1 time or something like that?
2 Q. I didn’t. That was an investigator.
3 A. It wasn’t you.
4 Q. Okay. You spoke to one of our investigators
5 named Jesus Castillo, correct?
6 A. That is correct.
7 Q. And you spoke to him around January 9th,
8 2005, right?
9 A. Must have been, yes.
10 Q. Okay. Okay. And do you know -- where did
11 that interview take place; do you know?
12 A. Yes. Was it the Holiday Inn, Santa Maria?
13 Q. Okay. And approximately how long do you
14 remember speaking with our investigator, Jesus
15 Castillo?
16 A. It took, I would say, about half an hour.
17 Q. Okay. And do you remember you told Mr.
18 Castillo that when you told the police that you
19 remembered Gavin and Star sleeping in Mr. Jackson’s
20 room, you meant the lower portion of the two-level
21 suite, correct?
22 A. That is correct.
23 Q. You told Mr. Castillo that Mr. Jackson’s
24 room has an upstairs portion and a downstairs,
25 correct?
26 A. That is correct.
27 Q. And you told him that you never saw Gavin or
28 Star sleeping in Mr. Jackson’s bed located upstairs, 4711
1 right?
2 MR. AUCHINCLOSS: I’ll object; foundation.
3 THE COURT: Overruled.
4 You may answer.
5 THE WITNESS: That is correct. I never saw
6 them sleeping in the bed. I saw them out of bed,
7 not sleeping.
8 Q. BY MR. MESEREAU: Right. The only place you
9 ever saw Gavin or Star sleeping was in the
10 downstairs portion of Mr. Jackson’s room, right?
11 MR. AUCHINCLOSS: Objection; foundation.
12 THE COURT: Overruled.
13 You may answer.
14 THE WITNESS: That is correct.
15 Q. BY MR. MESEREAU: Okay. And you remember
16 many guests of Mr. Jackson sleeping in his room,
17 sometimes upstairs and sometimes downstairs, right?
18 A. That is correct, if you’re talking about the
19 boys, yes.
20 Q. Yeah. He had guests come and sleep from
21 time to time --
22 A. That is correct.
23 Q. -- in that suite, correct?
24 A. That is correct.
25 Q. Sometimes you’d see them upstairs, sometimes
26 you’d see them downstairs, right?
27 A. That is correct.
28 Q. Okay. Now, one time you suspected that 4712
1 Gavin might have been drinking at a dinner table,
2 right?
3 A. That is correct.
4 Q. But you never saw Gavin drinking, right?
5 A. That is correct.
6 Q. And his family used to have dinner at the
7 dinner table, right?
8 A. That is correct.
9 Q. His mother used to have dinner at the dinner
10 table, correct?
11 A. Yes.
12 Q. Now, the prosecutor asked you questions
13 about whether or not children have a lot of freedom
14 at Neverland, right?
15 A. Right.
16 Q. And your answer was basically they do,
17 right?
18 A. That is correct.
19 Q. And so do their parents have freedom at
20 Neverland, correct?
21 A. That is correct.
22 Q. The prosecutor asked you about something
23 along the lines of first-class service. Do you
24 remember that?
25 A. Yes.
26 Q. And you said that Mr. Jackson liked to have
27 his guests get high-quality service, right?
28 A. That is correct. 4713
1 Q. But when you said that, you were also
2 including adult guests, correct?
3 A. Right.
4 Q. And when you were there and you saw Janet
5 Arvizo there, she was getting first-class service,
6 true?
7 A. Yes, she was.
8 Q. Do you remember a period of time when Janet
9 Arvizo was there with her former husband, David
10 Arvizo? Do you remember that?
11 A. One time, yes.
12 Q. And they both were entitled to first-class
13 service, correct?
14 A. That is correct.
15 Q. And when Janet came with just her children,
16 she had all the privileges that guests get at
17 Neverland, right?
18 A. That is correct.
19 Q. She was able to enter the main residence,
20 right?
21 A. Yes.
22 Q. She was able to order food when she wanted,
23 correct?
24 A. Yes.
25 Q. She could sit at the dinner table at the
26 main house and have dinner, or lunch, or breakfast,
27 right?
28 A. That is correct. 4714
1 Q. She also was allowed to enter the kitchen
2 and sit at that bar area and order breakfast when
3 she chose, right?
4 A. That is correct.
5 Q. She also ordered room service when she
6 wanted, right?
7 A. That is correct.
8 Q. And do you know which quarters she stayed
9 in?
10 A. If I remember, it was on Unit 4.
11 Q. And that’s one of the most beautiful rooms
12 on that property, isn’t it?
13 A. Yes, it is.
14 Q. It’s a room where Elizabeth Taylor and
15 Marlon Brando request to stay, or used to request to
16 stay from time to time, correct?
17 MR. AUCHINCLOSS: Objection; relevancy.
18 THE COURT: Sustained.
19 Q. BY MR. MESEREAU: Janet was entitled to the
20 same service that guests like Elizabeth Taylor and
21 Marlon Brando would get, correct?
22 MR. AUCHINCLOSS: Objection; relevancy.
23 THE COURT: Overruled.
24 Q. BY MR. MESEREAU: Right?
25 A. That is correct.
26 Q. And when you told the jury that the theater
27 would be open day and night, adult guests also were
28 allowed to go into the theater day or night, right? 4715
1 A. That is correct.
2 Q. And when you told the prosecutor that there
3 was some rooms in the theater with beds in them,
4 adults could use those rooms, true?
5 A. That is correct.
6 Q. The prosecutor talked about candy and sodas
7 and food being available at all hours of date. They
8 were also available for adult guests, correct?
9 A. That is correct.
10 Q. And isn’t it true that Mr. Jackson wanted
11 his adult guests to have special, classy service,
12 right?
13 A. That is correct.
14 Q. Now, you saw kids at Neverland visiting when
15 Mr. Jackson wasn’t there, correct?
16 A. That is correct.
17 Q. And typically, if kids visited Neverland
18 when Mr. Jackson wasn’t there, there were rules that
19 were supposed to be followed for safety, as you
20 said, right?
21 A. That is correct.
22 Q. And typically, it was their parents or
23 whatever adults were with them that appeared to be
24 in charge of them, correct?
25 A. That is correct.
26 Q. And you saw busloads of children from
27 various locations visit Neverland from time to time,
28 correct? 4716
1 A. That is correct.
2 Q. And to your knowledge, Mr. Jackson wasn’t in
3 charge of all of those busloads of children, was he?
4 A. No, he wasn’t.
5 Q. In fact, most of the time when lots of kids
6 would visit Neverland, some other adult appeared to
7 be in charge of those kids, right?
8 A. That is correct.
9 Q. And adults and children would visit
10 Neverland and be given tours of Neverland, right?
11 A. That is correct.
12 Q. Who typically would give those tours?
13 A. We assigned different people, employees of
14 Neverland Valley.
15 Q. And tell the jury how a tour would be
16 conducted when children and adults would visit
17 Neverland.
18 A. They were --
19 MR. AUCHINCLOSS: Objection. Relevancy;
20 beyond the scope.
21 THE COURT: Overruled.
22 Go ahead.
23 THE WITNESS: They would arrive at Neverland
24 Valley Ranch, park on the outside parking lot, walk
25 to the train station. And from there, they were
26 picked up either by train or walk, whatever they
27 preferred to do, okay, take them back to the
28 theater. Enjoy, you know, the petting zoo. They 4717
1 were allowed to visit where they wanted to. I mean,
2 we had a schedule for them and took them everywhere,
3 the property, to show them the place and enjoy the
4 place. And they ended up at the theater and at the
5 park.
6 Q. BY MR. MESEREAU: And you would schedule
7 lots of tours from time to time, right?
8 A. That is correct.
9 Q. Sometimes you’d have a couple of hundred
10 children visiting with adults, correct?
11 A. That is correct. Sometimes more than that.
12 Q. What’s the largest number of kids you
13 remember visiting at one time to Neverland?
14 A. I would say about 300, 300 kids.
15 Q. And did they come with adults who were in
16 charge of them?
17 A. Yes.
18 Q. Okay. And did you arrange tours for these
19 children as well?
20 A. Yes. We assigned the personnel to give them
21 a tour, yes.
