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JACKSON V AEGLive May 10

th

2013

10 th Traduzione in Italiano 2013 05/28/13 Please help us! Karen Faye (Hair and Makeup) Plaintiff’s

Karen Faye

(Hair and Makeup)

Plaintiff’s Witness.

Typed by WendyLovesMJ

Direct examination by Brian Panish.

Q W happened at the rehearsal?

A Michael sweat a lot when he was rehearsing. Michael Bush took him to the

bathroom to give him dry clothing. I was in the living room. Bush came out of the

bathroom, He said to me: Oh my God Turkle, I can see Michael’s heart beating through

the skin on his chest.

Q

Did you say anything back?

A

I know. He’s thin.

Q

Who’s Turkle?

A

That was Michael’s nickname for me.

Q

How were you both?

A

We were shocked, upset.

Q

Yesterday you said you received no written response to your email to Delio, about

your concerns, you were worried Michael would get so sick and die, is that right?

A

Correct.

Q

Did Mr. Dileo say anything to you about those emails?

A

No, but I asked if he received them. He did not respond.

Q

Did Mr. Dileo say anything to you about Michael Jackson’s eating or physical

condition?

A I told him Michael’s losing weight rapidly. To ask Michael Bush to verify how

much weight he’s losing? Later I saw him talking to Michael Bush. I heard him asking

something about Michael’s weight, I heard Bush verify

(Panish stops Karen Faye, tells her not to state what she heard Michael Bush say)

Q Did you hear Mr. Dileo make a statement about Michael’s food?

A

Yes.

Q

What did he say?

A

Get him a bucket of chicken.

Q

How did that make you feel?

A

Sir… (crying) It was so cold.

Q

How did you hear that Michael Jackson had died?

A

I was in the hallway at the Staples Center. Kenny Ortega came up to me, put his

arms around me and told me.

Q

How did you deal with it?

A

I can’t describe it.

Q

How did Mr. Ortega deal with it?

A

He and the people there continued on with the business of the situation

Q

Did you have any responsibility of preparing Michael’s body for funeral service?

A

Yes sir.

Q

What did you do?

A

(crying) I prepared his body for his family to view him in his casket.

Q

Did you learn a movie was going to be made from some of the performances that

was videotaped?

A

Yes.

Q

Were you ever asked to be part of that project?

A

Yes.

Q

What were you asked to do?

A

Help retouch the footage.

Q

And did you do that?

A

No sir, I did not.

Q

Why not?

A

Because it was a lie. I didn’t want to lie.

Q

What do you mean?

A

Everybody was saying Michael was well. And they knew he wasn’t. I felt

retouching Michael was just a part of that lie.

(Panish plays The Way You Make Me Feel clip)

Q Does this accurately depict how Mr. Jackson looked in the last days of his life?

AEG: Objection. No foundation. Judge: Overruled

A He looked better to me in real life than this. Especially in his legs.

(Panish exhibits a photo Michael in last days of his life)

Q Did he look robust, muscular, skeletal? How would you describe this? A Skeletal. Q

Q

Did he look robust, muscular, skeletal? How would you describe this?

A

Skeletal.

Q

What do you see there in his face that lead you to say that?

A

His eyes, his jaw, his ears, his neck, his lips are dry.

(Panish exhibit’s a photo of Michael in his History Tour gold pants on the right, next

to a photo of Michael in the red pants from This Is It footage on the left)

Q What differences do you see in Michael? A On the right is how he

Q What differences do you see in Michael?

A On the right is how he used to look to perform. On the left is how he looked for

This Is It.

(Panish exhibit’s two more photos side by side. On the right, a photo taken of

Michael in fitting room of This Is It. On the left, a photo from This Is It video taken

2 days before he died)

a photo from This Is It video taken 2 days before he died) Q Can you

Q Can you tell us what you see in these photos that concern you?

A In the photo on the right, his arms bones. The one on the left is blurry. I cant

make out too much. plus he’s got a lot of clothes on. He got a tee shirt on, under another

shirt, and another, and another.

Q

A

One is on the 19 th and one 23 rd , that’s 4 days.

Yes.

Q

was concerning to you?

Is there any question in your mind on This Is It that Michael Jackson’s appearance

A I was very concerned. I was scared.

Cross examination by Marvin Putnam.

Q You had previously retouched footage that was going to be used in concerts?

A I personally was not. I was working with the technicians to show them what was

best for Michael.

Q You said no to retouching the This Is It footage. Why?

A I was torn. This movie was going out. I wanted him to look good. But not lie. I

contacted my rep for advice. I did not participate.

Q

This rep, is that Ms. Wilkie? Your long-term rep?

A

Not long-term, several years.

Q

What is Ms. Wilkie’s personal relationship with the Jackson family?

A

She’s known Randy Jackson for a very long time.

Q

Randy Jackson, what do you mean?

A

They had a relationship.

Q

Was that long-term?

A

On and off, sir.

Q

A long-term on and off relationship?

A

Yes sir.

Q

A

Q

days?

A

You said you talked with Frank Dileo and he said get him a bucket of chicken?

That wasn’t with me. I heard it through a partition.

At Staples Center the 23 rd and the 24 th

Yes sir.

that would have been on one of those two

Q

A

quickly. His rehearsal was better, sir.

You previously testified on those days Mr. Jackson looked good?

I didn’t say he LOOKED good. There’s no way somebody could look good that

Q

A

He had better rehearsal on the 23 rd 24 th

but you still thought he was too thin?

Absolutely, sir. he was cold. very cold.

Q

Jackson’s life in 2009?

In fact you thought he looked too thin the entire time you were back in Mr.

A

Comparatively, not too thin initially. he didn’t have enough muscle mass to do a

concert

at that time. He progressively got thinner.

Q

And your main concern was Mr. Jackson was too thin, right?

A

That was only one of my concerns. his psychological -- his state of mind, sir.

Q

The concern about his psychological state, was that through the whole time back

you were with him May and June?

A It came to a peak in the last week. I progressively became more worried.

especially when he started miss rehearsals.

Q So that was starting on the week of June 8

A I can’t remember the date, once we reached the Forum rehearsals started, I began

noticing -- it was obvious to everybody -- he was periodically missing rehearsals or

th

?

coming

late.

Q

It’s important to be accurate.

A

Absolutely, sir.

Q

So what I’m going to do is go through your testimony and be accurate as to

EXACTLY what happened, okay?

A

Yes sir.

Q

So you said the first week of June, that was at Culver?

A

Sir, I don’t remember the exact dates we were at Culver City before we started

rehearsing at the Forum.

Q So let me represent to you your prior testimony in your deposition is that in the

first week, was when you were at Culver City working on videos?

Panish: Objection. Improper use of the deposition. Judge: Overruled.

Q

You said that was the first week you were in Culver?

A

Ok.

Q

Is that when you grew concerned for him psychologically or was it after?

A

I’m sorry. I can’t verify dates exactly, sir. I would say that I was starting to

become

concerned at that time.

Q 25

th

is the day of Mr. Jackson’s passing, right?

A

Q

A

Yes.

23

rd

and 24

Yes.

th

were the only days at the Staple Center, correct?

Q

something up.

