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JACKSON V AEG LIVE June 28

th

2013

JACKSON V AEG LIVE June 28 th 2013 Karen Faye testimony (Michael Jacksons Make-up Hair) Judge:

Karen Faye testimony

(Michael Jacksons Make-up Hair)

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:

previously sworn and testified as follows

OK. Ms. Faye, would you come forward? Karen Faye, recalled as a witness by the plaintiffs, was

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

read your transcript of what you said at trial?

for example, did you

A.

Yes.

Q.

You did? When did you do that?

A.

Just periodically over different times, sir. I can't tell you exactly what dates they were. It's kind of like in

between work and stuff when I had a chance to glance over that.

Q.

How did you get that?

A.

How did I get that? You guys sent me a copy.

Q.

No, I didn't.

A.

You sent

your company or something sent me copies of it. Yeah, you did.

Q.

This trial?

A.

Oh, not the trial. I thought you meant the deposition. I'm sorry. I totally misunderstood you.

Q.

That's OK.

A.

So it's a deposition that I was looking over.

Q.

So over the last seven weeks, you went back to look at your deposition testimony?

A.

Yes. Yes, I did.

Q.

And how many days were you deposed for?

A.

I think I was deposed with you for four or five days, I think. And then I think I talked to the plaintiffs for,

like, I think, one day.

Q.

And so you had about five or six days of deposition?

A.

That's a pretty good estimate, yes, sir.

Q.

And it was those transcripts you went back to look at in the last seven weeks?

A.

Yeah.

Q.

But you didn't look at what you said in the courtroom over the last seven weeks?

A.

No. I did not look at that.

Q.

Did you go back to look at any exhibits or anything over the last seven weeks?

A.

Oh. My phone's not off. Can I turn that off?

Q.

Of course.

A.

It just whistled at me. (turned off cell phone.) OK. I'm sorry.

Q.

Better now than later.

A.

Can you ask me that question again?

Q.

Yes, I can. In terms of the last seven weeks, I'm trying to see how

what you did to prepare so I have

some sense of how much I have to go through. Did you go back to look at any of the exhibits in the last seven

weeks?

A.

The exhibits of what was shown in court?

Q.

Yes, ma'am.

A.

No.

Q.

No? So what about meeting with plaintiffs' counsel? Did you meet with them in the last seven weeks or

talk on the phone?

A.

I briefly met with them today.

Q.

That's all? So we may have to do a little more of what occurred. We'll see. Do you remember where we

left off last time?

A.

I don't, sir.

Q.

OK. We were trying to go chronologically through your relationship with Mr. Jackson.

A.

OK.

Q.

It was June 2005; all right? The criminal trial, you had been there every day, arriving around 3:00 in the

morning, washing his hair, prayed, cried. You remember?

A.

Yes.

Q.

And he got acquitted, and you were in the hotel. That's how you heard about it. You didn't talk to Mr.

Jackson, didn't see him again, didn't speak with him, and he left the country. You remember that?

A.

Correct. No. I did speak with him on the phone.

Q.

You did?

A.

He called me a few times, probably about every three or four months. He would call me or send me a

present on the holidays or things like that in between that period of time.

Q. That's what we're getting to.

A. Oh, I'm sorry. Because you said I didn't have anything

and I did, so

I didn't talk to him between that period of time,

Q.

I was actually

A.

I was correcting that.

Q.

I was still in June 2005.

A.

OK. June. OK.

Q.

So you hear he was acquitted?

A.

Correct.

Q.

You don't talk to him at that time. He leaves the country?

A.

I didn't talk to him that day.

Q.

He leaves the country?

A.

Uh-huh.

Q.

And so you believe he left right away; correct?

A.

To my knowledge, he left pretty soon after that.

Q. Right. And you didn't talk to him between the time he was acquitted, while you were there, until the time

he left; right?

A.

Correct.

Q.

And, again, this is June 2005. Now, did that upset you in any way? That you had been there every day

helping him, but he gets acquitted, but he doesn't call you or talk to you but just leaves the country?

A.

It didn't upset me, no, sir.

Q.

Why is that?

A.

He had been through a horrible, horrible ordeal, and I was by his side. And to me, whatever he had to do

to recover from that was fine. He had said all his thank yous all along the way, you know, and was appreciative

of everything that I did when we were together during that time. So I really understood that he wanted to leave,

so I didn't feel bad. He needed to be with his family. He needed to spend time with his children. I thought that

was far more important. And I

towards what I did.

frankly, I just didn't feel that I needed to be thanked or any kind of gratitude

Q.

So it didn't upset you?

A.

No.

Q.

And he leaves the country. Do you know if he ever returned to Neverland after that?

A.

As far as I know, he never did.

Q.

And did you ever return to Neverland after that?

A.

No.

Q.

And you didn't see him again until April of 2009; correct?

A.

March, April

I think that's about right.

Q.

So when he moved back to Los Angeles in late 2008, you didn't see him then?

A.

Back in April

no. No, sir.

Q.

And when he moved into Carolwood at that time, you didn't go over to Carolwood and see him at the

time, correct, in late 2008?

A.

No, sir.

Q.

The first time you saw him was April 2009?

A.

Correct.

Q.

And

but he had returned to the states before then. In fact, he returned to the states in 2006; right?

A.

I don't know.

Q. You don't know?

A. No. I wasn't keeping track of where Michael was, really. I mean, it's, like, I have a life, you know, and he

has a life, and my life didn't

but, like, I have a child, I have a family, I have work. So I wasn't, like

newspaper and stuff, but that's about it. I didn't make an effort to go see him or anything. I mean, he called me, I

think, from Las Vegas and said, "we have some projects I want you to be involved in," and stuff. And I said,

"great. Just call me when you're ready" kind of a thing.

doesn't revolve

didn't revolve around him. He was a big part of it, of course,

you know, I would read things in the

Q. You said you talked to him every three months; right?

A. That's an estimate. I couldn't be exact on

Maybe five months went by. So that's just a guesstimate, sir.

you know, I would say about three, four months, you know.

Q.

The last time you were here, you told us you were like a brother and sister; right?

A.

I felt that that's what our relationship was like.

Q.

Now, in these times that he called you from Vegas and asked you if you could work on projects with him,

did any of those projects come to be? Did you ever come to work with him during that time period?

A.

Well, "This Is It" came up.

Q.

So you did eventually in 2009; correct?

A.

Uh-huh.

Q.

Let's talk about that. So it's 2009. How did you come to learn that the "This Is It" tour was being put

together?

A.

I saw it on television.

Q.

And whose program did you see?

A.

It was on the news.

Q.

Were you surprised?

A.

No. I can't say I was surprised.

Q.

Why not?

A.

Huh?

Q.

Why not?

A.

Because he told me there were projects coming up, and this, evidently, was one of them.

Q.

So he hadn't told you about it prior to you hearing it on the news; right?

A.

No, sir.

Q.

And did you hear from Mr. Jackson sometime after that announcement?

A.

Yes, sir.

Q.

How soon after the announcement?

