


5157

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 THURSDAY, APRIL 7, 2005

20

21 8:30 A.M.

22

23 (PAGES 5157 THROUGH 5211)

24

25

26

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

28 BY: Official Court Reporter 5157



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 5158



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 CHACON, Ralph 5161-SN 5202-M

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 5159



1 E X H I B I T S

2 FOR IN

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

4 790 Photograph 5177 5180

5 791 Photograph 5177 5180

6 792 Photograph 5177 5180

7 793 Photograph 5184 5186

8 794 Photograph 5184 5186

9 795 Photograph 5184 5186

10 796 Photograph 5196 5197

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 5160



1 Santa Maria, California

2 Thursday, April 7, 2005

3 8:30 a.m.

4

5 THE COURT: Good morning.

6 THE JURY: (In unison) Good morning.

7 COUNSEL AT COUNSEL TABLE: (In unison)

8 Good morning, Your Honor.

9 THE COURT: Counsel, you may proceed.

10 MR. SNEDDON: Mr. Chacon, would you come

11 forward, please. Right up there.

12 THE COURT: When you get to the witness

13 stand, please remain standing. Face the clerk and

14 raise your right hand.

15

16 RALPH CHACON

17 Having been sworn, testified as follows:

18

19 THE WITNESS: Yes, ma’am.

20 THE CLERK: Please be seated. State and

21 spell your name for the record.

22 THE WITNESS: Ralph Chacon, C-h-a-c-o-n.

23

24 DIRECT EXAMINATION

25 BY MR. SNEDDON:

26 Q. Mr. Chacon, in order for everybody to hear

27 you, you’re going to need to lean into that

28 microphone, okay? Would you do that for us? 5161



1 A. Yes, sir.

2 Q. Thank you.

3 Mr. Chacon, did you used to work at

4 Neverland Valley Ranch?

5 A. Yes, sir.

6 Q. During what period of time?

7 A. Between ‘91 and ‘94.

8 Q. And prior to working at Neverland Valley

9 Ranch, where -- what employment did you have?

10 A. I used to repo vehicles in Thousand Oaks.

11 Q. Is that where you’re from, Thousand Oaks?

12 A. Born and raised, yes, sir.

13 Q. And during the time that you were at

14 Neverland Valley Ranch, what was your position?

15 A. Security.

16 Q. And could you describe to the ladies and

17 gentlemen of the jury generally what your

18 responsibilities were as a security officer?

19 A. Secure Neverland property, front gate, fence

20 lines, around the main house, keeping intruders out,

21 and also taking care of the temperatures in the

22 animal areas.

23 Q. What shift did you work at the ranch?

24 A. Graveyard.

25 Q. Would you tell us what “graveyard,” what

26 that entails? What are the hours?

27 A. From 10:00 till 6:00 in the morning.

28 Q. Now, do you recall a time when you were 5162



1 working at the Neverland Valley Ranch in which Mr.

2 Jackson was the subject of an investigation?

3 A. Yes, sir.

4 Q. And what years was that; do you recall?

5 A. I really don’t. I don’t recall.

6 Q. During the time that you were at the ranch,

7 did you get subpoenaed to appear before the Santa

8 Barbara County Grand Jury?

9 A. Yes, sir, I did.

10 Q. Do you recall when that was?

11 A. I believe it was in ‘94.

12 Q. Do you recall the month?

13 A. I’m guessing, could be probably May or

14 something around there. I’m not sure.

15 Q. And do you know an individual by the name of

16 Kassim Abdool?

17 A. Yes, sir.

18 Q. Who is Kassim Abdool?

19 A. He was at that time chief of security at

20 Neverland.

21 Q. And at the time that you were subpoenaed

22 before the grand jury, were you and Mr. Abdool

23 carpooling back and forth to work?

24 A. Yes, sir, we were.

25 Q. And how long had you known Mr. Abdool?

26 A. Probably the duration of our employment at

27 Neverland. Probably about three years. Three, four

28 years. Something like that. 5163



1 Q. And to your knowledge, did Mr. Abdool also

2 get subpoenaed to appear before the grand jury?

3 A. Yes, sir, he did.

4 Q. And do you recall where you were directed to

5 appear, which county?

6 A. Supposed to be in Los Angeles County. But I

7 didn’t go to Los Angeles County.

8 Q. At some time prior to appearing before the

9 grand jury, pursuant to subpoena, were you contacted

10 by attorneys representing Mr. Jackson?

11 A. Yes, sir.

12 Q. On how many occasions?

13 A. I can remember two occasions that I was

14 called to come before them.

15 Q. And do you recall who those attorneys were?

16 A. Mr. Steve Cochran, I believe, and I remember

17 an Eric Mason. Mr. Sanger.

18 Q. Do you recall where the first meeting

19 occurred?

20 A. It happened in Mr. Jackson’s outside office

21 at Neverland.

22 Q. And do you recall when the second meeting

23 occurred?

24 A. It happened in Santa Barbara at Mr. Sanger’s

25 office.

26 Q. And were both of these meetings prior to the

27 time you were to appear before the grand jury, your

28 subpoena date? 5164



1 A. Yes, sir.

2 Q. Now, as a result of the receiving a subpoena

3 to the grand jury, did you make contact with law

4 enforcement?

5 A. Yes, I did.

6 Q. And do you recall who it was you contacted?

7 A. I believe it was Mr. Birchim.

8 Q. And do you recall what agency Mr. Birchim

9 worked for?

10 A. I believe it was the sheriff -- Santa

11 Barbara Sheriff’s Department.

12 Q. And when you -- I’m sorry. When you

13 contacted Mr. Birchim, did you have a conversation

14 with him?

15 A. Yes, sir.

16 Q. And did you relay to him certain

17 information?

18 A. I did.

19 Q. And after that, did you have contact with

20 any other -- was there more than one meeting with

21 Mr. Birchim?

22 A. I’m sure there was, but I don’t remember.

23 But I know there was more than two meetings with

24 him.

25 Q. Now, you told the ladies and gentlemen of

26 the jury that you did not appear before the Los

27 Angeles County Grand Jury. Did you at some time

28 make a statement under oath with regard to what you 5165



1 observed?

2 A. Yes, sir, I did.

3 Q. And do you recall when that was?

4 A. I believe it was ‘94. I’m not for certain.

5 It’s been a while.

6 Q. Do you recall whether it was at or about the

7 time when you were supposed to appear before the

8 grand jury?

9 A. Oh. Yes, sir. It was probably the day

10 after.

11 Q. And do you recall where it was that you were

12 interviewed?

13 A. In Santa Barbara.

14 Q. And do you recall who was present during the

15 time that you were interviewed?

16 A. Well, the only ones that I remember is

17 yourself and Mr. Birchim.

18 Q. And was that statement given under oath?

19 A. Yes, sir.

20 Q. Now, during the time that you were employed

21 at Neverland Ranch, did you personally observe

22 anything that you felt was inappropriate with regard

23 to Mr. Jackson’s behavior --

24 A. Yes, sir.

25 Q. -- or conduct?

26 And do you recall approximately what year

27 that was?

28 A. I want to say latter ‘92 or early ‘93. I am 5166



1 not -- I’m not positive.

2 Q. Do you recall what time of day or night it

3 was?

4 A. It was -- well, I had come on graveyard

5 shift, so it had to have been about probably

6 midnight, or before midnight.

7 Q. And do you recall what the weather was like

8 that night?

9 A. It was very nice. Very nice weather.

10 Q. Now, when you first came to work that

11 evening, what were the first things that you did; do

12 you recall?

13 A. I would come in and check out the radio. We

14 carried radios and a flashlight. I would check my

15 box for any memos that were generated. Then I

16 would -- we had -- there was electric golf carts

17 that we had to put on chargers for the night.

18 Q. At some time that evening, did you see Mr.

19 Jackson?

20 A. Yes, sir.

21 Q. And do you recall where Mr. Jackson was the

22 first time that you saw him that evening?

23 A. He was headed for the Jacuzzi.

24 Q. And do you know whether or not he was alone

25 or with someone?

26 A. He was with someone.

27 Q. And when you say he was with someone, do you

28 know who that was? 5167



1 A. Yes, sir.

2 Q. Who was that?

3 A. That was Jordie.

4 Q. And could you approximate the age of Jordie?

5 A. I want to say nine, ten years old.

6 Q. So he was with a child?

7 A. Yes, sir.

8 Q. Not an adult?

9 A. No.

10 MR. MESEREAU: Objection; leading.

11 THE COURT: Overruled. Next question.

12 Q. BY MR. SNEDDON: Now, I may have missed this

13 or I may have asked this. When you say you saw Mr.

14 Jackson in the company of this child, Jordie, what

15 direction were they headed?

16 A. Towards the Jacuzzi.

17 Q. Is that an area near where you were putting

18 things away?

19 A. It was close by. But from the area where I

20 was at, the garage area, I had -- I had gone to the

21 barbecue area, which was close, maybe ten feet, to

22 the Jacuzzi.

23 Q. And did you -- were you able to see Mr.

24 Jackson and the child in the Jacuzzi?

25 A. I couldn’t see them from where I was

26 standing, but I could hear them in the water.

27 Q. Now, at some point, did you hear Mr. Jackson

28 speak out? 5168



1 A. Yes, sir.

2 Q. And what --

3 Your Honor, this is not offered for the

4 truth of the matter, but simply to explain the

5 conduct that occurs thereafter?

6 THE COURT: All right.

7 Q. BY MR. SNEDDON: What did you hear Mr.

8 Jackson say?

9 A. While in the Jacuzzi?

10 Q. Yes.

11 A. They were just -- just laughing, playing. I

12 don’t remember what they were saying, but I know

13 that they were talking and having fun.

14 Q. At some time did Mr. Jackson request

15 something from the house?

16 MR. MESEREAU: Objection; leading.

17 THE WITNESS: That was before --

18 THE COURT: Just a moment.

19 MR. SNEDDON: You have to wait for the Judge

20 to rule, I’m sorry.

21 THE WITNESS: I’m sorry.

22 THE COURT: Overruled.

23 You may answer.

24 Q. BY MR. SNEDDON: Okay. Now you can answer.

25 THE COURT: Do you want the question read

26 back?

27 THE WITNESS: No, sir.

28 Well, actually, that was -- I heard them -- 5169



1 I heard him when I was still hooking up the golf

2 carts. He had called for security.

3 MR. MESEREAU: Objection; nonresponsive.

4 THE COURT: Sustained.

5 Q. BY MR. SNEDDON: Okay. So at some point you

6 heard Mr. Jackson yell for security?

7 A. Yes, sir.

8 Q. And where were you when that occurred?

9 A. I was in the garage area.

10 Q. Now, at some point that evening, did you see

11 Mr. Jackson and the child, Jordie, leave the

12 Jacuzzi?

13 A. Yes, sir, I did.

14 Q. Could you tell the ladies and gentlemen of

15 the jury, were you able to observe where they went?

16 A. Yes, sir.

17 Q. And where did they go?

18 A. They were going to the outside rest room

19 area by the rec room.

20 Q. And is the rec room near another building or

21 attached to a building on the premises?

22 A. Well, it’s on its -- the rest room’s

23 attached to the rec room. So it sits by itself.

24 It’s two stories.

25 Q. All right. Are there other facilities

26 inside of that building itself?

27 A. Just a game room, that’s all it was.

28 Q. Do you know what the game room is called? 5170



1 A. Just -- no, I don’t.

2 Q. Describe the game room, if you would.

3 A. They had, like, probably maybe 20 different

4 type of computer games, the first floor, and also

5 with the top, the top floor had different type of

6 games.

7 Q. Have you been in that building before?

8 A. Yes, sir.

9 Q. And do you know whether or not that building

10 has a cellar?

11 A. A what, sir?

12 Q. A cellar?

13 A. Um, I want to say that had a wine cellar,

14 yes, sir.

15 Q. All right. In any event, you saw Mr.

16 Jackson and the child heading towards the rest room

17 area; is that correct?

18 A. Yes, sir.

19 Q. Did you watch them the entire time?

20 A. Yes, sir.

21 Q. And did you see where they went?

22 A. They went inside the rest room.

23 Q. Now, where were you located when you

24 observed this?

25 A. I was in the barbecue area, where I usually

26 normally observe everything.

27 Q. That’s a security position you’re assigned?

28 A. Yes, sir. 5171



1 Q. Now, at the time that you saw Mr. Jackson

2 and the boy go into the rest room area, did you at

3 some point in time approach the rest room?

4 A. Yes, I did.

5 Q. Do you recall from the time that you saw

6 Mr. Jackson and the child go into the rest room

7 area, how long it was before you approached the

8 area?

9 A. Probably a half an hour, maybe 35, 40

10 minutes.

11 Q. And then could you describe to the ladies

12 and gentlemen of the jury where you went?

13 A. I went around the rec room that leads right

14 behind the rest rooms. That’s where I went.

15 Q. And what did you do when you got there?

16 Well, when you got in that area, did you hear or see

17 anything?

18 A. Yes, sir.

19 Q. And which?

20 A. Well, I heard first that Mr. Jackson and the

21 boy were inside a shower, the shower room in there.

22 Q. How many showers are there in the rest room?

23 A. There was only one shower.

24 Q. Let’s just stop right there for just a

25 second, before we go any further. Could you explain

26 to the ladies and gentlemen of the jury the interior

27 of the rest room area?

28 A. As you go in from the rec room, the women’s 5172



1 rest room is on the left and the men’s room is on

2 the right. And as you go in, there’s a dressing

3 area, and it’s open, and it leads into where the

4 wash basins are at, pretty large area. And then it

5 goes into another smaller room where there’s a

6 toilet and the showers.

7 Q. And you said “showers.”

8 A. Shower. Excuse me, shower.

9 Q. All right. Now, you’ve indicated that you

10 heard some people in the shower. Did you recognize

11 the voices?

12 A. Yes, sir, I did.

13 Q. Whose voices did you recognize?

14 A. Mr. Jackson’s and Jordie’s.

15 Q. And did you look into the shower area?

16 A. Not right away. Not the first time that I

17 came around, because I couldn’t see anything. But I

18 started to leave the area when I -- I was thinking,

19 I said, “What’s going on here?” You know, “There’s

20 a grown man in a shower with a boy.”

21 MR. MESEREAU: Objection; move to strike.

22 THE COURT: Stricken.

23 Q. BY MR. SNEDDON: All right. So you left?

24 A. Right.

25 Q. How far did you go?

26 A. I didn’t go too far, probably halfway around

27 the rec room.

28 Q. All right. And did you decide to go back? 5173



1 A. Yes, sir, I did.

2 Q. Why did you decide to go back?

3 A. I wanted to know what was going on in there.

4 Q. Why?

5 A. Because it wasn’t -- it wasn’t right.

6 MR. MESEREAU: Objection. Relevance; move

7 to strike.

8 THE COURT: I’ll strike the question, “Why?”

9 And the answer.

10 Q. BY MR. SNEDDON: Okay. So you went back.

11 When you went back, where did you go to?

12 A. I went back to the same area where the

13 shower was located. There was a window, and I was

14 able to see and they were no longer in the shower.

15 Q. So you looked into the window?

16 A. Yes, sir.

17 Q. All right. And what did you see -- where

18 did you see Mr. Jackson and the child at this point?

19 A. I saw them standing in the nude in the

20 middle area, and Jordie was on the right, and he was

21 on the left side. Standing, facing each other.

22 Q. Now, at the time that you saw that, what

23 were the lighting conditions inside of the rest

24 room?

25 A. Oh, it was litted up, just that area there.

26 Not where the shower’s at, but that area, it was --

27 the lights were on.

28 Q. Did you have any difficulty seeing in there? 5174



1 A. Not at all, sir.

2 Q. Now, from the point outside looking down

3 inside, what did you see go on between the

4 defendant, Mr. Jackson, and Jordan Chandler?

5 A. I saw that Mr. Jackson was caressing the

6 boy’s hair, he was kissing him on his head, and his

7 face, his lips. He started kissing him on the

8 shoulders and started going down to his nipples.

9 Started sucking his nipples. Started going down to

10 his penis and putting it in his mouth. And about

11 that time I just -- I left.

12 Q. Okay. You say you saw him go down and do

13 what?

14 A. He put the little boy’s penis in his mouth.

15 Q. Did you actually see that?

16 A. Yes, sir.

17 Q. And then you left?

18 A. Yes, sir.

19 Q. Where did you go?

20 A. I went back to the barbecue area.

21 Q. Do you recall, after you left that area and

22 observed the things you’ve just related to the jury,

23 did you see Mr. Jackson with the child again that

24 evening?

25 A. Yes, sir, I did.

26 Q. And where were you when you saw them?

27 A. I was in the barbecue area.

28 Q. And where -- where were they when you saw 5175



1 them again?

2 A. They were coming out of the rest room.

3 Q. Now, from the time that you had left, when

4 you had made your observations --

5 A. Yes, sir.

6 Q. -- and you left, till the time that they

7 came out of the rest room, how much time had elapsed

8 during that period of time?

9 A. Probably 20 minutes or 30 minutes.

10 Q. Now, when they came out of the rest room,

11 could you describe what was going on?

12 A. Jordie was mounted on Michael’s back,

13 piggybacked, and they were headed for the back of

14 the -- the kitchen door to the main house.

15 Q. Did the child, Jordan, have any clothing on?

16 A. He had -- I believe it was like -- it was a

17 towel. I believe it was a towel. It’s the type --

18 like it’s a rope, but it’s a towel.

19 Q. So a cloth robe or towel of some kind?

20 A. Yes, sir.

21 Q. Okay. And what was Mr. Jackson wearing, if

22 you recall?

23 A. Same.

24 Q. Could you see whether or not the child,

25 Jordan, had any other clothing on or not?

26 A. No, sir. I didn’t observe.

27 Q. And where did they go?

28 A. They went inside the house, the main house. 5176



1 Q. And when they went inside the main house,

2 did you hear or observe anything happen that you

3 felt was unusual?

4 A. Yes, Mr. Jackson double-locked the door, the

5 back door, which he normally never did. Security

6 always went inside to secure the house inside and

7 out.

8 Q. Now, you say -- you described to the jury

9 that Mr. Jackson was kissing the boy --

10 A. Yes, sir.

11 Q. -- that you observed.

12 How would you describe the kissing?

13 A. Well, it was very passionate. Very

14 passionately he was kissing him.

15 Q. And did you see his hands during the time he

16 was kissing him?

17 A. Yes, sir.

18 Q. Where were they?

19 A. They were all over his body.

20 Q. All right. I want to show you a couple of

21 photographs, if we might, Mr. Chacon.

22 I’ve shown these to counsel, Your Honor.

23 The photographs are 790, 791, and 792.

24 All right. Mr. Chacon, let’s look at the

25 photographs. First of all, let’s start with 790.

26 Do you recognize that?

27 A. 790?

28 Q. Yeah. I’m sorry, you have to turn it over 5177



1 on the back.

2 A. Oh, yes, sir.

3 Q. All right. Let’s start with that. Do you

4 recognize what’s depicted in the photograph, 790?

5 A. Yes, sir.

6 Q. And what is that?

7 A. That’s where the swimming pool’s at, and

8 it’s -- you’re facing at the rec room in front of

9 you, and to the left is the garage area where the

10 carts -- where I was hooking up the carts.

11 Q. Does that photograph depict a portion or

12 some of the route that you took where you walked to

13 the area that you observed Mr. Jackson and the

14 child, Jordan?

15 A. Yes, sir.

16 Q. Now, what I’d like you to do is to please

17 take that black felt tip pen that I’ve given you

18 there, and would you please just draw the path that

19 you took that’s covered by that photograph, that

20 portion of it.

21 And does that photograph accurately depict

22 the area of what you call the rec room at the time

23 that you made the observations of Mr. Jackson and

24 the child, Jordan?

25 A. Yes, sir.

26 Q. All right. Let’s turn that one over and go

27 to the next one that has “791” on it, okay? Do you

28 recognize that? 5178



1 A. Yes, sir.

2 Q. All right. What is 791?

3 A. It’s the pool area, and directly in front is

4 the rec room and the rest room. The rest rooms.

5 Q. Does the photograph, 791, show the area of

6 the entrance into the bathroom area?

7 A. Yes, sir.

8 Q. And does it show the Jacuzzi?

9 A. Yes, sir.

10 Q. And does it show the approximate area of

11 the -- where you made your observations?

12 A. Well, it’s behind the -- just the other side

13 of the Jacuzzi, yes, sir.

14 Q. Okay. With regard to that particular

15 photograph -- and I’m going to ask you, does it

16 accurately depict the area as you recall it in 1992

17 or ‘93 when you made your observations?

18 A. Yes, sir.

19 Q. All right. I’m going to ask you, please,

20 take that black marker, please, and if you would

21 just circle the area that depicts the entrance into

22 the rest room area?

23 And would you please put an “X” in the

24 approximate area where it was that you made the

25 observations of Mr. Jackson and the child?

26 Now, let’s take the last photograph, which

27 is 792 for identification purposes. Do you

28 recognize that photograph? 5179



1 A. Yes, sir.

2 Q. And can you tell the jury what that is,

3 please?

4 A. It’s the barbecue area.

5 Q. Okay. Now, is that the area that you have

6 made reference to in your testimony?

7 A. Yes, sir.

8 Q. And does that photograph accurately depict

9 that area as it was back when you were working at

10 Neverland Valley Ranch?

11 A. Yes, sir.

12 MR. SNEDDON: Your Honor, I move that 790,

13 791, and 792 be admitted into evidence.

14 MR. MESEREAU: No objection.

15 THE COURT: They’re admitted.

16 MR. SNEDDON: And, Your Honor, could we have

17 the input for the Elmo, please?

18 Q. BY MR. SNEDDON: This is a laser and I’m

19 going to ask you to point to some things.

20 A. Okay.

21 Q. All right. This is the exhibit that’s been

22 marked as Exhibit 790 for identification purposes,

23 all right? Do you recognize that, Mr. Chacon?

24 A. Yes, sir.

25 Q. Would you show the jury the black line that

26 you placed on this particular exhibit?

27 Okay. It starts at the left-hand side of

28 the photograph; is that correct? 5180



1 A. Yes, sir.

2 Q. And moves - go ahead, just trace it - all

3 the way to almost the right-hand side -- or the

4 left-hand side of the building, correct?

5 A. Yes, sir.

6 Q. Would you tell the ladies and gentlemen of

7 the jury, as you walk down past the side of that

8 building that’s depicted in the far right-hand side

9 of the photograph, People’s 790, what is down there?

10 A. There is a tennis court. It’s a sunken

11 tennis court.

12 Q. And what are the lighting conditions? Is

13 there a path that goes along there?

14 A. Yes, sir, there is.

15 Q. What are the lighting conditions along that

16 path?

17 A. Around the back, there wasn’t.

18 Q. How about along the path itself?

19 A. Towards the -- behind the rest rooms, there

20 was a path where there was just small little lights

21 on the ground.

22 Q. Now, did you have a flashlight with you that

23 night?

24 A. Yes sir.

25 Q. Is that part of your standard equipment --

26 A. Yes.

27 Q. -- that you carry on the graveyard shift?

28 A. Yes, sir. 5181



1 Q. The building that’s depicted on the far

2 right-hand side of the photograph - yes, sir, the

3 one you’re showing the jury there - what is that

4 building there?

5 A. That’s the rec room.

6 Q. And let’s go to 791, if we could.

7 All right. Would you show the ladies and

8 gentlemen of the jury, first of all, what you

9 referred to as a Jacuzzi?

10 A. Right here.

11 Q. So that’s in the lower left-hand corner of

12 the exhibit, 791?

13 A. Yes, sir.

14 Q. Now, where is the entrance to the rest room?

15 A. Right in there.

16 Q. And it’s hard to see, but you drew a circle

17 around that in black?

18 A. Yes, sir. Right there.

19 Q. And now, where -- on this photograph, if you

20 can, can you show the approximate area of where it

21 was that you have made the observations you

22 described to the jury?

23 A. Well, this is the rest room in front, and on

24 the side, about right in there. The path is right

25 on the other side on the building there.

26 Q. On the back side of the building?

27 A. Yes, sir.

28 Q. Okay. Now, let’s show the next photograph 5182



1 and then I’ll come back to this.

2 This is 792 in evidence. Do you recognize

3 that?

4 A. Yes, sir.

5 Q. And what is that?

6 A. That’s the barbecue area.

7 Q. Okay. Now, with regard to this particular

8 photograph, where were you located in your position

9 as a security officer on this evening when you

10 observed the defendant and the child, Jordan, walk

11 into the rest room?

12 A. I was about right in that area.

13 Q. So you’re indicating to the right-hand side

14 of the barbecue area, just to the right of the post?

15 A. Right. Yes, sir.

16 Q. The post on the -- and were you behind the

17 barbecue itself or on the other side of it?

18 A. Well -- well, actually, I was like -- I was

19 moving up and down the side of it, on the other

20 side.

21 Q. On the outside of it?

22 A. Yes, sir.

23 Q. So not in the interior part, but --

24 A. Well, it was in the -- the interior is on

25 the other side also. Because this is in the center.

26 Q. Just so we can get it clarified, which side

27 of that were you on?

28 A. I was on -- I believe I was on that other 5183



1 side.

2 Q. Now, is the area of the -- let’s go back to

3 791 for a second, if we could. You pointed out the

4 Jacuzzi, and obviously there’s a swimming pool also

5 there.

6 A. Yes, sir.

7 Q. Now, with regard to that area, is that area

8 lit at night?

9 A. It is.

10 Q. Or was it then? Let’s put it that way.

11 A. Yeah, just a bit. Because the sidewalks had

12 these lights, these small lights, as you went up

13 through the path. And if I remember correctly, I

14 guess there was some -- some lighting, but not that

15 much. But you could see where you were walking,

16 though.

17 MR. SNEDDON: Okay. All right. You can

18 take that down.

19 I have three more photographs, I’ve shown

20 them to counsel, that have been marked as 793, 794,

21 and 795 for identification purposes. I’d like to

22 show them to the witness.

23 THE COURT: All right.

24 Q. BY MR. SNEDDON: Mr. Chacon, I’m going to

25 show you the photograph marked as 793. You’ve seen

26 that photograph before?

27 A. Yes, sir.

28 Q. And do you recognize the person that you 5184



1 believe that that photograph depicts?

2 A. Yes, sir.

3 Q. Who is that?

4 A. Jordie.

5 Q. Is that a depiction of the child as you

6 recall him back in those days?

7 A. Yes, sir.

8 Q. And with regard to 794, it has two

9 photographs on it, one at the top and one at the

10 bottom. The one at the top is a singular photograph

11 of an individual, and the one at the bottom has four

12 people in that. Do you recognize the people in that

13 photograph?

14 A. Yes, sir.

15 Q. And again, who is that?

16 A. Jordie.

17 Q. And in the photograph at the bottom, there

18 are a number of people depicted. Which of them do

19 you recognize as Jordie?

20 A. This one here.

21 Q. Would you please take that black pen and

22 just put an arrow towards -- start on the white,

23 down below. Okay. Thank you.

24 And with regard to 795, do you recognize

25 that?

26 A. Yes, sir.

27 Q. And again, there are a number of people

28 depicted in that photograph, correct? 5185



1 A. Yes, sir.

2 Q. And do you recognize anybody in that

3 photograph?

4 A. Yes, sir, I do.

5 Q. Who would that be?

6 A. That’s Jordie.

7 Q. By “that” you mean who, in terms of --

8 there’s one, two, three, four, five people depicted.

9 A. The fifth one.

10 Q. All the way over to the left?

11 A. All the way over to the left.

12 Q. Are these accurate depictions of the child

13 as you recall him back in those days?

14 A. Yes, sir.

15 MR. SNEDDON: Move that they be admitted

16 into evidence, Your Honor.

17 MR. MESEREAU: No objection.

18 THE COURT: Admitted.

19 Q. BY MR. SNEDDON: Now, Mr. Chacon, are you

20 familiar with a child by the name -- a young boy by

21 the name of Brett Barnes?

22 A. Yes, sir.

23 Q. And have you seen Mr. Barnes before?

24 A. Yes, sir.

25 Q. Have you seen him at the ranch before?

26 A. Yes, sir.

27 Q. Have you seen him in the company of the

28 defendant before? 5186



1 A. Yes, sir.

2 Q. On how many occasions?

3 A. Numerous occasions. I couldn’t give you a

4 figure.

5 Q. When Mr. Barnes was at the ranch, do you

6 recall whether or not his parents were with him?

7 A. At times they were; at other times they

8 weren’t.

9 Q. Now, with regard to the child you’ve

10 described and identified as Jordan Chandler, and the

11 child that you also saw as Brett Barnes, can you

12 tell us what they look like?

13 A. Well, to me, I always got them confused,

14 because they looked the same, similar. I know one

15 was a little bit shorter than the other. But, you

16 know, I always got them confused, but they looked --

17 they looked alike. Maybe one had hair a little bit

18 shorter than the other.

19 MR. MESEREAU: Objection. Nonresponsive;

20 narrative.

21 THE COURT: Overruled.

22 Q. BY MR. SNEDDON: Go ahead.

23 A. But I would get them -- I would -- they just

24 looked the same to me.

25 MR. SNEDDON: All right. If we could have

26 the Elmo again.

27 Q. I’m going to start backwards at 795. Now,

28 would you use the -- thank you. 5187



1 That’s the child you identified by the name

2 of what?

3 A. Jordie.

4 Q. All right. And now 794. Let’s do the

5 bottom one for right now.

6 Now, the bottom one, you put an arrow; is

7 that correct?

8 A. Yes, sir.

9 Q. Which is the child that you were identifying

10 that you recognize as Jordie.

11 Okay. The one in the middle of the

12 photograph?

13 A. Yes.

14 Q. In the front --

15 A. Yes, sir.

16 Q. -- right?

17 And let’s -- let me ask a question about the

18 top photograph. With regard to that photograph, do

19 you recognize that person?

20 A. Yes, sir.

21 Q. All right. Who’s that?

22 A. That’s Jordie.

23 Q. Okay. And lastly, that’s 793 in evidence.

24 And you’ve identified that individual as also

25 Jordie, correct?

26 A. Yes, sir.

27 MR. SNEDDON: All right. Thank you. We

28 could have the lights again. 5188



1 Q. Now, during the time of your employment at

2 Neverland Valley Ranch -- let me go back a second,

3 okay?

