JACKSON V AEG LIVE July 22

nd
2013
Katherine Jackson, recalled as a witness by the plaintiffs, was previously sworn and testified as
follows:
Cross-examination (resumed) by Mr. Putnam:
Q. Good morning, Mrs. Jackson.
A. Good morning.
Q. Feeling better this morning?
A. Yes.
Q. On Friday I only had you for about 20 minutes, and in that time, what we talked about
was the filing of your lawsuit in September of 2010. Do you remember that?
A. Yes.
Q. And right after that, I had started to talk about something we call discovery, where each
side asks the other side to give them relevant documents. Do you remember that we started to
talk about that?
A. Yes.

Q. All right. And you understand that there were a couple years of discovery in this case,
ma'am?
A. Yes.
Mr. Panish: objection. It's irrelevant. We're in trial now. Discovery is irrelevant.
The judge: overruled.
Mr. Putnam: thank you, your honor.
Q. Mrs. Jackson, I want to ask you
A. Little bit about that, if I may. You've been sitting here for most of the Last 12 weeks;
correct?
A. Yes.
Q. And you've seen lots of documents that have gone up on these screens from AEG Live
to AEG Live and some even between people at AEG Live correct, ma'am?
A. Yes.
Q. Lots of e-mails?
A. Yes.
Q. Lots of documents?
A. Yes.
Q. Have you seen lots of e-mails or documents of any sort from you?
Mr. Panish: it's irrelevant. Objection. She doesn't use e-mail.
Mr. Putnam: any documents. I'm cutting time, your honor. We're going to go through
them.
Mr. Panish: it's irrelevant.
Mr. Putnam: not irrelevant, your honor.
The judge: overruled. Were there any e-mails from you?

The witness: no.

Q. In this discovery process, did you hand over any computers, ma'am?
A. No.
Q. What about any files? Did you hand over any financial documents, ma'am?
A. No.
Q. You mentioned that your son Michael would give you money in cash; correct?
A. Yes, I did.
Q. Okay. When that would occur, would you write that down anywhere?
A. No.
Q. You have a secretary; right, ma'am?
A. I have an assistant.
Q. An assistant? Is that Janice Smith?
A. Yes.
Q. And how long has she been your assistant?
A. I'm not good with dates. I don't remember. Been quite a while.
Q. Long time?
A. Yes. She's been in the family a long time, but she didn't work for me that long.
Q. When did she start working for you, ma'am?
A. She's been in the family about 30 years or more. She started working for me, I guess,
about 15 or 20 years ago not 20. About 15 years ago.
Q. Okay. And does she have an office?
A. Yes.
Q. Where is that office?

A. At Hayvenhurst where my home is. Was.

Q. I apologize. It's my fault. I missed the end of that. I'm not so good in hearing.
A. It's in Encino where I was living at the time.
Q. And that's speaking of Hayvenhurst, let me ask you a question. On Friday morning we
saw a kind of like a little documentary about your life. You remember, ma'am?
A. Yes.
Q. And in that presentation we saw your house on Jackson street in Gary, Indiana?
A. Yes.
Q. But you haven't lived there in about 60 years; correct, ma'am? Did I get the date wrong?
A. Yes, you did.
Q. 50 years?
A. Wrong.
Q. How long has it been?
A. It's been about 44 years.
Q. Pretty good with that date. So 44 years since you've lived there. And since that time
you've lived at Hayvenhurst; right, ma'am?
A. Yes. I'm not living there now, but I did.
Q. But you still have Hayvenhurst; correct?
A. Yes.
Q. And the reason you're not living there now is because you're having it renovated again?
A. Yes.
Q. And right now you're living in a gated community in Calabasas; correct?
A. That's correct.
Q. So going back to Hayvenhurst, in Hayvenhurst, there's an office where Janice smith
works; correct?

A. Yes, there is.

Q. And when you would get monies from your son Michael Jackson, would you let her
know that so she could write it down somewhere?
A. No. Not all the time.
Q. Not all the time. Sometimes?
A. Well, it was a gift, so I didn't think that I needed to report it to her.
Q. Okay. And so these monies that you were getting, you didn't report them anywhere, to
your knowledge?
Mr. Panish: well, objection. Vague and ambiguous. Overbroad. He said, "Janice."
The judge: overruled. You may answer.
The witness: repeat the question, please?
Q. of course, ma'am. You talked about getting this money from your son Michael in the
past.
A. Yes.
Q. And I asked if you ever reported it to anyone anywhere.
A. I might have mentioned it. My son took care of me. He paid for everything: food, shelter,
clothing. And when he gave me cash, it was just a gift from him. I didn't think I needed to
report it to everyone.
Q. So if I wanted to find out how much money Mr. Jackson gave you to pay for everything,
where would I look? Where would I find records like that, if you know?
A. He didn't give me money to pay for everything. He paid it himself from his office.
Q. Okay.
A. And the cash he gave me was just for gifts for myself.
Q. And are you aware of any records that show this being paid, ma'am?
A. No.
Q. You didn't give any records to show this, to your knowledge, did you?

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

Q. Okay. Do you have an accountant, ma'am?
A. No, I don't.
Q. You don't have an accountant?
A. No. Not a personal accountant.
Q. Okay. And what about bank accounts? Do you have bank accounts?
A. Now I do. And I had some then, but
Q. You did have them then?
A. Yes.
Q. Are you aware of whether you turned over any of your bank account information?
A. To who?
Q. To your lawyers to give to us in this case.
A. That's been years ago, I'm talking about.
Q. Okay, ma'am. So in September of 2010, you started this lawsuit?
A. Yes.
Q. Did you have a bank account then?
A. I don't think so. I'm not too sure. But I know my social security came to a bank, and I
think I I don't think I should have reported that.
Q. There's been a lot of testimony here over the Last 12 weeks that indicated that your son
was having financial problems. Certainly by the time of 2009. You heard that testimony?
A. What year?
Q. By the time of your son's passing, he was having financial difficulties. Have you heard
that testimony?
A. Yes, I have.

Q. Did that come as a surprise to you?

A. In a way, yes.
Q. Why is that, ma'am?
A. Because I know my son made a lot of money, and he had people working for him. One
fear that he had, a lot of times people that's okay. I won't answer that question.
Q. Let me ask it again. Were you aware at the time of your son's passing that he was having
financial difficulties?
A. Yes.
Q. And how were you aware of that, ma'am?
A. I had heard it.
Q. Who did you hear it from?
A. Different people.
Q. And if you know and you knew that at the time when he was still alive, ma'am?
A. Uhm, I found out.
Q. And did you find that out after he passed?
A. Well, they'd been saying for years, I would say the Last 15 years, that Michael Jackson
was broke, and he wasn't. So I didn't know how to believe any of that.
Q. Well, that's what I
A. And then, too, all down through the years, people were taking monies from him, also.
Stealing, I should say.
Q. What makes you think people were stealing from him over the years, ma'am?
A. I well, I hear a lot of stories about people made deals for him, a lot of them wanted
money under the table. Things like that.
Q. And who did you hear that from, ma'am?
A. Just different people.
Q. Were any of those people your son Michael Jackson?

A. Yes.
Q. So your son Michael Jackson had told you over the years, people asked for money
under the table when they were making deals with him?
A. Not with him. Making deals for him, and the people they made deals with came back and
told him.
Q. So people who were making deals for your son on his behalf? For your son?
Mr. Panish: unintelligible. Objection.
The judge: overruled.
The witness: repeat your question.
Q. so your son Michael Jackson told you would come to you and say that people had been
making deals for him and that they would take money for making those deals?
A. They were asking for money, and some of them would take money. But I don't want to
get into this. I've just all this is what I heard from my son. And what does this have to do with
the death of my son?
Q. I'm trying to understand what you knew at the time of his passing, ma'am, because in
many ways you're the only person we can find that out from.
Mr. Panish: objection to the narrative question of counsel.
The judge: overruled.
Q. so, ma'am, at the time of his passing, did you have an understanding from your son
Michael that he was having financial difficulties?
A. I think I answered that.
Q. If you did, ma'am, I didn't understand it, so let me just ask. Did you know that from your
son Michael ?
A. No. He never told me that.
Q. He never told you. So that's not a discussion you ever had with him?
A. No.

Q. And but you said that you had been hearing for years that he was bankrupt and that he
was having money problems; is that correct?
A. I didn't say bankruptcy.
Mr. Panish: objection. Misstates what she said.
The judge: sustained.
Q. you heard for years that your son was having financial difficulties?
A. I heard for years that Michael Jackson was broke. And he wasn't.
Q. And having heard this for years, did you ever bring it up to him and say, "I hear you're
having money trouble"?
A. No.
Q. Did you ever tell him that you'd been hearing that he was broke?
A. No, because I didn't believe it because he wasn't.
Q. Mrs. Jackson, you're aware that in this lawsuit, you're suing for an amount of
damages. Are you familiar with that?
A. You can talk to my lawyers about that.
Q. You talked to your lawyers about that?
A. I said, "you can."
Q. Okay. I want to ask all I want to understand, ma'am, is what you understand; okay? So,
for example, you saw that in your attorney's opening statements, he talked about the idea of it
being between 1.5 and $1.7 billion?
Mr. Panish: your honor, first of all, that's not what I said. And number two, this is improper
questioning of a plaintiff under Rifkind vs. Superior court, getting into factual contentions of a
plaintiff. If we need to go to sidebar, I have the cases. These are not appropriate questions.
Plaintiff can't say how much money they're asking for. Not something a plaintiff does. The jury
decides that.
The judge: okay. Let's go to sidebar and see the cases you're talking about.
Mr. Panish: yes. Sure.

(the following proceeding was heard at sidebar:)

Mr. Panish: first of all, I mean, for example, asking Mrs. Jackson these questions on
discovery, have you provided documents, we already heard in the cross-examination of Mr.
Erk about this 60,000 documents that AEG Subpoenaed from all accountants regarding Michael
Jackson's financial condition. So now for them to keep going in with this 83-some-year-old
witness, "did you have this document?" "did you have this document?" it's not appropriate.
Number two, factual contentions of a party are things that a lawyer does, not what a party does,
and that's what the Rifkind case is. And we went through this in the deposition extensively with
Mr. Putnam when he was asking questions, "give us the factual basis for this," "give us the
contention for that," and that's not appropriate. And the case is Rifkind vs. Superior court.
The judge: I need to look at it.
Mr. Putnam: yes. The difference of the time, your honor, because
Mr. Panish: I just wanted to give the citation of the case for the record.
The judge: okay.
Mr. Panish: 22 cal.app.4th 1255. Rifkind, r-I-f-k-I-n-d, vs. Superior court. 1994.
Mr. Putnam: and what the case makes clear, your honor we didn't understand at the time
how he could make a contention, couldn't understand what the plaintiffs' factual contentions
were. And so on the first day when we had her for a couple hours, they wouldn't let her answer
all of these questions. And I indicated, "you know what? I'm going to have to talk to the court
so I can understand what the basis of her claim is." and they said, "Rifkind, Rifkind, Rifkind."
and so we went off and read it and came back and explained to them that's not what the case
represents, your honor. What the case represents is not a very difficult idea, legally. I can't ask
for the legal basis. I can't ask her what the legal contentions that you're making here. I
understand that, and I'm not asking those. What I'm asking of her, your honor, is something I'm
very much allowed to do, which is to find out what her basis is factually. And in fact, your
honor, if you will recall, we had an argument about this very aspect that we're doing right now,
which is the aspect of her damages claim at the beginning of this case where you asked us to
come in with briefings. Ms. Chang argued it. I argued it. We came and talked about these
things. And you ruled twice at that time. And I can give you the cites of the trial transcript if
you like.
The judge: that's okay.
Mr. Putnam: okay. But, no, of course you can go into that arena. They can ask counter
questions, but we can go into that.
Mr. Panish: you never ruled that.
The judge: let me see Rifkind.

Mr. Panish: sure. And, your honor, what he's going to try to do now, I think, is get into the
statement of damages, which she's never seen.
The judge: sounds like it's dealing with depositions.
Mr. Panish: testimony.
The judge: trial?
Mr. Putnam: no.
Mr. Panish: deals with the testimony. Same thing. Deposition testimony, trial testimony. I
mean, this is totally inappropriate. It's a lawyer's work product of what is claimed, what are the
contentions, what's the complaint. That's the lawyer, not the client. And I'm going to go next. If
he finishes all this, then I'm going to go up on the stand, and we're going to discuss it all. Ms.
Chang: it basically stands for the proposition that someone who is a non-lawyer plaintiff cannot
be asked the basis for bringing legal claims and why, and what her factual understanding is, for
the same and simple reason that plaintiffs never know. And it's like an unfair trap by a lawyer to
say that they didn't understand or whatever. And she, of all people, hired attorneys, trusted the
attorneys to do their thing.
Mr. Panish: "and what is your claim for negligence?" it's the same thing. The plaintiff
doesn't know they
The judge: that would be asking a legal question.
Mr. Panish: but it's the same thing. What is your claim for damages? That's a legal basis
Mr. Boyle: here's the distinction, your honor. They try to get around this by saying, "oh, we're
just asking for her factual contentions." if this were a medical malpractice case, that would be
like asking the mother of the child, "well, what are the factual things that the doctor did wrong
that" you know what I mean? Or if this were a products liability case, "what are the facts that is
the defective design in the aviation cooling system?"
The judge: that's calling for expert
Mr. Boyle: right.
Mr. Panish: so is this damages. "what are your claimed economic damages?" expert. Same
thing. Legal conclusion. Interesting, Mr. Briggs wouldn't answer any of these questions,
saying "legal conclusion." their expert. It's asking for legal conclusions of a percipient plaintiff,
a non-expert plaintiff. And that's what that case interesting, in that case, the witness was a
lawyer that was being deposed. And the court says it doesn't matter if you're a lawyer or what
you are. That's the work product and the legal contentions of the lawyer, not of the party. Ms.
Chang: and I just want to clarify. The argument that I made at the beginning of the trial was for
them to be permitted to read from a document that was really not filed with the court. And the

purpose of it was just to give notice in the event of a default, and that it was never intended to
be used as an affirmative pleading in the case. That's what I argued and made a record of. And
we overruled on that, and he was able to use that $40 billion on
Mr. Putnam: and the reason, your honor, that it was overruled
The judge: let's hear the question first.
Mr. Putnam: is the case law didn't support the argument.
Mr. Panish: the
Mr. Putnam: yes. I can go through the case law.
Ms. Chang: we don't need to argue that.
Mr. Putnam: it says completely the opposite of the argument made. What I don't
understand is, we have had two different figures in this case: there's the $42 billion figure, and
now we have $1.5 billion that happened within a span of four months.
The judge: when was the $40 billion?
Mr. Putnam: on December 3rd, 2010.
Mr. Panish: it was a statement of damages that she's never seen.
The judge: yeah.
Mr. Panish: that's totally inappropriate. So what they're trying to say
Mr. Putnam: that's not inappropriate.
Mr. Panish: can I finish, please? Well, the statement of damages she's never seen says this,
now it says this; therefore, something must have happened. Now they are getting into legal
conclusions.
The judge: if that's where you're going, that sounds like you're asking legal questions
about a statement of damages that the lawyers file.
Mr. Putnam: but the lawyers
The judge: that she doesn't know anything about.
Mr. Panish: it's not even filed.
Mr. Boyle: not even filed.

