Katherine Jackson V AEG Live August 21

st
2013
Dr. David Adams(Anesthesiologist)
Q. Would you please state your full name for the record.
A. David Jeffrey Adams, A-d-a-m-s.
Q. And what is your profession?
A. I am an anesthesiologist here in Las Vegas. Let's start with educational history. Where did
you go to medical school?
A. Western University of Health Sciences, which is in Pomona, California.
Q. What year did you graduate?
A. 1999.

Q. And did you do a residency?

A. I did. I did an internship at St. Johns Episcopal Hospital which is in Far Rockaway, New
York, for one year, followed by an anesthesiology residency at USC LA County Hospital.
Q. Was the residency the first time that you specialized in anesthesiology?
A. That is correct.
Q. Where are you currently employed?
A. Here in Las Vegas. I am an independent anesthesiologist. So I'm basically self-employed.
Q. What is PBS Anesthesia?
A. PBS is Physicians Billing Service. They are a billing service. The way that I work is I work
for the surgeon or medical provider that needs anesthesia. So the surgeon will call PBS who acts
as a scheduler, credentialed, and they basically do my schedule. Then we bill either the patient
or the insurance company. the biller follows the money and makes sure that I get a paycheck
every once in a while.
Q. Okay. So PBS is both the scheduler and the biller?
A. They are the central point for the billing and the scheduling. Now, when you work with the
surgeons, is that always in a hospital?
A. Or surgery center.
Q. Is it both?
A. Both.

Q. With the cosmetic surgeons, is it in their offices?

A. No. It's in a surgery center.
Q. Also surgery center? And are these always -- "always" is a big word. Are these usually
facilities you've been in before?
A. Yes, they are.
Q. Did you ever administer Propofol to Mr. Michael Jackson?
A. Yes.
Q. How many times?
A. Four.
Q. How did you meet Mr. Jackson?
A. Through Carlos Letilier, who is an oral surgeon here in town, and he referred me to Dr. Mark
Tadrissi who is a cosmetic dentist here in town, and I knew Carlos from working with him at
Sunrise Hospital.
Q. Okay. And let's start from the beginning. How did you first hear -- did you hear from Dr.
Tadrissi, is that who you heard from?
A. I did.
Q. Did it go through the center?

A. It went through PBS.

Q. So did you receive a call from them?
A. I received a call from PBS stating that Dr. Tadrissi would like to talk to me --
Q. Okay.
A. -- about a VIP patient that he had, and he didn't tell the center who that patient was. He didn't
tell the billing service, he just wanted to speak directly to me.
Q. And that's the message that you got from PBS; is that correct?
A. That is correct.
Q. So when you get a message like that, do you call the doctor's office? What happens next,
generally, not in this instance?
A. I believe they gave me the number and I called Dr. Tadrissi.
Q. What did Dr. Tadrissi say to you?
A. He said I have a VIP patient that's coming in for a few procedures and he wanted to know if I
was interested in doing the anesthesia.
Q. Did he tell you at the time who it was?
A. No. I asked.
Q. And did he tell you when you asked?

A. I believe he did.
Q. Do you remember approximately when this was?
A. This was June 2008.
Q. How long after your call with Mr. Tadrissi did the procedure take place?
A. I believe he called me on a Monday. We scheduled a physical exam, I want to say on that
Thursday, and the procedure took place the next week on a Tuesday, I believe.
Q. Okay.
A. I'm not sure if those are the exact dates, but that's sort of the time frame. Is that your usual
procedure when you have a new patient that you meet with them at some point prior to the
actual procedure?
A. Normally I meet the patient the same day of the procedure unless there's an opportunity to
meet with them prior to that, but it's not necessary and I normally don't do that.
Q. And why did you in this instance, if you can recall?
A. I realized the magnitude of who I was working with and I wanted to make sure that -- that he
was healthy and that he could -- there wouldn't be any problems.
Q. Now, did you ask Dr. Tadrissi whether you could meet with Mr. Jackson in advance; is that
how it works?
A. I believe he asked me how I wanted to handle it. I just said I wanted to meet with him, talk to
him, get a history and physical, and then we would schedule it for another day.

Q. And did you set that up or did Dr. Tadrissi's office?

A. Dr. Tadrissi's office set it up.
Q. Did you talk with anyone associated with Mr. Jackson other than Dr. Tadrissi prior to that
physical?
A. No.
Q. Did Dr. Tadrissi explain to you what procedure was going to be done?
A. He did briefly.
Q. Do you recall what that was?
A. They were cosmetic implants, dental implants, and he wasn't sure at that time if there was
going to be other work needed. He did need a root canal and some other work, but you would
have to talk to Dr. Tadrissi to figure out exactly what that work was.
Q. And is this the type of thing that you had previously given Propofol for before?
A. Dental procedures, yes.
Q. Before we get to your checkup of Mr. Jackson, I want to ask this question. For a procedure
like this where you're going to go in -- I think we are talking about implants, do you always use
the same type of drugs in those instances or are you directed what to do by the doctor? Like Dr.
Tadrissi, would he say use Propofol or would that be your choice?
A. I never discuss really the drugs I'm going to use with the doctor. I tell him what I require to
do the procedure, and there's going to be more than just one type of drug there because
according on what the reaction of the patient is, is going to determine which drug that I use. So

there are some -- like I would require a narcotic, Demerol or fentanyl, a benzodiazepine, which
is normally Versed. The best induction agent for that procedure would be Propofol. But I may
also request that etomidate is there, and normally there is a smorgasbord of medications there,
that are there, as well as the medications that are in the crash cart.
Q. Do I understand you to be saying -- hope so -- there's a whole bunch of options?
A. That is correct.
Q. And depending on the situation you'll determine what to use?
A. That is correct.
Q. And typically for these procedures, is Propofol the principal anesthetic that you're using?
A. Current -- or at that time, yes.
Q. Has that changed?
A. No, it's still the drug of choice. What I'm going to be asked to be entered as Exhibit 2 is a
three-page document with the Bates range of LACC0797 through LACC0799. And then the
second document which will be marked as Exhibit 3 is a three-page document with LACC0800
through LACC0802.
Q. On the third exhibit, have you ever seen this document before?
A. This one right here?
Q. Yes, sir.
A. That's my document.

