


6140

1 SUPERIOR COURT OF THE STATE OF CALIFORNIA

2 IN AND FOR THE COUNTY OF SANTA BARBARA

3 SANTA MARIA BRANCH; COOK STREET DIVISION

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

5

6

7 THE PEOPLE OF THE STATE OF )

8 CALIFORNIA, )

9 Plaintiff, )

10 -vs- ) No. 1133603

11 MICHAEL JOE JACKSON, )

12 Defendant. )

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15

16

17 REPORTER’S TRANSCRIPT OF PROCEEDINGS

18

19 THURSDAY, APRIL 14, 2005

20

21 8:30 A.M.

22

23 (PAGES 6140 THROUGH 6198)

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26

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

28 BY: Official Court Reporter 6140



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)

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28 6141



1 I N D E X

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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.

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9 PLAINTIFF’S WITNESSES DIRECT CROSS REDIRECT RECROSS

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11 JACKSON, Janet 6144-Z (Contd.)

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28 6142



1 E X H I B I T S

2 FOR IN

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

4 24 Photograph 6165 6166

5 810 CD of DCFS interview 6178 6187

6 811 Releases given to Janet Arvizo

7 for signature 6194

8 812 Unsigned releases given to Janet Arvizo for signature 6194

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28 6143



1 Santa Maria, California

2 Thursday, April 14, 2005

3 8:30 a.m.

4

5 THE COURT: Good morning.

6 THE JURY: (In unison) Good morning.

7 COUNSEL AT COUNSEL TABLE: (In unison)

8 Good morning, Your Honor.

9 THE COURT: Ready to proceed?

10 MR. ZONEN: Yes, Your Honor.

11 THE COURT: Go ahead.

12

13 JANET JACKSON

14 Having been previously sworn, resumed the

15 stand and testified further as follows:

16

17 DIRECT EXAMINATION (Continued)

18 BY MR. ZONEN:

19 Q. Miss Arvizo, good morning.

20 A. Good morning. How are you?

21 Q. When we left off yesterday, we had been

22 talking about the interview with Brad Miller that

23 took place at your then boyfriend’s house, Major

24 Jackson; is that correct?

25 A. Yes.

26 THE BAILIFF: Is your microphone on?

27 MR. ZONEN: Yes. Just need to be closer,

28 okay. 6144



1 Q. When was it that you returned back to

2 Neverland after that interview?

3 A. The next day.

4 Q. And did you return back with your children?

5 A. Yes, I did.

6 Q. Did you have an understanding about that

7 with Frank?

8 A. Yes.

9 Q. When was that conversation? When did that

10 conversation take place?

11 A. Every day, many conversations. Even on that

12 day, the next day.

13 Q. Was there a conversation with Frank after

14 the interview with Brad Miller?

15 A. Yes. Even during.

16 Q. Even during?

17 A. Yes.

18 Q. Did he call during that?

19 A. Yes, he did.

20 Q. And did you speak with him during that?

21 A. Yes.

22 Q. All right. Tell me about the understanding

23 that you had with Frank about returning to

24 Neverland.

25 A. That the Germans had been fired, and -- and

26 me and the kids were coming back, and we didn’t have

27 to do the video at that point.

28 Q. And that’s when you went back to Neverland; 6145



1 is that correct?

2 A. That’s when I went back.

3 Q. Now, there was going to be a DCFS interview;

4 is that correct?

5 A. Yes.

6 Q. And that was going to be on the 20th?

7 A. Yes.

8 Q. Tell us about the conversation that you had

9 with Frank about the rebuttal video.

10 A. Okay.

11 Q. And specifically in time after you had

12 learned that there was going to be an interview with

13 your children with DCFS.

14 A. First, he had told me, no, that he wasn’t

15 going to bring the two kids back. It evolved and

16 that made me very stressed. And then he says the

17 only way they’ll bring back the kids if I do the

18 video. And then it evolved into that I wouldn’t

19 have to leave out of -- leave the country.

20 Q. You were already having conversations with

21 Frank about leaving the country?

22 A. Oh, yeah, that had been since --

23 Q. And had the location of where you were

24 supposed to go already been resolved?

25 A. Yes, Brazil.

26 Q. Brazil? All right. You then went back to

27 Neverland, you’ve already described. And then you

28 then turned around and went back to Los Angeles; is 6146



1 that correct?

2 A. Yes.

3 Q. Now, the rebuttal video took place where?

4 A. At Hamid’s house.

5 Q. Can you tell us when it took place?

6 A. The 19th until the 20th, like past

7 11-something at night, all the way into the a.m.

8 hours.

9 Q. The 19th of February being a Wednesday, I

10 think we’ve already established.

11 A. Yes.

12 Q. So it was late at night?

13 A. Yes.

14 Q. Into the morning hours?

15 A. Yes.

16 Q. Where did it take place?

17 A. In Hamid’s house.

18 Q. And Hamid is who?

19 A. His personal videographer.

20 Q. Had you met Hamid before that day?

21 A. I don’t think so.

22 Q. Do you know Hamid’s last name?

23 A. Moslehi.

24 Q. Moslehi?

25 A. Yes.

26 Q. How did you get to Hamid’s house?

27 A. Vinnie drove me.

28 Q. Do you know where Hamid lives? 6147



1 A. And that’s the first time that I met Vinnie.

2 Q. That’s the first time you met Vinnie?

3 A. Yes.

4 Q. Do you know where Hamid lives, or at least

5 lived at that time?

6 A. No. I just know we drove a long way, and I

7 met -- they said something about San Fernando

8 Valley, but I really don’t know where he lives.

9 Q. Do you know how long it took to drive from

10 Jackson’s apartment to Hamid’s residence?

11 A. No, I couldn’t tell you.

12 Q. Could you describe Hamid’s residence to us?

13 A. Yeah, I can.

14 Q. Go ahead and do so.

15 A. He has a bedroom. Rest room. The dining

16 area, but he had -- to me, I assumed it was a dining

17 area, but he had, like, some kind of table there,

18 and then this open area and the kitchen. But

19 everything’s, like, in -- open.

20 Q. All right. Now, were your kids there?

21 A. Yes.

22 Q. Were they there when you arrived?

23 A. Yes.

24 Q. Do you know how your kids got there?

25 A. My understanding is that Hamid took them

26 there himself.

27 Q. All right. And you say somebody named

28 “Vinnie” took you; is that right? 6148



1 A. Yes.

2 Q. Do you know Vinnie’s last name?

3 A. Amen.

4 Q. A-m-e-n?

5 A. Yes. Yeah.

6 Q. All right. You had never met Vinnie before?

7 A. No.

8 Q. Did he introduce himself to you in some

9 fashion?

10 A. Well, actually, Frank did the introduction

11 before.

12 Q. Frank did the introduction in person?

13 A. No, no, no. No. Frank, over the phone,

14 told me about Vinnie.

15 Q. All right.

16 A. And then Vinnie had shown up.

17 Q. So you knew in advance somebody named

18 “Vinnie” was coming?

19 A. Yes.

20 Q. Did Frank tell you who Vinnie was?

21 A. Yes.

22 Q. What did he say about Vinnie?

23 A. That he’s one of Michael’s people.

24 Q. Did he arrive with anybody else or by

25 himself?

26 A. By himself.

27 Q. Do you know approximately what time it was?

28 A. It was about -- I don’t know. My best 6149



1 estimate, probably about 11:00.

2 Q. Do you know why this video was done at

3 Hamid’s house in the San Fernando Valley?

4 A. Yeah. I didn’t want to go back to

5 Neverland.

6 Q. Did you say that to somebody?

7 A. Yes, I said it to Frank.

8 Q. All right. Now, at the video at Hamid’s

9 house, tell us who else was present.

10 A. Oh. In Hamid’s house, Brad Miller’s there,

11 on top of the film crew, Hamid, Vinnie, and Frank

12 continuously on the telephone.

13 Q. All right. So Miller was there, Brad

14 Miller?

15 A. Yes.

16 Q. Was he already there when you arrived?

17 A. Yes.

18 Q. Hamid, I assume, was already there?

19 A. Yes. My kids.

20 Q. Vinnie came with you?

21 A. Yes.

22 Q. Your three kids?

23 A. Yes.

24 Q. Anybody else that you can recall?

25 A. Yeah.

26 Q. Who else?

27 A. Christian. The one who’s asking the

28 scripted questions. 6150



1 Q. Christian was there?

2 A. Yes.

3 Q. Were either of the Germans there?

4 A. No. No Germans.

5 Q. But there were scripted questions?

6 A. Yes.

7 Q. Were these questions that you had already

8 seen?

9 A. Yes.

10 Q. And who had shown them to you?

11 A. Dieter.

12 Q. And when was that?

13 A. In Neverland.

14 Q. Was that prior to your leaving Neverland?

15 A. Yes. Prior to leaving with Jesus. And it

16 continued afterwards with Frank on the phone.

17 Q. So Frank went over the questions as well?

18 A. Yes.

19 Q. What essentially was it that they wanted you

20 to say?

21 A. Basically he’s a -- you know, a father

22 figure, everything in an answer to this Bashir

23 thing.

24 Q. All right. But what specifically was it

25 that they asked you to say?

26 MR. MESEREAU: I’m going to object to the

27 word “they” as vague.

28 THE COURT: Just a moment, please. 6151



1 Sustained.

2 MR. ZONEN: I’m sorry, I didn’t hear.

3 THE COURT: The word “they.”

4 MR. ZONEN: Oh, yes, that’s fine.

5 Q. Let’s start with Frank. Tell us what

6 exactly it was that Frank wanted you to say in this

7 video.

8 A. What I got in trouble for or what I ended up

9 actually saying?

10 Q. No, no. Tell us, in advance of doing this

11 video, what was it that Frank wanted you to say on

12 this video?

13 A. That he’s a wonderful father.

14 Q. Did he use the word “father”?

15 A. Yes. Basically, in summary, that he’s a

16 wonderful father.

17 Q. Now, with regard -- in regard to his own

18 children or in regards to your children?

19 A. To my children.

20 Q. Did you feel that that statement was

21 accurate?

22 A. I was confused. I was confused, and I was

23 sad at that moment.

24 Q. What was your confusion?

25 A. Well, because I -- I -- as things evolved,

26 I ended up finding out who were the bad guys.

27 Q. I’m asking you, now that you had this

28 conversation with Frank -- 6152



1 A. I was confused with him, because I still

2 believed his initial meeting in Miami. But I was

3 still -- and I was sad and confused as to why

4 everything was happening. I didn’t know why.

5 Q. Did you, in fact, say on the video that you

6 thought he was a father figure to your children?

7 A. I think so. Many times. In different ways.

8 Q. Did you mean it when you said it?

9 A. I was confused. I was sad. So basically I

10 was acting.

11 Q. What would you have been willing to say on

12 his behalf at that time if you had not been given a

13 script?

14 MR. MESEREAU: Objection; calls for

15 speculation.

16 MR. ZONEN: Relevant for her state of mind.

17 THE COURT: Overruled.

18 You may answer.

19 Q. BY MR. ZONEN: Do you understand the

20 question?

21 A. Yes. Nice things.

22 Q. Nice things like what?

23 A. Nice things of everything; that I believed

24 him in the initial meeting that he had told me in

25 Miami.

26 Q. Up to this point, had you had any reason to

27 be concerned about Mr. Jackson?

28 A. No. I was just sad and confused. 6153



1 Q. The incident that you saw on the plane

2 returning --

3 A. Yes.

4 Q. -- him licking Gavin --

5 A. Yes.

6 Q. -- was that something that you were thinking

7 about at the time of this video?

8 A. No, I --

9 MR. MESEREAU: Objection; leading.

10 THE WITNESS: I thought it was --

11 THE COURT: Sustained.

12 Just a moment.

13 The answer is in, but I’ll sustain the

14 objection. Next question.

15 Q. BY MR. ZONEN: What was your thought process

16 with regards to that licking incident?

17 MR. MESEREAU: Objection. Leading;

18 foundation.

19 THE COURT: Based on her answer to the

20 question that I sustained the objection to, I’ll

21 sustain this objection.

22 MR. ZONEN: All right.

23 Q. Did you have any concerns about Mr. Jackson

24 at all during the course of that video?

25 A. I said I was confused and I was sad, and

26 that’s it. And the prior incident on the airplane,

27 that had already been out of my mind.

28 Q. Did they talk to you about how you would 6154



1 dress for this video, or makeup, or anything like

2 that?

3 A. No.

4 Q. Did you do all that on your own?

5 A. No. Right there, inside the -- when I had

6 arrived there, Vinnie had told me to go ahead and

7 put some more on, and -- but Frank -- and that was

8 per Frank’s instructions to Vinnie.

9 Q. Hold on a second.

10 A. Because Vinnie had given him like an update

11 to how I looked.

12 Q. Now, did somebody talk to you in advance of

13 your going to Hamid’s house --

14 A. Yes, yes, at Jay’s house.

15 Q. You have to let me finish the question.

16 A. Oh, okay.

17 Q. Did somebody talk to you in advance of your

18 arrival at Hamid’s as to how you should dress, how

19 you should wear your hair, or how you should wear

20 makeup?

21 A. To put on makeup, because usually I don’t

22 put on makeup.

23 Q. And who was it who talked to you about that?

24 A. Frank.

25 Q. And that was over the telephone?

26 A. Yes.

27 Q. Did you have any further discussion with

28 anybody at Hamid’s house about makeup or hair or 6155



1 dress?

2 A. Well, Vinnie had given Frank an update as to

3 how I was. And then Vinnie, per Frank’s

4 instructions, told me to put some more on.

5 Q. Some more what?

6 A. Makeup.

7 Q. How about clothing, who made the decision as

8 to what clothing you would wear?

9 A. Nobody.

10 Q. You made that decision on your own?

11 A. I just -- yeah, yeah.

12 Q. Do you know what time that video started?

13 A. I think it was about -- I think it was about

14 3:00 a.m. I’m not sure.

15 Q. Do you know what time it was that you

16 arrived at Hamid’s house?

17 A. No. It was already the a.m. hours.

18 Q. What time did you -- what time was your

19 meeting with the Department of Child & Family

20 Services?

21 A. It was scheduled at 9:00, and -- but it

22 started around 10:00.

23 Q. And you’re talking about the next morning?

24 A. Yeah. And I hadn’t slept all night.

25 Q. All right. The -- the video then ended at

26 approximately what time?

27 A. I wouldn’t be able to tell you. I wouldn’t

28 be -- but it was definitely -- it was already 6156



1 morning, a.m. hours.

2 Q. Did you have any sleep at all that night?

3 A. Zero. Zero sleep.

4 Q. Before the video, did you have a

5 conversation with anybody over the telephone?

6 A. Before the video?

7 Q. Yes.

8 A. Yeah.

9 Q. With whom?

10 A. With Vicky Poderevski.

11 Q. How -- tell me how that came about.

12 A. Brad Miller dialed the phone, his private

13 investigator. And he handed it to me, and this

14 woman was on the phone.

15 Q. Did he tell you in advance that he was

16 dialing that number?

17 A. No.

18 Q. Did he tell you in advance who he was

19 calling?

20 A. No. And that was scary.

21 Q. When he -- so the first time you knew you

22 were getting on the phone with somebody is when he

23 handed you the phone?

24 A. Yeah, he dialed the number and handed it to

25 me.

26 Q. Did he tell you who the person was?

27 A. No. Zero.

28 Q. Or why he wanted you to talk to this person? 6157



1 A. No.

2 Q. And the person at the other end of the line

3 identified herself as who?

4 A. Vicky Poderevski, an attorney for Michael

5 Jackson and Geragos.

6 Q. And what did she tell you?

7 A. I came to find out per the investigation

8 now, but this is what they told me then.

9 Q. I’m asking you what you understood at the

10 time --

11 A. Okay.

12 Q. -- not what you’ve learned since.

13 A. Okay.

14 Q. All right? At the time of this

15 conversation, what did Miss Poderevski tell you?

16 A. That she was an attorney for Michael Jackson

17 and Geragos.

18 Q. And what did she recommend to you?

19 A. She recommended that she be present at the

20 CPS meeting.

21 Q. And what did you say?

22 A. “No.”

23 Q. Did she talk to you about who would pay her

24 bill at all?

25 A. No.

26 Q. Was there any discussion about payment?

27 A. No.

28 Q. Why did you say no, if she was offering her 6158



1 services?

2 A. Because I -- in the past, I had spoken to,

3 not these same exact people, but a different

4 department -- same department but different group of

5 people, and different city. And they were nice

6 people.

7 Q. And that was in --

8 A. Actually, it was a person. Nice person.

9 Q. When was that?

10 A. That was when David had been arrested. They

11 had sent someone from that department. But totally

12 different city. Totally different building.

13 Q. All right. But your experience with them

14 was what at the time?

15 A. It was positive. And you know what I liked

16 about her, is that she was concerned about my kids,

17 not me.

18 Q. You’re talking about the prior experience?

19 A. The prior one.

20 Q. All right. Did you have concerns about the

21 meeting the next morning?

22 A. Yes, I did.

23 Q. What were your concerns?

24 A. That my children were going to be taken away

25 from me.

26 Q. Did somebody tell you that?

27 A. Yes.

28 Q. Who? 6159



1 A. Vicky.

2 Q. Did you, in fact, have somebody present with

3 you at that time?

4 A. At the CPS meeting?

5 Q. Yes.

6 A. Not by my choice.

7 Q. Now, who is it that took you to the meeting

8 with the Department of Child & Family Services?

9 A. Vinnie. Vinnie took my children and me back

10 to Jay’s.

11 Q. Was anybody else present during that time?

12 A. No.

13 Q. I mean in the car coming back.

14 A. No.

15 Q. Just Vinnie, you and your children?

16 A. Yeah, and then another car following us.

17 Q. All right.

18 A. There was always --

19 Q. Do you know approximately what time in the

20 morning it was you arrived back at Jay’s house?

21 A. I think it was -- it was about one hour

22 prior to Jay going to work.

23 Q. So Jay was still there when you arrived?

24 A. Yeah.

25 Q. Had you told Jay in advance that there was

26 going to be that meeting at his house?

27 A. I think so.

28 Q. Did Jay stay for that meeting? 6160



1 A. No.

2 Q. Tell us, at the point that everybody arrived

3 at the apartment, how many people did you have at

4 the apartment?

5 A. Vinnie, me, the children, and then that --

6 those people that were following us.

7 Q. Excuse me.

8 A. But they --

9 Q. I’m sorry, do that one more time for me. I

10 didn’t hear. Who was there?

11 A. Me, Vinnie and the children, and those

12 people that were following us.

13 Q. You, Vinnie, the children, the people in the

14 other car?

15 A. Yes.

16 Q. Was it just one other car?

17 A. Yes.

18 Q. At some point in time, did you see who those

19 people were --

20 A. No.

21 Q. -- or who they were?

22 A. No.

23 Q. Who actually went into the apartment with

24 you?

25 A. Vinnie.

26 Q. Was Aja there at that time?

27 A. In -- in the meeting? Are we talking about

28 the meeting now? 6161



1 Q. We’re at Jay’s house now.

2 A. Okay.

3 Q. We’ve left Hamid’s house, all right?

4 A. Okay.

5 Q. And I think you said you arrived about an

6 hour before Jay went to work.

7 A. Yes. And my children --

8 Q. Can you tell us what time that was, if you

9 can recall?

10 A. I don’t know. The best I can recall is

11 maybe 5:00 or 6:00 a.m. That’s the best -- and

12 that’s just an estimate.

13 Q. The people who were in the other car, did

14 they go into the apartment with you?

15 A. No. No.

16 Q. At what time did the people from the

17 Department of Child Care Services arrive, Child

18 Family Services?

19 A. Okay. The meeting was scheduled for about

20 9:00, but it didn’t start until about 10:00. So I

21 don’t know. It’s within that time bracket,

22 because -- can I -- can I continue?

23 Q. Let me -- I’ll go ahead and ask.

24 A. Okay.

25 Q. Tell us who was there at the time that the

26 workers from the Department of Child Family Services

27 arrived.

28 A. Before the CPS people arrived? 6162



1 Q. Yes, before. Just before.

2 A. Okay. I know him as CPS, DCFS, different

3 names. But they’re all the same people to me, okay?

4 Asaf had arrived before those three ladies

5 did, before Aja did.

6 Q. And Aja?

7 A. Yes. Aja arrived just about the same time

8 as the ladies did.

9 Q. Was Vinnie still there?

10 A. Vinnie, no, no.

11 Q. Vinnie had left?

12 A. Yes.

13 Q. So he wasn’t in the apartment?

14 A. No. But he was within the area, now it’s my

15 understanding.

16 Q. But you didn’t see him in the apartment?

17 A. No, I didn’t.

18 Q. Was Asaf in the apartment?

19 A. Asaf was inside the apartment way before the

20 CPS people were.

21 Q. Did Aja arrive?

22 A. It’s almost as if Vinnie went out, Asaf came

23 in, like that.

24 Q. All right. How did Aja happen to be there?

25 A. Per Frank’s instruction, it was in -- per

26 my -- my suggestion -- his suggestion, my

27 suggestion, it was kind of like a compromise.

28 Q. Well, did you call Aja? 6163



1 A. Yes, I did.

2 Q. The “Aja” we’re referring to is Chris

3 Tucker’s girlfriend; is that right?

4 A. Yes.

5 Q. And your relationship with her up to that

6 point you would describe as how?

7 A. Real nice.

8 Q. Why did you want her to be there?

9 A. Well, it was -- like I said, it was kind of

10 like a compromise going back and forth with Frank,

11 until finally, I had to pick someone that he

12 approved of, and he approved of Aja.

13 Q. Why were you picking anybody, picking

14 somebody to do what?

15 A. Because Frank wanted an independent person

16 there, an independent person, because that’s per how

17 they use their choreography, they pull in

18 unsuspecting people until they stumble upon it.

19 Q. Why did you want Aja there?

20 A. I trusted her.

21 Q. Why did you want anybody there?

22 A. I was okay meeting with the CPS people by

23 myself, but it was per Frank’s instructions, and

24 then it ended up being a back-and-forth compromise

25 that he approved of her.

26 Q. Did Frank tell you who he wanted to be

27 present during this meeting?

28 A. No. He suggested Chris’s girlfriend, and 6164



1 then it went back and forth, and I -- I -- go ahead.

2 Q. “Chris’s girlfriend” being Aja?

3 A. Yes. And so I figured it would be okay. So

4 there was a period of compromising who.

5 Q. Is Asaf somebody you knew prior to that day?

6 A. No.

7 Q. That was the first time you met him?

8 A. Yes.

9 Q. Do you know Asaf’s last name?

10 A. No. I never learned it.

11 Q. Did you see him again after that day?

12 A. Asaf?

13 Q. Asaf.

14 A. I -- I think -- I think I did see him

15 briefly. I don’t remember clearly, but I think it

16 was a period between -- when I was in the Calabasas

17 area. And that’s briefly. I can’t remember that.

18 That’s my best -- I think that was the only other

19 time.

20 MR. ZONEN: Madam Clerk, is Exhibit No. 24

21 in evidence?

22 THE CLERK: It hasn’t been identified yet.

23 THE WITNESS: (To a juror) Bless you.

24 THE CLERK: It hasn’t been identified yet.

25 MR. ZONEN: May I approach the witness, Your

26 Honor?

27 THE COURT: Yes.

28 Q. BY MR. ZONEN: I’d like to show you two 6165



1 exhibits at this time, if I may. Exhibit No. 19

2 already in evidence, do you know who that is?

3 A. Vinnie Amen.

4 Q. Exhibit No. 24 for identification?

5 A. Asaf.

6 Q. All right. Is this photograph an accurate

7 photograph of Asaf?

8 A. Oh, yes, it is.

9 MR. ZONEN: Okay. Move to introduce --

10 THE WITNESS: It’s burned in here, their

11 faces.

12 MR. ZONEN: Move to admit Exhibit No. 24.

13 MR. MESEREAU: No objection.

14 THE COURT: It’s admitted.

15 MR. ZONEN: May I publish No. 24, Your

16 Honor?

17 THE COURT: Yes.

18 Q. BY MR. ZONEN: Miss Arvizo, if you could

19 face the screen and tell us if that’s, in fact,

20 Asaf.

21 A. That’s Asaf.

22 Q. Did Asaf tell you who he was?

23 A. Michael’s security.

24 Q. Did you have a conversation with Asaf at

25 some point that morning before the arrival of the

26 workers from the Department of Child & Family

27 Services?

28 A. Yes. 6166



1 Q. And did he give you any particular

2 instructions?

3 A. Yes. To play -- he was verifying that I was

4 going to play the vid -- the DVD. He told me that

5 if I put Michael in a bad light, that they know

6 where my parents live. He wanted to hear the

7 allegations read in front of him.

8 Let me see. What else?

9 He was verifying that I would do -- carry

10 out Carrie -- Vicky’s instructions and Frank’s

11 instructions.

12 Q. All right. You mentioned a DVD, play a DVD.

13 A. Yes.

14 Q. What was that?

15 A. That’s of Michael and Gavin.

16 Q. Had you ever seen that DVD before?

17 A. No. Prior to the Miami, never.

18 Q. Did you know that that DVD had actually been

19 prepared?

20 A. No.

21 Q. All right. Did you see it for the first

22 time?

23 A. For the first time in Miami.

24 Q. You saw it in Miami.

25 A. Yes.

26 Q. So they showed it to you there?

27 A. Yes.

28 Q. What was the circumstance of their showing 6167



1 you that DVD in Miami?

2 A. I don’t know. I don’t know.

3 Q. Well --

4 A. Evvy -- Evvy had given it to Gary, and Gary

5 had given it to Gavin while we were still at Chris’s

6 house.

7 Q. All right. And did they give any

8 instructions at that time as to what to do with it?

9 A. No, none.

10 Q. Now, that DVD then went to Miami?

11 A. Yes.

12 Q. And you saw it for the first time in Miami?

13 A. I saw it, like, complete in Miami, but a

14 little bit at Chris’s house.

15 Q. Explain to us the content of that DVD.

16 A. It’s of my son when he’s barely being ill,

17 and Michael and Star.

18 Q. The two of them walking together?

19 A. Yes.

20 Q. Is Star in it on occasion?

21 A. Yes. Star’s in there for a little bit.

22 Q. Now, did you keep that DVD from Miami?

23 A. Yes, I did.

24 Q. And did you have it in your possession?

25 A. Yes, I did.

26 Q. All right. Now, on the occasion of the

27 visit from the Department of Child & Family

28 Services, did you play that DVD to them? 6168



1 A. Yes, I did.

2 Q. Whose idea was it to do that?

3 A. Asaf, but he was verifying with Frank and

4 Vicky had gave me instructions to do. But mostly

5 Frank.

6 Q. But you had that DVD in your possession?

7 A. Yes, I did. And this is as best as I can

8 remember.

9 Q. That’s okay.

10 Did somebody give you a tape-recorder during

11 this interview?

12 A. Oh, yeah.

13 Q. Who was that?

14 A. Asaf. But I didn’t know that he had a

15 tape-recorder until after.

16 Q. Well, tell me what the circumstances were

17 with the tape-recorder. What happened with that?

18 A. Okay. When Asaf found out he was being

19 kicked out, that’s when he told me, “Can I talk to

20 you for a second?”

21 And he pulled me into Jay’s bedroom. And

22 then he gave me -- he gave me instructions, but it

23 was already on, it was already working. What I was

24 trying to find out was that I didn’t have to push

25 anything because it was already working. He gave me

26 instructions about to, “Take her here. Talk to her

27 here. Leave it here.”

28 And you could also hear in there that that 6169



1 period of week was very stressful for me, because

2 Karen had also -- they -- the CPS knew that I was --

3 Q. Let’s back up a little bit now.

4 A. Okay.

5 Q. Before Asaf talked to you about a

6 tape-recorder --

7 A. Uh-huh.

8 Q. -- did you have a discussion with anybody

9 among the Department of Child and Family Care

10 Services about having other people present during

11 this interview?

12 A. Yes, and I was referring that to Aja.

13 Q. Who did you ask to have present in the

14 interview?

15 A. Aja.

16 Q. Did you ask to have Asaf present?

17 A. No. Only Aja. I trust Aja.

18 Q. Did Asaf ask you to ask them to allow him to

19 remain?

20 A. Yes.

21 Q. Did you ask them to allow Asaf to remain?

22 A. No. I was -- hopefully I was -- I was

23 hoping that the CPS would make that call so Asaf

24 wouldn’t hear it come from my mouth. So I was

25 referring to Aja, but I had to, per Asaf’s order.

26 Q. Did you know that there was a tape-recorder

27 in the room at the time --

28 A. No. 6170



1 Q. Hold on. Hold on. Listen to the question.

2 Did you know that there was a tape-recorder

3 in the room prior to your discussion with the social

4 workers about who would be present during the

5 interview?

6 A. No.

7 Q. At some point in time, did somebody tell you

8 from the social workers who would be allowed to be

9 present during the interview?

10 A. Yes.

11 Q. All right. And what was that resolution?

12 Who was allowed to be present?

13 A. Just me and the children.

14 Q. Not Aja?

15 A. Not Aja.

16 Q. Not Asaf?

17 A. Not Asaf and not the baby.

18 Q. All right. Tell us when it was that Asaf

19 then had a conversation with you about a

20 tape-recorder.

21 A. When -- after that.

22 Q. All right. Now, what exactly did Asaf say

23 to you? What did he do?

