1 REPORTER’S CERTIFICATE
2
3
4 THE PEOPLE OF THE STATE )
5 OF CALIFORNIA, )
6 Plaintiff, )
7 -vs- ) No. 1133603
8 MICHAEL JOE JACKSON, )
9 Defendant. )
10
11
12 I, MICHELE MATTSON McNEIL, RPR, CRR,
13 CSR #3304, Official Court Reporter, do hereby
14 certify:
15 That the foregoing pages 9441 through 9500
16 contain a true and correct transcript of the
17 proceedings had in the within and above-entitled
18 matter as by me taken down in shorthand writing at
19 said proceedings on May 9, 2005, and thereafter
20 reduced to typewriting by computer-aided
21 transcription under my direction.
22 DATED: Santa Maria, California,
23 May 9, 2005.
24
25
26
27 MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304
28 9501
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
5
6
7 THE PEOPLE OF THE STATE OF )
8 CALIFORNIA, )
9 Plaintiff, )
10 -vs- ) No. 1133603
11 MICHAEL JOE JACKSON, )
12 Defendant. )
13
14
15
16
17 REPORTER’S TRANSCRIPT OF PROCEEDINGS
18
19 MONDAY, MAY 9, 2005
20
21 8:30 A.M.
22
23 (PAGES 9502 THROUGH 9678)
24
25
26
27 REPORTED MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304
28 BY: Official Court Reporter 9502
1 APPEARANCES OF COUNSEL:
2
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
9
10
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
14 -and-
15 SANGER & SWYSEN
16 BY: ROBERT M. SANGER, ESQ. 233 East Carrillo Street, Suite C
17 Santa Barbara, California 93101
18
19 The Interpreters: Rose O’Neill Doris Vick
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28 9503
1 I N D E X
2
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.
7
8
9 DEFENDANT’S
10 WITNESSES DIRECT CROSS REDIRECT RECROSS
11 SILVA, Violet 9558-SN 9597-SA 9614-SN
12 9618-SA
13 (Further)
14 VELASCO, Ramon 9622-SA 9633-A
15 MARCUS,
16 Joseph 9635-SA
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28 9504
1 E X H I B I T S
2 FOR IN DEFENDANT’S NO. DESCRIPTION I.D. EVID.
3
4 5030 Map of Solvang area 9671 9672
5
6
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28 9505
1 MR. SANGER: May I proceed?
2 THE COURT: Yes.
3 Q. BY MR. SANGER: Okay. You’ve described the
4 patrol -- you started to describe the patrol around
5 the house, and I think you said the person who’s
6 assigned to the house would be in that security
7 office at the end of the video library building,
8 garage building, and would also walk around the
9 house?
10 A. Yes.
11 Q. Does that mean walk inside the house?
12 A. No.
13 Q. Did security walk inside the house from time
14 to time?
15 A. Yes.
16 Q. Was that part of the regular patrol, to walk
17 inside the house?
18 A. No.
19 Q. When you say “walk around the house,” then
20 you literally mean around the outside of the house?
21 A. Yes.
22 Q. And what was the purpose of doing that?
23 A. To make sure we didn’t have any hazards or
24 uninvited guests or trespassers.
25 Q. Was it important to make sure that the
26 house, in general, was secure?
27 A. Yes.
28 Q. Now, during the time that you’ve been there, 9506
1 have there been trespassers located on the ranch?
2 A. Yes.
3 Q. And how close to the house did they get?
4 A. We’ve had one trespasser who did enter the
5 house.
6 Q. And where was that person ultimately found?
7 A. In the very top floor of the main house, in
8 the train room.
9 Q. So right up above where the children’s rooms
10 are, Prince and Paris’s rooms are?
11 A. Yes.
12 Q. So that was a very private part of the
13 house?
14 A. Yes.
15 Q. And without going into a lot of detail, who
16 was this person? Was this a fan or --
17 A. We determined she was not from this country.
18 She was a fan. We couldn’t communicate with her
19 very well, because she didn’t speak English, so she
20 was arrested.
21 Q. You speak Spanish yourself?
22 A. Yes.
23 Q. So she didn’t speak English or Spanish, I
24 take it?
25 A. I believe she spoke German, which I do not
26 speak.
27 Q. So sort of a -- not a normal person to sneak
28 into somebody’s house, though? 9507
1 A. No.
2 Q. And do you know how long that person was
3 there before she was located?
4 A. I’d estimate she was there approximately ten
5 hours.
6 Q. Have there ever been any people located on
7 the ranch who had weapons?
8 A. We recently did arrest someone who had a
9 weapon. It was not loaded with anything. It was a
10 disabled weapon.
11 Q. A handgun?
12 A. Handgun, yes. Nine-millimeter.
13 Q. Now, in your years of working in security,
14 have you ever performed security functions for Mr.
15 Jackson off of the ranch?
16 A. Yes.
17 Q. And where would that be?
18 A. I’ve taken them to the Lompoc fireworks
19 show. I think I’ve maybe done that two or three
20 times.
21 Q. Okay. If -- have you ever been gone on tour
22 or gone to other cities with them?
23 A. No.
24 Q. Does he have security staff who he employs
25 for that purpose?
26 A. Yes.
27 Q. And that security staff is not in your --
28 under your jurisdiction; is that correct? 9508
1 A. No.
2 Q. Excuse me. All right. So when this foot
3 patrol -- I’m saying “foot patrol,” but the person
4 around the house, you say foot patrol person around
5 the house, what are some of the things that they
6 check? You said there was some woman that got into
7 the upper house. I assume that’s something you try
8 to prevent.
9 A. Yes. We check the doors. The house is
10 secured at all times. Now the house is secured at
11 all times. So we make sure that the doors and
12 windows are closed. We also make sure that -- you
13 know, if there’s anything like a fire happening or
14 some other hazard that’s going on.
15 Q. And that sort of thing has happened in the
16 past, has it not?
17 A. As far as fires?
18 Q. Fires.
19 A. Yes.
20 Q. So you check the door, like the back door
21 and the front door, correct?
22 A. We check all the doors.
23 Q. Are there some doors around Mr. Jackson’s
24 private quarters?
25 A. Yes.
26 Q. What doors are there?
27 A. There’s a patio door entrance.
28 Q. All right. So there’s a patio right behind 9509
1 Mr. Jackson’s private suite, correct?
2 A. Yes.
3 Q. And there’s a door that locks in the wall
4 around that private patio; is that right?
5 A. Yes.
6 Q. And why is it important to keep that
7 secured?
8 A. To make sure -- well, we do open it
9 occasionally for people to go in and clean. If we
10 do find it unsecured, then we go as far as his back
11 door and make sure that it’s still secure, and we
12 clear the area, and then close it afterwards, lock
13 it.
14 Q. If some -- an intruder were to get in and
15 they knew where they were going, and they were able
16 to get through that door, that would be a pretty
17 significant breach of security as far as Mr.
18 Jackson’s personal area is concerned; is that
19 correct?
20 A. Yes.
21 Q. All right. Now, when we talk about the
22 personal area, are you aware that there are locks on
23 Mr. Jackson’s door into his personal bedroom suite?
24 A. Yes.
25 Q. All right. There are guests who have -- let
26 me withdraw that. If guests stay at the guest
27 quarters that are just across the front driveway --
28 is that right? By the lake, correct? 9510
1 A. Yes.
2 Q. If guests stay there, where do they take
3 their meals?
4 A. In the main house.
5 Q. So they would be expected to have the code
6 to come into the main house, sit down at the
7 breakfast table or the breakfast bar there?
8 A. Yes.
9 Q. Or the dining table, I suppose, for dinner,
10 right?
11 A. Yes.
12 Q. Is that fairly routine? In other words,
13 most of the guests that are staying overnight there
14 have access to the main house?
15 A. Yes.
16 Q. Do most of the guests who are staying
17 overnight there have access to Mr. Jackson’s private
18 quarters?
19 A. I wouldn’t say most guests.
20 Q. So Mr. Jackson will decide who he’s going to
21 allow into his private quarters; is that right?