A.

I don't remember the

I don't recall the exact amount of time that passed. I would say within two weeks,

three weeks, perhaps.

Q.

So if the announcement was on March 5th, 2009

A.

March 5th? OK.

Q.

you think sometime then?

A.

Probably around the middle of the month, I would say.

Q.

So mid March. And tell me about that. How did you hear from him?

A.

Well, the first person to call me was Michael Amir.

Q.

And who did you understand Michael Amir to be?

A.

Well, I didn't know at the time he called me, but he explained that he was Michael Jackson's assistant, and

Michael would like to speak to me regarding

would like to personally call me.

he would like to work with me on the "This Is It" tour, and he

Q. So some of those phone calls that you were receiving in the intervening four years when you were

speaking with Mr. Jackson, how did those phone calls come about?

A.

He called me directly. It was just him directly on the phone.

Q.

So in the

between 2005 and March 2009, when you heard from Mr. Jackson, you heard from him

directly?

A.

Yes, sir.

Q.

But this time you heard from Michael Amir Williams?

A.

Correct.

Q.

Did that surprise you?

A.

No.

Q.

Why not?

A.

Why not?

Q.

Well, you've been hearing from him directly every three months for the four years, and suddenly you get a

call from Michael Amir Williams.

A. Well, Michael explained that Michael's phone that he was calling from would be a blocked number, and so

it would

Michael would be calling me directly from

A. Blocked number, so to be sure to pick it up. So I guess it didn't strike me as weird that a personal assistant

would let me know he would be calling, and please pick up a blocked number.

Q.

But that's not how it occurred for the prior three years; right?

A.

No.

Q.

And you said he called you

did he tell you anything else? When Michael Amir called, did he say

anything else about the tour, what was happening?

A. No. He didn't give me too much information, other than Michael would be calling me. He would be

calling me from a blocked number, be sure to pick it up, and that it was about working with him on the tour.

Q.

And did a time come when Mr. Jackson then called you directly?

A.

Yes.

Q.

And how soon thereafter did that happen?

A.

To be very honest, I can't recall, but it was soon thereafter. I don't know if it was that day or the next day. I

really don't recall.

Q.

But he did call directly, then?

A.

Yes. From a blocked number, sir.

Q.

And what happened in that phone conversation?

A.

OK. I was lying in my bed, and a blocked call came in, and I said, "ah, that's probably Michael." it was

really happy and light. It was like, "oh, my gosh. I see you're doing a concert," you know. And he goes, "yeah."

and

saying, like, "I want to work with you." and, like, when I'm doing his makeup, it was, "work with me, Turkle."

he said that to me. "work with me, Turkle." so it was just fun and kind of laughed and chuckled. And I think I

said

he used to always use the phrase, "work with me, Turkle. Work with me, Turkle." you know, because he's

I mentioned during that conversation I was really excited for him. I said, "I see you're doing a lot of

shows." and he said, "yeah." he goes

he said, "I thought I was only going to do 10, but it looks like

I don't

know how I woke up, and now I'm doing 50." I said, "well, then, you know, that's a lot." and he goes

he was

kind of a little discouraged about the number, and I was a little apprehensive about it, too. But, I mean, we didn't

dwell on that whatsoever. You know, he was, like, "yeah, we got to do this." I said, "we got to get your hair

together, and we got to start working really fast," you know. He goes, "OK." and that was about it. We were just

bantering back and forth because it was nice to hear his voice, of course.

Q. Now, in those five to six days of deposition transcripts that you reviewed, do you remember ever telling

about that part of the conversation before? About the idea that you had talked about the 50 and the 10 shows,

and he was concerned?

A. Well, there was a lot

(indicating). Do I recall saying that in that particular

you know how thick those depositions were? They were, like, this thick

I don't recall, sir.

Q. You don't? Is it possible this is the first time that you've testified under oath that that part of the

conversation ever took place?

Mr. Panish:

calls for speculation.

Judge:

overruled.

A. sir, I told you. I don't really recall. I know that was a part of one of our conversations. I'm really not sure if

it was in that very first conversation I had, sir.

Q.

let's talk about the scheduling of shows. So it's March 5th

I'm sorry. Mid March

A.

OK, sir.

Q.

2009. You had this conversation with Mr. Jackson. Do you tell him at that time that you'll go work for him

on the tour?

A.

Yes.

Q.

So he asked you to work on the tour, and you said, "yes"?

A.

Yes.

Q.

Did he tell you when it was starting?

A.

No, sir.

Q.

Did he tell you where it was going to be located?

A.

I don't know if

I can't recall if he told me. It was all over the news, so it was something that I would have

known.

Q. The press conference. Did you see the press conference?

A. I remember seeing the media "bus" thing, where the media was flying over his bus. I don't think I actually

saw the announcement live. I saw it in retrospect, in it being played on the news, and things like that. But I don't

think I saw it at the time. I saw the helicopters, you know, and the buses, and all the expectation of Michael

going to it, but I think maybe I had to work and couldn't watch the rest of it, so I can't really be sure that I saw it

at that time that it was happening.

Q.

But a time came when you saw it either then or on the news?

A.

Yeah. It was on the news.

Q.

How did you think he looked?

A.

OK.

Q.

Were you concerned when you saw him? You hadn't seen him in four years. Did he look bad to you?

A.

No. I just thought he had a really bad hairpiece on, sir. But I have to explain that that's what I do, so those

are the things that I notice about everybody, is, like, their personal appearance, their hair, their makeup. And,

you know, it's just, like, an unconscious thing. I'll go to a restaurant and say, "oh, I wouldn't wear my eye

makeup like that." and I just noticed his wig was so big. So that was what I noticed most of all.

Q. A bad hairpiece. Otherwise, how did he look to you?

A. You have to

ago. How did I think he looked? The only thing that I can recall is, like, the hairpiece, sir. And I thought his

behavior was a little odd. I think he was

I'm trying to go back to that point when I first saw him, because, like, it was a long time

but not out of the ordinary.

Q.

Now, after that, a time came that you actually ended up seeing Mr. Jackson live; right?

A.

Yeah.

Q.

In person? But that didn't happen until April; correct?

A.

I think it was like around the beginning of April

Judge:

Juror no. 7, are you OK?

Mr. Panish:

why don't we take a quick break?

Judge:

10 minutes. (the jury exited the courtroom at 10:37 a.m.)

Judge:

I don't know what's going on, but 10 minutes. You can step down if you like or

Ms Faye: where am I going to go?

Mr. Putnam:

it's cooler outside.

Judge:

the juror is better. (the jury entered the courtroom at 10:47 a.m.)

Judge:

Juror no. 7, how are you doing? Juror no. 7: I'm OK. Sorry about that.

Judge:

can you make it until lunch? Juror no. 7: yes. I took some painkillers.

Judge:

OK. So let me know if there's anything else I can do. Juror no. 7: all right.

Judge:

if it's too painful or your brain gets foggy, let me know. We're going to be here for a while

we've

been here for a while, and we're going to be here for a while. Half a day doesn't make much difference.