Q. And that is a short form history and physical?

A. That is correct.
Q. Do you have an understanding as to what patient this was for?
A. Michael Jackson.
Q. So on this 5/27/08 meeting with Mr. Jackson, do you remember who was present -- actually,
why don't you walk me through it. Did you go to Dr. Tadrissi's office for this appointment?
A. I did.
Q. Was it in the evening, do you recall?
A. About five o'clock in the afternoon.
Q. And had you ever been to his office before?
A. Never.
Q. Did you arrive there before Mr. Jackson?
A. I did.
Q. So did you meet Dr. Tadrissi prior to Mr. Jackson's arrival?
A. I did.

Q. And did you talk about the upcoming procedure for Mr. Jackson?
A. I believe we did.
Q. Do you recall what was spoken about?
A. He just said he was going to do some procedures and Michael didn't want to feel it, didn't
want to know about it, and give him anesthesia. Wasn't much more than that, I mean.
Q. Did he say why Mr. Jackson didn't want to know about it?
A. He didn't really care for the dentist all that much.
Q. At some point Mr. Jackson arrived after you arrived; is that correct?
A. Yes.
Q. Did he arrive alone?
A. No, he had his entourage.
Q. Do you remember how big that entourage was?
A. Two bodyguards -- a driver, bodyguard, and Michael as far as I can remember.
Q. Who introduced you to Mr. Jackson?
A. Dr. Tadrissi.
Q. Did you have any small talk?

A. Yes.
Q. Can you recall what that was?
A. Yeah, he said you're tall, did you play basketball, where did you go to school.
A. Just general conversation, nothing...
Q. Any specifics about him taking any anesthetic?
A. I asked him if he had had anesthesia before and were there any reactions that he knew of.
Q. Um-hum.
A. He said he had had it before and it hadn't been a problem in the past.
Q. Did you weigh Mr. Jackson as part of his -- as part of this physical?
A. I did not.
Q. Okay. And do you remember what evaluation you took; was it all questions?
A. All questions.
Q. Do you remember what those questions were?
A. Any allergic reactions, past medical history, taking any medications for anything. That's
about it.

Q. It would be a little cumbersome. What can you recall if anything about this meeting with Mr.
Jackson; did he seem in good health?
A. He seemed thin, pale, but otherwise no medical problems.
Q. And can you remember, did you conduct any tests?
A. I had my stethoscope and I listened to his heart. I believe Dr. Tadrissi's medical assistant may
have done a blood pressure. I don't believe they weighed him.
Q. Who was in the room when this was going on?
A. Just myself and Michael for the actual questions and physical exam.
Q. And then at some point Dr. Tadrissi and his assistants were also there?
A. That is correct.
Q. Were his bodyguards ever in the room with you during the questioning?
A. Never. They were out front in the lobby and we were back in the examination room.
Q. And how long do you think you were with Mr. Jackson alone in that examining room?
A. No more than thirty minutes.
Q. Did you check any parts of his body; check his feet?
A. No.

Q. Did you check his arms?

A. No.
Q. Did you check his chest?
A. I checked his chest, his lungs, and I looked inside his mouth.
Q. What was your impression of Mr. Jackson, if you recall?
A. Thin, but muscular. Healthy. Just pale, you know.
Q. Got it. Did you have any concern at the end of this evaluation as to whether or not you could
perform your duties as an anesthesiologist with Mr. Jackson a couple of days later?
A. No. Did have a -- what I considered an abnormally large tongue, which I noticed on the
exam, which kind of concerned me because we are going to be performing a procedure in his
mouth with an unprotected airway, and not knowing him and not knowing if he had sleep apnea
or what his reaction would be under the anesthesia drugs, I was a little concerned because I
knew the magnitude of who I was working with.
Q. Did you discuss this with him at all?
A. I discussed the risks that were involved. I went from, you know, A to Z, in that any time you
go under anesthesia there's a risk involved.
Q. Did he indicate to you that it was okay, that he had done this before or anything like that?
A. No. He just said okay. And that was -- that was it.

Q. Now, at the top here it says history of present illness and then after that it says -- well, why
don't I ask you what it says after that since it's your writing.
A. Explanation of the items checked if necessary, patient denies any medical problems, social
history, patient denies smoking, alcohol, no drugs, and obviously he denied something else, but I
can't recall what that is as I can't read it.
Q. So this means the patient denies smoking, occasional alcohol, no drugs?
A. That's correct.
Q. And does that mean that's what Mr. Jackson told you?
A. That's what he told me.
Q. In the next line above that, it says the patient denies any medical problems. So that's what he
told you?
A. That is correct.
Q. And then the next line next to allergies?
A. No known drug allergies.
Q. Thank you. Current medications?
A. Just multivitamins.
Q. All right. And throughout -- I'm going to ask you if you could explain this to me. This second
page, LACC 0801?

A. Okay.
Q. So first it says anesthesia record. It says, "Anesthesia and monitoring equipment checked
before induction," and that is checked. What does that mean?
A. That means basically I'm checking to see if there's a crash cart in the room, if there's oxygen,
if there's a laryngeal scope with an ET tube, basically emergency equipment, if something goes
wrong that I'll be able to revive this patient.
Q. And you checked that -- you looked for that and then you checked that box once you've done
so?
A. That is correct.
Q. Next one says, "immediately prior to the induction of anesthesia, the patient was reassessed.
The history and physical exam and vital signs were reviewed."
A. That is correct.
Q. Now, you did all that again a second time?
A. Yes, because I'm taking one vital sign before, you know, I'm making sure that I have a blood
pressure. I have a pulse ox. I have an EKG reading before we --
Q. Start?
A. Before we -- I need a baseline, so that's giving me the baseline.
Q. Then it goes on to talk about the anesthesia management plan including the "risks, benefits,
potential complications and alternatives has been discussed with the patient/guardian. All
questions have been answered and the patient consents. Yes."

