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JACKSON V AEG LIVE July 19

th

2013

JACKSON V AEG LIVE July 19 th 2013 Katherine Jackson (Michael Jackson's Beloved Mother, Jackson Family

Katherine Jackson

(Michael Jackson's Beloved Mother, Jackson Family Matriarch, Plaintiff)

Plaintiff' Witness.

Judge: Is there anything we need to talk about before we call the jury? All right. Okay. Call them in.

(The jury enters the courtroom)

Judge: Katherine Jackson versus AEG Live. Good morning, everybody. Counsel, will you make your

appearances?

Mr. Panish: Yes. Good morning. Brian Panish for the Plaintiffs.

Mr. Boyle: Good morning. Kevin Boyle for the Plaintiffs.

Ms. Chang: Good morning. Deborah Chang for the Plaintiffs.

Ms. Stebbins: Jessica Stebbins Bina for the Defendants.

Ms. Robinson: Good morning. Laura Robinson for the Defendants.

Mr. Putnam: And Marvin Putnam for the Defendants.

Judge: Thank you. You may be seated. Plaintiffs, you can call your next witness.

Mr. Panish: Yes. Plaintiffs call Katherine Jackson at this time.

Katherine Jackson, called as a witness by the Plaintiffs, was sworn and testified as follows:

The clerk: Would you raise your right hand? Do you solemnly state that the testimony you're about to

give in the cause now pending before this court shall be the truth, the whole truth, and nothing but the

truth, so help you God?

The witness: I do.

The clerk: Thank you, ma'am. You may have a seat. And, ma'am, can you please state and spell your

first and last name for the record?

The witness: My name is Katherine Esther Jackson. K-a-t-h-e-r-i-n-e, j-a-c-k-s-o-n.

The clerk: Thank you.

Judge: Thank you, ma'am. You may begin.

Direct examination by Brian Panish:

Q.

Yes. Good morning, Mrs. Jackson.

A.

Good morning.

Q.

First of all, what is your date of birth?

A.

I was born may 4th, 1930.

Q.

I know this is not a great question, but how old are you?

A.

I'm 83 years old.

Q.

Is this the first time you've ever testified in a court with a jury like this?

A.

Yes.

Q.

Are you nervous?

A.

Yes, I am.

Q. Did you get a lot of sleep last night?

A. No.

Q. All right. Now, Mrs. Jackson, are there any medical conditions that you have that may make it hard

for you to testify here today?

A.

I'm a little hard of hearing, so I would appreciate it if you would talk a little louder.

Q.

Okay. Anything else?

A.

I -- in my 83 years, I've forgotten a lot of things, so I'll try to answer the questions as best I can.

Q.

Okay.

Mr. Panish: Your honor, is everybody able to hear okay?

Judge: It's hard.

Mr. Panish: I don't think so.

Mr. Panish: So I know it's kind of uncomfortable, but -- okay. Mrs. Jackson, can you say something

for us? Just test it out. Good morning.

A. Good morning.

Mr. Panish: Better?

Judge: You want her to use the book?

Mr. Panish: Good idea.

Q.

Okay. We're just trying to adjust the microphone. Let's try that. Good morning.

A.

Good morning.

Q.

Pretend you're singing in the choir. Try to get it out a little bit. I know it's hard for you. Okay?

A.

Okay.

Q.

All right. Mrs. Jackson, I know that you come from a famous musical family. Are you a private

person?

A.

Yes, I am. I leave the spotlight for my children. I always stay in the background.

Q.

Now, is it difficult for you to come here and bring up a public matter like this in front of the public?

A. Yes, it is. The most difficult thing is to sit here in this court and listen to all the bad things they say

about my son.

Q.

And why is that difficult for you?

A.

Pardon?

Q.

Why is that difficult for you?

A.

Well, a lot of the things that have been said are not the truth. He's not here to speak for himself.

Q.

So are you here to speak for your son, Michael?

A.

I'll try my best.

Q.

And why is it that you're here to testify today?

A.

Because I want to know what really happened to my son, and that's why I'm here.

Q.

And do you believe that your son was a bad person, or some of the things that have been said? And

the Defendants have said, "It's ugly," and they're "Going to expose the ugly of your family and your

son." Mr. Putnam said that at the beginning of the case. Do you believe that's the case?

Mr. Putnam: Objection, your honor. Misstates the testimony and my comments.

Q.

Mr. Putnam said in his opening statement. Did you sit here, hear his opening statement?

A.

Yes, I did.

Q.

Did Mr. Putnam take your deposition for many days?

A.

Yes, he did.

Q.

Did he ask you many questions you didn't like?

A.

Yes, he did.

Q.

And how does it make you feel to hear that they're going to tell everyone that your son is a bad

person?

A. Makes me feel real bad, because I know my son was a very good person. He loved everybody. He

gave to charity. He's in the Guinness book of records for giving the most to charity of all of the pop

stars. I'm so nervous. I'm sorry.

Q. Okay. Well, let's talk about you a little bit, Mrs. Jackson. Where were you born?

A. I was born in Barbour County, Alabama. A little, small town.

Q.

What was the name of the town?

A.

Barbour County. Town? Eufaula was the name of the town.

Q.

Eufaula, Alabama?

A.

Yes.

Q.

Let me ask you: And what was your -- well, who were your parents?

A.

My father was Prince Scruse, and my mother was Martha Upshaw.

Mr. Panish: I want to show exhibit 1007. All these have been given to counsel.

to show exhibit 1007. All these have been given to counsel. Q. And who is in

Q.

And who is in that picture, ma'am?

A.

That's my father. That's my father and Michael and myself.

Q.

And your father's name was Prince Scruse?

A.

Yes.

Q.

S-c-r-u-s-e?

A.

Yes.

Q. Is Prince a family name in your family, Mrs. Jackson?

A. That name goes all the way back to slavery. His father, his grandfather, his great grandfather, his

great grandfather were all named Prince.

Q. Were you pleased when you learned that your son was going to name -- Michael was going to name

his son Prince?

A.

Yes, I was.

Q.

Now, we heard all these things, well, since your son was the king of pop, he was going to name his

son Prince. Is that why he named his son Prince?

A.

No.

Q.

Why was it?

A.

It was because of my family. He loved my father.

Q.

Now, in your family, Mrs. Jackson, was there musical talent?

A.

Yes.

Q.

Tell us about it.

A.

My father -- my grandfather on my mother's side, my great grandfather, I should say. Name was

Columbus Brown. He was a very good singer. He sang in the church. And my mother used to tell me

that on Sunday mornings they would open the old wooden windows in the church in Alabama, and you

could hear my grandfather's song. His sang, and his voice rang all over the valley.

Q.

At some point in time did your family move from Alabama?

A.

Yes. I was three and a half years old when we moved to east chicago, Indiana.

Q.

And did -- how far is east Chicago, Indiana from Chicago, Illinois?

A.

We were only 20 minutes out of Chicago, but we were seven miles away from Gary, Indiana.

Q.

Did you grow up in a musical family in addition to your great grandfather, Columbus Brown, that

you mentioned?

A.

Yes.

Q.

Tell us about that.

A.

Well, my father taught himself to play the guitar.

Q.

What was your father's name?

A.

My father? Prince.

Q.

I'm sorry. I asked you that already. I'm sorry. I'm nervous, too. Okay. And what did your father --

what was his musical talent?

