Katherine Jackson V AEG Live AUGUST 28

TH
2013V
Dr. Petros Levounis, (Addiction Specialist)
Cross-examination (resumed) by Mr. Koskoff
Q. Dr. Levounis, since we broke off yesterday, have you had occasion to meet with counsel?
A. Yes.
Q. And when was that, sir?
A. This morning.

Q. For how long?

A. About 45 minutes.
Q. And have you -- did you read any additional materials last night?
A. I reviewed some of my own notes.
Q. Yesterday in court, I think you said you didn't have any notes.
A. These very notes right here that I have in front of me.
Q. When you say your notes, do you have any notes that you took yourself, sir?
A. It's the electronic ones of the slides that were shown yesterday.
Q. So it's just -- it's not really your notes, but you looked over that file again?
A. Yes.
Q. But you have no handwritten notes whatsoever?
A. No, I don't.
Q. And when you reviewed the depositions in the case, you reviewed Dr. Adams' deposition,
Dr. Farshchian, Dr. Finkelstein, doctor -- Mr. Fournier, Dr. Gordon -- all of those doctors. You
didn't take any notes of those reviews either?
A. No, I did not.

Q. You did those reviews -- by the way, this is deposition testimony. Your trial testimony
you looked at Dr. Schnoll, Karen Faye, Kenny Ortega, Travis Payne, Katherine Jackson --
Judge. Maybe we should just mark that and put it into evidence. We keep referring to it. Mr.
Panish wanted to do it at the beginning.
Mr. Panish. I'd been trying to do that.
Mr. Koskoff. He always gets his way.
Ms. Cahan. There is an issue in terms of the jury seeing it --
Mr. Panish. Just page 2 of the other one.
Ms. Cahan. That's fine.
Judge. It's a long laundry list of things he looked at and everybody keeps referring to it. Give
it a new number.
Mr. Koskoff. 1115 we're talking about, starting on page 2.
Mr. Panish. No, no, no.
Ms. Cahan. That was marked for identification yesterday as 11 -- okay. 1115.
Judge. Well, now it's in evidence.

(Plaintiffs exhibit 1115, was 2 received into evidence.)

Mr. Panish. It's a three-page document.

Judge. It will be no mystery.
Mr. Koskoff. And but those deposition names that I just read -- sorry, transcript names that I
just read are the ones you relied upon?
A. Yes.
Q. You read others as well, didn't you?
A. Yes.
Q. So who else did you read?
A. There were several in the beginning parts before the deposition. I remember Dr. Baxley,
for example.
Q. Who was he?
A. I believe he was a dentist, and it wasn't something that I find that was particularly
relevant.
Q. But you also said yesterday I think you said Dr. Czeisler.
A. Yes.
Q. And who was he?

A. Sleep expert.
Q. That was a lengthy transcript, wasn't it?
A. Yes.
Q. Did you -- did you read any other lengthy transcripts?
A. Ms. Debbie Rowes, I believe, was quite lengthy.
Q. And did you read -- I'm sorry?
A. I did read that.
Q. Did you read Dr. Emery brown's testimony?
A. I can't remember that.
Q. Now this morning, counsel and I worked something out, which was nice, and we gave a
copy of it. Those were Dr. Murray's medical records?
A. Okay.
Q. That's one of the things you relied upon for your opinion here?
A. Yes. Should I have a copy in front of me?
Q. Yes. I'm going to give you a copy and one for the court. If I may approach, your honor?

Judge. Yes.
Mr. Koskoff. If you'd just hand this up to the court, sir. It's exhibit number 11963. And you
were aware that of course Dr. Murray was one of the treating physicians in this case, correct?
A. Yes.
Q. And I'd like to, if we could, just put it up on the screen to start with, with 11963.0004.
Ms. Cahan. Can you also identify those by the LACC number when you go because I don't
have the exhibit pages.
Mr. Koskoff. That's the LACC number 0895.
Q. Now we're going to go through the record. We're not going to look at every one of them
because some are things like insurance forms and letters that are not at all pertinent. But what I
want to do with you, sir, if you could assist us in this, is go through these records so that we can
get an idea of actually how many times Dr. Murray actually ever treated Michael Jackson before
the spring of 2009.
Ms. Cahan. Objection, outside the scope. He didn't offer any opinions about Dr. Murray's
treatments of Mr. Jackson.
Judge. Sustained.

Mr. Panish. He reviewed and relied upon these records. He can be cross-examined on
anything he reviewed and relied on.

Judge. Did he?

Mr. Panish. He did. He just said that. And in the exhibit that was up there that he has as
things he reviewed and relied on is Mr. Murray's records.
Judge. I heard him say Czeisler and Rowe. Did you rely on Murrays records, too?

A. Yes, I did.
Ms. Cahan. Issue is, I guess, they are going to have him go through every time Dr. Murray
treated Mr. Jackson and that's -- he said he's not an internal medicine doctor.
Mr. Panish. Is there a legal grounds for the objection?

Ms. Cahan. Outside the scope of direct and his expertise in the case and the opinions he's
offering in the case.
Mr. Panish. The response would be he reviewed and considered and relied upon these under
evidence code 721, an expert can be cross-examined on anything reviewed, considered, and
relied on.
Judge. Overruled. You may.

Mr. Koskoff. Let's first look at the LACC 0895, and that is a medication log, correct, sir?

A. Yes.
Q. And you are familiar with the medications that are listed here?
A. Most of them, yes.
Q. Is there any that you are not familiar with?
A. Singular I'm not familiar with. Benefen is a cream I'm not particularly familiar with.
Lortab I don't use. I know what a Z-Pak is. Ornicef is a cream -- I'm sorry. It's for fungal
infections. I'm familiar with most of them.
Q. Is there anything on the list any kind of a narcotic?
A. Narcotic?
Q. Yeah.
A. Narcotic meaning opioid? No.
Q. So is this -- this is -- does this have a date on it? It doesn't really, does it?
A. It does say February 19th, '07 for the 20 percent --
Q. Start date. Then it says the end 11/19/08?
A. Right.

Q. So the medication list -- I'll move on. Next form I'd like you to look at -- by the way,
counsel was very nice in providing us with a copy that also has a translation in case you have a
problem reading doctors' notes. We, of course, know that doctors have great handwriting but just
in case you have a problem.
A. Guilty as charged.
Q. Before we get to the next handwritten note, I would like to turn to LACC 0906. Does
that appear to be an article from some sort of a medical treatise or journal?
A. Yes.
Q. And there is a circle around something?
A. Yes.
Q. And what is that circle around? What does that say, that circle?
A. Depigmentation.
Q. You know what depigmentation is, right?
A. Means discoloration essentially.
Q. And so there was an article in Dr. Murray's file about depigmentation. This is in Michael
Jacksons file, correct?
A. Yes.
Q. Now the next is LACC 0908, trial exhibit number is 11963.0017. What is that, sir?

A. That is a report of an MRI, magnetic resonance imaging, of right wrist without contrast.
Q. The name of the patient listed there is Paul Farance. By now I think we all agree that
refers to Michael Jackson. Is says "MJJ" next to it.
A. Yes.
Q. So this is an MRI. What part of the body is an MRI?
A. It's the right wrist.
Q. And the next page which is LACC 0909. It's trial exhibit 11963.0018. There is the
reading, is that right?
A. Yes.
Q. What does the reading say?
A. "impression: small foci of fluid in flexor and extensor tendon sheaths as discussed,
compatible" - -
Q. Better speak a little more slowly, sir.
A. "impression: small foci of fluid in flexor and extensor tendon sheaths as discussed,
compatible with mild tenosynovitis. No significant tendinopathy."
Q. Do you know what tenosynovitis is?
A. I can certainly understand that it is inflammation of a tendon and the synovial part.

Q. Now the next page is LACC 0910. It's a handwritten note for prince Jackson, is that
right?
A. Yes.
Q. It's trial exhibit 11963.0019. That's LACC 0910. That has to do with a treatment of
Prince Jackson on January 25th in 2009, correct?
A. Yes.
Q. He had a cold?
A. Yes.
Q. On the same day, the next page LACC 0911, trial exhibit 11963.0020, through no surprise
to anyone probably, there is a treatment of Blanket Jackson also for a cold, right?
A. Correct.
Q. The same day, two kids in the same family. And --

Mr. Putnam. Is there a question, your honor?

Mr. Panish. Could he finish before Mr. Putnam interrupts him.

Mr. Putnam. He's just making statements from the record, your honor. I'm asking for a
question.

Judge. Is there a question?

Mr. Panish. Is there a legal basis for that objection?

Mr. Koskoff. Next page, please, LACC --

Judge. What was the question --

Mr. Koskoff. The question is -- I'm sort of starting --

Judge. -- was he treated for a cold?

Mr. Koskoff. Was that treatment for a cold of two children in the same family, is that
surprising to you?

A. No, it's not.
Q. And the next page on the same day, January 25, 2009, is a -- it's LACC 0912, exhibit
number 11963.0021 -- is treatment of who?
A. Paris Jackson.

Q. For?
A. Viral upper respiratory infection with cough, nonproductive, no fever.
Q. So it's a cold again?
A. Correct.
Q. So the three children have colds apparently?
A. Yes.
Q. Now the next -- the next page is LACC 0913, and its exhibit number 11963.0022. It's a
typed form from global cardiovascular associates, correct?
A. Correct.
Q. And this has actually Michael Jacksons name on it, correct?
A. Yes.
Q. And what is the complaint? I'm sorry, the date is -- date of service is September 2008 on
this particular exhibit, right?
A. Correct.
Q. And what was the complaint on September 26, 2008?
A. Insomnia

Q. "patient complains of insomnia and having difficulty to sleep," right?

A. Correct.
Q. "he has no evidence of mood changes or signs of depression," correct?
A. Yes.
Q. "he is otherwise doing quite well, and at this time is in great health," right?
A. Yes.
Q. And what is the -- was there a prescription?
A. Yes.
Q. What was the prescription for?
A. Temazepam, 30 milligrams --
Q. I'm sorry?
A. Restoril. Same thing. Restoril 30 milligrams, one tablet by mouth before going to bed as
needed.
Q. Restoril, is that sort of a sedative --
A. It's a Benzodiazepine.
Q. Like Ativan or one of those, right?

A. Correct.
Q. It's to help people sleep?
A. Yes.
Q. And 30 milligrams, what kind of a dose is 30 milligrams?
A. It's typically given either 15 or 30 milligrams.
Q. And the prescription is by mouth as needed, right?
A. Before going to bed, yes.
Q. Now the next day -- that date there was September 26th, '08. And then there is a
handwritten note on that date which has the name Omar Arnold, correct?
A. Yes.
Q. And that has -- the exhibit number is LACC 0914, right?
A. Yes.
Q. And it's 11963.0023. And there is another date -- there was first the date listed there. But
then there is another date 11/19/08. That is another complaint. What is that complaint?
A. Insomnia and or anxiety.