Mr. Putnam: what it says, the case law says about that very thing; okay? That because it is
an element of what they're saying they believe their damages claim is, and they are an agent of
the person. If you look at it, it says, "Katherine Jackson hereby demands." that's what it says.
Mr. Panish: she doesn't sign it.
Mr. Putnam: and therefore I'm able to ask, "are you aware of this fact?" and that is clear.
And the reason the case law says and makes it very clear why is because of the fact that if
something is so out of whack this is what the case law says
Ms. Chang: it does not.
Mr. Putnam: is so out of whack with reality, the jury is allowed to assess that.
Mr. Panish: what case is that?
The judge: here's what I'm going to allow you to do: you're going to skip over this portion
of your questioning, and I want a brief on it.
Ms. Chang: okay.
Mr. Putnam: okay.
Mr. Panish: and I want to know the name of the case he keeps saying that says this. What's
the name of the case?
Mr. Putnam: the one that you cited on the record.
Mr. Panish: what is it?
Mr. Putnam: if you will let me finish, I will. And if you look at what we cited at the time
of this argument with ms. Chang, we went through
Ms. Chang: I cited the case.
Mr. Putnam: and then we came back with other cases that were cited, and they were cited
by ms. Strong at the time.
The judge: okay. So, fine. I want a briefing on the issue. Let's skip over this.
Mr. Putnam: i'll call her back.
The judge: I'm sure you have at lot of other questions. But I want it in writing so I can
consider it; okay?

Ms. Chang: yes.

Mr. Putnam: I have one more thing for the record.
The judge: and okay.
Mr. Putnam: I also want to note for the sake of the record, Mr. Panish indicated
several times he's going to call himself in reference to that. And I'd like to note we've done
actual research. Should he call himself in this matter, he does waive the areas he testifies about.
Mr. Panish: good. Looking forward to you cross-examining me.
(the following proceeding was heard in open court:)
The judge: you may continue.
Mr. Putnam: thank you, your honor.
Q. so Mrs. Jackson, you've been here for the Last 12 weeks; correct? Almost every day?
A. Correct.
Q. And during that time, you have seen that various claims of damages have been made;
correct?
A. Yes.
Q. And I have a question for you in reference to you said, "what does this have to do with
this case?" Mrs. Jackson, do you believe that your son is in any way responsible for his passing
in 2009?
A. No, I don't.
Q. You don't; right?
A. No.
Q. And you never have thought he was in any way responsible; correct, ma'am?
A. Repeat yourself.
Q. And you never thought he was in any way responsible for his passing; correct?
Mr. Panish: again, calls for a legal conclusion. Contention of the party.

The judge: overruled. You may answer.

The witness: repeat it.
Q. you, Mrs. Jackson, have never believed that your son had any part in his passing; is
that correct?
A. Correct.
Q. But do you believe that your son was aware that Dr. Conrad Murray was providing him
with propofol?
Mr. Panish: objection. No foundation, and it's also a legal conclusion. No foundation.
The judge: sustained.
Q. Mrs. Jackson, you attended the criminal trial of Dr. Conrad Murray; correct?
A. Yes.
Q. In fact, you helped the prosecution prosecute that matter; correct? Did you assist the
DA.'s office?
A. I don't understand the question.
Q. All right. There was a district attorney who was bringing that case on behalf of the city
of Los Angeles called David Walgren; correct?
A. Yes.
Mr. Panish: it wasn't the city of Los Angeles.
The judge: the people of the State of California.
Mr. Putnam: people of the State of California. Thank you, your honor.
Q. and did you assist him? Did you help him bring that case, ma'am?
The judge: well
Mr. Panish: I mean, come on.
The judge: they can bring a case regardless

Mr. Putnam: regardless

The judge: of what the parties want. Even if she didn't want to prosecute the case, the
dDA. Can decide to prosecute it. But I think it's a fair question to ask if she assisted,
cooperated with the DA, that type of thing. So, you know, rephrase it.
Q. do you remember helping Mr. Walgren in his prosecution of that matter, Ma'am?
A. No. I don't remember helping him, no.
Q. Okay. Do you remember during that criminal prosecution, you heard that your son
Michael Jackson had asked Dr. Conrad Murray to give him propofol?
Mr. Panish: objection. Calls for hearsay.
Mr. Putnam: I can ask if she heard it, your honor. And then I can ask if it surprised her and
discussed it with her.
Mr. Panish: it calls for a hearsay response.
The judge: overruled.
The witness: repeat it again.
Q. of course. I'm sorry, ma'am. I will always repeat I know we talk a lot on the side, so
anytime that happens, just let me know. At that criminal trial at the criminal trial, ma'am, did
you come to learn that your son Michael Jackson had specifically asked for the drug propofol
from Dr. Conrad Murray?
A. I had heard it.
Q. And you also heard during that criminal trial that he had asked for the drug from other
doctors; correct?
A. I had heard that.
Q. Are you saying you had or had not?
A. I had not heard that from other doctors.
Q. But did you hear that from the criminal trial?
A. That my son had asked for propofol?
Q. Uh-huh.

A. Yes.
Q. And you heard that he had asked that from Dr. Conrad Murray; correct?
Mr. Panish: objection. Asked and answered.
Mr. Putnam: trying to understand the answer, your honor.
The judge: sustained. She's answered it.
Mr. Putnam: okay.
Q. but you didn't hear during the criminal trial that he asked that from other doctors besides
Dr. Conrad Murray?
A. I might have. I don't remember.
Q. Don't remember?
A. No.
Q. And when you heard that your son Michael Jackson had asked for propofol from Dr.
Conrad Murray, did that come as a surprise to you at the time?
A. Yes.
Q. And why is that, ma'am?
A. Dr.Murray even though he asked for it, he could have said, "no."
Q. And you had never heard strike that. Had you ever heard, prior to that criminal trial, that
your son Michael Jackson was getting propofol from doctors at home?
A. No.
Q. That's not something you knew anything about; correct?
A. Correct.
Q. Now, you believe that your son hired Dr. Conrad Murray; correct?
A. No, I don't.

Q. You don't believe that?

A. No.
Q. You've heard here testimony that Dr. Conrad Murray worked for your son in Las Vegas;
correct?
A. Uhm
Mr. Panish: well, I'm going to object.
The witness: -- he didn't work for my son.
Q. okay. You haven't have you heard that testimony, though, here in the Last 12 weeks?
A. I might have heard it, but I didn't know what doctor. He got doctors for his children. I
don't know if it was Conrad Murray or not, in Vegas.
Q. And you understand that your son you've heard testimony that your son Michael
Jackson paid Dr. Conrad Murray for his services; correct?
A. For the children.
Q. Okay. But you've heard that testimony?
Mr. Panish: your honor, I'm going to object to all this, "you heard that testimony?"
The witness: no.
Mr. Panish: it's irrelevant.
Mr. Putnam: actually, your honor
Mr. Panish: can I finish the objection, please? What she heard, what the testimony speaks
for itself.
The judge: yeah. I think you need to follow up the question, if she heard it, yes. Then
Q. did you know before
The judge: so
Mr. Putnam: but the basis, your honor, is so much of this is what they knew at the time as
opposed to what they knew after.

The judge: that's okay. You need to follow up with the question
Mr. Panish: but it's irrelevant what she knew. They're not claiming anything against her.
Mr. Putnam: she said she had the cLosest relationship with her son.
Mr. Panish: but they're not claiming anything against Mrs. Jackson.
The judge: I understand that she's a plaintiff. I understand that. But just confirming she
heard something, we all heard it. So you need to follow up.
Mr. Putnam: exactly.
Q. and so you heard the testimony of your grandson, prince Michael , that he gave stacks of
hundreds wrapped in rubber bands. You remember that testimony, ma'am?
A. He didn't say, "stacks."
Q. Okay. What did he say, ma'am?
A. He measured with his finger.
Q. Uh-huh.
A. And it was just a small amount.
Q. Something like this; right (indicating)?
A. Because he felt bad for Dr.Murray because he didn't have any money.
Q. So you heard that testimony; correct, ma'am?
A. I remember that.
Q. Did you know that prior to hearing it at trial?
A. No.
Q. So you'd never heard that before?
A. No.
Q. And you just indicated that you don't believe that your son hired Dr. Conrad Murray;
correct?

A. No, I don't believe it, because I from listening here at court. I know I said it once, and
you'll probably bring that up, but I didn't really know.
Q. So what I'm about to bring up, what you're talking about, is the fact
A. Yes.
Q. that you've previously stated otherwise; correct, ma'am?
A. Yes, because someone had asked me, and there was a doctor. And not knowing that AEG
had hired him, I just said he hired a doctor.
Mr. Putnam: all right. So I'd like to show that, your honor. Exhibit 13,468.
Mr. Panish: Ive never seen it, so could I see it?
The judge: share it with plaintiffs. Ms. Chang: should we watch it somewhere?
Mr. Putnam: it's the dateline interview that she's referencing herself that she is expecting
me to bring up.
Q. is this something you looked at in preparation for your testimony here today?
Mr. Panish: well, how would she know? Objection. Foundation. How do we know? We
haven't seen it.
The witness: I remember
The judge: wait, ma'am. Hold on.
Mr. Putnam: the dateline interview's out there.
Mr. Panish: how do we know what it is if we haven't seen it? He just handed it to us right
now here.
The judge: he didn't turn
Mr. Panish: how are we supposed to know? How is she going to know if it's here
(indicating).
The judge: let's skip this part so they have an opportunity to look at it. And then you can
go back to it.
Mr. Putnam: this is cross, though, your honor. I don't have to give this in advance. Just
want to make sure it's understood.

Mr. Panish: also, not on the list.

Mr. Putnam: also what?
Q. so you're expecting me to ask this question. You just indicated that you know you said it
previously.
A. Yes.
Q. Why do you recall having said it previously?
A. Because I knew you were going to ask me, because I know from hearing all the e-mails,
they had said they hired him. On television I had heard that they had hired him. But at the time I
hadn't heard it, and so there was a doctor there, and I thought maybe Michael had hired him.
And I said it, not even knowing the facts.
Q. And are you talking about your dateline interview, ma'am? Is that what you're talking
about?
A. Yes.
Q. And you've indicated that you have some difficulty with some memories here. How do
you remember that so specifically?
A. Because that's what you all talked about. Of course, I didn't say I didn't remember
anything. I said I might have difficulties at first. I said, of my 83 years, I might not remember
everything clearly.
Q. But you do remember that you clearly stated previously that your son had hired a doctor?
A. Correct.
Q. And why do you remember that clearly? Just sticks out in your mind?
A. I just answered that question.
Q. So it sticks out in your mind as something you remember doing previously?
A. It sticks out in my mind because this is what you've been doing all during the trial.
Q. Okay.
A. And your people have said that they hired him, and you've been trying to say, "no."
Q. Are you talking about the line that Randy Phillips says on the interview, that portion of
the interview on sky news? Is that what you're talking about, ma'am?

A. I talked about what I had heard during the trial.

Q. Do you recall him saying
The judge: slow down.
Q. do you recall at any other time where that was said during this trial where somebody said
they hired Dr. Conrad Murray, other than that sky news piece with Randy Phillips?
A. It's been on e-mail.
Q. An e-mail said that we hired him?
A. I believe so. I'm not sure, but Ive heard that quite a bit here in this court.
Q. You have? And I'm asking you what "quite a bit" you heard, ma'am.
A. I answered that question.
Q. This interview on dateline, when was the Last time you saw it, ma'am?
A. I don't remember.
Q. Have you seen it since you gave the interview?
A. I don't remember.
Q. You can't remember the Last time you saw it?
A. No.
Q. But you can remember precisely what you said?
A. I answered that.
Q. Do you know if you've seen it since the interview was actually conducted?
Mr. Panish: she's already answered that.
The witness: I answered that question.

The judge: sustained. You're asking the same question.

Q. do you recall when that interview was, ma'am?
A. No, I don't.
Q. If I were to tell you it was on June 25th, 2010, would that sound right to you, ma'am?
A. I don't know.
Q. What if I that would be the first anniversary of your son's passing. Would that refresh
your recollection as to when that occurred?
A. No, it doesn't.
Q. If I were to tell you that it was eight weeks before you filed the lawsuit, would that
refresh your recollection, ma'am?
A. No. All I know is I remember hearing it.
Q. And have you told strike that. You said that why did you say it at that time?
A. Why did I say what?
Q. Why did you say on June let's assume for a moment it's June 2010. At the time can you
recall why you said that your son had hired a doctor and that he could have prevented and
therefore your son could have prevented his own passing?
A. I didn't say that.
Q. You didn't, ma'am?
A. I didn't say he "could have prevented his own passing."
Q. What do you recall you saying, ma'am?
A. I don't know exactly what I said, but I just said that I thought that
Q. Sorry, ma'am?
A. You're speaking of when I said he hired a doctor?
Q. That's the part you can recall?

A. Yes, I do recall that.

Q. Do you recall any other part of it, ma'am?
A. They asked me I can't recall exactly what was said, but then they said, "do you think his
death could have been prevented or" I can't remember all that, but I do remember saying he
hired a doctor that could have helped him.
Q. Prior to your son's passing, ma'am, had you ever met Dr. Conrad Murray?
A. No.
Q. And had you ever heard of Dr. Conrad Murray prior to your son's passing?
A. After he passed, I heard about Dr.Murray.
Q. Had you ever heard about him before your son passed?
A. No. Never heard the name.
Q. And so is it fair to say, then, that your son never discussed what treatments Dr. Conrad
Murray was providing him with?
A. No.
Q. Prior to your son's passing, did you know that there was a doctor spending the night at
your at your son's Carolwood home?
A. No, I didn't know anything about any doctors.
Q. And you had you ever discussed, prior to the trial, with your grandchildren that there was
a doctor spending the night at the house?
Mr. Panish: I'd just object. Other than what was discussed with the attorneys. I mean, this
could call for attorney/client privilege.
Mr. Putnam: I asked for anything
Mr. Panish: he didn't say that with the question.
The judge: rephrase that.
Q. other than the conversations you had with your attorneys

The judge: slow down so she can digest it.

Mr. Putnam: I'm sorry, your honor.
Q. prior to trial, Mrs. Jackson, did you ever have a conversation with your grandchildren
about a doctor spending the nights at the Carolwood home, other than any conversations you
may have had with your attorneys?
A. I can't remember.
Q. You can't remember, ma'am?
A. Say the question again.
Q. What I'm trying to find out, ma'am, is if you ever had any conversations with your
grandchildren prior to trial about a doctor spending the nights at the Carolwood home.
A. No.
Q. No. And so prior to trial, had any of your grandchildren ever told you that Dr. Conrad
Murray was spending six nights a week in the Carolwood home?
Mr. Panish: well, first, object. Other than meeting with the attorneys and her.
Q. I don't want to have any knowledge, ma'am, of any conversations you had with your
attorneys. So what I'm asking about is whether you ever had any conversation with your
grandchildren without the attorneys
A. No, I haven't.
Q. And so was the first time strike that. You had your grandson prince testify here in the
Last 12 weeks
A. Yes.
Q. correct, ma'am?
A. Yes.
Q. And during that testimony, he said that Dr. Conrad Murray would spend the night in the
house; correct, ma'am?

A. If he said it, I don't remember hearing it. I'm sure he might have said that. I don't
remember him saying that.
Q. So you don't remember that?
A. No.
Q. Do you remember him saying that he would stay six times a week?
A. No.
Q. Do you remember ever learning anywhere, ma'am, about Dr. Conrad Murray except with
your attorneys do you remember ever learning anywhere prior to this trial that Dr. Conrad
Murray was spending six nights a week at your son's Carolwood home?
A. No.
Q. So that's something you didn't know at the time you filed your lawsuit; correct, ma'am?
Mr. Panish: I'm going to object, your honor. I mean, it's seeking to invade the
attorney/client privilege.
Mr. Putnam: I don't want to know anything
Mr. Panish: no, but he says, "you didn't know," but then he needs to exclude conversations
with the children and attorneys all present. But by saying she didn't know, that's not true.
The judge: okay. Maybe you should have an agreement with Mrs. Jackson that all your
questions exclude any conversations between her and counsel so she understands going
forward. You don't have to keep repeating. So why don't you
Mr. Panish: that's fine.
The judge: discuss that with her.
Mr. Putnam: just to be clear, your honor, I am allowed to know what facts she knew
The judge: okay. I'm not disagreeing
Mr. Putnam: because if it's a fact
Mr. Panish: no. She can't tell if she got it from her attorneys.
The judge: facts are fine.

