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  • Jackson V AEG Live Transcripts-June 28th Karen Faye-MJ Make-up/Hair

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    TeamMichael
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    Judge: counsel, you have anything you need to speak to me about? No? Mr. Panish: just that we're calling... Ms. Faye is coming back. Judge: yes. So she is going to be the first one? Mr. Panish: yes. Mr. Panish: yes. Ms. Faye is here, and Mr. Putnam was in the middle of his cross-examination, so we're going to resume with that. Judge: OK. Ms. Faye, would you come forward? Karen Faye, recalled as a witness by the plaintiffs, was previously sworn and testified as follows Judge: and, Ms. Faye, you understand you're still under oath? A. yes, I do. Judge: very well. All right. You may begin. Mr. Putnam: thank you. Cross-examination (resumed) Q. Good morning, Ms. Faye. A. Oh, good morning, Mr. Putnam. How are you today? Q. Good. How are you? A. So far so good. It's nice and cool in here. So we'll see how it goes, huh? Q. During the course of the day you might feel a differently, but we'll get to that. A. I remember that. Q. It's a little better now. We have the fans. A. Oh, great. Q. A lot has Changed in the seven weeks since you've been here. A. Has it been that long? Q. Seven weeks. Because it's been seven weeks... you were here may 10th... I started to ask you some questions, but there had already been two days of testimony, so what I'm going to try to do is not recover any of that. I'm going to try to ask you if you remember certain things, if I have to, and if you don't, we may have to go back to it. But have you done anything to prepare in the seven weeks? Have you looked... for example, did you read your transcript of what you said at trial?

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    Judge: counsel, you have anything you need to speak to me about? No? Mr. Panish: just that we're calling... Ms. Faye is coming back. Judge: yes. So she is going to be the first one? Mr. Panish: yes. Mr. Panish: yes. Ms. Faye is here, and Mr. Putnam was in the middle of his cross-examination, so we're going to resume with that. Judge: OK. Ms. Faye, would you come forward? Karen Faye, recalled as a witness by the plaintiffs, was previously sworn and testified as follows Judge: and, Ms. Faye, you understand you're still under oath? A. yes, I do. Judge: very well. All right. You may begin. Mr. Putnam: thank you. Cross-examination (resumed) Q. Good morning, Ms. Faye. A. Oh, good morning, Mr. Putnam. How are you today? Q. Good. How are you? A. So far so good. It's nice and cool in here. So we'll see how it goes, huh? Q. During the course of the day you might feel a differently, but we'll get to that. A. I remember that. Q. It's a little better now. We have the fans. A. Oh, great. Q. A lot has Changed in the seven weeks since you've been here. A. Has it been that long? Q. Seven weeks. Because it's been seven weeks... you were here may 10th... I started to ask you some questions, but there had already been two days of testimony, so what I'm going to try to do is not recover any of that. I'm going to try to ask you if you remember certain things, if I have to, and if you don't, we may have to go back to it. But have you done anything to prepare in the seven weeks? Have you looked... for example, did you read your transcript of what you said at trial?

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    Jackson V AEG Live Transcripts-June 28th Karen Faye-MJ Make-up/Hair

    Transféré par

    TeamMichael
    Judge: counsel, you have anything you need to speak to me about? No? Mr. Panish: just that we're calling... Ms. Faye is coming back. Judge: yes. So she is going to be the first one? Mr. Panish: yes. Mr. Panish: yes. Ms. Faye is here, and Mr. Putnam was in the middle of his cross-examination, so we're going to resume with that. Judge: OK. Ms. Faye, would you come forward? Karen Faye, recalled as a witness by the plaintiffs, was previously sworn and testified as follows Judge: and, Ms. Faye, you understand you're still under oath? A. yes, I do. Judge: very well. All right. You may begin. Mr. Putnam: thank you. Cross-examination (resumed) Q. Good morning, Ms. Faye. A. Oh, good morning, Mr. Putnam. How are you today? Q. Good. How are you? A. So far so good. It's nice and cool in here. So we'll see how it goes, huh? Q. During the course of the day you might feel a differently, but we'll get to that. A. I remember that. Q. It's a little better now. We have the fans. A. Oh, great. Q. A lot has Changed in the seven weeks since you've been here. A. Has it been that long? Q. Seven weeks. Because it's been seven weeks... you were here may 10th... I started to ask you some questions, but there had already been two days of testimony, so what I'm going to try to do is not recover any of that. I'm going to try to ask you if you remember certain things, if I have to, and if you don't, we may have to go back to it. But have you done anything to prepare in the seven weeks? Have you looked... for example, did you read your transcript of what you said at trial?

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    JACKSON V AEG LIVE June 28

    th
    2013
    Karen Faye testimony
    (Michael Jacksons Make-up Hair)
    Ju!e" counsel, you have anything you need to speak to me about? o?
    #r$ %anish" !ust that "e#re calling$$$ Ms$ %aye is coming back$
    Ju!e" yes$ &o she is going to be the first one?
    #r$ %anish" yes$
    #r$ %anish" yes$ Ms$ %aye is here, and Mr$ Putnam "as in the middle of his cross-e'amination, so "e#re going
    to resume "ith that$
    Ju!e" ()$ Ms$ %aye, "ould you come for"ard? )aren %aye, recalled as a "itness by the plaintiffs, "as
    previously s"orn and testified as follo"s
    Ju!e" and, Ms$ %aye, you understand you#re still under oath?
    A$ yes, * do$

    Ju!e" very "ell$ +ll right$ ,ou may begin$


    #r$ %utnam" thank you$ -ross-e'amination (resumed)
    &$ .ood morning, Ms$ %aye$
    A$ (h, good morning, Mr$ Putnam$ Ho" are you today?
    &$ .ood$ Ho" are you?
    A$ &o far so good$ *t#s nice and cool in here$ &o "e#ll see ho" it goes, huh?
    &$ /uring the course of the day you might feel a differently, but "e#ll get to that$
    A$ * remember that$
    &$ *t#s a little better no"$ 0e have the fans$
    A$ (h, great$
    &$ + lot has -hanged in the seven "eeks since you#ve been here$
    A$ Has it been that long?
    &$ &even "eeks$ 1ecause it#s been seven "eeks$$$ you "ere here may 23th$$$ * started to ask you some
    4uestions, but there had already been t"o days of testimony, so "hat *#m going to try to do is not recover any of
    that$ *#m going to try to ask you if you remember certain things, if * have to, and if you don#t, "e may have to go
    back to it$ 1ut have you done anything to prepare in the seven "eeks? Have you looked$$$ for e'ample, did you
    read your transcript of "hat you said at trial?
    A$ ,es$
    &$ ,ou did? 0hen did you do that?
    A$ Just periodically over different times, sir$ * can#t tell you e'actly "hat dates they "ere$ *t#s kind of like in
    bet"een "ork and stuff "hen * had a chance to glance over that$
    &$ Ho" did you get that?
    A$ Ho" did * get that? ,ou guys sent me a copy$
    &$ o, * didn#t$
    A$ ,ou sent$$$ your company or something sent me copies of it$ ,eah, you did$
    &$ 5his trial?
    A$ (h, not the trial$ * thought you meant the deposition$ *#m sorry$ * totally misunderstood you$
    &$ 5hat#s ()$

    A$ &o it#s a deposition that * "as looking over$


    &$ &o over the last seven "eeks, you "ent back to look at your deposition testimony?
    A$ ,es$ ,es, * did$
    &$ +nd ho" many days "ere you deposed for?
    A$ * think * "as deposed "ith you for four or five days, * think$ +nd then * think * talked to the plaintiffs for,
    like, * think, one day$
    &$ +nd so you had about five or si' days of deposition?
    A$ 5hat#s a pretty good estimate, yes, sir$
    &$ +nd it "as those transcripts you "ent back to look at in the last seven "eeks?
    A$ ,eah$
    &$ 1ut you didn#t look at "hat you said in the courtroom over the last seven "eeks?
    A$ o$ * did not look at that$
    &$ /id you go back to look at any e'hibits or anything over the last seven "eeks?
    A$ (h$ My phone#s not off$ -an * turn that off?
    &$ (f course$
    A$ *t !ust "histled at me$ (turned off cell phone$) ()$ *#m sorry$
    &$ 1etter no" than later$
    A$ -an you ask me that 4uestion again?
    &$ ,es, * can$ *n terms of the last seven "eeks, *#m trying to see ho"$$$ "hat you did to prepare so * have
    some sense of ho" much * have to go through$ /id you go back to look at any of the e'hibits in the last seven
    "eeks?
    A$ 5he e'hibits of "hat "as sho"n in court?
    &$ ,es, ma#am$
    A$ o$
    &$ o? &o "hat about meeting "ith plaintiffs# counsel? /id you meet "ith them in the last seven "eeks or
    talk on the phone?
    A$ * briefly met "ith them today$
    &$ 5hat#s all? &o "e may have to do a little more of "hat occurred$ 0e#ll see$ /o you remember "here "e
    left off last time?

    A$ * don#t, sir$
    &$ ()$ 0e "ere trying to go chronologically through your relationship "ith Mr$ Jackson$
    A$ ()$
    &$ *t "as June 63378 all right? 5he criminal trial, you had been there every day, arriving around 9:33 in the
    morning, "ashing his hair, prayed, cried$ ,ou remember?
    A$ ,es$
    &$ +nd he got ac4uitted, and you "ere in the hotel$ 5hat#s ho" you heard about it$ ,ou didn#t talk to Mr$
    Jackson, didn#t see him again, didn#t speak "ith him, and he left the country$ ,ou remember that?
    A$ -orrect$ o$ * did speak "ith him on the phone$
    &$ ,ou did?
    A$ He called me a fe" times, probably about every three or four months$ He "ould call me or send me a
    present on the holidays or things like that in bet"een that period of time$
    &$ 5hat#s "hat "e#re getting to$
    A$ (h, *#m sorry$ 1ecause you said * didn#t have anything$$$ * didn#t talk to him bet"een that period of time,
    and * did, so$$$
    &$ * "as actually$$$
    A$ $$$ * "as correcting that$
    &$ * "as still in June 6337$
    A$ ()$ June$ ()$
    &$ &o you hear he "as ac4uitted?
    A$ -orrect$
    &$ ,ou don#t talk to him at that time$ He leaves the country?
    A$ * didn#t talk to him that day$
    &$ He leaves the country?
    A$ ;h-huh$
    &$ +nd so you believe he left right a"ay8 correct?
    A$ 5o my kno"ledge, he left pretty soon after that$

    &$ <ight$ +nd you didn#t talk to him bet"een the time he "as ac4uitted, "hile you "ere there, until the time
    he left8 right?
    A$ -orrect$
    &$ +nd, again, this is June 6337$ o", did that upset you in any "ay? 5hat you had been there every day
    helping him, but he gets ac4uitted, but he doesn#t call you or talk to you but !ust leaves the country?
    A$ *t didn#t upset me, no, sir$
    &$ 0hy is that?
    A$ He had been through a horrible, horrible ordeal, and * "as by his side$ +nd to me, "hatever he had to do
    to recover from that "as fine$ He had said all his thank yous all along the "ay, you kno", and "as appreciative
    of everything that * did "hen "e "ere together during that time$ &o * really understood that he "anted to leave,
    so * didn#t feel bad$ He needed to be "ith his family$ He needed to spend time "ith his children$ * thought that
    "as far more important$ +nd *$$$ frankly, * !ust didn#t feel that * needed to be thanked or any kind of gratitude
    to"ards "hat * did$
    &$ &o it didn#t upset you?
    A$ o$
    &$ +nd he leaves the country$ /o you kno" if he ever returned to everland after that?
    A$ +s far as * kno", he never did$
    &$ +nd did you ever return to everland after that?
    A$ o$
    &$ +nd you didn#t see him again until +pril of 633=8 correct?
    A$ March, +pril$$$ * think that#s about right$
    &$ &o "hen he moved back to >os +ngeles in late 633?, you didn#t see him then?
    A$ 1ack in +pril$$$ no$ o, sir$
    &$ +nd "hen he moved into -arol"ood at that time, you didn#t go over to -arol"ood and see him at the
    time, correct, in late 633??
    A$ o, sir$
    &$ 5he first time you sa" him "as +pril 633=?
    A$ -orrect$
    &$ +nd$$$ but he had returned to the states before then$ *n fact, he returned to the states in 633@8 right?
    A$ * don#t kno"$

    &$ ,ou don#t kno"?


    A$ o$ * "asn#t keeping track of "here Michael "as, really$ * mean, it#s, like, * have a life, you kno", and he
    has a life, and my life didn#t$$$ doesn#t revolve$$$ didn#t revolve around him$ He "as a big part of it, of course,
    but, like, * have a child, * have a family, * have "ork$ &o * "asn#t, like$$$ you kno", * "ould read things in the
    ne"spaper and stuff, but that#s about it$ * didn#t make an effort to go see him or anything$ * mean, he called me, *
    think, from >as Aegas and said, B"e have some pro!ects * "ant you to be involved in,B and stuff$ +nd * said,
    Bgreat$ Just call me "hen you#re readyB kind of a thing$
    &$ ,ou said you talked to him every three months8 right?
    A$ 5hat#s an estimate$ * couldn#t be e'act on$$$ you kno", * "ould say about three, four months, you kno"$
    Maybe five months "ent by$ &o that#s !ust a guesstimate, sir$
    &$ 5he last time you "ere here, you told us you "ere like a brother and sister8 right?
    A$ * felt that that#s "hat our relationship "as like$
    &$ o", in these times that he called you from Aegas and asked you if you could "ork on pro!ects "ith him,
    did any of those pro!ects come to be? /id you ever come to "ork "ith him during that time period?
    A$ 0ell, B5his *s *tB came up$
    &$ &o you did eventually in 633=8 correct?
    A$ ;h-huh$
    &$ >et#s talk about that$ &o it#s 633=$ Ho" did you come to learn that the B5his *s *tB tour "as being put
    together?
    A$ * sa" it on television$
    &$ +nd "hose program did you see?
    A$ *t "as on the ne"s$
    &$ 0ere you surprised?
    A$ o$ * can#t say * "as surprised$
    &$ 0hy not?
    A$ Huh?
    &$ 0hy not?
    A$ 1ecause he told me there "ere pro!ects coming up, and this, evidently, "as one of them$
    &$ &o he hadn#t told you about it prior to you hearing it on the ne"s8 right?
    A$ o, sir$

    &$ +nd did you hear from Mr$ Jackson sometime after that announcement?
    A$ ,es, sir$
    &$ Ho" soon after the announcement?
    A$ * don#t remember the$$$ * don#t recall the e'act amount of time that passed$ * "ould say "ithin t"o "eeks,
    three "eeks, perhaps$
    &$ &o if the announcement "as on March 7th, 633=$$$
    A$ March 7th? ()$
    &$ $$$ you think sometime then?
    A$ Probably around the middle of the month, * "ould say$
    &$ &o mid March$ +nd tell me about that$ Ho" did you hear from him?
    A$ 0ell, the first person to call me "as Michael +mir$
    &$ +nd "ho did you understand Michael +mir to be?
    A$ 0ell, * didn#t kno" at the time he called me, but he e'plained that he "as Michael Jackson#s assistant, and
    Michael "ould like to speak to me regarding$$$ he "ould like to "ork "ith me on the B5his *s *tB tour, and he
    "ould like to personally call me$
    &$ &o some of those phone calls that you "ere receiving in the intervening four years "hen you "ere
    speaking "ith Mr$ Jackson, ho" did those phone calls come about?
    A$ He called me directly$ *t "as !ust him directly on the phone$
    &$ &o in the$$$ bet"een 6337 and March 633=, "hen you heard from Mr$ Jackson, you heard from him
    directly?
    A$ ,es, sir$
    &$ 1ut this time you heard from Michael +mir 0illiams?
    A$ -orrect$
    &$ /id that surprise you?
    A$ o$
    &$ 0hy not?
    A$ 0hy not?
    &$ 0ell, you#ve been hearing from him directly every three months for the four years, and suddenly you get a
    call from Michael +mir 0illiams$

    A$ 0ell, Michael e'plained that Michael#s phone that he "as calling from "ould be a blocked number, and so
    it "ould$$$ Michael "ould be calling me directly from
    A$ 1locked number, so to be sure to pick it up$ &o * guess it didn#t strike me as "eird that a personal assistant
    "ould let me kno" he "ould be calling, and please pick up a blocked number$
    &$ 1ut that#s not ho" it occurred for the prior three years8 right?
    A$ o$
    &$ +nd you said he called you$$$ did he tell you anything else? 0hen Michael +mir called, did he say
    anything else about the tour, "hat "as happening?
    A$ o$ He didn#t give me too much information, other than Michael "ould be calling me$ He "ould be
    calling me from a blocked number, be sure to pick it up, and that it "as about "orking "ith him on the tour$
    &$ +nd did a time come "hen Mr$ Jackson then called you directly?
    A$ ,es$
    &$ +nd ho" soon thereafter did that happen?
    A$ 5o be very honest, * can#t recall, but it "as soon thereafter$ * don#t kno" if it "as that day or the ne't day$ *
    really don#t recall$
    &$ 1ut he did call directly, then?
    A$ ,es$ %rom a blocked number, sir$
    &$ +nd "hat happened in that phone conversation?
    A$ ()$ * "as lying in my bed, and a blocked call came in, and * said, Bah, that#s probably Michael$B it "as
    really happy and light$ *t "as like, Boh, my gosh$ * see you#re doing a concert,B you kno"$ +nd he goes, Byeah$B
    and$$$ he used to al"ays use the phrase, B"ork "ith me, 5urkle$ 0ork "ith me, 5urkle$B you kno", because he#s
    saying, like, B* "ant to "ork "ith you$B and, like, "hen *#m doing his makeup, it "as, B"ork "ith me, 5urkle$B
    he said that to me$ B"ork "ith me, 5urkle$B so it "as !ust fun and kind of laughed and chuckled$ +nd * think *
    said$$$ * mentioned during that conversation * "as really e'cited for him$ * said, B* see you#re doing a lot of
    sho"s$B and he said, Byeah$B he goes$$$ he said, B* thought * "as only going to do 23, but it looks like$$$ * don#t
    kno" ho" * "oke up, and no" *#m doing 73$B * said, B"ell, then, you kno", that#s a lot$B and he goes$$$ he "as
    kind of a little discouraged about the number, and * "as a little apprehensive about it, too$ 1ut, * mean, "e didn#t
    d"ell on that "hatsoever$ ,ou kno", he "as, like, Byeah, "e got to do this$B * said, B"e got to get your hair
    together, and "e got to start "orking really fast,B you kno"$ He goes, B()$B and that "as about it$ 0e "ere !ust
    bantering back and forth because it "as nice to hear his voice, of course$
    &$ o", in those five to si' days of deposition transcripts that you revie"ed, do you remember ever telling
    about that part of the conversation before? +bout the idea that you had talked about the 73 and the 23 sho"s,
    and he "as concerned?
    A$ 0ell, there "as a lot$$$ you kno" ho" thick those depositions "ere? 5hey "ere, like, this thick
    (indicating)$ /o * recall saying that in that particular$$$ * don#t recall, sir$

    &$ ,ou don#t? *s it possible this is the first time that you#ve testified under oath that that part of the
    conversation ever took place?
    #r$ %anish" calls for speculation$
    Ju!e" overruled$
    A$ sir, * told you$ * don#t really recall$ * kno" that "as a part of one of our conversations$ *#m really not sure if
    it "as in that very first conversation * had, sir$
    &$ let#s talk about the scheduling of sho"s$ &o it#s March 7th$$$ *#m sorry$ Mid March$$$
    A$ (), sir$
    &$ 633=$ ,ou had this conversation "ith Mr$ Jackson$ /o you tell him at that time that you#ll go "ork for him
    on the tour?
    A$ ,es$
    &$ &o he asked you to "ork on the tour, and you said, ByesB?
    A$ ,es$
    &$ /id he tell you "hen it "as starting?
    A$ o, sir$
    &$ /id he tell you "here it "as going to be located?
    A$ * don#t kno" if$$$ * can#t recall if he told me$ *t "as all over the ne"s, so it "as something that * "ould have
    kno"n$
    &$ 5he press conference$ /id you see the press conference?
    A$ * remember seeing the media BbusB thing, "here the media "as flying over his bus$ * don#t think * actually
    sa" the announcement live$ * sa" it in retrospect, in it being played on the ne"s, and things like that$ 1ut * don#t
    think * sa" it at the time$ * sa" the helicopters, you kno", and the buses, and all the e'pectation of Michael
    going to it, but * think maybe * had to "ork and couldn#t "atch the rest of it, so * can#t really be sure that * sa" it
    at that time that it "as happening$
    &$ 1ut a time came "hen you sa" it either then or on the ne"s?
    A$ ,eah$ *t "as on the ne"s$
    &$ Ho" did you think he looked?
    A$ ()$
    &$ 0ere you concerned "hen you sa" him? ,ou hadn#t seen him in four years$ /id he look bad to you?
    A$ o$ * !ust thought he had a really bad hairpiece on, sir$ 1ut * have to e'plain that that#s "hat * do, so those
    are the things that * notice about everybody, is, like, their personal appearance, their hair, their makeup$ +nd,

    you kno", it#s !ust, like, an unconscious thing$ *#ll go to a restaurant and say, Boh, * "ouldn#t "ear my eye
    makeup like that$B and * !ust noticed his "ig "as so big$ &o that "as "hat * noticed most of all$
    &$ + bad hairpiece$ (ther"ise, ho" did he look to you?
    A$ ,ou have to$$$ *#m trying to go back to that point "hen * first sa" him, because, like, it "as a long time
    ago$ Ho" did * think he looked? 5he only thing that * can recall is, like, the hairpiece, sir$ +nd * thought his
    behavior "as a little odd$ * think he "as$$$ but not out of the ordinary$
    &$ o", after that, a time came that you actually ended up seeing Mr$ Jackson live8 right?
    A$ ,eah$
    &$ *n person? 1ut that didn#t happen until +pril8 correct?
    A$ * think it "as like around the beginning of +pril$$$
    Ju!e" Juror no$ C, are you ()?
    #r$ %anish" "hy don#t "e take a 4uick break?
    Ju!e" 23 minutes$ (the !ury e'ited the courtroom at 23:9C a$m$)
    Ju!e" * don#t kno" "hat#s going on, but 23 minutes$ ,ou can step do"n if you like or$$$
    #s Faye: "here am * going to go?
    #r$ %utnam" it#s cooler outside$
    Ju!e" the !uror is better$ (the !ury entered the courtroom at 23:DC a$m$)
    Ju!e" Juror no$ C, ho" are you doing? Juror no$ C: *#m ()$ &orry about that$
    Ju!e" can you make it until lunch? Juror no$ C: yes$ * took some painkillers$
    Ju!e" ()$ &o let me kno" if there#s anything else * can do$ Juror no$ C: all right$
    Ju!e" if it#s too painful or your brain gets foggy, let me kno"$ 0e#re going to be here for a "hile$$$ "e#ve
    been here for a "hile, and "e#re going to be here for a "hile$ Half a day doesn#t make much difference$
    #r$ %utnam" may * approach, your honor?
    A$ no", during that little break, * kind of recalled something$ ,ou asked me if * revie"ed anything about the
    case in bet"een$ ,ou remember "hen * "as sick and couldn#t make it here? * had$$$ * found my old phone, sir,
    and * found some te'ts relating to this$$$ the period of a couple "eeks around Michael#s death, sir$
    &$ 1y Mr$ Putnam: are these te'ts that$$$ you "ere deposed in t"o different cases related to this8 right?
    A$ ;m, * "as deposed for >loyds, and * "as deposed at the same time for you$$$ you actually handed me a
    subpoena at the same time * "as there for >loyds for this case$
    &$ +nd those subpoenas asked you to hand over documents that related to Mr$ Jackson#s time period8 correct?

    A$ -orrect$
    &$ +s "ell as te'ts and phone messages?
    A$ -orrect$
    &$ 1ut you didn#t hand those over to us8 right?
    A$ * had no idea * still had the phone, sir$
    &$ 1ut since you#ve testified, you#ve no" found those te'ts?
    A$ 0hen * "as sick, sir, * "as looking, because * "as trying to remember stuff and dates and$$$ yes, sir$
    &$ /id it help you remember stuff no"?
    A$ *t helped me clarify some dates, sir$
    &$ +nd did you turn those te'ts over?
    A$ * gave them toE$
    &$ 5o "hom?
    A$ 5o plaintiffs, sir$
    &$ /id you give them to the people "ho asked for them in the actual subpoenas that you "ere given?
    A$ o, sir$
    &$ o? &o you didn#t hand them to them$ ,ou found them and gave them over to plaintiffs?
    A$ (no audible response$)
    &$ /id "e receive those?
    A$ * don#t kno", sir$
    &$ /id you ask them to give them to us?
    #r$ %utnam" * guess "e#re getting them no"$
    #r$ %anish" better no" than never$
    A$ "hen did *$$$
    Ju!e" "hen did you give them to them?
    A$ !ust recently$
    Ju!e" !ust no"?

    A$ yeah$ * mean, like, today$


    &$ 1y Mr$ Putnam: you gave them to them today?
    Ju!e" ()$ +ll right$
    &$ 1y Mr$ Putnam: is that "hat you#re saying? ,ou gave them to them today?
    A$ ,eah$ 5his morning$
    #r$ %utnam" "e can look at those at the break so * can try to prepare$
    &$ going for"ard, ma#am, did you find anything else?
    A$ /id * find anything else? * mean, * "as going through my dra"ers, sir, so nothing pertaining to this case$ *
    found some kind of se'y things bet"een my boyfriend and *$
    &$ /o you think this is funny?
    A$ ,ou asked me, sir, and * told you "hat * found$ 1ut do * think it#s funny? * don#t think this case, sir, is
    funny at all$
    &$ .oing back to "here "e "ere, ma#am, "hen did you let plaintiffs# counsel kno" that you found these
    te'ts?
    A$ * let them kno" last night, and * gave them to them this morning, sir$
    &$ +nd "hen did you find them? 0hen you "ere sick? Ho" long ago "as that?
    A$ -ouple "eeks ago, sir$
    &$ /id you let anybody kno" you found these a couple "eeks ago?
    A$ o, sir$ * think * told my boyfriend that * found$$$ because * "as$$$ you keep asking me things about dates,
    and * found that$$$ *#m trying to remember$ +nd so those things "ere trying$$$ * "as trying to refresh my memory
    about things, sir$
    &$ ,ou had a conversation "ith Mr$ Jackson sometime in mid March 633= about the idea of coming back
    and "orking "ith him and going on tour8 correct?
    A$ -orrect$
    &$ +nd then you agreed to go on tour "ith him8 correct?
    A$ -orrect$
    &$ +nd there "as a conversation about ho" many sho"s, the 23 versus the 738 correct?
    A$ * had a conversation "ith him$ * can#t be sure if it "as in the very first conversation that * had "ith him$
    1ut there "as a conversation regarding "aking up, and it "as, like, Bit started off as 23 sho"s, and * "oke up,
    and no" it#s 73$B it "as pretty lighthearted$

    &$ &o a lighthearted conversation about ho" many sho"s?


    A$ ,es$
    &$ +nd then you ended up seeing Mr$ Jackson for the first time in four years in the beginning of +pril 633=?
    A$ ,es$
    &$ +nd before you had seen him, you actually started doing some research about the number of sho"s, "hat
    the schedule "as, and the like?
    A$ *t "as soon after the first conversation$ * felt that * "as going to be a part of this, so * "ent online, and *
    sa" a schedule$
    &$ ,ou sa" a schedule?
    A$ >ike the tour dates$
    &$ +nd so this$$$ this is something you did before you had yet seen Mr$ Jackson8 correct?
    A$ ,es$
    &$ +nd as a result of seeing that schedule, you "ere concerned about the number of sho"s, and ho" the
    schedule "as created8 correct?
    A$ * "as concerned at ho" close the sho"s "ere together, sir$
    &$ +nd in fact, you reached out to )enny (rtega as a result of that concern, didn#t you?
    A$ * reached out to him, and * reached out to Michael$
    &$ +nd ho" is it that you kne" that )enny (rtega "as involved in the sho" at that point?
    A$ Ho" did * kno"? * can#t really recall ho" * kne", sir$
    &$ ()$
    A$ 1ut * did kno" because * called him$
    &$ ()$ +nd but at this point in time, you "ere concerned, because you didn#t think Michael "ould last a
    "eek "ith that kind of schedule8 right?
    A$ * don#t kno" if that "as my e'act "ords, that Bhe "ouldn#t last a "eek$B * mean, * kno" ho" he$$$ the time
    he needs to recuperate after a sho", and * didn#t kno" if he could continue very long "ith that schedule because
    there "asn#t enough time to recuperate$ * think * might have said something like, Bhe might make the first "eek,
    but it "as going to go do"nhill after that$B you kno", * felt that the schedule "as too difficult for him to
    maintain$ 5o be$$$ to try to ans"er your 4uestion, * don#t remember if * said a "eek or ho" * really e'plained
    that$
    &$ 1ut you did reach out to )enny (rtega, and you reached out to him because you "ere concerned?

