5395
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 FRIDAY, APRIL 8, 2005
20
21 8:30 A.M.
22
23 (PAGES 5395 THROUGH 5446)
24
25
26
27 REPORTED MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304
28 BY: Official Court Reporter 5395
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 -and-
19 OXMAN and JAROSCAK BY: R. BRIAN OXMAN, ESQ.
20 14126 East Rosecrans Boulevard Santa Fe Springs, California 90670
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22
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27
28 5396
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. Nicola is listed as “N” on index. Mr. Mesereau is listed as “M” on index.
6 Ms. Yu is listed as “Y” on index. Mr. Sanger is listed as “SA” on index.
7 Mr. Oxman is listed as “O” on index.
8
9 PLAINTIFF’S
10 WITNESSES DIRECT CROSS REDIRECT RECROSS
11 McMANUS, 5398-M 5434-Z 5441-M
12 Adrian Marie (Cont’d)
13 5447-Z (Further)
14 LeMARQUE, Phillip 5443-A
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16
17
18
19
20
21
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28 5397
1 Santa Maria, California
2 Friday, April 8, 2005
3 8:30 a.m.
4
5 THE COURT: Good morning.
6 THE JURY: (In unison) Good morning.
7 THE COURT: You may proceed, Counsel.
8 MR. MESEREAU: Thank you, Your Honor.
9
10 ADRIAN MARIE McMANUS
11 Having been previously sworn, resumed the
12 stand and testified further as follows:
13
14 CROSS-EXAMINATION (Continued)
15 BY MR. MESEREAU:
16 Q. Ms. McManus, your -- excuse me.
17 Ms. McManus, your deposition in the Chandler
18 lawsuit was on December 7th, 1993, right?
19 A. Correct.
20 Q. And the Complaint you filed against Michael
21 Jackson, along with Ralph Chacon, was December 2nd,
22 1994, a year later, approximately a year later,
23 right?
24 A. I believe so.
25 Q. Okay. Would it refresh your recollection
26 just to take a look at the Complaint?
27 A. Sure.
28 MR. MESEREAU: May I approach, Your Honor? 5398
1 THE COURT: Yes.
2 THE WITNESS: Okay. Yeah.
3 MR. MESEREAU: Thank you.
4 Q. Now, in that lawsuit, you were suing Mr.
5 Jackson for a number of different claims, and one of
6 the claims talked about you having appeared at a
7 deposition taken by Larry Feldman, and the claim
8 said that you were a potential material witness
9 against Jackson in both the civil suit and a
10 criminal investigation, right?
11 A. I believe so.
12 Q. And what that really meant was, by filing
13 that Complaint with that language, you were
14 essentially threatening Mr. Jackson that you would
15 change your testimony unless you were paid, right?
16 A. I’m not familiar with a lot of attorney
17 language, so I really don’t know how to answer that.
18 Q. How much money do you recall you were
19 seeking from Mr. Jackson in that lawsuit?
20 A. That’s another question I cannot answer.
21 That was dealing with my attorney.
22 Q. Well, you were in court when he argued to
23 the Santa Maria jury for millions of dollars, right?
24 A. I don’t even know if I was there at that
25 time. I could have been. I don’t remember.
26 Q. You certainly must have discussed with your
27 attorney during that six-month trial how much money
28 you were trying to get for yourself from Mr. 5399
1 Jackson, right?
2 A. Honestly, I don’t believe anybody knew how
3 much money anybody would be getting out of a trial.
4 Q. But how much did you want?
5 A. I really didn’t want anything. I just
6 wanted justice for what I had gone through.
7 Q. You didn’t want millions of dollars in that
8 lawsuit?
9 A. I wanted justice. I didn’t -- whatever -- I
10 wanted justice.
11 Q. But your idea of justice was millions of
12 bucks, right?
13 A. Well, that’s not what I call justice.
14 Q. You file a lawsuit, you go through
15 approximately eight days of depositions, all sorts
16 of paperwork, and you’re in trial for six months.
17 You wanted millions, right?
18 A. Honestly, a simple “Sorry for what we did to
19 you” would have been great for me.
20 Q. Did you ever write a letter to Mr. Jackson
21 saying, “Mr. Jackson, I don’t want to sue you. Just
22 tell me you’re sorry”?
23 A. No, I did not.
24 Q. Ever call Mr. Jackson and say, “Mr. Jackson,
25 I don’t really want to sue you. Just say you’re
26 sorry”?
27 A. I didn’t have a number to contact Mr.
28 Jackson. 5400
1 Q. Okay. When did you first go to the police
2 to tell them you had seen anything improper about
3 Mr. Jackson?
4 A. I can’t recall the date. I don’t remember.
5 Q. It was after your deposition in the Chandler
6 case, correct?
7 A. It might have been.
8 Q. Do you know approximately when you first
9 talked to anyone from the Santa Barbara Sheriff’s
10 Department about your claim that you’d seen Mr.
11 Jackson do anything improper?
12 A. You know, it might have been when I talked
13 to my attorney, Mr. Ring. It might have been
14 sometime then, that I can recall.
15 Q. And when you did that, you thought going to
16 the sheriffs would put pressure on Mr. Jackson to
17 pay money in your civil case, right?
18 A. No, I did not.
19 Q. Did you go to the sheriffs with your
20 attorney?
21 A. I don’t believe so.
22 Q. But certainly you went to an attorney before
23 anyone from law enforcement, right?
24 A. Actually, I recall going to law enforcement
25 to com -- to complain about the death threat that I
26 got from James Van Norman and strange circumstances
27 that were going on at Neverland Valley Ranch.
28 Q. But that was also to bolster your claim for 5401
1 millions of dollars, right?
2 A. That was before I even contacted an
3 attorney.
4 Q. But by doing that, you were setting the
5 stage for a lawsuit for millions of dollars against
6 Mr. Jackson, correct?
7 A. No, I was not.
8 Q. You went to tabloids, a lawyer, and the
9 sheriffs, all to get millions of bucks, right?
10 A. You’re wrong.
11 MR. ZONEN: Objection; compound.
12 THE COURT: The answer was, “You’re wrong.”
13 Overruled. Next question.
14 Q. BY MR. MESEREAU: Do you know Leslie Gomez?
15 A. No, I don’t.
16 Q. Do you know she was the manager of
17 McFrugal’s?
18 A. I think I know her as Beaver. That’s the
19 name I think I’m thinking of.
20 Q. You told her you had never seen Michael
21 Jackson act inappropriately with children, right?
22 A. I’ve never talked to her about Michael
23 Jackson.
24 Q. You told Leslie Gomez that, “The suit by
25 that kid,” meaning Mr. Chandler, “was a bunch of
26 bull,” right?
27 A. I’ve never told -- I’ve never talked to her
28 about anything to do with lawsuits or anything with 5402
1 Mr. Jackson.
2 Q. And do you know someone named Ludi Trujillo?
3 A. Yes, I do.
4 Q. Ludi Trujillo is your former boss at
5 Gottschalk’s, right?
6 A. No, she was not.
7 Q. Who is she?
8 A. She’s a girl that worked at Gottschalk’s.
9 Just a lady.
10 Q. She didn’t have any position above you?
11 A. No, she did not.
12 Q. Okay. You talked to her about the Chandler
13 lawsuit, didn’t you?
14 A. No, I did not.
15 Q. She asked you specifically if Mr. Jackson
16 ever molested children, and you told her, “Of course
17 Michael did not,” right?
18 A. No, I did not.
19 Q. You told her Michael Jackson was a great
20 boss, didn’t you?
21 A. No, I did not.
22 Q. Do you know someone named Jamie Vail?
23 A. No, I don’t.
24 Q. Didn’t Jamie Vail live across the street
25 from you?
26 A. Where was this? I don’t know the name.
27 Q. Okay. Do you remember telling someone named
28 Jamie Vail that you loved Michael Jackson, you love 5403
1 working at the ranch, and you never believed any of
2 the charges against him?
