


5517

1 SUPERIOR COURT OF THE STATE OF CALIFORNIA

2 IN AND FOR THE COUNTY OF SANTA BARBARA

3 SANTA MARIA BRANCH; COOK STREET DIVISION

4 DEPARTMENT SM-2 HON. RODNEY S. MELVILLE, JUDGE

5

6

7 THE PEOPLE OF THE STATE OF )

8 CALIFORNIA, )

9 Plaintiff, )

10 -vs- ) No. 1133603

11 MICHAEL JOE JACKSON, )

12 Defendant. )

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14

15

16

17 REPORTER’S TRANSCRIPT OF PROCEEDINGS

18

19 MONDAY, APRIL 11, 2005

20

21 8:30 A.M.

22

23 (PAGES 5517 THROUGH 5578)

24

25

26

27 REPORTED MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304

28 BY: Official Court Reporter 5517



1 APPEARANCES OF COUNSEL:

2

3 For Plaintiff: THOMAS W. SNEDDON, JR.,

4 District Attorney -and-

5 RONALD J. ZONEN, Sr. Deputy District Attorney

6 -and- GORDON AUCHINCLOSS,

7 Sr. Deputy District Attorney 1112 Santa Barbara Street

8 Santa Barbara, California 93101

9

10

11 For Defendant: COLLINS, MESEREAU, REDDOCK & YU BY: THOMAS A. 
MESEREAU, JR., ESQ.

12 -and- SUSAN C. YU, ESQ.

13 1875 Century Park East, Suite 700 Los Angeles, California 90067

14 -and-

15 SANGER & SWYSEN

16 BY: ROBERT M. SANGER, ESQ. 233 East Carrillo Street, Suite C

17 Santa Barbara, California 93101

18 -and-

19 OXMAN and JAROSCAK BY: R. BRIAN OXMAN, ESQ.

20 14126 East Rosecrans Boulevard Santa Fe Springs, California 90670

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28 5518



1 I N D E X

2

3 Note: Mr. Sneddon is listed as “SN” on index.

4 Mr. Zonen is listed as “Z” on index. Mr. Auchincloss is listed as “A” on index.

5 Mr. Nicola is listed as “N” on index. Mr. Mesereau is listed as “M” on index.

6 Ms. Yu is listed as “Y” on index. Mr. Sanger is listed as “SA” on index.

7 Mr. Oxman is listed as “O” on index.

8

9 PLAINTIFF’S

10 WITNESSES DIRECT CROSS REDIRECT RECROSS

11 JONES, Bob 5522-A 5540-M 5558-A 5561-M

12 5563-A

13 (Further)

14 BROWN, Stacy 5564-A

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28 5519



1 E X H I B I T S

2 FOR IN

3 PLAINTIFF’S NO. DESCRIPTION I.D. EVID.

4 803 On-page document dated

5 March 7, 2005 5536

6 804 E-mail 5538

7 805 E-mail 5538

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28 5520



1 Santa Maria, California

2 Monday, April 11, 2005

3 8:30 a.m.

4

5 (The following proceedings were held in

6 open court in the presence and hearing of the

7 jury:)

8

9 THE COURT: Good morning.

10 THE JURY: (In unison) Good morning.

11 COUNSEL AT COUNSEL TABLE: (In unison)

12 Good morning, Your Honor.

13 THE COURT: Ready to proceed?

14 MR. AUCHINCLOSS: Yes, Your Honor. People

15 call Bob Jones.

16 THE COURT: Remain standing, please. Face

17 the clerk here and raise your right hand.

18

19 BOB JONES

20 Having been sworn, testified as follows:

21

22 THE WITNESS: So help me God.

23 THE COURT: Please be seated. State and

24 spell your name for the record.

25 THE WITNESS: Bob Jones. B-o-b; J-o-n-e-s.

26 THE CLERK: Thank you.

27 //

28 // 5521



1 DIRECT EXAMINATION

2 BY MR. AUCHINCLOSS:

3 Q. Good morning, Mr. Jones.

4 A. Good morning.

5 Q. Mr. Jones, in your employment history, have

6 you ever worked for Michael Jackson?

7 A. Yes.

8 Q. And is he the man seated to my right with

9 the long black hair?

10 A. Yes, he is.

11 Q. What did you do for Michael Jackson?

12 A. I was vice-president of communications and

13 community relations.

14 Q. And when did you begin working in that

15 capacity for Mr. Jackson?

16 A. 1987.

17 Q. Can you tell me a little bit about what that

18 title involves in terms of work?

19 A. Dealing with the media, and the community,

20 and various other assignments.

21 Q. Such as?

22 A. Whatever came up. Getting -- arranging to

23 get awards, arranging for coverage in newspapers,

24 magazines. Assisting in the -- with the fan clubs,

25 et cetera.

26 Q. All right. Would it be fair to say that you

27 were the man in charge of public relations --

28 A. Yes. 5522



1 Q. -- for Michael Jackson?

2 A. Yes.

3 Q. And how many years did you work for Mr.

4 Jackson?

5 A. 16 and a half.

6 Q. And how did your employment come to an end?

7 A. I received a letter one day saying that,

8 “Thank you for your services. They’re no longer

9 needed.”

10 Q. Did you ever receive any explanation as to

11 why you were being terminated?

12 A. That, “We were restructuring” --

13 MR. MESEREAU: Objection; hearsay.

14 THE WITNESS: -- “and going in a different

15 direction.” That was in the letter.

16 THE COURT: Just a moment. Just a moment,

17 please.

18 THE WITNESS: I don’t know what you’re

19 saying.

20 THE COURT: All right. I’m going to overrule

21 the objection, but I’ll limit the examination in

22 that area.

23 Q. BY MR. AUCHINCLOSS: All right. As far as

24 your understanding as to why you were being

25 terminated, can you tell us what you believe to be

26 the reason why you were being terminated?

27 A. Well, I can only cite the letter that I

28 received. 5523



1 MR. MESEREAU: Objection. No foundation;

2 and irrelevant opinion.

3 MR. AUCHINCLOSS: I’ll rephrase it.

4 THE COURT: All right.

5 Q. BY MR. AUCHINCLOSS: Were you informed as to

6 the reason for your termination with Michael Jackson

7 as his man in charge of public relations?

8 A. No, because at all times --

9 MR. MESEREAU: Objection; nonresponsive.

10 THE COURT: I’ll allow the answer, “No.”

11 Q. BY MR. AUCHINCLOSS: All right. So you were

12 never given an explanation as to why you were being

13 terminated?

14 A. At all times --

15 Q. That’s a yes or no, question, sir.

16 MR. MESEREAU: Objection; nonresponsive.

17 THE COURT: Overruled. The question was,

18 “All right. So you were never given an explanation

19 as to why you were being terminated?” Is that true?

20 THE WITNESS: The letter, yes. The letter.

21 That’s all I can say.

22 Q. BY MR. AUCHINCLOSS: Okay. Now, one thing

23 we have to be careful about in the question and

24 answer of your examination is we have to be careful

25 we don’t talk over each other, so the reporter can

26 get everything down.

27 A. Okay.

28 Q. And you have to be careful just to answer 5524



1 the question that’s asked. All right?

2 A. Okay.

3 Q. Thank you.

4 So I believe you testified you were

5 terminated late in 2004; is that correct?

6 A. Yes.

7 Q. And since that time have you had any

8 employment?

9 A. No.

10 Q. Have you been involved in any activity at

11 this time concerning -- during that period of time

12 since your termination that concerns your years of

13 employment with Michael Jackson?

14 A. Yes.

15 Q. What is that?

16 A. I went to the State of California and filed

17 a complaint for my vacation pay.

18 Q. All right. Other than that, have you been

19 involved in the writing of any memoirs of your years

20 with Michael Jackson?

21 MR. MESEREAU: Objection; leading.

22 THE COURT: Overruled.

23 THE WITNESS: Is it --

24 THE COURT: You may answer.

25 THE WITNESS: Yes.

26 Q. BY MR. AUCHINCLOSS: And can you

27 specifically tell me what you’ve been doing in terms

28 of writing those memoirs? 5525



1 A. Preparing a book.

2 Q. Preparing a book?

3 A. Yes.

4 Q. And what is the subject matter of that book?

5 A. My -- well, my years and -- my years with

6 Michael Jackson.

7 Q. During your years of working with Michael

8 Jackson, did you have occasion to spend time with

9 him personally?

10 A. Seldom.

11 Q. Who was it that hired you?

12 A. Michael Jackson.

13 Q. Personally?

14 A. Yes.

15 Q. And did you ever travel with him?

16 A. Yes.

17 Q. On how many occasions?

18 A. I think on three tours, and perhaps on

19 special occasions for events that I had arranged,

20 such as the World Music Awards.

21 Q. Where was the World Music Awards?

22 A. Monaco.

23 Q. In Europe?

24 A. Yes.

25 Q. And when was that?

26 A. Now, I can’t tell you an exact date. I’m

27 not good on dates.

28 Q. All right. Can you approximate? 5526



1 A. I would say approximately ‘92.

2 Q. How long did that trip take?

3 A. The trip probably lasted about ten days.

4 Q. And did you travel with Mr. Jackson to

5 Monaco?

6 A. Yes.

7 Q. Did Mr. Jackson bring any guests with him on

8 that trip?

9 A. Yes.

10 Q. Who?

11 A. Jordie Chandler, his mother June Chandler,

12 and her sister -- his -- Jordie’s sister.

13 Q. Did you personally see Mr. Jackson and

14 Jordie Chandler together during that trip?

15 A. Of course.

16 Q. How often?

17 A. We -- well, whenever I saw one, I saw the

18 other.

19 MR. AUCHINCLOSS: If I may approach, Your

20 Honor.

21 THE COURT: Yes.

22 Q. BY MR. AUCHINCLOSS: Mr. Jones, I show you

23 People’s Exhibit 776. Can you identify that for me,

24 please?

25 A. That’s Jordie Chandler.

26 Q. Now, you said whenever you saw Mr. Jackson,

27 you saw Jordie Chandler with him?

28 A. Yes. 5527



1 Q. How often would you see Mr. Jackson during

2 that trip?

3 A. Well, I would say, doo-doo-doo-doo, in Monte

4 Carlo maybe I saw them three or four times.

5 Q. Did you travel on the plane with them to

6 Monaco?

7 A. Most definitely.

8 Q. Did you travel on the plane with them back

9 to the United States?

10 A. I -- yes, I traveled on the plane with them

11 from Monte Carlo to Paris, and then back to the

12 United States.

13 Q. Did Mr. Jackson attend the World Music

14 Awards?

15 A. Yes, he did.

16 Q. Did you see him there?

17 A. Yes.

18 Q. Did you ever see Mr. Jackson personally

19 demonstrate any physical affection towards Jordie

20 Chandler during this period?

21 MR. MESEREAU: Objection; leading.

22 THE COURT: Sustained.

23 Q. BY MR. AUCHINCLOSS: Did you ever see any

24 conduct involving any physical contact between

25 Michael Jackson and Jordie Chandler?

26 A. Yes.

27 Q. How often?

28 A. On the flight back from -- 5528



1 Q. The question is, first of all, how often did

2 you see this?

3 A. Well, just the one time.

4 Q. And you started to talk about the flight

5 back?

6 A. Well, that’s when the -- can I make a

7 correction?

8 Q. Yes.

9 A. Number one, I saw them together at the

10 awards. And then on the flight back from Paris to

11 Los Angeles.

12 Q. Okay. Were they in physical contact with

13 one another at the awards?

14 A. He sat -- yes.

15 Q. And can you describe -- were they in

16 physical contact during the flight back?

17 A. They were embraced into one another on --

18 sleeping on the airplane from Paris to Los Angeles.

19 Q. Now, going to the music awards, what was the

20 nature of the physical contact that you saw with

21 them at the World Music Awards?

22 A. Jordie sat on his lap.

23 Q. Where were you seated?

24 A. I sat a distance away from June, her

25 daughter, and Jordie and Michael.

26 Q. How many feet away were you when you were

27 observing Mr. Jackson and Mr. Chandler together?

28 A. Oh, I would say approximately 20 feet. 5529



1 Q. And if you would describe for me in detail

2 what you saw at the World Music Awards involving Mr.

3 Chandler and Jackson?

4 A. Well, during the performance, he sat on his

5 lap, Jordie sat on his lap. And the sister sat on

6 the other lap, but at one time Linda Evans took the

7 girl off of his lap and let her sit on her lap.

8 Q. Mr. Jones, during the World Music Awards

9 when you were watching Mr. Jackson and Jordie

10 Chandler sitting together, did you ever see Mr.

11 Jackson lick Jordie Chandler’s head?

12 A. No, sir.

13 Q. Have you been interviewed by police officers

14 concerning this matter?

15 A. Not that I recall.

16 Q. Didn’t you have an interview with Steve

17 Robel and your attorney and myself last week in the

18 victim/witness room --

19 A. Yes.

20 Q. -- concerning this incident?

21 A. Yes, yes, yes.

22 Q. At that meeting, didn’t you tell Mr. Robel

23 and myself and your attorney that you weren’t sure

24 if that happened?

25 A. I was very --

26 MR. MESEREAU: Objection.

27 THE WITNESS: I was adamant in saying I was

28 not sure that that happened. I could -- I could 5530



1 definitely say that they were embraced in one

2 another’s arms on the flight, but I don’t recall

3 anything about head licking.

4 Q. BY MR. AUCHINCLOSS: My question is, didn’t

5 you say that you didn’t remember that, but you

6 weren’t sure whether or not Mr. Jackson licked

7 Jordie Chandler’s head?

8 MR. MESEREAU: Objection. Leading, and

9 argumentative, and misstates the evidence.

10 MR. AUCHINCLOSS: This is impeachment, Your

11 Honor.

12 THE COURT: The objection is overruled.

13 You may answer.

14 THE WITNESS: I might have said that. But I

15 don’t recall.

16 Q. BY MR. AUCHINCLOSS: You don’t recall

17 whether you said that?

18 A. No, I don’t recall ever seeing any head

19 licking, and I made that as adamant as I could.

20 Q. All right. So is it your testimony today

21 that you don’t have a recollection of the head

22 licking --

23 MR. MESEREAU: Objection. Argumentative,

24 and asked and answered, and leading.

25 MR. AUCHINCLOSS: I don’t think I’ve gotten

26 an answer yet.

27 THE COURT: Well, you haven’t got the

28 question out, so go ahead and state your question. 5531



1 Q. BY MR. AUCHINCLOSS: I’m trying to clarify

2 the state of your memory, sir.

3 A. Sure.

4 Q. Is it your testimony today that you do not

5 remember whether or not you saw any head licking?

6 A. No. I don’t remember having seen any head

7 licking.

8 Q. Okay. So is it fair to say you were not

9 saying it couldn’t have happened?

10 MR. MESEREAU: Objection; argumentative.

11 THE COURT: Sustained.

12 MR. MESEREAU: Calls for speculation.

13 Q. BY MR. AUCHINCLOSS: Are you saying you just

14 simply do not have a recollection of it?

15 MR. MESEREAU: Objection. Asked and

16 answered; argumentative; and leading.

17 THE COURT: Sustained.

18 Q. BY MR. AUCHINCLOSS: Mr. Jones, you said

19 you’re writing a book in this case?

20 A. Sure.

21 Q. What is the title of that book?

22 A. “The Man Behind the Mask.”

23 Q. What is the complete title of that book?

24 A. “The Man” --

25 MR. MESEREAU: Objection. Objection.

26 Hearsay; relevance.

27 THE COURT: Overruled.

28 You may answer. 5532



1 THE WITNESS: Oh. “The Man Behind the

2 Mask.” In all honesty, I don’t -- I can’t tell you

3 the subtitle.

4 Q. BY MR. AUCHINCLOSS: You don’t recall the

5 name of your book?

6 A. No, I don’t recall the subtitle. I do know

7 “An Insider’s View of the Rise and Fall of the King

8 of Pop.” Maybe that’s it.

9 Q. Is the name of your book, “Michael Jackson,

10 The Man in the Mirror, An Insider’s Account of the

11 King of Pop’s Spectacular and Catastrophic Fall from

12 Grace”?

13 THE WITNESS: No.

14 MR. MESEREAU: Objection. Leading; hearsay.

15 Q. BY MR. AUCHINCLOSS: That is not the title

16 of your book?

17 A. The “Catastrophic” --

18 THE COURT: Just a moment. There’s an

19 objection.

20 It’s overruled.

21 MR. AUCHINCLOSS: All right.

22 THE WITNESS: “Catastrophic Fall” was taken

23 out. It was a suggested title and I took that

24 “Catastrophic” out. And it isn’t “The Man Behind

25 the Mirror.” It’s “The Man Behind the Mask.” Maybe

26 one of the suggested titles was that other that I

27 did not approve of.

28 Q. BY MR. AUCHINCLOSS: Is your book presently 5533



1 at the publisher?

2 A. It is being edited, but the book is not

3 complete. It is far from complete.

4 Q. Is your book presently at the publisher?

5 A. Yes, sir.

6 Q. What’s the name of that publisher?

7 A. System, I think. My co-writer handled that

8 end of it.

9 Q. And your book is currently being edited?

10 A. Yes.

11 Q. Has it been accepted by the publisher as a

12 prospect for publication?

13 A. It has been, but it has not been approved by

14 me.

15 Q. The manuscript that is at the publisher --

16 well, let me strike that.

17 Is the book that is being reviewed by your

18 publisher currently an honest account of your years

19 working with Michael Jackson?

20 MR. MESEREAU: Objection. Calls for

21 speculation; irrelevant opinion.

22 THE COURT: Sustained.

23 Q. BY MR. AUCHINCLOSS: Have you reviewed the

24 manuscript that is at the publisher’s?

25 A. I have looked at a manuscript that has not

26 been approved by me.

27 Q. How many times have you looked at this

28 manuscript? 5534



1 MR. MESEREAU: Objection; relevance.

2 THE COURT: I’m not sure where you’re going

3 with this. Are you -- is it your intent to impeach

4 him with his manuscript, is that what you’re --

5 MR. AUCHINCLOSS: Yes.

6 THE COURT: All right. The objection is

7 overruled.

8 THE WITNESS: Perhaps I’ve looked at it twice

9 and I have -- I have a co-writer.

10 Q. BY MR. AUCHINCLOSS: Okay. This manuscript

11 that you’ve looked at, is it fact or fiction?

12 A. It’s part --

13 MR. MESEREAU: Objection; no foundation.

14 There’s a co-writer. It’s not been approved. It’s

15 being edited by some other people.

16 MR. AUCHINCLOSS: I’m talking about the

17 manuscript he’s looked at.

18 THE COURT: Objection’s overruled.

19 Q. BY MR. AUCHINCLOSS: Is this a factual

20 manuscript or is it a fictional manuscript?

21 A. It is factual to a degree.

22 Q. To what degree is it factual?

23 A. It’s to a degree, because I -- my co-writer

24 also has included things that I didn’t approve of.

25 Q. I’m going to read to you a quote from that

26 manuscript and ask you whether it’s factual or

27 fiction.

28 A. Sure. 5535



1 MR. MESEREAU: Objection. Can we approach

2 the bench, Your Honor?

3 THE COURT: Just a moment.

4 Before you can impeach him with the

5 manuscript, you have to establish a foundation that

6 he, in fact, wrote this part that you want to

7 impeach him with.

8 I’ll allow you to approach the witness and

9 show it to him, but I’m not going to allow you to

10 read in open court something that may have been

11 written by somebody else.

12 MR. AUCHINCLOSS: That’s fine, Your Honor.

13 Q. Mr. Jones, I show you People’s Exhibit No.

14 803. It appears to be one page of typed -- this is

15 a word-processed document.

16 A. Okay.

17 Q. And it’s dated March 7th, 2005. There are

18 two paragraphs below the exhibit number. If you’d

19 read those two paragraphs, I’m going to ask you a

20 couple of questions about it.

21 A. Sure. “He’s one of the young” --

22 Q. Just a moment. Just read them silently.

23 A. Oh. Okay.

24 I did not write this. This I did write.

25 Q. All right.

26 THE COURT: So did he show you one he wrote

27 and one he didn’t write?

28 MR. AUCHINCLOSS: Yes. And for the record, 5536



1 he indicated --

2 Q. If I’m accurate, Mr. Jones, you indicated

3 the first paragraph in the lower portion of the page

4 you didn’t write, but the second paragraph you did

5 write?

6 A. Yes.

7 THE COURT: Is that clear to you which he

8 indicated, Counsel?

9 MR. MESEREAU: I think so, but I’d like to

10 talk to the prosecutor first. I think I understand.

11 Q. BY MR. AUCHINCLOSS: All right. That second

12 paragraph -- Mr. Jones, that second paragraph is an

13 account of what you observed at the World Music

14 Awards; is that accurate?

15 A. That’s what I observed on the airplane.

16 Q. Okay. In that paragraph, it states --

17 MR. MESEREAU: Objection; hearsay.

18 MR. AUCHINCLOSS: It’s impeachment. And I

19 can show it to you, Your Honor.

20 THE COURT: The objection’s overruled.

21 Q. BY MR. AUCHINCLOSS: It states, “I looked at

22 what was going on with the king and the boy.” Who

23 is “the king” in your --

24 A. The king of pop, Michael Jackson.

25 Q. All right. “Others looked at them rather

26 strange, too. They were holding each other tight,

27 almost in a romantic sense, cooing. There were

28 pecks on the cheeks and licks on the top of the 5537



1 head.”

2 Those are your words, sir, true?

3 A. Sir --

4 Q. That’s a “yes” or “no” question.

5 A. Yes, with reservations.

6 Q. Mr. Jones, did you see Michael Jackson lick

7 Jordie’s head?

8 MR. MESEREAU: Objection; asked and

9 answered.

10 THE COURT: Sustained.

11 MR. AUCHINCLOSS: If I may approach, Your

12 Honor.

13 THE COURT: Yes.

14 Q. BY MR. AUCHINCLOSS: Mr. Jones, I show you

15 People’s Exhibit 804. It appears to be an e-mail.

16 Can you identify that for me, please?

17 A. It’s from an e-mail that I sent to Stacy

18 Brown, my co-writer.

19 Q. The cite -- well, I won’t quote, but that is

20 your e-mail address at the top?

21 A. Yes, yes.

22 Q. And those are your words?

23 A. If they were sent by my e-mail, yes, they

24 have to be my words.

25 Q. You don’t dispute that those are your words?

26 A. No.

27 Q. And I show you People’s Exhibit No. 805. If

28 you’d identify that for me, please. Also appears to 5538



1 be an e-mail dated the same date, but the time on it

2 is 22:30:17 EDT.

3 The first one, for identification purposes,

4 804, is dated -- the time on it is 19:55:32 EDT.

5 Okay. So showing you Exhibit 805, is that

6 one of your e-mails, sir?

7 A. Well, they’re both from my e-mail.

8 Q. All right. You wrote them?

9 A. Yes.

10 Q. And in the first e-mail, 804 --

11 MR. MESEREAU: Objection; hearsay.

12 MR. AUCHINCLOSS: Offered as impeachment.

13 THE COURT: All right. Overruled.

14 Q. BY MR. AUCHINCLOSS: You wrote -- and

15 this -- first of all, let me ask you, is the date of

16 this e-mail accurate, October 30th, 2004?

17 A. I would imagine it is, sir.

18 Q. In that e-mail, you wrote, “Stacy: The

19 licking is going to be important because he did it

20 in this case, too.” Are those your words, sir?

21 A. Apparently so.

22 Q. And in the e-mail that was dated the same

23 day just a few hours later, did you write, “Stacy:

24 The stuff with Jordie will bite him big”?

25 A. If it’s -- if it came from my e-mail, I

26 wrote it. But I don’t -- that sounds a little

27 strange from my writing.

28 MR. AUCHINCLOSS: Thank you. I have no 5539



1 further questions.

2 THE COURT: Cross-examine?

3 MR. MESEREAU: Yes, please, Your Honor.

4

5 CROSS-EXAMINATION

6 BY MR. MESEREAU:

7 Q. Good morning, Mr. Jones.

8 A. Good morning.

9 Q. My name is Tom Mesereau and I speak for

10 Michael Jackson.

11 A. Sure.

12 Q. We haven’t met before, right?

13 A. No.

14 Q. Okay. The prosecutor referred to an

15 interview that you had with Sergeant Steve Robel and

16 another officer on April 7th, 2005.

17 A. Uh-huh.

18 Q. Do you remember that?

19 A. Yes.

20 Q. And do you remember you were asked by an

21 officer, “Um, did you see Mr Jackson engage in any

22 head licking in the World Music Awards?” And your

23 answer was, “No, no, no,” right?

24 A. Uh-huh.

25 Q. And then you were asked, “Um, did you see

26 Mr. Jackson engage in any head licking of anybody?”

27 And your answer was, “Never.” Remember that?

28 A. I recall. 5540



1 Q. Okay. And what you were not -- when you

2 were dealing with your co-writer and publisher, you

3 were not under oath, were you?

4 A. No.

5 Q. And of course today you are, right?

6 A. Yes.

7 MR. AUCHINCLOSS: Objection; argumentative.

8 THE COURT: Overruled. Next question. He

9 answered that.

10 Q. BY MR. MESEREAU: The reality is, Mr. Jones,

11 you have repeatedly said you don’t recall seeing

12 head licking on the plane, right?

13 MR. AUCHINCLOSS: Objection; misstates the

14 evidence.

15 THE COURT: Sustained.

16 Q. BY MR. MESEREAU: You don’t recall seeing

17 head licking by Michael on the plane with Jordie, do

18 you?

19 A. I said it, but it was in the -- it appeared

20 in an e-mail. I said I did not recall seeing it,

21 but it -- apparently so, because it appeared in an

22 e-mail that came from my machine.

23 Q. Well, in response to the prosecutor’s

24 questions, you said you had reservations about that

25 statement --

26 A. Yes.

27 Q. -- correct?

28 And what are your reservations about that 5541



1 statement?

2 A. That I just don’t recall exactly seeing

3 that. I truly don’t.

4 Q. And would you agree when you’re working with

5 a co-writer and a publisher to prepare a book about

6 Michael Jackson, there’s pressure to make things

7 sensational when you can, right?

8 A. Yes.

9 Q. And your publisher and others want a book

10 that can sell, correct?

11 A. My co-writer. The publisher wasn’t involved

12 in that particular end of it.

13 Q. Okay. And certainly, having worked with

14 Michael all those years, you’ve seen numerous

15 attempts by numerous people to sensationalize

16 aspects of Michael’s life, right?

17 A. Correct.

18 Q. And if you’re writing a book about Michael,

19 there certainly is always a temptation to

20 sensationalize if you don’t watch yourself, right?

21 MR. AUCHINCLOSS: Objection; argumentative.

22 THE COURT: Sustained.

23 Q. BY MR. MESEREAU: How is the book being

24 written?

25 A. Well, I don’t quite understand what

26 you’re --

27 Q. Let me rephrase it. It’s probably a poor

28 question. 5542



1 You have a co-writer?

2 A. That’s correct.

3 Q. Did your co-writer ever work for Michael

4 Jackson?

5 A. No, but my co-writer knows the family.

6 Q. Okay. And you’re both trying to prepare a

7 book about your observations and experiences in the

8 past, right?

9 A. Yes.

10 Q. And the prosecutor asked you some questions

11 about what stage it’s in, right?

12 A. Yes.

13 Q. And is there considerably more editing

14 required?

15 A. Most definitely.

16 Q. And is it a long ways from being published

17 as far as you’re concerned?

18 A. As far as I am concerned, and I’m supposed

19 to have final approval.

20 Q. And when you have a co-writer on a book like

21 that -- actually, let me make it more direct.

22 Does your co-writer have responsibility for

23 preparing drafts that you have to then review for

24 accuracy?

25 A. That is correct.

26 Q. Okay. And is it -- would it be appropriate

27 to say that what the prosecutor showed you has not

28 been approved for accuracy? 5543



1 MR. AUCHINCLOSS: I’m going to object to any

2 further leading of this particular witness, Your

3 Honor.

4 THE COURT: Overruled.

5 You may answer. Do you want the question

6 read back?

7 THE WITNESS: Would you repeat the question,

8 please?

9 THE COURT: I’ll have the court reporter read

10 it back.

11 (Record read.)

12 THE COURT: Are you talking about Exhibit

13 803, Counsel, or not?

14 MR. MESEREAU: Yes, Your Honor.

15 THE COURT: You need to show it to him,

16 because he’s been shown three exhibits.

17 MR. MESEREAU: I don’t know -- are the

18 exhibits in front of you, Mr. Jones?

19 THE WITNESS: Exhibits? I don’t have

20 anything.

21 THE COURT: They’re not up there.

22 MR. MESEREAU: May I approach, Your Honor?

23 THE COURT: You may.

24 Q. BY MR. MESEREAU: Mr. Jones, I’m showing you

25 what has been marked as Exhibit No. 803, okay? Do

26 you see that?

27 A. Uh-huh.

28 Q. That starts off with a title that you said 5544



1 is not accurate and has not been approved, correct?

2 A. That is correct.

3 Q. And you told the prosecutor you had written

4 the words at the bottom of the page that refer to

5 licking, right?

6 A. Uh-huh.

7 Q. And is it your testimony that you have not

8 approved the accuracy of that statement?

9 A. That is correct.

10 Q. Okay. Now, the prosecutor showed you an

11 e-mail that you indicated you think you sent; is

12 that correct?

13 MR. AUCHINCLOSS: Objection; misstates the

14 evidence.

15 THE COURT: Overruled.

16 Q. BY MR. MESEREAU: Do you see that?

17 A. Personally I don’t think this is in the

18 book, this statement.

19 MR. AUCHINCLOSS: I’ll object as

20 nonresponsive.

21 THE COURT: I guess it’s without -- his

22 answer shows me it’s without foundation. So do you

23 want to ask a foundational question on that?

24 MR. MESEREAU: Yes.

25 Q. Mr. -- well, let me just show you. I’m

26 looking now at Exhibit 805, okay? And that’s the

27 e-mail the prosecutor referred to.

28 A. Uh-huh. 5545



1 Q. And I think you said you believe you sent

2 the e-mail; is that right?

3 A. Uh-huh.

4 Q. And are the words in that e-mail accurate as

5 far as you’re concerned?

6 A. Perhaps they are.

7 Q. You don’t know?

8 A. Because I wrote -- if it came from my e-mail

9 address, I had to write it.

10 Q. Okay. And -- but you don’t know for sure?

11 A. No.

12 Q. And are the words on that e-mail words you

13 intend to include in your book?

14 A. Not like that. My -- my co-writer is

15 handling that, and I have tried to change certain

16 things in the way things were said on numerous

17 occasions with him.

18 Q. Would it be accurate to say that neither

19 Exhibit 803 nor Exhibit 805 are accurate as far as

20 you’re concerned?

21 MR. AUCHINCLOSS: Objection; misstates the

22 evidence --

23 THE COURT: Overruled.

24 MR. AUCHINCLOSS: -- as far as to 803.

25 THE COURT: Overruled.

26 You may answer.

27 THE WITNESS: Well, I don’t know which

28 one -- you got three different things there, don’t 5546



1 you?

2 MR. MESEREAU: Sure.

3 May I approach, Your Honor?

4 THE COURT: Yeah.

5 Q. BY MR. MESEREAU: Showing you Exhibit 803

6 and Exhibit 805, okay?

7 A. This is three. This is five.

8 Q. Yes. Okay? Let’s talk about 803. You’ve

9 already indicated the title -- what purports to be

10 the title is not going to be the title of your book,

11 right?

12 A. That’s correct.

13 Q. And you’ve already indicated that the bottom

14 paragraph that you say you wrote is not accurate; is

15 that correct?

16 A. Uh-huh. This I wrote.

17 Q. Yes.

18 A. Yes.

19 Q. But you’re indicating it’s not accurate,

20 true?

21 MR. AUCHINCLOSS: Objection; misstates the

22 evidence.

23 THE COURT: Overruled.

24 You may answer.

25 THE WITNESS: Not completely true as far as

26 I’m concerned.

27 Q. BY MR. MESEREAU: Okay. Let’s look at the

28 next exhibit, which is Exhibit No. 805. Do you see 5547



1 that?

2 A. Yes. This -- this one is true. I’m sorry.

3 Yes. I’m sorry.

4 Q. And you wrote that e-mail, correct?

5 A. Yes. Yes.

6 Q. And what you said in the e-mail was, in

7 summary, that you might -- and correct me if I’m

8 wrong, that you thought your knowledge of the

9 Chandlers might be an insurance policy for you?

10 A. Uh-huh.

11 Q. Correct?

12 A. Uh-huh.

13 Q. An insurance policy of employment, right?

14 A. Uh-huh.

15 Q. And what that means is, “I might try and

16 hold over Michael’s head what I could say about the

17 Chandlers,” right?

18 MR. AUCHINCLOSS: I’m going to object to

19 counsel ascribing any meaning to those words.

20 THE COURT: Sustained.

21 Q. BY MR. MESEREAU: What did you mean by

22 “insurance policy of employment”?