A. That's correct.
Q. And again, you went through with Mr. Jackson the various risk and things and he consented?
A. Yes.
Q. And following that is a chart of some sort, and I'm hoping you can explain that to me.
A. The temperature up top says 97, so that's basically saying that he has a steady temperature all
the way through. He's not febrile, so it says 97 degrees Fahrenheit. Next line on the left-hand
side you'll see EKG, you will see normal sinus rhythm, so basically he's stable all the way
through. And the lines under that, you'll see a series of dots and what looks like arrows. That's
telling you what his blood pressure is. His systolic was somewhere around a hundred, his
diastolic blood pressure was somewhere around 60, and he's pretty steady all the way through
from the time I administered the Propofol, and it's given in five-minute increments, and you can
see the time under that, it's telling you the procedure took approximately two hours. He's on a
nasal cannula, which is basically giving him oxygen through the nose. He's on three liters of
oxygen. I administered Propofol, a hundred, 50 and 50, and normal saline going approximately
250 ml's per hour, which comes out to a total of 500 ml's.
Q. And you said that it took about two hours. You get that from -- I'm trying to see where the 2
is. I saw that before as well. Time right there, so 1630 is from about 4:30 to about 6:30?
A. That is correct.
Q. Now, how soon after you started the Propofol does the dental procedure begin? And I can tell
you what my follow-up is going to be, is how soon after they stop do you start to bring him out
from the Propofol?
A. I'm going to make sure that Dr. Tadrissi in this case is ready to go. As soon as I give that
Propofol and he's sedated, we are going to start. I'm not going to give it to him early, because I
want to get through this procedure as fast as possible because he has an unprotected airway.

Q. Got it. And would that also mean that as soon as he's done, you're going to try to bring him
up as soon as possible thereafter?
A. As soon as -- I ask Dr. Tadrissi to give me ten minutes before he's putting in his last stitch or
last filling or whatever, and I will -- he's normally -- normally on a case, a patient has anesthesia
gas, but in a dental surgery suite we don't have anesthesia gas. He's not -- and there's not a tube
down his throat. I'm not -- I could give it through his nose, but I choose not to do that in this
case. In this case, I just say let me know when you have ten minutes to go so I don't administer
any more, in this case it would be Propofol, because I don't want to give him a dose of Propofol
that will keep him asleep any longer than it would take for him to wake up. So as you see, I
gave him a hundred for the initial induction, a hundred ml's, and then approximately thirty
minutes later I gave him another 50, and another 50. I'm not trying to put him completely
asleep. I just don't want him to remember what we have done. So he's not only getting the
Propofol, Dr. Tadrissi is administering novocaine or lidocaine or I don't know what, so he's
numb also. So that's not just the Propofol on board, there's also a local numbing agent just like
anybody else or when you go to the dentist you get novocaine, so he's going to administer that
too. I'm just trying to get him through it without him remembering it.
Q. So would this amount, 100, 500 -- 100, 50, 50, is that a small amount of Propofol?
A. It's about as small as I give to anybody.
Q. All right. Did you have any discussion with Mr. Jackson about this procedure, about the fact
that you were giving him Propofol?
A. No.
Q. And would you typically discuss that with a patient?
A. Never.
Q. Did you bring any drugs with you to the first procedure?
A. No.

Q. Did Mr. Jackson ask you any questions before the procedure?
A. No.
Q. Did he have any specific requests?
A. He didn't want to feel anything.
Q. Can you tell from your records here whether you billed Mr. Jackson for this procedure?
A. I didn't bill.
Q. You did not bill him?
A. I did not.
Q. How do you know that?
A. Because Michael kept asking me and Dr. Tadrissi, asked me how much this was going to
cost. I had no idea what to say.
Q. Okay.
A. So I told Michael and Mark, I says if he refers me other patients then I won't bill him. I'll do
it.
Q. Got it.
A. I'll do it for no money.

Q. So this first time you were there, you didn't bill him anything?
A. I didn't bill him for any of his procedures.
Q. None of the four?
A. None of the four.
Q. Okay. And if you'll elaborate a little bit, what was the reason for that?
A. Because I figured that the referrals and the patients that I would get from him would be worth
more than the money I would charge him for his procedures.
Q. When you say "him," do you mean Mr. Jackson?
A. Mr. Jackson. And truthfully I had no idea what to say. I'm not the type of person that would,
you know, jack my prices up or, you know, just this kind of caught me off guard, because
normally I just bill the insurance company. So in this case I just told him, I'll do it for free, just
give me your referrals.
Q. Let me just make sure I understand. So when you say you bill the insurance company, is
there a going rate with the insurance company that you're allowed to bill them?
A. I bill -- my office bills -- I want to say it's about 110 to 120 dollars a unit, which is every
fifteen minutes, so that's about $400 dollars an hour.
Q. Got it. And this was a private patient without insurance; is that correct?
A. I don't know whether he had insurance or not because I never asked him.

Q. This was a patient you were not going through his insurance company?
A. That is correct.
Q. When you started to administer the Propofol to Mr. Jackson, did you explain to him what you
were doing?
A. Did I explain to Mr. Jackson? I believe I told him we were going to start the procedure and he
may feel the medication going through his IV.
BY MR. PUTNAM:
Q. And did he respond in any way?
A. He may have shook his head, he may have said okay, but there was no other response.
Q. And did anything unusual happen during the procedure?
A. Unusual?
Q. Um-hum.
A. No.
Q. Was there a difference in his body type from the beginning or end of the procedure?
A. No.
Q. Can you remember anything else about this first procedure that was outside of the ordinary in
any way?