4 A. Yes, sir.

5 Q. With regard to the incidents that you just

6 described to the ladies and gentlemen of the jury

7 here involving Mr. Jackson and the child you’ve

8 identified as Jordan, correct?

9 A. Yes, sir.

10 Q. Are those -- is that -- is that what you

11 told the grand jury when you were interviewed back

12 in 1994?

13 A. Yes, sir, I did.

14 Q. Now, let’s go on for just a moment.

15 Did you see any other incidents involving

16 Mr. Jackson and the child you described as Jordan?

17 A. Yes, sir.

18 Q. With regard to the second -- and let’s just

19 call it the second incident. With regard to the

20 second incident, do you recall how much time had

21 elapsed between the two incidents?

22 A. I don’t recall, sir.

23 Q. Could you give us some idea whether it was

24 weeks, months, or years?

25 A. Could have been weeks. Could have been a

26 month. I’m not positive. It’s been a while.

27 Q. Okay. And let me go back just for one

28 second before we move on to the second incident. 5189



1 Was there another thing that occurred on the

2 evening of the incident where you saw Mr. Jackson

3 and the child, Jordan, in the rest room together

4 that you had to actually make a report on?

5 A. Yes, sir.

6 Q. And what was -- what was that?

7 A. Well --

8 Q. What happened?

9 A. Well, Kassim Abdool and myself, we were

10 going around the house, the back side of the house,

11 checking for anything that was open, the normal

12 security checkup that we would do around the house.

13 And we observed that the two French doors in the

14 middle of the house were wide open.

15 Q. And so a note was made of that to your

16 supervisor?

17 A. Yes, sir.

18 Q. Who was your supervisor?

19 A. Lieutenant Wade. Kassim Abdool had written

20 a report in regards to the French doors being open

21 and we didn’t close them.

22 MR. MESEREAU: Objection; nonresponsive.

23 THE COURT: Sustained.

24 MR. MESEREAU: Move to strike.

25 THE COURT: After “Lieutenant Wade” is

26 stricken.

27 MR. SNEDDON: Okay.

28 Q. So a report was prepared of that? 5190



1 A. Yes, sir.

2 Q. Now, the incident about the French doors

3 being open, was that before or after you had

4 observed Mr. Jackson?

5 A. After.

6 Q. It was later that evening?

7 A. Yes, sir.

8 Q. All right. Now we can move on.

9 On the second incident - we’re going to call

10 it the second incident just for purposes of - what

11 was it -- were you working graveyard again?

12 A. Yes, sir.

13 Q. And do you recall approximately what time of

14 the night it was?

15 A. It was in the evening, after ten o’clock

16 when I come on.

17 Q. Where were you?

18 A. I was in the pool area. Barbecue area, pool

19 area.

20 Q. And did you see Mr. Jackson that evening?

21 Let me go back. Did you see Jordan that evening?

22 A. Yes, I did.

23 Q. And the child you’ve identified as Brett,

24 did you see him that evening?

25 A. Yes, sir.

26 Q. Where were they?

27 A. They were in the rec room, playing with the

28 machines. 5191



1 Q. Was there any other children in the rec

2 room?

3 A. Yes, I noticed a little girl, probably five,

4 six years old. I didn’t know who she was, but I’m

5 sure she was probably a sister of one of the boys.

6 Q. And did you at some point become aware of

7 the fact -- let me ask you this. Prior -- when the

8 children were in the rec room playing, to your

9 knowledge, was Mr. Jackson on the premises?

10 A. No, sir.

11 Q. And did you become aware at some point in

12 time that Mr. Jackson was on the premises?

13 A. Yes, sir.

14 Q. And did you at some point see Mr. Jackson on

15 the premises?

16 A. Yes, sir.

17 Q. And where was Mr. Jackson the first time you

18 saw him?

19 A. He was coming out the back of his door --

20 the back door of his house, the main house.

21 Q. All right. And describe to the jury what

22 you observed Mr. Jackson to do.

23 A. He kind of ran up to the rec room, and he

24 was looking in from the outside, and he spotted

25 Jordie in one of those little -- it’s like a car you

26 play, a racing car. And Mr. Jackson went around the

27 area where the rest rooms were at. There’s a back

28 door that goes into the rec room, and he located 5192



1 Jordie back there, and he went to where Jordie was

2 at and --

3 Q. Let’s just stop right there for just a

4 second, okay? You saw him go into the rec room

5 through a back door entrance?

6 A. Yes, sir.

7 Q. At the time you saw him go up to Jordan,

8 where were the other children? Could you see?

9 A. Yeah, they were upstairs playing games.

10 Q. Were the lights on inside of the rec room?

11 A. Yes, sir.

12 Q. Did you have any difficulty seeing in the

13 rec room?

14 A. Oh, no. No, sir.

15 Q. And where were you located at the time you

16 made these observations?

17 A. I was around the pool area, almost right

18 directly in front of the rec room.

19 Q. Now, at that point in time when you saw Mr.

20 Jackson go actually physically into the rec room,

21 describe to the jury what you saw occur.

22 A. Well, I saw him enter through the back door

23 of the rec room, and he went over to Jordie. He

24 bent over and said something to him, and then he

25 kissed him. And then they got out the back door and

26 they ran over to Mr. Jackson’s Moon Rover, and --

27 that was a golf cart that he had specially made for

28 himself, and they took off. 5193



1 Q. When you say he kissed him, did you see

2 where he kissed him?

3 A. Not exactly, but I know he kissed him.

4 Q. Now, at some point that evening, did you see

5 Mr. Jackson again?

6 A. Yes, sir. When they came back.

7 Q. When they came back. And where were you

8 when they came back?

9 A. I was in the barbecue area.

10 Q. And when they came back, where did they --

11 physically, where did you see them when you --

12 A. They pulled up to what they called the

13 breezeway, which is between the main office and the

14 main house, the outside office and the main house.

15 Q. Okay.

16 A. Behind the back.

17 Q. And what did -- what -- was anybody else

18 present when they drove up?

19 A. Kassim Abdool was coming from the security

20 at that time also.

21 Q. So what did you see occur at that point in

22 time?

23 A. Well, I saw that Mr. Jackson and Brett --

24 I mean Jordie got off the cart. And Kassim noticed

25 that they were back, so he just headed back to the

26 security -- security office.

27 And Mr. Jackson and the boy were in front of

28 the -- they call it the Peter Pan display. It’s a 5194



1 window where Peter Pan lights up.

2 Q. Can you describe that? Where is that

3 located, what building?

4 A. Well, it’s the -- it’s where the office is

5 at, behind the main house. It’s connected. There’s

6 a breezeway, but it’s connected. And there’s a

7 display window, or a window where this Peter Pan

8 display is at, where it lights up and you see

9 Tinkerbell flying around the window.

10 Q. Okay. Could you describe to the jury the

11 positions of the child and the defendant, Mr.

12 Jackson?

13 A. Well, they were looking at the display, the

14 Tinkerbell lighting up. And he was -- Jordie was in

15 front, Mr. Jackson was in back, and he had his hands

16 over like this, and --

17 Q. You’re indicating over --

18 A. Over his back, towards the front.

19 Q. Okay.

20 A. And then he turned him around, kissed him.

21 It was passionate, but it didn’t last that long.

22 And then his hands went down to his private areas.

23 And then they ran inside the house.

24 Q. All right. You say he kissed him, and it

25 was not very long but it was passionate. Where did

26 he kiss the child?

27 A. In the mouth.

28 Q. And when you say “his hands went down,” 5195



1 where did they go -- whose hands went down where?

2 A. Mr. Jackson’s hands went down to his crotch

3 area, the boy’s.

4 Q. The boy’s?

5 A. Yes, sir.

6 Q. And what -- how long -- how long do you

7 estimate that this incident took?

8 A. It was -- it didn’t take very long.

9 Probably 10 seconds, 20 minutes. I’m not sure.

10 Q. And then at that point what did you see?

11 A. They went -- ran inside the back, the inside

12 of the house.

13 Q. Both the child and Mr. Jackson?

14 A. Yes, sir.

15 MR. SNEDDON: Just a moment, Your Honor.

16 Well, I must have misplaced it.

17 Your Honor, I have one other photograph I’d

18 like to have marked as 796 for identification

19 purposes. And I’ve shown it to counsel.

20 Q. With regard to the exhibit, 796, do you

21 recognize that?

22 A. Yes, sir.

23 Q. What is -- what is that?

24 A. This is behind the house. This is behind

25 the house. This is the office. And this is the

26 breezeway.

27 Q. So when you talk about a breezeway in your

28 testimony, this photograph depicts that breezeway? 5196



1 A. Yes, sir.

2 Q. And does it depict the office that you were

3 talking about?

4 A. Yes, sir.

5 Q. All right. What I want you to do is, on

6 that photograph, just draw a little arrow and an “O”

7 to the building that you indicated is the office,

8 okay?

9 A. Yes, sir.

10 Q. And then just put a big “B” in the area that

11 you call the breezeway.

12 All right. Is that photograph an accurate

13 depiction of the area as you recall it back when you

14 observed these incidents?

15 A. Yes, sir.

16 MR. SNEDDON: All right. Move that it be

17 admitted into evidence, Your Honor.

18 MR. MESEREAU: No objection.

19 THE COURT: It’s admitted.

20 MR. SNEDDON: Could we have the lights just

21 briefly, Your Honor?

22 Q. All right. This is 796, the photograph we

23 were just talking about, okay?

24 A. Yes.

25 Q. Would you use that little red laser again,

26 and indicate -- there’s the “B” that you put, and

27 that is the area that you consider the breezeway?

28 A. Yes, sir. 5197



1 Q. And you also put an “O” with an arrow.

2 Would you find that for the jury.

3 All right. And that’s the area that you

4 described as what?

5 A. The outer office where the display is on the

6 window.

7 Q. Okay. All right. All right. That’s good.

8 I just wanted to get those down so everybody can get

9 an idea of what it was like.

10 All right. We can have the lights again.

11 Now, prior to the time -- let me ask you

12 this: With regard to the testimony you’ve just

13 related to the ladies and gentlemen of the jury here

14 this morning, did you also describe those incidents

15 to the -- when you were asked to make a statement

16 under oath?

17 A. Yes, sir.

18 Q. When you were subpoenaed to the grand jury?

19 A. Yes, sir.

20 Q. Now, prior to the time that you appeared to

21 give a statement under oath as to the events that

22 you related here this morning, had you ever told

23 anyone about what you saw?

24 A. No, sir.

25 Q. Had you ever mentioned it to anybody?

26 A. No, sir.

27 Q. Why not?

28 MR. MESEREAU: Objection; relevance. 5198



1 THE COURT: Overruled.

2 You may answer.

3 THE WITNESS: Well, a lot of things went

4 through my mind, but one of the things was who would

5 believe me?

6 Q. BY MR. SNEDDON: Why?

7 A. Well --

8 MR. MESEREAU: Objection.

9 THE COURT: Sustained.

10 Q. BY MR. SNEDDON: What else went through your

11 mind?

12 MR. MESEREAU: Objection.

13 THE COURT: Sustained.

14 Q. BY MR. SNEDDON: Have you ever personally

15 met anybody by the name of Blanca Francia?

16 A. No, sir.

17 Q. Have you ever personally met anyone by the

18 name of Phillipe LeMarque?

19 A. No, sir.

20 Q. Have you met Wade Robeson?

21 A. Yes, sir.

22 Q. And how did you meet Wade Robeson?

23 A. Just by being on the property and -- and him

24 being on the property.

25 Q. How often was he on the property?

26 A. Numerous times, but I can’t give you a

27 number of how many times.

28 Q. Mr. Chacon, when you left the ranch as an 5199



1 employee - okay? --

2 A. Yes, sir.

3 Q. Oh, I had another question before we get

4 there.

5 Were you armed?

6 A. No, sir.

7 Q. At the time that Mr. Jackson -- during the

8 time that you became aware of the fact that Mr.

9 Jackson was under investigation, were there any

10 guards on the ranch property that were armed?

11 A. Yes, sir.

12 Q. And how many?

13 A. There was about four or five of them.

14 Q. Were they people who had been employed by

15 the ranch as security officers for -- prior to that

16 time?

17 A. No, sir.

18 Q. Now, when you left the ranch, why did you

19 leave?

20 A. I was forced to leave --

21 MR. MESEREAU: Objection; relevance.

22 THE COURT: Overruled.

23 You may answer.

24 THE WITNESS: I was forced to leave because

25 of the OSS, the bodyguards that came on the property

26 that were armed, because we would not comply with

27 whatever they wanted us to do or say, because we

28 didn’t -- we didn’t -- we went to the grand jury, 5200



1 but they didn’t know what we had said so they had

2 put pressure on us to quit.

3 Q. BY MR. SNEDDON: Did you ever tell anybody

4 after you went to the grand jury what you had

5 testified to in front of the grand jury?

6 A. After?

7 Q. Yeah. Anybody associated with Mr. Jackson.

8 A. Yes.

9 Q. Who was that?

10 A. Kassim Abdool.

11 Q. And that’s the person you worked with?

12 A. Yes, sir.

13 Q. Other than that, anybody else?

14 A. No, sir.

15 Q. Did you at some point in time file a lawsuit

16 against Mr. Jackson, you and other members of the

17 staff?

18 A. Yes, sir, we did.

19 Q. And in that particular lawsuit, where was

20 that tried?

21 A. Santa Maria, right here, sir.

22 Q. And did you lose that lawsuit?

23 A. Yes, sir.

24 MR. SNEDDON: I have no further questions,

25 Your Honor.

26 THE COURT: Cross-examine?

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

28 // 5201



1 CROSS-EXAMINATION

2 BY MR. MESEREAU:

3 Q. Good morning, Mr. Chacon.

4 A. Good morning, sir.

5 Q. Mr. Chacon, my name is Tom Mesereau, and I

6 speak for Mr. Jackson.

7 A. Yes, sir.

8 Q. I’d like to ask you a few questions about

9 that lawsuit you lost. That was the longest civil

10 trial in the history of Santa Maria, right?

11 A. I don’t know, sir.

12 Q. It went about six months, didn’t it?

13 A. I believe so, yes, sir.

14 Q. You sued Mr. Jackson and you wanted $16

15 million, right?

16 A. Well, I don’t know about the 16 million.

17 Q. You wanted millions, true?

18 A. No, sir.

19 Q. Really?

20 A. Well, I don’t know, sir. Whatever our

21 attorney was -- he’s the one who was speaking for

22 us.

23 Q. Okay. We’ll get into that.

24 You sued Mr. Jackson claiming you were

25 wrongfully terminated, right?

26 A. That’s correct, sir.

27 Q. He sued you claiming you had stolen property

28 from him, true? 5202



1 A. That’s correct, sir.

2 Q. The jury found you were not wrongfully

3 terminated by Mr. Jackson, correct?

4 A. But we were, sir.

5 Q. Answer my question, please. Did the Santa

6 Maria jury find you were not wrongfully terminated

7 by Mr. Jackson?

8 A. Yes, sir.

9 Q. And they also found you had stolen property

10 from Mr. Jackson, correct?

11 A. But I didn’t, sir.

12 Q. Did the Santa Maria jury find you had stolen

13 property from Mr. Jackson?

14 A. Yes, sir.

15 Q. A judgment was entered against you, Mr.

16 Chacon, for $25,000, the value of what you had

17 stolen, correct?

18 A. For candy bars, sir?

19 Q. A judgment was entered against you for

20 $25,000, the value of what the Court found you had

21 stolen, correct?

22 A. Well, if a candy bar is worth that much,

23 yes, sir.

24 Q. That’s not all you owe Mr. Jackson

25 currently, is it?

26 A. No, sir. I don’t owe him.

27 Q. In fact, Judge Zel Canter of this court,

28 entered a judgment against you and your 5203



1 co-defendants for $1,473,117.61, correct?

2 A. Yes, sir.

3 Q. He ordered you pay all of Mr. Jackson’s

4 legal fees and costs, correct?

5 A. Yes, sir.

6 Q. Have you ever paid any of that judgment, Mr.

7 Chacon?

8 A. No, sir. I filed bankruptcy.

9 Q. Now, the jury found you not only stole from

10 Mr. Jackson, but you acted maliciously, correct?

11 A. No, sir.

12 Q. Did a judge find you had acted with malice?

13 A. No, sir.

14 Q. Is there a judgment against you for acting

15 with fraud against Mr. Jackson?

16 A. That I know of, no, sir.

17 Q. Would it refresh your recollection to look

18 at the judgment?

19 A. Yes, sir.

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

21 THE COURT: Yes.

22 THE WITNESS: Okay.

23 Oh, it’s there, sir. I didn’t know. Yes,

24 sir.

25 Q. BY MR. MESEREAU: Have you had a chance to

26 look at that judgment, Mr. Chacon?

27 A. Do you mean right now?

28 Q. Yes. 5204



1 A. Yes, sir.

2 Q. There is not only a judgment against you in

3 favor of Mr. Jackson --

4 MR. SNEDDON: Wait a minute. I’m going to

5 object. He asked to refresh his recollection. He

6 should ask him if it did.

7 MR. MESEREAU: Sure.

8 THE COURT: That’s correct.

9 Q. BY MR. MESEREAU: Have you had a chance to

10 look at the judgment against you, Mr. Chacon?

11 A. I looked at that, yes, sir. But I don’t

12 remember it.

13 Q. Does it refresh your recollection that

14 there’s a judgment against you for fraud and

15 malice --

16 A. No, sir.

17 Q. -- in favor of Mr. Jackson?

18 A. Yes, sir.

19 Q. You never heard of that before?

20 A. Well, probably, but I don’t remember.

21 Q. After a six-month trial, you don’t remember?

22 A. Well, it’s been 12 years also, sir, or so.

23 Q. Do you remember stipulating and agreeing

24 that you had personally acted with fraud, oppression

25 and malice against Mr. Jackson?

26 A. Probably so, sir.

27 Q. You did that, didn’t you?

28 A. No, sir. 5205



1 Q. You didn’t stipulate that you had acted with

2 fraud, oppression, and malice against Mr. Jackson in

3 that case?

4 A. Well, yes, sir.

5 Q. After a six-month trial, this is a good way

6 to get even with him, isn’t it?

7 MR. SNEDDON: Argumentative. Object, Your

8 Honor. Move to strike.

9 THE COURT: Sustained.

10 Q. BY MR. MESEREAU: Do you have any motive

11 today, sir, to get even with Mr. Jackson?

12 A. No, sir.

13 Q. Do you remember telling a therapist you’d

14 rather get a million dollars from Mr. Jackson than

15 work?

16 A. No, sir.

17 Q. Do you remember being evaluated by a Ph.D.

18 named Dr. Scott Gorsuch?

19 A. I don’t recall, sir.

20 Q. Do you recall being evaluated by a therapist

21 in that lawsuit?

22 A. Probably at one point, but I don’t recall

23 it, sir.

24 Q. Who was your lawyer in that case?

25 A. Mr. Ring from Santa Barbara.

26 Q. Do you remember, in response to being called

27 a malinger, you said, “I’d like just a million from

28 Mr. Jackson”? 5206



1 A. That’s not true, sir.

2 Q. Never happened?

3 A. No, sir.

4 Q. Do you recall making statements you didn’t

5 want to work again?

6 A. No, sir.

7 Q. Okay. After you left Mr. Jackson, you filed

8 for disability, didn’t you?

9 A. Yes, sir.

10 Q. You weren’t disabled, were you?

11 A. I think it was just unemployment, wasn’t it?

12 Q. Did you file for disability, Mr. Chacon,

13 after you left Mr. Jackson’s employment?

14 A. It was unemployment, I believe it was.

15 Q. Okay. You had a deposition taken in that

16 case under oath, correct?

17 A. Yes, sir.

18 Q. And that was not the first time you had ever

19 been deposed, correct?

20 A. I don’t understand, sir, what you’re saying.

21 Q. You had had your deposition taken in

22 lawsuits before that one, true?

23 A. No, sir. Not that I recall.

24 Q. That was the first deposition you’d ever had

25 taken that you recall?

26 A. In my life?

27 Q. Yes.

28 A. Yes, sir. 5207



1 Q. Okay. Do you remember being asked if you

2 were aware that your attorney wanted $16 million for

3 you from Mr. Jackson and you said you understood

4 that?

5 A. No, sir.

6 Q. Would it refresh your recollection to show

7 you a page from your deposition?

8 A. Yes, sir.

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

10 THE COURT: Yes.

11 THE WITNESS: Where does it say 16 million?

12 Oh, okay, I see that.

13 Q. BY MR. MESEREAU: Have you had a chance to

14 look at that page of your deposition?

15 A. Yes, sir.

16 Q. Remember you said you were aware that your

17 lawyer had asked for 16 million?

18 MR. SNEDDON: I’m going to ask that counsel

19 be directed to ask whether it refreshes his

20 recollection before he reads.

21 MR. MESEREAU: I’m sorry. I will withdraw

22 the question.

23 Q. Have you looked at that deposition?

24 A. Yes, sir.

25 Q. You were under oath at the time, correct?

26 A. Yes, sir.

27 Q. Does it refresh your recollection that you

28 admitted you knew your lawyer had asked for $16 5208



1 million?

2 A. No, sir.

3 Q. In fact, you said you didn’t think 16

4 million was enough, correct?

5 A. No, sir.

6 Q. Would it refresh your recollection if I just

7 show you your deposition?

8 A. Yes, sir.

9 MR. MESEREAU: May I approach?

10 THE COURT: Yes.

11 THE WITNESS: That’s on there.

12 Q. BY MR. MESEREAU: Have you had a chance to

13 look at that page?

14 A. Yes, sir.

15 Q. Does it refresh your recollection that you

16 didn’t think $16 million was enough to you?

17 A. No, sir, I don’t.

18 Q. You didn’t say that?

19 A. No, I mean, I don’t -- now I see it’s

20 written down there, yes, sir.

21 Q. Well, how much did you want in the lawsuit,

22 sir?

23 MR. SNEDDON: Object as argumentative, Your

24 Honor.

25 THE COURT: Sustained.

26 Q. BY MR. MESEREAU: In that lawsuit, you tried

27 to extort Mr. Jackson, didn’t you?

28 A. No, sir. 5209



1 MR. SNEDDON: Object; argumentative, Your

2 Honor.

3 THE COURT: Sustained.

4 Q. BY MR. MESEREAU: Do you remember being

5 asked at the beginning of your deposition, “Have you

6 ever been deposed before?” And you said, “Yes”?

7 A. No, I don’t recall, sir.

8 Q. Might it refresh your recollection to see

9 that page?

10 A. Yes, sir.

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

12 THE COURT: Yes.

13 THE WITNESS: Okay, sir.

14 Q. BY MR. MESEREAU: Have you had a chance to

15 look at that?

16 A. Yes, sir.

17 Q. Does it remind you that you admitted you had

18 been deposed before?

19 A. I -- I don’t remember. But it’s down there,

20 yes, sir.

21 Q. Well, you’d been in other lawsuits before

22 this, hadn’t --

23 THE COURT: Counsel, I believe it’s time for

24 our break.

25 MR. MESEREAU: Oh.

26 (Recess taken.)

27 --o0o--

28 5210



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 5161 through 5210

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 7, 2005, and thereafter

20 reduced to typewriting by computer-aided

21 transcription under my direction.

22 DATED: Santa Maria, California,

23 April 7, 2005.

24

25

26

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

28 5211



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 THURSDAY, APRIL 7, 2005

20

21 8:30 A.M.

22

23 (PAGES 5157 THROUGH 5394)

24

25

26

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

28 BY: Official Court Reporter 5212



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 5213



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 CHACON, Ralph 5269-SN 5280-M

12 McMANUS, 5283-Z 5355-M

13 Adrian Marie

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 5214



1 E X H I B I T S

2 FOR IN

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

4 797 Photocopy of note 5342 5348

5 798 Photocopy of half of three

6 $100 bills 5342 5348

7 797 Photocopy of note 5352 5354

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 5215



1 THE COURT: Counsel?

2 MR. MESEREAU: Thank you, Your Honor.

3 Q. Mr. Chacon, you mentioned to the jury

4 someone named Kassim Abdool, right?

5 A. Yes, sir.

6 Q. And was Kassim Abdool someone you worked

7 with at Neverland?

8 A. Yes.

9 Q. And I believe you told the jury that he was

10 the first person you talked to about your claim that

11 Mr. Jackson was molesting young men, correct?

12 A. I believe so, yes, sir.

13 Q. Kassim Abdool joined you in that lawsuit

14 against Mr. Jackson, correct?

15 A. Yes, sir.

16 Q. Kassim Abdool also had a judgment against

17 him in favor of Mr. Jackson for $1,473,117.61,

18 correct?

19 A. I believe so, sir, yes.

20 Q. Kassim Abdool joined you in trying to get

21 millions from Mr. Jackson, right?

22 MR. SNEDDON: Object as argumentative, Your

23 Honor.

24 THE COURT: Overruled.

25 You may answer.

26 Q. BY MR. MESEREAU: Is that correct?

27 A. No, sir. No, sir.

28 Q. Oh, he didn’t? 5216



1 A. No, sir.

2 Q. He wasn’t a plaintiff with you in that case?

3 A. Oh, he was, yes, sir.

4 Q. You’re saying that Mr. Abdool was not

5 looking for millions like you?

6 A. No, sir.

7 Q. How much did he want, Mr. Chacon?

8 A. There wasn’t an amount, sir.

9 Q. After a six-month trial, your lawyer didn’t

10 ask the jury to award an amount for you, sir?

11 A. You’ll have to ask Mr. Ring.

12 Q. You were sitting there, weren’t you?

13 A. Yes, sir.

14 Q. Did you hear him give a closing argument to

15 the jury?

16 MR. SNEDDON: Your Honor, I’m going to

17 object; argumentative.

18 THE COURT: Sustained.

19 Q. BY MR. MESEREAU: Are you telling this jury

20 today, under oath, you don’t know how much your

21 lawyer asked for in that six-month trial?

22 A. I saw it earlier when you showed --

23 MR. SNEDDON: Excuse me. I’m going to

24 object as argumentative and immaterial.

25 THE COURT: Sustained.

26 Q. BY MR. MESEREAU: There was also someone

27 named Adrian McManus who joined you in suing Mr.

28 Jackson, correct? 5217



1 A. Yes, sir.

2 Q. And Adrian McManus had worked at Neverland,

3 right?

4 A. That’s correct, sir.

5 Q. And like you and Mr. Abdool, she lost the

6 case, correct?

7 A. Yes, sir.

8 Q. A Santa Maria jury ruled against her as

9 well, right?

10 A. That’s correct.

11 Q. Now, Adrian McManus was also found to have

12 stolen property from Mr. Jackson, true?

13 A. No, sir.

14 Q. Would it refresh your recollection if I show

15 you the judgment?

16 A. Yes, sir.

17 MR. SNEDDON: Your Honor, I’m going to

18 object as immaterial with regard to this witness’s

19 testimony; beyond his knowledge; no foundation.

20 THE COURT: Sustained.

21 Q. BY MR. MESEREAU: When did you last talk to

22 Adrian McManus?

23 A. Probably months; months ago.

24 Q. Did you talk about this case at all?

25 A. Only if I knew when I was coming down, and

26 how she was doing.

27 Q. Is that all you discussed about this case?

28 A. Yes, sir. 5218



1 Q. How long was the conversation?

2 A. Oh, couldn’t have lasted more than five

3 minutes, because she was at work.

4 Q. When did you last talk to Kassim Abdool?

5 A. I have not, sir, at all.

6 Q. Not at all?

7 A. No.

8 Q. Okay. When’s the last time you talked to

9 him?

10 A. Probably the time when we left court here.

11 Back then.

12 Q. Okay. All right. Now, when you sued Mr.

13 Jackson, you had judgments against you in other

14 cases, true?

15 MR. SNEDDON: Your Honor, I’m going to

16 object as immaterial.

17 THE COURT: Sustained.

18 Q. BY MR. MESEREAU: When you sued Mr. Jackson,

19 the wages you were getting from Mr. Jackson were

20 being partially garnished, correct?

21 MR. SNEDDON: Your Honor, I’m going to

22 object. Same objection.

23 MR. MESEREAU: Financial motive, Your Honor.

24 THE COURT: The objection is overruled.

25 You may answer.

26 Q. BY MR. MESEREAU: Correct?

27 A. Yes, sir.

28 Q. They were being garnished because you 5219



1 wouldn’t pay child support, true?

2 A. I was paying child support, sir.

3 Q. Then why were they garnished?

4 A. I assume that’s the procedure they do when

5 they want child support from you.

6 Q. You couldn’t just send a check yourself?

7 MR. SNEDDON: I’m going to object to that --

8 THE COURT: Sustained; calls for a legal

9 conclusion.

10 Q. BY MR. MESEREAU: At one point, you asked a

11 Santa Barbara sheriff for money, true?

12 A. I don’t recall, sir.

13 Q. Do you recall ever asking Mr. Birchim for

14 some money?

15 A. No, sir.

16 Q. Are you saying it never happened?

17 A. I don’t recall, sir.

18 Q. Okay. When did you last talk to Russ

19 Birchim?

20 A. This morning.

21 Q. Where did you talk to him?

22 A. Here at the courthouse.

23 Q. Did you talk about your testimony?

24 A. No, sir.

25 Q. Okay. So you’re not denying that you asked

26 him for money and you’re not denying he gave it to

27 you; you just don’t remember, right?

28 A. I don’t recall, sir. 5220



1 Q. When did you first meet Russ Birchim?

2 A. I believe it was back in ‘93, I believe.

3 I’m not sure.

4 Q. Ever hear of a company called Commercial

5 Trade?

6 A. No, sir.

7 Q. You didn’t have a lawsuit with Commercial

8 Trade in 1989?

9 MR. SNEDDON: Object as immaterial.

10 THE COURT: Sustained.

11 Q. BY MR. MESEREAU: Do you know someone named

12 Judge Byrd?

13 A. No, sir.

14 Q. Judge Byrd had a judgment against you for a

15 couple thousand dollars, didn’t she?