3 A. I don’t even know that person.
4 Q. Okay. Do you know who Gayle Goforth is?
5 A. Yes, I do.
6 Q. And who is Gayle Goforth?
7 A. She was a supervisor that worked at
8 Neverland Valley Ranch.
9 Q. Do you remember Gayle asked you if there was
10 anything to rumors about inappropriate conduct by
11 Mr. Jackson?
12 A. She never -- we never talked about that, no.
13 Q. In the autumn of 1993, you told her there
14 was no truth to those rumors about Mr. Jackson
15 acting inappropriately, right?
16 A. No, I did not.
17 Q. Now, you and Ralph Chacon and Kassim Abdool
18 started meeting secretly at Neverland to talk about
19 your lawsuit, didn’t you?
20 A. No, we did not.
21 Q. You and Ralph Chacon and Kassim Abdool began
22 to meet at Neverland to discuss the possibility of
23 selling stories to the media, right?
24 A. No, we did not.
25 Q. Did you ever discuss selling a story to the
26 media with Ralph Chacon?
27 A. No, I did not.
28 Q. When you were working at Neverland, did you 5404
1 ever learn that Ralph Chacon was thinking of selling
2 any story about Michael Jackson to the media?
3 A. No.
4 Q. When did you first hear anything about Ralph
5 Chacon’s willingness to go to the media with
6 information about Michael Jackson?
7 A. The only time that we all sold a story was
8 when we were already in our lawsuit with Mr.
9 Jackson, which was with Mr. Ring, our attorney.
10 Q. Now, at some point, you learned that Blanca
11 Francia had sold a story to Hard Copy, correct?
12 A. Yes.
13 Q. She sold her information before you sold
14 yours, right?
15 A. I don’t recall when Bianca -- Blanca sold
16 the story.
17 Q. Do you know someone named Charli Michaels?
18 A. Yes, I do.
19 Q. Who is Charli Michaels?
20 A. She was a security guard for Neverland
21 Valley Ranch.
22 Q. Did you ever hear information that Charli
23 Michaels was trying to sell a story about Michael
24 Jackson to the media?
25 A. No, I did not.
26 Q. To date, have you ever heard anything about
27 that?
28 A. No. 5405
1 Q. Ever have a discussion with Charli Michaels
2 about the possibility of making money from
3 information you’d learned at Neverland?
4 A. No. I only recall talking to Charli about
5 her having sexual harassment with people at the
6 ranch.
7 Q. Okay. So you and she never said anything
8 about the possibility of making a buck from the
9 media, correct?
10 A. No. No.
11 Q. Okay. Now, when you were at Neverland, you
12 learned that security guards at the Encino home of
13 the Jacksons on Havenhurst had sold stories for
14 approximately $100,000, right?
15 A. No, I never heard that.
16 Q. You knew they had sold stories about Michael
17 Jackson, didn’t you?
18 A. No.
19 MR. ZONEN: I’m going to object as asked and
20 answered.
21 THE COURT: Sustained.
22 Q. BY MR. MESEREAU: Do you know someone named
23 Francine Orosco?
24 A. Yes, I do.
25 Q. And who is Francine Orosco?
26 A. She was a maid for Neverland Valley Ranch.
27 Q. And at some point, she was a personal friend
28 of yours, was she not? 5406
1 A. We became friends, yes.
2 Q. Now, you knew that she became a witness
3 against your claims in the lawsuit, right?
4 A. Yes, I believe so.
5 Q. She said you were never sexually harassed by
6 anybody, right?
7 MR. ZONEN: I’ll object as hearsay.
8 THE COURT: Sustained.
9 Q. BY MR. MESEREAU: Didn’t you repeatedly tell
10 Francine Orosco that Michael Jackson was innocent of
11 any charge of molestation?
12 A. No, I did not.
13 Q. Do you remember telling Francine Orosco that
14 you were going to get big-time money in your lawsuit
15 against Michael Jackson?
16 A. No, I did not.
17 Q. And you tried to convince her to say that
18 she had seen acts of sexual harassment involving
19 you, right?
20 A. No, I did not.
21 Q. While you worked at Neverland, Francine
22 Orosco visited you at home, did she not?
23 A. Maybe one time.
24 Q. And you showed her a room in your house
25 filled with watches, posters, clocks, sunglasses,
26 T-shirts and other items you had taken from
27 Neverland, correct?
28 A. No. 5407
1 Q. You showed her laundry baskets filled with
2 Michael Jackson’s clothes that you had taken from
3 Neverland, right?
4 A. No, I did not.
5 Q. Do you remember one time at Neverland when a
6 box of black felt hats came for Mr. Jackson?
7 A. I can’t recall that.
8 Q. Do you remember that box of hats had Michael
9 Jackson’s name printed on the inside of the rim of
10 the hats?
11 A. I know he had hats, but I don’t recall the
12 hats being sent there.
13 Q. Do you remember taking a hat and saying you
14 were going to bring it home?
15 A. No.
16 Q. Now, you used to take food home from the
17 theater, did you not?
18 A. Food, like what are you talking about?
19 Dinners?
20 Q. Candy?
21 A. No.
22 Q. Never took bags of candy home?
23 A. There was a time when -- you say “take,”
24 you’re saying like -- you’re saying I’m just going
25 to take it, that is not correct.
26 There was a time when Gayle Goforth, a
27 supervisor, went down to the theater and took a lot
28 of the candy from there, because it was expired. 5408
1 She brought it back to the maids, the maids’ room,
2 and she let all the maids take candy that was
3 expired. She also gave it to security. That was
4 the only time.
5 Q. So you never stole any candy from Michael
6 Jackson?
7 A. No, I did not.
8 Q. Do you remember around Christmastime when
9 you worked at Neverland, Mr. Jackson used to
10 purchase toys for needy children?
11 A. I believe he did.
12 Q. And they tended to be fairly expensive toys,
13 did they not?
14 A. I really don’t know.
15 Q. You took some of those toys home, did you
16 not?
17 A. No, I did not. That was Janelle Wahl.
18 Q. Pardon me?
19 A. That was Janelle Wahl that would take that.
20 Q. You never took any Super Soaker guns home?
21 A. No, sir.
22 Q. Now, these are the kinds of things the jury
23 found that you had actually done, correct?
24 A. I don’t believe so.
25 Q. Well, they found that you had stolen from
26 Mr. Jackson, correct?
27 A. I believe it was what they thought I had
28 stolen was that sketch that I found in the trash. 5409
1 Q. And you’re saying you didn’t steal that
2 either, right?
3 A. I didn’t. I found it in the trash.
4 Q. That’s the sketch of Elvis?
5 A. Yes.
6 Q. You complained at Neverland that you should
7 be paid more, right?
8 A. I don’t believe I did.
9 Q. Never said that to anybody?
10 A. I don’t recall saying that.
11 Q. Okay. And you say you left voluntarily,
12 correct?
13 A. I left after the harassment and the death
14 threats, yes.
15 Q. And then you filed a claim for disability
16 with EDD, right?
17 A. No.
18 MR. ZONEN: Objection; asked and answered.
19 THE COURT: Sustained.
20 Q. BY MR. MESEREAU: Ralph Chacon stopped
21 working at Neverland the same day you stopped,
22 right?
23 A. I don’t believe so.
24 Q. Kassim Abdool stopped working there the same
25 day you stopped, didn’t he?
26 A. I don’t believe so.
27 Q. All -- excuse me.
28 Now, you sued someone named Bill Bray, 5410
1 correct?
2 A. Yes.
3 Q. And who is Bill Bray?
4 A. He was the -- how would you say it? Maybe
5 the top man for the Office of Special Services.
6 Q. You sued Betty Bailey, right?
7 A. Yes.
8 Q. And who was Betty Bailey?
9 A. She was maybe like his right hand.
10 Q. And you sued Mr. Jackson’s personal security
11 people, right?
12 A. Yes, I did.
13 Q. You sued Jimmy Van Norman, right?
14 A. Yes, I did.
15 Q. Marcus Johnson, right?
16 A. Yes. Yes.
17 Q. Tony Coleman?
18 A. Yes.
19 Q. And Jerome J.J. Johnson, right?
20 A. Yes.
21 Q. And at some point you approached Mr. Johnson
22 about testifying for you, right?
