JACKSON v AEG LIVE August 9

th
2013 VIDEO>> http://youtu.be/Hsw2p0i8M8Y
Steven Randal Jackson by way of Video deposition
the following proceedings were held in open court, in the presence of the jurors:
Judge. Good afternoon, everybody. We're going to play some deposition testimony?
Ms. Bina. Yes, your honor.
Judge. Why don't you introduce your deposition.

Ms. Bina. Defendants call Randy Jackson by video deposition.

(excerpts of the videotaped deposition of Randy Jackson were played.)
(Note from TeamMichael:-Notice how the pages skip through missing out numerous part of
the deposition)
Jackson v AEG Trial
Jackson, Randy (Steven)
Q. Can you please state your full name for the record.
A. Randy Jackson.
PAGE 10:03 TO 10:06 (RUNNING 00:00:05.959)
Q. And you understand that this is A deposition that's part of your mother's litigation against
AEG; correct?
A. Yes.
3. PAGE 57:23 TO 58:07 (RUNNING 00:00:17.605)
Q. And do you know who Grace Rwaramba is?
A. Yes.
Q. And --
A. Fired her, too.
Q. Okay. And why did you fire Grace?
A. Because he asked me to.
Q. Your brother Michael did?
A. Yes.
Q. Did he say why?
A. No.

PAGE 75:04 TO 75:14 (RUNNING 00:00:28.863)

Q. How would you describe your relationship with Michael?
A. Well, pretty close. Closest in age, so we -- pretty close, grew up.
Q. Would you say that --
A. Close.
Q. Amongst the siblings, would you say any one of you was closer to Michael than any other?
A. Maybe because we were closer in age. We were the last at home, so he and I, we roomed
together on tour, so --
PAGE 76:01 TO 76:11 (RUNNING 00:00:27.120)
Q. When was the last time you spoke to your brother before he passed?
A. I don't remember. He was traveling, Middle East and --
Q. Had it been years?
A. No. No.
Q. Did you talk to him in 2009?
A. I could have. I don't recall.
Q. You don't recall. Did you see him in 2009?
A. I don't remember.
PAGE 81:01 TO 81:15 (RUNNING 00:00:38.670)
Q. Do you know who Frank DiLeo is?
A. Yes.
Q. Who's Frank DiLeo?
A. That's Michael's manager.
Q. And if you know, when was he Michael's manager?
A. From what I understand, he was Michael's manager during -- up until my brother passed.

Q. And was there a period of time when he was not Michael's manager and then was his
manager again?
A. Yes.
Q. All right. So had he previously been Michael's manager before he passed?
A. Yes.
PAGE 84:04 TO 87:03 (RUNNING 00:03:41.228)
Q. Mr. Jackson, the question was, did was there ever a time where someone told you that your
brother didn't want to see you but you demanded to see him any way and then went into his
house?
A. Yes.
Q. Did that happen on more than one occasion?
A. Yes.
Q. Did it happen -- how many times did it happen that you can recall?
A. Three or four times.
Q. Could you tell me about each of them, please?
A. Well, I don't remember each one in detail but --
Q. Anything.
A. Just wanted to make sure he was okay and get him help.
Q. So for those three or four times, where was he living at the time?
A. One of the times, Vegas, L.A., New York.
Q. You can remember those three times?
A. Yes.
Q. Okay. And you said that you wanted to make sure he was okay.
A. Yes.

Q. If -- in what order did these occur, chronologically? Was Vegas first, then L.A., then New
York?
A. That's what I don't remember.
Q. Don't remember. Okay. Let's take Vegas, then, first. Why would -- why did -- were you
concerned that your brother might not be okay?
A. Because I had received a call that he had been abusing prescription drugs.
Q. And who did you get that call from?
A. Grace.
Q. Are you aware whether she called anyone else?
A. Not sure.

Q. And this -- do you remember when this happened, what year?
A. Not sure.
Q. Was it after the trial that you were speaking of earlier?
A. I know it was around that time. I don't know if it was before or after. I'm not sure.
Q. And was your brother staying at his house at the time in Vegas?
A. Yes.
Q. And when you went to see him that time, did you go by yourself?
A. No.
Q. Who did you go with?
A. With Jackie, Rebbie, I think Janet or Mar- -- I think Marlon. I'm not sure. I'm not sure.
Q. And for the people who went with you --
A. Yes.
Q. -- did you tell them that you had had this call with Grace?
A. Yes.

Q. Had they spoken to Grace about this as well?

A. Yes.
Q. Did they speak with Grace after you told them?
A. I think we may have had a -- I'm not sure. We may have had a conference call after or
whatever.
Q. After you first spoke to --
A. Yes.
Q. Make sure I have that. After you first spoke to Grace, then there was a conference call?
A. Uh-huh.
PAGE 87:08 TO 90:05 (RUNNING 00:02:51.893)
Q. Was anybody else on that conference call besides the people you just noted?
A. No.

Q. And were the people you just noted on that conference call?
A. Yes.
Q. Thank you. Now, at the time that Grace told you this, had you ever previously believed that
your brother might be misusing prescription drugs?
A. Yes.
Q. When was that?
A. She called me before.
Q. Okay. So this was not the first time she had called you about this?
A. Correct.
Q. How many times had she called you about this before?
A. Two or three times before.
Q. And had you -- did you ever confront your brother about what Grace told you?

A. Yes.
Q. Did you confront your brother every time that Grace told you?
A. Yes.
Q. Okay. Let's finish Vegas first and then go to the others. So Grace told you. You had a
conference call with several of your siblings, and then several of them went with you to Vegas?
A. Yes.
Q. And if I understand correctly, you were told that Michael didn't want to see you?
A. Yes.
Q. And who told you that?
A. Security.
Q. And did you attempt to see your brother anyway?
A. I just -- yes.
Q. And what did you do?
A. Just drove in and walked in the house.
Q. Did they let you come into the house?
A. The gate was open. We just drove in and walked in.
Q. So you didn't go through the gate or anything as dramatic as that?
A. No.
Q. Okay. And was the house open?
A. Yes.
Q. And did you see your brother?
A. Yes.
Q. And what did you say to him?
A. I told him I was taking him to rehab.

Q. And what did he say?

A. He said he's not going.
Q. All right. And what else -- and then what happened?
A. I told him, "Yes, you are." And he said, "No, I'm not."
Q. And did he eventually go to rehab?
A. No.
Q. No. Did any of your siblings say anything to him at this time as well?
A. Yes.
Q. What did they say?
A. The same thing.
Q. And was his response the same to all of them?
A. Yes.
Q. And did he say -- did he admit to having A problem?
A. No.
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Q. No. Did he deny that he had a problem with prescription drugs at that time?
A. No.
Q. Did he say anything about whether or not he had a problem with prescription drugs at that
time?
A. Rephrase that.
Q. It's hard for me to say. At that time during this conversation -- how long did -- how long were
you there with your brother?
A. A few hours.
Q. A few hours.

A. Uh-huh.
Q. And during those few hours, did your broth- -- you said your brother didn't say he had
problem with prescription drugs; is that correct?
A. No, he didn't say it. He didn't say he didn't.
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Q. Okay. Did he say anything about what you were saying Grace had told you?
A. He just said he's fine. "Don't worry. I'm fine. I'm okay. I'm not going to go."
Q. Okay. So he just said he was okay?
A. Uh-huh.
Q. Did he seem okay?
A. At the time, yes.
Q. So you didn't think he had -- did you think he had a problem at the time?
A. Yes.
Q. And did you leave there thinking he had A problem?
A. Yes.
Q. And did you ever discuss it with him again after that day?
A. Yes.
Q. When did you next discuss it with him, if you can recall?
A. But that day may have been the last time, maybe. Now, that's -- there were prior times.
Q. Got it. Now that you recall that that may have been the last time you discussed it with him,
does that refresh your recollection as to when it happened?
A. It was just around the Santa Maria trial.
Q. But you don't know if it was before or after?
A. It was after, I think.

Q. And from that time until the time of his passing, you never discussed it with him again; is that
correct?
A. No.
Q. And was there a reason why you never discussed it with him again?
A. I hadn't gotten a call from Grace or anyone like that.
PAGE 92:15 TO 93:11 (RUNNING 00:01:03.100)
Q. So did anyone ever tell you that they thought your brother had a problem after that day in
Vegas? And by "a problem," I mean a problem with drugs.
A. Leonard Rowe would tell me that.
Q. Excuse me. Leonard Rowe?
A. Leonard Rowe, uh-huh.
Q. When did Mr. Rowe tell you this?
A. When?
Q. Yes.
A. I guess around the time the shows in London were being prepared.
Q. So sometime in 2009?
A. No. No, let me correct that. Initially, we were playing our tour. And Rowe was around. The
brothers touring. That was the initial plan. And there was concern then.
Q. And who expressed that concern? Was that Mr. Rowe?
A. Yes.
Q. Did anyone else?
A. No.
PAGE 98:21 TO 100:16 (RUNNING 00:02:05.727)

Q. Okay. So going back to where we started, you talked about the time in Vegas.
A. Okay.
Q. Did you ever discuss that time with your parents?
A. In Vegas or --
Q. The time where you and your siblings went to talk to Michael about what Grace had told you.
A. Yes.
Q. And can you recall what their reaction was?
A. Displeased.
Q. With?
A. Him not getting the help that he needed.
Q. Do you know if they ever talked to him about what Grace had told you after you told them?
A. Did they --
Q. Talk to Michael?
A. Did they talk to him?
Q. Uh-huh.
A. I don't know.
Q. Okay. Now, did you have any professionals with you, something like a doctor?
A. Yes.
Q. What was the doctor's name?
A. I forgot his name.
Q. Was it --
A. Yes, I did.
Q. And was this doctor -- who brought the doctor into the mix?