16 MR. SNEDDON: Your Honor, I’m going to

17 object to this and ask the Court to admonish

18 counsel.

19 THE COURT: The --

20 MR. MESEREAU: It’s all part of the

21 financial motive, Your Honor.

22 THE COURT: There’s no time frame. The

23 problem you’re asking about is when. I don’t know

24 that. So I’ll sustain the objection on vagueness.

25 Q. BY MR. MESEREAU: At the time you sued Mr.

26 Jackson for an amount you don’t remember, isn’t it

27 true you had a judgment against you for $2600 by a

28 Ms. Judge Byrd? 5221



1 A. I don’t recall, sir.

2 Q. Would it refresh your recollection if I show

3 you your deposition where you talked about it?

4 A. Yes, sir.

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

6 THE COURT: Yes.

7 THE WITNESS: Oh, yes, sir.

8 Q. BY MR. MESEREAU: Have you had a chance to

9 look at that deposition page?

10 A. Yes, sir.

11 Q. Did it refresh your recollection?

12 A. Yes, sir.

13 Q. Do you know who Judge Byrd is?

14 A. No, sir.

15 Q. Okay. Do you know anything about a judgment

16 she ever had against you?

17 A. No, sir.

18 Q. Okay. Now, when did you first tell Kassim

19 Abdool, your co-plaintiff against Mr. Jackson, about

20 this alleged molestation you witnessed?

21 A. Probably when -- when we -- when we knew

22 that we were going to be subpoenaed to the grand

23 jury.

24 Q. And approximately when was that?

25 A. I believe it was in ‘94 sometime.

26 Q. By the way, do you remember testifying that

27 Sheriff Russ Birchim delivered money to you?

28 A. I don’t recall, sir. 5222



1 Q. Would it refresh your recollection if I show

2 you your deposition?

3 A. Yes, sir.

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

5 THE COURT: Yes.

6 THE WITNESS: It’s down there, but I don’t

7 recall that, sir, at all.

8 Q. BY MR. MESEREAU: Okay. Do you recall

9 saying it?

10 A. No, sir, I don’t.

11 Q. Don’t recall anything about it?

12 A. No, sir.

13 Q. Okay. It just is down there, right?

14 MR. SNEDDON: I’m going to object to the

15 comment as argumentative.

16 THE COURT: Sustained.

17 Q. BY MR. MESEREAU: Do you remember testifying

18 under oath you asked Mr. Birchim for money?

19 A. I don’t recall, sir.

20 MR. SNEDDON: That’s been asked and

21 answered.

22 THE COURT: Sustained.

23 Q. BY MR. MESEREAU: Do you remember asking for

24 money so your wife could relocate?

25 A. Probably -- probably so, sir. Yes, sir.

26 Q. Okay. Do you remember wanting other bills

27 paid?

28 A. No, sir. 5223



1 Q. Okay. How long after you told Kassim

2 Abdool, your co-plaintiff, about these alleged acts

3 of molestation did you speak to anyone from law

4 enforcement?

5 A. I don’t recall, sir.

6 Q. Was it years?

7 A. Oh, no. No, not years.

8 Q. How long was it?

9 A. Could have been weeks, days. I’m not

10 certain, sir. It’s been a while.

11 Q. Did you review any documents to get ready to

12 testify today?

13 A. No, sir.

14 Q. Anyone send you any documents to look at --

15 A. No.

16 Q. -- before you testified today?

17 A. No, sir.

18 Q. When did you last talk to Mr. Ring about

19 your suit against Mr. Jackson?

20 A. I haven’t talked to Mr. Ring in years, sir.

21 Q. Okay. All right. Now, at the time you

22 filed your lawsuit against Mr. Jackson, you knew

23 that other former employees at Neverland had sold

24 stories to tabloids about Mr. Jackson, didn’t you?

25 A. Could you rephrase that, sir?

26 Q. Sure. At the time you filed your lawsuit

27 against Mr. Jackson, you were aware that other

28 former employees at Neverland had sold stories to 5224



1 tabloids, correct?

2 A. I don’t understand the “others,” sir. Which

3 others?

4 Q. Blanca Francia?

5 A. No, sir.

6 Q. Never heard of it?

7 A. Oh, yes, I heard of it. But I didn’t -- I

8 wasn’t aware of that.

9 Q. Were you aware of anyone else at Neverland

10 who was employed at one point trying to go to a

11 tabloid to sell a story?

12 A. No, sir.

13 Q. Never heard anything about it?

14 A. No, sir.

15 Q. Okay. Did you ever hear anything about

16 Adrian McManus doing that?

17 A. Well, we went to a tabloid.

18 Q. Which one?

19 A. It was The Star.

20 Q. And who was “we”?

21 A. It was myself, Adrian McManus, Kassim

22 Abdool, and I guess that was it.

23 Q. And approximately when did you go to this

24 tabloid?

25 A. We had met at Mr. Ring’s office in Santa

26 Barbara.

27 Q. And after you met with your attorney, who

28 represented you in the lawsuit, you went to a 5225



1 tabloid, correct?

2 A. Right. Yes, sir.

3 Q. And you wanted money for a story, true?

4 A. Yes, sir.

5 Q. Who did you meet with at the tabloid when

6 you requested money?

7 A. Can you rephrase that, sir?

8 Q. Yes, sir. Who did you meet with when you

9 went to a tabloid to request money?

10 A. Oh, there was myself, Kassim, Adrian, and

11 whoever the reporter was, and Mr. Ring.

12 Q. Your lawyer was there with you, right?

13 A. Yes, sir.

14 Q. You did it with your lawyer because you

15 thought that negative publicity would pressure Mr.

16 Jackson into paying all of you money, right?

17 A. No.

18 MR. SNEDDON: Object as argumentative, Your

19 Honor.

20 THE COURT: Overruled. The answer was, “No.”

21 Next question.

22 Q. BY MR. MESEREAU: You went to the tabloid

23 before the case was tried to a jury, right?

24 A. I believe so, yes, sir.

25 Q. Had you filed a case before you went to the

26 tabloid?

27 A. I don’t recall, but I believe so, sir.

28 Q. Did you sell a story to the tabloid? 5226



1 A. Yes, sir.

2 Q. Did you ever hire a broker to help you sell

3 other stories to other tabloids?

4 A. No, sir.

5 Q. Did you ever hear anything about McManus

6 doing that?

7 A. No, sir.

8 Q. Okay. What other tabloids did you speak to?

9 A. None, sir.

10 Q. Just one?

11 A. Yes, sir.

12 Q. Just Star?

13 A. Yes, sir.

14 Q. But you were aware that McManus went to

15 other tabloids, true?

16 A. No, sir.

17 Q. Just Star?

18 A. Yes, sir.

19 Q. Did you ever speak to anyone at Inside

20 Edition?

21 A. No, sir.

22 Q. Okay. How about any other newspaper?

23 A. No, sir.

24 Q. Now, you wanted to sell information about

25 Mr. Jackson allegedly acting wrongfully with young

26 men, correct?

27 A. Yes, sir. To The Star.

28 Q. And you also wanted to sell information 5227



1 about his relationship with Lisa Marie Presley,

2 correct?

3 A. No, sir.

4 Q. Never did that?

5 A. No, sir.

6 Q. Ever hear of any of your co-plaintiffs doing

7 that?

8 A. That I recall, I don’t recall, sir.

9 Q. Don’t recall it at all?

10 A. No, sir.

11 Q. Okay. Was your story printed, to your

12 knowledge?

13 A. Yes, sir.

14 Q. Approximately when did that happen?

15 A. I don’t know the date, sir.

16 Q. Any idea at all?

17 A. No, sir.

18 Q. Okay. Can’t even estimate, right?

19 A. No, sir.

20 Q. Okay. All right. How long after you told

21 your co-plaintiff against Mr. Jackson, Mr. Kassim

22 Abdool, about these alleged acts of molestation did

23 you both go to a tabloid?

24 A. Oh, I -- it wasn’t -- it wasn’t right away.

25 But I don’t recall when it was.

26 Q. Okay. It was before you went to law

27 enforcement, wasn’t it?

28 A. No, sir. 5228



1 Q. Was it after it?

2 A. I believe so, sir. I don’t recall.

3 Q. Okay. Mr. Chacon, in late ‘93 and early

4 ‘94, you told other people that Michael Jackson was

5 innocent of molestation accusations, didn’t you?

6 A. No, sir.

7 Q. Never told that to anyone at the ranch?

8 A. No, sir.

9 Q. Okay. Are you familiar with a tabloid

10 called Splash?

11 A. Yes, sir.

12 Q. What is Splash?

13 A. I believe it’s a tabloid.

14 Q. Ever met with someone named Peter Burt from

15 Splash?

16 A. I don’t recall, sir.

17 Q. Are you saying you don’t recall, or you

18 don’t -- you didn’t?

19 A. I don’t remember, sir, if I did or not.

20 Q. So you could have, but you don’t remember?

21 A. Could have, but I don’t remember.

22 Q. Okay. Do you know somebody named Sandy

23 Domz?

24 A. Yes, sir.

25 Q. Who was Sandy Domz?

26 A. She was one of the secretaries at Neverland

27 Ranch.

28 Q. Okay. Do you recall Sandy Domz ever 5229



1 approaching a tabloid?

2 A. No, sir.

3 Q. Don’t know anything about it?

4 A. No, sir.

5 Q. All right. Do you recall speaking to a book

6 author named Gutierrez?

7 A. Yes, sir.

8 Q. And approximately when did you speak to a

9 book author named Gutierrez?

10 A. I believe that was before we went to Star,

11 and -- but I don’t remember the -- I don’t remember

12 the date or the time.

13 Q. Okay. Do you remember splitting money from

14 any tabloids with any other employees or former

15 employees of Neverland?

16 A. No, sir.

17 Q. You never split money for giving information

18 to a T.V. show called Inside Edition?

19 A. That I recall, no, sir.

20 Q. So you’re not telling the jury you didn’t do

21 it, you’re just saying, “I don’t recall”?

22 A. Well, I don’t -- I don’t think I did it or

23 we did it, no, sir.

24 Q. You don’t know for sure?

25 A. I just don’t recall if we did or not, sir.

26 Q. You might have, but you don’t remember,

27 right?

28 A. I don’t remember. 5230



1 Q. Did you ever complain at Neverland that you

2 should be paid more money than you were getting?

3 A. No, sir.

4 Q. Do you remember filing a claim for

5 disability with EDD after you left Neverland?

6 A. No, sir.

7 Q. Okay. Are you saying that didn’t happen?

8 A. Well, I filed for unemployment.

9 Q. Not disability?

10 A. No, sir.

11 Q. All right. When is the last time you worked

12 at Neverland; do you know?

13 A. It’s probably mid ‘94, I believe, or around

14 there.

15 Q. Now, when you sued Mr. Jackson in Santa

16 Maria, you also sued other people at Neverland,

17 right?

18 A. No, sir.

19 Q. You sued James Van Norman, didn’t you?

20 A. Oh, yes, sir.

21 Q. You sued Tony Coleman?

22 A. Yes.

23 Q. You sued Marcus Johnson, correct?

24 A. Yes, sir.

25 Q. And you sued Bill Bray, right?

26 A. Yes, sir.

27 Q. And Betty Bailey, right?

28 A. Yes, sir. 5231



1 Q. And Andrew Merritt, right?

2 A. I believe so, yes, sir.

3 Q. And you were claiming that they had

4 wrongfully interfered with your employment, correct?

5 A. Yes, sir, they did.

6 Q. And are these some of the people that you

7 described as being bodyguards for Mr. Jackson?

8 A. Yes, sir, the OSS.

9 Q. Yes.

10 A. Yes.

11 Q. You didn’t like the OSS being at Neverland,

12 did you?

13 A. No, sir.

14 Q. You wanted to handle all of the security

15 yourself, correct?

16 A. Well, there was a time that I was in charge,

17 and I knew what I was doing, sir.

18 Q. And you felt they didn’t, right?

19 A. Well, they shouldn’t have interfered with my

20 job.

21 Q. Okay. And obviously you lost that claim in

22 front of a Santa Maria jury, correct?

23 A. Yes.

24 MR. SNEDDON: Object as argumentative, Your

25 Honor.

26 THE COURT: Sustained.

27 Q. BY MR. MESEREAU: The claims against the

28 people in addition to Mr. Jackson who had worked at 5232



1 Neverland, you lost those claims, right?

2 A. Yes, sir.

3 Q. Now, at the time you sued Mr. Jackson, you

4 had complained that you couldn’t pay your rent,

5 right?

6 A. No, sir.

7 Q. Did you ever complain to anyone you couldn’t

8 pay your rent?

9 A. No, sir.

10 Q. Never complained to any sheriff, right?

11 A. I don’t recall. I don’t think so, sir.

12 Q. Okay. But you don’t know for sure?

13 A. No, sir.

14 Q. All right. All right. Now, when Mr.

15 Jackson sued you for stealing his property, do you

16 recall what property he was accusing you of stealing

17 from him?

18 A. Yes, sir.

19 Q. What was the property?

20 A. It was candy bars from the theater. And the

21 other stuff I’m not sure of, but I believe they were

22 referring to my briefcase that had memos, my

23 personal memos from my box at the security office.

24 Q. Anything else?

25 A. No, sir.

26 Q. Now, the jury found that the material you

27 stole was worth $25,000, correct?

28 A. No, sir. 5233



1 Q. Well, they entered a judgment against you

2 for $25,000 for maliciously converting Mr. Jackson’s

3 property, true?

4 MR. SNEDDON: Your Honor, I’m going to

5 object to this.

6 THE COURT: Sustained.

7 Q. BY MR. MESEREAU: Do you know what the

8 amount was, Mr. Chacon?

9 MR. SNEDDON: I’m going to object. It’s the

10 same question, just asked a different way.

11 THE COURT: Sustained.

12 Q. BY MR. MESEREAU: You were found to have

13 stolen documents from Mr. Jackson, true?

14 MR. SNEDDON: Your Honor, I’m going to

15 object; asked and answered.

16 MR. MESEREAU: I don’t think it is.

17 THE COURT: That question hasn’t been asked,

18 but the ruling that I made is that the issues that

19 you can go into are not the issues of the lawsuit.

20 It’s the same as the J.C. Penney case. You can go

21 into what he said, what he hasn’t said, the same

22 exact ruling, and you’re --

23 MR. MESEREAU: Okay.

24 THE COURT: The area you’re in now has to do

25 with the issues in the lawsuit. So I want you --

26 that’s the line we’re trying to walk here.

27 MR. MESEREAU: Okay. I’ll move on, Your

28 Honor. 5234



1 Q. Do you know someone named Linda Allen, Mr.

2 Chacon?

3 A. Yes, sir.

4 Q. Who is Linda Allen?

5 A. She was my landlady in Lompoc.

6 Q. For how long?

7 A. Probably about a year. I’m not for certain

8 of the length of time.

9 Q. When you were suing Mr. Jackson, you told

10 Linda Allen you would soon be able to pay her the

11 back rent you owed, right?

12 A. No, sir.

13 MR. SNEDDON: I’m going to object to that

14 question. The same 403 ruling.

15 THE COURT: Overruled.

16 Q. BY MR. MESEREAU: Did you do that, Mr.

17 Chacon?

18 A. No, sir.

19 Q. Did you ever tell Linda Allen, “I’m going to

20 be a star witness against Michael Jackson”?

21 A. No, sir.

22 Q. Okay. Ever tell Linda Allen you were going

23 to be on the T.V. show Hard Copy to talk about Mr.

24 Jackson?

25 A. No, sir.

26 Q. Did you ever tell Linda Allen you had a gun

27 permit because you were a star witness against

28 Michael Jackson? 5235



1 A. No, sir.

2 Q. Ever tell Ms. Allen you were going to make

3 two or three million dollars with your suit against

4 Mr. Jackson?

5 A. No, sir.

6 Q. Ever will tell Linda Allen you were going to

7 be driving a 450 Mercedes after you won your suit

8 against Mr. Jackson?

9 A. No, sir.

10 Q. All right. None of that rings a bell,

11 right?

12 A. No. No.

13 Q. Okay. Now, in your meeting with the first

14 tabloid that you talked to, okay, where Abdool was

15 present, who else was there?

16 A. I believe Adrian McManus, Abdool, myself,

17 Mr. Ring, and whoever represented that tabloid. I

18 don’t know, sir.

19 Q. Who arranged the meeting?

20 A. Mr. Ring.

21 Q. Okay. Do you know someone named Gary

22 Morgan?

23 A. I’ve heard the name before, yes, sir.

24 Q. Where have you heard the name?

25 A. Probably -- maybe he’s the one that

26 represented the tabloid. I’m not sure.

27 Q. Okay. Did you ever talk to Gary Morgan?

28 A. I probably did, but I don’t recall. 5236



1 Q. Okay. Do you recall ever being interviewed

2 by someone who claimed to be a media broker, meaning

3 they could actually get you to various tabloids on

4 T.V. or in print?

5 A. No, sir.

6 Q. Never heard of anything about that, right?

7 A. No, sir.

8 Q. Did you draft a story for the tabloids at

9 Mr. Ring’s office?

10 A. Probably, yes, sir. Probably did. I

11 don’t -- I don’t recall, but I probably did.

12 Q. Why do you say you probably did?

13 A. Because it’s kind of vague. It’s been a

14 long time, and I guess I did. I’m -- I would say I

15 did, yes, sir.

16 Q. Well, it hasn’t been much longer than the

17 period of time you claim you remember these events

18 about Mr. Jackson, true?

19 A. Well, I probably did, sir, draft that --

20 Q. Probably did, or you did?

21 A. I did.

22 MR. SNEDDON: It’s argumentative.

23 THE COURT: Overruled. The answer was he

24 did. Next question.

25 Q. BY MR. MESEREAU: Okay. And did you draft a

26 story for Splash?

27 A. I believe that was the tabloid, sir.

28 Q. Okay. And after you drafted it, did you 5237



1 meet with somebody from Splash?

2 A. Whoever it was. I don’t recall, sir.

3 Q. Were you personally interviewed by somebody

4 from Splash?

5 A. We all were, sir.

6 Q. Jointly or individually?

7 A. Jointly.

8 Q. Okay. How long was the interview with

9 Splash?

10 A. Could have been an hour or so. I’m not for

11 certain how long.

12 Q. Do you recall telling anyone that you were

13 using the money from Splash to help fund your

14 lawsuit against Michael Jackson?

15 A. Yes, the money went directly to Mr. Ring.

16 Q. And that was approximately $17,000, wasn’t

17 it?

18 A. I don’t know, sir. But whatever it was, he

19 did get it.

20 Q. So can you estimate what it was?

21 A. I can’t, sir.

22 Q. Okay. Did you get any money yourself as --

23 A. No, sir.

24 Q. Do you remember telling people you gave most

25 of it to Mr. Ring, but you took about 500 bucks

26 yourself?

27 A. Well, we had taken 500 bucks, but we gave it

28 back to Mr. Ring, because he was our lawyer and he 5238



1 needed money.

2 Q. Okay. That was to fund the lawsuit where

3 you sought millions from Michael Jackson, correct?

4 A. Well, that was the lawsuit, sir.

5 Q. That was the lawsuit you were trying to fund

6 by selling stories to tabloids, true?

7 A. No, sir.

8 Q. No?

9 A. I really don’t understand your question.

10 Q. Sure, I’ll rephrase.

11 You were taking money from tabloids and

12 using it to fund costs of your lawsuit against Mr.

13 Jackson?

14 A. Oh. Yes, sir. I’m sorry.

15 Q. And before you went to Mr. Ring, you had

16 told various people that you never saw anything

17 inappropriate at Neverland, true?

18 A. No, sir.

19 Q. You told various people you’d never seen

20 Michael Jackson molest anybody, true?

21 A. No, sir.

22 Q. So if anybody comes into court and says

23 that, they’re just not telling the truth, right?

24 A. That’s correct, sir.

25 Q. Okay. When you first met with

26 representatives of the sheriff’s department, did you

27 tell them everything that you have said today about

28 Mr. Jackson allegedly molesting young men? 5239



1 A. Um, when you mean a sheriff, a certain

2 sheriff, or at the sheriff’s department, or -- I

3 don’t understand.

4 Q. Let me rephrase.

5 When you first spoke to a sheriff from Santa

6 Barbara, did you tell that sheriff everything you’ve

7 said today in court?

8 A. No, sir.

9 Q. The story has changed considerably since

10 your first meeting with a sheriff, true?

11 MR. SNEDDON: Your Honor, I’m going to

12 object to the use of the word “considerably” as

13 argumentative.

14 THE COURT: Sustained.

15 Q. BY MR. MESEREAU: Would you agree that with

16 each interview you do, you add more lurid facts

17 about Mr. Jackson?

18 A. No, sir.

19 Q. You would agree your story about what you

20 claim he did has changed through the years, has it

21 not?

22 A. No, sir.

23 Q. Didn’t you just meet with Mr. Sneddon the

24 other day?

25 A. Yes, sir.

26 Q. Didn’t you tell Mr. Sneddon you had new

27 facts that you forgot in 1993?

28 MR. SNEDDON: Well, wait a minute. I’m 5240



1 going to object to that question. Your Honor,

2 that’s not asked in good faith with regard to the --

3 I can’t do it without a speaking objection, but if

4 we could approach the bench, because this is not

5 right.

6 THE COURT: Overruled.

7 The question was, “Did you tell Mr. Sneddon

8 you had new facts that you had forgot in 1993?”

9 THE WITNESS: Yes, I did.

10 Q. BY MR. MESEREAU: You told Mr. Sneddon that

11 you forgot to say certain things in 1993 about Mr.

12 Jackson allegedly molesting young men, true?

13 A. Yes, sir.

14 Q. But now you remembered them in 2005, right?

15 A. Vaguely, yes, sir.

16 Q. And you said the person that remembered them

17 with you is Kassim Abdool, true?

18 A. I haven’t talked to Kassim in years.

19 Q. Okay. When did you first start work at

20 Neverland, Mr. Chacon?

21 A. I believe it was in ‘91, sir.

22 Q. Okay. You knew that in late ‘93 and early

23 ‘94, the media was devoting a lot of attention to

24 stories about Mr. Jackson at Neverland, correct?

25 A. Well, the media was always at Neverland at

26 some time or other, sir.

27 Q. Before you chose to go to a tabloid, you

28 knew that others were going to tabloids to try and 5241



1 tell stories about Mr. Jackson?

2 A. No, sir.

3 Q. You were the first, right?

4 A. That went to the media, to the tabloids?

5 Q. Yes.

6 A. Yes, sir.

7 Q. And when did you go?

8 A. It was probably ‘94 sometime.

9 Q. But you knew there was a lot of media

10 attention before that, correct?

11 A. There always has been, sir.

12 Q. And you knew people were making money doing

13 that, right?

14 A. No, sir.

15 Q. Weren’t aware of that?

16 A. No, sir.

17 Q. Thought they were doing it all for free,

18 right, Mr. Chacon?

19 A. No, sir.

20 MR. SNEDDON: Object as argumentative, Your

21 Honor.

22 THE COURT: Sustained.

23 Q. BY MR. MESEREAU: Do you think Mr. Jackson

24 is an intimidating-looking individual?

25 A. No, sir.

26 Q. Do you remember in your deposition you said

27 you were entitled to damages because Mr. Jackson

28 stared at you? 5242



1 A. No, sir.

2 Q. Remember you said Mr. Jackson stared, and

3 you didn’t know how to take it?

4 A. No, sir.

5 Q. Would it refresh your recollection if I show

6 you your deposition?

7 A. Yes, sir.

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

9 THE COURT: Yes.

10 THE WITNESS: Okay. Okay. I remember.

11 Q. BY MR. MESEREAU: As part of your damage

12 claim, do you remember saying that Mr. Jackson

13 stared at you continuously?

14 A. Not continuously, sir.

15 Q. Well, you said “all the time,” right?

16 A. No, sir.

17 Q. You said no one else saw him staring at you,

18 right?

19 A. No, sir.

20 Q. But it bothered you, right?

21 A. No, sir.

22 Q. Okay. Why did you say it?

23 A. I guess just to say it.

24 Q. Okay. As part of your damage claim, you

25 claimed that employees were threatening you at

26 Neverland, right?

27 A. Yes, they were, sir.

28 Q. All right. And the jury didn’t believe 5243



1 that, did they?

2 MR. SNEDDON: I’ll object as argumentative.

3 THE COURT: Sustained.

4 Q. BY MR. MESEREAU: When did you start working

5 the graveyard shift at Neverland?

6 A. Immediately, sir, when I got hired on.

7 Q. Didn’t you gradually work your way into

8 that?

9 A. Immediately I went to the graveyard. Then

10 they shifted me to swings for a while, probably a

11 month or so, and then I ended back on graveyard. As

12 a matter of fact, I preferred to work graveyard,

13 sir, because I had a second job.

14 Q. Where was the second job?

15 A. In Lompoc.

16 Q. What was that?

17 A. I worked for Wayne’s Tires.

18 Q. Do you remember problems with intruders

19 while you worked at Neverland?

20 A. Yes, sir.

21 Q. And what problems with intruders do you

22 remember?

23 A. Them coming on property and -- and we turned

24 them over to the sheriff’s department.

25 Q. And how often do you remember that

26 happening?

27 A. Probably several times, sir.

28 Q. Do you recall Mr. Jackson getting nervous 5244



1 about that?

2 A. No, sir.

3 Q. Did he seem to care about it, to you?

4 A. He wasn’t even there when we apprehended the

5 people.

6 Q. He certainly learned about it, to your

7 knowledge, correct?

8 A. I don’t know, sir.

9 Q. You never talked to him about it?

10 A. No, sir.

11 Q. And you were not aware of anyone else

12 telling Mr. Jackson about these problems with

13 intruders?

14 A. No, sir.

15 Q. All right. Sir, Mr. Jackson had some

16 personal security guards because he was worried

17 about these intruders being caught on the property,

18 right?

19 A. I don’t believe so, sir.

20 Q. You and the other security people didn’t

21 carry any weapons, right?

22 A. No, sir, we didn’t.

23 Q. And at times, that was a concern of Mr.

24 Jackson’s, wasn’t it, that his security personnel

25 there didn’t have any weapon to protect him?

26 A. I don’t know, sir.

27 Q. He had a general policy of not wanting

28 people to carry weapons, true? 5245



1 A. I don’t know, sir.

2 Q. You don’t know at all?

3 A. No, sir.

4 Q. Did you ever see any of your security team

5 carrying a weapon?

6 A. No, sir.

7 Q. Did you know why?

8 A. No, sir.

9 Q. Had no idea at all?

10 A. No, sir.

11 Q. Never inquired?

12 A. No, sir.

13 Q. When you first joined up, did you ask

14 anybody, “Do security people carry weapons at

15 Neverland?”

16 A. No, sir.

17 Q. Were you given any manual to refer to when

18 you worked at Neverland?

19 A. Yes, sir.

20 Q. And what do you know about that manual?

21 MR. SNEDDON: I’m going to object; vague.

22 THE COURT: Sustained.

23 MR. MESEREAU: It’s vague, I’ll rephrase.

24 Q. Are you telling the jury that when you

25 started working security at Neverland, nobody told

26 you, “We have a general policy of having security

27 people not carry arms”?

28 A. Well, probably so, because nobody was 5246



1 carrying arms.

2 Q. Did you have a gun permit at the time?

3 A. No, sir.

4 Q. How many meetings did you have with

5 representatives of the sheriff’s department before

6 you think you told all the facts about what you say

7 Mr. Jackson did with young men?

8 MR. SNEDDON: Your Honor, I’m going to

9 object as argumentative; assumes facts.

10 THE COURT: Calls for a narrative. You can

11 break that question down.

12 MR. MESEREAU: Sure.

13 Q. When was your first meeting with any

14 representative of the sheriff’s department regarding

15 what you claim you saw at Neverland?

16 A. I don’t recall, sir.

17 Q. Do you know approximately when it was?

18 A. No, sir, I don’t.

19 Q. Was it after you saw the events you

20 described today?

21 A. I don’t recall, sir.

22 Q. Well, you’ve given the jury a detailed

23 description of the events you claim you saw at

24 Neverland, right?

25 A. Yes, sir.

26 Q. But you’ve forgotten when you talked to the

27 sheriffs, correct?

28 A. Well, I know I talked to them, but I just 5247



1 don’t recall exactly when it was at, sir.

2 Q. Do you know approximately when it was at?

3 A. It was in ‘94, I believe, sometime.

4 Q. Do you know how many meetings you’ve had

5 with the sheriffs to date where you have talked

6 about Mr. Jackson’s inappropriate behavior?

7 A. Well, with the sheriffs, I didn’t talk about

8 this, the allegations. But with the grand jury,

9 which I went to testify, that was the first time,

10 and there was sheriffs present there.

11 Q. You testified before a Santa Barbara Grand

12 Jury, right?

13 A. Yes, sir.

14 Q. And after you testified, no criminal charges

15 were brought, right?

16 A. Right, sir.

17 Q. You went to Los Angeles and talked to

18 prosecutors --

19 A. No, sir.

20 Q. -- about what you claim -- you never did

21 that?

22 A. No, sir.

23 Q. Didn’t you tell Mr. Sneddon on direct

24 examination that you were subpoenaed to a grand jury

25 in Los Angeles?

26 A. Oh, yes, sir. But I didn’t go.

27 Q. You didn’t go. But you went down to be

28 interviewed under oath instead of going, true? 5248



1 A. Yes, sir.

2 Q. And as a result of your interview under

3 oath, no charges were ever brought in Los Angeles,

4 right?

5 A. No, sir.

6 Q. Do you remember testifying how upset you

7 were at Neverland when you learned that other

8 employees got raises and you didn’t?

9 A. Yes, I believe there was one time.

10 Q. And tell the jury what that was all about.

11 A. Probably they had hired two or three

12 security, and they -- I believe they paid them $12

13 an hour, and we were only getting $9 an hour.