Mr. Putnam:

may I approach, your honor?

A. now, during that little break, I kind of recalled something. You asked me if I reviewed anything about the

case in between. You remember when I was sick and couldn't make it here? I had

and I found some texts relating to this

I found my old phone, sir,

the period of a couple weeks around Michael's death, sir.

Q. By Mr. Putnam: are these texts that

you were deposed in two different cases related to this; right?

A. Um, I was deposed for Lloyds, and I was deposed at the same time for you

subpoena at the same time I was there for Lloyds for this case.

you actually handed me a

Q. And those subpoenas asked you to hand over documents that related to Mr. Jackson's time period; correct?

A.

Correct.

Q.

As well as texts and phone messages?

A.

Correct.

Q.

But you didn't hand those over to us; right?

A.

I had no idea I still had the phone, sir.

Q.

But since you've testified, you've now found those texts?

A.

When I was sick, sir, I was looking, because I was trying to remember stuff and dates and

yes, sir.

Q.

Did it help you remember stuff now?

A.

It helped me clarify some dates, sir.

Q.

And did you turn those texts over?

A.

I gave them to….

Q.

To whom?

A.

To plaintiffs, sir.

Q.

Did you give them to the people who asked for them in the actual subpoenas that you were given?

A.

No, sir.

Q.

No? So you didn't hand them to them. You found them and gave them over to plaintiffs?

A.

(no audible response.)

Q.

Did we receive those?

A.

I don't know, sir.

Q.

Did you ask them to give them to us?

Mr. Putnam:

I guess we're getting them now.

Mr. Panish:

better now than never.

A. when did I

Judge:

when did you give them to them?

A. just recently.

Judge:

just now?

A.

yeah. I mean, like, today.

Q.

By Mr. Putnam: you gave them to them today?

Judge:

OK. All right.

Q. By Mr. Putnam: is that what you're saying? You gave them to them today?

A. Yeah. This morning.

Mr. Putnam:

we can look at those at the break so I can try to prepare.

Q. going forward, ma'am, did you find anything else?

A. Did I find anything else? I mean, I was going through my drawers, sir, so nothing pertaining to this case. I

found some kind of sexy things between my boyfriend and I.

Q. Do you think this is funny?

A. You asked me, sir, and I told you what I found. But do I think it's funny? I don't think this case, sir, is

funny at all.

Q.

Going back to where we were, ma'am, when did you let plaintiffs' counsel know that you found these

texts?

A.

I let them know last night, and I gave them to them this morning, sir.

 

Q.

And when did you find them? When you were sick? How long ago was that?

A.

Couple weeks ago, sir.

Q.

Did you let anybody know you found these a couple weeks ago?

 

A.

No, sir. I think I told my boyfriend that I found

because I was

you keep asking me things about dates,

and I found that

I'm trying to remember. And so those things were trying

I was trying to refresh my memory

about things, sir.

Q. You had a conversation with Mr. Jackson sometime in mid March 2009 about the idea of coming back

and working with him and going on tour; correct?

A.

Correct.

Q.

And then you agreed to go on tour with him; correct?

A.

Correct.

Q.

And there was a conversation about how many shows, the 10 versus the 50; correct?

A.

I had a conversation with him. I can't be sure if it was in the very first conversation that I had with him.

But there was a conversation regarding waking up, and it was, like, "it started off as 10 shows, and I woke up,

and now it's 50." it was pretty lighthearted.

Q.

So a lighthearted conversation about how many shows?

A.

Yes.

Q.

And then you ended up seeing Mr. Jackson for the first time in four years in the beginning of April 2009?

A.

Yes.

Q.

And before you had seen him, you actually started doing some research about the number of shows, what

the schedule was, and the like?

A. It was soon after the first conversation. I felt that I was going to be a part of this, so I went online, and I

saw a schedule.

Q.

You saw a schedule?

A.

Like the tour dates.

Q.

And so this

this is something you did before you had yet seen Mr. Jackson; correct?

A.

Yes.

Q.

And as a result of seeing that schedule, you were concerned about the number of shows, and how the

schedule was created; correct?

A.

I was concerned at how close the shows were together, sir.

Q.

And in fact, you reached out to Kenny Ortega as a result of that concern, didn't you?

A.

I reached out to him, and I reached out to Michael.

Q.

And how is it that you knew that Kenny Ortega was involved in the show at that point?

A.

How did I know? I can't really recall how I knew, sir.

Q.

OK.

A.

But I did know because I called him.

Q.

OK. And but at this point in time, you were concerned, because you didn't think Michael would last a

week with that kind of schedule; right?

A. I don't know if that was my exact words, that "he wouldn't last a week." I mean, I know how he

he needs to recuperate after a show, and I didn't know if he could continue very long with that schedule because

there wasn't enough time to recuperate. I think I might have said something like, "he might make the first week,

but it was going to go downhill after that." you know, I felt that the schedule was too difficult for him to

the time

maintain. To be

to try to answer your question, I don't remember if I said a week or how I really explained

that.

Q.

But you did reach out to Kenny Ortega, and you reached out to him because you were concerned?

A.

Yes, sir.

Q.

And you were concerned about Mr. Jackson's ability to actually do the tour; correct?

A.

Well, do the schedule that was on the web site.

Q.

And at this point you hadn't even seen Mr. Jackson; right?

A.

Correct, sir.

Q.

You hadn't seen him in four years?

A.

Correct, sir.

Q.

At this point did you have an understanding that the tour would take place in one location: London?

A.

Yes, sir.

Q.

And you had never been with Mr. Jackson before where he did a residency, had you?

A.

I've been in places where he's been there several weeks, but not a residency.

Q.

And did you understand at this point when you talked to Mr. Ortega that this was going to stay in one

location for 50 shows?

A.

I'm pretty sure I understood that.

Q.

Did you understand at that point in time that there was going to be a three-and-a-half-month break in the

middle?

A. I don't know that I knew that at that time. I'm not sure when I realized that. But when I was looking at the

schedule and had that conversation with Kenny, I cannot recall if I knew there was going to be a three-month

break.

Q. You said you went online to look at the schedules

A. I just looked at the first

that's what I saw.

top, sir. The first, like

I didn't scroll the whole page. I just saw those dates, and

Q. So you hadn't seen him in four years, you saw some of the dates, and you called Mr. Ortega and said, "this

is a problem"?

A. I said, "it could possibly be a problem." I didn't say definitively that, you know, that it was going to be a

problem. I said, "this should be something we should consider and look at."

Q. And you had already agreed you were going to be the hair and makeup person for Mr. Jackson; correct?

A. Correct.

Mr. Putnam:

Judge:

yes.

could I show exhibit 13,402? This was already entered. May I approach, your honor?

Q. By Mr. Putnam: give you a hard one

A. this isn't what I saw.

Judge:

can you pass that one down?

A. oh, to you? I'm sorry.

Judge:

thank you.

Mr. Panish:

you're saying this is on the web site?

Mr. Putnam:

no, I didn't say that.