23 A. Well, I was not -- I did not have a

24 confidentiality agreement.

25 Q. Okay.

26 A. That’s what I -- that’s what I basically

27 meant.

28 Q. And did you also mean that, “Because I’ve 5548



1 spent all these years with Michael, that I could

2 almost use as a threat writing an expose of him if

3 I’m not employed by him”?

4 MR. AUCHINCLOSS: Same objection. And

5 argumentative.

6 THE COURT: Overruled.

7 You may answer.

8 Q. BY MR. MESEREAU: Is that sort of what it

9 means?

10 A. No, not really, because I have never -- I

11 have never sued, I have never sold stories. I have

12 never -- in the 16 and a half years, I’ve never

13 attempted to extort in any manner.

14 Q. And I’m not saying you did. I’m just asking

15 you --

16 A. No, no, I did not mean it in that respect.

17 Q. Okay. Now, when did you say your work was

18 terminated?

19 A. June 9th, 2004.

20 Q. Okay. And where was your office at the

21 time?

22 A. In my home.

23 Q. You indicated in response to the

24 prosecutor’s question that you didn’t see Michael

25 very often, right?

26 A. No.

27 Q. And why was that?

28 A. This was -- this was Michael Jackson’s modus 5549



1 operandi from the very beginning. I saw Michael

2 mostly if we were on a tour that my presence -- if I

3 may explain. I have worked in the entertainment

4 industry prior to working with Michael Jackson for

5 17 and a half years, and I know familiarity breeds

6 contempt. And the further you stay away from

7 artists, the better off you are.

8 Q. And for that reason, did you not go to

9 Neverland very much?

10 A. I went to Neverland when I brought groups

11 up, such as the Challengers Boys & Girls Club. Such

12 as the First AME Church, et cetera. I was not a

13 regular visitor at Neverland at all.

14 Q. Now, who was the first group that you

15 mentioned that you brought?

16 A. The Challengers Boys --

17 MR. AUCHINCLOSS: Objection. Relevance;

18 beyond the scope.

19 THE COURT: Sustained.

20 Q. BY MR. MESEREAU: In a typical year, while

21 you were employed, how often would you visit

22 Neverland?

23 A. I haven’t been to Neverland in years. My

24 visits to Neverland were on a more frequent basis

25 about five years ago when I was able to get groups

26 approved to go to Neverland.

27 Q. Okay. And you had an office located where?

28 A. Before we closed the offices, we were at 5550



1 9255 Sunset Boulevard.

2 Q. Okay. And how many years did you spend in

3 that office?

4 A. I think we were there approximately ten

5 years, I think. I cannot be for certain.

6 Q. Okay. Now, you indicated at the music

7 awards, the World Music Awards, that at one point

8 you saw Jordie on Michael Jackson’s lap and his

9 sister on Michael Jackson’s lap together, right?

10 A. That is correct.

11 Q. Okay. And where was Michael Jackson sitting

12 in that event?

13 A. He was seated on the front row next to

14 Prince Albert of Monaco, and -- on one side, and

15 Linda Evans, the actress, on the other side.

16 And I attempted to get -- I had arranged for

17 the Chandlers to sit directly behind Mr. Jackson,

18 because I did not feel that the royalty wanted to be

19 bothered with those guests. But he insisted that

20 they sit with him, so I left it alone.

21 Q. Did the mother sit with Michael Jackson as

22 well?

23 A. Behind.

24 Q. Okay. So when you saw the brother and

25 sister sitting on Michael Jackson’s lap in the first

26 row, the mother was right behind, correct?

27 A. Correct.

28 Q. So this is the first row in full view of 5551



1 everyone at the awards show, correct?

2 A. That is correct.

3 Q. There was no effort to hide anything at any

4 time?

5 A. No.

6 Q. At some point, did you see the children with

7 their mother behind where Michael Jackson was

8 sitting?

9 A. When I brought them in to their seats, they

10 were seated behind Mr. Jackson. Mr. Jackson moved

11 them up front.

12 Q. Okay. Did -- when you say he moved them up

13 front, did he move them into seats up front?

14 A. He moved them into his seat.

15 Q. Okay. Okay. So the children moved into his

16 seat to sit with him?

17 A. With him.

18 Q. And the mother still stayed sitting behind?

19 A. That is correct.

20 Q. And at some point did you see the children

21 go back with their mother or did they always stay

22 with Michael?

23 A. No, they stayed up there.

24 Q. And I think at one point you saw Jordie

25 still sitting on Michael’s lap, and Jordie’s sister

26 sitting on Linda Evans’ lap?

27 A. That is correct.

28 Q. Please tell the jury what the World Music 5552



1 Awards show is.

2 A. The World Music Awards show is a show that’s

3 given annually in Monte Carlo for the best record

4 sales in -- the best worldwide record sales.

5 I had arranged for Mr. Jackson to be honored

6 by the World Music Awards, and -- because of his

7 record sales. And we had gone there for that

8 particular purpose, for him to be honored by the

9 World Music Awards. And to be seen around the

10 world. And I attempted, because perception is 90

11 percent of what the public thinks, to get those

12 people off of his lap.

13 Q. Did the Chandler family seem to remain

14 during the entire show sitting with Michael?

15 A. Oh, of course. Yes.

16 Q. Okay. Now, you -- how did you get to

17 Monaco?

18 A. We flew.

19 Q. Did you -- fly from where?

20 A. Los Angeles.

21 Q. Okay. And were there other stops on that

22 trip?

23 A. To Paris. We flew from Los Angeles to

24 Paris, and Paris to Nice, and we helicoptered to

25 Monte Carlo.

26 Q. Okay. Do you recall attending any other

27 events with Mr. Jackson on the trip to Monaco?

28 A. Of course, His Royal Highness Prince Albert 5553



1 hosted a reception for visiting dignitaries, and I

2 was -- he had an event -- when you go there, they

3 have an event each night for visiting dignitaries.

4 And there was only one event that Mr. Jackson

5 attended.

6 Q. And do you recall whether or not the

7 Chandler family were at that event?

8 A. They were with him.

9 Q. And that was because Michael insisted that

10 the Chandler family go?

11 A. I don’t know whether he insisted whether

12 they attend or not.

13 Q. Okay.

14 A. But all of his guests were invited.

15 Q. Okay. Were there any other guests of

16 Michael Jackson that you haven’t named?

17 A. No, just the Chandler family.

18 Q. Okay. Now, did you begin writing your book

19 after your employment ended?

20 A. I had made notes on certain things. Yes,

21 the actual beginning of the writing of the book

22 started after my employment ended, yes.

23 Q. And has there been an effort by you or your

24 co-writer to market the book overseas?

25 A. Well, I would imagine that the publisher

26 has.

27 Q. Has there been an attempt to market it in

28 the United States? 5554



1 A. I would imagine that the publisher has.

2 Q. Okay. And who is in charge of that issue?

3 A. My co-writer.

4 Q. Okay. Now, do you typically meet with your

5 co-writer periodically?

6 A. We talk on the phone. That’s -- that’s

7 perhaps one of the reasons there is some confusion,

8 because our -- he’s based in New York and I’m based

9 in Los Angeles.

10 Q. Okay. And do you sort of fax or e-mail

11 manuscripts to one another?

12 A. We e-mail.

13 Q. Okay. And do you then typically correct or

14 change what you think is either inaccurate or

15 inappropriate?

16 A. Oh, I’ve changed millions of things that

17 were inaccurate that I didn’t say.

18 Q. And how far away from having a product that

19 you think is accurate and complete are you?

20 A. I would say six to eight weeks.

21 Q. Okay. Have you come up with a date during

22 which you intend to announce the availability of the

23 book?

24 A. No.

25 Q. Okay. Do you remember in your interview on

26 April 7th, 2005, a police officer asking you about

27 whether or not there was any licking on the plane by

28 Michael, and you said, “I just don’t remember and I 5555



1 would be lying to say that I did”?

2 A. Of course I recall saying that.

3 Q. And that was the truth, right?

4 A. Yes.

5 Q. Now, on the plane coming back, do you

6 remember where Jordie’s mother June was seated?

7 A. Sure.

8 Q. Where was she seated?

9 A. We were all in first class, and on one side

10 of the rear of first class was Michael and Jordie

11 Chandler. On the total opposite side was June

12 Chandler and her daughter.

13 Q. Certainly June and her daughter were in a

14 position to observe Michael and Jordie, correct?

15 A. That is correct.

16 Q. So they were seated parallel to one another?

17 A. Yes.

18 Q. Nothing that went on was hidden from

19 anybody, correct?

20 A. No.

21 Q. And where were you seated in relation --

22 A. I was seated at least two front -- two rows

23 ahead of them.

24 Q. How many times have you been contacted by

25 any representative of the sheriffs or police

26 department in this case?

27 A. Well, I was contacted prior to my

28 registration -- I mean, my being served with a 5556



1 subpoena. And at one point, a Richard Steingard, I

2 approached him about representation because he had

3 represented me before in this case, and then he came

4 back and said that he could not represent me any

5 longer. And that’s when Attorney Sachs was

6 contacted. So I had been -- they attempted to serve

7 a subpoena to me, and at that time I did accept the

8 subpoena at Richard Steingard’s office, and

9 following which he informed me that he could no

10 longer represent me.

11 Q. Have you ever spoken to any prosecutor for

12 the government in this case directly?

13 A. Who do you mean, the government?

14 Q. These people. The prosecutors.

15 A. Certainly. I’ve -- Mr. Auchincloss and

16 Steve Robel.

17 Q. When did you last meet with Mr. Auchincloss?

18 A. I met with him on Friday when I was told to

19 go home and come back.

20 Q. Okay. And did you meet with him before

21 that?

22 A. Of course. You mentioned an April date that

23 Mr. Auchincloss had me to come up.

24 Q. Okay. Was that April 7th?

25 A. I guess, sir. I don’t -- I’m not good with

26 dates, so --

27 Q. You had an interview with Sergeant Steve

28 Robel, right? 5557



1 A. And Mr. Auchincloss.

2 Q. Okay. How many meetings did you have with

3 Sergeant Robel, if you know?

4 A. I only met Sergeant Robel when I was with

5 Mr. Auchincloss. I met them both at the same time.

6 Q. Okay. So when you said, “I just don’t

7 remember and I would be lying to say that I did,”

8 about head licking, Mr. Auchincloss was right there,

9 right?

10 A. We were -- we were there, yes, we were --

11 the three of us were in the room.

12 Q. So he clearly heard you say that, correct?

13 A. Mr. Auchincloss was in the room with Mr.

14 Robel.

15 Q. And he tried to misquote you in court today,

16 correct?

17 MR. AUCHINCLOSS: Objection. This is

18 argumentative; improper.

19 THE COURT: Sustained.

20 MR. MESEREAU: No further questions, Your

21 Honor.

22

23 REDIRECT EXAMINATION

24 BY MR. AUCHINCLOSS:

25 Q. Mr. Jones, you told Stacy Brown about this

26 head licking incident, true?

27 A. Apparently I did, sir.

28 Q. And you have previously stated that the 5558



1 words on the second paragraph of People’s Exhibit

2 803, which I’ve shown you - that’s the quotes from

3 the book --

4 A. Uh-huh.

5 Q. -- the second paragraph - those are your

6 words?

7 A. Yes.

8 MR. AUCHINCLOSS: All right. Your Honor, if

9 I may, I’d like to admit --

10 THE WITNESS: With -- with -- may I see

11 that, sir, again?

12 Q. BY MR. AUCHINCLOSS: Yes, you may.

13 A. Because -- it may be with exception.

14 Oh, yes, those are my words.

15 Q. All right. So you agree that those are your

16 words.

17 Your Honor, I’d like to admit People’s

18 Exhibit 803 into evidence at this time.

19 MR. MESEREAU: Objection. Hearsay;

20 foundation; relevance.

21 THE COURT: Let me see the exhibit.

22 All right. The objection’s sustained. It’s

23 not going into evidence.

24 MR. AUCHINCLOSS: All right. May I see

25 that?

26 Q. But so that we’re clear today about your

27 testimony, is it true that you looked at what was

28 going on with the king and the boy, they were 5559



1 holding each other tightly, almost in a romantic

2 sense --

3 MR. MESEREAU: Objection. Asked and

4 answered; move to strike.

5 MR. AUCHINCLOSS: I believe there’s been --

6 THE COURT: Overruled. Go ahead.

7 Q. BY MR. AUCHINCLOSS: “Holding each other

8 tightly almost in a romantic sense, cooing. There

9 were pecks on the cheeks and licks on the top of the

10 head”; is that true, those are your words?

11 A. I -- I -- with reservation. I know about

12 the -- as I told you --

13 Q. I’m asking you are those your words, sir?

14 A. They apparently are my words. If you have

15 them in an e-mail from me.

16 Q. Today your testimony is that, “The licking

17 is going to be important,” you told Stacy that,

18 “because it happened in this case, too.” Those are

19 your words as well?

20 A. I don’t recall saying anything about this

21 case. But if it was in an e-mail, I said it.

22 Q. You acknowledge that those words -- that

23 this is your e-mail address?

24 A. B7436@aol --

25 Q. And this is -- you acknowledged this is one

26 of your e-mails to Stacy Brown?

27 A. Nobody else could have done it but me.

28 Q. So do you acknowledge, based upon all the 5560



1 information that you have today, that you did, in

2 fact, see Michael Jackson lick Jordie Chandler on

3 the top of the head, sir? Yes or no.

4 MR. MESEREAU: Objection; asked and

5 answered.

6 THE WITNESS: I guess -- yes.

7 MR. AUCHINCLOSS: All right.

8 THE COURT: Just a moment. There was an

9 objection.

10 MR. AUCHINCLOSS: Sorry.

11 THE COURT: The objection is overruled. The

12 answer was, “Yes.”

13 Q. BY MR. AUCHINCLOSS: And your testimony is

14 that this incident happened on a plane flying back

15 from Europe?

16 A. On flying back from Paris to Los Angeles.

17 MR. AUCHINCLOSS: Thank you. I have no

18 further questions.

19

20 RECROSS-EXAMINATION

21 BY MR. MESEREAU:

22 Q. Mr. Jones, on April 7th, you told the police

23 and Mr. Auchincloss you’d be lying if you said you

24 saw Mr. Jackson licking Mr. Chandler, right?

25 MR. AUCHINCLOSS: Objection. Misstates the

26 evidence and argumentative.

27 THE COURT: Overruled.

28 You may answer. Do you want the question 5561



1 read back?

2 THE WITNESS: I would say since he -- I have

3 to say it has to be true if it came in my e-mail.

4 Q. BY MR. MESEREAU: But, sir, you just told

5 the police the other day that you’d be lying if you

6 said he did that, right?

7 MR. AUCHINCLOSS: Same objections.

8 THE COURT: Overruled.

9 Q. BY MR. MESEREAU: Right?

10 A. I -- I, again, have to say what I said. If

11 it’s in my e-mail, it’s true.

12 Q. But you just told the jury you don’t recall

13 seeing something like that, correct?

14 MR. AUCHINCLOSS: Objection. Asked and

15 answered; argumentative.

16 THE COURT: Overruled.

17 THE WITNESS: I go back with the same

18 answer. It was in my e-mail. So if it was in my

19 e-mail, I’m taking responsibility for the e-mail.

20 Q. BY MR. MESEREAU: Well, but you’ve also

21 indicated a number of the things you wrote are not

22 accurate, true?

23 A. I didn’t write anything. My co-writer wrote

24 those things. But he is -- he has shown me an

25 e-mail that I wrote and sent to my co-writer.

26 Q. But, sir, you just told the jury what you

27 told the police last week, which is that you’d be

28 lying if you said you saw that, right? 5562



1 MR. AUCHINCLOSS: I believe that misstates

2 the evidence.

3 THE COURT: Overruled.

4 Is that what -- he’s really asking you, “Is

5 that what you told the police?” Did you tell the

6 police --

7 THE WITNESS: Yes, that is what I told the

8 police.

9 MR. MESEREAU: No further questions.

10

11 FURTHER REDIRECT EXAMINATION

12 BY MR. AUCHINCLOSS:

13 Q. Mr. Jones, you didn’t say, “I would be lying

14 if I said that.” You said, “I would be lying if I

15 said I remembered that”; isn’t that true?

16 A. Yes, I did.

17 Q. And is it fair to say that based on

18 everything you have before you today, you now

19 remember the incidents that you’ve testified

20 concerning the licking?

21 A. I don’t remember. But there is an e-mail

22 which provides explicit evidence that the e-mail

23 came from me.

24 Q. And you believe your e-mails are true;

25 you’ve testified to that?

26 A. I would not have just made it up.

27 MR. AUCHINCLOSS: Thank you.

28 THE WITNESS: Okay. 5563



1 MR. MESEREAU: No further questions.

2 THE COURT: All right. Thank you. You may

3 step down.

4 MR. AUCHINCLOSS: Thank you, Your Honor.

5 Subject to re-call.

6 THE COURT: All right. I haven’t excused

7 him.

8 MR. AUCHINCLOSS: I’m sorry.

9 THE COURT: Call your next witness.

10 MR. AUCHINCLOSS: Call Stacy Brown.

11 THE COURT: When you get to the witness

12 stand, please remain standing.

13 Face the clerk, over here, and raise your

14 right hand.

15

16 STACY BROWN

17 Having been sworn, testified as follows:

18

19 THE WITNESS: Yes.

20 THE CLERK: Please be seated. State and

21 spell your name for the record.

22 THE WITNESS: Stacy Brown. S-t-a-c-y;

23 Brown, B-r-o-w-n.

24 THE CLERK: Thank you.

25

26 DIRECT EXAMINATION

27 BY MR. AUCHINCLOSS:

28 Q. Good morning, Mr. Brown. 5564



1 A. Good morning.

2 Q. What is your occupation, sir?

3 A. I’m -- currently I’m an analyst for MS-NBC

4 and I’m also an author.

5 Q. All right. As an author, have you had

6 occasion to collaborate with writers in the creation

7 of books?

8 A. Oh, yes, several.

9 Q. Can you give me an example?

10 A. Well, in 2002, published by Simon &

11 Schuster, I co-authored the book Blind Faith, a

12 biography of Stevie Wonder and his mom, Lula

13 Hardaway.

14 Q. Have you worked in the past to --

15 collaborated in the past with any members of the

16 family of Michael Jackson in the creation of books?

17 A. Yes, I have.

18 Q. Who would that be?

19 A. That would be his older sister, Rebbie

20 Jackson, and his brother Jermaine Jackson.

21 Q. And when I say “Mr. Jackson,” is he the man

22 seated to my right with the long black hair?

23 A. Yes.

24 Q. Were those -- was there ever any attempt to

25 publish those two books that you just described?

26 A. The latter two, Rebbie and Jermaine?

27 Q. Yes.

28 A. That I -- there was -- 5565



1 Q. Were they published?

2 A. No, they was not published.

3 Q. Do you know why not?

4 A. Well, the last one with --

5 MR. MESEREAU: Objection; calls for

6 speculation.

7 THE COURT: Sustained.

8 Q. BY MR. AUCHINCLOSS: Were those books,

9 either of them, pulled from the publisher by you?

10 A. Yes.

11 Q. Why?

12 A. At the direction of --

13 MR. MESEREAU: Objection. Relevance;

14 foundation.

15 THE COURT: Sustained.

16 Q. BY MR. AUCHINCLOSS: May I ask foundation or

17 relevance, Your Honor?

18 THE COURT: The relevance.

19 MR. AUCHINCLOSS: All right.

20 Q. Mr. Brown, did you collaborate with Bob

21 Jones or are you collaborating with Bob Jones in the

22 writing of a book concerning his experiences as an

23 employee of Michael Jackson?

24 A. That’s correct.

25 Q. How long have you been doing that?

26 A. Since last summer.

27 Q. How did you meet Bob Jones?

28 A. I met Bob years ago. He was, of course, 5566



1 working for Michael. I was a reporter for the L.A.

2 Daily News at the time, and we were covering a story

3 about Michael’s -- the birth of Michael’s first

4 child. And I had talked about -- everyone had

5 talked about, everyone in the media, when they want

6 information or comments from Michael on things

7 that -- like having a baby.

8 Q. Who approached whom concerning the writing

9 of this book?

10 A. Last January during the arraignment here,

11 Bob Jones approached me -- we were both standing

12 outside that day, and he approached me about writing

13 that book.

14 Q. And you’ve worked together to prepare a

15 manuscript?

16 A. Yeah, we did. And we didn’t -- you know, I

17 didn’t initially agree to write the book.

18 Q. Okay.

19 A. There was some concerns that I had. I

20 didn’t want to --

21 MR. MESEREAU: Objection; nonresponsive.

22 MR. AUCHINCLOSS: That’s fine.

23 THE COURT: Sustained.

24 Q. BY MR. AUCHINCLOSS: So did you originally

25 want to write this book?

26 A. Not originally, no.

27 Q. Why not?

28 A. Well, I knew -- 5567



1 MR. MESEREAU: Objection. Relevance; calls

2 for speculation.

3 THE COURT: Sustained.

4 MR. AUCHINCLOSS: It goes to -- offered as

5 credibility.

6 THE COURT: The objection is sustained.

7 Q. BY MR. AUCHINCLOSS: Tell me about the

8 collaboration process with Mr. Jones. How has this

9 book come together?

10 A. Well, I interviewed Bob, another writer also

11 interviewed Bob as well, about his experience, not

12 only with Michael. We have to remember Bob worked

13 with a lot of people including Lionel Ritchie, Rick

14 James, Barry Gordy, the Jacksons as a family.

15 Q. Uh-huh.

16 A. So Michael was -- and Bob’s mind was seen as

17 just a small part of his story, but obviously the

18 publisher wanted more about Michael because he is

19 Michael.

20 Q. When you’re collaborating with an individual

21 in the preparation of a manuscript, are there -- is

22 there a dialogue with publishers to see what kind of

23 book the publisher will be interested in?

24 A. Oh, absolutely.

25 Q. And do you employ a literary agent to try --

26 A. Yes.

27 Q. -- and market the book?

28 A. Yes. And in this particular case, we 5568



1 employed quite a few.

2 Q. Why is that?

3 A. Well, Bob has problems trusting people.

4 MR. MESEREAU: Objection; relevance.

5 MR. AUCHINCLOSS: I can withdraw that.

6 THE COURT: All right. I’ll strike his

7 answer. You can rephrase the question.

8 MR. AUCHINCLOSS: That’s fine.

9 Q. How many agents did you work with?

10 A. Gosh. It’s now -- five now.

11 Q. And you currently -- are you currently

12 employing an agent?

13 A. Yes, we are. We are currently employing

14 two.

15 Q. And what are their names?

16 A. Neil Gudovitz and Bill Gladstone.

17 Q. In working with Mr. Jones, how did you

18 communicate with one another?

19 A. We spoke a lot over the phone. We met in

20 person. And a lot of times, because of the

21 distance, we e-mailed each other.

22 Q. And so how would it work in terms of his

23 working with you?

24 A. What would happen is he would send me an

25 e-mail of a lot of his notes that he had kept over

26 the years. We would talk about them, and then I’d

27 start writing. And I would send him what I write,

28 and he would have to approve it, and then he would 5569



1 send it back with any type of changes that needed to

2 be made, and the changes would be -- then be made.

3 MR. AUCHINCLOSS: If I may approach, Your

4 Honor.

5 THE COURT: Yes.

6 Q. BY MR. AUCHINCLOSS: Mr. Jones -- or Mr.

7 Brown, I show you People’s Exhibit 803. Could you

8 identify those two passages for me?

9 MR. MESEREAU: Objection to the extent it

10 calls for hearsay.

11 THE COURT: Overruled. I’ll allow him to

12 identify them.

13 THE WITNESS: By “identify,” read them?

14 Q. BY MR. AUCHINCLOSS: No, just identify them.

15 Are those two passages that came from the book that

16 you’re working on with Mr. Jones?

17 A. That’s correct, yes.

18 Q. And while I’m up here, I’m going to show you

19 People’s Exhibit 804. Can you identify that for me?

20 A. An e-mail Bob Jones sent to me.

21 Q. You personally received that from Mr. Jones?

22 A. That’s correct.

23 Q. And an e-mail --

24 A. That’s correct. Another e-mail.

25 Q. That’s Exhibit 805. That’s one he sent you

26 as well?

27 A. That’s correct.

28 Q. Now, for the record, are these complete 5570



1 e-mails or did they have some material?

2 A. Oh, they had a lot of material.

3 Q. But this is just a portion of them?

4 A. Yeah.

5 Q. All right. Did Bob Jones, during your

6 collaboration with him in the writing of this book,

7 tell you about an incident in which he observed the

8 defendant, Michael Jackson, lick a boy by the name

9 of Jordie Chandler on the head?

10 MR. MESEREAU: Objection. Hearsay; and

11 leading.

12 MR. AUCHINCLOSS: Offered under 1236.

13 THE COURT: The objection is overruled.

14 THE WITNESS: I’m sorry.

15 THE COURT: Just answer that “yes” or “no.”

16 THE WITNESS: Yeah. Yes, he did.

17 Q. BY MR. AUCHINCLOSS: What did he tell you?

18 MR. MESEREAU: Objection; hearsay.

19 THE COURT: Overruled.

20 You may answer.

21 THE WITNESS: Well, he described an

22 incident, they were going to the World Music Awards

23 in Monaco, I believe it was. And he talked about

24 how strange it was, because Jordie had a head full

25 of hair, and he said, “I thought maybe it would be

26 more” -- you know, “It would be understandable if he

27 had a bald head.” But he just couldn’t understand

28 the licking of the head when he had a head full of 5571



1 hair.

2 Q. BY MR. AUCHINCLOSS: He said he saw Michael

3 Jackson lick Jordie’s head?

4 A. Correct.

5 Q. Those two passages that I showed you in

6 Exhibit 803, did you ever share that manuscript that

7 contained those passages with Mr. Jones?

8 A. Oh, yeah. Absolutely. Bob had to approve

9 everything that went to the publisher.

10 Q. So everything that went to the publisher was

11 approved by Mr. Jones?

12 A. That’s correct.

13 Q. And did this -- did those two passages that

14 I just showed you go to the publisher?

15 A. Oh, yeah.

16 Q. Did you discuss this issue of the licking

17 incident on more than one occasion?

18 A. Oh, yes, we did. Do you want me to --

19 Q. Go ahead.

20 A. Yeah, we did. Beginning in, I would say,

21 maybe August or September, he and I discussed it.

22 And we discussed it with another writer, Dennis

23 love, and also our agent and the publisher.

24 Q. Okay. You previously mentioned Neil

25 Gudovitz and Bill Gladstone. Was it discussed with

26 those two gentlemen?

27 A. Yes.

28 Q. And your publisher, who would that be? 5572



1 A. That would be Select Books.

2 Q. Okay. Specifically who was this issue

3 discussed with?

4 A. Well, it was discussed not only with --

5 well, specifically at Select Books?

6 Q. Yes. And I mean by Mr. Jones himself.

7 A. We had -- well, I don’t know that Bob

8 discussed it with Select. But we discussed it with

9 Simon & Schuster and Harper Collins in a conference

10 call that we had. Bob discussed it with them. They

11 discussed the entire -- the entire proposal that we

12 put before them, and that included that.

13 Q. All right. This e-mail that I showed you,

14 804 - I’ll show it to you again just so you’re

15 familiar with what I’m talking about - references

16 that, “The licking is going to be important because

17 he did it in this case, too.”

18 Can you tell me, what was the context of

19 that remark?

20 MR. MESEREAU: Objection. Relevance;

21 foundation; and calls for hearsay.

22 THE COURT: Sustained.

23 Q. BY MR. AUCHINCLOSS: What did you understand

24 he was referring to when he said, “this case, too”?

25 MR. MESEREAU: Objection. Foundation;

26 relevance.

27 THE COURT: Overruled.

28 Excuse me. Sustained. 5573



1 Q. BY MR. AUCHINCLOSS: Did you stay abreast of

2 the information in the media during the writing of

3 this book?

4 A. Yeah, I had to. It’s my job.

5 Q. Okay. Did you -- did you check the Internet

6 sources of news media?

7 A. Yeah. I look at different newspapers and

8 news outlets throughout the country, and their take

9 on what’s going on as well.

10 Q. And on October 30th, 2004, had you ever

11 heard of any kind of licking that had gone on in the

12 case of People v. Michael Jackson that’s presently

13 before the Court?

14 MR. MESEREAU: Objection. Relevance;

15 foundation; hearsay.

16 MR. AUCHINCLOSS: In the media outlets.

17 MR. MESEREAU: Improper hearsay.

18 THE COURT: I guess I’m not sure where you’re

19 going with what his knowledge is of this case, how

20 that relates to what Mr. Jones has said.

21 MR. AUCHINCLOSS: Whether it had been

22 reported in the media from another source - he says

23 he kept abreast of all the media sources - or

24 whether this was the first time he’d heard it.

25 THE COURT: All right. If you’ll rephrase

26 the question to relate to the relevance that you’re

27 describing.

28 MR. AUCHINCLOSS: Okay. 5574



1 Q. My question is this, Mr. Brown: When Mr.

2 Jones wrote you this e-mail on October 30th, were

3 you aware at that time that there was an allegation

4 of licking in the case involving Gavin Arvizo and

5 Mr. Jackson?

6 A. I can’t say that --

7 MR. MESEREAU: Objection; foundation.

8 THE COURT: The objection is overruled.

9 Q. BY MR. AUCHINCLOSS: All right. Go ahead.

10 A. I can’t say that I was, because I -- when

11 Bob told me, it was the first that I’d heard of the

12 incident. He had actually heard it first as it

13 pertains to this case, and that’s when -- that

14 prompted him to share with me that it was going to

15 be important.

16 Q. Now, he says in that e-mail, “The licking is

17 going to be important because he did it in this

18 case, too.” Was that the first time you heard of

19 the connection between the two --

20 A. Yes.

21 Q. -- cases?

22 Had he talked to you about the licking

23 before that?

24 A. We had started discussing --

25 MR. MESEREAU: Objection. Relevance;

26 foundation; hearsay.

27 THE COURT: I’ll overrule the objection.

28 But the question is simply whether or not he 5575



1 discussed this with you before that e-mail.

2 Q. BY MR. AUCHINCLOSS: So that’s a “yes” or

3 “no.”

4 A. That particular e-mail?

5 Q. Yeah, before that e-mail.

6 A. The e-mail, no. The incident, yeah.

7 Q. Okay, the incident. He discussed it before

8 that e-mail?

9 A. Yeah.

10 Q. Has Mr. Jones ever indicated to you a fear

11 of testifying in this case?

12 MR. MESEREAU: Objection. Foundation;

13 relevance; calls for speculation; move to strike.

14 THE COURT: Sustained. The objection is

15 sustained. Stricken.

16 Q. BY MR. AUCHINCLOSS: Was there a period of

17 time when Mr. Jones all of a sudden began to have a

18 loss of recollection or something of that nature

19 regarding this licking incident?

20 MR. MESEREAU: Objection. Leading; calls

21 for speculation.

22 THE COURT: I’ll sustain the objection as the

23 question is too broad.

24 Q. BY MR. AUCHINCLOSS: Okay. At some time

25 during your collaboration with Mr. Jones, did he

26 ever try to deny his recollections about this

27 licking incident?

28 MR. MESEREAU: Objection. Leading; calls 5576



1 for speculation; relevance; foundation.

2 THE COURT: I’ll overrule the objection. The

3 question should be read back to the witness.

4 (Record read.)

5 THE WITNESS: Yeah. He had fuzzy

6 recollections about it, yes.

7 Q. BY MR. AUCHINCLOSS: Was there --

8 THE COURT: Just a moment. We’re going to

9 take our break.

10 (Recess taken.)

11 --o0o--

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 5577



1 REPORTER’S CERTIFICATE

2

3

4 THE PEOPLE OF THE STATE )

5 OF CALIFORNIA, )

6 Plaintiff, )

7 -vs- ) No. 1133603

8 MICHAEL JOE JACKSON, )

9 Defendant. )

10

11

12 I, MICHELE MATTSON McNEIL, RPR, CRR,

13 CSR #3304, Official Court Reporter, do hereby

14 certify:

15 That the foregoing pages 5521 through 5577

16 contain a true and correct transcript of the

17 proceedings had in the within and above-entitled

18 matter as by me taken down in shorthand writing at

19 said proceedings on April 11, 2005, and thereafter

20 reduced to typewriting by computer-aided

21 transcription under my direction.

22 DATED: Santa Maria, California,

23 April 11, 2005.

24

25

26

27 MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304

28 5578



1 SUPERIOR COURT OF THE STATE OF CALIFORNIA

2 IN AND FOR THE COUNTY OF SANTA BARBARA

3 SANTA MARIA BRANCH; COOK STREET DIVISION

4 DEPARTMENT SM-2 HON. RODNEY S. MELVILLE, JUDGE

5

6

7 THE PEOPLE OF THE STATE OF )

8 CALIFORNIA, )

9 Plaintiff, )

10 -vs- ) No. 1133603

11 MICHAEL JOE JACKSON, )

12 Defendant. )

13

14

15

16

17 REPORTER’S TRANSCRIPT OF PROCEEDINGS

18

19 MONDAY, APRIL 11, 2005

20

21 8:30 A.M.

