I
15 would just flop down on the floor half the time.
16 Q. Mr. Culkin, the question was, did you ever
17 share a bed with Mr. Jackson --
18 A. Yes.
19 Q. -- the two of you by yourself, prior to
20 going to Bermuda?
21 A. If I remember correctly, probably, yes.
22 Q. On approximately how many occasions did you
23 and Mr. Jackson share a bed the entire night prior
24 to going to Bermuda?
25 A. A handful of times.
26 Q. Was it your expectation that in Bermuda that
27 you would be sleeping with Mr. Jackson?
28 A. Excuse me? 9840
1 Q. Was it your expectation that while in
2 Bermuda you would be sharing a hotel room and a bed
3 with Mr. Jackson?
4 A. I don’t remember it being like an
5 expectation. It was -- I may have fallen asleep in
6 the same bed with him there, but it was just as
7 likely I’d fall asleep on the couch watching T.V.
8 Q. You might have fallen asleep in the bed with
9 Mr. Jackson in Bermuda?
10 A. I might have fallen asleep on his bed, yes.
11 Q. Now, prior to going to Bermuda, you said it
12 may have been a handful of times. What is a handful
13 of times? About five or six?
14 A. Yeah, like half dozen times.
15 Q. Half dozen times?
16 A. Ten at most.
17 Q. Ten at most? This is prior to going to
19 A. Yeah, I’d known him for about a year, and
20 hung out, I’d been to his ranch about four or five
21 times, I think, within that year.
22 Q. So you think you might have shared his bed
23 with him six to ten times prior to going to Bermuda;
24 is that the case?
25 A. It’s possible.
26 Q. All right. On how many of those occasions
27 were you there by yourself without any sibling,
28 alone, without any sibling at all? 9841
1 A. I don’t really remember. But most every
2 time I was there, I was there with my siblings. And
3 most every time I was with my siblings, they were,
4 like, with me the entire time.
5 Q. All right. How many times do you think
6 prior to going to Bermuda did you share a bed with
7 Mr. Jackson by yourself?
8 A. I honestly don’t remember. I couldn’t say.
9 Q. How about either of your sisters? Did they
10 ever share a bed with Mr. Jackson by themselves?
11 A. Not that I know of, no.
12 Q. That never happened, did it?
13 A. Not that I know of.
14 Q. In fact, none of your brothers ever shared a
15 bed with Mr. Jackson by themselves either, did they?
16 A. I’m not sure if that’s true. But I don’t --
17 I don’t know. Sometimes I would -- I wouldn’t fall
18 asleep. I’d be up for a little bit longer and, you
19 know, my brothers would fall asleep who knows where.
20 Q. But there were occasions when you went to
21 Neverland without your siblings and without your
22 parents; is that right?
23 A. I think I took one trip there where I
24 arrived there before my family did, for like a day
25 or two, and then they showed up.
26 Q. Up until the age of, say, 14, are you
27 telling us every time you went to Neverland you were
28 with your parents and your siblings? 9842
1 A. In some kind of combination of siblings and
2 parents, yes.
3 Q. You never once went to Neverland by
5 A. Like I said, I think I showed up -- I showed
6 up there once, and it was like a day or two and then
7 my family met me there.
8 Q. Your home is New York; is that right?
9 A. Yeah, I’m born and raised in New York.
10 Q. You never lived in Los Angeles?
11 A. Not full time, no.
12 Q. All right. Up until the age of 14, did you
13 ever live in Los Angeles, even part time?
14 A. I did some work in Los Angeles, but besides
15 that, I’m from New York.
16 Q. Where else did you go besides New York,
17 London and Neverland with Michael Jackson, and
18 Bermuda? What other places did you and he travel
20 A. We went to Orlando from Bermuda because
21 that’s where Brock and his family lived.
22 Q. Okay. So during that trip, you went to
24 A. Yeah, it was the same trip. We swung by
25 there, and then from there I went home.
26 Q. How often did you go to Neverland between
27 the ages of 10 and 14?
28 A. How many times did I go there? 9843
1 Q. Yes.
2 A. A dozen times, maybe more.
3 Q. All those occasions did you sleep in his
5 A. At some point or another I think I
6 probably -- I might have ended up sleeping in his
7 room, but I couldn’t really say that I slept there
8 every single time that I was there or anything like
10 Q. Would it be safe to say that 90 percent of
11 the time you stayed there?
