Jackson V AEG Live, July 19th 2013, Transcripts of Katherine Jackson

JACKSON V AEG LIVE July 19
th
2013
Kather#e Ja$.so#
(Michael Jackson's Beloved Mother, Jackson Family Matriarch, Plaintiff)
Plaintiff' Witness.
Ju!+e& Is there anything e need to talk a!o"t !efore e call the #"ry$ %ll right. &kay. 'all them in.
01he 2ury e#ters the $ourtroo34
Ju!+e& (atherine Jackson vers"s %)* +ive. *ood morning, every!ody. 'o"nsel, ill yo" make yo"r
a,,earances$
%r( Pa#sh& -es. *ood morning. Brian Panish for the Plaintiffs.
%r( 5oyle& *ood morning. (evin Boyle for the Plaintiffs.
%s( Cha#+& *ood morning. .e!orah 'hang for the Plaintiffs.
%s( Ste))#s& Jessica /te!!ins Bina for the .efendants.
%s( *o)#so#& *ood morning. +a"ra 0o!inson for the .efendants.

%r( Put#a3& %nd Marvin P"tnam for the .efendants.
Ju!+e& 1hank yo". -o" may !e seated. Plaintiffs, yo" can call yo"r ne2t itness.
%r( Pa#sh& -es. Plaintiffs call (atherine Jackson at this time.
Kather#e Ja$.so#6 $alle! as a /t#ess )y the Pla#t""s6 /as s/or# a#! test"e! as "ollo/s&
1he $ler.& Wo"ld yo" raise yo"r right hand$ .o yo" solemnly state that the testimony yo"'re a!o"t to
give in the ca"se no ,ending !efore this co"rt shall !e the tr"th, the hole tr"th, and nothing !"t the
tr"th, so hel, yo" *od$
1he /t#ess& I do.
1he $ler.& 1hank yo", ma'am. -o" may have a seat. %nd, ma'am, can yo" ,lease state and s,ell yo"r
first and last name for the record$
1he /t#ess& My name is (atherine )sther Jackson. (3a3t3h3e3r3i3n3e, #3a3c3k3s3o3n.
1he $ler.& 1hank yo".
Ju!+e& 1hank yo", ma'am. -o" may !egin.
-re$t e7a3#ato# )y 5ra# Pa#sh&
4. -es. *ood morning, Mrs. Jackson.
%. *ood morning.
4. First of all, hat is yo"r date of !irth$
%. I as !orn may 5th, 6789.
4. I kno this is not a great :"estion, !"t ho old are yo"$
%. I'm ;8 years old.
4. Is this the first time yo"'ve ever testified in a co"rt ith a #"ry like this$
%. -es.
4. %re yo" nervo"s$
%. -es, I am.
4. .id yo" get a lot of slee, last night$

%. <o.
4. %ll right. <o, Mrs. Jackson, are there any medical conditions that yo" have that may make it hard
for yo" to testify here today$
%. I'm a little hard of hearing, so I o"ld a,,reciate it if yo" o"ld talk a little lo"der.
4. &kay. %nything else$
%. I 33 in my ;8 years, I've forgotten a lot of things, so I'll try to anser the :"estions as !est I can.
4. &kay.
%r( Pa#sh& -o"r honor, is every!ody a!le to hear okay$
Ju!+e& It's hard.
%r( Pa#sh& I don't think so.
%r( Pa#sh& /o I kno it's kind of "ncomforta!le, !"t 33 okay. Mrs. Jackson, can yo" say something
for "s$ J"st test it o"t. *ood morning.
%. *ood morning.
%r( Pa#sh& Better$
Ju!+e& -o" ant her to "se the !ook$
%r( Pa#sh& *ood idea.
4. &kay. We're #"st trying to ad#"st the micro,hone. +et's try that. *ood morning.
%. *ood morning.
4. Pretend yo"'re singing in the choir. 1ry to get it o"t a little !it. I kno it's hard for yo". &kay$
%. &kay.
4. %ll right. Mrs. Jackson, I kno that yo" come from a famo"s m"sical family. %re yo" a ,rivate
,erson$
%. -es, I am. I leave the s,otlight for my children. I alays stay in the !ackgro"nd.
4. <o, is it diffic"lt for yo" to come here and !ring ", a ,"!lic matter like this in front of the ,"!lic$
%. -es, it is. 1he most diffic"lt thing is to sit here in this co"rt and listen to all the !ad things they say
a!o"t my son.
4. %nd hy is that diffic"lt for yo"$
%. Pardon$
4. Why is that diffic"lt for yo"$
%. Well, a lot of the things that have !een said are not the tr"th. =e's not here to s,eak for himself.
4. /o are yo" here to s,eak for yo"r son, Michael$
%. I'll try my !est.
4. %nd hy is it that yo"'re here to testify today$
%. Beca"se I ant to kno hat really ha,,ened to my son, and that's hy I'm here.
4. %nd do yo" !elieve that yo"r son as a !ad ,erson, or some of the things that have !een said$ %nd
the .efendants have said, >It's "gly,> and they're >*oing to e2,ose the "gly of yo"r family and yo"r
son.> Mr. P"tnam said that at the !eginning of the case. .o yo" !elieve that's the case$
%r( Put#a3& &!#ection, yo"r honor. Misstates the testimony and my comments.
4. Mr. P"tnam said in his o,ening statement. .id yo" sit here, hear his o,ening statement$
%. -es, I did.
4. .id Mr. P"tnam take yo"r de,osition for many days$
%. -es, he did.
4. .id he ask yo" many :"estions yo" didn't like$
%. -es, he did.
4. %nd ho does it make yo" feel to hear that they're going to tell everyone that yo"r son is a !ad
,erson$
%. Makes me feel real !ad, !eca"se I kno my son as a very good ,erson. =e loved every!ody. =e
gave to charity. =e's in the *"inness !ook of records for giving the most to charity of all of the ,o,
stars. I'm so nervo"s. I'm sorry.
4. &kay. Well, let's talk a!o"t yo" a little !it, Mrs. Jackson. Where ere yo" !orn$
%. I as !orn in Bar!o"r 'o"nty, %la!ama. % little, small ton.
4. What as the name of the ton$

%. Bar!o"r 'o"nty. 1on$ )"fa"la as the name of the ton.
4. )"fa"la, %la!ama$
%. -es.
4. +et me ask yo"? %nd hat as yo"r 33 ell, ho ere yo"r ,arents$
%. My father as Prince /cr"se, and my mother as Martha @,sha.
%r( Pa#sh& I ant to sho e2hi!it 699A. %ll these have !een given to co"nsel.
4. %nd ho is in that ,ict"re, ma'am$
%. 1hat's my father. 1hat's my father and Michael and myself.
4. %nd yo"r father's name as Prince /cr"se$
%. -es.
4. /3c3r3"3s3e$
%. -es.
4. Is Prince a family name in yo"r family, Mrs. Jackson$

%. 1hat name goes all the ay !ack to slavery. =is father, his grandfather, his great grandfather, his
great grandfather ere all named Prince.
4. Were yo" ,leased hen yo" learned that yo"r son as going to name 33 Michael as going to name
his son Prince$
%. -es, I as.
4. <o, e heard all these things, ell, since yo"r son as the king of ,o,, he as going to name his
son Prince. Is that hy he named his son Prince$
%. <o.
4. Why as it$
%. It as !eca"se of my family. =e loved my father.
4. <o, in yo"r family, Mrs. Jackson, as there m"sical talent$
%. -es.
4. 1ell "s a!o"t it.
%. My father 33 my grandfather on my mother's side, my great grandfather, I sho"ld say. <ame as
'ol"m!"s Bron. =e as a very good singer. =e sang in the ch"rch. %nd my mother "sed to tell me
that on /"nday mornings they o"ld o,en the old ooden indos in the ch"rch in %la!ama, and yo"
co"ld hear my grandfather's song. =is sang, and his voice rang all over the valley.
4. %t some ,oint in time did yo"r family move from %la!ama$
%. -es. I as three and a half years old hen e moved to east chicago, Indiana.
4. %nd did 33 ho far is east 'hicago, Indiana from 'hicago, Illinois$
%. We ere only B9 min"tes o"t of 'hicago, !"t e ere seven miles aay from *ary, Indiana.
4. .id yo" gro ", in a m"sical family in addition to yo"r great grandfather, 'ol"m!"s Bron, that
yo" mentioned$
%. -es.
4. 1ell "s a!o"t that.
%. Well, my father ta"ght himself to ,lay the g"itar.
4. What as yo"r father's name$

%. My father$ Prince.
4. I'm sorry. I asked yo" that already. I'm sorry. I'm nervo"s, too. &kay. %nd hat did yo"r father 33
hat as his m"sical talent$
%. =e ,layed g"itar. I ,layed the clarinet in the school !and. My sister ,layed the cello in the
orchestra. Jose,h's side as very talented, also.
4. Who is Jose,h$
%. My h"s!and.
4. %nd yo"r h"s!and, hat a!o"t his family side's talent$
%. 1hey ere very talented. =is !rother ,layed the g"itar. &ne of them ,layed the sa2o,hone. %nd e
alays had m"sic aro"nd the ho"se, and I think that's hat enco"raged my children.
4. .id yo" have any health iss"es, Mrs. Jackson, hen yo" ere groing ",$
%. -es. I had ,olio as a child. It as 33 at that time it as called infantile ,aralysis !eca"se most !a!ies
got it at the time. B"t President 0oosevelt had it, also, and he started the March of .imes. %nd that as
!ack in the '59s hen I as in school.
4. %nd ho did that affect yo" hen yo" ere groing ",$
%. @hm, I ore a !race from the age of A ", "ntil 33
4. -o" ore !races$
%. J"st one !race on my left leg, and ore it ", "ntil the age of 7.
4. =o did that make yo" feel as a yo"ngster$
%. I as shy.
4. =o as yo"r son Michael ith children ho had disa!ilities$
%. Michael loved all children, !"t es,ecially the ones ho co"ldn't care for themselves or had
something rong ith them. )veryhere he o"ld go, he o"ld go to the or,hanages and o"ld go to
the hos,itals visiting children. =e o"ld alays give money for disa!led children. %nd hen he as
yo"ng, he o"ld alays have someone visiting from make a ish fo"ndation. Michael o"ld s,end all
day ith them, have l"nch ith them, ,lay ith them.
4. Mrs. Jackson, I ant to sho yo" e2hi!it 699;.
%r( Pa#sh& %ny o!#ection, co"nsel$ I'm sorry. 'an't hear yo".
%r( Put#a3& <o.

%r( Pa#sh& &kay. 1hank yo".
4. Who is that$ (indicating) there's a screen in front of yo".
%. &h, my gosh. 1hat's me.
4. %nd hen as that$
%. Pardon$
4. When as that ,ict"re$
%. I as in high school at the time.
4. 1hat yo"r grad"ation ,ict"re$

%. <o.
4. <o$ &kay. <o 33
%. 1ake it don.
4. What as that$
%s( Cha#+& /he said to take it don.
4. Mrs. Jackson, at some ,oint in time did yo" get married$
%. I did.
4. %nd ho old ere yo"$
%. I as 67.
4. Who did yo" get married to$
%. Jose,h Jackson.
4. =o old as he$
%. B6.
4. %nd here did yo" live hen yo" ere married$
%. I moved to *ary, Indiana.
4. %nd is *ary, Indiana 33 is that close to )ast 'hicago, Indiana$
%. -es. %!o"t seven miles.
4. &kay. %nd hen yo" and yo"r h"s!and ere married, did yo" have a ho"se$
%.
We !o"ght a little ho"se hen e first got married, a!o"t to or three months later e !o"ght a little
ho"se on Jackson street in *ary, Indiana. Fo"r rooms. We didn't have any kids then. I as ,regnant.
4. &kay. =old on.
%r( Pa#sh& Is there some feed!ack$
1he /t#ess& %m I too close$
4. I'll #"st move it !ack a little. =o,ef"lly e can still hear yo". <o, ho many rooMs ere in the
home that yo" lived in ith yo"r h"s!and in *ary$
%. /mall, little ho"se. +ooked like a garage, in a ay.
4. %ll right. I'm going to sho yo" e2hi!it 6997.
%r( Pa#sh& Mr. P"tnam, is there any o!#ection to any of o"r e2hi!its$ .o I need to ask yo" every
time$
%r( Put#a3& <o, yo" don't.
%r( Pa#sh& 1hank yo".
4. &kay. Is this the home yo" and yo"r h"s!and lived in$ (indicating)
%. -es, it is.
4. -o" said Jackson street. =ad that !een named after yo" hen yo" moved there$
%. <o.
4. Was this 33
%. <o. 1hat as the name of it. 1hat's the street e moved on. It as a coincidence.
4. %nd ho many children did yo" and yo"r h"s!and raise in that home$
%. <ine children.
4. 'an yo" tell "s the names from the oldest to the yo"ngest$
%. My oldest as my oldest da"ghter, 0e!!ie. =er name as Ma"reen. Jackie as the second. =is
name is /igm"nd. 1ito, 1ariano as his name. 1hen Jermaine, Marlon, Michael, 0andy and Janet.
4. /o Michael o"ld have !een yo"r Ath child$
%. -es.
4. %nd then yo" had three girls and si2 !oys$
%. -es.
4. Was that easy$
%. <o.
4. =o as it that yo" all lived in this 33 hen yo" say, >fo"r3room ho"se,> is this a fo"r3!edroom
ho"se$
%. <o. J"st fo"r rooms.
4. What rooms ere there$
%. We had to !edrooms, living room, kitchen and "tility room here e had the freeCer and ashing
machine. We ke,t things o"t there.
4. =o did yo" all fit into that 7 33 66 ,eo,le, I g"ess it asD is that right$
%. -es. %t one time, 66.
4. =o did yo" all fit in that ho"se$
%. I had tri,le !"nk !eds, and the largest !edroom as the !oys' room. %nd Joe and I had a room. %nd
then I 33 the to girls at the time, +a 1oya and 0e!!ie, they sle,t in the living room on a let3o"t co"ch,
,"ll3o"t co"ch.
4. %nd then did yo"r !oys 33 did they sing together at any time then$
%. -es, they did. /ometimes !y them slee,ing in the room together, sometimes I'd ake ", to them
harmoniCing and singing.
4. %nd hat kind of a 33 ho did si2 ,eo,le fit in three !"nk !eds$ 1ri,le !"nk !eds.
%. &kay. Jackie as the oldest so he had a !"nk to himself.
4. =e got his on !"nk$
%. *ot his on !"nk. =e as the l"cky one. %nd the others do"!led ",, other to. 0andy as a !a!y,
so he as in a cri! in o"r room.

4. &kay. /o to, to and one$
%. 0ight.
4. %ll right. <o, did yo"r h"s!and ork there in *ary$
%. -es. =e orked in the steel mill.
4. Is that something that as a !ig ind"stry at the time in *ary$
%. -es. %t the time. )ast 'hicago and *ary. 'hicago steel mill in the city.
4. %nd as the ork steady$
%. <o, not all the time. /ometimes the steel mill ent don, and he as laid off for times. /ometimes
a eek, to eeks. /ometimes for fo"r eeks or a month or more.
4. .id yo", Mrs. Jackson, ever ork o"tside the home$
%. I took a #o! after 0andy, !eca"se it's a!o"t five years !eteen 0andy and Janet. %nd I as a clerk at
sears roe!"ck to hel, o"t the family.
4. .id yo" like that$
%. It as nice. 1he money came in handy.
4. .id yo" alays have a lot of money$
%. <o, not at all.
4. Were yo" a!le to s"rvive and make it$
%. &h, yes. We 33 I made some of the children's clothes. I 33 and that as the first thing, is clothing and
feeding the children. I made a lot of clothes. I atched the nes,a,ers for sales. I !o"ght a lot of things
on sale. %nd sometimes e'd go don to the /alvation %rmy hen shoes ere earing o"t, and
sometimes e'd find shoes for some of them. %nd e made it that ay. %nd hen Joe as laid off, "s
having to live from ,ayday to ,ayday, the money as scarce, and so e had to eat. %nd so e o"ld
never ant to go on elfare. /o hat he did, he ent o"t to the farms. =e ,icked 33 he ,icked
vegeta!les, I canned food. %nd e o"ld alays !"y 33 every year e o"ld !"y a :"arter of a co or
half of a co and kee, it in the freeCer. %nd that's ho e s"rvived.
4. Were yo" a good cook$
%. 1he kids said so.
4. What did yo" like to cook$
%. *osh, I kno ho to cook ,otatoes in every ay yo" can think of !eca"se he "sed to ,ick the
,otatoes, clean the field for ,otatoes and things hen he as laid off. J"st reg"lar food.
4. <o, did yo" en#oy having a large family in *ary, Indiana$
%. I did.
4. Where yo"r home is, there's like a field or something !ehind itD is that right$
%. -es. B"t yo"'re not looking at it. We lived on a c"l3de3sac. /o in the !ack of the c"l3de3sac as a
leag"e field.
4. +ittle leag"e for !ase!all$
%. +ittle leag"e !ase!all field.
4. .id any of yo"r children ,lay !ase!all$
%. -es. Jackie ,layed and also 1ito and Jermaine.
4. I ant to sho yo" e2hi!it 6969. What is that a ,ict"re of$ (indicating)
%. 1hat's a ,ict"re of 1ito and Jermaine's team. %nd the man in the middle is the mayor of *ary. =is
name is Mayor (atC.
4. 1he mayor of *ary, Indiana, as in the ,ict"re$ Base!all ,ict"re$

%. -es. =e s,onsored the team.
4. %nd hat as the name of the team$
%. 1he name of the team as (atC (ittens, and his name as Mayor (atC.
4. &kay. %ll right. %nd the one ith the !o tie there$
%. -es.
4. %nd ho is in that ,ict"re ith Mayor (atC$
%. Jermaine is ne2t to Mayor (atC, and 1ito is ne2t to Jermaine.
4. .id yo" like to go to the games$
%. We alays did, Marlon and Michael. %nd then the girls "sed to sit o"t and atch the !oys ,lay all
the time. Michael en#oyed it !eca"se he o"ld save his little ,ennies and nickels, so hen they o,ened
",, there as a refreshment stand, and he o"ld alays go there and s,end his money on that, on
candy and cookies.
4. %nd hat did he do ith all that candy$
%. Well, he didn't eat it all. =e liked to ,lay >store man.> so he o"ld take it and ,"t it and set ", a
little store, and all the kids in the neigh!orhood o"ld come and !"y from him, and he felt like he as
the store man.
4. %ll right. <o, as religion an im,ortant ,art to yo" in raising yo"r family$
%. -es, it as. I alays as close to *od. I raised my children as !est that I can and gave them
s,irit"al g"idance. %nd I think that's im,ortant in every family, they sho"ld do that. Wo"ldn't !e so
m"ch crime today. B"t 33 I'm so nervo"s.
4. 1hat's okay. What religion ere yo" raised$
%. Well, I as raised Ba,tist. %nd hen I as old eno"gh to "nderstand, I sa a lot of things going on,
and I didn't think that's the ay it sho"ld !e. /o I started searching. %nd I !ecame a +"theranD I asn't
satisfied ith that. /o one day some!ody knocked on my door, and her name as Mrs. Midget.
4. Mrs. Midget$
%. -es.
4. /he asn't a midget, tho"gh$
%. <o, she asn't a midget.

