1 A. Yes.
2 Q. And who is that.
3 A. Marie Nicole.
4 Q. And with regard to this particular person,
5 was she in the suite -- did she remain in the suite
6 after you were introduced to her.
7 A. Yes.
8 Q. And do you know whether or not she left at
9 any time before you did.
10 A. No.
11 Q. And we have one left.
12 A. Two left.
13 Q. Two left, okay. And with regard to --
14 what’s the number on this one.
15 A. 43.
16 Q. 43. With regard to 43, who is that.
17 A. That’s Grace.
18 Q. That’s the person you knew as Grace.
19 A. Yes.
20 Q. Did you know what Grace’s responsibilities
21 were for Mr. Jackson.
22 A. She was the nanny.
23 Q. And by “nanny,” what do you mean.
24 A. She took care of the kids.
25 Q. And this lady depicted in the photograph,
26 People’s 43, was in the room that day.
27 A. Yes. For a moment. Yeah.
28 Q. For a moment. 657
1 A. They didn’t stay the whole time.
2 Q. And we have one last one. And the number on
3 that is.
4 A. 48.
5 Q. All right. And People’s 48, who’s that
6 person.
7 A. That’s my stepfather, Jay Jackson.
8 Q. All right.
9 I think we can turn the lights back on, Your
10 Honor.
11 The night following -- well, let me go back.
12 Did you see any other activities on this --
13 the day we’re talking about, okay, when you were in
14 the suite and you got there in the afternoon and you
15 stayed there till late at night, just so we know
16 we’re talking about the same day, did you see any
17 other occasions where your brother Gavin would go
18 somewhere with Mr. Jackson.
19 A. No.
20 Q. So --
21 A. We stood in the suite the whole day.
22 Q. Okay. Now, after that evening, you left.
23 Where did you go. Where did “you” go.
24 A. Straight to my room.
25 Q. And did anybody else go with you.
26 A. Well, me, my brothers and my mom.
27 Q. So you all left at the same time.
28 A. Yes. 658
1 Q. When you went back to your room that
2 evening, did you leave the room at any time.
3 A. No.
4 Q. Now, the next day when you got up, what did
5 you -- what was the first thing you did, if you
6 recall, of significance.
7 A. Just went straight up to Mr. Jackson’s room.
8 Q. I’m sorry.
9 A. We just went straight up to Mr. Jackson’s
10 room.
11 Q. All of you.
12 A. Yes.
13 Q. Or just you.
14 A. All of us.
15 Q. Now, on this particular day, did you get
16 some kind of a treat.
17 A. This is the last day that we were there.
18 This is the last day, we got -- I got a manicure and
19 pedicure.
20 Q. And how did that come about.
21 A. Well, me and Chris Tucker and Gavin, Star,
22 went to, like, the spa area.
23 Q. You have to speak up.
24 A. Me and Mr. -- Chris Tucker and my brothers,
25 we all went to the spa area.
26 Q. Okay. And you got --
27 A. I got a manicure and pedicure, and the boys
28 and Mr. Tucker got massages. 659
1 Q. Now, on this particular day, after that, did
2 you leave.
3 A. Yes.
4 Q. Where did you go.
5 A. We went to the ranch. Neverland Ranch.
6 Q. How did you get there.
7 A. On a private jet.
8 Q. And who was on the jet.
9 A. Me, my brothers, Paris and Prince, and
10 Prince the II, Mr. Jackson, Grace, another nanny,
11 Marie Nicole, Aldo, and I think Mr. Jackson’s
12 doctor.
13 Q. And was Mr. Jackson on the plane.
14 A. Yes.
15 THE COURT: Is this a good place for a break.
16 MR. SNEDDON: I want to keep going, Judge.
17 THE COURT: We’ll take our morning break.
18 (Recess taken.)
19 THE COURT: Go ahead.
20 Q. BY MR. SNEDDON: Before we start talking
21 about the plane ride from Miami, I want to go back
22 and -- go back, if we could.
23 A. Okay.
24 Q. From the time that you left - okay. - till
25 the time that you left with Chris Tucker on the
26 plane to Miami, did you have any contact with your
27 father.
28 A. Yes. 660
1 Q. On how many occasions.
2 A. Once or twice.
3 Q. I’m sorry.
4 A. Once or twice.
5 Q. Was there on one occasion that led to a
6 situation where you ended up talking to law
7 enforcement authorities.
8 A. Yes.
9 Q. And you ended up having to go to court.
10 A. Yes.
11 Q. And testify against your father.
12 A. Yes.
13 Q. And you were the victim.
14 A. Yes.
15 Q. Since the time that that occurred until you
16 left to Miami, have you ever seen your father, had
17 any contact with him.
18 A. No. Not personally.
19 THE COURT: Counsel, I’m sorry to interrupt
20 you, but my feed isn’t working here.
21 (Brief interruption.)
22 Q. BY MR. SNEDDON: Just moving to another
23 event now, and just going back and filling in some
24 details I left out while you and I were talking
25 earlier this morning, you recall earlier that you
26 testified that there was a point where some media
27 people came to your door at your apartment.
28 A. Yes. 661
1 Q. Do you recall that.
2 A. Yes.
3 Q. Do you remember how -- how that -- how many
4 days that was before you left for Miami.
5 A. A couple of days before.
6 Q. I’m sorry, I couldn’t hear the answer.
7 A. A couple days before.
8 Q. Did it happen on more than one occasion.
9 A. My grandma had called us and said there was
10 media at her house, but other -- to the apartment,
11 no.
12 Q. Now, one last thing, and then we’ll get back
13 on the plane there in Miami.
14 Your senior year in high school, where did
15 you go to high school.
16 A. Mountain View High School.
17 Q. What community is Mountain View High School
18 located.
19 A. In El Monte.
20 Q. Where did you live while you were going to
21 Mountain View High School.
22 A. With my grandmother.
23 Q. And they live in where.
24 A. El Monte.
25 Q. Now, after you graduated from high school,
26 where did you -- where did you live. With your
27 grandparents or somebody else.
28 A. We went back to live with my parents. 662
1 Q. With your parents meaning.
2 A. Jay Jackson and my mom.
3 Q. Have you lived there continuously since that
4 time.
5 A. Yes.
6 Q. How would you describe your relationship
7 with your stepfather.
8 A. Very nice relationship. Very, very loving.
9 I love him a lot.
10 THE COURT: Mr. Sneddon. This is a good
11 place to interrupt.
12 I’m not sure if it’s catching up. It’s
13 going back through the -- this morning.
14 THE REPORTER: It will eventually catch up.
15 MR. SANGER: It’s doing the same for us, if
16 that’s of any consolation.
17 MR. ZONEN: Us too.
18 THE COURT: That’s no consolation.
19 I’d like to wait a minute, if we could, so
20 we catch up.
21 (Brief interruption.)
22 THE COURT: All right. I think we can go
23 forward now.
24 MR. SNEDDON: Thank you, Your Honor.
25 Q. Okay. We’re going to go back now and we’re
26 going to start talking about the part of Miami where
27 you’re flying, you’re getting on a plane in Miami.
28 Okay. 663
1 A. All right.
2 Q. Now, you told us who was on the plane
3 before.
4 A. Yes.
5 Q. Now, I want to ask you something. Was there
6 an incident that occurred before you guys got on the
7 plane.
8 A. Like -- incident how.
9 Q. Was your mother on the plane.
10 A. Yes.
11 Q. And was your mother supposed to be on the
12 plane.
13 A. No.
14 Q. Okay. What happened.
15 A. They didn’t want my mom to go on the flight,
16 on the same flight that we were on.
17 MR. MESEREAU: Objection; hearsay.
18 THE COURT: Sustained.
19 Q. BY MR. SNEDDON: Were you present when your
20 mom was having a discussion about who was going to
21 go on the plane.
22 A. Yeah, she was on the phone.
23 Q. She was on the phone.
24 A. Yeah.
25 Q. And who else was present.
26 A. I think my brothers were. But it was in our
27 room, but it’s when we were getting ready to leave.
28 Q. Do you know who she was on the phone with. 664
1 A. Probably --
2 Q. To your knowledge, without --
3 MR. MESEREAU: Objection.
4 Q. BY MR. SNEDDON: Not something that somebody
5 told you, but to your knowledge.