12 A. In his bedroom?
13 Q. Yes.
14 A. I don’t think it would be 90 percent. It
15 would be --
16 Q. 80 percent?
17 A. It would be -- I slept in his room about as
18 often as I fell asleep anywhere. Like, I fell
19 asleep -- I would flop down -- we’d fall asleep in
20 the movie theater. He has beds in the movie
21 theater. I’d flop down and fall asleep there. I’ve
22 fallen asleep in the video game machines before. I
23 mean, I’ve -- I would go and play there basically
24 until I’d just run myself out, and I would just flop
25 down wherever I needed to.
26 Q. And you’d be pretty exhausted and go fast
27 asleep; is that right?
28 A. Yeah, I mean, that would happen. I’d wear 9844
1 myself out and fall asleep, just like any kid would.
2 Q. So your question about -- the question that
3 you answered about Mr. Jackson never molesting you,
4 your answer more accurately is he never did while
5 you were awake; is that correct?
6 A. Could you repeat that?
7 Q. Well, your answer to Mr. Mesereau’s question
8 about he never molested you.
9 A. Yes.
10 Q. Your answer more accurately is he never
11 molested you, to your knowledge, while you were
12 awake; is that true?
13 A. As far as I know, he’s never molested me.
14 Q. While you were asleep as a nine-year-old kid
15 who had run himself ragged, you wouldn’t know what
16 happened while you were asleep, right?
17 A. I find that unlikely.
18 Q. Well, but you just told us that sometimes
19 you’d be so exhausted after a day of playing you’d
20 fall asleep on a machine.
21 A. Yeah, but I think I’d realize if something
22 like that was happening to me.
23 Q. Yes? And on many of those occasions, you
24 would fall asleep in his bed?
25 A. It would happen.
26 Q. So you would have no recollection at all, of
27 all of your visits to Neverland, of ever actually
28 making arrangements to simply go to bed like anybody 9845
1 else, putting on pajamas and crawling into bed and
2 turning out the light?
3 A. I never really wore pajamas. But at the
4 same time, it was something like -- I mean,
5 occasionally, yeah, I’d have to -- like, we’d have
6 to wake up early in the morning because -- for
7 whatever reason, because I’d have to -- because we
8 were going to be leaving in the morning or whatever.
9 I mean, sometimes I was put on a schedule.
10 Q. Mr. Culkin, as a nine-year-old child, what
11 did you wear to bed?
12 A. I wore my clothes.
13 Q. You would just wear whatever you were
14 wearing during the day?
15 A. Yeah.
16 Q. Every single night?
17 A. Up until I was about 17 years old. That’s
18 when I kind of discovered what pajamas were.
19 Q. And you did that at home as well?
20 A. Yeah.
21 Q. Whatever you were wearing?
22 A. I always fell asleep in jeans and socks and
23 a T-shirt.
24 Q. All right. So whenever you were at
25 Neverland, you would crawl into bed in jeans and
26 socks and a T-shirt?
27 A. Yeah.
28 Q. Did you ever stay at his condo in Los 9846
2 A. Yeah, I think I’ve spent the night there.
3 Q. With your parents?
4 A. I’m not sure if they were there. I know
5 they’d been there before, but I’m not sure if they
6 ever spent the night there.
7 Q. You only spent one night in his condo in Los
8 Angeles? It’s in West L.A.; is that right?
9 A. I don’t really remember exactly where it
10 was. I was always either -- we’d just kind of go
11 there, and it was very secluded. It was in a garage
12 and things like that. That’s where the entrance
14 Q. All right. There was a hotel across the
15 street; is that correct?
16 A. I don’t really remember.
17 Q. Were there ever occasions where your parents
18 stayed in the hotel across the street and you stayed
19 at the condo by yourself with Mr. Jackson?
20 A. I don’t really remember. I don’t think so.
21 Q. But that’s possible?
22 A. I’m not sure if they stayed in the hotel
23 across the street or at another hotel. I don’t
25 Q. What is your date of birth?
26 A. August 26th, 1980.
27 Q. And you think when you first started coming
28 to Neverland you were nine years old, that would 9847
1 have been 1989?
2 A. About nine or ten years old, so it was
3 probably ‘90 or ‘91, like -- just like -- it was
4 after -- it was after the “Home Alone” movie came
6 Q. How old were you when you stopped sleeping
7 in bed with Michael Jackson?