A. He played guitar. I played the clarinet in the school band. My sister played the cello in the

orchestra. Joseph's side was very talented, also.

Q.

Who is Joseph?

A.

My husband.

Q.

And your husband, what about his family side's talent?

A.

They were very talented. His brother played the guitar. One of them played the saxophone. And we

always had music around the house, and I think that's what encouraged my children.

Q. Did you have any health issues, Mrs. Jackson, when you were growing up?

A. Yes. I had polio as a child. It was -- at that time it was called infantile paralysis because most babies

got it at the time. But President Roosevelt had it, also, and he started the March of Dimes. And that was

back in the '40s when I was in school.

Q.

And how did that affect you when you were growing up?

A.

Uhm, I wore a brace from the age of 7 up until --

Q.

You wore braces?

A.

Just one brace on my left leg, and wore it up until the age of 9.

Q.

How did that make you feel as a youngster?

A.

I was shy.

Q.

How was your son Michael with children who had disabilities?

A.

Michael loved all children, but especially the ones who couldn't care for themselves or had

something wrong with them. Everywhere he would go, he would go to the orphanages and would go to

the hospitals visiting children. He would always give money for disabled children. And when he was

young, he would always have someone visiting from make a wish foundation. Michael would spend all

day with them, have lunch with them, play with them.

Q. Mrs. Jackson, I want to show you exhibit 1008.

Mr. Panish: Any objection, counsel? I'm sorry. Can't hear you.

Mr. Putnam: No.

Mr. Panish: Okay. Thank you.

Q. Who is that? (indicating) there's a screen in front of you.

is that? (indicating) there's a screen in front of you. A. Oh, my gosh. That's me.

A.

Oh, my gosh. That's me.

Q.

And when was that?

A.

Pardon?

Q.

When was that picture?

A.

I was in high school at the time.

Q.

That your graduation picture?

A.

No.

Q.

No? Okay. Now --

A.

Take it down.

Q.

What was that?

Ms. Chang: She said to take it down.

Q.

Mrs. Jackson, at some point in time did you get married?

A.

I did.

Q.

And how old were you?

A.

I was 19.

Q.

Who did you get married to?

A.

Joseph Jackson.

Q.

How old was he?

A.

21.

Q.

And where did you live when you were married?

A.

I moved to Gary, Indiana.

Q.

And is Gary, Indiana -- is that close to East Chicago, Indiana?

A.

Yes. About seven miles.

Q.

Okay. And when you and your husband were married, did you have a house?

A.

We bought a little house when we first got married, about two or three months later we bought a little

house on Jackson street in Gary, Indiana. Four rooms. We didn't have any kids then. I was pregnant.

Q. Okay. Hold on.

Mr. Panish: Is there some feedback?

The witness: Am I too close?

Q. I'll just move it back a little. Hopefully we can still hear you. Now, how many rooMs were in the

home that you lived in with your husband in Gary?

A.

Small, little house. Looked like a garage, in a way.

Q.

All right. I'm going to show you exhibit 1009.

Mr. Panish: Mr. Putnam, is there any objection to any of our exhibits? Do I need to ask you every

time?

Mr. Putnam: No, you don't.

Mr. Panish: Thank you.

Q. Okay. Is this the home you and your husband lived in? (indicating)

Is this the home you and your husband lived in? (indicating) A. Yes, it is. Q.

A.

Yes, it is.

Q.

You said Jackson street. Had that been named after you when you moved there?

A.

No.

Q.

Was this --

A.

No. That was the name of it. That's the street we moved on. It was a coincidence.

Q.

And how many children did you and your husband raise in that home?

A.

Nine children.

Q.

Can you tell us the names from the oldest to the youngest?

A. My oldest was my oldest daughter, Rebbie. Her name was Maureen. Jackie was the second. His

name is Sigmund. Tito, Tariano was his name. Then Jermaine, Marlon, Michael, Randy and Janet.

Q. So Michael would have been your 7th child?

A. Yes.

Q. And then you had three girls and six boys?

A. Yes.

Q. Was that easy?

A. No.

Q. How was it that you all lived in this -- when you say, "four-room house," is this a four-bedroom

house?

A.

No. Just four rooms.

Q.

What rooms were there?

A.

We had two bedrooms, living room, kitchen and utility room where we had the freezer and washing

machine. We kept things out there.

Q.

How did you all fit into that 9 -- 11 people, I guess it was; is that right?

A.

Yes. At one time, 11.

Q.

How did you all fit in that house?

A.

I had triple bunk beds, and the largest bedroom was the boys' room. And Joe and I had a room. And

then I -- the two girls at the time, La Toya and Rebbie, they slept in the living room on a let-out couch,

pull-out couch.

Q. And then did your boys -- did they sing together at any time then?

A. Yes, they did. Sometimes by them sleeping in the room together, sometimes I'd wake up to them

harmonizing and singing.

Q.

And what kind of a -- how did six people fit in three bunk beds? Triple bunk beds.

A.

Okay. Jackie was the oldest so he had a bunk to himself.

Q.

He got his own bunk?

A.

Got his own bunk. He was the lucky one. And the others doubled up, other two. Randy was a baby,

so he was in a crib in our room.

Q.

Okay. So two, two and one?

A.

Right.

Q.

All right. Now, did your husband work there in Gary?

A.

Yes. He worked in the steel mill.

Q.

Is that something that was a big industry at the time in Gary?

A.

Yes. At the time. East Chicago and Gary. Chicago steel mill in the city.

Q.

And was the work steady?

A.

No, not all the time. Sometimes the steel mill went down, and he was laid off for times. Sometimes

a week, two weeks. Sometimes for four weeks or a month or more.

Q. Did you, Mrs. Jackson, ever work outside the home?

A. I took a job after Randy, because it's about five years between Randy and Janet. And I was a clerk at

sears roebuck to help out the family.

Q.

Did you like that?

A.

It was nice. The money came in handy.

Q.

Did you always have a lot of money?

A.

No, not at all.

Q.

Were you able to survive and make it?

A.

Oh, yes. We -- I made some of the children's clothes. I -- and that was the first thing, is clothing and

feeding the children. I made a lot of clothes. I watched the newspapers for sales. I bought a lot of things

on sale. And sometimes we'd go down to the Salvation Army when shoes were wearing out, and

sometimes we'd find shoes for some of them. And we made it that way. And when Joe was laid off, us

having to live from payday to payday, the money was scarce, and so we had to eat. And so we would

never want to go on welfare. So what he did, he went out to the farms. He picked -- he picked

vegetables, I canned food. And we would always buy -- every year we would buy a quarter of a cow or

half of a cow and keep it in the freezer. And that's how we survived.

Q.

Were you a good cook?

A.

The kids said so.

Q.

What did you like to cook?

A. Gosh, I know how to cook potatoes in every way you can think of because he used to pick the

potatoes, clean the field for potatoes and things when he was laid off. Just regular food.

Q.

Now, did you enjoy having a large family in Gary, Indiana?

A.

I did.

Q.

Where your home is, there's like a field or something behind it; is that right?

A.

Yes. But you're not looking at it. We lived on a cul-de-sac. So in the back of the cul-de-sac was a

league field.

Q.

Little league for baseball?

A.

Little league baseball field.

Q.

Did any of your children play baseball?

A.

Yes. Jackie played and also Tito and Jermaine.

Q.