22

23 (PAGES 5579 THROUGH 5770)

24

25

26

27 REPORTED MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304

28 BY: Official Court Reporter 5579



1 APPEARANCES OF COUNSEL:

2

3 For Plaintiff: THOMAS W. SNEDDON, JR.,

4 District Attorney -and-

5 RONALD J. ZONEN, Sr. Deputy District Attorney

6 -and- GORDON AUCHINCLOSS,

7 Sr. Deputy District Attorney 1112 Santa Barbara Street

8 Santa Barbara, California 93101

9

10

11 For Defendant: COLLINS, MESEREAU, REDDOCK & YU BY: THOMAS A. 
MESEREAU, JR., ESQ.

12 -and- SUSAN C. YU, ESQ.

13 1875 Century Park East, Suite 700 Los Angeles, California 90067

14 -and-

15 SANGER & SWYSEN

16 BY: ROBERT M. SANGER, ESQ. 233 East Carrillo Street, Suite C

17 Santa Barbara, California 93101

18 -and-

19 OXMAN and JAROSCAK BY: R. BRIAN OXMAN, ESQ.

20 14126 East Rosecrans Boulevard Santa Fe Springs, California 90670

21

22

23

24

25

26

27

28 5580



1 I N D E X

2

3 Note: Mr. Sneddon is listed as “SN” on index.

4 Mr. Zonen is listed as “Z” on index. Mr. Auchincloss is listed as “A” on index.

5 Mr. Mesereau is listed as “M” on index. Ms. Yu is listed as “Y” on index.

6 Mr. Sanger is listed as “SA” on index. Mr. Oxman is listed as “O” on index.

7

8

9 PLAINTIFF’S WITNESSES DIRECT CROSS REDIRECT RECROSS

10 BROWN, Stacy 5583-M 5593-A 5595-M

11 CHANDLER, June 5596-SN 5658-M 5727-SN 5734-M

12 SWINGLER, Dwayne 5736-A 5754-M 5765-A

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 5581



1 THE COURT: All right. Go ahead.

2 MR. AUCHINCLOSS: Thank you, Your Honor.

3 Q. Mr. Brown, where we left off, I was asking

4 you about this period of time when Mr. Jones started

5 to have some failure of recollection on the issue of

6 head licking.

7 When did that -- do you recall when that

8 began or when that started?

9 A. It’s been about a month or so now.

10 Q. Before that time, how many times had you

11 been involved in a conversation where Mr. Jones

12 talked about the head-licking incident?

13 MR. MESEREAU: Objection; relevance.

14 THE COURT: Overruled.

15 THE WITNESS: I can’t tell you exact number

16 of times, but it was more than a couple.

17 Q. BY MR. AUCHINCLOSS: Okay. And how would

18 you describe this change in his recollection, if you

19 can?

20 MR. MESEREAU: Objection; vague.

21 MR. AUCHINCLOSS: I can be more specific.

22 MR. MESEREAU: Relevance.

23 Q. BY MR. AUCHINCLOSS: My question goes to,

24 was it an abrupt change, or was it something that

25 occurred over a period of time, or something in

26 between?

27 MR. MESEREAU: Objection. Vague; relevance;

28 foundation. 5582



1 THE COURT: Overruled.

2 You may answer.

3 THE WITNESS: I would say it was more abrupt

4 than anything else.

5 MR. AUCHINCLOSS: Thank you, Mr. Brown. I

6 have no further questions.

7 THE COURT: Cross-examine?

8 MR. MESEREAU: Yes, please, Your Honor.

9

10 CROSS-EXAMINATION

11 BY MR. MESEREAU:

12 Q. Good morning, Mr. Brown.

13 A. Good morning.

14 Q. How long have you known Bob Jones?

15 A. The year Princess Diana died. I think it

16 was ‘97.

17 Q. Okay. And approximately when did he tell

18 you he intended to write a book?

19 A. It was about January, a few months before he

20 was terminated.

21 Q. And you’ve been interviewed by the sheriffs

22 in this case, right?

23 A. That’s correct.

24 Q. And you told the sheriffs that Bob Jones

25 told you he’s broke and he needs to make some money,

26 right?

27 A. That’s what --

28 MR. AUCHINCLOSS: Objection; hearsay. 5583



1 THE COURT: Sustained.

2 Q. BY MR. MESEREAU: Have you gone through

3 different drafts with Mr. Jones?

4 A. Yes, I have.

5 Q. On the issue of head licking, did Mr. Jones

6 tell you at one point he had to make money on this

7 book because he had financial problems?

8 MR. AUCHINCLOSS: Objection. Hearsay;

9 argumentative.

10 THE COURT: Overruled.

11 You may answer.

12 THE WITNESS: He didn’t -- Mr. Mesereau, he

13 didn’t tell me that in relation to the head licking.

14 That never came up in discussions of money.

15 Q. BY MR. MESEREAU: But he told you he’s broke

16 and has to get paid for this book, correct?

17 MR. AUCHINCLOSS: Objection. Hearsay;

18 argumentative.

19 THE COURT: Overruled.

20 You may answer.

21 THE WITNESS: When we first started the book,

22 he said he needs the money. He was just fired.

23 Q. BY MR. MESEREAU: And he said he was broke,

24 right?

25 A. Yes. That’s correct.

26 Q. You told the police you said he was broke,

27 right?

28 A. That’s correct. 5584



1 Q. Okay. Now, how did -- how did the -- let me

2 rephrase that.

3 Obviously at some point you met with Bob

4 Jones about writing a book, correct?

5 A. That’s correct.

6 Q. And where did you meet with him?

7 A. Well, as I said earlier, he first approached

8 me here at the court, back during the arraignment.

9 Q. And did he tell you then he wanted to write

10 something?

11 A. That’s correct.

12 Q. And that’s before he --

13 A. That’s before his termination.

14 Q. Okay. And how long before his termination

15 was that, do you think?

16 A. Well, it was January, so -- the termination

17 was in June. So four, five months.

18 Q. And did he tell you he was doing it

19 secretly?

20 A. Well, he didn’t say secretly, but he said --

21 obviously any process with a book, you don’t want

22 everyone to know this is what you are doing.

23 I did, however, myself, tell members of the

24 family, to get their thoughts on it, because that

25 was my concern, what their thoughts may be with me

26 doing a book with Bob Jones with -- chiefly it had

27 to be about Michael Jackson.

28 Q. Okay. Now, did Mr. Jones tell you he was 5585



1 talking to anyone from the sheriff’s department?

2 A. Not at that time, no.

3 Q. When did you first learn that he had spoken

4 to anyone from the sheriff’s department?

5 A. I believe they first contacted him in

6 December of last year.

7 Q. And based on the prosecutor’s questions to

8 you, you must have learned at some point that Bob

9 Jones was saying he couldn’t really remember seeing

10 any head licking, right?

11 MR. AUCHINCLOSS: Objection; hearsay.

12 THE COURT: I’m sorry, I can’t read the --

13 THE REPORTER: “Learned” instead of

14 “render.”

15 THE COURT: All right. The objection is

16 Overruled.

17 You may answer.

18 THE WITNESS: Could you repeat it, sir?

19 MR. MESEREAU: I’ll have it read back. May

20 it be read back, Your Honor?

21 THE COURT: Yes.

22 (Record read.)

23 THE WITNESS: Oh, I wouldn’t say it was

24 based on the prosecutor’s -- that. I think it was

25 simply when I spoke with him, he got a little

26 nervous about that particular vein. I think he

27 realized that it was going to become a part of this

28 -- 5586



1 Q. BY MR. MESEREAU: Well, did you and Mr.

2 Jones discuss the fact that the Arvizos went to

3 Larry Feldman, the same lawyer who represented the

4 Chandlers?

5 A. The --

6 MR. AUCHINCLOSS: Objection. Relevance;

7 beyond the scope; and argumentative.

8 THE COURT: Sustained.

9 Q. BY MR. MESEREAU: Has the name Larry Feldman

10 come up in the book you’re writing?

11 MR. AUCHINCLOSS: Same objection.

12 THE COURT: Overruled.

13 You may answer.

14 THE WITNESS: Not by name, but certainly by

15 title and by inference. Bob did say, based on his

16 notes back in --

17 Q. BY MR. MESEREAU: Well, just -- you just

18 have to answer the question, okay? I’ll get into

19 that --

20 A. Okay.

21 Q. -- okay?

22 Does the book concern this case in any

23 respect?

24 A. I would think in some respects.

25 Q. And is it your plan to market the book while

26 this trial is going on?

27 A. Well, it all depends on when it’s finished.

28 Q. Has he ever talked to you about when he 5587



1 plans to complete the book?

2 A. Well, I have a lot of say in that, so we’ve

3 talked about that, and we’ve always said we don’t

4 want it to be a rush job, and a lot of people want

5 it to be a rush job. The publisher wants it to be a

6 rush job.

7 Q. The publisher wants it to be a rough job --

8 A. Rush job.

9 Q. -- rush job because you can sell it better

10 while the trial is going on, right?

11 A. Obviously, if it comes out now, it would

12 probably pique some interest because it’s Bob Jones,

13 who, you know, has worked for Michael for so long,

14 and it’s Michael.

15 Q. Now, have you discussed the amount of money

16 he might make on the book?

17 A. No, you know, we -- we’ve been made promises

18 in the past. We don’t listen to that. We don’t

19 even speculate on what can be made.

20 Personally, I just enjoy writing, so, you

21 know, the money aspect -- I think I do pretty well.

22 It’s not a big deal to me.

23 Q. Do you remember you were interviewed by a

24 Santa Barbara sheriff on December 7th, 2004?

25 A. Around about, yeah.

26 Q. And you were approached by Sergeant Robel,

27 right?

28 A. Uh-huh. Yes, that’s correct. I’m sorry. 5588



1 Q. And the purpose of the interview was to talk

2 to you about this alleged head-licking event, right?

3 A. I’m not sure if that was the purpose of the

4 interview. We talked about various things back in

5 December, but I’m not sure that was the purpose of

6 it.

7 Q. And do you remember Sergeant Robel wanted to

8 know why you had said that Mr. Jones told you he saw

9 Michael Jackson kiss Jordie, not lick his head?

10 A. Well, that’s not exactly what -- that I

11 remember Sergeant Robel putting to me. There was a

12 question another investigator had had about whether

13 I said he -- Bob said he licked or kissed him, and

14 he wanted me to clarify that.

15 Q. And you had told the investigator that based

16 on your discussions with Bob Jones, he had said that

17 Michael Jackson kissed Jordie one time, didn’t lick

18 his head, right?

19 A. No, I didn’t say that.

20 Q. Do you remember you apologized?

21 A. No, no. What happened -- I apologized if it

22 was confused. But what happened was, I think the

23 investigator had misunderstood and that’s what he

24 was calling to clarify. That’s one of the reasons

25 why he called, to clarify exactly what I said. He

26 said he didn’t remember if I said “licking” or

27 “kissing.”

28 Q. Let me ask you if this is correct. 5589



1 A. Sure.

2 Q. “Brown apologized for the mistake. Said he

3 had not realized that he told me he was kissing as

4 opposed to licking.” Does that sound accurate to

5 you?

6 A. It’s probably accurate. But again, as I’m

7 explaining to you, I explained to Sergeant Robel

8 when he asked the question, when he asked me about

9 that, I had told the other investigator, I think it

10 was Zelis, I’m -- I’m not sure, but I think it was

11 Paul Zelis, the investigator’s name, and I think he

12 was the one who had actually made the mistake or --

13 I won’t even say “mistake.” He wanted to clarify,

14 is that what I said.

15 Q. Why did you apologize to him?

16 A. Well, I apologized for being polite. I

17 mean, it’s just a polite thing to do, you know. If

18 I was wrong, I have no problems apologizing.

19 Q. Now, you’re aware that Mr. Jones has

20 indicated he doesn’t remember head licking and has

21 said he’d be lying to say that he did. Are you

22 aware of that?

23 MR. AUCHINCLOSS: Objection; misstates the

24 evidence.

25 THE COURT: Sustained.

26 Q. BY MR. MESEREAU: You’re in the process of

27 writing the section of the book that deals with this

28 trip to Monaco, aren’t you? 5590



1 A. No. No, we’re long since past that.

2 Q. Well, Mr. Jones has indicated that he has

3 not approved --

4 A. Everything that has --

5 MR. AUCHINCLOSS: Objection. Argumentative;

6 hearsay as to what Mr. Jones said; and misstates the

7 evidence.

8 THE COURT: It’s an incomplete question, too.

9 Q. BY MR. MESEREAU: Mr. Jones has final

10 approval over what’s in that book, doesn’t he?

11 A. Absolutely.

12 Q. Would you agree that the more sensational

13 the book, the better the chance of making money on

14 it?

15 A. Well, obviously. I mean, we’ve been told

16 things that nothing surprises them about Michael

17 Jackson, so -- but it’s not our intentions to write

18 a book of scandal, if that’s what you’re inferring.

19 It’s certainly not mine, and I have to write it.

20 And I have people in his family who I happen to love

21 very much who I’m not going to disappoint.

22 Q. They’re not getting any money from the book,

23 are they?

24 A. The family?

25 Q. Yes.

26 A. Why should they?

27 Q. They’re not getting any money from the book,

28 are they? 5591



1 A. I’m sorry to respond in that way. No.

2 Q. The one who is going to make money is Bob

3 Jones, who’s broke, right?

4 A. We both will.

5 Q. You’re aware that Bob Jones was very upset

6 when he was terminated, aren’t you?

7 A. You know what? To be honest with you, he

8 wasn’t upset that he was terminated. He was upset

9 in which the way Randy terminated him.

10 Q. I’m not sure what that means.

11 A. Well, Bob had --

12 Q. Referring to Randy Jackson, right?

13 A. Randy Jackson, I’m sorry.

14 Bob had felt he’d been loyal to Michael for

15 basically half of Michael’s life, or most of

16 Michael’s life, I should say. And to get fired by a

17 messenger, you know, I felt bad, too. In fact, I

18 had spoke to someone in Michael’s family about that.

19 I said, “That’s horrible.”

20 But he was just upset in the method. He

21 knew that eventually his time was going to be up

22 just like everyone else’s.

23 Q. In the draft that you and Mr. Jones have

24 written, Mr. Jones says on at least two occasions

25 that he’s never seen Michael Jackson act

26 inappropriately with children, right?

27 MR. AUCHINCLOSS: Objection; hearsay.

28 THE COURT: Overruled. 5592



1 You may answer.

2 THE WITNESS: Well, if it was the exact --

3 well, I don’t remember the exact wording, but to say

4 that he saw him molest anybody, no, it does not say

5 he saw him molest anybody.

6 MR. MESEREAU: I have no further questions,

7 Your Honor.

8

9 REDIRECT EXAMINATION

10 BY MR. AUCHINCLOSS:

11 Q. Mr. Jones (sic), I previously showed you

12 People’s Exhibit 803. Did Mr. Jones approve those

13 two passages?

14 A. Yes.

15 MR. AUCHINCLOSS: Ask to move 803 into

16 evidence.

17 MR. MESEREAU: Objection. Hearsay;

18 foundation.

19 THE COURT: Sustained.

20 MR. MESEREAU: Relevance.

21 MR. AUCHINCLOSS: Offered as a prior

22 inconsistent statement as to the first passage and a

23 prior consistent statement as to the second.

24 MR. MESEREAU: Same objection.

25 THE COURT: The ruling remains the same.

26 MR. AUCHINCLOSS: All right. Ask at this

27 time to admit the two e-mails, Your Honor, Exhibits

28 804 and 805, into evidence at this time. 5593



1 MR. MESEREAU: Objection. Hearsay;

2 foundation; authenticity; relevance.

3 THE COURT: I’ll take that up later.

4 MR. AUCHINCLOSS: Okay.

5 Q. Mr. Brown, you said that Mr. Jones was

6 complaining about his finances on cross-examination.

7 A. Uh-huh. Yes.

8 Q. Is this a frequent complaint?

9 A. Yeah, he’s -- well, yeah, he’s made a few

10 complaints about that.

11 Q. Was there a time when he stopped complaining

12 about his finances during this period of

13 collaboration?

14 A. Yes.

15 Q. Was what -- when -- when he stopped

16 complaining about finances, tell me, was there any

17 relationship in time to that point and the time in

18 which he started to have this failure of

19 recollection?

20 MR. MESEREAU: Objection. Relevance; vague;

21 foundation.

22 THE COURT: I’ll sustain vague.

23 Q. BY MR. AUCHINCLOSS: Can you tell me

24 approximately when in time Mr. Jones stopped

25 complaining about his finances?

26 A. It’s been about a month or so.

27 Q. And when in time did he start to have his

28 failure of recollection? 5594



1 A. About a month or so.

2 Q. Did they -- did both of those coincide in

3 time?

4 A. I would say so, yes.

5 MR. AUCHINCLOSS: Thank you. I have no

6 further questions.

7

8 RECROSS-EXAMINATION

9 BY MR. MESEREAU:

10 Q. Mr. Brown, what I think the prosecutor just

11 elicited is the following: When he was broke, he

12 said there was licking. And when he didn’t have

13 financial problems, he said there wasn’t any, right?

14 A. Well, if that’s how you --

15 Q. Right?

16 A. -- break it down, yeah, I guess.

17 MR. MESEREAU: Thank you.

18 MR. AUCHINCLOSS: No further questions.

19 THE COURT: Thank you. You may step down.

20 Would you give me Exhibits 804 and 805?

21 Call your next witness.

22 MR. SNEDDON: June Chandler, Your Honor.

23 THE BAILIFF: She’s on her way, Your Honor.

24 THE COURT: 804 and 805 are not admitted.

25 Come forward, please. When you get to the

26 witness stand here, remain standing.

27 Face the clerk here and raise your right

28 hand. 5595



1 JUNE CHANDLER

2 Having been sworn, testified as follows:

3

4 THE WITNESS: I do.

5 THE CLERK: Please be seated. State and

6 spell your name for the record.

7 THE WITNESS: June Chandler. J-u-n-e;

8 C-h-a-n-d-l-e-r.

9 THE CLERK: Thank you.

10 THE WITNESS: You’re welcome.

11

12 DIRECT EXAMINATION

13 BY MR. SNEDDON:

14 Q. Good morning, Mrs. Chandler.

15 A. Good morning.

16 Q. I want to go back in time a little bit to

17 around 1992 and ‘93, okay?

18 A. Yes.

19 Q. And are you related in some fashion to

20 Jordan Chandler?

21 A. Yes. He is my son.

22 Q. Okay. And we’re going -- you know, I should

23 have done this before we started.

24 A. Yes.

25 Q. You have to lean right into that microphone

26 so everybody can hear what you have to say. We’ve

27 had the same problem with everybody, so it’s not

28 just you. 5596



1 A. Okay.

2 Q. You have a very soft voice, so you keep it

3 up, all right?

4 A. Okay. I will.

5 Q. Let me start all over again and ask you

6 again. Are you related to Jordan Chandler?

7 A. Yes, I am. He is my son.

8 Q. Do you have any other sons or daughters?

9 A. Yes, I have a daughter.

10 Q. And her name?

11 A. Lily Chandler.

12 Q. And how old is Lily right now?

13 A. 17 years old.

14 Q. Now, in 1992 and 1993, were you married?

15 A. Yes, I was.

16 Q. And to whom were you married?

17 A. To David Schwartz.

18 Q. And is David Schwartz the father of either

19 of your children?

20 A. Yes.

21 Q. Which one?

22 A. Lily Chandler.

23 Q. And prior to your marriage with David

24 Schwartz, you were married to Evan Chandler,

25 correct?

26 A. Correct.

27 Q. And Evan Chandler is the father of Jordan

28 Chandler? 5597



1 A. Correct.

2 Q. What is Jordan’s date of birth?

3 A. January 11th, 1980.

4 Q. And to your knowledge, had -- by the time of

5 the events in 1992 and ‘93, had Evan Chandler

6 remarried?

7 A. Yes.

8 Q. And do you know his wife or did you know his

9 wife at that time?

10 A. Yes, I did.

11 Q. And her name is?

12 A. Natalie Chandler.

13 Q. And did they have any other children?

14 A. Yes, they did.

15 Q. And the child’s name?

16 A. Nicky Chandler. And Emmanuelle Chandler.

17 Q. And at the time of 1992 and 1993, can you

18 give us the approximate ages of those children?

19 A. As best as I can recall, seven and four.

20 Q. And who is the oldest?

21 A. Nicky Chandler, the son.

22 Q. Okay. Now, I want to show you some

23 photographs. The first photograph we have that’s

24 marked is 793, the next one is 794, and the next one

25 is 795, okay?

26 The first one, 793, I’ll ask you if you

27 recognize the person depicted in that photograph?

28 A. No, I do not. 5598



1 Q. Have you ever seen that person before?

2 A. Not that I recall.

3 Q. And I want to show you a photograph marked

4 as 794, or Exhibit 794. Do you recognize the people

5 depicted in that photograph?

6 A. Not that I recall.

7 Q. Neither the top nor the bottom?

8 A. He might look familiar.

9 Q. Okay. And the bottom photograph?

10 A. I don’t recall.

11 Q. And with regard to Exhibit No. 795, do you

12 recognize any of the people depicted in that

13 photograph?

14 A. I recall this boy and Michael Jackson.

15 Q. All right. “This boy” meaning the person on

16 the far left-hand side of the Exhibit 795?

17 A. Correct.

18 Q. And do you recall the boy’s name?

19 A. Brett Barnes.

20 Q. Do you recall where you saw Mr. Barnes, or

21 the child Barnes?

22 A. At Neverland.

23 Q. Okay. So with regard to the Photographs

24 793, 794 and 795, none of those photographs are

25 pictures of your son, correct?

26 A. No. No.

27 Q. I want to show you 776; ask you if you

28 recognize that photograph? 5599



1 A. Yes, I do.

2 Q. And who is that?

3 A. That’s my son.

4 Q. Your son?

5 A. Jordan.

6 Q. All right. Thank you.

7 Your Honor, with the Court’s permission, I’d

8 like to publish these just so the jury knows what

9 the witness has testified to.

10 THE COURT: Yes.

11 MR. SNEDDON: And we’re going to do it on

12 the Elmo, Your Honor. So if we could have that.

13 All right, Gordon?

14 Q. All right. The photograph that’s on the

15 board that’s 793 is an exhibit of the child with the

16 long black hair. And that is not your son, Jordan

17 Chandler?

18 A. No, it’s not.

19 Q. All right. And the next exhibit would be

20 794. And specifically I’m going to direct your

21 attention to the child sitting on the floor with the

22 arrow drawn up to him. Do you recognize that child?

23 A. Barely.

24 Q. Who do you think that -- when you say

25 “barely,” who do you recognize --

26 A. I would say it’s probably a younger photo of

27 the boy above.

28 Q. And do you recognize who the boy above in 5600



1 that photograph is?

2 A. I think that’s Brett Barnes.

3 Q. Okay. And the last photo is 795. And you

4 indicated the child on the far left-hand side of the

5 photograph; is that correct?

6 A. Correct.

7 Q. The child with the hat next to Mr. Jackson?

8 A. Correct. That’s Brett Barnes.

9 Q. That’s Brett Barnes. All right. Thank you.

10 And lastly, the photograph marked as 776,

11 you’ve identified that as your child, Jordan,

12 correct?

13 A. My son Jordan.

14 Q. Your son Jordan?

15 A. Yes.

16 Q. All right. Thank you.

17 We can have the lights again, Your Honor.

18 Now, Mrs. Chandler, do you recognize the

19 defendant in this case, Michael Jackson?

20 A. I do.

21 Q. And have you been in Mr. Jackson’s presence

22 before?

23 A. Yes.

24 Q. Now, your son Jordan, did you have -- let me

25 go back in time. Did you have an occasion where you

26 actually met Michael Jackson?

27 A. Yes, I had an occasion.

28 Q. For the first time? 5601



1 A. Yes.

2 Q. Would you tell the ladies and gentlemen of

3 the jury, where did that occur?

4 A. That occurred at my ex-husband’s employment,

5 Rent-A-Wreck.

6 Q. And where is that located?

7 A. In West L.A.

8 Q. And was -- do you remember about

9 approximately when that occurred?

10 A. It was in the summer of ‘92. Late summer.

11 Q. And were you actually at the -- your

12 husband’s place of business when Mr. Jackson showed

13 up?

14 A. After he showed up, yes.

15 Q. Okay. You received a telephone call from

16 someone?

17 A. Yes, from my ex-husband.

18 Q. And by the way, your ex-husband’s name is

19 what?

20 A. David Schwartz.

21 Q. Did you ever take Mr. Schwartz’s last name?

22 A. No, I did not.

23 Q. So you’ve always been June Chandler?

24 A. I’ve always been June Chandler.

25 Q. So you received a telephone call and then

26 you went down to his place of business?

27 A. Yes, I did.

28 Q. With regard to your son Jordan, did Jordan 5602



1 go with you?

2 A. Yes, he did.

3 Q. Was Mr. Jackson there?

4 A. Yes, he was.

5 Q. And do you recall how long you were with Mr.

6 Jackson and Jordan that day?

7 A. Briefly. Five minutes. Ten minutes.

8 Q. And did -- was there any information

9 exchanged between you and Mr. Jackson that day?

10 A. Yes.

11 Q. And what was that?

12 A. I said, “If you would like to see Jordie or

13 if he could call you or if you’d like to speak to

14 him, here is our number, and you can give him a

15 call.”

16 Q. And you gave that to Mr. Jackson?

17 A. Yes, I did.

18 Q. Now, let me go back in time. Before this

19 meeting that you had at your husband’s place of

20 business in 1992, had Jordan ever expressed, to your

21 knowledge, some admiration for Mr. Jackson?

22 A. Oh, very much so, yes.

23 Q. How did he display that admiration?

24 MR. MESEREAU: Objection; hearsay.

25 MR. SNEDDON: I didn’t ask for a statement,

26 Your Honor. I asked for a display.

27 THE COURT: All right.

28 He’s not asking for anything that was said. 5603



1 Do you understand the question?

2 THE WITNESS: Would you repeat the question,

3 please?

4 Q. BY MR. SNEDDON: Yes.

5 How did your son Jordan, prior to this

6 meeting that occurred at David Schwartz’s place of

7 business, express -- display his admiration for Mr.

8 Jackson?

9 A. He had a little sparkly jacket that he would

10 wear to parties. He would have a glove like Michael

11 Jackson, and dance around like Michael Jackson.

12 Q. And this was all before he met Mr. Jackson?

13 A. Before he met Michael Jackson, yes.

14 Q. Now, after the incident occurred where there

15 was an exchange where you gave Mr. Jackson your

16 telephone number -- and let me go back and ask you a

17 question about that. Was the telephone number you

18 gave him your home number?

19 A. Yes, it was.

20 Q. Did -- to your knowledge, did Mr. Jackson

21 ever call your son Jordan?

22 A. Yes, he did.

23 Q. And do you recall, for the ladies and

24 gentlemen of the jury, approximately what the time

25 span was from the incident that occurred at your

26 ex-husband’s place of business to the time that Mr.

27 Jackson actually called your son?

28 A. To the best of my recollection, it could 5604



1 have been a month or two after our first meeting

2 with Michael Jackson at Rent-A-Wreck.

3 Q. Were you actually in the room when Mr.

4 Jackson called?

5 A. I don’t recall being in the room, but I

6 might have been.

7 Q. Do you recall at some time visiting

8 Neverland Ranch?

9 A. Yes, I do.

10 Q. Do you recall approximately when that

11 occurred?

12 A. I recall around February.

13 Q. Of?

14 A. 1993.

15 Q. 1993?

16 A. Yes.

17 Q. So what I want to ask you is, between the

18 time that Mr. Jackson started calling your son to

19 the time that you went to Neverland Ranch, can you

20 give the jury some idea of the number of times Mr.

21 Jackson called your son Jordan?

22 A. To the best of my recollection --

23 MR. MESEREAU: Objection; foundation.

24 THE COURT: Sustained.

25 Q. BY MR. SNEDDON: Were you present in the

26 house when these conversations occurred?

27 A. Yes, I was.

28 Q. Did you sometimes answer the phone? 5605



1 A. Yes.

2 Q. And Mr. Jackson was on the line?

3 A. Yes, he was.

4 Q. And were you also present in the house

5 during the time to observe the length of the

6 conversations between your son and Mr. Jackson?

7 A. Yes, I was.

8 Q. On more than one occasion?

9 A. Absolutely.

10 Q. All right. So based upon your observations

11 and the things that you saw and the things that you

12 heard, give us an estimate of the number of times,

13 that you know of, that Mr. Jackson called your son

14 Jordan.

15 A. I would say eight to ten times.

16 Q. And with regard to those conversations in

17 which you have personal knowledge of the length of

18 time, could you give the jury some idea of how long

19 these conversations lasted?

20 A. It was from maybe ten minutes, to an hour,

21 or an hour and a half. It progressed. It got

22 longer and longer.

23 Q. Could you describe to the jury what your

24 son’s reaction was to these phone calls?

25 A. He was excited to hear from him. They were

26 talking about things that interested Jordie, so,

27 um --

28 Q. In those occasions where you picked up the 5606



1 phone and you talked to Mr. Jackson, did he tell you

2 where he was?

3 A. No, he didn’t tell me. No.

4 Q. Now, how is it that you and Jordan ended up

5 going to Neverland Valley Ranch for the first time?

6 A. We were invited to go to Neverland, because

7 during those conversations, Michael Jackson said,

8 “Would you like to come to visit? When I am

9 finished touring,” he was doing a European tour, I

10 think, he said we can come and visit. And my son

11 was very excited to be able to go up there and see

12 Neverland.

13 Q. Now, the first time you went to Neverland,

14 you told the jury it was sometime in February of

15 1993. How did you get there?

16 A. I drove.

17 Q. And who went with you besides Jordan, if

18 anyone?

19 A. My daughter Lily.

20 Q. And at this point in time, how old was Lily?

21 A. Was seven, I think. Seven or eight.

22 Q. And Jordan was born in 1980, so he was 13

23 years old at the time you made the first visit,

24 correct?

25 A. 12, 13, yes. Yes.

26 Q. And do you recall whether it was during the

27 week or on a weekend that you visited?

28 A. On a weekend. 5607



1 Q. During the time that you were -- during this

2 first visit, do you recall how many days you were

3 there?

4 A. Oh, two nights.

5 Q. Okay. So two nights and at least two days

6 and possibly a third day?

7 A. Two nights. There was not a third day.

8 Q. And where did you stay while you were at the

9 ranch?

10 A. Guest cottage.

11 Q. Where did you personally stay?

12 A. The guest cottages at Neverland.

13 Q. And was there somebody in your cottage with

14 you?

15 A. Yes, my daughter and my son.

16 Q. So Jordan stayed with you and Lily in the

17 same cottage?

18 A. Yes.

19 Q. And was this during the entire length of

20 this first visit?

21 A. Yes.

22 Q. And while you were at the ranch during the

23 first visit, did you see Mr. Jackson?

24 A. Yes, we did.

25 Q. And did you spend time with Mr. Jackson?

26 A. Yes, I did.

27 Q. Did you spend a lot of time with Mr.

28 Jackson? 5608



1 A. Yes.

2 Q. And when you say, “Yes, I did,” can you tell

3 us about what Jordan and Lily did?

4 A. We were all either taking rides on the

5 Ferris wheel, playing video games. Jordie and

6 Michael were playing video games. I was watching.

7 Lily was playing. We looked at his animals that he

8 had. Just different things that were at Neverland.

9 Q. Okay. And I think you’ve described that as

10 being an amazing weekend?

11 A. Yes. Fun.

12 Q. Now, during the time that you were there on

13 this first visit, do you recall whether or not you

14 went with Mr. Jackson to a business called

15 Toys-R-Us?

16 A. Yes.

17 Q. And could you tell us about that?

18 A. I guess it was after hours, after Toys-R-Us

19 closed, and Michael said, “Jordie and Lily, you get

20 to go shopping and buy toys, get toys.”

21 So we went and --

22 Q. When you say “we went,” who’s “we”?

23 A. Lily and Jordie and Michael and I went. And

24 they had fun. They were shopping and Michael bought

25 lots of things for them. They picked out stuff, and

26 they were showered with great presents from

27 Toys-R-Us.

28 Q. And Mr. Jackson paid for all of that? 5609



1 A. I -- yes, he did.

2 Q. You didn’t, right?

3 A. No.

4 Q. Now, after you left Neverland Valley Ranch

5 after this first visit, did you ever go back to

6 Neverland Valley Ranch?

7 A. Yes.

8 Q. And do you recall how much time elapsed

9 between the first time you went there and the second

10 time you went back?

11 A. It could be a week later or two weeks after.

12 Q. And when you went back the second time, do

13 you recall how you got there?

14 A. I -- to the best of my recollection, I was

15 picked up by Michael Jackson.

16 Q. When you say “picked up by Michael Jackson,”

17 in what form of transportation was that?