8 A. Well, like I said, I stopped going there
9 just because I had really -- I had never really
10 found myself going to Los Angeles or anything like
11 that. So I didn’t really come back again until I
12 was about 17.
13 Q. The question was, when did you stop
14 sleeping --
15 A. I know. I’m getting there.
16 And so when I got -- when I started coming
17 back again, I found myself just not sleeping in bed.
18 And I’ve always kind of fell asleep in the guest
19 units ever since then.
20 Q. Why didn’t you stay with Mr. Jackson in his
22 A. Because I enjoyed my privacy a little bit
24 Q. All right. So is it safe to say that up
25 until and through your 13th year, you stayed with
26 Mr. Jackson in his room?
27 A. On occasion --
28 Q. More frequent -- 9848
1 A. On occasion I’d fall asleep there or
2 wherever. It wasn’t really like a thing to, like,
3 “Let’s go to sleep in a particular place.” On
4 occasion I’d end up falling asleep there. I’d fall
5 asleep anywhere.
6 Q. After you first met Mr. Jackson, did he
7 telephone you a lot?
8 A. We talked on the phone a good amount.
9 Q. And sometimes those telephone calls would go
10 two or three hours, wouldn’t they?
11 A. Sometimes. I guess. Yeah.
12 Q. Sometimes those telephone calls were in the
13 middle of the night, weren’t they?
14 A. Not really. I was in school. But sometimes
15 it would be in the later side.
16 Q. Did he express affection toward you during
17 those telephone calls?
18 A. How do you mean “affection”?
19 Q. Did he tell you how close he felt to you?
20 A. Yeah, we had a really close relationship
21 because we had this understanding of one another,
22 because one day I was --
23 MR. ZONEN: I’ll object as exceeding the
24 scope of the question, Your Honor. Nonresponsive.
25 MR. MESEREAU: Objection, Your Honor, he’s
26 cutting off the witness.
27 THE COURT: The objection is overruled.
28 The question was, “Did he tell you how close 9849
1 he felt to you?”
2 THE WITNESS: Yeah, and I’m trying to
3 explain --
4 THE COURT: You don’t need to explain.
5 THE WITNESS: Okay. I understand.
6 Yeah, we were close.
7 THE COURT: Next question.
8 Q. BY MR. ZONEN: Did he tell you that he had
9 thought of you like family?
10 A. Yes. From what I remember.
11 Q. Did he start telling you about seeing you as
12 family early on in your relationship with him?
13 A. I don’t know how far into the relation -- or
14 friendship it was, that we started talking about how
15 close we felt. But it was definitely something
16 where we understood each other early on.
17 Q. Even when you were nine years old?
18 A. Because of circumstances, yes.
19 Q. Did he give gifts to your parents?
20 A. I think so. But I honestly don’t remember.
21 This is a while ago. But he was -- he was very
22 generous. He always gave gifts to everybody.
23 Q. Do you remember what gifts he gave to your
25 A. Not offhand, no.
26 Q. Do you remember what gifts he gave to your
28 A. Not offhand. 9850
1 Q. Did you travel with Mr. Jackson to Las
3 A. No.
4 Q. Did you travel with Mr. Jackson to Europe?
5 A. No.
6 Q. Did you travel with Mr. Jackson to South
8 A. No.
9 Q. Did you ever stay at Neverland while Jordie
10 Chandler was there?
11 A. I don’t know. I’m not sure if I have. I’m
12 not sure if I know who Jordie Chandler is.
13 Q. Were you ever introduced to Jordie Chandler?
14 A. I couldn’t say. I met handfuls of people
15 kind of going in and out. There was always kind of
16 a revolving door of staff and of people kind of
17 coming in. Sometimes there would be guests there
18 that I had never really met before or things like
20 Q. Were you ever in Mr. -- in Mr. Jackson’s
21 bedroom overnight while another boy was present in
22 that room, other than your brothers?
23 A. On occasion, the other kids there that --
24 like I said, some of them were introduce -- like, I
25 was introduced to as, like, cousins or family
26 friends and stuff like that. And they’d bring their
27 kids there, and then -- same as me. They would --
28 they would play with me, and we’d fall asleep 9851
1 anywhere, sometimes his bedroom, sometimes in the
2 theater, sometimes anywhere.