22 A. Yes.
23 Q. And on a given day, you might have staff
24 people and visitors and a number of other people in
25 that main part of the house; is that right?
26 A. Yes.
27 Q. Does Mr. Jackson want to maintain some
28 privacy from that general group of people that might 9511
1 be there at any given time?
2 A. Yes.
3 Q. Now, there’s also an arcade -- I’m sorry,
4 no, that’s right, an arcade building.
5 A. Yes.
6 Q. We talked about the video library, but
7 there’s a separate building that’s the arcade
8 building, correct?
9 A. Yes.
10 Q. All right. And is that usually locked?
11 A. It’s locked at a certain hour, I would say
12 about 2 a.m. when guests are on property, unless
13 it’s been requested to leave it open all night.
14 Otherwise, it’s open approximately about 8 a.m. in
15 the morning.
16 Q. All right. And a part of that building are
17 a couple of bathrooms, a men’s room and a ladies’
18 room; is that correct?
19 A. Yes.
20 Q. And where is that in relation to the
21 swimming pool?
22 A. If you were facing the swimming pool, it
23 would be to the left.
24 Q. There’s also a tennis court nearby there; is
25 that correct?
26 A. Yes, it’s further left of that.
27 Q. So if people are using the tennis court or
28 the swimming pool, is that where they’d be likely to 9512
1 go if they were going to use the rest rooms?
2 A. Yes.
3 Q. And are those rest rooms, that rest room
4 area, is that left unlocked during the time people
5 are using the pool?
6 A. Yes.
7 Q. All right. Now, that leaves the supervisor,
8 I think. What does the supervisor do?
9 A. The supervisor is there to supervise the
10 officers. Make sure that -- we have daily duties
11 that we do, such as checking our inventory or
12 equipment, making sure that the basic part of our
13 duties are being met. We have something that’s a
14 little more elevated than regular routine business
15 there to manage that problem.
16 Q. I take it the supervisor also will keep an
17 eye out for security issues throughout the ranch; is
18 that right?
19 A. Yes.
20 Q. By the way, are any of the security guards
21 armed?
22 A. No.
23 Q. Not with anything?
24 A. We do have pepper spray. But that’s used
25 only under very limited conditions. We’ve never
26 pepper-sprayed anyone.
27 Q. That’s pretty limited. So you’ve never used
28 it? 9513
1 A. Never used it.
2 Q. And it’s there for the case of an intruder,
3 for the most part; would that be correct?
4 A. Yes.
5 Q. So you don’t carry firearms, stun guns,
6 anything like that?
7 A. Not during the time when I was chief.
8 Q. All right. You mentioned the gate logs.
9 And you’re aware that there was a search on November
10 18th, 2003; is that correct?
11 A. Yes.
12 Q. Did you -- were you at the ranch when the
13 search occurred?
14 A. Not initially. But I did arrive afterwards.
15 Q. Was it your shift to be there?
16 A. I was not going to start my shift until noon
17 that day.
18 Q. So somebody called you, and you came more
19 quickly?
20 A. Routinely I would call in the morning to see
21 what activities happened overnight, if there was
22 anything I needed to be briefed on. So I’d usually
23 call around 8 a.m. to see what was new or what would
24 be expected for that day.
25 I was actually on the phone with Brian
26 Salce, who’s a firefighter, just going over regular
27 things when he was describing to me what happened.
28 Q. All right. So what happened, you were 9514
1 hearing that a whole lot of sheriffs deputies and
2 other people all of a sudden arrived at the ranch;
3 is that correct?
4 A. Yes.
5 Q. So you came in?
6 A. Yes.
7 Q. At the time of the search, was there any
8 effort made to conceal anything from law
9 enforcement?
10 A. No.
11 MR. SNEDDON: Object; leading.
12 THE COURT: Sustained.
13 Q. BY MR. SANGER: All right. To your
14 knowledge, were there any efforts made one way or
15 another to prevent law enforcement from finding
16 something?
17 A. No.
18 MR. SNEDDON: Same objection, Your Honor.
19 THE COURT: Sustained.
20 Q. BY MR. SANGER: All right. In any event,
21 after the officers left, did you stay there till
22 they left?
23 A. Yes.
24 Q. About what time of night did they leave?
25 A. Approximately 11 -- between 10:30 p.m. and
26 11 p.m.
27 Q. All right. Excuse me one second.
28 I’ll just ask. Can I have the gate logs? 9515
1 I don’t remember the number. It’s the book with the
2 gate logs.
3 THE BAILIFF: Mr. Auchincloss has them.
4 MR. SANGER: There’s a good reason why you
5 can’t find it. All right. Thank you.
6 Q. All right. We’re talking about a gate -- or
7 I’m going to talk about gate logs here in a second.
8 So you told us about the gate logs being
9 kept at the ranch, right?
10 A. Yes.
11 Q. When are the entries made in the gate logs?
12 A. The entries are made as people arrive.
13 Their “in” time is documented or logged on the
14 sheet; when they leave.
15 Q. So in other words, they’re logs that are
16 made contemporaneously with the event. Something
17 happens, and it’s written down; is that right?
18 A. Yes.
19 Q. It’s not written down at the end of shift or
20 the next day, for the most part?
21 A. No.
22 Q. Okay. When the officers search -- the team
23 from the sheriff’s department and the District
24 Attorney’s Office searched and they left, did you --
25 at some point thereafter, did you have occasion to
26 determine whether or not they had located all of the
27 gate logs?
28 A. I believe they had complete access -- they 9516
1 did have complete access to it. We had two
2 investigators and one deputy in that security office
3 for approximately two hours.
4 Q. Did they take the gate logs for 2003?
5 A. No.
6 Q. Where were they located?
7 A. They were located in the file cabinet.
8 Q. Right there in the security office?
9 A. Yes.
10 Q. All right. Did you later at some point
11 locate those records?
12 A. I located them that same evening.
13 Q. Later, in the middle of the night?
14 A. I was there for another day.
15 Q. All right. So you didn’t go home that
16 night?
17 A. No.
18 Q. What did you do with the gate logs?
19 A. I left them in the file cabinet.
20 Q. At some point, did you take those gate logs
21 out and give them to somebody?
22 A. Yes.
23 Q. Who did you give them to?
24 A. Mark Geragos.
25 MR. SANGER: All right. I’m going to refer
26 to Exhibit 334 and 335, and I’d like to approach the
27 witness if I may, Your Honor.
28 THE COURT: You may. 9517
1 MR. SANGER: And I would -- there is some
2 Post-its on there. I don’t know if they’re -- okay.
3 May I inquire of counsel, Your Honor?
4 Did you put the Post-its on there, Mr.
5 Auchincloss?
6 MR. AUCHINCLOSS: One of them, yes.
7 MR. SANGER: Okay.
8 Q. All right. Well, just ignore the Post-its,
9 all right?
10 A. Okay.
11 Q. And take a look at Exhibit 334 and 335.
12 Just take your time and look through it.
13 So that’s the pages from where your hand is
14 all the way to the end of the book, basically, okay.
15 You don’t have to look at all the pages.
16 A. Okay.
17 Q. Somebody’s already made an identification,
18 but I’m just going to ask you if those, in general,
19 appear to be the gate logs that you located in the
20 office after the search?
21 A. Yes.
22 Q. And those are the gate logs that you -- that
23 you gave to Mr. Geragos; is that correct?
24 A. Yes.
25 Q. At the time you gave them to Mr. Geragos,
26 you understood that Mr. Geragos was representing Mr.
27 Jackson --
28 A. Yes. 9518
1 Q. -- correct?
2 And those gate logs are logs that were kept
3 on a contemporaneous basis? In other words, things
4 were written in them when they happened?
5 A. Yes.
6 Q. Okay. Now, before we go to some of the
7 details in there, let me ask you a couple more
8 general questions.
9 Do the gate logs sometimes indicate
10 instructions that are to be communicated to all of
11 the security staff?