Q. By the way, from your review of the records and the depositions, do you know what was
going on in Michael Jacksons life during this period of time?
Ms. Cahan. Objection, vague. Calls for speculation.
Judge. Sustained.
Mr. Koskoff. In terms of his professional career?
Ms. Cahan. Same objection.
Judge. Overruled.
A. I believe this was after his legal troubles, and I'm not sure what was going on after
specifically in the fall of 2008.
Mr. Koskoff. When were his legal troubles?
A. In the mid 2000's, I believe. This is all from just knowing generally some things about
Michael Jackson.
Q. And this is years after that, isn't it?
A. Yes.
Q. I'm talking about these months in particular. What was going on in his life during these
months?

Ms. Cahan. Objection, asked and answered.

Mr. Koskoff. In terms of his professional life.
Judge. Overruled. If he knows.
A. I know that he was going to be starting the "this is it" tour in 2009. So I'd expect
that at this time, there would be some kind of preparations for that.
Mr. Koskoff. But that's an assumption, but it's not something that you know from anything
you've read, is that true?
Mr. Putnam. Move to strike, your honor.
Judge. So is your answer, yes, it's an assumption?
A. It's an assumption, yes.
Judge. Motion granted. The answer is stricken. Speculation.
Mr. Koskoff. This is seven months before his death, is that right?
A. The, yes. The November one, yes.
Q. Is that November 1st or November 19th?

A. November 19th.
Q. And he had insomnia and anxiety is listed, right?
A. Correct.
Q. And he was -- there was a prescription for Xanax?
A. Yes.
Q. That's the antianxiety medication, another Benzodiazepine?
A. Right.
Q. What was the prescription?
A. 0.5 milligrams, one tablet every six hours as needed, 60 pills given times one.
Q. Is that dosage -- how does that dosage compare?
A. It's a normal dose for Xanax, alprazolam.
Q. There is a refill of Restoril?
A. Yes.
Q. And this is two months later after it was originally prescribed?
A. Yes.

Q. How many tablets were prescribed originally?

A. 30.
Q. This is two months later, and he's getting a refill now, right?
A. I believe it's a new prescription. It's not a refill.
Q. New prescription. And this time he gave him 60 tablets?
A. No. He gave him 30, I think.
Q. I think you're right. Xanax was 60, right?
A. Correct.
Q. So far we have two visits with Dr. Murray according to the record, is that correct?
A. Yes.
Q. And now the next record I want to show you is LACC 0915. Its exhibit number 11963.
Judge. I think there is an objection.
Ms. Cahan. I didn't want to interrupt you. But the two visits -- I just want to make sure you
were talking about on that one page. Otherwise, I'd object that misstates the document.
Mr. Koskoff. Yes, you're absolutely -- no. Wait a second. You may be right.

Ms. Cahan. We were looking at medication records that go back to 2007. We skipped a lot of
pages.
Mr. Koskoff. The medication record is different. These are progress notes.
Q. This is the second progress note we've seen, is that right?
A. For Michael Jackson?
Q. For Michael Jackson, yes. We should get --
Ms. Cahan. Sorry about that. I didn't want to interrupt.
Mr. Koskoff. I appreciate that.
Q. And but for Michael Jackson under progress notes, this is the second progress note?
We know there are other visits, but this is the second one we've come to?
A. There are two -- yes.
Q. Now LACC 0915, exhibit number 11963.0024. There is another typewritten note, is that
right?
A. Yes.
Q. What is that?

A. "patient complains of cough, nasal congestion, chills for two, three days, generalized
fatigue. All in family is sick."
Q. So that would be -- it's another cold. The whole family is sick, did you say?
A. It appears that's the case here, yes.
Q. So that would be a reference to a third visit, correct?
A. Yes.
Q. And that one is on February 1st, '08?
A. Yes.
Q. So apparently we're going backwards through the records, is that correct?
A. Yes.
Q. Which is typically the way medical records are organized, isn't it?
A. Yes and no. People are trying to change that these days. But, yes, it's one of the
traditional ways of going about records, yes.
Q. And then now we're going back to 2007 with LACC 0916, and it's exhibit number
11963.0025. What is the complaint on this visit?
A. Do you want me to explain in more lay terms what's going on here?

Q. Well, we can say first what the word is, and then you can explain what this is if you
know?
A. Onychomycosis. It says "no significant change, no Hepatopathy. Therefore, we
recommended Lamisil for 90 days for treatment of Onychomycosis of the feet.
Q. What is Onychomycosis?
A. Fungal infection of the toes.
Q. Doctor says, since there is no liver problems, he's going to prescribe a fungal cream or
some fungal treatment, right?
A. Typically you start with creams and then, if those don't work, you go into oral medication.
But you're very careful not to injure the liver. It seems here the liver is checked, and the labs are
reviewed, and the liver is fine. Then it's okay to give the oral medication which is much stronger
than the -- it's certainly outside the psychiatric field what I'm talking about here.
Q. Well, right. But you know what it's about?
A. Yes.
Q. This is going back -- this is visit number what by your count?
A. Now we have fourth, I believe.
Q. Fourth. Okay. Now the next typewritten form is LACC 0917, and it's exhibit number
11963.0026, what is the -- this is in March of 2007, right?
A. Yes.

Q. Exhibit numbers what?

A. 0916.
Q. Visit number?
A. Oh, visit number. Five.
Q. And the complaint is of what?
A. Chills, persistent productive cough with greenish brown phlegm, generalized weakness,
minor rales, crackles of the right lower lobe," that refers to the chest, "no wheezes. Chest x-ray
is consistent with small right lower lobe pneumonia"
Q. Was he given medication for that?
A. Yes.
Q. And that's the Z-Pak and Robitussin?
A. Right.
Q. And that date again is 3/7/07?
A. Yes.
Q. Now there are then on the LACC 0918, which is exhibit number 11963.0027, there is a
handwritten note which includes the previous -- for the previous dates, right, except there is one
additional date as I see it on this. That's February, correct?

A. I don't see -- the one further down above the February is -- I believe it may be the same as
the one in exhibit 0915.
Q. Yes, yes. That is the same. You're right. That is the same. That's just a handwritten note
of the same visit?
A. Correct.
Q. So now let's go to --
A. I know you're counting, so we're up to seven now?
Q. I think we're at five.
A. Five. Okay. Five.
Q. And then -- and the last three we talked about the dates were march of '07, April of '07,
and 11th February of '08, right? So now we should be moving backwards if things are working
the way we hope they do. And there is a handwritten note on LACC 00919, and it's 11963.0028.
Ms. Cahan. Misstates the document. I don't see a handwritten note.
Mr. Koskoff. Did I say "handwritten note"? I meant typewritten note.
Ms. Cahan. Objection withdrawn.
Mr. Koskoff. You don't have to object. Withdraw that question. It is a typewritten note, and
you're absolutely right.
Q. And that is -- does it say a date of service?

A. July 24, 2006.

Q. July 24, 2006. So this is a new visit as far as we're concerned, right?
A. Yes.
Q. This would be visit number six, correct?
A. Yes.
Q. What is that for?
A. "patient complains of generalized body aches, weakness, persistent cough with mild
yellowish phlegm, chills, and denies fever. Symptoms followed upper respiratory viral illness
that he encountered from his children. Patient and children have been having similar symptoms
with decrease appetite and fluid intake. No complaints of diarrhea, abdominal cramps, or
abdominal pain."
Q. Again, is that another virus going through the family?
A. It seems like.
Q. And then the next page is LACC 0920, and it's exhibit number 11963.0029. Do you
recognize this type of form?
A. It's a progress note form.
Q. And it's 7/24. You said that, right?
A. Yes.

Q. That's -- and is -- which is the same as the last one. This is still visit number six?
A. Yes.
Q. And it reflects the same information?
A. Yes.
Q. There was an assessment at the bottom of the page?
A. Yes
Q. And the assessment is dehydration?
A. "Viral syndrome, dehydration secondary to decreased fluid intake, cough, history of
generalized Vitiligo and Onychomycosis of both feet."
Q. So that's one -- that's, again, that's July of '06?
A. Yes.
Q. And then there is another one, which should be number seven on the next page, which is
LACC 0921, exhibit number 11963.0030.
A. Yes.
Q. And that one is a visit on January 11th of '06, right?
A. Yes.

Q. And that is exhibit number -- that's visit number seven?

A. I've lost count but yes.
Q. Is that correct?
A. Yes.
Q. That is a cold -- cough, cold, right?
A. "patient presented with a low grade temperature, generalized malaise with mild
production of yellowish phlegm and cough for roughly three or four days." Yes.
Q. Now can you find are there any other visits that Dr. Murray had with Michael Jackson
other than these seven visits?
Ms. Cahan. Objection, calls for speculation.
Q. That are recorded.
Ms. Cahan. Objection withdrawn
A. These are the essential ones. There are some studies also in the records, but they don't seem
to be corresponding with official visits.
Q. And the studies -- are they studies that were done by other individuals or by Dr. Murray?
A. Most likely by other individuals.
Q. There is nothing that is attributed to Dr. Murray in those records other than what we have
gone through, is that correct?

A. There is an echocardiogram that most likely was done by Dr. Murray since he signed it
but he may have just reviewed it. But, yes, there are two of them.
Q. And there is the period -- the period when this all begins is -- the first visit, at least
according to these records, is in January of '06.
A. Yes.
Q. And these seven visits cover essentially a two-year period, is that correct? Am I right
about that?
Ms. Cahan. Objection, misstates the document.
Judge. Sustained.
Mr. Panish. Three.
Mr. Koskoff. Three -- well, two and a half.
Ms. Cahan. I have --
Mr. Panish. January, 11, '06 --
Ms. Cahan. To November '08.
Mr. Panish. No, no. Yeah, you're right. November '08, however long that is, two-and-a-half
years, two years.
Mr. Koskoff. Two years and 10 months, right?

Mr. Panish. Right.

