1 patrol and worked my way up. I was the DARE officer
2 and school resource officer. And then I went on
3 into detectives. And during that time in
4 detectives, I was specializing in sexual assault and
5 child abuse cases.
6 Q. All right. Let’s stop there for just a
8 How long did you actually work in the
9 specialty of child abuse and sexual assault cases
10 for children.
11 A. Approximately five years.
12 Q. Now, did you have any special training or
13 preparation for that role as a detective on those
14 kinds of sensitive cases.
15 A. Yes, I have.
16 Q. All right. Would you explain that to the
17 ladies and gentlemen of the jury, please.
18 A. Yes, I’ve had numerous hours of education
19 through forensic interviewing, which was
20 approximately 80 hours. Child abuse and recognition
21 training, which was approximately 40 hours. I ended
22 up actually giving some training courses in forensic
23 interviewing classes, assisting other agencies in
24 that respect.
25 I’ve also -- excuse me just for a second. I
26 got to refer to my notes here.
27 Interviewing -- child abuse interviewing
28 techniques with children. And also an 80-hour 2143
1 sexual assault investigation course.
2 MR. SANGER: Your Honor, I’m going to object
3 for a moment to the witness interviewing (sic) his
4 notes, and -- I don’t think there was a basis for
5 it, but also I don’t believe I’ve seen those notes.
6 If I could have an opportunity to look at them, I
7 would appreciate it.
8 THE COURT: All right. You may approach the
10 MR. SANGER: Thank you.
11 MR. SNEDDON: Okay.
12 MR. SANGER: Thank you, Your Honor.
13 THE COURT: Your objection was he was looking
14 at notes without --
15 MR. SANGER: Without an adequate foundation.
16 THE COURT: Without a foundation. Is that
17 objection still being made after looking at the
19 MR. SANGER: Well, I’ll withdraw it as to
20 that question, but I would in the future make the
21 same objection.
22 THE COURT: All right. Did we finish that
24 MR. SNEDDON: I believe I did.
25 Q. Were you finished telling them about your
26 training and expertise in that area.
27 A. Yes, I am.
28 Q. Okay. Sergeant Robel, at some point in time 2144
1 were you assigned as the lead investigator into the
2 case against the defendant in this case, Michael
4 A. Yes, I was.
5 Q. And approximately, if you recall, what time
6 was it that you were assigned that particular
8 A. I want to say I believe it was around the
9 middle -- around the 20th or so of June of 2003.
10 Q. Now, at that time, who was the person that
11 you were reporting directly to.
12 A. That was Lieutenant Jeff Klapakis.
13 Q. The previous witness.
14 A. Correct.
15 Q. And was Paul Zelis, Detective Zelis, a part
16 of that particular investigative team.
17 A. Yes, he was.
18 Q. And did he work under your supervision.
19 A. Correct.
20 Q. Now, at some point did you participate in an
21 interview of the members of the Arvizo family.
22 A. Yes, I did.
23 Q. Would you tell the ladies and gentlemen of
24 the jury, when was the first occasion that you
25 interviewed the Arvizo family.
26 A. I believe it was on July 7th of 2003.
27 Q. Now, when I said “members of the Arvizo
28 family,” what -- what individuals within that family 2145
1 do you recall having interviews with.
2 A. Janet Arvizo, Star Arvizo, Gavin Arvizo, and
3 Davellin Arvizo.
4 Q. Now, the ladies and gentlemen of the jury
5 have heard testimony previously this morning -
6 actually, I guess you have too, most of the time you
7 were here - about the fact that there was a report
8 that Detective Flaa had obtained about the interview
9 between the Los Angeles social workers and the
10 Arvizo family. Do you recall that.
11 A. Yes, I do.
12 Q. Now, prior to the time that you interviewed
13 the family in July of 2003, were you familiar with
14 the contents of that report.
15 A. I was familiar with Detective Flaa’s report.
16 I read that. And also Detective Zelis’s phone
17 review of Dr. Katz.
18 Q. So you were familiar with both of those
19 before you actually interviewed the family.
20 A. Correct.
21 Q. And were you familiar with the fact that as
22 a result of the interview with the Los Angeles
23 social workers back on February 20th of 2003, that
24 your department had conducted an initial
26 A. Yes. After reading the report, I did
27 conclude that, yes.
28 Q. And that it had been closed. 2146
1 A. Correct.
2 Q. Now, did you conduct an interview with -- or
3 when did you conduct the first interview that you
4 had with Star Arvizo. Do you recall exactly what
5 date that was.
6 A. I believe it was Monday, July 7th.
7 Q. Do you recall where that was.
8 A. 2003. That was conducted in Santa Barbara
9 County, at our common interview place in Santa
11 Q. So would that be in the south part of the
13 A. That is correct.
14 Q. Was that interview tape-recorded, or
16 A. Yes, it was.
17 Q. And was a transcription of that
18 tape-recording made.
19 A. Yes.
20 Q. And you’ve had a chance to review both of
22 A. Correct.
23 Q. Now, with regard to Star Arvizo’s
24 interview - okay. --
25 A. Yes.
26 Q. -- during the course of that interview, how
27 many incidents did Star tell you in which he was
28 standing on the stairs that he saw Michael Jackson 2147
1 molest his brother Gavin.
2 A. Two.
3 Q. During that interview on July 7th of 2003,
4 did Star make statements to you about describing a
5 third incident that he had seen involving the
6 defendant, Michael Jackson, and his brother Gavin.
7 A. Yes, he did.
8 Q. And what did he say in that connection.
9 A. He told me --
10 MR. SANGER: Objection. Objection; hearsay.
11 THE COURT: Sustained.
12 MR. SNEDDON: Your Honor, it’s a prior
13 consistent statement. It’s admissible under the
14 Evidence Code. Counsel has -- I won’t say anything
15 else, but I --
16 THE COURT: Let me think for a moment.
17 MR. SNEDDON: Yeah.
18 THE COURT: Counsel approach, please.
19 (Discussion held off the record at sidebar.)
20 THE COURT: All right. The objection is
21 overruled. You may --
22 Q. BY MR. SNEDDON: Okay. Let’s go back just a
23 second, Sergeant Robel.
24 You had a videotaped conversation with Star
25 Arvizo on July 7th of 2003, correct.
26 A. Correct.
27 Q. And in that conversation, Star Arvizo
28 indicated to you that he had seen two incidents 2148
1 while standing on the stairwell where he saw the
2 defendant, Michael Jackson, molest his brother
3 Gavin, correct.
4 A. That’s correct.
5 Q. Now, during the course of that conversation,
6 did Star Arvizo relate to you a third incident in
7 which he had seen the defendant in this case,
8 Michael Jackson, touch his brother inappropriately.
9 A. Yes, he did.
10 Q. All right. Would you tell the ladies and
11 gentlemen of the jury what he told you.
12 A. Star told me that when he was up in
13 Michael’s bedroom, he was lying on what he described
14 as a couch-type setting, possibly a futon, and he
15 was -- pretended like he was sleeping.
16 And Michael came up into the bedroom and
17 crawled into bed where his brother Gavin was
18 sleeping. And when he got into bed, he scooted up
19 next to him, Mr. Jackson did, to Gavin, and started
20 moving back and forth.
21 And Star observed that, and he basically
22 pretended like he was sleeping at that time.
23 Q. Now, during the time that you were doing
24 these interviews, did you also have an interview
25 with Gavin Arvizo.
26 A. Yes, I did.
27 Q. And what date did that occur.
28 A. That was -- that would also have been on 2149
1 Monday, July 7th, 2003.
2 Q. And would that have been at the same
4 A. Yes, it was.
5 Q. And during this conversation, who else was
6 present besides you and Gavin.
7 A. It would have been Detective Zelis.
8 Q. And with regard to the previous interview
9 with Star, was Detective Zelis present then also.