A. I did, Janet did.

Q. You don't recall who did?
A. Yes.
Q. Do you recall how it was determined that this was the person you should take with you?
A. We decided that.
Q. And what was the basis of that determination?
A. He was an experienced interventionist.
Q. And how did you know that?
A. He told me, and I --
Q. Had you met him before?
A. No.
Q. Okay.
A. Internet.
Q. Is that where you first --
A. Probably.
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Q. Okay. Now, was this Mr. Webb?
A. No.
Q. No?
A. That doesn't sound right. It could be, though. I mean --

Q. You just don't recall?
A. I don't recall.
Q. That's all right.

PAGE 100:25 TO 102:17 (RUNNING 00:02:09.707)

Q. Now, besides the siblings that you mentioned who went and this doctor --
A. Yes.
Q. -- was there somebody else who went?
A. As I recall, there were two interventionist guys there. I don't know who the second one was. As
I recall, two guys, yeah.
Q. And did you arrange for both guys to come with you?
A. I didn't arrange it. Janet knew them, and I talked to them.
Q. Got it. And did you talk -- did they talk to Michael during these several hours that you were
there?
A. Yes.
Q. And what did they say?
A. I don't remember specifically. They just said that your family loves you and they're just here
to help you.
Q. And had you met these two doctors before that day?
A. Yes.
Q. And where had you met them?
A. We met at Madeo for lunch.
Q. Okay. Was that the only time you saw them before that day?
A. Probably met them one time before then.
Q. Okay. And do you recall what you discussed with them, if anything, before that day?
A. I do recall -- I'm sorry. Say again.
Q. Do you recall what you discussed with them when you met with them prior to the day in
Vegas?
A. Just what they do and what is the procedure here, what do they suggest.

Q. Now, Michael had been in rehab previously; correct?

A. Yes.
Q. So did you discuss that with them?
A. Yes.
Q. How many times had he been in rehab before, if you know?
A. I think one time.
PAGE 102:23 TO 103:16 (RUNNING 00:01:01.205)

Q. And did you discuss Michael's history with drugs with these two doctors?
A. Yes, as far as I knew, yes.
Q. And do you recall what you knew at the time?
A. I told them that there had been prior attempts to get him help and we weren't too successful,
so we thought we'd bring in professionals.
Q. And so -- and how many prior attempts had there been?
A. Once in New York, and another time at his ranch.
Q. So there had been two prior times that you're aware of?
A. That I'm -- that I can remember, yes.
Q. And did you -- you discussed that with the doctors?
A. Yes.
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Q. And did you discuss what had transpired at your brother's house with the doctors after you
left?
A. Yes.
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Q. Did you ever see those doctors again after that day?

A. No.
Q. Did you ever speak with them after that day?
A. No.
PAGE 105:17 TO 105:23 (RUNNING 00:00:22.215)
Q. Who was at the house besides Michael, if anyone?
A. Just security.
Q. And was there anyone else present when you had this conversation with Michael at his house
other than the people you've already mentioned?
A. Not that I know of.
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Q. Okay. Now, that's the Vegas time. You mentioned another one was in New York?
A. Yes.
Q. And if I understand, you now believe that happened sometime prior to the Vegas time;
correct?
A. Yes.
Q. And you indicated that each of those times you were worried about your brother?
A. Yes.
Q. What was the basis of your worry in New York?
A. Prescription.
Q. Let me ask, each time this occurred, was it the same concern?
A. Yes.
Q. Okay. And what was the basis of your concern this time, the New York time?
A. Prescription abuse.
Q. And -- but why were you concerned? Had Grace called you?

A. Yes. Oh, Grace called me, yes.

Q. And each --
A. Called me up.
Q. -- time that you were concerned, was it because Grace had called?
A. Yes.
Q. Okay. And where was your brother staying in New York, if you recall?
A. A hotel.
Q. And who was with you, if anyone?
A. It was Janet, Rebbie, Tito.
Q. And do you recall which hotel?
A. I don't remember. I don't remember.
Q. Can you recall when this occurred?
A. Early 2000, mid 2000.
Q. And Grace had called you; correct?
A. Yes.
Q. And did you call anybody else?
A. Family.
Q. Other family members?
A. Yes.
Q. Did you call Rebbie?
A. Yes.
Q. Tito?
A. Yes.

Q. Janet?
A. Yes.
Q. Okay. Anybody else?
A. Yes. That's it.
Q. And did she say why she believed that Michael was abusing drugs at this time?
A. Why?
Q. Why she believed it.
A. She just said, "You need to get down here."
Q. She didn't say why she believed that you needed to?
A. She didn't need to say. I mean --

Q. And why didn't she need to say?
A. Because, my brother.
PAGE 108:15 TO 109:15 (RUNNING 00:00:37.326)
Q. And did you take any doctors with you this time?
A. No.
Q. Did you take anyone beside the your siblings?
A. Just family.
Q. Okay. And was this one of those times where you wanted to see him and he said he wouldn't
see you?
A. No.
Q. So he agreed to see you?
A. I guess. I just sort of walk in, so --
Q. Okay. And -- that can happen. And what happened?

A. He wouldn't go.
Q. Excuse me?
A. He wouldn't go.
Q. The same thing happened this time that happened in Vegas?
A. Yeah.
Q. And did you each, once again, tell him to go?
A. Yeah.
Q. And did he, once again, tell you he wouldn't?
A. Yes.
PAGE 109:16 TO 109:25 (RUNNING 00:00:19.354)
Q. And how long were you there this time?
A. A few hours.
Q. And this time did he say he wasn't abusing prescription drugs?
A. I don't recall.
Q. Do you recall if he said he was abusing prescription drugs?
A. I don't remember the details of that --
Q. And --
A. -- conversation.
PAGE 110:01 TO 110:12 (RUNNING 00:00:28.588)
Q. Did he end up going to rehab this time?
A. No.
Q. And did you talk to your parents about it at this time?
A. No.

Q. And why not?

A. Didn't want to stress them, worry them.
Q. And did you talk to Michael about it again after you went to New York?
A. I don't recall.
Q. You don't recall. Do you recall any follow-up at all?
PAGE 110:15 TO 112:06 (RUNNING 00:01:45.362)
Q. Did you do anything to follow up on this intervention?
A. No. Just inquiring.
Q. Did you talk --
A. I called Grace.
Q. And what happened with the call to Grace?
A. She told me that he cleaned up.
Q. Really?
A. Yes, stopped.
Q. And did she say how?
A. Because I was there, probably, so --
Q. Did you stay with him this time?
A. No, but I made my point clear, so he --
Q. How did you make your point clear?
A. Brothers. Just talked to him.
Q. You talked to him. What did you tell him?
A. Just tell him that his family loves him, concerned for him and --
Q. Was anyone else there besides the family?

A. Just us.
Q. Just you. Did he clean up after the Vegas intervention as well?
A. Yes.
Q. And how long after that did he clean up?
A. He was clean for -- he stopped using those things. As far as I know, he stopped using it.
Q. And where did you learn that from?
A. I learned it from Grace. Pretty much Grace.
Q. Anybody else?
A. No.
Q. All right. Do you know how he cleaned up after you went to New York?
A. I don't know.
Q. Did anyone ever discuss how he cleaned up with you?
A. No.
Q. And what about after Vegas? Do you know how he cleaned up after Vegas?
A. No.
24. PAGE 113:12 TO 117:03 (RUNNING 00:03:23.400)
Q. So there was New York. There was Las Vegas. What was the third place? I have to find it.
A. The ranch.
Q. Thank you. The ranch. Did the time at the ranch occur after the time in New York, if you
know?
A. Yes.
Q. And did you once again get a call from Grace?
A. Yes.
Q. And do you recall what she said this time?

A. Same thing. "You need to get down here."

Q. And did Grace call other people as well?
A. Not that I know of. Maybe just me.
Q. And did you tell your siblings?
A. Yes.
Q. And who did you tell?
A. Rebbie, my brothers, Janet.
Q. Did you have another conference call?
A. Yes.
Q. And who was on that call, if you can recall?
A. Rebbie, Janet, you know, Jackie, all of us.
Q. Were your parents on the call?
A. No. No.
Q. Did you tell your parents about Grace's call?
A. The Grace one, I think we did. I think my mom find out about the Grace, yes.
Q. And then you went to the ranch to confront your brother?
A. Yes.
Q. Did you go by yourself?
A. No.
Q. And who went with you?
A. My family.
Q. Did your mom go?