I want to show you exhibit 1010. What is that a picture of? (indicating)

you exhibit 1010. What is that a picture of? (indicating) A. That's a picture of Tito

A. That's a picture of Tito and Jermaine's team. And the man in the middle is the mayor of Gary. His

name is Mayor Katz.

Q.

The mayor of Gary, Indiana, was in the picture? Baseball picture?

A.

Yes. He sponsored the team.

Q.

And what was the name of the team?

A.

The name of the team was Katz Kittens, and his name was Mayor Katz.

Q.

Okay. All right. And the one with the bow tie there?

A.

Yes.

Q.

And who is in that picture with Mayor Katz?

A.

Jermaine is next to Mayor Katz, and Tito is next to Jermaine.

Q.

Did you like to go to the games?

A.

We always did, Marlon and Michael. And then the girls used to sit out and watch the boys play all

the time. Michael enjoyed it because he would save his little pennies and nickels, so when they opened

up, there was a refreshment stand, and he would always go there and spend his money on that, on

candy and cookies.

Q. And what did he do with all that candy?

A. Well, he didn't eat it all. He liked to play "store man." so he would take it and put it and set up a

little store, and all the kids in the neighborhood would come and buy from him, and he felt like he was

the store man.

Q. All right. Now, was religion an important part to you in raising your family?

A. Yes, it was. I always was close to God. I raised my children as best that I can and gave them

spiritual guidance. And I think that's important in every family, they should do that. Wouldn't be so

much crime today. But -- I'm so nervous.

Q. That's okay. What religion were you raised?

A. Well, I was raised Baptist. And when I was old enough to understand, I saw a lot of things going on,

and I didn't think that's the way it should be. So I started searching. And I became a Lutheran; I wasn't

satisfied with that. So one day somebody knocked on my door, and her name was Mrs. Midget.

Q.

Mrs. Midget?

A.

Yes.

Q.

She wasn't a midget, though?

A.

No, she wasn't a midget.

Q.

Or a short person or --

A.

And she was placing Watchtowers. And from there, I got the watchtower, and I read it. And then I

called her, and I wanted to have a bible study. And I studied with her, and I found out that was the

religion I wanted. I found out that it was the true religion.

Q.

Okay. And what was that?

A.

Jehovah's Witness.

Q.

And what did you do about that?

A.

I joined. I got baptized, and I joined.

Q.

And have you been practicing that religion ever since?

A.

Yes.

Q.

How about your Jehovah’s witnesses, do they celebrate birthdays or holidays?

A.

No.

Q.

Are there any days that they do celebrate?

A.

They do celebrate one day, and that's the memorial of Jesus’s last super, and we celebrate that. And

it tells us to remember and keep doing this in memory of him. So that's the only holiday that we

celebrate. That's the only holiday that's in the bible that we're supposed to keep, because it says "keep

this day."

Q.

Have you spent a lot of time in your life reading the bible?

A.

Yes.

Q.

Now, did your children -- did they become raised Jehovah witnesses?

A.

Some -- they were raised, but some of them became witnesses. Michael became a witness, my

oldest daughter, and she still is. And LaToya became a witness.

Q.

And others went into other religions?

A.

They're not.

Q.

All right. We won't go there. Let me ask you this: Did you stop having holidays for your children

right away?

A. No. Not right away, because my husband wasn't a witness, so -- and we finally weaned him away

from the other holidays.

Q.

Now, did you still try to instill a love of music in your children?

A.

Yes.

Q.

Let's talk about your son Michael, your 7th son. I want to show you -- first of all, when was

Michael born?

A.

Michael was born August 29th, 1958.

Q.

I want to show you exhibit 1011, a photograph. And who's that? (indicating)

exhibit 1011, a photograph. And who's that? (indicating) A. That's Michael. He was about two or

A.

That's Michael. He was about two or three years old.

Q.

And what does this photograph show?

A.

It just shows him as a sweet little boy to me. My baby.

Q.

What was he like as a small child?

A.

Gosh. Michael has always been sensitive, been loving. I can remember Marlon, his older brother,

being sick. And at that time you could go to the drugstore, and the pharmacist -- you would tell them

the symptoms, what's going on, and the pharmacist would give you medicine. And by the time I got

back, Marlon had gotten worse. Marlon was standing there holding his hand -- I mean Michael was

standing there holding his hand, a boy of three years old, and crying.

Q.

Crying when his brother was sick?

A.

Crying when his brother was sick.

Q.

Did there come a time when you realized that your 7th child had an interest in music?

A.

Yes. He was born that way. He -- when all the kids was dancing around, he was in my arms, and he

couldn't be still. He was dancing, too, to the music. And when he started to walk, he would still dance.

And there's a story about -- I imagine I've told the story so many times.

Q. Share it with us.

A. We had an old, rickety washing machine, a Maytag. And if you could remember the washing

machines, when they were older, they had the dasher. And then they had the rolling -- you rolled your

clothes to dry them out, squeeze the water out of them. And it was so old and rusty, until it was done

washing, it would make a noise, and by the rotor going, it would make a rhythm noise, like "squeaky,

squeaky, katum, katum," something like that, and he would be down there dancing, sucking his bottle

to the squeaking of the washer. And I knew he was going to be -- he just loved music, and he loved to

dance.

Q. Did there come --

Mr. Panish: You can take that down.

Q. Did there come a time when you realized that your children had a real musical talent?

A. Yes. Like I say, they used to sing in their beds, and they played music. My father gave Tito his first

guitar. And Joe's brother, which is Trent’s father, he played guitar. So he would come over, and they

would play together, and that's what started Tito to play. And they loved the temptations, and they

would imitate the temptations all the time.

Q.

Temptations was a well-known group at the time?

A.

At Motown. Yes.

Q.

Okay. What is Motown?

A.

Pardon?

Q.

What is Motown?

A.

Motown is a record company which signed my children up later on.

Q.

Okay. Did you have a television?

A.

Oh, my goodness, yes, we had a TV, but we had an old TV. And sometimes it would break down.

And at the time there were tubes in TVs, and you could go to the drugstore and take your old tube and

get another and come back and put it in. But then later on, the TV would break down, and then we had

a TV man. He would come and take it away, and sometimes we didn't have the money to get it back.

And that's when the children first started singing. We would sing together, sing old country songs, folk

songs. Things like that.

Q.

Did you like country music?

A.

I grew up on country music.

Q.

Is that from Alabama?

A.

That's when -- we lived in East Chicago, and my father would listen to that, an old country -- I

mean, it was a country station coming out of Chicago called the "suppertime frolic." and on the

weekends we would listen to the grand ole opry. So we always had music in the house.

Q. Now, when is it that your children started getting involved in organized music?

A. They were very young. But they had done some singing even when Michael was about five years

old. And around town. And then they started singing, winning contests at the high school. And from

there, they went on to professional.

Q. And when you say concerts -- I'm sorry -- "contests," what do you mean?

A. Uhm, in Gary there was not a lot to do. So all the high schools had contests for the kids. And they

would go from high school to high school. And so my boys, they had got so that they won all the

contests that they -- every time there was a contest. And usually when the kids would sing -- when they

had the contests, and they seen the Jacksons coming, they would think, "oh, my God, they're going to

win again."

Q. Did they have a name, the group, or --

A. Yes, they did. I was thinking about naming them the Jackson brothers 5. But then, her name was

Evelyn Leahy, and she wanted them on her program. So she called me, and she said, "I want to

advertise them, so what is the name?" And I told her, "The Jackson Brothers 5." And she said, "Well,

let's cut that a little short and name it the Jackson 5." And I thought it sounded better, so I was for it.