23 A. No, I did not.
24 Q. Someone on your behalf did, right?
25 A. All I know is that I believe that, from what
26 I understand, he jumped onto our side and decided to
27 tell the truth about what was going on.
28 Q. And when you say he “decided to tell the 5411
1 truth,” you dropped your suit against him, right?
2 A. I believe we did.
3 Q. And the jury didn’t believe him either,
4 right?
5 MR. ZONEN: Objection.
6 THE COURT: Sustained.
7 MR. ZONEN: He never testified. Assumes
8 facts not in evidence that he testified.
9 THE COURT: I sustained your objection.
10 Q. BY MR. MESEREAU: Do you remember when Mr.
11 Johnson got in trouble for sending an extortion
12 letter to Mr. Jackson asking for three million
13 dollars?
14 A. I did learn of that through the later part
15 of my deposition, which I knew nothing about.
16 Q. At the point where you learned about Mr.
17 Johnson’s $3 million extortion letter to Mr.
18 Jackson, were you working with him on your lawsuit?
19 A. No.
20 Q. You stole commemorative Pepsi cans from
21 Neverland, did you not?
22 A. No, I did not.
23 Q. You were accused of that, right?
24 A. No, I was not.
25 Q. Do you know someone name Peter Burt?
26 A. No, I do not.
27 Q. Never heard the name?
28 A. I’ve heard of the name, but I do not know 5412
1 him.
2 Q. Okay. You do know Sandie Domz, do you not?
3 A. Yes, I do.
4 Q. Who is Sandie Domz?
5 A. She was an office administrator, a secretary
6 for Neverland Valley Ranch.
7 Q. You and the other plaintiffs in that lawsuit
8 decided that she would go to the show Hard Copy to
9 try and sell a story, correct?
10 A. Not that I ever recall.
11 Q. Are you saying that didn’t happen, or you
12 just don’t remember?
13 A. That did not happen.
14 Q. So you never got together and said, “We’ll
15 split money that we could get from Hard Copy”?
16 A. No, I did not.
17 MR. SANGER: Inside Edition.
18 (Off-the-record discussion held at counsel
19 table.)
20 Q. BY MR. MESEREAU: How much in total did Mr.
21 Ring collect on your behalf from tabloids or media?
22 A. From what I recall from my deposition, which
23 there were stubs in my deposition, that showed, I’m
24 thinking, maybe 32,000.
25 Q. Okay. Did any of that go to you?
26 A. 1,000.
27 Q. Now, you spent days being interviewed by a
28 book author named Mr. Gutierrez, right? 5413
1 A. Days being interviewed?
2 Q. Yes.
3 A. No.
4 Q. Were you interviewed by a book author named
5 Mr. Gutierrez?
6 A. I never was interviewed, but I did meet with
7 him.
8 Q. And approximately when did you meet with
9 him?
10 A. You know, I cannot recall the date.
11 Q. Well, you certainly had a discussion with
12 him about the fact that he was writing a book,
13 didn’t you?
14 A. No, I did not.
15 Q. So when you met with him, you didn’t know he
16 was writing a book?
17 A. No, when I met with him, he was going to try
18 to help us in our lawsuit.
19 Q. Did you ever learn he was writing a book
20 about Mr. Jackson?
21 A. I never -- I don’t recall him saying that he
22 was writing a book. I don’t remember that.
23 Q. Did you give him information about Mr.
24 Jackson?
25 A. Um, later I did.
26 Q. When you first talked to the Santa Barbara
27 Sheriffs, you didn’t tell them about inappropriate
28 behavior you’d seen by Mr. Jackson, correct? 5414
1 A. Probably not.
2 Q. You waited to say that in your lawsuit,
3 correct?
4 A. I don’t recall.
5 Q. Going back to your deposition in the
6 Chandler suit - okay? --
7 A. Uh-huh.
8 Q. -- you were asked if you’d ever seen Wade
9 Robeson at the ranch without one of his parents, and
10 you said, “No,” right?
11 A. I don’t -- I have not gone over that, so I
12 do not recall what I’ve said or --
13 Q. Would it refresh your recollection to just
14 take a look at the page?
15 A. Yeah.
16 MR. MESEREAU: May I approach, Your Honor?
17 THE COURT: Yes.
18 THE WITNESS: Okay.
19 Q. BY MR. MESEREAU: Have you had a chance to
20 look at that page?
21 A. Yes.
22 Q. Does it refresh your recollection about what
23 you said under oath in that deposition?
24 A. Yes.
25 Q. And on that issue, what did you say?
26 A. “No.”
27 Q. You said you had never seen Wade Robeson at
28 the ranch without one of his parents, right? 5415
1 A. Correct.
2 Q. You were asked if you had ever seen Brett
3 Barnes’ clothes in Mr. Jackson’s bedroom, right?
4 A. If it’s there. Like I said, I have not gone
5 over that.
6 Q. And your response was sometimes his mother
7 would give you his clothes to wash, right?
8 A. Yeah, probably.
9 Q. Is that what you remember saying?
10 A. Like I said, I have not gone over that in
11 probably ten years.
12 Q. Would it refresh your recollection to just
13 take a look at that page?
14 A. Sure.
15 MR. MESEREAU: May I approach, Your Honor?
16 THE COURT: Yes.
17 Q. BY MR. MESEREAU: Have you had a chance to
18 look at that page?
19 A. Yes, I did.
20 Q. Does it refresh your recollection about what
21 you said?
22 A. Yes.
23 Q. And you said that his mother would give you
24 his clothes, correct?
25 A. Correct.
26 Q. You didn’t see his clothes in Mr. Jackson’s
27 bedroom, right?
28 A. Um -- 5416
1 Q. Excuse me, at that point in time, you said
2 you didn’t see his clothes in Mr. Jackson’s bedroom,
3 his mother would give you his clothes, correct?
4 A. Correct.
5 Q. You also said you’d never seen any of the
6 Culkin boys’ clothes in Mr. Jackson’s bedroom,
7 right?
8 A. If it’s there, that’s probably what I said
9 at that time.
10 Q. Let me just go back a little bit. You said
11 that you saw Macaulay Culkin and his brother at
12 Neverland, right?
13 A. I probably did.
14 Q. Would it refresh your recollection to look
15 at that page?
16 A. Sure.
17 MR. MESEREAU: Okay. May I approach?
18 THE COURT: Yes.
19 THE WITNESS: Okay. Okay.
20 Q. BY MR. MESEREAU: Have you had a chance to
21 look at that page?
22 A. Yes, I did.
23 Q. Does it refresh your recollection about what
24 you said on that topic?
25 A. Yes.
26 Q. You said that you had never seen the Culkin
27 boys’ clothes in Mr. Jackson’s bedroom, right?
28 A. Yes. 5417
1 Q. You also told Mr. Feldman that you had never
2 come to Mr. Jackson’s room in the morning and seen
3 anything that indicated somebody may have slept on
4 his floor, right?
5 A. I don’t recall. Sorry.
6 Q. Would it refresh your recollection to look
7 at that page?
8 A. Sure.
9 MR. MESEREAU: May I, Your Honor?
10 THE COURT: Yes.
11 THE WITNESS: Okay.
12 MR. MESEREAU: Thank you.
13 THE WITNESS: Uh-huh.
14 MR. MESEREAU: Have you had a chance to look
15 at that?
16 A. Yes.
17 Q. Does that refresh your recollection about
18 what you said?
19 A. Yes.
20 Q. And what did you say?
21 A. “No.”
22 Q. Do you remember testifying that Mr. Jackson
23 had never given you money?
24 A. I don’t recall that. I don’t --
25 Q. Did Mr. Jackson give you money from time to
26 time?
27 A. No. There was just one time.
28 Q. Okay. And that was when you told the jury 5418
1 that you got 300 bucks to lie in a deposition?
2 A. That --
3 MR. ZONEN: Objection; misstates the
4 testimony of the witness.
5 MR. MESEREAU: Let me rephrase that.
6 Q. Did you tell the jury that Mr. Jackson gave
7 you $300 to lie in a deposition?
8 MR. ZONEN: Objection; misstatement of
9 evidence.