22 Q. Okay. And sometimes, if Michael Jackson was
23 on the premises, he would come out and say hello,
24 right?
25 A. That is correct.
26 Q. But he never was in charge of what these
27 kids did, right?
28 A. That is correct. 4718
1 MR. AUCHINCLOSS: Objection; vague as to
2 “kids.”
3 THE COURT: Overruled. The answer’s in.
4 Next question.
5 Q. BY MR. MESEREAU: Who would prepare the
6 schedule to indicate whether children were coming to
7 Neverland on a particular day?
8 A. I believe that came from L.A. office.
9 Q. And would it be posted somewhere?
10 A. Yes. All Neverland personnel got a schedule
11 of the kids coming to Neverland.
12 Q. And would you get a schedule typically the
13 day before or that morning?
14 A. Normally we got it, like, two days before, a
15 day before, yes.
16 Q. And as part of your work, you had to look at
17 the future schedule every day, didn’t you?
18 A. That is correct.
19 Q. Because almost every day something unusual
20 or special would be going on at Neverland, right?
21 A. That is correct.
22 Q. And how long did you work at Neverland?
23 A. The total was 20 years.
24 Q. During that 20-year period, would it be
25 accurate to say that many, many thousands of
26 children came through, right?
27 A. That is correct.
28 Q. They came from Los Angeles, right? 4719
1 A. That is correct.
2 Q. They came from Santa Barbara, right?
3 A. Right.
4 Q. They came from foreign countries, right?
5 A. That is correct, yes.
6 Q. Based upon your experience over 20 years,
7 Neverland was a real attraction for children around
8 the world, wasn’t it?
9 A. Yes, it was.
10 Q. And you considered a major part of your
11 responsibility to be making sure that Neverland was
12 kept up properly so that when children from all over
13 the world came, they’d have a good time, right?
14 A. That is correct.
15 Q. Over 20 years, it may have been hundreds of
16 thousands of children you saw visit, right?
17 A. That is correct.
18 Q. Now, the prosecutor asked you about the time
19 Janet Arvizo asked you to drive her to Los Angeles,
20 okay?
21 A. Correct.
22 Q. You told Jesus Castillo, our investigator,
23 that at no time did anyone forcibly keep her at
24 Neverland Ranch, right?
25 A. That is correct.
26 Q. And at no time was she ever locked in her
27 room, right?
28 A. Not that I was aware of. 4720
1 Q. And at no time was she kept at Neverland
2 Ranch against her will, right?
3 A. That is exactly what I said, yes.
4 Q. She called you upset and asked you to take
5 her home and you did so, right?
6 A. Yes.
7 Q. You took her, yourself, in December; is that
8 correct? Do you remember what month you took her
9 yourself in the Rolls Royce?
10 A. It was December or January, somewhere around
11 there. Pretty bad on dates.
12 Q. And then she came back, what, in less than a
13 week?
14 A. I would say in about a couple weeks,
15 thereabout.
16 Q. She came back, and then, a few weeks later,
17 wanted to leave again, right?
18 A. That is correct.
19 Q. And you arranged transportation for her to
20 leave again, right?
21 A. Yes, I had to call a limo.
22 Q. And that was, as far as you know, the last
23 time you ever saw the Arvizos, correct?
24 A. Correct.
25 Q. When you drove Ms. Arvizo and her children
26 in the Rolls Royce, she never made any complaints
27 about the way she’d been treated at Neverland,
28 right? 4721
1 A. That is correct.
2 Q. She never said she’d been abused at
3 Neverland, right?
4 A. That is correct.
5 Q. She never said her children had been taken
6 advantage of at Neverland, right?
7 A. That is correct.
8 Q. But she didn’t seem to like Dieter or
9 Ronald, right?
10 A. That is correct, yes.
11 Q. And she told you she was concerned about
12 media attention on her family, right?
13 A. She mentioned about that, yes.
14 Q. Her concerns to you were media attention and
15 the fact that she didn’t like Dieter, right?
16 A. That is correct, yes.
17 Q. She never complained about anything else,
18 did she?
19 A. No.
20 Q. In fact, she told you she respected and
21 liked Michael Jackson, right?
22 A. Yes, she did.
23 Q. She never complained to you about Michael
24 Jackson at all, did she?
25 A. Never.
26 Q. When you drove her in the Rolls Royce, she
27 was in the front seat with you, right?
28 A. Yes. 4722
1 Q. Her children were in the back seat, right?
2 A. That is correct.
3 Q. And you and she spoke during that three-hour
4 trip, right?
5 A. She didn’t spoke too much, but, yes, she
6 did.
7 Q. Did you speak to her very much when she used
8 to stay at Neverland?
9 A. No.
10 Q. Okay. And in -- on that trip, excuse me,
11 Janet Arvizo never complained that she was being
12 taken out of the country against her will, did she?
13 A. No, she never said anything.
14 Q. Do you remember when she returned, you
15 think, within the next couple of weeks?
16 A. It was in the next couple of weeks, yes.
17 Q. Do you remember seeing her suddenly show up
18 with her children again?
19 A. Yes.
20 Q. And do you know what time of day that was?
21 A. I believe it was afternoon.
22 Q. Did you talk to her when you saw her return?
23 A. Yes, I did.
24 Q. You never got the impression she was there
25 against her will at that point, did you?
26 A. No, I didn’t.
27 Q. The last time Janet and the kids left
28 Neverland, do you know who drove them home? 4723
1 A. Yes, I called a limousine service.
2 Q. So you took her in a Rolls Royce one time,
3 and the last time it was a limousine service that
4 you arranged, true?
5 A. That is correct.
6 Q. Do you remember any other times that Janet
7 and the children left Neverland?
8 A. That was the last time I saw them.
9 Q. So you’re only personally aware of two times
10 where they left Neverland; is that right?
11 A. Yes.
12 Q. That you had anything to do with?
13 A. That is correct.
14 Q. Okay. Now, the prosecutor asked you about a
15 safe that was brought onto the property to lock
16 keys. Do you remember that?
17 A. Uh-huh.
18 Q. And if you remember, whose idea was it to
19 put a safe where the keys could be locked?
20 A. It was the ranch manager idea and my idea.
21 Q. Did you discuss it with Michael Jackson?
22 A. No, we never did.
23 Q. You just ordered a safe?
24 A. We just ordered a safe.
25 Q. And you put the keys in the safe?
26 A. That is correct.
27 Q. And before that, where were the keys kept?
28 A. They were kept in the same room, behind 4724
1 the -- behind the door to the entry to the room,
2 yes.
3 Q. Is that the entrance to the wine cellar?
4 A. No, no, no. That’s the entrance to the
5 maids’ room.
6 Q. Okay. Okay. But they were hung out in open
7 view, right?
8 A. That is correct, yes.
9 Q. Do you remember Frank Tyson’s sister, Marie
10 Nicole?
11 A. Yes.
12 Q. Do you remember her staying at Neverland?
13 A. Yes.
14 Q. Do you remember her walking around the
15 property and playing with Michael Jackson?
16 A. Yes, I do.
17 Q. Was it your impression that the family was
18 close to Michael Jackson?
19 A. Yes.
20 Q. Did you see Frank Tyson’s parents visit from
21 time to time?
22 A. That is correct, yes.
23 Q. And do you remember their names?
24 A. I don’t. Sorry.
25 Q. Did you see Frank Tyson’s brothers visit
26 from time to time?
27 A. Yes.
28 Q. Okay. You talked about a combination to Mr. 4725
1 Jackson’s room. Remember that?
2 A. Yes.
3 Q. And did you always have that combination?
4 A. Yes, I did.
5 Q. Do you know if anyone else had it, to your
6 knowledge?
7 A. Ranch manager.
8 Q. What about staff who cleaned the room? Did
9 they typically have it?
10 A. Yes. Yes. We have -- we had another guy
11 there that also had it, know the combination of the
12 room.
13 Q. And that combination was changed
14 periodically, right?
15 A. My time there, we changed it about a couple
16 times.
17 Q. Okay. Do you remember it being changed
18 because too many people seemed to have it?
19 A. We noticed there was so many kids going into
20 the room, so we figured we change the combination,
21 yes.
22 Q. Do you remember Michael Jackson complaining
23 that Frank was going into his bedroom when Michael
24 was out of town?
