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JACKSON V AEG LIVE July 22

nd

2013

JACKSON V AEG LIVE July 22 nd 2013 Katherine Jackson, recalled as a witness by the

Katherine Jackson, recalled as a witness by the plaintiffs, was previously sworn and testified as

follows:

Cross-examination (resumed) by Mr.

Putnam:

Q.

Good morning, Mrs.

Jackson.

A.

Good morning.

Q.

Feeling better this morning?

A.

Yes.

Q.

On Friday I only had you for about 20 minutes, and in that time, what we talked about

was the filing of your lawsuit in September of 2010. Do you remember that?

A.

Yes.

Q.

And right after that, I had started to talk about something we call discovery, where each

side asks the other side to give them relevant documents. Do you remember that we started to

talk about that?

A. Yes.

Q. All right. And you understand that there were a couple years of discovery in this case,

ma'am?

A. Yes.

Mr. Panish:

objection. It's irrelevant. We're in trial now. Discovery is irrelevant.

The judge:

overruled.

Mr. Putnam:

thank you, your honor.

Q. Mrs.

Jackson, I want to ask you

A. Little bit about that, if I may. You've been sitting here for most of the Last 12 weeks;

correct?

A. Yes.

Q. And you've seen lots of documents that have gone up on these screens from AEG Live

to AEG Live

and some even between people at AEG Live

correct, ma'am?

A. Yes.

Q. Lots of e-mails?

A. Yes.

Q. Lots of documents?

A. Yes.

Q. Have you seen lots of e-mails or documents of any sort from you?

Mr. Panish:

it's irrelevant. Objection. She doesn't use e-mail.

Mr. Putnam:

any documents. I'm cutting time, your honor. We're going to go through

them.

Mr. Panish:

it's irrelevant.

Mr. Putnam:

not irrelevant, your honor.

The judge:

overruled. Were there any e-mails from you?

The witness:

no.

Q.

In this discovery process, did you hand over any computers, ma'am?

A.

No.

Q.

What about any files? Did you hand over any financial documents, ma'am?

A.

No.

Q.

You mentioned that your son Michael would give you money in cash; correct?

A.

Yes, I did.

Q.

Okay. When that would occur, would you write that down anywhere?

A.

No.

Q.

You have a secretary; right, ma'am?

A.

I have an assistant.

Q.

An assistant? Is that Janice Smith?

A.

Yes.

Q.

And how long has she been your assistant?

A.

I'm not good with dates. I don't remember. Been quite a while.

Q.

Long time?

A.

Yes. She's been in the family a long time, but she didn't work for me that long.

Q.

When did she start working for you, ma'am?

A.

She's been in the family about 30 years or more. She started working for me, I guess,

about 15 or 20 years ago not 20. About 15 years ago.

Q.

Okay. And does she have an office?

A.

Yes.

Q.

Where is that office?

A.

At Hayvenhurst where my home is. Was.

Q.

I apologize. It's my fault. I missed the end of that. I'm not so good in hearing.

A.

It's in Encino where I was living at the time.

Q.

And that's speaking of Hayvenhurst, let me ask you a question. On Friday morning we

saw a kind of like a little documentary about your life. You remember, ma'am?

A. Yes.

Q. And in that presentation we saw your house on Jackson street in Gary, Indiana?

A. Yes.

Q. But you haven't lived there in about 60 years; correct, ma'am? Did I get the date wrong?

A. Yes, you did.

Q. 50 years?

A. Wrong.

Q.

How long has it been?

A.

It's been about 44 years.

Q.

Pretty good with that date. So 44 years since you've lived there. And since that time

you've lived at Hayvenhurst; right, ma'am?

A.

Yes. I'm not living there now, but I did.

Q.

But you still have Hayvenhurst; correct?

A.

Yes.

Q.

And the reason you're not living there now is because you're having it renovated again?

A.

Yes.

Q.

And right now you're living in a gated community in Calabasas; correct?

A.

That's correct.

Q.

So going back to Hayvenhurst, in Hayvenhurst, there's an office where Janice smith

works; correct?

A.

Yes, there is.

Q.

And when you would get monies from your son Michael

Jackson, would you let her

know that so she could write it down somewhere?

A.

No. Not all the time.

Q.

Not all the time. Sometimes?

A.

Well, it was a gift, so I didn't think that I needed to report it to her.

Q.

Okay. And so these monies that you were getting, you didn't report them anywhere, to

your knowledge?

Mr. Panish:

well, objection. Vague and ambiguous. Overbroad. He said, "Janice."

The judge:

overruled. You may answer.

The witness:

repeat the question, please?

Q.

of course, ma'am. You talked about getting this money from your son Michael

in the

past.

A.

Yes.

Q.

And I asked if you ever reported it to anyone anywhere.

A.

I might have mentioned it. My son took care of me. He paid for everything: food, shelter,

clothing. And when he gave me cash, it was just a gift from him. I didn't think I needed to

report it to everyone.

Q. So if I wanted to find out how much money Mr. Jackson gave you to pay for everything,

where would I look? Where would I find records like that, if you know?

A.

He didn't give me money to pay for everything. He paid it himself from his office.

Q.

Okay.

A.

And the cash he gave me was just for gifts for myself.

Q.

And are you aware of any records that show this being paid, ma'am?

A.

No.

Q.

You didn't give any records to show this, to your knowledge, did you?

A.

No, I didn't. I didn't see why I needed to.

Q.

Okay. Do you have an accountant, ma'am?

A.

No, I don't.

Q.

You don't have an accountant?

A.

No. Not a personal accountant.

Q.

Okay. And what about bank accounts? Do you have bank accounts?

A.

Now I do. And I had some then, but

Q.

You did have them then?

A.

Yes.

Q.

Are you aware of whether you turned over any of your bank account information?

A.

To who?

Q.

To your lawyers to give to us in this case.

A.

That's been years ago, I'm talking about.

Q.

Okay, ma'am. So in September of 2010, you started this lawsuit?

A.

Yes.

Q.

Did you have a bank account then?

A.

I don't think so. I'm not too sure. But I know my social security came to a bank, and I

think I I don't think I should have reported that.

Q. There's been a lot of testimony here over the Last 12 weeks that indicated that your son

was having financial problems. Certainly by the time of 2009. You heard that testimony?

A.

What year?

Q.

By the time of your son's passing, he was having financial difficulties. Have you heard

that testimony?

A. Yes, I have.

Q.

Did that come as a surprise to you?

A.

In a way, yes.

Q.

Why is that, ma'am?

A.

Because I know my son made a lot of money, and he had people working for him. One

fear that he had, a lot of times people that's okay. I won't answer that question.

Q. Let me ask it again. Were you aware at the time of your son's passing that he was having

financial difficulties?

A.

Yes.

Q.

And how were you aware of that, ma'am?

A.

I had heard it.