Mr. Putnam: exactly.

The judge: what I'm saying is, maybe you can come to some agreement with her that your
questions
Mr. Putnam: yes, your honor.
The judge: exclude conversations with her attorneys.
Mr. Panish: and/or grandchildren with attorneys present.
Q. Mrs. Jackson, I'm only going to have a little bit of questions with you. I know it
seems forever
A. I couldn't hear that.
Q. Sure. I'm only going to have a little bit of questions with you. I hope to be able to finish
with you this morning, if I can. During the time I'm asking you questions, I don't want to know
about any conversations you had with your attorneys; okay, ma'am? That's an area I don't want
to know anything about. So if I ask you a question, and you know it from your attorneys, I don't
want to know that; all right, ma'am? That is something I don't want to know.
A. Okay.
Q. So as we move forward, and I ask questions, those conversations are separate; okay,
ma'am?
A. Okay.
Mr. Panish: can I propose that we stipulate that any answers she gives exclude any
discussions with her grandchildren and attorneys all present or just her and her attorneys
present?
Q. unless it's facts, ma'am.
Mr. Panish: well, no. If she learned facts from her attorneys, that doesn't make him allowed
to ask about that.

Mr. Putnam: that's not true, your honor.

Mr. Panish: it's absolutely true. It's totally privileged.
The judge: okay. It's privileged. Let's go forward.
Q. so Mrs. Jackson, prior to bringing your lawsuit on September 15th, 2010, had you
ever had a conversation with your grandchildren about Dr. Conrad Murray spending the night at
the house up to six times a week?
Mr. Panish: same stipulations.
The judge: you may answer.
The witness: no.
Q. ma'am, you've indicated on friday that you thought this would be a search for the truth;
correct?
A. Yes.
Q. Don't you think that's an important bit of information for you in the search for the truth,
those conversations?
Mr. Panish: well, again, calling for attorney/client information.
Mr. Putnam: I'm not asking for any attorney information, your honor.
Mr. Panish: yes, he is.
The judge: I don't understand the question.
Mr. Putnam: the question is this, your honor: she's made a very big statement, as she takes
the stand under Mr. Panish, that the only reason she's bringing this is to search for the truth.
The judge: right.
Mr. Putnam: and therefore I think what's important is what that search involves. And how
she determined that, this is the only venue that she can get this truth.

The judge: okay. All right.

Mr. Panish: as long as she didn't learn it from the attorneys.
The judge: all right.
Mr. Panish: and the attorneys were involved long before the lawsuit was filed.
The judge: Mr. Panish, I think Mrs. Jackson understands. You may continue.
Q. so Mrs. Jackson, don't you believe that bit of information is important in your search
for the truth?
A. What bit of information?
Q. The fact that Dr. Conrad Murray was spending six nights a week at the carolwood home
and had been for some time?
A. It would be important, but I never I told you, I didn't know, and I didn't talk to my
grandchild about that.
Q. Did you ever talk to your grandchildren about the fact that Dr. Conrad Murray was
treating Michael Jackson upstairs in a bedroom behind locked doors?
A. No.
Q. Is that something that you learned here at this trial?
Mr. Panish: well
The witness: I didn't learn it
Mr. Panish: your honor, it's a real problem with these questions.
The witness: yes.
Mr. Panish: I want to make sure that she understands about I mean, because it all infers that
she doesn't know this.
The judge: she may have learned it from her attorneys.
Mr. Panish: yes. And I mean, it's really inappropriate questions.

Mr. Putnam: not inappropriate questions, your honor.

Mr. Panish: yes, it is.
Mr. Putnam: there's a long line of case law
Mr. Panish: what case?
Mr. Putnam: about what a person knows, and when they learned it.
Mr. Panish: which case is that?
The judge: all right. So what is your question, again?
Mr. Putnam: my question was well, she answered the question, which was the question of
whether she knew that her son Michael Jackson was being cared for by Dr. Conrad Murray
behind locked doors upstairs, and she said she didn't know that previously.
Mr. Panish: with the other stipulations.
The judge: other than maybe her discussions with her attorneys.
Mr. Panish: and what's the relevance of
The judge: overruled.
Q. Mrs. Jackson, you do believe that Dr. Conrad Murray has some responsibility for your
son's death, do you not?
A. Of course.
Q. And that's something you certainly believed for some time; correct?
A. What do you mean by "some time"?
Q. Well, since at least the time of his criminal trial?
A. Yes.
Q. And you saw that Dr. Conrad Murray was convicted criminally in that trial; correct?
A. Yes.
Q. And he's in jail now?

A. I suppose.
Q. Are you unsure of that?
A. I can't prove it, but I hope he is.
Q. And Mrs. Jackson, is it true that you asked the district attorney to drop the $100
million restitution claim against Dr. Conrad Murray?
A. Yes, I did.
Q. Why did you do that, ma'am?
A. Because Dr. Murray has children, he has no money, and his money should go to the
children. That's how I feel. I don't know, and I can't prove that, either. But I did drop it.
Q. If you can't prove that, ma'am, then why would you ask the district attorney to drop that
$100 million restitution claim?
A. Because I felt that his children needed it.
Q. And why is it that you believe that Dr. Conrad Murray didn't have that kind of money?
Mr. Panish: I don't think she said that.
Mr. Putnam: I think that was an exact quote, your honor.
Mr. Panish: no.
The judge: I'm sorry. She didn't say it? Is that what you're saying?
Mr. Panish: yeah.
The judge: overruled.
The witness: well, from him asking for so much money a month, and it had been said that in
court that he didn't have any money.
Q. and so when you learned he didn't have any money, you asked the district attorney to drop
the $100 million restitution claim?
A. I asked him to drop it because of his children. He had quite a few children, seven or
eight, I heard. I don't know.

Q. And after you asked the district attorney to drop the $100 million restitution claim, did
the state of California then drop that part of their claim against Dr. Conrad Murray?
A. Uhm, I didn't find all that out, but I imagine they might have.
Q. Well, you were in the criminal court, weren't you, ma'am?
A. Yes, I was.
Q. And do you recall it being announced in the criminal court that you were dropping that
part of the claim?
A. No, I didn't hear it in criminal court.
Q. Okay. Mrs. Jackson, did you drop your restitution claim because of the effect it would
have on this lawsuit?
A. No. I never gave it a thought.
Q. Mrs. Jackson, I want to talk about your son for
A. Moment, Michael Jackson. During his lifetime, you never witnessed him under what
you believe to be the influence of any drug, did you?
A. No.
Q. That's something you never saw; correct?
A. I never saw it.
Q. And you would visit his house sometimes unannounced?
A. Yes.
Q. And you'd get in; right?
A. Yes.
Q. And in those visits, you never saw him in any way that's been described as "loopy"?
A. "loopy"?
Q. Yeah. There's been some testimony about somebody talked about him being under the
influence and "loopy" or "out of it." did that ever happen on any of the those visits where you
stopped to see your son unannounced?

A. No.
Q. And you would talk to your son sometimes on the telephone; correct?
A. Yes.
Q. And do you recall ever having a telephone conversation with your son where he seemed
out of it?
A. No. Out of what?
Q. Well, I'm trying to see, was there ever a time you've seen a person drunk before; right,
ma'am?
A. Yes.
Q. And you've seen it sometimes, when a person is drunk, they act a little out of control?
A. Yes.
Q. And sometimes their speech is blurred (sic)?
A. Yes.
Q. And they see so when I say "out of it," I mean, you know, something that indicates that a
person is not quite themselves because in this instance because of some drug or alcohol, or the
like, that they might be taking; okay?
A. Okay.
Q. So was there ever a time that you saw your son Michael Jackson like that?
A. No.
Q. Was there ever a time where you had a telephone conversation with him where he
seemed like that on the telephone?
A. No.
Q. But you indicated on Friday that your children had told you that they believed your son
was addicted to prescription medications; correct?
A. Yes.
Q. And those are your children who told you that?

A. Yes.
Q. And do you have any understanding as to why they told you that?
A. Because they had heard it.
Q. Do you know whether they had experienced him where they had seen him, and he
seemed out of it?
A. No. They hadn't told me that he seemed "out of it," as you call it.
Q. Is there a term you would prefer that I use?
A. No, I wouldn't.
Q. Okay. But you understand what I mean when I say that here; correct, ma'am?
A. Yeah. Now I do.
Q. So you had conversations with your children, and they said that they thought your son
Michael Jackson had a problem with prescription medications; correct?
A. Yes. But they had heard it.
Q. And as a result of their saying that to you, you had a conversation with your son Michael
Jackson about it; correct?
A. Uhm, that was much later.
Q. Okay.
A. Yes.
Q. Let me make sure I understand that. So you had a conversation with your children where
they indicated that they thought that your son had
A. Problem with prescription medications?
A. Uhm, I wouldn't say, "a conversation." I just heard.
A. Couple of my kids brought it to me that they had heard it out there.
Q. And I asked if, whether as a result of that, you had a conversation with your son Michael
Jackson about it.

A. I talked to him about it, yes.

Q. Okay. And did you have that conversation in person?
A. Yes.
Q. And do you remember that conversation taking place in Las Vegas?
A. Yes.
Q. Now, just do you remember when that happened?
A. Not I don't remember exactly the year or anything like that. But at that time he was
living in Las Vegas.
Q. So one thing you recall is he was living in Las Vegas at the time?
A. Yes.
Q. In I don't want to go into the details, ma'am. I'm just trying to use it as a place marker.
You remember your son's criminal trial; correct, ma'am?
A. Yes.
Q. And you were there every day for that; correct?
A. Yes.
Q. And do you remember that ending in 2005?
A. Yes.
Q. And after that, your son left the country; correct?
A. Yes.
Q. And he never lived in Neverland again; correct?
A. Correct.
Q. He left the country for a period of time, and eventually he came back to this country;
correct?
A. Yes.
Q. And do you recall that he came back to this country sometime in 2006?

A. No. I wouldn't know the year.

Q. Do you know can you recall whether it was about a year after the criminal trial?
A. Could have been.
Q. But you do recall let me ask: you do recall, do you not, ma'am, that your son, when he
came back to the states, moved to Las Vegas; correct?
A. Yes.
Q. And that's where he was living when he returned to the states?
A. I think he lived in Las Vegas he left he left Las Vegas and returned to Las Vegas. I don't
know the years. It was twice that he lived there.
Q. Okay. But I'm just trying to get a reference of time. He was living in Las Vegas up until
the time he moved back to Los Angeles and to Carolwood; correct?
A. I can't say "correct," but I imagine. I don't know.
Q. Is it fair to say that this conversation that you had with your son Michael Jackson
occurred after he moved back to the states and was living in Las Vegas?
A. I can't answer that question. I don't remember.
Q. You do remember it was in Las Vegas?
A. Yes.
Q. And you do remember he was living there then?
A. Yes.
Q. And you do remember that he moved back to Las Vegas after he returned to the states;
correct?
A. I don't really, I don't remember.
Q. Okay. Well, I will represent to you, ma'am, that there's been testimony that your son
Michael Jackson was living in Las Vegas from 2006 until 2008; okay?
A. Okay.
Q. Do you remember you said you remember it took place in Las Vegas.

A. Yes.
Q. Do you remember where the where it took place? Do you remember where you were
talking to your son when you had this conversation about the use of painkillers?
A. Yes. It was I was getting ready to leave, and there's a theater not too far from the door.
And we stepped inside the theater, and that's where I talked to him.
Q. Let me ask a little bit about that. When you say, "not too far from the door"
A. Front door.
Q. The front door of the house?
A. Yes.
Q. And what house was this?
A. In Las Vegas.
Q. Was this the Palomar house?
A. No.
Q. What house was it, ma'am? Do you remember where the house was?
A. No. I don't remember the street or anything.
Q. Can you describe it? What was it like?
A. Two-story house.
Q. Uh-huh. Was it light?
A. I don't even remember the color.
Q. Okay. Do you know if the children were living in the house at the time?
A. Yes.
Q. Do you remember approximately how old they were?
A. No, I don't.
Q. Okay. So you stepped out of the house, and there was

A. Theater. Was the theater on the property?

A. I didn't step out of the house.
B.
Mr. Panish: misstates what she said.
Mr. Putnam: I apologize.
Q. you said it was near the door?
A. Yes.
Q. Was the theater on the property?
A. Yes.
Q. So it was part of the house?
A. Yes.
Q. Okay. And so you're at the property, and you stepped into the door where the theater to
the house was; correct?
A. Yes.
Q. And you did this as you were getting ready to leave?
A. Yes.
Q. And this conversation was just between you and Mr. Jackson?
A. Yes, it was.
Q. And was this where you told him that you had heard that he was using prescription
drugs?
A. Yes.
Q. And is this the only time you ever had that conversation with him?
A. Yes.
Q. No other time ever in his lifetime where you had that conversation?

A. Only time.
Q. Okay. And is this the conversation that you mentioned on Friday where you said that
you didn't want him to end up that he would be like the others?
A. That's right.
Q. What did you mean by that?
A. I didn't want to hear one mention that or one day that something had happened to him.
Q. And when you told him this, that you had heard that he was using prescription drugs, he
denied it, didn't he, ma'am?
A. Yes, he did. He didn't yes, he denied it.
Q. And it didn't surprise you that he denied it, did it, ma'am?
A. Well, I'm his mother. And quite naturally he'll deny it, because he wouldn't want me to
think that. And then
Q. And then what, ma'am?
A. I'm his mother, and no child is going to admit if he thinks that I'm thinking something
bad about him, he's not going to admit that then. It might not have been bad at all, but he's not
going to say "yes" to anything like that.
Q. In fact, that was part
A. And I know he was taking pain pills, prescription pain pills, for his ailments.
Q. What ailments?
A. For his pain in his head and for his back.
Q. And at the time of this conversation with your son in Las Vegas, you knew that he was
taking pain pills?
A. Yes.
Q. And you asked him about it, and he denied it?
A. I didn't know he was taking pain pills. I couldn't prove it. It's what I had heard.

Q. That's what I'm trying to understand, ma'am. So you had heard he was taking pain pills,
you asked him if he was taking pain pills, and he denied taking pain pills; correct?
A. Yes.
Q. And that didn't surprise you because you're his mother?
A. I said it didn't surprise me, because your child is going to want and then they don't want
their mother worried about them. And then they I'm sure you understand what I mean.
Q. And I do, ma'am. And I'm trying but I'm trying to explore it so I can understand what you
mean to yourself what it is you understood and why. So at that moment you took him aside, you
asked him about this, and he denied it, and you said that didn't surprise you. You said that on
Friday as well. And you're saying it didn't surprise you because he wouldn't want his mother to
worry; correct?
A. Right.
Q. And this is the only conversation you ever had with him about him taking pain pills?
A. Yes.
Q. And so and this is sometime when you're in Las Vegas; correct?
A. Correct.
Q. Mrs. Jackson, if you knew your son was going to deny it, why did you ask him?
A. I like nothing.
Q. Excuse me, ma'am?
A. I'm not answering that question.
Q. Why, ma'am?
A. Because to me it doesn't make sense. I didn't know he was going to deny it, but he did.
Q. Just so I understand, you didn't know he was going to deny it, but it didn't surprise you
that he did? Is that what I am to understand?
A. It's because he didn't want me to worry. He's my son, and if any mother asks a child if
they're on drugs or anything but he wasn't on drugs. I just talked to him about it. I didn't think it
was that serious that
Q. What's not that serious, ma'am?