So Im going to go back through the history. Ask you some questions to clear

A

I will do my best.

Q

Let’s start with your work history with Mr. Jackson. You started working with him

in 1982 on the Thriller album, correct?

A

Correct.

Q

You mentioned a man named Frank Dileo. Michael Jackson’s manager. Did you

meet him?

A

Yes.

Q

So you met Frank Dileo on the photoshoot in 1982.

A

Oh no. Frank Dileo wasn’t the manager then. He had a different manager think it

was DeMann. Frank Dileo wasn’t Michael’s manager until Thriller started taking off.

Frank quit his job at Sony to become Michaels manager.

Q So you knew him almost as long as you knew Mr. Jackson is that right?

A Almost. after Frank Dileo was fired there was a long time span, I didn’t know

him as long as Michael.

Q And then he came back into Mr. Jackson’s life, right?

A I saw him working on This Is It, sir.

Q

There were a lot of people fired and then they came back, is that correct?

A

Correct.

Q

And you were one of those people?

A

I was never fired, sir.

Q

You weren’t fired?

A

I was released. I’m a freelance artist, sir.

Q

Were you not told in the middle of a tour that your services were no longer

needed?

A

Yes sir.

Q

You were told that by Mr. Jackson’s manager, Tarock, right?

A

Yes sir. He sent me a letter of release.

Q

When you were brought back into Mr. Jackson’s life, you hadn’t spoken to him

for years?

A Just in the last leg of the History Tour was really the only time I didn’t talk to

Michael.

Q Well Mr. Jackson left the country in 2005, correct?

A He did, sir.

Q

So the next time you saw him was 2009, correct?

A

Yes sir.

Q

So you too left Mr. Jackson for a period of time and then came back in, correct?

A

Correct sir.

Q

Was that an odd occurrence for people to leave and then come back in?

A

Not extremely odd, sir.

Q

Did that happen frequently?

A

Not, but it did happen.

Q

Then how would you characterize it?

A

Once in a while.

Q

You worked on the Moonwalker film. Were you aware that Mr. Dileo was the

executive producer on that film?

A

I believe so.

Q

Bad Tour. That was your first tour with Mr. Jackson. Wasn’t Mr. Dileo tour

manager?

A

Yes sir.

Q

The Bad Tour was 1987 to 1989, right?

A

If you say so. I’m not sure of the dates. Sounds right

Q

Was it sponsored by Pepsi?

A

To my knowledge it was. All of the posters and everything had Pepsi printed on

it.

Q

And this show started in Tokyo and ended in Hawaii?

A

One ended in Hawaii but I think your right -- Bad Tour ended in Orange County,

I think.

Q

Well, let me see if you remember a series of concerts that were cancelled due to

sickness, postponed to the following year?

A I cant recall that, sir. It was a longtime ago. You mean the ones in Orange County

were cancelled? Um. I know we did them.

Q

Did you do some several months later?

A

I can’t recall, sir. I’m sorry.

Q

No don’t be sorry. I’m actually not asking the question for the answer. It’s to see

what your memory is. This is over a long period of time, correct ma’am?

A

Yes sir.

Q

Do you remember some things vividly?

A

Yes sir.

Q

And some things you remember less vividly?

A

Like most people, sir.

Q I’m not suggesting that you don’t remember.

A Normal things of life, work and everything, you’re not going to remember details

of that. When something traumatic happens, it sticks in your head, sir.

Q Yesterday you were shown certain performances and asked if you could remember

one in Romania. Do you remember?

A I was in Romania my daughter was on stage for Heal The World. That was very

easy to remember, sir.

Q You were shown several clips yesterday and asked if you could remember. So I’m

going to do the same thing. Do you remember a DVD being made for a show at

Wembley? Do you remember that?

A Yes. I think Sony re-released them. But I haven’t seen them, sir.

Putnam: approaches KF.

Q Do you remember a series of shows in London?

A I remember being in Wembley. not number of shows. I remember the highlight

meeting Princess Diana. I was with Michael. I was not formally introduced.

Putnam:

recall them. I’m not all of them, just bits of it.

Alright. I’m going to show you to clips from the DVD and ask you if you

(Putnam plays Beat It clip)

Q Do you recall that?

A This specific show? Sir, I have to say that we did this show many times. So for

me to say I remember this specific show would be -- I remember the performance, sir.

Q

So do you remember this performance from that time period?

A

I remember Beat It, yes.

Putnam:

Okay. Let me play the next one, which is Smooth Criminal.

(Putnam plays Smooth Criminal clip)

Q

Is that the version of Smooth Criminal that was performed during this tour?

A

It appears to be, sir.

Q

So you were there for the entire Bad Tour, correct?

A

Yes.

Q

And the next tour you were on was the Dangerous Tour?

A

Yes, sir.

Q

Do you remember it was 1992?

A

1992 -- okay, I will take your word for it because I can’t verify the exact dates.

sir.

Q

Do you remember that Kenny Ortega was on that tour?

A

I don’t think he was on the whole tour. He was a creative director so once the tour

was set up, Kenny went on to other things.

Q

Does that mean he created the ideas on the tour.

A

Along with Michael, yes.

Q

So they did it together -- the concept of the show

A

Yes.

Q

Do you remember that tour had three legs to it -- Europe, Asia, then Asia again?

A

Yes, I believe so.

Q

Part of that tour was the clip we saw yesterday in Romania?

A

Yes.

Q

And this is the tour where you became increasingly concerned with Mr. Jackson

using drugs, is that right?

A

I’m sorry, can you re-phrase the question?

Q

Alright. This is the tour that ended with Mr. Jackson going into rehab, correct?

A

Correct.

Q

And this is the tour you told us yesterday was Dr. Forcast, the Lloyd’s doctor?

A

That was my understanding. Insurance doctor.

Q

And this is when Dr. Forcast grabbed you around your throat?

A

Yes sir.

Q Alright. I’m trying to bring you back to what we are talking about. When you

were asked to look at that clip in Bucharest, do you remember?

A

Yes sir.

Q

And when you were asked to look at the footage you mentioned that there may be

as many as 500,000 people. Do you remember saying that?

A

I think in Ireland, that was the count.

Q

So Bucharest wasn’t 500,000?

A

That stadium was much smaller; he could pull as much, especially in a wide open

field. The media said -- when we were in Ireland, people had actually broken down

barriers

and came in. There was about 500,000 people there, it was a tremendous

amount

Q

So yesterday when you said 500,000 people in Bucharest, that wasn’t correct?

A

Not in Bucharest sir, that stadium was much smaller.

Q

That’s what I was going to ask you about. Because that stadium officially holds

70,000.

A

Bucharest is kind of a depressed country so their facility was a lot smaller. But

there were also areas where there were big, open fields. So people would just pour in.

And it could be an exaggeration because, as you know, I’m not really great with numbers

but I remember media reported 200,000, 300,000. There was a place in Ireland where it

was just tremendous. They broke down the gates.

Q So the reason I’m over some of the stuff from yesterday is I’m trying to get a very

accurate picture of what we’re doing here as best we can.

A Well I’m 60 years old, sir. And you’re talking about a 30 year span. I’m doing the

best I can.

Q

And I understand that, I promise you.

A

How old are you?

Q

What?