18 A. In his car, limo.

19 Q. And who else was with you when you got

20 picked up? I mean, from your family. Let’s start

21 that way first.

22 A. It was Lily, my daughter, and Jordan.

23 Q. So the three of you?

24 A. My son.

25 Q. The three of you went back to the ranch?

26 A. Right.

27 Q. Was there anybody else in the limo that you

28 recall with Mr. Jackson? 5610



1 A. Well --

2 Q. Let me go back and make something clear.

3 A. Sure.

4 Q. Was Mr. Jackson actually in the limo

5 himself?

6 A. Yes, he was.

7 Q. Now, let’s ask the question --

8 A. Okay.

9 Q. -- was there anybody else in the limo other

10 than Mr. Jackson and the three of you?

11 A. Yes, there was Brett Barnes.

12 Q. And do you recall where Mr. -- where the

13 child Brett -- let me ask you this: With regard to

14 Brett Barnes, can you estimate about approximately

15 what age you felt Brett Barnes was at this point?

16 A. 11. 10, 11.

17 Q. So he was a child?

18 A. He was a child.

19 Q. And where was Brett Barnes in the car in

20 relationship to Mr. Jackson?

21 A. Sitting next to Michael Jackson.

22 Q. Now, on the second visit you went to the

23 ranch, do you recall how long you stayed?

24 A. A weekend.

25 Q. And did you spend time -- did you personally

26 spend time with Mr. Jackson that weekend?

27 A. Yes, I did.

28 Q. Did Jordan spend time with him that weekend? 5611



1 A. Yes, he did.

2 Q. And did you see Brett Barnes around there

3 that weekend?

4 A. Yes. I don’t really remember, but yes, he

5 was there, too. Yes, he was enjoying that time

6 also.

7 Q. And where did you personally sleep during

8 your stay, the second visit to Neverland Valley

9 Ranch?

10 A. Guest cottages.

11 Q. Where did Lily stay?

12 A. In the guest cottages.

13 Q. And where did your son Jordan stay?

14 A. In the guest cottages.

15 Q. Now, the guest cottages are all located in

16 one general area, correct?

17 A. Yes.

18 Q. They’re all sort of connected into one

19 building?

20 A. Correct.

21 Q. With regard to that building, did you ever

22 see Brett Barnes anywhere around the building and

23 the cottages?

24 A. Not that I recall.

25 Q. Now, how did you get home from Neverland on

26 this second visit?

27 A. We were driven home.

28 Q. In a limo? 5612



1 A. Yes.

2 Q. Was Mr. Jackson present?

3 A. I don’t recall.

4 Q. Was there ever an occasion where you went to

5 Disneyland?

6 A. Yes.

7 Q. And do you recall when that happened in

8 relationship to like either one of these first,

9 second visits?

10 A. That could have been that weekend, the

11 second weekend that we were at Neverland that we

12 went -- instead of going to Los Angeles, we went to

13 Anaheim, to Disneyland. It could have been that

14 weekend.

15 Q. And who all went to Disneyland?

16 A. I remember Jordan, Lily, Michael and I, and

17 perhaps Brett.

18 Q. Now, did you ever have an occasion to visit

19 Neverland Valley Ranch again?

20 A. Yes.

21 Q. And do you remember approximately how much

22 time elapsed between the second visit and the third

23 visit?

24 A. It could have been a week. A weekend.

25 Q. And when you went to the ranch on this third

26 occasion, was Mr. Jackson present?

27 A. Yes, he was.

28 Q. And where did you sleep? 5613



1 A. In the guest cottages.

2 Q. And where did Lily sleep?

3 A. In the guest cottages.

4 Q. And where did Jordan sleep?

5 A. In the guest cottages.

6 Q. At some point in time during any one of

7 these three visits to -- these three visits you’ve

8 described to the jury, did your son request to sleep

9 in Mr. Jackson’s bedroom?

10 A. Yes --

11 MR. MESEREAU: Objection; leading.

12 THE WITNESS: -- he did.

13 THE COURT: Overruled. Next question.

14 Q. BY MR. SNEDDON: And do you recall during

15 which one of the visits it was that the request

16 came?

17 A. Oh, the third visit.

18 Q. And did you allow him to do that?

19 A. No, I did not.

20 Q. Did you notice -- I may not have asked this

21 with regard to the third visit, but you indicated in

22 at least the first visit that Jordan slept with you

23 in your guest cottage, correct?

24 A. Correct.

25 Q. In the second visit, did Jordan sleep with

26 you in your guest cottage?

27 A. Yes, he did.

28 Q. And the third visit, did Jordan sleep with 5614



1 you in your guest cottage?

2 A. Yes, he did.

3 Q. Did you notice anything with regard to what

4 time of the day or night it was that Jordan finally

5 came to your cottage to go to bed?

6 A. I assume it was late, after eleven o’clock.

7 Q. Why do you assume that?

8 A. Because they were playing all day and all

9 night. And it was a weekend. He did not have

10 school, so he was allowed to stay up later than

11 11:00.

12 Q. During any of your visits to Neverland

13 Valley Ranch, did you ever meet any children from

14 New Jersey?

15 A. Yes.

16 Q. Do you remember their names?

17 A. Frankie and Eddie.

18 Q. And with regard to Frankie at this point in

19 time, do you recall approximately how old Frankie

20 was?

21 A. Around the same age as Jordan, or maybe

22 younger.

23 Q. And how about Eddie?

24 A. I don’t recall. I don’t know which one is

25 which.

26 Q. Do you recall their last name at all?

27 A. Cascio.

28 Q. And do you remember which one of the visits 5615



1 to the ranch was it that you met Frank Cascio?

2 A. No, I don’t.

3 Q. Was there -- was there some point in time

4 when you took a trip with Mr. Jackson to Las Vegas?

5 A. Yes, there was.

6 Q. And do you remember when that trip occurred?

7 Just approximately what month, for instance?

8 A. The end of March.

9 Q. Of 1993?

10 A. Of ‘93. Correct.

11 Q. Excuse me, my allergies are acting up today.

12 How did you get to Las Vegas?

13 A. By jet, private jet.

14 Q. And who was with you on the jet?

15 A. My son Jordan, Lily, myself and Michael.

16 Q. And when you got to Las Vegas, where did you

17 stay, what hotel?

18 A. The Mirage Hotel.

19 Q. And when you got to The Mirage Hotel, do you

20 remember what time of day or night it was?

21 A. No.

22 Q. Do you remember how long you stayed in Las

23 Vegas on this occasion?

24 A. Two or three nights.

25 Q. Now, when you got to Las Vegas, did you

26 have -- obviously you had a room --

27 A. Correct.

28 Q. -- in The Mirage. 5616



1 And who was in your room when you first got

2 there? Who was staying in your room?

3 A. Jordan, myself, Lily and Michael.

4 Q. All in the same room?

5 A. Correct.

6 Q. Now, did those arrangements change at any

7 point in time?

8 A. Yes.

9 Q. And when did they change?

10 A. The second night things changed.

11 Q. With regard to “things changed,” could you

12 tell me what changed first?

13 A. Well, there were approximately three

14 bedrooms in that suite at the Mirage Hotel. Lily

15 and I were staying in one bedroom, Jordie had

16 another bedroom, and Michael had another bedroom.

17 The second night, they were going to see a

18 performance, Cirque du Soleil performance.

19 Q. “They” meaning who?

20 A. Jordie and Michael --

21 Q. Okay.

22 A. -- and Lily and I. It was around 11 p.m. at

23 night, and I got a call from somebody at Cirque du

24 Soleil saying, “Where is Michael?” And I said, “He

25 should be there with my son.” They said, “He’s not

26 here.”

27 A little while later, another call, he still

28 didn’t show up. They still did not show up. And 5617



1 I -- there’s a knock on the door and it’s Michael

2 and Jordan, and they came back into the suite.

3 Michael --

4 Q. Now, let me stop you right there, okay?

5 A. Yes.

6 Q. About what time is it when your son Jordan

7 and the defendant in this case, Mr. Jackson, showed

8 up?

9 A. Well, I think the performance started at

10 11:00, and I would say Jordan and Michael showed up

11 around 11:30.

12 Q. Now, could you describe for the jury Mr.

13 Jackson’s demeanor at the time that they came back

14 to the room?

15 A. He was sobbing. He was crying, shaking,

16 trembling.

17 Q. Michael Jackson was?

18 A. He was.

19 Q. And what about your son’s demeanor?

20 A. He was quiet.

21 Q. Now, at that point in time, did Mr. Jackson

22 tell you why he was upset or crying?

23 A. Yes.

24 Q. All right. Tell the jury what he said.

25 A. He said, “You don’t trust me? We’re a

26 family. Why are you doing this? Why are you not

27 allowing Jordie to be with me?” And I said, “He is

28 with you.” 5618



1 He said, “But my bedroom. Why not in my

2 bedroom? We fall asleep, the kids have fun.

3 Boys” --

4 MR. MESEREAU: Objection. Nonresponsive;

5 narrative.

6 THE COURT: Narrative; sustained.

7 Q. BY MR. SNEDDON: All right. Tell us what -

8 Mr. Jackson said that he wanted your son to sleep

9 with him in his bed - what you said to Mr. Jackson.

10 A. What I said to Michael was, “This is not” --

11 “This is not anything that I want. This is not

12 right. Jordie should be able to do what he wants to

13 do. He should be able to fall asleep where he wants

14 to sleep.”

15 Q. Is this you talking or Mr. Jackson speaking?

16 A. I was saying this. And Michael was

17 trembling and saying, “We’re a family. Jordie is

18 having fun. Why can’t he sleep in my bed? There’s

19 nothing wrong. There’s nothing going on. Don’t you

20 trust me?”

21 Q. All right. How long do you think this

22 conversation lasted between you and Mr. Jackson over

23 where Jordan was going to sleep that night?

24 A. I would say 20 to 30, 40 minutes.

25 Q. So it was a back-and-forth conversation; is

26 that right?

27 A. Yes.

28 Q. Do you recall how many times during that 5619



1 conversation that Mr. Jackson emphasized the fact

2 that you didn’t trust him?

3 MR. MESEREAU: Objection; leading.

4 THE WITNESS: No, I don’t recall how many

5 times --

6 THE COURT: Just a moment.

7 THE WITNESS: I’m sorry.

8 THE COURT: Overruled.

9 Go ahead. You may answer.

10 Q. BY MR. SNEDDON: Go ahead.

11 A. I don’t recall how many times.

12 Q. Was it on more than one occasion?

13 A. Absolutely, yes.

14 Q. Was it on many occasions?

15 A. Quite a few.

16 Q. Do you remember how many times during the

17 conversation that Mr. Jackson emphasized to you that

18 you were family?

19 A. Many times.

20 Q. Did you at some point in time relent and

21 allow your son to sleep with Michael Jackson in his

22 bedroom?

23 A. Yes, I did.

24 Q. And was it after that discussion on that

25 night?

26 A. Yes.

27 Q. Is that the first occasion?

28 A. Correct. 5620



1 Q. When you were in Las Vegas, do you remember

2 how many of the nights in Las Vegas that your son

3 Jordan slept with the defendant, Michael Jackson, in

4 Michael Jackson’s room?

5 A. I would say two occasions.

6 Q. Now, at some point in time after you had

7 agreed to let your son Jordan sleep with Mr.

8 Jackson, were you the recipient of a gift from Mr.

9 Jackson?

10 A. Yes, I was.

11 Q. Would you describe that to the jury?

12 A. It was a gold bracelet, and it was given to

13 me by Michael.

14 Q. And you say “a gold bracelet.” Had you seen

15 that gold bracelet in a shop of some kind before?

16 A. I had seen it before, yes.

17 Q. And the brand name on that bracelet?

18 A. Cartier.

19 Q. Was it expensive, to your knowledge?

20 A. Oh, I -- yes, it was.

21 Q. When was it you received this gift in

22 relationship to having agreed to allow your son to

23 sleep in bed with Mr. Jackson?

24 A. I think it was the next evening when we were

25 attending a show, a magic show, by David

26 Copperfield.

27 Q. Mrs. Chandler, do you recall after Las Vegas

28 where you went, where you personally and Jordan 5621



1 went? When you came back from Vegas, where did you

2 go; do you recall?

3 A. After Vegas, I -- it could be back to

4 Disneyland, back to Neverland, or home. I’m not

5 exactly certain.

6 Q. Was Mr. Jackson with you wherever it was

7 that you went? Did he go back with you, in other

8 words?

9 A. Yes, he did.

10 Q. And did Mr. Jackson continue to spend his

11 nights with your son in the same room, in the same

12 bed, from Las Vegas, from that point on?

13 A. Yes.

14 Q. Were there other visits to Neverland Valley

15 Ranch after you came back from Las Vegas?

16 A. Yes, there were.

17 Q. And were there occasions when your son went

18 up to the ranch where you and Lily did not accompany

19 him to the ranch?

20 A. Yes.

21 Q. Do you remember on how many such occasions?

22 A. I would say two or three times.

23 Q. And were there occasions also where you and

24 Lily and Jordan also went up to the ranch after Las

25 Vegas?

26 A. Yes.

27 Q. And on those occasions when you went up to

28 the ranch after Las Vegas, where did you stay? 5622



1 A. I stayed in the guest cottages.

2 Q. And where did Lily stay?

3 A. In the guest cottages.

4 Q. And where did Jordan stay?

5 A. In Michael Jackson’s bedroom.

6 Q. Were there ever any occasions that you

7 recall where you actually, when you got to the

8 ranch, that you would take Jordan’s suitcase in and

9 take it into Mr. Jackson’s bedroom and leave it

10 there?

11 A. Possibly.

12 Q. So you knew that he was going to be spending

13 the night with Michael Jackson in Michael Jackson’s

14 bedroom at this point in time?

15 A. Yes.

16 Q. Now, were there occasions after you got back

17 from Las Vegas -- let me -- where Mr. Jackson

18 actually was invited to stay at your residence where

19 you lived at this point in time?

20 A. Yes.

21 Q. Now, what city was it that you lived in at

22 this time?

23 A. Santa Monica.

24 Q. We’re talking about 1993, in the spring,

25 right?

26 A. Correct.

27 Q. Okay. Where did you live?

28 A. Santa Monica. 5623



1 Q. And at this point in time, was Mr. Schwartz

2 living with you?

3 A. No, he wasn’t.

4 Q. So in the household was there anybody

5 besides you and Jordan and Lily?

6 A. My housekeeper.

7 Q. And was that a full-time housekeeper?

8 A. Yes, she was.

9 Q. 24 hours a day?

10 A. Yes.

11 Q. Did she live in the house?

12 A. Yes, she did. She was a live-in.

13 Q. That’s what I meant. Sorry. Clumsy

14 question.

15 And during this time, did Mr. Jackson ever

16 spend the night at your residence?

17 A. Yes, he did.

18 Q. And do you recall on how many occasions Mr.

19 Jackson spent the night at your residence?

20 A. I would say more than 30 times.

21 Q. And were some of those occasions on

22 consecutive days or nights?

23 A. Yes.

24 Q. And how long consecutively do you think that

25 that occurred?

26 A. Oh. It could be a week or two at a time.

27 Q. Where did Mr. Jackson stay in the house?

28 A. In Jordan’s bedroom. 5624



1 Q. Are there more than one bed in that room?

2 A. No.

3 Q. I am assuming that Jordan was going to

4 school during this period of time.

5 A. He was.

6 Q. So Mr. Jackson would spend the night there.

7 What would happen when Jordan would go to school?

8 To your knowledge, what did Mr. Jackson do?

9 A. Michael would leave.

10 Q. And approximately what time would he return?

11 A. After Jordan came home from school.

12 Q. And so was this the routine that was

13 followed during the time that Mr. Jackson was

14 staying at your residence?

15 A. Yes.

16 Q. Did you ever -- have you ever been to Disney

17 World --

18 A. Yes.

19 Q. -- in Orlando, Florida?

20 A. Yes.

21 Q. And have you been to Disney World with the

22 defendant in this case, Michael Jackson?

23 A. Yes.

24 Q. And do you remember approximately when it

25 was that you went to Disney World with Mr. Jackson?

26 A. I would say in May.

27 Q. Of ‘93?

28 A. Of ‘93. 5625



1 Q. And when you went to Disney World with Mr.

2 Jackson, who else went with you?

3 A. Jordan and Lily.

4 Q. Do you recall where you stayed?

5 A. I recall The Grand Floridian was one hotel.

6 Q. And during the time that -- do you remember

7 how many days -- did you go there on more than one

8 occasion?

9 A. Yes, we did.

10 Q. How many occasions?

11 A. Twice.

12 Q. And do you recall what the sleeping

13 arrangements were on the first occasion?

14 A. Jordie was with Michael and Lily was with

15 me.

16 Q. And when you say “with Michael” --

17 A. In Michael’s bedroom.

18 Q. Now, during the time that you visited Disney

19 World in Orlando, would you describe the nature of

20 the relationship that was going on, that you

21 observed personally, between the defendant in this

22 case, Michael Jackson, and your son Jordan?

23 A. The behavior, you say?

24 Q. Yeah.

25 A. The behavior with my son was he was not

26 wanting to be with Lily and I anymore, and he was

27 just with Michael the whole time, and he wasn’t too

28 happy. Just -- well, I couldn’t -- I didn’t have 5626



1 any communication with him really.

2 Q. Was this something that you observed for the

3 first time in Orlando or was this something that you

4 began to observe over a period of time?

5 A. It was a period of time, and it gradually

6 happened.

7 Q. Did you notice any change in your son --

8 A. Yes.

9 Q. -- Jordan?

10 A. Yes.

11 Q. What was the nature of the change?

12 A. Well, he started dressing like Michael. He

13 started acting withdrawn, sort of smart-alecky. Not

14 as sweet as he normally was. And withdrawn. He

15 just didn’t want to be with us, Lily and I.

16 Q. Had you always been close prior to that?

17 A. Extremely close.

18 Q. Do you -- I think you answered this, but

19 just in case, how many days did you think you were

20 in Florida?

21 A. Oh, I don’t really remember, but it’s

22 probably more than two nights. Two, three nights.

23 Q. And after you came back from Florida, do you

24 recall where you went?

25 A. After that, I think the next trip was to

26 Monaco.

27 Q. In between the time that you went to Florida

28 and to Monaco, do you recall where you were -- where 5627



1 you were personally staying?

2 A. No. I guess home.

3 Q. Do you remember how much time elapsed

4 between the two trips?

5 A. Not really, no.

6 Q. Was it more than a month, more than a week?

7 Obviously it was more than a day or so.

8 A. Yes. It was a couple -- it could be three

9 weeks.

10 Q. And during that time when you got back from

11 Florida till the time that you left for Monaco, were

12 you with Mr. Jackson?

13 A. At times.

14 Q. And the times that you were with Mr.

15 Jackson, was Jordan with Mr. Jackson?

16 A. Yes.

17 Q. And when he’s with Mr. Jackson, where did he

18 sleep?

19 A. With Mr. Jackson.

20 Q. Do you know somebody by the name of Joy

21 Robeson?

22 A. Yes.

23 Q. Do you know somebody by the name of Wade

24 Robeson?

25 A. Yes.

26 Q. And do you recall where it was that you met

27 Joy Robeson?

28 A. Yes, I do. 5628



1 Q. Where was that?

2 A. That was at Neverland, one of the visits.

3 Q. Do you recall when it was that you met Wade

4 Robeson?

5 A. One of the visits to Neverland.

6 Q. And do you recall approximately which visit

7 it would have been or what month it would have been

8 that you met these individuals?

9 A. It could have been my third visit to

10 Neverland.

11 Q. Did you meet them on more than one occasion?

12 A. I met Wade on more than one occasion, yes.

13 Q. And how many times did you meet Joy Robeson?

14 A. One.

15 Q. One occasion?

16 A. That I remember.

17 Q. There were occasions when Wade Robeson was

18 there that the mother was not there?

19 A. Correct.

20 Q. Now, you’ve indicated to the jury on at

21 least one occasion, perhaps two, that Brett Barnes

22 was also at Neverland Valley Ranch?

23 A. Yes, he was there too.

24 Q. And did you ever meet Brett Barnes’ mother?

25 A. No.

26 Q. So he was at the ranch by himself also?

27 A. Oh, yes. Yes, he was.

28 Q. Did you ever meet a Mr. Robeson, the father? 5629



1 A. No. No, not that I remember.

2 Q. Did you ever meet a Mr. Barnes at any point?

3 A. Not that I remember, no.

4 Q. So no fathers in the picture?

5 A. No.

6 Q. Now, prior to the time that you met Joe

7 Robeson for the first time - okay? --

8 A. Yes.

9 Q. -- on your visit to Neverland Valley Ranch,

10 did you have a discussion with the defendant in this

11 case, Mr. Jackson, with regard to some warnings that

12 Mr. Jackson gave you about Joy Robeson?

13 A. Yes.

14 Q. What did Mr. Jackson tell you?

15 MR. MESEREAU: Objection. Relevance.

16 MR. SNEDDON: I think it’s an admission of

17 Mr. Jackson with regard to the relationship with the

18 boys.

19 MR. MESEREAU: Relevance and hearsay.

20 THE COURT: I’m not sure what you’re trying

21 to introduce. I’m searching my memory for that. I

22 don’t know, maybe you should approach with counsel.

23 MR. SNEDDON: Thank you, Your Honor.

24 (Discussion held off the record at sidebar.)

25 Q. BY MR. SNEDDON: Mrs. Chandler?

26 A. Yes.

27 Q. Okay. Now, you had a conversation with Mr.

28 Jackson, is that correct? 5630



1 A. Yes.

2 Q. Now, at the time -- and please do not tell

3 us what was said, but did you subsequently have a

4 conversation with Miss Robeson --

5 A. Yes, I did.

6 Q. -- wade’s mother?

7 A. Correct.

8 Q. Okay. Now, after that conversation, did you

9 develop any concerns about some of the things that

10 she had told you?

11 A. I --

12 Q. I think you have to answer that “yes” or

13 “no.” We don’t want to get into what she said.

14 A. Yes.

15 Q. And with regard to that particular

16 conversation, let me ask you this: Had you been

17 invited by the defendant in this case, Mr. Jackson,

18 to go on a tour with him, you and Jordan?

19 A. Yes.

20 Q. And where were you invited by Mr. Jackson to

21 go on a tour?

22 A. I don’t know where the tour was going. I

23 guess a world tour somewhere in the summertime.

24 Q. Do you know where Miss Robeson, Mrs.

25 Robeson, was from, what country?

26 A. Australia.

27 Q. Do you know whether one of the stops on that

28 tour was going to be Australia? 5631



1 A. I think it was, yes.

2 Q. Okay. Let’s talk a little bit about your

3 trip to France.

4 A. Yes.

5 Q. Do you recall approximately when that was?

6 A. I think the middle of May.

7 Q. And how did you get there?

8 A. We flew.

9 Q. And was it on a charter or a commercial

10 airline?

11 A. Commercial airline.

12 Q. And you say “we,” so could you tell us who

13 it was that you went with?

14 A. My daughter, my son and Michael.

15 Q. And when you got to France, where in France

16 did you stay?

17 A. Monaco.

18 Q. And how long were you in Monaco?

19 A. Approximately four days.

20 Q. And during the time that you were there,

21 where did your son Jordan sleep?

22 A. In Michael Jackson’s bedroom.

23 Q. Now, did you ever go into that bedroom?

24 A. Yes.

25 Q. And were they in bed together on occasion?

26 A. On occasion, yes.

27 Q. Now, during the time that you were in

28 Monaco, did you do any shopping? 5632



1 A. Yes.

2 Q. And how was it that you -- well, let me put

3 it this way: Who went shopping with you?

4 A. My daughter.

5 Q. You and Lily?

6 A. Yes.

7 Q. And how many days did you do that?

8 A. Oh. One day.

9 Q. And who was paying for the --

10 A. Michael was.

11 Q. I’m sorry?

12 A. Michael was.

13 Q. And how did he arrange that?

14 A. I think I was given a credit card, his

15 credit card.

16 Q. So you went shopping in Monaco on Michael

17 Jackson’s credit card, you and your daughter?

18 A. Yes.

19 Q. Now, during this trip, did either your son

20 or Mr. Jackson get ill?

21 A. Yes, they both did.

22 Q. They had the flu?

23 A. Yes.

24 Q. And were they in the room together the

25 entire time?

26 A. Yes.

27 Q. And when you went to France, did you go to

28 any other country, any other places in France, other 5633



1 than Monte Carlo?

2 A. We also went to Euro Disney outside of

3 Paris.

4 Q. And do you recall how long you were there?

5 A. A couple of days.

6 Q. Again, when you say “we,” you’re talking

7 about Jordan and Lily, and was the defendant with

8 you?

9 A. Yes, he was.

10 Q. And you say you spent a couple of days.

11 Where did Jordan sleep?

12 A. With Michael Jackson.

13 Q. Now, do you have a brother?

14 A. Yes, I do.

15 Q. What’s your brother’s name?

16 A. I have two brothers.

17 Q. What are their names?

18 A. Steven Wong and Dale Wong.

19 Q. And was there a time when one of your

20 brothers -- where do they live? Let’s go that way.

21 A. One lives in Los Angeles. And the other

22 lives back east in New Jersey.

23 Q. And was there a time when you went back east

24 for a family wedding?

25 A. Yes.

26 Q. Do you remember about what month that was?

27 A. That was in September.

28 Q. And do you recall who it was who was getting 5634



1 married?

2 A. Yes.

3 Q. Who was that?

4 A. That was my brother Steve and his wife.

5 Q. And when you went back for the wedding, what

6 city did you go to?

7 A. We went to New York City.

8 Q. And when you went back there, who went with

9 you?

10 A. My son, my daughter, and myself.

11 Q. And when you first got there, where did you

12 stay?

13 A. We stayed in a hotel.

14 Q. Do you remember the name of the hotel?

15 A. Yes, The Rega Royal Hotel.

16 Q. And do you know who made the arrangements

17 for that hotel?

18 A. Yes, I do.

19 Q. Who was that?

20 A. Norma Stakos.

21 Q. And do you know who Mrs. Stakos is? Had you

22 had prior dealings with Mrs. Stakos?

23 A. Yes.

24 Q. On a number of occasions?

25 A. Telephone conversations only.

26 Q. And who did she work for?

27 A. She worked for Michael Jackson.

28 Q. And so she made the reservations for you at 5635



1 the hotel?

2 A. Yes.

3 Q. When did you learn that Mr. Jackson was

4 going to be with you in New York? Before or after

5 you left?

6 A. Before.

7 Q. Do you remember how many days before you

8 learned that?

9 A. Not really, no. I don’t remember.

10 Q. On the day of the actual wedding, was Mr.

11 Jackson there?

12 A. No, he was not.

13 Q. When did he show up in relationship to the

14 wedding?

15 A. After the wedding.

16 Q. Do you remember how many days he showed up,

17 how many days later?

18 A. It could be two days later.

19 Q. Now, when Mr. Jackson got there, did you see

20 him?

21 A. That evening briefly.

22 Q. Okay. Now, had something happened during

23 the time that you were in New York with your son

24 Jordan before Mr. Jackson arrived which caused some

25 problems in the family?

26 MR. MESEREAU: Objection. Leading and

27 vague.

28 THE COURT: Overruled. 5636



1 You may answer.

2 THE WITNESS: Yes.

3 Q. BY MR. SNEDDON: What was it?

4 A. Jordan was spending too much time with

5 Michael. I was getting upset. My brother was also

6 with me, and he was saying --

7 MR. MESEREAU: Objection; hearsay.

8 Q. BY MR. SNEDDON: Don’t tell us what he said,

9 but --

10 A. Okay.

11 Q. -- could you describe his demeanor to us?

12 A. Jordan was not with us. He didn’t want to

13 be with us. He was very -- he was sullen.

14 Q. Now, during this time, Mr. Jackson was not

15 there, correct?

16 A. Correct.

17 Q. And to your knowledge, from your own

18 personal knowledge, were Mr. Jackson and your son

19 Jordan in communication with each other during this

20 period of time?

21 A. Yes.

22 Q. By what method?

23 A. Telephone.

24 Q. And the frequency?

25 A. Often. Often. Long conversations.

26 Q. And was your brother upset by the situation,

27 too?

28 A. Yes. 5637



1 MR. MESEREAU: Objection; leading.

2 THE COURT: Sustained.

3 MR. MESEREAU: Move to strike.

4 THE COURT: Stricken.

5 Q. BY MR. SNEDDON: Could you describe to

6 the -- describe your brother’s reaction to this

7 situation that was -- that existed between Mr.

8 Jackson and your son Jordan.

9 A. Yes. My brother was happy for Jordan, but

10 he didn’t like that Jordie was just spending time

11 with Michael and not with his family.

12 Q. Now, when Mr. Jackson showed up in New York,

13 do you recall where he was staying?

14 A. Yes, he was staying across the hallway from

15 my room.

16 Q. And when Michael Jackson showed up, where

17 did Jordan sleep?

18 A. When Michael Jackson showed up, he slept in

19 Michael’s room.

20 Q. Now, when Mr. Jackson showed up the first

21 night, was there an incident that occurred in your

22 room?

23 MR. MESEREAU: Objection; leading.

24 THE WITNESS: My room?

25 Q. BY MR. SNEDDON: Yeah.

26 A. Yes, there was an incident.

27 MR. SNEDDON: You have to wait till the

28 Judge rules. 5638



1 THE COURT: Overruled.

2 You can answer.

3 Q. BY MR. SNEDDON: Okay, you can answer now.

4 A. Yes, there was an incident.

5 Q. Who was involved in the incident?

6 A. My daughter Lily --

7 Q. Okay.

8 A. -- Michael and Jordan.

9 Q. And when you got back to your particular

10 room, did you notice any damage in the room?

11 A. Yes, I did.

12 Q. And what was damaged?

13 A. I noticed there was damage in the morning.

14 There were two lamps that were broken.

15 Q. Now, did you at some point talk to Mr.

16 Jackson about what had happened the night before?

17 A. Yes.

18 Q. And with regard to that conversation, did it

19 involve Jordan?

20 A. Yes, it did.

21 Q. And did it involve you?

22 A. Yes, it did.

23 Q. And did it involve Mr. Jackson?

24 A. Yes, it did.

25 Q. And the relationship between the two or

26 three of you?

27 A. Yes.

28 Q. Would you tell the jury what the 5639



1 conversation was about?

2 MR. MESEREAU: Objection to the extent it

3 calls for hearsay.

4 MR. SNEDDON: Your Honor, this involves the

5 defendant and it involves statements that he makes.

6 THE COURT: But that’s not the question you

7 asked. I’ll sustain the objection.

8 Excuse me. Sustain the objection.

9 Q. BY MR. SNEDDON: All right. Let’s do it

10 this way. What did Mr. Jackson say about the

11 situation?

12 A. “Why can’t we be a family? Why are you

13 objecting to Jordie staying with me? Why can’t we

14 be a family? Why don’t you trust me?”

15 He was upset that I wanted my son back; that

16 I -- I didn’t like the situation. It was getting

17 out of hand.

18 Q. Now, you’ve told the ladies and gentlemen of

19 the jury that Mr. Jackson had given you a bracelet

20 at one point in time and that you had gone shopping

21 with Mr. Jackson on his credit card in Monte Carlo.

22 Were there any other occasions when Mr.

23 Jackson gave you gifts?

24 A. Yes.

25 Q. What else did he give you?

26 A. He also gave me jewelry.

27 Q. And do you recall approximately when that

28 was? 5640



1 A. I think it was approximately in June.

2 Q. And what kind of jewelry?

3 A. A pair of earrings, a necklace, and a ring.

4 Q. And where were these items when you first

5 saw them?

6 A. The boxes were open on my bed in Santa

7 Monica.

8 Q. At your house?

9 A. Yes.

10 Q. Was Mr. Jackson staying at your house at

11 that point in time?

12 A. Not really. Not really. He was there, in

13 and out.

14 Q. In and out. Okay. Any other gifts you ever

15 received from Mr. Jackson?

16 A. Yes, a gift certificate to a store.

17 Q. And the store?

18 A. To a store.

19 Q. Yes. The store?

20 A. Fred Segal.

21 Q. Now, to your knowledge, was there ever an

22 occasion where your son Jordan and the defendant in

23 this case, Michael Jackson, were at your

24 ex-husband’s house, Evan Chandler?

25 A. Yes. Yes.

26 Q. And do you remember on how many occasions?

27 A. I would say one or two occasions.

28 Q. And do you remember the length of the stays 5641



1 on those occasions that Jordan stayed there?

2 A. A few days each time.

3 Q. So during this period of time you had

4 custody of Jordan, correct?

5 A. Correct.

6 Q. Now, you told us, I think, that there were

7 two trips to Florida?

8 A. Yes.

9 Q. Do you remember when the second trip was?

10 A. After June. July, early July possibly.

11 Q. And do you recall how long you stayed there

12 on that occasion?

13 A. I would say two or three nights.

14 Q. And where did Jordan sleep on those

15 occasions?