10 THE COURT: Overruled.
11 You may answer.
12 THE WITNESS: What I said was the $300 was
13 given to me after Mr. Jackson had read the
14 transcripts of Jordie Chandler.
15 Q. BY MR. MESEREAU: Okay. And you interpreted
16 that as a token of his appreciation?
17 A. Yes, for covering up for him.
18 Q. Okay. 300 bucks?
19 A. Yes.
20 Q. Okay. Do you remember being asked if you’d
21 ever seen a woman in Mr. Jackson’s bedroom?
22 A. I can’t recall that.
23 Q. You said you had seen June Chandler in his
24 bedroom, right?
25 A. I believe to bring in Jordie’s clothes.
26 Q. Well, let me just go step by step. You
27 testified under oath in the deposition that you had
28 seen June Chandler in Mr. Jackson’s bedroom, right? 5419
1 A. To bring in his clothes, yes.
2 Q. You said you had never seen Mr. Jackson and
3 June Chandler in any romantic relationship, right?
4 A. Correct.
5 Q. You weren’t aware of her sleeping with Mr.
6 Jackson, right?
7 A. No.
8 Q. But you saw her in his room?
9 A. To bring in the clothes, yes.
10 Q. Well, you didn’t say “to bring in the
11 clothes” in the deposition, right?
12 A. I don’t know what’s in the deposition.
13 Q. Would it refresh your recollection to look
14 at that page?
15 A. Sure.
16 MR. ZONEN: I’ll object as irrelevant and
17 hearsay.
18 MR. MESEREAU: I think the prosecution
19 raised the issue of what was happening in that
20 bedroom.
21 THE COURT: I’ll allow you to refresh her
22 recollection.
23 MR. MESEREAU: May I approach, Your Honor?
24 THE COURT: Yes.
25 THE WITNESS: Okay.
26 Q. BY MR. MESEREAU: Have you had a chance to
27 look at that page of your deposition?
28 A. Yes, I did. 5420
1 Q. Does it refresh your recollection about what
2 you said about June Chandler being in Mr. Jackson’s
3 room?
4 A. Yes.
5 Q. You said you had seen June Chandler in his
6 room, right?
7 A. Yes.
8 Q. You didn’t explain it in terms of her coming
9 there for clothes, or with clothes, right?
10 A. I guess not, no.
11 Q. You testified that you had seen Jordie
12 Chandler and Michael Jackson together outside on a
13 Jet Ski in the water, right?
14 A. I probably did.
15 Q. Do you remember that?
16 A. Slightly.
17 Q. You indicated you had seen Mr. Jackson in
18 water balloon fights and squirt gun fights, right?
19 A. I believe so.
20 Q. And you saw that once in a while, didn’t
21 you, while you worked there?
22 A. Yes.
23 Q. He would do that with kids all the time,
24 wouldn’t he?
25 A. Yeah, sometimes.
26 Q. Was it your impression that Mr. Jackson
27 liked water balloon fights?
28 MR. ZONEN: I’ll object as speculative. 5421
1 THE COURT: Sustained.
2 Q. BY MR. MESEREAU: You said you had never
3 seen Mr. Jackson hold hands with anyone at the
4 ranch, right?
5 A. I don’t recall that.
6 Q. Could I refresh your recollection --
7 A. Sure.
8 Q. -- by showing you the page?
9 A. Sure.
10 MR. MESEREAU: May I, Your Honor?
11 THE COURT: Yes.
12 THE WITNESS: Okay.
13 Q. BY MR. MESEREAU: Have you had a chance to
14 look at that page?
15 A. Yes, I did.
16 Q. Does it refresh your recollection about what
17 you said?
18 A. Yes.
19 Q. You said you’d never seen Michael Jackson
20 hold hands with anybody at the ranch, right?
21 A. Correct.
22 Q. Okay. Now, there was approximately a
23 one-year period between this deposition and the
24 actual filing of your lawsuit against Mr. Jackson,
25 right?
26 A. Are you talking about Jordie Chandler?
27 Q. Well, approximately a one-year period
28 between your deposition in the Chandler case and the 5422
1 filing of your lawsuit, correct?
2 A. I believe so.
3 Q. Now, the Chandler deposition was in
4 December, and the next December you filed your
5 lawsuit, right?
6 A. I know the Chandler one was probably
7 December 7th of -- oh, gosh, I don’t know if it was
8 ‘93 or ‘94. I don’t -- I’m not -- I don’t know the
9 dates.
10 Q. Okay. We talked about a little earlier that
11 December 7th, 1993, is the deposition in the
12 Chandler case.
13 A. Okay.
14 Q. And your lawsuit is December 2nd, 1994?
15 A. Okay.
16 Q. Okay?
17 A. Yes.
18 Q. Now, how long after the Feldman deposition
19 in the Chandler case did you to go a lawyer to talk
20 about suing?
21 A. I don’t know how long after it was. I
22 just -- I know I left Neverland in the end of July
23 of ‘94. It might have been -- I don’t even want to
24 guess because I’m not real -- I’m not sure.
25 Q. You must have had a lot of meetings with Mr.
26 Ring before you actually finalized the lawsuit,
27 right?
28 A. I believe so. 5423
1 Q. And do you know roughly when that started?
2 A. You know, in my head, I don’t know why I
3 keep thinking 1995, but I don’t know.
4 Q. For how many months do you think you and
5 Ralph Chacon and Kassim Abdool met with Mr. Ring
6 before the action was filed?
7 A. I really can’t answer that, because I really
8 don’t know.
9 Q. Approximately when did you stop working at
10 Neverland?
11 A. The exact date -- my last day, I believe,
12 was July the 31st of ‘94.
13 Q. Do you recall participating in an Inside
14 Edition show?
15 A. I believe so.
16 Q. And when did you participate in a show about
17 Mr. Jackson for Inside Edition?
18 A. I believe that had to do when we contacted
19 Gary Morgan. That was all around the same time, so
20 our lawsuit had already been going on.
21 Q. Do you remember meeting with representatives
22 of Inside Edition?
23 A. I remember -- I remember those -- the people
24 from Inside Edition showing up at our attorney’s
25 office, so I guess, yeah.
26 Q. Did you meet with them with your lawyer?
27 A. Yes.
28 Q. And was Ralph Chacon in that meeting? 5424
1 A. You know what, I really can’t recall.
2 Q. Was Kassim Abdool in that meeting?
3 A. I don’t want to say yes, because I can’t
4 recall.
5 Q. But the subject was Mr. Jackson, right?
6 A. Yes, it was.
7 Q. Do you remember trying to sell information
8 about Mr. Jackson’s relationship with Ms. Presley?
9 A. There could have been something of that.
10 Possibly, yes.
11 Q. You say, “Possibly, yes”?
12 A. Yeah.
13 Q. Well, I mean, you were actually trying to
14 get money from tabloids in return for your giving
15 them personal information about Mr. Jackson’s
16 relationship with Miss Presley, right?
17 A. We were trying to get money to help with our
18 lawsuit to fight Mr. Jackson.
19 Q. Do you recall ever going to anyone in the
20 media and telling them you had inside information on
21 Mr. Jackson’s relationship with Miss Presley?
22 A. I don’t recall that.
23 Q. Okay. Do you recall ever giving information
24 to anyone in the media involving Miss Presley and
25 Mr. Jackson?
26 A. I believe we probably did with Gary Morgan.
27 Q. And he was your media broker, wasn’t he?
28 A. I believe so. 5425
1 Q. He was the one that you were using and Ralph
2 Chacon was using to find media outlets to sell
3 information to, right?
4 A. I believe so.
5 Q. Okay. And you met him through Attorney
6 Ring; is that correct?
7 A. Yes.
8 Q. Okay. Did you ever see any tabloids that
9 quoted you about Mr. Jackson?
10 A. I -- I could have.
11 Q. You’re not sure?
12 A. I’m not real, real sure.
13 Q. Did you ever see any tabloids that quoted
14 you about Mr. Jackson’s relationship with Miss
15 Presley?
16 A. I could have. It’s been a long time. I
17 kind of can’t remember.
18 Q. Do you remember Star magazine asking you to
19 sign a contract whereby you would give them
20 information about Mr. Jackson and his relationship
21 with his wife, Lisa Marie Presley?
