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JACKSON V AEG June 18

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Hearing prior to Kai Chase being called

Court: OK. Somebody wanted to talk to me?

Mr. Panish: yeah I do your honor. I mean I have multiple issues but I know the jury is coming in at 10.

Is it OK to bring it up now?

Court: yes you can.

Mr. Panish: well first obviously we need to finish Dr. Finkelstein the rulings and the arguments and such.

Court: yes. That's short. Was there

Mr. Boyle: well we each have a few more but I don't think it will take that long.

Court: I was hoping you could resolve them not come up with more.

Mr. Boyle: I know.

Mr. Panish: well that's par for the course. We have more.

Court: all right.

Mr. Panish: so the second thing is for tomorrow as witnesses I'm having a real problem.

My first suggestion would be

would work for him. Is that right you don't know yet?

And I discussed this with Mr. Putnam and he doesn't know yet whether it

Mr. Putnam: right. I'll try to check at lunch and see if I can reschedule Friday afternoon.

Mr. Panish: I was trying to see if it's possible to have half a day Wednesday and a full day Friday. For

two reasons: one I have witness issues and two Ms. Faye is going to take according to Mr. Putnam's

estimate at least a day. And maybe we could finish her on Friday if she came for the whole day. I don't

know if the court has plans. Mr. Putnam mentioned that he might have another matter but he's going to

see if it's possible at noon if he could reschedule that. Now I don't know whether any juror has made

plans in light of the scheduling so…

Court: this plan the jurors came up with it so we can ask.

Mr. Panish: and then if no one has made any plans and if Mr. Putnam can rearrange I would like to do

that if it's possible.

Court: OK.

Mr. Putnam what is it you need to do to see if…

Mr. Putnam: parenting.

Court: oh parenting issues.

Mr. Panish: I can relate to that.

Mr. Putnam: so see if I can be covered.

Court: you need coverage for Friday?

Mr. Putnam: exactly. I just want to check.

Mr. Panish: so if Mr. Putnam can work that issue out and assuming no jurors have a problem then we

have the issue of Mr. Leiweke which we want to play. I don't know in light of the court stayed here late

last night and it's been pretty busy today I don't know if the court had a chance to look at that.

Court: no.

Mr. Panish: and there are a lot of objections to Mr. Leiweke's transcript. So we need to somehow get that

figured out in time for tomorrow. I don't know how we're going to do that. Then there's…

Court: well he's not being

Is he being called live as well?

Mr. Panish: no. We're going to try to do it by video.

Mr. Boyle: depending on the rulings on the video we would play him by video. But as Mr. Panish

Said there are a lot of objections and if the video gets gutted then we'll have to call him live.

Mr. Panish: so we don't know about that issue. And then there's a private issue I need to discuss with the

court in chambers…

Court: OK.

Mr. Panish:

Which I've preliminarily discussed with Mr. Putnam but I want to discuss it with the

court. And Mr. Putnam and I have talked and we're going to further talk on that issue but I think I need

to raise that with the court.

Court: OK. Anything else?

Mr. Putnam: I have something your honor. So yesterday when alternate no. 6 came the

it sounded familiar. And so I went back into the transcripts to look at the prior two times he brought this

up. And what he indicated both prior times as well as this time is that he would be trying to buy the place

in Atlanta by the 28th of June. And if that was on schedule then he would have to be there august 28th.

And you informed him that second time that when he sold just to let us know which is what I think he

was doing. I don't think in light of that that there's reason to let him go at this point. If Mr. Panish is able

to keep to the schedule they've indicated I don't know what the evidence is going to show but I believe

timing-wise this shouldn't be an issue.

I thought that

Court: all right. We can ask him.

Mr. Putnam: and if it is I would like to revisit it in two weeks. One thing I'm sure of

other longer ones before

is prudent. I would hate more than anything for that to become an issue given how long we've done this.

And I've done

Once you start to lose you lose more. So the longer we can wait on that I think

Court: I can ask him further inquire say "initially you told us august 28th." he would be able to serve

until about that time. That's when he needed to return to Georgia.

Mr. Putnam: take up residency yes.

Court: and if that's still the case perhaps we can keep him. We'll talk to him.

Mr. Putnam: we can even tell him we can revisit it at the end of their case.

Mr. Panish: at the end of what?

Mr. Putnam: of your case.

Court: OK. So we'll revisit that with him. Half day and full day

When do you think you'll know?

Mr. Putnam: I have to find out

want me to do that before we ask the jurors? I can do that if you prefer.

I just have to get someone to cover me. I can get that at the break. You

Court: yeah. You can do that at the break.

Mr. Putnam: OK.

Court: but I want to make sure that it's doable before I suggest that to the jurors.

Mr. Putnam: in fact your honor while you're doing the objections I can go out and try to do it then.

Court: OK.

Mr. Putnam: is that all right with you?

Court: sure.

Mr. Putnam: OK.

Court: let's do the objections and then do the private issue when you come back.

Mr. Putnam: all right. I'll be right back.

Mr. Boyle: OK your honor. So one

Court: i'll need to get Finkelstein though. OK. All right. Let's talk about Finkelstein.

Mr. Boyle: OK your honor. So as an initial matter after all the rulings are done

court through all this work if it's going to be unnecessary but we're going to need to look at the script to

see if what we have left is enough and if we're going to have to have Dr. Finkelstein in live anyway. So I

apologize if that happens. I don't want you to think we're putting you through needless work. We'd like

to do this through video if we can but if there's some foundational things that will be kept out there are

And we hate to put the

some issues that we think we can lay the foundation live. But anyway where we kind of left off was the

court was going to sustain defendants' objection to page 66 line 23 through 67 line 7

Court: 66/23?

Mr. Boyle: correct. 66/23.

Court: I overruled that one unless I changed my mind about that one. But I'm looking at

at the correct thing? Yeah. Finkelstein page 66 lines 23 through 25 I overruled.

Am looking

Ms. Cahan: and your honor we had argued that yesterday and you had sustained it conditionally. That

was the one where Mr. Boyle said that he thought there was definitive testimony making the statement

that was stated in a speculative way and I think he found the definitive testimony. And it's our

understanding that in that circumstance your honor would sustain the objection since they have it in

another place where there is no an objectionable question and answer.

Court: I would overrule it if there is no prejudice to it.

Mr. Boyle: that was my understanding of what I was looking for because basically in 66 he's saying

Court: otherwise it doesn't make sense to delete it out of the deposition.

Mr. Boyle: right.

"is it a fair assumption that you would have told Mr. Gongaware what was going on?" and he says "yes."

So then your honor at lines

16.

Court: 53/21?

I'm sorry. Let's go back first. At lines 53

Page 53/21 through page 54 line

Mr. Boyle: correct.

"and sir when the second Bangkok show got postponed was it Mr. Gongaware that postponed the show?" the

witness: "I thought I postponed it. "OK. Well did you inform Mr. Gongaware of the situation with the artist?"

answer: "yes sir. "and what did you tell Mr. Gongaware in regard to the situation with the artist?" answer: "I

said 'I think we're going to have a problem.'" question: "and did you elaborate on that?" answer: "I don't

going to say 'yes' but I wouldn't know exactly what I said or

thought that Mr. Jackson had a dependency on opiates?" answer: "yes." so Bangkok was early on in the tour

which I mean when he assumed later in testimony he told him he did tell him.

I'm

" question: "well did you tell Mr. Gongaware you

So I think 66/23 should stay in.

Court: all right. I'll

It stays in.

Mr. Boyle: OK your honor. Then on that same line I would like to direct the court's attention to page 76

lines 21 through 24.

Court: 76?

Mr. Boyle: yes. 76 lines 21 through 24. And this is a question that was:

Question: "and it was your understanding that Mr. Gongaware was aware of the opiate problems that

Mr. Jackson was having; correct?" answer: "yes."

And so by that same token the fact that Mr. Gongaware told

Gongaware is the foundation for him understanding he's aware.

The fact that Dr. Finkelstein told Mr.

Court: OK.

Mr. Boyle: so I think that should be in. I think the objection should be overruled.

Court: let me just clarify. This is 76/21 through 24; correct?

Mr. Boyle: correct.

Court: OK.

Ms. Cahan: your honor the context of that one is a little bit different. They're discussing the period

between Bangkok and Mexico city that approximately three- to three-and-a-half-month period. And so

the testimony from Dr. Finkelstein was that he remembers telling Mr. Gongaware and others in Bangkok

at the very beginning of the leg of the tour "I think he may have a problem with opiate dependency."

and then he didn't treat

for that three-and-a-half-month period. So this question where it comes Mr. Gongaware was aware of the

opiate problems that Mr. Jackson was having that's discussed in that intervening three-and-a-half-month

period and that was the basis for the objection. Because it's not talking about what was discussed in

Bangkok. It's talking about what happened in the tour over that three and a half months. Mr. Boyle:

Bangkok happened first. That's where he gained the understanding. And then things happened like Dr.

Forecast broke into his bag to steal opiates for Michael. And so that's

think that has to come in.

Dr. Finkelstein didn't treat Mr. Jackson or provide any medical care to him

He had an understanding. I

Court: is your argument that Mr. Gongaware wouldn't have had an understanding in the subsequent

three months?

Ms. Cahan: so

Court: he's made aware but then he's otherwise not made aware the following three months?

Ms. Cahan: right. So the series of questions is

Bangkok "I think he may have a problem with opiates." then the tour goes on for three and a half

months Mr. Jackson is performing Dr. Finkelstein is not treating Mr. Jackson.

Mr. Gongaware is informed by Dr. Finkelstein in

Court: OK.

Ms. Cahan: he's not involved with his medical care. But these series of questions about the interactions

between Dr. Forecast and Dr. Finkelstein on the tour Dr. Finkelstein is traveling with

the doctor for all the 160 people on the tour and not for Mr. Jackson. So the series of questions makes

clear that although it's not stated in this one question and answer that the line of questions

question is really about the intervening three and a half months from Bangkok to Mexico city "were you

aware there was an opiate problem during that time?"

Dr. Finkelstein is

And this

Court: and why wouldn't Mr. Gongaware be aware of that?

Ms. Cahan: he was aware that there was a problem

Court: right.