    A$ ,es, sir$
    &$ +nd you "ere concerned about Mr$ Jackson#s ability to actually do the tour8 correct?
    A$ 0ell, do the schedule that "as on the "eb site$
    &$ +nd at this point you hadn#t even seen Mr$ Jackson8 right?
    A$ -orrect, sir$
    &$ ,ou hadn#t seen him in four years?
    A$ -orrect, sir$
    &$ +t this point did you have an understanding that the tour "ould take place in one location: >ondon?
    A$ ,es, sir$
    &$ +nd you had never been "ith Mr$ Jackson before "here he did a residency, had you?
    A$ *#ve been in places "here he#s been there several "eeks, but not a residency$
    &$ +nd did you understand at this point "hen you talked to Mr$ (rtega that this "as going to stay in one
    location for 73 sho"s?
    A$ *#m pretty sure * understood that$
    &$ /id you understand at that point in time that there "as going to be a three-and-a-half-month break in the
    middle?
    A$ * don#t kno" that * kne" that at that time$ *#m not sure "hen * realiFed that$ 1ut "hen * "as looking at the
    schedule and had that conversation "ith )enny, * cannot recall if * kne" there "as going to be a three-month
    break$
    &$ ,ou said you "ent online to look at the schedules$$$
    A$ * !ust looked at the first$$$ top, sir$ 5he first, like$$$ * didn#t scroll the "hole page$ * !ust sa" those dates, and
    that#s "hat * sa"$
    &$ &o you hadn#t seen him in four years, you sa" some of the dates, and you called Mr$ (rtega and said, Bthis
    is a problemB?
    A$ * said, Bit could possibly be a problem$B * didn#t say definitively that, you kno", that it "as going to be a
    problem$ * said, Bthis should be something "e should consider and look at$B
    &$ +nd you had already agreed you "ere going to be the hair and makeup person for Mr$ Jackson8 correct?
    A$ -orrect$
    #r$ %utnam" could * sho" e'hibit 29,D36? 5his "as already entered$ May * approach, your honor?
    Ju!e" yes$

    &$ 1y Mr$ Putnam: give you a hard one


    A$ this isn#t "hat * sa"$
    Ju!e" can you pass that one do"n?
    A$ oh, to you? *#m sorry$
    Ju!e" thank you$
    #r$ %anish" you#re saying this is on the "eb site?
    #r$ %utnam" no, * didn#t say that$
    #r$ %anish" oh, ()$
    &$ so, Ms$ %aye, there#s been testimony that this "as the schedule of sho"s$ * "ant to sho" you something$
    ,ou see, it has$$$ there#s never t"o in a ro"$ 5hree months of sho"s, then there#s three months off, and then
    three months again$ ,ou see that?
    A$ * see that$
    &$ &o "hat "as it that concerned you?
    A$ 0ell, this is$$$ first, isn#t "hat * sa"$
    &$ ()$
    A$ ()$ 0hat * sa" "as a list8 ()?
    &$ (f !ust dates?
    A$ (f dates$ +nd "hat * sa" "as, like, at the time "as like$$$ there "as a date, off, date, date, off$ ,ou kno",
    it "as closer together than this, sir, "hat * remember seeing$ 1ecause * remember seeing t"o dates in a ro" in
    places$
    &$ * "ill represent to you that there#s testimony that * think there "as$$$ five sho"s "ere moved from the
    original schedule$$$
    A$ -orrect$
    &$ $$$ to the end so that it started slightly later$
    A$ ()$
    &$ &o you may have seen the schedule$$$ but "ithout any t"o in a ro"$ ,ou sa" t"o in a ro"?
    A$ * thought * did, sir$
    &$ /o you recall e'actly "hat you told Mr$ (rtega?

    A$ /o * remember e'actly "hat * told Mr$ (rtega? o, sir, * don#t remember e'actly "hat * told him$
    &$ /o you remember generally "hat you told Mr$ (rtega?
    A$ Just "hat * told you !ust right no"$
    &$ +ll right$
    A$ 5hat * thought that the dates "eren#t really$$$ * thought Michael "ould need more time to recuperate$ *
    think they should really look at that and consider doing something that might be a little easier on him$ *t "as in
    that$$$ it#s not e'act "ords$ *t#s to that$
    &$ ()$ *#d like to sho" you an e'hibit that has been entered and that has been testified to e'tensively$ *t#s
    e'hibit 293-2, and it#s a series of e-mails bet"een Paul .onga"are and <andy Phillips$ ,ou kno" "ho they are8
    right?
    A$ -orrect$
    &$ +s "ell as )enny (rtega$ +nd there#s reference to a phone conversation in it that supposedly happened
    "ith you$ +nd * "ant to find out if this is the conversation that they#re talking about8 all right?
    #r$ %anish" has she seen this before?
    #r$ %utnam" * don#t kno" if she#s seen this before$ 1ecause she#s been t"eeting about it$ 1ut * don#t kno" if
    she#s$$$
    #r$ %anish" first of all, * ob!ect to the comment$
    A$ sir, * haven#t seen any e'hibits$$$
    Ju!e" "ait$ Hold on$ %irst of all$$$ there#s an ob!ection$
    #r$ %anish" counsel has been ob!ecting to sho"ing e-mails to people not on the e-mail$ *f he "ants to try to
    refresh her recollection, that#s fine, but, * mean, "e need some consistency$
    #r$ %utnam" and in terms of consistency, * have made those ob!ections, and you#ve allo"ed them to go in
    any"ay even if a person "asn#t on it$ *f they could talk about something, they could testify to it$ +nd in fact,
    this very e-mail, people have been asked about even if they#re not on the chain$ +nd * "ould like to do it "ith
    her$
    Ju!e" you#re saying that a conversation concerning her or "ith her is on the chain?
    #r$ %utnam" yes$
    Ju!e" all right$ ,ou may$
    #r$ %utnam" may * approach, your honor?
    Ju!e" you may$
    A$ thank you$

    Ju!e" but it#s in evidence already8 right?


    #r$ %utnam" yes$
    #r$ %anish" that#s fine, as long as "e can do that$
    A$ so this is from$$$
    Ju!e" hold it$ 0e haven#t looked at it$ .ive us a chance to look at it$ ,ou can read it yourself, but give us a
    chance to look at it$
    &$ 1y Mr$ Putnam: so, as * "as noting for you, this is a series of e-mails$
    A$ ()$
    &$ +nd you#ll see at the bottom, it starts "ith an e-mail to Mr$ (rtega$
    A$ %rom )enny (rtega$$$
    &$ 5o Paul .onga"are$$$
    A$ ;h-huh$
    &$ $$$ and John Houghdahl#s$
    A$ ()$
    &$ +nd, see, that#s on the 67th of March?
    A$ -orrect$
    &$ +nd belo" it goes through$$$ it talks about several conversations$ &aid: B* received a fe" callsB$$$
    Ju!e" are "e going to put this up?
    #r$ %utnam" yeah$
    A$ * have it in my hand$ * haven#t read the "hole thing because everybody is talking$
    #r$ %utnam" sorry$
    A$ go ahead$ *#ll go on as you go through it$
    &$ 1y Mr$ Putnam: !ust so you kno" "hat *#m going to ask, as you get to the bottom of that first page, as it
    goes on to the second page, it says: B)aren %aye, MJ#s personal makeup artist$B you see that? +nd goes on to the
    ne't page, talking about a conversation that he says that he had "ith you$
    A$ Bshe "as thrilled that "e "ould all be "orking together again and "ould make herself available to me to
    discuss the sho"$B ()$ * read the paragraph regarding me$ * didn#t read anything else$ ()$
    &$ &o you see there, it talks about the idea that on the 67th of March$$$

    A$ ;h-huh$
    &$ $$$ says: B)aren %aye called to check in and confirm that MJ had reached out to her regarding the sho"$
    &he "as thrilled that "e "ould all be "orking together again and "ould make herself available to me to discuss
    the sho" plan at any time$ &he also mentioned that she read online the tickets "ere being sold for every other
    day$B
    A$ * made$$$ * didn#t say anything about tickets$ * said * "ent online, like * said to you, and sa" that the sho"s
    "ere very close together, yes$
    &$ ,ou commented rather heavily "ith respect to this?
    A$ *t "as a concern of mine$ * mean, * don#t kno" "hat you mean by Bheavily$B * !ust thought it "as
    something that * should address in the very beginning to alert people, if they "ant this to be the best success for
    everybody, that this should be something that they look at, sir$
    &$ *t says: Bit#s her strong opinion that this is dangerous$B
    A$ o$ * mean, like, this is his "ords, not mine$ 5his is "hat he#s saying$
    &$ 5hat#s "hy *#m asking you, ma#am$
    A$ * didn#t say it "as dangerous$ * said it$$$ * mean, ho" can it be dangerous at this particular point? 5hat#s
    ridiculous$
    &$ 5hat#s "hy * "as asking$
    A$ * said it "asn#t the best schedule for Michael to be successful$
    &$ 5hat#s "hy *#m asking, ma#am, because a number of people have been asked$$$
    A$ ;h-huh$
    &$ $$$ "hether they "ere a"are as of this date$$$
    A$ ;h-huh$
    &$ $$$ of the fact that it "as dangerous and impractical because of this e-mail, so that#s "hy *#m asking you
    "hat you said$
    #r$ %anish" *#m going to ob!ect$
    A$ * didn#t "rite the e-mail, sir$
    #r$ %anish" *#m going to ob!ect to counsel#s characteriFation of "hat "as said$ *t misstates testimony and is
    improper$ +nd his response "hen * make an ob!ection$$$ it#s an improper 4uestion to this "itness$$$
    Ju!e" ()$
    #r$ %anish" $$$ representing things like that$
    Ju!e" ()$ &ustained$

    &$ 1y Mr$ Putnam: so you didn#t say it "as dangerous?


    A$ * can#t recall saying it "as dangerous, sir$ * !ust thought that in order to be successful, they should revisit
    the schedule$ 1ecause *#ve been on tour "ith Michael before$
    &$ ()$ +nd going on, did you say it "as Bimpractical "ith consideration to MJ#s healthB?
    A$ o$ * had no$$$ * mean, this is really "eird, because * had no concept of Michael#s health at this particular
    time$ * mean, this is, "hat, like March?
    &$ <ight$ ,ou hadn#t even seen him yet8 right?
    A$ o$ My concern "as !ust that the schedule, according to other tours that *#ve been on, that it#s difficult, and
    he needed, you kno", recuperate$$$ more recuperation than "hat * sa" on the original "eb site$ * didn#t$$$ there#s
    no "ay * "ould have said BdangerousB or BimpracticalB or$$$ * mean, BdangerousB? o$ * didn#t say$$$ * didn#t use
    those "ords, sir$
    &$ &o this is not correct?
    A$ ot ho"$$$ * mean, the concept that * did call and e'press my concern and think that Michael$$$ "asn#t the
    best schedule for Michael to be able to maintain to do 73 sho"s$ 1ut not BdangerousB and BimpracticalB and Ba
    consideration to Michael#s health and ability to perform$B * had no concept of Michael#s ability at this time, so *
    "ouldn#t have said that$
    &$ ()$ +nd it then goes on to say: Bin the past (23 to 26 years ago) )aren "ould often speak on his behalf
    "ith regard to these kinds of issues$B
    A$ * don#t kno" "hat he#s referring to there$
    &$ ,ou don#t?
    A$ * mean, * "as al"ays protective of Michael and his "ell-being$ +nd in the past 23 or 26 years ago, * "ould
    speak on his behalf "ith regards to these kinds of issues$ * really don#t kno" "hat he#s referring to e'actly, but *
    "as al"ays concerned "ith Michael#s "ell-being$ +nd "hen it "as$$$ "hen * sa" that there may be a problem or
    something that could help Michael, * did speak out$ 1ut "hat e'actly they#re referring to here, * do not kno"$
    &$ ()$ ,ou do recall our talking last time, right, about your being asked to not continue on the BhistoryB
    tour?
    A$ &ay that$$$ !ust restate the 4uestion$
    &$ +bsolutely$ ,ou remember our talking last time$$$
    A$ ;h-huh$
    &$ $$$ about you being asked to not continue on "ith the BhistoryB tour?
    A$ -orrect$
    &$ +nd didn#t "e talk about the idea that some believed it "as because of your speaking out on his behalf
    "ith regards to these kinds of issues?

    A$ 0hat#s the last part of the 4uestion?


    &$ 0asn#t it$$$ did "e not discuss$$$
    A$ ;h-huh$
    &$ $$$ the idea some thought it "as better for you not to continue at that time because of this very fact8 that you
    "ould speak out on his behalf "ith regard to these kinds of issues?
    A$ * had no kno"ledge of "hy they didn#t bring me along$
    &$ 1ut you did have a conversation "ith Mr$ (rtega at this time8 correct?
    A$ ,es$
    &$ +nd it "as a concern about the schedule?
    A$ -orrect$
    &$ +nd you indicated a moment ago that you also reached out to Mr$ Jackson$$$
    A$ * did$
    &$ $$$ about this? 0hy did you reach out to Mr$ Jackson about this?
    A$ 1ecause * think that he didn#t kno" ho" the schedule "as8 that * said it "ould be really smart$$$ that he
    should go and look at the schedule and see, you kno", ho" it#s scheduled$ +nd if$$$ ho" he feels about it, and if
    he "as feeling uncomfortable about it, he should say something about it$
    &$ ()$
    A$ +nd his response "as, Bthat#s funny$ My mother said the same thing$B
    &$ o"$$$
    A$ 1ut he had not, * think, seen the structure$
    &$ &o you think that at this point in time in March, that Mr$ Jackson "as una"are of "hat his schedule might
    be in >ondon?
    A$ 0ell, * don#t$$$ by the conversation * had "ith him, he didn#t seem like he kne", like, ho" many days, and
    ho" it "as structured8 that he !ust had to do 73 dates$ +nd * don#t think he "as$$$ he didn#t seem to be a"are$$$
    "hen * told him that, Bhave you seen the schedule? ,ou should see it$B and he goes, Bno, * haven#t$B * !ust
    "anted him to make sure that he kne" ho" it "as scheduled, to see if he "as comfortable "ith it$ +nd he said$$$
    his response "as, Bmy mother told me the same thing$B so$$$
    &$ *s it true that you reached out to Mr$ Jackson because you believed that he "as the one "ho "as
    responsible for having to do the sho"s?
    A$ Huh?

    &$ Just "hat * said$


    A$ 0hat? /id * reach out to Michael?
    &$ Mr$ Jackson, uh-huh$
    A$ 1ecause he "as the main performer, sir$
    &$ ;h-huh$ +nd he "ould also be the one responsible if he couldn#t do the sho"s8 correct?
    A$ -orrect$ *t "ould be his responsibility, sir$
    &$ +nd isn#t that the reason you reached out to him, because you kne" it "ould be him "ho "as responsible
    if he couldn#t do the sho"s?
    A$ &ay that one more time$ 0ould it$$$
    &$ /id you reach out to him because you believed he "as the person "ho "as going to be responsible if he
    couldn#t do these sho"s?
    A$ *t "ould come do"n on him, sir, because he "as the star$
    &$ * understand that$ My 4uestion is: is that the reason you reached out to him?
    A$ ,eah$ * think so$ * mean, it seems logical, "ith your statement, that if he couldn#t do the sho"s, and he
    could not make a sho", or if he got tired, that$$$ you kno", he#s the performer$ *t#s his name up there$
    &$ +nd so you "anted to make sure that he understood "hat the schedule "as and your concern that that
    might be difficult for him?
    A$ ,es$ * "as concerned, sir$
    &$ o", ho" "e got off on this is, "e "ere talking about, you said you had this conversation at the time
    "hen you spoke "ith Mr$ Jackson in March of 633= about the scheduling, remember, and "e "ere talking
    about your first contact?
    A$ ;h-huh$
    &$ +nd a time came after this, after you spoke "ith Mr$ (rtega on the 67th of March, "here you actually sa"
    Mr$ Jackson8 correct?
    A$ -orrect$
    &$ +nd that "as the beginning of +pril$ 0here did you see him?
    A$ +t -arol"ood$
    &$ +nd did you go by yourself?
    A$ o, sir$
    &$ 0ho did you go "ith?

    A$ &tuart +rtingstall$
    &$ 0ho is he?
    A$ He is my "ig maker$
    &$ +nd you thought some ne" "igs might be in order?
    A$ &ome "hat?
    &$ &ome ne" "igs might be in order?
    A$ &ir, "e needed to prepare for the sho", sir$
    &$ +nd then a time came, also, "here, after that$$$ after you "ere meeting "ith Mr$ Jackson, you ultimately
    started negotiating for a contract "ith +G. correct?
    A$ ,es$
    &$ +nd ultimately you entered into a contract "ith +G. is that right?
    A$ -orrect$
    &$ +nd you "eren#t paid by +G. 1efore you signed that contract, "ere you?
    A$ ;m, no, sir$ 0ell$$$ no$ o, * personally "as not paid$ * needed to get some funds to start creating the
    hairpieces for Michael, sir, and * "as informed by Gvvy to contact /r$ 5ohme$
    &$ &o you needed some funds in advance before you had contracted "ith +G., and you talked to Gvvy$ 0ho
    is Gvvy?
    A$ Gvvy "as Michael#s assistant that resides here, sir$ 5hat resides in >os +ngeles, sir$
    &$ /o you kno" her "hole name?
    A$ Gvvy 5avasci$
    &$ 5avasci$ &o you reached out to Ms$ 5avasci to find out "ho to speak to about getting funds, and she told
    you to go speak to "ho, /r$ 5ohme?
    A$ ,es$
    &$ +nd did you kno" Ms$ 5avasci because she had "orked for Mr$ Jackson previously?
    A$ ,es, sir$
    &$ +ppro'imately ho" long?
    A$ + long time$
    &$ &o she "as someone you had spoken to before?

    A$ ,es, sir$
    &$ +nd that#s "hy you spoke to her?
    A$ ,es$
    &$ /id you hear about /r$ 5ohme before?
    A$ o$
    &$ /id you actually reach out to /r$ 5ohme and seek funds?
    A$ ,es$ &he gave me his phone number, and * called and left a message$ He did not pick up, sir$
    &$ +nd "as this before or after you first sa" Mr$ Jackson in +pril of 633=? /o you kno"?
    A$ * can#t really recall, sir$
    &$ ()$ o", before you started negotiating this contract, do you remember saying$$$ *#ve asked you if you
    had any concerns "hen you first spoke to Mr$ Jackson$ +nd do you recall at all telling me that, yes, you had a
    concern about someone named <aymone 1ain and .race <"aramba?
    A$ ,es$
    &$ &o "hen one of your first concerns in that conversation$$$ *#m sorry$ 0hen you first thought of that
    conversation "as after Michael +mir 0illiams or after you spoke to Michael himself?
    A$ ()$ *#m confused, ()? 5ry to make it really clear here so * can ans"er your 4uestion$
    &$ o, please$ 5hat "as my fault$ 5errible 4uestion$ >ast time, * said: B/id you have any concerns at the time
    "hen Michael first contacted you about the concert tours?B and you said: B,es, * did$ * had a problem "ith
    <aymone 1ain and .race <"arambaB$$$
    A$ -orrect$
    &$ $$$ Bbecause * kne" they didn#t like me and pretty much responsible for me not being around for four
    years$B you remember saying that?
    A$ -orrect$
    &$ +nd "hy did you say that, ma#am?
    A$ 1ecause that "as my understanding at that time, sir$
    &$ +nd "hat "as your understanding?
    A$ 5hat they didn#t like me$
    &$ +nd "ho "as Ms$ 1ain?
    A$ &he "as$$$ at first she "as brought in as a publicist, sir$

    &$ Had you ever met her?


    A$ Have * met her? ,es, *#ve met her$
    &$ Had you met her at that time?
    A$ +t "hat time?
    &$ +t the time of that conversation in March of 633=$
    A$ (h, yes$ *#ve kno"n her for a "hile, sir$
    &$ +ll right$ +nd "hat "as the basis of your belief that she didn#t like you?
    A$ Probably kind of during the trial$ ,ou kno", they "ere$$$ *#m !ust trying to think of details here to$$$ you
    kno", "ell, .race kind of goes back 4uite a "hile$ * felt that she$$$ you kno", * really, really$$$ * really, really
    loved .race, you kno", "hen * first met her$ &he "as really$$$ * adored her$ * have to say that$ +nd * met her
    "ay back "hen she "orked at Michael#s office, and * "as really happy "hen Michael used her as the nanny$ 1ut
    * !ust felt that as her responsibilities gre", that she kind of stood in the "ay of$$$ or she al"ays appeared to, like,
    try to keep me a"ay from Michael, in a sense$ )eep it at a distance$ +nd then <aymone came later, sir$
    &$ /id the time ever come "ith Ms$ <"aramba "here you suspected that she "as involved "ith providing
    Mr$ Jackson "ith drugs?
    A$ * thought it "as a possibility$
    &$ +nd "hy did you think it "as possibility, ma#am?
    A$ 1ecause it seemed like Michael seemed to have issues sometimes "hen she "as around$
    &$ *#m sorry$ * didn#t 4uite$$$ he had issues "hen?
    A$ 0hen$$$ * felt there "ere issues "hen she "as around sometimes, sir, and$$$ let#s see$ *#m !ust trying to
    really think$ 5rying to ans"er your 4uestion properly$ * can#t really think$$$ "hat "as the 4uestion? Just kind of
    remind me of the 4uestion again$
    &$ 5he 4uestion "as$$$ and * can follo" up$ *#ll tell "hat you the 4uestion "as$ * asked you if a time ever
    came "hen you suspected that Ms$ <"aramba "as someho" involved "ith providing Mr$ Jackson "ith drugs$
    +nd if you ans"er that 4uestion, *#m going to ask a follo"-up, "ere there times you felt that "ay? 0as one of
    those times during the 6337 criminal trial?
    A$ * think it "as <andy Jackson "ho asked .race to leave everland, sir$
    #r$ %anish" *#m going to ob!ect$ *t#s all hearsay, "hat other people are saying, and speculation$
    Ju!e" yeah$ * don#t think he intended to elicit hearsay, but she#s saying hearsay$ +nd *#ll strike that portion of
    the ans"er$
    #r$ %anish" and also speculation, but go ahead$ +nd relevance, too$
    Ju!e" o$ (verruled on relevance$ 0hy don#t you re-ask the 4uestion?

    #r$ %utnam" * "ill$


    Ju!e" * don#t think you "ere intending to elicit hearsay, but it came out that "ay$ &o *#ll strike that portion of
    the ans"er$ ,ou can re-ask the 4uestion$
    &$ the 4uestion *#m asking, ma#am, is, * asked if you suspected at any point that Ms$ <"aramba "as in any
    "ay involved "ith perhaps providing Mr$ Jackson drugs? +nd you said there "ere times "hen she "as around$
    +nd * follo"ed up "ith, "as one of those times during the criminal trial in 6337?
    A$ ;m, * have no proof of anything, sir$ *t "as !ust things that * "as told and things that happened, sir$
    &$ 0hat "ere the things that happened?
    A$ Michael seemed to have a more difficult time during the trial "hen .race "as brought back to everland$
    &$ &o there "as a time at the beginning of the trial "hen Ms$ <"aramba "asn#t at everland8 correct?
    A$ &he "as at the hotel "here * "as staying, sir$
    &$ +nd then did a time come "hen she moved into everland during the trial?
    A$ * only heard$
    &$ /id you have an understanding that she "as there?
    #r$ %anish" *#m going to ob!ect to the understanding to be based on hearsay solely$
    Ju!e" it appears it#s going to end up that "ay$
    #r$ %utnam" ()$
    Ju!e" so, sustained$
    &$ 0hen you said that she came back, "as she not at the criminal trial at some point?
    Ju!e" you mean attending the criminal trial?
    #r$ %utnam" "ell, she said that things changed "hen .race <"aramba came back$
    Ju!e" to everland$
    A$ to everland$
    &$ to everland$ &o it "asn#t to the trial, it "as to everland?
    A$ ,es$
    &$ ()$ +nd "hat -hanged "hen she came back?
    A$ 0ell, * !ust noticed that Michael started having a lot of back pain, and it kind of coincided "ith him, "ith
    the symptoms of losing a lot of "eight, and the Bpa!ama day,B and all that$

    &$ +nd remind us, if you could$ 0hat "as the Bpa!ama dayB?
    A$ 0ell, it "as the day that Michael "ent to the hospital because something happened to his back, and he
    "as taken to the hospital$ +nd they gave him, * think, some sort of painkillers for his back$ +nd then as soon as
    he "as in the hospital and had the painkillers, the !udge "as informing Michael that he had to go to the
    courthouse and be on time, or he "ould go to !ail$ +nd Michael had left everland to go$$$ he "as in his
    pa!amas "hen he "ent to the hospital$ * "as still left at everland$ * grabbed some makeup things, and Michael
    1ush got his clothes, and "e "ent to the hospital, but the !udge "as demanding that Michael be$$$ that he didn#t
    have time to get ready$ +nd "e "ere rushed to the courthouse, and Michael "as still in his pa!amas$ +nd * "as
    in a follo"-up car "ith Michael 1ush "ith his clothes and hair and makeup stuff, but "e didn#t have any time to
    make him look better from that point on$ 5hey scooted him in$ 5hey let him go, because they "ere going to
    thro" him in !ail if he didn#t get there on time$
    &$ &o that#s an e'ample of the type of incident you "ere talking about you had concerns about after Ms$
    <"aramba came back?
    A$ * have to say that a lot of my information kind of came through 5aunya and$$$ you kno", stuff about their
    concerns$
    &$ 0ell, !ust remind us$ *s this 5aunya Hilkie?
    A$ ,es$
    &$ +nd 5aunya Hilkie is your agent, your manager?
    A$ +t the time, she "as not$
    &$ +t the time you "ere "orking "ith her on the "eb site "ith <andy Jackson$$$
    A$ <ight$
    &$ $$$ about Mr$ Jackson?
    A$ -orrect$
    &$ +bout Mr$ Michael Jackson? +nd she later became your manager? &he managed your business affairs?
    A$ &he took care of my business affairs$ /idn#t really manage my career$
    &$ * "ant to ask you that because that#s "here "e are going$
    A$ ()$
    &$ &o a time came you negotiated a contract "ith
    A$ $e$g$ correct?
    A$ -orrect$
    &$ +nd, again, *#d like to sho" you that contract$

    #r$ %utnam" it is already in, and it#s e'hibit @?2?$ May * approach, your honor?
    Ju!e" yes, you may$
    A$ are these both the same thing?
    Ju!e" oh, one#s mine$
    A$ *#m sorry$
    #r$ %utnam" that#s my fault$ * should have told you that$ * apologiFe$
    A$ * thought he "as !ust being generous$
    &$ 1y Mr$ Putnam: you recogniFe this, ma#am ?
    A$ * mean, "ithout reading it "ord for "ord, it appears to be my contract$
    &$ +nd "hat *#m going to try to do is go through it and ask you about certain portions, if * may$
    A$ +ll right$
    &$ &o this is$$$ as you see, it#s a multi-page document$ ;ltimately, it#s 29 pages$
    A$ ,es$
    &$ +nd *#m going to start at the very beginning, and the first paragraph, if * may$ +nd it says: "The agreement
    dated as of may 5th, 2009, by and between AEG Live produtions, in!, a "e#aware $orporation," and then in
    parentheses, it says, "%ompany&!" and the reason *#m going through this, ma#am, is because later those
    definitions "ill be used, so * "ant to try to do it in the beginning$
    A$ ,ou#ll probably have to revisit that because *#m horrible$ * don#t understand legalese all that "ell$
    &$ ()$ +nd then it says: "and 'i#(, )n!, a $a#ifornia $orporation %#ender&!"
    A$ <ight$
    &$ 0hat is "'i#(, )n!"*
    A$ Hilk, inc$ 0as 5aunya$
    &$ +nd by that you mean Ms$ Hilkie, the one "ho "as managing the business?
    A$ -orrect$
    &$ +nd you say she B"asB because she isn#t any longer?
    A$ -orrect$
    &$ ,ou said last time that you believed she and Mr$ <andy Jackson had been in a long-time special
    relationship?

    A$ ,es$
    &$ +nd then after that$$$ and then it says+ "f,s,o"!!! whih ) be#ieve is "for the servies of"!!! "-aren .aye
    /ein0e, p,(,a -aren .aye, a hair and ma(eup artist"!!!
    A$ * like Be'pert$B
    &$ 0e#ll get there$ +nd it says there, B(e'pert)$B in this contract you "ere referred to as the e'pert?
    A$ ()$
    &$ 5he lender is your manager$$$
    A$ ;h-huh$
    &$ $$$ and Hilk, *nc$ +nd then the company is +G. >ive productions$ ,ou see that?
    A$ 5he$$$ yes$
    &$ o", did you understand that you "ere not an employee of +G., but rather$$$
    #r$ %anish" finish your 4uestion$
    &$ but rather an employee of Hilk, *nc$?
    #r$ %anish" ob!ect$ -alls for a legal conclusion as to her understanding of her employment status$
    Ju!e" overruled$
    A$ you#re going to have to say that 4uestion again, there "as so much going on$
    &$ let me help you, make it easier$
    A$ ()$
    &$ * "ill sho" you paragraph 9$9$
    A$ ()$ 9$9?
    &$ ,es, ma#am$
    A$ &o, like, at the bottom of page 9?
    &$ ,es, it is$
    A$ ()$
    &$ +nd "hile you#re looking at it, * !ust "anted to note, the agreement "as may 7th, 633=$ &o it "as about
    t"o months$$$
    A$ (h, it#s up here, too$ .o ahead$

    &$ * don#t kno" "hich one you prefer to read$


    A$ ,es$ * haven#t made that decision yet, but this one is kind of cut off$ -an you move it over that "ay?
    0hoever is doing it$$$ then * prefer the one * can see$
    Ju!e" it#s cut off on this screen$ * don#t "ant her to press any buttons$
    A$ there#s enough up there$ * can see it$
    #r$ %utnam" can she approach, your honor?
    Ju!e" yes$
    &$ 1y Mr$ Putnam: it#s dated may 7th, 633=, so about t"o months after the announcement on March 7th,
    633=$
    A$ ()$ *#m sorry$ * don#t kno" "hat you "ere saying$ +ll right$
    &$ +ll right$ &o 9$9 says: Bthe e1pert is speifia##y deemed to be an emp#oyee of #ender!" and you sa", again,
    lender "as Hilk, *nc$?
    A$ .otcha$
    &$ +nd not of the company, "hich is +G. >ive productions?
    A$ ()$
    &. "the performane of e1pert2s"$$$ that#s you8 correct?
    A$ ,es$
    &$ "servies hereunder is in the apaity of as an independent ontrator!" you see that?
    A$ * do$
    &$ +nd if you go to the bottom right of the page$$$
    A$ ,es$
    &$ ,ou#ll see that there are initials?
    A$ -orrect$
    &$ +re those your initials?
    A$ o$
    &$ 0hose initials are they?
    A$ *t looks like 5aunya and Paul .onga"are$
    &$ Paul .onga"are?