A. I think so. I think so.

Q. And Janet?
A. Yes.
Q. And Rebbie?
A. Yes.
Q. Marlon?
A. No.
Q. LaToya?
A. I don't recall LaToya being there.
Q. Jermaine?
A. No.
Q. Jackie?
A. Yes.
Q. Did I ask about Marlon?
A. Yeah, you asked.
Q. Who am I forgetting?
A. That's it.
MS. BISCAY: Tito.
MR. PUTNAM: Tito, thank you.
THE WITNESS: I think Tito may have been there.
BY MR. PUTNAM:
Q. And did you tell your brother you were coming?
A. No.

Q. And when you arrived, did you ask to see him?

A. No.
Q. You just went in?
A. Yeah.
Q. And how did you get in this time?
A. Just walked in.
Q. Did anybody go over the fence?
A. Yeah. That's pretty good. You do your work.
Q. And who went over the fence?
A. One of my brothers.
Q. And did they go over the fence because security wouldn't let them in?
A. No. They wouldn't let them in -- it's not that they wouldn't let him in. I forget who did that,
though. I forgot which one did it.
Q. And why did they go over the fence, if you know?
A. To open the gate.
Q. Is that because security wouldn't open it for you?
A. Yeah. We don't ask.
Q. And did you end up seeing your brother Michael this time?
A. Yeah.
Q. And did you once again confront him?
A. Yes.
PAGE 117:07 TO 119:02 (RUNNING 00:01:48.254)
Q. Did he once again say he wouldn't go to rehab?

A. Yes.
Q. Okay. And how long were you there this time?
A. A few hours.
Q. And did you leave believing that your brother had a problem at that time with prescription
drugs?
A. Yes.
Q. And did doctors go with you this time?
A. No.
Q. So was it just family?
A. Yes.
Q. And did Michael this time deny that he had a problem with prescription drugs?
A. Yes.
Q. And he also, if I understand -- and I think you already said this. He also refused to go to
rehab; correct?
A. Yes.
Q. And -- but you didn't believe him when he said he didn't have a problem?
A. No.
Q. And did --
A. Yes, I didn't believe him.
Q. And did any -- did you discuss your not believing your brother with any of your siblings?
A. Yes.
Q. Who did you discuss it with?
A. Just leaving there, we all talked about it.

Q. Okay. And did anybody else indicate to you that they didn't believe that he wasn't abusing
prescription drugs as well?
A. In my family?
Q. Uh-huh.
A. Yes.
Q. And who was that?
A. Rebbie, Janet, you know, all of us.
Q. How about your mom?
A. Did my mom?
Q. Yeah. Did your mom say whether she believed he was abusing or not at the time?
A. My mom didn't believe it, but then she's my mom. She doesn't want to believe it, maybe. I
don't know.
PAGE 119:10 TO 119:13 (RUNNING 00:00:05.232)
Q. Now, did your brother end up going to rehab after you -- this attempted intervention at the
ranch?
A. No.
PAGE 119:16 TO 120:05 (RUNNING 00:00:38.115)
Q. You said the other two times your brother got clean afterwards?
A. Yes. The Vegas time, as I recall. I know that one because that was when I was helping him,
and I watched the cleanup. But I was around, and I think that, you know --
Q. When you say you were helping him, what do you mean?
A. With -- that's around the Santa Maria time.
Q. Got it.
A. So I watched things change.

Q. And did he talk to you about the fact that he was cleaning himself up?
A. No. He just did it and got ready for the 05 trial.
PAGE 120:09 TO 120:15 (RUNNING 00:00:10.829)
Q. Did Michael ever discuss with you that he believed he ever had a problem with prescription
drugs?
1
A. No.
Q. Did he ever discuss any drug problem with you ever?
A. No.
PAGE 120:16 TO 121:17 (RUNNING 00:01:24.976)
Q. So after the -- you were at the ranch, you said, a couple hours this time?
A. Yes. Two or three hours.
Q. And did you ever discuss Michael's drug use -- strike that. Did you ever discuss with Michael
that attempted intervention after that day?
A. The time at the ranch?
Q. Uh-huh.
A. Yes.
Q. When was that?
A. One other time with Janet.
Q. And when was that?
A. Maybe a month later.
Q. And where were you all, if you can recall?
A. The ranch.
Q. And who decided to bring it up?
A. We did.

Q. And what did you do? What did you say?

A. I told him that I wanted him to come to A therapist with me.
Q. And what did he say?
A. He said okay.
Q. And did he go to one?
A. In fact, it was later than that. No, because the whole Santa Maria thing started to happen. So
then that kind of took over.
PAGE 122:03 TO 122:06 (RUNNING 00:00:14.901)
Q. Except the times that you've mentioned here today, did you ever discuss your belief that
Michael was abusing prescription drugs with Michael?
A. No.
PAGE 127:12 TO 127:15 (RUNNING 00:00:11.712)
Q. What about Frank DiLeo? When was the last time you saw Frank DiLeo?
A. I went to visit him in the hospital after he was in a coma.
PAGE 128:17 TO 128:21 (RUNNING 00:00:24.292)
Q. How long have you known Mr. DiLeo?
A. 20, 30 years.
Q. When did you learn that he had come back as your brother's manager?
A. When I learned about the O2 shows.
PAGE 129:13 TO 129:15 (RUNNING 00:00:03.750)
Q. Did you think he was a good manager for your brother?
A. Yes.

PAGE 136:13 TO 136:17 (RUNNING 00:00:06.958)

Q. Did Michael ever discuss his pain from the burn with you?
A. Yes.
Q. And what did he tell you?
A. He said it was painful.
PAGE 136:23 TO 137:06 (RUNNING 00:00:21.273)
Q. Now, were you aware that Michael had A surgery subsequent to the burn to try to correct the
scarring?
A. Yes.
Q. And did you discuss that surgery with Michael ever?
A. Yes.
Q. And what did you discuss?
A. I just went to visit him in the hospital.
PAGE 138:05 TO 139:16 (RUNNING 00:01:48.044)
Q. Do you know if your brother Michael ever had trouble sleeping?
A. No.
Q. Did he ever discuss insomnia with you?
A. No.
Q. Did anyone ever discuss your brother's insomnia with you --
A. No.
Q. -- prior to his passing? Did -- has anyone ever discussed with you Michael's use of
anesthesiologists during tours?
A. No.

Q. Do you know if your brother Michael ever took any medication to help him sleep?
1
A. Other than in the Murray trial, no, not before that, no.
Q. And I don't want to know what you learned there. It's prior --
A. No.
Q. -- to his passing.
A. No.
Q. Okay. Did you ever see Michael ever take any prescription drugs?
A. Never.
Q. Did you ever see him take any illegal drugs?
A. Never.
Q. Prior to your brother's passing, had you ever heard of propofol?
A. Never heard of it.
Q. Had you -- have you heard of it now?
A. Yes.
Q. Okay. And what about Diprivan?
A. Never heard of it.
Q. Okay. Did your brother ever discuss taking something called milk to help him sleep?
A. No.
PAGE 163:16 TO 164:04 (RUNNING 00:00:23.933)
Q. The first question is, do you know whether your brother ever used illegal drugs?
A. I never got a call about illegal drugs.
Q. What's that?

A. I never got a call about illegal drugs.

Q. Did you ever talk -- see him use an illegal drug?
A. Never.
Q. Did anybody ever tell you he was using illegal drugs?
A. No.
Q. And did you ever believe he was using illegal drugs for any reason?
A. No.
PAGE 164:05 TO 165:09 (RUNNING 00:01:46.350)
Q. Okay. Now, you indicated that at various points you talked to various people, including
Grace, about Michael's misuse of prescription drugs. When did you first -- and that you believed
that he had a problem with prescription drugs, you've indicated. When did you first come to
believe that he had a problem with prescription drugs?
A. I guess it was Grace.
Q. Do you think she told you?
A. Yes.
Q. And can you recall when that happened?
A. The first time was Los Angeles; she called me.
Q. And when was that, if you can recall?
A. Around 2000, year 2000.
Q. Okay. And that -- can you recall what she said at that time?
A. She just told me that she was concerned.
Q. Did she say why she was concerned?
A. Yes. Because he was using prescription medicine too much.
Q. Did she say what kind of prescription medicine he was using too much of?

A. Sedatives, whatever they call them, sedatives, yeah.

Q. And did you talk to your brother about Grace's concern at this point?
A. No.
Q. Did you talk to anyone about it?
PAGE 165:13 TO 166:04 (RUNNING 00:01:03.499)
WITNESS: I talked to Rebbie about it.
BY MR. PUTNAM:
Q. And why didn't you talk to your brother Michael about it?
A. I was investigating it more.
Q. And how did you investigate it?
A. Talking to people around him.
Q. To who?
A. Rebbie. Also -- I'm just trying to think back because I don't -- it's awhile ago. Also, as I recall,
I tried calling a doctor in Vegas and a doctor in Florida, but they wouldn't talk to me about it.
Q. Were they doctors you had met before?
A. No.
Q. How --
A. And I forget their names.
PAGE 166:13 TO 167:02 (RUNNING 00:00:42.719)
Q. Did you ever talk to any doctor about your concern about your brother's misuse of
prescription drugs?
A. Yes.