Q.

Who did you hear it from?

A.

Different people.

Q.

And if you know and you knew that at the time when he was still alive, ma'am?

A.

Uhm, I found out.

Q.

And did you find that out after he passed?

A.

Well, they'd been saying for years, I would say the Last 15 years, that Michael

Jackson

was broke, and he wasn't. So I didn't know how to believe any of that.

Q. Well, that's what I

A. And then, too, all down through the years, people were taking monies from him, also.

Stealing, I should say.

Q. What makes you think people were stealing from him over the years, ma'am?

A. I well, I hear a lot of stories about people made deals for him, a lot of them wanted

money under the table. Things like that.

Q.

And who did you hear that from, ma'am?

A.

Just different people.

Q.

Were any of those people your son Michael

Jackson?

A. Yes.

Q. So your son Michael

under the table when they were making deals with him?

Jackson had told you over the years, people asked for money

A. Not with him. Making deals for him, and the people they made deals with came back and

told him.

Q. So people who were making deals for your son on his behalf? For your son?

Mr. Panish:

unintelligible. Objection.

The judge:

overruled.

The witness:

repeat your question.

Q. so your son Michael

making deals for him and that they would take money for making those deals?

Jackson told you would come to you and say that people had been

A. They were asking for money, and some of them would take money. But I don't want to

get into this. I've just all this is what I heard from my son. And what does this have to do with

the death of my son?

Q. I'm trying to understand what you knew at the time of his passing, ma'am, because in

many ways you're the only person we can find that out from.

Mr. Panish:

objection to the narrative question of counsel.

The judge:

overruled.

Q. so, ma'am, at the time of his passing, did you have an understanding from your son

Michael

that he was having financial difficulties?

A.

I think I answered that.

Q.

If you did, ma'am, I didn't understand it, so let me just ask. Did you know that from your

son Michael

?

A.

No. He never told me that.

Q.

He never told you. So that's not a discussion you ever had with him?

A.

No.

Q. And but you said that you had been hearing for years that he was bankrupt and that he

was having money problems; is that correct?

A. I didn't say bankruptcy.

Mr. Panish:

objection. Misstates what she said.

The judge:

sustained.

Q.

you heard for years that your son was having financial difficulties?

A.

I heard for years that Michael

Jackson was broke. And he wasn't.

Q.

And having heard this for years, did you ever bring it up to him and say, "I hear you're

having money trouble"?

A. No.

Q. Did you ever tell him that you'd been hearing that he was broke?

A. No, because I didn't believe it because he wasn't.

Q. Mrs.

damages. Are you familiar with that?

Jackson, you're aware that in this lawsuit, you're suing for an amount of

A.

You can talk to my lawyers about that.

Q.

You talked to your lawyers about that?

A.

I said, "you can."

Q.

Okay. I want to ask all I want to understand, ma'am, is what you understand; okay? So,

for example, you saw that in your attorney's opening statements, he talked about the idea of it

being between 1.5 and $1.7 billion?

Mr. Panish:

questioning of a plaintiff under Rifkind vs. Superior court, getting into factual contentions of a

plaintiff. If we need to go to sidebar, I have the cases. These are not appropriate questions.

Plaintiff can't say how much money they're asking for. Not something a plaintiff does. The jury

your honor, first of all, that's not what I said. And number two, this is improper

decides that.

The judge:

okay. Let's go to sidebar and see the cases you're talking about.

Mr. Panish:

yes. Sure.

(the following proceeding was heard at sidebar:)

Mr. Panish:

discovery, have you provided documents, we already heard in the cross-examination of Mr.

Erk about this 60,000 documents that AEG Subpoenaed from all accountants regarding Michael

Jackson's financial condition. So now for them to keep going in with this 83-some-year-old

witness, "did you have this document?" "did you have this document?" it's not appropriate.

Number two, factual contentions of a party are things that a lawyer does, not what a party does,

and that's what the Rifkind case is. And we went through this in the deposition extensively with

Mr.

contention for that," and that's not appropriate. And the case is Rifkind vs. Superior court.

first of all, I mean, for example, asking Mrs.

Jackson these questions on

Putnam when he was asking questions, "give us the factual basis for this," "give us the

The judge:

I need to look at it.

Mr. Putnam:

yes. The difference of the time, your honor, because

Mr. Panish:

I just wanted to give the citation of the case for the record.

The judge:

okay.

Mr. Panish:

22 cal.app.4th 1255. Rifkind, r-I-f-k-I-n-d, vs. Superior court. 1994.

Mr. Putnam:

and what the case makes clear, your honor we didn't understand at the time

how he could make a contention, couldn't understand what the plaintiffs' factual contentions

were. And so on the first day when we had her for a couple hours, they wouldn't let her answer

all of these questions. And I indicated, "you know what? I'm going to have to talk to the court

so I can understand what the basis of her claim is." and they said, "Rifkind, Rifkind, Rifkind."

and so we went off and read it and came back and explained to them that's not what the case

represents, your honor. What the case represents is not a very difficult idea, legally. I can't ask

for the legal basis. I can't ask her what the legal contentions that you're making here. I

understand that, and I'm not asking those. What I'm asking of her, your honor, is something I'm

very much allowed to do, which is to find out what her basis is factually. And in fact, your

honor, if you will recall, we had an argument about this very aspect that we're doing right now,

which is the aspect of her damages claim at the beginning of this case where you asked us to

come in with briefings. Ms. Chang argued it. I argued it. We came and talked about these

things. And you ruled twice at that time. And I can give you the cites of the trial transcript if

you like.

The judge:

that's okay.

Mr. Putnam:

okay. But, no, of course you can go into that arena. They can ask counter

questions, but we can go into that.

Mr. Panish:

you never ruled that.

The judge:

let me see Rifkind.

Mr. Panish:

statement of damages, which she's never seen.

sure. And, your honor, what he's going to try to do now, I think, is get into the

The judge:

sounds like it's dealing with depositions.

Mr. Panish:

testimony.

The judge:

trial?

Mr. Putnam:

no.

Mr. Panish:

deals with the testimony. Same thing. Deposition testimony, trial testimony. I

mean, this is totally inappropriate. It's a lawyer's work product of what is claimed, what are the

contentions, what's the complaint. That's the lawyer, not the client. And I'm going to go next. If

he finishes all this, then I'm going to go up on the stand, and we're going to discuss it all. Ms.

Chang: it basically stands for the proposition that someone who is a non-lawyer plaintiff cannot

be asked the basis for bringing legal claims and why, and what her factual understanding is, for

the same and simple reason that plaintiffs never know. And it's like an unfair trap by a lawyer to

say that they didn't understand or whatever. And she, of all people, hired attorneys, trusted the

attorneys to do their thing.

Mr. Panish:

doesn't know they

"and what is your claim for negligence?" it's the same thing. The plaintiff

The judge:

that would be asking a legal question.

