 


 
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, MARCH 10, 2005
20
21 8:35 A.M.
22
23 (PAGES 1526 THROUGH 1529)
24
25
26
27 REPORTED MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304
28 BY: Official Court Reporter 1525
 

 
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 (Not Present)
22
23
24
25
26
27
28 1526
 

 
1 Santa Maria, California
2 Thursday, March 10, 2005
3 8:35 a.m.
4
5 (The following proceedings were held in
6 open court outside the presence and hearing of the
7 jury:)
8
9 THE COURT: Good morning.
10 Try that again. Good morning.
11 COUNSEL AT COUNSEL TABLE: (In unison)
12 Good morning, Your Honor.
13 THE COURT: I notice the defendant’s not
14 present.
15 MR. MESEREAU: Yes, Your Honor. Mr. Jackson
16 is at --
17 THE COURT: They can’t hear you. Speak into
18 the microphone, please.
19 MR. MESEREAU: Mr. Jackson is at Cottage
20 Hospital in Santa Ynez with a serious back problem.
21 My understanding is he’s on his way in. The doctor
22 does want to talk to you on the phone. That’s the
23 last information I have.
24 I did give the -- I had the doctor on my
25 cell phone. I did give it to your clerk and tried
26 to make contact with you, but I -- I know that
27 they’re waiting, hoping to speak to you about it.
28 My understanding is that he does plan to come in. 1527
 

 
1 THE COURT: I’m going to issue a warrant for
2 his arrest. I’m forfeiting his bail.
3 MR. MESEREAU: Your Honor --
4 THE COURT: I’m going to hold that order for
5 one hour. In one hour I’m going to execute that
6 order.
7 Court’s in recess.
8 (Recess taken.)
9 --o0o--
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28 1528
 

 
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 1527 through 1528
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 March 10, 2005, and thereafter
20 reduced to typewriting by computer-aided
21 transcription under my direction.
22 DATED: Santa Maria, California,
23 March 10, 2005.
24
25
26
27 MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304
28 1529
 

 
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
18 REPORTER’S TRANSCRIPT OF PROCEEDINGS
19
20 THURSDAY, MARCH 10, 2005
21
22 (PAGES 1530 THROUGH 1714)
23
24
25
26
27 REPORTED MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304
28 BY: Official Court Reporter 1530
 

 
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 1531
 

 
1 I N D E X
2
3 Note: Mr. Sneddon is listed as “SN” on index.
4 Mr. Zonen is listed as “Z” on index. Mr. Auchincloss is listed as “A” on index.
5 Mr. Mesereau is listed as “M” on index. Ms. Yu is listed as “Y” on index.
6 Mr. Sanger is listed as “SA” on index. Mr. Oxman is listed as “O” on index.
7
8
9 PLAINTIFF’S WITNESSES DIRECT CROSS REDIRECT RECROSS
10
11 ARVIZO, Gavin-Anton 1536-SN (cont’d)
12 1608-SN 1686-M
13 (cont’d)
14 ROBEL, Steve Daniel 1598-SN 1600-SA 1607-SN
15
16
17
18
19
20
21
22
23
24
25
26
27
28 1532
 

 
1 E X H I B I T S
2
3 FOR IN PLAINTIFF’S NO. DESCRIPTION I.D. EVID.
4
5 99 Photograph of arcade 1638 1639
6 342 Bag containing watch 1561 1562
7 343 Bag containing black jacket 1561 1562
8 344 Diagram of interior of plane (Gavin Arvizo) 1564 1564
9 345 DVD, Neverland search,
10 containing the sound of bedroom suite chimes 1594 1608
11 346 Notes in Gavin Arvizo’s
12 handwriting 1610 1611
13 347 Note in Michael Jackson’s handwriting 1611 1611
14 348 Blue bag containing
15 schoolbooks 1652 1654
16 349 Clear plastic bag containing an orange plastic bottle 1658
17
18
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20
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22
23
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25
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27
28 1533
 

 
1 Santa Maria, California
2 Thursday, March 10, 2005
3 10:00 a.m.
4
5 (The following proceedings were held in
6 open court in the presence and hearing of the
7 jury:)
8
9 THE COURT: Good morning.
10 THE JURY: (In unison) Good morning.
11 COUNSEL AT COUNSEL TABLE: (In unison)
12 Good morning, Your Honor.
13 THE COURT: I’m sorry for the delay.
14 Mr. Jackson had a medical problem this morning, and
15 it was necessary for me to order his appearance.
16 I’m telling you that because I don’t want you to
17 draw any adverse inference about his guilt or
18 inference from the fact that I had to order him
19 here.
20 If one of you had called in and had not
21 appeared, or one of the attorneys, I would have had
22 to do the same thing. The trial is going to go
23 forward.
24 So I just want you to understand, in doing
25 that, I’m not expressing any opinion about the case,
26 about Mr. Jackson, or about the District Attorney.
27 It has nothing to do with guilt or innocence. Okay.
28 All right. Let’s see. Are you ready to go 1534
 

 
1 forward.
2 MR. SNEDDON: I am, Your Honor. And before
3 I begin, some housekeeping from yesterday.
4 THE COURT: Mike.
5 MR. SNEDDON: How’s that.
6 THE COURT: They’ve quit waving at me. It’s
7 probably okay.
8 MR. SNEDDON: Some housekeeping from
9 yesterday, Your Honor.
10 THE COURT: Yes.
11 MR. SNEDDON: Yesterday we saw the overheads
12 of those cards. For the record, I have consulted
13 with Mr. Sanger. The cards came from Item No. 1796
14 from the sheriff’s department. I now have the cards
15 themselves, and I will give them to the clerk to
16 substitute for the video in terms of the evidence.
17 THE COURT: All right.
18 MR. SANGER: I think it’s Exhibit 5004, and
19 we had temporarily lodged the disk. And now the
20 actual cards are being exchanged.
21 THE COURT: It is 5004, and I will release
22 the disk to you now. And thank you.
23 MR. SANGER: Thank you, Your Honor.
24 THE COURT: The cards are admitted into
25 evidence.
26 MR. SANGER: Thank you.
27 THE COURT: Oh, there’s one other issue I
28 want to address. And as you heard yesterday, this 1535
 

 
1 witness has one kidney. That causes a problem.
2 Sometimes he needs to go to the rest room more than
3 others. Although we all seem to have that problem.
4 (Laughter.)
5 THE COURT: If he needs to go, he’s going to
6 signal me, and we’ll just wait a minute while he
7 does that.
8 Go ahead.
9 MR. SNEDDON: Thank you, Your Honor.
10
11 GAVIN-ANTON ARVIZO
12 Having been previously sworn, resumed the
13 stand and testified further as follows:
14
15 DIRECT EXAMINATION (Continued)
16 BY MR. SNEDDON:
17 Q. Good morning.
18 A. Morning, Tom; Mr. Sneddon.
19 Q. I want to go back and talk about a couple of
20 things that I neglected to cover yesterday. And I
21 want to take you back in time to the first visit to
22 Neverland Ranch, and in particular to the computer
23 that Mr. Jackson gave you. Do you recall that.
24 A. Yes.
25 Q. What kind of computer was it.
26 A. It had an apple on it. I think it was a Mac
27 computer or something like that. It was, like, a
28 laptop. 1536
 

 
1 Q. After Mr. Jackson gave you the computer, did
2 you -- were you contacted by somebody to set up some
3 kind of Internet account for that computer.
4 A. Yes. Well, Michael told me to call Evvy and
5 see -- because he said he wanted me to get the
6 Internet for the computer.
7 Q. Did you know who Evvy was.
8 A. She was, like, an assistant lady for
9 Michael.
10 Q. Did you do that.
11 A. Yeah.
12 Q. And as a result of that, did you -- did
13 somebody contact you after you talked to Evvy.
14 A. Yeah. It was a guy named David, I think.
15 Q. And what was the purpose for which David
16 contacted you.
17 A. To help -- to tell me how to set up the
18 Internet account, because I didn’t know how.
19 Q. And who paid for that.
20 A. Michael did.
21 Q. Now, when you set up the Internet account,
22 did you have an e-mail address.
23 A. Yes.
24 Q. And where did you -- what was the e-mail
25 address.
26 A. Whitehawk344, I think.
27 Q. Now, you say “whitehawk.” Where did the
28 e-mail address come from. 1537
 

 
1 A. Well, my name “Gavin” in Irish, it means --
2 well, it means a lot of stuff. It means, like,
3 three different things, but one of the things it
4 means is “whitehawk.”
5 Q. So where did you get the idea to do that.
6 A. Because “Gavin” means “whitehawk,” so that’s
7 why I it put on my screen name.
8 Q. Did you have a password.
9 A. Yeah.
10 Q. What was your password.
11 A. Well, it could have been a lot of things,
12 but I think it was “American.”
13 Q. Did you change it from time to time.
14 A. Yes.
15 Q. Do you remember any of the other passwords
16 you used.
17 A. Password 123456, 654321.
18 Q. So you just changed the sequence of the
19 numbers.
20 A. Yeah.
21 Q. One other thing I want to talk to you about.
22 Between the time that -- well, let me ask it this
23 way: Did you ever visit Mr. Jackson at any hotels.
24 A. Yes.
25 Q. Where was that.
26 A. Once at a Universal Hilton.
27 Q. And was this before, during or after the
28 time you had cancer. 1538
 

 
1 A. This is during the time I had cancer.
2 Q. And do you remember how long you visited
3 with him.
4 A. Two hours.
5 Q. And how did you get there.
6 A. My biological father drove me over there.
7 Q. Yesterday you testified about the Bashir
8 video. Do you recall that.
9 A. Yes.
10 Q. And have you ever seen that video from start
11 to finish.
12 A. No, I’ve seen pieces of it, and I saw when
13 he interviewed me, but I didn’t really see the whole
14 thing.
15 Q. So you did see the part that involved you.
16 A. Yes.
17 Q. And when was the first time you saw that.
18 A. Well, when we were -- when I was in Miami,
19 me and Michael, he didn’t want to see it, so we
20 didn’t watch it there. I saw it in my house later
21 when VH-1 was showing it.
22 Q. Was this after you left the ranch for good.
23 A. Yeah, I believe so.
24 Q. Now, that portion of the video that shows
25 you sitting on the couch with Mr. Jackson, there’s a
26 point in time where you place your head on his
27 shoulder and hold hands with Mr. Jackson. Do you
28 recall that part of it. 1539
 

 
1 A. Yes.
2 Q. How did that come about.
3 A. I don’t know. We were just sitting there.
4 Well, the holding hands part, that was one of the
5 things that Michael told me to do. But I put my
6 head on his shoulder.
7 Q. Why did you do that.
8 A. Because -- I don’t know. It was -- like he
9 was -- I was really close to Michael, and he was
10 like my best friend, so I just put my head on his
11 shoulder.
12 Q. Okay. Now, from the time that you had the
13 interview with you and Mr. Jackson and Mr. Bashir
14 till the time that you left to go to Miami, did you
15 have any contact with Mr. Jackson.
16 A. From when I left from Martin Bashir.
17 Q. Right.
18 A. Can you repeat the question.
19 Q. Sure. From the time that you had the
20 interview with Mr. Bashir and Mr. Jackson and you --
21 A. Okay.
22 Q. -- okay. -- till the time shortly before you
23 left for Miami, did you have any contact with Mr.
24 Jackson.
25 A. No.
26 Q. Do you remember when the next contact with
27 Mr. Jackson was.
28 A. Like, right when the stuff came out, when 1540
 

 
1 the video documentary started showing on T.V.
2 Q. How did you find out that the documentary
3 was shown on T.V..
4 A. Well, it was -- it was being showed over in
5 Britain, but they were talking about it on the news
6 and stuff, so that’s how I found out.
7 Q. You actually heard it on the news yourself.
8 A. Yeah.
9 Q. Did any people come around your house at
10 all, that you know of.
11 A. No. I don’t know of any.
12 Q. Now, when you heard it on the news, about
13 the documentary, did you at some point have a
14 telephone conversation with the defendant, Mr.
15 Jackson.
16 A. Yes. He called me.
17 Q. All right. Tell us about the conversation.
18 A. He told --
19 Q. Where were you when you got the call.
20 A. I was in the house, in my house, when -- the
21 first time I moved in with my stepfather. And then
22 he called and wanted me to go to Miami because of
23 all the stuff that was going on. And he said that
24 he wanted to hold a press conference. And he wanted
25 me to be with him.
26 Q. With him --
27 A. During the press conference.
28 Q. What else did he say. 1541
 

 
1 A. He said that he wanted me to go over there.
2 And he said that -- that -- like, we were talking
3 about what was going on. And I was saying, “Ahh,”
4 like, “it’s not right what they’re saying,” and
5 stuff like that.
6 Q. Did Mr. Jackson make comments about -- to
7 you about what was going on.
8 A. No. He just said that he wanted me to go
9 over to Miami.
10 Q. Now, did you go to Miami.
11 A. Yes.
12 Q. Did you go by yourself.
13 A. No.
14 Q. Who went with you.
15 A. It was me, my brother, my sister, and my
16 mom. But at first, Michael didn’t really want -- he
17 only really wanted --
18 MR. MESEREAU: Objection; nonresponsive.
19 Move to strike.
20 THE COURT: Sustained.
21 MR. SNEDDON: I’ll move on from there.
22 THE COURT: The last sentence is stricken.
23 Q. BY MR. SNEDDON: Now, during the
24 conversation with Mr. Jackson - okay.
25 A. Okay.
26 Q. -- did the subject of the rest of your
27 family going to Miami come up.
28 MR. MESEREAU: Objection; leading. 1542
 

 
1 THE COURT: Overruled.
2 You may answer.
3 THE WITNESS: Can you repeat the question.
4 MR. SNEDDON: Yeah.
5 Q. During the time of your conversation with
6 Mr. Jackson, did the subject of the rest of your
7 family coming to Miami come up during the
8 conversation.
9 A. Yes.
10 Q. Would you tell us about it.
11 A. At first I asked him if my brother can come,
12 and then he was like, “Yeah.” And then I asked him
13 if my sister could come, and then he was, like, Uhh,
14 hmm, okay.”
15 And then I asked if my mom could come, but
16 he kind of got angry a little bit about my mom
17 coming. And then -- but I told him, “I can’t come
18 without my mom. My mom probably won’t let me.” And
19 he was like, “Okay,” and my mom came.
20 Q. Did -- during that conversation, did you --
21 did you see -- did you hear your mother talk to Mr.
22 Jackson.
23 A. I don’t really remember.
24 Q. Now, after that telephone conversation, did
25 you go to Miami.
26 A. Yes.
27 Q. With -- and how did you get to Miami.
28 A. I went with Chris Tucker on his private 1543
 

 
1 plane.
2 Q. Do you recall how you got to the plane.
3 A. First we went to his house, and then we put
4 our bags in the bus, and then we went to the
5 airport.
6 Q. And how did you get from your place to his
7 house.
8 A. I’m not sure. I think either I drove over
9 there, or -- yeah, I think I drove over there.
10 Well, my family took me over there.
11 Q. Now, do you remember about what time it was
12 when you left for Miami -- for Miami with Mr.
13 Tucker.
14 A. When we got there, there was -- like,
15 something was going on with the plane or whatever,
16 and we weren’t leaving for a while. And I was -- we
17 stood around for a while. So I think it was maybe,
18 like, 1:00 or 2:00 probably. I’m not sure.
19 Q. Was it still -- was it light or dark out.
20 A. It was light out.
21 Q. When you arrived in Miami, was it light or
22 dark out.
23 A. It was dark.
24 Q. And when you landed in Miami, where did you
25 go.
26 A. We went, all in a limousine, to the hotel.
27 Turnberry Resort, I think it was called.
28 Q. Now, on the plane going there, you’ve told 1544
 

 
1 us that your family was there and that Mr. Tucker
2 was there. Was there anybody else, if you recall,
3 on the plane.
4 A. With -- on Chris’s plane.
5 Q. Yes.
6 A. No.
7 Q. When you got to the airport, you left in a
8 limo, and you went where.
9 A. To the Turnberry Resort in Miami.
10 Q. Do you remember what you did when you got
11 there.
12 A. They put our -- they got our bags and
13 Michael put us up in the room. And then we were in
14 the room, and then -- yeah.
15 Q. And do you recall what you did the next day.
16 A. Yeah, the next day they told us that Michael
17 wanted to see us.
18 Q. Who told you that.
19 A. I forgot. But, I mean, just people. And
20 then so that morning we went up to Michael’s room,
21 and then we went and saw him.
22 Q. Who went up there.
23 A. Me, my mom, my brother, and my sister.
24 Q. And when you got up to Mr. Jackson’s room in
25 the hotel, was Mr. Jackson there.
26 A. Yes.
27 Q. And when you got there, did you meet people
28 that you didn’t know. 1545
 

 
1 A. Yes.
2 Q. Who did you meet.
3 A. Marie Nicole, Aldo. And then these two guys
4 were there, Dieter and Ronald.
5 Q. They were there when you got there.
6 A. Yeah -- well, I don’t know if they were
7 there when I got there, but I just remember I met
8 them in Michael’s room.
9 Q. And do you know what the relationship is
10 between Aldo and Marie Nicole and anybody else that
11 you met there that day or that you know.
12 A. Well, they told us that Marie Nicole and
13 Aldo were related to Frank Tyson. Like brother and
14 sister.
15 Q. Did you see Mr. Tyson that day.
16 A. Um, I don’t think I did.
17 Q. Did you see him at any time that you were in
18 Miami.
19 A. No, I don’t think so.
20 Q. Tell us what you did in Mr. Jackson’s room.
21 A. Well, he wanted me to have a meeting with
22 Ronald and Dieter, and so we went in there, and they
23 were talking about how they’re going to, like --
24 MR. MESEREAU: Objection; hearsay.
25 THE COURT: Sustained.
26 MR. SNEDDON: Your Honor, offered under
27 1223.
28 THE COURT: Well, the question -- it’s not 1546
 

 
1 responsive, so I don’t know that. He’s -- next
2 question.
3 MR. SNEDDON: All right.
4 Q. You told the ladies and gentlemen of the
5 jury you went somewhere with Mr. Jackson, you went
6 into a room with Mr. Jackson.
7 A. Yeah.
8 Q. Who else was in the room.
9 A. Dieter and Ronald.
10 Q. And who else.
11 A. Michael.
12 Q. Now, did you have a conversation with the
13 three of them.
14 A. Yes.
15 Q. All right. Would you tell us about the
16 conversation.
17 And it’s offered under 1223, Your Honor.
18 THE COURT: All right. This is offered
19 conditionally, as my previous instruction covered.
20 Go ahead.
21 THE WITNESS: We just -- Dieter and Ronald
22 told me about how they were going to, like, stop all
23 the media stuff from going on or whatever.
24 Q. BY MR. SNEDDON: Did they say how they were
25 going to do that.
26 A. No, not really. Dieter told me how he’d,
27 like -- he said that he owned, like, the name, the
28 rights to Michael’s name or something like that. 1547
 

 
1 Q. At any time while you were in Miami, did you
2 learn of any threats to you or your family.
3 MR. MESEREAU: Objection; leading.
4 THE COURT: Sustained.
5 Q. BY MR. SNEDDON: Do you recall any other
6 conversations that you had with Dieter or Ronald or
7 Mr. Jackson.
8 A. Not really. Well, there was some -- I had
9 talked with Michael in the room. It’s kind of like
10 connected to his big hotel room.
11 Q. All right. Let me just stop you there. So
12 you had another conversation with Mr. Jackson.
13 A. Yes.
14 Q. Were Dieter and Ronald present.
15 A. Well, first Michael was having, like, a
16 meeting with Ronald. And then Ronald left, and then
17 I went in there and was talking to him.
18 Q. Now, is this the same meeting that you
19 testified to the ladies and gentlemen of the jury,
20 or is this another meeting.
21 A. This is another one.
22 Q. Tell us about that meeting.
23 A. Michael was just, like, talking to me and
24 stuff, asking me how I was, and stuff like that.
25 And he gave me, like, another little audition thing,
26 and he improv’d, if he was a principal of a school,
27 and then a girl said that I did something bad, and
28 then -- 1548
 

 
1 MR. MESEREAU: Objection. Nonresponsive.
2 Move to strike.
3 THE COURT: “Tell us about the meeting” calls
4 for a narrative, so I’ll sustain the objection.
5 Q. BY MR. SNEDDON: Well, tell us what Mr.
6 Jackson said to you in the meeting.
7 A. He was, like, giving me a little audition,
8 and then we were improv-ing.
9 Q. All right. Describe the improv-ing.
10 A. He was, like, the principal of a school, and
11 I was a student that got in trouble because a girl
12 said that I, like, stole something from her or
13 something.
14 Q. How long did this go on between you and Mr.
15 Jackson.
16 A. I think it was like five minutes.
17 Q. Now, did anything else happen between you
18 and Mr. Jackson during your stay at the Turnberry.
19 A. Yes.
20 Q. What.
21 A. He brought me this -- he had poured -- I
22 didn’t really see what he did, but I found out
23 later. Like, I guess --
24 MR. MESEREAU: Objection; calls for
25 speculation.
26 Q. BY MR. SNEDDON: Just tell us what he did,
27 what you saw personally.
28 A. Okay. He brought me -- 1549
 

 
1 THE COURT: Just a moment. I’ll sustain the
2 objection, but you’re asking another question.
3 MR. SNEDDON: I am, Your Honor.
4 MR. MESEREAU: Move to strike, Your Honor.
5 THE COURT: I’ll strike the last half of his
6 answer. Go ahead.
7 Q. BY MR. SNEDDON: All right. Tell us what
8 you saw Mr. Jackson do.
9 A. Michael gave me a Diet Coke can.
10 Q. Did he tell you what was in the can.
11 A. Yeah, he told me that it was --
12 MR. MESEREAU: Objection; leading.
13 THE COURT: Overruled.
14 You may answer “yes” or “no.”
15 THE WITNESS: Michael --
16 Q. BY MR. SNEDDON: Just, did he tell you --
17 “yes” or “no”; did he tell you what was in the can.
18 A. Yes.
19 Q. All right. What did he tell you.
20 A. He told me if I ever heard of Jesus Juice,
21 and then --
22 Q. And what did you say.
23 A. And I said I didn’t know really what it was.
24 Q. And did he say anything after that.
25 A. Yeah, he told me, “You know how, like, Jesus
26 drank wine.” And I was like, “Yeah.”
27 And then he told me, “Well, we call it Jesus
28 Juice.” And then he said that -- to drink it. And 1550
 

 
1 I took a little sip, and I told him it --
2 MR. MESEREAU: Objection. Calls for a
3 narrative; nonresponsive; move to strike.
4 THE COURT: Strike after -- where he starts
5 to say “I took a little sip,” that’s stricken.
6 Q. BY MR. SNEDDON: After Mr. Jackson handed
7 you the can and he told you that it was Jesus Juice,
8 what did you do.
9 A. I drank a little bit of it, and I told him
10 that it tasted ugly.
11 Q. And what did he say.
12 A. He said that, “It’s okay, because it will
13 relax you,” and he told me that he knows that I’m
14 all stressed out because of all the media stuff
15 that’s going on, and that the Jesus Juice will relax
16 me.
17 Q. Now, during -- do you recall how long you’d
18 been in Mr. Jackson’s suite at the time that he
19 provided the alcohol to you.
20 A. I was in there for a while. Like, it was
21 after the second meeting with him in the other room,
22 the improv thing.
23 Q. And from the time that Mr. Jackson gave you
24 the can for the first time and you tasted it, how
25 many times do you think you drank out of that can.
26 A. Well, we went -- well, after he --
27 Q. Just -- first of all, I’ll -- first of all,
28 just how many times, that you estimate. 1551
 

 
1 A. Oh, I probably drank maybe -- I don’t think
2 I drank the whole can, but I probably drank like
3 three-fourths of it or something.
4 Q. Was the can ever refilled.
5 A. I don’t think it -- I’m not sure if it was
6 refilled. I don’t think it was.
7 Q. Had you ever had wine before.
8 A. Well, in church, but that’s about it.
9 Q. Now, did you have any further conversations
10 with Mr. Jackson, other than the ones that you’ve
11 already told the ladies and gentlemen of the jury
12 about, about the wine and drinking it.
13 A. Well, we -- after he told me that, about
14 Jesus Juice or whatever, we went into the living
15 room where everybody was, like Chris was and then my
16 mom, Marie Nicole and Aldo and stuff like that, and
17 we were sitting there, and then Michael was right
18 next to me. And then I don’t think my mom knew what
19 was going on.
20 MR. MESEREAU: Objection. Calls for
21 speculation; narrative; nonresponsive. Move to
22 strike.
23 MR. SNEDDON: Your Honor --
24 THE COURT: Just a moment.
25 What were you going to say.
26 MR. SNEDDON: I’m not going to say it now.
27 I’ll pick it up later.
28 THE COURT: The question was really if you 1552
 