(laughter in courtroom)

A

How old are you?

Q

I --

Panish: You don’t have to answer that.

A Is that hearsay?

(continued laughter in courtroom)

Panish: Objection.

Putnam: No. It’s only hearsay if someone else said it.

Faye: Well, I heard somebody say it.

(more laughter)

Q Um. Going back to the Dangerous Tour. You indicated yesterday that Paul

Gongaware managed the tour, and had a role in cancelling that tour?

A I think that was multiple question, so I was answering. Okay. Did Paul

Gongaware actually cancel a show? He may have been involved in figuring out what to

do if something happened regarding cancelling shows. But I am not in the office and

privy to that info sir.

Q

I understand. And that’s why I want to make sure everybody understands.

A

Yes. We were talking about chain of command, sir.

Q

And so you don’t know what Paul Gongaware did on that tour, correct?

A

I do know some of the things. But not the details. He was working with our

passports. visas. He was working with logistics, with rearranging schedules.

Q And in fact, when you were asked initially about what he did, you said there were

3 parts: A, B and C. And he dealt with the B part of the crew?

A

During the Dangerous Tour he traveled with the B group. sir.

Q

I just want to be sure. This is the tour where you said he was further down the

totem pole?

A

Yes sir.

Q

And do you know if during that tour Paul Gongaware had any interaction with

Michael Jackson, at all?

A Yes he did. Because there were many times when our hotel rooms were together

and intermixed. And at the stadiums there was interaction between everybody.

Q So do you remember specifically seeing interactions between Paul Gongaware

and Michael Jackson?

A Specifics, I can’t recall interactions between other people, you’re talking about

350 people traveling together on the tour, sir. But there were.

Q

Yesterday Bangkok tour was mentioned. And you talked about Mr. Jackson

having

some sort of scalp surgery, is that correct?

A

Yes.

Q

And he had this surgery just before going to Bangkok?

A

I really don’t know the exact date of the surgery, sir. I worked with him on a

shoot and the actual inflation device was under his scalp, just before we left Bangkok, the

device was removed, an operation to bring the skin together on his scalp had already been

completed.

Q

And you saw his scalp every time he performed, right?

A

Not every time he performed. But I had to deal with his wounds and covering

them.

Q

Do you remember seeing any signs of that surgery on the prior leg of the tour?

A

I do not recall on which leg of the tour, the in between stages, when he had the

surgery.

Q You do remember between legs of the tour he had the surgery and then you saw

the results, but you don’t remember between which leg of the tour he had the surgery,

 

correct?

A

Correct. Or the year?

Q

That was 92-93. This was 1993, we’re talking about Bangkok. And to be really

specific, I can tell you it was August 23, 1993.

A

And you’ve done your homework, sir.

Q

And you said yesterday he would get headaches as a result of the surgery, correct?

A

Yes. migraine headaches. He was in a lot of pain.

Q

And you’re trying to say this is the result of the surgery, is that correct?

A

Yes sir.

Q

And this was also the time that certain charges about possible child molestation

came out , is that right?

A

Yes sir.

Q

And are you aware that those charges occurred on the same day as the show in

Bangkok?

A

I know that is happened very close to that time, yes sir.

Q

So the tour goes on for several months and then finally ends in Mexico City. Did I

understand you yesterday to say this was the time you started to believe Mr. Jackson was

having a problem with pain killers?

A Yes. I believe I did. I pretty much know there was an issue because of the

patches, vials and syringes that Finkelstein told me about.

Q Let goes back to that. You said yesterday that someone asked you to bring a

package of vials and syringes to Bangkok. Who was that?

A

Jim Morey and Debbie Rowe.

Q

And who was Jim Morey.

A

He was, I believe his manager, along with Sandy Gallin.

Q

So you’ve already talked about a number of managers here, You talked about

Freddy

DeMann, Frank Dileo. Now Jim Morey and Sandy Gallin.

A

Correct.

Q

So Mr. Dileo and Mr. DeMann were no longer in the picture at this point?

A

No sir.

Q

So you said managers and Ms. Rowe talked about bringing the medicine into

Bangkok?

A Patches. I never saw them, it was explained to me, like the nicotine smoking

patches. It releases a certain amount of nicotine at a time.

Q

And do you know what those patches were for?

A

It was explained to me to relieve the pain from his surgery, sir.

Q

And who was Debbie Rowe working for at this time?

A

She was a nurse for Dr. Klein.

Q

Was Dr. Klein treating Mr. Jackson?

A

As far as my knowledge is, yes, sir.

Q

And so the nurse of one of this treating physicians talked to you about bringing

along a package with patches in it?

A

Correct, sir.

Q

You’re Mr. Jackson’s makeup artist. How is it this physician’s nurses came to talk

to you about taking packages into Bangkok?

A Because I was going along with him.

Q

And did you know any of his doctors?

A

Yes. I knew Dr. Klein before I knew Michael, sir.

Q

Did you know him professionally?

A

Yes, sir.

Q

Were you a patient.

A

Yes, sir.

Q

Ultimately, you declined to bring those packages into Bangkok, correct?

A

Correct, sir.

Q

Did you discuss your concern about his taking pain killers with Mr Jackson? Did

you ever say to Mr. Jackson: I’m concern you have a problem with pain killers?

A

No sir.

Q

Did you ever say anything to him about his use of pain killers during the

Dangerous Tour?

A The only time it was obvious was in Singapore when he was not able to work. He

knew I saw what happened when I tried to stop him. That was the only non-verbal

communication we had, I knew what was going on.

Q Did you ever say to him after the Singapore incident that you were really worried

about him?

A I have to say I really don’t recall because everything that was occurring was very,

very painful to Michael, sir. Emotionally. Physically. And I was a place of safety and

peace for him. I didn’t want to bring up the allegations sir. I wanted that to be a really

safe place.

Q

And so you didn’t discuss your concerns with him, correct?

A

I tried very hard not to.

Q

Do you remember ever discussing it with him, at all?

A

I can’t remember, sir. it may have come up. Especially after what happened in

that dressing room, it’s not anything that I would have ever brought up in our space. So I

can’t recall. But I know he thanked me for what I did in Singapore. If that’s what you

mean about any kind of conversation.

Q

He thanked you for what?

A

For stopping the show.

Q

And did you ever contact Mr. Morey and tell him: Hey I think Michael Jackson

has a problem with pain killers?

A

No sir. I was afraid of him.

Q

And why was that?

A

Because of what they asked me to do.

Q

You mean because they asked you to bring these packages to Bangkok?

A

Yes. It concerned me. Especially after what the doctor said was really in that

package, sir. I was very wary of them.

Q Did you ever discuss your concern with Mr. Jackson about them asking you to

bring packages to Bangkok?

A I can’t recall, sir. Maybe, after the fact. We had minimal conversations about

what happened that.

Q Did you contact Dr. Klein or Debbie Rowe about your concern about Mr.

Jackson’s use of pain killers during the Dangerous Tour?

A

No sir.

Q

Did you ever see Mr. Jackson take drugs?

A

No sir.

Q

Did you ever see him have any injections?

A

No sir.

Q

Did you ever give Mr. Jackson any drugs?

A

No sir.