A. That you have to drill me like this on him. Because if a child goes out and plays and does
something real ugly, and a parent asks him about it, he's going to deny it. And I'm sure you
understand what I'm trying to say. My child, he respects his mother, and he doesn't want her to
think that he's doing something that is bad. Or if it is bad, then it's not bad if it's prescription
drugs.
Q. But he wasn't a child in the school yard, ma'am. He was a 50-year-old man; correct?
A. He's still my child. And I'm still his mother, and he still wants my respect, and he still
wants to respect me.
Q. You said that you mentioned to your son that your children had heard that he was using
prescription drugs. But you never said to him that you heard that he was abusing drugs; correct?
A. Correct.
Q. This was just you were literally only asking if he was using them; correct, ma'am?
A. I told him I had heard, and I didn't mention I had heard he was using them. I just heard
maybe I did. You're just getting me confused so you can have something to come back on me
for. I'm telling you the truth.
Q. Ma'am, I didn't say you weren't, and I'm not trying to just come back with something
else. I'm trying to understand what has occurred.
A. You do understand it, but you keep asking me the same questions, and i've answered it.
I'm sorry.
Q. Has there ever been a time, ma'am, where you believe that your son was abusing
prescription medications?
A. No.
Q. Now
A. I knew he was taking them, but I didn't think he might have been abusing them.
Q. And in this conversation at Las Vegas, when he said that he wasn't taking them, you
didn't know whether he was taking them or not at that time; correct?
A. I just asked him the question because I wanted to make sure.
Q. Now, Mrs. Jackson, even though you've never believed that your son was abusing
prescription medication, you did participate in an attempted intervention of your son, did you
not?

A. Yes, I did.
Q. And that intervention was at the Neverland Ranch?
A. Yes, it was.
Q. And it was your children who asked you to help in this intervention, wasn't it?
A. Yes.
Q. And didn't you say on Friday that your children asked you to do so because they believed
that you, as his mother, might have some impact, and it would be important to this intervention?
A. Yes.
Q. And your daughter Janet Jackson participated; correct?
A. Yes.
Q. And your daughter Rebbie?
A. Yes.
Q. And your son Jackie?
A. I don't believe Jackie I'm not sure, but I don't think he was there.
Q. What about Tito?
A. I don't think so. I'm not sure.
Q. You don't know. What about Randy ?
A. Randy was there, I think.
Q. And La Toya?
A. Yes, I think so. I don't remember who all was there.
Q. Mrs. Jackson, I'm going to show you something and see if I can help refresh your
recollection; okay, ma'am? Are you aware of a book that your son Jermaine Jackson wrote
called, you are not alone, Michael?
A. Yes.

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

Mr. Putnam: may I approach, your honor?
The judge: you may.
Q. Mrs. Jackson
Mr. Panish: what page are you on?
Mr. Putnam: 356 to 357. Same as at the depo.
Q. Mrs. Jackson, what I'm going to ask you to look at it is beginning right here
(indicating), and goes through right here in the very beginning here where you see that it talks
about
Mr. Panish: well, your honor, if he wants her to read a portion, he should say, "please read"
The judge: yeah. Just show her.
Mr. Panish: and then ask if it refreshes her recollection.
Q. if you could read from here, ma'am, to here (indicating). And just so you know what's
coming, I'm going to ask you if it refreshes your recollection as to who was there and where it
refreshes your recollection as to when this occurred.
Mr. Panish: yeah. Read it to yourself.
The judge: read it to yourself, ma'am.
The witness: (witness complies.)
Q. Mrs. Jackson, I have a photocopy that's blown up a bit. If I may approach, I can give
you that, and it's a little easier to read.
A. Okay.
Q. This is that same thing starting there (indicating), and then goes to the next page
(indicating).

A. Okay.
Q. Okay, ma'am?
A. (reviewing document.)
Q. Did you have time to read that, ma'am?
A. Yes.
Q. Does that refresh your recollection as to who was at the intervention?
A. No.
Q. It doesn't refresh your recollection?
A. Because it doesn't mean all of them were there, no.
Mr. Panish: I think she answered the question.
Q. okay. Mrs. Jackson, so as you sit here today, and after looking at that, you still can only
recall that Janet, Rebbie, Randy and maybe you were there?
A. Yes. I recall that.
Q. Do you recall any of your other children being there?
A. I don't recall Jackie was there.
Q. What about Tito?
A. I don't recall Tito was there, either.
Q. So you don't recall any other children being there besides the three that you just
mentioned?
A. They could have. I have nine children. I don't remember who all was there.
Q. Okay, ma'am. Well, this was kind of a big deal, wasn't it? I mean, had you ever been
involved in an intervention with your son before?
A. No.
Q. Had you ever been involved with an intervention with your son since then?

A. No.
Q. So this was the only time you ever did this; correct, ma'am?
A. Yes.
Q. And you participated with a number of members of your family?
A. Yes.
Q. Did you also bring a doctor with you?
A. I didn't bring anybody with me. There was someone that came along, but it wasn't a
doctor.
Q. Was it someone whose specialty was interventions?
A. No.
Q. Do you know who that person was?
A. Somebody that Janet knows.
Q. So there was an intervention with somebody Janet knows. And did she bring him or her
along?
A. She brought him along.
Q. It was a him?
A. Yes.
Q. And how did you get there, ma'am?
A. Car.
Q. By car? Do you remember who you traveled with?
A. No, I don't.
Q. Did you travel from Hayvenhurst?
A. Yes.
Q. Did the people you traveled with all travel together?

A. I think we had two cars. Maybe more. I think it was only two.
Q. And do you recall this took place in 2002?
A. Since that I saw it.
Q. Do you recall that, ma'am?
A. Yes.
Q. Okay. And 2002 you were at Neverland. And did Mr. Jackson let you right in? By "Mr.
Jackson" I apologize. There were a lot of Jacksons, I know. Did Michael Jackson let you
right in?
A. I don't know because he had security. I don't remember if we went right in, or if they
called the house to get permission. I just don't remember that.
Q. Because it was common you'd have to call ahead and get permission; correct, ma'am?
A. Yes.
Q. And when you went to Neverland, Mr. Jackson, Michael Jackson, knew that you
all had come to speak with him about his use of prescription drugs; correct, ma'am?
A. I don't think so.
Q. You don't think so? Why not, ma'am?
A. I just don't believe so. I don't think they let him know that they were coming. I don't
believe so.
Q. So you don't believe your son knew why they were coming. And then did a time come
after you arrived that Mr. Jackson realized why you were there?
A. After we were there for a while, he did.
Q. And is it true that your son Michael Jackson was upset that you and his brothers and
sisters had come to Neverland for an intervention?
A. Yes, because when we got there, there was nothing wrong with him.
Q. So he was mad because when you got there, he was fine?
A. Yes, he was.
Q. And did Mr. Jackson tell you, "there's nothing wrong with me"?

A. I don't remember what he said, but we knew it.

Q. But you knew it not just because you just looked at him, he actually told you that he
wasn't abusing prescription drugs, didn't he, ma'am?
A. If that's what you read. I don't know. Jermaine was out of town. This was speculation,
also. But I'm not denying that we did it; we did. But anything else I might have read in that
book, maybe and someone else wrote the book with him.
Q. And Mrs. Jackson, that's why I'm not asking what the book says. I'm asking for your
memory, because you were there; right?
A. Yes, I was there.
Q. And your children asked you specifically to go because of your influence with your son;
correct?
A. Yes.
Q. And when you got there, you told him that you were there because there was a fear that
he was abusing prescription medications; correct?
A. I didn't tell him that, no.
Q. Did someone in your party tell him?
A. I didn't hear them say that.
Q. Do you remember your son denying that he was abusing prescription medications?
A. They didn't even question him about it. About prescription medication.
Q. What happened?
A. We just saw that he was okay, and he was upset, and so we didn't talk about it.
Q. So it wasn't talked about at all, ma'am?
A. That's what I said.
Q. So you all went up for an intervention, got there, he seemed okay, and then you didn't
discuss it?
A. Well, he they talked about why they came.

Q. Uh-huh.
A. And they didn't discuss it. Wasn't no heavy discussion or nothing like that.
Q. But he knew why you were there, ma'am; correct?
A. Of course, yes.
Q. And he said to you he denied that he was abusing prescription drugs; correct, ma'am?
A. He didn't deny anything. He was okay.
Q. So when you say "he discussed it," what did you mean?
A. I said we they discussed well, no deep discussion or anything like that. When we got
there, he was okay. He was upset, so
Q. Why was he upset?
A. not a big because they had come in for an intervention on him, and he didn't like it, I can
imagine. I don't know.
Q. So
A. I just know I was there, and it was kind of embarrassing because he didn't know they
were coming, and they didn't see anything. That's all I know.
Q. And you know he was upset because of it; correct, ma'am?
A. Yes, he was upset.
Q. But you're saying he didn't deny
A. But he wasn't upset to the point that he was yelling and fussing and stuff like that.
Q. But you could see that he was upset; correct, ma'am?
A. If I said he was upset, I could see it.
Q. Okay. And he also said he also said to you, did he not, ma'am, that he wasn't on
anything?
A. I didn't say that.
Q. You didn't say that, ma'am?

A. Repeat yourself.
Q. Please. I'm trying to find out whether your son Michael Jackson, when you arrived for
this intervention, and after he got upset, whether he said to you, "I'm not on it. I'm not on
anything."
A. He didn't say that.
Q. He didn't?
Mr. Putnam: your honor, I'd like to show Mrs. Jackson's deposition from April 17th, 2012.
Going from page 14, line 22, to
Ms. Chang: I'm sorry, what page?
Mr. Panish: 14.
Mr. Putnam: 114.
Mr. Panish: oh. You said 14.
Mr. Putnam: line 22, to 115, line 10.
Ms. Chang: I'm sorry. Can I have the line number again?
Mr. Panish: 10.
Mr. Putnam: line 22, to the next page, line 10.
Mr. Panish: go ahead.
Mr. Putnam: go ahead?
Mr. Panish: sure.
The judge: hold on. We need a bathroom break. All right. We'll play it when we come
back. Let's do 10 minutes, if we can.
Break

Mr. Putnam: any objections?

Mr. Panish: no.
(a video clip was played with the following testimony being said:)
"did you see him getting upset?
"I knew he was upset, but I didn't see him getting upset.
"how did you know he was upset?
"the way he talked.
"and what did he say that made you think he was upset?
"it's not what he said. It was how he said it. "I think "and that "sorry. "and I don't ask me to
explain. And he said, 'I'm not on it,' and, you know, that's all."
Q. do you remember that, ma'am?
A. Yes.
Q. Was that not so? Did he in fact not say that? Did he say, ma'am, "I'm not on it"?
A. I was upset with you, and the way you were asking me the questions.
Q. Kind of like today?
A. Worse.
Q. Okay. And so
A. And that's why I was talking the way I was talking, and I wanted you to leave me alone.
Q. And so you're saying that that's not how you talked through the whole deposition,
ma'am?
A. This deposition?
Q. Uh-huh.
A. Maybe. I don't know.
Q. Okay. So

A. I was trying not to.

Q. So my question, ma'am, though, wasn't how you felt about me. My question was: do you
recall at the intervention your son denying that he was on prescription drugs?
A. Tell you the truth, I don't know. I don't I'm not trying to get out of it. I just don't know.
Q. Okay. And when you said that he said, "I'm not on it" at the deposition, was that not true
at the time? You just wanted me to stop asking you questions?
A. I wanted you to stop asking me questions?
Q. I'm trying to figure out why you said to me at your deposition that he, Michael
Jackson, your son, said "I'm not on it."
A. I don't remember Michael saying that.
Q. You don't?
A. No.
Q. Do you remember your saying that he did say that?
A. I remember that. And I was upset with you because you kept and you know how you
were when I was in your office.
Q. Yes, I do, ma'am.
A. Okay.
Q. And so I'm going to ask you the question one more time, if I can, ma'am. Did your son
not say, "I'm not on it"?
A. And I told you, I don't remember.
Q. And then my question was: so why did you tell me that at your deposition?
Mr. Panish: well, your honor
The witness: I wasn't trying to lie or anything. I was just tired of you, the way you were
digging the same thing. You remember me asking you, "why are you doing this to me? You're
asking me the same question about 50 times and rephrasing them differently."

Q. and do you remember me explaining to you, ma'am, that you're bringing a lawsuit against
AEG Live for billions of dollars, and you're the person I need to ask questions of to get the
information?
A. But why 50 questions in different ways? And I gave you the same answer.
Q. Is it because sometimes your answer, ma'am, does something else other than addressing
the question I'm asking?
Mr. Panish: that's argumentative.
The judge: sustained.
Q. so Mrs. Jackson, you don't recall, as you sit here today, today, your son denying that
he was on prescription drugs with you at Neverland?
Mr. Panish: asked and answered.
The judge: sustained.
Q. did you
A. Excuse me?
Mr. Panish: you don't have to answer.
The witness: okay.
Q. do you remember in your deposition telling me that you didn't know whether to believe
your son or not?
A. You're at the house I mean, at the courthouse Ive told you that.
Q. So at the time of the intervention, ma'am, you didn't know whether to believe that your
son was on prescription drugs or not; correct?
A. I knew he was on prescription drugs, but I didn't think he was abusing them.
Q. And after this intervention in 2002, or attempted intervention, did your mind change as to
whether you believed he was or was not abusing prescription drugs?

A. Repeat the question.

Q. After you all went up to Neverland in 2002 and tried an intervention, and he seemed fine,
you can't remember what he said, but you recall that he seemed upset?
A. Yes.
Q. Did your mind change at that point in any way as to whether you believed your son was
abusing prescription drugs?
A. I didn't think one way or the other.
Mr. Putnam: can we get exhibit 12,717? May I approach, your honor?
Mr. Panish: could we have a sidebar on this issue?
Mr. Putnam: this is what you discussed in her direct; right?
Mr. Panish: no.
The judge: okay. Well, let's take it at sidebar, then.
(the following proceeding was heard at sidebar:)
Ms. Chang: okay. Are we on? Okay. Here is the only thing that we have to add. It's not as
drastic as you think. The first paragraph of this indicates that people magazine has "followed
other publications in reporting untrue and inaccurate information." we need that people
magazine article, because in order for this to make sense, it is a 2007 article, and it was alleging
that he was abusing it and that they had an intervention in 2007. So, therefore, this cannot make
sense without the people magazine article. It's partial; it's taken out of context. And this
appeared in people magazine's editorial section. And she was questioned about it in her
deposition without the original people magazine. She didn't recall what it was referring she said
her publicist had her sign it. But, in essence, it is true with respect to, there was no intervention
that the family asked for in 2007.
Mr. Putnam: and, your honor, first of all, she wasn't asked anything about this in her
deposition, so I'm not sure where we're getting that from. So that's categorically not true.
Second, your honor, she's able to explain, as the words of this state what this is, why she signed
it. And on direct, she was specifically asked about this, and she said, "I signed it." so, your
honor, I think I can ask if she says she doesn't recall, as she does for any hard question, she can
do that here. But I'm certainly allowed to ask her this, and it has her signature on it, and she said
she signed it.
Mr. Panish: all we're saying

Mr. Putnam: if they would like to explore on redirect any issues from the people
magazine piece, they're welcome to do so. I don't have to do that with this document.
Mr. Panish: we're just saying in the context. And I would just note for the record that Mr.
Putnam's statement that she says she doesn't recall for any hard questions, that seems kind of
ironic that someone who prepared their witnesses to remember nothing in all their depositions
in defense of this case would make such a statement.
Mr. Putnam: and I'd like it stated on the record, that's not how they were prepared.
However, I know you would like the jury and the press to believe, but that's not the case. But
for now, let's talk about why we're actually here.
Mr. Panish: then why did you bring it up?
Mr. Putnam: I would like to ask her the questions, if I may.
The judge: you can ask.
Mr. Panish: and we can bring in the article to clarify?
The judge: we can talk about it.
Mr. Putnam: thank you, your honor.
(the following proceeding was heard in open court:)
The judge: okay. You may continue.
Mr. Putnam: any objection, Mr. Panish?
Mr. Panish: no. Go ahead.
Mr. Putnam: all right. Could we please put up exhibit 12,717?
Q. By Mr. Panish: and so Mrs. Jackson, have you had time to review this document?
Mr. Panish: did you give her a copy?
Mr. Putnam: yes.
The witness: no, he didn't give me a copy.
Mr. Putnam: I apologize. May I approach, your honor?