10 A. That is correct.
11 Q. Now, in the conversation that you had with
12 Gavin Arvizo on the 7th of July of 2003, did
13 Gavin -- excuse me. Sorry, Counsel.
14 MR. SANGER: That’s all right.
15 Q. BY MR. SNEDDON: Did Gavin Arvizo indicate
16 to you the time frame as to when he thought that he
17 had been molested by the defendant in this case, Mr.
19 A. Yes, he did.
20 Q. And what did he tell you.
21 A. He told me it was towards the end of his
22 stay at Neverland.
23 Q. Now, after that interview on July 7, did you
24 have another interview with Gavin Arvizo.
25 A. Yes, I did.
26 Q. And when did that occur.
27 A. I believe that was August 13th of 2003.
28 Q. And in that interview, did the subject of 2150
1 the timing of when Mr. Jackson molested him come up.
2 A. Yes, it did.
3 Q. And what did he indicate to you on that
5 A. Again, he stated that it was towards the end
6 of his stay at Neverland.
7 Q. All right. Let’s shift gears here for a
8 second. I need to grab some water.
9 Okay. In November of 2003, you were part of
10 a number of people who executed a search warrant on
11 Neverland Valley Ranch, correct.
12 A. That is correct.
13 Q. And do you remember what date that was.
14 A. I believe it was November 18th, 2003.
15 Q. And were you, as the lead investigator,
16 involved in overseeing the preparation of the
17 affidavit in support of the search warrant that was
18 eventually submitted to the Judge to get
19 authorization for that search warrant.
20 A. Yes, I was.
21 Q. And in that connection, did you have a
22 recommendation or a desire with regard to how long
23 you thought the search of the ranch would take.
24 A. Yes, I did.
25 MR. SANGER: I’m going to object; relevance.
26 His state of mind.
27 THE COURT: Well, the objection’s sustained,
28 because you said “recommendation or a desire.” 2151
1 MR. SNEDDON: Okay. I’ll rephrase it. It’s
3 Q. With regard to the length of the time that
4 you thought that the search would take at Neverland
5 Valley Ranch, what was your desire with regard to
6 requesting judicial authorization as to the time
8 MR. SANGER: I’m going to object again.
10 THE COURT: Overruled.
11 I’m going to -- you know, “desire” is the
12 word that bothers me here. If you had a
13 recommendation, that’s what I would like to hear, as
14 opposed to his private desires.
15 MR. SNEDDON: Well, okay. It’s probably a
16 bad choice of words, then.
17 Q. In your conversations -- let me ask you
18 this: Who was the attorney you were dealing with in
19 the preparation of the affidavit for the search
21 A. It would have been Tom Sneddon.
22 Q. Me.
23 A. Yeah.
24 Q. Okay. And in the course of working with me
25 on that document, the affidavit in support of the
26 search warrant, did you have a recommendation that
27 you made with regard to the length of time that you
28 wanted to be on the ranch to execute that warrant. 2152
1 MR. SANGER: Objection. Calls for hearsay
2 and relevance.
3 THE COURT: Well, what is the relevance,
5 MR. SNEDDON: Judge, the relevance is the
6 amount of people that it took to do it, because --
7 THE COURT: All right. I’ll overrule the
9 Q. BY MR. SNEDDON: What was your -- what was
10 your request and recommendation.
11 A. I was requesting that we have authorization
12 to be on the ranch for two to three days.
13 Q. And was that request granted.
14 A. No, it was not.
15 Q. Who denied it.
16 A. You did.
17 Q. And what did I tell you in that connection.
18 MR. SANGER: Your Honor, I’m going to object
19 to that. That calls for hearsay. And I’m going to
20 move to strike the prior questions and answers on
21 the ground that this is not relevant.
22 THE COURT: The objection as to hearsay is
24 MR. SNEDDON: All right.
25 Q. In any case, when the warrant went to the
26 Judge for signature, the warrant provided for how
27 long that you could be on the property.
28 A. I believe it was approximately 24 hours or 2153
1 till midnight, I believe, of that day.
2 Q. Midnight of the day you executed it.
3 A. Correct. I believe it was midnight we had
4 to be out.
5 Q. What was the impact of the shorter time
6 frame than you requested on the decisions of how the
7 execution -- how the warrant was executed on the
8 ranch that day.
9 A. Well, it caused us to reevaluate our initial
10 plan and how many personnel that we were going to
11 take onto the ranch, which in turn caused us to
12 bring more personnel in order to get the job done
13 within the parameters of time that we were
15 Q. Now, do you know an attorney by the name of
16 Jerry Franklin.
17 A. Yes, I do.
18 Q. Who’s Mr. Franklin.
19 A. He’s a Senior Deputy D.A. with Santa Barbara
21 Q. Was Mr. Franklin on the ranch that day, the
22 day that the warrant was executed.
23 A. Yes, he was.
24 Q. And did you, in your capacity as the lead
25 investigator, have some interactions with Mr.
26 Franklin that day.
27 A. Yes, I did.
28 Q. And in what connection was that. 2154
1 A. On two separate occasions, he assisted me in
2 doing an addendum to a search warrant in the Los
3 Angeles area, and also he assisted -- I had him
4 assist Detective Zelis on doing an addendum for a
5 search on a certain or particular item on the ranch.
6 Q. Do you know how long Mr. Franklin was there
7 that day.
8 A. I want to say he was approximately there
9 maybe four or five hours, somewhere along that line.
10 Q. Now, it’s been indicated in the beginning of
11 your testimony that I was on the ranch that day; is
12 that correct.
13 A. Yes.
14 Q. Do you recall how long I was there or when I
16 MR. SANGER: I’m going to object. Lack of
18 THE COURT: The answer -- the objection is
19 overruled. But answer “yes” or “no.” Do you recall
20 how long he was there.
21 THE WITNESS: Yes.
22 Q. BY MR. SNEDDON: How long.
23 A. I think you left probably around 1:30 or
24 2:00 in the afternoon.
25 THE COURT: All right. Let’s take our break.
26 (Recess taken.)
27 THE COURT: I don’t know if everybody knows,
28 but we had a little longer break this morning, 2155
1 because the Olive Garden read a CNN report that
2 basically said the jurors were starving to death.
4 THE COURT: And they have to thank CNN
5 because Olive Garden sent over a bunch of pizzas, so
6 the jury has been -- they sent out an attack
7 squadron and threatened my life if I wouldn’t let
8 them eat the pizzas, so they’re -- they’ve --
9 they’re all full, and --
10 A JUROR: Oh, yeah.
11 THE COURT: Let me tell you the danger here
12 now. Having been a Judge for many years, this is
13 the best advice I can give anybody on a jury, and
14 that is: Don’t eat too much at lunch.
15 But today it’s okay.
17 Q. BY MR. SNEDDON: Okay. Sergeant Robel, I
18 think we were at the point that you’re at the ranch,
19 and you’re executing a search warrant on November
20 the 18th, 2003. Okay.
21 A. Yes.
22 Q. Okay. Now, during the course of the
23 execution of that search warrant, did you personally
24 seize any items that were booked into evidence.
25 A. Yes, I did.
26 Q. And in what room was that that you did that.
27 A. It was in Mr. Jackson’s.
28 Q. Michael Jackson’s. 2156
1 A. That’s correct.
2 Q. And what room.
3 A. His master bedroom.
4 Q. Would that be downstairs or upstairs.
5 A. It would be upstairs.
6 Q. Now, could you just describe to the ladies
7 and gentlemen of the jury what process that you used
8 in seizing the evidence and then making sure that it
9 got booked appropriately.
10 A. We had a designated person downstairs with a
11 laptop computer that was the person that was
12 documenting the items on a property form and giving
13 it an item number, a sheriff’s department item
15 As seizers, we would seize stuff and then we
16 would actually hand-carry it down to him, and then
17 he would actually go on ahead and it would be
18 packaged up and entered into the computer and given
19 an item number.