 
1 had any further conversations with Mr. Jackson. You
2 need to listen to the question. Just answer the
3 question. That would have been a “yes” or “no” type
4 question. So I’ll sustain the objection and have
5 you answer that question.
6 I’ll strike the rest of his answer.
7 THE WITNESS: Yes.
8 Q. BY MR. SNEDDON: Where did those
9 conversations take place.
10 A. In the living room.
11 Q. And were there other people present.
12 A. Yes.
13 Q. And what did Mr. Jackson say to you.
14 A. He was, like, telling me to keep drinking
15 the can of the wine.
16 Q. And where were you in the living room.
17 A. I was sitting on the couch, and he was
18 sitting next to me.
19 Q. Were there other people present in the room.
20 A. Yes.
21 Q. Who else was around.
22 A. Chris Tucker, my mom, Aldo, Marie Nicole, my
23 brother, my sister.
24 Q. And you say you were drinking out of a can.
25 What kind of a can.
26 A. Pretty sure it was a Diet Coke can.
27 Q. And do you recall whether -- the kind of
28 wine it was. 1553
 

 
1 A. I’m pretty sure it was white wine.
2 Q. Were there -- how many occasions were you in
3 the bedroom alone with Mr. Jackson.
4 A. At Miami.
5 Q. Uh-huh.
6 A. Once.
7 Q. Were you alone with him in any other rooms
8 in his suite or complex there.
9 A. No.
10 Q. Now, when you woke up the next day, how did
11 you feel.
12 A. Well, I didn’t know if it was from the wine,
13 but I felt really -- like, my head kind of hurt and
14 I felt like I just wanted to lay down.
15 Q. Now, after -- at some point in time that
16 night when you were in Mr. Jackson’s suite -- let me
17 strike that.
18 At some point when you were in Mr. Jackson’s
19 suite, did the subject of the Bashir video come up.
20 A. Yes.
21 Q. Tell us in what connection it came up. Who
22 spoke about it.
23 A. It was going to be shown in America that
24 same night, and it was going to come on, and then
25 Michael didn’t want us --
26 MR. MESEREAU: Objection. Nonresponsive;
27 move to strike.
28 THE WITNESS: Can I have some water. 1554
 

 
1 MR. SNEDDON: Sure. Help yourself.
2 THE COURT: All right. The last three words
3 I’ll strike, or four words, “Michael didn’t want
4 us....” He answered the question up till that
5 point.
6 THE WITNESS: I didn’t want to, like,
7 interrupt anything.
8 MR. SNEDDON: Okay.
9 Q. Now, about the Bashir filming that night,
10 did Mr. Jackson say anything.
11 A. Yeah, he said that he didn’t want --
12 Q. He said something.
13 A. Yes.
14 Q. All right. Tell us what he said.
15 A. He said that he didn’t want to watch it on
16 T.V.
17 Q. So was anybody else interested in watching
18 it.
19 A. Yeah.
20 MR. MESEREAU: Objection.
21 THE COURT: Overruled. Next question.
22 Q. BY MR. SNEDDON: Were they allowed to watch
23 it.
24 A. Not in his room.
25 Q. At some point that night, did you see your
26 mother leave.
27 A. I think so. I think she went back to the
28 room. 1555
 

 
1 Q. Did you -- did you see her later come back
2 to the -- to Mr. Jackson’s suite, or bedroom area,
3 after she left.
4 MR. MESEREAU: Objection; leading.
5 THE COURT: Overruled.
6 You may answer.
7 THE WITNESS: Yes.
8 Q. BY MR. SNEDDON: Now, at some point you left
9 Miami, correct.
10 A. Yes.
11 Q. And how -- when you left Miami, how -- what
12 form of transportation did you take.
13 A. It was in one of Michael’s planes.
14 Q. And how did you get to the plane.
15 A. In a limousine, I think.
16 Q. Now, who was on the plane.
17 A. Me, my brother, my sister, Marie Nicole.
18 Prince, Paris. Grace. My mom. Michael. And me.
19 So it was a pretty packed plane.
20 Q. Now, while you were on the plane, where were
21 you seated.
22 A. I sat next to Michael in the window.
23 Q. I’m sorry.
24 A. I had a window seat and Michael was sitting
25 right next to me.
26 Q. And do you recall who was sitting across
27 from you.
28 A. I think Prince and Paris were sitting in 1556
 

 
1 front of us, but then they kept on -- they got up
2 during the flight, and then other people would sit
3 there and stuff.
4 Q. So were people changing seats during the
5 flight.
6 A. Yes.
7 Q. Did you ever change seats.
8 A. No.
9 Q. Did Mr. Jackson ever change seats.
10 A. I think he got up for something once, but I
11 never moved from that seat.
12 Q. During the course of the flight from Miami,
13 did you ever drink any alcohol.
14 A. Yes.
15 Q. Now, who provided that alcohol to you.
16 A. Michael.
17 Q. And can you tell us in what -- what it was
18 provided to you in.
19 A. I think it was another Coke can or Diet Coke
20 can.
21 Q. And what kind of alcohol was it.
22 A. I think it was white wine again.
23 Q. And where -- did you see where Mr. Jackson
24 got the can from.
25 A. From the little place where they keep all
26 the sodas in the plane.
27 Q. Now, when -- where were you when you
28 physically drank out of the container, the can. 1557
 

 
1 A. I was next to Michael.
2 Q. And did Mr. Jackson say anything to you when
3 he gave you the can.
4 A. Yeah, he told me it was more Jesus Juice.
5 And he said that -- on the plane that -- he told me
6 about how he used to get scared about planes, and he
7 said that if I was scared and -- to drink the Jesus
8 Juice, because it will relax me.
9 Q. How much do you think you drank while you
10 were on the plane.
11 A. I think I drank the whole can.
12 Q. Was the can ever refilled.
13 A. Yes.
14 Q. Do you know how many times.
15 A. No.
16 Q. Were you always drinking out of the same can
17 as Mr. Jackson.
18 A. Yes.
19 Q. Did Mr. Jackson ever say anything to you
20 about him providing alcohol to you.
21 MR. MESEREAU: Objection; leading.
22 THE COURT: Overruled.
23 You may answer.
24 THE WITNESS: Um, yes.
25 Q. BY MR. SNEDDON: Will you tell us what he
26 said.
27 A. He would tell me that -- can you repeat the
28 question again. I’m sorry. 1558
 

 
1 MR. SNEDDON: Would you read it back.
2 (Record read.)
3 THE WITNESS: Yeah, he just told me that he
4 was getting it for me. I don’t really understand
5 too good.
6 Q. BY MR. SNEDDON: Did Mr. Jackson ever give
7 you any presents.
8 A. Yes.
9 Q. Other than the computer.
10 A. Yes.
11 Q. Did he ever give you any presents while you
12 were in Miami.
13 A. Well, he had, like, all these games from EA.
14 Q. I’m sorry.
15 A. EA, Electronic Arts, I think they’re called.
16 They got me a whole bunch of games. And then he let
17 me have all the games that Aldo didn’t really like.
18 Q. When you were on the plane, did Mr. Jackson
19 give you anything.
20 A. Yes.
21 Q. What did he give you.
22 A. As we were taking off -- well, in the hotel,
23 he also gave me a jacket. But when we were taking
24 off on the plane, he showed me a watch, and then he
25 had it on, and he told -- he gave me the watch as we
26 were taking off.
27 Q. Did he say why he gave you the watch.
28 A. He said not to tell anybody about the Jesus 1559
 

 
1 Juice, and he said that this is like a symbol that
2 we’ll be friends forever or something like that.
3 And then he gave me the watch.
4 Q. Did you have his jacket and his watch.
5 A. Yes.
6 Q. During the course of the flight, were you
7 awake the entire time.
8 A. No, I don’t think so. I think I fell asleep
9 once.
10 Q. Do you have any idea how long you were out.
11 A. No.
12 Q. Is there a telephone on this plane.
13 A. Yes.
14 Q. And where is the telephone located.
15 A. It was, like, right next to us. Probably
16 like right here. So I was sitting -- the window was
17 here and Michael was here, and the telephone was
18 right here.
19 Q. And did you see anybody use the telephone
20 during the course of the flight.
21 A. No, I don’t think so.
22 Q. Did you use the telephone during the flight.
23 A. Yeah.
24 Q. Pardon.
25 A. Yes.
26 Q. And what did you use the telephone for.
27 A. I called a friend of mine.
28 MR. SNEDDON: Your Honor, I have an exhibit 1560
 

 
1 marked 343 for identification purposes, a brown bag
2 with contents, and I’ll show it to the witness. And
3 I’m also going to leave in front of the witness a
4 clear plastic bag with the number “342” on it, and
5 the contents of that bag.
6 Q. Gavin, would you take a look at -- just look
7 inside and see if you recognize the item in 343.
8 A. Yes. I recognize the item.
9 Q. What is it.
10 A. It’s a jacket that Michael gave me in Miami.
11 MR. SNEDDON: Move that it be admitted into
12 evidence, Your Honor.
13 MR. MESEREAU: No objection, Your Honor.
14 THE COURT: It’s admitted.
15 Q. BY MR. SNEDDON: Okay. Could you just,
16 Gavin, stand up, and just put the jacket out so that
17 the ladies and gentlemen can see the jacket, the
18 front and the back.
19 Thank you.
20 Now, the next exhibit in front of you is a
21 clear plastic bag.
22 A. Yes.
23 Q. And what’s the number on that exhibit.
24 A. 342.
25 Q. All right. Do you recognize the contents of
26 People’s 342.
27 A. Yes.
28 Q. And what is that. 1561
 

 
1 A. This is the watch that Michael gave me right
2 before the plane took off.
3 MR. SNEDDON: Move that it be admitted into
4 evidence, Your Honor.
5 MR. MESEREAU: No objection.
6 THE COURT: It’s admitted.
7 Q. BY MR. SNEDDON: Yeah, why don’t you --
8 A. Give it to you.
9 Q. No, just stand up and show it to them.
10 Okay. Now I’m going to ask you a question
11 about the watch. With regard to that particular
12 watch, did Mr. Jackson make any statements to you
13 about the value of the watch when he gave it to you.
14 A. He told me that it was $75,000.
15 Q. Now, did you keep that watch.
16 A. Yes.
17 Q. At some point, did you give that watch to
18 somebody.
19 A. Yeah. I think I gave it to Tom.
20 Q. To me.
21 A. I mean -- no, Larry.
22 Q. Larry.
23 A. Yes.
24 Q. Do you know who Larry is.
25 A. Larry Feldman, I think.
26 Q. And do you remember when that was. Had you
27 left Neverland for the last time.
28 A. Yes. 1562
 

 
1 Q. And that’s -- and after that, you gave the
2 watch to him.
3 A. Yes.
4 Q. Now, when you were at Neverland Ranch, did
5 anybody ever ask you to give the watch back.
6 MR. MESEREAU: Objection; leading.
7 THE COURT: Overruled.
8 You may answer.
9 THE WITNESS: No.
10 Q. BY MR. SNEDDON: Now, let’s go back to the
11 flight just a second, if we can. All right.
12 A. Uh-huh.
13 Q. Where was your brother Star on the plane.
14 A. He was walking around on the plane.
15 Q. Did you ever see Star drink out of the soda
16 can.
17 A. Yes.
18 Q. Tell the jury what happened.
19 A. We called my brother Star over, and Michael
20 asked him if he knew what Jesus Juice was. And then
21 we gave him the can and we just told him to drink
22 it. And then when he drank it, he said that it
23 tasted bad, and so, like -- I don’t know. That’s
24 what happened.
25 Q. Did you see the expression on his face when
26 he drank it.
27 A. Yeah, he acted like it was a gross-tasting
28 taste, face. I don’t know how to say it. 1563
 

 
1 MR. SNEDDON: I have another exhibit we’re
2 going to spend a little time with.
3 THE WITNESS: Okay.
4 MR. SNEDDON: Your Honor, this exhibit is -
5 I’m sorry, Counsel - 344 for identification
6 purposes. I’m going to hand this to the witness.
7 And why don’t you hand me those two things right
8 there.
9 Take that. And here’s a pen. Don’t do
10 anything yet.
11 Q. All right. Do you recognize the exhibit
12 that I’ve just placed in front of you.
13 A. Yeah, it looks like the inside of the plane
14 that we were in.
15 MR. SNEDDON: All right. Your Honor, I’m
16 going to move that be admitted into evidence for the
17 purpose of illustrating his testimony.
18 MR. MESEREAU: I have no objection.
19 THE COURT: It’s admitted.
20 MR. SNEDDON: Okay. We’re going to put a
21 diagram on the board -- on the Elmo in just a
22 second.
23 This is a laser.
24 THE WITNESS: Okay.
25 MR. SNEDDON: Go ahead. Put it up.
26 MR. AUCHINCLOSS: It should be coming up.
27 THE BAILIFF: It will take a moment.
28 Q. BY MR. SNEDDON: Okay. Gavin -- 1564
 

 
1 A. Yes.
2 Q. -- I want you to look up on the board, and
3 ask if you can show the ladies and gentlemen of the
4 jury where you were seated on the plane.
5 Okay. So you’re indicating in the middle of
6 the diagram, correct.
7 A. Yes.
8 Q. Now, on the chart that’s in front of you -
9 okay. - 344 --
10 A. Yes.
11 Q. -- I want you to take that pen I gave you
12 and I want you to put your initials in the seat that
13 you’ve just showed to the ladies and gentlemen of
14 the jury.
15 Now, I want you to show the ladies and
16 gentlemen of the jury where Mr. Jackson was seated,
17 sitting.
18 Okay. It’s the one right next to you,
19 closest to the aisle; is that correct.
20 A. Yes.
21 Q. Would you put an “MJ” on the seat where he
22 was located.
23 Now, do you recall where your brother Star
24 was sitting at the time that he was offered the can
25 with the alcohol in it by Mr. Jackson.
26 A. I don’t think he was sitting. He was
27 standing, and he was --
28 Q. Where was he standing. 1565
 

 
1 A. Right there.
2 Q. Right in that area.
3 A. Yes.
4 Q. Would you put your brother’s initials -- and
5 by “that area,” you’re meaning in the aisle at the
6 end of the table, correct.
7 A. Yes.
8 Q. Okay. Just put your brother’s initials
9 where you....
10 Now, do you remember where your mom was
11 sitting.
12 A. I think she was sitting over here somewhere.
13 Q. Okay. Move the diagram, if you would. Do
14 you think she was down there.
15 A. Yeah, I think so.
16 Q. Okay. Put your mother’s initials in there,
17 if you would. And by “there,” we mean on the upper
18 side of the diagram with the chair that’s the
19 farthest to the left.
20 A. Okay. What do I put. “JJ” or --
21 Q. “JA.”
22 Do you remember where any other of the
23 people on the plane were sitting.
24 A. I’m not sure, but Prince and Paris started
25 out right there. And then I think Grace was in
26 there.
27 Q. Okay. Why don’t you -- where you say Prince
28 and Paris were, put two “P’s” on your diagram, 344. 1566
 

 
1 A. Okay.
2 Q. And you mentioned a person by the name of
3 Grace. Who is that, to your knowledge.
4 A. It’s like -- like Prince and Paris’s
5 guardian lady.
6 Q. Okay. So why don’t you put a “G” where you
7 think that the individual you knew as Grace was
8 sitting.
9 All right. Anybody else. Do you remember
10 where Aldo and Marie Nicole were sitting.
11 A. I’m not sure. I think they might have been
12 sitting on those things.
13 Q. On the area in blue.
14 A. Yeah.
15 Q. Okay.
16 A. I don’t know.
17 Q. But you’re not sure.
18 A. No.
19 Q. Okay. And how about your sister.
20 A. I think she was sitting there.
21 Q. Was she there the whole time.
22 A. No.
23 Q. Did you see where she moved to.
24 A. I don’t know. I’d just see her pass by. We
25 were all sitting sometimes.
26 Q. You indicated for your sister a seat that’s
27 up on the front part of the left side of the diagram
28 on the lower side of the plane, correct. 1567
 

 
1 A. Yeah.
2 Q. All right. Why don’t you put your sister’s
3 initials in there, then.
4 A. Okay.
5 Q. All right. I think we’re done with that.
6 A. Okay.
7 MR. SNEDDON: We can turn the lights back
8 on, Your Honor.
9 Put the cap on the pen, if you would,
10 please. Thanks, Gavin.
11 Q. Gavin, do you know what it means to be
12 intoxicated.
13 A. Yes.
14 Q. What’s that mean, in your words.
15 A. When you have a lot of alcohol in your
16 system.
17 Q. When you were on the plane, did you feel
18 intoxicated.
19 A. I don’t know. I don’t think so. Well,
20 maybe a little.
21 Q. Okay. Do you remember when you landed in
22 the plane whether it was daylight or dark outside.
23 A. I think it was -- it was dark.
24 Q. And when you landed, where did you go.
25 A. We went to Neverland.
26 Q. And how did you get there.
27 A. Michael had, like, this big SUV, white,
28 limousine. 1568
 

 
1 Q. And when you got to Neverland Ranch, where
2 did you spend the night.
3 A. I’m pretty sure we spent the night in
4 Michael’s room.
5 Q. You say “we.” Who is “we”.
6 A. Me and my brother.
7 Q. Do you remember if anything happened that
8 particular night.
9 A. When we got there, me and my brother ran
10 straight to the carts, because we wanted to ride the
11 carts, drive the carts around. But then we went to
12 Michael’s room and we slept there, and we all slept
13 in the bed together.
14 Q. In whose bed.
15 A. Michael’s.
16 Q. Now, are you familiar with a person by the
17 name of Jesus.
18 A. Yes.
19 Q. And where did you meet Jesus.
20 A. At the ranch.
21 Q. And to your knowledge, what was Mr. -- what
22 was Jesus’s responsibility.
23 A. I think he was like the manager of the
24 ranch.
25 Q. Now, after you got back from Miami and you
26 were on Neverland Ranch - okay. - at some point did
27 Jesus take you somewhere.
28 A. Yes. 1569
 

 
1 Q. Where did he take you.
2 A. He took us back to my grandma’s house.
3 Q. When you say he took “us,” who is “us”.
4 A. Me, my mom, my brother, my sister.
5 Q. Now, I want to talk about some things that
6 happened between the time that you got back from
7 Miami and you went to the ranch --
8 A. Uh-huh.
9 Q. -- okay. -- till the time that Mr. Salas,
10 I’m sorry, that Jesus took you to your grandmother’s
11 place, okay.
12 A. Okay.
13 Q. Now, you told us that the first time that
14 night you spent in Mr. Jackson’s room and you slept
15 in his bed, along with your brother and Mr. Jackson.
16 From the time you got back from Miami till the time
17 you left with Jesus, where did you sleep.
18 A. Can you repeat the question. I’m sorry.
19 Q. Uh-huh. From the time you got back from
20 Miami and you went to the ranch --
21 A. Okay.
22 Q. -- okay. -- till the time you left with
23 Jesus - all right. - where did you sleep.
24 A. Whenever Michael was there, we would all
25 sleep in Michael’s room.
26 Q. Was Mr. Jackson there during that time
27 period.
28 A. Yeah. 1570
 

 
1 Q. During the time after you got to the ranch,
2 when the limousine took you from the airport to
3 Neverland Valley Ranch, till the time you left with
4 Jesus, did you ever have any more alcohol.
5 A. Yes.
6 Q. On how many occasions.
7 A. Every night that Michael was there.
8 Q. All right. Do you remember where you drank.
9 A. We would -- like, in the arcade, because
10 that’s where the wine cellar was. Well, it’s kind
11 of like a wine cellar.
12 Q. You say “we.” Who’s “we”.
13 A. Me, my brother, Michael mainly.
14 Q. And how did you get into the wine cellar.
15 A. Michael would take us there.
16 Q. Can you tell the ladies and gentlemen of the
17 jury, just describe how you get down there.
18 A. Okay. In the back of the main house,
19 there’s an arcade. And then, like, you walk across,
20 and there’s a pool to the right, and then you go
21 inside the arcade.
22 And then, like, there’s this jukebox, and
23 then you have to move the jukebox. And then you
24 walk down these stairs, and there’s a door that you
25 open. It’s kind of like to the right. And then you
26 walk in there, and there’s no alcohol in the first
27 room. There’s, like, sleeping bags, I think, like a
28 little green couch. 1571
 

 
1 And then you walk through, and then to the
2 right there’s another door, and then there’s like
3 this hallway kind of thing, and then that’s where,
4 like, all the alcohol was, in refrigerators and
5 stuff like that.
6 Q. And who was it that took you down to that
7 area the first time.
8 A. Michael.
9 Q. Did you ever go down there without Mr.
10 Jackson.
11 A. No. Well, we went down there once. That
12 was just because we wanted to, like, look at the
13 little green thing that they had there with all the
14 trees and stuff on there. It was kind of like a
15 model thing.
16 Q. Did you ever go down there and drink any
17 alcohol without Mr. Jackson being present.
18 A. No.
19 Q. And you said “we” went down there to look at
20 these little green things. Who was it that went
21 with you.
22 A. Me and my brother.
23 Q. Was it a time when Mr. Jackson was on the
24 ranch.
25 A. Yes.
26 Q. Now, were there any other locations on the
27 ranch where you drank with Mr. Jackson.
28 A. Yes. 1572
 

 
1 Q. Where.
2 A. In his office and in his room.
3 Q. And would this be during the same time
4 period we’re talking about, from the time period
5 from when you got there from Miami till the time you
6 left with Jesus.
7 A. If it happened.
8 Q. Yes.
9 A. Yes.
10 Q. Was there ever any occasion that you drank
11 something other than wine.
12 A. Yes.
13 Q. Tell us what it was.
14 A. I drank Bacardi, vodka and Jim Bean.
15 Q. Jim what.
16 A. Jim Bean, I think it was called.
17 Q. Did you say “bean”.
18 A. Bean.
19 Q. Can you spell it.
20 A. B-e-a-n.
21 Q. Okay. And who provided you with the
22 Bacardi.
23 A. Michael.
24 Q. Who provided you with the Jim Bean.
25 A. Michael.
26 Q. And who provided you with the vodka.
27 A. Michael.
28 Q. Did Mr. Jackson ever say anything to you 1573
 

 
1 about drinking and providing this alcohol to you.
2 A. No, he just said, like, well, it’s Jesus
3 Juice and it was okay because Jesus drank it, and
4 stuff like that.
5 Q. Did you ever tell Mr. Jackson that you only
6 had one kidney.
7 A. Yes.
8 Q. And did you ever tell Mr. Jackson anything
9 about alcohol and your kidney.
10 MR. MESEREAU: Objection; leading.
11 THE COURT: Sustained.
12 Q. BY MR. SNEDDON: Did you ever have a
13 conversation with Mr. Jackson about your kidneys.
14 A. Yes.
15 Q. Kidney.
16 A. Kidney, yeah.
17 Q. Sorry. What did you tell him.
18 A. I told him that it was bad for me to drink
19 alcohol. And he said it’s okay; that it’s fine;
20 that nothing’s going to happen.
21 Q. Do you recall how many occasions you had
22 that conversation with Mr. Jackson.
23 A. I think like three times.
24 Q. I couldn’t hear you.
25 A. Maybe like three times.
26 Q. And where was it when you had these
27 conversations with Mr. Jackson.
28 A. I think once was in the office and the other 1574
 

 
1 two times were in kind of like the wine cellar
2 thing.
3 Q. Were there times that you went down to the
4 wine cellar where your brother wasn’t present.
5 A. It was just me and Michael.
6 Q. Yes.
7 A. Yes.
8 Q. How many times do you think that just you
9 and Michael went down to the wine cellar. Now, I
10 want to stay -- that was a bad question. Let me
11 just start over again. Okay.
12 A. Okay.
13 Q. I want to focus on the time where you got
14 there from Miami and the limo took you to the ranch
15 till the time that you left with Jesus, okay.
16 A. Okay.
17 Q. Did you ever go to the wine cellar with just
18 you and Mr. Jackson.
19 A. Yes.
20 Q. And on how many occasions was it just you
21 and Mr. Jackson in the wine cellar.
22 A. Not many. But, like, maybe five times
23 between Miami and Jesus.
24 Q. During the time that you were there from
25 Miami to Jesus, did you ever drink in the bedroom.
26 A. Yes.
27 Q. How many times do you think that was.
28 A. A lot, because we would sleep in his room, 1575
 