A. Not out of the ordinary, but when we administered the Propofol, his tongue relaxed. And
when I say it relaxed, I mean it obstructed his airway. So we had to position his head -- he's
sitting in a dental chair so we tilted the chair back and we extended his neck and we held his
chin, because Dr. Tadrissi is in his mouth so he gave him a jaw thrust which basically lifted the
tongue off the back of the pharynx to open the airway, and we had to maintain that position the
whole time. If not, he would obstruct. Every time we administered medication he would
obstruct.
Q. And I know we are going to go over the three other times where you gave Propofol. That
happened in each of the instances?
A. Every time. Each time that there was this reaction by Mr. Jackson, did you do something to
physically intercede to correct it?
A. I would tell the surgeon or the dentist to pull his chin forward.
Q. Had you ever seen this reaction before in any other patient?
A. Yes.
Q. And you did indicate that Mr. Jackson's tongue was quite large. Did this make it even more
of an issue?
A. It did.
Q. And if you hadn't seen it with your own eyes, would you have eventually realized the same
because of the oxygen levels that were being monitored?
A. Yes. But, you know, with the obstructed airway he would start to have labored breathing, you
may hear a snoring. But with Dr. Tadrissi or the dentist being in the mouth, you know, we would
-- we noticed it right away.

Q. You indicated earlier an issue earlier whether one has sleep apnea. Did you ask Mr. Jackson
whether he had sleep apnea?
A. I did. He said he didn't know.
Q. Did you ask Mr. Jackson whether he had insomnia?
A. I did not.
Q. Did he mention to you whether he had insomnia?
A. It was never discussed.
Q. During these four visits where you provided Propofol, was Mr. Jackson's sleeping habits
discussed in any way with you?
A. Not at all.
Q. During the course of the procedure, did you have any other concerns about the administration
of Propofol to Mr. Jackson, other than the fact that there was this moment where his airway was
obstructed by his tongue?
A. After the initial induction of the hundred milligrams of Propofol and we pulled the tongue off
of the pharynx and we opened the airway, there were no other issues.
Q. Did he seem to come up okay?
A. Fine, perfect.
Q. Is there any procedure that you have with the patient afterwards to make sure they're okay
once they come up, any questions or any procedures that you use?

A. Outside of just monitoring their vital signs and making sure they can walk out of the clinic,
then that's about it.
Q. Now, you indicated there were four occasions where you saw Mr. Jackson and administered
Propofol, can you remember how long after this first procedure was the second procedure?
A. I would say it was a month later.
Q. Okay.
A. And that was also at Dr. Tadrissi's.
Q. I'm going to show you a document similar to the one you just saw.
A. Okay.
Q. I'm going to have it entered as Exhibit 4, and it has a Bates range of LACC 0803 through
LACC 0804.
Q. Doctor, do you recognize this record?
A. Yes, it's my anesthesia record.
Q. Is this an anesthesia record much like the one we talked about a moment ago?
A. It is.
Q. What is the date of this record?

A. 6/3/08.
Q. And does this refresh your recollection as to the next time you saw Mr. Jackson?
A. It does.
Q. What date was that?
A. 6/3/08.
Q. All righty. And here there are a number of boxes filled, et cetera, like previously. Can you
look through and see if anything has a different meaning other than what you've already told us
here today about your prior record?
A. No. Pretty much the same procedure, everything else pretty much the same.
Q. I was going to say, this one is again two hours?
A. Yes.
Q. Again 200 milligrams of Propofol?
A. Yes.
Q. Initially a hundred then 50 and 50?
A. Yes.
Q. Again your signature throughout?

A. Yes.
Q. And you indicated, I just want to ask it again if I may, again there was an incident during this
procedure where once you gave Mr. Jackson the Propofol his tongue went back and started to
block his airway?
A. That is correct.
Q. And were you expecting it this time?
A. I was. Always aware that can happen when Propofol or any other induction agent is given.
Q. How often has it happened to you?
A. I've probably done, including colonoscopies and EGGs, I've probably done 5,000 of these
cases -- that might be high -- 4,000. I would say you get an obstruction like that maybe 500
times. So it's not uncommon.
Q. During this second -- instead of going through -- I'll ask a couple of questions about it. This
second procedure was again at Dr. Tadrissi's office?
A. That is correct.
Q. Can you recall who came with Mr. Jackson, if anyone?
A. Two bodyguards.
Q. In the second meeting with Mr. -- in this third meeting with Mr. Jackson, the second time that
you administered an anesthetic in Dr. Tadrissi's office, did you have any further discussions with
Mr. Jackson about the anesthetics that you would be using?

A. No.
Q. Did you discuss with Mr. Jackson the issue he had with his tongue in the prior proceeding?
A. No.
Q. That actually should have been procedure. I have proceedings, you have procedures. Did
you have any discussion with Mr. Jackson after the procedure about how the procedure had
gone?
A. I asked him was he satisfied, did he feel anything, and he was perfectly happy with what had
happened.
Q. Wow. Did Mr. Jackson during this procedure, this second procedure, make any specific
requests?
A. No. Just he was happy with the first procedure, that I was going to do the exact same thing.
Q. Do you remember what the second procedure was for?
A. I want to say the first procedure was to take an impression of his teeth for the implants, and I
believe he was also getting some cosmetic teeth that he would use to change his appearance.
And that's what those two were for, those two procedures were for.
Q. And this second one was again on 6/3/08?
A. That is correct.
Q. All right. And now I'm going to mark as my next exhibit, Exhibit 5, which I'll have entered
into the record and shown to you, a three-page document. This one has a different Bates number
which is ODABASHIAN005 through 007.