A. Yes.
Mr. Koskoff. Thank you, sir.
Judge. I'm assuming this is going to get to something related to his opinion?
Q. Is there anything in those records that you have reviewed of Dr. Murray that reveal
anything about Demerol or opiate use during that period of time?
A. No.
Q. Is there any indication in any of those records that doctor -- that there was Demerol use
during that period of time?
A. No.
Q. Is there any indication, from your review of those records, that there was any opiate use
during that period of time?
A. No.
Q. We're going into another are
A. Yesterday in your discussion with attorney Cahan, I think you stated that one of the reasons
that you felt that Michael Jackson had a problem with Demerol was the dosage that he had
received, is that right?
A. Yes

Q. And one of the things you mentioned is that it was your belief that -- well, I'll withdraw
that question. What is the usual starting dosage for an adult who receives Demerol?
A. Demerol is hardly used these days. But when it was more popular and it was used, it
would be something like 50 milligrams.
The reporter: 50?
A. 50.
Mr. Koskoff. What?
Mr. Panish. He said 5-0.
A. 50.
Q. Sir, would you agree that the PDR is a reliable reference for dosage?
A. Yes.
Q. And would it be correct to say that the PDR states that the usual dosage for Demerol
starting dose is 50 to 100 milligrams, that's orally, is that right?
A. I do not have the PDR in front of me, and I've never prescribed Demerol myself.
Q. But it is given -- but you did review some of the records in the case, didn't you?
A. Yes.
Q. And did you review the records of some of the doctors who actually prescribed Demerol?

A. Yes.
Q. And did you review Mr. Fournier's records?
A. Yes.
Q. Did Mr. Fournier say that he prescribed Demerol, that when he did it, the starting dose
was 50 to 100?
A. Let me check in the records of Mr. Fournier.
Q. Actually, I can help you with a page number, if you'd like, on his trial testimony. Do
you have that?
A. I have his medical records in front of me.
Q. I think it's 11936 on the trial testimony.
Ms. Cahan. He doesn't have it.
Mr. Putnam. Your honor, he's refreshing his recollection with the medical records.
Mr. Koskoff. I didn't ask him that. The question was "do you recall what Mr. Fournier said
was the usual dosage for Demerol" is what I asked.
Judge. He can use anything to refresh if this helps him.
Mr. Koskoff. Yes.

Judge. Are you talking about the first time he prescribed it?
Mr. Panish. The question was what's the normal --
Mr. Koskoff. What's the usual dosage of Demerol?
Mr. Putnam. The question at present is what Mr. Fournier prescribed for Mr. Jackson.
Correct?
Judge. Right. I'm assuming it would be --
Mr. Koskoff. Your honor, please. What I asked Mr. Fournier was "would you tell the jury
what the usual dose for Demerol is for pain." that was the question.
Judge. Okay. Then I don't think you need to look at anything for Fournier then. He's not
asking you about that.
A. I don't remember the exact answer that he gave to this question.
Q. Actually, let me show you the PDR and see if this refreshes your recollection.
(Off the record discussion between counsel.)
Ms. Cahan. May I come up and look with you?
Mr. Koskoff. Sure.
Q. I asked you what the PDR is. You didn't recall. I'm going to show it to you and see if
that refreshes your recollection as to what the usual dose is.

A. It says here in the PDR in the 2005 edition that the usual dose is 50 milligrams to 150
milligrams orally every three or four hours as necessary.
Q. 50 milligrams to 150 milligrams orally every three to four hours as necessary. Is that
right?
A. Yes.
Q. And when you said that a starting dose would be 50, that would be in the range that the
PDR says, is that right?
A. Yes
Q. And Demerol is a short-acting drug, isn't it?
A. One of the problems with Demerol is that, while the Meperidine itself is rather short
acting, rather quick onset, its metabolites are much longer acting, and they tend to accumulate.
Q. Actually, I was going to go into that, too. but I'm first just asking you about the Demerol
itself.
A. The Meperidine molecule itself is short acting, true.
Q. So the effects of the Demerol are short acting, the beneficial effects, the pain killing
affects?
A. The analgesic effects of Demerol tend to be short acting, yes.
Q. Now I think the jury has already heard this, but I think you started to talk about it. Once
Demerol gets into the body, it starts to get broken down, right? It starts to get burned up?

A. Metabolized.
Q. That's sort of a burning process, right, or a changing process?
A. Yes.
Q. And it leaves a residue, and the residue is called Normeperidine?
A. One of the most prominent one is Normeperidine, correct.
Q. So Demerol is Meperidine. Then, after it gets broken down in the body, it turns into this
Normeperidine?
A. Correct.
Q. Normeperidine does not have an analgesic or pain remedying affect, does it?
A. Much reduced from the Meperidine itself.
Q. And it -- what other affects does Normeperidine have?
A. Accumulates in the body and it can certainly exacerbate the negative effects of the
Meperidine, including depression most prominently.
Q. So it has negative affects?
A. Yes.

Q. Now the Normeperidine, what is the life, first -- Meperidine, how long does that last and
remain effective?
A. It has a short half-life, which means half of the drug metabolized, I believe, within four
to six hours while the --
Q. I'm just asking about the Demerol now. That lasts about four to six hours. So when a
person is given Demerol for pain, they get it repeated over the course of the day if they are
getting it for ongoing pain, is that correct?
A. Very few people get Meperidine these days. But when it was used, one of the ways of
using it was like you're describing it, where you'd give additional doses, one on top of the other,
in order to achieve effective analgesia which, of course, was very problematic.
Q. So that it would be done, for example, every three or four hours you'd get administration
of Demerol?
A. Certainly that was one of the ways of using Demerol.
Q. So that over the course of the day, a person could get, if they were getting 100 milligrams
at a shot over the course of a day, they could get how much?
A. This --
Q. I know it's not done now.
A. It's not done now, but this is not how you do it. First of all, I'm not a pain management
expert here.
Q. You don't have expertise in this area?

A. I do not have an expertise in pain management, but I can explain how it could be used if
you want me to.
Q. Well, I don't want you to explain something that you're not qualified to talk about.
A. I usually deal with the aftermath of these medications.
Q. Yes. Okay. Let's talk about that.
A. Okay.
Q. When a person abuses -- question withdrawn I'll get to that. When a person is on
Meperidine --
A. Yes.
Q. -- for a period of time, they can build up a tolerance, correct?
A. Correct.
Q. What a tolerance means is that it takes more and more of the same drug to bring about the
desired effect, is that right?
A. Or if you continue the same dose, the affect becomes less and less. So yes.
Q. Or if you continue to use it, the affect becomes less and less, right?
A. Correct.
Ms. Cahan. Objection, asked and answered.

Judge. Overruled.
Q. Now tolerance is the need for an increasing doses of opioids to maintain the affect such
as analgesia, pain killing, correct?
A. Yes.
Q. And physical dependence can result, correct?
A. Yes.
Q. And when a person becomes physically dependent on Meperidine and then they stop it
abruptly, they can get withdrawal symptoms?
A. Correct.
Q. Now one of the things that you talked about yesterday was withdrawal.
A. Yes.
Q. In fact, yesterday you talked about both tolerance, which is the need for increasing
amounts, and withdrawal, right?
A. No. I talked a lot about tolerance, and I did not put withdrawal as one of the symptoms,
one of the cluster of symptoms that supports my diagnostic impression for Michael Jackson.
Q. I understand that, sir. But you did talk about withdrawal yesterday. You had a chart on
withdrawal and what you felt were the --
A. Nonspecific.

Q. -- signs of withdrawal?
A. Yes.
Q. That's this chart. It's 11561.
A. Yes.
Q. Right?
A. I did talk about withdrawal, yes.
Q. And that comes about -- withdrawal comes about from the abrupt discontinuation of a
person who has built up a tolerance?
A. Correct.
Q. And it's characterized by restlessness, correct?
A. Are we talking about opioids?
Q. Yes, in particular Meperidine.
A. Okay. Yes.
Q. And you don't have that on your list,
A. Yes.

Q. Yes, you do?

A. Yes, I do not have it. Correct.
Q. Lacrimation. That's tearing, right
A. Yes.
Q. You do not have that on your list?
A. It's part of the flu-like symptoms, runny nose, runny eyes.
Q. And Myalgia, that's pain?
A. Body pains and aches, yes.
Q. What is Mydriasis?
A. Mydriasis. That is the dilation of the pupil of the eye.
Q. And also diarrhea is a common one, isn't it?
A. Yes. I should say that about the Mydriasis, this is not something that is seen typically
with Meperidine withdrawal. This is one of the few things where Meperidine is not as typical as
the rest of the opioids. It's trivial of my field.
Q. But in any rate, those symptoms, bot tolerance and withdrawal, can occur even in a
person who is not addicted as you use the word?
Mr. Putnam. Objection, vague.

Q. Correct?
Mr. Putnam. Objection, vague.
Judge. Overruled.
A. If people can develop tolerance and withdrawal without being -- without suffering from the
full illness of addiction, yes, that's correct.
Q. Because it can in fact -- opioid withdrawal is distinct from an opioid use disorder, isn't
it?
A. Opioid use disorder includes withdrawal as one of the symptoms that gives you the
diagnosis of opioid use disorder.
Q. Okay. So it can occur, but just because it occurs it doesn't mean that there is an opioid
use disorder, is that right?
A. Correct. The way we usually say that is that it's neither sufficient nor necessary
condition.
Q. But for determining if somebody has -- when I say "opioid use disorder," I'm using the
words, you understand, that dsm-5 uses where you use the word addiction. Okay?
A. Correct.
Q. We're using them the same way?
A. Very similar.

Q. When I say "opioid use disorder," first of all, that can have a genetic origin, can't it?
Can it? Yes or no?
A. Opioid use disorder, does it have a genetic component?
Q. Can it?
A. Can it have a genetic component? Yes.
Q. There is nothing in Michael Jackson's family history that you saw that would suggest that
he has or that would show that he has a genetic predisposition toward that, is that correct?
Ms. Cahan. Objection, calls for speculation. outside the scope of discovery in the case.
Judge. Overruled.
A. From what I have reviewed, I have not found family history of opioid use disorder.
Q. And I think -- this is obvious, but I'm going to ask it anyway. In coming to
your decision as to the extent of Michael Jackson's disorder, you had to do that without actually
ever having examined the patient?
A. Correct. That's why it's a diagnostic impression and not a diagnosis.
Q. That's why you weren't able to come up with a diagnosis?
A. Correct.
Q. And so you tried to get it to form an impression from other bits of information?
A. Correct.

Q. And there are -- some of the things you had to consider were whether or not Michael had
the diagnostic features, the features that you would expect in a person with an opioid use
disorder, correct?
A. Correct.
Q. Now do you agree, sir, that opioid use disorder includes signs and symptoms that reflect
compulsive, prolonged self-administration of opioid substances that are used for no legitimate
medical purpose or --
A. Okay.
Q. -- if another medical condition is present that requires opioid treatment that are used in
doses greatly in excess of the amount needed for that medical condition?
A. Yes. That is exactly what got us into the trouble we're now in.
Q. Well, was your answer is do you agree with that, or do you not agree?
A. I do not agree with the spirit of this.
Q. You do not agree with it?
A. I do not agree with it.
Q. But you do agree, sir, that that is what it says in diagnostic statistical manual number five
as the characteristic?
A. Okay.