 
1 and then we would take the Jesus Juice up there.
2 Q. So you’d take the stuff up there to drink.
3 A. Yes.
4 Q. Now, let me ask you a question: Do you know
5 what the term “crank call” means.
6 A. Yes.
7 Q. Tell the jury what “crank call” means.
8 A. When you call, like, a person that doesn’t
9 know you, and you, like, say something or make fun
10 of them and it will make you laugh, the people that
11 are making the phone call.
12 Q. Did you ever make any crank calls from Mr.
13 Jackson’s residence.
14 A. Yes.
15 Q. Where were you when you made them.
16 A. In his room mainly.
17 Q. Was there anybody else present.
18 A. Yes.
19 Q. Who.
20 A. My brother.
21 Q. And anybody else.
22 A. Aldo.
23 Q. Anybody else.
24 A. Michael. I guess that’s it. Yeah, that’s
25 it.
26 Q. Did anybody else make any crank calls
27 besides you.
28 A. We were all making crank calls. 1576
 

 
1 Q. You say “we were all.” Who do you mean by
2 “we”.
3 A. Aldo, Michael, me, my brother.
4 Q. And in connection with making these calls,
5 was there anything that -- do you know what it means
6 when the call doesn’t go through, you don’t get
7 somebody.
8 A. Yes.
9 Q. What happened when you did that.
10 A. Oh, this happened once. We had this big --
11 like, it was a bottle of wine, it was like that big.
12 And we made up this game. If you make a phone call
13 and, like, we would dial random numbers, and if it
14 rang and nobody picked up, you have to take a big
15 gulp of wine. Because we didn’t really like how it
16 tasted, so we made up that game.
17 Q. “So” what.
18 A. We didn’t really like how it tasted, so we
19 made that game up so we would have a drink, a gulp
20 of wine, if the call didn’t go through.
21 Q. Did anybody have to drink because the call
22 didn’t go through that night.
23 A. Yeah.
24 Q. You have that look on your face like it was
25 you.
26 A. Yeah, it was me.
27 Q. Anybody else.
28 A. I think my brother once or twice. It’s 1577
 

 
1 because, like, I would always -- because I kind of
2 liked making crank calls, so I would make a lot of
3 them, and so then a lot of them wouldn’t go through.
4 Q. During the time you were at the ranch again,
5 from the time you got there in the limo till the
6 time you left with Jesus, do you know where your
7 mother was staying.
8 A. In her unit.
9 Q. In her what.
10 A. In her unit that they gave her.
11 Q. And did you ever go visit her.
12 A. Yes.
13 Q. How many times do you think you visited her.
14 A. Like, three times a week.
15 Q. And did you have -- don’t tell us what she
16 said, just tell us -- I want to know, did you have
17 any conversations with her.
18 A. Yes.
19 Q. Did you ever have any conversations with her
20 about leaving.
21 A. Yes.
22 Q. Did you want to leave, you personally.
23 A. Not really, because I was kind of having
24 fun.
25 Q. Could you describe your mother’s demeanor or
26 attitude during the time that you’d visit her.
27 A. She was scared and she wanted to leave, and
28 she was -- 1578
 

 
1 MR. MESEREAU: Objection. Move to strike;
2 nonresponsive.
3 THE COURT: The last part of the answer is
4 stricken after “she was scared.”
5 MR. SNEDDON: Your Honor, I believe that I’m
6 offering the second part of it with regard to
7 conduct in conformance with the state of mind. It
8 was an exception.
9 THE COURT: The question was, “Could you
10 describe your mother’s demeanor or attitude.” Which
11 he then started describing her actions, so it’s
12 nonresponsive.
13 MR. SNEDDON: All right. I’ll break it up.
14 Q. Did your mother tell you that she wanted to
15 leave.
16 MR. MESEREAU: Objection. Hearsay; and
17 leading.
18 THE COURT: Further foundation would be
19 necessary.
20 MR. SNEDDON: All right.
21 Q. Were -- the conversations that you had with
22 your mother, where were they.
23 A. They were usually in her room.
24 Q. And how did the topics about her being
25 scared come up. Don’t tell us what was --
26 MR. MESEREAU: Objection.
27 Q. BY MR. SNEDDON: Just tell us who brought
28 the subject matter up. 1579
 

 
1 A. She did.
2 MR. MESEREAU: Objection. Foundation;
3 leading.
4 THE COURT: Overruled. Proceed with the
5 foundation.
6 MR. SNEDDON: I’m sorry.
7 Q. Who brought them up.
8 A. My mom.
9 Q. And were there any other persons present.
10 A. No, I don’t think so.
11 Q. During those conversations -- how many
12 conversations do you think you had with her about
13 the fact that she was scared.
14 A. Like every time I would go there.
15 Q. During those conversations, did she tell you
16 anything about whether or not she wanted to be on
17 the ranch.
18 A. Yes.
19 MR. MESEREAU: Objection. Hearsay;
20 foundation.
21 THE COURT: Overruled. State of mind.
22 Q. BY MR. SNEDDON: You may answer.
23 A. Yes.
24 Q. What did she tell you.
25 A. She told me that she was afraid that they
26 were going to kill us, and then that she wanted to
27 leave.
28 Q. Now, when you got back to the ranch -- back 1580
 

 
1 to the ranch, Neverland Valley Ranch, after you came
2 from Miami - okay. -- I think there’s a better way.
3 Let me do it this way.
4 Your Honor, I’m just going to -- instead of
5 showing them on the overhead, I’m just going to show
6 them to the witness because they’ve been up so many
7 times already, with the Court’s permission.
8 THE COURT: All right.
9 MR. MESEREAU: Excuse me, are they all in
10 evidence.
11 MR. SNEDDON: Yes. No, I’d show you
12 anything new.
13 Q. I’m going to show you a photograph. I’ll
14 just put these in front of you. Okay.
15 A. Okay.
16 Q. I’ll show you a photograph marked
17 People’s 28. Do you recognize the person in that
18 photograph.
19 A. Yes.
20 Q. Who is that.
21 A. Jamie Masada.
22 Q. All right. Why don’t you turn the next one
23 over. Just show it to the jury, if you would, for
24 just a second.
25 All right. Do you recognize the person
26 depicted in that photograph.
27 A. Yes.
28 Q. Who is that. 1581
 

 
1 A. Dieter.
2 Q. Okay. Turn it over.
3 The next one, what’s the number on that.
4 A. 18.
5 Q. 18. And who is that.
6 A. Ronald.
7 Q. Okay. Turn it over.
8 And the next one. All right. Who is that,
9 and what’s the number on that. Is that 20.
10 A. 20.
11 Q. All right. Who is that.
12 A. Frank.
13 Q. Turn that one down.
14 Does Frank have a last name, that you know
15 of.
16 A. Tyson.
17 Q. All right. The next one is what number.
18 21.
19 A. Yes.
20 Q. All right. Who’s that.
21 A. Aldo.
22 Q. All right. Why don’t you turn that one
23 over.
24 And the last one is 22.
25 A. Yes.
26 Q. And who is that.
27 A. That’s Marie Nicole.
28 Q. All right. Just go ahead and turn that one 1582
 

 
1 over.
2 Now, let me ask you a question about the
3 people you’ve identified as Dieter and Ronald.
4 Okay.
5 A. Okay.
6 Q. Now, when you got back from -- from Miami
7 and you went to the ranch - okay. - and before you
8 left with Jesus, same time period --
9 A. Okay.
10 Q. -- did you see either Dieter or Ronald at
11 Neverland Valley Ranch.
12 A. No, I don’t think so.
13 Q. Did you ever see them at the ranch.
14 A. Yes.
15 Q. When do you think you saw them there.
16 A. I think I saw them when we came back when --
17 after we left with Jesus.
18 Q. Now, you’ve identified the photograph of Mr.
19 Tyson.
20 A. Yes.
21 Q. And did you see Mr. Tyson at the ranch.
22 A. I don’t know. I don’t think so.
23 Q. During the entire time you were there, you
24 don’t recall seeing him.
25 A. Yeah, I remember seeing him there at
26 Neverland.
27 Q. Oh, okay. Do you recall when it was you saw
28 him there. 1583
 

 
1 A. I don’t remember the first time.
2 Q. Do you remember on how many occasions you
3 saw him there.
4 A. No. But I saw him there a lot. Well --
5 Q. I can’t hear you.
6 A. No, but I saw him there.
7 Q. Did you ever see -- the two people that you
8 talked about there, Dieter and Ronald - okay. --
9 A. Okay.
10 Q. -- were they at the ranch at the same time
11 as Mr. Jackson.
12 A. Yes, I believe so.
13 Q. Did you ever see them together.
14 A. I think so. I did once or twice.
15 Q. All right. You left with the person you’ve
16 identified to the jury as a person by the name of
17 Jesus. Do you recall that.
18 A. Yes.
19 Q. And you told us you went to your
20 grandparents’ place. What time was it when you left
21 with Jesus.
22 A. Late at night.
23 Q. And do you recall who it was that -- well,
24 was it the person you knew as Jesus who did the
25 driving.
26 A. Yes.
27 Q. When you got to your grandparents’ place,
28 did you ever go back to Neverland Valley Ranch after 1584
 

 
1 that.
2 A. Yes.
3 Q. And do you recall how many days there were
4 in between the time you left and the time you went
5 back.
6 A. I’m not sure. I think a few days.
7 Q. Do you ever recall, during the time that you
8 were off of the ranch, having a telephone
9 conversation with Frank Tyson.
10 A. Yes.
11 Q. And where were you when you received -- when
12 you participated in that telephone conversation.
13 A. I’m not sure.
14 Q. Do you recall who else was present during
15 the conversation.
16 A. My mom.
17 Q. And did you talk to Mr. Tyson.
18 A. Yes.
19 Q. And what did Mr. Tyson say to you.
20 And it’s offered under 1223, Your Honor.
21 THE COURT: All right. I’m accepting this
22 testimony conditionally, as before.
23 MR. MESEREAU: Objection noted, Your Honor.
24 THE COURT: Noted.
25 MR. MESEREAU: Thank you.
26 THE WITNESS: He was telling me about that
27 they were scared that something was going to happen
28 to me, and that they were worried, and they wanted 1585
 

 
1 us to come back up, stuff like that.
2 Q. BY MR. SNEDDON: Did you ever make any
3 complaints to Mr. Tyson.
4 A. Yeah.
5 Q. And what complaint did you make to Mr.
6 Tyson.
7 A. That I didn’t like the -- Dieter and Ronald.
8 Q. And why did you say that.
9 A. Because they had my mom worried, really.
10 And my mom was scared of them, so....
11 Q. Where was it that your mom had contact with
12 Dieter and Ronald.
13 MR. MESEREAU: Objection; foundation.
14 THE COURT: Sustained.
15 Q. BY MR. SNEDDON: Do you know where it was
16 that your mother had contact with Ronald or Dieter.
17 A. Now that I think back, I think it was at
18 Neverland, so I think they were there before we left
19 with Jesus. Or it could have been a phone call.
20 Q. I couldn’t -- all right. So you -- you
21 voiced a complaint to Mr. Tyson on the phone.
22 A. Yes.
23 Q. And what did Mr. Tyson say to you about the
24 complaint. Do you recall anything.
25 A. He said that we’ll never have to see them
26 again.
27 MR. MESEREAU: Objection, hearsay.
28 MR. SNEDDON: Offered for the same purpose, 1586
 

 
1 Your Honor.
2 THE COURT: All right. I’ll allow the
3 testimony under the conditional admittance of
4 hearsay that I’ve ruled on before.
5 I’m a little concerned, though. It’s not
6 clear to me --
7 MR. SNEDDON: How about if I go back and ask
8 a clarifying question. I think I know where the
9 Court’s going.
10 THE COURT: All right.
11 MR. SNEDDON: I might be able to help the
12 Court.
13 Q. You told the ladies and gentlemen of the
14 jury that you had a telephone conversation with
15 Mr. Tyson at some point after you had left the ranch
16 with Jesus; is that correct.
17 A. Yes.
18 Q. And that your mother was present during that
19 conversation.
20 A. Yes.
21 Q. And that you personally talked to Mr. Tyson.
22 A. Yes.
23 Q. All right. Now, you were about to tell us
24 something that Mr. Tyson said, and I believe -- if
25 you could do that.
26 And again, it’s offered for the same reason,
27 Your Honor.
28 MR. MESEREAU: Objection; hearsay. 1587
 

 
1 THE COURT: I’ll admit it conditionally.
2 Q. BY MR. SNEDDON: Go ahead.
3 A. He just told me that I would never have to
4 see them again.
5 Q. See “them,” meaning who.
6 A. Dieter and Ronald.
7 Q. Now, at some point you went back to the
8 ranch --
9 A. Yes.
10 Q. -- is that correct.
11 And do you recall how you got back there.
12 A. I’m not too sure.
13 Q. Who went back with you.
14 A. Me, my mom, my brother, my sister.
15 Q. And when you got back to the ranch, do you
16 recall whether -- what time of the day or night it
17 was.
18 A. No.
19 Q. When you got back to the ranch, do you
20 recall whether or not you saw Dieter or Ronald.
21 A. Yes.
22 Q. Do you recall where they were when you saw
23 them.
24 A. I think I saw Dieter in the kitchen sitting
25 on the stool thing. And he’s saying that we were
26 going to, like, go to --
27 Q. You’re going to have to talk into that and
28 not mumble. 1588
 

 
1 A. And he told us that he wanted to, like, go
2 to Australia or Brazil, or something like that, for
3 a vacation.
4 Q. Do you know whether or not your mom remained
5 on the ranch, or left that night or that day that
6 you got back.
7 A. I think that was the day that she went down
8 to see my now stepdad.
9 Q. I can’t hear you.
10 A. I think that was the day that she went down
11 to go see my now stepdad.
12 Q. Now, during the time that you were at
13 Neverland Valley Ranch, you’ve told us that you were
14 in Mr. Jackson’s bedroom and in his bed, correct.
15 A. Yes.
16 Q. Now, how do you get into Mr. Jackson’s
17 bedroom.
18 A. You walk through these big double doors, and
19 then -- and then you walk to the other door, and
20 then you punch in a code, and then there are two
21 other double doors, the little lock goes off, and
22 then you can open the door, and then -- and that’s
23 his room.
24 Q. Now, are there any -- does anything go off
25 when you get to a certain point --
26 A. Yes.
27 Q. -- that you’re walking down the hallway.
28 A. Yes. 1589
 

 
1 Q. What is it that goes off.
2 A. Well, when you go in the first door, it goes
3 like this, a little ringing sound goes off. And
4 then when you punch in the code, another -- it goes
5 off again.
6 Q. Can you hear from the outside of -- when it
7 goes off.
8 A. Yes.
9 Q. Can you tell us what it sounds like.
10 A. “Dee-doo, dee-doo.” Sounds like that.
11 Q. And do you recall how many times it goes --
12 I’m not going to imitate you -- how many times it
13 does that.
14 A. I’m not sure. I think it was like -- maybe
15 like three times.
16 Q. Now, where did you get the code to get into
17 Mr. Jackson’s bedroom or into his bedroom suite.
18 A. Michael.
19 Q. Pardon.
20 A. Michael.
21 Q. Was there more than one code to get in
22 there.
23 A. Yeah, I think so. Because the nurse -- I
24 mean, not the nurse. The maid lady would punch in a
25 different code than the one I knew.
26 Q. So did you get another set of codes from
27 somebody.
28 A. Oh, from -- for the other -- well, there’s 1590
 

 
1 another door to the main house that I knew a code
2 for.
3 Q. You did or did not.
4 A. Did.
5 Q. All right. Where did you get that
6 information from.
7 A. Either it was Michael that gave it to me or
8 the maids gave it to me. Because they change it
9 sometimes, so --
10 Q. Now, do you remember -- you told us that
11 some of the times that you drank vodka with Mr.
12 Jackson, correct.
13 A. Yes.
14 Q. Do you ever remember a situation -- what
15 effect did the vodka have on you.
16 A. Well, there was just one time -- well, vodka
17 really tasted --
18 Q. You’re going to have to lean into that and
19 talk so we can hear you.
20 A. I don’t really understand what you’re --
21 Q. What effect did the vodka have on you.
22 A. What did it make me feel like.
23 Q. Yeah.
24 A. Well, there was one time where -- where the
25 first time that Michael introduced me to vodka, he
26 had, like, a glass about that big --
27 MR. MESEREAU: Objection. Calls for a
28 narrative; nonresponsive. 1591
 

 
1 THE COURT: It’s nonresponsive.
2 Q. BY MR. SNEDDON: All right. Did Mr. Jackson
3 provide vodka to you.
4 A. Yes.
5 Q. And how did he -- and what did he provide it
6 to you in.
7 A. In a glass about that big.
8 Q. So you’re indicating maybe two or three
9 inches.
10 A. I guess. I don’t know.
11 Q. And what kind of a glass -- where were you
12 when he provided it to you.
13 A. I was in the wine cellar.
14 Q. And did you see him pour the vodka into it.
15 A. No.
16 Q. Did you know what it was when you first
17 sipped it.
18 A. No.
19 Q. How was it that you ended up drinking that
20 particular glass.
21 A. I walked down there, because I asked where
22 Michael was -- well, we were in the arcade, and
23 that’s what we usually kind of did. And then so I
24 went down to the wine cellar and I saw Michael
25 there, and then Michael had the glass poured. And
26 then I asked him what that was, and he said, “Drink
27 it.” And then he said like --
28 MR. MESEREAU: Objection. 1592
 

 
1 MR. SNEDDON: All right.
2 MR. MESEREAU: Nonresponsive.
3 Q. BY MR. SNEDDON: What did he say to you.
4 A. He told me to drink the --
5 THE COURT: Just a moment. There’s an
6 objection pending, or just to the narrative.
7 MR. MESEREAU: Narrative, Your Honor.
8 THE COURT: Go ahead with your next question.
9 Q. BY MR. SNEDDON: What did he say to you.
10 A. He told me to drink the vodka.
11 Q. And did you do that.
12 A. Yes, but I didn’t know it was vodka. I
13 thought it was water, because it’s, like, clear.
14 Q. Okay.
15 A. So I drank it really fast like if it was
16 water. And then I didn’t really -- when I brought
17 it to my nose, it smelled like rubbing alcohol, and
18 then I chucked it back really quick, and it started
19 burning. Well, I, like, took down the whole thing,
20 but it really burned.
21 And then like two or three seconds later my
22 head started -- like it looked like the room was
23 spinning, so I put my head inside the couch. You
24 know the green couch that I was talking about. I
25 put my head inside it so I couldn’t see the room
26 spinning, because it was kind of hurting.
27 Q. Why did you do that. Why did you put your
28 head into the couch, in the pillow. 1593
 

 
1 A. I -- I remember when I was a little, we’d
2 spin around a lot when we play. I would close my
3 eyes or put my head into a pillow or something, so
4 that way I wouldn’t see the room spin.
5 Q. Was that the only occasion that you drank
6 vodka with Mr. Jackson.
7 A. No.
8 Q. Were there other occasions.
9 A. Yeah.
10 Q. How many, do you think, where you had vodka
11 with Mr. --
12 A. I’m not sure. Because when we’d drink wine,
13 we’d usually have a little bit of vodka, so -- a lot
14 of times.
15 MR. SNEDDON: Your Honor, at this time I
16 have an exhibit marked as 345 for identification
17 purposes. And I’ve shown it to Mr. Sanger, but I’ll
18 show it to other counsel.
19 (Off-the-record discussion held at counsel
20 table.)
21 Q. BY MR. SNEDDON: Okay, Gavin.
22 A. Okay.
23 Q. I put in front of you an item marked as
24 Exhibit 345. Okay.
25 A. Yes.
26 Q. Do you recognize that.
27 A. Yes.
28 Q. Were you asked to look at that last night. 1594
 

 
1 A. Yes.
2 Q. And with regard to looking at that, were you
3 asked to see if you recognized the material that’s
4 on that video.
5 A. Yes.
6 Q. And did you.
7 A. Yes.
8 MR. SNEDDON: I move that it be admitted and
9 played to the jury, Your Honor.
10 MR. MESEREAU: Your Honor, we’re going to
11 object on foundation grounds. We’ve reviewed that.
12 There are severe problems with the accuracy of that.
13 BAILIFF CORTEZ: Can’t hear you, Mr.
14 Mesereau.
15 MR. MESEREAU: Oh. Pardon me.
16 THE COURT: Do you want to restate your
17 objection.
18 MR. MESEREAU: Yes, Your Honor. We have
19 reviewed the DVD. We strongly object on foundation
20 grounds and authenticity grounds. We think it’s a
21 mischaracterization and a misrepresentation of what
22 it tries to depict, and we have factual reasons for
23 that.
24 THE COURT: What is it a DVD of.
25 MR. SNEDDON: It’s the chimes that go off
26 when you go in the door.
27 THE COURT: Oh.
28 MR. SNEDDON: And it was -- I won’t say 1595
 

 
1 anything more, unless you want me to.
2 MR. MESEREAU: It’s inaccurate, Your Honor.
3 THE COURT: That’s subject to
4 cross-examination, though.
5 MR. MESEREAU: Your Honor, I think --
6 THE COURT: There is a foundation problem,
7 though. He didn’t create the video. He just
8 watched it.
9 MR. SNEDDON: That’s correct. But it’s
10 illustrative of what his testimony is with regard to
11 the sound. So I think it’s admissible on that
12 basis. And I’ll represent to the Court, without any
13 question we’ll be able to lay the foundation as to
14 who took that and that it is accurate.
15 MR. MESEREAU: We’d object on authenticity
16 and foundation, Your Honor. It’s not an accurate
17 depiction of what it purports to be.
18 THE COURT: The -- all right. Let me look a
19 minute, here.
20 All right. I’m going to sustain the
21 foundation objection. Right now the foundation that
22 you laid was: “Do you recognize 345.
23 “Yes.
24 “Were you asked to look at it last night.
25 “Yes.
26 “And with regard to looking at that, were
27 you asked to see if you recognized the material
28 on the video. 1596
 

 
1 “Yes.
2 “And did you.
3 “Yes.”
4 So I find that is an insufficient
5 foundation.
6 MR. SNEDDON: All right. Then what I
7 propose to do at this point, Your Honor, would be to
8 have this witness step down and I’ll put Sergeant
9 Robel on to lay the foundation.
10 THE COURT: All right.
11 MR. SNEDDON: I can do that between now and
12 the break, and then the witness can come back
13 immediately afterwards.
14 MR. MESEREAU: All right.
15 MR. SNEDDON: All right. Gavin, would you
16 step out, please.
17 Call Sergeant Robel.
18
19 STEVE DANIEL ROBEL
20 Having been sworn, testified as follows:
21
22 THE WITNESS: Yes, I do.
23 THE CLERK: Please be seated. State and
24 spell your name for the record.
25 THE WITNESS: Steve Daniel Robel.
26 R-o-b-e-l.
27 THE CLERK: Thank you.
28 // 1597
 

 
1 DIRECT EXAMINATION
2 BY MR. SNEDDON:
3 Q. You’re a Sergeant with the Santa Barbara
4 Sheriff’s Department.
5 A. Yes, I am.
6 Q. How long have you been with the sheriff’s
7 department.
8 A. Approximately 22 years.
9 Q. Now, on November the 18th of 2003, were you
10 present during the execution of a search warrant at
11 Neverland Valley Ranch.
12 A. Yes, I was.
13 Q. And are you one of the lead investigators
14 into the case against the defendant in this case,
15 Michael Jackson.
16 A. Yes, I am.
17 Q. Were you present at the time that entry was
18 made into his residence.
19 A. Yes, I was.
20 Q. And were you in the company of the
21 individual who was filming the entry into the house.
22 A. Yes, I was.
23 Q. And did you accompany that person all
24 through the house.
25 A. Yes, I did.
26 Q. And have you had occasion to review -- and
27 did he videotape the entire house before anybody
28 made any other entry into it. 1598
 