4. &r a short ,erson or 33
%. %nd she as ,lacing Watchtoers. %nd from there, I got the atchtoer, and I read it. %nd then I
called her, and I anted to have a !i!le st"dy. %nd I st"died ith her, and I fo"nd o"t that as the
religion I anted. I fo"nd o"t that it as the tr"e religion.
4. &kay. %nd hat as that$
%. Jehovah's Witness.
4. %nd hat did yo" do a!o"t that$
%. I #oined. I got !a,tiCed, and I #oined.
4. %nd have yo" !een ,racticing that religion ever since$
%. -es.
4. =o a!o"t yo"r JehovahEs itnesses, do they cele!rate !irthdays or holidays$
%. <o.
4. %re there any days that they do cele!rate$
%. 1hey do cele!rate one day, and that's the memorial of Jes"sEs last s",er, and e cele!rate that. %nd
it tells "s to remem!er and kee, doing this in memory of him. /o that's the only holiday that e
cele!rate. 1hat's the only holiday that's in the !i!le that e're s",,osed to kee,, !eca"se it says >kee,
this day.>
4. =ave yo" s,ent a lot of time in yo"r life reading the !i!le$
%. -es.
4. <o, did yo"r children 33 did they !ecome raised Jehovah itnesses$
%. /ome 33 they ere raised, !"t some of them !ecame itnesses. Michael !ecame a itness, my
oldest da"ghter, and she still is. %nd +a1oya !ecame a itness.
4. %nd others ent into other religions$
%. 1hey're not.
4. %ll right. We on't go there. +et me ask yo" this? .id yo" sto, having holidays for yo"r children
right aay$
%. <o. <ot right aay, !eca"se my h"s!and asn't a itness, so 33 and e finally eaned him aay
from the other holidays.

4. <o, did yo" still try to instill a love of m"sic in yo"r children$
%. -es.
4. +et's talk a!o"t yo"r son Michael, yo"r Ath son. I ant to sho yo" 33 first of all, hen as
Michael !orn$
%. Michael as !orn %"g"st B7th, 67F;.
4. I ant to sho yo" e2hi!it 6966, a ,hotogra,h. %nd ho's that$ (indicating)
%. 1hat's Michael. =e as a!o"t to or three years old.
4. %nd hat does this ,hotogra,h sho$
%. It #"st shos him as a seet little !oy to me. My !a!y.
4. What as he like as a small child$
%. *osh. Michael has alays !een sensitive, !een loving. I can remem!er Marlon, his older !rother,
!eing sick. %nd at that time yo" co"ld go to the dr"gstore, and the ,harmacist 33 yo" o"ld tell them
the sym,toms, hat's going on, and the ,harmacist o"ld give yo" medicine. %nd !y the time I got
!ack, Marlon had gotten orse. Marlon as standing there holding his hand 33 I mean Michael as
standing there holding his hand, a !oy of three years old, and crying.
4. 'rying hen his !rother as sick$
%. 'rying hen his !rother as sick.
4. .id there come a time hen yo" realiCed that yo"r Ath child had an interest in m"sic$
%. -es. =e as !orn that ay. =e 33 hen all the kids as dancing aro"nd, he as in my arms, and he
co"ldn't !e still. =e as dancing, too, to the m"sic. %nd hen he started to alk, he o"ld still dance.
%nd there's a story a!o"t 33 I imagine I've told the story so many times.
4. /hare it ith "s.
%. We had an old, rickety ashing machine, a Maytag. %nd if yo" co"ld remem!er the ashing
machines, hen they ere older, they had the dasher. %nd then they had the rolling 33 yo" rolled yo"r
clothes to dry them o"t, s:"eeCe the ater o"t of them. %nd it as so old and r"sty, "ntil it as done
ashing, it o"ld make a noise, and !y the rotor going, it o"ld make a rhythm noise, like >s:"eaky,
s:"eaky, kat"m, kat"m,> something like that, and he o"ld !e don there dancing, s"cking his !ottle
to the s:"eaking of the asher. %nd I kne he as going to !e 33 he #"st loved m"sic, and he loved to
dance.
4. .id there come 33
%r( Pa#sh& -o" can take that don.
4. .id there come a time hen yo" realiCed that yo"r children had a real m"sical talent$
%. -es. +ike I say, they "sed to sing in their !eds, and they ,layed m"sic. My father gave 1ito his first
g"itar. %nd Joe's !rother, hich is 1rentEs father, he ,layed g"itar. /o he o"ld come over, and they
o"ld ,lay together, and that's hat started 1ito to ,lay. %nd they loved the tem,tations, and they
o"ld imitate the tem,tations all the time.
4. 1em,tations as a ell3knon gro", at the time$
%. %t Moton. -es.
4. &kay. What is Moton$
%. Pardon$
4. What is Moton$
%. Moton is a record com,any hich signed my children ", later on.
4. &kay. .id yo" have a television$
%. &h, my goodness, yes, e had a 1G, !"t e had an old 1G. %nd sometimes it o"ld !reak don.
%nd at the time there ere t"!es in 1Gs, and yo" co"ld go to the dr"gstore and take yo"r old t"!e and
get another and come !ack and ,"t it in. B"t then later on, the 1G o"ld !reak don, and then e had
a 1G man. =e o"ld come and take it aay, and sometimes e didn't have the money to get it !ack.
%nd that's hen the children first started singing. We o"ld sing together, sing old co"ntry songs, folk
songs. 1hings like that.
4. .id yo" like co"ntry m"sic$
%. I gre ", on co"ntry m"sic.
4. Is that from %la!ama$
%. 1hat's hen 33 e lived in )ast 'hicago, and my father o"ld listen to that, an old co"ntry 33 I
mean, it as a co"ntry station coming o"t of 'hicago called the >s",,ertime frolic.> and on the
eekends e o"ld listen to the grand ole o,ry. /o e alays had m"sic in the ho"se.
4. <o, hen is it that yo"r children started getting involved in organiCed m"sic$
%. 1hey ere very yo"ng. B"t they had done some singing even hen Michael as a!o"t five years
old. %nd aro"nd ton. %nd then they started singing, inning contests at the high school. %nd from
there, they ent on to ,rofessional.
4. %nd hen yo" say concerts 33 I'm sorry 33 >contests,> hat do yo" mean$
%. @hm, in *ary there as not a lot to do. /o all the high schools had contests for the kids. %nd they
o"ld go from high school to high school. %nd so my !oys, they had got so that they on all the
contests that they 33 every time there as a contest. %nd "s"ally hen the kids o"ld sing 33 hen they
had the contests, and they seen the Jacksons coming, they o"ld think, >oh, my *od, they're going to
in again.>
4. .id they have a name, the gro",, or 33
%. -es, they did. I as thinking a!o"t naming them the Jackson !rothers F. B"t then, her name as
)velyn +eahy, and she anted them on her ,rogram. /o she called me, and she said, >I ant to
advertise them, so hat is the name$> %nd I told her, >1he Jackson Brothers F.> %nd she said, >Well,
let's c"t that a little short and name it the Jackson F.> %nd I tho"ght it so"nded !etter, so I as for it.
4. %nd that's ho the name came a!o"t$
%. 1hat's ho the name came a!o"t.
4. .id there come a time hen yo" realiCed or even realiCed that Michael might have
%. /,ecial talent himself$
%. -es. When Michael as in kindergarten and had started school, he as alays singing in the ho"se
anyay from a tiny kid all the ay ",. /o they ere having a contest 33 not a contest. I'm sorry. =aving
a ,rogram at school. %nd the teacher had sent a note home and told me Michael as in the ,rogram. /o
I and Michael's grandfather, Jose,h's father, ent don to school. %nd he 33 and I as thinking, >=o
is he going to go ", there #"st at five and sing$>
4. =o old as he$
%. Five years old. %nd he sang >'lim! )very Mo"ntain.> and I as so nervo"s hen he alked o"t on
the stage, !eca"se he as alays shy. %nd he started singing the song, and he sang it ith s"ch clarity
and didn't miss 33 not flat or anything. Joe's father sat there and cried like a !a!y. +ooked aro"nd, and I
as crying, too. =e got a standing ovation for his ,erformance. %nd he asn't nervo"s, and I as
shocked. %nd I think he m"st feel more at home on stage.
4. =o did that make yo" feel$
%. I felt 33 I as ,ro"d of him !eca"se I didn't think he co"ld do it.
4. .id there ever come a time hen it as disc"ssed of Michael #oining his !rothers in their gro",$
%. Well, that ha,,ened hen he as a!o"t si2 years old. %nd he as singing, and even after he had
sang >'lim! )very Mo"ntain,> I told Jose,h 33 !eca"se Jermaine as the lead singer. %nd I told him
Jermaine needed hel,, and I told him Michael co"ld hel, him. =e didn't !elieve me, so I forced him to
listen. %nd that's ho Michael got the #o!. %nd then after that, he !ecame leader hen they !ecame
,rofessionals. Moton made him a lead singer.
4. %nd did the Jackson F ever lose any contests$
%. When they ere at home$
4. -es.
%. Playing against high schools$ 1hey did. 1hey lost once. %nd I think that they ere sick of seeing
the Jacksons in. /o it as another team, and it as one of the !oys that !elonged to this other gro",
ho lived ne2t door to "s, and they on that year.
4. &kay. I ant to sho yo" e2hi!it 6968. %nd is that the gro", early on$ (indicating)
%. -es. 1hose are my !oys.

4. %nd here is Michael$
%. Michael is the little kid to the right of "s.
4. I'm sorry$
%. =e's on the right.
4. =ere$ (indicating)
%. 0ight there.
4. Who is that$ (indicating)
%. 1hat's Jermaine.
4. (indicating)
%. 1hat's o"r dr"mmer, Johnny Jackson. <o relation.
4. <ot related to yo"$
%. <o.
4. =ad the same name$
%. /ame name.
4. <ot one of yo"r children$
%. <o. 'oincidence, hich is good, tho"gh.
4. What does it say on the dr"m$
%. >1he Jackson F and Johnny.>
4. >and Johnny>$
%. -es.
4. &kay. /o there's si2 ,eo,le$
%. /i2 ,eo,le.
4. Who is this$ (indicating)
%. 1hat's Marlon, 1ito and Jackson.
4. %nd hen e sa 1J. %nd 1a#, they're 1ito's children$
%. 1hey're 1ito's children, yes.
4. <o, here did the !oys rehearse early in their career$
%. 1hey rehearsed at home.
4. In the fo"r3room ho"se$
%. In the living room. We o"ld ,"sh all the f"rnit"re !ack on the alls, and they o"ld dance and
,"t 33 set ", the dr"ms and things and rehearse right there.
4. %nd ho did yo" get the money to !"y the instr"ments$

%. Well, e saved it. I "sed to alays arg"e and f"ss ith Joe a!o"t, >I need more rooms. I need more
rooms.> and hen e o"ld save money, e'd !"y more instr"ments. We'd !"y am,lifiers and things
like that.
4. %nd ho made the cost"mes !ack then$
%. I did.
4. -o" s"ed them yo"rself$
%. -es, I did.
4. +et me look at e2hi!it 6965, ,lease (indicating). What are those called, those s"its$
%. =omemade s"its.
4. &kay. .id yo" make those s"its$
%. -es.
4. I g"ess that's hat they're called.
%. 1hat's hat they're called.
4. %ll right. %nd ho long did a homemade s"it last$
%. 1hey gre o"t of them m"ch too fast, !eca"se e had to save money to !"y more s"its !eca"se I
asn't going to attem,t that anymore.
4. &kay. %nd at some ,oint in time, after they had !een inning some of these contests, did they ever
get a gig, I g"ess yo"'d call it, here they o"ld get ,aid$
%. -es. 1hey had gotten to here the 1em,tations or *ladys knight or someone came aro"nd to
'hicago to ,lay at the theaters, I g"ess the oners of the theater o"ld alays call "s, and the !oys
o"ld !e on stage ith them. 1hey o"ld ,lay, and e got ,aid that ay.
4. <o, at some ,oint in time did the Jackson F sign ith a record com,any$
%. -es. 1hey signed ith Moton in 67H;.
4. %nd did yo" still live in *ary, Indiana, at that time$
%. -es.
4. %nd did yo" at that ,oint in time ever move$
%. -eah, e moved. 1he !oys moved first to 'alifornia. %nd later, a!o"t fo"r months later, I came. Me
and the children that ere left at home. +a1oya, 0andy and Janet, e all came o"t later.
4. &kay. %nd hat did yo" think hen yo" got to 'alifornia$
%. I had alays anted to live in 'alifornia. %nd hen I as a girl, I "sed to dream of coming to
'alifornia !eca"se it as so m"ch sno !ack home, cold. %nd sometimes it o"ld get 69, 6F !elo
Cero. %nd I o"ld go to the movies as a girl, and I o"ld see. %nd they o"ld alays sho 'alifornia
33 !eca"se e got o"r nes sometimes in the theater, es,ecially the ar nes, and all of that. %nd it
o"ld sho 'alifornia, ,eo,le r"nning aro"nd in converti!les and ,alm trees. %nd I alays tho"ght
hen I had to leave the theater and go o"t in the sno to get home, and my dream as to live in
'alifornia.
4. .id the Jackson F then start making records$
%. -es, they did, once they signed ", ith Moton.
4. %nd they had single recordsD is that right$
%. @hm, yes. 1he first fo"r singles that they made ith Moton !ecame gold records. <"m!er one
records.
4. <"m!er one records$
%. Fo"r n"m!er ones in a ro.
4.
%nd as there something called Jackson mania at that time$
%. %t that time. My goodness, don't mention that. /o many girls aro"nd the ho"se. I got so tired of 33
they o"ld come and stay all day, and sometimes some of them o"ldn't go home, so I had to go o"t at
night and drive them home.
4. %ll right. <o, let me sho 33 did yo" ,ick o"t for "s 33
%. Pardon$
4. .id
-o" hel, "s #"st get a co",le videos of the !oys and Michael hen they ere yo"ng to sho kind of an
e2am,le of hat they liked to do$
%. -es.
4. &kay. I ant to sho yo" e2hi!it 696F from the early years !ack. %nd this is the m"sic Michael
sang to hel, ,re,are this$
0a v!eo $lp s playe!4
4. 1hat's yo"r ho"se$
%. -es.
0the v!eo $lp $o#t#ues to )e playe!4
4. Who is Michael$
%. 1he little !oy !ack there like he's freeCing to death. 1hat's Michael.
4. &n the side there$
%. In the sno.
4. Is that in yo"r ho"se$
%. -es. 1hat's hen e ,"shed the f"rnit"re !ack, and they o"ld dance hen he as 33
4. %nd do yo" kno ho old he as there, Michael$

%. =e as a!o"t five.
4. Is this Moton$
%. -es. 1hat's Moton.
4. .id they go to an a"dition$
%. -es. 1hat's the a"dition.
4. What is this$
%. 1hat's on one of those television shos.
4. )d /"llivan$
%. 1hat's )d /"llivan there.
4. Is that Michael$
%. %nother television sho. I don't remem!er hich one.
4. Who is that$ Janet$
%. Michael and Janet.
4. .id yo" make those o"tfits$
%. Pardon$
4. 1hey had that cartoon series$
%. -es.
4. Where is this$
%. Moton BF.
4. %nd do yo" remem!er here this as$
%. Pardon$
4. .o yo" remem!er here this as filmed$
%. I think that as in Pasadena somehere.
4. Is one of the !rothers 33 this as the re"nion$
%. -es. Jermaine left the Jacksons hen they left Moton. =e as married to Barry *ordon's
da"ghter.
4. Barry *ordon, the oner of Moton$
%. &ner of Moton.
4. =e didn't leave$
%. =e didn't leave. /o Moton BF, that's hen they re#oined them.
1he /t#ess& %nd that's Jermaine h"gging them, and they ere ha,,y that he as !ack.
4. &kay. /o as a mother, hen yo" sa Michael ,erform like that, ho did yo" feel$
%. =o did I feel$
4. -eah.
%. I felt very ,ro"d.
4. When he did these s,ecial ,erformances, ere yo" s"r,rised to see ho he did in these s,ecial
events$
%. -es. )s,ecially one time hen he as 65. =e sang solo on one of the aard shos. %nd that as
very good, I tho"ght. I as most ,ro"d of him.
4. Were yo" there$
%. -es, I as.
4. =ave yo" ever heard of the %cademy %ards$
%. -es. It as at the %cademy %ards.