The judge: you may.

Q. I'm sorry, Mrs. Jackson (indicating).
Mr. Putnam: and one for the judge.
The judge: thank you.
Q. Mrs. Jackson, I'm going to go through this with you.
Mr. Panish: can she just read it, first?
Mr. Putnam: read it.
The witness: (reviewing document.)
Q. all right, Mrs. Jackson. So the top of this says, "the Jacksons." and then it goes on to
say, "September 7, 2007." do you see that, ma'am?
A. Yes, I do.
Q. And the next paragraph begins: "people magazine has followed other publications in
reporting untrue and inaccurate information about Michael Jackson and the Jackson
family. Of these wildly reported rumors, what has become most troubling and heinous is that
my son, and our brother, Michael Jackson, is dependent on painkillers and alcohol." do
you see that, ma'am?
A. I do.
Q. Do you remember this people magazine article?
A. No.
Q. Do you remember the other publications reporting something that was untrue and
inaccurate about your son being dependent on painkillers and alcohol
A. It was go on. Go on.
Q. in this time?
A. Repeat.

Q. Sure, ma'am. Do you remember in September of 2007 there being publications that were
reporting rumors of which the most troubling and heinous was that your son Michael Jackson
was dependent on painkillers and alcohol? Do you remember those publications?
A. I had seen some.
Q. Okay. So you had seen publications that had reported this. And when I asked you why
you talked to your son Michael Jackson, when he was living in Las Vegas, and talked about
this being, perhaps, in 2006 to 2008, you'd indicated that you had heard this information from
your children. Did you also get information from publications that there were rumors that your
son was using and I'm sorry, dependent on painkillers and alcohol?
A. It was out there in magazines and things. I never bought them and read them.
Q. Okay, ma'am.
A. And the reason I signed this paper, my children brought it to me. And some of this we
weren't trying to intervene and take over his business and everything like that. All these were
lies.
Q. So let's talk about those. That's the next paragraph. It says: "people and other news
organizations have quoted 'sources' indicating that our family has attempted a drug
intervention and engaged in an effort to take over his business affairs because of this
alleged drug and alcohol usage." correct?
A. I see what you read, yes.
Q. And is that what you're saying, you never attempted to do that? You never attempted to
take over your son's businesses?
A. No.
Q. Do you think it would have been inappropriate for you to intervene if you thought your
son had a drug problem?
A. Repeat yourself.
Q. Sure. Please, ma'am. I'm trying you just had a reaction to this idea of taking over your
son's businesses?
A. No.
Q. I'm trying that never happened; correct?
A. No.

Q. But you had attempted at least one intervention before, had you not?
A. Yes.
Q. And but what you're saying is that what you didn't do is that you never tried to take over
his business affairs; correct?
A. No.
Q. And in the next paragraph, it says: "we categorically deny ever planning, participating
in, or having knowledge of any kind of intervention whatsoever. We strongly believe that
these 'sources' and others, no matter who they are, are making these defamatory, inaccurate,
and untrue claims for monetary reasons." do you see that, ma'am?
A. I do.
Q. Now, that's not true, though; right? You can't categorically deny ever any planning,
participating in, or having knowledge of any kind of intervention; correct?
Mr. Panish: I'm going to object, your honor. It's referring to the article, if you go back to the
time.
The judge: overruled.
Mr. Putnam: it doesn't.
Mr. Panish: it does.
Q. I'm sorry, ma'am. You said "no" to that question?
A. Just because it's in the magazines, the tabloids, that means there's liars in the world. Most
of this letter is not true.
Q. Most of it is not true. Some of it's true, though; right?
A. Plus I didn't write this letter.
Q. Excuse me, ma'am?
A. They're just talking about me, and it says my son and let me see the first paragraph.
Q. I can show it
A. Quite naturally, Ill sign it because there are lies. These are all lies. Nobody planned to
take over his business, or anything like that.

Q. All right, ma'am. Well, it's those magazines may have published some lies, ma'am, but it
wasn't a lie that you'd attempted an intervention before, was it, ma'am? You had attempted an
intervention, hadn't you?
A. Yes. At one time, I told you. My children wanted me to go along.
Q. And you didn't remember if your children tried at other times, had they not?
A. I don't know. They might have. I don't know.
Q. You don't know. Goes on to say that: "Michael Jackson and the Jackson family
have endured years of false accusations and misrepresentations. It's time for the unfair and
hurtful rumors for profit to end. Thank you." you see that, ma'am?
A. Yes, I do.
Q. Now, at the bottom there are a bunch of signatures; right?
A. Yes.
Q. One purports to be the signature of Tito Jackson; one for Marlon; one for Jackie; one for
Jermaine. And there's yours at the bottom; correct, ma'am?
A. Correct.
Q. And you did sign this, didn't you?
A. That's my signature.
Q. And you said on Friday, when asked on your direct, if you could recall signing, was
asked that, you said, "yes, I can recall signing." do you recall signing this?
A. I told you Friday I recall signing it?
Q. Yes, ma'am. "you know what? I don't really remember that thing, but I did sign
something." is this the "something" you're talking about, ma'am?
A. Probably, yes.
Q. And why would you sign it if it wasn't true?
A. I signed it because I wanted them to stop talking about things that weren't true.
Q. You also wanted them to stop talking about your son?

A. This is not a letter to sign something that is true. It's a letter to sign something because
it's not true, and we want them to stop. But as far as the intervention, that's the truth.
Q. And, so, ma'am, it's your understanding that this was done to try to get the press to stop
talking about your son's drug use; is that correct, ma'am?
A. To stop telling a lot of lies.
Q. And would it be a lie to say that there had been an attempted intervention of your son?
A. No.
Q. Because there had been; correct, ma'am?
A. I told you, we went, and that was my first time ever.
Q. And is what you're trying to tell me, ma'am, is that you didn't try an intervention in
2007? Is that correct?
A. I don't remember. 2007?
Q. Uh-huh.
A. No.
Q. And do you know if your children attempted any interventions at that time?
A. I don't know. I only know that I did one time.
Q. And, ma'am, was it your hope that by sending this letter out, people would stop talking
about your son's rumored, rumored, drug use?
A. I knew most of the tabloids, that's the way they make money. I just wanted them to stop
lying about our trying to take over his business, and all of that.
Q. So that's what offended you at the time; right, ma'am? What you were worried about
was the press saying that you were trying to take over his business? Is that
A. I was worried about all the lies they were telling about the family.
Q. Was it telling a lie at the time, ma'am, that your son had a problem with prescription
drugs?
A. Pardon?

Q. Was it a lie for the press at the time to say that your son had a problem with prescription
drugs?
A. As far as I'm concerned, yes, because I didn't think he had a problem. But he might have
had a problem, because my children and other people was talking about it. I imagine that's just
hearsay. But I'm not trying to deny. But as far as the tabloids, I wouldn't waste my time on
them, because I know all they do is lie because they want to make money.
Q. But if that's true, ma'am, then why send this letter?
A. I don't know why.
Q. Isn't it true, ma'am, that you wanted to keep the intervention a secret?
A. I don't know what they I went on one intervention.
Q. Mrs. Jackson, isn't it true that your son Michael Jackson is the one who asked you
to sign this?
A. I don't remember Michael asking me to sign this.
Q. You don't?
A. No, I don't.
Q. Well, do you remember your son Michael Jackson being involved in the drafting and
ultimately the execution of this agreement? I'm sorry, not agreement. Letter.
A. Pardon?
Q. Do you remember your son's involvement in getting this written and signed?
A. No, I don't.
Q. You don't remember that at all?
A. No.
Mr. Putnam: can I please see the deposition of Randy Jackson? I want pages 223 and 224.
Mr. Panish: it's hearsay.
The witness: yes, it is.

Mr. Putnam: I'm sorry. What was the statement?

Mr. Panish: I said it was hearsay, and she agreed.
The witness: it is.
The judge: well, what are you trying to do, first?
Q. you know it was hearsay, ma'am?
The judge: wait a minute. You're talking to me.
Mr. Putnam: I'm sorry. I know you're not "ma'am." I'm absolutely not talking to you, your
honor.
The judge: okay.
Mr. Putnam: sorry. I would not do that. I apologize. I want to approach, if I may, and show
Mrs. Jackson her son's deposition.
Q. have you read your son's deposition in this matter, ma'am? Randy Jackson?
A. No.
Q. Have you read any of your children's depositions in this matter?
A. No.
Q. Why not?
A. Well, I don't know. I just didn't choose to.
Q. But this is a search for the truth, though; right, ma'am?
A. Yes. But just because he said it I don't know anything about it. You want the truth that I
knew.
Q. I'm going to put it on your screen. Not the big screen
The judge: well, can't put it up on the big screen.
Mr. Putnam: not the big one. I'll just bring it up so she can see it.

Mr. Panish: take it up.

Mr. Putnam: Ill bring it up. I was only doing it for time, your honor. I'll get the actual
hard copy. Trying to print it out for her.
Mr. Panish: why don't you ask about something else and come back to it?
Q. have you had a chance to look at the dateline piece?
Mr. Panish: no. Haven't had time to do anything.
Mr. Putnam: I thought you saw it at the break.
Mr. Panish: I helped Mrs. Jackson go to the bathroom. I'm sorry.
The judge: please don't have discussions among yourselves, please.
Mr. Putnam: while we're doing that, can we come back to it?
The judge: yes.
Q. so Mrs. Jackson, in terms of this letter that you're looking at, do you remember what
the result of that letter was?
A. You mean this letter (indicating)?
Q. Yes, ma'am.
A. No.
Q. You do remember signing it, but you don't remember who asked you to sign it?
A. No, I don't.
Q. And this was September of 2007; right, ma'am?
A. That's what it says.
Q. The conversation that you talked about having with your son Michael Jackson in Las
Vegas, do you recall whether you had that conversation before this letter was signed?
A. I don't even remember when this letter came.

Q. You don't?
A. No, I don't.
Mr. Putnam: may I approach, your honor?
The judge: yes.
Q. I'm just asking you if you could read it, ma'am, to yourself.
Mr. Panish: "does this refresh your recollection?" that question?
Mr. Putnam: uh-huh.
The witness: (reviewing document.)
Q. ma'am, does that refresh your recollection as to whether it was your son Michael
Jackson who asked you to sign this document?
A. No, it doesn't.
Q. It doesn't, ma'am?
A. No.
Q. All right. Let me ask you a question. Ma'am, let's assume for a moment that your son
Michael Jackson strike that. Let's assume for a moment that your son Randy Jackson
testified in deposition that it was Michael Jackson who asked you to sign this document, and
that's why you signed it. Would he if he said that in his deposition, ma'am, would he not be
telling the truth, or do you just not remember?
Mr. Panish: well, first of all, improper use of a deposition.
Mr. Putnam: done it that way for 12 years, your honor.
Mr. Panish: why does Mr. Putnam keep responding to my objections like that, your
honor? That's not appropriate.
The judge: is he going to testify?
Mr. Putnam: uh-huh.

The judge: all right. Overruled.

Q. if he says that, ma'am, would that be not true, or do you just not remember?
A. I don't I really don't remember.
Q. You just don't remember?
A. No, I didn't.
Q. So you're not saying Michael didn't tell you; you just don't remember if he did?
A. I don't remember.
Q. Prior to your son Michael Jackson's passing, ma'am, were you aware that your son
Michael Jackson had gone to rehab before?
A. I had heard it. I had heard Elizabeth Taylor had said something about him going there,
but I never knew that he went there.
Q. So you heard from someone that Elizabeth Taylor had said that your son Michael
Jackson had gone to rehab, but that's not something you ever discussed with your son Michael
Jackson?
A. No.
Q. No? Did were you here when the statement that your son made in '93 that he was going
to rehab, were you here when that was played?
A. No, I didn't yes, I heard. Played in court here?
Q. Yes.
A. Yes.
Q. So you heard that in court?
A. Yes.
Q. Was that something you had ever heard before playing it in court?
A. No, I hadn't heard it.
Q. So that was the first time you had heard that?

A. Yes.
Q. So up until that moment, all you had ever heard before was that Elizabeth Taylor had
said something about your son going to rehab?
A. I had heard that Elizabeth Taylor had announced out there that Michael she said
something about drugs, but I don't watch television that much. At that time I didn't. And so and
nobody came to me and said anything about my children probably didn't want me to know
about it, or worry about it, and nobody else told me, so I didn't know.
Q. So that was you learned it in this courtroom; correct, ma'am?

Mr. Panish: other than just obviously, other than in conversations with her attorneys.
Q. except for conversations you may have had with your attorneys, this was the first time
you had ever heard that announcement that your son was going to rehab?
A. I learned it in the court.
Q. Okay. And you never had a discussion with any of your children about your son Michael
Jackson going to rehab?
A. No.
Q. And you never had a discussion with Michael Jackson ever?
A. No.
Q. Is that correct?
A. No.
Q. Now, when you said that you had heard that Elizabeth Taylor said something, did you not
go talk to your son Michael Jackson then about it?
A. No, I didn't.
Q. Did you have an understanding do you remember when the "dangerous" tour was
happening in '92/'93, ma'am?
A. I remember the "dangerous" tour, but I don't know the years or whatever.
Q. Okay. But you do remember the "dangerous" tour?

A. I remember what was going on.

Q. Do you remember that ending before it was supposed to end and that the rest of the dates
were canceled?
A. I didn't know anything about that, either.
Q. You never heard that before?
A. No.
Q. And
A. I'm not saying it wasn't true. I just didn't hear it.
Q. And, ma'am, I'm not asking if it's true; I'm asking what you know. So that's something
you never heard before?
A. No.
Q. Mrs. Jackson, on Friday you mentioned that you shut your ears to bad things. You
remember saying that? That was the term. You shut your ears. You remember saying that?
A. I probably said it, but I don't remember saying it.
Q. Does that sound like something you would say, ma'am? That you would shut your ears to
bad things?
A. I don't like to hear bad news.
Q. And the reason I'm asking you, ma'am, is because when you said that on Friday, when
you say that you didn't hear before hearing in court your son's statements or hear about various
interventions or whatnot, are you telling me that you don't recall ever hearing it, or are you
saying that that's something that you shut out from hearing and didn't explore it, ever? What do
you mean when you say you didn't know about the end of the "dangerous" tour, for example? Is
that something you just never heard before?
A. I didn't hear about the end of the "dangerous" tour.
Q. And did you see your son after the "dangerous" tour ended?
A. I probably went to visit him sometime after the "dangerous" tour, but I don't know when.
Michael traveled a lot, too.
Q. Well, was this at the time when he was still living at Hayvenhurst?

