JACKSON V AEGLive April 30th RICHARD SENEFF/ Martinez Detective

866 299-5127
Veritext National Deposition & Litigation Services

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FOR THE PLAI NTI FFS: PANI SH, SHEA & BOYLE LLP
BY: BRI AN J . PANI SH
KEVI N R. BOYLE
ATTORNEYS AT LAW
11111 SANTA MONI CA BOULEVARD
SUI TE 700
LOS ANGELES, CALI FORNI A 90025
KOSKOFF, KOSKOFF & BI EDER
BY: MI CHAEL KOSKOFF
ATTORNEY AT LAW
350 FAI RFI ELD AVENUE
BRI DGEPORT, CONNECTI CUT 06604
( CONTI NUED ON FOLLOWI NG PAGE)

866 299-5127
1 APPEARANCES ( CONTI NUED) :
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3 FOR THE DEFENDANTS: O' MELVENY & MYERS LLP
4 BY: MARVI N S. PUTNAM
5 J ESSI CA STEBBI NS BI NA
6 SABRI NA STRONG
7 KATHRYN CAHAN
8 ATTORNEYS AT LAW
9 1999 AVENUE OF THE STARS
10 SUI TE 700
11 LOS ANGELES, CALI FORNI A 90067
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866 299-5127
1 MASTER I NDEX
2
3 TUESDAY, APRI L 30, 2013 - MORNI NG SESSI ON
4
5 CHRONOLOGI CAL AND ALPHABETI CAL I NDEX OF WI TNESSES
6 WI TNESS NAME DI RECT CROSS REDI RECT RECROSS
7 RI CHARD SENEFF
8 BY MR. PANI SH 2261
9 BY MS. CAHAN 2324
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13 EXHI BI TS
14 ( NONE)
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( THE FOLLOWI NG PROCEEDI NGS WERE HELD
I N OPEN COURT, OUTSI DE THE PRESENCE
OF THE J URORS: )
THE COURT: KATHERI NE J ACKSON VERSUS A. E. G. LI VE,
BC445597.
GOOD MORNI NG, EVERYBODY. COUNSEL, MAKE
YOUR APPEARANCES.
MR. PANI SH: BRI AN PANI SH FOR PLAI NTI FFS. GOOD
MORNI NG.
MR. BOYLE: GOOD MORNI NG, YOUR HONOR.
KEVI N BOYLE FOR PLAI NTI FFS.
MR. KOSKOFF: GOOD MORNI NG, YOUR HONOR.
MI CHAEL KOSKOFF FOR PLAI NTI FFS.
MR. PUTNAM: GOOD MORNI NG, YOUR HONOR.
MARVI N PUTNAM OF O' MELVENY & MYERS ON BEHALF OF
DEFENDANTS.
MS. BI NA: GOOD MORNI NG, YOUR HONOR.
J ESSI CA STEBBI NS BI NA FOR DEFENDANTS.
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1 MS. STRONG: SABRI NA STRONG FOR DEFENDANTS.
2 MS. CAHAN: AND KATHRYN CAHAN FOR DEFENDANTS.
3 THE COURT: OKAY. THANK YOU. WE HAVE A FEW
4 THI NGS TO DI SCUSS THI S MORNI NG. FI RST, THE NOTES. MY
5 STAFF HAS TOLD ME THAT YOU REVI EWED THE NOTES FROM THE
6 J URORS. THE FI RST NOTE, MR. KANG, HE' S ALTERNATE
7 NUMBER 6.
8 I T' S UNCLEAR TO ME WHETHER HE' S MOVI NG
9 PERMANENTLY TO ATLANTA, GEORGI A; OR I F HE J UST BOUGHT A
10 HOUSE AND NEEDS TI ME TO DEAL WI TH THAT. I DON' T KNOW.
11 I THI NK WE SHOULD ASK HI M SOME QUESTI ONS. BUT DOES
12 ANYBODY RECALL ANYTHI NG HE MI GHT HAVE SAI D DURI NG
13 QUESTI ONI NG ABOUT THI S, AND - -
14 MR. PUTNAM: NONE OF THI S, YOUR HONOR.
15 THE COURT: SO LET' S TALK TO HI M.
16 AND THEN THE SECOND NOTE, SOMEBODY HAS A
17 FUNERAL, MS. CHAI DEZ. I ' M NOT SURE WHI CH J UROR SHE I S.
18 MR. PANI SH: ALTERNATE 1.
19 I T' S A HE.
20 THE COURT: OH, MR. CHAI DEZ.
21 LOOKS LI KE HE HAS A FUNERAL ON - - TOMORROW
22 AT NOON. HE WANTS TO LEAVE " AS EARLY AS POSSI BLE SO I
23 CAN BE WI TH MY FAMI LY. " MAYBE WE SHOULD TALK TO HI M,
24 TOO, AND FI ND OUT WHAT I T I S THAT HE NEEDS.
25 CAN WE CALL THEM I N?
26 THE CLERK: BOTH OF THEM AT THE SAME TI ME, YOUR
27 HONOR?
28 THE COURT: NO. LET' S CALL CHAI DEZ FI RST.
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1 MS. STRONG: YOUR HONOR, ONE OF THE I SSUES WE
2 WANTED TO TALK TO YOU ABOUT WERE SOME HOUSEKEEPI NG
3 I SSUES, I NCLUDI NG SOME DEPO DESI GNATI ONS, AND I F WE
4 NEED TO TAKE TOMORROWTO TALK ABOUT THE DEPO
5 DESI GNATI ONS, THAT MI GHT BE AN APPROPRI ATE USE OF TI ME
6 TOMORROW.
7 THE COURT: OKAY. THANK YOU FOR THAT.
8 WHI LE WE' RE HERE, THERE' S A MOTI ON I N
9 LI MI NE THAT' S OUTSTANDI NG I NEED TO RULE ON. I THI NK
10 THE DEFENSE MENTI ONED I T. WHI CH ONE WAS I T? WHAT
11 NUMBER WAS I T?
12 MS. STRONG: I BELI EVE I T' S NUMBER 6, YOUR HONOR.
13 I T' S DEALI NG WI TH SPECULATI VE DAMAGES.
14 THE COURT: OKAY.
15 MS. STRONG: WOULD YOU LI KE TO HEAR ADDI TI ONAL
16 ARGUMENT ON THAT AT SOME POI NT, YOUR HONOR?
17 THE COURT: NO. I ' LL LOOK AT THE PAPERWORK. I F
18 I DO, I ' LL LET YOU KNOW.
19 MS. STRONG: OKAY. THANK YOU.
20 MR. PANI SH: WHEN THERE' S A CHANCE, YOU KNOW,
21 SI NCE WE' RE PUTTI NG ON OUR CASE, I WOULD LI KE TO HAVE A
22 FEWMI NUTES TO TALK TO THE COURT. I KNOWI T' S BEEN
23 KI ND OF DOMI NATED BY DEFENSE TI ME, BUT I WOULD J UST
24 LI KE A FEWMI NUTES TO DI SCUSS SOME I SSUES.
25 THE COURT: SURE.
26
27 ( ALTERNATE J UROR NUMBER 1 ENTERED THE
28 COURTROOM. )
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1 THE COURT: MR. CHAI DEZ, YOU WROTE US A NOTE.
2 YOU HAVE A FUNERAL ON WEDNESDAY. THAT' S TOMORROW.
3 ALTERNATE J UROR NUMBER 1: TOMORROW.
4 THE COURT: AT NOON?
5 ALTERNATE J UROR NUMBER 1: I T' S AT NOON.
6 THE COURT: AND YOU SAY HERE " I NEED TO LEAVE AS
7 EARLY AS POSSI BLE. "
8 CAN YOU TELL ME - - GI VE US A SENSE OF WHEN
9 YOU NEED TO LEAVE SO I CAN ACCOMMODATE - -
10 ALTERNATE J UROR NUMBER 1: I WOULD LI KE TO MAKE
11 THE FUNERAL; HOWEVER, I UNDERSTAND THAT I ' M I N SERVI CE,
12 SO I WOULD LI KE TO BE THERE AS EARLY AS POSSI BLE TO BE
13 THERE WI TH MY FAMI LY, AT LEAST.
14 THE COURT: OKAY.
15 ALTERNATE J UROR NUMBER 1: I T' S AT 12: 00
16 O' CLOCK.
17 THE COURT: I T' S I N CHI NO, WHI CH I S KI ND OF FAR.
18 HOWLONG DOES I T TAKE TO GET THERE?
19 ALTERNATE J UROR NUMBER 1: MAYBE 40 MI NUTES.
20 THE COURT: 40 MI NUTES?
21 OKAY. SO I F WE BROKE AT 11: 00 OR
22 SOMETHI NG, WE HAD A COUPLE OF HOURS OF TESTI MONY - -
23 ALTERNATE J UROR NUMBER 1: THAT WOULD BE AWESOME.
24 I MEAN, I J UST - - I WOULD BE GRATEFUL I F WE COULD DO
25 THAT.
26 THE COURT: OKAY. DO COUNSEL HAVE ANY QUESTI ONS?
27 MR. PUTNAM: NO, YOUR HONOR.
28 THE COURT: OKAY. ALL RI GHT. SO WE' LL
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1 ACCOMMODATE THAT.
2 ALTERNATE J UROR NUMBER 1: THANK YOU VERY MUCH,
3 YOUR HONOR.
4 THE COURT: WE HAVE PLENTY OF THI NGS WE CAN DO I N
5 YOUR ABSENCE.
6 LET' S BRI NG I N MR. KANG, ALTERNATE
7 NUMBER 6.
8
9 ( ALTERNATE J UROR NUMBER 1 LEFT THE
10 COURTROOM. )
11
12 THE COURT: WELL, ONE THI NG I WANTED TO BRI NG UP
13 WHI LE THEY' RE LOOKI NG FOR THAT ALTERNATE I S THERE' S A
14 REQUEST TO EXCLUDE WI TNESSES, CORRECT? THERE' S
15 WI TNESSES I N THE COURTROOM WHO WOULD BE CALLED FOR THE
16 PLAI NTI FFS WHO NEED TO BE EXCLUDED?
17 MR. PANI SH: WHO?
18 THE COURT: I N PARTI CULAR - -
19 MS. BI NA: YOUR HONOR, I N OUR CASE, I THI NK I T' S
20 MR. RANDY J ACKSON I S A WI TNESS ON OUR WI TNESS LI ST.
21
22 ( ALTERNATE J UROR NUMBER 6 ENTERED THE
23 COURTROOM. )
24
25 THE COURT: OKAY. MR. KANG, WE GOT YOUR NOTE,
26 AND WE' RE - - I HAD A QUESTI ON. ARE YOU MOVI NG
27 PERMANENTLY TO ATLANTA, GEORGI A; OR ARE YOU SAYI NG, " I
28 J UST - - I HAVE THESE - - I ' M PURCHASI NG A HOME THERE,
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1 AND I NEED SOME TI ME OFF TO COMPLETE THE PURCHASE, "
2 OR - - I WASN' T ENTI RELY 100 PERCENT CLEAR WHAT YOU WERE
3 SAYI NG.
4 ALTERNATE J UROR NUMBER 6: I WAS PLANNI NG ON
5 MOVI NG. I APOLOGI ZE FOR THE LATE NOTI CE. EVERYTHI NG
6 DI DN' T PASS UNTI L LAST WEDNESDAY.
7 THE COURT: OKAY. SO YOU DI DN' T KNOWFOR SURE I F
8 I T WAS GOI NG TO PAN OUT.
9 ALTERNATE J UROR NUMBER 6: RI GHT.
10 THE COURT: OKAY. I T SAYS STARTI NG J UNE 28.
11 ALTERNATE J UROR NUMBER 6: THAT' S THE CLOSI NG
12 DATE.
13 THE COURT: OKAY. WHEN DO YOU NEED TO - - WHEN DO
14 YOU NEED TO BE OUT OF CALI FORNI A, I GUESS, I S THE
15 QUESTI ON.
16 ALTERNATE J UROR NUMBER 6: WELL, I GUESS A
17 NUANCED ANSWER FOR THAT WOULD BE 60 DAYS AFTER CLOSI NG,
18 BECAUSE THAT' S WHEN - - I THI NK ACCORDI NG TO MY
19 CONTRACT, THAT' S WHEN I HAVE TO ESTABLI SH THAT I ' M
20 LI VI NG THERE AS MY SOLE PRI MARY RESI DENCE.
21 THE COURT: OKAY. YOU MEAN YOU HAVE TO BE
22 PRESENT THERE 60 DAYS AFTER - -
23 ALTERNATE J UROR NUMBER 6: I HAVE TO BE LI VI NG I N
24 THAT RESI DENCE.
25 THE COURT: AS OF 60 DAYS FROM CLOSI NG?
26 ALTERNATE J UROR NUMBER 6: YES.
27 THE COURT: SO AUGUST 28, ROUGHLY?
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1 THE COURT: OKAY. I DON' T THI NK THAT SHOULD BE A
2 PROBLEM. WE SHOULD BE DONE WI TH THE TRI AL BY THEN.
3 DO YOU HAVE ANY CONCERNS?
4 ALTERNATE J UROR NUMBER 6: NO. I MEAN, I GUESS I
5 WI LL J UST HAVE TO, YOU KNOW, PAY A MORTGAGE AND RENT
6 HERE, BUT, YOU KNOW, THAT' S - -
7 THE COURT: OKAY. WELL - -
8 ALTERNATE J UROR NUMBER 6: I MEAN, I J UST WANTED
9 TO BRI NG THI S UP BECAUSE, I MEAN, I T' S NOT LI KE THI S I S
10 A MANDATED MOVE FROM LI KE MY COMPANY. I ' M A REMOTE
11 EMPLOYEE SO I CAN WORK FROM ANYWHERE.
12 I ' VE BEEN I N THE PROCESS OF LOOKI NG FOR A
13 HOME HERE, BUT THE SOUTHERN CALI FORNI A MARKET I S A
14 LI TTLE CRAZY, AND SO I WENT TO ATLANTA FOR MY - - DURI NG
15 MY BI RTHDAY WEEK I N BETWEEN THE TI ME WHEN I GOT CALLED
16 I N THE FI RST DAY I REPORTED, AND I J UST WENT AND LOOKED
17 AROUND AT SOME CONDOS, AND THE PRI CES WERE A LI TTLE BI T
18 MORE FAVORABLE, SO I DECI DED TO - -
19 THE COURT: OKAY. THAT' S FI NE. I ' M J UST TRYI NG
20 TO FI GURE OUT I F WE CAN KEEP YOU UNTI L THE END OF THE
21 TRI AL.
22 I T SOUNDS LI KE WE CAN, CORRECT?
24 THE COURT: OKAY. YOU' RE J UST ALERTI NG US TO THE
25 FACT THAT THI S WAS GOI NG ON, AND - -
26 ALTERNATE J UROR NUMBER 6: WELL, I ALSO DI DN' T
27 TALK ABOUT THE DETAI LS OF THE CASE, BUT I TALKED TO
28 MY - - HE' S LI KE MY ATTORNEY, AS WELL.
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1 HE' S LI KE I SHOULD AT LEAST NOTI FY YOU
2 BECAUSE I DON' T WANT THAT COMI NG OUT AT THE END I N
3 CASE, WORST CASE SCENARI O, I ACTUALLY GET SELECTED ON
4 THE PANEL, AND I T TURNS OUT LATER I WASN' T A RESI DENT
5 OF CALI FORNI A FOR WHATEVER REASON. I F I WERE TO GO
6 AHEAD AND MOVE, THAT I S.
7 THE COURT: BUT YOU' RE NOT PHYSI CALLY GOI NG TO BE
8 THERE UNTI L 60 DAYS AFTER CLOSI NG, RI GHT?
9 ALTERNATE J UROR NUMBER 6: THAT' S THE
10 REQUI REMENT.
11 THE COURT: THE REQUI REMENT I N GEORGI A?
12 ALTERNATE J UROR NUMBER 6: FOR MY CONTRACT TO - -
13 I N TERMS OF THE PURCHASE.
14 THE COURT: OKAY. I DON' T THI NK I T SHOULD BE A
15 PROBLEM.
16 ALTERNATE J UROR NUMBER 6: OKAY.
17 THE COURT: COUNSEL HAVE ANY QUESTI ONS?
18 MR. PUTNAM: NONE, YOUR HONOR.
19 MR. PANI SH: WHEN ARE YOU GOI NG TO MOVE TO
20 GEORGI A?
21 ALTERNATE J UROR NUMBER 6: THAT' S - - I ' M FLEXI BLE
22 ON THAT DATE. I DON' T HAVE A REQUI RED DATE THAT I NEED
23 TO MOVE.
24 MR. PANI SH: ARE YOU PLANNI NG TO MOVE BEFORE
25 AUGUST 28TH?
26 ALTERNATE J UROR NUMBER 6: I HAVEN' T MADE
27 THOSE - - ANY KI ND OF PLANS.
28 THE COURT: OKAY. WELL, I F SOMETHI NG COMES UP,
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1 LET US KNOW, BUT THANK YOU FOR LETTI NG US KNOWAHEAD OF
2 TI ME WHAT' S GOI NG ON. I APPRECI ATE I T. THANK YOU.
3
4 ( ALTERNATE J UROR NUMBER 6 LEFT THE
5 COURTROOM. )
6
7 THE COURT: OKAY. THE WI TNESS I SSUE.
8 MR. PANI SH: I WOULD LI KE TO ADDRESS THAT, I F I
9 MI GHT.
10 THE COURT: OKAY.
11 MR. PANI SH: RANDY J ACKSON I S HERE SUPPORTI NG HI S
12 82- YEAR- OLD MOTHER. HE' S THE ONLY FAMI LY MEMBER THAT
13 COULD BE HERE TODAY. HE' S GI VEN A DEPOSI TI ON I N THE
14 CASE. HI S TESTI MONY HAS BEEN QUESTI ONED EXTENSI VELY.
15 I THI NK - - I WOULD ASK AN EXCEPTI ON FOR HI M
16 BE MADE. ANY OTHER WI TNESSES, FI NE; BUT SOMEONE
17 SUPPORTI NG 82- YEAR- OLD PLAI NTI FF WI TH SOME EMOTI ONAL
18 TESTI MONY, I DON' T SEE A REASON - - THE REASON FOR
19 EXCLUSI ONARY WI TNESS ORDERS I S SO THEY DON' T, YOU KNOW,
20 CHANGE THEI R TESTI MONY; BUT HE' S ALREADY TESTI FI ED
21 UNDER OATH.
22 MS. BI NA: YOUR HONOR, J UST TO RESPOND BRI EFLY,
23 THE WI TNESS' S NEPHEWWHO SUPPORTED HER THROUGH
24 DEPOSI TI ONS I S ALSO PRESENT TODAY. HER SON RANDY WAS
25 NOT AT THE DEPOSI TI ONS, WHERE HER NEPHEWWAS; AND HE I S
26 A FACT WI TNESS, YOUR HONOR.
27 I THI NK I F WE' RE GOI NG TO BE EXCLUDI NG FACT
28 WI TNESSES, PARTI CULARLY THOSE WHO ARE RELATED WI TH OR
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1 FRI ENDS WI TH AT LEAST HALF A DOZEN OTHER FACT
2 WI TNESSES, THERE I S A RI SK I N ALLOWI NG ANY OF THEM TO
3 REMAI N I N THE COURTROOM, AND I THI NK THAT - -
4 THE COURT: OKAY. WELL, PLAI NTI FFS, YOU CAN HAVE
5 YOUR CHOI CE OF WHO YOU WANT; BUT WE CAN' T HAVE FI VE OR
6 TEN FACT WI TNESSES I N HERE. AND YOU DON' T.
7 MR. PANI SH: WE DON' T HAVE THEM.
8 THE COURT: YOU DON' T HAVE THEM. I UNDERSTAND
9 YOU TO BE SAYI NG - -
10 MR. PANI SH: TODAY - -
11 THE COURT: HOLD ON. LI STEN.
12 I ' M SAYI NG I N THE FUTURE, WE CAN' T HAVE
13 FI VE PEOPLE GI VI NG SUPPORT TO OTHERS. I MEAN, YOU HAVE
14 ONE I N THE COURTROOM, THAT' S FI NE; BUT - - SO SHE CAN
15 REMAI N - - I MEAN HE CAN REMAI N, BUT - -
16 MR. PANI SH: I UNDERSTAND, YOUR HONOR.
17 THE COURT: ALL RI GHT. AND WE HAVE EXECUTI VES
18 HERE WHO ARE PARTI ES AND CAN REMAI N I N THE COURTROOM,
19 AS WELL. SO THAT' S FI NE. HE CAN REMAI N, BUT - -
20 MS. BI NA: YOUR HONOR, THE RULE I S DI FFERENT FOR
21 PARTI ES AND WI TNESSES. I UNDERSTAND THE COURT - - ARE
22 YOU SAYI NG THAT - - J UST TO BE CLEAR, YOUR HONOR, THAT
23 RANDY J ACKSON CAN SUPPORT HI S MOTHER EVERY DAY, OR I S
24 I T GOI NG TO BE WHI CHEVER ONE OF HER CHI LDREN - - BECAUSE
25 SEVERAL OF THEM ARE ON OUR WI TNESS LI ST, AND THAT' S
26 WHERE THE CONCERN HAS ARI SEN.
27 HER DAUGHTER REBBI E, WHO WAS HERE
28 YESTERDAY, I S ALSO ON OUR WI TNESS LI ST, WE DO I NTEND TO
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1 CALL HER. SO THAT' S A CONCERN, YOUR HONOR.
2 THE COURT: ONE PERSON, YOU DESI GNATE WHO THE
3 PERSON I S, COUNSEL. OKAY?
4 MR. PANI SH: YES, YOUR HONOR. BUT I DON' T
5 BELI EVE TRENT J ACKSON I S ON THEI R WI TNESS LI ST.
6 MS. BI NA: WE' RE NOT ASKI NG ABOUT TRENT, YOUR
7 HONOR. OUR SUGGESTI ON WAS THAT MR. RANDY J ACKSON COULD
8 LEAVE AND MR. TRENT J ACKSON COULD STAY.
9 THE COURT: THEY UNDERSTAND WHO THEY NEED FOR
10 SUPPORT.
11 MR. PANI SH: BUT THE POI NT BEI NG MR. - - TRENT I S
12 NOT ON THE WI TNESS LI ST, SO I T DOESN' T REALLY APPLY TO
13 HI M. THE I SSUE I S RANDY J ACKSON, YOU' VE ADDRESSED I T,
14 I UNDERSTAND.
15 MS. BI NA: MY ONLY REQUEST I S THAT OTHER J ACKSON
16 FAMI LY MEMBERS WHO ARE WI TNESSES NOT BE PERMI TTED TO
17 STAY, THAT' S ALL. OBVI OUSLY, I F THEY' RE NOT WI TNESSES,
18 I T' S NOT AN I SSUE.
19 THE COURT: WELL, I F SOMEBODY COMES I N, YOU HAVE
20 TO ALERT ME TO WHO.
21 MS. CAHAN: YOUR HONOR, J UST TO BE CLEAR,
22 MR. TRENT J ACKSON I S ON PLAI NTI FFS' WI TNESS LI ST,
23 ALTHOUGH I DON' T BELI EVE HE' S ON DEFENDANTS' . I F
24 THEY' RE NOT PLANNI NG TO CALL THEM, I THI NK THEY HAVE A
25 110 OR SO WI TNESSES, THAT' S FI NE. BUT HE MAY, I N FACT,
26 BE A WI TNESS I N THI S CASE.
27 THE COURT: WELL, I GUESS HE' S NOT GOI NG TO BE.
28 RI GHT?
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1 MR. PANI SH: NO.
2 THE COURT: OKAY. HE' S NOT GOI NG TO BE.
3 MR. PUTNAM: THANK YOU, YOUR HONOR.
4 THE COURT: ALL RI GHT. ONE OTHER THI NG BEFORE WE
5 CALL THE J URY I N. I DO WANT THE DEFENSE TO BRI EF THE
6 I SSUE REGARDI NG MURRAY' S POST- ARREST STATEMENT. I
7 DON' T KNOWI F HE WAS ACTUALLY I N CUSTODY AT THE TI ME
8 THE STATEMENT WAS GI VEN, OR I F I T WAS J UST AN
9 I NTERVI EW.
10 I N OTHER WORDS, WAS I T A POST- ARREST,
11 MI RANDI ZED I NTERVI EW, OR WAS I T J UST A VOLUNTARY
12 I NTERVI EWTHAT HE GAVE? I DON' T KNOW. BUT THE POI NT
13 I S THAT YOU WANT TO I NTRODUCE I T I N YOUR CASE - - AND I
14 ALLOWED I T FOR OPENI NG, WHI CH I S NOT EVI DENCE; BUT I F
15 YOU' RE GOI NG TO TRY TO I NTRODUCE I T I N YOUR CASE I WANT
16 A BRI EF ON WHY I T' S ADMI SSI BLE.
17 AND THE PLAI NTI FFS WI LL HAVE AN OPPORTUNI TY
18 TO RESPOND. WE CAN SET UP THE BRI EFI NG SCHEDULE A
19 LI TTLE LATER, BUT I WANTED TO ALERT YOU THAT I AM GOI NG
20 TO WANT YOU TO ADDRESS THAT.
21 MR. PANI SH: WELL, THAT' S ONE THI NG THAT, YOU
22 KNOW- - WE' RE NOT GETTI NG I NTO THAT TODAY, I HOPE.
23 THE COURT: NO, NO. I ' M J UST SAYI NG I WANT I T
24 BRI EFED AND I ' LL HAVE A HEARI NG ON I T.
25 MR. PANI SH: ALL RI GHT. NOW, FI RST OF ALL, J UST
26 CAN I BRI NG UP A FEWTHI NGS?
27 THE COURT: I THI NK - - DEFENSE, ARE YOU DONE WI TH
28 ALL YOUR - -
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1 MR. PUTNAM: YES, YOUR HONOR.
2 MS. STRONG: - - HOUSEKEEPI NG?
3 NO.
4 MR. PANI SH: WELL - -
5 THE COURT: WELL, LET THEM FI NI SH.
6 MS. STRONG: WI TH RESPECT TO DEPO DESI GNATI ONS,
7 I F WE' RE GOI NG TO ADDRESS THEM TOMORROW, I WANT TO
8 ADDRESS A PROCEDURAL I SSUE, WHI CH I S, YOUR HONOR, WE
9 HAVE SUGGESTED THAT WE HAVE A FORM THAT WAS COMPLETED
10 J OI NTLY WI TH BOTH PARTI ES.
11 WE PROPOSED ONE, WE SUBMI TTED OUR
12 OBJ ECTI ONS AND COUNTER DESI GNATI ONS ON THAT FORM TO THE
13 OTHER SI DE. AND I NSTEAD OF USI NG THAT FORM AND FI LI NG
14 A J OI NT DOCUMENT WI TH YOU, YOUR HONOR, THEY WENT AHEAD
15 AND FI LED SOLELY OBJ ECTI ONS TO OUR COUNTER DESI GNATI ONS
16 WI TH THE COURT.
17 SO YOU HAVE TWO SETS OF FI LI NGS FROM
18 PLAI NTI FFS WI TH RESPECT TO SOME DESI GNATI ONS, NONE OF
19 OUR OBJ ECTI ONS YET, BECAUSE WE THOUGHT WE WERE WORKI NG
20 TOGETHER ON THE PROCESS, BUT APPARENTLY THEY HAVE
21 DECI DED NOT TO ENGAGE I N THAT PROCESS, YOUR HONOR.
22 THE COURT: LET' S DO THI S. DO YOU HAVE THAT ON
23 A - - ON A DOCUMENT THAT CAN BE E- MAI LED TO THEM, AND
24 THEY CAN I NCORPORATE I T I NTO THEI R DOCUMENT AND I HAVE
25 ONE - -
26 MR. PANI SH: WE DI D E- MAI L I T TO THEM.
27 THE COURT: OKAY. WELL, I NCORPORATE I T I NTO
28 YOUR - - YOUR CHART, AND THEN I HAVE ONE DOCUMENT I AM
866 299-5127
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1 WORKI NG OFF OF.
2 MS. STRONG: OKAY. WE CAN DO THAT, YOUR HONOR;
3 BUT THESE ARE PLAI NTI FFS' DESI GNATI ONS, AND WHEN WE ARE
4 DESI GNATI NG, WE WI LL COORDI NATE I T. WE GAVE THEM A
5 CHART THAT THEY J UST NEEDED TO FI LL I N THEI R
6 I NFORMATI ON.
7 THE COURT: WELL, NORMALLY WHAT HAPPENS I S ONE
8 SI DE OR ONE PERSON OR PARTY COORDI NATES THESE.
9 MS. STRONG: THE DESI GNATI NG PARTY USUALLY DOES,
10 AND SO I T SWI TCHES AS TO WHO I S DESI GNATI NG.
11 THE COURT: I ' VE HANDLED THESE BEFORE, AND
12 USUALLY I T' S ONE COUNSEL OR PARTY THAT WI LL TAKE THE
13 LABORI NG OAR. I T' S A LOT OF WORK, BUT I T' S SOMETHI NG
14 THAT ONE COUNSEL WI LL VOLUNTARI LY TAKE ON TO MAKE I T
15 EASY FOR THE COURT.
16 MS. STRONG: WE WI LL DO I T.
17 THE COURT: I F YOU DON' T WANT TO DO I T, WE CAN DO
18 I T THE HARD WAY; BUT I ' D RATHER DO I T THE EASY WAY.
19 MS. STRONG: OF COURSE, YOUR HONOR. WE WI LL
20 I NTEGRATE I NTO THE FORM THEI R OBJ ECTI ONS TO OUR
21 COUNTERS, AND WE' LL GI VE THAT TO YOU TOMORROW.
22 THE COURT: THAT WAY, I HAVE ONE DOCUMENT.
23 MS. STRONG: RI GHT.
24 AND ARE YOU GOI NG TO HEAR ARGUMENT ON THE
25 OBJ ECTI ONS?
26 THE COURT: NORMALLY, I J UST RULE ON THEM, I
27 DON' T HEAR ARGUMENT. I SUPPOSE I F THERE' S SOMETHI NG
28 THAT I NEED ARGUMENT ON, I ' LL LET YOU KNOW; OR I F YOU
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2253
1 SEE A RULI NG THAT YOU FEEL PARTI CULARLY STRONGLY ABOUT,
2 YOU CAN ASK FOR ARGUMENT. I ' M NOT GOI NG TO HEAR
3 ARGUMENT ON EVERY SI NGLE OBJ ECTI ON. I F THERE' S
4 SOMETHI NG YOU FEEL VERY STRONGLY ABOUT, I ' LL CONSI DER
5 I T.
6 MS. STRONG: WE' LL GET YOU A J OI NT DOCUMENT AS
7 SOON AS WE CAN.
8 MS. BI NA: PLAI NTI FFS, COULD YOU SEND US WORD
9 VERSI ONS OF ALL OF YOUR OBJ ECTI ONS AND OBJ ECTI ONS TO
10 OUR COUNTERS?
11 MR. BOYLE: SURE.
12 MS. CAHAN: YOUR HONOR, THERE' S SOME OTHER
13 HOUSEKEEPI NG I SSUES THAT WE CAN DEAL WI TH TOMORROW, BUT
14 ONE THI NG WE WANTED TO RAI SE TODAY WAS THE I SSUE OF
15 WI TNESS ORDER. I BELI EVE AT THE F. S. C. YOU I NSTRUCTED
16 COUNSEL TO TELL EACH OTHER 48 HOURS I N ADVANCE BOTH WHO
17 THEY ARE I NTENDI NG TO CALL AND THE ANTI CI PATED ORDER.
18 OF COURSE, YOU TOLD US TO BE FLEXI BLE.
19 PLAI NTI FFS' COUNSEL I S NOT AGREEI NG AT THI S POI NT TO
20 TELL US THE ORDER; AND FOR WI TNESSES SUCH AS TODAY, WE
21 HAVE DETECTI VE MARTI NEZ, AND MR. SENEFF, THERE' S SOME
22 PHOTOGRAPHS THAT COULD COME I N THROUGH ONE OF EI THER OF
23 THOSE WI TNESSES, AND FOR OUR PREPARATI ON, I T WOULD BE
24 HELPFUL TO KNOWTHE ANTI CI PATED ORDER.
25 MR. BOYLE: YOUR HONOR, WE J UST DI DN' T THI NK WE
26 WERE ORDERED TO GI VE THEM THE ORDER; AND WE DON' T KNOW
27 THE ORDER. FOR EXAMPLE, WE J UST LEARNED THE ORDER
28 TODAY VERY RECENTLY, NOT WI THI N 48 HOURS, BECAUSE
866 299-5127
2254
1 PEOPLE HAVE SCHEDULES, SO I DON' T KNOWWHAT I T
2 MATTERS.
3 THE COURT: WELL, I THI NK YOU SHOULD TELL THEM
4 WHO AND I N WHAT ORDER. OKAY?
5 MR. BOYLE: I F WE KNOW.
6 THE COURT: WE WI LL BE FLEXI BLE, BUT - -
7 MR. PANI SH: OKAY.
8 THE COURT: OKAY.
9 MS. STRONG: THANK YOU, YOUR HONOR.
10 MR. PANI SH: COULD I TALK?
11 THE COURT: THANK YOU.
12 FI NI SHED NOW?
13 MS. STRONG: YES, YOUR HONOR.
15 PLAI NTI FF?
16 MR. PANI SH: FI RST OF ALL, ON THE WI TNESSES, I
17 ASKED DEFENSE COUNSEL - - MR. KOSKOFF ASKED, " FOR OUR
18 PLANNI NG, HOWLONG DO YOU I NTEND TO CROSS- EXAMI NE THE
19 WI TNESS?"
20 GUESS WHAT THE ANSWER I S. " WE DON' T KNOW.
21 WE DON' T KNOWWHAT THEY' RE GOI NG TO SAY. " WELL, I N
22 EVERY TRI AL, YOU DON' T KNOW. I N EVERY TRI AL, COUNSEL
23 HAS TO GI VE AN ESTI MATE. HOWARE WE SUPPOSED TO PLAN
24 OUR WI TNESSES WHEN THEY WON' T EVEN GI VE US ESTI MATES OF
25 HOWLONG THE CROSS- EXAMI NATI ON I S?
26 SO FI RST THI NG I ' D LI KE I S THEM TO BE
27 ORDERED TO GI VE US AN ESTI MATE OF THE CROSS- EXAMI NATI ON
28 OF A WI TNESS. I MEAN, THAT' S FUNDAMENTAL.
866 299-5127
2255
1 THE COURT: WELL, THI S I S WHAT WE' RE GOI NG TO DO.
2 I ' M GOI NG TO HAVE EVERY - - I ' M GOI NG TO HAVE YOU
3 DI SCLOSE WHO THE WI TNESSES ARE GOI NG TO BE - - OKAY? - -
4 WHO YOU' RE GOI NG TO BE CALLI NG, AND WE' RE GOI NG TO TALK
5 ABOUT THE ESTI MATED LENGTH FOR THE ENTI RE EXAMI NATI ON.
6 SO I ' M GOI NG TO ASK PLAI NTI FF, " HOWLONG DO
7 YOU ESTI MATE YOUR DETECTI VE? I S I T AN HOUR? TWO
8 HOURS?" I ' M GOI NG TO ASK FOR AN ESTI MATED CROSS SO WE
9 CAN HAVE A SENSE OF HOWLONG THAT WI TNESS I S GOI NG TO
10 BE ON I N TOTAL. SO WE WI LL GET THE I NFORMATI ON, BUT I T
11 WI LL BE THROUGH ME.
12 MR. PANI SH: WELL, THEY WON' T GI VE I T TO ME, SO
13 THAT' S FI NE.
14 THE COURT: THEY' LL GI VE I T TO ME.
15 MS. BI NA: AGAI N, YOUR HONOR, THEY ASKED US, " HOW
16 LONG ARE YOU GOI NG TO CROSS THEM?" AND THEY DI DN' T
17 DI SCLOSE HOWLONG THEY WERE GOI NG TO DI RECT OR ON WHAT
18 TOPI C, SO I T' S A BI T TOUGH TO - -
19 THE COURT: THAT' S WHY I ' M GOI NG TO DO I T.
20 MR. PUTNAM: THANK YOU.
21 MS. BI NA: THANK YOU, YOUR HONOR.
22 THE COURT: ANYTHI NG ELSE?
23 MR. PANI SH: YES. I MEAN, CAN I HAVE A FEW
24 MI NUTES? I MEAN, THEY HAVE BEEN USI NG A LOT OF THE
25 TI ME HERE, AND I HAVE TO PUT MY CASE ON FI RST.
26 THE COURT: I UNDERSTAND.
27 MR. PANI SH: THE NEXT I SSUE I S THI S COUNTER
28 DESI GNATI ON I SSUE REGARDI NG PARTI ES. I MEAN, WE
866 299-5127
2256
1 HAVEN' T HAD A CHANCE TO DI SCUSS I T. I DON' T WANT TO
2 ARGUE I T RI GHT NOW, BUT THEY ARE J UST THROWI NG THE
3 CODE, YOU KNOW, BEYOND - - THEY' RE TRYI NG TO I NTERRUPT
4 THE BURDEN - - OR THE - - THE PRESENTATI ON OF EVI DENCE BY
5 THE PLAI NTI FF.
6 SO THAT' S A WHOLE I SSUE THAT NEEDS TO BE
7 RESOLVED. I ' M NOT GOI NG TO ARGUE I T RI GHT NOW, BUT
8 THAT' S AFFECTI NG MY ABI LI TY TO DETERMI NE WI TNESS TI MES
9 AND SUCH. SO I J UST WANT TO SAY THAT WE WANTED TI ME TO
10 DI SCUSS I T. OBVI OUSLY, NOT NOWWHI LE THE J URY I S
11 WAI TI NG.
12 SO I GUESS, AS ONE OF THEM SUGGESTED ABOUT
13 THE GENTLEMAN, CHAI DEZ, HAVI NG A FUNERAL - - I GUESS WE
14 COULD DO I T TOMORROW.
15 MS. STRONG: AND, YOUR HONOR, I T' S BEEN BRI EFED,
16 SO - -
17 THE COURT: LET HI M FI NI SH.
18 MS. STRONG: I ' M J UST TRYI NG TO HELP ON THAT
19 POI NT. I T' S BEEN BRI EFED.
20 THE COURT: I UNDERSTAND, BUT YOU' VE HAD YOUR
21 OPPORTUNI TY.
22 MR. PANI SH: YOU KNOW, THAT' S ANOTHER THI NG, YOUR
23 HONOR. YESTERDAY - - I MEAN, I ' VE BEEN I N A FEWTRI ALS
24 MYSELF, AND I HAVE NEVER BEEN I N A TRI AL WHERE A - -
25 WHERE A LAWYER THAT' S NOT EI THER EXAMI NI NG THE WI TNESS
26 OR GI VI NG THE OPENI NG STATEMENT CAN START OBJ ECTI NG AND
27 DOI NG THAT.
28 I MEAN, THE RULE I S, I N CALI FORNI A, I T' S
866 299-5127
2257
1 ONE LAWYER PER WI TNESS. YESTERDAY, YOU SAI D THAT
2 ANYONE CAN OBJ ECT, OR - -
3 THE COURT: I SAI D FROM THE DEFENSE TEAM.
4 MR. PANI SH: YES, ANYONE FROM - - SO ONE OF ANY OF
5 THEI R FI VE OR SI X LAWYERS, BUT THAT' S NOT THE RULE I N
6 CALI FORNI A.
7 THE COURT: WHERE I S THE RULE?
8 MR. PANI SH: THE RULE?
9 I F YOU WANT ME TO FI ND I T - -
10 THE COURT: YES, I ' D LI KE YOU TO FI ND I T.
12 BUT I S THAT WHAT YOU ALLOW? I ' VE NEVER
13 SEEN THAT HAPPEN. MAYBE THAT' S YOUR RULE.
14 THE COURT: LET' S PUT I T THI S WAY. I T HASN' T
15 BEEN DI SRUPTI VE.
16 MR. PANI SH: I T' S GOI NG TO BE.
17 THE COURT: I F I T GETS DI SRUPTI VE, I WI LL CURTAI L
18 I T; BUT, FRANKLY, THERE WAS SOME OBJ ECTI ONABLE
19 ARGUMENTS. THERE WERE SOME ARGUMENTATI VE STATEMENTS
20 THAT YOU MADE DURI NG OPENI NG, WHI CH COULD HAVE BEEN
21 OBJ ECTED TO, AND THEY REFRAI NED FROM DOI NG I T.
22 MR. PANI SH: WELL, SO DI D THEY. THEY MADE
23 OBJ ECTI ONS - -
24 THE COURT: I ' M J UST SAYI NG I F YOU' RE - -
25 MR. PANI SH: THEY - -
26 THE COURT: LI STEN TO ME.
27 I F YOU' RE WORRI ED ABOUT MULTI PLE
28 OBJ ECTI ONS, OBJ ECTI ONS FROM DI FFERENT PARTI ES,
866 299-5127
2258
1 DI SRUPTI ON, I THI NK THEY' VE REFRAI NED FROM DOI NG THAT
2 WHEN THEY COULD HAVE OBJ ECTED; SO I F THERE' S AN ABUSE
3 OF THAT, THEN I WI LL STEP I N, BUT THERE HASN' T BEEN,
4 SO - -
5 MR. PANI SH: YOUR HONOR, I T GOES BOTH WAYS. I
6 DI DN' T OBJ ECT TO ANYTHI NG THEY SAI D. THEY WERE ARGUI NG
7 LI KE CRAZY. SO THAT - - BUT HERE WE ARE TODAY; SO
8 TODAY, WE' VE GOT THI S ONE, THAT ONE J UMPI NG UP FROM THE
9 BACK. WE' VE HAD FOUR OF THEM NOWARGUI NG ON ONE I SSUE
10 SO FAR TODAY. OKAY?
11 AND THEN THEY' RE SAYI NG THAT' S NOT TRUE.
12 THEY' RE J UST YELLI NG OUT STUFF FROM OVER THERE.
13 DI D YOU HEAR THAT?
14 THE COURT: NO.
15 LOOK, DO YOU HAVE AN ARGUMENT? DO YOU HAVE
16 SOMETHI NG YOU WANT ME TO DO? ASK ME. BECAUSE I HAVE A
17 J URY WAI TI NG OUTSI DE. SO I F YOU WANT ME TO DO
18 SOMETHI NG, ASK ME TO DO SOMETHI NG, I ' LL LET YOU KNOW.
19 MR. PANI SH: I WOULD ASK THAT WHEN I ' M TRYI NG TO
20 TALK THAT COUNSEL DOESN' T I NTERRUPT ME AND THAT THEY
21 DON' T MAKE COMMENTS LI KE THEY J UST DI D.
22 CAN WE HAVE THAT FOR BOTH SI DES?
23 THE COURT: COUNSEL, PLEASE DON' T I NTERRUPT EACH
24 OTHER.
25 MS. STRONG: FOR BOTH SI DES, I T WOULD BE GREAT I F
26 WE COULD HAVE THAT RULE. WE' D REALLY APPRECI ATE THAT,
27 YOUR HONOR.
28 THE COURT: ANYTHI NG ELSE SO WE CAN CALL THE J URY
866 299-5127
2259
1 I N?
2 MR. PANI SH: WHAT ARE WE GOI NG TO DO ABOUT
3 TOMORROW?
4 THE COURT: WE' LL TALK ABOUT THAT AT THE BREAK.
5 LET' S NOT TALK ABOUT THAT NOW. I WANT TO GET THE J URY
6 I N.
7 MR. PANI SH: ALL RI GHT. SOUNDS GOOD.
8
9 ( THE FOLLOWI NG PROCEEDI NGS WERE HELD
10 I N OPEN COURT, I N THE PRESENCE OF THE
11 J URORS: )
12
13 THE COURT: KATHERI NE J ACKSON VERSUS A. E. G. LI VE,
14 BC445597.
15 GOOD MORNI NG, EVERYBODY.
16 COUNSEL, I ' M GOI NG TO ASK YOU TO MAKE YOUR
17 APPEARANCES AGAI N FOR THE J URY.
18 MR. BOYLE: KEVI N BOYLE AND BRI AN PANI SH FOR THE
19 PLAI NTI FFS.
20 MR. KOSKOFF: AND MI CHAEL KOSKOFF FOR THE
21 PLAI NTI FFS.
22 MR. PUTNAM: MARVI N PUTNAM FOR THE DEFENDANTS.
23 MS. BI NA: J ESSI CA STEBBI NS BI NA FOR THE
24 DEFENDANTS.
25 MS. CAHAN: KATHRYN CAHAN FOR THE DEFENDANTS.
26 THE COURT: OKAY. THANK YOU. YOU MAY ALL BE
27 SEATED.
28 AND WE' RE GOI NG TO START THE PLAI NTI FFS'
866 299-5127
2260
1 CASE I N CHI EF.
2 PLAI NTI FF, YOU MAY CALL YOUR FI RST WI TNESS.
3
4 RI CHARD SENEFF,
5 CALLED BY THE PLAI NTI FFS AS A WI TNESS, WAS SWORN AND
6 TESTI FI ED AS FOLLOWS:
7
8 THE COURT: THANK YOU, SI R. COME FORWARD. STAND
9 BEHI ND THE COURT REPORTER TO MY LEFT, FACE THE CLERK TO
10 MY RI GHT.
11 THE CLERK: DO YOU SOLEMNLY STATE THAT THE
12 TESTI MONY YOU MAY GI VE I N THE CAUSE NOWPENDI NG BEFORE
13 THI S COURT SHALL BE THE TRUTH, THE WHOLE TRUTH, AND
14 NOTHI NG BUT THE TRUTH, SO HELP YOU GOD?
15 THE WI TNESS: SO HELP ME GOD.
16 THE CLERK: THANK YOU, SI R. YOU MAY HAVE A SEAT
17 TO YOUR RI GHT.
18 AND, SI R, CAN YOU PLEASE STATE AND SPELL
19 YOUR FI RST AND LAST NAME FOR THE RECORD.
20 THE WI TNESS: FI RST NAME, RI CHARD, R- I - C- H- A- R- D,
21 LAST NAME SENEFF, S- E- N- E- F- F.
22 THE CLERK: THANK YOU.
23 THE COURT: THANK YOU, SI R.
24 YOU MAY BEGI N.
25 MR. PANI SH: THANK YOU.
26 / / /
27 / / /
28 / / /
866 299-5127
2261
1 DI RECT EXAMI NATI ON
2 BY MR. PANI SH:
3 Q GOOD AFTERNOON - - OR GOOD MORNI NG.
4 A GOOD MORNI NG, SI R.
5 MR. PANI SH: ALL RI GHT. I ' VE ASKED MS. J ACKSON,
6 YOUR HONOR, TO LEAVE FOR THI S TESTI MONY.
7 Q SI R, BY WHOM ARE YOU CURRENTLY EMPLOYED?
8 A CI TY OF LOS ANGELES FI RE DEPARTMENT.
9 Q AND HOWLONG HAVE YOU BEEN SO EMPLOYED?
10 A ON MAY 5TH, I T WI LL BE 28 YEARS.
11 Q COULD YOU GI VE US A BACKGROUND OF YOUR - -
12 DI D YOU HAVE ANY EMPLOYMENT BEFORE THE FI RE DEPARTMENT?
13 A YES, SI R.
14 Q WHAT DI D YOU DO?
15 A 1980, I WAS AN E. M. T. , EMERGENCY MEDI CAL
16 TECHNI CI AN, FOR MEDEVAC AMBULANCE I N PASADENA. 1982, I
17 STARTED AS A PARAMEDI C FOR MERCY AMBULANCE OUT I N
18 ONTARI O, THEN I J OI NED THE FI RE DEPARTMENT I N 1985.
19 Q SO PRI OR TO J OI NI NG THE FI RE DEPARTMENT,
20 YOU HAD ABOUT FI VE YEARS' EXPERI ENCE AS AN E. M. T.
21 A E. M. T. AND THEN LATER AS A PARAMEDI C.
22 Q COULD YOU TELL US, SI R, WHAT I S THE
23 DI FFERENCE BETWEEN AN E. M. T. AND A PARAMEDI C?
24 A AN E. M. T. I S TRAI NED I N BASI C FI RST AI D,
25 C. P. R. SKI LLS, VENTI LATI ON, THOSE SORT OF THI NGS. MOST
26 OF THE AMBULANCES YOU SEE DRI VI NG THROUGH THE CI TY ARE
27 STAFFED BY E. M. T. ' S TRANSPORTI NG PEOPLE FROM ONE
28 FACI LI TY TO THE NEXT. PARAMEDI CS HAVE AN ADDI TI ONAL
866 299-5127
2262
1 1, 000 HOURS OF TRAI NI NG.