6 A. I don’t know.
7 Q. And how long did that discussion take.
8 A. They were on the phone for like ten minutes.
9 Q. And at the end of that conversation, did
10 your mom get on the plane with you.
11 A. Yes.
12 Q. Was -- were any people identified to you as
13 security guards on that plane when it left.
14 A. When it left, there was no security guards
15 on the plane.
16 Q. On the plane -- where -- let’s just do it
17 this way: You’re on the plane. Where are you
18 seated on the plane in relationship to your brother
19 Gavin.
20 A. Right across from him.
21 Q. And who’s sitting next to you, if anyone.
22 A. Paris is.
23 Q. Paris.
24 A. Yes.
25 Q. And with regard to the defendant in this
26 case, Mr. Jackson, where is he.
27 A. He’s sitting next to Gavin.
28 Q. And is there anything in between you and 665
1 Paris and Gavin and the defendant.
2 A. We were sitting at, like, a dining room --
3 like a little table. There were, like, cupholders
4 and stuff.
5 Q. Now, during the flight, during this flight,
6 did you at any time see Gavin drinking anything.
7 A. He had a Diet Coke can.
8 Q. Do you know where he got it from.
9 A. Mr. Jackson passed it to him.
10 Q. Did you see him actually drink from the can.
11 A. Yes.
12 Q. Do you remember on how many occasions.
13 A. They were sipping it back and forth.
14 Q. Now, when they were sipping this -- what
15 kind of a can was it.
16 A. A Diet Coke can.
17 Q. When they were sipping this Diet Coke can,
18 passing it back and forth, was there anything else
19 going on between your brother Gavin and the
20 defendant in this case, Mr. Jackson.
21 MR. MESEREAU: Objection; vague.
22 THE COURT: Overruled.
23 THE WITNESS: They were whispering.
24 Q. BY MR. SNEDDON: I’m sorry.
25 A. They were whispering back and forth.
26 Q. At any time during the time that they were
27 whispering back and forth, did you see Mr. Jackson
28 do anything. 666
1 A. He would pass the Diet Coke, they would
2 whisper, and then at one point Mr. Jackson took off
3 his watch and gave it to Gavin.
4 Q. Did you see Mr. Jackson do that.
5 A. Yes.
6 Q. Can you tell the ladies and gentlemen of the
7 jury, when he took the watch off and gave it to
8 Gavin, whether he said anything to him at that time.
9 A. He was whispering in his ear and then Gavin
10 put it on.
11 Q. During the course of this flight, did you
12 see Mr. Jackson give Gavin anything else.
13 A. Yes.
14 Q. What.
15 A. The jacket he had on.
16 Q. Can you describe the jacket.
17 A. It’s black and it’s sparkly on the back.
18 Q. Now, do you recall how long the plane ride
19 took from, say, Miami to where you eventually
20 landed.
21 A. Six, seven hours.
22 Q. Did you -- were you awake during the whole
23 trip.
24 A. No, I fell asleep at one point.
25 Q. Now, your brother Star was on the plane; is
26 that correct.
27 A. Yes.
28 Q. And where was your brother Star located on 667
1 the plane.
2 A. There was a bench behind Mr. Jackson and
3 Gavin. I’m -- not exactly behind, but like to the
4 back, my left-hand side, there was a bench. And he
5 would go from right there into a chair that was
6 right in front of them. He would go back and forth.
7 Q. So this was a plane you could get up and
8 move around on.
9 A. Yes.
10 Q. Where was your mom.
11 A. My mom was sitting behind me in one of the
12 four chairs that’s behind us.
13 Q. During the time that you were on this plane,
14 did you see whether or not the plane had any kind of
15 a telephone on it.
16 A. Yes.
17 Q. Where was the telephone located.
18 A. Right on my right-hand side, on the wall.
19 Q. And during the time of this ride on the
20 plane, did you see -- can you tell us whether or not
21 that telephone was ever used.
22 A. I saw Gavin use it once. He was calling one
23 of his friends.
24 Q. All right. Did you see that on any other
25 occasions.
26 A. No.
27 MR. SNEDDON: Excuse me just a moment, Your
28 Honor. 668
1 I have an exhibit. This will be 339, I
2 believe, for identification purposes.
3 (Off-the-record discussion held at counsel
4 table.)
5 Q. BY MR. SNEDDON: All right. I’m going to
6 hand you People’s Exhibit No. 339 and ask you if you
7 recognize that.
8 A. Yes.
9 Q. Can you tell the ladies and gentlemen of the
10 jury what that is.
11 A. The -- how -- the plane, the private jet.
12 Q. Is that the interior.
13 A. Yes.
14 Q. All right. I’m going to hand you this pen.
15 And just hang on to that for a second.
16 Does that diagram accurately represent the
17 interior of the plane as you recall it.
18 A. Yes.
19 MR. SNEDDON: I move that it be admitted
20 into evidence, Your Honor.
21 MR. MESEREAU: I’m sorry, Your Honor. I
22 didn’t hear.
23 THE COURT: It’s okay. He moved that exhibit
24 into evidence. She identified it.
25 MR. MESEREAU: There’s still a foundational
26 problem, Your Honor, as to whether that is actually
27 an accurate depiction of the interior of that plane.
28 I don’t think the foundation has been laid. 669
1 THE COURT: I’ll admit it. I think that’s a
2 subject of cross-examination.
3 MR. MESEREAU: Okay.
4 MR. SNEDDON: All right. We’re going to
5 display something up on the Elmo, Your Honor. And
6 what we’re going to display is 339.
7 Q. Now, you have the exhibit in front of you,
8 okay.
9 What I want you to do is, I want you to take
10 a felt tip pen, if you would, and I want you to put
11 your initials in the seat in which you were located.
12 Well, first of all, let me do this. Take
13 that light, the black thing with the light, okay,
14 and show the ladies and gentlemen of the jury where
15 you were seated.
16 A. Right there.
17 Q. All right. And where was your brother
18 Gavin.
19 A. Right there.
20 Q. And where was the defendant.
21 A. Right here.
22 Q. And where was Paris.
23 A. Right here.
24 Q. Okay. Now, what I want you to do is on the
25 exhibit that you have in front of you, I want you to
26 take that red pen I gave you, and I want you to put
27 your initials in your seat.
28 Okay. What did you put. 670
1 A. “DA.”
2 Q. That figures.
3 Now, would you please put the initials for
4 your brother in the seat that he was in on
5 Exhibit 339.
6 And then put just like an “MJ” for where
7 Mr. Jackson was sitting.
8 And a “PJ” for where Paris was sitting.
9 Now, would you show the ladies and gentlemen
10 of the jury with the light again, if you would,
11 where your mother was sitting on the plane.
12 A. She was sitting in one of these four seats.
13 Q. So you’re not sure which one of those four.
14 A. I don’t remember.
15 Q. So why don’t you just put your mother’s
16 initials right in the middle on the diagram. And
17 you put a what.
18 A. “JJ.” “JJ.”
19 Q. “JJ”.
20 A. Yeah, that’s my mom’s initials.
21 Q. Oh, Janet Jackson. You threw me for a
22 second. Way ahead of me.
23 All right. Now, your brother Star, when the
24 plane took off, do you recall where he was.
25 A. Yes.
26 Q. Would you show the ladies and gentlemen of
27 the jury.
28 A. He was either sitting right here or he would 671
1 go to this seat.
2 Q. So he moved back and forth between those
3 seats.
4 All right. The two seats that you said he
5 moved back and forth between, would you put his
6 initials in those seats on the Exhibit 339. Would
7 you put them in both of them.
8 Now, I want to direct your attention to
9 where you believed that you saw the telephone.
10 Okay.
11 A. Okay.
12 Q. Would you point that out to the jury.
13 A. Right here.
14 Q. Okay. And would you put -- you can put --
15 on the white area, put “TFC,” and then the arrow to
16 where it was located on the exhibit. Would you do
17 that. Good. Thank you.
18 Now, on the exhibit that looks like a blue
19 series of chairs, do you see that.
20 A. Yes.
21 Q. What is that.
22 A. That’s like a couch.
23 Q. And you told us that one of those seats was
24 occupied from time to time by your brother Star.