20 MR. SNEDDON: All right, Your Honor. I have
21 four more exhibits I’d like to have marked for
22 identification purposes. And I’ve shown them to
23 counsel. They’re Photos 278, a Photo 84, and a
24 Photo 283 and 284.
25 THE COURT: Thank you.
26 (Off-the-record discussion held at counsel
28 Q. BY MR. SNEDDON: Okay. Sergeant Robel, 2157
1 let’s do it in this order. I’m going take them
2 back. But with regard to the Photograph 278, do you
3 recognize that.
4 A. Yes, I do.
5 Q. And is that an accurate depiction of what it
6 purports to represent.
7 A. Yes, it is.
8 Q. All right. And turn over the next one, if
9 you would. Turn that over, if you would.
10 And the next one is 84. Do you recognize
12 A. I do.
13 Q. And is that an accurate depiction of what it
14 purports to represent.
15 A. Yes, it is.
16 Q. Would you turn that over.
17 And with regard to the next item, which is
18 284, do you recognize that.
19 A. Yes, I do.
20 Q. And is that an accurate depiction of what it
21 purports to represent.
22 A. Yes, it is.
23 Q. All right. Would you turn that over,
25 And I believe the other one is 283.
26 A. Yes.
27 Q. And is that an accurate depiction of what it
28 purports to represent. 2158
1 A. Yes, it is.
2 Q. And are these items that you saw during the
3 course of your execution of the search warrant at
4 Neverland Valley Ranch.
5 A. Yes, they are.
6 Q. And are items that you seized.
7 A. Yes, they are.
8 MR. SNEDDON: I move that these be admitted
9 into evidence.
10 MR. SANGER: I would object. I would
11 object, Your Honor, on the grounds that there is no
12 foundation, particularly as to the relevance of
13 these particular items to these proceedings.
14 THE COURT: I haven’t seen the pictures.
15 MR. SNEDDON: May I come around this way,
16 Your Honor.
17 THE COURT: Yes.
18 MR. SANGER: Should I approach as well.
19 THE COURT: Yes.
20 MR. SANGER: Thank you.
21 (Discussion held off the record at sidebar.)
22 Q. BY MR. SNEDDON: I’m going to give you these
23 back for just a second, and I’m going to ask you a
24 couple more questions, and then we’ll....
25 Sergeant Robel, with regard to the
26 photograph that’s on the top, which is -- what’s the
27 number on that.
28 A. 278. 2159
1 Q. 278. Do you recognize that photograph.
2 A. I do.
3 Q. And what does that photograph depict.
4 A. It’s a cardboard box that’s open, and it has
5 various magazines in it.
6 Q. Have you ever seen that cardboard box
8 A. Yes, I have.
9 Q. Where did you see it.
10 A. In Mr. Jackson’s upstairs portion of his
11 master bedroom, at the base of his bed.
12 Q. Does that photograph accurately depict the
13 condition of that cardboard box the first time you
14 looked inside of it.
15 A. Yes, it does.
16 Q. All right. With regard to the next
17 photograph, which is No. 84 I believe --
18 A. That’s correct.
19 Q. -- is that correct.
20 A. That’s correct.
21 Q. Now, with regard to Photograph 84, do you
22 recognize that photograph.
23 A. Yes, I do.
24 Q. And there is displayed in that photograph a
25 magazine on top, correct.
26 A. That is correct.
27 Q. And does that photograph accurately depict
28 the location of that photograph -- that magazine the 2160
1 first time you saw it inside that box.
2 A. Yes, it does.
3 Q. All right. Turn that one over, if you
5 With regard to -- is that 284.
6 A. Yes, it is.
7 Q. With regard to 284, that photograph depicts
8 a book, correct.
9 A. Yes, it does.
10 Q. Where was that book the first time you saw
12 A. That was inside the cardboard box.
13 Q. The one that’s depicted in the Photograph
14 284 -- in No. 84.
15 A. That is correct.
16 Q. And did you seize that item.
17 A. Yes, I did.
18 Q. All right. And the next one is 283.
19 A. Yes.
20 Q. And with regard to what’s depicted in that
21 photograph, 283, where was that item the first time
22 you saw it.
23 A. That was also inside the cardboard box.
24 Q. It’s depicted in the Photograph 84 and 278.
25 A. Correct.
26 Q. All right.
27 Your Honor, ask permission at this point
28 to -- that they be admitted and I can question the 2161
1 witness about them.
2 MR. SANGER: I’d renew my objection, Your
4 THE COURT: I’ll sustain the objection.
5 The -- there’s no connection to the present case
6 with the photographs.
7 MR. SNEDDON: I’m sorry, Your Honor, I
8 didn’t hear what you said.
9 THE COURT: There’s no connection to the
10 present case with that material.
11 MR. SNEDDON: May we approach the bench for
12 a second, Your Honor.
13 THE COURT: Yes.
14 (Off-the-record discussion held at counsel
16 MR. SNEDDON: Your Honor, may I display them
17 with your permission.
18 THE COURT: Yes. The Court has ruled they
19 are admissible.
20 Q. BY MR. SNEDDON: Before I do that, I want to
21 ask you a question. We saw the box in the
22 photograph that is -- well, let me just put the box
24 Your Honor, could we have the port for the
25 Elmo, if you --
26 THE COURT: Yes.
27 MR. SNEDDON: And Your Honor, I guess I also
28 need to tell the Court that at least one of these 2162
1 photographs has a cover which is maybe sexually
2 explicit, in case there’s any persons in the
3 courtroom below the age of 18, I guess, or 21.
4 THE COURT: I think we’ve asked any
5 18-year-olds -- there were some students visiting.
6 We’ve asked them not to come in during this period.
7 MR. SNEDDON: Thank you, Your Honor.
8 MR. AUCHINCLOSS: Could we have “Input 4,”
9 Your Honor.
10 THE BAILIFF: Is the machine on. You need
11 to push the button for the Elmo.
12 MR. SNEDDON: Well, if I stand on my head, I
13 can see it, I guess.
14 Q. All right. Sergeant Robel, that’s
15 Photograph Exhibit 278, correct.
16 A. Yes, it is.
17 Q. Can you tell the ladies and gentlemen of the
18 jury, where was it when you first saw that box in
19 Mr. Jackson’s bedroom.
20 A. The box itself was at the base of Mr.
21 Jackson’s bed on the floor.
22 Q. And is that the condition of the box when
23 you first saw it, or first looked into it.
24 A. Yes. The top was closed, but I opened it up
25 and that’s what I saw, what’s depicted up there.
26 Q. Now, let me show you another photograph,
27 which is People’s 84.
28 Was that magazine -- the one depicted in the 2163
1 front, was that the top magazine in the pile of
2 magazines that you picked up.
3 A. Can you rephrase that. I’m sorry.
4 Q. Yeah. Was that one of the magazines you saw
5 in the box.
6 A. Yes.
7 Q. Was that the first one you saw.
8 A. No.
9 Q. Was there another one on top of that one.
10 A. Yeah, there were quite a few others on top.
11 Q. So that was just down inside of it
13 A. That is correct.
14 Q. Do you remember how many of those -- how
15 many of those magazines you actually took out of
17 A. Before I got to that one, or just all
19 Q. No, eventually.
20 A. I would say approximately 15 to 20.
21 Q. Now -- okay. If you can take that one down.
22 And if we could put up 284. I guess I have
23 to give them to you first, don’t I. Put 283 up
25 With regard to this particular item, 283,
26 where was it located in the box; do you recall.
27 A. I don’t recall the exact location, but it
28 was inside the cardboard box. 2164
1 Q. And let’s put 284 up there.
2 In regard to this book, The Chop Suey Club
3 book, do you recognize that.