Q. Do you agree that it says that, sir? If you don't remember, I'll be happy to show it to you
to refresh your recollection.
A. Please do.
Q. Would you like me to?
A. Yes.
Ms. Cahan. May I see it?
Mr. Koskoff. Yes, I'm sorry. I have one exhibit marked. It's 1109-1.
Q. Calling your attention, sir, to page 542 of the dsm-5 where the paragraph that says
"diagnostic features," and it's the first sentence.
A. The key word here --
Mr. Koskoff. First, your honor, would you like a copy?
Judge. Are you asking him to read it to himself?
Q. Read it to yourself to refresh your recollection. Just read it to yourself. The
question is, is that what it says? And I'll read it to you again. Opioid use disorder includes signs
and symptoms that reflect compulsive, prolonged self-administration of opioid substances that
are used for no legitimate medical purpose or if another medical condition is present that
requires opioid treatment that are used in doses greatly in excess of the amount needed for that
medical condition. is that what it says in dsm-5?
A. That's what it says --

Q. Yes or no?
A. That's what it says here.
Q. Can you answer that question, sir?
A. It wasn't what you told me earlier, or what I heard earlier
Q. I'm sorry?
A. There is a significant difference there.
Q. That's what this says?
A. That's what it says.
Q. Do you agree with that?
A. I fully agree with this.
Q. You do agree with it?
A. Yes.
Q. If I misspoke, I apologize?
A. There is the key word "or." either I didn't hear, or you didn't say it. But that was what my
objection was.
Q. Okay, sir.

A. So that people understand what I'm talking about.

Q. I know. I know. And I said "or." I'm almost positive. You may not have heard it, but it
is true that it could be one of two things.
A. Correct.
Q. Either compulsive, prolonged self-administration -- let's start with that one first. is there
any proof in this case, any evidence that you saw that Michael Jackson self-administered
injectable drugs, narcotics? Do you have any evidence that says that anyone ever witnessed that?
A. There is very mild --
Q. You can say yes or no.
A. Direct evidence, no
Q. And the second part of that is, if another medical condition is present that requires opioid
treatment, then you can -- if it is used in doses greatly in excess of the amount needed for the
medical condition, correct?
A. Yes.
Q. And we're going to discuss that in just a minute. But then, is it also true that individuals
with opioid use disorder tend to develop such regular patterns of compulsive drug use that daily
activities and planning are planned around obtaining an administered opioid? Is that another
characteristic?
A. Yes.

Q. Is another characteristic that opioids are usually purchased on the illegal market but may
also be obtained from physicians by falsifying or exaggerating general medical problems or by
receiving simultaneous prescriptions from several physicians? Is that also true?
A. Yes.
Q. Most individuals with opioid use disorder, you agree, have significant levels of tolerance
and will experience withdrawal on abrupt discontinuation of opioid substances. Is that correct?
A. Yes.
Q. So withdrawal, in fact, is a characteristic of opioid use disorder, correct?
A. Certainly.
Q. And individuals with opioid use disorder also develop conditioned responses to drug-
related stimuli, right?
A. Correct.
Q. So is there evidence in this case that you saw that Michael Jackson used more Demerol
than was prescribed?
A. Not that it was prescribed, no.
Q. Is there any evidence that he ever sought drugs illegally?
A. No.
Q. Is there any evidence of cocaine or meth or heroin use?

A. No. I assume "meth," methamphetamine or methadone.

Q. Methamphetamine or methadone.
A. No.
Q. Didn't use either. Is there any evidence that Michael Jackson ever used drugs to produce
euphoria, to get high?
A. I'm trying to think. No.
Q. And is there evidence that the opiates prescribed were more than he needed for pain?
A. It's quite likely that this may be the case.
Q. Okay. Then let me ask you. Which doctor -- first of all, you were not there to examine
the patient, right?
A. Correct.
Q. You were not there to assess the pain, were you?
A. Correct.
Q. You know from Debbie Rowe -- you read Debbie Rowes testimony?
A. Yes.
Q. You know that Debbie Rowe said that he was deathly afraid of pain?

A. Yes.
Q. When he reached a pain level, did she say at three he'd become anxious, and when it was
six, he'd start turning white?
A. Yes.
Q. And that doctors who treated him were the ones who had the responsibility, sir, for
giving him an appropriate amount of pain medication, isn't that correct?
A. Only if they knew what the other doctors were doing.
Q. But the ones who were treating him had that responsibility, didn't they?
A. Only in the context of having ful information about what else he might be taking.
Q. Did they have the responsibility to assess the pain, sir?
A. They did.
Q. Did they have the responsibility, in fact, to administer pain medication in order to
adequately treat his pain? Did they have that responsibility?
A. To administer medications only in the cause benefit analysis only if the downside would
be considerably less than the upside, only you treat pain with more and more medication only
when you're absolutely convinced that the negative effects are not higher than the positive
effects, significantly so.
Q. Now you stated yesterday that you were not qualified to pass on the adequacy of
treatment of a dermatologist, isn't that correct?

A. Correct.
Q. Are you saying here that Dr. Klein committed malpractice in his administration of
Demerol to Michael Jackson?
A. That's a legal term. I wouldn't be able to tell.
Q. Did he depart from the standard of medical care for a dermatologist?
Ms. Cahan. Objection, outside the scope of his expertise.
Judge. Sustained.
Mr. Koskoff. Yes, I agree. I agree.
Mr. Putnam. Well, then why ask the question? Move to strike, your honor.
Mr. Koskoff. That was my point.
Mr. Panish. He doesn't know.
Q You are not qualified in this courtroom to say that the treatment given by Dr. Klein was
not adequate?
Ms. Cahan. Same objection, your honor.
Judge. Overruled.
Q. Isn't that correct?

A. The question being -- sorry.

Q. Would you like me to re-ask the question?
A. Yes.
Q. You are not qualified -- you agree you're not qualified to pass on the treatment given by
Dr. Klein?
A. Yes.
Ms. Cahan. Objection, vague.
Judge. Overruled.
Q. And you are not qualified to pass on the treatment given by Dr. Van Valin?
A. No.
Q. And you are not qualified to pass on the treatment on any of the other doctors who treated
Michael Jackson and who administered pain medication to him, isn't that correct?
A. That's correct.
Q. Now we're going to go into another area right now.
Judge. That's all right. Ten minutes. Keep going.
Q. Everyone in this case has agreed that Michael Jackson had a drug problem.

Ms. Cahan. Objection. Misstates the testimony, your honor.

Judge. I don't know who "everyone" is referring to.
Q. Plaintiff said so in opening statement that he had some points in his life where he had a
problem with prescription medication.
Ms. Cahan. Objection, your honor. Dr. Schnoll.
Judge. Sustained.
Q. There is no question, in your mind, that Michael Jackson at various times in his life had a
problem with Demerol, isn't that correct?
A. There is little doubt.
Q. And based upon your review of the records, this problem began from the time he
suffered burns to his scalp in the Pepsi commercial, isn't that correct?
A. That's when we have most records, yes.
Q. And at that time, he suffered severe burns, correct?
A. Yes.
Q. They were extremely painful, correct?
A. Yes.
Q. Demerol was the drug being used at the time, and morphine was being used at that time?

A. Yes.
Q. And Michael Jackson was prescribed those drugs by the doctors who treated him at that
time, correct?
A. Yes.
Q. And you have no quarrel with that prescription, do you?
A. They did. They had problems with it on prescriptions. Dr. Sasaki, for one, felt very
uncomfortable about writing these Percocet prescriptions. he was the expert, not me. He was
the one who knew what he was doing.
Q. What year were you talking about?
A. 1993, I believe.
Q. 1993. You know when was the Pepsi -- when was the burns from the pepsi commercial?
A. I believe it was before that. It was -- of course it was before that because that's when he
did the procedure.
Q. But when?
A. I don't recall the exact date.
Q. Was it a year before?
A. I don't know when it was.

Q. Was it within two years?

A. I do not know.
Q. How about five years?
Ms. Cahan. Your honor, asked and --
Judge. Overruled.
A. I do not know when he had the accident from the Pepsi commercial.
Q. So whenever it was though, Dr. Sasaki, did he treat him following the burns from the
Pepsi commercial at that time?
Ms. Cahan. Objection, vague as to "that time."
Judge. Overruled.
A. At some point, he delivered treatment which was a direct response to the traumatic event of
the Pepsi commercial.
Q. That was not until several years later. Isn't that correct, sir?
A. As I said before, I'm not sure when the Pepsi commercial was.
Q. But at any rate, Michael was given opiates for pain, whenever it was that the Pepsi
commercial took place, right, in the mid 80's?
A. Okay. I didn't know that.

Q. You didn't know that?

A. No.
Q. And he developed tolerance, didn't he?
A. I did not review the records from 1985.
Q. 1984. Was that the date when the Pepsi commercial was?
A. As I said --
Q. When were the first records you saw?
A. 1993, I believe.
Q. Now in getting off of a drug, where you've developed tolerance and you're going through
withdrawal, some people have a harder time than others, isn't that right?
A. Correct.
Q. There is no usual, right?
A. There are certainly patterns of withdrawal, absolutely.
Q. Right. There were patterns of withdrawal, but it's not a one size fits all formula?
A. Nothing in medicine is one size fits all.

Q. Right. There is no question from your review of the records that Michael Jackson had a
hard time getting off of these drugs when he was on them, isnt that -- is that correct?
A. It is correct. And the reason for that is that he tried a couple of times to beat his disorder,
and he did not succeed.
Mr. Koskoff. Ask that the second part be stricken. it was a yes or no question.
Judge. Motion denied.
Q. And during the course of the "dangerous" tour, there was a lot going on in his life,
wasn't there?
Ms. Cahan. Objection, vague.
Mr. Putnam. Objection, vague.
Mr. Panish. Was that a stereo objection or what?
Judge. Sustained.
Q. During the course of the "dangerous" tour, Michael Jackson was in a lot of pain, wasn't
he?
A. There are reports of pain during the "dangerous" tour, yes.
Q. In fact, he had a suspected neuroma of the scalp, isn't that right?
A. I don't recall a neuroma specifically of the scalp.
Q. He had a lot of surgery around that time, didn't he?

A. He did have surgery in 1993 and '94, yes.

Q. He was on a world tour, right?
A. Yes.
Q. So here he is -- and he's taking large amounts of Demerol, right?
A. He's taking Demerol.
Q. And who knows what else --
A. Correct.
Q. -- isn't that right? and this is over a period of -- how long did that tour last?
A. It was discontinued. I believe it was a few months in 1993, late 1993.
Q. You were all ready. You were all prepared to talk about when it was discontinued. I
wasn't asking you that. I was asking you when it started.
Mr. Putnam. Motion to strike, your honor.
Judge. Motion granted. Don't argue with the witness.
Q. When did it start?
Ms. Cahan. Objection, vague.