25 A. Yes.
26 Q. Who, if anyone, occupied the other seat.
27 A. Aldo and Marie Nicole were sitting in that
28 area, too. 672
1 Q. Do you remember which seats they were in.
2 A. No, they would switch around.
3 Q. Why don’t you just go ahead and put their
4 initials, just Aldo and Marie Nicole, in those two
5 seats, just -- and an arrow back and forth. How’s
6 that. Okay.
7 Now, you told us -- who else was on the
8 plane.
9 A. Mr. Jackson’s doctor and the two nannies.
10 Q. Do you know the doctor’s name.
11 A. No.
12 Q. Do you know where he was seated.
13 A. He was in one of the four chairs.
14 Q. Show us.
15 A. In one of these chairs.
16 Q. Okay. Who else was up in that four-chair
17 area besides your mother and this doctor.
18 A. The two nannies.
19 Q. Okay. So why don’t you just put “Doctor,”
20 just put a “DR,” just -- and “2-nannies.”
21 Okay. Now, if we could just move the
22 exhibit a little bit farther to the right, so it
23 shows all the way to the front, or all the way to
24 the end.
25 Okay. Now, from this particular exhibit,
26 339, the one that’s in front of you, looking at the
27 far left-hand part of the exhibit that’s on the
28 board above you, do you see that. What end of the 673
1 plane is that.
2 A. This is the back of the plane.
3 Q. Okay. Could you just write in the white
4 space above it “back” and put an arrow down to that.
5 Can you tell us, what are the areas depicted
6 in this particular part of Exhibit 339.
7 A. This is the bathroom. There was an area
8 back -- I don’t know. It was an area back here
9 where the flight attendant would make the food and
10 stuff.
11 Q. Okay.
12 A. And then the luggage is way in the back.
13 Q. Okay. So show us the bathroom again.
14 A. Right here.
15 Q. Okay. So that little white box that’s on
16 the screen there, do you see the little white box.
17 Is that part of the bathroom, on the lower part.
18 A. Yeah.
19 Q. Why don’t you write “BR” in there.
20 Okay. We’re going to slide the Exhibit 339
21 all the way to the other end. Okay.
22 So I take it that would be the front part of
23 the plane.
24 A. Yes.
25 Q. So could we just write “front” on there, if
26 you would.
27 Do you remember where the door to the plane
28 is where you got on. 674
1 A. It’s right there.
2 Q. Okay. Do you want to write “door” in that
3 space.
4 All right. I think we’re done with that
5 exhibit. Thank you.
6 May I have a moment, Your Honor. We can
7 turn the lights back on.
8 All right. Now, that exhibit that you put
9 in front of you, that’s 339, the plane.
10 A. Yes.
11 Q. Would you please just write your name on it.
12 Because we’re going to have several of those, and we
13 want to make sure that we have your name on it.
14 Thank you. Now, one other thing that I
15 think that I probably forgot to ask you that needs
16 to be asked: You told the ladies and gentlemen of
17 the jury that your brother had been diagnosed with
18 cancer.
19 A. Yes.
20 Q. And that he had had a battle with cancer,
21 and had been going to the hospital and out of the
22 hospital from time to time.
23 A. Yes.
24 Q. How long was it before -- how long did it
25 last. How long did that illness last.
26 A. A year.
27 Q. And what happened at the end of the year.
28 A. He was in remission. There was no more -- 675
1 they couldn’t find no more cancer cells.
2 Q. So it was a year from when it first happened
3 to when it went into remission.
4 A. Yes.
5 Q. Can you peg that for us in terms of where
6 you were in your schooling when he actually went
7 into remission.
8 A. My sophomore year.
9 Q. Was your father still in the house at the
10 time that he -- that Gavin -- Gavin went into
11 remission.
12 A. No.
13 Q. He was already gone.
14 A. Yes. He had left the month before.
15 Q. I’m sorry.
16 A. He had left the month before.
17 Q. Okay. Let’s move back to where we were
18 chronologically. And we’re talking about on the
19 plane coming from Miami.
20 Now, when the plane landed, did you know
21 where you were.
22 A. We were back in -- near the Neverland Ranch.
23 Q. And when you got off the plane, where did
24 you go.
25 A. We got picked up in a limo and we got took
26 to the ranch.
27 Q. Now, could you tell us, when you got off the
28 plane and you got into the limo, was it night or 676
1 day.
2 A. It was night.
3 Q. Do you remember about what time it was.
4 A. No. It was just pitch black.
5 Q. So you got into the limo. And were there
6 any stops between the airport and the ranch, to your
7 knowledge.
8 A. No. No.
9 Q. And when you got to the ranch, where did you
10 go.
11 A. I went to the guest room.
12 Q. Was it the same one you were in before or a
13 different one.
14 A. It was the same one.
15 Q. And do you know -- did you go in your mom’s
16 room, wherever your mom was staying.
17 A. Not that night. Just to say goodnight, but
18 not to stay there.
19 Q. So you went in there to say goodnight.
20 A. Yeah.
21 Q. Where was she staying.
22 A. She was staying next to me.
23 Q. Okay. In the guest quarters.
24 A. Yes.
25 Q. Now, with regard to your brothers, did you
26 see where they went when you got back to the ranch
27 and got out of the limo.
28 A. I just seen -- I saw them run off with Mr. 677
1 Jackson.
2 Q. I couldn’t hear you.
3 A. I just saw them run off with Mr. Jackson.
4 Q. Did you see in what direction they took off.
5 A. Towards the main house.
6 Q. Did you -- how far did you see them go
7 before you went and did something else.
8 A. I just saw them go into the main house.
9 Q. So you actually saw them go into the house.
10 A. Yeah.
11 Q. Did you see them at all the rest of that
12 night.
13 A. No.
14 Q. Now, while you were at the ranch now, had
15 you missed school.
16 A. No, because I was off track at that time.
17 Q. What does that mean.
18 A. I go to -- at that time I was on a
19 year-round school. So I would go to school for
20 three months; get three months off; and go to school
21 for three months.
22 Q. Now, you told us that when you were -- when
23 you heard about the trip to Miami, you called your
24 mom on a pay phone.
25 A. Yeah, it was like a couple days before the
26 vacation.
27 Q. But were you in school at that time.
28 A. I was in summer -- in like -- they have two 678
1 intersessions. One like summer school, but they had
2 it during the winter.
3 Q. Okay.
4 A. And I think I was -- I had some classes.
5 That’s why I was at school.
6 Q. Okay. And were your brothers, to your
7 knowledge, in school.
8 A. I think they were.
9 Q. Do you remember which school they were going
10 to at this time. By “this time,” I mean when you’re
11 at Neverland Valley Ranch after you’ve come back
12 from Miami.
13 A. I think they were in Hollenbeck. But I
14 couldn’t remember. I don’t remember really.
15 Q. Okay. At any time after you arrived back at
16 the ranch that night, did the person you described
17 previously as Dieter, the one you met in Miami at
18 the hotel --
19 A. Yes.
20 Q. -- did you ever see him on the ranch.
21 A. Later on.
22 Q. Okay. How many days later was it.
23 A. I think it was the next day or the following
24 day.
25 Q. Did you ever see the person that you named
26 as Ronald and identified in the photograph, did you
27 see that person come to the ranch.
28 A. Yes. 679
1 Q. Do you remember when that was.
2 A. Around the same time as Dieter.
3 Q. And during the time that you got to the
4 ranch, and when these two individuals arrived at the
5 ranch, did you know whether or not they were staying
6 at the ranch.
7 A. Yeah. I think so. Because they were there
8 all day from -- I’d see them.
9 Q. When you saw them, can you tell us whether
10 or not you ever saw them with Mr. Jackson.
11 A. Yes.
12 Q. On how many occasions during those first
13 days.
14 A. Well, anytime I’d really come into the main
15 house --
16 Q. You have to speak up.
17 A. Anytime I really, like, passed by the main
18 house, I would see them occasionally talking with
19 each other. But I really don’t remember.
20 Q. Okay.
21 A. It was a couple of times.
22 Q. Did you ever see them meeting and talking in
23 any other places on the location there.
24 A. No, not that I remember.
25 Q. Okay.
26 A. Like later on they would meet in the guest
27 quarters, but -- like Mr. Jackson and Ronald. But
28 not at the beginning. 680
1 Q. I couldn’t hear that.
2 A. Like later on --
3 Q. Okay.
4 A. -- like Mr. Jackson and Ronald would meet in
5 the guest quarters. But other than that, no.