Mr. Panish:

but it's the same thing. What is your claim for damages? That's a legal basis

Mr. Boyle: here's the distinction, your honor. They try to get around this by saying, "oh, we're

just asking for her factual contentions." if this were a medical malpractice case, that would be

like asking the mother of the child, "well, what are the factual things that the doctor did wrong

that" you know what I mean? Or if this were a products liability case, "what are the facts that is

the defective design in the aviation cooling system?"

The judge:

Mr. Boyle: right.

that's calling for expert

Mr. Panish:

thing. Legal conclusion. Interesting, Mr.

saying "legal conclusion." their expert. It's asking for legal conclusions of a percipient plaintiff,

a non-expert plaintiff. And that's what that case interesting, in that case, the witness was a

lawyer that was being deposed. And the court says it doesn't matter if you're a lawyer or what

you are. That's the work product and the legal contentions of the lawyer, not of the party. Ms.

Chang: and I just want to clarify. The argument that I made at the beginning of the trial was for

them to be permitted to read from a document that was really not filed with the court. And the

so is this damages. "what are your claimed economic damages?" expert. Same

Briggs wouldn't answer any of these questions,

purpose of it was just to give notice in the event of a default, and that it was never intended to

be used as an affirmative pleading in the case. That's what I argued and made a record of. And

we overruled on that, and he was able to use that $40 billion on

Mr. Putnam:

and the reason, your honor, that it was overruled

The judge:

let's hear the question first.

Mr. Putnam:

is the case law didn't support the argument.

Mr. Panish:

the

Mr. Putnam:

yes. I can go through the case law.

Ms. Chang: we don't need to argue that.

Mr. Putnam:

understand is, we have had two different figures in this case: there's the $42 billion figure, and

now we have $1.5 billion that happened within a span of four months.

it says completely the opposite of the argument made. What I don't

The judge:

when was the $40 billion?

Mr. Putnam:

on December 3rd, 2010.

Mr. Panish:

it was a statement of damages that she's never seen.

The judge:

yeah.

Mr. Panish:

that's totally inappropriate. So what they're trying to say

Mr. Putnam:

that's not inappropriate.

Mr. Panish:

can I finish, please? Well, the statement of damages she's never seen says this,

now it says this; therefore, something must have happened. Now they are getting into legal

conclusions.

The judge:

if that's where you're going, that sounds like you're asking legal questions

about a statement of damages that the lawyers file.

Mr. Putnam:

but the lawyers

The judge:

that she doesn't know anything about.

Mr. Panish:

it's not even filed.

Mr. Boyle:

not even filed.

Mr. Putnam:

an element of what they're saying they believe their damages claim is, and they are an agent of

the person. If you look at it, it says, "Katherine Jackson hereby demands." that's what it says.

what it says, the case law says about that very thing; okay? That because it is

Mr. Panish:

she doesn't sign it.

Mr. Putnam:

and therefore I'm able to ask, "are you aware of this fact?" and that is clear.

And the reason the case law says and makes it very clear why is because of the fact that if

something is so out of whack this is what the case law says –

Ms. Chang: it does not.

Mr. Putnam:

is so out of whack with reality, the jury is allowed to assess that.

Mr. Panish:

what case is that?

The judge:

here's what I'm going to allow you to do: you're going to skip over this portion

of your questioning, and I want a brief on it.

Ms. Chang:

okay.

Mr. Putnam:

okay.

Mr. Panish:

and I want to know the name of the case he keeps saying that says this. What's

the name of the case?

Mr. Putnam:

the one that you cited on the record.

Mr. Panish:

what is it?

Mr. Putnam:

if you will let me finish, I will. And if you look at what we cited at the time

of this argument with ms. Chang, we went through

Ms. Chang:

I cited the case.

Mr. Putnam:

and then we came back with other cases that were cited, and they were cited

by ms. Strong at the time.

The judge:

okay. So, fine. I want a briefing on the issue. Let's skip over this.

Mr. Putnam:

i'll call her back.

The judge:

I'm sure you have at lot of other questions. But I want it in writing so I can

consider it; okay?

Ms. Chang:

yes.

Mr. Putnam:

I have one more thing for the record.

The judge:

and okay.

Mr. Putnam:

I also want to note for the sake of the record, Mr.

Panish indicated

several times he's going to call himself in reference to that. And I'd like to note we've done

actual research. Should he call himself in this matter, he does waive the areas he testifies about.

Mr. Panish:

good. Looking forward to you cross-examining me.

(the following proceeding was heard in open court:)

The judge:

Mr. Putnam:

you may continue.

thank you, your honor.

Q.

so Mrs.

Jackson, you've been here for the Last 12 weeks; correct? Almost every day?

A.

Correct.

Q.

And during that time, you have seen that various claims of damages have been made;

correct?

 

A.

Yes.

Q.

And I have a question for you in reference to you said, "what does this have to do with

this case?" Mrs. Jackson, do you believe that your son is in any way responsible for his passing

in 2009?

A.

No, I don't.

Q.

You don't; right?

A.

No.

Q.

And you never have thought he was in any way responsible; correct, ma'am?

A.

Repeat yourself.

Q.

And you never thought he was in any way responsible for his passing; correct?

Mr. Panish:

again, calls for a legal conclusion. Contention of the party.

The judge:

overruled. You may answer.

The witness:

repeat it.

Q. you, Mrs.

that correct?

Jackson, have never believed that your son had any part in his passing; is

A.

Correct.

Q.

But do you believe that your son was aware that Dr. Conrad Murray was providing him

with propofol?

Mr. Panish:

objection. No foundation, and it's also a legal conclusion. No foundation.

The judge:

sustained.

Q. Jackson, you attended the criminal trial of Dr. Conrad Murray; correct?

Mrs.

A. Yes.

Q.

In fact, you helped the prosecution prosecute that matter; correct? Did you assist the

DA.'s

office?

A.

I don't understand the question.

Q.

All right. There was a district attorney who was bringing that case on behalf of the city

of Los Angeles called David Walgren; correct?

A. Yes.

Mr. Panish:

it wasn't the city of Los Angeles.

The judge:

the people of the State of California.

Mr. Putnam:

people of the State of California. Thank you, your honor.

Q. and did you assist him? Did you help him bring that case, ma'am?

The judge:

well

Mr. Panish:

I mean, come on.

The judge:

they can bring a case regardless

Mr. Putnam:

regardless

The judge:

of what the parties want. Even if she didn't want to prosecute the case, the

dDA. Can decide to prosecute it. But I think it's a fair question to ask if she assisted,

cooperated with the DA, that type of thing. So, you know, rephrase it.

Q.

do you remember helping Mr. Walgren in his prosecution of that matter, Ma'am?

A.

No. I don't remember helping him, no.

Q.