Mr. Panish:

oh, OK.

Q. so, Ms. Faye, there's been testimony that this was the schedule of shows. I want to show you something.

You see, it has

three months again. You see that?

there's never two in a row. Three months of shows, then there's three months off, and then

A.

I see that.

Q.

So what was it that concerned you?

 

A.

Well, this is

first, isn't what I saw.

Q.

OK.

A.

OK. What I saw was a list; OK?

 

Q.

Of just dates?

A.

Of dates. And what I saw was, like, at the time was like

there was a date, off, date, date, off. You know,

it was closer together than this, sir, what I remember seeing. Because I remember seeing two dates in a row in

places.

Q. I will represent to you that there's testimony that I think there was

original schedule

five shows were moved from the

A.

Correct.

Q.

to the end so that it started slightly later.

A.

OK.

Q.

So you may have seen the schedule

but without any two in a row. You saw two in a row?

A.

I thought I did, sir.

Q.

Do you recall exactly what you told Mr. Ortega?

A.

Do I remember exactly what I told Mr. Ortega? No, sir, I don't remember exactly what I told him.

Q.

Do you remember generally what you told Mr. Ortega?

A.

Just what I told you just right now.

Q.

All right.

A.

That I thought that the dates weren't really

I thought Michael would need more time to recuperate. I

think they should really look at that and consider doing something that might be a little easier on him. It was in

that

it's not exact words. It's to that.

Q.

OK. I'd like to show you an exhibit that has been entered and that has been testified to extensively. It's

exhibit 130-1, and it's a series of e-mails between Paul Gongaware and Randy Phillips. You know who they are;

right?

A.

Correct.

Q.

As well as Kenny Ortega. And there's reference to a phone conversation in it that supposedly happened

with you. And I want to find out if this is the conversation that they're talking about; all right?

Mr. Panish:

has she seen this before?

Mr. Putnam:

I don't know if she's seen this before. Because she's been tweeting about it. But I don't know if

she's

Mr. Panish: first of all, I object to the comment.

A. sir, I haven't seen any exhibits

Judge:

wait. Hold on. First of all

there's an objection.

Mr. Panish:

refresh her recollection, that's fine, but, I mean, we need some consistency.

counsel has been objecting to showing e-mails to people not on the e-mail. If he wants to try to

Mr. Putnam:

anyway even if a person wasn't on it. If they could talk about something, they could testify to it. And in fact,

this very e-mail, people have been asked about even if they're not on the chain. And I would like to do it with

and in terms of consistency, I have made those objections, and you've allowed them to go in

her.

Judge:

you're saying that a conversation concerning her or with her is on the chain?

Mr. Putnam:

yes.

Judge:

all right. You may.

Mr. Putnam:

may I approach, your honor?

Judge:

you may.

A. thank you.

Judge:

but it's in evidence already; right?

Mr. Putnam:

Mr. Panish:

yes.

that's fine, as long as we can do that.

A. so this is from

Judge:

chance to look at it.

hold it. We haven't looked at it. Give us a chance to look at it. You can read it yourself, but give us a

Q.

By Mr. Putnam: so, as I was noting for you, this is a series of e-mails.

A.

OK.

Q.

And you'll see at the bottom, it starts with an e-mail to Mr. Ortega.

A.

From Kenny Ortega

Q.

To Paul Gongaware

A.

Uh-huh.

Q.

and John Houghdahl's.

A.

OK.

Q.

And, see, that's on the 25th of March?

A.

Correct.

Q.

And below it goes through

it talks about several conversations. Said: "I received a few calls"

Judge:

are we going to put this up?

Mr. Putnam:

yeah.

A. I have it in my hand. I haven't read the whole thing because everybody is talking.

Mr. Putnam:

sorry.

A.

go ahead. I'll go on as you go through it.

Q.

By Mr. Putnam: just so you know what I'm going to ask, as you get to the bottom of that first page, as it

goes on to the second page, it says: "Karen Faye, MJ's personal makeup artist." you see that? And goes on to the

next page, talking about a conversation that he says that he had with you.

A. "she was thrilled that we would all be working together again and would make herself available to me to

discuss the show." OK. I read the paragraph regarding me. I didn't read anything else. OK.

Q. So you see there, it talks about the idea that on the 25th of March

A.

Uh-huh.

Q.

says: "Karen Faye called to check in and confirm that MJ had reached out to her regarding the show.

She was thrilled that we would all be working together again and would make herself available to me to discuss

the show plan at any time. She also mentioned that she read online the tickets were being sold for every other

day."

A.

I made

I didn't say anything about tickets. I said I went online, like I said to you, and saw that the shows

were very close together, yes.

Q. You commented rather heavily with respect to this?

A. It was a concern of mine. I mean, I don't know what you mean by "heavily." I just thought it was

something that I should address in the very beginning to alert people, if they want this to be the best success for

everybody, that this should be something that they look at, sir.

Q.

It says: "it's her strong opinion that this is dangerous."

A.

No. I mean, like, this is his words, not mine. This is what he's saying.

Q.

That's why I'm asking you, ma'am.

A.

I didn't say it was dangerous. I said it

I mean, how can it be dangerous at this particular point? That's

ridiculous.

Q.

That's why I was asking.

A.

I said it wasn't the best schedule for Michael to be successful.

Q.

That's why I'm asking, ma'am, because a number of people have been asked

A.

Uh-huh.

Q.

whether they were aware as of this date

A.

Uh-huh.

Q.

of the fact that it was dangerous and impractical because of this e-mail, so that's why I'm asking you

what you said.

Mr. Panish:

I'm going to object.

A. I didn't write the e-mail, sir.

Mr. Panish:

improper. And his response when I make an objection

I'm going to object to counsel's characterization of what was said. It misstates testimony and is

it's an improper question to this witness

Judge:

OK.

Mr. Panish:

representing things like that.

Judge:

OK. Sustained.

Q. By Mr. Putnam: so you didn't say it was dangerous?

A. I can't recall saying it was dangerous, sir. I just thought that in order to be successful, they should revisit

the schedule. Because I've been on tour with Michael before.

Q. OK. And going on, did you say it was "impractical with consideration to MJ's health"?

A. No. I had no

time. I mean, this is, what, like March?

I mean, this is really weird, because I had no concept of Michael's health at this particular

Q. Right. You hadn't even seen him yet; right?

A. No. My concern was just that the schedule, according to other tours that I've been on, that it's difficult, and

he needed, you know, recuperate

more recuperation than what I saw on the original web site. I didn't

there's

no way I would have said "dangerous" or "impractical" or

I mean, "dangerous"? No. I didn't say

I didn't use

those words, sir.

Q. So this is not correct?

 

A. Not how

I mean, the concept that I did call and express my concern and think that Michael

wasn't the

best schedule for Michael to be able to maintain to do 50 shows. But not "dangerous" and "impractical" and "a

consideration to Michael's health and ability to perform." I had no concept of Michael's ability at this time, so I

wouldn't have said that.