2 I T' S USUALLY A SI X- MONTH PROGRAM I NVOLVI NG
3 TWO MONTHS I N A CLASSROOM, APPROXI MATELY SI X WEEKS I N A
4 HOSPI TAL EMERGENCY ROOM, I . C. U. , OPERATI ONS, THI NGS
5 LI KE THAT, AND THEN TWO MONTHS TO THREE MONTHS AS THE
6 THI RD PERSON ON A WORKI NG PARAMEDI C UNI T.
7 Q WHAT I S A WORKI NG PARAMEDI C UNI T?
8 A A WORKI NG PARAMEDI C UNI T WOULD BE, HERE I N
9 THE CI TY OF LOS ANGELES, THE R. A. AMBULANCES THAT YOU
10 SEE RUNNI NG AROUND WI TH TWO PARAMEDI CS ON I T.
11 NATURALLY, I T HAS A DEFI BRI LLATOR, AN E. K. G. MACHI NE,
12 THEY HAVE THE ABI LI TY TO DO ADVANCED AI RWAYS, ADVANCED
13 CARDI AC LI FE SUPPORT, FLUI D RESUSCI TATI ON.
14 BASI CALLY THI NGS RELATED TO TRAUMA AND
15 THI NGS RELATED TO CARDI AC EMERGENCI ES.
16 Q OKAY. LET' S J UST BACK UP A LI TTLE BI T.
17 WHAT DOES AN R. A. MEAN?
18 A R. A. WOULD BE RESCUE AMBULANCE.
19 Q AND I S THAT SOMETHI NG THAT CAN ACTUALLY
20 CARRY SOMEBODY I N THE VEHI CLE?
21 A THAT' S CORRECT.
22 Q YOU ALSO MENTI ONED THE TERM
23 " DEFI BRI LLATOR. "
24 A YES, SI R.
25 Q WHAT I S A DEFI BRI LLATOR?
26 A DEFI BRI LLATOR I S THE BOX THAT YOU SEE I N
27 ALL THE MOVI ES. I T REGI STERS THE PATI ENT' S E. K. G. , THE
28 LI TTLE BLI PS THAT GO BEEP, BEEP, BEEP, AND I T ALSO HAS
866 299-5127
2263
1 THE ABI LI TY TO TAKE THE PADDLES OFF, PLACE THEM ON THE
2 PATI ENT, AND GI VES YOU THE ABI LI TY TO SHOCK THE
3 PATI ENT.
4 Q E. K. G. , WHAT I S THAT?
5 A ELECTROCARDI OGRAPH MACHI NE. I T RECORDS THE
6 ELECTRI CAL PATHWAYS I N THE HEART, WHAT EXACTLY THE
7 HEART I S DOI NG.
8 Q COULD YOU TELL US WHAT TYPE OF J OB DUTI ES
9 AND RESPONSI BI LI TI ES YOU' VE HAD FOR THE LAST 25 YEARS
10 FOR THE CI TY OF LOS ANGELES FI RE DEPARTMENT?
11 BEFORE I DO THAT, THE CI TY OF LOS ANGELES
12 FI RE DEPARTMENT, WHAT I S THEI R J URI SDI CTI ON OR AREA
13 THAT THEY COVER?
14 A THE CI TY OF LOS ANGELES FI RE DEPARTMENT, I
15 THI NK WE CURRENTLY HAVE 112 STATI ONS. WE COVER
16 EVERYONE FROM SAN PEDRO TO CHATSWORTH, THE ENTI RE
17 SAN FERNANDO VALLEY, PACI FI C PALI SADES, HOLLYWOOD,
18 BOYLE HEI GHTS, THE CI TY OF LOS ANGELES.
19 Q NOW, I S THERE A DI FFERENCE BETWEEN COUNTY
20 FI RE DEPARTMENT AND CI TY FI RE DEPARTMENT?
21 A THERE I S.
22 COUNTY FI RE DEPARTMENT COVERS THE
23 UNI NCORPORATED AREAS AND THE CI TI ES THAT CHOOSE NOT TO
24 HAVE THEI R OWN FI RE DEPARTMENT BUT CONTRACT WI TH THEM.
25 THE PRI MARY DI FFERENCE I S THAT THEI R PARAMEDI CS RI DE ON
26 SQUADS, LI KE THE T. V. SHOW" EMERGENCY, " AND THEY USE A
27 PRI VATE AMBULANCE TO DO THEI R TRANSPORTI NG.
28 I N THE CI TY OF LOS ANGELES, OUR PARAMEDI CS
866 299-5127
2264
1 RI DE ON OUR FI RE TRUCKS, BUT THEY ALSO RI DE ON OUR
2 AMBULANCES SO THAT THERE' S NO TI ME DELAY, WE CAN GET
3 GOI NG REALLY QUI CK.
4 Q TELL US, WOULD YOU, SI R, ABOUT THE TYPE OF
5 EXPERI ENCE AND WORK THAT YOU' VE DONE OVER THE 25 YEARS
6 WI TH THE CI TY OF LOS ANGELES FI RE DEPARTMENT.
7 A I HAVE HAD A FANTASTI C TI ME. CI TY OF
8 LOS ANGELES FI RE DEPARTMENT I S GREAT. THE PEOPLE THAT
9 I ' VE MET THROUGHOUT THE YEARS, FROM THE HOMELESS PEOPLE
10 TO THE WEALTHY TO THE BUSI NESSMEN, I T' S - - YOU LEARN SO
11 MUCH ABOUT THE COMMUNI TY, AND I T' S VERY - - VERY
12 ENJ OYABLE.
13 AS A PARAMEDI C, NATURALLY, I RESPOND TO THE
14 911 CALLS, PATI ENT NOT BREATHI NG, OR CHEST PAI N, OR - -
15 I ' VE DELI VERED I DON' T KNOWHOWMANY BABI ES. CAR
16 ACCI DENTS, BI CYCLES, ANYTHI NG - - PLANE CRASHES.
17 ANYTHI NG YOU CAN I MAGI NE THAT PEOPLE CAN GET THEMSELVES
18 I NTO, I ' VE BEEN THERE.
19 AND THEN I N 1992, I WENT TO OUR FI RE
20 ACADEMY AND WENT THROUGH OUR FI RE COURSE AND I BECAME A
21 FI REFI GHTER; SO NOWI AM BOTH A FI REFI GHTER AND A
22 PARAMEDI C, WHI CH QUALI FI ES ME TO RI DE ON THE PARAMEDI C
23 AMBULANCE, AND I T ALSO QUALI FI ES ME TO RI DE ON
24 PARAMEDI C ENGI NE COMPANI ES, ASSESSMENT ENGI NE
25 COMPANI ES.
26 ASSESSMENT FI RE ENGI NE HAS A PARAMEDI C ON
27 I T. SO I DO ALL OF THAT.
28 Q HOWMANY PARAMEDI CS ARE THERE,
866 299-5127
2265
1 APPROXI MATELY, WI TH THE CI TY OF LOS ANGELES FI RE
2 DEPARTMENT?
3 A APPROXI MATELY 1100.
4 Q AND HOWMANY OF THEM ARE ALSO FI REFI GHTERS,
5 APPROXI MATELY?
6 A APPROXI MATELY 1, 050.
7 Q SO ALMOST ALL OF THEM?
8 A RI GHT, ALMOST ALL OF THEM.
9 Q NOW, AS A PARAMEDI C FI REFI GHTER, WOULD THAT
10 BE YOUR TI TLE?
11 A YES, FI REFI GHTER PARAMEDI C.
12 Q DO YOU FI GHT FI RES?
13 A YES, SI R.
14 Q TELL US WHAT EXPERI ENCE YOU HAVE AS A
15 FI REFI GHTER EXCLUSI VE OF YOUR PARAMEDI C WORK.
16 A I HAVE RI DDEN ON FI RE ENGI NES THAT ARE NOT
17 PARAMEDI C UNI TS; AND I ' VE RI DDEN ON FI RE TRUCKS, TOO.
18 I ' VE BEEN TO FACTORY FI RES. OUR BREAD AND BUTTER I S
19 THE SI NGLE- FAMI LY DWELLI NG I N THE VALLEY OR THE CENTER
20 HALLWAY APARTMENTS DOWNTOWN WHERE YOU HAVE ONE ROOM
21 GOI NG.
22 I ' VE BEEN TO BRUSH FI RES, SEVERAL BRUSH
23 FI RES, AND COUNTLESS AUTO FI RES, AN AMAZI NG AMOUNT OF
24 TRASH FI RES I N DUMPSTERS, CHRI STMAS TREE FI RES. YOU
25 NAME I T. I F I T' S BURNED, I ' VE SEEN I T, AND I T' S - -
26 I T' S QUI TE AMAZI NG. I T' S AN AMAZI NG J OB.
27 Q HAVE YOU EVER RESCUED ANY CATS FROM TREES?
28 A I HAVE NOT RESCUED A CAT. I HAVE RESCUED A
866 299-5127
2266
1 DOG THAT WAS LAYI NG I N THE STREET THAT WAS HI T BY A
2 CAR.
3 Q WHERE ARE YOU CURRENTLY ASSI GNED?
4 A I ' M CURRENTLY ASSI GNED AT THE
5 FRANK HOTCHKI N MEMORI AL TRAI NI NG CENTER. I T' S NAMED
6 AFTER FRANK HOTCHKI N, A FI REFI GHTER WHO DI ED I N THAT
7 BUI LDI NG WHEN I T WAS ON FI RE YEARS AGO.
8 WE DO ALL THE TRAI NI NG FOR THE FI REFI GHTERS
9 FOR THE CI TY OF LOS ANGELES, BE I T FI RE TRAI NI NG OR BE
10 I T MEDI CAL TRAI NI NG. EVERY FI REFI GHTER I N THE CI TY OF
11 LOS ANGELES I S AN E. M. T. AS E. M. T. ' S, THEY BELONG TO A
12 PROGRAM WHERE EVERY TWO YEARS, THEY HAVE TO RECERTI FY.
13 I TEACH THOSE RECERTI FI CATI ON COURSES TO THEM.
14 Q HOWLONG HAVE YOU BEEN TEACHI NG OTHER FI RE
15 DEPARTMENTS?
16 A TWO AND A HALF YEARS.
17 Q PRI OR TO THAT, WHAT DI D YOU DO?
18 A PRI OR TO THAT, I - - MY LAST ASSI GNMENT
19 PRI OR TO THAT WAS FI RE STATI ON 71 I N BEL AI R, WHERE I
20 WORKED AS A PARAMEDI C; AND PART OF THE TI ME, I RODE ON
21 A RESCUE AMBULANCE, PART OF THE TI ME, I RODE ON
22 ENGI NE 71.
23 Q ARE THE ENGI NES DESI GNATED BY THE STATI ON
24 FROM WHERE THEY' RE ASSI GNED?
25 A YES, SI R.
26 Q WHEN YOU SAY YOU RI DE ON AN AMBULANCE, DO
27 YOU EVER DRI VE THE AMBULANCE?
28 A I DO THAT, TOO. THAT' S THE MOST FUN.
866 299-5127
2267
1 Q RUNNI NG THROUGH THE RED LI GHTS?
2 A I T I S. I T' S - - I DON' T KNOWWHAT TO TELL
3 YOU, BUT I T' S - - I WI LL TELL YOU THAT WHEN I ' VE BEEN
4 OFF WORK FOR SEVERAL DAYS, AND WE GET AN ALARM AND WE
5 GET TO J UMP BEHI ND THE WHEEL, I T' S FUN.
6 Q ALL RI GHT. I N J UNE OF 2009, WHERE WERE YOU
7 ASSI GNED?
8 A I N J UNE OF 2009, I WAS AT FI RE STATI ON 71
9 I N BEL AI R.
10 Q OKAY. AND WHAT I S THE EXACT LOCATI ON OF
11 THAT FACI LI TY?
12 A I T' S LOCATED AT THE CORNER OF SUNSET AND
13 BEVERLY GLEN.
14 Q AND WERE YOU ASSI GNED THERE ON J UNE 25TH,
15 2009?
16 A YES, SI R.
17 Q WHAT TYPE OF SHI FTS DO YOU WORK AS A
18 PARAMEDI C FI REFI GHTER?
19 A WE WORK WHAT WE CALL A PLATOON DUTY
20 SCHEDULE. ON A PLATOON DUTY SCHEDULE, WE WORK TEN DAYS
21 A MONTH. THAT I S 10 24- HOUR DAYS A MONTH. SO NORMALLY
22 ON THE C SHI FT, WHERE I WAS AT, YOU WOULD WORK
23 MONDAY - - YOU START MONDAY AT 6: 30 I N THE MORNI NG, AND
24 YOU' D WORK FOR 24 HOURS AND GET OFF TUESDAY MORNI NG AT
25 6: 30 I N THE MORNI NG.
26 AND YOU' D HAVE TUESDAY OFF, AND THEN YOU GO
27 BACK TO WORK ON WEDNESDAY, AND 24 HOURS. AND YOU' RE
28 OFF ON THURSDAY, AND THEN YOU WORK FOR 24 HOURS ON
866 299-5127
2268
1 FRI DAY. AND THEN YOU' RE OFF FOR FOUR DAYS I N A ROW.
2 AND THAT ROTATES; SO THE FOLLOWI NG WEEK, YOU WOULD WORK
3 WEDNESDAY, FRI DAY, SUNDAY, AND I T KEEPS CYCLI NG.
4 Q WHEN YOU SAY YOU' RE ON 24 HOURS, DOES THAT
5 MEAN YOU STAY AT THE FI RE STATI ON?
6 A WHEN WE' RE NOT ON A RESPONSE, YES.
7 Q SLEEP THERE, EAT THERE, WORK OUT, WHATEVER
8 YOU' RE DOI NG?
9 A WHATEVER WE' RE DOI NG.
10 Q OKAY. NOW, ON J UNE 25TH, 2009, DO YOU
11 REMEMBER RESPONDI NG TO THE LOCATI ON OF A POTENTI AL
12 FATALI TY?
13 A I RESPONDED TO A PATI ENT NOT BREATHI NG.
14 Q OKAY. SORRY.
15 HOWI S I T THAT I T' S DETERMI NED WHO RESPONDS
16 TO CALLS?
17 A WHEN THE 911 CALL COMES I N, I T COMES I NTO
18 OUR DI SPATCH CENTER. THEY HAVE TRAI NED DI SPATCHERS WHO
19 FOLLOWA SET OF PROTOCOLS, AND THEY ASK KEY QUESTI ONS,
20 AND BASED ON KEY WORDS THAT PEOPLE RESPOND, THEY WI LL
21 DI SPATCH THE APPROPRI ATE RESOURCE.
22 Q OKAY. I SEE THAT YOU BROUGHT A - - I T LOOKS
23 LI KE A BI NDER WI TH YOU TODAY.
24 A YES, SI R.
25 Q AND DOES THE LOS ANGELES FI RE DEPARTMENT
26 MAI NTAI N BUSI NESS RECORDS OF THE VARI OUS CALLS AND
27 RESPONSES OF I TS EMPLOYEES SUCH AS YOU?
28 A YES, SI R.
866 299-5127
2269
1 Q AND I N THI S CASE, WAS THERE DOCUMENTATI ON
2 OF WHAT TI ME AND WHAT OCCURRED WI TH RESPECT TO THE CALL
3 THAT YOU RECEI VED?
4 A YES, SI R, THERE WAS.
5 MR. PANI SH: OKAY. I ' D LI KE TO SHOWCOUNSEL
6 FI RST EXHI BI T 462- 9987. I F YOU COULD J UST PUT I T UP
7 FOR COUNSEL FI RST BEFORE I SHOWI T TO THE WI TNESS.
8 OKAY?
9 Q SO ARE YOU LOOKI NG AT - - I S I T ON YOUR
10 SCREEN?
11 A I T I S NOT ON MY SCREEN.
12 MR. PANI SH: COULD YOU PUT I T ON THE WI TNESS
13 SCREEN.
14 THE WI TNESS: NOWI T I S.
16 Q COULD YOU TELL US WHAT THAT I S?
17 A WHEN YOU' RE I N THE STATI ON AND THE ALARM
18 COMES I N, THE LI GHTS ALL COME ON, THE BELLS RI NG,
19 THERE' S NO WAY TO MI SS I T. AND A TELETYPE MACHI NE
20 CLI CKS OUT A PRI NTED PI ECE OF PAPER WI TH I NFORMATI ON ON
21 I T TELLI NG YOU WHERE TO GO.
22 Q AND WAS THAT PREPARED I N THE ORDI NARY
23 COURSE OF THE BUSI NESS OF THE LOS ANGELES FI RE
24 DEPARTMENT?
25 A YES.
26 MR. PANI SH: OKAY. I ' D LI KE TO SHOWTHAT
27 EXHI BI T, YOUR HONOR.
28 THE COURT: YOU MAY.
866 299-5127
2270
1 Q BY MR. PANI SH: ALL RI GHT. NOW, OBVI OUSLY,
2 THAT' S HARD TO READ, SO WHY DON' T WE BLOWUP EVEN MORE
3 THE FI RST PART, BECAUSE - - FI RST OF ALL, THERE' S
4 HANDWRI TI NG ON THAT EXHI BI T.
5 DO YOU KNOWWHOSE HANDWRI TI NG THAT I S?
6 A YES, SI R.
7 I T' S MI NE.
8 Q OKAY. YOU CAN I DENTI FY ALL OF THAT
9 HANDWRI TI NG?
10 A YES, SI R.
11 Q OKAY. WHY DON' T YOU - - THE TOP, I T SAYS
12 " E71R- - - "
13 A " RA71. "
14 Q ALL RI GHT. PLEASE EXPLAI N WHAT THAT I S.
15 A ALL RI GHT. SO THI S TELETYPE COMES OUT ON
16 EVERY I NCI DENT THAT WE RESPOND TO, ANY CALL. SO
17 ENGI NE 71, RESCUE 71, ARE THE UNI TS BEI NG RESPONDED TO
18 THI S I NCI DENT.
19 Q OKAY. CAN YOU J UST WALK US THROUGH WHAT
20 WE' RE SEEI NG I N THE TELETYPE, EXCLUDI NG THE HANDWRI TTEN
21 I NFORMATI ON THAT YOU - -
22 A YES, SI R.
23 THE NEXT, OF COURSE, I S THE ADDRESS,
24 100 NORTH CAROLWOOD DRI VE. THE CLOSEST CROSS STREET I S
25 SUNSET. THE NEXT LI NE DOWN I S THE I NCI DENT. I T' S
26 I NCI DENT NUMBER 512; SO AT THAT POI NT I N THE DAY, THERE
27 HAD BEEN - - THI S WAS THE 512TH I NCI DENT GENERATED
28 WI THI N THE FI RE DEPARTMENT.
866 299-5127
2271
1 Q NOT FOR YOUR STATI ON, BUT - - HOWMANY
2 STATI ONS DI D YOU SAY THERE WERE?
3 A THESE ALL START AT 112 STATI ONS.
4 Q SO 512 AS OF 12: 21 THAT DAY, AND I T STARTS
5 AT 12: 01 MI DNI GHT?
6 A CORRECT.
7 Q I T' S PRETTY BUSY OUT THERE.
8 A I T' S A VERY BUSY CI TY.
9 Q GO AHEAD.
10 A THERE' S THE DATE, 6/ 25/ 09, 50- YEAR- OLD
11 MALE. I ' M SORRY. I LEFT OUT, AFTER " I NCI DENT, "
12 " C. R. A. , " WHI CH STANDS FOR CARDI AC ARREST.
13 Q ARE YOU FAMI LI AR WI TH CARDI AC ARREST?
14 A YES, SI R.
15 Q WHAT I S THAT?
16 A CARDI AC ARREST I S WHEN YOUR HEART STOPS.
17 Q THE I NFORMATI ON THAT' S BEEN TYPED HERE BY
18 THE DI SPATCHER, HOWDO THEY RECEI VE THAT?
19 A BY - - VI A PHONE.
20 Q SOMEBODY CALLS I N.
21 DO THEY CALL - - HOW- - DO YOU KNOWWHETHER
22 THI S WAS CALLED TO 911?
23 A I - - I DON' T KNOWHOWTHEY GOT I T.
24 Q OKAY. CALL COMES I N, AND I THI NK YOU TOLD
25 US THAT THE DI SPATCHERS ARE TRAI NED ON WHAT QUESTI ONS
26 TO ASK AND WHAT I NFORMATI ON TO GET.
27 A YES, SI R.
28 Q OKAY. CAN YOU CONTI NUE ON WHAT I NFORMATI ON
866 299-5127
2272
1 THE DI SPATCHER PUT DOWN TO - - TO PROVI DE - - THI S I S
2 PROVI DED TO YOU; I S THAT CORRECT?
3 A THI S I S PROVI DED TO ME.
4 Q AT THE FI RE STATI ON?
5 A YES, SI R.
6 Q DOES I T PRI NT RI GHT OUT?
7 A I T PRI NTS RI GHT OUT.
8 Q DO YOU TEAR I T OFF?
9 A YES, SI R.
10 Q AND YOU GO?
11 A YES, SI R.
12 Q OKAY. GO AHEAD.
13 A ALL RI GHT. SO THE NEXT LI NE DOWN, I T SAYS
14 " 9E1, " AND THAT' S THE CATEGORY OF THE TYPE OF CALL.
15 I ' M NOT A DI SPATCHER, BUT I UNDERSTAND THAT " E" I S THE
16 HI GH PRI ORI TY CATEGORY. AND THEN NOT BREATHI NG AT ALL,
17 THAT' S THE CATEGORY, I T' S NOT BREATHI NG AT ALL, WHEN
18 THEY FLI P A CARD.
19 THE NEXT LI NE DOWN I S THE PHONE NUMBER THAT
20 THE CALL CAME FROM; AND THEN " RADI O 04, " THAT MEANS
21 I T' S BEI NG DI SPATCHED ON CHANNEL 4, SO WE ARE TO
22 MONI TOR CHANNEL 4. AND " DI STRI CT 71, " THAT MEANS I T' S
23 I N FI RE STATI ON 71' S AREA. AND THEN THE FI RE
24 DEPARTMENT HAS I TS OWN SERI ES OF MAPS, VERY DETAI LED,
25 AND I T' S MAP PAGE 491, GRI D 2472.
26 Q I S THAT LI KE A THOMAS BROTHERS?
27 A I T' S LI KE A THOMAS BROTHERS, ONLY I T' S MUCH
28 MORE DETAI LED AND I T USUALLY ENCOMPASSES ONLY A VERY
866 299-5127
2273
1 SMALL AREA.
2 THE NEXT LI NE DOWN I S THE DI SPATCH TI ME.
3 WE WERE DI SPATCHED AT 12: 22. NATURALLY, THE DATE; AND
4 THE " CONSOLE C17" MEANS THE DI SPATCHER WHO RECEI VED THE
5 CALL.
6 Q OKAY. PLEASE CONTI NUE.
7 A THE NEXT LI NE DOWN, I T' S " 911 CALL,
8 VERI ZON WI RELESS. " I ' M NOT SURE I F THAT' S THE PHONE
9 NUMBER THAT CALLED I T I N OR WHAT. I T CAME I N VI A
10 WI RELESS CALL.
11 Q SO I T WAS WI RELESS, A CELL PHONE?
12 A I WOULD BELI EVE SO, SI R.
13 Q OKAY.
14 A " BEVERLY HI LLS P. D. QUERY CALLER, " I
15 HONESTLY DON' T KNOWWHAT THAT MEANS.
16 Q ALL RI GHT.
17 A AND " ORI GI NAL W911 I NFO, " I ALSO DO NOT
18 KNOWWHAT THAT MEANS.
19 Q ALL RI GHT. OKAY. TELL US ABOUT - - WHEN
20 DI D YOU PUT THE HANDWRI TI NG ON THERE?
21 A NATURALLY WHEN YOU GO OUT THE DOOR AND YOU
22 GET I NTO YOUR RESCUE AMBULANCE, I N MY CASE, YOU GRAB
23 THI S PI ECE OF PAPER. I T' S I N YOUR HAND. I T BECOMES A
24 NATURAL PI ECE OF SCRATCH PAPER. SO WHEN I WAS AT THE
25 I NCI DENT I S WHEN I STARTED WRI TI NG DOWN NOTES,
26 GATHERI NG I NFORMATI ON, THAT SORT OF THI NG.
27 Q OKAY. WE' LL COME BACK TO THAT. HOW- -
28 STRI KE THAT.
866 299-5127
2274
1 WHO WAS I N THE AMBULANCE, THE RESCUE
2 AMBULANCE, WI TH YOU?
3 A MY PARTNER THAT DAY WAS MARTI N BLUNT. HE
4 WAS DRI VI NG.
5 Q HE' S ALSO A PARAMEDI C FI REFI GHTER?
6 A HE' S ALSO A FI REFI GHTER PARAMEDI C, YES.
7 Q DI D ANY OTHER PERSONNEL FROM YOUR STATI ON
8 RESPOND?
9 A YES, SI R.
10 ENGI NE 71, WI TH THE MAN WHO DRI VES THE FI RE
11 ENGI NE, ENGI NEER BRI GANDI ; THE CAPTAI N OF THE FI RE
12 ENGI NE, J EFF MI LLS; THE FI REFI GHTER ON THE ENGI NE,
13 BRETT HERON; AND THE PARAMEDI C ON THE ENGI NE,
14 MARK GOODWI N.
15 Q OKAY. WHO GOT THERE FI RST?
16 A THE ENGI NE PARKED OUT AT THE STREET. WE
17 FOLLOWED BEHI ND THE ENGI NE, AND THEN WE PULLED RI GHT
18 I NTO THE DRI VEWAY. WE ARRI VED SI MULTANEOUSLY.
19 Q WHAT TI ME DI D YOU ARRI VE AT THE SCENE?
20 A I ' LL HAVE TO LOOK.
21 12: 26. ACTUALLY, I THI NK I T WAS A LI TTLE
22 SOONER THAN THAT. I WOULD SAY 12: 25.
23 Q HOWDO YOU KNOWTHAT?
24 A BECAUSE WHEN I GOT TO THE PATI ENT, I WROTE
25 DOWN 12: 26.
26 Q OKAY. SO YOU ARRI VED AT THE SCENE.
27 WHERE - - WHERE DI D YOU PARK? WHERE WAS - - YOU DI DN' T
28 DRI VE, BUT WHERE WAS THE AMBULANCE PARKED?
866 299-5127
2275
1 A WHEN WE ARRI VED AT THE LOCATI ON, THERE WAS
2 A LOT OF SECURI TY PERSONNEL OUT FRONT, AND THEY WERE
3 WAVI NG US THROUGH THESE LARGE GATES THAT HAD J UST
4 OPENED UP.
5 AND WE DROVE I N, AND THERE WAS A WATER
6 FOUNTAI N AND A - - AND A DRI VEWAY AND A FRONT DOOR, AND
7 THEY WAVED US RI GHT UP TO THE FRONT DOOR AND WE PARKED
8 RI GHT NEXT TO THE FRONT DOOR.
9 Q WHAT DI D YOU DO UPON ARRI VI NG AT THE SCENE?
10 A WE GOT OUT OF THE AMBULANCE AND GOT OUR
11 EQUI PMENT.
12 Q WHAT EQUI PMENT DI D YOU TAKE WI TH YOU?
13 A WE NORMALLY TAKE OUR GURNEY WI TH US, OUR
14 GURNEY BEI NG THE BED WI TH THE WHEELS ON I T. AND
15 SI TTI NG ON THERE I S OUR - - OUR STARTER KI T. I T' S
16 SI MI LAR TO A FI SHI NG TACKLE BOX, BUT I T HAS ALL OF OUR
17 MEDI CI NES, NEEDLES, THI NGS LI KE THAT.
18 THEN WE ALSO HAVE OUR OXYGEN KI T WI TH OUR
19 AI RWAY TOOLS AND THAT; AND THEN WE ALSO HAVE THE E. K. G.
20 MONI TOR, DEFI BRI LLATOR. AND THAT' S ALL ON THE GURNEY
21 SO WE CAN J UST - - AS SOON AS WE STOP, THE DOORS COME
22 OPEN, THE GURNEY COMES OUT AND AWAY WE GO.
23 Q WHO WAS THE FI RST PERSON I N YOUR CREWTO
24 ENTER THE HOME?
25 A I WAS, SI R.
26 Q WHAT DI D YOU DO UPON ENTERI NG I NTO THE
27 HOME?
28 A I WAS FOLLOWI NG A SECURI TY GUARD. WE WERE
866 299-5127
2276
1 PULLI NG THE GURNEY BEHI ND US. THERE WAS A LARGE FLI GHT
2 OF STAI RS; AND AS SOON AS WE SAWTHE STAI RS AND THE
3 GURNEY WASN' T GOI NG TO GO UP THERE QUI CKLY, I GRABBED
4 THE STARTER BOX, THE DRUG BOXES, AND GRABBED I T OFF THE
5 GURNEY AND WENT RI GHT UP THE STAI RS.
6 Q DI D YOU TAKE THE GURNEY UP THERE WI TH YOU?
7 A NO.
8 WE LEFT THE GURNEY AT THE BOTTOM OF THE
9 STAI RS.
10 Q AND WHO WENT UP THERE WI TH YOU?
11 A I WAS FOLLOWI NG A SECURI TY GUARD. BEHI ND
12 ME WAS ONE OF THE FI REFI GHTERS, BRETT HERON; AND THEN,
13 ALSO, FI REFI GHTER PARAMEDI C MARTI N BLUNT; FI REFI GHTER
14 PARAMEDI C MARK GOODWI N; AND CAPTAI N J EFF MI LLS.
15 MR. PANI SH: I WANT TO SHOWYOU EXHI BI T 51 ( SI C) ,
16 DASH, 21.
17 I F YOU CAN NOT PUT I T - - J UST SHOWI T TO
18 THE WI TNESS, PLEASE.
19 CAN YOU I DENTI FY THAT WHEN I T COMES UP?
20 MS. CAHAN: I T' S NOT ON COUNSEL' S SCREEN.
21 MR. PANI SH: THERE I T I S.
22 MS. CAHAN: I T' S 500, DASH, 21?
23 MR. PANI SH: YES.
24 Q HAVE YOU SEEN THAT LOCATI ON BEFORE?
25 A YES, SI R, I HAVE.
26 Q WHAT I S THAT LOCATI ON?
27 A I T' S THE BEDROOM AT THE I NCI DENT WE' RE
28 DI SCUSSI NG.
866 299-5127
2277
1 Q OKAY. DOES THAT TRULY AND ACCURATELY
2 DEPI CT, GENERALLY SPEAKI NG, THE SCENE?
3 A YES, I T DOES.
4 MR. PANI SH: I ' D LI KE TO SHOWTHAT, YOUR HONOR.
6 MR. PANI SH: ALL RI GHT.
7 Q NOW, I S THI S THE BEDROOM THAT YOU RESPONDED
8 TO?
9 A YES, SI R, I T I S.
10 Q WHAT' S THE FI RST THI NG YOU SAWWHEN YOU
11 WALKED I NTO THE BEDROOM? WELL, STRI KE THAT.
12 WERE YOU WALKI NG? HURRYI NG? HOWWERE
13 YOU - - HOWWOULD YOU DESCRI BE YOUR MODE OF MOVI NG?
14 A I WAS CARRYI NG THE EQUI PMENT, AND WE HAD TO
15 GO UP THE STAI RS, AND EVERYONE WAS I N QUI TE A HURRY.
16 I , FOR LACK OF A BETTER TERM, GALLOPED.
17 Q WHAT DI D YOU SEE WHEN YOU GOT I NTO THE
18 ROOM?
19 A CAME I NTO THAT FRONT DOOR THERE, AND I SAW
20 WHO I LATER FOUND OUT TO BE DR. MURRAY AND A SECURI TY
21 GUARD AND A PATI ENT LAYI NG ON THE BED.
22 Q WHERE DI D YOU SEE DR. MURRAY?
23 A DR. MURRAY WAS ON THE FAR SI DE OF THE BED
24 NEAR THE NI GHTSTAND.
25 MR. PANI SH: I ' M GOI NG TO GI VE YOU - - MAY I
26 APPROACH THE WI TNESS, YOUR HONOR?
28 MR. PANI SH: I ' M GOI NG TO HAND YOU A LASER
866 299-5127
2278
1 POI NTER. BE CAREFUL. I T GOES LI KE THAT.
2 I F YOU COULD PLEASE I NDI CATE FOR US WHERE
3 DR. MURRAY WAS LOCATED WHEN YOU ENTERED THE ROOM.
4 THE WI TNESS: I N THI S AREA RI GHT I N HERE.
5 MR. PANI SH: I S THAT - - AM I NOT SEEI NG I T, OR I S
6 I T - -
7 THE COURT: I T' S VERY DI M.
8 MR. BOYLE: THERE I T I S.
9 MR. PANI SH: WHERE I S I T?
10 THE WI TNESS: I ' LL SHI NE I T OVER HERE, AND ON
11 THE - - WE' LL TRY - - I T WORKS BETTER THERE.
12 MR. PANI SH: WHY I S I T WORKI NG THERE?
13 Q ALL RI GHT. ANYWAY, SO SHOW- - YOU' RE
14 I NDI CATI NG NOW- - I WOULD SAY - - DOES THAT LOOK LI KE A
15 NI GHTSTAND?
16 A YES, SI R, THERE' S A NI GHTSTAND RI GHT HERE.
17 Q AND THERE LOOKS LI KE SOME KI ND OF BED LAMP
18 OR SOMETHI NG THERE?
19 A YES, SI R.
20 Q AND DR. MURRAY, WHAT WAS HE, STANDI NG? HOW
21 WAS HE POSI TI ONED?
22 A HE WAS LEANI NG OVER THE PATI ENT. HE WAS - -
23 THE PATI ENT WAS LAYI NG RI GHT ACROSS HERE; THE PATI ENT' S
24 HEAD WAS, OF COURSE, AT THE PI LLOW; AND DR. MURRAY WAS
25 STANDI NG RI GHT THERE NEXT TO THE PATI ENT AT THE HEAD OF
26 THE PATI ENT.
27 Q WHAT WAS HE DOI NG AT THAT TI ME?
28 A HE WAS MOVI NG THE PATI ENT.
866 299-5127
2279
1 Q PLEASE DESCRI BE WHAT YOU SAW.
2 A THE SECURI TY GUARD WAS STANDI NG NEXT TO
3 DR. MURRAY; AND TOGETHER, THE TWO OF THEM WERE MOVI NG
4 THE PATI ENT OFF THE BED ONTO THE FLOOR.
5 Q DI D YOU LEARN WHY HE WAS DOI NG THAT?
6 A WELL, WHEN I WALKED I N, I ' D ALREADY BEEN
7 TOLD THAT I T' S A CARDI AC ARREST, AND I - - I DI DN' T ASK
8 HI M WHY, BUT WE DON' T LI KE TO DO C. P. R. ON BEDS. I T' S
9 VERY I NEFFI CI ENT. WE DO C. P. R. ON FLOORS ALL THE TI ME.
10 SO I PRESUME THEY WERE MOVI NG HI M ONTO THE FLOOR TO DO
11 C. P. R.
12 Q OKAY. THI S DR. MURRAY, DI D YOU I DENTI FY
13 YOURSELF TO HI M? WERE YOU WEARI NG A UNI FORM LI KE YOU
14 ARE NOW?
15 A NO, SI R. THI S I S OUR DRESS UNI FORM FOR
16 SPECI AL OCCASI ONS.
17 Q WHAT KI ND OF UNI FORM WERE YOU WEARI NG THEN?
18 I T LOOKS GOOD, BUT WHAT KI ND OF - - WHAT KI ND OF UNI FORM
19 WERE YOU WEARI NG THEN?
20 A I WAS - - STANDARD FI REFI GHTER UNI FORM; NAVY
21 BLUE NOMEX PANTS, NAVY BLUE SHI RT, BLACK BUTTONS,
22 BADGE.
23 Q WOULD MOST PEOPLE SAY, " HEY, THAT' S A
24 FI REFI GHTER" ?
25 A YES, SI R.
26 Q ALL RI GHT. DI D YOU ADDRESS DR. MURRAY?
27 A YES, SI R.
28 Q WHAT DI D YOU SAY?
866 299-5127
2280
1 A I LOOKED - - I - - THE FI RST THI NG I SAI D TO
2 HI M WAS, " DOES THE PATI ENT HAVE A D. N. R. ?"
3 Q WHAT' S A D. N. R. ?
4 A A D. N. R. I S AN ADVANCED HEALTHCARE
5 DI RECTI VE, SHORT - - DO NOT RESUSCI TATE ORDER. WHEN I
6 FI RST WALKED I N, I SAWTHE MEDI CAL EQUI PMENT THERE, AND
7 I SAWTHE PATI ENT, AND I THOUGHT PERHAPS THI S WAS A
8 HOSPI CE PATI ENT.
9 Q WHAT' S A - - WHAT DO YOU MEAN, YOU THOUGHT
10 I T WAS A HOSPI CE PATI ENT?
11 A WELL, THE TYPE OF PATI ENTS WHO ARE AT THE
12 END STAGE OF A LONG- TERM I LLNESS, WHATEVER THE CAUSE,
13 WHO HAVE COME HOME TO DI E I N THE COMFORT OF THEI R HOME,
14 THEY WI LL HAVE A DO NOT RESUSCI TATE ORDER BECAUSE WHEN
15 THEY FI NALLY DO PASS, THEY DON' T WANT ANYBODY PUSHI NG
16 ON THEI R CHEST AND DOI NG ALL THE OTHER THI NGS BECAUSE
17 I T' S OVER.
18 Q SO THI S BASI CALLY I S SOMETHI NG THAT
19 BEFORE - - SOME PEOPLE, BEFORE THEY DI E, WRI TE OUT
20 I NSTRUCTI ONS OF HOWTHEY SHOULD BE DEALT WI TH I N THE
21 CASE OF CLOSE TO THE DEATH?
22 A YES, SI R.
23 Q AND DI D YOU SEE THE PATI ENT AT THAT TI ME?
24 A I COULD SEE THE PATI ENT, YES, SI R.
25 Q DESCRI BE WHAT YOU SAW.
26 A I SAWA PATI ENT WEARI NG PAJ AMAS, PAJ AMA
27 PANTS, A PAJ AMA SHI RT THAT WAS UNBUTTONED, AND SOME
28 SORT OF SURGI CAL- TYPE CAP COVERI NG THE WHOLE HEAD. THE
866 299-5127
2281
1 PATI ENT LOOKED VERY PALE, VERY, VERY UNDERWEI GHT. I
2 COULD SEE RI BS. THE PATI ENT LOOKED VERY I LL.
3 Q I S THAT WHY YOU THOUGHT THI S WAS SOMEBODY
4 THAT HAD SUFFERED FROM CANCER OR SOMETHI NG AND WAS
5 ABOUT TO DI E?
6 A YES, SI R.
7 Q BASED ON THE CONDI TI ON OF THE I NDI VI DUAL
8 THAT YOU SAW, I T WAS YOUR FI RST I MPRESSI ON THAT THI S
9 PERSON WAS A CANCER VI CTI M OR - - OR PATI ENT?
10 A OR ANY NUMEROUS CHRONI C DI SEASES. MY FI RST
11 I MPRESSI ON WAS YES, THI S I S A HOSPI CE PATI ENT, AND
12 THAT' S WHY MY FI RST WORDS TO THE GENTLEMAN STANDI NG
13 THERE WERE, " I S THERE A D. N. R. ?"
14 Q DI D YOU EVER LEARN WHETHER OR NOT THERE WAS
15 A D. N. R. ?
16 A THEY - - DR. MURRAY LOOKED AT ME AND SAI D,
17 " WHAT?"
18 I ' M SORRY. HE LOOKED AT ME BLANKLY FI RST;
19 AND I SAI D, " DO NOT RESUSCI TATE ORDER? ADVANCED
20 HEALTHCARE DI RECTI VE?"
21 AND HE SAI D, " NO, NO. THI S J UST HAPPENED. "
22 Q OKAY. NOW, HOWWOULD YOU DESCRI BE THE LOOK
23 ON DR. MURRAY' S FACE WHEN YOU FI RST SAWHI M?
24 A FRANTI C. HE WAS - - HE WAS PALE, HE WAS
25 SWEATI NG, HE WAS VERY BUSY.
26 Q NOW, DI D YOU EVER - - DI D YOU KNOWTHAT HE
27 WAS A DOCTOR AT ANY TI ME ON THAT - -
28 A HE I DENTI FI ED HI MSELF AS A CARDI OLOGI ST.
866 299-5127
2282
1 Q DI D YOU THI NK THAT WAS UNUSUAL?
2 A I ' VE - - I ' VE BEEN DOI NG THI S FOR MANY
3 YEARS; BUT EVEN I N BEL AI R, I T' S UNUSUAL TO HAVE THE
4 PERSONAL PHYSI CI AN AT THE HOUSE. I T DOES HAPPEN ON
5 OCCASI ON, BUT TO HAVE THE DOCTOR THERE I N THE HOUSE I S
6 UNUSUAL.
7 Q DO YOU KNOWWHAT DR. MURRAY' S RELATI ONSHI P
8 WAS WI TH MR. J ACKSON?
9 A NO, SI R.
10 Q DO YOU KNOWWHO HE WAS WORKI NG FOR,
11 ANYTHI NG LI KE THAT?
12 A NO, SI R.
13 Q DO YOU KNOWWHETHER HE TREATED MR. J ACKSON
14 BEFORE, OR NOT TREATED HI M?
15 A NO, SI R.
16 Q THAT WASN' T SOMETHI NG YOU GOT CONCERNED
17 WI TH?
18 A NO, SI R.
19 Q OKAY. SO THEN WHAT - - WHAT DI D YOU DO?
20 A I - - AT THAT POI NT, BRETT HERON, THE
21 FI REFI GHTER, AND I MOVED OVER TO THE SI DE OF THE BED OR
22 THE FLOOR WHERE THE PATI ENT WAS LAYI NG. AND THAT' S A
23 SMALL AREA I N THERE. YOU CAN SEE THERE' S CHAI RS,
24 NI GHTSTANDS, THOSE SORT OF THI NGS.
25 THERE' S NO ROOM FOR US TO WORK, SO WE MOVED
26 THE PATI ENT OVER HERE TO THE FOOT OF THE BED, I NTO THE
27 OPEN AREA. THE PATI ENT' S FEET WERE LAYI NG HERE, THE
28 PATI ENT' S HEAD WAS ON THI S END HERE.
866 299-5127
2283
1 Q NOW, I N THE COURSE OF YOUR 28 YEARS YOU' VE
2 RESPONDED TO SCENES LI KE THI S, HAVE YOU SEEN PATI ENTS
3 THAT LOOK HEALTHY?
4 A YES, SI R.
5 Q THAT J UST FOR SOME REASON, THERE' S
6 SOMETHI NG WRONG WI TH THEM, BUT THEY LOOK LI KE THEY' RE
7 HEALTHY?
8 A YES, SI R.
9 Q AND SOME YOU' VE SEEN THAT LOOK VERY
10 UNHEALTHY?
11 A YES, SI R.
12 Q THI S PATI ENT, WAS THI S PATI ENT LOOKI NG, TO
13 YOU, VERY HEALTHY? UNHEALTHY? HOWWAS THI S PATI ENT?
14 A I S THERE A CHOI CE AFTER " VERY UNHEALTHY" ?
15 Q HOWWOULD YOU DESCRI BE I T? DYI NG? GAUNT?
16 A WELL, AGAI N, TO ME, HE LOOKED LI KE SOMEONE
17 WHO WAS AT THE END STAGE OF A - - OF A LONG DI SEASE
18 PROCESS.
19 Q DI D YOU EVER CHANGE YOUR OPI NI ON OF THAT?
20 A NO, SI R.
21 Q ALL RI GHT. NOW, WHAT DI D YOU SEE I N THE
22 ROOM?
23 STRI KE THAT. I T WAS A BAD QUESTI ON.
24 DI D YOU SEE ANYTHI NG I N THE ROOM THAT YOU
25 THOUGHT WAS UNUSUAL?
26 A YES, SI R.
27 Q WHAT DI D YOU SEE THAT YOU FELT WAS UNUSUAL?
28 A AN I . V. POLE AND AN I . V. BAG ON THE POLE.
866 299-5127
2284
1 Q WHAT' S AN I . V. POLE AND BAG?
2 A WHENEVER YOU GO I N THE HOSPI TAL, OF COURSE,
3 YOU' VE ALL SEEN I . V. POLES NEXT TO A BED, AND THEN
4 THERE' S A BAG THERE, AND THE BAG USUALLY HAS A CLEAR
5 SOLUTI ON OF SOME SORT, SALI NE, THAT GOES THROUGH A TUBE
6 I NTO YOUR ARM. AND THAT' S WHAT I SAW.
7 Q DI D YOU SEE ANYTHI NG ELSE I N THERE?
8 A AN OXYGEN TANK.
9 Q WHAT ELSE?
10 A THAT' S - - MEDI CAL - - I ALSO SAWON THE
11 NI GHTSTAND THERE WERE MEDI CATI ON BOTTLES.
12 Q DI D THE PATI ENT LOOK LI KE THEY WERE
13 NOURI SHED? UNDERNOURI SHED? MALNOURI SHED? HOWWOULD
14 YOU DESCRI BE THEM?
15 A THE PATI ENT LOOKED UNDERWEI GHT TO ME.
16 Q DI D I T APPEAR TO YOU WHETHER THE PATI ENT
17 HAD J UST BECOME I LL OR HAD BEEN CHRONI CALLY I LL?
18 A THE PATI ENT APPEARED TO BE CHRONI CALLY I LL
19 TO ME.
20 MR. PANI SH: I WANT TO SHOWYOU FI RST, J UST
21 YOU - - I S THAT 21 - - I CAN' T SEE THAT FAR.
22 THE COURT: YES, 500, DASH, 21.
23 MR. PANI SH: I ' D LI KE TO SHOWYOU 500, DASH, 39.
24 DON' T PUT I T UP ON THE SCREEN, J UST SHOW
25 THE COUNSEL AND THE WI TNESS FI RST.
26 Q OKAY. NOW, I S THAT A PI CTURE DEPI CTI NG THE
27 SCENE LI KE OR SOMEWHAT LI KE WHAT I T WAS AT THAT TI ME?
28 A YES, SI R.
866 299-5127
2285
1 Q ALL RI GHT. LET' S PUT THAT UP.
2 CAN YOU POI NT OUT THE I . V. BOTTLE?
3 A YES, SI R.
4 THI S WOULD BE THE POLE; AND AT THE TOP OF
5 THE POLE, THERE' S A BAG RI GHT HERE. THAT WOULD BE THE
6 I . V. BAG.
7 Q OKAY. AND WHAT ARE THOSE BOTTLES OR TANKS
8 ON THE GROUND?
9 A THOSE ARE OXYGEN CYLI NDERS.
10 Q DO YOU KNOWWHAT THOSE ARE USED FOR?
11 A YES, SI R.
12 THOSE STORE OXYGEN.
13 Q DI D YOU SEE ANY VENTI LATORS OR - - OR HEART
14 MONI TORS?
15 A I DI D NOT.
16 Q I WANT TO SHOWYOU 500, DASH, 55.
17 DO YOU SEE THAT?
18 A YES, SI R.
19 Q AND LET ME SHOWTHAT, PLEASE.
20 AND I S THAT THE BEDSI DE TABLE?
21 A YES, SI R.
22 Q AND THERE ARE PI LL BOTTLES THERE?
23 A YES, SI R.
24 Q A GLASS OF WATER, LOOKS LI KE SOME J UI CE - -
25 OR NOT A GLASS OF WATER. I ' M SORRY. A BOTTLE - - I
26 GUESS - - I S THAT A BOTTLE OF WATER? BLOWTHAT UP A
27 LI TTLE, PLEASE. MAYBE I ' M J UST NOT SEEI NG - - LI KE FI J I
28 WATER, OR SOMETHI NG?
866 299-5127
2286
1 DO YOU KNOWWHAT THAT WAS?
2 A I DON' T KNOWWHAT THAT I S, SI R.
3 Q FAI R ENOUGH.
4 I T LOOKS LI KE THERE' S SOME KI ND OF NAKED
5 J UI CE OR SOMETHI NG.
6 HAVE YOU EVER HEARD OF THAT?
7 A YES, SI R. I T COMES FROM MY HOMETOWN. THE
8 FACTORY I S I N MY HOMETOWN.
9 Q WHAT' S YOUR HOMETOWN?
10 A GLENDORA, CALI FORNI A.
11 Q OKAY. OFF THE 210?
12 A YES.
13 Q ALL RI GHT. DI D YOU - - WERE YOU ABLE TO
14 I DENTI FY WHO THE PERSON WAS I N THE BED?
15 A I NI TI ALLY, NO; BUT AS THE CALL PROGRESSED,
16 SOMEONE MENTI ONED HI S NAME, AND THEN I LOOKED AND WENT,
17 " YES, I T I S. "