25 MR. AUCHINCLOSS: Objection; hearsay.
26 THE COURT: Sustained.
27 Q. BY MR. MESEREAU: Was it your understanding
28 that Frank could get into that room on occasion? 4726
1 MR. AUCHINCLOSS: Objection; foundation.
2 THE COURT: Sustained.
3 Q. BY MR. MESEREAU: Do you know whether or not
4 Frank seemed like he could get into Michael’s
5 bedroom from time to time?
6 MR. AUCHINCLOSS: Objection; foundation.
7 THE COURT: Sustained.
8 Q. BY MR. MESEREAU: Did you ever observe Frank
9 in Michael Jackson’s bedroom?
10 A. Yes.
11 Q. Did you ever see Marie Nicole in Michael
12 Jackson’s bedroom?
13 A. Yes.
14 Q. And again, when I say “bedroom,” we’re
15 talking about two levels, right?
16 A. That is correct.
17 Q. It’s a rather large area, isn’t it?
18 A. That is correct, yes.
19 Q. And on the lower level, people can sit down
20 and enjoy themselves, can’t they?
21 A. That is correct. Yes.
22 Q. What do you recall there being on the lower
23 level of Michael Jackson’s bedroom when you were
24 working there?
25 A. I just recall that it was a peaceful area
26 that people can sit and enjoy themselves there.
27 Fireplace or -- it was pretty peaceful place to be.
28 Q. And he would entertain people in the lower 4727
1 portion of his bedroom, correct?
2 A. That is correct, yes.
3 Q. People would get served food there, correct?
4 A. That is correct, yes.
5 Q. People would get served drinks there, right?
6 A. That is correct.
7 Q. And you say there’s a fireplace?
8 A. There’s a fireplace there.
9 Q. People would sit around the fireplace and
10 chat, correct?
11 A. Yes.
12 Q. And sometimes they did it when Mr. Jackson
13 was there, and sometimes they did it when he wasn’t
14 there, right?
15 MR. AUCHINCLOSS: Objection. Foundation;
16 assumes facts.
17 THE COURT: Overruled.
18 You may answer. Do you want the question
19 read back?
20 MR. MESEREAU: Do you want -- I’m sorry.
21 THE WITNESS: Answer it?
22 THE COURT: Yes. Do you want the question
23 read back?
24 THE WITNESS: No, I understood the question.
25 Pretty much when Mr. Jackson wasn’t there,
26 nobody was allowed to go into his room.
27 Q. BY MR. MESEREAU: There were times when he
28 let people in, weren’t there? 4728
1 A. Yes, there was.
2 Q. And they would have some fun when Mr.
3 Jackson wasn’t even there, right?
4 A. That is correct, yes.
5 Q. Okay. Now, approximately what year did you
6 start working at Neverland?
7 A. Since the beginning, do you mean?
8 Q. Yes.
9 A. I would say in ‘83, 1983.
10 Q. ‘83?
11 A. Uh-huh.
12 Q. So, there was a point in time where your
13 daughter used to visit Neverland, right?
14 A. That is correct.
15 Q. And what is her name?
16 A. Sandra.
17 Q. Sandra used to visit when she was
18 approximately five years old, right?
19 A. Five, six, yes.
20 Q. She used to play with Michael Jackson,
21 right?
22 A. Yes, that is correct.
23 Q. He used to give her gifts, right?
24 A. That is correct, yes.
25 Q. Now, normally do people who work at
26 Neverland bring their children there very often?
27 A. We have -- they have what is called “Family
28 Day,” yes. 4729
1 Q. And please tell the jury what “Family Day”
2 is.
3 A. Family Day is a day where it’s open for the
4 employees to bring all your family and have access
5 to all the facilities there, yes.
6 Q. And how often does that happen?
7 A. Once a year at least.
8 Q. And that’s a big event at Neverland, right?
9 A. That is correct, yes.
10 Q. And Michael Jackson closes Neverland off for
11 other visits and lets all of the help and their
12 family take over pretty much, right?
13 A. Yes, sir.
14 Q. And it starts in the morning, doesn’t it?
15 A. Yes.
16 Q. Goes late into the evening, right?
17 A. Yes.
18 Q. Now, you mentioned a petting zoo before.
19 Please tell the jury what the petting zoo is.
20 A. The petting zoo is a place where they have
21 just little animals for kids, where they can go and
22 play with the animals. We have -- I mean, they have
23 a variety of animals where kids can, pretty safe, go
24 and touch the animals.
25 Q. And what kind of animals do you have in the
26 petting zoo?
27 A. Well, they have llamas. They have deers.
28 They are rabbits. They have pigs. Birds. What 4730
1 else do they have? They have lots of animals.
2 Q. And the petting zoo is primarily designed
3 for kids, correct?
4 A. That is correct, yes.
5 Q. And then you have a larger zoo, right?
6 A. That is correct.
7 Q. And please tell the jury what’s in the
8 larger zoo.
9 A. Well, that’s where you can find the big
10 animals. Like you can find elephants, lions,
11 chimpanzees. You can find llamas and different
12 other animals. Wolfs. Stuff like that.
13 Q. You got giraffes, right?
14 A. Giraffes.
15 Q. There’s a camel?
16 A. Right, exactly.
17 Q. And typically, at least once a day, the
18 trainers walk two elephants through the property,
19 right?
20 A. That is correct, yes.
21 Q. And they walk the elephants through the
22 property, and very often guests, if they follow the
23 rules, can feed them, right?
24 A. That is correct, yes.
25 Q. And Mr. Jackson will pay for bags of
26 doughnuts and goodies to give to the elephants,
27 right?
28 A. That is correct, yes. 4731
1 Q. Is that a once-a-day affair?
2 A. Yes, pretty much once a day.
3 Q. Okay. It’s usually a big thing for kids and
4 their parents, right?
5 A. Right.
6 Q. Now, as part of your duties at Neverland,
7 you often would pay for toys for kids, correct?
8 A. That is correct. Yes.
9 Q. And you would be reimbursed, typically, if
10 you spent your own money on toys, right?
11 A. That is correct, yes.
12 Q. You would get a reimbursement check of --
13 for as much as $11,000 from time to time, right?
14 A. That is correct, yes.
15 Q. And what kind of rules did you follow as far
16 as buying toys for kids is concerned?
17 A. Really wasn’t any rules. We just went and
18 bought some toys.
19 Q. But the prosecutor asked you questions about
20 how influential Mr. Jackson was in running affairs.
21 Didn’t he give you a lot of flexibility in just
22 going out, buying hundreds of toys, and then just
23 charging him for it?
24 A. That is correct, yes.
25 Q. And where would you go buy those toys?
26 A. Toys-R-Us.
27 Q. Okay. Would you drive there yourself?
28 A. Pretty much Mr. Jackson came along or with 4732
1 the kids or some adults, yes.
2 Q. And Mr. Jackson would from time to time let
3 you drive parents and their children to Toys-R-Us,
4 right?
5 A. That is correct. Yes.
6 Q. And he would tell you to buy them whatever
7 they’d like, right?
8 A. That is correct, yes.
9 Q. You’d spend thousands of dollars on these
10 kids, right?
11 A. That is correct, yes.
12 Q. And that was one of your responsibilities as
13 ranch manager, right?
14 A. That is correct. Yes.
15 Q. To try and take care of the children as best
16 you could, right?
17 A. Correct, yes.
18 Q. Now, what are the safety regulations in
19 effect at the zoo, to your knowledge?
20 A. Well, there’s certain regulations for the
21 zoo, especially with the big animals. Again, for
22 the safety of the guests or kids, yes.
23 Q. And you have all these amusement rides as
24 well, right?
25 A. That is correct, yes.
26 Q. Please tell the jury what amusements rides
27 you have for the kids and the parents.
28 A. Well, there’s different rides. The Ferris 4733
1 wheel. They have the merry-go-round. They have a
2 big slide. They have a -- oh, got -- they have the
3 Sea Dragon. They have various rides also for kids,
4 for small kids, yes.
5 Q. And when you have these busloads of kids and
6 adults show up and they want to use the rides, what
7 safety precautions do you have?