14 Q. And did you complain about it to somebody?

15 A. Oh, yes, I did.

16 Q. Who?

17 A. Probably the lieutenant.

18 Q. And what happened?

19 A. Nothing ever happened.

20 Q. Was Mr. Abdool upset about that also, to

21 your knowledge?

22 A. I believe so, yes, sir.

23 Q. And you and he met and talked about it,

24 right?

25 A. Pardon me?

26 Q. You and he met and talked about it, correct?

27 A. Well, we all talked about that in security.

28 Q. You lodged a complaint, didn’t you? 5249



1 A. No, sir.

2 Q. Did you think Mr. Jackson’s security guards

3 were being paid more than you?

4 A. The new ones, yes, sir.

5 Q. How did you know what they were getting

6 paid?

7 A. I don’t remember. I don’t recall, sir, how

8 we found out.

9 Q. When you told the jury you saw a young boy

10 on Mr. Jackson’s back, was that in the shower?

11 A. No, it was coming out, going towards his

12 house.

13 Q. Was he on his shoulders?

14 A. You know, I don’t recall if he was on his

15 shoulders or on his back, like piggybacked, yes,

16 sir.

17 Q. When you went to work at Neverland, you were

18 asked to sign a confidentiality agreement, right?

19 A. Yes, sir.

20 Q. And everybody who works at Neverland is

21 asked to sign one, right?

22 A. Yes, sir.

23 Q. And the purpose, as explained to you, was

24 that Mr. Jackson doesn’t want employees just running

25 to tabloids and telling stories, right?

26 A. Yes, sir, I believe so.

27 Q. When you went to a tabloid, you violated the

28 agreement, correct? 5250



1 MR. SNEDDON: Object, Your Honor, calls for

2 a legal conclusion.

3 THE COURT: Overruled.

4 You may answer.

5 THE WITNESS: No, sir.

6 Q. BY MR. MESEREAU: You didn’t violate it all?

7 A. No, sir.

8 Q. So you thought going to a tabloid after you

9 left your employment at Neverland was perfectly

10 consistent with your confidentiality obligations to

11 Mr. Jackson, right?

12 A. I don’t think I ever signed a

13 confidentiality, sir.

14 Q. Sure about that?

15 A. I’m not for certain, but I don’t recall that

16 I ever did.

17 Q. Weren’t you asked to?

18 A. I probably was. But at that time they

19 didn’t have one for me.

20 Q. At the time you and Mr. Abdool and Ms.

21 McManus and your lawyer went to the tabloid, your

22 lawyer was trying to negotiate to get money from Mr.

23 Jackson, wasn’t he?

24 MR. SNEDDON: I’m going to object. Lack of

25 foundation and it assumes --

26 THE COURT: Foundation; sustained.

27 Q. BY MR. MESEREAU: At the time you and Mr.

28 Abdool and Ms. McManus and your lawyer went to a 5251



1 tabloid to give a story about Mr. Jackson, do you

2 know whether or not your lawyer was trying to

3 negotiate money from Mr. Jackson?

4 A. No, sir.

5 Q. Do you know whether or not your lawyer was

6 trying to pressure Mr. Jackson by threatening bad

7 publicity?

8 A. No, sir.

9 Q. Did you ever hear of anything like that

10 going on?

11 A. No, sir.

12 Q. Okay. So if that went on, you’d be shocked,

13 true?

14 A. Probably not, sir.

15 Q. Probably not?

16 A. I guess not, no.

17 Q. Did you ever explain to Mr. Jackson yourself

18 that you were having trouble making ends meet

19 financially?

20 A. No, sir.

21 Q. Did you explain to anyone at Neverland about

22 that before you left?

23 A. No, sir.

24 Q. All right. Without getting into any of your

25 discussions with your lawyer, who of your group

26 first went to that attorney?

27 A. Which attorney, sir?

28 Q. Ring. Mr. Ring. 5252



1 A. Who first went to Mr. Ring?

2 Q. Yes.

3 A. Of us?

4 Q. Of you. Excuse me, let me rephrase the

5 question. Make it clearer.

6 You, Mr. Abdool, Ms. McManus sued Mr.

7 Jackson, correct?

8 A. Yes, sir.

9 Q. You were represented by a lawyer in Santa

10 Barbara named Mr. Ring, correct?

11 A. Yes, sir.

12 Q. And he represented you throughout that

13 six-month trial that you lost, correct?

14 A. Yes, sir.

15 Q. Who first approached Mr. Ring about trying

16 to get money from Mr. Jackson?

17 A. We all did, sir.

18 Q. Together?

19 A. We hired him, yes, sir.

20 Q. Okay. Do you know how you found out about

21 him?

22 A. I don’t recall, sir.

23 Q. Was he the only lawyer you talked to, or did

24 you talk to some others?

25 A. I believe he was the only one we talked to,

26 yes, sir.

27 Q. Do you recall whether you ever told anyone,

28 “Mr. Jackson promised me if I did a good job, I 5253



1 would have a job at Neverland forever”?

2 A. No, sir.

3 Q. Did he ever say anything like that to you?

4 A. No, sir.

5 Q. Did anyone who hired you at Neverland?

6 A. No, sir.

7 Q. Okay. You met with Prosecutor Sneddon on

8 April 6th, correct?

9 A. Yes, sir.

10 Q. Was anyone else at the meeting?

11 A. Yes, sir.

12 Q. Who?

13 A. Russ Birchim.

14 Q. Where did the meeting take place?

15 A. Here in Santa Maria.

16 Q. And who arranged the meeting?

17 A. I believe it was Mr. Sneddon.

18 Q. Did he call you on the phone?

19 A. Yes, sir.

20 Q. Did he tell you where to meet?

21 A. Yes, sir.

22 Q. How long was the meeting?

23 A. Probably less than an hour.

24 Q. Did you discuss anything you were going to

25 say today?

26 A. I believe so, yes, sir.

27 Q. Did Mr. Sneddon tell you what questions he

28 was going to ask you today? 5254



1 A. Yes, sir.

2 Q. Did you tell him what answers you were going

3 to give to those questions?

4 A. No, sir.

5 Q. Did you tell him anything about how you were

6 going to respond?

7 A. I just told him that I would speak the

8 truth.

9 Q. That’s it?

10 A. Yes, sir.

11 Q. How long was the meeting?

12 A. Probably about -- less than an hour.

13 Q. So during the portion of that hour that you

14 spoke, all you ever said was, “I’ll tell the truth,

15 I’ll tell the truth, I’ll tell the truth,” or words

16 to that effect?

17 A. No, sir. No, sir.

18 Q. Okay. He told you what questions he was

19 going to ask you, correct?

20 A. I believe so, yes, sir.

21 Q. You told him what your responses were going

22 to be, right?

23 A. Yes, sir.

24 Q. When was the -- excuse me.

25 Before that meeting, when was the last time

26 you had met with anyone from the prosecuting office

27 here?

28 A. I didn’t meet with anybody. 5255



1 Q. Did you talk with anyone on the phone?

2 A. Yes, sir. I was --

3 Q. Who was that?

4 A. I believe it was a secretary from Mr.

5 Sneddon’s office.

6 Q. And what was that discussion about?

7 A. When I was supposed to be down here and how

8 to get -- how to get to Santa Maria.

9 Q. How many meetings have you had with any

10 representative of the sheriff’s department in total

11 to talk about your testimony?

12 MR. SNEDDON: Your Honor, I’m going to

13 object as vague as to time, a time period.

14 MR. MESEREAU: I’ll rephrase it.

15 THE COURT: All right.

16 Q. BY MR. MESEREAU: In the last year, how many

17 meetings have you had with anyone representing the

18 Santa Barbara Sheriff’s Department to talk about

19 this case?

20 A. I haven’t, sir.

21 Q. How about phone calls?

22 A. No, sir.

23 Q. All right. You’re aware of Mr. Jackson

24 going on tour -- excuse me. Let me rephrase it.

25 You’re aware that Mr. Jackson periodically

26 went on tour while you worked at Neverland, true?

27 A. Yes, sir.

28 Q. And it was your understanding he always had 5256



1 bodyguards with him, correct, on tour?

2 A. I understood that, yes, sir.

3 Q. Okay. You knew he was extremely concerned

4 about his security, right?

5 A. His bodyguard security or security on the

6 ranch?

7 Q. Well, Mr. Jackson was extremely concerned

8 about security on the ranch, wasn’t he?

9 A. I don’t know, sir.

10 Q. You don’t know?

11 A. No, sir.

12 Q. Even with these intruders, you’re not sure

13 if he was concerned?

14 A. Well, I’m sure he was concerned, but he was

15 never there when we did apprehend them.

16 Q. Okay. You knew he had concerns about his

17 personal security when he went on tour, right?

18 A. Oh, yes, sir. Yes, sir.

19 Q. And at all times that you worked on the

20 ranch, you knew he had personal bodyguards when he

21 went on tour, right?

22 A. When he went on tour, yes, sir.

23 Q. You knew he had personal protection when he

24 went other places for other reasons, true?

25 A. I assume so, sir. I don’t know.

26 Q. Do you remember complaining that Mr. Abdool

27 got a raise when you didn’t?

28 A. No, sir. 5257



1 Q. Never happened?

2 A. No.

3 Q. When you left Neverland, you just stopped

4 showing up for work, right?

5 A. Yes, sir.

6 Q. You stopped showing up for work after you

7 met with Attorney Ring, correct?

8 A. Probably so, yes, sir.

9 Q. You were disappointed that you weren’t

10 getting more money from tabloids, weren’t you?

11 A. No, sir.

12 Q. Never complained to anybody about that?

13 A. No, sir.

14 Q. The first incident you claim you saw Mr.

15 Jackson improperly touch a young man was when?

16 A. I don’t recall. Between ‘92 and ‘93, I

17 believe. I’m not for certain.

18 Q. Do you recall ever telling any

19 representative of law enforcement the month or the

20 year?

21 A. No, sir. I don’t -- no.

22 Q. And what shower are you claiming Mr. Jackson

23 used when you say you looked in a shower and saw him

24 acting inappropriately?

25 A. It was the outside rest rooms by the rec

26 room.

27 Q. There were two of them, right?

28 A. Two rest rooms? 5258



1 Q. Yes.

2 A. There was a women’s and a men’s room, I’m

3 sorry.

4 Q. And which one do you claim you saw Mr.

5 Jackson in?

6 A. In the men’s room, sir.

7 Q. Had you seen him in that men’s room before?

8 A. Yes, sir.

9 Q. Okay. By the way, when you went to the

10 Santa Barbara Grand Jury, you didn’t tell them

11 everything you said today, did you?

12 A. Yes, sir.

13 Q. Everything?

14 A. Yes, sir.

15 Q. Did you tell them everything you’ve told Mr.

16 Sneddon?

17 A. Well, that one incident that I recalled I

18 didn’t. I didn’t bring that up, no, sir.

19 Q. How long were you in front of a Santa

20 Barbara Grand Jury?

21 A. Could have been a couple hours.

22 Q. And at some point, you called to see if

23 anybody had charged Mr. Jackson with anything,

24 didn’t you?

25 A. No, sir.

26 Q. Never asked anyone?

27 A. No, sir.

28 Q. Never asked anyone in the sheriff’s 5259



1 department?

2 A. No, sir.

3 Q. Never asked Mr. Sneddon?

4 A. No, sir.

5 Q. To this day you’ve never asked that

6 question, right?

7 A. No, sir.

8 Q. All right. When did you first learn Blanca

9 Francia had sold a story to Hard Copy?

10 MR. SNEDDON: Your Honor, I’m going to

11 object. That question has been asked and answered

12 and that assumes facts not in evidence.

13 MR. MESEREAU: I’ll rephrase it.

14 THE COURT: All right.

15 Q. BY MR. MESEREAU: Did you ever learn that

16 Blanca Francia had told a story for $20,000 to the

17 T.V. show Hard Copy?

18 A. No.

19 MR. SNEDDON: Object. Asked and answered.

20 THE COURT: All right. He answered it. It’s

21 “No.” Next question.

22 Q. BY MR. MESEREAU: Did you ever learn she had

23 sold a story to Hard Copy, without knowing the

24 amount she got?

25 A. Yes, sir.

26 Q. When did you learn that?

27 A. Probably on the news.

28 Q. On the news when? 5260



1 A. I don’t recall, sir. It was -- it was

2 public knowledge.

3 Q. Did you see the show?

4 A. No, sir.

5 Q. Did you hear about it right after it

6 appeared on television?

7 A. No, sir.

8 Q. Were you employed when that was on

9 television?

10 A. No, sir.

11 Q. Where were you working at that point?

12 A. Where was I working? That’s a good

13 question. I believe I was already in Nevada by that

14 time.

15 Q. And what were you doing there?

16 A. I was a substitute teacher at a high school

17 and junior high.

18 Q. What year was this?

19 A. ‘96, ‘7, ‘8.

20 Q. Do you remember learning that security

21 guards at the Jackson home in Encino had sold

22 stories for $100,000?

23 A. No, sir, I didn’t know anything about that

24 place.

25 Q. Never heard anything about that?

26 A. Well, I know they had security guards, but I

27 never heard anything.

28 Q. Did you hear anything about security guards 5261



1 at the Encino home selling a story for $100,000?

2 A. No, sir.

3 Q. All right. Ever know someone named Quindoy?

4 A. I want to say that the Quindoys -- I believe

5 they were chefs, I believe, but I’m not positive.

6 Q. They were what?

7 A. I believe they were cooks or chefs there at

8 some property.

9 Q. Did you know them?

10 A. No, sir.

11 Q. Ever talk to them?

12 A. No, sir.

13 Q. Did you know they had tried to sell stories

14 to tabloids about Mr. Jackson?

15 A. No, sir.

16 Q. Had you ever heard anything about that as

17 you sit here today?

18 A. Probably have, but I don’t recall.

19 Q. Okay. Now, at some point you claimed you

20 were improperly subjected to electronic surveillance

21 at Neverland, right?

22 A. Could you be a little bit more specific,

23 sir?

24 Q. Sure.

25 MR. SNEDDON: Your Honor, I’m going to

26 object. I’m going to object because of the 403

27 ruling, but more specifically because there are

28 multiple defendants in the causes of action. It may 5262



1 be different as to different individuals.

2 MR. MESEREAU: I’m only talking about him,

3 Your Honor. His claims against Mr. Jackson.

4 THE COURT: I’m going to allow the question,

5 but I’m going to do so assuming it’s not related to

6 specific allegations in the Complaint, which I

7 already said you can’t directly go into.

8 MR. MESEREAU: Okay. Well, there were

9 such -- there were such claims, Your Honor.

10 THE COURT: I know, but we’re not

11 relitigating that issue. But he could have made a

12 claim or his attorney could have made a claim.

13 You’re asking him not about claims his attorney

14 made, but claims that he made.

15 MR. MESEREAU: Yes, I am.

16 THE COURT: I’m going to allow the question

17 with that understanding.

18 MR. MESEREAU: Thank you, Your Honor.

19 THE COURT: But you probably have to read it

20 back to him.

21 Do you remember the question?

22 MR. MESEREAU: I can rephrase it.

23 THE WITNESS: No.

24 MR. MESEREAU: I’ll withdraw it.

25 Q. Do you remember claiming that you were

26 emotionally distressed because you thought your

27 telephone conversations were listened in to at

28 Neverland? 5263



1 A. Yes, sir.

2 Q. And you never knew whether or not there was

3 a tap on any phone, correct?

4 A. Yes, I did, sir.

5 Q. Are you saying you did know there was a tap?

6 A. Yes, sir, I knew that they had equipment

7 where they were listening in.

8 Q. Do you remember testifying under oath you

9 didn’t know if your phone was tapped?

10 A. At home or at the ranch, sir?

11 Q. Either place.

12 A. Yes, sir.

13 Q. Did you ever state under oath you didn’t

14 know whether your phone was tapped?

15 MR. SNEDDON: Your Honor, I object to the

16 question as vague as to place.

17 THE COURT: Sustained.

18 Q. BY MR. MESEREAU: You claim you had been

19 emotionally damaged because someone listened in to

20 your calls at Neverland, right?

21 A. Emotionally damaged. Well, I probably --

22 probably didn’t say that, but I was upset because

23 they were listening to my personal phone calls, sir.

24 Q. Okay. And your basis for saying that was

25 that somebody had told you that was going on, right?

26 A. No, sir, I knew it was going on.

27 Q. You had no knowledge of electronic

28 surveillance at the time, did you? 5264



1 A. Yes, sir, I did.

2 Q. Did you have a check done on the phones?

3 A. No, sir.

4 Q. When is the last time you talked to any

5 tabloid about this case?

6 A. I have not, sir.

7 Q. You haven’t?

8 A. I haven’t talked to anyone.

9 Q. Are you planning to go to a tabloid after

10 you testify?

11 A. No, sir. I just want to go home.

12 Q. Did you make a complaint that your employee

13 file was unfairly looked at at Neverland?

14 A. Yes, sir.

15 Q. And who did you think had unfairly looked at

16 your employee file?

17 A. The OSS, sir.

18 Q. That’s Mr. Jackson’s personal security

19 guards?

20 A. Yes, sir.

21 Q. Did you have any idea why they were

22 suspicious of you?

23 A. No, sir.

24 Q. They were, weren’t they?

25 A. I don’t know, sir.

26 Q. Did you ever talk to them about why they

27 wanted to see what was in your personnel file?

28 A. Yes, I approached them. 5265



1 Q. This was around the time you went to a

2 tabloid, wasn’t it?

3 A. No, sir.

4 Q. This was around the time you went to Mr.

5 Ring, wasn’t it?

6 A. No, sir.

7 Q. It was very close to the time you left

8 employment at Neverland, wasn’t it?

9 A. I believe so, yes, sir.

10 Q. Do you remember saying you thought Mr.

11 Jackson should compensate you for the rest of your

12 life?

13 A. No, sir.

14 Q. Would it refresh your recollection to show

15 you your deposition transcript?

16 A. Yes, sir.

17 MR. MESEREAU: May I approach?

18 THE COURT: Yes.

19 THE WITNESS: Where is the beginning?

20 Oh, I must have, sir.

21 Q. BY MR. MESEREAU: Have you had a chance to

22 look at that page in your deposition?

23 A. Yes, sir.

24 Q. Does it refresh your recollection that you

25 testified under oath that you thought Mr. Jackson

26 should compensate you for the rest of your life?

27 A. I must have said that, yes, sir, because

28 it’s on there. 5266



1 Q. Now, was it the policy at Neverland to

2 notify the local sheriffs if an intruder was caught

3 on the property?

4 A. Yes, sir, that’s correct.

5 Q. Did you personally notify the sheriffs at

6 any time about an intruder being on the property?

7 A. No, sir.

8 Q. Do you recall you personally apprehending

9 any intruders?

10 A. Myself and Abdool, yes, sir.

11 Q. And what happened?

12 A. There was an intruder that came behind the

13 pool area. It was a reporter. And we just

14 apprehended him and took him down to the front gate

15 and probably the security at the gate called the

16 sheriffs.

17 Q. The pool area is right next to Mr. Jackson’s

18 house, isn’t it?

19 A. Around the area, yes, sir.

20 Q. And how many people did you apprehend on

21 that occasion?

22 A. One. One, sir.

23 Q. How far did that intruder have to travel to

24 get to the pool area?

25 A. I don’t know which direction he came in,

26 sir. Could have been -- could have been a mile, two

27 miles, three miles. I don’t know, sir.

28 Q. And you also were involved in some other 5267



1 situations where intruders tried to get to Mr.

2 Jackson, correct?

3 A. Yes, sir.

4 Q. And please describe those events.

5 A. Kind of vague, but I believe there was

6 two -- two young people, a male and a female, I

7 believe, and they were up by -- they were up by

8 the -- by the theater.

9 Q. The theater would be up near the zoo area?

10 A. Yes, sir.

11 Q. And who caught them?

12 A. I believe it was mobile. I don’t know who

13 it was that was on mobile that evening, that night,

14 but it was mobile patrol.

15 Q. Did you ever steal a watch from Mr. Jackson?

16 A. No, sir.

17 Q. Were you ever accused of that?

18 A. No, sir.

19 Q. You mentioned candy bars earlier, remember?

20 A. Yes, sir.

21 Q. Do you think the jury awarded Mr. Jackson

22 $25,000 against you because you took candy bars?

23 A. That’s what --

24 MR. SNEDDON: I’m going to object as

25 argumentative.

26 MR. MESEREAU: I have no further questions,

27 Your Honor.

28 THE COURT: Redirect? 5268



1 MR. SNEDDON: Yes.

2

3 REDIRECT EXAMINATION

4 BY MR. SNEDDON:

5 Q. All right. Let’s go back just for a second.

6 Mr. Chacon, were you subpoenaed to be here

7 this morning?

8 A. Yes, sir.

9 Q. You’re under subpoena?

10 A. Yes, sir.

11 Q. Did you want to come testify?

12 A. No, sir.

13 Q. When you testified before the grand jury,

14 were you under subpoena?

15 A. Yes, sir.

16 Q. Did you want to testify?

17 A. No, sir.

18 Q. Prior to your appearance before the grand

19 jury, you told the ladies and gentlemen that you met

20 with attorneys for Mr. Jackson; is that correct?

21 A. Yes, sir.

22 Q. And with regard to that conversation, did

23 they want to know what you were going to say?

24 A. They did.

25 Q. And what did you tell them?

26 A. I said that I got subpoenaed, and if I got

27 subpoenaed, that I would just speak the truth, but I

28 didn’t tell them what I knew, but they wanted to 5269



1 know.

2 Q. They wanted to know, but you wouldn’t tell

3 them?

4 A. Yes, sir.

5 Q. But you told them you were going to tell the

6 grand jury the truth?

7 A. Yes, sir.

8 Q. And did you do that?

9 A. Yes, sir.

10 Q. Now, with regard to Mr. Mesereau saying that

11 you added something to the events that occurred

12 yesterday when you and I were talking, do you recall

13 him asking you that question?

14 A. Yes, sir.

15 Q. The new information you provided yesterday

16 had nothing to do with the two events you’ve

17 described to the jury, had they?

18 A. No, sir.

19 Q. There was nothing that changed about that,

20 was there?

21 A. No, sir.

22 Q. In fact, the event that you indicated --

23 there was -- something that you remembered was

24 something you were told by another person; wasn’t

25 that correct?

26 A. Yes, sir.

27 Q. And who was that other person?

28 A. Abdool. 5270



1 Q. It was in no way connected to the testimony

2 you gave concerning the two incidents you observed?

3 A. No, sir.

4 Q. Now, with regard -- just so the jury has a

5 clear indication of the sequence here, you were

6 subpoenaed to appear before the Santa Barbara County

7 Grand Jury, correct?

8 A. Yes, sir.

9 Q. Now, when you actually gave your statement

10 under oath, was there a line of jurors like this in

11 the room?

12 A. Back in ninety --

13 Q. ‘94, when you came in.

14 A. Yes, sir.

15 Q. Now, how long after that was it that Mr.

16 Ring became involved in the civil lawsuit? Let me

17 put it this way: After you appeared before the

18 Santa Barbara Grand Jury and gave a statement under

19 oath, do you recall that?

20 A. Oh, yes, sir.

21 Q. And you went back to work at the ranch, did

22 you not?

23 A. Yes, sir.

24 Q. And you worked at the ranch, Neverland

25 Valley Ranch, for a while before you left there,

26 correct?

27 A. Probably a month or so, or two. I’m not

28 positive. 5271



1 Q. Was it at that point that you became

2 involved in the lawsuit with Mr. Ring?

3 A. Yes, sir.

4 Q. Whose idea was it to go to the tabloid for

5 the story?

6 A. Well, we probably talked about it, but we

7 talked to Mr. Ring about it. I guess it was all of

8 us in general.

9 Q. After you -- Mr. Mesereau asked you about

10 your salary at the ranch. Do you recall that?

11 A. Yes, sir.

12 Q. And you spoke about being dissatisfied with

13 the wages that you were getting --

14 A. Yes, sir.

15 Q. -- compared to some people that had been

16 hired afterward, correct?

17 A. Yes, sir.

18 Q. After your conversations with Mr. Sanger and

19 Steve Cochran about your grand jury appearance, were

20 you offered a raise?

21 A. Yes, sir, I was.

22 Q. And it was before your testimony actually

23 occurred before the grand jury, correct?

24 A. Yes, sir.

25 Q. So it was in between the time they found out

26 you were going and the time that you actually

27 appeared they offered you a raise?

28 A. Yes, sir. 5272



1 Q. And Mr. Kassim also, right?

2 A. Yes, sir.

3 Q. Actually, it’s Mr. Abdool.

4 A. Yes, sir.

5 Q. Now, during the course of the -- let me ask

6 you this: After you testified before the grand jury

7 and gave your statement under oath about what you

8 saw happen on those two incidents - okay? - did you

9 receive threats?

10 A. Oh, yes, sir.

11 Q. In what form?

12 MR. MESEREAU: Objection; beyond the scope.

13 THE COURT: Sustained.

14 MR. SNEDDON: Judge, it’s what led to the

15 lawsuit. And counsel was allowed to go into that.

16 THE COURT: All right. With that

17 representation, I’ll change my ruling.

18 THE WITNESS: Could you --

19 MR. SNEDDON: Yes.

20 Q. You said you were threatened. In what form?

21 A. Verbally, and -- well, verbally, and

22 somewhat physically by someone touching their --

23 Tony Coleman touching his weapon.

24 Q. Tony Coleman was who?

25 A. He was OSS.

26 Q. All right. Would you describe to the

27 jury -- if you have to stand up, do it. Describe to

28 the jury what Mr. Coleman did. 5273



1 A. We were in the security office, and we were

2 arguing about an intruder that came in, and he

3 wanted to do it his way. And I said, “If you do it

4 that way, we’re going to” -- “it’s not the

5 procedure.”

6 And then he says, “Well, I’m going to do it

7 my way because I’m here to oversee you.” And he

8 touched -- he pulled his coat back and he touched

9 his weapon, and he says, “I’m in charge here.” I

10 believe that’s the words he used.

11 Q. Did he at any other time ever use his weapon

12 to indicate a threat towards you?

13 A. No, sir, that was about the first time.

14 Q. Did you ever receive any phone calls of any

15 kind that were threatening?

16 A. Yes, sir.

17 Q. Did you report those to law enforcement?

18 A. Yes, I did, sir.

19 Q. How many occasions did that occur?

20 A. Several times. One time when we first

21 started, somebody says --

22 MR. MESEREAU: Objection; nonresponsive

23 THE COURT: After “several times,” sustained.

24 Q. BY MR. SNEDDON: All right. Tell us about

25 those threats that you received.

26 A. The first time I received it, they said,

27 “I’m going to kill you.”

28 MR. MESEREAU: Objection; hearsay. 5274



1 MR. SNEDDON: Your Honor, goes to the state

2 of mind and to the reason for the lawsuit.

3 THE COURT: I’m going to overrule the

4 objection as to state of mind.

5 Q. BY MR. SNEDDON: Go ahead.

6 A. Someone called and said, “I’m going to kill

7 you,” and hung up. And then other times we had

8 calls at the house where they would either laugh or

9 wouldn’t say words, but we knew that someone was --

10 I believe it was OSS behind this.

11 Q. Did you as a result -- did you take these

12 things seriously?

13 A. Oh, yes, sir.

14 Q. Did you approach anyone with regard to

15 obtaining a gun permit?

16 A. Yes, sir.

17 Q. And who did you approach?

18 A. I asked Mr. Birchim and yourself for a gun

19 permit. So I carried a concealed weapon permit for

20 about two years, I believe it was.

21 Q. You indicated that you may have asked

22 Sergeant or now Commander Birchim for money for your

23 wife --

24 A. Yes, sir.

25 Q. -- do you recall?

26 Do you remember why that was?

27 A. Yes, sir.

28 Q. Why was that? 5275



1 A. Well, my wife’s sister-in-law had just died,

2 and --

3 Q. That’s all right, I’ll withdraw the

4 question. That’s okay. It’s not important.

5 Mr. Mesereau asked you about - we’ll turn to

6 a subject a little easier - about my conversation

7 with you yesterday --

8 A. Yes, sir.

9 Q. -- with Mr. Birchim being there.

10 A. Yes, sir.

11 Q. And you told Mr. Mesereau how long the

12 conversation lasted, correct?

13 A. Yes, sir.

14 Q. Was Mr. Birchim present during the entire

15 conversation?

16 A. Yes, he was.

17 Q. Were there portions of time before Mr.

18 Birchim got there that you and I talked a little

19 bit?

20 A. Yes, sir.

21 Q. Did we talk about anything about this case?

22 A. No, sir. We talked about my military

23 experience, and that you knew some people that I

24 knew where I was born and raised.

25 Q. Had nothing to do with the case during the

26 time Birchim wasn’t there?

27 A. No, sir.

28 MR. MESEREAU: Objection; asked and 5276



1 answered.

2 THE WITNESS: No, sir.

3 Q. BY MR. SNEDDON: Now, when we were talking

4 yesterday --

5 THE COURT: Sustained. Go ahead.

6 (Laughter.)

7 Q. BY MR. SNEDDON: When we were talking

8 yesterday and Mr. Mesereau asked you did I tell you

9 what questions I was going to ask you today, do you

10 recall him asking you that question?

11 A. Yes, sir.

12 Q. What was the question that I actually asked

13 you; do you remember?

14 A. I believe it was the incidents that took

15 place, the two incidents that happened on the ranch.

16 Q. And I asked you just to describe them in

17 your own words to me?

18 A. Yes, sir.

19 Q. And Sergeant -- or Commander Birchim was

20 there during that entire time?

21 A. Yes, he was.

22 Q. Mr. Mesereau mentioned something about an

23 individual called Victor Gutierrez. Do you remember

24 that?

25 A. Yes, sir.

26 Q. Were you ever paid any money by Mr.

27 Gutierrez?

28 A. No, sir. 5277



1 Q. Did you ever give him a statement at all?

2 A. No, sir.

3 Q. You indicated that the individuals who were

4 on the ranch that were armed were called the OSS.

5 Was that their official name, or was that a name

6 that the security staff gave them?

7 A. I believe that’s -- it was used for them as

8 a short title. Office of Special Services, but they

9 used it as -- just call them OSS.