4 A. Yes, I do.
5 Q. And where was that when you first saw it.
6 A. That was also inside the cardboard box.
7 MR. SNEDDON: Okay. We can have the lights
8 again, Your Honor.
9 Q. Now, with regard to the items that you’ve
10 talked about that you took out of that box, the
11 books and the magazines, what did you do with them
12 after you physically removed them from the box.
13 A. What I did -- what I did was, I put them on
14 top of the bed until I was finished going through
15 the magazines that I thought were within the scope
16 of the warrant, and then after I finished, I took
17 the magazines and the books downstairs and gave them
18 to Detective Padilla.
19 Q. Okay. And then Detective Padilla was
20 responsible for packaging them up.
21 A. That is correct.
22 (Off-the-record discussion at counsel
24 Q. BY MR. SNEDDON: I’m going to hand you an
25 exhibit marked as 279. Do you recognize that
27 A. Yes, I do.
28 Q. And what is it. 2165
1 A. It’s a layout of Mr. Jackson’s upstairs
3 Q. Does that look -- does that look like the
4 layout as you recall it when you were you were up
5 there on November the 18th.
6 A. Yes, it does.
7 MR. SNEDDON: Your Honor, I’ve indicated to
8 Mr. Sanger that even though there are some
9 measurements on that, that we’re just using this
10 simply to illustrate where the officer found the
11 items for purposes of demonstrative evidence at this
12 point in time only.
13 THE COURT: All right.
14 MR. SNEDDON: And I would move that that be
15 admitted into evidence at this point, Your Honor.
16 MR. SANGER: I don’t have any objection for
17 that purpose. The numbers on it that we have just
18 seen, the numbers would not be admitted for the
19 truth of the matter without further foundation. But
20 it can be put up.
21 MR. SNEDDON: I agree.
22 THE COURT: All right. It’s admitted for
23 that limited purpose.
24 Do you need the screen, then.
25 MR. SNEDDON: Please, Your Honor.
26 Q. Sergeant Robel, you have the exhibit in
27 front of you, and there is a copy of it exhibited to
28 the jury on the Elmo, okay. 2166
1 Now, let’s talk a little bit about the
2 exhibit. It’s 279, correct.
3 A. That is correct.
4 Q. Now, you told us you recognize that. Would
5 you use the laser, please, and show the ladies and
6 gentlemen of the jury approximately where Mr.
7 Jackson’s bedroom would have been. I’m sorry, bed.
8 A. It would have been right in this area here,
9 up to there, over, right up into here.
10 Q. So basically in the area where it has “MJ’s
11 Bedroom” written in letters on there.
12 A. That is correct.
13 Q. Now, could you show the ladies and gentlemen
14 of the jury where the box that you took the items
15 that you’ve told us about, where that was located
16 when you first saw it.
17 A. It was right here at the base of the bed on
18 the floor.
19 Q. You’re indicating -- I’m sorry, go ahead.
20 A. Just kind of like where that half inch is.
21 Q. Between the “4” and the “1”.
22 A. Yeah, right in that area right there.
23 Q. Okay. Now, on your exhibit that’s in front
24 of you - okay. --
25 A. Yes.
26 Q. -- could you please take the pen that we
27 have, and can you please put a little -- just draw a
28 box into the approximate location of where that item 2167
1 was found.
2 A. Okay.
3 Q. And there was a number assigned to the items
4 that you took down to Deputy Padilla, correct.
5 A. Yes.
6 Q. An item number. What item number was
7 assigned to those particular things.
8 A. I want to say 363.
9 Q. All right. Would you put a “363” on there.
10 And then at the bottom of that exhibit,
11 would you please sign your name.
12 (Off-the-record discussion held at counsel
14 Q. BY MR. SNEDDON: All right. Sergeant Robel,
15 I think you can put that down right now if you want.
16 And I think we can turn the lights back on,
17 Your Honor.
18 Let’s leave it, rather than go back and
19 forth. Let’s see if we can finish it.
20 I have a brown bag that I’ve shown counsel,
21 Your Honor. We had it previously marked as 280 for
23 MR. SANGER: Could you say the number again.
24 I apologize.
25 MR. SNEDDON: 280.
26 MR. SANGER: Thank you.
27 Q. BY MR. SNEDDON: Sergeant Robel, I’m going
28 to ask you to look inside -- the bag is open. If 2168
1 you would just look inside the contents of 280, if
2 you would, please. Do you recognize that item.
3 A. Yes, I do.
4 Q. And where and when -- let’s take it one at a
5 time. Where was that item the very first time you
6 saw it.
7 A. It was inside a nightstand upstairs in Mr.
8 Jackson’s bedroom.
9 Q. And when you saw it, what did you do with
11 A. I seized it.
12 Q. And was that among one of the items you gave
13 to Deputy Padilla.
14 A. Yes, it was.
15 Q. Does that bag that it was in, Exhibit 280,
16 does that have a number on it.
17 A. Yes.
18 Q. An item number.
19 A. Yes, it does.
20 Q. What is that.
21 A. 362.
22 Q. Now, could you please, using your laser,
23 indicate to the ladies and gentlemen of the jury
24 where Item 280 was found, or to be more correct,
25 where Exhibit No. 280 was found.
26 A. There was a night -- there was a nightstand
27 right here, had a drawer in it, and I opened up the
28 drawer and it was found inside the drawer inside the 2169
2 Q. Would you please indicate on your exhibit
3 and just put the item number there so we know which
4 one that is.
5 That’s the approximate location of where it
6 was when you first saw it.
7 A. That is correct.
8 Q. All right.
9 All right. I think I just have a couple
10 more questions, and then we’ll be done.
11 (Off-the-record discussion held at counsel
13 MR. SNEDDON: Your Honor, at this time I’ve
14 shown counsel two clear plastic bags. The first one
15 has been marked 281 for identification purposes.
16 And the second one -- the first one, by the way, has
17 ink at the top and the number “224,” so make sure we
18 don’t get confused.
19 But the second one is marked as 282 for
20 identification purposes, and it has a black pound
21 figure with a “225” at the top. I’ll show them to
22 the witness. Sorry.
23 Q. All right. With regard to 281, do you
24 recognize that.
25 A. Yes. Yes, I do.
26 Q. All right. What is 281.
27 A. It is Star Arvizo’s fingerprints and palm
28 prints. 2170
1 Q. And when and where was the first time you
2 saw those prints.
3 A. I took those prints on 5-5 of ‘04.
4 Q. When you say you took those prints, would
5 you describe for the ladies and gentlemen of the
6 jury what you did.
7 A. I met with Star, and I proceeded to go on
8 ahead and fingerprint him with all ten fingers, and
9 also his palm prints.
10 Q. And were you -- were you the one that
11 oversaw and directed him in obtaining those prints.
12 A. Yes, I was.
13 Q. All right. With regard to 282, do you
14 recognize that item.
15 A. Yes, I do.
16 Q. And what is that.
17 A. These are Gavin Arvizo’s finger and palm
19 Q. And with regard to those particular prints,
20 did you have a role in obtaining those.
21 A. Yes, I did.
22 Q. What role was that.
23 A. I proceeded to do the same thing with Gavin
24 Arvizo as I did with Star and rolled his
25 fingerprints and his palm prints.
26 Q. Was that done on a different occasion or on
27 the same day.
28 A. No, that was done on a separate occasion. 2171
1 Q. What was the date when you obtained Gavin’s.
2 A. That was on 9-14 of ‘04.
3 MR. SNEDDON: Your Honor, I request that
4 both of those items be admitted into evidence.
5 THE COURT: They’re admitted.
6 MR. SNEDDON: Madam Clerk, would you help me
7 please. The chart, 279, is that in evidence. Or
9 THE CLERK: No.
10 MR. SNEDDON: I move that that be admitted
11 as demonstrative evidence of the officer’s
12 testimony, Your Honor.