Q. Who was that?

A. I talked to doctor friends that I knew, just to my friends who were doctors.
Q. Did you ever talk to any of Michael's doctors?
A. No.
Q. And so after this first conversation you had with Grace in around 2000, from that point on,
did you believe that your brother had a problem with prescription drugs?
A. Yes.
PAGE 169:05 TO 169:17 (RUNNING 00:00:28.433)
Q. And did you believe he was addicted?
A. I don't know if I would call it -- I wasn't sure. I wasn't clear on it.
Q. What did you believe his problem was?
A. Sorry?
Q. You believed that he had a problem with them. What problem do you think he had with them?
A. Just excessive use, maybe. I guess I mean, I don't know if I would call that an addict. I don't
know.
Q. Well, I don't know either.
A. I'm not a doctor.
PAGE 170:21 TO 172:05 (RUNNING 00:01:42.689)
Q. Okay. Did your brother ever tell you that he was addicted to prescription drugs?
A. No.
Q. Did he ever tell you he had a problem with prescription drugs?
A. No.
Q. All right. Did you ever discuss your belief that your brother had a problem with prescription
drugs with your mother?

A. Yes.
Q. And when was that?
A. That was after the second attempt at intervention, around that time.
Q. And that was the one at Neverland?
A. Around that time, yes. The one my mother attended.
Q. And can you -- where did that conversation take place?
A. Where?
Q. Yeah.
A. On the phone.
Q. And did you initiate the conversation?
A. Yes.
Q. And what did -- how did you initiate the conversation?
A. How did I?
Q. I mean, did you say, "Mom, I think Michael" --
A. Yes.
Q. -- "has a problem"?
A. Yes. And I told her that we need to plan an intervention and -- and her being our mother,
because she was there.
Q. And she ultimately agreed to be there?
A. Yes.
PAGE 172:06 TO 172:08 (RUNNING 00:00:03.656)
Q. Now, did your mother ever tell you that she believed your brother had a problem with
prescription drugs?

44. PAGE 172:13 TO 172:18 (RUNNING 00:00:10.188)

A. No. No, she didn't tell me that she believed.
Q. Did she tell you she believed he didn't have a problem?
A. She wasn't sure, but she's, you know, A mother, so --
PAGE 174:10 TO 175:06 (RUNNING 00:00:50.218)
Q. How many times did you and your father attempt through telephone calls to talk to your
brother?
A. We called and tried to get through Carolwood. I think it was during the time at Carolwood
that we made calls. But we were unsuccessful.
Q. So you actually tried to talk to your brother when he was living at Carolwood?
A. We tried to talk to him, other people around him.
Q. So you had a concern when he was at Carolwood that there might be a drug issue?
A. There was a drug issue. He wasn't eating. All of these things were happening at the same time.
And, you know, a lot of pressure, you know.
Q. And what was your basis for your belief at the time that you thought he might have a drug
problem during the time he was living at --
A. Leonard Rowe was -- was involved very much in the shows and was giving reports to me that
he didn't look too good. So --
PAGE 175:18 TO 175:22 (RUNNING 00:00:22.505)
Q. Did you or any member of your family did you and any member of your family discuss the
idea of doing an intervention around the time he was living at Carolwood?
A. We may have, yes. Yes. Yes. Yes.
PAGE 177:12 TO 177:22 (RUNNING 00:00:24.436)

Q. Okay. Was the conversation -- did you discuss the idea of putting him in a rehabilitation
center at that time?
A. Yes.
Q. And did you have one in mind?
A. Yes.
Q. Which one?
A. Bay area, San Francisco area.
Q. And how was that one chosen?
A. The same place where the interventionist worked out of that had gone with me to Vegas.
PAGE 178:09 TO 178:15 (RUNNING 00:00:08.985)
Q. Did you ever see him drunk?
A. Sorry?
Q. Drunk.
A. No.
Q. No. Did your brother drink alcohol?
A. I never seen him drink alcohol.
PAGE 179:11 TO 179:15 (RUNNING 00:00:10.507)
Q. From 2000 until the time that your brother passed, were there periods of time where you
believed he did not have a problem with prescription drugs?
A. Yes.
Ms. Bina. Your honor, the parties have stipulated that occurred in 2002 -- 2004, 2005, because
he's not clear on the record.
Judge. You mean the firing?

Ms. Bina. Yes, the firing of Ms. Rwaramba that he referred to there.
Judge. Thank you.
(excerpts of the videotaped deposition of Randy Jackson were played.)
PAGE 202:04 TO 203:17 (RUNNING 00:01:45.999)
Q. When you were with Michael on tour, did he seem to enjoy touring?
A. Yes.
Q. Why do you say that?
A. Well, because we like to tour, perform. Yes.
Q. Either while you were on tour with him as part of the Jacksons or while you visited him on
his solo tours, did you ever observe him under the influence of prescription medication while on
tour?
A. No.
Q. You never saw any signs?
A. On tour, no.
Q. Did you ever see any signs at other -- at other times other than what we discussed at your
last deposition, to the extent you remember?

A. Did I ever see any signs of --

Q. Signs that he was on prescription medications.
A. Yes.
Q. And when was that?
A. When was it that I --
Q. That you saw signs.
A. It's been more than one time. In his home. His home.
Q. Which home?
A. 19- -- 2005, I think it was, Shadow Wood, around that time. The Shadow Wood home.
Q. Where was the Shadow Wood home?
A. Beverly Hills.
Q. And what did you see there?
A. He was under the influence of something.
Q. What was he doing to make you think he was under the influence?
A. Slurred speech.

Q. Anything else?
A. And then Grace would tell me -- his nanny, she would tell me all the time that, "You need to
get over here. Something's not right."
PAGE 203:23 TO 205:09 (RUNNING 00:01:49.633)
Q. Okay.
A. I went over to help him out and take everything away as I could. But, you know...
Q. To take the medications away?
A. Yes.
Q. Okay. Let's go back first to the one time at the Shadow Wood home that you saw him with --
when he appeared to be under the influence.
A. Yes.
Q. Why were you at the house at that time?
A. Why was I there?
Q. Yeah.
A. I wasn't there. I was called and I came over.

Q. Called by who?
A. I think it was Grace again who called me.
Q. Why did she tell you to come over?
A. She needed help with him. He wasn't doing so well.
Q. Did she say anything else?
A. We had discussed this before, her and I, so I kind of knew what was going on. So I went over.
Q. And what did you see when you went over there?
A. He was certainly under the influence of something that was altering his normal way of
functioning. And I -- I tried to get him some help.
Q. How did you try to get him help?
A. First thing I tried to do was take everything away, from Grace, too, because -- it was ironic
because she was the one giving it to him but at the same time complaining about it. So it was a
strange situation. It was upsetting to me because she -- I think she had a hard time saying no to
him. But she would go and get it for him and then give it to him.
PAGE 205:24 TO 206:20 (RUNNING 00:00:51.792)
Q. Do you know if the prescriptions were in Grace's name?
A. Yes.

Q. They were in her name?

A. Um-hum, which I thought -- it was very upsetting to me.
Q. Do you know what doctor was providing the prescriptions?
A. No, I don't recall that.
Q. So when you went that day to help Michael, you said you took everything away?
A. The best that I could, yes.
Q. You just looked around the house and took bottles?
A. Yeah. I made her show me where everything was, because what good would it be to help him
if you're leaving stuff there?
Q. Did you talk to Michael?
A. Yes.
Q. What did you say to him?
A. Well, not much because, you know, to talk to someone like that, you know, you're not really --
PAGE 206:23 TO 209:17 (RUNNING 00:03:43.027)
A. -- you're not really getting anywhere, so...

Q. You mean he wasn't in a condition that you could talk to him?

A. Yes. I could talk to him, but I would pick my moments. I'd wait till he would be a little bit
more in tune with...
Q. So he didn't tell you what he had taken specifically?
A. No.
Q. Did you do anything else besides take away --
A. Yeah. He -- I was there, and I went downstairs. I think he had some friends over. And I went
downstairs to eat something. And they ran downstairs and told me that he had collapsed. And I
went upstairs. I picked him up. I put him on the bed, and I -- this is pretty late. And as I recall, I
called my -- I called my doctor who lived literally like right around the corner, woke him up, and
I said, "I'm coming to get you. I'll be there in like two minutes." And my doctor came over, and
he took care of him. He said, "He'll be okay." Just -- that was that time.
Q. And who was that doctor?
A. He's not my doctor now. I think he's retired. Dr. Glasier. Glasier. I'll get you the right
spelling.
Q. Did he do anything to treat Michael?
A. Yeah. He gave him something that would counter -- help counter whatever it was he had
done. And he said, "Just let him rest it off. Somebody should sleep next to him, make sure he
doesn't vomit or choke, anything like that." So I instructed someone to sleep near him while I
took the doctor back.
Q. Who did you instruct to sleep near him?