8 A. Well, we have a -- we just got to make sure
9 that the kids don’t get hurt. We have regulations
10 for that. We have personnel there guiding the kids
11 and taking care of the kids so nobody gets hurt.
12 Q. And the personnel specialize in the
13 amusement park portion of Neverland, right?
14 A. That is correct, yes.
15 Q. And are they in charge of maintaining the
16 rides, making sure the machinery’s okay?
17 A. That is correct, yes.
18 Q. And were they under your supervision?
19 A. No.
20 Q. Okay. Who was supervising the people who
21 run the amusement park?
22 A. There’s -- Neverland has different groups of
23 people, you know, like departments, what we call it,
24 and it was the person in charge of the amusement
25 park.
26 Q. Just like there’s a group in charge of the
27 petting zoo and the bigger zoo, right?
28 A. That is correct, yes. 4734
1 Q. And when these children and these adults
2 visit Neverland, these different groups are all
3 available to make sure kids are safe, right?
4 A. That is correct. Yes.
5 Q. Now, when you have hundreds of children
6 running around Neverland, they can sometimes get
7 into all kinds of mischievous situations, right?
8 A. Absolutely, yes.
9 Q. You’ve seen kids caught in the house in
10 various rooms, right?
11 A. That is correct.
12 Q. And they’ve been politely asked to leave,
13 right?
14 A. That is correct, yes.
15 Q. You’ve seen kids trying to get in doors
16 they’re not supposed to get through, correct?
17 A. Correct.
18 Q. You’ve seen kids trying to get into the
19 arcade whenever they can, right?
20 A. That is correct, yes.
21 Q. And kids are sometimes caught with things in
22 their hands, little things they found in the main
23 house and they have -- you have to take them away
24 from them, right?
25 A. That is correct, yes.
26 Q. And it’s never been your understanding that
27 Mr. Jackson is personally supervising all of this,
28 right? 4735
1 A. No.
2 Q. In fact, he’s amazingly generous in letting
3 people come into his home and go through it, and see
4 it, right?
5 A. Yes, he is.
6 Q. And this is a large home that has a lot of
7 beautiful antiques, correct?
8 A. That is correct, yes.
9 Q. A lot of family pictures, right?
10 A. That is correct, yes.
11 Q. He has things he’s collected from all over
12 the world, right?
13 A. Yes.
14 Q. And he often lets whoever visits come
15 through the house so they can see all of this,
16 right?
17 A. Yes.
18 Q. And when he has guests stay over in the
19 guest quarters, I believe you said that they pretty
20 much can walk into that main house when they want,
21 right?
22 A. That is correct, yes.
23 Q. He has staff available all the time to
24 prepare a meal for them if they want one, right?
25 A. Yes.
26 Q. And in that kitchen area, you have
27 unlocked -- an unlocked refrigerator area, correct?
28 A. That’s correct. It’s open. 4736
1 Q. And they can go in there all the time and
2 get sodas, right?
3 A. That is correct.
4 Q. Juice, right?
5 A. Yes.
6 Q. Milk?
7 A. Whatever their choice is.
8 Q. And you’ll find wine in there, right?
9 A. That is correct, yes.
10 Q. And he lets his adult guests go in there and
11 get wine when they choose, correct?
12 A. That is correct, yes.
13 Q. And glasses are nearby if they want a glass,
14 right?
15 A. Yes.
16 Q. It’s a very large refrigerator area, isn’t
17 it?
18 A. It is.
19 Q. How many glass doors do you think are on
20 that large refrigerated area?
21 A. Oh, God. About six, eight, something like
22 that.
23 Q. Six or eight transparent doors they can go
24 into to get all kinds of beer, wine, soda, milk,
25 orange juice, right?
26 A. That is correct, yes.
27 Q. And there’s a menu that’s posted on a
28 blackboard most days, right? 4737
1 A. That is correct, yes.
2 Q. And what do you typically find on that menu?
3 A. You find the menu for the food or whatever
4 the people wants to use.
5 Q. There’s usually some special dishes that the
6 staff are preparing for that day, right?
7 A. Exactly, yes. Right.
8 Q. And there also is a standard menu that
9 Michael Jackson printed up that he gives that people
10 have to order from, right?
11 A. That is correct, yes.
12 Q. And you got sandwiches and soup and stuff
13 like that, right?
14 A. Yes.
15 Q. And on that bar area where people can come
16 anytime of day, you can sit there and just ask
17 whoever is there to prepare eggs or an omelet,
18 whatever you want, right?
19 A. That is correct, yes.
20 Q. And there are homemade buns and doughnuts
21 that are put on there every day, right?
22 A. Right.
23 Q. Anytime of day, 24 hours a day, you can go
24 into that main house and get what you want, correct?
25 A. That is correct, yes.
26 Q. Even when Mr. Jackson is upstairs with his
27 children, very often people will come downstairs to
28 either see the house or get something to eat, right? 4738
1 A. That is correct, yes.
2 Q. The prosecutor asked you about candy and ice
3 cream and stuff like that. That’s available to
4 everybody, isn’t it?
5 A. That is correct, yes.
6 Q. It’s not just available to children. It’s
7 available for adults as well, right?
8 A. That is correct, yes.
9 Q. And when you walk into that theater, you’ve
10 got a whole candy/ice cream area in the front,
11 right?
12 A. Yes.
13 Q. And typically, Mr. Jackson will have one of
14 his people there just to serve whatever people want,
15 right?
16 A. That is correct, yes.
17 Q. Ice cream sandwiches, ice cream cones,
18 right?
19 A. Whatever they prefer, yes.
20 Q. There’s a big popcorn area, correct?
21 A. Correct.
22 Q. And you will see sometimes visitors looking
23 at movies anytime of day, right?
24 A. That is correct, yes.
25 Q. And there’s a huge collection of movies they
26 can sometimes choose from, right?
27 A. Right.
28 Q. And other times there are just a couple that 4739
1 you can choose for the day, right?
2 A. That is correct, yes.
3 Q. Okay. There are other areas of Neverland
4 people want to see, right?
5 A. Right.
6 Q. There are areas where they can see Mr.
7 Jackson’s costumes that he’s worn on music tours,
8 right?
9 A. That is correct, yes.
10 Q. There are areas where they can see his
11 glove? Kids love to see the gloves he’s worn,
12 right?
13 A. That is correct, yes.
14 Q. In fact, some of the memorabilia from his
15 musical tours around the world are actually in an
16 area not far from the wine cellar; correct?
17 A. That is correct, yes.
18 Q. You also have sleeping bags stored down in
19 the area near where the wine cellar is, correct?
20 A. That is correct.
21 Q. Did you work there before Mr. Jackson
22 purchased the property?
23 A. Yes, I did.
24 Q. That wine cellar area was already there when
25 Mr. Jackson purchased the property, right?
26 A. Yes, it was.
27 Q. Now, there is a procedures manual at
28 Neverland that, at least on paper, identifies what 4740
1 people are supposed to do or not do, right?
2 A. That is correct.
3 Q. And security is a concern there, is it not?
4 A. Yes.
5 Q. Because if you really look at the perimeter
6 of Neverland, you can get in those fences, can’t
7 you?
8 A. Absolutely, yes.
9 Q. In fact, it’s -- it’s easy for anyone to go
10 in or out of those three-rail fences anytime, right?
11 A. Absolutely.
12 Q. And you’ve caught people on the property who
13 tried to get over to Neverland and find Mr. Jackson,
14 correct?
15 A. Many times.
16 Q. And there are roads around the property
17 where cars drive at high speeds, correct?
18 A. Yes.
19 Q. And there is also a concern that children
20 will somehow wander on the road, right?
21 A. That is correct, yes.
22 Q. Let me get back to Janet Arvizo.
23 Didn’t she complain one time that she felt
24 Frank and Vinnie were separating her from Michael
25 Jackson?
26 A. I don’t recall her telling me that, no.
27 Q. Did she complain that Dieter and Ronald were
28 separating her from Michael Jackson? 4741
1 A. Yes.
2 Q. She appeared not to like Dieter or Ronald at
3 all, right?
4 A. That is correct, yes.
5 Q. When Janet and the children would arrive on
6 the property, were they given assistance in
7 transporting their luggage to their rooms?
8 A. Absolutely.
9 Q. Who would help Janet transport her luggage
10 to her rooms?