6 Q. Okay. That was later on, though.
7 A. Yes.
8 Q. Now, did you personally have any contact
9 with the people -- let’s say Dieter first. Let’s
10 start with the person you described as Dieter. Did
11 you ever have any conversations with him.
12 A. Couple times.
13 Q. What were the subjects of the conversations.
14 A. On the rebuttal film and us going to Brazil.
15 Q. All right. Let’s talk about the rebuttal
16 film, all right. What did Dieter tell you about the
17 rebuttal film. And first of all, let’s go back.
18 Where did -- excuse me.
19 Where did that conversation take place.
20 A. There was one conversation in one of the
21 guest quarters with me and my mom and my brothers.
22 Q. All right. Anybody else present.
23 A. No, it was just Dieter and us.
24 Q. And how many days do you think it was that
25 you’d been there before that conversation occurred.
26 A. Less than a week. Three days, four days.
27 Q. And what was the subject matter of the
28 conversation. 681
1 MR. MESEREAU: Objection; hearsay.
2 MR. SNEDDON: It’s offered under 223.
3 THE COURT: I’ll accept it conditionally.
4 Excuse me. I’ll accept the testimony conditionally
5 under the instructions I gave you earlier.
6 Q. BY MR. SNEDDON: Go ahead.
7 A. It was about the watch.
8 Q. All right. What about the watch.
9 A. He wanted it back.
10 Q. Who wanted it back.
11 A. Dieter wanted it back from Gavin.
12 Q. And what was said.
13 A. That he wanted it back; that he could put it
14 in a safe and take care of it for him and he might
15 lose it, and he just wanted it back.
16 Q. All right. And did he get it back.
17 A. No.
18 Q. Why.
19 A. Gavin didn’t want to give it to him.
20 Q. What was your mother’s attitude towards
21 that.
22 A. Just -- she didn’t see no point in it. She
23 just -- whatever Gavin wanted.
24 Q. Now -- I got it. It’s all right.
25 Now, you told us that the other
26 conversations that you had with this gentleman
27 Dieter involved the rebuttal film.
28 A. Yes. 682
1 Q. Okay. Now, when you talk about a rebuttal
2 film, what do you mean by that.
3 A. They said they wanted to do another video,
4 and they wanted it to just be of us.
5 Q. Who’s “they”.
6 A. Dieter and Frank talked about it.
7 Q. Now, when -- let’s talk about Dieter first
8 of all, okay. When did you have a conversation with
9 Dieter about this rebuttal film.
10 A. I think it was in -- near, like, the kitchen
11 area. In that area. Like in the sitting area.
12 Q. Okay. And do you recall how long you’d been
13 at the ranch before -- when that conversation took
14 place.
15 A. It was after the watch incident, so five
16 days or so. I think.
17 Q. What did he say about -- what did he say to
18 you about the rebuttal.
19 MR. MESEREAU: Objection; hearsay.
20 MR. SNEDDON: Offered for the same purpose,
21 Your Honor.
22 THE COURT: All right. I’ll accept it
23 conditionally.
24 Q. BY MR. SNEDDON: Go ahead.
25 A. It was just -- we were supposed to say nice
26 things about him and just -- and he offered us -- to
27 give us a paper.
28 Q. A paper. What do you mean by “a paper”. 683
1 A. It was kind of like a script, just of things
2 to say.
3 Q. Did you read it.
4 A. Yeah.
5 Q. Do you remember what was on it.
6 A. Just nice things of Mr. Jackson, and that’s
7 it.
8 Q. Now, at some point in time after you arrived
9 at the ranch from Miami, and you’re on the ranch,
10 okay --
11 A. Yes.
12 Q. -- did you leave.
13 A. From --
14 Q. From Neverland. I’m not asking you how
15 long. I’m just asking did you leave.
16 A. We left at -- just to do the rebuttal.
17 Q. Okay.
18 A. And there was -- that’s all I remember,
19 yeah.
20 Q. Do you remember meeting a man at the ranch
21 by the name of Jesus.
22 A. Yes.
23 Q. Okay. Who is Jesus.
24 A. He’s one of the security guards there or
25 just one of the head people around the ranch.
26 Q. And did you ever leave the ranch with Jesus.
27 A. Yeah. Now I remember, yeah.
28 Q. Do you recall with regard to that particular 684
1 incident -- between the time that you arrived at the
2 ranch at Neverland and the time that you left with
3 Jesus, okay. We’re talking about that time.
4 A. (Nods head up and down.)
5 Q. Where did your mother stay on the ranch.
6 A. She stood in the guest quarters.
7 Q. And could you tell us, under your personal
8 observations and opinion, did your mother come out
9 of the room very often.
10 A. Never.
11 Q. Why.
12 A. She just never came out, and then --
13 MR. MESEREAU: Objection. Calls for
14 speculation; hearsay. And no foundation.
15 MR. SNEDDON: Let me see if I can go back
16 and cure it a little bit, Judge. I think I can do
17 that without any problem.
18 THE COURT: All right.
19 Q. BY MR. SNEDDON: Okay. During the time that
20 you got from Miami and you got to the ranch --
21 A. Yes.
22 Q. -- to the time that you left with Jesus,
23 okay --
24 A. Yes.
25 Q. -- where were your brothers.
26 A. They were running around with Mr. Jackson.
27 Q. Did you see much of them.
28 A. Not really. 685
1 Q. So the only person that you know on the
2 ranch was your mother.
3 A. Yes.
4 Q. And did you spend time with your mother.
5 A. Yes.
6 Q. And where did you spend time with your
7 mother.
8 A. In her room.
9 Q. And your room was next door to your mother’s
10 room.
11 A. Yes.
12 Q. So, do you have an opinion with regard to
13 how much your mother came out of her room.
14 A. Hardly never. Not really at all.
15 Q. During the time that you were there from --
16 you got back from Miami and before you left with
17 Jesus - okay. - how long was that; do you recall.
18 A. I’m sorry, repeat the question. I was
19 thinking about me and my mom in the room.
20 Q. Did I forget to ask you something about you
21 and your mom.
22 A. No, just thinking about the whole situation.
23 Can you repeat the question.
24 Q. Sure. From the time you arrived at the
25 ranch till the time you left with Jesus, okay, how
26 many days do you think that was.
27 A. I don’t remember. Close to a week or less.
28 I don’t remember. 686
1 Q. Okay.
2 A. It had been a while, though.
3 Q. Now, had -- can you describe your mother’s
4 demeanor and attitude during the time that she was
5 at the ranch between the time you got there and the
6 time you left with Jesus.
7 A. She seemed kind of worried and just didn’t
8 really understand the whole situation, what was
9 really going on. And she was kind of scared.
10 Q. Now, when -- when you left with Jesus, do
11 you remember what time of the night or day it was
12 that you left.
13 A. It was night.
14 Q. How do you know that.
15 A. Because it was really dark out.
16 Q. And do you remember the circumstances under
17 which you left.
18 A. Yeah, we were scared and we just --
19 MR. MESEREAU: Objection. Hearsay;
20 foundation; calls for speculation.
21 THE COURT: Overruled.
22 Q. BY MR. SNEDDON: Go ahead.
23 A. We were kind of scared and we just really
24 didn’t -- the way the conversations with Dieter
25 went, they were real aggressive and just -- we were
26 scared, so -- of course Gavin didn’t want to leave.
27 But my mom and me, mainly my mom wanted to get us
28 out of there. 687
1 Q. All right. And then do you recall how Mr.
2 Salas -- I’m sorry, how Jesus got involved in this.
3 A. My mom asked him to take us to home.
4 Q. Were you present when she did that.
5 A. Not that I remember.
6 Q. So at some point you were told what, by your
7 mom.
8 A. By my mom, that we were leaving.
9 Q. And you gathered up your stuff, I take it.
10 A. Some little things. Not really. We just
11 really wanted to get out of there.
12 Q. And then what did you do.
13 A. We left.
14 Q. And who went.
15 A. Jesus, me, my brothers and my mom.
16 Q. Now, I don’t want you to speak for anybody
17 else, okay. I want you to speak for yourself. Why
18 was it that you felt that you were scared.