18 Q AND WHO DI D THEY TELL YOU THAT I T WAS?
19 A MI CHAEL J ACKSON.
20 Q HAD YOU SEEN ANY PHOTOGRAPHS OR SEEN
21 MR. J ACKSON, AT LEAST, BEFORE COMI NG THERE?
22 A YES, SI R, OF COURSE.
23 Q WERE YOU ABLE TO RECOGNI ZE HI M I N THAT
24 CONDI TI ON?
25 A YES. ONCE SOMEONE SAI D HI S NAME AND I
26 ACTUALLY LOOKED AT THE PATI ENT' S FACE, YES, I WAS ABLE
27 TO.
28 Q BEFORE THAT, YOU WEREN' T?
866 299-5127
2287
1 A NO, SI R.
2 Q NOW, DI D YOU TRY TO DETERMI NE WHAT, I F ANY,
3 MEDI CAL TREATMENT HAD BEEN PROVI DED TO MR. J ACKSON
4 PRI OR TO ARRI VI NG?
5 A I ' M SORRY, SI R. COULD YOU - -
6 Q CERTAI NLY.
7 AS A PARAMEDI C, WHEN YOU COME ON THE SCENE,
8 ARE YOU TRYI NG TO GATHER I NFORMATI ON?
9 A YES, SI R.
10 Q WHY DO YOU DO THAT?
11 A BECAUSE WE WANT TO KNOWWHAT WE' RE DEALI NG
12 WI TH SO WE KNOWWHAT THE APPROPRI ATE TREATMENT I S.
13 ALSO, NOT ONLY THE TREATMENT, BUT WE' RE NOT DOCTORS.
14 WE ARE THE EYES AND EARS FOR THE DOCTORS AT THE
15 HOSPI TAL. WHEN I CALL UP THE HOSPI TAL, I WANT TO GI VE
16 THEM AN ACCURATE REPORT SO THAT THEY KNOWWHAT THE
17 APPROPRI ATE TREATMENT I S, AND THEN ORDER ME TO DO THAT
18 TREATMENT.
19 Q DI D YOU TRY TO FI ND OUT WHAT TREATMENT
20 WOULD HAVE BEEN PROVI DED, I F ANY, BEFORE YOU ARRI VED?
21 A YES, SI R, I DI D.
22 Q WHAT DI D YOU DETERMI NE?
23 A WHEN I WALKED I N THE ROOM, I SAWTHAT THERE
24 WAS AN I . V. POLE, I SAWTHAT THERE WERE MEDI CATI ONS ON
25 THE NI GHTSTAND, I SAWTHAT THE DOCTOR WAS THERE, SO I
26 ASKED WHAT HI S UNDERLYI NG CONDI TI ON WAS, WHAT HI S
27 MEDI CAL HI STORY WAS.
28 AT THAT POI NT, THE DOCTOR SAI D, " NOTHI NG, "
866 299-5127
2288
1 AND SOMETHI NG TO THE EFFECT OF - - I COULDN' T - - I
2 COULDN' T QUI TE UNDERSTAND WHAT HE SAI D, BUT THEN " 16
3 HOURS LAST NI GHT. I ' M J UST TREATI NG HI M FOR
4 DEHYDRATI ON AND EXHAUSTI ON. "
5 Q HAVE YOU EVER SEEN PEOPLE THAT WERE
6 DEHYDRATED AND EXHAUSTED BEFORE?
7 A YES, SI R.
8 Q OFTEN?
9 A REGULARLY, SI R.
10 Q DI D I T APPEAR TO YOU, BASED ON YOUR
11 TRAI NI NG AND EXPERI ENCE, THAT MR. J ACKSON WAS SUFFERI NG
12 FROM DEHYDRATI ON OR EXHAUSTI ON?
13 A NO, SI R, I T DI D NOT ADD UP.
14 Q WHY NOT?
15 A DEHYDRATI ON AND EXHAUSTI ON I S RELATI VELY
16 MI LD. YOU REST AND PUT SOME FLUI D BACK I NTO YOU, A FEW
17 BAGS. BUT YOU' RE NOT UNDERWEI GHT, YOU' RE NOT PALE LI KE
18 THAT. I T' S - - I T J UST LOOKED LI KE I T WAS MUCH MORE
19 COMPLI CATED THAN DEHYDRATI ON AND EXHAUSTI ON.
20 Q DI D YOU TRY TO DETERMI NE WHETHER OR NOT - -
21 STRI KE THAT.
22 WHEN YOU ARRI VE AT A SCENE LI KE THI S, DO
23 YOU TRY TO FI ND OUT WHETHER OR NOT THE PATI ENT HAD BEEN
24 TAKI NG ANY MEDI CATI ON?
25 A YES, SI R, OF COURSE I DO.
27 A MEDI CATI ON I S A BI G PART OF HI STORY. I
28 WANT TO KNOWWHAT YOUR HI STORY I S, AND I WI LL ASK
866 299-5127
2289
1 DI FFERENT QUESTI ONS DI FFERENT WAYS. I CAN ASK SOME
2 PEOPLE QUI TE SI MPLY, " DO YOU HAVE HI GH BLOOD PRESSURE?"
3 AND THEY WOULD, OF COURSE, SAY, " NO, I
4 DON' T. "
5 THEN I NEED TO FOLLOWTHAT UP WI TH, " DO YOU
6 TAKE HI GH BLOOD PRESSURE MEDI CATI ON?"
7 THEY SAY, " WELL, YES, I DO. " BECAUSE I N
8 THEI R MI ND, THEY DON' T HAVE A PROBLEM BECAUSE THEY TAKE
9 THE MEDI CATI ON. SO MEDI CATI ON I S ANOTHER WAY TO ASK
10 HI STORY QUESTI ONS.
11 Q DI D YOU TRY TO FI ND OUT WHETHER MR. J ACKSON
12 HAD BEEN TAKI NG ANY MEDI CATI ON?
14 Q WHAT DI D YOU DETERMI NE?
15 A ACCORDI NG TO DR. MURRAY, NO, HE WAS NOT.
16 Q DI D DR. MURRAY SAY ANYTHI NG ABOUT
17 MR. J ACKSON USI NG ANY PROPOFOL?
18 A NO, SI R.
19 Q DI D DR. MURRAY - - OR DI D YOU LEARN FROM HI M
20 TELLI NG YOU ANYTHI NG ABOUT THAT MR. J ACKSON HAD J UST
21 GOT I N THI S CONDI TI ON, OR HE HAD BEEN I N THI S CONDI TI ON
22 FOR A PERI OD OF TI ME?
23 A BY " CONDI TI ON, " ARE YOU REFERRI NG TO
24 CARDI AC ARREST?
25 Q GOOD POI NT.
26 J UST HOWHE WAS THERE. I THI NK YOU SAI D - -
27 MENTI ONED THAT YOU WERE TOLD HE WAS SUFFERI NG FROM
28 DEHYDRATI ON AND EXHAUSTI ON.
866 299-5127
2290
1 A YES, SI R.
2 Q OKAY. AND YOU SAI D - - I THOUGHT YOU SAI D
3 SOMETHI NG LI KE J UST FOR MI NUTES, OR SOMETHI NG LI KE
4 THAT.
5 A WHEN I - - WHEN I WALKED I N THE ROOM AND
6 ESTABLI SHED THAT THERE WAS NO D. N. R. , I ' D ALREADY
7 RESPONDED TO A CARDI AC ARREST, SO I ' M ON THE ASSUMPTI ON
8 I T' S A CARDI AC ARREST. SO THEN MY NEXT FOLLOWUP
9 QUESTI ON I S, " WHEN DI D THI S HAPPEN?"
10 AND THE DOCTOR SAI D, " J UST NOW. "
11 Q J UST LI KE MI NUTES AGO?
12 A HE SAI D, " J UST NOW, RI GHT WHEN I CALLED
13 YOU. "
14 Q OKAY. AND DI D YOU EXAMI NE THE PATI ENT?
15 A I - - YES.
17 A WELL, WHEN WE MOVE THE PATI ENT OVER, YOU
18 CAN' T HELP BUT LOOK AT THEM. WHEN YOU' VE BEEN DOI NG
19 THI S FOR A WHI LE, YOU CAN WALK I N A ROOM AND HAVE A
20 REAL GOOD I DEA OF WHAT' S GOI NG ON WI TH A PATI ENT RI GHT
21 OFF THE BAT.
22 BUT YES, NATURALLY, WE' RE CHECKI NG FOR
23 PULSES, WE' RE CHECKI NG HI S HEART, WE' RE CHECKI NG HI S
24 EYES AND THI NGS LI KE THAT.
25 Q DI D HE HAVE A PULSE?
26 A NO, SI R, NO PULSE.
27 Q HOWWERE HI S EYES?
28 A HI S EYES - - HI S PUPI LS WERE FULLY DI LATED.
866 299-5127
2291
1 I N FACT, I T' S WHAT WE CALL FI XED AND DI LATED. AND HI S
2 EYES THEMSELVES WERE QUI TE DRY.
3 Q WHAT DOES THAT MEAN?
4 A TI ME HAD ELAPSED.
5 Q CAN YOU EXPLAI N?
6 A SURE.
7 YOUR EYES AREN' T DRY RI GHT NOWBECAUSE
8 YOU' RE CONTI NUOUSLY BLI NKI NG. BUT WHEN YOUR HEART - -
9 OR WHEN YOUR BODY' S LI FE STOPS, YOU' RE NOT MAKI NG
10 TEARS, YOU' RE NOT BLI NKI NG, AND AI R CI RCULATES ACROSS
11 YOUR OPEN EYES, AND THEY DRY OUT.
12 Q I S THAT A SI GN OF ANYTHI NG?
13 A I T' S A SI GN THAT SOME TI ME HAD ELAPSED THAT
14 THE PATI ENT HAD ARREST. TO US, I T DI DN' T MAKE SENSE
15 THAT I T HAD J UST HAPPENED.
16 Q DI D YOU TOUCH THE BODY OF MR. J ACKSON?
17 A YES, SI R.
18 WHEN I MOVED THE PATI ENT FROM THE SI DE OF
19 THE BED OUT TO THE FLOOR AT THE FOOT OF THE BED, I
20 LI FTED HI S LEGS; THUS, MY HANDS WERE TOUCHI NG HI S BARE
21 SKI N.
22 Q DI D YOU LEARN ANYTHI NG SI GNI FI CANT FROM
23 THAT?
24 A HI S SKI N WAS VERY COOL TO THE TOUCH.
25 Q WHAT - - WHAT DOES THAT MEAN TO A PARAMEDI C
26 FI REFI GHTER - - STRI KE THE QUESTI ON.
27 WHAT DOES THAT MEAN - - WHAT DI D THAT MEAN
28 TO YOU?
866 299-5127
2292
1 A WHAT THAT MEANT TO ME WAS THAT, AGAI N, TI ME
2 HAD ELAPSED.
3 Q ANY I DEA HOWMUCH TI ME? WAS I T A COUPLE OF
4 MI NUTES? HOURS? WHAT CAN YOU GI VE US ON THAT?
5 A WELL, WHEN I WALKED I N AND THE DOCTOR TOLD
6 ME THAT I T HAD J UST HAPPENED, I WAS ON THE ASSUMPTI ON
7 THAT I T HAD J UST HAPPENED AND THE PATI ENT HAD BEEN
8 LYI NG I N BED. WHEN I PI CKED HI M UP AND MOVED HI M, HE
9 WAS VERY COOL TO THE TOUCH. HOWMUCH TI ME? A LOT
10 LONGER THAN THE DOCTOR HAD ALLUDED TO.
11 I WOULD SAY LESS THAN AN HOUR; BUT HOWMUCH
12 LESS THAN AN HOUR, I ' D BE SPECULATI NG. BUT THE POI NT
13 BEI NG I S THAT YOUR BODY TEMPERATURE WHEN YOU' RE LAYI NG
14 I N BED DOESN' T GET COLD THAT FAST. I T TAKES A LI TTLE
15 BI T OF TI ME VERSUS I F I WAS TO FI ND YOU LAYI NG ON A
16 SI DEWALK SOMEWHERE.
17 Q COULD YOU - - WHY I S THAT?
18 A THE BED I S I NSULATED, I T WI LL PRESERVE YOUR
19 HEAT FOR A WHI LE.
20 Q COULD YOU TELL US WHETHER THERE WAS ANY
21 COLOR TO THE SKI N OF THE BODY?
22 A THE MAI N CORE OF THE BODY, MEANI NG THE
23 LEGS, THE - - THE TRUNK AND SUCH, WAS VERY PALE WHI TE.
24 THE HANDS, THE FEET, THE LI PS WERE TI NGED BLUE. WE
25 CALL THAT CYANOSI S.
26 Q CYANOSI S.
27 AND WHAT DOES THAT I NDI CATE, WHEN YOUR
28 LI PS, HANDS AND FEET ARE I N A BLUI SH COLOR?
866 299-5127
2293
1 A THAT YOU' VE NOT BEEN BREATHI NG, OR YOU' RE
2 NOT GETTI NG ENOUGH VENTI LATI ON.
3 Q DOES I T TAKE A PERI OD OF TI ME BEFORE THE
4 CYANOSI S DEVELOPS WHERE ONE CAN SEE I T?
5 A YOU CAN BE ALI VE AND BE VERY SHORT OF
6 BREATH AND END UP WI TH BLUE LI PS AND BLUE FI NGERNAI L
7 BEDS; BUT BY THE TI ME YOUR HANDS AND FEET START TURNI NG
8 BLUE, I T J UST TELLS ME THAT YOU' VE STOPPED BREATHI NG,
9 ANOTHER I NDI CATOR OF TI ME.
10 Q OKAY. I ' D LI KE TO GO BACK NOWTO
11 EXHI BI T 500, DASH, 39, WHERE YOU MADE SOME HANDWRI TTEN
12 NOTES, WHAT YOU CALLED YOUR SCRATCH PAD.
13 A YES, SI R.
14 Q I S THAT THE RI GHT NUMBER?
15 LET' S TRY 462, DASH, 9987. HOWI S THAT?
16 OKAY. WE COULD BLOWTHAT UP A LI TTLE BI T
17 NOW.
18 WE' VE GONE OVER THE TYPEWRI TTEN PORTI ON.
19 CAN YOU TELL US WHAT YOU WERE I NDI CATI NG WI TH YOUR
20 HANDWRI TTEN NOTES ON THE EXHI BI T I N FRONT OF YOU?
21 A YES, SI R.
22 WHEN I FI RST GOT TO THE PATI ENT, THAT' S THE
23 12: 26 RI GHT HERE. I WAS WONDERI NG WHAT HI S GLUCOSE
24 READI NG WOULD BE, HI S BLOOD SUGAR READI NG, SO THAT' S
25 " GLUCOSE" RI GHT THERE.
26 Q WHY DO YOU TAKE A GLUCOSE READI NG?
27 A WE PUNCTURE THEI R SKI N, PRI CK THEI R FI NGER
28 AND TAKE THE BLOOD SAMPLE OFF OF THAT AND PUT I T ON A
866 299-5127
2294
1 CHEM STRI P AND STI CK I T I NTO A LI TTLE MACHI NE, A METER,
2 THAT READS THE BLOOD SUGAR READI NG.
4 A WE' RE TRYI NG TO FI ND OUT WHY THI S PATI ENT
5 I S NOT RESPONDI NG. LOWBLOOD SUGAR CAN LEAD TO CARDI AC
6 ARREST, SO WE WANT TO FI ND OUT WHAT THE UNDERLYI NG
7 PROBLEM I S SO THAT WE CAN RECTI FY I T.
8 Q AND WHAT DI D YOU DETERMI NE? HOWDI D THAT
9 STACK UP, THE GLUCOSE?
10 A I DON' T HAVE I T I NDI CATED ON HERE. I ' D
11 HAVE TO LOOK ON ANOTHER FORM. I KNOWI ' VE WRI TTEN I T
12 DOWN HERE.
14 A ALL RI GHT. THE " EPI 3. 5, " THAT' S
15 EPI NEPHRI NE, WHI CH I S A TYPE OF ADRENALI NE. AS WE ALL
16 KNOW, WHEN YOU FEEL ADRENALI NE, YOUR HEART SPEEDS UP.
17 EPI NEPHRI NE, THAT' S WHAT I T I S. WE I NJ ECT I T. 3. 5 I S
18 A DOSE THAT WAS - - THAT WE HAD ORDERED.
19 12: 40 I S A TI ME THAT I J UST WROTE DOWN WHEN
20 I WAS ADMI NI STERI NG SOME EPI NEPHRI NE. A. L. L. E. G. I S
21 SHORT FOR ALLERGY. THAT WAS WHEN I FI RST WALKED I N THE
22 ROOM AND I ASKED THE DOCTOR WERE THERE ANY ALLERGI ES.
23 AND UNDERNEATH, THAT' S J UST SHORTHAND - - MY SHORTHAND
24 FOR THORAZI NE.
25 THE DOCTOR HAD I NDI CATED TO ME THE PATI ENT
26 WAS ALLERGI C TO THORAZI NE. WHEN I FI RST CONTACTED THE
27 HOSPI TAL, TO THE RI GHT, WHERE I T SAYS " EPI " AND
28 " ATROPI NE, " THAT WAS THE I NI TI AL ORDERS THAT THE
866 299-5127
2295
1 HOSPI TAL SAI D, GI VE HI M EPI AND GI VE HI M ATROPI NE.
2 ATROPI NE I S ANOTHER THI NG TO HELP THE HEART SPEED UP.
3 Q WHAT HOSPI TAL DI D YOU CONTACT?
4 A I CONTACTED U. C. L. A.
5 Q OKAY. THAT' S I N WESTWOOD?
6 A THAT' S I N WESTWOOD, YES, SI R.
7 Q PLEASE CONTI NUE.
8 A SURE.
9 DOWN BELOWI N THI S BOX, I WROTE " H. Y. D. "
10 THAT WAS SHORT FOR HYDRATI ON, WHEN THE DOCTOR TOLD ME
11 HE WAS TREATI NG HI M FOR DEHYDRATI ON. " LORAZEPAM. "
12 WHEN I ASKED THE DOCTOR I F HE WAS TAKI NG ANY
13 MEDI CATI ONS, THE DOCTOR I NDI CATED HE HAD GI VEN HI M A
14 LI TTLE BI T OF LORAZEPAM.
15 Q ANY I NDI CATI ON WHY THAT WAS GI VEN?
16 A TO HELP HI M SLEEP. LORAZEPAM I S COMMONLY
17 KNOWN AS ATI VAN. YOU MAY HAVE SEEN THAT.
18 AND DOWN BELOW, WHERE I T SAYS " SECOND, "
19 THAT' S " SECOND BI CARB. " SODI UM BI CARBONATE I S ONE OF
20 THE MEDI CATI ONS WE GI VE I N THE FI ELD. WHEN SOMEONE HAS
21 BEEN DOWN FOR A WHI LE, LACTI C ACI D BUI LDS UP I N YOUR
22 CELLS, AND YOU BEGI N TO HAVE A HI GH ACI D LEVEL I N YOUR
23 BLOOD STREAM, AND THAT' S NOT COMPATI BLE WI TH YOUR HEART
24 WORKI NG, SO WE GI VE THAT TO COUNTERACT THE ACI D LEVEL.
25 I T' S A BASE.
26 THE TI ME BELOWTHAT ACTUALLY SAYS 1400, AND
27 THAT' S MY MI STAKE. I T SHOULD SAY 1300. I T' S J UST THE
28 E. K. G. MACHI NE HAS A CLOCK ON I T, AND THE CLOCK WAS
866 299-5127
2296
1 OFF.
2 Q OKAY. I F WE COULD J UST LOOK DOWN AT THE
3 BOTTOM NOW?
4 A SURE.
5 Q THOSE ARE ALSO YOUR NOTES?
6 A YES, SI R.
7 THOSE ARE OUR TI MES
8 Q OKAY. WHAT DO YOU MEAN, OUR TI MES?
9 A WELL, 12: 22 I S WHEN WE WERE DI SPATCHED;
10 12: 23 I S WHEN I ' M ROLLI NG DOWN THE STREET; 12: 25 I S
11 WHEN I PARKED I N FRONT OF THE BUI LDI NG; AND 1307 I S
12 WHEN WE LEFT THE HOME TO TRANSPORT TO THE HOSPI TAL; AND
13 1313 I S WHEN I ARRI VED AT THE HOSPI TAL.
14 Q DOES O. N. S. MEAN " ON THE SCENE" - - " ON
15 SCENE" ?
16 A " ON SCENE, " YES, SI R.
17 Q T. S. P. , " TRANSPORT" ?
18 A YES, SI R.
19 Q H. S. P. , " HOSPI TAL" ?
20 A YES, SI R.
21 Q AND I T SAYS " MI CHAEL" ?
22 A YES, SI R.
23 Q I S THAT REFERRI NG TO MR. J ACKSON?
24 A YES, SI R.
25 Q AND THEN WHAT ELSE DO YOU - -
26 A WELL, UNDERNEATH, I T SAYS " CAPNOGRAPHY. "
27 Q WHAT I S THAT?
28 A I WAS - - WHI LE I ' M WORKI NG, I WAS THE LEAD
866 299-5127
2297
1 MEDI C AT THE I NCI DENT, SO I ' M COORDI NATI NG ALL THE
2 ACTI ONS THAT ARE GOI NG ON, AND I ' M THI NKI NG ABOUT
3 THI NGS. AND ONE OF THE THI NGS I HAD THOUGHT ABOUT WAS
4 WHAT THE CAPNOGRAPHY WAS. SO THAT WAS A NOTE I WROTE
5 TO MYSELF TO ASK THE OTHER MEDI CS WHO WERE WORKI NG
6 ABOUT THE CAPNOGRAPHY.
7 Q OKAY.
8 A AND I CAN EXPLAI N CAPNOGRAPHY I F YOU WANT.
9 Q YOU' RE ANTI CI PATI NG MY NEXT QUESTI ON.
10 A OKAY. YOU I NHALE OXYGEN, YOU EXHALE CARBON
11 DI OXI DE. WE ALL DO THAT. SO YOUR CELLS REALLY I NHALE
12 THE OXYGEN, AND YOUR CELLS PUT OUT THE CARBON DI OXI DE
13 BECAUSE YOUR CELLS ARE HEALTHY.
14 SO WHEN WE PUT A TUBE I NTO YOUR LUNGS TO
15 BREATHE FOR YOU, J UST LI KE YOU SEE I N ALL THE MOVI ES,
16 OR I F YOU HAVE A SURGERY, WE PUT A TUBE I NTO YOUR LUNGS
17 AND WE BREATHE FOR YOU WI TH OUR BAG AND WE SQUEEZE THE
18 BAG. NOW, WE HAVE TO KNOWFOR SURE AND FOR CERTAI N
19 WHETHER THAT TUBE I S I N THE RI GHT PLACE OR NOT.
20 I T' S EASY TO PUT THE TUBE I NTO THE STOMACH
21 ACCI DENTALLY. I T' S EASY TO PUT THE TUBE J UST I NTO THE
22 RI GHT SI DE OF THE LUNG ACCI DENTALLY. WE WANT TO MAKE
23 SURE I T' S I N THE RI GHT PLACE SO BOTH LUNGS GET THE
24 MAXI MUM AMOUNT OF AI R.
25 SO BY HAVI NG THE CAPNOGRAPHY DEVI CE THERE,
26 I T ALLOWS US TO SEE WHAT THE NUMBERS ARE. THE
27 CAPNOGRAPHY MEASURES THE CO2 THAT' S EXI TI NG YOUR BODY
28 THAT YOUR CELLS ARE EXHAUSTI NG. THEY SUCK I N THE
866 299-5127
2298
1 OXYGEN, THEY EXHAUST CARBON DI OXI DE. CAPNOGRAPHY
2 MEASURES THAT CARBON DI OXI DE.
3 Q OKAY. WHAT' S THE NEXT QUESTI ON?
4 ANY SI GNI FI CANCE I N THI S CASE RELATED TO
5 THE CAPNOGRAPHY?
6 A I WOULD HAVE TO LOOK AT MY OTHER REPORT
7 FORMS.
8 Q OKAY. WHY DON' T WE FI NI SH THI S PAGE AND
9 THEN WE' LL MOVE ON.
10 THE NUMBERS ARE WHAT, I F YOU KNOW?
11 A ACTUALLY, I DON' T RECALL WHAT THAT NUMBER
12 I S THERE.
13 Q AND HOWABOUT " CONTI NUE" ? DO YOU REMEMBER
14 WHAT THAT WAS FOR?
15 A YES, SI R.
16 WHEN WE I NI TI ALLY GOT ON SCENE, WE DI D OUR
17 I NI TI AL FI RST EFFORTS. WE PLACED THE TUBE I NTO THE
18 PATI ENT' S LUNGS TO BREATHE FOR HI M, WE STARTED DOI NG
19 C. P. R. , WE CHECKED HI S HEART, WE DO ALL THE THI NGS THAT
20 YOU DO TO SAVE SOMEONE' S LI FE.
21 AND THEN WE GAVE OUR FI RST DRUGS, OUR
22 ADRENALI NE, OUR EPI NEPHRI NE AND OUR ATROPI NE TO SPEED
23 THE HEART UP. AND THEN WE CI RCULATE THAT AROUND.
24 AFTER ABOUT FI VE MI NUTES OR SO, WE GI VE SOME MORE
25 DRUGS, WE CHECK EVERYTHI NG, AND WE SEE WHETHER THERE' S
26 BEEN ANY - - ANY LI FE COMI NG BACK.
27 AT THI S POI NT, I T' S - - THERE WASN' T ANY
28 LI FE COMI NG BACK, SO I NOTI FI ED THE HOSPI TAL WHAT WAS
866 299-5127
2299
1 GOI NG ON. AGAI N, I ' M REPORTI NG FOR THEM. AND WE' RE
2 MAKI NG THE DECI SI ON WHETHER WE' RE GOI NG TO CONTI NUE THE
3 LI FE- SAVI NG EFFORT OR TO STOP AT THI S POI NT BECAUSE I T
4 WAS FUTI LE. SO THEY SAI D CONTI NUE, SO I WROTE
5 " CONTI NUE" ON MY FORM.
6 Q DI D YOU THI NK THERE WAS ANY CHANCE AT THAT
7 TI ME?
8 A NO, SI R.
9 Q BUT YOU WERE FOLLOWI NG DI RECTI ONS?
10 A YES, SI R.
11 MR. PANI SH: I ' D LI KE TO I DENTI FY FOR THE RECORD
12 EXHI BI T 506 ( SI C) , DASH, 6 AND DASH, 8, L. A. FI RE
13 DEPARTMENT E. M. S. REPORT. 408- 789 I S THE
14 I DENTI FI CATI ON.
15 Q SI R, DI D YOU PREPARE - -
16 I F WE COULD J UST SHOWTHE FI RST PAGE TO THE
17 WI TNESS AND COUNSEL.
18 DI D YOU - -
19 THE COURT: WAI T. THI S I S 507, DASH, 6?
20 MR. PANI SH: YES, YOUR HONOR.
21 THE COURT: ALL RI GHT.
22 Q BY MR. PANI SH: DI D YOU AUTHOR THI S?
24 Q I S THAT A REGULAR BUSI NESS RECORD THAT' S
25 MADE I N THE COURSE OF WORK FOR THE LOS ANGELES FI RE
26 DEPARTMENT AT OR NEAR THE TI ME OF THE EVENT?
27 A YES, SI R.
28 MR. PANI SH: I F YOU' D TAKE A LOOK AT 507, DASH,
866 299-5127
2300
1 8.
2 I F WE COULD SHOWTHAT TO THE WI TNESS.
3 Q DI D YOU ALSO DO THI S?
4 A YES, SI R. THAT' S THE PAGE 2 OF THE
5 FI RST - - THE FI RST REPORT THAT I J UST SHOWED YOU.
6 Q ALL RI GHT. SO I ' M GOI NG TO SHOWYOU THE
7 FI RST PAGE.
8 ARE THESE STANDARD RECORDS THAT YOU FI LL
9 OUT EVERY DAY OF YOUR J OB?
10 A YES, SI R, EVERY PATI ENT THAT WE SEE ON
11 EVERY DAY GETS ONE OF THESE.
12 Q NOW, THE WRI TI NG I S SMALL.
13 I S THAT LI KE AN 8 AND A HALF BY 11, OR I S
14 I T SMALLER?
15 A YES, SI R, I T' S AN 8 AND A HALF BY 11,
16 STANDARD SI ZE.
17 Q SO ABOVE THERE, YOU HAVE - - J UST WALK US
18 THROUGH BRI EFLY THE FI RST PART OF WHAT WE' RE LOOKI NG
19 AT?
20 A WELL, NATURALLY, WE HAVE THE DATE, 6/ 25; WE
21 HAVE THE I NCI DENT NUMBER; WE HAVE THE DI SPATCH CODE;
22 HOWMANY PATI ENTS THERE ARE; HOWMANY WERE TRANSPORTED,
23 HOWMANY - - MEANI NG HOWMANY WE TOOK TO THE HOSPI TAL;
24 WHO WAS THERE, MEANI NG ENGI NE 71 WAS THERE.
25 AND THEN RESCUE 71; AND THE TI ME WE GOT THE
26 CALL, 12: 22; THE TI ME WE ARRI VED AT THE LOCATI ON,
27 12: 26; WHEN WE TRANSPORTED, 1307; AND THE TI ME AT THE
28 HOSPI TAL; AND WHEN WE WERE FI NI SHED WI TH EVERYTHI NG AND
866 299-5127
2301
1 BACK AVAI LABLE AND I N SERVI CE. BY I N SERVI CE, I MEAN
2 WE COULD RESPOND TO ANOTHER CALL.
3 THERE' S THE ADDRESS, OF COURSE, 100 NORTH
4 CAROLWOOD. 818 I S THE HOSPI TAL I CONTACTED, 818 I S THE
5 HOSPI TAL I ARRI VED AT, BOTH U. C. L. A. TRANSPORTED TO
6 MAR, WHI CH I S MOST ACCESSI BLE RECEI VI NG HOSPI TAL,
7 MEANI NG THE CLOSEST HOSPI TAL. THE COMPANY I . D. , RESCUE
8 71; THE TI ME; THE TI ME AT THE PATI ENT, SO 12: 26 AT
9 SCENE, WI TH THE PATI ENT AT 12: 27.
10 THAT' S MY I D NUMBER, THAT' S MY SI GNATURE,
11 AND THESE ARE THE I . D. NUMBERS OF THE OTHER PARAMEDI CS
12 THAT WERE THERE.
13 Q OKAY. I T ALSO SAYS THERE " CODE 3" ?
14 A YES, SI R.
15 Q WHAT I S A CODE 3?
16 A CODE 3 I S WHEN YOU' RE DRI VI NG RED LI GHTS
17 AND SI REN.
18 Q I T MEANS YOU CAN GO THROUGH THE RED LI GHTS?
19 A YES, SI R.
20 Q DI D YOU GO DOWN SUNSET TO GET TO U. C. L. A. ?
21 A SUNSET TO HI LGARD AND DOWN HI LGARD.
22 Q DOWN HI LGARD.
23 LEFT ON HI LGARD?
24 A YES, SI R.
25 Q OKAY. ALL RI GHT. NOW, I F WE CAN GO
26 DOWN - - THERE' S AS NARRATI VE THAT YOU WROTE OUT?
27 A CORRECT, BELOWTHE PATI ENT I DENTI FI CATI ON
28 AND THE PATI ENT FI LE NUMBER AT U. C. L. A. , THERE' S A
866 299-5127
2302
1 NARRATI VE THAT I WROTE.
2 Q OKAY. CAN YOU J UST READ THAT, WHAT YOU
3 WROTE FOR US?
4 A YES, SI R.
5 I T SAYS " 50- YEAR- OLD MALE FOUND SUPI NE ON
6 FLOOR. C. P. R. I N PROGRESS VI A PERSONAL MEDI CAL DOCTOR,
7 MURRAY, CALI FORNI A, " HI S LI CENSE NUMBER. " NO VI SI BLE
8 NEWTRAUMA, GOOD LUNG SOUNDS FOLLOWI NG I NTUBATI ON. "
9 I NTUBATI ON I S WHEN WE PLACE THE TUBE I NSI DE THE LUNGS.
10 Q AND YOU I NTUBATED THE PATI ENT?
11 A MARTI N BLUNT I NTUBATED THE PATI ENT.
12 Q SOMEBODY WI TH YOU?
13 A SOMEBODY WI TH ME, YES, SI R.
14 " I . V. I N PLACE VI A PERSONAL MEDI CAL DOCTOR,
15 MURRAY, LEFT LEG. LATER, I . V. J UGULAR LEFT SI DE VI A
16 PARAMEDI C NUMBER 1. " PARAMEDI C NUMBER 1 I S RI GHT HERE,
17 WHI CH HAPPENS TO BE ME. " PULSES WI TH C. P. R. "
18 CAPNOGRAPHY WAS I NI TI ALLY 16.
19 Q WHAT I S THE SI GNI FI CANCE OF THAT?
20 A THAT' S A VERY LOWREADI NG, I T' S NOT
21 COMPATI BLE WI TH LI FE.
22 Q I N OTHER WORDS, SOMEBODY I S DEAD, THAT' S
23 THEI R READI NG?
24 A YES.
25 Q OKAY.
26 A AND THEN AT TRANSFER, THE CAPNOGRAPHY
27 READI NG HAD RI SEN UP TO 26 WI TH GOOD LUNG SOUNDS
28 THROUGHOUT AND AT TRANSFER. AND THEN THE REST OF THE
866 299-5127
2303
1 NARRATI VE I S ON PAGE 2. AND BELOWTHAT I S THE
2 MEDI CATI ONS THAT - - THAT WE WERE TOLD ABOUT.
3 Q FROM DR. MURRAY?
4 A YES, LORAZEPAM, 1, 000 C. C. ' S OF NORMAL
5 SALI NE FOR HYDRATI ON, ALLERGY TO THORAZI NE. AND THE
6 REST I S ALL RELATED TO THE TI ME THAT WE WERE THERE AND
7 THE VI TAL SI GNS. FOR EXAMPLE, AT 12: 20, THERE WAS NO
8 BLOOD PRESSURE, THERE WAS NO PULSE, THERE WAS NO
9 RESPI RATI ONS; AND AT 12: 34, AGAI N, NO PULSE, NO
10 RESPI RATI ONS.
11 AND TO THE RI GHT OF THAT I S THE E. K. G. ,
12 ELECTROCARDI OGRAPH, THE MACHI NE, YOU KNOW, THAT
13 MEASURES YOUR HEART, AND THOSE ARE THE CARDI AC RHYTHMS.
14 THE I NI TI AL ONE WAS P. E. A. , WHI CH WE CALL PULSELESS
15 ELECTRI CAL ACTI VI TY. I T' S J UST EXTRA LI TTLE FUNNY
16 LI TTLE ELECTRI CAL THI NGS THAT SHOWUP ON I T, AND THEY
17 DO NOTHI NG.
18 Q HAVE YOU HEARD OF THE TERM " FLAT LI NE" ?
19 A YES, SI R.
20 Q I S THAT WHAT WAS OCCURRI NG?
21 A WELL, BELOWTHAT, I I NDI CATE ASYSTOLE.
22 ASYSTOLE I S MEDI CAL FOR FLAT LI NE. SO FLAT LI NE WI TH A
23 COUPLE OF LI TTLE BEATS THAT DO ABSOLUTELY NOTHI NG ON
24 THE MONI TOR, THAT' S CALLED P. E. A. , PULSELESS ELECTRI CAL
25 ACTI VI TY.
26 Q DO YOU REMEMBER WHAT DAY OF THE WEEK THI S
27 WAS?
28 A NO, SI R.
866 299-5127
2304
1 Q WAS I T A WEEKEND OR WEEKDAY?
2 A I T WAS A WEEKDAY.
3 Q THERE' S SOMETHI NG I NDI CATED THERE AS A
4 " G. C. S. " ON YOUR REPORT?