10 Q. And with regard to -- you told the jury that

11 they interfered with you on how you did your job.

12 In what respect? I mean, what was the tension or

13 the friction between the two of you?

14 A. They just -- they just interfered in every

15 aspect of our duty as security there. They would

16 break the beams, the security beams, and they would

17 cause us to run out there thinking it was an

18 intruder. They would come by and laugh, and just

19 make jokes, and/or sit out in their vehicle and

20 stare at us inside the security office.

21 Q. With regard to the lawsuit itself that Mr.

22 Mesereau has asked you a number of questions about,

23 were you ever consulted about the amount of money

24 that was going to be sued for?

25 A. No, sir.

26 Q. Whose judgment did you leave that decision?

27 A. Mr. Ring.

28 Q. Did you legit -- did you feel, yourself, 5278



1 that you were entitled to some money from Mr.

2 Jackson because of the way you were treated on the

3 ranch?

4 A. Yes, sir.

5 Q. Do you still feel that way?

6 A. Yes, sir.

7 MR. MESEREAU: Objection. Move to strike;

8 relevance.

9 THE COURT: Sustained; stricken.

10 Q. BY MR. SNEDDON: You told the jury that you

11 knew that you were being -- your telephones on the

12 ranch were being monitored, correct?

13 A. Yes, sir.

14 Q. How did you know that?

15 A. It was common knowledge that -- in the main

16 office where Sandy Domz worked at, there was a

17 computer paper printout that -- you could hear, and

18 it printed out the phone calls as they were made,

19 either going out or coming in.

20 Q. Now, just a couple of more questions.

21 With regard to the lawsuit, the trial, the

22 civil lawsuit, were you -- or did you -- during that

23 lawsuit, were you allowed or permitted to testify

24 concerning the incidents you told this jury about

25 this morning in that lawsuit?

26 A. No, sir. As a matter of fact, the judge

27 said if I -- if we --

28 Q. You just weren’t allowed to? 5279



1 A. No, sir.

2 Q. Okay. Mr. Chacon, is there anything that

3 you’ve told this jury this morning about what you

4 saw out there on those two incidents that is

5 anything but the truth?

6 A. It’s the truth, sir.

7 MR. SNEDDON: No further questions.

8

9 RECROSS-EXAMINATION

10 BY MR. MESEREAU:

11 Q. Mr. Chacon, the prosecutor has just asked

12 you to talk about problems you had with the OSS,

13 right?

14 A. Yes, sir.

15 Q. And the OSS was a nickname someone developed

16 to call Mr. Jackson’s personal bodyguards?

17 A. They themselves, sir.

18 Q. You wanted money to be awarded to you from a

19 Santa Maria jury because of your problems with the

20 personal security guards of Mr. Jackson, correct?

21 A. Yes, sir.

22 Q. Your claims were rejected, true?

23 A. Yes, sir.

24 Q. You also claimed at the time $16 million

25 wasn’t enough for you, right?

26 A. I probably did, sir. Yes, sir.

27 Q. The prosecutor just asked you if you knew

28 anything about the amounts you were seeking, and of 5280



1 course you did, right?

2 A. Yes, sir.

3 Q. You wanted money because you claim that

4 people were calling your home and hanging up,

5 correct?

6 A. That was part of it, sir, yes, sir.

7 Q. And a Santa Maria jury rejected that claim,

8 correct?

9 A. Yes, sir.

10 Q. You said that someone named Coleman had put

11 his hand on his gun because he didn’t like the way

12 you wanted to handle an intruder; is that correct?

13 A. No, because he wanted to handle it.

14 Q. He was a personal security guard, correct?

15 A. OSS. Not a security guard.

16 Q. He was carrying a -- well, this group you

17 call the OSS, they’re bodyguards for Mr. Jackson,

18 right?

19 A. Yes, sir, they are.

20 Q. And they were carrying weapons, correct?

21 A. Yes, sir.

22 Q. And he was concerned about the intruder,

23 correct?

24 A. No, sir.

25 Q. You sued also claiming you should get money

26 because of what Mr. Coleman did on that day,

27 correct?

28 A. He threatened me, yes, sir. 5281



1 Q. And that was rejected by a Santa Maria jury

2 as well, correct?

3 A. Yes, sir.

4 Q. And you wanted money because you said Mr.

5 Jackson stared at you on occasion, correct?

6 A. No, sir.

7 Q. Why did you say it?

8 A. Just to say it.

9 MR. MESEREAU: No further questions.

10 MR. SNEDDON: No questions, Your Honor.

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

12 step down.

13 Call your next witness.

14 MR. ZONEN: Call Adrian McManus to the

15 stand.

16 THE COURT: Come to the front of the

17 courtroom, please.

18 When you get to the witness stand, please

19 remain standing. Face the clerk over here and raise

20 your right hand.

21

22 ADRIAN MARIE McMANUS

23 Having been sworn, testified as follows:

24

25 THE WITNESS: Yes.

26 THE CLERK: Please be seated. State and

27 spell your name for the record.

28 THE WITNESS: Adrian Marie McManus; 5282



1 A-d-r-i-a-n; M-a-r-i-e; M-c-M-a-n-u-s.

2 THE CLERK: Thank you.

3 MR. ZONEN: May I proceed?

4 THE COURT: Yes.

5

6 DIRECT EXAMINATION

7 BY MR. ZONEN:

8 Q. Ms. McManus, good morning.

9 A. Good morning.

10 Q. Without telling us the location or the name

11 of where you’re working, describe the kind of work

12 you’re currently doing.

13 A. I work in a jewelry department where I sell

14 diamonds.

15 Q. Is this a department store?

16 A. Yes, sir.

17 Q. Is it in the Santa Maria area?

18 A. Yes.

19 Q. How long have you been working at that

20 department store?

21 A. Seven years in July.

22 Q. You work in the diamond department, do you?

23 A. Yes.

24 Q. All right. There is such a thing as a

25 diamond department?

26 A. Yes.

27 Q. They sell raw diamonds or finished diamonds

28 or jewelry? 5283



1 A. Fine diamonds, jewelry.

2 Q. All right.

3 A. It’s actually a lot of diamonds.

4 Q. Okay. Have you worked in that department

5 the entire time?

6 A. No.

7 Q. Have you worked in other departments in that

8 store as well?

9 A. Yes.

10 Q. Prior to that, what kind of work were you

11 doing?

12 A. I was a merchandise assistant for the

13 cosmetic department.

14 Q. At the same store?

15 A. Yes.

16 Q. For what period of time?

17 A. Probably the beginning of my employment.

18 Maybe about four years.

19 Q. And prior to that, what kind of work were

20 you doing?

21 A. Do you mean like after that or before that?

22 Q. Before working with this store.

23 A. I worked for Sears, and I ran -- I was in

24 the cosmetic department.

25 Q. Did you ever work for Michael Jackson?

26 A. Yes.

27 Q. Do you see Michael Jackson in this

28 courtroom? 5284



1 A. I don’t have my glasses. I forgot them

2 upstairs.

3 Q. How far can you see?

4 A. I can’t see real far.

5 Q. Can you see me?

6 A. Yeah, blurry.

7 Q. I won’t ask that question, then.

8 Can you read, in the event we need to show

9 you some documents?

10 A. No, I need to get my glasses.

11 Q. We’re going to have a break in a few

12 minutes. I’ll reserve all those questions until we

13 have that break.

14 You did work for Michael Jackson at some

15 point, did you not?

16 A. Yes.

17 Q. For what period of time did you work for

18 Michael Jackson?

19 A. From, I think, August 29th of 1990 through

20 July 31st of 1994.

21 Q. In what capacity? What kind of work did you

22 do for Mr. Jackson?

23 A. At the beginning I was just a maid, regular

24 housekeeper. Nine months later I was cleaning his

25 bedroom.

26 Q. And did you continue that job for the

27 duration of your employment?

28 A. Yes. 5285



1 Q. Were you the only person cleaning his

2 bedroom?

3 A. Yes.

4 Q. Tell me how that worked. Why were there not

5 other people involved in cleaning his bedroom as

6 well?

7 MR. MESEREAU: Objection; foundation.

8 THE COURT: Sustained.

9 Q. BY MR. ZONEN: What were you told about who

10 would be cleaning his bedroom?

11 A. I was just told that I was flexible and that

12 I was the one to clean his bedroom.

13 Q. And that was that entire time after a few

14 months after you commenced working for Mr. Jackson?

15 A. Yes.

16 Q. So it was early ‘91?

17 A. I just know it was nine months after,

18 because I started in ‘90, and --

19 Q. Now, up to that point, you were responsible

20 for cleaning other locations at Neverland; is that

21 correct?

22 A. Yes.

23 Q. What were those other locations? Tell us

24 what your job included.

25 A. Before that time?

26 Q. Yes.

27 A. Cleaning the rec room, the ranch house, the

28 guest units, the hill house, the main house, except 5286



1 his bedroom at that time.

2 Q. Do you know who the person was who was

3 responsible for cleaning his bedroom before you?

4 A. Blanca Francia.

5 Q. And did you know Blanca Francia?

6 A. Yes.

7 Q. Were you the one who took over that job when

8 she left?

9 A. Yes.

10 Q. Did you take over that job as soon as she

11 left?

12 A. Yes.

13 Q. Describe to us what those responsibilities

14 included, cleaning --

15 THE COURT: Let’s take a break.

16 (Recess taken.)

17 THE COURT: Go ahead.

18 Q. BY MR. ZONEN: Thank you. Where we left off

19 before the break, I was asking you about your

20 responsibilities, once you assumed the position of

21 being the personal maid for Michael Jackson.

22 And before I get to that, do you have your

23 glasses?

24 A. Yes.

25 Q. Is Mr. Jackson here in the courtroom?

26 A. Yes.

27 Q. Okay. Could you identify him, please?

28 A. He’s right here. 5287



1 MR. ZONEN: And the record should reflect.

2 THE COURT: Yes.

3 Q. BY MR. ZONEN: What were your

4 responsibilities as his personal maid?

5 A. To pick up after Mr. Jackson, anything to do

6 with his clothes, his -- washing his clothes, fixing

7 his bed, cleaning his bedroom.

8 BAILIFF CORTEZ: I’m sorry, can you speak

9 more into the microphone?

10 Q. BY MR. ZONEN: You have to stay fairly close

11 to the microphone to be able to be heard all the way

12 to the back of the courtroom, if you will.

13 Describe his bedroom suite for us, please.

14 A. It was a very big room. There was a second

15 level to it. There was a Jacuzzi on one side with a

16 bathroom. A closet. Inside that closet was a

17 secret closet.

18 The other side of the room there was a

19 bathroom also, and another walk-in closet, and there

20 was a stairway that led up to the second level.

21 Q. Were your responsibilities limited to that

22 suite?

23 A. At one time, yes.

24 Q. All right. What if Mr. Jackson was gone for

25 a while, if he was on tour, or out of town for a

26 period of time, what would you do?

27 A. I still had to pick up the room, as far as

28 keeping it dusted, and brassing, and cleaning the 5288



1 tub. There was still a lot to do.

2 Q. Were there responsibilities that went beyond

3 the suite on those occasions?

4 A. Yes.

5 Q. Did Mr. Jackson have monkeys during that

6 period of time, or apes, or chimps, or --

7 A. Yes.

8 Q. -- primates?

9 A. Yes.

10 Q. Were they living in his room?

11 A. They weren’t living in his room, but they

12 were brought into his room.

13 Q. Were there cages for them?

14 A. Some -- well, when I seen them, they were

15 running around.

16 Q. Did you ever see cages in his room?

17 A. I don’t recall seeing cages in the room.

18 Q. Were you, on occasion, required to tend to

19 the monkeys or clean up after the monkeys?

20 A. Yes.

21 Q. And describe what that obligation was.

22 A. Well, there was a little monkey, a chimp,

23 and --

24 MR. MESEREAU: Objection; relevance.

25 THE COURT: Relevance, Counsel?

26 MR. ZONEN: I’ll withdraw the question. Let

27 me move on.

28 Q. Were you the personal maid for the balance 5289



1 of time that you were there?

2 A. Yes.

3 Q. All right. Do you know a person by the

4 name -- or did you know a person by the name of Wade

5 Robeson?

6 A. Yes.

7 Q. Who was Wade Robeson?

8 A. He was a little boy that used to go to the

9 ranch, and he was from Australia.

10 Q. How old was he when you saw him at the

11 ranch?

12 A. I don’t know exact. Maybe 10, 11.

13 Q. Now, you have a son, do you not?

14 A. Yes.

15 Q. And your son at that time was approximately

16 how old?

17 A. Maybe ten.

18 Q. About the same age as Wade Robeson?

19 A. Yes.

20 Q. Did your son ever come with you to Neverland

21 Ranch?

22 A. Yes.

23 Q. On many occasions?

24 A. Yes.

25 Q. Did your son know Wade Robeson?

26 A. Yes.

27 Q. Did they, on occasion, play together?

28 A. Off and on. 5290



1 Q. For what period of time did you see Wade

2 Robeson there at the ranch; do you recall?

3 A. Are you talking about, like, months or --

4 Q. Well, for what period of time did Wade

5 Robeson visit the ranch?

6 A. Are you talking about years or just the

7 timing, like?

8 Q. From the earliest time that you saw him

9 visit to, say, the last time you saw him visit, if

10 you can recall, give us a sense of what period of

11 time that was.

12 A. I would say probably 1992. I don’t know how

13 many months.

14 Q. And did you see him there for a long period

15 of time?

16 MR. MESEREAU: Objection; vague.

17 THE COURT: Sustained.

18 Q. BY MR. ZONEN: How often did he visit during

19 that period of time? In other words, how many

20 separate times did he come, to your recollection?

21 A. There were a lot of times. Come maybe for a

22 week or the weekend.

23 Q. All right. And that was my next question.

24 A. Sorry.

25 Q. How long would he stay when he did come?

26 A. Sometimes a weekend, sometimes maybe a

27 little longer.

28 Q. And during that period of time, where did -- 5291



1 where did Wade Robeson stay when he was at the

2 house, when he was at the ranch?

3 A. In Mr. Jackson’s room.

4 Q. Were you the personal maid for Mr. Jackson

5 during the entire time that Wade Robeson visited?

6 A. I believe so. Yes.

7 Q. Let me change that again.

8 During the period of time that you were the

9 personal maid, was Wade Robeson visiting that entire

10 time?

11 A. Yes.

12 Q. Okay. I think you said among your

13 responsibilities were to pick up after Mr. Jackson

14 and wash clothing. Do you have a recollection as to

15 whether or not you saw Wade Robeson’s personal

16 possessions?

17 A. Sometimes.

18 Q. And I asked you where Wade Robeson stayed,

19 and you said Mr. Jackson’s room. Do you know where

20 he stayed in the room?

21 A. In the same bed as Mr. Jackson.

22 Q. Okay. Were there other beds in Mr.

23 Jackson’s suite during that period of time?

24 A. Yes.

25 Q. Where were the other beds?

26 A. There was one upstairs in like -- I don’t

27 know if you’d call it -- in like a loft.

28 Q. Was that bed ever used? 5292



1 A. No.

2 Q. Do you have a recollection of ever changing

3 sheets on that bed?

4 A. I did, you know, just to keep it kind of up,

5 but not always.

6 Q. Do you have a recollection of anybody ever

7 seeping in that bed; in other words, coming in and

8 discovering that those sheets had simply been used,

9 the bed had been used?

10 A. Yes.

11 Q. How often?

12 A. Maybe -- maybe once.

13 Q. During the entire time that you were the

14 personal maid for Mr. Jackson?

15 A. I believe so.

16 Q. All right. Did you know Wade Robeson’s

17 parents, mother or father?

18 A. I don’t ever remember meeting a father, but

19 I remember the mother.

20 Q. And where did she stay when they were there?

21 A. In the guest unit.

22 Q. Did Wade Robeson have any brothers or

23 sisters who came?

24 A. Not that I recall.

25 Q. Do you know if Wade Robeson’s mother ever

26 stayed in Mr. Jackson’s residence?

27 A. No. I recall her in the guest units.

28 Q. Did you see Wade Robeson in Mr. Jackson’s 5293



1 residence?

2 A. Yes.

3 Q. Do you know who Macaulay Culkin is?

4 A. Yes.

5 Q. Who is Macaulay Culkin?

6 A. He was a little boy that used to come to the

7 ranch.

8 Q. Do you know during what period of time

9 Macaulay Culkin came to the ranch?

10 A. 1990, maybe, through maybe ‘93.

11 Q. He was there for extended periods as well?

12 A. Yes.

13 Q. And by “extended periods,” what do we mean?

14 A. Sometimes a week. Sometimes longer.

15 Q. Did he visit frequently during that period

16 of time?

17 A. Yes.

18 Q. Was he ever there during the period of time

19 that Wade Robeson was there?

20 A. I can’t recall.

21 Q. Did Macaulay Culkin have brothers or

22 sisters?

23 A. Yes.

24 Q. Do you know how many brothers or sisters he

25 had?

26 A. I’m thinking maybe seven or eight.

27 Q. It was a large family?

28 A. Yes. 5294



1 Q. Did you ever meet his parents?

2 A. Yes.

3 Q. Would all of them come to the ranch on

4 occasion?

5 A. Sometimes.

6 Q. Were there occasions when Macaulay Culkin

7 came by himself?

8 A. Sometimes.

9 Q. And on those occasions when he came by

10 himself, how long, typically, would he stay?

11 A. The weekend. Sometimes his parents would

12 show up later and they’d be there maybe a week.

13 Q. How old was Macaulay Culkin when he was

14 visiting the ranch during that period of time?

15 A. Maybe 11. 10 or 11 maybe.

16 Q. At the earliest -- you gave us a period of

17 time that was over two or three years. What was the

18 youngest age you remember seeing him, as best you

19 can recall?

20 A. Maybe ten.

21 Q. Okay. Was Macaulay Culkin -- do you know

22 him to be an actor?

23 A. Yes.

24 Q. Have you seen things that he’s been in,

25 movies or television?

26 A. Maybe one.

27 Q. Do you know where Macaulay Culkin stayed

28 when he was at the ranch? 5295



1 A. In Mr. Jackson’s room.

2 Q. And as I had asked previously, do you know

3 where in Mr. Jackson’s room he stayed?

4 A. In his bedroom, in his bed.

5 Q. And how do you know that?

6 A. Because when I would -- when I would go in

7 the room the next day, there was just one bed that I

8 had to fix.

9 Q. Do you know if Macaulay Culkin and Wade

10 Robeson’s visit would overlap on occasion, when both

11 would be there at the same time?

12 A. Can you repeat that?

13 Q. I’m sorry?

14 A. Can you repeat it?

15 Q. If their visits would overlap, if they would

16 be there at the same time. Do you have a

17 recollection of seeing Macaulay Culkin and Wade

18 Robeson there at the same time?

19 A. I could have.

20 Q. Do you know where Macaulay Culkin’s family

21 stayed when they were at the ranch?

22 A. Usually at the guest units.

23 Q. And the guest units were a separate

24 building?

25 A. Yes.

26 Q. Do you know if his brothers or sisters ever

27 stayed overnight in Mr. Jackson’s personal

28 residence, his personal suite? 5296



1 A. Not that I know of.

2 Q. Who is Jordan Chandler?

3 A. He’s another little boy that used to come to

4 the ranch.

5 Q. Do you know what period of time he used to

6 come to the ranch?

7 A. Maybe ‘93.

8 Q. Was it for as long a period of time as Mr.

9 Culkin, Macaulay Culkin came to the ranch?

10 A. No.

11 MR. MESEREAU: Objection; vague.

12 THE COURT: Sustained.

13 Q. BY MR. ZONEN: Can you tell us the period of

14 time that Jordan Chandler visited at Neverland? In

15 other words, at what time did it commence and at

16 what time did it end, if at all, during your period

17 of employment?

18 A. Maybe 1993 and maybe through ‘94. Maybe

19 early, maybe late -- actually, maybe late ‘93.

20 Q. Who is Brett Barnes?

21 A. Another boy that used to come to the ranch.

22 Q. How old was Brett Barnes when he visited?

23 A. Probably maybe 11.

24 Q. For what period of time did Brett Barnes

25 come to the ranch?

26 A. He was there quite a lot. Mid -- maybe

27 1993.

28 Q. Do you know approximately what period of 5297



1 time Brett Barnes would come and visit? In other

2 words, over what period of time, measured in months,

3 measured in years, measured in weeks, from the first

4 visit to the last?

5 A. I would -- I’m thinking maybe 1992 through

6 maybe 19 -- late 1993.

7 Q. When Brett Barnes came to the ranch, did he

8 come with family?

9 A. Yes.

10 Q. And who in his family did he come to the

11 ranch with?

12 A. With his mother and his sister.

13 Q. Did you ever meet Brett Barnes’ father?

14 A. I don’t believe there was a father in that

15 picture. I have never seen a father.

16 Q. Brett Barnes has a sister, you say, who

17 came?

18 A. Yes.

19 Q. How old was she?

20 A. I would say maybe 13.

21 Q. How frequently did Brett Barnes come to the

22 ranch during that period of time?

23 A. A lot.

24 Q. And by “a lot,” what do we mean? Would it

25 be more than one visit a month?

26 A. Yes.

27 Q. And when he came, how long did Brett Barnes

28 stay? 5298



1 A. Sometimes -- sometimes a week. Sometimes

2 less than a week.

3 Q. Where did he stay when he came?

4 A. In Mr. Jackson’s room.

5 Q. Where did he sleep when he was there?

6 A. In Mr. Jackson’s bed.

7 Q. Do you have a recollection at any time

8 either fixing a bed for Brett Barnes that was

9 separate from Mr. Jackson’s bed or cleaning up after

10 a bed separate from Mr. Jackson’s bed?

11 A. No.

12 Q. I had asked you about Jordan Chandler. When

13 he came to Neverland Ranch, did he come with his

14 family?

15 A. Jordan came with his mother and his little

16 sister.

17 Q. Do you know how old the little sister was?

18 A. Maybe four.

19 Q. She was a small child?

20 A. Yes.

21 Q. Did you ever meet Jordan Chandler’s father?

22 A. I never -- I never met -- I never seen his

23 father around there. I never met him.

24 Q. During the visits when Jordan Chandler came,

25 where did his mother and sister stay?

26 A. In the guest unit.

27 Q. And where did Jordan Chandler stay?

28 A. In Mr. Jackson’s room. 5299



1 Q. Consistently?

2 A. Yes.

3 Q. Where did Jordan Chandler sleep when he was

4 in Mr. Jackson’s room?

5 A. In Mr. Jackson’s bed.

6 Q. Now, do you have a recollection of these

7 four boys being there at the same time, Macaulay

8 Culkin, Jordan Chandler, Brett Barnes, and Wade

9 Robeson?

10 A. Um, I -- I kind of recall Brett being there

11 with Jordie, at the same time. And, you know, it

12 could have been Wade also, when Brett was there.

13 Q. Would that have been a common occurrence?

14 MR. MESEREAU: Objection; vague.

15 THE COURT: Overruled.

16 You may answer.

17 THE WITNESS: Not always.

18 Q. BY MR. ZONEN: Do you understand -- not

19 always?

20 A. Not always.

21 Q. Do you have a recollection of specific

22 events of all of them being there together or the

23 two or the three that you mentioned?

24 MR. MESEREAU: Objection; asked and

25 answered.

26 THE COURT: Overruled.

27 You may answer.

28 THE WITNESS: I just recall seeing them 5300



1 there at the same time, Brett and Jordie.

2 Q. BY MR. ZONEN: Brett and Jordie?

3 A. Yes.

4 Q. Do you know how many times you saw Brett and

5 Jordie there together?

6 A. At least two times.

7 Q. During the entire period of time that you

8 worked as Michael Jackson’s maid, personal maid, was

9 it a frequent occasion that there would be one of

10 those four boys there?

11 A. Yes.

12 MR. MESEREAU: Objection; vague.

13 THE COURT: Overruled. The answer was,

14 “Yes.” Next question.

15 Q. BY MR. ZONEN: Was there ever an occasion

16 that one of those four boys was there and did not

17 stay in Michael Jackson’s bedroom and bed?

18 MR. MESEREAU: Objection; foundation.

19 THE COURT: Sustained.

20 Q. BY MR. ZONEN: Was there ever an occasion

21 that you personally witnessed during the time that

22 you worked as his personal maid when any of those

23 four boys stayed -- and you were on duty, where they

24 stayed in the guesthouse and not in Mr. Jackson’s

25 bed?

26 A. No.

27 Q. As part of your obligations and

28 responsibilities as the maid, did you clean up in 5301



1 the bathrooms?

2 A. Yes.

3 Q. Was there a Jacuzzi in the bathroom?

4 A. It wasn’t in -- yes, but --

5 Q. Am I describing the room incorrectly or

6 inaccurately?

7 A. Yeah, because it wasn’t really attached. It

8 was just one room where the Jacuzzi was, and off to

9 the side there was a bathroom and a shower.

10 MR. ZONEN: Just one second.

11 Q. During the period of time that you were

12 working as Mr. Jackson’s personal maid, did you ever

13 see behavior by Mr. Jackson toward any of these boys

14 that concerned you?

15 MR. MESEREAU: Objection; vague.

16 THE COURT: Overruled.

17 You may answer.

18 THE WITNESS: Yes.

19 Q. BY MR. ZONEN: And which of the four boys

20 are we talking about?

21 A. Macaulay Culkin, Brett Barnes and Jordie

22 Chandler.

23 Q. All right. Let’s begin with Macaulay

24 Culkin. What is it that you saw that concerned you?

25 A. I was coming out of the bathroom by his

26 bedroom, by Mr. Jackson’s bedroom. I was cleaning

27 that bathroom. And when I came out, I saw Mr.

28 Jackson and Macaulay in the library, and Mr. Jackson 5302



1 was kissing him on his cheek, and he had his hand

2 kind of by his leg, kind of on his rear end.

3 Q. Did they know that you were there?

4 A. I don’t know --

5 MR. MESEREAU: Objection; calls for

6 speculation.

7 THE COURT: Sustained.

8 Q. BY MR. ZONEN: Did you announce your

9 presence to them?

10 A. No.

11 Q. Where were you at the time you witnessed

12 this?

13 A. I was coming out of the bathroom by Mr.

14 Jackson’s bedroom.

15 Q. All right. Is that on the first floor?

16 A. Yes.

17 Q. Is that where you were?

18 A. Yes.

19 Q. Were they on the first floor as well?

20 A. Yes.

21 Q. Did you -- did you note that they were in

22 the room or had come into the room?

23 A. No.

24 Q. Were you surprised to see them?

25 A. Yes.

26 Q. Had you been cleaning in that room?

27 A. In the bathroom?

28 Q. Yes. 5303



1 A. Yes.

2 Q. How did you come upon them? How did that

3 happen?

4 A. I was leaving the bathroom, and when I

5 walked out of the bathroom, I looked up and I saw.

6 Q. How far away from you were they?

7 A. I don’t know the feet. It was a little

8 distance.

9 Q. Between the distance that you and I are at

10 this moment?

11 A. Maybe a little further.

12 Q. All right. Let’s say to the back rail over

13 here, behind me?

14 A. Probably a little further. Maybe a little

15 further.

16 Q. Second or third row?

17 A. Maybe second row.

18 MR. ZONEN: Okay. And for the record, could

19 we say that’s 30 feet, 25? The second row?

20 THE COURT: I’m not testifying.

21 (Laughter.)

22 Q. BY MR. ZONEN: How far do you think that is

23 in feet? Do you have any way of knowing?

24 A. No.

25 Q. All right. You did not hear them come into

26 the room?

27 A. No.

28 Q. When you got to the position where you saw 5304



1 them, were either of them looking at you?

2 A. No.

3 Q. Were either of them facing you?

4 A. No.

5 Q. And you testified that you saw Michael

6 Jackson kissing Macaulay Culkin?

7 MR. MESEREAU: Objection; asked and

8 answered.

9 THE WITNESS: Yes.

10 THE COURT: Just a moment.

11 THE WITNESS: Oh, I’m sorry.

12 THE COURT: The objection is sustained.

13 Q. BY MR. ZONEN: Where did he kiss him?

14 A. On the cheek.

15 Q. And where did he touch him?

16 A. Kind of like by his leg, and it went to his

17 rear end.

18 Q. And how long did that last?

19 A. I don’t know how long. I just walked off.

20 Q. And you say you walked off.

21 A. Yes.

22 Q. Walked off where?

23 A. I went to the laundry room.

24 Q. All right. Were you in a position where you

25 could do that without being seen?

26 A. I believe so.

27 Q. All right. Did you leave the -- literally

28 leave the suite? 5305



1 A. I was in the rest room and I left the rest

2 room.

3 Q. Okay. Now, can you describe that for us,

4 how you could do that without necessarily being seen

5 or detected in his room? You didn’t have to walk by

6 them or anything?

7 A. No. They were at a distance, so I just

8 walked through the hall.

9 Q. Did Mr. Jackson ever mention to you anything

10 about that?

11 A. No.

12 Q. Did you ever mention anything to him about

13 that?

14 A. No.

15 Q. Was that the first thing that you had seen

16 in terms of behavior toward a child that caused you

17 concern?

18 A. Yes.

19 Q. Did you see any other incidents that caused

20 you concern in terms of Mr. Macaulay Culkin?

21 A. No.

22 Q. What was the next thing that you saw that

23 caused you concern?

24 A. Brett Barnes.

25 Q. And what did you see?

26 A. Well, I was up in the video room, and Mr.

27 Jackson had me taking videos out of the wall. There

28 was -- the room was a video room. It was actually a 5306



1 soldier room. And he had me taking all of the

2 videos out of the wall, and there was like -- I

3 don’t know what you call them, like wood things that

4 would hold the videos, and they had, like, screws in

5 the wall. So I was pulling those all out because he

6 had heard that you could see down into his bedroom.

7 MR. MESEREAU: Objection; nonresponsive.

8 THE COURT: Sustained.

9 MR. MESEREAU: Move to strike.

10 THE WITNESS: So --

11 THE COURT: Just a moment. I’ll strike from

12 the point where she said, “So I was pulling those

13 out.”