Q

Did you ever deliver any drugs to Mr. Jackson?

A

No sir.

Q

Were any drugs ever prescribed in your name for Mr. Jackson?

A

I have no knowledge of that occurring, sir.

Q

You also mentioned another doctor yesterday -- Dr. Metzger. You indicated he was

a longtime doctor of Mr. Jackson?

A

I think he was like a family doctor, that also took care of the Jacksons. He was

around

as long as I can remember.

Q

When you were asked to bring medication to Bangkok, did you already know Dr.

Metzger?

A

Yes sir.

Q

Did you discuss with Dr. Metzger about bringing those medications into

Bangkok?

A

No sir.

Q

And there was never a point on any tour when you ever brought Mr. Jackson any

drugs, is that correct

A

(Hesitates

)

If you consider Latisse a drug, sir?

Q

Do you get that by prescription?

A

Yes, Then I would say Latisse is something that I did bring to Michael, sir.

Q

What is Latisse?

 

A

Latisse grows eyelashes, sir.

Q

And how did that come about?

A

Dr. Metzger, sir.

 

Q

Dr. Metzger prescribed this for Mr. Jackson?

A

I wanted it because I didn’t want him to wear false eyelashes, sir.

Q

Was this prescribed in your name?

A

I believe it was because the tour was so hectic -- This Is It -- that I wanted to be

able to pick it up close to my house.

Q

So Dr. Metzger prescribed Latisse in your name for Mr. Jackson?

A

And something else, sir.

Q

What else, ma‘am?

A

Propecia.

Q

This was also prescribed in your name?

A

Yes, I picked it up at the same pharmacy.

Q

And this was all for Mr. Jackson?

A

Yes. It wasn’t for me.

Q

Is this something that Mr. Jackson went to Dr. Metzger for and then had you pick

up?

A

I had a conversation with both Michael, Dr. Metzger and Dr. Klein to make sure

that these things were going to be okay for Michael to take in regard to his cosmetic look.

Q These are direct conversations you had with Dr. Metzger and Dr. Klein?

A Yes, I also discussed Botox, sir. Because everything that I was requesting was for

cosmetic purposes for This Is It.

Q So let me get this. It’s Propecia, Latisse and Botox, is that right?

A No I didn’t get Botox. I was just inquiring whether it was an option. I wanted to

know if it’s safe to suggest to Michael. Botox stops sweating, sir.

Q Is that what you inquired for?

A

Yes. For his scalp. Because he wears hair that is not all his, so perspiring is a real

issue.

Q

Back to the Dangerous Tour. Did you ever talk to any doctors about getting any

prescriptions for Mr. Jackson during?

A

Not to my knowledge, sir.

Q

Did you talk to anyone in Mr. Jackson’s family about him abusing pain killers, at

the time?

A

Which time, sir?

Q

During the Dangerous Tour, ma’am.

A

I did have conversations with family members about Michael’s situation, I don’t

think it was during the Dangerous Tour. I think it was after that.

Q

With whom did you have conversations?

A

The majority of my conversations were with Rebbie, sir.

Q

Did you have conversations with other members of Mr. Jackson’s family about

your concerns?

A

I think La Toya, sir.

Q

La Toya Jackson? Any other members?

A

In the whole 30 years? I’ve had many conversations with his family members

about concerns. I met with his mother and family after he died.

Q

No. Just answer up until the time of Mr. Jackson’s passing. Any conversations

you’ve

had with any members of Mr. Jackson’s family about your concerns about his

drug.

A

The one that stands out in my mind is the one with Rebbie, sir.

Q

The one with La Toya Jackson, that occurred after?

A

Yes, sir.

Q

The conversation with Rebbie Jackson happened after the Dangerous Tour?

A

Yes.

Q When did it occur?

A I can’t remember, sir. it occurred. In my house, in the living room. She came over

to my house.

Q Back to the Dangerous Tour. You’ve testified you don’t recall having any

conversations with Mr. Jackson about your concerns about his use of pain?

A I said I don’t recall any details about a conversation. As I’m saying, I kind of

avoided the molestation/drugs issue like the plague.

Q

I’m only asking about the drugs, ma‘am.

A

I avoided them both. Because they were both interconnected, sir.

Q

And you said you don’t recall having any discussion with Mr. Jackson about being

asked to bring any packages into Bangkok, is that right?

A Not with Mr. Jackson, No. But as I said, when we discussed it much later and it

was brought up, it’s possible we discussed that but I’m not sure if I did.

Q

You mean past Dangerous tour time?

A

Yes.

Q

And you talked about this thing that happened with Dr. Forcast. Where he

attacked you? Did you ever talk to Mr. Jackson about it?

A

He was there, sir.

Q

Did you ever bring it up to him afterwards and say anything?

A

Not until later, sir. Because during that time I didn’t want to bring up anything

horrible to him.

Q

So then after the tour. Did you ever bring it up with any of his managers?

A

No sir.

Q

Did you ever bring it up with any one on the tour?

A

Probably Michael Bush. Because he was up on stage in the quick change room,

after what I heard in Michael’s backstage room. So he was party to the situation.

Q

You say you believe this Dr. Forcast was the insurance doctor for Lloyd’s, is that

right?

A

It’s kind of what I recall, sir. That he was from Lloyd’s of London regarding the

insurance.

Q

Do you recall why you thought this?

A

Somebody told me, I guess. Or it was on a call sheet, I really don’t know.

Q

Did you ever get the impression that Dr. Forcast was Mr. Jackson’s personal

doctor

on the tour?

A

I never got that impression.

Q

Did anyone ever tell you that Dr. Finkelstein was also doctor for rest of the tour,

for the crew and others?

A

He served in that purpose also, sir.

Q

Did Dr. Finkelstein came to serve Mr. Jackson in Dr. Forcast’s absence, how many

times?

A

How many times? No, I don’t sir.

Panish: Objection. No foundation of the facts. Counsel is testifying.

Judge: Sustained.

Q

So this tour ended with Mr. Jackson going into a rehab, correct?

A

Correct, sir.

Q

And did you come to understand that he went into rehab because of his addiction

problem to pain killers?

A

Yes sir.

Q

He went to England?

A

Yes sir.

Q

And you said yesterday that at the time, you didn’t know where he’d gone until

someone contacted you and told you where he was, correct?

A

Nobody ever told me where he was. They just said they wanted me to go.

Q

So I want to break that down.

A

Okay.

Q

So by the time the tour ended, you were in Mexico, correct?

A

Correct.

Q

Did you talk to Mr. Jackson in Mexico about him leaving to go to England?

A

No. He didn’t know, sir.

Q

What do you mean, he didn’t know?

A

I don’t think he knew there was going to be someone intervening to take him

away and try and help him.

Q So you knew after he was gone. That’s not something anyone discussed with you

prior to him leaving?

A

I’m trying to take myself back there, I don’t know if I knew Elizabeth Taylor was

coming

or if she was called, or I didn’t know, sir.

Q And you came to find out where he was from the television, right?

A No. The TV and media was searching for him. I don’t think they knew where he

was. I wasn’t even told where he was, sir. When they asked me to go.

Q Who asked you to go?

A Trying to think if it was Norma or Evvy in charge then. Those were two assistants

that overlapped at one time.