16 A. With Michael.

17 Q. Did Lily go with you on that trip?

18 A. Yes, she did.

19 Q. Had Jordan’s behavior or attitude changed in

20 any respect since the first time you described his

21 change from Florida, the first trip?

22 A. It was the same. Same.

23 Q. Father’s Day is in June, okay?

24 A. Yes.

25 Q. Do you remember a situation where you were

26 with Jordan, your son, on Father’s Day?

27 A. Yes.

28 Q. In 1993? 5642



1 A. Yes.

2 Q. I’m sure you were with him on other

3 occasions. Do you recall where you were in 1993 on

4 Father’s Day?

5 A. Yes, I was in New York.

6 Q. And to your knowledge, in your presence, did

7 Jordan call his father on Father’s Day?

8 A. Eventually he did, yes.

9 Q. And initially, did you have a conversation

10 with him?

11 A. Yes, I did.

12 Q. Did he want to call his father?

13 A. No, he didn’t.

14 MR. MESEREAU: Objection. Hearsay; move to

15 strike.

16 THE COURT: Sustained. Stricken.

17 Q. BY MR. SNEDDON: As a result of the

18 conversation that you had with your son Jordan, did

19 he eventually call his father?

20 A. I think he did, yes.

21 Q. All right. At some point in time, did you

22 receive a message of some sort from your ex-husband

23 Evan about Mr. Jackson?

24 A. Yes.

25 Q. And don’t tell us what was said, okay? I

26 just want to get the facts and the background to it.

27 Where were you when you first heard the message?

28 A. In Michael Jackson’s car. In his limo. 5643



1 Q. And was Mr. Jackson with you?

2 A. Not when I got that call.

3 Q. Did the call come directly to you or did you

4 access it in some other fashion?

5 A. From another fashion.

6 Q. How was that?

7 A. Answering machine. I dialed in.

8 Q. So you dialed the answering machine on whose

9 answering machine?

10 A. My answering machine at home.

11 Q. And there was a message on the machine from

12 your ex-husband Evan, correct?

13 A. Correct.

14 Q. Did you at some point later play that

15 message for Mr. Jackson?

16 A. I don’t recall.

17 Q. Are you familiar with a person by the name

18 of Anthony Pellicano?

19 A. Yes, I am.

20 Q. And who is Anthony Pellicano, to your

21 knowledge?

22 A. A private investigator.

23 Q. And was Mr. Pellicano introduced to you by

24 somebody?

25 A. By Bert Fields and Michael Jackson.

26 Q. In relationship to this voice message that

27 you received on your message machine at your house,

28 do you recall how many days after that particular 5644



1 message, you received that message, that you were

2 introduced to Mr. Pellicano and Mr. Fields by Mr.

3 Jackson?

4 A. It could be a week later.

5 MR. MESEREAU: Objection. Move to strike;

6 misstates the evidence; and no foundation.

7 THE COURT: Sustained, stricken.

8 Q. BY MR. SNEDDON: Did you meet Anthony

9 Pellicano through the defendant, Michael Jackson?

10 A. Yes.

11 MR. MESEREAU: Objection; leading.

12 THE COURT: Overruled. The answer is,

13 “Yes.” Next question.

14 Q. BY MR. SNEDDON: Did you meet Bert Fields

15 through the defendant, Michael Jackson?

16 A. Yes.

17 Q. Were you present during conversations with

18 Mr. Pellicano and Mr. Fields and Mr. Jackson?

19 A. Yes, I was.

20 Q. And this all occurred after the voice mail

21 had been left on your message machine by your

22 ex-husband Evan Chandler?

23 A. Yes, sir.

24 Q. Now, did the defendant, Michael Jackson,

25 tell you who Anthony Pellicano was?

26 A. Yes, he did.

27 Q. What did he say about Mr. Pellicano?

28 A. “He can find out anything. He’s really good 5645



1 at this. He’s really good at investigating. If

2 you’re having a problem, he’ll get to the bottom of

3 it.”

4 Q. And Mr. Fields, Bert Fields, is what -- you

5 know him by name. What occupation is he?

6 A. He’s an attorney.

7 Q. And he’s an attorney who works for who? Or

8 at this point in time, who did you know he was

9 working for?

10 A. He worked for Michael Jackson.

11 Q. Now, at some point in time, did you go to

12 Mr. Pellicano’s office to be interviewed by Mr.

13 Pellicano?

14 A. Yes.

15 Q. And did somebody go with you?

16 A. Yes.

17 Q. Who was that?

18 A. My ex-husband, Dave Schwartz.

19 Q. And was there anybody else present during

20 this conversation?

21 A. I don’t remember. It could be Bert Fields

22 also.

23 Q. Now, after that conversation, did you go

24 somewhere else? Do you recall where you went?

25 A. To Michael Jackson’s home in Century City,

26 apartment in Century City.

27 Q. And was Mr. Jackson there?

28 A. He might have been. 5646



1 Q. At that particular location, was your son

2 Jordan Chandler there, can you tell us?

3 A. Yes, he might have been there, too.

4 Q. Do you recall whether or not or do you

5 recall an incident -- doesn’t have to be on that

6 particular occasion, but do you recall an occasion

7 whether or not your son Jordan Chandler was ever

8 interviewed by Anthony Pellicano?

9 A. Yes, he was.

10 Q. Where did that interview take place?

11 A. In the Century City apartment.

12 Q. Were you present?

13 A. Yes.

14 Q. Were you present during the conversation?

15 A. No.

16 Q. Where were you?

17 A. Upstairs or in his -- somewhere else.

18 Q. And do you recall how long that conversation

19 took?

20 A. Could have been 45 minutes.

21 Q. Now, after Mr. Pellicano and Mr. Fields were

22 introduced to you by Michael Jackson, were you

23 involved in some issues involving a change in

24 custody of your son Jordan?

25 A. Yes.

26 Q. And were you -- were you presented with some

27 papers to sign?

28 A. Yes, I was. 5647



1 Q. And those papers did what?

2 MR. MESEREAU: Objection. Hearsay;

3 foundation; relevance.

4 THE COURT: Foundation; sustained.

5 Q. BY MR. SNEDDON: The papers were presented

6 to you by whom?

7 A. By Pellicano.

8 Q. And was Mr. Fields present?

9 A. I don’t think at that time.

10 Q. Do you recall if the defendant, Michael

11 Jackson, was present?

12 A. No, he wasn’t.

13 Q. At some point in time did you have a

14 conversation with Michael Jackson about signing

15 those papers?

16 A. I don’t recall talking to Michael about the

17 papers.

18 Q. Do you recall giving a statement to an

19 attorney, a Deputy District Attorney with the Los

20 Angeles District Attorney’s Office on September 3rd

21 of 1993?

22 A. Yes, I do.

23 Q. And it was Miss Lauren Weis?

24 A. Yes, it was.

25 Q. And you gave a rather lengthy statement to

26 Miss Weis?

27 A. Yes, I did.

28 Q. Do you recall telling Miss Weis that -- 5648



1 MR. MESEREAU: Objection. Leading; hearsay;

2 move to strike.

3 MR. SNEDDON: It’s foundational, or to

4 refresh her recollection.

5 THE COURT: If you want to refresh her

6 recollection with something, you can approach her

7 and show the item.

8 MR. SNEDDON: All right. Counsel, page 95,

9 lines 15 to 19.

10 MR. MESEREAU: Objection. Foundation, Your

11 Honor.

12 THE COURT: You have to ask her if it will

13 help refresh her recollection, or it might.

14 MR. SNEDDON: Can I show it to her first?

15 That’s the way counsel’s been doing it.

16 MR. MESEREAU: No, I haven’t at all.

17 THE COURT: Actually, he’s been asking them

18 if it would refresh their recollection if he showed

19 them something.

20 MR. SNEDDON: All right.

21 Q. Do you recall that conversation?

22 A. Yes, I do.

23 Q. And -- and it occurred at a point in time

24 when things were a lot fresher in your mind than

25 they are now?

26 A. Yes.

27 Q. Would it help, perhaps, if you looked at the

28 statement, that it might help refresh your 5649



1 recollection?

2 A. Yes.

3 MR. SNEDDON: May I approach the witness,

4 Your Honor?

5 THE COURT: Yes.

6 Q. BY MR. SNEDDON: Just read it to yourself.

7 Start here and right down to here. How’s that?

8 Counsel, I’m having her read lines 11 to

9 line 25.

10 MR. MESEREAU: I’m going to object to that.

11 That’s improper refreshing of recollection and it’s

12 hearsay, foundational, to have her just read it.

13 MR. SNEDDON: That’s all I’m asking her to

14 do. I’m just trying to help you try to find out

15 where it is.

16 THE COURT: All right. Just let her look at

17 it. Counsel knows you can refresh a person’s

18 recollection with anything.

19 MR. MESEREAU: Your Honor, I thought she was

20 reading it out loud. That was my mistake. I

21 withdraw the objection.

22 THE COURT: That would have been improper.

23 MR. SNEDDON: We’ve been down that road

24 before.

25 THE COURT: All right, I’m sorry. Did we --

26 where are we?

27 (Laughter.)

28 MR. SNEDDON: I know where we are. 5650



1 THE COURT: Is it break time yet? No.

2 (Laughter.)

3 MR. SNEDDON: I’m sorry, Judge. You’re

4 going to have to suffer for six more minutes and

5 you’re not getting out of here a minute early.

6 Payback is you-know-what.

7 Q. All right. Mrs. Chandler, with regard to

8 whether or not the defendant was present, did that

9 refresh your recollection?

10 A. Yes, it does.

11 Q. And do you recall whether the defendant was

12 present?

13 A. He was present.

14 Q. And does it refresh -- did the defendant,

15 Michael Jackson, make statements to you with regard

16 to the particular documents that you were being

17 asked to sign?

18 A. Yes, he did.

19 Q. And do you recall what he told you?

20 A. He was frantic. He was begging me to, “Come

21 over and sign this so there won’t be any lawsuits or

22 anything. Just sign it, sign it.”

23 Q. And, in effect, what you signed did what to

24 you personally?

25 MR. MESEREAU: Objection. Hearsay;

26 foundation.

27 MR. SNEDDON: Let me go back, Judge. I

28 think I can correct this. 5651



1 Q. I am assuming you read the document before

2 you signed it?

3 A. Briefly.

4 Q. And you understood what it meant when you

5 were signing it?

6 A. Not really.

7 Q. Okay. You understood -- well, let me ask

8 you this: Did you understand -- if you didn’t

9 understand all of it, you understood some of it,

10 correct?

11 A. Yes, I did.

12 Q. Did you understand a part of it that had to

13 do with who was going to have custody for the

14 children temporarily?

15 A. Exactly, yes.

16 MR. MESEREAU: Objection; leading.

17 THE COURT: Overruled.

18 Q. BY MR. SNEDDON: I’m sorry?

19 A. Yes.

20 Q. And it wasn’t going to be you anymore?

21 A. Exactly.

22 Q. Did you sign that paper?

23 A. I did.

24 Q. Mrs. Chandler, I neglected to ask you about

25 one other incident that occurred at Neverland Ranch,

26 okay?

27 A. Yes.

28 Q. So pardon me if we can go back in time from 5652



1 where we are presently. And then we’re almost done,

2 okay?

3 A. Okay.

4 Q. Do you recall whether there was ever any

5 occasion where your brother and your sister-in-law

6 ever visited Neverland Valley Ranch?

7 A. Yes, I do recall.

8 Q. Do you know approximately when it was that

9 they visited Neverland Valley Ranch?

10 A. Approximately May.

11 Q. And do you know how long they were there?

12 A. For the day.

13 Q. Just came up for the day?

14 A. Yes. For the day.

15 Q. And do you recall, were you with them while

16 they were at the ranch?

17 A. Yes, I was.

18 Q. Was Jordan at the ranch?

19 A. Yes, he was.

20 Q. Where was Jordan?

21 A. With Michael.

22 Q. Now, do you remember about what time it was

23 when you left that day, you personally?

24 A. Before eight o’clock.

25 Q. Eight o’clock --

26 A. P.m.

27 Q. P.m. Now, do you recall seeing Mr. Jackson

28 and Jordan before you left? 5653



1 A. Yes.

2 Q. And where did you see them?

3 A. They were in Michael Jackson’s bedroom.

4 Q. And do you recall -- did you go into the

5 bedroom?

6 A. Yes.

7 Q. Did you go in there with your brother and

8 sister-in-law?

9 A. Yes, we did.

10 Q. And when you went into the bedroom, where

11 was Mr. Jackson?

12 A. In the bedroom with Jordan.

13 Q. Do you recall where?

14 A. Could be on the bed.

15 Q. You don’t remember specifically?

16 A. Not specifically.

17 Q. Okay. And Jordan, do you recall where he

18 was?

19 A. On the bed, too.

20 Q. Now, at some point in time, Mrs. Chandler,

21 your son Jordan Chandler was involved in a lawsuit,

22 Chandler versus Jackson, a civil lawsuit. Do you

23 recall that?

24 A. Yes, I do.

25 Q. And were you a participant in that lawsuit

26 as a representative of your son?

27 A. Yes, I was.

28 Q. And who was the lawyer who represented your 5654



1 son during the majority of that litigation?

2 A. Larry Feldman.

3 Q. And to your knowledge, was a lawsuit filed

4 on behalf of your son against the defendant, Michael

5 Jackson?

6 A. Yes.

7 Q. And did you assist or help Mr. Feldman in

8 the preparation of that lawsuit?

9 A. Yes.

10 Q. And did you support your son during that

11 lawsuit?

12 A. I did.

13 Q. Now, as a result of the lawsuit, did your

14 son -- and please -- don’t tell us the amount,

15 please. Did your son receive monetary compensation

16 from Mr. Jackson?

17 A. Yes, he did.

18 Q. Now, also as a result of that lawsuit, did

19 you receive some monetary compensation?

20 A. Yes, I did.

21 Q. Did you ever ask to be compensated in any

22 way as a result of what had happened?

23 A. No.

24 MR. MESEREAU: Objection. Foundation; and

25 hearsay.

26 THE COURT: All right. Overruled.

27 Q. BY MR. SNEDDON: You did not?

28 A. No. 5655



1 Q. And where did the idea for you receiving

2 compensation come from, to your knowledge?

3 MR. MESEREAU: Objection, to the extent it

4 calls for hearsay.

5 THE COURT: Sustained.

6 Q. BY MR. SNEDDON: As a result of this

7 lawsuit, did you receive money?

8 A. Yes, I did.

9 Q. Did you have to sign something in exchange

10 for that money?

11 A. Yes, I did.

12 Q. And what did you sign?

13 A. A disclosure agreement.

14 Q. And what does that mean?

15 A. Confidentiality agreement.

16 THE COURT: All right. Let’s take our break.

17 (Recess taken.)

18 THE COURT: Go ahead.

19 Q. BY MR. SNEDDON: Mrs. Chandler, I just have

20 a couple of questions.

21 I want to go back to something we talked

22 about before. You told the jury that the defendant,

23 Michael Jackson, gave you a gift certificate at one

24 point in time?

25 A. Correct.

26 Q. And it was to Segal?

27 A. Fred Segal is a store in Santa Monica.

28 Q. Okay. And what was the amount of that 5656



1 certificate?

2 A. $7,000.

3 Q. Okay. Now, let’s just go back and finish up

4 the last part of what we were talking about.

5 With regard to the lawsuit, you signed some

6 kind of an agreement, correct?

7 A. Correct.

8 Q. In exchange for that, you were given some

9 money?

10 A. Yes.

11 Q. Do you recall, based upon what you know,

12 what the agreement was, what it required of you?

13 MR. MESEREAU: Objection; hearsay.

14 THE COURT: Sustained.

15 Q. BY MR. SNEDDON: What did you give up in

16 return for receiving money?

17 MR. MESEREAU: Same objection. Hearsay and

18 foundation.

19 THE COURT: Sustained.

20 Q. BY MR. SNEDDON: Did you read the agreement

21 before you signed it?

22 A. Yes.

23 Q. And who presented it to you?

24 A. Larry Feldman.

25 Q. Did he go over it with you before you signed

26 it?

27 A. Yes.

28 Q. And you understood what you were signing? 5657



1 A. Yes, we did.

2 Q. And you read the document?

3 A. Yes.

4 Q. And what did it require you to do in order

5 to obtain money from the defendant, Mr. Jackson?

6 You personally.

7 A. We couldn’t --

8 MR. MESEREAU: Objection. Hearsay and

9 foundation.

10 THE COURT: Sustained.

11 Q. BY MR. SNEDDON: Have you ever written any

12 books --

13 A. Never.

14 Q. -- about what happened?

15 A. No, I have not.

16 Q. Did any interviews?

17 A. Never.

18 Q. Made any money selling anything --

19 A. No.

20 Q. -- about your experience?

21 A. No.

22 MR. SNEDDON: Nothing further.

23 THE COURT: Cross-examine?

24 MR. MESEREAU: Yes, please, Your Honor.

25

26 CROSS-EXAMINATION

27 BY MR. MESEREAU:

28 Q. Mrs. Chandler, my name is Tom Mesereau and I 5658



1 speak for Michael Jackson, okay?

2 A. Yes.

3 Q. If anything I ask you is not clear, please

4 don’t answer. Just say you don’t understand it, and

5 I’ll try to rephrase it, okay?

6 A. Okay.

7 Q. Now, in response to the prosecutor’s

8 questions, you said you entered into a stipulation

9 regarding custody of your son Jordie, correct?

10 A. Correct.

11 Q. And in response to the prosecutor’s

12 questions, you said you did it because Michael

13 Jackson told you to do it, right?

14 A. One of the people. He was one.

15 Q. Well, do you remember signing a sworn

16 declaration regarding that stipulation?

17 A. I remember signing something about custody

18 of Jordie.

19 Q. Do you remember signing a sworn declaration

20 in which you said the only reason you signed the

21 stipulation was because your ex-husband wouldn’t

22 return Jordie to you if you didn’t, right?

23 A. Correct.

24 Q. And you said further, you thought the

25 stipulation was merely for a one-week visitation

26 period, right?

27 A. Correct.

28 Q. Nowhere in that declaration did you say 5659



1 anything about Michael Jackson telling you to sign

2 anything, right?

3 A. That’s not correct.

4 Q. Would it refresh your recollection to look

5 at your declaration?

6 A. I’d be happy to.

7 MR. MESEREAU: May I approach, Your Honor?

8 THE COURT: Yes.

9 Q. BY MR. MESEREAU: Miss Chandler, have you

10 had a chance to look at that sworn declaration?

11 A. Yes, I have.

12 Q. Does it refresh your recollection about what

13 you said in the declaration?

14 A. Sort of.

15 Q. Isn’t it true you said the only reason you

16 signed it was because your ex-husband told you that

17 if you didn’t sign the stipulation, you would not

18 have Jordan returned to you, right?

19 A. That’s correct.

20 Q. You said that was the only reason, correct?

21 A. That’s not the only reason.

22 Q. Well, you signed it under penalty of

23 perjury, did you not?

24 A. I wasn’t asked who else was asking me to

25 sign it.

26 Q. Who prepared the declaration for you to

27 sign?

28 A. Evan Chandler’s attorney. 5660



1 Q. Were you represented by counsel when you

2 signed this declaration?

3 A. Oooh. I might have been.

4 Q. You actually were, weren’t you?

5 A. I -- I don’t recall.

6 Q. You were represented by counsel because you

7 were trying to set aside the stipulation in court,

8 right?

9 MR. SNEDDON: Well, Your Honor, I’m going to

10 object to that. That’s misleading as to point and

11 time, and vague.

12 MR. MESEREAU: It’s not misleading at all.

13 MR. SNEDDON: Wait a minute, Counsel.

14 Judge, I object as vague as to time as to

15 when she was represented.

16 THE COURT: All right. I’ll sustain the

17 objection. It’s an argumentative question.

18 Q. BY MR. MESEREAU: Miss Chandler, at some

19 point you hired a lawyer to help you set aside that

20 stipulation, right?

21 A. I don’t know if that was the reason why an

22 attorney was hired, if it was for that reason.

23 Q. And your attorney prepared your declaration,

24 true?

25 A. I don’t recall.

26 Q. Do you recall if the stipulation was ever

27 set aside by your attorney?

28 A. I don’t recall. 5661



1 Q. Do you recall being represented by an

2 attorney named Freeman?

3 A. Yes, I do.

4 Q. And who is Mr. Freeman?

5 A. He’s an attorney that represented me for a

6 short time.

7 Q. Do you recall asking Michael Jackson if he

8 would loan David Schwartz four million dollars?

9 A. Never.

10 Q. You say you never did that?

11 A. Never did that.

12 Q. Okay. Do you recall your ex-husband David

13 Schwartz asking you to do that?

14 A. Never.

15 Q. Do you recall him being five million dollars

16 in debt around the time you were associating with

17 Michael Jackson?

18 A. No.

19 Q. Don’t recall that at all?

20 A. Not at all.

21 Q. Okay. When you sued Michael Jackson, you

22 sued through Larry Feldman, true?

23 A. I did not sue Michael Jackson. Jordan

24 Chandler and his family were -- that was his family.

25 We did not sue Michael Jackson.

26 Q. Okay. So you never sued him yourself,

27 you’re saying?

28 A. I don’t believe that’s how it was worded. 5662



1 Q. Okay. Do you recall meetings with your

2 attorney about that lawsuit?

3 A. Yes, I do.

4 Q. Now, you -- you and Jordan’s father Evan

5 were divorced in 1985, true?

6 A. Correct.

7 Q. And you obtained sole custody of Jordan,

8 right?

9 A. Yes.

10 Q. And you had an informal arrangement where

11 Evan could have custody or at least visitation

12 rights of Jordie from time to time, correct?

13 A. Correct.

14 Q. What year did you marry David Schwartz?

15 A. 1985.

16 Q. Now, is it correct that he became Jordan’s

17 stepfather?

18 A. Correct.

19 Q. And for how long was he Jordie’s stepfather?

20 A. For approximately six to eight years.

21 Q. What year did he cease to be Jordie’s

22 stepfather?

23 A. When we divorced.

24 Q. And what year was that?

25 A. 1994.

26 Q. And how old is Jordie now?

27 A. He is 25 years old.

28 Q. Can I ask you when you last spoke to him? 5663



1 A. 11 years ago.

2 Q. At one point, David Schwartz sued Michael

3 Jackson, correct?

4 A. I don’t recall.

5 Q. Do you recall him suing Michael Jackson

6 claiming that Michael had interfered with his

7 business?

8 MR. SNEDDON: Your Honor, I’m going to

9 object as immaterial; irrelevant; calls for hearsay.

10 THE WITNESS: I don’t recall.

11 THE COURT: It’s vague as to time.

12 MR. MESEREAU: Okay. I’ll rephrase it, Your

13 Honor.

14 Q. Around the time you and Evan and Jordie sued

15 Michael Jackson with Attorney Larry Feldman, do you

16 recall your ex-husband, David Schwartz, also suing

17 Michael Jackson?

18 MR. SNEDDON: Same objection, Your Honor.

19 THE WITNESS: I don’t recall.

20 THE COURT: Overruled.

21 You may answer.

22 THE WITNESS: I don’t recall.

23 Q. BY MR. MESEREAU: Okay. Do you recall, in

24 response to your lawsuit, Mr. Jackson suing for

25 extortion?

26 MR. SNEDDON: Your Honor, I’m going to

27 object to that question.

28 THE COURT: Sustained. Foundation. 5664



1 Q. BY MR. MESEREAU: You sued Michael Jackson,

2 right?

3 A. Jordan Chandler sued Michael Jackson.

4 Q. Were you listed as a plaintiff?

5 A. Yes.

6 Q. And in response to your suit, Mr. Jackson

7 sued for extortion, true?

8 A. I don’t recall.

9 Q. Okay. Were you and Evan and Jordie all

10 represented by Larry Feldman?

11 A. Yes, we were.

12 Q. Do you know approximately when that suit

13 settled?

14 A. I guess in ‘95.

15 Q. Do you recall Evan suing Mr. Jackson a

16 second time?

17 A. No.

18 Q. Don’t know anything about that?

19 A. Nothing.

20 Q. Never heard about it?

21 A. No.

22 Q. Do you know who Attorney Barry Rothman is?

23 A. Yes.

24 Q. Who is Attorney Barry Rothman?

25 A. He was Evan Chandler’s attorney.

26 Q. Do you recall Attorney Barry Rothman also

27 suing Michael Jackson?

28 A. No, I don’t. 5665



1 Q. Okay. Now, during your trips with Michael

2 Jackson, do you recall the name “Sony” ever being

3 mentioned?

4 A. Yes.

5 Q. And in what context was Sony mentioned?

6 A. The gifts that Michael Jackson gave were

7 from Sony. Sony recorders. We flew on the Sony

8 jet. That’s what I remember.

9 Q. And do you recall, around the time you were

10 associating with Michael Jackson, that Michael

11 Jackson had an endorsement deal with PepsiCo?

12 A. Yes.

13 Q. And to your knowledge, that was the most

14 lucrative endorsement deal anyone in the music

15 business had ever entered into with PepsiCo,

16 correct?

17 A. I didn’t know that.

18 MR. SNEDDON: Your Honor, that’s immaterial

19 and irrelevant.

20 THE COURT: Foundation; sustained.

21 Q. BY MR. MESEREAU: Do you recall learning

22 from Michael Jackson that he owned an interest in

23 The Beatles’ catalog?

24 A. Yes.

25 Q. Did you discuss that with Mr. Jackson?

26 A. Never.

27 Q. Did you discuss his deal with PepsiCo with

28 Mr. Jackson? 5666



1 A. No.

2 Q. When you filed your lawsuit against Mr.

3 Jackson, your attorney was threatening to ruin Mr.

4 Jackson’s music deals, correct?

5 A. No. Not that I recall.

6 Q. You don’t recall that at all?

7 A. Not at all.

8 Q. Do you recall participating in settlement

9 negotiations?

10 A. Yes.

11 Q. And when you participated in settlement

12 negotiations, where did you used to meet?

13 A. Larry Feldman’s offices.

14 Q. When did you last talk to Larry Feldman?

15 A. Oh, a few days ago.

16 Q. Did you talk about what you were going to

17 say in court?

18 A. No.

19 Q. Did you talk about what he said in court?

20 A. Briefly.

21 Q. Did he call you or did you call him?

22 A. I called him.

23 Q. Before this discussion a few days ago, when

24 was the last time before that you had spoken to

25 Larry Feldman?

26 A. Oh, um, maybe two months before that.

27 Q. And did you talk to him about this case in

28 that discussion? 5667



1 A. Yes.

2 Q. Did you talk to him about what you were

3 going to say?

4 A. No.

5 Q. Did you call him or did he call you?

6 A. I called him.

7 Q. Did you talk on the phone with him or did

8 you meet with him?

9 A. Yes, talk on the phone.

10 Q. Before that discussion, when had you last

11 spoken to Attorney Larry Feldman?

12 A. Perhaps ten years ago.

13 Q. Okay. But you never discussed anything

14 about this case in those discussions, right?

15 A. No.

16 Q. And you never talked about what you were

17 going to be asked in this courtroom in any of those

18 discussions, right?

19 A. Not to that effect, no.

20 Q. Did Mr. Feldman tell you he represents the

21 Arvizos in either of those discussions?

22 A. I don’t know what that is.

23 Q. Okay. So he never talked about his

24 representing anyone associated with this case,

25 besides you, right?

26 A. Correct.

27 Q. Now, you said something in response to the

28 prosecutor’s questions about your son changing the 5668



1 way he dressed at one point, right?

2 A. Correct.

3 Q. Didn’t your son used to try and dress like

4 Michael Jackson before he even met him?

5 A. When he was very young.

6 Q. Did you meet with the prosecutor before you

7 testified today?

8 A. Yes.

9 Q. When did you meet with the prosecutor to

10 talk about anything you said today?

11 A. Two days ago.

12 Q. And where was that meeting?

13 A. In downtown L.A.

14 Q. And who did you meet with?

15 A. With my attorney.

16 Q. And who is your attorney?

17 A. Brad Barnholtz.

18 Q. Who else did you meet with?

19 A. Tom Sneddon.

20 Q. Okay. How long a discussion was that?

21 A. Oh, perhaps an hour and a half.

22 Q. Did you talk about what you were going to

23 say today?

24 A. Yes.

25 Q. Did Mr. Sneddon go over some questions that

26 he was going to ask you?

27 A. Yes.

28 Q. Did you ever go over some answers that you 5669



1 were going to give?

2 A. Yes.

3 Q. When had you met with Mr. Sneddon before

4 that meeting?

5 A. Never.

6 Q. Have you talked to him on the phone?

7 A. Yes.

8 Q. How many times?

9 A. Once or twice.

10 Q. Okay. Now, where did you first meet Michael

11 Jackson?

12 A. At Rent-A-Wreck. The business of my

13 ex-husband.

14 Q. And that was the day that Mr. Jackson had a

15 problem with his car, right?

16 A. Yes.

17 Q. Okay. And when did you see him after that

18 initial meeting?

19 A. I guess maybe approximately a few months

20 after that.

21 Q. The first meeting was approximately August

22 ‘92, right?

23 A. Correct.

24 Q. Okay. And when do you think the next

25 meeting was?

26 A. Perhaps maybe in February.

27 Q. Okay. And again, how did that meeting

28 happen? Who called who? 5670



1 A. How did the meeting --

2 Q. The second meeting. The first time you saw

3 him when he had a problem with his car, right?

4 A. Correct.

5 Q. And then there was a meeting after that?

6 A. Right.

7 Q. How did that happen?

8 A. Through phone conversations with my son.

9 And he -- and Michael Jackson invited us to

10 Neverland.

11 Q. Okay. How did you get to Neverland?

12 A. By car. By my car. I drove.

13 Q. Okay. And did you stay over at Neverland

14 that first time?

15 A. Yes, I did.

16 Q. How long did you stay?

17 A. I would say for two nights. One or two

18 nights.

19 Q. Okay. And your daughter was there as well,

20 right?

21 A. Yes, she was.

22 Q. Okay. And you said that you, your daughter,

23 your son, stayed in the guesthouses, correct?

24 A. Correct.

25 Q. Now, what did you do during the day during

26 that visit, during the two days you were there?

27 A. We watched movies. We went on rides. We

28 visited his zoo. Things like that. 5671



1 Q. Okay. And how did you get home? Did you

2 drive?

3 A. Yes, I did.

4 Q. When did you next talk to Michael Jackson

5 after that?

6 A. Oh, I think probably the day after we got

7 back.

8 Q. Did he call you?

9 A. Yes.

10 Q. Okay. Did you talk to him?

11 A. Yes.

12 Q. And when did you get together again?

13 A. Perhaps a week later. A week or two later.

14 Q. Did you go to Neverland again?

15 A. Yes, we did.

16 Q. How did you get there?

17 A. He drove. His -- sorry, his chauffeur

18 drove.

19 Q. Okay. And did you stay over --

20 A. Yes.

21 Q. -- on that second trip?

22 A. Yes.

23 Q. And how long was your stay over there?

24 A. A couple of nights.

25 Q. Okay. Do you remember what you did on that

26 second trip?

27 A. Same thing.

28 Q. Okay. Did you see Michael very often on the 5672



1 first trip?

2 A. The whole time, yes.

3 Q. Did you see him --

4 A. Yes.

5 Q. -- very often on the second trip?

6 A. Yes.

7 Q. When you said you went to the zoo and did

8 these fun things, was Michael always with you?

9 A. The first and second time?

10 Q. Yes.

11 A. Basically, yes.

12 Q. Okay. Did you have dinner in the main house

13 with Michael?

14 A. Yes.

15 Q. And of course your children were there too,

16 right?

17 A. Correct.

18 Q. After that second trip, when did you next

19 have contact with Michael, if you remember?

20 MR. SNEDDON: Your Honor, I’m going to

21 object to the use of the first name.

22 THE COURT: All right.

23 MR. MESEREAU: I’ll say “Michael Jackson,”

24 Your Honor.

25 Q. After your second visit to Neverland, did

26 you have further contact with Michael Jackson?

27 A. Yes, I did.

28 Q. And please explain what your next contact 5673



1 was all about.

2 A. I don’t know if that was the time we again

3 went to Neverland or we had taken a trip to Las

4 Vegas.

5 Q. Now, in your discussion with the Los Angeles

6 District Attorney in 1993, you talked about your

7 visits with Mr. Jackson, right?

8 A. Correct.

9 Q. Have you looked at that transcript recently?

10 A. Yes.

11 Q. When did you last look at the transcript?

12 A. Briefly, today.

13 Q. And how did you get a copy of it?

14 A. Through Mr. Sneddon.

15 Q. Okay. Did he ask you to read it today?

16 A. Did he ask me to read it today?

17 Q. Yes.

18 A. No.

19 Q. Did he ask you to read it at any time?

20 A. Yes, he did.

21 Q. And when was that?

22 A. Last week.

23 Q. Did he give you anything else to read before

24 you testified?

25 A. That’s it.

26 Q. Okay. And did you read it from cover to

27 cover?