Okay. Do you remember during that criminal prosecution, you heard that your son

Michael

Jackson had asked Dr. Conrad Murray to give him propofol?

Mr. Panish:

objection. Calls for hearsay.

Mr. Putnam:

I can ask if she heard it, your honor. And then I can ask if it surprised her and

discussed it with her.

Mr. Panish:

it calls for a hearsay response.

The judge:

overruled.

The witness:

repeat it again.

Q. of course. I'm sorry, ma'am. I will always repeat I know we talk a lot on the side, so

anytime that happens, just let me know. At that criminal trial at the criminal trial, ma'am, did

you come to learn that your son Michael

from Dr. Conrad Murray?

Jackson had specifically asked for the drug propofol

A.

I had heard it.

Q.

And you also heard during that criminal trial that he had asked for the drug from other

doctors; correct?

A.

I had heard that.

Q.

Are you saying you had or had not?

A.

I had not heard that from other doctors.

Q.

But did you hear that from the criminal trial?

A.

That my son had asked for propofol?

Q.

Uh-huh.

A. Yes.

Q. And you heard that he had asked that from Dr. Conrad Murray; correct?

Mr. Panish:

objection. Asked and answered.

Mr. Putnam:

trying to understand the answer, your honor.

The judge:

sustained. She's answered it.

Mr. Putnam:

okay.

Q. but you didn't hear during the criminal trial that he asked that from other doctors besides

Dr. Conrad Murray?

A.

I might have. I don't remember.

Q.

Don't remember?

A.

No.

Q.

And when you heard that your son Michael

Jackson had asked for propofol from Dr.

Conrad Murray, did that come as a surprise to you at the time?

A.

Yes.

Q.

And why is that, ma'am?

A.

Dr.Murray even though he asked for it, he could have said, "no."

Q.

And you had never heard strike that. Had you ever heard, prior to that criminal trial, that

your son Michael

Jackson was getting propofol from doctors at home?

A.

No.

Q.

That's not something you knew anything about; correct?

A.

Correct.

Q.

Now, you believe that your son hired Dr. Conrad Murray; correct?

A.

No, I don't.

Q. You don't believe that?

A. No.

Q. You've heard here testimony that Dr. Conrad Murray worked for your son in Las Vegas;

correct?

A.

Uhm

Mr. Panish:

well, I'm going to object.

The witness:

-- he didn't work for my son.

Q. okay. You haven't have you heard that testimony, though, here in the Last 12 weeks?

A. I might have heard it, but I didn't know what doctor. He got doctors for his children. I

don't know if it was Conrad Murray or not, in Vegas.

Q. And you understand that your son you've heard testimony that your son Michael

Jackson paid Dr. Conrad Murray for his services; correct?

A.

For the children.

Q.

Okay. But you've heard that testimony?

Mr. Panish:

your honor, I'm going to object to all this, "you heard that testimony?"

The witness:

no.

Mr. Panish:

it's irrelevant.

Mr. Putnam:

actually, your honor

Mr. Panish:

can I finish the objection, please? What she heard, what the testimony speaks

for itself.

The judge:

yeah. I think you need to follow up the question, if she heard it, yes. Then

Q. did you know before

The judge:

so

Mr. Putnam:

but the basis, your honor, is so much of this is what they knew at the time as

opposed to what they knew after.

The judge:

that's okay. You need to follow up with the question

Mr. Panish:

but it's irrelevant what she knew. They're not claiming anything against her.

Mr. Putnam:

she said she had the cLosest relationship with her son.

Mr. Panish:

but they're not claiming anything against Mrs.

Jackson.

The judge:

I understand that she's a plaintiff. I understand that. But just confirming she

heard something, we all heard it. So you need to follow up.

Mr. Putnam:

exactly.

Q. and so you heard the testimony of your grandson, prince Michael

hundreds wrapped in rubber bands. You remember that testimony, ma'am?

, that he gave stacks of

A.

He didn't say, "stacks."

Q.

Okay. What did he say, ma'am?

A.

He measured with his finger.

Q.

Uh-huh.

A.

And it was just a small amount.

Q.

Something like this; right (indicating)?

A.

Because he felt bad for Dr.Murray because he didn't have any money.

Q.

So you heard that testimony; correct, ma'am?

A.

I remember that.

Q.

Did you know that prior to hearing it at trial?

A.

No.

Q.

So you'd never heard that before?

A.

No.

Q.

And you just indicated that you don't believe that your son hired Dr. Conrad Murray;

correct?

A. No, I don't believe it, because I from listening here at court. I know I said it once, and

you'll probably bring that up, but I didn't really know.

Q. So what I'm about to bring up, what you're talking about, is the fact

A. Yes.

Q. that you've previously stated otherwise; correct, ma'am?

A. Yes, because someone had asked me, and there was a doctor. And not knowing that AEG

had hired him, I just said he hired a doctor.

Mr. Putnam:

all right. So I'd like to show that, your honor. Exhibit 13,468.

Mr. Panish:

I’ve never seen it, so could I see it?

The judge:

share it with plaintiffs. Ms. Chang: should we watch it somewhere?

Mr. Putnam:

it's the dateline interview that she's referencing herself that she is expecting

me to bring up.

Q. is this something you looked at in preparation for your testimony here today?

Mr. Panish:

well, how would she know? Objection. Foundation. How do we know? We

haven't seen it.

The witness:

I remember

The judge:

wait, ma'am. Hold on.

Mr. Putnam:

the dateline interview's out there.

Mr. Panish:

how do we know what it is if we haven't seen it? He just handed it to us right

now here.

The judge:

he didn't turn

Mr. Panish:

how are we supposed to know? How is she going to know if it's here

(indicating).

The judge:

let's skip this part so they have an opportunity to look at it. And then you can

go back to it.

Mr. Putnam:

this is cross, though, your honor. I don't have to give this in advance. Just

want to make sure it's understood.

Mr. Panish:

also, not on the list.

Mr. Putnam:

also what?

Q. so you're expecting me to ask this question. You just indicated that you know you said it

previously.

A.

Yes.

Q.

Why do you recall having said it previously?

A.

Because I knew you were going to ask me, because I know from hearing all the e-mails,

they had said they hired him. On television I had heard that they had hired him. But at the time I

hadn't heard it, and so there was a doctor there, and I thought maybe Michael

And I said it, not even knowing the facts.

had hired him.

Q.

And are you talking about your dateline interview, ma'am? Is that what you're talking

about?

A.

Yes.

Q.

And you've indicated that you have some difficulty with some memories here. How do

you remember that so specifically?

A. Because that's what you all talked about. Of course, I didn't say I didn't remember

anything. I said I might have difficulties at first. I said, of my 83 years, I might not remember

everything clearly.

Q.

But you do remember that you clearly stated previously that your son had hired a doctor?

A.

Correct.

Q.