11 A. Many times it was security, Neverland Valley
12 security, or myself.
13 Q. And would Janet pretty much tell you what to
14 carry from her car or however she got there?
15 A. No, not really.
16 Q. Who would assign the rooms to the Arvizos
17 when they visited and stayed at Neverland?
18 A. I did.
19 Q. And what would determine, for you, what room
20 to put them in?
21 A. It would depend. Many times we had some
22 other guests on the property. And if we have one
23 available, that was the only one that was going to
24 be for them. And many times I ask them, “Okay,
25 which room do you guys want to stay in?” So that’s
26 how I decided.
27 Q. Did anyone ever complain about the room that
28 they were placed in? 4742
1 A. No, not really.
2 Q. Did the kids ever complain?
3 A. No.
4 Q. The rooms they were placed in, as far as
5 you’re concerned, were all beautiful rooms, weren’t
6 they?
7 A. Yes, they are.
8 Q. They were cleaned every day, correct?
9 A. That is correct.
10 Q. And they had constant room service if they
11 wanted it, right?
12 A. That is correct. Yes.
13 Q. Mr. Jackson wanted them treated just as well
14 as any other guests, right?
15 MR. AUCHINCLOSS: Objection; asked and
16 answered.
17 THE COURT: Sustained.
18 Q. BY MR. MESEREAU: How many times, Mr. Salas,
19 has the prosecution contacted you to talk to you
20 about the case?
21 A. A couple times.
22 Q. And how many times did you meet with
23 representatives of the sheriff’s department?
24 A. A couple times.
25 Q. They never asked you if you ever brought
26 nonalcoholic beverages for the Arvizo children, did
27 they? They never asked you that question, did they?
28 A. No, they didn’t. 4743
1 Q. Now, I think you said that Michael Jackson
2 appeared frustrated at what Frank was doing on the
3 property from time to time, right?
4 A. That is correct. Yes.
5 MR. AUCHINCLOSS: Objection; misstates the
6 evidence.
7 MR. MESEREAU: I don’t think it does, Your
8 Honor.
9 THE COURT: Overruled. The answer was,
10 “Yes.” Next question.
11 Q. BY MR. MESEREAU: Michael Jackson was
12 frustrated that Frank was bringing guests to
13 Neverland without him knowing about it, right?
14 A. That is correct, yes.
15 Q. And how old was Frank at the time, do you
16 think?
17 A. I’m not sure how old was he. I will say he
18 was about, what, 35.
19 Q. Early twenties?
20 A. Somewhere around there, yes.
21 Q. To your knowledge, how was Frank able to
22 bring guests to the property without Michael Jackson
23 knowing about it?
24 MR. AUCHINCLOSS: Objection; foundation.
25 THE COURT: Overruled.
26 You may answer.
27 THE WITNESS: It was his own decision.
28 Q. BY MR. MESEREAU: But what would Frank do, 4744
1 if you know, to bring guests onto the property
2 without Michael Jackson knowing about it?
3 A. What he would do there?
4 Q. Yes.
5 A. Just have fun at Neverland.
6 Q. Oh, no, excuse me. I didn’t state it
7 properly. It’s my mistake.
8 If Frank wanted to bring guests onto the
9 property without Michael Jackson knowing about it,
10 what would he do?
11 A. He would just call security and tell -- let
12 security know that he had some guests coming in, or
13 tell me.
14 Q. Would he typically tell them that Michael
15 wants them visiting?
16 A. No, he never said that.
17 Q. He just said he wanted them to visit, right?
18 A. That is correct.
19 Q. Okay. And he would bring a number of female
20 guests from time to time, correct?
21 A. Correct.
22 MR. AUCHINCLOSS: Objection; relevance.
23 THE COURT: Overruled. The answer is,
24 “Correct.”
25 Q. BY MR. MESEREAU: In fact, he tried to bring
26 a lot of girls onto the property, didn’t he?
27 A. That is correct.
28 Q. He used to brag to them that he was a friend 4745
1 to Michael Jackson, right?
2 MR. AUCHINCLOSS: Objection. Hearsay;
3 relevance.
4 THE COURT: Sustained.
5 Q. BY MR. MESEREAU: Now, you mentioned someone
6 named Malnik visited the property one time, right?
7 A. Right.
8 Q. Did you speak to him?
9 A. Not in a conversation, no, I didn’t.
10 Q. You just saw him?
11 A. Just saw him, say hi. And that was it.
12 Q. The prosecutor mentioned someone named Zia,
13 right?
14 A. That’s correct. That is correct.
15 Q. Did you see Zia on the property?
16 A. Yes, I did.
17 Q. Did you talk to him?
18 A. Just for a short time. Not --
19 Q. And Zia was, to your knowledge, Mr.
20 Jackson’s attorney, right?
21 A. Yes.
22 Q. Did you see him there often?
23 A. No, I only saw him there a couple times.
24 Q. And what did you see him doing?
25 A. Just had a meeting with Mr. Jackson.
26 Q. Okay. You would see all kinds of people
27 visit from time to time to meet with Mr. Jackson,
28 right? 4746
1 A. Yes.
2 MR. AUCHINCLOSS: Objection; vague.
3 MR. MESEREAU: I’ll rephrase.
4 Q. The prosecutor has limited his questions to
5 you to Dieter, Ronald, Frank. Mr. Jackson didn’t
6 spend all of his time meeting with these people, did
7 he?
8 A. Not all the time, no.
9 Q. Mr. Jackson from time to time would have
10 numerous visitors to Neverland to see him, correct?
11 A. That is correct.
12 MR. AUCHINCLOSS: Objection; vague as to
13 time.
14 THE COURT: Overruled.
15 You may answer.
16 THE WITNESS: That is correct.
17 Q. BY MR. MESEREAU: You would often see a full
18 schedule of people visiting Neverland to see Mr.
19 Jackson, right?
20 MR. AUCHINCLOSS: Objection; foundation.
21 THE COURT: Overruled.
22 You may answer.
23 THE WITNESS: That is correct.
24 Q. BY MR. MESEREAU: Do you recall Mr. Jackson
25 doing work in his studio at Neverland?
26 A. Yes.
27 Q. And what do you recall seeing him doing?
28 A. Doing some recording. Dancing. Practicing. 4747
1 Yes.
2 Q. Did you watch him practice dance?
3 A. No, I didn’t.
4 Q. And how did you know he was practicing
5 dance? Would he tell you?
6 A. Right.
7 Q. And would he tell you not to let anyone in,
8 that he’s doing his creative work?
9 MR. AUCHINCLOSS: Objection; hearsay.
10 THE COURT: Overruled.
11 You may answer.
12 THE WITNESS: Because of his work, yes, he
13 did not want to be bothered, yes.
14 Q. BY MR. MESEREAU: Did you also see him
15 teaching kids how to dance from time to time?
16 A. I never saw that.
17 Q. Okay. How about in his recording studio,
18 would he bring kids and adults into his recording
19 studio to see it?
20 A. Yes, he did.
21 Q. And didn’t he used to show them how he does
22 his work in his recording studio?
23 A. Yes.
24 Q. And sometimes he wanted to just be left
25 alone in there, right?
26 A. That is correct. Yes.
27 Q. And when he wanted to be left alone, he’d
28 spend hours and hours in there, right? 4748
1 A. That’s correct, yes.
2 Q. Okay. Now, you would see Mr. Jackson awake
3 on his property at all different hours, right?
4 A. Yes.
5 Q. Sometimes he gets up at 3:00 in the morning,
6 doesn’t he?
7 A. That is correct, yes.
8 Q. And he will take walks alone on his
9 property, right?
10 A. That’s right.
11 Q. That’s how he does a lot of his composing,
12 right?
13 A. That is correct.
14 MR. AUCHINCLOSS: Objection; foundation.
15 THE COURT: Sustained.
16 Q. BY MR. MESEREAU: You’d also see Mr. Jackson
17 from time to time driving alone on his property,
18 right?
19 A. That is correct, yes.
20 Q. Would you know in advance if Mr. Jackson was
21 going to leave the property to go somewhere?
22 A. Yes.
23 Q. And who would you -- who would tell you that
24 Mr. Jackson was leaving the property?
25 A. Sometimes I found out about -- by his
26 bodyguard.