A. What year was it? I don't remember that.

The judge: well, let's stop here, and we'll
Lunch..
(The following proceedings were heard in open court, outside the presence of the jurors):
Mr. Panish: Your honor, we're trying to watch some video they just gave us, so -- to maybe
expedite having a sidebar. So if we could wait, that would be helpful.
Judge: Is it going to be long? Do I need to get off the --
Mr. Panish: I don't think it should take too long.
Mr. Putnam: It's something they already had, your honor.
Mr. Panish: That doesn't matter.
Mr. Putnam: It's on the exhibit list, your honor.
Mr. Panish: So?
Judge: Is this Dateline or Nightline?
Mr. Panish: No. A different one.
Mr. Putnam: This is Oprah Winfrey, your honor. I figured since we're doing it differently now,
I'll give everything well in advance, then.
Judge: Very good. That's thinking ahead.
Ms. Stebbins: Also, your honor, we have the order that you marked up. I've given it to
Plaintiffs' counsel, and we expect to get that back to you.
Mr. Panish: And then whenever we finish this witness, there's another witness. There's some
exhibits we'll need to talk to the court about, but we don't need to do that until this is done.

Judge: And I did get a deposition of Dr. Kazakhi that I need to --

Mr. Putnam: Thank you, your honor. Do you have any objection other than it's long?
Ms. Chang: Well, I think it's an improper use of impeachment for a lot of it, because she's
saying the exact same things that she says now. There are a couple of points, I think --
Judge: Well, she's a party.
Ms. Chang: But it's not sworn testimony, it's an Oprah interview where -- the case law, your
honor, is -- I did bring some case law -- is that we don't know what was left on the editing floor.
And there's very famous interviews where they cut it off right at a pertinent time period, and it is
very unfair and hard to impeach someone with something that is not sworn testimony. And so
therefore, the Oprah Winfrey show, I don't know. This was in 2010. I just listened to a part of it,
and I don't think it's sworn testimony contemplated by the C.C.P. When they talked about a
statement by a party.
Judge: Okay.
Ms. Chang: I think it still has to go through the steps and the hurdles --
Judge: Well, is it all about Mr. Jackson's death?
Mr. Putnam: Yes.
Ms. Chang: It's about -- I can show you the portion. It is about questions that Oprah Winfrey
asked Mrs. Jackson about whether she knew if her son was addicted to painkillers, and whether
she believed him.
Mr. Panish: Among other things. The interview, according to this transcript that we're given, is
28 pages; and they want to play about -- about a page.
Ms. Chang: Do you want to see it for the record?
Judge: Okay. So there's 28 pages of the interview. You want to play a page, is that it?
Mr. Putnam: Yes, your honor.
Ms. Stebbins: Yes, your honor. It's basically the same as the Phillips interview, your honor,
when they played a portion of it and, obviously, we played a larger portion. But I don't think --
for completeness purposes. But it's an interview by a party.

Judge: Is there anything that you wanted added?

Ms. Chang: I have to read the whole -- I honestly was not at -- I can state to the court, and Mr.
Putnam knows -- he keeps saying it was played at the deposition. I was not at the deposition. I've
never seen the Oprah Winfrey thing before, so I'm looking at this transcript for the very first
time. I highly doubt that the whole interview was played at the deposition. I could be wrong.
Mr. Putnam: Nor does it have to be played for me to play it now.
Ms. Chang: So for you to ask me if there's a counterpart, I don't know yet; but if you give me
five minutes, I can read it very quickly.
Judge: We can do that later. Didn't we do that with Randy Phillips?
Mr. Putnam: Yes. In fact, they wouldn't show us the whole thing, we had to go find it by doing
research and come back in and do it.
Mr. Panish: That's not true. Whatever.
Judge: Well, read it all; but I think we'll move forward with it.
Mr. Putnam: Thank you, your honor.
Ms. Chang: Can I just have a moment now?
Judge: Yes. Was this disclosed in discovery?
Mr. Putnam: Yes; and it's on our exhibit list, as well, your honor.
Mr. Panish: It wasn't disclosed in discovery, but they used part of it at her deposition. We're not
denying that. Of course, it doesn't say which part.
Ms. Chang: But there were like hundreds of thousands of things disclosed on their witness list.
Judge: It's her statement. Supposedly she knows about her interview.
Ms. Stebbins: And I believe the clip at the deposition is the same as the one we'll be playing.
Mr. Panish: Why don't we get going, we'll look at it while we're going.

Judge: The portion they wanted to play?

Mr. Putnam: We've actually played it for them.
Ms. Chang: You know what? To save time, what can we do?
Judge: Well, what you can do is if later you want to do something for completeness, you can.
Let's just --
Mr. Panish: That's fine. Let him go and then we'll do what we need to do.
Judge: All right.
Mr. Panish: Okay. We're ready.
(The following proceedings were held in open court, in the presence of the jurors):
Judge: Katherine Jackson versus AEG Live. You may continue with cross examination.
Mr. Putnam: Thank you, your honor.
Continued cross examination by Marvin Putnam:
Q. Hello, Mrs. Jackson.
A. Hello.
Q. We had been speaking before lunch -- is it on, ma'am?
A. Yes.
Q. We had been speaking before lunch about the attempted intervention in 2002 at Neverland.
Do you remember that, ma'am?
A. Yes.
Q. And do you remember that time period that a Dr. Farshchian came on to treat your son for his
addiction to Demerol?
A. No, I don't -- I don't know Dr. Farshchian.

Q. You've never heard of Dr. Farshchian before?

A. No.
Q. Can -- do you recall ever talking to Dr. Farshchian on the telephone?
A. No, I don't. Might have, but I don't remember. I'm not saying he didn't treat him.
Q. You just don't remember that?
A. I just don't remember it.
Q. Well, can you remember having a telephone conversation with any of your son Michael
Jackson's doctors in this time period, 2002, about your son's addiction to Demerol?
A. No.
Q. So you don't remember talking to any doctor about this before, correct?
A. No, I don't.
Mr. Putnam: Can I get Dr. Farshchian? Page 129. May I approach, your honor?
Judge: Okay, you may.
Mr. Putnam: Actually, what I want -- I'm sorry. It is the 129 one. Okay. We have two of them,
one for your honor --
Judge: That's okay, as long as each side has it.
Mr. Putnam: All right. Ms. Jackson, I printed out a portion. If you could look at this. It's just
this part right here.
Q. Okay, ma'am? Have you had some time to review it, ma'am?
A. Pardon?
Q. Have you had time to review it?
A. Yes. Just this page?

Q. Just that page, ma'am.

A. Yes.
Q. Does that refresh your recollection as to whether or not you spoke to a Dr. Farshchian about
his treatment of your son Michael Jackson for Demerol addiction?
A. No, it doesn't.
Q. It doesn't. Mrs. Jackson, if I were to represent to you that a Dr. Farshchian has testified in this
matter during deposition that he spoke to you about Michael's dependency on Demerol
specifically because you wanted the details of his treatment, would that be -- would I be telling a
falsehood, or do you simply not remember whether that occurred?
A. I don't remember -- remember a Dr. Parshchian (sic). I don't remember anybody treating
Michael for Demerol, so I can't answer your question. I don't remember that, and I don't think -- I
don't remember Dr. Parshchian (sic) speaking to me.
Q. And you see his name on there, Dr. Farshchian, with an f, right, ma'am?
A. Pardon?
Q. Dr. Farshchian is the name, f-a-r-s-c-h-i-a-n? Farshchian?
A. I don't see his name here.
Mr. Putnam: If you look on the first page, ma'am, it's spelled out, if that, maybe, helps you.
You see -- may I approach, your honor, to help?
Mr. Panish: What's --
The witness: I'm okay.
Q. Do you see that there in the middle, ma'am?
Mr. Panish: She doesn't need your help. She's got it.
Mr. Putnam: Okay.
The witness: Yes, I see it.

Q. Do you see that? Do you recognize that name at all, ma'am?

A. No.
Q. Do you remember hearing testimony here earlier from one of the doctors that were called in
your case, a Dr. Schnoll, about him reviewing medical testimony about your son getting an
implant to help with drug addiction --
A. No.
Q. -- into his abdomen?
A. I don't know anything about that.
Q. You don't remember hearing that testimony while you were sitting here, ma'am?
A. I was sitting here?
Mr. Putnam: Here, ma'am.
Ms. Chang: She may not have been here.
The witness: I missed some days. I must have missed that one.
Mr. Putnam: Okay.
Q. Do you remember a Dr. Farshchian ever talking to you about putting an implant in?
Mr. Panish: Excuse me, your honor. There's no foundation. She doesn't even know who he is or
talked to him.
The witness: No.
Judge: Sustained, sustained.
Mr. Panish: And asked and answered, and he keeps asking the same question.
Mr. Putnam: I was hoping the implant might remind her.
Q. Do you remember ever discussing an implant that your son had in 2002?

A. No.
Q. Put it this way. Do you remember in december of 2002 being at Neverland for Christmas
with your son Michael Jackson and Dr. Lou Farrakhan was coming? Do you remember that?
A. No, I don't. I don't celebrate Christmases, so I don't remember that, no.
Q. Okay. Well, have you ever met Louis Farrakhan
ever before?
A. Yes.
Q. From the Nation of Islam?
A. Yes, I have.
Q. And do you remember the first time you met him?
Was the first time you met him at Neverland with Mr. Jackson?
A. First time I met him was not at Neverland.
Q. It was not at Neverland?
A. I don't remember ever seeing him at Neverland.
Q. You don't recall that?
A. No.
Q. And do you not recall your son Michael Jackson at this time period showing you a narcan
implant?
A. No. I would remember something like that.
Q. That's what I wanted
To ask you.
A. I don't remember that.

Q. So -- but that's the kind of thing you think you'd remember, right, ma'am?
A. Yes.
Q. But you're saying that you don't recall that ever happening?
A. No.
Q. And you don't recall any doctor being present to show it to you with your son Michael
Jackson?
A. No.
Q. So going back to my -- my hypothetical that I did before, which is if there is a doctor who
testified that he was there on Christmas of 2002 and showed you a narcan implant on your son, if
he were to testify to that, would he not be telling the truth?
Mr. Panish: Your honor, again, asked and answered.
Mr. Putnam: I didn't ask about the implant, your honor; and she just said it's the kind of thing
that she would remember.
Mr. Panish: Your honor, when I object, counsel is not supposed to say -- go into a diatribe.
Judge: This is Farshchian?
Mr. Panish: Yes.
Judge: Sustained. You asked her about Farshchian, she said she's never talked to him, doesn't
remember.
Mr. Putnam: But my question is if he said that, are you saying that that would not be true,
about the implant?
A. I haven't seen it, so --
Mr. Panish: Improper question, so -- it's an improper question for her to assess somebody else's
credibility that she doesn't even know. We're not talking about --
Judge: Sustained.

Q. Mrs. Jackson, are you aware that there are a number of doctors who provided deposition
testimony in this case?
A. I've haven't seen --
Q. You've seen those?
A. No, no, no. I didn't say that. I know there's some doctors that have been called in, but -- I
know that.
Q. Are you also aware that there are a number of doctors who had their depositions taken in this
matter?
A. No.
Q. You weren't aware of that?
A. No.
Mr. Panish: Well, other than what she discussed with her attorneys.
Mr. Putnam: Ask you a follow-up question.
Q. Can you recall looking at any of the deposition testimony of any doctor in this case, ma'am?
A. No.
Q. Do you recall sitting down for an interview with -- with Oprah Winfrey?
A. Yes.
Q. And do you remember doing that sometime in the fall of 2010?
A. Yes.
Q. And that aired, I'll represent to you, on november 8, 2010. Does that sound right to you,
ma'am?
A. That's about right.
Q. So -- and that would be a little over a month after you filed your lawsuit against AEG Live,

correct?
A. Could have been.
Q. And have you ever had a chance to see -- did you ever see your interview on Oprah?
A. When it first aired.
Q. Where did you watch that, ma'am?
A. At my home in Hayvenhurst in Encino.
Q. So you watched it at both locations? I'm sorry. Maybe I misunderstood. Did you only watch it
at Hayvenhurst?
A. Yes.
Q. I did misunderstand. I'm sorry. And during that interview, Ms. Winfrey asked you a number
of questions, correct?
A. Yes.
Q. And you gave her a number of answers?
A. I answered whatever she asked me.
Q. And did you try to tell the truth in that interview, ma'am?
A. Did I try to tell the truth?
Q. Uh-huh.
A. Yes.
Q. Now, you indicated today, did you not, that you never believed that your son was addicted to
drugs?
A. I told Oprah that, yes.
Q. What did you tell Oprah, ma'am?

A. She asked me if I believed what he had said. I didn't say I never believed he was addicted to
drugs. She asked me did I believe him.
Q. When I asked you here today, ma'am, if you thought your son was ever addicted to drugs, this
morning, you told me no, didn't you, ma'am?
A. I may have. I don't -- I don't remember, but I might have. I don't remember that.
Q. Did I ask you this morning whether you ever believed that your son was abusing painkillers?
A. You didn't ask me like that, didn't stay that.
Q. I didn't, ma'am?
A. You did ask me if he was using painkillers; and I told you I knew he was on painkillers but I
didn't think he was abusing them.
Mr. Putnam: Let me show you that little clip of Oprah, if I may. Your honor, that would be
exhibit 12933.
(A video clip is played)
Q. Mrs. Jackson, just so I can understand, when you say that part of you wanted to believe him,
but you didn't believe him, what did you mean during the Oprah -- during the interview with Ms.
Oprah Winfrey?
A. Because I had been hearing it from a lot of people.
Q. So in point of fact, then, you didn't believe your son when he denied his addiction?
A. Well, I kind of believed him and I didn't believe him because I'd been hearing it from other
people, hearing it from my children that heard it from others, so I didn't know what to believe.
Q. And, Mrs. Jackson, there, you indicated that your son responded by saying, "It's not true. My
own mother, she doesn't believe me." is that what happened when you confronted him with this?
A. Yes.
Q. So he, in fact, denied having any kind of addiction problem; is that correct, ma'am?
A. He said, "It's not true, my own mother didn't believe me," so I imagine so.

Q. And did watching this remind you that that's what happened?
A. Yes, it is what happened.
Q. Yes, I understand, ma'am; but I've asked you about this this morning, so I'm asking is it from
watching this that you're now reminded of your son denying it and saying it wasn't true?
A. I think I answered the question.
Q. Did this refresh your recollection at all, ma'am?
A. About what?
Q. About what happened when you confronted your son and asked him if he was abusing
painkillers.
A. Yes.
Q. So as you sit here today, ma'am, do you think that your son had a problem that he was
abusing painkillers?
A. I don't know.
Q. But you thought he might be, correct, ma'am?
A. I didn't know what to believe and I thought he might be, yes.
Q. And because of that belief, that's why you went up to Neverland with your family, right,
ma'am?
A. I went up to Neverland because my children kept telling me, "mother, please come because it
will mean more if you would come."
Q. And that's also why you asked him about this in Las Vegas; is that correct, ma'am?
A. Pardon?
Q. Is that also why you asked your son about this, your son Michael Jackson, in Las Vegas?
A. Yes.