And why do you remember that clearly? Just sticks out in your mind?

A.

I just answered that question.

Q.

So it sticks out in your mind as something you remember doing previously?

A.

It sticks out in my mind because this is what you've been doing all during the trial.

Q.

Okay.

A.

And your people have said that they hired him, and you've been trying to say, "no."

Q.

Are you talking about the line that Randy

Phillips says on the interview, that portion of

the interview on sky news? Is that what you're talking about, ma'am?

A.

I talked about what I had heard during the trial.

Q.

Do you recall him saying

The judge:

slow down.

Q. do you recall at any other time where that was said during this trial where somebody said

they hired Dr. Conrad Murray, other than that sky news piece with Randy Phillips?

A.

It's been on e-mail.

Q.

An e-mail said that we hired him?

A.

I believe so. I'm not sure, but I’ve heard that quite a bit here in this court.

Q.

You have? And I'm asking you what "quite a bit" you heard, ma'am.

A.

I answered that question.

Q.

This interview on dateline, when was the Last time you saw it, ma'am?

A.

I don't remember.

Q.

Have you seen it since you gave the interview?

A.

I don't remember.

Q.

You can't remember the Last time you saw it?

A.

No.

Q.

But you can remember precisely what you said?

A.

I answered that.

Q.

Do you know if you've seen it since the interview was actually conducted?

Mr. Panish:

she's already answered that.

The witness:

I answered that question.

The judge:

sustained. You're asking the same question.

Q.

do you recall when that interview was, ma'am?

A.

No, I don't.

Q.

If I were to tell you it was on June 25th, 2010, would that sound right to you, ma'am?

A.

I don't know.

Q.

What if I that would be the first anniversary of your son's passing. Would that refresh

your recollection as to when that occurred?

A.

No, it doesn't.

Q.

If I were to tell you that it was eight weeks before you filed the lawsuit, would that

refresh your recollection, ma'am?

A.

No. All I know is I remember hearing it.

Q.

And have you told strike that. You said that why did you say it at that time?

A.

Why did I say what?

Q.

Why did you say on June let's assume for a moment it's June 2010. At the time can you

recall why you said that your son had hired a doctor and that he could have prevented and

therefore your son could have prevented his own passing?

A.

I didn't say that.

Q.

You didn't, ma'am?

A.

I didn't say he "could have prevented his own passing."

Q.

What do you recall you saying, ma'am?

A.

I don't know exactly what I said, but I just said that I thought that

Q.

Sorry, ma'am?

A.

You're speaking of when I said he hired a doctor?

Q.

That's the part you can recall?

A.

Yes, I do recall that.

Q.

Do you recall any other part of it, ma'am?

A.

They asked me I can't recall exactly what was said, but then they said, "do you think his

death could have been prevented or" I can't remember all that, but I do remember saying he

hired a doctor that could have helped him.

Q.

Prior to your son's passing, ma'am, had you ever met Dr. Conrad Murray?

A.

No.

Q.

And had you ever heard of Dr. Conrad Murray prior to your son's passing?

A.

After he passed, I heard about Dr.Murray.

Q.

Had you ever heard about him before your son passed?

A.

No. Never heard the name.

Q.

And so is it fair to say, then, that your son never discussed what treatments Dr. Conrad

Murray was providing him with?

A. No.

Q. Prior to your son's passing, did you know that there was a doctor spending the night at

your at your son's Carolwood home?

A.

No, I didn't know anything about any doctors.

Q.

And you had you ever discussed, prior to the trial, with your grandchildren that there was

a doctor spending the night at the house?

Mr. Panish:

could call for attorney/client privilege.

I'd just object. Other than what was discussed with the attorneys. I mean, this

Mr. Putnam:

I asked for anything

Mr. Panish:

he didn't say that with the question.

The judge:

rephrase that.

Q. other than the conversations you had with your attorneys

The judge:

slow down so she can digest it.

Mr. Putnam:

I'm sorry, your honor.

Q. prior to trial, Mrs.

about a doctor spending the nights at the Carolwood home, other than any conversations you

may have had with your attorneys?

Jackson, did you ever have a conversation with your grandchildren

A.

I can't remember.

Q.

You can't remember, ma'am?

A.

Say the question again.

Q.

What I'm trying to find out, ma'am, is if you ever had any conversations with your

grandchildren prior to trial about a doctor spending the nights at the Carolwood home.

A. No.

Q. No. And so prior to trial, had any of your grandchildren ever told you that Dr. Conrad

Murray was spending six nights a week in the Carolwood home?

Mr. Panish:

well, first, object. Other than meeting with the attorneys and her.

Q. I don't want to have any knowledge, ma'am, of any conversations you had with your

attorneys. So what I'm asking about is whether you ever had any conversation with your

grandchildren without the attorneys

A.

No, I haven't.

Q.

And so was the first time strike that. You had your grandson prince testify here in the

Last 12 weeks

A. Yes.

Q. correct, ma'am?

A. Yes.

Q. And during that testimony, he said that Dr. Conrad Murray would spend the night in the

house; correct, ma'am?

A. If he said it, I don't remember hearing it. I'm sure he might have said that. I don't

remember him saying that.

Q. So you don't remember that?

A. No.

Q. Do you remember him saying that he would stay six times a week?

A. No.

Q. Do you remember ever learning anywhere, ma'am, about Dr. Conrad Murray except with

your attorneys do you remember ever learning anywhere prior to this trial that Dr. Conrad

Murray was spending six nights a week at your son's Carolwood home?

A. No.

Q. So that's something you didn't know at the time you filed your lawsuit; correct, ma'am?

Mr. Panish:

attorney/client privilege.

I'm going to object, your honor. I mean, it's seeking to invade the

Mr. Putnam:

I don't want to know anything

Mr. Panish:

no, but he says, "you didn't know," but then he needs to exclude conversations

with the children and attorneys all present. But by saying she didn't know, that's not true.

The judge:

questions exclude any conversations between her and counsel so she understands going

forward. You don't have to keep repeating. So why don't you

okay. Maybe you should have an agreement with Mrs.

Jackson that all your

Mr. Panish:

that's fine.

The judge:

discuss that with her.

Mr. Putnam:

just to be clear, your honor, I am allowed to know what facts she knew

The judge:

okay. I'm not disagreeing

Mr. Putnam:

because if it's a fact

Mr. Panish:

no. She can't tell if she got it from her attorneys.

The judge:

facts are fine.

Mr. Putnam:

exactly.

The judge:

what I'm saying is, maybe you can come to some agreement with her that your

questions

Mr. Putnam:

yes, your honor.

The judge:

exclude conversations with her attorneys.

Mr. Panish:

and/or grandchildren with attorneys present.

Q. Mrs.

seems forever

Jackson, I'm only going to have a little bit of questions with you. I know it

A.

I couldn't hear that.

Q.