Ms. Cahan:

Dr. Finkelstein had a concern about a problem in Bangkok.

Court: right.

Ms. Cahan: but there's no evidence whatsoever that anyone either Dr. Finkelstein or Mr. Gongaware had

an awareness of whether Mr. Jackson was continuing to uses opiates had been detoxed was using other

medications at that time.

Court: but isn't that an inference that can be drawn?

Mr. Boyle: I believe so your honor. What he became aware of in Bangkok was very severe and also other

things happened like the breaking into the bag of Dr. Forecast. And the question is just simply "is it your

understanding that Mr. Gongaware was aware of the opiate problem?" "yes."

Ms. Cahan: and that's

Mr. Boyle: you know.

Ms. Cahan: I'm sorry. Didn't mean to cut you off.

Mr. Boyle: so based on the prior testimony that he told Mr. Gongaware about it having an understanding

that he's aware I think is a perfectly reasonable thing to

Ms. Cahan: I think it's fair to let the jury draw the inference

Court: yes.

Ms. Cahan:

That if he knew in Bangkok he must have assumed things continued to happen. But here

Dr. Finkelstein is speculating about what Mr. Gongaware knew or didn't know three and a half months

later when there is not a foundation that either Dr. Finkelstein knew anything about Mr. Jackson's

medical care in the intervening three and a half months or that he discussed it with Mr. Gongaware to

the extent he knew something.

Court: OK. I'm going to overrule that objection.

Mr. Boyle: OK.

Court: that was 76/21 through 24; correct?

Mr. Boyle: yes your honor. Thank you.

Court: so are there similar

Mr. Boyle: no. Actually because of that I'm going to skip two of them then. I'm not going to do the one on

86 or 87. If your honor would go to

These will be quick. 73/24 to 25.

Ms. Cahan: that's not one that you had mentioned to me.

Mr. Boyle: 73/24 to 25 this is discussing Michael's opiate use. And there was a question that no one

objected to. And the question: "now is it a caricature (sic) flaw for someone to be addicted to opiates?"

answer: "no." so then a few lines later I asked

Court: "does it make him a bad person?"

Mr. Boyle: "would that make him a bad person?" right. And the objection was "unduly prejudicial." but

that only would mean that they are trying to prejudice Mr. Jackson by making people think he's a bad

person. And I don't see why we can't use an addiction expert to say you're not a bad person if you have

an addiction.

Court: well is it really relevant whether somebody is a bad person or a good person if they're using

drugs? I mean does that have any connection?

Mr. Boyle: well in this case

Court: you can be a good person and use drugs; you can be a bad person and use drugs.

Mr. Boyle: it goes to the noneconomic loss. I mean if you lose a loved one if they're

some bad scumbag bad person drug addict that might make it less

You know if they're

Court: that would make it less painful for someone who loses a relative because they're

Mr. Boyle: well that's part of the defense here. "ugly things will come out in this trial" "ugly things will

come out about Michael." and now we have a doctor saying "he's not a bad person because he was

addicted to opiates." I don't know how that's prejudicial for anybody.

Ms. Cahan: your honor to make the record completely clear we are not taking that position. And the

issue here is

experts who they can come testify. Dr. Schnoll was going to come at one point. He's not currently on the

48-hour schedule but presumably he will be coming or could come. The larger issue here is that Dr.

Finkelstein's testimony is clear that he treated Mr. Jackson twice in 1993 I believe he treated him once in

1995 for a back pain issue and then had no contact with him for 14 subsequent years until Mr. Jackson

passed. And so it really is irrelevant. It does lack foundation. And I have no objection to their addiction

expert offering

There are a couple issues. I think one is that they do have addiction experts retained

Their retained expert offering that testimony.

Court: when is it ever relevant whether someone is a good person or bad person? I mean either you're

liable; you're not liable; you're a drug addict; you're not a drug addict. But whether you're a good

person or a bad person

Mr. Boyle: I think in noneconomic wrongful death cases the jury evaluates the value of the loss and what

is lost. And the loss of a horrible person is probably you know not as valuable as the loss of a great

person. But more importantly it's to dispel the myth that addicts are somehow lesser people you know.

And this guy is a non-retained expert by the defendants and a non-retained expert by the plaintiffs. And

he's saying addicts aren't bad people. I don't see how that's prejudicial. I don't understand

Court: well you do have in here: "now is it a character flaw for somebody to be addicted to opiates?" I

allowed that. But "good person" "bad person" I'm going to sustain that.

Mr. Boyle: OK.

Court: you're free to argue that in closing.

Mr. Boyle: I understand. That will take care of a couple of them then. And then I think I just have one

more. So your honor one is 73

Page 70 line 3 through page 70 line 11.

Ms. Cahan: that was sustained as a hearsay objection.

Court: 70 line 3 through 7. OK. I see that. All right. Give me a minute.

Mr. Boyle: I just wanted to clarify. Is the reason the court sustained the objection based on hearsay?

Court: hold on. (reviewing document.) Well he goes on to say "you'd be calling

speculate." I think that's where I had the

"you'd be asking me to

"but if you want me to speculate the answer is 'yes.'"

Mr. Boyle: yes. I wasn't going to argue that part of it. I was just talking about 70/3 through 11:

"based on your communication with Dr. Forecast did you have an understanding that Mr. Jackson was

receiving pain medication on a consistent basis for the three and a half months between Bangkok and Mexico

city?" answer: "yes."

So Dr. Finkelstein did have an understanding that Michael was consistently getting medication for those

three months. And I think that fits in.

Ms. Cahan: classic hearsay your honor. And actually the points that I wanted to raise this morning are

related points about Dr. Forecast

What Dr. Forecast told Dr. Finkelstein.

Court: there's a lot of communication between Dr. Forecast and Dr. Finkelstein.

Mr. Boyle: but your honor an expert can rely on hearsay.

Court: well the other thing

Ms. Cahan: he's not a retained

Court:

This is all in connection with Michael Jackson's treatment isn't it?

Mr. Panish: yes.

Court: so I mean wouldn't it be somewhat well inherently reliable that they're talking to each other about

treatment for Michael Jackson?

Ms. Cahan: Dr. Finkelstein was not Michael Jackson's treating physician. He treated him on two

occasions when Dr. Forecast wasn't available: once at the beginning of the leg of the tour and once at the

end in Bangkok and Mexico city.

Court: OK.

Ms. Cahan: so they weren't having ongoing communications about Mr. Jackson's medical care. Dr.

Forecast is somebody plaintiffs could have located and deposed in this case had they wanted to. His

statements to Dr. Finkelstein are classic hearsay and we think that they are inadmissible. And it's here as

well as a couple other examples that I wanted to bring up with your honor.

Court: well are you suggesting

Well forecast and Finkelstein were on the same tour; right?

Mr. Boyle: correct.

Ms. Cahan: but

Court: and one broke into the bag of another. Sounds like they had communications

Mr. Panish: they did.

Court:

About Michael Jackson; right?

Mr. Boyle: correct. Correct.

Court: anyway

Well

Mr. Boyle: yeah. You know

Court: I went back and forth on this as I was reviewing this.

Mr. Boyle: Dr. Finkelstein did treat Michael on that tour even though he was the tour doctor and forecast

was more of a personal doctor. He did treat Michael Jackson. Finkelstein and forecast talked about the

treatment of Michael Jackson and his problems like you said. Forecast broke into Finkelstein's bag to

give him more drugs. I think Finkelstein having an understanding based on essentially a co-treatment

with Dr. Forecast that Dr. Forecast was giving Michael drugs is totally admissible and non-hearsay. Also

experts can rely on hearsay to form this understanding. And he's a non-retained expert for both sides.

Ms. Cahan: and your honor I don't believe that that hearsay

apply here. Experts are allowed to rely on hearsay in order to form opinions and offer opinions but

they're not allowed to backdoor hearsay in through sponsoring it in their expert testimony. So if Dr.

Finkelstein were to appear in the capacity as an expert and testify about you know "I had an

understanding that Michael Jackson had a drug dependency problem in the '90s both from my treating

him and from things that I was informed of" that would be permissible. But what he can't say is "and

one of the things I was informed of is was that Dr. Forecast told me" and that's hearsay and I'm not

hearing any exception.

That's a hearsay exception that would

Court: well isn't there an exception

But it does seem as though there's some inherent reliability when two doctors are talking to each other

about treating a patient as long as the conversation is at the time the treatment is being given that there is

some inherent reliability in that discussion.

I can't recall an exception for two doctors talking to each other.

Ms. Cahan: and I don't think there's any foundation that there was a discussion at the time any

treatment was being given except

up in Bangkok. Dr. Forecast had not yet arrived and so he gave Michael Jackson some pain medication

at the direction and over the phone with Dr. Metzger who was calling from California. So he had

interaction with Dr. Metzger at the time he administered medication to Michael Jackson in Bangkok.

Three and a half months go by he's not providing any medical treatment to Mr. Jackson. And at the time

he treated him in Mexico city again for an urgent pain issue was at a time when Dr. Forecast was not

available which is why Dr. Finkelstein stepped in. So it wasn't as though they are consulting physicians

treating physicians having a conversation about the best medical care to render to Michael Jackson. It's

one isolated incident before he ever met Dr. Forecast and one other isolated incident where Dr. Forecast

is out of Mexico city and unavailable to take care of Michael Jackson.

So my understanding from Dr. Finkelstein's testimony is he showed

Mr. Boyle: your honor I will also

says that he saw Dr. Forecast administer medicine to Michael so he was in the same room and saw it

happen. So that's another basis of his understanding. And I don't

there is treatment exception when you have two doctors essentially combining treatment on a patient it's

inherently reliable and that can come in.

Very shortly before that quote he also says that

Dr. Finkelstein

I can't cite it to you now but I think

Court: I'm not sure there's an exception but there's that catchall where if there's some reliability to it

And I went back and forth on that as I was reviewing all the various designations in terms of well is this

something that is inherently reliable because there's two doctors who appear to be communicating about

his treatment.

Mr. Boyle: and your honor also

Court: maybe not a lot but there's some

what they were doing at the time.

It appears that the communication was contemporaneous to

Mr. Boyle: and I think you know I agree with you your honor. And the final is 1250

1252 it's being offered to prove or explain the acts or conduct of the declarant. Prove or explain what Dr.

