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2013 VIDEO>> http://youtu.be/Hsw2p0i8M8Y
Steven Randal Jackson by way of Video deposition
the following proceedings were held in open court, in the presence of the jurors:
Judge. Good afternoon, everybody. We're going to play some deposition testimony?
Ms. Bina. Yes, your honor.
Judge. Why don't you introduce your deposition.
Q. And was there a period of time when he was not Michael's manager and then was his
manager again?
A. Yes.
Q. All right. So had he previously been Michael's manager before he passed?
A. Yes.
PAGE 84:04 TO 87:03 (RUNNING 00:03:41.228)
Q. Mr. Jackson, the question was, did was there ever a time where someone told you that your
brother didn't want to see you but you demanded to see him any way and then went into his
house?
A. Yes.
Q. Did that happen on more than one occasion?
A. Yes.
Q. Did it happen -- how many times did it happen that you can recall?
A. Three or four times.
Q. Could you tell me about each of them, please?
A. Well, I don't remember each one in detail but --
Q. Anything.
A. Just wanted to make sure he was okay and get him help.
Q. So for those three or four times, where was he living at the time?
A. One of the times, Vegas, L.A., New York.
Q. You can remember those three times?
A. Yes.
Q. Okay. And you said that you wanted to make sure he was okay.
A. Yes.
Q. If -- in what order did these occur, chronologically? Was Vegas first, then L.A., then New
York?
A. That's what I don't remember.
Q. Don't remember. Okay. Let's take Vegas, then, first. Why would -- why did -- were you
concerned that your brother might not be okay?
A. Because I had received a call that he had been abusing prescription drugs.
Q. And who did you get that call from?
A. Grace.
Q. Are you aware whether she called anyone else?
A. Not sure.
Q. And this -- do you remember when this happened, what year?
A. Not sure.
Q. Was it after the trial that you were speaking of earlier?
A. I know it was around that time. I don't know if it was before or after. I'm not sure.
Q. And was your brother staying at his house at the time in Vegas?
A. Yes.
Q. And when you went to see him that time, did you go by yourself?
A. No.
Q. Who did you go with?
A. With Jackie, Rebbie, I think Janet or Mar- -- I think Marlon. I'm not sure. I'm not sure.
Q. And for the people who went with you --
A. Yes.
Q. -- did you tell them that you had had this call with Grace?
A. Yes.
A. Yes.
Q. Did you confront your brother every time that Grace told you?
A. Yes.
Q. Okay. Let's finish Vegas first and then go to the others. So Grace told you. You had a
conference call with several of your siblings, and then several of them went with you to Vegas?
A. Yes.
Q. And if I understand correctly, you were told that Michael didn't want to see you?
A. Yes.
Q. And who told you that?
A. Security.
Q. And did you attempt to see your brother anyway?
A. I just -- yes.
Q. And what did you do?
A. Just drove in and walked in the house.
Q. Did they let you come into the house?
A. The gate was open. We just drove in and walked in.
Q. So you didn't go through the gate or anything as dramatic as that?
A. No.
Q. Okay. And was the house open?
A. Yes.
Q. And did you see your brother?
A. Yes.
Q. And what did you say to him?
A. I told him I was taking him to rehab.
A. Uh-huh.
Q. And during those few hours, did your broth- -- you said your brother didn't say he had
problem with prescription drugs; is that correct?
A. No, he didn't say it. He didn't say he didn't.
PAGE 91:03 TO 92:14 (RUNNING 00:01:50.337)
Q. Okay. Did he say anything about what you were saying Grace had told you?
A. He just said he's fine. "Don't worry. I'm fine. I'm okay. I'm not going to go."
Q. Okay. So he just said he was okay?
A. Uh-huh.
Q. Did he seem okay?
A. At the time, yes.
Q. So you didn't think he had -- did you think he had a problem at the time?
A. Yes.
Q. And did you leave there thinking he had A problem?
A. Yes.
Q. And did you ever discuss it with him again after that day?
A. Yes.
Q. When did you next discuss it with him, if you can recall?
A. But that day may have been the last time, maybe. Now, that's -- there were prior times.
Q. Got it. Now that you recall that that may have been the last time you discussed it with him,
does that refresh your recollection as to when it happened?
A. It was just around the Santa Maria trial.
Q. But you don't know if it was before or after?
A. It was after, I think.
Q. And from that time until the time of his passing, you never discussed it with him again; is that
correct?
A. No.
Q. And was there a reason why you never discussed it with him again?
A. I hadn't gotten a call from Grace or anyone like that.
PAGE 92:15 TO 93:11 (RUNNING 00:01:03.100)
Q. So did anyone ever tell you that they thought your brother had a problem after that day in
Vegas? And by "a problem," I mean a problem with drugs.
A. Leonard Rowe would tell me that.
Q. Excuse me. Leonard Rowe?
A. Leonard Rowe, uh-huh.
Q. When did Mr. Rowe tell you this?
A. When?
Q. Yes.
A. I guess around the time the shows in London were being prepared.
Q. So sometime in 2009?
A. No. No, let me correct that. Initially, we were playing our tour. And Rowe was around. The
brothers touring. That was the initial plan. And there was concern then.