Q

Assistants to whom?

A

Personal assistants. They stayed at home in Los Angeles and handled secretarial

duties.

Q

Personal assistants to Mr. Jackson?

A

Yes.

Q

So one of these personal assistants contacted you and asked you to go to Mr.

Jackson, wherever he was?

A

Yes.

Q

You’re back in Los Angeles by now. Did you ever try to reach out to Mr. Jackson

to see if he was okay?

A I was concerned, sir, I would have asked his people if he was okay. But it was not

my business. I wasn’t to know where he was. The media wasn’t to know where he is.

That’s not something I would pressure anyone to tell me

Q You came to understand that Elizabeth Taylor was involved. Did you discuss that

with her?

A

No, sir.

Q

When you went to visit Mr. Jackson, did you speak to anyone other than him

while you were there?

A

Yes, sir.

Q

Who did you speak with?

A

I spoke with the person in charge of his therapy -- I can’t remember his name --

maybe

you can tell me, he also had worked with Elton John. He asked about my concerns

and I said I was afraid Michael could die. And he told me --

AEG (Stebbins): Objection.

Karen Faye: Oh my, are you objecting? Sidebar.

Panish: Are they objecting to their own questions now?

(laughter in the courtroom)

Q Um. What I was asking was -- you were telling the therapist about some concerns,

and you said you were concerned that Mr. Jackson might die.

A He asked me what why concerns were -- for Michael. I stated the worst case

scenario, that this could kill him.

Q So the only time you saw Mr. Jackson somewhat effected by drugs was that one

time in Singapore during the Dangerous Tour, is that right?

A It was always a concern. was something that I was always watching out for.

When the date was cancelled, I was concerned. There were times when he was okay, and

there were times when I was worried.

Q Can you recall any other time during the Dangerous Tour seeing him under the

influence of drugs?

A We did so many dates and traveled so much, sir. You’re talking about years ago,

and I cannot recall specifics other than the really dramatic situation that occurred.

Q So other than that really dramatic situation in Singapore, do you recall any other

time during the Dangerous Tour that you saw something --

A

It was always a concern, sir.

Q

I understand that. I’m asking you if you remember any other times during the

Dangerous Tour where you thought he was under the influence of drugs?

A I’m just really confused by this. I’m telling you. That this entire leg of the tour, I

was really concerned. Doctors were telling me they were working on the BALANCE of

-- killing the pain for him, and being able to perform. I was always conscious of what was

happening during this part of the tour. Other than the traumatic ones. I can’t really recall

any specific time.

Q

Was this the only time you ever saw Mr. Jackson in rehab?

A

Yes.

Q

You’re not sure how many days you were there, right?

A

I can’t really recall. I believe I stayed overnight there -- for a few days.

Q

Did you come to an understanding whether Mr. Jackson thought he should be

there?

A

Yes. We had a conversation.

Q

And did he think he should be there?

A

No sir.

Q

Why not?

A

He didn’t think he had a problem, sir.

Q Did you tell him that you thought he did have a problem?

A I encouraged the situation. I said: This is a nice place. Everybody is really nice. I

think it’s good for you.

Q

Did you remind him what happened in Singapore?

A

I don’t recall.

Q

Did you find out why Mr. Jackson wanted you to come and see him?

A

I think he wanted me to come and maintain him -- a little bit cosmetically and I

think for moral support. I washed his hair. Did those sort of things.

Q Getting Mr. Jackson’s hair ready was a somewhat involved process -- more than

just a shampoo?

A

Yes it was.

Q

You said yesterday that during the criminal trial a couple years later, you would

start at 3am getting him ready, correct?

A I would get there then because it was a process of him coming up to the room

where we worked. Going through the process. Yes.

Q Now. After Mr. Jackson left rehab, do you remember him making a public

announcement about going to rehab?

A He made a public announcement regarding the situation. Yes, sir. He personally

explained in his own words what was wrong.

(Putnam plays AUDIO clip of Michael’s initial Nov. 1993 announcement, NOT the

televised Dec. 1993 VIDEO clip announcement from Neverland)

Q

Do you remember that?

A

I remember the visual of that. He had the eyelashes that I didn‘t -- that I hated.

Q

Say that again?

A

He was wearing the eyelashes. He wanted me to put the eyelashes on. I didn’t

want to, but I did.

Q

Are you saying you put the eyelashes on him to accompany the video?

A

Yes. I went up to Neverland to get it right.

Q

And you watched the filming of the announcement?

A

You asked me this in the deposition. I usually was in the room, but I can’t

remember if I watched him or if I did his makeup and then he went in another room to

make the announcement.

Q

Now. If announcement occurred the day after the tour ended --

A

Wait. It happened the day after the tour ended?

Q

Let me ask that question. Do you know when this occurred?

A

I have to say -- (long pause) I have to say I can’t accurately say when that

happened, sir.

Q

And do you know whether this happened prior to you visiting Mr. Jackson in the

UK?

A

I can’t recall, sir.

Q

You do recall telling me that morning that Mr. Jackson left. You didn’t know

where he was. You ultimately came to understand that he was in the United Kingdom?

A

I did, sir.

Q

Doesn’t this prove you knew where he was because you helped him with this

before?

A

Well if he did this announcement before -- oh gosh. This is a long time ago, how

long is this? Mexico City. (long pause) I really can’t recall. I know I was there to do his

makeup for the announcement. So if he came home and did that before he left? You got

me, I’m sorry.

Q Why is that?

A Well no. I mean my memory is being -- I’m trying to logistically recall things,

and a lot of it is difficult for me.

Q

Well let me ask you about that.

A

Because you’re a lawyer. And you’re trying to, you know -- you’re doing your

job, sir.

Q

You have a long history of doing tweets online.

A

Yes sir.

Q

Do you blog?

A

I do have, yes. I guess you could say that. I haven’t been there in a long time.

Q

And a website?

A

Yes.

Q

It would be fair to say you’ve put out hundreds if not thousands of tweets on

Michael Jackson?

A

Probably.

Q

And in this blog you’ve written extensively about your relationship with Mr.

Jackson?

A

Not extensively. I wrote for awhile. It was too painful so I stopped writing.

Q

The photos we saw yesterday were photos from that blog?

A

I haven’t been there in a very long time. The photos? On my blog? I don’t know

where they are. I put them on different sites.

Q

You have different sites?

A

Yes. I have different accounts. I use the internet, sir.

Q

And there are a number of Michael Jackson fan sites out there?

A

There are.

Q

Is it true you’ve posted and communicated on those websites?

A

Well during the time that I worked for MJJSource. But I haven’t -- I don’t go and

post on sites.

Q What’s MJJSource?

A MJJSource was a website that Michael and Randy Jackson created together to

have a vehicle for the truth to get out about the trial. The impending trial of the

molestation charges.

Q In fact, in all of these tweets and blogs you have said a number of unfavorable

things about AEG, haven’t you?

A I’ve stated the truth as far as my experience, sir.

Q My question was not about truth. Have you or have you not posted a number of

unfavorable things about AEG?

A

I have to give you the same answer on that, sir.

Q

I’m not asking you to give me the same answer on that. I asking you if you

understand the term unfavorable?