Finkelstein was doing because he had this information from Dr. Forecast and to prove why what he did

on this tour in Mexico city got the group together and said "hey Michael has a problem" et cetera et

cetera. That is a recognized hearsay exception in addition to the other reasons.

Evidence code

Ms. Cahan: and your honor I don't think that applies. I think Mr. Boyle is conflating the two situations.

The conversation that Dr. Finkelstein had with members of the tour about his concern about Mr.

Jackson's health was in Bangkok before Dr. Forecast arrived before anybody ever met Dr. Forecast.

Court: OK.

Ms. Cahan: and then the one other time he treated him was when Dr. Forecast was not there or available.

I don't think there is

there is an exception a catchall exception for inherently reliable testimony. And I don't think 1250 applies

here because although the conversations may go to Dr. Forecast's understanding of Michael Jackson's

medical condition there's no foundation that Dr. Finkelstein had any contemporaneous conversations

with Dr. Forecast the two times the two isolated times he treated Mr. Jackson or that any conversations

he did have with Dr. Forecast informed the way he treated Michael Jackson. He gave him pain

medication in Mexico city and had there been conversations about opiate dependency and what might or

might not be appropriate he did not testify as to whether the medical treatment the pain medication he

gave Mr. Jackson in Mexico city wasninfluenced by any understanding he had from Dr. Forecast.

I'm certainly willing to be corrected but I don't think in California state court

Mr. Boyle: your honor in fact

Sorry.

Ms. Cahan: sorry. Just to add something. Ms. Faye is someone who has testified about Dr. Forecast. She

has some pretty negative things to say about him. She recounted an incident where he grabbed her by the

throat and held her up against the wall and choked her which caused her to leave the tour for a time. So

to the extent that one is thinking about a situation of two physicians who are rendering medical care and

are sort of upstanding members of the profession I don't think the record is clear as to who Dr. Forecast

was or what his character was or the reliability of his statements is good.

Mr. Boyle: your honor on Ms. Faye I mean I'm glad to say they put so much faith in what Ms. Faye has

to say. I have a feeling on Friday they're going to do all they can to impeach Ms. Faye. But regardless of

that there is evidence they had continuing communications. In fact right above the section we're talking

about Dr. Finkelstein said: "and Dr. Forecast and I were in communications because we didn't want

Kind of want to take the hit for what other doctors had done before him"; right? So they were talking

about this the whole time. There was an issue.

Court: well is there a catchall?

Mr. Boyle: I think there's a catchall in

Ms. Cahan: more a federal.

Court: maybe in federal court. Is there such a thing?

Mr. Boyle: I think the court has inherent power also because if we can get this done we don't have to call

in a live witness.

Court: that's not a reason to throw out the hearsay rules because it's easier.

Ms. Cahan: your honor to be clear he wouldn't

be allowed in his live testimony either. There's no difference. If he comes in and sits here he's still not

allowed to sponsor hearsay testimony.

Our position is that if this is disallowed now it wouldn't

Mr. Boyle: we can say "based on everything you experienced with Dr. Forecast."

Court: why don't you do some research. I know you don't want to but why don't you do some research

and tell me whether

Mr. Boyle: there's a catchall

Court: catchall or maybe physicians' statements to each other. Something in the case law that might

discuss that.

Ms. Cahan: and your honor I don't want to take any more time on this but just for the record because

the jury is waiting the three points I did want to argue are also about things Dr. Forecast told Dr.

Finkelstein. And those are 129 lines 3 to 7; 129/23 to 131/5; and 136 line 24 to 137 line 8. And this is all

Court: yeah this was all towards the end. OK. I remember thinking about the issue. So OK.

Mr. Boyle: thank you.

Court: I would appreciate it if you would look and find out. There's probably something addressing this

in the case law.

Mr. Boyle: thank you your honor.

Ms. Cahan: yes your honor. We're happy to confer about that before we take up more of the court's time

on this.

Court: OK.

Ms. Cahan: thank you.

Mr. Boyle: thank you.

Court: so there's nothing immediate that

Mr. Boyle: I think all the ones we talked about will be covered if there's a catchall or the doctor thing.

Court: you can start cutting the video and leave those things out for now.

Mr. Boyle: correct.

Mr. Panish: any idea when you might be able to get to Leiweke?

Court: pardon?

Mr. Panish: when I might be able to address Mr. Leiweke?

Court: when? As soon as I can.

Mr. Panish: no. I just said any idea when you might have the time to do that? That's all. Court: maybe

tomorrow.

Mr. Panish: not until tomorrow. So we're not going to be able to play it tomorrow?

Court: probably not. I have six motions.

Mr. Panish: I'm just asking.

Court: I know.

Mr. Panish: if you can't do it I understand. I'm just trying to get a feel for the evidence. That's all.

Mr. Boyle: your honor do you know in terms of the new fire marshal rules if a party is having one lawyer

at the podium can they have two lawyers sitting at the table and just switch when the… does anyone

know the rule on that?

Court: I don't know what the rules are. I keep getting told one thing then ….

Mr. Panish: nobody said we couldn't do that.

Court: nobody said you couldn't do that.

Mr. Panish: OK. The clerk: we were told only four chairs at counsel table.

Court: no he's not saying to have a chair. He's saying one person at the podium

Mr. Panish: if we have four chairs we're not violating any rules.

Court: right. So if one person stands there and two are here I guess it's not a problem.

Mr. Boyle: OK. Thank you.

Mr. Panish: two and two.

Court: didn't you want to have a conference or something?

Mr. Putnam: before we do your honor I can tell you that I can switch Friday and Wednesday.

Court: OK. Good. Then we'll ask the jury.

Mr. Panish: thank you.

Court confers in chambers off the record…

thank you. Court confers in chambers off the record… Direct Examination by Ms. Chang Kai Chase

Direct Examination by Ms. Chang

Kai Chase

(Chef April 09 Then June 09)

Q.

Good morning Ms. Chase.

A.

Good morning.

Q.

Can you tell us what your current occupation is?

A.

I'm a professional Chef.

Q.

How long have you been a professional Chef?

A.

For about 17 years.

Q.

And who do you currently work for today?

A.

I work for Katherine Jackson and the Jackson children Paris Blanket and Prince.

Q.

OK. The oldest being Prince?

A.

Yes.

Q.

The middle being?

A.

Paris.

Q.

And the youngest being?

A.

Blanket.

Q.

All right. And prior to working for mrs. Jackson did you work for Michael Jackson while he was preparing

for the "This Is It" tour and living at 100 north Carolwood Drive?

A.

Yes I did.

Q.

OK. Is it all right with you today if I call it "the Carolwood house"?

A.

Fine. Yes.

Q.

All right. How long did you work for Mr. Jackson at the Carolwood house?

A.

I worked for Mr. Jackson for approximately two months.

Q.

All right. And was it continuous or was it separated?

A.

It was separated.

Q.

OK.

A.

I started at the end of March and was let go in May and brought back in June.

Q.

All right. So it was at the end of March for the whole month of April?

A.

Yes.

Q.

And then you did not work in may and then you came back in June

A.

June.

Q.

Is that correct?

A.

Yes.

Q.

And was that at the beginning of June?

A.

Yes it was.

Q.

Until his death?

A.

Until his death yes.

Q.

All right. Let's start a little bit and hear about your background. Can you tell us about your educational

background?

A. I started my culinary profession back early on at a small boutique culinary school called Epicurean. Before

that I worked as an interviewer for a music magazine called the Urban Network and took most of my clients

from that particular job with me into the culinary field Went to Paris France and studied at Le Cordon Bleu

where I got my master's degree there. And I came back to the United States and started a catering company

called "Kai Catering."

Q.

And when you say

Is that the Le Cordon Bleu Culinary academy in Paris?

A.

In Paris France yes.

Q.

OK. Can you tell me why did you want to become a Chef after working for I think you called it Urban

network magazine?

A. Yes. I come from a family of artists and entertainers so my artistic gift is the culinary profession and giving

back through my expression of love through food.

Q.

And that's your art?

A.

That's my art.

Q.

Tell us a little bit about Le Cordon Bleu Culinary academy in Paris.

A.

The Le Cordon Bleu in a very prestigious culinary campus in Paris France. It's been founded since the

1800s. And Julia Child is one of the famous Chefs to have graduated from this school.

Q.

All right. And I'd like to show exhibit 900.

Q.

By Ms. Chang: all right. And can you tell us is that you…?

A.

That's me.

Q.

And is this the famous Le Cordon Bleu culinary academy?

A.

Yes it is.

Q.

OK. There was recently a movie called "Julie & Julia"?

A.

Right. That was the famous school yes where she attended.

Q.

Meryl Streep?

A.

Meryl Streep yes.

Q.

Did you enjoy studying in Paris?

A. I loved Paris. I loved the sights the sounds the people the Chefs. It was a very very beautiful experience.

One that I will never forget. I still keep in contact with the friends there speak a little French. But the food was

amazing.

Q.

Did you learn a lot about food?

A.

I learned a lot about food and technique. And the overall experience was just beautiful.

Q.

And when did you graduate from Le Cordon Bleu?

A.

'97. 1997.

Q.

All right. And what you're wearing there is that the typical what I call the Chef's outfit?

A.

That is. That is the standard uniform for Chefs.

Q.

OK. And what did you do after you graduated? I think you said you started your own catering company?

A.

I started my own catering company when I returned to the states and started acquiring the clients from the

magazine that I worked for. So a lot of musicians producers film tv became my clients in the catering field yes.

Q. OK. And are you accustomed to working with people in the entertainment industry?

A. Yes. My godfather was Redd Foxx so I grew up as a little girl with you know feeding my godfather making

him little cakes and stuff for him. So that's just been part of my world.

Q.

And I think you told us you came from a very artist-oriented family?

A.

Very artistic yes.

Q.

Can you tell us some of the clientele

A.

Some of the clients I've cooked for President Barrack Obama being one; Bernie Mac Steve Harvey Macy

Gray Jaylyn Rose John Salley congresswoman Maxine Waters. The list goes on. I've worked with Wolfgang

Puck. I worked with Pamela Anderson in her restaurant. It was the same style.

Q.