27 Q. Okay. And what are some of the other ways
28 that you would find out Mr. Jackson might be either 4749
1 leaving the property or going out of town?
2 A. By Mr. Jackson.
3 Q. Okay. Did you speak to Mr. Jackson every
4 day when he was there?
5 A. Pretty much, yes.
6 Q. When he wasn’t there, who would you speak
7 to?
8 MR. AUCHINCLOSS: Objection. Ambiguous;
9 relevance.
10 THE COURT: Overruled.
11 THE WITNESS: When he wasn’t there, well,
12 nobody is -- the ranch manager.
13 Q. BY MR. MESEREAU: Let me ask you this: When
14 Mr. Jackson’s out of town, which you saw him do
15 quite often during your 20 years there, right?
16 A. Right.
17 Q. You saw him go on music tours, right?
18 A. That is correct.
19 Q. And you saw him travel to various cities in
20 America, right?
21 A. Yes.
22 Q. And he would travel to various cities around
23 the world, right?
24 A. Yes.
25 Q. When he’s not there, does the place pretty
26 much run the way it runs when he’s there?
27 A. It runs the same way.
28 Q. And that’s because there are various 4750
1 procedures in effect to make sure it runs properly,
2 correct?
3 A. That is correct, yes.
4 Q. When Mr. Jackson’s there, he’s not walking
5 around the property just running everything, is he?
6 A. No, no.
7 Q. In fact, very often when he’s there, you
8 hardly see him, right?
9 A. That is correct, yes.
10 Q. Because Mr. Jackson is doing his creative
11 work for hours and hours on end, right?
12 A. Correct.
13 Q. So how does the place sort of run when he’s
14 not there? I mean, if you can explain it.
15 A. Because of the people in charge of running
16 the place, so we’ll -- the place always running the
17 same, so -- whether he’s there or not.
18 Q. And even if he’s there, you have to report
19 to other individuals to get information, don’t you?
20 A. That is correct, yes.
21 Q. Okay. So when the prosecutor asked you
22 about your reporting directly to Michael Jackson,
23 you didn’t mean you’re talking to him all day about
24 what’s going on?
25 A. No.
26 Q. And if you report to him on a given day, it
27 might be just one time, right?
28 A. That is correct, yes. 4751
1 Q. Okay. In response to the prosecutor’s
2 questions, you mentioned some things about Frank
3 saying he’ll take care of things, correct?
4 A. Correct, yes.
5 Q. But Frank also used to brag about how close
6 he was to Michael Jackson, didn’t he?
7 A. Right.
8 Q. You didn’t get the impression he was always
9 telling the truth, did you?
10 MR. AUCHINCLOSS: Objection; calls for a
11 conclusion.
12 THE COURT: Sustained.
13 Q. BY MR. MESEREAU: You said, in response to
14 the prosecutor’s questions, that on occasion you
15 would see Frank and Michael Jackson together, right?
16 A. Right.
17 Q. But you also often saw Frank not around Mr.
18 Jackson, correct?
19 A. Oh, yes.
20 Q. And you often saw Mr. Jackson without Frank,
21 right?
22 A. That is correct, yes.
23 Q. And you didn’t really know what work Frank
24 was doing, correct?
25 A. That is correct, yes.
26 Q. But from time to time, he would try and brag
27 that he was in the music business, right?
28 A. Correct. 4752
1 MR. AUCHINCLOSS: Objection; hearsay.
2 THE COURT: Sustained.
3 Q. BY MR. MESEREAU: I want to ask you a little
4 more about security at Neverland, okay? It’s about
5 2800 acres of property, right?
6 A. Uh-huh.
7 Q. Very spread out over hills, right?
8 A. Yes.
9 Q. And it’s surrounded by these fences that you
10 said anybody could come in, right?
11 A. That is correct, yes.
12 Q. You have a front gate that you have to stop
13 at if you’re driving in, right?
14 A. Correct.
15 Q. And you have to push a button and identify
16 who you are, right?
17 A. That is correct, yes.
18 Q. And people at that security gate typically
19 have a list of who’s supposed to be allowed in,
20 right?
21 A. Right.
22 Q. And I think what you said is that Frank
23 would often call the people at that gate and say,
24 “Let so and so in,” right?
25 A. That is correct, yes.
26 Q. Okay. Now, you did indicate there had been
27 efforts by people to drive and get onto the property
28 and find Mr. Jackson, right? 4753
1 A. Right.
2 Q. And you have some security guards who patrol
3 the property a bit, right?
4 A. Correct.
5 Q. And they don’t have weapons, right?
6 A. Not to my knowledge.
7 Q. Because Michael Jackson doesn’t want weapons
8 on his property, right?
9 A. Correct.
10 MR. AUCHINCLOSS: Objection. Foundation;
11 hearsay.
12 THE COURT: Sustained.
13 Q. BY MR. MESEREAU: Do you know whether or not
14 Mr. Jackson has a policy that he doesn’t want
15 weapons on his property?
16 A. Yes, I do.
17 Q. And he’s typically very concerned about his
18 children’s safety, correct?
19 A. That is correct.
20 Q. You said that Frank was staying in the video
21 library, right?
22 A. Correct.
23 Q. And was there a bed in there?
24 A. It’s a couch that turns into a bed, yes.
25 Q. Is that where he would stay when he visited?
26 A. Correct.
27 Q. There were long periods of time Frank wasn’t
28 even there, right? 4754
1 MR. AUCHINCLOSS: Objection as to -- vague
2 as to time.
3 Q. BY MR. MESEREAU: Let’s go to 2003.
4 I’ll rephrase it, Your Honor.
5 THE COURT: All right.
6 Q. BY MR. MESEREAU: Let’s take the year 2003.
7 There were periods of time you wouldn’t even see
8 Frank on the property, right?
9 A. There was some times, yes.
10 Q. And there are times you would also see him,
11 correct?
12 A. Correct. Yes.
13 Q. There were times you would see Dieter on the
14 property, right?
15 A. Correct.
16 Q. And there were times you wouldn’t see him at
17 all, right?
18 A. Correct. Yes.
19 Q. There were times you’d see Ron on the
20 property, correct?
21 A. That is correct. Yes.
22 Q. And there were times you wouldn’t see him at
23 all?
24 A. Right.
25 Q. And during this period of time, you had your
26 constant visitors on a daily basis to the property,
27 correct?
28 A. Yes. 4755
1 Q. You had many other people who had scheduled
2 meetings with Michael Jackson, right?
3 A. Right. Yes.
4 Q. And you also had your periodic tours of
5 children and adults to Neverland, right?
6 A. That is correct, yes.
7 Q. You indicated that you think that Mr.
8 Jackson was at Neverland when the Arvizos visited in
9 2003, right?
10 A. Right.
11 Q. You’re not sure that he was there every day,
12 though, are you?
13 A. That is right, yes.
14 Q. If there were days he wasn’t there when the
15 Arvizos were there in 2003, you’re just not sure,
16 correct?
17 That’s a bad question. Let me -- I don’t
18 think I could answer that one.
19 In 2003 when the Arvizos were at Neverland,
20 sometimes Michael Jackson was there and sometimes he
21 wasn’t, right?
22 A. That is correct. There was days that he was
23 not there, yes.
24 Q. There were times he was out of town, right?
25 A. Right.
26 Q. There were times he was gone from the
27 premises during the day, right?
28 A. That is correct, yes. 4756
1 Q. There were times he was in his studio,
2 right?
3 A. That is correct, yes.
4 Q. There were times he was doing his dance
5 routines, correct?
6 A. Correct.
7 Q. There were times he was taking children
8 around Neverland on a tour, right?
9 A. Correct, yes.
10 Q. And there would be constant meetings of one
11 form or another involving Michael Jackson with other
12 people, correct?
13 A. That is correct, yes.
14 Q. Okay. The prosecutor asked you about
15 Michael Jackson playing with kids. Michael Jackson
16 plays with kids all the time at Neverland, doesn’t
17 he?
18 A. Yes, he does.
19 Q. He often acts like a kid himself, doesn’t
20 he?
21 A. Yes.
22 Q. And he takes pride particularly in bringing
23 inner city kids to Neverland to have fun, doesn’t
24 he?