4. %nd I have a cli, of that. .o yo" kno hat song Michael sang$
%. =e sang Ben. It's a song a!o"t a rat. %nd it's a song from a Movie.
4. %nd Michael, hen he ent to ,erform, yo" said he as a!o"t 65$
%. =e as 65 at the time.
4. %nd he as yo"nger than his son Prince is no$
%. -es.
4. %nd ere yo" nervo"s a!o"t it$
%. I as a little !it, !"t he did ell.
4. &kay. Well, let's 33 e2hi!it 696H. -o" remem!er ho introd"ced Michael (indicating)$
%. -es. &ne of my favorite actors.
4. Who is that$
%. I'm so nervo"s, I can't remem!er. I kno ho he is very ell, !"t 33
4. 1his as Michael at 65$
%. -eah.
4. Was Michael singing that song again$
%. -es. =e's older. %s yo" can see, his voice has changed there.
4. .id he like that song, Ben$
%. -es, I do.
4. .id Michael like that song$
%. -es, he liked that song !eca"se he liked rats. 1hat song is a!o"t a rat. %nd I can remem!er a story
that e ent to Beverly =ills to have dinner, and e ere eating, and Michael ke,t ,"lling his coat ",
and ,"tting cr"m!s into his ,ocket. %nd I said, >hat are yo" doing$> and he held it ",, and he had a
rat in his ,ocket, and he as feeding it. %nd I as really ",set ith him.
4. =o a!o"t 33 !y the ay, the actor, yo" heard of that movie Ben3="r$
%. &h, yes. %nd isn't that af"l.
4. 'harlton =eston$
%. 1hank yo". I can't think of his name, !"t I love him.
4. .id Michael like animals$
%. -es, he did. B"t one thing he didn't like ere dogs.
4. Why not$
%. Well, he had a !ad e2,erience ith dogs. &ne year hen he as a kid, Johnny Jackson, o"r
dr"mmer, ent on vacation, so he left his ,it !"ll ith "s to take care of. %nd Michael and 0andy as
,laying ith the dog 33
4. =old on one second.
%. I'm too close$
4. Why don't yo" ,"sh it forard a little more.
%. =o is that$ Is that !etter$
4. Better.
%. Is that !etter$ &kay. Where as I$
4. -o" ere telling "s a!o"t dogs.
%. &h, yes. %nd Johnny left the ,it !"ll ith "s to take care of. %nd Michael and 0andy as ,laying
ith the ,it !"ll, and Michael discovered d"ring their ,lay, the dog got mad. %nd I don't kno hy he
got ",set, !"t Michael discovered that, so he ran and #"m,ed on to, of the #ee,. %nd 0andy as teasing
Michael, >&h, yo"'re scared of a little old dog.> %nd he said, >For real, 0andy. 1hat dog is mad.> %nd
so 0andy ent over teasing the dog, and the dog t"rned on him. /o 0andy tried to #"m, on the Jee,,
and !efore he co"ld get aay, he took a !ig ch"nk o"t of his arm and o"t of his heel. When he #"m,ed
o"t at him, took a ch"nk o"t of his heel. %nd I r"shed him to emergency, !"t he !it don to the !one.
%nd I don't kno ho he took that ch"nk of meat o"t of his arm like that. +ike some!ody took a shar,
s,oon and d"g it o"t. %nd I co"ld see his !ones and everything. %nd so Michael has !een afraid of dogs
ever since.
4. %nd at some ,oint in time, des,ite his fear of dogs, did he get a dog for his children$
%. -es, he did.
4. %nd hat kind of dog as that$
%. % chocolate +a!rador.
4. What as the name of the dog$
%. (enya. %nd e still have him.
4. %nd hen Michael ,assed aay, in addition to getting a la!, did yo" get some other ,ets, too$
%. I inherited almost a Coo. -es. 1here as a ,arakeet and ,arrot. Ferrets, mice. /o m"ch I can't think
of it.
4. Besides singing and dancing 33
%. %nd to cats. )2c"se me. %nd I don't like cats.
4. Besides singing and dancing, did Michael like to do other things$ .raing$ %rt$ %nything like
that$
%. 'an yo" re,eat$ I didn't hear.
4. &kay. I'm sorry. =o are yo" doing$ -o" doing okay$
%. -es.
4. &kay. %ll right. In addition to singing and dancing, did Michael like to do other things$ %ny art$
%nything like that$
%. &h, yes. Michael as a very good artist. =e did a lot of art in school. %nd some of his ,ict"res have
!een sold since. %nd he rites songs.
4. %ll right. %nd did Michael like to sit aro"nd and atch 1G$
%. <o. -o"'d never catch him doing that. %nd I had to sit here and see that email talk a!o"t ho laCy
Michael Jackson as. 1hat's the !iggest lie in ton. My son is not laCy, and yo" kno that he asn't
laCy.
4. =o as Michael in school$
%. Michael as good in school. =e as not an e2ce,tional st"dent, !"t he as fair st"dent.
4. Was he as good as Prince$
%. <o, not at all.
4. &kay.
%. Prince is a straight a st"dent.
4. %t some ,oint in time yo" mentioned that the Jackson F left Moton e2ce,t for Jermaine.
%. -es. 1hey left Moton, and I think they ent to ),ic records at that time.
4. .o yo" kno ho many records they'd sold !y that time$
%. With Moton$ I can't remem!er e2actly. B"t at ),ic, I think their first record ent do"!le
,latin"m.
4. 0emem!er hat that as$
%. <o. I think that as the al!"m .estiny.
4. %nd aro"nd that time, as Michael shoing an interest in movies$
%. -es.
4. Was Michael in a movie$
%. =e as in 1he WiC that as taken from the WiCard of &C.
4. .o yo" kno ho the director as$
%. /idney +"met.
4. .id he do other ,ict"res$
%. =e made, I think, 6B %ngry Men.
4. 1hat's a!o"t a #"ry, act"ally.
%. -es. %nd also he did Midnight )2,ress and some others. I can't remem!er them.
4. &kay. I ant to #"st sho yo" a cli, from 1he WiC. that's 696A. %nd do yo" remem!er hat 1he
WiC as a!o"t$
%. It as something taken from 1he WiCard of &C. It as 33 .iana 0oss as .orothy, and Michael
as a /carecro. It as aro"nd the same thing.
4. &kay.
%. B"t in a different ay.
4. 1his is kind of their yello !rick road. %ll right. +et's take a look.
4. Is that Michael$
%. 1hat's Michael.
4. %ll right. <o, did Michael meet some!ody that !ecame im,ortant in his life !y doing that$
%. -es. 4"incy Jones did the m"sic for the movie, and so he met 4"incy.
4. I kno 4"incy is :"ite famo"s, !"t did yo" kno 4"incy for a long time$
%. -es.
4. %nd ho did him and Michael interact$
%. Gery ell. 1hey made several al!"ms together hich did very ell.
4. /o did Michael then ork ith 4"incy Jones$
%. -es.
4. %nd did he ork ith him thro"gh vario"s ,ro#ects$
%. -es.
4. 1hriller$
%. -es. &ne of them.
4. Bad$
%. %nother.
4. &ff 1he Wall$
%. -es.
4. %nd aro"nd this time hen Michael as B6, did Michael rite don hat his goals ere$
%. -es. Michael 33 ell, as e all kno, Michael rote notes to himself all the time, ho he felt, and
he o"ld alays rite on the mirror ith a grease ,en and here he anted to !e at a certain time.
When he o"ld make an al!"m, he o"ld alays rite don ho m"ch he o"ld ant that al!"m to
sell, at least so many. %nd everything he rote don #"st a!o"t came tr"e.
4. %nd hen Michael as B6, here as he living$
%. =e as living ith me.
4. With yo"$
%. =e as still at home.
4. =ayvenh"rst$
%. -es.
4. %ll right. %nd did Michael ever ant to !e knon as something other than Michael Jackson$
%. Well, he had 33 !y a certain time in his life he didn't ant to !e knon as Michael Jackson, !eca"se
that as little Michael Jackson from the Jackson F. =e anted to !e knon as MJ.
4. &kay.
%. Why, I don't kno.
4.
%nd did there come a time hen he came o"t and did something as MJ$
%. Well, !y the time he as on Moton BF, and he did the Moonalk, that changed things.
4. &kay. Well, let's 33 ho 33 ere yo" there$
%. -es.
4. =o did the crod react to Michael that night$
%. &h, my goodness, I can't 33 do e have a thing of it$
4. -es, I do have one. +et's take a look at 696;. %nd the Moonalk, had Michael ever done this in
,"!lic$
%. <o. I hadn't even seen it. I'm s"re he as ,racticing it, !eca"se he "sed to ,ractice all the time. %nd
e had a room ",stairs over the garage here he o"ld alays ,ractice. %nd he o"ld go ", every
/"nday and /at"rday and dance to ho"rs straight itho"t sto,,ing. %nd I'm s"re he as doing the
Moonalk ", there, !"t e never kne it.
4. %ll right. +et's take
%. +ook. 1his is the Moonalk, Moton BF.
(a v!eo $lp s playe!4
4. <o, that !lack s,arkly #acket, here did he get it$
%. =e !orroed that from me. 1hat as my dinner #acket.
4. Was Michael having a lot of s"ccess$

%. Pardon$
4. Was Michael having a lot of s"ccess$
%. -es.
4. .id it go to his head$
%. <o. Michael as the most h"m!lest ,erson yo"'d ever meet.
4. .id he contin"e living ith yo"$
%. -es.
4. @ntil he as 89$
%. -es.
4. .id Michael ever do anything s,ecial for yo" at yo"r home here yo" lived together at
=ayvenh"rst$
%. Michael did so many s,ecial things for me. *osh. I don't kno here to start.
4. Well, did he hel, re!"ild the ho"se$
%. &h, yes.
4. .id he 33
%. When he !ecame 6;, he anted to !"y me a ho"se. We ent sho,,ing everyhere. By that time,
ho"ses had gone ", to millions and millions of dollars. We sho,,ed everyhere, and e came !ack
home and decided to remodel, !eca"se e co"ldn't find a ho"se ith as m"ch ,ro,erty aro"nd it, and
the kids gre ", there, and he had go3carts and did everything at the ho"se, ,layed !asket!all and
sim. /o e decided to 33 so he remodeled, and the ay yo" see =ayvenh"rst no is the ho"se he
re!"ilt for me.
4. /o it as re!"ilt$
%. Pardon$
4. 0emodeled, yo" said. 0e!"ilt$
%. 0e!"ilt, really.
4. %nd at some ,oint later did Michael do something to a co",le rooms for yo"$
%. -es. =e 33 ", over the garage, like I said, he "sed to ,ractice all the time. =e'd lock that room ",,
and he told "s not to come in. %nd he took all my ,ict"res 33 !eca"se I as ondering, >Where are my
,ict"res going$> =e took all the ,ict"res, enlarged them, and instead of all,a,er, he #"st ,"t them all
aro"nd the all and invited the hole family over hen he got ready to o,en it ",. %nd he said, >=ere's
yo"r s"r,rise. 'ome in.>
4. .id he have ,eo,le come hel, him do this$
%. Well, ,eo,le hel,ed him enlarge them and all of that, yes.
4. B"t the ork of ,"tting ", the ork and the design and everything$
%. =e hel,ed and 33 yes, he did.
4. %ll right. +et's look first at e2hi!it 6967 (indicating). Is this a ,la:"e that Michael gave yo"$
%. -es.
4. It says? >To take a picture is to capture a moment to stop time, to preserve the way we were, the
way we are. They say a picture speaks a thousand words, so with these photographs, I will recreate
some wonderful magical moments in our lives. Hopefully this journey into the past in picturesque
form will be a stimulant to create a brighter, successful tomorrow. Michael ackson.> Is that in yo"r
ho"se in =ayvenh"rst$
%. -es. It's still there.

4. %nd did Michael rite that and ,"t that ", for yo"$
%. -es, he did.
4. Where is that in the home$
%. It's over the garage, and it's 33 I think it's to rooms ", there. =e did the hole ",stairs that ay.
4. &kay. +et's look at it. )2hi!it 69B9 (indicating). %nd did Michael ,re,are this for yo"$
%. -es, he did.
4. =o did it make yo" feel$
%. I felt ,ro"d. =e as alays giving me things.
4. &kay. Is Michael singing 33 hat song is he singing here$
%. >-o" %re <ot %lone.> !"t 33
4. Why don't yo" tell "s hat yo"'re looking at$
%. -o"'re looking at a ,ict"re that he had taken !efore they left *ary, Indiana. 1hat's my father there.
4. We're looking at the alls of the room$
%. 1hat's 0e!!ie hen she as at high school. Joe ,laying the g"itar. Myself and Janet, +a 1oya.
4. We can see there's like a indo, and there's the alls.
%. -es.
4. Michael did all this for yo"$
%. -es.
4. %nd he made all the all,a,er. 1here's yo"r driver's license.
4. Who is that$
%. 1hat as me, and that's ith the :"een.

4. %nd that's the ceiling ", there$
%. -es.
4. Michael ,"t all that ", there$
%. )verything as covered ith ,ict"res.
4. %nd Michael made all that for yo"$
%. -es.
4. -o" still have it that ay$
%. -es.
4. %ll right.
Ju!+e& /hall e take a 6F3min"te !reak "ntil 66?99$
%r( Pa#sh& -es, yo"r honor. 1hat o"ld !e great.
Ju!+e& +et's do that. Break "ntil 66?99, and then e'll come !ack.
01he 2ury e7ts the $ourtroo34
05rea.4
01he 2ury e#ters the $ourtroo34
Ju!+e& (atherine Jackson vers"s %)* +ive. -o" may contin"e.
%r( Pa#sh& 1hank yo", yo"r honor.

4. Mrs. Jackson, did Michael ever thro a dinner ,arty for yo" hen he serenaded yo"$
%. -es.
4. .oes this em!arrass yo"$
%. -es.
4. &kay. +et's look at e2hi!it 69BH.
4. Where is this$ .o yo" remem!er this dinner ,arty$
%. -es, I do.
4. Who as sitting ne2t to yo"$
%. It as my favorite ,ianist.
4. Who is that$
%. Floyd 'ramer, concert ,ianist.
4. Is this song that Michael sings, is this one of yo"r favorites$
%. -es, it is.
4. Is that Floyd$
%. Pardon me$
4. <ever mind.
4. Is that Mr. 'ramer ith the !o tie$
%. -es, it is.
4. .id Michael, hen he as living at home, hen he asn't to"ring or doing other ork, as he 33
did yo" and he share stories a!o"t his ork$ .id yo" share stories a!o"t the ork he as doing$ 1alk
a!o"t the ork he as doing$
%. When e ere here$
4. %t home.
%. &h. I don't "nderstand the :"estion.
4. &kay. Fair eno"gh. .id Michael like m"sic videos$
%. &h, yes.
4. .id yo" talk a!o"t those ith him$
%. &h, yes.
4. What o"ld yo" talk a!o"t$
%. We talked a!o"t the 33 they ere really short movies, and I o"ld alays tell him 33 hen he made
his first movie, he said, >!ell, mother, the second one is going to be better than the first.> %nd I as
ondering 33 I o"ld tell him, >How are you going to top that"> %nd he said, >#ou$ll see.> %nd the
ne2t one as 1hriller, and he did to, the first one. %nd he invited me don to here he as doing
another short movie, and it as *host. I don't think it to,,ed thriller. B"t it as f"nny.
4. &kay. +et's take a look at that. )2hi!it 69B6 (indicating). -o" ent to the set of this$
%. -es.
4. %nd ho is that$
%. <o it's Michael. %t first I didn't kno ho it as. I kno ho it is no. B"t I as sitting at the
set, and after they got thro"gh, I 33 this man came ", to me, and s",,osed to !e the hite mayor of the
ton. %nd I told him, >I'm here to see my son, Michael.> %nd he said, >Mother, it's me.> I anted him
to get him for me.
%r( Pa#sh& %ll right. Is that a video$ J"st a ,ict"re$ &kay.
4. <o, did Michael, as he involved in the Jehovah Witness religion for a hile$
%. -es, he as.
4. .id he ever go o"t ith yo" 33 and is ,art of the religion to go o"t to ,eo,le and s,read the ord of
yo"r faith$
%. -es. Field service, e call it. =e had to 33 the ay he's dressed no. /o one morning e got ",, and
it as the first time that he dressed that ay, !eca"se ,eo,le kne ho he as, so he co"ldn't do field
service or kids and ,eo,le folloing him. /o he had to try to disg"ise himself. %nd the first time he
disg"ised himself, he got a fat s"it, not real fat. %nd I came don, and he had had !reakfast. %nd I as
getting ready to go o"t in field service ith him, and I s,oke to this man, like >=ello. =o are yo"$>
and he said, >It's me, mother.> B"t he had to do it.
4. /o he o"ld go o"t and knock on ,eo,le's doors ith the s"it on$
%. -es.
4. =e'd get the door slammed in his face$
%. +ots of times. B"t they never kne ho it as, so that as good.
4. %ll right. /o then in 67;; did Michael ,"rchase the <everland 0anch and move o"t$
%. -es, he did.
4. %nd hen he as asn't traveling aro"nd, did he stay at <everland$
%. -es.
4. .id yo" visit him there$
%. +ots of times.
4. &kay. I ant to sho e2hi!it 69BB, some e2cer,ts ith the m"sic that's act"ally ,layed. Is the
m"sic act"ally ,layed hen he lived there at <everland$
%. %ll the time. %ll over the ranch, herever yo" ent, yo" heard m"sic.
4. &kay. +et's take a look. Is that the !eginning of the ranch$
%. -es.
4. /o this m"sic o"ld contin"ally ,lay$
%. -es. %ll the time.
4. .id Michael rite this ,oem$ >!hen children play, tyrants cry, there is nothing to slay. %airies
dance and goblins sing in the garden, we frolic awhile. Those are the moments when babies smile.>
%. -es.
4. Is that the candy store$
%. -es. Finally got a candy store.
4. What is that$ % sea dragon$
%. -es.
4. .id yo" ever go on that$

%. I did. 1hat's the only thing that I o"ld go on.
0the v!eo $lp $o#t#ueS to )e playe!4
4. .id Michael make the ranch availa!le to ,eo,le$
%. -es. %nd es,ecially for "nder,rivileged children. %nd he had them 33 the movie theater on the
ranch. %nd in the movie theater, he o"ld have !eds for children that ere sick and co"ldn't sit ",.
1hey ,ro,,ed them ", to see the shos that they ,"t on for the children.
4. Is that the ho"se$
%. -es, that's the ho"se. =e o"ld invite classes of children.
4. Who is that$
%. &h, that's 33 here$ &h, that as grace and the cook.
4. What is this$
%. 1hat's a note that Paris rote to Michael hen he as sick. >I love you daddy so much more than
that. &et well.>
4. Is that at night$
%. -es.
4. .id it have a train station$
%. -es.
4. What as it called$
%. (atherine.
4. .id yo"r grandchildren, Paris, Prince and Blanket, did they like <everland$
%. 1hey loved <everland.
4. ."ring the time they lived there, ere they !eing home3schooled$
%. -es.
4. %nd e sa a lot of animals that Michael had there$