22 A. I remember something to do with Gary Morgan
23 and something with Star, but I don’t remember
24 everything that was discussed with that.
25 Q. Might it refresh your recollection if I just
26 show you that document?
27 A. Sure.
28 MR. MESEREAU: May I, Your Honor? 5426
1 THE COURT: Yes.
2 THE WITNESS: Okay.
3 Q. BY MR. MESEREAU: Have you had a chance to
4 look at that document?
5 A. Yes.
6 Q. Does it appear to be a contract with Star
7 magazine?
8 A. Yes.
9 Q. And you signed that, correct?
10 A. Yes.
11 Q. Okay. And among other things, you agreed to
12 provide information about Mr. Jackson’s relationship
13 with Lisa Marie Presley, right?
14 A. I believe so.
15 Q. And Ralph Chacon signed that, did he not?
16 A. I believe so.
17 Q. Now, you’ve heard the name Splash, correct?
18 A. Correct.
19 Q. And who was Splash?
20 A. I really -- all I know about Splash is that
21 it was linked up with Gary Morgan, so I don’t know a
22 lot of this tabloid stuff. I don’t know.
23 Q. Well, Splash was an agency, was it not, that
24 was retained by you to find media sources, right?
25 A. If it was retained, it would have been with
26 Michael Ring, my attorney.
27 Q. Okay. You signed an agreement with Splash
28 News and Picture Agency, right? 5427
1 A. I believe so.
2 Q. And was your involvement with Splash always
3 through Mr. Ring?
4 A. Yes.
5 Q. Did you ever deal with Splash directly?
6 A. No, I did not.
7 Q. How long were you working with Splash?
8 A. I have no idea. I don’t know the dates.
9 Q. At some point -- at some point did your
10 relationship with Splash end?
11 A. I’m sure it did.
12 Q. Okay. Do you know approximately when?
13 A. No, I do not.
14 Q. Were you giving information to any tabloids
15 or media sources during your trial?
16 A. Only through Splash.
17 Q. And that went on during the trial, right?
18 A. Probably sometime during the trial, yes.
19 Q. Do you recall trying to sell what you called
20 “Mr. Jackson’s sex secrets”? Do you remember that?
21 A. I know something was written about that, but
22 I know sometimes tabloids write other stuff that
23 they like to put in, so I don’t know.
24 Q. You were quoted in an issue of Star magazine
25 titled “Five of His Closest Servants Tell All.
26 Kinky Sex Secrets of Michael and Lisa Marie’s
27 Bedroom,” right?
28 A. I don’t believe I said that. 5428
1 Q. Have you seen that article before?
2 A. I did during my deposition.
3 Q. Was that the first time you’d ever seen this
4 article?
5 A. Yes.
6 Q. You are quoted in the article, correct?
7 A. I don’t know. I could be. I don’t know.
8 Q. Would it refresh your recollection if I just
9 show you --
10 A. Sure, you can.
11 MR. MESEREAU: May I, Your Honor?
12 THE COURT: Yes.
13 THE WITNESS: Kind of hard to see that.
14 Okay.
15 Q. BY MR. MESEREAU: Have you had a chance to
16 look at that article?
17 A. Yes.
18 Q. Does it refresh your recollection about you
19 being quoted in that article?
20 A. Yes.
21 Q. You were going to tabloids and saying that
22 you were the only person with a key to Mr. Jackson’s
23 bedroom and you had information to sell, right?
24 A. Um, as I’ve said, I know we did interview --
25 the interview with Gary Morgan. But a lot of the
26 times with those tabloids, those tabloids write
27 other stuff and put it in there, and it makes it
28 look like I said it, when I didn’t say it. So I 5429
1 don’t know how to answer that.
2 Q. Well, did he have authorization from you to
3 quote you with various tabloids?
4 A. You know what, that’s where I don’t know.
5 He was dealing with Michael Ring, so I really don’t
6 know. I kind of got stuck in the middle.
7 Q. Well, at some point you must have known that
8 your quotes were appearing in tabloids regarding Mr.
9 Jackson, true?
10 MR. ZONEN: Assumes facts not in evidence
11 that there were quotes.
12 THE COURT: Sustained.
13 Q. BY MR. MESEREAU: During the time you were
14 represented by Attorney Ring, did you learn from
15 time to time that your name and various quotes about
16 Mr. Jackson were appearing in the media?
17 A. Just through the Gary Morgan deal. That’s
18 all I recall.
19 Q. What I’m trying to find out is this: Did
20 you sort of leave it to other people to sort of
21 quote you when they wanted in the media?
22 A. Actually, sometimes you have no control over
23 what people quote you in the media.
24 Q. But you’re not saying you had nothing to do
25 with these quotes, are you?
26 A. I can’t answer that, because I don’t know
27 what was quoted.
28 Q. Okay. You never learned? 5430
1 A. No. Huh-uh.
2 Q. During your trial with Mr. Jackson, were you
3 speaking to various newscasters?
4 A. Only Gary Morgan is all that I recall, and
5 when we met with Victor Gutierrez, and that was it.
6 Q. Would he arrange meetings for you?
7 A. Victor Gutierrez?
8 Q. No, Mr. Morgan.
9 A. I believe he might have, through Mr. Ring.
10 Q. Was it -- let me rephrase that.
11 Was it typical during your relationship with
12 Mr. Morgan that he would fax a story to you to have
13 you review it, and ask you to see if you wanted any
14 changes, and then you would fax it back?
15 A. What I recall is viewing one -- I don’t know
16 what you call it, I don’t know if it was a
17 transcript, and that’s the only thing I remember
18 seeing.
19 Q. Did the group used to meet with Mr. Morgan?
20 A. The only time we all met was with Mr. Ring
21 at his office.
22 Q. And you had a number of meetings with Mr.
23 Ring, Mr. Morgan, and the group that was suing
24 Michael Jackson, true?
25 A. Maybe two meetings that I can recall.
26 Q. And Ralph Chacon was at those meetings,
27 right?
28 A. He might have been at one. I don’t know if 5431
1 he was at all of them.
2 Q. When did you last talk to Ralph Chacon?
3 A. It’s been a while. I don’t know, maybe -- I
4 really can’t -- it’s been a while.
5 Q. When did you last talk to Kassim Abdool?
6 A. Actually, the last time I spoke with Kassim
7 was during our verdict, when we lost, and I have not
8 seen him since.
9 Q. How about Melanie Bagnall?
10 A. I see her off and on.
11 Q. Do you recall your being quoted in any
12 Australian newspapers about Mr. Jackson’s private
13 life?
14 A. No.
15 Q. Was it your understanding that Mr. Morgan
16 was going to try and use your quotes in foreign
17 newspapers about Mr. Jackson?
18 A. I have no idea.
19 Q. How many television shows do you think you
20 appeared on where you purported to give private
21 information about Michael Jackson?
22 A. The only thing that I can recall that I
23 appeared on was maybe with Inside -- I think it was
24 Inside Edition. There wasn’t an interview with me,
25 but I think they captured me walking, maybe, with --
26 I don’t know if it was Kassim.
27 Q. Do you recall meeting with any
28 representative of the media while you worked at 5432
1 Neverland?
2 A. No.
3 Q. And you’re telling the jury that you never
4 had any discussion with any employee while you
5 worked at Neverland about what you could make by
6 selling a story?
7 A. The only thing I recall when I worked at
8 Neverland was one of the maids, Francine Orosco, had
9 contacted the media. I don’t know if it was -- it
10 was one of the tabloids and they had offered her
11 $2,000, and she was going to come out and talk, but
12 they wanted her picture. And she was considering
13 doing that. That’s the only thing I ever remember
14 with that.
15 Q. Finally, when did you last talk to anyone
16 representing any media outlet about Mr. Jackson?
17 A. I have not interviewed with anybody about
18 Mr. Jackson.
19 Q. I don’t mean an interview. I mean when have
20 you last spoken with anyone who purported to
21 represent the media?
22 A. I haven’t really been talking to anybody
23 about anything in the -- with the media.
24 Q. Has anyone called you from the media?
25 A. I did get a call from somebody from London
26 at my job, and they wanted to interview, and I told
27 them no.