13 THE COURT: All right. It’s admitted.
14 MR. SNEDDON: I believe all of them have
15 been admitted at this point.
16 Thank you. And I have no further questions.
17 MR. SANGER: Well, wait a second. Except
18 280 was --
19 THE CLERK: 280 wasn’t received yet.
20 MR. SNEDDON: I thought --
21 MR. SANGER: 280 is not the chart.
22 THE COURT: That’s not the chart.
23 MR. SNEDDON: The chart was 279. And 280 is
24 the note.
25 THE COURT: Yes.
26 MR. SNEDDON: Okay. I move that that be
28 MR. SANGER: No objection. 2172
1 THE COURT: All right. 280 is admitted.
2 MR. SNEDDON: Apologize for that, for the
6 BY MR. SANGER:
7 Q. Well, let’s start at the end and work
8 backwards. How would that be.
9 First of all, you roll the prints of Star
10 and Gavin Arvizo, which is what you just told us,
12 A. Yes, I did.
13 Q. And that’s Exhibit 281, 282, correct.
14 A. Correct.
15 Q. Are you a certified fingerprint examiner.
16 A. No, I’m not.
17 Q. So you’ve learned to roll prints as a police
18 officer, as a sheriff; is that correct.
19 A. Correct.
20 Q. Let’s talk about the -- this was not marked;
21 is that right.
22 Let’s talk about what you found here, just
23 moving backwards, going through these boxes.
24 Your Honor, I’m going to put up on the
25 screen, if I may, 278, which has been received, if
26 that’s acceptable.
27 THE COURT: All right.
28 MR. SANGER: In fact, I’m going to take it 2173
1 off for one second. I’m sorry. Okay.
2 Q. All right. This was -- you basically were
3 searching the residence, along with a lot of other
4 officers, and we’ll get to that in a bit, right. Is
5 that correct.
6 A. Yes.
7 Q. And you found this box.
8 A. Correct.
9 Q. You personally found the box.
10 A. Yes.
11 Q. Do you know if anybody looked in the box
12 before you got to it.
13 A. I don’t know that.
14 Q. All right. In other words, the way this
15 looked is -- I guess we will go in general, here, to
16 set the stage.
17 The way this worked, I think you told us
18 before, is you had that -- I think what you called a
19 sweep or a protective sweep, or something, of the
20 whole residence when you first arrived there; is
21 that correct.
22 A. That is correct.
23 Q. And that was theoretically not a time to be
24 looking in boxes and seizing evidence. It was a
25 time to look in doors and see if people are in
26 there, and sort of see what the interior looked
27 like; is that correct.
28 A. Correct. 2174
1 Q. All right. And then after you completed the
2 sweep of the premises, then various officers were
3 assigned various locations to go actually do
4 searches; is that right.
5 A. That is correct.
6 Q. And you said there was some people who are
7 the seizers and some who were the scribes.
8 A. That is correct.
9 Q. Okay. Sounds like it could be something
10 from ancient Rome, I suppose.
11 But the scribes were the officers who were
12 just going to sit there and they were going to write
13 out your sheriff’s SH -- what is it. -- 541.
14 A. 451.
15 Q. 451. Okay. Sorry. I got it backwards.
16 Your 451 forms, those are the inventories
17 where you say, “We give it a number, and this is
18 what it is, and this is where it was located”; is
19 that right.
20 A. That’s correct.
21 Q. And then there were other officers who were
22 looking around, and eventually some of those
23 officers might actually see something and say, “I
24 want to seize this,” and they’d actually pick it up,
26 A. Correct.
27 Q. And then they’d take it over to the scribe
28 and say, “I seized this. This is where it came 2175
1 from,” and the scribe would write down on the -- on
2 the 451 form that it was Sergeant Robel that seized
3 it, right.
4 A. That’s correct.
5 Q. All right. Now, in the course of this,
6 however, there were officers who would be going
7 through the same materials sometimes, going through
8 opening boxes, and yet another officer might come
9 along and be the one that might seize something from
10 that box; is that true.
11 A. Do you mean in addition to the actual search
12 personnel that --
13 Q. No, no, the search personnel, the search
14 personnel in the room, somebody might open a box and
15 look through it, and another officer might come back
16 and look at it a second time and say, “I want to
17 seize something out of that box”; is that true.
18 A. I don’t know if that’s true or not. That
19 didn’t happen in my situation, but --
20 Q. So -- well, you’re telling us you’re the
21 first one to look in that box.
22 A. The box was closed when I opened it up.
23 Q. All right. Well, that was going to be my
24 next point. So the box was closed.
25 A. It was closed.
26 Q. So the photograph is a photograph of the
27 box. Exhibit 278 is a photograph of the box after
28 you opened it up. 2176
1 A. That is correct.
2 Q. Was it sealed or was it just folded in.
3 A. It was folded like you would normally fold a
4 cardboard box, kind of the flaps in between each
5 other to keep it closed.
6 Q. All right. Now, as the investigator in this
7 case, the lead investigator in this case, you are
8 not aware of any witness who said that they
9 specifically saw any one of these particular items,
10 that being 283, 284 and 84; is that correct.
11 A. At this present time, no.
12 Q. Okay. So I just asked one of those bad
13 questions. I said, “Is this correct.” Let me try
14 not to do that.
15 Based on your investigation, did anybody,
16 any witness, specifically say that they saw any of
17 these items, other than you as the searching
19 A. To the best of my knowledge, no.
20 Q. Thank you. Okay. Now, none of these
21 items -- and by “items,” I’m referring 284, 283 and
22 84. None of these items are per se illegal to
23 possess, are they.
24 I’ll just put them up quickly.
25 They’re not contraband.
26 A. No, those are not illegal to possess,
28 Q. So when they say “teenaged,” these are 2177
1 magazines that show models or people who are over --
2 who are 18 or over. However young they may look,
3 that’s -- they’re 18 or over, as far as you can
4 tell, correct.
5 A. They’re supposed to be, yes.
6 Q. And those are commercially available. You
7 can go to a store and buy them, correct.
8 A. As far as I know, yes.
9 Q. All right. Now, 283 -- I hate to just keep
10 putting these up, but -- but 283 is a collector’s
11 item of some sort, is it not.
12 A. I really don’t know.
13 Q. Did you find some nudist magazines when you
14 were looking around that were from the 1930s.
15 A. Inside that box.
16 Q. Anywhere.
17 A. I believe some other people, some other
18 searchers found that.
19 Q. And you had no witness -- there was no
20 witness that said they were shown that book or saw
21 that book, as far as you know, right.
22 A. Correct.
23 Q. All right. Now I’m going to put up 284.
24 You seized that because it appeared to be a
25 book that came within some concept of adult
26 material; is that right.
27 A. Correct.
28 Q. Do you know who Bruce Weber is. 2178
1 A. I do not.
2 Q. Now, when you were going through Mr.
3 Jackson’s home, did you see a number of items from
4 notable people that were just lying around, or
5 hanging on the wall, or sitting on a -- I’ll give
6 you some examples if you want. Did you see, for
7 instance, a letter from Steven Spielberg that was
8 just sitting on a table.
9 A. I did not see that, no.
10 Q. All right. Did you see a letter from
11 President Bush.
12 A. I believe I saw that, yes.
13 Q. Did you see some correspondence from Ronald
15 A. Yes.
16 Q. Did you see other correspondence from other
17 notable celebrities and politicians and other
19 A. I don’t recall exactly who they were, but he
20 had a lot of various things framed from those
21 particular people, yes.
22 Q. And some things that weren’t framed, right.
23 A. The items that I found, that I saw.
24 Q. That you saw.
25 A. They were framed.
26 Q. Okay. Did you notice that -- first of all,
27 how many books do you think there were in Mr.
28 Jackson’s residence, taking the -- taking the places 2179
1 that you searched on the ranch.