24 A. “Can I talk to you for a second?” And told

25 me that -- told me that it was working, that I

26 didn’t have to push anything. Told me to talk --

27 to, you know, in the room, “Leave it here. Talk to

28 her here. Take it here.” 6171



1 And you could also hear in there when I

2 was -- I got very scared when I thought the DVD of

3 Gavin and Michael were missing. Because that was

4 one of the orders that I had to do.

5 Q. Did he then hand you a tape-recorder?

6 A. Yes, he did, after he said, “Can I talk to

7 you for a second?”

8 Q. Now, what did you do with this

9 tape-recorder?

10 A. He put it on the desk. And I just went

11 ahead like -- that was -- I just played along with

12 him, “Yeah, yeah, sure, uh-huh.” You know,

13 basically that kind of behavior.

14 Q. What was your intent --

15 A. But I didn’t say those words. My

16 behavior -- that was my behavior.

17 Q. At the time that he gave you the

18 tape-recorder, what did he ask you to do with it, in

19 terms of where to keep it, where to place it?

20 A. He placed it on the desk area.

21 Q. Okay.

22 A. Just to, “Leave it here. Talk to her here.

23 Take her here.” Because Karen had said she was

24 going to talk to each one of us individually, so he

25 assumed that it was going to be in the bedroom.

26 And he also -- you know.

27 Q. “Karen” being one of the social workers?

28 A. Yes, Karen was the supervisor. 6172



1 Q. Do you know her last name?

2 A. Karen Walker.

3 Q. Did you have any concerns about the

4 tape-recorder?

5 A. Yes.

6 Q. What were your concerns?

7 A. That these people are going to be illegally

8 taped.

9 Q. Did you think there was an illegality

10 problem?

11 A. Yes, because she had just said, “This is

12 confidential.”

13 Q. All right.

14 A. And I wasn’t aware at that time that he had

15 the tape-recorder.

16 Q. All right. Now, did everybody finally leave

17 the room, in terms of Aja and Asaf?

18 A. Okay. Asaf didn’t leave until I had came

19 out of the rest room. I thought he had already -- I

20 thought he had already gone. So you could even hear

21 me on the tape-recorder, because I was going to tell

22 the lady there -- I figured he had already gone. So

23 I -- I started telling her, because the lady -- one

24 of the women had pulled me -- well, not pulled me,

25 was talking to me also in the area where the

26 tape-recorder was. And so I’m -- I was going to

27 start to tell her, and then there’s Asaf right

28 there. And I just -- you can hear my -- my voice. 6173



1 Q. Okay. Did Asaf tell you anything about any

2 other tape-recorders?

3 A. Yes.

4 Q. What did he say?

5 A. After I turned it off, came out of the rest

6 room, and then he was still -- Jay’s apartment, it

7 was very long. It was like an apartment house, but

8 it’s only one bedroom.

9 So he was in a distance where a wall was

10 covering, but he can hear.

11 Q. Who’s “he”?

12 A. Asaf. Asaf can hear.

13 And so that’s when he called me over. And

14 at this point he told me that there’s another one in

15 the room. So I didn’t know whether it was a

16 tape-recorder or a monitoring device. I didn’t know

17 what it was. But there was certainly another one in

18 the room.

19 Q. When the interview finally began, who was

20 present in the interview room?

21 A. When -- the three ladies, me and my

22 children.

23 Q. And were all of you interviewed together?

24 A. Yes.

25 Q. At any time did they separate you from the

26 children or each of the children from each other?

27 A. No. No. I carried out Vicky’s

28 instructions. 6174



1 Q. And what were those instructions?

2 A. Not to let the children be separated,

3 interviewed separately. Ask what are my rights,

4 what are the children’s rights. Have the

5 allegations read before -- before the meeting.

6 Just, you know, different things like that.

7 Q. Did you play or record the entire

8 conversation?

9 A. Me?

10 Q. Yes.

11 A. No, I turned it off.

12 Q. You turned it off when?

13 A. I turned it off when I thought he had

14 already gone, and he was there.

15 Q. Why did you turn it off?

16 A. Because it’s illegal to tape people without

17 them knowing.

18 Q. At some subsequent time, did you have an

19 opportunity to listen to a recording that you

20 believed to be that recording?

21 A. There?

22 Q. Let me try that one more time.

23 A. Okay.

24 Q. At some later time --

25 A. Yes.

26 Q. -- sometime after the meeting --

27 A. Yes.

28 Q. -- did you have an opportunity to listen to 6175



1 a tape-recording?

2 A. Yes. At the grand jury, the D.A.’s Office,

3 right before the grand jury, I was like -- it was

4 like hours before, hours. And they only had two

5 minutes -- about two minutes’ worth of that DCFS

6 tape. And I told them, you know, “There’s more.

7 There’s more to this tape.”

8 So he -- so the D.A.’s Office had -- had me

9 explain to them how much more there was. And I

10 said, “Because that’s not all of it. There’s still

11 more.”

12 Q. All right.

13 A. I was monitored continuously by those

14 people.

15 Q. The first tape that you listened to at the

16 time of the grand jury was a tape from what?

17 A. From a -- I don’t know whether it’s a media

18 report, area, I don’t know what you properly call

19 the show. Abrams Report.

20 Q. Television?

21 A. Yes.

22 Q. Something that had played on television?

23 A. Yes. Yes.

24 Q. And after having listened to that, what was

25 your view of whether or not that was the entirety of

26 the conversation?

27 A. That was not its entirety.

28 Q. Since then, have you had an opportunity to 6176



1 listen to another tape?

2 A. Yes.

3 Q. What is your opinion about that other tape?

4 A. This one is accurate.

5 Q. Up until the point where you turned it off?

6 A. Yes.

7 Q. Okay. Well, through the time, the entirety

8 of the tape?

9 A. Yes. And he turned it on when the CPS

10 people arrived. Not prior.

11 Q. Okay. Can you make out the different voices

12 in this tape?

13 A. Yes, I can.

14 Q. And how many different voices are there in

15 this tape?

16 A. The three ladies from Child Protective

17 Services. Aja. And my three children. You kind of

18 can hear the baby a little bit. That’s their --

19 he’s a toddler. And you can hear Asaf. You can

20 hear him say he’s Michael’s security.

21 Q. And during the course of that time, did you

22 play the video that they had asked you to play?

23 A. Yes, I did. And I got scared, because I

24 thought -- I thought it went missing. I thought I

25 misplaced it, so I got really scared because that

26 was one of the instructions.

27 Q. All right. Now, did you say positive things

28 about Michael Jackson? 6177



1 A. Yeah, I had to. At this point now, it’s

2 a -- now it’s a have-to. Because everything’s

3 evolving. And he had said that -- to put Michael --

4 don’t say anything that would put Michael in a bad

5 light, because they knew where my parents lived, he

6 knew where my parents lived. And this is prior to

7 the tape-recording.

8 Q. Miss Arvizo, did you know why Child

9 Protective Services were at your house, those social

10 workers?

11 A. No, I did not know why. And they didn’t

12 even want to tell me on the phone when I was trying

13 to talk to them.

14 Q. At some point in time after they arrived,

15 did they explain why they were there?

16 A. They didn’t explain it until I was alone

17 with the children.

18 Q. Did Miss Poderevski, in her conversation

19 with you, tell you why, her opinion, they were

20 there?

21 A. No. She just told me to -- to basically

22 drive it home for him being a good father.

23 MR. ZONEN: Thank you. We’re going to play

24 it at this time.

25 Your Honor, we have marked for

26 identification a CD, a tape-recording, No. 810,

27 8-1-0, and we would like to play that at this time.

28 THE COURT: Do you have a transcript of 6178



1 that?

2 MR. ZONEN: We do. And we’ll -- I have it

3 here, but we’ll have a copy for the Court before the

4 session is over today, along with the one from

5 yesterday that I promised you.

6 THE COURT: How long is the tape?

7 MR. ZONEN: I’m sorry?

8 THE COURT: How long is it?

9 MR. AUCHINCLOSS: 19 minutes.

10 MR. ZONEN: 19 minutes, Your Honor.

11 May we begin?

12 THE COURT: Yes.

13 THE WITNESS: And this is all the best that

14 I can remember.

15 (Whereupon, a portion of a CD, Plaintiff’s

16 Exhibit No. 810, was played for the Court and jury.)

17 MR ZONEN: We’re pausing it a moment.

18 Q. Miss Arvizo, what is the music that we’re

19 hearing right now?

20 A. That is from the DVD, the background music

21 to the DVD that Michael and Gavin were in, and a

22 little bit of Star was in there.

23 Q. This goes for approximately what, six

24 minutes?

25 A. I think so.

26 MR. ZONEN: All right. Let’s go ahead.

27 (Whereupon, a portion of a CD, Plaintiff’s

28 Exhibit No. 810, was played for the Court and jury.) 6179



1 MR. ZONEN: We’re stopping the tape

2 momentarily.

3 Q. Miss Arvizo, can you tell us what that sound

4 was that we were hearing just prior to stopping this

5 tape; do you know?

6 A. No, I don’t know. I don’t know.

7 Q. Do you have a recollection of that sound

8 from the time of this event itself?

9 A. No, I don’t. But it sounds like tape. But

10 I don’t know.

11 Q. Was that taped to you at any time?

12 A. No.

13 Q. Were you able to see the tape-recorder prior

14 to him giving it to you, before he gave it to you?

15 A. Yes.

16 Q. Where was it?

17 A. The best I can remember, he took something

18 out of his pocket, so I don’t know.

19 Q. Do you remember what he was wearing at the

20 time?

21 A. Yeah.

22 Q. We’re talking about Asaf, right?

23 A. Blue shirt.

24 Q. He had a shirt?

25 A. Blue shirt, long-sleeved, collar.

26 Q. Did he have a jacket on at all?

27 A. No, just a blue shirt.

28 Q. And prior to him taking it out, did you see 6180



1 that tape-recorder?

2 A. No. So I don’t know if he -- you know,

3 where.

4 Q. There was a single man’s voice, a deep

5 voice, that came on just before we turned off the

6 tape.

7 A. Yes.

8 Q. Who was that?

9 A. Asaf.

10 Q. Was he the only male in that room at that

11 time?

12 A. He was the only male. And plus my two boys

13 and plus the toddler, Aja’s baby.

14 Q. He was the only adult male in the room at

15 the time?

16 A. Yes, he was the only adult male.

17 MR. ZONEN: Let’s go ahead and resume.

18 (Whereupon, a portion of a CD, Plaintiff’s

19 Exhibit No. 810, was played for the Court and jury.)

20 Q. BY MR. ZONEN: Miss Arvizo, the tape just

21 ended?

22 A. Yes.

23 Q. How did it end?

24 A. I turned it off.

25 Q. We heard some rustling sound within the last

26 couple of minutes before it ended.

27 A. I was trying to figure out -- it was like

28 some very high-tech thing, and I couldn’t figure out 6181



1 where the “off” was. And I -- I tried my best. And

2 so I -- that -- and even when I turned it off, I was

3 unsure that I had turned it off. So what I did, I

4 put it inside a closet and I put two towels

5 completely covering it.

6 Q. In what room were you at the time you did

7 that?

8 A. In the bedroom.

9 Q. All right. And where were the workers at

10 this time?

11 A. They were in the -- okay. Like I said,

12 Jay’s apartment was -- even though it’s a

13 one-bedroom apartment, they call it apartment

14 houses. It’s long.

15 So they were way over there in the living

16 room. And that’s when -- afterwards Asaf was still

17 in there. He was there present with the CPS people.

18 Q. All right. At the time that you turned off

19 the tape-recorder, were the CPS workers in the same

20 room with you?

21 A. Me? No.

22 Q. Did you have to move the tape-recorder to a

23 different room before you turned it off?

24 A. No, it was all within the bedroom.

25 Q. And was the interview going to be held in

26 the living room or in the bedroom?

27 A. Asaf had assumed that it was going to be in

28 the bedroom, and they said to, “Take her here. Talk 6182



1 to her here. Leave it here.”

2 Q. So at one point prior to this, you asked to

3 go to the rest room; is that correct?

4 A. Yes.

5 Q. Did you actually go to the rest room?

6 A. No, I was just pretending I was in there.

7 Q. And the purpose for that was what?

8 A. So -- to create some -- some -- so I can

9 have some privacy so I could turn off the tape.

10 Q. That is what you wanted to do?

11 A. That’s what I wanted.

12 Q. Now, in the course of this interview, they

13 represented that this was going to be a completely

14 confidential interview; is that right?

15 A. Yes.

16 Q. And that none of these records or documents

17 would become public; is that correct?

18 A. Exactly.

19 Q. And, in fact, what did happen with these

20 documents?

21 A. All this stuff got leaked.

22 MR. MESEREAU: Objection; foundation.

23 THE WITNESS: All of it.

24 THE COURT: Sustained.

25 MR. ZONEN: I’ll lay the foundation.

26 Q. Did you see any of these records in the

27 public forum at some subsequent time?

28 A. Yes. Every single sheet of paper that was 6183



1 ever created from my children, about my children or

2 me from the DCFS people, was all over.

3 Q. All over where?

4 A. All over the world.

5 Q. On television?

6 A. On television. Internet. Every single

7 place.

8 Q. How long after this interview was it that

9 that happened?

10 A. Right after he was arrested.

11 Q. “He” being Mr. Jackson?

12 A. Michael. Mr. Jackson.

13 Q. How long did this interview go on after you

14 turned off the tape-recording?

15 A. After I had turned off -- I used the rest

16 room. Turned off the tape-recorder. And then I got

17 extremely frightened, because I saw him still there

18 with the CPS people. And that’s when he called me

19 over.

20 And I went over there, the separate area out

21 of the bedroom, and that’s when he had told me that

22 he had placed another one -- the ladies are still

23 distracted with my kids. And so that’s when he had

24 talked to me and told me about that there was

25 another one there. And I’m like, “Where?” I had

26 been in the rest room. “Where.”

27 Q. Did he tell you?

28 A. No, he didn’t tell me where this one was at. 6184



1 Q. Did he tell you whether it was open or

2 hidden? Did he say anything about it?

3 A. No.

4 Q. Do you know whether or not there was a

5 second one in that room?

6 A. No, I don’t know.

7 Q. To this day you don’t?

8 A. To this day I don’t know.

9 Q. Did Asaf finally leave and go outside?

10 A. Yes.

11 Q. Did Aja go outside?

12 A. Aja had left almost immediately. Aja and

13 the baby.

14 Q. In what room did the interview finally take

15 place?

16 A. It took place in the -- okay, the dining and

17 the living room, it’s combined. But it just looks

18 like, you know --

19 Q. There is some conversation with you and the

20 social worker that’s on this tape; is that correct?

21 A. Yes.

22 Q. All right. Where did this conversation take

23 place? Where was the tape-recorder during that

24 conversation?

25 A. In the bedroom.

26 Q. So they were with you initially in the

27 bedroom?

28 A. No, no, no. I’m sorry, I’m thinking about 6185



1 when the lady was talking to me by myself.

2 Q. Yes.

3 A. And I tried to tell her, and that’s when

4 Asaf popped up.

5 Q. Yes.

6 A. That part, when there’s one person talking

7 to me is -- towards the end is in Jay’s bedroom.

8 Q. And that person came into the bedroom with

9 you?

10 A. Yes, she came into the bedroom.

11 Q. Do you know who that person was, what her

12 name was?

13 A. I don’t remember her name, but I can -- I

14 can tell you who -- who it is by the description.

15 Q. By the description?

16 A. Yes, I can.

17 Q. There were how many social workers there at

18 the time?

19 A. Three.

20 Q. Did one appear to be a supervisor to you?

21 A. Yes, she -- Karen Walker.

22 Q. And the person who had the conversation with

23 you that is picked up, was that Karen Walker or one

24 of the others?

25 A. You could pick up Karen Walker in the

26 beginning. But this one was not Karen Walker in the

27 bedroom.

28 Q. All right. To the extent that this 6186



1 tape-recording goes on for approximately 19 minutes,

2 does this tape-recording accurately capture the

3 conversations?

4 A. Yes. And Asaf began taping when the CPS

5 women walked in.

6 MR. ZONEN: Your Honor, we would move to

7 introduce into evidence Exhibit No. 810 with the

8 representation that the transcript will be furnished

9 within the day.

10 MR. MESEREAU: No objection.

11 THE COURT: It’s admitted.

12 Q. BY MR. ZONEN: How long did that interview

13 go on with Child Protective Services or Department

14 of Child Family Services?

15 A. Yeah, I couldn’t tell you, Mr. Zonen.

16 Q. At -- presumably this conversation ended at

17 some point in time, did it not?

18 A. Yes.

19 Q. Did they make any representations to you,

20 “they” being any of the social workers?

21 A. The three women?

22 Q. Yes.

23 A. They were just concerned about Mr. Jackson.

24 They just didn’t want to be sued by Michael Jackson.

25 They had not a single sheet of paper in front of

26 them. They didn’t even take a single piece of note

27 from me or my children.

28 Q. Do you know if they tape-recorded the 6187



1 conversation?

2 A. No, I don’t know.

3 Q. You didn’t see a tape-recording?

4 A. I didn’t see anything.

5 Q. They didn’t tell you they were

6 tape-recording?

7 A. They didn’t tell me.

8 Q. None of them had notes that they were

9 taking?

10 A. None of them had a single sheet of pad,

11 notepad, pencil, pen, pulled out. All they kept

12 telling me was that they didn’t want to be sued by

13 Michael Jackson, over and over.

14 Remember I told you there was a difference

15 of people? The one that had been brought out way,

16 way -- her sole concern was my children. But in

17 these, their sole concern was Michael Jackson.

18 Q. Did they ask any questions of your children

19 in your presence?

20 A. Yes, they did.

21 Q. Did they ask them if anything had happened

22 to them when they were at Neverland?

23 A. Not really.

24 Q. What did they ask them?

25 A. It was just -- it was more of a -- of a pep

26 talk.

27 Q. What did your children say to them in their

28 presence? 6188



1 A. They basically said happy things about

2 Michael. And them being together.

3 Q. And did you do the same?

4 A. Yes, I did.

5 Q. Did you tell them that he was a father

6 figure to your children?

7 A. Yes, I did. Almost identical to the

8 scripted video. But not as long. It was kind of

9 like -- it was extremely short.

10 Q. All right. Presumably they left at some

11 time after?

12 A. Yes.

13 Q. Who was still present among the ones that

14 you’ve previously identified after the social

15 workers left?

16 A. Aja, the baby, Asaf, me, the children, then

17 Vinnie was there now. After the CPS women walked

18 out.

19 Q. Excuse me. Did Asaf talk to you after the

20 social workers left?

21 A. Yes. He was making sure that me and Aja had

22 no private time. And he had told me, “Hold on.

23 Vinnie wants to tell you something.” And he

24 escorted Aja and the kids out to Aja’s car.

25 Q. Now, did Asaf in your presence retrieve the

26 tape-recorder?

27 A. I think -- I remember him walking into the

28 bedroom, but that’s the -- because what happened was 6189



1 when -- after -- when the CPS women came, I ran into

2 the bedroom and I put it back in the same place that

3 he had placed it.

4 Q. All right. And did he then retrieve it?

5 A. Yes.

6 Q. And he retrieved it from the same place?

7 A. From the same place.

8 Q. All right. Did he make any effort to listen

9 to it in your presence?

10 A. No.

11 Q. Did you tell him that you had stopped it?

12 A. No.

13 Q. Or attempted to stop it?

14 A. I -- yeah, I tried and -- but I did end up

15 turning it off. Because I was pushing.

16 Q. Did he say anything to you at all about

17 whether or not this tape had run the entire time?

18 Did he make any inquiries of you?

19 A. No.

20 Q. Did you have any conversation with Asaf at

21 all following the moment when the social workers

22 left?

23 A. Well, Vinnie was there now. And he told me

24 that Vinnie had -- that Vinnie had to talk to me.

25 Q. All right.

26 A. While he escorted Aja and the children out

27 to Aja’s car.

28 Q. So there was no additional conversation? 6190



1 A. No additional conversation. This is the

2 best I can remember.

3 Q. With Asaf?

4 A. With Asaf. He told me that Vinnie had

5 something to tell me.

6 Q. Did you then talk with Vinnie at that point?

7 A. Yes.

8 Q. What did Vinnie say to you?

9 A. That I had done -- that I had not done an

10 adequate job on the video, and we were going to have

11 to proceed with leaving out of the country.

12 Q. Is this the first time that anybody talked

13 to you about your performance or the performance of

14 the children in the rebuttal video?

15 A. Yes, it was Vinnie.

16 Q. And he said it wasn’t adequate?

17 A. That’s right.

18 Q. Did he give you any specifics as to what was

19 not adequate in this interview?

20 A. Yeah, that I -- I was supposed to stick

21 strictly to the script. I went out of -- the things

22 I got in trouble for, because of God, the Child

23 Welfare Services thing, and Gavin’s cancer.

24 Q. All right. Now, we have seen this video a

25 couple times already.

26 A. Okay.

27 Q. Let’s go back. These are things that Vinnie

28 specifically told you? 6191



1 A. Yes.

2 Q. Let’s start with the first one. What did he

3 say about references to God?

4 A. Okay. I was supposed to say that Michael

5 healed Gavin.

6 Q. And did you not say that?

7 A. I did not say it exactly like they wanted me

8 to. Instead I said -- Dieter had also presented to

9 me to say, “Via God’s Grace,” because I was so, “No,

10 it’s God who healed Gavin, not Michael healed Gavin.

11 God did.” And so then I was supposed to say that

12 sentence plus that, them.

13 Q. And what did he say about the other two

14 issues that you had mentioned?

15 A. That I was supposed to make no issue -- see,

16 the whole video, plus the outtakes, was also

17 scripted. It wasn’t -- it wasn’t -- it was the --

18 the whole thing, from outtakes, to video filming, to

19 everything, every single thing was part of the

20 choreography.

21 Q. What did he say to you specifically, Vinnie?

22 What did he say to you about the other two issues

23 that you mentioned?

24 A. Well, I didn’t say about Gavin’s cancer,

25 that’s why they repeatedly -- I wasn’t on target

26 about that, what they wanted.

27 Q. What did he want you to say more about

28 Gavin’s cancer? 6192



1 A. Well, how they had scripted it.

2 Q. How was that? How was it different than

3 what you actually said?

4 A. Well --

5 Q. Do you recall?

6 A. The best I can remember is that I said

7 Gavin -- about -- I totally was not on script about

8 Gavin’s cancer. I said from my heart.

9 Q. All right. And what was the third thing?

10 A. The Child Welfare Services, I was supposed

11 to make no commentary about that at all. Zero.

12 Q. And you did?

13 A. And I did.

14 Q. Now, where did everybody go after this took

15 place and the social workers were gone? Where did

16 the kids end up going at that point?

17 A. Okay. The kids and Aja went to Neverland,

18 and they were also being followed, and Aja don’t

19 know she’s being followed.

20 Q. Just tell us where they went. They went

21 back to Neverland?

22 A. Yes, they went to Neverland.

23 Q. Did they get any sleep that night at all?

24 A. The children?

25 Q. Yeah.

26 A. They must have slept about one hour. About

27 one hour.

28 Q. Where? 6193



1 A. At Jay’s.

2 Q. At Jay’s house before the workers got there?

3 A. Before the workers got there. And me?

4 Zero.

5 Q. Did you have to wake them up?

6 A. Yes, I did.

7 MR. ZONEN: Excuse me.

8 Your Honor, I’d like to approach the

9 witness, if I can, to show a couple of exhibits

10 already shown to counsel, defense counsel.

11 THE COURT: All right.

12 MR. ZONEN: Before I do that, I need a

13 stapler.

14 Q. I’d like to show you Exhibit No. 811. And

15 then I’m going to show you 812. Let’s start with

16 811 here.

17 A. Okay.

18 Q. 811 is a collection of four pieces of paper

19 stapled together; is that correct?

20 A. Yes.

21 Q. Have you ever seen any of those documents

22 before?

23 A. Yes.

24 Q. All right. Tell us what those documents

25 are.

26 A. This is when we got off the car at Hamid’s

27 house, Vinnie had told me that I had to sign these

28 releases. And this was part of it. 6194



1 Q. Now, are these the releases, in fact, that

2 were given to you?

3 A. Yes.

4 Q. And did you, in fact, sign that release?

5 A. Yes, I did.

6 Q. And why did you do that?

7 A. Because this is all part of what they

8 requested.

9 Q. All right.

10 A. In order -- in order for us not to leave the

11 country and for my children to be let go and not

12 have to deal with this anymore.

13 Q. Did you consult with an attorney before

14 signing that release?

15 A. No.

16 Q. Did you have any discussions with Vicky

17 Poderevski about that release?

18 A. No.

19 Q. Was there any other attorney that was

20 brought to the -- to the -- to the house to --

21 A. No.

22 Q. Did you ever talk with Mark Geragos about

23 that release?

24 A. No. I’ve never even spoke to Mark Geragos.

25 Q. Never had any conversation?

26 A. Zero conversation.

27 Q. Did you ever meet Mark Geragos?

28 A. Never. 6195



1 Q. Did you have some discussion with either

2 Vinnie or anybody else there about the nature of

3 that release before signing it?

4 A. No.

5 Q. I’d like you to look at the next exhibit

6 that’s -- incidentally, before you turn back,

7 there’s four pages there.

8 A. Yes.

9 Q. Tell us how each of those pages differ from

10 one another.

11 A. I -- I don’t understand your question.

12 Q. All right. Is the -- are the signatures the

13 same on each one?

14 A. Of -- no. They’re all different, except

15 Vinnie’s. Vinnie’s is the same on all of them.

16 Q. And whose are the other signatures? Is one

17 of the signatures yours?

18 A. My three children and myself.

19 Q. Do you have a recollection of your three

20 children actually signing those releases?

21 A. Yes, I do.

22 Q. Were you present at the time?

23 A. Yes, I was.

24 Q. Was anything explained to them at the time

25 they signed it?

26 A. No.

27 Q. Did you encourage them to sign it?

28 A. No. 6196



1 Q. Who was it who presented the releases to

2 them?

3 A. Vinnie.

4 Q. And, in fact, Vinnie’s signature is on each

5 of them as well?

6 A. Yes.

7 Q. All right. Do you recall if any of your

8 children asked any questions about those releases

9 before signing them?

10 A. They didn’t.

11 Q. Did anybody talk to you about whether or not

12 releases signed by a child would be legally binding?

13 A. I’m sorry?

14 Q. Did anybody talk to you about the question

15 of whether or not releases that are signed by a

16 child -- wait till the question is asked.

17 A. Okay.

18 Q. That releases signed by a child would be

19 legally binding? Did that discussion come up at all

20 with Vinnie?

21 A. No.

22 Q. Or with anybody else?

23 A. No.

24 THE COURT: All right. We’ll take our break.

25 (Recess taken.)

26 --o0o--

27

28 6197



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 6144 through 6197

16 contain a true and correct transcript of the

17 proceedings had in the within and above-entitled

18 matter as by me taken down in shorthand writing at

19 said proceedings on April 14, 2005, and thereafter

20 reduced to typewriting by computer-aided

21 transcription under my direction.

22 DATED: Santa Maria, California,

23 April 14, 2005.

24

25

26

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

28 6198



1 SUPERIOR COURT OF THE STATE OF CALIFORNIA

2 IN AND FOR THE COUNTY OF SANTA BARBARA

3 SANTA MARIA BRANCH; COOK STREET DIVISION

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

5

6

7 THE PEOPLE OF THE STATE OF )

8 CALIFORNIA, )

9 Plaintiff, )

10 -vs- ) No. 1133603

11 MICHAEL JOE JACKSON, )

12 Defendant. )

13

14

15

16

17 REPORTER’S TRANSCRIPT OF PROCEEDINGS

18

19 THURSDAY, APRIL 14, 2005

20

21 8:30 A.M.

22

23 (PAGES 6199 THROUGH 6374)

24

25

26

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

28 BY: Official Court Reporter 6199



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 6200



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 JACKSON, Janet 6345-Z (Resumed)

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 6201



1 E X H I B I T S

2 FOR IN

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

4 259 Brazilian trip records,

5 applications for birth certificates 6218 6220

6 271 Gavin Arvizo’s school

7 checkout records; driver’s licenses 6286 6293

8 272 Star Arvizo’s school checkout

9 records 6291 6293

10 276 Rental documents 6277 6293

11 277 Handwritten note 6331 6331

12 806 Birth certificates and passports 6237 6238

13 811 Releases given to Janet

14 Arvizo for signature 6194 6203

15 812 Unsigned releases given to Janet Arvizo for signature 6194 6210

16 813 DVD - Compilation of

17 surveillance tapes 6335

18 814 Copy of Exhibit #812 with Vinnie’s writing on back 6211

19

20

21

22

23

24

25

26

27

28 6202



1 THE COURT: All right. Counsel?

2 MR. ZONEN: Thank you, Your Honor.

3 Q. We were looking at Exhibit 811, which I

4 think you still have in front of you.

5 A. Yes.

6 Q. All right. And are those accurate copies --

7 THE BAILIFF: Oh, microphone, please.

8 Q. BY MR. ZONEN: We were looking initially at

9 811. Those are the four documents that are stapled

10 together. And you’ve already testified as to what

11 they were --

12 A. Yes.

13 Q. -- and when they were signed.

14 Are those accurate duplicates of the

15 documents signed that evening by you and your three

16 children?