 
1 A. Yes, he did.
2 Q. Did you accompany him in that part of the
3 house where the hallway leads into Mr. Jackson’s
4 bedroom suite.
5 A. Yes, I did.
6 Q. Were you present when he videotaped that.
7 A. Yes, I was.
8 Q. And have you reviewed that videotape in
9 connection with this investigation.
10 A. Yes.
11 Q. And with regard to the particular exhibit
12 that’s in front of you marked as -- 345. 344.
13 A. It’s 345.
14 Q. 345. Did you review that.
15 A. Yes.
16 Q. Is that a portion of the videotape that was
17 taken by the person who accompanied you at the time
18 that you folks executed the search warrant --
19 A. Yes, it is.
20 Q. -- on the 18th.
21 A. Yes, it is.
22 Q. And is it an accurate depiction of the sound
23 that you heard when you entered Mr. Jackson’s
24 bedroom suite.
25 A. Yes.
26 THE COURT: Cross-examine.
27 MR. SANGER: That’s my witness, if that’s
28 all right. 1599
 

 
1 MR. SNEDDON: No further questions, I guess
2 I should have said, Your Honor.
3
4 CROSS-EXAMINATION
5 BY MR. SANGER:
6 Q. Sergeant Robel, at the time -- let’s start
7 with this. 345 is a snippet, as it were, from a
8 many-hour-long video; is that correct.
9 A. Yes, it is.
10 Q. And that little snippet was selected today,
11 or for today’s proceedings, by you; is that right.
12 Or was it selected by somebody else.
13 A. This was off of a CD.
14 Q. Who selected it.
15 A. I did and Detective Bonner.
16 Q. You did.
17 A. And Detective Bonner.
18 Q. And Detective Bonner.
19 A. Yes.
20 Q. So you went through to find a part of that
21 CD where you might hear a bell.
22 A. Yes.
23 Q. Okay. At the time that you were going
24 through the residence when this tape was actually
25 being made, you were not listening for that bell,
26 were you.
27 A. No, we weren’t.
28 Q. Okay. You were walking through, and you 1600
 

 
1 were -- this was your first opportunity to go inside
2 Mr. Jackson’s bedroom suite; is that right.
3 A. As -- under a circumstance of a protective
4 sweep, yes.
5 Q. In other words, you started your search by
6 going through the house and making sure that there
7 was nobody in the rooms, and making sure you knew
8 where everything was; is that right.
9 A. Exactly. And making sure that if there were
10 people in the rooms, we would bring them downstairs
11 and centrally locate them, yes. Safety purposes.
12 Q. And the filming was going on at that time.
13 A. Yes.
14 Q. And you had never been in Mr. Jackson’s
15 bedroom suite before that time; is that correct.
16 A. No, I hadn’t.
17 Q. So you were looking around. You were
18 vigilant to see if there was anybody in there. You
19 were doing your job at that point, correct.
20 A. Yes.
21 Q. All right. So you weren’t really listening
22 for that bell.
23 A. I wasn’t. Not actively, no.
24 Q. And the reason you found this part of the
25 tape is, you went back to listen to the tape, and
26 you and Detective Bonner found a place where you
27 heard something about the bell; is that correct.
28 A. That’s incorrect. 1601
 

 
1 Q. Okay. Well, let’s move on.
2 THE COURT: Let’s take a break.
3 MR. SANGER: Let’s take a break and move on.
4 (Recess taken.)
5 THE COURT: Go ahead, Counsel.
6 MR. SANGER: May I proceed. Thank you, Your
7 Honor.
8 Q. Sergeant Robel, this particular tape we’re
9 talking about, 345, was not made for the express
10 purpose of representing how this bell sounded inside
11 of Mr. Jackson’s room when the bell went off, was
12 it.
13 A. No, you are correct.
14 Q. Okay. And the equipment that was used, the
15 sound-recording -- it’s a video; it’s part of a
16 videotape, right.
17 A. I believe so, yes.
18 Q. And the sound-recording device that was
19 used, are you familiar with that particular device.
20 A. I’m really not.
21 Q. Okay. Do you know if it measures the
22 decibel level of the sounds that it’s recording.
23 A. No, I don’t believe so.
24 Q. And this particular tape doesn’t preserve in
25 any way the decibel levels of the sounds that it’s
26 recording, does it.
27 A. I don’t believe so.
28 Q. All right. Now, you’ve listened to this 1602
 

 
1 carefully, I take it, this 345; is that right.
2 A. Yes.
3 Q. And it is -- it is, in part, a scene where
4 you are talking with a gentleman about the key pad,
5 and getting the correct combination to go into the
6 suite of rooms that we’ve described as Michael
7 Jackson’s bedroom suite, the first floor, second
8 floor, that area, correct.
9 A. Correct.
10 Q. So you’re talking to him, he’s giving some
11 instructions. And in the background, if you listen,
12 you can hear the bell ringing, is that correct,
13 while you’re still in the hallway.
14 A. Up by the key pad, I believe you’re correct,
15 yes.
16 Q. In other words, I’m talking about, you
17 reviewed this --
18 A. Right.
19 Q. -- trying to remember what this shows.
20 Okay.
21 A. Right.
22 Q. This particular 345.
23 You start to hear a fairly faint bell as
24 you’re standing in the hallway before you go through
25 the door, correct. You start to hear on this
26 tape --
27 A. I just need clarification. When you talk
28 about the door, are you talking about the first set 1603
 

 
1 of doors that we’re going through going down the
2 hallway, or talking about the double doors to
3 Michael’s bedroom.
4 Q. The double doors to Michael’s bedroom, what
5 we’re calling Michael’s bedroom. This is where you
6 have the first floor and you go back and there’s a
7 second floor, right.
8 A. Okay. The second floor I’m familiar with
9 inside his bedroom, yes.
10 Q. So we’re talking about going through the
11 double doors that lead you down three or four steps
12 into a living room area, correct.
13 A. Correct.
14 Q. And then behind that is the door and the
15 stairway to a second floor; is that correct.
16 A. Correct.
17 Q. All right. So we’re at those double doors.
18 You’re in this video that you have reviewed, Exhibit
19 345, you and some other officers are up there at or
20 near this front double door area that goes into this
21 living room; is that right.
22 A. Correct.
23 Q. And the cameraman -- I was going to move
24 back, but then you wouldn’t be able to hear me, or
25 somebody wouldn’t -- the cameraman is standing back
26 a few paces behind all of you; is that correct.
27 A. I believe so. I don’t know exactly where he
28 was. But he was behind me, yes. 1604
 

 
1 Q. And the microphone, to pick up the sound, is
2 on his camera; is that correct.
3 A. That is correct.
4 Q. Didn’t have a boom mike or somebody else
5 wasn’t miked in this situation.
6 A. Correct.
7 Q. All right. And when you reviewed this, at
8 some point you start to hear the dinging of the bell
9 that’s fairly faint from the cameraman’s position in
10 the hallway; is that correct.
11 A. Where I heard it was when I was standing at
12 the key pad. That’s when I first heard it.
13 Q. All right. And I’m talking about this --
14 what this depicts.
15 A. Right.
16 Q. This depicts sound picked up from this
17 cameraman back in the hallway, and the bell rings
18 about 12 times; is that correct.
19 A. I didn’t count them, but it was more than
20 once, yes.
21 Q. It was more than three.
22 A. Right.
23 Q. And it was about 12, was it not, sir.
24 A. If -- I would say it was approximately that,
25 yes.
26 Q. All right. And as the cameraman -- as you
27 come in, and you walk down the few steps into the
28 living room area, you then make -- you start to walk 1605
 

 
1 towards the door that goes up the stairway to Mr.
2 Jackson’s bedroom; is that correct.
3 A. I believe so.
4 Q. And just as you get to his door, that’s
5 pretty much where this tape ends; is that right.
6 A. I think so, yes.
7 Q. Okay. And as you’re getting to his door,
8 the cameraman is just starting to walk into the room
9 and down the stairs, into this living room area down
10 the stairs, correct.
11 A. Correct.
12 Q. And the sound is becoming louder, the sound
13 of the bell is becoming louder just as the tape
14 ends; is that correct.
15 A. Really didn’t pay attention as far as
16 whether it was becoming louder or not. I mean, I
17 could hear it, and I was in front. When I was
18 viewing that, I didn’t determine whether it was
19 louder or fainter.
20 Q. In other words, I understand what -- your
21 recollection of what really happened when you were
22 there is, but what this depicts is a cameraman
23 several paces behind a group of three officers and a
24 civilian; is that correct.
25 A. Correct.
26 Q. And your group, at least the three officers,
27 move into the downstairs, and move towards the door
28 to Mr. Jackson’s stairway and his upper bedroom, 1606
 

 
1 right.
2 A. Correct.
3 Q. And the cameraman is still back -- he’s
4 behind you, moving up.
5 A. Correct.
6 Q. And the sound is actually louder as you get
7 closer to that bedroom door; isn’t that correct.
8 A. I don’t know. I don’t know until I hear
9 that again. I mean, I viewed that two or three
10 times, but I never really determined whether it was
11 louder or not.
12 MR. SANGER: I have no further questions.
13 THE COURT: Thank you.
14 MR. SANGER: The objection stands.
15 THE COURT: You may step down.
16 Bring the other witness in.
17 MR. SNEDDON: Wait. I have a question.
18 THE COURT: All right.
19
20 REDIRECT EXAMINATION
21 BY MR. SNEDDON:
22 Q. Sergeant Robel, with regard to the bell
23 system itself, is that laser-activated, to your
24 knowledge.
25 A. To my knowledge, yes.
26 Q. So that every time somebody passes it, it
27 sets it off again.
28 A. That is correct. 1607
 

 
1 Q. So when Mr. Sanger asked you if you heard it
2 go 12 times in a row, every time one of the people
3 connected with the walk-through went through, it
4 would go off again.
5 A. Correct.
6 MR. SANGER: I’m going to object and move to
7 strike. That is a leading question and --
8 THE COURT: Overruled.
9 You may step down.
10 I’m going to allow the exhibit to go in.
11 Bring the witness in.
12 BAILIFF CORTEZ: Yes, Your Honor.
13 THE COURT: You may be seated. You’re still
14 under oath.
15
16 GAVIN-ANTON ARVIZO
17 Having been previously sworn, resumed the
18 stand and testified further as follows:
19
20 THE COURT: Go ahead.
21 MR. SNEDDON: We’re activating the disk,
22 Your Honor. It’s --
23 THE BAILIFF: Are you playing it out of your
24 computer.
25 THE COURT: Do you need “Input 1”.
26 MR. AUCHINCLOSS: Your Honor, we’d ask for
27 “Input 4.” Thank you.
28 THE COURT: “Input 4”. 1608
 

 
1 MR. AUCHINCLOSS: Yeah.
2 (Whereupon, a portion of a DVD, People’s
3 Exhibit 345, was played for the Court and jury.)
4
5 DIRECT EXAMINATION (Continued)
6 BY MR. SNEDDON:
7 Q. Gavin, did you hear the chime go off.
8 A. Yes.
9 Q. Is that the chime that went off when you
10 were visiting Neverland Valley Ranch.
11 A. Yes.
12 Q. Now, I want to ask you a couple more
13 questions and then we’ll move on to another subject,
14 okay. But I want to ask you a little bit about some
15 of the drinking that you did at the ranch.
16 A. Okay.
17 Q. Do you know what the term “passed out”
18 means.
19 A. Yes.
20 Q. Tell the jury what that means.
21 A. When you, like, lay down and you, like, go
22 to sleep and you sleep for a long time and you sleep
23 pretty hard.
24 Q. During the time that you were at the ranch
25 and you drank alcohol with the defendant, Mr.
26 Jackson, did you ever pass out.
27 A. Maybe once or twice. But I don’t think I
28 really ever -- well, when I’d go to sleep, I would 1609
 

 
1 usually sleep pretty hard, but I don’t know about,
2 like, just sitting somewhere and just (indicating);
3 you know what I mean.
4 Q. I guess. I wouldn’t admit it even if I did.
5 Did you ever get sick.
6 A. Yeah.
7 Q. How did you feel when you got sick.
8 A. Felt like -- my stomach hurt a lot. I don’t
9 think I ever really threw up, though. But, like, I
10 felt, like, nauseated.
11 Q. All right. We’re going to move on to
12 another subject now, if we can, and I’m going to
13 show you a couple more exhibits. And I’m going to
14 show them to counsel first, so just give me a
15 moment.
16 A. Okay.
17 (Off-the-record discussion held at counsel
18 table.)
19 Q. BY MR. SNEDDON: All right. I’m going to
20 hand you an eight-by-ten piece of paper, and ask you
21 if you recognize the notes, that particular exhibit.
22 A. Yes.
23 Q. Is that your handwriting.
24 A. Yes.
25 Q. And you wrote it.
26 A. Yes.
27 Q. Now I’m going to hand you an exhibit marked
28 as 347 for identification purposes. Do you 1610
 

 
1 recognize that.
2 A. Yes.
3 Q. And whose handwriting is that.
4 A. Michael’s. It looks like Mike -- yeah, it’s
5 Michael’s.
6 Q. And that particular exhibit, 347, was that
7 something that was given to you at one time by Mr.
8 Jackson.
9 A. Yes.
10 Q. I’m sorry.
11 A. Yes.
12 MR. SNEDDON: All right. Your Honor, I’m
13 going to ask the Court’s permission to put these on
14 the Elmo, and ask the witness some questions about
15 them, and I move that they be admitted into
16 evidence.
17 MR. MESEREAU: No objection.
18 THE COURT: They’re admitted.
19 THE BAILIFF: You need to take it off “Black
20 Screen.”
21 Q. BY MR. SNEDDON: All right. Gavin, I’m
22 going to ask you to look at the first two at the
23 top, and the note makes reference to a trip to
24 Florida. Do you see that.
25 A. Yes.
26 Q. Have you ever been to Florida with Mr.
27 Jackson on more than one occasion.
28 A. No. Only went there once. 1611
 

 
1 Q. Just the one you testified to.
2 A. Yes.
3 Q. And did you write this note. Do you recall
4 when it was you actually wrote this note to Mr.
5 Jackson.
6 A. No. But I think it was like toward the
7 beginning -- like maybe a week or two after we came
8 back from Miami.
9 Q. Was the time that you flew to Miami with
10 Mr. Carter the first time you were ever on the
11 plane.
12 A. Mr. Carter.
13 Q. Tucker, I’m sorry.
14 A. Chris Tucker.
15 Q. Yes.
16 A. That was -- I mean, when I flew to Oakland
17 with him to the Raider game --
18 Q. Okay.
19 A. -- that was, like, the first time I was ever
20 in a plane.
21 Q. Okay.
22 A. And this is the first time I was ever on a
23 plane with Michael.
24 Q. Oh, okay. All right.
25 Now we’re going to show the other exhibit,
26 People’s 346 -- 347, I’m sorry.
27 Well, and the last part of the exhibit, 346,
28 do you recognize that. 1612
 

 
1 A. Well, not really. But I think I wrote that.
2 Q. Looks like your handwriting, does it not.
3 A. Yeah.
4 Q. Or does it.
5 A. Well, kind of.
6 Q. All right. Let’s put up 347.
7 Now, when the exhibit says, “I want you to
8 have a great time in Florida. I’m very happy to be
9 your Daddy,” now, do you recall when it was Mr.
10 Jackson gave you this particular note.
11 A. No. It was probably around the time that I
12 wrote him those notes. I think -- I think Frank
13 gave me those notes. Or, no, I don’t think Frank.
14 I think somebody gave me those notes because Michael
15 was busy, and he gave me those notes from Michael.
16 Q. Did you ever discuss them with Mr. Jackson.
17 A. Not really.
18 Q. But you recognize the handwriting as being
19 his.
20 A. Yes.
21 MR. SNEDDON: All right. You can take that
22 down.
23 Q. Now, in the exhibit, 347, it’s signed by Mr.
24 Jackson as “dad,” and in the exhibit he makes
25 reference to being your “daddy.”
26 A. Yes.
27 Q. Had you -- had Mr. Jackson ever called
28 you -- asked you -- strike that. 1613
 

 
1 Had Mr. Jackson ever used the word “daddy”
2 to you prior to the time he wrote this note to you.
3 A. I don’t know. I would call him “dad”
4 sometimes, because I don’t really have, like, a set
5 dad at that time; you know what I mean.
6 Q. So how long do you think it was between you
7 and Mr. Jackson that you were calling him “dad”.
8 A. When I was up there.
9 Q. Up where.
10 A. After Miami, like a couple weeks after
11 Miami, he started calling me “son,” and I would call
12 him “dad.”
13 Q. So that was a fairly usual thing between the
14 two of you.
15 A. Yeah.
16 Q. At some point in time, did you participate
17 in a taped interview other than the one with Mr.
18 Bashir.
19 A. It wasn’t really an interview. It was,
20 like, where -- I don’t know what you would refer to,
21 but there was one time when he taped me carrying me
22 across a bridge. I don’t know if you’re talking
23 about that, but --
24 Q. Okay. You were filmed -- and was this when
25 you had cancer.
26 A. Yes.
27 Q. And when you were filmed in that particular
28 piece, did you ever see that piece. 1614
 

 
1 A. Yes.
2 Q. When did you see it for the first time.
3 A. We showed it to Chris. And then when he
4 showed it to Chris, that’s when I saw it.
5 Q. Okay. Now, do you know an individual by the
6 name of Hamid.
7 A. Yes.
8 Q. All right. Where did you meet Hamid for the
9 first time.
10 A. At -- I’m not sure. I think he was the guy
11 that filmed Michael carrying me across the bridge,
12 but I’m not sure.
13 Q. Okay. The time after you came back from
14 Miami -- all right.
15 A. Okay.
16 Q. -- and you were at the ranch, did you ever
17 meet Hamid there.
18 A. Yes.
19 Q. All right. Tell us about -- where were you
20 when you met him.
21 A. I don’t know. But I was somewhere on the
22 ranch, because I remember he drove us to his house.
23 Q. He drove you to his house.
24 A. From Neverland.
25 Q. And who is you.
26 A. It was me, my mom, my brother and my sister.
27 Q. And you went to his house. Do you remember
28 where he lived. 1615
 

 
1 A. No.
2 Q. Do you remember how long it took to get
3 there.
4 A. Two hours, probably.
5 Q. And when you got there, what did you do.
6 A. They had this camera set up and like this
7 big sheet thing that was coming down. Well,
8 actually, the first thing, I went there, he had some
9 video games, and I started playing his video games.
10 And then, I don’t know, they waited for some people
11 to come, or whatever, and then they came.
12 Q. Do you remember who the people were you were
13 waiting for.
14 A. Dieter.
15 Q. Anybody else you remember.
16 A. I think it was Vinnie. We were waiting for
17 Vinnie, too.
18 Q. Is that the first time you ever met Vinnie,
19 or had you met him before that.
20 A. I think that was the first time I ever met
21 Vinnie.
22 Q. Do you remember anybody else arriving. Let
23 me ask it this way: Did Vinnie come alone or was he
24 with somebody.
25 A. I think he might have been with Frank. I’m
26 not too sure.
27 Q. Now, during the time that you were there,
28 did an interview take place or a filming of some 1616
 

 
1 kind take place.
2 A. Yes.
3 Q. And who was doing the filming.
4 A. I believe it was Hamid.
5 Q. And do you recall about what time it was
6 when the filming started.
7 A. It was really late at night. It probably
8 started like around 11:00 -- 10:00, 11:00 or
9 midnight, one of those, around there, because I
10 remember being really, really tired while I was
11 doing it.
12 Q. Now, prior to the time that you participated
13 in that interview at Hamid’s house -- okay.
14 A. Uh-huh.
15 Q. -- had anybody ever told you what to say on
16 that interview.
17 A. Yes.
18 Q. And who was that.
19 A. Dieter.
20 Q. And what did Dieter say to you.
21 And it’s offered under 1223, Your Honor.
22 THE COURT: I’ll admit this testimony
23 conditionally. The objection is noted.
24 MR. MESEREAU: Objection noted, Your Honor.
25 THE WITNESS: Dieter would say -- like he
26 was telling us -- you know, remember how, like,
27 Michael told me what to say in the Martin Bashir
28 thing. 1617
 

 
1 Q. BY MR. SNEDDON: Okay.
2 A. Like, Dieter was kind of doing the same
3 thing. Like, he was telling us - me, my mom and my
4 brother, my sister - what to say on this tape thing
5 for -- they said it was like a rebuttal tape, or
6 something like that.
7 Q. And what did he tell you to say.
8 A. He said that, like, tell them -- tell him,
9 like, Michael helped us a lot and, like, cured me
10 from cancer practically, and stuff like that.
11 Q. Did you ever see anything written down about
12 what you were to say.
13 A. Yeah. They had like -- well, it was -- I
14 don’t think it was really -- well, they had, like,
15 this paper with a bunch of questions and stuff,
16 but -- you know.
17 Q. And did you -- did you get a chance to see
18 the questions before you went on the film.
19 A. Yeah.
20 Q. And did you go over the answers to those
21 questions before you went on to film.
22 A. Well, kinda. It wasn’t really like we sat
23 down for an hour and was, like, talking and stuff.
24 It was kind of a brief thing. He wanted us to say
25 this and this and that; you know what I mean.
26 Q. Okay. At the time that you participated in
27 this particular video at Hamid’s house late in the
28 evening or -- what was your attitude towards Mr. 1618
 

 
1 Jackson.
2 A. Well, I liked him a lot. I was like -- he
3 was like my best friend in the whole world.
4 Q. Still at this point.
5 A. Yes.
6 Q. Now, on that particular video -- you’ve had
7 a chance to see it since the time it was made, have
8 you not.
9 A. Yes.
10 Q. Was everything that you said on the video
11 true.
12 A. Not really.
13 Q. What parts of that video do you recall as
14 not being true.
15 A. I mean -- because, like, I said stuff like
16 that Michael helped me a lot during -- while I had
17 cancer. And, like, really he wasn’t really there
18 all that much.
19 Q. Anything else.
20 A. Um, I’m not too sure. It was a while ago.
21 Q. I’m sorry.
22 A. I’m not too sure. It was a while ago.
23 Q. That’s the one that sticks out in your mind.
24 A. Yes.
25 Q. After the, what you call the rebuttal tape
26 was filmed that night, do you recall where you went.
27 A. I think Vinnie and Frank took us to, like,
28 an inn. 1619
 

 
1 Q. Do you recall what you did the next day.
2 A. Um, no. Not really.
3 Q. Do you ever recall having a meeting with
4 some social workers.
5 A. Oh. Yeah. It was --
6 Q. When did that occur.
7 A. It was in the East -- no, no, where we used
8 to live on St. Andrews.
9 Q. Where you used to live on St. Andrews with
10 who.
11 A. Jay.
12 Q. Who else lived there with you.
13 A. My mom, my brother.
14 Q. Your sister.
15 A. I don’t think she lived there. I think she
16 was at my grandma’s.
17 Q. Now, in -- just so the ladies and gentlemen
18 of the jury can understand, in relationship to the
19 Hamid rebuttal film that you’ve talked about -
20 okay. - was the meeting with the social workers
21 before or after that.
22 A. It was -- I’m pretty sure it was after.
23 Q. Do you remember who was present during that
24 interview.
25 A. The social worker one.
26 Q. Yeah.
27 A. It was me, my brother, my mom. Aja was
28 there, Chris’s girlfriend. 1620
 

 
1 Q. Okay.
2 A. And the social worker ladies. And I think
3 Vinnie was there. But I don’t think he was
4 upstairs. I’m not too sure. And there was this guy
5 in a blue shirt.
6 Q. Describe the guy in the blue shirt for us.
7 A. I think he had like black hair and light
8 skin, kind of like me. And he was wearing, like,
9 dress pants and dress shoes and, like, a blue shirt.
10 Q. Can you describe what he was like
11 physically.
12 A. Well, probably like five-foot-eleven or
13 something like that. And about my body mass, but,
14 like, just bigger.
15 Q. Do you know who that person was. Did he
16 introduce himself to you.
17 A. No.
18 Q. Were you present when he arrived.
19 A. Yes.
20 Q. Did you hear him identify himself at any
21 time to anybody.
22 A. No.
23 Q. Did you at any time while you were there see
24 a tape-recorder that morning.
25 A. Yes.
26 Q. And where did you see a tape-recorder.
27 A. I saw it on our kitchen counter -- yeah, on
28 our kitchen counter. 1621
 