Q. Because you were concerned?

A. Yes.
Q. And did there ever come -- did there ever come a time when you weren't concerned that he
was -- that he might be abusing painkillers?
A. I can't say I weren't concerned.
Q. Okay. There has been -- were you here when Karen Faye testified, ma'am?
A. Yes.
Q. Do you remember her talking about an incident in -- during the criminal trial where Mr.
Jackson was getting painkillers from a doctor and he ended up going -- arriving at the court in
pajamas, she called it pajama day? Do you remember that?
A. Yes, I remember that day.
Q. Do you remember that day?
A. Yes.
Q. Did you ever have a concern -- and -- strike that. You had indicated this morning you were
there every day of the criminal trial, correct, ma'am?
A. Yes.
Q. Were you staying at Neverland at the time?
A. Yes.
Q. Was there ever a time during the criminal trial where you had a concern that your son might
be under the influence of any drugs?
A. No.
Q. Was there ever a time during the criminal trial where you saw -- where you saw him where he
looked like he might be out of it?

A. No.
Q. You talked about this concern you had that he might be abusing painkillers. Did you ever
discuss that concern, ma'am, with -- ma'am, with any of Michael Jackson's lawyers?
A. No.
Q. Did you ever discuss that concern with any of Mr. Jackson's managers?
A. No.
Q. And you spoke with his managers on occasion, did you not, ma'am?
Mr. Panish: Vague, ambiguous as to time.
The witness: No, I can't remember.
Mr. Putnam: Did you sometimes have conversations with your son's managers?
Mr. Panish: Vague and ambiguous as to time.
The witness: No.
Judge: Overruled.
Mr. Panish: She already answered.
Mr. Putnam: No?
A. No.
Q. So you can't remember ever having conversations with Frank Dileo?
A. That's been so many years ago. I talked to Frank Dileo even after Michael let him go many
times, and just friendly conversations.
Q. Do you remember having conversations with Mr. Frank Dileo as Michael's manager in 2009?
A. About what?

Q. About anything, ma'am. Do you remember him coming back in as your son's manager in
2009 before his passing?
A. Yes, I do.
Q. And do you remember having conversations with Mr. Dileo in that time after he came back as
a manager?
A. No. I just remember answering the phone and knowing when he came back; and when Frank
Dileo came back, I -- I wasn't that thrilled over it. He thought I should be happy because I know I
had been trying for years to talk to Michael to rehire him; but when Frank Dileo came back,
Michael had let him go, the first thing that jumped to my mind was they keep hiring all these
people that Michael had fired, and why are they hiring these people back? That's what bothered
me more than anything else.
Q. Did you have an understanding that someone other than your son hired -- hired Frank Dileo
back as his manager?
A. I would think so, because Michael never wanted him back.
Q.
Did you -- didn't Mr. Dileo call you and let you know that Michael had hired him back? Isn't
that what you're referring to, ma'am?
A. He didn't tell me Michael had hired him back, he just told me he was back.
Q. You'd indicated that you've been here many days. Did
You see the letter from your son that was shown into evidence that said that he was hiring Frank
Dileo back as his manager?
A. Michael had told me that he had hired Frank Dileo back; and he had told frank, and also
frank told me, come to think of it, that, "I'm back, but I'm only back for the tour, and after the
tour, I work no longer for Michael." Michael didn't want him because he was -- Michael had told
me once before he was taking monies and he was told by people that really knew what he was
doing.
Q. And so you do remember having a conversation, then, with Mr. Dileo after he had been hired
back as your son's manager, correct?
A. I remember that, yes.

Q. And did you ever have a conversation with Frank Dileo where you told him that you were
concerned that your son was abusing painkillers?
A. I don't remember that since he was back last, no.
Q. No? Do you remember having a conversation with anybody on your son's management team
about your concern that your son was abusing painkillers?
A. No.
Q. Do you remember having that conversation with anyone other than your son Michael Jackson
and your children?
A. No, I don't.
Q. Did you ever tell AEG Live that you were concerned that your son had a drug problem?
A. No.
Q. Did you ever tell that to Randy Phillips?
A. No. I don't remember telling him that. I never talked to him that much.
Q. All right. So do you remember ever saying that to somebody named Paul Gongaware?
A. No.
Q. Did you ever tell any of these people that you had tried an intervention with your son
previously but it hadn't worked?
A. No.
Q. Do you have any understanding as to whether anybody on your son's management team ever
knew that you had tried an intervention?
A. I don't know what they knew.
Q. But you never told them; is that right, ma'am?
A. I don't think so, no.

Q. Ms. Jackson, you've been -- you testified both on friday and this morning that you were
financially dependent on your son Michael Jackson, correct?
A. Yes.
Q. You were also receiving monies from your daughter Janet Jackson, correct?
A. Yes.
Q. And, in fact, your daughter Janet Jackson was giving you monies every month on a monthly
basis for years, correct?
A. Yes.
Q. And she was doing that for at least five or six years up until the time of your son Michael
Jackson's passing, correct?
A. I don't know how many years.
Q. Is it more than five years, ma'am?
A. I don't know how many years. I don't.
Q. You have no idea?
A. I really have no idea. It was something she wanted to do.
Q. And this was on a monthly basis, correct?
A. Yes.
Q. And that was $10,000 --
A. Not at first.
Q. Excuse me?
A. Not at first monthly basis.
Q. Not at first?

A. It became --
Q. It became a monthly basis?
A. She did start sending it monthly.
Q. And was that $10,000 a month?
A. Yes.
Q. And if I were to represent to you that you indicated you thought it was five or six years at
your deposition, does that sound right to you, ma'am?
A. I told you I don't remember.
Q. You just don't remember?
A. No, I don't.
Q. Is it true that you were receiving this $10,000 a month on a monthly basis from your daughter
Janet Jackson at the time of your son Michael Jackson's passing?
A. As I answered you before, yes.
Q. And how -- did you also receive that money in cash?
A. No.
Q. How did you receive that money, ma'am?
A. I don't know if it was in -- it could have been in checks to me.
Q. Did you receive it yourself, or did it go directly --
A. It went to janice. It went to the office. It might have gone to --
Q. So this was going directly to janice, your assistant in your office at Hayvenhurst, on a
monthly basis?
A. I believe so.

Q. And at the time of your son's passing, did you stop getting that money?
A. No. I told her maybe -- I don't know how many months afterward.
Q. What did you tell her, ma'am?
A. That she didn't have to give me money; and she wanted to continue, but I told her no.
Q. So your daughter Janet Jackson had been giving you that money on a monthly basis, but you
told her to stop --
A. Yes.
Q. -- isn't that right? I have no further questions at this time, your honor.
Judge: Okay. Redirect?
Redirect examination by Brian Panish:
Q. Ms. Jackson, who is paying for all the house expenses for Hayvenhurst?
A. It's coming in from -- they call themselves the estate, but the estate really is the children and
myself and --
Q. No. I mean before Michael died, was he paying for everything?
A. Yes, he was.
Q. All your food, everything like that?
A. Paying everything.
Q. Were you relying on him for the necessities of life?
A. Yes, he was paying for it, so --

Q. Now, Ms. Jackson, Mr. Putnam was asking you whether you were upset with him today as
much as you were in your deposition. Do you remember that?
A. Yes.
Q. And during the deposition, Mr. Putnam, did he ask you a lot of questions that asked for a lot
of personal information that you didn't think had anything to do with this case?
A. Yes. He knows he even asked me, "Did your husband beat you?"
Q. All right. Well, you don't have to get into what he asked you. But he asked you a lot of
questions?
A. Yes.
Q. That you didn't think -- and about the Nation of Islam, for example?
A. Yes.
Q. He asked questions like today, he wanted to inject the Nation of Islam. Does that have
anything to do with your son's death, the Nation of Islam?
A. No.
Mr. Putnam: Objection; move to strike the question in its form, your honor, "He tried to inject."
Judge: It's a little argumentative. Sustained.
Mr. Panish: Okay.
Q. Well, when Mr. Putnam interjected in his question Dr. Farrakhan and the Nation of Islam, and
when he asked you in your deposition if brother Michael was a member of the Nation of Islam,
did that have anything to do in your mind with your son's death?
A. Not at all.
Mr. Putnam: Same objection, your honor.
Judge: Sustained as to the form. Did it upset her, maybe, is the appropriate question.

Mr. Panish: Did it upset you that he would want to attack the Nation of Islam?
A. Yes.
Mr. Putnam: Objection, your honor.
Judge: Overruled.
Ms. Stebbins: No one has attacked the Nation of Islam, your honor.
Judge: No. The point is was she upset and that's why her demeanor was the way it was.
Mr. Panish: Mr. Putnam asked you a lot of questions. I want to just ask you a few. Let's start
with he asked you a lot about the search for the truth.
The witness: The --
Q. Ms. Jackson, are you -- you can't hear me?
A. He asked a lot about what?
Q. The search for the truth.
A. Oh, yes.
Q. Ms. Jackson, are you a lawyer?
A. No.
Q. Ms. Jackson, are you a private investigator?
A. No.
Q. Do you own a computer, Mrs. Jackson?
A. No.
Q. Have you ever sent email?
A. I don't know how. I'm computer illiterate. I don't know anything about a computer.

Q. And what is the highest level of your education, Mrs. Jackson?

A. I finished high school.
Q. Now, Ms. Jackson, did you hire someone to go on your behalf to try to find out information?
A. Yes, I did.
Q. Who did you hire?
A. I hired your firm.
Q. Why?
A. Because I wanted to find out what really happened to my son.
Q. And did you learn, for example, about Mr. Phillips telling the t.V. And many other people that
AEG Hired Dr. Murray?
A. Yes, I have heard.
Mr. Putnam: Objection; no foundation for "many other people," your honor.
Judge: As to "many other people," sustained. But Randy Phillips, yes, we saw the video.
Mr. Panish: And let's look at --
Judge: So let's re-ask the question.
Mr. Panish: Okay. Well, let's look at this video. Exhibit 378, sky t.V.
Q. Did you know about that before you hired any lawyers?
A. Yes, I did.
Q. Did you see it during this trial?
A. Yes.
Q. Okay. We don't have to show it. Everyone has seen it enough. And I want to show you Mr.
Phillips' testimony in trial, page 6288, lines 8 through 12, where Mr. Phillips told other -- where

he admitted that he told other news outlets that AEG Live hired Dr. Murray at Michael Jackson's
behest. Can we put that up, please. Do you remember him saying this, Mr. Phillips, here at the
trial? This is Mr. Phillips' testimony.
A. Yes.
Q. Do you remember hearing that?
A. Yes.
Q. And, Ms. Jackson, did you have the ability to -- could you serve subpoenas to get
information? Do you know how to do that?
A. No.
Q. Do you know what discovery is in a lawsuit?
A. No.
Q. Did you, in your search -- did you read 10,000 pages of depositions in this case?
A. No.
Q. Did you, Ms. Jackson, go to AEG And ask them for all their emails about Dr. Murray?
A. No.
Q. Have you seen some in this case that you never would have seen but for this lawsuit?
A. Yes.
Q. Did AEG -- by the way, we heard from Mr. Ortega that Mr. Gongaware and Mr. Phillips
loved Michael Jackson. Did you hear that?
A. Yes, I did.
Q. When your son passed away, did Mr. Phillips ever call you?
A. None of them ever called me.
Q. Did he ever send a card?

A. No.
Q. Did Mr. Gongaware ever call you and just express their condolences for your loss of your
son?
A. No.
Q. Did they send you a card?
A. No.
Q. Did Mr. Ortega ever call or come see you?
A. Mr. Ortega did come to see me.
Q. Now, Ms. Jackson, Mr.
Putnam asked you if you knew a lot about hearsay. Do you remember that question he asked?
A. Yes.
Q. Said, "Do you know about hearsay, ma'am?" Do you remember that?
A. Yes.
Q. Do you know about the hearsay rule? Do you know what hearsay is, other than sitting here?
A. I heard it from other people. I know what it is.
Q. Well -- okay.
A. It's like a rumor, I imagine. I don't know.
Q. All right. And, Ms. Jackson,
Was the purpose of hiring myself and lawyers to let the lawyers do their job and find out this
information from AEG?
A. I didn't hear.
Q. I'll ask it this way. Do you know what a discovery request is?

Mr. Putnam: Objection; asked and answered.

Judge: Sustained.
Mr. Panish: Okay.
Q. Have you ever taken a deposition, Mrs. Jackson?
A. Yes.
Q. No. I mean have you ever questioned someone like Mr. Putnam in a deposition.
A. Have I ever questioned him? Yes. I don't understand what you mean.
Q. Okay. You see Mr. Putnam. Remember when he took your deposition?
A. Yes.
Q. Who asked the questions?
A. He did.
Q. Okay. Did you get to ask him questions?
A. No.
Q. Did you get to ask Mr. Gongaware questions?
A. No.
Q. Did you get to ask Mr. Phillips questions?
A. No.
Q. Who does that?
A. The -- the person --
Q. Did you ever go to law school?

A. No.
Q. Do you know how long you have to go to law school to become an attorney?
A. No, I don't; but I imagine it's many years.
Q. Did you ever go to college?
A. No.
Q. Mrs. Jackson, you said that the search for the truth -- did you know that your son was sleep-
deprived for 60 days?
A. No, I didn't.
Mr. Putnam: Objection; lacks foundation, your honor.
Judge: Overruled.
The witness: I didn't know that.
Judge: Well, did you know that there was testimony here?
Mr. Panish: Well, no one is going to be -- that's correct.
Q. Did you know that Mr. Hougdahl, before you hired lawyers to search for the truth, had
written an email to AEG Executives saying that he's been watching Michael deteriorate for eight
weeks before his own eyes? Did you know that, before this case was filed?
A. No.
Q. Did you know that AEG Executives were writing emails back and forth regarding Michael
being paranoid?
A. No.
Q. Did you know that people were writing emails about Michael losing weight?
A. I didn't know that before.
Q. Did you know that Mr. Ortega was writing emails concerned about Michael's health and

physical condition?
A. I learned it here in court.
Q. Did you know before this lawsuit and hired lawyers that Mr. Phillips had described Michael's
condition as either physiological or chemical? Did you know that before you hired lawyers to
search for the truth?
A. No.
Q. Did AEG Ever tell you any of that information; that they knew that your son was
deteriorating in front of their eyes before he passed away?
A. Not until this court.
Q. Did AEG Ever tell you that Mr. Hougdahl watched Mr. Jackson, your son, deteriorate in front
of his eyes for eight weeks before he passed away?
Mr. Putnam: Objection; asked and answered, your honor.
Judge: Sustained, asked and answered.
Mr. Panish: No, I didn't ask if AEG Told them.
Judge: Sustained.
Q. Did AEG Ever contact you and tell you anything about your son deteriorating, paranoia,
rambling, speaking to god, losing weight, any of that information before this lawsuit was filed?
A. They could have called me. He was asking for his father. Because my grandson told me that,
"daddy was nervous and he was scared and he was asking for joseph."
Q. Did -- did AEG Ever tell you that Mr. Trell's boss and Mr. Trell e-mailed back and forth and
called your son a freak before this lawsuit was filed?
A. No.
Q. Did AEG Ever tell you that Mr. Trell said it was creepy -- creepy to think of meeting with
your son?
A. No.

Q. Your son -- your -- I want to show you exhibit --

A. Why did they sit there and let him -- without calling somebody? My husband and I would
have been there in a second.
Mr. Panish: Ms. Jackson --
Mr. Putnam: Move to strike as nonresponsive, your honor.
The witness: They watched him waste away, from what I can hear. I know they did.
Mr. Panish: If you saw your son in those conditions described here, what would you have
done for him?
Ms. Stebbins: Your honor, objection, move -- this is getting into m.I.L. Territory in terms of the
should have done and the --
Judge: Well, what she would have done. Sustained. It's obvious what she would have done, Mr.
Panish.
Mr. Panish: But they raised this whole search for the truth, Mr. Putnam here in his questions.
Judge: Sustained.
Q. Now, Ms. -- did -- Ms. Jackson, if you -- strike the question. Ms. Jackson, your son -- your
grandson prince Jackson -- Mr. Putnam asked you did you hear the testimony, how he was
paying Dr. Murray. Do you remember those questions?
A. Yes, I read that.
Q. Okay. And do you remember him testifying about that he felt that his dad told him to give
him some money? Do you remember that?
A. Yes.
Q. Because AEG Wasn't paying him?
A. Yes.
Q. And that he had no money?