19 A. Just the whole situation. The whole
20 secrecy. The -- just real aggressive. I was just
21 scared. I didn’t understand what was going on and
22 why it was like this. I was just scared.
23 Q. Did you -- during this time, when you first
24 got to the ranch and before you left with Jesus, did
25 you have any interaction with the defendant in this
26 case, Mr. Jackson.
27 A. Just little interaction, yeah.
28 Q. All right. And can you describe that. 688
1 A. Hi; a hug; there would be times where I’d
2 walk in where Mr. Jackson and the boys and Aldo
3 would be and just say hi and stuff like that. But I
4 would leave immediately.
5 Q. Why.
6 A. Because they would tell me, “Oh, don’t you
7 want to go do that.” And just felt uncomfortable,
8 like if they didn’t want me there.
9 Q. So, just to fill in the rest of it for the
10 jury, the people that you’ve identified in those
11 photographs as Aldo and Marie Nicole, did they go to
12 the ranch at the same time that you folks did. From
13 the limo, from the plane, to the ranch.
14 A. Yes.
15 Q. And they were there.
16 A. Yes.
17 Q. And do you know where Marie Nicole was
18 staying.
19 A. She stood in the main house.
20 Q. And how do you know that.
21 A. Because we would talk and stuff. And then I
22 stood in the room with her at one time, just sitting
23 and talking.
24 Q. To your knowledge, at any time did the boys
25 come back and stay in the guest cottage.
26 A. One time Star did.
27 Q. Between the time that you arrived from Miami
28 till the time you left with Jesus, did the boys come 689
1 back and stay in the guest cottage.
2 MR. MESEREAU: Objection; foundation.
3 THE COURT: Sustained.
4 Q. BY MR. SNEDDON: To your knowledge, based
5 upon what you saw and observed, did you ever see the
6 boys stay the night in the guest cottage before you
7 left with Jesus.
8 MR. MESEREAU: Same objection; foundation.
9 THE COURT: Overruled.
10 You may answer.
11 THE WITNESS: Um, I think that was after,
12 after we came back.
13 Q. BY MR. SNEDDON: What was after.
14 A. The incident with Star coming to sleep in
15 the room. It was after we had come back.
16 Q. Come back from.
17 A. I don’t know where it was placed. All I
18 know, there was one incident Star came and slept
19 with me in the room.
20 Q. Okay. So there was one time.
21 A. Yeah.
22 Q. All right. Can you tell us whether or not,
23 from your own personal observation -- strike that.
24 Did you see your mother interact with Dieter
25 and Ronald.
26 A. There was one incidence I saw him coming out
27 of my mom’s room, but -- I don’t remember. She
28 would tell me -- 690
1 Q. Don’t tell us what she said.
2 A. Okay.
3 Q. It’s not your fault.
4 A. From what I saw, no.
5 Q. You weren’t present during those
6 conversations.
7 A. No.
8 Q. But there were occasions when you saw Dieter
9 and Ronald coming out of your mom’s room.
10 A. Yeah.
11 Q. Did you go into -- don’t tell us what she
12 said. But after that, did you go in to see her
13 right away.
14 A. Yeah.
15 Q. Could you tell us whether or not she was
16 upset.
17 A. Yes. She seemed upset.
18 MR. MESEREAU: Objection.
19 I’ll withdraw the objection.
20 Q. BY MR. SNEDDON: Now, when you left with
21 Jesus, do you remember where you were taken.
22 A. Yes.
23 Q. Where were you taken.
24 A. To my grandmother’s house.
25 Q. And was your grandmother still living in El
26 Monte.
27 A. Yes.
28 Q. Now, after -- I’m sorry. Now, after you got 691
1 to -- got to El Monte, do you remember what time it
2 was.
3 A. It was night.
4 Q. Still night.
5 A. Uh-huh.
6 Q. So that night, did you spend the night there
7 with your grandparents.
8 A. Yes.
9 Q. At this point, was -- to your knowledge, was
10 your mother still seeing Major Jackson.
11 A. Yes.
12 Q. And, in fact -- let me put it this way: At
13 the point before you left for Miami, okay, for the
14 trip to Miami, was she still seeing Major Jackson.
15 A. Yes.
16 Q. At that point in time, was your mother
17 staying at the Soto Street address or with Major
18 Jackson.
19 A. Um --
20 Q. If you know.
21 A. At the very beginning we were still staying
22 at the Soto apartment.
23 Q. Okay.
24 A. And then would go sleep over at his house,
25 but we were still living at the Soto apartment.
26 Q. When you got back from Neverland Ranch,
27 you’re back at your grandparents’ place, all right.
28 Now, did you remain at your grandparents’ or did you 692
1 go somewhere else.
2 A. We went to Jay Jackson’s house.
3 Q. And do you remember how many days you were
4 there.
5 A. We didn’t sleep over that night.
6 Q. How about the next night.
7 A. I think that’s the day that the ladies came
8 over from -- the social workers.
9 Q. Do you ever remember --
10 MR. MESEREAU: Excuse me.
11 THE COURT: She’s not speaking loud enough.
12 You need to speak up.
13 MR. SNEDDON: Okay.
14 THE COURT: Would you like the answer read
15 back.
16 MR. MESEREAU: Yes, please, Your Honor.
17 Thank you.
18 THE COURT: Please.
19 (Record read.)
20 Q. BY MR. SNEDDON: Okay. Do you remember an
21 incident at Jay Jackson’s apartment where a private
22 investigator came to the apartment.
23 A. Yes.
24 Q. Was that before or after the time you went
25 to talk to the social workers.
26 A. This was before.
27 Q. Was it before -- well, was it after you left
28 the ranch with Mr. Jesus. 693
1 A. I think it was after. I don’t remember.
2 Q. Do you remember what day of the week it was.
3 A. No.
4 Q. Okay. Describe the meeting to us, if you
5 would.
6 A. Mr. Miller came in and --
7 Q. You knew his name.
8 A. Yes.
9 Q. Okay. What was it.
10 A. Mr. Bradley Miller.
11 Q. Okay. Go ahead.
12 A. Mr. Miller -- we all sat on the -- Jay’s
13 couch, and -- me and my mom and my brothers and Jay
14 and Mr. Miller. And Mr. Miller just told us to say
15 what we thought about our father and say how we felt
16 about Mr. Jackson.
17 Q. Did -- did you remain during the entire time
18 that Mr. Miller was there.
19 A. Yes.
20 Q. To your knowledge, did you ever see a
21 tape-recorder.
22 A. Yes.
23 Q. Where was the tape-recorder.
24 A. It was placed on the glass table.
25 Q. Whose tape-recorder was that.
26 A. That was Mr. Miller’s.
27 Q. And during the course of the conversations
28 between you and Mr. Miller, did he ever turn it off. 694
1 A. Yes.
2 Q. Do you remember how many times he did that.
3 A. It was several times. But he would turn it
4 off and say “Um, that’s not necessary. You don’t
5 need to talk about that. Let’s start over. I want
6 to talk about this now,” and he would restart the
7 tape.
8 MR. MESEREAU: Objection.
9 THE COURT: Just a moment. Overruled.
10 Go ahead. Overruled.
11 Q. BY MR. SNEDDON: Okay. Go ahead.
12 A. He would start to rewind it and say,
13 “That’s” -- “You don’t need to say that.”
14 Q. Do you remember how long the conversation
15 with Mr. Miller lasted.
16 A. Half an hour, I think.
17 Q. Now, at some point after this tape-recorded
18 conversation with this person you knew as
19 Mr. Miller -- okay. -- did you go back to the ranch.
20 A. Yes.
21 Q. And who did you go back to the ranch with.
22 A. My brothers and my mom.
23 Q. And how did you get back to the ranch.
24 A. Someone came and picked us up.
25 Q. Now, do you remember the name of the person
26 who picked you up.
27 A. I don’t remember who it was.
28 Q. When you were picked up, do you remember 695
1 where you were when you got picked up.
2 A. At Jay’s apartment.
3 Q. You’re going to have to speak up.
4 A. At Jay’s apartment.
5 Q. That’s great. Just keep it right like that.
6 Okay. At Jay’s apartment. And where did
7 you go.
8 A. To Neverland Ranch.
9 Q. Were there any stops made between the point
10 you left Major Jackson’s place and you got to the
11 ranch, to your knowledge or recollection.