%. +ots of animals. F"nny story is 33 kids liked to go to 'h"ck ). 'heese.
4. 'h"ck ). 'heese$
%. -es.
4. +ike ,iCCa$ +ike a lot of kids r"nning aro"nd$
%. % lot of kids r"nning aro"nd. /o *race had them at 'h"ck ). 'heese, and the lady there, she as
asking them, >.o yo" like animals$ .o yo" have any animals$> %nd the kids said, >-es. We have an
ele,hant, and e have giraffes,> %nd #"st naming all the !ig animals. %nd the lady t"rned to *race and
said, >.on't they have great imaginations$> <ot knoing that they really had those things.
4. &kay. +et's talk a little !it a!o"t interventions.
%. &kay.
4. <o, as Michael's mother, did there ever come a time hen yo" heard nes that he had medical
iss"es ca"sed !y ,ain$
%. -es.
4. What ca"sed ,ain for Michael that yo" ere aare of$
%. Well, he had !een !"rnt.
4. Bad !"rns$
%. Bad !"rns on the !ack and the to, of his head. =e even had a !alloon !eteen his scal, and his
head.
4. .id he get migraine headaches$
%. =e got headaches. Gery !ad headaches.
4. Was that from the Pe,si commercial$
%. -es.
4. %nd did Michael take money from 33 that as given to him as a res"lt of !eing !"rned from the
Pe,si commercial and do anything ith that$
%. =e took that money, and he donated it to the !"rn center. %ll of it.
4. .id he have other medical conditions and in#"ries that ca"sed ,ain$
%. Back.
4. Back in#"ries$
%. =e had !ack in#"ries.
4. .id he have a skin condition$
%. -es. =e had vitiligo.
4. What is vitiligo$
%. It's a disease that t"rns yo"r skin hite. B"t hile it's doing that, yo" have 33 yo"'re s,otted. It
orks sloly. %nd so he #"st anted to get it over ith, and so he #"st t"rned the hole thing that ay.
4. <o, did 33 did yo" ever disc"ss ith Michael hether he ever had insomnia$
%. -o" kno, he didn't talk m"ch a!o"t insomnia to me, !"t he o"ld tell me sometimes, >I didn't
slee, last night.> that as hen he as at home. /o I imagine it as #"st starting.
4. .id Michael 33 (!rief ,a"se in the ,roceedings)
4. %ll right. We're talking a!o"t Michael. .id he tr"st doctors$
%. -es, he did.
4. .o yo" kno ho his doctor as$ =is ,rimary doctor$
%. When he as groing ",$
4. When he got older.
%. %s he got older$ I kno that .r. MetCger as his doctor even hen they ere yo"ng, too.
4. .id yo" ever see him a!"se dr"gs or medications$
%. <o. I've never seen that in him.
4. .id yo" hear that ,eo,le said that Michael as a!"sing ,rescri,tion medications$
%. I had heard it.
4. .id yo" hear it from some of yo"r children$
%. -es.
4. .id yo" !elieve it$
%. Well, I kno he as taking ,ain ,ills. %nd hen he said >a!"sing them,> I didn't kno. Beca"se at
that time I had seen Michael so many times, gone to his home "nanno"nced and called him, he didn't
kno I as calling him, I never heard or seen him in that ay. /o I don't kno ho to !elieve it.
4. .id yo" or yo"r children ever try to have any ty,e of intervention of any kind ith Michael$
%. -es. I ent ith them on an intervention once, !eca"se 33 I didn't ant to go, !eca"se I didn't
!elieve it then that he as a!"sing dr"gs. B"t I had heard it from them, and they had heard it, also. B"t
I ent !eca"se they ke,t telling me, >it o"ld mean m"ch more, mother, if yo" o"ld go.>
4. /o yo" ent$
%. /o I ent.
4. %nd did Michael say he had a ,ro!lem$
%. When e got there, Michael as fine.
4. .id yo" hear of other times that ,eo,le tried doing interventions ith Michael$
%. <ot 33 the children talked a!o"t it, !"t I imagine if they did any others, they did it itho"t letting
me kno.
4. .id yo" kno hether he had a ,ro!lem one ay or the other$
%. I co"ldn't ,rove it.
4. .id yo" think may!e he might$
%. I ke,t hearing it. I tho"ght may!e he might. %nd then I 33 hen I ent to his home after he had
moved to +as Gegas, and I talked to him a!o"t it !eca"se I as orried. %nd he ,romised, and he ke,t
saying, >mother, I'm okay. I'm okay.> !"t sometimes the mother's the last to kno. %nd sometimes
they're em!arrassed and don't ant to let me kno. B"t I as 33 I told him, >I don't ant to ake ",
one morning to the nes that yo"'re not here anymore.>
4. <o, hen yo"r son as rehearsing and !eing on to"rs, o"ld yo" see him very often$
%. Pardon$
4. When he as rehearsing or going on to"rs, o"ld yo" see him often$
%. -es, sometimes.
4. .id yo" have a family gathering in May of B997$
%. -es, e did.
4. What as that for$

%. 1hat as s",,osed to !e for my H9th anniversary, !"t it as the rong time. I think Janet #"st
named it that so e co"ld have an anniversary or a ,arty.
4. Were yo" ever asked !y anyone to sign anything saying Michael had any iss"es in B99A$
%. .id I ever$ -es, I did. B"t yo" kno hat$ I really don't remem!er that thing. B"t I did sign
something.
4. .id yo" see Michael 33 in Peo,le magaCine or something$
%. -es.
4. .id yo" see Michael in May at the family gathering$
%. When$ In '97$
4. -es. I ant to sho yo" e2hi!it 636. Is this the family ,ict"re$ (indicating)
%. -es, it is.
4. %nd ho did yo" think Michael as at that time$
%. %t that time, to me, Michael looked okay. +ater I 33 hen I sa it, I sa he as thinner. Beca"se he
as dressed in a #acket and all, I didn't notice that he as very thin.
4. +et me ask yo" this? 'an yo" descri!e 33 okay. +et's look at Michael.
%r( Pa#sh& 'an e Coom in on him$ 1here he is.
4. Who's got the hat on$
%. 1hat's +a1oya.
4. &kay. %nd Michael is ne2t to +a1oya$
%. @h3h"h.
4. >yes>$ &kay. 1hat's good. 'an yo" tell "s, Mrs. Jackson, can yo" descri!e yo"r relationshi, ith
yo"r son Michael$
%. Michael and I ere very close. Michael, he as the ty,e of son, a mother o"ldn't ant a !etter son
than Michael.
4. Was he shy$
%. Michael as very shy.
4. .id he rite a ,oem for yo"$
%. -es, he did. =e rote several ,oems for me.
4. I'm going to sho yo" e2hi!it 69B8, a ,oem he rote called >Mother.> >Mother> 33 did Michael
rite this for yo"$
%. -es.
4. >Mother dear, you gave me life. 'ecause of you, no struggle or strife. #ou gave me joy and
position, cared for me without condition.> %nd it goes on. =o did yo" feel$ In the end, it says? >(o
matter where I go from here, you$re in my heart, my mother dear.> =o did that make yo" feel hen
Michael gave that to yo"$
%. Well, it made me cry, for one thing. %nd I felt very 33 I felt loved. I kne he loved me.
4. %nd after Michael died, did yo" find another ,oem that he had ritten for yo"$
%. -es. =e had scri!!led that on some ,ieces of ,a,er, and Jermaine gave it to me framed. =e m"st
have fo"nd it, and he framed it and gave it to me.
4. +et me sho yo" e2hi!it 69B5 (indicating). %nd this is in Michael's handriting. >a reflection of a
mother's heart is in the glimmer in her children's every> I
%s( Cha#+& Page B.

%r( Pa#sh& It's easier to read. 1his is entitled, >Mother, my &uardian )ngel* !y Michael Jackson?
>The reflection of a mother$s heart is in the glimmer in her children$s eyes. Her every emotion and
feeling is somewhere in her child$s character. (oblemen are what their mother$s made them. !hy
does my mother cry" )re those happy tears or tears of sorrow" +h, please, &od, let them be happy
tears. )ll my success has been based on the fact that I wanted to make my mother proud, to win her
smile of approval.>
When yo" received that, Mrs. Jackson, ho did yo" feel$
%. I cried.
4. %nd ere yo" financially de,endent on yo"r son Michael hile he as alive$
%. -es. Michael took care of me. My every need, my every ant. =e gave me everything.
4. 1he necessities of life, he ,rovided for yo"$
%. -es.
4. .id he give yo" gifts$
%. %ll the time.
4. 'ars, #eelry, mo!ile homes, things like that$
%. -es.
4. .id he give yo" money$
%. -es.
4. .id he give yo" cash$
%. %lays.
4. Why not checks$
%. =e never rote checks.
4. .id Michael ,rovide yo" ith moral s",,ort$
%. -es.
4. 'an yo" tell "s ho have yo" !een affected !y the loss of the love, com,anionshi,, affection,
s",,ort, !y the loss of yo"r son, Michael$
%. )2c"se me. 'an yo" re,eat$
4. /"re. 1he loss of yo"r son, Michael, the s",,ort, the love, ho has that affected yo"$
%. When a mother loses a child, yo" 33 no one knos "ntil it ha,,ens
to them. 1hat's the orst thing that can ha,,en to a ,erson, losing a child. I lost my mother, my father
and my sister. I'm the only one left. B"t hen I lost Michael, I lost everything. =e as the most loving,
don to earth, he loved every!ody. Gery h"m!le. Gery h"m!le. <o matter 33
4. %ll right. %re yo" okay, Mrs. Jackson$
%. I'm okay.
4. +et me ask yo" a!o"t this is it. J"st a little !it a!o"t it. .o yo" remem!er hen yo" first heard
a!o"t it$
%. 1his is it$ -es.
4. %nd ho did yo" learn a!o"t it$
%. Well, I think grace had called me and told me.
4. *race 0aram!a$
%. -es.
4. %ll right. %nd no, the other day, the .efendants, %)*, ,layed a ,ortion of yo"r de,osition,
something to the effect that Michael told yo" that 33 or I think yo" said he #okingly said he didn't ant
to !e moonalking on to"r at the age of F9. -o" remem!er that$
%. -es, I do.
4. 1ell "s a!o"t that.
%. It as 33 Michael said that :"ite a fe years !ack. %nd he as #oking. We ere talking one day, and
e ere #oking, and he said, >I don't ant to !e moonalking at the age of F9.> and I tho"ght it as
f"nny. %nd most of "s say things like that. I "sed to think that F9 as very old. I imagine yo"'ve said
that yo" didn't ant to !e in a co"rtroom ,racticing la at the age of F9, !eca"se yo" think that 33 !"t at
the age 33
4. =ere I am.
%. B"t at the age of F9, it's not as !ad as 33 yo" kno, yo"ng ,eo,le think that a F93year3old is an old
oman, and !y the time yo" get F9, yo" don't even feel old. I can vo"ch for that.
4. <o, Mrs. Jackson, did yo" think yo"r son co"ld have done F9 shos$
%. -es. B"t the only ay he co"ld have done them is if they had them s,aced o"t. 1hey co"ldn't !e
every other night like %)* Wanted at first. 1hat's hy I ke,t calling.
4. Who ere yo" calling$

%. I called 0andy Philli,s, and I called doctor 33 hat's the name$
4. .r. 1ohme$
%. 33 .r. 1ohme, first. %nd I told him, >Michael can't do those shos. 1hey have to change the
sched"le of it.>
4. /o yo" ere #"st concerned a!o"t the s,acing o"t of the concerts$
%. I as concerned a!o"t that. If they s,aced it o"t, he co"ld have done many shos.
4. .id yo" visit Michael ever at the 'arolood home$
%. -es.
4. .id yo" go there !efore he had his ,ress conference in )ngland$
%. -es.
4. Before the ,ress conference, did yo" go in his !edroom$
%. -es.
4. Were there any doors locked at that time$
%. <o. )very time I ent there, e ent into his !edroom, and e ent into all the other ,arts of the
ho"se. My ne,he sitting there no, he o"ld alays !e ith me, and Michael o"ld invite "s ",
there, and e o"ld atch movies, and he o"ld sho "s different things that he had !een doing.
4. &kay. <o, did yo" ever kno ho 'onrad M"rray as !efore yo"r son died$
%. <o.
4. =ad Michael ever mentioned his name or introd"ced yo" to him$
%. <o.
4. When as the first time yo" ever sa 'onrad M"rray$
%. %fter Michael died. %nd I 33 at the time I didn't kno Michael as dead, !eca"se they had #"st
called me and told me to come o"t to the hos,ital. %nd I tho"ght Michael might have !een #"st sick.
4. .id yo" kno anything a!o"t 'onrad M"rray, %)*, negotiations, contracts 33 anything like that
!eteen the to$
%. <o.
4. <o, ho did yo" hear a!o"t Michael's death$

%. I had !een o"t in field service that morning, and hen I came home, I had a call from Joe, my
h"s!and, and he told me that one of the fans had called him and said 33 yo" kno, fans are alays
hanging aro"nd the ho"se o"tside. %nd told him that he sa them !ring some!ody o"t on a g"rney, and
he as covered com,letely ",. %nd Joe called me, and I sort of got angry, and I as scared at the same
time. %nd I said, >oe, that doesn$t have to be Michael. !hy are you doing that to me"> /o later on I
got a call to go to the hos,ital, !eca"se I tho"ght may!e he as sick.
4. .id yo" go to the hos,ital$
%. -es, I did.
4. Who as there$
%. Well, I sa some of the ,eo,le that orked for Michael, and I sa 'onrad M"rray, not knoing
ho he as. =e as ,acing !ack and forth. %nd so my ne,he and I ere talking, >!ho is this man
that is going back and forth"> %nd e sa Frank .ileo, and finally Frank .ileo said, >That$s ,r.
Murray.> 1hat's the only time I kne ho he as. %nd still I as asking him, >!here is Michael" I
want to go see him.> %nd no!ody anted to tell me. %nd so they took me to a room, and I as sitting
in there aiting. %nd so I g"ess they ere !ack there de!ating some!ody to come. %nd so Frank .ileo
came and told me that Michael had a reaction. %nd I said, >!ell, how is he"> %nd no!ody said
anything at first. 1hey looked so f"nny. %nd I said, >!ell, did he make it" ,id he make it"> %nd Frank
said, >(o.>
4. What did yo" do$
%. I as 33 everything ent dark, and I #"st heard screaming.
4. .id yo" see Paris and Blanket and Prince at this time$
%. <o. I didn't see them "ntil later. 1hey took me into a room, and they had to n"rses in there. %nd
then they !ro"ght Paris and Blanket and Prince in the room. %nd they as crying so hard.
4. Was Paris doing anything in ,artic"lar$
%. /he as #"st screaming, looking ", at the sky, to the ceiling, saying, >,addy, I want to go with
you. I can$t live without you. I$m going with you.> 1hat's all she ke,t saying. %nd then they ke,t going
don to the morg"e. I g"ess it as the morg"e. /omehere in the hos,ital. I didn't go !eca"se I didn't
ant to see Michael like that. %nd they ke,t going don and coming !ack and go !ack again. Finally,
+a 1oya came, and she ent don ith them. %nd I said, >!hat are they doing"> and she said,
>They$re hugging their daddy and crying.>
4. .id 33 after yo" left the hos,ital, did yo" take the children to =ayvenh"rst ith yo"$
%. -es. 1hey told "s that it as time for "s to go and that 33 e had !een there for a long time. %nd
Paris and the kids came o"t, e alked o"t to the garage here the cars ere, and Paris looked at me
and said, >&randma, where are we going">

4. It's okay. We're going to get thro"gh this. .id Paris say something to yo"$
%. Pardon$
4. .id Paris say something to yo", Mrs. Jackson$
%. -es, she did. /he looked ", at me and said, >&randma, where are we going"> %nd I told her,
>#ou$re going home with grandma.>
4. %ll right. I ant to sho 33 move off that 33 698836. 1his is a ,ict"re at the memorial service
(indicating). Is that yo" ith Blanket and Paris$
%. -es.
4. &kay. =as it !een a diffic"lt ad#"stment for the children itho"t their father$
%. 1he to !oys ad#"sted fine. I o"ldn't say >fine,> !"t 33 !eca"se yo" never kno ith their
thinking. B"t Paris had the hardest time. B"t I tho"ght she as the !ravest !eca"se 33 she had so many
,ict"res of Michael. When I told her I as going to decorate her !edroom, and I !o"ght everything and
decorated. %nd I had some of my ,ict"res for her !edroom. %nd she said, >I have ,ict"res.> and she had
a!o"t five !ig ,ict"res of Michael, and she said, >I ant these to over my !ed> and over her desk. /he
had them all over her room. %nd I as ondering, >=o co"ld she do that$> Beca"se I didn't ant to
see himD every time I sa him, I felt so sad. 1hen after e moved, she #"st had a collage. =er hole
all, like the one yo" sa of the ho"se that Michael did for me. =er !edroom as #"st Michael's
,ict"res.
4. <o, did Paris do something a!o"t getting a necklace ith a heart$
%. -es. Before e ,"t Michael aay, my ne,he and I and Paris and her !rothers, she had "s r"nning
everyhere trying to find this s,ecial heart. %nd it as a heart, a !roken heart. %nd hen she got it, she
ent to the morg"e, and she h"ng one ,art aro"nd her father's neck, and she ore the other half.
4. I ant to sho yo" e2hi!it 698536. Is that Prince (indicating)$
%. -es.
4. =o has Prince !een affected$
%. Prince, he talks a!o"t his father sometimes. B"t he has a lot of com,any ith his co"sins and
things, and he doesn't sho his emotions that m"ch.
4. =e's more s"!d"ed$
%. -es.
4. 'an yo" tell he misses his father$

%. &h, yes, he does.
4. <o, Paris. +et me sho 698F36 (indicating). Paris. .id she "sed to take one of Michael's shirts
and do something ith it$
%. -es. /he took his ,a#ama to, hen he first died, and she didn't ant any!ody to ash it. /he said,
>I ant it #"st the ay daddy ore it. I ant his scent on it.> she ,"t it in a ,illo, and she ,"t a !ell
aro"nd it, and she sat it on her !ed, and that's the ay she anted it.
4. =o has Paris !een affected !y the loss of her father$
%. &h, my goodness. /he 33 one of my grandchildren told me that she o"ld tell them that she anted
to go here daddy as.
4. /he had a hard time$
%. /he had a very hard time at first.
4. =as she had to get medical hel,$
%. Pardon$
4. =as she had to get medical hel,$
%. -es.
4. *o to the hos,ital$
%. -es.
4. =as she had a really hard time ith the loss of her father$
%. -es.
4. =o a!o"t Blanket$
%. Blanket as yo"ng. =e as seven hen Michael died. =e's 66 no. =e's come a long ay.
4. =o often as he ith his father$
%. )veryhere Michael ent. 1he other kids ere in school, so everyhere Michael ent, he took
Blanket ith him.
4. +et me sho e2hi!it 698H36 (indicating). Is that Blanket$
%. 1hat's Blanket.
4. =e still have long hair$
%. -es.
4. .oes he like long hair$
%. =e don't ant to c"t it !eca"se that's the ay Michael liked it. =e's 66, !"t he's going to have to c"t
it sooner or later.
4. -o" don't ant him ith long hair$
%. I don't ant the long hair, !"t he doesn't ant to c"t it so I'm not going to do it to him yet.
4. +et's talk a!o"t Michael !eing a father. .o yo" kno if he anted to !e a father$
%. My goodness. More than anything else.
4. .id yo" have occasion to talk ith him and o!serve him ith children$
%. -es. 1alked to him a lot.
4. =o o"ld yo" descri!e Michael as a father$
%. =e's one of the !est fathers. -o"'d !e s"r,rised. -o" o"ld really !e s"r,rised at hat a good father
he as. =e cooked for them. =e did all these things. %nd he never cooked !efore, !"t the kids think it's
the !est food they ever tasted.
4. .id Michael's riting of m"sic change at all after he had children$
%. -es, it did.
4. =o$
%. Well, his m"sic as more, I sho"ld say, loving, more meaningf"l. =e rote from his heart more. It
#"st changed his life, and it reflected in his m"sic.
4. Is there a song that he rote that's very s,ecial to yo" after his children ere !orn$
%. %fter$
4. %fter the children.
%. Were !orn, yo" said$
4. -eah.
%. I can't think of anything like 33 /,eechless.
4. I kno he
Wrote that song, /,eechless$
%. -es.
4. What is that song a!o"t$
%. 1hat song's a!o"t the love a ,erson had for their children. %nd hen it comes to descri!ing it,
yo"'re s,eechless, !eca"se there are no ords to com,are to ho yo" feel.
4. %nd did Michael rite that song in a long time or a short time$
%. In 5F min"tes.
4. .o yo" kno here he as$
%. =e as somehere on the road. %nd *race told me I
%r( Put#a3& &!#ection. 'alls for hearsay, yo"r honor( 0S189 P91NA%:4
Ju!+e& /"stained. *race told her.
%r( Pa#sh& 1hat's fine. 1hat's okay.
4. +et's ask? .id yo" go thro"gh some videos and ,ict"res to make something, a tri!"te to Michael of
him ith his children ith the song that he rote a!o"t children$
%. -es.
4. %nd did yo" 33 hat's the name of the song$
%. >s,eechless.>
4. &kay. I'm going to mark 69BF. %nd I'm #"st going to ,lay it.
0Pla#t""s; e7h)t #o( 102<6 a v!eo $lp o" Spee$hless6 /as 3ar.e! "or !e#t"$ato#4
4. Is that one of yo"r favorite songs$
%. Pardon$
4. Is that one of yo"r favorite songs$
%. -es.
4. &kay. +et's take a look at that.
4. Mrs. Jackson, do yo" miss yo"r son$
%. Words can't e2,lain it.
%r( Pa#sh& &kay. 1hat's all the :"estions I have. 1hank yo".
Ju!+e& &kay. 'ross3e2amination.