A. One of the Cascios.

Q. Was one of the Cascios staying at Michael's house at that time?
A. Yeah. They were friends. Yeah.
Q. And when you came that day, did you come with anyone else?
A. No.
Q. So did you stay overnight?
A. Yes, I did.
Q. How was Michael the next morning?
A. He was sleeping pretty late, so I just wanted to make sure he was okay. Then I left.
Q. Did you talk to him about that incident afterwards?
A. Yeah, I did.
Q. What did you say?
A. I said that, "Do you remember what happened?" He goes, "No, no, but I heard." He said --
he said he took it to help him sleep, and he said that -- he said it was a mistake. He was sorry
about it.
Q. What did you say in response?

A. I said -- I don't remember exactly what I said, but, you know, I was just kind of taken aback
by it maybe.
Q. Did you have concerns about Michael's drug use at that point?
A. Yeah, I did, pretty much.
Q. Did you take any further actions?
A. Yes.
Q. What did you do?
PAGE 209:18 TO 209:22 (RUNNING 00:00:17.013)
A. It's funny because you already know, but you ask. I'm sure you heard from everybody else all
the stuff I've done. I staged several interventions and set up -- tried to get him help many times.
PAGE 209:25 TO 210:09 (RUNNING 00:00:20.418)
Q. You mentioned that Grace was the one who would call you about his problems but Grace
was also getting him the medications.
A. Yeah.
A. few times I would meet her at the pharmacy and say, "What are you doing here?" Actually, I
would like -- when I found out that she was -- I would, like, race to the pharmacy. "What in the
heck are you doing? What are you doing?" She's like, "Oh" -- I would get upset.

PAGE 210:24 TO 214:04 (RUNNING 00:04:27.680)

Q. So apart from this one instance, I know you mentioned you staged several interventions. Last
time I think we talked about three different ones.
A. Um-hum.
Q. We talked about one in New York?
A. Um-hum.
Q. One at Neverland Ranch?
A. Yes.
Q. And one in Las Vegas?
A. Yes.
Q. Do you recall any other interventions?
A. It was more than one at Neverland.
Q. More than one?
A. Yeah. There were a few of them there.
Q. How many do you think?

A. Oh, I don't know. Maybe four or five.

Q. Four or five?
A. Yes.
Q. Do you remember approximately what years those were?
A. The ones at Neverland were around 2004, 2005, around that time. 2005, 2006. Yeah, around
that time it was pretty -- because I was spending a lot of time with him so I kind of got a close
look at what was going on. Wrote letters.
Q. You wrote letters to who?
A. You can't volunteer information in these things. I wrote letters to my family about his
problem and that we had to do something to help. I said that -- that's what I said.
Q. Do you remember who specifically you wrote these letters to?
A. Everybody. I copied everybody on it. Everyone. I made sure everybody knew it. I would say
he has -- he's an addict, and at this point, addicts aren't so responsible for what they do. So this
is where the family needs to step in and do something about it because their desire becomes
physical.
Q. Did you write these letters to your mother as well?
A. Everybody got a copy of it.
Q. Was it a letter as opposed to an e-mail?
A. How did I get it to them?

Q. Yes.
A. It was a letter. I wrote it down on paper. It may have been -- I had my assistant copy it. Was it
a letter or was it an e-mail? I don't remember, but I know that everybody got a copy. It was very
important to me. Because not everybody in my family looks at their e-mail so you've got to --
Q. Got it.
A. The older people don't do that.
Q. Did you get responses from people in your family?
A. I think everyone was in shock, maybe a little denial. And I always got responses from the
people -- same people who really were more interested in really doing something about it.
Q. And who were those people?
A. My dad, Rebbie and Janet. Always those ones.
Q. What about your mom?
A. No. My mom, no. As a mom, I guess maybe it was hard for her, you know, for a mother to see
that. So...
Q. So when you did these four or five interventions at Neverland between 2004 and 2006, I
know the one that we talked about last time, there were a bunch of you that went, including your
mother, I believe.
A. One of them included my mom.

Q. For the other three or four, did anyone else go or was it just you?
A. Oh, no. Other people would come. Sure. Rebbie, Jackie. I had Jackie -- I just wanted as
many family members to be there, just -- Rebbie, Janet went on all of them except maybe one or
two. She was out of town. Jackie.
PAGE 214:16 TO 215:17 (RUNNING 00:01:16.406)
Q. Yeah. Describe to me the first one that you can remember in that set of three or four
additional interventions.
A. The first one that I can remember, the first one was at Neverland. Yes. The first one was at
Neverland.
Q. And this was not one that Katherine was at, correct?
A. No.
Q. Who was there?
A. It was Janet, myself, I want to say Rebbie. Maybe my mom was at that one. I think my mom
was there.
Q. So do you think now that she was at more --
A. Jermaine was there, myself. Jermaine was at that one. Jermaine was there as well.
Q. Do you think your mother was at more than one intervention at Neverland?
A. No, that was the one she was

at.
Q. Okay.
A. I'm trying to remember the sequential order of these. That was the one that my mom was at.
That must have been the first one.
Q. Was that in around 2002, I think you said last time? I could --
A. Yeah. 2002, 2003. Around that time.
PAGE 215:22 TO 217:02 (RUNNING 00:01:38.046)
Q. Let's move on to the next one at Neverland.
A. Yeah. I mean, same thing. My sisters were always, you know, really supportive, there all the
time. My sisters, Rebbie and Janet.
Q. Went with you the second time?
A. Yeah. Always with me. My dad, also. Very supportive of that.
Q. Did you bring any doctors with you that time?
A. No.
Q. Anyone else besides you, your sisters and your father?
A. No. No one else.

Q. What happened when you got to Neverland?

A. I think that time he wasn't there. Sometimes he wasn't there.
Q. So you didn't actually speak with him that time?
A. No.
Q. Do you know that he wasn't there?
A. Yeah. But, see, people would tip him off at the same time. So we'd try to do this -- you know,
he had friends that worked in the town so he knew when I was coming. So it's bad news. Randy's
coming to shake things up.
Q. After you went that time and he wasn't there, did you follow up with him and try and find
him?
A. We went again another time, and I took some interventionist with me the second time. We --
PAGE 218:14 TO 218:17 (RUNNING 00:00:07.821)
Q. Okay. In the one where you brought the interventionist, what happened when you guys got to
-- this was also at Neverland?
A. This was at Vegas.
PAGE 218:23 TO 219:14 (RUNNING 00:00:38.717)

Q. Okay. So after the Vegas one, were there any more?

A. No.
Q. No more?
A. No more after Vegas.
Q. And did the Vegas come before or after the Shadow Wood?
A. It came after Shadow Wood.
Q. After Shadow Wood?
A. Yes.
Q. Okay.
A. There was no more interventions. I tried to get -- I still tried to get him help, but, you know, I
couldn't get as many people to stage an intervention. But I still tried to get him help.
Q. How did you try to --
A. Tried to jump the gate a few times.
PAGE 219:18 TO 221:10 (RUNNING 00:02:51.571)
Q. When you say you tried to get him help, you just tried to go to his house and see him and
talk to him again?

A. Yeah. My dad and I tried a few times to get him help.

Q. Back to the Shadow Wood for a moment. Do you know where Michael's children were when
you came to see him that day?
A. Shadow Wood is like a 50,000-square-foot house. I hated that place. It's too big. They were
somewhere.
Q. They were in the house somewhere?
A. Yeah.
Q. But you never saw them?
A. No.
Q. At any other point at any time, did you ever see Michael in a condition like you did at the
Shadow Wood home that day?
A. Yes. Yes.
Q. When?
A. When? I mean, a few times. Michael wouldn't want to really be around his family too much,
but I think it was because he didn't want us to see him like that, or me, especially me, because
I'm not just kind of not doing anything. He'd kind of hide from me.
Q. Could you give a range of years that this was happening?

A. No. I mean, it happened over a period of time. When I was -- he stopped doing it, also. When
I was helping him with his situation in Santa Maria, I got him to stop. And I was able to do that
by firing Grace. So I was able to stop where it was coming in. And he really, really enjoyed
participating with his children. He had a great time, you know. Without anybody or any help, he
would take care of the kids, cook for them. He'd do all these things that he really enjoyed doing.
It was great. He was in a great place. And then somehow Grace came back around, and he
started using, doing it again. I was really upset about that.
PAGE 221:25 TO 224:21 (RUNNING 00:03:58.799)
Q. Do you have an understanding as to about when he started using prescription drugs again?
A. He started, and I got him to stop again. He started right before the Santa Maria trial started,
and then I got him to stop. And I was able to get him to stop because I told Rebbie, "Don't leave
his side," because I didn't trust Grace anymore. I fired her again because I noticed there was a
pattern. Whenever she's around, he's wasted. So I fired her again. And I said, "Rebbie, don't
leave his side. Make sure you watch everything he does, because I have to get him in this
courtroom every day and see this thing through."
Q. So you got him to stop during the Santa Maria trial?
A. Um-hum.
Q. And then did you have an understanding that he started using prescription drugs again after
that?
A. No.
Q. No?
A. No.