Q.

And that's how the name came about?

A.

That's how the name came about.

Q.

Did there come a time when you realized or even realized that Michael might have

A.

Special talent himself?

A.

Yes. When Michael was in kindergarten and had started school, he was always singing in the house

anyway from a tiny kid all the way up. So they were having a contest -- not a contest. I'm sorry. Having

a program at school. And the teacher had sent a note home and told me Michael was in the program. So

I and Michael's grandfather, Joseph's father, went down to school. And he -- and I was thinking, "How

is he going to go up there just at five and sing?"

Q. How old was he?

A. Five years old. And he sang "Climb Every Mountain." and I was so nervous when he walked out on

the stage, because he was always shy. And he started singing the song, and he sang it with such clarity

and didn't miss -- not flat or anything. Joe's father sat there and cried like a baby. Looked around, and I

was crying, too. He got a standing ovation for his performance. And he wasn't nervous, and I was

shocked. And I think he must feel more at home on stage.

Q.

How did that make you feel?

A.

I felt -- I was proud of him because I didn't think he could do it.

Q.

Did there ever come a time when it was discussed of Michael joining his brothers in their group?

A.

Well, that happened when he was about six years old. And he was singing, and even after he had

sang "Climb Every Mountain," I told Joseph -- because Jermaine was the lead singer. And I told him

Jermaine needed help, and I told him Michael could help him. He didn't believe me, so I forced him to

listen. And that's how Michael got the job. And then after that, he became leader when they became

professionals. Motown made him a lead singer.

Q.

And did the Jackson 5 ever lose any contests?

A.

When they were at home?

Q.

Yes.

A.

Playing against high schools? They did. They lost once. And I think that they were sick of seeing

the Jacksons win. So it was another team, and it was one of the boys that belonged to this other group

who lived next door to us, and they won that year.

Q. Okay. I want to show you exhibit 1013. And is that the group early on? (indicating)

A. Yes. Those are my boys. Q. And where is Michael? A. Michael is the

A.

Yes. Those are my boys.

Q.

And where is Michael?

A.

Michael is the little kid to the right of us.

Q.

I'm sorry?

A.

He's on the right.

Q.

Here? (indicating)

A.

Right there.

Q.

Who is that? (indicating)

A.

That's Jermaine.

Q.

(indicating)

A.

That's our drummer, Johnny Jackson. No relation.

Q.

Not related to you?

A.

No.

Q.

Had the same name?

A.

Same name.

Q.

Not one of your children?

A.

No. Coincidence, which is good, though.

Q.

What does it say on the drum?

A.

"The Jackson 5 and Johnny."

Q.

"and Johnny"?

A.

Yes.

Q.

Okay. So there's six people?

A.

Six people.

Q.

Who is this? (indicating)

A.

That's Marlon, Tito and Jackson.

Q.

And when we saw TJ. And Taj, they're Tito's children?

A.

They're Tito's children, yes.

Q.

Now, where did the boys rehearse early in their career?

A.

They rehearsed at home.

Q.

In the four-room house?

A.

In the living room. We would push all the furniture back on the walls, and they would dance and

put -- set up the drums and things and rehearse right there.

Q. And how did you get the money to buy the instruments?

A. Well, we saved it. I used to always argue and fuss with Joe about, "I need more rooms. I need more

rooms." and when we would save money, we'd buy more instruments. We'd buy amplifiers and things

like that.

Q.

And who made the costumes back then?

A.

I did.

Q.

You sued them yourself?

A.

Yes, I did.

Q.

Let me look at exhibit 1014, please (indicating). What are those called, those suits?

please (indicating). What are those called, those suits? A. Homemade suits. Q. Okay. Did you make

A.

Homemade suits.

Q.

Okay. Did you make those suits?

A.

Yes.

Q.

I guess that's what they're called.

A.

That's what they're called.

Q.

All right. And how long did a homemade suit last?

A.

They grew out of them much too fast, because we had to save money to buy more suits because I

wasn't going to attempt that anymore.

Q. Okay. And at some point in time, after they had been winning some of these contests, did they ever

get a gig, I guess you'd call it, where they would get paid?

A. Yes. They had gotten to where the Temptations or Gladys knight or someone came around to

Chicago to play at the theaters, I guess the owners of the theater would always call us, and the boys

would be on stage with them. They would play, and we got paid that way.

Q.

Now, at some point in time did the Jackson 5 sign with a record company?

A.

Yes. They signed with Motown in 1968.

Q.

And did you still live in Gary, Indiana, at that time?

A.

Yes.

Q.

And did you at that point in time ever move?

A.

Yeah, we moved. The boys moved first to California. And later, about four months later, I came. Me

and the children that were left at home. LaToya, Randy and Janet, we all came out later.

Q. Okay. And what did you think when you got to California?

A. I had always wanted to live in California. And when I was a girl, I used to dream of coming to

California because it was so much snow back home, cold. And sometimes it would get 10, 15 below

zero. And I would go to the movies as a girl, and I would see. And they would always show California

-- because we got our news sometimes in the theater, especially the war news, and all of that. And it

would show California, people running around in convertibles and palm trees. And I always thought

when I had to leave the theater and go out in the snow to get home, and my dream was to live in

California.

Q.

Did the Jackson 5 then start making records?

A.

Yes, they did, once they signed up with Motown.

Q.

And they had single records; is that right?

A.

Uhm, yes. The first four singles that they made with Motown became gold records. Number one

records.

Q.

Number one records?

A.

Four number ones in a row.

Q.

And was there something called Jackson mania at that time?

A. At that time. My goodness, don't mention that. So many girls around the house. I got so tired of --

they would come and stay all day, and sometimes some of them wouldn't go home, so I had to go out at

night and drive them home.

Q.

All right. Now, let me show -- did you pick out for us --

A.

Pardon?

Q.

Did

You help us just get a couple videos of the boys and Michael when they were young to show kind of an

example of what they liked to do?

A. Yes.

Q. Okay. I want to show you exhibit 1015 from the early years back. And this is the music Michael

sang to help prepare this?

(a video clip is played)

Q. That's your house?

A. Yes.

(the video clip continues to be played)

Q.

Who is Michael?

A.

The little boy back there like he's freezing to death. That's Michael.

Q.

On the side there?

A.

In the snow.

(the video clip continues to be played)

Q. Is that in your house?

A. Yes. That's when we pushed the furniture back, and they would dance when he was --

Q. And do you know how old he was there, Michael?

A. He was about five.

(the video clip continues to be played)

Q.

Is this Motown?

A.

Yes. That's Motown.

Q.

Did they go to an audition?

A.

Yes. That's the audition.

(the video clip continues to be played)

Q.

What is this?

A.

That's on one of those television shows.

Q.

Ed Sullivan?

A.

That's Ed Sullivan there.

(the video clip continues to be played)

Q. Is that Michael?

A. Another television show. I don't remember which one.

(the video clip continues to be played)

Q.

Who is that? Janet?

A.

Michael and Janet.

Q.

Did you make those outfits?

A.

Pardon?

Q.

They had that cartoon series?

A.

Yes.

(the video clip continues to be played)

Q. Where is this?

A.

Motown 25.

Q.

And do you remember where this was?

A.

Pardon?

Q.