28 A. Tried. 5674



1 Q. Pardon me?

2 A. Yes.

3 Q. Okay. Okay. You told the District Attorney

4 in Los Angeles when describing your first trip

5 there, “Michael Jackson wasn’t the superstar. He

6 was a regular person, and we couldn’t believe how

7 nice he was,” right?

8 A. Correct.

9 Q. And you said that after you got there, he

10 offered to let you stay over, correct?

11 A. Correct.

12 Q. Your plan initially wasn’t to stay over,

13 right?

14 A. Correct.

15 Q. You said that first night, Jordie actually

16 knocked at your door and said he was going to stay

17 with you, right?

18 A. Correct.

19 Q. So the first night he stayed with you and

20 your daughter, right?

21 A. Correct.

22 Q. Okay. Now, when did you go to Toys-R-Us

23 with Michael Jackson?

24 A. Could have been the first visit or the

25 second visit.

26 Q. Okay. And did Michael Jackson offer to take

27 you there?

28 A. Yes. 5675



1 Q. And he did take you there, right?

2 A. Yes, he did.

3 Q. Did he drive or did you have a driver take

4 you there, do you know?

5 A. We must have had a driver.

6 Q. Okay. Now, at one time, did you visit Roy

7 Disney’s widow with Michael?

8 A. Never.

9 Q. Okay. At some point you told the Los

10 Angeles District Attorney that Michael was visiting

11 Roy Disney’s widow in Beverly Hills; do you remember

12 that?

13 A. Not really, but I don’t recall.

14 Q. Do you recall telling that to the Los

15 Angeles District Attorney?

16 A. I don’t recall.

17 Q. Would it refresh your recollection to let

18 you see that page?

19 A. Yes.

20 MR. MESEREAU: May I approach, Your Honor?

21 THE COURT: Yes.

22 THE WITNESS: Thank you.

23 Q. BY MR. MESEREAU: Have you had a chance to

24 look at that?

25 A. Yes.

26 Q. Does it refresh your recollection about what

27 you told the Los Angeles District Attorney?

28 A. Yes. 5676



1 Q. And what did you tell them about that?

2 A. I said that I was -- we had left and Michael

3 was -- I had left Neverland with Jordie and Lily,

4 and he was going to visit Roy Disney’s widow.

5 Q. Okay. Now, was that while you were visiting

6 Neverland?

7 A. After we left.

8 MR. SNEDDON: Object as to vague as to time

9 as to what visit.

10 MR. MESEREAU: I’ll rephrase it.

11 Q. During what visit did Michael Jackson tell

12 you he had to visit Roy Disney’s widow?

13 A. The first visit.

14 MR. SNEDDON: Object as to hearsay.

15 THE COURT: Overruled.

16 Q. BY MR. MESEREAU: Was it the first visit?

17 A. I think so.

18 Q. Do you recall if you and your family stayed

19 at Neverland while Mr. Jackson left the premises?

20 A. I don’t recall that.

21 Q. Okay. Do you recall him making a trip like

22 that?

23 A. Yes.

24 Q. Okay. You talked about gifts that Mr.

25 Jackson gave you, okay?

26 A. Okay.

27 Q. Did you ever ask for any of those gifts?

28 A. No. 5677



1 Q. Did he just give them to you on his own

2 initiative as far as you’re concerned?

3 A. Yes.

4 Q. Okay. Tell us all the gifts you recall him

5 giving you.

6 A. A gold bracelet. A pair of earrings. A

7 necklace. A ring. A gift certificate to a

8 boutique. That’s what I recall.

9 Q. Okay. And you said he gave you his credit

10 card to use?

11 A. Yes.

12 Q. Did he do that more than once?

13 A. He might have, yes.

14 Q. And do you recall what you bought with

15 Michael Jackson’s credit card?

16 A. I know I -- I think two handbags.

17 Q. Anything else?

18 A. Not that I recall, no.

19 Q. Okay. How many nights do you recall Mr.

20 Jackson staying at your house?

21 A. To the best of my recollection, 30 nights.

22 Q. And approximately what time period was that,

23 if you know?

24 A. Beginning the middle of April till the end

25 of May.

26 Q. Were you at your house on every evening that

27 Michael Jackson stayed over?

28 A. Yes. 5678



1 Q. You said something to the effect, I believe,

2 that Mr. Jackson would leave during the day?

3 A. Correct.

4 Q. Do you know where he went?

5 A. Not really. I --

6 Q. Did you ever ask him?

7 A. Sometimes.

8 Q. Okay. And where did he tell you he was

9 going?

10 A. Going home.

11 Q. To Neverland?

12 A. Working. No, not to Neverland. I think his

13 hideout, to his place that he calls “The Hideout” in

14 Century City.

15 Q. That’s the place you visited, correct?

16 A. Correct.

17 Q. How many times were you at that apartment?

18 A. Approximately three or four times.

19 Q. Okay. When you went to the apartment that

20 you’ve described as Michael Jackson’s hideout, were

21 you always with your son?

22 A. Yes.

23 Q. Were you ever with anyone else?

24 A. Not that I recall.

25 Q. Okay. You indicated you met someone named

26 Brett Barnes at Neverland, right?

27 A. Correct.

28 Q. Do you know when you first met him? 5679



1 A. It could have been the second time that we

2 were going to Neverland.

3 Q. And he was actually in the limousine that

4 Michael Jackson sent to pick you up, right?

5 A. Correct.

6 Q. Was that the first time you had met him?

7 A. Yes.

8 Q. Okay. Was that the trip you went to

9 Disneyland?

10 A. It could be, yes.

11 Q. And was Brett Barnes with you on that trip?

12 A. I would assume so. I’m -- I don’t recall.

13 Q. Do you know if his mother was there on that

14 trip?

15 A. No.

16 Q. So it was you, Michael Jackson, your two

17 children, and Brett, right?

18 A. Perhaps Brett.

19 Q. You’re not sure?

20 A. Exactly.

21 Q. Did you go back to Neverland after the trip

22 to Disneyland?

23 A. I don’t recall.

24 Q. Okay. You indicated you met someone named

25 Joy, right?

26 A. Correct.

27 Q. And when did you meet someone named Joy?

28 A. Later on, in -- could be May. April or May. 5680



1 Q. And where did you meet her?

2 A. At Neverland.

3 Q. Okay. Was she staying there when you stayed

4 there?

5 A. Yes.

6 Q. And did she have a son, to your knowledge?

7 A. Yes, she did.

8 Q. And who was that?

9 A. Wade.

10 Q. Okay. How often did you see Joy Robeson and

11 Wade Robeson at Neverland?

12 A. I remember seeing Joy once. And Wade, I --

13 it could be a few times. I don’t recall.

14 Q. When you were at Neverland at the same time

15 that they were there, did you associate with them?

16 A. Yes.

17 Q. Okay. And what did you do with them?

18 A. I had dinner with Joy, where we talked. And

19 with Wade, if we went -- if there was a movie

20 playing, I guess he was with us also.

21 Q. When Michael Jackson used to stay at your

22 home, were you in the middle of a divorce

23 proceeding?

24 A. No.

25 Q. Were you separated?

26 A. Yes.

27 Q. Did you used to discuss your problems with

28 David Schwartz with Michael Jackson? 5681



1 A. Yes.

2 Q. You actually had a lot of discussions,

3 didn’t you?

4 A. Not a lot.

5 Q. You told him it was a poor relationship,

6 didn’t you?

7 A. What was a poor relationship?

8 Q. Your relationship with David Schwartz.

9 A. I told whom? I’m sorry.

10 Q. Michael Jackson.

11 A. Oh. No. I -- I don’t -- I didn’t get into

12 my relationship about David Schwartz to Michael.

13 Q. So you never discussed it with Michael

14 Jackson?

15 A. I just said that we were separated and these

16 were not wonderful times for us.

17 Q. And you would discuss with him from time to

18 time the problems you were having, wouldn’t you?

19 A. No. No, I wouldn’t.

20 MR. SNEDDON: Object as irrelevant, Your

21 Honor, not to mention hearsay.

22 THE COURT: Overruled. The answer was,

23 “No.” Next question.

24 Q. BY MR. MESEREAU: During those 30 nights

25 that Michael Jackson stayed at your house, did he

26 have dinner at your house?

27 A. Yes.

28 Q. And was it usually you, he, your son and 5682



1 daughter at dinner?

2 A. At times.

3 Q. Who else would join you for dinner?

4 A. That’s it.

5 Q. Did you ever have dinner yourself, without

6 your children, just with Michael Jackson?

7 A. No.

8 Q. Have you ever traveled with Michael Jackson

9 without your children?

10 A. No.

11 Q. When did you go to Las Vegas with Michael

12 Jackson?

13 A. Around the end of March.

14 Q. And what was the purpose of that trip?

15 A. I guess Steve Wynn, the owner of the Mirage

16 Hotel, invited Michael to come and stay and vacation

17 in Las Vegas for a few days.

18 Q. And did you meet Mr. Wynn while you were

19 there?

20 A. Yes, I did.

21 Q. How long were you in Las Vegas for that

22 trip?

23 A. Two or three nights.

24 Q. And again, how did you get there?

25 A. Steve Wynn’s jet.

26 Q. And did his jet take you back home

27 afterwards?

28 A. Yes. 5683



1 Q. All right. When you went to Las Vegas on

2 Steve Wynn’s jet, had Michael Jackson begun to stay

3 over at your home?

4 A. No.

5 Q. Did Michael Jackson begin to stay at your

6 home after that trip to Las Vegas?

7 A. Yes.

8 Q. Now, did you travel with Michael Jackson to

9 any other cities in America during this period of

10 time?

11 A. Yes.

12 Q. Where did you travel to?

13 A. To Florida and New York.

14 Q. Was that Orlando, Florida?

15 A. Correct.

16 Q. And when did that trip happen,

17 approximately?

18 A. Oh, approximately April, I guess.

19 Q. And what was the purpose of that trip, if

20 you know?

21 A. To go to Disney World.

22 Q. Did you do that?

23 A. Yes, we did.

24 Q. How long a trip was that?

25 A. A couple of days.

26 Q. And then did you come back?

27 A. Yes.

28 Q. The rooms in your hotel, describe the rooms, 5684



1 if you would.

2 A. I don’t remember The Grand Floridian, what

3 the rooms were like.

4 Q. And did you have your own room?

5 A. Yes.

6 Q. Did Michael Jackson have his own room?

7 A. Yes, he did.

8 Q. And did your children have their own room?

9 A. I’m not sure.

10 Q. Do you know where your children stayed?

11 A. Yes.

12 Q. Where did they stay?

13 A. Jordie, my son, stayed with Michael, and

14 Lily stayed with me.

15 Q. And did you ever object, during that trip,

16 to your son staying with Michael?

17 A. No.

18 Q. You never suspected anything improper was

19 going on on that trip, correct?

20 A. Correct.

21 Q. You mentioned some children from New Jersey

22 that you met at Neverland, right?

23 A. Correct.

24 Q. And who were they again?

25 A. Frank and Eddie Cascio.

26 Q. Okay. And did you ever meet their parents?

27 A. No.

28 Q. When did you first see them at Neverland? 5685



1 A. I don’t recall. Could be the third visit to

2 Neverland. Fourth visit.

3 Q. When was the first time your son Jordan

4 asked if he could sleep with Michael Jackson?

5 A. I would say starting the third visit to

6 Neverland, second or third visit to Neverland,

7 because there were always boys around and staying in

8 his bedroom, and why couldn’t he? And that’s when

9 he started asking.

10 Q. And was it your understanding that there

11 were a lot of kids hanging around Michael Jackson’s

12 bedroom?

13 A. Yes.

14 Q. Did you see --

15 A. Boys.

16 Q. Excuse me. Did you see a lot of kids at

17 Neverland while you were there?

18 A. A lot of Michael’s --

19 MR. SNEDDON: Excuse me.

20 Object as to vague.

21 MR. MESEREAU: I’ll rephrase it. Let’s go

22 through the first trip.

23 Q. Did you see a lot of kids at Neverland

24 during your first trip?

25 A. No.

26 Q. Did you see a lot of kids at Neverland

27 during your second trip?

28 A. No. 5686



1 Q. How many other children at Neverland did you

2 see on your first trip?

3 A. No other kids on the first trip.

4 Q. How many kids at Neverland did you see on

5 your second trip?

6 A. One.

7 Q. How about your third trip?

8 A. Third -- Frank and Eddie Cascio.

9 Q. Any other children on the third trip?

10 A. It could have been Macaulay Culkin also.

11 Q. Okay. Did you meet Macaulay Culkin at

12 Neverland?

13 A. Yes.

14 Q. Macaulay Culkin doesn’t look at all like

15 your son, does he?

16 A. No.

17 Q. Did you meet Macaulay’s parents?

18 A. Father.

19 Q. At Neverland?

20 A. Yes.

21 Q. And that was, you think, the third trip?

22 A. Could be. Could have been.

23 Q. Did you ever see him at Neverland again?

24 A. Yes.

25 Q. When did you next see Macaulay Culkin at

26 Neverland?

27 A. Fourth or fifth visit.

28 Q. Was anyone else from his family there; do 5687



1 you know?

2 A. His brothers were there.

3 Q. Okay. Was it your understanding that the

4 Culkins were good friends of Michael Jackson?

5 A. That Macaulay Culkin was good friends with

6 Michael Jackson.

7 Q. What about his family? Was it your

8 understanding his family were close friends of

9 Michael Jackson?

10 A. Not close friends.

11 Q. Did you really know?

12 A. It didn’t appear that they were close

13 friends, no.

14 Q. Do you know if his parents used to visit

15 Neverland?

16 A. His father used to visit Neverland with

17 Macaulay.

18 Q. Did you hang out with them when you were at

19 Neverland?

20 A. Did I hang out with --

21 Q. The Culkins.

22 A. No.

23 Q. Then how would you know whether or not they

24 were close with Michael Jackson?

25 MR. SNEDDON: Your Honor, I’m going to

26 object as argumentative.

27 THE COURT: Sustained.

28 Q. BY MR. MESEREAU: When you were in Las Vegas 5688



1 with Mr. Jackson, you went to Cirque du Soleil,

2 correct?

3 A. No, I did not.

4 Q. Did your son?

5 A. Yes, he did.

6 Q. And did your daughter go as well?

7 A. To Cirque du Soleil?

8 Q. Yes.

9 A. No, she did not.

10 Q. Did you have any problem at that time

11 letting your son go to Cirque du Soleil with Mr.

12 Jackson?

13 A. No.

14 Q. And did your son stay with Mr. Jackson that

15 evening, to your knowledge?

16 A. To my knowledge, yes.

17 Q. Okay. You told the prosecutor that Mr.

18 Jackson got upset at one point about your not

19 trusting him, right?

20 A. Correct.

21 Q. And he said words to you to the effect that,

22 “We’re family,” right?

23 A. Correct.

24 Q. You suggested that you let Jordie sleep

25 wherever he wants to sleep, right?

26 A. Yes.

27 Q. And you told him, “Look, I’ve had two

28 husbands that I can’t trust,” right? 5689



1 A. Correct.

2 Q. You said, “I think you’re a wonderful

3 person, but I can’t let my trust down,” right?

4 A. Correct.

5 Q. And you described Michael as saying that he

6 was going to take care of you, right?

7 A. No.

8 MR. SNEDDON: Your Honor, excuse me, I’m

9 going to object as vague as to point in time of the

10 conversation.

11 MR. MESEREAU: Sure. Sure.

12 Q. When was the conversation where Michael got

13 upset because he didn’t think you trusted him?

14 A. In Las Vegas in the hotel room.

15 Q. Okay. You said to Michael, “I’ve had males

16 in my life that, you know, have disappointed me.

17 How can I have you in my life and you’re saying that

18 you’re going to take care of us, that you’re so

19 wonderful, everything’s going to be okay, how am I

20 going to do that?”

21 MR. SNEDDON: Your Honor, I’m going to

22 object to counsel reading from the document.

23 MR. MESEREAU: I haven’t finished the

24 question yet, Your Honor.

25 MR. SNEDDON: Well, he’s reading --

26 THE COURT: Well, all right, what is the

27 question?

28 MR. MESEREAU: I was going to ask her if she 5690



1 made that statement.

2 THE COURT: All right. You may.

3 Q. BY MR. MESEREAU: Did you make a statement

4 to that effect?

5 A. Yes.

6 Q. And Michael said to you he wanted a family

7 to just treat him like a regular person, right?

8 A. Correct.

9 Q. He said he didn’t want to be like a

10 stranger, right?

11 A. Correct.

12 Q. And he asked you to trust him, right?

13 A. Yeah.

14 Q. Do you remember telling the District

15 Attorney in Los Angeles that when you talked to your

16 ex-husband Evan about Michael Jackson’s relationship

17 with your family, that Evan saw this as a wonderful

18 means for Jordie not having to worry for the rest of

19 his life?

20 A. Would you repeat your question?

21 Q. Yes. Didn’t you tell the Los Angeles

22 District Attorney that your ex-husband Evan, the

23 father of Jordie, told you that the relationship

24 with Michael was a wonderful means of Jordie not

25 having to worry for the rest of his life?

26 A. Yes.

27 Q. And to you, that meant Michael Jackson

28 supporting you financially for the rest of your 5691



1 life, correct?

2 A. No.

3 Q. That’s what you thought your ex-husband

4 meant by it, true?

5 MR. SNEDDON: Calls for speculation.

6 THE WITNESS: Speculation.

7 THE COURT: Sustained. Sustained.

8 (Laughter.)

9 Q. BY MR. MESEREAU: Just asking you what you

10 thought, not what your ex-husband thought.

11 A. Well, I’m speculating also. I would be

12 speculating if I answered.

13 Q. Well, if someone says to you, “This is a

14 wonderful way not to have to worry for the rest of

15 our life,” doesn’t that suggest that maybe someone

16 is thinking about Michael Jackson supporting you?

17 MR. SNEDDON: Your Honor, I’m going to

18 object. We just went through this. Calls for

19 speculation.

20 THE COURT: Sustained.

21 Q. BY MR. MESEREAU: When did you go to France

22 and Monaco with Michael Jackson?

23 A. In May.

24 Q. Did he invite you?

25 A. Yes.

26 Q. Did he invite your whole family?

27 A. Jordan and Lily, yes.

28 Q. At one point you said that Michael Jackson 5692



1 stayed at your ex-husband’s house when Jordan was

2 there, correct?

3 A. Correct.

4 Q. And to your knowledge, was your ex-husband

5 at the house when Michael Jackson stayed there?

6 A. Yes.

7 Q. How many days, to your knowledge, did

8 Michael Jackson stay at your ex-husband’s house?

9 A. Approximately four to seven days.

10 Q. To your knowledge, was that consecutive or

11 were they periodic visits?

12 A. Consecutive.

13 Q. And do you recall anything about your

14 ex-husband wanting Michael Jackson to finance a wing

15 on his house?

16 A. Yes.

17 Q. And to your knowledge, Michael Jackson never

18 did that, right?

19 A. No.

20 Q. Now, at that point in time, Jordan’s father

21 Evan was writing a screenplay, right?

22 A. Correct.

23 Q. And to your knowledge, he was spending a lot

24 of time on that screenplay, right?

25 A. Yes.

26 Q. And you were complaining that he wasn’t

27 spending enough time with his son, right?

28 A. Correct. 5693



1 Q. At the time you were happy that Michael was

2 around, because Jordan’s father was not spending

3 time with him, and you were separated from David,

4 correct?

5 A. True.

6 MR. SNEDDON: I’m going to object as to

7 vague as to what time, time period. We have several

8 months here.

9 MR. MESEREAU: Well, I can --

10 THE COURT: Sustained.

11 MR. MESEREAU: Okay.

12 MR. SNEDDON: Move to strike the answer.

13 THE COURT: Stricken.

14 Q. BY MR. MESEREAU: Did there come a time when

15 you were happy that Michael Jackson was around,

16 because your ex-husband Evan was spending time

17 writing a screenplay and you were separated from

18 David?

19 A. Correct.

20 Q. Approximately what -- when was that?

21 A. In the beginning I was happy.

22 Q. Okay. When did Michael go to Cartier and

23 buy you that jewelry?

24 A. When we went to Las Vegas.

25 Q. Was he with you when he did that?

26 A. No.

27 Q. Did he do it on his own?

28 A. He did it with Jordie. 5694



1 Q. Okay. And did he come back and give it to

2 you?

3 A. Yes.

4 Q. Okay. Now, you described that to the Los

5 Angeles District Attorney as a love bracelet, did

6 you not?

7 A. Yes.

8 Q. Is that what it was?

9 A. Yes.

10 Q. What is a love bracelet?

11 A. It’s a bracelet that’s a gold bracelet and

12 that’s what it’s called.

13 Q. Okay. Had you ever told Michael Jackson you

14 liked that kind of jewelry?

15 A. No.

16 Q. Were you surprised when he bought it for

17 you?

18 A. Yes.

19 Q. Okay. Now, you mentioned that during that

20 trip, you went to the David Copperfield show; is

21 that right?

22 A. Correct.

23 Q. And who went to that show?

24 A. Jordan, Lily and Michael.

25 Q. Did the four of you have dinner that night

26 together?

27 A. I don’t recall.

28 Q. Okay. Did Michael give you his credit card 5695



1 on that trip?

2 A. No.

3 Q. Okay. At some point did you all see an

4 Exorcist movie?

5 A. No.

6 Q. Do you recall anyone watching an Exorcist

7 movie?

8 A. I was told Jordan and Michael watched an

9 Exorcist movie.

10 Q. All right. Did you ever object to Jordie

11 sleeping in Michael’s room on that trip?

12 A. Yes.

13 Q. And what did you say?

14 A. “Jordie, when you come home, go to your bed.

15 Go to your own bed. Come to our bed, not to

16 Michael’s bed.”

17 He said, “Mom, I want to stay there.” And I

18 was very upset about that.

19 Q. Now, this was before the approximately 30

20 nights that he stayed at your home --

21 A. Yes.

22 Q. -- in Santa Monica, right?

23 A. Correct.

24 Q. And you did allow him to stay at your home

25 in Santa Monica, right?

26 A. Afterwards.

27 Q. Now, you mentioned in your interview that

28 when Michael Jackson’s not working, he’s a lonely 5696



1 person, correct?

2 A. Correct.

3 Q. And you also mentioned that the Cascios

4 owned a restaurant, true?

5 A. True.

6 Q. How did you know they owned a restaurant?

7 A. I was -- I don’t recall how I knew.

8 Q. And do you remember telling the District

9 Attorney that Michael would help Jordie with his

10 homework?

11 A. Correct.

12 Q. Would he do that at your home?

13 A. Yes.

14 Q. You also said he played a lot like a child,

15 correct?

16 A. Correct.

17 Q. And he seemed to play at Neverland a lot

18 like a child, correct?

19 A. Yeah, yes.

20 Q. You mentioned Tommy and Merdie. Do you

21 remember that?

22 A. Yes.

23 Q. And who are Tommy and Merdie?

24 A. Merdie; are my brother and sister-in-law.

25 Q. Okay. At some point you stayed in Santa

26 Monica with them, correct?

27 A. Yes.

28 Q. Was Michael Jackson there? 5697



1 A. He was there.

2 Q. Did Michael Jackson stay with you at their

3 home?

4 A. No.

5 Q. Did he stay at their home?

6 A. No.

7 Q. Did he stay at your home?

8 A. Not that time, no. Not at that time.

9 Q. And you stayed in Santa Monica with Tommy

10 and Merdie?

11 A. Meredith. Merdie.

12 Q. Merdie, okay. You stayed with them at one

13 point, right?

14 A. They stayed with me.

15 Q. Oh, they stayed with you?

16 A. Yes.

17 Q. Was Michael Jackson there that night?

18 A. I don’t recall, no.

19 Q. Okay. To your knowledge, did Michael

20 Jackson ever meet Tommy and Merdie?

21 A. I don’t recall.

22 Q. Okay. Now, when Michael Jackson was staying

23 at your home in Santa Monica during those 30 days

24 that you mentioned, was Jordan in school?

25 A. Yes, he was.

26 Q. Was he going to school each day?

27 A. Yes, he was.

28 Q. Okay. You mentioned Steve and Jo Ellen. Do 5698



1 you remember that?

2 A. Do I remember mentioning --

3 Q. Mentioning Steve and Jo Ellen to the

4 District Attorney?

5 A. Yes.

6 Q. Who are Steve and Jo Ellen?

7 A. Steve is also my brother, and his wife Jo

8 Ellen.

9 Q. Did they visit you in Santa Monica during

10 the time that Michael Jackson was staying over?

11 A. No.

12 Q. You said that they witnessed Michael Jackson

13 and Jordie in the bedroom, didn’t they?

14 A. Correct.

15 Q. When was that?

16 A. At Neverland.

17 Q. Did they stay there?

18 A. No.

19 Q. Okay. Did they go into Michael Jackson’s

20 bedroom?

21 A. Yes, they did.

22 Q. And did you go into Michael Jackson’s

23 bedroom?

24 A. Yes.

25 Q. How many times do you think you went into

26 Michael Jackson’s bedroom at Neverland?

27 A. It stopped after maybe the tenth time.

28 Q. Okay. Describe, if you would for the jury, 5699



1 what Michael Jackson’s bedroom looks like?

2 A. Lots of dolls. Lots of playthings. It

3 looks like a boy’s room, big boy’s room. Lots of

4 toys and things.

5 Q. Is it a big area?

6 A. Yes.

7 Q. How big would you describe it as, if you

8 can?

9 A. Oh, it’s a long time ago.

10 Q. Was it kind of huge?

11 A. Well, there’s an upstairs and a downstairs.

12 Yes, it’s kind of huge.

13 Q. When you used to visit Michael Jackson’s

14 bedroom, would you see other people in there?

15 A. Yes.

16 Q. Who do you remember seeing in there?

17 A. The Cascio brothers. Macaulay. Brett.

18 Wade.

19 Q. And you saw their parents in there, too,

20 didn’t you?

21 A. No.

22 Q. Did you ever see Macaulay’s father in there?

23 A. In the bedroom?

24 Q. Yes.

25 A. No.

26 Q. And why were you in the bedroom those ten

27 times?

28 A. Because I’m Jordie’s mother. I’m allowed to 5700



1 go into the bedroom.

2 Q. Were you dropping clothes off?

3 A. Oh, I might have. I don’t recall.

4 Q. Did you ever sit down and watch T.V. or

5 anything in there?

6 A. Yes.

7 Q. How often did you do that?

8 A. A few times.

9 Q. Did you ever have food delivered to you in

10 Michael Jackson’s bedroom?

11 A. I don’t recall.

12 Q. Okay. Did David Schwartz, to your

13 knowledge, ever visit Neverland?

14 A. No. No.

15 Q. Okay. When you were in Monaco with Michael

16 Jackson, what did you do?

17 A. We went to an awards ceremony. We -- well,

18 Jordie and Michael -- Jordie and Michael were sick,

19 so Lily and I went shopping and drove around. We

20 were driven around.

21 Q. Did Michael Jackson pay for the whole trip?

22 A. Yes, the trip was paid for. I don’t know

23 who paid for it.

24 Q. To your knowledge, did Michael Jackson pay

25 for it?

26 A. No. No. It was an awards. I think he was

27 given tickets to attend this award because he was

28 receiving some kind of -- 5701



1 Q. Who paid for your hotel room, if you know?

2 A. I don’t know.

3 Q. Now, you indicated that at one point Jordie

4 and Michael had the flu, right?

5 A. Correct.

6 Q. And where did you find out they had the flu?

7 A. In the hotel room.

8 Q. And were they staying in the same room at

9 that point?

10 A. Yes, they were.

11 Q. Did you ever complain about that?

12 A. Yes.

13 Q. And what happened?

14 A. The room was boarded up. I couldn’t get in

15 there. It started to get weird now. Things started

16 to go downhill pretty quickly.

17 Q. Did you ever take your son and leave on your

18 own?

19 A. No.

20 Q. After you got back from Monaco, did Michael

21 Jackson spend nights at your home?

22 A. Yes.

23 Q. Were the 30 nights you’ve described after

24 you got back from Monaco?

25 A. No.

26 Q. How many nights after you got back from

27 Monaco do you think Michael Jackson stayed at your

28 home? 5702



1 A. Oh, perhaps a week or two.

2 Q. And this was a point where you were getting

3 upset that your son wanted to spend all of his time

4 with Michael Jackson, right?

5 A. Yes.

6 Q. Now, while you were in Monaco, you never saw

7 Michael Jackson and your son ever take a bath

8 together, right?

9 A. No.

10 Q. You never saw them shower together, right?

11 A. No.

12 Q. And when did you go to France on that trip?

13 A. I think that was in May.

14 Q. And what was the purpose of that trip, if

15 you know?

16 A. To get an award. He was receiving an award.

17 Q. Was that after the trip to Monaco or before?

18 A. I’m sorry?

19 Q. Was that after the trip to Monaco?

20 A. What was? What are you asking?

21 Q. The trip to France you described. Was there

22 a --

23 A. That is the trip.

24 Q. That’s the trip?

25 A. Yes.

26 Q. It was all in Monaco?

27 A. Monaco, yes.

28 Q. Did you ever go anywhere else? 5703



1 A. We went to Euro Disney also, outside of

2 Paris.

3 Q. Was the trip to Euro Disney after you were

4 in Monaco for the awards or before it, if you know?

5 A. To the best of my recollection, it was after

6 the awards.

7 Q. And how much time did you spend on that

8 portion of the trip?

9 A. I would say a couple of nights.

10 Q. Okay. Now, one point you visited Evan,

11 Jordan’s father, at his home when Michael Jackson

12 was there, right?

13 A. I don’t recall.

14 Q. Do you recall seeing Evan and Michael in a

15 squirt-gun-type fight?

16 A. That was my home, sir.

17 Q. That was your home?

18 A. Yes.

19 Q. So Evan had come to your home at that point?

20 A. Correct.

21 Q. Okay. And Evan, Michael and Jordie were in

22 a squirt gun fight, right?

23 A. Along with his other son Nicky.

24 Q. Okay. And you got upset a little bit at

25 that, right?

26 A. Yes.

27 Q. Okay. How did you learn that Michael

28 Jackson was going to stay over at Evan’s house? 5704



1 A. Through my son Jordan.

2 Q. And approximately when did that occur?

3 A. After the trip to Monaco, I think.

4 Q. How many visits, to your knowledge, did

5 Michael Jackson make to Evan’s house?

6 A. To my knowledge -- to the best of my

7 recollection, one or two visits.

8 Q. Okay. And to your knowledge, did he spend

9 the night there?

10 A. Yes, he did.

11 Q. To your knowledge, did Jordan spend the

12 night there?

13 A. Yes, he did.

14 Q. And to your knowledge, was Evan there both

15 nights?

16 A. To the best of my knowledge, yes.

17 Q. Jordan never missed school while Michael

18 Jackson was staying at your home, right?

19 A. To the best of my recollection, no, he did

20 not miss school.

21 Q. Okay.

22 A. There might have been one or two days where

23 he missed, but --

24 Q. Okay. You said that Michael Jackson saw you

25 in New York at one point?

26 A. Yes.

27 Q. And when was that?

28 A. In June, the middle of June. 5705



1 Q. Was he staying at the same hotel you were

2 at?

3 A. He arrived after we were there, yes.

4 Q. Did you know in advance he was going to be

5 staying at the same hotel?

6 A. Yes.

7 Q. And how did you know he was going to be

8 staying at the same hotel as you and your children?

9 A. His secretary informed me.

10 Q. Did he pay for those hotel rooms, to your

11 knowledge?

12 A. I don’t know who paid for the hotel rooms.

13 Q. Did you?

14 A. No.

15 Q. And which hotel was this?

16 A. The Rega Royal Hotel in New York City.

17 Q. And how long did you stay at that hotel --

18 A. Oh, perhaps --

19 Q. -- on that trip?

20 A. -- four nights.

21 Q. Okay. Was Mr. Jackson there during the four

22 nights, to your knowledge?

23 A. Part -- part of those nights, yes.

24 Q. Okay. And did you introduce Mr. Jackson to

25 other members of your family on that trip?

26 A. I don’t recall.

27 Q. Did you mention your brothers were there on

28 that trip? 5706



1 A. They were in New York, yes.

2 Q. Okay. Did they come to your hotel; do you

3 know?

4 A. I don’t recall.

5 Q. Okay. Do you know whether or not Michael

6 met your brothers on that trip?

7 A. I don’t recall that, no.

8 Q. Okay. And what month are we in now, if you

9 know?

10 A. June. In June.

11 Q. Okay. And just to clarify, the first time

12 Mr. Jackson ever stayed at your home in Santa Monica

13 was what month?

14 A. In April.

15 Q. Okay. Do you remember telling Michael

16 Jackson, “You’re like a magnet?”

17 A. I don’t recall.

18 Q. Do you remember telling Michael Jackson,

19 “You’re like Peter Pan. Everybody wants to be

20 around you and spend 24 hours”?

21 A. Yes.

22 Q. You told him, “Lily would too, except she’s

23 not old enough”?

24 A. Yes.

25 Q. Now, you said there was an incident in a

26 room in New York, right?