14 Q. BY MR. ZONEN: All right. Why -- what were

15 you pulling out from the walls?

16 A. Videotapes.

17 Q. Why were you doing that?

18 A. Because Mr. Jackson had heard that you could

19 see down into his bedroom. There was like a little

20 cubbyhole in the back of the walls up in that room,

21 so he wanted to see if you could see down into his

22 bedroom.

23 Q. So did you, in fact, remove videotapes?

24 A. Yes.

25 Q. Could you see down into the bedroom?

26 A. Yes.

27 Q. Did you show him that, or did he see that

28 with you? 5307



1 A. He was in his room, and where I was at was

2 above his room, so he came up with Brett Barnes to

3 that room.

4 Q. He came up to the room?

5 A. Up to the video room with Brett Barnes.

6 Q. While you were there?

7 A. Yes.

8 Q. All right. And did you show him that spot

9 while he was there?

10 A. Yes.

11 Q. All right. Now, when did you see him doing

12 something with Brett Barnes?

13 A. After that?

14 Q. Yes. Was it right after that?

15 A. It was kind of right after that, yeah.

16 Q. And where was he?

17 A. They were walking back down the stairs, and

18 they went down through the hall by his bedroom, and

19 I kind of followed because it was very hot up there

20 in that room. And I was on the landing after you

21 get on the stairs, and I kind of looked over the

22 landing, and he was walking away with Brett to his

23 room, and I saw him put his hand on Brett’s rear

24 end, and he gave Brett a kiss on the cheek.

25 Q. In like fashion to what you described you

26 had seen with Macaulay Culkin?

27 A. Yes.

28 Q. All right. Which of those incidents took 5308



1 place first, Macaulay Culkin or Brett Barnes?

2 A. Macaulay Culkin.

3 Q. How far away from them were you at that

4 time? How far away from them? How far away?

5 A. With Brett?

6 Q. Yes.

7 A. Oh, gosh, not that far. Maybe from where

8 I’m at to maybe the third row back.

9 Q. Okay. I’m done estimating distances, so

10 we’ll leave it at that.

11 All right. Is that the only incident that

12 you saw with Brett Barnes?

13 A. Yes.

14 Q. Did you see an incident with anybody else?

15 A. With Jordan Chandler.

16 Q. And when was that?

17 A. Asking about the year?

18 Q. Relative to the incident that you saw with

19 Brett Barnes.

20 A. God, I can’t even think of the year.

21 Probably ‘93.

22 Q. Was it toward the end of your employment

23 there?

24 A. Maybe -- maybe -- a little, maybe.

25 Q. And what did you see?

26 A. I was up in Mr. Jackson’s bedroom and I

27 was -- I was on the second -- the loft area, and I

28 was dusting. And I heard the chimes go off, so I 5309



1 knew somebody was coming into the bedroom.

2 Q. What does that mean, you heard the chimes go

3 off? Where were there chimes?

4 A. There’s like a sensor, like it rings.

5 They’re bells that ring when anybody’s coming into

6 Mr. Jackson’s room, or if you leave the room, the

7 chimes will go off.

8 Q. And when they go off, how long do they ring?

9 A. Until --

10 Q. If you walk through it, it will ring for how

11 long?

12 A. For a while. For a little while, until I

13 guess people are out of the area where you’re seen.

14 Q. So once you clear, does it stop?

15 A. It will stop after, yeah.

16 Q. And the chimes going off meant what to you?

17 A. That somebody was coming into the room.

18 Q. All right. Was that an unusual occurrence

19 while you were cleaning?

20 A. What, the chimes going off?

21 Q. Yes. Somebody coming into the room. If you

22 were cleaning there during the day, would that

23 startle you if that happened?

24 A. No.

25 Q. What did you do?

26 A. Well, I was upstairs, and I -- I heard

27 talking, like voices. So I knew it was probably

28 Michael and Jordie. 5310



1 Q. Now, “upstairs” means -- there’s a second

2 bed up there?

3 A. Yes.

4 Q. Like a loft you said?

5 A. A loft, uh-huh.

6 Q. Were you cleaning at that time?

7 A. Yes.

8 Q. Okay. Do you know if the bedroom door was

9 open when you heard the chimes?

10 A. I believe so.

11 Q. And what happened then?

12 A. I kind of looked down from the stairs, from

13 the stairs up there a little, and I saw Mr. Jackson

14 with Jordie, and they were changing their clothes.

15 Like -- I figured they were at the water fort. And

16 I looked down and I saw Mr. Jackson kissing on --

17 on Jordie.

18 Q. What part?

19 A. His cheek, and then his mouth, and his hand

20 was on his crotch.

21 Q. What was Jordie wearing at the time?

22 A. He had pants on.

23 Q. How long did that last?

24 A. I -- when I saw that, I was quiet, and I

25 can’t even say how long that lasted.

26 Q. What did you do?

27 A. I was kind of shocked, flushed, and I stood

28 quiet where I was at. 5311



1 Q. You didn’t say anything?

2 A. I didn’t say nothing.

3 Q. For you to go and leave that room where the

4 loft is, you would have to walk down the stairs,

5 would you not?

6 A. Yes.

7 Q. Would you have had to have walked past them?

8 A. Yes.

9 Q. All right. What did you do?

10 A. I stayed up there very quietly, I didn’t say

11 anything. I stood very quietly. And I waited for

12 them to leave the room.

13 Q. And did they leave the room?

14 A. Yes.

15 Q. How was Jordie Chandler dressed at the time?

16 A. I just remember he had pants on, and they

17 were changing shirts. He had pants on and so did

18 Mr. Jackson.

19 Q. And when you said his hand was on Jordie

20 Chandler’s crotch, on the outside of the pants or on

21 the inside of the pants?

22 A. On the outside.

23 Q. Was he kissing him the entire time that you

24 were watching?

25 A. From what I saw, yes.

26 Q. Where exactly were you at the time that you

27 heard the chimes?

28 A. Upstairs in the top loft. 5312



1 Q. And do you know where in that room?

2 A. Kind of by the stairs. By the stairs. I

3 was dusting the stairs.

4 Q. So right at the top landing?

5 A. Yes.

6 Q. Did you stay up there until Jordie Chandler

7 and Mr. Jackson left the room?

8 A. Yes.

9 Q. Did you then go downstairs?

10 A. Yes. After I heard the chimes go off, I

11 knew they had left, and I waited and then I left.

12 Q. How long after this happened did you leave

13 your employment with Michael Jackson?

14 A. Well, I left July. I don’t know, like, the

15 months. I know I left July 31st of ‘94.

16 Q. Did you ever see any incidents involving

17 Wade Robeson? You told us about Brett Barnes, and

18 Jordan Chandler, and Macaulay Culkin. Did you ever

19 see an incident involving Wade Robeson?

20 A. No.

21 Q. I started to ask you a bit ago about the

22 Jacuzzi. There’s a Jacuzzi that’s located in the

23 master bedroom suite. Describe for us where that

24 is.

25 A. When you go into Mr. Jackson’s room, right

26 when you go down the steps, there’s steps in his

27 room, there’s a rest room like on that side, like

28 right-hand side, where if you go around his bed, 5313



1 there’s another area where there’s another rest

2 room, and there’s a Jacuzzi.

3 Q. How large?

4 A. Oh, God, it’s big. It’s big.

5 Q. Would it hold more than one person?

6 A. Yes.

7 Q. Comfortably?

8 A. Yes.

9 Q. Was water kept in that Jacuzzi all the time?

10 A. No.

11 Q. What were your responsibilities with regard

12 to cleaning the Jacuzzi?

13 A. I would have to clean the Jacuzzi off and

14 on, run the water in it. But there were times when

15 I had to let the water out of the Jacuzzi.

16 Q. All right. And were there things in the

17 Jacuzzi on occasion?

18 A. Yes.

19 Q. Like what?

20 A. Like Mr. Jackson’s undershorts, and a little

21 boy’s undershorts.

22 Q. Do you know which boys had been staying

23 there during that time?

24 A. A lot of the little boys were staying there

25 at that time.

26 Q. You wouldn’t know which boy’s it was, the

27 undershorts?

28 A. Brett -- it could -- Brett. Jordie. 5314



1 Macaulay. That happened frequently.

2 Q. They’d actually be in the Jacuzzi in the

3 water?

4 A. They’d be in the water, or sometimes they’d

5 be on the floor by the Jacuzzi.

6 Q. And these were underpants?

7 A. Yes.

8 Q. And you could tell the difference between

9 the boy’s underpants and Mr. Jackson’s underpants?

10 A. Yes.

11 Q. Did you have to clean them?

12 A. Yes, I washed them.

13 Q. Did you, on occasion, wash the children’s

14 underwear as well?

15 A. At times, yes.

16 Q. If it was left behind?

17 A. Yes.

18 Q. You’d pick it up and wash it?

19 A. Yes.

20 Q. These four boys during the time that they

21 were staying at Neverland, how did their behavior --

22 how was their behavior?

23 MR. MESEREAU: Objection; vague.

24 MR. ZONEN: As to “behavior” or as to

25 “boys”? I’ll object to the objection as vague. Or

26 I’ll reask the question.

27 THE COURT: Well, it’s compound, I think.

28 MR. ZONEN: I’ll reask the question. 5315



1 THE COURT: All right.

2 Q. BY MR. ZONEN: During the period of time

3 that you were working as Mr. Jackson’s personal

4 maid, did you have an opportunity to observe the

5 behavior of the children who were frequent visitors

6 at Neverland Ranch?

7 A. Yes.

8 Q. And did that include the four boys that

9 we’re talking about so far?

10 A. Yes.

11 Q. Did it include other children who were

12 frequent visitors at Neverland Ranch?

13 A. Yes.

14 Q. All right. And I’m not asking you questions

15 about busloads of kids who would arrive for a day

16 and leave at the end of the day. I’m asking about

17 the ones who were Mr. Jackson’s personal guests and

18 who stayed for periods of time. Do you understand

19 that?

20 A. Yes.

21 Q. All right. Was there anything about that

22 behavior that was unique, in your mind?

23 MR. MESEREAU: Objection. Vague; relevance;

24 and leading.

25 THE COURT: The thing I’m having a problem

26 with is not the vague, but the fact that you’re

27 asking about all of the boys as oppose -- as to

28 their behavior. 5316



1 MR. ZONEN: I’ll make that easier.

2 Q. Macaulay Culkin, what was his behavior like

3 when he was at Neverland Ranch?

4 A. He was very, very wild.

5 Q. Describe what you mean by that.

6 A. For us maids?

7 Q. Yes.

8 A. He was a lot of work when he -- when he was

9 around there.

10 Q. What does that mean, “a lot of work”?

11 A. He was destructive. I mean, throwing

12 popcorn at Mr. Jackson. Soda, from the top, being

13 thrown at Mr. Jackson’s head.

14 Q. The top of what?

15 A. At the top of the theater. Like a

16 projection room way up on the top.

17 Q. Did you actually witness that?

18 A. Yes.

19 Q. So there’s apparently two stories at the

20 theater?

21 A. Yes.

22 Q. And is the upper story open in such a way

23 that you can actually have contact with somebody

24 below you?

25 A. Yes. They will -- yes.

26 Q. Open in what way?

27 A. There were windows up in the top-top. I

28 don’t know if you call it a -- I don’t know if it 5317



1 was called maybe a viewing room. And if you were up

2 there, you had to take a stairway to get up to the

3 top, and you could open these windows.

4 Q. What did you see him do?

5 A. He threw sodas. I had just made popcorn,

6 because he asked for popcorn, and he wanted a soda.

7 So I gave it to him. And he went upstairs, and he

8 dumped it on Mr. Jackson’s head, along with the

9 popcorn.

10 Q. All right. Did that create a mess?

11 A. Yes.

12 Q. Mess for you to clean up?

13 A. Yes.

14 Q. Was that a unique event with regard to Mr.

15 Macaulay Culkin?

16 A. Was it unique?

17 Q. Well, were you always cleaning up after him?

18 A. Yeah, but certain kids made it worse. And

19 he was one of them.

20 Q. All right. Which other kids were a problem?

21 A. Jordie Chandler.

22 Q. What did Jordie do?

23 A. Um --

24 Q. Before I get to Jordie Chandler, let me ask

25 you another incident about the popcorn and the soda.

26 What did Mr. Jackson say to Macaulay Culkin

27 when he poured popcorn and soda from the second

28 story on top of him? 5318



1 MR. MESEREAU: Objection; foundation.

2 THE COURT: Overruled.

3 You may answer.

4 Q. BY MR. ZONEN: Go ahead.

5 A. It was like a joke. It was funny.

6 Q. He didn’t discipline him?

7 A. No.

8 Q. He didn’t tell him, “That’s inappropriate”?

9 A. No.

10 Q. Nor did he help you clean up, I assume.

11 A. No.

12 Q. And Jordie Chandler, describe his behavior

13 for us during the time that he was there.

14 A. He was rude.

15 Q. In what way?

16 A. Very demanding.

17 Q. In what way demanding?

18 A. Like if I was in the laundry room washing

19 clothes, he’d come and say, “Where’s my shirt?” You

20 know, “I want my shirt.” Just not nice to where you

21 ask, “Do you have my shirt?” Just kind of “Give it

22 to me now,” like that.

23 Q. Was his behavior like that fairly

24 consistently during the entire time that you were

25 exposed to him?

26 A. Yes.

27 Q. Brett Barnes, how did he behave?

28 A. That little boy, I -- he was not a rude 5319



1 little boy. He was pretty well-behaved.

2 Q. The entire time?

3 A. Yes.

4 Q. Wade Robeson, how did he behave?

5 A. He was kind of wild, too. Not as much as

6 Macaulay. Just wild, tear everything up. Leave

7 messes all over, you know. Just --

8 Q. Were you ever encouraged to discipline these

9 kids in any way?

10 A. No.

11 Q. Were you discouraged from doing so?

12 A. Yes.

13 Q. In what way?

14 A. Well, I was told by Norma Stakos that --

15 MR. MESEREAU: Objection; hearsay.

16 MR. ZONEN: Her state of mind to explain her

17 behavior.

18 THE COURT: Sustained.

19 Q. BY MR. ZONEN: Did you ever go up to any

20 child and say, “Don’t do that. That’s

21 inappropriate”?

22 A. No.

23 Q. Did you ever see any employee or hear of any

24 employee go up to a child and say, “Don’t do that.

25 That’s inappropriate”?

26 A. No.

27 Q. Other than Brett Barnes, was the behavior of

28 the three children that you described consistently 5320



1 bad the entire time they were there?

2 A. Yes.

3 Q. Did that include times when they were in the

4 presence of Michael Jackson?

5 A. Yes.

6 Q. Did you ever hear Michael Jackson discipline

7 them in any way or tell them not to behave in such a

8 destructive fashion?

9 A. No.

10 Q. Did you tell anybody about the events that

11 you saw, the three incidents that you testified to

12 involving those three children, Brett Barnes,

13 Macaulay Culkin and Jordie Chandler?

14 A. Yes.

15 Q. Who was the first person you discussed that

16 with?

17 A. Lawyers I had. Lawyers.

18 Q. The lawyer who was representing you?

19 A. Yes.

20 Q. Which lawyer was that?

21 A. Michael Ring.

22 Q. Had you told anybody about those events

23 prior to that?

24 A. I believe I talked to Kiki Fournier. I

25 didn’t even know -- I think it might have been after

26 I -- it might have been after I had left.

27 Q. Now, you worked there, I believe you said,

28 about four years; is that correct? 5321



1 A. Yes.

2 Q. All right. Why did you leave there?

3 MR. MESEREAU: Objection; relevance.

4 THE COURT: Overruled.

5 You may answer.

6 THE WITNESS: When Mr. Jackson had that

7 Jordie Chandler molestation case, whatever,

8 bodyguards were brought -- brought to the ranch.

9 They weren’t the regular security people. These

10 people were called OSS, Office of Special Services.

11 And there were a lot of these guys, and they started

12 harassing --

13 MR. MESEREAU: Objection. Narrative;

14 nonresponsive.

15 THE COURT: Sustained.

16 Q. BY MR. ZONEN: Well, “OSS” stands for Office

17 of what?

18 A. Of Special Services.

19 Q. All right. Who were these people? Do you

20 know their names?

21 A. There was one, Jimmy Van Norman. Tony

22 Coleman. Marcus Johnson. Jerome Johnson.

23 Q. Were these people armed with weapons?

24 A. Yes. Yes.

25 Q. And they came to the ranch after the

26 commencement of the Jordan Chandler investigation?

27 A. Yes.

28 Q. Did you know when the Jordan Chandler 5322



1 investigation began?

2 A. Yes.

3 Q. Was there a search that was conducted at

4 Neverland by Los Angeles Police Department?

5 A. Yes.

6 Q. Were you present at the time that happened?

7 A. I -- yes, but I -- yes, but I had called in

8 sick that day and I had to go back to the ranch.

9 Q. You had called in sick that day?

10 A. I was sick on that day.

11 Q. By coincidence, or you knew there was going

12 to be a search?

13 A. No, I didn’t know. I did not know. I just

14 was sick and I called in sick.

15 Q. And had anybody heard of anything in advance

16 of that search?

17 A. No.

18 Q. There had been no talk about that at all?

19 A. No.

20 Q. Fair to say there was probably considerable

21 talk thereafter?

22 A. Yes.

23 Q. Were you interviewed by anybody from law

24 enforcement during this investigation?

25 A. Um --

26 Q. I think the question that I asked was, had

27 you been interviewed by anybody from law enforcement

28 during the course of that investigation? 5323



1 A. I believe so.

2 Q. All right. Did you become aware of the fact

3 that there had been a lawsuit filed on behalf of

4 Jordan Chandler?

5 A. Yes.

6 Q. Were you called to testify in a deposition?

7 A. Yes.

8 Q. And did you, in fact, give a deposition to

9 attorneys representing both Mr. Jackson and Mr.

10 Chandler?

11 A. Yes.

12 Q. Do you remember who those attorneys were?

13 A. Larry Feldman, Howard Weitzman, and some

14 lady named, I think, Jan Faye or --

15 Q. Were you still employed at Neverland during

16 that time?

17 A. Yes.

18 Q. During the course of that deposition, were

19 you asked if you observed any behavior by Michael

20 Jackson directed toward Jordie Chandler or anybody

21 else that you thought was inappropriate or any form

22 of sexual behavior?

23 A. Yes.

24 Q. How did you answer that question?

25 A. I didn’t tell the truth.

26 Q. What did you say?

27 A. I said I didn’t see anything.

28 Q. All right. Why did you say that in this 5324



1 deposition?

2 A. Because when -- when I had taken over the

3 job for Mr. Jackson’s room, Mr. Jackson had

4 threatened me.

5 Q. What did he say to you?

6 A. He had told me, “You know, Adrian, if you

7 ever say or you do something that I don’t like, all

8 I have to do is tell Bill Bray or Norma Stakos, and

9 they will take care of you, but it wouldn’t come

10 from me. “

11 Q. Were you concerned about that statement?

12 A. I was very concerned with that.

13 Q. That was what, three years earlier?

14 A. That was right when I took the bedroom.

15 Q. Why did you continue to work there after

16 that statement?

17 A. I don’t know. I -- I got caught up, I

18 guess, in -- my husband was laid off, and we had a

19 house payment, and I just stayed.

20 Q. What was your salary at Neverland?

21 A. I worked 40 hours a week, but I started at

22 7.50 an hour.

23 Q. What was your salary at the time that you

24 left Neverland?

25 A. I left at 8.86 an hour.

26 Q. In the four years, your salary went up $1.80

27 an hour?

28 A. Yes. 5325



1 Q. What hours did you maintain at Neverland?

2 What was your schedule?

3 A. Sometimes 8:30 to 5:00. Sometimes 8:30 till

4 one o’clock in the morning. You never knew, kind

5 of, when you were going to go home.

6 Q. Every day you went to Neverland, you didn’t

7 know if you would go home at 5:00?

8 A. Right.

9 Q. How often was it that you were asked to stay

10 after 5:00?

11 A. There were a lot of times.

12 Q. In a week period, how many days in that week

13 would you expect to stay after 5:00?

14 A. You just never knew. It depended if there

15 were guests. Sometimes it could have been two

16 times. Three times. You just didn’t know when you

17 were going to go home.

18 Q. And you could stay actually until the early

19 morning?

20 A. Yes.

21 Q. And then come back the next day at 9:00?

22 A. Yes.

23 Q. Were you ever asked to work weekends?

24 A. Yes.

25 Q. If you were asked to work on an evening or

26 on a weekend, and you didn’t want to, would you just

27 simply say, “I can’t do that tonight”?

28 A. No. 5326



1 Q. Why?

2 A. Because you were scheduled and you had to

3 show up.

4 Q. Now, you started talking about OCC -- OSS.

5 A little dyslexia here, excuse me. OSS. And you

6 named the people who were involved in OSS; is that

7 right?

8 A. Yes.

9 Q. Up until that time, had there been people

10 armed at Neverland?

11 A. No.

12 Q. Were each of those people armed with

13 weapons?

14 A. I believe so.

15 Q. How was their behavior toward you?

16 A. They were terrible.

17 Q. How did they behave toward you? What did

18 they do?

19 A. Jimmy Van Norman would --

20 MR. MESEREAU: Objection; vague as to time

21 and individuals.

22 Q. BY MR. ZONEN: Let’s begin with Jimmy, then.

23 I’ll withdraw the question. Ask you specifically

24 about Jimmy Van Norman. All right.

25 And from the time that he came on working

26 until the time you quit was approximately how many

27 months?

28 A. I would say maybe six or seven months, 5327



1 maybe.

2 Q. During that time, was his behavior toward

3 you fairly consistent?

4 A. Yes.

5 Q. And describe things he would do to you, or

6 with you.

7 A. He called my home one morning when I was

8 still kind of asleep, and he woke me up with a phone

9 call. And I was going to take my son to school that

10 day. It was a Monday, I remember. And he said,

11 “Adrian” --

12 MR. MESEREAU: Objection; hearsay.

13 MR. ZONEN: Goes to her state of mind and

14 explaining her conduct.

15 THE COURT: The state of mind being why she

16 left?

17 MR. ZONEN: And commenced a lawsuit.

18 THE COURT: All right. I’ll overrule the

19 objection.

20 Q. BY MR. ZONEN: All right. What happened in

21 this call?

22 A. He called my home early in the morning, and

23 he said, “Adrian?” And I said, “Yes?” And he says,

24 “You sound different.” And I said, “Well, I just

25 woke up” You know, I hadn’t had coffee. My voice

26 was a little bit rough.

27 And he says something about what kind of

28 underwear I wear, and when was the last time I got 5328



1 “it”; that apparently I needed it.

2 Q. Did you recognize the voice when he called?

3 A. Yes, I did.

4 Q. Did he have to identify himself?

5 A. No, he didn’t. But I knew it was him.

6 Q. What did you do when you said that?

7 A. I changed the subject, because I thought

8 maybe Mr. Jackson needed something and maybe he was

9 just calling to -- to get Mr. Jackson to talk to me

10 or something. I didn’t know.

11 Q. Did he ultimately communicate a message to

12 you from Mr. Jackson?

13 A. Sometimes -- not him, but sometimes the

14 other ones would.

15 Q. But on that occasion, that particular call,

16 did he ultimately communicate a communication from

17 Mr. Jackson?

18 A. No, he didn’t.

19 Q. Did he ever tell you why he was calling?

20 A. No.

21 Q. Okay. Did you hang up that phone call?

22 A. Actually, he got another call, and the phone

23 was ringing in the back, which I knew was a Merlin

24 phone, because I knew the sounds of the phones, and

25 he said, “Darn, I’ll call you right back.”

26 Q. Did he call you right back?

27 A. He didn’t call back.

28 Q. Had you received more than that one phone 5329



1 call from this person, Van Norman?

2 A. I did receive another call later, and I --

3 and I don’t know the month. Right now I can’t think

4 of the month. And it was Jimmy, and he --

5 MR. MESEREAU: Objection; hearsay.

6 MR. ZONEN: Same reason.

7 THE COURT: Well, you know, I’m not getting

8 to her state of mind either. All of that testimony

9 I let in for her state of mind I let in at your

10 request for her state of mind.

11 MR. ZONEN: Let me withdraw the last

12 question and let me move on.

13 THE COURT: I need an offer as to why I’ve

14 let other testimony in.

15 MR. ZONEN: Let me withdraw that question

16 right now and move on.

17 Q. Did you quit your job at Neverland?

18 A. Yes, I did quit.

19 Q. Why did you quit?

20 A. Because I was being sexually harassed. I

21 had death threats. I was being chased in the house

22 with a stun gun. More like abuse. And mentally I

23 could not deal with it.

24 Q. Was this all the new collection of guards

25 that had been brought in?

26 A. Yes.

27 Q. Did you ever talk with Mr. Jackson about

28 what was going on? 5330



1 A. I don’t believe so, with that.

2 Q. And why not?

3 A. I believe he left. He had left later, maybe

4 in February. And Marcus Johnson left with him with

5 the bodyguards, but there was still bodyguards

6 around, so Mr. Jackson wasn’t really around where

7 you could tell him, so --

8 Q. What made you decide to file a lawsuit

9 against Mr. Jackson?

10 A. When I realized that I didn’t have to work

11 in a job where I was being sexually harassed, and

12 abused, and having to deal with death threats and --

13 Q. Did you talk with Mr. -- who was your

14 attorney? Who represented you?

15 A. Actually, we had Michael Gray and Michael

16 Barber, and we had Michael Ring and Kelly Frances.

17 Q. All from the same firm?

18 A. At the time, yes.

19 Q. Who was the lead attorney in that case?

20 A. Michael Barber. And Michael Ring (sic)

21 ended up, I guess, getting out of it. I don’t know

22 what happened there, but Michael Ring ended up

23 taking over.

24 Q. Michael Ring?

25 A. Michael Ring.

26 Q. Was he the one who tried the case?

27 A. Yes.

28 Q. That case went on for quite some number of 5331



1 months, didn’t it?

2 A. Yes, it did.

3 Q. Did you quit your job before or after

4 seeking counsel from Michael Ring or any other

5 lawyer?

6 A. I believe I quit my job first while I went

7 out on doctor’s care.

8 Q. You were not the only plaintiff in that

9 suit, were you?

10 A. No.

11 Q. Who were the other plaintiffs?

12 A. There was Melanie Bagnall, Kassim Abdool,

13 Sandie Domz, and Ralph Chacon.

14 Q. Was there a counterclaim that was filed

15 against you? Were you accused of anything?

16 A. Yes.

17 Q. What were you accused of?

18 A. I believe of -- of, I think, taking Super

19 Soaker water guns. Taking candy, balloons, posters,

20 sunglasses.

21 Q. Were you accused of taking a drawing?

22 A. Yes.

23 Q. All right. Tell us about the drawing.

24 A. The drawing, actually, I had found it in the

25 trash outside by the rec room. It was a trash area

26 there. And I had taken trash out from the house,

27 from the kitchen, and I saw it in there. There was

28 a bag out there, and it was just open and it was a 5332



1 sketch. It wasn’t a big sketch. It was a small

2 sketch.

3 Q. About how big?

4 A. Oh, gosh. Probably -- I don’t even know.

5 Maybe about that big. Maybe like that. It wasn’t

6 very big.

7 Q. Six inches by five inches --

8 A. Yeah.

9 Q. -- something like that?

10 MR. MESEREAU: Objection; leading.

11 THE WITNESS: Yeah, something like that.

12 THE COURT: Sustained.

13 Q. BY MR. ZONEN: Can you give us an estimate

14 on the record, the size of it? Because you were

15 holding your hands out.

16 A. Maybe three-by-five. I don’t know.

17 Something like that.

18 Q. All right. You said you found it in the

19 trash?

20 A. Yes.

21 Q. Where?

22 A. Outside. Outside by the rec room. There

23 was a trash area back there.

24 Q. Did you know who did the drawing?

25 A. I didn’t know who did it, but I thought --

26 well, maybe. I was really -- I don’t know who did

27 it.

28 Q. Who did you believe did it? 5333



1 A. Um --

2 MR. MESEREAU: Objection; calls for

3 speculation.

4 MR. ZONEN: Explains why she took it.

5 THE COURT: Actually, you know, we’re having

6 the same problem that when Mr. Mesereau was asking

7 questions. You seem to be going into the

8 allegations in the Complaint, which -- the facts of

9 the lawsuit, which I’ve said we can’t do. So I’m

10 going to ask you to go into a different area.

11 MR. ZONEN: All right.

12 Q. After many months in trial, was there a

13 resolution to that case?

14 A. Yes.

15 Q. What happened?

16 A. We lost.

17 Q. Each of you?

18 A. Yes.

19 Q. As to all counts?

20 A. Yes.

21 Q. Was there a judgment against you?

22 A. Yes.

23 Q. For a great deal of money?

24 A. Yes.

25 Q. How much?

26 A. 1.6 million.

27 Q. Did you go into bankruptcy afterward?

28 A. No. 5334



1 Q. So that debt still exists today?

2 A. Yes.

3 Q. You owe Mr. Jackson $1.6 million?

4 A. Yes.

5 Q. Is that for all the attorney’s fees and the

6 court costs?

7 A. Yes.

8 Q. Have you paid any part of that?

9 A. A lien was put on my paycheck when I was

10 working at Sears and there was money taken out, but

11 I don’t recall how much.

12 Q. Okay. Is there a lien currently on your

13 paycheck where you currently work?

14 A. For the lawsuit?

15 Q. For this lawsuit.

16 A. No.

17 Q. Do you anticipate that will happen?

18 A. I don’t --

19 MR. MESEREAU: Objection. Calls for

20 speculation; relevance.

21 THE COURT: Sustained.

22 Q. BY MR. ZONEN: Are you concerned that that

23 will happen?

24 MR. MESEREAU: Same objection.

25 THE COURT: Sustained.

26 Q. BY MR. ZONEN: Had there been a deposition

27 that was taken of you prior to the commencement of

28 that lawsuit? 5335



1 A. Do you mean like before, with Jordie

2 Chandler?

3 Q. Yes.

4 A. Yes.

5 Q. In the course of that deposition, did you

6 disclose the events that took place that you’ve

7 disclosed to this jury?