Q. OK. And it then goes on to say: "in the past (10 to 12 years ago) Karen would often speak on his behalf

with regard to these kinds of issues."

A.

I don't know what he's referring to there.

Q.

You don't?

A.

I mean, I was always protective of Michael and his well-being. And in the past 10 or 12 years ago, I would

speak on his behalf with regards to these kinds of issues. I really don't know what he's referring to exactly, but I

was always concerned with Michael's well-being. And when it was

something that could help Michael, I did speak out. But what exactly they're referring to here, I do not know.

when I saw that there may be a problem or

Q.

OK. You do recall our talking last time, right, about your being asked to not continue on the "history"

tour?

A.

Say that

just restate the question.

Q.

Absolutely. You remember our talking last time

A.

Uh-huh.

Q.

about you being asked to not continue on with the "history" tour?

A.

Correct.

Q.

And didn't we talk about the idea that some believed it was because of your speaking out on his behalf

with regards to these kinds of issues?

A.

What's the last part of the question?

Q.

Wasn't it

did we not discuss

A.

Uh-huh.

Q.

the idea some thought it was better for you not to continue at that time because of this very fact; that you

would speak out on his behalf with regard to these kinds of issues?

A.

I had no knowledge of why they didn't bring me along.

Q.

But you did have a conversation with Mr. Ortega at this time; correct?

A.

Yes.

Q.

And it was a concern about the schedule?

A.

Correct.

Q.

And you indicated a moment ago that you also reached out to Mr. Jackson

A.

I did.

Q.

about this? Why did you reach out to Mr. Jackson about this?

A.

Because I think that he didn't know how the schedule was; that I said it would be really smart

that he

should go and look at the schedule and see, you know, how it's scheduled. And if

he was feeling uncomfortable about it, he should say something about it.

how he feels about it, and if

Q.

OK.

A.

And his response was, "that's funny. My mother said the same thing."

Q.

Now

A.

But he had not, I think, seen the structure.

Q.

So you think that at this point in time in March, that Mr. Jackson was unaware of what his schedule might

be in London?

A. Well, I don't

how it was structured; that he just had to do 50 dates. And I don't think he was

when I told him that, "have you seen the schedule? You should see it." and he goes, "no, I haven't." I just

wanted him to make sure that he knew how it was scheduled, to see if he was comfortable with it. And he said

his response was, "my mother told me the same thing." so

by the conversation I had with him, he didn't seem like he knew, like, how many days, and

he didn't seem to be aware

Q. Is it true that you reached out to Mr. Jackson because you believed that he was the one who was

responsible for having to do the shows?

A. Huh?

Q.

Just what I said.

A.

What? Did I reach out to Michael?

Q.

Mr. Jackson, uh-huh.

A.

Because he was the main performer, sir.

Q.

Uh-huh. And he would also be the one responsible if he couldn't do the shows; correct?

A.

Correct. It would be his responsibility, sir.

Q.

And isn't that the reason you reached out to him, because you knew it would be him who was responsible

if he couldn't do the shows?

A.

Say that one more time. Would it

Q.

Did you reach out to him because you believed he was the person who was going to be responsible if he

couldn't do these shows?

A.

It would come down on him, sir, because he was the star.

Q.

I understand that. My question is: is that the reason you reached out to him?

A.

Yeah. I think so. I mean, it seems logical, with your statement, that if he couldn't do the shows, and he

could not make a show, or if he got tired, that

you know, he's the performer. It's his name up there.

Q. And so you wanted to make sure that he understood what the schedule was and your concern that that

might be difficult for him?

A.

Yes. I was concerned, sir.

Q.

Now, how we got off on this is, we were talking about, you said you had this conversation at the time

when you spoke with Mr. Jackson in March of 2009 about the scheduling, remember, and we were talking

about your first contact?

A.

Uh-huh.

Q.

And a time came after this, after you spoke with Mr. Ortega on the 25th of March, where you actually saw

Mr. Jackson; correct?

A.

Correct.

Q.

And that was the beginning of April. Where did you see him?

A.

At Carolwood.

Q.

And did you go by yourself?

A.

No, sir.

Q.

Who did you go with?

A.

Stuart Artingstall.

Q.

Who is he?

A.

He is my wig maker.

Q.

And you thought some new wigs might be in order?

A.

Some what?

Q.

Some new wigs might be in order?

A.

Sir, we needed to prepare for the show, sir.

Q.

And then a time came, also, where, after that

after you were meeting with Mr. Jackson, you ultimately

started negotiating for a contract with AEG correct?

A.

Yes.

Q.

And ultimately you entered into a contract with AEG is that right?

A.

Correct.

Q.

And you weren't paid by AEG Before you signed that contract, were you?

A.

Um, no, sir. Well

no. No, I personally was not paid. I needed to get some funds to start creating the

hairpieces for Michael, sir, and I was informed by Evvy to contact Dr. Tohme.

Q. So you needed some funds in advance before you had contracted with AEG, and you talked to Evvy. Who

is Evvy?

A.

Evvy was Michael's assistant that resides here, sir. That resides in Los Angeles, sir.

Q.

Do you know her whole name?

A.

Evvy Tavasci.

Q.

Tavasci. So you reached out to Ms. Tavasci to find out who to speak to about getting funds, and she told

you to go speak to who, Dr. Tohme?

A.

Yes.

Q.

And did you know Ms. Tavasci because she had worked for Mr. Jackson previously?

A.

Yes, sir.

Q.

Approximately how long?

A.

A long time.

Q.

So she was someone you had spoken to before?

A.

Yes, sir.

Q.

And that's why you spoke to her?

A.

Yes.

Q.

Did you hear about Dr. Tohme before?

A.

No.

Q.

Did you actually reach out to Dr. Tohme and seek funds?

A.

Yes. She gave me his phone number, and I called and left a message. He did not pick up, sir.

Q.

And was this before or after you first saw Mr. Jackson in April of 2009? Do you know?

A.

I can't really recall, sir.

Q.

OK. Now, before you started negotiating this contract, do you remember saying

I've asked you if you

had any concerns when you first spoke to Mr. Jackson. And do you recall at all telling me that, yes, you had a

concern about someone named Raymone Bain and Grace Rwaramba?

A.

Yes.

Q.

So when one of your first concerns in that conversation

I'm sorry. When you first thought of that

conversation was after Michael Amir Williams or after you spoke to Michael himself?

A.

OK. I'm confused, OK? Try to make it really clear here so I can answer your question.

Q.

No, please. That was my fault. Terrible question. Last time, I said: "Did you have any concerns at the time

when Michael first contacted you about the concert tours?" and you said: "Yes, I did. I had a problem with

Raymone Bain and Grace Rwaramba"

A.

Correct.

Q.

"because I knew they didn't like me and pretty much responsible for me not being around for four

years." you remember saying that?

A.

Correct.

Q.

And why did you say that, ma'am?

A.

Because that was my understanding at that time, sir.

Q.

And what was your understanding?

A.

That they didn't like me.

Q.

And who was Ms. Bain?

A.

She was

at first she was brought in as a publicist, sir.