Cross=e7a3#ato# )y %arv# Put#a3&
4. -o" okay, Mrs. Jackson$
%. -es.
4. If at any ,oint yo" need a !reak for any reason, o"ld yo" ,lease #"st let me kno, ma'am$
%. -es.
4. Prior to !eing here today, Mrs. Jackson 33
%. Pardon$
4. Prior to !eing here today 33
%. -es.
4. 33 did yo" have the o,,ort"nity to go over yo"r testimony here today ith yo"r attorney$
%. -es.
4. %nd so yo" ent thro"gh the things, and hat as going to !e shon, and the :"estions askedD
correct$
%. <ot today, !"t yesterday.
4. We haven't had that o,,ort"nity, have e$
%. <o.
4. %nd so as a res"lt, I'm going to !e going thro"gh different ,laces. If yo" don't "nderstand my
:"estion or anything, co"ld yo" ,lease #"st let me kno$
%. -es, I ill.
4. %ll right. 1hank yo", ma'am. -o" initiated this las"it against
%)* +iveD correct$
%. -es.
4. %nd do yo" remem!er hen yo" filed this las"it, ma'am$
%. I don't remem!er the e2act time.
4. If I ere to tell yo" that it as in /e,tem!er of B969, o"ld that so"nd right to yo"$
%. 1hat's a!o"t right.
4. %nd yo" !ro"ght this las"it on !ehalf of yo"rselfD correct$
%. -es.
4. %nd yo" also !ro"ght it as the g"ardian to Mr. Jackson's three childrenD correct$
%. -es.
4. %nd as it yo"r choice, Mrs. Jackson, to !ring this las"it$
%. -es, it as.
4. %nd did yo" ever talk to Mr. Jackson's children a!o"t hether or not to !ring this las"it$
%. I never talked to the children a!o"t it.
4. &kay. /o this as yo"r decision aloneD correct$
%. -es.
4. .id yo" ever disc"ss it ith any of yo"r children ,rior to !ringing the las"it$
%. %fter.
4. %fter. %nd hat a!o"t ith yo"r h"s!and, Joe Jackson$ .id yo" disc"ss it ith him$
%. <o, I never did.
4. /o did yo" disc"ss this ith any!ody !esides yo"r attorneys ,rior to !ringing the las"it$
%. I don't think so. I can't remem!er that, doing anything like that. My h"s!and doesn't live ith me,
so I didn't disc"ss it ith him.
4. %nd yo" !ro"ght this las"it, yo" said, des,ite the fact that yo"'re a very ,rivate ,ersonD correct,
ma'am$
%. -es, I am.
4. %nd 33 !"t yo" have lived a very ,"!lic life for the last 59 years, have yo" not, ma'am$
%. =o many$
4. 59.
%. My family's famo"s. I haven't lived a very ,"!lic life !eca"se I as alays in the !ackgro"nd.
4. B"t yo" have given intervies on .ateline, haven't yo"$
%. -es, I have.
4. &n B9JB9$
%. -es.
4. H9 Min"tes$
%. -es.
4. &,rah$
%. -es. 1hat as after my son died.
4. %nd hat a!o"t 33 yo"'ve come o"t ith !ooksD correct$
%. Pardon$
4. -o"'ve come o"t ith !ooks, ma'am$
%. -es.
4. Incl"ding the story of yo"r life$
%. -es.
4. -o"'ve gone on !ook to"rs$
%. -es.
4. %nd so hen yo" say that yo"r life is ,rivate, I #"st ant to "nderstand hat yo" meant !y that.
%. I don't "nderstand yo"r :"estion.
4. Well 33
%. What 33
4. )2c"se me, ma'am$
%. My life is ,rivate as m"ch as I can kee, it ,rivate.
4. %nd yo" said a co",le times that yo"'re nervo"s, and I as ho,ing to "nderstand hy, ma'am. Why
are yo" nervo"s$

%. I'm ", here talking in front of all these ,eo,le. I don't kno them. %nd I imagine anyone o"ld !e
nervo"s at first. I'm a little more calm no.
4. &kay. %nd yo" said that yo" !ro"ght the las"it !eca"se yo" anted to search for the tr"thD is that
right, ma'am$
%. -es.
4. %nd is that hat yo"'re ho,ing ill come o"t of this las"it$
%. I ant to find o"t, and I think I oe it to my son to find o"t hat really ha,,ened to him. I've had 33
heard a lot of stories, and I kno and I even heard from my grandchildren after my son died that my
son as !eing ,ress"red, and he as asking for his father. %nd the kids o"ld tell him he didn't kno
hat to do. My son as sick, and no!ody is like 33 I can't think of 33 (enny &rtega said they o"ldn't
even hand him a hot c", of tea, and they kne he as sick. %nd instead of calling 33 no!ody said,
>+et's call the doctor. +et's see hat's rong ith him.> <o!ody said that. %nd I as sitting there
listening, and I as ondering, and I as sitting there listening to all the names they called. 1hat's hard
for me, sitting in co"rt and listening to them call my son a freak, saying he as laCy. %nd not too long
ago, co",le days last eek, I had 33 no, I as 33 this eek I had to listen to a lot of things, talking a!o"t
ho !roke he as. =e didn't take a dime home. B"t if yo" kno he didn't take a dime home, hy didn't
yo" look f"rther and see that hy he didn't take a dime home$ =e gave it to charity, and he gave a lot
of things to charity.
4. %nd I a,ologiCe, ma'am. I don't :"ite "nderstand it. When yo" say >she said,> ho are yo" talking
a!o"t$
%. -o" kno ho I'm talking a!o"t$
4. Who are yo" talking a!o"t, ma'am$
%r( Pa#sh& Ms. /trong.
4. &h, yo" mean the oman asking the :"estions$
%. It h"rts to sit here in co"rt and listen to all these things a!o"t him, defining him as a freak and all of
that. It's hard for me. %nd then listening to ho sick my son as and no!ody as trying to hel, him.
4. <o, d"ring this time ,eriod, ma'am, yo"'ve !een here most days, have yo" not, for the last 6B
eeks$
%. -es, I have.
4. %nd yo" do "nderstand that the ,eo,le ho ere called as itnesses in the last 6B eeks ere
called !y yo"r attorneyD correct$
%. -es.
4. %nd, ma'am, hen yo" talk a!o"t ,eo,le calling the doctors, I mean, yo"'ve heard ,eo,le testify
a!o"t trying to reach the doctor or reach the doctor or call the doctor$ .id yo" hear that, ma'am$ .id
yo" hear the testimony$
%r( Pa#sh& Gag"e and am!ig"o"s as to time.
1he /t#ess& <o, not 33
Ju!+e& &verr"led.
%r( Pa#sh& <ever mind. *o ahead.
1he /t#ess& <ot 33 not o"tside doctors. My son needed another doctor, not .r. M"rray.
4. B"t yo" hadn't met .r. M"rray everD correct, ma'am$
%. <o, I hadn't.
4. B"t yo" did hear testimony here saying yo"r son had !een "sing .r. M"rray as his ,hysician since
B99H, didn't yo", ma'am$
%. 1hat doctor as for his children, !"t I didn't kno ho he as. I had heard from grace that they
had got a doctor. %nd later I heard that it as .r. M"rray. I didn't kno.
4. /o yo" had heard from Ms. 0aram!a that a doctor had !een hadD is that correct, ma'am$
%. From ho$
4. Ms. 0aram!a. *race. -o" had heard that from her$
%. I had heard hen the children ere sick that some!ody got a doctor in vegas for them.
4. When yo" say that it's hard to sit here and listen to ,eo,le say these things, and yo" mentioned no
a co",le times the idea of yo"r son !eing laCy, yo" also heard Mr. *ongaare e2,lain that hat he
meant !y that as that yo"r son didn't like to rehearse. -o" did hear thatD correct, ma'am$
%. %ll I heard as >laCy.> may!e he as talking a!o"t rehearse, !"t he's not laCy.
4. I "nderstand that. I'm asking, did yo" hear hat Mr. *ongaare act"ally meant !y those ords$
%. -es.
4. %nd yo" heard hat he saidD that he as talking a!o"t the fact that Mr. Jackson historically didn't
like to rehearse$
%. Mr. Jackson as sick, and he co"ldn't rehearse.

4. Well, for e2am,le, yo" heard the testimony, did yo" not, ma'am, here it talks a!o"t the fact that he
didn't like to rehearse for the dangero"s to"r$
%. -es.
4. %nd did yo" hear the testimony here he said he didn't like to rehearse for the history to"r$
%. <o.
4. <o$ %nd 33
%. <o. I had heard from the to"r that he's taking 33 as taking no. I never heard he as laCy for the
other to"rs. Michael never rehearsed a lot, !eca"se he kne hat he as doing, and he kne 33 and he
as ,art of creating the dances and all of that, so he didn't need that m"ch rehearsing.
4. I fact, he often didn't rehearse !eca"se he as doing the same dances that he had createdD correct,
ma'am$
%. -es.
4. %nd if yo" recall, the email that Mr. *ongaare rote, he rote ,rior to Mr. Jackson starting the
to"r rehearsals for the 1his Is It to"r, talking a!o"t the idea that he had !een laCy on ,rior to"rs !eca"se
he didn't rehearse. -o" remem!er that testimony, ma'am$
%. <o, I don't. I remem!er him talking a!o"t him !eing laCy, and a lot of things I didn't hear !eca"se
that h"rts, and I closed my ears to it.
4. &kay. B"t yo" do ant to kno the tr"thD right, ma'am$
%. I ant to kno the tr"th hat ha,,ened to him.
4. %nd yo" said that it's hard to sit here and listen to all these "ntr"e, !ad things. What ere the other
"ntr"e, !ad things that yo"'ve heard in the last 6B eeks$
%. I can't remem!er. I #"st kno they ere !ad things.
4. &kay. B"t other than the >laCy,> yo" don't remem!er hat that asD is that correct, ma'am$
%r( Pa#sh& &ther than hat she already testified to$
%r( Put#a3& @h3h"h. -es, sir.
1he /t#ess& 1hank yo".
4. Is that correct, ma'am$
%. What's correct$
4. 1hat hen yo" said that it's hard to sit here and listen to these !ad things, one mentioned the idea 33
the email here Mr. *ongaare said that he as laCy, and I'm asking yo" if yo" can remem!er hat
other !ad, "ntr"e things yo"'ve heard in the last 6B eeks$
%. 1hey called him a freak.
4. %nd yo"'re talking a!o"t the email 33
%. 1hey ere making f"n of him. >Finally get a chance to meet the freak.>
4. %nd are yo" talking 33
%. %nd yo" kno 33
4. -o"'re talking a!o"t an email from someone ho isn't a ,arty to this las"itD correct, ma'am$ 1hat
as some!ody o"tside of the .efendants in the las"it ho said that. .o yo" remem!er that, ma'am$
%r( Pa#sh& I'm going to o!#ect. It's not o"tside the defense. It's the general co"nsel layer.
%r( Put#a3& <o, it's not general co"nsel.
%r( Pa#sh& It as %)*'s general co"nsel 33
%r( Put#a3& <ot tr"e.
Ju!+e& &verr"led.
%r( Pa#sh& 33 Mr. Fikre.
%r( Put#a3& Fikre.
%r( Pa#sh& -eah. Mr. 1rell's !oss.
%r( Put#a3& <ot Mr. 1rell's !oss.
4. .o yo" recall that, Mrs. Jackson, that it as act"ally sent to some!ody at %)* +ive, not sent from
%)* +ive$ -o" remem!er that, ma'am$
%. I don't kno ho it as, !"t I'm #"st saying that it's hard to sit here and listen to it.
4. %nd I "nderstand that, ma'am. I do. I'm #"st trying to "nderstand. -o" said it's hard to listen to the
"ntr"ths, and yo"'re looking for a search to the tr"th, and I'm trying to think of hat "ntr"e things yo"
heard, ma'am.
%. =e's not a freak.
4. %nything else, ma'am$

%. My son is dead. =e's not here to talk for himself, so anything !ad that's said a!o"t him h"rts very
m"ch.
4. B"t 33
%. %nd some ,eo,le love doing that to him.
4. .oing that to yo"r son$
%. -es.
4. In fact, that as one of the hard things for yo", I'm s"re, the last fo"r years of all the !ad things that
ere said a!o"t yo"r sonD correct, ma'am$
%. -es.
4. %nd that's !eca"se ,eo,le didn't kno the Michael Jackson yo" kneD correct, ma'am$
%. 1r"e.
4. 1hey only kne hat they sa e2ternallyD they didn't kno hat he as act"ally like ,rivatelyD
correct, ma'am$
%. -es.
4. In yo"r attorney's o,ening statements, he said that yo"r son, Michael Jackson, as a dr"g addict.
-o" remem!er hen he said that$
%r( Pa#sh& &!#ection. Misstates hat I said.
Ju!+e& &verr"led. 1he #"ry ill remem!er hatever yo" said.
4. 0emem!er that, ma'am$
%. <o, I don't remem!er that.
4. .o yo" remem!er in o,ening statements hen yo"r attorney talked a!o"t the idea that they o"ld
not deny the fact that yo"r son had tro"!le ith dr"gs$
%. -o" kno, I don't remem!er. B"t my son as on ,rescri,tion dr"gs, !"t it doesn't make it tr"e a!o"t
hat other dr"gs they say he's on, !eca"se all his dr"gs 33 !eca"se if he had ,ro!leMs.
4. %nd that's hat I anted to ask yo", ma'am, !eca"se yo" said it as hard to sit here and listen to
the things "ntr"e. %nd I as ondering if one of the things that as "ntr"e as hat yo"r attorney said
a!o"t his ,ro!lem in o,ening statements a!o"t his ,ro!lem ith dr"gs$
%. -es, it o"ld !e hard to listen to.

4. /o that as hard to listen to as ellD correct, ma'am$
%. I don't even remem!er him saying that, to tell yo" the tr"th.
4. -o" don't, ma'am$
%. <o.
4. &kay. +et's go !ack to this las"it, ma'am. /o in /e,tem!er of B969 yo" !ro"ght this las"itD
correct, ma'am$
%. -es.
4. %nd one of the ,eo,le yo" s"ed as (enny &rtega, asn't it$
%. I don't kno.
4. -o" don't remem!er that, ma'am$
%. <o.
4. %t the time 33 !"t only yo" decided to !ring this las"it$
%. 1here as a list of ,eo,le, !"t I can't remem!er ho all as on the list.
4. %nd one of those ,eo,le 33 I'll re,resent to yo", ma'am, that one of those ,eo,le as (enny &rtegaD
okay$
%. &kay.
4. .o yo" remem!er hy yo" !ro"ght a las"it against (enny &rtega$
%. 1hat as all ,art of 33
4. I'm sorry, ma'am$
%. Forget it.
4. Forget hat, ma'am$ 'an I have the :"estion reread for yo", ma'am$
%. Pardon$
4. Wo"ld yo" like me to have the :"estion reread$ Wo"ld that !e hel,f"l$
%. <o. It o"ldn't !e hel,f"l.
4. It o"ldn't !e hel,f"l$
%. <o.
4. Why is that, ma'am$ Is it !eca"se yo" don't kno hy$
%r( Pa#sh& -o"r honor, I o"ld o!#ect. %nything disc"ssion ith her attorneys and s"ch, that's
,rotected.
Ju!+e& If it concerns disc"ssions ith her attorneys, then that o"ld !e ,rivileged.
%r( Put#a3& I didn't ask 33 I asked her hy she !ro"ght the las"it.
%r( Pa#sh& If it's things her and her attorneys disc"ssed, it's ,rivileged.
Ju!+e& Ma'am, o"ld it involve the disc"ssions yo" had ith yo"r attorneys$
1he /t#ess& -es.
%r( Pa#sh& 1hat's an "nverified com,laint filed !y the layers.
Ju!+e& %ll right.
4. .id yo" have an "nderstanding that the time came here yo" dro,,ed yo"r las"it against (enny
&rtega$
%r( Pa#sh& /ame o!#ection.
Ju!+e& /"stained. Will yo" sti,"late that that's hat ha,,ened$
%r( Pa#sh& We already !ro"ght that ", already. It's in evidence. )very!ody knos that.
Ju!+e& Is there a sti,"lation that (enny &rtega as s"ed and dro,,ed from the las"it vol"ntarily$
%r( Pa#sh& %!sol"tely. We ent thro"gh that ith Mr. &rtega.
Ju!+e& %ll right.
4. .id yo" have an "nderstanding hen the time came that yo" dro,,ed yo"r las"it against (enny
&rtega$
%r( Pa#sh& &ther than if yo" learned it from the layers.
%r( Put#a3& It's a fact, yo"r honor, that it o"ld not !e ,rotected that yo" dro,,ed a las"it against
someone.
Ju!+e& =e's sti,"lating to it. %re yo" ref"sing to acce,t the sti,"lation$
%r( Put#a3& I acce,t the sti,"lation. I ant to kno if she kne that.
%r( Pa#sh& It's irrelevant.
Ju!+e& /"stained. 1he sti,"lation acce,ted. 1he #"ry has to acce,t it. It's tr"eD it's sti,"lated. %nd it's
also 6B?99. /o 6?89.
01he 2ury e7ts the $ourtroo34
Ju!+e& &kay. 6?89.
0Lu#$h )rea.4
01he "ollo/#+ pro$ee!#+s /ere hear! # ope# $ourt6 outs!e the prese#$e o" the 2ury4&
%r( Pa#sh& Ms. Jackson got less than three ho"rs slee,, she as slee,ing at l"nch, I think an ho"r or
so ill ,ro!a!ly !e her limit. Mr. P"tnam s"ggests ho"rs, so I don't think e'll finish today. I informed
Mr. P"tnam of that.
Ju!+e& &kay. We'll do as m"ch as e can.
%r( Pa#sh& &kay. I #"st don't ant her to !e too tired.
01he "ollo/#+ pro$ee!#+s /ere hel! # ope# $ourt6 # the prese#$e o" the 2urors4&
Ju!+e& (atherine Jackson vers"s %)* +ive. -o" may contin"e ith cross e2amination
%r( Put#a3& 1hank yo", yo"r honor.
Co#t#ue! $ross e7a3#ato# )y %arv# Put#a3&
4. Mrs. Jackson, yo" remem!er earlier, !efore l"nch, I indicated if yo" had to sto, at any time, e
co"ld, right, ma'am$
%. -es.
4. %nd I've !een told that yo"'d like to go only a!o"t another ho"r todayD is that correct, ma'am$
%. -es.
4. /o I'm going to try to get a little !it in thereD and then in a!o"t an ho"r, e'll !reak. %ll right,
ma'am$
%. -es, thank yo".
4. /o here e left off, yo" had indicated that in 33 in !ringing this las"it, yo" hadn't s,oken to yo"r
grandchildren and yo" hadn't s,oken to yo"r si!lings and yo" co"ldn't remem!er conferring ith
anyone else !efore yo" !ro"ght the las"it e2ce,t yo"r attorneysD is that correct, ma'am$
%. -es.
4. %nd this as in /e,tem!er of B969$
%. I don't remem!er, !"t yo" remind me.
4. &kay. If I ere to re,resent to yo" that it as /e,tem!er 6F, B969, o"ld that so"nd right, ma'am$
%. /o"nds right.
4. %nd can yo" recall that this as !efore there had !een a criminal trial of .r. 'onrad M"rray$
%. <o. I think it as after. I'm not s"re.
4. If I ere to let yo" kno that the criminal trial as the folloing year, that o"ld 33 o"ld that
come as a s"r,rise to yo", ma'am$
%. I'm not s"re.
4. -o" #"st don't remem!er$
%. <o.
4. Beca"se yo" did attend the criminal trial, correct, ma'am$
%. -es, I did.
4. %nd yo" tried to attend that almost every day$
%. Pardon$
4. %lmost every day$
%. -es.
4. Is it fair to say, ma'am, that the criminal trial of .r. 'onrad M"rray didn't ,lay in in any ay in yo"r
decision to !ring this action here$
%r( Pa#sh& &!#ection, yo"r honor. %gain, calls for disc"ssions of attorney. %ll this is attorneyJclient.
/he's already said that she didn't disc"ss it ith anyone other than her attorneys, so any information she
o"ld have o"ld !e from her attorneys.
%r( Put#a3& -o"r honor, information, as yo" kno, is not ,rivileged. 1here are facts that are facts.
1hat said, yo"r honor, hat I am asking is I ass"me she made an inde,endent decision as to hether or
not to !ring this las"itD and in so doing, I'm asking hether the criminal trial of .r. 'onrad M"rray
,layed any role in her determination to !ring this las"it.
%r( Pa#sh& B"t if she disc"ssed it ith her attorneys 33