Q. What is this document?

A. Anesthesia record with a history and physical.
Q. And is it your record?
A. It is.
Q. And you will see the date here is 6/18/08?
A. That's correct.
Q. Was that the third time that you performed a procedure on Mr. Jackson?
A. It is.
Q. And I look through here and I see, for example, there at the bottom on the left-hand side it
says root canal in terms of the operation.
A. That's correct.
Q. Do you remember the doctor performing a -- Dr. Odabashian performing a root canal on Mr.
Jackson?
A. I do.
Q. Was that on 6/18/08?
A. It was.

Q. Was that the third time you administered anesthetic to Mr. Jackson?
A. It is.
Q. Can you tell from this record what anesthetic you provided?
A. Propofol.
Q. And is that because it's written here on the page?
A. That's correct.
Q. And there, unlike the last time, here it says 100, 20, 20, 20?
A. Yes.
Q. Could you tell me what that means?
A. That means I gave him a hundred for induction to put him to sleep or put him under, since
sleep is a very controversial term in this case, and 20, 20 and 20 was basically to keep him
under.
Q. And in this instance, and here it's over the course of an hour; is that correct?
A. It's about an hour and a half.
Q. Okay.
A. Yeah, hour and fifteen minutes.

Q. Under times it has 1730 to 1830; is that right?

A. That is correct, um-hum.
MR. PUTNAM: As we move to the front. But before we do that let me ask you a question.
THE WITNESS: Yes.
BY MR. PUTNAM:
Q. So this was with another doctor?
A. Yes. Dr. Tadrissi was there though.
Q. That's what I was going to ask. All right, who was present during this procedure?
A. Dr. Odabashian, myself, the patient Michael, Dr. Tadrissi and one assistant, like a dental tech.
Q. The doctor performing the root canal, had you met him before?
A. I had not.
Q. Had you worked for him before?
A. I had not.
Q. And do you know how it came to be that you were the anesthesiologist for this doctor for this
root canal?
A. Dr. Tadrissi brought me with him.

Q. And did you know that you would be doing this third procedure at the close of the second
procedure?
A. No.
Q. How did it come to be that you learned that your services would be needed on the 18th?
A. Dr. Tadrissi said he noticed some cavities and he may need a root canal, and would I be
willing to administer the anesthesia for the root canal.
Q. Did you ever receive a call from Mr. Jackson in reference to these four visits that we are
talking about?
A. After the first procedure he called me on his cell phone.
Q. What did he say?
A. It was pretty much small talk. I had given everybody my card because I said if anything goes
wrong I want you to call me, and Michael had called me and he just -- I informed him hey, you
got to call me and let me know you're okay, and he called me and it was just very small talk.
Just more where I went to school, what did I do, where do I live. Just very general terms and
then let me know he was okay.
Q. And this was after the first procedure that you performed at Dr. Tadrissi's office?
A. That is correct.
Q. How soon thereafter did he call?
A. Two hours after the procedure.

Q. Were you surprised?

A. Very. Well, no. I was surprised that he had actually called, because I informed his bodyguards
and his driver to basically let me know he was okay. I wanted somebody to call, but I was
surprised that he actually called me himself.
Q. Were you surprised that he was asking you where you went to school and where you lived
and whatnot?
A. Yeah, I was surprised that he asked or even cared.
Q. How long did that conversation last?
A. Ten minutes.
Q. Do you remember anything else about the call?
A. He said he was going to buy the house that was down the street from me at Spanish Trail, it's
where the sultan lived. He said he was looking into purchasing that house and that's all --
nothing -- oh, it's a nice house, it's 60 million dollars.
Q. Did he say this after you told him where you lived?
A. Yes.
Q. Did you like him?
A. Michael?
Q. Yeah.

A. He was very personable, nothing like I had imagined, but I didn't, you know, the short time
that I got to know him he was very pleasant, very polite, very personable. And very quiet.
Q. Except for that one call, did there come a time -- any other occasion where you talked to Mr.
Jackson on the telephone?
A. No. What's the difference between general anesthesia and sedation, one local anesthesia?
A. General anesthesia is going to be a deeper sedation, where normally a patient is going to be
on a ventilator, and it's -- he's not in a twilight sleep, he's getting more medication for pain. He's
in a deeper state of sleep.
Q. For each of these, we were not in that deeper state of sleep, were we?
A. No, because we didn't have a ventilator -- we didn't have him on a ventilator. Do you
remember that there came a time where there was a fourth procedure that you performed on Mr.
Jackson?
A. Yes.
Q. Do you remember what doctor that was?
A. That was with Carlos Letilier who was the oral surgeon I had worked with at Sunrise
Hospital and who had referred me to Dr. Tadrissi. I guess we're still friends. The third time you
performed a procedure on Mr. Jackson, did you provide Mr. Jackson with Propofol on that
procedure as well?
A. I did.
Q. And that was with Dr. Letilier's office, correct?

A. Letilier, that's correct.

Q. Now, it was the fourth time?
A. It was.
Q. And it was still in 2008?
A. It was.
Q. And can you remember what the procedure was?
A. It was for the actual screwing the implants into his jaw.
Q. How many implants were there, if you recall?
A. I believe there were two.
Q. At this instance can you recall who accompanied Mr. Jackson, if anyone?
A. It was two bodyguards, and then Dr. Tadrissi, and then Carlos and Carlos's assistant was
there, two assistants were there.
Q. And you had worked in Dr. Letilier's office before, correct?
A. I had not.
Q. You had not?