All right. So it sounds like a wide variety

I heard a few NBA stars in there?

A.

Yeah.

Q.

Singers songwriters entertainers?

A.

Exactly.

Q.

All right. I'd like to show exhibit 901 And can you tell us what that is a picture of?

A.

That's the 1997 event that I did for President Barrack Obama for his inauguration.

Q.

He was here in Los Angeles?

A.

He was here in Los Angeles.

Q.

And how were you selected to be the Chef for President Obama?

A.

It was out of ten different caterers and executive Chefs. And I got the gig because I'm good.

Q.

Great. OK. And did you have a chance to meet with him?

A.

Yes I did.

Q.

And did you actually have a conversation with him?

A.

Yes I did. I was so honored as I am to work with any of my you know higher celebrity clients. Always

honored. But when I got a chance to actually meet him it was two pictures. We took a picture side by side And

then I was actually very lucky to get a second photo which was this one. And I got it in really fast so I started

saying to him the meal that I prepared for the cocktail reception that he was having and he was very

You

know he was pleased to see a young African-American female actually doing her thing. So that was

That

picture is of proud and honor.

Q. That's wonderful. OK. And can you tell us how long did you have your own catering company?

A. I had my catering company for

company down at that point because I was doing a lot of catering on TV and film sets. And the high-powered

security that the studios were having they weren't allowing a lot of outside caterers on the set. So my business

started to slow down and small businesses were not in demand at that

Since I came back to the states until 2001 when 911 hit. And I closed my

point.

Q.

Is that when restaurants also took a hit on 911?

A.

Right.

Q.

People weren't going out?

A.

Well yes. People were very fearful after that terrorist attacks.

Q.

So after you closed down your catering company where did you work after that?

A.

I worked for Wolfgang Puck catering events.

Q.

And just for some people here who don't know. Who is Wolfgang Puck?

A.

Wolfgang Puck you've probably seen his pizzas in Gelson's supermarket but Wolfgang Puck is a

Celebrity Chef worldwide.

Q.

And I think

Is there restaurants?

A.

Yes. He does the Oscars. He has Wolfgang Puck and Spago in Beverly Hills and Chicago.

Q.

And iron Chef?

A.

And also iron Chef.

Q.

He was.

A.

He was.

Q.

I want to also show exhibit 902 is that the Wolfgang Puck you were talking about?

A.

Yes. Me and my former boss.

Q.

Did you learn from him?

A.

Very much yes.

Q.

OK.

A.

He's very well-rounded and he loves to support up-and-coming Chefs. He's not afraid to pass the baton.

And he's well-

His favorite motto is "live love eat." so it's a celebration of food and good life.

Q.

How long did you work for Mr. Puck?

A.

Two years.

Q.

And what did you do after that?

A.

I went into the private Chefing world.

Q.

OK. Is that where you work as the sole Chef for someone?

A.

Yeah. I worked as a sole Chef for a CEO of a black-owned bank. One united bank he and his wife.

So I worked for them a few years after leaving Wolfgang.

Q. All right. Ms. Chase for all the training and experience that you've shared with us are you trained as a

Nutritionist?

A.

No I am not.

Q.

OK. Do you have any background in the field of nutrition?

 

A.

Um I have

Well not professionally but I have

You know I've studied

In the world of food I've

studied nutritional ways of life as far as vegetarianism veganism macrobiotics raw living foods things of that

nature. But as a Nutritionist I have no credentials for that.

Q.

In the culinary world is a professional Chef separate and distinct from a professional Nutritionist?

A.

Absolutely.

Q.

And you don't hold yourself out to be a Nutritionist?

A.

No.

Q.

OK. All right. Well after this experience how did you first become to be considered as a Chef for Michael

Jackson?

A. I got a phone call one day. This is right after I had left working for the CEO of One United

Bank. I received a phone call from a company called

Culinary Staffing. And they're a company I had used before with my catering company to hire out staff. So they

called one day and they said there was

A. Client looking for a professional Chef and they knew that I was of that status. The client was a

husband and wife and two kids. And the husband was a businessman. And would I be interested in the job. And

yes I was because I had already been Private Chefing for private clients and was looking for a new job. "can

you please send your resume over to us so the client could take a look at it?" I did just that. I got a phone call

back within an hour and they said "the client was very impressed with your resume and would like to meet with

you." So great. We set up a meeting to go meet at the Coffee Bean & Tea Leaf at the grove in Los Angeles.

And

It was a

Q. When you got there who did you meet with?

A. Well I didn't know who I was meeting with and the client didn't tell me. I don't know if they even knew. But

I met with a gentleman by the name of Michael Amir.

Q. OK.

A. So I was looking for this man named Michael and he didn't look like a businessman to me. He was young.

But I thought maybe this was the client. So we interviewed back and forth and he asked

me of course about nutrition about work schedules and things that you would speak about with another Chef.

Q. And you thought he was your client?

A. I thought he was my client. So I asked him I said "so you're the client?" And he said "no I am not. But this

is who you will be working for." and he gave me a card a business card and it said "The Michael Jackson

Company" on it. And when he handed me the card I was whoa you know. I was like wow this is really a big

honor honestly. And he said "the client was very impressed with your resume having come from working for

these people." this is how I in turn got the job to work for him.

Q.

Were you excited?

A.

Yes I was.

Q.

Did you have a second interview?

A.

Yes. I had a second interview which was at

The house on Carolwood.

Q.

OK. And who was present at this second interview?

A.

Well it wasn't Mr. Jackson. It was my junior clients which were Michael's children.

Q.

OK.

A.

And they interviewed me first.

Q.

And so it was just the three children interviewing you?

A.

Yes.

Q.

And it was Prince Paris and Blanket?

A.

Yes.

Q.

All right. At the time how old were they?

A.

Prince was 12; Paris was 10 11.

Q.

About to turn 11?

A.

About to turn 11. And Blanket was 9.

Q.

OK. I'd like to show exhibit 903

Q.

By Ms. Chang: and does this photograph fairly and accurately depict what the children looked like in 2009

when you met them?

A.

Yes.

Q.

All right. So why don't you

Why don't I start out. And this handsome fellow here to the left who is that?

A.

That's Prince.

Q.

OK. And he's holding hands with his sister and that's?

A.

Paris.

Q.

Is that Paris?

A.

That's Paris.

Q.

And Paris is wearing a hello kitty t-shirt?

A.

She loved pink and loved hello kitty.

Q.

All right. When you first started she was still wearing hello kitty and wearing pink?

A.

Wearing pink.

Q.

And this little guy to the right is?

A.

Blanket.

Q.

I want to show 931 now. And just so that we have an idea is this about the age and how they appeared

around the time their father died?

A.

Yes.

Q.

All right. And that's little Blanket there?

A.

Yes.

Q. N back in March of 2009 when tou're having your second interview with your junior clients where in the

house did the interview take place?

A. In the kitchen. There's a little dinette dining room kitchenette in the kitchen and we sat at the table there.

Everyone was talking

Q.

Was anyone else there?

A.

Their nanny Grace.

Q.

Is that Grace Rwaramba?

A.

Rwaraba. Yes.

Q.

And what was discussed at that interview?

A.

Well they were talking one over another. They were very excited. They had anticipated me coming And we

spoke about everything from food to video games and everything in between you know. But they wanted to

make sure that I knew how to prepare healthy meals because that was what they and their father eats and that's

the way they eat. "We eat healthy. We don't eat any pork we don't eat any beef. Can you fix vegetarian? Daddy

likes apricots we like fruit Blanket likes mangos." And they were very more so into making sure that I knew

what was required for their healthy living.

Q.

And did you pass your interview?

A.

I certainly did.

Q.

OK. And did you feel like you had a connection with them at that time?

A.

Yeah. It was really interesting because it felt like immediately a bond. We were developing. It just felt like

this is a place I need to be here. And it was a beautiful

a beautiful beginning.

Q.

And that was approximately when that this interview took place?

A.

The end of March.

Q.

End of March of 2009?

A.

2009 yes.

Q.

And when did you start working?

A.

The very next day.

Q.

All right. So I first want to take you through the first segment of your employment which would be the end

of March to the end of April 2009. In your first month there as a Chef for the Jackson household can you tell us

what your duties and responsibilities were?

A. My duties on a daily were

the kids prepared meal-wise and get their dad's breakfast ready as well. Breakfast lunch and dinner is what I

was to prepare and snacks. And also clean up keep the pantry well stocked and grocery shop. Those were my

duties.

I would arrive at the home at 8:00 between 8:00 and 8:30 in the morning to get

Q.

And how many days a week were you at the Carolwood house?

A.

I started with seven days.

Q.

That's tough.

A.

Yeah. That was very tough. I started with seven days and then eventually moved to six days having Sundays

off.

Q.

All right. And what were your hours? You said you came in about 8:00 or 8:30. What time did you go

home?

A.

Around that month I would go home around

It fluctuated. 6:00 8:00. Around those times.

Q.

Was there anything

What had to be done before you could go home?

A.

Well clean up. You know they'd have dinner first. After the dinner was done then I'd remove the

plates off the dinner table clean up put the dishes in the dishwasher straighten everything and go home.

Q.

Like in most households did dinner time fluctuate?

A.

Yeah.

Q.

Sometimes it could be on time and sometimes it was a little later?

A.

Depending. Depending on work schedules and things like that. But yes.

Q.

What was the normal lunchtime?

 

A.

12:30.

Q.

And what was the normal dinnertime?

 

A.

5:30

6:30. 6:30. Sorry.

Q.

And do you remember meeting Michael Jackson for the first time?

A.

Yes. I met him about a week

No a few days into a week later. I was at the home and he had come

downstairs. He had some guests waiting for him in the parlor and they were getting ready to discuss his travel

arrangements to go to London.

Ms. Bina: objection. Hearsay. Move to strike to the extent she talks about what other people were

discussing.

Court: overruled.

Q. And what was your first encounter like with Mr. Jackson?

A. He came down the stairs. I in turn was bringing a silver platter of beverages bottled water for the guests.

And we kind of had this introduction like bumped into one another. And I don't know if this is the way he

wanted to meet me but we kind of looked at each other like hey "how are you" kind of like thing. And he

One of the gentlemen said to him "this is your Chef" you know. "have you met your Chef before?" And he said

"I'm meeting her for the first time." but he had been in and out of the house. So that was the first introduction.