Q. And who expressed that concern? Was that Mr. Rowe?
A. Yes.
Q. Did anyone else?
A. No.
PAGE 98:21 TO 100:16 (RUNNING 00:02:05.727)
Q. Okay. So going back to where we started, you talked about the time in Vegas.
A. Okay.
Q. Did you ever discuss that time with your parents?
A. In Vegas or --
Q. The time where you and your siblings went to talk to Michael about what Grace had told you.
A. Yes.
Q. And can you recall what their reaction was?
A. Displeased.
Q. With?
A. Him not getting the help that he needed.
Q. Do you know if they ever talked to him about what Grace had told you after you told them?
A. Did they --
Q. Talk to Michael?
A. Did they talk to him?
Q. Uh-huh.
A. I don't know.
Q. Okay. Now, did you have any professionals with you, something like a doctor?
A. Yes.
Q. What was the doctor's name?
A. I forgot his name.
Q. Was it --
A. Yes, I did.
Q. And was this doctor -- who brought the doctor into the mix?
A. No.
Q. Did you ever speak with them after that day?
A. No.
PAGE 105:17 TO 105:23 (RUNNING 00:00:22.215)
Q. Who was at the house besides Michael, if anyone?
A. Just security.
Q. And was there anyone else present when you had this conversation with Michael at his house
other than the people you've already mentioned?
A. Not that I know of.
PAGE 105:24 TO 108:07 (RUNNING 00:02:13.646)
Q. Okay. Now, that's the Vegas time. You mentioned another one was in New York?
A. Yes.
Q. And if I understand, you now believe that happened sometime prior to the Vegas time;
correct?
A. Yes.
Q. And you indicated that each of those times you were worried about your brother?
A. Yes.
Q. What was the basis of your worry in New York?
A. Prescription.
Q. Let me ask, each time this occurred, was it the same concern?
A. Yes.
Q. Okay. And what was the basis of your concern this time, the New York time?
A. Prescription abuse.
Q. And -- but why were you concerned? Had Grace called you?
Q. Janet?
A. Yes.
Q. Okay. Anybody else?
A. Yes. That's it.
Q. And did she say why she believed that Michael was abusing drugs at this time?
A. Why?
Q. Why she believed it.
A. She just said, "You need to get down here."
Q. She didn't say why she believed that you needed to?
A. She didn't need to say. I mean --
Q. And why didn't she need to say?
A. Because, my brother.
PAGE 108:15 TO 109:15 (RUNNING 00:00:37.326)
Q. And did you take any doctors with you this time?
A. No.
Q. Did you take anyone beside the your siblings?
A. Just family.
Q. Okay. And was this one of those times where you wanted to see him and he said he wouldn't
see you?
A. No.
Q. So he agreed to see you?
A. I guess. I just sort of walk in, so --
Q. Okay. And -- that can happen. And what happened?
A. He wouldn't go.
Q. Excuse me?
A. He wouldn't go.
Q. The same thing happened this time that happened in Vegas?
A. Yeah.
Q. And did you each, once again, tell him to go?
A. Yeah.
Q. And did he, once again, tell you he wouldn't?
A. Yes.
PAGE 109:16 TO 109:25 (RUNNING 00:00:19.354)
Q. And how long were you there this time?
A. A few hours.
Q. And this time did he say he wasn't abusing prescription drugs?
A. I don't recall.
Q. Do you recall if he said he was abusing prescription drugs?
A. I don't remember the details of that --
Q. And --
A. -- conversation.
PAGE 110:01 TO 110:12 (RUNNING 00:00:28.588)
Q. Did he end up going to rehab this time?
A. No.
Q. And did you talk to your parents about it at this time?
A. No.
A. Just us.
Q. Just you. Did he clean up after the Vegas intervention as well?
A. Yes.
Q. And how long after that did he clean up?
A. He was clean for -- he stopped using those things. As far as I know, he stopped using it.
Q. And where did you learn that from?
A. I learned it from Grace. Pretty much Grace.
Q. Anybody else?
A. No.
Q. All right. Do you know how he cleaned up after you went to New York?
A. I don't know.
Q. Did anyone ever discuss how he cleaned up with you?
A. No.
Q. And what about after Vegas? Do you know how he cleaned up after Vegas?
A. No.
24. PAGE 113:12 TO 117:03 (RUNNING 00:03:23.400)
Q. So there was New York. There was Las Vegas. What was the third place? I have to find it.
A. The ranch.
Q. Thank you. The ranch. Did the time at the ranch occur after the time in New York, if you
know?
A. Yes.
Q. And did you once again get a call from Grace?
A. Yes.
Q. And do you recall what she said this time?
A. Yes.
Q. Okay. And how long were you there this time?
A. A few hours.
Q. And did you leave believing that your brother had a problem at that time with prescription
drugs?
A. Yes.
Q. And did doctors go with you this time?
A. No.
Q. So was it just family?
A. Yes.
Q. And did Michael this time deny that he had a problem with prescription drugs?
A. Yes.
Q. And he also, if I understand -- and I think you already said this. He also refused to go to
rehab; correct?