12 A. Yes.
13 Q. And what’s the purpose of that?
14 A. So that we follow that directive for the
15 day. Or if it’s a directive that’s given to us for
16 a two-week period, then it’s noted in the gate log
17 and then carried over until it’s no longer in
18 effect.
19 MR. SANGER: All right. May I approach and
20 retrieve the book?
21 THE COURT: Yes.
22 MR. SANGER: Thank you.
23 Q. All right. Let me go back to a subject that
24 you had discussed earlier with regard to records
25 that were kept. There are medical records; is that
26 right?
27 A. Yes.
28 Q. And the medical records, are they part of 9519
1 the gate logs, or are they just --
2 A. No, they’re separate.
3 Q. So it’s a separate file folder that you keep
4 these --
5 A. A separate binder.
6 Q. Or a binder? All right.
7 You mentioned that there was a -- if
8 somebody was disciplined, for instance, for -- or
9 let me withdraw that.
10 If somebody was involved in a golf cart
11 accident, as an example, there would probably be a
12 record of that made; is that right?
13 A. Yes.
14 MR. SANGER: And I’m going to put, if I may,
15 Your Honor, 300 up on the -- on the board. Or on
16 the screen.
17 THE COURT: All right.
18 Q. BY MR. SANGER: Now, the trick is to look at
19 the board, and when you’re ready to answer, turn
20 around and speak into the microphone.
21 A. Yes.
22 Q. So, first of all, just for the record, I’m
23 showing Exhibit 300, and it shows the tab at the
24 bottom there. And this particular document, the
25 testimony was it was seized by the officers. Do you
26 know where that was seized from?
27 A. It was most likely in a binder that was
28 located at the security office near the house. 9520
1 Q. Okay. Now, I’ll ask you another question in
2 a minute, so we’ll leave that up there, with the
3 Court’s permission.
4 Was it the position of the staff, including
5 the security staff, to reprimand guests, whether
6 adults or children?
7 A. Yes.
8 Q. Okay. And when would that occur?
9 A. Whenever we felt their safety was in
10 jeopardy.
11 Q. All right. If it’s not a safety issue, or
12 an issue of legality, for that matter, you know,
13 something that involves security, was it your
14 position to criticize guests?
15 A. No.
16 Q. Okay. What was the policy at Neverland as
17 far as how you treated guests, whether adults or
18 children?
19 A. We were very accommodating. Our emphasis is
20 on hospitality and making sure that they feel
21 welcome.
22 Q. Okay. And why was that?
23 A. That’s what Mr. Jackson wanted.
24 Q. And as far as -- even though there are a lot
25 of people involved, were you trying to make the
26 atmosphere welcome to the guests, as if it was
27 somebody’s home?
28 A. That was our primary duty was to make them 9521
1 feel welcome.
2 Q. Okay. Now, if somebody was driving the golf
3 cart and there was a safety issue, you now have this
4 up on the board, and it appears that the driver in
5 this case was Gavin Arvizo, is that correct, on
6 Exhibit 300?
7 A. Yes.
8 Q. Okay. And this is something that happened
9 June 21st of ‘02; is that correct?
10 A. Yes.
11 Q. All right. Now, according to this -- by the
12 way, it says the reporting officer is G. Silva.
13 That’s not you?
14 A. No.
15 Q. As -- you were the chief at this time,
16 though; is that correct?
17 A. Yes.
18 Q. And you were responsible ultimately for all
19 of the reports and acts by your officers; is that
20 correct?
21 A. Yes.
22 Q. Now, it indicates here, “Gave verbal warning
23 to slow down or golf cart would be taken away.”
24 Would that be a policy?
25 A. Yes.
26 Q. And so what would you expect your officer to
27 do at a time like that?
28 A. To take the cart away, if it was necessary. 9522
1 Q. So if it went on, actually take the cart
2 away and say, “You can’t drive the cart”?
3 A. Yes.
4 Q. And did that happen from time to time with
5 guests?
6 A. Yes.
7 MR. SANGER: All right. Now I’ll take this
8 one down.
9 And give me just a second, please, Your
10 Honor, because otherwise the book is going to be a
11 mess.
12 All right. The book is going to be a mess
13 anyway. I have to deal with it in a second.
14 Q. Okay. Now, did guests -- were guests
15 cleared to do --
16 We can have the lights, if that’s all right.
17 I’ll come back to this in just a minute.
18 Were guests cleared to do certain things?
19 A. Yes.
20 Q. Were some guests not cleared to do certain
21 things?
22 A. Yes.
23 Q. And there was a list which -- because the
24 book is falling apart, I’m not going to turn to it
25 right now, but there is a list when people are
26 coming on the property that, at various times during
27 the time you were there, guests would be cleared for
28 certain activities and not others; is that right? 9523
1 A. Yes.
2 Q. And one of the activities was using the
3 quadrunners; was that right?
4 A. Yes.
5 Q. If a guest was not behaving properly on the
6 quadrunners or didn’t show they were able to handle
7 them, they might be excluded from using the
8 quadrunners the next time?
9 A. Yes.
10 Q. That would show up in your records so that
11 you would be able to refer to that; is that right?
12 A. If we were asked for a particular event, we
13 would be able to.
14 Q. Now, did you always make things available to
15 guests -- take your time. Have some water.
16 A. Excuse me.
17 Q. That’s okay.
18 You also make equipment available to guests?
19 A. Yes.
20 Q. If they asked for it?
21 A. Well, if they were allowed to use it, yes.
22 Q. Okay. Were there occasions where you would
23 not allow guests to use certain equipment?
24 A. Yes.
25 Q. And what technique would you use to advise
26 guests that -- or convince guests that they might
27 not use certain equipment?
28 A. Well, if they requested it and they were 9524
1 allowed to use it, of course we would make it
2 available to them.
3 If they requested it and they were not
4 allowed to use it, then we would be very diplomatic
5 about our reason for not allowing it to be used at
6 that time.
7 Q. And how might you do that?
8 A. We might -- we just would say simply that
9 the quads were not available for this weekend or for
10 this day.
11 Q. Something like that. All right. So once
12 again, you’re trying to be courteous to the guests,
13 right?
14 A. Yes.
15 Q. We’ll come back to the gate logs in a little
16 bit, but let me ask you some general questions.
17 I’m going to take you back to the period from 1991
18 to 1993 when you worked there.
19 A. Okay.
20 Q. Did you have occasion to know the Robson
21 family?
22 A. Yes.
23 Q. And can you describe the Robson family?
24 A. The family that I knew is a mother, daughter
25 and son. Wonderful family. They seemed to be very
26 close-knit. Both Chantal and Wade are bright, very
27 articulate young people. And they’re always very
28 pleasant to be around. 9525
1 Q. Did you ever see anything inappropriate
2 occur with regard to the Robson family?
3 A. No.
4 MR. SNEDDON: Object; vague.
5 THE COURT: Overruled. The answer is, “No.”
6 Next question.
7 Q. BY MR. SANGER: Did you know the Culkin
8 family?
9 A. Yes.
10 Q. Can you describe that family?
11 A. Mother and father. I don’t quite remember
12 how many kids they had. I think they had a few.
13 Nice family.
14 Q. Okay. How about the Barnes family?
15 A. Yes.
16 Q. Tell us about them.
17 A. I met the mother, Karlee and Brett as well.
18 I met the father once or twice. Wonderful family as
19 well.
20 Q. And did they -- did these families spend
21 time at the ranch while you were there?
22 A. Yes.
23 Q. Did they spend time as a family?
24 A. Yes.
25 Q. Did they engage in activities at the ranch?
26 A. Yes.
27 Q. Was Mr. Jackson always there when these
28 families were there? 9526
1 A. Not always.
2 Q. Did you see Mr. Jackson interact with the
3 families?
4 A. Yes.
5 Q. If Mr. Jackson was on the property, did he
6 spend all of his time with these families when they
7 visited?
8 A. No.
9 Q. What would Mr. Jackson do during this period
10 of time besides spend time entertaining the guests?