 
1 Q. And did you ever see anybody pick up the
2 tape-recorder.
3 A. I think I saw my mom pick it up, or -- yeah.
4 Q. And did you ever see your mom discuss
5 talking to this other individual you’ve described as
6 the --
7 A. I saw him and my mom go into another room
8 where my mom and my stepdad sleep, slept. And I
9 don’t know, they were talking in there, I guess.
10 Q. Did you see where the tape-recorder was at
11 the time they went into the bedroom.
12 A. No. I think it might have been in my mom’s
13 hand, but I’m not sure.
14 Q. When you actually had the interview with the
15 social workers, did everybody remain in there during
16 the interview.
17 A. No. I think Brad left or -- yeah, that’s
18 his name, Brad, because I was just thinking, like,
19 Brad, because -- wasn’t it Brad Miller.
20 Q. I’m not testifying.
21 A. Oh, okay. All right.
22 Q. All right. So somebody left.
23 A. Yeah.
24 Q. All right. And who was left during the
25 interview.
26 A. Me, my mom, my brother, and my sister, I
27 think.
28 Q. And do you recall the questions that the 1622
 

 
1 social workers asked you.
2 A. They asked me about Michael and --
3 Q. And do you remember what you told them.
4 A. Yeah.
5 Q. What did you tell them.
6 A. I told them that he was a nice guy, and
7 that -- like the stuff that we said on the rebuttal
8 tape.
9 Q. Pretty much the same stuff.
10 A. Yeah.
11 Q. Do you remember -- did they ask you whether
12 or not you slept in a bed with Mr. Jackson.
13 A. Yes.
14 Q. And what did you say.
15 A. I said that we do now, because we were over
16 at the ranch, but I told them that nothing happens
17 when we’re on the bed.
18 Q. I’m sorry.
19 A. I told them nothing, like, bad happens.
20 Q. Was that the truth.
21 A. At the time, yes.
22 Q. After the interview with the social workers,
23 do you remember where you went.
24 A. I think we went back up to Neverland with
25 Aja.
26 Q. And by “we,” who do you mean.
27 A. Me, my brother, my sister.
28 Q. And when you went back up to the ranch, when 1623
 

 
1 was the next time you left, if you recall.
2 A. Left from the ranch.
3 Q. Yeah. Do you remember going anywhere after
4 you got back up there from the social workers.
5 A. Yeah.
6 Q. Did you at any time ever go shopping with
7 Frank or Vinnie.
8 A. Yes.
9 Q. All right. Tell the jury where -- where
10 that occurred.
11 A. Well, we went to a mall, and they took us to
12 a place called Anchor Blue.
13 Q. And what did you do at Anchor Blue.
14 A. They bought us clothes because we didn’t
15 have any clothes. We didn’t have that many clothes.
16 Q. Now, why were they buying you clothes.
17 A. Because they didn’t really want us to go
18 back to our apartment, so they had us buy clothes
19 from there.
20 Q. Now, at the time that you went to Anchor
21 Blue and they bought you these clothes, where were
22 you staying at that point in time.
23 A. I believe I was staying -- yeah, that’s when
24 I was staying at the Cal -- bleh. The Calabasas Inn
25 place. The inn in Calabasas.
26 Q. Okay. And who was there with you.
27 A. My mom, my brother, and my sister, and Frank
28 and Vinnie. 1624
 

 
1 Q. Now, were Frank and Vinnie in the same room
2 as you.
3 A. No.
4 Q. Do you recall where their room was, if you
5 know.
6 A. No. I believe -- I’m pretty sure it was
7 down the hall.
8 Q. Now, at the time that you went to the
9 Calabasas Inn and you went shopping with Frank and
10 Vinnie, did you go any other places.
11 A. Yes.
12 Q. Where.
13 A. They went to get us visas and passports.
14 Q. And why were you getting visas and
15 passports.
16 A. Because they said they were going to take us
17 to Brazil.
18 Q. When did you first learn that you were going
19 to go to Brazil.
20 A. From Dieter.
21 Q. And when did you first learn from Vinnie and
22 Frank Tyson that they were going to take you out and
23 buy you clothes and things.
24 A. I don’t remember. It was probably a few
25 days after when I found out from Dieter. But I’m
26 not sure.
27 Q. Did you actually go with them when the
28 passports and the visas were obtained. 1625
 

 
1 A. Yes.
2 Q. And were both Vinnie and Frank with you.
3 A. I believe so. I think Vinnie was there.
4 I don’t think Frank was there.
5 Q. Now, what was your understanding about when
6 you were going to go to Brazil.
7 A. A few weeks after we got our visas.
8 Q. Now, did you, in the presence of the
9 defendant in this case, Mr. Jackson, ever have a
10 conversation about the trip to Brazil.
11 A. Yes.
12 Q. And who else was present during that
13 conversation.
14 A. Frank.
15 Q. Frank Tyson.
16 A. Yes.
17 Q. And where did that conversation take place.
18 A. In his room.
19 Q. “In his room” --
20 A. Michael’s room.
21 Q. And which part of the room in his house.
22 A. On his bed. Like, Frank was on his knees,
23 like on -- his hands were over the bed like that
24 (indicating).
25 Q. And where were you.
26 A. Me and Michael were laying on the bed.
27 Q. All right. Tell us about the conversation.
28 MR. MESEREAU: Objection; vague. 1626
 

 
1 THE COURT: Sustained.
2 Q. BY MR. SNEDDON: How did the subject of
3 Brazil come up.
4 A. Frank was getting angry because my mom
5 didn’t want to go. And then Frank was yelling
6 because he was, like, “Oh, we have a tutor over
7 there and we still haven’t left, and we ended up
8 paying for a tutor,” or something like that.
9 And then Michael was -- he didn’t really
10 respond much, but he was, like, nodding his head,
11 like --
12 Q. You’ve nodded your head which way.
13 A. Up and down.
14 Q. To you, what does that mean.
15 A. “Yeah.” “Yes.”
16 Q. Okay. And how many times did you see Mr.
17 Jackson nod his head up and down.
18 A. A few times.
19 Q. Did Mr. Jackson ever say anything to you
20 about going to Brazil.
21 A. Yeah.
22 Q. What did he say.
23 A. He said that we were going to go to Brazil
24 and that we were going to have a good time.
25 Q. Do you remember anything else Mr. Jackson
26 said to you about that trip.
27 A. That he was going to come a week later after
28 we got there. 1627
 

 
1 Q. Now, let’s go back to the point that you
2 were at Calabasas at the inn. Okay.
3 A. Uh-huh.
4 Q. Now, you tell us that Frank and Vinnie were
5 there; is that correct.
6 A. Yes.
7 Q. Did you see any other people there that
8 Frank and Vinnie knew.
9 You just have to answer that “yes” or “no”
10 first, and then I’ll ask you the next question.
11 A. No.
12 Q. Okay. Did you see anybody in the lobby.
13 A. The lobby of the inn.
14 Q. Yeah.
15 A. I don’t think so.
16 Q. When you were at the Calabasas Inn, did you
17 feel you were free to come and go as you pleased.
18 A. No.
19 Q. Why not.
20 A. Because they had our cards to our hotel --
21 to our room, or whatever.
22 Q. Who did.
23 A. Vinnie and Frank had the cards, the key
24 cards.
25 Q. Did you ever try to go anywhere.
26 A. Not really, because even if we tried to go
27 out in the hallway or anything, they would tell us
28 to go back in our room. 1628
 

 
1 MR. MESEREAU: Objection. Calls for
2 speculation. Move to strike.
3 THE COURT: Overruled.
4 MR. SNEDDON: Your Honor, I’m going to need
5 just a second. Can I go this way or -- excuse me,
6 Mr. Oxman.
7 Q. All right.
8 A. Do you want me to take this stuff out.
9 Q. No, that’s all right. Just leave it in for
10 right now.
11 I’ve placed in front of you the exhibit
12 book, and in that exhibit book is what we’re calling
13 Exhibit 260. Okay.
14 A. All right.
15 Q. Do you recognize the piece of paper in front
16 of you.
17 A. Kinda.
18 Q. Do you recognize the photograph of the
19 person in that piece of paper.
20 A. Yes.
21 Q. And do you remember when it was that that
22 photograph was taken, where it was taken.
23 A. I think it was when we were getting, like,
24 our visas or our passports, or whatever like that.
25 Q. Now, on that particular document, there
26 was -- there’s -- by your picture on the document is
27 a signature line, correct.
28 A. Yes. 1629
 

 
1 Q. Is that your signature.
2 A. Right next to my name. Oh. Well, it’s my
3 name.
4 Q. I know. But is that your signature.
5 A. Not really.
6 Q. Did you fill -- do you recall ever filling
7 that application out.
8 A. No.
9 Q. Do you remember anybody ever telling you you
10 were going to go to Italy or France.
11 A. No. They always told me I was going to go
12 to Brazil.
13 Q. All right. Now, I want you to turn --
14 turn -- I put a little pink pad -- do you see it at
15 the top.
16 A. Yes.
17 Q. Okay. Would you turn to that document.
18 This is in 261.
19 A. Okay.
20 Q. That’s a document from the Brazilian
21 consulate, correct.
22 A. Like a -- yes.
23 Q. I couldn’t hear you.
24 A. Yes.
25 Q. And again, it has your photograph on it.
26 A. Yes.
27 Q. And do you recall ever filling out that
28 application. Let me put it this way: Is that 1630
 

 
1 handwriting on the application yours.
2 A. No.
3 Q. Do you remember going to the Brazilian
4 consulate.
5 A. Yes.
6 Q. Do you recall who you went with.
7 A. Vinnie.
8 Q. Were there any other people present with
9 you.
10 A. My mom, my brother, and my sister, I think.
11 Q. All right. You can close that up, Gavin.
12 You told us that you recall going to the
13 shopping outlet, or a mall of some kind, to go to
14 Anchor Blue.
15 A. Yes.
16 Q. Do you recall any other places that you went
17 to buy clothes.
18 A. No, I think we just went to that place.
19 Q. Were there times that anybody would buy
20 things for you and bring them back to the room for
21 you.
22 A. Yes.
23 Q. Who did that.
24 A. I think it was -- I don’t know. Probably
25 Vinnie. They bought me some shoes.
26 Q. Was this while you were at the Calabasas
27 Inn.
28 A. No, this is up in Neverland. 1631
 

 
1 Q. Okay. Was there any times when you were at
2 the Calabasas Inn where people would buy you things
3 and bring them back, that you recall.
4 A. Maybe food once, but I’m not -- no.
5 Q. But not clothes.
6 A. No.
7 Q. Did you have a suitcase with you.
8 A. For my clothes.
9 Q. No, for going to Brazil.
10 A. No, I don’t think so.
11 Q. Do you know what you were going to pack your
12 stuff in.
13 A. Well, we came down there with a suitcase,
14 but I don’t think the suitcase was for us to go to
15 Brazil, because I think we were going to go back up
16 to Neverland, and later we were going to go to
17 Brazil somewhere.
18 Q. Where did you get the suitcase.
19 A. They bought us a suitcase.
20 Q. Who’s “they”.
21 A. Vinnie and Frank.
22 Q. All right. Now, after you come back from
23 Calabasas - okay. - the trip that you told the
24 ladies and gentlemen of the jury about, after you
25 came back, did you go back to Neverland.
26 A. After that, with Vinnie and them to get the
27 visas and passports.
28 Q. Yeah. 1632
 

 
1 A. Yeah.
2 Q. And Mr. Jackson, was he there.
3 A. To Neverland. I don’t think he was.
4 Q. Did he come, at some point, after that.
5 A. Yes.
6 Q. And where did you sleep when Mr. Jackson --
7 after Calabasas, when Mr. Jackson was on the
8 premises, where did you sleep.
9 A. When Michael Jackson was there.
10 Q. Yeah.
11 A. I would sleep in his room.
12 Q. With who.
13 A. It would be me and my brother and Michael.
14 And sometimes Aldo would sleep there, too.
15 Q. Was there ever any times when there was just
16 you and Mr. Jackson.
17 A. Yes.
18 Q. And when, in relationship to when you came
19 back to the ranch after the Calabasas trip, was
20 that.
21 A. That was, like, toward the end, like when --
22 like maybe a month in relation to the end, where we
23 finally left for good.
24 Q. Do you remember leaving for good.
25 A. Yes.
26 Q. And do you remember how it was you left for
27 good, what happened.
28 A. I’m not too sure, but -- I’m not sure. I’m 1633
 

 
1 not too sure how we left, but I remember being
2 there, and, like, Frank came down. I was trying to
3 think. They were knocking on the door and stuff,
4 and they left some stuff that we had with us up
5 there in front of our door.
6 Q. At your home.
7 A. Yeah.
8 Q. After you left.
9 A. Yeah.
10 Q. Is that your suitcase.
11 A. Yes. They bought us suitcases.
12 Q. Now, after the time you came back from
13 Calabasas, and before you left -- all right.
14 A. Uh-huh.
15 Q. -- were there any nights where there were
16 just you and Mr. Jackson sleeping together.
17 A. Yes.
18 Q. And were there nights, after you came back
19 from Calabasas and before you left, where you drank
20 any alcoholic beverages.
21 A. Can you repeat -- I mean, with Michael or --
22 Q. With anybody.
23 A. We would only really drink with Michael,
24 so --
25 Q. All right. So when you came back from
26 Calabasas and Mr. Jackson was there, did you drink
27 with him.
28 A. Yes. 1634
 

 
1 Q. Was there ever an occasion when you were on
2 the ranch -- I’m not talking about back when you
3 were sick with cancer or when you were there with
4 Chris Tucker, but from the time you came back from
5 Miami till the time you left for the very last
6 time --
7 A. Yes.
8 Q. -- okay. -- was there ever an occasion where
9 you and Mr. Jackson were on the ranch at the same
10 time that you didn’t drink.
11 A. No, I don’t think so, because it would
12 usually be at nighttime when we would drink. And
13 we’d rarely drink in the daytime.
14 Sometimes, like while we were in his office,
15 we’d usually drink some wine or whatever. But it
16 was usually toward it was getting dark, and we would
17 start running to the arcade, and played video games
18 and drink and stuff. But every time Michael was
19 there, we would drink.
20 Q. Okay, Gavin. We’re just going to do a
21 little bit of cleanup work here. Okay.
22 A. Okay.
23 Q. I’ve handed you a photograph that’s marked
24 as People’s Exhibit 188. Do you recognize that.
25 A. Yes.
26 MR. SNEDDON: Hang on just a second. We got
27 some technical difficulties.
28 We’re not going to need the lights, Your 1635
 

 
1 Honor. I’m not going to....
2 Thank you. That’s dark enough.
3 Q. Okay. 188, Gavin, do you see what that is.
4 A. Yes. I’m sorry.
5 Q. I’m not keeping you awake, am I.
6 (Laughter.)
7 THE WITNESS: All I need is a pillow.
8 Q. BY MR. SNEDDON: All right. 188, what is
9 that.
10 A. It’s the front door to Neverland. Or the
11 front entrance to Neverland.
12 Q. The front entrance for what at Neverland.
13 A. Not Neverland. The main house at Neverland,
14 sorry.
15 Q. Mr. Jackson’s house.
16 A. Yes.
17 Q. Why don’t you turn that over.
18 Now, what’s the next photograph.
19 A. It’s like you’re in the hallway --
20 Q. No, wait a minute.
21 Go ahead.
22 A. You’re like in the hallway to go to his
23 room. And this is at the door.
24 Q. The door to what.
25 A. The door that would like, if you opened it,
26 the chimes rung.
27 Q. And are you talking about the bedroom or the
28 main room. 1636
 

 
1 A. The bedroom. Well --
2 Q. Downstairs or upstairs.
3 A. Downstairs.
4 Q. Okay. Why don’t you turn that over.
5 And that’s a picture of who.
6 A. Hamid.
7 Q. And what number is that.
8 A. 29.
9 Q. All right. And the next picture is of.
10 A. Jesus Salas.
11 Q. And that is No. 30.
12 A. Yes.
13 Q. All right. Would you turn that over.
14 Do you recognize those pictures of the
15 people. And who’s that and what number is it.
16 A. It’s 19.
17 Q. And who is that.
18 A. Vinnie.
19 Q. Yes.
20 So in your testimony here, the person you
21 referred to as Vinnie, that’s the person you were
22 talking about.
23 A. Yes.
24 Q. Okay. Turn that over.
25 And the next photograph.
26 A. That’s the Country -- well, that’s the inn
27 that we stood at.
28 Q. When you went shopping that time. 1637
 

 
1 A. Yes.
2 Q. Okay. Turn that over now.
3 What’s the number on the next one. By the
4 way, let’s go back one, Gavin. I don’t think I got
5 the numbers. Is that 125.
6 A. Yes.
7 Q. All right. By “that,” I mean the Calabasas
8 Inn photograph.
9 A. Yes.
10 Q. All right. Now, let’s go to the next one.
11 And what number is that.
12 A. 99.
13 Q. All right. And what is that.
14 A. That’s the arcade.
15 Q. So, in your testimony when you were talking
16 about going into the arcade down to the wine cellar,
17 that’s the building that you were talking about.
18 A. Yes.
19 Q. All right. Why don’t you turn that one
20 over.
21 THE CLERK: Judge, 99 hasn’t been identified.
22 MR. SNEDDON: It hasn’t.
23 THE CLERK: No.
24 Q. BY MR. SNEDDON: Do you recognize that.
25 Is that an accurate depiction of that photograph,
26 99.
27 A. Well, that’s the side of the -- of the
28 arcade, but the front entrance is, like, over here. 1638
 

 
1 Well, the entrance to the arcade is over here.
2 Q. Let me have the photograph.
3 Move that -- apparently 99 is not in
4 evidence, Your Honor, the clerk tells us. And I’ve
5 shown it to counsel, and I don’t think he has any
6 problem with it.
7 MR. MESEREAU: No objection, Your Honor.
8 THE COURT: All right. Admitted.
9 MR. SNEDDON: Getting dangerous back here.
10 The cords came up, Your Honor.
11 Q. All right. I have one other photograph I
12 want to show you.
13 A. Okay.
14 Q. This is 153, and it’s in evidence.
15 A. Uh-huh.
16 MR. SNEDDON: We’re going to display that,
17 Your Honor. There’s going to be some testimony
18 about it.
19 THE COURT: Do you need it on “1” or “4”.
20 MR. AUCHINCLOSS: Could we have that on “1,”
21 Your Honor.
22 Q. BY MR. SNEDDON: All right. Do you
23 recognize what’s up on the board.
24 A. Yes.
25 Q. That’s a copy of the photograph that you
26 have in front of you, correct.
27 A. Yes.
28 Q. Now, have you ever seen that mannequin 1639
 

 
1 before.
2 A. Yes.
3 Q. Where was it the first time you saw it.
4 A. In Michael’s room.
5 Q. You’re going to have to turn around and talk
6 into that mike.
7 A. Michael’s room.
8 THE COURT: Is that 153 that’s on the screen.
9 MR. SNEDDON: It is, Your Honor. I
10 apologize for that.
11 Q. All right. Where was it on the floor.
12 A. It was next to the computer on the floor.
13 Q. Next to the computer on the floor.
14 A. Yeah.
15 Q. Now, where was the computer located in Mr.
16 Jackson’s room.
17 A. Well, there’s the bed, and then like at the
18 foot of the bed, the computer was right there on --
19 near the -- it was like the railing. It was wood
20 railing to the stairs.
21 Q. And do you recall what kind of computer it
22 was.
23 A. No. It was -- it was a desktop computer,
24 but I don’t know what kind it was. Like nobody used
25 it, because it was --
26 Q. I’m sorry.
27 A. Nobody used it because it was bad, like it
28 wasn’t connected. 1640
 

 
1 Q. The computer that Mr. Jackson gave you, the
2 one that you described as an Apple.
3 A. Yes.
4 Q. -- was that a desktop or a laptop.
5 A. It was a laptop, the one that he gave me.
6 Q. Now, directing your attention to the
7 mannequin that’s in the photograph in front of you -
8 okay. - did you ever see Mr. Jackson do anything
9 with that mannequin.
10 A. Yes.
11 Q. Tell us what he did.
12 A. Well, me and my brother were looking at the
13 mannequin, and we started laughing at it because it
14 was shaped funny, and then we showed Michael and he
15 started laughing. And then he started acting like
16 he was, like, having sex with the mannequin because
17 it was shaped funny.
18 Q. I couldn’t hear you.
19 A. Because it was shaped funny.
20 Q. All right. So what did he do with the
21 mannequin.
22 A. He acted like he was humping it.
23 Q. And where was he when he was doing that.
24 A. On the bed.
25 Q. Where were you and your brother.
26 A. I was sitting on the bed and I think my
27 brother might have been standing up.
28 Q. Now, the time that you saw Mr. Jackson on 1641
 

 
1 the bed with the mannequin, do you recall whether
2 that happened before or after you went to Calabasas.
3 A. I’m not sure. It was probably before. But
4 I’m not too sure.
5 Q. But you remember the incident.
6 A. Yes.
7 Q. All right. We can take that down, if you’d
8 like.
9 I’m going to show an exhibit marked as 470.
10 A. Uh-huh.
11 Q. Ever seen that before.
12 A. Yes.
13 Q. Where was it the first time you saw it.
14 A. It was next to, like, this -- it wasn’t
15 really a couch. Well, it felt like a couch, but --
16 it was like a one-person couch, and it had, like,
17 this place where you could put your feet up --
18 Q. Okay.
19 A. -- that was, like, the same material, but it
20 was like a little square cushion thing, and you put
21 your feet up there.
22 Q. And what -- what building was this.
23 A. This was in his room.
24 Q. Do you know what room it was.
25 A. It was in Michael’s room. But when you walk
26 in the door, like to the right would be the door to
27 go up to his bed, and then if you walk in there and
28 you walk this way and then go to the right inside 1642
 

 
1 this room, and you’d walk and there’s a couch thing.
2 Q. Was there anything else in that room.
3 A. Yeah, there was like a sink with a bunch of
4 his, like, perfumes and colognes. And there was
5 like a big mirror, like three-sided mirror. And
6 then there was a rest room. And then there’s a big
7 kind of tub, but kind of looks like a Jacuzzi,
8 though.
9 Q. Now, when you first saw the suitcase, where
10 was it in that room.
11 A. It was next to -- it was to the left of that
12 couch thing.
13 Q. And did you ever see Mr. Jackson pick up the
14 Exhibit 470.
15 A. Yeah, like I was hanging out with him in
16 there, and he was like putting on his makeup or
17 something, I don’t know. And then he -- he grabbed
18 the -- grabbed the suitcase, and then he told me --
19 he told me it was Frank’s. And he showed me, he was
20 like, “This is” --
21 Q. Okay. Well, what did he show you.
22 A. He was, like, “Look at the” -- “Look at this
23 stuff. Frank’s stinking a-s-s.” Frank’s
24 stinking -- it was S- -- Frank’s stinking ass.
25 Q. All right. What was inside the suitcase.
26 A. Adult materials.
27 Q. And how many did you look at with Mr.
28 Jackson. 1643
 

 
1 A. Well, he showed me just one -- like he
2 showed me, and there was this girl in there and then
3 he put it away.
4 Q. And how was the girl.
5 A. She had her legs spread open, and her vagina
6 was, like, showing.
7 Q. All right. Did you ever see that suitcase
8 again.
9 A. Yes.
10 Q. Where.
11 A. We had it -- like, we had it up in his --
12 near his bed, and then we were looking at all the
13 stuff.
14 Q. Who was “we”.
15 A. Me, my brother and Michael.
16 Q. And do you recall, where in the bedroom was
17 the suitcase when you first saw it that time.
18 A. The first time I saw it, it was in the rest
19 room kind of thing. And then the second time we --
20 I don’t know if we brought it up there or, like,
21 Michael brought it up there or something. I don’t
22 know. But it was up next to his bed. And we were
23 all going through the thing and we were making fun
24 of Frank.
25 Q. Did you look at the magazines.
26 A. Yes.
27 Q. How many magazines do you think you saw.
28 A. We saw, like, practically everything, but 1644
 