28 Q. When was that? 5433
1 A. Maybe about -- within the last week.
2 Q. And you didn’t interview because there is a
3 court order in this case that you’re not allowed to
4 do that if you’re a witness, right?
5 A. That’s correct.
6 Q. Did you agree with them that on a future
7 date you may speak to them?
8 A. I told them that I was not interested in
9 doing any interviews, that I was under a gag order.
10 MR. MESEREAU: No further questions at this
11 time.
12 THE COURT: Redirect?
13
14 REDIRECT EXAMINATION
15 BY MR. ZONEN:
16 Q. Mr. Mesereau asked you some questions about
17 an article that was in a tabloid that quotes you as
18 saying that you have all kinds of information about
19 kinky sex secrets between Michael Jackson and Lisa
20 Marie Presley. He showed you that article and asked
21 you if it refreshed your recollection as to whether
22 there was, in fact, such an article, and you said
23 yes, it refreshed your recollection as to that
24 article.
25 About the quotations in the article, are
26 they accurate?
27 A. No, they are not.
28 Q. Did you ever give information about kinky 5434
1 sex secrets between Michael Jackson and Lisa Marie
2 Presley to any publication, any media, or any
3 reporter?
4 A. No, never.
5 Q. Do you, in fact, have information of kinky
6 sex secrets between Michael Jackson and Lisa Marie
7 Presley?
8 A. No, I do not.
9 Q. Have you ever seen Michael Jackson with Lisa
10 Marie Presley?
11 A. How do you mean, “seen”?
12 Q. Was she at the ranch during the period of
13 time that you were there?
14 A. Yes, she was.
15 Q. Were they married during that time?
16 A. No.
17 Q. Were they visiting one another?
18 A. I believe so.
19 Q. Do you have any information at all that Lisa
20 Marie Presley ever stayed with Michael Jackson in
21 his room?
22 A. No.
23 Q. Did you ever see any woman stay with Michael
24 Jackson in his room in the four years you worked for
25 him?
26 A. No, I did not.
27 Q. You stated in the deposition that you had
28 never seen Michael Jackson hold hands with anyone. 5435
1 Is that a correct statement?
2 A. No.
3 Q. Have you seen him holding hands with people?
4 A. Yes.
5 Q. Who?
6 A. Brett Barnes. The children that were at the
7 ranch.
8 Q. You told Mr. Feldman during the deposition
9 that you had never come into Mr. Jackson’s room and
10 seen evidence that somebody had slept on the floor.
11 Was that, in fact, a correct statement?
12 A. That’s correct.
13 Q. In fact, during the time that you had worked
14 there, you had never seen any evidence that someone
15 had slept on the floor?
16 A. Correct.
17 Q. You told Mr. Mesereau about June Chandler
18 unpacking clothing in Mr. Jackson’s bedroom. Did
19 that, in fact, happen?
20 A. Yes, it did.
21 Q. Explain that to us, please.
22 A. June Chandler had gone into Mr. Jackson’s
23 room and brought in suitcases of Jordie Chandler’s
24 clothes, since he was staying with Mr. Jackson in
25 his bedroom.
26 Q. I guess that begs the question, Miss
27 Chandler obviously knew that her son was sleeping in
28 that room, correct? 5436
1 A. Yes.
2 MR. MESEREAU: Objection; calls for
3 speculation.
4 THE COURT: Argumentative; sustained.
5 Q. BY MR. ZONEN: Did she do this on more than
6 one occasion?
7 A. I believe so.
8 Q. Was there a dresser or a drawer set up for
9 Jordie’s clothing?
10 A. No. The clothes would just get put anywhere
11 in the room.
12 Q. Were there any -- was there any occasion
13 that you saw June Chandler in Michael Jackson’s room
14 when she was not attending to her child’s clothing?
15 A. Not that I can recall.
16 Q. You testified in the deposition that you had
17 not seen Wade Robeson on the property without a
18 parent. Was that a correct statement?
19 A. I’m sorry, you lost me.
20 Q. Had you ever seen Wade Robeson at Neverland
21 without a parent?
22 A. No.
23 Q. Who was the parent that was always there?
24 A. His mother.
25 Q. And you never met the father?
26 A. No.
27 Q. Your initial conversations with the
28 sheriff’s office, were they at a time that you were 5437
1 still employed at Neverland Ranch?
2 A. Yes.
3 Q. You testified in the deposition that Brett
4 Barnes’ mother would bring you his clothes to wash.
5 Was that, in fact, true?
6 A. At times that was true.
7 Q. Was that always the manner in which you
8 washed his clothes?
9 A. No.
10 Q. In what other ways would you be washing his
11 clothes?
12 A. If they were left in Mr. Jackson’s room, I
13 would take them and wash them along with Mr.
14 Jackson’s clothes.
15 Q. You have testified in the Chandler
16 deposition that you never saw Jordie and Michael
17 Jackson in his bedroom together. Was that a correct
18 statement?
19 A. No, it was not.
20 Q. Had you seen the two of them together in the
21 bedroom?
22 A. Yes.
23 Q. On more than one occasion?
24 A. Yes.
25 Q. Had you ever seen them in bed together?
26 A. Not in bed, no.
27 Q. You testified that you never saw Brett
28 Barnes sleep in the bedroom with Michael Jackson. 5438
1 You testified to that in the deposition, the
2 Chandler deposition. Was that a correct statement?
3 A. No, it was not.
4 Q. Had you, in fact, seen Brett Barnes sleep in
5 a bedroom with Michael Jackson?
6 A. He was staying with Mr. Jackson.
7 Q. Did you ever actually see either Michael
8 Jackson or Brett Barnes in bed in Michael Jackson’s
9 room?
10 A. One morning I might have seen them in bed,
11 yes.
12 Q. Do you have a recollection of that?
13 A. Yes.
14 Q. What did you see?
15 A. I brought breakfast and they were sitting in
16 the bed.
17 Q. Both of them together?
18 A. Yes.
19 Q. Do you recall how they were dressed?
20 A. I don’t recall.
21 Q. Were they in the bed, under the covers,
22 or --
23 A. Yes.
24 Q. They were in the bed under the covers?
25 A. Yes.
26 Q. You testified that you never saw Jordie
27 Chandler either get ready for bed or get up in the
28 morning. Were either of those statements true? 5439
1 A. Yes.
2 Q. Both of them?
3 A. Yes.
4 Q. You testified that you never saw a chimp in
5 his bedroom. Was that statement true?
6 A. No.
7 Q. In fact, you’d been bitten by a chimp in his
8 bedroom; is that true?
9 A. Yes.
10 Q. Did you used to clean up after the monkeys?
11 A. Yes.
12 Q. Did you ever have to change their diapers?
13 MR. MESEREAU: Objection; leading.
14 THE COURT: Overruled.
15 You may answer.
16 THE WITNESS: Yes, I did.
17 Q. BY MR. ZONEN: Did you ever have to clean up
18 monkey droppings on the floors?
19 A. Not on the floor. Just on the walls.
20 Q. On the walls?
21 A. Sometimes monkeys get wild.
22 Q. You actually have to clean up their --
23 A. Yes.
24 Q. -- mess on the walls?
25 A. Yes.
26 Q. You testified that you had never seen Jordie
27 and Michael Jackson in the Jacuzzi. Is that a
28 correct statement? 5440
1 A. Yes.
2 Q. You had testified yesterday that you had
3 testified in the Chandler lawsuit that you had no
4 problems leaving your son with Michael Jackson. Was
5 that true?
6 A. No.
7 Q. Were you, in fact, concerned about your son
8 and Michael Jackson?
9 A. Yes, I was.
10 Q. Did you ever see Michael Jackson with your
11 son behave in a way that concerned you?
12 A. Yes.
13 Q. What did he do?
14 A. Mr. Jackson would rub his fingers through my
15 son’s hair.
16 Q. Did that concern you at the time?
17 A. A little bit, yeah. I was a little upset.
18 MR. ZONEN: I have no further questions.
19 MR. MESEREAU: Very briefly.
20
21 RECROSS-EXAMINATION
22 BY MR. MESEREAU:
23 Q. You tried to sell a story to a tabloid about
24 Mr. Jackson putting his fingers through your son’s
25 hair, didn’t you?