27 A. Correct.

28 Q. And did you actually see what happened? 5707



1 A. No.

2 Q. When did you learn what happened in the

3 room?

4 A. In the morning I saw lamps, two lamps were

5 broken.

6 Q. Okay. And Michael told you he had kicked

7 the two lamps, right?

8 A. My son said that Michael Jackson did a

9 karate kick and kicked the lamps.

10 Q. Actually, Michael told you that, too, didn’t

11 he?

12 A. I don’t recall.

13 Q. Would it refresh your recollection to show

14 you what you said to the District Attorney?

15 A. Thank you. Yes.

16 MR. MESEREAU: May I approach, Your Honor?

17 THE COURT: Yes.

18 THE WITNESS: Correct.

19 Q. BY MR. MESEREAU: Have you had a chance to

20 look at that page?

21 A. Yes, I have.

22 Q. Does it refresh your recollection --

23 A. Yes.

24 Q. -- about what you said?

25 Michael told you he kicked the two lamps

26 practicing karate, right?

27 A. Correct.

28 Q. And he said he would pay for it, right? 5708



1 A. Correct.

2 Q. And you said to him, “Lily told me a

3 different story,” right?

4 A. Correct.

5 Q. But Lily told you they were just playing,

6 correct?

7 A. Correct.

8 Q. Now, when do you remember meeting Bert

9 Fields for the first time?

10 A. Sometime in August.

11 Q. Was Michael Jackson still spending evenings

12 at your home in August?

13 A. No.

14 Q. When had he stopped spending evenings at

15 your home, if you know?

16 A. I would say late June.

17 Q. And had you heard of who Bert Fields was

18 before that meeting?

19 A. No.

20 Q. You weren’t aware he’s one of the best-known

21 entertainment lawyers in Los Angeles?

22 A. I was told that by Michael Jackson.

23 Q. And how long was your meeting with Bert

24 Fields?

25 A. I don’t recall. It could be an hour.

26 Q. And that’s where Mr. Pellicano was present?

27 A. I don’t recall.

28 Q. Okay. Is that the only time you’ve ever met 5709



1 with Bert Fields, to your knowledge?

2 A. I don’t recall.

3 Q. In the sworn declaration you filed regarding

4 your attempt to set aside that stipulation, is there

5 any reason why you didn’t mention Mr. Fields, Mr.

6 Pellicano or Mr. Jackson in that declaration?

7 A. Is my -- I don’t understand the question.

8 Q. That’s where you said the only reason you

9 signed the stipulation was because of what your

10 ex-husband threatened you with.

11 A. Correct.

12 Q. But you told the jury initially that the

13 reason you signed it was because Michael Jackson

14 wanted you to sign it, true?

15 A. Correct.

16 Q. That’s not contained in your declaration, is

17 it?

18 A. No.

19 MR. SNEDDON: Objection. Asked and answered

20 and argumentative.

21 THE COURT: Sustained.

22 Q. BY MR. MESEREAU: You didn’t mention Mr.

23 Fields or Mr. Pellicano either in that declaration,

24 right?

25 MR. SNEDDON: Same objection, Your Honor.

26 THE COURT: Overruled.

27 Q. BY MR. MESEREAU: Right?

28 THE COURT: You may answer. 5710



1 THE WITNESS: Correct.

2 Q. BY MR. MESEREAU: When had you separated

3 from David Schwartz?

4 A. Around August of ‘92, approximately.

5 Q. Do you remember complaining that Evan,

6 Jordan’s father, had promised him money for helping

7 him write the screenplay?

8 A. Yes.

9 Q. And you complained that Evan had not paid

10 Jordan the money he owed him, true?

11 A. I didn’t complain. It was a statement.

12 Q. Well, you asked him to pay him the money,

13 right?

14 A. No, I did not.

15 Q. You didn’t tell him he owed your son $5,000?

16 A. It was a discussion.

17 Q. Okay. Did you want him to pay him that

18 money?

19 A. It would have been a nice thing, yes.

20 Q. He didn’t do it, did he?

21 A. No, he did not.

22 Q. Now, you mentioned a gift certificate for

23 $7,000 --

24 A. Yes.

25 Q. -- that you got from Michael Jackson, right?

26 A. Yes.

27 Q. And did you go to Fred Segal and use that

28 gift certificate? 5711



1 A. Yes.

2 Q. What did you get with it?

3 A. Oh, clothes, jewelry. That’s it.

4 Q. That’s it?

5 A. Yes.

6 Q. Okay. Before today, when is the last time

7 you ever saw Mr. Jackson?

8 A. Oh, ten years ago.

9 Q. Okay.

10 A. Eleven years ago.

11 Q. Have you talked to Evan at all about what

12 you’re saying in court today?

13 A. No.

14 Q. When is the last time you spoke to him?

15 A. Ten years ago.

16 Q. To your knowledge, did Michael Jackson ever

17 stay at David Schwartz’s home?

18 A. No.

19 Q. Did he ever visit there, to your knowledge?

20 A. No. Not that I recall.

21 Q. Other than the first time when you met Mr.

22 Jackson at David Schwartz’s rental car company, do

23 you recall ever seeing Michael Jackson meeting with

24 David Schwartz?

25 A. No.

26 Q. Do you remember Evan threatening David

27 physically?

28 A. Yes. 5712



1 Q. And when did that happen?

2 MR. SNEDDON: Your Honor, I’m going to

3 object as immaterial.

4 THE COURT: Sustained.

5 Q. BY MR. MESEREAU: Approximately when did you

6 get settlement money from the settlement with

7 Michael Jackson?

8 A. Oh, I would say approximately October of

9 ‘93.

10 Q. Have you received any settlement money since

11 then?

12 A. No.

13 Q. You mentioned to the District Attorney in

14 Los Angeles a meeting Michael Jackson had with

15 Elizabeth Taylor and Nelson Mandela. Do you

16 remember that?

17 A. Correct.

18 MR. SNEDDON: Your Honor, I object as

19 immaterial.

20 THE COURT: Sustained.

21 Q. BY MR. MESEREAU: Do you remember, was

22 Jordie with Michael at that meeting?

23 A. I don’t recall.

24 Q. David Schwartz was also at the apartment

25 that Michael Jackson owned in Century City that you

26 called “The Hideout,” right?

27 A. Correct.

28 Q. And approximately when was that meeting? 5713



1 MR. SNEDDON: Your Honor, I’m going to

2 object as vague as to time. What meeting?

3 MR. MESEREAU: I’ll rephrase it.

4 Q. When, to your knowledge, did David Schwartz

5 visit Michael Jackson’s home in Century City that

6 you call “The Hideout”?

7 A. It could be late August, early September.

8 Q. Who else was there when you got to the

9 apartment?

10 A. I don’t recall who else was there.

11 Q. Do you remember in your meeting with Mr.

12 Pellicano telling Mr. Pellicano, “Well, it’s Michael

13 Jackson. I know Evan. It could be money. It could

14 be”?

15 MR. SNEDDON: Object as hearsay, Your Honor.

16 THE COURT: Sustained.

17 Q. BY MR. MESEREAU: Did you ever personally

18 tell Mr. Pellicano that Evan’s concerns could be

19 only about money?

20 MR. SNEDDON: Same objection, Your Honor.

21 THE COURT: Sustained.

22 Q. BY MR. MESEREAU: Was your lawyer, Michael

23 Freeman, at that meeting with Mr. Pellicano?

24 A. I believe so.

25 Q. Is that the same meeting Bert Fields was

26 present?

27 A. I don’t recall, but possibly. Quite

28 possibly. 5714



1 Q. If your lawyer, Michael Freeman, was at the

2 meeting, you must have been able to get legal advice

3 about what to sign, right?

4 MR. SNEDDON: I’m going to object to that

5 question. Assumes facts and calls for speculation.

6 Can I throw in argumentative, too?

7 THE COURT: The objection is sustained.

8 Q. BY MR. MESEREAU: Did you ask Attorney

9 Michael Freeman to be at the meeting?

10 A. No. I don’t recall.

11 Q. Do you know how he got there?

12 A. I don’t think he was there.

13 MR. SNEDDON: I’m going to object to that

14 question. She has not said he was there. Assumes

15 facts.

16 MR. MESEREAU: She did. She did.

17 THE WITNESS: I don’t recall him being

18 there.

19 THE COURT: Just a moment.

20 Objection sustained.

21 Q. BY MR. MESEREAU: Who is Michael Freeman?

22 A. An attorney. My attorney.

23 Q. And when did you first meet Michael Freeman?

24 A. Oh, I don’t recall when.

25 Q. Did he represent you at some point during

26 the time period you’ve described today?

27 A. At some point, yes.

28 Q. And he was your personal lawyer -- 5715



1 A. Correct.

2 Q. -- is that right?

3 You mentioned -- actually, let me ask you

4 this: Did you mention Norma Stakos earlier?

5 A. Yes, I did.

6 Q. Where did you meet Norma Stakos?

7 A. I’ve never met Norma Stakos.

8 Q. Have you ever spoken to her?

9 A. Yes.

10 Q. In what context did you speak to Norma

11 Stakos?

12 A. By telephone, about where we should meet, or

13 when Michael Jackson is coming in to New York, or

14 things like that.

15 Q. Did she seem to be the person that arranged

16 your trips?

17 A. Everything. Everything.

18 Q. Did she seem to be the person who would get

19 plane tickets, for example?

20 A. Absolutely, yes.

21 Q. Would she be the person who would arrange

22 transportation on your trips with Michael Jackson?

23 A. Yes.

24 Q. Okay. Do you remember at your meeting with

25 Mr. Pellicano, that Mr. Pellicano said, “This is all

26 extortion”?

27 MR. SNEDDON: Your Honor, I’m going to

28 object to that question. Calls for hearsay. 5716



1 THE COURT: Sustained.

2 Q. BY MR. MESEREAU: Now, at the time you met

3 Mr. Fields and Mr. Pellicano, to your knowledge, did

4 Evan have his own attorney?

5 A. I don’t recall.

6 Q. At some point during the time you were

7 represented by Larry Feldman, do you recall Evan

8 also having another lawyer?

9 A. I don’t recall that.

10 Q. Do you recall the name Barry Rothman?

11 A. Yes.

12 Q. And where did you first hear about Barry

13 Rothman?

14 A. Before Larry Feldman. That was Evan’s

15 attorney.

16 Q. Now, at some point were you represented by

17 Attorney Gloria Allred?

18 A. Two seconds. For two seconds.

19 Q. It was a little bit more than that, wasn’t

20 it?

21 A. Two hours.

22 (Laughter.)

23 Q. You and Evan and Jordan were represented by

24 Gloria Allred initially, correct?

25 A. Initially.

26 Q. You had meetings with her, correct?

27 A. One or two, yes.

28 Q. And then you went to Attorney Larry Feldman, 5717



1 right?

2 A. He came into the picture, yes.

3 Q. Okay.

4 A. Yes.

5 Q. Do you know approximately when Gloria Allred

6 represented you, Evan and Jordie?

7 A. Before Larry Feldman.

8 Q. Do you know approximately --

9 A. No.

10 Q. -- what year that was?

11 A. Yes, ‘94.

12 Q. Okay. Were you referred to Gloria Allred by

13 someone?

14 A. No.

15 Q. How did you wind up being represented by

16 her?

17 MR. SNEDDON: Your Honor, I’m going to

18 object as immaterial.

19 THE COURT: Sustained.

20 Q. BY MR. MESEREAU: How many times did you

21 meet with Mr. Pellicano?

22 A. Approximately three times. Three to four

23 times.

24 Q. Do you know where those meetings took place?

25 A. As far as I recall, in his office.

26 Q. Did you travel to his office?

27 A. Yes, I did.

28 Q. Were you there with your attorney, Michael 5718



1 Freeman, ever?

2 A. I don’t think so, no, no.

3 Q. Did you have discussions with Mr. Pellicano?

4 A. Yes.

5 Q. Did you ever believe he was your

6 investigator?

7 A. Yes.

8 Q. And when was that?

9 A. When we had meetings.

10 Q. When you had meetings with Mr. Pellicano,

11 you had already retained Michael Freeman as your

12 lawyer, hadn’t you?

13 A. I don’t think so, no.

14 Q. What month do you think you first saw Mr.

15 Pellicano?

16 A. In August. Approximately August.

17 Q. The declaration I referred to earlier was

18 signed on August 10th, 1993, correct?

19 A. Okay. Yes.

20 Q. And it’s on Freeman & Golden, Lawyers,

21 stationery, correct?

22 A. I guess so.

23 Q. Would it refresh your recollection if I show

24 you the declaration?

25 A. Thank you.

26 MR. MESEREAU: May I approach, Your Honor?

27 THE COURT: Yes.

28 THE WITNESS: That’s correct. 5719



1 Q. BY MR. MESEREAU: (Indicating.)

2 A. Thank you.

3 Q. Have you had a chance to look at the

4 declaration?

5 A. Yes.

6 Q. And does it appear that that declaration was

7 signed August 10th, 1993?

8 A. Yes, it was.

9 Q. And it’s on Freeman & Golden, Lawyers,

10 stationery, correct?

11 A. Correct.

12 Q. And your lawyer helped you prepare this

13 declaration, true?

14 A. Correct.

15 Q. Was Michael Freeman representing you in your

16 domestic dispute with Evan?

17 A. No. I don’t recall. I don’t recall.

18 Q. When did he stop representing you, if you

19 know?

20 A. Shortly thereafter. Not --

21 Q. Okay. Now, was Michael Freeman representing

22 you when Gloria Allred was representing you?

23 A. I don’t recall.

24 Q. Was Michael Freeman representing you when

25 Larry Feldman was representing you?

26 A. No.

27 Q. Do you recall at one point meeting with

28 Robert Shapiro? 5720



1 A. Yes.

2 Q. And when was that?

3 A. In Larry Feldman’s office.

4 Q. How many meetings did you have with Robert

5 Shapiro?

6 A. I don’t recall.

7 Q. Do you know why he was at the meeting?

8 A. I -- I think as part of Michael Jackson’s

9 legal team.

10 Q. Who, Robert Shapiro?

11 A. I think so. I don’t recall.

12 Q. Okay.

13 A. It was so long ago.

14 Q. Well, he was there because Michael Jackson’s

15 attorneys were claiming extortion, right?

16 A. I don’t recall.

17 Q. Robert Shapiro was there because he’s a

18 criminal defense lawyer, right?

19 MR. SNEDDON: Your Honor, excuse me. I want

20 to interpose an objection before the next question

21 comes out. Speculation. She says she doesn’t have

22 any recollection of this, so why Mr. Shapiro --

23 THE COURT: Stop talking. You’re just

24 supposed to give your grounds for the objection.

25 MR. SNEDDON: I’m sorry. Object.

26 Speculation.

27 THE COURT: All right. Overruled.

28 The question -- the last question, would the 5721



1 court reporter read it back, please?

2 (Record read.)

3 THE COURT: You may answer.

4 THE WITNESS: Correct.

5 Q. BY MR. MESEREAU: Do you remember also in

6 your meetings, meeting -- excuse me, let me rephrase

7 that.

8 In the meetings you’ve described with Larry

9 Feldman, Michael Freeman, Robert Shapiro, do you

10 also remember a lawyer named Richard Hirsch being

11 present?

12 MR. SNEDDON: Your Honor, I’m going to

13 object as to all those people and compound.

14 THE COURT: It’s vague.

15 We’ll take our break now.

16 (Recess taken.)

17 THE COURT: Mr. Mesereau.

18 MR. MESEREAU: Thank you, Your Honor.

19 Q. Just very briefly, you and Evan hired

20 attorneys and tried to negotiate a financial

21 settlement before you ever talked to any police

22 officer, right?

23 A. No.

24 Q. You were negotiating for money before you

25 ever reported anything to any police officer in Los

26 Angeles, correct?

27 A. Not correct.

28 Q. Do you know the dates you hired your 5722



1 attorneys?

2 A. After we spoke with the police.

3 Q. You’re saying that under oath?

4 A. That’s what I believe, yes.

5 Q. You don’t know that for sure, do you?

6 A. I’m sure.

7 Q. Your negotiations went on long before you

8 ever went to any police officer in Los Angeles,

9 true?

10 A. False.

11 Q. Do you know when you first went to any

12 police officer?

13 A. After the police, after we spoke to the

14 police.

15 Q. It was after you spoke to Larry Feldman on a

16 number of visits, correct?

17 A. Not correct.

18 Q. It was actually Larry Feldman who contacted

19 the police, wasn’t it?

20 A. No.

21 Q. You didn’t talk to any prosecutor in Los

22 Angeles before you retained Gloria Allred, correct?

23 A. Yes. Correct.

24 Q. You didn’t talk to any police officer in Los

25 Angeles before retaining Gloria Allred, correct?

26 A. Can you backtrack a bit? Can you --

27 Q. You retained Gloria Allred before you ever

28 contacted any police officer in Los Angeles, true? 5723



1 A. Not true.

2 Q. Who did you contact in the LAPD before you

3 hired Gloria Allred?

4 A. The police department. LAPD.

5 Q. You didn’t give any police statement before

6 negotiations had already begun to settle the case,

7 true?

8 A. Not correct.

9 Q. Did you call them yourself?

10 A. Did I call?

11 Q. The police yourself?

12 A. Department of Children Services.

13 Q. How about police?

14 A. No. Department of children Services.

15 Q. I’m asking you about the police.

16 MR. SNEDDON: It’s argumentative, Your

17 Honor.

18 THE COURT: Overruled.

19 Q. BY MR. MESEREAU: You were negotiating for

20 money --

21 THE COURT: Just a minute.

22 MR. MESEREAU: Oh, pardon me.

23 THE COURT: All right. She did answer it

24 before the objection. Go ahead, Counsel, next

25 question.

26 Q. BY MR. MESEREAU: You said you contacted

27 Department of Children Services, correct?

28 A. Yes. 5724



1 Q. That’s not the police department, is it?

2 MR. SNEDDON: That’s argumentative, Your

3 Honor. And assumes facts not in evidence.

4 THE COURT: Sustained; argumentative.

5 Q. BY MR. MESEREAU: And you contacted

6 Department of Children’s Services after first

7 talking to a lawyer, true?

8 A. Not correct.

9 Q. In fact, you personally never called the

10 police department, ever, about anything involving

11 Mr. Jackson, true?

12 A. True.

13 Q. When did you first hire Gloria Allred?

14 A. After we spoke to the District Attorney.

15 Q. When did you first hire Larry Feldman?

16 A. After the police were notified, Department

17 of Children’s Services, and Lauren Weis, the

18 District Attorney.

19 Q. Your strategy was to negotiate a settlement

20 before ever contacting law enforcement, true?

21 A. No strategy, sorry.

22 Q. And one of the levers you were trying to

23 hang over Mr. Jackson was bad publicity if he didn’t

24 pay, right?

25 A. Incorrect.

26 Q. Okay. When you talked to Mr. Sneddon, did

27 he ever show you the dates when you contacted your

28 first lawyer in this case? 5725



1 A. No.

2 Q. When you talked to Mr. Sneddon, did he ever

3 show you the dates before any contact was ever made

4 to a police officer?

5 A. No.

6 Q. Do you know when your civil case was first

7 filed?

8 A. I’m not sure of the exact date.

9 Q. Do you know who filed it?

10 A. I’m not exactly sure. Sorry.

11 Q. Okay. Do you know when you first contacted

12 Department of Children’s Services?

13 A. Sometime in August.

14 Q. You don’t know when you hired Gloria Allred,

15 correct?

16 A. Correct.

17 Q. Do you know if Gloria Allred contacted

18 Department of Children Services?

19 A. I don’t know that.

20 Q. Do you know when Evan first hired Barry

21 Rothman?

22 A. I do not know that.

23 Q. He hired Barry Rothman before any report was

24 made to DCFS, correct?

25 A. I don’t know.

26 MR. SNEDDON: I’m going to object. Calls

27 for speculation.

28 THE COURT: Sustained. 5726



1 Q. BY MR. MESEREAU: When did you first hire

2 Attorney Michael Freeman?

3 MR. SNEDDON: Object as asked and answered.

4 THE COURT: I believe she said she didn’t

5 know.

6 MR. MESEREAU: Okay. No further questions.

7 THE COURT: All right.

8

9 REDIRECT EXAMINATION

10 BY MR. SNEDDON:

11 Q. Mrs. Chandler, do you know whether or not in

12 Los Angeles, that the Los Angeles Police Department

13 has sworn peace officers attached to the Child Abuse

14 Unit in the Department of Child Services?

15 A. Correct.

16 Q. Sorry?

17 A. Yes, I do.

18 Q. Were those the people that you talked to

19 when you were interviewed?

20 A. Yes, they were.

21 Q. And do you have a recollection at this

22 present time as to specifically when in August you

23 interviewed with them?

24 A. Specifically, no.

25 Q. Would it refresh your recollection if I

26 showed you a document about that interview?

27 A. Yes.

28 MR. SNEDDON: May I approach, Your Honor? 5727



1 THE COURT: Yes.

2 THE WITNESS: Okay. Thank you.

3 Q. BY MR. SNEDDON: Does that refresh your

4 recollection?

5 A. Yes, it does.

6 Q. With regard to -- I’m sorry, to when you

7 were interviewed by members of the Los Angeles

8 Police Department?

9 A. Yes, it does.

10 Q. And what was the date on that?

11 A. 8-7-93.

12 Q. Now, let’s go back, if we can. And just to

13 clarify, you were not the one who originally

14 contacted the -- made the report?

15 A. Correct.

16 Q. Do you know who did, of your own knowledge?

17 A. Of my knowledge, it was Jordan Chandler, my

18 son.

19 Q. Now, let’s go back for just a second.

20 Mr. Mesereau asked you about a meeting on Saturday

21 involving your attorney and myself. Do you recall

22 that?

23 A. Yes, I do.

24 Q. And was there also another person that was

25 present with us that I brought along?

26 A. Yes.

27 Q. Do you remember the person’s name?

28 A. No, I don’t remember his name, but he was a 5728



1 detective.

2 Q. With the sheriff’s department?

3 A. With the sheriff’s department.

4 Q. So he was also present during that entire

5 meeting?

6 A. He was -- absolutely, yes.

7 Q. All right. Now, he also asked you about

8 conversations that you and I had on the phone. Do

9 you recall that?

10 A. Correct.

11 Q. And that we had talked a couple of times on

12 the phone?

13 A. Correct.

14 Q. And with regard to those conversations, the

15 first conversation we had, do you recall the

16 substance of that conversation?

17 A. That I would be subpoenaed and for --

18 testifying.

19 Q. And did I indicate to you that I wanted to

20 talk to you, to do an interview with you?

21 A. That we would be speaking later on, yes.

22 Q. Okay. And did you -- did you have to check

23 with somebody to make sure that was okay because of

24 the confidentiality agreement?

25 A. Yes.

26 Q. And who was that?

27 A. Larry Feldman.

28 Q. So is that one of the phone calls that you 5729



1 had with Mr. Feldman, was to make sure --

2 A. Yes.

3 Q. -- to make sure it was okay for you to talk

4 to me?

5 A. Correct.

6 Q. Now, Mr. Mesereau asked you about some

7 countersuit that Michael Jackson alleged against you

8 and members of your family. Do you recall that

9 question?

10 A. Yes.

11 Q. Did you ever pay a penny to Mr. Jackson in

12 any lawsuit to settle anything?

13 A. No. No.

14 Q. Now, you indicated that these two children

15 from New Jersey that you mentioned, the Cascios, do

16 you remember the name of the restaurant in New

17 Jersey that they allegedly owned?

18 A. Aldo’s Restaurant.

19 Q. You talked with Mr. Mesereau about the

20 incident that occurred in New York where the lamps

21 got broken and the karate kicks and all that?

22 A. Correct.

23 Q. Okay. Did you subsequently learn that the

24 version of what happened was not truthful?

25 MR. MESEREAU: Objection; leading.

26 THE WITNESS: Correct.

27 THE COURT: Sustained. The answer’s

28 stricken. 5730



1 Q. BY MR. SNEDDON: Did you subsequently -- can

2 you tell us how you eventually -- let me put it this

3 way: Did you ultimately learn other information

4 about that incident?

5 A. Yes.

6 Q. You personally?

7 A. Yes.

8 Q. And did you determine from that information

9 that the original version wasn’t correct?

10 A. Correct.

11 Q. We talked a little bit in your direct

12 examination about the change-in-custody agreement

13 that Mr. Jackson asked you to sign. Do you recall

14 that?

15 A. Yes.

16 Q. Okay. And you said you did sign it?

17 A. I did.

18 Q. Now, after having signed that document, did

19 you ever get custody of your child back?

20 A. No.

21 Q. Mr. Mesereau asked you about your son Jordan

22 and about some things you may or may not have seen

23 with regard to taking showers. And I want to ask

24 you a few questions about that, okay?

25 A. Yes.

26 Q. During the time that you were -- you stayed

27 at Neverland Valley Ranch, and your son slept in Mr.

28 Jackson’s room - okay? - did you ever see your son 5731



1 come back to the guest cottages to take showers?

2 A. No.

3 Q. During the time that your son was in Monaco

4 and stayed in Mr. Jackson’s room for several days in

5 a row, did you ever see your son come back to take

6 showers in your room?

7 A. No.

8 Q. During the time that you were in Florida and

9 Mr. Jackson and your son spent the time together and

10 he was sleeping in Mr. Jackson’s room, did you ever

11 see your son come back to your room to take showers

12 or to clean up?

13 A. No.

14 Q. And if I were to ask you that same question

15 with regard to baths - okay? - would there be any

16 different answers?

17 A. No.

18 Q. Or with regard to seeing your son getting

19 dressed in the morning, would there be any different

20 answers?

21 A. No.

22 Q. Now, with regard to the meeting that Mr.

23 Mesereau talked about, where you were at the

24 hideout, Mr. Jackson’s hideout, the Century City

25 place -- in Century City? I don’t know where it is.

26 A. Yes, it is.

27 Q. And we’re talking about the evening that you

28 described where Mr. Pellicano was talking to Jordan 5732



1 downstairs and you were upstairs with David

2 Schwartz.

3 A. Correct.

4 Q. You told us that lasted about 45 minutes?

5 A. Yes, it did.

6 Q. Do you recall whether or not Mr. Jackson was

7 present during that conversation?

8 A. I don’t recall him being there.

9 Q. Now, if I show you your statement that you

10 gave to the Los Angeles District Attorney’s Office,

11 might that refresh your recollection to that event?

12 A. Yes.

13 MR. SNEDDON: May I, Your Honor?

14 THE COURT: Yes.

15 MR. SNEDDON: Page 90, Counsel.

16 THE WITNESS: Thank you.

17 Q. BY MR. SNEDDON: Does having seen that

18 statement refresh your recollection as to whether or

19 not Mr. Jackson was present with Mr. Pellicano

20 during Jordan’s conversation or interview?

21 A. Yes, it does.

22 Q. And was he?

23 A. Yes, he was present.

24 Q. You told the jury that it’s been 11 years

25 since you’ve had any conversations with your son

26 Jordan, correct?

27 A. Correct.

28 Q. Is that by your choice? 5733



1 A. No.

2 Q. You told the jury that as a result of the

3 conversation with Mr. Jackson in Las Vegas where he

4 urged you to trust him - okay? --

5 A. Yes. I’ll be okay. Thank you.

6 Q. -- that during that conversation in Las

7 Vegas where Mr. Jackson urged you to trust him, do

8 you recall that?

9 A. I do.

10 Q. Do you regret ever doing that?

11 A. Very much so.

12 MR. SNEDDON: Nothing further.

13

14 RECROSS-EXAMINATION

15 BY MR. MESEREAU:

16 Q. Briefly, do you recall Evan hired counsel

17 in June to start negotiating with Mr. Jackson?

18 A. No, I don’t recall.

19 Q. Do you recall being in any meetings with

20 Evan and his counsel in June to try and settle the

21 matter?

22 A. No.

23 Q. Do you recall Mr. Pellicano making

24 settlement offers to Evan on your behalf in June?

25 A. No, I don’t.

26 Q. Do you recall any contact between Evan and

27 lawyers in May?

28 A. No. 5734



1 Q. Okay. You never discussed that with Evan at

2 the time?

3 A. No.

4 Q. Didn’t you have a lot of -- we’re talking

5 about 1993. Didn’t you have a lot of contact with

6 Evan at that point about hiring counsel?

7 A. No.

8 Q. And weren’t you in a dispute with Evan at

9 that point over custody?

10 A. Yes.

11 Q. Okay. And when did that dispute begin, if

12 you know?

13 A. In August of ‘93.

14 Q. But you had had problems with Evan for

15 months before that, had you not?

16 A. Not -- not terrible.

17 Q. And you don’t know when he hired his

18 attorney?

19 A. No, I don’t. No, I don’t.

20 MR. MESEREAU: Okay. No further questions.

21 MR. SNEDDON: Nothing further, Your Honor.

22 THE COURT: All right. Thank you. You may

23 step down.

24 THE COURT: Call your next witness.

25 MR. AUCHINCLOSS: People call Dwayne

26 Swingler.

27 THE COURT: When you get to the witness

28 stand, please face the clerk and raise your right 5735



1 hand.

2

3 DWAYNE SWINGLER

4 Having been sworn, testified as follows:

5

6 THE WITNESS: Yes, ma’am.

7 THE CLERK: Please be seated. State and

8 spell your name for the record.

9 THE WITNESS: My name is Dwayne Swingler;

10 D-w-a-y-n-e, Swingler, S-w-i-n-g-l-e-r.

11 THE CLERK: Thank you.

12

13 DIRECT EXAMINATION

14 BY MR. AUCHINCLOSS:

15 Q. Good afternoon, Mr. Swingler.

16 A. Good afternoon.

17 Q. What is your current occupation, sir?

18 A. Right now I do stand-in work, movie sets.

19 Q. Okay. And what kind of -- stand-in work,

20 what does that --

21 A. Stand in for stars. It’s called second

22 team. They don’t use the stars to get the lights

23 bright. They use stand-ins.

24 Q. I see. During the year 2003, at some point

25 during that year, did you -- were you employed by

26 Michael Jackson?

27 A. Yes, sir.

28 Q. Is he the man seated to my right with the 5736



1 long black hair?

2 A. Yes, sir.

3 Q. Thank you.

4 When did you begin working for Mr. Jackson?

5 A. In June of 2003. Early June of 2003.

6 Q. And what was your -- what was your

7 assignment for Mr. Jackson?

8 A. Supervisor of Neverland.

9 Q. How did you come to get that position?

10 A. I met Michael at a studio, Marvin Gaye’s

11 studio in Hollywood.

12 Q. What were you doing at the studio?

13 A. My cousin was engineering Michael’s music

14 session, and Michael needed someone to whistle on a

15 track, so my cousin called me and said, “Would you

16 like to come down and whistle on Michael’s track?”

17 And I said, “I can’t whistle that well, but I would

18 love to come down and meet Michael Jackson.”

19 Q. Okay. Are you yourself a musician?

20 A. Yes, I am.

21 Q. And you met Mr. Jackson on that date?

22 A. Yes, sir.

23 Q. Can you tell me about -- was that in 2003?

24 A. Yes, it was.

25 Q. About what month was it, if you recall?

26 A. That was probably early -- sometime in

27 April.

28 Q. And how did it come about that you were 5737



1 offered employment?

2 A. I hung out at the studio with Michael and

3 his kids, and Chris Carter, maybe four, five days in

4 a row, three, four days in a row, while they were

5 working on the session.

6 Q. Who did you understand Chris Carter to be?

7 A. Michael’s personal security.

8 Q. And so somebody offered you employment?

9 A. On the last day there, Chris Carter asked me

10 to come outside. So I walked outside with him, and

11 at that time he told me that, you know, “Michael

12 likes you. He would love to bring you aboard. What

13 are you currently doing right now”?

14 Q. Were you available?

15 A. Yes.

16 Q. Did they tell you what type of job they

17 wanted to hire you for?

18 A. Initially they hired me to be security,

19 along with Chris Carter, to travel with Michael.

20 Q. And how did that work out?

21 A. Well, that didn’t work for me because I had

22 triplets. I got three-year-old triplet boys, so....

23 Q. All right. So traveling wasn’t an option?

24 A. No. Actually, Michael was the one who said,

25 “If he has triplet boys, then I don’t want him to be

26 traveling with me all the time.”

27 Q. So you said you became ranch manager?

28 A. Yes. 5738



1 Q. How did that come about?

2 A. I guess Michael suggested to Chris, “If he

3 has triplets, he’ll be away from his kids a lot. So

4 maybe we should offer him another job,” and that’s

5 when supervisor of Neverland came up.

6 Q. So who offered you that position, I guess is

7 my question?

8 A. I guess Michael. But Chris Carter’s the one

9 who told me about the position.

10 Q. At some time did you discuss with Mr.

11 Jackson personally your employment?

12 A. I don’t understand the question.

13 Q. Did you ever have a discussion with Mr.

14 Jackson about your employment as ranch manager?

15 A. Yes, I did.

16 Q. Did he ever discuss with you the terms by

17 which you could be terminated if he was dissatisfied

18 with your work?