3 Q. All right. Do you know whether any of those
4 boys who happened to fall asleep with you in his
5 room, if any of those boys, any one of them, was
6 Jordan Chandler?
7 A. It was 15 years ago. I’m not sure if I
8 remember the names.
9 Q. Are you aware of the allegations in 1993?
10 A. Yes, I was.
11 Q. In 1993, were you aware of the allegations
12 while they were going on?
13 A. Michael had called me about a month or so,
14 or maybe a couple of weeks before the allegations
15 hit the press. And he let me know that some people
16 were going to be saying something, and they were
17 absolutely untrue, and, “Don’t worry about it. I
18 just need you to be my friend right now.” And I
19 said, “Absolutely.”
20 Q. At the time that Mr. Jackson placed that
21 phone call, did you know who Jordan Chandler was?
22 A. I don’t know. I’m not sure exactly who
23 Jordan Chandler is, so I can’t -- I can’t say.
24 Q. But back in ‘93, there wasn’t a face that
25 went with that name? In other words, when he
26 mentioned the name “Jordan Chandler,” was there a
27 face that automatically came to mind for you?
28 A. I think I had met the accuser from ‘93 or 9852
1 ‘94, if that’s who you’re talking about. I had met
2 him once or twice. But I don’t remember his name,
3 so --
4 Q. How about Jason Francia? Did you ever meet
5 Jason Francia?
6 A. I don’t know. I can’t remember. Like I
7 say, this was -- this was, you know, 13 years ago,
8 you know. 14 years ago. And it wasn’t anything --
9 it was just sometimes there would be some kids
10 there, you know.
11 Q. Did you ever spend a night in the same room
12 with Brett Barnes at Neverland?
13 A. I’m not sure if I remember Brett Barnes.
14 Q. Did you ever spend a night in the same room
15 with Wade Robson?
16 A. No.
17 Q. Wade Robson you remember?
18 A. I remember him, yes, because he was a very
19 good dancer. And I know him also because of what
20 he’s accomplished in his own career recently.
21 Q. So he’s -- he has stayed in the United
22 States and you’re familiar with him?
23 A. I am familiar with him. He had a T.V. show
24 for a while.
25 Q. You don’t have a recollection of spending a
26 night with Wade Robson in the same room, Michael
27 Jackson’s room; is that correct?
28 A. Not that I remember, no. I mean, we did 9853
1 hang out, the day, like, after the shoot, and we
2 went to his condo in Los Angeles.
3 Q. How many nights did you spend with Michael
4 Jackson alone in his room and in his bed between the
5 ages of 9 and 14?
6 A. How -- could you repeat that?
7 Q. How many nights do you believe you spent
8 alone in Michael Jackson’s room and in his bed,
9 alone with Michael Jackson, between the ages of 9
10 and 14?
11 A. It couldn’t have been more than like -- it
12 was a handful of times. It couldn’t have been more
13 than, like, five times, four times.
14 Q. Sir, you told us it was a handful of times
15 that did you that before you went to Bermuda and
16 that was at age 10?
17 A. Altogether -- like I said, I went a lot
18 between the ages of about 10 and -- about 9 and 12,
19 9 and, like, 11. And then I found -- I never really
20 worked a whole lot in Los Angeles. It was only when
21 I was in town that I would go over there. And I
22 worked -- I worked on two films out here when I
23 was -- one when I was 12, the other one when I was
24 11 or so, or 10. And those are the times that I
25 would go out there, and occasionally I would fall
26 asleep in his room.
27 Q. All right. After age 10, from age 11
28 through 14, how many times do you think you went to 9854
2 A. From 10 to 14? Like, six to eight times.
3 Q. And of those six to eight times, how many
4 times of those did you spend in his -- let me redo
5 that again.
6 Six to eight times doesn’t necessarily mean
7 six to eight nights, does it?
8 A. No, I would -- sometimes I would stay for a
9 weekend, sometimes it would be -- I’d try to get up
10 there -- even if it was for a day, I’d go up there.
11 But sometimes it would be, like, four days,
12 sometimes five days.
13 Q. What’s the longest you ever stayed at
15 A. When I was -- I think I was 20, I stayed
16 there for about, I don’t know, 10 days, 14 days.