17 A. Yes.

18 MR. ZONEN: And, Your Honor, I would move to

19 introduce 811 into evidence.

20 MR. MESEREAU: No objection.

21 THE COURT: It’s admitted.

22 Q. BY MR. ZONEN: Now, prior to your signing it

23 or even subsequent to your signing it, was there any

24 subsequent conversation with Vinnie or anybody else

25 about money that would be received?

26 A. No.

27 Q. Did you discuss with an attorney anything

28 about money? 6203



1 A. No.

2 Q. Did they offer you money?

3 A. No.

4 Q. Did you ask for money?

5 A. No.

6 Q. And I think that you had already said that

7 that was not part of the conversation that you had

8 with Vicky Podberesky.

9 A. Exactly.

10 Q. And did they offer you any other legal

11 assistance, anybody else to talk --

12 MR. MESEREAU: Object to the word “they” as

13 vague.

14 MR. ZONEN: I’ll withdraw the question.

15 Q. Did Vinnie tell you about any other lawyers

16 who might be available for you to discuss -- to talk

17 about this release?

18 A. No.

19 Q. Was there ever any representation by them

20 that they would pay you or your children for your

21 participation in this video?

22 A. No.

23 MR. MESEREAU: Objection to the word “them”

24 as vague.

25 MR. ZONEN: I’ll withdraw the question.

26 Q. Was there ever any representation by Vinnie

27 that you would be paid for your participation in

28 this video? 6204



1 A. No.

2 Q. Did you ever request of Vinnie that you be

3 paid for your participation in the video?

4 A. No.

5 Q. Did you ever have a discussion about being

6 paid for this video with any employee of Michael

7 Jackson?

8 A. No.

9 Q. Did you ever talk with Michael Jackson about

10 it?

11 A. No.

12 Q. Did you expect to be compensated for it?

13 A. No.

14 Q. Did you have a conversation prior to doing

15 this video with Jay Jackson about whether or not you

16 should be compensated for this video?

17 A. No.

18 Q. Did Jay Jackson have a conversation with you

19 where he reviewed the content of a conversation he

20 had with Frank?

21 A. No.

22 Q. Were you aware that he had had a

23 conversation with Frank about this video?

24 A. No.

25 Q. Now, I’d like you to look at the other

26 document that’s right in front of you. It’s No.

27 812. Have you seen that document before?

28 A. I’ve seen it per your investigation and over 6205



1 there at Neverland.

2 Q. Okay. When was the first time you saw that

3 document?

4 A. I think the best I remember was in

5 Neverland.

6 Q. And do you know who it was that showed that

7 document to you?

8 A. It was Frank and Vinnie.

9 Q. Was that before the video was done?

10 A. No.

11 Q. It was after the video was done?

12 A. Yes.

13 Q. Did somebody hand that to you and ask you to

14 sign it?

15 A. Yeah.

16 Q. All right. Who was that who handed it to

17 you?

18 A. By this time my signing days were over.

19 Q. Tell us when that was, approximately.

20 A. That was in Neverland after -- after the

21 Chris Carter thing.

22 Q. Okay. Now, the person -- I’m sorry, who was

23 it again who handed that to you?

24 A. Frank and Vinnie.

25 Q. Were they both together at the time?

26 A. Sometimes together.

27 Q. But on the first occasion that you saw this

28 document -- 6206



1 A. Frank.

2 Q. -- it was Frank?

3 Did you see that document on more than one

4 occasion?

5 A. Wait. Best I remember. It could have been

6 Vinnie. Vinnie or Frank. I don’t know.

7 Q. Take a moment. Take a moment.

8 A. Uh-huh. I think -- the best I can remember,

9 I think -- yeah, the best I can remember was Vinnie,

10 then Frank, then both. That’s the best I can

11 remember.

12 Q. Let’s start with Vinnie, whether he was

13 first or second. Do you remember what Vinnie

14 specifically said to you about that document?

15 A. “Sign here.”

16 Q. Did he explain what it was?

17 A. No.

18 Q. Did he explain what it was for?

19 A. No.

20 Q. Did he give you any detail at all about that

21 document or why he wanted you to sign it?

22 A. No.

23 Q. How about Frank? When he talked to you

24 individually, what did he say about that document?

25 A. Nothing. Just, “Sign it.”

26 Q. Do you remember when this was relative to

27 the video that you had already done?

28 A. After. 6207



1 Q. Do you know approximately how long after?

2 A. No, I wouldn’t be able to tell you.

3 Q. Okay. Did Frank give you any direction as

4 to why he wanted you to sign that document?

5 A. No.

6 Q. And when the two of them were together and

7 spoke to you about that document, did either one of

8 them, in the course of that conversation, say

9 anything to you about why they wanted you to sign

10 it?

11 A. No.

12 Q. All right. Now, the document that you have

13 in front of you --

14 A. Yes.

15 Q. -- has your name preprinted; is that

16 correct?

17 A. Uh --

18 Q. At the bottom of the page?

19 A. Oh, I see. Yeah. At the bottom.

20 Q. And was that how it was at the time that

21 they had handed it to you?

22 A. Yes.

23 Q. Did you, in fact, refuse to sign that

24 document?

25 A. Yes.

26 Q. You never did?

27 A. Huh-uh.

28 Q. In the course of your -- 6208



1 A. I got in trouble for that.

2 Q. -- discussions with either Vinnie or Frank

3 about your signing or not signing that document, did

4 you make a demand for money?

5 A. No.

6 Q. Did you ever ask them for money?

7 A. No.

8 Q. Did you tell them why you didn’t want to

9 sign the document?

10 A. Because my signing days were over. That’s

11 it.

12 Q. What does that mean?

13 A. They had me sign a bunch of different

14 things --

15 Q. Were there --

16 A. -- over the course of from Miami to this.

17 I’m talking in total. And that’s it. You know,

18 “Let me go. Let my kids go.” That’s all I wanted.

19 Q. All right. Ultimately you did not sign that

20 document?

21 A. No.

22 Q. Did you see if there were similar copies of

23 that document but with the names of your children?

24 A. Yes. Yes.

25 Q. Did they show them to your children at all?

26 A. I -- they may have. They may have. Because

27 they had a period of time when they were alone with

28 the children. 6209



1 Q. Do you know from personal knowledge? In

2 other words, did your children ever sign those

3 documents in your presence?

4 A. In my presence, never.

5 Q. All right. Do you have any information, one

6 way or the other, as to whether or not they

7 ultimately signed that release on 812?

8 A. I don’t know about this release.

9 Q. Okay. Is that, in fact, an accurate copy of

10 the release that was shown to you at Neverland?

11 A. Yes.

12 Q. Were you shown that release on more than one

13 occasion?

14 A. Yes.

15 Q. On how many separate occasions were you

16 shown that release?

17 A. I wouldn’t be able to tell you, Mr. Zonen.

18 Q. Can you give us a sense of it?

19 A. No.

20 Q. Okay. More than once?

21 A. Yes.

22 MR. ZONEN: Your Honor, I would move to

23 introduce 812 into evidence at this time.

24 MR. MESEREAU: No objection.

25 THE COURT: It’s admitted.

26 MR. ZONEN: Just one moment, Your Honor,

27 please.

28 (Off-the-record discussion held at counsel 6210



1 table.)

2 MR. ZONEN: May I approach the witness, Your

3 Honor?

4 THE COURT: Yes.

5 Q. BY MR. ZONEN: Miss Arvizo, I’m showing you

6 No. 814 for identification. No. 814 for

7 identification. I’d like to -- I’d like you to take

8 a look at this, please. Take a moment and look at

9 it.

10 A. Uh-huh. Okay.

11 Q. Is that a document you’ve seen before?

12 A. Yes.

13 Q. Where did you see that before?

14 A. I think I seen this in -- I think I seen

15 this in Neverland.

16 Q. Okay. Is that your handwriting?

17 A. No.

18 Q. Do you know whose handwriting it is?

19 A. This is Vinnie’s.

20 Q. Was that drafted in your presence?

21 A. I don’t think so.

22 Q. Turn the document over, if you would.

23 A. Oh, my God.

24 Q. Excuse me. Tell us what that is on the

25 other side of the document.

26 A. It’s the same one.

27 Q. In other words, it’s --

28 BAILIFF CORTEZ: Your microphone, sir. 6211



1 MR. ZONEN: Okay. We’re back on.

2 Q. I’ve now asked you to turn this document

3 over on the other side.

4 A. Yeah.

5 Q. And what is it on the other side?

6 A. It’s the same one.

7 Q. It’s the copy of exhibit number what?

8 A. Yes.

9 Q. I’m sorry, exhibit number what? Tell us

10 what exhibit that is. I think it’s 812. No?

11 A. Yes, 812.

12 Q. So the back side of the one that I just

13 showed you which has Vinnie’s handwriting --

14 A. Yes.

15 Q. -- is, in fact, a copy of 812?

16 A. Yes.

17 Q. Is it the one that has your name preprinted

18 or one of the kid’s?

19 A. It’s mine, preprinted.

20 Q. Did Vinnie ever show you that document, the

21 written one?

22 A. I don’t -- I can’t remember. I --

23 Q. Do you have a recollection of having seen it

24 at some point in time?

25 A. Yes, I think so. At Neverland.

26 Q. Did you ever sign a handwritten document?

27 A. A handwritten document?

28 Q. Yes. 6212



1 A. No.

2 Q. Is your signature on that document?

3 A. No, it isn’t.

4 Q. But your name is on it?

5 A. But my name is on it.

6 Q. Does that appear to be some form of a model

7 release?

8 A. It says, “This model release....”

9 Q. Was there ever a discussion between you and

10 Vinnie or you and Frank about coming up with some

11 kind of a release that was suitable for you?

12 A. No.

13 Q. The release that you’re holding in your hand

14 right now, the printed form on the back of that

15 page, that was presented to you before or after you

16 did the video rebuttal?

17 A. After.

18 Q. You can go ahead and put those down.

19 A. Okay.

20 Q. Miss Arvizo, 812 that I showed you

21 initially, the one that does not have something on

22 the back --

23 A. Okay.

24 Q. -- is that, in fact, an accurate copy of

25 the release that was given to you by both Vinnie and

26 Frank?

27 A. Yes.

28 MR. ZONEN: I’d move -- is 812 in evidence 6213



1 already?

2 THE COURT: Yes.

3 MR. ZONEN: It is in evidence. Okay. Never

4 mind.

5 MR. ZONEN: Tom, do you want to stipulate to

6 this coming in?

7 MR. MESEREAU: No.

8 MR. ZONEN: Then I’ll lay the foundation.

9 Excuse me.

10 Q. After the social workers left and your kids

11 went back to Neverland, where did you go on that

12 day?

13 A. Well, that began the process of getting the

14 passports and visas. The first step was getting the

15 birth certificates.

16 Q. All right. And did you, in fact, get birth

17 certificates that day?

18 A. On that day was the application. And when I

19 arrived there, I had to do -- they -- I had to write

20 a little kind of paragraph stating that it was an

21 emergency; that I had to get out -- something about

22 out of the country. I don’t recall, but they wanted

23 it fast enough.

24 Q. Did they say -- who is “they”?

25 A. Michael’s people.

26 Q. Well, somebody in particular had you write

27 something?

28 A. Vinnie. And Frank over the phone. Frank 6214



1 never left our side, whether he was on the phone or

2 in person.

3 Q. Vinnie asked you to write something that

4 stated it was an emergency?

5 A. Yes.

6 Q. Did he tell you what that was for?

7 A. Well, that’s what -- the information that he

8 had got, because he had asked the birth certificate

9 people that he needed it immediately. And they had

10 told him, “No, the only way we can do it, if there’s

11 an emergency.” And so he had told me that to write

12 it’s an emergency.

13 Q. Who was it who told you, “You’re going to

14 Brazil now”?

15 A. Frank, Vinnie.

16 Q. What did you tell them in response to

17 whether or not you wanted to go to Brazil?

18 A. They knew I didn’t want to go.

19 Q. Did you tell them that?

20 A. Yes, I did.

21 Q. Tell us why you didn’t want to go.

22 A. I didn’t want to go because first, first and

23 main reason, is Gavin’s doctor is here. He has to

24 see an oncologist and a nephrologist. He depends on

25 those doctors, first. And second, I waited a

26 lifetime to find someone I could give a valentine

27 to, and that was Jay.

28 Q. You didn’t want to leave that relationship? 6215



1 A. No, I didn’t.

2 Q. Did you tell this to either Vinnie or Frank?

3 A. Yes.

4 Q. What did they say?

5 A. Well, the part about no, no going to Brazil.

6 Not the part about Jay.

7 Q. Did you talk to either Vinnie or Frank about

8 medical issues?

9 A. Yes. I told him I couldn’t -- you know, I’m

10 trying to negotiate for mine and my children’s

11 freedom --

12 Q. Uh-huh.

13 A. -- by saying, you know, “Sorry, I can’t go,”

14 you know. “The doctors are here.”

15 And nope, still got to go.

16 Q. Okay. Why did you ultimately agree to go?

17 I mean, why not just say, “I’m not going”?

18 A. Because of my parents’ life, my -- and Jay’s

19 life.

20 Q. What does that mean, “your parents’ life”

21 and “Jay’s life”?

22 A. Well --

23 Q. What did that have to do with going to

24 Brazil?

25 A. That they were going to be killed.

26 Q. Who told you that?

27 A. Frank. Frank became the worst out of all of

28 them. 6216



1 Q. Did you have any additional conversations

2 with either Dieter or Ronald?

3 A. No, the Germans are out of the picture.

4 They’re no longer in the picture. Slowly -- there

5 was a transition period where Ronald and Dieter were

6 replaced by Frank and Vinnie. Frank and Vinnie took

7 the spots of Ronald and Dieter. The Germans are out

8 of the picture now.

9 Q. Did you tell them that you were going to go

10 to Brazil?

11 A. No.

12 Q. Did you start doing things toward going to

13 Brazil?

14 A. Yes.

15 Q. All right. And you started to mention

16 something about birth certificates.

17 A. Yes.

18 Q. Okay. Now, on this -- was it the same day

19 as the interview that you had with the department --

20 with the social workers that you went and started

21 gathering up materials?

22 A. Yes. Same day.

23 Q. What materials did you gather?

24 A. The only thing was the birth certificate

25 application. They -- they assumed that we were

26 going to get the application on the spot, and so --

27 MR. ZONEN: Counsel?

28 (Off-the-record discussion held at counsel 6217



1 table.)

2 MR. ZONEN: May I approach the witness, Your

3 Honor?

4 THE COURT: Yes.

5 MR. ZONEN: Did you want these separate from

6 the notebooks at the time we introduce them?

7 THE COURT: I’m sorry?

8 MR. ZONEN: I think I’ve made the decision

9 already. I’ll withdraw that question.

10 Q. I’m going to show you three items that are

11 part of one exhibit. We will ultimately staple it

12 together. At the moment it’s three separate pages.

13 And this exhibit number is No. 259. I’d

14 like you to look at the three different pages. Do

15 you know what this is?

16 A. Yes, this is an application for the birth

17 certificate.

18 Q. All right. And have you seen these

19 documents before?

20 A. Yeah. This is on -- when we did the

21 application thing, when we had a paper.

22 Q. At the time you actually got the

23 applications?

24 A. Yes, yes.

25 Q. And who were you with when you got those

26 applications?

27 A. Vinnie, and the people that were following

28 us. I always had a crew following us. 6218



1 Q. There were others in a separate car?

2 A. Yes.

3 Q. Do you know who was in the separate car?

4 A. No, I never knew. And that was the scary

5 part. Vinnie would always point them out to me.

6 Q. Go ahead and look at this document now,

7 which is No. 259.

8 A. Yes.

9 Q. And are those, in fact, applications for

10 each of you?

11 A. Yes.

12 Q. All right. Whose signature is on those

13 applications?

14 A. There’s no signature. Just printed.

15 Q. It’s just printed out?

16 A. Yes.

17 Q. Is any of that your handwriting?

18 A. Yes, it’s all my writing.

19 Q. And then each of the names are on here; is

20 that correct?

21 A. Yes.

22 Q. And each of the children’s names are on

23 here?

24 A. Yes.

25 Q. Are those, in fact, accurate copies of those

26 applications for birth certificates?

27 A. I feel they are.

28 Q. Do you remember where it was they were 6219



1 deposited?

2 A. In Norwalk. It’s by the 605 freeway.

3 Q. Okay. Now, the third document in

4 here titled “The Registrar Recorder” --

5 A. Yes.

6 Q. -- does have a signature on it, does it not?

7 A. Yes.

8 Q. And whose signature is that?

9 A. That’s mine. This is that emergency thing.

10 Q. All right. And that you recall signing?

11 A. Yes. Yes.

12 Q. And the date on it is what, now?

13 A. The date on it is February 20th, the day of

14 the CPS meeting. Afterwards.

15 MR. ZONEN: I would move to introduce into

16 evidence Item No. 259.

17 MR. MESEREAU: No objection.

18 THE COURT: It’s admitted.

19 MR. ZONEN: May I approach through here,

20 Your Honor?

21 THE COURT: Yes.

22 MR. ZONEN: If you would staple them

23 together as one exhibit.

24 THE COURT: When you previously marked that

25 exhibit, you meant it to have three pages when you

26 prepared your notebook?

27 MR. ZONEN: Yes.

28 Q. Miss Arvizo, I’m going to show you now 6220



1 Exhibit No. 2-6-0. No. 2-6-0. 11 pages, separate.

2 We will staple them together as one exhibit, No.

3 2-6-0.

4 I’d like you to turn through the pages of

5 that exhibit, please. And when you’ve gone through

6 each of the pages, let us know.

7 A. Read them?

8 Q. You don’t need to read it in its entirety.

9 A. Oh, okay.

10 Q. Just gain familiarity with them.

11 A. Okay.

12 Q. Have you seen these documents before?

13 A. Yes.

14 Q. All right. I’m going to separate them now

15 and I’m going to show you four specific pages on

16 here of the documents.

17 A. Okay.

18 Q. Take a look at those four pages. Tell me

19 what they are.

20 A. It says up here, “Application for U.S.

21 Passport.”

22 Q. All right. Are these, in fact, four pages

23 of applications for a passport for you and your

24 children?

25 A. Yes. This isn’t my writing.

26 Q. All right. That’s my next question. Let’s

27 begin with -- and perhaps what we can do is we can

28 number these. This exhibit is 260. We’re going to 6221



1 number these four pages specifically 260-A, B, C and

2 D. And if I can have four tags for that. Well,

3 let’s do it as separate tags. 260-A, B, C and D.

4 And then we’ll distinguish them that way.

5 Let’s start with the --

6 THE COURT: Do you realize that exhibit is

7 in, already admitted in its entirety?

8 MR. ZONEN: Would you prefer to distinguish

9 these four pages from the other -- oh, it’s already

10 in evidence?

11 THE COURT: It’s in evidence in its entirety.

12 MR. ZONEN: Can we just label it with a pen,

13 then, those four pages on the outside of the vinyl

14 cover, A, B, C and D? Can we do that?

15 THE COURT: All right. They have numbers

16 within them, don’t they?

17 MR. ZONEN: I --

18 THE COURT: 821 and 822?

19 MR. ZONEN: Do they?

20 THE COURT: They do in the book you gave me.

21 That’s in the bottom in the right-hand corner.

22 MR. ZONEN: Yes, they do.

23 THE COURT: Could you just reference those

24 numbers?

25 MR. ZONEN: I sure can.

26 THE COURT: All right.

27 MR. ZONEN: I sure can. Let me just have a

28 moment to make sure I have the right numbers. 6222



1 (Off-the-record discussion held at counsel

2 table.)

3 MR. ZONEN: Your Honor, the numbers that I’m

4 looking at in the lower right-hand corner, mine are

5 in red, is that what you have in your notebook?

6 THE COURT: They’re not in red, but --

7 MR. ZONEN: Are those numbers Q-1, Q-2, Q-3

8 and Q-4?

9 THE COURT: No.

10 MR. ZONEN: Okay. That’s my concern.

11 THE COURT: Go ahead the way you were going

12 to do it. That’s fine.

13 Q. BY MR. ZONEN: Let’s do it the way -- we’re

14 just going to take one, two, three and four, four

15 documents. And let’s start with the first one, and

16 write -- on the vinyl on the lower left hand, just

17 write “A,” the letter “A.”

18 And this one is whose application, please?

19 A. This one is mine.

20 Q. All right. Is your signature on it?

21 A. Yes, my signature is on it.

22 Q. Is the content of the application your

23 handwriting or your printing?

24 A. No, it isn’t.

25 Q. Do you know who filled this out?

26 A. Vinnie did.

27 Q. Did he fill it out in your presence?

28 A. No, he told me he did. 6223



1 Q. And where was it that he had you sign it?

2 Where were you? Not on the document. Where are you

3 at the time he had you sign it?

4 A. I think it was when I was in the motel.

5 Q. And in this particular one, No. A, does this

6 application have on it a destination?

7 A. Yes, it does.

8 Q. What is that destination?

9 A. The “Destination” says, “Countries to be

10 visited: Italy, France.”

11 Q. Did anybody talk to you about going to Italy

12 or France?

13 A. No. No.

14 Q. Did you notice that at the time that you

15 signed that application --

16 A. No.

17 Q. -- that it said “Italy” or “France”?

18 A. No.

19 Q. Was there any discussion about going to

20 someplace other than Brazil at the time that you

21 signed that document?

22 A. No. Only Brazil at that time.

23 Q. All right. Now, let’s go to the next one

24 and mark a “B” on the second one in the lower hand,

25 on top of the vinyl. And whose picture is that,

26 please?

27 A. That’s my daughter Davellin.

28 Q. On the first one, “A,” is your picture as 6224



1 well, is it not?

2 A. Yes, it is.

3 Q. Do you know where those pictures were taken?

4 A. Yes. I think -- I don’t know. I think I

5 remember it’s a Walgreen’s. I think. I may be off.

6 My best estimate is a Walgreen’s.

7 Q. They took you there?

8 A. Yes, Vinnie.

9 Q. Vinnie took you there?

10 A. Yes.

11 Q. Was that a Walgreen’s someplace near

12 Neverland or someplace in Los Angeles?

13 A. Here. No, somewhere right here in

14 Neverland. Here in Neverland, I think.

15 Q. Here in Santa Barbara County?

16 A. Yes, that’s the best that I can remember.

17 Q. Again, the handwriting on this one, or the

18 printing on this one, is that your daughter’s

19 printing?

20 A. No, it isn’t.

21 Q. Is there a signature on there?

22 A. Yes, it is.

23 Q. And whose signature is that?

24 A. I don’t know if it’s my daughter’s

25 signature. I don’t know.

26 Q. Were you present at a time that that was

27 handed to your daughter?

28 A. Yes. 6225



1 Q. Does that appear to be your daughter’s

2 signature?

3 A. I wouldn’t be able to tell you that.

4 Q. Okay. What’s the destination on that

5 particular application?

6 A. This one says, “Italy, France.”

7 Q. All right. Move to the next one. And let’s

8 mark that one “C.” Whose picture is that, please?

9 A. That’s my son Gavin.

10 Q. All right. And the application handwriting

11 is whose?

12 A. Vinnie.

13 Q. Is there a signature on that?

14 A. No, there isn’t, of his.

15 Q. So is there a signature at all?

16 A. That’s mine.

17 Q. Okay. And where it says on there “Gavin

18 Anton Arvizo” --

19 A. That’s printing.

20 Q. It’s printed?

21 A. Yes.

22 Q. That’s your signature?

23 A. Yes.

24 Q. Gavin’s signature is nowhere on there?

25 A. No, it isn’t.

26 Q. Did you sign that at the time you signed the

27 other one?

28 A. Yes. 6226



1 Q. The destination on that is what again,

2 please?

3 A. “Italy, France.”

4 Q. Move to the next one, please. And this

5 would be “D.” Who is that?

6 A. That’s Star.

7 Q. The handwriting on that is whose, please?

8 A. The handwriting is my name.

9 Q. The handwriting is your name?

10 A. Yes.

11 Q. All right. And the signature on that is

12 whose?

13 A. It is mine.

14 Q. All right. Did Star sign that at all?

15 A. No.

16 Q. And the destination of that is what?

17 A. “Italy, France.”

18 Q. If you haven’t already labeled that as “D,”

19 please go ahead and do that, lower left.

20 MR. ZONEN: Your Honor, as to the collection

21 of these documents, which I would ask to be bound

22 together and admitted as No. 260, I believe already

23 in evidence; is that correct?

24 THE COURT: That’s correct.

25 MR. ZONEN: Are any of these subsections, A,

26 B, C or D, not yet in evidence?

27 THE COURT: No, the whole package is in.

28 MR. ZONEN: The whole package is in, all 6227



1 right.

2 May I approach through here?

3 THE COURT: Yes.

4 Q. BY MR. ZONEN: Item No. 261, currently in

5 evidence, I believe --

6 THE COURT: Correct.

7 Q. BY MR. ZONEN: -- is a collection of one,

8 two, three, four, five, six, seven, eight, nine --

9 ten different pages. I’d like you to take a moment

10 and just look through them to gain familiarity with

11 each of them.

12 Have you seen any of these documents before?

13 A. Yes.

14 Q. I would like to show you specifically a

15 couple pages in here.

16 Let’s go ahead and mark each of these A

17 through, on the vinyl as we did before, so we can

18 distinguish one page from the other. Just mark “A”

19 on the first page here, and then we’re going to skip

20 through it.

21 A. Okay.

22 Q. The second page we’ll mark “B.” Put it

23 right there, if you can.

24 What is this, No. B, please?

25 A. It says, “Visa Application Form.”

26 Q. All right. And is your picture on that?

27 A. Yes.

28 Q. Is there handwriting on that application or 6228



1 printing?

2 A. Printing.

3 Q. Is that your printing?

4 A. No.

5 Q. Did you not fill that out?

6 A. No.

7 Q. Is there a signature on there anywhere? Is

8 that your signature?

9 A. No, it isn’t my signature.

10 Q. Do you know whose signature it is?

11 A. It’s Vinnie’s.

12 Q. Is the signature in Vinnie’s name or is it

13 in your name?

14 A. His name.

15 Q. But nowhere on there is your signature?

16 A. No.

17 Q. Okay. Now, the photograph that’s on there

18 is, in fact, your photograph; is that right?

19 A. Yes, it is.

20 Q. Do you remember where that photograph was

21 taken?

22 A. No, I don’t.

23 Q. Does it list the names of your parents?

24 A. Yes, it does.

25 Q. And are their names accurately listed on

26 there?

27 A. Yes, they are.

28 Q. First, middle and last name as to both your 6229



1 parents?

2 A. That’s correct.

3 Q. Did you ever see this document prior to the

4 grand jury?

5 A. This one?

6 Q. Yes.

7 A. I don’t remember that.

8 Q. I mean, did you see it -- did Vinnie ever

9 show you that document?

10 A. Oh, no. Vinnie never showed me this.

11 Q. Were you aware at the time that there was an

12 application process under way for visas to go to

13 Brazil?

14 A. Yes.

15 Q. He had told you that?

16 A. Yes.

17 Q. Did he tell you anything about the

18 applications that would go with it?

19 A. No. I was aware where Brazil was in the

20 future.

21 Q. Let’s mark this -- let’s mark this next page

22 261-C. Do you know what that document is?

23 A. It says something “itinerary.”

24 Q. “For flights”?

25 A. Yes.

26 Q. Is your name on that document?

27 A. Yes.

28 Q. Where is your name? 6230



1 A. It says, “Miss Janet Arvizo,” and it has

2 a --

3 Q. Go ahead.

4 A. The address is 111520 Trent -- I guess it’s

5 “CT.”

6 Q. Court?

7 A. Trent -- 111520 Trent Court, Calabasas,

8 California 93102.

9 Q. Have you ever lived at such an address?

10 A. I never lived in such an address.

11 Q. Do you know whose address that is?

12 A. No, I don’t.

13 Q. Did you know the address for Hamid?

14 A. I think it was somewhere -- I heard

15 something like San Fernando Valley.

16 Q. All right. Did anybody ever mention that

17 particular address in your presence?

18 A. Never.

19 Q. Did anybody tell you that there was a flight

20 itinerary to Brazil in effect?

21 A. No, not something like this.

22 Q. Is there a date on that in terms of the

23 flight out?

24 A. Yeah.

25 Q. Can you read it?

26 A. Yes. It says up here, “Date, February 25th,

27 2003.”

28 Q. All right. The last one was 261-C. 6231



1 We’re now going to 261-D, if you’d write

2 that in smaller print right there.

3 A. “D”?

4 Q. “261-D.”

5 A. Oh, “261-D.”

6 Q. Tell us what we’re looking at there.

7 A. We’re looking at my son Star.

8 Q. All right. That’s his photograph?

9 A. Yes.

10 Q. Taken at the same time and place as yours?

11 A. I figure so.

12 Q. The handwriting on that application is

13 yours? The printing, rather?

14 A. The print, it’s not mine. It’s Vinnie’s.

15 Q. The signature at the bottom left?

16 A. Vinnie’s.

17 Q. It’s in his name? His signature, his name?

18 A. Yes.

19 Q. All right. That one is “D.”

20 Let’s make this one 261-E. Tell us what

21 that is.

22 A. This is my son Gavin.

23 Q. Is that the same application for a visa?

24 A. Yes, it is.

25 Q. It appears to be the same as the other two

26 you’ve discussed so far?