    A$ -orrect$
    &$ &o did you have Ms$ Hilkie sign this on your behalf?
    A$ *f * had her$$$ * guess you could say that she did that, yes$
    &$ +nd then, if you go to page 22 of the agreement on the bottom, is that your signature there?
    A$ 0ait a minute$
    &$ &orry
    A$ ,es$
    &$ ()$ &o did you have an understanding as to "hether you "ere an employee of +G. >ive productions,
    *nc$?
    A$ &ay that again? /id *$$$
    &$ Have an understanding$$$
    A$ ,es$
    &$ $$$ as to "hether you "ere an employee of +G. >ive productions, *nc$?
    A$ /id * have an understanding? >ike, * really don#t$$$ that#s kind of$$$ did * have an understanding if * "as$$$ *
    "orked for B5his *s *tB and the production of B5his *s *tB$ that "as my understanding$
    &$ ()$ o", at the time of this agreement, do you remember having certain re4uests that you made in
    reference to your employment? +nd *#ll help you$ *f you go a little further do"n$$$
    A$ 5o "here?
    &$ *#m looking$ *#m sorry$ Page 26$ *f you look, it says, B5his *s *tB?
    A$ 0ait a minute$ 0ait a minute$ 0ait, "ait, "ait$ ()$ 26$ ()$ .otcha$ +ll right$ *#m on the page$
    &$ +t the top, you see that it says there, "This )s )t" ontratua# re3uests, -aren .aye re 4r! 4ihae#
    5a(son2s persona# ma(eup and hair artist,on#y!" you see that?
    A$ ,es$
    &$ +nd you see, there are a number of enumerated re4uests that follo", 2D in total, over t"o pages?
    A$ ()$
    &$ /o you understand "hat these are?
    A$ * think they "ere things that * kind of needed to do my !ob, sir$
    &$ +nd so these are the specifics that you needed, and, thus, they "ere your re4uests?

    A$ * think so$ * haven#t read them$ * need to read over them$ *t#s been a long time$
    &$ >et#s go over a couple of them$
    A$ (), sir$
    &$ &tart "ith the first one$ *t says: "aess to 4r! 5a(son 26 hours, seven days a wee(, per his re3uest!" "hat
    does that mean? +nd most importantly, * "ant to ask about Bper his re3uest!" "hat#s that?
    A$ 5hat means that * needed to have access to him because of his hair8 ()? 5here "ere$$$ like, because "e
    had to "ork at times that "e "ere not performing, and the process of his hair took a long time$ &o * need to be$$$
    this is there because * needed to be able to get to him$ * don#t kno" "here they "ere going to put me, or "here
    they "ere going to put him$ 1ecause sometimes "e could have been in different cities$ +nd * "anted to make
    sure that * could get to him "hen he needed me$
    &$ +nd so "hen it says, "per his re3uest," "hat does that mean? 0as this at his re4uest?
    A$ 5o be able to do his hair, yes$
    &$ +nd "ithout going into all the details$$$
    A$ ;h-huh$
    &$ $$$ about$$$ this "as$$$ and * told you last time * didn#t "ant all the details at this point$
    A$ ()$
    &$ 1ut it "as a very involved process, "as it not, doing his hair?
    A$ ,es, sir$
    &$ +nd that#s "hy, "hen it says, "estimated five hours, but ou#d be more or #ess," you#re talking about five
    hours$$$ the reason it#s so long "e#re talking about is because of ho" much had to be done?
    A$ -orrect$
    &$ +nd, again, not going into details$ 5here "ere certain things that had to be clipped into the scalp?
    A$ More e'tensive than that, but, yes$
    &$ * "as trying to not give all the details$ o", you go on, then, to the ne't one$ >et#s go to 6$ +nd it#s$$$ "ell,
    * should ask you, so this "as a re4uest that you "ere specifically making, correct, to do your !ob?
    A$ ,es$
    &$ o$ 2, the one "e !ust did?
    A$ ,es, sir$

    &$ o$ 6$ *t says: "for optimum wor( onditions for 4r! 5a(son, ) re3uest a separate and private room #ose
    to 4ihae# 5a(son2s residene e3uipped with a hydrau#i hair in whih the ba( re#ines, a shampoo bow#,"
    goes on from there$ 0as this also a specific re4uest you "ere making so you could do your !ob?
    A$ ,eah$ Michael liked privacy "hen he did this, so this "ould be the ultimate$ * mean, * have done things in
    bathrooms and everything, but this "ould be under$$$ you kno", doing this, this "ould be the most comfortable
    condition to do this !ob$
    &$ +nd "hen you said, BMr$ Jackson liked privacy,B "hat do you mean?
    A$ 0hen you do somebody#s hair, sir, there#s a lot involved, and he doesn#t "ant people seeing$
    &$ +nd ne't, it goes to$$$ let#s go to D$ 5here#s
    A$ ;) cell phone$ .oes on from there about having it$ 0as that another thing you had re4uested?
    A$ ,es, sir$
    &$ o$ 7 talks about: "the ompany wi## pay for a## grooming needs for 4r! 5a(son! There wi## be items of
    importane that wi## have to be paid in fu## in order for the items to be seure!"
    A$ -orrect$
    &$ 0hat#s that about?
    A$ His "igs, sir$
    &$ +nd, again, "ithout going into lots of details, but "ere these ine'pensive items, these "igs?
    A$ o, sir$
    &$ 0ere they very e'pensive items?
    A$ *t depends$$$ saying, Bvery e'pensive,B it depends on "hat your vie"point is for "igs, sir$ &ome people
    think I933 is a lot, and some people think normal is 7,333$ *t depends on the 4uality$ &o, you kno"$$$
    &$ Ho" much did these cost?
    A$ 5o the best of my recollection, * think * got &tuart do"n to, * think, I9,733 a "ig$ * think$
    &$ +nd ho" many "igs "ere there?
    A$ 0ell, * needed appro'imately$$$ at least five to even leave for >ondon, sir$ +nd then$$$ and, * mean, it takes
    a long time to make them, because they#re "hat they call Bventilated$B it#s each and every hair is basically
    crocheted into a netting, and it#s hair by hair$ +nd it takes a long time to do because they#re really nice, and it
    had to look real$ +nd that#s the only "ay a hairpiece looks real, if it#s actually gro"ing out of the scalp$ &o they
    ventilate it$ *t takes a long time and had to be a good 4uality of hair$ &o it takes a long time$ &o that#s "hy *
    really needed to get started really soon on getting these done, because * needed at least five before * left$ +nd
    there "ould be an ongoing$$$ and, like, * don#t kno" the durability, you kno", of "hat Michael did, ho" much
    he s"eat, and everything, ho" many * "as going to need$ +nd * needed to have a reserve$ *f something
    happened to it at the last minute, * had to be able to remove it and put another one on immediately$

    &$ *s that "hy you sought the monies in advance from /r$ 5ohme?
    A$ ,es, sir$
    &$ +nd at the time "hen you "ent to meet "ith Mr$ Jackson in early +pril of 633=, did he have any of these
    kinds of high 4uality "igs at that time, or did you have to make them all ne"?
    A$ He had only one on his head, that big kind of heavy one that "ould never even stay on his head during a
    performance$ &o * had to get started so he even had one to "ork "ith for rehearsals$
    &$ +nd did you have a lot of time to get this done "hen you started in +pril, or little time, in your opinion?
    A$ * "as concerned that if * didn#t get started right a"ay, * "ouldn#t have enough time to get it done$
    &$ >et#s go to the ne't one$ o$ @$ *t says+ "4r! 5a(son re3uires that his persona# needs and supp#ies remain
    omp#ete#y private and onfidentia#! ) wi## ho#d a## of 4r! 5a(son2s itemi0ed reeipts! ) wi## on#y re#ease them
    upon his re3uest! ) wi## submit my persona# invoies with desriptions of 2persona# servies2 and 2produts2
    un#ess advised otherwise by 4r! 5a(son!" "hat did that mean?
    A$ *t meant that Michael didn#t "ant people to kno" he "ore a "ig$ +nd * kne" "hen you hand in receipts,
    people "ant to kno" "hat they are for, and * "anted to make sure * could keep Michael#s personal$$$ this as
    private as * possibly could$ &o that "as my re4uest8 that unless Michael ()s letting everybody kno" "hat it is,
    * "anted it to be as private for him as possible$
    &$ o", last time "hen you "ere here, you had testified about a /r$ MetFger?
    A$ -orrect$
    &$ +nd could you remind us "ho /r$ MetFger is?
    A$ He#s a doctor$
    &$ /id you have an understanding as to his relationship "ith Mr$ Jackson?
    A$ He had been a doctor that had taken care of Michael for a very long period of time in his life$
    &$ +nd do you remember testifying that you had talked to /r$ MetFger and had gotten him to prescribe some
    medications for Mr$ Jackson, and he had done so in your name?
    A$ -osmetic$
    &$ 5hat "as propecia and latisse?
    A$ ,es$
    &$ 0ere those also the types of things you "ere talking about in terms of not "anting to put in that Mr$
    Jackson had a prescription for latisse or a prescription for propecia?
    A$ ,eah$ 5hings that "ere private, that#s "hat this "as for$ * think "hen * "rote it, * "as more concerned for
    his hair and not that$ 1ut, yes, that "ould come under that category$

    &$ (n that testimony about asking /r$ MetFger for these prescriptions, you also mentioned a /r$ +rnold
    )lein$ /id you ever ask /r$ +rnold )lein for any prescriptions for Mr$ Jackson?
    A$ * "as in4uiring$$$ * think * e'plained to you before about 1oto', because 1oto' inhibits s"eating$ +nd *
    "as thinking that perhaps Michael could have 1oto' in!ections in his$$$ on his scalp to stop the s"eating$ *t
    "ould help the "ig and the adhesives of the "ig during his performance to stay in place, "ould stay more
    secure "ithout s"eat coming from underneath$ +nd * kne" it "as possible to do under your arms$ * had read
    that$ &o * in4uired "ith /r$ MetFger if it "ould "ork that "ay$ +nd he said, Byeah, it "ould probably react in
    the same "ay,B he goes, Bbut, you kno", * don#t$$$ you#d have to go to /r$ )lein for that, because * don#t kno",
    you kno", "hat Michael#s$$$ * don#t kno", you kno", other things he#s doing, like, to give an in!ection of 1oto'
    for$B so * called /r$ )lein$ * left a message, and * never got a return call at this particular time, regarding this$
    1ut * think that#s the only prescription, if that#s called a prescription, a 1oto' in!ection "ould be prescription or
    not$ 1ut * "ent in$$$ Michael also used creams that /r$ )lein makes, and * "ent into the office$ +nd /r$ )lein
    also had a supply of latisse$ +nd he said, Bhere, you can !ust take this for Michael, also$B and sunscreen$
    &$ +nd sunscreen?
    A$ +nd eye drops$
    &$ +nd, again, those prescriptions "ere all in your name, not in Mr$ Jackson#s name8 correct?
    A$ ;m, the ones from /r$ MetFger, the latisse and the propecia "as$ * asked him specifically if he "ould do
    that for me because$$$ and * "anted him to do it at a pharmacy near me so * could take them to Michael$ +nd
    especially the latisse to start using, because it takes about si' "eeks to start, and so * "anted to start Michael on
    that right a"ay$ +nd so he put the prescription in my name for the latisse and the propecia$ 5he propecia also
    is$$$ it re!uvenates hair on men#s scalps$ +nd so * needed as much healthy hair as possible on his scalp in order to
    secure his hairpieces$
    &$ (ther than that time "ith /r$ MetFger, or times "hen you "ere getting propecia and the latisse, are you
    a"are of any other time "hen /r$ MetFger prescribed medications of any sort for Mr$ Jackson in your name?
    A$ o, sir$
    &$ 0as there any other time "here you asked him to do so?
    A$ ()$ *#ve got to think back$ *s there any other time? 5hat#s a long time to think back$ *#d have to say, you
    kno", "ithout staying here for, like, about an hour and a half trying to figure it out, that * really don#t recall$
    &$ +nd "hat about "ith /r$ +rnold )lein? 0as there ever a time that you#re a"are of "here /r$ +rnold
    )lein had prescriptions for Mr$ Jackson done in your name?
    A$ * "ould pick up things for Michael at the pharmacy, but$$$ * "ould pick up skin creams, for his propecia$ *
    don#t kno" if they "ere put in my name$ +nd * kno" "ith the eye drops, * "ould sometimes pick them up for
    Michael$ +nd * cannot recall, for the life of me, "hether they "ere in my name or not$ * kno" Gvvy "ould send
    me some creams to take to Michael "hen * "as going to "herever he "as in the "orld$ &he "as, B(h, Michael
    needs this$ 0ill you take this cream?B
    &$ &o his$$$
    A$ +nd * can#t recall, for the life of me, "hether my name "as on it or not$
    &$ 5hat#s all *#m asking, if you remember$

    A$ * can#t$
    &$ &o you don#t kno" "hether prescriptions "ere put in your name for Mr$ Jackson? ,ou !ust don#t
    remember?
    A$ <ight$ * don#t recall if they "ere in my name$ *#m telling you the things that * did pick up for him$
    &$ <ight$ +nd in terms of these pickups$$$ let me make sure * understand$ &o there "ere times "hen Mr$
    Jackson "as on tour "here Ms$$$$ *#ll mess up her name, *#m sorry, Gvvy 5avasci?
    A$ 5avasci$
    &$ &he "ould contact you and ask you to bring stuff to Mr$ Jackson?
    A$ * mean, it "as$$$ * mean, not$$$ * mean, it "as very rare$ <arely$ Aery rarely$ 1ut it "as his skin cream$
    &$ 1ut that happened on occasion, then?
    A$ 5hree or four times in 6C years$ 0ell, she "asn#t there 6C years, but$$$ yeah, it "as$$$ they "ere a"k"ard
    because they "ere really big tubs$
    &$ ()$ +nd did you agree and bring those to Mr$ Jackson?
    A$ ,eah$
    A$ %e" times, yeah$
    &$ .oing back to your contract, "hich is "here "e "ere, do you recall ho" you "ere paid?
    A$ * think there "as$$$ it "as put into 5aunya Hilkie#s account, our business account$
    &$ +nd do you recall being paid a different amount "hile you "ere in >os +ngeles than "hat you "ere going
    to be paid in >ondon?
    A$ -orrect$ * think it "as about half$ 5hat "as the usual procedure: "hen you#re on tour, that the rehearsal
    rate is usually about half$$$ "ell, it#s al"ays been "ith me$ * don#t kno"$ * never revie"ed other people#s
    contracts$ 1ut during the preparation, it "as about half the rate$ +nd then as soon as you got on tour, you "ould
    get your full rate$
    &$ +nd is it fair to say that the amount of monies that you "ould be receiving "ere a large portion of your
    income?
    A$ 0hen you#re$$$ yes$
    &$ +nd you said it "as paid to Ms$ Hilkie$ /id she then take a portion of those monies?
    A$ * think * "as giving her something to take care of all of my business and pay bills "hile * "as$$$ and * can#t
    recall ho" much it "as$
    &$ ()$ 0as it a percentage or a flat fee?

    A$ * can#t recall$ *t could have been one or the other$ * mean, * kno" * "as$$$ * remember negotiating "ith her
    something that "as fair, because she "ouldn#t be doing a "hole lot$
    &$ +nd she doesn#t "ork for you anymore8 right?
    A$ o$
    &$ &o, ultimately, a time did come, then, "here you signed this agreement8 correct? * sho"ed you that
    signature$
    A$ 5his particular piece? 5his particular thing * don#t think * signed, but this one$
    &$ 0hen you say, Bthis particular oneB$$$
    A$ (h, * don#t see$$$ those "eren#t my initials$
    &$ 0hen you say, Bthis particular thing,B you#re talking about the list of re4uests?
    A$ 5he "hat? 0hat particular thing?
    &$ ,ou !ust said, B* didn#t sign this particular thing$B
    A$ -orrect$
    &$ +re you talking about the list of re4uests?
    A$ * don#t see that my signature is on it$ 5hat#s all *#m saying$
    &$ 5hose "ere your re4uests?
    A$ 5hese "ere my "orking re4uests$
    &$ >et me ask you a 4uestion$ ,ou talked about "ho you "orked for$ /id$$$ did Mr$ .onga"are ever tell you
    ho" to perform your services to Mr$ Jackson?
    A$ o$
    &$ 0ould Mr$ <andy Phillips?
    A$ He "ould not tell me ho" to do makeup or hair, sir, no$
    &$ +nd "hat about )enny (rtega?
    A$ He "ould not tell me ho" to do makeup or hair, sir$ He did re4uire me to put things in Michael#s ears$ He
    demanded it$ He demanded Michael take off his sunglasses$ 5hey did give me orders, sir, but not pertaining to
    his makeup and hair$
    &$ 0ho did you ans"er to about your makeup and hair?
    A$ Michael, sir$
    &$ +nd did you consider him to be the person "ho hired you?

    A$ He re4uested me, sir$


    &$ +nd ho" do you kno" he re4uested you?
    A$ He called me and asked me$
    &$ ()$ &o the re4uest "as made of you$ 0hen you said he re4uested you, he re4uested that you$$$
    A$ /o his makeup and hair$
    &$ &o he asked you to come "ork for him8 correct?
    A$ -orrect$
    &$ +nd you said, ByesB8 correct?
    A$ -orrect$
    &$ +nd you started "orking for him at that time8 correct?
    A$ -orrect$
    &$ +nd sometime thereafter, a contract "as negotiated "ith +G. >ive for your payment?
    A$ -orrect$
    &$ +t the time that you "ere hired, ma#am, do you kno" if anyone did a background check on you?
    A$ *t#s so funny$ * don#t think so$
    &$ 0hy is that funny?
    A$ 1ecause * kno" there#s a "hole thing about background checks$
    &$ Ho" do you kno" that?
    A$ 1ecause it#s in the ne"s$ *t#s "hat the case is about, isn#t it, a lot of it? &o, no, there "as no background
    check on me, that *#m a"are of$
    &$ Have you been follo"ing the case closely?
    A$ ot too, because there#s not that much information$ 1ut * do hear things, yes, sir, on the ne"s, internet$
    &$ *n fact, you talked last time about the idea that you have "eb sites and t"itter accounts$ ,ou#ve been
    t"eeting about this, have you not?
    A$ Aery little$ * catch myself$ People ask me 4uestions, t"eet me stuff, ask me, and so *#m, Boh, no$ * really
    shouldn#t be talking about this,B so * really tried not to$
    &$ >ittle t"eets about the evidence, and things like that8 correct?

    A$ 5he evidence?
    &$ 5estimony that comes in$
    A$ * don#t kno"$ * can#t recall all "hat * t"eeted and "hat * didn#t$ * t"eet a lot, sir$
    &$ ,ou do t"eets a lot?
    A$ -orrect$
    &$ +nd you t"eet a lot about this case and Mr$ Jackson, do you not?
    A$ * had before it started, and *#ve tried to not say too much no", sir$
    &$ &o you#ve tried to not say too much since the case started?
    A$ -orrect$
    &$ Haven#t been able to control it, so you !ust go out and do it any"ay?
    A$ &orry?
    &$ &o if you tried not to, "hy did you t"eet any"ay?
    A$ * t"eet all the time, and not necessarily about the case all the time$ 1ut since$$$ a lot$$$ most of my
    follo"ers are fans and "ho follo" it very, very closely$ + lot closer than * do8 ()? &o they#ll say something,
    and my instinct is to ans"er the 4uestion$ +nd sometimes * t"eet it before *$$$ you kno", and then * say, Boh, no,
    * can#t,B so * pull back, and * try not to, sir$
    &$ 5he$$$ so you said that you thought it "as funny$ *#ll ask you: do you have any idea "hether Mr$ Jackson
    did a background check on you, ever?
    A$ ot to my kno"ledge$ * have no kno"ledge of "hat he did or did not do, because it "as$$$ * "as, like, 6C
    "hen * first met him$ &o * don#t kno" if he did something "ay back then or not, or any of his people did$ * have
    no clue$
    &$ +nd "hat about at this point in time in March or +pril of 633= "hen he called and asked you to come
    back and "ork for him? /o you think he did one then?
    A$ /id Michael?
    &$ ;h-huh$
    A$ * doubt it$
    &$ 0hat about$$$
    A$ * don#t kno", but it "ould be unlikely$
    &$ 0hy "ould it be unlikely, ma#am?
    A$ 1ecause *#ve kno"n him for a very, very long time$

    &$ ,ou already "orked "ith him before?


    A$ Pardon?
    &$ He had already "orked "ith you before?
    A$ ,ears, sir$ 0e gre" up together, sir, basically$
    &$ +nd do you have any understanding as to "hether +G. >ive productions did a background check you
    on?
    A$ * have no idea, sir$
    &$ *#m not going to go into details on this$ *#m going to ask you a 4uestion, though$
    A$ +ll right$
    &$ *f they did a financial background check on you, "ould they find things that "ould indicate you might be
    a financial risk?
    #r$ %anish" *#m going to ob!ect: no$ 2, relevance8 no$ 6, speculation as to financial risk$ +nd also goes into
    privacy and confidentiality of this "itness, "ho is not a party and hadn#t put that in issue$
    #r$ %utnam" * think it#s 233 percent at issue, your honor$
    #r$ %anish" this "itness hasn#t volunteered$$$ come on$
    Ju!e" sustained$
    #r$ %utnam" all right$ *#ll move past that, then, your honor$
    &$ so you started "orking for Mr$ Jackson in +pril and may of 633=8 correct? *#m going to ask you very
    briefly, if you could tell me, "hat did you do in +pril and may, 633=, "ith Mr$ Jackson?
    A$ %our years ago, "hat did *$$$ bet"een +pril$$$ you#re talking about$$$ ()$ *$$$ ()$ >et me !ust$$$ because *
    have to really think back$ ()$ 1et"een +pril$$$ you#re talking about after * first met him?
    &$ ;h-huh$
    A$ 5o "hat date in May? 5o "hat "as going on in may? May, "ere "e at the forum$
    &$ >et me try to help "ith that, then$
    A$ 5hank you$ * appreciate that, because it#s, like$$$
    &$ ()$ +nything to help$ ,ou moved to the forum the very beginning of June$ 1efore that, they#re at center
    staging$$$
    A$ -orrect$

    &$ $$$ as "ell as he#s doing things at -arol"ood$ &o that#s "hy *#m asking the 4uestions$ ;p until the forum, so
    +pril and May, you go to -arol"ood "ith the "ig maker?
    A$ ;h-huh$
    &$ 0hat do you do in +pril and May "ith Mr$ Jackson up until the forum?
    A$ 0ell, there "ere some production meetings$$$ like$$$ ()$ 0e "ere at the staging, ()$ 0hat#s it called?
    -enter staging?
    &$ ;h-huh$
    A$ +nd * "ould go there, kind of prep Michael#s hair a little bit$ 0e "ould have some meetings$ * "as still
    doing other !obs at the very beginning, because nothing "as really solidified$ obody "as giving me a schedule
    of "hat * "as supposed to do$ * "as researching all the adhesives that "ere available$ * "as figuring out "ays to
    do my !ob and make it successful$ * "as doing a lot of that "ork$ +nd * "ould$$$ they "ould call me and say,
    BMichael is here, and he#s asking for you,B so * "ould have to go to center staging "hen he re4uested me$ * had
    to$$$ * "ent to a fe" production meetings$ 5hings like that$
    &$ +nd did you get$$$ in this time period, did the production provide you, say, "ith a daily schedule of "hat
    "as going on?
    A$ o, sir$
    &$ 0as there ever a time "hen they gave you a daily schedule of "hat "as going on?
    A$ o, sir$
    &$ +nd "hen it came$$$ you said they "ould call you and tell you you needed to come to center staging
    because Mr$ Jackson "as asking for you$ 0ho "ould call you?
    A$ 0as usually +lif, sir$
    &$ +lif &ankey?
    A$ ,es, sir$
    &$ +nd in this time period, +prilJMay 633=, ho" often did you see Mr$ Jackson?
    A$ ()$ Ho" many days is that? ,ou#re talking about$$$ give me a span of$$$
    &$ >et#s say it#s @3$
    A$ Huh? @3 days?
    &$ @3 days$ +pril and May$
    A$ (h, +pril and may$ * really don#t recall$ * "ould go there as much as * could "hen Michael "as there$ &o
    "hen he "as there, * "as usually there$
    &$ &o let#s take an estimate$$$

    A$ Ho" many days "as Michael there? ,ou#re asking me to guess stuff, you kno"$
    &$ *#m certainly not asking you to guess, ma#am$
    A$ ,eah$ ,ou said, Blet#s guess$B
    &$ * said, let#s estimate$
    A$ >et#s estimate$
    &$ * "asn#t there, you "ere$ &o *#m trying to find out$$$
    A$ <ight$
    &$ $$$ ho" often "ere you there? ,ou said you "ere usually$$$
    A$ ()$ +nd the forum$ +re you including the forum in that, also?
    &$ o$ +pril, may$
    A$ Just center staging?
    &$ Just center staging$ +nd that#s e'actly "hy *#m doing it$ *#m trying to break it into parts$
    A$ 5hey "ere there "orking before * "as$ * began$$$ *#m telling you, * began to "ork "ith Michael almost
    immediately, trying to do all these "igs and things$ &o * don#t kno" ho" often * really "ent$ * could not tell
    you$ * can#t even really kind of guesstimate, because * can#t recall$ 1ut * "ould be there "hen Michael "as there,
    "hen people re4uested me to be there$ +nd * "ent as often as * could$
    &$ +nd that "as at center staging?
    A$ -orrect$
    &$ ,ou mentioned that you "ent this first time to -arol"ood "ith your "ig maker?
    A$ -orrect$
    &$ /id you go other times to -arol"ood in +pril and May?
    A$ ,eah, * "ould have, because the first time * didn#t get to do "hat * needed to do$ * needed to take
    measurements of Michael#s head$ 5hat#s "hy * brought the "ig maker "ith me$ 0e had to make e'act
    measurements of every aspect of his head, and that didn#t get done, because "e spent so much time kind of
    hanging out and being happy and talking, and so that never happened$ &o "e had a return visit to do that$ &o
    that "ould have been t"ice$ 5hen once that "as made, * "ent back to put it on for him, so$$$
    &$ 5hree times?
    A$ ,eah, maybe$
    &$ ()$ +nd in that time, did you get a tour of the house?
    A$ o, sir$ * never had a tour of the house, no$

    &$ /id you ever leave the first floor?