2 I’m not talking about, obviously, anyplace
3 you didn’t search, storage places or elsewhere, but
4 on the ranch.
5 MR. SNEDDON: Your Honor, I’m going to
6 object. Go ahead.
7 MR. SANGER: Let me withdraw it.
8 MR. SNEDDON: It’s unintelligible, that’s
9 what I’m saying.
10 MR. SANGER: All right. I’ll withdraw it.
11 Q. Taking into account the areas that you went
12 through -- let’s back up. What areas did you go
14 A. That I particularly searched.
15 Q. No, that you went through. You walked
16 through all the areas that were eventually going to
17 be searched; is that correct.
18 A. Correct.
19 Q. All right. And so you went through the main
21 A. Correct.
22 Q. Went through Mr. Jackson’s office.
23 A. Correct.
24 Q. You went upstairs from his office into the
25 video library.
26 A. Correct.
27 Q. And some other little rooms associated with
28 that, correct. 2180
1 A. Correct.
2 Q. You went into the arcade building, correct.
3 A. Correct.
4 Q. All right. Any other locations that you
5 went through.
6 A. The security.
7 Q. The security office at the end of the
8 office -- or the building that had Mr. Jackson’s
9 office in it, correct.
10 A. The one clear at the end, yes.
11 Q. Okay. So, as you went through these various
12 locations, there were over 10,000 books, were there
14 A. That’s going to be kind of difficult for me
15 to say over 10,000. I would say that there were
16 definitely several hundred, but 10,000, I really
17 couldn’t say that for sure. There were quite a few,
19 Q. Okay. You remember the library.
20 A. Correct.
21 Q. And the library had, for the most part,
22 leather-bound books and sets and that sort of thing,
24 A. Yes, it did.
25 Q. There were hundreds of books just in that
26 library, were there not.
27 A. That’s correct.
28 Q. And then the hallway leading to Mr. 2181
1 Jackson’s quarters, where he had the first floor and
2 the bedroom upstairs, that hallway had books,
3 bookcases lining one side of the hallway, correct.
4 A. That is correct.
5 Q. And there were hundreds of books there, were
6 there not.
7 A. There were quite a few, yes.
8 Q. And then when you went into Mr. Jackson’s
9 private quarters and you went down the steps into
10 that -- the big living room area, whatever it is,
11 with the big screen T.V., there were quite a number
12 of books stacked up on the floor there, were there
14 A. There were.
15 Q. And then there was -- there was another
16 bookcase full of books; is that correct.
17 A. I believe that, yes, you’re right.
18 Q. Okay. And then there were books lying
19 around stacked up in various places, in the bathroom
20 and his -- his bedroom upstairs, quite a number of
21 books stacked up.
22 A. Correct.
23 Q. And then upstairs in the house, in between
24 the craft room and Prince Michael’s bedroom, Mr.
25 Jackson’s son’s bedroom, there’s a little cove with
26 children’s books; is that right.
27 A. There were books there, yes. I’m not sure
28 if they were children’s books, but you’re correct. 2182
1 Q. Quite a number of books there.
2 A. Right.
3 Q. Okay. And then in Mr. Jackson’s office,
4 there were books stacked up, for the most part, in
5 various parts of his office; is that correct.
6 A. Yeah. Mainly around his desk area, yes.
7 Q. And there was actually a separate room as
8 you would go into the office, into the front office.
9 You turn left, there’s a little hallway, left again,
10 there was a little room that had shelves with
11 hundreds of books; is that correct.
12 A. Is that where the bathroom is. Is that what
13 you’re referring to.
14 Q. Just before the bathroom, yes. Talking
15 about his office.
16 A. Right.
17 Q. Turn left, a closet, a big closet area with
18 shelves in it with hundreds of books.
19 A. Correct. Correct.
20 Q. Okay. And then in the arcade, there was
21 a -- a room with a low door on the second floor,
23 A. Correct.
24 Q. And in there, there were thousands of books
25 in bookshelves like a bookstore, right.
26 A. Yeah. It looked like a library, yes.
27 Q. And there were boxes of books still in
28 boxes, correct. 2183
1 A. Correct.
2 Q. All right. Now, you saw all of this on
3 November the 18th, 2003, correct.
4 A. Correct.
5 Q. So you don’t know what exactly was there in
6 February or March; is that correct.
7 A. That’s a true statement.
8 Q. All right. Now, having talked about all
9 those books, among the books as you went through,
10 did you notice from time to time there might be more
11 than one copy of the same book.
12 A. Me, no, did not notice that.
13 Q. Did you notice that it appeared that a
14 publisher or an author had sent books to Mr.
16 A. I am unaware of that.
17 Q. All right. Now, this particular book,
18 Mr. Weber, who’s up there, Bruce Weber, The Chop
19 Suey Club, were you aware that Mr. Weber sent this
20 to Mr. Jackson unsolicited.
21 A. No, I’m not.
22 Q. Were you aware that Mr. Weber was a
23 photographer who had photographed The Jackson 5.
24 A. No.
25 Q. Photographed other people, Nelson Mandela
26 and a lot of other people.
27 A. No.
28 Q. Inside that very book, there’s an actual 2184
1 photograph of Elizabeth Taylor; is that correct.
2 A. It’s been a while since I’ve looked at that
3 book, so I couldn’t say for sure.
4 Q. Okay. And if I didn’t specifically ask you
5 on that, this, there was no witness that said they
6 were shown this book or saw this book, is that
7 correct, other than you and the officer that booked
8 it into evidence.
9 A. To the best of my knowledge, yes.
10 Q. All right. So you -- let me have just one
12 You originally got involved in this case by
13 virtue of an assignment by Lieutenant Klapakis; is
14 that correct.
15 A. Actually, it came higher up than the
16 lieutenant, but he was involved in it, yes.
17 Q. Did it come directly from Mr. Sneddon.
18 A. No. He wasn’t involved in that.
19 Q. You’re aware Mr. Sneddon had talked directly
20 with Lieutenant Klapakis about being assigned to
21 this case; is that correct.
22 MR. SNEDDON: Your Honor, I object. That
23 misstates the evidence.
24 MR. SANGER: Well, let me withdraw it.
25 THE COURT: I’ll sustain the objection.
26 Q. BY MR. SANGER: Somebody -- you’re saying
27 you were assigned -- anyway, whoever assigned you,
28 somebody assigned you; Lieutenant Klapakis or 2185
1 somebody higher up.
2 A. Correct.
3 Q. Right.
4 A. Right.
5 Q. And what day were you first assigned to the
7 A. To the best of my knowledge, I think it was
8 right around June, between June 15th and June 20th,
9 I’m not exact on the date, 2003.
10 Q. All right. So at the time you were assigned
11 on June 20th, Detective Zelis had already been
12 assigned to this case; is that correct.
13 A. That’s what I was told, yes.
14 Q. And so Detective Zelis was already starting
15 to work on the case.
16 A. To the best of my knowledge, yes.
17 Q. And then you came in and basically took over
18 the lead investigator responsibilities; is that
20 A. I was initially told that I was coming on to
21 supervise it and to actually conduct the interviews
22 and be a part of that process, yes.
23 Q. All right. Now, what I’m going to do is,
24 I’m going to give you a timeline. And I’m going to
25 show counsel.
26 Who’s doing this. Oh, Tom. I’m sorry.
27 With the Court’s permission, I’d like to
28 have this piece of paper -- it has a timeline on it. 2186
1 No content. I’d like to ask that this be marked for
2 identification next in order. And I’d like to
3 approach the witness, if I may.
4 THE COURT: All right. What number is that.
5 THE CLERK: That’s 5035.
6 THE COURT: 5035.
7 Q. Okay. Sergeant, let me go back so they can
8 hear me.
9 I’ve given you 5035 for identification,
10 which is a timeline.