26 A. No, I did not.
27 Q. You tried to sell stories to tabloids about
28 your son’s experiences at Neverland, correct? 5441
1 A. No, I did not.
2 Q. Do you recall Mr. Jackson living at Lisa
3 Marie Presley’s home during the week, and Lisa Marie
4 Presley visiting on weekends during the time that
5 you worked at Neverland?
6 A. No.
7 Q. You saw her there?
8 A. Yes, I did.
9 Q. Okay. Did you ever see Brooke Shields there
10 before Lisa Marie Presley?
11 A. Yes, I -- I saw Brooke Shields, but I don’t
12 know if it was before.
13 MR. MESEREAU: No further questions.
14
15 FURTHER REDIRECT EXAMINATION
16 BY MR. ZONEN:
17 Q. Where did Brooke Shields stay when she
18 stayed at Neverland Ranch?
19 A. In a guest unit.
20 MR. ZONEN: No further questions.
21 MR. MESEREAU: No further questions.
22 THE COURT: All right. Thank you. You may
23 step down.
24 THE WITNESS: Thank you.
25 THE COURT: Call your next witness.
26 MR. MESEREAU: Witness be subject to
27 re-call, Your Honor?
28 THE COURT: Yes. 5442
1 MR. AUCHINCLOSS: Phillip LeMarque would be
2 our next witness, Your Honor.
3 THE COURT: Remain standing. Raise your
4 right hand. Face the clerk here.
5
6 PHILLIP LeMARQUE
7 Having been sworn, testified as follows:
8
9 THE WITNESS: I do.
10 THE CLERK: Please be seated. State and
11 spell your name for the record.
12 THE WITNESS: My name is Phillip LeMarque.
13 P-h-i-l-l-i-p; LeMarque, L-e-M-a-r-q-u-e.
14 MR. MESEREAU: Excuse me, Your Honor.
15 I think we have that issue that was raised.
16 THE COURT: That doesn’t come up until your
17 exam.
18 MR. MESEREAU: Okay.
19 THE COURT: Go ahead.
20 MR. AUCHINCLOSS: All right.
21
22 DIRECT EXAMINATION
23 BY MR. AUCHINCLOSS:
24 Q. Good morning, Mr. LeMarque. Where did you
25 work in 1991?
26 A. At the Neverland Valley.
27 Q. And who was your employer?
28 A. Michael Jackson. 5443
1 Q. Is he the man seated to my right?
2 A. Yes.
3 Q. How long did you work at Neverland?
4 A. Oh, somewhere around ten months or more.
5 Somewhere like that.
6 Q. And what did you do at Neverland?
7 A. Was in charge of the food. Majordomo of the
8 food. And my wife was the cook.
9 Q. All right. What do you mean by “majordomo
10 of the food”?
11 A. Well, in charge of serving the food and
12 preparing and organizing for the guests and so
13 forth.
14 Q. And you said your wife also worked there at
15 the same time?
16 A. That’s correct.
17 Q. Where did you live while you were living --
18 or while you were working at Neverland?
19 A. We were living at the ranch.
20 Q. Whereabouts at the ranch?
21 A. It was a house which is maybe -- was by the
22 zoo.
23 Q. Were you involved in serving the food as
24 well as preparing it?
25 A. Yes.
26 Q. And you said you left your employment there
27 after about ten months?
28 A. Yes, somewhere around ten months. 5444
1 Q. Why did you leave Neverland? Why did you
2 leave the employment there?
3 A. There was an issue happening with Norma
4 Stakos, who was Michael’s private secretary.
5 THE COURT: All right. We’re going to take a
6 break.
7 MR. AUCHINCLOSS: All right. We have a
8 morning break.
9 (Recess taken.)
10 --o0o--
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28 5445
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 5398 through 5445
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 April 8, 2005, and thereafter
20 reduced to typewriting by computer-aided
21 transcription under my direction.
22 DATED: Santa Maria, California,
23 April 8, 2005.
24
25
26
27 MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304
28 5446
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 FRIDAY, APRIL 8, 2005
20
21 8:30 A.M.
22
23 (PAGES 5447 THROUGH 5515)
24
25
26
27 REPORTED MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304
28 BY: Official Court Reporter 5447
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 -and-
19 OXMAN and JAROSCAK BY: R. BRIAN OXMAN, ESQ.
20 14126 East Rosecrans Boulevard Santa Fe Springs, California 90670
21
22
23
24
25
26
27
28 5448
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. Nicola is listed as “N” on index. Mr. Mesereau is listed as “M” on index.
6 Ms. Yu is listed as “Y” on index. Mr. Sanger is listed as “SA” on index.
7 Mr. Oxman is listed as “O” on index.
8
9 PLAINTIFF’S
10 WITNESSES DIRECT CROSS REDIRECT RECROSS
11 LeMARQUE, Phillip 5470-M 5493-A 5495-M
12 5498-A 5499-M
13 (Further) (Further)
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28 5449
1 E X H I B I T S
2 FOR IN
3 PLAINTIFF’S NO. DESCRIPTION I.D. EVID.
4 800 Photograph of arcade 5459 5460
5 801 Photograph of arcade 5460 5460
6 802 Handwritten Statement by
7 Phillip LeMarque 5495 5495
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28 5450
1 (The following proceedings were held in
2 open court outside the presence and hearing of the
3 jury:)
4
5 THE COURT: Counsel? Did you wish to address
6 me?
7 MR. MESEREAU: Yeah, Your Honor. I believe
8 the prosecutor filed a memorandum this morning
9 regarding impeachment of this witness.
10 THE BAILIFF: No one can hear you.
11 MR. MESEREAU: Oh, I’m sorry.
12 Your Honor, the prosecutor filed a pleading
13 this morning regarding impeachment of this
14 particular witness.
15 THE COURT: Yes.
16 MR. MESEREAU: And he has, as I understand
17 it, requested that the defense not mention the fact
18 that this witness has been in the --
19 MR. AUCHINCLOSS: I’ll ask --
20 MR. MESEREAU: -- the pornographic website
21 business.
22 MR. AUCHINCLOSS: May I object, and just ask
23 that the Court -- the Court is aware of the issues.
24 I don’t think it’s necessary to publish them.
25 THE COURT: That’s true. He did -- not in
26 the terms you just stated.
27 For once you want to use “pornographic” when
28 no one else wants to. It was the other way around 5451
1 recently.
2 But what -- your point being?
3 MR. MESEREAU: Your Honor, we can prove that
4 this witness tried to use tabloid stories about Mr.
5 Jackson --
6 THE COURT: What’s your argument against his
7 position? I understand what you can prove. I think
8 his position is well-taken. What’s your argument?
9 MR. MESEREAU: My argument is that what we
10 would like to show, Your Honor, is that he tried to
11 use information allegedly about Mr. Jackson to get
12 into this business.
13 THE COURT: All right. I’ll sustain his
14 objection. You cannot impeach him based on the work
15 he did on that --
16 MR. MESEREAU: Website?
17 THE COURT: -- website after these incidents.
18 All right. Bring in the jury.
19
20 (The following proceedings were held in
21 open court in the presence and hearing of the
22 jury:)
23
24 THE COURT: Go ahead, Counsel.
25 MR. AUCHINCLOSS: Thank you, Your Honor.
26 Q. Mr. LeMarque, where we left off, we were
27 talking about the reasons that you left your
28 employment at Neverland. 5452
1 A. The reason, there was some problem with
2 Norma Stakos, who was Michael’s secretary.
3 Q. What was that problem?
4 A. She wanted to have my wife to sign an
5 affidavit stating that Bianca had been involved into
6 looking into purses of other maids. And since my
7 wife didn’t see it, she didn’t want to sign it.
8 Q. When you say Bianca was her name, do you
9 know what her last name was?
10 A. No, I forgot.
11 Q. Did she have a different first name; do you
12 know?
13 A. Not that I remember.
14 Q. Okay. And what was this woman Bianca’s --
15 what was her job at Neverland?