    A$ * "orked on the very ground floor, and * had seen the first floor, sir$
    &$ &o "hen you say, Bground floor,B is that the floor belo" "here you "alk in?
    A$ 5hat#s correct$
    &$ * think they said there "as a gym do"n there and a theater?
    A$ * didn#t "ander around there too much, because * "orked in a bedroom "ith a good-siFed bathroom in it,
    "as "here * "as$
    &$ /o"nstairs?
    A$ -orrect$
    &$ /id you ever go to the second floor? 5o the bedrooms on the second floor?
    A$ o, sir$
    #r$ %utnam" should * start a ne" area, or is it$$$ it#s up to you$
    Ju!e" if it#s a ne" area, no$ 0e can break no"$ ()$ 2:93$
    #r$ %anish" "ell, your honor, * think you have
    A$ -alendar this afternoon$
    Ju!e" oh, * do$ ,ou guys kno" more than * do$ ()$ 6:33, then$ 5hank you$ (the !ury e'ited the courtroom at
    22:7? a$m$)
    Ju!e" ()$ &ee you in the afternoon, then$
    'the (o))o*in! +ro,eein!s *ere hear in o+en ,ourt- outsie the +resen,e o( the .ury/"
    Ju!e" /oes she need any of the documents that you gave her earlier?
    #r$ %utnam" *f so, your honor, *#ll give her ne" ones$
    #s$ Ste00ins" ,our honor, "e have e'tra copies8 so if anything is needed, "e can find another one$
    #r$ %anish" * doubt it$
    (the follo"ing proceedings "ere held in open court, in the presence of the !urors):
    Ju!e" )atherine Jackson versus +G. >ive$ .ood afternoon, everybody$ ,ou May continue$

    #r$ %utnam" 5hank you, your honor$


    Cross1e2amination 0y #ar3in %utnam"
    K$ Ms$ %aye, in the hopes of getting this over "ith today, *#m going to do a couple of things to maybe speed it up a bit$
    +$ 5hat "ould be great$
    K$ *#m trying$ *f it goes too fast so you don#t understand the 4uestion, please let me kno"$
    +$ (kay$
    K$ (ne "ay * thought * could do it is this$ 5here "as an e'hibit that "as admitted before that sho"s the calendar "here
    people "ere at certain points$ +nd *#m going to put that up, if * May$ *t#s e'hibit 29D39$
    +$ 5hat#s the venue thing?
    K$ <ight$
    +$ 5hat#s not this?
    K$ *t#s a demonstrative !ust to sho" -- *#m going to go through like "e did before$ &o the date "e#re talking about "as at
    -enter &taging from March 6? to May 6C$ /o you see that there?
    +$ (h, here$ *#m sorry$ * thought you "ere talking about this thing$ (kay$ March 6?th through May 6Cth, -enter &taging$
    (kay$
    K$ +nd then it moved on to the %orum May 6C to June 69rd$ /o you see that?
    +$ (kay$
    K$ +nd then June 69rd until Mr$ Jackson#s passing --
    +$ 1ecause "e moved out of the %orum before the 69rd$
    K$ G'actly, because you moved out and they had to take a couple of days to move in, right?
    +$ -orrect, uh-huh$
    K$ +nd does this roughly comport to your understanding --
    +$ /oes it "hat?
    K$ *s it roughly "hat you remember as to "here --
    +$ 0hat "as the "ord that you used?
    K$ B-omport$B
    +$ B-omport$B 5hat#s a ne" one$ (kay$ *t looks pretty -- it looks pretty accurate$
    K$ (kay$ &o *#ll !ust leave that there to help, maybe help it go along$ &o the time "e "ere talking about "as the time at
    -enter &taging, and "e talked about -- you talked about a couple of times, you said three, that you might have gone to
    -arol"ood in that time period$

    +$ (kay$
    K$ +nd "e "ere trying to figure out if you had any idea of ho" often you sa" Mr$ Jackson at -enter &taging in this time
    period$ +nd you asked ho" many days, * had guessed @3$ &o a little --
    + * !ust -- * can#t remember$
    K$ ,ou don#t kno"$ /o you think it "as more than once a "eek?
    +$ ,es$
    K$ /o you think it "as as many times as four times a "eek?
    +$ * mean, it could have been$ * can#t s"ear to it$
    K$ ,ou !ust don#t kno"?
    +$ (kay$ * don#t kno"$
    K$ 5hat#s my 4uestion$ ,ou !ust don#t kno"?
    +$ * !ust can#t really recall ho" many times * "ent there$
    K$ +ll right$ +nd then the time came "here it moved to the %orum$ ,ou remember that, right?
    +$ ,es$
    K$ +nd do you remember the time that it moved to the %orum, concurrently, you "ere shooting short films do"n at
    -ulver?
    +$ -orrect, correct$
    K$ /o you remember that?
    +$ *t "as like in the beginning --
    K$ (f June?
    +$ 1efore "e even really did anything at the %orum, * think$
    K$ (kay$ +nd in this time period, the beginning of June, *#m not talking about the last "eek -- all right? &o the beginning
    of June, at that time period, did you believe that Mr$ Jackson seemed upbeat?
    +$ +re you talking about "hen "e "ere making the films?
    K$ Making the films in your first t"o "eeks at the %orum there$
    +$ He seemed okay$
    K$ +nd did he seem focused to you at that time period?
    +$ *n comparative to ho" * used to kno" him$
    K$ ;h-huh$
    +$ *t "as -- it "as a little different, you kno"$ * can#t say it "as e'actly ho" it used to be, you kno"8 but he seemed

    relatively okay, he "as able to function, everything$ * noticed some physical things that "ere odd, but --
    K$ (kay$
    +$ +t that time --
    K$ +nd it had been four years since you#d last seen him, correct?
    +$ -orrect$
    K$ +nd it had been more than a decade since you had "orked "ith him and he had performed, correct? (r about a decade?
    +$ 0hen "as his last performance?
    K$ * think it "as maybe 6332$
    +$ 6333 -- * think so, yeah$
    K$ 5he 93th anniversary sho"?
    +$ &o that "ould be -- oh, yeah$
    K$ &o --
    +$ * appreciate the help$ *#m really bad "ith dates and stuff$ * really do$ * really do$ &o if you --
    K$ 5hat#s "hat *#m trying to do this afternoon$ * don#t "ant to be too leading "ith it to the point "here *#m putting "ords in
    your mouth$
    +$ * gotcha$ 1ut date and time is kind of helpful to me because *#m old$ (kay$
    K$ &peaking of old, Mr$ Jackson "as a lot older at this point, too, right?
    +$ -orrect$ * think 73$
    K$ *t had been about a decade since you#d "orked "ith him?
    +$ ;h-huh$
    K$ 1ut at this time period at the beginning at the %orum, you didn#t have any particular concerns, correct?
    +$ 5he dryness of his skin bothered me during the filming, because it "as really, really dry, and that kind of bothered me$
    1ut it "asn#t something that "ould send up any kind of ma!or alarms$
    K$ +nd, in fact --
    +$ *t "as his -- his thinness kind of -- * "as trying -- let me -- * -- his thinness "as still bothering me because * -- * noticed
    that he "asn#t -- from the time * first met him, * thought he needed to gain like 27 pounds8 but instead, he "asn#t like
    gaining anything, so that "as concerned -- that "as a concern to me so much that acacia -- * brought +cacia over$ +nd she
    used to be his cook a long time ago, chef, during the 1ad tour, and during the 1ad era, from the very beginning$ +nd he
    used to love her food$ +nd she opened up a restaurant across the street from -ulver &tudios, so * thought it "ould be a
    really good "ay to try to introduce him into maybe eating more by inviting her over to bring some lunch, so * did that$ *
    still "as concerned, because * did that$ * !ust really "anted him to get in touch "ith things that he really liked, you kno",
    and maybe he#d start eating more$

    K$ 1ut -- but there "as not particular concern, other than the "eight and the dry skin, during this period of time, correct?
    +$ * "ould say that "as correct$
    K$ +nd !ust very 4uickly on the +cacia$ +cacia had formerly been his chef, right?
    +$ ,es$
    K$ +nd you had brought her over -- do you remember it "as on June ? that you brought her over?
    +$ * don#t remember the date, again8 but it "as during the filming, because she "as so close, and * really "anted --
    because, you kno", +cacia had never met his kids or anything, you kno"$ *t "as really nice$
    K$ 5hat "as a great day, "asn#t it?
    +$ *t "as a good day, yeah$
    K$ +nd it "as like a 26-hour day, "as it not? /o you remember?
    +$ * don#t recall$
    K$ /o you remember him being there 4uite a long day that day?
    +$ *t "as a "orking day$ *n my business it can be a long -- 26 hours$
    K$ 1ut a time came "here you did gro" concerned, and that "as in the "eek prior to his passing, correct?
    +$ ,es$
    K$ +nd "as that the time period in "hich you actually -- that#s "hen you first became truly concerned that there might be
    something "rong "ith Mr$ Jackson?
    +$ ,es$
    K$ +nd you noticed a change that "eek?
    +$ * have to say "hen -- you kno", "hen he first got up onstage, the first thing he kind of did onstage "as a solo thing$ *
    think it "as 1illie Jean, and you kno", he did -- did really "ell$ *t "asn#t the -- you kno", the Michael Jackson "hen he
    "as 6=8 but, you kno" -- and 1illie Jean is -- he did 1illie Jean and the dancers all "atched him and, you kno", they "ere
    !ust -- Bthat#s Michael Jackson$ *#m seeing him do 1illie Jean$ they "ere all really e'cited about it, and "e all felt good
    about that$ 1ut then after"ards, "hen -- it !ust kind of changed "hen he had to get up onstage "ith everybody else and
    actually do -- start rehearsing the sho"$
    K$ +nd that concern arose in the last "eek of his life, correct, ma#am?
    +$ Pardon?
    K$ 5hat concern of yours arose in the last "eek of his life, correct?
    +$ (no audible response)
    K$ ,ou tried to figure out "hy there "as a change?
    Ju!e" 4as that a 5yes56
    7he *itness" 58es$5 I9m sorry$

    K$ +nd you tried to figure out "hat "as "rong, didn#t you?
    +$ ,es$
    K$ +nd ho" did you go about trying to figure out "hat "as "rong?
    +$ 0ell, * think the first thing "as * asked Michael#s security if he "as going to /r$ )lein$
    K$ &o you "ere concerned8 and your first 4uestion "as to his security to say, B*s he going to see /r$ )lein?B "hy did you
    ask that?
    +$ *t "as -- because -- because, as * said before, and * e'plained before, * "as al"ays kind of on the lookout for doctors
    and things like that getting involved$
    K$ +nd -- but did you ask them if he "as going to see /r$ MetFger?
    +$ o, * didn#t ask them that because * had talked to /r$ MetFger about other things, and * think /r$ MetFger "ould have
    told me$
    K$ +nd you also had been to /r$ )lein#s office to pick up creams, had you not?
    +$ ,es$
    K$ &o "hy "as it that "hen you sa" that there "as something "rong, you "ent to security to ask is he going to see /r$
    )lein?
    +$ &ay that 4uestion again?
    K$ 0hen you became concerned in that last "eek, you "ent to Mr$ Jackson#s security and said, Bis he going to see /r$
    )lein?B -orrect?
    +$ ;h-huh$
    K$ +nd "hy is it /r$ )lein is the person you asked if he "as going to see?
    +$ 0hy did * go to /r$ )lein? 1ecause in the media, there "ere reports that he "as -- like the -- that he had gone there,
    you kno", and * kind -- "hat * asked "as ho" often "as he going$
    K$ +nd you kne" /r$ )lein, did you not?
    +$ ,es$
    K$ +nd you had kno"n that he "as a dermatologist?
    +$ -orrect$
    K$ +nd you had kno"n that Mr$ Jackson had seen him for years, correct?
    +$ -orrect$
    K$ +nd you had an understanding that he "as going to see him in this time period, correct?
    +$ 1y the media, yes, correct$
    K$ 1ut then you asked security, and did they confirm for you "hether he "as seeing -- going to see /r$ )lein?

    +$ ,es$
    K$ +nd did they confirm to you ho" often?
    +$ 5hey said probably maybe three, four days a "eek$
    K$ +nd did that concern you?
    +$ ,es$ (h, * said, Byes$B ,es, it did$
    K$ +nd "hy did that concern you?
    +$ 0ell, because of the past "ith everything * e'plained to you before, "hen * see doctors getting really involved in his
    life, it kind of "as this moment of -- "here * "ould be concerned$
    K$ &o it "asn#t /r$ )lein in particular?
    +$ 0ell, it "as /r$ )lein in particular in this instance because that#s "here he "as going$
    K$ 1ut you also kne" that he had a /r$ MetFger "ho "as his longtime doctor, right?
    +$ ,es$
    K$ 1ut you "eren#t concerned about him seeing /r$ MetFger?
    +$ * didn#t see him going to him on a regular basis$ *n fact, /r$ MetFger asked me if * could -- could * -- B* "ould love to
    see Michael$ -an you tell him that * "ould !ust love to see him and meet his children?B so there "asn#t -- he "asn#t going
    -- that#s "hy it "asn#t a concern, because /r$ MetFger !ust "anted to say hello to him$
    K$ &o at this point in time, "hich is the "eek before Mr$ Jackson#s passing, you didn#t have an understanding as to "hether
    or not /r$ MetFger had already seen Mr$ Jackson in that time period? +nd by Bthat time period,B * mean 633=$
    +$ * think they actually -- * think they met$ * think they actually did meet at some particular time$ * can#t be certain of that$
    K$ (kay$ o", did you ask Mr$ Jackson#s security "hy they "ere taking Mr$ Jackson to see /r$ )lein?
    +$ o$
    K$ *#m not asking "hat they told you, *#m asking did you ask them$
    +$ o$
    K$ &o you didn#t ask them$ /id you ask them "hy -- "hat kind of treatment /r$ )lein "as providing?
    +$ o$
    K$ /id you ask Mr$ Jackson "hy he "as going to see /r$ )lein?
    +$ o$
    K$ 1ut you "ere concerned about the fact that he "as going to see /r$ )lein, correct?
    +$ *t -- yeah, * "as a little concerned$
    K$ /id you e'press that concern to anybody?

    +$ ,es$
    K$ 0ho did you e'press that to?
    +$ %rank /ileo$
    K$ +nd "ho is Mr$ /ileo? Just to remind --
    +$ %rank /ileo "as "orking -- "ell, you kno", * !ust can#t -- it#s really hard for me to tell you because the title is so
    unclear$
    K$ (kay$ >et me ask you in a broader sense$
    +$ (kay$
    K$ Ho" long had you kno"n Mr$ /ileo at this point?
    +$ *#ve kno"n %rank /ileo since the #?3#s$
    K$ +nd have you kno"n him about as long as you#ve kno"n Mr$ Jackson?
    +$ Probably longer, because * kind of kne" him in pittsburgh "hen * "as gro"ing up$ 0e#re both from the same city$ 1ut
    yes -- yes, but not professionally -- *#ve kno"n him for a long time$
    K$ +nd you kne" him to be Mr$ Jackson#s manager at various points?
    +$ -orrect$
    K$ +nd he "as "orking "ith Mr$ Jackson in some capacity on the 5his *s *t tour?
    +$ -orrect$
    K$ +nd he#s the person you asked about "hy Mr$ Jackson "as going to see /r$ +rnold )lein?
    +$ o, * didn#t ask him that 4uestion$
    K$ ,ou spoke to him about it? *#m not asking "hat he said, but you spoke to him about it?
    +$ *#m !ust trying to think$ /id * speak to -- * had conversations "ith him regarding my concerns, and part of that "as
    Michael#s visits to +rnold )lein$
    K$ +nd by this period of time, you understood that Mr$ Jackson "as seeing a /r$ -onrad Murray, as "ell, did you not?
    +$ * did not kno" that until the middle of the "eek "hen * "as really getting "orried about Michael#s psychological state$
    K$ +nd that#s the "eek before his passing, correct?
    +$ -orrect$
    K$ &o at this period of time, you "ere concerned about /r$ +rnold )lein, and you "ere a"are of /r$ -onrad Murray8 is
    that fair to say?
    +$ -orrect, in the "eek before Michael passed, yes$
    K$ +nd did you e'press any concern to anyone about /r$ -onrad Murray at that time?

    +$ * had a conversation "ith )enny (rtega "hen )enny (rtega told me about --
    K$ * don#t "ant to kno" "hat he told you$
    +$ (h$ * --
    K$ Just -- *#m sorry if * put my hand up$ *#m not trying to be rude$
    +$ * got the hand$ * got the hand$ * kno" you#re trying to stop me$ (kay$ * had a conversation "ith )enny (rtega$
    K$ +bout -- and did you ask Mr$ (rtega about /r$ -onrad Murray?
    +$ ,es$
    K$ +nd did you ask him "hy he "as treating Michael Jackson?
    +$ o$
    K$ /id you ask Mr$ (rtega "hy /r$ +rnold )lein "as treating Michael Jackson?
    #r$ %anish" 8our honor- e2,use me$ Isn9t this a)) hearsay6
    #r$ %utnam" 5:i you as; him65
    Ju!e" %ro0a0)y$
    #r$ %anish" 5:i you as; him-5 that re3ea)s the su0stan,e o( the ,on3ersation$ I( you as;e him- i( the ans*er is
    yes- then that9s a hearsay statement$
    #r$ %utnam" No$ A,tua))y- your honor 11
    #r$ %anish" A0so)ute)y is$
    #r$ %utnam" 8our honor- *hat I9m as;in! 11 0e,ause *hat I thin; is im+ortant here is *hat her ,on,erns *ere-
    an *ho she *ent to to as; a0out them- an *hat she in<uire o($ I9m not as;in! *hat they sai- I9m not as;in!
    *hat the res+onse *as$ I on9t *ant to ;no* any o( that$ 4hat I *ant to ;no* is *hat she i$
    #r$ %anish" 4hat you in<uire o( is hearsay$
    Ju!e" O3erru)e$ 8ou #ay ,ontinue$
    #r$ %utnam" 7han; you$
    7he *itness" A(ter a)) that- *ou) you min re+eatin! it- +)ease6
    #r$ %utnam" I on9t min at a))- ma9am$
    K$ &o at this time period, did you e'press to )enny (rtega any concern you had about /r$ -onrad Murray?
    +$ ,es$
    K$ +nd at that time period, did you e'press any concern you had about -- strike that$ *n terms of that, "hat "as your
    concern at that time, your concern at that time about Mr$ -onrad Murray?
    + if he "as a psychologist$

    K$ +nd that "as something you e'pressed to Mr$ (rtega?


    +$ -orrect$
    K$ +nd did you have any other concern that you e'pressed to Mr$ (rtega at that time in terms of /r$ -onrad Murray?
    +$ * didn#t kno" -onrad Murray at that particular point, so * didn#t have a reference of 4uestions$
    K$ (kay$
    +$ (ther than "hat * thought Michael needed$
    K$ +nd in terms of /r$ +rnold )lein, "ere you at all specific to )enny (rtega as to "hat your concern "as about /r$
    +rnold )lein?
    #r$ %anish" Just (or the re,or- it9s ,a))in! (or hearsay$
    #r$ %utnam" I9m not as;in! *hat the res+onse *as$
    Ju!e" 8eah$ I ;no*$ I9m o3erru)in! your o0.e,tion$
    #r$ %anish" A)) ri!ht$ I9m .ust ma;in! my re,or$ 7he hearsay is ,omin! in a)) o3er- so 11
    K$ /o you remember the 4uestion?
    +$ +gain?
    K$ *#m sorry$ &o at that time, did you e'press your concern to )enny (rtega as to "hat /r$ +rnold )lein "as doing in
    terms of his treatment of Michael Jackson?
    +$ * can#t recall having a conversation about /r$ )lein "ith )enny (rtega$
    K$ o", you never met /r$ -onrad Murray, correct?
    +$ o, not -- not -- * "as never introduced to him$
    K$ 1ut you did see him once?
    +$ * sa" the back of his head, sir$
    K$ +nd do you remember "hen that "as, ma#am, and "here?
    +$ (n June 2?th, sir$
    K$ /o you remember "here that "as?
    +$ +t the %orum$
    K$ &o "e#re in this last "eek, and it "as during that -- there#s been a lot of testimony about that last "eek, so *#m not going
    to try to revisit all of it$ *#m going to ask you do you understand that in that time period, a day came "hen Mr$ Jackson
    "as cold and left rehearsal?
    +$ -orrect$
    K$ +nd do you remember that to be the 2=th of June?

    +$ -orrect$
    K$ &o you remember that day, yes?
    +$ -orrect$
    K$ +nd "hen you "ere here last time, you provided some testimony about a fitting on that day, and you "ere asked about
    a photo that "as taken$ /o you remember this testimony at all?
    +$ -orrect$
    K$ +nd you testified last time that you "ere there in the room for Mr$ Jackson#s fitting on the 2=th$ /o you remember
    saying that?
    +$ * "asn#t there for the entire fitting$ * "as there "hen it began and then * left the room because Michael "as going to be
    changing clothes$ +nd then after the fitting, * "ent back in$
    K$ &o in point of fact -- because the testimony last time asked if you "ere there for the fitting, and you said yes$ 1ut you#re
    clarifying no" that you "ere there, but !ust at the very beginning and the very end8 is that correct?
    #r$ %anish" I9m !oin! to o0.e,t to ,ounse)9s testimony as to *hat the testimony 11
    #r$ %utnam" I9)) sho* it$
    Ju!e" Sustaine$ Or you ,an as; her- 54as your testimony this65
    K$ 0as your testimony previously that on June 2=th, you "ere in the room for the fitting "hen you "ere sho"n the
    photograph of Mr$ Jackson "ith the "hite t-shirt on? /o you remember that testimony "hen you "ere here previously?
    +$ 5he e'act thing * said, but *#m going to clarify -- because like * "as -- can * do that?
    K$ ,es$
    +$ (kay$ * "as preparing -- doing his makeup and hair in the same room "hen the clothing designer and his assistant "as
    bringing in all the clothes, hanging them up, and preparing them, and sho"ing them, and everything$ 1ut "hen it came
    time for Michael to actually put on the clothes -- oh, Michael also asked for Michael 1ush to !oin him$ &o "hen Michael
    1ush came in the room -- and then * left "hile they actually did the fitting$ +nd then "hen they -- Michael "as actually in
    the clothes, * -- "hen they "ere done, * came back in and Michael 1ush and Michael Jackson "ere in the room$ &o * "as
    not there "hen they "ere like actually putting the clothes on him, but * "as there during portions of it$
    K$ +nd so -- that#s a proper clarification as to ho" --
    +$ 0hy * "ould say -- "hy * "as there during the fitting$
    K$ +nd so the photo you "ere sho"n --
    +$ -orrect$
    K$ -- you didn#t actually see Mr$ Jackson "hen he "as do"n to his t-shirt, correct?
    +$ * sa" him do"n to his t-shirt on several occasions$ /id * see the actual -- "hen they put those things on his shoulders? *
    "asn#t in the room "hen they did that or took pictures$ 1ut * have to say that * had to "ire Michael#s body during this
    particular time, and he had to be in a t-shirt, and * "as putting "ires and battery packs on him$
    K$ +nd *#m !ust asking about the fitting that day on the 2=th$

    +$ (kay$ &orry$ .o ahead$


    K$ &o you didn#t -- that photo that you "ere sho"n, you didn#t see him as he "as depicted in that photo, correct? /o you
    remember the photo --
    +$ ,es, * did not see that picture being taken$
    K$ (kay$ 5he -- so on the 2=th, Mr$ Jackson ultimately "as sent home and didn#t go out and rehearse that evening,
    correct?
    +$ -orrect$
    K$ +nd for point of record, *#m !ust going to tell you that "as the 2=th, it#s a %riday$ (kay?
    +$ -orrect$
    K$ +nd do you remember testifying last time that you "ere pressured to get Michael onstage and to not listen to him?
    +$ ,es$
    K$ *#m going to ask you a 4uestion$ /id <andy Phillips personally ever pressure you to get Michael Jackson onstage?
    +$ o$
    K$ /id Paul .onga"are ever pressure you personally to get Michael Jackson onstage?
    +$ o$
    K$ /id <andy Phillips ever instruct you personally to not listen to Michael Jackson?
    +$ o$
    K$ /id Paul .onga"are ever personally instruct you not to listen to Michael Jackson?
    +$ o$
    K$ /id you ever personally observe <andy Phillips telling anyone that Michael Jackson had to get onstage and rehearse?
    +$ He told me he "anted to build a "all around Michael, so that#s "hat Michael -- so Michael "as left "ith only time --
    BI want to put a wall --B he said, BI want to put a wall around Michael so he doesn't have to do anything but get to
    rehearsals$B He "as concerned about that, and he "as concerned "ith him not being at rehearsals$
    #r$ %utnam" I mo3e to stri;e as nonres+onsi3e- your honor$
    #r$ %anish" I on9t thin; so$
    Ju!e" O;ay$ #otion !rante- the ans*er is stri,;en$
    #r$ %utnam" Let me as; you the <uestion a!ain$
    7he *itness" O;ay$
    K$ /id you ever tell him -- did you ever hear him instructing anybody that they needed to get Mr$ Jackson up onstage?
    +nd by Bhim,B * mean <andy Phillips$

    +$ <ight$ *#m -- *#m trying to think because * "as not around <andy Phillips a lot$ *#d have to say not that * can recall$
    K$ 1ut you "ere there on the 2=th "hen Mr$ Jackson "as cold, correct?
    +$ -orrect$
    K$ +nd you "ere there "hen he "asn#t feeling "ell, correct?
    +$ -orrect$
    K$ +nd Mr$ -- and you kno" that Mr$ Jackson "as told to go home and not to rehearse, correct?
    +$ -orrect$
    K$ +nd do you have an understanding as to "hether Mr$ Jackson took a couple of days off after that?
    +$ -orrect$
    K$ *f that "as a %riday, the 2=th, do you understand that he -- that he didn#t rehearse &aturday, &unday or Monday?
    +$ -orrect$
    K$ o", on days like that -- let#s take the 63th to the 62st and the 66nd$ 0ould you still go to rehearsal?
    +$ 5hey "ere moving$ 5here#s nothing to go to rehearsal for, sir$
    K$ 5hat#s "hat * "as trying to ask you$ &o at this time that they "ere moving out, there "as nothing for you to do as the
    makeup person?
    +$ ,es8 * "as supposed to go to his house, sir$
    #r$ %anish" Just a se,on$ Someone9s +hone is rin!in!$
    7he *itness" I thin; it9s my +hone in here an you9re hearin! it on the mi,ro+hone$ It9s .ust 3i0ratin!- it9s not
    rin!in! 0e,ause I turne it o(($
    #r$ %anish" Some +eo+)e *ou) say that9s rin!in!$
    7he *itness" 4e))- is that 11 i9m sorry$ I turne it o(( 11 I in9t turn o(( the +hone- 0ut I turne o(( the 11
    #r$ %utnam" No *orries$
    7he *itness" O;ay$
    K$ ,ou said that on those days, you "ere supposed to go?
    +$ (kay$ * "as -- it "as time -- it "as time to change the unit that Michael had on his head, and "e "ere trying to
    schedule a time to do it over that "eekend$
    K$ +nd by the Bunit,B you mean the "ig?
    +$ ,es$
    K$ +nd "hy "as it time to change it? ,ou !ust had to do that intermittently?
    +$ 0hat?

    K$ ,ou had to change it intermittently, every once in a "hile?


    +$ 0ell, he had had that one on for "hat, like a month or something, month and a half, * put it on -- that "as the first
    piece * had made for him that "as going to be similar to the one he "as going to be "earing for the duration$ *t "as the
    first -- because the other piece that he had "as a big, heavy kind of straight "ig8 and "e "ent -- * made something that
    "as a lot lighter and it had more natural curly hair to it$ &o -- and it "as really important, also, you kno", that "e "ork
    out any bugs in it because * "as making all kinds of alterations to it so it#s something that he could perform in$ &o he had
    had that one on for -- for like a month or so, it "as time to -- * made -- the ne't one "as ne" and improved, and it "as
    time to put another one on$
    K$ ,ou "ere scheduled to do that that "eekend, ma#am?
    +$ ,es$
    K$ +nd did you, in fact, go to -arol"ood -- "as that to take place at -arol"ood?
    +$ ,es, sir$
    K$ +nd did you, in fact, go over to -arol"ood that "eekend and change the unit?
    +$ o$ * think * "as supposed to go on &aturday, and * got a phone call, and * can#t remember "ho it "as from, and * think
    said, Bno, he doesn#t "ant to do it today$B * think it "as probably one of his security guys called, and then it "as
    rescheduled for Monday$
    K$ &o you didn#t go &aturday and you didn#t go &unday, correct?
    +$ <ight$ *t "as %ather#s /ay$
    K$ *t "as %ather#s /ay?
    +$ ;h-huh$
    K$ &o that "ould be the 63th and the 62st$ +nd then the 66nd, did you go over and replace his hair?
    +$ * "ent over, sir, but he did not -- * "aited for a fe" hours, but * didn#t get a chance -- an opportunity to do it$ He said
    Michael didn#t -- * think 5rav -- * remember seeing 5ravis there, but he !ust stuck his head in$ * can#t recall if it "as 5ravis
    that said that, BMichael doesn#t "ant to really do that today, so you can go$B
    K$ +nd you said you "ere there a couple of hours?
    +$ ,es, sir$ * "as "aiting in the room underground "here "e usually "orked in$
    K$ 0ere you there by yourself?
    +$ His kids came by "ith their pets, and "e "ere talking and stuff$ 1ut other than that, yes$
    K$ 1ut you didn#t see Mr$ Jackson that day?
    +$ * did not$
    K$ /id you speak to his assistant, Mr$ Michael +mir 0illiams?
    +$ *#m !ust trying to kind of think because somebody had to have let me in the house, things like that, so * probably had
    some sort of communication "ith somebody "ho let me in the house$

    K$ * "as actually going to ask you about that$ (n the times that you "ent to the house, because you said there "ere
    probably three times in +pril and May, "e#re talking about this time no" on the 66nd of June$ 0hen you#d arrive at the
    house, can you !ust "alk me through ho" you#d get in? >ike you#d arrive$ 0as there a gate?
    +$ ,es, there "as a gate and a little intercom system$
    K$ &o you#d buFF the --
    +$ Push the button, identify yourself$
    K$ +nd then you#d go in? +nd "ould there be security there?
    + usually$
    K$ 0ould you "alk in or "ould you ring the bell? 0hat did you do ne't?
    +$ * "as usually met, somebody came to my car$
    K$ +nd then "ould you be brought into the house?
    +$ ,eah8 or they#d point to the door, or they#d -- a lot of times *#d have things or they#d help me carry it in, you kno", yes$
    K$ 0ould you go in the front door or "ould you go in the side door to the right?
    +$ * recall going through the kitchen once, but mostly through the front door$
    K$ +nd the kitchen "ould be that door to the right?
    +$ ,eah, it#s over and kind of in the back on the side, yeah$
    K$ +nd "hen you did this, "ould you go past the security trailer?
    +$ * think there "as some sort of structure -- * don#t kno" if it had "heels or not, but a structure on the right side$
    K$ +nd did you ever go in that structure?
    +$ Huh-uh$
    K$ +nd on this day on the 66nd, you can#t recall ho" you got in?
    +$ (kay$ ,ou "ant me to think about this? (kay$ ,ou kno", * can#t recall$
    K$ 1ut you do kno" that you didn#t see Mr$ Jackson that day?
    +$ -orrect$ +nd * "ent do"nstairs and "aited for him$
    K$ +nd then ultimately, he "asn#t going to see you, so you left?
    +$ -orrect$
    K$ /id you see him the ne't day, the 69rd?
    +$ &o that "ould be 5uesday, right? 5hat#s "hen "e "ent to the &taples -enter, correct? ,es$
    K$ &o this is the first time that you guys "ere at the &taples -enter, "hich is June 69rd?