 
1 there was a few we didn’t look at.
2 Q. How much time do you figure you were looking
3 at all those things.
4 A. 30 minutes to an hour, probably.
5 Q. Did Mr. Jackson make any comments during the
6 time -- other than the ones you’ve talked about, any
7 other comments that he made at any of the
8 photographs or the magazines.
9 A. Not really. We just were, like, making fun
10 of Frank.
11 Q. Okay. Now, with regard to the first time
12 you saw it downstairs - okay. - in that room that
13 you described where he puts his makeup on, things
14 like that, do you remember whether that occurred
15 before or after Calabasas.
16 A. Well, while we were in there. That was
17 like --
18 Q. The first time.
19 A. Me and Michael only. When he showed me the
20 thing I said about Frank.
21 Q. Right.
22 A. Okay. That was like the same day that we
23 got back -- no. Yeah, the same night we got back
24 from Miami.
25 Q. All right. What about the second incident
26 where you were upstairs. When was that in
27 relationship to Calabasas.
28 A. A few weeks -- a week later, probably, or 1645
 

 
1 two weeks.
2 Q. So can you tell us whether that would be
3 before or after Calabasas.
4 A. Before Calabasas.
5 Q. Was there anything else in the suitcase that
6 you saw other than magazines themselves.
7 A. There was, like, cut-out pieces of
8 magazines.
9 Q. What kind of cut-out pieces from the
10 magazines.
11 A. Cut-out pieces of, like, girls taking a
12 shower or, like, just girls naked.
13 Q. All right.
14 (Off-the-record discussion held at counsel
15 table.)
16 Q. BY MR. SNEDDON: I have another photograph
17 I’m going to show you. It’s 165. Would you take a
18 look at that, please. Do you recognize that.
19 A. Yes.
20 Q. What is that.
21 A. It’s a telephone that, like, we would listen
22 to, like, security guards talking to, like, their
23 girlfriends and stuff.
24 Q. How do you know that.
25 A. Michael showed me.
26 Q. Showed you what.
27 A. How to, like -- because what you do, like
28 when you see one of these lights flashing, it means 1646
 

 
1 that someone’s on one of those lines, and then you
2 push the line and you can hear them. But once you
3 push it, you can’t say anything because they can
4 hear you. And then you push “mute” so they can’t
5 hear you, and then you can hear who they’re talking
6 to and what they’re talking about and stuff.
7 Q. Now, who showed you how to do that.
8 A. The first time Michael did.
9 Q. Now, were you present with Mr. Jackson when
10 he listened in on people’s conversations.
11 A. Yes.
12 Q. How many times.
13 A. We would do it a lot. Like, we would listen
14 to security guards talking to their girlfriends.
15 Q. You say “we.” Who do you mean by “we”.
16 A. Me and Michael.
17 Q. Were there any times when you overheard
18 conversations of your mother.
19 A. Yes.
20 Q. How many times.
21 A. Like three times. Or once or twice. I
22 don’t know.
23 Q. Were those with Mr. Jackson or were those by
24 yourself.
25 A. I think they were with Michael. And then
26 maybe one time I was by myself listening.
27 Q. Did you ever have a conversation with Mr.
28 Tyson about overhearing conversations. 1647
 

 
1 MR. MESEREAU: Objection; leading.
2 THE COURT: Overruled.
3 THE WITNESS: Yes.
4 MR. SNEDDON: Offered under 1223, Your
5 Honor.
6 Q. What did he tell you.
7 MR. MESEREAU: Objection; hearsay.
8 MR. SNEDDON: Wait just a second. Let
9 the --
10 THE COURT: I’ll admit it for limited
11 purposes.
12 Q. BY MR. SNEDDON: Go ahead.
13 A. Wait, can you repeat the question.
14 Q. Yeah. What did Mr. Tyson tell you.
15 A. About listening to my mom.
16 Q. Listening to conversations, yes.
17 A. He just told me that my mom -- just told me
18 about him listening to my mom’s phone calls talking
19 with Jay.
20 Q. Did he tell you how many occasions he’d
21 overheard or listened to your mom’s conversations.
22 MR. MESEREAU: Objection; hearsay. And
23 leading.
24 THE COURT: Overruled. And I’ll again admit
25 it for the conditional use. I said “limited use,”
26 but I meant conditional use.
27 Go ahead.
28 THE WITNESS: He told me about my mom and 1648
 

 
1 how he would listen to him, and he would kind of --
2 was talking to me about it kind of angrily, about my
3 mom talking to Jay and saying she wanted to leave,
4 and stuff like that.
5 Q. BY MR. SNEDDON: That’s what Mr. Tyson told
6 you.
7 A. Yes.
8 Q. All right. You can put that photograph
9 down. Just turn it over. Okay.
10 Now, while you were at Mr. Jackson’s ranch,
11 did you ever watch a movie called -- it had a title
12 in it that -- in Spanish, with subtitles.
13 A. Yes.
14 Q. Do you remember the name of the movie.
15 A. No, but it was about like a 1940, or
16 whatever, those years. And it was about a ghost,
17 and like a little kid that got killed, and an older
18 man killed him and put him in, like, this pool where
19 there was a lot of water.
20 And then the little kid was trying to, like,
21 warn, like, all the other orphans in the orphanage,
22 that’s where it was, and that they were all going to
23 die, or something like that. It was all in Spanish.
24 Q. Did you watch that movie on more than one
25 occasion while you were at Mr. Jackson’s ranch.
26 A. I think we saw it twice. We really liked
27 it.
28 Q. Pardon. 1649
 

 
1 A. We really liked it.
2 Q. Now, did -- while you were watching that
3 movie on any occasion, did you see Mr. Jackson enter
4 the room or was he watching the movie with you.
5 A. Well, I’m pretty sure the first time, we
6 were watching the movie with him.
7 Q. Okay.
8 A. But I don’t really remember him walking up
9 there while we were watching that. I thought the
10 second time, he was watching with us, too. I’m not
11 too sure.
12 Q. Did you ever have any conversations with
13 Mr. Jackson with regard to whether it was natural to
14 be naked or nude.
15 MR. MESEREAU: Objection; leading. Move to
16 strike.
17 THE COURT: Stricken.
18 MR. MESEREAU: Ask that the prosecutor be
19 admonished.
20 MR. SNEDDON: Well --
21 THE COURT: Ask another question, please.
22 Q. BY MR. SNEDDON: Was -- was there ever any
23 occasion where you had -- well, was there ever an
24 occasion where you saw anything with regard to
25 Mr. Jackson coming up the stairs.
26 A. Yes.
27 MR. MESEREAU: Objection; vague.
28 THE COURT: Overruled. 1650
 

 
1 Q. BY MR. SNEDDON: And where were you when you
2 saw Mr. Jackson coming up the stairs.
3 A. Me and my brother were laying on the bed.
4 Q. And what were you doing.
5 A. I think we were just laying there.
6 Q. All right. And when Mr. Jackson came up the
7 stairs, did you notice anything.
8 A. Yeah, he was naked.
9 Q. When you say “naked,” what do you mean by
10 that.
11 A. Like, not clothes on.
12 Q. Did Mr. Jackson do or say anything at that
13 point in time.
14 A. No, he just ran up and just got something
15 and went back down.
16 Q. I’m sorry.
17 A. I think he just ran up there and got
18 something and went back downstairs.
19 Q. Do you recall him saying anything at that
20 point.
21 A. No.
22 Q. And what was your reaction to what you saw.
23 A. Nothing. It was just kind of like -- me and
24 my brother were kind of like, “eeuuww”; you know
25 what I mean.
26 Q. Kind of like what.
27 A. “Eeuuww,” like we never really saw a grown
28 man, like, naked before. 1651
 

 
1 Q. I want to show you one other exhibit, if we
2 can.
3 A. Okay.
4 MR. SNEDDON: Your Honor, I have a brown
5 paper bag that’s been marked as 348 for
6 identification purposes. And I’ve shown it to
7 Counsel. And with Counsel’s permission and the
8 Court’s permission, I’d like to open the package.
9 MR. MESEREAU: May I just see what’s in
10 there, Your Honor.
11 THE COURT: Yes.
12 MR. MESEREAU: Thank you.
13 MR. SNEDDON: Do you want to open it, Tom.
14 MR. MESEREAU: I can stand there while you
15 open it.
16 MR. SNEDDON: No, we can do it down here.
17 THE BAILIFF: (To a person in the audience)
18 Sit down.
19 THE COURT: 348.
20 MR. SNEDDON: 348. Is it all right if I
21 take it out of the bag to show it to the witness.
22 MR. MESEREAU: Yes.
23 MR. SNEDDON: Your Honor, for the record,
24 there was a brown paper bag which has the number
25 “348” on it, and I’ve broken the seal on the bag,
26 the evidence seal, with counsel, and we’ve removed
27 from the bag a brown -- “a brown.” A blue bag.
28 And I’m going to show the blue blag (sic) to 1652
 

 
1 the witness at this point.
2 THE WITNESS: Blue blag.
3 MR. SNEDDON: Blue. Don’t make fun of me.
4 This is a tough job.
5 Q. All right. Okay. Gavin, first of all, with
6 regard to the blue bag, do you recognize the blue
7 bag.
8 A. Yes.
9 Q. And where did you see that blue bag the
10 first time.
11 A. That was the case that my brother’s sleeping
12 bag came from. It was in -- or -- yeah.
13 Q. It was your brother’s, Star.
14 A. That was a case where my brother’s sleeping
15 bag was in.
16 Q. Now, from the blue bag, we took out a number
17 of items, correct.
18 A. Yes.
19 Q. And do you recognize those.
20 A. Yes.
21 Q. And what are those.
22 A. They’re like my seventh grade or eighth
23 grade -- I’m not sure. They’re like my junior high
24 school books that I used for school.
25 Q. And did you have those books with you at
26 Neverland.
27 A. Yes.
28 Q. And do you recall where they were at 1653
 

 
1 Neverland.
2 A. They were -- I think they were -- we left
3 them in a rest room on the way to Michael’s room.
4 Q. Now, so -- now, the exhibits that we have
5 just -- that you just talked about, you recognize
6 all of them; is that correct.
7 A. Yes.
8 MR. SNEDDON: All right. Your Honor, I’d
9 like to have them admitted into evidence, 348.
10 MR. MESEREAU: No objection.
11 THE COURT: They’re admitted. Number 348 is
12 admitted.
13 MR. SNEDDON: Okay. And then I’d like to
14 show on the board with the lights, Your Honor, some
15 of the exhibits.
16 THE COURT: All right. Which input do you
17 need.
18 MR. AUCHINCLOSS: “Input 1,” Your Honor.
19 THE COURT: Are you ready.
20 Q. BY MR. SNEDDON: Okay. Gavin, with regard
21 to one of the items that was taken out of 348, do
22 you recognize that, the one that’s on the board
23 right now.
24 A. Yes.
25 Q. Would you tell the ladies and gentlemen of
26 the jury what that is.
27 A. That’s my workbook that I had for English
28 and junior high school. 1654
 

 
1 Q. Okay. Now, let’s go to the next one, so we
2 get them all identified.
3 Do you recognize that.
4 A. Yes.
5 Q. And what class was that from.
6 A. Before I left -- it was an English class
7 also. It was like Black Education Month.
8 Q. I don’t think we can hear you. You’re going
9 to have to turn around and --
10 A. Before we had left to go to Neverland, I
11 think it was like Black History Month, and then our
12 teacher wanted us to write about a black person, to
13 write an essay or something.
14 Q. Did you ever do that.
15 A. I never had time to. I never really did,
16 because we came up here, came up to Neverland.
17 Q. So you didn’t do the assignment while you
18 were at Neverland.
19 A. No.
20 Q. All right. Is there any other books or
21 materials there.
22 A. Yes.
23 Q. All right. Let’s look at the next one.
24 That’s just the inside of the first one.
25 A. Yeah, that’s the inside. And that’s my
26 teacher, Miss Super.
27 Q. Who was that.
28 A. Miss Super. 1655
 

 
1 Q. And what are those on the board there.
2 A. Those -- those are, like, the assignments
3 that they gave me to do.
4 Q. Go ahead.
5 A. Because my mom asked -- or I don’t know
6 who. I think my mom asked Frank and Vinnie to do
7 it, to get my homework that I needed to do.
8 Q. All right. And those materials were
9 contained in a little -- like a manila envelope.
10 A. Yes.
11 Q. Inside of Exhibit 348.
12 A. Yes.
13 Q. Okay. Thank you.
14 Now, there’s one last book up on the board,
15 if you could. Do you recognize that.
16 A. Yes.
17 Q. Do you see a book in the materials in 348.
18 A. Yes.
19 Q. All right. What is that.
20 A. It’s because in our program, the United
21 States Naval Sea Cadets, I was going to become an
22 E-3, and --
23 Q. A what.
24 A. E-3.
25 Q. Okay.
26 A. So I was going to move up rank, because I
27 was E-2, and you either have to study and pass a
28 test either from a seaman book, an airman book, or a 1656
 

 
1 fireman book. And I chose airman, because I like
2 planes and jets and stuff. So I wanted to study an
3 airman and pass the test, and so I took it up there
4 and I figured I would study.
5 Q. Did you do it.
6 A. No. I studied and then passed the test
7 later.
8 Q. How long have you been in that program.
9 A. I’ve been in it for -- since -- well, I
10 joined the Navy League when I was 12, and then I
11 went to boot camp. So I’ve been in it for maybe
12 three years.
13 Q. Where did you go to boot camp.
14 A. I went to sea cadet boot camp in Port
15 Huenema in Ventura, I think.
16 Q. How long was that.
17 A. Two weeks long.
18 Q. Have you been to any other boot camps
19 associated with the military training.
20 A. Yes.
21 Q. Where.
22 A. I went to one in Norfolk, Virginia.
23 Q. And when was that.
24 A. It was during the winter.
25 Q. And how long was that.
26 A. It was also two weeks long, or more like ten
27 days long. It was petty officer leadership academy.
28 I wanted to become a petty officer, and I wanted to 1657
 

 
1 do that so I could gain leadership ability before I
2 went to pass the test for petty officer. So I went
3 to that program, that class, for -- that training
4 for two weeks, and I gained a lot of leadership
5 skills.
6 Q. Now, I just have one last question. With
7 regard to this program that you were in, how often
8 do you have to go to participate in it.
9 A. It’s two times a month.
10 Q. On what days.
11 A. Every third and fourth Saturday of the
12 month.
13 MR. SNEDDON: All right. I think we can
14 take that down.
15 Counsel.
16 Your Honor, I have a clear plastic bag which
17 contains an orangish bottle inside. I’ve shown it
18 to counsel. It’s 349 for identification purposes.
19 And I’d like to show it to the witness at this time.
20 THE COURT: All right.
21 Q. BY MR. SNEDDON: Do you recognize that.
22 A. Yes.
23 Q. What’s that.
24 A. The doctor would sometimes order a
25 24-hour-period urine test. And so I would have
26 to -- because of my kidney and, like, stuff like
27 that. And so what you do is, you wake up in the
28 morning, and then you start your first pee in the 1658
 

 
1 bottle, and then you -- all the pees on, until that
2 time again.
3 So, like, say you wake up at eight o’clock.
4 You say, “Okay, this is my morning pee.” I’m going
5 to go pee in this bottle. And then every pee you
6 have to do till eight o’clock the next morning you
7 do in the bottle.
8 Q. Was there ever a time when you were at
9 Neverland Ranch where you had to pee in the bottle.
10 A. Yes.
11 Q. And take it to a doctor.
12 A. Yes.
13 Q. And is that the type of bottle that you
14 used, that you had to use.
15 A. Yes.
16 Q. At any time while you were on the ranch,
17 Neverland Valley Ranch, did you ever have a
18 discussion with Mr. Jackson about you having to pee
19 in that bottle.
20 A. Yes.
21 Q. And when was that discussion; do you recall.
22 A. It was down in the cellar, and I was afraid
23 that --
24 Q. I mean, let me just ask a few more questions
25 before I ask you what was said. Okay. You told us
26 it was in the cellar.
27 A. Yes.
28 Q. Who else was there. 1659
 

 
1 A. It was only me and my -- me and Michael.
2 Q. Okay. And you’re in the cellar. And can
3 you tell us whether it’s daytime or nighttime.
4 A. I think it was nighttime. Or early night.
5 So it was probably like 7:00 or 8:00.
6 Q. And how did the subject of the urine
7 specimen come up, or urine bottle come up, peeing in
8 the bottle.
9 A. I was afraid that the alcohol would show up
10 in my urine, so I asked Michael, I told him,
11 “Michael, I think the alcohol might show in my
12 urine.”
13 MR. MESEREAU: Objection; calls for a
14 narrative; nonresponsive. Move to strike.
15 THE COURT: Overruled.
16 Q. BY MR. SNEDDON: All right. So you’re
17 talking to Mr. Jackson.
18 A. Yes.
19 Q. Okay. And now -- and you already told us
20 that you told him about the test. Tell us the rest
21 of the conversation, what you told Mr. Jackson.
22 A. I told him that I was afraid that the
23 alcohol was going to show up in my urine when they
24 got the test. So I asked him, “What should I do.”
25 And then he said, “Doo-Doo, just don’t take
26 the test.”
27 Q. He said what.
28 A. “Doo-Doo, just don’t take the test.” 1660
 

 
1 Q. What do you mean, “Doo-Doo”.
2 A. Well, he called a lot of kids “Doo-Doo” or
3 “Doo-Doo Head.”
4 Q. Did you say anything back to Mr. Jackson
5 when he told you, “Just don’t take the test”.
6 A. Well, I kind of told him I had to take the
7 test. And he just said, “Don’t take the test.” And
8 then after that, I just kind of nodded my head and
9 didn’t say anything.
10 Q. Did you do any drinking after that.
11 A. Like, we were already in the wine cellar and
12 I had my glass poured.
13 Q. Well, did you drink it.
14 A. Yeah.
15 Q. Did Mr. Jackson drink.
16 A. Yes.
17 Q. Now, at some point later, did you tell
18 anybody that you had been drinking alcohol, other
19 than Mr. Jackson.
20 A. Yes.
21 Q. Let me rephrase that question, because
22 that’s not a good question.
23 A. Okay.
24 Q. At some point, did you tell somebody else
25 that you’d been drinking alcohol in connection with
26 the fact that you had to collect your pee in that
27 bottle.
28 A. Yes. 1661
 

 
1 Q. Who was that.
2 A. It was my mom.
3 Q. And do you remember where you were when you
4 told your mom.
5 A. I was in Michael’s room, and that phone with
6 all the lines, I called my mom up.
7 Q. Do you know where Mr. Jackson was at the
8 time you made the call.
9 A. He was upstairs on the bed.
10 Q. And when you made the call to your mother,
11 do you remember about what time it was.
12 A. Like four o’clock in the morning.
13 Q. And when was it you were supposed to go to
14 the doctor.
15 A. Well, I was going to start the test that
16 morning. And so the day after that, I guess.
17 Q. How long -- did you tell your mother.
18 A. Well --
19 Q. Let me go back. What did you say to your
20 mother.
21 A. Well, I called her, and I told her, “Well,
22 mom, you know how Jesus drank juice” -- I mean,
23 “Jesus drank wine.” And then she told me -- I don’t
24 know. I don’t remember what exactly she said. She
25 was like, “Yeah.”
26 And then, like, I just tried to tell her,
27 and then I’m not really too sure what happened in
28 that conversation. I know I called my mom and I 1662
 

 
1 told her, and then --
2 Q. Do you remember, after you called your mom,
3 anybody coming to the doors and banging on the
4 doors.
5 MR. MESEREAU: Objection, leading.
6 THE COURT: Sustained.
7 Q. BY MR. SNEDDON: Do you remember, after the
8 telephone conversation that you had with your
9 mother, that anything unusual occurred.
10 A. No. Because after the conversation I went
11 to sleep.
12 Q. Now, did you -- did you at some point go to
13 the doctor’s with that bottle there that’s in front
14 of you.
15 A. Yes.
16 MR. MESEREAU: Objection. Assumes facts not
17 in evidence; misstates the evidence; and leading.
18 THE COURT: Overruled. Do you want the
19 question read back.
20 THE WITNESS: Yes.
21 (Record read.)
22 THE COURT: Okay. It’s already in.
23 Okay. We’ll take our break.
24 (Recess taken.)
25 MR. SANGER: Your Honor, your clerk wanted
26 us to clarify one thing. I talked to Mr. Sneddon --
27 if we could do that.
28 THE COURT: Yes. 1663
 

 
1 MR. SANGER: With regard to Exhibit 5004,
2 those were the cards that we showed on the screen --
3 THE COURT: Yes.
4 MR. SANGER: -- and I said at the time I
5 showed them that I believe there were three cards.
6 It turns out, when we had the actual paper, there
7 are four cards. However, these pages in this 5004
8 are all of the pages that were shown on the screen.
9 It is the same thing. It’s just there are actually
10 four separate cards, instead of three.
11 THE COURT: All right.
12 MR. SANGER: And Mr. Sneddon, I believe,
13 agrees with that.
14 MR. SNEDDON: I do.
15 MR. SANGER: And we’ll then give this back
16 to your clerk.
17 THE COURT: Thank you, Counsel.
18 MR. SNEDDON: Ready, Your Honor.
19 Q. Gavin, we were talking before the break
20 about the bottle.
21 A. Yes.
22 Q. Okay. Did you ever take that to the
23 doctor’s appointment.
24 A. Yes.
25 Q. And do you recall who went with you.
26 A. I know that Vinnie, my mom and me went, but
27 I don’t know if anybody else went.
28 Q. And do you recall at the time that you left 1664
 

 
1 to go to the doctor’s appointment, how much pee you
2 had put in the bottle, just generally.
3 A. It was filled up all the way to the top.
4 Q. And when -- when you got in the car, where
5 did you sit in the car.
6 A. I sat right behind my mom. My mom was in
7 the passenger seat, so --
8 Q. And who was doing the driving.
9 A. Vinnie.
10 Q. And at some point between the time you left
11 the ranch with Vinnie and your mother -- well, let
12 me go back. Who had the bottle.
13 A. It was, like, sitting -- it was on the floor
14 in front of my mom.
15 Q. Now, at some point on the -- and when you
16 left the ranch and before you got to Kaiser, did you
17 stop for any reason.
18 A. Yeah. I needed to pee.
19 Q. And so where did you go. Do you remember
20 where you stopped.
21 A. I think we stopped at a Denny’s.
22 Q. And you went inside.
23 A. Yes.
24 Q. Do you know whether or not your mother went
25 inside.
26 A. Yeah, I’m pretty sure my mom went inside
27 with me.
28 Q. Now, at any time during that trip, did you 1665
 

 
1 hear some conversation about the contents of that
2 bottle in front of you with the pee.
3 A. Yes.
4 MR. MESEREAU: Objection; leading.
5 THE COURT: Overruled.
6 THE WITNESS: Yes.
7 Q. BY MR. SNEDDON: And with regard to that
8 conversation, who spoke first; do you recall.
9 A. I think it was my mom.
10 Q. Do you recall what she said.
11 A. She said the bottle was empty.
12 Q. And was this before you actually got to the
13 hospital itself and went inside.
14 A. When --
15 Q. If you can answer “yes” or “no” first.
16 A. Yes.
17 Q. Okay. Now, where was it when that
18 conversation occurred.
19 A. Well, it was -- we were pulling up to the
20 curb right next to the hospital entrance, and I
21 think my mom was about to pick it up to go inside
22 the hospital, and I think that’s when she figured
23 out that the bottle was empty.
24 Q. Did you actually handle the bottle at any
25 time after that. When she said it was empty, did
26 you pick it up yourself.
27 A. No.
28 Q. Did you go into the hospital with your 1666
 

 
1 mother.
2 A. Yes.
3 Q. Did Vinnie go with you.
4 A. No, I don’t think so. I think he went to go
5 park the car or something.
6 Q. I want -- let me grab that out of the way
7 for just a second.
8 THE COURT: That’s not been admitted yet.
9 Were you offering it, or not.
10 MR. SNEDDON: I am, Your Honor. I thought
11 we did.
12 MR. MESEREAU: I’m going to object, Your
13 Honor. Because the witness did not say that was the
14 actual bottle he used.
15 THE COURT: They can’t hear you back there.
16 MR. MESEREAU: The witness did not state
17 under oath that’s the actual bottle he used. I
18 believe Mr. Sneddon presented it like a bottle that
19 supposedly looked like it.
20 MR. SNEDDON: Well, may I be heard on that,
21 Your Honor, before you rule.
22 THE COURT: Yes.
23 MR. SNEDDON: Your Honor, you’re allowed to
24 use exhibits, even if they’re not exact ones, that
25 are illustrative of the ones that were used. And I
26 believe the witness has established that this was
27 like the one that he used. You don’t need to bring
28 in the exact one that was used. What if it was 1667
 