Q.

Had you ever met her?

A.

Have I met her? Yes, I've met her.

Q.

Had you met her at that time?

A.

At what time?

Q.

At the time of that conversation in March of 2009.

A.

Oh, yes. I've known her for a while, sir.

Q.

All right. And what was the basis of your belief that she didn't like you?

 

A.

Probably kind of during the trial. You know, they were

I'm just trying to think of details here to

you

know, well, Grace kind of goes back quite a while. I felt that she

loved Grace, you know, when I first met her. She was really

way back when she worked at Michael's office, and I was really happy when Michael used her as the nanny. But

I just felt that as her responsibilities grew, that she kind of stood in the way of

try to keep me away from Michael, in a sense. Keep it at a distance. And then Raymone came later, sir.

you know, I really, really

I really, really

I adored her. I have to say that. And I met her

or she always appeared to, like,

Q. Did the time ever come with Ms. Rwaramba where you suspected that she was involved with providing

Mr. Jackson with drugs?

A.

I thought it was a possibility.

Q.

And why did you think it was possibility, ma'am?

 

A.

Because it seemed like Michael seemed to have issues sometimes when she was around.

Q.

I'm sorry. I didn't quite

he had issues when?

A.

When

I felt there were issues when she was around sometimes, sir, and

let's see. I'm just trying to

really think. Trying to answer your question properly. I can't really think

remind me of the question again.

what was the question? Just kind of

Q. The question was

came when you suspected that Ms. Rwaramba was somehow involved with providing Mr. Jackson with drugs.

And if you answer that question, I'm going to ask a follow-up, were there times you felt that way? Was one of

those times during the 2005 criminal trial?

and I can follow up. I'll tell what you the question was. I asked you if a time ever

A. I think it was Randy Jackson who asked Grace to leave Neverland, sir.

Mr. Panish:

I'm going to object. It's all hearsay, what other people are saying, and speculation.

Judge:

yeah. I don't think he intended to elicit hearsay, but she's saying hearsay. And I'll strike that portion of

the answer.

Mr. Panish:

and also speculation, but go ahead. And relevance, too.

Judge:

No. Overruled on relevance. Why don't you re-ask the question?

Mr. Putnam:

I will.

Judge:

the answer. You can re-ask the question.

I don't think you were intending to elicit hearsay, but it came out that way. So I'll strike that portion of

Q. the question I'm asking, ma'am, is, I asked if you suspected at any point that Ms. Rwaramba was in any

way involved with perhaps providing Mr. Jackson drugs? And you said there were times when she was around.

And I followed up with, was one of those times during the criminal trial in 2005?

A.

Um, I have no proof of anything, sir. It was just things that I was told and things that happened, sir.

Q.

What were the things that happened?

A.

Michael seemed to have a more difficult time during the trial when Grace was brought back to Neverland.

Q.

So there was a time at the beginning of the trial when Ms. Rwaramba wasn't at Neverland; correct?

A.

She was at the hotel where I was staying, sir.

Q.

And then did a time come when she moved into Neverland during the trial?

A.

I only heard.

Q.

Did you have an understanding that she was there?

Mr. Panish:

I'm going to object to the understanding to be based on hearsay solely.

Judge:

it appears it's going to end up that way.

Mr. Putnam:

OK.

Judge:

so, sustained.

Q. When you said that she came back, was she not at the criminal trial at some point?

Judge:

you mean attending the criminal trial?

Mr. Putnam:

well, she said that things changed when Grace Rwaramba came back.

 

Judge:

to Neverland.

A.

to Neverland.

Q.

to Neverland. So it wasn't to the trial, it was to Neverland?

A.

Yes.

Q.

OK. And what Changed when she came back?

A.

Well, I just noticed that Michael started having a lot of back pain, and it kind of coincided with him, with

the symptoms of losing a lot of weight, and the "pajama day," and all that.

Q. And remind us, if you could. What was the "pajama day"?

A. Well, it was the day that Michael went to the hospital because something happened to his back, and he

was taken to the hospital. And they gave him, I think, some sort of painkillers for his back. And then as soon as

he was in the hospital and had the painkillers, the judge was informing Michael that he had to go to the

courthouse and be on time, or he would go to jail. And Michael had left Neverland to go

pajamas when he went to the hospital. I was still left at Neverland. I grabbed some makeup things, and Michael

Bush got his clothes, and we went to the hospital, but the judge was demanding that Michael be

have time to get ready. And we were rushed to the courthouse, and Michael was still in his pajamas. And I was

in a follow-up car with Michael Bush with his clothes and hair and makeup stuff, but we didn't have any time to

make him look better from that point on. They scooted him in. They let him go, because they were going to

throw him in jail if he didn't get there on time.

he was in his

that he didn't

Q. So that's an example of the type of incident you were talking about you had concerns about after Ms.

Rwaramba came back?

A. I have to say that a lot of my information kind of came through Taunya and

concerns.

you know, stuff about their

Q.

Well, just remind us. Is this Taunya Zilkie?

A.

Yes.

Q.

And Taunya Zilkie is your agent, your manager?

A.

At the time, she was not.

Q.

At the time you were working with her on the web site with Randy Jackson

A.

Right.

Q.

about Mr. Jackson?

A.

Correct.

Q.

About Mr. Michael Jackson? And she later became your manager? She managed your business affairs?

A.

She took care of my business affairs. Didn't really manage my career.

Q.

I want to ask you that because that's where we are going.

A.

OK.

Q.

So a time came you negotiated a contract with

A.

.e.g. correct?

A.

Correct.

Q.

And, again, I'd like to show you that contract.

Mr. Putnam:

it is already in, and it's exhibit 6818. May I approach, your honor?

Judge:

yes, you may.

A. are these both the same thing?

Judge:

oh, one's mine.

A. I'm sorry.

Mr. Putnam:

that's my fault. I should have told you that. I apologize.

A.

I thought he was just being generous.

Q.

By Mr. Putnam: you recognize this, ma'am ?

A.

I mean, without reading it word for word, it appears to be my contract.

Q.

And what I'm going to try to do is go through it and ask you about certain portions, if I may.

A.

All right.

Q.

So this is

as you see, it's a multi-page document. Ultimately, it's 13 pages.

A.

Yes.

Q.

And I'm going to start at the very beginning, and the first paragraph, if I may. And it says: "The agreement

dated as of may 5th, 2009, by and between AEG Live productions, inc., a Delaware Corporation," and then in

parentheses, it says, "(company)." and the reason I'm going through this, ma'am, is because later those

definitions will be used, so I want to try to do it in the beginning.

A.

You'll probably have to revisit that because I'm horrible. I don't understand legalese all that well.

Q.

OK. And then it says: "and Zilk, Inc., a California Corporation (lender)."

A.

Right.

Q.

What is "Zilk, Inc."?

A.

Zilk, inc. Was Taunya.

Q.

And by that you mean Ms. Zilkie, the one who was managing the business?

A.

Correct.

Q.

And you say she "was" because she isn't any longer?

A.