    +$ -orrect$
    K$ +nd had you been in the &taples -enter yet before the 69rd for the B5his *s *tB tour?
    +$ o$
    K$ +nd "as your area all set up already "hen you arrived, or did you have to set it up?
    +$ 5hey sho"ed me a room "here -- that "ould be my room$
    K$ +nd "hen that happened, the stuff that you -- did you have stuff at the %orum that had to be moved to the &taples
    -enter?
    +$ ,es, * had some cases8 and then * also had a makeup mirror and things that had to be positioned in Michael#s room$
    K$ +nd "as that already done "hen you arrived, or did that have to occur once you arrived?
    +$ (h, gosh$ * don#t kno"$ * -- Michael#s -- * think Michael#s mirror "as set up in his room already, and probably the case
    "as !ust rolled into the other room$
    K$ +nd "as Mr$ Jackson already there "hen you arrived?
    +$ (n the 69rd$ * can#t really recall$
    K$ -an you recall being concerned about Mr$ Jackson#s health on %riday the 2=th?
    +$ G'tremely$
    K$ +nd no" it#s -- on the 62st -- sorry -- 66nd$ (n the 66nd, you "ent to his house and had hoped to put on a ne" unit and
    you couldn#t$ /id that make you -- "ere you still concerned at that point?
    +$ &ir, * "as very concerned during this period of time, this -- this time$ *t "as like -- * "as very, very frightened$ *n fact, *
    remember seeing -- "hen his children came in to see me, * -- * !ust had horrible thoughts of like, oh, my gosh, "hat if
    something "ere to happen? * don#t kno" "hat "ould happen to these children$ * "as !ust really, really frightened$
    K$ /id you ask Mr$ Payne, "hen you sa" him, ho" is Mr$ Jackson doing?
    +$ He !ust stuck his head in and ran out$ ,ou kno", it "as !ust like -- you kno", and ran out, so there "as no even time to
    discuss anything at that particular time$
    K$ /o you recall asking any of the security "hen you arrived ho" Mr$ Jackson "as doing?
    +$ * made a phone call on &aturday to +lberto +lvareF and asked him to make sure he "atches Michael very carefully
    because * "as afraid$
    K$ 0ho is Mr$ +lvareF?
    +$ He "as one of Michael#s security$ He "as the one security guard that * e'changed phone numbers "ith that * "ould
    call that he "ould tell me if Michael "as going to go to rehearsals$ 1ecause * "asn#t getting any information from the
    production company on -- on any of the schedules, so * relied on +lberto to tell me "hat "as going on and "hen Michael
    "as going to arrive and if he "as going to go that day or if he "asn#t going to go that day$
    K$ &o you called Mr$ +lvareF on &aturday the 63th and told him to be careful and "atch over Mr$ Jackson?
    +$ Just to "atch because * "as very frightened for him$

    K$ +nd did you ask Mr$ +lvareF ho" Mr$ Jackson "as doing that day?
    +$ Mr$ +lvareF didn#t "ant to even stay on the phone$ He goes, B0hat do you mean?B and he goes, B* gotta go$B
    K$ &o you didn#t ask him ho" Mr$ Jackson "as doing?
    +$ * can#t really recall$ * probably did because * could talk to +lberto, you kno", so * probably said, B*s Michael okay?B *
    can#t be absolutely positive e'actly "hat * said$
    K$ +nd did you see Mr$ +lvareF on the 66nd "hen you "ent to the house and "aited for Mr$ Jackson for t"o hours?
    +$ +s * said before, * don#t recall "ho actually entered or "hich -- "hich security guard met me or anything$
    K$ /o you remember asking any of the security ho" Mr$ Jackson "as doing on that Monday?
    +$ * really didn#t have an opportunity to talk to anybody but the children, and * "asn#t going to ask them$
    K$ +ll right$ 1ut you "ere there about t"o hours, right?
    +$ ,es$
    K$ &o no" "e#re on the 69rd, and you#re at the &taples -enter$ /id a time come "here Mr$ Jackson arrived?
    +$ ,es$
    K$ Ho" did he seem?
    +$ *#m trying to think$ *nitially, he seemed okay$
    K$ /id you -- "ere you alone "ith him in the makeup room?
    +$ ot at first$ 5here "ere kind of like meetings$ * remember there "ere a lot of people there, and "e "ere sitting around
    a monitor "atching "hat "as shot at -- at the -- "as it that day or the -- "e "ere -- there#s one of those days "e "ere
    "atching the monitor, "atching "hat "as shot at -ulver -ity$
    K$ 0as there a time "hen you "ere alone "ith Mr$ Jackson on that day?
    +$ *#m thinking -- pardon?
    K$ 0as there a time that day you "ere alone "ith Mr$ Jackson?
    +$ ,es$
    K$ +nd "hen you "ere alone "ith Mr$ Jackson, did you ask him if he "as feeling any better after the 2=th?
    +$ * don#t recall "hat * actually said, sir$ * probably said, BHo" are you doing? +re you okay?B you kno"$ * probably
    addressed it very casually, but * don#t remember having any heavy conversation about it$
    K$ &o you didn#t ask him "hat "as "rong "ith him the prior %riday?
    +$ o, sir$
    K$ +ll right$ 0ell, ho" "as his performance that day? /id he rehearse that day?
    +$ *#m sorry that *#m pausing$ *#m !ust trying to go back$

    K$ * "ant you to$


    +$ 1ecause it#s a really long -- a long time ago$
    K$ Place and time, it#s the 2=th, he left --
    +$ * kno"$ *#m !ust thinking of -- because * kno" * "as setting up under the stage because he had to have a 4uick-change
    room under the stage "here "e "ere going to have rehearsal$ (kay$ *#m sorry$ 0hat "as the 4uestion? 0as the --
    K$ /id you think Mr$ Jackson had a good rehearsal on the 69rd?
    +$ *t "as much improved, sir$
    K$ 0hat about on the 6Dth? He rehearsed that day, as "ell, did he not?
    +$ -orrect$
    K$ +nd ho" did he rehearse on that day, ma#am?
    +$ *t "as improved$
    K$ He stayed until about 26:93 that night, so into the morning of the 67th?
    +$ * kno" "e "ere all trying to get out of there probably around midnight or so, so * "ould say that "as probably
    accurate$
    K$ /id you feel like those -- you "ere "orried on the 2=th, you said you "ere "orried all of that "eek$ /id you feel that
    ho" he performed at those rehearsals restored your hope in terms of ho" things "ere going to go?
    +$ * "ould say yes$
    K$ +nd did you think that as a result of those t"o rehearsals, that you thought that he could be ready in time for >ondon?
    +$ (h, no$
    K$ ,ou didn#t?
    +$ (h, no$
    K$ &o that didn#t -- you didn#t think that he could be ready no"?
    +$ o$ 5hat "as like in t"o "eeks$ Michael -- he didn#t gain like any "eight, you kno", in those fe" days$ He "as still
    e'tremely thin$ * didn#t think physically he could actually do a sho" unless they made some ma!or alterations to the -- ho"
    strenuous it "as or if they could delay it, you kno", even longer$
    K$ &o you didn#t think he could be ready after seeing those t"o rehearsals?
    +$ o$
    #r$ %utnam" Can I !et the e+osition- +)ease6
    #s$ Ste00ins" 4hi,h one6
    #r$ %utnam" Goo <uestion$ 1=3=2013$ An I9m s+e,i(i,a))y )oo;in! at )ines 11 to 22$
    #r$ %anish" 4hat +a!e6

    #s$ Ste00ins" 1>8$


    #r$ %anish" 4hat i you say the ate o( that one *as6
    #r$ %utnam" 1=13- I thin; it *as$ No$ Sorry$ 1=3$ #ay I a++roa,h- your honor6
    #r$ %anish" Just !i3e me a se,on to (in that$ January 11
    #r$ %utnam" #ay I a++roa,h- your honor6
    K$ Ms$ %aye --
    +$ ,es?
    K$ -- *#m going to ask you to look at the 4uestions and ans"ers -- it goes do"n to --
    +$ 5hat "as -- this "as at the %orum$ 5his took place$ (kay$ &o you#re saying --
    Ju!e" ?o) on$ Let9s see *hat *e9re oin! (irst$
    #r$ %anish" Can I .ust see it6 @e,ause I on)y ha3e 11
    #s$ Ste00ins" ?ere9s a ,o+y$
    #s$ Chan!" 7han; you$
    #r$ %anish" 7han; you$ I9m sorry$ 1>8- )ine 11- you sai6 Is that ri!ht6
    #s$ Ste00ins" I thin; so$
    7he *itness" Oh- here *e !o$
    Ju!e" So o you *ant her to rea it to herse)( ri!ht no*6
    #r$ %utnam" 8es- to herse)($ I *ant to see i( it re(reshes her re,o))e,tion as to *hether or not at that +oint in time
    she ha ho+e that he ,ou) 0e reay in time (or Lonon$
    7he *itness" 8eah- I ha ho+e that he ,ou) 0e reayA 0ut there *ou) ha3e to 0e a )ot o( a)terations to 11 to *hat
    he ha to o- sir$ @e,ause it *as a 3ery strenuous sho*$
    K$ &o you thought he could be ready, but only "ith alterations?
    +$ 5here "as hope$ *t "as !ust hope$ * mean, * think it "as !ust that * had hope$
    K$ +nd "ere you relieved?
    +$ ,ou kno", * "as some"hat relieved, sir$ * had to say like * -- because * sa" more of Michael, he "as laughing and he
    "as actually participating in a rehearsal, so there "as -- there "as relief that came "ith that$
    K$ ,ou thought he "as on a better track?
    +$ ,es, sir$
    K$ /id you think some of those symptoms you "ere "orried about on the 2=th "ere gone?

    + he "as still cold8 but his spirit "as better, sir$


    K$ +nd is this the point in time in "hich -- you said a point in time came "here you talked to Mr$ /ileo$ 0as this the
    point in time "here you talked to Mr$ /ileo? +nd don#t tell me "hat you said$ *#m !ust asking is this the point in time
    "hen you talked to him?
    +$ ,es$
    K$ +nd is this the point in time -- did you tell Mr$ /ileo that you "ere glad to see that Mr$ Jackson "as doing better?
    +$ * asked him "hy he "as$
    K$ (kay$ /on#t tell me -- the -- and at this point in time, he "as participating in rehearsals, right?
    +$ ,es$
    K$ +nd * "ant to ask you about that$ He -- had he gone through from the beginning of the sho" all the "ay through "hat
    "as called the Moto"n medley?
    +$ 0ithout any stops or anything?
    K$ o$ /id he go through the songs from the beginning until the Moto"n medley?
    +$ 0e did -- * can#t recall, sir$ * can#t really recall "hat "e "ent through because * don#t even remember the --
    K$ Play list?
    +$ * don#t remember the play list$ * mean, *#d have -- * don#t think * could have -- you kno", even if * sa" the play list -- *
    !ust have -- * don#t kno"$ * don#t have enough information and can#t recall "hat actually he did$ * "as -- * remember they --
    they spent a lot of time "ith the spider that "as for 5hriller$
    K$ 5he spider, you said?
    +$ ,eah, there "as this spider thing that -- that Michael "as supposed to come out of, and "e "ere under the stage, and
    he "as supposed to cra"l up into this spider and then come out of the spider, so it "as a real like mechanical thing that
    they "ere "orking on that they "ere trying to see ho" that "as going to "ork$
    K$ +nd do you kno" "hether or not he "ent through song after song after song?
    +$ o, * don#t recall that$
    K$ ,ou don#t recall? &o if -- you mentioned +lif &ankey earlier$ 0ho is +lif &ankey?
    +$ &he "as )enny (rtega#s assistant$
    K$ +nd she "as the person that you said "ould sometimes get in touch "ith you to let you kno" "hen to be --
    +$ -orrect$
    K$ -- at a place? 0as she a friend of yours, as "ell?
    +$ * -- "hat -- ho" do you define Bfriend,B sir?
    K$ /id you like her?
    +$ * liked her$ 0e didn#t hang out together, and like -- * kne" her from "ay back and some other productions, and so --

    yes, * liked her$


    K$ +nd had you "orked "ith her before?
    +$ * think * recall on another tour$
    K$ +nd did you trust her?
    +$ &ure$
    K$ o", if she#s testified here that he performed song after song after song, do you have any reason to believe that her
    memory is faulty in some "ay?
    +$ o$
    K$ ,ou !ust can#t recall "hether he did many songs?
    +$ -orrect, * can#t recall like the -- the set list and ho" many songs he "ent through$ * don#t recall if -- like he could have
    gone through maybe half -- half of the -- but like "hether he "ent "ithout stopping, * can#t recall, because, you kno", like
    rehearsals, you go through some, and then "hen you -- you hit a point "here you have to like revisit it and make
    corrections, you stop, things like that$ &o like going through nonstop, * can#t say that * recall that that happened$
    K$ +nd -- but you thought he might have done about half of them that night? 0hat about the ne't night, the 6Dth?
    +$ 5he same thing$ * have really -- you kno", "e "ent through things and, you kno", it "as -- it "as a night like the night
    before$ *t "as -- he "as actually rehearsing, and he "as onstage, sir$
    K$ o", can you recall if Mr$ Phillips "as there that night?
    #r$ %anish" 4hi,h 11 are you ta);in! a0out the 11
    #r$ %utnam" 7hat9s a !oo o0.e,tion$
    #r$ %anish" I9m not o0.e,tin!$ I .ust *ant to ;no* *hat ate$
    K$ /o you recall if Mr$ Phillips "ere there on the night of the 69rd?
    +$ * recall him being there one night8 but * can#t recall "hat time, "hich night$ * recall seeing him at the &taples -enter,
    and "e "ere only at the &taples -enter for t"o nights, so --
    K$ * missed that last past$
    +$ 0e "ere only at the &taples -enter for t"o, you kno", "ork days, so -- i remember seeing him there, so -- but * can#t
    recall "hich day -- oh, you kno", it "as probably -- "ait a minute$ 5he last day$
    K$ ,ou sa" him on the 6Dth$ 0hat do you remember seeing?
    +$ 1ecause he "as in Michael#s room at the end of the night$
    K$ &o you recall that from the last night "hen you "ere there until about 26:93, 26:33, 26:93?
    +$ * think so, sir$
    K$ (kay$ +nd do you have any idea one "ay or the other "hether or not he "as there the night before, as "ell, on the
    69rd?

    +$ * can#t recall$
    K$ Just don#t kno"?
    +$ * can#t recall, sir$
    K$ o", but -- and if * understand correctly, though, on neither of those nights did you mention to -- strike that$ ,ou
    indicated that Mr$ Jackson#s -- there "as a levity and spirit, there "as more of a lightness to him than there had been$
    +$ ,es, sir$
    K$ +nd he "as laughing again?
    +$ ,es, sir$
    K$ /o you remember making fun of the headphones that you talked about before?
    +$ ,es, sir$
    K$ +nd he "as referring to you by your nickname again?
    +$ ,es, sir$
    K$ &o all these "ere things that gave you hope?
    +$ ,es, sir$ He still kept repeating, though, "hich * found really odd, BI have no control. Why don't I have any control?B
    he said that a fe" times$ 5here "as still like this little -- a little anger there, you kno"$ 1ut yes, "e did laugh, and -- they
    gave me headphones because they "ere making him "ear those earphones, and he didn#t like them, and -- but that "as the
    only "ay they could hear each other$ &o they gave me one of those little things so * could talk to him$ +nd "e "ere
    making fun of that, you kno", because it "as !ust funny, you kno", he had to hear me and * had to hear him$ +nd he#d go
    Boh, no, no" she kno"s$B it "as !ust like fun$
    K$ *#m !ust curious$ +s the hair and makeup person, "hy "ould he need to hear you onstage and "hy "ould you need to
    hear him?
    +$ /irections$
    K$ %or hair and makeup stuff?
    +$ 0ell, * -- * also -- "e also helped him "ith e'its and entrances and -- yes$ * mean, because unlike other sho"s that "e
    did, the room -- the changing room is -- they put the stage -- the changing room under the stage, so * could not be able to
    vie" "hat he "as doing up onstage, like on top of the stage$ +nd sometimes * had to be belo" the stage, so "e needed to
    be able to communicate$ 1ut the other tours * "as al"ays "ith, the changing rooms "ere al"ays located on the stage off
    to the side so * could !ust go out and see "hat "as going on$
    K$ (kay$ o", you talked about Mr$ Jackson#s "eight8 and last time you testified you talked a lot about that$ &o his
    "eight in this time period "as something you "ere 4uite concerned "ith, correct?
    +$ ,es, sir$
    K$ +nd "hen you first sa" him in +pril of 633=, after not having seen him for four years, "ere you concerned about his
    "eight the first time you sa" him?
    +$ * "asn#t concerned about his "eight for his everyday life$ ,ou kno", like for everyday, it "as fine$ 1ut * "as
    concerned for his performance "eight$

    K$ +nd "hen you say Bperformance "eight,B did Mr$ Jackson have an ideal performance "eight, something he called his
    stage "eight?
    +$ * don#t kno" e'actly "hat that "as, but * think he liked to be at a certain -- a certain "eight for performance and the
    "ay the clothes looked and things, so --
    K$ &omething you might call his average "orking "eight?
    +$ ,ou kno", the -- i#m not familiar "ith a number, *#m not familiar "ith a conversation that * had "ith Michael regarding
    that$
    K$ /o you remember ever testifying that his average "orking "eight "as 263 pounds?
    +$ * said that in regards to >isa Marie Presley gave me that information, sir$
    K$ &o -- okay$ 1ut do you remember testifying --
    +$ +nd * think * said some"here -- because >isa Marie Presley and * became friends, and she told me that the "eight that
    he liked to be "as 263 pounds$ &orry$ *s that hearsay stuff?
    #r$ %anish" 8es$
    7he *itness" Sorry$
    Ju!e" 8es$
    #r$ %anish" 4hy 11
    #r$ %utnam" I9 )i;e to sho* you somethin!- i( I ,an- ma9am$ It9s !oin! to 0e your e+osition on A+ri) 2Bth- 2012$
    An I9m !oin! to sho* you )ines C throu!h 1D$
    #r$ %anish" %a!e *hat- no*6 C00 an *hat6
    #r$ %utnam" 2CB- )ine C$
    7he *itness" C006 4e ha3e a )on! e+osition$
    #r$ %utnam" 2CB$
    7he *itness" 4o*$ O;ay$ A)) ri!ht$
    #r$ %utnam" #ay I a++roa,h- your honor6
    Ju!e" 8es$
    7he *itness" 8ou in9t as; me$
    #r$ %utnam" #ay I a++roa,h- #s$ Faye6
    7he *itness" 8es- you #ay- sir$
    #r$ %utnam" 8ou9)) see here- I9m )oo;in! at those )ines C throu!h 11$
    K$ /o you see there --
    +$ D through --

    #r$ %anish" 2CB- *hi,h )ines 11


    Ju!e" Eea it to yourse)($
    7he *itness" O;ay$ Sorry$
    #r$ %utnam" C to 11$
    K$ /o you see that, ma#am?
    #r$ %anish" 4ait a minute$ ?o) on$ I9m on +a!e 2CB$ Is this the ri!ht 11
    #r$ %utnam" 7hat must 0e a i((erent ate$
    #s$ Ste00ins" ?ere$
    K$ /o you see that, Ms$ %aye?
    +$ * do$
    #r$ %anish" Can I .ust )oo; at it one se,on$ A)) the *ay to 216
    #r$ %utnam" I9m not sho*in! it- I9m as;in! her i( it re(reshes her re,o))e,tion$
    K$ /oes this refresh your recollection as to "hether you testified that Mr$ Jackson#s "orking "eight is 263, that that#s --
    +$ ,es, and * got that information the same "ay * told you$
    K$ (kay$ +nd do you remember testifying that#s "hat he aspired to be?
    +$ ,es$
    K$ +nd that "as his perfect "eight?
    +$ &omebody told me that$
    K$ (kay$ *#m asking if you testified --
    +$ * don#t kno" ho" to address that$
    #r$ %anish" I9m !oin! to mo3e to stri;e$ It9s a)) 0ase on hearsay- *hat she9s testi(yin! to$
    Ju!e" O;ay$ Sustaine$
    #r$ %utnam" O;ay$
    Ju!e" 7he ans*er is stri,;en$
    K$ 5his concern you had about Mr$ Jackson#s "eight --
    +$ ,es?
    K$ -- did it become truly a greater concern for you in the last "eek of his life?
    +$ ,es$

    K$ +nd in that period of time, did you think Mr$ Jackson, !ust in that "eek, had lost 23 to 27 pounds?
    +$ *t "as a lot, and that "as my estimate$
    K$ &o your estimate in the last "eek of his life "as that he had lost 23 to 27 pounds?
    +$ 5hat "as my estimate$
    K$ +nd had you observed that Mr$ Jackson "as getting thinner and thinner?
    + yes, sir$
    K$ /id you ever discuss that "ith Mr$ Jackson?
    +$ o, sir$
    K$ /id you ever tell him during that last "eek that he "as really dramatically losing "eight?
    +$ /id * tell him he "as dramatically losing "eight? o$
    K$ /id you tell him in that last "eek he "as losing "eight at all?
    +$ &ir, Michael "asn#t very coherent in that last "eek to have a discussion like that$
    #r$ %utnam" I mo3e to stri;e- your honor$
    Ju!e" #otion !rante$
    K$ /id you ever discuss that "ith him, ma#am?
    +$ o, sir$
    K$ /id you ever tell him about your concern for his "eight?
    +$ ,es$
    K$ ,ou did? 0hen "as that, ma#am?
    +$ *n -- in the beginning "hen -- in -- like March, +pril$
    K$ +nd in this last "eek, did you discuss it "ith him at all?
    +$ o, sir$
    K$ +nd did you not do that because you thought it "ould make the situation "orse?
    +$ o, sir$
    K$ /o you remember testifying that you believed that you didn#t tell Mr$ Jackson that last "eek because you thought it
    "ould make the situation "orse?
    +$ 5hat it "ould make -- you kno", * tried to e'plain that a minute ago, but like you "on#t let me say that, so --
    K$ &ay "hat?

    +$ ,ou !ust struck "hat * said, you kno"$ &o like "hat you#re asking me, you kno", is because of Michael#s condition, *
    didn#t approach him "ith things like that because it could possibly make things "orse$
    K$ (kay$ +ll right$
    +$ /id * say that in a "ay that "on#t be stricken?
    Ju!e" 4e))- i( he9s as;in! you (or the e2+)anation- you9re (ree to !i3e the e2+)anation$
    7he *itness" O;ay$ I !et ,on(use 11 I9m sorry 11 *hat9s a))o*e- *hat9s not- *hat9s stri,;en- hearsay$ I9m a
    ma;eu+ artist$ I ,an te)) you a0out eye)ashes an *ho nees a ()attenin! iron$
    K$ &o you didn#t tell him in that last "eek that you "ere concerned about his "eight, correct?
    +$ * can#t recall saying anything to Michael about his "eight in the last "eek$
    K$ +nd that "as because you thought it "ould make the situation "orse because he didn#t seem coherent to you?
    +$ -orrect$
    K$ +nd did you -- isn#t it true that you thought that "hile you could notice this "eight loss, you "eren#t convinced that
    other people "ould be able to notice it?
    +$ * thought others "ho didn#t kno" him "ell or only sa" him "ith layers and layers of clothing could not recogniFe it,
    sir$
    K$ *n fact, you thought even the dancers that "ere performing "ith him didn#t necessarily notice, correct?
    +$ *t "as possible that they didn#t, yes$
    K$ +nd it "as possible that the people "atching him from in the &taples -enter couldn#t have realiFed this "eight loss, as
    "ell, correct?
    +$ 5hat#s probably possible, sir$
    K$ +nd you say that#s because of the layers and layers$ 0hat do you mean by that?
    +$ Michael "as "earing layers and layers of baggy clothes, sir, during rehearsals$
    K$ &o you thought that "ould make it hard for anyone to realiFe ho" much "eight he "as losing?
    +$ 5hose "ho didn#t kno" him, yes$
    K$ +nd there#s previously been testimony and evidence presented that Mr$ Jackson "eighed 29@ pounds at the time of his
    passing, from the coroner#s report$ ,ou#re a"are of that, correct?
    +$ ,es$
    K$ +nd you find that impossible to believe, right?
    +$ ,es$
    K$ +nd "hy is that, ma#am?
    +$ 1ecause Michael had lost so much "eight, and he "as thin to begin "ith, and he kept losing "eight, and * don#t kno"
    if *#d ever -- you kno", 29@ pounds is a lot for Michael$

    K$ 5hat#s "hat * "as going to ask you, ma#am$ <egardless of "hether 263 "as his perfect "orking "eight, you think 29@
    "ould be a lot for Mr$ Jackson, no?
    +$ ,es$
    K$ +nd then that#s "hat the coroner#s report reads, correct?
    #r$ %anish" O0.e,tion- your honor$ First o( a))- it9s ,a))in! (or hearsay$ She oesn9t ;no* 11 she hasn9t rea the
    ,oroner9s re+ort$
    #r$ %utnam" 8es- she has$ She9s testi(ie to it$
    #r$ %anish" E2,use me$ An ,ounse) is testi(yin!$
    Ju!e" O;ay$ I9m !oin! to stri;e the <uestion an the ans*er$ Start o3er$
    #r$ %utnam" O;ay$ 7han; you$
    K$ /id you have a -- "ere you asked about the coroner#s report in your deposition?
    +$ ,es$
    K$ 0ere you sho"n the coroner#s report in your deposition?
    +$ Pardon?
    K$ 0ere you sho"n the coroner#s report in your deposition?
    +$ * don#t kno" if * sa" it or not$ * kno" it "as -- did * see the coroner#s report?
    K$ * can sho" it to you again if you like$
    +$ +ll right$
    Ju!e" ?e ,an sho* it to her no*$
    #r$ %utnam" It9s e2hi0it 133F2$ #ay I a++roa,h- your honor6
    Ju!e" 8ou #ay$
    #r$ %utnam" #s$ Faye 11
    7he *itness" Is that *hat9s u+ here- too6
    #r$ %utnam" 8es$ Ei!ht here- ma9am$
    Ju!e" One o( them is mine$
    7he *itness" 7hat9s ri!ht$ I9m sorry$ I9m stin!y$
    #r$ %utnam" An I9)) ire,t your attention to +a!e 1D- I thin; it is$ An i( you )oo; at the 0ottom ri!ht$
    7he *itness" 4ait- *ait$ %a!e *hat6
    #r$ %utnam" 1D$ I( you )oo; at the 0ottom ri!ht- there9s a )on! num0er- an it ens at 1D$

    7he *itness" O;ay$ A)) ri!ht$ O;ay$ @e,ause there9s a ,ou+)e o( )on! num0ers on the 0ottom$
    #r$ %utnam" Ei!ht$
    K$ /o you remember being sho"n this at your deposition, ma#am?
    +$ ,ou kno", * have to say * don#t recall, but doesn#t mean it "asn#t$ * don#t recall$
    K$ * understand$ *t#s a 4uestion about "hether you recall or not$ ,ou prepared Mr$ Jackson#s body, did you not, for his
    internment?
    +$ ,es$
    K$ +nd you did that at the coroner#s office, correct?
    +$ 0hat?
    K$ ,ou did that -- did you go from the coroner#s office "ith the body from the mortuary, or did you pick it up at the
    mortuary?
    +$ *t "as at the mortuary, sir$
    K$ +nd did you ever discuss Mr$ Jackson#s "eight at that time "ith anyone?
    +$ * asked the mortician that * "as "orking "ith ho" much did he think he "eighed$
    K$ +nd he told you, correct?
    +$ He gave me an ans"er, sir$
    K$ *#m going to ask you a 4uestion$ ,ou#ve talked a lot about -- and this is a lot from "hat happened last time$ *#m trying
    not to go back and revisit it, if possible -- but about your concerns in this last "eek, particularly your concerns on the
    2=th, your concerns for Mr$ Jackson#s "ell being, and your concerns about his "eight$ /o you remember that?
    +$ ,es$
    K$ +nd do you remember getting very upset on the stand, particularly about the idea that you thought no one "ould listen
    to you in this time period?
    #r$ %anish" I9m !oin! to o0.e,t to his ,hara,teriGation o( her emeanor on the *itness stan$
    #r$ %utnam" I *as tryin! to 0e e)i,ate$
    Ju!e" O3erru)e$
    K$ /o you remember crying on the stand, ma#am?
    +$ * remember being upset by certain things -- the line of 4uestioning, sir$
    K$ +nd do you remember part of that "as being upset because you felt like no one "ould listen to you in this time period?
    + "hen he "as dead?
    K$ o, ma#am$ * mean in the "eek prior to his passing$

    +$ * -- * "as kind of thinking people "eren#t listening to me, sir, because nobody "as -- * "as voicing my opinions, and
    "hat * thought, and * didn#t feel * "as being -- * "asn#t getting too much response, sir$
    K$ * "ant to talk about it a little bit$ 1ut those "ere concerns that you never e'pressed in that time period to Mr$ Jackson?
    +$ * mean, "e had conversations "ith me "anting for him to eat, things like that, but -- but * -- *#m !ust trying to go back
    to the time because it#s really difficult$ 5hat "as a long time ago$ 5here "ere issues about him eating, and * don#t kno" if
    they "ere all "ith )enny or * had them "ith Michael also included in those conversations$ * can#t recall$
    K$ /o you remember ever testifying, ma#am, as to "hether you had told Michael Jackson anything "as "rong and
    "hether he needed to leave, your saying, B*#m not going to alert him to horrible things, he#s putting up this frontB?
    +$ -an you -- can you like give me more information about that? 1ecause * don#t recall$
    K$ &ure$ *n your deposition, "hen you "ere asked "hy didn#t you talk to Mr$ Jackson --
    +$ (kay$ o" *#m kind of getting "hat you mean here$ &o can you elaborate on that so *#m sure "e#re on the same page?
    K$ &ure$ My 4uestion "as, BDid you ever talk to Mr. Jackson in this last week about this? Did you ever say, 'Michael, is
    soething wrong? Do you need to leave?'B +nd do you recall saying, B!o. I ean, the thing is I' not going to alert
    hi to horrible things. "e's putting up this #ront, it's obvious that he's putting up a #ront because --B * can keep going if
    it helps$ *#m trying to do it "ithout having to go through the "hole thing "ith you$
    +$ (kay$ 0hen he "ent out on the stage, * kno" -- like he "as a professional, and * kno" -- yes$
    K$ 0hat#s the Byes,B ma#am?
    +$ 5he ByesB is like he "ould pretend everything "as okay$
    K$ /id you ask him if he "as okay in this "eek, ma#am?
    +$ /id * ask him if he "as okay? * have to say he "asn#t in a state of mind for me to ask him that 4uestion
    K$ &o you didn#t ask him?
    +$ * "ould -- * "ould say that#s probably accurate$
    K$ +nd "henever he "as at rehearsal in that last "eek, you "ere "ith him, correct?
    +$ -orrect$
    K$ /id you ever e'press your concern that -- in that last "eek to any member of his family?
    +$ ot directly$
    K$ /id you ever e'press it to his mother?
    +$ o, sir$
    K$ His brothers in that time?
    +$ o, sir$
    K$ ,ou had "orked "ith his brother <andy Jackson before, right?