Sure. I'm only going to have a little bit of questions with you. I hope to be able to finish

with you this morning, if I can. During the time I'm asking you questions, I don't want to know

about any conversations you had with your attorneys; okay, ma'am? That's an area I don't want

to know anything about. So if I ask you a question, and you know it from your attorneys, I don't

want to know that; all right, ma'am? That is something I don't want to know.

A.

Okay.

Q.

So as we move forward, and I ask questions, those conversations are separate; okay,

ma'am?

A. Okay.

Mr. Panish:

discussions with her grandchildren and attorneys all present or just her and her attorneys

present?

can I propose that we stipulate that any answers she gives exclude any

Q. unless it's facts, ma'am.

Mr. Panish:

to ask about that.

well, no. If she learned facts from her attorneys, that doesn't make him allowed

Mr. Putnam:

that's not true, your honor.

Mr. Panish:

it's absolutely true. It's totally privileged.

The judge:

okay. It's privileged. Let's go forward.

Q. so Mrs.

ever had a conversation with your grandchildren about Dr. Conrad Murray spending the night at

the house up to six times a week?

Jackson, prior to bringing your lawsuit on September 15th, 2010, had you

Mr. Panish:

same stipulations.

The judge:

you may answer.

The witness:

no.

Q. ma'am, you've indicated on friday that you thought this would be a search for the truth;

correct?

A. Yes.

Q. Don't you think that's an important bit of information for you in the search for the truth,

those conversations?

Mr. Panish:

well, again, calling for attorney/client information.

Mr. Putnam:

I'm not asking for any attorney information, your honor.

Mr. Panish:

yes, he is.

The judge:

I don't understand the question.

Mr. Putnam:

the question is this, your honor: she's made a very big statement, as she takes

the stand under Mr.

Panish, that the only reason she's bringing this is to search for the truth.

The judge:

right.

Mr. Putnam:

and therefore I think what's important is what that search involves. And how

she determined that, this is the only venue that she can get this truth.

The judge:

okay. All right.

 

Mr. Panish:

as long as she didn't learn it from the attorneys.

The judge:

all right.

Mr. Panish:

and the attorneys were involved long before the lawsuit was filed.

The judge:

Mr.

Panish, I think Mrs.

Jackson understands. You may continue.

Q. so Mrs.

for the truth?

Jackson, don't you believe that bit of information is important in your search

A.

What bit of information?

Q.

The fact that Dr. Conrad Murray was spending six nights a week at the carolwood home

and had been for some time?

A. It would be important, but I never I told you, I didn't know, and I didn't talk to my

grandchild about that.

Q. Did you ever talk to your grandchildren about the fact that Dr. Conrad Murray was

treating Michael

Jackson upstairs in a bedroom behind locked doors?

A. No.

Q. Is that something that you learned here at this trial?

Mr. Panish:

well

The witness:

I didn't learn it

Mr. Panish:

your honor, it's a real problem with these questions.

The witness:

yes.

Mr. Panish:

I want to make sure that she understands about I mean, because it all infers that

she doesn't know this.

The judge:

she may have learned it from her attorneys.

Mr. Panish:

yes. And I mean, it's really inappropriate questions.

Mr. Putnam:

not inappropriate questions, your honor.

Mr. Panish:

yes, it is.

Mr. Putnam:

there's a long line of case law

Mr. Panish:

what case?

Mr. Putnam:

about what a person knows, and when they learned it.

Mr. Panish:

which case is that?

The judge:

all right. So what is your question, again?

Mr. Putnam:

my question was well, she answered the question, which was the question of

whether she knew that her son Michael

behind locked doors upstairs, and she said she didn't know that previously.

Jackson was being cared for by Dr. Conrad Murray

Mr. Panish:

with the other stipulations.

The judge:

other than maybe her discussions with her attorneys.

Mr. Panish:

and what's the relevance of

The judge:

overruled.

Q. Mrs.

son's death, do you not?

Jackson, you do believe that Dr. Conrad Murray has some responsibility for your

A.

Of course.

Q.

And that's something you certainly believed for some time; correct?

A.

What do you mean by "some time"?

Q.

Well, since at least the time of his criminal trial?

A.

Yes.

Q.

And you saw that Dr. Conrad Murray was convicted criminally in that trial; correct?

A.

Yes.

Q.

And he's in jail now?

A.

I suppose.

Q.

Are you unsure of that?

A.

I can't prove it, but I hope he is.

Q.

And Mrs.

Jackson, is it true that you asked the district attorney to drop the $100

million restitution claim against Dr. Conrad Murray?

A.

Yes, I did.

Q.

Why did you do that, ma'am?

A.

Because Dr. Murray has children, he has no money, and his money should go to the

children. That's how I feel. I don't know, and I can't prove that, either. But I did drop it.

Q. If you can't prove that, ma'am, then why would you ask the district attorney to drop that

$100 million restitution claim?

A.

Because I felt that his children needed it.

Q.

And why is it that you believe that Dr. Conrad Murray didn't have that kind of money?

Mr. Panish:

I don't think she said that.

Mr. Putnam:

I think that was an exact quote, your honor.

Mr. Panish:

no.

The judge:

I'm sorry. She didn't say it? Is that what you're saying?

Mr. Panish:

yeah.

The judge:

overruled.

The witness:

well, from him asking for so much money a month, and it had been said that in

court that he didn't have any money.

Q. and so when you learned he didn't have any money, you asked the district attorney to drop

the $100 million restitution claim?

A. I asked him to drop it because of his children. He had quite a few children, seven or

eight, I heard. I don't know.

Q. And after you asked the district attorney to drop the $100 million restitution claim, did

the state of California then drop that part of their claim against Dr. Conrad Murray?

A.

Uhm, I didn't find all that out, but I imagine they might have.

Q.

Well, you were in the criminal court, weren't you, ma'am?

A.

Yes, I was.

Q.

And do you recall it being announced in the criminal court that you were dropping that

part of the claim?

A.

No, I didn't hear it in criminal court.

Q.

Okay. Mrs. Jackson, did you drop your restitution claim because of the effect it would

have on this lawsuit?

A.

No. I never gave it a thought.

Q.

Mrs.

Jackson, I want to talk about your son for

A.

Moment, Michael

Jackson. During his lifetime, you never witnessed him under what

you believe to be the influence of any drug, did you?

A.

No.

Q.

That's something you never saw; correct?

A.

I never saw it.

Q.

And you would visit his house sometimes unannounced?

A.

Yes.

Q.

And you'd get in; right?

A.

Yes.

Q.

And in those visits, you never saw him in any way that's been described as "loopy"?

A.

"loopy"?

Q.

Yeah. There's been some testimony about somebody talked about him being under the

influence and "loopy" or "out of it." did that ever happen on any of the those visits where you

stopped to see your son unannounced?

A.

No.

Q.