A

I guess you -- unfavorable. Could you please define the word unfavorable?

Q

Putting things on the internet about AEG in which you paint them in a light one

would consider not favorable. A bad light.

A

I paint them in a truthful light based on my experience, sir.

Q

Do you consider that a positive light. Are you lauding AEG on these sites?

A

No I’m not lauding them. I’m not singing their praises.

Q

You said before I’d be happy if you couldn’t remember the facts. I’m trying to

figure out why you said that. Is it because of the various things you’ve said on websites?

A

No because you’re a lawyer, sir.

Q

Let’s get back to this for a minute -- rehab. You saw and heard this announcement.

And you’re saying you not sure if you’d been there, correct?

A

I’m sorry. Can you say that again?

Q

You did not know where Mr. Jackson was when he was going into rehab?

A

Correct.

Q

But you are sure you were there for the announcement?

A

I did his makeup and hair, sir. The visual.

Q

And are you sure this visual, that you’re sure you were present at, is the visual that

accompanied this announcement?

A

I just know the visual one. I’m not familiar with the written one you showed

there.

Q

After you saw Mr. Jackson in rehab, did you come back to the States?

A

Yes.

Q

And you said when you were there that Mr. Jackson didn’t think he should be

there, right?

A

Correct.

Q

Did you tell his family that?

A

I wasn’t in contact with his family.

Q

Did you let his managers know that Mr. Jackson didn’t think he should be there?

A

I wasn’t in contact with his managers, sir.

Q

What about his doctors? Did you let his doctor’s know?

A

I wasn’t in contact with his doctors, sir.

Q

So that happened in 1993. Did you continue to work with Mr. Jackson after he

returned from rehab?

A Yes sir.

Q The next tour was the History Tour in 1996. In between the end of the Dangerous

Tour and the History Tour, did you work with Mr. Jackson during those 3 years?

A

I’m sure I did. I continued to work with Michael as a client.

Q

During that period did you ever talk to him about his time in rehab?

A

I can remember, sir.

Q

Do you remember during this time ever being concerned about Mr. Jackson’s drug

use?

A

I’m just trying to remember what was happening. I’m not sure if we were

shooting short films or -- can you tell me what Michael was doing professionally at that

time? Because that’s how I relate to see what was going on, because I worked for him.

Q

How did you work for him?

A

I worked as a makeup and hair artist for him, sir.

Q

I’m going to sorely disappoint you right now. And your understanding of lawyers.

I have no idea. Do you recall at all?

A

What album was out?

Q

Right now it’s History.

A

History was coming out. Okay. There was a History trailer in Budapest. That’s

when he married Lisa Marie, I believe. During that period of time.

Q State her full name for the record.

A Lisa Marie Presley, sir. I believe he was staying in New York at the time. I went

to Budapest. I can’t recall having any concerns during that period of time.

Q

Did you attend Mr. Jackson’s wedding?

A

With Lisa Marie -- Presley? No sir.

Q

Did you do his hair for it?

A

No. He got married in the Dominican Republic. So I did not.

Q

So the History Tour is 1996 1997. You went on this tour right?

A

A portion of it.

Q

But this is the tour you were informed your services were not longer needed?

A

After the first leg.

Q

Who asked you to be on the tour?

A

Michael.

Q

You indicated Mr. Ortega was on this tour. Do you know what he did?

A

Creative director, as usual.

Q

Was Travis Payne on this tour again?

A

I believe so.

Q

He was choreographer.

A

A dancer, choreographer.

Q And this is the tour where Paul Gongaware had a higher position than on the

Dangerous Tour, correct?

A

It appeared to be so.

Q

Did you know if there was company called AEG at this time?

A

I wasn’t familiar with that.

Q

You hadn’t heard of them then, right?

A

No. Not that I can recall ever hearing about.

Q

Who was Paul Gongaware working for on this tour?

A

I assumed Tarock and whatever organization was setup at that time.

Q

Who was Tarock?

A

There was a Saudi Prince or King running things at that time.

Q

Was Tarock Saudi royalty?

A

No. He was working with them, I believe. You’re talking again, above the line.

These were people who I never knew their exact positions. I was just doing my job as

makeup and hair artist. I wasn’t inquiring what position everybody had. It was pretty

aloof.

Q

What do you mean by above the line and below the line.

A

The chain of command. There are the worker bees and there are people that the

worker

bees work for and report to.

Q

Mr. Tarock was above the line?

A

Yes.

Q

He was Mr. Jackson’s manager?

A

I wouldn’t put a label on him that he was, sir.

Q

You traveled with him on the History Tour?

A

He traveled in a different group from me. He traveled in the A group, I traveled in

the B group. I would say he was working in a capacity similar to Paul Gongaware.

Personally negotiating my contract. Somebody making the rules.

Q When you say somebody similar to Paul Gongaware, are you talking about Paul

Gongaware role on the This Is It Tour?

A All I know is I had to go in and negotiate with Tarock on this tour, and I also had

conversations in the same regard with Paul Gongaware.

Q You had conversations with both Tarock and Paul Gongaware during the History

Tour to negotiate your contract?

A

From what I gathered, it was two people I had to deal with, go through and report

to.

Q

You didn’t continue after the first leg of this tour. Was that after you had an

argument with this Tarock?

A

Yes sir.

Q

And what was that argument about?

A

Tarock was trying to get rid of me, sir. And I felt that he was making things very

difficult for me. He was telling me that he would allow me to do Michael’s makeup but I

wasn’t allowed to speak to Michael while doing so. And my pay would be reduced. And

the figure he gave me was a very low amount. I’ve got a child and a home to support and

there was no way I could financially handle that.

Q Did you understand why Tarock during History Tour wanted you to do Mr.

Jackson’s hair but not speak with him?

A

It was never explained to me why. But my feeling was that it was about control.

Q

When you say control, what do you mean, ma’am?

A

Most every manager that came through Michael always wanted to replace me.

Because I was in a position that stood in front of Michael and touched him. And it was

always

very evident -- and Michael even told me -- about all the management wanting to

replace

me with someone they wanted there in front of Michael. It’s pretty common in

Hollywood. There’s a power struggle. The ones at the top want to have complete control

over people below the line. So it was pretty common for me to have someone above the

line not want me in Michael’s company for long periods of time.

Q

So Tarock told you that your services would no longer be needed?

A

Correct.

Q

Did you discuss this with Mr. Jackson?

A

No. Not until afterwards.

Q

When was that?

A

When I came back. When Tarock was gone and Michael asked for me back. After

the History Tour.

Q Did Mr. Jackson or his manager reach out to you and ask you why you weren’t

returning?

A

His manager. Who was his manager, sir?

Q

I don’t know. I asked you if Tarock was. You said you didn’t know.

A Well he certainly didn’t reach out to me to find out why. He was the one who

released me, sir.

Q

Mr. Jackson didn’t ask you why you weren’t there?

A

No sir.

Q

Your understanding is that Mr. Jackson knew that you weren’t going to be

continuing on the tour?

A

Michael Jackson told Michael Bush. He asked Michael Bush why I wasn’t there.

Q

So you had an understanding that Mr. Jackson didn’t know why you weren’t

there?