Do you remember where this was filmed?

A.

I think that was in Pasadena somewhere.

(the video clip continues to be played)

Q. Is one of the brothers -- this was the reunion?

A. Yes. Jermaine left the Jacksons when they left Motown. He was married to Barry Gordon's

daughter.

Q.

Barry Gordon, the owner of Motown?

A.

Owner of Motown.

Q.

He didn't leave?

A.

He didn't leave. So Motown 25, that's when they rejoined them.

(the video clip continues to be played)

The witness: And that's Jermaine hugging them, and they were happy that he was back.

Q.

Okay. So as a mother, when you saw Michael perform like that, how did you feel?

A.

How did I feel?

Q.

Yeah.

A.

I felt very proud.

Q.

When he did these special performances, were you surprised to see how he did in these special

events?

A. Yes. Especially one time when he was 14. He sang solo on one of the award shows. And that was

very good, I thought. I was most proud of him.

Q.

Were you there?

A.

Yes, I was.

Q.

Have you ever heard of the Academy Awards?

A.

Yes. It was at the Academy Awards.

Q.

And I have a clip of that. Do you know what song Michael sang?

A.

He sang Ben. It's a song about a rat. And it's a song from a Movie.

Q.

And Michael, when he went to perform, you said he was about 14?

A.

He was 14 at the time.

Q.

And he was younger than his son Prince is now?

A.

Yes.

Q.

And were you nervous about it?

A.

I was a little bit, but he did well.

Q.

Okay. Well, let's -- exhibit 1016. You remember who introduced Michael (indicating)?

A.

Yes. One of my favorite actors.

Q.

Who is that?

A.

I'm so nervous, I can't remember. I know who he is very well, but --

Q.

This was Michael at 14?

A.

Yeah.

(a video clip is played)

Q.

Was Michael singing that song again?

A.

Yes. He's older. As you can see, his voice has changed there.

Q.

Did he like that song, Ben?

A.

Yes, I do.

Q.

Did Michael like that song?

A.

Yes, he liked that song because he liked rats. That song is about a rat. And I can remember a story

that we went to Beverly Hills to have dinner, and we were eating, and Michael kept pulling his coat up

and putting crumbs into his pocket. And I said, "what are you doing?" and he held it up, and he had a

rat in his pocket, and he was feeding it. And I was really upset with him.

Q.

How about -- by the way, the actor, you heard of that movie Ben-Hur?

A.

Oh, yes. And isn't that awful.

Q.

Charlton Heston?

A.

Thank you. I can't think of his name, but I love him.

Q.

Did Michael like animals?

A.

Yes, he did. But one thing he didn't like were dogs.

Q.

Why not?

A.

Well, he had a bad experience with dogs. One year when he was a kid, Johnny Jackson, our

drummer, went on vacation, so he left his pit bull with us to take care of. And Michael and Randy was

playing with the dog --

Q.

Hold on one second.

A.

I'm too close?

Q.

Why don't you push it forward a little more.

A.

How is that? Is that better?

Q.

Better.

A.

Is that better? Okay. Where was I?

Q.

You were telling us about dogs.

A.

Oh, yes. And Johnny left the pit bull with us to take care of. And Michael and Randy was playing

with the pit bull, and Michael discovered during their play, the dog got mad. And I don't know why he

got upset, but Michael discovered that, so he ran and jumped on top of the jeep. And Randy was teasing

Michael, "Oh, you're scared of a little old dog." And he said, "For real, Randy. That dog is mad." And

so Randy went over teasing the dog, and the dog turned on him. So Randy tried to jump on the Jeep,

and before he could get away, he took a big chunk out of his arm and out of his heel. When he jumped

out at him, took a chunk out of his heel. And I rushed him to emergency, but he bit down to the bone.

And I don't know how he took that chunk of meat out of his arm like that. Like somebody took a sharp

spoon and dug it out. And I could see his bones and everything. And so Michael has been afraid of dogs

ever since.

Q.

And at some point in time, despite his fear of dogs, did he get a dog for his children?

A.

Yes, he did.

Q.

And what kind of dog was that?

A.

A chocolate Labrador.

Q.

What was the name of the dog?

A.

Kenya. And we still have him.

Q.

And when Michael passed away, in addition to getting a lab, did you get some other pets, too?

A.

I inherited almost a zoo. Yes. There was a parakeet and parrot. Ferrets, mice. So much I can't think

of it.

Q.

Besides singing and dancing --

A.

And two cats. Excuse me. And I don't like cats.

Q.

Besides singing and dancing, did Michael like to do other things? Drawing? Art? Anything like

that?

A.

Can you repeat? I didn't hear.

Q.

Okay. I'm sorry. How are you doing? You doing okay?

A.

Yes.

Q.

Okay. All right. In addition to singing and dancing, did Michael like to do other things? Any art?

Anything like that?

A. Oh, yes. Michael was a very good artist. He did a lot of art in school. And some of his pictures have

been sold since. And he writes songs.

Q. All right. And did Michael like to sit around and watch TV?

A. No. You'd never catch him doing that. And I had to sit here and see that email talk about how lazy

Michael Jackson was. That's the biggest lie in town. My son is not lazy, and you know that he wasn't

lazy.

Q.

How was Michael in school?

A.

Michael was good in school. He was not an exceptional student, but he was fair student.

Q.

Was he as good as Prince?

A.

No, not at all.

Q.

Okay.

A.

Prince is a straight a student.

Q.

At some point in time you mentioned that the Jackson 5 left Motown except for Jermaine.

A.

Yes. They left Motown, and I think they went to Epic records at that time.

Q.

Do you know how many records they'd sold by that time?

A.

With Motown? I can't remember exactly. But at Epic, I think their first record went double

platinum.

Q.

Remember what that was?

A.

No. I think that was the album Destiny.

Q.

And around that time, was Michael showing an interest in movies?

A.

Yes.

Q.

Was Michael in a movie?

A.

He was in The Wiz that was taken from the Wizard of Oz.

Q.

Do you know who the director was?

A.

Sidney Lumet.

Q.

Did he do other pictures?

A.

He made, I think, 12 Angry Men.

Q.

That's about a jury, actually.

A.

Yes. And also he did Midnight Express and some others. I can't remember them.

Q.

Okay. I want to just show you a clip from The Wiz. that's 1017. And do you remember what The

Wiz was about?

A. It was something taken from The Wizard of Oz. It was -- Diana Ross was Dorothy, and Michael

was a Scarecrow. It was around the same thing.

Q.

Okay.

A.

But in a different way.

Q.

This is kind of their yellow brick road. All right. Let's take a look.

(a video clip is played)

Q. Is that Michael?

A. That's Michael.

(the video clip continues to be played)

Q.

All right. Now, did Michael meet somebody that became important in his life by doing that?

A.

Yes. Quincy Jones did the music for the movie, and so he met Quincy.

Q.

I know Quincy is quite famous, but did you know Quincy for a long time?

A.

Yes.

Q.

And how did him and Michael interact?

A.

Very well. They made several albums together which did very well.

Q.

So did Michael then work with Quincy Jones?

A.

Yes.

Q.

And did he work with him through various projects?

A.

Yes.

Q.

Thriller?

A.

Yes. One of them.

Q.

Bad?

A.

Another.

Q.

Off The Wall?

A.

Yes.

Q.

And around this time when Michael was 21, did Michael write down what his goals were?

A.