    +$ ,ears before that, yes, sir$


    K$ /id you -- "ell, 5anya Hilkie, "ere you still "orking "ith her at this point?
    +$ ,es, sir$
    K$ 0as she still in a relationship "ith Mr$ Jackson?
    +$ * think so, sir$
    K$ +t this period of time, "ere you "orried at all that drugs had something to do "ith "hy Mr$ Jackson "as in the
    condition he "as that last "eek?
    +$ * "as concerned it May be a possibility$
    K$ +nd did you think it "as one of several possibilities or "as the sole possibility?
    +$ * didn#t kno"$
    K$ 5hat#s "hat *#m asking$
    +$ * didn#t kno" "hat it "as, and * have to come from that particular point$ * "as trying to find out -- * thought it "as a
    possibility, but * did not kno"$
    K$ +nd -- so -- * !ust "ant to understand$ &o at that point in time, going back to that time, you !ust didn#t --
    +$ 0hich time?
    K$ 5hat final "eek up until his passing, as opposed to today$
    +$ -orrect$
    K$ ,ou didn#t kno" "hat "as "rong "ith him, right?
    +$ * did not$
    K$ ,ou "ere concerned?
    +$ -orrect$
    K$ 1ut you didn#t kno" "hat the basis -- "ell, you kne" "hy you "ere concerned, but you didn#t kno" "hy Mr$ Jackson
    "as cold or having difficulty or --
    +$ (r so thin, correct$
    K$ +nd you didn#t ask him "hy it "as, correct?
    +$ -orrect$
    K$ +nd you never asked any of his doctors "hy it "as?
    +$ * didn#t have really contact "ith the doctors he "as seeing, sir$
    #r$ %utnam" An I on9t ;no* ho* *e9re oin! 0rea; toay- !i3en the i((erent time- your honor$ I ha3e a ne*
    se,tion- *e ,an ;ee+ !oin!$ I on9t ;no* *hat you *ant to o$

    Ju!e" I *ant to ;ee+ !oin!$


    #r$ %utnam" O;ay$ 7hat *i)) 0e !oo$
    K$ ,ou and Mr$ Jackson "ere very close in your 6C years together, correct?
    +$ * "ould say so$
    K$ /id you feel like you shared a lot of things?
    +$ * "ould say "e kne" each other "ell, "hat "e shared "as probably not "hat -- probably the grandeur that you#re
    thinking of$ ,ou#d have to be more specific$ *#m sorry$
    K$ >ast time you "ere here you testified that Michael -- testified that Michael al"ays thought that "hatever doctors gave
    him, that "ould be okay$ /o you remember that testimony?
    +$ ,es, sir$
    K$ 0hat "as that based on?
    +$ 5hat "ent "ay, "ay back, sir, you kno"$ 5hat "as !ust like in a conversation that he al"ays relied that doctors "ould
    be giving him, you kno" -- "ould give him "hat "as good for him, sir$
    K$ &o that#s from conversations you actually had "ith Mr$ Jackson?
    +$ ,es, sir$ 1ut like that -- it "as like, you kno", close -- *#m saying this is our relationship$ *t "as probably around this --
    about this time$ 5his is the beginning, this is the end$ *t "as probably around in here some"here "hen "e had that
    conversation$
    K$ &o as you sit here today, you can remember having that type of conversation "ith Mr$ Jackson in the #?3#s?
    +$ * !ust remember his attitude to"ards doctors, you kno", a long time ago, you kno"$ He read medical !ournals, he
    "ould bring them to photo shoots, so he "ould study, you kno" -- he#d bring medical !ournals, anatomy books$ * mean, he
    "as -- he read everything$ He "as 4uite a reader, and he studied many things$ +nd, you kno", * !ust remembered that, you
    kno", some"here in the beginning -- in our conversations, like he believed that doctors, "hatever they gave him or
    prescribed to him "as okay$
    K$ +nd you sa" him actually studying up on medical issues through books and magaFines and the like?
    + but of everything, sir$ +nd that "as !ust one aspect$ He "as fascinated "ith anatomy and looking at operations$ ,ou
    kno" those kind of like gory things sometimes "here -- the operation books "here you see like guts and everything? 1ut,
    * mean, his -- he "ould like have like massive variety of books, music, things that he "ould bring that he liked to read$
    K$ +nd in any of those times that you had those conversations, did you ever discuss propofol "ith Mr$ Jackson?
    +$ ever, sir$
    K$ Had you ever heard of propofol --
    +$ o, sir$
    K$ -- before Mr$ Jackson passed?
    +$ o, sir$
    K$ 0ere you ever a"are that Mr$ Jackson had been "arned repeatedly by doctors that he could die if he took propofol at

    home?
    #r$ %anish" Assumin! (a,ts not in e3ien,e$
    Ju!e" Sustaine$
    7he *itness" I mean- )i;e *hen6
    #r$ %anish" :on9t ans*er$
    Ju!e" Sustaine$ It9s a sustaine o0.e,tion$
    K$ /id you ever speak to Mr$ Jackson about any kind of drug at all?
    +$ * remember him asking me if my daughter smoked pot, and that * should never let her do that$ * mean, it "as more like
    telling me !ust stuff like that$ * mean, like having -- he asked me that one time if * had any --
    K$ Painkillers?
    +$ -- painkillers$ * remember that time$ 1ut it "asn#t something that "e talked about very much, or at any length$
    K$ +nd in the year 633=, in the time you "ere doing that, did you discuss any drugs at all "ith him during that time
    period?
    +$ 633=, the entire year?
    K$ ,es$
    +$ o$
    K$ +nd the first time you heard of propofol "as "hen Mr$ Jackson passed?
    +$ ,es, sir$
    K$ +nd "ere you surprised to hear that he had passed from an overdose of propofol?
    +$ ,es$
    K$ +nd "hy "ere you surprised, ma#am?
    +$ 1ecause * had never even heard of it before$
    K$ +nd you said that you didn#t kno" "hat "as "rong "ith him at the time?
    +$ -orrect$
    K$ ;p until his passing, correct?
    +$ -orrect$
    K$ +nd then "hen you learned that he had overdosed from propofol, "as
    -- "as that something that then made sense to you?
    +$ * didn#t even kno" "hat it "as, sir, so -- you kno", * -- did it make sense?
    #r$ %utnam" Hh1huh$

    #r$ %anish" It9s irre)e3ant *hat her state o( min 11


    7he *itness" I ,an9t 11 I in9t ;no* *hat it *as- you ;no*$
    #r$ %anish" 8ou93e !ot to sto+ (or a se,on$
    #r$ %utnam" 8our honor- (oreseea0i)ity is an e)ement o( this- an the +erson *ho is ,)osest to him 11
    #r$ %anish" Can I ma;e the o0.e,tion6
    Ju!e" O;ay$ #a;e the o0.e,tion$
    #r$ %anish" O;ay$ It9s irre)e3ant an (ounation as to this *itness9s state o( min on +ro+o(o)- *hat ha++ene$ I
    mean- *here are *e !oin!6
    Ju!e" 4hat *as your <uestion to her6
    #r$ %utnam" 7his is a +erson *ho *as 3ery ,on,erne a0out 11
    Ju!e" 4hat *as your <uestion6
    #r$ %utnam" Is it +ossi0)e to rea it 0a,;6
    Ju!e" 8es$
    'the <uestion *as rea/
    Ju!e" 5#ae sense to you56
    #r$ %anish" 4hat is 11 *hether it mae sense 11
    Ju!e" I thin; that9s 3a!ue$ 7he <uestion that you as;e +re3ious)y- 54ere you sur+rise-5 I )et that one !o$ @ut
    *hether 5It mae sense to you-5 Sustaine$
    #r$ %utnam" O;ay$
    &$ 8ou ha ,on,erns an you in9t unerstan *hat the +ro0)em *as *ith #r$ Ja,;son +rior to his +assin!-
    ,orre,t6
    #r$ %anish" It9s as;e an ans*ere three times$
    Ju!e" Sustaine$
    K$ 0ere your concerns about Mr$ Jackson addressed "hen you learned ho" Mr$ Jackson had died?
    +$ 0hen my --
    #r$ %anish" Va!ue an am0i!uous- no (ounation$
    Ju!e" Sustaine$
    #r$ %utnam" O;ay$ I9)) mo3e on to another thin!$
    K$ >ast time you "ere here, you said Michael Jackson never took no for an ans"er$ /o you remember saying that?

    +$ ,es$ /id * say that here?


    K$ ,es$
    +$ * kno" it#s -- it "as true in my case "ith "hat my availability in -- in -- my availability as a makeup artist$ He never
    took no for an ans"er from me$
    K$ &o you didn#t mean that broadly, you only meant that in terms of yourself specifically, in terms of --
    +$ 5hat#s all * can talk about, sir$
    K$ (h$ (kay$
    +$ * mean, that#s all * kno" is -- "hen * "ould say, B* can#t do that,B he "ould come back to me and say, B,es, you can$B
    K$ 0as it your understanding that Mr$ Jackson "anted to do these sho"s at the 36?
    +$ *s it my understanding that he "anted to do these sho"s at the 36$ * have to say the "ay he talked about it to me -- am *
    allo"ed to say that?
    K$ ,es$
    +$ -- he talked to me about it, it al"ays seemed like he "as convincing himself he "anted to do it$
    K$ 0hy do you say that?
    +$ *t "as !ust that he al"ays said like -- he told me "hy he "as -- B*#m doing this for my children, *#m doing it for this$B
    and like it "as al"ays kind of like he "as talking himself into it$ &o he "as saying that, but like it "as al"ays -- like do
    you kno" "hen somebody tries to, you kno" -- keeps saying things and they#re trying to convince themself that that#s the
    thing to do? 5hat is the impression * got, especially in the very beginning$
    K$ &o your impression "as you "eren#t sure "hether he actually sincerely "anted to do them?
    +$ -orrect$
    K$ +nd as it got closer to the end, "e#re talking about --
    +$ o, that "as "hen * first met him and "e started talking about it, sir$ 1ecause like * kne" Michael didn#t like to do
    long-term engagements and concerts$ He really didn#t like doing that$ 5hat "asn#t -- that "as something he really didn#t
    en!oy doing because it "as very difficult on him$ 1ecause he told me the only reason he really liked to do that is, B* get to
    go to different cities and go into orphanages and go into hospitals$B he made that very clear, even in an intervie" that *
    "as "orking "ith him on "here "e had to actually re-tape the 4uestion because he told the truth and they didn#t "ant to
    hear that$ &o --
    K$ *n -- to"ards the end, the last "eek of Mr$ Jackson#s life, at that point in time, did you have a sense that maybe Mr$
    Jackson "as self-sabotaging himself in terms of his ability to do the sho"s?
    +$ * didn#t understand "hat "as going on at that particular time, sir, in everything$ *t "as still a 4uestio
    n that * didn#t kno" "hat "as happening, sir$
    K$ &o is that a yes or no in terms of did you think at the time that he "as self-sabotaging?
    +$ * didn#t kno" "hat "as happening, sir8 and * thought if he "as doing any kind of -- anything -- any kind of drugs, that
    that could possibly, you kno", not be to the best of his ability to do the sho"s$
    K let#s talk about it very specifically$ >ast time plaintiffs had you and they "ere asking you a series of 4uestions$ +nd they

    asked you about t"o specific emails that you had received from fans of Mr$ Jackson, and that you for"arded to Mr$ %rank
    /ileo$ /o you recall being asked about those emails?
    +$ ,es, sir$
    K$ +nd these are ones that you had for"arded after your concerns on %riday, June 2=th?
    +$ &ay that one more time?
    K$ 5hese "ere before -- a result of your concerns on June 2=th?
    +$ * for"arded them$
    K$ %or"arded them to Mr$ %rank /ileo?
    +$ * "rote them to %rank /ileo$
    K$ +nd you attached some fan emails to for"ard them, correct?
    +$ -orrect$
    K$ +nd you said at the time that you understood that you "ere to give them to Mr$ /ileo because there "as some "hat
    you called chain of command, and that "as the "ay to get them to Mr$ <andy Phillips$ /o you remember saying that?
    +$ * remember e'plaining chain of command and above the line and belo" the line, sir8 and * "as instructed to go to
    %rank#s -- %rank /ileo told me * "as to go to him "ith all of my concerns, so that#s "hat * did$
    K$ &o you actually -- so the reason, then, if * understand, that you gave them to Mr$ /ileo "asn#t because you thought that
    that#s ho" you got it to Mr$ Phillips, it "as because you understood you "ere supposed to e'press your concern to Mr$
    /ileo?
    +$ (kay$ (ne more time, say that, no"? /id --
    K$ 0hen you testified last time --
    +$ .o ahead, ask me the 4uestion again$
    K$ *#m asking you here today "hen you provided them to Mr$ /ileo --
    +$ -orrect$
    K$ -- you "ere providing them to Mr$ /ileo because you understood that#s "ho you should e'press your concerns to and
    not because there "as a chain of command and that#s ho" you got it to Mr$ Phillips?
    #r$ %anish" Va!ue- o0.e,tion$ Va!ue- uninte))i!i0)e$
    7he *itness" It9s ;in o( har to 11
    Ju!e" :o you unerstan it6
    7he *itness" 4e))- I unerstanA 0ut )i;e the thin! is *hen 11 *hen I9m te))in! some0oy a0o3e the )ine my
    ,on,erns- I9m 11 my state o( min to that 11 my ,on,erns *ou) 11 that it *ou) !o to the +eo+)e *ho it *ou) 11
    ,ou) he)+ or to ta;e ,are o($ Li;e i( you *ere to 11 some0oy 11 you *ere su++ose to re+ort to some0oy o(
    somethin! in an or!aniGation- you (i!ure your ,on,erns that you9re !i3in! that +erson to *ou) 0e is+erse to the
    +eo+)e *ho it *ou) ,on,ern$ So that9s ;in o(- I thin;- my 11 not 5thin;$5 that *as my (rame o( minA that he is
    !oin! to ta;e that in(ormation an is+erse it to the +eo+)e- you ;no*- *ho ,ou) he)+$

    K$ /id you tell %rank because he told you to tell him?


    +$ He told me to bring my concerns to him$
    K okay$ +nd is that "hy you sent him these emails?
    +$ -orrect$
    K$ +nd as you mentioned before, he#s someone you had kno"n for a long time?
    +$ -orrect$
    K$ ,ou#re friends "ith him?
    +$ B%riendsB is like vague to me$
    K$ /id you feel close to him?
    +$ * felt he#s somebody * could talk to$
    K$ ,ou had nicknames for each other?
    +$ 0ell, everybody had the same --
    Ju!e" Let9s ta;e a 0rea;$ Let9s ta;e a ten1minute 0rea;$ 7en minutes$ O;ay6

    'the (o))o*in! +ro,eein!s *ere he) in o+en ,ourt- outsie the +resen,e o( the .urors/"
    Ju!e" 0e need to get done today$
    #r$ %utnam" 5hat#s "hy * skipped all these sections$
    #r$ %anish" Ho" much longer?
    #r$ %utnam" 63 minutes$
    #s$ Chan!" 5here is one thing, your honor$ >ast time "e talked about having )enny (rtega come in, having him deny
    certain things, and then bringing her back -- *#m sorry$ Having )enny (rtega come in, deny certain things, and bringing
    her back for the prior inconsistent statement that "e talked about before$
    Ju!e" * vaguely remember that$
    #s$ Chan!" *#m !ust alerting you$
    Ju!e" ,ou#re alerting me that she May be back for that purpose?
    #s$ Ste00ins" ,our honor, obviously, if she needs to come back, "e#ll have discussions at the time and evaluate "hether
    it#s acceptable or not$
    #r$ %anish" %irst of all, *#m sure as soon as * get up, they#ll be doing sidebars$ 1ut "e#ll see$
    #r$ %utnam" if you#d like to ask us about things in advance --
    Ju!e" -an you estimate ho" much more time you have?

    #r$ %utnam" *#m going through t"o emails$ 63 minutes$ 5he key dates, your honor, the 63th and the 66nd, they "ent like
    an hour, certain portions$ * "ant to do the other portion$
    #r$ %anish" ,our honor, *#ve looked at the total pages that * asked$ He#s already e'ceeded the number of page numbers
    on his 4uestions$ o", *#m not complaining, he can do it as long as he "ants8 but * think "hat they#re going to try to do is
    run me out to the end of the day so -- "hatever he "ants to do$ 1ut *#m not complaining, he can go as long as he "ants$
    *#m !ust letting the court kno" that, that at D:63, *#m going to get up there on a %riday and, you kno", it#s really -- and *
    hate to have her come back$ +nd *#ve been limited$ 1ut "hatever$
    Ju!e" 5he problem is there#s been some repetition$
    #r$ %anish" ,eah, a lot$
    #r$ %utnam" 5hat#s "hy *#m going to this portion, your honor$
    #r$ %anish" He asks the same 4uestions over and over$
    #r$ %utnam" ,our honor, if "e could have this discussion -- *#m not sure the "itness should be here for all of this$
    Ju!e" ,ou can step do"n$
    7he *itness" (h, you "ant me to go a"ay?
    Ju!e" *#m !ust concerned about the repetition$
    #r$ %utnam" *#m going to go only through these t"o emails "hich "e#ve not asked about$
    #r$ %anish" 1ut he#s asked the same --
    Ju!e" 27 minutes is the most$
    '@rea;/
    'the (o))o*in! +ro,eein!s *ere he) in o+en ,ourt- in the +resen,e o( the .urors/"
    Ju!e" Katherine Ja,;son 3ersus AEG Li3e$ Continue- +)ease$
    #r$ %utnam" @e(ore the 0rea;- ma9am- *e *ere ta);in! a0out t*o emai)s$
    7he *itness" Oh- hi$
    #r$ %utnam" ?i$ Sorry$ I *as .ust tryin! to rush so *e ,ou) !et one$
    7he *itness" I *as .ust tryin! to sit o*n an 11 o;ay$
    K$ .ood?
    +$ +s "ell as can be e'pected$ *#ve got a headache, and it#s hot$
    K$ ,eah$ &o you "ere asked about t"o emails last time, and * "ant to talk a little bit about those emails$
    +$ (kay$

    K$ +s indicated before the break, these "ere emails that you had sent on to %rank /ileo$ +nd if * May approach, your
    honor, *#m approaching "ith e'hibit 26?73$ *s that okay?
    Ju!e" 8es$
    K$ 0hile you#re looking at that, the -- do you remember being asked about this email "hen you "ere here being
    4uestioned by Mr$ Panish?
    +$ )ind of$ * remember like reading some of it, or -- like, yeah, it "as -- * think * -- the past --
    K$ Just remind everyone, "ho is 5ookie in this?
    +$ 5ookie, that is %rank /ileo#s nickname$
    K$ &o this is an email that you had sent to %rank /ileo8 and that "as on &aturday, June 63th, in the morning?
    +$ -orrect$
    K$ +nd that "as the day that originally you "ere going to go over and redo Mr$ Jackson#s hair, but they cancelled, correct?
    +$ * believe so$
    K$ +nd *#m going to summariFe the email belo" it in one short "ord, "hich "as a fan "as "riting to e'press concern
    about Mr$ Jackson#s "eight, correct?
    +$ ,es, correct$
    K$ +nd * !ust "ant to ask you very 4uickly, "hy "ere you getting this email, if you kno"? /id you get emails from fans
    "ith any kind of regularity?
    +$ * "as on facebook8 and they "ere sending them to me, sir$
    K$ &o "as it common for you to receive emails from fans in this time period?
    +$ -orrect$
    K$ +nd this one here, this fan, marika, is in %rance?
    +$ * don#t kno"$
    K$ (kay$ *#ll represent to you --
    +$ 5he fr indicates --
    #r$ %anish" 0ell, counsel is testifying as to "here this person is no"?
    #r$ %utnam" *#ll represent to her that Hotmail$fr is a Hotmail account in %rance$
    Ju!e" He can ask her does she have an understanding$
    K$ /id you kno" "ho Marika "as?
    +$ o, sir$
    K$ *s she someone "ho you had communicated "ith before?

    +$ * had seen her$ 5here "ere fans that * "ould kno" "hat they look like but not necessarily associate their name "ith
    their face, and they "ere people around Michael$
    K$ 0as she one of them?
    +$ * think so$
    K$ (kay$ /o you kno" if you#ve ever met her personally?
    +$ * can#t recall$
    K$ -an you recall "hether you ever corresponded "ith her other than this email?
    + * can#t recall$
    K$ +ll right$ +nd go up$ +nd it says that -- B$ub%ect, Met MJ last week and worried.B <ight above it, it says BMarika sent
    you a essage.B and then there#s an email that * believe is your email to Mr$ /ileo$ *t says B&rank, un#ortunately she is
    right. I a #ear#ul he will ake hisel# so sick he will die. I# he doesn't do this show, he has nowhere else to go$B /id
    you "rite that, ma#am?
    +$ ,es$
    K$ * "ant to ask you, "hen you say Bunfortunately, they#re right,B this is "here she#s talking about he#s "ay too thin?
    +$ -orrect$
    K$ +nd it goes on to say B*#m fearful he#ll make himself so sick he#ll dieB?
    +$ -orrect$
    K$ 0hat "ere you referring to there, ma#am?
    +$ He "as so thin, sir, * didn#t kno" "hat he "as doing, or ho" he "as -- you kno", * -- * "as afraid -- he "as obviously
    not eating enough, sir8 and * "as !ust afraid he "as going to get so sick he could die$
    K$ (kay$ +nd then you go on to say Bif he doesn#t do the sho", he has no"here else to goB? + correct$ K "hat did you
    mean by that?
    +$ 5hat "as regarding a -- things that )enny (rtega told me on the 2?th$
    K$ +nd * don#t "ant to kno" those$ +ll right? &o that#s -- so you#re referring to something else, this is -- you#re e'pressing
    it to Mr$ /ileo, correct?
    +$ -orrect$
    K$ +ll right$ ,ou sent this off to him on the 63th, correct?
    +$ -orrect$
    #r$ %utnam" An then 11 i( I may a++roa,h- your honor6 Ju!e" 8es$
    #r$ %utnam" 7his is e2hi0it 12BC8$
    7he *itness" 7his is hers- ri!ht6

    #r$ %utnam" ?o+e(u))y not- 0e,ause I *rote a)) o3er it tryin! to e2+eite this$
    7he *itness" I9m sorry$ I thou!ht that *as the se,on one$
    Ju!e" 7han; you$
    #r$ %utnam" A)) ri!ht$
    K$ o", do you recall sending this email to Mr$ /ileo "here you "ere for"arding another fan email?
    +$ -orrect$
    K$ +nd the email belo" it, it says to )aren and Michael$ +gain, * "on#t go through the "hole thing, because you testified
    about it before$ +nd it ends "ith &andy &tadler, s-t-a-d-l-e-r, in e" ,ork city$ /o you see that?
    +$ -orrect$
    K$ /o you kno" "ho Ms$ &tadler is?
    +$ ot really$ + fan, sir$
    K$ *s she someone you#ve met before?
    +$ * don#t kno"$
    K$ *s she someone you#ve spoken "ith before?
    +$ * don#t kno"$
    K$ *s she someone you corresponded "ith before?
    +$ * don#t kno"$
    K$ &o "hen you say she#s a fan, it#s based upon this email alone?
    +$ -orrect$
    K$ +nd, again, *#ll !ust summariFe this is another email "here a fan is "riting in saying that Mr$ Jackson is too thin,
    correct?
    +$ -orrect$
    K$ o", in the email "here you for"arded this email to Mr$ /ileo -- let#s go into that one$ *t#s -- it says from "ingheart7$
    5hat#s you, correct?
    +$ -orrect$
    K$ +nd, again, it#s to tookie, Mr$ /ileo?
    +$ -orrect$
    K$ o", this is June 66nd --
    +$ -orrect$
    K$ -- 633=? *t looks like !ust before 23:33 in the morning$

    +$ -orrect$
    K$ o", this "as the day that you actually "ent to -arol"ood and "aited for several hours and ended up not seeing Mr$
    Jackson, correct?
    +$ -orrect$
    K$ /o you kno" if you "ent to see Mr$ Jackson before 23:33 am that morning or after 23:33 am that morning?
    +$ *t "as after$
    K$ &o this is something you sent to Mr$ /ileo prior to going to see Mr$ Jackson?
    +$ -orrect$
    K$ *#d like to go through it, if * can$ *t says B'ookie$B 5hat#s his nickname, correct?
    +$ -orrect$
    K$ o", one thing * "ant to note, and then "e#ll go through it straight through -- but let me find the line here$ *n the -- *#ll
    call it the second full paragraph -- you can tell the indentions from the right, not the left$ &o it says B0hen he asked to do
    this in May$B /o you see that?
    +$ ;h-huh$
    K$ *t says B0hen he asked to do this in May --B
    +$ BWhen he asked e$B
    K$ 5hank you$ BWhen he asked e to do this in May, and et with hi, I saw a slender but strong and coherent
    Michael Jackson$B
    +$ -orrect$
    K$ /o you see that? o", this says May$ ,ou actually met Mr$ Jackson prior to that, right?
    +$ -orrect$ 5hat "as an error on my part$
    K$ +nd so "hen you say that he "as slender but strong and coherent, you#re talking about "hen you first sa" him in
    633=?
    +$ -orrect$ 5hat "as -- it "as March and not May$ 5hat "as a -- an error on my part$
    K$ +ll right$ o", going up !ust -- *#m going to go do"n through the email, if * can$ &o it begins "ith BI %ust want you to
    have this in#oration to be one step ahead.B
    +$ -orrect$
    K$ /o you recall "hat you meant by that?
    +$ ,es$ * "anted him to kno" this$
    K$ (kay$ +nd you go on to talk about his fragile state, and then you say it seems like he is setting himself up to be the
    victim$

    +$ -orrect$
    K$ BI see his pattern once again eerging with his caretakersB?
    +$ -orrect$
    K$ B"e uses the to #inance his li#eB?
    +$ -orrect$
    K$ B(nd then oves on when he cannot deliver on his proises. I a not saying his original intent isn't to #ul#ill his
    obligations, but I' erely speculating that he becoes paraly)ed with #ear. 'his is why I thought therapy #or hi is
    the ost iportant eleent to this being able to succeed$B /o you see that?
    +$ * do$
    K$ o", "hat did you mean "hen you said that he "as setting himself up to be the victim?
    +$ &ir, * "as desperate "hen * "rote this email because * felt that * "asn#t being heard or considered, and * really -- *
    "anted to get attention from the people above the line because * felt * "asn#t being heard or ackno"ledged$ &o * composed
    a letter almost in their language to get their attention, to make them feel that they could be responsible if they don#t do
    something$ 5hat "as my intent of this, and to use language that "as -- "ould get their attention$ %rank /ileo told me * "as
    not allo"ed to --
    K$ o, !ust --
    +$ -- communicate "ith the fans$ &orry$
    K$ * don#t "ant to hear "hat anybody said to you, * !ust "ant to understand "hat you meant by each letter like that$
    +$ *#m trying to e'plain$
    K$ (kay$ &o "hen you say B5his pattern once again emerging "ith his caretakers,B 0hat did that mean?
    +$ * sa" him "hen he "ent to 1ahrain after the trial, and * kno" the &ultan of 1ahrain "as really trying to help Michael,
    and they set up a record company, * think$ He "as supposed to, you kno", "ork "ith them and do records$ +nd through
    the media, * found out that that never really occurred, that * kno" -- * think the &ultan and the people in 1ahrain helped
    Michael financially "ith his past trial, and * don#t kno" "hat happened$ *#m merely speculating$ +nd * "as trying to find
    patterns, * "as trying to find out "hat "as going on "ith Michael because * "as desperate here, and *#m trying to say that
    Michael -- * didn#t feel that Michael had intentions to do "hat he "as doing, but that he "as scared to death$ He "as
    frightened at this point, and trying to get -- and like that happened "here Michael ended up not fulfilling those obligations
    "ith the people in 1ahrain after * felt that they "ere helping him, and then * see this happen "herever -- there#s all these
    people and -- for 5his *s *t, and * sa" kind of a pattern, and * "as afraid there#s something that -- fear "as involved in this$
    5here "as something frightening Michael because he goes in "ith really good intentions and then something happens, and
    *#m !ust trying to figure out "hat this is$ +nd * thought the best path"ay, that he needed some psychological help for the
    pain that he had suffered physically, mentally, in the past$
    K$ o", in the ne't paragraph, you say BI see so any people invest in his success and believe in hi. 'hen I have to
    watch hi sel#-destruct. I have seen with y own eyes hi deteriorate physically in a onth. I have seen hi do this
    several ties in y relationship with hi$B
    +$ -orrect$
    K$ 0hen had you seen him do this several times in your relationship?
    +$ 5he trial, sir$

    K$ (kay$
    +$ 5he trial and -- and "hat *#m trying to say is * remember -- * think * discussed like the beacon theater$ >ike everybody
    "as there for him, even all the talent and the celebrities, and "e had gone through rehearsals, everything seemed fine$ 1ut
    "hen * "ent, he had taken something that made him, you kno", in an incoherent state "hen * had to take -- "hen he had
    to do the sho"$ &o all *#m trying to do, *#m trying to figure out "hat is going on and *#m trying to put these patterns
    together$ +nd * !ust keep coming up "ith there#s some sort of fear going on$ +nd then, also, the things that )enny told me
    previously that had happened$
    K$ (kay$ 1ut "hen you say B* personally have seen,B you "ere talking about the things you#ve personally seen up until the
    )enny part, correct?
    +$ * think so$ * --
    K$ (kay$
    +$ 0ell, yeah, the things they e'perienced "ith him$ &orry$
    K$ +nd you "ent on to say BI watch hi -- I watch hi turn people against each other who are working so hard to help
    hi$B
    +$ -orrect$
    K$ 0hat did you mean by that?
    +$ (kay$ 5o e'plain this is that * think * -- * don#t kno" if * e'plained this before or not, but the "orld around Michael is
    so competitive, and it seems like people are al"ays trying to fight for a position to be closest to Michael$ +nd -- ho" did *
    say this for -- and * !ust see this situation -- okay$ -an * give you an e'ample?
    K$ &ure$
    +$ %or instance, the "hole like "hen Michael "as getting fitted for -- and there "as this designer Haldi "ho "as fitting
    his clothes$ +nd "hen Haldi left, and * "as in the room, and Michael 1ush "as there, Michael asked Michael 1ush, B*
    can#t "ear those clothes$ * -- they#re not going to "ork for me$ -an you start "orking on other clothes?B and -- and
    Michael 1ush said okay, but that "asn#t "hat Michael 1ush#s !ob in the -- in 5his *s *t "as going to be$ 1ut Michael never
    told anybody else, he didn#t tell Haldi he couldn#t "ear those clothes, and he -- you kno", so it created a conflict, you
    kno"$ +nd * sa" things like "here Michael -- "here Michael had like Mark &chaffel and Peter 0eiss kind of in the same
    position at one time, kind of managers, and it created conflicts$ &o this is kind of the thing$ +nd %rank -- * "as "riting this
    to %rank /ileo, somebody "ho had "orked "ith him a long time "ho understood the competitiveness around Michael,
    and "hat "as -- and -- and the conflicts that could come "hen you#re "orking "ith somebody "ho "as so prestigious$
    People "ant to be ne't to you, people "ant to -- they "ant to be you "hen you#re ne't to somebody like that$
    K$ +nd then it goes on to say B"e hurts hisel# ost o# allB?
    +$ ,es$
    K$ 0hat did you mean by that, ma#am?
    +$ He#s dead$
    K$ 0ell, he "asn#t at this point, "as he, ma#am?
    +$ o$ 1ut *#m saying that -- that the -- the things that are going on -- okay? -- by creating the conflict "ith, say, Haldi and
    Michael 1ush, things kind of are difficult to negotiate for everybody$