A

By Michael Bush telling me that Michael Jackson was asking HIM why I wasn‘t

there, kind of indicated that he didn’t know. But I really don’t know what anyone knew or

didn’t know, sir. Because I wasn’t there.

Q Did you ever come to have a belief that Debbie Rowe had been involved in you

not being there?

A

A little bit, sir.

Q

Who was Ms. Rowe at the time?

A

At the time, that was his wife.

Q

You indicated a moment ago that you thought Lisa Marie Presley was his wife. So

I’m a little confused.

A

Pardon?

Q

So at this time who -- Lisa Marie Presley was not his wife at this time?

A

No. Not the History Tour, sir.

Q

So you came to believe that his wife, Ms. Rowe had some role in your being

asked not to continue on tour?

A Actually, after it happened she told me she was. After I was back. She apologized

to me for playing a role in that situation.

Q Did you understand what role she played?

A This is so complicated. I needed another person to work on tour with me. Debbie

Rowe introduced me to a hairdresser named Tommy Simms, a good friend of hers. I liked

Tommy very much and I took him with me on tour to work with us. There was a lot going

on that I wasn’t privy to, or didn’t really understand about all of this. Debbie Rowe was

pregnant. And she was obviously in love with Michael Jackson. She had told me for

many years. That was her desire to be with him. She told me that she was jealous of me

being there as Michael‘s makeup artist. She thought that Michael liked me better than her.

And she felt more comfortable with her friend, Tommy Simms taking my place.

Q So you were on the first leg of the History Tour in 1996. You’d seen Mr. Jackson

in rehab in 1993. You said you were often concerned in the Dangerous Tour that Mr.

Jackson was obviously using drugs. Were you ever concerned that Mr. Jackson was using

drugs during the History Tour?

A To be honest, I was always concerned. But he seemed to be fine on this part of

the tour, sir.

Q So even with the previous history, you didn’t see anything on this tour that was of

concern to you?

A

That I can recall, sir.

Q

You mentioned yesterday there were doctors you saw on this tour. Dr. Ratner?

A

I think I only saw him in the hallway once, at the very end of the first leg.

Q

What about Dr. Klein? Did you see Dr. Klein on this tour?

A

I can’t recall if I ever saw him, sir.

Q

What about Dr. Metzger? You didn’t see Dr. Metzger on this tour?

A

I can’t recall seeing him.

Q

So there was a time when you started working with Mr. Jackson again, Do you

remember how that came to be?

A Just that Evvy called and said: Michael wants to talk to you and would like to

have you back. How do you feel about that? And I said: Great.

Q Did you ever explain to Mr. Jackson what happened with Tarock?

A A little bit. Because he was in the room when he asked Debbie to apologize to

me. So there was discussions and apologies regarding that situation.

Q Yesterday you talked about an incident in Munich where a bridge collapsed. Do

you recall if that was in 1999?

A

I don’t recall the exact year, sir.

Q

It was 1999.

A

Seoul and then Munich.

Q

Mr. Ortega was actually working with Mr. Jackson on those two concerts, wasn’t

he?

A

Correct.

Q

Was Mr. Payne working again, as well?

A

I think so, sir.

Q

Paul Gongaware had no role, correct?

A

Not to my recollection.

Q

You described yesterday the bridge collapsed. Mr. Jackson fell. You witnessed that

first hand, right?

A

Yes.

Q

You said you were devastated?

A

It was frightening to watch, sir.

Q

You remember saying that you thought he might be dead?

A

When the bridge went past the stage and I couldn’t see it -- it went into the

orchestra pit -- I didn’t know what happened and I thought it was possible.

Q I’m going to show you the whole clip if I may.

A Okay. We’re going to watch this again.

(Putnam plays clip of Munich bridge collapse)

Q Did Mr. Jackson seem thin to you there?

A I wasn’t looking for that, sir. He always slender. Well not always. There were

times when he got a little hefty, like at the end of the Mexican -- when we took him out,

he was a little heavier.

Q Let me just try and understand. So you’re saying he got a little thinner at the time

he went to rehab?

A

Yes sir.

Q

Can you remember any other time when Mr. Jackson was heavier?

A

In New York, at the release of Invincible, he was heavier.

Q

At this time in Seoul and Munich, were you concerned about Mr. Jackson’s drug

use?

A

No sir.

Q

So this is 1999. And you continued to work with Mr. Jackson at Anniversary

Show, the 30 th --

A

The Madison Square Garden show. Yes.

Q

Madison in 2002.

A

Yes.

Q

This is the show you talked about yesterday where you said there was a doctor

who gave drugs to him?

A I just went to the door to get him ready and the doctor was present when I

knocked on the door.

Q

Was this a different doctor?

A

Yes sir.

Q

Was this a doctor you’d ever seen before?

A

I didn’t recognize him, sir.

Q

Was this a doctor you ever saw again?

A

I don’t think I ever saw him after that.

Q

Did you know his name?

A

No sir.

Q

Did you know how he knew him?

A

He told me he gave Michael a sleeping aid.

Q

Did he say what that sleeping aid was?

A

No sir.

Q

But he said it would make him sleep for 5 or 6 hours?

A

He said Michael would be asleep. Come back in 5 or 6 hours.

Q

Did you see Michael and concur if he was there at that time?

A

Michael was there. I think Frank Cascio went up to his bedroom and got him up

for me and brought him, because I didn’t go into his bedroom.

Q

Why do you say that?

A

I’m a lady, sir. I don’t go into men’s bedrooms unannounced.

Q

So Mr. Cascio went to get him. Who is Mr. Cascio?

A

He was working as Michael Jackson’s assistant, and friend.

Q

Do you know who Mr. Jackson’s manager was at this time?

A

I don’t think he had one at that time. I don’t know if Dieter Weisner was there at

the time? But I don’t think he was. I can’t recall.

Q Is Dieter Weisner another person who served at some point as one of Mr.

Jackson’s managers?

A I mean -- managers? We are throwing around that term rather loosely so -- even

when they were working for Michael it was kind of vague as to what a manager was and

who was managing and what their role was. There were people that were involved in

Michael’s business -- managing his career, managing his money -- it’s really not clear to

me what you mean by manager. When you ask me that, I really can’t answer if they were

a manager, so to speak. There were people that may have been his manager that didn’t

work in a position that I would call a manager.

Q So let me ask you. Did you have an understanding whether or not someone was

Michael Jackson’s manager or were these just things you presumed? For example Tarock.

You said you thought he might be his manager. Did they ever tell you that?

A To me it was above the line, and below the line. That’s as clear as it ever got for

me. As I said, I was never really sure what position the line of responsibilities went above

the line. Because there were a lot of people around. A lot. There was Charles Bobbit. I

was never sure of their position. Nor did I ask anyone to clarify that to me.

Q So at various points you’ve been asked if someone was a manager. You’ve

indicated what role you thought someone was playing. So those are presumptions and not

something anyone ever told you?

Panish: Objection. Vague and assuming. A number of people have been named.

Judge: Overruled.

Q

Your distinction is above or below the line?

A

That’s one of the factors, sir. Yes.

Q

Now. After that you continue to work with Mr. Jackson. Another time -- a very

difficult time -- which was in the early 2000’s during the criminal trial.