17 And that was the longest trip I’d ever taken there.
18 Q. At age 20?
19 A. Yes.
20 Q. All right. Well, can I assume that at age
21 20 you were not sleeping with Michael Jackson?
22 A. I don’t think he was there on that trip. I
23 kind of just said, “I need to relax. Is it okay if
24 I use your house?” And he said, “Sure.”
25 Q. Even if he was there --
26 MR. MESEREAU: Objection. He cut off the
27 witness, Your Honor.
28 THE COURT: Sustained. 9855
1 MR. MESEREAU: May the witness complete his
3 THE WITNESS: No --
4 THE COURT: Yes.
5 THE WITNESS: No, I was just staying there by
6 myself, and I’d just stay in the guest units, and it
7 was just -- it was just that. He wasn’t even there.
8 Q. BY MR. ZONEN: Even at age 20, you wouldn’t
9 have been sleeping with him anyway, would you have?
10 MR. MESEREAU: Objection; calls for
12 THE COURT: Overruled.
13 You may answer.
14 THE WITNESS: Would you repeat the question?
15 Q. BY MR. ZONEN: But even at age 20, you would
16 not have been sleeping with him in any event; is
17 that correct?
18 A. Probably not. Like I said, you know, as you
19 get older, you start enjoying your privacy and you
20 start getting on more of a schedule. And I was
21 falling asleep on -- I had more of a schedule going.
22 I was basically going out there to write and things
23 like that, and to relax.
24 Q. Probably not -- have you slept with Mr.
25 Jackson since you turned 20?
26 A. No.
27 Q. Were there ever any occasions that you spent
28 a night in Mr. Jackson’s room in the presence of 9856
1 another boy, not your brothers?
2 A. Could you specify? So you’re saying with
3 another boy but not with my brothers or something
4 like that?
5 Q. With another boy, not your brothers. In
6 other words, did you ever --
7 A. Like I said, yes.
8 Q. Did you ever spend a night in Mr. Jackson’s
9 bedroom with another boy, not your brothers?
10 A. Sometimes. Sometimes, like I said, there
11 would be kids there. They’d be introduced as
12 cousins or something like that. And they would hang
13 with us, just as much as anyone else would.
14 Q. Do you remember the names of any of them?
15 A. Not offhand, no.
16 Q. Can you describe any of them?
17 A. They were kids. They were -- you know, some
18 of them had dark hair. Darker skin, that kind of
20 Q. What is the oldest child who ever stayed
21 with you in Michael Jackson’s room for the night?
22 A. I wouldn’t remember. I mean, they were all
23 about my age, maybe a little bit older.
24 Q. And you were 10 to 12?
25 A. It wasn’t -- what was that?
26 Q. You were 10 to 12 in that period of time,
27 10 to 13?
28 A. Right around there, yeah. Whenever I was 9857
1 around, sometimes there would be other kids around.
2 And, you know, it wasn’t like we all, like, “Oh,
3 it’s time to go to bed. Let’s huddle in.” It’s
4 like, you know, you’re chatting in bed, and the next
5 thing you know you’re asleep.
6 Q. But most of the occasions that you stayed at
7 Michael Jackson’s house was between the ages of 9
8 and 10; is that right?
9 A. Most of the times that I went there?
10 Q. Yes.
11 A. Yeah, just about. Probably that would be
12 about right. When I first -- when I first went
13 there, it was such an amazing place, that I decided
14 to -- you know, any opportunity I had to go out
15 there, I would go.
16 Q. And after the Bermuda trip, your visits to
17 Neverland diminished? They were fewer?
18 A. Not necessarily by choice. I just didn’t
19 really find myself out on the West Coast as often.
20 Q. Did Mr. Jackson ever take you on shopping
22 A. Yeah, we’d go shopping.
23 Q. Where?
24 A. We used to do this thing where in the middle
25 of the night -- not necessarily the middle of the
26 night, but around, like, after the stores had
27 closed, he would arrange for us to go to Toys-R-Us.
28 And sometimes he wouldn’t even arrange it. We would 9858
1 go there, and he’d literally knock on the door, and
2 the janitor would drop his mop, and go, “What the
3 heck?” and let us in. And then they’d -- you know,
4 we’d go shopping basically at Toys-R-Us when the
5 store was totally empty, because it’s the only time
6 that he could really go shopping like that.