And after that it blossomed into a client/friendship relationship.

Q. How often would you say he interacted with you?

A. More so on a daily you know. He was very much hands-on in his children's life and their nutrition. So he'd

always come down into the kitchen in the mornings in the afternoons. We'd hold conversations about healthy

eating juicing that kind of thing. And just life. People places. He wanted to get to know the woman who was in

the house that was feeding him and his family.

Q.

Did he seem interested in you and who you were?

A.

Yes. Yes.

Q.

All right. Did you have the opportunity during that month and also during the month of June to observe

Michael Jackson and his children together?

A.

Yes I did.

Q.

And how would you describe that relationship?

A.

It was very loving. It was very loving and very

They were together a lot. These children were his world

you know. Out of all the words to all the songs in the world those children meant everything to him. When he

would come home from maybe working in the studios back in April

lunch would be served. He'd have lunch with his children privately at a beautifully-set table. And they'd sit

together. They would crack jokes. They would tell stories. They'd play together in the house. But everything

those children meant the world to him.

he was in the recording studio a lot

the

Q. Can you describe what the household was like when you were there in April of 2009?

A. The house was very warm. It was a good feeling a good energy of love in the home. Fireplaces in the rooms

in the den in the parlor in the sitting room in the dining room were always going.

Q. With a fire?

A. With a fire. And music would play in the home. Sometimes Disney music would escalate from the echoes

of the stairwells or something. It was a beautiful place and the energy

what he always wanted.

It was a good feeling there and that's

Q. Was it always disney music or a variety?

A. No. It was never always Disney. We played K-earth 101 in the kitchen. Like we'd hear the stones and David

Bowie and things. And then he would have classical in other parts of the house. But you know he's a musician

so it's quite right.

Q. And you mentioned that he liked to have meals with his children. And did you serve the meals and set up for

the meals?

A. Every day yes.

Q. And how did he like to have meals with his children? Can you describe that?

A. He liked the meals with his children to be just comforting. I mean this is their time to bond. This was their

time when daddy comes home from work after a busy day. This is his time with his children privately.

Q.

You said it was beautifully set. Did you have something to do with that?

A.

I set the table.

Q.

And did he like creativity in settings?

A.

Yes. He had a lot of different table cloths different creative types of napkins and glasses and plates so I

would always try to make it fun. I'd try to make it fun and tried to make things just a beautiful setting. Change

the color of the tables with the napkins and glasses so every time they sat down at the dinner table it would be a

new experience.

Q. And did you try to make it educational for the children as well?

Ms. Bina: objection. Leading.

Court: overruled.

The witness: yes I did. We would sometimes eat in other parts of the country. So say for instance one day we

would have East Indian food but we would discuss what part of you know India we were eating from. Or I'd go

into the kitchen and I'd write the menu on a chalkboard that was sitting on the island in the kitchen of what the

meal was for the day so the kids could understand and learn about food.

Q. By Ms. Chang: they learned different words for food?

A. Yeah. They would learn different words depending

remember one time Blanket he climbed up on the chair

the chalkboard was sitting. So he climbs up there to read what his menu was going to be for dinner. And he said

"A puree? What is a puree?" And I said "No. A puree of soup." so now he knows what soup puree is. So the

education kept going.

Say if I were making a potato puree soup

And I

There was a chair around the end of the island where

Q. So when you got there at 8:00 to 8:30 did you have a typical day?

A. Well the typical day was getting what needed to be done on time and

Fashion yes.

You know in a timely

Q. OK. And you indicated that the children had school. Did they go out to school or were they home-

schooled?

A. The children were home-schooled. And depending

Friday. So every day was a different day. Mr. Jackson loved to keep it creative for them since they were home-

schooled. So say Monday it would be reading day you know. Or Tuesday it would be more maybe arts and

crafts day. Wednesday would be movie day. Maybe we would

write about that. So every day of the week was something different just to

greater knowledge for them.

They were home-schooled from Monday to

They would see a classic movie and have to

For educational purposes and for

Q. Did they learn creative writing?

A.

Yes.

Q.

Did they learn science?

A.

They learned a lot of skills children needed for school yes.

Q.

And math?

A.

Math science current affairs.

Q.

And foreign languages?

A.

And foreign languages yes.

Q.

And was there a teacher that came in?

A.

Yeah. They had a teacher that would come in in the mornings and leave in the afternoon. And then one of

the days whatever day that was they would go into theater day or whatever else. But they were constantly being

educated.

Q. And did Mr. Jackson share with them things that they learned or discuss with them things they learned?

Ms. Bina: objection. Lacks foundation calls for hearsay.

Court: overruled.

A. He would. You know the interaction and the development of a young child's mind is very important to

children of a smaller age. So him being the father that he is he took great pride in helping develop you know

the foreign languages or whatever they were taught in school and whatever they needed to

teaching them as far as film and art and that nature.

What he was

Q. From what you observed in being at the home every day did the kids get on the internet and watch tv a lot?

A. No. The children were not allowed to watch television. And I don't think that

those types of fathers you know. TVs computers that was nothing that they were interested in doing.

Mr. Jackson wasn't one of

Q. And being in the household with the Jackson family what did you observe as to how he was as a

father? Was it all fun and games or did they have

Was he a disciplinarian? How would you describe it?

Ms. Bina: I'm just going to object. Not trying to break up the flow. She said that she served meals.

There's no foundation for a broader

Court: sustained.

Q. OK. Let me ask you a question Ms. Chase. Did you just stay in the kitchen cooking or did you spend time

with the children throughout the entire house?

A. Uhm I stayed a lot

plan in the home so where the kitchen was it extended to the den where the children would play a lot. So on

some of my breaks down time I would interact with the children and play you know games monopoly and that

kind of thing. So it kept the bond of us more like family.

Most of the time in the kitchen doing a lot of the cooking. But it was an open floor

Q. And did they share things with you in the kitchen of what they were learning and what they were

doing?

A. Yes. Again it was an open floor plan so they could come and interact with me I would interact with them. I

would teach them more about food and technique and they would teach me a lot about games and playing. And

sometimes we'd go in the backyard and play on my breaks. And we had a nice time at the house.

Q.

You were like their friend?

A.

Their friend.

Q.

And from where you were in that open layout of that first floor did you have a chance to see and

observe Mr. Jackson with his children?

A.

Yes.

Q.

And at mealtime?

A.

At mealtime sometimes because he dined with them privately. But a lot of the time in the den. He

would go into the den and sometimes they would bring the bird. They had a bird that did a lot of talking. And

the dog. So it was more of a family home setting there. So in the den it would be the dog and Mr. Jackson and

the children and the bird and it was just a beautiful experience always.

Q. And did you get to see him when he came home for example from a long day and see him greet his

children?

A. Yes. And that was something to cherish because seeing those children run up to their father when he would

walk through the door of the living room

and they'd run and grab him around the ankles and around the waist and he had kids hanging. And just the love

was the most beautiful thing you could ever see. It would bring tears to my eyes so much love there.

He'd walk through the door and they would take off like lightning

Q. And from the time period that you observed them throughout the first floor and seeing them both at

mealtime and otherwise was it all fun and games or did they have a schedule and did they

that expected them to follow the rules?

Was he a father

A. He was a disciplinary when it was needed. Especially when it was school. If they had school the children

had to be in bed at a certain time. Now as all children "oh I don't want to go to bed" they wanted to stay up but

this was not something

school at a certain time and on time. And they respected their father for that you know. They respected and they

obeyed him.

He was disciplined with being in bed at a certain time making sure they were at

Q.

And was he fun also?

A.

Oh he was fun. He was fun.

Q.

Were they allowed to eat sweets every day

A.

No.

Q.

And anything they wanted?

A. No. That was a no-no. Sweets were only dictated when he said and that was very rare. Mondays through

Fridays

Monday through Friday Saturday and I did very healthy meals during the week. So I had written him this letter

saying that you know possibly could we do a comfort food Saturday so that the kids and we can all eat things

that are not so healthy like you know some fried chicken or maybe some

And he loved it and he gave me a

thumbs up for that. So we had comfort food Saturdays. It breaks up the monotony of always healthy eating.

I remember this story if I can tell. I remember this story. I had written him a letter because I worked

And it's good for the kids you know so that the kids don't start abusing unhealthy eating habits.

Q.

And did they look forward to that day?

A.

Yes.

Q.

Was that their favorite day?

A.

Yes.

Q.

Did they have sweets on weekends?

A.

That was very rare but a little bit yes.

Q.

OK. From what you observed did Mr. Jackson instill in his children any instruction as to how to live their

life?

Ms. Bina: I'm going to object. Lack of foundation on this.

Court: sustained.

Q. By Ms. Chang: did you observe activities that the children did in your presence for others?

A. Mr. Jackson always made it a point

giving and loving nature. So he would always instill the property of "how do you see yourself giving back?"

First of all he was a very giving

Has a very giving spirit very

Ms. Bina: objection. Hearsay lack of foundation. Same issue.

Ms. Chang: your honor it's not hearsay. It's not used for

of instructional motivation rather than the truth of the matter asserted "how do you see yourself

Giving back?" there's no truth or non-truth.

It's not even

It's words of action it's words

Ms. Bina: I still haven't heard the foundation for it. Did she observe Mr. Jackson giving speeches to the

children? Did the children repeat it?

Court: sustained on foundation.

Ms. Chang: all right

Q. D you observe the children doing activities for others and hear conversations with their father regarding

giving to others?

A. Well when he would ask me how do I see myself giving back this is something that I know that he instilled

in his children. And Paris the giver that she is I would observe her

She'd go get clothing

that maybe she wasn't wearing or using anymore. And she'd sit there with a little sewing kit and she'd cut maybe

I saw her always

jeans or shorts that she wasn't using anymore and cut them to make them into little skirts and hand sewed them.

One day I asked her I said "what are you making there? That looks creative." She said "I'm making these little

skirts that I'm going to put in a box and ship overseas and give to others that are more underprivileged." And

that was a beautiful thing.

Q.

You mentioned that they had a bird that talked

A.

Lot. Were there a lot of animals in the household?

A.