A. I had worked with Carlos at Sunrise Hospital, but I had never worked in his surgical suite
there.
Q. Okay. Had you gone in advance and looked at what equipment he had?
A. I did not.
Q. Did you check on it that day?
A. I did.
Q. And did it all seem to be adequate for you?
A. It did.
Q. Was there anything out of the ordinary about this procedure?
A. In the previous three procedures, Michael asked me not to give him any narcotics. I asked
him why. He just said he had had a problem with them in the past and he didn't want to have a
problem with them again. So if you look at my records, you won't see any narcotics. I didn't
give him any, as requested. During this procedure, after it was over, he asked for something for
the pain, and I remember saying are you sure? And we had mentioned Toradol, which is a
nonnarcotic pain reliever, and he requested something stronger.
Q. What did he request?
A. He didn't request anything, but he did say, you know, that Toradol is not going to work.
Q. Okay. So he asked for something stronger?

A. And we ended up giving him Versed, which is a benzodiazepine, and also morphine for the
pain.
Q. Now, was that something -- did you give him this for the pain in the office or was that
something you prescribed him so he could take it home?
A. No, it was right there. It was through the IV.
Q. IV? And so was this after he came up out of the Propofol?
A. This was after the procedure, um-hum.
Q. And did you ask him if he wanted anything or did he request something?
A. He requested it.
Q. And how soon after he came to did he request this?
A. Immediately.
Q. And were you surprised by this?
A. I was surprised. But I also saw the procedure. And they screwed the implant into his jaw, and
you know, it wasn't unusual.
Q. Is there anything unusual about this visit that you can recall?
A. No.
Q. Do you recall how long this procedure lasted?

A. Hour and a half, two hours.

Q. And I should ask this for this procedure, I know the answer, but since I don't have the
records, did you administer Propofol during this procedure?
A. I did.
Q. Do you remember how much?
A. Approximately the same that I've administered. It was 200 too. 200 milligrams.
Q. I'm going to ask some general questions about those four, and then we will move to the
March meeting and then that will be largely it. During these four visits with Mr. Jackson in
2008, did you ever discuss Propofol with Mr. Jackson in any way?
A. Never discussed. The only drug we discussed was narcotics and he just said he didn't want
any and he just gave me -- and he just, you know, went the broad category of narcotics. He
didn't say one specifically by name. During your five visits with Mr. Jackson, four of which you
provided Propofol, did you ever discuss any other doctors with Mr. Jackson?
A. No. I knew doctors that had worked with him in the past and I consulted with a couple of
them before I put him under the first time to see if there was anything unusual. And -- but I
never discussed that with Michael.
Q. And when you say you discussed with doctors prior to putting him under the first time, is that
prior to the first time you provided Mr. Jackson with Propofol in May of 2008?
A. Yeah, prior to me ever putting him under the first time.
Q. And what doctors did you speak with prior to that visit about their prior care with Mr.
Jackson?

A. Dr. Steve Gordon, Dr. Carl Virgil, Dr. -- last name Habashy -- I couldn't tell you.
Q. And that's different than the doctor we mentioned a moment ago?
A. Yes. Those were two anesthesiologists. Michael had a few plastics and maybe collagen,
Botox, whatever procedures, and I knew the plastic surgeon Steven Gordon, because I had
worked with him or I still work with him. And he just told me there was nothing unusual, just
that he didn't want to feel anything. For every procedure, he didn't want to know anything.
Q. Did a time come when you actually met Dr. Conrad Murray?
A. Yes.
Q. When was that?
A. I want to say it was late March, early April 2009.
Q. In terms of the time, what makes you think it was in that time period?
A. After Michael died, I kind of went back through my mind and looked at what I was doing
when I met Murray and figured I could narrow it down to those dates.
Q. Sunday in March. And how did it come to be that you met Dr. Conrad Murray on a Sunday in
March of 2009?
A. 2009, I was up getting ready to go to church. I know it sounds crazy, but you know.
Q. And why did you go anyway?

A. Well, if you're having a heart attack or if you have a heart problem and, you know, why not.
I'm a doctor. You know, this is Michael Jackson, you know. I mean, you know, if he says he
needs something I'm going to go.
Q. And where you went, that was to Dr. Murray's office?
A. That's correct.
Q. Was that at his office on East Flamingo Road?
A. That is correct.
Q. Had you ever been to his office before?
A. Never.
Q. How did you know what the address was?
A. He told me.
Q. Did he ever tell you how he got your number?
A. I believe Michael gave it to him.
Q. I think I asked this, but just to make sure, this is the first time you ever spoke to Dr. Conrad
Murray, correct?
A. I had seen him before, never talked to him before.
Q. When you arrived at Dr. Conrad Murray's offices on East Flamingo Road, who was there?

A. Nobody. Just me.

Q. So they weren't there when you arrived?
A. That's correct.
Q. Did you try to get in, it was locked?
A. No. I just -- well, the front door was locked, so then I went back to my car.
Q. And did a time came thereafter when someone arrived?
A. Yeah, Dr. Murray and Michael. Dr. Murray was driving, Michael was in the back seat.
Q. Was it just the two of them?
A. Yes.
Q. What happened next?
A. Well, Michael and Dr. Murray got out of the car, I got out of my car, we introduced ourselves
to each other, and I told Michael how ridiculous he looked because he had a scarf and he was all
dressed in black and it was about a thousand degrees outside, and we sort of joked. And then we
went inside.
Q. Were you surprised to see he seemed okay?
A. Well, he never really seemed completely normal, and when I say that, you know, he always
had a different, I want to say outfit on, but this time he was -- usually when he came to the

surgery center he had a very relaxed look, maybe even pajamas, but this time he had on a suit
coat, a scarf, a hat, I don't think he had an umbrella, but he definitely had too many clothes on.
Q. How did Dr. Murray introduce himself?
A. I'm Conrad Murray. You know, Dave Adams. You're Michael. If that's a disguise you're
wearing, everybody knows who you are.
Q. And what happened next?
A. We went into Murray's office, and Michael sat where you sat, I was sitting in a Libo and Dr.
Murray was sitting to the left of me, and that was basically the real chair there that Michael was
sitting in, and we were sitting in what I presumed would be patients' chairs if we walked into
the office, and he was sitting where I thought Murray should have sat.
Q. And what happened next?
A. We started talking and I believe Michael started talking about this tour.
Q. Had you heard about the tour at that point?
A. I had heard about it on TV. And I says, you know, I knew about the tour, and the conversation
went on.
Q. What did they say about the tour?
A. Michael explained why he was doing the tour.
BY MR. PUTNAM:
Q. What did he say?