11 A. I wouldn’t know. I guess whatever Mr.
12 Jackson does on his own time.
13 Q. Okay. Does Mr. Jackson have a studio on the
14 ranch?
15 A. He has a dance studio.
16 Q. Does he spend time in the dance studio?
17 A. Yes.
18 Q. Is that someplace where he goes to work?
19 A. Yes.
20 Q. Does he spend sometimes hours in the dance
21 studio?
22 A. Yes.
23 Q. Does he work in the dance studio till late
24 night, late at night sometimes?
25 A. Yes.
26 Q. All right. Now, by the way, do you know the
27 Chandler family?
28 A. Yes. 9527
1 Q. Can you tell me about the Chandler family?
2 A. Mother, young daughter at the time, I
3 believe her name is Lily, and Jordie.
4 Q. Okay. And did you -- same questions I asked
5 with regard to the other families. Did you see Mr.
6 Jackson spend time with that family?
7 A. Yes.
8 Q. And sometimes he’d be on the property and
9 wouldn’t be with the family?
10 A. Yes.
11 Q. And sometimes he would not be on the
12 property?
13 A. Yes.
14 Q. Now, for the most part, when children
15 visited Neverland Ranch, did they visit the ranch
16 with their parents?
17 A. Most of the time, yes.
18 Q. Now, we’ve heard about the large groups of
19 kids that would come from either hospitals, or
20 Make-A-Wish, or disadvantaged circumstances. That’s
21 a different situation, I take it; is that right?
22 A. Yes.
23 Q. And can you describe what would happen when
24 those people would come to the ranch? I say “those
25 people.” When those groups would be invited to the
26 ranch.
27 A. A typical day for them is they would arrive
28 approximately between 10:30 a.m. and 11:00. They 9528
1 would be greeted by Neverland staff. Depending on
2 the size of the group, they’d either be divided into
3 two groups or kept in one group.
4 What they would see on the property is the
5 zoo area, which they would arrive via small train
6 that we have. They’d spend time there. They would
7 have lunch approximately around noon, and either go
8 to the theater or the amusement park. If we had two
9 groups, one group would go to the arcade and do the
10 same thing, but switch off so they weren’t in the
11 same places at the same time.
12 Eventually both groups would end up at the
13 amusement park at the same time.
14 Q. Did those groups of kids tend to have a good
15 time there, as far as you could tell?
16 A. Oh, yes.
17 Q. Okay. Is it part of the job that you
18 enjoyed watching these kids?
19 A. Absolutely.
20 Q. Now, those groups of kids would be monitored
21 or - what’s the word? - chaperoned or supervised by
22 people that generally came along with the group; is
23 that correct?
24 A. Yes.
25 Q. And then staff people at Neverland would
26 also assist?
27 A. Yes.
28 Q. With regard to the other children that came 9529
1 to the ranch, did the other children who came to the
2 ranch generally come with their parents?
3 A. Yes.
4 Q. In other words, the guests, the ones that
5 might stay overnight, came with their parents
6 generally?
7 A. Yes.
8 Q. Okay. If parents were there to supervise,
9 would it be appropriate for staff to override a
10 parent’s decision on something?
11 A. Yes.
12 Q. And would that be appropriate?
13 A. That would be appropriate, again, if their
14 immediate safety was in jeopardy.
15 Q. So if kids were getting out of control,
16 would you intercede?
17 A. I’m sorry, I didn’t hear the last --
18 Q. If kids were getting out of control, would
19 you intercede?
20 A. Yes.
21 Q. Did you have any knowledge of any child
22 drinking alcohol or appearing to be under the
23 influence at any time when you worked there from
24 1991 to the present?
25 A. No personal knowledge, no.
26 Q. And the alcohol on the ranch was -- where
27 was that kept?
28 A. We -- I believe there is some alcohol 9530
1 located in the kitchen. Generally it’s kept in the
2 wine cellar.
3 Q. All right. And was the wine cellar
4 generally locked?
5 A. Yes.
6 Q. Were children allowed to go into the wine
7 cellar?
8 A. No.
9 Q. Where was the key kept for the wine cellar?
10 And I’m going to ask you if it’s moved from one time
11 to another. Would you tell us about that?
12 A. Depending on the activity, there are two
13 keys available. One in the main house and one in
14 the security office.
15 Q. All right. And do you know where the key in
16 the main house was kept?
17 A. Mostly behind the door as you enter the
18 house staff’s break room.
19 Q. So in the house, if you go through the back
20 door, there is a little hallway that takes you to
21 the left. That would take you to the kitchen and
22 the family room, dining room, that sort of thing; is
23 that correct?
24 A. Yes.
25 Q. And if you went through all of that, you’d
26 keep going, you’d get to the library and to Mr.
27 Jackson’s private area; is that correct?
28 A. Yes. 9531
1 Q. If you come in the back door and enter that
2 hallway, just to the right is where the maids’ break
3 room is; is that correct?
4 A. If you go through the back door, it’s
5 directly across. You go straight into the --
6 Q. So instead of going left down the hallway,
7 you just go straight into that room?
8 A. Straight into it.
9 Q. All right. And is that a room that has
10 couches and chairs and whatnot?
11 A. Yes.
12 Q. Comfortable room?
13 A. Yes.
14 Q. And that’s used for the staff to take
15 breaks, I take it?
16 A. Yes.
17 Q. And as you go across that hallway, just
18 right inside the back door, the rack with the keys
19 on it is just behind the door as you enter the break
20 room; is that right?
21 A. Yes.
22 Q. And the break room is left unlocked for the
23 most part; is that right?
24 A. As far as I know it is.
25 Q. Okay. Now, with regard to children visiting
26 the ranch and activities - and let’s talk about the
27 guests who were staying overnight as opposed to the
28 guests from the Make-A-Wish and that sort of thing - 9532
1 were both boys and girls included in the activities
2 at Neverland?
3 A. Yes.
4 Q. Was there any discrimination, to your
5 knowledge?
6 A. No.
7 Q. Did girls seem to have a good time?
8 A. Yes.
9 Q. Do you remember Marie Nicole?
10 A. Yes.
11 Q. And who’s Marie Nicole?
12 A. Marie Nicole is the only daughter in the
13 Cascio family.
14 Q. Okay. And did she have the same run of the
15 ranch, as it were, as her brothers?
16 A. Yes.
17 Q. And you mentioned the families -- the Robson
18 family, the Barnes family. They both had daughters?
19 A. Yes.
20 Q. And the Culkin family also had daughters; is
21 that correct?
22 A. One daughter.
23 Q. Were those girls entitled to the same
24 privileges that their brothers were?
25 A. Yes.
26 Q. Did they engage in Super Soaker games from
27 time to time?
28 A. Yes. 9533
1 Q. Water balloon fights?
2 A. Yes.
3 Q. Did they go in the Jacuzzi?
4 A. Yes.
5 Q. The pool?
6 A. Yes.
7 Q. Play in the arcade?
8 A. Yes.
9 Q. Go in the house?
10 A. Yes.
11 Q. All right. Now, at some point, you met a
12 person named Gavin Arvizo; is that correct?
13 A. Yes.
14 Q. Do you recall roughly when the first time
15 was that Gavin Arvizo came to the ranch?
16 A. August of 2002.
17 Q. August of 2002?
18 A. August of 2000, excuse me.
19 Q. Okay. That’s fine. And the -- did he come
20 there with his family?
21 A. The first time I met him, I met him with his
22 brother Star and his father David, I believe.
23 Q. Okay. Did you ever -- the first -- let me
24 withdraw that.
25 Was Janet Arvizo there the first time you
26 met Gavin?
27 A. I did not meet Mrs. Arvizo the first time.
28 Q. What do you recall about the first visit 9534
1 that the Arvizos had to the ranch?
2 A. Well, Gavin was quite sick at the time.
3 What I most remember is the dad being present and
4 taking care of him with his brother.
5 Q. Okay. Were there other visits between 2000
6 and 2003? In other words, before February of 2003,
7 were there other visits that the Arvizo family made
8 to the ranch?