A lot. We had a few animals and the bird was very cute. Siberia.

Q.

You said there was a dog. What kind of a dog was there?

A.

A chocolate lab.

Q.

Kenya?

A.

Kenya. And we had a bird Siberia. A. Talking bird. So cute. He whistled when pretty girls would come by

especially me. He would go "woo-hoo" you know. So we got a kick out of that the kids and I did. And Prince

had a rat. A rat he would walk around the house. So the kids loved animals. We had two cats. Katie and

Thriller. Thriller was the black cat and Katie was the orange cat. And the children were very responsible in

taking care of their pets. Feeding the

cookbook for dogs. You know a cookbook for doggie treats. So for Kenya's birthday we made a cake just for

the dog. You know a lot of interactive fun stuff we would do.

Feeding the cat feeding the dog. Sometimes

we went and got this

Q. Now when you indicated that you would play with the kids outside did you also engage in activities with the

kids outside regarding animals with Paris?

A. Yes. The cats were you know outside. They had a rabbit. So she had a little dollhouse that her daddy had

bought for her and the dollhouse sat in the grass by the little lake. So little tea parties with the animals.

Sometimes the dog would swim with the kids when it was swim time on Saturdays. So it was just really

family affair.

just a

Q.

And did Paris like all animals?

A.

Yes. The children do. Mr. Jackson does yeah.

Q.

All right. And was there ever an occasion that you and Paris were looking for a science project or

little animals that you thought you might get in trouble?

A. Oh my goodness yeah. You know there was an incident where she and I we sort of were creating for school

a science project for snails. So we decided to do a you know a snail hunt in the middle of the night you know.

So she

daddy snail but we don't have a mommy and baby snail." So we go outside with these massive flashlights and

we're looking for snails and we collected all these little snails. And so we're coming back up the stairs into the

house and there stands their father. And at that point I knew I was going to get fired. It was like this is not good.

I'm going to get fired. But he was fine. That's fine and he interacted with his daughter. "let me see what you

have here." What we decided to do is we got glass vases put moss down put little cocktail umbrellas and we

made a family of snails and put it in the kitchen. It looked like children lived there. We had Blanket's art

coloring on the refrigerator door and a snail farm on one of the counters like any family would that has children.

I was leaving work and she asked me she said "we've got to go outside to get snails. So far we have a

Q. And did Mr. Jackson get involved in putting the little cocktail

A.

Yes he did. Anything that was creative that way he participated in.

Q.

What was his personality like when he was home with the kids?

A.

His personality with his children was always interactive. It was always interactive. And it was always just

warm and loving. And it was just a day to day these are my babies. These are my babies. And he engaged in

games. He played games and we played Monopoly. And at dinnertime

his children when he came home.

But everything was surrounded around

Q. Did he have a sense of humor?

A. Yes he did. A huge sense of humor. They

things that

the kitchen cooking getting ready for dinner and Paris comes into the kitchen and said "you have to come quick

into the den. Your boyfriend is here." I knew I didn't have a boyfriend at the time so I said "OK." this will be

interesting to see. So I go into the den where everybody is sitting and there's this huge bust from her

(indicating) to the head of Ed Hardy kind of a manikin sitting at the bar wearing a white wife beater some Ray-

bans and they had turned the lights down. So by the time I walked in there I see this figure but I'm not sure.

And the lights go up and I screamed like "oh my gosh." something like that. Mr. Jackson jumps out from

behind a chair Blanket's jumping up and down "we got you we got you we got you." and then everyone's

laughing.

So you know at that point I'm like OK I'm getting somebody in this house back.

He was a practical jokester you know and that was one of the

I had no idea. So one time I was in

Because he would always catch you off guard. Especially

Q. And like in most homes was the kitchen a place where the whole family liked to be?

A. Well the kitchen is the nucleus of the home. the kitchen is the nucleus of every home. People come into the

kitchen to have camaraderie and to speak and to

kitchen was. Not

where

the kitchen.

You know to generally be together. And that's how this

Even though it was an open floor plan I made it a home there you know. I made it to

the energy was already good but I brought more love into it by putting the children's art and things into

Q.

Snails?

A.

And the

But in jars yes.

Q.

I'd like to show exhibit 904. Can you tell us what that is?

A.

That's the chalkboard where I would write the menu for the day. And this right here is Paris's writing.

Q.

I'm going to show a laser there. Right there or the whole thing?

A.

The whole thing.

Q.

Can you read us what it says?

A.

"I love daddy." it was "love daddy" at the top; second line "I love daddy." "Smile. It's for free." and that's

how the household was every day.

Q. And in fact was this what was on the chalkboard the day that Mr. Jackson died?

A. I can't recall.

Q.

OK. Fair enough. What kind of

is that the kind of messages that was at the house when you were there?

A.

Well when I would erase the menu she would put something like that for just love. More love.

Q.

What kind of food did Michael Jackson like you to prepare for him?

A.

Mr. Jackson

Considering he was getting ready for this tour he wanted to stay strong well and of course eat

very healthy. So he did

vegetables and fruits. He had a lot of lean proteins a lot of vegetables and overall nutrition throughout the day.

I did a lot of juicing for him a lot of beet juice. A. Lot of organic juicing with

Q.

When you say "lean proteins" was that mostly chicken and fish?

A.

Chicken fish and turkey. No pork and no beef.

Q.

Was that the same for his children too?

A.

Same for his children yes.

Q.

OK. Did he have a particular favorite meal that you'd make for him?

A.

He enjoyed a lot of the things that I made. In particular he was very much into Mexican. He liked Mexican

food a lot. So considering you know he wasn't doing the beef or the pork I decided to do a vegan ground beef

tacos. So it consisted of blue corn tortilla shells vegan ground beef guacamole salsa. That kind of thing. And I

remember making the plates for him where he had three tacos. Prince always wanted to be like his Dad so he

wanted the same portion the kids had less. But he was biting into the taco and he couldn't believe

"are you sure it's not beef? It's amazing." so you know that was one of the favorites that I would repeatedly

make a lot.

He said

Q. And just to torture us a little can I show

Exhibit 905 Is this the famous tacos?

A.

Those are the tacos.

Q.

And that was his favorite meal?

A.

That was one of his favorites yes.

Q.

Did the kids like it also?

A.

Oh yes. The kids loved that.

Q.

Now in April of 2009 which is the first full month that you worked there did the family celebrate a birthday?

A.

The family celebrated Paris's birthday.

Q.

And I think you said it was her 11th birthday?

A.

She was turning 11.

Q.

And what day was that?

A.

It was a Friday I believe. Yes.

Q.

And was that the first week of April?

A.

Yes.

Q.

All right. And can you tell us about that birthday party? Well first let me ask you: what happened on that

day? What kind of event did you have planned?

A. Well that day was

anything you want today. It's your birthday." And considering we're having a birthday party at the house we

decided to decorate the dining room into the theme that she wanted. And what she wanted was

was the theme of the birthday. So we scrambled around putting up Michael Jackson posters and album covers

taped to the walls and decorated the table very pretty with colored glass and balloons everywhere and played his

music because this is what she wanted for her 11th birthday. So when she came in and she was surprised with

the surprise happy birthday there was cheese pizza and hot wings and banana splits and just things that kids love

They ate you know they had

a great time.

that they don't eat on the norm you know. So this was a big you know celebration

Since it was a birthday it was

Mr. Jackson had told his children "you can eat

Her daddy

Q.

Did she have a birthday cake?

A.

She had a birthday cake.

Q.

What did she want on her birthday cake?

A.

Well at the time her favorite was Lilo & Stitch the cartoon Lilo & Stitch. So we had a cake designed by

Hansen's cakes. And it had the Lilo & Stitch on the front and she was ecstatic. So they ate. They had a beautiful

time. And just when you thought that wasn't enough he took his children to the backyard which he had this

whole setup of a beautiful Cirque Du Soleil type performance for her.

And I just remember looking out the kitchen window at this performance where it was just

my eyes. It was him and his children. They walked down the stairs and there were gentlemen on stilts and a

woman in a big balloon like a circus act. And they sat there and they watched this private circus For her

birthday and I cried.

brought tears to

Q.

Why did you cry?

A.

Because it was the most beautiful expression of love I've ever seen.

Q.

And that was the last birthday Paris had with her father?

A.

That was the last birthday she'd had with her father.

Q.

And you're working for them now. Do you know if she's ever had a birthday party like that since?

A.

No. Paris hasn't had any birthdays since.

Q.

She doesn't want to celebrate?

A.

She doesn't want to celebrate that way.

Q.

Now in April 2009 how would you describe Mr. Jackson's appearance as far as his health and

Energy level?

A.

In April?

Q.

In April.

A.

Mr. Jackson was very

He was very upbeat. He was very excited about what was to happen about the tour

about having his children see him perform this greatest comeback tour. He'd come down in the kitchen

sometimes and speak to me and talk to me a whole conversation. He would be dressed sharp. He would have

black Levi's on and a tweed blazer glasses on Tom Ford cologne. Just energized and the Michael Jackson that I

know him to be.

Q. And you said that he sometimes went to the studio. Did you ever see or observe him creating music in the

house?

A. They had a studio

guest house into a recording studio.

He had a studio set up

Q. Did you go there?

There was a guest house on the property so they turned that

A. Sometimes I went back there to bring him his meals because he would be back there getting the album ready

and laying down tracks or you know hearing tracks over. So I'd go back there. Got a chance to listen to some of

the tracks feed him his food. And he would actually ask "how does this sound to you? I'm excited. It's going to

be the best comeback tour." So I was privy to some of that at the time.

Q. And were you asked by him or the family to go with them to London for the "This Is It" tour?

A. I was asked

if you would accompany us to London as the Chef?" And I was honored for that and graciously said "yes."

Prince actually told me that his Daddy wanted me to go. And he said "Daddy wants to know

Q.

Were the kids excited too?

A.

Yes they were excited. They wanted me there.

Q.

Did you

You said you tried to make foods in other countries. Did you turn to British food?

A.

We did a little bit of that. Getting ready to go to London we did a couple of the shepherd's pie. We did some

fish and chips. We practiced our British Cockney accent. So we had fun getting prepared for the flight and the

trip over there.