27 A. Yes.

28 Q. Again, the same handwriting? 6232



1 A. It’s printing.

2 Q. I’m sorry?

3 A. Printing, the same printing. Printing.

4 Q. And the signature on the lower left?

5 A. It is Vinnie’s.

6 Q. All right. That photograph of Gavin is the

7 photograph that was taken at the same time as yours?

8 A. I figure so.

9 Q. Do you recall that?

10 A. I don’t remember. This set of pictures, I

11 thought it was --

12 Q. Do you remember any other occasion that

13 pictures were taken of you or your children for

14 purposes of some official document?

15 A. No, I don’t remember the order.

16 Q. So this would be F, 261-F, if you could

17 write that perhaps right here in small print.

18 A. Okay.

19 Q. Tell me what we’re looking at now.

20 A. We’re looking at my son Gavin’s birth

21 certificate.

22 Q. All right. 261-G. And what is that

23 document?

24 A. This is mine and my children’s child

25 custody -- I don’t know what -- exactly what the

26 title, but may I read this?

27 Q. Read the title.

28 A. Yes, sir. It says, “Child Custody and 6233



1 Visitation Order Attachment.”

2 Q. All right. Tell us what that is, to your

3 understanding. What do you believe that document

4 is?

5 A. Okay. To my understanding, this is

6 something to do with the restraining order.

7 Q. Was there any discussion with either Vinnie

8 or Frank about having to have a legal document?

9 A. Yes.

10 Q. And that attested to your custody of your

11 children?

12 A. Yes.

13 Q. Do you believe that that’s what that

14 document is?

15 A. Yes, it is.

16 Q. Who is it who asked you to get that?

17 A. Vinnie and Frank.

18 Q. Did they explain to you why you needed such

19 a thing?

20 A. For the -- the processing of the passports.

21 Q. Do you know where you got that document?

22 A. I think -- I don’t remember whether I had --

23 no, I did, I did. I think I -- yeah, because I

24 always carried one with me all the time, the

25 restraining order.

26 Q. Do you think that that came from your

27 collection of materials from your restraining order?

28 A. Yes, yes, yes, yes. But you asked me from 6234



1 where, so I don’t know exactly where, but I always

2 made it a point to have it with me.

3 Q. Why did you carry a copy of the restraining

4 order --

5 A. Because if --

6 Q. Let me finish the question. Why did you

7 carry a copy of the restraining order with you at

8 all times?

9 A. Because of David.

10 Q. Okay. That’s 261-G you’re looking at.

11 That’s the custody order.

12 261-H would be who, or what?

13 A. Oh. This is a birth certificate for my son

14 Star.

15 Q. That’s 261-H.

16 A. H?

17 Q. Yes.

18 261-I is the next one. And what is that?

19 A. This one is a visa application form, and my

20 daughter is on it.

21 Q. This is for Davellin?

22 A. This is for Davellin.

23 Q. All right. The printing on that form is

24 whose printing?

25 A. This is Vinnie’s.

26 Q. All right. The signature on the bottom is

27 whose?

28 A. Vinnie’s. 6235



1 Q. The photograph in the document is whose?

2 A. It is Davellin, my daughter.

3 Q. And the photograph was current for that

4 time; is that correct?

5 A. Yes, it is.

6 Q. That was a photograph of her at about that

7 age?

8 A. Yes.

9 Q. J, which would be 261-J.

10 A. Okay.

11 Q. Tell me what that is.

12 A. This is a birth certificate for my daughter

13 Davellin.

14 MR. ZONEN: Your Honor, I’m not certain that

15 261 is in in its entirety or if at all. If not, I

16 would move to introduce into evidence at this time

17 261.

18 THE COURT: 261 is in evidence.

19 MR. ZONEN: It’s in evidence.

20 Q. On the 20th and the 21st, do you remember

21 where you stayed the night of the 20th; in other

22 words, after you were with Vinnie gathering up the

23 birth certificates?

24 A. For most of the part on the 20th, I stood in

25 Jay’s apartment by myself.

26 Q. And then that night, did you spend the night

27 in Jay’s apartment?

28 A. That’s what I’m talking about. 6236



1 Q. Your children were where?

2 A. They were already in Neverland.

3 Q. The next day, did you meet up with Vinnie

4 again?

5 A. Yes.

6 Q. Do you recall where you went on that next

7 day, the 21st?

8 A. The next day, the best I can remember is

9 Marc Schaffel’s house, and he -- and Vinnie picked

10 upp the passport applications from his house.

11 That’s the best I can remember.

12 MR. ZONEN: Could I approach the witness,

13 Your Honor?

14 THE COURT: Yes.

15 Q. BY MR. ZONEN: I’m going to show you No.

16 806. This is in a clear evidence bag which has a

17 separate number of 1732. The court exhibit for

18 identification, No. 806, pulling out the content.

19 A. And I’m being followed this whole entire

20 time.

21 Q. That’s okay. Thank you.

22 Inside this exhibit are five pieces of

23 paper. Would you take a look at those, please? Are

24 those, in fact, duplicate copies of birth

25 certificates --

26 A. Yes.

27 Q. -- of you and your children?

28 A. Yes. Those are originals. 6237



1 Q. And the cover letter Affidavit to Amend

2 Record?

3 A. Yes.

4 Q. County of Los Angeles?

5 A. Yes.

6 Q. And I’m handing you four items now. Take a

7 look at those.

8 A. Finally. Finally.

9 Q. Well, just look at them one at a time and

10 tell us what they are.

11 A. These are --

12 Q. Go ahead and look at all four first. What

13 are they?

14 A. They’re my passports.

15 Q. Now, had you ever seen those documents

16 before today, those passports?

17 A. No.

18 Q. All right. Is this what you understood to

19 be the passports that they applied for at the time?

20 A. Yes. I had seen them when Vinnie was

21 holding on to them --

22 Q. At some point in time --

23 A. -- in Neverland.

24 Q. Let’s go ahead and put these separate.

25 I don’t know if 806 is not in evidence. I

26 would move to move 806 into evidence at this time.

27 MR. MESEREAU: No objection.

28 THE COURT: It’s admitted. 6238



1 THE WITNESS: These are the ones that Bill

2 wrote for that I wanted.

3 Q. BY MR. ZONEN: “Bill” is Bill Dickerman?

4 A. That’s right.

5 Q. You just looked at those four passports.

6 And those four passports are of you and your

7 children; is that correct?

8 A. Yes.

9 Q. Now, did you mention that you had seen them

10 at some time previous?

11 A. Yes.

12 Q. When was that that you saw them?

13 A. In Neverland.

14 Q. And do you remember when at Neverland it

15 was?

16 A. Yes. Afterwards.

17 Q. And in whose possession were those

18 passports?

19 A. Vinnie.

20 Q. How is it that you happened to see them in

21 Vinnie’s possession?

22 A. Because he was rummaging through his like, I

23 don’t know what. I don’t know. It kind of looks

24 like a suitcase, but it’s not a suitcase. It’s a

25 bag that you open up like this, and he was rummaging

26 through the things. And that’s where I seen my

27 passports. And I told him, “Could I have them?”

28 And he said, “No.” 6239



1 Q. How did you know that they were your

2 passports?

3 A. Because he was rummaging through all these

4 things, and then I happened to see them, and I said,

5 “Is that my passports?” And he said, “Yes.”

6 Q. Okay. Did you see more than just the cover

7 of them?

8 A. No, I -- just the cover.

9 Q. But you asked him if they were yours?

10 A. Yes.

11 Q. And he said?

12 A. He said, “Yes.”

13 Q. Did you ask to have them?

14 A. Yes.

15 Q. And what did he say?

16 A. He said, “No.”

17 Q. Did he say why he wasn’t giving them to you?

18 A. No, he just said, “No.”

19 Q. Now, at some later time, you retained an

20 attorney by the name of Bill Dickerman?

21 A. Yes, I did.

22 Q. All right. And did he request, by way of

23 letter that was shown to you, to have these

24 passports returned?

25 A. Yes, he did.

26 Q. Were they, in fact, ever returned to you?

27 A. No, they were never returned to me.

28 Q. Prior to today? 6240



1 A. Prior to today.

2 Q. Have you ever seen them?

3 A. I haven’t seen them.

4 Q. Where did you stay after you left on the

5 21st? Where did you go after the 21st of February;

6 do you recall?

7 A. Neverland. After Marc Schaffel’s

8 application, I went to Neverland.

9 Q. Let me ask you about Marc Schaffel. Who is

10 Marc Schaffel? Who do you understand Marc Schaffel

11 to be?

12 A. They just -- I know now per the

13 investigation, it’s different.

14 MR. MESEREAU: Objection.

15 Q. BY MR. ZONEN: Hold on. At the time, did

16 you know the name “Marc Schaffel”?

17 A. No, I didn’t. But I had spoken to a Marc

18 when the Germans were there.

19 Q. All right.

20 A. Marc --

21 Q. In person --

22 A. Marc Schaffel.

23 Q. All right. In person or over the telephone?

24 A. Over the telephone.

25 Q. Did this person identify himself to you?

26 A. Yes. He said he was Marc Schaffel.

27 Q. He said he was Marc Schaffel?

28 A. Yeah, and then that’s the one that I told 6241



1 about the audio you can hear. And I said he was

2 very unkind, because he was saying I had to do the

3 video, and I thought he was one of the Germans.

4 Q. This was a person you spoke to prior to

5 doing the rebuttal video?

6 A. Yes.

7 Q. And he was talking to you about the video?

8 A. No. He said I had to do the video. And

9 this is before Jesus.

10 Q. All right. Now, at some point on the 21st

11 you were taken to a home?

12 A. Yes.

13 Q. Did somebody tell you that was Marc

14 Schaffel’s home?

15 A. Yes, Vinnie did.

16 Q. Did you meet Marc Schaffel?

17 A. No, I didn’t.

18 Q. To this day, have you ever seen a picture of

19 him?

20 A. To this day I’ve never met him.

21 Q. All right. What were you doing at Marc

22 Schaffel’s house?

23 A. Picking up the applications for passports.

24 Q. Were you with your kids or by yourself?

25 A. No, I was by myself.

26 Q. With Vinnie?

27 A. With Vinnie and the people that would --

28 Q. You’re saying there was another car of 6242



1 people?

2 A. There was always someone following us.

3 Q. Did you know who those people were?

4 A. I didn’t know at the time.

5 Q. Could you tell how many people were in that

6 car?

7 A. Yes, sometimes there was two. And sometimes

8 there was three. And sometimes there was one.

9 Q. Did you recognize any of them at any time?

10 A. No.

11 Q. You already knew Asaf’s appearance.

12 A. Yes.

13 Q. Did you know if Asaf was ever one of them?

14 A. No, I just happened to see Asaf one other

15 time, and - I think so - that was during that

16 Calabasas period.

17 Q. All right. Where did you go on the 21st?

18 Where did you stay after that?

19 A. On the 21st, I stood at Neverland.

20 Q. And for how long were you at Neverland?

21 A. Until the 25th.

22 Q. And on the 25th, you went where?

23 A. To the hotel. I don’t know if it’s hotel,

24 motel, in Calabasas.

25 Q. All right. Do you remember the name of it?

26 A. I think it’s Country Inn & Suites.

27 Q. In Calabasas?

28 A. Yes. 6243



1 Q. All right. Let me go back to that period of

2 time from the 21st to the 25th that you were at

3 Neverland. Where did you stay during that time?

4 A. In the guesthouse.

5 Q. And were your children there as well?

6 A. Yes.

7 Q. Where did Davellin stay?

8 A. In the guesthouse next to me.

9 Q. Not your unit?

10 A. And -- and I don’t mean to say “guesthouse.”

11 It’s actually one building divided into four, and

12 they’re actually just bedrooms.

13 Q. Four separate units in a building?

14 A. Four separate units?

15 Q. Yes. And you had one of the units?

16 A. Yes.

17 Q. And Davellin had another?

18 A. Yes.

19 Q. Where were the boys?

20 A. The boys were in the house.

21 Q. And that’s Gavin and Star you’re referring

22 to?

23 A. Yes, yes.

24 Q. They were staying in the house?

25 A. Yes.

26 Q. Did they stay in the house the entire time?

27 A. Yes.

28 Q. Do you know if Michael Jackson was there 6244



1 during that period of time?

2 A. At that time, I don’t know.

3 Q. Do you have a recollection of seeing him

4 during that time?

5 A. At that time, I don’t remember.

6 Q. Were you seeing your sons throughout that

7 period?

8 A. No.

9 Q. The 21st through the 25th?

10 A. No.

11 Q. Where were you during the day?

12 A. In the guesthouse.

13 Q. Did you ever leave?

14 A. Not really.

15 Q. Where did you take your meals?

16 A. In -- in there.

17 Q. In the guesthouse?

18 A. Yes, I did.

19 Q. Did you ever go into the main house for

20 meals?

21 A. No. No.

22 Q. Did you ever walk around the property?

23 A. Um, I think in that whole period from when I

24 returned, from the 21st on, I’m being generous if I

25 say -- if I may, my best estimate, if I say twice.

26 Q. “Twice” what?

27 A. I walked out into Neverland. And that’s my

28 best -- and we’re talking about the period from the 6245



1 21st on.

2 Q. Were you having -- were you spending time

3 with your sons during that four-day period?

4 A. No.

5 Q. On the 25th, where did you go?

6 A. On the 25th?

7 Q. Yes. The 25th of February.

8 A. Okay. The 25th of February, went to my

9 son’s doctor’s appointment. Then from there, I went

10 to -- to Jamie’s, and then from there the hotel.

11 Q. All right. Let’s talk about the first two

12 that you mentioned.

13 A. Okay.

14 Q. There was an appointment you had, I assume

15 with Gavin; is that right?

16 A. Yes, I did. And Vinnie was there.

17 Q. And Vinnie went with you?

18 A. And the people that were following us.

19 Q. And another vehicle behind you?

20 A. Yes.

21 Q. And did you go with your other two children?

22 A. All three of my kids.

23 Q. All of your kids went?

24 A. Yes.

25 Q. The doctor’s appointment was where?

26 A. In Kaiser. That was his cancer specialist,

27 his oncologist.

28 Q. And did they make another appointment for 6246



1 him or for testing at that time?

2 A. Yes. Yes, they did.

3 Q. What was that appointment?

4 A. That was -- I don’t know what the correct

5 medical term is, but Gavin has to go -- yes, he is a

6 healthy boy, but he’s got a lot of medical issues,

7 and they have to watch out for -- and so they -- I

8 don’t know what this one is called. I don’t know

9 whether it’s called a CT scan, ultrasound. The main

10 purpose of that was to check his kidney, because

11 there’s a constant concern that Gavin could possibly

12 lose his kidney.

13 Q. Is this a concern that exists today?

14 A. It still exists today.

15 Q. All right. Now, the -- he had an

16 appointment with the doctor. So he actually visited

17 with the doctor on the 25th?

18 A. Yes.

19 Q. During that visit, where did Vinnie go?

20 A. Oh, Vinnie was right there.

21 Q. What is “right there”?

22 A. With us, with me, the whole entire time with

23 us. And usually our doctor visits, me and the kids

24 are always like a group, you know.

25 Q. All right.

26 A. Because when I go to the doctors’

27 appointments, yes, I -- you know, Sergeant Mommy.

28 But I’m always like this, weak in my knees, because 6247



1 I never know what is going to happen, I have to

2 have, after the visit. So prior to the visit, I am

3 holding my breath.

4 Q. Did Gavin actually have an examination with

5 the doctor?

6 A. Yes.

7 Q. I assume that was separate from where Vinnie

8 was.

9 A. Yes.

10 Q. Were you present during --

11 A. No, Vinnie was right there. Vinnie had

12 expressed to me that there was something they could

13 listen to me.

14 Q. I don’t understand what “right there” means.

15 A. Right there. Right outside the doctor’s

16 room.

17 Q. Is that where you were?

18 A. Yes.

19 Q. So he was with you?

20 A. And he was with the kids.

21 Q. All right. And the kids were there, too?

22 A. Yes.

23 Q. Is this a waiting room of some kind?

24 A. No, it isn’t. It’s actually the hallway

25 outside the doctor’s room.

26 Q. When you left the doctor’s office on the

27 25th, did you have an appointment to have an

28 appointment to return to the doctor at some time in 6248



1 the future?

2 A. Yes. I --

3 Q. Was that for an examination or a test?

4 A. No, that was a test. Purely a test. No

5 doctor visit whatsoever.

6 Q. And what day was that?

7 A. March 10th.

8 Q. What was the test?

9 A. I don’t know. Like I told you, Mr. Zonen, I

10 don’t know whether it was one of those CT scans or

11 ultrasound. The main purpose of that test was to

12 check on his kidney.

13 Q. All right. Was that the day that you were

14 supposed to turn in a sample of -- a collection of

15 his urine?

16 A. Yes.

17 Q. Now, let’s go back to this, now, again.

18 A. A 24-hour collection.

19 Q. A 24-hour collection. We’re going to cover

20 this in just a moment. Let’s go back to the 25th.

21 A. Okay.

22 Q. You said that you had a doctor’s appointment

23 with all of you, and then you went to, you said,

24 The Laugh Factory?

25 A. Yes, I did.

26 Q. What was your reason for going to The Laugh

27 Factory?

28 A. Okay. We were already on Sunset Boulevard. 6249



1 And the Laugh Factory is not that far from Kaiser,

2 so I tried to -- I tried to -- I’m -- I’m trying --

3 all along through this period, I’m trying to reach

4 people to help me, to let them know the best that I

5 knew at that time, because it kept evolving into

6 more and more escalation.

7 MR. MESEREAU: Objection; nonresponsive.

8 THE WITNESS: Okay. That’s my answer,

9 though.

10 THE COURT: Just a moment, please.

11 THE WITNESS: Yes.

12 THE COURT: I think it was nonresponsive.

13 MR. ZONEN: I think it was.

14 Q. Now, you were going to go to The Laugh

15 Factory. Excuse me, I’m sorry. Were you expecting

16 to meet somebody at The Laugh Factory?

17 A. Yes.

18 Q. Who were you expecting to meet at The Laugh

19 Factory?

20 A. I was expecting to meet just Jamie. And I

21 think that Jamie on his own called Mr. Dickerman.

22 Q. Did you know who Mr. Dickerman was prior to

23 that day?

24 A. Yes.

25 Q. And how did you know who Mr. Dickerman was?

26 A. Because Jamie had told me that Mr. Dickerman

27 could possibly maybe help put a stop to Gavin’s

28 being ridiculed and called “gay” and all these 6250



1 things.

2 Q. Do you mean the television show?

3 A. Yes, because they were making no effort.

4 Q. Did you understand Mr. Dickerman to be an

5 attorney?

6 A. Yes, I did.

7 Q. Did you understand him to be Jamie’s

8 attorney, Jamie Masada’s?

9 A. Yes, I did.

10 Q. Did you tell Vinnie in advance that you were

11 going to go visit with a lawyer?

12 A. No, I didn’t.

13 Q. Why not?

14 A. Because I was -- there was -- there was

15 consequences, consequences for going out of their

16 plan.

17 Q. Okay. When you arrived at The Laugh

18 Factory, what did you tell Vinnie was the purpose of

19 going to The Laugh Factory?

20 A. Just -- just visit Jamie.

21 Q. Did you tell him who Jamie was?

22 A. Yeah, I had told him Jamie’s a good friend,

23 and that’s about it. And so the second I went in

24 there, there was -- in two minutes I had to leave.

25 Q. All right. You went in there. Did you go

26 in with any of your children?

27 A. I think it was one of them. He had two of

28 them stay with him. And then now Frank’s on the 6251



1 phone going crazy because I’m talking to Jamie,

2 so --

3 Q. Hold on a second. Hold on a second.

4 You’re inside The Laugh Factory right now?

5 A. Yes.

6 Q. How do you know Frank’s on the phone with

7 anybody?

8 A. Because Davellin came in running and said,

9 “Mommy, let’s” -- “Frank’s on the phone, and he’s

10 mad and he’s going crazy.”

11 Q. All right. How long were you inside talking

12 to Jamie at that time?

13 A. My gosh, it was like -- not that long. Not

14 that long.

15 Q. What is “not that long”? Five minutes? Ten

16 minutes? 20 minutes? Give us a sense of it.

17 A. My best estimate -- my best estimate, less

18 than maybe ten minutes.

19 Q. Less than ten minutes?

20 A. Yes.

21 Q. All right.

22 A. And that’s my best estimate.

23 Q. Where did you go after that? This is the

24 25th. Where did you go after that?

25 A. Then they -- then Vinnie had told me that --

26 do you just want me to tell -- not what happened

27 prior?

28 Q. Yes, just where did you go after you left 6252



1 The Laugh Factory?

2 A. The motel.

3 Q. The motel in Calabasas?

4 A. Yes. Or hotel, the Country Inn.

5 Q. How many days did you stay in Calabasas?

6 A. The 25th through the 2nd of March.

7 Q. That’s a 28-day month, February.

8 A. Yes.

9 Q. So you were there five days?

10 A. Yes.

11 Q. 25th, 26th, 20 --

12 A. And I didn’t know I was going to stay there.

13 Q. Did they tell you why you were there as

14 opposed to going back to Neverland?

15 A. Yes, Vinnie had said that the killers had

16 arrived at -- at Neverland, so we weren’t going to

17 be able to go back. We had absolutely no kind of

18 piece of luggage with us. Nothing. That was a

19 complete surprise.

20 Q. So --

21 A. Yes.

22 Q. -- where did Vinnie say you were going after

23 the Calabasas hotel?

24 A. After?

25 Q. Yes.

26 A. Not during?

27 Q. Well, while you were at Calabasas at that

28 hotel, Vinnie told you that it was not safe to go 6253



1 back to Neverland?

2 A. That’s right.

3 Q. All right. Did he tell you where you were

4 going to go?

5 A. We were going to a motel.

6 Q. And after the motel?

7 A. After -- now, what are you talking? During?

8 Q. You said you were going to go to a motel.

9 You were in a motel.

10 A. Yeah, that’s it.

11 Q. Did he tell you you were going -- how long

12 did he tell you you were going to have to stay at

13 that motel?

14 A. No, he didn’t. It was always one day. One

15 day. Every day everything changed.

16 Q. You had no other clothing with you?

17 A. No.

18 Q. All your clothing --

19 A. No clothing.

20 Q. -- was at Neverland?

21 A. Was at Neverland.

22 Q. At some --

23 A. Every piece of clothing was at -- in

24 Neverland that I had with me.

25 Q. At some point in time did you go shopping?

26 A. Yes.

27 Q. Where did you go shopping?

28 A. And this is -- again, I had told them this 6254



1 is to replace -- because I wouldn’t accept anything

2 from them. It was only in replacement. They said

3 it was not -- not safe to return, so they were going

4 to replace the children’s items, and that’s how they

5 tricked us.

6 Q. All right. Ultimately how long did you stay

7 at that hotel at Calabasas?

8 A. From February 25th to March 2nd.

9 Q. And during that time, on how many of those

10 days did you go shopping for clothing?

11 A. One day.

12 Q. Was there any discussion during that

13 five-day period of time as to when you were going to

14 be going to Brazil?

15 A. Yes. It was -- we were going to Brazil.

16 That’s it.

17 Q. Did they give you a day? Did they say in a

18 week? In a month? Did they say when?

19 A. No. No, the second they get them, the

20 second we’re going to go.

21 Q. The second they get what?

22 A. The second they get all of this covered.

23 Q. The documentation that they needed?

24 A. Yes, uh-huh.

25 Q. Did you believe at that time that you were

26 actually going to go to Brazil?

27 A. Yes. And this is the period when I called

28 Wheezy, Louise Palanker. 6255



1 Q. You called her from the hotel in Calabasas?

2 A. No, I didn’t. I don’t know where I was.

3 I don’t know where I was, but I called her during

4 this period. That I can remember clear.

5 Q. All right. Who was at the hotel during this

6 five-day period, other than you and your three

7 children?

8 A. Frank. Vinnie. Johnny. This -- another

9 guy that I never saw that always would stand outside

10 my window. And then these other people that I never

11 came to find out who they were.

12 Q. How many other people are we talking about?

13 A. Like I said, sometimes in the car there was

14 one, sometimes there was two, and sometimes there

15 was three.

16 Q. Were they there all the time?

17 A. Yes.

18 Q. Or one of them all the time?

19 A. Yes. Oh, there was -- nobody left my side

20 at all.

21 Q. Were Frank and Vinnie with you the entire

22 time?

23 A. No. It was these people that were all the

24 time.

25 Q. Somebody named “Johnny” you just mentioned.

26 A. Yes.

27 Q. All right. What does he look like?

28 A. He’s -- he’s big. 6256



1 Q. I’m sorry, I asked you about Johnny.

2 A. He’s big.

3 Q. Big?

4 A. Yes.

5 Q. What color hair does he have?

6 A. It’s a light color.

7 Q. Was he there the entire time?

8 A. Yes, the entire time.

9 Q. And day and night?

10 A. Day and night.

11 Q. Was there some -- if you walked out of your

12 door, did you always see somebody there?

13 A. Yes. Absolutely. Outside my door, and

14 outside my window, and wherever we went.

15 MR. ZONEN: If I could approach the witness,

16 Your Honor.

17 THE COURT: Yes.

18 Q. BY MR. ZONEN: Showing you No. 26, please,

19 would you tell us who this is?

20 A. This is Johnny.

21 Q. That’s Johnny?

22 A. Yes.

23 Q. During this period of time did you have

24 telephone calls with anybody else?

25 A. Me?

26 Q. Yes.

27 A. But my phone calls were being monitored and

28 listened to. 6257



1 Q. Somebody told you that?

2 A. Yes.

3 Q. Who?

4 A. Frank and Vinnie.

5 Q. Did you believe that to be true?

6 A. Yes, I did believe them.

7 Q. Notwithstanding that belief, did you make

8 phone calls from the hotel?

9 A. Yes, I did. What I did, I tried to give --

10 drop clues to every person. I figured -- I figured

11 by all -- this was all going to be resolved by God’s

12 miracles, and I figured one day -- there will be one

13 day that all these people could give clues as to

14 when me and my children would have disappeared,

15 clues, clues, and this way this puzzle would have

16 been put together.

17 Q. Who did you call during that period of time

18 when you were at the hotel?

19 A. I called my mom, but I tried to like whisper

20 to her in Spanish, and she said, “Que?” And so --

21 and --

22 Q. Your mom’s a little hard-of-hearing, isn’t

23 she?

24 A. Yes, so -- so that didn’t help me.

25 Q. All right. Did you tell your mother you

26 were going to Brazil?

27 A. No, I don’t think so.

28 Q. She didn’t know? 6258



1 A. No.

2 Q. Who else did you call?

3 A. But Aja did.

4 Q. You called Aja during this period of time?

5 A. Yes, yes. I sneaked it in there.

6 Q. You called her from where?

7 A. From the hotel.

8 Q. Okay. And you say you sneaked it in. What

9 does that mean?

10 A. Yes, yes. Like, you know, I was letting

11 her -- I was talking and kind of dropping people

12 clues. Oh, you know, just kind of making --

13 Q. Hold on a second. The question was, how did

14 you sneak a call in? What does that mean?

15 A. Okay. No, no, all my conversations were

16 being monitored and listened to, all of them. What

17 I’m trying to say is, I sneaked it in a way where

18 I -- I said it to her, hoping that nobody had

19 listened in on what I had told her.

20 Q. Who else did you call besides Aja, your mom

21 and Louise?

22 A. Aja, my mom, Louise -- but I didn’t call

23 Louise from the hotel. I don’t remember where I

24 called her from.

25 Q. Okay.

26 A. Um -- um, I think it was one of my cousins.

27 My mom.

28 Q. Did you call Jay during that period of time? 6259



1 A. Yes, I called Jay. I hadn’t called him for

2 days.

3 Q. And you did call him from that hotel?

4 A. Yes.

5 Q. All right. Did you call the police during

6 that time?

7 A. No.

8 Q. Why not?

9 A. Because my calls are being monitored, they

10 were being listened to, my parents are in danger,

11 Jay’s in danger, and who could possibly believe

12 this?

13 Q. What do you mean by, “Who could possibly

14 believe it?” What was your concern in that regard?

15 A. That nobody would believe me. And that’s

16 because Frank said nobody would believe me.

17 Q. Did you, in your conversation with Jay from

18 the hotel, tell him what was going on?

19 A. No.

20 Q. Did you tell him you were going to Brazil?

21 A. I told him the same way I tried to talk to

22 Aja. Everything was always broken. It was never

23 complete. So in my -- in the midst of a regular

24 conversation, I’d throw something in, hoping that it

25 hadn’t been heard, and yet that this -- that part

26 could stick in somebody’s mind, and hopefully one of

27 these days this puzzle could be put together. I

28 tried. 6260



1 Q. After five days there, where did you go?

2 A. Back to Neverland.

3 Q. So this is now on the 2nd of March; is that

4 right?

5 A. Yes.

6 Q. And how long did you stay at Neverland from

7 the 2nd of March?

8 A. Till March 10th.

9 Q. During that eight-day period of time, where

10 did you stay?

11 A. Like I told you, Mr. Zonen, from the 21st

12 on, when I was at Neverland, I just stood in the

13 room. That’s it. And that was per their order.