A. Yes.
Q. And -- but you didn't believe him when he said he didn't have a problem?
A. No.
Q. And did --
A. Yes, I didn't believe him.
Q. And did any -- did you discuss your not believing your brother with any of your siblings?
A. Yes.
Q. Who did you discuss it with?
A. Just leaving there, we all talked about it.
Q. Okay. And did anybody else indicate to you that they didn't believe that he wasn't abusing
prescription drugs as well?
A. In my family?
Q. Uh-huh.
A. Yes.
Q. And who was that?
A. Rebbie, Janet, you know, all of us.
Q. How about your mom?
A. Did my mom?
Q. Yeah. Did your mom say whether she believed he was abusing or not at the time?
A. My mom didn't believe it, but then she's my mom. She doesn't want to believe it, maybe. I
don't know.
PAGE 119:10 TO 119:13 (RUNNING 00:00:05.232)
Q. Now, did your brother end up going to rehab after you -- this attempted intervention at the
ranch?
A. No.
PAGE 119:16 TO 120:05 (RUNNING 00:00:38.115)
Q. You said the other two times your brother got clean afterwards?
A. Yes. The Vegas time, as I recall. I know that one because that was when I was helping him,
and I watched the cleanup. But I was around, and I think that, you know --
Q. When you say you were helping him, what do you mean?
A. With -- that's around the Santa Maria time.
Q. Got it.
A. So I watched things change.
Q. And did he talk to you about the fact that he was cleaning himself up?
A. No. He just did it and got ready for the 05 trial.
PAGE 120:09 TO 120:15 (RUNNING 00:00:10.829)
Q. Did Michael ever discuss with you that he believed he ever had a problem with prescription
drugs?
1
A. No.
Q. Did he ever discuss any drug problem with you ever?
A. No.
PAGE 120:16 TO 121:17 (RUNNING 00:01:24.976)
Q. So after the -- you were at the ranch, you said, a couple hours this time?
A. Yes. Two or three hours.
Q. And did you ever discuss Michael's drug use -- strike that. Did you ever discuss with Michael
that attempted intervention after that day?
A. The time at the ranch?
Q. Uh-huh.
A. Yes.
Q. When was that?
A. One other time with Janet.
Q. And when was that?
A. Maybe a month later.
Q. And where were you all, if you can recall?
A. The ranch.
Q. And who decided to bring it up?
A. We did.
Q. Do you know if your brother Michael ever took any medication to help him sleep?
1
A. Other than in the Murray trial, no, not before that, no.
Q. And I don't want to know what you learned there. It's prior --
A. No.
Q. -- to his passing.
A. No.
Q. Okay. Did you ever see Michael ever take any prescription drugs?
A. Never.
Q. Did you ever see him take any illegal drugs?
A. Never.
Q. Prior to your brother's passing, had you ever heard of propofol?
A. Never heard of it.
Q. Had you -- have you heard of it now?
A. Yes.
Q. Okay. And what about Diprivan?
A. Never heard of it.
Q. Okay. Did your brother ever discuss taking something called milk to help him sleep?
A. No.
PAGE 163:16 TO 164:04 (RUNNING 00:00:23.933)
Q. The first question is, do you know whether your brother ever used illegal drugs?
A. I never got a call about illegal drugs.
Q. What's that?
A. Yes.
Q. And when was that?
A. That was after the second attempt at intervention, around that time.
Q. And that was the one at Neverland?
A. Around that time, yes. The one my mother attended.
Q. And can you -- where did that conversation take place?
A. Where?
Q. Yeah.
A. On the phone.
Q. And did you initiate the conversation?
A. Yes.
Q. And what did -- how did you initiate the conversation?
A. How did I?
Q. I mean, did you say, "Mom, I think Michael" --
A. Yes.
Q. -- "has a problem"?
A. Yes. And I told her that we need to plan an intervention and -- and her being our mother,
because she was there.
Q. And she ultimately agreed to be there?
A. Yes.
PAGE 172:06 TO 172:08 (RUNNING 00:00:03.656)
Q. Now, did your mother ever tell you that she believed your brother had a problem with
prescription drugs?
Q. Okay. Was the conversation -- did you discuss the idea of putting him in a rehabilitation
center at that time?
A. Yes.
Q. And did you have one in mind?
A. Yes.
Q. Which one?
A. Bay area, San Francisco area.
Q. And how was that one chosen?
A. The same place where the interventionist worked out of that had gone with me to Vegas.
PAGE 178:09 TO 178:15 (RUNNING 00:00:08.985)
Q. Did you ever see him drunk?
A. Sorry?
Q. Drunk.
A. No.
Q. No. Did your brother drink alcohol?
A. I never seen him drink alcohol.
PAGE 179:11 TO 179:15 (RUNNING 00:00:10.507)
Q. From 2000 until the time that your brother passed, were there periods of time where you
believed he did not have a problem with prescription drugs?
A. Yes.
Ms. Bina. Your honor, the parties have stipulated that occurred in 2002 -- 2004, 2005, because
he's not clear on the record.
Judge. You mean the firing?
Ms. Bina. Yes, the firing of Ms. Rwaramba that he referred to there.
Judge. Thank you.
(excerpts of the videotaped deposition of Randy Jackson were played.)