9 A. Yes.
10 Q. And during those visits, was Mr. Jackson
11 always present at the ranch?
12 A. No.
13 Q. Who did they tend to come with when Mr.
14 Jackson was not present?
15 A. Chris Tucker.
16 Q. Was the father always present?
17 A. No. After they came, I believe, after Gavin
18 was sick, he seemed to recover, and I don’t remember
19 the father coming after that.
20 Q. Okay. So while Gavin was sick, his father
21 was there; is that correct?
22 A. Yes.
23 Q. And while the father was there, how did the
24 boys behave?
25 A. There were very well behaved.
26 Q. When the father stopped coming, how did the
27 boys behave?
28 A. They increasingly became a little more 9535
1 rambunctious.
2 Q. All right. Now, you said that Gavin seemed
3 to be ill and was eventually recovering, and he got
4 to a point where he seemed to have recovered?
5 A. Yes.
6 Q. Okay. While he was visibly ill, how did Mr.
7 Jackson interact with him?
8 A. I think he was very gentle with him, very
9 caring, just what I remember at the time.
10 Q. Did he seem to be concerned about him, his
11 well-being?
12 A. Yes.
13 MR. SNEDDON: I’m going to object. Calls
14 for speculation.
15 THE COURT: It’s leading. Sustained.
16 Q. BY MR. SANGER: All right. Now, let’s talk
17 about up to the point just before February 2003. Do
18 you recall the last time that this family or any
19 members of this family visited the ranch?
20 A. I believe it was in the summer of 2002.
21 Q. And how were the Arvizo boys behaving during
22 that time, in the summer of 2002?
23 A. They were quite active during that time
24 period.
25 Q. And when you say “quite active,” what did
26 they do?
27 A. I would say they were enjoying all the
28 privileges of the ranch. I wouldn’t say they were 9536
1 nonstop, but they were pretty active.
2 Q. Okay. And did they have some problems that
3 seemed to need some attention?
4 A. Yes.
5 Q. Can you describe what that was?
6 A. Well, we just had a viewing of a golf cart
7 accident, so that would be one example.
8 Q. Okay. Do you recall the family coming to
9 the ranch in February of 2003?
10 A. Yes.
11 Q. And what happened in February 2003? Let me
12 withdraw that.
13 Let’s start with this: What were the Arvizo
14 children doing in February of 2003?
15 A. They were there for an extended amount of
16 time. I don’t know exactly what they were there
17 for.
18 Q. Okay. Did they tend to be in the presence
19 of the security people?
20 A. Yes.
21 Q. Describe that.
22 A. Well, they were there for quite a while, off
23 and on, throughout the weeks. We had contact with
24 them because of their behavior, their activity.
25 That’s pretty -- it was pretty limited to that.
26 Q. What did they -- what kind of behavior are
27 you talking about?
28 A. You know, again, they were active. I guess 9537
1 I’m trying to be polite here. They were very
2 active.
3 Q. Well, you have to be -- it’s nice that
4 you’re being polite, but we have to ask you to just
5 tell it like it is, whatever it is.
6 A. They were pretty reckless at the time. They
7 were driving very fast in the golf carts. They were
8 also driving ranch vehicles. They’d get in a ranch
9 vehicle, and take off and drive, and we’d have to
10 stop them. You know, they were young. They
11 couldn’t drive a regular vehicle.
12 Q. Well, let me stop you at that for a moment.
13 When you say “ranch vehicles,” what kind of vehicles
14 did you have to stop them in?
15 A. A regular van, like an Astro van. Mr.
16 Jackson’s personal vehicle, a Navigator at the time.
17 Other things, like -- they were pretty destructive,
18 I would say.
19 Q. So let’s talk about the vehicles first. At
20 the ranch, are the keys usually left in the vehicles
21 during the day?
22 A. Yes.
23 Q. Are they left in the vehicles during the
24 night?
25 A. Yes.
26 Q. In fact, in the garage -- there are some
27 vehicles that are parked in the garage, correct?
28 A. Yes. 9538
1 Q. And the keys for those vehicles are sitting
2 right up on the dashboard right there in view?
3 A. Depending on what is in the garage at the
4 time, I would say yes.
5 Q. Okay. So when the Arvizo kids got the --
6 say, the Astro van, an Astro is like a regular
7 mini-van, right?
8 A. Yes.
9 Q. When they got in, say, the Astro van and
10 started driving it, to your knowledge, did they ask
11 anybody for permission?
12 A. No.
13 Q. And where would they drive it?
14 A. They would drive it on the property.
15 Q. Okay. Do you know if they ever drove out
16 through the gates, the golden gates I guess you call
17 them?
18 A. Well, they did drive it around. How far
19 they went -- they never drove off the property, but
20 they drove on the property.
21 Q. Okay. Did they drive golf carts through the
22 golden gates?
23 A. Yes.
24 Q. So they would be out in that area between
25 the -- I still don’t have the word for it, but
26 whatever it is, the private --
27 A. Occupied area of the property.
28 Q. There you go. Occupied area. They’d be out 9539
1 in the area that is more or less ranch land; is that
2 correct?
3 A. Right.
4 Q. All right. Were they neat and tidy?
5 A. Not always.
6 Q. What would you tell us about that?
7 MR. SNEDDON: I’m going to object, unless
8 there’s some foundation as to personal knowledge as
9 to this.
10 THE COURT: Sustained.
11 Q. BY MR. SANGER: To your knowledge, did you
12 see whether or not they were neat and tidy?
13 MR. SNEDDON: Same objection.
14 THE COURT: Sustained. “To your knowledge”
15 still encompasses beyond her personal knowledge.
16 MR. SANGER: “Did you see” is what I asked.
17 Okay. Let me withdraw the first part.
18 Q. Did you see any behavior with regard to
19 whether or not they were neat and tidy?
20 A. Yes.
21 Q. Okay. What did you see?
22 A. I saw them wearing the same clothes for a
23 few days.
24 Q. How about taking care of policing their area
25 or picking up after themselves? Did they do that?
26 A. Well, they littered quite a bit. So -- the
27 personal area I didn’t have access to.
28 Q. All right. Now, from February to March of 9540
1 2003, did you see Janet Arvizo from time to time?
2 A. No.
3 Q. Did you ever see her?
4 A. Rarely.
5 Q. Okay. So let’s talk about the rare times
6 when you saw her, okay? Can you describe her
7 demeanor during the rare times you saw her from
8 February through March?
9 A. I would say she was from either excited or
10 not excited. She was never just -- I don’t want to
11 say “normal,” but she was either very happy or she
12 wasn’t speaking.
13 Q. All right. Was that unusual to you?
14 A. I don’t know. I didn’t know Mrs. Arvizo, so
15 I don’t know what her demeanor -- her regular
16 demeanor was.
17 Q. I guess what I’m saying, are you describing
18 somebody that we’d all -- never mind. Let’s put it
19 this way: Are you describing what you might call
20 normal behavior or did this seem to be more extreme?
21 MR. SNEDDON: Your Honor, I’m going to
22 object as lack of foundation.
23 THE COURT: Sustained.
24 Q. BY MR. SANGER: All right. So she’d either
25 be happy or she would be very quiet?
26 A. Very quiet.
27 MR. SNEDDON: I’m going to object. Asked
28 and answered. 9541
1 MR. SANGER: It’s leading into the next
2 question.
3 MR. SNEDDON: Well, that doesn’t make it --
4 THE COURT: The answer was, “Very quiet.”
5 Next question.
6 Q. BY MR. SANGER: Where would she go when she
7 was on the ranch during that period of time,
8 February and March?
9 MR. SNEDDON: Object; lack of foundation.
10 THE COURT: Sustained.
11 Q. BY MR. SANGER: Did you see where she went?
12 A. I saw that she -- I know she was assigned a
13 guest unit.
14 Q. And did you see her at -- now, you would not
15 be in the house; is that right?
16 A. No.
17 Q. Did you see her around other parts of the
18 property from time to time?