11 And if the Court would permit, what I
12 propose to do is just put a blank timeline, same
13 thing, up there --
14 THE COURT: You may.
15 MR. SANGER: -- on the screen. So I think
16 we need Input....
17 Q. Okay. Now, before you start writing on
18 that, which is what I’m going to ask you to do --
19 close enough -- I’ve given you the same document
20 that’s on the screen; is that correct.
21 A. Yes.
22 Q. Okay. And what I’m going to ask you to do
23 is write on yours, and if you still have that
24 pointer up there, I’ll ask you at future moments
25 here to refer to the one on the screen so we can see
26 what we’re doing.
27 But first of all, why don’t you write your
28 name up there where it says “Witness,” so we can 2187
1 remember who did this.
2 All right. And what I’d like you to do
3 is -- you understand the timeline. It should be
4 pretty --
5 A. Yes, it’s 2003 and 2004.
6 Q. Starting with January, February, March,
7 April, May.
8 A. Correct.
9 Q. So, just as a point of reference, you
10 understood, from your investigation, the general
11 time frame in which the allegations were made. In
12 other words, the allegations were made about a
13 general time frame; is that correct.
14 A. Correct.
15 Q. All right. Somewhere between February 7th
16 to March the 13th; is that correct.
17 A. That is correct.
18 Q. Okay. So could you just make a bracket or a
19 mark on your copy there for that time period that
20 pertains to the allegations that were made against
21 Mr. Jackson.
22 MR. SNEDDON: Your Honor, I’m going to
23 interpose an objection that it’s vague because there
24 are several counts in this case involving several
25 different allegations, and the time frames are
27 MR. SANGER: We have -- Your Honor, if I
28 may -- 2188
1 MR. SNEDDON: Well, I object to the
2 question, the form of the question.
3 MR. SANGER: I’ve asked for the general time
4 period, and I will break it down later.
5 THE COURT: You’re not asking him to make a
6 mark now before you get to a specific charge.
7 MR. SNEDDON: Well, he did.
8 THE COURT: Well, I wasn’t sure if he was
9 making a general instruction or a specific question.
10 MR. SANGER: Yeah, I was asking him to put a
11 bracket so that we have a frame of reference on this
12 exhibit as to the general time frame. We will
13 obviously go back --
14 THE COURT: I’ll ask you to do it one at a
15 time so that he knows exactly what you’re asking him
16 to put on the diagram.
17 MR. SANGER: Okay.
18 Q. Well, let’s do it -- because we are going to
19 go through this in more detail, but I want to get
20 the big picture.
21 There was a time that you were told, and you
22 found from your investigation, that the Arvizo
23 children and Janet Arvizo and Mr. Jackson and others
24 returned to the Neverland Valley Ranch after being
25 in Florida; is that right.
26 A. That is correct.
27 Q. And what was that date.
28 A. I believe it was right around the 6th of 2189
2 Q. 7th perhaps.
3 A. 7th. Somewhere right in there.
4 Q. So why don’t you just mark that roughly.
5 Put a little line, and you can put --
6 A. Do you want me to put “March 7th” there.
7 Q. Sure. Put a little line and you can write
8 up above what it is.
9 MR. SNEDDON: Your Honor, I think --
10 Q. BY MR. SANGER: “Arrived.”
11 MR. SNEDDON: I think he misspoke.
12 MR. SANGER: Who misspoke.
13 MR. SNEDDON: I think he said March.
14 THE WITNESS: No, that’s right. I did.
15 MR. SANGER: I’m sorry, I meant to say
17 THE WITNESS: It’s February 7th.
18 MR. SANGER: Did we both say March.
19 THE WITNESS: I think I did.
20 MR. SANGER: Okay. Let’s get it right.
21 It’s February 7th.
22 Q. All right. And then there was a time that
23 you came to understand the Arvizos claimed that they
24 left Neverland Valley Ranch for the last time.
25 A. Yes.
26 Q. Do you know what date that was.
27 A. That I believe was March 12th.
28 Q. March 12th. 2190
1 A. Okay. And could you mark March 12th.
2 Q. And then why don’t you just -- I’m sure
3 everybody’s on board, but just so -- in case, from
4 the angle, it’s hard, just point roughly where you
5 are on this timeline.
6 February 7th through 22.
7 A. Yeah, February 7th. And then over here
8 would be March the 12th.
9 Q. All right. There you go.
10 I’m going to -- I will come back to a more
11 detailed timeline with a different chart that has
12 February and March called out later, but that gives
13 you the parameters.
14 When do you understand Mr. Feldman and
15 Mr. Katz made contact with the Santa Barbara
16 District Attorney in this case.
17 MR. SNEDDON: Your Honor, I’m going to
18 object. That assumes facts not in evidence. Plus,
19 it’s compound because it has two names in it.
20 Q. BY MR. SANGER: Okay. Let’s put it this
21 way: It’s your understanding that Mr. Feldman
22 called Mr. Sneddon; is that correct.
23 A. I believe so, yes.
24 Q. Okay. Do you know when that occurred, based
25 on your investigation.
26 A. I want to say it was possibly sometime in
28 Q. Okay. Do you have a report to refresh your 2191
1 recollection that would help you with that.
2 I don’t know if you have the Bates stamps up
3 there or not. Yes, page 25, if you do.
4 A. No, I don’t have that.
5 Q. Page two of Detective Zelis’s report.
6 A. That’s the one I -- yes, it was June 13th,
8 Q. All right. So, can you indicate on your
9 chart -- why don’t you just point, so we do it
10 consistently, where that would be, roughly.
11 A. Right there.
12 Q. June 13. In between June and July, okay.
13 So why don’t you indicate that on your report -- I
14 mean, on your exhibit.
15 And your understanding was that that same
16 day, June 13th, Detective Zelis actually called
17 Dr. Katz and interviewed Dr. Katz; is that correct.
18 A. Yes.
19 Q. All right. So maybe you can make a note on
20 that, “Dr. Katz interviewed.” You can abbreviate so
21 it all fits.
22 Okay. Now, you were involved in all of the
23 interviews that were tape-recorded of the Arvizo
24 family prior to the grand jury testimony; is that
26 A. That is correct.
27 Q. What was the first date that you conducted
28 an interview with the Arvizo family. Let’s take the 2192
1 children for right now.
2 A. That would have been July 7th.
3 Q. July 7th, 2003.
4 And so three or four weeks after the Katz
5 interview; is that correct.
6 A. That is correct.
7 Q. All right. Why don’t you put that on your
8 chart there.
9 And what was the next time -- I’ll let you
10 finish that, I’m sorry.
11 A. Okay.
12 Q. What was the next time that you interviewed
13 the Arvizo children.
14 A. That would have been August 13th --
15 Q. All right.
16 A. -- 2003.
17 Q. Put that interview up there. Okay.
18 A. Okay.
19 Q. All right. Now, you were aware that Mr.
20 Sneddon had a meeting with the -- with Mrs. Arvizo
21 at some point; is that correct.
22 MR. SNEDDON: Your Honor, I’m going to
23 object to that question. It’s vague as to what
24 point in time, I believe, when he’s dealing with
25 dates in here. It’s vague.
26 MR. SANGER: I’ll tell you what.
27 THE COURT: He asked him “at some point.”
28 MR. SANGER: Yes, then I’ll ask him when, if 2193
1 he knows.
2 Q. Did Mr. Sneddon have a meeting, a meeting
3 alone with Mrs. Arvizo, sometime before the search
5 A. Yes.
6 Q. Do you know what the date of that was.
7 A. I do not.
8 Q. Okay. Sometime in early November.
9 A. It could have been. It was before the
10 search warrant service. I do know that.
11 Q. All right. We’ll skip that. We’ll come
12 back to that later.