Yes. Michael -- well, as we all know, Michael wrote notes to himself all the time, how he felt, and

he would always write on the mirror with a grease pen and where he wanted to be at a certain time.

When he would make an album, he would always write down how much he would want that album to

sell, at least so many. And everything he wrote down just about came true.

Q. And when Michael was 21, where was he living?

A. He was living with me.

Q.

With you?

A.

He was still at home.

Q.

Hayvenhurst?

A.

Yes.

Q. All right. And did Michael ever want to be known as something other than Michael Jackson?

A. Well, he had -- by a certain time in his life he didn't want to be known as Michael Jackson, because

that was little Michael Jackson from the Jackson 5. He wanted to be known as MJ.

Q.

Okay.

A.

Why, I don't know.

Q.

And did there come a time when he came out and did something as MJ?

A.

Well, by the time he was on Motown 25, and he did the Moonwalk, that changed things.

Q.

Okay. Well, let's -- how -- were you there?

A.

Yes.

Q.

How did the crowd react to Michael that night?

A.

Oh, my goodness, I can't -- do we have a thing of it?

Q.

Yes, I do have one. Let's take a look at 1018. And the Moonwalk, had Michael ever done this in

public?

A. No. I hadn't even seen it. I'm sure he was practicing it, because he used to practice all the time. And

we had a room upstairs over the garage where he would always practice. And he would go up every

Sunday and Saturday and dance two hours straight without stopping. And I'm sure he was doing the

Moonwalk up there, but we never knew it.

Q. All right. Let's take

A. Look. This is the Moonwalk, Motown 25.

(a video clip is played)

Q. Now, that black sparkly jacket, where did he get it?

A. He borrowed that from me. That was my dinner jacket.

Q.

Was Michael having a lot of success?

A.

Pardon?

Q.

Was Michael having a lot of success?

A.

Yes.

Q.

Did it go to his head?

A.

No. Michael was the most humblest person you'd ever meet.

Q.

Did he continue living with you?

A.

Yes.

Q.

Until he was 30?

A.

Yes.

Q.

Did Michael ever do anything special for you at your home where you lived together at

Hayvenhurst?

A.

Michael did so many special things for me. Gosh. I don't know where to start.

Q.

Well, did he help rebuild the house?

A.

Oh, yes.

Q.

Did he --

A.

When he became 18, he wanted to buy me a house. We went shopping everywhere. By that time,

houses had gone up to millions and millions of dollars. We shopped everywhere, and we came back

home and decided to remodel, because we couldn't find a house with as much property around it, and

the kids grew up there, and he had go-carts and did everything at the house, played basketball and

swim. So we decided to -- so he remodeled, and the way you see Hayvenhurst now is the house he

rebuilt for me.

Q.

So it was rebuilt?

A.

Pardon?

Q.

Remodeled, you said. Rebuilt?

A.

Rebuilt, really.

Q.

And at some point later did Michael do something to a couple rooms for you?

A. Yes. He -- up over the garage, like I said, he used to practice all the time. He'd lock that room up,

and he told us not to come in. And he took all my pictures -- because I was wondering, "Where are my

pictures going?" He took all the pictures, enlarged them, and instead of wallpaper, he just put them all

around the wall and invited the whole family over when he got ready to open it up. And he said, "Here's

your surprise. Come in."

Q.

Did he have people come help him do this?

A.

Well, people helped him enlarge them and all of that, yes.

Q.

But the work of putting up the work and the design and everything?

A.

He helped and -- yes, he did.

Q.

All right. Let's look first at exhibit 1019 (indicating). Is this a plaque that Michael gave you?

1019 (indicating). Is this a plaque that Michael gave you? A. Yes. Q. It says: "

A.

Yes.

Q.

It says: "To take a picture is to capture a moment to stop time, to preserve the way we were, the

way we are. They say a picture speaks a thousand words, so with these photographs, I will recreate

some wonderful magical moments in our lives. Hopefully this journey into the past in picturesque

form will be a stimulant to create a brighter, successful tomorrow. Michael Jackson." Is that in your

house in Hayvenhurst?

A.

Yes. It's still there.

Q.

And did Michael write that and put that up for you?

A.

Yes, he did.

Q.

Where is that in the home?

A.

It's over the garage, and it's -- I think it's two rooms up there. He did the whole upstairs that way.

Q.

Okay. Let's look at it. Exhibit 1020 (indicating). And did Michael prepare this for you?

A.

Yes, he did.

Q.

How did it make you feel?

A.

I felt proud. He was always giving me things.

(a video clip is played)

Q. Okay. Is Michael singing -- what song is he singing here?

A. "You Are Not Alone." but --

(the video clip continues to be played)

Q.

Why don't you tell us what you're looking at?

A.

You're looking at a picture that he had taken before they left Gary, Indiana. That's my father there.

Q.

We're looking at the walls of the room?

A.

That's Rebbie when she was at high school. Joe playing the guitar. Myself and Janet, La Toya.

Q.

We can see there's like a window, and there's the walls.

A.

Yes.

Q.

Michael did all this for you?

A.

Yes.

Q.

And he made all the wallpaper. There's your driver's license.

(the video clip continues to be played)

Q. Who is that?

A.

That was me, and that's with the queen.

Q.

And that's the ceiling up there?

A.

Yes.

Q. Michael put all that up there?

A. Everything was covered with pictures.

(the video clip continues to be played)

Q. And Michael made all that for you?

A. Yes.

Q. You still have it that way?

A. Yes.

Q. All right.

Judge: Shall we take a 15-minute break until 11:00?

Mr. Panish: Yes, your honor. That would be great.

Judge: Let's do that. Break until 11:00, and then we'll come back.

(The jury exits the courtroom)

(Break)

(The jury enters the courtroom)

Judge: Katherine Jackson versus AEG Live. You may continue.

Mr. Panish: Thank you, your honor.

Q.

Mrs. Jackson, did Michael ever throw a dinner party for you when he serenaded you?

A.

Yes.

Q.

Does this embarrass you?

A.

Yes.

Q.

Okay. Let's look at exhibit 1026.

(a video clip is played)

Q.

Where is this? Do you remember this dinner party?

A.

Yes, I do.

Q.

Who was sitting next to you?

A.

It was my favorite pianist.

Q.

Who is that?

A.

Floyd Cramer, concert pianist.

Q.

Is this song that Michael sings, is this one of your favorites?

A.

Yes, it is.

Q.

Is that Floyd?

A.

Pardon me?

Q.

Never mind.

(the video clip continues to be played)

Q.

Is that Mr. Cramer with the bow tie?

A.

Yes, it is.

Q.

Did Michael, when he was living at home, when he wasn't touring or doing other work, was he --

did you and he share stories about his work? Did you share stories about the work he was doing? Talk

about the work he was doing?

A. When we were where?

Q.

At home.

A.

Oh. I don't understand the question.

Q.

Okay. Fair enough. Did Michael like music videos?

A.

Oh, yes.

Q.

Did you talk about those with him?

A.

Oh, yes.

Q.

What would you talk about?

A.

We talked about the -- they were really short movies, and I would always tell him -- when he made

his first movie, he said, "Well, mother, the second one is going to be better than the first." And I was

wondering -- I would tell him, "How are you going to top that?" And he said, "You'll see." And the

next one was Thriller, and he did top the first one. And he invited me down to where he was doing

another short movie, and it was Ghost. I don't think it topped thriller. But it was funny.