PAGE 202:04 TO 203:17 (RUNNING 00:01:45.999)
Q. When you were with Michael on tour, did he seem to enjoy touring?
A. Yes.
Q. Why do you say that?
A. Well, because we like to tour, perform. Yes.
Q. Either while you were on tour with him as part of the Jacksons or while you visited him on
his solo tours, did you ever observe him under the influence of prescription medication while on
tour?
A. No.
Q. You never saw any signs?
A. On tour, no.
Q. Did you ever see any signs at other -- at other times other than what we discussed at your
last deposition, to the extent you remember?
Q. Anything else?
A. And then Grace would tell me -- his nanny, she would tell me all the time that, "You need to
get over here. Something's not right."
PAGE 203:23 TO 205:09 (RUNNING 00:01:49.633)
Q. Okay.
A. I went over to help him out and take everything away as I could. But, you know...
Q. To take the medications away?
A. Yes.
Q. Okay. Let's go back first to the one time at the Shadow Wood home that you saw him with --
when he appeared to be under the influence.
A. Yes.
Q. Why were you at the house at that time?
A. Why was I there?
Q. Yeah.
A. I wasn't there. I was called and I came over.
Q. Called by who?
A. I think it was Grace again who called me.
Q. Why did she tell you to come over?
A. She needed help with him. He wasn't doing so well.
Q. Did she say anything else?
A. We had discussed this before, her and I, so I kind of knew what was going on. So I went over.
Q. And what did you see when you went over there?
A. He was certainly under the influence of something that was altering his normal way of
functioning. And I -- I tried to get him some help.
Q. How did you try to get him help?
A. First thing I tried to do was take everything away, from Grace, too, because -- it was ironic
because she was the one giving it to him but at the same time complaining about it. So it was a
strange situation. It was upsetting to me because she -- I think she had a hard time saying no to
him. But she would go and get it for him and then give it to him.
PAGE 205:24 TO 206:20 (RUNNING 00:00:51.792)
Q. Do you know if the prescriptions were in Grace's name?
A. Yes.
A. I said -- I don't remember exactly what I said, but, you know, I was just kind of taken aback
by it maybe.
Q. Did you have concerns about Michael's drug use at that point?
A. Yeah, I did, pretty much.
Q. Did you take any further actions?
A. Yes.
Q. What did you do?
PAGE 209:18 TO 209:22 (RUNNING 00:00:17.013)
A. It's funny because you already know, but you ask. I'm sure you heard from everybody else all
the stuff I've done. I staged several interventions and set up -- tried to get him help many times.
PAGE 209:25 TO 210:09 (RUNNING 00:00:20.418)
Q. You mentioned that Grace was the one who would call you about his problems but Grace
was also getting him the medications.
A. Yeah.
A. few times I would meet her at the pharmacy and say, "What are you doing here?" Actually, I
would like -- when I found out that she was -- I would, like, race to the pharmacy. "What in the
heck are you doing? What are you doing?" She's like, "Oh" -- I would get upset.
Q. Yes.
A. It was a letter. I wrote it down on paper. It may have been -- I had my assistant copy it. Was it
a letter or was it an e-mail? I don't remember, but I know that everybody got a copy. It was very
important to me. Because not everybody in my family looks at their e-mail so you've got to --
Q. Got it.
A. The older people don't do that.
Q. Did you get responses from people in your family?
A. I think everyone was in shock, maybe a little denial. And I always got responses from the
people -- same people who really were more interested in really doing something about it.
Q. And who were those people?
A. My dad, Rebbie and Janet. Always those ones.
Q. What about your mom?
A. No. My mom, no. As a mom, I guess maybe it was hard for her, you know, for a mother to see
that. So...
Q. So when you did these four or five interventions at Neverland between 2004 and 2006, I
know the one that we talked about last time, there were a bunch of you that went, including your
mother, I believe.
A. One of them included my mom.
Q. For the other three or four, did anyone else go or was it just you?
A. Oh, no. Other people would come. Sure. Rebbie, Jackie. I had Jackie -- I just wanted as
many family members to be there, just -- Rebbie, Janet went on all of them except maybe one or
two. She was out of town. Jackie.
PAGE 214:16 TO 215:17 (RUNNING 00:01:16.406)
Q. Yeah. Describe to me the first one that you can remember in that set of three or four
additional interventions.
A. The first one that I can remember, the first one was at Neverland. Yes. The first one was at
Neverland.
Q. And this was not one that Katherine was at, correct?
A. No.
Q. Who was there?
A. It was Janet, myself, I want to say Rebbie. Maybe my mom was at that one. I think my mom
was there.
Q. So do you think now that she was at more --
A. Jermaine was there, myself. Jermaine was at that one. Jermaine was there as well.
Q. Do you think your mother was at more than one intervention at Neverland?
A. No, that was the one she was
at.
Q. Okay.
A. I'm trying to remember the sequential order of these. That was the one that my mom was at.
That must have been the first one.
Q. Was that in around 2002, I think you said last time? I could --
A. Yeah. 2002, 2003. Around that time.
PAGE 215:22 TO 217:02 (RUNNING 00:01:38.046)
Q. Let's move on to the next one at Neverland.
A. Yeah. I mean, same thing. My sisters were always, you know, really supportive, there all the
time. My sisters, Rebbie and Janet.