12 A. I think there was a point that we stopped
13 at Jamie’s, The Laugh Factory.
14 Q. You have to --
15 A. I think that was the point that we stopped
16 at The Laugh Factory.
17 Q. You remember there was an incident that you
18 stopped at The Laugh Factory.
19 A. Yeah.
20 Q. Okay. You got back to the ranch at some
21 point, correct.
22 A. Yeah.
23 Q. And when you got back to the ranch, did you
24 see anybody at the ranch that you recognized that
25 had been there before, when you first got there.
26 A. Frank was there. And I met Vinnie.
27 Q. Can you tell us whether or not Dieter was
28 there. 696
1 A. I don’t think he was. I don’t remember.
2 Q. When you guys got back to the ranch on this
3 occasion, did your mother stay with you.
4 A. I think she did. I’m trying to place where
5 I was at.
6 Q. All right. Take a second and place it,
7 okay.
8 A. Okay.
9 I think so.
10 (Off-the-record discussion held at counsel
11 table.)
12 MR. SNEDDON: Excuse me just a second, Your
13 Honor. It will take me just a second, Your Honor.
14 Q. Let me ask you something else while I’m
15 looking for this. Let’s go back just a moment in
16 time.
17 At the time you were at the ranch before you
18 left with Mr. Salas, with Jose -- Jesus, did you
19 hear anybody threaten you or any member of your
20 family.
21 MR. MESEREAU: Objection; leading.
22 THE COURT: Sustained.
23 THE WITNESS: Um --
24 THE COURT: Just a moment. He’ll have to ask
25 you another question.
26 THE WITNESS: Oh.
27 Q. BY MR. SNEDDON: Well, can you tell us
28 whether or not you personally ever received any 697
1 comments from somebody that scared you.
2 MR. MESEREAU: Objection; leading.
3 MR. SNEDDON: It’s not a leading question.
4 It’s an open-ended question.
5 THE COURT: All right. Overruled.
6 THE WITNESS: There was one point that Frank
7 had told us that there was death threats on us.
8 Q. BY MR. SNEDDON: All right. Okay. Do you
9 remember a point in time where you -- let me ask
10 this question: Have you ever been to the residence
11 of Hamid Moslehi.
12 A. Yes.
13 Q. And what was going on when you went to his
14 house. Why did you go there.
15 A. That’s where we did the rebuttal at.
16 Q. And where had you been prior to going to his
17 house.
18 A. The ranch.
19 Q. And who was at the ranch at that time.
20 A. Frank -- no, Frank wasn’t there. Vinnie
21 was --
22 Q. Let me ask it this way: How did you get
23 from the ranch to his house.
24 A. Hamid came and picked us up.
25 Q. Who did.
26 A. Hamid.
27 Q. Who was in the car with you.
28 A. Me, my mom and my brothers. 698
1 Q. Okay. And you went to where.
2 A. To his house.
3 Q. Okay. And what was the -- what was the --
4 why were you there.
5 A. To do the rebuttal film.
6 Q. Now, before you left the ranch that
7 particular night, did you have a conversation with
8 anybody about the film.
9 A. Yes.
10 Q. And who was that.
11 A. Dieter.
12 Q. And what did Dieter tell you.
13 A. To say nice things.
14 MR. MESEREAU: Objection; hearsay.
15 MR. SNEDDON: Same purpose, Your Honor.
16 THE COURT: Overruled.
17 THE WITNESS: To say nice things and to not
18 talk about what goes on around the ranch.
19 Q. BY MR. SNEDDON: I’m sorry.
20 A. What goes on in the ranch.
21 Q. I didn’t hear you. You’re going to have to
22 lean in there and talk --
23 A. To say nice things about Mr. Jackson.
24 Q. And you said something else.
25 A. And to not talk about what goes on in the
26 ranch.
27 Q. Where did this conversation take place.
28 A. I think it was the main house. 699
1 Q. What -- what time was it when you left the
2 ranch.
3 A. It was night.
4 Q. Was it dark outside.
5 A. Yeah. It was late night.
6 Q. When you got to Hamid’s house, who else was
7 there.
8 A. Frank was there. Vinnie was there. And
9 another male, younger male was there. And Bradley
10 was there, Mr. Miller was there.
11 Q. Okay. And that night, you eventually ended
12 up in a video; is that correct.
13 A. Yes.
14 Q. An interview.
15 A. Yes.
16 Q. Do you remember the name of the gentleman
17 who actually did the interviewing.
18 A. No. I don’t remember. He was a young male.
19 Q. Can you describe him at all.
20 A. Thin face. White skin. He was
21 young-looking. I don’t remember.
22 Q. Now, before -- when you got to Mr. -- when
23 you got to Hamid’s house and before the filming took
24 place, what were you doing. You personally, what
25 were you doing. Where you were in the house.
26 A. In Hamid’s house.
27 Q. Yes.
28 A. Standing, facing the -- like the area where 700
1 we filmed it.
2 Q. Did you see where your mother was in the
3 house.
4 A. She was getting ready, like in the rest
5 room, like --
6 Q. Did you see your mom have any conversations
7 with anybody.
8 A. Don’t remember.
9 Q. Okay. Now, who participated in the video.
10 A. Me, my mom and my brothers.
11 Q. And how long did it last.
12 A. Very long time. We were there until, I
13 think it was like 4:00 in the morning.
14 Q. Now, during the interview -- I want you to
15 speak for yourself, okay.
16 A. Okay.
17 Q. Nobody else. During the interview, you were
18 depicted at one point crying on the interview.
19 A. Yes.
20 Q. Okay. And why were you crying.
21 A. I was crying for my brother.
22 Q. And why were you crying for your brother.
23 A. Because I was talking about things about
24 him.
25 Q. What was so upsetting about that.
26 A. Because Gavin had heard, like, people say
27 that he was a faggot. And he would cry to me about
28 that. And that hurt me, being his older sister. I 701
1 wanted to protect him any way I can.
2 Q. Were there any other things that you had
3 heard that were upsetting you when you were talking
4 on this video that made you cry.
5 MR. MESEREAU: Objection; leading.
6 THE WITNESS: No.
7 THE COURT: Overruled.
8 You may answer.
9 THE WITNESS: The only thing that hurt me
10 was things about my brother. There was no other
11 reason to cry.
12 Q. BY MR. SNEDDON: Didn’t have anything to do
13 with the defendant.
14 A. No.
15 MR. MESEREAU: Objection.
16 THE COURT: Leading; sustained. The answer
17 is stricken.
18 Q. BY MR. SNEDDON: On the video, there are
19 some statements with regard to Mr. Jackson
20 helping -- helping you kids with homework. Do you
21 remember those statements.
22 MR. MESEREAU: Objection; leading.
23 MR. SNEDDON: Just foundational, Your Honor.
24 MR. MESEREAU: And hearsay.
25 THE COURT: Yeah, the objection is overruled.
26 You may answer the question. I’ll have it
27 read back for you.
28 (Record read.) 702
1 THE WITNESS: Yes.
2 Q. BY MR. SNEDDON: Did Mr. Jackson ever help
3 you with your homework.
4 A. No.
5 Q. Why are you smiling about that.
6 A. Becasue they took us out of school. There
7 was no homework to help us with.
8 Q. On the video, there are statements to the
9 effect that Mr. Jackson was always there and you had
10 a phone number where you could call him.
11 A. Uh-huh.
12 Q. Do you remember that.
13 A. Yeah.
14 MR. MESEREAU: Objection. Leading.
15 THE COURT: Overruled.
16 Q. BY MR. SNEDDON: Was that statement true.
17 A. No.
18 Q. Why.
19 A. Because any phone number we had of him, that
20 Gavin had of him, it would get disconnected.
21 MR. MESEREAU: Excuse me, Your Honor. I
22 didn’t quite hear that. Could I have it read back,
23 please.
24 THE COURT: Yes.
25 MR. MESEREAU: Thank you.
26 (Record read.)
27 MR. MESEREAU: Thank you.
28 Q. BY MR. SNEDDON: At this particular point in 703
1 time, with regard -- I only want you to speak for
2 yourself, not for anybody else on that video. Okay.
3 There are statements on that video that --
4 about people thinking of Mr. Jackson as family.