25 A. Correct. Yes.
26 Q. We’re talking about kids from poverty, kids
27 from broken homes, right?
28 A. That is correct, yes. 4757
1 Q. He sometimes personally arranges those
2 visits himself, doesn’t he?
3 MR. AUCHINCLOSS: Objection; foundation.
4 THE COURT: Sustained.
5 Q. BY MR. MESEREAU: Do you know whether or not
6 Michael Jackson sometimes personally arranges visits
7 by kids to Neverland?
8 A. Yes.
9 Q. And typically when these busloads of kids
10 get to Neverland, they all want to see Michael
11 Jackson, right?
12 A. Correct.
13 Q. And sometimes you schedule all these kids
14 and these adults to be at a certain location to wait
15 for Michael to come out and see them, right?
16 A. That is correct.
17 MR. AUCHINCLOSS: I’ll object as cumulative.
18 THE COURT: Overruled.
19 Q. BY MR. MESEREAU: Isn’t that true?
20 A. That is correct, yes.
21 Q. And he would call you and arrange to have
22 toys available for all these kids when they would
23 visit, right?
24 A. Correct.
25 Q. And you would typically have all the kids
26 assemble on the property, and staff would start
27 distributing toys to them, right?
28 A. That is correct, yes. 4758
1 Q. And very often in the middle of the toy
2 distribution, Michael comes out to see the kids,
3 right?
4 A. On some occasion, yes.
5 Q. And you’ll see them running to Michael.
6 They want to see him; they want to touch him, right?
7 A. Correct.
8 Q. The adults will do the same, correct?
9 A. Correct, yes.
10 Q. Now, the prosecutor asked you what these
11 children do at Neverland, and you talked about bike
12 riding.
13 A. Yes.
14 Q. What did you mean by bike riding?
15 A. He’s got so many toys, they can just take
16 off on the quad-runners, scooters. That’s what I
17 meant.
18 Q. And you never got the impression Michael
19 Jackson was supervising the bike riding, did you?
20 A. No.
21 Q. People on the property who worked for Mr.
22 Jackson take care of that, don’t they?
23 A. Especially security, yes.
24 Q. And also you expect the parents or the
25 adults in charge to have some responsibility, right?
26 A. Yes.
27 Q. You talked about quads, okay. And what did
28 you mean by that? 4759
1 A. They have those four-wheelers that they can
2 go off, off the road. That’s --
3 Q. And they typically ride on the roads at
4 Neverland, right?
5 A. Yes.
6 Q. And who supervises that, typically?
7 A. Oh, themself. Themselves or security.
8 Q. You have never thought Michael Jackson was
9 walking around supervising who got into those
10 vehicles, did you?
11 A. No, no.
12 Q. He doesn’t seem to supervise any of that,
13 does he?
14 A. No, he doesn’t.
15 Q. Okay. He assumes staff on the premises
16 will, right?
17 MR. AUCHINCLOSS: Objection. Objection. No
18 foundation, as to what Mr. Jackson assumes. Calls
19 for speculation.
20 THE COURT: Sustained.
21 Q. BY MR. MESEREAU: You told the prosecutor
22 that sometimes Michael Jackson would play with kids
23 on a daily basis, right?
24 A. That is correct, yes.
25 Q. And you would see him playing with kids all
26 over the premises, right?
27 MR. AUCHINCLOSS: Objection; asked and
28 answered. 4760
1 THE COURT: Sustained.
2 Q. BY MR. MESEREAU: Did you see Michael
3 Jackson take these kids to the petting zoo?
4 A. Yes.
5 Q. Did you see him take them to the bigger zoo?
6 A. Yes.
7 Q. Did you see him take them to the arcade?
8 A. Yes.
9 Q. Did you see him take them to the theater?
10 A. Yes.
11 Q. How about ride with them on the train?
12 A. Correct.
13 Q. Okay. This went on all the time, didn’t it?
14 A. That is correct, yes.
15 Q. Now, the prosecutor asked you questions
16 about Mr. Jackson appearing intoxicated, okay?
17 A. Right.
18 Q. Now, you never saw him drinking, right?
19 A. No, I didn’t.
20 Q. And were you aware that there were times
21 when he had a prescription drug problem?
22 A. Yes, I -- yes, I was.
23 Q. And he had gotten a lot of injections from
24 various physicians?
25 A. That is correct, yes.
26 MR. AUCHINCLOSS: Objection; foundation.
27 THE COURT: Sustained.
28 Q. BY MR. MESEREAU: Did you know Michael 4761
1 Jackson had -- excuse me, let me rephrase. Did you
2 know whether or not Mr. Jackson at various times had
3 a prescription drug problem?
4 A. Yes, I did.
5 Q. And did you know he was treated for that?
6 A. Yes.
7 Q. When you saw him appearing intoxicated, you
8 don’t know what the cause was, correct?
9 A. That is correct, yes.
10 Q. You knew he had suffered severe burns on his
11 body, didn’t you?
12 MR. AUCHINCLOSS: Objection. Foundation;
13 relevance.
14 THE COURT: Foundation; sustained.
15 Q. BY MR. MESEREAU: Did you know whether or
16 not, during one entertainment event, Mr. Jackson
17 suffered severe burns all over his body?
18 MR. AUCHINCLOSS: Ob -- I’ll --
19 THE WITNESS: Yes.
20 Q. BY MR. MESEREAU: Did you know he was being
21 treated for that?
22 MR. AUCHINCLOSS: Objection; vague as to
23 time.
24 THE COURT: Sustained.
25 Q. BY MR. MESEREAU: Did you know whether or
26 not Mr. Jackson was being treated by physicians with
27 medication because he’d been badly burned?
28 MR. AUCHINCLOSS: Objection; vague as to 4762
1 time.
2 Q. BY MR. MESEREAU: At any time?
3 A. Yes.
4 Q. That was common knowledge at Neverland, was
5 it not?
6 MR. AUCHINCLOSS: I’ll object and move to
7 strike the last answer. Still vague as to time.
8 THE COURT: Stricken.
9 Q. BY MR. MESEREAU: During the year 2002, were
10 you aware -- excuse me. During the year 2002, do
11 you know whether or not Michael Jackson was being
12 treated by various physicians for health problems?
13 MR. AUCHINCLOSS: Objection. Vague as to
14 “health problems.”
15 THE COURT: Overruled.
16 You may answer.
17 MR. AUCHINCLOSS: I’ll object as to
18 foundation.
19 THE COURT: The answer -- the question calls
20 for a “yes” or “no” answer. You may answer.
21 THE WITNESS: Yes.
22 Q. BY MR. MESEREAU: And during the year 2002,
23 were you aware that Mr. Jackson --
24 MR. AUCHINCLOSS: Objection to the form of
25 the question. “Were you aware” assumes facts.
26 THE COURT: You have to let him finish the
27 question.
28 Q. BY MR. MESEREAU: During the year 2002, were 4763
1 you aware -- excuse me. During the year 2002, did
2 you know whether or not Mr. Jackson was taking
3 medications for a broken leg?
4 A. Yes.
5 Q. During the year 2002, did you know whether
6 or not Mr. Jackson was taking medications for a foot
7 problem?
8 A. Yes.
9 Q. And during the year 2002, did you know
10 whether or not Mr. Jackson had recurring problems
11 because he had been badly burned?
12 A. Yes.
13 Q. During the year 2002, did you know whether
14 or not Mr. Jackson had back problems?
15 A. Yes.
16 MR. AUCHINCLOSS: I’m going to object as to
17 foundation.
18 THE COURT: Sustained.
19 Q. BY MR. MESEREAU: During the year 2003, did
20 you know whether or not Mr. Jackson was taking
21 prescription drugs for a leg problem?
22 MR. AUCHINCLOSS: Objection; foundation.
23 THE COURT: Sustained.
24 Q. BY MR. MESEREAU: Do you know whether or not
25 Mr. Jackson took prescription drugs in the year 2003
26 while you were working there?
27 MR. AUCHINCLOSS: Objection; foundation.
28 THE COURT: Overruled. 4764
1 THE WITNESS: Yes.
2 Q. BY MR. MESEREAU: Do you recall seeing Mr.
3 Jackson’s children in his bedroom?
4 A. Yes.
5 Q. They would be in there a lot during the time
6 you worked there, right?