 
1 destroyed. You don’t need to do that.
2 THE COURT: Okay. I’ll take that under
3 advisement.
4 MR. MESEREAU: Thank you.
5 Q. BY MR. SNEDDON: All right. Gavin, I want
6 to go back for just a second. Do you remember me
7 asking you questions about Mr. Jackson coming up the
8 stairs.
9 A. Yes.
10 Q. And the time that you said he was naked.
11 A. Yes.
12 Q. And I asked you whether or not he said
13 anything to you at that particular point in time.
14 A. Uh-huh.
15 Q. And you said you didn’t recall anything.
16 A. I do not.
17 Q. Do you recall testifying at the grand jury.
18 A. Yes.
19 Q. You testified there a couple of times, did
20 you not.
21 A. Yes.
22 Q. One time that I asked you questions and one
23 time that Mr. Zonen did.
24 A. Yes.
25 Q. Would it refresh your recollection if I
26 showed you what you said to the grand jury about
27 that incident.
28 A. Probably. 1668
 

 
1 MR. MESEREAU: Objection. Objection.
2 THE BAILIFF: You have to go -- -
3 MR. MESEREAU: Improper question. He can’t
4 coach the witness like that, Your Honor.
5 THE COURT: I agree.
6 MR. SNEDDON: I can’t refresh his
7 recollection, Your Honor.
8 THE COURT: Not till he says he doesn’t
9 recollect.
10 THE WITNESS: I do not recollect.
11 (Laughter.)
12 THE COURT: Oh, that’s it.
13 MR. SNEDDON: He already said that. Now may
14 I approach the witness.
15 THE COURT: No.
16 MR. SNEDDON: Sorry.
17 Q. Do you have a recollection of what you told
18 the grand jury.
19 A. About that situation.
20 Q. Yeah.
21 A. I don’t recollect anything that he said when
22 he came up there.
23 Q. Do you recall what you told the grand jury
24 about that.
25 A. No.
26 Q. Would it refresh your recollection if you
27 were able to see what you told the grand jury.
28 A. Yes. 1669
 

 
1 MR. MESEREAU: I’m going to object, Your
2 Honor. This is highly improper. He’s trying to
3 coach the witness with a transcript.
4 THE COURT: The --
5 MR. MESEREAU: You can’t just lead him along
6 and say --
7 THE COURT: It’s not clear to me what you’re
8 asking about that he doesn’t recollect, so --
9 MR. SNEDDON: I’ll go back and do it again,
10 then, Your Honor.
11 Q. Gavin, with regard to that portion of your
12 testimony, when you indicated to this jury just a
13 little while ago that you had no recollection of
14 what Mr. Jackson said when he walked in front of you
15 naked, do you recall that.
16 A. Yes. Well, he didn’t really walk. He just
17 came up the stairs.
18 Q. He came up the stairs.
19 A. Yes.
20 Q. And you saw that he was naked.
21 A. Yes.
22 Q. And I asked you if you recall whether he
23 said anything to you, do you recall that, in front
24 of this jury here.
25 A. Yes.
26 Q. And you said you did not.
27 A. Yes.
28 Q. Now, did you testify -- 1670
 

 
1 MR. MESEREAU: Objection; leading. They’re
2 all leading questions. Move to strike.
3 MR. SNEDDON: It’s foundational to
4 whether --
5 THE COURT: Overruled. The next question
6 is.
7 MR. SNEDDON: You interrupted me. I forgot,
8 Judge.
9 All right. I think I can --
10 THE COURT: Would you like the court reporter
11 to read it back to you.
12 MR. SNEDDON: I don’t think I got it out.
13 It was one of those senior citizen moments.
14 I do want the last question read back.
15 Thank you.
16 If you don’t mind.
17 (Record read.)
18 MR. SNEDDON: Thank you.
19 Q. Did you testify to an incident before the
20 grand jury with regard to Mr. Jackson coming in.
21 A. I believe I did testify about that.
22 Q. And did you tell them what he said; do you
23 recall.
24 A. I don’t recall him saying anything.
25 Q. Would it refresh your recollection if you
26 were able to look at that testimony.
27 A. Yes.
28 MR. MESEREAU: Same objection. 1671
 

 
1 THE COURT: You may -- you may show him the
2 testimony to see if it refreshes his recollection.
3 MR. SNEDDON: Thank you, Your Honor.
4 Counsel, page 424, lines 1 to 3.
5 Q. Gavin, I’m going to show you this and -- and
6 I just want you to read it to yourself. Don’t say
7 anything about it. Okay.
8 A. All right.
9 MR. SNEDDON: Actually, Counsel, I’m looking
10 to start on the lines before, just so he gets the
11 whole incident. I’ll start at line 24.
12 Q. All right. Having read your grand jury
13 testimony, does that refresh your recollection as to
14 what you told the ladies and gentlemen of the grand
15 jury.
16 A. Yes.
17 Q. What did you tell them about whether or not
18 the defendant made any statements.
19 A. Oh, we were sitting on the bed. When me and
20 my brother were “eeuuww,” that’s when Michael said,
21 “It’s okay,” that it’s natural. And I remember that
22 by reading the grand jury testimony.
23 Q. So that refreshed your recollection.
24 A. Yes.
25 Q. I want to go back and just ask one or two
26 questions about your homework, and then we’ll move
27 on to another subject. Okay.
28 The books that you have in front of you 1672
 

 
1 there, in the exhibit -- I think it was 349. 348.
2 What is that. We don’t have the bag.
3 A. Oh, yeah, it was in the brown bag.
4 MR. SNEDDON: Madam Clerk, could you help me
5 with that. Somehow the tag must have come up.
6 THE CLERK: I’m sorry, what was that.
7 MR. SNEDDON: It’s the one with the homework
8 in it.
9 THE COURT: That’s 348.
10 MR. SNEDDON: The sticker must be -- I have
11 it. It was stuck to some plastic.
12 Q. All right. With regard to the items, 348,
13 that are in front of you, some of those items that
14 are in front of you look like you have some writing
15 on them. Did you ever do any homework while you
16 were at Neverland.
17 A. I think I, like, started and never --
18 Q. I can’t hear you.
19 A. I probably started, like, one assignment,
20 and then never finished it, and then went and played
21 some more.
22 Q. I can’t hear you.
23 A. I think I just started like one, like,
24 homework, but I didn’t finish and just went and
25 played some more.
26 Q. Now, on the rebuttal video -- do you
27 remember that.
28 A. Yes. 1673
 

 
1 Q. Do you remember somebody making a comment
2 about Mr. Jackson helping with their homework.
3 A. Yes.
4 Q. Did he ever help you with your homework.
5 A. Yeah, I think that was the time. Like, I
6 was in his room.
7 Q. You were in his room.
8 A. Yeah.
9 Q. And he helped you.
10 A. Well, for that part. And then we started,
11 like, playing around.
12 Q. All right. I’m going to show you some
13 photographs. This is the last bit of photographs.
14 And I’m almost done. Okay.
15 A. Okay.
16 Q. I’m going to show you the photographs that
17 are marked as 76, 77, 78, and 79 - okay. --
18 A. Okay.
19 Q. -- in evidence.
20 All right. The first one on top is 77,
21 correct.
22 A. No. 76.
23 Q. 76. All right. Go ahead and put it up on
24 the board.
25 With regard to the photograph, 76, is that
26 the one that’s up on the board.
27 A. Yes.
28 Q. All right. Do you recognize that. 1674
 

 
1 A. Yes.
2 Q. What is that.
3 A. That’s Michael’s bed.
4 Q. And with regard to this particular
5 photograph, you’ve told the ladies and gentlemen of
6 the jury -- let me strike that. Start over again.
7 You told the ladies and gentlemen of the
8 jury that at times that you were with Mr. Jackson
9 and you were in that bedroom and you drank alcohol.
10 A. Yes.
11 Q. Do you see any places in that photograph
12 where you used to put the alcohol.
13 A. On the sides of the bed.
14 Q. What do you mean “on the side of the bed”.
15 There’s a little laser up there. Can you
16 show the ladies and gentlemen of the jury. No,
17 there isn’t.
18 Okay. Go ahead.
19 A. He would sometimes put the wine bottles on
20 the sides of the bed. I think I put it one time on
21 this ledge, but it didn’t really work too good
22 because of all this stuff here.
23 Q. Now, is there anything in this particular
24 photograph that you see that’s different than when
25 you were there.
26 A. Yeah, that crib. The crib wasn’t there.
27 And then this computer wasn’t there.
28 Q. Those are on the far right-hand side of the 1675
 

 
1 exhibit, 76; is that correct.
2 A. Yes.
3 Q. All right. Let’s go to the next photograph.
4 Do you recognize that photograph. What
5 number is that, by the way.
6 A. 77.
7 Q. All right. Do you recognize that.
8 A. Yes. It’s the same room.
9 Q. Pardon.
10 A. It’s the same room.
11 Q. All right. And was there anything in that
12 particular photograph that’s different from when you
13 were there.
14 A. There -- I’m pretty sure there was a desk
15 right here. And hey, there’s the vacuum. But the
16 crib was right here, and then -- I mean, the crib
17 wasn’t there, and the computer wasn’t there.
18 Q. All right. Now, would you hold the spot
19 where you thought there might be a desk right by
20 where that silver case is on the floor in the yellow
21 bag.
22 A. Yes.
23 Q. Let’s go to the next photograph.
24 Now, do you recognize that.
25 A. Yes.
26 Q. And that photograph is what number.
27 A. 78.
28 Q. All right. And I want to show you the next 1676
 

 
1 one, and then I’m going to ask you some questions
2 about both of them. What’s the next photograph you
3 have.
4 A. 78.
5 Q. And the next one.
6 A. Oh. 79.
7 Q. All right. Now, do you recognize 79.
8 A. Yes.
9 Q. Okay. Now, you have 78 and you have 79 in
10 front of you.
11 A. Yes.
12 Q. Okay. Which -- where was the table that you
13 were talking about with the computer that didn’t
14 work.
15 A. Right here.
16 Q. All right. I’m going to take this little --
17 okay. You can take this pen and sort of draw where
18 it is that you saw the table, where you believe the
19 table was, on the photograph.
20 And would you put your initials on that,
21 please. Just somewhere on the photograph.
22 MR. SNEDDON: Your Honor, we’re going to
23 transition to the Elmo for just a second. We’re
24 done with this, Your Honor.
25 THE COURT: So we want to go to the -- is it
26 the same input.
27 THE BAILIFF: The input is “4.”
28 MR. SNEDDON: We’ve got it, Your Honor. 1677
 

 
1 Q. Up on the board is the photograph I asked
2 you to mark, correct.
3 A. Yes.
4 Q. And the “GA,” that’s your initials.
5 A. Yes.
6 Q. And the area that’s in black represents
7 what.
8 A. That’s the little -- where the desk was.
9 Q. Now, do you see where you put the “GA,” in
10 the white area there.
11 A. Yes.
12 Q. What is that.
13 A. That’s, like, kind of like a movie screen
14 thing. And then -- oops, sorry. And then
15 there’s -- then we would direct all the movies that
16 we would watch onto that screen.
17 Q. Turn around and look into the microphone, if
18 you can, for me. With regard to that screen, was
19 that screen there when you were there.
20 A. After we came back from Miami, yes.
21 Q. All right.
22 Go ahead and turn the lights on.
23 Now, Gavin --
24 A. Yes.
25 Q. -- at any time while you were at Neverland
26 Ranch, did Mr. Jackson ever touch you
27 inappropriately.
28 A. Yes. 1678
 

 
1 Q. All right. How many times.
2 A. What I saw in my memory is only twice, but,
3 I mean, there’s -- like I kind of feel it was more
4 than twice, but, I mean, the only times that I saw
5 in my mind that he did it was only twice.
6 Q. All right. Tell us about the first
7 occasion.
8 A. The first time -- well, my brother stopped
9 sleeping in our room with us.
10 Q. You’re going to have to slow down and talk
11 right into that mike now. I know you’re nervous,
12 but go ahead.
13 A. My -- my brother had stopped sleeping in our
14 room and --
15 MR. MESEREAU: Objection; nonresponsive.
16 Move to strike.
17 MR. SNEDDON: I’ll lay some foundation, Your
18 Honor.
19 THE COURT: Stricken.
20 Q. BY MR. SNEDDON: Gavin, the first time he
21 touched you, where were you. What room.
22 A. We were in his room.
23 Q. Where were you in his room.
24 A. On the bed.
25 Q. Was there anybody else present besides you
26 and Mr. Jackson.
27 A. No, I think it was only us.
28 Q. Now, you told the ladies and gentlemen of 1679
 

 
1 the jury that on many occasions, that you and your
2 brother and Mr. Jackson shared a bed in his bedroom,
3 correct.
4 A. Yes.
5 Q. On this particular occasion, had your
6 brother Star been with you and Mr. Jackson in bed
7 before that.
8 A. Before this --
9 MR. MESEREAU: Objection; leading.
10 MR. SNEDDON: That’s a terrible question
11 anyhow. I’ll withdraw it.
12 Q. Was there a period of time where your
13 brother Star stopped sleeping with you and Mr.
14 Jackson.
15 A. Yes.
16 MR. MESEREAU: Objection; leading.
17 THE COURT: Overruled. The answer was “Yes.”
18 Q. BY MR. SNEDDON: And was it before or after
19 the time that Mr. Jackson touched you for the first
20 time.
21 A. When my brother stopped.
22 Q. Yeah.
23 A. It was before, because he stopped sleeping
24 in our room -- in the room.
25 Q. All right. Tell the jury how it came about
26 that you and Mr. Jackson were in bed together and
27 what you were doing.
28 A. Well, we were -- well, we just had come back 1680
 

 
1 from drinking a lot in the arcade, and it was --
2 Q. Doing what.
3 A. Drinking in the arcade.
4 Q. Can you pull that down just a little bit.
5 There. Okay. Go ahead.
6 A. We just came back from drinking in the
7 arcade, and then we went up to his room. And then
8 we were sitting there for a while, and Michael
9 started talking to me about masturbation.
10 Q. So you were in the room for a while and the
11 defendant started talking to you about masturbation.
12 A. Yes.
13 Q. What did he say to you.
14 A. He -- he told me -- he said that if men
15 don’t masturbate, that they can get to a level where
16 they can -- might rape a girl or they might be,
17 like, kind of unstable. So he was telling me that
18 guys have to masturbate.
19 And he told me a story that --
20 MR. MESEREAU: Objection; nonresponsive.
21 Q. BY MR. SNEDDON: All right. We’ll stop
22 right there.
23 A. Okay.
24 Q. What else did he say to you.
25 A. He told me a story of he saw a boy one
26 time - he was looking over a balcony or something -
27 and he saw a boy who didn’t masturbate and he had
28 sex with a dog. 1681
 

 
1 Q. Did he tell you anything else during this
2 conversation.
3 A. That particular section. Or --
4 Q. Yeah. I mean, did he tell you anything
5 else.
6 A. He told me that boys had to masturbate, or
7 males have to masturbate.
8 Q. Okay.
9 THE BAILIFF: They cannot hear.
10 Q. BY MR. SNEDDON: They couldn’t hear what you
11 had to say, Gavin. I know it’s hard. Lean right
12 into it.
13 A. He told me that males have to masturbate.
14 Q. All right. Now, when he said that, what, if
15 anything, did he do or say after that.
16 A. He said that if I masturbated; and I told
17 him that I didn’t. And then he said if I didn’t
18 know how, that he would do it for me.
19 Q. And what did you say.
20 A. And I said I didn’t really want to.
21 Q. All right. And then what happened.
22 A. And then he said it was okay, that it was
23 natural, and that it’s natural for boys to do it.
24 Q. All right. What happened after that.
25 A. And then so he -- we were under the covers,
26 and I had his pajamas on, because he had this big
27 thing of pajamas and he gave me his pajamas.
28 Q. Okay. 1682
 

 
1 A. And so I was under his covers, and then
2 that’s when he put his hand in my pants and then he
3 started masturbating me.
4 Q. Could you see Mr. Jackson while he was doing
5 that to you.
6 A. Not really. I wasn’t really looking at him.
7 Q. Could you tell whether or not he was moving.
8 A. Well, he was -- he was himself.
9 Q. Yes.
10 A. I wasn’t really looking at him. All I
11 could -- I could kind of feel him moving, but, I
12 mean, I never really saw him moving.
13 Q. Do you know approximately how long Mr.
14 Jackson masturbated you.
15 A. Maybe five minutes, I guess.
16 Q. Did -- do you know what an “ejaculation” is.
17 A. Yes.
18 Q. And did you have an ejaculation.
19 A. Yes.
20 Q. Did Mr. Jackson say anything to you
21 afterwards.
22 A. I kind of felt weird. I was embarrassed
23 about it. And then he said it was okay; that it was
24 natural.
25 Q. Did anything else happen that evening
26 between you and Mr. Jackson.
27 A. No. We just -- after that, we just -- he
28 tried to say that it was okay and that -- kind of 1683
 

 
1 like to comfort me, because I felt weird. I felt
2 weird about it. And then after a while, we just
3 went to sleep.
4 Q. Was there any other occasion where Mr.
5 Jackson touched you.
6 A. Yeah.
7 Q. When was that.
8 A. Well, there was about a day after that, he
9 did it -- he did it one more time.
10 Q. All right. Where were you.
11 A. In his bed.
12 Q. And was it daytime or nighttime.
13 A. It was nighttime.
14 Q. And who else was -- was there anybody else
15 present besides you and Mr. Jackson.
16 A. No.
17 Q. And what were you doing up in his bedroom at
18 this point in time.
19 A. Well, we just came back from the arcade
20 again, and then we went up to his room. And then we
21 were sitting -- I think we were watching T.V. or
22 something, and then we were on top of his covers,
23 and he did it again.
24 Q. How were you dressed on this occasion.
25 A. In his pajamas again, because I would always
26 use his pajamas.
27 Q. All right. And how was Mr. Jackson dressed;
28 do you remember. 1684
 

 
1 A. He was in his pajamas, too.
2 Q. Now, with -- tell us what happened.
3 A. The same thing happened again. And he said
4 that he wanted to teach me. And then we were laying
5 there, and then he started doing it to me. And then
6 he kind of grabbed my hand in a way to try to do it
7 to him. And I kind of -- I pulled my hand away,
8 because I didn’t want to do it.
9 Q. Did Mr. Jackson say anything before he
10 reached over and grabbed your private parts.
11 A. He would always say that it was natural and,
12 “Don’t be scared,” and it was okay.
13 Q. Now, how long do you think it lasted the
14 second time.
15 A. The same time.
16 Q. Did you ejaculate the second time.
17 A. I think I did.
18 Q. Now, when was it, at point in time, that Mr.
19 Jackson reached over and grabbed your arm.
20 A. Maybe like halfway through it.
21 Q. Did you say anything to him when you pulled
22 your hand away.
23 A. I said that I didn’t want to.
24 Q. Did Mr. Jackson say anything to you.
25 A. I don’t think he did.
26 Q. Were there any other occasions where Mr.
27 Jackson tried to do something to you that you felt
28 was inappropriate, that you remember. 1685
 

 
1 A. No.
2 MR. SNEDDON: Nothing further, Your Honor.
3 THE COURT: Cross-examine.
4
5 CROSS-EXAMINATION
6 BY MR. MESEREAU:
7 Q. Gavin, my name is Thomas Mesereau and I
8 speak for Mr. Jackson. Okay.
9 A. Okay.
10 Q. I’m on his side. All right.
11 A. All right.
12 Q. Not the government. I’m on Mr. Jackson’s
13 side. Okay.
14 We’ve never spoken before, right.
15 A. No.
16 Q. We’ve never met, right.
17 A. No.
18 Q. If I ask you any question and you don’t
19 understand the question, just say so. Don’t answer
20 it. Okay.
21 A. Okay.
22 Q. If something seems unclear, just say, “It’s
23 unclear, I don’t understand it.” Okay. And I’ll
24 try and rephrase it.
25 A. Okay.
26 Q. Now, you’ve told the jury that it was not
27 till after your interview with three social workers
28 that any inappropriate touching happened, right. 1686
 

 
1 A. Hmm.
2 Q. Did you tell the jury that it was not until
3 after your interview with three social workers in
4 Los Angeles --
5 A. Yes.
6 Q. -- that Mr. Jackson inappropriately touched
7 you.
8 A. It was after.
9 Q. It was after, right.
10 A. Yes.
11 Q. Now, in that interview, you told the three
12 social workers that Mr. Jackson was a good guy,
13 right.
14 A. Yes.
15 Q. You said he had been like a father figure to
16 you, right.
17 A. Yes.
18 Q. You said he had helped you with your cancer,
19 correct.
20 A. Um, I don’t know in that interview if I did.
21 But I just said he was a good guy.
22 Q. You said a lot of good things about him,
23 true.
24 A. Pretty much, yeah.
25 Q. Okay. Now, that was the point in time where
26 you claim that Mr. Jackson wanted your family to go
27 to Brazil, right.
28 A. I don’t know if I told the social workers 1687
 

 
1 that we were going to go to Brazil. I don’t think I
2 did.
3 Q. But your statement about Mr. Jackson and
4 Frank wanting you to go to Brazil was before or
5 after the three social workers interviewed you.
6 A. The statement to who.
7 Q. You said that Mr. Jackson said something
8 about wanting you to go to Brazil, didn’t you.
9 A. Yes.
10 Q. And when was that, approximately.
11 A. When Michael wanted me to go to Brazil.
12 Q. Yes.
13 A. I’m not too sure.
14 Q. Was it before or after you interviewed the
15 three social workers -- or, excuse me, they
16 interviewed you.
17 A. I’m not too sure, but I believe --
18 Q. Well, you left Neverland --
19 MR. SNEDDON: Your Honor, he’s answering the
20 question.
21 MR. MESEREAU: Pardon me. Pardon me.
22 THE COURT: Go ahead.
23 THE WITNESS: I believe we went to Calabasas
24 after -- I think it was after the social workers.
25 Q. BY MR. MESEREAU: So you went to Calabasas
26 after the interview with the social workers, right.
27 A. Yes.
28 Q. The interview with the social workers was at 1688
 

 
1 Jay Jackson’s apartment, right.
2 A. Yes.
3 Q. And Vinnie took you to Calabasas, correct.
4 A. Yes.
5 Q. You stayed at the Calabasas Inn, right.
6 A. Vinnie and Frank took us there.
7 Q. Yes. You went right to the Calabasas Inn
8 from the interview, right.
9 A. No.
10 Q. Where did you go after the interview.
11 A. Aja took us up to Neverland.
12 Q. And you had a discussion -- the plans for
13 Brazil were already being discussed, weren’t they.
14 A. Not with me.
15 Q. Well, you’d heard about it.
16 A. I don’t know if I had.
17 Q. Well, let me just ask you this: You
18 complained after the Bashir documentary that people
19 in the school yard were making fun of you, correct.
20 A. Yes.
21 Q. You went to Florida right after that.
22 A. Yes.
23 Q. You came back, right.
24 A. Yes.
25 Q. There were media around your house, right.
26 A. I can’t -- I don’t know, because I didn’t
27 even -- from Miami I went to Neverland.
28 Q. Well, the DCFS interview, the interview with 1689
 

 
1 the social workers, had to do with an investigation
2 of Mr. Jackson, true.
3 A. Yes, and as a result of the Martin Bashir
4 documentary.
5 Q. Yes. And you went to Calabasas after that,
6 right.
7 A. No, I went up with Aja to Neverland.
8 Q. How long were you at Neverland then.
9 MR. SNEDDON: Your Honor, excuse me, the
10 witness didn’t get a chance to finish his answer.
11 MR. MESEREAU: I’m sorry. I’m sorry.
12 THE WITNESS: After -- after the DCSF, we
13 went up to Neverland with Aja.
14 Q. BY MR. MESEREAU: Yes.
15 A. Yes.
16 Q. And to the best of your knowledge, there
17 were plans in effect to take you to Brazil, right.
18 A. I don’t know. I’m not sure if I knew about
19 them at that time.
20 Q. So what you’re telling the jury is that
21 after you were interviewed by three social workers
22 investigating Michael Jackson and after all the
23 commotion that followed the Bashir documentary,
24 somehow Mr. Jackson starts to improperly touch you,
25 correct.
26 A. No, it was more toward the end. Toward when
27 we were already about to leave, after we’d been
28 drinking alcohol and all that stuff. It wasn’t 1690
 