Ju!+e& Well, hat yo" can do is ,erha,s ,hrase it, >inde,endent of any conversations yo"'ve had 33>
%r( Put#a3& I'd !e ha,,y to. %!sol"tely, yo"r honor.
Ju!+e& If there is no inde,endent, then 33
4. /o, Mrs. Jackson 33 ell, let me ask it this ay? .id yo" consider anything in !ringing this las"it
inde,endent of yo"r disc"ssions ith yo"r attorneys$
%. -es.
4. -o" did. %nd did that incl"de the criminal trial of .r. 'onrad M"rray$
%. %fter atching.
4. %fter atching$
%r( Pa#sh& &!#ectionD the las"it as filed. =e said !efore the criminal trial, so ho co"ld it have
anything to do ith this$
%r( Put#a3& 1hat's hy I'm asking.
Ju!+e& &verr"led.
1he /t#ess& I don't "nderstand a lot of things yo"'re saying. I hear yo", !"t 33
%r( Put#a3& +et me try to !reak it don for yo" a little !it. &kay, ma'am$
4. -o" filed yo"r las"it in /e,tem!er of B969, correct$
%. -es.
4. %nd if I "nderstand correctly, yo" didn't consider anything 33 yo" didn't have conversations ith
anyone other than yo"r attorneys a!o"t !ringing that las"it, correct$
%. J"st 33 #"st the attorneys.
4. J"st the attorneys, right, ma'am$ 1here as no!ody else yo" talked a!o"t yo"r considerations in
!ringing a las"it ,rior to !ringing the las"it, correct$
%. 'orrect.
4. %nd hen yo" ere thinking a!o"t hether or not to !ring that las"it, as a consideration at that
time the fact that .r. 'onrad M"rray as going to !e having a criminal trial$
%r( Pa#sh& <on3 33 incom,rehensi!le. )verything as ith the disc"ssions ith her attorneys. =o
co"ld something else !e a factor$

Ju!+e& If it's inde,endent of the attorneyJclient 33 yo" need to make it clear to her so she's 33 the fear is
that she's going to inadvertently disclose comm"nications ith her attorney, so 33
%r( Put#a3& +et me !e very clear, Ms. Jackson. I don't ant to kno anything that yo" disc"ssed
ith yo"r attorneys ever. %ll right, ma'am$ Before the las"it or after the las"it. 1hat's not hat I'm
asking for. What I'm trying to determine, ma'am, is yo"r inde,endent considerations, hat yo" yo"rself
tho"ght a!o"t o"tside of those conversations ith yo"r attorneys.
4. Was there anything that yo" considered e2ce,t hat as given to yo" !y yo"r attorneys in terms of
!ringing this las"it$
%r( Pa#sh& I'm going to o!#ect to >What as given to yo".> I mean, e #"st disc"ssed 33 there 33 I
o!#ect to the :"estion, >given to.>
Ju!+e& &verr"led.
1he /t#ess& I'm getting conf"sed the ay he's asking the :"estions.
4. Was there anything yo" tho"ght a!o"t other than yo"r disc"ssions ith yo"r attorneys hen yo"
decided to !ring this las"it, ma'am$
%. 0e,eat yo"rself.
4. &f co"rse. Was there anything other than yo"r disc"ssions ith yo"r attorneys that yo" considered
in deciding to !ring this las"it in /e,tem!er of B969$
%. Before conrad M"rray's trial$
4. It as, in fact, !efore .r. 'onrad M"rray's trial, ma'am, yes.
%. I don't remem!er.
4. %ll right. %nd is it fair to say as yo" sit here today, ma'am, that yo" don't remem!er hether .r.
'onrad M"rray's trial as !efore or after yo" !ro"ght yo"r las"it$
%. -o"'re the one that got me conf"sed.
4. =o did I get yo" conf"sed$ .id I get yo" conf"sed 33
%. I #"st don't remem!er.
4. .id I get yo" conf"sed !eca"se I let yo" kno that the las"it ith .r. 'onrad M"rray as after
yo"r las"it$ Is that hat conf"sed yo"$
%r( Pa#sh& First of the all, there's no las"it.
%r( Put#a3& 'riminal trial.

%r( Pa#sh& It's also irrelevant.
%r( Put#a3& I don't !elieve it's irrelevant, yo"r honor.
%r( Pa#sh& 0elevant for hat$
Ju!+e& &verr"led. &kay. Why don't yo" #"st sti,"late that that's the time frame$
%r( Pa#sh& We already did. 1hey kno hen the case as filed. =e's already testified.
%r( Put#a3& Move to strike, yo"r honor, his comments.
%r( Pa#sh& Mr. P"tnam has already said the dates. We're not dis,"ting the dates. %gain, there's no
iss"e a!o"t that.
%r( Put#a3& I'm trying to "nderstand her reasons s",,ort !ringing the las"it, yo"r honor.
%r( Pa#sh& =er reasons for !ringing 33
%r( Put#a3& I'm s"re yo"'d like to say hat they are. %nd hat I'm trying to determine is if there's
anything inde,endent of the conversation she had ith these attorneys that as relevant to !ringing this
las"it.
Ju!+e& Well, yo"'ve asked a co",le of times. I'll let yo" ask it one more time, !"t yo"'ve asked a
co",le times already. B"t 33
%r( Put#a3& %nd I haven't gotten an anser yet, I'm trying to fig"re o"t a ay to ask it 33
%r( Pa#sh& /he has ansered the :"estion.
Ju!+e& %sk it one more time.
4. Mrs. Jackson, e2ce,t for conversations that yo" had ith yo"r attorneys, as there anything
inde,endent of that that yo" considered hen deciding to !ring yo"r las"it 33 this las"it in
/e,tem!er of B969$
%. I don't remem!er.
4. /o this las"it starts in /e,tem!er of B969. .o yo" remem!er that once the las"it started, each of
the sides asked the other side for information and gave each other doc"ments$ .o yo" remem!er
anything a!o"t that, ma'am$
%. -es.
4. %nd do yo" recall yo"r ,roviding any doc"ments to the .efendants in this case, yo" yo"rself,
ma'am$
%. 'an yo" re,eat yo"r 33

%r( Pa#sh& -o" mean thro"gh her attorneys$
%r( Put#a3& -es, thro"gh her attorneys.
Ju!+e& Make it clear. Beca"se she's not going to !e alking over to yo"r office and handing them to
yo", so make it clear that 33
4. Mrs. Jackson, did yo" ,rovide any doc"ments to yo"r attorneys so that they co"ld give them to "s
in the three years !eteen the start of this las"it and o"r !eing at trial in this las"it$
%. My doc"ments$
%r( Pa#sh& Wait a min"te. Wo"ldn't that !e attorneyJclient ,rivilege, hat she ,rovided to "s$
Ju!+e& &verr"led.
1he /t#ess& -es.
4. -o" gave some doc"ments$
%. <o, no, no, I'm not saying >yes> for yo".
%r( Put#a3& &kay. -o"'re ansering his :"estion. *o ahead.
Ju!+e& 0e,eat the :"estion.
%r( Put#a3& &kay.
4. %re yo" a!le to go on today, Mrs. Jackson$ Is it too hard to go on today$
Ju!+e& =o are yo" doing.
01he /t#ess spea.s to the Ju!+e # u#!erto#e4
Ju!+e& I think she's ,ro!a!ly had eno"gh today. Why don't e recess for today. /he's tired, so I think
it's a good time. +et me #"st find o"t hen I need to call yo" !ack. &kay$ 7?89 on Monday. 1hank yo".
.on't talk a!o"t the case, disc"ss the case, or read anything a!o"t the case.
01he "ollo/#+ pro$ee!#+s /ere hel! # ope# $ourt6 outs!e the prese#$e o" the 2urors4&
Ju!+e& .oes someone ant to assist the itness don$
%r( Pa#sh& I'll hel,.
1he /t#ess& I as getting conf"sed. I'm tired.
%r( Pa#sh& 1hat's okay.

Ju!+e& Well, I #"st o"ld make a s"ggestion. J"st try to !e clear ith some of the :"estions !eca"se,
o!vio"sly 33 !reak them don a little !it, es,ecially hen she's I it's toard the end of the day, and
she's getting tired.
%r( Pa#sh& It's very fast, the :"estions. <ot that they're "n"s"ally fastD !"t may!e for someone for
that age, it might !e !etter to slo don the :"estions and !reak them don a little !it.
Ju!+e& It might !e 33
%r( Pa#sh& I'm going to start o!#ecting. I mean, a lot of this st"ff, yo" kno, e're getting
contentions 33 e'll deal ith it later.
%s( Ste))#s& -o"r honor, it's not "nfair or im,ro,er to ask a itness hy she !ro"ght the las"it,
and I think that's all that as trying to !e asked.
%r( Pa#sh& Why 33 hatever. We'll deal ith 33
%s( Cha#+& We have the case la for it.
%r( Pa#sh& We'll deal ith it Monday. I don't need to res,ond.
%s( Ste))#s& /,eaking of Monday, yo"r honor, o!vio"sly, Plaintiffs have not com,leted their case
today. %ss"ming Mrs. Jackson finishes Monday, do Plaintiffs intend to rest Monday$ I ask !eca"se 33
%r( Pa#sh& <o, e're not resting !eca"se Mr. &rtega hasn't finished. &"r case doesn't rest. %nd e
still have the iss"e regarding *race 0aram!a that yo" and Ms. 'hang have talked a!o"t. B"t after
Mrs. Jackson, I think yo" sho"ld have itnesses ready to go on Monday.
%s( Ste))#s& -o"r honor, I think e sho"ld ,ro!a!ly talk a!o"t if they have m"lti,le additional
itnesses. What I as going to say is they filed designations of video for one of .efendants' e2,erts,
roma -o"ngD e filed o!#ections to that as c"m"lative.
%r( Pa#sh& We're not 33
Ju!+e& I sa that. I as s"r,rised to see that.
%s( Ste))#s& %nd e're still orking on, yo" kno, they ant to have arg"ment on Mr. 1aylor. %nd if
they ant to call 33 she #"st mentioned Ms. 0aram!a. My "nderstanding is that she's availa!le ne2t
eekD so if that's the case, I o"ld rather she !e finished ith their caseD and then if Mr. &rtega is
o"tstanding, that's one thing, !"t I don't ant there to !e a !"nch of itnesses o"tstanding. I'm #"st kind
of conf"sed as to here Plaintiffs are at.
%s( Cha#+& I think o"r "nderstanding at the de,osition as stated clearlyD and I think e had an
agreement that Ms. 0aram!a had to receive medical treatment for her condition, e all agreed she
o"ld have time to revie and correct anything in her transcri,t !efore e co"ld call her. We had an
agreement that e ,laced on the record, and that time ,eriod hasn't e2,ired yet.
%s( Ste))#s& Monday as the day she as s",,osed to revie. 1he im,ression I got from her
co"nsel as that she o"ld !e availa!le to testify ne2t eek. I'm not ,ositive, !"t e sho"ld confirm
that, !eca"se if she is 33 and there are some iss"es ith her testimony that e may !e addressing, !"t 33
Ju!+e& Is she going to !e designated or a,,earing live$
%s( Cha#+& We have to check ith her attorney, de,ending 33 #"st so the co"rt knos, she has a very
serio"s l","s condition 33
%r( Pa#sh& Is this ,rivileged, ,rivacy for her$
%s( Cha#+& I g"ess I sho"ldn't state it, !"t I'll ,"t it in a !rief "nder seal, !"t she has some severe
health iss"es, and I have to address them ith her attorney.
%s( Ste))#s& -o"r honor, I don't think there's any ay she co"ld a,,ear !y designation. 1he hole
,"r,ose of her de,osition, if yo"'ll recall, as she as not de,osed d"ring discovery. /he testified she
actively evaded discovery. /he then 33 Plaintiffs said they anted to add her to the list. %,,arently at
the time they said they had !een comm"nicating ith her for a co",le of months.
%s( Cha#+& <ot tr"e.
%s( Ste))#s& 1hey then arranged this de,osition. My 33 I as "nder the "nderstanding at the time it
as going to !e a de,osition for !oth sides to ,re,are for her trial testimony, so 33 and I act"ally did not
ask :"estions on 33 I did not cond"ct a cross e2amination at the de,osition, in ,art !eca"se Plaintiffs'
co"nsel ass"red me she'd !e a,,earing live. .esignation o"ld !e a,,ro,riate here, since the only
reason she as de,osed is !eca"se she came forard and said even tho"gh e're late, I ant to testify
live.
%r( Put#a3& 1hat's im,ortant to note, #"st to remem!er, yo"r honor, this is after e had started trial,
they came and said, >'an e add some!ody$>
Ju!+e& I remem!er.
%r( Put#a3& %nd yo" said, >-o" can add them as long as yo" get to de,ose them.> it as not that
they get to de,ose them and then ,"t her on not live.
Ju!+e& Why didn't yo" cross, then$
%s( Cha#+& /he did, for ho"rs.
%s( Ste))#s& I asked :"estions, yo"r honorD !"t it as an e2,loratory de,osition ith 33 my
"nderstanding 33 e can arg"e this 33
%r( Pa#sh& We don't need to arg"e this right no.
%s( Ste))#s& =ere's the iss"e, yo"r honor, in a n"tshell. I as trying to get hat the sense of her
testimony as in ,re,aration for live testimony. /he stated several times on the record she intended to
testify live. %t one ,oint, I as looking for something and Plaintiffs' co"nsel, d"ring a !reak 33 not Ms.
'hang, !"t her colleag"e 33 said, >hy are yo" even !othering asking her this$ -o" can cover it all on
cross e2amination hen she testifies.> !ring ", for o!vio"s reasons, !eca"se it as a de,osition, I as
trying to "nderstand hat her testimony as going to !e. It as not 33 to my "nderstanding 33
Ju!+e& It asn't trial ,reservation testimony.
%s( Ste))#s& )2actly, yo"r honor.
%r( Pa#sh& 1hat doesn't matter.
%r( Put#a3& <or o"ld it !e a,,ro,riate to have s"ch a thing !eca"se the only reason they ere
added after trial started 33 they said, >We ant to add her to o"r trial list,> and yo" said, >-o" only get
to do that if defense gets to de,ose her !efore yo" do so.> to then "se that as a !ackdoor method to no
have something to ,"t forard in this co"rt in terms of de,osition testimony on video is a!sol"tely
ina,,ro,riate.
%s( Cha#+& 'an e #"st state one thing$ I think this is ,remat"re !eca"se I haven't talked to her
attorney yet, and I don't kno ho everything ent. /he is not a citiCen of the state of 'alifornia. /he
lives o"tside the state, so there's ,ro!lem n"m!er 6. When that oman chooses 33
Ju!+e& +ike Mr. %nsch"tC.
%r( Pa#sh& )2actly, ho they ref"se to !ring.
%s( Cha#+& /o there are iss"es involved. %nd I think hat e sho"ld do is e sho"ld 33 I ill "se this
coming, hen can she come, does she agree to come. I "nderstand that, yo" kno, from her attorney
that she fo"nd the :"estioning gr"eling, and I think that hat e ill do is #"st find o"t. It's not orth
fighting a!o"t no or talking a!o"t no. We'll #"st cross that !ridge hen e comeD I ill call her
attorney as soon as I get o"t, and I'll try to find o"t hat the stat"s is.
%s( Ste))#s& %gain, o"r "nderstanding as that she o"ld !e testifying live, she stated that at her
de,osition, that as the only reason e had the de,osition as "nder that ass"m,tion. 1here's going to
!e significant iss"es if she's testifying anything other than live. B"t e don't need to orry a!o"t that at
this ,oint.
%r( Pa#sh& 1hen hy !ring it ",$
Ju!+e& 1hat's hy I as kind of s"r,rised hen I sa her designation that as filed.
%s( Ste))#s& <o. 1hat as Ms. -o"ng.
%s( Cha#+& I as going to say I'd !e im,ressed if someone designated her. Wo, cesar, good.
%s( Ste))#s& J"st no is the first I have heard that Ms. 0aram!a might not !e testifying live. 1hat
is com,letely different from my "nderstanding.
Ju!+e& I as s"r,rised to see -o"ng there !eca"se Plaintiffs have never mentioned -o"ng !efore.
%s( Ste))#s& We ere, too, yo"r honor. %nd e filed an o!#ection today !eca"se e !elieved that
o"ld !e c"m"lative. B"t e don't ant to !egin o"r case itho"t knoing that they've finished theirs.
Ju!+e& /ometimes yo" have to.
%r( Pa#sh& It ha,,ens like every trial.
Ju!+e& 1hey're not alays that nice and neat and tied ", in a !o.
%r( Pa#sh& %nd they already did start their case.
%s( Ste))#s& B"t e'd like to have some idea, yo"r honor, is there one itness o"tstanding$ 1o$
Fo"r$
Ju!+e& 1hat's fine.
%r( Pa#sh& 1hey already did start their case. 1he ay these things go, they had to call itnesses in
o"r case, if e recall that. /o hen they say, >We don't ant to start o"r case,> they already started it a
long time ago !y calling o"t of order to itnesses !eca"se of sched"ling.
Ju!+e& -es. 1he ,oint !eing 33
%r( Pa#sh& I "nderstand the ,oint.
Ju!+e& 33 they ant to kno ho many yo" have left.
%r( Pa#sh& 1hat's not a ,ro!lem.
%s( Ste))#s& We're not trying to !e infle2i!le if there's legitimate sched"ling iss"es.
%r( Pa#sh& 1he only iss"e that I kno right no, other than 33 Ms. 0aram!a, o"ld !e it. I don't
kno of any other.
Ju!+e& &rtega.
%r( Pa#sh& &rtega and 0aram!a.
%s( Ste))#s& /o not Ms. -o"ng$
%r( 5oyle& We're going to revie yo"r o!#ections and let yo" kno.
%r( Pa#sh& &ther than that, that I kno of at this ,oint, s"!#ect to ortega, nothing else.
Ju!+e& What is roma -o"ng$
%s( Ste))#s& % defense =0 e2,ert. We intend to call her live in o"r case at ,resent, and I've told
Plaintiffs' co"nsel that.