Correct.

Q.

You said last time that you believed she and Mr. Randy Jackson had been in a long-time special

relationship?

A.

Yes.

Q.

And then after that

and then it says: "f/s/o"

which I believe is "for the services of"

"Karen Faye

Heinze, p/k/a Karen Faye, a hair and makeup artist"

A.

I like "expert."

Q.

We'll get there. And it says there, "(expert)." in this contract you were referred to as the expert?

A.

OK.

Q.

The lender is your manager

A.

Uh-huh.

Q.

and Zilk, Inc. And then the company is AEG Live productions. You see that?

A.

The

yes.

Q.

Now, did you understand that you were not an employee of AEG, but rather

Mr. Panish:

finish your question.

Q. but rather an employee of Zilk, Inc.?

Mr. Panish:

object. Calls for a legal conclusion as to her understanding of her employment status.

Judge:

overruled.

A.

you're going to have to say that question again, there was so much going on.

Q.

let me help you, make it easier.

A.

OK.

Q.

I will show you paragraph 3.3.

A.

OK. 3.3?

Q.

Yes, ma'am.

A.

So, like, at the bottom of page 3?

Q.

Yes, it is.

A.

OK.

Q.

And while you're looking at it, I just wanted to note, the agreement was may 5th, 2009. So it was about

two months

A. Oh, it's up here, too. Go ahead.

Q. I don't know which one you prefer to read.

A. Yes. I haven't made that decision yet, but this one is kind of cut off. Can you move it over that way?

Whoever is doing it

then I prefer the one I can see.

Judge:

it's cut off on this screen. I don't want her to press any buttons.

A. there's enough up there. I can see it.

Mr. Putnam:

can she approach, your honor?

Judge:

yes.

Q.

By Mr. Putnam: it's dated may 5th, 2009, so about two months after the announcement on March 5th,

2009.

A.

OK. I'm sorry. I don't know what you were saying. All right.

Q.

All right. So 3.3 says: "the expert is specifically deemed to be an employee of lender." and you saw, again,

lender was Zilk, Inc.?

A.

Gotcha.

Q.

And not of the company, which is AEG Live productions?

A.

OK.

Q.

"the performance of expert's"

that's you; correct?

A.

Yes.

Q.

"services hereunder is in the capacity of as an independent contractor." you see that?

A.

I do.

Q.

And if you go to the bottom right of the page

A.

Yes.

Q.

You'll see that there are initials?

A.

Correct.

Q.

Are those your initials?

A.

No.

Q.

Whose initials are they?

A.

It looks like Taunya and Paul Gongaware.

Q.

Paul Gongaware?

A.

Correct.

Q.

So did you have Ms. Zilkie sign this on your behalf?

 

A.

If I had her

I guess you could say that she did that, yes.

Q.

And then, if you go to page 11 of the agreement on the bottom, is that your signature there?

 

A.

Wait a minute.

Q.

Sorry

A.

Yes.

Q.

OK. So did you have an understanding as to whether you were an employee of AEG Live productions,

 

Inc.?

A.

Say that again? Did I

 

Q.

Have an understanding

A.

Yes.

Q.

as to whether you were an employee of AEG Live productions, Inc.?

 

A.

Did I have an understanding? Like, I really don't

that's kind of

did I have an understanding if I was

I

worked for "This Is It" and the production of "This Is It". that was my understanding.

Q. OK. Now, at the time of this agreement, do you remember having certain requests that you made in

reference to your employment? And I'll help you. If you go a little further down

A.

To where?

Q.

I'm looking. I'm sorry. Page 12. If you look, it says, "This Is It"?

A.

Wait a minute. Wait a minute. Wait, wait, wait. OK. 12. OK. Gotcha. All right. I'm on the page.

Q.

At the top, you see that it says there, "This Is It" contractual requests, Karen Faye re Mr. Michael

Jackson's personal makeup and hair artist/only." you see that?

A.

Yes.

Q.

And you see, there are a number of enumerated requests that follow, 14 in total, over two pages?

A.

OK.

Q.

Do you understand what these are?

A.

I think they were things that I kind of needed to do my job, sir.

Q.

And so these are the specifics that you needed, and, thus, they were your requests?

A.

I think so. I haven't read them. I need to read over them. It's been a long time.

Q.

Let's go over a couple of them.

A.

OK, sir.

Q.

Start with the first one. It says: "access to Mr. Jackson 24 hours, seven days a week, per his request." what

does that mean? And most importantly, I want to ask about "per his request." what's that?

A. That means that I needed to have access to him because of his hair; OK? There were

had to work at times that we were not performing, and the process of his hair took a long time. So I need to be

this is there because I needed to be able to get to him. I don't know where they were going to put me, or where

they were going to put him. Because sometimes we could have been in different cities. And I wanted to make

sure that I could get to him when he needed me.

like, because we

Q.

And so when it says, "per his request," what does that mean? Was this at his request?

 

A.

To be able to do his hair, yes.

Q.

And without going into all the details

A.

Uh-huh.

Q.

about

this was

and I told you last time I didn't want all the details at this point.

A.

OK.

Q.

But it was a very involved process, was it not, doing his hair?

 

A.

Yes, sir.

Q.

And that's why, when it says, "estimated five hours, but could be more or less," you're talking about five

hours

the reason it's so long we're talking about is because of how much had to be done?

 

A.

Correct.

Q.

And, again, not going into details. There were certain things that had to be clipped into the scalp?

 

A.

More extensive than that, but, yes.

Q.

I was trying to not give all the details. Now, you go on, then, to the next one. Let's go to 2. And it's

well,

I should ask you, so this was a request that you were specifically making, correct, to do your job?

A.

Yes.

Q.

No. 1, the one we just did?

A.

Yes, sir.

Q. No. 2. It says: "for optimum work conditions for Mr. Jackson, I request a separate and private room close

to Michael Jackson's residence equipped with a hydraulic chair in which the back reclines, a shampoo bowl,"

goes on from there. Was this also a specific request you were making so you could do your job?

A. Yeah. Michael liked privacy when he did this, so this would be the ultimate. I mean, I have done things in

bathrooms and everything, but this would be under

condition to do this job.

you know, doing this, this would be the most comfortable

Q.

And when you said, "Mr. Jackson liked privacy," what do you mean?

A.

When you do somebody's hair, sir, there's a lot involved, and he doesn't want people seeing.

Q.

And next, it goes to

let's go to 4. There's

A.

UK cell phone. Goes on from there about having it. Was that another thing you had requested?

A.

Yes, sir.

Q.

No. 5 talks about: "the company will pay for all grooming needs for Mr. Jackson. There will be items of

importance that will have to be paid in full in order for the items to be secure."

A.

Correct.

Q.

What's that about?

A.

His wigs, sir.

Q.

And, again, without going into lots of details, but were these inexpensive items, these wigs?

A.

No, sir.

Q.

Were they very expensive items?

A.

It depends

saying, "very expensive," it depends on what your viewpoint is for wigs, sir. Some people

think $300 is a lot, and some people think normal is 5,000. It depends on the quality. So, you know

Q.