    K$ +nd the ne't paragraph, you say BI don't think you, *enny or +andy deserve becoing the villains or the #inancial
    victis$B /o you see that?
    +$ -orrect$
    K$ 0hy did you think they didn#t deserve to become the villains or the financial victims?
    +$ 1ecause * felt people "eren#t doing enough and taking my concerns, and * thought that "ould get their attention
    because * -- * "anted to make it clear that they could possibly be responsible for -- for Michael collapsing, for Michael --
    for something horrible happening to Michael onstage$ +t this point, you kno", yes, the possibility of death "as there for
    me, because he "as deteriorating so rapidly8 but the fact that he "ould be onstage, that they "ould push him to be onstage
    in his frail state, they could be responsible for that in some "ay$ Just kind of like "here "e are right no"$
    K$ +nd so you "ere "riting this because you believed that this "ould get the attention of -- of <andy and )enny and
    others above the line "ho could do something about this?
    +$ * "as hoping so, sir$
    K and you "rote it specifically "ith that intent?
    +$ ,es, sir$
    #r$ %utnam" Let9s !o to the )ast +ara!ra+h$
    Ju!e" A (e* more minutes$
    #r$ %utnam" 7his is it$
    K$ *n this last paragraph, you see it says B'his is between you and e aloneB?
    +$ ,es, sir$
    K$ /o you see "here you say that?
    +$ * do, sir$
    K$ +nd you "rote that to Mr$ -- *#m sorry -- to Mr$ /ileo, %rank /ileo, "ho had been Mr$ Jackson#s manager off and on
    for 93 years, someone you kne" personally$ +nd here you say B'his is between you and e alone. I a leaving this in
    your hands as you have instructed e to do$B so B5his is bet"een you and me alone$B 5hat sounds like you#re saying it#s
    bet"een you and %rank /ileo$ /id you actually mean it "as bet"een you and him and +G. >ive and the --
    +$ +ctually, yes$ * "as hoping to scare him enough that he "ould do it, sir, because he instructed me that * "as supposed
    to come to him, and * "as hoping and making this letter dire enough that he "ould take care of things$ (kay? +nd * kne"
    %rank couldn#t stop the concert or postpone the concert$ * "as trying to get their attention to do something$ * "as
    desperate, and * felt * "asn#t being listened to$ * "anted a therapist for Michael all along, and they kept "ant- -- telling me,
    Boh, they have this doctor$B and, you kno", * !ust felt at this point -- this is the second letter * "rote "ith no response$ o
    response from %rank /ileo, no response from anybody, and * "as trying to get their attention "ith this, sir$
    K$ &o this is both -- you#re talking about "hat happened on the 63th and the 66nd "hen you for"arded emails about Mr$
    Jackson being too thin --
    +$ -orrect$
    K$ -- to %rank /ileo? +nd on this, you have -- you "ere saying B5his is bet"een you and me aloneB?
    +$ ,es, sir$

    K$ +nd that "as meant to mean that he "as to direct these to the people at +G. and to the concert director? 5hat#s "hat --
    that#s your testimony?
    +$ * "as trying to make him feel that * "as confiding in him this truth$ * -- my intention "as for something -- somebody to
    help Michael, "hatever it took, sir$
    K$ 5hat, * understand, ma#am$ 1ut you did say that this "as bet"een you and %rank alone?
    +$ * e'plained because he told me that * had to secretly bring him all the information * kne" about Michael, sir$
    K$ +nd, again, you didn#t mention -- the ne't day you go and see Mr$ Jackson at the 69rd and the 6Dth because those are
    the rehearsals at the &taples -enter?
    +$ -orrect$
    K$ +nd you didn#t ask Mr$ Jackson about his problems on the 2=th on those days, correct?
    #r$ %anish" As;e an ans*ere numerous times$
    Ju!e" Sustaine$
    #r$ %utnam" No (urther <uestions- your honor$
    Ju!e" O;ay$
    #r$ %anish" Can *e +ut that 0a,; u+- that e2hi0it6
    Ju!e" Eeire,t6
    #r$ %anish" I9m !oin! to try to (inish- your honorA 0ut it9s 0een a)) ay$ So I on9t *ant to ;ee+ 11 it *i)) !o (ast- so
    11 that9s e2hi0it num0er 12BC8$ An i( *e ,ou) (o,us on 11
    #s$ Chan!" 3CC- ash- 1$
    #r$ %anish" 4e))- *hate3er$ 5Michael is pain#ully thin-5 that +ara!ra+h$ I( *e ,ou) )oo; at that$
    7he *itness" 4here 11
    #r$ %anish" 4e93e !ot to 0)o* it u+$ 5Michael 115
    #s$ Chan!" Can *e s*it,h to +am rea) <ui,;6
    Ju!e" It9s the )ast one *e *ere )oo;in! at- ri!ht6
    #s$ Chan!" 7he one ri!ht 0e(ore it- ri!ht 0e(ore- 5#i,hae) is too thin$5
    #r$ %anish" O;ay$ ?ere *e !o$ It says 5Michael is pain#ully thin. "is bones are protruding. I' the one person that
    has physical contact with hi every day. Michael is old, he's getting worse$5
    7he *itness" OC:
    #s$ Chan!" OC:
    #r$ %anish" I9m !ettin! o)$

    7he *itness" I ;no*- that C ,an )oo; )i;e a )- ,an9t it6


    #r$ %anish" A)) ri!ht$ 5"e repeats his actions and rabling words constantly, rarely coherent with the present
    conversation. I see 'ravis struggling and winded %ust going through the otions at rehearsal doing MJ's part.5
    Eeire,t e2amination 0y @rian %anish"
    K$ /id * read that right?
    +$ -orrect$
    K$ *s that "hat you "ere seeing?
    +$ ,es, sir$
    K$ /oes that accurately sho" the concerns that you had, some of them?
    +$ ,es, sir$
    K$ *t says BWe are having Michael on a cherry picker over the audience, clibing very high, steep steps, and so #ar, he
    can't even walk down the rap without assistance. *enny has asked the #eale dancers to assist hi leaving the
    stage$B is that problems that you sa" Mr$ Jackson having?
    +$ ,es, sir$
    K$ +re you a medical doctor?
    +$ o, sir$
    K$ 5hese concerns that you had, did you try to do everything you could to ring the alarm, the red flags, on the problems
    that e'isted?
    +$ -orrect$
    K$ /id Mr$ Phillips or Mr$ .onga"are ever come over and tell you, B"e#re going to take care of itB?
    #s$ Ste00ins" O0.e,tionA )a,;s (ounation that they e3er ;ne* o( these +ro0)ems (rom #s$ Faye$
    Ju!e" Sustaine$
    #r$ %anish" 4e))- no$
    K$ /id either Mr$ Phillips or Mr$ .onga"are come discuss Michael#s physical condition "ith you?
    +$ o$
    #r$ %anish" No*- )et9s ta;e a )oo; at e2hi0it num0er 08>D$ 0>>D$
    #s$ Chan!" It9s 08>>D$
    #r$ %anish" Somethin! )i;e that$
    7he *itness" :o I ha3e that6
    #r$ %anish" ?ere$ 7ryin! to !et throu!h this$

    K$ *s that an email that you "rote?


    #s$ Ste00ins" Just i( *e ,an see it 0e(ore *e start 11
    #r$ %anish" 4e))- I ha3en9t +ut it u+ yet$
    K$ (kay$ Have you seen that before?
    +$ ,es, sir$
    K$ /id you "rite that email?
    +$ ,es, sir$
    K$ -an "e put it up, please$ 0hat#s the date of that email?
    +$ 5he one -- !uly 2st$
    K$ (kay$ 5hat#s a fe" days after Michael died?
    +$ ,es$
    K$ +nd "ere you "riting to Mr$ Phillips to tell him that there "as some film taken of Mr$ Jackson "here he "as at his
    "orst, shuffling and "rapped in a blanket?
    +$ ,es$
    K$ +nd had you told Mr$ (rtega to make sure they didn#t shoot Michael looking like that?
    +$ ,es, sir$
    K$ +nd "as it disconcerning to you that this film had been taken?
    +$ ,es, sir$
    K$ +nd did Mr$ Phillips respond to you?
    +$ ,es, sir$
    K$ >et#s see "hat he said$ 5his is "ithin -- ho" many days are in June? 5he ne't one$ Ho" many days are in June? 93?
    (kay$ &o this is "ithin si' days of the death, right?
    +$ * think so$ * don#t kno" ho" many days are in June, sir$
    K$ * think it#s 93$ *#m looking at the calendar$ /id Mr$ Phillips "rite back to you
    +$ ,es, sir$
    K$ 0hat did he say?
    +$ ,ou "ant me to read it?
    K$ ,es, please$
    +$ BWe control all the #ootage and it is locked in the vault at $taples -enter$B

    K$ (kay$ o", * "ant to sho" you "hat#s in evidence, e'hibit 6@?, dash, 2$
    +$ 0hat#s that?
    #r$ %anish" *e))- I9m !oin! to 11 I9)) !i3e you a ,o+y- +ut it u+$
    #s$ Ste00ins" 8our honor- I o0.e,tA )a,;s (ounation to as; this *itness a0out this ,hain o( emai)s$ A)so 0eyon the
    s,o+e o( ,ross1e2amination$
    #r$ %anish" No$ 7hey as;e a0out a)) ;ins o( emai)s that she han9t seen- an this is ,onsistent *ith *hat she sa*$
    I mae that same o0.e,tion an sai 11
    Ju!e" I unerstanA 0ut in that emai)- she *as re(eren,e in that emai)$ 7his one- I on9t ;no*$ Can I see the
    emai)- ma9am6
    #r$ %anish" 4e))- )et me as; you this$
    Ju!e" 4ait$ Let me rea it$
    #r$ %anish" I ,an o it *ithout the emai)$
    Ju!e" O0.e,tion sustaine$
    #r$ %anish" O;ay$ I *ant you to assume that 7ra3is +ayne *rote an emai) on June 1Fth- it *as ,ommuni,atin!
    *ith #i,hae) 0earen- an that they *ere is,ussin! 11
    Ju!e" ?o) on$ Is this emai) in e3ien,e6
    #r$ %anish" 8es- it is- your honor$
    Ju!e" A)) ri!ht$
    #s$ Ste00ins" I thin; it is$
    #r$ %anish" I *ant you to assume that they *ere ,ommuni,atin! on June 1Fth- 5MJ is not in shape enough to sing
    the live stu## and dance at the sae tie$5 O;ay6 5"e can use the ballads to sing live and get his staina back once
    he's healthy enough and has ore strength.5
    K$ (kay? 0as that "hat you "ere seeing?
    #s$ Ste00ins" O0.e,tionA )eain!$
    Ju!e" O3erru)e$
    7he *itness" I *as 11 .ust rea it a!ain- so 11 I9m sorry$ I9m .ust 11
    K$ 0ere you seeing that Michael "as having a problem doing the performance, the singing, as of June 2@?
    +$ ,es, sir$
    K$ (kay$ o", * "ant you to assume further that Mr$ <andy Phillips "rote that he didn#t kno" "hat Michael#s problem
    "as, chemical or physiological$ (kay? -an you assume that?
    +$ -an * assume that --

    K$ 5hat <andy "rote that on June 63th$ (kay?


    +$ ,es$
    K$ 0as that consistent "ith "hat you thought?
    +$ ,es, sir$
    K$ /id you think that Michael Jackson needed some type of medical assistance at that time?
    +$ +bsolutely$
    K$ (kay$ o", * "ant you to assume that on June 63th, 1ugFee Hougdahl "rote BMy layan's degree tells e he,B
    meaning Michael Jackson, Bneeds a shrink to get hi entally prepared to get onstage, and then a trainer to get hi in
    physical shape$B +nd that#s five days before he died$ *s that consistent "ith "hat you "ere observing?
    +$ ,es, sir$
    #s$ Ste00ins" I9m !oin! to o0.e,t- your honor- to im+ro+er hy+otheti,a)s- )a,;s (ounation$ 7here9s no reason (or
    this *itness to 11 the .ury ,an etermine *hether the o0ser3ations are simi)ar or i((erent- your honor$ As;in! her
    *hether she a!rees *ith *hat other +eo+)e es,ri0e is not +ro+er e3ien,e$ ?e shou) as; her *hat she o0ser3e$
    %)us they9re a)) )eain!- your honor$
    Ju!e" O3erru)e$
    #r$ %anish" Anythin! e)se6
    #s$ Ste00ins" 7hat9s !oo$
    Ju!e" #r$ %anish- i( you ha3e a ,omment- you ,an ire,t it to me$
    #r$ %anish" 4e))- I *as tryin! to (inish$ A)most e3ery <uestion I as;- they o0.e,t to$ I in9t o0.e,t 11 not mu,h$
    4hen I i- it *as sustaine$
    So I *ant you to assume that #r$ ?ou!ah) sai 5My layan's degree tells e he-5 #i,hae) Ja,;son- 5needs a
    shrink to get hi entally prepared to get onstage, and then a trainer to get hi in physical shape.5 Assume that he
    sai that$ No* thin; o( the o0ser3ations you *ere ma;in! as o( June 1>th$
    7he *itness" An *hat time *as that 11 that emai) that you 11 (rom @u!Gee6
    #r$ %anish" Late in the e3enin!- 22"DB$
    7he *itness" On Saturay6
    #r$ %anish" Friay- June 1>th$
    7he *itness" 8es$
    K$ *s that similar and consistent to "hat you "ere observing?
    +$ ,es, sir$
    K$ * "ant you to further assume that 1ugFee said BI have watched Michael Jackson deteriorate in #ront o# y eyes over
    the last eight weeks.B (kay? 0ere you observing the same thing?
    +$ ,es, sir$

    K$ * "ant you to further assume that )enny (rtega, as of June 27th, didn#t think Michael "as in good physical shape$ /id
    you think he "as in good physical shape or not on June 27th?
    +$ o, sir$
    K$ o, he "as not?
    Ju!e" #a9am- you nee to ans*er 11
    7he *itness" No- he *as not in !oo +hysi,a) sha+e on the 1Dth$
    #r$ %anish" O;ay$
    K$ /id you -- "ere you a"are -- and counsel asked you about June -- e'cuse me -- March 69rd, and * don#t "ant to bring it
    back, e'hibit 2932, dash, 6, and about the -- he sho"ed you this calendar here$ /o you remember that?
    +$ * remember him sho"ing me that$
    K$ 1ut that "asn#t "hat you looked at, right?
    +$ o, sir, it "asn#t$
    K$ 0ere you a"are that Mr$ .onga"are "as trying to prepare the calendar for Michael Jackson, "ithin t"o days of your
    email, stating that he "anted to make the calendar look like Michael "asn#t "orking as much as he "as?
    #s$ Ste00ins" O0.e,tion$
    &$ 4ere you a*are o( that (a,t6
    #s$ Ste00ins" O0.e,tionA )eain!- )a,;s (ounation$
    Ju!e" Sustaine$
    K$ /id anyone -- do you kno" -- all right$ Have you seen any emails regarding "hether Mr$ .onga"are "as trying to
    make the calendar look like Michael "asn#t "orking as much --
    #s$ Ste00ins" Same 11
    #r$ %anish" Can I (inish the <uestion6
    #s$ Ste00ins" Sure$ I9m .ust tryin! to sa3e time$
    #r$ %anish" 7hat *ou) 0e a (irst$
    7he *itness" I9m sorry$ 7hat *as (unny$
    K$ 0ell, you didn#t think -- did you think Michael could do the schedule as it "as set forth?
    +$ 5he schedule that * sa" online?
    K$ ,es$
    +$ o$
    K$ /id you raise concerns "ith anyone about that?

    +$ ,es, * did$
    K$ (kay$ +nd "ho did you raise concerns "ith it about?
    +$ )enny (rtega$
    K$ +nd do you kno" "hether or not +G., subse4uent to that, tried to change the schedule?
    +$ * didn#t kno", sir$
    K$ /o you kno" "hether Mr$ .onga"are tried to make it look like it "asn#t as much "ork as it "as?
    +$ o, * didn#t kno" that$
    #s$ Ste00ins" O0.e,tionA )a,;s (ounation$
    Ju!e" Sustaine- an the ans*er is stri,;en$ 8ou as;e the same <uestion$ 7hat9s *hy she9s o0.e,tin! in a3an,e$
    She a)reay ;no*s *hat you9re !oin! to as;$ So I9m !oin! to a))o* you to o that- #s$ @ina$ 8ou ha3e 20 minutes$
    #r$ %anish" 8our honor 11 o;ay$
    K$ Ho" long "as your contract for that counsel sho"ed you?
    +$ 5"o years$
    K$ 5hree --
    +$ o$ * thought it "as t"o or three$ 5"o$
    K$ >et#s take a look here$
    +$ * thought it "as t"o$
    K$ 0ell, let#s look$
    +$ *#m not sure$ * don#t have it, * didn#t memoriFe it$ (h, "ait$ *t "as in -- * don#t kno"$ ,ou#d have to take the page, or --
    K$ Here it is$ <ight here$ 5he term of the contract "as --
    +$ 5erm period?
    #r$ %anish" 4hat +ara!ra+h is that6
    #s$ Chan!" :o you *ant me to sho* you6
    #r$ %anish" Just te)) me$
    #s$ Chan!" I ha3e to !o u+ there$
    #r$ %anish" 4hi)e she (ins that 11
    7he *itness" I9m sorry$
    #r$ %anish" O;ay$ ?ere it is$ I9m sorry$ I ha the ri!ht +)a,e$

    7he *itness" 8es- you9re ri!ht$


    #r$ %anish" O;ay$
    K$ Ho" long "as the contract for?
    +$ *t#s from -- from July 633? to conclude on or about March 2st, 6322$
    K$ 5hat#s a three-year contract, correct?
    +$ -orrect$
    K$ 0as your --
    #s$ Ste00ins" I9)) .ust o0.e,t it misstates the o,ument$
    #s$ Chan!" Eea the term 0e)o*$
    #r$ %anish" 7he term 0e)o* says 5../, ter, a period coencing on or about the date hereo#, and continuing until
    one day #ollowing the last per#orance o# the tour unless sooner terinated as provided below.5
    K$ /id * read that right?
    +$ (kay$
    K$ >et#s !ust put it up$ *#m sorry$
    +$ 2$6, right?
    Ju!e" 1$C$
    7he *itness" Oh- 1$C6
    #r$ %anish" Let9s +ut it u+- the (irst +a!e- +)ease$
    7he *itness" Ju)y 8 11 Ju)y 8 11 I (ee) )i;e this is the home stret,h an the horses are runnin! as (ast as they ,an$
    Ju!e" 4e on9t ha3e that mu,h time$
    7he *itness" I9m .ust )i;e 11 I9m sorry$ I9m tryin! to unerstan$
    #r$ %anish" It9s a)) ri!ht$ O;ay$ %ara!ra+h 1$C$ A)) ri!ht$ 7here *e !o$ 7he term$
    K$ /o you see that#s "hat it says for the term "hich * !ust read? +nd let#s look at 2$6$
    +$ <ight$
    K$ +nd 2$6 says --
    +$ BJuly 0, 1220, to conclude on or about March 3.st, 12..$B
    K$ +nd it says B( series o# concert per#orances o# the artist in various countries and territories throughout the world
    and conteplated to coence July 1220 and go #or a period up to March 3, 12..5?
    +$ 92$

    K$ &o that "as the contract you had for more than !ust >ondon, "asn#t it?
    +$ (h, yes$
    K$ +nd you said you "ere re4uested by Michael Jackson8 is that right?
    +$ ,es$
    K$ 5o be the makeup e'pert?
    +$ Michael -- Michael re4uested me$
    K$ (kay$ +nd "ho did you negotiate the contract "ith?
    +$ +G., sir$
    K$ +nd did Michael sign your contract?
    +$ o, sir$
    K$ &o "ho signed the contract?
    +$ * think it "as Paul .onga"are, his initials at the bottom --
    K$ (n behalf of +G. >ive?
    +$ Pardon?
    K$ (kay$ ,ou "ere re4uested by Michael Jackson, and Mr$ .onga"are signed the contract to retain your services on
    behalf of +G. >ive, correct?
    +$ -orrect$
    K$ o", ne't$ *#m not going to ask about any shampoo or any bo"ls or any "igs, but "hat * do "ant to kno" is, "hy is it
    that Mr$ Jackson needed these hairpieces?
    +$ 0hy is it? %or the sho"$
    K$ 0ell, had something happened to his head at some --
    +$ (h, yeah$ He "as burned a long time ago$
    K$ +nd that#s --
    +$ He had damage to his scalp$
    K$ /id he have serious burn in!uries, as far as you kne"?
    +$ 0ell, he had first-, second- and third-degree burns on his scalp from the fire$
    K$ +nd *#m sure counsel "asn#t trying to make fun of him or anything, but "as the reason that he needed the hair because
    he had suffered a serious in!ury?
    +$ -orrect$
    K$ o", you "ere asked about your -- "hether they checked your background$ /o you remember those 4uestions?

    +$ ,es$
    K$ 0ere you being paid I273,333 a month?
    +$ o, sir$
    K$ 0ere you providing medical care to anyone?
    +$ o, sir$
    K$ /id you take a hippocratic oath "hen you became a makeup artist?
    +$ o$ * had to take a union test, though$
    K$ (kay$ /id you -- did you -- has anyone ever died "hen makeup, to your kno"ledge, has been applied to them?
    +$ * never even burned somebody "ith a hot iron, sir$
    K$ /o you think that you "ere in a similar position "hen counsel "as asking you about /r$ Murray?
    +$ 0hat#s the 4uestion? *#m sorry$
    K$ 0ere you providing any medical care to anyone?
    +$ o, sir$
    K$ (kay$ >et#s talk about Mr$ /ileo$ 1y the "ay, this .race <"aramba, did you ever see her give any drugs to Michael
    Jackson?
    +$ o, sir$
    K$ ,ou -- did Michael Jackson have issues "ith %rank /ileo, to your kno"ledge?
    +$ /id he have issues?
    #s$ Ste00ins" Ca))s (or hearsay$
    7he *itness" I on9t 11
    Ju!e" 4ait$ :i *hat6
    K$ /id Michael Jackson have issues "ith %rank /ileo based on "hat you observed and your history and years of "orking
    "ith him?
    Ju!e" O3erru)e$
    7he *itness" 4hat oes that mean6
    Ju!e" 8ou #ay ans*er$
    7he *itness" I9m sorry$ I9m !ettin! ,on(use$ 8es- he9s ha issues *ith Fran; :i)eo$
    K$ +nd "ere you surprised to see %rank /ileo come back?
    +$ ,es, sir$

    K$ 0hy?
    +$ 0ell, Michael told me he#d never hire him again, sir$
    #s$ Ste00ins" O0.e,tionA hearsay$
    Ju!e" Sustaine- the ans*er is stri,;en$
    7he *itness" Sorry$
    #r$ %anish" O;ay$
    K$ 0as %rank /ileo the one that said go get Michael a bucket of chicken?
    +$ ,es, sir$
    K$ o" * "ant to ask you did you -- counsel "as asking you about did you go back and find some te't messages
    regarding these events and discussions "ith Mr$ (rtega on the day the events occurred$
    +$ ,es, sir$
    K$ +nd did that refresh your recollection about certain facts that occurred in this case?
    +$ ,es, sir$
    #r$ %anish" O;ay$ So I *ant to mar; 11 I on9t ;no* *hat the ne2t e2hi0it is- your honor$ :o you ha3e that6 4e
    !a3e it to ,ounse)$
    #s$ Ste00ins" 8our honor- i( this is the e2hi0it that #s$ Faye +rou,e this mornin!- *e9re !oin! to nee a sie0ar$
    #r$ %anish" I9m .ust tryin! to re(resh her re,o))e,tion$ I on9t *ant to use u+ 11
    Ju!e" 4e))- you ,an mar; it i( you9re .ust re(reshin! ri!ht no*$
    #r$ %anish" For that- 0ut it9s !oin! to a)so 0e use (or im+ea,hment *ith #r$ Orte!a$ @ut I ha3en9t sho*e it yet$
    First I *ant to 11
    #s$ Ste00ins" It #ay 0e 11
    #r$ %anish" Let me +)ease mar; the e2hi0it (irst$ O;ay6 Can *e o that6
    Ju!e" 8es$
    #r$ %anish" O;ay$ Can I sho* it to the *itness6
    Ju!e" 8es$
    #r$ %anish" Can I as; her to rea it6
    Ju!e" Let9s o this$ 8ou ,an )ay a (ounation (or it- )et9s not !o any (urther 0e,ause 11
    #s$ Ste00ins" 8our honor- *e9re !oin! to nee to 0e rea))y ,are(u) 0e,ause this is materia) that an o0.e,tion has
    a)reay 0een sustaine mu)ti+)e times on +)ainti((s9 ire,t$

    #r$ %anish" 7here9s a0so)ute)y no o0.e,tion sustaine on this e2hi0it 0e,ause I in9t ha3e it$
    #s$ Ste00ins" Not to the e2hi0it- 0ut to the su0.e,t matter o( the e2hi0it- your honor$
    #s$ Chan!" 8our honor- it ,han!es a )ot o( thin!s- so *e9re 11 0ut he9s !oin! to .ust mar; it an as; <uestions 0ase
    on re(reshin! re,o))e,tion ri!ht no*$
    #r$ %anish" I9m not !oin! to sho* it yet$ @e(ore I sho* it- I *i)) is,uss it *ith the ,ourt$
    Ju!e" A)) ri!ht$
    #r$ %anish" I9m !oin! to mar; it as e2hi0it >83$
    'mar;e (or ienti(i,ation- e2hi0it >83- te2t messa!es/
    #s$ Ste00ins" I9 sti)) )i;e a sie0ar- your honor$
    Ju!e" 7here9s on)y ten minutes )e(t$ I9m not !oin! to ta;e u+ ten minutes *ith a sie0ar$
    #r$ %anish" An I ,an re(resh her re,o))e,tion *ith e3erythin!$
    Ju!e" 7rue$ 7rea ,are(u))y$
    K$ /id these te'ts refresh your recollection about --
    Ju!e" She hasn9t seen them$ 7hey ,an9t re(resh anythin! no*$ 7his is *hat you nee to o$ 8ou nee to as; her a
    <uestion- an then as; her i( re3ie*in! the te2ts *ou) re(resh her re,o))e,tion$ Let9s 11
    #r$ %anish" O;ay$ :o you ;no* *hat ha++ene on June 186
    #s$ Ste00ins" O0.e,tion to the e2tent this ,a))s (or hearsay- your honor$ I9m ,on,erne the *itness is !oin! to
    3o)unteer hearsay 0ase on the )en!thy e0ate *e ha on this issue )ast time$
    #r$ %anish" Just say yes or no$
    Ju!e" O3erru)e$ :o you remem0er *hat ha++ene on June 186
    #r$ %anish" 4ithout )oo;in! at the te2t$
    7he *itness" 8es$
    #r$ %anish" 4e)) 11
    Ju!e" 4hat6 She oesn9t nee to )oo; at it yet$
    #r$ %anish" I ha3en9t !ot there yet$
    7he *itness" :o I remem0er6
    #r$ %anish" 8es- s+e,i(i,a))y e3erythin! that ha++ene on that ay in3o)3in! Kenny Orte!a an #i,hae) Ja,;son
    an Eany %hi))i+s$
    7he *itness" :o I remem0er6 8es$
    K$ o", do you kno" "hether or not any meetings occurred that --

    Ju!e" Oh$ So 11 *e)) 11


    7he *itness" I on9t ;no* *hat to o$
    #r$ %anish" O;ay$
    K$ 0ho is 1arry?
    +$ 1arry is my boyfriend, sir$
    K$ (kay$ /id something happen, don#t tell me "hat it is, on June 2? that caused you serious concern?
    +$ ,es, sir$
    K$ (kay$ +nd "hat time at night did you get home "hen you "ere concerned about this event? /on#t tell me "hat it is$
    +$ ,ou#re asking me "hat time, but don#t tell you?
    K$ o, no$ 0hat time did you get home? &orry$ /o you remember "hat time you got home?
    +$ ,es$
    K$ 0hat time?
    +$ 6:93 in the morning$
    K$ (kay$ 0ere you very upset?
    +$ ,es, sir$
    K$ (kay$ 5he ne't morning "hen you a"oke, did you immediately do something? /on#t tell me "hat it "as, !ust "hether
    or not you did something$
    +$ ,es, sir$
    K$ /id you send a te't -- don#t tell me "hat "as in it -- to anyone at that time immediately upon a"akening?
    +$ ,es, sir$
    K$ +nd do you kno" did Michael come to rehearsal on June 2?th?
    +$ ,es, sir8 but late$
    K$ 0hat time did he come?
    +$ He came in at =:93, sir$
    K$ Ho" "as Mr$ -- Mr$ (rtega#s demeanor on that date?
    +$ Garlier, he "as very angry, sir$
    K$ 0hat did you observe -- don#t tell me "hat he said -- in his demeanor?
    +$ He "as very angry that Michael hadn#t been to rehearsal yet$
    K$ /o you kno" "hether -- don#t tell me -- !ust yes or no, "hether a meeting occurred "ith Michael Jackson and anyone

    else that day?