Q. Went with you the second time?
A. Yeah. Always with me. My dad, also. Very supportive of that.
Q. Did you bring any doctors with you that time?
A. No.
Q. Anyone else besides you, your sisters and your father?
A. No. No one else.
A. No. I mean, it happened over a period of time. When I was -- he stopped doing it, also. When
I was helping him with his situation in Santa Maria, I got him to stop. And I was able to do that
by firing Grace. So I was able to stop where it was coming in. And he really, really enjoyed
participating with his children. He had a great time, you know. Without anybody or any help, he
would take care of the kids, cook for them. He'd do all these things that he really enjoyed doing.
It was great. He was in a great place. And then somehow Grace came back around, and he
started using, doing it again. I was really upset about that.
PAGE 221:25 TO 224:21 (RUNNING 00:03:58.799)
Q. Do you have an understanding as to about when he started using prescription drugs again?
A. He started, and I got him to stop again. He started right before the Santa Maria trial started,
and then I got him to stop. And I was able to get him to stop because I told Rebbie, "Don't leave
his side," because I didn't trust Grace anymore. I fired her again because I noticed there was a
pattern. Whenever she's around, he's wasted. So I fired her again. And I said, "Rebbie, don't
leave his side. Make sure you watch everything he does, because I have to get him in this
courtroom every day and see this thing through."
Q. So you got him to stop during the Santa Maria trial?
A. Um-hum.
Q. And then did you have an understanding that he started using prescription drugs again after
that?
A. No.
Q. No?
A. No.
Q. So all of the interventions you described were before the Santa Maria trial?
A. There was one after. You're good. The Vegas one was after. It was after.
Q. So you did have an understanding at some point after Santa Maria that he was using
prescription drugs?
A. I think the Vegas one was after. Yeah. Yeah. The Vegas one was after. And yes, he was using
again because there was a -- it was quite disturbing to me. There was a People Magazine article
that was coming out. It was going to talk about his drug use. And Grace had told him that I was
behind putting this article out. Grace and actually Raymone Bain because I fired them both.
They told my brother that I did this article, but I fired both of them. That's probably why they did
it. But they both said that. It had nothing to do with me. And I can remember that he had gotten a
lot of people in my family to sign a letter that was put in People magazine saying that he never
did drugs, never used them in an inappropriate way, kind of signed off on the letter. I was really
disturbed by that. I wasn't behind the article, but I wasn't going to sign a letter like that. It wasn't
true. The only people who didn't sign it was Janet, Rebbie, and my dad. And I was really
disturbed by that.
Q. Whose idea was it to have the letter?
A. His.
Q. Michael?
A. Yeah. It was his idea. I still get upset thinking about it.
Q. You didn't sign the letter, right?
A. No. Janet didn't sign it and Rebbie didn't sign it, I didn't sign it, my dad didn't sign it.
Q. Did your mother sign it?
A. My mom, La Toya, and all my brothers. But my mom, you know, she would never want to
believe it. She's a mom, you know. I felt bad for her because he would -- I felt bad for her. He
was -- he knew how to sweet-talk my mom. He knew how to do that. He was good at that.
Q. Do you think your mom ever believed he did have a problem?
PAGE 224:24 TO 225:01 (RUNNING 00:00:09.727)
THE WITNESS: I don't know. Did she ever believe he had a problem? Yeah, but I think she was
in denial. She didn't want to believe it.
PAGE 225:14 TO 225:23 (RUNNING 00:00:26.040)
Q. Did you ever talk to Michael about that letter?
A. No. He wouldn't want to talk to me too much because -- you know.
Q. Why not?
A. Well, because maybe I wasn't afraid to say no to him. So he would really -- he would, like,
get physical with me because -- and I wouldn't be afraid to say no to him. But he's like 90 pounds
so it wouldn't do much.
PAGE 227:19 TO 229:21 (RUNNING 00:02:48.477)
Q. Okay. So just jumping back for a second to when you said that you'd seen Michael in the
state that he was at Shadow Wood a few times, when were those other times and what do you
recall about them?
A. I mean, somehow, maybe during the trial -- before the trial actually started, you know,
maybe during the phase that we're at in this trial, I don't know what you call this, in the Santa
Maria trial, before the trial, the pretrial stuff, he -- I think he was really scared. And somehow, I
don't know how Grace did it, but they were able to -- I figured out, I don't know how, but she was
able to get him something. I don't know how she did it. Because it was like, "Man, I'm watching
everything." It's like -- and I think those were the times when he didn't -- he didn't want to go to
court. He didn't show up to court. And I was freaking out because it was on the news. I told -- I
went to the hospital and he said to me, he says, "I don't know what you're thinking. I'm not
walking into that courtroom so don't even think about it, Randy." And I said, "Okay." I said, "But
you're going to court." He goes, "No, I'm not."
Q. Was he in the hospital because he had had a reaction to his drug use?
A. No. He was in the hospital because he didn't want to go to court. But I think Grace -- she
was always around. And he seemed as though he was under some kind of influence. That
happened -- must have happened before the hospital. But we had him go to court and had the
doctor with him. She was somehow getting it to him. Then I later found out that she had gotten
him a patch. I was livid. That's how I couldn't catch it. Some kind of patch.