19 A. He didn’t discuss with me personally. But

20 Chris Carter and Joe Marcus did.

21 Q. And did you have an understanding about how

22 you could be terminated?

23 A. Yes.

24 Q. And what was that?

25 A. Grounds of giving up information of where

26 Michael Jackson’s whereabouts are, and, you know,

27 there was a rule on the ranch -- I don’t know if it

28 came directly from Michael, but, you know, Chris 5739



1 told me and Joe Marcus told me as well, that you can

2 never say no --

3 MR. MESEREAU: Objection; hearsay.

4 MR. AUCHINCLOSS: Okay, let’s just back up a

5 minute.

6 Q. I think what my question is, did you know --

7 did you have some indication from Mr. Jackson as to

8 who had authority to terminate you?

9 A. Yes.

10 Q. And who was that?

11 A. From my understanding, it was only supposed

12 to be Michael Jackson.

13 Q. Okay. At some point during 2003, were you

14 terminated?

15 A. Yes.

16 Q. Tell me about that. How did that come

17 about?

18 A. I had --

19 MR. MESEREAU: Objection; vague as to time.

20 THE COURT: I’ll ask you to clarify the time.

21 MR. AUCHINCLOSS: Okay.

22 Q. When were you terminated?

23 A. Early August 2003.

24 Q. And how long had you been working at that

25 point for Mr. Jackson?

26 A. Maybe five, six weeks.

27 Q. When did you start work?

28 A. I was hired in the end of April, early May. 5740



1 But I had to go back to Michigan for a couple of

2 weeks, so the hiring process took awhile. You know,

3 background checks, physicals.

4 Q. When did you start going to Neverland?

5 A. In May.

6 Q. In May?

7 A. Yeah.

8 Q. And when did you start getting a paycheck?

9 A. In June.

10 Q. Okay. And what were you doing there in May?

11 A. I just came out to the ranch to check things

12 out to see the position that I would be, you know,

13 filling.

14 Q. In May, was it understood that you would be

15 the ranch manager?

16 A. Yes.

17 Q. And did you go up there and receive some

18 instruction from anybody as to what the duties were,

19 in May?

20 A. I received, well, sort of from Joe Marcus,

21 some instruction, but not as much as I did once I

22 started in June.

23 Q. What was Mr. Marcus’s assignment at that

24 time?

25 A. Ranch manager.

26 Q. So he was ranch manager and you were going

27 to take it over?

28 A. No. Ranch manager, you deal with the 5741



1 majority of the workers outside, the garden, the

2 landscapers, things like that. The carnival, the

3 festival, whatever.

4 Q. What was Joe Marcus doing?

5 A. What do you mean?

6 Q. Well, you said Joe Marcus was ranch manager.

7 A. Right, that was his position. Ranch

8 manager, you deal with all the employees basically

9 outside of the house.

10 Q. And your position was going to be?

11 A. Supervisor. Deal with the employees and

12 Michael and the kids in the house.

13 Q. Oh, in the house?

14 A. Yes.

15 Q. So house manager?

16 A. House manager.

17 Q. All right. Good.

18 So you began work in June, but you went up

19 there for how many weeks to get some training?

20 A. Not really training, just sort of to come

21 check things out, and to see who -- you know, what

22 position I would be taking and where the office was,

23 and things like that.

24 Q. And when was it you were terminated?

25 A. In early August.

26 Q. And how did that come about?

27 A. I had had a meeting with Michael about

28 transferring my position. And I liked working for 5742



1 him. I wanted to work for him somewhere in Los

2 Angeles, because my triplets were only one years old

3 at the time. So I was missing them, them being in

4 Los Angeles and me being here, and me staying the

5 night at Neverland often. Wasn’t working for me.

6 So I had a one-on-one meeting with him to be

7 transferred.

8 Q. And how did your termination come about?

9 A. I --

10 Q. Let me ask you this: Were you terminated?

11 A. Yes, I was.

12 Q. And how were you terminated?

13 A. I was terminated by Joe Marcus. He -- I

14 arrived at Neverland one morning for work and he

15 told me -- he had changed the locks on me. And then

16 I went into -- I mean, some -- one of the

17 employees -- one of my employees in the house told

18 me Joe came to change the locks. And I said, “Why?”

19 And they said, “I don’t know.” And I had already

20 been told by the guard at the gate that Joe --

21 MR. MESEREAU: Objection; hearsay.

22 THE COURT: Sustained.

23 Q. BY MR. AUCHINCLOSS: So the locks were

24 changed. Did you go talk to Mr. Marcus?

25 A. Yes, I did.

26 Q. What did he tell you?

27 MR. MESEREAU: Objection; hearsay.

28 THE WITNESS: He told -- 5743



1 MR. AUCHINCLOSS: I can go back to my last

2 question, I guess. I’ll withdraw that question,

3 Your Honor.

4 THE COURT: All right.

5 Q. BY MR. AUCHINCLOSS: And how specifically --

6 I want you to go directly to the answer on this

7 question. How specifically did you learn that you

8 were terminated?

9 A. I --

10 MR. MESEREAU: Objection; asked and

11 answered.

12 THE COURT: Overruled.

13 You may answer.

14 Q. BY MR. AUCHINCLOSS: Go ahead.

15 A. I learned directly from Joe Marcus that my

16 services would no longer be needed at Neverland, and

17 that he didn’t have to give me a reason. Because

18 I --

19 Q. You asked him for a reason?

20 A. Yes, I did. I didn’t think I had done

21 anything wrong. Well, I know I hadn’t done anything

22 wrong.

23 Q. Okay. So you’d been at Neverland for a

24 little over a month, and you’d worked there for a

25 few weeks before that time as well?

26 A. Well, not worked. But like -- I wasn’t

27 getting paid for that time. That was just to come

28 out there and check the ranch out. 5744



1 Q. During the time that you were at Neverland,

2 did you have personal interaction with Michael

3 Jackson?

4 A. Yes.

5 Q. On how often a basis?

6 A. If he was there. All the time, if he was

7 there.

8 Q. More than once a day?

9 A. Yes.

10 Q. And who was responsible for handling Mr.

11 Jackson’s appointments while he was on the ranch?

12 A. At Neverland, I would take the -- all the

13 phone calls. It didn’t matter who it was calling;

14 mother, father, business person.

15 Q. So if he had an appointment for a day, would

16 you take that -- would that be part of your duties?

17 A. Yes.

18 Q. To schedule those appointments?

19 A. Yes.

20 Q. Did you have occasion to observe visitors of

21 Mr. Jackson that were child visitors?

22 A. Yes.

23 Q. Did you see child visitors spend the night

24 at Neverland?

25 A. Yes.

26 Q. Did you see child visitors spend the night

27 in Mr. Jackson’s room?

28 A. Yes. 5745



1 MR. MESEREAU: Objection. Leading; and

2 violates the Court’s order.

3 THE COURT: Sustained.

4 Q. BY MR. AUCHINCLOSS: Who did you see visit

5 Mr. Jackson who was a child visitor?

6 MR. MESEREAU: I’m going to object.

7 Violates the Court’s order.

8 THE COURT: Sustained.

9 Q. BY MR. AUCHINCLOSS: When you were at

10 Neverland, did you interact with Mr. Jackson about

11 issues dealing with activities on the ranch?

12 MR. MESEREAU: Objection; vague.

13 THE COURT: Overruled.

14 THE WITNESS: Issues dealing with activity on

15 the ranch?

16 Q. BY MR. AUCHINCLOSS: Well, whatever -- let’s

17 back up. What were your duties as house manager?

18 A. To answer all the phone calls. To, you

19 know, schedule the maids. To help the maids out

20 with cleaning rooms and suites. And basically to,

21 you know, take care of whatever Michael and the kids

22 needed.

23 Q. And in terms of the day-to-day issues in

24 terms of running the ranch, can you characterize

25 how -- Mr. Jackson’s degree of involvement?

26 A. As far as -- I mean --

27 MR. MESEREAU: Objection. Vague; and

28 relevance. 5746



1 THE COURT: Overruled.

2 You may answer.

3 THE WITNESS: Mr. Jackson is in total charge

4 of the ranch.

5 Q. BY MR. AUCHINCLOSS: Why do you say that?

6 A. Well, when I was terminated, because of my

7 previous conversation with Chris Carter that only

8 Michael Jackson could terminate me, I called Evvy,

9 which is Michael’s personal assistant --

10 MR. MESEREAU: Objection. Nonresponsive;

11 hearsay.

12 MR. AUCHINCLOSS: That’s fine.

13 MR. MESEREAU: And relevant as to time.

14 THE COURT: Sustained.

15 Q. BY MR. AUCHINCLOSS: So when you were on the

16 ranch, did you have occasion to see Mr. Jackson in

17 terms of making orders at the ranch?

18 A. Yes.

19 Q. Did he make orders?

20 A. Yes. He made some to me.

21 MR. MESEREAU: Continuing relevance

22 objection, Your Honor, as to time.

23 THE COURT: Time?

24 Q. BY MR. AUCHINCLOSS: During the time that

25 you were ranch manager, during that five-week

26 period.

27 A. Yes.

28 MR. MESEREAU: That’s the objection, Your 5747



1 Honor. The time period’s irrelevant.

2 THE COURT: All right. That’s overruled.

3 Q. BY MR. AUCHINCLOSS: Go ahead. You can

4 answer that question.

5 A. Yes, I observed it. He made some to me

6 personally.

7 Q. Did you have occasion to see individuals,

8 his other employees, in terms of their relationship

9 with Mr. Jackson?

10 A. Meaning like Joe Marcus and Grace and those?

11 Q. I mean -- let’s talk about your employees.

12 Did you have employees that were working under you

13 as house manager?

14 A. Yes.

15 Q. Who?

16 A. Cooks?

17 Q. Yeah, just generally speaking.

18 A. Cooks, housekeepers, maids.

19 Q. Okay. And had some of these people been

20 working at the ranch longer than you had?

21 A. Yes. The majority of -- all of them.

22 Q. And did you have occasion to see their

23 interaction with Mr. Jackson?

24 A. Yes.

25 Q. And what level of service did Mr. Jackson

26 expect?

27 MR. MESEREAU: Objection. Relevance; vague;

28 no foundation. 5748



1 THE COURT: It’s vague; sustained.

2 Q. BY MR. AUCHINCLOSS: Can you characterize

3 the demeanor of the employees around Mr. Jackson

4 when they were in his presence?

5 MR. MESEREAU: Objection. Vague; relevance.

6 Particularly the time period.

7 MR. AUCHINCLOSS: I’ll be specific.

8 Q. During the time you were ranch manager, or

9 house manager.

10 MR. MESEREAU: Same objection.

11 THE COURT: Overruled.

12 THE WITNESS: Can you ask me the question

13 again?

14 Q. BY MR. AUCHINCLOSS: Yeah. My question is,

15 can you characterize the demeanor -- how did these

16 people act, these employees, when they were around

17 Mr. Jackson in his presence?

18 A. I mean, they act like they liked him. Mr.

19 Jackson was nice to people.

20 Q. Did they act like they’d speak their mind

21 around him?

22 MR. MESEREAU: Objection; leading.

23 THE COURT: Sustained.

24 Q. BY MR. AUCHINCLOSS: Did they act -- did

25 they act comfortable around him?

26 MR. MESEREAU: Objection. Leading; vague;

27 relevance; and foundation.

28 THE COURT: Sustained. 5749



1 Q. BY MR. AUCHINCLOSS: Do you know if -- do

2 you know if Mr. Jackson would fire people at

3 Neverland?

4 MR. MESEREAU: Objection. Foundation;

5 relevance.

6 THE COURT: Foundation; sustained.

7 Q. BY MR. AUCHINCLOSS: Well, you yourself were

8 fired; is that correct?

9 A. Yes, sir.

10 Q. Do you know who fired you?

11 MR. MESEREAU: Objection; asked and

12 answered.

13 THE COURT: Sustained.

14 Q. BY MR. AUCHINCLOSS: Who -- when you were

15 working with Mr. Jackson, did you have occasion to

16 see individuals who were employees of his that were

17 closer than other employees?

18 MR. MESEREAU: Objection. Vague; leading;

19 relevance; foundation.

20 MR. AUCHINCLOSS: Objection, Counsel’s

21 fishing for a reason to object to that question.

22 MR. MESEREAU: I object to the colloquy,

23 move to strike.

24 THE COURT: I’ll sustain the “vague”

25 objection to that question.

26 Q. BY MR. AUCHINCLOSS: Did you see

27 employees -- did you see any employees that spent

28 more time with Mr. Jackson than other employees? 5750



1 MR. MESEREAU: Objection. Leading; vague;

2 foundation; and relevance.

3 THE COURT: Overruled.

4 You may answer.

5 THE WITNESS: Yes, I did.

6 Q. BY MR. AUCHINCLOSS: Did you see -- well,

7 let’s go ahead and make a list. Who did you see

8 that spent more time with Mr. Jackson than other

9 employees?

10 MR. MESEREAU: Objection. Relevance;

11 foundation; vague.

12 THE COURT: Overruled.

13 You may answer.

14 THE WITNESS: Vase -- Grace, I’m sorry.

15 Grace, Chris Carter. Those are the two that I think

16 spent most of the time with Mr. Jackson.

17 Q. BY MR. AUCHINCLOSS: Did you ever see an

18 individual visit the ranch by the name of Dieter

19 Weizner?

20 A. I would have to see a picture to be sure.

21 MR. MESEREAU: Could we approach, Your

22 Honor? We’d like a proffer.

23 MR. AUCHINCLOSS: Be happy to make one.

24 THE COURT: I don’t really need that. I --

25 it’s clear to me where....

26 Q. BY MR. AUCHINCLOSS: I show you People’s

27 Exhibit No. 17, Mr. Swingler. Can you identify that

28 for me, please? 5751



1 A. I can’t say I’ve seen that gentleman.

2 Q. You haven’t seen him?

3 A. No.

4 Q. Did you see -- did you previously have a

5 conversation with Detective Bonner about the facts

6 of this case?

7 A. Yes, sir.

8 Q. And in that conversation, did you

9 identify -- just a moment, if you would, please.

10 Did you identify a number of individuals

11 that you thought were within Michael Jackson’s inner

12 circle?

13 MR. MESEREAU: Objection. Leading; and

14 vague.

15 MR. AUCHINCLOSS: It’s impeachment.

16 THE COURT: Sustained.

17 MR. AUCHINCLOSS: I’m sorry?

18 THE COURT: It’s vague.

19 Q. BY MR. AUCHINCLOSS: Did you identify Dieter

20 Weizner as a member of Michael Jackson’s inner

21 circle?

22 MR. MESEREAU: Objection. Leading; and

23 foundation.

24 THE COURT: Overruled.

25 You may answer.

26 THE WITNESS: In my conversation with

27 Detective Bonner?

28 Q. BY MR. AUCHINCLOSS: With Detective Bonner, 5752



1 did you not identify Dieter Weizner specifically as

2 a member of Michael Jackson’s inner circle?

3 A. I can’t -- I can’t really recall, because I

4 don’t know the face. I never seen the face before.

5 The name I know. The face I don’t.

6 Q. Do you know the name Dieter Weizner?

7 A. Yes.

8 Q. Did you meet a man by the name of Dieter

9 Weizner?

10 A. Looking at the face --

11 Q. I’m not asking you about the face.

12 MR. MESEREAU: Objection. He’s arguing with

13 the witness. Leading and foundation.

14 THE COURT: Overruled.

15 Q. BY MR. AUCHINCLOSS: Did you meet a man by

16 the name of Dieter Weizner?

17 A. I can’t remember.

18 Q. Did you meet a man -- well --

19 A. Like I say, the name sounds familiar. I

20 know I’ve heard the name. Maybe I spoke with him on

21 the phone a few times there, but the face didn’t --

22 MR. MESEREAU: Objection. Calls for

23 speculation; move to strike; nonresponsive.

24 Q. BY MR. AUCHINCLOSS: Did you meet a man by

25 the name of Ronald Konitzer?

26 THE COURT: There’s an objection pending.

27 THE BAILIFF: Judge, can you turn the

28 microphone on? 5753



1 THE COURT: All right. The objection is

2 overruled. And you had another question. Go ahead.

3 Q. BY MR. AUCHINCLOSS: Did you meet a man by

4 the name of Ronald Konitzer?

5 A. I can’t -- by the name -- I would have to

6 see a picture.

7 Q. Did you meet two German businessmen?

8 A. Yes.

9 Q. Did they meet with Mr. Jackson?

10 A. Yes.

11 Q. On how many occasions?

12 A. Three or four.

13 MR. AUCHINCLOSS: Thank you. I have no

14 further questions.

15 THE COURT: Cross-examine?

16

17 CROSS-EXAMINATION

18 BY MR. MESEREAU:

19 Q. Good afternoon.

20 A. Good afternoon.

21 Q. My name’s Tom Mesereau. I speak for Mr.

22 Jackson.

23 A. How you doing, sir?

24 Q. Good. Good. We’ve never spoken before,

25 right?

26 A. No.

27 Q. You worked for a five-week period?

28 A. Four and a half, five weeks, yes, sir. 5754



1 Q. Four and a half, five weeks. How many days

2 a week did you work?

3 A. Six or seven.

4 Q. And the prosecutor asked you about how many

5 meetings Mr. Jackson had with two German

6 individuals, right?

7 A. Yes, sir.

8 Q. Do you really know how many meetings there

9 were?

10 A. Around, I’m guessing, three to four.

11 MR. MESEREAU: Okay. Move to strike the

12 testimony, Your Honor.

13 THE COURT: Denied.

14 Q. BY MR. MESEREAU: You’re guessing three to

15 four, but you don’t really know, right?

16 A. No, I couldn’t say. I couldn’t pinpoint it.

17 I wasn’t --

18 Q. You weren’t in the meetings, right?

19 A. No.

20 Q. You don’t remember what they looked like,

21 right?

22 A. I do remember what they looked like if I saw

23 a picture of them, yes.

24 Q. Well, the picture the prosecutor showed you,

25 you couldn’t identify, right?

26 A. Yes, sir.

27 Q. Okay. Now, you wanted to be transferred to

28 Los Angeles; is that correct? 5755



1 A. Yes. Yes, sir.

2 Q. And did you tell -- excuse me, who did you

3 talk to about the transfer?

4 A. Mr. Jackson.

5 Q. Okay. And you explained that the commute

6 and the hours were just too much to raise your

7 family?

8 A. I just wasn’t seeing my kids, and they were

9 one years old.

10 Q. And did you ask Mr. Jackson to be

11 transferred somewhere in Los Angeles?

12 A. Yes.

13 Q. Okay. And where was that?

14 A. I just asked him to be transferred to any

15 business in Los Angeles that he had.

16 Q. But you really didn’t even know if there was

17 a job available in Los Angeles, right?

18 A. No, that’s why I was asking.

19 Q. Okay. Right. Okay. And approximately when

20 did you ask him; do you know?

21 A. Maybe three weeks into the job.

22 Q. Okay. And Mr. Jackson was always nice to

23 you, wasn’t he?

24 A. Yes, sir.

25 Q. And as far as you know, there may not have

26 been a job available in Los Angeles, right?

27 A. He told me there was one.

28 Q. He told you there was one? 5756



1 A. Yes, sir.

2 Q. Where did he say?

3 A. A&R, his record label.

4 Q. Pardon me?

5 A. A&R of his record label.

6 Q. Had you ever worked at a record label

7 before?

8 A. No, I hadn’t.

9 Q. All right. But at some point you learned

10 that you weren’t being hired, right?

11 A. No. As a matter of fact, I saw Michael

12 again at his birthday party in Los Angeles and he

13 told me I was still hired.

14 Q. Okay. But it never came through, right?

15 A. No, I’m still waiting for my paycheck now.

16 Q. Okay. You’re trying to write a book about

17 your experiences at Neverland, correct?

18 A. Well, no, I’m not trying to write a book

19 about my experiences at Neverland.

20 Q. Well, didn’t you -- excuse me. Did you say

21 Michael Jackson has a record label?

22 A. He told me he had a record label.

23 Q. Okay. Do you know that he doesn’t have one?

24 MR. AUCHINCLOSS: Objection; assumes facts.

25 THE COURT: Sustained.

26 Q. BY MR. MESEREAU: Do you know whether or not

27 he really has a record label?

28 A. I was just told by him he had a record 5757



1 label.

2 Q. Okay. All right. Now, you prepared notes

3 for a book called “Entering Neverland, Secrets

4 Behind the Gate,” right?

5 A. Does it have my signature on it? Because I

6 know that within the last month or two, I started

7 jotting down information to myself and somehow my

8 information come up missing out of my house, but

9 whatever.

10 Q. Did you prepare notes for a book titled

11 “Entering Neverland, Secrets Behind the Gate” --

12 A. No.

13 Q. -- “By Dwayne Swingler, Head Supervisor of

14 Neverland Ranch, Summer of 2003,” did you prepare

15 that?

16 A. No.

17 MR. AUCHINCLOSS: Objection; asked and

18 answered.

19 THE COURT: Overruled. The answer is, “No.”

20 Q. BY MR. MESEREAU: Are you aware of anything

21 like that?

22 A. No.

23 Q. You didn’t --

24 A. Am I aware of it? What do you mean?

25 Q. Yeah. Have you written out anything for a

26 book called “Entering Neverland, Secrets Behind the

27 Gate, by Dwayne Swingler”?

28 A. No, I haven’t written anything, or titled 5758



1 anything, or signed anything, or spoke to anybody

2 about, “This is my deal.”

3 Q. Have you talked to a group called News of

4 the World?

5 A. Have I?

6 Q. Yes.

7 A. Yeah, I spoke with one lady one time, yes.

8 Q. And to your knowledge, who is News of the

9 World?

10 A. To my knowledge, it’s a news media overseas.

11 Q. And why were you speaking to them?

12 A. Because I was interested in maybe possibly

13 writing down some information to -- to cash in on

14 something like everybody else was, because Michael

15 wasn’t -- I hadn’t received the paycheck from A&R at

16 the time.

17 Q. Okay. Did you enter into a nondisclosure

18 agreement with News of the World?

19 A. No, I did not.

20 Q. Have you ever seen one?

21 A. No, I did not.

22 Q. Did you ever talk to someone named David

23 Han-Schmidt?

24 A. The same time I spoke with the News of the

25 World lady, he’s the one that contacted her and

26 contacted me.

27 Q. And to your knowledge, who is David

28 Han-Schmidt? 5759



1 A. He said that he was a media agent. I don’t

2 even know how he got my phone number.

3 Q. When did you last talk to David Han-Schmidt?

4 A. He -- as a matter of fact, he called me

5 today.

6 Q. And to your knowledge, is he with a public

7 relations company?

8 A. I really don’t know what he did. He never

9 clarified that with me. He said he was an agent, he

10 was a producer, he was in public relations. I

11 basically ended the situation.

12 Q. To your knowledge, did anyone ever send you

13 a nondisclosure agreement regarding News of the

14 World?

15 A. No. I haven’t signed any nondisclosure

16 agreements, and I haven’t taken any money from

17 anyone.

18 Q. How many discussions have you had with David

19 Han-Schmidt?

20 A. Three. Four. Can’t remember.

21 Q. And when was the last one with him? Today?

22 A. He called me today, because he said he heard

23 that I was coming to testify.

24 Q. Okay. Have you ever put together any notes

25 for a possible book on the computer?

26 A. Excuse me?

27 Q. Have you ever put any notes for a possible

28 book on your computer? 5760



1 A. No, I haven’t.

2 Q. Have you ever written any notes out for a

3 possible book?

4 A. I told you I jotted down some information on

5 a piece of paper, and that’s all I’ve done.

6 Q. Did you ever ask any public relations person

7 to put together a proposal for you?

8 A. No, I haven’t.

9 Q. But you’re thinking of doing it, right, like

10 everybody else?

11 A. Yes, I was thinking about doing it.

12 Q. Okay. Okay. Have you ever seen -- excuse

13 me. Has anyone ever brought to your attention that

14 somebody has prepared notes for a possible book in

15 your name?

16 A. David.

17 Q. David Han-Schmidt?

18 A. Yes.

19 Q. Did he prepare them, to your knowledge?

20 A. He just said he received papers. I don’t

21 know -- like I told you, I don’t even know how he

22 got my phone number.

23 Q. Okay. If I showed you these papers, might

24 it refresh your recollection about where they came

25 from?

26 A. No, it probably wouldn’t, because I never

27 typed any papers or wrote out -- the only thing I

28 did was write down notes, jotted down notes on a 5761



1 piece of paper.

2 Q. Okay. And that was about your experience

3 during the five weeks at Neverland?

4 A. That was about my experience totally, not

5 just the five weeks at Neverland. That was my

6 experience with Michael’s manager and everything.

7 Q. Okay. Did you ever write down on those

8 notes the words “Secrets Behind the Gate”?

9 A. No, I did not.

10 Q. Okay. Did David Han-Schmidt tell you how he

11 got your name?

12 A. No, he did not.

13 Q. Okay. Did you ever ask him, “Why did you

14 call me?”

15 A. Well, actually, he started the conversation

16 off, and he just, whew, went straight to talking

17 about a lot of money, so I was listening to him

18 about a lot of money first.

19 Q. Did he promise you a lot of money?

20 A. That’s what he promised, yes.

21 Q. Okay. How much money did he promise?

22 A. He never said figures. He just said, you

23 know, “You can make a lot of money.” You know, “Why

24 aren’t you telling anyone your story?” That’s what

25 he said to me.

26 Q. It’s your understanding that he’s located in

27 Phoenix, Arizona?

28 A. Yes. That’s where he said he’s from. 5762



1 Q. Okay. Did he ever tell you he was going to

2 prepare a possible manuscript for you?

3 A. He asked me would I like him to, and I said

4 no. Like I told you, I terminated the conversation

5 when he told me what he wanted to do.

6 Q. Okay. And did he want some scandal sheet

7 about Michael, something like that?

8 A. Actually, he’s for Michael. He’s pro

9 Michael.

10 Q. Did he want you to write something about

11 Michael?

12 A. He wanted to speak on Michael’s behalf, yes.

13 Q. Okay. And how often -- in those three

14 conversations, did you talk about money each time?

15 A. No, I did not.

16 Q. Okay. Have you ever spoken to Miss Carol

17 Maung, M-a-u-n-g, who is the U.S. editor of News of

18 the World?

19 A. I spoke with her. I spoke with her when she

20 was with David when I got there.

21 Q. And did she fax you anything or e-mail you

22 anything?

23 A. Fax me anything or e-mail me anything?

24 Q. Yes.

25 A. No, sir.

26 Q. Okay. All right. When you were at

27 Neverland working --

28 A. Yes. 5763



1 Q. -- you had no direct contact with any member

2 of the Arvizo family, right?

3 A. The Arvizo family?

4 Q. Yes.

5 A. No, sir.

6 Q. That means you didn’t have any contact with

7 the Arvizos?

8 A. Yes.

9 Q. Okay. Do you remember meeting Dominick

10 Cascio at Neverland?

11 A. Yes, sir.

12 Q. And he’s the -- did you speak to him?

13 A. Often.

14 Q. Okay. And to your knowledge, he’s a father?

15 A. He’s a father?

16 Q. Yes.

17 A. I didn’t know he was a father.

18 Q. Okay. Did he ever talk to you about work he

19 did?

20 A. Did Dominick ever talk to me about work he

21 did?

22 Q. Yeah.

23 A. Some work at the restaurant that his family

24 owned.

25 MR. MESEREAU: Okay. I have no further

26 questions, Your Honor.

27 MR. AUCHINCLOSS: Counsel?

28 (Off-the-record discussion held at counsel 5764



1 table.)

2 MR. AUCHINCLOSS: Maybe we should approach.

3 Your Honor, may we approach?

4 THE COURT: For what?

5 MR. AUCHINCLOSS: Concerning the materials

6 that counsel is using to cross-examine the witness

7 on.

8 THE COURT: All right.

9 (Discussion held off the record at sidebar.)

10 MR. AUCHINCLOSS: If I could just have a

11 moment, Your Honor.

12 THE COURT: Yes.

13 MR. AUCHINCLOSS: I think I can finish with

14 this witness, Your Honor. Just one question.

15

16 REDIRECT EXAMINATION

17 BY MR. AUCHINCLOSS:

18 Q. Mr. Swingler, do you know if David Schmidt

19 has any affiliation with Michael Jackson?

20 A. I just know that he has a website; that

21 he’s, you know, pro Michael Jackson.

22 MR. AUCHINCLOSS: All right. Thank you.

23 I have no further questions.

24 MR. MESEREAU: No further questions, Your

25 Honor.

26 THE COURT: All right. Thank you. You may

27 step down.

28 THE WITNESS: Thank you, sir. 5765



1 THE COURT: Do you have another witness?

2 MR. AUCHINCLOSS: (To Mr. Sneddon) Go

3 ahead.

4 MR. SNEDDON: You.

5 MR. AUCHINCLOSS: Do you want me to do it?

6 (Laughter.)

7 MR. SNEDDON: We’re trying to figure out

8 which one of us should take responsibility for

9 telling you “No.”

10 (Laughter.)

11 MR. SNEDDON: And being the great delegator

12 I am, I’m leaving it up to Gordon.

13 MR. AUCHINCLOSS: We have no further

14 witnesses, Your Honor. We just anticipated that

15 there would be -- it would take a little longer to

16 get through these witnesses today.

17 THE COURT: All right. There’s a couple of

18 items that we can take up. I’ll go ahead and excuse

19 the jury.

20 (To the jury) Remember the admonitions I’ve

21 given you and I’ll see you tomorrow morning at 8:30.

22 But it’s a half day tomorrow, remember. How could

23 you forget, right?

24

25 (The following proceedings were held in

26 open court outside the presence and hearing of the

27 jury:)

28 5766



1 THE COURT: All right. First, there was --

2 my understanding is that the special master will

3 have the report available tomorrow morning for you

4 on the computer hard drives.

5 MR. SNEDDON: On both of them, Your Honor?

6 THE COURT: Yes. They’re working on some

7 last-minute details. So it will be available

8 tomorrow morning.

9 MR. SNEDDON: Now, at that point, then, Your

10 Honor, does it need to go to you for final decision,

11 or is that the decision?

12 THE COURT: I don’t know. I haven’t read

13 the report. I was handed a rough draft of one by my

14 research attorney this morning -- well, not this

15 morning, a few minutes ago. And I asked him to talk

16 to Mr. Sanger about an issue. So I can’t answer

17 your question.

18 MR. SNEDDON: Okay.

19 THE COURT: I suspect it doesn’t need to go

20 beyond what’s been done by the special master, so --

21 MR. SNEDDON: Okay.

22 THE COURT: But I won’t know till I’ve looked

23 at it.

24 The second thing is that both of you have

25 submitted points and authorities on Janet Arvizo.

26 The District Attorney’s I’ve read.

27 And I just received the defense, so I

28 haven’t had time to read yours. 5767



1 When do you expect to call Janet Arvizo?

2 MR. ZONEN: Either tomorrow or Wednesday.

3 Depending on if we finish the witnesses scheduled

4 before her tomorrow. If not --

5 THE COURT: They can’t hear behind you.

6 (To the audience) He said either tomorrow

7 or Wednesday.

8 MR. ZONEN: As early as tomorrow.

9 THE COURT: As early as tomorrow.

10 Okay. Well, I’m not really prepared to deal

11 with that issue. We’ll have to deal with it before

12 she’s called, but I’ll need to study the material

13 you’ve given me, the defense has given me.

14 MR. ZONEN: Thank you.

15 THE COURT: Was there anything else pending?

16 MR. SANGER: On that issue, Your Honor, as I

17 explained to you, as I explained to your clerk, we

18 were served with their papers this morning. We

19 thought they might call Ms. Arvizo today.

20 THE COURT: Right.

21 MR. SANGER: So we put something together

22 very quickly, and I would like to have an

23 opportunity to explain to the Court a little more,

24 in a little more organized fashion, where this goes,

25 now that we’ve had a few more minutes to think about

26 it.

27 THE COURT: I’ll make sure you have that

28 opportunity. 5768



1 MR. SANGER: Okay. Thank you.

2 THE COURT: All right. Then we’ll recess

3 until tomorrow morning.

4 (The proceedings adjourned at 2:30 p.m.)

5 --o0o--

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28 5769



1 REPORTER’S CERTIFICATE

2

3

4 THE PEOPLE OF THE STATE )

5 OF CALIFORNIA, )

6 Plaintiff, )

7 -vs- ) No. 1133603

8 MICHAEL JOE JACKSON, )

9 Defendant. )

10

11

12 I, MICHELE MATTSON McNEIL, RPR, CRR,

13 CSR #3304, Official Court Reporter, do hereby

14 certify:

15 That the foregoing pages 5582 through 5769

16 contain a true and correct transcript of the

17 proceedings had in the within and above-entitled

18 matter as by me taken down in shorthand writing at

19 said proceedings on April 11, 2005, and thereafter

20 reduced to typewriting by computer-aided

21 transcription under my direction.

22 DATED: Santa Maria, California,

23 April 11, 2005.

24

25

26

27 MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304

28 5770