Q. So all of the interventions you described were before the Santa Maria trial?
A. There was one after. You're good. The Vegas one was after. It was after.
Q. So you did have an understanding at some point after Santa Maria that he was using
prescription drugs?
A. I think the Vegas one was after. Yeah. Yeah. The Vegas one was after. And yes, he was using
again because there was a -- it was quite disturbing to me. There was a People Magazine article
that was coming out. It was going to talk about his drug use. And Grace had told him that I was
behind putting this article out. Grace and actually Raymone Bain because I fired them both.
They told my brother that I did this article, but I fired both of them. That's probably why they did
it. But they both said that. It had nothing to do with me. And I can remember that he had gotten a
lot of people in my family to sign a letter that was put in People magazine saying that he never
did drugs, never used them in an inappropriate way, kind of signed off on the letter. I was really
disturbed by that. I wasn't behind the article, but I wasn't going to sign a letter like that. It wasn't
true. The only people who didn't sign it was Janet, Rebbie, and my dad. And I was really
disturbed by that.
Q. Whose idea was it to have the letter?
A. His.
Q. Michael?
A. Yeah. It was his idea. I still get upset thinking about it.
Q. You didn't sign the letter, right?
A. No. Janet didn't sign it and Rebbie didn't sign it, I didn't sign it, my dad didn't sign it.
Q. Did your mother sign it?

A. My mom, La Toya, and all my brothers. But my mom, you know, she would never want to
believe it. She's a mom, you know. I felt bad for her because he would -- I felt bad for her. He
was -- he knew how to sweet-talk my mom. He knew how to do that. He was good at that.
Q. Do you think your mom ever believed he did have a problem?
PAGE 224:24 TO 225:01 (RUNNING 00:00:09.727)
THE WITNESS: I don't know. Did she ever believe he had a problem? Yeah, but I think she was
in denial. She didn't want to believe it.
PAGE 225:14 TO 225:23 (RUNNING 00:00:26.040)
Q. Did you ever talk to Michael about that letter?
A. No. He wouldn't want to talk to me too much because -- you know.
Q. Why not?
A. Well, because maybe I wasn't afraid to say no to him. So he would really -- he would, like,
get physical with me because -- and I wouldn't be afraid to say no to him. But he's like 90 pounds
so it wouldn't do much.
PAGE 227:19 TO 229:21 (RUNNING 00:02:48.477)
Q. Okay. So just jumping back for a second to when you said that you'd seen Michael in the
state that he was at Shadow Wood a few times, when were those other times and what do you
recall about them?

A. I mean, somehow, maybe during the trial -- before the trial actually started, you know,
maybe during the phase that we're at in this trial, I don't know what you call this, in the Santa
Maria trial, before the trial, the pretrial stuff, he -- I think he was really scared. And somehow, I
don't know how Grace did it, but they were able to -- I figured out, I don't know how, but she was
able to get him something. I don't know how she did it. Because it was like, "Man, I'm watching
everything." It's like -- and I think those were the times when he didn't -- he didn't want to go to
court. He didn't show up to court. And I was freaking out because it was on the news. I told -- I
went to the hospital and he said to me, he says, "I don't know what you're thinking. I'm not
walking into that courtroom so don't even think about it, Randy." And I said, "Okay." I said, "But
you're going to court." He goes, "No, I'm not."
Q. Was he in the hospital because he had had a reaction to his drug use?
A. No. He was in the hospital because he didn't want to go to court. But I think Grace -- she
was always around. And he seemed as though he was under some kind of influence. That
happened -- must have happened before the hospital. But we had him go to court and had the
doctor with him. She was somehow getting it to him. Then I later found out that she had gotten
him a patch. I was livid. That's how I couldn't catch it. Some kind of patch.
Q. Do you know what kind of a patch?
A. No. Whatever they put in those patches. I don't know.
Q. And was that what you think he had that day that he was at the hospital?
A. Yeah.
Q. And what signs was he exhibiting to you that made him seem under the influence?
A. Just slurry speech and all that. And he was really frightened to go to that courtroom. He
didn't know who to trust because people around him were lying to him, telling him things, just to
-- just to, you know, secure their positions.

PAGE 230:24 TO 232:10 (RUNNING 00:01:52.476)

Q. Okay. Other than that one time and the time at Shadow Wood, were there any other times
that you've seen him under the influence?
A. No.
Q. Those are the only two times?
A. No.
Q. No, there were more?
A. Yeah. I would get phone calls from Grace all the time. That's the ironic thing about it. She'd
be the one calling me, yet the one still getting it for him. It didn't make sense.
Q. But did you ever see Michael yourself in that condition at any other times?
A. Not that I can remember. I mean...
Q. When was the last time you remember receiving a phone call from Grace about Michael?
A. About that?
Q Yeah.
A. It was a long time ago. After I -- I made my presence known, there wasn't a lot more. She
didn't have to call.

Q. So then I think we figured that Vegas was the latest intervention --

A. Yes.
Q. -- the most
recent. Did you have an understanding that he stopped using prescription drugs at some point
after the Vegas intervention?
A. Yes. I had heard -- yes.
Q. When was that?
A. He stopped in Ireland. He stopped. Before the -- because I know that he was doing good in
Ireland from what I recall. And -- yeah.
Q. Do you remember when he was in Ireland?
A. I don't remember. I know it was after -- it must have been like '06, '07. Like '07, '08, around
that time.
PAGE 234:09 TO 234:13 (RUNNING 00:00:09.919)
Q. Do you know if he slept well on tour, if he had any sleeping issues?
A. He slept well.
Q. No issues that you know of?
A. Yeah.

PAGE 237:06 TO 238:18 (RUNNING 00:01:37.636)

Q. Do you know if Leonard Rowe and your father mentioned this to anyone besides you?
A. I don't know that.
Q. Did you mention this to anyone besides Leonard Rowe and your father?
A. No. My dad and I tried to get in the house, Carolwood.
Q. When did that happen?
A. After I had heard this. I said, "Come on. Let's go. We're going over there."
Q. Did you go to Carolwood?
A. Yes.
Q. Just the two of you?
A. Yes.
Q. What happened when you got there?
A. They wouldn't let me through. I mean, of course my brother wouldn't let me through because
he wouldn't want me to see him like that. So he was very...
Q. Who did you see there?

A. Security guys.
Q. Do you know which one?
A. I don't know. I don't know them by name.
Q. What did they say to you?
A. Maybe "He's not here. He's not there." Stuff like that. I said, "Well, why do you have the gate
closed? Open it up. What's the big deal?" That's how I knew he was there.
Q. So what happened?
A. If somebody is not there, you let them in. Sorry?
Q. Did you just go home?
A. Yeah, I would go home.
Q. After you and your father tried to go to Carolwood, did you or your father take any other
actions with respect to seeing Michael or talking to him about his drug use?
PAGE 238:21 TO 239:02 (RUNNING 00:00:29.492)
A. What was the question again? Sorry.
Q. After you and your father went to Carolwood to try and see Michael that day that we just
discussed, did you or your father take any other actions to try and see Michael about his drug
use?

A. No. After that time, no. No.

PAGE 256:01 TO 257:01 (RUNNING 00:01:05.562)
Q. You mentioned the interventions in New York, at Neverland, and in Las Vegas. Were you
aware of another intervention that you may or may not have been involved in in Taiwan?
A. I was -- yeah, I was. I forget. Yeah.
Q. Were you involved in that one?
A. Yeah.
Q. You went to Taiwan?
A. Um-hum.
Q. Who went with you?
A. I think Rebbie, some family members. I forget exactly everybody that was there. Yeah.
Taiwan, too. Yes.
Q. Do you recall when that was, if it was before the other interventions or after?
A. It was before.
Q. Before all of the other ones?

A. Yeah. Yes.
Q. Do you remember about what year?
A. It was a while back. Not terribly long -- let's see. Bill Bray was living. I don't remember the
year.
Q. Do you remember why Michael was in Taiwan?
A. He was doing shows.
Q. He was on tour?
A. Yeah. Yes.
PAGE 257:04 TO 257:15 (RUNNING 00:00:36.494)
Q. Sorry. That was a bad question. What spurred you to go to Taiwan?
A. The fact that he needed help. I think because he was far away, and, you know, we hadn't seen
him for a while. So probably we said, like, we need to go.
Q. Did you know that something was wrong at that point?
A. Well, I didn't know anything, but we had heard things. I forgot exactly how we heard it. It
was a long time ago. But that's why we went there, that particular one.
PAGE 257:19 TO 258:15 (RUNNING 00:01:29.980)

Q. What happened when you got to Taiwan?

A. You know, we went there and we visited with him just to give him some family love and just
change his thinking, make him feel comforted so that he wouldn't think about doing those things.
Q. How did he seem to you?
A. He was good.
Q. Did he seem like he was using drugs at that time?
A. Yeah, his speech was a little slurred, just -- but -- yeah. Nothing terribly, you know, wrong.
Q. Did you ask him if he was using drugs?
A. I mean, yeah, maybe, but I don't remember specifically all that was said. That could have
been one of -- the first one, the first intervention. That was probably the first one.
Q. Do you remember what he said to you?
A. I didn't set that one up. I kind of just jumped in there after I heard about it. So I don't
remember particularly what had happened. But the other ones I had pretty much done, set them
up.
PAGE 267:13 TO 268:22 (RUNNING 00:01:32.185)
Q. At any point in time did you ever feel like Michael was isolating himself from members of his
family?