Q. Do you know what kind of a patch?
A. No. Whatever they put in those patches. I don't know.
Q. And was that what you think he had that day that he was at the hospital?
A. Yeah.
Q. And what signs was he exhibiting to you that made him seem under the influence?
A. Just slurry speech and all that. And he was really frightened to go to that courtroom. He
didn't know who to trust because people around him were lying to him, telling him things, just to
-- just to, you know, secure their positions.
A. Security guys.
Q. Do you know which one?
A. I don't know. I don't know them by name.
Q. What did they say to you?
A. Maybe "He's not here. He's not there." Stuff like that. I said, "Well, why do you have the gate
closed? Open it up. What's the big deal?" That's how I knew he was there.
Q. So what happened?
A. If somebody is not there, you let them in. Sorry?
Q. Did you just go home?
A. Yeah, I would go home.
Q. After you and your father tried to go to Carolwood, did you or your father take any other
actions with respect to seeing Michael or talking to him about his drug use?
PAGE 238:21 TO 239:02 (RUNNING 00:00:29.492)
A. What was the question again? Sorry.
Q. After you and your father went to Carolwood to try and see Michael that day that we just
discussed, did you or your father take any other actions to try and see Michael about his drug
use?
A. Yeah. Yes.
Q. Do you remember about what year?
A. It was a while back. Not terribly long -- let's see. Bill Bray was living. I don't remember the
year.
Q. Do you remember why Michael was in Taiwan?
A. He was doing shows.
Q. He was on tour?
A. Yeah. Yes.
PAGE 257:04 TO 257:15 (RUNNING 00:00:36.494)
Q. Sorry. That was a bad question. What spurred you to go to Taiwan?
A. The fact that he needed help. I think because he was far away, and, you know, we hadn't seen
him for a while. So probably we said, like, we need to go.
Q. Did you know that something was wrong at that point?
A. Well, I didn't know anything, but we had heard things. I forgot exactly how we heard it. It
was a long time ago. But that's why we went there, that particular one.
PAGE 257:19 TO 258:15 (RUNNING 00:01:29.980)
A. I mean, nothing -- I mean, yeah. I mean, but like brothers and sisters or family does. But
sometimes he would isolate himself and wouldn't want to. I just figured it was probably because
he didn't want people to hear his voice. Maybe for that reason.
Q. Because he might be using drugs?
A. Yeah.
PAGE 313:16 TO 314:24 (RUNNING 00:02:10.941)
Q. Were you in communication with AEG or anyone at AEG Live after Michael's death?
A. Yes, I was.
Q. When was that?
A. Well, after Michael died, everyone was shocked. There was so much going on. I was really
displeased with all the stuff that was going on in court and with the whole Branca and Weitzman
thing. We were still trying to figure out how to grieve, and these people are in court, and wills,
and this nonsense. And I'm, like, I haven't even buried my brother yet, and all this court stuff is
going on. And so I didn't want that to be, like, pushed to the side. So I said I'm going to give him
put together this memorial for him, and I did it at AEG with Kenny Ortega and those guys. I
did it. I was there at their office pretty much every day.
Q. Did you have a positive experience with AEG?
A. Horrible. No, I'm just joking. Yeah, they were -- they were nice. They were very nice. Yeah.
We just -- you know, I practically slept there. I put together the show with them. And my sisters
were doing other things. They were cleaning up some, also, still.
Q. Do you recall telling Randy Phillips that you see that Michael was fortunate to have AEG
involved in his return to the stage?
A. I don't remember saying that, but that doesn't mean I didn't say it. I kind of felt that way at
the time.
Ms. Bina. That concludes the videotaped testimony of Randy Jackson.
Judge. Okay. Thank you. Okay. We're going to adjourn for today, and I want you to return on
Monday at 10:00 a.m.
the following proceedings were held in open court, outside the presence of the jurors:
Judge. Okay. Did you want to talk about anything?
Mr. Putnam. No, your honor.
Ms. Cahan. Your honor, we have a couple of issues. There's one issue with the Dr. Sasaki
video that plaintiffs have raised, and I think the Slavit rulings that we got from you yesterday --
there's one where you had a question mark. I think it would just take a minute to go through.
Mr. Panish. You're doing those on Monday?
Mr. Putnam. One of them.
Mr. Panish. Which one?
Mr. Putnam. We haven't heard back from three people whether they can go Monday, so we're
just preparing in case.
Mr. Panish. Can I be excused? Mr. Boyle can handle that.
Judge. Yes.
Mr. Panish. All right.
Mr. Putnam. Good luck with your drive.
Judge. There's two volumes of Slavit?
Ms. Cahan. Slavit is one volume and Sasaki is one volume.
Mr. Boyle. I can give you Sasaki. I think Sasaki is not going to be very long.
Judge. Which one do you want to do first?
Mr. Boyle. I would say Slavit just because I think there's a couple more of them.
Judge. Okay.