5 A YES, SI R.
6 Q DO YOU SEE THAT?
7 A YES, SI R.
8 Q COULD YOU POI NT THAT OUT TO US?
9 A I F WE COULD BRI NG I T - -
10 Q BRI NG I T UP A LI TTLE MORE. I T' S ON THE
11 BOTTOM THERE.
12 A KEEP GOI NG. KEEP GOI NG.
13 THERE WE ARE.
14 Q OKAY.
15 A OKAY.
16 Q A G. C. S. , I S THAT ALSO REFERRED TO AS
17 WHAT' S KNOWN AS A GLASGOWCOMA SCALE?
18 A THAT' S CORRECT, THE GLASGOWCOMA SCALE.
19 Q I S THAT SOMETHI NG THAT' S ADMI NI STERED AS A
20 TEST TO A PATI ENT?
21 A YES, SI R, I T I S.
22 Q AND I S THAT SOMETHI NG THAT YOU' RE TRAI NED
23 I N HOWTO ADMI NI STER THAT?
24 A YES, SI R.
25 Q COULD YOU EXPLAI N WHAT A GLASGOWCOMA SCALE
26 I S AND WHAT - - WHAT I S THE PURPOSE OF GI VI NG SUCH A
27 TEST TO A PATI ENT?
28 A GLASGOWCOMA SCALE CAME FROM A HOSPI TAL I N
866 299-5127
2305
1 GLASGOW, SCOTLAND; AND I T WAS DESI GNED ORI GI NALLY TO
2 ASSESS PATI ENTS THAT WERE I N A COMA WARD TO FI ND OUT
3 J UST HOWWELL THEY WERE FUNCTI ONI NG OR NOT FUNCTI ONI NG,
4 WHETHER THEY WERE I MPROVI NG OR NOT I MPROVI NG.
5 I T ASSESSES YOUR LEVEL OF CONSCI OUSNESS,
6 YOUR ABI LI TY TO RESPOND TO ME. I T HAS SI NCE BEEN - -
7 I T' S SO SUCCESSFUL I T HAS SI NCE BEEN USED FOR - - EVERY
8 PATI ENT WE GO ON, WE ESTABLI SHED A G. C. S. ON. SO THE
9 WAY I T WORKS, WHEN I WALK UP, ARE YOUR EYES OPEN?
10 I F YOUR EYES ARE OPEN AND YOU' RE LOOKI NG AT
11 ME, YOU I MMEDI ATELY GET A NUMBER OF 4. MOTOR SKI LLS.
12 I F YOU' RE ABLE TO MOVE AND TALK AND WALK, THEN WE GI VE
13 YOU A NUMBER OF 6. OKAY? AND FOR VERBAL, I F YOU' RE
14 ABLE TO TALK TO ME, YOU GET 5. AND 4, 6 AND 5 TOTAL
15 FOR A SCORE OF 15.
16 SO ALL OF YOU SI TTI NG RI GHT HERE, YOUR
17 G. C. S. I S CURRENTLY 15. ON THE OTHER HAND, I F YOU' RE
18 UNCONSCI OUS, THAT' S GOI NG TO LOWER THE NUMBERS. YOUR
19 EYES WOULD BE 1. I F YOU' RE NOT MOVI NG, YOU GET A 1;
20 AND I F YOU' RE NOT TALKI NG, YOU GET A 1; SO YOUR SCORE
21 I S NOWA 3.
22 Q SO LI KE THI S TABLE RI GHT HERE, THAT WOULD
23 HAVE A SCALE - - A GLASGOWCOMA SCALE OF 3?
24 A CORRECT.
25 Q NOW, DI D DR. MURRAY I NDI CATE TO YOU THAT HE
26 HAD GI VEN MR. J ACKSON LORAZEPAM TO SLEEP?
27 A YES, SI R.
28 Q WHEN YOU I NTUBATED MR. J ACKSON, WAS THAT
866 299-5127
2306
1 YOUR EQUI PMENT THAT YOU BROUGHT WI TH YOU?
2 A YES, SI R.
3 Q AND WAS THERE AN I . V. I N THE NECK?
4 A I PLACED AN I . V. I N THE NECK LATER.
5 Q OKAY. THAT' S WI TH YOUR EQUI PMENT?
6 A YES, SI R.
7 Q ALL RI GHT. NOW, DI D YOU NOTI CE WHETHER ANY
8 I . V. ' S HAD BEEN HOOKED UP THAT DR. MURRAY WAS DEALI NG
9 WI TH?
10 A YES, SI R, THERE WAS AN I . V. I N PLACE WHEN
11 WE ARRI VED ON SCENE.
12 Q AND WHERE WAS THAT I . V. LOCATED?
13 A I T WAS ON THE I NSI DE OF HI S LEFT CALF, J UST
14 BELOWTHE KNEE.
15 Q DI D YOU DI SCUSS THAT WI TH DR. MURRAY?
16 A I DI D NOT DI SCUSS I T - - I DI DN' T DI SCUSS I T
17 WI TH HI M, NO.
18 Q OKAY. DI D YOU OR THE PEOPLE WI TH YOU TAKE
19 ANY EFFORTS I N ATTEMPT TO RESUSCI TATE MR. J ACKSON?
20 A YES, SI R.
22 A AS SOON AS WE MOVED HI M TO THE FLOOR,
23 BRETT HERON, WHO HAD BEEN CARRYI NG THE TORSO - - WHEN WE
24 MOVED HI M ONTO THE FLOOR, HE I MMEDI ATELY STARTED DOI NG
25 CHEST COMPRESSI ONS.
26 MARTI N BLUNT I MMEDI ATELY GRABBED AN AMBU
27 BAG, A BREATHI NG BAG, PLACED I T OVER HI S FACE, STARTED
28 PRESSI NG I N SO WE COULD BREATHE FOR HI M. PARAMEDI C
866 299-5127
2307
1 GOODWI N I MMEDI ATELY STARTED PATCHI NG - - PUTTI NG THE
2 ELECTRODES ON HI M SO WE COULD SEE WHAT' S GOI NG ON WI TH
3 THE HEART.
4 I ' M HELPI NG PARAMEDI C GOODWI N DO THI S. AT
5 THE SAME TI ME, I ' M ASKI NG THE DOCTOR WHAT KI ND OF
6 HI STORY, WHAT KI ND OF PROBLEMS, YOU KNOW, THOSE SORT OF
7 THI NGS THAT WE DI SCUSSED. AND THEN WE TURNED ON THE
8 MONI TOR AND FI ND OUT WHAT HI S RHYTHM I S.
9 AS I I NDI CATED THERE, I T WAS FLAT LI NE.
10 MARTI N BLUNT THEN PLACES THE TUBE I NTO THE LUNGS AND
11 STARTS BREATHI NG FOR HI M MORE EFFECTI VELY. PARAMEDI C
12 GOODWI N I S LOOKI NG FOR AN I . V. SI TE I N THE ARMS. YES,
13 THERE' S AN I . V. I N THE LEG; BUT THAT' S NOT OUR I . V. , WE
14 DI DN' T PLACE I T THERE, SO WE DON' T TRUST I T.
15 SO WHI LE PARAMEDI C GOODWI N I S LOOKI NG FOR
16 THAT, I CHANGE OUT ALL THE TUBI NG BECAUSE WE USE A
17 DI FFERENT I . V. SYSTEM, SO I CHANGE OUT ALL THE TUBI NG,
18 SET UP A NEWBAG, AND THEN I HOOK I T UP, AND THEN I
19 FLUSH OUT THE I . V. I N HI S LEG SO I KNOWI T WORKS GOOD,
20 AND WE START PUTTI NG CARDI AC DRUGS I NTO THE I . V. I N THE
21 LEG.
22 Q AND THAT' S WHEN YOU PUT I N WHAT YOU CALL
23 THE EPI NEPHRI NE AND THE - -
24 A ATROPI NE.
25 Q - - ATROPI NE?
26 A YES, SI R.
27 Q NOW, WAS DR. MURRAY DOI NG ANYTHI NG DURI NG
28 THI S TI ME, THAT YOU OBSERVED?
866 299-5127
2308
1 A YES, SI R.
2 Q WHAT WAS HE DOI NG?
3 A HE WAS TRYI NG TO HELP AS BEST HE CAN. HE
4 WAS GI VI NG US SOME ORDERS, AND HE WAS LOOKI NG FOR
5 THI NGS I N OUR BOX, OUR DRUG BOX.
6 Q DI D YOU SEE HI M ATTEMPT TO GI VE ANY
7 I NJ ECTI ONS OR MEDI CATI ON TO MR. J ACKSON?
8 A AS THE CALL PROGRESSED, YES.
9 Q WHAT WAS HE DOI NG I N THAT REGARD?
10 A AFTER WE DI D OUR I NI TI AL - - OUR
11 RESUSCI TATI ON EFFORT, AND WERE CONTI NUI NG ON, THE CALL
12 I S GOI NG ON, DR. MURRAY WOULD REACH I NTO OUR BOX AND
13 TAKE OUT SOME OF OUR DRUGS AND THEN GI VE ADDI TI ONAL
14 TREATMENTS.
15 Q DO YOU KNOWWHAT HE DI D?
16 A YES, SI R.
17 HE GAVE ADDI TI ONAL I NJ ECTI ONS OF
18 EPI NEPHRI NE AND ATROPI NE, AND HE ASKED US TO GI VE SOME
19 MAGNESI UM, AND HE ASKED US TO START A CENTRAL LI NE.
20 Q DI D YOU HAVE ANY DI FFI CULTI ES I N TRYI NG TO
21 START A NEWI . V. I N MR. J ACKSON' S ARM?
22 A YES, SI R.
23 PARAMEDI C GOODWI N ATTEMPTED TO START AN
24 I . V. ON BOTH SI DES, AND WAS UNABLE TO.
25 Q WHY I S THAT?
26 A I . V. ' S, AS I ' M SURE ALL OF YOU HAVE HAD
27 YOUR BLOOD DRAWN AT SOME POI NT, CAN BE DI FFI CULT TO GET
28 THE NEEDLE I N THE VEI N. I T' S VERY DI FFI CULT WHEN
866 299-5127
2309
1 THERE' S NO BLOOD PRESSURE BECAUSE THE VEI N J UST LAYS
2 FLAT. SO THAT' S WHY HE WAS - - I ' M SURE THAT' S WHY HE
3 WAS HAVI NG TROUBLE.
4 Q SO WHAT DI D HE DO?
5 A WELL, HE LOOKED ON THE LEFT ARM, AND THEN
6 HE TRI ED SEVERAL TI MES ON THE LEFT ARM, THEN HE MOVED
7 OVER TO THE RI GHT ARM AND HE TRI ED SEVERAL TI MES ON THE
8 RI GHT ARM.
9 Q BOTH UNSUCCESSFUL?
10 A YES, SI R.
11 Q SO WHERE DI D HE PLACE THE I . V. ?
12 A PARAMEDI C GOODWI N DI DN' T - - ENDED UP NOT
13 PLACI NG AN I . V. HE ENDED UP STI CKI NG THE NEEDLES I N,
14 NOT GETTI NG ANYTHI NG, COMI NG BACK, STI CKI NG THE NEEDLES
15 I N, NOT GETTI NG ANYTHI NG - -
16 Q WAS THERE ANY I NTUBATI ON EQUI PMENT AT THE
17 SCENE BEFORE YOU GOT THERE?
18 A NOT THAT I ' M AWARE OF, SI R.
19 Q WAS THERE ANY CAPNOGRAPHY EQUI PMENT THERE
20 BEFORE YOU GOT THERE?
21 A NOT THAT I ' M AWARE OF.
22 Q DR. MURRAY, DI D YOU EVER OBSERVE HI M TRYI NG
23 TO TAKE MR. J ACKSON' S PULSE?
24 A YES, SI R.
25 Q WAS THERE ANY I NDI CATI ON THAT THERE WAS
26 EVER ANY PULSE?
27 A DR. MURRAY FELT THE FEMORAL ARTERY, WHI CH
28 I S THE LARGE ARTERY ON THE I NSI DE OF YOUR GROI N, AND A
866 299-5127
2310
1 STANDARD PLACE TO CHECK FOR A PULSE. AND HE FELT FOR A
2 PULSE; AND HE SAI D THAT, " I BELI EVE THERE' S A PULSE. "
3 Q DI D YOU CHECK THAT YOURSELF?
4 A YES, SI R.
5 AT THAT POI NT, I I NSTRUCTED THE TEAM TO
6 STOP DOI NG CHEST COMPRESSI ONS BECAUSE I F YOU' RE DOI NG
7 GOOD C. P. R. , YOU' RE SUPPOSED TO GET A PULSE. SO THEY
8 STOPPED DOI NG CHEST COMPRESSI ONS, THEY CONTI NUED
9 VENTI LATI ON, AND I LOOKED AT THE CARDI AC MONI TOR, WHI CH
10 WAS STI LL FLAT, AND THEN I FELT FOR A PULSE I N THE SAME
11 SPOT.
12 ADDI TI ONALLY, THE OTHER MEMBERS WERE
13 FEELI NG I N DI FFERENT PLACES ON OUR PATI ENT.
14 Q DI D ANYONE WI TH YOU OR YOURSELF EVER FI ND A
15 PULSE FOR MR. J ACKSON?
16 A NO, SI R.
17 Q ONCE YOU - - HOWLONG WERE YOU THERE TRYI NG
18 TO PROVI DE TREATMENT BEFORE YOU BEGAN TO TRANSPORT THE
19 PATI ENT?
20 A 30, 35 MI NUTES, SOMEWHERE AROUND THERE.
21 Q DI D YOU DECI DE THEN TO TRANSPORT TO
22 U. C. L. A. ?
23 A YES, SI R.
24 Q AND HOWDI D YOU DO THAT?
25 A UM, WE HAD THE STAI RS THAT WE MENTI ONED
26 EARLI ER. OUR GURNEY I S HEAVY AND BULKY, AND I T' S AT
27 THE BOTTOM OF THE STAI RS, SO WE BROUGHT UP A CANVAS
28 CARRI ER. WE CALL I T A FLAT. I T' S A LI GHTWEI GHT METAL
866 299-5127
2311
1 CONTRAPTI ON WI TH A CANVAS DEAL.
2 AND WE PLACE THAT NEXT TO THE PATI ENT,
3 SLI DE THE PATI ENT ONTO I T, STRAP THEM ON WI TH SOME SEAT
4 BELTS, AND THE EQUI PMENT THAT WE' RE USI NG TO MONI TOR
5 THE HEART AND SUCH, AND CARRY THEM DOWN THE STAI RS.
6 Q AND YOU MENTI ONED THAT - - STRI KE THAT.
7 HAD YOU ALREADY CONTACTED U. C. L. A. ?
8 A YES, SI R.
9 I CONTACTED U. C. L. A. WI THI N THE FI RST FI VE
10 MI NUTES I WAS I N THE BEDROOM.
11 Q HOWMANY COMMUNI CATI ONS DI D YOU HAVE WI TH
12 U. C. L. A. ?
13 A ONE, BUT I T WAS AN ONGOI NG CONVERSATI ON.
14 Q HOWDO YOU CONTACT THEM?
15 A I USED A CELL PHONE.
16 Q I S THAT COMMON, HOWYOU DO I T?
17 A YES, SI R.
18 Q WHEN YOU GOT I N THE CAR - - EXCUSE ME - - THE
19 AMBULANCE, YOU DROVE WI TH THE LI GHTS AND SI RENS?
20 A YES, SI R.
21 Q AND I T TOOK ABOUT - - I CAN' T REMEMBER NOW.
22 YOU HAVE I T I NDI CATED THERE.
23 CAN WE GO BACK TO THAT 462- 9987, THE VERY
24 BOTTOM OF THE SHEET? THERE. OKAY.
25 SO YOU SAY I T TOOK ABOUT SI X MI NUTES TO GET
26 TO U. C. L. A.
27 A YES, SI R.
28 Q APPROXI MATELY?
866 299-5127
2312
1 A APPROXI MATELY.
2 Q YOU WEREN' T TO THE EXACT SECOND, BUT YOUR
3 BEST RECORDATI ON OF THE TI ME I S ABOUT SI X MI NUTES?
4 A YES, SI R.
5 Q WHEN YOU ARRI VED AT U. C. L. A. , HAD
6 MR. J ACKSON' S CONDI TI ON CHANGED AT ALL?
7 A NO, SI R.
8 Q I WANT TO SHOWYOU - - OH. DI D MR. - - DI D
9 DR. MURRAY GO WI TH YOU I N THE AMBULANCE?
10 A YES, SI R.
11 Q PARDON ME?
12 A YES, SI R.
13 Q DI D DR. MURRAY WANT TO TRANSPORT
14 MR. J ACKSON HI MSELF?
15 A SI R, I ' M UNCLEAR AS TO WHAT YOU MEAN.
16 Q ALL RI GHT. AT SOME POI NT, DI D YOU TELL
17 DR. MURRAY THAT YOU' D DONE EVERYTHI NG THAT YOU THOUGHT
18 YOU COULD DO AND YOU NEEDED TO, QUOTE, UNQUOTE, CALL
19 I T?
20 A THE WAY I T TRANSPI RED WAS I ' M TALKI NG TO
21 THE HOSPI TAL ON THE PHONE, AND THEY' RE GETTI NG CONSTANT
22 UPDATES AS TO WHAT' S GOI NG ON. SO WE' VE GI VEN HI M ALL
23 THE NORMAL MEDI CATI ONS THAT YOU CAN GI VE, WE' VE GOT
24 GOOD I NTUBATI ON, GOOD LUNG SOUNDS, WE' VE GOT GOOD
25 I . V. ' S, EVERYTHI NG I S WORKI NG WELL, BUT THE PATI ENT I S
26 NOT RESPONDI NG.
27 THESE ARE I NDI CATI ONS THAT I T' S - - I T' S
28 FUTI LE. SO AFTER A FEWTRI ES WI TH THE MEDI CATI ONS AND
866 299-5127
2313
1 SUCH, 20, 25 MI NUTES HAD ELAPSED, THE HOSPI TAL I S
2 SAYI NG, " I T' S FUTI LE. WOULD YOU LI KE TO GO AHEAD AND
3 CALL THE CALL?" MEANI NG STOP, I T' S OVER, AND - -
4 Q THEY' RE LI KE SAYI NG CALL I T LI KE ON
5 " EMERGENCY" ON T. V. , CALL THE TI ME OF DEATH? I S THAT
6 WHAT WE' RE TALKI NG ABOUT?
7 A EXACTLY.
8 Q OKAY. AND HOWDI D DR. MURRAY RESPOND WHEN
9 YOU SAI D THE HOSPI TAL SAI D TO CALL I T?
10 A WHEN THE HOSPI TAL I NSTRUCTED ME TO SAY,
11 " WHAT DO YOU THI NK ABOUT CALLI NG I T?" I KNEWDR. MURRAY
12 WOULD NOT WANT TO, SO I LOOKED AT DR. MURRAY AND SAI D,
13 " RI GHT NOW, THE HOSPI TAL WOULD LI KE TO GO AHEAD AND
14 CALL I T. "
15 AND HE SAI D NO. AND THEN I - - GO AHEAD.
17 A I EXPLAI NED TO HI M THAT AS A PHYSI CI AN ON
18 SCENE, WE HAVE A PROCEDURE THAT WE FOLLOWWHERE THE
19 HOSPI TAL PHYSI CI AN I S NO LONGER TREATI NG THE PATI ENT,
20 HE CAN TAKE OVER THE CALL BECAUSE HE I S A PHYSI CI AN.
21 BUT I N ORDER TO TAKE OVER THE CALL, HE HAS TO ACCOMPANY
22 THE PATI ENT I N THE AMBULANCE TO THE HOSPI TAL, AND
23 THAT' S WHAT HE DI D.
24 Q HE AGREED TO DO THAT?
25 A HE AGREED TO DO THAT.
26 Q HOWWAS HI S DEMEANOR AT THI S TI ME?
27 A AT THAT TI ME, HE WAS HI GHLY CONCERNED,
28 PROFESSI ONAL. HE WAS DOI NG - - HE WAS DOI NG FI NE.
866 299-5127
2314
1 Q NOW, WHEN YOU - - WHEN YOU - - WHEN YOU WERE
2 GETTI NG MR. GURNEY ( SI C) - - SORRY.
3 ONCE YOU BROUGHT THE GURNEY OUT TO
4 TRANSPORT MR. J ACKSON, HE WAS SECURED TO THE GURNEY,
5 RI GHT?
6 A YES, SI R.
7 Q AND THEN DI D YOU GO BACK UPSTAI RS TO
8 RETRI EVE ANY EQUI PMENT?
9 A YES, SI R.
10 I T TAKES ALL OF US TO CARRY THE PATI ENT
11 DOWN THE STAI RS WI TH STI LL DOI NG C. P. R. , STI LL
12 VENTI LATI NG. AND SO AS SOON AS THE PATI ENT WAS ON THE
13 GURNEY, I KNEWTHAT THEY COULD SECURE HI M AND - - AND DO
14 WHAT THEY NEED TO DO, SO I TOOK OFF AND WENT RI GHT BACK
15 UP THE STAI RS TO GET THE EQUI PMENT THAT WE' D LEFT
16 BEHI ND.
17 Q AND WHEN YOU WENT UP TO THE ROOM, WAS
18 ANYONE I N THE ROOM?
19 A YES, SI R.
20 DR. MURRAY WAS.
21 Q WHAT WAS DR. MURRAY DOI NG?
22 A HE HAD A BAG I N ONE HAND, AND HE WAS
23 PI CKI NG THI NGS UP OFF THE FLOOR.
24 Q WHAT KI ND OF BAG?
25 A A PLASTI C BAG.
26 I THI NK I T WAS A WHI TE PLASTI C BAG.
27 Q AND WHAT WAS HE PI CKI NG UP?
28 A I DON' T KNOW, SI R. I COULDN' T SEE.
866 299-5127
2315
1 Q DI D HE SEE YOU ENTER THE ROOM?
2 A YES, SI R.
3 Q HOWDI D HE LOOK WHEN YOU ENTERED THE ROOM?
4 A SURPRI SED.
5 Q WOULD YOU DESCRI BE I T AS A DEER - - LOOKED
6 LI KE A DEER, OR SOMETHI NG LI KE THAT?
7 A PREVI OUSLY, I HAVE DESCRI BED I T AS A DEER
8 I N THE HEADLI GHTS LOOK.
9 Q AND WHAT DOES THAT MEAN?
10 A HE - - HE FROZE. WHEN I CAME THROUGH THE
11 DOOR, HE J UST - - HE FROZE, AND HE WAS OBVI OUSLY
12 SURPRI SED TO SEE SOMEONE COME I N.
13 Q OKAY. AND WHERE I N THAT ROOM WAS
14 DR. MURRAY WHEN YOU SAWHI M?
15 A ON THE OTHER SI DE OF THE BED NEAR THE
16 NI GHTSTAND.
17 Q AND YOU ALL RODE I N THE AMBULANCE TOGETHER
18 TO THE HOSPI TAL?
19 A YES, SI R.
20 Q WHAT WAS I T LI KE - - WHAT WAS THE SCENE AT
21 THE HOUSE WHEN YOU WERE LEAVI NG?
22 A THE SCENE AT THE HOUSE WHEN WE WERE LEAVI NG
23 WAS UNBELI EVABLE.
24 Q DESCRI BE I T.
25 A WHEN WE ARRI VED, THERE WAS J UST THE FI RE
26 ENGI NE, THE AMBULANCE AND THE SECURI TY PEOPLE. WE WENT
27 I NSI DE, WE DI D OUR J OB, WE CAME OUTSI DE, WE' RE TRYI NG
28 TO LEAVE. NOW, WE HAVE TO BACK OUT. I T WAS VERY
866 299-5127
2316
1 DI FFI CULT TO BACK OUT BECAUSE THERE WERE SO MANY PEOPLE
2 I N THE WAY PUTTI NG CAMERAS AGAI NST THE WI NDOWS OF THE
3 AMBULANCE.
4 THERE WAS A TOUR BUS THERE, THERE WERE
5 PEOPLE ALL OVER THE TOUR BUS TAKI NG PI CTURES, THERE WAS
6 ALL KI NDS OF PEOPLE WI TH EVERY SI ZE CAMERA YOU COULD
7 POSSI BLY I MAGI NE. THERE WAS AN UNBELI EVABLE AMOUNT
8 OF - - OF COMMOTI ON AND PEOPLE RUNNI NG AROUND.
9 Q HAVE YOU EVER SEEN ANYTHI NG LI KE THAT
10 BEFORE?
11 A NEVER, SI R.
12 Q WHEN YOU WERE I N THE AMBULANCE, WHERE WERE
13 YOU SEATED AND WHERE WERE THE OTHERS SEATED ON THE WAY
14 TO THE HOSPI TAL?
15 A I WAS SEATED AT THE - - WE CALL I T THE J UMP
16 SEAT AT THE HEAD OF THE GURNEY, SO THE - - THE PATI ENT' S
17 HEAD WOULD BE RI GHT HERE, AND I ' M RI GHT HERE. THAT
18 ALLOWS ME TO FUNCTI ON THE RADI OS AND BREATHE FOR THE
19 PATI ENT.
20 Q WHERE WERE THE OTHERS SEATED?
21 A PARAMEDI C GOODWI N WAS I N A SEAT RI GHT HERE
22 DOI NG C. P. R. , AND THEN THERE' S A BENCH RI GHT ALONG HERE
23 WHERE PARAMEDI C BLUNT I S, AND DR. MURRAY WAS NOT
24 SEATED. HE WAS STANDI NG. DOWN THE CENTER OF THE
25 AMBULANCE I S A BAR TO HOLD ON TO, AND HE WAS STANDI NG
26 UP HOLDI NG ON TO A BAR AT THE BACK OF THE AMBULANCE.
27 Q WHAT WAS HE DOI NG?
28 A TALKI NG ON HI S CELL PHONE.
866 299-5127
2317
1 Q WERE YOU ABLE TO OVERHEAR ANY OF HI S
2 CONVERSATI ONS?
3 A NO, SI R.
4 Q WAS ANYONE FOLLOWI NG THE AMBULANCE?
5 A NOT TO BE GLI B. RESPECTFULLY, EVERYBODY
6 WAS FOLLOWI NG THE AMBULANCE.
7 Q DO YOU KNOWWHETHER ANY OF MR. J ACKSON' S
8 SECURI TY WERE FOLLOWI NG THE AMBULANCE?
9 A YES, SI R.
10 Q WERE THEY?
11 A YES, SI R.
12 THERE WERE BLACK SUBURBANS, TI NTED WI NDOWS,
13 THAT WERE FOLLOWI NG RI GHT BEHI ND US, TWO OR THREE OF
14 THEM.
15 MR. PANI SH: I WANT TO SHOWYOU EXHI BI T 855,
16 DASH, 1.
17 THE COURT: COUNSEL, I S THI S I N YOUR BOOK
18 SOMEWHERE?
19 MR. PANI SH: I SURE HOPE SO. I F YOU LOOK, YOUR
20 HONOR, UNDER - -
21 THE COURT: OH, I SEE I T. FOUND I T.
22 MR. PANI SH: THANK YOU.
23 Q HAVE YOU SEEN THAT? DOES THAT DEPI CT A
24 CERTAI N SI TUATI ON?
25 A YES, SI R. THAT' S ME I N THE PI CTURE DURI NG
26 TRANSPORTATI ON.
27 MR. PANI SH: LET ME SHOWTHAT TO EVERYONE.
28 Q I S THAT YOUR ARM?
866 299-5127
2318
1 A YES, SI R. I ' M AT THE HEAD OF THE GURNEY
2 RI GHT HERE. OBVI OUSLY, OUR PATI ENT I S HERE. THAT' S MY
3 ARM, AND I ' M - - THERE' S A RADI O SET RI GHT HERE, SO I ' M
4 DI ALI NG I N THE CODE FOR THE RADI O, AND SI TTI NG RI GHT
5 HERE, AND WE ARE - - WE ARE J UST BACKI NG OUT AND THEN
6 PULLI NG FORWARD TO GO DOWN THE STREET.
7 Q SOMEBODY OUTSI DE TOOK THAT PI CTURE?
8 A YES, SI R.
9 Q PEOPLE WERE PUTTI NG CAMERAS UP EVERYWHERE?
10 A I T WAS A LARGE VI DEO CAMERA, AND THE MAN
11 J UST PLOPPED I T AGAI NST THE WI NDOWAND WAS RUNNI NG DOWN
12 THE STREET HOLDI NG THE CAMERA AGAI NST THE WI NDOW.
13 Q WHEN YOU ARRI VED AT THE HOSPI TAL, WHAT
14 HAPPENED?
15 A WHEN WE ARRI VED AT THE HOSPI TAL, WE BACKED
16 UP TO THE BACK DOOR. HOSPI TAL SECURI TY WAS NOT
17 DEPLOYED YET, SO THE PRI VATE SECURI TY THAT HAD FOLLOWED
18 US FORMED A CORRI DOR, AND THEY - - THEY KEPT EVERYBODY
19 AWAY, AND THEN WE WERE ABLE TO ROLL OUR PATI ENT OUT AND
20 RI GHT I NTO THE EMERGENCY ROOM.
21 Q THEY ASSI STED YOU?
22 A YES, SI R.
23 Q AND ONCE YOU GOT I N THE EMERGENCY ROOM,
24 THEN WHAT DI D YOU DO?
25 A WE WENT I NTO THE - - THE TREATMENT ROOM FOR
26 THE HOSPI TAL; AND THERE, THERE WAS THE STAFF WAI TI NG.
27 THE RESPI RATORY THERAPY, THE E. K. G. PEOPLE, THE DOCTOR,
28 THE X- RAY PEOPLE, ALL OF THOSE WERE WAI TI NG. SO WE
866 299-5127
2319
1 WHEELED THE PATI ENT I N, AND I ' M EXPLAI NI NG TO THE
2 DOCTOR WHAT WE' VE ALREADY DONE.
3 WE' VE GI VEN THREE ROUNDS OF EPI NEPHRI NE,
4 WE' VE GI VEN TWO ROUNDS OF ATROPI NE, TWO BI CARBS OF
5 CALCI UM. J UST A QUI CK RECAP OF WHAT WE' VE DONE.
6 THERE' S NO CHANGES; AND AT THAT TI ME, I ' M BREATHI NG FOR
7 THE PATI ENT. AND THEN WE LI FT THE PATI ENT OVER ONTO
8 THE GURNEY, AND THEN I LEAVE THE ROOM.
9 Q WHAT DI D YOU DO THEN?
10 A WALKED OUT I N THE HALLWAY AND STARTED
11 PUTTI NG ALL MY EQUI PMENT AWAY, AND THEN WE HAD A
12 DEBRI EFI NG.
13 Q WHO DI D YOU DEBRI EF?
14 A OUR CHI EF CALLED US ALL ASI DE, PUT US I N A
15 CONFERENCE ROOM AND WANTED TO DI SCUSS THE CALL.
16 Q THE CHI EF FI RE PERSON?
17 A OUR - - THERE' S THE BI G FI RE CHI EF; BUT
18 UNDER THE BI G FI RE CHI EF, THERE' S A LOT OF LI TTLE FI RE
19 CHI EFS.
20 Q CALLED BATTALI ON CHI EFS?
21 A YES, SI R, BATTALI ONS.
22 Q A LOT OF CHI EFS, NO I NDI ANS, HUH?
23 OKAY. SO THEN YOU HAD A DEBRI EFI NG FOR A
24 PERI OD OF TI ME, J UST RAN THROUGH WHAT YOU DI D?
25 A YES, SI R.
26 Q THEN WHAT DI D YOU DO?
27 A CONTI NUED GETTI NG THE AMBULANCE BACK I N
28 SERVI CE, AND I WAS PERSONALLY WRI TI NG REPORTS.
866 299-5127
2320
1 Q AND HOWLONG UNTI L YOUR NEXT CALL?
2 A OUR NEXT CALL, I WOULD - - I WOULD HAVE TO
3 CHECK THE J OURNAL, BUT I T WAS LATER I N THE EVENI NG,
4 AROUND 6: 00 O' CLOCK, I WANT TO GUESS.
5 THE COURT: BEFORE WE GET - - LET' S DO A SHORT
6 BREAK, TEN- MI NUTE BREAK. TEN MI NUTES, THEN BACK TO THE
7 COURTROOM.
8
9 ( 11- MI NUTE RECESS TAKEN. )
10
12 I N OPEN COURT, OUTSI DE THE PRESENCE
13 OF THE J URORS: )
14
15 THE COURT: OKAY. LET' S CALL THE J URORS I N. YOU
16 MAY BE SEATED.
17
19 I N OPEN COURT, I N THE PRESENCE OF THE
20 J URORS: )
21
22 THE COURT: J ACKSON VERSUS A. E. G. LI VE, BC445597.
23 I T' S COME TO MY ATTENTI ON THAT PERHAPS
24 SOMEBODY MAY BE ATTEMPTI NG TO PHOTOGRAPH J URORS. I ' M
25 GOI NG TO ADVI SE THE J URORS I F YOU SEE THAT OCCURRI NG,
26 PLEASE GET A DESCRI PTI ON OF WHO MAY BE DOI NG THAT, AND
27 WHAT THEY' RE DOI NG, AND PROVI DE I T TO ME OR MY STAFF.
28 WE WI LL LET THE SHERI FF' S DEPARTMENT KNOW
866 299-5127
2321
1 AND TRY TO I NVESTI GATE WHAT' S GOI NG ON. THAT SHOULDN' T
2 BE HAPPENI NG; BUT I F I T I S, LET US KNOW, WE WI LL DO
3 SOME I NVESTI GATI ON ON I T. I T SHOULDN' T BE HAPPENI NG.
4 SO, ALSO, I N THE AUDI ENCE, BE AWARE YOU ARE NOT TO BE
5 PHOTOGRAPHI NG J URORS.
6 OKAY. THANK YOU. YOU MAY CONTI NUE.
7 MR. PANI SH: YES, SI R.
8 Q WAS THERE ANY I NDI CATI ON THAT DR. MURRAY
9 HAD TRI ED TO ESTABLI SH AN AI RWAY BEFORE YOU ARRI VED?
10 A NO, SI R.
11 Q WAS THERE ANY I NDI CATI ON BEFORE YOU ARRI VED
12 THAT DR. MURRAY WAS TRYI NG TO ASSI ST MR. J ACKSON I N ANY
13 WAY WI TH BREATHI NG?
14 A NO, SI R.
15 Q DI D YOU EVER LEARN FROM DR. MURRAY THAT HE
16 HAD GI VEN MR. J ACKSON VERSED?
17 A NO, SI R.
18 Q DO YOU KNOWWHAT VERSED I S?
19 A YES, SI R.
20 Q WAS THERE ANY I NDI CATI ON FROM - -
21 THE COURT: WHAT I S THAT?
22 THE WI TNESS: VERSED I S A - - I T CALMS YOU DOWN.
23 I T' S FOR SLEEPI NG; AND I N STRONGER DOSES, I T TAKES OUT
24 YOUR RESPI RATORY DRI VE AND ALLOWS DOCTORS TO PUT TUBES
25 I NTO LUNGS AND THI NGS LI KE THAT.
26 MR. PANI SH: THANK YOU, YOUR HONOR.
27 Q ALSO, WAS THERE ANY I NDI CATI ON OR
28 I NFORMATI ON GI VEN TO YOU BY DR. MURRAY THAT HE HAD
866 299-5127
2322
1 GI VEN MR. - - MR. J ACKSON ANY VALI UM?
2 A NO, SI R.
3 Q NOW, I N YOUR REPORT, THERE' S AN I NDI CATI ON
4 OF 1, 000 C. C. ' S I . V.
5 A YES, SI R.
6 Q OKAY. WHAT WAS GI VEN WI TH I . V. 1, 000
7 C. C. ' S?
8 A THE I . V. BAG OF NORMAL SALI NE THAT WAS
9 HANGI NG ON THE I . V. POLE, THAT WAS NOWEMPTY.
10 Q OKAY.
11 A I T HOLDS 1, 000 C. C. ' S, THAT BAG.
12 Q OKAY. AND THAT WAS THERE WHEN YOU ARRI VED?
13 A YES, SI R.
14 Q AND " HYDROXATI VE" ( PHONETI C) , HAVE YOU
15 HEARD OF THAT TERM?
16 A " HYDROXATI VE" ?
17 Q I ' M SURE I GOT I T WRONG.
18 H- Y- R- A- X- R- A- T- I - V- E.
19 NEVER MI ND. THAT WAS - - STRI KE THAT
20 QUESTI ON. I ' M SORRY.
21 YOU DI D ANOTHER CALL THAT DAY?
22 A YES, SI R.
23 Q WHAT WAS THAT?
24 A I T WAS AN ELDERLY RUSSI AN WOMAN WHO HAD
25 FAI NTED, AND WHEN WE - - SHE HAD - - SHE WAS I N HER ROOM.
26 HOWMUCH DO YOU WANT ME TO TELL?
27 Q J UST BRI EFLY.
28 A SHE WAS I N HER APARTMENT OVER I N WEST L. A. ,
866 299-5127
2323
1 SHE HEARD THE NEWS THAT MI CHAEL HAD PASSED, AND SHE
2 FAI NTED. AND WHEN WE GOT THERE, SHE HAD STRUCK HER
3 HEAD ON A COFFEE TABLE, MI NOR I NJ URI ES, BUT SHE WAS
4 J UST DEEPLY EMOTI ONAL, AND WE TOOK HER TO THE HOSPI TAL.
5 Q DI D YOU HELP HER OUT?
6 A YES, SI R.
7 MR. PANI SH: OKAY. THAT' S ALL I HAVE RI GHT NOW.
8 THANK YOU, SI R.
10 CROSS EXAMI NATI ON?
11
12 CROSS- EXAMI NATI ON
13 BY MS. CAHAN:
14 Q GOOD MORNI NG, MR. SENEFF.
15 A GOOD MORNI NG.
16 Q WE WERE J UST TALKI NG ABOUT A FEWDI FFERENT
17 DRUGS. YOU WERE ASKED ABOUT VERSED AND VALI UM.
18 DO YOU REMEMBER THAT?
19 A YES, MA' AM.
20 Q AND WHAT' S THE GENERI C NAME OF VERSED?
21 I S I T MI DAZOLAM?
22 A MI DAZOLAM, YES.
23 Q OKAY. AND THE GENERI C NAME FOR VALI UM, I S
24 THAT DI AZEPAM?
25 A YES, SI R.
26 Q OKAY. AND ARE THOSE - - ARE THOSE BOTH I N
27 THE CATEGORY OF DRUGS CALLED BENZODI AZEPI NES?
28 A YES, MA' AM.
866 299-5127
2324
1 Q AND CAN YOU J UST TELL US BRI EFLY WHAT KI NDS
2 OF DRUGS BENZODI AZEPI NES ARE?
3 A BENZODI AZEPI NES ARE ANTI ANXI ETY DRUGS.
4 PEOPLE COMMONLY CONFUSE THEM WI TH SLEEPI NG PI LLS, BUT
5 THEY' RE REALLY NOT. THEY J UST CALM YOUR BRAI N DOWN TO
6 ALLOWYOU TO SLEEP. COMMON ONES WOULD BE XANAX OR
7 ATI VAN. STRONGER ONES THAT PARAMEDI CS CARRY WOULD BE
8 VERSED; AND, OF COURSE, PROPOFOL I TSELF I S A VERY
9 STRONG LEVEL OF BENZODI AZEPI NE.
10 Q SO ATI VAN AND XANAX, THOSE ARE BRAND NAMES
11 OR TRADE NAMES FOR DRUGS?
12 A YES.
13 Q AND THOSE DRUGS ALSO HAVE GENERI C OR
14 CHEMI CAL NAMES, CORRECT?
15 A YES.
16 Q AND THE GENERI C NAME FOR ATI VAN I S
17 LORAZEPAM?
18 A YES, MA' AM.
19 Q AND FOR XANAX I S ALPRAZOLAM?
20 A YES, SI R.
21 Q I S I T CORRECT THAT ALL THE BENZODI AZEPI NES
22 END I N " AM, " " PAM" OR " LAM" ?
23 A I WOULDN' T KNOW.
24 Q OKAY. AND ARE THEY USED AS SEDATI VES OR
25 SEDATI VE HYPNOTI CS?
26 YOU SAI D TO HELP SLEEP.
27 A YES.
28 Q ARE THEY ALSO USED AS ANTI ANXI ETY DRUGS?
866 299-5127
2325
1 A YES.
2 THAT' S THEI R MOST COMMON USE.
3 Q ARE THEY ALSO USED AS ANTI CONVULSANTS?
4 A YES.
5 Q AND ALSO AS MUSCLE RELAXANTS?
6 A YES.
7 Q YOU WERE ASKED EARLI ER ABOUT THE C. P. R.
8 EFFORTS FOR MR. J ACKSON.
9 A YES, MA' AM.
10 Q AND WHAT DOES C. P. R. STAND FOR?
11 A CARDI OPULMONARY RESUSCI TATI ON.
12 Q SO THE CARDI O PART I S THE HEART?
13 A YES, MA' AM.
14 Q AND THE PULMONARY PART I S THE LUNGS?
15 A YES, MA' AM.
16 Q SO I S I T FAI R TO SAY THAT THERE ARE TWO
17 GOALS OF C. P. R. , ONE I S TO GET THE HEART PUMPI NG AND
18 THE OTHER I S TO GET THE LUNGS EXCHANGI NG OXYGEN FOR
19 C02?
20 A YES, MA' AM.
21 Q AND YOU DO THAT BECAUSE I F SOMEONE I S NOT
22 GETTI NG OXYGENATED BLOOD I NTO THEI R BODY, THEY DI E,
23 CORRECT?
24 A YES, MA' AM.
25 Q OKAY. SO YOU' LL BREATHE FOR SOMEONE, USE
26 AN AMBU BAG OR OTHER DEVI CE TO GET - - HELP GET AI R I NTO
27 THE LUNGS?
866 299-5127
2326
1 Q AND THAT AI R THEN GOES THROUGH THE LUNGS,
2 BECOMES OXYGENATED I N THE - - OXYGENATED BLOOD - - OR
3 OXYGENATES THE BLOOD, AND THEN THE HEART SQUEEZES AND
4 PUMPS AND MOVES THE BLOOD THROUGH THE BODY, CORRECT?
5 A THAT WOULD BE CORRECT.
6 Q AND I N YOUR EFFORTS, YOUR TEAM' S EFFORTS,
7 TO RESUSCI TATE MR. J ACKSON, YOU WERE FOCUSI NG ON THE
8 BREATHI NG AS WELL AS THE - - THE HEART PUMPI NG ASPECTS
9 OF C. P. R. , CORRECT?
10 A YES, MA' AM.
11 Q YOU WERE ASKED ABOUT C. P. R. BEI NG DONE - -
12 MORE APPROPRI ATELY DONE NOT ON A BED, I T' S BETTER TO DO
13 I T ON A HARD SURFACE?
14 A YES, MA' AM.
15 Q I S THAT BECAUSE YOU' RE SUPPOSED TO COMPRESS
16 THE CHEST - - THE RI B CAGE ABOUT 2 I NCHES TO GET
17 ADEQUATE SQUEEZI NG OF THE HEART TO PUSH THE BLOOD
18 THROUGH THE BODY?
20 Q I T' S A PRETTY BI G COMPRESSI ON OF THE RI BS,
21 RI GHT?
22 A YES.
23 Q OFTEN, RI BS GET BROKEN WHEN C. P. R. I S DONE
24 PROPERLY?
25 A THE COMMON LAY TERM I S THAT RI BS GET
26 BROKEN. I T' S NOT REALLY THAT THE RI BS GET BROKEN, I T' S
27 THAT - - THE RI BS ARE HERE ON YOUR SI DES, AND THEY' RE
28 HELD TOGETHER WI TH CARTI LAGE RI GHT HERE, AND THAT
866 299-5127
2327
1 CONNECTI ON, WHI CH I S CARTI LAGE, I T' S NOT REALLY BONE,
2 THAT' S WHAT BREAKS. AND I T ALWAYS BREAKS.
3 Q OKAY. I F THE C. P. R. I S DONE PROPERLY?
4 A YES.
5 Q WERE YOU ABLE TO ASSESS WHETHER THAT
6 CARTI LAGE CONNECTI ON WAS BROKEN WHEN YOUR TEAM BEGAN
7 RESUSCI TATI VE EFFORTS?
8 A I DI DN' T - - I WAS NOT THE FI RST PERSON TO
9 DO CHEST COMPRESSI ONS. THE FI RST PERSON TO DO CHEST
10 COMPRESSI ONS WOULD KNOWRI GHT AWAY, BECAUSE AS SOON AS
11 THEY GO TO COMPRESS - -
12 Q YOU FEEL I T?
13 A YEAH, YOU FEEL I T CRACK.
14 Q OKAY. AND I BELI EVE YOU SAI D YOU HELP
15 RECERTI FY E. M. T. ' S NOWI N YOUR CURRENT POSI TI ON.
17 Q DOES THAT I NCLUDE C. P. R. TRAI NI NG?
18 A YES.
19 Q OKAY. SO FAI R TO SAY THAT YOU ARE AN
20 EXPERT I N THE PROPER - - PROPER METHODS OF ADMI NI STERI NG
21 C. P. R. ?
22 A I ' M VERY FAMI LI AR WI TH I T.
23 Q OKAY. AND I N YOUR EXPERI ENCE, I S I T - - DO
24 PHYSI CI ANS GENERALLY KNOWHOWTO PROPERLY RENDER
25 C. P. R. ?
26 MR. PANI SH: OBJ ECTI ON; FOUNDATI ON AS TO
27 PHYSI CI ANS.
28 THE COURT: SUSTAI NED AS TO FOUNDATI ON.
866 299-5127
2328
1 MS. CAHAN: OKAY.
2 Q YOU I NTERACT WI TH PHYSI CI ANS FROM TI ME TO
3 TI ME, CORRECT?
4 A YES, MA' AM.
5 Q AT HOSPI TALS?
6 A YES, MA' AM.
7 Q AND I THI NK YOU SAI D YOU DI D 1, 000 HOURS OF
8 SPECI ALI ZED TRAI NI NG TO BECOME A PARAMEDI C THAT
9 I NCLUDED HOSPI TAL TRAI NI NG AND E. R. AND THE I . C. U.
10 A YES, MA' AM.
11 Q AND CLASSROOM TRAI NI NG WI TH PHYSI CI ANS AND
12 NURSES?
13 A YES, MA' AM.
14 Q OKAY. SO YOU' VE HAD AN OPPORTUNI TY TO
15 OBSERVE PHYSI CI ANS ADMI NI STERI NG C. P. R. ?
16 A YES, MA' AM.
17 Q HOWOFTEN, I F YOU CAN ESTI MATE, HAVE YOU
18 SEEN A PHYSI CI AN APPARENTLY UNABLE TO RENDER ADEQUATE
19 C. P. R. ?
20 A THE - - THE PROBLEM HERE I S - - OF ANSWERI NG
21 THI S QUESTI ON I S PHYSI CI ANS RARELY DO C. P. R. THEY - -
22 THEY DI RECT, THEY COMMAND, THEY' RE THE GENERAL, AND
23 I T' S THE NURSES AND THE PARAMEDI CS AND THE TECHS THAT
24 DO THE C. P. R. , SO THE ONLY TI ME I WI LL EVER SEE A
25 PHYSI CI AN DOI NG C. P. R. I S I N A DOCTOR' S OFFI CE WHERE
26 SOMETHI NG HAS GONE SOUTH.
27 Q AND WHEN YOU' VE SEEN THAT, DO THE
28 PHYSI CI ANS TYPI CALLY RENDER APPROPRI ATE C. P. R. ?
866 299-5127
2329
1 A THEY DO OKAY.
2 Q OKAY. YOU SPOKE A LI TTLE BI T EARLI ER ABOUT
3 A DEFI BRI LLATOR BEI NG ONE OF THE PI ECES OF EQUI PMENT
4 THAT' S ON THE RI G.
5 A YES, MA' AM.
6 Q I N WHAT CI RCUMSTANCES WOULD YOU USE A
7 DEFI BRI LLATOR?
8 A WE DON' T USE A DEFI BRI LLATOR NEAR AS MUCH
9 AS YOU WOULD SEE I N THE MOVI ES. WE ONLY DO I T TO
10 DEFI BRI LLATE. TO DEFI BRI LLATE I S - - BECAUSE MOST OF
11 THE TI ME WHEN YOUR HEART I S HAVI NG A PROBLEM, THE
12 DEFI BRI LLATOR I S NOT GOI NG TO SOLVE THE PROBLEM, BUT
13 THERE' S ONE I NCI DENT WHERE I T DOES.
14 THAT' S WHEN YOU GO I NTO FI BRI LLATI ON. YOUR
15 HEART NORMALLY PUMPS WI TH A VERY SYNCHRONI ZED MOTI ON.
16 I T GOES BOOM, BOOM, BOOM, BOOM AND I T DOES I TS THI NG.
17 BUT THERE' S FOUR CHAMBERS I N THE HEART, AND THEY ALL
18 HAVE TO BEAT I N SYNCHRONI CI TY FOR I T TO WORK.
19 BUT WHEN THE HEART GETS CONFUSED
20 ELECTRI CALLY SPEAKI NG, BECAUSE THE HEART CONTRACTS
21 EVERY TI ME I T GETS AN ELECTRI CAL STI MULI , THE HEART
22 WON' T PUMP I N SEQUENCE ANY MORE, AND THE HEART
23 LI TERALLY LOOKS LI KE A BOWL FULL OF J ELLO WI GGLI NG,
24 I T' S NOT PUMPI NG EFFECTI VELY ANYMORE, SO YOUR BLOOD
25 PRESSURE DROPS AND SO DO YOU.
26 WHEN WE SHOCK YOU WI TH A DEFI BRI LLATOR, I T
27 STOPS ALL OF THAT AND GI VES THE HEART A CHANCE TO TAKE
28 A BREATH AND START FI RI NG I N SEQUENCE AGAI N. BUT MOST
866 299-5127
2330
1 PATI ENTS DON' T NEED TO BE DEFI BRI LLATED.
2 Q SO AM I CORRECT I N UNDERSTANDI NG THAT WHEN
3 A HEART I S FUNCTI ONI NG PROPERLY, THERE' S AN ELECTRI CAL
4 PULSE, AND THEN THE MUSCLE OF THE HEART I S SQUEEZI NG ON
5 I TS OWN I N A REGULAR RHYTHM?
6 A CORRECT.
7 Q OKAY. AND THAT' S WHY WHEN YOU WERE TALKI NG
8 ABOUT THE E. K. G. , ONE OF THE THI NGS I T MONI TORS, THE
9 ELECTRI CAL I MPULSES I N THE HEART, GI VES YOU AN
10 I NDI CATI ON OF WHETHER THE HEART I S GETTI NG THE CURRENT,
11 SO TO SPEAK, NECESSARY TO DO THOSE SQUEEZI NG MOTI ONS?
12 A THE E. K. G. ONLY MONI TORS THE ELECTRI CAL
13 ACTI VI TI ES THAT' S GOI NG ON I N THE HEART, BUT I T DOES
14 NOT RECORD OUR - - PI CK UP OR EVEN REGI STER THE
15 MECHANI CAL PART, SO YOU CAN HAVE A PERFECT E. K. G. AND
16 HAVE NO PULSE WHATSOEVER.
17 Q AND YOU SAI D, SI R, AT NO TI ME DI D YOU OR A
18 TEAM MEMBER DETECT A PULSE?
20 Q YOU BELI EVED MR. J ACKSON HAD BEEN DEAD FOR
21 SOME TI ME BEFORE YOU ARRI VED?
22 A YES, MA' AM.
23 Q NOT J UST DOWN FOR A FEWMI NUTES?
24 A YES, MA' AM.
25 Q SO DR. MURRAY, I T SEEMED TO YOU, WASN' T
26 TELLI NG YOU THE TRUTH?
27 A I - - I DON' T EVEN GO THERE. I ' M NOT
28 WORRI ED ABOUT THAT. I ' M WORRI ED ABOUT THE PATI ENT AND
866 299-5127
2331
1 ALL THE I NFORMATI ON I CAN GET. I ' M MORE OF THE - - I ' M
2 J UST - - FI GURED THAT HE HAD A LOT GOI NG ON. I DON' T
3 KNOWI F HE WAS I NTENTI ONALLY LYI NG OR NOT.
4 Q BUT I N YOUR - - I T WAS YOUR I MPRESSI ON THAT
5 WHAT HE WAS TELLI NG YOU DI DN' T ADD UP WI TH WHAT YOU
6 WERE SEEI NG I N MR. J ACKSON, CORRECT?
7 A THAT' S CORRECT, I T WAS NOT ACCURATE.
8 Q I N YOUR EXPERI ENCE, ARE PEOPLE USUALLY
9 FORTHCOMI NG WI TH I NFORMATI ON WHEN YOU GO TO HELP
10 ASSESS, RESCUE THEM?
11 A YES, MA' AM.
12 Q AND THAT' S TRUE AS TO THE PATI ENTS AND THE
13 PEOPLE WHO ARE AROUND THE PATI ENT?
14 A YES, MA' AM.
15 Q I S ONE OF THE THI NGS YOU TYPI CALLY ASK
16 ABOUT WHETHER THERE' S BEEN ANY RECREATI ONAL DRUG USE
17 I NVOLVED?
18 A YES, MA' AM.
19 Q AND WHY I S THAT?
20 A BECAUSE PEOPLE TEND TO KEEP RECREATI ONAL
21 DRUGS A SECRET, BUT THERE' S A LOT OF RECREATI ONAL DRUGS
22 OUT THERE THAT CAN HAVE ALL KI NDS OF WI LD EFFECTS ON
23 YOU, AND SOME OF THEM, WE ACTUALLY CARRY THE ANTI DOTES
24 FOR, SO I T' S A BI G AI D WHEN WE GET A HEAD START.
25 Q I S THAT A QUESTI ON YOU ASKED DR. MURRAY?
26 A RECREATI ONAL DRUGS?
27 ACTUALLY, I DON' T RECALL I F I ASKED THAT OR
28 NOT. I T' S A STANDARD QUESTI ON.
866 299-5127
2332
1 Q YOU' VE TREATED PATI ENTS WHO ARE UNDER THE
2 I NFLUENCE OF DRUGS, CORRECT?
3 A YES, MA' AM.
4 Q MANY TI MES?
5 A MANY, MANY, MANY TI MES.
6 Q AND YOU OFTEN DON' T FI ND OUT UNTI L LATER
7 THAT THEY WERE UNDER THE I NFLUENCE OF DRUGS?
8 A I OFTEN FI ND OUT LATER WHAT THE DRUG WAS.
9 Q OKAY. AND HAVE YOU HAD CASES WHERE THE
10 PEOPLE CLOSE TO THE PATI ENT ARE NOT AWARE OF WHAT DRUGS
11 THE PATI ENT MAY HAVE TAKEN?
12 A YES, MA' AM.
13 Q I S THAT COMMON?
14 A YES, MA' AM.
15 Q HAVE YOU HAD CASES WHERE A PATI ENT' S FAMI LY
16 MEMBERS DON' T KNOWWHAT DRUGS THE PATI ENT HAS BEEN
17 TAKI NG?
18 A YES, MA' AM.
19 Q COMMON?
20 A YES, MA' AM.
21 Q OKAY. AND WHEN - - I N THE CI RCUMSTANCES - -
22 STRI KE THAT.
23 ARE SOME OF THOSE CI RCUMSTANCES I LLEGAL
24 DRUGS AS OPPOSED TO PRESCRI PTI ON DRUGS?
25 A YES, MA' AM.
26 Q AND I S THAT BECAUSE DRUG ADDI CTS ARE OFTEN
27 I NTERESTED I N KEEPI NG THEI R DRUG ABUSE SECRET, THEY
28 DON' T TELL THE PEOPLE AROUND THEM WHAT THEY' RE DOI NG?
866 299-5127
2333
1 MR. PANI SH: THERE' S NO FOUNDATI ON FOR THI S
2 WI TNESS.
3 THE COURT: SUSTAI NED.
4 Q BY MS. CAHAN: DO YOU REMEMBER BEI NG ASKED
5 AT THE PRELI MI NARY HEARI NG FOR DR. MURRAY ABOUT YOUR
6 EXPERI ENCE WI TH TREATI NG PEOPLE WHO YOU LATER FI ND OUT
7 ARE ABUSI NG DRUGS?
8 MR. PANI SH: I T' S I RRELEVANT.
9 THE COURT: COULD YOU RE- ASK THE QUESTI ON?
10 MR. PANI SH: I T' S ALSO AN I MPROPER QUESTI ON.
11 Q BY MS. CAHAN: DO YOU REMEMBER BEI NG ASKED
12 AT THE PRELI MI NARY HEARI NG - - DO YOU REMEMBER YOU WERE
13 CALLED TO TESTI FY AT A PRELI MI NARY HEARI NG FOR
14 DR. MURRAY I N THE CRI MI NAL PROCEEDI NGS?
15 A YES, MA' AM.
16 Q OKAY. AND DO YOU REMEMBER BEI NG ASKED
17 THERE ABOUT YOUR EXPERI ENCE I N TRYI NG TO HELP PEOPLE
18 WHO YOU THEN FI ND OUT HAVE BEEN ABUSI NG DRUGS?
19 MR. PANI SH: SAME OBJ ECTI ON. I T' S NOT RELEVANT,
20 FOUNDATI ON.
21 THE COURT: OVERRULED.
22 THE WI TNESS: I ' M SORRY. DOES THAT MEAN I
23 ANSWER?
24 THE COURT: YOU CAN ANSWER.
25 THE WI TNESS: ALL RI GHT.
26 YES, I DO REMEMBER BEI NG ASKED ABOUT
27 DRUGS - - PEOPLE TAKI NG DRUGS.
28 MS. CAHAN: OKAY.
866 299-5127
2334
1 Q AND DO YOU REMEMBER SAYI NG THAT I T WAS NOT
2 UNUSUAL FOR PEOPLE AROUND THE DRUG USER TO TELL YOU
3 THAT THEY HAD NO I DEA THAT THE PERSON WAS USI NG DRUGS?
4 MR. PANI SH: OBJ ECTI ON; I MPROPER USE OF PRI OR
5 TESTI MONY.
6 THE COURT: I T' S I MPROPER I MPEACHMENT.
7 MR. PANI SH: AND I T' S ALSO CONTRARY TO YOUR PRI OR
8 RULI NG.
9 MS. CAHAN: I ' LL ASK A FRESH QUESTI ON.
10 Q I N YOUR EXPERI ENCE, I S I T UNUSUAL FOR
11 FRI ENDS, FAMI LY MEMBERS, PEOPLE AROUND A PATI ENT TO
12 TELL YOU THAT THEY DI DN' T KNOWTHE PATI ENT WAS ABUSI NG
13 DRUGS?
14 MR. PANI SH: SAME OBJ ECTI ONS.
15 THE COURT: I S I T USUAL WHEN YOU ATTEND TO - -
16 I ' M - - I DON' T UNDERSTAND YOUR QUESTI ON. MAYBE YOU CAN
17 RE- ASK I T.
18 MS. CAHAN: SURE.
19 Q I S I T TYPI CAL - - WHEN YOU' RE DEALI NG WI TH A
20 SI TUATI ON WHERE SOMEONE HAS OVERDOSED, SAY, ARE THE
21 FRI ENDS AND FAMI LY MEMBERS AROUND OFTEN SAYI NG THEY' RE
22 SURPRI SED - - TELL YOU THEY' RE SURPRI SED, THEY DI DN' T
23 KNOWTHE PERSON WAS TAKI NG DRUGS?
24 THE COURT: OVERRULED.
25 MR. PANI SH: I DI DN' T OBJ ECT.
26 MS. CAHAN: YOU CAN ANSWER THAT ONE. WE GOT
27 THERE, FI NALLY.
28 THE COURT: I WAS ANTI CI PATI NG THE OBJ ECTI ON.
866 299-5127
2335
1 MR. PANI SH: I DI DN' T DO I T.
2 THE WI TNESS: SO THE QUESTI ON I S, I S I T TYPI CAL
3 FOR FRI ENDS AND FAMI LY NOT TO - - I ' M SORRY.
4 Q BY MS. CAHAN: I N AN OVERDOSE SI TUATI ON, I S
5 I T TYPI CAL FOR FRI ENDS AND FAMI LY MEMBERS AROUND TO SAY
6 SOMETHI NG TO THE EFFECT OF, " I DI DN' T KNOW" ?
7 A YES, I T' S TYPI CAL.
8 Q THANK YOU.
9 YOU WERE ASKED SOME QUESTI ONS ABOUT THE
10 DI FFI CULTY OF FI NDI NG A VEI N I N MR. J ACKSON.
11 A YES, MA' AM.
12 Q AND YOU SAI D HE HAD NO BLOOD PRESSURE AT
13 THE TI ME, SO HI S VEI NS WERE COLLAPSED?
14 A YES, MA' AM.
15 Q ARE YOU AWARE OF ANY I NFORMATI ON THAT
16 MR. J ACKSON' S VEI NS WERE SCLEROTI C?
17 A SCLEROTI C I S WHEN YOU GET SCAR TI SSUE ON
18 THE VEI NS, AND THEY GET HARD, YOU CAN FEEL I T WHEN YOU
19 PUT THE NEEDLE I T. I T MAKES I T A LOT MORE DI FFI CULT TO
20 GET THE I . V. I ONLY STUCK AN I . V. I N HI S NECK, AND I
21 DI DN' T FEEL ANY SCLEROSI S THERE. PARAMEDI C GOODWI N DI D
22 NOT MENTI ON I T TO ME.
23 Q OKAY. AND YOU PUT THE I . V. I N THE J UGULAR,
24 WHI CH I S THAT VEI N I N THE NECK THAT TAKES THE BLOOD
25 FROM THE BRAI N BACK TO THE HEART?
27 Q OKAY. AND BEFORE THAT, THOUGH, MR. J ACKSON
28 HAD AN I . V. ON HI S LOWER LEFT CALF, I THI NK YOU SAI D?
866 299-5127
2336
1 A YES, LEFT - - LEFT LEG, THE CALF, I NSI DE.
2 Q I S THAT AN UNUSUAL PLACE TO HAVE AN I . V.
3 POSI TI ONED?
4 A I ' VE SEEN I T BEFORE; BUT I T' S UNUSUAL, YES.
5 Q OKAY. AND WHERE ARE I . V. ' S NORMALLY PUT?
6 I N THE ARMS?
7 A USUALLY, YES.
8 Q WHY?
9 A ACCESSI BI LI TY.
10 Q OKAY. I N WHAT CI RCUMSTANCES WOULD YOU
11 PLACE AN I . V. I N SOMEONE' S LOWER LEG?
12 A I WI LL - - I T' S A DI FFI CULT PLACE TO PLACE
13 AN I . V. , SO I NORMALLY WOULD NOT DO I T.
14 Q HAVE YOU EVER DONE I T?
15 A I ' VE NEVER - - I ' VE NEVER PUT ONE I N THAT
16 AREA OF THE LEG. FEET, YES; HANDS, YES; BUT NOT - - NOT
17 I N THE CALF THERE, NO.
18 Q OKAY. YOU SAI D THAT DR. MURRAY WAS
19 I NVOLVED WI TH ADMI NI STERI NG OF MEDI CAL TREATMENTS TO
20 MR. J ACKSON DURI NG THE TI ME THAT YOU WERE PRESENT AT
21 HI S HOME, CORRECT?
22 A YES, MA' AM.
23 Q OKAY. AND HE ACTUALLY WENT I NTO THE BAG
24 WI TH MEDI CATI ON, OR THE BOX OF MEDI CATI ON THAT YOUR
25 TEAM HAD BROUGHT?
26 A YES, MA' AM.
27 Q AND WHY DI D YOU PERMI T HI M TO DO THAT?
28 A HE' S A CARDI OLOGI ST, A DOCTOR, AND WHAT HE
866 299-5127
2337
1 WAS DOI NG WAS REASONABLE AT THE TI ME, THE MEDI CATI ONS
2 HE WAS TAKI NG.
3 Q DI D HE TELL YOU HE WAS MR. J ACKSON' S
4 PERSONAL - - PERSONAL MEDI CAL DOCTOR? I S THAT WHY YOU
5 WROTE THAT ON THE FORM?
6 A YES, MA' AM.
7 THE COURT: LET' S STOP THE EXAMI NATI ON AND WE' LL
8 RESUME AT 1: 30. HAVE A GOOD LUNCH, WE' LL SEE YOU AT
9 1: 30.