19 A. Very rarely.
20 Q. Who was taking care of the boys, Gavin and
21 Star?
22 MR. SNEDDON: Object. Calls for a
23 conclusion; lack of foundation.
24 MR. SANGER: Okay. Let me withdraw it, just
25 to make this clear.
26 Q. I’m going to ask you about what you observed
27 yourself, okay? So the first question is, based on
28 your observations, who was taking care of the boys? 9542
1 MR. SNEDDON: I still object. There’s been
2 no foundation that she ever saw anything, and it
3 calls for a conclusion.
4 THE COURT: Sustained.
5 Q. BY MR. SANGER: Did you see the boys, Star
6 and Gavin, during this period of time, February to
7 March of 2003?
8 A. Yes.
9 Q. Did you see Davellin?
10 A. Yes.
11 Q. Did you have an opportunity to determine who
12 was taking care of the boys?
13 A. I would say Davellin was taking care of
14 them.
15 Q. Did you see Janet Arvizo interact with her
16 boys at all during that period of time?
17 A. No.
18 Q. What would Davellin do to take care of the
19 boys?
20 A. If they needed correcting or if they were
21 being -- if they were saying something that was
22 inappropriate, she would ask them to stop talking
23 about that, or she’d remind them to go take a
24 shower, or something like that.
25 Q. And what was Davellin doing on the ranch
26 during this period of time?
27 A. She was doing what the boys were doing.
28 Watching movies. Driving around in golf carts. 9543
1 Q. Did she seem to be having a good time?
2 A. Yes.
3 Q. Did any of the Arvizo kids spend time, to
4 your knowledge, to your observation, with the
5 security staff?
6 A. Yes.
7 Q. What did they do?
8 A. They would come and visit us from time to
9 time in the office and sit in our -- sit in our
10 office.
11 Q. And would they talk to you?
12 A. Yes.
13 Q. What would they talk about?
14 A. Oh, just regular things. You know, what we
15 were doing, and, you know, what was going on, that
16 type of thing.
17 Q. Did they ever complain to you about
18 anything?
19 A. No.
20 Q. Now, you said you saw Janet Arvizo from time
21 to time. Did she ever complain to you about
22 anything?
23 A. No.
24 Q. During the February to March 2003 period,
25 did the Arvizos leave the ranch from time to time?
26 A. Yes.
27 Q. Who took them off the ranch?
28 A. I would say it was limited to either Vinnie 9544
1 Amen or Chris Carter. Occasionally Mr. Marcus, Joe
2 Marcus, would take them off property.
3 Q. Okay. And what were the purposes of going
4 off the property?
5 A. I’m not sure. I didn’t inquire. Once they
6 were there at the gate and they were ready to leave,
7 we would just open the gate and let them leave.
8 Q. Were there times they went off the property,
9 for instance, during the day, and they came back
10 three or four hours later?
11 A. Yes.
12 Q. And when they went through the gate, did
13 they check in and out just like any other guests?
14 A. Most of the time. I mean, sometimes if we
15 have a guest that’s, you know, coming on and off the
16 property, we wave them through, make sure we get a
17 head count to see who’s leaving so we can account
18 for them later.
19 Q. So when people would go off for a trip to
20 town, for instance, you would not necessarily always
21 write that down; is that correct?
22 A. No, we would write it down. I mean, someone
23 will slip through. You don’t always see someone.
24 Maybe they’re sitting down in the seat. And we try
25 not to hold anyone up at the gate if they’re
26 leaving.
27 Q. All right. Did you -- do you know Ronald
28 Konitzer and Dieter Weizner? 9545
1 A. Yes.
2 Q. And were they at the ranch in February and
3 March of 2003?
4 A. Yes.
5 Q. Were they there every single day?
6 A. No.
7 Q. Was Ronald Konitzer there with anybody?
8 A. He was there with his wife and his son.
9 Q. And did you have an opportunity to observe
10 Mr. Konitzer and his wife and his son?
11 A. Yes.
12 Q. Can you describe their demeanor?
13 MR. SNEDDON: Object as irrelevant, Your
14 Honor.
15 THE COURT: Overruled.
16 THE WITNESS: They seemed to interact like a
17 regular family.
18 Q. BY MR. SANGER: Were they impolite, or
19 polite, or --
20 A. No, they were very polite.
21 Q. Did you see -- when you saw Dieter Weizner
22 there, what did you see him doing?
23 A. He was there on the property. Exactly what
24 his function was, I don’t know.
25 Q. All right. Did you see either Ronald
26 Konitzer or Dieter Weizner ever treat any of the
27 Arvizos in an unusual or inappropriate fashion?
28 A. No. 9546
1 MR. SNEDDON: Object; lack of foundation.
2 THE COURT: Sustained.
3 Q. BY MR. SANGER: Did you ever see any of the
4 Arvizos in the presence of Mr. Konitzer and Mr.
5 Weizner?
6 A. I can’t recall a specific time, but they
7 were there on the property at the same time.
8 Q. They were there together with --
9 MR. SNEDDON: Move to strike as
10 nonresponsive.
11 THE COURT: I’ll strike the last phrase,
12 they were on the property.
13 Q. BY MR. SANGER: Okay. Well, during February
14 and March 2003, were Konitzer and Weizner on the
15 property at the same time as the Arvizos?
16 A. Yes.
17 Q. Did you see any interaction between them?
18 A. No.
19 Q. By the way, who is Miko Brando?
20 A. Miko Brando is the son of Marlon Brando.
21 Q. And was he a guest or an employee, to your
22 knowledge?
23 A. He’s been both. But on this occasion,
24 again, I don’t know what he was doing. I know that
25 he was there off and on.
26 Q. Did you ever see Janet Arvizo leave the
27 premises with Katie Bernard?
28 A. Yes. 9547
1 Q. Who is Katie Bernard?
2 A. Katie Bernard was the secretary at the time.
3 Q. All right. So she’s an employee of the
4 ranch, correct?
5 A. Yes.
6 Q. And what kind of a vehicle did they leave
7 in; do you know?
8 A. I don’t recall right at this moment. It
9 probably was a ranch vehicle.
10 Q. All right. And do you recall roughly when
11 this occurred?
12 A. It was during the time they were there. I
13 believe during the initial part of their visit.
14 Q. Okay. Initial part of February? I couldn’t
15 hear you.
16 A. The initial part of their visit, yes.
17 Q. Would that be the first part of February?
18 A. Yes.
19 Q. And do you recall Katie Bernard -- let me
20 withdraw that.
21 Do you recall the purpose of Janet Arvizo
22 leaving with Katie Bernard?
23 A. I believe she had a salon visit.
24 Q. Okay. Was there any film crew following
25 them as they left the ranch?
26 A. No. I -- actually, I don’t know.
27 Q. Okay.
28 A. Not that -- I was not told that. 9548
1 Q. All right. You didn’t see any film crew
2 there to follow them when they left the ranch?
3 A. No.
4 Q. All right. Was there anything that would
5 have prevented any guest at the ranch, including
6 Janet Arvizo, from calling 9-1-1 if they had some
7 sort of emergency?
8 A. No.
9 Q. And how do you call 9-1-1 from the ranch?
10 A. From the guest units, you immediately
11 receive an outside line, so you could pick up the
12 phone and dial 9-1-1.
13 Q. So the guest units, you don’t even have to
14 use the code?
15 A. No. I haven’t done it for a long time, but
16 from what I believe, you can just pick up the phone
17 and you get an outside line.
18 Q. On some of the other phones, you have to
19 dial a code to get an outside line?
20 A. Correct.
21 Q. And that would be true for any kind of a
22 call; is that correct?
23 A. Correct. We have a -- an emergency
24 procedure, something that would be similar in a
25 hotel room, that shows you how to get out if there’s
26 an emergency. It’s near the phone. It gives you
27 directions on what to do in the event of an
28 emergency. It would be either to call extension -- 9549
1 the extension at the gate and report whatever the
2 problem was.