14 Q. Was there somebody around?

15 A. Yes. Either Frank or Vinnie, or both. But

16 this guy Joe, he was really scary. You know what’s

17 more scary? When you’re not spoken to and you’re

18 just watched. That was really scary.

19 Q. Do you know Joe’s name?

20 A. I don’t know his last name, but he’s -- he

21 is extremely loyal to him, to Mr. Jackson.

22 Q. What does he look like, “Joe”?

23 A. He is tall, kind of balding, a little bit of

24 hair you can see.

25 Q. Do you mean a shaved head?

26 A. Yes.

27 Q. Do you know his last name?

28 A. I don’t know his last name. 6261



1 Q. Did you ever hear it before?

2 A. No. Always -- the last names I would always

3 find out by accident. They never told me their last

4 names. Only when I would overhear them.

5 Q. What was it about Joe’s behavior that

6 frightened you?

7 A. That -- that this particular specific time,

8 for example, they would stand right outside my

9 window, and Frank and Vinnie would talk to him, and

10 then they’d turn around, Joe would go like this

11 (indicating), and he’d go back and like this

12 (indicating) and just stand there.

13 Q. Was Chris Carter there during that time?

14 A. Chris Carter. Um, I don’t know. I don’t

15 know. I stood there inside the room.

16 Q. Was Jesus there during that time?

17 A. Yes. And whenever Jesus would -- whatever,

18 come into my room, I’d go -- you know, right there

19 in my room I’d try talk to him, and he would tell

20 me, “I can’t help you.”

21 Q. Where were your boys during this time, from

22 the 2nd to the 10th?

23 A. From the 2nd to the 10th, they were -- they

24 were with Michael. This time I did see him.

25 Q. Could you tell if he was there the entire

26 time, from the 2nd --

27 A. Oh, yes.

28 Q. Who are we talking about now? 6262



1 A. Yes, because I’d see him. They’re running

2 around with my kids like crazy, crazy nuts, you

3 know. You know, I --

4 Q. All right, wait. You said “him.” Who is

5 “him”?

6 A. Mr. Jackson.

7 Q. All right. And “they” were running with

8 him. Who are “they”?

9 A. My boys.

10 Q. “Like nuts,” explain that to me. What does

11 that mean?

12 A. Yeah, you know, I could see through my

13 window at a distance. I know they’re my kids, but

14 they’re this little. When you see someone really

15 far, they’re about this little, and I see him this

16 much bigger. It’s clearly them, them riding around

17 in a go-cart and -- goodness gracious.

18 Q. Was there something about your boys’

19 behavior at that time that was alarming you?

20 MR. MESEREAU: Objection; leading.

21 THE WITNESS: No guidelines.

22 THE COURT: Just a minute.

23 Overruled.

24 You may answer.

25 THE WITNESS: No guidelines.

26 Q. BY MR. ZONEN: What does that mean, “no

27 guidelines”?

28 A. There’s no guidelines. There’s -- that’s 6263



1 it. I’ve lost my kids.

2 Q. Did you have any contact with them during

3 this period of time?

4 A. No.

5 Q. And “no guidelines.” How were they actually

6 behaving? Tell us how they were behaving at that

7 time.

8 A. Doing everything they wanted with Mr.

9 Jackson.

10 Q. All day long?

11 A. All day long, all night long.

12 Q. Where were they staying at night?

13 A. With Mr. Jackson.

14 Q. All right. Did you ever go into Mr.

15 Jackson’s residence at night?

16 A. No.

17 Q. Were you able to go into his residence?

18 A. No. From -- like I told you, Mr. Zonen,

19 from the period of the 21st on, no. I’d be generous

20 if I say, as my best estimate, two times.

21 Q. Did you tell the social workers from the

22 Department of Child & Family Services, did you tell

23 them that you would check on your children inside

24 the house throughout the night?

25 A. With the DCFS meeting, if you take a smaller

26 version of the video that we did on that same day,

27 if you make it smaller, that’s what -- that’s what

28 was discussed. 6264



1 Q. Right. But did you, in fact, tell them

2 that?

3 A. I could have. I could have.

4 Q. Did you know where your children --

5 A. And then but don’t forget about the other

6 additional tape-recording thing that Asaf had left

7 there.

8 Q. Okay. Did you know where the boys were

9 sleeping inside the house?

10 A. No. At that time. Now I know.

11 Q. At the time, where do you believe that they

12 were sleeping?

13 A. I believed that the children stayed with

14 children. That’s what I believed.

15 Q. Do you mean his own children?

16 A. Well, with other children, because -- just

17 children. That’s what I believed.

18 Q. Did you ever ask Gavin or Star where exactly

19 in the house they were sleeping during that time?

20 A. At that time, no.

21 Q. Did you ever have any conversations with

22 Michael Jackson during that period of time from the

23 2nd of March until the 10th of March?

24 A. No. Zero. They were having too much fun.

25 Q. Did you have any conversations with either

26 Vinnie or Frank during that period of time?

27 A. Oh, God. A lot of them.

28 Q. And -- 6265



1 A. I didn’t have conversations. They -- they

2 were coming at me.

3 Q. And what types of things were they telling

4 you at that time?

5 A. And just following their orders. Oh, this

6 is one of the things when they were trying to make

7 me sign that -- that waiver.

8 Q. That waiver.

9 A. And I said, “No, no, I’m sorry, but my

10 signing days are over.”

11 Q. Were your children in school during this

12 period of time that they were at Neverland?

13 A. No, no school.

14 Q. Were they getting any private instruction

15 while they were at Neverland?

16 A. No. See --

17 Q. No, did you complain about that to anybody?

18 A. I brought it to Mr. Jackson’s attention --

19 THE REPORTER: And to whose attention?

20 THE WITNESS: To Mr. Jackson, on that

21 first -- prior to that meeting with Jesus.

22 Q. BY MR. ZONEN: During the initial stay?

23 A. Yes, the initial --

24 Q. Early in February?

25 A. Yes.

26 Q. What did Mr. Jackson say to you about your

27 children getting tutoring or schooling?

28 A. That Ronald and Dieter would fix everything. 6266



1 Q. Now, during this subsequent stay from the

2 2nd to the 10th of March of 2003, did you complain

3 about them not getting any schooling during that

4 time?

5 A. No. My complaining -- my speaking days were

6 over, because the second I would say something,

7 “Ahh.”

8 Q. The second you would say something, somebody

9 would do something?

10 A. Yes. Frank would holler at me.

11 Q. Were you aware that there was a private

12 school located near Neverland?

13 A. No.

14 Q. Did you ever ask them to send the children

15 to a private school?

16 A. No.

17 Q. At some point in time did your children

18 visit a dentist while they were at Neverland?

19 A. Yes.

20 Q. For what purpose?

21 A. Remember how I told you I kept trying to

22 do -- do things, Mr. Zonen, about ways -- ways of

23 getting out of there? And so I had told them that

24 if I didn’t get -- if I didn’t get the

25 orthodontist’s teeth -- braces removed, that they

26 will -- the social workers were going to call the

27 police.

28 And originally, Ronald and Dieter, way when 6267



1 the Germans were involved, they had said that it was

2 bad PR for the police to get involved for Mr.

3 Jackson.

4 So I used that, and I told them that they

5 were going -- if I didn’t get the braces removed,

6 that they were going to call the social workers.

7 Q. All right.

8 A. So I used that, because what I was trying to

9 do was go to my orthodontist, so this way it was

10 someone I knew that could possibly believe me.

11 Q. All right. Now, whose idea was it to go to

12 a different orthodontist?

13 A. Their idea.

14 Q. And did you, in fact, go to a different

15 orthodontist?

16 A. Yes. And get this: After the orthodontist

17 was closed, no other patient was there. It was

18 after hours, and with that scary guy Joe, and being

19 put on notice that I was being listened and

20 monitored. So again, I, the mother, failed again.

21 Q. All right. Now, did they take off the

22 braces at that time?

23 A. Yes, they took off the braces.

24 Q. Were they, in fact, ready to have their

25 braces removed?

26 A. They were not ready to take off the braces.

27 My children were supposed to have -- I think one of

28 them was, I think two years of orthodontistry. And 6268



1 the other one had -- Star needed -- required

2 orthodontic care, and I think it was about three

3 years.

4 And so we -- the kids only had -- at that

5 period, I think they only had them on for -- oh, I

6 think they only had had them on at a period of six

7 months at that time. And that’s my best estimates.

8 So they weren’t supposed to be taken off.

9 Q. Why didn’t you simply change your mind about

10 it and say, “No, we won’t take them off”?

11 A. Then they would have known then that I’m

12 trying to escape. Because every time I tried to

13 leave, there was huge consequences.

14 Q. Did you have a talk with anybody at

15 Neverland about moving out of your apartment on Soto

16 Street?

17 A. This was -- it was an evolvement of

18 different things. First evolvement was when --

19 because the killers had gone to my apartment, I had

20 to move out and different things. But this only

21 came after -- after they found out that I had in my

22 home Michael’s letter, a rabbit that he had given my

23 son, which he wanted him to call him “Michael,” just

24 different pictures. So my apartment was meaningless

25 to them until they found out that Michael’s things

26 were there.

27 MR. MESEREAU: Objection. Nonresponsive;

28 move to strike. 6269



1 THE WITNESS: That’s my whole answer.

2 THE COURT: Just a moment. Just a moment.

3 It’s sustained.

4 Q. BY MR. ZONEN: Let’s back up a couple

5 notches if we can.

6 A. Okay.

7 Q. The first conversation that you had about

8 moving out of the apartment on Soto Street was with

9 whom? Just tell me the name.

10 A. With Ronald and Dieter.

11 Q. That was with Ronald and Dieter?

12 A. Yes. Way back.

13 Q. So that was way back?

14 A. Yes.

15 Q. And did they talk to you at that time about

16 moving out of the apartment?

17 A. Yes.

18 Q. At some point in time, did you tell -- did

19 you tell somebody that in your possessions at that

20 apartment --

21 A. Yes.

22 Q. -- were letters from Michael Jackson?

23 A. Yes.

24 MR. MESEREAU: Objection; leading.

25 THE COURT: Overruled.

26 Q. BY MR. ZONEN: That answer was “Yes”?

27 A. Yes.

28 Q. With whom did you have that conversation? 6270



1 A. With Ronald and Dieter.

2 Q. Now, in fact, where were those letters?

3 A. In my apartment.

4 Q. And where in your apartment were they?

5 A. Okay. They were in different places. But

6 one specific place that I remember is, I had a clay

7 pot and it was Gerbera daisies, artificial Gerbera

8 daisies. They weren’t real. So when you lift it

9 up, it’s empty, because the artificial flowers do

10 not belong to that pot. You can -- you can easily

11 lift it up and out.

12 And I had placed them there. The -- and the

13 reason that I had placed them there is because David

14 is very sneaky. He does things, so I didn’t want

15 David to get his hands on them.

16 Q. The letters were from Michael Jackson to

17 whom?

18 A. To Gavin. Purely to Gavin.

19 Q. Had you read those letters?

20 A. Who?

21 Q. You.

22 A. Me? Yes. Yes.

23 Q. Why did you keep them at all, those letters?

24 A. Because they -- Michael had sent them, and

25 they said “I love you” to Gavin, and, “Love you,

26 Apple Head,” and “Doo-Doo Head.” Just -- I just

27 kept them, you know, along with all these other

28 things that I had ever received from other people. 6271



1 Q. You had other letters there as well?

2 A. Yeah. From other people, too.

3 Q. Now, did you tell either Dieter or Ronald

4 where those letters were?

5 A. No, I didn’t. I just said they were in my

6 apartment.

7 Q. Did you tell them that anything else was in

8 your apartment that had come from Neverland or from

9 Michael Jackson?

10 A. Yeah. Pictures. And then the rabbit. It

11 was a little pretend rabbit, not a real rabbit.

12 Q. All right. A rabbit from Neverland?

13 A. Yeah, it was just a rabbit that came in a

14 gift basket.

15 Q. Where was that kept?

16 A. That was out in the open.

17 Q. Now, you said Ronald and Dieter talked to

18 you about moving out of the apartment?

19 A. Yes.

20 Q. At some point did either Frank or Vinnie

21 talk with you about moving out of the apartment?

22 A. Oh, yes.

23 Q. Who was the first, between the two of them,

24 to the best of your recollection?

25 A. Frank, on the phone, telling me it was so

26 dangerous.

27 Q. At some point in time did you move out of

28 the apartment? 6272



1 A. Yes, I did.

2 Q. Who did you tell that you were willing to

3 move out?

4 A. I didn’t tell them that -- that yes, for

5 sure. That I would think about it.

6 Q. Who is it that you told that to?

7 A. To Frank. But it wasn’t a “Yes.” I would

8 think about it.

9 Q. Were you ultimately moved out of that

10 apartment?

11 A. Yes. And this time I had said, “No.” I

12 thought about it, and then it was a “No.”

13 Q. Do you recall if you signed anything that

14 reflected your willingness to move out of that

15 apartment?

16 A. I didn’t sign a thing.

17 Q. Did you have a conversation with anybody

18 about moving out?

19 A. Yeah. Frank and Vinnie. And then Ronald,

20 Dieter in the beginning.

21 Q. All right. Now, was there any rent that was

22 owed on that apartment at that time?

23 A. That’s another thing that they had found

24 out. It had slipped out --

25 Q. Hold on just one second.

26 A. Okay.

27 Q. The question was, was there any money that

28 was owed on that apartment? 6273



1 A. At that current time, it was -- no.

2 Q. How long had you lived in that apartment?

3 A. Five years.

4 Q. Was there any point in time during that

5 five-year period where you did not pay rent?

6 A. Yes.

7 Q. And when was that?

8 A. That was when Gavin was ill.

9 Q. And for how many months was that?

10 A. That was two months.

11 Q. And what did the landlord say about that?

12 A. One -- one month he gave -- he gave us. And

13 the second one was owed to him, and he had told us

14 to pay it when we can and it’s okay.

15 Q. All right. One month was simply gratis; it

16 was given to you --

17 A. Yes.

18 Q. -- for free?

19 A. Yes.

20 Q. And the second month you owed?

21 A. Yes.

22 Q. How much money was -- what was the rent for

23 that apartment?

24 A. My apartment rent was 425. But I was

25 current to the point that -- since 2000. That was

26 since 2000.

27 Q. All right. So at the time that you were at

28 Neverland for this period between the 2nd and the 6274



1 10th --

2 A. Was already 2003. And I was still current

3 on my month (sic), every month.

4 Q. How about that one month that you were going

5 to pay back at a later time? Was that ever paid

6 back?

7 A. No. Never.

8 Q. So there was still a --

9 A. Yeah, it’s something that I knew.

10 Q. There was still 400-plus dollars that --

11 A. No, it was actually -- it was two months

12 that weren’t paid. But he said one was okay, and

13 one was -- but it was two.

14 Q. Well, tell me, what was the amount that was

15 owed at --

16 A. 850 from the year 2000. Nothing current.

17 My rent was paid current.

18 Q. All right. 850 would reflect two months; is

19 that right?

20 A. Yes.

21 Q. And that was --

22 A. Of the year 2000.

23 Q. Didn’t you say that one of those months was

24 forgiven?

25 A. Yeah, that’s what he said. But I didn’t --

26 I still didn’t -- you know.

27 Q. It was either 425, one month, or 850 for two

28 months? 6275



1 A. It was for two months, but he had

2 voluntarily said that one month is okay.

3 Q. All right.

4 A. But --

5 Q. Did you believe you owed 850?

6 A. Yeah.

7 Q. All right.

8 A. Yes, I did.

9 Q. Do you know if somebody paid off the balance

10 of the rent that was owed?

11 A. Yes.

12 Q. Do you know who that was?

13 A. I came to find out -- it had slipped out of

14 Vinnie that they didn’t want no one to be able to --

15 to miss me or the kids, or start raising questions

16 as to where the kids were. And usually because

17 of -- this is what Vinnie said; that they would

18 possibly start looking for me because I hadn’t paid

19 my rent.

20 Q. Do you know if somebody paid off that

21 balance?

22 A. Yes, I became aware of that.

23 Q. Do you know who it was that paid it off?

24 A. No, I don’t. That part I don’t know.

25 Q. It wasn’t you?

26 A. No.

27 THE COURT: Counsel? Take a break.

28 (Recess taken.) 6276



1 MR. ZONEN: May I approach the witness,

2 please?

3 THE COURT: Yes.

4 MR. ZONEN: Yes, please.

5 Madam Clerk, is 276 in evidence? I don’t

6 believe it is. 276.

7 THE CLERK: It hasn’t been identified yet.

8 Q. BY MR. ZONEN: All right. I’m showing you

9 now Exhibit No. 276, which is two separate sheets,

10 the second one having two documents in it, front and

11 back.

12 And do we have that pen that you had

13 initially?

14 And again, on the vinyl of 276, not on the

15 document itself, perhaps right here, tell us what --

16 let’s mark “A” for 276-A. And is that an envelope?

17 A. Yes, it is.

18 Q. To whom?

19 A. To me.

20 Q. From whom?

21 A. From my old landlord.

22 Q. Okay. At the Soto Street address?

23 A. Yes.

24 Q. And the address to where that was sent?

25 A. The address where it was sent was my

26 mother’s home address.

27 Q. In El Monte?

28 A. In El Monte. 6277



1 Q. Let’s go to the second document, No. B. And

2 mark that “B,” if you would, please, on the vinyl

3 again.

4 BAILIFF CORTEZ: You have to speak into the

5 microphone.

6 THE WITNESS: Oh.

7 Q. BY MR. ZONEN: And does that appear to be a

8 letter?

9 A. Yes.

10 Q. Is your name typed on the end of that

11 letter?

12 A. Yes, it is typed.

13 Q. And is that your signature above it?

14 A. No, it’s not my signature.

15 Q. Would you read the content of that letter,

16 please. To yourself.

17 A. Oh. Okay. Okay.

18 Q. All right. What does that letter purport to

19 do?

20 A. What does --

21 Q. What does the letter say?

22 A. Oh. It says basically -- should I read it

23 or just tell -- summarize?

24 Q. Go ahead and read it.

25 A. It says, “I, Janet Arvizo, who have lived in

26 Apartment 208, have spoken to Yolanda about ending

27 my lease. As of March 1st, 2003, my apartment is

28 cleaned and I have officially moved out as per the 6278



1 conversation. This letter is official notification

2 of the monthly lease on Apartment 208’s

3 termination.”

4 Q. And what is the date of the letter itself?

5 A. March 4th, 2003.

6 Q. Did you, in fact, sign that letter?

7 A. No, I didn’t.

8 Q. Turn the letter over, this document, No. B,

9 over. Is there another letter on that?

10 A. Yes, there is.

11 Q. Is your name on that?

12 A. The printed name is on it.

13 Q. Is there a signature above your printed

14 name?

15 A. Yes, there’s a signature.

16 Q. Is that, in fact, your signature?

17 A. It is not my signature.

18 Q. Read that letter to yourself.

19 A. Okay. Okay.

20 Q. And what does that document say?

21 A. It says, “As per my conversation with

22 Yolanda, the official final liabilities owed to the

23 management is an amount of $850. This is an

24 official receipt of this liability owed to the

25 building manager and fully absolves me of any

26 further payment. Upon signing this form, the

27 management of the apartment building on 807 North

28 Soto Street, Los Angeles, California, for my 6279



1 apartment, Apartment 208, recognizes payment in

2 full, and no other moneys to be received by the

3 management of this building from me, Janet Arvizo.

4 And I am fully free of any debts owed to the

5 management.”

6 Q. All right. Were these letters sent to you?

7 A. Yes.

8 Q. Were they sent -- who sent these letters to

9 you?

10 A. The landlord did.

11 Q. Was that after you had already moved out?

12 A. Yes.

13 Q. Who is it you were talking to about moving

14 out of your apartment? In other words, who at

15 Neverland was it that you were talking to about

16 moving out?

17 A. Frank and Vinnie.

18 Q. At some point in time did you give them the

19 key to that apartment?

20 A. I think they had taken the key from me.

21 Q. I’m --

22 A. I think, maybe. I don’t know.

23 Q. Do you have a recollection of how they got

24 the key?

25 A. No, I don’t remember.

26 Q. What were your feelings about moving out of

27 your apartment at that time?

28 A. Remember how I said I would think about it? 6280



1 Well, at this time now it’s a no.

2 Q. All right. Did you tell them no, you didn’t

3 want to move out of your apartment?

4 A. That’s correct.

5 Q. Do you know where your possessions went to

6 after they moved you out?

7 A. No, I do not.

8 Q. Did they ever tell you where your

9 possessions were moved to?

10 A. No, they didn’t. That’s another reason why

11 I needed Mr. Dickerman’s help after I left

12 Neverland.

13 Q. Did anybody tell you that they were put into

14 storage?

15 A. No.

16 Q. Did you ever return to that apartment on

17 Soto Street after you left Neverland at the time?

18 A. No.

19 Q. Did you talk to anybody at Neverland about

20 the boys being withdrawn from school?

21 A. Until afterwards.

22 Q. I’m sorry, “afterwards” of what?

23 A. Until after they had checked Davellin out.

24 Q. All right. Now, Davellin was going to

25 school where at the time?

26 A. She was going to school at Roosevelt High

27 School, which was down the street from my Soto

28 Street apartment. 6281



1 Q. So that was in East Los Angeles?

2 A. In East L.A. It’s even on Soto Street, the

3 high school.

4 Q. Now, let me back you up just a little bit,

5 before you went off to Miami.

6 A. Okay.

7 Q. I think you had testified that you were

8 living part time at Jay Jackson’s apartment in

9 mid-Wilshire.

10 A. I was visiting.

11 Q. And part time at Soto Street?

12 A. I lived in Soto Street.

13 Q. The address that you used for the boys to go

14 to the school that they were in on Wilshire --

15 A. First they attended Hollenbeck.

16 Q. Okay.

17 A. They attended Hollenbeck. This is a school

18 down the street from Soto Street. And because the

19 boys were not involved in any gangs, they kept

20 getting beat up, because they wouldn’t join any

21 gangs. And so I told Jay about it, and so moved

22 them to another school within the same L.A. school

23 district.

24 Q. And the school that you moved them to was

25 which one?

26 A. John Burroughs.

27 Q. And John Burroughs is located where?

28 A. It’s near Jay’s apartment. 6282



1 Q. Did you use Jay’s address to be able to do

2 that?

3 A. Yes, I did.

4 Q. And --

5 A. And also they became aware of that

6 afterwards, but it was already on the record and

7 they were okay with it.

8 Q. Okay. Now, where were you actually residing

9 during that period of time prior to going to Miami?

10 A. In my East L.A. apartment.

11 Q. All right. Would you spend the nights at

12 Jay’s apartment as well?

13 A. Yes, sir, I did.

14 Q. Can you give us a sense of how many nights a

15 week you would be at the East L.A. apartment and how

16 many nights a week you would be at Jay’s apartment,

17 on average?

18 A. Depending if Jay had to work late or -- it

19 all depended upon Jay’s work.

20 Q. All right. Now, when you stayed at Jay’s

21 apartment during the week, where did Davellin stay?

22 A. She always stood in -- and this is what

23 would happen: We’d all stay there in East L.A.

24 She’d go to school, and then I’d take off on the bus

25 to drop off the boys. And then I’d go to Jay’s

26 apartment, clean his apartment, do anything to --

27 just make myself serviceable.

28 Q. All right. On the nights that you actually 6283



1 stayed overnight at Jay’s apartment --

2 A. Yes.

3 Q. -- during the week, where would Davellin

4 stay?

5 A. Okay. When that would happen, I would -- I

6 would contact my parents, and so since my dad has

7 like a swing shift -- he’s a truck driver, my dad.

8 I would let my parents know, and then so they’d go

9 by the apartment and go pick up Davellin.

10 Q. All right. Let me move you back now to this

11 period from the 2nd to the 10th of March, and back

12 at Neverland again.

13 A. Okay.

14 Q. Did you have a discussion with anybody at

15 Neverland about checking your kids out of school?

16 A. Yes. After Davellin was checked out.

17 Q. All right. Did you have a discussion with

18 anybody about checking Davellin out of school --

19 A. No. No.

20 Q. -- before you checked her out of school?

21 A. No.

22 Q. Did Davellin check out of school?

23 A. They checked Davellin out of school.

24 Q. Did you know that they were doing that in

25 advance?

26 A. No, I did not know.

27 Q. And that was from Roosevelt School?

28 A. That was Roosevelt. 6284



1 Q. In East L.A.?

2 A. East L.A., yes.

3 Q. Now, was Davellin out of school this entire

4 period of time?

5 A. Yeah. They’re off track. So I don’t know

6 if they’re familiar here with “track.”

7 Q. Well, let me see if we can figure this out.

8 From the period of time in early February

9 when you first went to Miami --

10 A. There’s a portion --

11 Q. Hold on. There’s no question pending.

12 A. I’m sorry.

13 Q. From the time you went to Miami in early

14 February until the 10th of March, was Davellin going

15 back to high school at all?

16 A. I think that’s -- I think -- I can’t

17 remember, but I think Davellin was off track. “Off

18 track” means you don’t go to school during that

19 period.

20 Q. This is one of those schools where

21 students --

22 A. Yes.

23 Q. -- attend --

24 A. It’s year-round school.

25 Q. It’s one of those schools where students

26 attend at different times?

27 A. Yes.

28 Q. And it’s sometimes not necessarily in the 6285



1 summertime --

2 A. Yes.

3 Q. -- they are out of school?

4 A. Yes. And I think that’s the best I can

5 remember.

6 Q. Now, as to the boys, did you have a

7 conversation with anybody at Neverland about the

8 boys being checked out of school?

9 A. Okay, this is when Frank and Vinnie holler

10 at me that I have to sign this paper. That’s why it

11 came to a point where my signing days were over. I

12 had to sign a paper for them to check out the boys,

13 but with Davellin, they did it without my signature.

14 They did it themself.

15 Q. I’d like to show you a document now, or a

16 couple documents.

17 If I may approach the witness, Your Honor.

18 THE COURT: Yes.

19 Q. BY MR. ZONEN: Exhibit No. 271 -- do you

20 have a pen there?

21 A. Yes, I do.

22 Q. Exhibit No. 271 for identification, not in

23 evidence, for identification, mark that first one on

24 there “A,” and then we’re going to move on to the

25 second one.

26 Let’s go to 271-B. Mark that “B,” and tell

27 me what that is.

28 A. This one? 6286



1 Q. Yes.

2 A. Okay. It says, “Checkout sheet.”

3 Q. From where?

4 A. From John Burroughs.

5 Q. All right. Is --

6 A. The boys’ -- my boys’ school.

7 Q. John Burroughs Middle School?

8 A. Yes.

9 Q. Is this for one of your sons?

10 A. Yes. This is for Gavin.

11 Q. All right. Is there a date on that?

12 A. It says March 6th, 2003.

13 Q. Is there a signature on that document?

14 A. Yes, there is. It says, “Parent’s

15 signature.”

16 Q. And whose signature is it?

17 A. It’s Vinnie’s.

18 Q. All right. It says “date of birth” on

19 there?

20 A. Yes.

21 Q. Is that Gavin’s birth --

22 A. That is Gavin’s birth date.

23 Q. Does it indicate where the new address is

24 going to be for this child, for this student?

25 A. Yes. It says -- “City” is “Phoenix.” The

26 state is “Arizona.”

27 Q. All right. Is this in your handwriting at

28 all? 6287



1 A. Not in my writing at all.

2 Q. Did you ever see this document?

3 A. I’ve never seen this document before.

4 Q. All right. You -- before today or before

5 the grand jury?

6 A. Before -- I think it was the grand jury. I

7 think that time. Or before --

8 Q. But at the time all this was happening --

9 A. At that time, no.

10 Q. Back on March 6th, 2003 --

11 A. No.

12 Q. -- did you ever see that document?

13 A. No.

14 Q. Now, did anybody talk to you about moving to

15 Arizona, to Phoenix?

16 A. No. Except in that letter, the one -- the

17 letter with the “Phoenix, Arizona,” that you showed

18 me.

19 Q. Oh, all right.

20 A. That one.

21 Q. But conversations?

22 A. Conversation, no.

23 Q. Nobody had a conversation with you at

24 Neverland about you moving to Phoenix, Arizona?

25 A. No, no. Zero.

26 Q. Did either Vinnie or Frank mention Phoenix,

27 Arizona, to you?

28 A. No. Zero. 6288



1 Q. Did either of them indicate where they wrote

2 on these checkout forms where they were moving you

3 to?

4 A. It says right here, “New address.”

5 Q. But in conversations that you may have had

6 with Vinnie and Frank at the time?

7 A. No, no, it was Brazil.

8 Q. This is B.

9 Let’s go to C, if we can, right here. Mark

10 that one “C.”

11 A. This is what I’m talking about.

12 Q. All right. Would you take a look a moment

13 at that document?

14 A. Okay.

15 Q. Have you ever seen that document before?

16 A. Yes, this is the one with --

17 Q. Is your signature on that?

18 A. Yes, this one has my signature.

19 Q. And read that document.

20 A. It says, “I, Janet Arvizo, allow Vincent

21 Armenta to check out my son Gavin Anton Arvizo from

22 John Burroughs” -- I mean, “from Burroughs Middle

23 School. He will be placed in another school

24 district in Phoenix, Arizona, where a current new

25 residence is being sought.”