7 Q. How many times did he do that with you?
8 A. Oh, gosh. Like two times, three times --
9 Q. How old were you?
10 A. -- something like that.
11 About -- I think the first time we did it
12 was, like, ten.
13 Q. Did you ever have a conversation with either
14 of your parents about the propriety of your sharing
15 a bed with Michael Jackson?
16 A. Did I ever have a conversation with him --
17 with them about what?
18 Q. Let me change that question.
19 Did you ever have a conversation with your
20 parents prior to the age of 13? In other words, 12
21 or younger. While you were 12 years of age or
22 younger, did you ever have a conversation with
23 either of your parents about whether or not you
24 should be sharing a bed with Michael Jackson?
25 A. No. They never really saw it as an issue.
26 Q. Did they know that you were sleeping in his
28 A. I assume so. 9859
1 Q. You assume so?
2 A. I can’t tell you what they -- what they knew
3 or didn’t know or what they thought or didn’t think.
4 Q. Can we assume from that your parents never
5 came into the room while you were in bed with
6 Michael Jackson?
7 A. That’s not true, no. Sometimes my father
8 would wake us up, because he liked going horseback
9 riding or something like that and, you know, things
10 that I didn’t necessarily enjoy as much as he did,
11 but he would wake me up early in the morning to go
12 horseback riding.
13 Q. And you would be in bed alone with Michael
15 A. Not always alone, no. And sometimes I
16 wouldn’t be always there. I would be wherever. But
17 I knew they knew that I was in that room, and they
18 knew I fell asleep there.
19 Q. Mr. Culkin --
20 MR. MESEREAU: Objection, he’s cutting off
21 the witness.
22 MR. ZONEN: The answer is nonresponsive to
23 the question.
24 THE COURT: It’s overruled. And you are
25 cutting him off.
26 THE WITNESS: Yeah, he knew that I was --
27 MR. ZONEN: There’s no question pending.
28 Q. BY MR. ZONEN: Mr. Culkin -- 9860
1 THE COURT: Well, just a minute. Let me
2 take a minute here. You are getting kind of rushed
3 here. And you are cutting the witness off.
4 I’ll just go back and take a look at this.
5 Ask a new question, please.
6 Q. BY MR. ZONEN: Did your father ever come
7 into Michael Jackson’s bedroom while you were in bed
8 with Mr. Jackson alone?
9 A. From what I remember, yeah.
10 Q. Did that happen more than once?
11 A. Yeah. From I remember, it’s -- I don’t
12 really remember all these kind of details, but I
13 knew he knew I was staying there. So -- and
14 occasionally, I would be woken up to do something
15 that he felt like doing.
16 Q. When was the first time your father walked
17 into the room while you were in bed alone with
18 Michael Jackson?
19 A. I can’t recall.
20 Q. How old were you the first time your father
21 walked into the room when you were alone with
22 Michael Jackson?
23 A. I don’t recall. It was during one of the
24 earlier trips.
25 Q. So you were about nine years old?
26 A. Probably a little bit older. Like -- I
27 don’t think I went there -- I think I went there the
28 first time when I was ten. I think I first met 9861
1 Michael when I was nine.
2 Q. So the first time you would have been alone
3 in bed with him, you were already ten years old?
4 A. Probably, yes.
5 Q. All right. Is there -- was there at the
6 time an alarm on his door going into his bedroom?
7 A. There was like a walkway kind of thing where
8 if somebody was approaching the door, it would kind
9 of like “ding-dong, ding-dong.”
10 Q. All right. Do you remember hearing any
11 “ding-dongs, ding-dongs” as your father came into
12 the room?
13 A. When anyone would approach the room, yeah,
14 you’d hear this kind of -- soft kind of alarm, like
15 “ding-dong” kind of thing.
16 Q. On the occasion that your father came into
17 the room while you were in bed alone with Michael
18 Jackson, did he say anything to you about that?
19 A. No.
20 Q. Did he say anything to Michael Jackson in
21 your presence about your sleeping with him?
22 A. No. He didn’t really seem to have a problem
23 with it, from what I remember.
24 Q. And I asked you if he said anything. Did he
25 say anything to Michael Jackson in your presence?
26 A. Well, what do you mean by “anything”?
27 Q. Did he say anything to Michael Jackson about
28 him sharing a bed with his ten-year-old son? Did he 9862