5 A. Yeah.
6 Q. And as your dad.
7 A. Yeah.
8 Q. Or daddy. Only speaking for yourself at
9 this point in time, were those sentiments that you
10 shared.
11 A. At the beginning, I found him like a close
12 friend, but they started changing, my feelings
13 towards him.
14 Q. Why.
15 MR. MESEREAU: Objection; nonresponsive.
16 THE COURT: Just a moment, please.
17 Sustained; nonresponsive.
18 Do you want the question read back.
19 MR. SNEDDON: I do, because I thought it
20 was. Maybe I can look at it on the screen or read
21 it back.
22 (Record read.)
23 THE COURT: I sustained the objection. I
24 didn’t mean for you to read the answer.
25 THE REPORTER: I’m sorry.
26 THE COURT: The question was -- just
27 rephrase the question so we can move on.
28 Q. BY MR. SNEDDON: With regard to the 704
1 statements about considering Michael Jackson, the
2 defendant in this case, as “Daddy” or “Michael
3 Daddy,” did you share those sentiments.
4 A. No.
5 Q. Did you share them at one time.
6 A. As a close friend, yes.
7 Q. Pardon.
8 A. I felt him as a close friend, yes.
9 Q. When was that.
10 A. At the beginning.
11 Q. Now, after this -- before you went up to
12 the -- let’s go back, now, before you’ve gone to the
13 filming, okay. What was the atmosphere like for you
14 personally at the ranch before the filming.
15 A. It was just a lot of secrecy. I was mainly
16 by myself. Or other times I would go in my mom’s
17 room. Just -- I don’t know. It was weird.
18 Q. Did you have any interaction with Dieter,
19 with the person you’ve identified as Dieter.
20 A. Not by myself, no.
21 Q. Not by yourself. With you and others.
22 A. Yeah, with my brothers. Like he would pull
23 us aside and talk to us and he would say, “I need to
24 talk to you guys.”
25 Q. And what would he talk to you about.
26 A. Well, during the time of the rebuttal film,
27 he had told us about the death threats.
28 MR. MESEREAU: Objection; hearsay. 705
1 MR. SNEDDON: Same offer, Your Honor.
2 THE COURT: Conditionally admitted.
3 Q. BY MR. SNEDDON: Okay. Could you start over
4 again about what Dieter told you.
5 I don’t know why I’m leaning into this.
6 It’s not on.
7 A. Other than the rebuttal film, it was that he
8 told us there was death threats on us. And that’s
9 why we needed to leave.
10 Q. All right. After the filming took place,
11 where did you go. After you filmed at Hamid’s
12 house, where did you guys go that night.
13 A. Vinnie took us -- we stood at a hotel in
14 Calabasas, I think. I think that was a period of
15 time.
16 Q. Did you remember a situation where you met
17 with some social workers.
18 A. Yes.
19 Q. And when did that occur. Before or after
20 the rebuttal film.
21 A. That was after the rebuttal film.
22 Q. Do you remember when in relationship to the
23 rebuttal film, in terms of time.
24 A. After.
25 Q. Okay. Bad question. How long after.
26 A. I think it was the next day. Next morning.
27 That morning. Because we did -- we slept -- we
28 didn’t really get that much sleep, and then the 706
1 ladies came that morning.
2 Q. Okay. Where did the interview occur.
3 A. At Jay’s house.
4 Q. How did you get to Jay’s.
5 A. Vinnie took us.
6 Q. From where.
7 A. From Hamid’s house.
8 Q. From Hamid’s house.
9 A. Yeah.
10 Q. Now, were you a part of that conversation.
11 A. Yes.
12 Q. And prior to the time -- let’s just try it
13 this way. What time -- do you remember what time it
14 was when everybody started to arrive at the
15 apartment.
16 A. It was early. Late morning, early -- yeah,
17 it was early afternoon.
18 Q. Okay. So who’s at the apartment.
19 A. Um --
20 Q. Before anybody arrives, who’s at the
21 apartment.
22 A. Jay -- no. Jay wasn’t there. It was me, my
23 mom, my brothers.
24 Q. Who’s the first person to arrive.
25 A. Aja is.
26 Q. And Aja is who.
27 A. Chris Tucker’s fiancee.
28 Q. Okay. And when they arrived, did she bring 707
1 somebody with her.
2 A. She brought her little baby, Dustin.
3 Q. And who arrived after that.
4 A. One of Mr. Jackson’s security bodyguards.
5 Q. Can you describe this guy for us.
6 A. He was a big man, light skin, blondish-type
7 hair, orange, I don’t know. And he was just -- big
8 arms.
9 Q. Called “buffed”.
10 A. Yeah.
11 Q. All right. Now, had you ever met him before
12 at this point in time.
13 A. No.
14 Q. And were you present when he actually came
15 into the apartment.
16 A. Yes.
17 Q. Did you answer the door.
18 A. No. I think the door was open.
19 Q. And did you hear him identify himself.
20 A. Yeah. He talked to my mom.
21 Q. Okay. Now, did anybody else arrive before
22 the social ladies -- social workers.
23 A. Other than Aja and the bodyguard, no.
24 Q. Now, do you recall what happened when the
25 social service ladies arrived.
26 A. They asked everybody to leave. They only
27 wanted to talk to me and my mom and my brothers.
28 Q. How many ladies came. 708
1 A. Three ladies.
2 Q. Do you remember their names at all.
3 A. No.
4 Q. Now, did anything happen before, or at the
5 time that the ladies asked everybody to leave.
6 A. Yeah.
7 Q. What happened.
8 A. There was a time that Mr. Jackson’s
9 bodyguard pulled my mom aside into her room -- well,
10 Jay’s room.
11 Q. So you couldn’t hear what was going on
12 inside that room.
13 A. No.
14 Q. Could you see anything.
15 A. Well, after he left --
16 Q. No --
17 A. Not after he left, but like the door --
18 Q. Let me rephrase the question. At that time,
19 when your mother and the bodyguard walked into the
20 bedroom, could you see anything at that point in
21 time.
22 A. No.
23 Q. Okay. Now, later, did you go into that
24 bedroom.
25 A. Later I could see into the bedroom.
26 Q. Okay. And what did you see.
27 A. There was, like, a black little square thing
28 on the bed. And I saw my mom grab it and put it on 709
1 top -- inside the closet, on top.
2 Q. Okay. Now, did -- were there any other
3 things that occurred before you started your
4 interview with the ladies.
5 A. No.
6 Q. Did you see a video played at any time.
7 A. Not that I remember.
8 Q. All right. Tell us what happened during the
9 interview. Who’s present during the interview.
10 A. Me, my mom and my brothers and the three
11 ladies.
12 Q. And were you interviewed all at the same
13 time or at separate times.
14 A. All together.
15 Q. And how did that occur.
16 A. They just asked us what were the sleeping
17 arrangements, how we felt about Mr. Jackson, and
18 that’s what I remember.
19 Q. Do you remember what you said during that
20 time.
21 A. I don’t remember.
22 Q. Were you present during the entire
23 conversation. All of you stayed there the whole
24 time.
25 A. Yes.
26 Q. Okay. Now, how long did that conversation
27 take.
28 A. About 30 minutes. It wasn’t that long. 710
1 Q. And you guys -- when I say “you guys,” you
2 and your brothers and your sister and your mother --
3 all remained in the same room through the entire
4 conversation.
5 A. Me and my brothers and my mom, yeah.
6 Q. Yeah, your sister. I apologize.
7 Now, after that conversation with the social
8 ladies - all right - where did you go.
9 A. Aja took us back to the ranch, because --
10 Q. Took “us.” Who is “us”.
11 A. Me and my brothers. My mom stayed. But the
12 bodyguard wanted to take us, but we asked Aja to
13 take us.
14 Q. So the bodyguard was still there when you
15 guys finished the meeting.
16 A. Afterward. We didn’t know where he went.
17 And then he showed up afterwards. And we were,
18 like, near Aja’s car, and we were saying bye to her.
19 Q. And where did your mother go, to your
20 knowledge.
21 A. She stood there at Jay’s apartment.
22 Q. So you went back to the ranch, and did you
23 stay there, that night, at the ranch.
24 A. Yes.
25 Q. Okay.
26 MR. SNEDDON: All right. I want to show
27 some photographs at this point.