Judge. Overruled.
Q. When did the tour start? how many tour concerts did he do before the tour was canceled?
A. I don't recall. I know it was several countries already visited -- Bangkok, Singapore, I
know Mexico city. I know there were several countries, so I would assume it was a good chunk
of time.
Q. Did you read that it was 70 concerts? He did 70 concerts while he had the pain, while he
was on Demerol, while he had his medical problems? Did you read that?
Ms. Cahan. Objection, compound, misstates the evidence, and calls for speculation.
Judge. Overruled.
A. I did read that he was on the world tour and he had many performances.
Q. I'm sorry?
A. True he had many performances on the tour. I can't remember the number 70, but I can
remember he did quite a few.
Q. And how close to the end of the tour was the tour terminated?
A. I know it was terminated in Mexico City, but I don't know how many more
performances were scheduled or planned after that.
Q. But that was one of the points that you -- wasn't that one of the points that you were
concerned about to show how terribly this drug problem interfered with Michael Jackson's
career and life?

Mr. Putnam. Objection, vague.

Judge. Overruled.
A. Yes.
Q. So you used it as a point for showing how much it interfered. But you don't know how
many concerts actually ended up being canceled, right?
A. I don't know the number, no.
Q. And you don't know if it's in accordance with what most other performers failure rates are
for concerts, do you?
A. I cannot compare it with other performers and their discontinuation of world tours, no.
Q. If I were to tell you that the tour was canceled in November and it was supposed to end in
December, would that be in accordance with your memory of the events in this case?
A. 1993?
Q. Yes.
A. Somewhere there, yes.
Q. And he canceled the tour because he wanted to help himself, didn't he?
A. Yes.
Q. And he wanted to go into rehab, didn't he?

A. Correct.
Q. And he did go continue to rehab?
A. Yes, in England.
Q. In England.
A. Yes.
Q. And when did he go into rehab?
A. In late 1993, I believe.
Q. And after late 1993, when is the next time, based on your review of the records, that
Michael Jackson had Demerol?
A. There is an incident with Mr. Fournier.
Q. With who?
A. Mr. Fournier
Judge. Fournier.
Q. When was that?

A. It was sometime after September of 1993. I don't know when it was exactly, but that's
when Michael Jackson appeared to be rather intoxicated to Mr. Fournier, and he actually
canceled the operation.
Q. So was that 1993, sir, or was that 2003?
A. It was sometime -- I'm sorry. That was 2003. Exactly. I'm sorry. Sorry about that.
Q. Now you're ten years ahead of me. We'll get there.
A. I'm sorry about that.
Q. So between 1993 -- after 1993, after he went into rehab, when was the next time, based
on the records, that Michael Jackson ever had any Demerol?
A. There is testimony from Debbie Rowe that Dr. Klein gave him Demerol between 1993
and 1997, and then we have more definitive evidence of that in December of 2001 with Dr.
Saunders.
Q. So 2001 is the first time you have any record of any Demerol being given, correct?
Ms. Cahan. Objection, misstates the testimony.
Judge. You're talking about a written record?
Mr. Koskoff. Yes.
Judge. Overruled.
A. Medical records do show up in 2001. that's true.

Q. That's the first time after 1993. And Debbie Rowe said that at some point that he was
seeing Dr. Klein and having Dr. Klein administer Demerol?
A. Correct.
Mr. Koskoff. Is this a good time, your honor? it's good for me.
Judge. We can go 15 minutes.
Q. We know in 1991 -- first of all, you said he was secretive. Michael was secretive?
A. Yes.
Q. Did you know that in 1993, he came out publicly and talked about his drug problem?
A. Correct.
Q. And did you know that in 1997, he wrote a song called "Morphine" which was on one of
the biggest selling albums in history about his struggle that he had gone through?
Ms. Cahan. Objection, calls for speculation. there is no evidence. This is hearsay, your
honor, what the song was about? There has been no testimony on it.
Mr. Koskoff. It's a song called "morphine."
Judge. Overruled. If he knows.
A. I've never heard the song that I can remember or recall. I may have heard it and not
recognized.
Judge. Maybe he's heard of the album but not the song.

A. What's the name of the album

Q. Then in 1999 --
A. I don't follow this very closely.
Q. In 1999 another -- Michael had another incident in his life which caused a lot of pain,
didn't he?
A. I believe that's when he fell from the bridge.
Q. Actually, he didn't fall. The bridge collapsed?
A. Yes, both fell.
Q. He suffered some injuries then, is that right?
A. Yes.
Q. By 2001 we know that he was back on Demerol again?
A. Yes.
Mr. Putnam. Objection, misstates the testimony.
Judge. Overruled.
Q. And, again, in 2001 and 2003, he was clearly dependent on medication, is that right?

A. 2001 to 2003?
Q. Between that period of time.
A. Yes, he certainly developed a dependence.
Q. And, again, he said "I want to get off," didn't he?
A. Yes.
Q. And he went and he told -- he told Dr. Saunders he wanted to get off, didn't he?
A. He did.
Q. He told Dr. Farshchian he wanted to get off, didn't he?
A. He did.
Q. He told even his security guard Mr. Laperruque he wanted to get off, didn't he?
A. He believed that he wanted be clear.
Q. He wanted to be clear. He wasn't secretive with them, was he, about his problem, was
he?
A. With some people he was clear, and some he wasn't.
Q. Sir, everyone is secretive with some people about their medical condition, isn't that
right?

A. Uh-huh, hopefully not with your doctors.

Q. Sir.
A. Yes.
Q. These people were treating him.
A. Okay.
Q. He told them he had a problem. He was not in denial, was he?
A. He was in denial.
Q. He was in denial. But he was in denial but he told Dr. Farshchian. He told Dr. Saunders.
He told Mr. Laperruque, all of them, he was concerned about his condition, isn't that
right?
A. That's totally consistent.
Q. And then he went to Dr. Farshchian for these implants, is that right?
A. Yes.
Q. And those implants were, at least according to Dr. Farshchian, were for a drug called
naltrexone, correct?
A. The implants were the naltrexone, yes.
Q. As far as you know, was there any such implant on the market in 2002 through 2003?
Was there any such one on the market?

A. There was not commercially available implants as far as I know, but it's something that
people can prepare with a pharmacy and make it.
Q. It was not approved by the at the FDA time?
A. Certainly not.
Q. But Dr. Farshchian, for whatever reason, prescribed it?
A. Yes.
Q. Did you read Dr. Farshchian's deposition?
A. Yes.
Q. He called it Narcan, didn't he?
A. Yes. That's a mistake.
Q. It's a mistake. It is not Narcan?
A. It is not.
Q. Naloxone is Narcan?
A. Naloxone.
Q. So is it clear that he knew what he was doing, in your mind, Dr. Farshchian? This is an
area where you are specialized.

A. Certainly. It is an extreme intervention to give somebody implants. I think that there are
quite a few other interventions that should have preceded that, and I didn't see records of that.
Q. Have you ever put in a naltrexone implant in anyone?
A. No.
Q. So but Michael had -- how many implants did -- how many times did Dr. Farshchian
implant naltrexone?
A. I believe four or five.
Q. I have some dates. Tell me if you think I've got them. In October of '02, there were two,
think, one in the beginning one toward the end.
A. Okay.
Q. Then there is one in November of '02 -- I'm sorry, two in November of '02. One in
January of '03 and one in April of '03. Does that comport with your --
A. That's about six, right?
Q. Yeah.
A. That's in the range of what I remember.
Q. So, again, he was -- he tried this -- Dr. Farshchian tried putting in these implants. And
by the way, naltrexone has another name, doesn't it? Diprenorphine? Is that it?
A. No, very different drugs.

Q. What is it?
A. Naltrexone is Revia, r-e-v-I-
A. And Buprenorphine, the commercial name is Suboxone.
Q. Do you use either one of those two drugs in your practice today?
A. Yes, both.
Q. Which one -- so you use Suboxone?
A. Yes.
Q. Is that right?
A. Yes.
Q. And that is buprenorphine?
A. It's four parts buprenorphine, one part Naloxone.
Q. So naloxone and four parts buprenorphine.
A. Correct.
Q. That has been a very successful drug in treating addiction, isn't it?
A. Correct.

Q. That's on the market now, and that is approved by the FDA, right?
A. Yes.
Q. And the other drug you use is just plain Buprenorphine?
A. There is plain buprenorphine as well, but the other drug that we're referring to here was
Naltrexone.
Q. No, the one you use now.
A. I use naltrexone as well. Suboxone was the combination, four parts buprenorphine, one
part Naloxone. and then there is just buprenorphine which usually comes with the name
Subutex, s-u-b-u-t-e-x.
Q. So after the last implant in April of '03, what was the next time you saw any record that
Michael Jackson ever had Demerol?
Ms. Cahan. Objection, misstates the evidence about the timing of the implants.
Judge. Is there some other date you have in mind?
Ms. Cahan. July '03
Mr. Koskoff. I have April '03.
Judge. Are you suggesting July '03?
Mr. Koskoff. Did I say July?

Judge. No, she's suggesting July.

Mr. Panish. Just because she's suggesting --
Judge. Just trying to clear the record.
Mr. Koskoff. I don't know if it's right, but I don't think there would be any misrepresentation,
so I'll take July of '03.
Q. Is there any record from July of '03 until late 2008 that Michael Jackson ever had any
Demerol?
A. There is some evidence to that.
Q. Where is the record? What record are you referring, sir?
A. I'm referring to the record of Dr. Gordon where he treated Michael Jackson on July 30th,
and Michael Jackson asked for 300 milligrams of Demerol for the road.
Q. Now that was July 30th of what year?
A. 2003
Q. 2003. We're talking now about -- so after that, is there any indication of any Demerol?
He didn't give it to him, did he?
A. He did not give it to him, but Michael Jackson certainly asked for it which is highly
suggestive that, you know, something that he would very well be using.
Mr. Panish. Move to strike. Speculation. No foundation.

Mr. Putnam. Your honor, is there any evidence of use.

Judge. Motion denied.
Q. Is there any record is really what I was asking? Is there any record of any use by Michael
Jackson after I think we decided July of '03 that he ever had Demerol until --
A. 2008.
Q. 2008?
A. Not until 2008.
Q. Not until 2008. So if he didn't, that would be -- if he didn't, just hypothetically, that's five
years without any, right?
A. Simple mathematics, yes.
Q. And then -- and during that five-year period, we just saw the records of Dr. Murray,
right?
A. Yes
Q. They didn't show any indication of any opiate use, right?
A. Correct
Q. You know that you read the records of Dr. David Adams, correct?
A. Yes

Q. And Dr. David Adams said that he saw him. When did Dr. Adams see Michael?
A. That was in Las Vegas, I believe, in 2008.
Q. And the first three times he saw him, Michael said no opiates, right?
A. What do you mean that he was not using opiates?
Q. That he didn't want any, didn't he?
A. He didn't want any. I can't remember the exact phrase of that, but I can look it up again.
Q. One of the people you said in your list of doctors that you relied upon is Dr. Adams, Dr.
David Adams?
A. Correct.
Q. And what did you rely on him for if not for the administration -- the four times he saw
him?
Ms. Cahan. Objection, argumentative.
Judge. No. Overruled. You're asking what did you rely on? Overruled. Why don't you think
about that over the break. Ten minutes.
Recess taken at 11:15
Judge. You may continue with cross.