A. Yeah, he would do that. He would do that.

Q. When did that happen?
A. There's no specific date, but he wouldn't want family to see the way he was probably.
Q. Was this something that would just happen on and off, or can you --
A. It happened a few times.
Q. What about in the five years before his death?
A. What do you mean? How many times?
Q. Was that a period when he was isolated from his family generally or only parts of that
period?
A. Oh, parts. Times. You know, parts of it.
Q. Would you say that you spoke to him regularly in the five years before his death?
A. I don't talk to any of my family regularly. We talk to each other off and on. Yeah. In the five
years prior to it?
Q Yes.
A. No. I mean, we -- you know. No.
Q. Do you know if anyone in your family talked to Michael regularly in the five years prior to
his death?

A. I mean, nothing -- I mean, yeah. I mean, but like brothers and sisters or family does. But
sometimes he would isolate himself and wouldn't want to. I just figured it was probably because
he didn't want people to hear his voice. Maybe for that reason.
Q. Because he might be using drugs?
A. Yeah.
PAGE 313:16 TO 314:24 (RUNNING 00:02:10.941)
Q. Were you in communication with AEG or anyone at AEG Live after Michael's death?
A. Yes, I was.
Q. When was that?
A. Well, after Michael died, everyone was shocked. There was so much going on. I was really
displeased with all the stuff that was going on in court and with the whole Branca and Weitzman
thing. We were still trying to figure out how to grieve, and these people are in court, and wills,
and this nonsense. And I'm, like, I haven't even buried my brother yet, and all this court stuff is
going on. And so I didn't want that to be, like, pushed to the side. So I said I'm going to give him
put together this memorial for him, and I did it at AEG with Kenny Ortega and those guys. I
did it. I was there at their office pretty much every day.
Q. Did you have a positive experience with AEG?
A. Horrible. No, I'm just joking. Yeah, they were -- they were nice. They were very nice. Yeah.
We just -- you know, I practically slept there. I put together the show with them. And my sisters
were doing other things. They were cleaning up some, also, still.

Q. Do you recall telling Randy Phillips that you see that Michael was fortunate to have AEG
involved in his return to the stage?
A. I don't remember saying that, but that doesn't mean I didn't say it. I kind of felt that way at
the time.
Ms. Bina. That concludes the videotaped testimony of Randy Jackson.
Judge. Okay. Thank you. Okay. We're going to adjourn for today, and I want you to return on
Monday at 10:00 a.m.
the following proceedings were held in open court, outside the presence of the jurors:
Judge. Okay. Did you want to talk about anything?
Mr. Putnam. No, your honor.
Ms. Cahan. Your honor, we have a couple of issues. There's one issue with the Dr. Sasaki
video that plaintiffs have raised, and I think the Slavit rulings that we got from you yesterday --
there's one where you had a question mark. I think it would just take a minute to go through.
Mr. Panish. You're doing those on Monday?
Mr. Putnam. One of them.
Mr. Panish. Which one?

Mr. Putnam. We haven't heard back from three people whether they can go Monday, so we're
just preparing in case.
Mr. Panish. Can I be excused? Mr. Boyle can handle that.
Judge. Yes.
Mr. Panish. All right.
Mr. Putnam. Good luck with your drive.
Judge. There's two volumes of Slavit?
Ms. Cahan. Slavit is one volume and Sasaki is one volume.
Mr. Boyle. I can give you Sasaki. I think Sasaki is not going to be very long.
Judge. Which one do you want to do first?
Mr. Boyle. I would say Slavit just because I think there's a couple more of them.
Judge. Okay.
Ms. Cahan. my only -- I was just going to address the one where you had a question mark,
your honor, which is it was as to plaintiffs' counter designation of 124-14 to 127-20. There was a
hearsay objection to -- from 124, line 25, to 125, line 5.
Judge. Okay. "did he tell you that he had been told by representatives of Mr. Jackson that they
would not be able to be produced?" "yes, he told me that no records would be available --" that
sounds like a hearsay statement.

Mr. Boyle. Your honor, we're not designating that for its truth. In fact, we're designating it for
the opposite, which is that it's probably not true. What this is in reference to is Dr. Slavit was
the doctor hired to do the insurance exam, and Bob Taylor was the broker, and so there was an
issue where they were trying to get Michael Jackson's medical records and, you know, they
weren't necessarily -- our position is weren't necessarily giving over all the medical records to the
insurance people.
Judge. To Slavit?
Mr. Boyle. Correct. Anything that would go to Slavit would have to go to, you know -- would
have to go to the insurance analysis.
Ms. Cahan. so these -- these records, just to give a little bit of context, your honor -- these
records were not part of Slavit diagnosing or treating Michael for anything. Dr. Slavit did his
insurance figures, wrote up a report, and then there was a follow-up request after the report for
some medical records, existing medical records of Mr. Jackson dating back three years to be
provided to the -- I guess the insurers were asking for them, so the insurance broker was asking
for them. So this is not a situation of Dr. Slavit needing to have the records and reviewing the
records to render some kind of diagnosis or treatment for Mr. Jackson. So it does distinguish it
from the vast majority of the statements that we're dealing with physicians either speaking with
other physicians or relying on records of other physicians.
Judge. But it seems to me you're offering it for the truth.
Ms. Cahan. and that's how it seemed to us, your honor. That's why we objected.
Judge. "he told me the records would be available for me to review." isn't that what you want to
show, that Slavit would have the records to review?
Mr. Boyle. No. We want to show that Mr. Taylor is lying because Mr. Taylor was involved in
communications with the AEG people about how they were going to get all of Michael Jackson's
records.

Ms. Cahan. your honor, this doesn't show that Mr. Taylor was lying, and as your honor ruled,
Mr. Taylor's deposition, which was not taken in this case but was taken in the other case, is not
admissible in this case. We don't want to create a whole side show about -- maybe plaintiffs do,
but we don't want to create a whole side show about what Mr. Taylor was doing. I don't see this
as an exception to hearsay because, as Mr. Boyle conceded, they're using it not for the truth but
to show it's not true. They're using the underlying statement to be analyzed as to the veracity of
what Mr. Taylor said, which is clearly hearsay.
Judge. I'm going to sustain the objection.
Ms. Cahan. thank you, your honor.
Judge. Do I have a ruling on there?
Mr. Boyle. You had overruled --
Ms. Cahan. you checked overruled with a question mark. And I didn't have anything else that
I wanted to address. I don't know whether Mr. Boyle --
Mr. Boyle. I did. I have a couple of other quick ones, and I don't know if counsel had a
problem. 121 to 123, page 121 to 123, lines 20 --
Ms. Cahan. the objection was just to 121, line 8 to line 19.
Judge. "I could not say anything about his condition in June"? That?
Ms. Cahan. uh-huh.
Judge. This is Dr. Slavit speaking.
Mr. Boyle. Right. Okay.

Judge. Dr. Slavit saying, "I could not say anything with regards to his condition in June, I can
only -- as to his condition in February."
Mr. Boyle. I don't see why that's objectionable.
Judge. What was the objection?
Ms. Cahan. The objection is it's outside the scope and calling for speculation. The next
question is the most problematic part. It follows, "same answer for do you have an opinion
within a reasonable degree of medical probability as to his physical or psychological condition in
may 2009?" he says, "I have no information as to any change within his mental medical
condition or mental condition or capabilities between February and may or June." he said the
only time he ever saw him was in February. The idea that -- there is an insinuation there,
obviously, that his health condition changed substantially. He doesn't have a foundation, he is
speculating, and he says, "I have no idea what he was like in May or June."
Mr. Boyle. No, no. The reason that's going in is because the point is he can't know, and so to
the extent the defense is showing Dr. Slavit saying, "hey, look, Michael was fine," it's like,
"okay. Well, Dr. Slavit, you didn't see how Michael was doing in June. You only knew how
Michael was doing when you saw him in February." that's the whole point. Now, if he would
have given how Michael was doing in June, that's probably speculation and should be out, but he
answered, "I can't tell you that because I don't know." and that's the whole point of why that was
designated, so I think that should be in.
Judge. All right. I'm overruling the defense objection.
Ms. Cahan. Your honor, that does leave an answer without a question, so I think to the extent
that you're inclined to overrule, it should start at 120, line 24, where the preceding question
begins.
Judge. Okay. 120, line 24.
Ms. Cahan. You had sustained the objection to that.