26 Q. That is your signature?

27 A. Yes, it is.

28 Q. And written -- typed below is the name 6289



1 “Janet Arvizo”?

2 A. Yes.

3 Q. Is this the letter you’re referring to?

4 A. Yes, this is what I was talking about.

5 Q. Now, at the time that you signed that, did

6 you talk to them about, “What’s the business with

7 Phoenix, Arizona?”

8 A. And they said this way nobody would be able

9 to find me or the kids.

10 Q. This is C.

11 Let’s go to D, please.

12 A. Okay.

13 Q. Go ahead and write “D” on that. What is

14 “D”?

15 A. “D” is my driver’s license. Oh, that’s

16 another thing they had.

17 Q. Just tell us what it is right now.

18 A. My driver’s license.

19 Q. And who else?

20 A. Vinnie’s driver’s license.

21 Q. At some point in time did somebody tell you

22 that they needed a copy of your driver’s license?

23 A. No, they took my driver’s license.

24 Q. All right. Who is “they”?

25 A. Frank and Vinnie.

26 Q. Well, did both of them take it?

27 A. Yes. Yes. Frank was present when Vinnie

28 took it. So -- 6290



1 Q. Tell me what you mean by “took it.” What

2 did they do?

3 A. They said, “Let me have your driver’s

4 license.”

5 Q. And did you hand it over to them?

6 A. Yes, I did. At that point I was doing

7 everything they said.

8 Q. Was it about this time that you did that?

9 A. Yes. Yes, I did.

10 MR. ZONEN: Oh, I’m sorry. I’ll do that.

11 Q. Exhibit No. 272. At this time No. 272.

12 Would you tell us what that is, please?

13 A. It’s “John Burroughs Middle School Checkout

14 Sheet.”

15 Q. That’s for who?

16 A. For my son Star.

17 Q. Is this the same form as the one that we had

18 previously looked at for Gavin?

19 A. Yes. And it says, “Star David Arvizo.”

20 Q. His full name is on there?

21 A. Yes, his full name is on there.

22 Q. This one also states you’re going to

23 Phoenix, Arizona?

24 A. This one also states I’m going to Phoenix,

25 Arizona.

26 Q. Put an “A” on that. So that’s 272-A. And

27 we’ll turn it over.

28 A. And the parent’s signature is not mine. 6291



1 Q. There is a spot for parent’s signature?

2 A. Yes.

3 Q. And whose signature is that?

4 A. It’s not mine. It’s Vinnie’s.

5 Q. Did he sign his own name?

6 A. Yes, he did. And it says, “Date of birth:

7 12-11-1990.”

8 Q. Is that, in fact, Star’s birthday?

9 A. Yes, it is.

10 Q. And Vinnie, I’m assuming, is not his parent?

11 A. Yes, it’s -- oh.

12 Q. This is A. This is B.

13 A. Yes.

14 Q. Right here. Mark “B” on that, please.

15 And that document, is that the same

16 document; however, the letter, that’s signed by you,

17 except this one is for Star?

18 A. Exact -- exactly.

19 Q. And that is, in fact, your signature?

20 A. Yes, it is my signature.

21 MR. ZONEN: Your Honor, I would like to move

22 into evidence Exhibit -- Exhibit No. 276, which

23 would be A and B, which is the envelope as well as

24 the letter dealing with the landlord. And I would

25 so move at this time.

26 MR. MESEREAU: No foundation.

27 THE COURT: It’s admitted.

28 MR. ZONEN: I’m sorry, the Court’s ruling? 6292



1 THE COURT: It is admitted.

2 MR. ZONEN: All right. I would also move to

3 introduce into evidence 271, as to B, C, D, and

4 272-A and B.

5 MR. MESEREAU: No objection.

6 THE COURT: It’s admitted.

7 MR. ZONEN: May I publish a few of these

8 documents at this time?

9 THE COURT: Yes.

10 MR. ZONEN: Let’s start with 271-B and C.

11 MR. AUCHINCLOSS: May we have “Input 4,”

12 Your Honor?

13 Q. BY MR. ZONEN: Now, this is the “John

14 Burroughs Middle School Checkout Sheet”; is that

15 right?

16 A. Yes.

17 Q. And who’s “the student”?

18 A. “The student” is Gavin Anton Arvizo.

19 Q. And the printing on that -- the handwritten

20 printing on that, is that yours?

21 A. No, it isn’t.

22 Q. All right. Was this filled out in your

23 presence?

24 A. No.

25 Q. And again, this is a document you did not

26 see until a court proceeding in Santa Barbara?

27 A. Correct.

28 Q. “Parent’s signature,” that’s Vinnie’s? 6293



1 A. Yes.

2 Q. And the date of birth; is that right?

3 A. Yes.

4 Q. And this is the document that indicates

5 “Phoenix, Arizona”?

6 A. Yes.

7 Q. Let’s go to the next one, please.

8 Exhibit C from that same exhibit, is this

9 the letter, then?

10 A. Yes.

11 Q. And that is your signature?

12 A. It is my signature.

13 Q. And then 276-B on the front side -- what

14 happened to our laser?

15 Put it on so both signatures are on there.

16 And then the second down here, where it says

17 “Janet Arvizo,” is that your signature?

18 A. No, it isn’t.

19 Q. All right. Do you know if that is Yolanda

20 Lozalde’s signature?

21 A. Yes, it is.

22 Q. And then turn it over.

23 This is the second letter that you

24 identified. And that signature here, is that your

25 signature?

26 A. No, it isn’t.

27 MR. ZONEN: Okay. You can turn on the

28 lights. 6294



1 Q. I’d like to move you ahead to the 10th of

2 March, if I may.

3 A. Okay.

4 Q. You told us that you had a preexisting

5 schedule requiring a visit again back at Kaiser

6 Hospital; is that right?

7 A. Yes.

8 Q. And what exactly was it that Gavin had to do

9 in preparation for that visit?

10 A. He had to -- okay, well, actually the

11 creatinine clearance, Mr. Zonen, had to be turned in

12 immediately. The creatinine clearance, that had to

13 be turned in immediately after the doctor’s visit,

14 which was way back in February, February 25th.

15 MR. MESEREAU: Objection, Your Honor.

16 Nonresponsive; move to strike.

17 THE COURT: Sustained. Stricken.

18 Q. BY MR. ZONEN: I want to be very specific

19 about the questions that I ask --

20 A. Okay.

21 Q. -- and the answers that you give.

22 A. Okay.

23 Q. The purpose of the visit on the 10th of

24 March was for what?

25 A. Just to check his kidney.

26 Q. And was there a requirement that he had to

27 furnish a urine sample?

28 A. That was required since February 25th. 6295



1 Q. Okay. And why --

2 A. I had to do that the next day.

3 Q. Why didn’t you do it on February 25th?

4 A. Because they didn’t let me. They didn’t

5 want me to go back to Kaiser to turn it in.

6 Q. Did he have an examination that had to take

7 place on the 10th as well?

8 A. Yes.

9 Q. And the examination was to do what?

10 A. Was to check his kidney.

11 Q. All right. Did they, in fact, do that at

12 that time?

13 MR. MESEREAU: Object to the word “they.”

14 Move to strike.

15 THE COURT: Sustained. Stricken.

16 Q. BY MR. ZONEN: Did he have an examination of

17 some kind at Kaiser Hospital on the 10th?

18 A. Yes.

19 Q. And what was the examination that he had?

20 A. To check the inside of his kidney.

21 Q. Were you present during that exam?

22 A. Yes.

23 Q. And did that exam take place?

24 A. And so was Vinnie.

25 Q. And that exam took place?

26 A. Yes.

27 Q. Now, the creatinine clearance, tell us what

28 that is, please. 6296



1 A. The creatinine clearance is a 24-hour urine

2 collection to check on Gavin’s kidney.

3 Q. And was there some piece of equipment that

4 he had to have to collect it in?

5 A. Yes. It’s a big, giant jug that -- it’s

6 made to collect urine.

7 Q. Now, I’m told that this is not a used

8 exhibit.

9 A. Okay.

10 Q. And this is No. 349. Can you tell us if

11 this Exhibit No. 349 is similar or dissimilar --

12 A. It’s similar, but it’s not it.

13 Q. It’s not the same?

14 A. No.

15 Q. Tell us how that is different from the one

16 that you had.

17 A. Okay. It doesn’t have this, this thing, at

18 all. It’s just completely closed.

19 Q. All right. Is the configur -- and the thing

20 that you’re saying, “this thing” --

21 A. The cap. The cap.

22 Q. The cap is different on it?

23 A. Yes.

24 Q. All right. Now, the cap on the one that you

25 had, did it close in the same fashion?

26 A. It closed. It’s completely closed, sealed.

27 Q. So there wasn’t a part that you could open

28 up? 6297



1 A. There is no part that you can open up like

2 that.

3 Q. On the one that you had, did it twist

4 closed?

5 A. Yes.

6 Q. In the same fashion?

7 A. Yes. Yes.

8 Q. Was it --

9 A. It’s similar, the bottle, though.

10 Q. The bottle and the size was similar?

11 A. Yes.

12 Q. The cap on the one that you had, did it

13 close to the same extent?

14 A. Completely sealed, because --

15 Q. You need to wait until the question is asked

16 in its entirety.

17 A. Okay.

18 Q. The top, did it seal closed to the same

19 extent that this one does?

20 A. Yes.

21 Q. So it twisted closed?

22 A. Yes.

23 Q. All right. The one that you had, was it as

24 secure as the one that this is?

25 A. Yes.

26 Q. Okay. All right. Now, was the color the

27 same?

28 A. Yes, just about. 6298



1 Q. All right. Where did you get that

2 particular container, the one that --

3 A. At Kaiser at the laboratory.

4 Q. All right. Was that on the 25th?

5 A. That was on the 25th. And I was supposed to

6 do that --

7 Q. Did you have a specific time schedule for

8 returning it?

9 A. Immediately.

10 Q. All right. And it wasn’t done until the

11 10th?

12 A. It wasn’t done.

13 Q. All right. Whose idea was it to do it

14 around the time of the 10th?

15 MR. MESEREAU: Objection; foundation.

16 THE COURT: Overruled.

17 You may answer.

18 Q. BY MR. ZONEN: Go ahead and answer.

19 A. Every time -- I had done these creatinine

20 clearance already for years, since the year 2000.

21 MR. MESEREAU: Objection; nonresponsive.

22 THE COURT: Sustained.

23 Q. BY MR. ZONEN: Again, you need to listen to

24 the question.

25 A. Okay.

26 Q. Whose idea was it to do it the 10th, you or

27 somebody else?

28 A. I had kept having Gavin do the urine 6299



1 clearance, and every time there was an excuse why it

2 couldn’t get turned in. It was lost; it was -- the

3 urine wasn’t continued --

4 MR. MESEREAU: Objection. Nonresponsive;

5 move to strike.

6 THE WITNESS: That’s my answer.

7 MR. ZONEN: No, you need to listen to the

8 question.

9 THE COURT: Sustained.

10 Q. BY MR. ZONEN: Who decided to do it on the

11 10th?

12 A. I did.

13 Q. All right. That was the question.

14 A. But there was many times before --

15 Q. Hold on.

16 MR. MESEREAU: Move to strike as

17 nonresponsive.

18 MR. ZONEN: Hold on. We’ll take care of it.

19 THE COURT: Sustained.

20 Q. BY MR. ZONEN: You need to listen to the

21 question being asked.

22 Did you then give this container to Gavin to

23 do this urine collection?

24 A. It had been given to him since the 25th.

25 Q. So he had it in his possession?

26 A. Yes. Yes.

27 Q. All right. Did you have a conversation with

28 Gavin about him collecting his urine? 6300



1 A. Yes.

2 Q. At about that time?

3 A. Yes.

4 Q. Was it at least 24 hours prior to your going

5 back to Los Angeles?

6 A. Yes, it had to be.

7 Q. Did you talk with him about collecting the

8 urine during that time?

9 A. Yes. From the doctors.

10 Q. Yes. And, now, this is something he had

11 done previously; is that right?

12 A. Yes. For years already.

13 Q. Now, to your understanding, did he begin

14 collecting his urine?

15 A. He started collecting it from -- from

16 like -- I think it was from the 2nd on, when we

17 returned to Neverland. Because from the 25th to the

18 2nd when we were in the hotel, Frank had taken them

19 away from us, because we weren’t going to go to the

20 doctors anymore.

21 Q. I didn’t understand that. Frank actually

22 took one of these containers away?

23 A. Yes, he took it away from Gavin.

24 Q. At the hotel?

25 A. At the motel.

26 Q. You had one of these at the hotel?

27 A. Yes.

28 Q. Did you have a conversation with Gavin at 6301



1 Neverland about turning in this urine?

2 A. No, I didn’t. I had told Vinnie and Vinnie

3 had told Gavin. It was like I said; no more contact

4 with my children from when we returned to --

5 Q. At some time prior to your going back to Los

6 Angeles, did Gavin call you?

7 A. Yes. On March 10th.

8 Q. All right. Did he say something to you

9 concerning the urine?

10 A. Yes.

11 Q. What --

12 A. It was about 4 a.m.

13 MR. MESEREAU: Objection. Nonresponsive and

14 hearsay.

15 THE COURT: I’ll strike after, “Yes.”

16 Q. BY MR. ZONEN: What did he tell you about

17 his urine sample?

18 MR. MESEREAU: Objection. Hearsay.

19 MR. ZONEN: It would be a spontaneous

20 declaration and an excitable utterance.

21 MR. MESEREAU: No foundation.

22 MR. ZONEN: It also explains the conduct of

23 the parties thereafter.

24 THE COURT: I’ll overrule the objection.

25 Q. BY MR. ZONEN: All right. What did he say

26 to you about the urine sample?

27 A. He called me about 4 a.m., and -- he had

28 phoned into the guesthouse, into the room I was. 6302



1 And he had told me, “Mommy, we need to reschedule,”

2 because this was the end --

3 Q. Just tell us what he said.

4 A. Okay. Every time I wanted to do a

5 creatinine clearance, they would always say no.

6 Finally, I was using this appointment --

7 MR. MESEREAU: Objection. Nonresponsive;

8 move to strike.

9 Q. BY MR. ZONEN: You need to tell us -- the

10 question specifically is, what did Gavin tell you?

11 A. Gavin had called me about 4 a.m., and he had

12 told me that Michael was scared because he had drank

13 some Jesus Juice; that it was going to be detected

14 in his urine.

15 And that’s when I told him, “Baby, what do

16 you mean.”

17 THE COURT: Wait, stop. He just asked what

18 Gavin said.

19 THE WITNESS: Oh, okay.

20 THE COURT: Just stop.

21 Q. BY MR. ZONEN: Did you know what “Jesus

22 Juice” was?

23 A. I had asked what “Jesus Juice” was.

24 Q. Did he tell you what “Jesus Juice” was?

25 A. Wine.

26 Q. Was this the first time you knew that he had

27 been --

28 A. This is the first time. 6303



1 Q. You need to listen to the question.

2 Was this the first time you had learned that

3 Gavin was drinking alcohol?

4 A. Yes.

5 Q. When did you leave to go to the hospital?

6 A. From 4 a.m., I didn’t sleep anymore. It

7 was -- I tried to get them up about 6:00. Nobody

8 could find Gavin, so we left there in the morning.

9 Q. What do you mean, “Nobody could find Gavin”?

10 A. They couldn’t find Gavin.

11 Q. Did --

12 A. The security people. And they said that,

13 “They’re with Michael,” and that was it; that they

14 needed Jesus’s help to locate Michael with the boys.

15 Q. All right. Now, how did you find Gavin that

16 morning? How were you able to find Gavin?

17 A. Well, finally Jesus brought him over.

18 Q. At what time was that?

19 A. That was -- I don’t know. I don’t know. We

20 were supposed to leave Neverland at 7:00, and I know

21 we didn’t because --

22 MR. MESEREAU: Objection. Nonresponsive;

23 move to strike.

24 THE WITNESS: I can’t -- so it had to be

25 after 7:00, because we didn’t leave at --

26 THE COURT: Just a moment.

27 THE WITNESS: Okay. Yes, sir.

28 THE COURT: I’ll strike that. Ask the 6304



1 question again.

2 Q. BY MR. ZONEN: Do you know what time it was

3 you left Neverland?

4 A. No. It was after 7:00, my best estimate.

5 Q. Were you up from four o’clock in the

6 morning?

7 A. Yes.

8 Q. Was Gavin with you when you left?

9 A. Yes. And so was Vinnie.

10 Q. Did you have the container of urine with

11 you?

12 A. Yes.

13 Q. Who was holding on to the container?

14 A. Gavin handed it to me.

15 Q. So you were holding on to it during the

16 drive?

17 A. Yes. Oh, yes, I was.

18 Q. Where were you sitting in the car?

19 A. I was sitting in the front of the car, in

20 the front seat, and Gavin handed it to me.

21 Q. All right. Did you hold on to it for the

22 length of the drive?

23 A. Yes, I did.

24 Q. Where was Gavin sitting?

25 A. Gavin was laid out, passed out in the back

26 seat.

27 Q. He was asleep?

28 A. In deep sleep. 6305



1 Q. And was it Vinnie who was driving?

2 A. Yes. It was Vinnie.

3 Q. Anybody else in the car?

4 A. No. Just me, Vinnie, and -- me, Vinnie and

5 Gavin, and -- and those people.

6 Q. At some point in time, did you stop on your

7 way to the hospital?

8 A. Yes.

9 Q. Why did you stop?

10 A. I -- I had to go -- I had to use the rest

11 room really bad, because I had been drinking the

12 whole entire time to keep me up, so I wouldn’t fall

13 back to sleep.

14 Q. Drinking what?

15 A. I kept drinking coffee.

16 Q. Okay. You had to use the rest room?

17 A. Yes.

18 Q. Where did you stop?

19 A. I stopped at Denny’s, and I tried to hold it

20 so much.

21 Q. Did you -- do you know where it was that you

22 stopped?

23 A. No.

24 Q. The location?

25 A. No.

26 Q. Do you know how long you were in the car at

27 the time that you stopped to use the rest room?

28 A. I don’t know. My best estimate, maybe 6306



1 halfway.

2 Q. Did you then go into the restaurant?

3 A. Yes, I went into Denny’s.

4 Q. When you came back out, where was the car?

5 A. Gone.

6 Q. How long did you wait for the car to return?

7 A. Maybe about -- maybe about not more than

8 five minutes. It was just minutes.

9 Q. Was Gavin still asleep in the back?

10 A. He was asleep.

11 Q. All right. And did you talk to Vinnie about

12 where he had been?

13 A. Yeah. I asked him, “Where did you go?” He

14 says, “Oh, I went driving around.” I’m thinking,

15 “We’ve just been driving for a long time. Why would

16 you need to drive any more?”

17 Q. Did you get back in the car and proceed to

18 the hospital?

19 A. Yes.

20 Q. Did you notice the urine sample at that

21 time?

22 A. Yes.

23 Q. What did you notice about the urine sample?

24 A. I noticed that the bag had been moved a

25 little bit, okay?

26 Q. It was in a bag?

27 A. Yes, in a paper bag, okay?

28 So then I said, “Okay,” so then I picked it 6307



1 up. And when I picked it up -- when it had urine,

2 it’s heavy. And it was light. And there was

3 only -- do I continue?

4 Q. You --

5 A. There was only this much urine in it.

6 Q. All right. Did you ask Vinnie -- was the

7 top sealed back on?

8 A. It was sealed back on and it was like a

9 little bit wet.

10 Q. All right.

11 A. And it wasn’t closed tight, though, because

12 when Gavin had handed it to me, it’s customarily

13 that I always check the cap.

14 MR. MESEREAU: Objection. Move to strike;

15 nonresponsive.

16 THE COURT: Stricken.

17 Q. BY MR. ZONEN: When you noticed that the

18 container was missing, did you say anything to

19 Vinnie?

20 A. The container wasn’t missing. It was --

21 Q. The content of the container was

22 substantially less than before; is that right?

23 A. Yes. I asked him -- it was only this much

24 in there.

25 Q. How much had been in there up to that time?

26 A. Almost this way.

27 Q. And by “this way,” you mean about 90 --

28 A. About this full. 6308



1 Q. About 90 percent full?

2 A. About this full. And then there was this

3 much after I went to Denny’s.

4 Q. Maybe 10 percent full?

5 A. About this much.

6 Q. Okay.

7 A. I don’t know percent.

8 Q. That’s okay.

9 All right. Did you ask him what happened?

10 A. Yes. I said, “What happened?”

11 Q. What did he say?

12 A. And he didn’t answer me. And then he just

13 commented, “Oh, it must have fallen.”

14 Q. I’m sorry?

15 A. He said -- he commented -- because he didn’t

16 answer me. And then he said, “It must have fallen.”

17 And that’s it. I knew at that point, zip the lip.

18 Q. All right. But were you able to tell --

19 MR. MESEREAU: Move to strike;

20 nonresponsive.

21 THE COURT: Stricken.

22 Q. BY MR. ZONEN: Were you able to tell whether

23 urine had spilled into the car or not?

24 A. There was no urine odor, wasn’t wet, nothing

25 like that.

26 Q. You weren’t able to see any evidence that

27 urine spilled inside --

28 A. That’s right. 6309



1 Q. Listen to the question in its entirety.

2 You weren’t able to see any evidence of

3 urine having been spilled anywhere inside the car?

4 A. That’s correct.

5 Q. Did you ask Vinnie to explain how it

6 happened?

7 A. I asked him what happened. He didn’t

8 answer. But afterwards he had commented.

9 Q. What did he comment to you about?

10 A. “It must have fallen.”

11 Q. Did you continue on to Kaiser Hospital?

12 A. Yes, I did. And I stood quiet.

13 Q. And did Gavin, in fact, have the test that

14 he was supposed to have at that time?

15 MR. MESEREAU: Objection; foundation.

16 MR. ZONEN: I’ll withdraw the question.

17 Q. Did Gavin go into the hospital --

18 A. Yes.

19 Q. -- with you?

20 A. Yes.

21 Q. Was Vinnie there?

22 A. Yes.

23 Q. Was the urine sample turned in?

24 A. Yeah. I turned it in and --

25 MR. MESEREAU: Objection. Nonresponsive;

26 move to strike.

27 MR. ZONEN: The question is, was it turned

28 in, and she said yes. 6310



1 THE COURT: The objection is overruled.

2 Q. BY MR. ZONEN: All right. Where did you

3 turn it in?

4 A. In to the laboratory.

5 Q. Did you talk with anybody there about the

6 content of the bottle?

7 A. They said --

8 MR. MESEREAU: Objection; hearsay.

9 Q. BY MR. ZONEN: The question is, did you --

10 A. Yes.

11 Q. Yes or no?

12 Okay. And did you at that time turn it in?

13 A. Yes.

14 Q. Prior to your leaving the car to go to the

15 rest room, how tight was the top of that

16 container --

17 A. It was --

18 Q. Wait till the question is answered (sic).

19 A. Okay.

20 Q. How tight was the top of the container

21 screwed onto the container?

22 A. It was tight.

23 Q. Was that your habit and custom each time?

24 A. It was a habit and custom, because I always

25 had to travel with the urine on a bus, so --

26 Q. Do you know how long you were at the

27 hospital, Kaiser Hospital, with Vinnie and with

28 Gavin? 6311



1 A. Well, when I went to go try to turn that in

2 to the laboratory, and then we went to the

3 appointment, which was in a different building.

4 Q. All right. And after you left that

5 building, where did you go?

6 A. Then I went to the apartment.

7 Q. You went to whose apartment?

8 A. Jay’s apartment.

9 Q. Was Jay there?

10 A. Jay was not there.

11 Q. Was Vinnie with you?

12 A. Vinnie was with me.

13 Q. Was Gavin with you?

14 A. Gavin was with me. But they didn’t go into

15 the apartment.

16 Q. How long did you stay at the apartment?

17 A. Long enough to ask Jay to meet me at the

18 nail shop.

19 Q. All right. Did you call Jay from the nail

20 shop or from the apartment?

21 A. I called him from the apartment and told him

22 to -- you know, because since they’re monitoring my

23 phone calls, like I told you how I would speak to

24 people. And then I told him, “Oh, why don’t you

25 meet me in” -- “at the nail shop.”

26 Q. All right. Did you then go to the nail

27 shop?

28 A. I did go to the nail shop. 6312



1 Q. Was he there when you got there?

2 A. No, he wasn’t there.

3 Q. Did you have whatever they do at a nail shop

4 done?

5 A. No. I had used the -- their phone. I had

6 waited for Vinnie to cross the street, and that’s

7 when I did it.

8 Q. What do they do, manicures at a nail shop?

9 A. They do manicuring and waxing there.

10 Q. Did you have any of that done?

11 A. I had done only a leg wax.

12 Q. Did you have a manicure?

13 A. No.

14 Q. Where was Vinnie while you were having a leg

15 wax done?

16 A. Okay. He had came in --

17 Q. No, no. Where was Vinnie when you were

18 doing --

19 A. Me, Vinnie and Gavin, when we originally

20 arrived at the nail shop, we were all three

21 together.

22 Q. And while you were having this procedure --

23 A. No.

24 Q. -- where was he?

25 A. First Vinnie checked the area out. And then

26 I told her, “I came here for a leg wax.”

27 Q. While you were having the leg wax, where was

28 Vinnie? 6313



1 A. Then he saw that I was going to do the leg

2 wax, and then that’s when he walked across the

3 street.

4 Q. So he left?

5 A. Yes.

6 Q. Where was Gavin?

7 A. With him.

8 Q. He was with him?

9 A. Yes.

10 Q. Did Jay eventually arrive?

11 A. That’s when I called Jay to come.

12 Q. So you called him a second time --

13 A. Yes.

14 Q. -- from the beauty salon?

15 A. Yes.

16 Q. And did he, in fact, come?

17 A. Yes, he did.

18 Q. Now, did you go back with Vinnie?

19 A. No.

20 Q. At some point in time, did Vinnie come back

21 and see Jay?

22 A. Oh, yeah.

23 Q. What happened?

24 A. He turned red.

25 Q. Vinnie did?

26 A. Yes.

27 Q. All right. Did Vinnie say something to Jay

28 or to you? 6314



1 A. He said, “Okay. Let’s go now, Janet.”

2 Q. What did you say in response to that?

3 A. I told him that I kind of wanted to stay

4 since I had a Family Court appointment the next day.

5 And so I told -- I used that as a reason why I could

6 stay, me -- me and Gavin.

7 Q. All right. Did you want to stay with Gavin?

8 A. Yes.

9 Q. Your other two children were still at

10 Neverland?

11 A. Yes. But I had to do everything as if --

12 not to raise suspicion.

13 Q. Did you say something to Vinnie specifically

14 that you were not going back?

15 A. Yes.

16 Q. What did he say?

17 A. “No. That’s not part of the plan.”

18 Q. Now, was Gavin standing there at the time?

19 A. Yes.

20 Q. How was Gavin behaving?

21 A. At that time he’s just -- he’s just

22 observing.

23 Q. All right.

24 A. It’s until he talks to Frank that he gets --

25 he becomes distressed.

26 Q. Are you aware as to whether or not Vinnie

27 got on the phone with anyone?

28 A. Yes, he did. He goes, “I got to call 6315



1 Frank.”

2 Q. And did he, in fact, call Frank?

3 A. Yes, he did.

4 Q. Did he have a conversation with Frank in

5 your presence?

6 A. Yes, he did.

7 Q. Were you able to hear what he was saying to

8 Frank?

9 A. No, but Gavin got on the phone calls.

10 Q. You noticed that Gavin was on the phone as

11 well?

12 A. Yes, because Vinnie wanted to talk to

13 Frank -- to Gavin. Frank wanted to talk to Gavin.

14 Q. Was Jay Jackson there during this

15 conversation?

16 A. Yes.

17 Q. Was Jay Jackson in uniform?

18 A. Yes.

19 Q. And what kind of a uniform does he wear

20 during the day?

21 A. His military uniform. A camouflage.

22 Q. Camouflage. That’s his daily uniform; is

23 that right?

24 A. Yes. That’s his work uniform.

25 Q. At some point in time, was it decided who

26 was going to go back to Neverland and who was going

27 to stay?

28 A. Jay got upset that Frank -- that Vinnie had 6316



1 said no. So then Jay starts -- he starts becoming a

2 little bit -- I don’t know if “confrontational” is a

3 correct word. I don’t know. But a little -- you

4 can see that he’s upset. So I -- and then that’s

5 when Frank -- another time he goes out right there,

6 right outside the nail shop door.

7 And then that’s when I tell Jay, I said,

8 “Please, Jay, please, Davellin and Star are there.

9 Just play along. Just play along.”

10 Q. So who went back to Neverland?

11 A. Vinnie and Gavin.

12 Q. Why did you agree for Gavin to go back to

13 Neverland?

14 A. Well, because. When Vinnie came back, I

15 said, “Vinnie, Vinnie, I just want to spend some

16 time alone with Jay. You know, that kind of stuff.

17 That’s all. You know, we’ll” -- “We’ll see each

18 other back in” -- “in the Family Court.” You know,

19 you just bring all my kids, and I’ll go back. I

20 just kind of want to spend some of that kind of

21 time, quality time, with Jay.”

22 So then when -- when he saw me behave that

23 way, then he says, “Okay.” He agreed to that.

24 Q. All right. Family Court?

25 A. Yeah.

26 Q. All right. Tell us about Family Court. Did

27 you have an appearance in Family Court?