Mr. Putnam: Objection; misstates prior testimony.

The witness: Yes.
Ms. Stebbins: That was actually stricken, your honor.
Judge: Sustained. The answer is stricken, and the question is stricken.
Mr. Panish: Well, Ms. Jackson, I want to show you exhibit 8, dash, 59. This was a photograph
taken on june 19th. 8, dash, 54. I apologize.
Q. Okay, Ms. Jackson? You've seen this photograph in the trial here today?
A. (witness moves head up and down)
Q. Have you ever seen your son look like that before, ma'am?
A. Never.
Q. Okay. Ms. Jackson, did you have that photograph before this lawsuit and search for the truth?
A. No.
Q. Now, counsel asked you whether you assisted the district attorney. Have you tried a lot of
criminal cases representing the people and the state of california, Mrs. Jackson?
A. I didn't understand.
Q. Well, counsel asked if you assisted and helped the district attorney prosecute their case. Do
you remember these questions?
A. Yes.
Q. Have you ever been a lawyer in a criminal case, Mrs. Jackson?
A. No.
Mr. Putnam: Objection; asked and answered, your honor.

Judge: Overruled.
Q. Do you know how to try a criminal case, Mrs. Jackson?
A. No.
Q. On the issue of the restitution, that was the state's decision to -- to have something for
restitution, which you told them not to do, correct?
A. Right.
Q. That figure was set by the state of california, was it not? Or --
Mr. Putnam: Objection; lacks foundation, your honor.
Judge: Sustained.
Mr. Panish: Let me re-ask the question.
Q. Did you set the figure for restitution, Mrs. Jackson?
A. No.
Mr. Panish: I don't have any further questions.
Judge: Recross?
Mr. Putnam: Just one, your honor.
Judge: Go ahead.
Mr. Putnam: Can we show the Dateline clip now, sir?
Mr. Panish: Sure, absolutely.
(a video clip is played)

Recross examination by Marvin Putnam:

Q. And this was in june 2010, correct, Mrs. Jackson? Do you recall this Dateline interview was
in june 2010?
A. Yes.
Q. That was a year after your son's passing?
A. Yes.
Q. And in that year, your grandchildren had been living with you, correct?
A. Can you speak louder?
Q. I'm sorry, ma'am. In that time period, your grandchildren had been living with you, had they
not?
A. Yes.
Q. So they'd lived with you about a year at that point, ma'am?
A. Yes.
Q. And do you remember Mr. Panish was just asking you questions about the search for truth in
terms of getting subpoenas and the like? Do you remember those questions just a moment ago?
A. Yes.
Q. But when I asked you those questions, I was asking you questions about conversations you
could have with your grandchildren, paris, prince and blanket, correct?
A. Yes.
Q. And you said that you didn't have any conversations with them at the time to find out what
had actually happened in terms of Dr. Conrad Murray and his treatment of your son Michael
Jackson, correct?
A. I didn't.
Q. Okay. So you -- and you don't need a subpoena to talk to your grandchildren, correct, ma'am?

A. Pardon?
Q. You could talk to your grandchildren every day in your house, couldn't you, ma'am?
A. I could, but I didn't want to bring that up to them. They were young.
Q. Okay.
A. They --
Q. Sorry?
A. Go on.
Q. What about Kai Chase? Kai Chase is your chef, correct?
A. Now, yes.
Q. And Kai Chase had been your chef for Michael Jackson?
A. For about a month or two.
Q. Did you ever have any conversations with her where you asked what happened in the house,
Carolwood?
A. We don't bring that up. She didn't bring it up to me.
Q. And do you know who Sister Rose is?
A. Yes.
Q. Who is Sister Rose, ma'am?
A. One of the children's nanny.
Q. And she's someone who continued to be the children's nanny, correct?
A. Yes.

Q. And she was in the house at Carolwood during this time when Dr. Conrad Murray was there?
A. Yes.
Q. Did you have any conversations with her?
A. Yes.
Q. And what were those conversations, ma'am? What did she tell you?
A. She told me that Michael was very weak, and she told me that she had to help him up -- she
was talking to me about he went down to practice and you had to hold him up.
Q. And was this a conversation you had with her prior to bringing your lawsuit?
A. I -- I don't remember.
Q. You don't remember?
A. No.
Q. Did you have any conversations with Sister Rose about whether Dr. Conrad Murray was
coming to the Carolwood
house six times a week?
A. No, I didn't ask her all of that. She was just talking about what happened to Michael and how
weak he was and how they wanted him to rehearse and he wasn't able to.
Q. So you did talk to her about that, but you didn't ask her anything about Dr. Conrad Murray?
A. No, I didn't.
Q. And just a little moment ago, because I want to make sure I understand -- Sister Rose, do you
have an understanding as to why Sister Rose is called Sister Rose as opposed to just rose? Why
is she called Sister Rose, ma'am?
A. No, I don't.
Q. And what about brother Michael amir?
Do you have an understanding as to why he's called brother?

A. In our religion, we call each other brother and sister. I imagine it could be that.
Q. Okay. And talking about religion, ma'am, there was an implication that I had brought up
Nation of Islam for some improper means. You testified as to your religion at length on friday,
didn't you, ma'am?
A. Pardon?
Q. You testified about your religion at length on friday, didn't you?
A. I did testify, talked about why we don't celebrate holidays. Only one holiday we celebrate.
Q. And did I say anything to you to leave you with the impression that I have any issue with the
Nation of Islam?
A. No; but you were asking me questions about it in my deposition.
Q. And -- and in those questions, ma'am, was I asking you about Mr. Jackson's security
personnel? Do you remember that I was asking about the security for your son that he had?
A. I don't know if you mentioned security or not.
Q. All right, ma'am. You indicated that Mr. Phillips and Mr. Gongaware had never apologized to
you. Prior to your son's passing --
Judge: She didn't say "apologize."
Mr. Panish: I didn't say "apology."
Judge: Condolence.
Mr. Putnam: Thank you. Did they send any kind of condolences to you at the time of your son's
passing.
Q. Do you remember that, ma'am?
A. Yes, I do.
Q. Had you ever met Paul Gongaware?

A. No, I hadn't ever met him.

Q. Had you ever had a conversation with him?
A. No; but that shouldn't have stopped him from saying, "I'm sorry what happened to your son."
Q. Were you involved in the memorial service that was held for your son at the staples center?
A. No, I wasn't involved in it, but I had -- had several calls from them.
Q. And in those several calls, did you have an understanding that they were helping to put on
this memorial service, this tribute to your son?
A. No, I didn't understand that at first. They called for the use of their -- of the staples center or
the -- I forget the name of it. The forum.
Q. The forum? They talked to you about whether or not they could hold a memorial there for
your son?
A. Yeah, they did. Because I was thinking about going to the coliseum because it was larger and
held more people.
Q. But ultimately that was held at the staples center, correct, ma'am?
A. Pardon?
Q. Ultimately that was held at the staples center?
A. Yes. They told me if I held it there, I wouldn't have to pay for it.
Q. Is that because they paid for it?
A. I don't know. But I had heard that they wanted us to pay for it after they -- it was just hearsay,
so I don't know.
Q. And who did you hear that from, ma'am?
A. Just hearsay, I said.
Q. Did anybody ever ask you to pay for that memorial service, ma'am?

A. Not me.
Q. Okay. Are you aware of anybody asking for the family to pay for that memorial service,
ma'am?
A. I have to find out. It could have been paid for by the estate. They might have paid it and they
might not have. I don't know.
Q. Do you have an understanding as to whether anybody paid for that memorial service, ma'am?
A. I don't know.
Mr. Putnam: I have no further questions.
Further redirect examination by Brian Panish:
Q. They still didn't send any cards, did they?
A. Pardon?
Q. They still didn't send a card, did they?
A. No, they didn't.
Q. Did people that you didn't know send cards to you?
A. Thousands and thousands.
Q. Did you just expect people that -- strike that. Forget that question. Let me ask you this. Are
you -- what religion are you in?
A. I'm a Jehovah's Witness.
Q. Is that part of the Nation of Islam?

A. No.
Q. Is there a difference?
A. Yes, there is.
Q. Now, first of all, this thing about who hired Dr. Murray that was played, you never talked to
your son or Dr. Murray about that, did you?
A. No. I just assumed when I was speaking -- I didn't know, I just assumed that.
Q. And that's part of what you hired lawyers to find out, right?
A. Yes.
Q. Okay. So let's look at exhibit 378, which the lawyers obtained. You can play that first. And,
by the way, that interview you gave was before your attorneys had even been hired, wasn't it?
A. Yes.
Mr. Panish: Start looking for the evidence. And let's see some of the evidence that we found.
First let's see the CEO of AEG, what he says.
(A video clip of Phillips saying "We hired him [Murray]" is played)
Mr. Panish: Okay.
Q. Did you -- did you have that information before you had your t.V. Interview?
A. No.
Q. Okay. Let's look at page 6288 of Mr. Phillips' trial testimony. And this would be lines 8
through 11. And this is -- Mr. Phillips says "and you told other --" me asking him, "and you told
other news outlets that AEG Live hired Dr. Murray at Michael Jackson's behest, correct?"
answer, "correct."
Mr. Putnam: Objection; asked and answered a minute ago, your honor.
Mr. Panish: I'm responding to what he just played.

Judge: Overruled.
Mr. Panish: And, Ms. Jackson --
Judge: Wait a minute. What was her answer?
Mr. Panish: She didn't answer.
Q. My question is to this testimony of his client, Mr. Putnam's client, you didn't have that
information until you hired lawyers, did you, Mrs. Jackson?
A. No.
Q. Counsel asked you about your discussions with Sister Rose. Do you remember those
questions he just asked?
A. Yes.
Q. Did Sister Rose discuss with you AEG pressuring Michael Jackson?
A. Yes.
Mr. Putnam: Objection; calls for hearsay, your honor.
Mr. Panish: He just asked the same --
Mr. Putnam: I didn't ask the question, she volunteered it, your honor.
Mr. Panish: No. He just asked what Sister Rose discussed with Mrs. Jackson. Counsel just
asked that.
Mr. Putnam: I asked about Dr. Murray, your honor.
Mr. Panish: No. It doesn't matter.
Judge: What was the question?
Mr. Panish: The question was, counsel asked did you discuss, before filing the lawsuit -- did
you need a subpoena to talk to the children or Sister Rose.

Judge: Or Kai Chase.

Mr. Panish: Or Kai Chase. And we're going to get to that one next.
Q. And Sister Rose, when you spoke to Sister Rose, did she tell you about what AEG Had been
doing to your son?
Mr. Putnam: Again, calls for hearsay, your honor.
The witness: Yes.
Judge: Overruled. Just yes or no.
Mr. Panish: And what did she tell you?
Mr. Putnam: Same objection, your honor.
Judge: Isn't that hearsay?
Mr. Panish: It's as to what he just asked.
Mr. Putnam: I asked if she had a conversation, your honor, and whether it required a subpoena.
Judge: Sustained.
Q. Kai Chase, she wasn't working for you after Michael died, was she?
A. No.
the way, there was a suggestion in this case that you hired Kai Chase back because she was
going to be a witness in this case. Did you hear that? Were you here that day?
Ms. Stebbins: Objection; argumentative.
Judge: Overruled.
A. Kai Chase hasn't been working for me I don't think quite a year. It might be a year if it's a
year.
Mr. Panish: Okay.

Q. But did you hire Kai Chase so she would testify in your favor in this case?
A. No.
Q. Like they've suggested?
A. No, not at all. The children knew her, and they wanted her. That's why.
Mr. Panish: Nothing further.
Mr. Putnam: One question, your honor.
Further recross examination by Marvin Putnam:
Q. Just to lay the foundation, you saw the clip of Mr. Phillips given one week, on sky news, after
your son's passing. You saw that clip, right, ma'am? The one that was just shown of Randy
Phillips?
A. Yes.
Q. And in there, he says, "so we hired him." you saw that, right?
A. Yes.
Q. And then a year later, you saw the clip of you on Dateline saying your son hired him, correct?
A. Like I said, I didn't know who hired him at that time --
Q. I understand that.
A. -- and I just assumed Michael might have hired him.
Q. One of you from those two interviews -- one of you is not correct, right, ma'am?

A. I'm not correct because I -- I said I assumed. It's not what I knew and I heard here since this
court.
Q. So you're saying that between the two, yours wasn't correct, but Randy Phillips' was? Is that
what you're saying, ma'am?
A. If that's what he said, they said they were paying him.
Q. But you said it, as well, didn't you, ma'am?
A. I said -- I didn't say they were paying him, I said they hired -- a doctor was hired. I didn't say
who hired him, or they hired a doctor or he hired a doctor. I don't remember. But I did say hire.
Q. You said he hired a doctor to look over him. That's what you said, ma'am?
A. Maybe I did.
Q. So one of you is not right in that interview, correct? Either you're not right or Randy Phillips
isn't right, correct?
A. You tell me who's not right.
Q. Didn't you just tell us who wasn't right? You said that you didn't know; is that correct,
ma'am?
A. Yes, I did.
Mr. Putnam: Thank you. Further redirect examination by
Mr. Panish:
Q. And, Ms. Jackson, Mr. Phillips testified on this witness stand under oath that he hired Mr. --
Dr.
Murray?
A. I didn't say just now I didn't know who was right, I just said I didn't know that Michael didn't
hire him, hired him.
Q. You weren't involved in any of that, were you?

A. No, I wasn't.
Q. Okay. But would you expect the CEO of AEG Who is negotiating a contract with Dr. Murray
to know whether or not they hired Dr. Murray?
A. Repeat that.
Q. Who do you think is in a better position to know whether Dr. Murray was hired by AEG, you
or the CEO of AEG?
A. The CEO of AEG
Mr. Panish: Nothing further.
Judge: Okay. Thank you, ma'am. You may step down. Hold on, let's make sure we have
somebody to assist you down.
Mr. Panish: I will. And we're going to have to discuss some other issues. I don't know if we
need to do it now.
Judge: Is it the next witness?
Mr. Panish: Yes. I don't know if this is an early break.
Judge: Don't we have a depo to play?
Ms. Stebbins: No, your honor.
Mr. Putnam: We have a witness ready to go. Your honor, this is, obviously, subject to recall
because we have some outstanding portions --
Judge: Well, she's going to attend the rest of the trial?
Mr. Boyle: Not today. She's going to go home and rest for today.
Judge: Okay. Is this something we can do at sidebar, or is this something thajohn meglent I have
to send the jury out?
Mr. Boyle: Depending on the direct exam, they might not get to it right off the bat. But Ms.
Stebbins and I discussed what it was.

Ms. Stebbins: I think it could be handled at sidebar quickly.

Mr. Boyle: If the court was suggesting we do it at sidebar now, that's fine.
Judge: Do we need to do it now?
Mr. Boyle: That's up to them. She knows what our issue is. I don't know when they're getting to
that portion in the direct exam.
Ms. Stebbins: I probably won't get to it in the first 20 minutes, your honor.
Judge: Then let's start. Call your next witness.
Mr. Putnam: Our first witness.
Mr. Panish: No. You've already called witnesses, actually.