10
11 ( THE NOON RECESS WAS TAKEN UNTI L
12 1: 30 P. M. OF THE SAME DAY. )
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866 299-5127
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THE COURT: KATHERI NE J ACKSON VERSUS A. E. G.
LI VE, BC 445597.
GOOD AFTERNOON, EVERYONE.
MR. PUTNAM: GOOD AFTERNOON, YOUR HONOR.
THE COURT: WOULD YOU LI KE TO TALK ABOUT
SOMETHI NG?
MR. PANI SH: J UST WOULD LI KE TO KNOWABOUT THE
SCHEDULE, BECAUSE I HAVE WI TNESSES ON CALL. I VI SI TED
WI TH NELLI E, AND SHE SAI D YOU WERE GOI NG TO LEAVE I T UP
TO THE J URORS.
I UNDERSTAND YOU HAVE A PRETTY BUSY CALENDAR
TOMORROW; THAT I T' S POSSI BLE THAT WE COULD START AT
10: 00. I T' S ALSO POSSI BLE WE COULD START AT 10: 30, AND
I T WAS I NDI CATED THAT YOU WOULD PROBABLY STOP AT 11: 00.
THE COURT: WELL, THAT' S THE TI ME I TOLD THE
J UROR WE WOULD STOP.
MR. PANI SH: NO, NO. I ' M J UST TRYI NG TOUN-
DERSTAND THE SI TUATI ON. I WOULD NOT WANT TO KEEP THE
J UROR FROM HI S FUNERAL. I UNDERSTAND THAT COMPLETELY.
866 299-5127
2339
1 SO, I MEAN, YOU KNOW, I ' M GOI NG TO BRI NG A WI TNESS FOR
2 HALF AN HOUR?
3 THE COURT: WELL, NO. I WAS THI NKI NG 10: 00 OR
4 10: 30. I WAS HOPI NG WE COULD GET AT LEAST AN HOUR I N,
5 BUT I WAS GOI NG TO LEAVE I T TO THE J URORS AND TALK TO
6 YOU AS TO WHAT YOU WANT TO DO.
7 I DON' T KNOWWHAT YOUR PREFERENCES ARE. I
8 COULD GO EI THER WAY.
9 MR. PANI SH: I MEAN, I J UST - - I DON' T THI NK
10 ANY WI TNESSES ARE GOI NG TO GET DONE I N AN HOUR OR HALF
11 AN HOUR.
12 THE COURT: THEY WON' T GET DONE I N AN HOUR, BUT
13 WE COULD MAKE HEADWAY. I DON' T KNOWWHAT WI TNESS YOU' RE
14 GOI NG TO HAVE ON OR WHO I T I S.
15 MR. PANI SH: YOU WANT TO CONFER?
16 MR. PUTNAM: I DON' T KNOWWHO THE WI TNESS I S.
17 MR. PANI SH: WELL, I F MR. MARTI NEZ I S STI LL ON,
18 WE CAN CARRYOVER WI TH HI M.
19 THE COURT: HE I S THE WI TNESS COMI NG I N AFTER
20 THI S PERSON?
21 MR. PANI SH: YEAH. HE' S L. A. P. D. THE OTHER
22 GUY' S FROM THE CORONER' S OFFI CE, SO THAT' S GOI NG TO BE
23 MORE OF A PROBLEM.
24 SO WHY DON' T WE - -
25 THE COURT: YOU WANT TO REVI SI T THI S AT THE END
26 OF THE DAY?
27 MR. PANI SH: YEAH. CAN WE AGREE THAT I F
28 MR. MARTI NEZ NEEDS TO COME BACK, THAT WE COULD DO HI M?
866 299-5127
2340
1 I F WE FI NI SH HI M, THEN WE CANNOT COME. I MEAN, WE CAN
2 BE HERE, BUT NOT THE J URY.
3 MS. BI NA: AND ON THURSDAY WE CAN BRI NG THE
4 WI TNESSES FROM WEDNESDAY?
5 MR. PANI SH: WELL, I DON' T THI NK ONE OF THEM
6 CAN COME ON THURSDAY. THAT' S THE PROBLEM. ONE CAN, AND
7 ONE' S GOI NG TO GO OUT OF TOWN ON THURSDAY, SO WE' D HAVE
8 TO SUBSTI TUTE SOMEBODY ELSE I N.
9 MS. BI NA: BUT YOU' LL LET US KNOW?
10 MR. PANI SH: SURE. J UST FI NDI NG OUT RI GHT NOW
11 WHAT' S GOI NG ON.
12 THE COURT: OKAY. ALL RI GHT. LET' S - -
13 MR. PANI SH: AND WE CAN PROCEED I N THAT ORDER.
14 OH, WHI LE WE' RE HERE, THI S WHOLE I SSUE WI TH
15 DR. MURRAY' S POLI CE STATEMENT. NOW, OBVI OUSLY DETECTI VE
16 MARTI NEZ WAS I NVOLVED. I DON' T I NTEND TO GET I NTO I T,
17 AND I HAVE MOTI ONS, AND I OBJ ECTED TO I T BEI NG
18 I NTRODUCED I N THE OPENI NG STATEMENT. THE COURT
19 OVERRULED I T FOR THAT TI ME.
20 I WOULD ASK THAT WE NOT GET I NTO I T NOW. I
21 KNOWTHERE' S GOI NG TO BE BRI EFI NG. I F THERE' S SOMETHI NG
22 THAT' S ALLOWED, HE CAN ALWAYS COME BACK AND ADDRESS THAT
23 LATER, SO WE DON' T HAVE TO HAVE A BI G FI GHT WHEN THAT
24 COMES UP.
25 MR. PUTNAM: I WAS GOI NG TO DO A SI DEBAR, SO
26 THI S I S PERFECT.
27 THE ONE I SSUE ON THI S, YOUR HONOR, I COMPLETELY
28 AGREE THAT WE DON' T NEED TO GO DOWN THAT ROAD EXCEPT
866 299-5127
2341
1 WHI LE HE' S HERE FOR AUTHENTI CATI ON, WHI CH MAY NOT BE A
2 PROBLEM. BUT, OBVI OUSLY, HE WOULD BE THE PERSON TO
3 AUTHENTI CATE THE AUDI O FI LE, AS WELL AS THE TRANSCRI PT,
4 LI KE HE DI D AT THE CRI MI NAL TRI AL. I F YOU STI PULATE TO
5 THAT, THEN I DON' T HAVE TO DO THAT.
6 MR. PANI SH: J UST SHOWME WHAT I T I S.
7 MR. PUTNAM: THE ONE YESTERDAY, THE TRANSCRI PT
8 AND THE AUDI O. I ' LL GET YOU THE EXHI BI TS.
9 MR. PANI SH: I F I T' S WHAT' S ADMI TTED I N THE
10 CRI MI NAL TRI AL, I MEAN - -
11 MR. PUTNAM: YES. SAME EXACT ONE.
12 MR. PANI SH: J UST SHOWI T TO ME, AND I DON' T
13 THI NK THAT' S A PROBLEM.
14 THE COURT: SO YOU DON' T HAVE TO GET I NTO I T AT
15 ALL?
16 MR. PANI SH: RI GHT. I DON' T WANT TO GET I NTO
17 THE WHOLE SI DEBAR. I ' D RATHER GET THE OTHER STUFF NOW,
18 AND THEN I F AND WHEN THAT I SSUE ARI SES, WE CAN DEAL WI TH
19 I T. I DON' T THI NK HE I S GOI NG TO GO ANYWHERE.
20 MS. BI NA: WE' RE GOI NG TO GET THE COPI ES.
21 THE COURT: CAN WE DO THAT LI KE - -
22 MR. PUTNAM: I ' LL HAVE THEM PULL I T RI GHT NOW.
23 MS. BI NA: HAVE THEM HAND I T TO HI M - -
24
25 ( THE J URY ENTERED THE COURTROOM AT 1: 42 P. M. )
26
27 THE COURT: KATHERI NE J ACKSON VERSUS A. E. G.
28 LI VE, BC 445597.
866 299-5127
2342
1 GOOD AFTERNOON, EVERYBODY.
2 THE J URY: GOOD AFTERNOON.
3 THE COURT: LET' S CONTI NUE WI TH THE
4 CROSS- EXAMI NATI ON OF MR. SENEFF.
5 THE WI TNESS: SENEFF, YOUR HONOR.
6 THE COURT: OKAY.
7
8 CROSS- EXAMI NATI ON ( RESUMED)
9 BY MS. CAHAN:
10 Q GOOD AFTERNOON, MR. SENEFF.
11 A GOOD AFTERNOON.
12 Q DI D YOU HAVE A GOOD LUNCH?
13 A I HAD AN EXCELLENT LUNCH. THANK YOU.
14 Q GOOD.
15 SO RI GHT BEFORE THE BREAK WE WERE TALKI NG ABOUT
16 DR. MURRAY I DENTI FYI NG HI MSELF TO YOU AS MI CHAEL
17 J ACKSON' S PERSONAL PHYSI CI AN?
18 A YES, MA' AM.
19 Q DI D HE SAY, " I AM MI CHAEL J ACKSON' S DOCTOR, " OR
20 DI D HE SAY, " I ' M HI S DOCTOR, " OR WHAT DI D HE SAY TO YOU?
21 A HE SAI D, " I ' M HI S CARDI OLOGI ST. "
22 Q OKAY. AND AT THAT POI NT DI D YOU RECOGNI ZE
23 MR. J ACKSON?
24 A NO, MA' AM.
25 Q DI D HE HAVE A WI G OR ANY MAKEUP ON WHEN YOU SAW
26 HI M?
27 A HE HAD A SURGI CAL CAP COVERI NG ALL OF HI S HAI R.
28 MAKEUP, I DON' T THI NK SO.
866 299-5127
2343
1 Q NOT THAT YOU NOTI CED?
2 A NO.
3 Q OKAY.
4 AND YOU' VE TESTI FI ED EARLI ER THAT I T WAS AROUND
5 12: 30 I N THE AFTERNOON WHEN YOU GOT THERE. I THI NK YOU
6 SAI D 12: 26.
7 A 12: 26, YES.
8 Q AND MR. J ACKSON WAS I N HI S BEDROOM?
9 A YES, MA' AM.
10 Q WERE THE CURTAI NS CLOSED? WAS I T DARK I N
11 THERE?
12 A I DO NOT RECALL.
13 Q OKAY. AND WHEN YOU FI RST CAME UP, YOU SAW- -
14 YOU WERE THE FI RST PERSON I NTO THE BEDROOM; CORRECT?
15 A YES, MA' AM.
16 Q AND DR. MURRAY AND A SECURI TY PERSON WERE I N
17 THE COURSE OF MOVI NG MR. J ACKSON FROM THE BED TO THE
18 FLOOR NEXT TO THE BED, AND THEN YOU TESTI FI ED THAT YOU
19 SUBSEQUENTLY MOVED HI M TO THE FOOT OF THE BED?
21 Q OKAY. AND DI D HE HAVE THE I V I N HI S LEG AT
22 THAT TI ME?
23 A YES.
24 Q DO YOU REMEMBER WHERE THE I V POLE WAS?
25 A YES. I T WAS AT THE FOOT OF THE BED - -
26 Q OKAY.
27 A - - NEXT TO WHERE HI S RI GHT FOOT WOULD HAVE BEEN
28 I F HE HAD STAYED ON THE BED. I T WAS NEXT TO THE RI GHT
866 299-5127
2344
1 FOOT.
2 Q BUT AT THAT POI NT HE WAS BEI NG MOVED TO THE
3 FLOOR?
4 A WELL, I F HE WAS LAI D ON THE BED, THE POLE WAS
5 POSI TI ONED WHERE HI S RI GHT FOOT WOULD HAVE BEEN. BUT,
6 YES, HE WAS MOVED TO THE FLOOR.
7 Q WHEN YOU MOVED HI M TO THE FOOT OF THE BED, DI D
8 YOU MOVE THE I V POLE, TOO?
9 A YES, MA' AM.
10 Q YOU SAI D HE WAS WEARI NG PAJ AMAS?
11 A YES, MA' AM.
12 Q AND A SURGI CAL CAP. I S THAT LI KE THOSE BLUE
13 CAPS YOU SEE ON DOCTORS?
14 A I T WAS SOMETHI NG LI KE THAT. BLUE SURGI CAL,
15 ELASTI C, THI N COTTON. COVERED HI S ENTI RE HAI RLI NE.
16 Q AND THERE WAS MEDI CAL EQUI PMENT AROUND?
17 A YES, MA' AM.
18 Q BOTTLES OF MEDI CATI ON?
19 A YES, MA' AM.
20 Q OXYGEN TANKS?
21 A YES.
22 Q DO YOU REMEMBER OXYGEN BOTTLES?
23 A WE CALL THEM 02 BOTTLES.
24 Q OKAY. HOWBI G WERE THOSE?
25 A THEY WERE - - I THI NK THEY WERE E CYLI NDERS.
26 YEAH, THEY' RE ABOUT LI KE THAT ( I NDI CATI NG) .
27 Q OKAY. AND THEY' RE BI G METAL?
28 A YEAH. THEY' RE ABOUT - -
866 299-5127
2345
1 THE COURT: ABOUT THREE, FOUR FEET TALL?
2 THE WI TNESS: I ' D SAY THREE FEET TALL BY EI GHT
3 I NCHES I N DI AMETER.
4 Q BY MS. CAHAN: AND THERE WERE MORE THAN ONE OF
5 THOSE?
6 A I DI DN' T EVEN COUNT. THERE WAS MORE THAN ONE.
7 Q OKAY. AND WE TALKED ABOUT THE I V POLE WI TH THE
8 BAG HANGI NG FROM I T.
9 A YES, MA' AM.
10 Q ANY OTHER MEDI CAL EQUI PMENT THAT YOU REMEMBER
11 SEEI NG AT THAT TI ME?
12 A THE OXYGEN, THE I V BAG, THE POLE. NO, I DON' T
13 REMEMBER SEEI NG ANYTHI NG ELSE SPECI FI CALLY, OTHER THAN
14 THE MEDI CATI ONS AND - - NO. THERE WAS STUFF ON THE
15 NI GHTSTAND, BUT I DI DN' T GET OVER AND LOOK.
16 Q WAS THE ROOM KI ND OF A MESS?
17 A NO, NOT REALLY. J UST A LOT OF THI NGS ON THE
18 NI GHTSTAND.
19 Q OKAY. AND YOU SAI D THAT MR. J ACKSON LOOKED
20 PALE TO YOU, AND HI S EXTREMI TI ES WERE BLUE?
21 A YES.
22 Q CONSI STENT WI TH SOMEONE WHO HAD BEEN DEAD FOR
23 SOME TI ME OR CONSI STENT WI TH SOMEBODY WHO HAD NOT HAD
24 OXYGEN GOI NG TO THEI R BODY FOR SOME TI ME?
25 A YES.
26 Q AND HE LOOKED UNDERWEI GHT TO YOU?
27 A YES.
28 Q AND DR. MURRAY WAS PRESENT?
866 299-5127
2346
1 A YES.
2 Q AND I T WAS THE TOTALI TY OF ALL THOSE
3 CI RCUMSTANCES THAT LED YOU TO I NI TI ALLY THI NK THAT HE
4 MI GHT BE A HOSPI CE PATI ENT OR SOMEONE I N GRAVE PHYSI CAL
5 CONDI TI ON?
6 A THAT' S CORRECT. THE TOTALI TY.
7 Q OKAY. AND THE MEDI CAL EQUI PMENT THAT YOU
8 TALKED ABOUT, I S I T FAI R TO SAY THAT I SN' T THE KI ND OF
9 EQUI PMENT YOU NORMALLY SEE I N SOMEONE' S HOME WHO I S NOT
10 A HOSPI CE PATI ENT OR OTHERWI SE SUFFERI NG FROM A SERI OUS
11 DI SEASE?
12 A THAT' S FAI R TO SAY, WI TH THE EXCEPTI ON I T' S NOT
13 UNCOMMON TO SEE OXYGEN I N PEOPLE' S HOME. SOMETI MES
14 PEOPLE HAVE OXYGEN, ESPECI ALLY EMPHYSEMA PATI ENTS. BUT
15 YOU DON' T SEE I V POLES HANGI NG I N PEOPLE' S ROOMS. YOU
16 J UST DON' T.
17 Q DI D YOU SEE ANYTHI NG I NDI CATI NG TO YOU WHAT THE
18 OXYGEN WAS BEI NG USED FOR, I F ANYTHI NG?
19 A I - - NO, I DI DN' T.
20 Q OKAY. I ' VE SEEN THESE CLEAR PLASTI C TUBES
21 SOMETI MES THAT GO UNDER SOMEBODY' S NOSE WHEN THEY' RE I N
22 A HOSPI TAL BED. I THI NK I T' S CALLED A NASAL CANNULA; I S
23 THAT RI GHT?
24 A THAT' S CORRECT. A NASAL CANNULA. I DI D NOT
25 SEE ONE.
26 Q AND YOU DI DN' T SEE ANY OTHER TYPE OF BREATHI NG
27 EQUI PMENT AROUND THE ONE - - ONE OF THOSE BAGS OR
28 SOMETHI NG LI KE THAT?
866 299-5127
2347
1 A I UNDERSTAND. I DI D NOT.
2 Q OKAY.
3 MS. CAHAN: CAN WE PULL UP THE - - I T' S 507,
4 PAGE 6, I BELI EVE THANKS, PAM.
5 CAN YOU ZOOM I N TO THE TOP THI RD OF THAT FORM?
6 OKAY.
7 Q BY MS. CAHAN: AND I APOLOGI ZE I F THI S WAS
8 ASKED BEFORE. I WAS TRYI NG TO FOLLOWALONG.
9 THI S I S YOUR HANDWRI TI NG ON THI S FORM? YOU
10 FI LLED I T OUT?
11 A YES, I T I S.
12 Q OKAY. AND I S THERE A PORTI ON WHERE I T ASKS
13 FOR, I N THE TOP RI GHT WHERE I T ASKS FOR WEI GHT? THERE' S
14 A WT, I THI NK THREE ROWS DOWN, TWO BOXES, THREE BOXES
15 FROM THE RI GHT?
16 A HERE ( I NDI CATI NG) ?
17 Q EXACTLY.
18 A YES.
19 Q AND DI D YOU WRI TE - - I S THAT 150?
20 A I DI D.
21 Q OKAY. AND HOWDI D YOU - - DI D YOU ACTUALLY
22 WEI GH MR. J ACKSON?
23 A NO, MA' AM.
24 Q WAS THI S AN ESTI MATE OF HI S WEI GHT?
25 A I T WAS AN ESTI MATE, YES.
26 Q OKAY. AND DI D YOU HAVE A SENSE OF HI S HEI GHT
27 AS WELL?
28 A HE WAS NOT STANDI NG UP, OF COURSE, SO HE WAS
866 299-5127
2348
1 J UST LAYI NG THERE. AND I T WAS - - I T' S HARD TO GUESS,
2 BUT HE LOOKED LI KE HE WAS 5- 9I SH, SOMETHI NG LI KE THAT.
3 BUT I DON' T REALLY REMEMBER.
4 Q HOWOFTEN DO YOU ESTI MATE - - STEP BACK A
5 SECOND.
6 GENERALLY SPEAKI NG, HOWMANY CALLS DO YOU DO I N
7 A 24- HOUR SHI FT?
8 A I N THE PAST, I USUALLY AVERAGE AROUND 10, 12
9 CALLS A DAY.
10 Q AND YOU DO 10 SHI FTS A MONTH?
11 A YES.
12 Q SO ABOUT 100, 120 CALLS A MONTH?
13 A AT LEAST.
14 Q AND YOU WORK YEAR ROUND?
15 A YES.
16 Q OKAY. AND I N THI S TI ME PERI OD, AROUND 2009,
17 WERE YOU COMMONLY THE PERSON WHO WAS FI LLI NG OUT - - THI S
18 I S A FORM THAT GETS FI LLED OUT EVERY TI ME?
19 A YES, MA' AM.
20 Q WERE YOU THE ONE TYPI CALLY FI LLI NG OUT THE
21 FORM?
22 A YES, MA' AM.
23 Q SO YOU WERE ESTI MATI NG PEOPLE' S WEI GHT 100, 120
24 TI MES A MONTH?
25 A YES.
26 Q FAI R TO SAY YOU GOT PRETTY GOOD AT MEASURI NG
27 SOMEBODY' S WEI GHT?
28 A THERE' S A CERTAI N MONOTONY TO A J OB, AND YOU
866 299-5127
2349
1 FI ND THI NGS TO AMUSE YOURSELF WI TH, AND I GOT PRETTY
2 GOOD AT I T.
3 Q YOU CAN HAVE THAT J OB AT THE COUNTY FAI R OF
4 GUESSI NG PEOPLE' S WEI GHT?
5 A YES, MA' AM.
6 MS. CAHAN: YOUR HONOR - - I ' D LI KE TO MOVE THAT
7 I NTO EVI DENCE AT THI S TI ME, YOUR HONOR.
8 MR. PANI SH: YOUR HONOR, I ' D LI KE TO MOVE ALL
9 THE EXHI BI TS THAT I MARKED I NTO EVI DENCE. I DON' T HAVE
10 ANY OBJ ECTI ON TO ANY OF THEM.
11 THE COURT: ALL RI GHT. THEY' RE RECEI VED.
12 ALL OF THEM?
13 MR. PANI SH: YES.
14
15 ( DEFENDANTS' EXHI BI T NO. 507 WAS
16 MARKED AND RECEI VED I N EVI DENCE. )
17
18 ( EXHI BI TS MARKED I N MORNI NG SESSI ON
19 WERE RECEI VED I N EVI DENCE. )
20
21 Q BY MS. CAHAN: MR. SENEFF, AS PART OF YOUR J OB,
22 YOU TREAT PATI ENTS I N EMERGENCY SI TUATI ONS; CORRECT?
23 A YES.
24 Q LI FE- OR- DEATH SI TUATI ONS?
25 A YES.
26 Q DO YOU RELY ON PATI ENTS TO BE FORTHRI GHT WI TH
27 YOU TO THE EXTENT THAT THEY' RE ABLE TO SPEAK WHEN YOU' RE
28 TREATI NG THEM?
866 299-5127
2350
1 A YES.
2 Q I S I T I MPORTANT THAT THEY TELL YOU EXACTLY WHAT
3 HAPPENED?
4 A YES.
5 Q AND TELL YOU HOWTHEY' RE FEELI NG? WHAT THEY
6 BELI EVE I S WRONG WI TH THEM?
7 A WE DON' T WANT THEM TO TELL US WHAT THEY BELI EVE
8 I S WRONG WI TH THEM BECAUSE I T WI LL LEAD YOU DOWN THE
9 WRONG PATH, BUT WE WANT THEM TO TELL US, BE FORTHRI GHT
10 I N WHAT THEY' RE FEELI NG AND WHAT' S HAPPENED.
11 Q ARE PEOPLE USUALLY FORTHRI GHT WI TH YOU?
12 A YES.
13 Q DO THEY USUALLY TELL YOU WHAT MEDI CATI ONS
14 THEY' VE TAKEN?
15 A YES.
16 Q WHETHER THEY' VE BEEN TAKI NG ANY RECREATI ONAL OR
17 I LLEGAL DRUGS?
18 A RECREATI ONALLY SPEAKI NG - - REMEMBER, I DEAL
19 WI TH PEOPLE FROM EVERY WALK OF LI FE.
20 Q UH- HUH.
21 A AND THE PEOPLE THAT LI VE ON THE STREET AND DO
22 RECREATI ONAL, NO, THEY' RE NOT GOI NG TO BE FORTHRI GHT.
23 BUT SOMEONE WHO I S AN ELDERLY PERSON WHO TAKES A LOT OF
24 PRESCRI BED MEDI CATI ONS, THEY WI LL. AND THERE' S
25 EVERYTHI NG I N BETWEEN.
26 Q I T' S I MPORTANT FOR YOU TO HAVE ACCURATE
27 I NFORMATI ON TO DETERMI NE THE PROPER COURSE OF TREATMENT?
28 A YES.
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1 Q AND DO YOU HAVE A REASON TO BELI EVE THAT A
2 PATI ENT' S PHYSI CI AN WOULD ALSO WANT TO BE FORTHRI GHT
3 WI TH YOU?
4 A I WOULD EXPECT THEM TO BE.
5 Q WHY I S THAT?
6 A HI PPOCRATI C OATH.
7 Q WHAT' S THE HI PPOCRATI C OATH, I F YOU KNOW?
8 A DOCTORS BASI CALLY SWEAR TO PUT - - TO BE
9 TRUTHFUL AND HONEST AND PUT THEI R PATI ENT' S NEEDS BEFORE
10 THEI R OWN.
11 Q SETTI NG ASI DE THI S SI TUATI ON, HAVE THERE EVER
12 BEEN TI MES WHEN YOU FELT A PHYSI CI AN WASN' T TELLI NG YOU
13 THE TRUTH ABOUT A PATI ENT' S FERVENT MEDI CAL NEEDS?
14 A I WOULDN' T BE SURPRI SED, BUT I HONESTLY CAN' T
15 RECALL EVER KNOWI NG THAT A DOCTOR WASN' T BEI NG TRUTHFUL.
16 Q OKAY. I N YOUR 28 YEARS OF DOI NG THI S?
17 A RI GHT.
18 Q FAI R TO SAY YOU WOULD TRUST A PHYSI CI AN TO BE
19 STRAI GHTFORWARD WI TH YOU TALKI NG ABOUT THE DRUGS A
20 PATI ENT HAS TAKEN?
21 A YES, MA' AM.
22 Q AND YOU WOULD RELY ON A PHYSI CI AN' S STATEMENT?
23 A YES, MA' AM.
24 Q ESPECI ALLY DURI NG EMERGENCI ES?
25 A ESPECI ALLY THEN.
26 Q BECAUSE TI ME I S OF THE ESSENCE?
27 A YES, MA' AM.
28 Q AND I BELI EVE YOU TESTI FI ED EARLI ER, WHEN YOU
866 299-5127
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1 ASKED DR. MURRAY QUESTI ONS, SOME OF HI S ANSWERS DI DN' T
2 MAKE SENSE TO YOU.
3 A YES, MA' AM, THAT' S CORRECT.
4 Q DI D YOU HAVE TO ASK DR. MURRAY CERTAI N
5 QUESTI ONS MORE THAN ONCE BEFORE YOU GOT AN ANSWER?
6 A YES, I DI D.
7 Q DO YOU REMEMBER WHAT QUESTI ONS THOSE WERE?
8 A YES.
9 WHEN I ASKED HI M WHAT THE PATI ENT' S UNDERLYI NG
10 HEALTH CONDI TI ON WAS, I HAD TO REPEAT THAT A COUPLE OF
11 TI MES. ACTUALLY, AT LEAST THREE TI MES.
12 WHEN I ASKED HI M WHAT MEDI CATI ONS THE PATI ENT
13 WAS TAKI NG.
14 Q AND WHAT DI D HE ULTI MATELY SAY ABOUT THE
15 UNDERLYI NG HEALTHCARE SI TUATI ON? THAT HE WAS HEALTHY?
16 A NOTHI NG. HE SAI D NOTHI NG. NO, NOTHI NG. " I ' M
17 J UST TREATI NG HI M FOR DEHYDRATI ON AND EXHAUSTI ON. "
18 Q WHAT KI ND OF EQUI PMENT WOULD YOU USE TO TREAT
19 SOMEBODY WI TH DEHYDRATI ON?
20 MR. PANI SH: EXCUSE ME, YOUR HONOR. J UST FOR
21 CLARI TY, ARE WE TALKI NG ABOUT FROM A PARAMEDI C' S
22 STANDPOI NT OR A PHYSI CI AN' S STANDPOI NT?
23 MS. CAHAN: I ASKED HI M.
24 THE COURT: WELL, OVERRULED.
25 YOU MAY ANSWER.
26 THE WI TNESS: MYSELF, I WOULD USE A SALI NE
27 SOLUTI ON.
28 Q BY MS. CAHAN: AND HOWDO YOU GET THE SALI NE
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SOLUTI ON I NTO SOMEBODY' S BODY?
A I WOULD START AN I V, AND I ' D PUT A NEEDLE I N
THEI R VEI NS, LEAVE WHAT' S CALLED A CANNULA, A STRAWI N
THE VEI N, AND RUN THE FLUI D I N.
Q AND I T' S A CLEAR BAG OF SALI NE THAT RUNS
THROUGH THE I V TO WHERE YOU PLACED I T I N THE PERSON' S
BODY?
A THAT' S CORRECT.
Q AND WHEN YOU' RE ADMI NI STERI NG EPI NEPHRI NE AND
ATROPI NE AND OTHER DRUGS TO TRY TO HELP SOMEONE WHEN THE
HEART HAS STOPPED, DO YOU START A SALI NE I V FI RST AND
GET THAT GOI NG, AND THEN RUN THE DRUGS I N, OR DO YOU
SOMETI MES J UST I NJ ECT DI RECTLY I NTO THE VEI N?
A NO. WE NEVER I NJ ECT DI RECTLY I NTO THE VEI N.
THAT' S MAI NLI NI NG. WE NEVER DO THAT.
NORMALLY WE START A SALI NE LOCK. I T' S A STI CK
I N THERE, AND YOU DON' T HANG ANY I V TUBI NG, WE J UST PUT
I T STRAI GHT I NTO THE LOCK. BUT SI NCE THERE WAS ALREADY
I V TUBI NG THERE, WE J UST SWI TCHED OUT. I T' S EASI ER TO
J UST CONTI NUE USI NG THE I V TUBE.
Q YOU FLUSHED THE LI NE FI RST TO MAKE SURE I T' S A
VI ABLE LI NE?
A YOU HAVE TO FLUSH THE LI NE FI RST TO MAKE SURE
I T' S A VI ABLE LI NE, MEANI NG THAT A BLOOD CLOT HASN' T
FORMED I N THE CANNULA, AND THEN NOTHI NG GOES THROUGH.
SO YOU FLUSH I T TO MAKE SURE I T STI LL WORKS.
AND THEN AFTER YOU GI VE THE MEDI CATI ON, YOU
FLUSH THE LI NE SO THERE' S NO RESI DUAL MEDI CATI ON I N THE
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LI NE, SO WHEN YOU FLUSH I N ANOTHER MEDI CATI ON THE TWO
DON' T MI X AND YOU HAVE A PROBLEM.
Q OKAY. I WANT TO TALK FOR A MI NUTE ABOUT
PROPOFOL.
A YES, MA' AM.
Q AND BEFORE WE GET I NTO THE DETAI LS, YOU SAI D
YOU HAD ABOUT 1, 000 HOURS OF SPECI ALI ZED TRAI NI NG WHEN
YOU BECAME A PARAMEDI C?
A YES, MA' AM.
Q AND BEFORE THAT, YOU HAD SOME TRAI NI NG AS AN
E. M. T. ?
A YES, MA' AM.
Q AND YOU' VE HAD EXPERI ENCE I N EMERGENCY ROOMS?
A YES, MA' AM.
Q I . C. U. S?
A NO.
Q AS PART OF YOUR PARAMEDI C TRAI NI NG?
A NO. WHAT WE ARE - - THE PARAMEDI C TRAI NI NG, WE
ROTATED THROUGH THE OPERATI NG ROOM, BECAUSE THEY
I NTUBATE BREATHI NG TUBES, SO WE WERE THERE FOR THAT.
BUT, NO, WE DI DN' T SPEND TI ME I N THE I . C. U. S. WE SPENT
A LOT OF TI ME I N EMERGENCY ROOMS, AND LABOR AND
DELI VERY.
Q I ' M SORRY. I DI DN' T MEAN TO CUT YOU OFF.
A AND LABOR AND DELI VER.
Q I ' M SURE THAT COMES I N HANDY.
FAI R TO SAY YOU HAVE A GOOD AMOUNT OF
EXPERI ENCE I N VARI OUS MEDI CAL SETTI NGS, HOSPI TALS AND
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OTHERWI SE?
A YES, MA' AM.
Q PRI OR TO J UNE 25TH, 2009, WHAT DI D YOU KNOW
ABOUT PROPOFOL, I F ANYTHI NG?
A I KNEWI T WAS AN ANESTHETI C USED I N GENERAL
ANESTHESI A I N SURGERY. THAT' S ALL I KNEWABOUT I T,
THOUGH.
Q OKAY. HAD YOU EVER USED I T WI TH A PATI ENT?
A NO, MA' AM.
Q HAD YOU EVER SEEN I T ADMI NI STERED I N AN
OPERATI NG ROOM BEFORE SURGERY?
A NO, MA' AM.
Q HAD YOU EVER SEEN I T ADMI NI STERED BY ANYONE FOR
ANY PURPOSE?
A NO, MA' AM.
Q DR. MURRAY NEVER SAI D ANYTHI NG ABOUT PROPOFOL
TO YOU; CORRECT?
A NO, MA' AM.
Q YOU HAD NO I DEA THAT PROPOFOL WAS I NVOLVED?
A NO, MA' AM.
Q WHEN DI D YOU LEARN THAT MR. J ACKSON HAD
RECEI VED PROPOFOL ON THE DATE THAT HE DI ED?
A THROUGH THE MEDI A.
Q APPROXI MATELY WHEN? A COUPLE MONTHS AFTER HE
DI ED?
A YEAH. SEVERAL MONTHS.
Q OKAY. PROPOFOL - - FAI R TO SAY, PROPOFOL WASN' T
EVEN SOMETHI NG THAT ENTERED YOUR MI ND AS A POSSI BLE
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CAUSE FOR MR. J ACKSON' S CONDI TI ON?
A THAT WOULD BE CORRECT.
Q I N ALL YOUR 28 YEARS AS A FI REFI GHTER/
PARAMEDI C, HAD YOU EVER ENCOUNTERED ANYBODY ELSE WHO HAS
HAD A PROPOFOL OVERDOSE?
A NO, MA' AM.
Q FAI R TO SAY, I T WAS UNHEARD OF BY YOU?
A YEAH, I WOULD SAY SO.
MS. CAHAN: OKAY. NOTHI NG FURTHER AT THI S
TI ME, YOUR HONOR.
THE COURT: REDI RECT?
MR. PANI SH: YES.
REDI RECT EXAMI NATI ON
BY MR. PANI SH:
Q HAVE YOU EVER SEEN ANYONE WHO HAD A
CARDI OLOGI ST I N THEI R ROOM THAT DI ED FROM SOME TYPE OF
ADMI NI STRATI ON OF MEDI CATI ON?
A NO, SI R.
Q AND YOU WOULD EXPECT A CARDI OLOGI ST TO BE ABLE
TO ADMI NI STER C. P. R. ; CORRECT?
A YES, SI R.
Q AND DI D YOU HAVE AN UNDERSTANDI NG OF WHETHER OR
NOT DR. MURRAY, I N YOUR OPI NI ON, WAS PROPERLY
ADMI NI STERI NG C. P. R. ?
A I DI D NOT HAVE AN UNDERSTANDI NG. I DI D NOT SEE
HI M ACTUALLY PERFORMI NG C. P. R.
Q DO YOU HAVE AN UNDERSTANDI NG OF WHETHER C. P. R.
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I S SUPPOSED TO BE DONE ON A BED OR ON THE FLOOR?
A I HAVE A VERY CLEAR UNDERSTANDI NG ON THAT.
Q TELL US WHAT I T I S.
A AMERI CAN HEART ASSOCI ATI ON, WHI CH SETS THE
STANDARDS, CLEARLY STATES THAT I F I T' S PERFORMED ON A
BED, THAT' S LESS THAN DESI RABLE, THAT YOU MUST PLACE A
HARD SURFACE UNDER THE PATI ENT.
I N OUR SI TUATI ONS, THEY TALK ABOUT DOI NG C. P. R.
I MMEDI ATELY, AS SOON AS POSSI BLE, AND THAT' S I MPORTANT,
BUT I F I T' S NECESSARY TO MOVE A PATI ENT TO THE FLOOR,
THEN THAT TAKES PRI ORI TY OVER I T.
WHEN YOU PUSH DOWN ON SOMEONE' S CHEST DOWN ON
THE BED, THE BED PUSHES DOWN, AND YOU DON' T COMPRESS THE
CHEST ADEQUATELY.
Q SO DI D YOU HAVE ANY I NFORMATI ON THAT DR. MURRAY
HAD EVEN ATTEMPTED C. P. R. BEFORE YOU ARRI VED?
A I DI D NOT.
Q AND WOULD YOU EXPECT A CARDI OLOGI ST PROPERLY
TRAI NED TO BE ABLE TO DO THAT?
A LET ME BACKTRACK A LI TTLE BI T. HE HAD SAI D HE
HAD DONE C. P. R.
Q SO, I N OTHER WORDS, I F HE HAD DONE C. P. R. , HE
WOULD HAVE BEEN DOI NG I T I MPROPERLY ON A BED?
A THAT' S TRUE, YES.
Q AND I N YOUR OPI NI ON, A DOCTOR THAT' S PERFORMI NG
- - A CARDI OLOGI ST WHO' S PERFORMI NG C. P. R. ON A BED
WOULDN' T BE FI T TO PERFORM THAT FUNCTI ON, WOULD THEY?
A SORRY?
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Q THAT' S NOT THE WAY YOU' RE SUPPOSED TO DO I T?
A THAT' S CORRECT. THAT' S NOT HOWYOU' RE SUPPOSED
TO DO I T.
Q AND A DOCTOR I S SUPPOSED TO BE COMPETENT,
QUALI FI ED AND FI T TO PERFORM THE DUTI ES THEY' RE SUPPOSED
TO PERFORM?
A I WOULD ASSUME SO, YES, SI R.
Q AND BASED ON WHAT YOU LEARNED, DI D YOU FEEL
THAT DR. MURRAY WAS COMPETENT AND FI T TO PERFORM C. P. R.
ON MR. J ACKSON?
MS. CAHAN: OBJ ECTI ON. LEADI NG. CALLS FOR
SPECULATI ON.
THE COURT: OVERRULED.
THE WI TNESS: I DI D NOT.
Q BY MR. PANI SH: YOU DI D NOT BELI EVE HE WAS;
CORRECT?
A I DI D NOT BELI EVE HE WAS.
Q ALSO, COUNSEL ASKED ALL THESE QUESTI ONS ABOUT
PHYSI CI ANS AND TELLI NG YOU HI STORY AND SUCH.
WOULD YOU EXPECT A COMPETENT AND FI T PHYSI CI AN
TO PROPERLY SET FORTH THE HI STORY OF THEI R PATI ENT?
A YES, SI R, I WOULD.
Q AND WAS I T YOUR UNDERSTANDI NG THAT DR. MURRAY
DI D NOT SET FORTH ALL OF THE HI STORY OF HI S PATI ENT AT
THE TI ME, MR. J ACKSON?
A I DI D NOT BELI EVE HE WAS TELLI NG ME THE FULL
STORY AT THE TI ME.
Q AND WOULD YOU EXPECT A PHYSI CI AN THAT' S
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COMPETENT AND FI T TO SET FORTH THE ENTI RE HI STORY OF
THEI R PATI ENT WHEN ASKED BY A PARAMEDI C?
A YES, I WOULD.
Q AND I N YOUR OPI NI ON, DR. MURRAY DI DN' T DO THAT,
DI D HE?
A NO, HE DI D NOT.
Q NOW, YOU, SI R, YOU' RE NEUTRAL HERE; RI GHT?
A YES, SI R.
Q YOU' RE NOT ON EI THER SI DE?
A NO, SI R.
Q YOU' RE J UST DOI NG YOUR J OB FOR THE CI TY OF LOS
ANGELES?
A YES, SI R.
Q NOW, ON THE WEI GHT, WOULD YOU RELY ON YOUR
ESTI MATE OR THE CORONER' S ACTUAL WEI GHT THAT THEY TOOK
OF MR. J ACKSON?
A I WOULD RELY ON THE CORONER' S WEI GHT.
Q COUNSEL ASKED YOU WHETHER THE PATI ENT - - STRI KE
THAT.
WHETHER I T WAS YOUR EXPECTATI ON THAT THE
PATI ENT WOULD TELL YOU ABOUT THEI R MEDI CAL CONDI TI ON TO
HELP YOU.
REMEMBER THOSE QUESTI ONS?
A YES, SI R.
Q COULD YOU TELL US WHAT MR. J ACKSON TOLD YOU
THAT DAY?
A NOTHI NG, SI R.
Q BECAUSE HE WAS DEAD BEFORE YOU GOT THERE,
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WASN' T HE?
A YES, SI R.
Q NOW, COUNSEL ASKED YOU LOTS OF QUESTI ONS ABOUT
I VS, AND I J UST WANT TO CLEAR UP ONE POI NT.
ONE OF THE GENTLEMAN ASSI STI NG YOU WAS ANOTHER
FI REFI GHTER BY THE NAME OF GOODWI N; I S THAT CORRECT?
A YES, SI R.
Q AND I THI NK YOU MENTI ONED THAT - - WHAT DO YOU
CALL A FI REFI GHTER? AN OFFI CER? A FI REFI GHTER?
A WE CALL THEM FI REFI GHTERS.
Q OKAY. FI REFI GHTER GOODWI N WAS ATTEMPTI NG TO DO
I VS I N BOTH OF MR. J ACKSON' S ARMS?
A THAT' S CORRECT.
Q AND I T WAS UNSUCCESSFUL?
A THAT' S CORRECT.
Q HOWMANY TI MES DI D HE TRY ON EACH SI DE?
A AT LEAST THREE TI MES ON EI THER SI DE.
Q SO THAT WOULD BE ABOUT SI X EFFORTS?
A YES, SI R.
Q AND HE NEVER PUT ANY FLUI DS I N HI M; CORRECT?
A NO, HE DI D NOT.
Q THAT' S CORRECT?
A THAT' S CORRECT.
Q NOW, ARE YOU FAMI LI AR WI TH WHAT A RESPI RATORY
ARREST I S?
A YES, SI R.
Q EXPLAI N THAT TO US.
A WE' RE ALL SI TTI NG HERE BREATHI NG, AND OUR
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HEARTS ARE ALL BEATI NG, AND EVERYTHI NG I S GOOD, BUT WHEN
YOU STOP BREATHI NG, THAT' S CALLED RESPI RATORY ARREST.
I T DOESN' T MEAN YOUR HEART HAS STOPPED, I T J UST
MEANS THAT YOU HAVE STOPPED BREATHI NG.
Q AND, SI R, HAVE YOU ADMI NI STERED C. P. R. TO
PATI ENTS THAT HAVE BEEN SUFFERI NG FROM A RESPI RATORY
ARREST?
A C. P. R. , I TAKE TO MEAN DOI NG CHEST
COMPRESSI ONS. I HAVE NOT DONE CHEST COMPRESSI ONS ON
SOMEONE WHO I S I N RESPI RATORY ARREST.
Q HOWABOUT RESUSCI TATI ON?
A I HAVE BREATHED FOR THEM, I HAVE VENTI LATED
THEM ON NUMEROUS OCCASI ONS.
Q AND WHEN SOMEBODY I S HAVI NG A RESPI RATORY
ARREST - -
A YES, SI R.
Q - - YOU' VE ARRI VED ON THE SCENE ON THOSE
OCCASI ONS?
A YES, SI R.
Q AND YOU HAVE BEEN ABLE TO HELP THE PATI ENT NOT
DI E; I S THAT RI GHT?
A MANY TI MES THEY HAVE WOKEN UP LATER AND TALKED
TO ME.
Q AND I S I T I MPORTANT TO BEGI N YOUR EFFORTS TO
SAVE THE PATI ENT AS SOON AS THEY GO I NTO RESPI RATORY
ARREST?
A YES, SI R. TI ME I S CRI TI CAL.
Q AND WHY I S THAT?
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A WHEN YOU' RE NOT BREATHI NG, AS I SAI D EARLI ER,
YOUR CELLS START PRODUCI NG LACTI C ACI D. AS THE LACTI C
ACI D BUI LDS UP I NTO YOUR BLOOD SYSTEM, I T MAKES FOR AN
AREA - - OR PH LEVELS, ACI D- BASED BALANCE LEVELS, THAT
AREN' T GOOD FOR YOUR HEART.
YOUR HEART I S ELECTRI CAL, AND I T NEEDS TO HAVE
THE CORRECT PH LEVEL, CORRECT ACI D- BASED BALANCE. WHEN
LACTI C ACI D BUI LDS UP, EVENTUALLY THE HEART I S GOI NG TO
CEASE TO FUNCTI ON.
Q I WANT YOU TO ASSUME MR. J ACKSON HAD
RESPI RATORY ARREST.
A YES, SI R.
MS. CAHAN: YOUR HONOR, WELL OUTSI DE THE SCOPE
OF THE CROSS.
THE COURT: OVERRULED. I F YOU NEED TO ASK FOR
QUESTI ONS, YOU CAN DO I T.
MS. CAHAN: OKAY.
Q BY MR. PANI SH: AND WOULD YOU EXPECT THAT A
COMPETENT AND FI T PHYSI CI AN I N THE PRESENCE OF A PATI ENT
HAVI NG A RESPI RATORY ARREST COULD REVI VE AND HAVE THAT
PATI ENT LI VE WI TH PROPER EFFORTS?
A YES, SI R, I WOULD EXPECT THAT.
Q HAVE YOU DONE THAT MANY, MANY TI MES?
A YES, SI R.
Q AND YOU WOULD EXPECT A COMPETENT AND FI T
PHYSI CI AN TO HAVE BEEN ABLE TO REVI VE SOMEONE THAT HAD A
RESPI RATORY ARREST; CORRECT?
A YES, SI R.
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Q NOW, COUNSEL ASKED YOU QUESTI ONS ABOUT THI S
I SSUE RELATI NG TO YOUR OPI NI ON THAT MR. J ACKSON APPEARED
TO BE SI MI LAR TO A PATI ENT THAT WAS I N HOSPI CE CARE.
A YES, SI R.
Q AND YOU TOLD ME, I BELI EVE - - CORRECT ME I F I ' M
WRONG - - THAT WHEN YOU SAWHOWHE LOOKED, YOU THOUGHT
THAT HE WAS SUFFERI NG FROM A CHRONI C I LLNESS; I S THAT
CORRECT?
A YES, SI R, I DI D.
Q AND THAT - - WHEN YOU SAY " CHRONI C I LLNESS, " DO
YOU MEAN SOMETHI NG THAT HAS J UST COME ON, OR SOMETHI NG
THAT HAS EXI STED FOR A PERI OD OF TI ME?
A TO ME I T LOOKED LI KE SOMETHI NG THAT HAD EXI STED
FOR A PERI OD OF TI ME.
Q NOT SOMETHI NG I N THE LAST DAY OR TWO?
A NO, SI R.
Q AND YOU' VE SEEN MANY, MANY PATI ENTS THAT HAVE
BEEN SUFFERI NG FROM CHRONI C I LLNESS THAT HAPPENED WEEKS
OR MONTHS EARLI ER THAT HAVE BEEN OCCURRI NG; RI GHT?
A YES, SI R.
Q AND I N YOUR OPI NI ON, BASED ON WHEN YOU SAW
MR. J ACKSON PHYSI CALLY, WAS I T YOUR OPI NI ON THAT HE WAS
SUFFERI NG FROM A CHRONI C I LLNESS THAT J UST DI DN' T
DEVELOP I N THE RECENT DAYS?