How much did these cost?

A.

To the best of my recollection, I think I got Stuart down to, I think, $3,500 a wig. I think.

Q.

And how many wigs were there?

A.

Well, I needed approximately

at least five to even leave for London, sir. And then

and, I mean, it takes

a long time to make them, because they're what they call "ventilated." it's each and every hair is basically

crocheted into a netting, and it's hair by hair. And it takes a long time to do because they're really nice, and it

had to look real. And that's the only way a hairpiece looks real, if it's actually growing out of the scalp. So they

ventilate it. It takes a long time and had to be a good quality of hair. So it takes a long time. So that's why I

really needed to get started really soon on getting these done, because I needed at least five before I left. And

there would be an ongoing

he sweat, and everything, how many I was going to need. And I needed to have a reserve. If something

happened to it at the last minute, I had to be able to remove it and put another one on immediately.

and, like, I don't know the durability, you know, of what Michael did, how much

Q.

Is that why you sought the monies in advance from Dr. Tohme?

A.

Yes, sir.

Q.

And at the time when you went to meet with Mr. Jackson in early April of 2009, did he have any of these

kinds of high quality wigs at that time, or did you have to make them all new?

A. He had only one on his head, that big kind of heavy one that would never even stay on his head during a

performance. So I had to get started so he even had one to work with for rehearsals.

Q.

And did you have a lot of time to get this done when you started in April, or little time, in your opinion?

A.

I was concerned that if I didn't get started right away, I wouldn't have enough time to get it done.

Q.

Let's go to the next one. No. 6. It says: "Mr. Jackson requires that his personal needs and supplies remain

completely private and confidential. I will hold all of Mr. Jackson's itemized receipts. I will only release them

upon his request. I will submit my personal invoices with descriptions of 'personal services' and 'products'

unless advised otherwise by Mr. Jackson." what did that mean?

A. It meant that Michael didn't want people to know he wore a wig. And I knew when you hand in receipts,

people want to know what they are for, and I wanted to make sure I could keep Michael's personal

private as I possibly could. So that was my request; that unless Michael OKs letting everybody know what it is,

I wanted it to be as private for him as possible.

this as

Q.

Now, last time when you were here, you had testified about a Dr. Metzger?

A.

Correct.

Q.

And could you remind us who Dr. Metzger is?

A.

He's a doctor.

Q.

Did you have an understanding as to his relationship with Mr. Jackson?

A.

He had been a doctor that had taken care of Michael for a very long period of time in his life.

Q.

And do you remember testifying that you had talked to Dr. Metzger and had gotten him to prescribe some

medications for Mr. Jackson, and he had done so in your name?

A.

Cosmetic.

Q.

That was propecia and latisse?

A.

Yes.

Q.

Were those also the types of things you were talking about in terms of not wanting to put in that Mr.

Jackson had a prescription for latisse or a prescription for propecia?

A. Yeah. Things that were private, that's what this was for. I think when I wrote it, I was more concerned for

his hair and not that. But, yes, that would come under that category.

Q. On that testimony about asking Dr. Metzger for these prescriptions, you also mentioned a Dr. Arnold

Klein. Did you ever ask Dr. Arnold Klein for any prescriptions for Mr. Jackson?

A. I was inquiring

was thinking that perhaps Michael could have Botox injections in his

would help the wig and the adhesives of the wig during his performance to stay in place, would stay more

secure without sweat coming from underneath. And I knew it was possible to do under your arms. I had read

that. So I inquired with Dr. Metzger if it would work that way. And he said, "yeah, it would probably react in

the same way," he goes, "but, you know, I don't

I don't know, you know, other things he's doing, like, to give an injection of Botox

for." so I called Dr. Klein. I left a message, and I never got a return call at this particular time, regarding this.

But I think that's the only prescription, if that's called a prescription, a Botox injection would be prescription or

not. But I went in

also had a supply of latisse. And he said, "here, you can just take this for Michael, also." and sunscreen.

I think I explained to you before about Botox, because Botox inhibits sweating. And I

on his scalp to stop the sweating. It

you'd have to go to Dr. Klein for that, because I don't know,

you know, what Michael's

Michael also used creams that Dr. Klein makes, and I went into the office. And Dr. Klein

Q.

And sunscreen?

A.

And eye drops.

Q.

And, again, those prescriptions were all in your name, not in Mr. Jackson's name; correct?

A.

Um, the ones from Dr. Metzger, the latisse and the propecia was. I asked him specifically if he would do

that for me because

especially the latisse to start using, because it takes about six weeks to start, and so I wanted to start Michael on

that right away. And so he put the prescription in my name for the latisse and the propecia. The propecia also

is

secure his hairpieces.

and I wanted him to do it at a pharmacy near me so I could take them to Michael. And

it rejuvenates hair on men's scalps. And so I needed as much healthy hair as possible on his scalp in order to

Q. Other than that time with Dr. Metzger, or times when you were getting propecia and the latisse, are you

aware of any other time when Dr. Metzger prescribed medications of any sort for Mr. Jackson in your name?

A.

No, sir.

Q.

Was there any other time where you asked him to do so?

A.

OK. I've got to think back. Is there any other time? That's a long time to think back. I'd have to say, you

know, without staying here for, like, about an hour and a half trying to figure it out, that I really don't recall.

Q. And what about with Dr. Arnold Klein? Was there ever a time that you're aware of where Dr. Arnold

Klein had prescriptions for Mr. Jackson done in your name?

A. I would pick up things for Michael at the pharmacy, but

don't know if they were put in my name. And I know with the eye drops, I would sometimes pick them up for

Michael. And I cannot recall, for the life of me, whether they were in my name or not. I know Evvy would send

me some creams to take to Michael when I was going to wherever he was in the world. She was, "Oh, Michael

needs this. Will you take this cream?"

I would pick up skin creams, for his propecia. I

Q.

So his

A.

And I can't recall, for the life of me, whether my name was on it or not.

Q.

That's all I'm asking, if you remember.

A.

I can't.

Q.

So you don't know whether prescriptions were put in your name for Mr. Jackson? You just don't

remember?

 

A.

Right. I don't recall if they were in my name. I'm telling you the things that I did pick up for him.

Q.

Right. And in terms of these pickups

let me make sure I understand. So there were times when Mr.

Jackson was on tour where Ms

I'll mess up her name, I'm sorry, Evvy Tavasci?

A.

Tavasci.

Q.

She would contact you and ask you to bring stuff to Mr. Jackson?

 

A.

I mean, it was

I mean, not

I mean, it was very rare. Rarely. Very rarely. But it was his skin cream.

Q.

But that happened on occasion, then?

 

A.

Three or four times in 27 years. Well, she wasn't there 27 years, but

yeah, it was

they were awkward

because they were really big tubs.

Q.

OK. And did you agree and bring those to Mr. Jackson?

A.

Yeah.

A.

Few times, yeah.

Q.

Going back to your contract, which is where we were, do you recall how you were paid?

A.