8 A. No, I did not.

9 Q. Are you talking about the Jordie Chandler

10 lawsuit, deposition?

11 A. Yes.

12 Q. Was there a subsequent -- another deposition

13 that was done in the lawsuit of your case, Kassim

14 Abdool and everyone else against Michael Jackson and

15 everyone else?

16 A. Yes.

17 Q. In that deposition, did you disclose what

18 you saw?

19 A. Yes, I did.

20 Q. At some point during the course of that

21 lawsuit, either before the commencement of trial or

22 during, were you involved with others in selling a

23 story to a tabloid?

24 A. Yes.

25 Q. Which tabloid was it?

26 A. Actually, there was a man named Gary Morgan,

27 and he was from Splash.

28 Q. What is Splash? 5336



1 A. I don’t know -- I don’t know if he’s

2 affiliated with different -- I’m not even really

3 sure. I just know that he sold stuff.

4 Q. But it was a tabloid?

5 A. I believe so.

6 Q. Did you actually have an interview with

7 them?

8 A. Yes.

9 Q. Did they give you money?

10 A. Me personally?

11 Q. Yes.

12 A. They were -- well, can I explain, because I

13 don’t --

14 Q. Who did the interview? In other words, how

15 many of the plaintiffs involved that you’ve

16 identified did this interview?

17 A. Everybody was there, including our attorney.

18 Q. Did he participate in the interview as well,

19 your attorney?

20 A. He was there with -- yeah.

21 Q. Who is it who negotiated what would be paid?

22 A. I believe Michael Ring.

23 Q. Did you have any say in that at all?

24 A. No, I didn’t.

25 Q. Was it understood that some of the money

26 would be going to you, or all of the money?

27 A. From what I recall, all of the money went

28 into a trust in Michael Ring’s name in order to 5337



1 fight the lawsuit against Mr. Jackson.

2 Q. Did any of that money actually go to you?

3 A. At one time, yes.

4 Q. And how much was that?

5 A. A thousand dollars.

6 Q. Do you know how much money in total was

7 turned over to Michael Ring?

8 A. I would honestly -- I mean, my best

9 recollection, I’d say probably maybe 32,000 or more.

10 Q. And did that go to finance the lawsuit?

11 A. Yes.

12 Q. Were you involved in another lawsuit at that

13 time or prior to that time?

14 A. Yes.

15 Q. What was that?

16 A. Well, it had to do with my husband’s

17 sister-in-law.

18 Q. And what happened?

19 A. My husband was -- my husband had two half

20 brothers. They had different fathers. And one of

21 the half brothers was real close with my husband,

22 and he ended up diabetic and he lost his eyes and

23 his kidneys and they had him on dialysis. He went

24 blind.

25 And he was married, and his wife and him, I

26 guess they had a very -- a relationship that wasn’t

27 very good. From what I understand, she started

28 fooling around with a radio talk show guy, and she 5338



1 got pregnant --

2 Q. Tell us what happened with regard to the

3 lawsuit.

4 A. I’m sorry.

5 Q. Who was suing who?

6 THE COURT: How many lawsuits are we going to

7 cover?

8 (Laughter.)

9 THE WITNESS: I’m sorry.

10 We got sued.

11 Q. BY MR. ZONEN: Okay. For what? The

12 resolution of his estate?

13 A. Actually, my husband was left as a

14 beneficiary, and my husband got kind of fed up with

15 her. And that was a family thing on their side of

16 the family. And I kind of just got drug into it,

17 but --

18 Q. Did you have counsel representing you in

19 this lawsuit?

20 A. No, we didn’t.

21 Q. Was it a jury trial?

22 A. No.

23 Q. Was it a court trial?

24 A. Yes.

25 Q. You were representing yourself?

26 A. Yes.

27 Q. Was the other side represented by counsel?

28 A. Yes. 5339



1 Q. Was there a judgment entered against you or

2 your husband?

3 A. I believe 17,000 from each one of us.

4 Q. Was this from money from the estate?

5 A. Yes.

6 Q. Did you pay that?

7 A. I made payments, and I don’t even recall how

8 much I made payments for. And then I couldn’t do it

9 no longer.

10 Q. All right. Did you lose your home in this

11 process?

12 A. No. We sold our home.

13 Q. And are renting today?

14 A. Yes.

15 Q. Do you know anybody in the Arvizo family?

16 Do you know that name?

17 A. No.

18 Q. Do you know a Janet Arvizo?

19 A. No.

20 Q. Gavin Arvizo?

21 A. No.

22 Q. Star Arvizo?

23 A. No.

24 Q. Davellin Arvizo?

25 A. No.

26 Q. I had asked you earlier about a drawing.

27 Was that drawing sold to someone during the course

28 of your litigation? 5340



1 A. Yes.

2 Q. And who was it sold to?

3 A. Well, actually, at Michael Ring’s office,

4 our attorney, Gary Morgan had asked if we had any

5 photographs or pictures or something, and I said,

6 “Well,” you know, “there’s a sketch that I found, I

7 found in the trash.” I told him, “You can have it.”

8 It was just a sketch. It wasn’t a -- it wasn’t a

9 Polaroid, you know, it was just ink. And I gave it

10 to him. And I guess he went and sold it.

11 Q. Who sold it?

12 A. Gary Morgan.

13 Q. And Gary Morgan is who?

14 A. He’s from Splash.

15 Q. Did you get any money for that?

16 A. Actually, I think that when -- I believe

17 that’s where that thousand dollars might have come

18 from.

19 Q. From the sale of that picture?

20 A. I think so.

21 Q. Did you represent that as a drawing that had

22 been done by Michael Jackson?

23 A. I believe I might have said it, that I

24 thought it was done by Michael Jackson.

25 Q. Did you believe it was?

26 A. I did.

27 Q. Why did you have it in the first place? Why

28 did you take it? 5341



1 A. Because I found it in the trash and I

2 figured it was in the trash, so if something’s in

3 the trash, I mean, somebody might not have wanted

4 it.

5 Q. Did you take it because you believed he did

6 it or did you take it because you liked it?

7 A. I took it because I liked it, because I

8 liked to draw and I thought it was pretty neat.

9 Q. I’d like to show you a few exhibits, if I

10 may.

11 Counsel, you’ve seen these.

12 MR. MESEREAU: Yeah.

13 Q. BY MR. ZONEN: I’d like to show you Exhibit

14 797 and 798. What are those two exhibits, 797 and

15 798?

16 A. They’re -- they’re -- it’s an exhibit of a

17 note that Mr. Jackson had given me on an index card,

18 along with $300.

19 Q. Okay. Those are the two exhibits. One is

20 the note and the other is what?

21 A. The $300.

22 Q. It’s not actually $300 you have in front of

23 you, is it?

24 A. Half.

25 Q. Well, it’s a Xerox or a photocopy; is that

26 right?

27 A. Right, a Xerox copy.

28 Q. Explain what that is. Where did that money 5342



1 come from?

2 A. Well, I have to tell a story in order for

3 that to --

4 Q. Let me ask you a question and see if I can

5 lead you in that direction. Who gave you the $300?

6 A. Mr. Jackson.

7 Q. When did he give you that $300?

8 A. After he had read my transcript from the

9 Jordie Chandler deposition.

10 Q. All right. How did he happen to have your

11 transcript from the Jordie Chandler deposition?

12 MR. MESEREAU: Objection; foundation.

13 THE COURT: Sustained.

14 Q. BY MR. ZONEN: Did you give him that

15 transcript?

16 A. Yes, because he called me at home and asked

17 me --

18 MR. MESEREAU: Objection. Nonresponsive;

19 move to strike.

20 THE COURT: I’ll strike after, “Yes.”

21 Q. BY MR. ZONEN: All right. Did you have a

22 conversation with Mr. Jackson about your testimony

23 during the Jordie Chandler deposition?

24 A. Yes, I did.

25 Q. And that was the deposition you previously

26 told us wherein you denied that anything had

27 happened that you had seen; is that correct?

28 A. That’s correct. 5343



1 Q. All right. In the course of that

2 conversation with Mr. Jackson, did he ask you if you

3 had a copy of that transcript?

4 A. Yes, he did.

5 Q. Did he ask to see it?

6 A. Yes, he did.

7 Q. Did you give it to him?

8 A. Yes. Yes, I did.

9 Q. When did you give it to him? How long after

10 that telephone conversation was it that you gave it

11 to him?

12 A. I believe it might have been the next day.

13 Q. And how did you happen to have a copy of the

14 transcript?

15 A. I had gotten it earlier than usual, than the

16 usual wait for a transcript, and I believe I -- I

17 believe I had called Jan, I think her name was Jan

18 Faye, and then they had sent it to me, but I got it

19 earlier than you would wait for a deposition.

20 Q. Had you already read that transcript before

21 you gave it to Mr. Jackson?

22 A. Maybe parts of it.

23 Q. What was your next conversation with Mr.

24 Jackson?

25 A. Are you talking about, like, on the phone

26 or --

27 Q. Well, did you have a follow-up conversation

28 about that transcript? 5344



1 A. Yeah. He told me that he had read it.

2 Q. Did he give it back to you, the transcript?

3 A. Actually, I got it back. I told him I was

4 going to take it.

5 Q. Did he give you anything?

6 A. Yes, he did.

7 Q. What did he give you?

8 A. The $300 and the little note.

9 Q. And the note says what?

10 A. It said, “Adrian, thanx for everything.”

11 Q. And the $300 were in what denominations?

12 A. In 100-dollar bills.

13 Q. Did you see anything unique about the

14 hundred-dollar bills?

15 A. Yes, I did.

16 Q. What was that?

17 A. The serial numbers were all, like, in

18 sequence, which was really neat, because I had never

19 seen anything like that, and I thought that was

20 really neat.

21 Q. How did you happen to have a Xerox copy of

22 them or a photocopy?

23 A. Because -- I thought it was so neat that I

24 photocopied it, because I had never seen anything

25 like that, you know, the sequence of bills like

26 that.

27 Q. Did you keep the money?

28 A. Actually, when -- when he gave it to me, I 5345



1 called him up at the theater, he was in the theater,

2 and I told him I didn’t want the money. And he

3 asked me why. And I said, “I just” -- “I don’t want

4 the money.”

5 Q. He didn’t give you the money in person?

6 A. He gave me the money, but it was in an index

7 card and it was folded.

8 Q. Okay.

9 A. And he told me to read it, to open it. It

10 was in his bedroom. He handed it to me in his room.

11 And I didn’t open it right away, because I was

12 cleaning.

13 And he kept saying, “Open it, open it, open

14 it.” And I opened it after he left the room, and I

15 saw the $300 and the note was all attached.

16 Q. And then you called him?

17 A. And I called them. He went to the theater

18 and I called him.

19 Q. All right. What did you say to him?

20 A. And I told him, “I can’t take that money.”

21 And he said, “Why?” And I said, “I just can’t take

22 it.” And he said -- he kept asking, “Why?” And

23 then he said, “Well, then give it to your son.”

24 Q. Did you do so?

25 A. I ended up giving my son some of the money,

26 yeah.

27 Q. Did you keep the balance of it?

28 A. I kept some money. I don’t even recall how 5346



1 much.

2 Q. The Xeroxes that you’re looking at, the one

3 of the note itself, does that accurately reproduce

4 the note?

5 A. Yes.

6 Q. All right. Now, the other one that shows

7 the three hundred-dollar bills, can you tell us why

8 it only shows half of the $100 bills?

9 A. I don’t understand the question.

10 Q. Well, as you look at that exhibit, do you

11 see that only half of each $100 bill is depicted in

12 that Xerox or that photocopy? Am I right?

13 A. Yeah, you’re right.

14 Q. And tell me why that is. Tell me why the

15 Xerox doesn’t show the entire $100 bill.

16 MR. MESEREAU: Objection; foundation.

17 MR. ZONEN: Withdraw that question.

18 Q. Do you know why that is? When you -- go

19 ahead.

20 A. Actually, when I photocopied, I photocopied

21 both sides, you know, like the front side of the

22 bills and then the back side of the bill. But in

23 what I turned over in my deposition, the whole bills

24 were there. I don’t know why it’s just half.

25 Q. You’ve never seen that before?

26 A. I’ve never seen this before.

27 Q. All right. To the extent that those are

28 three $100 bills with consecutive numbers, do they 5347



1 appear to be the same $100 bills?

2 A. Yes.

3 Q. And they are, in fact, $100 bills with

4 consecutive numbers; is that correct?

5 A. Yes.

6 MR. ZONEN: I move to introduce both of

7 those exhibits into evidence.

8 MR. MESEREAU: I’ll object; no foundation.

9 She did not recognize the document.

10 THE COURT: I’ll admit the documents.

11 MR. ZONEN: Thank you.

12 Q. I’d like to show you some additional

13 photographs, if I may.

14 MR. MESEREAU: Could I see those?

15 Q. BY MR. ZONEN: Showing you a photograph

16 previously identified as 793, do you recognize the

17 person in that photograph?

18 A. Kind of looks like Brett Barnes, but I’m not

19 sure.

20 Q. Do you believe that might be Brett Barnes?

21 A. Kinda, yeah.

22 Q. Let me show you the photograph in 795.

23 Let’s start with 794. Two different

24 photographs. The first with the child on the top,

25 and the second with a number of children on the

26 bottom. Start with the photograph with the child on

27 the top. Do you know who that is?

28 A. That’s Brett Barnes. 5348



1 Q. And then the photograph on the bottom, do

2 recognize any of the four people?

3 A. I can’t -- no. I can’t tell if that’s

4 Brett. He was little. I just --

5 THE REPORTER: I’m sorry, I can’t hear you.

6 Q. BY MR. ZONEN: Speak into the microphone.

7 A. The first photo I believe is Brett Barnes.

8 The second one I can’t really tell.

9 Q. Let me show you Exhibit 795. Do you

10 recognize anybody in that photograph?

11 A. Brett Barnes.

12 Q. And where is Brett Barnes in that photo?

13 A. Right here.

14 Q. All right. Who is he sitting next to in

15 that photograph?

16 A. Mr. Jackson.

17 Q. Do you know the other people in that

18 photograph?

19 A. I think it’s Carly in the middle. They look

20 different, though, from when I seen them.

21 Q. Carly is the middle person?

22 A. Yeah, the sister of Brett.

23 Q. And the mother to her on the right side of

24 her?

25 A. Right.

26 THE COURT: We’re going to break a little

27 early. Take our afternoon break.

28 (Recess taken.) 5349



1 THE COURT: Go ahead.

2 MR. ZONEN: I have just a couple more

3 questions.

4 Q. Is there a wine cellar at Neverland?

5 A. Yes.

6 Q. And where is the wine cellar?

7 A. It’s in the rec room, the recreation room.

8 Q. All right. Is that sometimes called the

9 arcade?

10 A. Yes.

11 Q. That’s the building that’s different from

12 the residence?

13 A. Yes.

14 Q. Is there a door that secures the wine

15 cellar?

16 A. Yes.

17 Q. Is that door kept locked, or was it kept

18 locked during the time that you worked there?

19 A. It was always locked.

20 Q. Was it a key that opened that door or a

21 combination lock?

22 A. It was a key.

23 Q. And do you know where the key was kept?

24 A. In the maids’ room.

25 Q. And where was the maids’ room?

26 A. In the main house.

27 Q. In the main house?

28 A. Yes. 5350



1 Q. Was there more than one key to the door?

2 A. I believe there was.

3 Q. Did you ever have occasion to go down into

4 the wine cellar?

5 A. Yes.

6 Q. For what reason?

7 A. To pick it up, clean. Just to make sure

8 everything was cleaned up in there.

9 Q. And to do that, you have to first go get the

10 key?

11 A. Right.

12 Q. All right. The room where the key was kept

13 at that time, was that a room that was open to

14 anybody in the public?

15 A. Well, it was the maids’ room. The maids

16 were usually in there. I mean, somebody could walk

17 in there.

18 Q. But it wasn’t a room that was generally one

19 of the rooms on tour when people took a tour of

20 Neverland?

21 A. No.

22 Q. Was it a room that somebody lived in or

23 simply worked in? You said maids’ room. What is

24 the maids’ room?

25 A. The maids’ room is just like where the maids

26 would go to take a break. It had a rest room and --

27 Q. Do you know if there were any other keys at

28 that time? 5351



1 A. I believe so.

2 Q. And do you know who else had those keys?

3 A. I believe security at that time had -- in

4 their office, they had a key to that.

5 Q. You would pick up in the wine cellar on

6 occasion?

7 A. Yes.

8 Q. What would require cleaning in the wine

9 cellar? What do you mean by “pick up”?

10 A. Like, to go in there and to make sure that

11 everything is -- sometimes you would have to brass.

12 There was a lot of brass out there, so we’d have to

13 brass, like, the sinks. So they had -- the faucets

14 were of brass.

15 Q. All right. Cleaning is what you mean?

16 A. Just cleaning, yeah.

17 Q. I’m going to show you two photographs

18 already shown to counsel. These two photographs are

19 No. 786 already in evidence, and No. 799 for

20 identification, not yet in evidence.

21 No. 786, first of all, take a look at this

22 photograph and tell us what that is.

23 A. That’s Mr. Jackson’s bedroom where the

24 Jacuzzi is.

25 Q. Is that the Jacuzzi that you were referring

26 to when you were describing having to clean that

27 Jacuzzi?

28 A. Yes. 5352



1 Q. 799, tell us what this photograph is.

2 A. This is the theater.

3 Q. Now, can you actually see windows up on that

4 far wall on the theater?

5 A. Actually, you have the projection room right

6 here, and there was a window right here, a room, a

7 bedroom. There was two bedrooms. There was one on

8 this side, and there was one I believe on the other

9 side.

10 And there was an area where you go up some

11 stairs on the side and would take you up, up high

12 where you’d be like in a viewing room. And the

13 viewing room would have -- I’m trying to think if

14 that’s it up there.

15 Q. You’re pointing right now to what?

16 A. I believe that is probably the viewing room

17 up above. It was up above the bedrooms.

18 Q. You were previously describing testimony of

19 popcorn and Coke being thrown through windows

20 above --

21 A. Right.

22 Q. -- in the theater.

23 A. Right.

24 Q. Are those windows shown in that particular

25 photograph?

26 A. I believe it’s up here.

27 Q. All right. Now, that photograph that you’re

28 looking at - which I believe I said was 799 - 799, 5353



1 is the subject matter of that photograph accurately

2 depicted in the photograph? In other words, does it

3 accurately portray what’s inside?

4 A. I believe so, yes.

5 MR. ZONEN: I’d move to introduce 799 into

6 evidence.

7 MR. MESEREAU: No objection.

8 THE COURT: It’s admitted.

9 MR. ZONEN: If I could publish 799 at this

10 time.

11 Q. If you could, turn around and look at the

12 screen behind you. And tell us, is that the

13 photograph that you just viewed, 799?

14 A. Yes, I believe so.

15 Q. Is that the theater?

16 A. Yes.

17 Q. All right. Now, on the desk in front of

18 you, there’s a laser pen, a laser pointer. If you

19 can do that -- that’s not it. That’s it.

20 A. Okay.

21 Q. Don’t --

22 A. Okay.

23 Q. Show us the windows that you were referring

24 to.

25 A. The window from up above?

26 Q. Yes.

27 A. It would be up here.

28 Q. And that’s the -- a viewing room? 5354



1 A. I believe it was a viewing room, yes.

2 Q. And the stairway to get up there is where?

3 A. I believe it’s on -- it used to be kind of

4 like on the side as you’re coming in the back out

5 here. There was a stairway. It’s been so long.

6 I know there was a stairway on the side, and I’m

7 thinking somewhere back here, that would take you up

8 to the top.

9 BAILIFF CORTEZ: Ma’am, you need to talk

10 into that microphone.

11 THE WITNESS: I’m sorry.

12 Q. BY MR. ZONEN: So you believe the stairway

13 was on the side; is that what you said?

14 A. I believe it was on the side.

15 MR. ZONEN: Thank you. No further

16 questions.

17 THE COURT: Cross-examine?

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

19

20 CROSS-EXAMINATION

21 BY MR. MESEREAU:

22 Q. Good afternoon, Miss McManus.

23 A. Good afternoon.

24 Q. We haven’t met. My name is Tom Mesereau and

25 I speak for Michael Jackson.

26 A. Okay.

27 Q. The prosecutor for the government mentioned

28 a case you were involved in where you were sued by 5355



1 Rosalie Hill, correct?

2 A. Correct.

3 Q. You were sued by Rosalie Hill as the

4 guardian ad litem for two children, correct?

5 A. Correct.

6 Q. The children were Shane McManus and Megan

7 McManus, correct?

8 A. Correct.

9 Q. And the prosecutor for the government

10 mentioned that you didn’t have a lawyer representing

11 you, right?

12 A. Correct.

13 Q. And that case was not tried before a jury,

14 right?

15 A. Right.

16 Q. It was tried before a judge of the Santa

17 Barbara Superior Court, correct?

18 A. I believe so.

19 Q. That was Judge Richard A. St. John, Judge of

20 the Santa Barbara Superior Court, true?

21 A. I believe so.

22 Q. And you and your husband testified before

23 Judge St. John, right?

24 A. I believe so.

25 Q. You told them your position under oath,

26 correct?

27 A. I believe so.

28 Q. And after you told Judge St. John your 5356



1 position under oath, he found that you and your

2 husband willfully and maliciously defrauded these

3 children out of the money in the estate, true?

4 A. I believe so.

5 Q. Judge St. John found that that money was to

6 be held in trust for the benefit of those two

7 children, right?

8 A. Yes.

9 Q. He found that you and your husband

10 dissipated those funds, right?

11 A. I believe so.

12 Q. He found that you and your husband violated

13 that trust, right?

14 A. I believe so.

15 Q. He entered a judgment against you and your

16 husband for $30,000 -- excuse me, 30,584.89,

17 correct?

18 A. I believe so, but I believe it was -- I

19 thought it was like separate, like -- I thought it

20 was maybe 17 for me and 17 for my husband. Maybe --

21 I don’t know. Maybe that’s right, what you have

22 there.

23 Q. Would it refresh your recollection if I just

24 show you Judge St. John’s judgment?

25 A. Sure.

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

27 THE COURT: Yes.

28 THE WITNESS: Okay. 5357



1 Q. BY MR. MESEREAU: Have you had a chance to

2 look at that judgment?

3 A. Right here? Yes.

4 Q. Does it refresh your recollection about the

5 amount Judge St. John awarded the plaintiffs against

6 you and your husband?

7 A. Yes.

8 Q. Okay. It was $30,584.89, which was

9 principal and interest due, correct?

10 A. I believe so.

11 Q. And after he entered that judgment, Judge

12 St. John also awarded the plaintiffs attorney’s

13 fees, right?

14 A. I believe so.

15 Q. He signed a separate judgment awarding the

16 people who sued you and your husband $5,085.27 in

17 attorney’s fees and costs, right?

18 A. I believe so.

19 Q. And in that judgment, Judge St. John also

20 found, again, that you and your husband had

21 willfully and maliciously stolen the money from

22 those children, right?

23 MR. ZONEN: Objection; asked and answered.

24 THE COURT: Sustained.

25 Q. BY MR. MESEREAU: All right. Now, that

26 lawsuit was before you sued Michael Jackson,

27 correct?

28 A. I believe so. 5358



1 Q. And who did you join with in your suit

2 against Michael Jackson?

3 A. Kassim Abdool -- do you want the names?

4 Q. Yes, please.

5 A. Kassim Abdool, Ralph Chacon, Melanie Bagnall

6 and Sandie Domz.

7 Q. And in that case you had a lawyer, right?

8 A. Yes.

9 Q. In fact, you had a number of lawyers, right?

10 A. Correct.

11 Q. And you’ve already identified the lawyers

12 that represented you and the other people that sued

13 Michael Jackson with you, correct?

14 A. Correct.

15 Q. Now, that case went to a jury, right?

16 A. Yes.

17 Q. That was a jury in this courthouse in Santa

18 Maria, right?

19 A. Yes.

20 Q. In that particular case, a Santa Maria jury

21 held that you had stolen from Michael Jackson,

22 right?

23 A. I believe so.

24 Q. And they awarded Mr. Jackson $35,000 for

25 what you personally had stolen from him, right?

26 A. The sketch that I found in the trash, yes.

27 Q. That was a sketch he had done of Elvis

28 Presley, right? 5359



1 A. Well, I thought it looked like Elvis

2 Presley, but I don’t really know for --

3 Q. But you tried to sell it to a tabloid,

4 correct?

5 A. Yes.

6 Q. You did sell it to a tabloid, correct?

7 A. Well, I gave it to Gary Morgan.

8 Q. You sold it to a tabloid, right?

9 A. I believe he did.

10 Q. You don’t know for sure?

11 A. I don’t know who he actually really sold it

12 to, but --

13 Q. You certainly inquired at some point,

14 correct?

15 A. I think I saw somewhere later that it was

16 printed, but I don’t remember like what, but it was

17 printed.

18 Q. But when you sold it, you believed it was a

19 sketch by Michael Jackson of Elvis Presley, right?

20 A. I thought so.

21 Q. And a Santa Maria jury held that you had

22 stolen that from Michael Jackson, right?

23 A. That’s what they thought, yeah.

24 Q. And that was their verdict, true?

25 A. I believe so.

26 Q. Okay. There was a finding that you had

27 acted with fraud and malice against Michael Jackson

28 in that case, correct? 5360



1 A. I believe -- you know, it’s been so long, I

2 don’t remember, but probably.

3 Q. You actually stipulated that you had engaged

4 in fraud, oppression, and malicious conduct against

5 Mr. Jackson, true?

6 A. You know what, I don’t remember everything.

7 It’s been a while, but --

8 Q. Would it -- excuse me. Would it refresh

9 your recollection if I show you that judgment?

10 A. Sure. That’s fine.

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

12 THE COURT: Yes.

13 MR. ZONEN: May I see, Counsel?

14 (Off-the-record discussion held at counsel

15 table.)

16 MR. MESEREAU: Let me withdraw the question

17 and ask it again.

18 Q. The jury found you had acted with fraud,

19 oppression and malice against Mr. Jackson, true?

20 A. You know what? Honestly I don’t really

21 recall. I don’t know.

22 Q. Would it refresh your recollection if you

23 see the judgment?

24 A. Well, sure.

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

26 THE COURT: Yes.

27 THE WITNESS: Okay.

28 Q. BY MR. MESEREAU: Have you had a chance to 5361



1 read that judgment?

2 A. Yes.

3 Q. Does it refresh your recollection about the

4 jury in Santa Maria finding that you had acted with

5 fraud, oppression, and malice against Mr. Jackson?

6 A. Yes.

7 Q. That’s what they held, right?

8 A. That’s what they -- yeah.

9 Q. All right. Now, the total amount -- excuse

10 me, let me start again.

11 The suit began when you and the others sued

12 Mr. Jackson, right?

13 A. Correct.

14 Q. And after you and Ralph Chacon and Mr.

15 Abdool and Ms. Bagnall sued Mr. Jackson, he

16 responded with a countersuit, correct?

17 A. Correct.

18 Q. And the countersuit was an allegation that

19 you had stolen property from him, right?

20 A. I believe so.

21 Q. Okay. Mr. Jackson’s suit was a response to

22 your suit, right?

23 A. Correct.

24 Q. Everything began when you and Mr. Chacon and

25 Mr. Abdool filed the action, right?

26 A. Correct.

27 Q. And that’s the action where you were

28 represented by Mr. Ring, correct? 5362



1 A. Correct.

2 Q. Okay. At the end of the case, there was a

3 judgment signed by Judge Zel Canter of the Superior

4 Court of Santa Barbara in Santa Maria against you

5 and Mr. Chacon and Mr. Abdool and Melanie Bagnall

6 and Sandie Domz for $1,473,117.61, right?

7 A. I believe it was more. I -- I thought it

8 was 1.6 million each person.

9 Q. Would it refresh your recollection if I just

10 show you --

11 A. Sure.

12 Q. -- this?

13 May I approach, Your Honor?

14 THE COURT: Yes.

15 MR. MESEREAU: Thank you.

16 THE WITNESS: Okay. All right. Uh-huh.

17 Q. BY MR. MESEREAU: Have you had a chance to

18 look at that judgment?

19 A. Yes.

20 Q. And does it refresh your recollection about

21 the amount?

22 A. Yes.

23 Q. Okay. Now, do you recall that Mr. Jackson

24 was entitled to have a hearing on what are called

25 punitive damages after he won the jury verdict,

26 right?

27 A. I believe so.

28 Q. And Mr. Jackson agreed to waive that portion 5363



1 of the trial, correct?

2 A. I believe so.

3 Q. He did it in return for one dollar, right?

4 A. Correct.

5 Q. Now, the prosecutor asked you some questions

6 about a deposition that you appeared at in the

7 Jordie Chandler lawsuit, right?

8 A. Correct.

9 Q. And I believe you told the jury that you had

10 lied under oath in that lawsuit, correct?

11 A. Can you repeat that? I’m sorry.

12 Q. Yes, sure. I believe you told the jury that

13 you lied under oath in that lawsuit, correct?

14 A. What jury? During our trial?

15 Q. No, let me start the question again. If you

16 don’t understand anything I ask you, don’t answer,

17 just ask me. I’ll try and rephrase.

18 A. Okay.

19 Q. In response to the prosecutor’s questions,

20 you told the jury that you had appeared at a sworn

21 deposition in the Jordie Chandler lawsuit, right?

22 A. Correct.

23 Q. That was a lawsuit that you knew Mr.

24 Chandler’s parents had filed against Mr. Jackson,

25 right?

26 A. Correct.

27 Q. And you appeared and testified under oath in

28 a deposition, right? 5364



1 A. Correct.

2 Q. And you were asked questions by a number of

3 lawyers, including Larry Feldman, right?

4 A. Correct.

5 Q. That deposition took place on December 7th,

6 1993, right?

7 A. Yes. Correct.

8 Q. When have you last reviewed that deposition?

9 A. Actually, I never really went through it to

10 really review it.