A YES, SI R, THAT' S CORRECT.
MR. PANI SH: THAT' S ALL I HAVE. THANK YOU.
THE COURT: DO YOU HAVE ANY FURTHER QUESTI ONS?
MS. CAHAN: NO, YOUR HONOR.
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THE COURT: THANK YOU.
THANK YOU, SI R. YOU MAY STEP DOWN.
PLAI NTI FF, YOU MAY CALL YOUR NEXT WI TNESS.
MR. PANI SH: YES. DETECTI VE ORLANDO MARTI NEZ.

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MR. PANI SH: YES. DETECTI VE ORLANDO MARTI NEZ.
ORLANDO MARTI NEZ,
CALLED AS A WI TNESS BY THE PLAI NTI FFS,
WAS SWORN AND TESTI FI ED AS FOLLOWS:
THE COURT: ARE YOU DETECTI VE MARTI NEZ? YOU
MAY STEP FORWARD. STAND BEHI ND THE COURT REPORTER TO MY
LEFT. FACE THE CLERK TO MY RI GHT.
THE CLERK: DO YOU SOLEMNLY STATE THAT THE
TESTI MONY YOU' RE ABOUT TO GI VE I N THE CAUSE NOWPENDI NG
BEFORE THI S COURT SHALL BE THE TRUTH, THE WHOLE TRUTH,
AND NOTHI NG BUT THE TRUTH, SO HELP YOU GOD?
THE WI TNESS: I DO.
THE CLERK: THANK YOU. YOU MAY HAVE A SEAT TO
YOUR RI GHT.
AND, SI R, CAN YOU PLEASE STATE AND SPELL YOUR
FI RST AND LAST NAME FOR THE RECORD?
THE WI TNESS: ORLANDO MARTI NEZ. O- R- L- A- N- D- O,
M- A- R- T- I - N- E- Z.
THE CLERK: THANK YOU.
THE COURT: THANK YOU, SI R.
YOU MAY BEGI N.
/ / /
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866 299-5127
2365
1 DI RECT EXAMI NATI ON
2 BY MR. PANI SH:
3 Q GOOD AFTERNOON.
4 A GOOD AFTERNOON.
5 Q BY WHOM ARE YOU PRESENTLY EMPLOYED?
6 A CI TY OF LOS ANGELES, LOS ANGELES POLI CE
7 DEPARTMENT, ROBBERY/ HOMI CI DE DI VI SI ON, HOMI CI DE SPECI AL
8 SECTI ON.
9 Q COULD YOU TELL US A LI TTLE BI T ABOUT YOUR
10 EDUCATI ONAL BACKGROUND?
11 YOU' RE A DETECTI VE; I S THAT RI GHT?
12 A YES, SI R.
13 Q I S THERE A CERTAI N GRADE OF DETECTI VE THAT YOU
14 ARE?
15 A YES. I ' M A DETECTI VE SUPERVI SOR, WHI CH WOULD
16 BE EQUAL I N RANK TO A SERGEANT.
17 Q OKAY. WHY DON' T YOU TELL US, DETECTI VE - - I S
18 I T PROPER TO CALL YOU DETECTI VE?
19 A YES, SI R.
20 Q DETECTI VE, WHY DON' T YOU TELL US ABOUT YOUR
21 EDUCATI ONAL EXPERI ENCE.
22 A I N RELATI ON TO LAWENFORCEMENT?
23 Q ABOUT YOUR BACKGROUND. I J UST WANT TO GET A
24 LI TTLE BI T ABOUT YOUR BACKGROUND.
25 A I ' VE BEEN A POLI CE OFFI CER FOR 19 YEARS AND A
26 DETECTI VE SI NCE 2001. I ' VE WORKED HOMI CI DE
27 I NVESTI GATI ON SI NCE MAY OF 2001.
28 TRAI NI NG, REGULAR BASI C POLI CE- ACADEMY TRAI NI NG
866 299-5127
2366
1 AND ALSO VARI OUS DETECTI VE SCHOOLS THAT ARE CERTI FI ED BY
2 P. O. S. T. , PEACE OFFI CER STANDARDS AND TRAI NI NG, THE
3 GOVERNI NG BODY FOR CALI FORNI A LAWENFORCEMENT.
4 I HOLD A BASI C AND I NTERMEDI ATE AND SUPERVI SORY
5 CERTI FI CATE FOR P. O. S. T.
6 I ' M A P. O. S. T. I NSTRUCTOR. I TEACH CRI ME SCENE
7 AND HOMI CI DE SCHOOL TO OTHER POLI CE OFFI CERS, NOT ONLY
8 L. A. P. D.
9 Q LET ME BREAK THAT DOWN A LI TTLE BI T.
10 A SURE.
11 Q YOU J OI NED THE FORCE I N WHAT YEAR?
12 A 1994.
13 Q DI D YOU HAVE ANY WORK EXPERI ENCE BEFORE THAT?
14 A YES.
16 A I WORKED AT AN AMUSEMENT PARK, AND I WORKED AT
17 FOSTER' S FREEZE.
18 Q DI D YOU MAKE THOSE DI P CONES?
19 A I DI D.
20 Q OKAY.
21 NOW, YOU WANTED TO BE A POLI CE OFFI CER. YOU
22 APPLI ED TO THE L. A. P. D. ?
23 A YES.
24 Q WHEN YOU WERE ACCEPTED, YOU THEN WENT TO THE
25 ACADEMY?
26 A YES.
27 Q AND WAS THAT I N ELYSI AN PARK THAT YOU ATTENDED?
28 A YES, I T WAS.
866 299-5127
2367
1 Q CAN YOU TELL US WHAT' S ENTAI LED FOR A POLI CE
2 OFFI CER I N GOI NG THROUGH THE ACADEMY? WHAT YOU DO, WHAT
3 YOU LEARN, HOWYOU' RE TRAI NED.
4 A THEY TEACH YOU PHYSI CAL FI TNESS; TEACH YOU LAW,
5 POLI CI ES AND PROCEDURES FOR THE POLI CE DEPARTMENT AND
6 FOR CALI FORNI A LAW, AND FI REARMS, TACTI CS. THAT SORT OF
7 STUFF.
8 Q I NVESTI GATI ONS? ARE YOU TAUGHT ABOUT HOWTO
9 I NVESTI GATE MOTOR VEHI CLE ACCI DENTS?
10 A YES. PRELI MI NARY I NVESTI GATI ON, REPORT
11 WRI TI NG, I NTERVI EWAND I NTERROGATI ON.
12 Q BASI C POLI CE SKI LLS?
13 A YES.
14 Q OKAY. ONCE YOU GRADUATE FROM THE ACADEMY, YOU
15 THEN GO OUT AS AN OFFI CER WI TH WHAT' S CALLED A FI ELD
16 TRAI NI NG OFFI CER?
17 A YES, YOU DO.
18 Q AND WHAT HAPPENS DURI NG THAT PERI OD?
19 A I T' S A YEAR PROBATI ONARY PERI OD. YOU GO OUT
20 WI TH SEVERAL DI FFERENT TRAI NI NG OFFI CERS WHERE THEY RATE
21 YOU, AND THEY TEACH YOU HOWTO BE A POLI CE PERSON,
22 POLI CE OFFI CER.
23 Q LI KE ON- THE- J OB TRAI NI NG, SO TO SPEAK?
24 A EXACTLY.
25 Q ONCE YOU COMPLETE THAT, ARE YOU THEN ASSI GNED
26 TO A PATROL DI VI SI ON?
27 A YOU DO THAT AT A PATROL DI VI SI ON, AND ONCE YOU
28 COMPLETE I T, YOU GET SENT TO ANOTHER PATROL DI VI SI ON.
866 299-5127
2368
1 Q WHEN YOU COMPLETED YOUR ONE- YEAR - - BY THE WAY,
2 THE ACADEMY I S THREE MONTHS?
3 A SEVEN MONTHS.
4 Q SEVEN MONTHS. SO YOU DI D SEVEN MONTHS ACADEMY
5 TRAI NI NG, ONE YEAR ON- THE- J OB FI ELD OFFI CER TRAI NED?
6 A YES.
7 Q SO THEN AFTER A YEAR AND SEVEN MONTHS, YOU' RE
8 THEN ASSI GNED TO A PATROL DI VI SI ON?
9 A YES.
10 Q WHERE WERE YOU ASSI GNED?
11 A I WAS ASSI GNED TO DEVONSHI RE AREA.
12 Q I N THE VALLEY?
13 A YES.
14 Q AND WHAT WERE YOUR J OB DUTI ES AT THAT TI ME?
15 A I WAS AT DEVONSHI RE FOR A WHI LE. AND I WORKED
16 GANGS, I WORKED THE SPECI AL PROBLEMS UNI T, PATROL, AND
17 THE AUTO THEFT TASK FORCE, AND BI KE UNI T, AND NARCOTI CS.
18 Q LI TTLE ROUGH OUT THERE.
19 SO YOU WERE LEARNI NG, AS YOU WENT, BASI C SKI LLS
20 THAT A POLI CE OFFI CER HAS TO AVAI L HI MSELF TO
21 I NVESTI GATE, FI ND EVI DENCE, I NTERVI EWWI TNESSES, AND
22 PREPARE REPORTS AND PRESERVE EVI DENCE TO COME TO COURT?
23 A YES.
24 Q OKAY. HOWLONG DI D YOU STAY AT DEVONSHI RE?
25 A UNTI L 1999.
26 Q DI D YOU ADVANCE I N RANK DURI NG THAT TI ME?
27 A I DI D NOT.
28 Q I N 1999 WHAT DI D YOU DO?
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1 A I TRANSFERRED TO WI LSHI RE DI VI SI ON, WHI CH I S
2 LI KE THE MI RACLE MI LE AREA.
3 Q AND WHAT POSI TI ON DI D YOU ASSUME THERE I N
4 WI LSHI RE?
5 A I WAS STI LL POLI CE OFFI CER I I .
6 Q OKAY. WERE YOU I N A PATROL CAR THEN?
7 A YES. WORKI NG PATROL.
8 Q DI D YOU HAVE A PARTNER?
9 A YES, I DI D.
10 Q SO YOU WOULD BE ON A SHI FT WI TH A PARTNER
11 PATROLLI NG THE J URI SDI CTI ON OF WI LSHI RE?
12 A YES.
13 Q AND DURI NG THAT PERI OD OF TI ME, WHAT KI ND OF
14 WORK DI D YOU DO?
15 A MORNI NG WATCH PATROL. SO WHAT PEOPLE CALL
16 GRAVEYARD SHI FT. RESPONDI NG TO RADI O CALLS AND
17 CONDUCTI NG POLI CE WORK THAT YOU OBSERVE.
18 Q CRI MES?
19 A YES.
20 Q ROBBERY?
21 A YES.
22 Q HOMI CI DE?
23 A CORRECT.
24 Q MOTOR VEHI CLE ACCI DENTS?
25 A YES.
26 Q D. U. I . ?
27 A YES.
28 Q ANYTHI NG ELSE? ASSAULT AND BATTERY?
866 299-5127
2370
1 A ASSAULTS, SEXUAL ASSAULTS, DOMESTI C VI OLENCE.
2 Q AND WHAT WERE THE HOURS?
3 A MY - -
4 Q 11: 00 TO?
5 A I T WAS 10: 00 TO 5: 00 I N THE MORNI NG, I BELI EVE.
6 Q SO WHATEVER HAPPENS BETWEEN 10: 00 AND 5: 00 I N
7 THE MORNI NG, YOU' RE GETTI NG A CALL?
8 A YES, SI R.
9 Q HOWLONG DI D YOU DO THAT?
10 A FOR ONE YEAR.
11 Q AND THEN WHAT DI D YOU DO?
12 A THEN I MADE DETECTI VE, AND THEY SENT ME BACK TO
13 DEVONSHI RE.
14 Q WELL, TO BECOME - - HOWDO YOU BECOME A
15 DETECTI VE I N THE LOS ANGELES POLI CE DEPARTMENT? I S THAT
16 SOMETHI NG THAT YOU' RE THERE FOR A PERI OD OF TI ME, YOU' RE
17 PROMOTED, OR I S THERE SOME REQUI REMENTS OF MERI T TO
18 I NCREASE TO BE A DETECTI VE?
19 A YOU HAVE TO QUALI FY TO TAKE THE TEST BY HAVI NG
20 ENOUGH TI ME AND GRADE, AND THEN YOU TAKE A WRI TTEN TEST,
21 WHI CH I S A PASS OR FAI L, AND THEN YOU TAKE AN ORAL
22 I NTERVI EWI N WHI CH YOU' RE RANKED ON YOUR SCORE. AND
23 FROM THAT RANKI NG, YOU GET PUT ON A LI ST, AND THEY MAKE
24 A CERTAI N AMOUNT, AND I F YOU' RE RANKED HI GH ENOUGH, YOU
25 GET PROMOTED.
26 Q SO YOU MADE THE GRADE OF DETECTI VE?
27 A YES.
28 Q AND WHEN YOU FI RST BECOME A DETECTI VE, WHAT I S
866 299-5127
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1 THAT CALLED? DETECTI VE I ?
2 A YES.
3 Q AND THEN YOU WENT BACK TO DEVONSHI RE?
4 A I DI D.
5 Q AND WHAT WERE YOU DOI NG THERE AS DETECTI VE I ?
6 A WHEN I FI RST GOT THERE, I WAS I NVESTI GATI NG
7 CRI MES AGAI NST PERSONS AND DOMESTI C VI OLENCE.
8 Q AND " CRI MES AGAI NST A PERSON, " WHAT I S THAT?
9 A THAT WOULD BE A BATTERY, AN ASSAULT,
10 BRANDI SHI NG.
11 Q BRANDI SHI NG A WEAPON?
12 A YES, SI R.
13 Q AND I S THAT KI ND OF WHEN YOU BECOME A
14 DETECTI VE, HOWYOU START OUT?
15 A YES.
16 Q THEY J UST DON' T PUT YOU RI GHT I NTO THE HOMI CI DE
17 DI VI SI ON?
18 A NO, SI R.
19 Q OKAY. HOWLONG DI D YOU WORK I N THE DEVONSHI RE
20 DI VI SI ON I N THAT FI RST POSI TI ON AS A DETECTI VE I ?
21 A THREE MONTHS.
22 Q THREE MONTHS. DI D YOU GET PROMOTED?
23 A I WAS MOVED I NTO THE HOMI CI DE UNI T.
24 Q I N THE SAME DI VI SI ON, DEVONSHI RE?
25 A YES.
26 Q WHAT YEAR WAS THAT THAT YOU WERE MOVED I NTO THE
27 HOMI CI DE DI VI SI ON?
28 A 2001.
866 299-5127
2372
1 Q SO NOWAT THAT TI ME HOWLONG HAVE YOU BEEN A
2 POLI CE OFFI CER? SEVEN YEARS?
3 A EI GHT YEARS.
4 Q EI GHT YEARS. OKAY. WHAT DI D YOU DO - - DI D YOU
5 HAVE THE SAME TI TLE?
6 A YES. DETECTI VE I .
7 Q WHAT DI D YOU DO WHEN YOU WERE MOVED I NTO THE
8 HOMI CI DE DI VI SI ON?
9 A THEN YOU HANDLE - - DEVONSHI RE WAS 56 SQUARE
10 MI LES, SO YOU HANDLE ANY DEATHS, MURDER, ATTEMPT MURDER
11 THAT OCCURS I N THAT 56 SQUARE MI LES. SO THERE WAS FOUR
12 OF US THAT HANDLED THAT AREA.
13 Q WAS I T BUSY?
14 A NOT AS BUSY AS SOME OTHER DI VI SI ONS, BUT BUSY
15 ENOUGH.
16 Q HOWMANY YEARS DI D YOU DO THAT?
17 A UNTI L 2005. FOUR YEARS.
18 Q FOUR YEARS.
19 CAN YOU GI VE US AN I DEA OF WHAT YOUR DAY- TO- DAY
20 ACTI VI TI ES WERE DURI NG THOSE FOUR YEARS AS A DETECTI VE
21 I N THE HOMI CI DE DI VI SI ON OF THE DEVONSHI RE DI VI SI ON OF
22 THE LOS ANGELES POLI CE DEPARTMENT?
23 A DAY- TO- DAY ACTI VI TI ES? AROUND THEN, WE WOULD
24 AVERAGE ABOUT 25 MURDERS A YEAR. SO THAT WOULD BE 12
25 THAT ME AND MY PARTNER WOULD HANDLE.
26 AND YOU WOULD HAVE TO I NVESTI GATE MULTI PLE ONES
27 AT ONCE, PLUS UNSOLVEDS FROM PRI OR YEARS. I NTERVI EWI NG
28 WI TNESSES, CATALOGI NG EVI DENCE, ASKI NG FOR AND REVI EWI NG
866 299-5127
2373
1 RESULTS OF EVI DENTI ARY TESTS. YOU KNOW, WEARI NG DOWN
2 THE SHOE LEATHER TALKI NG TO PEOPLE, GOI NG OUT ON THE
3 STREET.
4 Q WERE YOU TRAI NED I N PRESERVI NG EVI DENCE?
5 A YES.
6 Q WHY I S I T I MPORTANT TO PRESERVE EVI DENCE?
7 A UHM, AS A HOMI CI DE DETECTI VE, I ' M ALWAYS
8 THI NKI NG FOR THE END GAME, THE COURT PROCEEDI NGS AND
9 PRESENTI NG I T TO A J URY.
10 Q AND YOU WERE TRAI NED I N THAT?
11 A YES.
12 Q NOW, WHEN YOU' RE I NVESTI GATI NG MURDERS AND
13 THI NGS LI KE THAT, DO YOU GET TRAI NED I N VARI OUS ASPECTS,
14 SUCH AS I NVESTI GATI NG I NTENT, MOTI VE, METHOD OF THE
15 HOMI CI DE?
16 A YES.
17 Q TELL US ABOUT THAT.
18 A UHM, I T' S REALLY THE COMMON SENSE. THE WHO,
19 WHAT, WHEN, WHERE, WHY AND HOW. TRYI NG TO FI GURE OUT
20 ALL THE PI ECES OF WHAT HAPPENED, WHY I T HAPPENED, WHEN
21 I T HAPPENED.
22 SO TRYI NG TO FI ND OUT REASONS FOR THI NGS TO
23 GI VE YOU AN I DEA AS TO WHAT TO LOOK FOR AND WHERE TO
24 FI ND I T AND WHAT TO ASK.
25 Q AND AS PART OF YOUR EXPERI ENCE FROM DOI NG THESE
26 CASES, LEARNI NG FOR THE NEXT CASE?
27 A ALWAYS LEARNI NG. ALWAYS LEARNI NG.
28 Q 2004, YOU WENT SOMEWHERE ELSE?
866 299-5127
2374
1 A YES.
2 Q WHERE DI D YOU GO?
3 A I WENT TO THE MI SSI ON AREA. THE L. A. P. D.
4 OPENED UP A BRAND- NEWSTATI ON THAT ENCOMPASSED SOME OF
5 DEVONSHI RE' S EARLI ER AREA CALLED MI SSI ON STATI ON, SO I
6 WENT THERE WORKI NG HOMI CI DE.
7 Q I S THAT SAN FERNANDO?
8 A YES.
9 Q AND YOU DI D THE SAME J OB THERE?
10 A I DI D.
11 Q HOWLONG DI D YOU STAY THERE?
12 A A YEAR.
13 Q I NVESTI GATI NG MURDERS, LEARNI NG ON THE J OB,
14 THAT KI ND OF STUFF?
15 A YES.
16 Q WHAT WAS THE NEXT THI NG YOU DI D?
17 A I WAS - - I CAME TO ROBBERY/ HOMI CI DE DI VI SI ON.
18 Q OKAY. WHERE I S THE ROBBERY/ HOMI CI DE DI VI SI ON
19 LOCATED?
20 A I T' S LOCATED HERE I N DOWNTOWN L. A.
21 Q I N THE NEWPOLI CE BUI LDI NG?
22 A I N THE NEWPOLI CE ADMI NI STRATI ON BUI LDI NG.
23 Q FORMERLY PARKER CENTER?
24 A PARKER CENTER WAS THE OLD BUI LDI NG. THE NEW
25 ONE I S CALLED THE POLI CE ADMI NI STRATI ON BUI LDI NG.
26 Q THAT' S WHERE YOU WORK NOW?
27 A YES.
28 Q HOWLONG HAVE YOU WORKED THERE?
866 299-5127
2375
1 A SI X YEARS.
2 Q AND WHAT DO YOU DO THERE?
3 A UHM, AT ROBBERY/ HOMI CI DE DI VI SI ON, HOMI CI DE
4 SPECI AL SECTI ON, WE HANDLE HI GH- PROFI LE MURDERS.
5 SO I F A DI VI SI ON GETS BUSY, WE' LL HANDLE THE
6 CASES THAT THEY CAN' T HANDLE BECAUSE THEY DON' T HAVE
7 ENOUGH MANPOWER. WE ALSO HANDLE SERI AL KI LLERS,
8 MULTI PLE MURDERS, HI GH- PROFI LE MURDERS, COMPLI CATED
9 MURDERS. MURDERS AND ATTEMPTED MURDERS OF POLI CE
10 OFFI CERS. AND ANYTHI NG THAT THE CHI EF DEEMS THAT HE
11 WANTS US TO HANDLE.
12 Q OKAY. DURI NG THI S TI ME, WERE YOU WORKI NG UNDER
13 THE DI RECTI ON OF CHI EF BRATTON?
14 A YES, I WAS.
15 Q I N THE UNI T THAT YOU' RE I N RI GHT NOW, I S THAT
16 AN ELI TE UNI T OF THE LOS ANGELES POLI CE DEPARTMENT?
17 A YES.
18 Q WHY I S THAT?
19 A UHM, WE' RE SUPPOSED TO BE VERY WELL - - WE' RE
20 SUPPOSED TO BE VERY GOOD AT WHAT WE DO.
21 Q WELL QUALI FI ED?
22 A YES.
23 Q HOWMANY HOMI CI DE I NVESTI GATI ONS WOULD YOU SAY
24 THAT YOU' VE I NVESTI GATED?
25 A NI CE ROUND NUMBER I S 100.
26 Q AND HAVE YOU COME TO COURT AND TESTI FI ED AND
27 QUALI FI ED AS AN EXPERT I N YOUR FI ELD?
28 A I DON' T THI NK THAT I ' VE EVER BEEN VOI R DI RED AS
866 299-5127
2376
1 AN EXPERT, BUT I ' VE TESTI FI ED MANY TI MES.
2 Q YOU' VE TESTI FI ED ABOUT WHAT HAPPENED, YOUR
3 I NVESTI GATI ON, WHY YOU DI D THI NGS, WHAT YOU DI D? THI NGS
4 LI KE THAT?
5 A YES.
6 Q OKAY. DO YOU HOLD ANY CERTI FI CATES FROM ANY
7 LAWENFORCEMENT ORGANI ZATI ONS?
8 A YES.
9 Q TELL US ABOUT THAT.
10 A I HOLD A BASI C, I NTERMEDI ATE AND SUPERVI SORY
11 CERTI FI CATE FROM P. O. S. T. , PEACE OFFI CER STANDARDS AND
12 TRAI NI NG.
13 I ' M ALSO A MEMBER I N GOOD STANDI NG OF THE
14 CALI FORNI A HOMI CI DE I NVESTI GATORS ASSOCI ATI ON AND THE
15 I NTERNATI ONAL HOMI CI DE I NVESTI GATORS ASSOCI ATI ON.
16 Q P. O. S. T. , PEACE OFFI CER STANDARDS AND TRAI NI NG,
17 THAT I S WHERE YOU HAVE TO COMPLETE COURSEWORK - -
18 A YES.
19 Q - - I N CERTAI N AREAS?
20 A YES.
21 Q AND YOU HAVE TO GO FOR A CERTAI N NUMBER OF
22 HOURS?
23 A CERTAI N NUMBER OF HOURS EVERY YEAR TO KEEP
24 CURRENT. AND ALSO, YOU CAN DO MORE THAN THAT TO BETTER
25 YOURSELF. LI KE I ' M ALSO AN I NSTRUCTOR FOR P. O. S. T.
26 Q WHAT LEVELS HAVE YOU COMPLETED?
27 A UHM, THE THREE - - BASI C, I NTERMEDI ATE AND
28 SUPERVI SORY.
866 299-5127
2377
1 Q SO THAT' S THE HI GHEST LEVEL, SUPERVI SORY?
2 A THAT I ' VE COMPLETED, YES, SI R.
3 Q AND HOWMANY PEOPLE DO YOU SUPERVI SE NOW?
4 A AT MY DI VI SI ON, EVERYONE I S - - MOST OF THE
5 FOLKS ARE OF EQUAL RANK, SO WE DON' T REALLY SUPERVI SE
6 EACH OTHER.
7 Q OKAY.
8 NOW, J UNE 25TH, 2009. DI D YOU RECEI VE A CALL
9 TO I NVESTI GATE A DEATH AT 100 CAROLWOOD?
10 A YES.
11 Q I S THAT THE RI GHT ADDRESS?
12 A NORTH CAROLWOOD.
13 Q NORTH CAROLWOOD. THANK YOU.
14 AND HOWWAS I T THAT YOU BEI NG I N THE DOWNTOWN
15 OFFI CE - - THAT WOULD BE THE J URI SDI CTI ON, I THI NK, OF
16 THE WEST DI VI SI ON?
17 A WEST L. A.
18 Q WEST L. A. DI VI SI ON. HOWI S I T THAT YOU GOT
19 THAT ASSI GNMENT BEI NG DOWNTOWN VERSUS THE WEST L. A.
20 DI VI SI ON?
21 A THE CHI EF OF DETECTI VES DECI DED I T WAS A
22 HI GH- PROFI LE CASE AND WANTED US TO HANDLE I T.
23 Q WERE YOU AWARE OF WHO THE DEATH I NVOLVED WHEN
24 YOU WERE FI RST DI SPATCHED?
25 A YES.
26 Q HOWDI D YOU LEARN THAT?
27 A FROM MY LI EUTENANT.
28 Q WHAT' S HI S NAME?
866 299-5127
2378
1 A GREGG, G- R- E- G- G, STRENK, S- T- R- E- N- K.
2 Q WHERE WERE YOU DI SPATCHED TO?
3 A U. C. L. A. HOSPI TAL.
4 Q DO YOU KNOWABOUT WHAT TI ME YOU ARRI VED AT
5 U. C. L. A. ?
6 A LI TTLE BI T AFTER 3: 00 I N THE AFTERNOON.
7 Q WHAT DI D YOU DO WHEN YOU ARRI VED AT THE
8 HOSPI TAL?
9 A FI RST THI NG I DI D WAS MEET WI TH TWO WEST L. A.
10 DETECTI VES WHO WERE ALREADY AT SCENE. DETECTI VE PORCHE,
11 P- O- R- C- H- E, AND BENHKE, B- E- N- H- K- E.
12 Q AND DI D THEY KI ND OF BRI EF YOU ON THE
13 SI TUATI ON?
14 A YES, SI R.
15 Q THEN WHAT DI D YOU DO?
16 A THEN I SPOKE WI TH FAHEEM MUHAMMAD AND ALBERTO
17 ALVAREZ AND HOSPI TAL STAFF.
18 Q AND, I ' M SORRY, I DI DN' T HEAR THE LAST PART.
19 A HOSPI TAL STAFF.
20 Q DI D YOU HAVE AN UNDERSTANDI NG OF WHO
21 MR. MUHAMMAD WAS AND MR. ALVAREZ?
22 A YES.
23 Q AND WHAT WAS YOUR UNDERSTANDI NG OF WHO THEY
24 WERE?
25 A MR. MUHAMMAD WAS THE CHI EF OF MR. J ACKSON' S
26 PERSONAL SECURI TY, AND MR. ALVAREZ SAI D HE WAS DI RECTOR
27 OF LOGI STI CS FOR MR. J ACKSON' S SECURI TY TEAM.
28 Q WHEN YOU ARRI VED AT THE HOSPI TAL, DI D YOU SEE
866 299-5127
2379
1 ANYONE AFFI LI ATED WI TH A. E. G. ?
2 A YES.
3 Q WHO DI D YOU SEE?
4 A I SAWMR. DI LEO AND MR. PHI LLI PS.
5 Q RANDY PHI LLI PS?
6 A YES.
7 Q DI D YOU SEE ANYONE THERE FROM THE J ACKSON
8 FAMI LY?
9 A YES.
10 Q WHO DI D YOU SEE?
11 A I SAWMRS. J ACKSON AND RANDY J ACKSON. I DON' T
12 THI NK - - AND THE CHI LDREN.
13 Q OKAY. WHEN YOU SAY " MRS. J ACKSON, " YOU MEAN
14 KATHERI NE J ACKSON?
15 A YES.
16 Q AND WHEN YOU SAY " THE CHI LDREN, " YOU MEAN
17 MI CHAEL' S THREE CHI LDREN?
18 A YES.
19 Q HOWWERE THEY DOI NG?
20 A I DI DN' T - - I SAWTHEM FROM A DI STANCE, SO I
21 DON' T - - I WOULDN' T BE ABLE TO GI VE YOU THAT.
22 Q ALL RI GHT. OKAY. WHAT WAS YOUR ROLE I N THE
23 I NVESTI GATI ON AT THAT TI ME?
24 A AT THAT TI ME I T WAS A DEATH I NVESTI GATI ON, SO
25 THE PRI MARY HANDLI NG AGENCY WOULD BE THE LOS ANGELES
26 COUNTY CORONER' S DEPARTMENT.
27 SO ASSI STI NG THEM TO COMPLETE THEI R
28 I NVESTI GATI ON, AND ALSO TRYI NG TO DEAL WI TH LOGI STI CS
866 299-5127
2380
1 AND SECURI NG THE ROOM THAT MR. J ACKSON WAS I N, ARRANGI NG
2 TRANSPORTATI ON, AND, YOU KNOW, GATHERI NG FACTS OR
3 STATEMENTS.
4 Q I S THAT HOWYOU DO ANY I NVESTI GATI ON? YOU WANT
5 TO SECURE THE SCENE, AND THEN YOU WANT TO START
6 GATHERI NG THE EVI DENCE?
7 A YES, SI R.
8 Q AND I S THAT WHAT YOU DI D I N THI S CASE?
9 A YES.
10 Q DI D YOU ATTEMPT TO SPEAK TO DR. MURRAY AT
11 U. C. L. A. MEDI CAL CENTER?
12 A YES.
13 Q WERE YOU ABLE TO?
14 A I WAS NOT.
15 Q WHY NOT?
16 A HE HAD LEFT.
17 Q DI D YOU LEARN AT SOME POI NT I N TI ME THAT DAY
18 THAT MI CHAEL J ACKSON HAD BEEN PRONOUNCED DEAD?
19 A YES.
21 A I BELI EVE I LEARNED I T FROM DR. COOPER.
22 Q OKAY. AND WHO I S DR. COOPER?
23 A DR. COOPER WAS THE DOCTOR I N CHARGE OF THE
24 EMERGENCY ROOM.
25 Q HAVE YOU HEARD THE TERM " ATTENDI NG PHYSI CI AN" ?
26 A YES.
27 Q I S THAT WHAT DR. COOPER WAS, YOUR
28 UNDERSTANDI NG?
866 299-5127
2381
1 A YES.
2 Q NOW, WHEN SOMEBODY PASSES AWAY THERE AT THE
3 HOSPI TAL, AND THE CORONER I S I NVOLVED I N AN
4 I NVESTI GATI ON, WHAT HAPPENS TO THE BODY?
5 A THE BODY I S TRANSPORTED TO THE CORONER' S
6 OFFI CE.
7 Q AND THEN THE CORONER TAKES CUSTODY OF THE BODY?
8 A CORRECT.
9 Q DO YOU KNOWWHAT HAPPENED TO MR. J ACKSON' S
10 BODY?
11 A YES.
12 Q WHAT HAPPENED?
13 A UHM, WE, ROUND ROBI N, WE SPOKE ABOUT HOWBEST
14 TO GET HI M TO THE CORONER' S OFFI CE AND CAME UP WI TH A
15 PLAN TO GET HI M THERE.
16 Q WHAT WAS THE PLAN?
17 A THE PLAN WAS TO FLY HI M FROM U. C. L. A. I N A
18 HELI COPTER TO THE CORONER' S OFFI CE TO AVOI D ANY REPEAT
19 MESSES THAT WE HAD HAD I N THE PAST.
20 Q I N OTHER WORDS, YOU DI DN' T WANT TO HAVE A BI G
21 SCENE FOLLOWI NG THE VEHI CLE THAT WAS TRANSPORTI NG THE
22 BODY?
23 A YES.
24 Q PEOPLE, PAPARAZZI TYPES?
25 A THERE HAD BEEN A SI MI LAR I NCI DENT J UST A FEW
26 WEEKS PRI OR THAT. LUCKI LY, I T DI DN' T TURN OUT BAD.
27 Q SO I T WAS THE DETERMI NATI ON OF THE POLI CE
28 DEPARTMENT AND THE CORONER THAT THE BEST BET WAS TO HAVE
866 299-5127
2382
1 A HELI COPTER TRANSPORT MR. J ACKSON' S BODY FROM U. C. L. A.
2 OVER TO THE CORONER' S OFFI CE BY COUNTY U. S. C. MEDI CAL
3 CENTER?
4 A YES, SI R.
5 Q WHEN THAT WAS ACCOMPLI SHED AND DONE, DI D YOU
6 THEN LEAVE TO GO SOMEWHERE ELSE?
7 A YES.
8 Q WHERE DI D YOU GO?
9 A I WENT TO THE CAROLWOOD ADDRESS.
10 Q AND WHY DI D YOU GO THERE?
11 A THAT I S THE SCENE OF WHERE THE I NJ URY - -
12 Q THE DEATH HAD OCCURRED?
13 A YEAH.
14 Q ABOUT WHAT TI ME THAT DAY OR NI GHT WAS I T THAT
15 YOU ARRI VED AT THE CAROLWOOD RESI DENCE?
16 A LI TTLE BI T BEFORE 8: 00 AT NI GHT.
17 Q WAS I T DARK YET?
18 A YES, I T WAS.
19 Q WERE THERE PEOPLE ALL ABOUT THE SCENE?
20 A YES, SI R.
21 Q NOW, WERE PHOTOGRAPHS TAKEN AT THE SCENE?
22 A THERE WERE.
23 Q ALL RI GHT. I WANT TO SHOWYOU FI RST - - OR SHOW
24 YOU AND COUNSEL EXHI BI T 500- 329 ( SI C) . I DENTI FY THAT AS
25 A MAI LBOX PHOTOGRAPH. SHOWI T TO COUNSEL.
26 THE COURT: I T' S 500 - -
27 MR. PANI SH: 500- 39. I T' S J UST LOADI NG UP
28 SLOWLY. I THI NK THERE' S A LOST - - OKAY.
866 299-5127
2383
1 LET' S LOOK AT THE PHOTOGRAPH ( I NDI CATI NG) .
2 Q BY MR. PANI SH: OKAY. I S THAT THE MAI LBOX?
3 A YES.
4 Q OKAY. WE PROVED THAT. ALL RI GHT.
5 SO THAT' S WHERE - - YOU J UST USED THAT TO
6 DOCUMENT. AS A POLI CE OFFI CER, I T' S I MPORTANT TO
7 DOCUMENT THI NGS.
8 SOME PEOPLE LI KE ME MI GHT SAY, WHY DO YOU NEED
9 A PI CTURE OF THE MAI LBOX? YOU WOULD SAY WHAT?
10 A I ' D SAY I ' D WANT TO GI VE THE VI EWER OF THE
11 PHOTOGRAPHS A VI SUAL J OURNEY THROUGH THE SCENE.
12 Q AND THAT' S WHAT YOUR J OB I S TO DO?
13 A YES.
14 Q OKAY.
15 SO THEN I ' D LI KE TO SHOWYOU EXHI BI T 500- 11.
16 ANOTHER LOS ANGELES POLI CE DEPARTMENT PHOTOGRAPH
17 ( I NDI CATI NG) .
18 AND THAT I S THE WHAT?
19 A THI S I S THE FRONT OF THE CAROLWOOD RESI DENCE
20 FROM J UST I NSI DE OF THE ELECTRI C WROUGHT I RON GATE.
21 Q AND DI D YOU ATTEMPT TO I DENTI FY ANY OF THE
22 VEHI CLES THAT WERE PARKED AT THI S LOCATI ON?
23 A YES, I DI D.
24 Q LET ME SHOWYOU EXHI BI T 500- 192 ( I NDI CATI NG) .
25 THAT' S - - WHAT KI ND OF CAR I S THAT?
26 A THAT' S A BMW6 SERI ES.
27 Q DI D YOU TAKE PHOTOGRAPHS OF THAT?
28 A YES.
866 299-5127
2384
1 Q LET ME SHOWYOU ANOTHER ONE. 193 ( I NDI CATI NG) .
2 THAT' S THE FRONT OF THE VEHI CLE?
3 A I T I S.
4 Q 194 ( I NDI CATI NG) .
5 SOMEBODY I S I N THE BACKGROUND. WHO I S THAT?
6 A DETECTI VE SMI TH.
7 Q HE' S WORKI NG WI TH YOU?
8 A YES, SI R.
9 Q AND EXHI BI T 500- 195 ( I NDI CATI NG) .
10 SOMEBODY ELSE I N THAT PHOTOGRAPH?
11 A YES.
12 Q WHO I S THAT?
13 A ME.
14 Q OKAY. DI D YOU MAKE A DETERMI NATI ON AS TO
15 WHO - - STRI KE THAT.
16 WHY WOULD YOU WANT TO DETERMI NE WHOSE VEHI CLES
17 WERE AT THE SCENE?
18 A LOOKI NG FOR ADDI TI ONAL WI TNESSES AND EVI DENCE.
19 Q THAT' S STANDARD PRACTI CE I N AN I NVESTI GATI ON
20 LI KE THI S?
21 A YES.
22 Q DI D YOU DETERMI NE WHO THE OWNER OF THE BMWWAS?
23 A THE OWNER AND DRI VER, YES.
24 Q OKAY. AND WHO WAS THAT?
25 A DR. MURRAY. DR. CONRAD MURRAY.
26 Q DI D YOU SEARCH THE VEHI CLE AT THAT TI ME?
27 A NO.
28 Q WHY NOT?
866 299-5127
2385
1 A I WANTED TO GET A SEARCH WARRANT FI RST.
2 Q WHY DO YOU NEED TO DO THAT?
3 A THI NKI NG FORWARD TO COURT, I N CASE THERE' S ANY
4 I SSUES OF STANDI NG, I T' S - - WE WERE I N NO RUSH. EASY
5 FOR ME TO WRI TE A SEARCH WARRANT TO GET I NTO THE CAR.
6 THAT WAY I T WOULD BE - - ANYTHI NG THAT WE FOUND I NSI DE
7 WOULD BE ADMI TTED AS EVI DENCE AND NOT HAVE ANY I SSUES.
8 Q SO YOU DON' T J UST RUSH I N, OPEN SOMEONE' S CAR
9 AND START LOOKI NG AROUND, GENERALLY SPEAKI NG?
10 A CORRECT.
11 Q AND THEN A J UDGE, THEN, WOULD SI GN OFF ON A
12 SEARCH WARRANT, SAYI NG YOU HAD PROBABLE CAUSE TO SEARCH
13 THE VEHI CLE?
14 A YES, SI R.
15 Q AND I N THE MEAN - - HOWLONG DOES I T TAKE TO GET
16 THE SEARCH WARRANT PREPARED, SI GNED BY A J UDGE? YOU GO
17 WAKE THEM UP THAT NI GHT, LI KE ON TV?
18 A WE COULD. WE HAVE. I N THI S CASE I DI D NOT,
19 BUT I T CAN BE ANYWHERE FROM AN HOUR TO A FEWHOURS.
20 Q OKAY. SO WHAT DI D YOU DO? DI D YOU LEAVE THE
21 CAR THERE?
22 A I DI D NOT.
23 Q WHY NOT?
24 A I WANTED, A, TO GI VE DR. MURRAY A REASON TO
25 COME TALK TO ME; AND B, TO LOOK THROUGH I T I N A SECURE
26 ENVI RONMENT. SO I HAD I T I MPOUNDED.
27 Q SOMEBODY TOWTHE VEHI CLE?
28 A YES.
866 299-5127
2386
1 Q AND I S THAT - - DO YOU HAVE LI KE AN I MPOUND LOT
2 WHERE YOU STORE EVI DENCE?
3 A YEAH. WE HAVE SEVERAL OFFI CI AL POLI CE GARAGES
4 THAT HAVE SECURE, WHAT WE CALL " PRI NT SHEDS, " THAT
5 NOBODY CAN GET I N AND OUT OF EXCEPT FOR AUTHORI ZED
6 PERSONNEL.
7 I HAD I T TRANSPORTED TO THE ONE THAT HANDLED
8 THE WEST L. A. AREA.
9 Q I S THAT ON BARRI NGTON I N WEST LOS ANGELES?
10 A YES.
11 Q DI D YOU EVER GET THE KEYS TO THE VEHI CLE?
12 A I DI D.
13 Q WHERE DI D YOU GET THOSE FROM?
14 A FROM DR. MURRAY.
15 Q OKAY. DO YOU KNOWWHO J EFFREY ADAMS I S?
16 A YES.
17 Q WHO I S THAT?
18 A HE WAS DR. MURRAY' S FRI END/ BODYGUARD WHO WAS
19 ACTUALLY I N POSSESSI ON OF THE KEYS, AND DR. MURRAY TOLD
20 HI M TO GI VE THEM TO ME.
21 Q OKAY. DI D YOU THAT NI GHT ENTER THE HOME?
22 A YES, I DI D.
23 Q AND WHAT WERE YOU DOI NG? WHY DI D YOU DO THAT?
24 A TO LOOK AT THE - - TO LOOK AT THE SCENE TO
25 RECOVER ANY EVI DENCE. TO I NVESTI GATE THE DEATH OF
26 MR. J ACKSON.
27 Q DI D YOU NEED A SEARCH WARRANT TO DO THAT?
28 A DI D NOT.
866 299-5127
2387
1 Q WHY NOT?
2 A AT THAT TI ME WE WERE J UST I NVESTI GATI NG THE
3 DEATH. DI DN' T KNOWI F THERE WAS A CRI ME OR NOT. AND
4 THE CORONER' S OFFI CE HAS LEGAL STANDI NG TO GO AND SEE
5 THE SCENE FOR PURPOSES OF DETERMI NI NG CAUSE OF DEATH.
6 Q DI D YOU GO I NTO THE BEDROOM WHERE MR. J ACKSON
7 WAS LOCATED?
8 A YES.
9 Q ALL RI GHT. I WANT TO SHOWYOU EXHI BI T 500- 21,
10 A LOS ANGELES POLI CE DEPARTMENT PHOTOGRAPH ( I NDI CATI NG) .
11 I S THAT THE BEDROOM THAT YOU ENTERED?
12 A YES.
13 Q WHERE WAS THAT? ON THE FI RST OR SECOND FLOOR?
14 A SECOND FLOOR.
15 Q AND WAS THAT ON THE END? I N THE MI DDLE? WHERE
16 WAS THAT?
17 A I T WAS THE SECOND ROOM GOI NG FROM THE LEFT TO
18 THE RI GHT AT THE TOP OF THE STAI RS.
19 Q OKAY. NOW, WHEN YOU WENT I N THE ROOM, DI D YOU
20 NOTI CE ANYTHI NG THAT YOU FELT, BASED ON YOUR TRAI NI NG
21 AND EXPERI ENCE, WAS UNUSUAL?
22 A YES.
23 Q TELL US ABOUT I T.
24 A WELL, I SAWAN I V STAND WI TH AN EMPTY I V BAG,
25 SOME TUBI NG, AN AMBU BAG.
26 Q WHAT KI ND OF BAG?
27 A AN AMBU BAG. A BAG USED TO HELP BREATHI NG, TO
28 HELP RESUSCI TATE PATI ENTS.
866 299-5127
2388
1 OXYGEN TANKS, PI LL BOTTLES AND VI ALS OF LI QUI D.
2 Q DI D I T LOOK TO YOU LI KE ANYONE HAD TRI ED TO DO
3 ANYTHI NG I N THE ROOM AFTER MR. J ACKSON HAD BEEN REMOVED?
4 A I DON' T KNOW- - I T LOOKED LI KE THE ROOM HAD
5 BEEN CLEANED UP.
6 Q WHAT DO YOU MEAN BY THAT, " CLEANED UP" ?
7 A YOU KNOW, TRAI NI NG AND EXPERI ENCE, AS YOU CAN
8 SEE I N THE PHOTO, THERE' S A LI TTLE GLASS TABLE NEXT TO
9 THE BED. AND LOOKI NG AT THE TABLE, THERE' S J UNK PI LED
10 ON TOP OF EACH OTHER, AND YET THERE' S CLEAR OPEN AREAS.
11 SO NORMAL HUMAN CONDUCT, I T' S NOT SOMETHI NG
12 THAT I SEE THAT PEOPLE WOULD STACK STUFF UP. THEY' D LAY
13 I T I N OPEN AREAS. SO I T LOOKED LI KE THERE WERE AREAS
14 WHERE THI NGS WERE MI SSI NG.
15 Q THAT' S A PART OF WHAT YOU LEARNED AS AN
16 I NVESTI GATOR, BEI NG ON NUMEROUS SCENES, THAT YOU' D LOOK
17 FOR THI NGS LI KE THAT?
18 A YES.
19 Q SO BASED ON THAT, WHAT DI D YOU THI NK AT THAT
20 TI ME?
21 A THAT THI NGS HAD BEEN REMOVED FROM THE ROOM
22 PRI OR TO MY ARRI VAL. OR PRI OR TO THE POLI CE' S ARRI VAL.
23 MR. PANI SH: CAN I APPROACH, YOUR HONOR?
25 Q BY MR. PANI SH: OKAY. I ' M GOI NG TO GI VE YOU A
26 LASER POI NTER HERE. DOESN' T REALLY WORK THERE, SO WE
27 HAVE TO DO I T UP THERE ( I NDI CATI NG) .
28 CAN YOU J UST POI NT OUT FOR US BY THE CLOCK
866 299-5127
2389
1 THERE WHAT YOU' VE I NDI CATED WAS THE NI GHTSTAND THAT YOU
2 BELI EVE HAD BEEN CLEANED UP?
3 A TOWARDS THE MI D RI GHT SECTI ON OF THE PHOTO
4 ( I NDI CATI NG) . NEXT TO A - - LI KE A CAPTAI N' S CHAI R.