A. He says the only reason I'm doing this tour is because I want to prove to my kids that I'm the
best entertainer in the world. And I'm not doing it for any other reason.
Q. I'm trying to figure out, you're sitting there on a Sunday afternoon in Dr. Murray's office and
Michael Jackson's explaining why he's going on tour. Did a time come when you were
wondering why you were there?
A. I wondered that from the time the phone rang at my house, I'm still wondering it the whole
time I'm there. Because I'm waiting for him to hold his chest or tell me he's short of breath or
he's got chest pain. I'm sitting in a cardiologist's office with Michael Jackson on a Sunday
afternoon, and I'm just sitting.
Q. Did a time come when you understood why he asked you to his office?
A. He asked me to go on tour with him.
Q. And what did he ask you exactly?
A. Well, this didn't happen during -- right then. Murray excused his self and left the office. And
then me and Michael talked and it was sort of like I was on an interview. And he was telling me
a little bit about him and how he felt, and his family and different entertainers, and this, this and
this, and we sat there and we talked about an hour and a half.
Q. Just you and Mr. Jackson?
A. Just Michael and myself.
Q. Did you start to feel like you were on an interview?
A. I -- well, not so much on an interview, but he wanted to know a lot about me. He wanted to
know did I have kids, was I married, this, that and the other, and I still wanted to know why.
Okay, you're not holding your chest, you don't have chest pain, what's going on.

Q. Then did a time come in that conversation -- do I understand you to say after about an hour
and a half --
A. And he also wanted to know about my practice. He told me he wanted to build a hospital,
that he wanted to build a children's hospital. We talked about Steven Spielberg, we talked about
Bono, we talked about the tour. He didn't have good things to say about those people either. He
talked about his family, he talked about his kids. He talked about everything.
Q. And did there come a time during that conversation where he then asked you to go on tour
with him?
A. No. That didn't happen until about an hour and a half later, Dr. Murray comes back and
Michael says to Murray, we're sitting in the office, he pulled him to the back, and they stayed
back there for about fifteen minutes, and I'm getting restless because I don't know what's going
on. So I walk to the back and they're having a conversation and I says hey, you know, I've got
things to do, I've got to go. And they said hold on a second, just hold on, so I says okay. I go
back to the office. Michael and Murray walk back in and Murray really looked like he had just
lost his best friend, and he sits there in the chair and Michael sits there, and then that's when
Michael says to me, I would like for you to go on tour. And I says, you know basically, on tour?
Okay. And do what? You know? I says I don't sing, I really can't dance, so to do what? And he
says -- these are his exact words, I remember like it was yesterday. He says, I would like for
you to help me get my rest. And I referred to Dr. Murray, and I said what do you mean get your
rest? And he says well, you know, I'm entertaining, I'm jumping around, I'm doing this. Every
once in a while I need an IV, and he says I just need you to help me get my rest. They were
pretty vague. In hindsight, I know what they were talking about, but then I says help you get
your rest, what do you mean? And I told him that Dr. Murray could do that, you know, he's a
cardiologist, I'm just an anesthesiologist, you know. And then they just started asking me about
my practice. Well, how much money did I make. You know, if you were to shut down for a year,
how much money would you need? And I just -- I just -- I didn't know what to say. You know, I
just says I'll get back -- I don't know. You know, I'm here thinking the guy's having a heart
attack and they're asking me about going on tour, and you know, I couldn't even begin to fathom
what they were talking about.
Q. Did you have any idea what they meant at the time when they told you that they wanted you
to help Mr. Jackson get his rest?

A. I had no idea.
Q. Did they talk to you about insomnia during this visit?
A. Never.
Q. Did they mention that Mr. Jackson had any trouble sleeping?
A. Never. They said they wanted you to be in London with Mr. Jackson?
A. That is correct.
Q. Did they say they wanted you to be in Vegas with Mr. Jackson?
A. No.
Q. Did they say they wanted you to be in Los Angeles with Mr. Jackson?
A. No.
Q. Did they say that they wanted you to help him in his rehearsals for the tour?
A. No. What I did tell them is that I don't have a license to practice in England.
Q. And did you indicate that you would need to get some kind of permission to practice in
England?
A. Well, I was -- I still wasn't under the impression that I was going to be practicing medicine.
You know, help you get your rest. What do you mean? You want me to sing to you as you go to
sleep? I don't know, you know, I'm not under that impression that you need me, because I even

asked him, hey, can I help with VIP ticket sales. You know, no we got that under control. I had
no idea what they were talking about.
BY MR. PUTNAM:
Q. You said that when Mr. Jackson said this to you, that Conrad Murray looked upset; is that
correct?
A. Oh, he was truly upset.
Q. Were they asking you to join Dr. Conrad Murray with Mr. Jackson on tour in the U.K.?
A. In this meeting I had no idea what they -- it was just sort of mind-boggling that someone
would be asking me to go anywhere.
Q. So how much longer were you there at Dr. Murray's office?
A. After they asked me to go on tour, probably fifteen minutes. Michael asked me not to give
him an answer right then, to go home and think about it.
Q. So how long were you there all told?
A. Two and a half hours, maybe three.
Q. Did you give him an answer right then?
A. I didn't have an answer.
Q. How did you leave it?