Q.

Okay. Let's take a look at that. Exhibit 1021 (indicating). You went to the set of this?

A.

Yes.

Q.

And who is that?

A.

Now it's Michael. At first I didn't know who it was. I know who it is now. But I was sitting at the

set, and after they got through, I -- this man came up to me, and supposed to be the white mayor of the

town. And I told him, "I'm here to see my son, Michael." And he said, "Mother, it's me." I wanted him

to get him for me.

Mr. Panish: All right. Is that a video? Just a picture? Okay.

Q.

Now, did Michael, was he involved in the Jehovah Witness religion for a while?

A.

Yes, he was.

Q.

Did he ever go out with you -- and is part of the religion to go out to people and spread the word of

your faith?

A. Yes. Field service, we call it. He had to -- the way he's dressed now. So one morning we got up, and

it was the first time that he dressed that way, because people knew who he was, so he couldn't do field

service or kids and people following him. So he had to try to disguise himself. And the first time he

disguised himself, he got a fat suit, not real fat. And I came down, and he had had breakfast. And I was

getting ready to go out in field service with him, and I spoke to this man, like "Hello. How are you?"

and he said, "It's me, mother." But he had to do it.

Q. So he would go out and knock on people's doors with the suit on?

A.

Yes.

Q.

He'd get the door slammed in his face?

A.

Lots of times. But they never knew who it was, so that was good.

Q.

All right. So then in 1988 did Michael purchase the Neverland Ranch and move out?

A.

Yes, he did.

Q.

And when he was wasn't traveling around, did he stay at Neverland?

A.

Yes.

Q.

Did you visit him there?

A.

Lots of times.

Q.

Okay. I want to show exhibit 1022, some excerpts with the music that's actually played. Is the

music actually played when he lived there at Neverland?

A.

All the time. All over the ranch, wherever you went, you heard music.

Q.

Okay. Let's take a look. Is that the beginning of the ranch?

A.

Yes.

(a video clip is played)

Q. So this music would continually play?

A. Yes. All the time.

(the video clip continues to be played)

Q. Did Michael write this poem? "When children play, tyrants cry, there is nothing to slay. Fairies

dance and goblins sing in the garden, we frolic awhile. Those are the moments when babies smile."

A.

Yes.

Q.

Is that the candy store?

A.

Yes. Finally got a candy store.

Q.

What is that? A sea dragon?

A.

Yes.

Q. Did you ever go on that?

A. I did. That's the only thing that I would go on.

(the video clip continueS to be played)

Q. Did Michael make the ranch available to people?

A. Yes. And especially for underprivileged children. And he had them -- the movie theater on the

ranch. And in the movie theater, he would have beds for children that were sick and couldn't sit up.

They propped them up to see the shows that they put on for the children.

(the video clip continues to be played)

Q.

Is that the house?

A.

Yes, that's the house. He would invite classes of children.

Q.

Who is that?

A.

Oh, that's -- where? Oh, that was grace and the cook.

(the video clip continues to be played)

Q. What is this?

A. That's a note that Paris wrote to Michael when he was sick. "I love you daddy so much more than

that. Get well."

Q.

Is that at night?

A.

Yes.

Q.

Did it have a train station?

A.

Yes.

Q.

What was it called?

A.

Katherine.

Q.

Did your grandchildren, Paris, Prince and Blanket, did they like Neverland?

A.

They loved Neverland.

Q.

During the time they lived there, were they being home-schooled?

A.

Yes.

Q.

And we saw a lot of animals that Michael had there?

A.

Lots of animals. Funny story is -- kids liked to go to Chuck E. Cheese.

Q.

Chuck E. Cheese?

A.

Yes.

Q.

Like pizza? Like a lot of kids running around?

A.

A lot of kids running around. So Grace had them at Chuck E. Cheese, and the lady there, she was

asking them, "Do you like animals? Do you have any animals?" And the kids said, "Yes. We have an

elephant, and we have giraffes," And just naming all the big animals. And the lady turned to Grace and

said, "Don't they have great imaginations?" Not knowing that they really had those things.

Q.

Okay. Let's talk a little bit about interventions.

A.

Okay.

Q.

Now, as Michael's mother, did there ever come a time when you heard news that he had medical

issues caused by pain?

A.

Yes.

Q.

What caused pain for Michael that you were aware of?

A.

Well, he had been burnt.

Q.

Bad burns?

A.

Bad burns on the back and the top of his head. He even had a balloon between his scalp and his

head.

Q.

Did he get migraine headaches?

A.

He got headaches. Very bad headaches.

Q.

Was that from the Pepsi commercial?

A.

Yes.

Q.

And did Michael take money from -- that was given to him as a result of being burned from the

Pepsi commercial and do anything with that?

A.

He took that money, and he donated it to the burn center. All of it.

Q.

Did he have other medical conditions and injuries that caused pain?

A.

Back.

Q.

Back injuries?

A.

He had back injuries.

Q.

Did he have a skin condition?

A.

Yes. He had vitiligo.

Q.

What is vitiligo?

A.

It's a disease that turns your skin white. But while it's doing that, you have -- you're spotted. It

works slowly. And so he just wanted to get it over with, and so he just turned the whole thing that way.

Q. Now, did -- did you ever discuss with Michael whether he ever had insomnia?

A. You know, he didn't talk much about insomnia to me, but he would tell me sometimes, "I didn't

sleep last night." that was when he was at home. So I imagine it was just starting.

Q.

Did Michael -- (brief pause in the proceedings)

Q.

All right. We're talking about Michael. Did he trust doctors?

A.

Yes, he did.

Q.

Do you know who his doctor was? His primary doctor?

A.

When he was growing up?

Q.

When he got older.

A.

As he got older? I know that Dr. Metzger was his doctor even when they were young, too.

Q.

Did you ever see him abuse drugs or medications?

A.

No. I've never seen that in him.

Q.

Did you hear that people said that Michael was abusing prescription medications?

A.

I had heard it.

Q.

Did you hear it from some of your children?

A.

Yes.

Q.

Did you believe it?

A. Well, I know he was taking pain pills. And when he said "abusing them," I didn't know. Because at

that time I had seen Michael so many times, gone to his home unannounced and called him, he didn't

know I was calling him, I never heard or seen him in that way. So I don't know how to believe it.

Q. Did you or your children ever try to have any type of intervention of any kind with Michael?

A. Yes. I went with them on an intervention once, because -- I didn't want to go, because I didn't

believe it then that he was abusing drugs. But I had heard it from them, and they had heard it, also. But

I went because they kept telling me, "it would mean much more, mother, if you would go."

Q.

So you went?

A.

So I went.

Q.

And did Michael say he had a problem?

A.

When we got there, Michael was fine.

Q.

Did you hear of other times that people tried doing interventions with Michael?

A.

Not -- the children talked about it, but I imagine if they did any others, they did it without letting

me know.

Q.

Did you know whether he had a problem one way or the other?

A.

I couldn't prove it.

Q.

Did you think maybe he might?

A.

I kept hearing it. I thought maybe he might. And then I -- when I went to his home after he had

moved to Las Vegas, and I talked to him about it because I was worried. And he promised, and he kept

saying, "mother, I'm okay. I'm okay." but sometimes the mother's the last to know. And sometimes

they're embarrassed and don't want to let me know. But I was -- I told him, "I don't want to wake up

one morning to the news that you're not here anymore."