Ms. Cahan. my only -- I was just going to address the one where you had a question mark,
your honor, which is it was as to plaintiffs' counter designation of 124-14 to 127-20. There was a
hearsay objection to -- from 124, line 25, to 125, line 5.
Judge. Okay. "did he tell you that he had been told by representatives of Mr. Jackson that they
would not be able to be produced?" "yes, he told me that no records would be available --" that
sounds like a hearsay statement.
Mr. Boyle. Your honor, we're not designating that for its truth. In fact, we're designating it for
the opposite, which is that it's probably not true. What this is in reference to is Dr. Slavit was
the doctor hired to do the insurance exam, and Bob Taylor was the broker, and so there was an
issue where they were trying to get Michael Jackson's medical records and, you know, they
weren't necessarily -- our position is weren't necessarily giving over all the medical records to the
insurance people.
Judge. To Slavit?
Mr. Boyle. Correct. Anything that would go to Slavit would have to go to, you know -- would
have to go to the insurance analysis.
Ms. Cahan. so these -- these records, just to give a little bit of context, your honor -- these
records were not part of Slavit diagnosing or treating Michael for anything. Dr. Slavit did his
insurance figures, wrote up a report, and then there was a follow-up request after the report for
some medical records, existing medical records of Mr. Jackson dating back three years to be
provided to the -- I guess the insurers were asking for them, so the insurance broker was asking
for them. So this is not a situation of Dr. Slavit needing to have the records and reviewing the
records to render some kind of diagnosis or treatment for Mr. Jackson. So it does distinguish it
from the vast majority of the statements that we're dealing with physicians either speaking with
other physicians or relying on records of other physicians.
Judge. But it seems to me you're offering it for the truth.
Ms. Cahan. and that's how it seemed to us, your honor. That's why we objected.
Judge. "he told me the records would be available for me to review." isn't that what you want to
show, that Slavit would have the records to review?
Mr. Boyle. No. We want to show that Mr. Taylor is lying because Mr. Taylor was involved in
communications with the AEG people about how they were going to get all of Michael Jackson's
records.
Ms. Cahan. your honor, this doesn't show that Mr. Taylor was lying, and as your honor ruled,
Mr. Taylor's deposition, which was not taken in this case but was taken in the other case, is not
admissible in this case. We don't want to create a whole side show about -- maybe plaintiffs do,
but we don't want to create a whole side show about what Mr. Taylor was doing. I don't see this
as an exception to hearsay because, as Mr. Boyle conceded, they're using it not for the truth but
to show it's not true. They're using the underlying statement to be analyzed as to the veracity of
what Mr. Taylor said, which is clearly hearsay.
Judge. I'm going to sustain the objection.
Ms. Cahan. thank you, your honor.
Judge. Do I have a ruling on there?
Mr. Boyle. You had overruled --
Ms. Cahan. you checked overruled with a question mark. And I didn't have anything else that
I wanted to address. I don't know whether Mr. Boyle --
Mr. Boyle. I did. I have a couple of other quick ones, and I don't know if counsel had a
problem. 121 to 123, page 121 to 123, lines 20 --
Ms. Cahan. the objection was just to 121, line 8 to line 19.
Judge. "I could not say anything about his condition in June"? That?
Ms. Cahan. uh-huh.
Judge. This is Dr. Slavit speaking.
Mr. Boyle. Right. Okay.
Judge. Dr. Slavit saying, "I could not say anything with regards to his condition in June, I can
only -- as to his condition in February."
Mr. Boyle. I don't see why that's objectionable.
Judge. What was the objection?
Ms. Cahan. The objection is it's outside the scope and calling for speculation. The next
question is the most problematic part. It follows, "same answer for do you have an opinion
within a reasonable degree of medical probability as to his physical or psychological condition in
may 2009?" he says, "I have no information as to any change within his mental medical
condition or mental condition or capabilities between February and may or June." he said the
only time he ever saw him was in February. The idea that -- there is an insinuation there,
obviously, that his health condition changed substantially. He doesn't have a foundation, he is
speculating, and he says, "I have no idea what he was like in May or June."
Mr. Boyle. No, no. The reason that's going in is because the point is he can't know, and so to
the extent the defense is showing Dr. Slavit saying, "hey, look, Michael was fine," it's like,
"okay. Well, Dr. Slavit, you didn't see how Michael was doing in June. You only knew how
Michael was doing when you saw him in February." that's the whole point. Now, if he would
have given how Michael was doing in June, that's probably speculation and should be out, but he
answered, "I can't tell you that because I don't know." and that's the whole point of why that was
designated, so I think that should be in.
Judge. All right. I'm overruling the defense objection.
Ms. Cahan. Your honor, that does leave an answer without a question, so I think to the extent
that you're inclined to overrule, it should start at 120, line 24, where the preceding question
begins.
Judge. Okay. 120, line 24.
Ms. Cahan. You had sustained the objection to that.
Judge. Yes, I think that's probably right. But I understand now why. Did I have a question
mark by that or you're just raising it?
Mr. Boyle. There was no question mark. We just thought that one maybe was, perhaps, an
error. There's a lot of these to rule on. You're batting 999, which is pretty good.