A That was the mid-2000’s, I believe. Oh, the charges, yes. We were in Las Vegas

when that happened. When we found out.

Q

And what were you doing in Las Vegas, ma’am?

A

We were doing a short film, sir.

Q

What short film were you working on?

A

It was for a song off of Invincible, I can’t recall right now. [One More Chance]

It was so short. Because we --

Q

This is 2003. 2005 was the actual criminal trial, correct?

A

Correct.

Q

You continued to serve as Mr. Jackson’s hair and makeup person. You talked

yesterday about arriving there at 3am to help put his hair and makeup together for the

trial, correct?

A

Correct.

Q

You also said this morning that you were working with Mr. Randy Jackson. Was

that. Was this during that time period?

A I can’t say I was working with Randy Jackson. I was working on the website.

Q

This was the website conceived by Mr. Randy Jackson and Mr. Michael Jackson?

A

Correct.

Q

Were you also working with Tanya Zilkie on the website?

A

Correct.

Q

Ms. Zilkie who you said this morning was also your representative/agent?

A

That’s how we met.

Q

I just want to understand. You met working on the website?

A

We met over the phone first.

Q

You met over the phone. Was it regarding you coming to work on this website in

 

support

of Mr. Michael Jackson during the criminal trial?

A

Correct.

Q

Ms. Zilkie later comes to represent you as your manager?

A

Not a manager. She didn’t manage my career. It was after the trial. The trial was

over and Michael was acquitted. That time period we all spent together was very intense.

And we got very close, sir. And -- we said now what? We were picking up the pieces of

our lives after this. She was a good organizer and we had a good rapport on the website. I

asked if she would be interested in repping me. Not managing my career, not finding me

work, but a liaison for when things arose. It’s not good for artists to negotiate money with

your clients. I needed somebody to help me negotiate contracts.

Q Yesterday you said there was a time during the criminal trial when you became

concerned again about Mr. Jackson. Was that because of possible drug use?

A Sir, the signs were there.

Q What were the signs, ma’am?

A Him going to the hospital. The physical pain. Because when he was under stress

-- he could not sleep, his back hurt from the injuries, and -- just the emotional of having

to go through that. It’s bad enough for me here to talk about it. I can’t imagine what he

endured.

Q

So you started to have concerns. How long did the trial go on?

A

I think 3 months, or something.

Q

And during this time did you become increasingly concerned he was taking drugs

again?

A

I was increasingly concerned for his well-being, sir.

Q

And this morning you talked about praying together every day while getting him

ready, right?

A

Yes.

Q

During these endless times together, did you express your concern to Mr. Jackson

about him using drugs again?

A

No sir.

Q

And during any of those times, you said you were working with them at the time,

did you ever express a concern to Mr. Randy Jackson or Tanya Zilkie about Mr. Jackson

using drugs again?

A

I don’t think so, sir.

Q

And Mrs. Jackson -- Katherine Jackson. She was there every day of the trial, is

that right?

A

Yes sir.

Q

Did you go to trial during the day?

A

I wasn’t allowed, sir. I was on the witness list.

Q

Did you testify at the trial?

A

No I did not.

Q

Other than Randy Jackson or Tanya Zilkie, did you discuss your concerns about

Mr. Jackson’s drug use with anyone else?

A

Michael Bush.

Q

That’s the man who was dressing Mr. Jackson?

A

Correct.

Q

But never with Mr. Jackson himself, correct?

A

No sir.

Q

And is there a reason for that?

A

I have to go back to, the time I spent with him was a time of peace. Not

confrontation. He had to go into court. I didn’t see him other than that space in time every

morning. It was my job. It was my duty as a friend. To make that time and space as

peaceful and calm as I could before he had to go were he had to go. I didn’t want to

confront him with anything. And no matter what he was doing, I could never blame him

for that. Because of the pain. Physical, psychological, emotional pain.

Q Did Mr. Jackson ever ask you for any pain killers?

A He asked me one time.

Q

And what did you tell him?

A

I said no. I don’t.

Q

Did he ever ask you again for that?

A

Never.

Q

Did you say anything to him when he asked you for pain killers about your

concern about him doing drugs again?

A

No sir.

Q

Did you ever see Mr. Jackson use drugs during this time period?

A

No sir.

Q

Did you ever see him during this time where you thought he was on drugs?

A

When he went to the hospital, sir. It appeared that they had given him some sort

of pain relief.

Q

Any other time after the hospital when he appeared that way?

A

Well on pajama day it was really evident, sir.

Q

That was the day you took him back from the hospital?

A

No. I watched it on TV when he got out of the car.

Q

You saw him on TV, you thought he was under the influence?

A He went to the hospital. The pain increased. His stress increased. His weight went

down drastically.

Q

Did you have an understanding why Mr. Jackson went to the hospital?

A

Yes. He told me he was suffering extreme pain in his back.

Q

Did he indicate this pain was in any way associated with the fall in Munich?

A

Yes.

Q

But you didn’t believe him?

A

I believe that. I believed he was in pain. And I believe that when he got very

slender

and very weak, it aggravated that injury.

Q

Did a time ever come where Mr. Jackson admitted to you he ever had a problem

with drugs?

A

Admitted to me personally or admitted publicly, sir?

Q

Admitted to you personally, ma’am.

A

No sir.

Q

You said a time came where you had a conversation with Ms. Rebbie Jackson

about concerns about Mr. Jackson‘s drug use, correct?

A

Correct.

Q

Was it during this time?

A

As I said before, I can’t remember exactly what time period it was, sir.

Q

It happened at your house?

A

Yes it did.

Q

Did you reach out to her about your concern?

A

She reached out to me, sir.

Q

Did you have an understanding why she reached out to you?

A

Yes, she told me. She was asking me -- about her brother.

Q

Do you recall what you told her?

A

Everything I could, sir. I answered all of her questions.

Q

Do you know whether this happened after the criminal trial?

A

I told you before, I can’t recall. I really can’t. I don’t know. All in can say is, it

was probably between 1990 and 2005. I’m just not clear when this was. I wish I could tell

you. I really do. I mean, maybe Rebbie knows. Maybe she recalls. Ask her.

Q

Had you ever had this type of conversation with any member of his family

before?

A

Not to this extent.

Q

Did you ever have this type of conversation with any member of his family about

this after that prior to the time of his passing?

A

Wait. Between when and when?

Q

You said you had this conversation with Ms. Rebbie Jackson between 1990 and

2005. Did you ever have this type of conversation with any member of his family after

this conversation, up until the time of his passing?

A

I believe I had conversations, but in a very brief manner, with Randy Jackson

during

this time. I believe there were brief mentions with Randy Jackson because of the

trial situation during this time. There were concerns about his condition.

Q And do you know if anyone ever did anything as a result of those concerns? For

example: Was there any attempt to get him into rehab again?

A

It’s my understanding that there were.

Q

Is it your understanding that the family actually tried to get him into rehab?

A

It’s my understanding that there were efforts to help Michael.

Q

Do you have an understanding if that happened more than once?

A

It’s my understanding that there were several, sir.

Q

Is it your understanding whether or not they were ever successful in getting Mr.

Jackson to go into rehab?

A

I never knew that to be successful, sir.

Q