And you would talk to your son sometimes on the telephone; correct?

A.

Yes.

Q.

And do you recall ever having a telephone conversation with your son where he seemed

out of it?

A.

No. Out of what?

Q.

Well, I'm trying to see, was there ever a time you've seen a person drunk before; right,

ma'am?

A.

Yes.

Q.

And you've seen it sometimes, when a person is drunk, they act a little out of control?

A.

Yes.

Q.

And sometimes their speech is blurred (sic)?

A.

Yes.

Q.

And they see so when I say "out of it," I mean, you know, something that indicates that a

person is not quite themselves because in this instance because of some drug or alcohol, or the

like, that they might be taking; okay?

A.

Okay.

Q.

So was there ever a time that you saw your son Michael

Jackson like that?

A.

No.

Q.

Was there ever a time where you had a telephone conversation with him where he

seemed like that on the telephone?

A.

No.

Q.

But you indicated on Friday that your children had told you that they believed your son

was addicted to prescription medications; correct?

A.

Yes.

Q.

And those are your children who told you that?

A.

Yes.

Q.

And do you have any understanding as to why they told you that?

A.

Because they had heard it.

Q.

Do you know whether they had experienced him where they had seen him, and he

seemed out of it?

A.

No. They hadn't told me that he seemed "out of it," as you call it.

Q.

Is there a term you would prefer that I use?

A.

No, I wouldn't.

Q.

Okay. But you understand what I mean when I say that here; correct, ma'am?

A.

Yeah. Now I do.

Q.

So you had conversations with your children, and they said that they thought your son

Michael

Jackson had a problem with prescription medications; correct?

A.

Yes. But they had heard it.

Q.

And as a result of their saying that to you, you had a conversation with your son Michael

Jackson about it; correct?

A.

Uhm, that was much later.

Q.

Okay.

A.

Yes.

Q.

Let me make sure I understand that. So you had a conversation with your children where

they indicated that they thought that your son had

A.

Problem with prescription medications?

A.

Uhm, I wouldn't say, "a conversation." I just heard.

A.

Couple of my kids brought it to me that they had heard it out there.

Q.

And I asked if, whether as a result of that, you had a conversation with your son Michael

Jackson about it.

A.

I talked to him about it, yes.

Q.

Okay. And did you have that conversation in person?

A.

Yes.

Q.

And do you remember that conversation taking place in Las Vegas?

A.

Yes.

Q.

Now, just do you remember when that happened?

A.

Not I don't remember exactly the year or anything like that. But at that time he was

living in Las Vegas.

Q.

So one thing you recall is he was living in Las Vegas at the time?

A.

Yes.

Q.

In I don't want to go into the details, ma'am. I'm just trying to use it as a place marker.

You remember your son's criminal trial; correct, ma'am?

A.

Yes.

Q.

And you were there every day for that; correct?

A.

Yes.

Q.

And do you remember that ending in 2005?

A.

Yes.

Q.

And after that, your son left the country; correct?

A.

Yes.

Q.

And he never lived in Neverland again; correct?

A.

Correct.

Q.

He left the country for a period of time, and eventually he came back to this country;

correct?

A.

Yes.

Q.

And do you recall that he came back to this country sometime in 2006?

A.

No. I wouldn't know the year.

Q.

Do you know can you recall whether it was about a year after the criminal trial?

A.

Could have been.

Q.

But you do recall let me ask: you do recall, do you not, ma'am, that your son, when he

came back to the states, moved to Las Vegas; correct?

A.

Yes.

Q.

And that's where he was living when he returned to the states?

A.

I think he lived in Las Vegas he left he left Las Vegas and returned to Las Vegas. I don't

know the years. It was twice that he lived there.

Q. Okay. But I'm just trying to get a reference of time. He was living in Las Vegas up until

the time he moved back to Los Angeles and to Carolwood; correct?

A.

I can't say "correct," but I imagine. I don't know.

Q.

Is it fair to say that this conversation that you had with your son Michael

Jackson

occurred after he moved back to the states and was living in Las Vegas?

A.

I can't answer that question. I don't remember.

Q.

You do remember it was in Las Vegas?

A.

Yes.

Q.

And you do remember he was living there then?

A.

Yes.

Q.

And you do remember that he moved back to Las Vegas after he returned to the states;

correct?

A.

I don't really, I don't remember.

Q.

Okay. Well, I will represent to you, ma'am, that there's been testimony that your son

Michael

Jackson was living in Las Vegas from 2006 until 2008; okay?

A.

Okay.

Q.

Do you remember you said you remember it took place in Las Vegas.

A.

Yes.

Q.

Do you remember where the where it took place? Do you remember where you were

talking to your son when you had this conversation about the use of painkillers?

A. Yes. It was I was getting ready to leave, and there's a theater not too far from the door.

And we stepped inside the theater, and that's where I talked to him.

Q.

Let me ask a little bit about that. When you say, "not too far from the door"

A.

Front door.

Q.

The front door of the house?

A.

Yes.

Q.

And what house was this?

A.

In Las Vegas.

Q.

Was this the Palomar house?

A.

No.

Q.

What house was it, ma'am? Do you remember where the house was?

A.

No. I don't remember the street or anything.

Q.

Can you describe it? What was it like?

A.

Two-story house.

Q.

Uh-huh. Was it light?

A.

I don't even remember the color.

Q.

Okay. Do you know if the children were living in the house at the time?

A.

Yes.

Q.

Do you remember approximately how old they were?

A.

No, I don't.

Q.

Okay. So you stepped out of the house, and there was

A. Theater. Was the theater on the property?

A. I didn't step out of the house.

B.

Mr. Panish:

Mr. Putnam:

misstates what she said.

I apologize.

Q.

you said it was near the door?

A.

Yes.

Q.

Was the theater on the property?

A.

Yes.

Q.

So it was part of the house?

A.

Yes.

Q.

Okay. And so you're at the property, and you stepped into the door where the theater to

the house was; correct?

A.

Yes.

Q.

And you did this as you were getting ready to leave?

A.

Yes.

Q.

And this conversation was just between you and Mr. Jackson?

A.

Yes, it was.

Q.

And was this where you told him that you had heard that he was using prescription

drugs?

A.

Yes.

Q.

And is this the only time you ever had that conversation with him?

A.

Yes.

Q.

No other time ever in his lifetime where you had that conversation?

A.

Only time.

Q.

Okay. And is this the conversation that you mentioned on Friday where you said that

you didn't want him to end up that he would be like the others?

A.

That's right.

Q.

What did you mean by that?

A.

I didn't want to hear one mention that or one day that something had happened to him.

Q.

And when you told him this, that you had heard that he was using prescription drugs, he

denied it, didn't he, ma'am?

A.

Yes, he did. He didn't yes, he denied it.

Q.

And it didn't surprise you that he denied it, did it, ma'am?