28 A. Oh, yes. 6317



1 Q. And when was that appearance scheduled for?

2 A. It was the next day.

3 Q. And had you already told them about that --

4 A. Yes.

5 Q. -- the Family Court appearance?

6 A. Yes.

7 Q. Who is it that you told about the Family

8 Court appearance?

9 A. Frank and Vinnie knew.

10 Q. Did you know whether or not your children

11 had to be at that appearance at Family Court?

12 A. I knew that they didn’t have to be there.

13 But again, it’s like that orthodontist visit. I had

14 said they had to be there.

15 MR. MESEREAU: Objection. Nonresponsive;

16 move to strike.

17 THE COURT: I’ll strike after, “I knew they

18 didn’t have to be there.”

19 Q. BY MR. ZONEN: The question was whether you

20 knew whether or not the kids had to be there. And

21 the answer was you knew?

22 A. I knew they didn’t have to be there.

23 Q. They didn’t have to be there.

24 Did you tell Frank or Vinnie --

25 A. No, I didn’t tell them that. I told them

26 that they had to be there.

27 Q. And who was it you told, Frank or Vinnie or

28 both? 6318



1 A. Both.

2 Q. What was the purpose of the Family Court

3 session on the 11th?

4 A. Because I was finally going to be awarded

5 support.

6 Q. All right. It was a spousal support, or a

7 child support --

8 A. Spousal support, child support, all that.

9 Q. Were you represented by an attorney during

10 that time?

11 A. Yes, I was.

12 Q. Who was the attorney?

13 A. Michael Manning.

14 Q. Family law lawyer?

15 A. Yes. That I’ve had for years, already

16 years.

17 Q. All right. Did Vinnie represent that he

18 would or would not bring the children back for this

19 appearance?

20 A. He said he will bring all three of my kids

21 back.

22 Q. Did you spend the night in Los Angeles?

23 A. Yes, I did.

24 Q. The next day was the Family Court

25 appearance?

26 A. Yes. And now I’ve told Jay everything that

27 night.

28 Q. So you had a complete conversation? 6319



1 A. Told him everything.

2 Q. All right. Now, did you have an

3 understanding with Vinnie as to how you would get to

4 the Family Court appearance the next day?

5 A. Yes. The condition --

6 Q. Yes or no.

7 A. Oh. Yes.

8 Q. Okay. You’re doing better.

9 A. Okay.

10 Q. All right. Now, at what time was that

11 appearance?

12 A. The appearance, I don’t remember, but maybe

13 8:00 or --

14 Q. It was a morning appearance?

15 A. It was a morning.

16 Q. How were you going to get to the court

17 appearance?

18 A. The condition was Vinnie was going to pick

19 me up and take me there.

20 Q. And the kids?

21 A. With him.

22 Q. All right. Did Vinnie arrive the next

23 morning?

24 A. He did. He went all the way to Neverland

25 and arrived early that morning.

26 Q. All right. When he arrived, did he have the

27 kids with him?

28 A. He had no kids with him. 6320



1 Q. Did he explain to you why the kids weren’t

2 there?

3 A. He said I had to go back.

4 Q. He said you had to go back?

5 A. I had to go back.

6 Q. All right. Did you go to the Family Court

7 appearance with Vinnie?

8 A. I did.

9 Q. And at the conclusion of the Family Court

10 appearance, where did you go?

11 A. I went back to -- I went back to Jay’s.

12 Q. Did he take you back to Jay’s?

13 A. He took me back to Jay’s.

14 Q. You did not go back to Neverland?

15 A. I didn’t go back to Neverland.

16 Q. Did you ever go back to Neverland?

17 A. I never went back to Neverland.

18 Q. Now, this is now the 11th of March; is that

19 right?

20 A. Yes, it is.

21 Q. Did you engage in some effort at this point

22 to get your kids delivered to Los Angeles?

23 A. I did.

24 Q. All right. What was this effort? What did

25 you do?

26 A. When Jay came home, we called Karen Walker,

27 the supervisor of the -- I don’t know. CPS, DCFS,

28 that. And I and Jay both talked to her, and she 6321



1 said, “It’s out of my hands. It’s out of my hands.

2 Go get yourself some legal help. I’m sorry, I can’t

3 help you.” That’s what she said.

4 Q. Was Karen --

5 A. Karen Walker said that.

6 Q. Hold on.

7 Was Karen Walker one of the three that had

8 been to Jay’s --

9 A. Yes.

10 Q. Listen to the whole question.

11 Was Karen Walker one of the three workers

12 who had been to Jay’s apartment on the day of that

13 interview on the 20th?

14 A. Yes.

15 Q. Now, after you called Karen Walker, what did

16 you then do?

17 A. She didn’t help us, me or Jay. We both

18 talked to them, and so we were trying to find a way

19 where we can go get the kids where they wouldn’t do

20 anything before we got the kids.

21 Q. What did you decide to do?

22 A. For my parents to play sick. My --

23 specifically my dad.

24 Q. So did you have one of your parents call

25 Neverland?

26 A. Okay. When Jay returned to work, he called

27 from his work, because now he’s aware that our phone

28 calls are being monitored. 6322



1 Q. So he called from work to whom?

2 A. To my parents.

3 Q. And talked with who, your father?

4 A. With my dad, and -- well, my dad and mom,

5 but my mom speaks only Spanish, so my dad told my

6 mom.

7 Q. Okay. And in that process communicated to

8 them this plan?

9 A. Yes. Yes.

10 Q. Now, were the kids at some point in time

11 then delivered to your parents’ house?

12 A. Yes, I negotiated for my kids. I told them

13 I would give them myself in exchange for my parents

14 being able to see my children.

15 Q. Who did you talk to?

16 A. To Frank.

17 Q. And did you tell him that; that you would --

18 A. Yes.

19 Q. -- go back to Neverland?

20 A. Yes, I negotiated for one hour. One hour.

21 And I got two. And then I got a day. And then I

22 finally got two days.

23 Q. All right. So by the time you got off the

24 phone with Frank, it was understood that your kids

25 would visit for how long?

26 A. For two days.

27 Q. And that was a conversation that you had

28 with Frank? 6323



1 A. With Frank.

2 Q. And you were placing that phone call to

3 Frank, or he called you? Which?

4 A. Let me see. I had originally -- as Jay’s

5 calling my parents, I’m calling Frank. And I’m

6 letting him know.

7 Q. So you called Frank?

8 A. Yes.

9 Q. And you called from which telephone?

10 A. From Jay’s apartment.

11 Q. And you called Frank on the number that you

12 had for him?

13 A. I think -- I don’t know whether it was his

14 number or Neverland number, but on the other line

15 was Frank, on the other end of the line.

16 Q. Were your kids, in fact, delivered to your

17 parents?

18 A. Yes.

19 Q. Was it that day or the next day?

20 A. That day.

21 Q. Were you present at the time --

22 A. And I was made aware that our every step is

23 being watched.

24 MR. MESEREAU: Objection. Move to strike;

25 nonresponsive.

26 THE COURT: Stricken.

27 Q. BY MR. ZONEN: Were you there at the time

28 your kids were delivered to your parents’ house? 6324



1 A. No, I was --

2 Q. Do you know what time it was that you

3 finally saw your kids?

4 A. In the evening.

5 Q. Did you go with Jay?

6 A. Yes.

7 Q. All right. At the time you got to your

8 parents’ house, who is present? Who was there?

9 A. My mom and dad and my three children.

10 Q. How were your children behaving at that

11 time? Let me be more specific. How was Gavin

12 behaving at the time you got there?

13 A. They were not my kids anymore.

14 Q. Well, describe Gavin’s behavior

15 specifically, how he was behaving.

16 A. He didn’t want to talk to Jay.

17 Q. We’re talking about Gavin right now.

18 A. Yeah.

19 Q. Describe Gavin’s behavior specifically.

20 A. Angry, violent. Yeah.

21 Q. Did you tell him that he was not going back

22 to Neverland?

23 A. Yeah.

24 Q. And you say “angry” and “violent.” What do

25 you mean? Describe what he was doing or what he was

26 saying.

27 A. Just hollering, telling me that -- yelling

28 at me at the top of his lungs that Michael loves 6325



1 him, and that he had to go back.

2 Q. All right. Were you the one telling him he

3 wasn’t going back?

4 A. That’s right.

5 Q. How long did his behavior continue that way?

6 A. For hours.

7 Q. How long was it before his behavior was back

8 to normal?

9 MR. MESEREAU: Objection. Assumes facts not

10 in evidence; no foundation.

11 THE COURT: Overruled.

12 Q. BY MR. ZONEN: You can answer the question.

13 A. It took a long time.

14 Q. And what is that, “a long time”? Give me a

15 sense of it.

16 A. I can’t.

17 Q. Are we talking about days or weeks or

18 months?

19 A. It took weeks.

20 Q. Weeks?

21 When did you tell either Frank or Vinnie

22 that none of you were going back to Neverland?

23 A. Excuse me. I didn’t call Frank or Vinnie.

24 We contacted Jesus the very next day.

25 Q. You contacted Jesus?

26 A. Yes.

27 Q. Did you tell him?

28 A. Yes. 6326



1 Q. All right. What happened after you told

2 Jesus?

3 A. And we weren’t coming back. And the only

4 reason we contacted Jesus was because when the

5 children were leaving, Frank had taken away all of

6 the new clothes that they had purchased, plus some

7 of my children’s clothing also in the -- in the

8 removing the new clothes, because Frank had told

9 them that they had to come back if they wanted their

10 new clothes.

11 Q. When they came to your mother’s house, do

12 you know if they actually had anything with them

13 when they came?

14 A. Gavin wasn’t allowed to bring nothing.

15 Zero.

16 Q. And how about the other two?

17 A. The other two did bring their luggages and

18 my bag with them.

19 Q. Did you start receiving telephone calls or

20 visits?

21 A. Yes.

22 Q. All right.

23 A. Immediately.

24 Q. And in terms of visits, who was it who came

25 to the house?

26 A. It wasn’t visiting. It was -- it was

27 following us in a very, very visual way. Knocks.

28 Throwing rocks. Following us. Very -- they weren’t 6327



1 hiding about it. They were in-my-face type of

2 attitude.

3 Q. Do you know --

4 A. To come back.

5 Q. Are we talking about people who now are new,

6 people-you-hadn’t-seen people, or --

7 A. Okay.

8 Q. Wait till the question is answered (sic).

9 A. Okay.

10 Q. Are you talking about people you hadn’t seen

11 before or people that you were familiar with?

12 A. People that I hadn’t seen before. And also,

13 in addition to that, new ones.

14 Q. Among the people that you had seen before,

15 tell us who they were.

16 A. The people that I seen before was Johnny,

17 Frank and Vinnie. And then some other people.

18 Q. You actually saw Frank and Vinnie at some

19 location?

20 A. Yes, yes.

21 Q. Where?

22 A. At Jay’s apartment. And I knew it, because

23 I looked through the peephole.

24 Q. Did you stay at your parents’ house?

25 A. No.

26 Q. Did you go to Jay’s?

27 A. Jay’s.

28 Q. Did you stay anyplace but Jay’s thereafter? 6328



1 A. Only Jay’s. And I enrolled Davellin,

2 because I believe in, you know --

3 Q. No, the question is whether you stayed at

4 some other location.

5 A. No, just Jay’s.

6 Q. For what period of time did you stay at

7 Jay’s?

8 A. From that point on, till now.

9 Q. Your Soto Street apartment was now vacated?

10 A. Gone.

11 Q. You said that you saw Frank and Vinnie at

12 Jay’s. Did you actually talk to them?

13 A. No. I didn’t open the door.

14 Q. You saw them through the peephole?

15 A. Yes, I did.

16 Q. Both of them together or on different

17 occasions?

18 A. Well, on this occasion they were both

19 together.

20 Q. Were they saying anything to you?

21 A. Yeah. “Open the door.” Just knocking.

22 MR. MESEREAU: Objection. Move to strike;

23 vague.

24 THE COURT: Sustained.

25 Q. BY MR. ZONEN: Do you know who it was who

26 was talking to you through the door?

27 A. Frank. I could see him through the -- I

28 could see everything. 6329



1 Q. Were you able to hear his voice?

2 A. Yes.

3 Q. You could hear what he was saying?

4 A. Yes.

5 Q. And did you recognize his voice?

6 A. Yes.

7 Q. Did you engage either one of them in

8 conversation through the door?

9 A. No. Zero.

10 Q. Did you acknowledge to them that you were

11 there?

12 A. No. Didn’t even want to let them know that

13 I was there. But they knew. Because Frank was

14 saying, “I know you’re in there.”

15 Q. Were you receiving telephone calls as well?

16 A. Yes.

17 Q. Continuously?

18 A. Continuously.

19 Q. Were you answering any of the calls?

20 A. No. No more answering.

21 Q. Did you have any conversation with Vinnie or

22 Frank?

23 A. No.

24 Q. Did you ever see Johnny?

25 A. Yes.

26 Q. Okay. Where did you see Johnny?

27 A. On my front door. And also there was one

28 time when I was watching through the peephole, he 6330



1 had slipped a note through the side of Jay’s

2 apartment. Before -- before they had put this thing

3 around there, it was open all the way around, and so

4 he slipped a note through there. And I saw him

5 writing it.

6 MR. ZONEN: May I approach the witness?

7 THE COURT: Yes.

8 Q. BY MR. ZONEN: Exhibit No. 277, please, for

9 identification, have you seen that exhibit before?

10 A. Yes, I have.

11 Q. Is that the note that you just described?

12 A. Yes, this -- this is the note.

13 Q. And how do you know that it was Johnny who

14 left that note?

15 A. Because I’m looking at him while he’s

16 writing it. I’m looking at him as he’s slipping it

17 in.

18 Q. Okay. And he left that note where?

19 A. At Jay’s apartment.

20 Q. And that’s the note you then turned over to

21 law enforcement?

22 A. Yes, I did.

23 MR. ZONEN: Move to --

24 THE WITNESS: I put it in --

25 MR. ZONEN: Move to admit that exhibit into

26 evidence, please.

27 MR. MESEREAU: No objection.

28 THE COURT: It’s admitted. 6331



1 MR. ZONEN: Your Honor, may I publish that

2 note, please?

3 THE COURT: Yes.

4 Q. BY MR. ZONEN: Now, it appears there’s

5 something on the front and on the back; is that

6 correct?

7 A. Yes.

8 Q. What is the back part? I’m assuming that’s

9 the back. What does that say?

10 A. It says, “To Star or Gavin.”

11 Q. And then on the front it says?

12 A. It says, “Please call Frank, Vinnie, at

13 emergency, 1-805-686-5466.” And it says “Now,” and

14 it’s underlined.

15 Q. The top part’s in red. “Now” is in what

16 color?

17 A. Blue.

18 Q. And the back, “To Star or Gavin,” is?

19 A. In black.

20 Q. Is that the front of the note that’s 277,

21 Exhibit 277? Miss Arvizo, is that, in fact, what

22 we’re looking at, the same thing?

23 A. Yes. Yes.

24 Q. And I’m going to turn it over at this time.

25 And this is the part that says, “To Star or

26 Gavin”?

27 A. Yes.

28 Q. Now, in response to that note, did you call 6332



1 either Star or Gavin?

2 A. No. No.

3 Q. I’m sorry, did you -- did you call either

4 Frank or Vinnie in response to that?

5 A. No more. And then --

6 Q. Do you recall at this point you had any

7 conversations with Frank or Vinnie?

8 A. No more.

9 Q. For what period of time did this continue,

10 the phone calls and things like that?

11 A. It -- it went for months.

12 Q. You said at one point stones were thrown?

13 A. Yes. At my mom’s house.

14 Q. Did you ever see who was doing that?

15 A. No, I didn’t. Davellin saw him.

16 Q. All right. But you were not present at the

17 time it happened?

18 A. No. It was my mom and Davellin present.

19 Q. Now, I think that you had also said that

20 people were following you?

21 A. Yes.

22 Q. How did you become aware of the fact that

23 people were following you?

24 A. Because now they were in my face.

25 Q. And explain what that means.

26 A. Meaning before, everything was being done a

27 little bit -- a little bit secretly. And now it

28 was -- I mean, it was more intimidating than it was 6333



1 before. That’s the best I can say.

2 MR. MESEREAU: Objection. Move to strike;

3 nonresponsive.

4 THE COURT: Overruled. Next question.

5 Q. BY MR. ZONEN: Could you tell who it was who

6 was following you?

7 A. Yes. Johnny. And then some of those other

8 people that I had told you I never came to know who

9 they were. And this is the first time I also saw a

10 female and -- because the rest were always male.

11 And then --

12 Q. Did you recognize any of them, other than

13 Johnny?

14 A. Only Johnny. And then -- and then they were

15 replaced by some other people.

16 Q. How were you aware of the fact that people

17 were following you? I mean, what is it that you

18 noticed specifically?

19 A. Well, I’m in the lane, they change the lane.

20 I’m in a lane, they change a lane. I get off, they

21 get off. I go to my under -- Jay’s underground

22 parking, they’re right there. When I’m -- when

23 Gavin went to church, one of these -- there’s --

24 there’s -- I don’t know what kind of camera, but

25 it’s kind of like this, right there. Just right

26 there, showing me that they’re doing it.

27 Q. All right. Now, at some point in time, were

28 you actually shown video images of yourself and your 6334



1 family?

2 A. Barely now. Just the other day. Mr. Zonen

3 showed it to me.

4 Q. All right. Did you see other images at the

5 time of the grand jury?

6 A. No --

7 Q. Okay.

8 A. -- I didn’t.

9 Q. You have no recollection of seeing other

10 images?

11 A. No.

12 MR. ZONEN: All right. Your Honor, Exhibit

13 No. 813 is a DVD. I’ve consulted with counsel.

14 We’ve agreed it can be played at this time. There’s

15 no sound, so there’s no transcript.

16 Q. Now, you’ve had an opportunity to view these

17 images in advance; is that correct?

18 A. Yes. Yes, Mr. Zonen.

19 Q. And you have recognized the people in it; is

20 that correct?

21 A. Yes.

22 THE COURT: How long is it?

23 MR. ZONEN: I’m sorry?

24 THE COURT: How long is it?

25 MR. ZONEN: Five minutes. Five, six

26 minutes. About that, I think. If we can, let’s go

27 ahead.

28 Q. Excuse me one second. 6335



1 Part of this, as well, is of your apartment

2 on Soto Street, is it not?

3 A. Yes.

4 Q. There appears to be people moving your

5 things out?

6 A. Yes.

7 Q. And that’s at the very end of it?

8 A. Yes.

9 MR. ZONEN: Let me revise it. I think it’s

10 more like ten minutes.

11 THE COURT: Is this the PC, “No. 1”?

12 MR. AUCHINCLOSS: It is, Your Honor.

13 THE COURT: You’re ready?

14 MR. AUCHINCLOSS: Yes.

15 MR. ZONEN: We’re ready.

16 (Whereupon, a portion of a DVD, Plaintiff’s

17 Exhibit No. 813, was played for the Court and jury.)

18 MR. MESEREAU: Your Honor, they added the

19 title to that. I didn’t approve that. That’s

20 nothing we’ve seen before. Mr. Zonen added it.

21 It’s not part of the original, so we object to this.

22 MR. ZONEN: Well, I -- all right.

23 MR. MESEREAU: We object on foundation and

24 authenticity and that it’s been tampered with.

25 THE COURT: All right. The --

26 MR. ZONEN: I’d like to be heard on that

27 issue.

28 THE COURT: You may, but -- maybe what we’ll 6336



1 do --

2 MR. ZONEN: All right. There is --

3 THE COURT: I think we’ll -- I think we’ll

4 excuse the jury, and let you discuss it with me.

5 That way they’ll get a little extra break here.

6

7 (The following proceedings were held in

8 open court outside the presence and hearing of the

9 jury:)

10

11 THE COURT: Okay.

12 MR. ZONEN: Are we back in session?

13 THE COURT: We are back in session.

14 Mr. Mesereau.

15 MR. MESEREAU: Yes, Your Honor.

16 THE COURT: Maybe you want to -- can you move

17 it back to the opening screen so we can look at what

18 the objection was about?

19 MR. ZONEN: While he’s doing it, I can

20 explain what the understanding was that we had that

21 preexisted the showing.

22 MR. AUCHINCLOSS: It’s up, Your Honor, if

23 you go to “Input 1.”

24 THE COURT: This is what you were objecting

25 to, Mr. Mesereau?

26 MR. MESEREAU: Yes, Your Honor.

27 MR. ZONEN: I explained --

28 THE COURT: Could I have Mr. Mesereau’s 6337



1 objection, so I fully understand it?

2 MR. MESEREAU: Yes, Your Honor.

3 This particular wording is not part of the

4 original tape. It’s been added by the prosecution.

5 It was not disclosed to me. It was done to

6 influence the jury. There’s been no foundation laid

7 that these are Brad Miller’s surveillance tapes at

8 all. The numbers have been added by them.

9 THE COURT: So, to be specific, what we’re

10 looking at is the “Brad Miller Surveillance

11 Videotape, Item 811, 812, 816 and 815,” and that was

12 not on the --

13 MR. MESEREAU: No, not --

14 THE COURT: -- not on the DVD that you saw?

15 MR. MESEREAU: Not that I have seen.

16 They have laid no foundation to prove that

17 Brad Miller arranged to have these tapes made. They

18 have thrown different names around, Johnny and Asaf,

19 et cetera. They have not ever proven who these

20 people actually worked for. They haven’t proven who

21 did the surveillance. They haven’t laid a

22 foundation to where they found these tapes and

23 whether or not they’ve been tampered with. There’s

24 no authenticity. There’s no foundation. There’s no

25 logical connection, and they basically tampered with

26 the tapes by adding these words.

27 THE COURT: Was there an agreement.

28 MR. MESEREAU: Not to have this. That’s a 6338



1 surprise to me.

2 THE COURT: All right.

3 MR. ZONEN: Well, counsel knows that they’re

4 not tampered with at all.

5 And furthermore, we had a discussion in

6 advance of showing this where I explained to counsel

7 that there were two witnesses who will subsequently

8 lay a foundation. The first witness who will

9 testify that these -- that this is a compilation of

10 tapes that were -- it’s -- it’s put now onto one DVD

11 that were, in fact, a compilation of tapes that were

12 seized from - guess where? - Brad Miller’s office.

13 And the second witness will be the one who actually

14 seized the tapes from Brad Miller’s office.

15 All right. Now, the content of the

16 surveillance thereafter is identical. Nobody has

17 touched anything on there, and counsel knows that.

18 My --

19 MR. MESEREAU: I don’t know that.

20 MR. ZONEN: I had asked him if it would be

21 agreeable that we could show this in advance of the

22 other two witnesses laying the foundation; one, that

23 they were seized from Brad Miller’s office; and

24 number two, that they were compiled into one DVD for

25 ease of showing at this time, and he agreed to that.

26 My suggestion at this time is that you

27 instruct the jury to disregard this frame on it, and

28 we will commence the showing from the point where 6339



1 the car is in -- in session.

2 MR. MESEREAU: We object on foundational and

3 authenticity, Your Honor. And we’d ask that the

4 individual tapes be played, not their concoction.

5 MR. ZONEN: Well, you know, I had asked his

6 permission and he gave it to me to do so.

7 MR. MESEREAU: To play videotapes.

8 MR. ZONEN: Wait a second.

9 I am relying upon his representation of what

10 he said he was agreeing for us to do.

11 THE COURT: Sounds like he thought you were

12 going to play two separate --

13 MR. ZONEN: No, he didn’t. I made it --

14 MR. MESEREAU: Yes, I did. Nowhere was this

15 ever described to me.

16 MR. ZONEN: I made it very clear that we

17 compiled it into one DVD. Now, this I did not say.

18 This I didn’t know was going to be shown.

19 THE COURT: What’s the -- what’s the

20 compilation? Is it a serial, just the first one and

21 then the second one?

22 MR. ZONEN: Yes; one right after the other.

23 THE COURT: You intermixed the two?

24 MR. ZONEN: We can show it to you right now.

25 It only takes a couple minutes, if you’d like to see

26 it.

27 THE COURT: I thought you said ten minutes.

28 MR. ZONEN: The bulk of it is the cleaning 6340



1 out of the apartment, which is one separate tape,

2 but the initial surveillance is less than five

3 minutes, of different segments of surveillance.

4 MR. MESEREAU: I might suggest, Your Honor,

5 that the cleaning out of the apartment, as I

6 understand it, was to show what was being moved in

7 or out, and it’s not a surveillance tape. That is

8 their concoction.

9 MR. ZONEN: Once again, this was something

10 counsel approved of.

11 MR. MESEREAU: No, I didn’t.

12 MR. ZONEN: He’s lying. That’s simply not

13 true.

14 MR. MESEREAU: He’s lying.

15 THE COURT: All right.

16 MR. ZONEN: I’ll take a polygraph.

17 MR. MESEREAU: You’ll fail it.

18 THE COURT: Just a moment. I don’t want to

19 hear anything like that. You don’t accuse each

20 other of lying. There’s a misunderstanding here.

21 You’ve added something. And that’s not professional

22 conduct. I won’t put up with that.

23 Do you understand, Mr. Zonen?

24 MR. ZONEN: Yes.

25 THE COURT: And you are not to respond to

26 him. You two talk to me.

27 MR. MESEREAU: I apologize, Your Honor.

28 THE COURT: Now, I think what we’ll do is, 6341



1 I will explain to the jury that the initial title of

2 the tape was added by the District Attorney, and

3 they’re to disregard that; that this is a

4 compilation of two separate videos, and that it’s

5 being entered with --

6 MR. ZONEN: Let me have just one moment,

7 please. Let me have one moment.

8 MR. MESEREAU: If I may, Your Honor, it’s

9 four videos they’re made to look like one. They’re

10 not one at all.

11 MR. ZONEN: Let me have just one moment.

12 THE COURT: All right.

13 (Off-the-record discussion held at counsel

14 table.)

15 MR. MESEREAU: If I may address the Court,

16 Your Honor.

17 THE COURT: Wait till he’s through with his

18 conference.

19 MR. MESEREAU: Sure.

20 (Off-the-record discussion held at counsel

21 table.)

22 MR. ZONEN: Your Honor, we’re going to play

23 the original ones. We’re going -- as soon as we get

24 it. We will not play this one. We will do the

25 originals. We don’t have them here. We’re going to

26 make arrangements to get them as quickly as we can.

27 THE COURT: All right. I think I -- I think

28 I find that to be an acceptable way to proceed. I 6342



1 do want to tell the jury, though, when they come

2 back in that the initial title they saw was, in

3 fact, added by you, and not part of the seized

4 tapes. They were tapes, right?

5 MR. ZONEN: Yes. The original videotapes

6 have been transposed to a DVD.

7 THE COURT: Okay.

8 MR. MESEREAU: Thank you, Your Honor.

9 MR. SNEDDON: Ron?

10 Can I just have one moment?

11 THE COURT: Yes.

12 (Off-the-record discussion held at counsel

13 table.)

14 MR. ZONEN: The problem that we’re dealing

15 with at this moment is that all of the detectives

16 are currently at a funeral, and I’m not sure that

17 we’re going to be able to get -- are we --

18 THE COURT: Let me tell you, what we’ll do

19 is, you know, we’ll start our break now that we

20 normally take at 1:15. So, the jury’s already out,

21 so we won’t bring them back in. And we’ll just

22 start our break, and take a -- let’s take a

23 20-minute break, and then you can decide how you’re

24 going to proceed on the break.

25 What we do know is you’re not going to --

26 MR. ZONEN: I will be not showing this one.

27 I will show the originals.

28 THE COURT: And I do want to remember, when 6343



1 they come back in, to tell them to disregard the

2 opening title. And -- okay? Any objection to that?

3 MR. MESEREAU: No, Your Honor.

4 THE COURT: All right. Let’s start our

5 break, then.

6 MR. AUCHINCLOSS: Can you go to “Black

7 Screen,” Your Honor? Thank you.

8 (Recess taken.)

9

10 (The following proceedings were held in

11 open court in the presence and hearing of the

12 jury:)

13

14 THE COURT: Go ahead.

15 MR. ZONEN: Your Honor, we’re going to

16 withdraw this exhibit at this time and we’re going

17 to play it tomorrow morning.

18 THE COURT: (To the jury) All right. On the

19 exhibit that we started to show you just before the

20 break, there was a label, a heading on it, and the

21 label was not part of the seized exhibit. It was

22 added by the District Attorney as a title, and I’m

23 going to instruct you to disregard that label and do

24 not consider it in any way in your deliberations in

25 the case. And you’ll -- you will see the material

26 but it will come in in a different form than it was

27 going to come in today.

28 All right. You may proceed. 6344



1 MR. ZONEN: Thank you.

2

3 DIRECT EXAMINATION (Resumed)

4 BY MR. ZONEN:

5 Q. Miss Arvizo, by the time that you got back

6 to El Monte and then back to your residence in Los

7 Angeles, how long had the children been out of

8 school?

9 A. About less than two months. Less than.

10 Q. Did they have any instruction during that

11 period of time at all?

12 A. None. Zero.

13 Q. Did you have, during that period of time,

14 a conversation with either Michael Jackson or Vinnie

15 or Frank about them getting tutoring?

16 A. Yeah. We had to go to Brazil if we wanted

17 to get tutored.