 
1 directly after the DCSF. It was more toward the end
2 of the --
3 Q. So right before you’re supposed to leave to
4 Brazil --
5 A. No, right before we left Neverland.
6 Q. Oh, right before you left Neverland for
7 good.
8 A. No, right before -- maybe a few days.
9 Q. A few days before you left Neverland for
10 good.
11 A. Yes, because -- yeah.
12 Q. Okay. So it’s actually a little bit after
13 the interview with the social workers, then, right.
14 A. Maybe it’s a little bit after. And it’s
15 probably -- I don’t think it happened right -- like,
16 it didn’t happen, like, the day -- like, he did it,
17 and then the day after, we left. I don’t think it
18 happened like that.
19 Q. But it’s right before you leave Neverland
20 for good, right.
21 A. Maybe a week before, or something like that.
22 Q. Okay. Okay. And you’ve already had the
23 interview with the social workers, as you said,
24 right.
25 A. Yes.
26 Q. You’ve already been to the Calabasas Inn,
27 right.
28 A. Yes. 1691
 

 
1 Q. And you’ve already left the Calabasas Inn
2 and gone by The Laugh Factory and met with an
3 attorney, right.
4 A. I believe so.
5 Q. So after you meet with an attorney, you
6 suddenly come up with a story that you were
7 masturbated by Michael Jackson, correct.
8 MR. SNEDDON: Object. Argumentative, Your
9 Honor.
10 THE WITNESS: No, because --
11 MR. SNEDDON: Excuse me.
12 THE COURT: Overruled.
13 You can go ahead and answer.
14 Q. BY MR. MESEREAU: Correct.
15 A. No, because I did not tell the attorney
16 anything about what Michael was doing.
17 Q. But you’re saying it started after --
18 A. Yes, I did not tell the attorney anything
19 about alcohol or anything like that.
20 Q. Okay. Okay. Vinnie takes you, your mom,
21 and Star to The Laugh Factory on Sunset, correct.
22 A. Yes.
23 Q. You and your mom get out of the car, right.
24 A. Yes.
25 Q. You go into The Laugh Factory on Sunset,
26 correct.
27 A. Yes.
28 Q. You meet with Jamie Masada and an attorney 1692
 

 
1 named William Dickerman, correct.
2 A. Yes.
3 Q. You have a meeting with the two of them,
4 right.
5 A. Yes.
6 Q. You come back, you get in the car, right.
7 A. Yes.
8 Q. You go back to Neverland, right.
9 A. I think we did.
10 Q. And then you leave Neverland again, right.
11 A. I don’t know. I think. I guess.
12 Q. And not long after your meeting with the
13 attorney, you say that Mr. Jackson inappropriately
14 masturbates you, true.
15 A. No, because I didn’t really say it right
16 after I met him. I didn’t.
17 Q. It was a while after you met him, right.
18 A. Yeah.
19 Q. That’s when the inappropriate touching
20 starts.
21 A. I didn’t -- the only person I said it to was
22 to my psychologist, Dr. Katz, and the officer, Steve
23 Robel, and Paul Zelis, that’s --
24 Q. We’ll get to that. You first went to
25 Attorney Larry Feldman after Attorney William
26 Dickerman, correct.
27 A. Yes.
28 Q. And Attorney Larry Feldman then referred you 1693
 

 
1 to a psychologist, right.
2 A. Yes.
3 Q. When you first went to Attorney William
4 Dickerman, you were talking about being harassed and
5 things of that sort, correct.
6 A. I -- I don’t remember what I talked about.
7 Q. Well, you met with him with your mom, true.
8 A. Yes.
9 Q. And then you and your mom met with Larry
10 Feldman, right.
11 A. Yes.
12 Q. It was only after you met with Larry Feldman
13 that you started talking about inappropriate
14 touching, true.
15 A. I didn’t talk -- I didn’t randomly talk
16 about it with people.
17 Q. Well, I didn’t ask if you randomly talked
18 about it. I asked if you talked about it.
19 A. Who are you specifying that I talked about
20 it to.
21 Q. Larry Feldman, whom you knew had sued
22 Michael Jackson in the early ‘90s, right.
23 A. No, I did not tell anything like that to
24 Larry Feldman. The only person I told anything even
25 resolving (sic) to that was Dr. Katz. And I told
26 the whole story to Steve Robel and Paul Zelis.
27 Q. But, no, you first went to the two lawyers,
28 a psychologist, before you went to any police 1694
 

 
1 officer, true.
2 MR. SNEDDON: I’m going to object as
3 argumentative by saying “no” in the beginning.
4 MR. MESEREAU: I’ll rephrase it, if you
5 want, Your Honor.
6 THE COURT: All right.
7 Q. BY MR. MESEREAU: You went to two lawyers,
8 and a psychologist whom Larry Feldman referred you
9 to, before you went to any police officer, right.
10 A. Yes.
11 Q. Now, these weren’t the first attorneys
12 you’ve ever talked to, correct.
13 A. I’ve talked to other people, other attorneys
14 before.
15 Q. Well, you had an attorney representing you
16 in the J.C. Penney case, correct.
17 A. I think so. I’m pretty sure.
18 Q. You testified under oath in that case,
19 correct.
20 A. Yes.
21 Q. Did you tell the truth under oath in that
22 case.
23 A. Of course.
24 Q. Didn’t tell one solitary lie.
25 A. No.
26 Q. You said that security guards had body
27 slammed your mother in a parking lot.
28 MR. SNEDDON: Your Honor, I’m going to 1695
 

 
1 object. 403 ruling.
2 THE COURT: Sustained.
3 Q. BY MR. MESEREAU: How many days -- just a
4 couple of days before you left Neverland for good,
5 you’re saying this inappropriate touching went on.
6 A. No, I said probably -- maybe a week or two.
7 Q. Couple of days. You said a couple days
8 before, didn’t you.
9 A. No, I said maybe a week or two.
10 Q. Well, but after you went with the lawyer,
11 though, right.
12 MR. SNEDDON: Object as argumentative, Your
13 Honor.
14 MR. MESEREAU: All right. It’s asked and
15 answered. I’ll rephrase.
16 MR. SNEDDON: That, too.
17 Q. BY MR. MESEREAU: Now, you told the jury
18 yesterday that Michael Jackson didn’t do much for
19 your cancer, correct.
20 A. Yes.
21 Q. Was that a true statement.
22 A. Yeah, because I didn’t see him much. He
23 would tell me that he wasn’t there, when he was
24 there at the ranch. And it made me really sad,
25 because in my mind, he was my best friend in the
26 whole world, and my best friend was trying to avoid
27 me while I had cancer.
28 Q. Did Michael Jackson call you at the hospital 1696
 

 
1 while you had cancer.
2 A. Yes, he called me and invited me up to the
3 ranch.
4 Q. He talked to to you a lot in the hospital,
5 didn’t he.
6 A. No.
7 Q. Do you remember telling the police in your
8 first interview -- you were asked the question, “And
9 did you talk to him a lot while you were in the
10 hospital.”
11 “A. I talked to him a lot. Like, he would
12 call and I’d call him and stuff, and we’d just
13 talk about, like, video games.”
14 Do you remember that.
15 A. Yeah. I probably meant lengthy conversation
16 as in time.
17 Q. You were then asked, “How often did he call
18 you.”
19 “I don’t know. But I think it was probably
20 at least three times a week or something.”
21 Do you remember that.
22 A. Yeah. Including outside of the hospital.
23 My grandmother’s house.
24 Q. But that’s not what you told the sheriffs,
25 was it. You told him that he called you
26 approximately three times a week.
27 MR. SNEDDON: Excuse me. He’s not even
28 giving the witness a chance to answer the question. 1697
 

 
1 MR. MESEREAU: I thought he answered the
2 question.
3 THE COURT: You’re cutting him off.
4 MR. MESEREAU: I apologize. Pardon me.
5 Let’s go over it again.
6 Q. You told Santa Barbara Sheriffs in your
7 first interview, Mr. Arvizo, that Michael Jackson
8 called you about three times a week at the hospital
9 and you would talk for two or three hours at a time,
10 correct.
11 A. Yeah. During the -- probably during the
12 period of when -- in the beginning, of the first
13 few -- two months of my cancer where I was actually
14 going and hanging out with Michael. And after those
15 two months, it was all cut off.
16 Q. Did you tell the Santa Barbara Sheriffs that
17 when you were in the hospital with cancer --
18 A. Uh-huh.
19 Q. -- Michael Jackson would call you at least
20 three times a week, and speak to you for an hour,
21 two hours or three hours at a time.
22 A. Michael would call me during the --
23 probably -- during the beginning of my cancer,
24 probably three times a week. And I would call him
25 and we would talk for a long time. We would talk
26 about video games. We would talk about people he
27 knew, people I knew, stuff like that.
28 Q. In the hospital, right. 1698
 

 
1 A. Sometimes he would call me in the hospital.
2 Q. I’d like to explore your statement to the
3 jury that he didn’t do much to you -- much for you
4 when you had cancer.
5 A. Okay.
6 Q. You’ve just talked about the calls, right.
7 A. Yeah.
8 Q. He invites your family to his home, correct.
9 A. He invited us to Neverland in the beginning,
10 yeah.
11 Q. He lets your family stay at his home for
12 weeks, correct.
13 A. Yeah.
14 Q. He gives you a car to use, true.
15 A. Yes, same car he takes back in the middle of
16 the time that I really needed a -- that my family
17 needed a car.
18 Q. Gives your family an SUV so they can go back
19 and forth to the hospital, right.
20 A. Yes.
21 Q. Gives you a computer, right.
22 A. Yes.
23 Q. Flies your family to Florida and lets them
24 stay at a resort for two nights, right.
25 A. No, he took me to Florida in result of the
26 Martin Bashir documentary that was being aired.
27 Q. Did your family stay at the resort hotel
28 called Turnberry in Florida. 1699
 

 
1 A. Michael put us up in the resort, in the
2 Turnberry.
3 Q. Did you get a massage.
4 A. Yes. Chris Tucker paid for that massage.
5 Q. Okay. Did you get a massage.
6 A. Yes. Chris Tucker paid for that massage.
7 Q. Did you get a watch --
8 A. Yes.
9 Q. -- from Mr. Jackson.
10 A. Yes.
11 Q. Did you get a jacket from Mr. Jackson.
12 A. Yes.
13 Q. Did your family go back and forth and stay
14 at Neverland free.
15 A. Everyone stays at Neverland for free.
16 Q. Well, who do you think pays the bills.
17 MR. SNEDDON: Object as argumentative, Your
18 Honor.
19 THE COURT: Well, on both parts. Let’s start
20 another question. Don’t --
21 Q. BY MR. MESEREAU: Mr. Arvizo --
22 THE COURT: Just a minute. I’m sorry. I’ll
23 instruct both the witness and the attorney not to
24 argue with each other.
25 Q. BY MR. MESEREAU: Mr. Arvizo, your family
26 would stay for weeks free of charge at Neverland,
27 true.
28 A. Yes. 1700
 

 
1 Q. Your meals would be paid by -- for by Mr.
2 Jackson, true.
3 A. Probably. Yes.
4 Q. Do you know someone else that paid for it.
5 A. No. But I was pretty sure it was Michael.
6 Q. You would travel by limousine back and
7 forth, true.
8 A. Yes.
9 Q. You also traveled by Rolls Royce on
10 occasion, true.
11 A. No, I only traveled in a Rolls Royce when I
12 was escaping from Neverland with Jesus.
13 Q. When you were escaping.
14 A. Yes.
15 Q. And you went back -- how long after you
16 escaped did you go back there again.
17 A. I think a few days later, when Vinnie and
18 Frank came down.
19 Q. Okay. Okay. When you escaped, where did
20 Jesus take you.
21 A. He took me to my grandmother’s house.
22 Q. And then two days later you went back with
23 Vinnie.
24 A. I don’t know about two days, but maybe a few
25 days.
26 Q. So you went back, and then you escaped a
27 second time, right.
28 A. I think so. Whatever. 1701
 

 
1 Q. And then you went back and you escaped a
2 third time, right.
3 A. No.
4 Q. Well, there were like three escapes, weren’t
5 there.
6 A. I don’t know.
7 Q. Okay. Have you ever talked to Mr. Sneddon
8 about how many times you people went back
9 voluntarily and then escaped from Neverland.
10 A. Mr. Sneddon.
11 Q. Yes.
12 A. I think we did. I’m pretty sure we did.
13 Q. When you were at Neverland, you would use
14 the amusement park when you wanted, correct.
15 A. Yes. But -- well, I couldn’t always do it
16 because I would feel sick all the time --
17 Q. Well --
18 A. -- with cancer.
19 Q. -- who do you think paid the utilities to
20 run all the amusement rides at Neverland.
21 A. Probably Michael.
22 Q. And you would use the zoo when you wanted,
23 correct.
24 A. No, because I wouldn’t go to the zoo.
25 Michael would take us over there when he wanted to
26 take us over there, and we’d see the tigers.
27 Q. Who do you think was paying for all of that.
28 A. Michael, because Michael wanted all that in 1702
 

 
1 his house.
2 Q. Oh. And do you think he was really being
3 good to you by letting you stay there and go to the
4 zoo, the amusement rides.
5 A. He probably was. But, I mean, this is
6 talking about the first few months. And I don’t
7 really -- see, Mr. Mesereau, it takes more --
8 MR. MESEREAU: Objection, Your Honor. Could
9 he just answer the question.
10 THE COURT: Sustained.
11 Just answer the question.
12 Q. BY MR. MESEREAU: Did you use ATV’s at
13 Neverland.
14 A. Yes. Yes.
15 Q. Who paid for the ATV’s.
16 A. I’m pretty sure Michael paid for the ATV’s.
17 Q. What else did you do at Neverland when you
18 used to hang out there with your brother, your
19 sister, your father, your mother.
20 A. Probably be in my unit, because I was sick.
21 Q. Was there a blood drive for you at
22 Neverland.
23 A. Yeah.
24 Q. And Mr. Jackson put that together, didn’t
25 he.
26 A. Probably.
27 Q. You don’t know.
28 A. No, I heard something about a blood drive, 1703
 

 
1 but I can’t really remember too much about it.
2 Q. You don’t remember a blood drive at
3 Neverland that Mr. Jackson put together for you when
4 you had cancer.
5 A. I remember -- I remember something about my
6 friend -- my friend had come down to the hospital
7 and told me about it, but I don’t -- I remember
8 something about a blood drive, but I’m not too sure
9 about it. He -- I’m pretty sure he did.
10 Q. Now, I believe you told the jury yesterday
11 you thought George Lopez did more for you when you
12 had cancer than Michael Jackson, correct.
13 A. Yeah. For my 11 year-old mind, he came and
14 visited me and would always talk to me and buy me
15 shirts and stuff.
16 Q. Did Mr. Lopez let your family move into his
17 home.
18 MR. SNEDDON: Object as argumentative, Your
19 Honor.
20 THE COURT: Sustained.
21 Q. BY MR. MESEREAU: Mr. Arvizo, did Mr. Lopez
22 give you a Rolls Royce for your family to ride
23 around town in.
24 A. No.
25 Q. Did he provide limousines for your family to
26 ride around town in.
27 A. No.
28 Q. Did he pay a lot of your bills so your 1704
 

 
1 family could stay at hotels.
2 A. I don’t know. That’s up to my --
3 Q. Did he pay for flights so your family could
4 go cross country.
5 A. I’m pretty sure he did, to pay for us to go
6 to Miami.
7 Q. How many times do you think your family
8 visited Neverland and stayed there.
9 A. Every time Michael wanted us to.
10 Q. But you went there many times when Michael
11 wasn’t even there, right, Mr. Arvizo.
12 A. Only with Michael’s permission.
13 Q. Did you and your family go to Neverland and
14 stay many times when Michael Jackson wasn’t even
15 around.
16 A. I would. Not my whole family. Me and my
17 father would. Because in the first two months of my
18 cancer, when I was -- when I thought I was pretty
19 close to Michael, I would go up there and stay with
20 him between my rounds of chemotherapy.
21 Q. Can you look this jury in eye and tell them
22 Michael Jackson did nothing for you when you had
23 cancer.
24 A. I never said Michael did nothing for me.
25 Q. Did you say he did very little.
26 A. Yeah. He didn’t do as much as I felt, as my
27 11-year-old mind felt.
28 Q. He should. 1705
 

 
1 A. No. He shouldn’t -- it’s not his obligation
2 to do anything.
3 Q. Well, are you telling the jury you deserved
4 a lot more from Michael Jackson than you and your
5 family got.
6 A. No.
7 Q. Is that what you’re saying.
8 A. No. I’m just saying that -- see, when I
9 have a friend, Michael, and you’re saying all these
10 things that he did, but, you know, when my
11 11-year-old mind -- and when I see my friend say
12 that he’s not there, and he’s not at Neverland Ranch
13 trying -- and I see him walking and I see his car
14 that he only drives going down at Neverland, you
15 know, it felt like my heart broke right there.
16 Q. So by doing all of these things --
17 A. And I don’t remember George Lopez or Jamie
18 Masada or Louise Palanker ever doing that to me.
19 Q. Did they take your family into their homes,
20 any of them.
21 A. Actually, I went over to -- actually, I
22 spent a night at Chris Tucker’s house.
23 Q. Did he let your family move into his home;
24 yes or no.
25 A. I’m sure he probably would have if we really
26 got to a point where we couldn’t live at our house
27 no more.
28 Q. There isn’t one celebrity that you 1706
 

 
1 approached who let your family move into his home,
2 except Michael Jackson, true.
3 A. I didn’t --
4 MR. SNEDDON: Excuse me. I’m going to
5 object to the question. Assumes a fact not in
6 evidence, and it’s argumentative.
7 THE COURT: Overruled.
8 THE WITNESS: I never moved into Michael’s
9 house. I never moved my stuff over there and lived
10 there permanently. I stood there and visited.
11 Q. BY MR. MESEREAU: Your family was there for
12 weeks at a time, correct.
13 A. Yes. And they also kept us there for weeks
14 at a time when we wanted to leave.
15 Q. Is this one of your many escapes where you
16 came back.
17 MR. SNEDDON: Object as argumentative, Your
18 Honor.
19 THE COURT: Sustained.
20 MR. MESEREAU: I withdraw it, Your Honor.
21 Q. Mr. Arvizo, when your family decided not to
22 go to Brazil, where did they go.
23 A. What do you mean.
24 Q. Well, when your family decided they didn’t
25 want to go to Brazil, they went to your
26 grandparents’ house, right.
27 A. When we left with Jesus, we went to my
28 grandma’s house. I don’t really understand. 1707
 

 
1 Q. When you left with Vinnie for the final
2 time, you went to your grandparents’, right.
3 A. I don’t really -- as I told Mr. Sneddon, I
4 don’t really remember how it came about that we left
5 the last time.
6 Q. I’m not asking you how it came about. But
7 you got in a car with Vinnie and went to your
8 grandparents’ the last time.
9 A. Now you’re telling -- right now you’re
10 telling me how it came about. I don’t know how it
11 came about.
12 Q. Do you recall Vinnie taking your family to
13 your grandparents’ when you left Neverland for good.
14 A. No, because I do not remember what happened
15 when we left for the last time.
16 Q. Do you remember leaving for the last time at
17 all.
18 A. I know that we left, because I remember, I
19 went to my grandma’s house.
20 Q. When you say you escaped with Jesus, where
21 did you escape to.
22 A. We went to my grandma’s house.
23 Q. Jesus took you in a Rolls Royce to your
24 grandma’s house, right.
25 A. Yes.
26 Q. When your family wanted to leave, they left,
27 right.
28 MR. SNEDDON: Object; argumentative. 1708
 

 
1 THE COURT: Overruled.
2 THE WITNESS: Can you repeat the question.
3 Q. BY MR. MESEREAU: When your family wanted to
4 leave Neverland, you either had a limousine or a
5 Rolls Royce take you where you wanted to go, right.
6 A. No. It wasn’t a limousine. And we never
7 left in a limousine, because when we left it was
8 when they didn’t really know.
9 Q. It was a Rolls Royce, wasn’t it.
10 A. Yes, because that was the only car
11 available. It wasn’t as if we told Jesus to take us
12 in a Rolls Royce.
13 Q. Okay.
14 A. It was a vehicle. An automobile that we can
15 use to leave.
16 Q. Has any lawyer told you what to say in this
17 courtroom.
18 A. No.
19 Q. Has any lawyer ever told you what to say
20 under oath.
21 A. No.
22 Q. Remember, your deposition was taken in the
23 J.C. Penney case.
24 A. Yes. It was taken when I had cancer,
25 because I was unable to show up at the court case.
26 Q. And that was when you and your mom were
27 suing J.C. Penney, correct.
28 A. I believe it was my whole family that was 1709
 

 
1 suing them.
2 Q. Did a lawyer tell you what to say in that
3 case.
4 A. No.
5 Q. Remember, you said under oath, “Did anyone
6 tell you what you should testify about here today or
7 how you should say things,” and your answer was,
8 “Only our lawyer”.
9 A. What.
10 Q. Do you remember saying that in the J.C.
11 Penney deposition.
12 A. No.
13 Q. Would it refresh your recollection if I just
14 show that to you.
15 A. Uhh, sure, I guess.
16 MR. MESEREAU: May I approach, Your Honor.
17 THE COURT: Yes.
18 Q. BY MR. MESEREAU: Have you had a chance to
19 review that page of your deposition in the J.C.
20 Penney case.
21 A. Yes.
22 Q. Remember testifying that a lawyer had told
23 you what to say.
24 A. They didn’t tell us what to say.
25 Q. Huh.
26 A. They didn’t tell us what to say.
27 Q. But that’s what you said when you had your
28 deposition taken, right. 1710
 

 
1 A. They probably -- I don’t know, because, I
2 mean, I was eight years old. And I don’t really
3 remember what was going on.
4 Q. You were ten years old, right.
5 A. Maybe -- ten years old probably at the
6 deposition. But, I mean, I was eight years old when
7 it happened.
8 Q. Did you and your mom talk about the facts of
9 that case before your deposition was taken.
10 A. No, I don’t think we were allowed to.
11 Q. So you never discussed it with your mom
12 before the deposition was taken.
13 A. No.
14 Q. Have you ever talked about the facts of this
15 case with your mother.
16 A. No. I don’t think we’re allowed to either.
17 Q. So you’ve never discussed the facts of this
18 case with your mother.
19 A. Um, no.
20 Q. Have you ever discussed the Bashir
21 documentary with your mother.
22 A. Yeah.
23 Q. When.
24 A. We had talked about it with her sometimes,
25 like how I felt about what I said on there.
26 Q. And when did you last discuss the Bashir
27 documentary with your mother.
28 A. I do not remember. 1711
 

 
1 Q. Pardon me.
2 A. I don’t remember.
3 MR. MESEREAU: Okay.
4 THE COURT: We’ve come to the end of the day.
5 MR. MESEREAU: Thank you, Your Honor.
6 THE COURT: We’re going to do something
7 different. Everyone remain seated, please.
8 Take the jury and the witness out.
9 I’ll see you all Monday.
10 A JUROR: Bye.
11
12 (The following proceedings were held in
13 open court outside the presence and hearing of the
14 jury:)
15
16 THE COURT: I just didn’t want to say this in
17 front of the jury.
18 This morning I issued a warrant for Mr.
19 Jackson’s arrest and held it for an hour. The
20 warrant is recalled.
21 The Court also forfeited Mr. Jackson’s bail
22 at the request of Mr. Jackson. His bonding company
23 has agreed to resume the liability on the bond, and
24 has given the Court permission to reinstate the
25 bond. The Court therefore reinstates the bond as
26 previously -- as previously filed and orders that
27 the reinstatement be filed with the Court.
28 Court’s in recess. Thank you. 1712
 

 
1 (The proceedings adjourned at 2:30 p.m.)
2 --o0o--
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28 1713
 

 
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 1534 through 1713
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 March 10, 2005, and thereafter
20 reduced to typewriting by computer-aided
21 transcription under my direction.
22 DATED: Santa Maria, California,
23 March 10, 2005.
24
25
26
27 MICHELE MATTSON McNEIL, RPR, CRR, CSR #3304
28 1714