A.

Well, I'm his mother. And quite naturally he'll deny it, because he wouldn't want me to

think that. And then

Q. And then what, ma'am?

A. I'm his mother, and no child is going to admit if he thinks that I'm thinking something

bad about him, he's not going to admit that then. It might not have been bad at all, but he's not

going to say "yes" to anything like that.

Q.

In fact, that was part

A.

And I know he was taking pain pills, prescription pain pills, for his ailments.

Q.

What ailments?

A.

For his pain in his head and for his back.

Q.

And at the time of this conversation with your son in Las Vegas, you knew that he was

taking pain pills?

A.

Yes.

Q.

And you asked him about it, and he denied it?

A.

I didn't know he was taking pain pills. I couldn't prove it. It's what I had heard.

Q. That's what I'm trying to understand, ma'am. So you had heard he was taking pain pills,

you asked him if he was taking pain pills, and he denied taking pain pills; correct?

A.

Yes.

Q.

And that didn't surprise you because you're his mother?

A.

I said it didn't surprise me, because your child is going to want and then they don't want

their mother worried about them. And then they I'm sure you understand what I mean.

Q. And I do, ma'am. And I'm trying but I'm trying to explore it so I can understand what you

mean to yourself what it is you understood and why. So at that moment you took him aside, you

asked him about this, and he denied it, and you said that didn't surprise you. You said that on

Friday as well. And you're saying it didn't surprise you because he wouldn't want his mother to

worry; correct?

A.

Right.

Q.

And this is the only conversation you ever had with him about him taking pain pills?

A.

Yes.

Q.

And so and this is sometime when you're in Las Vegas; correct?

A.

Correct.

Q.

Mrs.

Jackson, if you knew your son was going to deny it, why did you ask him?

A.

I like nothing.

Q.

Excuse me, ma'am?

A.

I'm not answering that question.

Q.

Why, ma'am?

A.

Because to me it doesn't make sense. I didn't know he was going to deny it, but he did.

Q.

Just so I understand, you didn't know he was going to deny it, but it didn't surprise you

that he did? Is that what I am to understand?

A. It's because he didn't want me to worry. He's my son, and if any mother asks a child if

they're on drugs or anything but he wasn't on drugs. I just talked to him about it. I didn't think it

was that serious that

Q. What's not that serious, ma'am?

A. That you have to drill me like this on him. Because if a child goes out and plays and does

something real ugly, and a parent asks him about it, he's going to deny it. And I'm sure you

understand what I'm trying to say. My child, he respects his mother, and he doesn't want her to

think that he's doing something that is bad. Or if it is bad, then it's not bad if it's prescription

drugs.

Q.

But he wasn't a child in the school yard, ma'am. He was a 50-year-old man; correct?

A.

He's still my child. And I'm still his mother, and he still wants my respect, and he still

wants to respect me.

Q. You said that you mentioned to your son that your children had heard that he was using

prescription drugs. But you never said to him that you heard that he was abusing drugs; correct?

A.

Correct.

Q.

This was just you were literally only asking if he was using them; correct, ma'am?

A.

I told him I had heard, and I didn't mention I had heard he was using them. I just heard

maybe I did. You're just getting me confused so you can have something to come back on me

for. I'm telling you the truth.

Q. Ma'am, I didn't say you weren't, and I'm not trying to just come back with something

else. I'm trying to understand what has occurred.

A. You do understand it, but you keep asking me the same questions, and i've answered it.

I'm sorry.

Q. Has there ever been a time, ma'am, where you believe that your son was abusing

prescription medications?

A.

No.

Q.

Now

A.

I knew he was taking them, but I didn't think he might have been abusing them.

Q.

And in this conversation at Las Vegas, when he said that he wasn't taking them, you

didn't know whether he was taking them or not at that time; correct?

A.

I just asked him the question because I wanted to make sure.

Q.

Now, Mrs.

Jackson, even though you've never believed that your son was abusing

prescription medication, you did participate in an attempted intervention of your son, did you

not?

A.

Yes, I did.

Q.

And that intervention was at the Neverland Ranch?

A.

Yes, it was.

Q.

And it was your children who asked you to help in this intervention, wasn't it?

A.

Yes.

Q.

And didn't you say on Friday that your children asked you to do so because they believed

that you, as his mother, might have some impact, and it would be important to this intervention?

A.

Yes.

Q.

And your daughter Janet Jackson participated; correct?

A.

Yes.

Q.

And your daughter Rebbie?

A.

Yes.

Q.

And your son Jackie?

A.

I don't believe Jackie I'm not sure, but I don't think he was there.

Q.

What about Tito?

A.

I don't think so. I'm not sure.

Q.

You don't know. What about Randy ?

A.

Randy was there, I think.

Q.

And La Toya?

A.

Yes, I think so. I don't remember who all was there.

Q.

Mrs.

Jackson, I'm going to show you something and see if I can help refresh your

recollection; okay, ma'am? Are you aware of a book that your son Jermaine Jackson wrote

called, you are not alone, Michael?

A. Yes.

Q. Do you recall looking at this during your deposition?

Mr. Putnam:

may I approach, your honor?

The judge:

you may.

Q. Mrs.

Jackson

Mr. Panish:

what page are you on?

Mr. Putnam:

356 to 357. Same as at the depo.

Q. Mrs.

(indicating), and goes through right here in the very beginning here where you see that it talks

Jackson, what I'm going to ask you to look at it is beginning right here

about

Mr. Panish:

well, your honor, if he wants her to read a portion, he should say, "please read"

The judge:

yeah. Just show her.

Mr. Panish:

and then ask if it refreshes her recollection.

Q. if you could read from here, ma'am, to here (indicating). And just so you know what's

coming, I'm going to ask you if it refreshes your recollection as to who was there and where it

refreshes your recollection as to when this occurred.

Mr. Panish:

yeah. Read it to yourself.

The judge:

read it to yourself, ma'am.

The witness:

(witness complies.)

Q. Mrs.

you that, and it's a little easier to read.

Jackson, I have a photocopy that's blown up a bit. If I may approach, I can give

A.

Okay.

Q.

This is that same thing starting there (indicating), and then goes to the next page

(indicating).

A.

Okay.

Q.

Okay, ma'am?

A.

(reviewing document.)

Q.

Did you have time to read that, ma'am?

A.

Yes.

Q.

Does that refresh your recollection as to who was at the intervention?

A.

No.

Q. It doesn't refresh your recollection?

A. Because it doesn't mean all of them were there, no.

Mr. Panish:

I think she answered the question.

Q. okay. Mrs. Jackson, so as you sit here today, and after looking at that, you still can only

recall that Janet, Rebbie, Randy and maybe you were there?

A.

Yes. I recall that.

Q.

Do you recall any of your other children being there?

A.

I don't recall Jackie was there.

Q.