18 Q. Who was that you had a conversation with?

19 A. With Frank and Vinnie.

20 Q. At different times or together?

21 A. Different times, together.

22 Q. What did Frank tell you specifically about

23 tutoring?

24 A. That if I wanted a tutor for my children,

25 that we had to leave the country and go to Brazil;

26 that they could provide a tutor there. Everything

27 was always Brazil.

28 Q. All right. Was there any mention by either 6345



1 Frank or Vinnie that a tutor had already been

2 arranged in Brazil?

3 A. I can’t remember that.

4 Q. All right. Did either one of them tell you

5 where specifically in Brazil you were going to be

6 going?

7 A. Yes.

8 Q. Where?

9 A. In Brazil, it had to be in a place where

10 there was no American hotels, no hotels, so no one

11 could notice me and my children.

12 Q. Did they tell you whether any of them,

13 meaning Frank or Vinnie, would be going with you to

14 Brazil?

15 A. Yes. Frank and Vinnie and Brad Miller and

16 Marc Schaffel had already prepared an apartment full

17 of surveillance and everything there. This is what

18 Frank and Vinnie told me.

19 Q. Did they tell you what city in Brazil?

20 A. No. They did tell me that it was away from

21 any hotel.

22 Q. Did they tell you what size city or

23 community or town you would be going to?

24 A. No.

25 Q. Did they tell you how long you would be

26 there?

27 A. Until they did damage control for Mr.

28 Jackson. And I followed everything that they said. 6346



1 There may be a possibility that I could come back,

2 depending on what I did.

3 Q. Did they actually tell you in terms of days

4 or weeks or months?

5 A. At this point, no. It was until they

6 decided.

7 Q. Did they tell you whether or not Mr. Jackson

8 would be joining you there in Brazil?

9 A. No. Mr. Jackson would not be joining us

10 there.

11 Q. Did either of them say that specifically?

12 A. Yes.

13 Q. Who?

14 A. Frank and Vinnie. And remember, this is an

15 evolution, different times --

16 MR. MESEREAU: Objection; move to strike her

17 comments.

18 THE COURT: I’ll strike the last sentence.

19 Q. BY MR. ZONEN: Do you recall when the

20 conversation was specifically with Frank about

21 whether or not Michael Jackson would be joining you

22 there?

23 A. That was towards the end. There was going

24 to be just me and my kids, and -- in the apartment

25 that Brad Miller, Marc Schaffel had prepared full of

26 high-tech monitoring surveilling system, surveilling

27 me and the kids, and --

28 Q. Did your two sons and Davellin enroll back 6347



1 in school again?

2 A. Yes, I enrolled them back in school.

3 Q. Which school did the boys enroll in?

4 A. The boys re -- I reenrolled them back into

5 John Burroughs.

6 Q. Did you continue living at the St. Andrews

7 apartment?

8 A. I now began living in the St. Andrews

9 apartment.

10 Q. Full time?

11 A. Full time in a one-bedroom apartment, now

12 with Jay.

13 Q. Where did Davellin reenroll in?

14 A. I enrolled her in a high school near my

15 mom’s out in El Monte.

16 Q. This is a different high school --

17 A. Different high school.

18 Q. Hold on. Wait till the question is asked.

19 This is a different high school than the one

20 prior to going to Miami?

21 A. That’s correct, it’s a different high school

22 now.

23 Q. And which high school was it in El Monte?

24 A. Now it’s Mountain View High School.

25 Q. And did she live with your parents?

26 A. Now my daughter began living with my

27 parents.

28 Q. Where does she live now? 6348



1 A. My -- my daughter lives with us now.

2 Q. Were you able to get your possessions back?

3 A. Until the police got involved.

4 Q. Did you know -- by “possessions,” I mean

5 your possessions from the Soto Street address.

6 A. That’s correct.

7 Q. What did you have at the Soto Street address

8 at the time that it was moved from that location?

9 A. All my stuff. All my stuff from my

10 apartment.

11 Q. What do you mean by “stuff”?

12 A. My furniture, the -- what was still there,

13 because some -- some of these things got rid of.

14 Q. All right.

15 A. Our clothing. Our --

16 Let me see. What else?

17 Q. Did you have furniture?

18 A. No. The only thing that they left in there

19 was my kitchen table with my kitchen chairs.

20 Q. All right. But was there some understanding

21 with either Frank or Vinnie or somebody else that

22 your possessions would either be stored or moved?

23 A. No. At this point it was a no. Remember I

24 said I would think about it? And then I finally

25 said no.

26 Q. When you finally got your possessions back,

27 was what was returned to you everything that existed

28 in the apartment? 6349



1 A. No.

2 Q. What was missing?

3 A. What was missing was all of -- everything to

4 do with Mr. Jackson. Everything.

5 Q. How about furnishings, furniture?

6 A. My kitchen table, my chairs were returned

7 back to me.

8 Q. Okay.

9 A. My children’s clothing, my clothing. My

10 pictures that were hanging on my wall.

11 Q. Were returned?

12 A. Were returned.

13 Q. Okay.

14 A. And -- but all the stuff that Mr. Jackson

15 had given Gavin were gone.

16 Q. Did you have kitchen appliances of sorts?

17 A. Yes, I did.

18 Q. Pots and pans?

19 A. Yes, I did.

20 Q. Silverware?

21 A. Yes, I did.

22 Q. Plates?

23 A. Yes.

24 Q. Cups?

25 A. Yes.

26 Q. Was that all returned?

27 A. Yes.

28 Q. Prior to going to Miami had you moved any of 6350



1 your possessions to Jay’s apartment?

2 A. No.

3 Q. Did you seek help from anybody in an effort

4 to get your property back?

5 A. Yes, I did.

6 Q. Who?

7 A. From Mr. Dickerman.

8 Q. Before contacting Mr. Dickerman, did you

9 contact anybody from Neverland to --

10 A. No.

11 Q. Wait till the whole question’s asked.

12 A. Uh-huh.

13 Q. Before contacting Mr. Dickerman, did you

14 contact anybody from Neverland in an effort to get

15 your property returned?

16 A. No way.

17 Q. Did you have any other conversations with

18 anybody from Neverland after you left?

19 A. No.

20 Q. Did you know where your possessions were?

21 A. No, I didn’t.

22 Q. Did Mr. Dickerman write a number of letters

23 on your behalf?

24 A. Yes, he did.

25 Q. Did you read those letters?

26 A. Yes, I did.

27 Q. Had you noted -- had you seen your passports

28 prior -- well, you answered that you had seen them 6351



1 with Frank; is that right?

2 A. No. Vinnie.

3 Q. I’m sorry, with Vinnie.

4 A. Yes.

5 Q. Were your passports among the items that

6 were requested to be returned?

7 A. Yes.

8 Q. And I assume they were not returned to you?

9 A. They weren’t. They weren’t.

10 Q. Were there other personal items that were

11 requested returned?

12 A. Yes. The children’s clothing. That’s one

13 of them.

14 Q. Was there something else that you wanted Mr.

15 Dickerman to do on your behalf?

16 A. Yes. For Michael’s people to stop following

17 us; that we did not want to go back. To get the

18 message, “Please, leave us alone.”

19 Q. Was that communicated in the form of a

20 letter as well?

21 A. Yes, it was.

22 Q. And do you know to whom those letters were

23 sent?

24 A. To Mr. Geragos.

25 Q. Mark Geragos?

26 A. Yes.

27 Q. Do you know if your children were still

28 appearing on television in that production “Living 6352



1 with Michael Jackson”?

2 A. Yes, they were.

3 Q. How do you know that?

4 A. Because Mr. Dickerman had told me, Jamie had

5 told me.

6 Q. Others were telling you --

7 A. Others were telling us.

8 Q. -- that it was still being featured?

9 A. Yes.

10 Q. Did Mr. Dickerman on your behalf attempt to

11 get your children off television?

12 A. Yes, he did.

13 Q. At some point in time -- I’d like to move

14 back one second, if I could.

15 I believe that you had testified that the

16 workers, the social workers from the Department of

17 Child & Family Services, that interview was

18 conducted on the 20th in the morning hours; is that

19 correct?

20 A. Yes.

21 Q. Did you see any of them the next day?

22 A. Yes, I did. On the 21st I did.

23 Q. Who did you see on the 21st?

24 A. I saw Karen Walker, the supervisor.

25 Q. What was the purpose of that meeting?

26 A. She had called -- like I had mentioned

27 before, all my phone calls was being monitored every

28 day, 24 hours a day. Monitored, listened, 6353



1 surveilled, watched, followed. Everything.

2 She had came -- she requested that I sign a

3 paper that said I understood the language in

4 English. Bilingual form.

5 Q. All right.

6 A. Over the phone. So I went ahead, I said,

7 “Yes, please come.”

8 Q. And did you sign that document?

9 A. Yes. She came, she met me outside. And I

10 tried to run around on her driver’s side to try to

11 talk to her secretly, and at that time I’m being

12 followed right here, and Vinnie’s right here, so I

13 was unable to communicate to her. So when I ran

14 around this way, now Vinnie comes up and talks to

15 her, and I’m trying to talk where -- behind him to

16 her.

17 Q. Was she in her car at the time?

18 A. She was in her car.

19 Q. Do you know what kind of a car she was

20 driving?

21 A. I can’t remember.

22 Q. Do you know cars at all?

23 A. Yeah, I do.

24 Q. Was it a sedan, or some other kind of car?

25 A. No, no. It was kind of like a little --

26 kind of like a little -- I don’t know if it’s called

27 a little SUV. I don’t know. Kind of like a Range

28 Rover type of thing. 6354



1 Q. Did you communicate to her anything other

2 than the fact you spoke both English and Spanish?

3 A. No. But when Vinnie was talking to her,

4 telling her that --

5 MR. MESEREAU: Objection. Nonresponsive;

6 move to strike.

7 THE COURT: I’ll strike after, “No.”

8 Q. BY MR. ZONEN: Did Vinnie say something to

9 Karen Walker in your presence?

10 A. Yes, he did.

11 Q. All right. Where was Vinnie standing at the

12 time?

13 A. Right there on the passenger-side window,

14 talking to her.

15 Q. And where were you?

16 A. I was right here.

17 Q. I don’t know where “here” is.

18 A. Right behind him off to the side.

19 Q. You were on the passenger-side window as

20 well?

21 A. Yes.

22 Q. And next to Vinnie?

23 A. Yes, sir.

24 Q. What did Vinnie say to Karen Walker that you

25 were able to hear?

26 A. Vinnie told Karen Walker that the children

27 were being put in school immediately. Because Karen

28 Walker asked him, were the children going to be put 6355



1 in school. And he said yes, the next day.

2 Q. This was on the 21st of February?

3 A. Yes, which was a Friday.

4 Q. And the kids were not put in school

5 thereafter?

6 A. They weren’t put in school.

7 Q. Did you seek a tutorial for your children or

8 a tutoring program once you were back out of

9 Neverland?

10 A. Yes, I did.

11 Q. Where did you seek to do that?

12 A. After the children -- we were out, and I

13 reenrolled the children in John Burroughs. I took

14 them to a place called G -- I apologize, JEI

15 Learning Center to bring them up to speed for all

16 those weeks that they had missed school.

17 Q. How did you select JEI?

18 A. I was looking, actually, for a learning

19 center somewhere in the vicinity of John Burroughs

20 so they would waste no time from attending school

21 all day and then go there. And then that’s where I

22 found it.

23 Q. Excuse me, I’m sorry.

24 At some point in time, were you introduced

25 to an attorney by the name of Larry Feldman?

26 A. Yes.

27 Q. Who is it who introduced you to Larry

28 Feldman? 6356



1 A. Bill Dickerman.

2 Q. Do you recall when it was you were

3 introduced to Larry Feldman?

4 A. Yes, when Michael’s people wouldn’t stop

5 following us.

6 MR. MESEREAU: Objection; move to strike.

7 THE COURT: Stricken.

8 Q. BY MR. ZONEN: Tell us the date, if you

9 recall, of your first meeting with Larry Feldman.

10 A. I can’t remember.

11 Q. Tell us approximately how many weeks after

12 you finally -- after your children left Neverland it

13 was that you actually met with Larry Feldman, if you

14 recall.

15 A. No, I can’t remember.

16 Q. Whose idea was it to go to Larry Feldman?

17 A. Mr. Dickerman’s.

18 Q. After you saw Larry Feldman, did he refer

19 you to somebody else to see?

20 A. Yes.

21 Q. Who was that?

22 A. He referred us to see Dr. Katz.

23 Q. Is that Dr. Stan Katz?

24 A. Yes.

25 Q. What kind of a doctor did you understand

26 Stan Katz to be?

27 A. Something with mental.

28 Q. Psychologist or psychiatrist? 6357



1 A. Yes.

2 Q. Do you know which one he was, psychologist

3 or psychiatrist?

4 A. No, I don’t.

5 Q. Did each of you meet with Dr. Katz?

6 A. Yes, we did.

7 Q. And by “each of you,” who are we referring

8 to?

9 A. Me and my three children. Davellin, Gavin

10 and Star.

11 Q. Did you know why you were meeting with him?

12 A. Yes, because Mr. Feldman --

13 MR. MESEREAU: Objection.

14 THE COURT: After “Yes,” I’ll strike that.

15 Q. BY MR. ZONEN: What was your understanding

16 of why you were meeting with Mr. -- Dr. Katz?

17 A. Because basically my house was a cuckoo

18 house now.

19 Q. At the time that you went to Mr. Feldman,

20 did you have any understanding of accusations of

21 sexual abuse --

22 A. No.

23 Q. -- to Gavin?

24 A. No.

25 Q. Had Gavin talked to you up to that point

26 about anything that had happened at Neverland to

27 him?

28 A. Um -- 6358



1 MR. MESEREAU: Objection; hearsay.

2 THE COURT: Overruled.

3 You may answer “yes” or “no.”

4 THE WITNESS: Yes. Gavin --

5 Q. BY MR. ZONEN: No, just “yes” or “no.”

6 A. Oh, yes.

7 Q. Gavin did have a conversation with you?

8 A. No, it wasn’t a conversation. It was like

9 an erupted volcano.

10 Q. Hold on.

11 At some point in time, did you actually sit

12 down with Gavin and have a conversation with him

13 about what took place at Neverland?

14 A. No. It was always broken, always.

15 Q. At some point in time, did you sit down and

16 have a conversation with Star about what happened at

17 Neverland?

18 A. He, too, it was always broken. I would

19 always hush them up. I’d say, “Just forget.

20 Forgive, forget. Forgive, forget.”

21 Q. Did you have any belief at the time you went

22 to Mr. Feldman that either of your boys had been

23 molested?

24 A. No, not molested. But I was aware of

25 things.

26 MR. MESEREAU: Move to strike the comments.

27 THE COURT: Strike the last sentence.

28 Q. BY MR. ZONEN: Did you go to Mr. Feldman 6359



1 because you believed your children were molested?

2 MR. MESEREAU: Objection; leading.

3 THE COURT: Overruled.

4 You may answer.

5 THE WITNESS: My children -- Gavin was like

6 an erupted volcano, all the different things.

7 MR. MESEREAU: Objection; nonresponsive.

8 THE COURT: Sustained. Stricken.

9 THE WITNESS: That’s my answer.

10 Q. BY MR. ZONEN: Let me withdraw the question

11 and let me ask it again.

12 A. Okay.

13 Q. Why did you go to Mr. Feldman?

14 A. Because as time progressed, I was finding

15 out more and more. I -- I thought it was just

16 alcohol.

17 Q. Were you concerned about the fact that your

18 child had been given alcohol?

19 A. Yes.

20 Q. That was something --

21 A. That was enough for me.

22 Q. Was that something you told Mr. Feldman?

23 A. Yes.

24 Q. Why were you concerned about your child

25 having been given alcohol?

26 A. Because he only has one kidney --

27 MR. MESEREAU: Move to strike.

28 THE WITNESS: -- and it’s malfunctioning. 6360



1 THE COURT: Just a minute. You have to wait

2 when there’s an objection.

3 THE WITNESS: Okay. Okay.

4 THE COURT: All right. The objection is

5 overruled. And the answer was, “Because he only has

6 one kidney.” Next question.

7 Q. BY MR. ZONEN: During the course of your

8 interview with Dr. Katz, did you tell Dr. Katz that

9 you believed that your child had been molested?

10 MR. MESEREAU: Objection; leading.

11 THE COURT: Overruled.

12 You may answer.

13 THE WITNESS: I don’t remember what I told

14 Mr. -- Dr. Katz. But -- I don’t remember, because

15 as time went by it was progressing.

16 MR. MESEREAU: Objection. Nonresponsive;

17 move to strike.

18 THE COURT: “I don’t remember,” I’ll leave

19 that part in. Strike the rest of it.

20 Q. BY MR. ZONEN: At the time of your meeting

21 with Dr. Katz, did you believe that your child had

22 been molested?

23 MR. MESEREAU: Objection. Asked and

24 answered; and leading; and foundation.

25 THE COURT: Sustained.

26 Q. BY MR. ZONEN: Did you ever come to a

27 conclusion that your child had been molested?

28 MR. MESEREAU: Objection. Asked and 6361



1 answered; foundation; and leading.

2 THE COURT: Overruled.

3 You may answer.

4 THE WITNESS: Yes. When I was told by the

5 D.A., police office --

6 MR. MESEREAU: Objection. Move to strike;

7 nonresponsive.

8 THE COURT: I’ll leave the “Yes” and strike

9 after that.

10 Q. BY MR. ZONEN: I just want you to tell us

11 when, not the circumstance. But when did you come

12 to the conclusion that your child had been molested?

13 A. Okay, when. I don’t remember when.

14 Q. Was it before or after your meeting with Dr.

15 Katz?

16 A. Oh, it’s way after.

17 Q. Was it before or after your initial meeting

18 with one of the detectives from the sheriff’s

19 office?

20 A. It was after the police, the police form a

21 trust bond with Gavin --

22 MR. MESEREAU: Objection. Move to strike;

23 nonresponsive.

24 MR. ZONEN: The question is simply when.

25 THE COURT: Just a moment. Just a moment.

26 THE WITNESS: Yes.

27 THE COURT: All right. I’ll leave the

28 answer, “It was after the police,” and strike the 6362



1 rest of that sentence. Next question.

2 Q. BY MR. ZONEN: Approximately how long after

3 your initial conversation with detectives was it?

4 A. I can’t remember. But it was after the

5 police got involved.

6 Q. Okay.

7 A. But I was aware of things.

8 Q. That’s all. Just --

9 MR. MESEREAU: Objection; move to strike.

10 THE COURT: Stricken.

11 Q. BY MR. ZONEN: When did you finally get your

12 possessions back?

13 A. Until the police got involved. Yeah.

14 Q. Where were your possessions moved to at that

15 time?

16 A. They were moved into another storage area,

17 because I -- I no longer had a place now.

18 MR. MESEREAU: Objection. Move to strike;

19 nonresponsive.

20 THE WITNESS: I -- okay.

21 THE COURT: Overruled. Next question.

22 Q. BY MR. ZONEN: Did you have an opportunity

23 to go through your items after they were ultimately

24 returned?

25 A. Yes. With the police there.

26 Q. All right. And where was that that you went

27 through all of your items?

28 A. I immediately went to the clay pot that I 6363



1 told you where I had --

2 Q. Just tell us where it was that you looked at

3 these items. Where is the location where the items

4 were where you looked at them?

5 A. Dino’s Storage.

6 Q. Do you know where that is?

7 A. I can’t remember.

8 Q. Okay. Was it someplace in Los Angeles

9 County, to your knowledge?

10 A. Yeah. Yes.

11 Q. Now, at that location, did you go through

12 all of your --

13 A. Oh, God, no. I think it’s somewhere near,

14 like, Calabasas area. Somewhere like that.

15 Q. In the valley somewhere?

16 A. Yeah, in that area.

17 Q. San Fernando Valley?

18 A. Yes.

19 Q. Now, at that location did you go through all

20 of your items to see what was there and what was not

21 there?

22 A. Yes.

23 Q. Were you able to find any of the letters

24 that Mr. Jackson had sent to Gavin?

25 A. I immediately went to the clay pot. Lifted

26 it up. Gone.

27 Q. Was everything missing from the clay pot?

28 A. Everything was missing. 6364



1 Q. Were there any other items besides letters

2 that were missing?

3 A. Yes. Pictures, and that rabbit.

4 Q. By “pictures” do you mean photographs?

5 A. Yes.

6 Q. And these are photographs of what?

7 A. Of Michael with the children.

8 Q. And then you said a rabbit.

9 A. Yes.

10 Q. You’re talking about a doll of some kind?

11 A. Yes. Yes.

12 Q. And from where did this rabbit come from?

13 A. From Michael, from Mr. Jackson.

14 Q. And what became of that?

15 A. Gone.

16 Q. Do you recall the jacket that you referred

17 to that was given to Gavin by Mr. Jackson?

18 A. Yes, I do.

19 Q. What happened to that jacket?

20 A. I turned that over to Mr. Sneddon.

21 Q. And did you identify that jacket before the

22 grand jury?

23 A. I don’t remember if I did that. I don’t

24 remember.

25 Q. Can you describe that jacket for us?

26 A. Yes, I can. It’s black with -- Mr. Jackson

27 said it was crystals on the back.

28 Q. Something that glittered? 6365



1 A. Yes. Mr. Jackson said it was real crystals.

2 Q. Was there anything else that was given to

3 any of your children by Mr. Jackson during the time

4 that they were with him during the months of

5 February or March?

6 MR. MESEREAU: Objection; foundation.

7 THE COURT: Sustained.

8 Q. BY MR. ZONEN: Did you ever see a watch?

9 A. Yes. Mr. Jackson told Gavin that it was a

10 $75,000 watch.

11 Q. And where did you see that watch?

12 A. On his wrist. On Gavin’s wrist.

13 Q. At --

14 A. Mr. Jackson took it off of his wrist and

15 placed it onto Gavin’s wrist.

16 Q. Were you watching that happen?

17 A. I don’t think I did. I don’t think I did.

18 I just know afterwards this is what I found out.

19 MR. MESEREAU: Objection. Move to strike;

20 no foundation.

21 THE COURT: Sustained. Stricken.

22 Q. BY MR. ZONEN: Where did you first see that

23 watch?

24 A. I first seen it when -- I think when Gavin

25 got off the airplane. And then the rest of the time

26 when they were at Neverland.

27 Q. Did he wear that watch while you were at

28 Neverland? 6366



1 A. Yes, he did.

2 Q. Can you describe the watch for us?

3 A. Oh, it was gold, and it had stuff that

4 looked like diamonds on the face. That’s the best I

5 can remember.

6 Q. For how long did Gavin wear that watch?

7 A. Every day until -- every day. Every day, I

8 think, prior to going back to Neverland. I think

9 so. I don’t remember. I’m doing my best estimate.

10 Q. When he took the watch off, what happened to

11 the watch?

12 A. Oh, he didn’t take it off while he had it on

13 at Neverland at all.

14 Q. At some point in time did he stop wearing

15 the watch?

16 A. Yeah. When we got back, I took it off. You

17 know, “Stop wearing this ridiculous watch.”

18 Q. Okay. What did you do with the watch?

19 A. I think I had -- I think I had Jay -- I left

20 it at Jay’s apartment.

21 Q. And ultimately where did the watch go?

22 A. I gave it to the police.

23 Q. Mr. Sneddon?

24 A. Yes, Mr. Sneddon. The police.

25 Q. The police. Do you remember who it was you

26 gave it to?

27 A. Let me see. Okay. Yes, I did. I gave it

28 to the attorneys, because I didn’t want it in my 6367



1 house. And then --

2 Q. Which attorneys?

3 A. I gave it to Mr. Dickerman, and then we

4 ended up giving it to Mr. Feldman, and then the

5 police retrieved it from Mr. Feldman’s office,

6 the -- yeah.

7 Q. While you were at Neverland, did anybody

8 talk to you about finding you a place to live

9 ultimately after Brazil?

10 A. No. The -- it was at Brazil.

11 Q. No, but did anybody ever talk to you about

12 getting a house for you or apartment or a condo or

13 something like that?

14 A. The condition was that we had to leave the

15 country.

16 Q. I’m sorry. The question was, did somebody

17 talk to you about getting a house or an apartment at

18 some time?

19 A. Only if we left the country.

20 Q. Does that mean the answer is “yes,” somebody

21 did --

22 A. Yes.

23 Q. Okay. Now, this conversation was with whom?

24 A. With Frank and Vinnie.

25 Q. At the same time?

26 A. Yeah.

27 Q. Okay. Were both of them talking to you?

28 A. Yes. They were trying to get me to leave 6368



1 the country.

2 Q. And this was still while you were at

3 Neverland?

4 A. Yes.

5 Q. What did they say specifically about getting

6 you a house or an apartment, or what --

7 A. If I left the country, I can have that.

8 Q. You could have what?

9 A. A house and an apartment to go back and

10 forth. But, no, I didn’t want to leave the country.

11 Q. I don’t understand, “a house” -- I don’t

12 understand. What does that mean, “to go back and

13 forth”?

14 A. That’s what they said. Frank and Vinnie

15 came up with different things every time. But the

16 key here, that is consistent, is that, “You got to

17 leave the country.”

18 Q. Conditioned upon going to Brazil?

19 A. Yes.

20 Q. What did they say specifically about a house

21 or an apartment? What did they say?

22 A. If I left the country I could have that.

23 Q. You could have what?

24 A. A house and an apartment.

25 Q. Did they say why you would need both a house

26 and an apartment?

27 A. They said something like to go back and

28 forth. This way there’s still -- I have that burned 6369



1 in my brain, appeasing the killers. This way, if

2 the killers showed up at the apartment, I could go

3 to the house; from the house to the apartment.

4 Q. Did they tell you Michael Jackson would be

5 purchasing that for you or renting that for you or

6 what the arrangement would be financially?

7 A. That Mr. Jackson would do it if I left the

8 country.

9 Q. Did you understand that you would actually

10 own this?

11 A. No.

12 Q. They didn’t say one way or the other

13 whether --

14 A. No, they just said as I told you.

15 Q. You didn’t ask whether this would be

16 something in your name or somebody else’s name?

17 A. No.

18 Q. Or whether you’d have to pay rent on it?

19 A. I knew I didn’t want to leave the country.

20 I don’t care what they promised me.

21 Q. Did either Frank or Vinnie make any other

22 representations to you in terms of money, or college

23 education, or anything else that they would be

24 giving you if you went to Brazil?

25 A. No.

26 Q. Did he make any representations of what they

27 would be giving to you even if you didn’t leave for

28 Brazil? 6370



1 A. No. Zero.

2 Q. During the period of time from the time that

3 you were contacted by Michael Jackson back in early

4 February of ‘03 to the time that you left Neverland

5 and your children left Neverland on around the 11th

6 of March, did you ever ask anybody from Neverland,

7 whether it was Michael Jackson or Vinnie or Frank,

8 for money?

9 A. No. Zero.

10 Q. Did you ever ask any of them for money prior

11 to that time --

12 A. No.

13 Q. -- on February 4th?

14 A. That’s not my nature.

15 Q. Did either or any of them at Neverland make

16 an offer to give you money?

17 A. No.

18 Q. Did you receive money from any of them?

19 A. Nope.

20 Q. And by receiving money, I mean at any time

21 since you first visited Neverland back in August of

22 2000 until you ultimately left and had no further

23 communication with them.

24 A. No.

25 Q. Did you ever have a conversation with

26 anybody at Neverland, whether it was Michael Jackson

27 or Vinnie or Frank or anybody else, about the

28 subject of whether money would be given to you? 6371



1 A. No.

2 Q. Did you ever ask anybody at Neverland,

3 whether it was Michael Jackson or anybody else, to

4 support you for the rest of your life?

5 A. No.

6 MR. ZONEN: Could counsel and I approach the

7 bench briefly about the exhibit?

8 THE COURT: All right.

9 (Discussion held off the record at sidebar.)

10 THE COURT: Okay. We’re ready to go.

11 Q. BY MR. ZONEN: Miss Arvizo, are you

12 intending on filing a lawsuit against Michael

13 Jackson?

14 A. No.

15 Q. Are you intending on filing a lawsuit

16 against Michael Jackson on behalf of your children?

17 A. No.

18 Q. Are you intending on doing it anytime during

19 this proceeding or anytime thereafter?

20 A. No.

21 MR. ZONEN: Your Honor, I have no further

22 questions at this time. I do intend to play the

23 video once the particulars are worked out on it.

24 And --

25 THE COURT: All right. What we agreed to at

26 the sidebar here was the District Attorney needs to

27 prepare the three or four tapes that he was going to

28 show earlier that was compiled into one. He’s going 6372



1 to show them separately based on an earlier ruling I

2 made. And rather than have Mr. Mesereau start late

3 in the afternoon with cross-examination and then be

4 interrupted with that, we’re going to recess early.

5 (To the jury) I knew you’d be unhappy about

6 that. I’ll see you tomorrow morning at 8:30.

7 Remember the admonition.

8 (The proceedings adjourned at 2:10 p.m.)

9 --o0o--

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28 6373



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 6203 through 6373

16 contain a true and correct transcript of the

17 proceedings had in the within and above-entitled

18 matter as by me taken down in shorthand writing at

19 said proceedings on April 14, 2005, and thereafter

20 reduced to typewriting by computer-aided

21 transcription under my direction.

22 DATED: Santa Maria, California,

23 April 14, 2005.

24

25

26

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

28 6374