Ju!+e& /o yo" ant to call her in yo"r case$
%s( Ste))#s& 1hey ant to "se a small ,ortion of her video de,osition to !olster their on =0 e2,ert
o"t of conte2t. It's c"m"lative of testimony !y Mr. 1rell and Ms. /earight and a !it of detective
martineC. 1here's no ,"r,ose to that. We've o!#ected to it as c"m"lative, e've also ,rovided co"nter
designations sho"ld the co"rt 33
Ju!+e& 1hat so"nds c"m"lativeD and if they're going to call her in their case 33
%r( Pa#sh& 1hey didn't say there ere.
%r( 5oyle& We think their e2,ert said some things that are hel,f"l to "s. If they're
saying their e2,ert is c"m"lative to o"rs, hy can they call her$ B"t I ill look at their o!#ections.
%nd, also, they kee, saying, >We intend to call her at ,resent.> if they 33 I already told
Ms. /te!!ins if they are committing to calling her, e don't even need to fight this fight. B"t they, of
co"rse, are not committing to doing that.
%s( Ste))#s& -o"r honor, hat I told Mr. Boyle is at ,resent e 699 ,ercent intend to call her.
1here's alays the ,ossi!ility 33 I don't kno, it's the end of /e,tem!er and e're trying des,erately to
c"t 33 something may ha,,en. I don't think e're going to get to that ,oint, !eca"se o"r intention is to
finish in a"g"st, as e said the other dayD and I !elieve Ms. -o"ng ill !e called d"ring that ,eriod.
1hat is my re,resentation at this time. B"t her testimony, o!vio"sly, is not c"m"lative of Ms.
/earight's. It's contrary to Ms. /earight's. 1hey've gone thro"gh and cherry3,icked a co",le of
,oints o"t of conte2t to try to !olster Ms. /earight. It's not ,ro,er and it's c"m"lative.
Ju!+e& If that's the case, ,ro!a!ly not going to allo it in yo"r case. It's c"m"lative.
%r( Pa#sh& B"t yo" haven't heard anything.
Ju!+e& -o"'re right, I haven't looked at it.
%r( 5oyle& May!e a sol"tion is if they don't call her, e raise it later, ,lay this short video cli,.
Ju!+e& +ike re!"ttal$
%r( Pa#sh& I as reading the transcri,t 33 #"st I ant to clear something ", !eca"se I asn't here
hen there as a hole disc"ssion a!o"t .r. Bron's testimony. %nd I read the ro"gh transcri,t, and
Mr. P"tnam as :"estioned !y the co"rt, >%re yo" calling .r. M"rray$> and the ro"gh transcri,t said
>We don't intend to call .r. M"rray "nless e are re:"ested to.>
%r( 5oyle& >@nless yo" re:"est it, yo"r honor.>
%r( Pa#sh& %nd no the other transcri,t has !een changed to say something different. /o hat I
o"ld #"st like is some clarification on that iss"e. Beca"se I tho"ght yo" asked Mr. P"tnam, and I
asn't here, so I'm only reading the transcri,t 33 !eca"se this hole .r. M"rray 33 I as reading the
arg"ment, and I tho"ght it said, >Mr. P"tnam, are yo" calling .r. M"rray$>
Ju!+e& I did ask that.

%r( Pa#sh& &kay. %nd Mr. P"tnam gave a res,onse on the recordD and hat I o"ld like 33 !eca"se
the to transcri,ts are different, I o"ld like to kno hat is the res,onse.
%s( Ste))#s& -o"r honor, e didn't ask for any modification of the ro"gh, so I o"ld ass"me the
final transcri,t is hat the co"rt re,orter took don and hat as act"ally said.
Ju!+e& What did the final say$
%r( 5oyle& It says >e 33 I 33 I ,ersonally do not intend to call .r. M"rray "nless it's re:"ested, yo"r
honor.> hat does that mean$
%r( Pa#sh& B"t ho is going to re:"est it$
%r( Put#a3& I don't think I o"ld say that, !"t I don't kno 33
Ju!+e& )ven if yo" did, hat's the significance$
%r( Pa#sh& I don't kno. If e're going to rest 33
Ju!+e& -o" have a do"!t as to hether they are going to call him or not$
%r( Pa#sh& 1hat's all I ant to kno is the anser to the :"estion.
Ju!+e& I think the anser to the :"estion is ,ro!a!ly no. 1he anser has to !e no. I don't kno ho
they're going to get M"rray o"t of c"stody and in here.
%s( Caha#& It also attri!"tes it to me, and I did not anser that :"estion.
%r( Pa#sh& 1hat's hat I'm saying. 1here seemed to !e an error in the transcri,t, and that's hy I'm
asking, for hatever reason.
Ju!+e& I'd !e s"r,rised if 33
%s( Ste))#s& +et's look at the final transcri,t.
%r( Pa#sh& Well, hat is the anser$ -o" can #"st clarify it and then e don't have to orry a!o"t it.
%r( Put#a3& -o"r honor asked me if my ,resent intention as to call himD and as I indicated, my
,resent intention as not to call him.
%r( Pa#sh& 1hat asn't the :"estion, hether it as yo"r ,resent intention.
%r( Put#a3& /he said, >.o yo" intend to call.> I ass"me she meant at that ,oint.
%r( Pa#sh& )verything is like that ith them.
%r( Put#a3& Well, I s"s,ect she asn't saying a month from no, might I intend. /he had to indicate
hat did I intend to do at the time. In my case, I do not intend to call 33
Ju!+e& Well, let's o"t it this ay. If yo" intend to call .r. M"rray, there's a hole heck of a lot of other
things that need to !e done !efore that ill ha,,enD a very lengthy hearing, his attorney has to !e
,resent, there has to !e all kinds of things that have to !e done !efore he co"ld testify. <one of those
things have !een done.
%r( Put#a3& I agree.
Ju!+e& %nd so the likelihood of that ha,,ening, very, very lo.
%r( Put#a3& Which is hy I said at the time, yo"r honor 33 as yo" recall, the conte2t in hich it arose
as !eca"se, as yo" kno, for 6B eeks e have !een trying to get the ,ortion of .r. 'onrad M"rray's
intervie ith the +%P. in 33 It as in that conte2t that it arose, !eca"se yo" indicated that that
,ortion as not going to come in !eca"se it as hearsay. If other ,ortions did, that o"ld de,end on
hat else occ"rredD !"t that ,ortion, there as no reason to !ring it in. In that conte2t, yo" said o"ld I
!e !ringing himD and as I said at the time, e ere also talking a!o"t hen e ere going to end, I said
e're going to end this at the end of a"g"st, hich is hy I said, as yo"'re noting at the moment, there's
a hole ,rocess. My ,resent intention is not to call him, yo"r honor.
%r( Pa#sh& I "nderstand it !etter, !"t he didn't tell "s he as resting in a"g"st "ntil the ne2t day. /o 33
%r( Put#a3& <o.
%r( Pa#sh& B"t hatever. Mr. P"tnam said, no it's clear, I don't have to rely on the to transcri,ts,
I'll take his ord for hat he said, and then thank yo" for clarifying that.
%r( Put#a3& %nd hen he's not availa!le, he might ask his co3co"nsel ho ere here and heard hat
he said, yo"r honor.
%r( 5oyle& I heard it.
%r( Pa#sh& Both transcri,ts are different, Mr. P"tnam. 1hat's hy I asked. I read the transcri,ts, !oth
of themD and that's hy 33 there is a difference, and that's hy I asked. %nd I did ask them first, and
they looked at the transcri,t 33
Ju!+e& It's not a !ig deal. It's 33 it's so "nlikely to ha,,en that I think yo"'re overreacting, frankly.
1here's #"st so m"ch that needs to !e done in advance of s"ch a hearing that 33
%r( Pa#sh& Fair eno"gh. 1hank yo".
%s( Ste))#s& /o if I "nderstand 33
Ju!+e& It's not going to ha,,en, I can tell yo" that. I #"st kno hat has to !e done !efore something
like that co"ld occ"r. 1hat's e2tremely "nlikely.
%s( Ste))#s& If I "nderstand correctly ith regard to Ms. -o"ng, Plaintiffs are not going to call her
no. If e do not call her in o"r case, they may raise the iss"e again, e'll still o!#ect to it as
c"m"lative and raise it at that time.
%r( 5oyle& 0eserving all rights, yes.
%s( Caha#& Based on the re,resentation that e're going to finish ith Ms. Jackson, and Mr. &rtega
and Ms. 0aram!a ill !e dealt ith se,arately, e've !een ,re,aring to arrange itnesses for ne2t
eek. In the conte2t of that, e ,re,ared some de,osition designations. %s yo"r honor may remem!er,
hen e started the case, Plaintiffs' co"nsel designated B9 de,ositions, and e had 5; ho"rs to do
co"nters, designations and o!#ections to those. 1hey all got lodged ith the co"rt, and then they ere
"nha,,y ith the designation co"nted as 33 e had a difference of o,inion. %nd on may 6st, yo"r honor
said, >Well, hatever yo" ant to do ith the designations, Plaintiffs, in essence, I'll give yo" a eek
to revise hatever yo" ant, and then e'll do that.> so !"t !efore that ha,,ened, e had essentially a
five3day ,rocess that as disc"ssed and agreed to at the final stat"s conference here de,ositions ere
,rovided, there as 5; ho"rs to do co"nter designations and o!#ections, another B5 ho"rs to do
res,onses or o!#ections to the co"nter designations, and then they o"ld !e filed and r"led on. &n
Monday evening, in ,re,aration for ne2t eek, e sent Plaintiffs' co"nsel fo"r de,osition designations.
&ne as one that e had sent them !ack in may, !ack hen they said, yo" kno, >We don't ant to
deal ith these d"ring o"r case, !"t e'll get hatever yo" need done :"ickly hen it's time for
.efendants to start their case.> one of them didn't need to !e modified !eca"se it had !een sent over
,revio"sly. 1he other three, they had for three days. We got one !ack at the end of the day yesterday.
%fter a lengthy e2change of emails ith Plaintiffs' co"nsel, they gave "s a second one aro"nd 66?89 last
nightD and e haven't gotten the the to that e have have gotten !ack, hich are .r. Farshchian and
.r. /a"nders, e've lodged the transcri,ts and given the com!ined charts to yo"r honor. I think one
as #"st filed at l"nch. We o"ld ask if yo" co"ld ,lease try to look those over :"ickly, e'd a,,reciate
that, !eca"se e'd like to ,lay those videos ne2t eek.
Ju!+e& I'll !e looking over them as soon as I can.
%s( Caha#& We don't kno hen e'll !e getting the third one !ack, .r. (aCakhi.
%r( 5oyle& 1hey gave "s fo"r at 69?89 on Monday, e've given them three of the fo"r !ack, and I got
the fo"rth one in my email hile Mrs. Jackson as on the stand, I haven't looked at it yet. .o I need to
address the ,ream!le that she gave$ 1hat's really not acc"rate, a!o"t the 5; ho"rs and all that st"ff. B"t
if I don't need to address it, I on't.
%s( Caha#& What e o"ld like, yo"r honor, is some clarity going forard !eca"se e didn't e2,ect
that three short designation, giving them three days, o"ld !e a ,ro!lemD and e #"st need to make s"re
that e're not going to !e ,"tting yo"r honor "nder "nd"e ,ress"re or interr",ting the flo of o"r case,
and so may!e e need to reesta!lish an a,,ro,riate time frame.
Ju!+e& Well,
ho many more designations, de,o 33
%s( Caha#& We act"ally have :"ite a lot !eca"se e have so many ,hysicians and ,eo,le ho are o"t
of state. 1hey are largely short. Most of them are !eteen half an ho"r to an ho"r. %nd e're ha,,y to
send them on a rolling !asis. 1here's one more that e o"ld like to !e a!le to ,lay ne2t eek that e
haven't sent over yet, e can do that today. B"t I think e #"st need some clarity on the ,rocess to
make s"re that the co"rt has eno"gh time, that e have eno"gh time, and that Plaintiffs have eno"gh
time so that as e're sending them on a rolling !asis, e have some kind of ass"rance that e'll !e
getting them !ack on a reg"lar !asis.
Ju!+e& Mr. Boyle 33
%r( 5oyle& Whatever the r"le as, e're fine ith.
%s( Caha#& 5; ho"rs.
%r( Pa#sh& It as five days, according to Ms. /trong.
%s( Ste))#s& %t one ,oint, e had a to3,art system. %fter there as some concern ith the initial
timeta!le, hich as 5; ho"rs, it as then set ", that it o"ld !e 5; ho"rs for ,riority and five days for
non3,riority. I don't kno hether that's orka!le ith 33 if it is, e can 33
%r( 5oyle& 1hey're trying to shorten the time on "s, hich is fine. We said e'll ork hard ith them
to hel,. 1hey gave "s fo"r at 69?89 on Monday night, e got three of the fo"r !ack, e're getting the
fo"rth !ack, all ithin the five3day ,eriod that Ms. /trong demanded. /o this is a non3iss"e that 33 I
think hat they're asking yo" is they ant a shorter time frame, is hat they're asking, !"t they're
afraid to ask it.
%s( Caha#& I o"ld ask that e have the same arrangement that Plaintiffs had and they made "s do 33
e did 6; sets of co"nter and o!#ections on 5; ho"rs notice in a one3eek ,eriod, and that re:"ired a
lot of o"r time to 33
Ju!+e& %re yo" asking they do the same$ -o" ant to do 6; 33
%s( Caha#& <o, yo"r honor. We ant to !e reasona!le. We have feer than 6; total, altho"gh e ill
!e ,laying the ones that e'll !e sending to Plaintiffs, "nlike 33 I think they ,layed fo"r o"t of of the B9
that 33
%r( Pa#sh& <o. 1hat's rong.
%r( 5oyle& We filed fo"r, e ,layed fo"r. 1his thing, the reason e had to lodge so many on them 33 I
anted to do it on a ,riority !asis. 1hey ere insisting that they all !e t"rned over for hatever reason,
may!e they anted to kno hat or intentions ere ith the case.
%r( Put#a3& <ot tr"e.
%s( Caha#& 1hat's not tr"e, !"t I think hat e o"ld ask is that Plaintiffs !e held to hat e ere
held, to hich is 5; ho"rs.
%r( Pa#sh& It asn't.
%s( Caha#& 1his is the second sched"le that as agreed to, 5; ho"rs for ,riority de,ositions, hich
the ones that e sent over this eek ere, altho"gh e gave them AB ho"rs, and five days for anything
that's not a ,riority, and e ill send them on a rolling !asis 33
Ju!+e& Is that acce,ta!le or not$ If not, hat's yo"r alternative$
%r( Pa#sh& I o"ld say three days is fine 33
Ju!+e& -o"'re not doing it. Isn't Mr. Boyle doing it$
%r( 5oyle& Most it.
Ju!+e& Mr. Boyle has !een doing all this ork on the de,os.
%r( Pa#sh& 1hey can't send it at 69?59 at night, yo"r honor. It sho"ld !e !"siness ho"rs.
Ju!+e& I'm s"re they get it as soon as they can.
%r( Pa#sh& %ll of a s"dden fo"r of them come Monday night at 69?59$
%s( Caha#& My email as at ;?B6 ,.M., for the record.
Ju!+e& It's a !"sy trial day.
%s( Caha#& We're all orking aro"nd the clock, e're doing things as soon as e can, and I anted to
get them to them Monday night as o,,osed to t"esday morning to give them more time to get it !ack to
"s.
%r( 5oyle& It as kind of a !"sy eek for "s, yo"r honor.
Ju!+e& I "nderstand. -o"'re !"sy trial layers, I get it. What I'm trying to get is hether 33 Mr. Boyle,
hat can yo" ork ith$ 'an yo" ork ith that sched"le$
%r( 5oyle& I can ork 33 three days o"ld !e ,refera!leD !"t if they are dying to fill a slot ith a
itness, #"st like they've done, they tell "s, >look, e really ant to ,lay this one on 2 day,> e ill ,"t
it ", and do it in to days.
%s( Caha#& AB ho"rs for all the co"nters and o!#ections is fine for "s, yo"r honor.
Ju!+e& If there's an emergency, he said 33
%r( Pa#sh& %ll right. Forget it. <o emergencies, then.
Ju!+e& Mr. Panish, like I said, Mr. Boyle is doing the ork.
%s( Caha#& If there's an emergency, yo"r honor, e'll raise it ith yo" if there's a ,ro!lem.
Ju!+e& +et him make the sched"le for his 33
%r( Pa#sh& =o do yo" kno I'm not doing that$