3 Again, I’m not very clear if you can just
4 pick up the phone. I’m almost certain you can; that
5 you can pick up the phone and dial out and get an
6 outside line.
7 Q. So let’s put it this way: The phones in the
8 guest units may or may not require a code to get an
9 outside line?
10 A. Correct.
11 Q. But if you can make a phone call from the
12 guest units one way or the other to Los Angeles, for
13 instance, you can call 9-1-1, correct?
14 A. Yes.
15 MR. SNEDDON: Your Honor, I’m going to
16 object to the form of the question in the sense that
17 she says she doesn’t know whether there’s a code to
18 get out or not.
19 THE COURT: Sustained.
20 Q. BY MR. SANGER: All right. If there’s no
21 code, you would just dial 9-1-1, and you get
22 emergency dispatch, right?
23 A. Yes.
24 MR. SNEDDON: Object. Calls for
25 speculation. She doesn’t know.
26 THE COURT: Overruled.
27 Q. BY MR. SANGER: And if the phones in the
28 guest room had the same code as other phones on the 9550
1 ranch, you would dial the outside code and then
2 9-1-1; is that right?
3 A. Yes.
4 Q. All right. And my question is, whichever
5 way it worked, if you could make calls to Los
6 Angeles, for instance, from the phone in the guest
7 ranch, you would also be able to call 9-1-1,
8 correct?
9 A. Yes.
10 Q. So if somebody knows the code to call an
11 ordinary number, that’s the same code you’d use to
12 get an outside line if you needed it, right?
13 A. Yes.
14 Q. Was there an occasion when Janet Arvizo was
15 supposed to leave the ranch and did not want to go
16 or did not show up?
17 A. I recall a time that the kids left before
18 her, and she left maybe an hour, hour and a half
19 after them. I don’t recall the date, but I
20 remember, leaving, it seemed a little inefficient to
21 me, since they were all leaving, that she wasn’t
22 ready or -- I don’t know the reason for her delay,
23 but she didn’t leave the same time they did.
24 Q. What kind of vehicle was there waiting for
25 her?
26 A. I don’t recall the vehicle exactly.
27 Q. All right. Some sort of vehicle that was
28 being chauffeured by someone? 9551
1 A. It could have been a ranch vehicle.
2 Q. But it was being driven by somebody?
3 A. Yes.
4 Q. Okay. So somebody had the vehicle there and
5 the kids were ready, but Janet wasn’t?
6 A. Right.
7 Q. All right. Let me ask you about the kids,
8 that is, the Arvizo children, being allowed to leave
9 the ranch. Were they allowed to leave the ranch
10 anytime they wanted to?
11 A. They were allowed to leave the ranch, but
12 they were supervised.
13 Q. All right. Was there a concern about them
14 not being supervised?
15 A. Well, their mother wasn’t there on some
16 occasions, so I would say yes.
17 Q. All right. And when their mother wasn’t
18 there, were they allowed to leave the ranch if they
19 didn’t have an adult with them?
20 A. Yes.
21 Q. Okay. Let me ask that again. Maybe you
22 meant to say that. But if they didn’t have an
23 adult --
24 A. If they didn’t have an adult, they were not
25 allowed to leave.
26 Q. If there was not an adult?
27 A. They needed to be supervised.
28 Q. Do you recall if that was communicated to 9552
1 the security staff at any time?
2 A. Yes.
3 Q. And how was it communicated?
4 A. It was directed to me verbally, and it was
5 also a written directive.
6 Q. And who told you that?
7 A. I came in on my shift, and I believe one of
8 my supervisors advised me of the directive and
9 that’s how I was notified.
10 Q. Did the -- did the children -- you talked to
11 the children from time to time, right?
12 A. Yes.
13 Q. Did they ever say they wanted to leave --
14 MR. SNEDDON: Object. Calls for hearsay.
15 THE COURT: Overruled.
16 MR. SANGER: I actually didn’t finish the
17 question, but let’s just leave it at that.
18 Q. Did they ever -- did the Arvizo children
19 ever say in your presence that they wanted to leave
20 the ranch?
21 A. No.
22 Q. To your knowledge, were they ever prevented
23 from leaving the ranch when they requested it?
24 A. No.
25 MR. SANGER: Now, Your Honor, what I’d like
26 to do is put up Exhibit 334. And this is the one
27 that has multiple pages, so I’m going to refer to
28 MJ00154 as the particular page from Exhibit 334. 9553
1 May I publish that?
2 THE COURT: Yes.
3 MR. SANGER: Thank you.
4 Q. All right. That’s not focusing really well.
5 Can you read it?
6 A. It --
7 Q. I’m going to --
8 A. The 19th of February?
9 Q. Yes. February 19. And I’m going to refer
10 to this line right here. Can you read that line?
11 If you can’t, I’ll bring it up to you so you can
12 read it.
13 A. Yes, I can read it.
14 Q. What does that line say, first of all?
15 A. “The kids are not allowed to leave per Joe.
16 ‘Kids’ meaning like Gavin, Star, et cetera.”
17 Q. Who wrote that there; do you know?
18 A. I believe that was Officer Elenes.
19 Q. So there was -- that was an officer who was
20 doing that at whose direction; do you know?
21 A. Per Joe Marcus.
22 Q. And there’s a number, “1752.” So that would
23 be 5:52 in the afternoon?
24 A. Yes.
25 Q. Do you know if the kids, in fact, left the
26 ranch that same night?
27 A. I’m not sure what time they left.
28 Q. All right. If you look at the gate logs, 9554
1 you could figure that out. We won’t have you do it.
2 They’ve already been introduced.
3 A. Yes.
4 Q. So you could tell from the gate logs
5 presumably when they left?
6 A. Yes. I’m sorry.
7 MR. SANGER: All right. All right. We can
8 turn the lights back on.
9 Is that your Post-it?
10 MR. AUCHINCLOSS: Yes.
11 MR. SANGER: That’s yours?
12 Q. And the contacts that you had with Janet
13 Arvizo, did she ever indicate to you that she wanted
14 to leave?
15 A. No.
16 Q. And if she indicated she wanted to leave,
17 would she have been allowed to leave?
18 A. Yes.
19 Q. Were you aware as to whether or not
20 transportation was arranged for -- you mentioned one
21 time. Other than that one time, was transportation
22 arranged for her to leave the ranch from time to
23 time?
24 A. Yes.
25 MR. SANGER: All right. May I have just one
26 moment, Your Honor?
27 THE COURT: Yes.
28 Q. BY MR. SANGER: Okay. While the Arvizos 9555
1 were there at the ranch from February to March 2003,
2 did you see them have contact with other guests?
3 A. Yes.
4 Q. And in particular, Davellin. Did Davellin
5 have contact with other guests?
6 A. Yes.
7 Q. Who do you recall, if anyone in particular?
8 A. Marie Nicole. Whatever -- whatever other
9 guests were there as well. We had quite a few
10 guests during that time period. I can’t recall
11 exactly who was there, but whoever was there, she
12 was involved with them.
13 Q. Did she spend a lot of time with Marie
14 Nicole?
15 A. I believe so. They were two girls, and so
16 they did spend some time together.
17 Q. And did Davellin also spend time with one of
18 the firefighters, firemen, or whatever you call them
19 there? I’m sorry.
20 MR. SNEDDON: Object; lack of foundation.
21 Q. BY MR. SANGER: To your knowledge.
22 THE COURT: Just a moment.
23 MR. SANGER: Let me withdraw it. I’ll say
24 some other words and make it better.
25 THE COURT: Okay.
26 Q. BY MR. SANGER: You said you saw the kids
27 spending time in the security office from time to
28 time? 9556
1 A. Yes.
2 Q. Was there anybody in particular, either
3 security or fire person, who Davellin -- who you saw
4 Davellin spend time with?
5 A. During that time period, or --
6 Q. February to March of 2003.
7 A. Not anyone particular. I mean, she was
8 there, but I can’t remember anyone specifically.
9 Q. All right. So she spent time with more than
10 one person?