7 A. That is correct, yes.
8 Q. You would see his children at the lower
9 level, right?
10 A. Correct.
11 Q. You would see them in his bedroom upstairs,
12 right?
13 A. Correct, yes.
14 Q. Did you typically spend much time with Mr.
15 Jackson’s children?
16 A. I would say I didn’t spend too much time
17 with them because -- but saw them, I mean, every day
18 there, yes.
19 Q. Every day?
20 A. Yes.
21 Q. And you would mainly see them in the main
22 house?
23 A. Yes.
24 Q. Would you see them on the property also?
25 A. Yes.
26 Q. But you saw them in his room quite often,
27 didn’t you?
28 A. Yes. 4765
1 Q. Do you know anything about an alarm system
2 that one has to use to get into Mr. Jackson’s
3 bedroom?
4 MR. AUCHINCLOSS: Objection; vague as to
5 “one has to use” an alarm system.
6 THE COURT: Overruled.
7 You may answer.
8 THE WITNESS: Yes.
9 Q. BY MR. MESEREAU: And have you set off that
10 alarm from time to time?
11 A. No, not really.
12 Q. Have you heard the alarm go off?
13 A. No.
14 Q. Okay. Do you know much about that alarm
15 system?
16 A. I know about it, but I -- you know, not --
17 didn’t get involved in that too much.
18 Q. It’s not something that you would typically
19 handle?
20 A. No.
21 Q. Okay. Okay. Have you seen Mr. Jackson
22 entertain adults at his home in the evening?
23 A. Oh, yes.
24 Q. He does that quite often, doesn’t he?
25 A. That is correct, yes.
26 Q. And when he does that, you often see adults
27 drinking alcohol, don’t you?
28 A. Right. 4766
1 Q. You see staff serving them alcohol, right?
2 A. That’s correct.
3 Q. And they’re free to go into the kitchen area
4 and grab alcohol if they want to, typically, right?
5 A. That is correct, yes.
6 Q. You’ve also seen them served alcohol in his
7 bedroom, correct?
8 A. Correct.
9 Q. You’ve seen adults sitting in the lower
10 level of his bedroom drinking, right?
11 A. That is correct, yes.
12 Q. And typically there would be an order placed
13 by someone, and staff will bring alcohol into his
14 bedroom for that purpose, right?
15 A. Right.
16 Q. Okay. Now, the prosecutor asked you about
17 complaints involving kids in the wine cellar, right?
18 A. Right.
19 Q. During the 20 years you worked at Neverland,
20 that area you call the wine cellar was always a wine
21 cellar, was it not?
22 A. That is correct, yes.
23 Q. And this is the area that you said, close
24 by, has an area which has Mr. Jackson’s memorabilia
25 from tours around the world, right?
26 A. Correct, yes.
27 Q. And in that area nearby is where you can see
28 his costumes, his gloves, and things of that sort, 4767
1 right?
2 A. That is correct, yes.
3 Q. And typically kids and adults want to go
4 there and see all these costumes from his very
5 successful music career, right?
6 A. That is right, yes.
7 Q. And once in a while, somebody will bring
8 people down to that cellar area so they can see all
9 that memorabilia, right?
10 A. Right.
11 MR. AUCHINCLOSS: Objection. Misstates the
12 evidence that the memorabilia is in the cellar area.
13 MR. MESEREAU: That’s what he testified to,
14 Your Honor.
15 THE COURT: No, it’s not. Rephrase your
16 question.
17 MR. MESEREAU: Yes, sir.
18 Q. Let’s take the area that we’ve identified as
19 the wine cellar, okay? You got to go down the
20 stairs to get there, right?
21 A. Right, yes.
22 Q. When you get down those stairs, where do you
23 see the wine cellar when you reach the foot of the
24 stairs?
25 A. It’s on the wall. Placed on the wall.
26 Q. There are other areas around the wine cellar
27 which have other purposes in the house, right?
28 A. Right. 4768
1 Q. And doesn’t one of those areas have
2 costumes, gloves, and memorabilia from Mr. Jackson’s
3 tours?
4 A. Not specifically in that area.
5 Q. Well, it’s not far away, though, right?
6 A. It’s outside there.
7 Q. But you can certainly -- from time to time,
8 he has stored stuff there, hasn’t he?
9 A. Yes. I would say that, yes.
10 Q. And sometimes people have gone down to look
11 at that stuff, right?
12 A. That is correct, yes.
13 Q. And there’s some other areas at Neverland
14 where that stuff is stored as well, right?
15 A. The main part, yes.
16 Q. Because there’s a ton of stuff.
17 A. Yes.
18 Q. From a long, successful career.
19 A. Yes.
20 Q. Now, during the 20 years you’ve been at
21 Neverland, there have been very few complaints about
22 children being in the wine cellar, right?
23 A. That is correct.
24 Q. You’re talking about maybe a couple over a
25 20-year period, right?
26 A. That is correct, during my time there, yes.
27 Q. Mr. Jackson’s policy is not to let kids in
28 the wine cellar, right? 4769
1 A. That is correct, yes.
2 Q. The prosecutor talked about young boys from
3 Los Olivos, and you identified their pictures,
4 right?
5 A. Right.
6 Q. And you’ve seen them there with their
7 parents from time to time, haven’t you?
8 A. No, not with their parents.
9 Q. The parents have visited?
10 A. Yes, yes.
11 Q. But they also have come from time to time on
12 their own, correct?
13 A. Themself, yes.
14 Q. And they’ve come from time to time when Mr.
15 Jackson wasn’t even there, right?
16 A. That is correct, yes.
17 Q. And people on the property know them,
18 correct?
19 A. Correct.
20 Q. And generally nobody objects to their
21 visiting Neverland, right?
22 A. That is correct, yes.
23 Q. They sometimes come alone and they sometimes
24 come with their parents, right?
25 A. Yes.
26 Q. They’re really neighbors, aren’t they?
27 A. Yes.
28 Q. And once in a while they’ve gotten into some 4770
1 trouble there, correct?
2 A. That is correct, yes.
3 Q. They’ve been known as mischievous kids,
4 right?
5 A. Right.
6 Q. They’ve been caught in various places around
7 Neverland, haven’t they?
8 A. That is correct, yes.
9 Q. They’ve been caught in rooms, true?
10 A. Correct.
11 Q. They were caught playing hide-and-seek in
12 the house, weren’t they?
13 A. Right, yes.
14 Q. Now, if you catch kids playing hide-and-seek
15 in the house or getting into trouble, typically what
16 do you do?
17 A. Well, you try to explain to them that -- you
18 know, if you caught them doing something they’re not
19 supposed to be doing, you just let them know that,
20 you know, that’s not what they should be -- you
21 know, that there’s some certain things that, you
22 know, they’re allowed to do, there’s things that
23 they’re not allowed to do, so we let them know.
24 Q. But like -- let’s take these kids from Los
25 Olivos that are neighbors who are allowed on the
26 property, and sometimes their parents aren’t there.
27 Who kind of watches them when they come alone?
28 A. Pretty much nobody. They’re on their own. 4771
1 Q. Do people on the property keep an eye on
2 them, or what happens?
3 A. Well, you know, I would say yes, security,
4 just for safety reasons, yes. Or the staff
5 personnel if they’re at the amusement park, yes.
6 Q. If they go into the main house, which they
7 do from time to time, who would be in the main house
8 typically, who might see them?
9 A. I would say that will be the maids, the
10 cooks, yes. Or myself.
11 Q. And if they start going upstairs into the
12 bedrooms, who are they likely to run into?
13 A. Well, they’ll run into the doors. They
14 can’t go in.
15 Q. Besides the doors, who might they see? Will
16 they see the people who are cleaning?
17 A. Yes, they might run into maids or somebody
18 else from the house staff. Yes.
19 Q. And how many kids are we talking about?
20 A. We’re talking about the --
21 Q. Three?
22 A. Three kids, yes.
23 Q. All right. And how long have they been
24 coming onto the property, to your knowledge? Excuse
25 me, let me rephrase that.
26 When you were working there, for how long a
27 period of time do you remember their coming freely
28 on and off the property? 4772
Subject: April 4, 2005 
Fri Mar 16, 2012 4:59 am