Mr. Koskoff. Moving right along.

Mr. Putnam. Question withdrawn?
Q. I think, when we broke, I was asking you about Dr. Adams. I just really have, I think,
one question about him, and that is that based on your review of Dr. Adams, the first three times
he went to Dr. Adams, he requested no opiates, correct?
A. I'd have to review the records for that.
Q. If you don't remember, that's fine. And the last time he said he did want a shot of
morphine, that's when a dentist drilled right into his jaw in what was described as a very painful
procedure, isn't that right?
A. I cannot remember that part.
Q. Now in your discussion, when we were talking earlier about withdrawal and tolerance,
and you mentioned that I think tolerance was one of the criteria that you used for deciding that
Michael had a substance use problem.
A. Correct.
Q. Do you agree with me, sir, that symptoms of tolerance and withdrawal occurring during
appropriate medical treatment with prescribed medications are specifically not counted when
diagnosing a substance use disorder? Do you agree with that statement, sir?
A. Yes. We fought very hard for the word "appropriate" in there. That makes all the
difference in the world.
Q. I think we agreed earlier that you are not qualified to testify regarding the appropriateness
of the treatment rendered by the dermatologist, the surgeon, or the anesthesiologist, correct?

A. The specific physicians, whether it was exactly right or not, I cannot render an opinion.
Q. From all you've read, you have not reviewed any testimony by any experts in the field of
dermatology, anesthesiology, dentistry, or any of the other areas that -- you have not reviewed
any testimony of their's that have in any way criticized the care given by those specialists, right?
Ms. Cahan. Objection, vague
Judge. Overruled.
A. No
Q. One of the things you talked about was the friendships that Michael had with doctors?
A. Yes.
Q. And you -- did you -- basically you were trying to -- well, you believed he was trying to
con them?
Ms. Cahan. Objection, misstates the testimony
Q. Isn't that a word that's a word you used in your deposition, "con"?
A. It's one of the possibilities. I've offered several ideas about why physicians and patients
may be defending each other, and why is that problematic
Q. But one of the reasons could be that he was worried about his health and wanted to have
a doctor nearby, isn't that right?
A. It's yet another possibility.

Q. And one of the possibilities -- in fact have you ever seen any testimony that he actually
had held hands with a doctor who did not prescribe medication to him?
A. Testimony of somebody who held hands with Michael Jackson --
Q. A doctor, sir.
A. A doctor holding hands with him and not --
Judge. That's vague. During a procedure or just -- it's a little vague.
Q. I'll try to refresh your recollection
A. Okay.
Q. You said you read Dr. Fournier's -- I'm sorry. I said "doctor." he's an anesthesiologist.
Ms. Cahan. Objection, misstates Mr. Fournier's testimony about his profession.
Judge. Sustained.
Mr. Koskoff. I would claim it, your honor.
Judge. Rephrase.
Mr. Koskoff. I'll rephrase it.
Q. Did you read Mr. Fournier's testimony?

A. Yes.
Q. Mr. Fournier said he was called in on 25 to 35 occasions to be with Michael Jackson, isn't
that right?
A. Okay.
Q. And didn't he say that he only actually administered medication on 25 occasions?
A. I don't remember the numbers. I do not remember that.
Q. And didn't he say that on the rest of the occasions, he actually was there to hold his hand?
Do you recall that?
A. No, I don't.
Q. Do you recall my asking him, "do you mean that literally or figuratively," and he said
"both" because he actually held his hand. It gave Michael security, correct?
A. As I said, I don't remember this part.
Q. And he also said, sir, in the deposition, if you recall, that Michael -- that he was the one,
that is, Mr. Fournier is the one who always decided what medications to give and how much,
didn't he?
A. I don't recall this part.
Q. He said Michael never asked for more pain medications, didn't he?
Mr. Putnam. Objection, your honor. Lacks foundation. He's indicated he doesn't recall this
testimony. His impression was what he has.

Mr. Koskoff. He listed this as a basis of his opinion of Mr. Fournier's testimony. He
specifically relied heavily on Mr. Fournier when Mr. Fournier -- in criticism of Michael.
Judge. Overruled.
A. I just don't recall this part.
Q. Aside from taking drugs -- withdraw the question. Aside from being given drugs for
pain, anxiety, insomnia, do you know of Michael Jackson ever taking or receiving drugs for any
other purpose? When I say "drugs," I'm referring to opiate drugs.
A. Specifically opioid. I'm not sure if I've ever seen him taking opioids for anxiety, but yes.
Q. But he did -- he took them for pain?
A. Yes.
Q. And you know that Mr. Laperruque saw Michael. I think you depended on his testimony
as well, is that right?
A. Yes.
Q. And Mr. Laperruque saw Michael twice when he went to work for him first, and then he
came back to work for him, right?
A. Yes.
Q. Do you remember those approximately years of those?

A. Early 2000's was the first round, and then I believe 2007, 2008 was the second one,
somewhere there.
Q. And the early time was that period of time that we went over earlier where Michael was
in very bad straits as far as his drug use was concerned, is that right?
A. I'm not sure if he was any worse or better than other times. T certainly was a period --
actually was a period where we know that he made an effort to cut down or discontinue his use.
Q. Before that is when he had been seeing a lot of doctors and getting a lot of Demerol,
right?
A. Are we talking about Dr. Saunders and Van Valin?
Q. Yes.
A. Yes.
Q. This was around the 2003 area that was a bad time. We know that.
A. Okay.
Q. But when Mr. Laperruque came back and Mr. Laperruque recognized that, that Michael
was impaired some of the times he saw him, correct?
A. Correct.
Q. But when Mr. Laperruque came back in 2007, he didn't believe Michael had any
problems at that point, did he? He said he looked good, didn't he?
A. I'd have to look exactly what you're referring to.

Q. But if he said he looked good, Dr. Murray didn't note any problems with him at that
time, the promoters said he looked good at that time, is that right?
A. I don't know what the promoters thought.
Q. Dr. Slavit --
A. Certainly.
Q. You remember Dr. Slavit?
A. Yes.
Q. Dr. Slavit said he looked good?
A. That's correct, with minor flu symptoms. But yes.
Q. By the way, what was Dr. Slavit's specialty? Do you remember?
A. I believe he was another either internal medicine or general medicine or family medicine.
17
Q. Ent?
A. Ent.
Q. Is that what you meant?
A. I'm sorry. He certainly did not act as an ent physician for --

Q. No, he didn't. He was actually doing an insurance exam, wasn't he?

A. Certainly. He acted as a general physician.
Q. But he didn't see anything with Michael at the time?
A. Quite -- there was -- there were several parts of the history that were missing. But he did
not -- his conclusions were that essentially Michael Jackson was healthy.
Q. And he examined his body, and there were no track marks, correct?
A. That's correct.
Q. And he -- and that is different from what had happened in 1993 when Dr. Finkelstein saw
him, isn't that right?
A. Are you referring to the episode where Dr. Finkelstein tried to inject Michael Jackson
and was not able to?
Q. Yes, yes. When Dr. Finkelstein tried to inject Michael in 1993, he found that his
gluteous, his butt, was abscessed, and he was unable to put a needle in at that time, isn't that
right?
A. Track marks and what you're referring are two different things. Should I explain?
Q. I apologize. Well, but Dr. Finkelstein at that time attributed that to multiple injections of
Demerol, didn't he?
A. He did not see it. He had to first inject it and then realized that there was -- there were
abscesses in there, necrotic tissue.

Q. So Dr. Finkelstein was clear that he felt that there was a drug problem at that time, and
that that's why these abscesses were there, isn't that right?
A. I did not recall him realizing there was a drug problem at the time. He did realize that he
had a lot of injections done, and that's why -- two reasons actually why he did not -- he found a
problem with injecting him with the medication. One was that the needle would not go in. the
other was that he felt that inoculated which means having an erratic absorption. What that means
is because all the scar tissue, if you were to give a bolus of medication, then that medication
could sit there for a while and then all of the sudden get released into the bloodstream at which
point it could be an overdose for the patient.
Q. My question is, did he -- did you say he did not note that there was a drug problem at that
time?
Ms. Cahan. Objection, misstates the testimony.
Judge. Overruled.
Q. Didn't Dr. Finkelstein -- withdraw that. didn't Dr. Finkelstein in fact tell Paul
Gongaware, according to Dr. Finkelstein's testimony, that he thought Michael had a drug
problem?
A. There were conversations between Dr. Finkelstein and Mr. Gongaware about a drug
problem, yes. I recall that, yes.
Q. Now and at that time, his butt had those abscesses that you described?
A. Yes.
Q. And he didn't get a needle in. Dr. Slavit didn't see any wrong physically with Michael,
any signs of needle marks or anything, did he?

A. He did not see track marks. Yes, that's correct.

Q. And what about Dr. Rogers? What did Dr. Rogers say?
A. I haven't reviewed Dr. Rogers.
Q. Do you know who Dr. Rogers is?
A. I don't recall Dr. Rogers.
Q. Isn't Dr. Rogers the medical examiner, the coroner?
A. Oh, I have reviewed the autopsy, yes.
Q. Did you review his testimony here in court?
A. No.
Q. Well, Dr. Rogers -- Dr. Rogers testified that there were no signs -- he was able to attribute
every needle mark to resuscitation efforts, that there were no other signs of drug use from his
autopsy. Is that something that you considered in your opinion originally?
A. I did look at the autopsy, yes.
Q. And he said there was no liver damage. Did you consider that?
A. Yes. We have evidence of that, that there was no liver damage.
Q. And that aside from the death from Propofol, he was in physically good health from what
he could tell from the organ systems?

A. There was an adenoma but in general, yes.

Q. And he also said -- he said in his testimony that there were had no sclerosed veins.
Would that affect your opinion?
A. I believe the autopsy, yes.
Q. Sclerosed veins can occur when someone has multiple needle injections, correct?
A. Especially when they are contaminated, same with track marks.
Q. Now you did mention the -- we mentioned the autopsy. Then we mentioned the tox
report?
Q. Again, the toxicology report showed no Demerol, right?
A. Correct.
Q. How many times was it analyzed?
A. I'll bet multiple, but I can't remember. Sure.
Q. Multiple. It was at least the heart and the femoral vessels, and then there was the
hospital, three times, right?
A. I don't remember how many times.
Q. No Demerol and no Normeperidine which lasts longer in the system, right?