5 TAN/ CREAM CAPTAI N' S CHAI R.
6 Q LET' S ZOOM THAT I N MORE.
7 OKAY. NOWWE' RE LOOKI NG AT I T?
8 A YES, SI R.
9 Q OKAY. NOWI WANT TO SHOWYOU EXHI BI T 500- 91
11 OKAY. AND I ASSUME THESE PI CTURES ARE TAKEN
12 FOR A REASON, J UST LI KE THE MAI LBOX?
13 A YES.
14 Q AND WHAT I S THE REASON FOR TAKI NG SCENE
15 PHOTOGRAPHS?
16 A TO DOCUMENT THE SCENE I N SI TU, AS I T I S, FOR
17 LATER USE EI THER AT AN I NQUEST OR DURI NG TRI AL.
18 Q LI KE HERE.
19 SO, I N OTHER WORDS, YOU' RE ABLE TO EXPLAI N WHAT
20 YOU SEE I N THE PHOTOGRAPHS?
21 A YES, SI R.
22 Q OKAY. AND I N THI S PHOTOGRAPH, 500- 91, THERE' S
23 SOMETHI NG THAT' S BEI NG I NDI CATED, I ASSUME, I S WHY THI S
24 PHOTOGRAPH WAS TAKEN?
25 A YES.
26 Q AND WHAT WAS THAT?
27 A I T' S A BOTTLE OR VI AL OF PROPOFOL I NJ ECTABLE
28 EMULSI ON, 1 PERCENT, THAT I S LYI NG ON THE FLOOR
866 299-5127
2390
1 UNDERNEATH THE NI GHTSTAND.
2 Q CAN YOU I NDI CATE THAT FOR US, PLEASE, ON THE
3 EXHI BI T?
4 A I N THE CENTER OF THE PHOTOGRAPH ( I NDI CATI NG) .
5 Q I SEE. SO THAT PHOTOGRAPH WAS TAKEN FOR THAT.
6 LET ME SHOWYOU 500- 92 ( I NDI CATI NG) .
7 MR. PANI SH: YOUR HONOR, WHEN I SAY THAT, I
8 MEAN DASH 92.
9 Q BY MR. PANI SH: AND WHAT DOES THAT SHOWTHERE?
10 A A CLOSE- UP OF THE SAME BOTTLE.
11 Q OKAY. AND HOWABOUT 500- 95 ( I NDI CATI NG) ?
12 I S THAT A REAL CLOSE- UP?
13 A YES, I T I S.
14 Q ALL RI GHT. ALL THESE ARE OF THE SAME PROPOFOL
15 BOTTLE?
16 A THEY ARE.
17 Q AND THAT WAS THERE WHEN YOU ARRI VED?
18 A YES.
19 Q WERE THERE OTHER THI NGS THAT YOU PHOTOGRAPHED
20 THAT YOU FELT WOULD BE I MPORTANT TO MAI NTAI N AS PART OF
21 YOUR I NVESTI GATI ON?
22 A YES.
23 Q LET ME SHOWYOU NOW500- 39 ( I NDI CATI NG) .
24 OKAY. I S THERE SOMETHI NG I N THAT PI CTURE THAT
25 WAS I MPORTANT?
26 A YES.
27 Q WHAT I S THAT?
28 A THE I V STAND, THE SALI NE BAG, THE TUBI NG AND
866 299-5127
2391
1 THE SYRI NGE ATTACHED TO I T, AND ALSO THE OXYGEN BOTTLES.
2 Q LET ME SHOWYOU 500- 44 ( I NDI CATI NG) .
3 WHEN YOU MENTI ONED THAT TERM AMBU BAG - -
4 A AMBU.
5 Q AMBU. CAN YOU POI NT THAT OUT FOR US?
6 A AT THE LOWER CENTER OF THE PI CTURE, THI S
7 BLUI SH/ PURPLE THI NG I S AN AMBU BAG ( I NDI CATI NG) .
8 Q AND I S THERE AN OXYGEN TANK I N THERE?
9 A YES, THERE I S.
10 Q WHERE I S THAT LOCATED?
11 A I N THE LOWER RI GHT FOURTH OF THE PHOTOGRAPH.
12 SI LVER AND GREEN.
13 Q DI D YOU SEE A MASK TO GO WI TH THE OXYGEN?
14 A THERE WAS A - - LI KE A TRI ANGULAR COVER THAT
15 WENT WI TH I T, BUT I T WAS NOT ATTACHED.
16 Q RI GHT.
17 OKAY. LET ME SHOWYOU 500- 56 ( I NDI CATI NG) .
18 THI S LOOKS TO BE WHAT?
19 A THESE ARE THREE PRESCRI PTI ON BOTTLES THAT WERE
20 FOUND AT THE SCENE I N THE NAME OF MR. J ACKSON.
21 Q PRESCRI BED BY A PHYSI CI AN?
22 A YES, SI R.
23 Q AND THEN THERE' S BAYER ASPI RI N? I S THAT FI J I
24 WATER?
25 A YES, I T I S.
26 Q AND YOU TOOK THAT TO PRESERVE THAT I N EVI DENCE?
27 A YES.
28 Q AND LET ME SHOWYOU NOW500- 276 ( I NDI CATI NG) .
866 299-5127
2392
1 WHAT I S THAT?
2 A THESE ARE TWO PI LL BOTTLES AND ONE SALVE BOTTLE
3 THAT WERE FOUND I N HI S - - I BELI EVE I N HI S BATHROOM.
4 Q OKAY. AND THEN ONE OF THEM LOOKS LI KE
5 DI AZEPAM, 10 MI LLI GRAMS; LORAZEPAM, 2 MI LLI GRAMS. AND
6 THEN THE ONE ALL THE WAY TO THE LEFT, I S THAT LI KE A - -
7 WHAT DO YOU CALL I T? A SALVE KI ND OF - -
8 A NYSTATI N CREAM FOR FUNGAL I NFECTI ONS.
9 Q YOU PUT ON YOUR SKI N?
10 A YES, SI R.
11 Q AND YOU DOCUMENT THAT?
12 A YES, SI R.
13 Q WHAT WERE THE I SSUES THAT YOU WERE
14 I NVESTI GATI NG ON J UNE 25TH?
15 A J UNE 25TH, TRYI NG TO ASSI ST THE CORONER' S
16 OFFI CE I N DETERMI NI NG THE CAUSE AND MANNER OF DEATH.
17 Q AND AT THAT TI ME DI D YOU DETERMI NE WHETHER THI S
18 WAS ACCI DENTAL, NATURAL, BASED ON SI GNS OF TRAUMA? WHAT
19 WAS YOUR I MPRESSI ON AT THAT TI ME?
20 A AT THAT TI ME I WAS LEANI NG TOWARDS A NATURAL OR
21 ACCI DENTAL. THERE WERE NO SI GNS OF TRAUMA. NO - - OTHER
22 THAN THE OBJ ECTS THAT WERE RECOVERED AT THE SCENE, NO
23 REAL SI GNS OF FOUL PLAY. I T WAS ODD, BUT NOT A RED
24 FLAG.
25 Q DI D YOU GO BACK TO THE LOCATI ON ON ANOTHER DAY?
26 A YES.
27 Q WHEN WAS THAT?
28 A WENT BACK ON THE 26TH AND THE 29TH.
866 299-5127
2393
1 Q OKAY. WHY DI D YOU GO BACK ON THE 26TH?
2 A TO RECOVER ADDI TI ONAL EVI DENCE.
3 Q AND WHY DI D YOU GO BACK ON THE 29TH?
4 A TO RECOVER EVEN MORE EVI DENCE.
5 Q DI D YOU LEARN, AS PART OF YOUR I NVESTI GATI ON,
6 ABOUT OTHER EVI DENCE THAT MAY BE BACK AT THE HOME?
7 A YES.
8 Q WHAT WAS THAT?
9 A UHM, LEARNED ABOUT - - I BELI EVE I T WAS THREE
10 BAGS FULL OF MEDI CI NES THAT WERE I N THE CLOSET NEXT TO
11 THAT ROOM THAT WAS SHOWN.
13 A FROM DR. MURRAY.
14 Q OKAY. WAS THERE A SEARCH ON THE 29TH OF THE
15 PREMI SES?
16 A YES.
17 Q WERE YOU PRESENT DURI NG THAT SEARCH?
18 A NOT FOR ALL OF I T.
19 Q OKAY. DI D YOU HAVE TO LEAVE AT SOME POI NT?
20 A YES.
21 Q WHY DI D YOU HAVE TO LEAVE?
22 A I HAD TO BRI EF THE CHI EF OF POLI CE.
23 Q NOW, I WANT TO SHOWYOU - - AND, BY THE WAY, CAN
24 YOU - - WHAT I S THE CHAI N OF CUSTODY? WHAT DOES THAT
25 MEAN?
26 A CHAI N OF CUSTODY I S A WAY WE DOCUMENT HOWWE
27 TAKE POSSESSI ON OF EVI DENCE, AND HOWI T' S STORED. THAT
28 WAY THERE' S NO QUESTI ON AS TO I F SOMEONE MESSED WI TH I T,
866 299-5127
2394
1 TAMPERED WI TH I T, CHANGED I T, AND THAT - - FOR COURT
2 PURPOSES.
3 Q OKAY. WI TH RESPECT TO THE EVI DENCE TAKEN AT
4 THE FACI LI TY, AT THE PREMI SES ON THOSE SEVERAL DAYS, ARE
5 YOU ABLE TO LAY THE CHAI N OF CUSTODY FOR US?
6 A YES.
7 Q OKAY. I WANT TO SHOWYOU EXHI BI T 500- 343
9 WHAT I S THI S ATTEMPTI NG TO SHOW?
10 A THI S I S SHOWI NG THE OPEN CABI NET ABOVE THE
11 DRESSER.
12 Q CAN YOU POI NT I T OUT FOR US?
13 A THE OPEN CABI NET ABOVE THE DRESSER HAS THREE
14 BAGS I NSI DE OF I T, AND THAT I S WHAT I S BEI NG DEPI CTED I N
15 THAT PHOTOGRAPH.
16 Q DO YOU KNOWWHO PUT THOSE BAGS THERE?
17 A DR. MURRAY.
18 Q I WANT TO SHOWYOU EXHI BI T 500- 344
20 A J UST A CLOSE- UP, DI FFERENT ANGLE, OF THE SAME
21 BAGS.
22 Q OKAY. AND HOWABOUT 352 ( I NDI CATI NG) ?
23 A TWO OF THE BAGS HAD BEEN REMOVED, AND I T' S
24 ANOTHER BAG THAT WAS UP THERE THAT YOU COULDN' T SEE
25 BECAUSE I T WAS BEI NG BLOCKED I N THE OTHER PHOTOGRAPHS.
26 Q I T APPEARS TO ME THERE ARE DOORS TO THE
27 CABI NET?
28 A YES. DOUBLE DOORS THAT CLOSE.
866 299-5127
2395
1 Q SO WHEN YOU WENT THERE, WHEN THE POLI CE WENT
2 THERE, THE CABI NET WAS CLOSED?
3 A YES, SI R.
4 Q AND THEN WHEN YOU TOOK THE PHOTOGRAPHS, YOU
5 OPENED THE DOORS - -
6 A YES, SI R.
7 Q - - TO DOCUMENT I T; I S THAT RI GHT?
8 A YES, SI R.
9 Q WHAT DI D THE POLI CE FI ND - - STRI KE THAT.
10 WHEN YOU OPENED THE BAGS, DI D YOU FI ND EVI DENCE
11 I N THERE?
12 A YES, WE DI D.
13 Q DI D YOU DOCUMENT WHAT THAT EVI DENCE WAS?
14 A YES.
15 Q I ' D LI KE TO SHOWYOU 500- 356 ( I NDI CATI NG) .
16 THI S I S ONE OF THE BAGS?
17 A I T I S.
18 Q AND WHAT WAS I N THAT BAG?
19 A A - - MAY I USE THE - -
20 Q YES, PLEASE.
21 A A BLOOD PRESSURE CUFF STI LL I N I TS CARTON AND
22 BOTTLES OF, I BELI EVE, PROPOFOL AND LI DOCAI NE.
23 Q WHAT I S LI DOCAI NE?
24 A LI DOCAI NE I S A LOCAL ANESTHETI C.
25 Q DO YOU KNOWWHAT THAT WAS USED FOR?
26 A PROPOFOL BURNS WHEN I T' S GOI NG I N, SO I T' S USED
27 TO REDUCE THE BURNI NG SENSATI ON.
28 Q LI KE NUMB I T UP, KI ND OF?
866 299-5127
2396
1 A YES.
2 Q LET' S LOOK AT 500- 358 ( I NDI CATI NG) .
3 I S THI S THAT BLUE BAG WE SAWI N THE OTHER
4 PHOTOGRAPH?
5 A YES, SI R.
6 Q WHAT WAS I NDI CATED TO BE CONTAI NED WI THI N THAT
7 BAG?
8 A THERE WAS A PULSE OXI METER - - A NON- ALARM PULSE
9 OXI METER, THE BLACK THI NG WI TH THE CABLE. BOTTLES OF
10 PROPOFOL, AND ALSO, LI KE, SYRI NGES AND TRASH WRAPPERS
11 FROM OPEN MEDI CAL EQUI PMENT.
12 Q OKAY. WI THI N THAT BLUE BAG, I S THERE ALSO A
13 PLASTI C WHI TE BAG?
14 A A - - ARE YOU REFERRI NG TO THE SALI NE BAG?
15 Q WELL, HAVE YOU EVER BEEN TO, LI KE, CVS?
16 A YES.
17 Q YOU KNOWTHOSE KI ND OF WHI TE - - YOU BUY YOUR
18 STUFF, AND THEY PUT I T I N A BAG LI KE THAT?
19 A YES.
20 Q DI D YOU SEE A PLASTI C BAG THAT HAD STUFF I NSI DE
21 THE BLUE BAG?
22 A YES.
23 Q AND I S THAT DEPI CTED - - COULD YOU SHOWUS THAT
24 I N THE PHOTOGRAPH?
25 A I T' S THI S BAG RI GHT HERE ( I NDI CATI NG) . I T' S - -
26 YOU CAN SEE THE RED ON I T.
27 Q DI D YOU TAKE FI NGERPRI NTS OF THAT?
28 A NOT AT THE SCENE. WE PRI NTED EVERYTHI NG AT THE
866 299-5127
2397
1 CORONER' S OFFI CE A LI TTLE BI T LATER.
2 Q DI D YOU FI ND DR. MURRAY' S FI NGERPRI NTS ON THAT
3 WHI TE PLASTI C BAG? DO YOU REMEMBER?
4 A I ' M NOT SURE I F ON THE BAG. I ' M NOT POSI TI VE.
5 Q OKAY. ON THE OTHER BAGS YOU FOUND
6 DR. MURRAY' S?
7 A ON THE BOTTLES.
8 Q OKAY. ALL RI GHT.
9 NOW, LET' S LOOK AT 500- 360 ( I NDI CATI NG) .
10 OKAY, FI RST OF ALL, THAT RULER THAT' S THERE,
11 WAS THAT THERE WHEN YOU ARRI VED?
12 A NO. THAT' S PLACED THERE BY THE PHOTOGRAPHER.
13 Q AND WHY DOES THE PHOTOGRAPHER PLACE A - - I S
14 THAT A 12- I NCH RULER?
15 A NO. SI X I NCHES.
16 Q AND I S THAT STANDARD POLI CE WORK TO USE THAT
17 KI NDS OF RULER TO ORI ENT PEOPLE ABOUT HOWBI G THE
18 PHOTOGRAPH I S?
19 A EXACTLY.
20 Q I DON' T KNOWI F THAT WAS A CORRECT QUESTI ON.
21 A I T' S FOR SCALI NG.
22 Q SCALI NG. THAT' S I T, THANK YOU. FOR SCALE.
23 SO YOU KNOWTHAT' S A SI X- I NCH AREA WHERE THOSE
24 THREE BOTTLES ARE, AND THOSE ARE THREE BOTTLES OF
25 LI DOCAI NE?
26 A YES, SI R.
27 Q LET' S LOOK NOWAT 500- 362 ( I NDI CATI NG) .
28 YOU SEE, ONCE AGAI N, I S THAT THE SAME
866 299-5127
2398
1 SI X- I NCH- SCALE RULER?
2 A YES, SI R.
3 Q AND TO THE RI GHT - - TO MY RI GHT, ANYWAY - -
4 THERE' S A BLACK AND RED DEVI CE.
5 A YES, SI R.
6 Q DO YOU KNOWWHAT THAT I S?
7 A THAT I S A NONI N ONYX PULSE OXI METER.
8 Q DO YOU KNOWWHAT THAT DOES, OR WHAT I T' S USED
9 FOR?
10 A I T MEASURES THE OXYGEN SATURATI ON I N THE BLOOD.
11 Q AND WAS THAT PLUGGED I N?
12 A I T WAS NOT.
13 THE COURT: CAN I ASK WHERE YOU FOUND THESE
14 I TEMS? WHAT ARE WE LOOKI NG AT? I S THAT A FLOOR OR
15 TABLETOP?
16 THE WI TNESS: THE TABLETOP WAS J UST FOR THE
17 PHOTOGRAPH. I T WAS FOUND I N THE LI GHT BLUE SATCHEL.
18 THE COURT: SO YOU HAD ACTUALLY REMOVED SOME OF
19 THESE TO PHOTOGRAPH THEM?
20 THE WI TNESS: YES, MA' AM.
21 MR. PANI SH: THANK YOU, YOUR HONOR. THAT WAS A
22 GOOD QUESTI ON.
23 Q BY MR. PANI SH: LET' S LOOK AT THE NEXT ONE,
24 500- 381 ( I NDI CATI NG) .
25 SAME THI NG. I S THI S SOMETHI NG REMOVED FROM THE
26 BAG, PLACED ON THI S TABLE TO PHOTOGRAPH I T?
27 A YES.
28 Q AND WHAT ARE WE SEEI NG I N THAT LOCATI ON?
866 299-5127
2399
1 A AN EMPTY PROPOFOL BOTTLE, AND ALSO AN EMPTY I V
2 BAG WI TH A - - I THI NK I T WAS ABOUT A TWO- AND- A- HALF- I NCH
3 SLI T I N THE MI DDLE OF I T.
4 Q DO YOU KNOWWHO SLI T THE I V BAG?
5 A DR. MURRAY.
6 Q AND WHEN YOU SLI CE I T, DOES ALL THE LI QUI D COME
7 OUT?
8 A YES.
9 Q OKAY. I WANT TO SHOWYOU NOW383. 500- 383
11 SAME QUESTI ONS. TAKEN FROM THE BAG, PLACED ON
12 THE TABLE TO DOCUMENT?
13 A YES.
14 Q WHAT DI D WE SEE THERE?
15 A WE SEE EYE DROPS TO THE FAR LEFT; A BOTTLE OF
16 PROPOFOL; BOTTLE OF LI DOCAI NE; A TUBE OF BENOQUI N; A
17 BOTTLE OF EPHEDRI NE AND CAFFEI NE PI LLS; AND AT THE TOP,
18 A BUSI NESS CARD FOR DR. MURRAY' S HOUSTON, TEXAS OFFI CE,
19 ACRES HOME AND HEART CLI NI C.
20 Q OKAY. LET' S GO TO THE TUBE THERE. WHAT I S
21 THAT A TUBE OF?
22 A A MI X OF BENOQUI N.
23 Q WHAT I S THAT?
24 A I T' S LI KE A - - I T' S SOMETHI NG THAT YOU RUB ON
25 THE SKI N TO GET RI D OF - - I T BLEACHES THE SKI N. I T GETS
26 RI D OF SCARS AND SPOTS.
27 Q AND THOSE RED AND BLUE PI LLS, THOSE LOOK LI KE
28 ENERGY PI LLS.
866 299-5127
2400
1 A EPHEDRI NE AND CAFFEI NE, ASPI RI N. YES, ENERGY
2 PI LLS.
3 Q AND LET' S LOOK AT 384 ( I NDI CATI NG) . I THI NK
4 THI S I S J UST A - - THI S I S A CLOSE- UP - - I S THI S J UST A
5 CLOSE- UP OF THE OTHER PI CTURE?
6 A YES, SI R.
7 Q OKAY. LET' S LOOK AT 390.
8 THESE ARE TAKEN OUT OF THE BAG; CORRECT?
9 A YES, SI R.
10 Q I S THAT THE BLUE BAG THEY WERE TAKEN FROM?
11 A I THI NK I T WAS STI LL THE LI GHT BLUE BAG, NOT
12 THI S.
13 Q TELL US WHAT WE SEE THERE.
14 A FOUR BOTTLES, FOUR LARGE BOTTLES OF THE
15 PROPOFOL AND - - J UST FOUR REGULAR BOTTLES OF PROPOFOL;
16 TWO BOTTLES OF FLUMAZENI L, BOTTLES OF MI DAZOLAM, AND A
17 BOTTLE ON THE FAR RI GHT OF LORAZEPAM.
18 Q LET' S START ON THE FAR RI GHT.
19 LORAZEPAM, I S THAT SOMETHI NG THAT' S GI VEN I N
20 PI LL FORM, ALSO?
21 A YES, SI R.
22 Q AND YOU FOUND A BOTTLE OF PI LLS OF THAT; RI GHT?
23 A I BELI EVE SO.
24 Q AND THI S I S FOR I NJ ECTI ONS, THE LI QUI D; RI GHT?
25 A YES.
26 Q NEXT TO THAT, THAT' S THE GENERI C NAME FOR
27 ATI VAN?
28 A YES.
866 299-5127
2401
1 Q WHAT DO YOU CALL I T AGAI N?
2 A MI DAZOLAM.
3 Q THAT' S ALSO A LI QUI D SUBSTANCE THAT CAN BE
4 I NJ ECTED.
5 LORAZEPAM I S ATI VAN, MI DAZOLAM I S VERSED. DOES
6 THAT REFRESH YOUR RECOLLECTI ON?
7 A YES.
8 Q I ' M NOT A PHARMACI ST, BUT I THI NK THAT' S RI GHT.
9 THEN THE NEXT TWO BOTTLES ARE WHAT?
10 A FLUMAZENI L.
11 Q WHAT I S THAT?
12 A I BELI EVE I T' S FOR PROSTATE.
13 Q DO YOU KNOWWHAT THAT WAS FOR?
14 A I ' M NOT SURE ABOUT THE FLUMAZ.
15 Q ALL RI GHT.
16 LET' S LOOK AT EXHI BI T 500- 337 ( I NDI CATI NG) .
17 THESE ARE OXYGEN BOTTLES LOCATED I N THE HOUSE?
18 A THEY WERE I N A GUARD SHED RI GHT AT THE SI DE OF
19 THE HOUSE. I T WAS LI KE A TRAI LER THAT THE GUARD SAT I N.
20 Q ALL RI GHT. LET' S LOOK AT 500- 86 ( I NDI CATI NG) .
21 MS. BI NA: I ' M SORRY. WHAT WAS THAT LAST ONE?
22 MR. PANI SH: EXHI BI T NUMBER?
23 MS. BI NA: YES.
24 MR. PANI SH: 337.
25 Q BY MR. PANI SH: OKAY. WHAT ARE THOSE?
26 A MR. J ACKSON' S CLOTHI NG THAT WAS I N THE CLOSET
27 OFF THE ROOM WHERE HE WAS BEI NG TREATED.
28 Q OKAY. NOW- -
866 299-5127
2402
1 MR. PANI SH: WHAT TI ME ARE WE TAKI NG THE BREAK,
2 YOUR HONOR? 3: 00?
3 THE COURT: YEAH. FI VE MI NUTES.
5 Q BY MR. PANI SH: SO THE BMWTHAT WE TALKED
6 ABOUT, WAS THAT CAR REGI STERED TO DR. MURRAY, OR WAS
7 THAT CAR REGI STERED TO SOMEONE ELSE?
8 A I T WAS REGI STERED TO SOMEONE ELSE.
9 Q WHO WAS THAT VEHI CLE - - OR HOWDO YOU DETERMI NE
10 WHO I S THE REGI STERED OWNER OF THE VEHI CLE?
11 A RUN I T THROUGH D. M. V. , THE DEPARTMENT OF MOTOR
12 VEHI CLES.
13 Q I S THAT AN EASY THI NG TO DO FOR A POLI CE
14 OFFI CER LI KE YOURSELF?
15 A YES, SI R.
16 Q OR ANYONE?
17 A YES, SI R.
18 Q AND WHEN YOU GOT THAT BACK - - I ASSUME THAT
19 YOU - - DO YOU DO THAT LI KE A COMPUTER SEARCH?
20 A YES, SI R.
21 Q AND THEN I T TELLS YOU THE NAME OF AN OWNER?
22 A YES.
23 Q AND THAT WAS NAMED SARA MURRAY?
24 A SUSAN RUSH.
25 Q SUSAN RUSH. I ' M SORRY. AND DI D THAT
26 I NDI VI DUAL HAVE A TEXAS ADDRESS?
27 A YES, SHE DI D.
28 Q AND DI D YOU CONTACT THAT I NDI VI DUAL?
866 299-5127
2403
1 A I DI D.
2 Q AND DI D YOU DETERMI NE WHETHER OR NOT SHE WAS
3 THE ACTUAL OWNER OF THE VEHI CLE?
4 A I DI D.
5 Q AND WHAT DI D YOU LEARN?
6 A THAT I T WAS J UST REGI STERED I N HER NAME, BUT I T
7 WAS HER BROTHER' S CAR.
8 Q DI D SHE TELL YOU WHY I T WAS REGI STERED I N HER
9 NAME?
10 A I DI D NOT ASK HER.
11 Q OKAY. WHO I S HER BROTHER?
12 A DR. CONRAD MURRAY.
13 Q OKAY. WAS DR. CONRAD MURRAY - - STRI KE THAT.
14 AS A RESULT OF ALL THE I NVESTI GATI ON YOU DI D,
15 WAS DOCTOR - - WHERE WAS CONRAD MURRAY LI VI NG?
16 A WELL, HE WAS LI VI NG I N SANTA MONI CA AND I N LAS
17 VEGAS.
18 Q WAS HE LI VI NG I N TEXAS?
19 A HE WOULD STAY AT HI S SI STER' S HOUSE WHEN HE
20 WOULD GO TO HI S CLI NI C I N TEXAS.
21 Q HE DI DN' T GO TO TEXAS VERY OFTEN, DI D HE?
22 A NO, HE DI D NOT.
23 Q SO THAT VEHI CLE THAT HE HAD, HE PRI MARI LY USED
24 THAT I N NEVADA AND CALI FORNI A?
25 A THAT I KNOWOF, YES, SI R.
26 Q WHERE DI D HE STAY I N SANTA MONI CA?
27 A WI TH HI S GI RLFRI END/ MI STRESS I N - - OFF OF 6TH
28 STREET.
866 299-5127
2404
1 Q WHAT WAS THE NAME OF THE I NDI VI DUAL?
2 A I DON' T REMEMBER.
3 Q NI COLE?
4 A NI COLE ALVAREZ.
5 Q AND DI D HER AND DR. MURRAY HAVE A CHI LD
6 TOGETHER?
7 A YES.
8 Q DI D YOU LEARN THAT DR. MURRAY HAD A LOT OF
9 CHI LDREN?
10 A YES, I DI D.
11 Q NOW, LET' S TAKE A LOOK AT 500- 314 ( I NDI CATI NG) .
12 THI S SHOWS THE LI CENSE PLATE SCH134. DO YOU
13 KNOWWHAT YEAR THAT VEHI CLE WAS?
14 A UHM, NOT OFF THE TOP OF MY HEAD. I CAN GET I T
15 FOR YOU I F YOU NEED I T.
16 Q I ' LL TELL YOU WHAT, AT THE BREAK WE' LL GET THAT
17 I NFORMATI ON.
18 AND THEN I F WE LOOK AT 500- 317 ( I NDI CATI NG) .
19 I S THI S A PHOTOGRAPH THAT WAS TAKEN OF THE
20 I NSI DE OF THE VEHI CLE BEFORE YOU SEARCHED I T?
21 A ON MONDAY, THE 29TH, YES.
22 Q OKAY. AND I S THAT WHEN YOU SEARCHED THE
23 VEHI CLE, ON MONDAY, THE 29TH?
24 A YES, SI R.
25 Q OKAY.
26 MR. PANI SH: WOULD THI S BE AN OKAY TI ME, YOUR
27 HONOR?
28 THE COURT: SURE. I F I T' S A GOOD TI ME FOR YOU,
866 299-5127
2405
1 SURE.
2 OKAY. 15 MI NUTES. I ' LL SEE YOU AT 3: 15.
3
4 ( THE J URY EXI TED THE COURTROOM AT 3: 00 P. M. )
5
6 ( A RECESS WAS TAKEN. )
7
8 THE COURT: J ACKSON VERSUS A. E. G. LI VE, BC
9 445597.
10 MR. PUTNAM BROUGHT I T TO MY CLERK' S ATTENTI ON
11 THERE MAY BE WI TNESSES DOWNSTAI RS WATCHI NG TESTI MONY?
12 MR. PUTNAM: I ' M J UST ASKI NG I F THEY' VE MADE AN
13 ANNOUNCEMENT DOWN THERE THAT MAY BE SHOWI NG, BECAUSE I
14 WANTED TO MAKE SURE THERE WOULDN' T BE ANY - -
15 THE COURT: I DON' T KNOWI F ANYONE HAS MADE ANY
16 ANNOUNCEMENT DOWN THERE.
17 I THI NK I F YOU WANTED TO SEND SOMEBODY DOWN
18 THERE WHO CAN MONI TOR - - I MEAN, THAT' S HOWWE WOULD DO
19 I T HERE, BECAUSE I DON' T KNOWWHO THE WI TNESSES ARE,
20 ONLY YOU KNOW.
21 SO I T WOULD BE I NCUMBENT UPON YOU TO TELL ME
22 WHO I S I N THE AUDI ENCE, WHETHER I T' S HERE OR THE OTHER
23 ROOM, AND THEN I CAN EXCLUDE THEM. BUT I CAN' T SEND
24 SOMEBODY DOWN THERE TO MONI TOR I T.
25 MR. PUTNAM: NO WORRI ES. WHAT I CAN DO - -
26 THE COURT: EVEN I N HERE, MY STAFF DOESN' T KNOW
27 WHO THE WI TNESSES ARE.
28 SO J UST BRI NG I T TO MY ATTENTI ON I F YOU SEE
866 299-5127
2406
1 SOMETHI NG LI KE THAT.
2 MR. PUTNAM: THAT' S EXACTLY WHAT WE' LL DO.
3 MR. PANI SH: ARE THEY WORKI NG ON THE AI R
4 CONDI TI ONI NG TODAY?
5 THE COURT: THEY DI D. I DON' T KNOW- -
6 MR. PANI SH: I DON' T KNOWI F I T WAS SUCCESSFUL.
7 THE CLERK: ACTUALLY COOLER TODAY THAN
8 YESTERDAY.
9 THE BAI LI FF: I T WENT FROM 63 TO 61.
10 THE COURT: THAT' S NOT A LOT, BUT I T' S
11 SOMETHI NG.
12 MS. BI NA: YOUR HONOR, ON THE WI TNESS LI ST, I
13 DON' T KNOWI F I T WOULD MAKE SENSE FOR " WI TNESSES
14 EXCLUDED" SI GNS, MAYBE, THAT CAN BE PUT ON THE DOOR OF
15 THE OTHER ROOM.
16 THE COURT: I THI NK WE CAN TRY TO DO THAT.
17 THANK YOU.
18
19 ( THE J URY ENTERED THE COURTROOM AT 3: 21 P. M. )
20
21 THE COURT: KATHERI NE J ACKSON VERSUS A. E. G.
22 LI VE, BC 445597.
23 YOU MAY CONTI NUE.
24 MR. PANI SH: THANK YOU, YOUR HONOR.
25 Q BY MR. PANI SH: DETECTI VE, I WANT TO SHOWYOU
26 EXHI BI T 500- 394 ( I NDI CATI NG) .
27 THE CLERK: YOUR HONOR, I S I T 394 OR - - OKAY.
28 Q BY MR. PANI SH: AND J UST TELL US BRI EFLY WHAT
866 299-5127
2407
1 THAT SHOWS.
2 A FOUR MORE BOTTLES OF PROPOFOL, ONE OF
3 FLUMAZENI L, ONE OF LORAZEPAM, AND ANOTHER OF MI DAZOLAM.
4 Q NOW, BEFORE THE BREAK - - WE CAN TAKE THAT
5 DOWN - - WE TALKED ABOUT YOU GETTI NG A SEARCH WARRANT AND
6 THEN GOI NG TO SEARCH DR. MURRAY' S CAR.
7 A YES.
8 Q OH, I FORGOT TO ASK YOU THI S: DI D YOU SEE WHAT
9 YEAR THAT WAS?
10 A YOU KNOWWHAT? I FORGOT TO LOOK, BUT I CAN
11 FI ND I T RI GHT AWAY.
13 A 2005.
14 Q WHEN YOU CONDUCTED THE SEARCH OF THE VEHI CLE,
15 WHERE WAS THAT CONDUCTED?
16 A I T WAS AT - - OUR OFFI CI AL POLI CE GARAGE, WHI CH
17 I S CALLED QUI CKSI LVER TOWI NG.
18 Q AND THAT' S I N WEST LOS ANGELES?
19 A YES, SI R.
20 Q COULD YOU TELL US WHAT YOU FOUND I N THE
21 VEHI CLE?
22 A I FOUND THREE I TEMS THAT I DEEMED WERE GERMANE
23 TO THE CASE OF EVI DENTI ARY VALUE.
24 ONE WAS AN ENVELOPE THAT HAD HANDWRI TTEN NOTES
25 ON I T OF SEVERAL PHARMACI ES, ADDRESSES AND PHONE
26 NUMBERS.
27 ANOTHER WAS A BUSI NESS CARD FOR BRANDON RANDY
28 PHI LLI PS, AND I T HAD A CELL PHONE NUMBER ON THE REVERSE
866 299-5127
2408
1 SI DE.
2 AND THE LAST WAS A PAPER CONTRACT BETWEEN
3 DR. MURRAY AND A. E. G. WI TH DETAI LS FOR EMPLOYMENT.
4 Q OKAY. AS OF THI S TI ME NOW- - WE' RE TALKI NG
5 ABOUT THE 29TH OF J UNE; I S THAT RI GHT?
6 A MONDAY, THE 29TH.
7 Q OKAY. AS OF THI S TI ME, HAD YOU HAD A CHANCE TO
8 I NTERVI EWDR. MURRAY?
9 A YES.
10 Q OKAY. WI THOUT GOI NG I NTO THE SUBSTANCE OF
11 THAT, AFTER THAT I NTERVI EWI S WHEN YOU FI RST SEARCHED
12 THE CAR; I S THAT RI GHT?
13 A YES.
14 Q OKAY. AND WHEN YOU FOUND THESE I TEMS, DI D YOU
15 ATTEMPT TO I NTERVI EWMR. MURRAY AGAI N - - OR DR. MURRAY
16 AGAI N REGARDI NG THOSE I TEMS?
17 A YES.
18 Q WERE YOU SUCCESSFUL I N YOUR ATTEMPT TO THEN GO
19 QUESTI ON DR. MURRAY ABOUT THESE I TEMS THAT YOU FOUND I N
20 THE VEHI CLE?
21 A NO, I WAS NOT.
22 Q DI D HE REFUSE TO GI VE ANY MORE I NTERVI EWS?
23 A YES, HE DI D.
24 Q SO YOU WEREN' T ABLE TO ASK HI M ABOUT THESE
25 I TEMS?
27 Q LET' S LOOK AT THE FI RST ONE, 500- 326
28 ( I NDI CATI NG) . AND I F WE COULD BLOWTHAT UP, THAT I S
866 299-5127
2409
1 THE - - YOU WANT SOME WATER?
2 A I ' M FI NE. THANK YOU.
3 Q I T' S HOT I N HERE. ARE YOU HOT AT ALL?
4 A I AM HOT, BUT - -
5 Q I THOUGHT I T WAS J UST ME.
6 OKAY. WHY DI D YOU PHOTOGRAPH THE CARD OF
7 BRANDON RANDY K. PHI LLI PS, PRODUCER ( SI C) AND C. E. O. OF
8 A. E. G. LI VE?
9 A HAD TO DO WI TH - - HAD TO DO WI TH MI CHAEL
10 J ACKSON AND DR. MURRAY AND THE TOUR. HAD TO DO WI TH THE
11 CASE.
12 Q ALL RI GHT. FOUND THAT TO BE RELEVANT EVI DENCE?
13 A YES, SI R.
14 Q AND I MPORTANT I N YOUR I NVESTI GATI ON?
15 A YES, SI R.
16 Q THE BACKSI DE OF THE CARD HAD, YOU SAI D,
17 MR. PHI LLI PS' CELL PHONE NUMBER?
18 A I T HAD A PHONE NUMBER ON I T.
19 Q DI D YOU KNOWWHETHER OR NOT I T WAS HI S CELL
20 PHONE NUMBER?
21 A I BELI EVE I T WAS.
22 Q BUT YOU DI DN' T KNOWAT THAT TI ME WHOSE NUMBER
23 I T WAS?
24 A I DI D NOT.
25 Q BUT SUBSEQUENTLY YOU OBTAI NED PHONE RECORDS OF
26 DR. MURRAY, AND YOU WERE ABLE TO TRACK DOWN WHO THE
27 I NDI VI DUALS WERE THAT HE WAS CALLI NG?
28 A YES.
866 299-5127
2410
1 Q I S THAT PART OF HOWPOLI CE OFFI CERS DO THEI R
2 I NVESTI GATI ON?
3 A I T I S.
4 Q AND WE WON' T SHOWMR. PHI LLI PS' PRI VATE PHONE
5 NUMBER.
6 LET' S LOOK, THEN, AT EXHI BI T NO. 500- 324
8 AND WHAT I S THI S, SI R?
9 A THI S WAS THE ENVELOPE I FOUND I N THE CENTER
10 CONSOLE. PHARMACY NAMES AND PHONE NUMBERS WRI TTEN ON
11 I T.
12 Q OKAY. RI TE AI D, 24- HOUR PHARMACY, CVS. AND
13 THEN I DON' T KNOWWHAT THAT - - I T LOOKS LI KE DI RECTI ONS,
14 ACTUALLY. GI VES AN ADDRESS, 4119 SEPULVEDA BOULEVARD.
15 SEPULVEDA AND SAWTELLE, THEY ACTUALLY GO THE SAME WAY
16 BUT THEN GI VES YOU DI RECTI ONS ON HOWTO GET THERE, I
17 GUESS?
18 A YES. SEPULVEDA AND SAWTELLE MEET.
19 Q I N - -
20 A I N CULVER CI TY.
21 Q I N CULVER - - I T BENDS. YOU' RE RI GHT.
22 SO WAS I T YOUR UNDERSTANDI NG - - WAS THAT THE
23 SAME PHARMACY OR A DI FFERENT PHARMACY?
24 A AT THI S MOMENT I DON' T RECALL WHAT I T WAS FOR.
25 Q OKAY. FAI R ENOUGH.
26 AT 1808 WI LSHI RE, THAT' S A SANTA MONI CA
27 ADDRESS?
28 A I ' M NOT SURE WHAT CI TY I T' S I N, BUT WI TH THE
866 299-5127
2411
1 NUMBERS, I T' S MOST PROBABLY SANTA MONI CA.
2 Q WI TH A 310 PHONE NUMBER; 1808, THAT WOULD BE
3 18TH AND WI LSHI RE, WHI CH WOULD BE I N THE CI TY OF SANTA
4 MONI CA?
5 A YES.
6 Q AND WAS I T YOUR UNDERSTANDI NG, DR. MURRAY, THI S
7 FRI END HE WAS STAYI NG WI TH, MS. ALVAREZ, SHE WAS LI VI NG
8 I N SANTA MONI CA?
9 A YES.
10 Q OKAY.
11 NOW, I ' D LI KE TO LOOK - - ACTUALLY, I WANT TO
12 MARK - - I DON' T THI NK I ' M GOI NG TO SHOWI T RI GHT NOW.
13 AND I DON' T KNOWI F THI S I S SUBJ ECT TO THE COURT' S
14 RULI NGS OR NOT.
15 5- 96, WHI CH I S THE BACK OF MR. PHI LLI PS'
16 CARD - - DON' T SHOWI T - - WI TH THE PHONE NUMBER.
17 MR. PANI SH: CAN I J UST SHOWI T TO THE WI TNESS
18 AND HAVE HI M I DENTI FY I T, AND THEN WE' LL DEAL WI TH I T?
19 THE COURT: YES.
20
21 ( PLAI NTI FFS' EXHI BI T NO. 5- 96, BACK
22 OF MR. PHI LLI PS' CARD, WAS MARKED FOR
23 I DENTI FI CATI ON. )
24
25 Q BY MR. PANI SH: COULD YOU J UST LOOK AT THI S AND
26 TELL US, I S THAT THE BACK OF THE CARD THAT YOU
27 PHOTOGRAPHED AT THAT TI ME WI TH THE TELEPHONE NUMBER THAT
28 YOU LATER LEARNED WAS MR. PHI LLI PS' PRI VATE CELL PHONE
866 299-5127
2412
1 NUMBER?
2 A YES.
3 Q OKAY. J UST DON' T PUT THAT UP.
4 LET' S TAKE A LOOK NOWAT 500- 327 AND 328
6 OKAY. THI S - - I S THI S THE OTHER I TEM THAT YOU
7 FOUND I N HI S CAR?
8 A YES.
9 Q AND WHAT WAS THI S? J UST GENERALLY YOUR
10 UNDERSTANDI NG OF WHAT I T I S.
11 A I T' S A CONTRACT AGREEMENT.
12 Q DI D YOU READ I T?
13 A YES, I DI D.
14 Q YOU' RE NOT A LAWYER, ARE YOU?
15 A I AM NOT.
16 Q BUT YOU' RE ABLE TO TELL I T WAS A CONTRACT?
17 A YES.
18 Q WAS I T SI GNED BY ANYONE?
19 A THI S COPY WAS NOT SI GNED.
20 Q OKAY. DI D YOU SEE WHO THE PARTI ES TO THE
21 CONTRACT WERE LI STED AS?
22 A YES.
23 Q AND WHO WERE THEY?
24 A MR. J ACKSON, A. E. G. AND DR. MURRAY.
25 Q AND, ACTUALLY, I F YOU' D LOOK, LET' S LOOK AT THE
26 NEXT PAGE. I S I T J UST TWO? HOWMANY PAGES WERE THERE?
27 A I THI NK THERE' S THREE STAPLED PAGES.
28 Q CAN I HAVE THE NEXT PAGE?
866 299-5127
2413
1 A I DON' T BELI EVE WE TOOK PI CTURES OF EACH PAGE
2 I NDI VI DUALLY.
3 Q OH, OKAY. I T' S ACTUALLY SEVEN PAGES.
4 THE ONE CONTRACT YOU HAD WASN' T SI GNED BY
5 ANYONE; RI GHT?
6 A CORRECT.
7 Q OKAY. WHEN YOU SAWTHE CONTRACT AND A CARD OF
8 MR. PHI LLI PS, AS AN I NVESTI GATOR, I S THERE ANYTHI NG THAT
9 DREWYOUR ATTENTI ON TO THAT AND ANYWHERE YOU WANTED TO
10 CHANNEL YOUR I NVESTI GATI ON?
11 A YES.
12 Q WHAT WAS THAT?
13 A THI NKI NG AT THE MOMENT THAT THE CRI ME THAT MAY
14 HAVE OCCURRED WAS NEGLI GENCE, PARTLY DUE TO
15 I NCOMPETENCE, AFTER SEEI NG THE CONTRACT AND THE AMOUNTS
16 OF MONEY I NVOLVED, FOCUSI NG ON WHETHER FOR A MOTI VE, THE
17 FI NANCI AL ASPECT OF I T MAY HAVE BEEN I MPORTANT TO
18 DR. MURRAY. HI S WI LLI NGNESS TO, YOU KNOW, DI SREGARD HI S
19 HI PPOCRATI C OATH FOR FI NANCI AL GAI N.
20 Q HOWDI D YOU DETERMI NE THAT J UST LOOKI NG AT THE
21 CONTRACT?
22 A WELL, THE CONTRACT STATED HE WAS GOI NG TO GET
23 $150, 000 A MONTH. THAT' S A LOT OF MONEY FOR ANYBODY.
24 AND SEEI NG THE SCENE, AND TALKI NG TO HI M, THE
25 THI NGS THAT HE HAD DONE, REASONS WHY, YOU KNOW, THE WHO,
26 WHAT, WHEN, WHY AND HOW, WHY HE DI D I T.
27 Q RAI SED QUESTI ONS I N YOUR MI ND?
28 A YES, SI R.
866 299-5127
2414
1 Q OKAY. DON' T TELL US WHAT DR. MURRAY SAI D, BUT
2 YOU DI D CONDUCT AN I NTERVI EWWI TH HI M WI TH HI S LAWYER
3 PRESENT; I S THAT RI GHT?
4 A WI TH TWO LAWYERS PRESENT, YES.
5 Q TWO LAWYERS.
6 AND AT THAT TI ME, AFTER THAT I NTERVI EW, DI D YOU
7 GO AND TRY TO VERI FY WHAT HE HAD TOLD YOU?
8 A YES.
9 Q DI D YOU - - WERE YOU ABLE TO DETERMI NE WHETHER
10 WHAT HE TOLD YOU, AS AN I NVESTI GATOR, YOU BELI EVED HE
11 WAS BEI NG HONEST AND FORTHRI GHT, OR SOMETHI NG DI FFERENT?
12 A HE WAS NOT BEI NG HONEST AND FORTHRI GHT.
13 Q DO YOU THI NK THAT HE WAS MAKI NG UP A STORY TO
14 PROTECT HI MSELF?
15 A YES.
16 Q DI D YOU BELI EVE ANYTHI NG HE SAI D?
17 A YES.
18 Q MOST OF WHAT HE SAI D?
19 A NO.
20 Q DO YOU KNOWWHETHER HE HAD BEEN MEETI NG WI TH
21 A. E. G. REPRESENTATI VES AT THE HOSPI TAL, AND OTHER TI MES
22 PRI OR TO YOUR I NTERVI EWI NG HI M WI TH HI S TWO LAWYERS
23 PRESENT?
24 A I KNOWHE HAD MET WI TH SOME AT THE HOSPI TAL,
25 AND, YES, AT A DI FFERENT LOCATI ON PRI OR.
26 Q PRI OR TO YOUR I NTERVI EW?
27 A PRI OR TO MY I NTERVI EW, YES.
28 Q NOW, AS AN I NVESTI GATOR OF CRI MES AND DEATHS,
866 299-5127
2415
1 DO YOU LOOK TO SEE WHETHER OR NOT THERE CAN BE EVI DENCE
2 TO MAKE A CASE FOR WHY SOMEBODY WOULD DO SOMETHI NG?
3 A YES.
4 Q I S THAT SOMETI MES CALLED MOTI VE?
5 A YES.
6 Q AND I N THI S CASE DI D YOU THI NK THERE WOULD HAVE
7 POTENTI ALLY BEEN A MOTI VE AS TO WHY DR. MURRAY DI D WHAT
8 HE DI D, THAT YOU WANTED TO I NVESTI GATE?
9 A YES.
10 Q OKAY. AND WHAT WAS THAT?
11 A FOR HI S OWN FI NANCI AL GAI N.
12 Q OKAY. WELL, HOW, AS AN I NVESTI GATOR, WOULD YOU
13 GO ABOUT I NVESTI GATI NG WHETHER SOMEBODY WOULD DO
14 SOMETHI NG FOR FI NANCI AL GAI N?
15 A UHM, WHEN WE DO CASES, WE DO BACKGROUNDS ON THE
16 PEOPLE TO SEE I F THEY' RE I N FI NANCI AL TROUBLE, I F THEY
17 ARE GAMBLERS. THAT KI ND OF THI NG.
18 SO DOI NG A BACKGROUND ON HI M AND THEN RUNNI NG
19 HI M THROUGH POLI CE DATABASES AND PUBLI C DATABASES AND
20 CREDI T HI STORI ES TO SEE HOWTHEY ARE WI TH MONEY, I F
21 THEY' RE I N TROUBLE, OR I N DEEP WATER, THAT' S PART OF
22 WHAT WE DO.
23 Q AND THAT' S SOMETHI NG THAT YOU' RE TRAI NED TO DO
24 I N YOUR REGULAR DUTI ES AS A POLI CE OFFI CER I N CONDUCTI NG
25 I NVESTI GATI ONS?
26 A YES.
27 Q AND DI D YOU FOLLOWYOUR TRAI NI NG AND EXPERI ENCE
28 I N I NVESTI GATI NG ANY POTENTI AL FI NANCI AL MOTI VE THAT
866 299-5127
2416
1 DR. MURRAY HAD FOR HI S BEHAVI OR?
2 A YES.
3 Q OKAY. TELL US WHAT YOU DI D, AND HOWYOU WENT
4 ABOUT DOI NG I T.
5 A I WENT ONTO OUR POLI CE COMPUTERS AND THE PUBLI C
6 AND NATI ONAL DATABASES TO RUN HI M FOR J UDGMENTS AGAI NST
7 HI M, LI ENS AGAI NST HI M, BANKRUPTCI ES, CRI MI NAL HI STORY,
8 HI S APPLI CATI ONS FOR LOANS AND HI S APPLI CATI ONS FOR THE
9 MEDI CAL BOARD TO GET ALL THAT I NFORMATI ON.
10 Q SO I F YOU WANT TO SEE WHETHER SOMEBODY' S I N
11 FI NANCI AL TROUBLE, ONE WOULD BE TO SEE I F THERE ARE
12 FI NANCI AL J UDGMENTS OR LAWSUI TS THAT THEY' RE I NVOLVED
13 I N?
14 A YES, SI R.
15 Q ANOTHER WAY MI GHT BE TO LOOK AT WHETHER OR NOT
16 THEY HAD ANY LOANS THAT WERE OUTSTANDI NG?
17 A YES, SI R.
18 Q ANOTHER WAY COULD BE WHETHER THEY OWED CHI LD
19 SUPPORT?
20 A YES, SI R.
21 Q DI D YOU DETERMI NE HOWMANY CHI LDREN DR. MURRAY
22 HAD?
23 A I BELI EVE I T WAS EI GHT.
24 Q EI GHT. AND HOWMANY DI FFERENT I NDI VI DUALS DI D
25 HE HAVE THEM WI TH?
26 A I THI NK I T WAS SEVEN.
27 Q SEVEN.
28 SO YOU HAVE CHI LD SUPPORT YOU' RE LOOKI NG AT,
866 299-5127
2417
1 LI ENS, J UDGMENTS - - CREDI T CARDS, DO YOU LOOK AT THAT?
2 A CREDI T CARDS AND TAXES.
3 Q TAXES. HOME LOANS?
4 A YES, SI R.
5 Q UNPAI D BI LLS?
6 A STUDENT LOANS.
7 Q STUDENT LOANS. THI NGS LI KE THAT?
8 A YES, SI R.
9 Q DI D YOU FI ND ANYTHI NG THAT LED YOU TO BELI EVE
10 THAT DR. MURRAY WAS I N DESPERATE FI NANCI AL TROUBLE?
11 A YES, SI R.
12 Q HOWWOULD YOU CLASSI FY DR. MURRAY' S FI NANCI AL
13 CONDI TI ON AS OF MAY AND J UNE I N 2009?
14 A SEVERELY DI STRESSED. HI S HOME WAS ABOUT TO BE
15 TAKEN AWAY; HI S OFFI CE WAS BEI NG CLOSED. THE TOTAL WAS,
16 LI KE, 500 GRAND I N DEBT.
17 Q OKAY. WELL, LET' S LOOK AT THAT.
18 FI RST OF ALL, LI KE J UDGMENTS AND THI NGS LI KE
19 THAT, THEY' RE EASY TO FI ND; RI GHT?
20 A YES, SI R.
21 Q I MEAN, YOU DON' T HAVE TO BE A POLI CE OFFI CER
22 TO FI ND THAT OUT?
23 A PUBLI C RECORD.
24 Q PUBLI C RECORD.
25 I N FACT, I F YOU WANT TO RUN SOMEONE' S CREDI T,
26 YOU CAN DO THAT, TOO?
27 A AS A POLI CE OFFI CER, RI GHT.
28 Q I MEAN, YOU HAVE SERVI CES. ARE YOU FAMI LI AR
866 299-5127
2418
1 WI TH THOSE?
2 A YES.
3 Q SOMEONE J UST SI GNS AND YOU GO TO LI KE EQUI FAX?
4 A EXPERI AN, EQUI FAX, TRANSUNI ON.
5 Q AND YOU GET A QUI CK REPORT, AND I T WI LL PRI NT
6 OUT SOMEONE' S CREDI T HI STORY?
7 A YES, SI R.
8 Q DI D YOU DO THAT FOR DR. MURRAY?
9 A I DI D.
10 Q DI D THE POLI CE EXECUTE A SEARCH WARRANT ON
11 DR. MURRAY' S LAS VEGAS HOME?
12 A YES.
13 Q DI D YOU BECOME AWARE OF I NFORMATI ON THAT THE - -
14 I GUESS THAT' S THE LAS VEGAS POLI CE?
15 A I T WAS D. E. A. , OURSELVES AND LAS VEGAS METRO.
16 Q SO YOU HAVE TO HAVE THE LOCAL AGENCY I N LAS
17 VEGAS, WHAT THEY CALL METRO - - FOR THE LOCAL POLI CE
18 DEPARTMENT I N LAS VEGAS I T' S CALLED METRO?
19 A YES.
20 Q SO THEM AND D. E. A. AND L. A. P. D. WERE KI ND OF
21 BEI NG THERE, BUT YOU CAN' T BE PRI MARY BECAUSE I T' S OUT
22 OF YOUR J URI SDI CTI ON?
23 A WE COULD BE PRI MARY, BUT I T WAS THEI R HOUSE,
24 THEI R SHOP, SO THEY DI D I T FOR US.
25 Q KI ND OF A PROFESSI ONAL COURTESY?
26 A YES, SI R.
27 Q YOU DI DN' T WANT TO TRY TO RUN THE SHOWI N
28 LAS VEGAS?
866 299-5127
2419
1 A YES, SI R.
2 Q D. E. A. , WHAT I S THAT?
3 A DRUG ENFORCEMENT ADMI NI STRATI ON.
4 Q SO DI D YOU LEARN ANY I NFORMATI ON THAT YOU FELT
5 WAS PERTI NENT TO THE I NVESTI GATI ON FOR A FI NANCI AL
6 MOTI VE FOR DR. MURRAY' S CONDUCT FROM THAT SEARCH WARRANT
7 OF HI S HOME?
8 A YES.
9 Q WHAT DI D YOU LEARN?
10 A THERE WAS A NOTI CE UP THAT THE HOUSE WAS ON
11 LI EN OR BEI NG FORECLOSED ON. I THI NK I T WAS BEI NG
12 FORECLOSED ON.
13 Q AND DI D YOU FOLLOWTHAT UP?
14 A YES, SI R.
15 Q DI D YOU GET DOCUMENTS - - DI D YOU OBTAI N
16 DOCUMENTS TO DETERMI NE WHETHER OR NOT I N FACT THAT WAS
17 THE CASE?
18 A YES.
19 Q ALL RI GHT. I ' M GOI NG TO SHOWYOU EXHI BI T
20 5- 1344 THROUGH 1425 ( I NDI CATI NG) . LET ME J UST SHOWYOU
21 THE FI RST PAGE J UST SO YOU CAN I DENTI FY THAT.
22 OKAY. I S THAT FROM A TI TLE COMPANY?
23 A YES, I T I S.
24 Q ALL RI GHT. I S THAT DOCUMENTS THAT YOU OBTAI NED
25 I N THE REGULAR COURSE OF BUSI NESS AS A RESULT OF SEARCH
26 WARRANTS THAT WERE SERVED?
27 A I BELI EVE THAT WAS A GRAND J URY SUBPOENA.
28 Q OKAY. LET' S GO TO PAGE 3 OF THAT EXHI BI T, ALSO
866 299-5127
2420
1 5- 1336 ( I NDI CATI NG) .