Ju!+e& Beca"se he's the one that's doing all the de,os.
%r( Pa#sh& &kay, yo"r honor.
%r( 5oyle& =o a!o"t three and five$ If they have a non3,riority, they're ,ro!a!ly not going to ,lay it
anyay.
%s( Caha#& We're only sending ones e intend to ,lay.
%r( Pa#sh& %s of today. Present intention.
Ju!+e& /o, Mr. Boyle, I ant yo" to recite hat yo"r agreement is.
%r( 5oyle& 1hree days ,riority, five days non3,riority. %nd if they have an "rgent thing here they
ant it and it's a short one sooner than three days, e'll ork ith them and try to get it done.
%s( Caha#& 1hat's fine, yo"r honor.
Ju!+e& &kay. 1hank yo".
%r( Pa#sh& <o, on Monday, so e're going to finish Mrs. Jackson. I have no 33 I don't kno a!o"t
Ms. 0aram!a. /o then they o"ld !e calling itnesses or video$ What is the ,lan$
%s( Caha#& We on't have video ready in time no.
%r( Pa#sh& /o yo"'ve got itnesses on Monday$
%s( Ste))#s& +et's try to fig"re o"t hat's ha,,ening ith Ms. 0aram!a !eca"se, o!vio"sly, the
ideal o"ld !e that she go immediately after Mrs. Jackson. &therise 33
%r( Put#a3& I'll let yo" kno tomorro morning, 5;3ho"r r"le. I have to find someone for Monday if
yo"'re telling me that yo"'re act"ally resting.
%r( Pa#sh& I've !een telling yo" that. 1hat's okay. /o they don't kno ho their itness ill !e, and
they'll tell "s tomorro at 7?89.
%r( Put#a3& +ike e have !een.
%r( Pa#sh& Well, yo" haven't told "s any !eca"se e've !een the ones calling 33
%s( Ste))#s& .on't orry. We'll give yo" every !it of notice that e received.
Ju!+e& /o hatever itness yo" call ill !e a lengthy itness or short itness or do yo" have any 33
%r( Put#a3& <o, I don't think any of them ill !e lengthy, yo"r honor.
Ju!+e& /o yo" may have to call m"lti,le itnesses$

%r( Put#a3& -es. 1he reason e're asking a!o"t the sched"le, making s"re the three and five and
everything, is e're trying to make s"re e can do this as efficiently as ,ossi!le. %nd e're ho,ing to
call many each day !eca"se e ant to get thro"gh this. 1hat's the ,resent intent, hich is also hy on
the front end e're trying to set it ", to "nderstand hat the ,arameters are so e can ,ro,erly
sched"le 33 a n"m!er have !een in a holding ,attern !eca"se e had told almost all of them to free ",
the time ,eriod a!o"t a month ago. /o it's a little later, so e're having a little more tro"!le than e
e2,ected in trying to get ,eo,le into certain s,ots.
%r( Pa#sh& If they ask "s, e're certainly illing to ork ith them on sched"ling a itness. =aving
had the ,ress"re on "s, e "nderstand it's diffic"lt. We're more than illing to ork ith them on any
sched"ling iss"es. If they need a video done in B5 ho"rs !eca"se they don't have someone the ne2t day,
e're illing to ork ith them !eca"se it's also o"r intention to get this done as :"ickly as ,ossi!le.
We're more than ha,,y to ork ith them.
%s( Ste))#s& &n the s"!#ect of Plaintiffs' case, yo"r honor, the one o"tstanding iss"e, then, o"ld !e
Mr. 1aylor's de,osition. &!vio"sly, e think yo"r tentative is correctD and I don't kno if Plaintiff still
anted to "se that de,osition or if they anted to arg"e that. B"t e if they anted to do that, e
sho"ld do it !efore their case closes.
Ju!+e& +et's talk a!o"t it no.
%r( Pa#sh& 'an e get o"r st"ff together$
Ju!+e& -es.
%r( Put#a3& In terms of o"r sched"le, hen ill e kno if yo"'re calling Ms. 0aram!a on
Monday$
%s( Cha#+& %s soon as I can find o"t. I ill email #essica. Is that okay$
%s( Ste))#s& -es. &!vio"sly, e need some time to ,re,, so 33
%r( Pa#sh& We're going to tell yo" ithin the 5;3ho"r r"le, right$ By 7?89 tomorro. Is that the 5;3
ho"rs$
%r( Put#a3& -esD and then I ill let yo" kno as soon as I can thereafter if yo" ill then !e resting
yo"r case e2ce,t for o"tstanding itnesses.
Ju!+e& 1his hole thing a!o"t yo" have to rest 33
%r( Pa#sh& 1hat's not ho it orks.
Ju!+e& 1hey don't have to formally rest for yo" to start calling yo"r itnesses.
%r( Put#a3& I agree, yo"r honor.
Ju!+e& /o if I tell yo" yo" ,"t on a itness, yo" ,"t on a itness.

%r( Put#a3& %nd I ill do that, yo"r honor.
Ju!+e& 1hey don't have to formally rest. /ame thing 33 ait a min"te. Why are yo" to talking hen
I'm trying to address 33
%s( Cha#+& I'm sorry.
%r( Put#a3& -es, yo"r honor.
Ju!+e& In order to move the trial along, e take the itnesses as they come. &kay$ %nd they'll rest
hen a,,ro,riate. It's not going to affect anything. It's #"st a formality. 1here are motions for nons"it,
that 33
%r( Put#a3& 1here are motions that come in.
%r( Pa#sh& B"t they'll still do the motions anyay. It doesn't matter.
Ju!+e& /o !e ,re,ared, is all I'm saying, and don't e2,ect them to rest cleanly. 1here's going ,ossi!le a
dangling itness o"t there. It doesn't really make any difference.
%r( Put#a3& 1hat's hat e're trying to ask, yo"r honor. We're trying to ask 33 e e2,ect something
to !e dangling o"t there, and I'd like to kno hat that is.
%r( Pa#sh& I o"ld say this. I o"ld !e ready to call itnesses as soon as yo" think yo"'re going to
finish ith Ms. Jackson, #"st in case.
%s( Ste))#s& %s Ms. 'hang as #"st ,ointing o"t 33 I did say that I o"ld !e fle2i!le and ork ith
Ms. 0aram!a ith any sched"ling iss"esD !"t at the same time, e o"ld like her to go as soon as
,ossi!le !eca"se since she's ,art of Plaintiffs' case.
%s( Cha#+& I a,ologiCe to the co"rt. I didn't mean to !e talking hen yo" ere talking. I as trying to
ork something o"t ith Jessica 33 ell, Ms. /te!!ins Bina, and I as reminding her of a conversation
e had here e told the co"nsel !eca"se e kne she had treatment, she co"ld have more time if she
needed to revie the transcri,t. It's three vol"mes, !eca"se it ent on three different days. /o !asically
she 33 she has to revie it, and I ill find o"t, and I ill comm"nicate directly ith her, and e ill
ork together as e told her e o"ld.
%s( Ste))#s& %t the close of the last day, yo"r honor 33 these ere ,artial days, I got a!o"t fo"r and a
half ho"rs. B"t at the close of the day, Ms. 0aram!a and her co"nsel re,resented that they o"ld
revie the transcri,t on Monday and sign off on it !y Monday. I don't have any reason to !elieve that's
not the case. %t this ,oint, ,erha,s Ms. 'hang knos something I don't.
%s( Cha#+& I kno nothing. I've !een here.
%s( Ste))#s& I e2,ect the de,osition transcri,t ill !e finaliCed on Monday so she can go 33
%s( Cha#+& I'm #"st reminding every!ody that e had indicated if she needs more time, e're ha,,y
to ork ith her. /o I have no idea, she has no idea. I ill find o"t and comm"nicate ith the other
side.
%r( Pa#sh& Who is her layer$
%s( Cha#+& .an ."n!ar.
%r( Pa#sh& Why don't yo" #"st call him$
%s( Cha#+& I ill. 'an I !e e2c"sed, yo"r honor, to ork on that$
Ju!+e& -es. .id yo" get all the items yo" needed for the ro!ert 1aylor motion$
%r( Pa#sh& -es, I think so.
%r( 5oyle& -es.
Ju!+e& 1his is a hile ago.
%r( 5oyle& -o"r honor, e read yo"r tentative and "nderstand the co"rt's ,osition. &"r ,osition is
sim,ly that Mr. 1aylor testified to an inconsistent statement of Mr. 1rell regarding %)* em,loying .r.
M"rray. Mr. 1aylor as asked :"estions, "-o this was -hawn Trell telling you that ).& !as
employing ,r. /onrad Murray on the instruction of 00* Answer, *of Michael.* Question, *of Mr.
ackson"* Answer, */orrect.* /o that as o"r intention for "sing Mr. .ay elementary, along ith
some other things regarding the ins"rance. It as a different case, o!vio"sly. It as a case that %)*
=ad !een involved in. We !elieve their interests ere still re,resented !eca"se of their 'o3.efendant
as still in the case at the time of this de,osition, re,resented !y co"nsel, ho also re,resented %)* In
that litigation. /o e !elieve they, in essence, had re,resentation at that de,osition hich, "nder the
r"les, o"ld allo "s to "se that in o"r case.
%r( Pa#sh& -o"r honor, #"st 33 in 667B, it looks at the interest of the ,arty as to hether or not a
de,osition can !e "sed !eca"se
%)* as a ,arty in the case. 1hey ere also re,resented at the time !y the same layer that contin"ed
in the case.
%r( Put#a3& 1hat's not tr"e.
%r( Pa#sh& )2c"se me. Mr. P"tnam as act"ally involved in that case as the layer for %)* after, I
!elieve, he came in for another la firm or to. (insella WeitCman as in that la firm re,resenting
%)* for a ,eriod of time, then Mr. P"tnam, and it's the same interests. %nd Mr. 1rell denies all the
these statementsD and this gentleman, ho has no interest in this case, testifies "nder oath hat Mr.
1rell told him. It's clearly relia!le.
Ju!+e& Well, I think I "nderstand hy yo" ant to "se itD !"t the :"estion is can yo".
%r( Pa#sh& @nder 667B, I !elieve they had the same interest. 0emem!er, they're !oth 33 "nder Mr.
1rell 33 and Mr. *ongaare, I !elieve, testified a!o"t the ins"rance and ho Michael 33 remem!er they
ent thro"gh the contract, and Michael had an o!ligation to get the ins"rance, and they ere !oth
together, had the same interest to have the ins"rance$ /o no there's this claim over the ins"rance, they
have no differing interests, they !oth had the idea to get the claim, to get the money from the ins"rance
com,any, and "nder 33
Ju!+e& I'm not s"re that's the interest that they're talking a!o"t. 1hey're talking a!o"t the interest in the
cross3e2amining at the de,osition. 1hat's the interest at iss"e, not that their interests are someho
aligned ,re3litigation.
%r( Pa#sh& B"t .r. M"rray, if yo" remem!er the testimony that Mr. 1rell 33 of Mr. 33 ell, there ere
emails regarding if .r. M"rray as em,loyed !y %)*, that they co"ld get that "nder the ins"rance
,olicy.
Ju!+e& I "nderstand. 1hat's not the interest 33 I think this is addressed to 33
%r( Pa#sh& <o. 1hat's 33 follo ith me. With .r. M"rray 33 and yo" remem!er the :"estions in Mr.
1rell's email to the !roker if 33 there had to !e ,ayments, and they asked can e get the ,ayments
covered "nder the ,olicy. /o if the claim is made against the ,olicy, and the ,ayments are covered
"nder the ,olicy, it o"ld !e the same interest of ho's in the case as %)* to get the money from the
,olicy. %nd if .r. M"rray as covered as his em,loyment "nder the ,olicy, their interests o"ld !e the
same, and 33 that s,ecific iss"e that the :"estions ere asked a!o"t.
%r( 5oyle& I o"ld also add really !riefly, yo"r honor, for the record, another arg"ment is Mr. 1aylor,
at the time this conversation o"ld have ha,,ened, as an agent of %)* =e as their ins"rance agent,
their ins"rance !rokerD so, also, e think it's a flat3o"t admission !y an agent of the .efendant in this
case.
%s( Ste))#s& Briefly, yo"r honor, Mr. 1aylor is not an agent of %)* +ive. =e's their ins"rance
!roker. 1here are certain limited areas in hich an ins"rance !roker can act as an agent, !"t not in
testifying in a de,osition that a.).*. +ive kne nothing a!o"t. 'ertainly he as not a"thoriCed to
a,,ear or testify, so I think e can dis,ense ith that one ,retty easily. 1his is evidence code section
6B7B. I think Mr. Panish said 667B.
(reading)? )vidence of former testimony is not made inadmissi!le !y the hearsay r"le if the declarant is
"navaila!le, offered in a civil action, and the iss"e is s"ch that the ,arty to the action or ,roceeding in
hich the former testimony as given had the right and o,,ort"nity to cross the declarant ith an
interest and motive similar to that hich the ,arty against hom the testimony is offered has at the
hearing. 1hat's this hearing. /o the only ay this comes in, yo"r honor, is if someone at Mr. 1aylor's
de,osition had an incentive and motive to cross3e2amine Mr. 1aylor that is similar to hat %)* +ive
has at this hearing. %nd that's sim,ly not the case, yo"r honor. %s Plaintiffs note, %)* +ive as
initially s"ed in that ins"rance action. 1hey ere a .efendant. We served as their co"nsel in that matter
and then ere dismissed !eca"se !asically the estate had the claim 33 or the Michael Jackson com,any
had the claim. /o %)* +ive has !een o"t of that case for a very, very long time, as not ,resent or ,art
of this de,osition. =ad they !een, it o"ld have !een relatively easy to cross3e2amine Mr. 1aylor, sho
him a doc"ment that shoed that any conversation he remem!ers as act"ally ith Mr. Woolley and
as to months later in may, not march. We o"ld have had those materials at the ready and ,ro!a!ly
o"ld have corrected it. <o!ody as there ith that motive and incentive, no one had that knoledge,
and that's e2actly hy former testimony is not admitted in violation of the hearsay r"le. I'm ha,,y to go
on on this, yo"r honorD !"t I think yo"r order is correct, I think there is no similar motive. I mean, #"st
!eca"se there as a 33 a motive to get ins"rance 33
Ju!+e& Ins"rance together.
%s( Ste))#s& 33 or even a motive to have the ,olicy ,aid. 1hat's not a motive to cross3e2amine a
itness a!o"t a conversation they had ith %)* +ive and the details of hen it took ,lace in the ay
that e o"ld have in this ,roceeding. %nd I #"st think that's ,retty self3evident, yo"r honor.
Ju!+e& &kay. I'm denying the motion.
%r( 5oyle& 1hank yo", yo"r honor.
%s( Ste))#s& 1hank yo", yo"r honor.
Ju!+e& &kay. .o e have anything else$
%s( Ste))#s& I don't think so, yo"r honor.
Ju!+e& I think that's it.
%r( Put#a3& .id yo" say 7?89 on Monday$
1he $ler.& Monday$ -es.
Ju!+e& I kno I'll end ", thinking a!o"t something e sho"ld talk a!o"t hen I'm driving home 33 or
my sister is driving home.
%r( Pa#sh& 1hat's nice.
Ju!+e& %nything else$
%s( Ste))#s& We're done ith -o"ng, done ith 1aylor, e're checking on 0aram!a, and Mrs.
Jackson is going Monday.
%r( Pa#sh& I'm s"re e'll think of something hen e're leaving.
%s( Ste))#s& -o" don't have any other itnesses, right$ 1here as a co",le yo" gave notice of this
eek, Mr. Panish and Mr. Barrett.
Ju!+e& %re yo" filing an o,,osition ,a,er to the motion to :"ash$
%r( Put#a3& -es.
Ju!+e& -o" are. &kay. It #"st hasn't !een filed$
%r( Put#a3& 1hey talked to me. -o"'re good. -o" kne there as something.
Ju!+e& I'm #"st trying to remem!er, kee, it straight in my head. 1he other thing is that there ere
some minor edits to yo"r sti, and order.
%s( Ste))#s& We're going to ,"t them in, send them to Mr. Boyle. I've already shon him, I don't
think there's any iss"es.
%r( 5oyle& I haven't seen it. /end me the scanned one, too.
%s( Ste))#s& I'll send yo" !oth.
Ju!+e& %lso yo"r designations and co"nter designations. &kay. I think 33 have a good eekend.
0Court a!2our#e! to %o#!ay6 July 226 20134

Jackson V AEG Live, July 19th 2013, Transcripts of Katherine Jackson

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Jackson V AEG Live, July 19th 2013, Transcripts of Katherine Jackson

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JACKSON V AEG LIVE July 19

%s( *o)#so#& *ood morning. +a"ra 0o!inson for the .efendants.

4. .id yo" get a lot of slee, last night$

4. What as the name of the ton$

4. Is Prince a family name in yo"r family, Mrs. Jackson$

4. What as yo"r father's name$

%r( Put#a3& <o.

4. 1hat yo"r grad"ation ,ict"re$

so he as in a cri! in o"r room.

4. 1he mayor of *ary, Indiana, as in the ,ict"re$ Base!all ,ict"re$

%. <o, she asn't a midget.

from the other holidays.

%. -es. 1hose are my !oys.

4. %nd ho did yo" get the money to !"y the instr"ments$

4. %nd do yo" kno ho old he as there, Michael$

%. -es. It as at the %cademy %ards.

4. Was Michael having a lot of s"ccess$

%. -es. It's still there.

%. 1hat as me, and that's ith the :"een.

%r( Pa#sh& 1hank yo", yo"r honor.

4. .id yo" ever go on that$

4. %nd e sa a lot of animals that Michael had there$

4. What as that for$

%s( Cha#+& Page B.

4. Who ere yo" calling$

4. <o, ho did yo" hear a!o"t Michael's death$

and said, >&randma, where are we going">

4. 'an yo" tell he misses his father$

Ju!+e& &kay. 'ross3e2amination.

are yo" nervo"s$

%. Mr. Jackson as sick, and he co"ldn't rehearse.

4. %nything else, ma'am$

%. -es, it o"ld !e hard to listen to.

%r( Pa#sh& B"t if she disc"ssed it ith her attorneys 33

co"ld something else !e a factor$

%r( Put#a3& 'riminal trial.

%. 'an yo" re,eat yo"r 33

%r( Pa#sh& 1hat's okay.

Plaintiffs' co"nsel that.

Ju!+e& I did ask that.

%r( Pa#sh& =o do yo" kno I'm not doing that$

Ju!+e& /o yo" may have to call m"lti,le itnesses$

Ju!+e& /o if I tell yo" yo" ,"t on a itness, yo" ,"t on a itness.

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%s( o)#so#& ood morning. +a"ra 0o!inson for the .efendants.