Q.

Now, when your son was rehearsing and being on tours, would you see him very often?

A.

Pardon?

Q.

When he was rehearsing or going on tours, would you see him often?

A.

Yes, sometimes.

Q.

Did you have a family gathering in May of 2009?

A.

Yes, we did.

Q. What was that for?

A. That was supposed to be for my 60th anniversary, but it was the wrong time. I think Janet just

named it that so we could have an anniversary or a party.

Q. Were you ever asked by anyone to sign anything saying Michael had any issues in 2007?

A. Did I ever? Yes, I did. But you know what? I really don't remember that thing. But I did sign

something.

Q.

Did you see Michael -- in People magazine or something?

A.

Yes.

Q.

Did you see Michael in May at the family gathering?

A.

When? In '09?

Q.

Yes. I want to show you exhibit 1-1. Is this the family picture? (indicating)

you exhibit 1-1. Is this the family picture? (indicating) A. Yes, it is. Q. And how

A.

Yes, it is.

Q.

And how did you think Michael was at that time?

A. At that time, to me, Michael looked okay. Later I -- when I saw it, I saw he was thinner. Because he

was dressed in a jacket and all, I didn't notice that he was very thin.

Q. Let me ask you this: Can you describe -- okay. Let's look at Michael.

Mr. Panish: Can we zoom in on him? There he is.

Q.

Who's got the hat on?

A.

That's LaToya.

Q.

Okay. And Michael is next to LaToya?

A.

Uh-huh.

Q.

"yes"? Okay. That's good. Can you tell us, Mrs. Jackson, can you describe your relationship with

your son Michael?

A. Michael and I were very close. Michael, he was the type of son, a mother wouldn't want a better son

than Michael.

Q.

Was he shy?

A.

Michael was very shy.

Q.

Did he write a poem for you?

A.

Yes, he did. He wrote several poems for me.

Q.

I'm going to show you exhibit 1023, a poem he wrote called "Mother." "Mother" -- did Michael

write this for you?

A. Yes. Q. " Mother dear, you gave me life. Because of you, no struggle

A.

Yes.

Q.

"Mother dear, you gave me life. Because of you, no struggle or strife. You gave me joy and

position, cared for me without condition." And it goes on. How did you feel? In the end, it says: "No

matter where I go from here, you're in my heart, my mother dear." How did that make you feel when

Michael gave that to you?

A.

Well, it made me cry, for one thing. And I felt very -- I felt loved. I knew he loved me.

Q.

And after Michael died, did you find another poem that he had written for you?

A.

Yes. He had scribbled that on some pieces of paper, and Jermaine gave it to me framed. He must

have found it, and he framed it and gave it to me.

Q. Let me show you exhibit 1024 (indicating). And this is in Michael's handwriting. "a reflection of a

mother's heart is in the glimmer in her children's every" –

Ms. Chang: Page 2. Mr. Panish: It's easier to read. This is entitled, " Mother,

Ms. Chang: Page 2.

Mr. Panish: It's easier to read. This is entitled, "Mother, my Guardian Angel" by Michael Jackson:

Page 2. Mr. Panish: It's easier to read. This is entitled, " Mother, my Guardian Angel"

"The reflection of a mother's heart is in the glimmer in her children's eyes. Her every emotion and

feeling is somewhere in her child's character. Noblemen are what their mother's made them. Why

does my mother cry? Are those happy tears or tears of sorrow? Oh, please, God, let them be happy

tears. All my success has been based on the fact that I wanted to make my mother proud, to win her

smile of approval."

When you received that, Mrs. Jackson, how did you feel?

A.

I cried.

Q.

And were you financially dependent on your son Michael while he was alive?

A.

Yes. Michael took care of me. My every need, my every want. He gave me everything.

Q.

The necessities of life, he provided for you?

A.

Yes.

Q.

Did he give you gifts?

A.

All the time.

Q.

Cars, jewelry, mobile homes, things like that?

A.

Yes.

Q.

Did he give you money?

A.

Yes.

Q.

Did he give you cash?

A.

Always.

Q.

Why not checks?

A.

He never wrote checks.

Q.

Did Michael provide you with moral support?

A.

Yes.

Q.

Can you tell us how have you been affected by the loss of the love, companionship, affection,

support, by the loss of your son, Michael?

A. Excuse me. Can you repeat?

Q. Sure. The loss of your son, Michael, the support, the love, how has that affected you?

A. When a mother loses a child, you -- no one knows until it happens

to them. That's the worst thing that can happen to a person, losing a child. I lost my mother, my father

and my sister. I'm the only one left. But when I lost Michael, I lost everything. He was the most loving,

down to earth, he loved everybody. Very humble. Very humble. No matter --

Q.

All right. Are you okay, Mrs. Jackson?

A.

I'm okay.

Q.

Let me ask you about this is it. Just a little bit about it. Do you remember when you first heard

about it?

A.

This is it? Yes.

Q.

And how did you learn about it?

A.

Well, I think grace had called me and told me.

Q.

Grace Rwaramba?

A.

Yes.

Q.

All right. And now, the other day, the Defendants, AEG, played a portion of your deposition,

something to the effect that Michael told you that -- or I think you said he jokingly said he didn't want

to be moonwalking on tour at the age of 50. You remember that?

A.

Yes, I do.

Q.

Tell us about that.

A.

It was -- Michael said that quite a few years back. And he was joking. We were talking one day, and

we were joking, and he said, "I don't want to be moonwalking at the age of 50." and I thought it was

funny. And most of us say things like that. I used to think that 50 was very old. I imagine you've said

that you didn't want to be in a courtroom practicing law at the age of 50, because you think that -- but at

the age --

Q. Here I am.

A. But at the age of 50, it's not as bad as -- you know, young people think that a 50-year-old is an old

woman, and by the time you get 50, you don't even feel old. I can vouch for that.

Q. Now, Mrs. Jackson, did you think your son could have done 50 shows?

A. Yes. But the only way he could have done them is if they had them spaced out. They couldn't be

every other night like AEG Wanted at first. That's why I kept calling.

Q.

Who were you calling?

A.

I called Randy Phillips, and I called doctor -- what's the name?

Q.

Dr. Tohme?

A.

-- Dr. Tohme, first. And I told him, "Michael can't do those shows. They have to change the

schedule of it."

Q.

So you were just concerned about the spacing out of the concerts?

A.

I was concerned about that. If they spaced it out, he could have done many shows.

Q.

Did you visit Michael ever at the Carolwood home?

A.

Yes.

Q.

Did you go there before he had his press conference in England?

A.

Yes.

Q.

Before the press conference, did you go in his bedroom?

A.

Yes.

Q.

Were there any doors locked at that time?

A.

No. Every time I went there, we went into his bedroom, and we went into all the other parts of the

house. My nephew sitting there now, he would always be with me, and Michael would invite us up

there, and we would watch movies, and he would show us different things that he had been doing.

Q.

Okay. Now, did you ever know who Conrad Murray was before your son died?

A.

No.

Q.

Had Michael ever mentioned his name or introduced you to him?

A.

No.

Q.

When was the first time you ever saw Conrad Murray?

A.

After Michael died. And I -- at the time I didn't know Michael was dead, because they had just

called me and told me to come out to the hospital. And I thought Michael might have been just sick.

Q. Did you know anything about Conrad Murray, AEG, negotiations, contracts -- anything like that

between the two?

A. No.