2 AND DOES THAT I NDI CATE THE AMOUNT OF THE LOAN
3 ON DR. MURRAY' S HOME?
4 A YES.
5 Q AND HOWMUCH WAS THAT?
6 A $1, 644, 644. 25.
7 Q LET' S TURN TO PAGE 1338 OF EXHI BI T 5. OH, I ' M
8 SORRY. WHAT' S THE DATE? I ' M SORRY. GO BACK.
9 THE DATE THAT I T WAS DUE, THE LOAN?
10 A J ULY 23RD.
11 Q J ULY 23RD, 2009, I S WHEN I T WAS ALL OWED?
12 A YES, SI R.
13 Q SO THAT' S WI THI N A MONTH OF THE DEATH OF
14 MR. J ACKSON?
15 A YES, SI R.
16 Q LET' S GO TO PAGE 1338 ( I NDI CATI NG) .
17 DI D YOU DETERMI NE WHETHER THERE WERE ANY TAX
18 LI ENS THAT DR. MURRAY HADN' T PAI D ON HI S HOME?
19 A YES, SI R.
20 Q AND WHAT DI D YOU DETERMI NE I N THAT REGARD?
21 A I T WAS ABOUT 11 GRAND I N LI ENS.
22 Q A GRAND, A THOUSAND?
23 A 11, 000. EXCUSE ME.
24 Q AND WAS THAT PERTI NENT AS PART OF YOUR
25 I NVESTI GATI ON?
26 A YES. AS TO MOTI VE.
27 Q ALL RI GHT.
28 LET' S, THEN, TURN TO EXHI BI T 5- 1447 AND 1448
866 299-5127
2421
2 MR. PANI SH: PLEASE SHOWTHAT TO THE WI TNESS.
3 Q BY MR. PANI SH: AGAI N, ANOTHER DOCUMENT FI LED,
4 PUBLI C RECORD, I N THE CI TY OF LAS VEGAS?
5 YOU SEEN THAT BEFORE?
6 A YES, SI R.
7 Q ALL RI GHT. AND THI S I S WHAT?
8 A THI S I S STATI NG THAT HE' S I N ARREARS, A LI TTLE
9 BI T OVER $15, 000, AS OF J ANUARY OF 2009.
10 Q SO AS OF J ANUARY OF 2009, HE HADN' T BEEN PAYI NG
11 HI S MORTGAGE?
12 A YES, SI R.
13 Q AND THE MORTGAGE WAS APPROXI MATELY 3, 000 OR
14 SOMETHI NG A MONTH?
15 A I DON' T RECALL HOWMUCH HI S MORTGAGE WAS PER
16 MONTH.
17 Q BUT I T HAD RUN UP - - BUT I T HADN' T BEEN PAI D
18 SI NCE J ANUARY 2009; I S THAT RI GHT?
19 A I THI NK I T WAS - - ACTUALLY, I THI NK I T WAS
20 ABOUT - - HADN' T BEEN PAI D FOR A FEWMONTHS BEFORE
21 J ANUARY.
22 Q BEFORE J ANUARY 2009.
23 OKAY. LET' S LOOK AT THE NEXT ONE, 5- 1450
24 THROUGH 55 ( I NDI CATI NG) .
25 LET' S LOOK AT THE FI RST PAGE. THI S I S WHAT' S
26 CALLED A " TRUSTEE' S SALE I NSTRUCTI ONS AND DECLARATI ON OF
27 DEFAULT. "
28 I N THE MI DDLE OF THE PAGE, I T SAYS, " UNPAI D
866 299-5127
2422
1 BALANCE, 1, 644, 000" AND CHANGE.
2 DELI NQUENT PAYMENTS, PRI NCI PAL, I NTEREST, I N
3 THE AMOUNT OF 15, 165?
4 AND THEN I F WE GO DOWN, I T SAYS:
5 " WE HEREBY DECLARE A DEFAULT
6 UNDER THE TERMS OF THE ABOVE NOTE AND
7 DEED OF TRUST AS FOLLOWS. "
8 OKAY. THI S ACTUALLY SAYS HE ALSO HAS LATE
9 CHARGES ACCRUI NG, LATE CHARGES OF 3, 477. 95; I S THAT
10 RI GHT?
11 A PER MONTH, YES, SI R.
12 Q ALL RI GHT. SO THI S WAS SHOWI NG THAT THEY WERE
13 I NTENDI NG TO SELL, I GUESS, I N A FORECLOSURE STATEMENT,
14 DR. MURRAY' S HOME I N LAS VEGAS?
15 MR. PUTNAM: OBJ ECTI ON. LACKS FOUNDATI ON, YOUR
16 HONOR.
17 Q BY MR. PANI SH: WHY DON' T WE LOOK AT THE TOP OF
18 THE DOCUMENT AND SEE WHAT I T SAYS.
19 WHAT WAS YOUR UNDERSTANDI NG OF WHAT I T SAI D ON
20 THE TOP OF THE DOCUMENT?
21 A SALE I NSTRUCTI ONS AND A DECLARATI ON OF DEFAULT.
22 Q DOES THAT MEAN SOMEBODY I S I N GOOD FI NANCI AL
23 STANDI NG OR BAD FI NANCI AL STANDI NG?
24 A BAD.
25 MR. PUTNAM: LACKS FOUNDATI ON.
27 Q BY MR. PANI SH: WELL, AS A POLI CE OFFI CER,
28 YOU' VE I NVESTI GATED HUNDREDS OF CASES FI NANCI ALLY TO
866 299-5127
2423
1 FI ND FI NANCI AL MOTI VE?
2 A YES.
3 Q AND HAVE YOU LEARNED WHAT A TRUSTEE' S SALE - -
4 WHEN SOMEBODY I S NOT PAYI NG THEI R MORTGAGE, WHETHER
5 THAT' S I NDI CATI VE OF WHETHER THEY' RE I N GOOD OR BAD
6 FI NANCI AL CONDI TI ON?
7 MR. PUTNAM: SAME OBJ ECTI ON, YOUR HONOR.
9 MR. PANI SH: WHAT' S THE OBJ ECTI ON?
10 MR. PUTNAM: OBJ ECTI ON I S HE LACKS FOUNDATI ON
11 TO SAY THI S.
12 HE CAN SAY WHAT THE DOCUMENT SAYS, BUT HE LACKS
13 FOUNDATI ON WHETHER HE KNOWS OR NOT WHETHER THEY WERE
14 ACTUALLY GOI NG TO SELL I T OR WHETHER OR NOT THERE WAS
15 FI NANCI AL PROBLEMS.
16 MR. PANI SH: I S THAT A GROUND FOR AN OBJ ECTI ON?
17 MR. PUTNAM: LACKS FOUNDATI ON, YOUR HONOR.
20 Q BY MR. PANI SH: I S THERE ANY QUESTI ON I N YOUR
21 MI ND THAT DR. MURRAY WAS I N DI RE FI NANCI AL STRAI TS?
22 A NO. NO, THERE' S NO QUESTI ON.
23 Q ALL RI GHT. LET' S GO TO THE NEXT ONE, 5- 1456
25 THI S I S A LETTER DATED J ULY 27TH TO DR. MURRAY
26 SAYI NG:
27 " ENCLOSED I S A COPY OF A
28 NOTI CE OF DEFAULT, WHI CH WAS RECORDED
866 299-5127
2424
1 PURSUANT TO THE REQUEST OF THE
2 BENEFI CI ARI ES OF THE NOTE FOR WHI CH
3 DEED OF TRUST ENCUMBERI NG THE
4 PROPERTY LOCATED AT THAT ADDRESS WAS
5 SECURI TY. "
6 AND THAT WAS A LETTER SENT TO DR. MURRAY
7 NOTI FYI NG HI M THAT HE WAS I N THI S PROBLEM?
8 A YES.
9 Q OKAY. LET' S LOOK AT THE NEXT ONE,
10 EXHI BI T 5- 1390 ( I NDI CATI NG) .
11 THESE ARE ALL DOCUMENTS YOU OBTAI NED AS A
12 RESULT OF A GRAND J URY SUBPOENA?
13 A YES.
14 Q OKAY. THI S I S A DOCUMENT THAT' S RECORDED,
15 AGAI N, WI TH THE CLARK COUNTY, CI TY OF LAS VEGAS, PUBLI C
16 RECORD; CORRECT?
17 A YES, SI R.
18 Q I T' S ACTUALLY, ELECTRONI CALLY, YOU CAN GO ON
19 THE I NTERNET AND FI ND THI S?
20 A DEED OF TRUST? YES, SI R.
21 Q AND THAT' S THE DEED OF TRUST FOR DR. MURRAY' S
22 PROPERTY; RI GHT?
23 A YES.
24 Q AND I T TALKS ABOUT THE PRI CE. I F WE GO TO
25 PAGE 2, HE PAI D 1 MI LLI ON - - OR THAT WAS THE SELLI NG
26 PRI CE, 1, 656, 000?
27 A CORRECT.
28 Q LET' S GO TO THE NEXT ONE, EXHI BI T 5 - - EXCUSE
866 299-5127
2425
1 ME - - EXHI BI T 462- 8459, A 1- PAGE DOCUMENT ( I NDI CATI NG) .
2 OR, ACTUALLY, DON' T SHOWTHAT.
3 DI D YOU DO AN I NVESTI GATI ON I N THE CI TY OF
4 LAS VEGAS TO DETERMI NE WHETHER OR NOT DR. MURRAY' S LOAN
5 WAS I N DEFAULT, AND THERE WAS A SALE THAT WAS GOI NG TO
6 BE SET UP?
7 A FOR HI S HOME PROPERTY?
8 Q YES.
9 A YES.
10 Q AND DI D YOU CONDUCT THAT BY I NTERVI EWI NG
11 ATTORNEYS AND PEOPLE I N LAS VEGAS?
12 A AND - - YES.
13 Q OKAY. LET' S GO TO THE NEXT ONE, 5- 1338
15 THI S I S ANOTHER DOCUMENT. PUT THAT UP.
16 I T' S ENTI TLED " TRUSTEE' S SALE. " I NDI CATES THAT
17 DR. MURRAY HAD OUTSTANDI NG TAX LI ENS; I S THAT CORRECT?
18 A YES.
19 Q OKAY. LET' S GO TO THE NEXT ONE, 5- 1343
21 AGAI N, THI S I S ALL LI ENS AGAI NST DR. MURRAY' S
22 HOME; CORRECT?
23 A YES.
24 Q OKAY. AND WHAT DOES THI S I NDI CATE, ALL PUBLI C
25 RECORDS, THAT HE HAD MORE LI ENS - - WHAT I S A LI EN? DO
26 YOU KNOW?
27 A A CLAI M AGAI NST HI M FOR MONEY.
28 Q OKAY. SO THERE WERE CLAI MS BEI NG MADE HERE BY
866 299-5127
2426
1 THE DEPARTMENT OF CHI LD SUPPORT SERVI CES, COUNTY OF
2 SANTA CLARA. THAT' S I N CALI FORNI A?
3 A YES.
4 Q DEPARTMENT OF CHI LD SERVI CES, SANTA CLARA. AND
5 ANOTHER THAT' S A J UDGMENT AGAI NST DR. MURRAY. THESE
6 WERE ALL ADDI TI ONAL LI ENS THAT WERE HELD AGAI NST HI S
7 PROPERTY?
8 A YES.
9 Q ALL RI GHT. AND THESE WOULD BE FI LED WI TH THE
10 COUNTY RECORDER?
11 A YES.
12 Q OKAY. LET' S GO TO THE NEXT ONE.
13 THI S I S ANOTHER CHI LD - - THI S I S - - I ' M SORRY.
14 5- 14, 15 AND 1516 ( I NDI CATI NG) . AGAI N, YOU CONTI NUED TO
15 FI ND CHI LD SUPPORT I SSUES WI TH DR. MURRAY?
16 A YES.
17 Q DI D YOU FI ND ANOTHER J UDGMENT HERE FOR THE
18 COUNTY - - OR CLARK COUNTY, DI STRI CT COURT, FOR ANOTHER
19 CHI LD. DR. MURRAY OWED ANOTHER $10, 000 HERE?
20 A YES, I DI D.
21 Q LET' S GO TO THE NEXT ONE, 5- 1360 ( I NDI CATI NG) .
22 ANOTHER ORDER, ATTORNEY' S FEES AND CHI LD
23 SUPPORT I N SAN DI EGO THAT DR. MURRAY OWED. THAT' S
24 5- 1360; CORRECT?
25 A YES.
26 Q LET' S GO TO THE NEXT ONE. THI S I S 13 - - EXCUSE
27 ME - - 5- 1379 THROUGH 1383 ( I NDI CATI NG) .
28 THI S I S, AGAI N, ANOTHER J UDGMENT AND FI NDI NGS
866 299-5127
2427
1 I N THE CHI LD COURT REGARDI NG MONI ES THAT DR. MURRAY
2 OWED?
3 A YES.
4 Q AND J UDGMENT CREDI TOR, THI S I S SOMEONE HE OWED
5 MONEY TO?
6 A YES.
7 Q LET' S GO TO THE NEXT ONE, 462- 8181 AND 8182
9 THI S I S ANOTHER PUBLI CLY- FI LED NOTI CE OF LI EN,
10 CLARK COUNTY. THAT' S LAS VEGAS; I S THAT RI GHT?
11 A I T I S.
12 Q FAMI LY SUPPORT DI VI SI ON FROM SAN J OSE I S MAKI NG
13 A CLAI M I N LAS VEGAS.
14 YOU SEE THAT?
15 A I DO.
16 Q AND THAT' S FOR ANOTHER 22, 000 THAT HE OWED?
17 A YES.
18 Q GO TO THE NEXT ONE ( I NDI CATI NG) . THI S I S
19 ANOTHER J UDGMENT FI LED I N LAS VEGAS. THI S I S THE FI RST
20 PAGE. THI S I S A DEFAULT J UDGMENT AGAI NST DR. MURRAY
21 WHERE HE OWES MORE MONEY.
22 I ' M SORRY. I HAVE TO SAY THE NUMBER. 5- 1371
23 TO 1373. RI GHT?
24 A YES.
25 Q OKAY. NEXT ONE, 5- 1461 AND 1462 ( I NDI CATI NG) .
26 THI S I S AN ASSESSOR' S VALUE OF DR. MURRAY' S
27 PROPERTY; I S THAT RI GHT?
28 A YES.
866 299-5127
2428
1 Q I F THI S SHOWS, I F WE GO TO PAGE 2, 5- 1462, THAT
2 THE TAXABLE VALUE THAT HE WAS PAYI NG TAXES ON WAS
3 1, 568, 069?
4 MR. PUTNAM: YOUR HONOR - - I F I MAY, YOUR
5 HONOR, I ' M GOI NG TO OBJ ECT. MR. PANI SH I S TESTI FYI NG
6 FOR THE WI TNESS. I F THE WI TNESS COULD TESTI FY WHAT HE
7 UNDERSTANDS THI S TO BE, I ' D APPRECI ATE I T.
8 THE COURT: THAT' S OKAY. YOU CAN LEAD HI M ON
9 THI S.
10 MR. PANI SH: I MOVE ALL THESE I NTO EVI DENCE.
11 MR. PUTNAM: YOUR HONOR, I T LACKS FOUNDATI ON.
12 NO FOUNDATI ON HAS BEEN SHOWN.
13 THE COURT: I WI LL CONDI TI ONALLY ADMI T THEM.
14 MR. PUTNAM: THAT' S FI NE, YOUR HONOR.
16 Q BY MR. PANI SH: OKAY. WERE THESE BUSI NESS
17 RECORDS THAT WERE OBTAI NED BY YOU BY A GRAND J URY
18 SUBPOENA FOR CUSTODI AN OF RECORDS?
19 A SOME WERE BUSI NESS, SOME WERE COURT.
20 Q COURT RECORDS, OFFI CI AL DOCUMENTS FI LED I N A
21 COURT OF LAW?
22 A YES, SI R.
23 Q THAT ANYONE THAT WENT TO THE OFFI CE OF THE
24 COURT, FOR PAYI NG A FEE, COULD OBTAI N THOSE DOCUMENTS?
25 A YES, SI R.
26 Q OKAY. TELL US WHAT I T SAYS. TAXABLE VALUE - -
27 THAT WAS THE VALUE THAT DR. MURRAY WAS PAYI NG TAX ON; I S
28 THAT RI GHT?
866 299-5127
2429
1 MR. PUTNAM: AGAI N, YOUR HONOR, LACKS
2 FOUNDATI ON.
3 THE COURT: WHY DON' T YOU TELL US WHAT THE
4 SI GNI FI CANCES ARE OF THESE DOCUMENTS TO YOUR
5 I NVESTI GATI ON?
7 THE COURT: THAT WOULD BE A BETTER WAY TO DO
8 I T.
9 Q BY MR. PANI SH: LET' S START WI TH THI S ONE
11 THE COURT: OVERRULED WI TH THAT QUESTI ON.
12 THE WI TNESS: I N J UDGI NG DR. MURRAY' S FI NANCI AL
13 STATUS, NOTI CI NG THAT THE VALUE OF HI S HOUSE WENT DOWN
14 ABOUT $500, 000, J UST THI NKI NG OF HI S MONEY I SSUES AND
15 HI S MONEY PROBLEMS.
16 THE COURT: THAT' S WHAT I T I NDI CATED TO YOU - -
18 THE COURT: - - I N TERMS OF YOUR I NVESTI GATI ON?
20 THE COURT: OKAY.
21 Q BY MR. PANI SH: AND J UST SHOWUS ON THE
22 DOCUMENT HOWYOU COME TO THAT CONCLUSI ON THAT HE WAS
23 500, 000 UNDERWATER, SO TO SPEAK, ON HI S HOME?
24 THE COURT: GO AHEAD.
25 THE WI TNESS: THE TAXABLE AT THE TI ME OF SALE,
26 AND THE NEWTAXABLE AMOUNT. SO 15, 680 - - I ' M SORRY.
27 LET ME LOOK AT I T ON MY SCREEN. 1, 568, 068, AND
28 1, 081, 203.
866 299-5127
2430
1 Q BY MR. PANI SH: LET' S GO BACK TO THE FI RST
2 PAGE, 5- 1461, AND I T SAYS, " REAL PROPERTY ASSESSED
3 VALUE. " I F WE COULD FOCUS I N ON THAT.
4 AND I F I T' S POSSI BLE TO LI NE UP THE TWO PAGES
5 WI TH THE FI SCAL YEAR AND THE VALUE. YOU SEE WHERE I T
6 SAYS REAL PROPERTY, ASSESSED PROPERTY, FI SCAL YEAR?
7 A I DO.
8 Q OKAY. OKAY. SO THE ONE ON THE LEFT, WHAT YEAR
9 I S THAT?
10 A 2008/ 2009.
11 Q AND THE ONE ON THE RI GHT, WHAT YEAR I S THAT?
12 A 2009/ 2010.
13 Q SO WHAT WAS - - BASED ON YOUR REVI EWOF THESE
14 DOCUMENTS FROM THE ASSESSOR, OFFI CI AL GOVERNMENT
15 DOCUMENTS FROM THE STATE OF NEVADA, CLARK COUNTY, CI TY
16 OF LOS ANGELES - - CI TY OF LAS VEGAS, WHAT WAS THE
17 ASSESSED VALUE FOR TAX PURPOSES OF DR. MURRAY' S PROPERTY
18 AS OF THE FI SCAL YEAR 2008/ 2009?
19 A $1, 568, 068.
20 Q WHAT WAS THE ASSESSED VALUE OF DR. MURRAY' S
21 PROPERTY ON THE FI SCAL YEAR 2009/ 2010?
22 A $1, 081, 203.
23 Q WAS THERE A DROP I N THE ASSESSED VALUE OF THE
24 PROPERTY THAT HE HAD A LOAN FOR 1. 6 MI LLI ON ON?
25 A YES, THERE WAS.
26 Q AND WHAT WAS THE DROP?
27 A HALF A MI LLI ON DOLLARS, ABOUT.
28 Q APPROXI MATELY?
866 299-5127
2431
1 A YES, SI R.
2 Q AND THE FACT THAT DR. MURRAY HAD A LOAN OF OVER
3 1. 6 MI LLI ON, AN ASSESSED VALUE AT THE TI ME OF
4 MR. J ACKSON' S DEATH OF 1, 081, 000, WAS THAT SI GNI FI CANT
5 TO YOU I N YOUR I NVESTI GATI ON OF DR. MURRAY' S FI NANCI AL
6 CONDI TI ON AND MOTI VE?
7 A YES.
8 Q TELL US WHY.
9 A LEADI NG ME TO OPI NE THAT HE MAY, FOR THI S EASY
10 MONEY, THE $150, 000 A MONTH, HE MAY BREAK THE RULES,
11 BEND THE RULES, DO WHATEVER HE NEEDED TO DO TO GET PAI D.
12 MI GHT SOLVE HI S MONEY PROBLEMS.
13 Q LET' S LOOK AT THE NEXT EXHI BI T ( I NDI CATI NG) .
14 DI D YOU - - I ' M GOI NG TO SHOWI T TO YOU. THI S
15 I S EXHI BI T 462- - - DON' T PUT I T UP YET - - - 8460.
16 DI D YOU CONDUCT AN I NVESTI GATI ON TO SEE WHETHER
17 DR. MURRAY HAD ANY LAWSUI TS FI LED AND PENDI NG AGAI NST
18 HI M I N THE CI TY OF LAS VEGAS AT THI S TI ME?
19 A YES.
20 Q WHAT DI D YOU DETERMI NE I N THAT REGARD?
21 A THERE WAS A COMPANY THAT DI D BUSI NESS FOR - -
22 BUSI NESS WI TH HI S GLOBAL CARDI OVASCULAR ASSOCI ATES, HI S
23 MEDI CAL BUSI NESS I N LAS VEGAS, AND THEY WERE SUI NG
24 HI M - - I ' M NOT SURE - - FOR THOUSANDS OF DOLLARS FOR WORK
25 THEY HAD DONE, AND HE HADN' T PAI D I T.
26 Q WAS I T OVER 100, 000?
27 A YES.
28 Q LET' S GO TO THE NEXT DOCUMENT. THI S I S A - -
866 299-5127
2432
1 LET' S SHOWTHI S. 462- 482 ( I NDI CATI NG) . THI S I S A
2 6- PAGE DOCUMENT FI LED WI TH THE COURT. SHOWYOU THAT,
3 SI R. THI S I S I N THE COUNTY OF SAN DI EGO, OFFI CI AL COURT
4 DOCUMENT.
5 I F WE COULD PUT THAT UP.
6 THI S GOES BACK TO THE YEAR J ULY 17TH, 2005.
7 CAN WE PUT I T UP, PLEASE? OKAY.
8 AND DI D DR. MURRAY FI LE A DOCUMENT UNDER OATH
9 WHERE HE STATED HOWMUCH - - OR, I DON' T KNOW, I TAKE
10 THAT BACK.
11 HI S LAWYER FI LED THI S DOCUMENT, WHERE
12 DR. MURRAY STATED HOWMUCH HI S MONTHLY I NCOME WAS AT
13 THI S TI ME?
14 A YES.
15 Q AND WHAT WAS THAT?
16 A I T WAS NEGATI VE $2, 706 AND SOME CHANGE.
17 Q AND DI D DR. MURRAY I NDI CATE THAT HE HAD A
18 SI GNI FI CANT - - I F WE TURN TO PAGE 4886 OF THAT
19 EXHI BI T - - SI GNI FI CANT MONEY OWED FOR OTHER LOANS?
20 A YES, HE DI D.
21 Q LET' S TAKE A LOOK AT THAT. YOU CAN PUT THAT UP
23 THESE ARE STUDENT LOANS AND DEBTS OF
24 DR. MURRAY?
25 A YES.
26 Q LI STI NG OUT 69, 000, 26, 000, 3, 500, 16, 000,
27 7, 900 AND SOME OTHER DEBTS THAT HE OWED. AND, ACTUALLY,
28 HE GOT A LEVY AGAI NST HI M FROM THE FRANCHI SE TAX BOARD.
866 299-5127
2433
1 WHAT' S A LEVY?
2 A THAT, I DON' T KNOW.
3 Q OKAY.
4 THE COURT: A FEWMORE MI NUTES TO 4: 00. I WANT
5 TO ADJ OURN AT 4: 00 SO WE CAN TALK ABOUT THI NGS BETWEEN
6 4: 00 OR 4: 30. SO WE' LL RESUME TOMORROW.
7 MR. PANI SH: I WON' T OBJ ECT I F WE STOP NOW.
8 THE COURT: WHY DON' T WE STOP NOW?
9 I ' M GOI NG TO HAVE YOU COME BACK TOMORROWAT
10 10: 00, BECAUSE I WANT TO CONTI NUE; HOWEVER, ONE OF OUR
11 J URORS HAS A FUNERAL THEY HAVE TO GO TO, SO WHAT WE' RE
12 GOI NG TO DO I S GO FROM 10: 00 TO 11: 00, AND THEN I ' M
13 GOI NG TO LET YOU GO. I KNOWI T' S ONLY AN HOUR, BUT
14 PERHAPS WE CAN FI NI SH WI TH THI S WI TNESS I N THAT HOUR.
15 SO SEE YOU AT 10: 00. SORRY I T' S A SHORT DAY.
16
17 ( THE J URY EXI TED THE COURTROOM AT 3: 59 P. M. )
18
19 THE COURT: OKAY. YOU NEED TO ADDRESS THE
20 COURT?
21 MS. BI NA: NO, YOUR HONOR. J UST WORKI NG ON
22 PROTOCOL TO GET PAPER COPI ES.
23 MR. PUTNAM: I WON' T OBJ ECT TO FOUNDATI ON I F I
24 KNOWWHAT I T I S. I T WOULD MAKE I T EASI ER I F WE HAVE
25 THEM.
26 MR. PANI SH: ALL RI GHT. WELL, I - - I HAD ASKED
27 FOR PAPER COPI ES, AND THEY OBJ ECTED, AND THE COURT SAI D,
28 NO, ELECTRONI C I S FI NE. I ' LL BRI NG PAPER COPI ES TO GI VE
866 299-5127
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1 TO THEM.
2 MS. BI NA: YEAH. AND I THOUGHT - -
3 MR. PANI SH: BUT THEY HAVE ALL OF THESE
4 EXHI BI TS.
5 THI S I S WHY I RAI SED THI S I SSUE, BECAUSE I T' S
6 HARD WHEN YOU' RE I N A TRI AL, AND COUNSEL HAS PUT I N THE
7 PAPER EXHI BI TS TO LOOK ON YOUR COMPUTER.
8 AND I RAI SED THAT WI TH THE COURT, AND I WANTED
9 PAPER, BECAUSE I ' VE BEEN DOWN THI S ROAD, AND THE COURT
10 DI DN' T FEEL I NEEDED I T, AND THEY OBJ ECTED TO I T. NOW
11 THEY WANT PAPER COPI ES, WHI CH I WANTED TO GI VE THEM ALL
12 ALONG, AS LONG AS THEY GAVE THEM TO ME.
13 MS. BI NA: YOUR HONOR, I THI NK THERE' S A
14 MI SUNDERSTANDI NG HERE.
15 AT THE FI NAL STATUS CONFERENCE, YOUR HONOR
16 ORDERED THAT THE PARTI ES EXCHANGE THE DOCUMENTS, AND WE
17 DECI DED TO EXCHANGE THE ENTI RE EXHI BI T LI ST
18 ELECTRONI CALLY; HOWEVER, MY UNDERSTANDI NG WAS ALWAYS
19 THAT I N ADDI TI ON TO THE BI NDERS TO BE GI VEN TO THE COURT
20 BEFORE USE I N DI RECT EXAMI NATI ON, WE WOULD A HAND PAPER
21 COPY TO OPPOSI NG COUNSEL, THE DOCUMENTS WE WERE USI NG
22 WI TH THE WI TNESS THEN AND THERE, AND THEY WOULD DO THE
23 SAME.
24 MR. PUTNAM: AS LONG AS EVERYONE AGREES.
25 MR. PANI SH: THAT' S NOT WHAT I T SAYS I N
26 MS. STRONG' S PROTOCOL THAT WE SPENT ALL THI S TI ME ON.
27 SHE DI DN' T SAY THAT. I T WAS COMPLETELY DI FFERENT.
28 MS. BI NA: AGAI N, MAYBE I T' S A
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1 MI SUNDERSTANDI NG. MY UNDERSTANDI NG WAS ALWAYS THAT WE
2 HAVE - - OBVI OUSLY HAVE PAPER COPI ES - -
3 MR. PANI SH: YOU GUYS WROTE I T. I ASKED FOR
4 THE PAPER. REMEMBER, EVERY TI ME I ASKED FOR SOMETHI NG,
5 THEY OBJ ECT, AND THEN WHEN WE GET I NTO THE REAL PROCESS
6 OF HOWTHE TRI AL GOES, NOWTHEY SAY THEY WANT I T. BUT
7 EVERYTHI NG I WANT, THEY OBJ ECT TO.
8 I ' M HAPPY TO GI VE THEM EVERY EXHI BI T I N THE
9 WHOLE TRI AL. I WANTED TO GI VE THEM I N PAPER AS LONG AS
10 I GOT THE SAME THI NG. I HAVE NO PROBLEM.
11 THAT WAY - - NORMALLY MY EXPERI ENCE I S, I N A
12 TRI AL, THERE ARE EXHI BI T BOOKS. AND WHEN COUNSEL REFERS
13 TO AN EXHI BI T, YOU OPEN THE BOOK, AND THERE' S THE
14 EXHI BI T. THAT' S THE WAY I T USUALLY WORKS.
15 MS. BI NA: AGAI N, YOUR HONOR, I F YOU' LL RECALL,
16 MR. PANI SH WASN' T HERE AT THE FI NAL STATUS CONFERENCE.
17 THI S WAS ACTUALLY DI SCUSSED I N SOME DETAI L.
18 AND THE I DEA WAS THAT WE WOULD NOT NECESSARI LY
19 HAVE AN ENTI RE BI NDER, BUT AS AN EXHI BI T WAS USED, WE
20 WOULD HAND I T OVER, AND THE COURT WOULD HAVE A BI NDER OF
21 ALL OF THE EXHI BI TS AT THE BEGI NNI NG OF THE DAY. AND I
22 THI NK THAT SHOULD WORK J UST FI NE.
23 THE COURT: THAT' S FI NE.
24 MR. PANI SH: I ' LL WORK I T OUT WI TH THEM.
25 THE COURT: SO WHATEVER DOCUMENTS YOU' RE USI NG
26 WI TH A PARTI CULAR WI TNESS, WE WOULD NOT ONLY GI VE THE
27 COURT A COPY BUT GI VE THE OTHER SI DE. I THI NK THAT' S
28 REASONABLE.
866 299-5127
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1 ALSO, REGARDI NG THE OBJ ECTI ONS TO THE
2 DOCUMENTS, MOST OF THESE ARE COURT RECORDS OR PUBLI C
3 RECORDS, SO, I MEAN, THERE REALLY I SN' T A REASON TO - -
4 MR. PANI SH: GRAND J URY SUBPOENA.
5 MS. BI NA: YOUR HONOR, J UST BECAUSE THEY WERE
6 PRODUCED I N RESPONSE TO A GRAND J URY SUBPOENA DOESN' T
7 MEAN THEY' RE ALL PUBLI C RECORDS. ONE OF THESE WAS OVER
8 100 PAGES LONG.
9 I F PLAI NTI FFS' COUNSEL WOULD LI KE TO LAY A
10 FOUNDATI ON THAT - - HE - - AT SOME POI NT MR. PANI SH WAS
11 TESTI FYI NG, SAYI NG THI S WAS PUBLI C RECORD. WE NEED TO
12 HEAR THAT FROM THE WI TNESS, OR HAVE I T J UDI CI ALLY
13 NOTI CED. AND SOME OF THESE ARE PUBLI C RECORDS, AND SOME
14 AREN' T. AND WI THOUT THE FOUNDATI ON BEI NG ADEQUATELY
15 LAI D, I T' S DI FFI CULT.
16 THE COURT: SOME OF THEM ARE PUBLI C RECORDS.
17 YOU CAN TELL BY LOOKI NG AT I T.
18 MR. PUTNAM: WE AGREE.
19 THE COURT: SOME MAY BE NOT QUI TE AS CLEAR.
20 MS. BI NA: WHEN WE GET THE PAPER COPI ES, THAT
21 MI GHT BE A QUI CK WAY TO RESOLVE.
22 THE COURT: THAT WAY WE CAN AVOI D THOSE TYPES
23 OF OBJ ECTI ONS.
24 MR. PUTNAM: WE AGREE.
25 THE COURT: SO GOOD I DEA TO EXCHANGE THE
26 DOCUMENTS AHEAD OF TI ME SO WE DON' T HAVE THAT PROBLEM.
28 THE COURT: SO TOMORROW, I GUESS, CAN WE - - OR
866 299-5127
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1 I CAN GI VE YOU MY BI NDERS.
2 MR. PANI SH: I ' LL BRI NG THEM. THEY' VE GOT THEM
3 ALL. THEY KNOWTHE NUMBERS. I ' LL WORK I T OUT,
4 HOPEFULLY, WI TH MR. PUTNAM. HOPE SPRI NGS ETERNAL.
5 MR. PUTNAM: I T DOES. HE' S RI GHT; I T DOES.
6 MS. BI NA: J UST NOT AFTER THEY' RE PUTTI NG I T
7 UP.
8 THE COURT: I UNDERSTAND. WE' LL TAKE CARE OF
9 I T.
10 MR. PANI SH: PROBABLY NOT GOI NG TO START AT
11 10: 00.
12 THE COURT: I ' LL DO MY BEST.
13 MR. PUTNAM: WHAT ARE WE DOI NG AFTERWARDS?
14 THE COURT: WE WERE GOI NG TO TALK ABOUT
15 PAGE/ LI NE DESI GNATI ONS.
16 MR. PUTNAM: THI NGS OF THAT NATURE. I J UST
17 WANT TO ASK - -
18 MR. PANI SH: THAT' S OKAY.
19 MS. BI NA: I KNOWTHERE' S A BRI EF THAT THE
20 PLAI NTI FFS FI LED ON SOME OF OUR OBJ ECTI ONS AND PROPOSED
21 COUNTERS. WE FI LED A RESPONSE. I THI NK MS. STRONG
22 I NTENDED TO ARGUE THAT.
23 WE HAVE HOUSEKEEPI NG MATTERS. I ' M SURE
24 PLAI NTI FF HAS HOUSEKEEPI NG MATTERS WE CAN DEAL WI TH
25 TOMORROW.
26 MR. PANI SH: I DON' T HAVE ANY HOUSEKEEPI NG
27 MATTERS.
28 MR. BOYLE: BEFORE YOU GO THROUGH TONS OF WORK
866 299-5127
2438
1 ON COUNTER- DESI GNATI ONS, I THI NK THE THRESHOLD QUESTI ON
2 I S, THE RULE MAKES I T CLEAR THAT WE CAN USE THEI R
3 EMPLOYEES' STUFF FOR ANY PURPOSE; RI GHT? I F WE DO THAT,
4 THAT THEN GRANTS THEM THE ABI LI TY TO USE THEI R OWN
5 DEPOSI TI ON THAT THEY NORMALLY WOULDN' T - - WELL, I T WOULD
6 BE HEARSAY.
7 THE ONLY I SSUE I S, WHEN CAN THEY DO THAT? OUR
8 POSI TI ON I S THEY CAN DO I T I N THEI R CASE ALL THEY WANT,
9 BUT THEY CANNOT DESI GNATE THE ENTI RE DEPO - -
10 MS. BI NA: NOBODY HAS DESI GNATED THE ENTI RE
11 DEPO.
12 MR. PANI SH: YES, THEY HAVE. WE CAN DO I T
13 TOMORROW.
14 MS. BI NA: DO I T TOMORROW.
15 MR. PANI SH: CAN I ASK, YOUR HONOR, CAN WE ASK
16 HOWLONG - - AND I KNOWI HAVEN' T FI NI SHED - - J UST AN
17 ESTI MATE OF THE CROSS- EXAMI NATI ON, BECAUSE I HAVE TO
18 ARRANGE WI TNESSES FOR THURSDAY. HOWLONG?
19 MR. PUTNAM: RI GHT NOWI WOULD SAY I ' M GOI NG TO
20 GO ABOUT AS LONG AS YOU HAVE GONE THROUGH.
21 MR. PANI SH: HOWLONG HAVE I GONE?
22 MR. PUTNAM: I ' M GOI NG TO GO BACK.
23 THE COURT: PROBABLY GO BEYOND AN HOUR.
24 MR. PUTNAM: WI THOUT QUESTI ON.
25 MR. PANI SH: WELL, CAN I J UST LI KE - - I S I T ONE
26 HOUR? TWO HOURS? THREE HOURS? TWO TO THREE? I MEAN,
27 HOWHARD I S I T TO GI VE AN ESTI MATE? I ' D LOVE AN ANSWER.
28 MR. PUTNAM: I HAVEN' T FI NI SHED. I HAVEN' T
866 299-5127
2439
1 GOTTEN TO LOOK AT THE WHOLE DOCUMENT YET, THE SUBPOENA
2 OR OTHERWI SE, SO WHAT I ' VE - - WE' LL CERTAI NLY GO BEYOND
3 THE HOUR TOMORROW. I BELI EVE I WI LL GO ABOUT THE SAME
4 HE HAS GONE, BECAUSE WI TH EACH SI NGLE DOCUMENT, THERE
5 HAVE BEEN QUESTI ONS TO FOLLOWUP ON, BECAUSE, I N MY
6 OPI NI ON, I THI NK CERTAI N THI NGS WERE NOT ASKED, AND
7 THAT' S WHY I HAVE TO DO THI S.
8 MR. PANI SH: I DON' T CARE.
9 THE COURT: MR. PANI SH, I CAN' T HEAR.
10 MR. PUTNAM: MAYBE YOU DON' T LI KE THE ANSWER,
11 BUT I ' M GI VI NG YOU THE HONEST ANSWER; OKAY? SO I THI NK
12 I T WI LL BE ABOUT THE SAME TI ME.
13 MR. PANI SH: ALL I WANT TO KNOWI S, I S I T ONE
14 HOUR? TWO HOURS? I ' VE BEEN GOI NG NOWFOR ABOUT AN HOUR
15 AND 32 MI NUTES.
16 THE COURT: WHAT I WAS GOI NG TO SUGGEST I S, TWO
17 HOURS, I F YOU CAN TELL ME - -
18 MR. PANI SH: J UST TELL ME TWO HOURS. THAT' S
19 FI NE. AS LONG AS I KNOW.
20 THE COURT: I ' LL BE FLEXI BLE.
21 MR. PUTNAM: I F HE' S ABOUT TWO HOURS, I THI NK I
22 WI LL BE TWO HOURS.
23 MR. PANI SH: I J UST DON' T WANT TO HAVE THE
24 MEDI CAL EXAMI NERS SI TTI NG AROUND WHEN THEY HAVE ALL
25 THESE DEAD BODI ES I N THE MORGUE. THAT' S ALL.
27 MR. PUTNAM: I WON' T SPEAK TO THAT I SSUE, YOUR
28 HONOR. BUT WI TH ALL DUE RESPECT, I ' M TRYI NG - - I T' S
866 299-5127
2440
1 YOUR COURTROOM. BUT TWO- THI RDS OF THE WAY OF MY
2 OPENI NG, I WAS TOLD TO CUT I T BY QUI TE A BI T, AND I
3 WOULD LI KE TO BE ABLE TO DO ABOUT THE TI ME THAT I
4 ANTI CI PATE WI TH THI S PERSON, AND I T WOULD BE ABOUT THE
5 SAME.
6 THE COURT: I ' M ESTI MATI NG ROUGHLY.
7 MR. PANI SH: I DON' T HAVE ANY OBJ ECTI ON FOR
8 MR. PUTNAM TAKI NG A WEEK. I J UST NEED TO KNOW- -
9 MR. PUTNAM: I DO.
10 MR. PANI SH: - - FOR PLANNI NG OF WI TNESSES.
11 THAT' S ALL. I HAVE NO OBJ ECTI ON. THEY CAN TAKE AS LONG
12 AS THEY WANT.
13 THE COURT: YOU HAVE A REDI RECT, SO - -
14 MR. PANI SH: BUT I J UST NEED TO KNOW- - YOU
15 KNOW, I DON' T WANT ALL THESE PEOPLE WAI TI NG. THAT' S THE
16 REASON. THAT' S ALL I WANT TO KNOW.
17 I ' M NOT TRYI NG TO LI MI T HI M I N ANY WAY. HE CAN
18 GO AS LONG AS HE' D LI KE. NO PROBLEM. I J UST NEED TO
19 KNOWSO I DON' T GET I N A PROBLEM WI TH WI TNESSES WHO ARE
20 PUBLI C SERVANTS, THEY' RE GOI NG TO GET UPSET WI TH ME FOR
21 MAKI NG THEM WAI T AROUND.
22 THAT' S ALL I ASK.
23 MS. CAHAN: YOUR HONOR, CAN WE GET SOME
24 I NFORMATI ON ABOUT WHO I S BEI NG CALLED THURSDAY? I S I T
25 ORI GI NALLY GOI NG TO BE THE WI TNESSES FOR WEDNESDAY?
26 MR. PANI SH: WELL, I ' M GOI NG TO HAVE TO GO BACK
27 AND FI GURE I T OUT NOW- - -
28 MR. BOYLE: I THI NK THAT' S THE PROBLEM.
866 299-5127
2441
1 WI THOUT AN ESTI MATE, I T' S HARD TO TELL.
2 THE COURT: YOU HAVE AN ESTI MATE, ROUGHLY TWO
3 HOURS. THE REDI RECT DEPENDS ON HOWMUCH YOU' RE GOI NG TO
4 REDI RECT, SO - -
5 MR. PANI SH: I MEAN, I COULD DO THEI R DEAL.
6 DEPENDS ON WHAT HE ASKS. BUT MY REDI RECT - -
7 THE COURT: I ' LL GI VE YOU HALF AN HOUR.
8 MR. PANI SH: ALL RI GHT.
9 MS. BI NA: HOWMUCH DO YOU HAVE LEFT?
10 MR. BOYLE: WE LI TERALLY J UST LEARNED THE
11 ESTI MATE, AND SO NOWWE HAVE A GUY THAT WAS SCHEDULED.
12 MR. KOSKOFF: FOR EXAMPLE, PROBABLY BRI NG HI M
13 I N THE AFTERNOON.
14 MR. PANI SH: WE WERE PLANNI NG ON CALLI NG YET
15 TOMORROW, TWO MEDI CAL EXAMI NERS. NOWWE KNOWTHAT ONE
16 MEDI CAL EXAMI NER I S NOT AVAI LABLE THURSDAY; OKAY? WE
17 WERE J UST GOI NG TO TRY TO MOVE THEM OVER.
18 ONE I S AVAI LABLE. WE CAN TELL THEM WHO THAT I S
19 WHO I S AVAI LABLE.
20 MR. KOSKOFF: ROGERS.
22 MR. KOSKOFF: SEEMS LI KE WHAT' S REASONABLE TO
23 THI NK I S THAT, YOU WI LL GO - - AFTER THAT TOMORROW,
24 MR. PANI SH WI LL FI NI SH HI S DI RECT, I WOULD ASSUME.
25 THEN YOU WI LL GO WI TH YOUR CROSS, THERE WI LL BE
26 A REDI RECT. I HAVE DR. ROGERS COMI NG I N THE AFTERNOON.
27 MR. PUTNAM: THAT' S AWESOME.
28 THE COURT: OKAY. AND THEN YOU' LL TELL US THEN
866 299-5127
2442
1 WHO YOUR OTHER WI TNESSES ARE GOI NG TO BE AND GET THE
2 DOCUMENTS TODAY?
3 MR. PANI SH: THURSDAY I S THE LAST DAY OF THE
4 WEEK.
5 MR. KOSKOFF: YES. THURSDAY I S THE LAST DAY.
6 THE COURT: OKAY. THAT' S TRUE.
8 THE COURT: OKAY. THANK YOU.
9
10 ( AT 4: 10 P. M. PROCEEDI NGS WERE ADJ OURNED
11 UNTI L APRI L 31, 2013, AT 10: 00 A. M. )
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JACKSON V AEGLive April 30th RICHARD SENEFF/ Martinez Detective

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JACKSON V AEGLive April 30th RICHARD SENEFF/ Martinez Detective

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