Q. And around this time period Paris's birthday and for the first two weeks of April was the nanny

Grace Rwaramba also there?

A.

Grace was there the first week or two of April and then I didn't see her after that.

Q.

OK. And did you observe Grace's relationship with the children?

A.

Yes.

Q.

And did you gain an understanding of how long she had been their nanny?

Ms. Bina: objection. Relevance.

Court: overruled.

A. Grace and the children's interaction was very warm and loving. This is the mother that they knew. This is the

mother that

So this is the mother that they knew and they treated her as such.

She had been with the children and with Michael for years. She was there when they were born.

Q. Did there come a time when you learned that Grace had been terminated by AEG live?

A. Yes.

Ms. Bina: objection. Lacks foundation.

Court: sustained as to

Q.

Did you gain some knowledge while you were working there that Grace Rwaramba the Nanny

A.

Right.

Q.

Had been terminated?

A.

Yes I did. I was told that she had been let go.

Q.

OK. And were you told by which entity?

Ms. Bina: objection. Calls for hearsay.

Court: it does. Sustained.

Ms. Chang: all right.

Q. Did you ever learn why Grace had been terminated?

A. No.

Ms. Bina: I'm going to object on the grounds in the motion in limine.

Court: I'm sorry?

Ms. Bina: the motion in limine.

Ms. Chang: can we have a sidebar your honor?

Court: OK. Let's have a sidebar.

Q.

Did there come a time Ms. Chase when you were also let go?

A.

Yes. I was let go in May.

Q.

OK. And when in May?

A.

The beginning of May.

Q.

All right.

A.

First week in may.

Q.

Can you tell me the circumstances of how you were laid off?

A.

I was let go by Mr. Michael Amir. At the time they were preparing I believe for an earlier departure to go

over to London and they were trying to make sure of the different employees that were going to be

accompanying Mr. Jackson. So at the time I knew I was one of the ones and I mentioned to Mr. Amir you

know. He had asked me "what is your situation with pay to go overseas?" So he had discussed a pay rate with

me and he said "OK. Let me get that approved." He comes back and he lets me know that "there's been a

change in management and you therefore are not going." I begged and I pleaded with him. I even said to him

"my rate's negotiable at this point. I have been getting Mr. Jackson

healthy and getting him ready for this tour. So my rate's negotiable. You have to work with me." That wasn't

the case. He said to me "Sorry. We're letting you go. There's a change in management. There's nothing I can do

about it."

Feeding him healthy and his children

Q. Did he indicate to you what that change in management went from to what?

Ms. Bina: objection. Calls for hearsay.

Court: sustained.

Q. What was your understanding of the change of management?

Ms. Bina: same objection. Calls for hearsay.

Court: sustained.

Q.

And was it in preparation for the "This Is It" tour?

A.

It was in preparation for the "This Is It" tour yes.

Q.

Were you told this in person or over the telephone or by e-mail?

A.

I was told this on two occasions. first I was told that

In person "let me see what I can do if it's negotiable."

Then the next day I was coming in to work. I was getting in the car to drive to the home and I got a phone call

from Mr. Amir saying "there's no need to come in. We're not going to use you. You're fired." And I asked him

why. And once again you know "there's a change in management. We're going to get someone else."

Q.

All right.

A.

And I pleaded with them. "these are the hands that feed him and his children. You cannot do this."

Q.

Did you ever get to say goodbye to the children?

A.

No I did not.

Q.

Or Mr. Jackson?

A.

No.

Q.

And did you ever have a personal discussion with Mr. Jackson about all of this the salary any of that?

A.

No I did not.

Q.

During this time period that you worked in April did you receive your pay on a regular basis?

A.

No I did not. The pay was very sketchy.

sometimes I would be paid on time; sometimes I wouldn't get paid

at all.

Q. And did you ask Mr. Amir for an explanation for that?

A. Yes I would. And he would always say to me "just be patient. Everyone hasn't gotten paid either" Which I

didn't believe. But you know what could I do?

Q.

Did he also attribute that to the change of management going on?

A.

Yes he did.

Q.

OK. And do you know whether or not Mr. Jackson knew that you were let go?

A.

I believe he did not know.

Q.

And why do you say that?

A.

Well because that wouldn't

I don't believe that that would happen in that way.

Q.

And in fact when you came back did he indicate to you whether he knew you had been let go?

A.

No he did not.

Ms. Bina: objection calls for hearsay.

Court: overruled.

A.

No he did not.

Q.

By Ms. Chang: did he tell you he knew?

A.

No. When I came back

I came back in June and the way I came back is the kids and Mr. Jackson were

requesting me to come back. I don't even believe that he knew that I was gone. But the kids were requesting he

was requesting me to come back. And by the time I did come back at the top of June he came to me and pulled

me to the side and said "I had

healthy. I need you to keep me and my children healthy."

Where have you gone? I had no idea that you left. I need you to keep me

Q. Did he ask for your help?

A. He asked for my help. He said "I need you to keep me healthy. I'm working hard. They're killing me. I need

you to keep me healthy."

Ms. Bina: I'm going to object and move to strike all of that as hearsay.

Court: overruled.

Q. All right. before we get into that Ms. Chase let me ask you this: you were let go during that first week of

May. Did you work at all in the Carolwood house in May?

A.

No I did not.

Q.

Did you ever see Mr. Jackson at the Carolwood house in may?

A.

No I did not.

Q.

Or the children?

A.

No.

Q. OK. How was it that you were asked to return in June of 2009?

A. In June the beginning of June I received a phone call from Michael Amir the same one who hired me and let

me go. I received a phone call from him saying that "Mr. Jackson and the children are requesting you to come

back. The energy in the house is not the same."

Q. Now first I want you to

would you describe his physical condition when you last saw him?

The time that you left Mr. Jackson in April you described him as upbeat. How

A. In April?

Q. Yes.

A. His physical

And

He was strong. He was healthy he was active. He was interactive with a lot of us.

Yeah. He looked good.

Q. All right. now before I get into June did you reach an agreement with Mr. Amir on your new pay terms on

the tour?

A. Yes. When we spoke on the phone about my return I spoke to him about me possibly getting

what my wages would be to come back and me possibly getting half of my salary upfront as

very nervous about not getting paid again.

you know

because I was

Q. Did you write him an e-mail?

A. I wrote him an e-mail and put all of this in writing just to make sure we were on the same page.

Ms. Chang: all right. Let's just show counsel 627-27.

Ms. Bina: I object to this your honor as hearsay and irrelevant.

Ms. Chang: your honor can we have a sidebar?

Court: Don't

let me look at it first.

Ms. Chang: OK.

Court: (looks at document) Is that the totality of it?

Ms. Chang: yes. There's also a reply from Mr. Amir which I can show you now.

Court: OK.

Ms. Chang: 627-28 just for the judge and counsel please.

Court: (looks at document) OK. Your objection?

Ms. Bina: it's hearsay your honor and irrelevant.

Court: I wouldn't say irrelevant but it could

hearsay.

Ms. Chang: can we have a sidebar your honor?

Court: all right.

Ms. Chang: or do you think this would be

Court: let's go to sidebar.

Ms. Chang: OK.

LUNCHBREAK

(hearing in open court, outside the presence of the jury):

Ms. Chang: I am happy to report, your honor, that Ms. Stebbins and I met, we conferred, and we agreed and

stipulated to I'm going to ask a series of three questions. The first one will be leading by stipulation, and to work

out our deal, no emails will be shown, but the question will be asked as per agreed. And then I will go into two,

and then move on to another area. So we're all in accord. And I did have a case -- I had a case that I shared with

her, and it's all good.

Ms. Stebbins: The case I think was actually on a different issue, but we've agreed on the factual

foundational problem and we've got an answer.

Judge: Okay. And the witness is aware of what she --

Ms. Stebbins: So I've been told.

Ms. Chang: By agreement, I said I'm going to go and make sure we had no problems, and she

understands.

Judge: Okay.

Ms. Chang: And I got an assurance that there will be at least three questions that will not have an

objection.

Judge: Okay. I think you said that would end the examination, or --

Mr. Panish: No.

Judge: No. There's more. You just said you were done with that area?

Ms. Chang: That area, yes.

Mr. Panish: Okay. So tomorrow, we're coming in after -- the afternoon, right? Because judge has a

busy calendar in the morning, correct?

Judge: Is that what we decided?

The Clerk: I thought we switched Friday for tomorrow, Friday half day for tomorrow.

Mr. Panish: Right, right. But only in the afternoon.

The Clerk: Yes.

Mr. Panish: So then we really have only the video of Finkelstein, but it looks like potentially that Ms. Chase

could carry over. I want to let judge know that. And then Thursday, I guess, we're going to have to start a little

later because a juror has an interview, so it's possible --

Judge: 10:30, I think she said she'd be here, at the earliest.

Mr. Panish: So it is what it is. So thursday's witnesses potentially do carry over to friday, but Ms. Faye, we still

have to be here whenever that witness is done to go right on on Friday.

Judge: Well, I think if we're not done with whatever witness is on the stand, we should proceed with Ms. Faye

just so we can get her done.

Mr. Panish: The problem is he's coming from Boston, a doctor.

Judge: That's all right.

Mr. Panish: Well, he's going to have to go back to Boston and come back again.

Judge: No. He'll just stay in LA. And follow after Faye. How much longer --

Mr. Panish: Mr. Putnam thinks he could be a day with Ms. Faye.

Mr. Putnam: Yes. That's what I said always.

Judge: What's wrong with the doctor waiting a day to go back to Boston, right?

Ms. Stebbins: Stay in town over the weekend, I think is what she's --

Mr. Panish: Well, I haven't -- I haven't -- I don't know the -- I assume he's teaching class, I assume he's busy,

but I will check on it. But depending how much time is left, if Ms. Faye doesn't finish, she's going to have to

come back, I understand that, but we have a full day. I guess I shouldn't have even brought it up. Let's just wait

and see what happens.

Judge: I think that's a good idea.

Mr. Panish: I was just trying to anticipate the schedule, so -- anyway.

Judge: Was Ms. Faye -- was cross examination commenced?

Mr. Putnam: I had just started.

Mr. Panish: They did a half day.

Ms. Stebbins: She was two full days of testimony.

Mr. Panish: No, she was not.