A. Correct.
Q. You know how to figure out how long it's in the system, right?
A. From -- there is how long something is in the system of a live person, and there is how
long something is in the system of a dead person. I have no expertise about how long something
stays in the body of a dead person, but I do have some expertise about how long
drugs of abuse stay in a live person
Q. You would know that they would stay in longer with a dead person, right?
A. I don't know.
Q. But anyway, the Normeperidine, which is the byproduct, has a half-life, correct?
A. Correct.
Q. And the half-life, what is the half-life of Normeperidine?
A. Can go up to 30 hours.
Q. Half-life 30 hours?
A. Correct.
Q. But it can be 15 hours, right? That's what the textbook says, right?
A. That's not inconsistent with what I understand.
Q. Somewhere in 15 to 30 hours is the half-life. To find out what the full life would be, you
could -- you multiply by five, right? Not a fixed rule.

A. Certainly not a fixed rule. It very much relies on the cutoff points of what are we talking
about detectible levels, and what kind of acid (sic) you use would have different cutoff points.
Q. But the half-life at least is 15 to 30 hours?
A. 15 to 30 hours. That sounds correct.
Q. Normeperidine would be there?
A. Right.
Q. So there is no evidence that Michael -- there is no evidence that says that he took any
drug within that period of time, right, any Demerol?
A. Any Demerol.
Q. Or any other opiate?
A. Or any other opiate. Again, I do not know how long these drugs last in a deceased
person.
Q. In your review of Dr. Klein's record just show that he came in, he started getting 100
milligrams, right?
A. Correct.
Q. Which we decided was the sort of a usual dose of Demerol?
Mr. Putnam. Objection, misstates the testimony.

Q. Right? Wasn't that the usual dosage? In the PDR wasn't that the usual dose, is that correct?
Judge. Sustained. 50 to 100.
Q. But that's within the range of the normal dose, isn't that correct?
Mr. Putnam. In 2009.
Mr. Koskoff. It was 50 to 150 actually. That's okay.
Q. 100 is not an abnormal dose?
Mr. Panish. It doesn't change in 2009, the PDR.
Judge. We don't know what's there.
Q. Has it changed?
A. Nobody uses Demerol anymore.
Q. Nobody uses it anymore?
A. So we don't know what it is.
Q. We're talking a long time ago, right?
A. Yes.
Q. 50 to 150 milligrams would not be out of the ordinary, would it?

A. For extremely severe pain in an emergency situation, that's where this medication is truly
indicated, as an oral dose we talk about, that would be normal, yes.
Q. And Mr. Fournier -- do you recall Mr. Fournier saying that in an injectable dose
intramuscular, his normal starting dose was 50 to 100 milligrams q four hours, in other words,
every three to four hours for pain?
Ms. Cahan. Objection, asked and answered.
Judge. Overruled.
Q. Mr. Fournier said, didn't he, sir, that his normal administration of Demerol at the time -- and
he used Demerol -- was 50 to 100 milligrams every three to four hours, correct?
A. I would have to review his testimony of that.
Q. If he did say that, you wouldn't be critical of him for it, would you?
A. I would certainly have to know a number of other things that were going on before I
could render an opinion whether I'd be critical or not. Most important --
Q. And you're not qualified because you're not a nurse anesthetist or anesthesiologist, isn't
that correct?
A. No, that's not exactly correct.
Q. Well, at any rate Dr. Klein's -- you're not also able to criticize the dose of 100 milligrams
given by Dr. Klein when started, correct?
A. Criticize -- I don't quite understand what that means. The fact that something is -- I'm not
a hundred percent sure that something is inappropriate, doesn't necessarily make it appropriate.
There are two different things there.

Q. Started at 100 milligrams, Dr. Klein, and he ended at 100 milligrams, is that right?
A. You're talking about the period of 2009?
Q. Yes.
A. It seems like that is this arc, yes.
Q. Bringing him up, tapering him off, right?
A. Correct.
Q. And the last dose was on June 22nd?
A. Yes.
Mr. Koskoff. No further questions.
Redirect examination by Ms. Cahan.
Q. Good morning, Dr. Levounis.
A. Good morning.
Q. I'm not going to -- try not to cover the majority of the things you've talked about, but just
sort of talk about a couple of things that came up on cross. okay?
A. Okay

Q. So first you were asked a number of questions this morning about doctor -- medical
records of Dr. Murray for Michael Jackson and his children.
A. Yes.
Q. Do you have any understanding as to whether those records reflect the full time period
and scope of treatment that Dr. Murray provided to Michael Jackson?
A. It's simply the general medicine family practice aspect of his care.
Q. Were there any records from 2009 in the set that you saw?
A. No.
Q. None whatsoever?
A. No.
Q. And you said there were some studies in those records. Why would there be studies in
the records if Dr. Murray didn't perform them, the studies?
A. Oh, because it's typical medical practice you order studies, and then you put them in the
record from somebody else.
Q. And that's something that somebody's primary care doctor would --
A. Would receive from other specialties and other studies, labs.
Q. Did you note anything in that record that was out of the ordinary or inconsistent with the
provision of general medical care to Mr. Jackson and his children in that 2006 to 2008 time
period?

A. No.
Q. Did you note any records of any opioids being prescribed by Dr. Murray to Mr. Jackson?
A. No
Q. So there is no opioid use in the records of Dr. Murray. Are you aware of Mr. Jackson
getting opioids from some other source in late 2008 and first half of 2009
A. Yes.
Q. What's that source?
A. Dr. Klein.
Q. That's what you were just talking about with Mr. Koskoff?
A. Yes.
Q. And on the topic of medical records, you were asked about whether there was any record
from July of 2003 until 2008 of Mr. Jackson using Demerol, correct?
A. Yes.
Q. And setting aside Dr. Murray's records which we just said don't have any records of
opioids in them --
A. Correct

Q. -- do you have any other medical records covering that time period that indicated
provision of opioids?
A. No, not that I recall.
Q. And you were asked this morning about the frequency of dosages for opioids to treat
pain.
A. Correct.
Q. Is it possible to be addicted to opioid even if you're not using them every few hours?
A. Yes.
Q. And can you have addiction without physical dependence, the tolerance and withdrawal?
A. Absolutely.
Q. And can you have physical dependence without the full-blown addiction?
A. Yes, you can.
Q. Switching topics for a second, you were asked some questions yesterday about board
certifications. Do you remember those?
A. Yes.
Q. And do you remember being asked about whether the boards are state by state or
national?
A. Yes.

Q. And I just want to clear that up. Is board certification for a specialty like your
certification in psychiatry and addiction psychiatry a national certification?
A. Yes, it is
Q. What about the boards that issue licenses to practice medicine like your license in New
Jersey and New York? Are those national, or are those state by state?
A. These are state boards.
Q. And you were also asked about whether you're board certified in specialties like
dermatology or surgery or maxillofacial surgery. Do you remember those questions?
A. Yes, I do.
Q. Do you need to have those board certifications to express any of the opinions that you've
offered here at trial?
A. No.
Q. Why not?
A. Because that's what we do as addiction specialists. We help patients who have been
addicted to either street drugs or prescription drugs. That is very much what our specialty is.
Q. So you can express an opinion about whether the amounts of a drug being used or a way
that a drug is being used is indicative of an addiction or not even if you can't say that, you know,
Botox in the eye requires -- in the area of the eye requires a certain amount of pain medication?
A. Correct.

Q. And let's talk about a diagnosis versus a diagnostic impression. Do you remember being
asked some questions about that?
A. Yes
Q. When you used the term "diagnostic impression," is that the same as, you know, I might
meet somebody at a cocktail party, speak to them for a few minutes and have an impression of
that person?
A. No, completely two different things. We reserve the word diagnosis for somebody we
have fully examined, fully reviewed the records, and we can offer a quite definite opinion about
their diagnosis. something like what we are doing today is only an impression but a diagnostic
impression, a serious one otherwise could be called a diagnostic assessment or diagnostic
opinion. But within reasonable medical certainty, I'm confident that this is correct.
Q. You were asked some questions about the use of the term "addiction."
A. Yes.
Q. And the DSM- versus the DSM-5. Do you remember those?
A. Yes.
Q. First of all, is addiction a dirty word in your field? Is it not used anymore?
A. It is widely, widely used. As a matter of fact, the primary body of the American
psychiatric association, the body that publishes the DSM, has the name council on addiction
psychiatry. This is the primary body within the American psychiatric association that advises the
American psychiatric association about matters relating to addiction, and I'm a member of that
board. We have the journal of addiction medicine. We have the American academy of addiction
psychiatry, the journal of addictive diseases. the word addiction is pretty much everywhere, and
we've trying to de-stigmatize the word the same way that cancer centers these days all across the

10 united states are coming out with the name, and they are just calling themselves cancer
centers.
Q. Does it make any difference to your conclusion that Mr. Jackson was addicted to opioids
whether you analyze the records and testimony you saw under the criteria of the DSM- or the
dsm-5?
A. No, these would be semantics.
Q. So just to make sure we're clear, if you did the same analysis that you walked through
yesterday under the dsm-5 version of the criteria, you'd still come to the same conclusion that
Mr. Jackson had an opioid addiction?
A. Yes.
Q. If you took out tolerance from the criteria that you're relying on --
A. Yes.
Q. -- would you still come to the conclusion that Mr. Jackson was an opioid addict under the
DSM- or the DEM-5 definition?
A. Yes, I would.
Q. Do you remember Mr. Koskoff --
Judge. Why is that? Does he -- he has to have three factors, right?
A. He has to have three. I have about five. There is -- even the other two can be evidence but
doesn't rise to the level that I'd put them up as my foremost criteria met.

Q. Do you remember Mr. Koskoff asking you yesterday about Mr. Jackson's drug use and
today not being secretive because he made a public announcement in 1993, and he was seeking
treatment for pain killer dependency?
A. Yes.
Q. Does that Mr. Jackson wasn't necessarily secretive about his drug use?
A. No, not at all. Addiction is a chronic relapsing illness. It does have periods of remission.
It has periods of exacerbation. And so coming out and announcing to the world with one
incident in this whole arc, this whole trajectory of a person who suffers from addiction and
struggles with addiction pretty much all of her or his life. So the overall picture of Michael
Jackson's life, at least over the period of 1993 to 2009, is very highly indicative of an addictive
disorder.
Q. So there was a public announcement in 1993, but he continued to use after 1993
periodically?
A. Yes.
Q. Are you aware of any evidence that Mr. Jackson ever publicly announced after 1993 that
he had a drug problem?
A. No, quite the contrary. We have a letter that was sent, I believe, to people magazine at
the suggestion of Michael Jackson denouncing he has any kind of drug problem.
Q. That was in 2007?
A. Yes, I believe so.
Q. And that was something that Randy Jackson testified about?