Judge. Well, sometimes you have to look -- what happens is you look at the specific thing, but
then you have to look at other things from other parts of the depo for context, and you point it
out to me and it makes more sense.
Ms. Cahan. it's a little bit of a puzzle.
Mr. Boyle. And I think there was one similar to that. Line 133, line 17 --
Judge. Page 133?
Mr. Boyle. I'm sorry. Page 133, line 17.
Judge. Okay.
Mr. Boyle. This would be -- now that you've ruled the way you did about the Taylor records, I
think you'll probably -- Michael was -- if your objection was going to say overruled to the
questions to Bob Taylor about records, then I think this would also be overruled. Maybe if you
take a look at it, you'll see what I mean.
Ms. Cahan. So are you arguing --
Mr. Boyle. I think they should both be in, but I see now --
Ms. Cahan. This is the same issue that we discussed previously, and the ruling should be
consistent. And, obviously, our position is that this is also hearsay being offered for the truth.
Mr. Boyle. The reason I raised it is because originally you overruled their objection, but if
you're changing that, then I can see why you would do this.
Judge. Whatever is consistent is --
Ms. Cahan. Which is how you had worked previously, your honor.
Judge. I sustained this one, but it was the other one I had a question on.
Ms. Cahan yes, you sustained this one. No changes to this one.
Mr. Boyle. I understand.
Ms. Cahan. thank you, your honor. And then did you want to talk about Dr. Sasaki?
Mr. Boyle. This will be brief, your honor. This is on the issue of Sasaki. We talked about this
before, the defense designated about Mr. Jackson inviting Michael Jackson to the house. And
you asked if we could work out a little bit about what happened at the house. There is a section
that we would like to play and we can't reach an agreement on whether or not it should play.
Judge. I think what happened was the relevance was on the part of the -- the defense argument
was, well, he had a pattern of inviting doctors to Neverland ranch, kind of befriending them so
that they would be more likely to do what he wanted them to do, I think is -- wasn't that your
argument, why that was relevant?
Ms. Cahan. Yes, our addiction experts opine that crossing the kind of boundary that most
people keep with their physicians, whether it's conscious or unconscious, is something that is
typically seen in people with addiction to prescription medication.
Judge. And your response was --
Mr. Boyle. We said, your honor, we should be able to at least show what happened at
Neverland so the jury can have a full picture about whether this was really drug-seeking behavior
or something else. Your honor made clear, "Mr. Boyle, I'm not going to let you put in the part
where he says what a nice guy Mr. Jackson is." I disagreed with it, but understood, but I said
there is some other language about what happened when he went to Neverland that I wanted to
put in.
Judge. Okay.
Mr. Boyle. It is page 120 -- I take that back.
Judge. Is this a salad for lunch?
Ms. Cahan. No, this is they read the bible together, your honor.
Mr. Panish. 203-21 to 204, line 20.
Judge. Begins "and, in fact"?
Mr. Boyle. Yes, your honor.
Judge. "and, in fact, he invited you and your family to his home, correct?" "yes." "based on
your experience with Mr. Jackson, Mr. Jackson was a religious man?" "I'll say he knew the
scriptures well."
Mr. Boyle. Then it stops at line 20. And so my argument would be that that's what they did at
the house, they read the bible together for ten minutes, and the jury should know that so they can
perhaps draw the conclusion that, "well, maybe Michael wasn't there just trying to get drugs from
the guy, you know."
Judge. He did a lot of things other than that, though, right?
Ms. Cahan:. Yes, your honor. I think there's testimony that they did a variety of activities.
And to be clear, our position is not that Michael Jackson invited Dr. Sasaki into the ranch, pulled
him into a private room and said, "can I have some drugs?" it's that with Dr. Sasaki and others,
Mr. Jackson had a habit of forming friendships with his physicians, and that's something that at a
general high level, our addiction experts are going to be speaking about.
Judge. The problem is -- but it would seem odd, though, that he asked him to come over but
there's no explanation of what happens when he's there, as though something nefarious is going
on.
Mr. Boyle. As if it's bad to be friends with doctors. Some people are married to doctors.
Ms. Cahan. Are you referring to me, Mr. Boyle?
Mr. Boyle. I know some people who are married to doctors. They're making it sound like it's
some nefarious thing, he invited him to the ranch.
Ms. Cahan. I believe your honor already allowed in the testimony where Dr. Sasaki said he
was invited to the ranch with his family and he spent the day there and had lunch there. I do
believe that's in, so I don't know why this page and a half about Mr. Jackson's religious beliefs
and practices that refers to the fact that ten minutes when they were at Neverland, they looked at
the bible is necessary to understand his family's visit to Neverland and spending the day there.
Judge. So there is some explanation of the tour of the ranch and having lunch there in the
designation, because I do think it would be a little strange to just say because of the drug-seeking
behavior, since that's kind of what you're describing, he befriends these people because he wants
them to do what he wants them to do, which is be more likely to give him drugs when he asks.
There should be some explanation of what really happens there. But if that's already been done,
then I don't think we need to go into --
Mr. Boyle. Your honor, or he befriends people because he actually has something in common
with them, and they're friends. And Dr. Sasaki says, "we spent about 10 minutes, 15 minutes,
talking about the bible."