Ms. Stebbins: He got in a couple of hours. I have the numbers somewhere actually tallied up, how many each

side. But just to have -- but there's a substantial amount of time on direct. Cross had begun, and it had gotten

partially under way, and I think it was the afternoon, and then --

Judge: Okay.

Mr. Panish: I'm not at this time yet arguing with how much time he has. Obviously, we'll wait and see, but I've

never objected they're taking too long. We'll see what he does. But he had begun, and he says he has a day, so

we'll just see what happens.

Judge: Okay.

Mr. Panish: She was not on for two days, I recall.

(back to open court, in presence of jurors)

Continued direct examination by Deborah Chang:

Q. Ms. Chase, before the lunch break, we were discussing you coming back to the Jackson household. Let me

ask you, did you decide to come back because you understood that AEG Live would be covering your salary in

England?

A.

Yes.

Q.

All right. And were you given a form thereafter to fill out for the UK entry permit by Mr. Amir?

A.

Yes, I was.

Q.

And what was your understanding of who that request came from to fill these papers out?

A.

My understanding was that was from AEG.

Q.

Okay. And that was the tour promoter that you understood it to be?

A.

Exactly.

Q.

Okay. So after you had a deal, so to speak, did you return to the Carolwood house?

A.

Yes, I did.

Q.

And could you tell us approximately when you did return to the Carolwood house?

A.

I returned June the 2nd.

Q.

All right. Now, previously I had asked you what Mr. Jackson was like when you had left in April, and now

I'm going to ask you did you notice any difference in Mr. Jackson in June of 2009 from the last

time that you had seen him.

A.

Yes. I noticed that Mr. Jackson -- he looked very different.

Q.

How did he appear to you?

A.

He appeared very -- very weak. He looked very much thinner, he looked undernourished, and he

didn't look as well as I had seen him in April.

Q.

Would you say that the -- this was a subtle difference or an obvious difference?

A.

It was an obvious difference.

Q.

Okay. Did it alarm you?

A.

Yes, it did. It concerned me greatly.

Q.

Did you talk to Mr. Jackson that first day?

A.

Yes, I did.

Q.

Did he give you any specific instructions?

Ms. Stebbins: Objection, hearsay.

Ms. Chang: Actually –

Judge: Is it concerning nutrition, or –

Ms. Chang: Yes.

Judge: Overruled.

A. He came to me and he asked me -- actually, he told me -- he said, "I need you to keep me healthy. I don't

know why you left, I don't -- I need you to keep me and my children healthy." I looked at him with great

concern, and I felt bad, but he -- he was saying, basically, "I need you to take care of my health and feeding me

healthy and feeding my children healthy. They're killing me." So when he said that to me, I thought that he was

being overworked, he was over rehearsed.

Ms. Stebbins: I'm going to object and move to strike the portions that don't relate to her instructions,

specifically, "I need you to keep me and my children healthy and they're killing me." That's hearsay.

Judge: Okay. Motion granted, the answer is stricken.

Ms. Chang: Your honor, just in response to that, she had already testified that he said, "They're killing

me," and it's actually not hearsay because whether or not they were killing him or not, it's just his state

of mind and physical condition at that time, pursuant to --

Judge: Motion granted. The answer is stricken.

Ms. Chang: Okay. I have a case for later, but -- I will provide it.

Judge: Okay.

Q. In any event, when you came back and you noticed these changes in Mr. Jackson and you talked to him, did

you assure him that you would try to keep him healthy?

A. Yes. Actually, I said to Mr. Jackson -- he asked me, he said, "Do you have my beet juice ready? Do you have

my juices ready? You know, I need you to keep me healthy, I need to be strong for this tour." and I said to him,

"Yes, I do. As a matter of fact," and I started naming off a string of different juices that I had already prepared

when I got there. And he was getting -- he sounded excited. He said, "That's what I'm talking about. That's it.

Tell me more. Tell me more," that kind of attitude.

Q. Now, did you notice any changes in the pantry when you got there?

A. When I arrived at the home, you know, the first thing a chef does, checks out the environment, checks out

what's needed for grocery shopping. The pantry was bare. There was two sides to the pantry. One side, I stored

all the Fiji waters. Fiji is a very high-end water. Large, medium and small bottles. There were none. On the

other side of the pantry lined were like pantry goods and staples. They were gone. And the refrigerator was

bare. There were coca-colas, Red Bull and Starbucks coffee drinks, which I know Mr. Jackson was not

drinking, or his children, because I never bought those items.

Ms. Stebbins: I'm going to object, lacks foundation as to whether Mr. Jackson and his children were

drinking those items.

Judge: Sustained.

Q.

Had you ever seen in the time period that you were there any of the children or Mr. Jackson drink Red Bull?

A.

No, never.

Q.

All right. And so did you go to the grocery store to restock the pantry and the refrigerator?

A.

Yes, I did. I went to the whole foods market, is where I shop most of the time to buy all the

organic ingredients for him and his kids. While there, shopping -- two full carts of groceries. Now, working

there, I had a credit card which whole foods provides for chefs for private -- private clients.

It's called a shopping for others account. And what they do is they put a credit card on file, the actual chef is a

signer on the card, so whatever would be the limit for that day, that's it, you sign your name and you go. So I

got to the check-out, pulled my -- pulled the account up, tried to sign for it, the credit

card was declined.

Q. Okay.

A. So at that point, I had no other choice but to pull out my own money and pay for the groceries to feed him

and his family.

Q. All right. And did you try to ascertain later why the credit card was declined?

A. Well, I had asked Mr. Amir what was going on. That was the first time. But it happened a few times after

that again.

Q. Okay.

A. And I never had an answer. "Don't worry about it." Sometimes I'd have to leave the groceries at the market

and couldn't come home with groceries, or I'd pay for them myself, or get what I could sparingly and bring it to

the house.

Q. All right. And this change in Mr. Jackson that you observed, did you observe anything while you

were there in June that indicated to you that he was having difficulty going upstairs or being in pain?

Ms. Stebbins: Objection, leading.

Judge: Overruled.

A. Mr. Jackson, with his rehearsals and his schedule, I could see that it was taking a toll on him. And, you

know, one day I did observe his son Prince, the eldest, actually having to help him up the stairs into the den area

where the children would play. At that point, he looked very thin, he looked very weak. And for a 12-year-old

to be trying to carry his father into an area to still play with them like they used to, what they used to do back in

April, it saddened me, and I knew that I had -- I had to get this man as healthy as possible, but I did not know

why he was deteriorating this way.

Q.

Did you ever see Mr. Jackson need his son's help going upstairs in April?

A.

No, never.

Q.

Did you share your concerns with anyone?

A.

I shared my concerns with my parents, because it was concerning me. I didn't know who I could talk to at the

home, so -- but my -- it concerned me, so I talked to my parents about that a lot.

Q. Did you have the same type of conversations with Mr. Jackson in June as you did in April when you

talked about food and music and family?

A. Well, the conversations became very -- well, they weren't limited, but they were very far and few in between,

knowing that his rehearsal schedule was so intense that we didn't have as much of upbeat

conversations as we did in the past.

Q. Now, I asked you about Mr. Jackson's reaction when you came back. Were the children glad to see you

back?

A. The children were excited to see me. As a matter of fact, the day that I did come back, they greeted me at the

door and were happy to see me. Paris had created a beautiful box called -- it was a shoe box called the Box of

Happiness.

Q. Did she make that herself?

A. She made it herself.

Ms. Chang: Okay. I'd like to just show counsel exhibit 907.

Ms. Stebbins: That's fine.

Ms. Chang: Okay. Let's show that.

Q.

All right. Is this the Box of Happiness that Paris made you?

A.

Yes, it is.

Q.

Okay. And what was inside the Box of Happiness?

A.

What was inside were a lot of little stuffed animals and coloring books and bubbles and things that we used

to play with together. So it was kind of like, "Glad that you're back, let's pick up where we left off, we missed

you, we love you."

Q.

Did you make it a practice of keeping things from the kids in this Box of Happiness?

A.

No.

Q.

Okay. Did they write you notes periodically?

A.

They would write a lot of notes, a lot of thank you letters. Again, these children were very -- very much

givers.

Q. Okay.

A. And very -- they appreciated and understood --

Ms. Chang: Okay. Exhibit 908.

Ms. Stebbins: The only thing I would ask on 908 is the foundation as to when it was created.

Ms. Chang: Yes, that's my first question.

Ms. Stebbins: Before we show it.

Ms. Chang: Let's show the witness exhibit 908, please.

Judge: Can I see it, too?

Ms. Chang: Of course.

Q.

Looking at the screen, do you recognize this letter?

A.

Yes.

Q.

And what month was this written in, in April or June?

A.

June.

Ms. Chang: Okay. And do you have any objection?

Ms. Stebbins: No.

Ms. Chang: Okay. Let's show this. There we go. Okay.

Q.

And do you want that blown up, or can you read it to us? First, tell us, who is this note from?

A.

It's from Paris Jackson.

Q.

Okay. And can you read that note to us?

A.

This says "Dear Kai, thank you for those beautiful gifts you gave us. Oh, and I'm writing this letter with

the magic wand pen you gave me. I hope you like the presents and the pictures, and thank you for the

presents for P.," Prince, "B.," Blanket, "and Daddy. They like them. Lots of love, Paris Jackson.

P.S., The theme of Pirates of the Caribbean is called 'He's a Pirate' from the first movie."

Q. Okay. Can you tell us what led to this letter?

A. Actually, this kind of began when I had all seven days I was working, and when I finally was able to have

my first day off, I went to Disneyland, which is one of my favorite amusement parks, so -- so I went to

Disneyland, and I brought the kids back some gifts. As I said, you know, they were home

schooled, and they stayed a lot in the home, and we played a lot, so I brought back magic wand pens and a lot of

books on art, literature, and -- artistic books from Disneyland. So that's what that was. She's thanking me for the

pen I gave her. And the gift I gave to Mr. Jackson was a table book, "The Art of the Pirates of the Caribbean,"

because he was very much into art and the type of mystical pirates thing.

Q. Did the family like "Pirates of the Caribbean"?

A. That's when the movie came out, as -- close to when the movie came out, so we had a debate. It was Paris