A. I asked Michael who did he want me to contact, him or Dr. Murray. And I don't think he
answered. I just said I'll communicate through Dr. Murray.
Q. At that time did you have Dr. Murray's number?
A. No, he gave me his -- no, his number was either in my cell phone, but he eventually gave me
a card.
Q. Did they give you a time frame as to when you should get back to them?
A. I told him give me a few days. I don't really -- you know, it was just -- I was just -- I'm
supposed to be coming for a guy with chest pains, they want me on tour now.
Q. How did the meeting end?
A. We all walked out together, Michael, Murray and I. They got in a car, I got in the car and
went home.
Q. Did you discuss any specific medications during that meeting?
A. Never.
Q. And do I understand you to be saying you did not discuss Propofol at all during that meeting?
A. I have never discussed Propofol with Dr. Murray or Michael Jackson.
Q. Did Dr. Murray administer any drugs to Mr. Jackson during that visit?
A. Not that I know of.
Q. And did you?

A. No, I did not.

Q. Did a time come when you again spoke to Dr. Murray?
A. I talked to him on the phone that week. And I believe there's a couple of texts between he and
I.
Q. How many conversations did you have with him?
A. I want to say two or three.
Q. And let's go to the first one. How long did that last?
A. I'm not really sure, but it was no longer than five minutes.
Q. And the second?
A. The same.
Q. The third?
A. If there was one, it was no longer than five minutes. BY MR. PUTNAM:
Q. You said a time came where you had a conversation about how much you would be paid; is
that correct?
A. That conversation did come up.
Q. What do you recall of that conversation?

A. Well, I told -- I remember asking them how long that they were going to need me for, and
when they told me how long, because it was very open-ended, they says well, we really don't
know because we don't know how long this tour is going to go. They thought that after London
it might go to other countries after that. And I says well, I will have to shut my practice down,
and I gave them a figure. I told them I needed enough money to shut my practice down and
make it feasible.
Q. And what was that figure?
A. I think it was a hundred thousand a month, and I told them that it wouldn't be feasible for me
doing it for a year. I told them it would have to be for a longer period of time because I couldn't
see shutting my practice down and then coming back and trying to open a practice again. So if I
was to sign any contract with them it was going to have to be -- I think I asked for three years.
BY MR. PUTNAM:
Q. That's what I was going to ask. So you never spoke with him again after that?
A. Never.
Q. Did you text with him after that?
A. I texted him basically, you know, what's going on, I'm on board. And no response.
Q. Were there any further communications back from Dr. Murray after that point?
A. No.
Q. Were there any further conversations with Michael Jackson after that point?
A. No.

Q. Did you have any further conversation -- any communications with anyone after that point
who works for Mr. Michael Jackson?
A. The day that Michael died, I was in the OR here in Vegas. And I was watching TV just like
everybody else and I texted Murray, sorry to hear what happened. Take care.
Q. And did you ever hear back?
A. Never.
Q. Prior to Mr. Jackson's passing, had you ever heard of AEG?
A. I have.
Q. In what context did you hear of AEG?
A. I think they promoted a concert and I heard they were promoters. I had no idea who they
were or why.
Q. Did you ever discuss AEG with Mr. Michael Jackson?
A. I believe during the conversation in Dr. Murray's office he referred to either AEG or the
promoters -- and I'm not sure.
Q. Do you remember what he said about them?
A. Not exactly.
Q. Do you remember what he said generally?

A. That they had sold a lot of tickets to his concerts.

Q. Did Mr. Jackson ever discuss AEG Live with you?
A. No.
Q. Have you ever heard of Paul Gongaware?
A. No.
Q. Have you ever heard of Randy Phillips?
A. No.
Q. Did Michael ever ask you to do anything you thought was medically inappropriate?
A. Never.
Q. And Michael, I think you said that he was clear that he did not want narcotic painkillers in
three of the four times that you treated him?
A. Well, he just mentioned that when I first met him.
Q. Okay, fair enough. And then he didn't change that until the fourth procedure?
A. It never changed until the last procedure.
Q. That fourth procedure, can you describe just a little more in detail about physically what that
procedure entailed?

A. Well, basically you're taking a tooth, an artificial tooth that has a screw in the bottom of it
and you're screwing it into somebody's jaw. You're cutting his gums and screwing it into the jaw.
Q. Based on your experience, is that a painful procedure?
A. I've never had one, but it looked painful to me.
Q. You've had other patients who have woken up from anesthesia in that circumstance and been
under significant pain?
A. That's correct.
Q. Anything unusual about giving somebody painkiller for that kind of surgery?
A. Not at all.
Q. Do you have any idea whether he got any additional, other than the one dose there at the
time? I think you said it was morphine and Versed?
A. Morphine and Versed. I believe he got the Versed. I want to say before the procedure he got
the Versed. I would have to look at the record or maybe during the procedure, but Versed is not
a medication. So he either -- he came in anxious. You know, he came in with a different
demeanor than he normally came in for the first three times. He came in a little more anxious, so
we gave him the Versed I want to say before the procedure started, and gave him the morphine
after and the Propofol in between. Just a little more nervous.
Q. A little more nervous about the --
A. About getting ready to get the implant screwed into his jaw.
Q. As far as you know, was he given any kind of narcotics other than in Dr. Letilier's office --

A. No.
Q. -- for that procedure?
A. As far as I know, no. Is there anything in your examinations that you determined was
inconsistent with what he stated his medical history was?
A. Nothing at all.
Q. Did you ever see any needle marks on his arms, for example?
A. Nothing at all. Very difficult veins to stick to. Very muscular arms, very small veins.
Q. What does that have to -- why do you mention that?
A. I just mentioned it because I can remember sticking him twice, three times, every time trying
to get an IV.
Q. So is what you're saying is that you believe you would have seen needle marks in his arms if
there were?
A. That is correct.
Q. You never saw any?
A. Never saw any.
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