A. Yes.
Q. In your opinion, was Michael Jackson's behavior, with respect to that 2007 letter to
people magazine, consistent with somebody who was being secretive about his drug use?
A. Yes, it is.
Q. You reviewed the testimony of Katharine Jackson?
A. Yes.
Q. Did she say that she recognized her son Michael was an opioid addict after 1993?
A. Her testimony was somewhat confusing to me I believe she meant that she would
recognize some signs and symptoms of the disease, but she, as a mother, felt that it wasn't
appropriate for her to fully recognize such signs and symptoms.
Q. Did she say that Mr. Jackson ever came to her after '93 and said, "I have a problem"?
A. I can't remember this part exactly when she did.
Q. What about Michael's -- you reviewed the testimony about intervention attempts by his
family?
A. Yes.
Q. And did anyone testify that Michael reacted to an intervention attempt by saying -- after
1993 -- by saying "I have a problem; you're right
A. No, I don't think so. No.

Q. Let's talk about secrecy in 2009 in particular. You named four medical providers
yesterday who treated Mr. Jackson in 2009 -- Dr. Metzger, Dr. Murray, Dr. Klein and Dr. Lee,
right?
A. Yes.
Q. Did you see any evidence that Mr. Jackson was secretive with those medical providers?
A. Oh, yes, certainly. Ms. Lee took a very comprehensive history for Michael Jackson and
not once did he say that he suffered from addiction. He was quite secretive about that. We also
know that the other physician Dr. Klein, Dr. Murray -- did not really know about each other's
doings. So there was absolutely no communication of medical care during that time.
Q. Just a couple more questions. You were asked some questions about whether Mr. Jackson
-- there was evidence of Mr. Jackson using Demerol between July 2003, when he had the last
naltrexone implant and 2008 when he began seeing Dr. Klein?
A. Yes.
Q. And you said that he went to Dr. Fournier and asked for some Demerol and wasn't given
it?
A. Yes.
Q. Was there ever a time in 1993 where Demerol was -- after July 1993 where Demerol was
found in Mr. Jackson's home?
A. Yes. November of 2003 Demerol was found in Neverland.
Q. Do you draw any inferences from that?
Mr. Panish. Objection, speculation. Inferences are not drawn by witnesses.

Q. In your experience as an addiction psychiatrist who treats addictive people, is it common

for people who are abstinent from a drug to keep that drug around in their house?
A. It's very common to do the opposite, to get rid of all the drugs you're addicted to and
whatever else you might be addicted to.
Judge. Overruled.
Ms. Cahan. I think I said '93 and meant 2003. If I did, I apologize for that.
Q. Is it your recollection that the evidence of the Demerol found at Neverland was in 2003?
Mr. Panish. Objection, leading and suggestive.
Judge. Overruled
A. Yes.
Q And Mr. Koskoff asked you some questions about the spectrum of severity for
substance use disorder under the dsm-5?
A. Right.
Q. Just to be clear, you're not saying whether Mr. Jackson was addicted to benzodiazepines
or Propofol anywhere on that spectrum, right?
A. Correct.
Q. Where on the spectrum would you place Mr. Jackson's opiate addiction?

A. On the severe side.

Mr. Panish. Beyond the question of the cross-examination. It's also going to be cumulative by
the witnesses. But go ahead. If he's going to testify to it, that would eliminate others. Go ahead.
Judge. Overruled. you may answer. You put him on the severe end of the spectrum?
A. Yes.
Q. You're basing that on the evidence you reviewed in this case?
A. Yes.
Q. Including medical records covering decades for Mr. Jackson?
A. Yes.
Q. And testimony of his doctors?
A. Yes.
Q. And you're looking at all this in retrospect?
A. Yes, in retrospect of course.
Q. With the benefit of your expertise?
A. Yes.

Q. Are you aware of defendants having decades of Mr. Jackson's medical records available
to them in 2009?
A. I have no idea
Mr. Panish. Speculation. No foundation.
Judge. Overruled. He answered the question. He doesn't know.
Q. Even though Mr. Jackson had a severe form of opioid addiction, it's still your opinion
that it would have been difficult for lay people to recognize that?
Mr. Panish. That's also beyond the scope of any questions that were asked on cross-
examination.
Judge. Overruled.
Mr. Panish. This wasn't gone into.
Judge. Overruled.
A. I'm sorry. What was the question? I'm sorry.
Q. Even though you think Mr. Jackson suffered from a severe form of opioid addiction, it's
still your opinion that it would have been difficult for lay people to see it?
A. Yes
Q. And why is that briefly?

A. Several reasons about that. First of all, it's -- if you have been an addict for a long time, it
becomes easier and easier for you to hide your addiction. but also from the people around you, it
becomes -- if you're addicted to prescription opioids, if you're addicted to things that doctors
prescribe, then it is much more difficult to get the warning signs of addiction to be
very brief.
Ms. Cahan. Nothing further, your honor.
Mr. Panish. How much time do we have? Now because this new area he just went into, it may
take a while
Judge. It's not a new area I'll give you five more minutes.
Mr. Panish. We're going to need more than that.
Judge. You're not asking the questions. Mr. Koskoff is.
Mr. Panish. I wrote them out though.
recross-examination by Mr. Koskoff.
Q. So what you're saying, doctor, is no matter what anybody says, you're going to have the
same opinion. you're going to say he was addicted even if nobody saw any signs of addiction,
even if there was no proof he had any rugs, even if there was no signs of withdrawal that
anybody noticed, even if there was -- no matter what -- no matter what the evidence, you're
going to stick to your guns, is that right?
Ms. Cahan. Objection, argumentative. Misstates the testimony.
Mr. Koskoff. It does not misstate the testimony.
Judge. Overruled.

A. There is plenty of evidence from the medical records and from the testimony that we do
have a severe illness here.
Mr. Koskoff. Give me from 2003 to -- during when he went back to Dr. Klein, give me one
piece of evidence that he was using drugs. Nobody saw it, did they?
A. I don't have the evidence of taking it. We do have the Demerol found in his home, but we
don't have much more evidence about that.
Q. Was he living there at the time? You said Demerol found in his home. Was he living
there at the time?
A. It was his home but, yeah.
Q. Who else was living there?
A. I don't know who was living there.
Q. In other words, you'd say, if there is Demerol in your home, you're guilty. You are
possessing it, and you are using it for purposes of addiction
A. Patients who suffer from addiction are not the way that you describe them. That is not
correct.
Q. Once an addict, always an addict as far as you're concerned, right?
A. I explained that in some detail yesterday how a lot of people can beat the disorder. I don't
see the evidence here that this is not a chronic relapsing illness. What I do see here is evidence
of exacerbation of the illness, some functional issue of the illness, an overall deterioration that is
very consistent with opioid disorder.

Q. If he's an extreme addict, what do you call a person who is lying in the streets, shooting
himself up with heroin who has no job, no family, and no prospects. What do you call that if he's
an extreme addict?
A. The most difficult part of my job is the very, very poor and the very rich. This is the most
difficult part because both of them --
Q. Answer my question what do -- is it extreme? What is your label?
A. The same way that they can come in all kinds of severity like everybody else. I didn't say
extreme. We don't have extreme. I called it severe.
Judge. He used severe.
A. It's a very different world.
Mr. Koskoff. So severe. Did it interfere with his relationship with his children?
A. I did not see that sign with the children, certainly with a lot of other aspects of his life as
I've explained for the past two days.
Q. You haven't looked at that?
A. His relationship with his children?
Q. Yes.
A. Not specifically, no.
Q. And it certainly didn't interfere with his prospect of getting a job with AEG Live, did it?

A. Did it interfere with his prospect of getting -- I believe the -- of getting the job to begin
with, I don't know. But during that time of 2009, we do see quite a lot of evidence of the --
Q. What I asked you is this: it didn't interfere with AEG Live's decision to enter a contract
for him for a world tour, did it?
Ms. Cahan. Objection, calls for speculation.
Judge. Overruled.
Q. Did it?
A. Can you please repeat the question.
Q. Did it interfere with his prospect for getting a world tour with AEG Live?
A. I do not know.
Q. Isn't one of the things you do to determine whether a person is a severe addict is you
look at, first of all, the amount of their drug use, right?
A. It's part of it.
Q. You look at their tolerance levels, right?
A. It's part of it.
Q. Unless the treatment is part of -- part of the adequate medical treatment.
A. Appropriate, yeah.

Q. Appropriate. You look at the relationships and how it affects his everyday life, right?
A. Correct.
Q. You look at how it affects his ability to get jobs, right?
A. That's part of it, yes.
Q. You look at how it affects his family relations, right?
A. Certainly.
Q. And as far as his ability to get jobs, it appears to have been pretty good in 2007, didn't it
2008 rather, didn't it?
A. I've not looked at this part of the record. I don't know what exactly happened with that.
Q. You didn't look at all into the relationship with his family to see how it affected that?
A. We do have the relationship with his ex-wife, with Debbie Rowe. I did look into her
testimony, yes.
Q. But at least, as far as all of the social and economic ramifications that affect people who
have severe drug problems, you didn't see any social ramifications at all, did you?
A. I did see social ramifications.
Q. You didn't see any family problems, did you that resulted from it?

A. To the extent there was such kind of relationship with Debbie Rowe, who was his ex-
wife, yes; I did see problems there, too.
Q. Relationship with his ex-wife that you considered as a --
A. As a family issue, yes.
Q. Is it common for people to have really great relationships with their ex-wife?
A. Yes.
Q. I don't want to get too personal. You did say it didn't affect his relationship with his kids
as far as you were concerned?
A. No. That, I do not know, no.
Q. When he did -- you said it was very difficult that people, even ordinary people, can't
determine when someone is having a problem that might be drug related, correct?
A. It's one of the illnesses that are difficult to tell
Q. But in fact, when Michael came back from Dr. Klein, Travis Payne noticed, didn't he?
A. It's interesting Travis Payne noticed it, but he also forgave it in some ways. He said that,
since he came back from Dr. Klein, then it must have been okay. Once again, the fallacy that, if
something is prescribed by a physician, it must be, by definition, okay.
Q. Randy Phillips actually questioned in an e-mail whether Michael was suffering from a
chemical problem in June of 2009, didn't he?
Ms. Cahan. Objection, calls for speculation as to the scope.

Judge. Overruled. If he knows.

A. I don't know, no.
Q. You did review e-mails, right?
A. Just once before my deposition I looked over them.
Mr. Koskoff. I have no further questions.
Ms. Cahan. Nothing further, your honor.
Judge. Thank you. 1:45. I have to give a full hour and a half for lunch, so 1:45.