13 The next significant event I want you to
14 focus on is the actual execution of the search
15 warrant, which was November the 18th, 2003; is that
17 A. That’s correct.
18 Q. And can you list that -- why don’t you point
19 at the map there, just in case, just to show where
20 we are on our trip down the road here.
21 So now we’re on November the 18th, halfway
22 in between November-December. Okay.
23 Why don’t you make a notation there. That’s
24 the search warrant.
25 A. Okay.
26 Q. The next documented interview with the
27 Arvizo children was when.
28 A. Do you mean beyond the August 13th. 2194
1 Q. Yes. You put August 13th up there.
2 A. Yeah, I already have August 13th.
3 Q. So what’s the next one. Was it November the
5 A. I don’t recall another -- are we talking
6 about a -- an interview with them.
7 Q. Yes.
8 A. Oh. No, I -- I do have it here. That’s for
9 the bucchal swabs. I have that. That was November
11 Q. Okay. November 25th.
12 A. Of 2003.
13 Q. And that was actually tape-recorded, is that
14 correct, an interview.
15 A. I believe it was, yes.
16 Q. So can you put “November 25th, 2003.” All
18 A. Okay.
19 Q. And then when was the next documented
20 interview with the Arvizo children.
21 A. That I don’t believe I conducted. There was
22 various things that we would contact them in regards
23 to, but as far as an interview, no. I can’t -- I
24 can’t recall.
25 Q. Was there a tape-recorded interview on
26 January the 19th, 2004.
27 A. I don’t recall. I don’t have that report.
28 Who’s the author of that. Me. Or -- 2195
1 Q. Well, I have the transcript here, and I’ll
2 have to find the report. But while I’m doing that,
3 or before I do that, let me see if I can refresh
4 your recollection a little bit.
5 Do you recall a meeting with the Arvizo
6 children during which, or preceding which, they were
7 played the rebuttal video.
8 A. I do remember that.
9 Q. And after the rebuttal video was played for
10 them, then you interviewed the various children one
11 by one; is that correct.
12 A. Yeah, but I was not involved in the
13 interview process of that. I was there, in and out.
14 That would be Detective Zelis that was the author of
15 that report. And he participated with the
17 Q. Okay. And when you say “the attorneys,” who
18 was there.
19 A. I believe it was Mr. Zonen and Mr. Sneddon.
20 Q. All right. Mr. Zonen and Mr. Sneddon
21 actually engaged in asking questions and making
22 remarks during those interviews, correct.
23 A. I do recall, yes.
24 Q. Okay. All right. So, could you --
25 A. Mr. Sanger.
26 Q. Yes.
27 A. No, it was -- I stand corrected on that. It
28 was Mr. Zonen that was in there conducting that. 2196
1 Mr. Sneddon was with me outside the room. I mean,
2 we watched the videos together, but then when it
3 came to questioning the kids, we both stepped out,
4 and it was Mr. Zonen and Detective Zelis that
5 handled that.
6 Q. Okay. Let me see if I can refresh your
7 recollection in that regard.
8 May I approach.
9 THE COURT: Yes.
10 Q. BY MR. SANGER: I’m showing you a
11 transcript. And you’re welcome to look at the whole
12 thing. The introduction and subsequent pages where
13 there’s some references, does that refresh your
14 recollection that --
15 A. Yes, it does.
16 Q. Okay. Was Mr. Sneddon there and did he
17 actually participate in part of the interview.
18 A. Yes, he did.
19 Q. All right. Okay. So having said that, can
20 you put on your chart -- let me take the book back.
21 Thank you.
22 Put on your chart a reference for this
23 interview, which is January 19, 2004, or series of
25 A. Okay.
26 Q. All right. And then I’ll ask you to do one
27 other thing. You remember the grand jury
28 proceedings in this case; is that correct. 2197
1 A. I do.
2 Q. Do you recall the approximate time of the
3 grand jury proceedings.
4 A. March and April, I think, 2004.
5 Q. End of March, beginning of April.
6 A. Yeah, that sounds about right.
7 Q. Okay. Could you simply make a notation on
8 your chart indicating “grand jury” and just that
9 general time period there.
10 A. Okay.
11 Q. Having done all of that, does that fairly
12 and accurately represent the testimony that you’ve
13 given so far about these dates.
14 A. Yes, it does.
15 MR. SANGER: Your Honor, I’d move the
16 admission and ask for permission to publish the
18 THE COURT: It’s admitted. You may publish.
19 MR. SANGER: Thank you.
20 May I approach and retrieve it.
21 THE COURT: Yes.
22 MR. SNEDDON: Mr. Sanger. Thank you.
23 MR. SANGER: Yes.
24 Q. Okay. Can we go through, just really
25 quickly with the pointer there, so you can tell us
26 what you wrote.
27 A. Okay. On February the 7th, that’s when the
28 family returned back from Miami. 2198
1 March the 12th, that’s when the Arvizos left
2 the ranch for good.
3 On June 13th, 2003, we received a call from
4 Attorney Feldman. And then on June 13th, Dr. Katz
5 was interviewed.
6 And July 7th was the first interview with
7 the Arvizo children.
8 August 13th was a follow-up interview with
9 the kids.
10 November 25th is when I met with Star and
11 Gavin for the bucchal swabs.
12 And November 18th is when we served the
13 search warrant at Neverland.
14 January 19th, 2004, that’s when the family
15 was interviewed regarding the rebuttal tape.
16 And then end of March through April of 2004,
17 the grand jury.
18 Q. Okay. Thank you.
19 Now, this means that you interviewed -- let
20 me withdraw that.
21 Were there other times that the children
22 were talked to by law enforcement officers during
23 the period depicted on Exhibit 5035 that were not
24 reduced to reports and were not tape-recorded.
25 A. There were various times that I would
26 contact them to see how they were doing and things
27 to that effect. But as far as interviews, no.
28 Q. And based on your training and experience, 2199
1 you would want to record the important and relevant
2 materials, either by way of a written report, or a
3 written report with an actual tape-recording.
4 A. That is correct.
5 Q. All right. So, before the search on
6 November 18th -- I wonder if I could borrow -- it
7 really belongs to the prosecution, so I should ask
8 the prosecution if I can borrow their pointer. If I
9 may address directly, Your Honor.
10 MR. SNEDDON: I don’t have it.
11 MR. SANGER: It’s up there.
12 MR. SNEDDON: Oh, of course.
14 MR. SNEDDON: You’re a taxpayer. It belongs
15 to the county.
16 MR. SANGER: There you go.
17 MR. SNEDDON: I think you pay your taxes.
18 MR. SANGER: Now I have to figure out how to
19 use it.
20 Ahh, that’s how you use it. Thank you.
21 Q. Okay. Now, if we look at -- we have July
22 the 7th is the first set of interviews, right, that
23 are on tape.
24 A. That’s correct.
25 Q. And then August 13th, right.
26 A. Correct.
27 Q. Up to that point, you have not really
28 gathered much in the way of physical evidence in 2200
1 this case; is that correct.
2 A. That is correct.
3 Q. November 18th, you told us that you had
4 conducted a search at Neverland Ranch, right.
5 A. That’s correct.
6 Q. And that’s where you had quite a number of
7 officers and you were there all day, correct.
8 A. Right.
9 Q. And you’ve told us some of the things that
10 your department retrieved as a result of this
11 search, correct.
12 A. That’s correct.
13 Q. There was certainly quite a number of other
14 items that were retrieved, were seized, as a result
15 of that search; is that right.
16 A. Correct.
17 Q. In addition to that, two other locations
18 were searched on that same day, on November the
19 18th, correct.
20 A. That’s correct.
21 Q. One of the locations was Hamid Moslehi’s
22 house; is that right.
23 A. That’s correct.
24 Q. And the other location was the office of
25 Brad Miller.
26 A. Correct.
27 Q. Okay. Now, with regard to all of these
28 searches, you were responsible for the briefing of 2201