Judge. Yes, I think that's probably right. But I understand now why. Did I have a question
mark by that or you're just raising it?
Mr. Boyle. There was no question mark. We just thought that one maybe was, perhaps, an
error. There's a lot of these to rule on. You're batting 999, which is pretty good.
Judge. Well, sometimes you have to look -- what happens is you look at the specific thing, but
then you have to look at other things from other parts of the depo for context, and you point it
out to me and it makes more sense.
Ms. Cahan. it's a little bit of a puzzle.
Mr. Boyle. And I think there was one similar to that. Line 133, line 17 --
Judge. Page 133?
Mr. Boyle. I'm sorry. Page 133, line 17.
Judge. Okay.
Mr. Boyle. This would be -- now that you've ruled the way you did about the Taylor records, I
think you'll probably -- Michael was -- if your objection was going to say overruled to the
questions to Bob Taylor about records, then I think this would also be overruled. Maybe if you
take a look at it, you'll see what I mean.
Ms. Cahan. So are you arguing --
Mr. Boyle. I think they should both be in, but I see now --
Ms. Cahan. This is the same issue that we discussed previously, and the ruling should be
consistent. And, obviously, our position is that this is also hearsay being offered for the truth.

Mr. Boyle. The reason I raised it is because originally you overruled their objection, but if
you're changing that, then I can see why you would do this.
Judge. Whatever is consistent is --
Ms. Cahan. Which is how you had worked previously, your honor.
Judge. I sustained this one, but it was the other one I had a question on.
Ms. Cahan yes, you sustained this one. No changes to this one.
Mr. Boyle. I understand.
Ms. Cahan. thank you, your honor. And then did you want to talk about Dr. Sasaki?
Mr. Boyle. This will be brief, your honor. This is on the issue of Sasaki. We talked about this
before, the defense designated about Mr. Jackson inviting Michael Jackson to the house. And
you asked if we could work out a little bit about what happened at the house. There is a section
that we would like to play and we can't reach an agreement on whether or not it should play.
Judge. I think what happened was the relevance was on the part of the -- the defense argument
was, well, he had a pattern of inviting doctors to Neverland ranch, kind of befriending them so
that they would be more likely to do what he wanted them to do, I think is -- wasn't that your
argument, why that was relevant?
Ms. Cahan. Yes, our addiction experts opine that crossing the kind of boundary that most
people keep with their physicians, whether it's conscious or unconscious, is something that is
typically seen in people with addiction to prescription medication.
Judge. And your response was --

Mr. Boyle. We said, your honor, we should be able to at least show what happened at
Neverland so the jury can have a full picture about whether this was really drug-seeking behavior
or something else. Your honor made clear, "Mr. Boyle, I'm not going to let you put in the part
where he says what a nice guy Mr. Jackson is." I disagreed with it, but understood, but I said
there is some other language about what happened when he went to Neverland that I wanted to
put in.
Judge. Okay.
Mr. Boyle. It is page 120 -- I take that back.
Judge. Is this a salad for lunch?
Ms. Cahan. No, this is they read the bible together, your honor.
Mr. Panish. 203-21 to 204, line 20.
Judge. Begins "and, in fact"?
Mr. Boyle. Yes, your honor.
Judge. "and, in fact, he invited you and your family to his home, correct?" "yes." "based on
your experience with Mr. Jackson, Mr. Jackson was a religious man?" "I'll say he knew the
scriptures well."
Mr. Boyle. Then it stops at line 20. And so my argument would be that that's what they did at
the house, they read the bible together for ten minutes, and the jury should know that so they can
perhaps draw the conclusion that, "well, maybe Michael wasn't there just trying to get drugs from
the guy, you know."
Judge. He did a lot of things other than that, though, right?

Ms. Cahan:. Yes, your honor. I think there's testimony that they did a variety of activities.
And to be clear, our position is not that Michael Jackson invited Dr. Sasaki into the ranch, pulled
him into a private room and said, "can I have some drugs?" it's that with Dr. Sasaki and others,
Mr. Jackson had a habit of forming friendships with his physicians, and that's something that at a
general high level, our addiction experts are going to be speaking about.
Judge. The problem is -- but it would seem odd, though, that he asked him to come over but
there's no explanation of what happens when he's there, as though something nefarious is going
on.
Mr. Boyle. As if it's bad to be friends with doctors. Some people are married to doctors.
Ms. Cahan. Are you referring to me, Mr. Boyle?
Mr. Boyle. I know some people who are married to doctors. They're making it sound like it's
some nefarious thing, he invited him to the ranch.
Ms. Cahan. I believe your honor already allowed in the testimony where Dr. Sasaki said he
was invited to the ranch with his family and he spent the day there and had lunch there. I do
believe that's in, so I don't know why this page and a half about Mr. Jackson's religious beliefs
and practices that refers to the fact that ten minutes when they were at Neverland, they looked at
the bible is necessary to understand his family's visit to Neverland and spending the day there.
Judge. So there is some explanation of the tour of the ranch and having lunch there in the
designation, because I do think it would be a little strange to just say because of the drug-seeking
behavior, since that's kind of what you're describing, he befriends these people because he wants
them to do what he wants them to do, which is be more likely to give him drugs when he asks.
There should be some explanation of what really happens there. But if that's already been done,
then I don't think we need to go into --
Mr. Boyle. Your honor, or he befriends people because he actually has something in common
with them, and they're friends. And Dr. Sasaki says, "we spent about 10 minutes, 15 minutes,
talking about the bible."

Judge. But he was there for hours.

Mr. Boyle. So is the argument now that talking about the bible is unduly prejudicial?
Judge. It could be. Anything religious related could be. Sure.
Mr. Boyle. So it unduly prejudices the defense, AEG because Michael Jackson knew about the
bible?
Ms. Cahan. Your honor, the testimony that was allowed in that we didn't even object to was at
page 42 and 43. And it says, you know, "we went up there, the staff serves us lunch, shows us
around." "you went with your family to Neverland. When was that?" it's about 1993. There's
context here so it is not right now a mysterious gap as to what happened when he went to
Neverland, and I don't think it really adds anything substantive in a page and a half about his
religious beliefs and practices, I think it is not appropriate here.
Judge. I'm going to sustain the objection.
Mr. Boyle. I want to make sure the record notes that counsel for AEG is taking the position
that the bible is unduly prejudicial.
Mr. Putnam. And I'll note for the record that I do think that it can be absolutely prejudicial
when it's not appropriate or unjustified for what the underlying cause of action is, yes.
Judge. Okay. All right.
Mr. Boyle. That's all, your honor. Thank you.
Ms. Cahan. And I think your honor has designations pending for Dr. Gordon -- that one, the
Dr. Gordon one, is kind of a big project.
Judge. The Gordon one? I started doing the Adams one.

Mr. Putnam. That's not bad.

Ms. Cahan. The Adams one is not bad, the Gordon one is going to be more time consuming.
And there are some more in the pipeline. There are three more that we are expecting from
plaintiffs' counsel this weekend that we intend to file the end of next week, and I think that
should be the end of it.
Ms. Bina. You have -- David Adams and Jeffrey Adams have been both filed.
Judge. So I have two Adams?
Ms. Cahan. yes. It's confusing everyone.
Judge. So there's David Adams -- what's the other Adams?
Ms. Cahan. Jeffrey Adams, who is a security staff person, and then David Adams, who is a
physician. That one, you've had for a bit longer.
Judge. I'm almost done with that one.
Ms. Cahan. your honor, we really appreciate it.
Mr. Putnam. I'm just terrified about telling you we're almost done and then we have another
one.
Ms. Cahan. we wanted to give your honor a sense of where we are in the process because I
know it's been
A. Lot of work for your honor, and we appreciate it.

Judge. At least it's not an asbestos case.

Mr. Boyle. I'm not trying to reargue, your honor. I want to note for the record that AEG, Mr.
Leiweke, testified extensively about a prayer meeting and a bible meeting he had with Mr.
Jackson when they were in the wooing of Mr. Jackson phase, so I just don't see -- I don't see why
it would be unduly prejudicial to put it in from Dr. Sasaki when the AEG guys were doing it,
too. But I understand the court's ruling.
Ms. Cahan. I would disagree with that characterization. I don't believe it's the same situation.
Thank you, your honor.
Judge. All right. Thank you. Did you object to that, Mr. Boyle?
Mr. Boyle. No. I played it for the court -- played it for the jury.
Judge. So nobody objected to it. Maybe I would have sustained an objection to it.
Mr. Putnam. We thought about it at the time, decided not to.
Ms. Cahan: to be clear, your honor, in that context, it was -- Jesse Jackson was at a meeting with
AEG people, and so there was a question why Mr. Jackson would have been -- Mr. Jesse Jackson
would have been at such a meeting, which is why we chose not to object at that time, because of
the context. Thank you, your honor.
(proceedings adjourned to Monday August 12
th
)