28 All right. We’ve had a little break here. 711
1 I’ll just move this over.
2 All right. You ready.
3 MR. MESEREAU: Yes.
4 MR. SNEDDON: I didn’t want to start --
5 MR. MESEREAU: Thank you.
6 Q. BY MR. SNEDDON: The photograph you have in
7 front of you is People’s 19 for identification. Do
8 you recognize that.
9 A. Yes.
10 Q. I’m sorry. Do you recognize that. Is that
11 an accurate depiction of the person it represents.
12 A. Yes.
13 Q. Just flip that over, if you could.
14 Now, turn that one sideways. No, the other
15 one, the new one, so I can see the number.
16 All right. That’s People’s 30 for
17 identification. Do you recognize the person in this
18 photograph.
19 A. Yes.
20 Q. And is that an accurate depiction of that
21 person.
22 A. Yes.
23 Q. Okay. Why don’t you turn that one over.
24 And People’s 23, do you recognize that
25 person.
26 A. Yes.
27 Q. Is that an accurate depiction.
28 A. Not really. 712
1 Q. Okay. He’s a little different than when you
2 saw him, right.
3 A. Yes, he’s --
4 Q. We’ll go into that in just a second. But
5 you recognize the person.
6 A. Yes.
7 Q. Okay. Now, the exhibit that you have there,
8 that you just turned sideways, is 194. And do you
9 recognize that.
10 A. Yes.
11 Q. Okay. Is that an accurate depiction of what
12 it represents.
13 A. Yes.
14 Q. Okay. Turn that over.
15 135. And do you recognize that.
16 A. Yes.
17 Q. And is that an accurate depiction.
18 A. Yes.
19 Q. Okay. And 138, do you recognize that.
20 A. Yes.
21 Q. And is that an accurate depiction.
22 A. Yes.
23 Q. All right. The last one, which is 125, do
24 you recognize that.
25 A. Yes.
26 Q. And is that an accurate depiction.
27 A. Yes.
28 Q. Okay. Why don’t you flip those back over in 713
1 the same order, and I’m going to ask you some
2 questions about them. And we’re going to show some
3 photographs.
4 MR. AUCHINCLOSS: Can we go to Input 1, Your
5 Honor. Thank you.
6 Q. BY MR. SNEDDON: All right. The photograph
7 that’s on the board there -- first of all, I’m
8 sorry, Your Honor, I apologize. I don’t think
9 there’s any issue, move to admit these exhibits that
10 have just been identified.
11 MR. MESEREAU: There’s no objection.
12 MR. SNEDDON: I’m sorry.
13 THE COURT: They’re admitted.
14 Q. BY MR. SNEDDON: What is the number of the
15 exhibit that’s on the board up there.
16 A. 19.
17 Q. Do you recognize that person.
18 A. Yes.
19 Q. Who is that.
20 A. Vinnie.
21 Q. Do you know Vinnie’s last name.
22 A. No.
23 Q. Okay. Why don’t you turn that one over,
24 then.
25 Do you remember where it was that you met
26 Vinnie for the very first time.
27 A. It was at the ranch.
28 Q. All right. The next -- what’s the number of 714
1 the next one in front of you.
2 A. That’s Jesus. No. 30.
3 Q. No. 30. Okay. And would you look up on
4 the -- that’s No. 30.
5 A. Yeah.
6 Q. Who is that.
7 A. Jesus.
8 Q. Okay. Where did you meet Jesus for the
9 first time.
10 A. At the ranch.
11 Q. Okay. And the next one. What number is
12 that.
13 A. 23.
14 Q. 23. And who is that.
15 A. That’s Bradley Miller.
16 Q. And you said that there’s something about
17 this photograph that’s a little different than you
18 remember about this individual at the time.
19 A. He’s bigger. He’s --
20 Q. I’m sorry.
21 A. He’s not as thin any -- he’s not as thin.
22 He’s fuller in the face.
23 Q. Now or then.
24 A. Now he’s fuller in the face.
25 Q. Okay. So he looks skinnier in this
26 photograph.
27 A. Yeah.
28 Q. Okay. And where was Mr. Miller the first 715
1 time that you met him; do you remember.
2 A. At Jay Jackson’s apartment.
3 Q. All right. Why don’t you turn that over and
4 we’ll get to the next one.
5 All right. What’s the number on that.
6 A. 194.
7 Q. 194. Okay. And what is one -- not that
8 one. Keep going. No, keep going.
9 Okay. Is that 194 that’s on the board there
10 now.
11 A. Yes.
12 Q. And with regard to that particular
13 photograph, what is that.
14 A. That’s Hamid’s house.
15 Q. And --
16 A. That’s where we filmed the rebuttal.
17 Q. In that room.
18 A. In that area.
19 Q. Okay. What part of the area. Take the
20 light. Take the light, that little meter, and show
21 the ladies and gentlemen of the jury where it is.
22 A. Right here. They moved the couch and they
23 put a screen behind us.
24 Q. Okay. Hold on just a second.
25 The next number that you have there.
26 A. It’s 135.
27 Q. Okay. What’s 135.
28 A. It’s -- it’s a -- it’s the kitchen of the -- 716
1 Q. Tell us what’s in the photograph.
2 A. It’s the kitchen of the suite.
3 Q. All right. All right. There we go. Now,
4 do you recognize that.
5 A. Yes.
6 Q. Okay. And you say, “The kitchen of the
7 suite.” Where was this.
8 A. In Calabasas.
9 Q. Now, let’s -- that’s all right. Just leave
10 it up there.
11 Now, did you stay in the room in Calabasas.
12 A. Yes.
13 Q. How long were you there.
14 A. Couple days.
15 Q. And who was -- who stayed in that room with
16 you.
17 A. Me, my mom and my brothers.
18 Q. Were there any other people staying at the
19 same -- at the same time at that place.
20 A. Yes.
21 Q. Who.
22 A. Frank and Vinnie were. Well, at first it
23 was Vinnie and then Frank came later on.
24 Q. Do you know, of your own personal knowledge,
25 where their room was.
26 A. If you -- if you were to go out the door,
27 there was a hallway of just rooms. And we couldn’t
28 get to the elevator unless we passed by their room. 717
1 Q. And how -- what floor were you on.
2 A. I think it was the second or third floor.
3 Q. Okay. Could you see the lobby from your --
4 outside your room.
5 A. If you walk out our door and go to the
6 right, you can look down into the lobby.
7 Q. When you went into the lobby area, did you
8 see anybody you recognized.
9 A. Yes.
10 Q. Who was that.
11 A. It was one of the bodyguards.
12 Q. Had you ever seen him before.
13 A. Yeah. I think he was the same one that gave
14 us the -- he was the one that came during the
15 ladies, with the meeting with the ladies from -- the
16 social workers.
17 Q. How often did you see him down in the lobby.
18 A. Anytime we looked down there.
19 Q. And were there times when you would walk
20 down the hall towards the elevator.
21 A. Yeah.
22 Q. You and your brothers.
23 A. And either -- they would have their door
24 open if they were there.
25 Q. Who’s “they”.
26 A. Frank and Vinnie.
27 Q. And what happened.
28 A. Just -- they would ask us, “Where are you 718
1 going. What do you need to do. We’ll get it. Just
2 stay in your room.”
3 Q. All right. The next photograph is -- do you
4 recognize what’s depicted in that photograph in
5 front of you.
6 A. Yeah.
7 Q. And what’s the number.
8 A. 138. That’s the room that I stood in.
9 Q. The one that’s on the board now is 138,
10 correct.
11 A. Yes.
12 Q. That’s the one you stayed in.
13 A. Yes.
14 Q. Did you have a room all by yourself.
15 A. Yes.
16 Q. And then the next one is 125.
17 A. Yes.
18 Q. And that’s -- what’s 125.
19 A. That’s the outside of the hotel.
20 Q. And this is the hotel you stayed in.
21 A. Yes.
22 Q. Now, when you say this is the hotel you
23 stayed in, it’s the one that has the kitchen and the
24 bed that you just talked about for the ladies and
25 gentlemen of the jury.
26 A. Yes.
27 MR. SNEDDON: Now, I have one last
28 photograph, Your Honor, I neglected to get marked, 719
Subject: March 3, 2005 
Tue Mar 20, 2012 7:46 am