11 A. Well, we’re a staff, and we’re active just
12 as well. So I’m sure in passing, you know, there
13 was a greeting. “Hello, how are you?” that type of
14 thing, or she would come in and ask for something,
15 so --
16 Q. All right. Now, what about the boys? Who
17 would they spend time with, Star and Gavin?
18 A. They would mostly spend time with each other
19 or alone, you know, so -- I believe Mr. Brando’s son
20 was there during that time period. So one of the
21 Cascio -- the younger Cascio boys was there as well.
22 Q. Did they spend time with the Cascio boys, or
23 one of the boys?
24 A. Yes.
25 Q. Did they spend time with one of the Brando
26 kids? This must be a grandchild.
27 A. Yes.
28 Q. A grandchild of Marlon Brando? 9557
1 A. Shane.
2 Q. Shane. Did they spend time together?
3 A. Yes.
4 MR. SANGER: Okay. Very good. I have no
5 further questions.
6 THE COURT: Cross-examine?
7
8 CROSS-EXAMINATION
9 BY MR. SNEDDON:
10 Q. Good morning.
11 A. Good morning.
12 Q. During the time that you were at the ranch,
13 you had a progression of responsibilities that got
14 larger and larger, correct?
15 A. Yes.
16 Q. So you worked there continuously from ‘91?
17 A. Yes.
18 Q. Until current? You’re a current employee?
19 A. Yes.
20 Q. And you worked your way up to head of
21 security at one point in time, correct?
22 A. Yes.
23 Q. And now you’re -- you’ve been -- I don’t
24 want to use the wrong term, but you are no longer
25 head of security?
26 A. No.
27 Q. And there’s somebody else who’s head of
28 security out there, correct? 9558
1 A. Yes.
2 Q. Now, during this period of time, you met a
3 lot of families that visited the ranch, I would
4 assume, correct?
5 A. Yes.
6 Q. And you’ve mentioned the Robeson family, the
7 Robson family --
8 A. Yes.
9 Q. -- as one of the families.
10 The Culkin family?
11 A. Yes.
12 Q. The Barnes family?
13 A. Yes.
14 Q. And the Chandler family?
15 A. Yes.
16 Q. The Cascio family?
17 A. Yes.
18 Q. Okay. And the Arvizo family are just a few
19 of the ones that visited the ranch, correct?
20 A. Yes.
21 Q. With respect to the Robeson -- or Robson
22 family, I’m sorry, after the first visit of that
23 family to the ranch, the father was never there
24 anymore, was he?
25 A. I never met the father.
26 Q. And with regard to the Barnes family, after
27 the Barnes family visited for the very first time,
28 the father was never there at the ranch when they 9559
1 visited, were they -- was he?
2 A. The father returned and made visits.
3 Q. How many occasions do you recall Mr. Barnes
4 being on the property?
5 A. From one visit to another? Do you mean
6 separate incidents --
7 Q. Yes, ma’am.
8 A. -- or days?
9 I would say at least two or three times
10 afterwards.
11 Q. Now, there were times that Brett Barnes, the
12 young child, that he was at the ranch alone,
13 correct, without any of his parents?
14 A. There could have been a time, yes.
15 Q. There could have been more than one time,
16 couldn’t there?
17 MR. SANGER: Objection; calls for
18 speculation.
19 THE COURT: Sustained.
20 Q. BY MR. SNEDDON: Do you recall there was
21 more than one occasion when Brett Barnes was on the
22 ranch without any parents being present?
23 A. Yes.
24 Q. In fact, he would stay several days at a
25 time on the ranch, correct?
26 A. I wouldn’t -- I don’t remember the exact
27 number of days, but I do remember him being there.
28 Q. And when he stayed at the ranch, he stayed 9560
1 in Mr. Jackson’s bedroom, correct, when his mother
2 was not at the ranch?
3 A. I don’t know exactly where he stayed. But
4 he would stay in the main house.
5 Q. So to your knowledge, he was in the main
6 house, but you don’t know where in the main house?
7 A. Correct.
8 Q. And when Mr. Robson -- not “Mr.,” the child
9 Robson visited the ranch, he was there on occasion
10 without his mother or his father, correct?
11 A. I don’t remember exactly that, but there
12 could have been.
13 Q. When he did, he stayed in the main residence
14 also, correct?
15 A. Yes.
16 MR. SANGER: I’m going to object to the
17 question of “When he did” as assuming facts not in
18 evidence.
19 MR. SNEDDON: Well --
20 MR. SANGER: Or vague.
21 THE COURT: Overruled. The answer was,
22 “Yes.”
23 Q. BY MR. SNEDDON: And you say, with regard to
24 both Brett Barnes and to Wade Robson, that you just
25 know they’re in the house, because the staff was not
26 allowed into the house, correct, the security staff,
27 except if there was an emergency or at Mr. Jackson’s
28 request? 9561
1 A. Yes.
2 Q. And you recall the Chandler family, correct?
3 A. Yes.
4 Q. Did you ever recall meeting Mr. Chandler?
5 A. No.
6 Q. Or a Mr. Chandler at all?
7 A. No.
8 Q. Or a husband at all?
9 A. No.
10 Q. And the child’s name was Jordan Chandler,
11 correct?
12 A. Yes.
13 Q. You know who I’m talking about when I talk
14 about Jordan Chandler?
15 A. Yes.
16 Q. And Jordan Chandler visited the ranch on a
17 number of occasions without his mother, correct?
18 A. Again, my recollection is he may have. I’m
19 not sure.
20 Q. And when he did, he stayed in the main
21 house?
22 A. Yes.
23 Q. And again, you don’t know where he stayed in
24 the main house?
25 A. No.
26 Q. And Macaulay Culkin visited the ranch
27 without his parents, correct?
28 A. I remember him mostly being with his 9562
1 parents, unless he was an adult. He’s been there
2 recently without his parents.
3 Q. Well, I don’t mean -- you’re right. I
4 should go back.
5 Between the period of 1991 and 1993,
6 Macaulay Culkin visited the ranch without his
7 parents being present, is that correct, on occasion?
8 A. My recollection is that he was there with
9 his parents.
10 Q. Is it your recollection also that he stayed
11 in the house?
12 A. Yes.
13 Q. Now, you mentioned one of the families that
14 you saw a good deal of is the Cascio family,
15 correct?
16 A. Yes.
17 Q. And one of the people who you observed over
18 the years was Frank Cascio, correct?
19 A. Yes.
20 Q. And you know him as Cascio, right?
21 A. Yes.
22 Q. And when you first met Mr. Cascio, he was
23 just a young boy, wasn’t he?
24 A. Yes.
25 Q. In other words, he was about 11 or 12 years
26 old?
27 A. I’m not sure of his age.
28 Q. Would he -- would he be about the same age 9563
1 as the other boys who were visiting around that
2 time, Brett Barnes, Wade, Jordan?
3 A. Most likely, yes.
4 Q. And he also would spend time with Mr.
5 Jackson in Mr. Jackson’s house, correct?
6 A. Yes.
7 Q. And the difference is that in this case
8 Frank Cascio used to visit with Mr. Jackson a lot,
9 correct, kept an ongoing relationship with Mr.
10 Jackson?
11 A. The family kept an ongoing relationship.
12 Q. Okay. That’s fair enough. So it was the
13 whole family, as well as Frank Cascio, that kept a
14 relationship with the defendant?
15 A. Yes.
16 Q. And you would describe, would you not, that
17 this family is very close to Mr. Jackson?
18 A. Yes.
19 Q. Based on your observations?
20 A. Yes.
21 Q. And you would -- I believe you said that in
22 the year 2000, you knew that Mr. -- Frank Cascio
23 went to work for Mr. Jackson, correct?
24 A. I have not said that here.
25 Q. No. I’m asking. You said that to an
26 investigator, correct?
27 A. Yes, possibly.
28 MR. SANGER: Objection; calls for hearsay. 9564
Subject: May 9, 2005 
Tue Mar 13, 2012 3:51 am