16 A. She was the private maid for Michael. She
17 was the only one who could enter his room.
18 Q. So the affidavit that your wife was asked to
19 sign was a false affidavit?
20 A. Well, it was false as far as my wife was
21 concerned, because she never saw Bianca looking into
22 any purses so --
23 Q. Did she believe that Bianca looked into any
24 purses?
25 A. No, of course she didn’t believe it.
26 Q. Okay. And how much time transpired between
27 the time that your wife was asked to sign this false
28 affidavit and the time that you were asked to leave 5453
1 Neverland?
2 A. We were -- we were not asked, really, to
3 leave, but we had a conference with Norma a few days
4 later, maybe three or four days, and Norma said I
5 guess --
6 MR. MESEREAU: Objection; hearsay, Your
7 Honor.
8 THE COURT: Sustained.
9 MR. AUCHINCLOSS: Offered to explain conduct
10 only.
11 THE COURT: The question was how much time
12 transpired between the signing of the affidavit, so
13 it’s not responsive to the question.
14 MR. AUCHINCLOSS: That’s fine.
15 Q. So let’s go back to that first question.
16 How much time between the time that you --
17 that your wife was asked to sign the false affidavit
18 and the time that you actually left your employment
19 at Neverland?
20 A. I would say four or five days.
21 Q. Okay.
22 A. Maybe a week. I don’t know.
23 Q. And were you terminated from your
24 employment?
25 A. No, we came into --
26 Q. That’s just a “yes” or “no” question.
27 A. Yes.
28 Q. You were terminated? 5454
1 A. (Nods head up and down.)
2 Q. Okay.
3 A. No. Yes and no.
4 Q. Yes and no. Okay. That’s fine.
5 A. Common agreement.
6 Q. Why do you say, “Yes and no”?
7 A. Because it was a common agreement that we
8 decided, since we didn’t want to sign the affidavit,
9 that was not a place for us to work.
10 Q. Okay. While you were at Neverland during
11 that ten-month period, did you observe Mr. Jackson
12 to have child visitors?
13 A. Yes.
14 Q. Would these children spend the night at
15 Neverland?
16 A. Some of them, yes.
17 Q. Would any of them come with families?
18 A. Yes.
19 Q. Would any of them come by themselves?
20 A. I think on one occasion I saw.
21 Q. Did you notice whether or not Mr. Jackson
22 would spend time equally with all the child visitors
23 at Neverland?
24 A. No.
25 MR. MESEREAU: Objection; vague.
26 THE COURT: Sustained.
27 Q. BY MR. AUCHINCLOSS: Did Mr. Jackson show
28 any special preference towards the children that 5455
1 visited him at Neverland?
2 A. Yes.
3 MR. MESEREAU: Objection; leading.
4 THE COURT: Overruled.
5 Q. BY MR. AUCHINCLOSS: You may answer.
6 A. Yes.
7 Q. And was there anything in common that -- the
8 children that Mr. Jackson showed preference to, was
9 there anything in common that these children shared?
10 A. Yes.
11 Q. What was that?
12 A. Little boys around 10, 11 years old.
13 Q. How would Mr. Jackson show preference to
14 these 10- or 11-year-old boys?
15 A. He would spend most of his time with them.
16 Q. Would he ever buy them gifts?
17 A. Yes.
18 Q. Did he buy them more gifts than the other
19 children?
20 A. Yes.
21 MR. MESEREAU: I’m going to object. No
22 foundation; move to strike.
23 MR. AUCHINCLOSS: I can ask some additional
24 questions on that.
25 THE COURT: On the question that he objected
26 on, did he buy them more than any other children,
27 I’ll sustain the foundation.
28 MR. AUCHINCLOSS: Okay. 5456
1 Q. Mr. LeMarque, were you ever asked by Mr.
2 Jackson to go out and buy toys as gifts for these
3 children?
4 A. Yes.
5 Q. On how many occasions?
6 A. I don’t -- several times.
7 Q. Okay. And can you characterize the number
8 of gifts that you would buy, the number of toys?
9 A. I would go to Toys-R-Us and pick out toys
10 for boys of 10, 11 years old.
11 Q. Were you instructed to buy such toys?
12 A. No, but I figured that was what they were
13 for, so --
14 Q. And when you brought these toys to Mr.
15 Jackson, did you have any occasion to see him give
16 these toys as gifts to the children?
17 A. Well, usually they were put into an area or
18 a tabletop where the kids would come in, you know,
19 tear the papers off and pick up the toys.
20 Q. Did you see Mr. Jackson give more toys to
21 the boys than the other children?
22 A. Yeah, they were mainly toys for boys.
23 Q. Okay. When Mr. Jackson had these children
24 as guests at Neverland, what type of hours would
25 they keep, in terms of time that they were spending
26 together?
27 A. Sometimes all day, all night.
28 Q. Was it uncommon for him to stay up all night 5457
1 with the children?
2 A. Yeah, it was very common.
3 Q. Where did the children sleep? And I’m
4 talking specifically about the 10- or 11-year-old
5 boys.
6 A. Mainly with Michael.
7 Q. Whereabouts?
8 A. I don’t know, because we couldn’t get
9 into his apartment, so --
10 Q. But somewhere in his private --
11 A. In his quarters, yeah.
12 Q. -- quarters?
13 MR. MESEREAU: Objection; leading.
14 THE COURT: Well, actually he didn’t finish
15 the question. I’ll strike the answer and have you
16 rephrase the question.
17 Q. BY MR. AUCHINCLOSS: My question was, you
18 said that mainly they would sleep with Michael, and
19 I was asking if that was in his private quarters.
20 A. Yes.
21 Q. During the time that you were employed at
22 Neverland, did you ever see Michael Jackson sleep
23 with anyone other than children?
24 A. No.
25 MR. AUCHINCLOSS: May I approach, Your
26 Honor?
27 THE COURT: Yes.
28 Q. BY MR. AUCHINCLOSS: Mr. LeMarque, I show 5458
1 you People’s Exhibit No. 721. Can you identify that
2 for me, please?
3 A. Yes.
4 Q. Who is that in that photograph?
5 A. Macaulay Culkin.
6 Q. Did Macaulay Culkin visit Neverland while
7 you were working there?
8 A. Yes.
9 Q. Was he a guest of Mr. Jackson’s?
10 A. Yes.
11 Q. Did he spend the night there?
12 A. Yes.
13 Q. I show you two photographs which I’ve
14 previously shown to counsel. The first one is
15 People’s Exhibit 800. Can you identify that for me,
16 please?
17 A. Yes, this is the arcade.
18 Q. Okay. And is that a fair representation of
19 the floor plan of the arcade when you were working
20 there?
21 A. Yeah.
22 Q. Are there some differences in terms of the
23 items that are in this picture --
24 A. Yes.
25 Q. -- than the items that were in the arcade
26 back when you worked there?
27 A. Yes.
28 Q. What would that be? 5459
1 A. Some of the artifacts here were not there.
2 And some of the games have been changed. I mean,
3 they were different, a little bit different.
4 Q. But the floor plan is essentially the same?
5 A. The floor plan is the same, yeah.
6 Q. I show you People’s Exhibit 801. Same
7 question. Can you identify that for me?
8 A. That’s the arcade also. Different angle.
9 Q. And same distinctions?
10 A. Yeah. Some of the artifacts have been
11 changed and so forth. The pool table was there.
12 And some of the toy -- the games are different.
13 MR. AUCHINCLOSS: Okay. Ask that People’s
14 800 and 801 be admitted.
15 MR. MESEREAU: No objection.
16 THE COURT: Admitted.
17 Q. BY MR. AUCHINCLOSS: Mr. LeMarque, at some
18 time during your employment, did you see something
19 involving Mr. Jackson and one of these boys that
20 upset you?
21 A. Yes.
22 Q. Do you know the name of that boy?
23 A. Macaulay Culkin.
24 Q. And how long had you worked at Neverland
25 when this incident occurred?
26 A. Well, I’m not too sure there. I mean, six,
27 seven months maybe.
28 Q. Okay. Where did this incident occur? 5460
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Subject: April 8, 2005 
Thu Mar 15, 2012 2:26 pm