    +$ ,es, sir$
    #s$ Ste00ins" O0.e,tionA )a,;s (ounation$ ?er on)y (ounation- your honor- (or this is hearsay$ 4e93e ha )en!thy
    sie0ars on this 0e(ore$
    #r$ %utnam" 7his *as a )en!thy sie0ar *hen she testi(ie )ast time$
    #s$ Ste00ins" Ori!ina))y- your honor- se3era) *ee;s a!o$ 4e93e !one (ar o*n this roa 0e(ore$
    Ju!e" ?o* mu,h more o you ha3e on your e2amination6 In other *ors- ,an *e ,ome 0a,; to this an you ,an
    (inish *hat you ha3e6
    #r$ %anish" I ,an !o to some other thin!s- sure$ I mean- I ha3e three +a!es o( <uestions$ I93e 0een sittin! here (or 11
    ,an *e o this on #onay- then6
    Ju!e" I on9t *ant to 0rin! her 0a,;$
    #r$ %anish" I ;no*- 0ut it9s ;in o( im+ortant$ An I on9t mean to o it- 0ut I on)y !ot u+ here at C"00 somethin!$
    Let9s !o on to the other areas- (inish them u+- an may0e *e ,an o a sie0ar rea) <ui,;$
    7he *itness" 4hat time are *e one6
    Ju!e" Let him (inish$
    K$ *n the last t"o "eeks of Michael#s life, don#t tell me "hat he said, did you observe "hether he "as scared?
    +$ ,es$
    K$ /id you observe "hether he "as paranoid?
    +$ ,es$
    K$ /id you observe "hether he -- in your -- look to be pressured?
    +$ ,es$
    K$ /id you e'press -- strike that$ (h$ 5he depositions$ /id you have your deposition taken in another case "here there
    "ere no representatives of )atherine Jackson, 1lanket Jackson, Paris Jackson and Prince Jackson?
    +$ * don#t -- okay$ 0ere they there?
    K$ o$ 0ere any la"yers representing them present?
    +$ /uring my deposition? o$
    K$ (kay$ +nd Mr$ Putnam "as there 4uestioning you$ %or ho" many days "as he 4uestioning you, Mr$ Putnam?
    +$ %ive days$
    K$ %ive days$ +nd that "as about ?33 and some pages of 4uestions "here you "ere 4uestioned by Mr$ Putnam and a
    la"yer for >loyd#s of >ondon, correct?
    +$ 5hat "as my original subpoena, sir, yes$

    K$ (kay$ +nd then "hen you "ere at that deposition, did Mr$ Putnam then serve you "ith a subpoena to have a deposition
    in this case?
    +$ -orrect, sir$
    K$ +nd the depositions, "hich they took from me, "ere about -- and *#m indicating a little less than a foot high, all the
    pages of the 4uestions that Mr$ Putnam "as asking, correct?
    + correct, sir$
    K and no one "as there representing )atherine Jackson, 1lanket Jackson, Prince Jackson or Paris Jackson, correct?
    +$ o, sir$
    #s$ Ste00ins" As;e an ans*ere$
    Ju!e" O3erru)e$
    #r$ %anish" No*- you to) me you9re not a o,tor$
    K$ *s there any 4uestion in your mind that Michael Jackson "as deteriorating "hen you sa" him at the end of -- from June
    on?
    +$ o$ * "as 4uite sure he "as deteriorating, sir$
    K$ +nd did you, in fact -- strike that$ +nd you didn#t kno" "hat "as "rong, correct?
    +$ -orrect, * had no idea "hat "as "rong$
    K$ 1ut you felt -- did you feel something "as "rong or it "as okay?
    +$ *t "as very, very "rong$
    K$ (kay$ +ll right$ o" * "ant to sho" you e'hibit number -- * think it might be -- oh$ 0hile "e#re looking for that, do
    you remember the picture that "as taken on June 2=th, counsel asked you "hether you "ere there or not there, and in the
    room or out of the room$ ?-7D$ 5hank you$ /o you remember that?
    +$ -orrect$
    K$ 5hose 4uestions?
    +$ ,es$
    K$ (kay$ *s that ho" Michael Jackson looked on June 2=th?
    +$ ,es, sir$
    K$ (kay$ +nd "hen you "ent to see him at the -- at the mortuary to assist the mortician, did you discuss "ith the
    mortician Michael Jackson#s "eight?
    +$ ,es, sir$
    K$ /id he look "orse than he looks in this picture that#s in front of you?
    +$ He "as dead, sir$ * mean, it#s like, *#m sorry$ 5hat#s like -- did he look "orse?

    K$ * mean his physical body$ * kno" he "as -- he "as not alive$


    +$ 1ut it#s hard -- hard to say because his body "ent through so much$
    K$ +ll right$ (kay$
    +$ 1ut it "as --
    K$ +ll right$
    +$ He "asn#t any heavier than that$
    K$ +nd "hen those fan emails that Mr$ Putnam "as sho"ing you -- specifically e'hibit 26?73 -- do you still have that in
    front of you? *f "e can put that up real 4uick?
    +$ 5his one?
    K$ ,es$
    +$ (kay$
    K$ +nd let -- if "e look here, if "e go do"n, "hat you "ere being told here on June 63th, "here it says BI told Michael to
    try it because he becae really thin and we were a#raid it wouldn't #it,B do you remember "hat that#s referring to?
    +$ 0here are you? 5hey made a !acket for him, sir$
    K$ 5here "e go$
    +$ 0here are you? /o * need to kno" "here you are?
    K$ *t#s right in front of you$
    +$ (kay$
    K$ 0hen they say they "anted him to try something on, "hat "ere they referring to?
    +$ 5hey#d made a !acket for him$
    K$ (kay$ -an you read to us "hat the fan that sent you this email that you for"arded on told you about Michael#s physical
    condition on June 63th?
    +$ B"e took his %acket o## and I saw soething horrible. ( skeleton. I watched his back. It was only bones. I a still in
    shock, and y best #riend, too. "e was so -- we knew he was skinny, but we were always seeing hi with a %acket on or
    a large top. 4ut as he was dressed this day, it was as i# he was naked and we saw how aw#ul it was$B
    K$ +nd let#s go do"n "here it says B0e don#t kno"$B 5hat line here$ 5his is "hat the fans "ere telling you, correct?
    +$ ,es$
    K$ *s this consistent "ith "hat you "ere concerned about?
    +$ ,es$
    K$ (kay$ <ead the ne't paragraph$
    +$ BWe don't know i# he is anore5ic and stopped eating, as he has told us, or i# it's soething ore coplicated than

    that, a disease or soething else$B


    K$ /o you kno" "hether these fans "ere medical doctors?
    +$ * don#t kno", sir8 but * don#t think they "ere$
    K$ 0as this something that, in addition to everything you sa", concerned you severely about Michael#s physical condition
    "ithin a "eek of his death?
    +$ ,es, sir$ 5hat#s "hy * sent it on$
    #r$ %anish" A)) ri!ht$ So no* I thin; 11 I9m on that )ast issue- your honor$ O;ay6 An I ;no* it9s Friay at C"31-
    an e3ery0oy is )oo;in! at me- 0ut it is 11
    Ju!e" 4e9)) ta;e a )itt)e 0it o( time$ I *ant to !et this one$
    #r$ %anish" I unerstan$
    Ju!e" 7han; you$
    #r$ %anish" O;ay$ So a(ter you 11 )ast time you *ere here- #r$ %utnam as;e you some <uestions a0out ,ertain
    thin!s that o,,urre in the 11 *hat ay it *as- an *ho sai *hat$
    K$ /o you remember that?
    +$ -orrect$
    K$ (kay$ +nd then you "ent back and, as you told him today, you found your old phone and you found te't messages
    regarding certain events, correct?
    +$ -orrect$
    K$ (kay$ +nd you told us earlier about the circumstances in "hich the te't messages "ere prepared$ /on#t tell me "hat#s
    in them$ +nd "ere those te't messages contemporaneous of the events that you heard from Mr$ (rtega? 1ut don#t tell me
    "hat he said$
    +$ -orrect$
    #s$ Ste00ins" O0.e,tionA 3a!ue as to 5,ontem+oraneous$5 8our honor- I thin; *e9re !oin! to nee that sie0ar$
    #r$ %anish" I9m not !ettin! into *hat *as sai yet$ I9m .ust )ayin! my (ounation$
    Ju!e" O3erru)e$
    #r$ %anish" Can I o that6 Is that o;ay6
    K$ +nd "hen Mr$ (rtega -- you told me that day, the 2?th, "as upset, "hat "as your reaction -- strike that$ /on#t tell me
    "hat Mr$ (rtega said8 but did he make some statements in your presence that day, "ithout telling me "hat he said?
    +$ ,es$
    K$ (kay$ +nd ho" did you feel "hen you heard the statements that he made? /on#t tell us "hat he said$
    +$ o$ *#m !ust trying to go back to that time "hen * heard it to try to be accurate of my feelings$ * "as pretty -- * "as
    pretty upset about it because it "asn#t --

    K$ * don#t "ant you to say "hat#s there$


    +$ o$
    K$ *#m going to get in trouble$
    +$ *t "asn#t "hat * thought should happen$
    K$ (kay$ 0as it upsetting to you?
    +$ ,es, sir, it "as upsetting to me$
    K$ +nd you got home at "hat time that night?
    +$ 6:93, sir$
    K$ +nd the minute you "oke up, did you "rite a te't reflecting e'actly "hat Mr$ (rtega had said?
    +$ ,es, sir$
    K$ +t that time, did you have any idea "hether or not Mr$ Jackson "ould be dead si' days later?
    +$ o, sir$
    K$ 0ere you still upset "hen you "rote the te't?
    +$ ,es, sir$
    K$ +t the time that you sent the te't, did you have any idea that there "as going to be this la"suit?
    +$ o, sir$
    K$ Ho" "as Michael#s demeanor and psychological psyche on June 2=th?
    #s$ Ste00ins" O0.e,tion as to +sy,ho)o!i,a) +sy,he- your honor$ 7his is a )ay *itness$
    Ju!e" Sustaine$
    K$ Ho" "ould you describe Michael#s emotional state on June 2=?
    +$ June 2= or June 2??
    K$ >et#s go to June -- let#s take June 2?$
    +$ 1ecause the 2?th "as the day he came back to the -- at =:93$
    K$ =:93 at night?
    +$ +t night$
    K$ +nd ho" "as he doing there?
    +$ He "as pretty much -- * reported -- * think * said that before, that he "as almost kind of catatonic$ He "as like so stoic,
    * think is the "ord that * used$ ;sually he#s kind of happy and stuff, but he appeared to be scared to death$
    K$ +nd that#s at =:93 at night?

    +$ 0hen he came in$


    #r$ %anish" O;ay$ 8our honor- so those are my <uestions on that issue$ I ;no* it9s 11
    Ju!e" O;ay$ So you nee a sie0ar6
    #r$ %anish" So *e9re at the +oint o( sie0ar$
    #s$ Chan!" Can *e .ust hu)e (or a se,on an ma;e a su!!estion6
    Ju!e" 8ou mean ta); amon! yourse)3es6
    #s$ Chan!" No$ 4ith you$
    #r$ %anish" 4e on9t nee the re+orter$ Just to ma;e a 11 I9m tryin! to s+ee this u+$ I9m sorry$
    #s$ Ste00ins" 8our honor- I on9t min a hu)e- 0ut *e mi!ht nee the re+orter at some +oint$
    Ju!e" Let9s try the hu)e (irst$
    'Sie0ar- not re+orte/
    Ju!e" O;ay$ Just a <ui,; <uestion to ,ounse)$ Are *e one *ith the <uestionin!6
    #r$ %anish" 8es- su0.e,t to *hat *e is,usse$
    Ju!e" 8es- o( ,ourse$
    #r$ %anish" An reser3in! the ri!ht$
    Ju!e" I !et that$ O;ay$ I9m !oin! to )et you !o (or toay- 0ut I o nee to s+ea; to a)ternate num0er D an
    a)ternate num0er 1$ An I (or!ot *hat time *e sai *e9re ,omin! 0a,; on #onay$ I ha a )i!ht ,a)enar- so I
    thin; they sai >"30 on #onay$ O;ay6 >"30 on #onay$ 7han; you$ ?a3e a !oo *ee;en$ No*- e3ery Friay- o
    you remem0er my amonition6 :on9t is,uss the ,ase- on9t rea the ne*s re+orts- on9t )isten to anythin! or rea
    anythin! on the internet$ O;ay6 7han; you$ ?a3e a !oo *ee;en$ A)ternate num0er D an a)ternate num0er 1- I
    nee you to stay$
    'the (o))o*in! +ro,eein!s *ere he) in o+en ,ourt- outsie the +resen,e o( the .urors- e2,e+t a)ternate .urors 1 an
    D/"
    Ju!e" (kay$ 0hat happened is my court assistant said that you "ere approached by someone "ho mentioned something
    to you about a"arding money$
    A)ternate .uror num0er D" ,es$
    Ju!e" + "oman?
    A)ternate .uror num0er D" ,es$
    A)ternate .uror num0er 1" + "oman$
    Ju!e" * !ust "anted to in4uire about that conversation$ &omebody "earing red, a female "earing red? +nd so "e need to

    talk about that$ +nd -- okay$ * don#t kno" "ho "ants to address it first$ +lternate number 7? &hould * 4uestion them
    separately?
    #r$ %anish" ,eah, probably$ * think probably$
    #s$ Ste00ins" ,our honor, maybe "e should not have all the press here for it? * don#t kno" if it matters$
    Ju!e" * don#t kno" if it should be done in that fashion$
    #s$ Ste00ins" * don#t kno" "ho "as doing the approaching, so * don#t kno" "hat the issue is$
    Ju!e" o, * don#t think it#s the press$ +ctually, it#s been described as a fan, actually$
    #r$ %utnam" (kay$
    Ju!e" (kay$ *#m going to ask one of you to step out$ 0ho "ants to talk about it first? ,ou#re alternate number 7?
    A)ternate .uror num0er 1" o, *#m number 2$
    Ju!e" 0ould you step in the !ury room, number 7, * guess, and "e#ll call you "hen "e#re ready to talk about it?
    A)ternate .uror num0er D" (kay$
    'a)ternate .uror num0er D )e(t the ,ourtroom/
    Ju!e" 5he attorneys are hearing about this for the first time, as "ell, so can you tell me "hat happened?
    A)ternate .uror num0er 1" Me and alternate 7 "ere standing by the "ater fountain$
    Ju!e" (n this floor?
    A)ternate .uror num0er 1" (n this floor$ 5here "as a "oman that "as standing "ith red pants, a light shirt, and a
    bandanna-looking thing, hair-holder thing$ &he "as standing by the restrooms, by the escalators, and * noticed that she
    "as standing there for a long time$ *t seemed to me like she "as kind of like trying to listen to "hatever she could hear$
    +nd --
    Ju!e" >isten to you, or !ust --
    A)ternate .uror num0er 1" &he "as !ust standing there$ *t !ust seemed kind of "eird to me that she "as !ust standing
    there as people "ere !ust going back and forth to the restrooms or "hatever$ 5hen she -- actually, * noticed her, and * told
    alternate number 7, * said, Bdo you see that girl there? * think she#s trying to listen to "hatever she can,B or "hatever$ +nd
    "hen * said that, she "alked in our direction and said, B* !ust "ant to say something$ +re you guys !urors in the case?B and
    "e#re like --
    Ju!e" ,ou have the !uror badge on, right?
    A)ternate .uror num0er 1" +nd then she#s, B"ell, * "ant to say something, and * !ust "ant to tell you --B she said -- she
    said, B* !ust "anted to tell you not to -- not to a"ard them any money$ 5hose people, don#t a"ard those people any
    money$B and * told her, Bma#am, you should not be talking to us$B she goes, B* kno"$B and * said, B"ell then you need to
    stop talking$B and she said, Byeah, but * "ant to tell you that you shouldn#t be a"arding those people$ * kno" the truth$B *
    said, Bma#am, seriously, you need to stop talking to us right no" because you#re going to end up getting in trouble$B and
    she "as !ust -- she "as !ust standing there, she "asn#t leaving$ &he -- she maybe attempted to say it again8 and at that
    point, "e both "alked a"ay to"ards the hall"ay "here "e line up to come inside$ &he "as -- she continued to follo" us,
    and she continued to say, you kno", Bi !ust "ant to say don#t a"ard those people any money$B
    Ju!e" &he "as follo"ing you as you "ere "alking?

    A)ternate .uror num0er 1" &he kind of "alked in the same direction "e "ere "alking$ &he "alked to"ard the elevator,
    pushed the button like she "as going to go in the elevator, but she did not go in the elevator, she !ust stood there$ +nd *
    "as telling her, Bma#am, * don#t "ant to hear you$ .o a"ay$ .o a"ay$ 5hank you, bye,B and that "as it$ +nd she actually
    eventually did "alk -- "alk to"ards the escalator and do"n$ &he "ent do"n$
    Ju!e" Have you seen her before?
    A)ternate .uror num0er 1" o, * never noticed her before$
    Ju!e" %irst time you#ve ever seen this person?
    A)ternate .uror num0er 1" * believe so$
    Ju!e" *s that person in the courtroom?
    A)ternate .uror num0er 1" *s there a person "earing red pants?
    Ju!e" /o you see anybody in the courtroom that looks like that person?
    #r$ @oy)e" ,our honor, * actually --
    #r$ %anish" /on#t say anything$ 0as anyone --
    Ju!e" 0ait a minute$ *#m asking if he recogniFes anybody in the courtroom that looks like that person$
    A)ternate .uror num0er 1" * don#t believe so$
    Ju!e" (kay$
    #r$ %anish" -an * ask something?
    #r$ %utnam" &hould someone step out and see if there#s a person in red pants "ho is still here?
    A)ternate .uror num0er 1" *#m not sure if you observed$ 1ut he "as "alking by$
    #r$ @oy)e" ,eah$
    #r$ %anish" 5hat "as my 4uestion$ (ther than yourself and alternate number 7, did you see anyone else in the vicinity
    that might be able to identify the person?
    A)ternate .uror num0er 1" *#m sorry$ * --
    #r$ %anish" Mr$ 1oyle?
    A)ternate .uror num0er 1" * did see Mr$ 1oyle "alk past us$ * don#t kno" if you "ere going that "ay or this "ay$
    #r$ @oy)e" * "as going do"n to get a gatorade, and * did see that interaction, because * sa" you talking to somebody, and
    * "as thinking * "onder if that#s one of their "ives or something$ &he "as holding keys in her hands$ * remember you guys
    talking to a "oman$
    A)ternate .uror num0er 1" 0e "ere trying to discourage her from talking to us$
    #r$ %anish" 0ould you think if you sa" her, you could identify her?
    A)ternate .uror num0er 1" Probably$

    #r$ %anish" (kay$ 0ell, that#s good$ &o if -- "e#ll !ust ask your honor if he sees her to immediately, you kno", point it
    out to Aeronica, and "e can get that person$ 1ecause * didn#t see it, * don#t kno" -- "hen did this happen?
    A)ternate .uror num0er 1" Just before "e came in from the last break$ +nd * "as looking for a deputy, and then
    Aeronica "asn#t out there, and * "as like -- she "ent a"ay$
    #r$ %anish" 5hey#re never there "hen you need them, right? *#m kidding$
    #r$ %utnam" * "ant to ask you a 4uestion, if * could, your honor$ 5his is something "e noted in the very beginning of the
    case that "e "ere concerned "ith because of all the numbers of fans lining up "ith t-shirts and --
    #r$ %anish" * don#t think "e should be doing these discussions in front of the !uror$
    Ju!e" /o you have any 4uestions of --
    #r$ %utnam" o$
    Ju!e" (kay$ (kay$ 0ell, let me ask you, does that have any impact on ho" you feel about the case?
    A)ternate .uror num0er 1" +bsolutely not$
    Ju!e" +bout any issues in the case?
    A)ternate .uror num0er 1" o$ * -- * thought her -- * noticed her because * see other fans standing closer, but * sa" her
    separate$ 5hat#s "hy * noticed her$ o, no$ +s far as the interaction, * --
    Ju!e" +nd it "on#t influence you in making decisions in the case?
    A)ternate .uror num0er 1" o$
    Ju!e" ,ou can put it aside?
    A)ternate .uror num0er 1" ,eah, * can$ +bsolutely$
    Ju!e" /oes anybody "ant to ask him any 4uestions?
    #r$ %anish" 5hank you for bringing it to the court#s attention$
    #r$ %utnam" 5hank you very much$
    Ju!e" +nd "e May ask you -- * agree, if you see this person, let us kno" right a"ay$
    A)ternate .uror num0er 1" * "ill$
    Ju!e" 0e May ask you at some point -- if "e think "e find the person, "e May ask you to identify her$
    A)ternate .uror num0er 1" 5he ne't time * see her, * "ill let somebody kno"$
    Ju!e" +ll right$ *#m going to let you go and "e#ll bring in --
    A)ternate .uror num0er 1" /o you need me to "ait until he#s done?
    Ju!e" o$ 1ut "ill you get the other !uror and ask him to come in?
    A)ternate .uror num0er 1" &ure$ 5hank you$ Have a good "eekend$

    Ju!e" 5hank you$ ,ou, too$


    'a)ternate .uror num0er 1 )e(t the ,ourtroom/
    Ju!e" 0hat * "as going to say is maybe this person sits in the overflo" room$
    #r$ %utnam" 0hat * "as noting, your honor, is "e#ve been 4uite concerned about this !ust generally because they bring
    placards and t-shirts and stand up --
    (alternate !uror number 7 entered the courtroom)
    Ju!e" Hello$ 5ell us "hat happened about this person "ho approached you$
    A)ternate .uror num0er D" (kay$ *t "as after the break -- yeah, it "as after the break$ 0e "ere by "here the -- like the
    payphone kind of things are$
    Ju!e" ,ou mean you and alternate number 2?
    A)ternate .uror num0er D" Juror number 7: ,es, me and the other !uror "ere by "here the payphones are, little rooms
    "ith the pay phones$
    Ju!e" (n this floor?
    A)ternate .uror num0er D" ,es$ +nd in front of the elevator area, there "as that person "ho * had seen before over here
    by the benches$ &he !ust kept kind of staring and staring$ * noticed she kept looking to"ards "here "e "ere at$ +nd then
    she comes up and asks, Bare you guys the !urors --B no$ &he says, B* kno" you guys are the !urors for the Michael
    Jackson$B and * !ust looked at the floor, * didn#t say anything$ &he goes, B"ell, * kno" you guys are8 and * need to tell you
    guys something$B so at that point, * !ust -- * started to "alk a"ay, like * didn#t even address it, * !ust started to "alk a"ay$
    +nd she continued to talk at that point, the other !uror addressed and said, Byou#re not supposed to be talking to us$B * !ust
    continued to "alk to"ards "here "e all "ent up in the corner right there, and noticed she continued talking, saying
    something about -- * heard the "ord BfriendsB and BcourtB -- or BfriendsB and Bcase$B * overheard her say those t"o "ords$
    +nd she mentioned, Bplease don#t give anyone any money$B at that point, * !ust "alked a"ay and sat in the benches$ *
    looked around for Aeronica or anybody else, * didn#t see anybody$ +nd * guess she kind of got the hint at that point,
    because she "ent and stood in front of the elevators$ +nd that "as pretty much it$ +s soon as "e sa" Aeronica, that#s
    "hen "e "ent and approached her and told her "hat happened$
    Ju!e" (kay$ /o you see that person in the courtroom?
    A)ternate .uror num0er D" o, * don#t$
    Ju!e" /o you think you could recogniFe that person if that person "as in the courtroom?
    A)ternate .uror num0er D" * think * "ould$ &he "as "earing red pants, light-skinned, thin$ * "ant to say she had either a
    bo" or a bandanna or something "rapped in her hair, but * don#t think * see her$
    Ju!e" (kay$ &o if you see that person again, "ould you let us kno"?
    A)ternate .uror num0er D" ,es, definitely$
    Ju!e" 5he other 4uestion * had is "hat you heard, is it possible for you to !ust disregard it?
    A)ternate .uror num0er D" 5hat#s "hy * "alked a"ay$ >ike * said, other than those t"o "ords she said, BfriendsB and
    Bcase,B or Bfriends in the case,B something like that, * "alked a"ay, * paid no attention to it and "alked a"ay$ *t seemed
    like a fan, it#s not somebody * had seen before$ *t didn#t look like a reporter$ Most of them carry something$ &he didn#t have
    anything, so she -- * !ust disregarded her$

    Ju!e" &o "hen * say put it out of your mind, * mean you "on#t let it affect any decisions in the case?
    A)ternate .uror num0er D" o, not at all$
    Ju!e" one of the decisions in the case?
    A)ternate .uror num0er D" o$
    Ju!e" 0on#t affect you?
    A)ternate .uror num0er D" ot at all$
    Ju!e" (kay$ /o the attorneys "ant to ask any 4uestions?
    #r$ %anish" 5he person, "ould you say like -- "as this -- "hat "as the race of the person?
    A)ternate .uror num0er D" Probably "hite$
    #r$ %anish" -aucasian?
    A)ternate .uror num0er D" Probably -aucasian$
    #r$ %anish" Ho" about the age? * kno" it#s hard to tell$ 1allpark?
    A)ternate .uror num0er D" My age, perhaps$
    #r$ %anish" * can#t tell "hat you are, either$
    A)ternate .uror num0er D" 5hank you$ Mid 93#s, maybe$ &he "asn#t a young person, she "asn#t really an elder person$
    #r$ %anish" &o 93 to D3 "ould be your best estimate?
    A)ternate .uror num0er D" ,eah, 93 to D3$
    #r$ %anish" +nd ho" about the hair? 0hite? >ight? /ark?
    A)ternate .uror num0er D" * couldn#t tell you, "ith all honesty$ 1ut * do remember there being something in her hair like
    a bo" or bandanna or something$ 1ut hair color, i#m sorry, * couldn#t -- but *#d recogniFe her if * sa" her face"ise, * think$
    #s$ Ste00ins" /id you say you#d seen her before?
    A)ternate .uror num0er D" 5oday$
    #s$ Ste00ins" (h, !ust today?
    A)ternate .uror num0er D" ,eah, * had seen her "hen "e broke for lunch, * had -- * noticed her standing outside$
    #r$ %anish" 0as she sitting "ith anyone else?
    A)ternate .uror num0er D" o, * think she "as by herself$ * don#t remember anybody sitting ne't to her or talking to her$
    Ju!e" +ny more 4uestions? o$ (kay$ 5hank you, sir$ ,ou May go home$
    A)ternate .uror num0er D" (kay$ +nd =:93, you said, right?

    Ju!e" ,es$ Have a good "eekend$


    'a)ternate .uror num0er D )e(t the ,ourtroom/
    Ju!e" +ctually, "e can !ust ask Aeronica if she had seen the person before$ * haven#t spoken to Aeronica$ 0here is
    Aeronica?
    #r$ %anish" &he#s probably "ith the !urors$
    #r$ @oy)e" ,our honor, * sa" her, as "ell$ * sa" -- * didn#t kno" "hat "as said, but * sa" that interaction happen$ *t "as
    !ust -- * happened to be "alking by$ &o *#d never seen her before$
    Ju!e" ,ou#d never seen her before, first time?
    #r$ @oy)e" <ight$
    #s$ Ste00ins" /id you see "hat she looked like?
    #r$ @oy)e" )ind of like they described$ * couldn#t be that -- that -- but it "as kind of a strange interaction, and * !ust sa"
    that$
    Ju!e" Have you seen that person before, the person "ho "as talking to the !urors? 0as it the first time you#ve seen her?
    7he ,ourtroom assistant" * didn#t see her$
    Ju!e" * mean, before as in any other day$
    7he ,ourtroom assistant" * didn#t see today$
    #r$ %anish" o foundation$ Hearsay$
    Ju!e" /o you think she may be in the other room, the overflo" room, or something, maybe? 5he courtroom assistant: *
    tried calling the overflo" room, but they didn#t ans"er$
    #r$ %utnam" 5here must be some basis for her to say -- the second !uror said that, Byou#re a !uror in the case, aren#t you?B
    so she must recogniFe him from something$
    #r$ %anish" 0ell, ho" about the badge?
    #r$ %utnam" 5hat#s true$ 5hat#s true$
    #r$ %anish" 5hat#s normally -- that#s "hy they "ear the badges$
    Ju!e" (kay$
    #r$ %anish" 0e#ve got Mr$ 1oyle of our group$ *f he sees her, he#ll, you kno", corral her and get the people on her$
    Ju!e" (kay$ *s there anything else you think * should do at this point?
    #r$ %utnam" * "ant to think about it over the "eekend$ 1ecause "e#re "orried about there are lots of forms of
    communication, as you kno", people "earing placards and signs and everything else$
    Ju!e" * understand the concern8 and * discussed this, actually, "ith Judge 1uckley$ +nd the problem is that people have
    first amendment rights, and if they "ant to "ear t-shirts and have signs, you kno", there#s -- there#s -- *#m sure there#s
    limits to it, but, you kno", * -- t-shirts and things that are pretty innocuous, there#s nothing * can do about that$ * mean, if
    you have an idea, let me kno"$

    #r$ %utnam" * "ant to think about this because this takes it to another level, obviously$
    Ju!e" ,es$ *f they#re interfering "ith !urors, that#s another story$ 1ut * think like t-shirts and signs, you kno" --
    #r$ %anish" 5hat#s !ury tampering, so --
    Ju!e" +bsolutely$
    #r$ %anish" 5hat#s clearly a felony in this state$
    Ju!e" 5hat#s a problem$
    #r$ %utnam" ,es$
    #r$ %anish" &o that person committed a felony8 and, obviously, "e need to get to the bottom of that$ +nd, obviously,
    none of the parties "ant that to happen$
    Ju!e" o, no$ * agree$ 5hat#s a problem$ 1ut Mr$ Putnam "as raising issues about t-shirts and things like that$
    #r$ %anish" ,ou can#t do anything about that$
    #r$ %utnam" 5he other thing * "ant to think about is !ust their o"n safety$
    #r$ %anish" 0hose safety?
    #r$ %utnam" 5he !urors#$
    #r$ %anish" * don#t think there#s been any physical issues$
    Ju!e" (kay$
    #r$ @oy)e" * think those t"o guys could have taken her, from my observation$
    #r$ %anish" 5hey could have held their o"n, * think$
    Ju!e" (kay$ &o !ust "hat are "e doing on Monday?
    #r$ %anish" 5hat#s a good 4uestion$
    #s$ Ste00ins" Mr$ 5a! Jackson --
    #r$ %anish" * don#t kno" if he can come on Monday$
    #s$ Ste00ins" 1ecause he#s interrupted half"ay through$
    #r$ %anish" ,eah, he has been interrupted$ &o let me find -- * told him "e had 5uesday$ >et me find out$ 0e only have
    three days ne't "eek, right?
    Ju!e" ,es$
    #r$ %anish" 0e#re off on the Dth and 7th$ +ll right$
    Ju!e" 0ell, * kind of "anted to kno" "hat -- you don#t kno"?
    #r$ %anish" * kno" "ho#s coming on 5uesday$ *#m trying to get either --

    Ju!e" ,ou don#t kno" "ho#s coming on Monday?


    #r$ %anish" *#m trying to get 5a! to come back8 but if he can#t, *#m going to have to get somebody else$
    Ju!e" ,ou#ll definitely let the defendants kno", right?
    #r$ %anish" (f course$
    Ju!e" (kay$ &ee you at =:93 on Monday$
    #r$ %utnam" 5hank you, your honor$
    ',ourt a.ourne to #onay- Ju)y 1- 2013- at >"30 am/

    Exhibit 865 - 1

    Exhibit 865 - 2

    Exhibit 865 - 3

    Exhibit 865 - 4

    Exhibit 865 - 5

    Exhibit 865 - 6

    Exhibit 865 - 7

    Exhibit 865 - 8

    Exhibit 865 - 9

    Exhibit 865 - 10

    Exhibit 865 - 11

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