11 Q. I’m sorry?

12 A. I never really went through it to review it.

13 Q. Okay. Before I ask you some questions about

14 that deposition, when did you last talk to any

15 prosecutor about your testimony in this trial?

16 A. Last night.

17 Q. And who did you talk to about your testimony

18 in this trial from the prosecution side?

19 A. Ron Zonen.

20 Q. That’s Prosecutor Zonen, who just asked you

21 some questions?

22 A. Yes.

23 Q. Okay. Did he talk to you about what you

24 were going to be asked today?

25 A. No.

26 Q. Was it a phone call or a meeting?

27 A. A meeting.

28 Q. Where did the meeting take place with 5365



1 Prosecutor Zonen?

2 A. In Santa Maria.

3 Q. And how long did the meeting last?

4 A. A little over three hours.

5 Q. Did Prosecutor Zonen give you anything to

6 review before you testified today?

7 A. No.

8 Q. Did you review any documents to prepare for

9 your testimony today?

10 A. Well, I -- I have my deposition from when I

11 sued Mr. Jackson, and I did go over that.

12 Q. Now, that’s the deposition from your suit

13 against Mr. Jackson, right?

14 A. Right.

15 Q. That’s not the deposition that you gave in

16 the Chandler lawsuit, right?

17 A. Correct.

18 Q. Now, did you review the deposition you gave

19 in your suit against Mr. Jackson to prepare for your

20 testimony today?

21 A. Yes.

22 Q. But you didn’t review your deposition in the

23 Chandler case to prepare for your testimony today?

24 A. Correct.

25 Q. Did Prosecutor Zonen ask you to review that

26 deposition in your suit against Mr. Jackson to

27 prepare for your testimony today?

28 A. No. 5366



1 Q. Did he ask you to review any documents

2 before you testified?

3 A. No.

4 Q. You spent three hours with him last night?

5 A. Yes.

6 Q. Did that take place at the District

7 Attorney’s Office here?

8 A. No.

9 Q. Where did it take place?

10 A. Somewhere in Santa Maria, a home.

11 Q. Okay. Was Prosecutor Zonen the only one

12 present, besides yourself?

13 A. No.

14 Q. Who else was there?

15 A. During that meeting?

16 Q. Yes, please.

17 A. Russ Birchim.

18 Q. That’s a -- Russ Birchim, a Santa Barbara

19 sheriff?

20 A. I believe so.

21 Q. Was anyone else present?

22 A. Just them in the room.

23 Q. Okay. And during those three hours, they

24 went over what you were going to be asked today,

25 right?

26 A. Well, they went over my depo -- Ron went

27 over my deposition.

28 Q. Did he point to specific pages in your 5367



1 deposition?

2 A. No.

3 Q. Well, your deposition is volume after volume

4 after volume, isn’t it?

5 A. Yeah.

6 Q. How many volumes was your deposition in your

7 suit against Mr. Jackson?

8 A. You know what? I’m thinking I was deposed

9 for eight days. That’s what I think.

10 Q. Did Prosecutor Zonen bring a copy of that

11 deposition with him to your meeting?

12 A. I think he had one.

13 Q. Okay. Did he appear to have all of the

14 volumes to the deposition with him?

15 A. I really don’t know.

16 Q. Okay. But he had specific parts he wanted

17 to talk to you about, right?

18 A. Not really specific parts. Just kind of

19 going through it, you know.

20 Q. Did you go through all those eight days of

21 deposition with Prosecutor Zonen in three hours?

22 A. I don’t believe so.

23 Q. Okay. Who chose what portions of the

24 deposition you were going to look at during the

25 three-hour meeting, if you know?

26 A. I have no idea.

27 Q. Okay. Correct me if I’m wrong, Prosecutor

28 Zonen had portions of those deposition volumes he 5368



1 wanted to talk to you about, correct?

2 MR. ZONEN: Objection as to what he wanted

3 to talk about. Vague and speculative.

4 THE COURT: Sustained.

5 Q. BY MR. MESEREAU: Did Prosecutor Zonen

6 point out certain portions of those volumes that he

7 wanted -- that he appeared to want to discuss with

8 you?

9 MR. ZONEN: Objection as to asked and

10 answered and speculative as to what he appeared to

11 want to ask.

12 THE COURT: I think you need to cut that

13 question in half.

14 MR. MESEREAU: Okay. All right.

15 THE COURT: I’ll sustain the objection.

16 Q. BY MR. MESEREAU: During your three-hour

17 meeting last night with Prosecutor Zonen, you looked

18 at seven or eight volumes of your deposition, right?

19 MR. ZONEN: Objection; assumes facts not in

20 evidence that she looked at seven or eight volumes

21 of anything.

22 THE COURT: Overruled.

23 You may answer.

24 THE WITNESS: I’m sorry, you lost me. Um,

25 can you repeat it?

26 Q. BY MR. MESEREAU: Yes, sure.

27 During your three-hour meeting last night

28 with Prosecutor Zonen, you went through volumes of 5369



1 the deposition you gave in your suit against Michael

2 Jackson, correct?

3 A. I don’t know if it was volumes. It was just

4 whatever page had opened, you know.

5 Q. Who opened the pages?

6 A. It wasn’t me.

7 Q. It was Prosecutor Zonen, wasn’t it?

8 A. Yes.

9 Q. And he seemed to have certain pages he

10 wanted to talk to you about, correct?

11 MR. ZONEN: Objection as to what he wanted

12 to talk about. Speculative.

13 THE COURT: Overruled.

14 You may answer.

15 THE WITNESS: I have no idea. I just was --

16 he was just going through it, period. I don’t --

17 Q. BY MR. MESEREAU: And was he asking you

18 questions about what you said in that deposition?

19 A. No. He was just reading it.

20 Q. Okay. I’m going to ask you some questions

21 about the deposition you gave in the Chandler

22 suit --

23 A. Uh-huh.

24 Q. -- on December 7th, 1993, okay?

25 A. Sure.

26 Q. Do you remember you said under oath that you

27 trust Mr. Jackson and you would leave your son alone

28 with him? 5370



1 A. I don’t recall any of that. I don’t recall --

2 I don’t know what I said, because I have not looked

3 at that.

4 Q. Might it refresh your recollection if I just

5 show you that page?

6 A. Sure.

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

8 THE COURT: Yes.

9 THE WITNESS: Okay.

10 Q. BY MR. MESEREAU: Have you had a chance --

11 excuse me. Have you had a chance to look at those

12 pages of your deposition?

13 A. No. Oh, right now? Yes, I’m sorry. Sorry.

14 Q. Does it refresh your recollection about what

15 you said in that deposition?

16 A. Yes.

17 Q. You said words to the effect, “I trust Mr.

18 Jackson,” and you would leave your son alone with

19 him, right?

20 A. I believe so.

21 Q. Okay. You were asked if you ever saw Jordie

22 Chandler in Michael Jackson’s bedroom and you said,

23 “No,” right?

24 A. Correct, I believe.

25 Q. You said you had never seen Brett Barnes

26 sleep in Michael Jackson’s room, right?

27 A. Probably. I can’t recall everything in

28 that. 5371



1 Q. Would it refresh your recollection if I show

2 you?

3 A. I hate to have you keep coming back, but

4 that’s fine.

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

6 THE COURT: Yes.

7 THE WITNESS: Yeah.

8 Q. BY MR. MESEREAU: Have you had a chance to

9 look at that page?

10 A. Yes.

11 Q. Does it refresh your recollection about what

12 you said under oath in that deposition?

13 A. Yes.

14 Q. You said you had never seen Brett Barnes

15 sleep in Michael Jackson’s room, right?

16 A. Correct.

17 Q. You didn’t recall when you had met Wade

18 Robeson for the first time, right?

19 MR. ZONEN: Objection; hearsay.

20 MR. MESEREAU: I’ll rephrase it. I’ll

21 withdraw it.

22 Q. Do you remember testifying under oath that

23 you didn’t recall when you met Wade Robeson for the

24 first time?

25 MR. ZONEN: Objection; hearsay.

26 THE COURT: Overruled.

27 You may answer.

28 THE WITNESS: Um, actually, I don’t -- I 5372



1 don’t recall. I didn’t go over that, so I don’t --

2 Q. BY MR. MESEREAU: Would it refresh your

3 recollection if you look at that page?

4 A. Sure.

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

6 THE COURT: Yes.

7 THE WITNESS: Okay.

8 Q. BY MR. MESEREAU: Have you had a chance to

9 look at that page of your deposition?

10 A. Yeah.

11 Q. Does it refresh your recollection about your

12 saying you don’t know when you first met Wade

13 Robeson?

14 A. Yes.

15 Q. Do you remember testifying you didn’t know

16 how many times Brett Barnes had been to the ranch?

17 A. Probably.

18 Q. Do you know if that’s what you said?

19 A. I believe -- I don’t know.

20 Q. Would it refresh your recollection to look

21 at the page?

22 A. Sure.

23 MR. MESEREAU: May I approach?

24 THE COURT: Yes.

25 THE WITNESS: Okay.

26 Q. BY MR. MESEREAU: Have you had a chance to

27 look at that page?

28 A. Yes. 5373



1 Q. And you testified under oath you didn’t know

2 how many times Brett Barnes had been to the ranch,

3 right?

4 A. I believe so.

5 Q. Okay. Do you remember testifying under oath

6 that you didn’t know where Brett Barnes slept?

7 A. I probably did. I don’t remember.

8 Q. Might it refresh your recollection if I show

9 you the page?

10 A. (Nods head up and down.)

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

12 THE WITNESS: Okay.

13 Q. BY MR. MESEREAU: Have you had a chance to

14 look at that page?

15 A. Yes.

16 Q. Does it refresh your recollection about what

17 you said under oath about whether you knew where Mr.

18 Barnes slept?

19 A. Yeah.

20 Q. And what did you say?

21 A. I believe I said, “I don’t know.”

22 Q. Okay. Now, you knew you were under oath in

23 this deposition, right?

24 A. Yes.

25 Q. Did Prosecutor Zonen discuss with you last

26 night what you were going to say if confronted with

27 this sworn deposition in trial?

28 A. No. 5374



1 Q. Did the issue of what you had said under

2 oath in the Chandler deposition ever come up during

3 the three hours you spent last night with Government

4 Prosecutor Zonen?

5 A. No.

6 Q. Okay. Do you remember being asked under

7 oath in that deposition if you ever saw Jordie

8 Chandler’s clothes at the ranch?

9 A. I believe that I do recall that.

10 Q. Do you remember saying that you saw his

11 mother bring them into Mr. Jackson’s room in a

12 suitcase?

13 A. Yes.

14 Q. Do you remember being asked questions by

15 Mr. Feldman about the alarm system in Mr. Jackson’s

16 room?

17 A. I don’t recall that.

18 Q. Remember telling him, “People like to kill

19 celebrities, so you have to be careful with your

20 life”?

21 A. I don’t recall that.

22 Q. Okay. Would it refresh your recollection if

23 I show you that portion of your deposition?

24 A. Sure.

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

26 THE WITNESS: Okay.

27 Q. BY MR. MESEREAU: Have you had a chance to

28 review that page? 5375



1 A. Yes.

2 Q. Does it refresh your recollection about what

3 you said under oath to Mr. Feldman on that subject?

4 A. Yes.

5 Q. You did say, “When you’re a celebrity, you

6 live a different life than regular people. I mean,

7 people like to kill celebrities, so, you know, he

8 has to be careful, you know, with his life.” And

9 then --

10 MR. ZONEN: I’m going to object as to

11 hearsay, reading from a deposition that’s not

12 inconsistent with current testimony.

13 THE COURT: Sustained.

14 Q. BY MR. MESEREAU: Now, are you telling the

15 jury that throughout this deposition you committed

16 perjury?

17 MR. ZONEN: Objection; calls for a legal

18 conclusion.

19 MR. MESEREAU: I believe it was raised on

20 direction examination by the prosecutor, Your Honor.

21 MR. ZONEN: Not issues of perjury.

22 THE COURT: I’ll sustain the objection to

23 the question as phrased.

24 MR. MESEREAU: Okay.

25 Q. You told Prosecutor Zonen that you

26 repeatedly lied under oath in that deposition,

27 correct?

28 A. Are you -- what are you talking about? 5376



1 Q. When Prosecutor Zonen asked you some

2 questions today in court, remember that?

3 A. Okay, yes.

4 Q. He asked you if you had lied under oath in

5 the Chandler deposition, right?

6 A. Right.

7 Q. You said you did, right?

8 A. Right.

9 Q. Do you know how many times you lied under

10 oath in the Chandler deposition?

11 A. I believe the whole time I did not tell the

12 truth on that.

13 Q. Did you believe you were committing a crime

14 when you did that?

15 A. I really didn’t. I really didn’t think of

16 it that way.

17 Q. Well, let me ask you this: So far, you’ve

18 admitted you lied under oath in the Chandler

19 deposition for what, a day?

20 A. Well, throughout that -- throughout that

21 deposition, yes.

22 Q. And Judge St. John found that you lied in

23 that trial, right?

24 MR. ZONEN: Objection. Asked and answered;

25 argumentative.

26 THE COURT: The objection is sustained.

27 Q. BY MR. MESEREAU: And the jury found you

28 didn’t tell the truth in your suit against Mr. 5377



1 Jackson, right?

2 MR. ZONEN: Objection. Asked and answered;

3 and argumentative.

4 THE COURT: Sustained.

5 Mr. Mesereau, a few questions back, after

6 you refreshed her recollection with the transcript

7 about “you’re a celebrity,” I sustained an

8 objection, and I was incorrect.

9 MR. MESEREAU: Okay.

10 THE COURT: Do you want to reask that

11 question? I’ll reverse my ruling on that.

12 MR. MESEREAU: Thank you, Your Honor.

13 THE COURT: So what had happened is she’d

14 refreshed her recollection, and then you wanted

15 to --

16 MR. MESEREAU: Okay.

17 THE COURT: Go ahead.

18 Q. BY MR. MESEREAU: Do you remember I showed

19 you the page of the deposition about what you said

20 about “people try to kill celebrities”?

21 A. Yes.

22 Q. And did that refresh your recollection about

23 what you said on that issue under oath?

24 A. I believe so.

25 Q. Okay. And as you recall, what did you say

26 under oath on that issue?

27 MR. ZONEN: Objection; irrelevant.

28 THE COURT: Overruled. 5378



1 THE WITNESS: I forgot.

2 Q. BY MR. MESEREAU: Would it refresh your

3 recollection if I show it to you again?

4 A. Yes.

5 THE COURT: What I’m going to do is let you

6 read it to her. That’s what I stopped you from

7 doing. And I’ll allow you to do it.

8 MR. MESEREAU: Thank you, Your Honor.

9 THE COURT: And he’s going to ask you if

10 this is --

11 You ask her.

12 (Laughter.)

13 MR. MESEREAU: Okay. All right.

14 Q. Ms. McManus, this is what you said under

15 oath: “But you have to understand now, when you’re

16 a celebrity, you live a different life than regular

17 people. I mean, people like to kill celebrities,

18 so, you know, he has to be careful, you know, with

19 his life, and that little sensor benefits him for

20 his life.”

21 Remember saying that?

22 A. I believe so.

23 Q. Okay. Now, you weren’t lying when you said

24 that, were you?

25 A. No.

26 Q. In fact, you knew that Mr. Jackson is very

27 nervous about his personal security, isn’t he?

28 MR. ZONEN: Objection. Speculative as to 5379



1 what he is nervous about; lack of foundation.

2 THE COURT: Overruled.

3 You may answer.

4 THE WITNESS: Repeat it, please.

5 Q. BY MR. MESEREAU: You knew when you worked

6 at Neverland that Mr. Jackson is extremely nervous

7 about his security, isn’t he?

8 A. I really don’t know.

9 Q. Well, when you saw his bodyguards, right?

10 A. Are you talking --

11 Q. Huh?

12 A. Are you talking OSS or just security from

13 the house?

14 Q. Let me rephrase it. I think I was too vague

15 on that one.

16 A. Okay.

17 Q. During the time you worked at Neverland --

18 A. Uh-huh.

19 Q. -- was it your understanding that Mr.

20 Jackson is someone who’s very concerned about his

21 personal security?

22 A. I really don’t know. I mean -- I don’t

23 know.

24 Q. You knew he had personal bodyguards to

25 protect him, right?

26 A. Yeah.

27 Q. You knew they traveled with him when he went

28 on tours around the world, right? 5380



1 A. Yeah.

2 Q. You knew they were often armed, right?

3 A. Yes.

4 Q. And you knew that he was always concerned

5 about threats to his personal welfare, right?

6 A. I don’t know about that. But, I mean, I

7 don’t want to answer that, because I don’t know.

8 Q. Did it ever occur to you that he might be

9 concerned about his personal welfare?

10 A. I -- I don’t know. I --

11 Q. Okay. You testified under oath that twice

12 you saw June Chandler bring her son Jordie’s clothes

13 in a suitcase into Mr. Jackson’s room?

14 A. I don’t know if it was twice. I know at

15 least once. I don’t remember what I said on that.

16 Q. Would it refresh your recollection if I just

17 show you that page?

18 A. Sure.

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

20 THE COURT: Yes.

21 THE WITNESS: Okay.

22 Q. BY MR. MESEREAU: Have you had a chance to

23 look at that page of your sworn deposition?

24 A. Yes.

25 Q. Does it refresh your recollection about what

26 you said on that subject?

27 A. Yes.

28 Q. What did you say? 5381



1 A. Twice.

2 Q. Okay. You testified that you saw Mrs.

3 Chandler open the suitcase and take clothes out,

4 right?

5 A. I -- you know what, I don’t recall.

6 Q. Do you remember saying that she would sit

7 down on the floor, take clothes out of the suitcase,

8 fold them? Do you remember that?

9 A. Honestly, no, I don’t remember.

10 Q. Would it refresh your recollection if I show

11 you that page?

12 A. Yeah. Sorry.

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

14 THE WITNESS: Okay.

15 Q. BY MR. MESEREAU: Have you had a chance to

16 look at that page of your sworn deposition?

17 A. Yeah.

18 Q. Does it refresh your recollection about what

19 you said on that subject?

20 A. Yes.

21 Q. What did you say?

22 A. That she would fold the clothes.

23 Q. That she would bring the suitcase and get on

24 the floor and --

25 A. And fold the clothes, yes.

26 Q. Remember testifying under oath that you were

27 never there at night when Jordie Chandler was in the

28 room? 5382



1 A. You know what, I don’t recall.

2 Q. Remember testifying you said you were never

3 at Neverland at night when Jordie was there?

4 A. I don’t recall that either.

5 Q. Would it refresh your recollection if I show

6 you that page?

7 A. Sure. Probably, yes.

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

9 THE COURT: Yes.

10 THE WITNESS: Okay.

11 Q. BY MR. MESEREAU: Have you had a chance to

12 look at that page of your sworn deposition?

13 A. Yes.

14 Q. Does it refresh your recollection about what

15 you said about that subject?

16 A. Yes.

17 Q. What did you say?

18 A. That I wasn’t there at night with Jordie.

19 Q. Now, there were many occasions where Jordie

20 Chandler, his mother and sister would come to the

21 ranch and stay, right?

22 A. I believe so.

23 Q. Do you remember what his sister’s name was?

24 A. Lily.

25 Q. Did you ever talk to Lily?

26 A. I don’t believe so.

27 Q. Do you know what his mother’s name was?

28 A. June Chandler. 5383



1 Q. Did you ever talk to June Chandler?

2 A. Yes.

3 Q. What were your typical hours working at

4 Neverland?

5 A. They varied, actually.

6 Q. Was there a particular time you normally

7 punched in?

8 A. Sometimes 8:30, sometimes 9:00 in the

9 morning.

10 Q. Do you remember testifying that you have

11 never seen Mr. Jackson in bed?

12 A. I don’t recall.

13 Q. Might it refresh your recollection if I show

14 you your deposition?

15 A. Sure.

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

17 THE COURT: Yes.

18 THE WITNESS: Okay.

19 Q. BY MR. MESEREAU: Have you had a chance to

20 look at that page?

21 A. Yes.

22 Q. Does it refresh your recollection about what

23 you said --

24 A. Yes.

25 Q. -- on that occasion?

26 A. Yes.

27 Q. What did you say?

28 A. That I didn’t see him in his bed. 5384



1 Q. You’d never seen Mr. Jackson in bed, right?

2 A. Right.

3 Q. What was your understanding about when you

4 were supposed to be at Neverland to do your work?

5 A. Well, there was a schedule, and we kind of

6 just followed the schedule. But then there were

7 times that you didn’t know when you were going to go

8 home because of the guests being there late. So you

9 come in at a certain time, but that didn’t mean that

10 you were going to leave at the time that you were

11 scheduled.

12 Q. So how would you learn what time you had to

13 be there?

14 A. I believe there was a schedule that was

15 made. You know, like supervisor would make it. And

16 you’d be on the schedule at maybe 8:30 or 9:00,

17 sometimes maybe till 5:30 or 6:00. But then, like I

18 said, if there were guests, you didn’t know what

19 time you were going to go home.

20 Q. Do you remember testifying you couldn’t tell

21 if Mr. Jordie Chandler ever took a shower with Mr.

22 Jackson, right?

23 A. A shower with Jackson?

24 Q. Yes.

25 A. Perhaps.

26 Q. Would it refresh your recollection if I show

27 you that page?

28 A. Yeah. 5385


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

2 THE COURT: Yes.

3 THE WITNESS: Yes.

4 Q. BY MR. MESEREAU: Have you taken a look at

5 that page?

6 A. Yes.

7 Q. Does it refresh your recollection about what

8 you said?

9 A. Yes.

10 Q. And what did you say?

11 A. I said I didn’t -- I said I didn’t -- I

12 don’t know, I just forgot. Sorry.

13 Q. You said you couldn’t tell if Mr. Jackson

14 ever took a shower with Mr. Jackson, right?

15 A. I couldn’t tell. Right. Right.

16 Q. You said you’d never seen Mr. Jackson in a

17 Jacuzzi, right?

18 A. In a Jacuzzi, like taking a bath in a

19 Jacuzzi, is that what you’re talking about?

20 Q. You said you had never seen Mr. Jackson in

21 his Jacuzzi?

22 MR. ZONEN: I’ll object as hearsay if it’s

23 not inconsistent with current testimony, also vague.

24 THE COURT: Sustained.

25 Q. BY MR. MESEREAU: You testified under oath

26 that you’d never seen Jordie Chandler get ready to

27 go to bed, right?

28 A. Perhaps. Like I said, I haven’t gone over 5386



1 that, and I’m sorry.

2 Q. Would it refresh your recollection if I show

3 you that page?

4 A. Yeah.

5 MR. MESEREAU: May I approach?

6 THE COURT: Yes.

7 Q. BY MR. MESEREAU: Have you had a chance to

8 look at that page?

9 A. Yes.

10 Q. Does it refresh your recollection about what

11 you said?

12 A. Yes.

13 Q. And what did you say about Mr. Chandler on

14 that issue?

15 A. That I didn’t see him ready to go to bed.

16 Q. And you also said you’d never seen him get

17 up in the morning, right?

18 A. Correct.

19 Q. The prosecutor asked you a couple of

20 questions about whether Mr. Jackson ever played with

21 a pet monkey in his bedroom, right?

22 A. Yes.

23 Q. And I believe you said he had; is that

24 right?

25 A. Yes.

26 Q. Okay. Was that chimpanzee’s name Max?

27 A. I believe so.

28 Q. When you had your deposition taken in the 5387



1 Chandler case, you said you’d never seen a

2 chimpanzee in his bedroom, right?

3 A. Perhaps.

4 Q. Would it refresh your recollection if I show

5 you the deposition?

6 A. Yes.

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

8 THE COURT: Yes.

9 THE WITNESS: Okay.

10 Q. BY MR. MESEREAU: Have you had a chance to

11 look at that page?

12 A. Yes.

13 Q. Does it refresh your recollection about what

14 you said under oath at that deposition?

15 A. Yes.

16 Q. And what did you say?

17 A. I said, “No.”

18 Q. You said everybody plays with the chimpanzee

19 but you’ve never seen it in Mr. Jackson’s room,

20 right?

21 A. I believe so.

22 Q. Okay. Did you work at Neverland when Blanca

23 Francia was working there?

24 A. Yes, I did.

25 Q. And how long did you work at Neverland when

26 Blanca Francia was also working there?

27 A. I would think maybe nine months.

28 Q. Did you share similar responsibilities with 5388



1 Blanca Francia?

2 A. Are you talking about Mr. Jackson’s room, or

3 just as a maid, as an aide?

4 Q. Let me rephrase it.

5 When you worked at Neverland, what did you

6 understand Blanca Francia’s responsibilities to be?

7 A. Blanca had Mr. Jackson’s room. She was his

8 personal maid. Although Blanca did help out with

9 the other things in the house or the guest units.

10 She kind of did a lot of everything.

11 Q. And when you worked at Neverland, what did

12 you understand your responsibilities to be?

13 A. Are you talking about the beginning or --

14 Q. Let’s start at the beginning, sure.

15 A. Okay. When I started, I was just a regular

16 maid, like everybody else. I was in the kitchen

17 helping wash dishes. Set tables. I mean, actually

18 a lot of different stuff. You know, cleaning the

19 guest quarters, the theater, everything, except Mr.

20 Jackson’s room.

21 Q. When did you begin to clean Mr. Jackson’s

22 room?

23 A. Actually, about nine months after my

24 employment, which was when Blanca quit.

25 Q. During the first nine months of your

26 employment when Blanca was working there, did you

27 ever go into Mr. Jackson’s room?

28 A. I can’t recall. 5389



1 Q. Do you recall ever having similar

2 responsibilities in Mr. Jackson’s house to Blanca

3 Francia?

4 A. At times, yeah, maybe.

5 Q. Were there times when she would clean Mr.

6 Jackson’s room on a given day, and on another day

7 you would clean Mr. Jackson’s room?

8 A. No. No.

9 Q. Okay. So you didn’t go near his room for

10 the first nine months you worked there, right?

11 A. Correct.

12 Q. During those nine months, did you and Blanca

13 Francia speak to each other?

14 A. Yes.

15 Q. Did you speak to each other often during

16 those first nine months?

17 A. Yes.

18 Q. Did you ever learn that Blanca Francia had

19 sold a story to a television show?

20 A. Um, I heard she did.

21 Q. Did you hear she had sold a story for money

22 to Hard Copy?

23 A. I heard she did.

24 Q. Okay. Did you and Blanca ever discuss that

25 subject?

26 A. No.

27 Q. How many -- let me rephrase that.

28 You sold the sketch to a tabloid, right? 5390



1 A. Me personally?

2 Q. Yes.

3 A. Not me personally. Somebody else did.

4 Q. Well, they did it on your behalf, right?

5 A. Well, I would probably think so. I don’t --

6 yeah.

7 Q. Well, how did that person get the sketch?

8 A. Gary Morgan had gone to our attorney’s

9 office, Mr. Ring, Michael Ring, and that’s where he

10 got it, from there, at the attorney’s office.

11 Q. Did you bring the sketch to Mr. Ring’s law

12 office?

13 A. Yes, I did.

14 Q. Did you tell Mr. Ring, “I took this from

15 Neverland Ranch”?

16 A. No, I -- actually, I don’t even -- I don’t

17 even think Michael Ring -- I don’t even think he saw

18 it. I don’t know if he saw it.

19 I told Gary Morgan that I got it out of the

20 trash. And I told him he could have it. So that’s

21 kind of where that went. And I don’t know what

22 Gary --

23 Q. Well, you didn’t really say he could have

24 it, you sold it?

25 A. Actually, I told him he could have it. And

26 he went and, I guess, sold it. And then I think he

27 said something in the tabloid, I don’t even know

28 which one it was, something that I had told him that 5391



1 I got it out of Mr. Jackson’s bedroom in the trash

2 or something to that -- which was not correct.

3 Q. You’re telling the jury that Michael Jackson

4 did a sketch of Elvis Presley and you picked it out

5 of the trash?

6 A. I found it outside by the rec room in the

7 trash, in the trash. And when I found it there, I

8 thought, well, it was neat, so I took it. It was in

9 the trash.

10 Q. Is that one of the items the Santa Maria

11 jury found you had stolen?

12 A. Well, that’s what they --

13 MR. ZONEN: Objection; asked and answered.

14 THE COURT: Sustained.

15 Q. BY MR. MESEREAU: When you went to Mr. Ring,

16 did you tell this attorney where you got the sketch?

17 A. I don’t even recall if I -- he probably

18 heard during the deposition that -- because I think

19 I was questioned about that during the deposition,

20 and I did say that I found it in the trash. But I

21 don’t remember -- I don’t remember telling him about

22 that myself. It must have been, you know, at the

23 deposition where I said I found it in the trash.

24 Q. Did you sell that sketch before you went to

25 trial in your lawsuit against Michael Jackson?

26 A. Before I went to trial?

27 Q. Yes.

28 A. You know what? I don’t even know -- I 5392



1 really don’t know when that -- the timing. I don’t

2 know if it was during the trial maybe, later during

3 the trial.

4 Q. Let me ask you this: You’ve told the jury

5 the money that came -- excuse me. Let me rephrase

6 it.

7 You’ve told the jury the money that was

8 obtained in return for that sketch helped fund your

9 lawsuit against Mr. Jackson, right?

10 A. Correct.

11 Q. Did you know when you did that that Mr.

12 Jackson was alleging that you had stolen that

13 sketch?

14 A. Not that I know of.

15 Q. Let me ask you if this statement is

16 accurate: You took what you were accused of

17 stealing and sold it for money to fund your lawsuit

18 against Mr. Jackson, right?

19 A. I took what I found in the trash and gave it

20 to Gary Morgan and he sold it.

21 Q. And at some point you knew you were accused

22 of stealing that sketch of Elvis Presley, right?

23 A. I got accused of that, yes.

24 THE COURT: All right. Let’s end for today.

25 (The proceedings adjourned at 2:30 p.m.)

26 --o0o--

27

28 5393



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 5216 through 5393

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 7, 2005, and thereafter

20 reduced to typewriting by computer-aided

21 transcription under my direction.

22 DATED: Santa Maria, California,

23 April 7, 2005.

24

25

26

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

28 5394



